AGILITIES EVALUATION
OF HIGH EFFICIENCY BOILER
DESTRUCTION OF PCB WASTE
July 1980
By:
J.E. Cotter and R J. Johnson
Contract Number 68-02-3174, Task Number 11
EPA Project Officer: D.C.Sanchaz
INDUSTRIAL ENVJRONMENTAL RESEARCH LABORATORY
US. ENVIRONMENTAL PROTECTION AGENCY
!ANGLE PARK, N.C. 27711
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AGILITIES EVALUATION
OF HIGH EFFICIENCY BOILER
DESTRUCTION OF PCB WASTE
uly 1980
By:
J.E. Cotter and R J. Johnson
Contract Number 68-02-3174, Task Number 11
EPA Project Officer: D.C. Sanchez
INDUSTRIAL ENVIRONMENTAL RESEARCH LABORATORY
U.S. ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PARK, N.C. 27711
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FACILITIES EVALUATION OF HIGH EFFICIENCY
BOILER DESTRUCTION PCB WASTE
by
J. E. Cotter
R. J. Johnson
TRW, Inc.
One Space Park
Redondo Beach, California 90278
Contract No. 68-02-3174
Program Element No. C1YL1B
EPA Project Officer: David C. Sanchez
Industrial Environmental Research Laboratory
Office of Environmental Engineering and Technology
Research Triangle Park, NC 27711
Prepared for
U.S. Environmental Protection Agency
Office of Research and Development
Washington, DC 20460
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ABSTRACT
A rendering plaint byproduct, yellow grease, was found to be contamin-
ated by PCB's from a transformer leak. The PCB content (under 500 ppm)
determines the method of disposal under 40 CFR Part 761. For this evalua-
tion, destruction in a high efficiency boiler was evaluated as an alternative
to landfill disposal. The process steam boiler belonging to the waste
owner, Seattle Rendering Works, was evaluated as a candidate site for waste
destruction. The logistics and fuel handling requirements were found to be
feasible to set up 1n a short time, and the boiler size and residence time
were determined to be likely to allow high destruction efficiency. With
99.9% destruction of PCB's, the downwind concentration was estimated by
diffusion modeling to be less than OSHA limits for industrial exposure*
Fuel characteristics of the yellow grease were used to support the recom-
mendation for 100% grease fired as fuel.
A second high-efficiency boiler candidate was also evaluated. The
Shuffleton power plant, operated by Puget Sound Power & Light Company,
operates three boilers from a common oil fuel supply system. The size and
facilities at this site were determined to satisfy all the prerequisites
for high efficiency boilers (40 CFR Part 761), and to best be operated by
blending the waste with the normal fuel oil supply. A 30% waste blend was
evaluated and found to be completely miscible and feasible with respect to
logistical support.
A verification test bum was recommended and outlined for either can-
didate site. Current EPA protocol and policy developments for PCB destruction
were found to be appropriate for the preparation of a candidate facility
test poan and an example public notice.
This report 1s submitted in fulfillment of Contract Nol 68-02-3174, Work
Assignment No. 11, by TRW Environmental Engineering Division, under sponsorship
of the U.S. Environmental Protection Agency. This report covers the period
10 January 1980 to 1 April 1980, and work was completed as of 1 July 1980.
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CONTENTS
Abstract
1. Background information ............................................ 1
Source of contaminated waste ................... ,...,.... ..... 1
D1 sposal optl ons .................. . ....... . .................. 1
Prerequisites for high efficiency boiler destruction ......... 2
Candidate sites for waste destruction ........................ 2
Scope of work reported ............. * ..... . .................. .3
2. Seattle rendering works analysis .................................. 4
Facility background ................................... . ...... 4
Plant operations ............................................. 4
Reconmendations of the feasibility of using the Seattle
rendering boi 1 er ...................... . , . . . ..... . .......... 6
Recommendations for facility modifications requirements ...... 9
Conduct of the waste Incineration ........................... 10
Envi ronmental impact ........ . ............................... 13
3. Shuffleton power plant analysis ................................. '16
Fad 11 ty background ......................................... 16
Plant operati ons. .................... . ...... * ........ . ..... 16
Recommendations on the feasibility of using the Shuffle ton
boilers for PCB waste incineration ........................ 18
Recomnendations for facility modifications .................. 21
Conduct of the waste incineration ........................... 21
\
Environmental impact ............ . ........................... 23
References ...................... .... .............. . ....... . . ........ 25
Appendix A. Local meteorological data ........................ - ...... 26
Appendix B. Test Plan for evaluation of PCB destruction efficiency
at the candiate fadHtes ................................. 2S
Appendix C. Example public notice .................................... 36
11
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1. BACKGROUND INFORMATION
SOURCE OF CONTAMINATED WASTE
A quantity of tallow (yellow grease), produced from the rendering of
chicken packing by-products, was contaminated by a transformer leak at a
packing plant 1n Billings, MT. The Incident occurred 1n 1979, and by mid-
1979 the contaminated yellow grease had already been sold to distributors who
had combined the contaminated material with other stocks. Routine FDA Inspec-
tions Identified the PCB contamination, and subsequent analyses of blended
stocks were carried out. The FDA notified the EPA Region X headquarters in
September 1979 of the results of those analyses where the PCB content was
greater than 50 ppm, and therefore subject to EPA jurisdiction (1).
All grease stocks containing more than 50 ppm of PCB were traced to two
tanks at 2900 llth Avenue SW, Seattle, WA; the grease is owned by Seattle
Rendering Works, Inc., Seattle, WA. The tanks contain (as of the date of this
report) approximately 500,000 Ibs and 600,000 Ibs, or about 150,000 gallons
total (2). FDA inspection of the grease revealed PCB concentrations ranging
from 116 to 391 ppm, (3) based on four samples taken from the tanks, and
duplicate assays.
DISPOSAL OPTIONS
The contaminated grease, having a PCB content of under 500 ppm, does not
require destruction in an EPA-approved Incinerator (1). The final ruling
governing PCB disposal, 40 CFR Part 761 (1), Identifies destruction In high
efficiency boilers or disposal in chemical landfills as acceptable alternatives.
"High efficiency" boilers are defined to include power generation boilers
and Industrial boilers that operate at a high combustion efficiency (99.9%) as
defined by the percentage ratio of C02 to CO+C02 concentrations 1n the combus-
tion gases. These boilers are assumed to be capable of achieving 99.9% or
greater PCB destruction efficiency.
There are two approved locations in EPA Region X where PCB contaminated
waste may be disposed. These chemical landfills are Chem-Nuclear Systems
(Arlington, OR) and Wes-Con (Grand View, ID). It was estimated by Region X
that landfill ing would cost a waste owner around 8
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PREREQUISITES FOR HIGH EFFICIENCY BOILER DESTRUCTION (1)
The Regional Administrator may grant approval for PCB Thermal destruction
In a boiler 1f a nuntier of prerequisites are met:
1. The boiler 1s rated at a minimum of 50 million BTU/hour,
2. The PCB contaminated waste comprises no more than ten percent (102)
of the total of volume of fuel,
3. The waste will not be added to the combustion chamber during boiler
start-up or shut-down operations.
4. The combustion emissions will contain at least three percent (32)
excess oxygen and the carbon monoxide concentration will be less
than 50 ppm for oil or gas-fired boilers or 100 ppm for coal-fired
boilers,
5. The combustion process will be monitored continuously or at least
once each hour that the PCB contaminated wastes are being burned
to determine the percentage of excess oxygen and the carbon monoxide
level 1n the combustion emissions,
6. The primary fuel and waste feed rates are monitored at least every
15 minutes whenever burning the waste,
7. The carbon monoxide and excess oxygen levels are monitored at least
once an hour and 1f they fall below the levels specified, the flow
of wastes to the boiler 1s stopped Immediately, and
8. Records are maintained that Include the monitoring data 1n (5) and
(6) above and the quantities of PCB contaminated waste burned each
month. When burning PCB wastes, the boiler must operate at a level
of output no less than the output at which the reported carbon
monoxide and excess oxygen measurements were taken.
