&EPA
              United States
              Environmental Protection
              Agency
              Municipal Environmental Research  EPA-600/2-78-108
              Laboratory           May 1978
              Cincinnati OH 45268
              Research and Development
Kepone
Incineration
Test Program

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                RESEARCH REPORTING SERIES

Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology.  Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:

      1.  Environmental  Health  Effects Research
     2.  Environmental  Protection Technology
     3.  Ecological Research
     4.  Environmental  Monitoring
     5.  Socioeconomic Environmental Studies
     6.  Scientific and Technical Assessment Reports (STAR)
     7.  Interagency Energy-Environment Research and Development
     8.  "Special" Reports
     9.  Miscellaneous Reports

This report has  been assigned  to the ENVIRONMENTAL PROTECTION TECH-
NOLOGY series. This series describes research performed to develop and dem-
onstrate  instrumentation, equipment, and methodology to repair or prevent en-
vironmental degradation from point and non-point sources of pollution. This work
provides the new or improved technology required for the control and treatment
of pollution sources to meet environmental quality standards.
This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.

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                                      EPA-600/2-78-108
                                      May 1978
     KEPONE INCINERATION TEST PROGRAM
                    by

               Bruce A. Bell
            Design Partnership
         Richmond, Virginia  23226

             Frank C. Whitmore
                Versar Inc.
       Springfield, Virginia  22151
            Grant No. R-805112
              Project Officer

             Richard A. Carnes
Solid and Hazardous Waste Research Division
Municipal Environmental Research Laboratory
          Cincinnati, Ohio  45268
         This study was conducted
            in cooperation with
         Commonwealth of Virginia
           Department of Health
         Richmond, Virginia  23219
MUNICIPAL ENVIRONMENTAL RESEARCH LABORATORY
    OFFICE OF RESEARCH AND DEVELOPMENT
   U.S. ENVIRONMENTAL PROTECTION AGENCY
          CINCINNATI, OHIO  45268

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                                 DISCLAIMER
     This report has been reveiwed by the Municipal Environmental Research
Laboratory, U.S. Environmental Protection Agency, and approved for publica-
tion.  Approval does not signify that the contents necessarily reflect the
views and policies of the U.S. Environmental Protection Agency, nor does
mention of trade names or commercial products constitute endorsement or
recommendation for use.

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                                 FOREWORD
     The Environmental Protection Agency was created because of increasing
public and government concern about the dangers of pollution to the health
and welfare of the American people.  Noxious air, foul water, and spoiled
land are tragic testimony to the deterioration of our natural environment.
The complexity of that environment and the interplay between its components
require a concentrated and integrated attack on the problem.

     Research and development is that necessary first step in problem solu-
tion, and it involves defining the problem, measuring its impact, and
searching for solutions.  The Municipal Environmental Research Laboratory
develops new and improved technology and systems to prevent, treat, and
manage wastewater and solid and hazardous waste pollutant discharges from
municipal and community sources, to preserve and treat public drinking water
supplies, and to minimize the adverse economic, social, health, and aesthetic
effects of pollution.  This publication is one of the products of that re-
search, a most vital communications link between the researcher and the user
community.

     The aftermath of the release of large quantities of Kepone to the envir-
onment in Hopewell, Virginia, has resulted in the collection of Kepone and
Kepone-contaminated materials for which a safe, economical, and environ-
mentally acceptable method of destruction is required.  The study reported
here presents the results of a pilot-scale study of incineration of Kepone.
                                      Francis T. Mayo, Director
                                      Municipal Environmental Research
                                         Laboratory
                                     iii

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                                   SUMMARY
     One result of Kepone production operations by the Life Sciences Corpora-
tion in Hopewell, Virginia, has been an accumulation of large amounts of
Kepone and Kepone-contaminated materials that must be disposed of.  Work by  '
Design Partnership of Richmond, Virginia, under contract to the Commonwealth
of Virginia, has indicated that thermal destruction is the safest and most
convenient way to dispose of these materials.  In addition, Rubey and Duvall (1)
have shown that Kepone is thermally destroyed at temperatures on the order of
350° to 400°C but that several thermal degradation products are stable to
temperatures of 900°C.

     The Kepone Incineration Test  (KIT) program was undertaken to evaluate
incineration as a method of destroying Kepone and Kepone-containing materials
and to determine the range of operating variables required for complete de-
struction.  The program, undertaken at the Surface Combustion Division of
Midland-Ross Corporation in Toledo., Ohio, was divided into two phases:
(a) experiments involving the direct injection of low BTU solutions of Kepone
into the afterburner, and (b) experiments involving the co-incineration of
sewage sludge and various amounts of Kepone injected into a rotary kiln.
Each phase was designed so that succeeding experiments involved larger amounts
of Kepone and/or alterations in afterburner temperature and residence time.

     The management structure of the KIT program worked well and contributed
much to completion of the program.  A committee of representatives from the
federal, state, and local agencies whose responsibilities include air and
water quality was organized and designated the Burn Authority.  This group,
which had at least one member on the site at all times during the tests, had
final authority to allow the experiments to continue, to cease, or to be
modified in order to meet the pre-assigned standard that under no circum-
stances would Kepone emission of 1 microgram per cubic meter be reached.
The Burn Authority was aided by the Experimental Management Group, which was
made up of one senior member from each participating contractor.  This latter
group had the additional responsibility of conducting the experiments and re-
porting the results to the Burn Authority.  The Health and Safety Group saw
that the facility was properly prepared to isolate the contaminated areas and
was responsible both for training all personnel in the use of safety equip-
ment and for monitoring the use of safety equipment. \ The Public Information
Group had the responsibility for keeping the press and the interested public
completely informed as to the program.

     The experimental procedures are outlined in Section 5 of this report and
fully treated in Appendix D.  The Burn Authority and the Experimental Manage-
ment Group altered procedures when it became apparent that the high-level in-
                                      iv

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jection experiments could result in emissions approaching the preset allow-
able limit.

     The pertinent experimental results obtained in the KIT program follow.
                  RESULT OF KEPONE INCINERATION EXPERIMENTS
Experiments
Kepone feed
   rate
Total      »            Stack
feed  Total Kepone    emission
time       fed     concentration
               (g/min)    (min)
                        (g)
                       (g/m3)
           After-
Total stack burner
  output    temp.

   (g)      (°C)
Injection
runs
1
2
3
4
5
Sludge
runs
6+
7
8
- 9
10
11
Totals
Acetic acid
only
1.67 x 10-5
1.67 x 10~5
1.67 x 10~2
1.50

Background
Toledo sludge
only
5.68
, 5.68
5.68
24.2
—
130
135
100
115


120
120
315
240
220
165
—
2.16 x 10~3 ND
2.25 x 10- 3 ND
1.67
172.5


—
— '
1789
1354
1241
3995
8553
ND*
5.35 x ID'8


2.96 x 10~7
ND
1.7 x 10~8
2.4 x 10-8
2.55 x 10-8
2.95 x 10~8
—
1260
ND 1260
ND 1093
ND* 1093
1.76 x 10-4 1093


7.1 x 10~4 1093
ND 1093
1.85 x 10~4 1149
1.85 x 10~4 1093
1.53 x 10~4 1038
1.67 x 10~4 10931
1.58 x 10-3 —

 *   There was an apparent Kepone peak on the extract from the filter—a peak
    that disappeared on base partitioning of the extract.

 +   Experiment 6 was run with a contaminated scrubber  (25 ppb) in an attempt
    to determine the cause of the high emission in the previous experiment.


 For each experiment the efficiency of destruction exceeded 99.9999 percent.
 Health and safety procedures were adequate in that no individual was exposed
 to detectable levels of Kepone, as indicated by before and after blood tests,
 and no escape of Kepone into the ambient air was detected by air samplers on
 the premises.

     The recommendations that derive from these experiments may be summarized
 as follows:

     (1)  The incinerator system should consist of a fume incinerator capable
          of sustained operation at about 1000°C and with sufficient volume
                                      v

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     to allow residence times of about 2 seconds, a pyrolyzer capable
     of substained operation at about 450°C to vaporize and (probably)
     to decompose the Kepone partially, a strongly basic (pH above 9.0)
     scrubber system, and a suitable pollution control system.   The
     entire system must be designed to operate at a significantly nega-
     tive pressure and should be fitted with sensors that detect and
     warn when these conditions are not met.

(2)   Provision should be made to Jeed solid materials directly into
     sludge because the use of acetic acid seems to introduce complica-
     tions for large-scale operations.  The direct feed of low-BTU
     solutions into the. incinerator without the mediation of the pyro-
     lyzer should be possible even though the particular combination of
     conditions at the experimental site seems to indicate that this is
     not a useful approach.

(3)   The facility should have a full-time safety engineering group on
     its staff.  The experience at Midland-Ross suggests that even
     though the personnel have been carefully trained in the need for
     and the proper use of protective equipment, they need to be re-
     minded to use such equipment properly.  In addition, the acetic
     acid spill that occurred during the KIT program points out the need
     for prompt action in the event of an accident—action that can be
     properly initiated only by a professional safety engineer.

(4)   The incineration system used for the large-scale destruction of
     Kepone and Kepone-bearing materials should be separated into areas
     that could be heavily contaminated and those areas that could not.
     The introduction of protective gear could thus be controlled to
     minimize both the equipment needed and the time and efficiency
     penalties exacted by its use.

(5)   The facility should provide for the retention of all liquid and
     solid effluent streams until analysis shows they are not contamina-
     ted.  In this context, there should be a well designed sampling
     arrangement built into the plant and a suitably designed sampling
     program.  This sampling program should be fully supported by on-
     site analytical capability suitable for trace analysis.

(6)   For successful operation, a public information program should be
     an integral part of the provisions for final disposal.

(7)   The KIT program did not include the determination of parameters
     for materials used, the precise geometry of a suitable incinerator
     system, or even the possible performance penalties exacted by the
     use of safety equipment.  Such matters were left for later design
     studies and should be evaluated.
                                VI

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                             CONTENTS


Foreword	ill
Summary	iv
Figures.,	viii
Tables	ix
Acknowledgment	x

     1.   Introduction	1

     2.   Conclusions	5

     3.   Recommendations	6

     4.   Facilities	8

     5.   Experimental Program and Results	21

References	50

Appendices

     A.   Kepone fact sheet	51
     B.   Wipe test protocol and results	54
     C.   Laboratory equipment and supplies on site	63
     D.   Experimental procedures	64
     E.   Furnace and incinerator system data	82
     F.   Typical chromatograms	122
     G.   Log of events	130
     H.   ERA(RTP) confirmatory analysis results and
             blood test  results	134
                              vii

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                                 FIGURES
Number
                                                                  Page
   1  Program Management Structure	     2

   2  Kepone Incineration System Schematic	     8

   3  Experimental Area - Isolation Plan	    10

   4  Injection Feed Head	    13

   5  Pneumatic Diagram of Kepone Injection System	    14

   6  Electrical Network, Feed System Control	    15

   7  Mix Room	    16

   8  Calculated Scrubber Load of Kepone as a Function of
         Time  11.2 gm/rain. Kepone Feed; AB Temp. 1149°C
         (2100°F) 	    34

   9  Calculated Scrubber Load of Kepone as a Function of
         Time  5.64 gm./min. Kepone Feed; AB Temp. 1093°C
         (2000°F)	    35

  10  Calculated Scrubber Load of Kepone as a Function of
         Time  5.64 gm./min. Kepone Feed; AB Temp. 1038°C
         (1900°F) 	    36

  11  Calculated Scrubber Load of Kepone as a Function of
         Time  24.2 gm./min. Kepone Feed; AB Temp. 1093°C
         (2000°F) 	    37

  12  Kiln Exit Temperature as a Function of Time 11.2
         gm. /min. ; AB 1149°C Coincineration	    41

  13  Kiln Exit Temperature as a Function of Time Feed
         5.6 gm./min.; AB 1093°C Coincineration	    42

  14  Kiln Exit Temperature as a Function of Time Feed
         5.6 gm./min.; AB 1038°C Coincineration	    43

  15  Kiln Exit Temperature as a Function of Time Feed
         24.2 gm./min.;  AB 1093°C Coincineration	    44


                                 viii

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                                   TABLES


Number                                                             Page

  1-1  Results of Kepone Incineration Experiments	     v

   1   Summary of Kepone Incineration Experiments	    24
                 *
   2   Summary of Stack Sampling Data	    25

   3   Summary of Stack Velocity Data	    26

   4   Stack Kepone Concentration Data for Injection
         Experiments	    27

   5   Stack Kepone Concentration Data for Coincineration
         Experiments	    28

   6   Scrubber Sample Data	i	    30

   7   Combustion Efficiency for Kepone Injection	    31

   8   Coincineration Efficiency for Kepone with Sewage
         Sludge	    32

   9   Tabulation of Kepone Input and Loss Rates (Scrubber)	    38

  10   Incinerator Efficiency as Derived from Scrubber Data	    40
                                   IX

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                               ACKNOWLEDGMENT
     The Kepone Incineration Program could not have been successfully carried
to completion without the full and complete cooperation of the members of the
Burn Authority and the agencies they represent:

          E.H. Bartsch, Director, Bureau of Sanitary Engineering,
               Department of Health, Virginia
          R.A. Carnes, Environmental Scientist, Solid and Hazardous
               Waste Research Division, MERL, USEPA
          D. Krygielski, Engineer, Toledo Pollution Control Agency
          K.J. Klepitsch, Jr., Chief, Solid Waste Branch, USEPA,
               Region V
          Julius Foris, Chief, Division of Technical Support Operations,
               Office of Air Pollution Control, Ohio EPA

     We would like to express our appreciation to Richard A. Carnes, USEPA
Project Officer, for his assistance and cooperation throughout this project.
In addition, special thanks are extended to the public officials and the
people of the City of Toledo for their patience and understanding:  most
particularly Paul Finlay, Director, Toledo Pollution Control Agency.
                                      x

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                                  SECTION 1

                                INTRODUCTION

     The serious environmental contamination produced by the Kepone manufac-
turing operations of Life Sciences Corp., of Hopewell, Virginia, has resulted
in the necessity for the disposal of large quantities of Kepone and Kepone
contaminated water, soil, sewage sludge, and a variety of other materials.
A strong concensus of opinion, supported by a study conducted by Design
Partnership of Richmond, Virginia, has developed that the safest, most econ-
omical and most convenient method of disposal of these materials is by
thermal destruction.  This decision is strongly supported by the laboratory
studies of Duvall and Rubey(l) which have shown that Kepone is thermally
unstable at temperatures above 350°C and that even the most thermally stable
of its breakdown or thermal rearrangement products (hexachlorobenzene) is
unstable at temperatures on the order of 900°C.

     The general difficulties inherent in the extrapolation of laboratory
scale data to large scale operations made it imperative that an intermediate
(pilot) scale test series be carried out.  This pilot scale series would
serve the dual purpose of extending and confirming the Rubey and Duvall^l)
findings, while at the same time define the necessary range of operating
parameters for the safe and complete destruction of Kepone and its products.
The desirable physical arrangement of equipment for these pilot scale tests
would consist of a rotary kiln for volatilization in conjunction with an
afterburner capable of operating at temperatures of the order of 1100°C with
residence times of the order of several seconds.  In addition, the installa-
tion should possess adequate air pollution control equipment.  A search re-
vealed that such an installation was not available within the Commonwealth,
but that the facility at Midland-Ross, Surface Combustion Division in Toledo,
Ohio was available.

     In the course of negotiations with Surface Combustion, it became obvious
that the wide publicity that had been accorded the disastrous effects that
resulted from the exposure of the employees of the Life Sciences Co. had
generated a situation which made it very difficult for the officials of the
City of Toledo and the State of Ohio to grant the necessary permission for
the tests to take place.  The result of this concern was an extended series
of meetingswith representatives of the responsible governmental bodies.  From
these meetings a detailed plan of operations was evolved that all parties
agreed would allow the necessary tests to be carried out under conditions
that would guarantee the safety of the surrounding community as well as that
of the operating personnel.  Specifically, the result of these deliberations
was the generation of a unique management structure which provided the re-
sponsible governmental officials with a strong measure of control of the day-
to-day operations.  In addition, a very detailed protocol for the

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experimental program was constructed.

PROGRAM MANAGEMENT

     After much discussion, the program management structure as outlined in
Figure 1 was evolved as offering the strongest possible control over the
program by both the responsible governmental bodies and by the technical
staff that would be assigned to the program.  Briefly, the plan was for the
detailed experiments to be carried out under the direction of the Experimen-
tal Management Group under stringent safety procedures established by and
monitored by the Health and Safety Group.  The results of each experiment
were then presented to the Burn Authority along with any necessary additonal
information.  The latter group was then empowered to make the decision as to
whether the program should proceed on the basis of the protocol, or should be
modified.  The results of each experiment and the resulting Burn Authority
decision were then to be transmitted to the interested public through the
medium of the Public Information Group.

The Burn Authority

     The Burn Authority consisted of the following individuals:

          E.H. Bartsch, Director, Bureau of Sanitary Engineering,
               Department of Health, Virginia
          R.A. Carnes, Environmental Scientist, Solid and Hazardous
               Waste Research Division, MERL, USEPA
          D. Krygielski, Engineer, Toledo Pollution Control Agency
          K.J. Klepitsch, Jr., Chief, Solid Waste Branch, USEPA,
               Region V
          J. Foris, Chief, Division Technical Services, Ohio EPA

     In order that the Burn Authority could properly fulfill its responsi-
bilities with respect to the Kepone incineration test (KIT) program while
at the same .time to allow the members to meet their individual agency
responsibilities, it was arranged that at least one member of the Authority
would be in residence at all times.  In addition, daily telephone communi-
cation between members of the Authority would be maintained.  In those
situations which might suggest that a significant alteration of the protocol
was required, the entire Burn Authority was to be assembled.

Health and Safety Group

     The responsibility of the Health and Safety Group began with assistance
in the design of the facilities at Surface Combustion so as to provide maxi-
mum isolation of the facility.  Further, this group was to provide for the
personnel safety requirements during operations and the daily monitoring of
personnel and facility to assure that proper hygiene was maintained and that
the required protective measures were, in fact, employed.  A further dis-
cussion of the health and safety measures that were undertaken and enforced
is presented in Section 4   of this report.  The effectiveness of these
measures is treated in Section 5   and in Appendix B.

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u>
HEALTH
 AND
SAFETY
                                    BURN
                                  AUTHORITY
                                EXPERIMENTAL
                                 MANAGEMENT
                                 EXPERIMENTS
                                                   PUBLIC
                                                    INFO-
          FIGURE  I     PROGRAM  MANAGEMENT  STRUCTURE

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Public Information

     The activities of the Public Information Group were primarily directed
to explaining to the interested press and the public the facts of the pro-
gram so as to allay any fears of even a small chance for contamination
resulting from these experiments.  During the actual experimental program,
the Public Information Group took the responsibility of releasing a daily
bulletin which outlined the results of that day's experiment and indicated
the nature of the next step in the program.  The nature of the general infor-
mation that was made public may be seen by examination of the "Kepone Fact
Sheet" that is included as Appendix A to this report.

Experimental ?-!anagement Group

     The responsibilities of the Experimental Management Group, which was
made up of a senior individual from each of the three contractors that par-
ticipated in the program, was charged with the detailed conduct of the exper-
imental program and with the responsibility of keeping the Burn Authority
completely informed of the daily progress.  Further, this body was required
to assist the Burn Authority in its deliberations as to the significance of
the results of each specific experiment and as to the propriety of continuing
as scheduled.

GENERAL OBSERVATIONS ON THE OPERATION OF THIS STRUCTURE

     In spite of the obvious complexity of the management structure outlined
above, the result was, in practice, highly successful.  The dedication of
the members of the Burn Authority in their responsibilities to the public and
their sympathy for the goals of the program, were in no small way responsible
for the successful outcome.  The only point at which the management structure
was not particularly successful was in the area of the Experimental Manage-
ment Group.  The precise reasons for this problem are not clear, but it would
seem that a troika of technical managers is not the most appropriate way to
manage an experimental program; there should have been one individual
charged with the responsibility subject to inputs from the individual field
managers, and whose final decisions are subject to review by the Burn
Authority.

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                                  SECTION 2

                                 CONCLUSIONS

     The results and conclusions derived from the KIT program may be summar-
ized as follows:

     (1)  Coincineration of Kepone with sewage sludge is a safe and environ-
          mentally acceptable method of disposal of Kepone.  The results of
          these experiments indicate that the destruction efficiency of
          Kepone is in excess of 99.9999 percent in a system consisting of a
          pyrolyzer, fume incinerator operating in the order of 1000°C with
          residence times in the order of two (2) seconds and a caustic
          quench/scrubber system.  In no case was a detectable/Kepone level
          found in the pyrolyzer ash.

     (2)  Periodic deviations from negative pressure in the kiln permitted
          the escape of small quantities of Kepone to the air in the kiln
          room.

     (3)  Direct injection of low BTU solutions of Kepone would appear from
          these experiments not to be a useful process.  This conclusion is
          not as firmly based as one would hope as is discussed in Section
            5.  Although acetic acid appears to be the best and safest
          available choice as a Kepone solvent, the addition of acetic
          acid to sludge resulted in foaming problems.

     (4)  Adequate safety instruction coupled with constant monitoring to
          assure the proper use of safety equipment is necessary to prevent
          the exposure of operatingopersonnel.

     (5)  The planning of the facility and its isolation structures were such
          as to prevent the escape of Kepone into the surroundings while at
          the same time making it very easy to clean up the facility after
          the completion of the tests.

     (6)  Real time analyses of Kepone on the site of such a procedure is
          highly satisfactory and of great assistance in the decision making
          process.

     (7)  The concept of a Burn Authority made up of representatives of the
          responsible agencies is highly satisfactory in the control of an
          experiment such as the KIT program.

     (8)  Only a completely informed public can be cooperative at least in
          terms of an experiment such as the KIT program.

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                                  SECTION 3

                               RECOMMENDATIONS

     As a result of the KIT program several recommendations may be made that
will be applicable to the operations of a full scale installation for the de-
struction of Kepone and Kepone containing materials.

     (1)  The incinerator system should consist of a fume incinerator that is
          capable of sustained operation at temperatures of the order of
          1000°C and with sufficient volume as to allow residence times of
          the order of two seconds; a pyrolyzer capable of sustained opera-
          tion at temperatures of the order of 450°C which serves to vapor-
          ize (and probably to partially decompose) the Kepone; a strongly
          basic (pH above 9.0) scrubber system and a suitable air pollution
          control system.  The entire system must be designed to operate at
          a significantly negative pressure and should be fitted with sensors
          that detect and warn when these conditions are not met.

     (2)  Provision should be made to allow feed of solid materials directly
          into sludge since the use of acetic acid, which for experimental
          purposes was an excellent choice, seems to introduce additional
          complications for large scale operations.  The direct feed of low
          BTU solutions into the incinerator without the mediation of the
          pyrolyzer should be possible even though the particular combin-
          ation of conditions at the experimental site seems to indicate
          that this is not a useful approach.

     (3)  The facility should have a full-time safety engineering group on
          its staff.  The experience at Midland-Ross suggests that even
          though the personnel have been carefully trained in the need for
          and the proper use of protective equipment, they are in constant
          need to be reminded to use such equipment properly.  In addition,
          the acetic acid spill that occurred during the KIT program points
          out the need for prompt action in the event of an accident - action
          that can only be properly initiated by a professional safety
          engineer.

     (4)  The incineration system that is used for the large scale destruc-
          tion of Kepone and Kepone bearing materials should be separated
          into areas that are potentially heavily contaminated and those
          areas that are not subject to potential contamination.  By this
          type of separation, the introduction of protective gear can be
          controlled so as to minimize the equipment needed.  By such a pro-
          cedure, it should be possible to minimize the time and efficiency
          penalties that are exacted by the use of protective equipment.

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(5)   The facility should provide for the retention of all liquid and
     solid effluent streams until analysis shows that they are not con-
     taminated.   In this context there should be a well designed
     sampling arrangement built into the plant which should be accom-
     panied by a suitably designed sampling program.  This sampling pro-
     gram should be supported by on-site analytical capability suitable
     for trace analysis of all samples derived from the system.

(6)   A fully informed public is a requirement for the successful oper-
     ation of a program of this type.   Therefore, a public information
     program should be an integral part of the final Kepone disposal
     program.

(7)   The KIT program was designed to determine the feasibility of incin-
     eration for the disposal of Kepone and the range of conditions that
     are required to affect this disposal in a safe manner.   There was
     no serious attempt to determine the proper range of such parameters
     as materials that should be used, the precise geometry for a
     suitable incinerator system or even the performance penalties that
     would be exacted by the use of personnel safety equipment.   Such
     matters were deemed to be appropriate subjects for the design
     studies that would follow the demonstration that Kepone could be
     thermally destroyed in a safe manner under thermal conditions that
     were reasonable.

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                                  SECTION 4

                                 FACILITIES

     It Is appropriate to discuss the facilities that were involved in this
program in several categories: (a) the Surface Combustion incineration fac-
ility; (b) the temporary installations that were added to the Surface Com-
bustion facility to provide isolation of the facility and to provide for
personnel safety and hygiene; (c) the facilities that were provided for the
handling of Kepone and Kepone solutions; and (d) the facilities that were
provided for sampling and for real time analysis of the sampled material.

SURFACE COMBUSTION EXPERIMENTAL INCINERATOR

     A schematic of the layout of the experimental incinerator at Surface
Combustion is shown in Figure 2.  The individual components and their char-
acteristics are discussed in the following section.

Rotary Kiln Pyrolyzer

     The rotary kiln pyrolyzer was 1.52 m in diameter and 3.0 m in length
fitted with rotary seal charge and discharge connections so as to minimize
the leakage of gases into or out of the kiln.  It was heated directly by the
hot gases from a 0.923 J/sec burner to maintain a nominal temperature of
500°C.  Normally this kiln was batch fed through cover doors on the side, but
for the purposes of the coincineration experiments the sludge feed was
accomplished through a water cooled feed line which entered the kiln through
the discharge pipe.  The maximum feed rate was a nominal 45 kg/hr (100 lb/
hr).  Cake build-up within the kiln was prevented by ten rows of link
chain within the kiln.

Fume Incinerator - Afterburner

     The fume incinerator, with a residence chamber volume of 2.4m-^, was
fired by two 0.147 J/sec capacity throat mix burners and an auxiliary gas
supply.  The incinerator was equipped with a temperature controller and a
high limit safety shutoff instrument.  In this configuration, the maximum
temperature that could be sustained was 1260°C with residence times of the
order of several seconds.

