Unmd!
Environmental Proi*cno"n
' (Wet of
Solid Wi»i« and
Em«rg«ncv
DIRECTIVE NUMBER: 9527.02(84)
-:'-- f .. "".
TITLE: -Permitting Mobile Treatment Units, PAT Comments;
EPA's Mobile Incinerator, Denney Farm Site, MO
APPROVAL DATE: --7-20-84.,;. .j;.v^.;:. -.. ......
•»..«••"•..'•••>•. '"''y_ i •• ' •". -• •' •— " •'. .'.- i,' .• "'• .-. '-7'.-". . • .•
"EFFECTIVE DATE: >T26:84 ' "
• •'•.. - * • *••'*" ^-" '
.. •.' .f,
- • *- • •
-------
PART 270 SUBPART F-- SPECIAL FORMS OF PERMITS DOC: 9527.02(84)
Key Words: Incineration
Regulations: 40 CFR 270.62
Subject: Permitting Mobile Treatment Units, PAT Comments: EPA's Mobile
Incinerator, Denney Farm Site, MO
Addressee-: Joe Galbraith, Permit' Writer, Region VII
Originator: Randolph L. Chrismon, PAT Incinerator Coordinator
Source Doc: #9527.02(84)
Date: 7-20-84
Summary:
Applicants for permits for mobile treatment units should use the model
application and permit developed at the first permitted mobile treatment unit
site to expedite permit processing at subsequent sites.
Under RCRA, a mobile treatment unit must obtain a permit for each site where
it intends to operate. To reduce the burden on such units, RCRA regulations
allow the permittee to submit results of a validly conducted trial burn in lieu
of a trial burn plan at subsequent sites.
The EPA promulgated final regulations on January 14, 1985, listing several
dioxln waste streams as acutely hazardous wastes. The regulations which go
into effect July 15, 1985, require interim status as well as permitted inciner-
ators to demonstrate that they have a "99.9999% ORE for each principal organic
hazardous constituent (POHC) designated .... This performance must be
demonstrated on POHCs that are more difficult to incinerate than tetra-, penta-,
and hexachlorodibenzo-p-dioxins and dibenzofurans." A RCRA permit cannot be
issued for dioxin wastes until July 15, 1985. If a RCRA permit is issued before
that date, and the applicant wants to add any of the new listed wastes to their
permit, it would require a major modification of the permit.
Mobile incinerators must be treated as new facilities when operated in
areas that differ from the area specified In the original operating permit
and therefore satisfy additional regulatory requirements. Substantive
procedural requirements for permitting include establishment of a statement of
basis and an administrative record supporting each operating condition in the
permit, and public participation in the decision making process.
-------
9527.02 (84]
JX20E6J
HEMOPANDUM
Subject: PAT Connents: EPA's Mobile Incinerator, Denney Fara
Site, HO
Promt Randolph L. Chrisaon
PAT Incinerator Coordinator
Tot Joe Galbraith
Permit Writer, Region 7TI
I have completed my review of ORD'a application to operate
the Mobil* Incinerator at the Denney Para site in Missouri. I have
several general comments that I will discuss in this memo and
specific comments that are set forth in the attached PAT document.
My first concern is that there are several major deficiencies
in this application. These deficiencies are of such a nature that
this application* in its current font, will not support the issuance
of a RCRA permit for incineration. These deficiencies could have
been avoided by complying with the attached po'licy from the Assistant
Administrator on permitting mobile treatment units.
The objective of the mobile treatment unit policy is to
facilitate the issuance of peraits to such units by developing a
model application, and. permit at the first site where the unit is
permitted. The applicant could than use this model application and
permit to expedite permit processing at subsequent sites. The model
application and permit for this facility were developed in Region
II. ORO should have used those models to prepare its subraittal to
Region VII. ORD, however, submitted an entirely new application.
This aew application fails to address several major issues which
were resolved in the original application and perait.
In the inerest of time, I urge you to encourage ORO to submit
the model Region II Kin-Buc application to Region VII along with a
letter incorporating all relevant portions of the Region II appli-
cation by reference. In the meantime, you should encourage ORE to
implement the mobile treatment unit policy by revising the site-
specific portions of the model application so that document can
stand on its own as the basis for permitting this incinerator.