CANDIDATE SITES FOR WASTE DESTRUCTION (2)
A survey of potential boiler or Incinerator sites by Region X produced
the following Initial possibilities:
1. The steam boiler at the Seattle Rendering Works plant, located at
5795 S. 130th Place, Seattle, WA;
2. The utility boilers at Puget Sound Power & Light's Shuffleton Plant,
located at 1101 Lake Washington Blvd., Renton, WA;
3. A kiln at Ideal Cement Co., 1n Seattle, WA;
4. A utility boiler at the Pacific Power & Light Centralla (WA) plant.
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Sites (3) and (4) subsequently dropped out of consideration, leaving the
Seattle Rendering and Puget Power boilers as candidates.
SCOPE OF WORK REPORTED
EPA Region X requested support in evaluating candidate boiler facilities
from IERL-RTP. The required support was provided by TRW under Contract No.
68-02-3174.
The scope of work Included an evaluation report for each facility, includ-
ing general background information, description of boiler and operating
procedures, and recommendations for modifications required to meet regulatory
requirements and good engineering practice, The scope also Included 9 Test
Plan for the evaluation of PCB destruction efficiency, and the preparation of
an example public notice of intent to conduct verification testing.
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2. SEATTLE RENDERING WORKS ANALYSIS
FACILITY BACKGROUND
The Seattle Rendering Works, Inc., facility 1s located at 5795 S. 130th
Place, Seattle, WA, adjacent to the Duwamish River and the Foster Golf Course,
The plant location 1s Indicated on the topographic map, Figure 1. The
vicinity of the plant Is mixed Industrial-commercial-residential. The nearest
residential areas are Immediately west of the plant (about 100 meters), and
about 400 meters north, on a bluff approximately 50 meters high.
The plant produces by-products from edible rendering operations, Includ-
ing tallow (or yellow grease). It operates three shifts. Seattle Rendering
1s also 1n the business of distribution of bulk sales of grease, through
purchases of smaller batches from other rendering plants. The manager 1n
charge 1s Mr. Wes Benefiel, President.
PLANT OPERATIONS
The boiler at Seattle Rendering Is a dual-fuel (gas and/or #6 oil) water-
tube Cleaver-Brooks model (Delta D-60) with a design capacity of 35,000 Ibs
steam/hr. The oil burner 1s a low-pressure, air atomizing type. The rated
gas-fuel efficiency Is 78$, so the design heat Input 1s 46,000,000 Btu/Hour.
The furnace volume Is 755 cu.ft. in the Immediate combustion zone, excluding
the upper radiant section. Typical stack temperatures at maximum firing are
550-560'F. The combustion zone temperatures are 1n excess of 2200°F at the
back wall. A steam-heated preheater 1s capable of raising Incoming oil temp-
eratures up to 100-240eF. The oil feed pressure 1s maintained by a gear pump,
which Is protected by a duplex 30-mesh strainer on the suction side (4).
The boiler has the standard set of safety controls, Including a programmed
burner shut-down In the event of flame failure; low water conditions; low fuel
oil temperature; low fuel oil pressure; low atomizing air pressure; or excess
steam pressure. Under normal operation, the oil metering valve and the
secondary air flow butterfly are regulated by a modulating motor driving both
linkages (5).
The boiler operates at full modulation from a low fire to high fire
position, regulated by steam pressure, which 1s directly affected by steam
demand. Since a PCB destruction program would be required to operate at a
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'*c."iTiTTi"v77- ':/
::£*: / ,'/
S-t-r . V*- \'J_. ' / '
'V'i."!?"' }\
;"'""l » .
:..RJYerton.Hei
Figure 1. Seattle Rendering Works location
5
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steady rate of waste fuel consumption, there would be a change from normal
boiler operating practice. If the fuel waste were consumed at maximum fuel
feed rates, then some of the generated steam would have to be dumped when
process demands dropped off. In the case of waste fuel consumption at some
Intermediate rate, auxiliary heating must be made up by firing natural gas
simultaneously during high demand periods, and excess steam would have to be
dumped at low demand conditions.
Facilities for storage of yellow grease at Seattle Rendering Include two
270,000 Ib capacity heated storage tanks. The grease 1s pumpable at about
100°F, and congeals at lower temperatures. Other storage and transport equip-
ment Includes two 50,000 Ib Insulated trailers, and one 20,000 Ib Insulated
trailer. Very large heated storage tanks are rented at terminal facilities,
such as at Harbor Island.(6).
The processing operations are not expected to be hindered by the proposed
PCB waste Incineration. Presently there 1s a spare storage tank at the site,
and one of the large Insulated trailers (and the smaller one also) can be made
available.
RECOMMENDATIONS ON THE FEASIBILITY OF USING THE SEATTLE RENDERING BOILER
Suitability of Yellow Grease as Boiler Fuel (7)
The Inspection of a grease sample from one of the contaminated shipments
(Fujltsukl Maru II, port tank 09-15-79) produced the results, shown in Table
2-1; two grades of fuel oil are shown by comparison. These Inspection re-
sults provide some confidence that the grease could be burned undiluted,
since:
The viscosity 1s between that of 15 and #6 fuel oil, so atonrization
should be good with a burner that 1s usually run with 16 oil.
The fuel value of the grease 1s 932 of a 16 oil value.
The ash content 1s low.
Furthermore, a telephone report obtained from Mr. Keith Markegard at
Pierce Packing*confirmed that they had burned 600,000 Ibs of grease in their
steam boiler, with good combustion characteristics.
*Bmings, MT.
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TABLE 2.1 LABORATORY INSPECTIONS
Viscosity
SUS S 122*F
SUS g 200'F
Density, Ibs/gal
@ 122°F
@ 180-F
Btu/lb
Moisture %
Water & Sediment X
Carbon %
Hydrogen %
Oxygen X
Sulfur %
Ash %
Grease
143.7
59.8
7.459
7.266
16,779
0.41
2.8
76.6
11.9
10.5
0.01
0.12
#5 Fuel Oil
40
@ 60', 8.0
18.250
0.05
1
87.5
10.2
-
1.1
16 Fuel Oil
300
& 60*. 8.33
18,000
0.05
2
88.3
9.5
-
1.2
0.1
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Estimated Destruction Efficiency
The residence time of the PCB's in the furnace combustion zone has to be
determined as part of the evaluation of destruction efficiency.;. At a waste
feedrate of 6 GPM, the actual volumetric flowrate of combustion gases through
the 755 cu.ft. furnace volume is 43,097 ACFM, yielding a residence tine of
1.1 seconds. The residence time will be twice as long at a feedrate of 3 GPM,
since the gas volumetric rate is half as much.
The estimated destruction efficiencies under these conditions depends on
a number of factors, including:
t Comparison of residence time and temperature to those specified in
40 CFR, Part 761, Subpart E: 1200-C (2191°F) 9 2 seconds, or 1600'C
(2912°F) 0 1.5 seconds dwell:
{These conditions are for waste Incinerators, burning PCB wastes of
any concentration).
Estimated efficiency of the Cleaver-Brooks burner, and the ease of
atomization of the grease fuel, as compared to 16 fuel oil.
The likelihood of achieving high destruction efficiencies with PCB
concentrations of a few hundred ppm, vs. percentage range concentra-
tions found in some other wastes (it's always easier to remove high
percentages of high concentrations). 99.935 destruction efficiency 1s
often obtained with high efficiency incinerators and high PCB concen-
trations.
The likelihood of achieving 99.9 + % PCB destruction is estimated to be
very good at a 3 GPM feedrate, since the time and temperature relationships
may approximate those of good incinerator practice. It is less certain that
a 6 GPM feed rate would yield equivalent destruction efficiency, but the
operation at 6 GPM would certainly be preferred for reducing the program
length. Therefore, the verification test should determine the destruction
efficiency and combustion temperature at both feedrates.
The boiler operation under automatic control will allow full modulation
from low fire to high fire, regulated by steam pressure. High fire fuel
demand would be about 6 GPM, since the Btu content of grease and #6 oil are
similar. Low fire demand is about 25* of high fire, or about 1.5 GPM (4).