Quench

     The hot gases from the incinerator were cooled by evaporative cooling
of the quench water that was injected at the bottom of the incinerator.  The
quench system, as well as the emergency cooling spray system, used water de-
rived from the brine tank to compensate for evaporative losses with the

                                      8

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                                                            STACK
                           KEPONE
                           INJECTION
                           (INJECTION RUNS ONLY)
                    STACK
                    SAMPLE
SLUDGE
FROM
FEED
SYSTEM
(SLUDGE
RUNS
ONLY)
                 KILN
AFTERBURNER
SCRUBBER
                                                     SCRUBBER  SLOWDOWN
                                                     TO  CONTAMINATED
                                                     STORAGE
              FIGURE 2  KEPONE  INCINERATION SYSTEM SCHEMATIC

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Scrubber

     The scrubber, a 76 cm diameter tower, was packed to a depth of 1.83 m
with 5 mm Intalox plastic saddle packing.  A liquid distributor at the top
of the packed bed caused the liquid to be evenly distributed across the
packed bed.  The mist eliminator consisted of a 15 cm bed of saddles placed
above the liquid distributor.  The motive force for gas flow through the en-
tire system was an induced draft fan with capacity of 0.94 m^/sec. mounted
at the top of the scrubber.  A recirculation tank at the bottom of the scrub-
ber was interconnected with the quench tank so that they together served as a
single reservoir for recirculating fluids.  The pH of the recirculating water
was periodically measured and subsequently adjusted to lie between 9 and 10
by the addition of a 12 percent caustic solution from a separate caustic
solution reservoir.

Sludge Feed System

     Kepone contaminated sludge was simulated by the mechanical mixing of
appropriate amounts of Kepone solution in acetic acid into Toledo sludge in
the feed tank.  The latter was a cylindrical vessel, 86 cm in diameter and
60 cm high fitted with a pneumatic stirrer.  The 10 cm outlet port in the
conical bottom of the feed tank was fitted with a screen and connected to a
two stage, size 3 variable speed Moyno pump.  The discharge line was fitted
with a pressure relief valve and with provision to either inject sludge from
the feed tank or water from the mains.  The feed line, which entered the kiln
within the kiln discharge line, was water jacketed to prevent caking within
the feed line.  At the end of a run, the feed line was flushed with water.

Stack

     During the initial injection experiments, there seemed to be a serious
problem with excess water in the stack, so that a new alloy stack was in-
stalled.  There was also added a stack reheater which effectively reduced
stack condensation.

HEALTH AND SAFETY FACILITIES

     The contributions of the Health and Safety Group to the facilities
consisted largely in the design of the protective enclosure that isolated
the facility and that provided for the protection of the operating person-
nel.  The general features of the facility that was provided are shown in
Figure 3.

Operations and Control Area

     The Operations and Control Area, which included the incinerator, the
scrubber, the furnace operational equipment and the brine and caustic
storage tanks, was enclosed by a wooded framework lined on the inside with
heavy plastic material.  This area was accessible only to specifically
authorized personnel through the normally locked doors and was considered
to be minimally contaminated.  Personnel that worked within this area were
required to wear disposable coveralls, rubber boots and rubber gloves.  On


                                      10

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            OBSERVATION
             WINDOWS
AMBIENT
                          ^CONTAMINATED V!
                          V////7///////
                OPERATIONS
                  AND
                 CONTROL

                 MINIMAL
              CONTAMINATION
                                   yCJ
                                                          SHOWER
                                                          LOCKER
                                                           CLEAN
                                                                   y
                                      ENTRANCE ONLY
                                               B SERVAT 1 ON
                                               WINDOWS
                                                 FIBERGLASS FILTERS
                                                 FOR AIR  MOVEMENT
                AMBIENT
                                          ENTRANCE  ONLY
CLEAN

CONTAMINATED

MINIMAL CONTAMINATION
                                                          OFFICE
                                                           AND
                                                          STORAGE
               LABORATORY
                FIGURE 3'-   EXPERIMENTAL AREA-
         y
ISOLATION  PLAN
                                                                       y

-------
leaving, it was necessary to remove the protective clothing and wash face and
hands at the sink that was provided at the egress.

Kiln and Mixing Areas

     Since it was anticipated that Kepone and Kepone solutions would be
exposed within this area, this was designated as a hazardous area.  Per-
sonnel that worked in these areas were required to wear full protective
equipment including respirator.  Further, when the operator was handling
glacial acetic acid, he was required, in addition, to wear a face mask.  The
only entrance to this area was through the Change/Shower area; the doors
shown to the outside (Figure 3) from the mixing room were emergency doors.

Change/Shower Area

     The Change/Shower Area was provided to afford proper isolation of the
facility by maintaining contaminated clothing within the change area and by
making persons exiting from the Mixing/Kiln Area shower before dressing in
street clothes.  In addition, all personnel that had been in the Operations
Room were required to shower at the end of the day.

     All waste waters from the facility, including from the shower, were im-
pounded in underground tanks fro the duration of the program.  Only after
these impounded waters were shown to have undetectable Kepone levels could
they be released into the normal sewage system.  In the event that there were
detectable traces of Kepone, these waters were to be placed in drums for
return to Hopewell.

General Features

     The walls and the floors of the facility were specially prepared so as
to allow a rapid and safe cleanup at the completion of the program.  After
wipe tests were shown to indicate no residual Kepone contamination, the
plastic wall coverings were removed and destroyed.  In addition, during the
course of the program, frequent wipe tests were conducted to assure the ab-
sence of Kepone contamination within the various areas if the facility.  The
protocol for these wipe tests is discussed in Appendix B.  There is also a
summary of the results of the wipe tests included in Appendix B.

FEED SYSTEMS

     The experiments that made up the KIT Program were of two general forms,
direct injection of glacial acetic acid solutions of Kepone into the incin-
erator and coincineration of Kepone 'doped1 Toledo sludge injected into the
kiln.  The feed equipment used for each is discussed below.

Direct Injection System

     The direct injection experiments were designed to study the feasibility
of direct injection of Kepone containing low BTU fluids into the incinerator
without the necessity of the intermediate route through the kiln.  The
equipment that was designed for this purpose consisted of a set of two (2)


                                      12

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injection nozzles and the facility necessary to mix, store and feed  solutions
of Kepone in glacial acetic acid.

     It was decided that the injection nozzles should be placed  as near  to
the input port of the incinerator as was physically possible  in  order  to ob-
viate the possibility of deposition of Kepone on  the cool walls  of the duct
from the kiln to the incinerator.  The thermal conditions that were  thought
to exist at the point within the duct at which the injection  heads were  to
be introduced suggested that the small openings in a conventional spray  in-
jection head would soon be  clogged.  For this reason a  less conventional de-
sign, shown in Figure 4, was adopted for these heads.   The Kepone solution
was fed through a 5mm diameter  stainless tube to  the head.  The  thermal
conditions that were computed to exist within the head  were such that  vapori-
zation should have occurred within the enlarged portion of the head.   The
heads, spaced some 30 cm apart, were directed upstream  so as  to  increase the
exposure time to assure the elimination of  droplets.

     The feed system that was used for the  mixing, storage and feed  of the
glacial acetic acid solutions of Kepone is  shown  in  the schematic diagram
Figure 5 with the electrical control system diagram  shown in  Figure  6.  It
will be noted from Figure 5 that the motive force that  was used  for  the
transfer of solutions throughout the system was dry  nitrogen  gas. The elec-
trical system is somewhat complex, a complexity necessitated  by  the  require-
ment of interlocking the various operations so as to obviate  a possible  mis-
management of the highly corrosive acetic acid.   The corrosive nature  of the
solvent also required that  all  the fittings in the feed system be either of
aluminum,  teflon or stainless  steel.   The physical layout of  the feed  system
and  its associated electrical  control  system are  shown  in Figure 7 which also
shows  the  nature of the portective equipment that was required within  the
mixing room.

Sludge Feed System

     As is indicated in Section 4 it was decided  that the sludge exper-
iments would best be conducted  by  'doping'  Toledo sludge with Kepone so  as
to generate a series of concentrations with a fixed  sludge feed  rate (45kg/hr)
which was  dictated by the kiln  characteristics.   It was further  decided  that
personnel  protection during the mixing and  feed operations could best  be
obtained by mixing solutions of Kepone in glacial acetic acid into the sludge
rather than by adding the dry Kepone to the sludge.  There is no basis for
concluding that a dry mixing system could not be  used in a facility  better
equipped.  The only significant problem that developed  during these  mixing
operations was connected with the rather vigorous reaction of the acetic acid
with the sludge, a reaction that caused some foaming to occur.

SAMPLING AND ANALYTICAL PROCEDURES

Sampling Methods

     The stack gas stream was sampled at the output of  the scrubber  using
the EPA Standard Method 5 (2) with an RAG Stacksampler  (R) along two perpendi-
cular traverses at four sampling points per traverse.   The heated probe  was
introduced through each 7.8 cm  diameter port in turn and maintained  at each


                                      13

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               SECTION A
RIGHT END VIEW
        L- 3.0  _
2.O

WELD


..
r-

WELD
_
IM
^
3.0

.WELD



1.5
-^
*r

>.
^WELO ^^
.50
                                                             3.0O
                                 -WELD
                                 -WELD
                                                                       .266 DIA.EIGHT HOLES EQUALLY
                                                                       SPACED ON 9.000 01A 8C
                   I.OO DIA TUBE WELDED IN 1.02
                   OIA HOLE — SEE NOTE I
                                                                       .38 DIA TUBE -SEE NOTE I
NOTES:
I. MATERIAL OF 1.00 DIA. TUBE AND
 .38 DIA. TUBE -TYPE 304 STEEL
2. TOLERANCES:
     3 DEC PLACE  TOL * .005
     2 DEC PLACE  TOL - .010
      I DEC PLACE  TOL - .10
              FIGURE  4   INJECTION   FEED   HEAD

-------
• TO KILN
                                                                               CHARCOAL
               FIGURE   5   PNEUMATIC   DIAGRAM   OF
                 KEPONE    INJECTION   SYSTEM

-------
FIGURE  6  ELECTRICAL NETWORK, FEED SYSTEM  CONTROL

-------

-------
sampling point for approximately five (5) minutes.  The collected sample
was passed through a 0.45 micron filter prior to its introduction into the
impinger train.  The first two impinger tubes of the sample train contained
100 ml of spectrograde isoctane.  The entire assembly of impingers was
maintained at near OoC by use of ice and salt.

     Isokinetic sampling was accomplished by first calibrating the S pitot
tube against a calibrated Dwyer pitot tube using a slant gauge manometer.
Minor adjustments were continuously made in the pumping speed as needed to
compensate for variations in air stream velocity during a  sampling run or
when the probe was moved to a new sampling point.

     On  completion of a sampling run, the filter-cyclone  assembly was
removed from the heated probe box, transferred to a container and removed to
the laboratory where the sample was recovered.  An identical procedure was
followed *-ith th  first ind -ecund imp'ng r t be   th  entire assembly was
removed from the sampling box, transferred to a carrying box and removed to
the laboratory.  This procedure was adopted to decrease the possibility of
contamination but was also found to markedly increase the  efficiency of
handling the collected samples.

     At the end of each stack sampling run, a one  (1) liter sample of the
scrubber water was taken.  During the high level coincineration runs, further
scrubber samples were taken so as to derive a profile of the changes in
scrubber concentration as a function of time.  Ash samples were taken at the
end of each coincineration run.

Analytical Methods

     The laboratory that was set up on site and the detailed equipment list
are discussed  in Appendix C.  Suffice it to say here that  the primary instru-
mentation that was used was a Hewlett-Packard Model 5700 series gas chroma-
tograph with a Ni63 electron capture detector.  The column that was normally
used was a pyrex column 180 cm by 0.4 cm packed with 5% OV-210 on Gas
Chrom Q, operating with the injection port at 200°C, the column temperature
at 1950C and the detector port temperature at 250°C.  The  carrier gas used
was a mixture of argon and methane  (95% argon) at a flow rate of 45-50 ml/min.
Quantification was made using peak area as determined by a Hewlett-Packard
Model 3380 recorder-integrator.  Since the identity of the Kepone was based
on the retention time, numerous authentic samples were injected to assure
proper identity of the Kepone peak.

     G.C. retention time was found to "wander" to a greater extent than is
normally observed in the laboratory.  It was apparent that the extreme weather
conditions that occurred during these experiments, coupled with the absence
of temperature control in the laboratory (personnel frequently had to work
in the laboratory fully clothed in overcoats, mufflers and gloves), caused
variations in operating conditions of the gas chromatograph.  The only ef-
fective control measure that could be taken was the introduction of frequent
authentic samples.

     Calibration

     As suggested above, the extreme weather conditions at the site during


                                      18

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these experiments made it necessary that authentic and known concentration
samples of Kepone be injected on a schedule far more frequently than is nor-
mally the case.  In addition, it was found necessary to check the volumetric
calibration of measuring glassware by preparing spiked samples - this also
made necessary because of the abnormal temperatures in the laboratory.  As
indicated above, the laboratory was well equipped with primary standards as
well as with secondary working standards of Kepone solutions.  The primary
observed variation in the  GC  records for Kepone was a wandering of the re-
tention time, there was no discernable effect on quantitation of the amount
of Kepone present.

     Quality Control Measures

     Deliberate duplicates and spiked samples were introduced ad lib as part
of the internal quality control program.  In addition, a random number of
method blanks were used with distilled water as the sample.  Further, spiked
filters provided by the EPA and spiked water samples provided by the Virginia
Consolidated Laboratory were analyzed.  Many of the ambient air filters and
the high volume air monitor filters were split and sent to EPA (RTF) for
confirmatory analysis.  Results of these EPA (RTP) confirmatory analysis are
presented in Appendix H.

     Laboratory Monitoring and Interferences

     As is usual, the laboratory was constantly monitored by an ambient air
monitor on a continuous basis.  Further, routine wipe samples were taken at
weekly intervals from the floor, ceiling and laboratory benches.   In ad-
dition, at frequent but irregular intervals "clean glassware" was rinsed
in pesticide grade benzene, the washings concentrated and the concentrate
injected into the GC, in order to determine the adequacy of the glassware
washing procedures.  No glassware contamination was observed by these tests.
All reagents used in this program were similarily checked for possible Kepone
contamination and for the presence of interferences.  At no time during the
experimental program was Kepone detected either in the ambient air filter or
as a contaminant in clean glassware or in reagents.

Sample Handling

     Because of the considerable variety of sample types that were treated in
the course of this program, it is appropriate to discuss the initial sample
preparation for each of the following classes of samples:

     Filters and Paper Samples

     In this category are included stack sample filters, ambient air filters,
high volume air filters and wipe samples (made from a piece of Whatman filter
paper).  In the case of the first two, filters were delivered to the labora-
tory in a sealed holder; the wipe samples and the high volume filters were
delivered in sealed envelopes.  Each filter was routinely checked for mois-
ture, color, physical change and particle deposition before being handled,
without noteworthy observation.  After inspection, each filter was folded
into a cylindrical shape, using clean tweezers, and placed into a 30 ml


                                     19

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 glass-stoppered graduated centrifuge tube.  Measured amounts of benzene (10
 ml for stack gas filter and ambient air filter, 50 ml for the others) was
 then added to the tube, the  hole stoppered and allowed to soak for 10-15
 minutes.  A 3 microliter aliquot of the extract was injected into the gas
 chromatograph.  A second sample served as a check on the first.

      Scrubber Samples

      The one (1) liter scrubber samples were transported to the laboratory
 and cooled to room temperature by immersion in cold water.  A homogeneous
 200 ml sample was then transferred to a 500 ml erlenmeyer flask wherein the
 sample was acidified by the addition of 50% l^SO^ dropwise while stirring.
 The resulting solution was then transferred to a separatory funnel and ex-
 tracted with three successive portion (20 ml each) of benzene.  The extracts
 were then combined and concentrated by evaporation to 5 ml.  A3 microliter
 aliquot was injected into the GC for measurement.

      Cyclone and Impinger Samples

      After the volume of the condensed fluids in the cyclone was measured
 and the pH determined, the cyclone assembly was washed with several succes-
 sive acetone washings.  The combined washings and the collected fluids were
 then acidified with 6N HC1 and extracted with benzene.  The benzene extract,
 after concentration to 5 ml, was injected into the GC in the form of a 3
 microliter  aliquot for analysis.
      The procedure followed for the impinger bottles paralleled that for the
 cyclone assembly, the contents of the first and second impinger being com-
 bined to form the sample.

      Kiln Ash Samples

      At the end of each of the coincineration experiments, a sample of the
 collected ash was taken for residual Kepone analysis.  After the sample was
 thoroughly mixed, a 1.00 gram portion was weighed out.  This sample was ex-
 tracted with 50 ml benzene and the resulting suspension filtered through a
 Whatman filter.  The filtrate was then concentrated to 5 ml, from which a 3
 microliter aliquot was injected into the GC.  If there was an indication that
 the sample contained Kepone  the original material was then extracted on
 a soxhlet extractor and again chromatographed.

      Additional Sample Cleanup

      In some cases, particularly during the coincineration experiments, the
 benzene extracts were found to exhibit a large number of chromatographic
 peaks,  thus making accurate identification of the Kepone peak difficult.  In
 these cases an additional cleanup step was instituted.  The benzene extract
 was dried under a gentle stream of nitrogen in a 45 C water bath.   The resi-
 due was dissolved in 10 ml of 1 N NaOH followed by three successive extrac-
 tions with 10 ml portions of hexane.   The combined hexane extracts were con-
 centrated to 5 ml and analyzed for degradation products of Kepone.   The
residual basic solution was acidified with 50% H-SO  and extracted with ben-
zene.  The benzene extract was  then chromatographed for Kepone.  On spiked
samples, this method of base-partitioning has shown Kepone recoveries of
better than 90%.
                                      20

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                                  SECTION 5

                      EXPERIMENTAL PROGRAM AND RESULTS

EXPERIMENTAL PROGRAM

     The toxicity of Kepone and the nature of the publicity associated with
the aftermath of the Hopewell incident  made it essential that every safe-
guard be taken to prevent any exposure of the people of Toledo to unburned
Kepone.  The measures taken in this regard may be summarized here as follows:

     1.   The absolute imposition of an upper limit on the allowed emission,
          established as one microgram per cubic meter at stack conditions.

     2.   The careful sampling of the stack during all periods of Kepone
          injection into the furnace system.
     3.   Use of high-volume air samplers at various locations on the Midland-
          Ross property; these samplers to be in use during the entire experi*
          ment.

     4.   The entrapment and entrainment of all waters generated within the
          facility so that no discharge of Kepone to the environment could
          occur through this route.
     5.   Provision of essentially real time analysis of all stack samples so
          as to assure .that the stack levels did not exceed the 1.0 ygm/mr
          limit.
     6.   The use of an experimental protocol designed as a series of experi-
          ments with stepwise increases in the injection rate of Kepone such
          that any significant approach toward the emission limit would cause
          the experiments to be terminated.
     7.   The placing of control of continuation into the next experiment in
          the hands of a committee of officials directly concerned with
          environmental protection who could, after review of each completed
          experiment, decide to proceed or to alter the course of the program.
          To proceed in an orderly manner, a detailed protocol, discussed
          earlier, was designed before the beginning of the experiments.

EXPERIMENTAL PROTOCOL

     In order to establish a standard procedure for progressive increases in
the Kepone injection rate, a definite series of experimental steps was es-
tablished prior to the beginning of the test program.  It was provided that
the Burn Authority would have the absolute authority to determine continua-
tion or cessation of the experimental program, and, further, it was deemed
appropriate for the Burn Authority to utilize the technical staff for assis-

                                      21

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tance in the decision making process, especially if it were predicted that  to
continue along the pre-arranged steps would lead to the emission of unaccep-
table levels of Kepone.  The protocol outlined below was established as a
guideline for an experimental program, subject to change as dictated by ex-
perimental findings as the program advanced.

     Initial Program

     It was considered appropriate to carry out the experimental program in
two phases; (a) Direct injection of Kepone solutions into the duct leading
to the afterburner so as to simulate processes associated with the destruc-
tion of technical grades of Kepone, and (b) Coincineration of Kepone in
sewage sludge to simulate processes expected to be involved in the incinera-
tion of the sludge from the Hopewell Lagoon.  In this spirit, the following
set of experiments were planned (for completeness, the final pre-program
protocol is appended as Appendix D):

     Phase 1.  Direct injection Experiments

          1.  Kepone feed at 1.5 x 10~5 gm/min., 1260° C (2300°F),
                   2 second residence times.*

          2.  Kepone feed at 1.5 x 10 ~5 gm/min., 1093°C (2000°F),
                   2 second residence time.

          3.  Kepone feed at 1.5 x 10 ~2 gm/min., 1093°C (2000°F),
                   2 second residence time.

          4.  Kepone feed at 15 gm/min., 1093°C (2000°F),
                   2 second residence time.

          5.  Kepone feed at 15 gm/min, 1093°C  (2000°F),
                   1 second residence time.
                                            o       o
          6.  Kepone feed at 15 gm/min. 1038 C (1900 F),
                   1 second residence time.

     Phase 2.  Coincineration Experiments

          1.  Toledo sludge blank, 1093°C  (2000°F),
                   2 second residence time.
**
     2.  Hopewell sludge at same conditions as above.

     3.  James River sediments at same conditions as above.**

In all cases, the stated residence time is a nominal figure used as a
lower bound on an acceptable residence time.

Because the James River was completely frozen over, this experiment was
dropped from the protocol.
                                     22

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           4.  Toledo sludge doped at 25 percent  (on dry basis) with
                    Kepone, same conditions as above.

           5.  Toledo sludge doped at 50 percent  (on dry basis) with
                    Kepone, same conditions as above.

      Modified Program

      As the direct injection experiments proceeded during the program, it
 became obvious from stack gas analyses that the higher injection rates
 planned would seriously challenge the afterburner so as to allow the stack
 emissions to approach or exceed the limit of 1 microgram per cubic meter, and
 that some alteration of the protocol was required.  It was then determined
 that, in the interests of completing the experiments without exceeding the
 emission limits, it was desirable to omit the high level injection experi-
 ments and proceed to the coincineration studies.

      As a result of such decisions based on the completed experiments, the
 actual series of experiments that were carried out consisted of the following:

      Phase  1.  Direct Injection Experiments

           1.  Acetic acid alone

           2.  Acetic acid solution of kepone; 1.67 x 10   gm/min.,
                    1260°C (2300°F), with 2 second residence time.*

           3.  Acetic acid solution of kepone; 1.67 x 10   gm/min.,-
                    1093°C (2000°F), with 2 second residence time.
                                                        _2
           4.  Acetic acid solution of kepone; 1.67 x 10   gm/min.,
                    1093 C (2000°F), with 2 second  residence time.

      Phase  2.  Coincineration Experiments

           1.  Toledo sludge, 1093°C (2000°F), 2 second  residence time.

           2.  Toledo slydge with kepone, 5.68 gm/min. of kepone,
                    1149 C (2100°F),with 2 second residence time.

           3.  Toledo sludge with kepone, 5.68 gm/min. of kepone,
                    1093°C (2000°F),with 2 second residence time.

           4.  Toledo sludge with kepone, 5.68 gm/min. of kepone,
                    1038°C (1900°F), with 2 second residence time.

           5.  Toledo sludge with kepone, 24.2 gm/min. of kepone,
                    1093°C (2000 F), with 2 second residence time.

*   As before, the cited residence times are to be considered as nominal
values to be used as a lower bound on the actual  (calculated) residence time.
                                      23

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EXPERIMENTAL RESULTS

     The chief results of these experiments are displayed in Table 1 which
summarizes the primary data derived from these tests.  The detailed data on
the furnace operations are presented in full in Appendix E, whereas the
data derived from the stack and scrubber Kepone concentration measurements
are displayed in the sections which immediately follow.  In order to further
simplify the following presentation, examples of typical chromatograms of
authentic standards and of typical samples are displayed in Appendix F.  In
addition, a detailed log of the day by day events that characterized this
program is presented in Appendix G.

     Before proceeding with the presentation of the detailed data it is
appropriate to indicate several results of a general nature that derive from
these experiments.  First, the interaction of the Burn Authority with the
Experimental Management Group was continuous and of great benefit to the
overall program.  Evidently, this form of program management is a viable and
useful tool to be exploited in all such experiments with hazardous materials.

     There has been some question raised about the effect of the personnel
safety measures on the productivity of the operating personnel.  Although
this was not considered to be an experimental variable, the reduction in
productivity did have a major impact on the program costs.   Specifically, the
day-by-day wearing of protective equipment in the Operations Room and the
personal hygiene regimen imposed on those workers, appears to have resulted
in a 15 to 20 percent increase in costs of these day-by-day operations.  It
would also appear that the necessity of the full protection, including the
respirator, resulted in a 50 percent decrease in productivity (this is only
an estimate).  Further, the expenditure of some 10 hours per person in the
lecture portion of the safety program, had a significant impact on the total
manpower hours that were expended, especially in terms of a program limited
to some eight weeks.

Stack Sampling Data

     The stack samples were collected in accordance with EPA Method Five
using the RAC Staksampler (R).  The data for the twenty eight (28) separate
stack sampling runs are summarized in Table 2 and 3 which follow.  The de-
rived quantities were calculated in accordance with the procedures outlined
in ASTM Method D2929-  The corresponding Kepone concentrations found for
these stack runs are tabulated in Tables 4 and 5.  It will be noted that at
no time did the stack emission rate exceed the pre-established level of
1 x 10   gm/m  at stack conditions.