My second concern is that ORO appears to believe they can get
a national RCRA permit by satisfying the trial burn requirements in
Region VII. RCRA makes it clear that a mobile treatment unit must
get a permit for each site where it intends to operate. While this
-------
imposes a burden on mo5He treatment units, both the regulations
and the taobile treatment unit policy provide some relief. First,
the regulations allow ORD to su'Mait the results of. a validly eon-
ducted trial burn in lieu of a trial burn plan at subsequent sites,
thereby saving the coat and effort of conducting an additional
trial burn. Second, the Mobile treatment unit policy reduces the
amount of time necessary to prepare and review the new application
becauaa significant portions should have already been reviewed. In
no case, however, do the regulations or the mobile treatment unit
policy allow for a nationwide RCRA perait.
My third concern is the reoeated references to a RCRA permit
to incinerate TCDD. TCDO is not now a RCRA hazardous waste. The
Agency has proposed regulations listing TCDD as a hazardous waste
but these regulations have not been pronulgated. Until the final
rule is published in the Federal Register, the Arjency cannot assume
in advance what technical standards will be required to treat, store
or dispose of TCDO and cannot issue a perait for the treatment,
storage or disposal of TCDD. He can conduct a trial burn using
TCDD as a POHC because it is listed in Appendix VIII. ORO is free
to conduct such tests with the goal of demonstrating 99.9999% DR£
but mist keep in aind that there is no assurance this will be the
standard once the dioxin rule becomes final. Finally, if ORD
receives a RCRA pemit and the dioxin rule is promulgated and
beeones effective before ORD has completed its activities, a major
modification to the perait may b*j..necessary.
All parties must recognize that the Mobile Incinerator oust be
treated as a new facility at the Denney Para site. The Mobile
Incinerator does not have interim status in Missouri and its perait
is for operations at Kin—Buc in Region II. Since the unit aust be
treated as a new incinerator, several additional regulatory require-
ments- nust be satisfied. ORD has not addressed these requirements
in the submission to Region VII (see specific comments), although
these were addressed in the model application.
Finally, many people in the Region and Headquarters are familiar
with this unit, its details of operation, and its capabilities. 1C
the only substantive procedural requirement was to satisfy the
pemit writer that the incinerator could an
-------
cc t
Lyndell Harrington
D«rtd W«gon«r
Frank rr««mton«
Ira wild«r
John H. Skinner
a rue* K. W«xjdl«-
Pflter Guerrero
Tarry Grogan
-3-
-------
PAT COMMESTS
U.S. EPA KOHLS INCINERATOR
DENSKT FAJW SITS, MO.
All cites are to title 40
of th« Coda of Federal Re-
gulations (40 CFR)
1. 270.«2(a),
270.<52(b)(l)
2. 270.<2(c)
3. 270.62(b)(2)
(i), waste analysis
Thi* !• a new unit at the Denney Fara
•It*. The applicant Must propose condi-
tion* necessary to oo«rate in compliance
with the performance standards in 264.343.
The proposed conditions must address the
initial start up of the Incinerator after
and what e-rer period of tirae up to 720
hours is necessary to ensure that all
•ystests are functioning properly. During
this period/ the applicant Bust propose
restrictions on waste constituents, waste
feed rates and the operating parameters.
••suits from the trial burn in Region II
would help in establishing the appropriate
•hake-down operating parameters but the
applicant failed to provide the detailed
Information necessary (note that the
tables at D-3 through D-12 are not adequate
to «et operating conditions and/ without
the supporting docuzoentat ion, are con-
elusory in nature). -
The applicant also needs to provide
•iailar information for operations after
the trial burn but before final permit
sodification. This information could be
supported by the original application and
permit if the applicant incorporates
these docunents by reference. The regula-
tion* require restrictions on waste
constituents, waste feed rates, and
operating parameters. If ORO sunnli*s
the information required at 270,62(b)(6)-
(3) originally developed tor tn«» Raqion
II permit, it is likely that such restric-
tions would allow, at least, the Incinera-
tion of PCB contaminated liquids anj
oth«r PCRA hazardous wastes until fir.al
permit modification.
The applicant nust provide an analysis of
the waste in the for-n and cornosition in
which it will be burne-J. Furthers re,
264.340 requires that the applicant demon-
strate 99.99% ORE of POHC for each waste
-------
£••4* The trial burn*a purpose ia to
dcaoaatrata that the incinerator can
adequately treat haxardous waste in tha
fora in which that waste ia fed to tht»
inclaerator. Therefore, the applicant
•uat provide the following information:
a). A listing of all Appendix VIII
constituents present in the contarsina tar?
soil and liquid wastes to be incinerated.
b). A listing of all Appendix VIII
constituents not reasonably expected to
be found in the waste and the basis ^tor
excluding these wastes.
c). Representative heat values for all
waste streaas and viscosity for all
liquid waste streaas (including contami-
nated water; see consent below).
d}» The wasta analysis mist rely on
analytical techniques specified in SV-345
or equivalent. The acutal test oetncxj
•ust be specified or/ If a method equiva-
lent to SW-34S is used, the basis for
determining equivalency.