8
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Recommended Exceptions to Standard Prerequisites for Boiler Specifications
and Operations
Although the Cleaver-Brooks boiler at Seattle Rendering does not meet the
standard prerequisite of 50 million Btu/hr heat Input (at full output), 1t
comes close at 46 million Btu/hr.
It 1s recommended that the standard prerequisite of a maximum blend of
10% waste (with the remainder fuel oil) Is less appropriate for the Seattle
Rendering program than a 100% waste fuel choice. The 10% blend 1s based on
the possibility of using any waste, Including those with very low fuel value.
As already noted, the Btu content of yellow grease 1s very close to #5 or #6
fuel oils, and the combustion characteristics are judged to be good. Further-
more, there are no present facilities available for blending of grease and
fuel oil.
RECOMMENDATIONS FOR FACILITY MODIFICATIONS REQUIREMENTS
Logistics
Verification Testing; Use 50,000 Ib (-6700 gal) trailer, go for 1.5 days,
then switch to small (3000 gal) trailer for 0.75 days while large trailer is
returned to port for reloading. This assumes that flexible lines can be
directly coupled to the oil feed pump for the trailer.
Post Test; Transfer from 50,000 Ib trailer to heated 270,000 Ib storage tank
(9 days storage). The trailer will have to make 6 round trips to get the
tank filled. Since turn-around time (gate-to-gate) for a trailer 1s about 1
hour for loading, (or unloading) and the port-to-plant transit time 1s about
0.5 hr, 2 loads/day will be'easy. Three days of waste fuel can be brought
into the plant in one day.
A copy of each loading ticket should be recorded. If the transport of the
grease falls Into a hazardous waste category, compliance with the necessary
state and DOT manifest regulations will be required.
Trailer-to-Tank Transfer
A temporary dike must be set up around the transfer area, sized to retain
up to 10% of the storage tank capacity (10% X 4839 cu.ft. - 484 cu.ft.). This
can be made up with sandbags and 6 mil polyethylene. Vent control will not be
required because of the low volatility of grease and PCB's.
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The trailer and transfer hoses should be dedicated during the program.
The existing 300 GPM transfer pump can be used, along with existing transfer
hoses and quick-disconnect couplings.
Waste Fuel Handling System
This 1s Illustrated schematically 1n Figure 2. Modification or additional
equipment requirements are as follows;
a. Provide booster pump (20 GPM centrifugal, 0.5 HP) prior to existing
tank to oil feed pump (Note: existing 300 GPM pump cannot be used as
both a loading and feeding pump, since these two requirements will
conflict). Disconnect existing oil feed and return lines.
b. Tee from bottom discharge line to booster pump suction: break con-
nection at branch to second storage tank, to Insure that no contam-
inated grease could be run down to second tank. Provide valves on
suction and discharge to allow removal for repair if necessary.
c. Install 2 inch line from booster pump discharge to existing oil pump
suctionrun through back wall of boiler room to minimize run length.
Provide 1 Inch Insulation, and return line to storage tank to maintain
high flow velocity to prevent setting up,
d. Install pressure gages upstream of basket strainers at oil pump stand.
Additional measurement points that should be installed for adequate boil-
er monitoring during PCB Incineration include:
Flowrate indicator and recorder downstream of oil regulating valve.
A1r windbox pressure indicator.
CONDUCT OF THE WASTE INCINERATION
Verification Testing
Background emission levels will be determined by running the PCB emissions
testing procedure while the boiler is burning #6 fuel oil at a steady feed rate
A PCB analysis will be required for fuel oil samples.
Normally, three separate tests are conducted at the same conditions for
verification of the efficiency of PCB waste Incineration. In this program the
performance at multiple grease feedrates is needed to decide on recommended
operating conditions. Therefore, the verification test plan will be:
10
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CONNECTION TO
EXISTING RETURN LINE (c)
CONNECTION TO
EXISTING FUEL OIL
PUMP SET & FILTERS
(c), INSTALL PRES-
SURE GAGES (d)
DISCONNECT OIL FEED &
RETURN LINES (a)
BOILER ROOM
TEMPORARY 2" LINE (INSULATED) (c)
V I BL1
BLIND EXISTING
\ y CONNECTION TO
V S\ 2ND
v
270,000 Ib
STORAGE
300 GPM PUMP
EXISTING TRANSFER LINE
TEMPORARY 2" RETURN LINE(c)
BOOSTER PUMP (a)
Figure 2. Waste Fuel Handling Schematic.
11
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Duplicate tests at 3 GPM feedrate.
t Duplicate tests at 6 GPM feedrate.
Boiler fuel control must be set on manual during these tests.
If automatic boiler fuel control 1s used during subsequent Incineration,
the feedrate should be kept from going below the recommended feedrate by dump-
Ing steam 1f process demands are low. If the verification test demonstrates
that at least 99.92 PCB destruction 1s achieved, then the remainder of the
waste can be burned with confidence.
The emissions tests during the verification burn will be carried out
according to the GCA draft test manual (8). The test procedure will use an Inte-
grated sampling train with a solid adsorbent (florlsll) section that is effective
in capturing PCB's 1n low concentration. The sampling will be conducted
Isokinetically, with the sample probe positioned at a number of pre-specified
points during the traverse of the boiler stack, at two ports 90 apart.
The sampling effort Is expected to take 3 hours to get sufficient PCB capture
for analysis detection. The adsorbent material and impinger rinses will be
sealed and taken to a laboratory that Is experienced in PCB analysis. Both
gas chromatography (GC) and gas chromatograph mass spectroroetry (GC/MS)
analysis methods will be used for analysis of all PCB isomers. A quick
prescreening test for total chlorinated hydrocarbons will be used to evaluate
verification tests. A detailed description of the sampling and analysis
methodology for PCB destruction verification 1s given in Appendix B.
Operations and Surveillance
The boiler will be started up on natural gas fuel to reach steady opera-
tions, as determined by stack measurements of temperature, CO, and 02. The
grease circulation loop will then be started, Including the feed preheater.
When the feed temperature reaches 140-150*F, the grease fuel can be directed
to the burner and the gas fuel gradually reduced, such that stack temperatures
and steam pressure remains constant. The grease fuel should not be heated
above 180*F, since it may smoke at any point where 1t comes Into air contact
(probably the storage tank).
Surveillance of the boiler and fuel handling areas must be maintained on
a 24-hour basis, with the following data to be recorded: CO, 02* fuel rate.
12
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t Boiler shut-down should be done 1n a similar manner to start-up, with
gas fuel used to finish off the firing before shut-down. The grease
should be drained from the fuel line before any shut-down; otherwise
it should be kept hot and circulating.
t If a fuel leak 1s detected in the system that cannot be corrected by
a fitting adjustment, then the grease circulating loop must be shut-
down and drained prior to repair. The grease already spilled should
be allowed to congeal and then be scraped up and returned to the fuel
storage tank. Scraping congealed grease Into the hatch of an unload-
ing trailer may be possible. Final spill cleanup can be done with a
hexane solvent.
The contaminated waste will be transported 1n a dedicated trailer,
and transfer hoses will also be dedicated to the disposal program.
This procedure will avoid the mixing of contaminated grease with non-
contaminated grease.
Cjean-Uj)
The following equipment clean-up will be required:
- Trailer
- Transfer hoses
- Transfer pump
- Booster feed pump
- Feed and recycle lines, including fuel oil pump.
The entire transport-and-fuel feed system should be flushed with uncon-
tamlnated grease and combustion continued until the grease PCB concentration
drops below 50 PPM. The temporary connections can then be removed and the #6
fuel oil feed loop restored.
ENVIRONMENTAL IMPACT
The anticipated Impact of PCB waste burning at the Seattle Rendering
facility was modeled with a point-source dispersion model, actual stack dimen-
sions, and a range of local meteorological conditions, as reported from the
PSAPCA* station at Tuckwlla/South Center, about 2 miles south of the plant,
(Appendix A.).
*Puget Sound Air Pollution Control Agency
13
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The flat-terrain dispersion model 1s only useful for Impact analysis up
to the point of a significant terrain change. The prevailing winds at the
source location (35Z of the time) are south to southwest, with neutral (Class
"0") atmospheric stability.