Scrubber Data

     The scrubber samples were, in the earlier experiments, taken at the end
of each stack sample run.  Unfortunately, it was discovered that the position
from which such samples were taken was the reservoir for the scrubber system
and thus the concentration measurements were of little significance.  In
addition, it was found that the average level of water in the scrubber system
                                     24

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                                                            TABLE 1: SUMMARY OF KEPONE INCINERATION EXPERIMENTS
              Experiments

Kepone Feed
Rate
(gms/min)
Total
Feed
Time
(min)
Total
Kepone
Fed
(gms)
Stack
Emission
Concentration
o
(gm/m )
Total
Stack
Output
(gms)
                                                                                  After-    After-    Key for     Key for
                                                                                  burner    burner    Scrubber     Stack
                                                                                   Temp     Temp    Samples       Scans
            Injection Runs
                   1
                   2
                   3
                   4
                   5
Acetic Acid Only
1.67x10"
1.67x10"'
1.67x10
     1.50
        ,-5
,-2

130
135
100
115

2.16 xlO"3
2.25 x10"3
1.67
172.5

ND
ND
ND*
5.3Sx10"8

ND
ND
ND*
1.76 x 10"*
1260
1260
1093
1093
1093
2300
2300
2000
2000
2000
1
2,3
4-6
7,8
9-11
1
2^3
4,5,6
7,8
9,10,11
Ul
            Sludge Runs
6*»
7
8
9
10
11
Background
Toledo Sludge Only
5.68
5.68
5.68
24.2
120
120
315
240
220
165
-
-
1789
1354
1241
3995
                                                                                            ,-7
                                                                                    2.96x10
                                                                                         ND
                                                                                    1.7 x 10"8
                                                                                    2.4 x10"8
                                                                                    2.55 x 10~8
                                                                                    2.95 x 10~8
7.1 x 10"^
ND
1.85X10"4
1.85 xW4
1.53 x 10"4
1.67x 10"4
1093
1093
1149
1093
1038
1093
2000
2000
2100
2000
1900
2000
12
13,14
16-22
23-31
32-40
41-46
12
13,14
16-19
20-22
23-25
26-28
            Totals
                                                                       8553 gms
                                                                   1.58x 10~Jgms
                Apparent kepone peak on chromatogram of filter collected. The kepone peak did not appear after base
                partitioning of original extract.
                Experiment 6 was run with a highly contaminated scrubber water (25 ppb of kepone)  in an attempt to find the causes
                of the high emission in the previous experiment.
                See Tables 4, 5, & 6
                See Tables 2 & 3

-------
                  TABLE 2  Summary of Stack Sampling Data
Run  Pmeter  Impinger  Sample    Water    Total   Percent  Sample  Water
No.            Temp.   Volume  Collected  Sample   Water    Time    Loss

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
(mm Hg)
678
579
599
617
597
478
511
538
544
627
572
645
533
(°K) (m3)
300
300
303
290.5
291.6
301
298
306
300
296
306
300
263
1.
1.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
138
169
537
993
933
663
780
477
662
681
637
817
741
(ml)
100
100
145
105
100
460
429
400
412
91
380
170
444
	 	 Aborted 	
572
544
551
480
478
572
658
470
467
460
584
587
634
305
298
301
310
313
314
305
311
305
301
301
297
302
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
676
713
706
665
648
630
447
648
545
651
688
655
527
349
377
226
202
215
246
165
185
170
260
143
156
163
(tn3)
1.
1.
0.
1.
1.
1.
1.
1.
1.
0.
1.
1.
1.


1.
1.
1.
1.
1.
1.
0.
1.
0.
1.
0.
0.
0.
267
316
768
171
113
645
619
188
418
798
290
102
580


277
376
111
060
070
029
688
015
897
170
954
921
774
15
17
36
41
18
62
55
64
57
21
56
27
56
—
52
54
41
46
49
49
41
47
46
52
29
32
37
(min . )
48
45
31
48
48
42
42
40
40
41
35
39
39
—
34
32
32
32
32
29
25
32
29
30
32
30
26
(gm/sec)
32
31
84
38
13
125
119
117
105
36
119
70
135
	
123
126
94
90
88
102
98
87
85
107
72
78
102
.8
.5
.5
.5
.2






















                                    26

-------
                  TABLE 3  Summary of Stack Velocity  Data
                    Sp. Gr.            __
              %      Stack     Tg     fVK)        v              Q
Run No.    Water     Gas         .        ave     ave	
  T  =  Stack Temperature (  K)
   s
  h   = Velocity Pressure (nrniH^o)

  v   = Stack Gas Velocity (m/sec)
                                       3
  Q   = Stack Gas Flow Rate (Standard m /hour)
                                   27
                               (°K)              (m/sec)     (SCMH x 10 3)
2
3
4
5
6
7
8
9
10
11
12
13
14
1 C
13
16
17
18
19
20
21
22
23
24
25
26
27
28
15
17
36
41
18
62
55
65
57
21
56
27
56

~~
52
54
41
46
49
49
41
47
46
52
29
32
37
0.815
0.794
0.869
0.852
0.932
0.780
0.803
0.773
0.797
0.921
0.800
0.900
0.800


0.814
0.809
0.852
0.835
0.825
0.825
0.852
0.831
0.836
0.816
0.894
0.883
0.866
362
361
361
352
358
355
355
355
355
355
351
386
390
A r\ f\*V*^* Q n
ADOirtEQ
405
408
408
405
411
411
422
405
405
405
405
405
405
0.397
0.383
0.438
0.430
0.358
0.410
0.417
0.318
0.335
0.314
0.374
0.465
0.468


0.449
0.461
0.473
0.478
0.446
0.432
0.424
0.484
0.450
0.484
0.503
0.477
0.496
8.43
8.23
8.99
8.82
7.07
8.83
8.84
6.89
7.13
6.22
7.89
9.70
10.42

___«
10.09
10.44
10.43
10.61
10.03
9.71
9.51
10.77
9-99
10.87
10.80
10.30
10.81
1.52
1.48
1.62
1.62
1.30
1.61
1.61
1.26
1.31
1.14
1.46
1.63
1.73

— ___
1.62
1.66
1.66
1.70
1.59
1.54
1.46
1.72
1.60
1.74
1.73
1.65
1.73

-------
                 TABLE 4  Stack Kepone Concentration Data
                         for Injection Experiments
Sample

  2
  3
  4
  5
  6
  7
  8
  9
 10
 11
 12
 13
 14
 15
Kepone Detected
(gms)
ND
ND
ND
ND
ND
ND*
ND
ND
90 x 10 g
17 x 10
296 x 10 ~9
ND
ND
ABORTED
Sample Vol.
(SCM)**
1.267
1.316
0.768
1.171
1.113
1.645
1.619
1.188
1.418
0.798
1.290
1.102
1.580

Kepone Cone.
   (gm/M3)

      0
      0
      0
      0
      0
      0
      0
      0  _9
  63 x 10 n
  21 x 10
 229 x 10 y
      0
      0
Kepone Emmission
     Rate
  (gm/minQ _

       0
       0
       0
       0
       0
       0
       0

 13.8 x IQ-
  4.0 x 10~
55.
    7 x 10
       0
       0
          ~7
*A peak appeared in the original extract of the cyclone sample which
disappeared after base partitioning of the extract.

**SCM = Standard Cubic Meters at 21.1QC (70°F)  and 760 mm Hg pressure.
                                   28

-------
                TABLE 5  Stack Keoone Concentration Data
                    for Colncineration Experiments
Sample Run

   16
   17
   18
   19
   20
   21
   22
   23
   24
   25
   26
   27
   28
Kenone
Detected
(gms)
ND
ND
10 x 10
43.9 x 1Q~9
40 x 10
30 x 10~9
28 x 10 n
Q
37 x 10 „
Q
22 x 10 f

34 x 10
31.2 x 10 9
31.3 x 10 9
27 x 10 y
Sample
Volume
(SCM)**

1.11
1.06
1.07
1.03
0.688
1.015
0.897

1.17
0.954
0.021
0.774
Kepone
Cone
(gm/M3)
—
9 x 10~9
41.4 X 10~g
37.4 x 10
29 x 10~9
40.7 x 10~9
36 x 10~9
24.5 x 10~9

29.1 x 10 y
32.7 x 10~9
34.0 x 10 9
34.9 x 10
Kepone Emission
Rate
(gm/min)
—
2.5 x 10~7
11.7 x 10~ 7
7.4 x 10
9.9 x 10~7
10 x 10~7
6.5 x 10~7
_ /
8.4 x 10 '
9.4 x 10~7
9.4 x 10~7
10 x 10~7
*SCM = Standard Cubic Meters at 21.1°C  (70°F) and 760 mm He pressure.
                                  29

-------
was not recorded during the earlier runs so that there was no way to deter-
mine the total level of Kepone within the scrubber system.  These defic-
iencies were corrected so that scrubber samples 16 through 46 were taken at
the appropriate site within the scrubber system and the level of water within
the system was recorded so that total quantities of Kepone within the scrub-
ber/quench system could be determined.  The results of the analyses of the
scrubber concentrations are tabulated in Table 6.

     The data that are presented in Column 5 of Table 6 were derived under
the assumption that when the scrubber reservoir had a level of 1.57 m the
total volume of the scrubber/quench system was 1325 1 and that a 2.54 cm
change in this level corresponded to a 16.7 1 change in volume.  With this
basis it was possible to convert the measured concentrations of Kepone within
the scrubber (Column 2 - Table 6) into total scrubber kepone loads.

ANALYSIS OF EXPERIMENTAL RESULTS

Efficiency of Combustion

     The results from the direct injection experiments are displayed in
Table 7 and those for the coincineration experiments in Table 8.   The re-
ported efficiencies all of which exceed 99.99 percent which are based on the
stack emission rate divided by the Kepone input rate, strongly support the
conclusion that incineration is a viable and safe method of disposal of
Kepone and of Kepone contaminated sludges at least under the conditions that
the afterburner temperature is not less that 1038°C (1900°F) and the res-
idence time is of the order of two (2) seconds.

     The relatively high levels of Kepone detected in the stack during the
1.5 gm/min. injection run suggested that further tests with even higher in-
jection rates could lead to unacceptable Kepone emission rates; as a result,
such experiments were discontinued in favor of the coincineration studies.
The results of the highest level injection run were complicated by the ab-
sence of any useful method of determining whether passage of Kepone through
the afterburner was due to inadequate vaporization within the injection
nozzle  (which was of unconventional design), or to some transient change in
afterburner conditions, or did, in fact, represent an accurate measure of the
capabilities of the afterburner.  The internal consistence of the discussion
presented in Section 7.3 does, however, suggest that the measured efficiency
from the injection experiments are entirely consistent with those from the
coincineration experiments.

     The high Kepone emission rates that were observed during runs 12-14,
which occurred with no Kepone feed into the system but with relatively
heavily contaminated scrubber water (25 ppb), cannot be readily explained,
especially in view of the fact that during the last of the coincineration
experiments the scrubber concentration rose to even higher levels.  It is
perhaps relevant to point out that the measured stack water content was also
                                     30

-------
                  TABLE 6  Scrubber Sample Data

Measured
Kepone
Time Scrubber Scrubber Kepone
Sample No.# Concentration Taken Volume** Kepone Load Feed

16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43

44
45
46
#
(ppb)
0
0.74
3.0
3.1
3.1
6.6
5.2
8.3
6.7
5.5
5.2
4.8
4.8
5.19
13.7
11.8
9.6
11.9
15.0
10.9
14.1
13.7
17.2
15.1
13.3
29
31.7
27

32.4
25.9
18.1
(min)*
(Background)
105
155
185
230
260
290
(Background)
30
60
90
125
150
180
210
240
(Background)
10
40
70
100
130
160
180
205
(Background)
18
48

78
108
138
Scrubber sampling during the
AB Temp.
(M3) (gms) (gms/min) (°C)
o .
1.14 8.4 x 10~4 5.68
1.108 3.33 x 10~3
1.242 3.80 x 10
1.292 4.00 x 10~3
1.058 6.99 x 10~3
1.225 6.37 x 10~3
n
1.175 7.87 x 10":: 5.68
1.004 5.52 x 10
0.842 4.38 x 10~3
1.067 5.12 x 10
0.900 4.32 x 10~|
1.125 5.84 x 10
0.933 1.28 x 10~2
1.241 1.47 x 10 2
f\
1.183 1.41 x 10~2 5.68
0.996 1.45 x 10~2
1.376* 1.50 x 10 ,
1.125* 1.59 x 10 j
1.283 1.76 x 10~2
1.067 1.84 x 10
1.195 1.80 x 10
1.050 1.40 x 10~2
f\
1.083 3.43 x 10"^ 24.
0.879 2.37 x 10~2
— /
1.100 3.56 x 10
0.908 2.35 x 10 2
1.133 2.05 x 10
1149
(2100°F)





1093
(2000°F)







1038
(1900°F)







1093
2 (2000°F)





first set of experiments was deemed to
be of no value since there was no measure available for


of the (closed)
data for samples
scrubber system at the time of sampling
1-15 are not
included in this summary.
the volume
. Thus the

 *  Measured from onset of Kepone feed.
**  Calculated from scrubber water level data, based on average filled
    scrubber volume of 1325 L (350 gal).
                                31

-------
             TABLE 7  Combustion Efficiency for Kepone Injection

                                  After-
                                  burner                       Efficiency of
               Kepone Feed Rate    Temp    Stack Kepone Loss    Combustion
Stack Sample       (gm/min)        (°C)        (gm/min)	   	%	

     2             1.67 x IQ~5     1260           0            100*
     3             1.67 x 10~^     1260           0            100
     4             1.67 x 10~^     1093           0            100
     5             1.67 x IQ~1     1093           0            100
     6             1.67 x 10 ;>     1093           0            100
     7             1.67 x 10~2     1093           0            100
     8             1.67 x 10"2     1093           0            100
     9             1.50            1093           0            100
    10             1.50            1093           0            100
    11             1.50            1093      13.8 x 10"'        99.99991
    12             0               1093       4.0 x 10 •'        **
    13             0               1093      55.7 x 10"'        **
    14             0               1093           0
    15             0               1093           0
     *  To speak of 100 percent combustion efficiency is somewhat unrealistic
        but is a natural consequence of the definition for efficiency of
        combustion in those situations for which there is so small a stack
        load of Kepone that it was undetectable.  Further, the expression of
        the combustion efficiency in terms of 6 or 7 decimal places is just-
        ified since even if both the input rate and the emission rate were
        in error by as much as 25 percent, the extremes would only affect the
        combustion efficiency in the sixth decimal place — again a conse-
        quence of the definition of the combustion efficiency and the very
        small emission rates that were found.

    **  Stack samples 12, 13 and 14 were taken during experiments 6 and 7
        (see Table 1-1 for details).  The scrubber was contaminated so that
        even in the absence of Kepone feed there was detectable Kepone in
        the stack.
                                      32

-------
                TABLE 8  Coincineration Efficiency for Kepone
                             with Sewage Sludge
Stack Sample

    16
    17
    18
    19
    20
    21
    22
    23
    24
    25
    26
    27
    28
                   After-
                   burner
Kepone Feed Rate    Temp
    (gm/min)
Stack Kepone Loss
    (gm/min)
                                                               Efficiency of
                                                               Destruction *
5.
5.
5.
5.
5.
5.
5.

5.
5.
5.
24.
24.
24.
68
68
68
68
68
68
68

68
68
68
2
2
2
1149
1149
1149
1149
1093
1093
1093

1038
1038
1038
1093
1093
1093
0
0
2.
11.
9.
7.
9.

10
6.
8.
9.
9.
10
5
7
9
4
9


5
4
4
4

X
X
X
X
X

X
X
X
X
X
X
10
10
10
10
10

10
10
10
10
10
10

-7
-7
-7
-7
-7


-7
-7
-7
-7
-7

100
100
99.
99.


99995
99998
99-99998
99.
99-

99.
99.
99.
99.
99.
99.
99998
99998

99998
99999
99998
999996
999996
999996
    *  See footnote Table 7.
                                     33

-------
highly variable during this run and also that the pH of the water collected
in the stack sample also varied from neutral to highly basic (the larger
the collected volume the more likely it was to be basic).  Further, the
ambient weather conditions that prevailed during the early set of measure-
ments (runs 1 through 14) when the average temperature was well below 0°C,
had the effect of causing the stack plume to appear to arise from well within
the stack itself.  In the interval between the first set of runs and the last
series which involved coincineration (16-28), a new stack and a stack re-
heater were installed.  The modified stack coupled with the considerable
amelioration in the weather probably affected the observed results.

Scrubber Kepone Concentration and Kepone Load

     During the coincineration experiments it was decided that frequent
scrubber samples should be taken in order to understand better the effects
that the scrubber had on the apparent Kepone destruction ratio of the total
system.  The scrubber Kepone load at any instant was found by multiplying the
concentration at that moment by the instantaneous volume of the scrubber
using the conversion factors that are discussed in Section 6.2.  The results
of such measurements and calculations are displayed in Table 6 (Column 5)
and more graphically in Figures 8 through 11.

     A study of the Figures 8 through 11 indicates that the time rate of
change of the total scrubber Kepone load is quite different in each case and
further, that there are very striking differences in the nature of the ob-
served changes.  The data in each plot are summarized by the least squares fit
to an equation of the form

                              m(t) - m(0) + b(t)           (7.1)

     where m(t) is the total Kepone mass in the scrubber at time t
           m(0) is the initial  Kepone mass in the scrubber at time t=0
           b is a constant that characterizes each set of conditions
           t is the elapsed time
[note also that the constant b is the slope of the plot of m (t) vs. t]

     In order to attempt an understanding of the significance of the curves
presented in Figure 8 through 11, it is useful to summarize the data on
stack emission rates from Table 5, with the slopes of the curves in Figures
8 through 11,in Table 9.  It is first of all important to note that the-
stack emmission rates (Column 2, Table 9) are, in all cases, on the order of
one percent of the rate o  change of the scrubber JKepone load (Column 3,
Table 9).  With this observation, we may assume that the rate of loss of
       from the scrubber due to evaporative losses up the stack is only a
small effect and thus may be neglected in what follows.

     Now, the rate of change of Kepone  mass within the scrubber is neces-
sarily the result of the interaction of several phenomena; that is to say,
       was injected into the scrubber from the unburned material that
traversed the incinerator.  One would expect, in view of the smallness of
the rate of stack emission, that the slopes of the curves in Figure 8 through
                                     34

-------
                                     LEAST SQUARES FIT

                                     M(t) = [-9.7X10-4 + 2.63XIO-5t](gms)
u>
      CM

      O
      E
      cr>
      Q
      <
      O
      O
      Q.
      ca
      UJ
      OQ
      00
      •=>
      on
      O
     0.8 ••
           0*5 ..
     0,3 ••
           0.1 •-
FIGURE  8  :
                                100
                                          200             300

                                         TIME OF FEED(min.)
400
                           CALCULATED  SCRUBBER LOAD OF KEPONE AS A FUNCTION

                           OF TIME  (.5.64gm/min. KEPONE FEED-,ABTEMP. II49°C(2IOO°F)

-------
            1.5 T
                             LEAST SQUARES  FIT
                             M(t) = [9.41 x  10-3~5.82 x
                             M(t) = [1.24 x  10-2+ll.13x
10-5t]gms  (0  <;±  <,
10-H]gms  (I00*t)
                                                                     ICOminj
       CM
       g

       x
        10
        E
        o>
    i.O -•
to
3

UJ
z
o
Q_
111
       Q
       UJ
       O

       <
       
-------
                                     LEAST SQUARES FIT

                                     M(t)  = [1.35  x l(T2+2.75xlO-5t]gms
       CM
       O

       X
        in
        E
        o>
            I.9T
     1.8'
CO
--J
LU

O
a.
LU
             1.7-
            1.6 • •
        cr
        LU
        CD
        CD
        Z)
        IT
        O
     1.5- •
            1.4-
             I.3--
                                                 4-
                                50
                                         100              150

                                        TIME OF FEED(min.)
2OO
     FIGURE I0  '
                    CALCULATED  SCRUBBER LOAD  OF KEPONE AS A FUNCTION

                    OF TIME   5.64 gm/min. KEPONE  FEED; ABTEMP. I038°C(I900°F)

-------
             3.5 X
          LEAST SQUARES FIT

          m(t)° [3.47X10-2 - 9.27 XIQ-StJ gms
OJ
oo
        CM
        O

        X

        V)

        E
        Q
        <
        O
        Ul
        z
        O
        Q.
        LU
        a:
        UJ
        CD
        CD
        3
        cc
        O
            2.5"
            2.0"
                                50
                     100

                 TIME OF FEED(minJ
150
200
      FIGURE _LL
CALCULATED SCRUBBER  LOAD OF KEPONE AS A FUNCTION
OF TIME  24.2gm/min. KEPONE FEED;ABTEMP.I093°C(2000°F)

-------
 TABLE 9  Tabulation of Kepone Input and Loss Rates  (Scrubber)
Stack Sample

    16
    17
    18
    19
    20
    21
    22
    23
    24
    25
    26
    27
    28
Stack
Kepone Loss
(gm/min.)


2.5

11.7

9.9
7.4
9.9
10
6.5
8.4
9.4
9.4
10

0
0
X

X

X
X
X
X
X
X
X
X
X


10-7
_7
X V* —1
— /
10 '
ID'7
^
10 '
io:
10 7
10_7
10 '
io-7
Slope of
Scrubber Load
(gm/min.)

2.
2.
2.

2.

-5.
9-
9.
2.
2.
2.
-9.
-9.
_Q

63
63
63

63

82
64
64
75
75
75
27
27
27

X
X
X

X

X
X
X
X
X
X
X
X
X

10
10
10

10

10
10
10
10
10
10
10
10
10
-5
_5
^J
-5


_S
_/
-5
-5

-5
~wf
-5

~5
Scrubber
Kepone Input
Rate
(gm/min. )

11.
11.
11.

11.

12.
12.
12.
18.
18.
18.




9
9
9

9

0
0
0
9
9
9




X
X
X

X

X
X
X
X
X
X
0
0
0

10"^
10-5
10 *

10
^n- ^
10

1°1
10 ^
10 J
10 5



                               39

-------
11 would all be positive; that is one would expect the scrubber load to con-
tinually increase with time.  That is clearly not the case, as for example in
Figure 11.  It then becomes necessary to assume that there are processes that
operate within the scrubber to decrease the amount of Kepone that is present;
that is to say, there must be processes that are operative within the scrub-
ber that can destroy Kepone. *

     In general, the amount of kepone that passes through the incinerator for
a given rate of input to the kiln must necessarily depend on the Kepone feed
rate and on the thermal conditions that occur   within the afterburner and in
the kiln.  Suppose that, for the sake of argument, it is assumed that the
particular conditions that existed during the run from which the data dis-
played in Figure 11 were obtained, were such as to reduce the rate of Kepone
injection into the scrubber to zero.  Under these circumstances, the behavior
of the scrubber during that experiment was governed only by those destructive
processes particular to the scrubber itself.  From this observation, we may
estimate that those processes operate to destroy kepone at the rate

                         dm/dt = 9-27 x 10~5 gm/min        (7.2)

as obtained from the slope of Figure 11.

     If it is now assumed that these processes are always operative indepen-
dent of the conditions that occur  within the kiln or the afterburner, then
the results shown in Equation (7.2 ) may be used in conjunction with the
observed slopes in Figures 8 through 10, to compute the rate at which Kepone
must have been injected into the scrubber in those experiments.  The results
of these calculations are displayed in Column 4 of Table 9.

     With the data that are displayed in Table 9 and those in Table 1 (for
the Kepone injection rate from Column 2 of Table 1) it is possible to com-
pute the effective efficiency of the incinerator - kiln plus afterburner -
independently of the scrubber effects.  The results of this calculation are
displayed in Table 10.

     To carry this discussion one step further, it will be recalled that
during the 1.5 gm/min injection experiment, the scrubber Kepone concentra-
tion changed such that, after a total feed of 178 gm of Kepone,  the scrubber
load was 3.3 x 10~  gins (corrected for the assumed scrubber loss mechanisms).
If it is now asserted that this result was a consequence of the direct chal-
lenge to the afterburner, then the efficiency of the afterburner for Kepone

*"The discussion regarding the disappearance of Kepone from the scrubber
 solution was particularly interesting.   I believe, however,  that the dis-
 appearance of the Kepone is caused by its chemical destruction in the hot
 caustic solution of scrubber.   Our data at this laboratory show that Kepone
 can be completely converted to  NaCl and Na2C03 by exposure to caustic solu-
 tion at 350°C under pressure with excess oxygen with a residence time of 5
 minutes.   I think that a similar process is occurring in the caustic solu-
 tion of the scrubber in contact with the hot  gases at a somewhat slower
 rate.    By A.J.  Frank in response to technical review solicitation,
 Corporate Director,  Environmental Planning.
                                     40

-------
combustion was 99.981 at a temperature of  1093°C and with a residence  time of
the order of two  (2) seconds.

     To return to the coincineration experiments which involve the kiln as
well as the afterburner, it is appropriate to indicate the kiln exit, temper-
ature as functions of time.  The data are  presented in Figures 12 through
15.  It is immediately noted from Figures  12 through 14, that during these
experiments, the kiln temperature was below 350°C.  According to the results
of Rubey and Duvali /Kepone is unstable at temperatures above 350°C so that
it is reasonable to assume that during the experiments described by Figures
       TABLE 10  Incinerator* Efficiency as Derived from Scrubber Data
         Afterburner      Kepone Feed     Kepone Input     Efficiency of
         Temperature     Rate to Kiln      to Scrubber       Incinerator
            (°C)            (gm/min)       (gm/min)           (percent)

            1149              11.2        1.19 x 10~4         99-9989
                                                   -4
            1093  --  --    -   5.64       1.2  x 10           99.99789

            1093              24.2

            1038               5.64       1.89 x lo"4         99-9966

         *  Incinerator includes both kiln and afterburner but excludes
            possible effects due to scrubber.
                                      41

-------
  o
  o
  W
     500 T
     450 • •
     400 • •
  £  350

  2

  UJ
  *,  30°
     250 '
         0
30      60      90      120      150

                       FEED TIME (MIN.)
180
2IO
240
270
FIGURE J2_
         KILN EXIT TEMPERATURE AS A FUNCTION OF TIME

             5.6gm/min.,  AB I 149°c CO INCINERATION

-------
to
           400 T
           350 •
           3OO -•
       o
       LU
       CE

       13
o:
UJ
0.
5
HI
H
       X   250
       UJ
           200 -•
           150
     FIGURE -11-
                                                   l
                       30       60      90       120       150

                                                FEED TIME (MIN.)
                                                           180
210
240
                           KILN EXIT TEMPERATURE AS A FUNCTION OF TIME

                              FEED 5.6 g/min., AB I093°C.COINCINERATION

-------
  o
  o
  LU
  cc
  LU
  0.
  5
  UJ
      450
      400
      350
300
  2   25°
      200
           0
FIGURE J±.
            30
                    O ,
60
90
 120      150
FEED TIME
180
210
240
                      KILN EXIT TEMPERATURE AS A FUNCTION OF TIME
                         FEED 5.6 gm/min.,AB I038°C COINCINERATION

-------
           500
        O
        o
        LLl
•e'-
en
cr
in
a.
5
UJ
            400 ••
        X
        LU
            300 ••
                        30       60      90      120      150

                                                 FEED TIME (WIN.)
                                                            ISO
210
      FIGURE
                          KILN EXIT TEMPERATURE ASA FUNCTION OFTIME

                             FEED24.2 gm/min.,AB I093°C COINCINERATION

-------
12 through 14, some of the input Kepone to the kiln escaped to enter the
afterburner.