4. 270.C2(b)(2)(i) TXe applicant appropriately proposes the
con't use of artificial waste feeds during the
trial burn in order to establisn a flexible
operating envelooe for the incinerator.
The applicant fails, however/ to prop so an
acceptable aritifical feed. The applicant
proposes to use PC3s and CC14 absorbed on
Imbiber beads and mixed with sand as a
surrogate for contaminated soil. labiber
beads provide aa organic and, therefore,
aoobustible ma,trix for containment of
the POHCa. The actual POKCs, however,
will be absorbed on contaminated soil, a
relatively inorganic and, therefore,
incombustible matrix, while it is irrele-
vant for RCRA permitting whether the
incinerator actually decontaminates the
soil, the characteristics of the soil are
relevant to a determination as to whether
there will be more or less PQUCd in the
flue gas. Substitution of.a combustible
matrix for an inco'inust ible matrix is not
an adequate surrogate for tha waste in
the foroi in which it will be inc iner
I would, therefore, propose that the
applicant use b«ntonita as' the absorptive
aiatrix for the solids test burn.
-2-
-------
4. Continued The applicant proposes to uae clean water
to cool the rotary kiln during the trial
burn but indicates hi* intention to use
contaminated water during actual operations
The applicant•aust either use contaminated
water during the trial burn and satisfy. .
the waste analysis requirements for this
waste feed/ or the applicant will be
limited to the use of clean water durinc
operations. The choice is up to the apoli-
cant. Acain, the regulations require the
99.99% ORE demonstration to be made on
the waste in the fora in which it will be
incinerated.
5. 270.62(b)(2)(ii) The applicant needs to provide a better des-
Detailed engineering cription of the solids feed Mechanist*.
description. A schematic drawing would be helpful
although a aore complete rerbal description
will do* The information should be
sufficient to show the permit writer that
waste feed rate will be accurately and
continuously monitored, that automatic
waste feed cut-off will be successful,
and that fugitive emission will not
escape from the solids feed mechanism.
The applicant's statements as to tne
above requirements are not sufficient;
the drawings and description must demon-
strate actual compliance with these
requirements.
The description of the automatic waste
feed cutoff system is inadequate in that
several parameters for initiating cutoff
have not been identified. Specifically,
what are the minimum and maximum combustion
gas velocities, maximum solids feed rate,
maximum temperature at the HX scrubber,
miniaun quench water, aaximun pressure
droo across e*ch air pollution control
device, mini-u.Ti pressure drop at tne I. L.
fan, maxinun vibration amplitude, etc.
Most of this information is contained in
the original aoplication and should be
reproduced here.
I an confuted as to wf.ether the water
injection nozzles ancJ the waste oil
injection nozzles are the sar-s cr different
Clarify.
-3-
-------
f. - T70.C2(b)(2H£U
con't
270.62(b)(2)(lli)
Planned analytical
procedures
270.62(b)(2){v>
Test protocol
Pmrt 264.347 r»qulres;"aaonc other things,
that CO be monitored on a continuous
basis. Continuous means continuous, not
once every fire minutes. 264.345 requires
that the waste feed autoaatically cease
if CO levels sat in the permit are
exceeded. This a»eans the continuous CG
•onitor Must be tied into the automatic
waste feed cutoff. Therefore, the
applicant aiust tie the NOIR into the
waste feed cutoff and propose a limit
which will trigger automatic waste feed
cutoff. This limit nay be higher than
the liait that will trigger waste feed
cutoff fro« the GC.
The applicant does not provide information
procedures to clean all qlassvare, sampling.
devices, etc. This trial burn will
require state of the art trace organic
analysis. Particular attention must be
paid to adequate preparation of all
sampling, storage, and analytical hardware.
Extraction methods for the
have not been specified.
solids feed
The protocol citeJ for the VOS train
is obsolete. The procedure in EPA 600/
8-84-007 should be used.
The procedures for analyzing solids
samples (including use of a aortar) aay
result in volatilization o£ CC14. In
fact, the discussion generally does not
account for CCl^s high volatility. Pro-
cedures must be adopted that either mini-
mize this lo*s or quantify it.
As mentioned earlier, the applicant Bust
either deoonstrate adequate ORE on an
aqueous waste or use only clean water to
cool the rotary kiln. If the'applicant
elects to demonstrate D?.E on a contaminated
water, he aust propose appropriate ranges
of feed rate, PORC concentration, continuous
feed rate monitoring, etc.
-4-
------- |