There is a sharp terrain rise of 50 m. only 400 m. 1n a prevailing (SSW)
direction from the rendering plant source. The calculated effective stack
height is 40-65 meters. Model predictions at 400 m. of PCS concentrations at
the plume center-line (which is worst-case conditions) are as follows:
Feed Rate
6 GPM
6 GPM
3 GPM
3 GPM
Wind Speed
10 m/sec
4 m/sec
10 m/sec
4 m/sec
No PCB Destruction
6.4 yg/rn
16.0 yg/m
1.6 yg/m
4.0 yg/m
99. 9X PCB Destruction
6.4 ng/m
16.0 ng/m
1.6 ng/m
4.0 ng/m
The modeling estimates are based on calculated emission quantities as
follows:
6 GPM feedrate using worst case of 400 ppm PCB's: 9110 SCFM stack
discharge, 0.12 gm/sec uncontrolled, 0.12 mg/sec controlled emission
rates.
3 GPM feedrate, using moderate case of 175 ppm PCB's 4555 SCFM stack
discharge, 0.03 gm/sec uncontrolled, 0.03 mg/sec controlled emission
rates.
The ground-level concentration of the plume under flat-terrain assump-
tions may be more realistic at 1.5 to 2 km downwind, after the plume has
passed over the bluff. The atmospheric PCB concentrations for a 99.9J effi-
cient destruction operation are in the range of 0.1 to 0.4 ng/m .
Techniques for ambient monitoring of these extremely low PCB concentra-
tions are still being developed, but it 1s recommended that an attempt be
made to make such a measurement at the most likely downwind position, in
support of the verification test. The ambient monitoring methodology 1s
described In Appendix B,
14
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An analysis of downwash concentrations of PCB's was also done, using the
* an area source. In a downwash model, dispersal of pollutants
occurs In the Immediate, ground level vicinity of a source, rather than
through an elevated plume. Calculated atmospheric concentrations of PCB's
were estimated to be around 0.2 ng/m3 with 99.9% destruction, The OSHA
limit for worker exposure to PCB's on an 8-hour day, 40-hour week basis 1s
1 mg/m3 with 42 percent PCB chlorine content, so that the downwash concentra-
tion certainly does not threaten worker safety.
15
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3. SHUFFLETON POWER PLANT ANALYSIS
FACILITY BACKGROUND
The Shuffleton Power Plant, owned by the Puget Sound Power and Light Co.(PSPL)i
1s located at 1101 Lake Washington Blvd., Renton, WA. The plant 1s on the
southern edge of Lake Washington, as Indicated on the topographic map,
Figure 3. The vicinity 1s generally Industrial and recreational. The near-
est residential areas are about 1 km east of the plant.
Shuffleton 1s operated at a steady level of 330,000 Ib/hr of steam 1n
each of three oil-fired boilers. The plant was constructed in 1929, and 1s
expensive to operate. Consequently, Shuffleton 1s only run when the antici-
pated load demand in the PSPL service area cannot be met by other generating
sources (9), The plant superintendent is Mr. Bill Clark.
PLANT OPERATIONS
The Shuffleton boilers are balanced draft type (FD, ID fans); there are
16 Peabody mechanical burners in each boiler, burning #6 fuel oil heated to
200"F.
The available measurements Include air/fuel ratio, oil pressure, wlndbox
pressure, furnace draft, fuel oil temperature, air preheater temperature and
pressure, and oxygen in the stack gases. Fuel oil 1s not presently metered,
although an orifice exists in the fuel oil line.
The fuel oil is supplied from large storage tanks to two smaller service
tanks, each having a working capacity of 800 bbls. The tanks are run alter-
nately, on about a 5-hour cycle, while 3600 to 3900 bbl per day of fuel oil
are consumed. The tanks have open hatches at the top which could be used
for pumping in other fuels to get a mixed fuel. The fuel is kept at 150'F
in the service tanks. The fuel oil 1s pumped out of the service tanks by
three 80 GPM pumps, and distributed through heat exchangers to raise the fuel
temperature to 200*F. The fuel is then Injected Into each of the burners 1n
the three boilers. The viscosity of #6 oil is sufficiently lowered by the
200°F preheat to get good burner and combustion performance (9).
The operations of the Shuffleton power plant are not expected to be
hindered by the proposed PCB waste Incineration, as indicated by the follow-
16
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^wLdWTsn rW^r
v / - py ft - ^m
fi1' fr^ **^! v:\w
Figure 3. Shuffleton (Puget Power) Plant location
17
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1ng discussion on feasibility. Three-shift operations coverage of the boiler
and fuel handling system will provide the necessary surveillance of combus-
tion performance that 1s needed for PCS Incineration. There Is reason to
believe that close surveillance 1s mandatory for maintaining good combustion
at Shuffleton. The plant has received frequent citations for opacity vio-
lations (10), despite a test of the No. 1 boiler which showed particulate
emissions within compliance (11). A combustion'consultant's report submitted
to Puget Power Identified possible causes of poor combustion to Include
Inadequate fuel atomlzatlon (due to low fuel oil temperature) and dirty
burners (12).
RECOMMENDATIONS ON THE FEASIBILITY OF USING THE SHUFFLETON BOILERS FOR PCS
WASTE INCINERATION
Suitability of Yellow Grease as a Boiler Fuel
The first consideration for suitability 1s the determination of nrisd-
b111ty, or degree of mixing, of grease and 16 fuel oil, since using a blended
fuel 1s the technically simplest method for waste Incineration 1n a large
boiler. Yellow grease and 16 fuel oil mixing tests were conducted by North-
west Laboratories at two blend ratios (10* and 30% grease, by volume) and two
temperatures (180*F and 200*F). The results of these four tests were consist-
ent; the blends were misclble, with no stratification, at all conditions (13).
The Inspection of a grease sample from one of the contaminated batches
by Northwest Laboratories produced the results reported In Table 2-1; two grades of
fuel oil are shown by comparison.
The previous Inspection results provide further confidence that the
grease will combust well with 16 fuel oil, since:
The viscosity 1s between that of #5 and 16 fuel oil, so burner
atomlzatlon with the blended fuel should be good.
t The fuel value of the grease 1s 93* of a #6 oil value.
The ash content 1s low.
Estimated Destruction Efficiency
The residence time of the PCB's 1n the boiler combustion zone 1s a con-
sideration 1n the evaluation of destruction efficiency. At a typical fuel
18
-------
feed rate of 38 6PM, and 4-5% excess cwygen, the calculated rate of combus-
tion gas flow 1s 1111 std. cu ft/sec (14). The estimated residence time 1n the
lower half of the boiler 1s 2.5 seconds, with another 2.5 seconds dwell in
the upper zone (15). The temperature 1n the combustion zone 1n the vicinity
of the burners, has been measured at 2800»F (16).
The estimated destruction efficiencies under these conditions depends on
a number of factors, including:
t Comparison of residence time and temperature to those specified in
40 CFR, Part 761, Subpart E: 1200°C (2192°F) @ 2 seconds, or 1600°C
(2912°F) § 1.5 seconds dwell:
(These conditions are for waste incinerators, burning PCB wastes of
any concentration).
Efficiency of the burners and the ease of atomization of the grease
and 16 fuel oil blend.
The likelihood of achieving high destruction efficiencies with
blended PCB concentrations of less than a hundred ppm, vs. percentage
range concentrations found in some other wastes (it's always easier
to remove high percentages of high concentrations). 99.99% destruc-
tion efficiency 1s often obtained with high efficiency Incinerators
and high PCB concentrations.
The likelihood of achieving 99.9% PCB destruction is estimated to be
good, given the similarity of the boiler conditions to good incinerator prac-
tice, and the compatibility of the grease and #6 fuel oil.
Becoroiended Exceptions to Standard Prerequisites for Boiler Operations
It is recommended that the PCB incineration be conducted with a grease-
to-fuel oil ratio of 30/70 instead of the standard prerequisite ratio of
lo/90. There are good arguments for using a 3055 blend, since the length of
needed to complete the effort will be shortened by a proportionate
, and the grease 1s not expected to cause any combustion problems or
ble heat reductions. The environmental consequences of burning a SOX
blend, and the logistical limitations of supporting a higher grease percent-
are discussed below.