     At this point it should be possible to unravel the separate effects due
to the kiln from those due to the afterburner.  Unfortunately, this possi-
bility was not recognized in the initial phases of the experimental study so
that no provisions were made to allow sampling of the (rather lengthy) duct
from the kiln output to the afterburner input.  Thus any serious attempt to
discover the separate effects would be almost entirely speculative.  There
are several remarks that can be made.  If we examine the kiln output
temperature as shown in Figure 15, it is clear that in this case, the exit
temperature never fell below 400°C and this particular experiment exhibited
the behavior shown in Figure 11 wherein the scrubber Kepone load decreased
throughout the entire experiment.  Presumably, this behavior arose because
little or perhaps no Kepone was able to escape destruction within the kiln.
Thus it would certainly seem that the function of the kiln in this particular
application is something more than a simple pyrolyzer to vaporize the Kepone
from the sludge.

The Scrubber Effect

     Several features of these experiments indicate that there are processes
that occur within the scrubber that have not been illuminated by the nature
of the available data.  For example, the apparent association of Kepone with
sodium hydroxide within the escaping stack gases is difficult to account for.
In all cases in which Kepone was found in the stack sample, the fluids that
were collected showed a basic pH.  Further, the rate at which Kepone was
"evaporated" from the scrubber as compared to the rate at which water was
evaporated seemed to indicate that the kepone concentration in the stack
water was quite comparable to that in the scrubber as a whole.

     The nature of the Kepone destruction process(es) that are postulated to
occur within the scrubber are difficult to visualize, although it should be
noted that the process whereby the hot stream of gases from the afterburner
is quenched should be a rather violent process.  It is possible that the
exposure of Kepone to these hot gases in the moment of explosive evaporation
of the quench water might be sufficient to disrupt the molecule.  It is even
conceivable that the solution so rapidly evaporated in the quench process
would contribute to the stack load of Kepone.  Unfortunately, the scope of
this program was such as to make it  impractical to carry out the additional
measurements that would be required  to unravel these questions.

     It should be stressed that the  overall destruction efficiency for Kepone
of the incinerator system including  the scrubber was found to be higher than
the kiln-incinerator system without  the scrubber.

Observations of the Utility of a Field Laboratory

     The climate in which these experiments were conducted was such that it
was imperative that every effort be  made to prevent the exposure of either
the operations personnel or the general community to Kepone.  It was also
                                      46

-------
deemed essential that there be provided an on-site analytical capability to
perform, on essentially a real-time basis, Kepone analyses of quality com-
parable to those of a standard laboratory. As indicated in Appendix C, a
considerable stock of equipment and reagents was brought to the site in order
to allow these analyses to be carried out.  It is gratifying that the only
materials that required local purchase was a supply of distilled and de-
ionized water and ice.

     In spite of the somewhat makeshift nature of the physical facilities and
the rigors of the weather, it was found that trace Kepone analyses could be
completed in approximately 15 minutes for aqueous samples and about 30 min-
utes for filters and similar materials.  Such promptness allowed almost real-
time results to be made available to the Burn Authority and thus greatly
facilitated important decisions on program changes and continuation.

     In the course of some 38 days of laboratory operation nearly 1000 indi-
vidual analyses were performed by a staff of one analytical chemist and one
technical assistant - this is truly remarkable.

     The experience that has been gained by this activity suggests that such
a portable facility can be used for many such trace organic analyses.  How-
ever, the specific characteristics of Kepone, that is the relative ease with
which Kepone can be separated from other chlorinated organics by base parti-
tioning, were of importance in the speed with which sample cleanup and sub-
sequent analysis could be accomplished.  Analyses of compounds such as PCBs
could be expected to be somewhat more time consuming because of the elaborate
cleanup procedures that would normally be required.

Observations on the Adequacy of the Health and Safety Program

     The Health and Safety Program was conceived as an integral part of the
KIT program and was found to be entirely adequate.  Prior to the onset of
the program, all operating personnel were required to have a blood sample
taken to be compared with a similar sample at the completion of the program.
This test is a very sensitive measure of the magnitude of exposure that was
received.  In all cases there was no observed change found in the blood pic-
ture of the operating personnel.*  From these data it can be asserted that
no individual was exposed to measurable amounts of Kepone.

     In addition, the rather extensive wipe sample program that was under-
taken (as described in Appendix B) showed that the method of isolation that
was employed within the facility was also entirely adequate.  At no time was
there detected significant evidence of contamination on the walls or floor of
the operations room.  On the other hand, even the contamination found within
the kiln and mixing rooms was of such a nature that relatively little surface
cleaning was required prior to the disassembly of the facility.

     The success of the approach used in the KIT program suggests that simi-
lar methods could be of great utility in any installation that is involved

*See Appendix H
                                     47

-------
in the handling of toxic materials.

     An interesting side light on the need for training is the need for and
the use of protective equipment was brought out by the acetic acid spill
which occurred during the coldest weather in Toledo.  The freezing point of
glacial acetic acid is some 16.6°C so that it was frozen when the 55 gallon
containers were brought into the mixing room.  Valiant attempts to thaw the
material finally led to the use of a heating belt on the can.  Unfortunately,
the can overheated and caused the plastic liner to be ruptured.  By a strange
series of circumstances, this particular container had a small opening near
the bottom of the can, so that with the integrity of the liner breached,
acetic acid began to leak onto the floor.  In the excitement of the moment,
the container was turned on its side with the result that a significant
amount of the acid was allowed to spill onto the floor.  In any event, the
entire incident was cleaned up with only one very small skin burn resulting -
this in spite of the very corrosive nature of glacial acetic acid.

Seme General Observations

     The Surface Combustion facility was not constructed specifically for the
KIT program.  This fact introduced several factors into the program that
merit further discussion.

     The kiln, which was designed for batch operations, was not new and thus
suffered a number of breakdowns that served to delay the program.   The sludge
feed, which was to be continuous, was accomplished by the makeshift intro-
duction of a water cooled line through the hot exit gas duct into the kiln.
This procedure apparently resulted in the flash evaporation of Kepone without
allowing it to remain for a time in contact with the drying sludge.  It was
probably fortunate that Kepone is degraded at temperatures of the order of
350-400 C, since otherwise a great deal more of the material would have been
presented to the afterburner.  In addition, sludge was noted to fall from the
walls of the kiln onto the cooled water line with the result that there was
a considerable buildup of partially combusted material on the line.  At the
end of the run this deposited material was found to be admixed with the ash
so that ash concentration measurements were not particularly meaningful.

     Because of the particular arrangement of the components of the system,
there was an excessively long duct run from the kiln to the afterburner.  In
spite of the frequently expressed fears that Kepone deposition on the walls
of this duct would vitiate the results of the experiment, there was no evi-
dence of such a deposition when the experiments were finished.  Nevertheless,
the use of such a long duct run certainly decreased the thermal efficiency of
the system.

     A number of unexplained phenomena plagued the injection runs.  The suc-
cessive stack sampling runs were almost impossible to explain in terms of the
measured water content, which was found to fluctuate wildly.  After a new
stack fitted with a reheater was installed, there were no such variations
noted.  A possible explanation of these results might lie in the extreme
                                     48

-------
weather that occurred during the earlier experiments: it was cold enough  that
the plume was actually formed within the stack such that variations in the
actual level at which it formed would account for  the variations in the ob-
served results.  On the other hand, some of the stack water samples that  were
collected showed rather high pH, of the order of 9 to 10, and only when there
was a high pH was there Kepone found in the stack.  In the experiments that
involved the coincineration (with the newly installed stack and reheater) no
such high pH waters were collected even though traces of Kepone were detected
in the higher level experiments.

     The obvious failure of the Injection head-afterburner combination in
Experiment 5 does not lend itself to a ready explanation.  The injection  head
design was not conventional, as is discussed in Section 4.3.1, and could  not
be directly tested for its ability to entirely vaporize the acetic acid solu-
tion under the conditions that occur  within the feed duct.  On the other
hand, the flame out detector within the afterburner was not sufficiently
rapid in response to preclude a momentary flameout with the result that con-
siderable gas could pass through without the normal residence time.  In the
analysis of the scrubber effect in Section 7.2, it could with justification,
be assumed that the observed Kepone feedthrough in Experiment 5 was in fact
due to the lack of thermal capacity of the afterburner and thus these results
do represent the efficiency of the afterburner.  If this is assumed to be
true, then it seems that the primary destruction of Kepone occurred within
the pyrolyzer.

     The Surface Combustion incinerator system depended on the fan located on
top of the scrubber to provide the motive force for gas transport through the
entire system.  In particular, the ambient pressure within the kiln was main-
tained at slightly below atmospheric by the combined effect of this fan and
the gases generated by the flame input to the kiln as well as from the evap-
orating water and combustion fumes from the sludge.  During the period where-
in the coincineration experiments were being conducted, there is evidence
that the kiln experienced excursions of positive pressure.  Part of the evi-
dence for this statement arises from visual observation of steam rising from
the ports on the kiln, from the observation of smoke during the period after
the sight glass fell out but more strongly from the observation of Kepone
losses from the kiln.  The latter information derives from the observation
that the high volume sampler that was located on the roof of the Mixing Room
so as to sample the exhaust fan from the kiln room.  During the period 18
February through 25 February, this sampler picked up Kepone emissions.
During this same time, the level of .Kepone found in the stack was very much
below that detected by the high volume sampler.  Fortunately, other high vol-
ume samplers located down wind from the offender showed that dilution effects
had reduced the observed levels to well below the action level.

     The discussion on the Scrubber Effect in Section 7.2 indicated that
there was actually no provision for the determination of the actual volume of
the scrubber at any particular time.  This necessitated that one assume a
volume and calculate the level effects.  Had the system been designed for
research, such provisions would surely have been made.
                                     49

-------
                                 REFERENCES
1.   Duvall, D. S., and Rubey, W. A., Laboratory Evaluation ofHigh-Tempera-
     ture Destruction and Pesticides, EPA/2-76-299, December, 1976.
2.   "Standard of Performance for New Stationary Sources," Federal Register
     36 (247): 24876-24895 (23 December 1971).
                                     50

-------
                                APPENDICES
APPENDIX A.  FACT SHEET - KEPONE BURN

1.   Data from Duvall and Rubey at UDRI have shown that Kepone is com-
     pletely destroyed at temperatures in excess of 500°C (932°F) (Figure
     21, their report).  These results were obtained in dry air without
     flame and with 1 sec residence time.

2.   Data from Duvall and Rubey at UDRI also show that DDT (p-p'-DDT) under
     similar conditions is completely destroyed at 450°C (842°F) .

3.   Work by Versar (Contract 68-01-1587) demonstrated a destruction ratio
     of over 99.99% for DDT during co incineration with sewage sludge at 650°C
     (1200°F) nominal temperature and afterburner residence times on the
     order of 0.1 sec.
                 •

4.   The inference from the above is that the conditions within the surface
     combustion furnace/afterburner (1426°C - 2600°F with residence time of
     2 sec) is more than adequate for complete destruction of Kepone.

5.   The experimental protocol is designed as follows:

     Exp. 1.  Injection of Kepone solution at the rate of 2.5 x 10   gm/min
     for a total injection time of 4 hr for a total injection of 6 mg
     (0.0002 oz) of Kepone.

     The stack sampling and subsequent analysis is capable of detecting a
     quantity of Kepone that is less than 1 millionth of the hourly injection
     rate.  Thus, in this primary experiment, even if the afterburner had no
     effect on the Kepone, the airborne concentration at the ground 100 ft
     from the stack would not exceed 2.8 x 10~8 gm/m^ = 2.5 x 10~ H gm/liter.

     Assume that a 145-lb human has a lung tidal rate on the order of 5 11-
     ters/min and he is exposed to Kepone-laden air at a level of 2.5 x
     10"11 x5x60x4=3x 10~8 gm.

     Published data(2) suggest LDcQ~1.32 x 10~1 gm/kg body weight for Ke-
     pone in rats.  Assume that the same LD5Q obtained for humans; then

                             145 Ib   = 66 kg
                                    .7 gm
     Hence total exposure ~3 _ of LD^Q dose.
                           100,000,000

                                      51

-------
     Needless to say, no such exposure Is reasonable to expect, and  the  evi-
     dence for complete combustion of the Kepone is persuasive.

6.   The total amounts of Kepone to be used in the preliminary experiments
     are as follows:

     (1)  6 x 10-3 ^
     (2)  0.60 gm
     (3)  60 gm
     (4)  6000 gm
     (5)  0.60 gm
     (6)  0.60 gm

     TOTAL 6.062 x 103 gm = 13.4 Ib

7.   Safety Arrangements:

     (a)  General Public

          In view of the computation in Section 5, a level of Kepone emission
          (measured at the stack) of less than 1 x 10~^ gm/m3 is sufficiently
          stringent to assure public protection.  The analytical/sampling
          techniques involved are capable of detecting 5 x 10~12 gm Kepone,
          which for aim3 sample (^28 ft3) represents an emission level
          100,000 times below the safe level.

          On the completion of an experiment, the analytical data will be
          examined by a committee of senior environmentalists representing
          the community, the state, and the Federal EPA.  This group will
          have the final say as to whether it is safe and prudent to go to
          the next step of the experiment.  In all cases, an emission that
          approaches the limit of 1 x 10~6 gm/m3 will preclude proceeding
          further.

     (b)  Laboratory Personnel and Observer

          (1)  All Kepone used in this experiment will be in the form of
               solutions in sodium hydroxide/water and will be maintained in
               sealed containers.  Feed of these solutions will be through
               tygon tubing directly into the furnace.  At no time will
               Kepone feed solutions be exposed to the laboratory air.

          (2)  All safety and health precautions will be directed and over-
               seen by the Safety Group made up of recognized representatives
               of local and state health departments.

          (3)  All personnel entering the laboratory will receive blood tests
               before and after possible exposure.

8.  Pilot-Scale Experiments
                                     52

-------
     With the successful completion of the direct injection experiments (#1
     through 6),  additional experiments will be conducted with sewage sludge
     and soil samples, as follows:

          (7)  Uncontaminated sludge

          (8)  Hopewell sludge

          (9)  Kepone-injected sludge

          (10) Kepone-containing sediments

     (a)  Kepone quantities

          The Hopewell sludge contains  ^ I ppm Kepone,

               thus:  1000 Ib sludge    - 0.5 gm Kepone

                      injected sludge I - 2 x 10^ gm Kepone

                      injected sludge II- 4 x 10  gm Kepone

                      sediments         - 2.5 gm Kepone

          The injection process will require that Kepone solution be injected
          into the sludge just before the admission of the combined Kepone
          sludge into the furnace.  The entire experiment, if completed,  will
          involve at most approximately 150 Ib Kepone.  Actually, a total
          of 150 gal of Kepone solution  is  involved at most.

          It is planned to initially ship 15 gal of Kepone solution to the
          test site.  This is sufficient to complete the first six experi-
          ments.   Only after these experiments have been successfully run
          will the additional material be shipped.

     (b)  Sampling/Analysis

          In the pilot-scale experiments, sampling and analysis will be ex-
          tended to scrubber water (which will be impounded until it is
          determined that there is no Kepone therein) and to the furnace
          residuals; these in addition to the stack sampling.

9.    Waste and contaminated materials:

     (a)  Experimental Program is Completed as Proposed - Case I

          At the completion of the experiment, all contaminated equipment,
          supplies, and residues will be incinerated, with the usual test and
          analytical procedures being used.   This will be effective since the
          fact that the experiments have been allowed to go to completion
                                     53

-------
          infers that the incineration does indeed completely remove Kepone.

     (b)  Experimental Program Terminated Before Completion of Proposed Work-
          Case II

          Early termination of the experiment will result from the failure of
          incineration to completely destroy Kepone.  In this event, all con-
          taminated materials, supplies, and equipment will be dismantled and
          returned to Hopewell in sealed containers.

APPENDIX B. WIPE TEST PROCEDURE

     Open the Wipe Test Packet.  Remove the gloves from the packet and put
them on without bringing the outside of the gloves into contact with anything
other than the gloves or the inside of the glove package.

     Remove the sampling paper envelope and the sampling scale.  Take the
15-cm Whatman #4 paper in the right hand.  Place the 30-cm sampling scale
against surface to be wiped with the left hand.  Wipe the surface the length
of the sample scale.

Move the sampling scale to a new location.

Wipe five separate areas for each sample.

Replace the filter in the envelope, seal it, and record the location, date,
time, and initials of sampler.
                                     54

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                 TABLE B-l KEPONE WIPE SAMPLES 1/12/77

Sampled  Description                      Wipe Sample      Level of
                                        f micrograms 'N   Contamination
                                        V   1125cm2  /  (microgms/sq.ft.)

  1    blank                                 .003             .002

  2    walls & floor of lab                  .01              .008

  3    walls of lab                          ND               ND

  4    floor-kiln rra.                        ND               ND

  5    walls-kiln rm.                        ND               ND

  6    floor-mixing rm.                      ND               ND

  7    walls-mixing rm.                      ND               ND

  8    floor-all rooms shower trailer        ND               ND

  9    walls-all rooms shower trailer        ND               ND

 10    control rm. floor                     ND               ND

 11    control walls & equipment             ND               ND

 12    sampling platform floor               ND               ND

 13    sampling platform walls & equipment   ND               ND



 *ND = No Kepone detected  in sample.
                                   55

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                 TABLE B-2 KEPONE WIPE SAMPLES 1/24/77

Sample//   Description                     Wipe Sample      Level of
                                        /micrograms \  Contamination
                                        \   1125cm2) (microgms/sq.ft.)

  14    mixing rm.  walls before              2.53           2.08
        opening Kepone

  15    mixing room floor before             0.15           0.12
        opening Kepone

  16    mixing room floor after              0.35           0.29
        opening Kepone

  17    mixing room walls after               -*
        opening Kepone

  18    kiln room floor after opening Kepone  -              -

  19    kiln room walls after opening Kepone  ND             ND

  20    lab floor                             ND             ND

  21    lab walls                             ND             ND

  22    locker rm.  floor                      ND             ND

  23    locker rm walls                       ND             ND

  24    shower rm.  walls                      ND             ND

  25    shower rm.  floor                     0.0197         0.0163

  26    sampling platform floor              0.014          0.011

  27    sampling platform walls               ND             ND

  28    operations  & control rm. floor

  29    operations  & control rm. walls       0.028          0.023

  30    change room floor                    ND              ND

  31    change room walls                    ND              ND

  laboratory accident,  sample lost.


                                   56

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                TABLE B-3 KEPONE WIPE SAMPLES 1/31/77
Sample//   Description



  32      change rm. floor

  33      hallway floor

  34      blank

  35      mixing rm. floor

  36      mixing rm. walls

  37      kiln room floor

  38      left in change rm.

  39      left in change rm.
Wipe Sample    Level of
(micrograms \ Contamination
  HZScm^) (microgms/sq.ft.)
 <.0.02

 <0.0112

 <0.02

 <0.02

 «3.02

 <0.02
<0.02

<0.092

<0.02

<0.02

<0.02

<0.02
                                   57

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                TABLE B-4 KEPONE WIPE SAMPLES 2/22/77
Sample//   Description









  43    kiln rm. walls




  44    kiln rm. floors




  45    mixing rm. floor




  46       	*



  47




  48    mixing rm. walls




  49    mixing rm. floor in area of spill




  50    hall floor




  51    change rm. floor




  52    sampling platform floor




  53    sampling platform walls




  54    operation & control room floor




  55    operation & control room walls




  56    laboratory floor




  57    laboratory walls




  58    locker room floor




  59    locker room floor CLEAN
Wipe Sample     Level of
/micrograms \
\ 1125cmz /
^» ~
0.0015
0.0024
1.56
ND
ND
0.36
L 1.8
0.78
0.0134
0.186
ND
ND
ND
ND
ND
ND
0.3
Contamination
(microgms/sq . f t .
0.0012
0.0020
1.29
ND
ND
0.30
1.5
0.64
0.0110
0.153
ND
ND
ND
ND
ND
ND
0.2
  *Sample identification lost in transit.
                                   58

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                TABLE B-5 KEPONE WIPE  SAMPLES  2/25/77



Sample//   Description                    ,Wlpe Samplex
	   ,	                    / micrograms
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
kiln rm. walls
change rm.
change rm.
	
hall walls
mixing rm.
mixing rm .
floor
walls


walls
floor
kiln rm. floor
locker rm.
locker rm.
shower rm.
laboratory
laboratory
shower rm.
	
control rm
samp, plat
samp, plat
control rm
floor
walls
floor
walls
floor
walls

. floor
. floor
. walls
. walls
   Level of

Contaminat ion
1125cm2 / (microgms/sq.ft.
* •** ~"
0.17
0.17
0.00008
0.4
0.00008
0.00048
0.00252
0.00004
0.02
ND
0.00005
ND
ND
0.00005
0.00002
ND
ND
ND
ND
0.14
0.14
0.00007
0.3
0.00007
0.00040
0.00208
0.00003
0.02
ND
0.00004
ND
ND
0.00004
0.00002
ND
ND
ND
ND
                                   59

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                TABLE B-6 KEPONE WIPE SAMPLES 3/1/77




Sample//   Description                     Wipe Sample    Level of
/ micrograms \ Contamination
\ il25cm^ / (microgms/ sq.ft.
79
80
81
82
83
84
85
86
' 87
88
89
90
91
92
93
94
95
96
97
samp. plat, floor 0.08
control rm. walls
locker rm. floor
locker rm. walls
shower rm. floor
shower rm. walls
samp . plat . walls
control rm. floor
lab floor & counter (northside)
lab trailer Southside (office)
change rm. floor
change rm. walls
VOID
hall floor
hall walls
mixing rm. floor
mixing rm. walls
kiln rm. floor
kiln rm. walls
0.05
0.13
0.13
0.26
0.40
0.06
0.08
0.13
0.26
12.4
0.52
-
43.3
1.6
36.6
3.66
3.0
1.4
0.07
0.04
0.11
0.11
0,21
0.33
0.05
0.07
0.11
0.21
10.1
0.43
-
35.8
1.3
30.1
3.01
2.5
1.2
                                  60

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                TABLE B-7 KEPONE WIPE SAMPLES 3/3/77

Sample//   Description                     Wipe Sample     Level of
                                         / micrograms \ Contamination
                                         ^  1125cm2  I (microgms/sq.ft.)

  99    change rm. floor                     ND            ND

 100    hall floor                          1.89          1.56

 101    hall walls                          0.04          0.03

 102    mixing rm. floor                    3.3           2.7

 103    mixing rm. walls                    0.2           0.2

 104    kiln rm. floor                      0.3           0.2

 105    kiln rm. walls                      0.05          0.04
                                   61

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                TABLE B-8 KEPONE WIPE SAMPLES 3/7/77

Sample//   Description                    Wipe Sample     Level of
                                       /micrograms\  Contamination
                                       {    1125cm2  ) (microgms/sq.ft.)

 106    hall floor                        <0.01           <0.01

 107    mixing rm. floor                  -*0.01           <0.01
                                 62

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APPENDIX C.  LABORATORY EQUIPMENT AND SUPPLIES ON SITE

Laboratory Equipment

     The laboratory equipment that was  transported  to the site consisted
of the following items:

     Gas Chromatograph - Hewlett Packard Model 5700 series equipped with
a Ni*>3 electron capture detector and a  Hewlett Packard Model 3380A Inte-
grator for both peak area determinations and for the preparation of a hard
copy of the chromatogram.

     Gas chromatographic columns of pyrex glass  (180 cm long x 4 mm ID)
packed with:

     a.   5% OV-210 on gas chrom Q  (100-120 mesh)

     b.   1.5% OV-17 + 1.95% QF-1 on gas chrom Q (100-120 mesh)

     c.   3% OV-210 on gas chrom Q  (100-120 mesh)

     d.   10% OV-1 on chromosorb-W  (AW).

     Concentrator - An elevated  (45°C)  evaporator using a gentle (5-10 ml/
min) stream of dry nitrogen gas.

Assorted Glassware -

     a.   Graduated cylinders, 10,  50,  250 ml - one dozen each

     b.   Erlenmeyer flasks with ground glass stoppers:  25, 50, 10&, 250,
          500 and 1000 ml - one dozen each

     c.   Separatory funnels with teflon stop cocks:  50, 125, 500, 1000
          and 2000 ml - six of each

     d.   Pipets - Pasteur, glass disposable, 1, 2, 5, 10 ml - 6 dozen of
          each

     e.   Evaporative flasks and test tubes - graduated 15, 50 and 250 ml -
          two dozen of each

     f.   Microsyringe, 10 yl - six dozen

     g.   Tweezers, spatulas, etc., teflon coated

     h.   Glass columns with fritted discs and reservoirs.

     Reagents, Solvents and Standards

     a.   Benzene, methanol, hexane, isoctane, petroleum ether, diethyl
                                     63

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          ether (all pesticide grade, glass distilled)

     b.   Sodium sulfate Fisher Certified, granular, anhydrous

     c.   Florisil, activated

     d.   Sulfuric and hydrochloric acid, Fisher Certified (ACS)
          extracted with benzene

     e.   Sodium hydroxide l.ON (ACS) pre-extracted with benzene

     f .   Triple distilled water

     g.   Reference Materials:

          1.   Kepone, hexachlorobenzene, hexachlorocyclopentadiene}
               mono and dihydro Kepone, reference grade all provided
               by U.S. EPA

          2.   Stock standard Kepone solutions - 200 yg/ml in 98%
               benzene + 2% methanol (EPA)

          3.   1 yg/yl in benzene from anhydrous Kepone used as
               secondary reference

     h.   Working standard solutions of Kepone and possible degradation
          products
                   *
            5
           10 pg/yl
           30 pg/yl     all in 99% benzene + 1% methanol
           50 pg/yl
          100 pg/yl
* pg = 1 x 10~12 gm.
APPENDIX D.  PRE-BURN EXPERIMENTAL PROTOCOL

Incineration Test Program Objective

     The proposed incineration test program will establish procedures for
the incineration of the Kepone contaminated sewage sludge at the lagoon in
Hopewell, Virginia.  It will also help establish public confidence in pro-
grams for the incineration of Kepone and Kepone contaminated substances.

The following information regarding the incineration of Kepone and Kepone
contaminated substances will be studied by this program.*

The effectiveness of incineration to destroy Kepone (and its hazardous by-
products) at various time-temperature combinations and Kepone concentrations.
                                     64

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The effectiveness of Incineration to produce a residue  free  from Kepone
(and its hazardous degradation products) which can be safely disposed
of by normal means.

Parameters for sludge decontamination and  incineration.

Parameters for equipment design.

Background Technology

     General - The following summary of information applicable to this in-
cineration test provides the background for the technology to be employed
in this incineration test.

Laboratory Evaluation of High Temperature  Destruction of Kepone and Re-
lated Pesticides —

                  University of Dayton Research Institute
                       D. S. Duvall arid W. A. Rubey
                                 May 1976

Abstract — The serious problems concerning the Kepone Manufacturing opera-
tions in the Hopewell, Virginia area have  been widely publicized.  Disposal
problems and environmental cleanup associated with Kepone being found in
soil, water, sewage sludge, etc., have been substantial.  Thermal disposal
was considered to be a primary means for solving this disposal problem.
However, basic high-temperature data on Kepone were lacking; accordingly,
the objectives of this study were directed to provide necessary information.

This study was concerned with thermal destruction testing conducted with
three pesticides:  Kepone, Mirex, and DDT.  A specialized laboratory tech-
nique incorporating a two-stage quartz system (vaporization  first, then
high-temperature exposure) was developed.  It is important to note that in
this system the pesticide was first converted to the gas phase, then ex-
posed to the high-temperature destruction  conditions.  Critical parameters
of temperature and residence time were accurately measured.  Both the Ke-
pone and DDT molecules, at a residence time of 1 sec, were essentially de-
stroyed at 500°C; however, Mirex, at the same residence time, required
700°C for destruction.

EPA's Chemical Waste Incineration Program  by John Schaum and Alfred Lindsey,
1975.

Engineering Feasibility Report - Destruction of Kepone Contaminated Waste
in the Lagoon located at the Hopewell Sewage Treatment Plant by Design
Partnership, May 20, 1976 0

Conference - Toledo, Ohio, 23 June 1976 -  This meeting between representatives
from EPA, the State of Ohio, the City of Toledo, D. P. Versar, Inc., and
Surface Division, Midland-Ross dealt with  the activities related to the
incineration test of Kepone in Toledo and  public reaction c
                                      65

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Conference - Washington, DC, 8 July 1976 - This meeting held at EPA was
attended by representatives of EPA, the Commonwealth of Virginia, the
State of Maryland, University of Dayton Research Institute, Allied Chemical,
and D. P. Versar, Inc..  The purpose of the discussion was to share tech-
nology concerning the thermal destruction of Kepone.

Project - 437 - 1973 - Research of Pesticide Disposal by Sewage Sludge
Incinerators by Versar, Inc.

Project - 465 - 1975 - PBC Incineration by Versar, Inc.

Project - 454 - 1974 - Microeconomic Analysis for Selected Toxic Substances
by Versar, Inc.

Project - 474 - 1974 - Microeconomic Study of Various Toxic Substances by
Versar, Inc.

Project - 461 - 1975 - Gas Stream Sampling by Versar, Inc.

Project-464 - 1975 - Water and Waste Water Analysis by Versar, Inc.

Determination of Incinerator Operating Conditions Necessary for Safe Disposal
of Pesticides by Thomas L. Furguson, Fred J. Bergman, Gary R. Cooper, Ray-
mond T. Li and Frank I. Honea - EPA-600/2-75-041

Summation of Conditions and Investigations for the Complete Combustion of
Organic Pesticides by Boyd T. Riley, Jr. EPA-600/2-75-044

Authority, Participants, and Observers

     The incineration test is being done for the Kepone Task Force of Vir-
ginia.  Due to the nature of the chemical involved and the concern with
public and environmental safety, the incineration test program will be under
the direction of the Test Burn Authority.

Incineration Test Authority — The Incineration Test Authority will be made
up of officials from the Commonwealth of Virginia,  EPA/MERL,
Toledo Pollution Control Agency, EPA Region V and Ohio EPA.

The Authority will have the following responsibilities:

     Direct the test program and authorize decisions required during the
     test progression.

     •  Interface with regulatory agencies.

     •  Prepare and authorize all press releases.

        Transport and dispose of residues.

     •  Assure the public safety.
                                     66

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The Incineration Test Management Group — The Incineration Test activities
are under the direction of Design Partnership, Inc., consultants to the
Kepone Task Force.  The consultants have arranged for Surface Division,
Midland-Ross to provide the incineration test facilities and Versar, Inc.,
to provide testing and laboratory services.  Representatives of these firms
will form the Incineration Test Management Group with the following structure:

     •  The Project Manager will be from Design Partnership and will be in
        overall control of the project.

     •  The Operations Manager will be from Surface Division, Midland-Ross
        and will be in charge of incineration operations.

     •  The Sampling and Testing Manager will be from Versar, Inc., and be
        responsible for all sampling and laboratory work.

     •  Industrial Hygienist

     The Incineration Test Management Group will have the responsibility and
authority for the following aspects of the project:

     •  Safety and Hygiene on the incineration test site.

     •  Burn procedure.

        Documentation.

Observers — Other people, agencies, and organizations interested in the
incineration test will be considered visitors and observers and will be
admitted only by invitation of the Incineration Test Authority.

Description of Facilities

     The Incineration test will be done at the Research Laboratory of Sur-
face Division, Midland-Ross in Toledo, Ohio.

Incineration Equipment — The following equipment is available in the Re-
search and Development Laboratory:

Rotary kiln pyrolyzer — The Rotary Kiln Pyrolyzer is five feet in diameter
and 10 ft long.  It rotates at 1 rpm and has capability for continuous load-
ing and unloading as well as two hatches for batch loading and unloading.
It is heated directly by hot gases and from a 1 MM BTU/hr capacity burner.
Charge and discharge connections for the hot gases have rotary seals to
prevent leakage of gases into or out of the kiln.  The kiln can be operated
at about 1000°F.

Fume incinerator (high temperature afterburner) — The Fume Incinerator to be
used for the pilot tests is equipped with two 500,000 BTU/hr capacity throat
mix burners.  The residence chamber volume is about 30 ft^.  The incinerator
is furnished with temperature controller and high limit safety shut-off
                                      67

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instrumentation.

Quench — Quench is used to cool the gases from the incinerator by evapora-
tive cooling.  It is equipped with recirculation tank, pumping system, and
spray nozzles.  Emergency cooling water spray nozzle is also provided.

Scrubber — Scrubber is a 30-in. diameter tower packed with 2-in. intalox
saddle plastic packings.  The packed bed height is about 6 ft.  Scrubbing
is done by 18% caustic solution flowing counter current to gas stream.  The
scrubber is equipped with I.D. fan and recirculation tank.  Scrubbing fluid
pH is controlled by adding caustic solution.  Liquid level in the recircu-
lation tank is maintained by adding make-up water.  A controlled quantity
of liquid is purged from scrubber to a brine retention tank continuously.

Sampling and Analysis Equipment —

     The following equipment is either available at the Research and Develop-
ment Laboratory, or will be brought to the site by Versar, Inc.:

     1.   02, CO, C02, and Hydrocarbon Analyzers (available)

     2.   The gas chromatograph and its related equipment which includes a
          Hewlett Packard Model 5710A gas chromatography system and a Fisher
          Model 5000 integrating recorder.  The gas chromatograph is equipped
          with an electron capture detector (Ni^3).  TWO types of columns
          are used:  A nonpolar 3% OV-1 on 100-200 mesh gas chrom  Q.
          Moderately polar, i.e., 1.5% OV-17 + 1.95% OF-1 on 100-200 mesh
          gas chrom Q.

     These columns have been tested with analytical standards of Kepone and
HCB standards and have been found to be heat stable, efficient and to have
good resolving power.

     3.   RAC Staksampler, control unit, sampling box with stainless steel
          sampling probe and pitot assembly and all the assorted glassware.

     4.   The feed assembly including pump, feed lines and injection probe.

Facilities —-

     The facilities on location will include the incineration test facility,
a sample testing laboratory, a conference room, and a temporary office for
the use of the Incineration Test Authority and the Incineration Test Manage-
ment Group.

Sample Transportation

Pure Kepone — Pure Kepone will be transported to Toledo, Ohio, in double
sealed containers.
                                      68

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Keoone Contaminated Sludge —

     Kepone contaminated sludge will be  supplied by  the Kepone Task Force of
Virginia.  The sludge will be loaded in  sealed drums at the lagoon in Hope-
well, Virginia and transported to Toledo, Ohio.  The sample will be two 55-
gal drums (30 - 65% solids, 0-57 ppm Kepone).

Blank Sludge —

     Blank sludge will be obtained  from  a sewage treatment plant in the Toledo
area and transported to the site.

Incineration Test Program

     The critical aspect of the proposed program lies in  the cumulative toxic
nature of Kepone which imposes the  necessity of absolute  assurance that there
is no loss of this material to the  environment as a  result of these tests.
The absolute sensitivity of the analytical methods available are very high:
Specifically, the gas-chromatograph electron capture detector (G.C.E.C.) is
capable of unambiguous detection of 2  -  3 x 10"^  gm of Kepone.  Thus, by
suitable selection of the size of the  samples that are taken from the
emergent streams from the incinerator, highly sensitive observation of all
residual matter may be made.

     The stack exhaust stream is the only uncontrollable  output stream from
the incinerator and hence represents the critical path to the environment.
In the absence of a published emission standard, it  is proposed to adopt the
criterion of safety as being an emission (at stack temperature) not to exceed
1 x 10~" gm/m-*.  This factor is such that, on dispersion  and dilution in
the atmosphere, the resulting ambient  air concentration would be less than
2.5 x 10~° gm/nr (this latter concentration has been taken to be the interim
permissible limit to be used until  promulgation of a suitable standard) when
account is taken of the dilution factor  of 40 or more.
*The hot polluted stream from the stack ejected into the surrounding air
creates considerable turbulence, which with the natural mixing due to air
currents, causes rapid dilution and mixing of the emergent plume.  Under
these circumstances, according to Smith^^, the concentration of any given
pollutant appears, at least initially, to decrease exponentially with the
distance from the point of emission, according to the empirical equation
                             C(x) = C(o)K x-p
where x is the  (downwind) distance, K is a parameter that describes the source
and the nature  of the specific pollutant, and p is a parameter varying be-
tween 1.5 and 2.  Since the values of K can vary between 0.1 and 10, it is
seen that the concentration at a point 100 ft downwind would be of the order
of 1 percent of that at the stack.  More complex descriptions have been given,
but the general result is much the same as that from Smith.  See also Cadle(2).
(1)  Smith, M.E., "Chemical Reactions in the Atmosphere."
     Interscience, New York, 1961.
(2)  Cadle, R.D., "Particle Size." Reinhold. New York, 1965, pp. 267 ff.
                                      69

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Initial Program --

     The initial phase of the program is designed to determine the efficiency
of combustion of Kepone under conditions that guarantee complete safety.  This
phase consists of conducting a series of tests with the injection of Kepone
solutions directly into the duct leading from the kiln to the fume incinera-
tor.

Initial test — The initial test will involve the injection, upstream of the
fume incinerator, of Kepone solutions at a rate of 2.5 x 10~5 gm/min which is
sufficiently low that, even in the absence of any combustion, the emergent
stack stream concentration would not exceed the criterion emission level.
Sampling of the stack stream will be carried out such that levels of less
than 1 percent of the criterion emission level will be detectable.  After
suitable assurance that combustion is complete, additional direct injection
tests will be conducted at increasing concentrations until it is clear that
conditions existing with the fume incinerator are such as to completely com-
bust the Kepone.  On the completion of these preliminary low level tests the
program will proceed to larger scale studies with sewage sludge.

     Kepone solution will be injected into the duct at a rate that will in-
sure that, even in the absence of combustion, the emergent (stack) level
will not exceed the criterion level of 1 x 10~6 gm/m^.  During this test the
fume incinerator will operate at 2300°F  while samples of particulate and
gaseous matter are conducted.

Follow-up tests — Upon the successful completion of the initial test(by
successful, it is meant that the emergent Kepone level is less than 1 per-
cent of the permissible level) additional tests will be conducted at in-
creasing Kepone levels as follows:

Test           Temp. (°F)          Time (sec)          Rate (gm/min)

 1                2300                 2               2.5 x 10~5

 2                2000                 2               2.5 x 10~5

 3                2000                 2               2.5 x 10~2

 4                2000                 2                    25

 5                2000                 1                    25

 6                1900                 1                    25

     In each case, triplicate stack samples, taken in sufficient volume
to allow detection of 1 percent of criterion emission rate, will be analyzed
before the next test is conducted.

     In all cases following the initial test, samples of all aqueous streams
will also be taken for analysis.
                                      70

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Consultation — At the completion of the analyses for each test, a decision
by the Incineration Test Authority will be made as to the safety in pro-
gressing to the next test.

Kepone injection — As indicated in Section 5 the Kepone solutions will
be injected into the hot gases from the kiln at some convenient point before
entry into the fume incinerator.  A stainless steel nozzle assembly will be
fabricated and will project through the wall into the duct.  The assembly will
be provided with leak-tight seals at the point of entry.  Kepone solutions
will be introduced through a metered peristaltic pump from a closed reservoir
at rates as indicated below:

     Test 1-10 ml/min of solution containing
              2.5 x 10~3 gm/liter of Kepone

     Test 2-10 ml/min of solution containing
              2.5 x 10~3 gm/liter of Kepone

     Test 3-10 ml/min of solution containing
              25 gm/liter of Kepone

     Test 4 - 200 ml/min of solution containing 125 gm/liter of Kepone
          5   Same as 4
          6   Same as 4

     The above tests will require a total of 80 liters of solution made up
at 125 gm/liter of Kepone in NaOH solution (approximately 22 gal).

     The feed line external to the furnace injection line will be of tygon
which will be incinerated at the completion of tests.

Pilot Scale Test —

     On the successful completion of the preliminary test, attention will
turn to practical scale tests.  In each case all emergent streams will be
sampled during the1 run and advancement to the next step would be conditional
upon satisfactory completion of the previous step.  In all cases, the emission
will be the controlling factor.

     The specific practical scale program will be as follows:

     *  Sludge blank - some 1,000 Ib wet weight (18% solids) of sludge ob-
        tained locally will be incinerated.

     •  Hopewell sludge - some 500 Ib wet weight (18% solids) of Hopewell
        sludge containing up to 500 ppm (dry weight) will be incinerated.

     •  Doped sludge - 1,000 Ib wet weight; (18% solids) sludge obtained
        locally will be doped to the level of 25% dry weight Kepone and
        will be incinerated.
                                      71

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        Doped sludge - 1,000 Ib wet weight (18% solids) of sludge obtained
locally will be doped to the level of 50% dry weight Kepone and incinerated.

     In each case the sludge will be injected by Moyno pump at a rate of 100
Ib/hr of sludge.  Each run will be of sufficient duration as to allow tripli-
cate (quadruplicate for the sludge containing Kepone) stack gas sampling.  In
addition, periodic samples of the scrubber liquor and the scrubber water will
be taken.

Sampling and Analysis

     As in the case in all situations wherein it is necessary to sample
streams of gases of liquids, the size of the sample and the method whereby
it is taken are established by the dual requirements of allowable levels of
the particular contaminant and the ultimate sensitivity of the analytical
method.

     In the case of Kepone, the final detection and quantitation step ex-
hibits an ultimate detectivity of 2 to 3 x iO~^ gm.  If provision is made
for analytic recovery during the extraction and concentration phases, the
practical ultimate detectivity is taken to be 5 x 10~12 gm.  This latter,
practical detection limit, will be used in what follows.

Air Stream Analyses —

     It is proposed that the primary monitoring point in the incineration
system be the emergent stack.  Air stream analysis will be accomplished with
a full EPA Method Five sampling procedure.  The (heated) sampler probe will
be operated along two mutually perpendicular traverses with full provision
for isokinetic sampling.  The impinger train will utilize a glass cyclone
and .045 micron glass fiber filter assembly followed by the conventional four-
bottle impinger train.  The non-particulate impinger solution (confined to
the first two impingers) will be 1.0N NaOH in deionized distilled water.
Drying of the gas stream before metering will be accomplished by indicator
DrieriteW.  The metering equipment will be the RAG stacksampler assembly.

     As an additional safety feature, in order to produce essentially real
time analyses, the first of the triplicate gas stream samples will be taken
with the RAG impinger train modified so as to introduce a small cartridge
packed with 10 to 20 gm of uncoated, washed and heat activated Chromosorb
101 absorbent interposed between the 0.45-micron filter and the first impinger
bottle.  Although this method does not have the force of extensive use, it
does offer the great convenience that subsequent to sampling, the cartridge
may be removed, the adsorbed chloro carbons removed by hexane washing and
immediately analyzed by chromatography.  This method has been shown to be
applicable for chlorinated hydrocarbons to levels of the order of 15 ppt(*)
*Mann, J. B., Enos, H. F., Gonzales, J., and Thompson,
J. F. Environ. Sci. and Techno., 8, 584 (1974).
                                      72

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(2 x 10~8 gm/m3) and will be used to get a quick check of the levels of Kepone
and also of the principal chlorinated hydrocarbons  (hexachlorobenzene, for
example)** in the exhaust stream.

    If the observed levels are acceptable, then the  test will be continued
for sufficient time to allow two additional  samples  to be collected by the
more traditional NaOH impinger train.

Air stream sample volume — As suggested above, the  criterion advanced for the
distribution between a successful and an unsuccessful test is a Kepone level
of not more than 1 x 10~6 gm/m3  (at stack temperature).  The analytical method
used for Kepone (see Section 7  ') is found to have an absolute detection
limit ^ 5 x 10~12 gm of Kepone.  Since the sample extraction procedure re-
sults in a final concentrated sample volume  of 0.5 cm3 and the normal injec-
tion volume is 10 A (10-2 Cm3)t  it is then necessary to collect a total of
2.5 x 10"   gm Kepone from the sampled gas stream    Thus, processing aim3
gas sample (^ 0.8 m3 at box temperature) should yield a total Kepone sample
of the order of 40,000 times the detection limit if  the level in the gas
stream were at the criterion level of 1 x 10-6 gm/m3.  To put this in a
slightly different way, the detection limit  is 0.0025 percent of the crite-
rion level.

Other Emergent Stream Samples —

    In addition to the primary samples (the  stack gases) it will be appro-
priate to also sample the following on a routine basis:
    — The emergent quench water
    — The emergent scrubber water
    — The ash from the kiln

Additional samples — It will be necessary to sample all charges to the kiln
before the pyrolysis of those samples.  In addition, background analyses will
be made of the feed water and of any other material  admitted to the furnace
system.  Further, environmental samples from within  the prototype facility
will be analyzed on the completion of the experimental program - this to aid
in any clean up that may be required.

Analytical Method —

    Initial sample preparation —  Non-aqueous samples, if they are organic
in nature, are first macerated with an equal weight  of isopropanol and then
with benzene and anhydrous sodium sulfate.   After being allowed to equilibrate
for 12 hr, the filtered extract is evaporated to dryness by impinging a
stream of purified air on the surface of the liquid.  The resulting residue
is treated in a manner similar to inorganic  specimens.

    The dried residue or inorganic matter is transferred to a separatory
**Duvall, D. S., and Rubey, W. A. Private Communication.
                                      73

-------
funnel with small volumes of N-hexane to make a total volume of 100 ml to
which is added 25 ml 1:1 oleum mixture.  Shake vigorously, allow layers to
separate and discard the lower layer.  Repeat the process several times,
finally washing hexane layer with 10 ml concentrated sulfuric acid, followed
by 5 ml water.  Discard all washings.

    Extract the dried hexane layer with 100 ml 0.1 M sodium hydroxide three
times, combining the aqueous sodium hydroxide extracts in a 500 ml separatory
funnel .

Analysis of NaOH solution of Kepone — Add few drops of phenolphthalein
solution to the aqueous extracts in the 500 ml separatory funnel.  Add 9M
sulfuric acid until the end point (colorless) is reached.  Add a few ml of
9M sulfuric acid to insure an acidic solution.  Extract this acidified
solution with 150 ml of benzene.  After the phases have equilibrated, draw
off the lower (aqueous) phase and discard.

    Filter the benzene through a bed of anhydrous, granular ^2864 into a
300 ml flask.  Wash both the funnel and the filter bed with benzene and
washings added to the flask.  Evaporate the extract on a steam bath under a
stream of nitrogen until fumes remain.  After cooling, and the vapors con-
dense, wash the walls of the flask with ethyl ether.  Transfer quantitatively
to a graduated cylinder with small portions of ether.  Evaporate the solvent
on a steam bath under a stream of nitrogen to approximately 0.3 ml.  Determine
the exact volume.  Transfer the concentrate to a small stoppered vial and
freeze until analysis.

    The final step involves the injection of a 5 to 10 y aliquot of the con-
centrate into an Electron Capture G.C. System with the following charac-
teristics:
    Electron Capture detector using
    Column of either
          10% DC-200 + 15% QF-1 or
          1.5% OV-17 + 1.95% QF-1 on 100/120 GCQ
          Carrier gas:  95% Argon + 5% methane
          Gas flow: 4-55 ml/run
          Injection port:  200?C
          Oven temp (isothermal) : 220°C
          Detector temp: 250 C

    A typical chromatogram derived in our laboratories of Kepone indicates
a retention time of the order of 10.6 min and an ultimate detectivity on
the order of 2.5 x 10~12 gm.

Kepone combustion products — Although the full spectrum of possible inter
mediate combustion productions of Kepone has not been determined, it is
known that hexachlorobenzene is one of the principal products.
                                      74

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Operating Variables —

    In addition to Kepone and chlorinated hydrocarbon analysis of the discharge
streams from the incinerator, it will also be necessary to collect the
following parametric data:

    Sludge feed rate
    Kepone feed rate
    Kiln temperature
    Air and gas flow to the kiln burner
    Flow of gases from the kiln
    Analysis of gases from the kiln
    Pressure in the kiln
    Temperature in incinerator
    Air and gas flows to incinerator burners
    Auxiliary gas flow to the incinerator
    Effluent gas flow from the incinerator
    Quench liquid flows
    Make-up water flow to quench
    Temperature of stack gases
    Scrubbing liquid flow
    Caustic addition flow
    Purge brine flow from scrubber
    Temperature of gases from quench
    Pressure of gases from quench
    Flow of gases in the stack
    Temperature of scrubbing liquid

Proposed Schedule

    In the interest of efficiency and to minimize furnace operation times,
it  is proposed that the study be carried out on an essentially two-shift
basis:  the daytime devoted to the actual combustion runs and the necessary
sampling and the night shift devoted to analysis.  The field operations will
take the following form:
    Week  1
          Mon./Tues.      1st  injection  run;  sampling/analyses
          Wed./Thurs.     2nd  injection  run;  sampling/analyses
          Fri./Sat.       3rd  injection  run;  sampling/analyses
    Week  2
          Tues./Wed.      4th  injection  run;   sampling/analyses
          Thurs./Fri.     5th  injection  run;   sampling/analyses
    Week 3
          Monday          6th  injection run;   sampling/analyses
                                       75

-------
          Tuesday        Sludge blank run;  Sampling/analyses
          Wednesday      Hopewell contaminated sludge sampling/analyses
          Thursday       Hopewell contaminated sludge sampling/analyses
          Friday         Toledo sludge @ 25% Kepone
    Week 4

          Monday         Toledo sludge @ 25% Kepone
          Tuesday        Toledo sludge @ 50% Kepone
          Wednesday      Toledo sludge @ 50% Kepone
          Thursday       River sediments
          Friday         Recap meeting

    Week 5

          Monday/Friday  Clean up

Residual Disposal

    Except, of course, for emissions to the air any material at the end of
the test that cannot be disposed of locally due to public health considera-
tions will be transported to Hopewell, Virginia, for disposal.

Emissions to the Air —

    As described previously all air emissions will be constantly monitored.
The test program is designed to ensure that the level of Kepone if emitted
will not reach the maximum level of 1 x 10~6 gm/m^ at stack temperature.

Solids and Liquids —

    Ashes and scrubber liquor will result during all incineration tests of
sludge.  When pure Kepone is incinerated, there will be no ashes.

    All liquid and solid residues resulting from the incineration tests will
be either re-incinerated or repackaged and transported to Virginia for dis-
posal.

Laboratory Residuals —

    Same procedures as Solids and Liquids

Spillage and Clean-Up—

    Minor spills should they occur will be mopped up.  Liquid will be trans-
ferred to the liquid retention tank and rags, etc., will be stored in a
Contaminated-Material Container (CMC).  Major spills should they occur will
be absorbed in dry compound.  The sweepings will again be placed in the CMC.

    All disposable gloves, etc., will be placed in the CMC.
                                     76

-------
    Testing program will include incineration of the CMC as part of the
clean-up after incineration tests.

Equipment Clean-Up —

    After the incineration test program is complete all equipment and resi-
duals contaminated during the process will be either incinerated or cleaned
with NaOH (which will put Kepone in a solution) for ultimate disposal.

    The equipment to be cleaned includes the following:

          Moyno pump (stator and rotor) used to pump the sludge
          Feed pipe and mixing tank for the sludge
          Rotary kiln
          Duct between the rotary kiln and the afterburner
          Scrubber tower and piping
          Quench and pumps
          Brine retention tanks
          Safety equipment (gloves, respirators, clothing, etc.)

Safety and Hygiene

    The prime consideration during the incineration test will be to protect
the personnel, the environment, and the public from being exposed to this
compound.  To ensure safety the measures included in this section will be
followed in addition to those normally used.

Incineration Test —

    The personnel at the testing facility are experienced with the handling
and burning of toxic and other dangerous chemicals.  Such work has been
done and safety procedures are already established.

    In order to inform the operating and management personnel about Kepone
and recommend handling procedures a medical briefing will be conducted by
personnel from the Commonwealth of Virginia, Department of Health at the site
prior to the incineration test program.