19
-------
RECOMMENDATIONS FOR FACILITY MODIFICATIONS
Logistics
The two alternating service tanks (800 bbl working capacity) will be
used for temporary storage of the grease (as a blend), and for making up a
blend in the off-line tank; this should be done while the tank Is filling
with #6 oil, to get the benefit of agitation during the fill.
If a 10% blend 1s made up, 1t would require 3200-3400 gallons of grease
to be added to the service tank, and one trailer (6500 gal. capacity) for
support. The single trailer could probably split a load between two alternate
tank fillings, and then return to the port. The plant-to-port round trip,
with filling, 1s estimated to take 3 to 4 hours. This turnaround time will
not be limiting, given a 5-hour cycle time with the tanks.
If a 302 blend 1s made up (as recommended), it would require 9600-10,200
gallons of grease addition per tank, and two trailers for support. They
would both be required to return for reloading following each tank filling.
Blends much greater than 302 would cause a logistical limitation.
Traller-to-Tank Transfer
The rundown line between two large storage tanks and thessrvlce tanks has
a connection that could be used for transfer, but top-filling of the service
tanks is preferred for the agitation benefit. The transfer area must have
a temporary dike set up, sized to retain a trailer load (under 1000 cu.ft.)
using sandbags and polyethylene sheet.
The transfer pump and temporary power connections must be provided, along
with transfer hoses. The transfer pump should have about a 200 GPM capacity,
to prevent any unnecessary hold-up time for trailers.
CONDUCT OF THE WASTE INCINERATION
Verification Testing
Background emission levels will be determined by running the PCS emis-
sions testing procedures while the boilers are burning uncontamlnated #6 fuel
oil. A PCB analysis will also be done on fuel oil samples.
20
-------
The schedule will Include emissions testing on three sequential days of
operation, to determine what day-to-day differences may occur. This series
of tests will be done with one batch of blended grease and fuel oil each day,
so that PCB's will not be burned unless emission testing 1s In progress.
Continuous oxygen and carbon monoxide monitoring of stack gases will also be
done during the verification test sequence. If the verification test demon-
strates that at least 99.9% PCB destruction is achieved, then the remainder
of the waste can be burned with confidence.
The emissions tests during the verification burn will be carried out
according to the 6CA draft test manual (8). The test procedure will use an
Integrated sampling train with a solid adsorbent (florisil) section that 1s
effective in capturing PCB's 1n low concentrations. The sampling will be
conducted 1sok1netically, with the sample probe positioned at a number of
prespecified points during the traverse of the boiler stack. Since equal
amounts of fuel are supplied to each of the three identical boilers, then 1t is
sufficient to sample one stack rather than all three. The sampling effort
1s expected to take 3 hours to get sufficient PCB capture for analysis
detection. The adsorbent material and Impinger rinsed will be sealed and taken
to a laboratory that is experienced 1n PCB analysis. Both gas Chromatography
(GC) and gas chromatograph-mass spectrometry (6C/MS) analysis methods will be
used for analysis of all PCB Isomer, A quick prescreenlng test for total
chlorinated hydrocarbons will be used to evaluate verification tests. A
detailed description of the sampling and analysis mehtodology for PCB destruction
verification is given in Appendix B.
Operations and Surveillance.
The grease should not be pumped Into the fuel oil service tank until it
nas been established that the boiler Is operating satisfactorily, as evidenced
by the combustion parameters holding at the criteria specified by regulation
40 CFR 761, and visual Inspection of the burner flame. After the blended
fuel firing 1s initiated, a relnspectlon of the combustion parameters will
be required.
Surveillance of the boiler and fuel handling areas must be maintained on
a 24-hour basis, with the following data to be recorded: CO, 02, fuel rate.
Periodic measurements of COz will also be done.
21
-------
Clean-Up
The following equipment clean-up will be required:
- One to two trailers
- Transfer hoses
- Transfer pump
If any spill or leak occurs during trailer unloading, the equipment used
to scrape up the congealed grease will also require cleaning. A hexane sol-
vent can be used for cleaning, and added to the fuel oil 1n small quantities.
The blended grease and fuel oil will probably not be considered a contaminant
in the fuel oil handling system, since the PCB content will be well below
50 ppnu The system will be purged by the routine use of uncontamlnated fuel
oil.
ENVIRONMENTAL IMPACT
The anticipated Impact of PCB waste burning at Shuffleton power plant
was modeled with the EPA "Valley" model, which takes Into account a certain
amount of terrain variation. The computer program was run by the PSPL
quality staff, using terrain and stack dimension parameters already set up for
the Shuffleton plant and vicinity.
The model was run with a low wind speed of 2.5 m/sec and a prevailing
southwest wind, over a range of atmospheric stability conditions. Local wind
speed and direction data are given in Appendix A. The most stable condi-
tions ("F" stability) usually yield the highest ground concentrations of a
pollutant, since dispersion by air mixing is minimal. The following normal-
ized data factors were computed for stability Classes A thru F (A being the
most unstable). The data factors are multiplied by an estimated emission rate
to get a maximum 1-hour concentration at the indicated downwind distance.
Data Factor +
Location of maximum
1 Hr PCB concentra-
tion @ ground! evel
Stability Class
F
3.95
2 km NE
E
2.11
2 km NE
D
0.027
12 km NE
C
0.129
4 km NE
B
0.245
2 km NE
A
0.20
near plant
22
-------
The maximum 1-hr PCS concentration can then be estimated, using "F"
stability conditions, from the emission rates determined as follows:
a. lot blend, 3200 gal. of 400 ppm (worst case) grease burned over 5-hour
period yield 0.24 g/sec (no control), or 0.24 mg/sec (99.935 control-
led) emission rate;
Worst case model prediction for downwind PCB concentration «
3.95 X 0.24
" 0.9 vg/m3 (no control), or 0.9 ng/m (99.9% control) at 2 km NE of
plant.
b. 30% blend yields three times the emission rate above0.71 g/sec
(no control), or 0.71 mg/sec (99.9% control).
Estimated downwind PCS concentration at 2 km NE then will be:
2.7 yg/m3 (no control), or 2.7 ng/m (99.9* control).
These estimates can be compared to the OSHA exposure limit for PCB's.
The OSHA allowable concentration for worker exposure on an 8-hour day, 40-hour
week basis 1s 1 mg/m3 with 42 percent chlorine content 1n the PCB's.
Techniques for ambient monitoring of these extremely low PCB concentra-
tions are still being developed, but It 1s recommended that an attempt be made
to make such a measurement at the most likely downwind position, 1n support
of the verification test. The recommended methodology 1s described 1n
Appendix B,
23
-------
REFERENCES
1. 40 CFR Part 761, Polychlorlnated Biphenyls (PCB's) Manufacturing, Pro-
cessing, Distribution 1n Commerce, and Use Prohibitions, Federal
Register 44, 31514-31568, May 31, 1979.
2. K. Feigner, status review meeting, Region X, 01-14-80.
3. Letter (09-28-79) from R. V. Mlecko (FDA) to 0. Donaldson, EPA
Region X.
4. Letter (01-03-80) from H. I. Bosler, Bosler Energy Systems, to K.
Feigner, Region X, also, personal communication with M. I. Bosler.
5. Operating Instructions, Cleaver-Brooks Burner, Model B.
6. VI. Beneflel, personal communication.
7. Laboratory Report to Seattle Rendering Works (01-15-80),
Laboratory Report to Seattle Rendering Works (01-18-80), fuel inspec-
tions of yellow grease performed by Northwest Laboratories, Seattle,
Washington.
8. Test Plan for Evaluation of PCS Destruction Efficiency 1n Industrial
Boilers, GCA June 1979.
9. Personal communication, W. A. Wood, Assistant Superintendent, Puget
Sound Power & Light Company.
10. Puget Sound A1r Pollution Control Agency, Inspection reports.
11. Atmospheric Emission Evaluation. Alsid, Snowden & Associates report to
P5P&L Company, February 1979.