    Only operating and management personnel directly involved with the
incineration test operation will be allowed in either the incineration test
or laboratory areas.  Before and after the incineration test they will be
subjected to blood tests to determine if any residual Kepone exists.

    Isolation will be accomplished by organizing the incineration test area
and physical facilities such that only those persons whose duties necessitate
their presence are in areas where hazardous materials are handled.  Prepara-
tion for incineration tests and equipment readiness will be accomplished
prior to handling of Kepone or Kepone bearing materials or their introduction
into the incineration system.
                                      77

-------
     Kepone and Kepone bearing materials will be handled only in closed
systems or in the isolated area designated for mixing, feeding and storage.
The only normal entrance and egress to this area will be through a shower
area with a change of clothes required upon entry and a shower and change of
clothes required prior to leaving the area.

     There will be an emergency exit for life safety from this area and a
viewing port to allow observation during the handling procedures.

     The control and operation of the incineration and pollution control
equipment will take place in the designated area separated from the mixing,
feeding and kiln areas by barriers preventing air and other materials move-
ment.

     Equipment and surfaces in the incineration test area shall be covered
with strippable coverings or plastic film wherever practical.  All floors
in the incineration test area will be sealed with either paint or resin
sealants to facilitate cleaning.

     Areas within the incineration test area subject to spillage shall be
curbed to contain any foreseeable leakage.

     All personnel who have entered the incineration test area for any pur-
pose will shower before leaving the premises and will leave their clothing
including socks and underwear which was worn within the incineration test
area in designated lockers within the contaminated change room.  At the end
of the incineration test period this clothing will be incinerated.  Street
clothing will be stored in the clean locker room.

     Personnel protective equipment worn will be that which is deemed suit-
able for the job and conditions at hand by the Industrial Hygienists assigned
to the incineration test.  A list of suitable equipment is attached as Table
D-l.
                                      78

-------
                    TABLE D-l  PERSONAL PROTECTIVE EQUIPMENT
     Safety glasses with side shields
     Goggles - Sellstrom 882 Fog-free lens
     Respirators - Comfo II GMP Type, Part No.  448848,  MSA
     Cartridges (pesticide) GMP Type No.  448847,  MSA
     High gauntlet gloves,  MSA, Python Neoprene 37994
     Paper suits, Edmont-Wilson 55-510
     Rain gear, Edmont-Wilson, Coat & Hood 65-110,  Bib  Overalls  65-120
     Boots-Servus, Neoprene 11901,  steel toe
     Disposable boots (plastic)
     Paper boots (paper)
     Paper headcover
     Disposable towels - obtain locally
     Plastic bags (large) - obtain locally
     Bag rack - obtain locally
     Utility gloves, MSA, 37643 flexible plastic gloves

     The above are.  examples of equipment needed and does not  constitute
an endorsement of the products.  Substitution can be made on an  equivalent
basis.

     The actual number of pieces and sizes of equipment will be  determined by
Surface Combustion and will be reviewed at the meeting  on September  21, 1976,
in Cincinnati, Ohio.
                                      79

-------
Pure Kepone Transport and Handling —

     Since all the Kepone on the incineration test site will be in a liquid
solution, Kepone in the atmosphere (as with dust in the pure powder form)
will be minimized if not eliminated.  This means that the exposure to the
operating personnel will be the absolute minimum.

     The Kepone will be packaged and transported as previously described.
Kepone containers will be opened by authorized personnel wearing protective
clothing including respirator and goggles.  Containers will only be opened in
the incineration test area or the laboratory.

     Kepone spills are not anticipated.  If there are any, they will be
handled carefully and the clean up material disposed by the procedures des-
cribed in the section on residuals.

Air Sampling and Laboratory Personnel —

     Air sampling personnel and laboratory personnel will attend the medical
briefing and will undergo blood tests before and after the incineration test
program.  During all times of operation, personnel will wear protective
clothing, goggles and hard hats.  Whenever Kepone is handled, respirators
will be used.

Visitors —

     No visitors will be allowed in the incineration test area and laboratory
areas.

     During the incineration test, visitors will be able to observe the in-
cineration test operation via closed circuit TV from a monitor in the confer-
ence room.  A register will be kept of all visitors entering and leaving the
conference room.

Publicity and Communication

     Publicity and communication with regard to the incineration test will
be controlled by the Incineration Test Authority (ITA).  Under the direction
of the ITA, the Incineration Test Management Group will perform the following
activities:
     Escort visitors and inform them of the incineration test and sampling
operation.
     Interface with regulatory agencies.
     Coordinate the documentation effort.

Press Release —

     Press releases will be authorized by the Incineration Test Authority
and cleared through the Toledo Public Information Director.

     Prior to the incineration test,  Surface Division, Midland-Ross is
                                      80

-------
planning the following pre-incineration test news releases through the Toledo
PID:
     30 days prior to test - general newspaper article, science oriented, on
Surface Division work in hazardous waste disposal.
     15 days before test - general newspaper article, business oriented,
on Surface Division's new business venture  in hazardous waste disposal.

     After Kepone contract award and prior  to incineration test - newspaper
article to announce R & D program to demonstrate controlled incineration
technology for Kepone disposal.

     During and after the incineration test, Surface Division is planning
the following news releases with the approval of the Incineration Test
Authority:
     In process - announcement  that Surface Division engineers are working
with small quantities of Kepone.
     30 days after incineration test - Kepone incineration success story:
1977 - articles in technical journals.

Documentation

     The Incineration Test Management Group will be in charge of documentation
of  the incineration test program and results.

     The Operations Manager will report on  the technical aspects of the in-
cineration test, the equipment  used, and the residuals.

     The Sampling and Testing Manager will  report on the test results, on
the air samples, residuals and  Kepone inventory.

     The Project Manager will write a summary report (including other
aspects, such as transportation, safety and visitors).

     During the incineration test, daily oral reports will be made to the
Incineration Test Authority.  All day-to-day decisions will be based on
these reports.  Distribution of the data will be controlled by the
Incineration Test Authority.

     The Project Manager will prepare the final report for submission to the
Incineration Test Authority for submission  ultimately to the Virginia Kepone
Task Force.
                                      81

-------
              APPENDIX E. FURNACE AND INCINERATOR SYSTEM DATA
oo
                    N2
                  KEPONE
                 SOLUTION
                 INJECTION
                   TANK
SAMPLING
 PORTS
                FIGURE E -I'  KEPONE  INCINERATION  SYSTEM  SCHEMATIC

-------
                                                                                                                                      Sat. Temp 184 Deg. F
         JKS
         3-7-77
00
        3230-3730 SCFH Air
        340-400 SCFH Fuel
        6 - 6.5 GPH Water
Sludge
                                                                            Kepone 0.9 mg/l
                                                                            Acetic Acid (9 lit/hr) or 125 SCFH Gas
                                                                                  •n
                                                                                  Si
                                                                                  3)
                                                                                  00
                                                                                  C
                                                                                  3D
                                                                               (2300 Deg.
                                                                                   F)
                                                                              27,300 SCFH
                                                                                                 Air (20,000 SCFH)
                                                                                                 Fuel (1860-1910)
                                                                                                       Methane
                                               8
                                               30
                                               5
                                               CD
                                               m
                                               33
                                                         49,450
                                                                                                                          SCFH
                                                                  Fuel Air
                                                             Caustic 7.5 GPM

                                                             Water 1.99 GPM
                                                                            Res. Lime 2.15 sec.
            (a) Water in Kiln      1130 SCFH
            (b) Water from Fuel   4620 SCFH
            (c) Water in Scrubber 2_2,100SCFH
               TOTAL        27,850 SCFH (Maximum)

            Dry Gas (without leakage) = 21,600 SCFH
                                          FIGURE E-2    FLOW SCHEMATIC-KIT RUN NO. 1

-------
                                                                                                                                    Sat. Temp. 181 Deg. F
           JKS
           3-7-77
             Kepone 0.9 mg/hr
             Acetic Acid 9 lit/hr (125 SCFH)
oo
        3930-4835 SCFH Air
        325-370 Fuel
        5.5 - 6 GPH Water
              or
        960-1040 SCFH
                                                                                 >
                                                                                 •n
                                                                                 3D
                                                                                 CD
                                                                                 c
                                                                                 3D
                                                                                 z
                                                                                 m
                                                                                 3D
                                                                            27,710 SCFH
                                                                                               Air (20,000 - 20,300 SCFH)
                                                                                               Fuel (1355-1640)
                                                                                                     Methane       46,970 SCFH
                                                CO
                                                o
                                                CD
                                                CD
                                                m
                                                3D
Sludge
                                                                          Res. Time 2.38 sec.
              (a)   Water in Kiln      1040 SCFH
              (b)   Water from Fuel   4020 SCFH
              (c)   Water in Scrubber 19260SCFH
                   TOTAL         24320 SCFH

              Dry Gas (without leakage) = 22,650 SCFH
                                                                  Fuel Air
                                                                                                                           Caustic 5.6 GPH
                                                                                                                          Water 104.9 GPH
                                         FIGURE E-3   FLOW SCHEMATIC - KIT RUN NO. 2

-------
                                                                                                                                         Sat. Terrp. 180 Deg. F
           JKS
           3-7-77
oo
Ul
        (3615-4515) Air
        (155-175) Fuel
        6-6.7 GPH Water
              or
        (1040-1170 SCFH)
            I Kepone 0.9 gms/hr
            I Acetic Acid 9 lit/hr (125 SCFH)
                                                                                   •33
                                                                                   00
                                                                                   c
                                                                                   3D
                                                                                   m
                                                                                   3D
                                                                                                   Air (19,700-20.000)
                                                                                                   Fuel (570 - 690)
                                                                                                         Propane
                                                        46,680 SCFH
                                                 CO
                                                 o
                                                                                                                w
                                                                                                                CO
                                                                    Fuel Air
                                                                                                                               Caustic 6.0 gph
                                                                                                                              Water 103.8 gph
Sludge
                                                                             Res. Time 2.37 sec.
              (a)   Water In Kiln      1170 SCFH
              (b)   Water from Fuel   3460 SCFH
              (c)   Water in Scrubber 19140SCF_H
                   TOTAL         23770 SCFH
                                                                             Dry Gas (without leakage) = 32,910 SCFH
                                           FIGURE E-4   FLOW SCHEMATIC-KIT RUN NO. 3

-------
                                                                                                                                     Sat. Temp. 180 Deg. F
          JKS

          3-7-77
00
        (42104420) Air SCFH

        (175-180) Fuel

        6.5 - 7.5 gph Water
           I Kepone 90 gms/hr

           t Acetic Acid 9 lit/hr (125 SCFH)
                                                                                 m
                                                                                 3J
                                                                                 w
                                                                                 c
                                                                                 30
                                                                                 Z
                                                                                 m
                                                                                 3)
                                                                             (2000 Deg. F)



                                                                             26,975 SCFH
                                   Air (19,500 SCFH)

                                   Fuel (520-630) SCFK

                                         Propane     145,725 SCFH
                                              8
                                              ID
                                              CO
                                              m
                                              3J
                                                                                                                                   1
                                                                                                                               Fuel Air
                                                           - Caustic 4.0 gph


                                                           •Water 103.5 gph
Sludge
             or
        (1130-1310 SCFH)
                                                                           Res. Time 2.44 sec.
             (a)    Water in Kiln       1310 SCFH

             (b)    Water from Fuel    3240 SCFH

             (c)    Water in Scrubber  18750_SCF_H_

                   TOTAL          23300 SCFH


                   Dry Gas (without leakage) = 22,425
                                          FIGURE E-5    FLOW SCHEMATIC - KIT RUN NO. 4

-------
                                                                                                                                      Sat. Temp. 179 Deg. F
        JKS
        3-7-77
             Kepone 0 gms/hr
             Acetic Acid 0 lit/hr
00
        4330 SCFH Air
        178SCFHFuel
        5.7 gph Water (990 SCFH)
                                                                                  m
                                                                                  •Si
                                                                                  m
                                                                                  c
                                                                                  30
                                                                                  m
               (2000 Deg. F)

               27,630 SCFH
                                                                                                 Air (20,000 - 20,800) SCFH
                                                                                                 Fuel 575 SCFH
                                                                                                     Propane        46,830 SCFH
                                                                                                              CO
                                                                                                              O
                                                                                                              3)
                                                                                                              C
                                                                                                              CD
                                                                                                              CD
Sludge
                                                                           Res. Time 2.39 sec.
             (a)   Water in Kiln       990 SCFH
             (b)   Water from Fuel    3010 SCFH
             (c)   Water in Scrubber 1920p_SCjFH_
                  TOTAL         23200 SCFH

             Dry Gas (without leakage) = 23,630 SCFH
                                                                                                                                 Fuel Air
                                                                                                                           Caustic 0 gph

                                                                                                                           Water 110.1 gph
                                          FIGURE E-6   FLOW SCHEMATIC-KIT RUN NO. 5

-------
                                                                                                                                  61,520
          JKS
          3-7-77
              Kepone
              Acetic Acid
00
00
         (4140 - 7640) Air SCFH
         <212-345) SCFH Fuel
         5.9 - 9 gph Water
         (1030-1570) SCFH
                                                                                   m
                                                                                   •x
                                                                                   CD
                                                                                   c
                                                                                   30
                                                                               (2000 Deg. F)
                                                                               32,080 SCFH
                                                                             Res. Time 2.06 sec.
Sludge
0.16gpm
79 Ibs/hr water (1660 SCFH)
J^ Ibs/hr solids
76 Ibs/hr sludge (18% solids)
                                                                                                   Air (19,200 SCFH)
                                                                                                   Fuel (630-660) SCFH.
                                                                                                         Propane
                                                      54,370 SCFH
                                                        Sat. Temp.
                                                        183 Deg. F
                                                U)
                                                o
                                                30
                                                03
                                                CD
                                                m
                                                30
                                                                                                                                  Fuel  Air
                                                                                                                              27 SCFH 6960-7100 SCFH
                                                                                                                            Caustic 5.25 gph

                                                                                                                            Water 122.6 gph
(a)    Water in Kiln      3230 SCFH
(b)    Water from Fuel   4020 SCFH
(c)    Water in Scrubber 2227(>_SQF_H_
TOTAL               29540 SCFH

Dry Gas (no leakage) = 24,830 SCFH
out of Scrubber
Ibs of  H2O/lb of dry gas = 0.76
                                           FIGURE E-7   FLOW SCHEMATIC - KIT RUN NO. 6

-------
                                                                                                                                   57,400 SCFH
         JKS
         3-7-77
               Kepone - 0
               Acetic Acid •
00
           (6510-7265) SCFH Air
           (295-330) Fuel SCFH
           0 Water
                                                                                     m
                                                                                     •33
                                                                                     CO
                                                                                     c
                                                                                     30
                                                                                     m
                                                                                     3)
                                                                                (2100 Deg. F)

                                                                                29,070 SCFH
                                                                                  (Maximum)
                                                                                                    Air 18,500 SCFH
                                                                                                    Fuel (600-640) SCF
                                                                                                        Propane
                                                        50,380 SCFH
                                                         Sat. Tertp.
                                                         182 Deg. F
                                                  8
                                                  30
                                                  CD
                                                  CD
                                                  m
                                                                                                                                      o
                                                                                                                                   Fuel  Air
                                                                                                                                36 SCFH (6750 SCFH)
                                                                Caustic 5 gph

                                                                Water 117.2 gph (maximum)
                                                                              Res. Time 2.18 sec.
 Sludge (0.145GPM)
 1.05 Ibs Kepone/hr
14.60 Ibs Solids/hr
62.45 Ibs Water/hr
_8190Jbs Ac. Acid/hr
87.00 Ibs/hr (18% Solids)
(a)    Water in Kiln       1300 SCFH
(b)    Water from Fuel    3880 SCFH
(c)    Water in Scrubber  2_1J1P_SC_F_H_
TOTAL                26490 SCFH
                                                                                                    Dry Gas from Scrubber (no leakage) •
                                                                                                    Ibs of H2O/lb. of dry gas = 0.71
                                                                     23,890
                                            FIGURE E-S   FLOW SCHEMATIC-KIT RUN NO. 7

-------
                                                                                                                                57,035 SCFH
          JKS
          3-7-77
               Kepone- 0
               Acetic Acid - 0
vo
O
          (6700 - 6800) Air
          (255 - 260) Fuel
          0 Water
                                                                                     rr!
                                                                                     30
                                                                                     03
                                                                                     c
                                                                                     30
                                                                                     m
                                                                                     30
                                                                                                    Air (19,300-19,500)
                                                                                                    Fuel (530 - 600) SCFJi
                                                                                                        Propane
                                                        50,000 SCFH
                                                          Sat. Temp.
                                                          180Deg. F
                                                  8
                                                  30
                                                  03
                                                  CD
                                                  rn
                                                  3)
                                                                                                                                  Fuel     Air
                                                                                                                               43 SCFH  6950 SCFH
                                                                                                                              Caustic 0 gph

                                                                                                                              Water 117.9 gph (maximum)
                                                                              Res. Time 2.23 sec.
 Sludge 0.15 GPM
 0.54 Ibs/hr Kepone
15.66 Ibs/hr Solids
69.20 Ibs/hr Water (1450 SCFH)
_4J80Jbs/nr Acetic Acid (25 SCFH)
90.00 Ibs/hr (18% Solids)
(a)    Water in Kiln       1450 SCFH
(b)    Water from Fuel    3440 SCFH
(c)    Water in Scrubber  20500_§CJFH_
TOTAL               25390 SCFH
                                                                                                     Dry Gas from Scrubber (no leakage):
                                                                                                     Ibs Water/I b of Dry Gas = 0.66
                                24,610 SCFH
                                            FIGURE E-9   FLOW SCHEMATIC - KIT RUN NO. 8

-------
                                                                                                                         58,540 SCFH
JKS
3-7-77
                                                                    Kepone- 0
                                                                    Acetic Acid - 0
(6750 - 6850) Air SCFH
260 SCFH Fuel
0 Water
                                                                           •n
                                                                           m
                                                                           30
                                                                           co
                                                                           3D
                                                                           m
                                                                       31,190 SCFH
                                                                        (Maximum)
                                                                                           Air (20,500 - 21,000) SCFH
                                                                                           Fuel (540 - 590) SCF.H	
                                                                                                 Propane
                                                         51,670 SCFH
                                                           Sat. Temp.
                                                           179Deg. F
                                                                                                        30
                                                                                                        c
                                                                                                        00
                                                                                                        CO
                                                                                                        m
                                                                                                        30
                                                                                                                          Fuel  Air
                                                                                                                           60 6600-6750
                                                                 Caustic 0 gph

                                                                 Water 117.5 gph (maximum)
                                                                    Res. Time 2.20 sec.
  Sludge (0.167 GPM)
  0.6 Ibs/hr Kepone
 17.4 Ibs/hr Solids
  5.1 Ibs/hr Acetic Acid (30 SCFH)
_76.9Jbs/hr Water (1610 SCFH)
100.0 Ibs/hr (18% Solids)
(a)    Water in Kiln       1610 SCFH
(b)    Water from Fuel    3400 SCFH
(c)    Water in Scrubber 20480.SCFM.
TOTAL               25490 SCFH

Dry Gas from Scrubber (no leakage) = 26,180 SCFH
IDS H2)/lb of dry gas = 0.62
                                   FIGURE E-10    FLOW SCHEMATIC - KIT RUN NO. 9

-------
                                                                                                                                56,370 SCFH
           JKS
           3-7-77
Kepone
Acetic Acid
N>
            (6750-6500) SCFH Air
            255 - 257 Fuel
            0 Water
                                                                                     3)
                                                                                     CD
                                                                                     c
                                                                                     3>
                                                                                     Z
                                                                                     m
                                                                                     33
   (2000 Deg. F)

   29,220 SCFH
   (Maximum)
                                                                                                    Air (19.500-19,700)
                                                                                                    Fuel (530-600) SCF
                                                                                                         Propane
                                        49,520 SCFH
                                          Sat. Temp.
                                          179 Deg. F
                                                  3J
                                                  CD
                                                  CO
                                                  m
                                                  3J
                                                     Fuel  Air
                                                 53SCFH  6750SCFH
                                                                                                                               Caustic 6.5 gph

                                                                                                                               Water 110 gph
                                                                              Res. Time 2.26 sec.
 Sludge (0.133GPM)
 3.33 Ibs/hr Kepone
 8.67 Ibs/hr Solids
28.30 Ibs/hr Acetic  Acid (180 SCFH)
39-70Jbs/hr Water (830 SCFH)
80.00 Ibs/hr (15% Solids)
                      (a)    Water in Kiln       830 SCFH
                      (b)    Water from Fuel    3430 SCFH
                      (c)    Water in Scrubber ?0300J5CF_H_
                      TOTAL               24560 SCFH
                      Dry Gas from Scrubber (no leakage)
                      ibs H2O/lb of Dry Gas = 0.62
                                                                                                                                     24,960 SCFH
                                             FIGURE E-11    FLOW SCHEMATIC-KIT RUN NO. 10

-------
TABLE E-1
                                                          KIT RUN NO. 1
                                                                       DATE: 1-14-77
         Time
Variable
                                   1535
        1630
1700
1730
1830
                                                      1930
                                                                                                                                          COMMENTS
EUMEJ.ICJNIRATO.B.
Incinerator Tenp. {Deg. C)
Total Air Input (SCMH)
Gas Input @ Pilot No. 1 (SCWH)
Gas Input at Pilot No. 2 (SCMH)
Aux. Gas Input (SCMH)
Inlet Gas Temp. (Deg. C)
Stack Flow Rate (SCMH)
Air in Stack Burner (SCMH)
Pilot Gas to Stack Burner (SCMH)
Aux. Gas to Stack Burner (SCMH)
Stack Temp. (Deg. C)
% Oxygen in Stack
1260
560
8.54
8.54
36.40
456
1260
560
8.54
8.54
35.00
459
1260
560
8.54
8.54
_
—
1260
560
8.54
8.54
—
458
1260
560
8.54
8.54
...
411
1260
560
8.54
8.54
_.
407
                                                                                                    Methane
                                                                                                    Methane
                                                                                                    Methane
3.0
           4.5
 KILN.
 Burner Gas Temp. (Deg. C)
 Gas Discharge Temp. (Deg. C)
 Air Input to Burner (SCMH)
 Gas Input to Burner (SCMH)
 Water to Burner (l/min.)
 Compressed Air to Burner (SCMH)
 Compressed Air Press (kN/M2)
 Sludge feed (I/sec.)
 Kepone Solution (l/hr.)
 Kepone Solution Cone, (mg/l)
 Ash (kg)
 Draft in Kiln (cm W. C. )
1066
538
78.4
10.36
0.378
12.04
138
N/A
N/A
N/A
N/A
1016
532
78.4
9.52
0.410
12.04
138
N/A
N/A
N/A
N/A
—
—
—
_.
_
_.
—
N/A
N/A
N/A
N/A
1024
538
89.6
9.80
0.397
12.04
138
N/A
9
0.1
N/A
1015
543
92.6
11.20
0.397
12.04
138
N/A
9
0.1
N/A
1016
538
92.6
11.20
0.397
12.04
138
N/A
9
0.1
N/A
                                                                                                   Methane
                                                                                                   Methane

-------
TABLE E-l (continued)
         Time
Variable
                                  1535
1630
                                                         1700
                                                                    1730
                                  1830
1930
                                                                                                                                         COMMENTS
SCRUBBER
Brine to Fog Nozzle (I/sec.)
Brine to 2" Nozzle (I/sec.)
Brine to 1" Nozzle (I/sec.)
Brine to Cone (I/sec.)
Brine to Scrubber (I/sec.)
Caustic Tank level (cm)
Brine Tank level (cm)
Quench level (cm)
Caustic Flow (l/min)
Press @ Brine Pump (kN/M2)
Press @ Retention Tank (kN/M2)
Press @ Caustic Pump (kN/M
Scrubber pH

FEED STARTED® 1730
                       ,2,
0.441
3.02
0.945
2.52
1.44
310

255
62.1
62.1
9.2
0.416
3.02
0.945
2.71
1.47
302
0.57
262
62.1
62.1
9.2
0.416
3.09
0.945
2.71
1.47
300
0.38
262
55.2
62.1
9.1
0.441
3.09
0.976
2.71
1.51
297
0.38
255
62.1
62.1
9.1
0.441
3.09
0.976
2.71
1.51
292
0.38
255
62.1
62.1
9.1
0.441
3.09
0.976
2.71
1.51
286
0.47
262
62.1
62.1
9.0
FEED STOPPED® 1930

-------
       TABLE E-2
                                                                KIT RUN NO. 2
                                                                                                                   DATE:  1-15-77
VO
Ui
               Time
       Variable

       FUMEXNCJNERATOR
       Incinerator Temp. (Deg. C)
       Total Air Input (SCMH)
       Gas Input  Pilot No. 1  (SCMH)
       Gas Input @ Pilot No. 2  (SCMH)
       Aux. Gas Input (SCMH)
       Inlet Gas Temp. (Deg. C)
       Stack Flow Rate (SCMH)
       Air in Stack Burner (SCMH)
       Pilot Gas to Stack Burner (SCMH)
       Aux. Gas to Stack Burner (SCMH)
       Stack Temp. (Deg. C)
       % Oxygen in Stack
1300
1330
1430
1530
1630
1093
560
8.96
8.96
. 28.00
448
1093
568
8.82
8.82
26.88
446
1093
568
8.82
8.82
26.32
444
1093
568
8.54
8.54
21.56
388
1093
560
8.82
8.82
20.30
381
                                                                                                       COMMENTS
                                                                                                       Methane
                                                                                                       Methane
                                                                                                       Methane
                                     4.8
        KILN_
        Burner Gas Temp. (Deg. C)
        Gas Discharge Temp. (Deg. C)
        Air Input to Burner (SCMH)
        Gas Input to Burner (SCMH)
        Water to Burner U/min.)
        Compressed Air to Burner (SCMH)
        Compressed Air Press (kN/M2)
        Sludge feed (I/sec.)
        Kepone Solution (l/hr.)
        Kepone Solution Cone, (mg/l)
        Ash (kg)
        Draft in Kiln (cm W.C)
1056
538
106.4
10.36
0.378
12.18
138
N/A
N/A
N/A
N/A
1051
538
98.0
9.52
0.347
12.04
138
N/A
N/A
N/A
N/A
1036
538
103.6
9.52
0.347
12.04
138
N/A
9
0.1
N/A
944
538
103.6
9.52
0.359
12.04
138
N/A
9
0.1
N/A
1031
538
103.6
9.10
0.359
12.04
138
N/A
9
0.1
N/A
                                                                                                       Methane