12. Boiler Combustion Efficiency, Shuffleton Power Plant, Puget Sound
Power & Light Company, Wei land, Lindgren and Associates, March 1979.
13. Laboratory Report to Seattle Rendering Works (01-28-80), mlsdblHty
tests of yellow grease and #6 oil.
14. Air Pollution Engineering Manual, AP-40, U.S. Environmental Protection
Agency.
15. PSP&L Company Drawing RB430, Boiler cross section, Shuffleton Power
Plant.
16. Personal comnunlcatlon, T. Van Decar, PSP&L Company.
24
-------
APPENDIX A
.LOCAL METEOROLOGICAL DATA
1. Local wind speed (1/80)
2. Local wind direction (1/80)
3. Location of met station (#17)
-------
- STA1IONI 1UK*11A. SOUIH CENTER 4MBIE.NT A|H QUALITY UATA tt£f>OH1*.* DATA REf0HT AO90R46I-I
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iwr AVC SHOWN UMDEN ENDING HR PMOJECTI 01 COMV FACTONI NONE USED
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- - TOTAL-NUHBtM OF HOUMLV AVCNAGESI 737 - IMOICATCS 4 II HOURS AVA1LAW.E f» OAIL* AVERAGE
-------
i\jMtt\.fc» SOOTH cunt* »**AMtitMY AIM OUALIIV OAT A Mti»om*»» DATA HUMNT AO?OIU«I-I PAKI 21
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H* AVC SHOWN UNDER CNOIN6 MR PROJECT! 81 CONV f ACTOWI NONE USED NOTE! DEMOTES CALM RUN-OATI 05/«7/79
OA 8) 01 02 03 04 OS
057 Mil
S3 034 32*
317- 3** 357 349
343 3S6 343 039
95 IM !! 3**
34*- 62* 357 34*
2M
2M
IM IM 216 I8S
351 357
161 - |*3 174 192
MS 857 Ml 161
61 M
2 T
64 T
6SF
-MS
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M N
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11 T
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13 S
14 S
-IS »-
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17 II
18 T
19 T
26 S
-n s-
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23 T
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25 T
2*r
27 S
26 S
2* M
-3* T
31 M
342
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-355
31
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.
143
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351
326
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-
113
- 162
191
36*
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247
1*8
8M-
_.
185
174187
356
354
_.. ....
101
HOURS PST
67 68
75 Ml
358 338
35* 025
069 077
42 34*
352 357
12*
-1*5
138 085
18* 17*
116 12*
_
326
1*6-
2*3 »9S
IM 19*
1*7 -2»5
1*3
^A6K f. 6^8E
CW9 «V9
340-346
Ml 354
0*
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326
2
0*0
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3*5
201
206
26
1*2
13*
-
2M
1*2
..
17*
IV*
_
1
10
IM
M
353
76
32*
351
143
185
36
147
-
17*
168
206
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._ . . .
28
II
1*2
17
343
M
346
346
691
337
638
206
172
228
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200
194
13
IS2
2*4-
85
625
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121
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691
33*
352
681
93
185
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133
337
205
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215
183
172
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221
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M
12
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349
341
110
62
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-
117
209
215
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16*
199
23
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163
243
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614
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337
344
97
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343
124
040
331
19*
355
12*
003
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191
217
216
36
157
187
624
38
155
263
22
352
IS
71
343
352
90
34*
354
105
73
359
349
229
337
12*
33*
132
175
237
216
66
174
176
OM
18
345
23
049
18
16
049
346
003
094
346
0*2
58
333
214
346
006
337
116
187
198
211
204
103
24
34
142
352
3**
5
OS
17
76
352
3*0
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353
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52
1*2
32*
214
210
3SZ
06*
335-
103
192
2*7
201 -
212
21
65ft
«M-
3*0
91
351
18
6M
3*0
3*0
95
349
92
179
331
213
202
354
344
249
96
171
101
2M
232
24
177
25
M
348
If
161
353
M
349
235
1*3
173
339
194
162
3*6
611
659
179
173
6M
626
IM
624
694
11
28
IM
01
351
*
347
0*5
126
137
321
169
IM
341
632
to
195
IM
IM
90
03
174
17
37
21
35«
344
47
342
219
145
176
33*
342
10
186
312
211
152
176
22
116
624
327
346
351
11*
1*5
IM
199
323
335
204
329
175
181
613
127
23
690
350
320
105
344
296
097
142
181
199
195
330
205
2M
337
164
IM
162
49
7*
150
24 NAM
184 121
3*«
327 340
112 355
35* 3*0
357
320
206
147 359
349
195 357
192 229
029 355
3*0
339
20S
100 335
22* 22*
205 247
355 355
3*0
2M 211
176 232
026
196
176 221
34* 352
3*0
127
355
354
1*8
197- M*
1*4 174 177 1*7
1*4 186 1*9 1*1
-I9-+44 175-196
26)
2M 1*2 1*8
ITS IT*186--
- 355 334
33* 342 662
NO 1?-I* - IS IS- I* 18- 1726-16 - IT - 20 25 23 2* 2«
MX 359 3*6 34* 355 357 3*0 356 357 3*5 353 346 352 3*0 355 359
25 26 24 21 22 IS 17 21 16
3*0 3*0 3*0 353 351 358 351 358 356 3*0
TOTAL NUNKR OF MOUNLV AVCMMCSl 462
-------
IS78
flTnOSPHCRlC SflnPLING NETWORK
SOUND am POLLUTION CONTROL REGION
urn ,.«.o
-------
APPENDIX B. EXAMPLE TEST PLAN FOR EVALUATION
OF PCB DESTRUCTION EFFICIENCY
STACK SAMPLING
Sampling Methods
The sampling train to be used for PCBs will be a modified Method 5 train as
described 1n "A Preliminary Procedure for Measuring the PCB Emissions from
Stationary Sources?: W. J. Mitchell, U.S. EPA, August 26, 1976. A solid
adsorbent tube containing 7.5 grams of pre-extracted 30/60 mesh Florisil is
Placed between the third and fourth Impingers. Alternative adsorbants are
XAD-2 and Tenax GC.
The sampling and velocity traverse will be along two diameters of the
stack for a nominal 40 inch diameter stack, a total of 44 points will be
sampled to provide a representative sample of the flue gas composition. Total
sampling time at a flow rate of approximately 1.0 ft3/min. should be long
enough to yield approximately 10 wg of PCBs, based on a destruction efficiency
of 99.9 percent.
Sampling will be isokinetlc (±10 percent) with readings of flue gas
Parameters recorded at every sampling point during the traverse. In the
event that isokinetic sampling cannot be maintained, the train will be shut
down and the problem remedied. In the event that either steady operation is
not maintained, or monitored gas parameters (CO, C02, 02) are out of the
specified limits, the testing will be stopped until conditions are stabilized.
Steady operation of the boiler will be the responsibility of operating
Personnel and the verification burn coordinator.
lest Matrix
A series of PCB emission tests at steady boiler operating conditions
WH1 be conducted, such that three separate days of testing are carried out
for a single waste fuel feed rate. If multiple waste feed rates are eval-
uated, two successive days of testing will be scheduled for each of tiie
Proposed feed rates. The test schedule is Indicated 1n the test matrix,
Table A-l.
29
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TABLE II-1 TEST MATRIX
Sample
Morisil resin
Condensed water
Impinged participates
Train wash
Florisil blank
Train wash blank
Waste fuel
No. 6 fuel
Polyurethane plug
Source
PCU train
D.I.G. hexane
D.I.G. acetone
Trickle value (inte-
grated)
Trickle value (inte-
grated)
High-vol sampler
Container
Amber glass
PCB train impingers Amber glass
Amber glass
Amber glass
Amber glass
Amber glass
Amber glass
Amber glass
Species
Analyzed
PCDs
PCDs
PCDs
PCD background
PCD background
PCD
PCD
PCB's
Number
(Maximum)
5
1
1
4
1
8
-------
In order to provide background data on emissions from the boiler, a pre-
liminary test will be conducted with No. 6 fuel oil nnlj nnt dnj prior to the
initiation of the PCB test burn. This test will be for the same duration
and at the same conditions as those to be used for the PCB sampling. The
test will use a PCB train and will provide emissions data for the boiler as
operated at normal load and firing No. 6 fuel oil. A measurement of the
precision of stack collection of PCB will be provided by the simultaneous
operation of duplicate PCB trains on the second day of the burn.