-------
       TABLE E-2 (continued)

                Time
       Variable                            1300       1330       1430       1530       1630                                                      COMMENTS,

       SCRUBBER
       Brine to Fog Nozzle (I/sec.)               0.44        0.18        000
       Brine to 2" Nozzle (I/sec.)                3.09        3.09        3.09        3.09        3.09
       Brine to 1" Nozzle (I/sec.)                0.977       0.977       0.977       0.977       0.977
       Brine to Cone (I/sec.)                    1.26        2.08        2.08        2.08        1.64
       Brine to Scrubber (I/sec.)                 1.32        1.23        1.32        1.27        1.30
       Caustic Tank level (cm)                361        359        356         349        344
       Brine Tank level (cm)                 —          —          —         —          —
       Quench level (cm)                    —          —          —         —          —
       Caustic Flow (l/min.)                 -              0.189       0.284       0.473       0.378
       Press @ Brine Pump (kN/M2)           241        276        276         276        276
       Press @> Retention Tank (kN/M2)         69.0      138.0       117.0        82.7        82.7
vo     Press @ Caustic Pump (kN/M2)           55.2        55.2        55.2        55.2        55.2
"^     Scrubber pH                        -          -          -         -

       FEED STARTED @ 1430

       FEED STOPPED® 1640

-------
TABLE E-3

         Time
Variable
                                   KIT RUN NO. 3
                                                                                       DATE:  1-22-77
                                   1505
                       1535
                       1605
1635
1735
                                                                                                                   COMMENTS
Incinerator Temp. (Deg. C)
Total Air Input (SCMH)
Gas Input @ Pilot No. 1 (SCMH)
Gas Input @ Pilot No. 2 (SCMH)
Aux. Gas Input (SCMH)
Inlet Gas Temp. (Deg. C)
Stack Flow Rate (SCMH)
Air in Stack Burner (SCMH)
Pilot Gas to Stack Burner (SCMH)
Aux. Gas to Stack Burner (SCMH)
Stack Temp. (Deg. C)
% Oxygen in Stack
            1093       1093        1093
             560        552         552
               2.94       2.94        2.94
               3.50       3.50        3.50
              12.88      11.76       11.48
             443        451         451
                                  1093        1093
                                   552         552
                                     2.94        2.94
                                     3.50        3.50
                                    12.88        9.52
                                   452         401
                                                                     Propane
                                                                     Propane
                                                                     Propane
 Burner Gas Temp (Deg. C)
 Gas Discharge Temp (Deg. C)
 Air Input to Burner (SCMH)
 Gas Input to Burner (SCMH)
 Water to Burner (l/min.)
 Compressed Air to Burner (SCMH)
 Compressed Air Press (kN/M2
 Sludge feed (I/sec.)
 Kepone Solution (l/hr.)
 Kepone Solution Cone, (mg/l)
 Ash (kg)
 Draft in  Kiln (cm W.C.)
r»4*l
1088       1053       1082       1102        1036
 538        538        538        538         532
 114.8       95.2        98.0       95.2        89.6
   4,90       4.34        4.56       4.68        4.48
   0.42       0.39        0.39       0.38        0.42
  11.62      11.76       11.90      11.90       11.62
 124        124        124        124         124
N/A       N/A        N/A        N/A        N/A
N/A       N/A        N/A           9        N/A
N/A       N/A        N/A           0.1      N/A
N/A       N/A        N/A        N/A        N/A
                                                                                                                   Propane

-------
        TABLE E-3 (continued)

                Time
        Variable                            1501       1535       1605        1635       1735                                                       COMMENTS,

        SCRUBBER
        Brine to Fog Nozlle (I/sec.)            —          —          —
        Brine to 2" Nozzle (I/sec.)                3.09        3.09        3.09        3.09        3.09
        Brine to 1" Nozzle (I/sec.)                0.98        0.98        0.98        0.98        0.98
        Brine to Cone (I/sec.)                    2.58        2.71        2.71        2.71        2.71
        Brine to Scrubber (I/sec.)                 1.04        0.98        0.98        1.02        1.02
        Caustic Tank level (cm)                325        323        323         319        312
        Brine Tank level (cm)                 _-_.___          —
        Quench Level (cm)                   __..__          _.
        Caustic Flow (i/m'm.)                 -              0.378       0           0.567      0.473
        Press @ Brine Pump (kN/M2)            275.8      289.6       289.6       289.6       289.6
        Press @ Retention Tank (kN/M2)         27.58       27.58       27.58       27.58       27.58
^      Press @ Caustic Pump (kN/M2)           62.06       62.06        0          62.06       62.06
oo      Scrubber pH                         —              9.0         9.0         83         9.0

        FEED STARTED @> 1638

        FEED STOPPED® 1815

-------
TABLE E-4

         Time
Variable
                                          1125
                                                                 KIT RUN NO. 4
                                                                                                                     DATE: 1-25-77
                                                     1155
                                                          1230
1330
                                                                                        1430
                                                                                                                                                  COMMENTS
vo
       Incinerator Temp. (Deg. C)
       Total Air Input (SCMH)
       Gas Input @ Pilot No. 1 (SCMH)
       Gas Input @ Pilot No. 2 (SCWH)
       Aux. Gas Input (SCMH)
       Inlet Gas Temp. (Deg. C.)
       Stack Flow Rate (SCWH)
       Air in Stack Burner (SCMH)
       Pilot Gas to Stack Burner (SCMH)
       Aux. Gas to Stack Burner (SCMH)
       Stack Temp. (Deg. C)
       %Oxygen in Stack
1093
546
3.14
3.36
11.2
438
1093
546
3.14
3.36
11.2
447
1093
546
3.14
3.36
10.9
448
1093
546
3.22
3.44
8.4
393
1093
546
3.22
3.50
7.84
414
                                                                                                                                           Propane
                                                                                                                                           Propane
                                                                                                                                           Propane
       KiLN_
       Burner Gas Temp. (Deg. C)
       Gas Discharge Temp (Deg. C)
       Air Input to Burner (SCMH)
       Gas Input to Burner (SCMH)
       Water to Burner (l/min.)
       Compressed Air to Burner (SCMH)
       Compressed Air Press (kN/M )
       Sludge feed (I/sec.)
       Kepone Solution (l/hr.)
       Kepone Solution Cone, (mg/l)
       Ash (kg)
       Draft in Kiln (cm W.C.)
1080
538
151.2
6.16
0.504
11.48
137.9
N/A
N/A
N/A
N/A
-0.76
1021
538
109.2
5.04
0.397
12.04
137.9
N/A
N/A
N/A
N/A
-1.02
997
538
112.0
5.04
0.410
11.76
124.1
N/A
N/A
N/A
N/A
-1.27
1011
538
109.2
5.04
0.441
11.54
124.1
N/A
9
10
N/A
-0.76
977
538
106.4
4.90
0.473
11.48
124.1
N/A
9
10
N/A
-0.76
                                                                                                                                           Propane

-------
       TABLE E-4 (continued)
               Time
       Variable
                                         1125
                                                    1155
                                                         1230
                                                                    1330
1430
                                                                                                                                               COMMENTS
O
O
SCRUBBER
Brine to Fog Nozzle (I/sec.)
Brine to 2" Nozzle (I/sec.)
Brine to 1" Nozzle (I/sec.)
Brine to Cone (I/sec.)
Brine to Scrubber (I/sec.)
Caustic Tank level (cm)
Brine Tank level (cm)
Quench level (cm)
Caustic Flow (l/min.)
Press @ Brine Pump (kN/M2)
Press @ Retention Tank (kN/M2)
Press @ Caustic Pump (kN/M )
Scrubber pH

FEED STARTED® 1240
3.09
0.977
2.71
0.851
304.8

296.5
13.79
0
3.09
0.977
2.71
0.851
304.8
0
296.5
13.79
0
3.09
0.977
2.71
0.851
304.8
0
296.5
13.79
0
3.09
0.945
2.71
0.851
302.3
0.189
296.5
13.79
55.16
3.09
0.977
2.71
0.851
294.6
0.567
296.5
13.79
55.16
       FEED STOPPED® 1430

-------
TABLE E-5

         Time
Variable
                       KIT RUN NO. 5
                                                                           DATE: 1-26-77
                                   1330
           1420
                                                                                                        COMMENTS
Incinerator Temp (Deg. C)
Total Air Input (SCMH)
Gas Input @ Pilot No. 1 (SCMH)
Gas Input @ Pilot No. 2 (SCMH)
Aux. Gas Input (SCMH)
Inlet Gas Temp. (Deg. C)
Stack Flow Rate (SCMH)
Air in Stack Burner (SCMH)
Pilot Gas to Stack Burner (SCMH)
Aux. Gas to Stack Burner (SCMH)
Stack Temp. (Deg. C)
% Oxygen in Stack
1093
 582.4
   3.14
   3.44
   9.52
 437
1093
 560.0
   3.16
   3.42
   9.52
 437
Propane
Propane
Propane
               4.7
 K[LN_
 Burner Gas Temp. (Deg. C)
 Gas Discharge Temp. (Deg. C)
 Air Input to Burner (SCMH)
 Gas Input to Burner (SCMH)
 Water to Burner (l/min.)
 Compressed Air to Burner (SCMH)
 Compressed Air Press (kN/M )
 Sludge feed (I/sec.)
 Kepone Solution (l/hr.)
 Kepone Solution Cone, (mg/l)
 Ash (kg)
 Draft in Kiln (cm W.C.)
 999
 538
 109.2
    4.98
    0.36
   12.04
 124.1
   -1.02
                                                                                            Propane

-------
TABLE E-5 (continued)

         Time
Variable                           1330       1420                                                                                      COMMENTS.

SCRUBBER
Brine to Fog Nozzle (I/sec.)           —         —
Brine to 2" Nozzle (I/sec.)               3.09
Brine to 1" Nozzle (I/sec.)               0.98
Brine to Cone (I/sec.)                   2.33
Brine to Scrubber (I/sec.)                0.72    —
Caustic Tank level (cm)               293       —
Brine Tank level (cm)                —         —
Quench level (cm)                   —         —
Caustic Flow (l/min.)                   0       —
Press @ Brine Pump (kN/M2)           296.5
Press @ Retention Tank (kN/M2)         13.79    -
Press @ Caustic Pump (kN/M )           0       —
Scrubber pH                        -

FEED STARTED®— RUN ABORTED

FEED STOPPED® —

-------
      TABLE E-6
                                                                KIT RUN NO. 6
                                                                          DATE: 2-14-77
o
u>
               Time
      Variable

      FUMfiNCINERATgR
      Incinerator Temp. (Deg. C)
      Total Air Input (SCMH)
      Gas Input @ Pilot No. 1 (SCMH)
      Gas Input @ Pilot No. 2 (SCIVH)
      Aux. Gas Input (SCMH)
       Inlet Gas Temp (Deg. C.)
      Stack Flow Rate (SCMH)
       Air in Stack Burner (SCMH)
       Pilot Gas to Stack Burner (SCMH)
       Aux. Gas to Stack Burner (SCIVH)
       Stack Temp. (Deg. C)
       %Oxygen in Stack
       KM-N_
       Burner Gas Temp. (Deg. C)
       Gas Discharge Temp. (Deg. C)
       Air Input to Burner (SCMH)
       Gas Input to  Burner (SCMH)
       Water to Burner (l/min.)
       Compressed Air to Burner (SCMH)
       Compressed Air Press (kN/M )
       Sludge feed (I /sec.)
       Kepone Solution (l/hr.)
       Kepone Solution Conc.(%)
       Ash (kg)
       Draft in Kiln (cm W.C.)
1215
1245
1315
1415
1515
1093
546.0
2.9
3.2
12.7
442
198.8
—
—
77
6.5
993
491
112.0
6.16
0.37
12.0
138
N/A
N/A
N/A
1093
537.6
3.0
3.2
11.9
—
198.8
_
_
77
7.0
952
482
103.6
5.94
0.37
12.3
138
N/A
N/A
N/A
1093
534.8
2.9
3.1
12.5
—
196.0
—
—
74
5.5
1010
410
201.6
9.66
0.55
12.3
138
0.01
N/A
0
1093
537.6
2.9
3.1
11.6
421
194.9
0.17
0.59
116
*""
939
477
168.0
8.54
0.54
11.5
138
0.01
N/A
0
1093
537.6
2.9
3.1
11.9
448
196.0
—
_.
121
~"
893
516
166.6
8.26
0.57
11.5
138
_
N/A
0
                                                                                                       COMMENTS
                                                                                                       Propane
                                                                                                       Propane
                                                                                                       Propane
                                                                                                      Propane
                                                                                                      Feed Line
                                                                                                      plugged total
                                                                                                      sludge fed =
                                                                                                      0.049 M3

-------
TABLE E-6 (continuedI

         Time
Variable                            1215       1245        1315       1415        1515                                                      COMMENTS^

SCRUBBER
Brine to Fog Nozzle (I/sec.)           —          —
Brine to 2" Nozzle (I/sec.)                 3.0         3.0         3.0         3.0         3.0
Brine to 1" Nozzle (I/sec.)                 0.98        0.98        0.98       0.98        0.98
Brine to Cone (I/sec.)                     2.7         2.7         2.7         2.7         2.7
Brine to Scrubber (I/sec.)                  1.13        1.13        1.12       1.10        1.10
Caustic Tank level (cm)                324        322         320        316         311
Brine Tank level (cm)                 _          _          _          _          —
Quench level (cm)                    _.__._          —
Caustic Flow (l/min.)                 -             0.38        0.28       0.28        0.38
Press @ Brine Pump (kN/M2)           290        293         293        293         293
Press @ Retention Tank (kN/M )         82.7        82.7        96.5        96.5        96.5
Press @ Caustic Pump (kN/M2)          62.1        55.2        55.2        55.2        55.2
Scrubber pH                            9.3         9.4         9.2         9.3         9.3

FEED STARTED® 1308

FEED STOPPED® 1520

-------
TABLE E-7

         Time
Variable
                                          1535
         1630
                                                                 KIT RUN NO. 8
                                                           1700
1730
                                                                                  1830
1930
                                                                                                                2030
                                                                                                                      DATE: 2-18-77
                                                                               2115
                                                                                                                                                   COMMENTS
O
Ui
       Incinerator Temp. (Deg. C)
       Total Air Input (SCMH)
       Gas Input @ Pilot No. 1 (SCMH)
       Gas Input @ Pilot No. 2 (SCMH)
       Aux. Gas Input (SCMH)
       Inlet Gas Temp. (Deg. C)
       Stack Flow Rate (SCMH)
       Air in Stack Burner (SCMH)
       Pilot Gas to Stack Burner (SCMH)
       Aux. Gas to Stack Burner (SCMH)
       Stack Temp. (Deg. C)
       % Oxygen in Stack
        KILN
        Burner Gas Temp. (Oeg. C)
        Gas Discharge Temp. (Deg. C)
        Air Input to  Burner (SCMH)
        Gas Input to Burner (SCMH)
        Water to Burner (l/min.)
        Compressed  Air to Burner (SCMH)
        Compressed  Air Press (kN/M )
        Sludge Feed (I/sec.)
        Kepone Solution (l/hr.)
        Kepone Solution Cone. (%)
        Ash (kg)
        Draft in Kiln (cm W.C.)
1149
512.4
2.82
3.08
12.0
—
195
0.17
0.84
—
4.4
849
364
169.4
8.40
14.3
124
N/A
N/A
N/A
1149
518.0
2.86
3.05
11.5
363
195
0.17
0.84
132
4.7
821
388
168.0
8.26
14.4
124
0.01
N/A
1.2
1149
518.0
2.86
3.05
11.2
349
195
0.17
0.84
132
5.0
824
371
168.0
8.26
14.3
124
0.01
N/A
1.2
1149
518.0
2.86
3.05
11.2
341
195
0.17
0.84
138
5.0
832
366
168.6
8.54
14.3
124
0.01
N/A
1.2
1149
518.0
2.91
3.08
10.9
329
195
0.17
0.84
135
5.0
829
349
169.4
8.57
14.4
124
0.01
N/A
1.2
1149
518.0
2.91
3.08
11.2
299
195
0.17
0.84
132
5.0
838
310
189.0
9.24
14.3
124
0.01
N/A
1.2
1149
518.0
2.94
3.11
10.9
296
195
0.17
0.84
132
4.7
843
316
187.6
9.32
14.4
124
0.01
N/A
1.2
1149
518.0
2.94
3.19
10.6
308
195
0.17
0.84
132
4.6
837
329
189.0
9.24
14.4
124
0.01
N/A
1.2
                                                                                                      Propane
                                                                                                      Propane
                                                                                                      Propane
                                                                                                      Propane
                                                                                                      Propane
                                                                                                      Propane
-0.5
           -0.5
                       -0.5
                                  -0.5
                                              -0.5
                                                         0.8
                                                                     -0.5
                                                                                -0.8

-------
TABLE E-7 (continued)

         Time
Variable                            1535        1630       1700        1730       1830       1930        2030       2115                   COMMENTS^

SCRUBBER
Brine to Fog Nozzle (I/sec.)            _______          _
Brine to 2" Nozzle (I/sec.)                3.0         3.1         3.1          3.1         3.0         3.1         3.0         3.0
Brine to 1" Nozzle (I/sec.)                1.0         1.0         1.0         1.0         1.0         1.0         1.0         1.0
Brine to Cone (I/sec.)                    1.4         1.4         1.4         1.4         1.4         1.4         1.3         1.3
Brine to Scrubber (I/sec.)                 0.85        1.0         1.0         1.0         0.95        1.0      -              1.1
Caustic Tank level (cm)                301         300        296         293        287        286         282         278
Brine Tank level (cm)                __.__          —         —          —          —
Quench level (cm)                    —           —          —           —          —         —          —          —
Caustic Flow (l/min.)                 -              0.66        0.57        0.57        0.57    -             0.57        0.47
Press @ Brine Pump (kN/M2)           303         290        290         290        290        290         303         303
Press @ Retention Tank (kN/M2)        117         117        117         124         90         97         103         82
Press @ Caustic Pump (kN/M2)         -             55.2        55.2        55.2        69.0     —            62.1       62.1
Scrubber pH                        —              9.3         9.3         9.4         9.4         9.3         9.3         9.5

FEED STARTED ©1615

FEED STOPPED® 2115

-------
o
--J
TABLE E-8

         Time
Variable
                                                                 KIT RUN NO. 9
       Incinerator Temp. (Deg. C)
       Total Air Input (SCMH)
       Gas Input @ Pilot No. 1 (SCMH)
       Gas Input @ Pilot No. 2 (SCMH)
       Aux. Gas Input (SCMH)
       Inlet Gas Temp. (Deg. C)
       Stack Flow Rate (SCMH)
       Air in Stack Burner (SCMH)
       Pilot Gas to Stack Burner  (SCMH)
       Aux. Gas to Stack Burner  (SCMH)
       Stack Temp.  (Deg. C)
       % Oxygen in  Stack
       KU_N_
       Burner Gas Temp (Deg. C)
       Gas Discharge Temp. (Deg. C)
       Air Input to Burner (SCMH)
       Gas Input to Burner (SCMH)
       Water to Burner (l/min.)
       Compressed Air to Burner (SCMH)
       Compressed Air Press (kN/M2)
       Sludge Feed (I/sec.)
       Kepone Solution (l/hr.)
       Kepone Solution Cone (%)
       Ash (kg)
       Draft in Kiln (cm W.C.)
                                          1245
1093
 546.0
   2.7
   3.0
  11.2
 326

 194.6
   0.36
   0.84
 143
   5.5
 755.6
 343.3
 187.6
    7.3
N/A
N/A
N/A

 -0.8
           1330
                                                          1400
          1430
           1500
                                                                                                    1530
                                                                      1600
                                                                                                                      DATE: 2-23-77
                                                                                                                           1630
                                                                                             1700
                                                                                                                                                   COMMENTS
1093
546.0
2.7
3.0
11.2
334
194.6
0.36
0.84
143
5.5
755.6
332.2
187.6
7.1
0.01
N/A
0.6
1093
540.0
2.7
2.9
11.2
321
194.6
0.36
0.84
141
6.0
690.0
282.2
190.4
7.3
0.01
N/A
0.6
1093
540.4
2.7
2.9
11.2
260
194.6
0.36
0.84
141
6.0
687.8
280.0
190.4
7.1
0.01
N/A
0.6
1093
540.4
2.7
2.9
11.2
272
194.6
0.36
0.84
138
6.3
688.9
254.4
191.2
7.3
0.01
N/A
0.6
1093
540.4
2.7
2.9
11.5
262
194.6
0.36
0.84
143
6.3
682.8
243.3
190.4
7.1
0.01
N/A
0.6
1093
546.0
2.7
2.9
11.2
254
194.6
0.36
0.84
138
6.1
678.9
226.7
190.4
7.1
0.01
N/A
0.6
1093
546.0
2.7
2.9
11.2
246
194.6
0.36
0.84
138
5.0
678.3
226.7
190.4
7.1
0.01
N/A
0.6
1093
546.0
2.7
2.9
9.2
246
194.6
0.36
0.84
143
6.8
677.2
190.6
190.4
7.1
0.01
N/A
0.6


Propane
Propane
Propane


Propane
Propane





Propane



                                                -1.0
-0.8
•0.8
-1.3
-0.5
                                                                      -0.5
                                                                                  -0.5
                                                                                                                                       -0.6

-------
       TABLE E-8 (continued)
                Time
       Variable
                                          1245
                                              1330
                                                                1400
                                                                            1430
                                                                                1500
1530
                                                                                                       1600
                                                                                                                         1630
                                                                                                                              1700
                                                                                                                                                COMMENTS
O
00
SCRUBBER
Brine to Fog Nozzle (I/sec.)
Brine to 2" Nozzle (I/sec.)
Brine to 1" Nozzle (I/sec.)
Brine to Cone (I/sec.)
Brine to Scrubber (I/sec.)
Caustic Tank level (cm)
Brine Tank level (cm)
Quench level (cm)
Caustic Flow (l/min.)
Press @ Brine Pump (kN/M2)
Press @ Retention Tank (kN/M )
Press @ Caustic Pump (kN/M )
Scrubber pH
3.09
1.0
1.3
1.6
137.75
3.15
1.0
1.4
1.6
137.75
3.15
1.0
1.4
1.6
137.75
3.15
1.0
1.4
1.6
137.75
3.15
1.0
1.5
1.6
137.75
3.15
1.0
1.5
1.6
137.75
3.15
1.0
1.5
1.6
137.75
3.15
1.0
1.5
1.6
137.75
3.15
1.0
1.5
1.6
137.75
0
310.3
96.5
0
9.5
0
317.2
75.8
0
9.3
0
317.2
69.0
0
9.4
0
317.2
89.6
0
9.3
0
317.2
82.7
0
9.4
0
317.2
75.8
0
9.3
0
317.2
69.0
0
9.3
0
317.2
69.0
0
9.3
0
317.2
69.0
0
9.3
       FEED STARTED® 1318
       FEED STOPPED® 1718

-------
TABLE E-9

         Time
Variable
                                   1415
          1445
                                                          KIT RUN NO. 10
                                                          1515
                                 1545
                                                                                  1615
                                                         1645
                                                                                                               DATE: 2-24-77
                                                                                                         1715
                                                                                1800
                                                                                                                                            COMMENTS
Incinerator Temp. (Deg. C)
Total Air Input (SCMH)
Gas Input @ Pilot No. 1 (SCMH)
Gas Input @ Pilot No. 2 (SCMH)
Aux. Gas Input ISCMH)
Inlet Gas Temp. (Deg. C)
Stack Flow Rate (SCMH)
Air in Stack Burner (SCMH)
Pilot Gas to Stack Burner (SCMH)
Aux. Gas to Stack Burner (SCMH)
Stack Temp. (Deg. C)
% Oxygen in Stack
1037.8
588.0
2.5
3.1
9.5
273.9
187.6
0.14
1.5
137.8
5.5
1037.8
579.6
2.7
2.9
10.9
348.9
187.6
0.14
1.5
137.8
6.5
1037.8
574.0
2.7
2.9
10.6
361.7
187.6
0.14
1.5
137.8
6.5
1037.8
574.0
2.7
2.9
10.3
346.7
184.8
0.14
1.5
135.0
6.8
1037.8
588.0
2.7
2.9
10.3
320.6
187.6
0.14
1.46
135.0
6.7
1037.8
579.6
2.7
3.0
10.3
306.7
189.0
0.14
1.46
140.6
6.2
1037.8
588.0
2.7
3.0
9.5
296.7
187.6
0.14
1.46
146.1
7.7
1037.8
588.0
2.7
3.0
9.5
273.9
187.6
0.14
1.46
137.8
8.0
                                                                                                       Propane
                                                                                                       Propane
                                                                                                       Propane
                                                                                                       Propane
                                                                                                       Propane
 KILN_
 Burner Gas Temp. (Deg. C)
 Gas Discharge Temp. (Deg. C)
 Air Input to Burner (SCMH)
 Gas Input to Burner (SCMH)
 Water to Burner (l/min.)
 Compressed Air to Burner (SCM-0
 Compressed Air Press (kN/M )
 Sludge feed (I/sec.)
 Kepone Solution (l/hr.)
 Kepone Solution Cone. (%)
 Ash (kg)
 Draft in  Kiln (cmW.C.)
777.2
354.4
190.4
7.3
0
0
0
N/A
N/A
N/A
758.3
398.9
190.4
7.3
0
0
0
N/A
N/A
N/A
765.0
387.8
189.0
7.1
0
0
0
0.01
N/A
0.6
747.2
348.9
189.0
7.3
0
0
0
0.01
N/A
0.6
713.3
315.6
190.4
7.2
0
0
0
0.01
N/A
0.6
748.9
310.0
190.4
7.2
0
0
0
0.01
N/A
0.6
750.0
298.9
191.8
7.2
0
0
0
0.01
N/A
0.6
757.2
265.6
191.8
7.2
0
0
0
0.01
N/A
0.6
-1.0
           -1.0
                       -0.5
                                  -1.3
                                                                                   -1.3
                                                         -0.5
                                                                     -0.5
                                                                                -1.0
                                                                                                       Propane