Boiler and Stack Gas Parameter Measurements
During each of the tests, boiler operational parameters will be as
Indicated in Table A-2. Continuous monitoring of flue gas for CO, COo,
and 02 will be provided. The monitors will be equipped with a gas condition-
ing system and recorders. Monitors will be calibrated prior to use and as
required. Parameters will be continuously recorded during each test.
Other flue gas parameters will also be measured Including the flue gas
velocity, static pressure and temperature. These measurements will be made
prior to each run for the determination of proper nozzle size and sampling
rate. These are also shown in Table A-2.
Table A-2. SUPPORTING PARAMETER MEASUREMENTS DURING TEST
Parameter measured Method
C02in flue gas Continuous gas analyzer
CO in flue gas Continuous gas analyzer
Og In flue gas Continuous gas analyzer
Flue gas velocity Calibrated pi tot tube/manometer
Flue gas temperature Thermocouple
Flue gas pressure P1tot tube/manometer
percent moisture In flue gas Moisture gain 1n Method 5 tests
Fuel flow rate Positive displacement or differential
pressure flowmeter
31
-------
Sampling Requirements
The stack sampling program will require approximately four days of tes-
ting with four team members on site. A total of three to four tests and one
background test will be conducted. Other requirements to be provided Include
the following:
three 20 amp circuits accessible to stack;
three 20 amp circuits for monitors;
area for sample recovery.
Quality Control
In order to prevent any contamination of samples with materials which
may interfere with analysis, the highest level of quality control will be
observed 1n all field testing. All solvents and resins will be checked for
purity before the sampling program; filter paper and glass wool will be
solvent-cleaned. Appropriate blanks will be included to provide background
information. The sampling trains will be all glass and precleaned to remove
any residues. At no time will plastics or grease be used on the organic
sample portions of the sampling train. Sample packing lists will be included
for each test with information regarding source lot numbers and preservation/
extraction techniques.
Each PCS train will be spiked in the field with a solution containing a
known amount of deuterated tetrachloroblphenyl Internal standard. Laboratory
analysis of the internal standard will provide information on sampling and
analysis efficiency.
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AMBIENT MONITORING
Sampling Method and Schedule
Sampling will be with high-volume samplers, modified as described 1n
"A Method for Sampling and Analysis of Polychlorlnated Blphenyls (PCBs)
in Ambient A1r," EPA-600/4-78-048 (Figure A-l). The airborne PCB 1s
collected on a series of two precleaned polyurethane foam plugs housed 1n
the sampler throat, a 16-cm long threaded, aluminum tube. Motor exhaust
1s diverted from the sampler Intake by a duct, now rate through the
sampler will be maintained at between 20 and 35 ft3/m1n for a sampling
period time coordinated with the verification test.
Wind directions expected to prevail during the test period will be
used to select two nearby downwind sites. Positioning of the two on-s1te
downwind monitors will be done each morning prior to the start of the
sampling period. This will be done on the basis of forecast weather, on-
$1te wind conditions, and expected plume dispersal.
ANALYTICAL METHODOLOGY
Stack Sampling
The following procedures apply after sample recovery 1n the field.
A prescreenlng analysis will be used, requiring perchlorl nation of PCBs
with antimony pentachloride. This procedure converts all PCB Isomers 1n
a sample to a single Isomerlc species, decachloroblphenyl (DCB). This
approach can only be used for confirmatory purposes and to increase
sensitivity. Because different amounts of DCB are produced by each Isomer
(mono-, b1-, trl-, etc.), adjustment factors are necessary to convery DCB
values to specific Aroclor mixtures. Blphenyl, a known emission from com-
bustion sources and present 1n Aroclor mixtures, 1s converted In the
perch!or1nation process to DCB. Thus, 1f blphenyl 1s suspected to be
present 1n significant amounts, 1t must be determined separately to
correct DCB values. The exposed Flor!s1l sorbent trap 1s extracted with
hexane 1n a Soxhlet, cooled, and then concentrated to about 5 ml. Contents
of the first two (water filled) 1mp1ngers are extracted with hexane, dried
by passing through columns filled with anhydrous NagSO^, and added to the
extract. The probe and Implngers are rinsed with acetone then
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Faceplate
Stainless Steel Throat Extension
Polyurethane Foaa
Plug Location
Throat Extension
Wire
Retainer
Motor Unit
Adapter
- Exhaust Duct
(3 minimum length)
Figure A-l.
Assembled sampler and shelter vrlth exploded
view of the filter holder.
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hexane. The rinses are dried with anhydrous ^SCty and added to the com-
bined extracts. The combined extracts are then cleaned by extracting with
concentrated H2S04 (1f the cleaned extract 1s still colored, liquid chroma-
tography on Fieri$11 can be used). The extract 1s then made to 25 ml
volume and split Into four portions: three 5-ml volumes for perchlorinatlon
and one 10-ml aliquot for confirmation studies by GC/MS. After perchlorina-
tlon, the solution 1s extracted four times with hexane and made to 5 ml.
Analysis for decachloroblphenyl 1s performed by 6C-ECD. Chromatographlc
parameters are:
t Chromatograph - Any suitable Instrument.
4 fi^
t Detector - Electron capture, H or N.
Column - 1.8 m x 2 mm ID, 3% OV-210 on Supelcoport, 100/120 mesh.
t Temperatures - Column 280'C, others not specified.
Carrier gas - Not specified (N2 or H2)» 30 ml/m1n.
t Detection limit - Not specified, but standards of 25 to
50 pg/yl are suggested. The overall detection limit 1s
specified as 10 ng DCB 1n a 5 ml perchlorinatlon aliquot.
This Indicates a minimum detection limit of 2 pg/yl Injected.
Results are reported 1n terms of ng DCB per cubic meter of combustion
effluent sampled. GC/MS 1s used to verify the presence of PCBs by pattern
matching with Aroclor mixtures. The precision of the DCB analysis Is
estimated to be 10-15X, and recovery of PCBs through the entire sampling
and analysis procedure 1s estimated to be 85-95%.
Ambient Samples
Polyurethane foam plugs will be collected from ambient monitors and
returned to the laboratory 1n precleaned amber glass jars with Teflon-Hned
caps. The samples will be Soxhlet extracted for 3 hours with hexane. After
cooling, the extracts will be transferred to a Kuderna-Danlsh (K-D) eva-
porative concentrator and the volume reduced to 5 ml. The extract will then
be divided Into a reserve plus two portions for perchlorinatlon according
to the method outlined above.
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APPENDIX C. EXAMPLE PUBLIC NOTICE
NOTICE OF INTENT TO CONDUCT VERIFICATION
TEST OF PCS DESTRUCTION
1.0 BACKGROUND
A quantity of PCB-contaminated yellow grease, produced as a rendering
byproduct, 1s currently stored at 2900 llth Avenue SE, Seattle, WA. The
contaminated material, amounting to 1,100,000 Ibs (150,000 gallons), 1s
owned by Seattle Rendering Works, Seattle, WA. The PCB1 content of the
grease (116 to 391 ppm range) qualifies 1t for destruction in a high effi-
ciency boiler or, alternatively, disposal 1n a chemical landfill under 40
CFR Part 761. The Regional Administrator of U. S. Environmental Protection
Agency Region 1U will review the proposed destruction of the waste 1n a
high-efficiency boiler to assure that the prerequisites of 40 CFR Part 761
are satisfied.
A high efficiency boiler has been selected by the owner for use in
disposing of PCB - contaminated yellow grease. It is the U.S. EPA Regional
Office intent to require a verification bum to demonstrate that PCB con-
taminated waste can be destroyed effectively.
(1) The boiler capacity is rated at 46 million Btu/hr heat Input,
as compared to the prerequisite SO million Btu/hr.