-------
TABLE E-9 (continued)
         Time
Variable
                                  1415
1445
1515
1545
                                  1615
                                  1645
                                                                                                      1715
                                                                                                                 1800
                                                                                                                                        COMMENTS
SCRUBBER
Brine to Fog Nozzle (I/sec.)
Brine to 2" Nozzle (I/sec.)
Brine to 1" Nozzle (I/sec.)
Brine to Cone (I/sec.)
Brine to Scrubber (I/sec.)
Caustic Tank level (cm)
Brine Tank level (cm)
Quench level (cm)
Caustic Flow (l/min.)
Press @ Brine Pump (kN/M2)
Press @ Retention Tank (kN/M2)
Press @ Caustic Pump (kN/M2)
Scrubber pH

FEED STARTED @ 1450
3.1
1.0
1.4
1.6
350
3.1
1.0
1.4
1.6
350
3.1
1.0
1.6
1.6
350
3.1
1.0
1.6
1.6
350
3.1
1.0
1.6
1.6
350
3.1
1.0
1.5
1.6
350
3.1
1.0
1.5
1.6
350
3.1
1.0
1.5
1.6
350
0
317.2
62.1
0
9.3
0
317.2
62.1
0
9.2
0
317.2
62.1
0
9.4
0
317.2
62.1
0
9.3
0
317.2
69.0
0
9.5
0
317.2
62.1
0
9.4
0
296.5
69.0
0
9.5
0
289.6
62.1
0
9.5
FEED STOPPED® 1820

-------
TABLEE-10                                               KIT RUN NO. 11                                      DATE: 2-25-77

         Time
Variable                            1230       1300       1330       1400        1430       1500       1530        1550

FUME JJNCINE RATOR_
Incinerator Temp. (Deg. C)
Total Air Input (SCWH)
Gas Input @ Pilot No. 1 (SCMH)
Gas Input @ Pilot No. 2 (SCMH)
Aux. Gas Input (SCMH)
Inlet Gas Temp. (Deg. C)
Stack Flow Rate (SCMH)
Air in Stack Burner (SCMH)
Pilot Gas to Stack Burner (SCMH)
Aux. Gas to Stack Burner (SCMH)
Stack Temp. (Deg. C)
% Oxygen in Stack


 Ki_LN_
 Burner Gas Temp. (Deg. C)
 Gas Discharge Temp. (Deg. C)
 Air Input to Burner (SCMH)
 Gas Input to Burner (SCMH)
 Water to Burner (l/min.)
 Compressed  Air to Burner (SCMH)
 Compressed Air Press (kN/M2)
 Sludge feed (I/sec.)
 Kepone Solution (l/hr.)
 Kepone Solution Conc.(%)
 Ash (kg)                           _______
 Draft in Kiln (cm W.a)                 -1.02        -0.25       -0.51       -0.76        -0.76        -0.51       -1.02       -0.25
1093.3
551.6
2.7
2.9
10.9
319.4
189
0.22
1.1
132.2
5.0
765.6
393.3
190.4
7.14
0
0
0
N/A
N/A
N/A
1093.3
551.6
2.7
2.9
11.2
374.4
189
0.22
1.3
135.0
6.0
768.8
454.4
189.0
7.20
0
0
0
N/A
N/A
N/A
1093.3
551.6
2.7
2.9
10.6
403.3
189
0.22
1.3
132.2
6.5
763.3
460.0
189.0
7.14
0
0
0
0.1
N/A
4.16
1093.3
551.6
2.7
2.9
9.9
409.4
189
0.22
1.3
132.2
3.2
761.1
457.2
190.4
7.14
0
0
0
0.1
N/A
4.16
1093.3
546.0
2.7
2.9
9.9
423.3
189
0.22
1.3
132.2
3.0
761.1
479.4
190.4
7.14
0
0
0
0.1
N/A
4.16
1093.3
551.6
2.7
2.9
9.9
430.6
189
0.22
1.3
1375
3.0
761.7
482.2
189.0
7.14
0
0
0
0.1
N/A
4.16
1093.3
551.6
2.7
2.9
9.5
432.8
189
0.22
1.3
137.8
3.1
761.1
482.2
189.0
7.20
0
0
0
0.1
N/A
4.16
1093.3
551.6
2.7
2.9
9.2
438.4
189
0.22
1.3
137.8
3.2
757.2
482.2
189.0
7.20
0
0
0
0.1
N/A
4.16
 COMMENTS
 Propane
 Propane
 Propane
 Propane
 Propane
Propane
Dry Basis

-------
TABLE E-10 (continued)

         Time
Variable

SCRLBBER
Brine to Fog Nozzle (I/sec.)
Brine to 2" Nozzle (I/sec.)
Brine to 1" Nozzle (I/sec.)
Brine to Cone (I/sec.)
Brine to Scrubber (I/sec.)
Caustic Tank level (cm)
Brine Tank level (cm)
Quench level (cm)
Caustic Flow (l/min.)
Press @ Brine Pump (kN/M2)
Press @ Retention Tank (kN/M )
Press @ Caustic Pump (kN/M )
Scrubber pH

FEED STARTED® 1328
1230
1300
1330
1400
                                             1430
                                                         1500
                                                                    1530
                                                                               1550
3.15
1.01
1.51
1.59
350
0
310
69
0
9.2
3.15
1.01
1.51
1.59
350
0
310
69
0
9.2
3.06
0.98
1.39
1.59
350
0
310
69
0
9.2
3.15
1.01
1.51
1.59
348
19.05
310
69
55.2
9.2
3.15
1.01
1.51
1.59
344
19.05
310
96.5
55.2
9.3
3.18
0.99
1.51
1.59
342
19.05
310
96.5
55.2
9.6
3.15
0.99
1.51
1.59
342
0
317
69
0
9.8
3.12
0.99
1.76
1.59
342
0
317
69
0
9.8
                                                                                                       COMMENTS
FEED STOPPED® 1600

-------
TABLEE-11
KEPONE INCINERATION TESTS DAT.A SUMMARY
Run
No.
1
2
3
4
5
6
7
8
9
10
11
Date Kepone Incinerator*
Feed Temp.
gm/hr. Oeg.C.
1/14/77
1/15/77
1/22/77
1/25/77
1/26/77
2/14/77
2/1 7/77
2/18/77
2/23/77
2/24/77
2/25/77
0.9
0.9
0.9
90
None
None
410
470
250
270
1510
1260
1093
1093
1093
1093
1093
1149
1149
1093
1038
1093
Kiln*
Inlet
Tenp.
Deg. C
1024
1036
1102
997
999
952
877
849
700
758
763
Kiln*
Outlet
Temp.
Deg. C
538
538
538
538
538
482
427
364
343
399
454
Flow thi
Inciner
SCIV
764.4
775.9
771.1
755.3
773.6
998.2
-
814.0
826.0
873.3
818.2
*At Start of Run
*»At
End of Run
                                                  Flow through   Flow through   Incinerator    %   Residence  Kiln**  Kiln**  Incinerator**   Feed
                                                                                           (X,   Time Sec.   Inlet   Outlet    Inlet Temp.    Time
                                                                                                                                        Hours
                                                                  1384.6
                                                                  1315.2
                                                                  1307.0
                                                                  1280.3
                                                                  1311.2
                                                                  1722.6

                                                                  1607.2
                                                                  1597.0
                                                                  1639.1
                                                                  1578.4
Deg. C
438
444
452
448
437
442
427
363
326
349
374
•fe
3.75
4.8
—
-
4.7
5.5
3.7
4.4
5.5
6.5
3.1

2.15
2.38
2.39
2.44
2.39
2.06
-
2.18
2.23
2.20
2.26
Temp.
Deg. C
1016
1031
1036
977
999
893
877
837
677
757
757
Temp.
Deg. C
538
538
532
538
538
516
427
329
191
266
482
Deg
407
381
401
414
437
448
427
308
246
274
434
                                                                                       2.0
                                                                                       2.0
                                                                                       1.67
                                                                                       1.67

                                                                                       2.0
                                                                                       0.33
                                                                                       5.0
                                                                                       4.0
                                                                                       3.5
                                                                                       2.5

-------
  60
  50
UJ
>
UJ
  40
  30
              I
          I
          I
                                                         2.0gpm
                                        AVERAGE  WATER CONSUMPTION

                                        IN  QUENCH = 1.87 gpm
            I
          I
          l
    4=00
5--00
6=00
  TIME
  7=00
( O'CLOCK)
8 00
9=00
10=00
             FIGURE-E12' QUENCH WATER  FOR  KIT RUN  N0.8

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  60
cc
X
o
_J
UJ
>
UJ
  50
  40
                                1.68 gpm
                                        AVERAGE WATER  CONSUMPTION

                                        IN QUENCH = 1.67 gpm
   30
                               _L
                          -L
     1 = 00
2=00          3=00

         TIME   (O'CLOCK)
4=00
6=00
              FIGURE-EI3' QUENCH  WATER FOR KIT  RUN N0.9

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  63
  58
tn
*:
cc
  48
I
o
UJ
>
UJ
  38
  28
       I INCH = 4.4 GALLONS
                                                          1.61 gpm
                       AVERAGE WATER CONSUMPTION

                       IN  QUENCH =  1.82 gpm
    2 00
3=00
  4= 00

TIME (O'CLOCK)
5 = 00
6--00
             FIGURE-E14: QUENCH  WATER  FOR  KIT RUN NO.IO
7--00

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  7O
  60
cr
<
2
I
o
£50
UJ
            I
       AVERAGE WATER  CONSUMPTION
       IN QUENCH = l.77gpm
                                            69gpm
                                      1= 4.4 GALLONS
    I2--00
1-00
4:00
                  2:00           3-00
                    TIME  (O'CLOCK)
FIGURE- EI5- QUENCH  WATER  FOR KIT RUNNO.II
5.00

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         0.3
       5
       Q_
00
       LlJ
       CE


       O
       UJ
       UJ
         0.1
                                                   AVERAGE  FLOW 0.145 GPM
                                       I
              I
              I
                 0.5
1.5
2     2.5      3

   TIME (MRS)
3.5
4.5
                  FIGURE-E16= SLUDGE FEED  RATE FOR KIT  RUN NO. 8

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VO
         0.3
       Ul
cr


o
UJ
ui
         O.I
                                                      AVERAGE  FLOW  0.15 GPM
                                 1
                                        1
                     1
1
                  0.5
                   I
1.5
3.5
4.5
                     2      2.5     3

                        TIME (MRS)


FIGURE- EI7-. SLUDGE FEED  RATE  FOR KIT RUN  NO. 9

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 0.3
LU
cr


Q
LU
LU
LL
                                            AVERAGE FLOW  0.167  GPM
           I
I
 I
I
                           I
\
I
I
I
          0.5
I
1.5
                    3.5
                     2      2.5     3

                       TIME (HRS)

FIGURE-E18= SLUDGE FEED RATE  FOR  KIT RUN  NO. 10
                    4.5

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 0.3
UJ
I-

cr


Q
UJ
UJ
U-


  0.1
                                                AVERAGE FLOW  0.133 GPM
                   J	I	I	I	I	I	I	L
           0.5       I      1.5      2      2.5      3      3.5      4      4.5

                                     TIME (HRS)

            FIGURE- E19: SLUDGE FEED  RATE  FOR KIT RUN  NO. 11

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                                                                 FIGURE  F-l
                                                   TYPICAL CHROMATOGRAM OF STACK GASES
                                                    FILTER EXTRACT (10ml) ON GLASS COLUMN
                                                    PACKED WITH 1.5% OV-I7+1.95% QF-I ON
                                                    GAS CHROM Q
     APPENDIX F. TYPICAL CHROMATOGRAMS
K3

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to
OJ
                                                             FIGURE F-2
                                                TYPICAL CHROMATOGRAM  OF KEPONE ON
                                                GLASS  COLUMN PACKED WITH 1.5% OV-I7+
                                                1.95% QF-I ON GAS CHROM Q

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              FIGURE  F-3
TYPICAL CHROMATOGRAM  OF HIGH VOLUME
AMBIENT AIR SAMPLER NO I ON COLUMN
1.5% 0V-17+1.95% OF-I  ON GAS CHROM Q

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ho
Ul
                                                             FIGURE F-4
                                                TYPICAL CHROMATOGRAM  OF INCINERATION
                                                ASH EXTRACT (2ml of I g ash) ON GLASS

                                                COLUMN 15% OV-I7-M 95%QF-I ON  GAS

                                                CHROM Q

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                                                              FIGURE F-5
                                                 TYPICAL CHROMATOGRAM  OF SCRUBBER
                                                 WATER  ON  GLASS COLUMN PACKED WITH
                                                 1.5% OV-I7-H.950/. QF-I ON GAS CHROM  Q
Ox

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             FIGURE F-6
TYPICAL CHROMATOGRAM OF STACK GASES
FILTER EXTRACT (2 ml JON GLASS COLUMN
PACKED WITH 1-5% OV-|7+I.95% OF-I ON
GAS CHROM Q

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00
                                                               FIGURE  F-7
                                                  TYPICAL CHROMATOGRAM OF STACK  GAS
                                                  IMPRINGER  EXTRACT ON GLASS COLUMN
                                                  PACKED WITH 1.5% OV-I7+I.95% OF-1 ON
                                                  GAS CHROM Q

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VO
                                                            FIGURE F-8
                                               TYPICAL CHROMATOGRAM OF CYCLONE
                                               CONDENSATE EXTRACT OF STACK GASES
                                               ON COLUMN  1.5% 0V-17+1.95% OF-1  ON
                                               GAS CHROM  Q

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APPENDIX G. LOG OF EVENTS
    A.

    Date

    11/1/76

    11/1 to 12/23/76


    12/26 to 12/30/76

    1/3 to 1/7/77


    1/10 to 1/13/77


    1/14/77

    1/15/77

    1/16 to 1/18/77
    1/19/77

    1/20-21/77

    1/24/77

    1/25/77

    1/26/77

    1/27/77

    1/28/77

    1/31 to 2/11/77
TIME TABLE OF MAJOR EVENTS

    Events

    Contract awarded to Surface Division

    Fabrication, construction and installation of
    major equipment

    Outside contractor work

    Safety training and start-up checkout for
    Air Pollution Control System

    Troubleshooting for burner system electrical
    wiring

    Test Run #1

    Test Run #2

    Changed over to propane, installed a direct
    water line for Kepone project as main header
    had frozen and burst and heat traced newly in-
    stalled water line

    Acetic acid spill in mix room and cleanup

    Test Run #3

    Trouble with removing Kepone from drum

    Test Run #4

    Test Run #5 (blank run)

    Draining and rinsing of scrubber system

    Sludge feed system checkout

    Removal of old stack, installation of new stack
    and installation of a burner in the new stack,
    replacing inner layer of insulation inside the
    kiln inlet duct
                                     130

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     Date                      Events

     2/14/77                   Test Run #6 (insulated  feed  line)

     2/15-16/77                Water jacieted feed line installed,  and  a water
                               trough installed around the  kiln  inlet duct  to
                               reduce hot spots

     2/17/77                   Test Run #7 (kiln rotation stopped after 20
                               minutes of feeding)

     2/18/77                   Test Run #8

     2/22/77                   Broken axle replaced for kiln  drive  system,
                               frozen core in sludge and required hard  work
                               to chip it off - it was too  late  to  make a run

     2/23/77                   Test Run #9

     2/24/77                   Test Run #10

     2/25/77                   Test Run #11

     2/26 to  3/4/77            Major clean-up of test  area

     3/7 to 3/11/77            Minor clean-up

     3/14-15/77                Final clean-up and tearing down of the walls in
                               control area

B.  SUMMARY DESCRIPTION OF KIT RUNS

Run #1  (1/14/77)

     Kepone solution  in acetic acid with a concentration of  0.1 mg/1 injected
into duct at  a rate of  9 1/hr   and vapors incinerated at 1260°C. for a period
of two hours.  The kiln outlet temperature was maintained  at 538 C for entire
test run.

     Calculated residence time in the incinerator was 2.15 seconds at  the
maximum flow  rate through the  incinerator.   (Air leakage into the  system is
not considered for this calculation in all runs.)

Run #2  (1/15/77)

     Kepone solution  in acetic acid with a concentration of  0.1 mg/1 injected
into duct at  a rate of  9 1/hr.  and vapors incinerated at 1093 C Qfor a period
of two hours.  The kiln outlet temperature was maintained  at 538 C.

     Calculated residence time in the incinerator was 2.38 seconds at  maximum
flow rate through the incinerator.
                                      131

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Run #3 (1/22/77)

     Fuel system changed to propane gas because of shortage of natural  gas.
A separate, heat traced water system installed as the main water heater had
frozen and burst.  Kepone solution (0.1 gm/1) injected into duct at  9 1/hr
and vapors incinerated at 1093 C  for 1 hour, 40 minutes.

     Calculated residence time was 2.39 seconds at maximum flow rate through
the incinerator.  The kiln outlet temperature was in the range of 533 - 538
C.

Run #4 (1/25/77)

     Versar personnel had difficulties in removing Kepone from the storage
drums as it had lumped, so the run was made at a lower concentration than
planned.  The concentration of the solution was 10 gms/1 and it was  injected
into the duct at a rate of 9 1/hr  for 1 hour, 40 minutes.  The vapors  were
incinerated at 1093°C.

     Calculated residence time in the incinerator was 2.44 seconds at maximum
flow rate.  The kiln outlet temperature was 538°C.

Run #5 (1/26/77)

     Detectable levels of Kepone were observed by Versar in stack and scrubber
during run #4.  No Kepone solution was injected for run #5, but sampling was
carried out for this blank run to understand the causes of detectable levels
of Kepone during run #4.  Scrubber system drained and rinsed with water after
the run as 25 mg/1 of Kepone was detected in scrubber liquid.

Run #6 (2/14/77)

     A new alloy stack equipped with a 0.147 J/sec capacity burner was  in-
stalled to prevent water condensation in the stack.  Toledo sewage sludge was
fed through 1.27-cm line into kiln at a rate of 0.01 liters/feec for about 2 hr.
The feed line into the kiln was plugged after about 1 1/2 hr of feeding.
                                   ^o"^
The incinerator was operated at 1093 C , and kiln outlet temperature dropped
from 482 C to 410 C and again came up to 515°C.

    ' Calculated residence time in the incinerator was 2.06 sec.  Hot spots
observed on the duct from burner to kiln inlet.

Run //7 (2/17/77)

     An insulated feed line was tried prior to this run and a water jacketed
feed line was installed.  A water trough was installed around the duct from
burner to kiln inlet to keep the duct cool.  Twenty-five liters of Kepone
solution (117 gm/liter)were added to drum of Toledo sewage sludge.  The
Kepone sludge mixture was fed to kiln at a rate of .0078 liters^ec for 20 min
and retort rotation stopped.  Feed was stopped and retort drive system
                                     132

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repaired.  Four bolts and  a bolting  pad were  broken.  Bolts were replaced and
the pad rewelded.

Run #8 (2/18/77)

     The Kepone sludge mixture prepared for run #7 was used for feed.  The
mixture was fed atQan average rate of 0.009 liters/sec for  5 hr.  The incin-
erator was at  1149  C and kiln outlet temperature dropped from 388°C to 310°C
and came back  up  to 329 C.  Residence time in the incinerator was calculated
to be 2.18 sec at maximum  flow rate.

Run #9 (2/23/77)

     The friction drive roller had worn out as the axle was broken and was
replaced.  The sludge had  a frozen core and had to be broken loose.  The
operator used  a wrong mark on the measuring stick and transferred only 12
liters of Kepone  solution  instead of 25 liters into  a drum load of sludge.
Kepone sludge  mixture was  fed to the kiln at  a rate  of 0.0095 liters/sec
for 4 hr.  The incinerator was at 1093°C, and the kiln outlet temperature
dropped from 343  C  to 190  C.   Kiln inlet  gas  temperature was lower as the
insulation in  the duct from the burner to kiln inlet was blown out and
water trough was  cooling the  inlet gases  considerably.  The water jacketed
feed line was  cooling the  gases at the outlet.  The  retort was stopping
frequently as  oil from the drive chain went into clutch.

Run #10  (2/24/77)

     The duct  from  the burner to kiln inlet was insulated.  Burner block
refractory was observed to be molten and  obstructing the path of gases from
the burner.  Noisy  burner  during previous run was due to this obstruction.
The clutch was cleaned.  Kepone sludge mixture was prepared as in run #9
and was fed into  the kiln  at  a rate  of 0.0105 liters/sec for 3.5 hr.  The in-
cinerator was  operated at  1038°C, and kiln outlet temperature dropped from
399°C to 266°C.   Calculated residence time in the incinerator was 2.2 sec.

Run #11  (2/25/77)

     Two bolts were replaced  for the drive system.   Approximately 95 liters
of Kepone sludge  mixture were left over in the feed  tank from run #10.  About
59 liters of Kepone solution  in acetic acid  (117 gm/literjwere added to the
Kepone-sludge  mixture left in the tank.   This mixture was  fed to the kiln at Q
a rate of 0.0084  liters/sec for 2.5  hr.   The  incinerator was operated at 1093
C.  Water flow to the jacketed feed  line  was  reduced fo get higher temperature
at the outlet  from  kiln.   Kiln outlet temperature increased from 454 C to
482°C during the  feed time.   Calculated residence time in  the incinerator
was 2.26 sec for  maximum flow.  Two  holes of  0.32 cm diameter were drilled,
one at each injection point in the duct,  after the feed was stopped and air
was blown into duct to clear  it from dust.
                                      133

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APPENDIX H. EPA (RTP) CONFIRMATORY ANALYSIS RESULTS AND BLOOD TEST RESULTS


         1         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
        J              ENVIRONMENTAL MONITORING AND SUPPORT LABORATORY
        *                          RESEARCH TRIANGLE PARK
                                    NORTH CAROLINA 27711

                                      April  5, 1977
     Dr. Mohamad N.  Khattak
     VERSAR,  Inc.
     6621  Electronic Drive
     Springfield, Virginia  22151

     Dear  Dr.  Khattak:

          Listed below you will find Versar percent recoveries for the quality
     assurance spiked kepone filter samples sent to you by Dr. Moseman.  In
     all cases, other than the blanks, your reported values are lower than
     the spiked kepone concentrations reported by Dr. Moseman.

     Filter              EPA                Versar              Versar
     Number    Spiked Concentration        Analysis           % Recovery
     _    _ ng/f i 1 ter _        ng/filter          _
      004                 2500                2200                 88
      005                 1250                 760                 61
      006                   0              None detected
      007                 500                 360                 72
      008                 1250                 960                 77
      009                 2500                1880                 75
      010                 500                 430                 86
      Oil                 1250                 950                 76
      012                   0              None detected
      013                 1250                1010                 81
      014                 500                 420                 84
      015                 2500                2470                 99
      016                 500                 410                 82
      017                 2500                2070                 83

                                                  Average        80%

          If you have specific questions concerning sample preparation and
     analysis, please contact Dr. Moseman directly.
                                       Sincerely yours,
                                        Thomas A. Hartlage
                                  Chief, Field Studies Section
                                 Environmental Monitoring Branch
                                             (MD-76)
    cc:  Dr. Moseman (MD-69)
         R. Carnes, EPA, Cincinnati
                                     134

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                                               0,

JAMES B. KENLEY.M.D.                    Department of Health
COMMISSIONER                         Richmond. Va. 23219

                                       SUBJECT:   KEPONE  INCINERATION TEST

                                       25 March  1977


    Dr.  Prank Whitmore
    Versar, Inc.
     6621 Electronic Drive
     Springfield, Virginia   22151

     Dear Dr. Whitmore:

    We have received the analyses  of  the blood samples collected
     before and after the Kepone Incineration Test  Program on personnel
     who were to work on the test program.   This is to  advise that  all
     samples were negative and  no Kepone was detected.

     I  would appreciate it if you would  pass this information on to
     the appropriate personnel.


                                       Sincerely,
                                       Eric H.  Bartsch,  P.  E.,  Director
                                       Bureau of Sanitary Engineering
     EHB/c
                                   135

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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
 . REPORT NO.
 EPA-600/2-78-108
              3. RECIPIENT'S ACCESSION NO.
 A. TITLE AND SUBTITLE
 KEPONE INCINERATION  TEST PROGRAM
                                                            5. REPORT DATE
                                                              May 1978  (Issuing Date)
             6. PERFORMING ORGANIZATION CODE
 7. AUTHOR(S)
  Bruce A. Bell
  Frank C. Whitmore
                                                            8. PERFORMING ORGANIZATION REPORT NO.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Design Partnership
  Richmond, Virginia   23226   and
  Versar, Inc.
  Springfield, Virginia   22151
              10. PROGRAM ELEMENT NO.  ]DC618

               SOS #4, Task 10
              11. CONTRACT/GRANT NO.

               R-805112-01-0
 12. SPONSORING AGENCY NAME AND ADDRESS
 Municipal  Environmental  Research Laboratory—Cin.,OH
 Office of Research and  Development
 U.S.  Environmental Protection Agency
 Cincinnati, Ohio  45268
                                                             13. TYPE OF REPORT AND PERIOD COVERED
              14. SPONSORING AGENCY CODE

               EPA/600/14
 15. SUPPLEMENTARY NOTES
 Richard A.  Carnes  (Project Officer) 513/684-7871
 16. ABSTRACT
 The  Kepone Incineration  Test (KIT) program was  undertaken to evaluate incineration
 as a method of destroying  Kepone and Kepone-containing materials  and to determine
 the  range of operating variables required for complete destruction.   The program was
 divided into two phases:  (a) experiments involving the direct  injection of low BTU
 solutions of Kepone into the afterburner, and (b)  experiments  involving the co-
 incineration of sewage sludge and various amounts  of Kepone injected into a rotary
 kiln.   Each phase was designed so that succeeding  experiments  involved longer amounts
 of Kepone and/or alterations in afterburner  temperature and residence time.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
 Research
 Temperature
 Degradation
 Organic Compounds
Retention  Time
Excess  Air
Incineration
Rotary  Kiln
13B
 8. DISTRIBUTION STATEMENT
RELEASE TO PUBLIC
                                               19. SECURITY CLASS (ThisReport)'

                                                 UNCLASSIFIED
                           21. NO. OF PAGES

                              146
20. SECURITY CLASS (Thispage}
  UNCLASSIFIED
                           22. PRICE
EPA Form 2220-1 (9-73)
                                             136
                                                                       ft U.S. GOVERNMENT PRINTING OFFICE: 1978— 7 5 7 -140 /1333

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