(2) The recommended waste feed rate will be 100% waste as fuel,
rather than the prerequisite of 10% waste with 90% normal
fuel. Both full and half feed rates will be demonstrated.
The Condensed Chemical Dictionary, Van Nostrand Reinhold Company, 1977, page
696. "polychlorinated blpnenyl (PCB). One of several aromatic compounds
containing two benzene nuclei with two or more substltuent chlorine atoms.
They are highly toxic. Their chief use is in heat exchange and Insulating
fluids in closed systems. FDA has prohibited their use 1n plants manufacturing
foods, animal feeds, and food-packaging materials, and has established strict
tolerances on their presence 1n many food products (2.5 ppm).
NOTE: Because of their persistence and ecological damage from water pollution
their manufacture has been discontinued In the U. S. (1976)."
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1,1 OBJECTIVES OF THE VERIFICATION BURN
The purpose of this verification 1s to accurately measure the destruc-
tion efficiency of the designated high efficiency boiler for PCB, using the
recommended operating conditions. The test results are expected to reveal
minimum destruction-efficiencies of greater than 99.9 percent based on other
test results In related equipment. If the destruction efficiency is confir-
med at greater than 99,9%, confidence will then exist that the unit can
destroy the PCB waste, consistent with the intent of 40 CFR Part 761. This
will then serve to support the operational disposal of all the contaminated
stocks by the owner,
2.0 DESCRIPTION OF PROPOSED TEST FACILITY
2.1 EXISTING FACILITY
It is proposed that the waste grease containing PCB will be incinerated
in the process steam boiler at Seattle Rendering Works, located at 5795 S.
130th Place, Seattle, WA. The boiler at Seattle Rendering Is a dual-fuel
(gas and/or 16 oil) water-tube Cleaver-Brooks model (Delta D-60) with a design
capacity of 35,000 Ibs steam/hr. The oil burner is a low-pressure, air
atomizing type. The rated gas-fuel efficiency 1s 782, so the design heat
input is 46,000,000 Btu/hr. The furnace volume is 755 cu. ft. in the imme-
diate combustion zone, excluding the upper radiant section. Typical stack
temperatures at maximum firing are 550-560 F. The combustion zone tempera-
tures are in excess of 2200 F at the back wall.
The boiler has the standard set of safety controls, including a programmed
burner shut-down in the event of flame failure; low water conditions; low fuel
oil temperature; low fuel oil pressure; low atomizing air pressure; or excess
steam pressure.
Facilities for storage of yellow grease at Seattle Rendering include two
270,000 Ib capacity heated storage tanks. The grease is pumpable at about
100 F, and congeals at lower temperatures. Other storage and transport equip-
ment includes two 50,000 Ib Insulated trailers, and one 20,000 Ib Insulated
trailer.
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2.2 REQUIRED MODIFICATIONS TO THE EXISTING FflHTI TTTF<;
The normal oil-feed supply to the boiler will be blocked off, and a
temporary waste fuel line Installed. The temporary Une will run from a
grease storage trailer to the fuel feed pump of the boiler with a circulating
return line, the trailer and transfer lines will be dedicated during the
verification burn.
Additional measurement points that will be Installed for adequate boiler
monitoring during PCB Incineration Include:
(1) Flowrate Indicator and recorder downstream of oil regulating
valve.
(2) A1r wlndbox pressure Indicator.
(3) Continuous carbon monoxide and excess oxygen monitoring 1n the
flue gas.
2.3 OPERATIONAL REQUIREMENTS
The Seattle Rendering boiler normally operates at full modulation from
a low fire to high fire position, regulated by steam pressure. Since the
PCB destruction verification bum will be required to operate at a steady
rate of waste fuel consumption, process steam generation will be held
constant during the test period.
The following table compares the proposed verification test conditions
with boiler and operating condlsltons presented In 40 CFR Part 761.
EPA Requirement Proposed
(Federal Register 40 CFR Part 761) Verification Test
1. Boiler must be rated at a minimum 1. 46 MM BTU/hour rating
of 50 MM BTU per hour.
2. 011 'flow containing PCB's must be less 2. 100 % contaminated fuel.
than 10* of the total fuel flow.
3. 011 containing PCB must not be added 3. Same (gas-firing will be used)
during startup and shutdown.
4. Before burning PCB contaminated 4. Same
oil, the owner/operator must conduct
tests and determine that the
combustion emissions contain at least
3% excess oxygen and no more than
50 parts per million of carbon
monoxide.
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5. The company must notify the
appropriate EPA Regional Adminis-
trator at least 30 days prior to the
test and has supplied the combustion
emissions data required 1n No. 4.
6. The combustion process 1s monitored
continuously or, for boilers burning
less than 30,000 gallons of mineral
oil annually, at least once each
hour that PCB contaminated oil 1s
being burned.
7. The primary fuel and mineral oil
feed rates are monitored at least
every 15 minutes whenever FCB
contaminated mineral oil Is being
burned.
8. The carbon monoxide and excess
oxygen levels are checked at least
every 15 minutes whenever burning
PCB contaminated mineral oil.
5. Emissions will be determined
for proper combustion prior
to verification burn.
6. The combustion process will
be monitored continuously
for all boilers.
7. The fuel feed rates will be
monitored continuously for
all boilers.
8. Proposed bum will require
CO, C02- Excess 02 and
opacity levels to be
monitored continuously.
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3.0 TECHNICAL SUITABILITY OF CONDUCTING THE VERIFICATION BURN
3.1 FUEL CHARACTERISTICS
The laboratory Inspection of grease samples Indicated below Indicate
that the contaminated waste can be burned as a boiler fuel substitute for
No. 6 fuel oil, with good combustion characteristics.
1) The viscosity Is between that of 15 and #6 fuel oil, so atom-
Ization should be good with a burner that 1s usually run with
*6 oil.
2) The fuel value of the grease 1s 93% of a 16 oil value.
3) The ash content 1s low.
3.2 SUITABILITY OF THE BOILER
The waste fuel will be fired at full rate (6 gal Ions/minute) and half/rate
(3 gallons/minute). The residence time of PCB and temperature in the furnace
combustion zone are as follows:
Fuel Rate(gallons/minute) Temperature (*F) Residence Time (sec)
3 2200 (with 2.2
supplementary gas
firing)
6 2200 1.1
The residence time of PCB's and temperature for 3 galIons/minute firing
rate are similar to those specified for conmercial waste Incinerators as
called out in 40 CFR, Part 761, Subpart E (2191°F at 2 seconds).
3.3 SUITABILITY OF THE TEST PLAN
Normally, three separate tests are conducted at the same conditions for
verification of the efficiency of PCB waste Incineration. The verification
bum performance at multiple grease feedrates 1s needed to decide on recom-
mended operating conditions. Therefore, the verification test plan will be:
(1) Duplicate tests at 3 GPM feedrate.
(2) Duplicate tests at 6 GPM feedrate.
The boiler v/111 be started up on natural gas fuel to reach steady opera-
tions, as determined by stack measurements of temperature, CO, and Og. The
grease circulation loop will then be started. When the feed temperature
reaches 140-150 F, the grease fuel will be directed to the burner and the
40
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gas fuel gradually reduced, such that stack temperatures and steam pressure
remains constant.
The emissions tests during the verification burn will be carried out
according to (an EPA-approved) test manual. The test procedure will use an
integrated sampling train with a solid adsorbent that 1s effective 1n cap-
turing PCB's 1n low concentrations. The sampling will be conducted 1so-
Ic1net1cally, with the sample probe positioned at a number of prespedfied
points during the traverse of the boiler stack. The sampling effort 1s
expected to take 3 hours to get sufficient PCB capture for analysis detection.
The adsorbent material and 1mp1nger rinses will be sealed and taken to a
laboratory that 1s experienced in PCB analysis. Both gas chromatography (GC)
and gas chromatograph mass spectrometry (GC/MS) analysis methods will be
used.
4.0 ENVIRONMENTAL SUITABILITY OF CONDUCTING THE VERIFICATION BURN
The A1r Quality analysis results were obtained for worst-case
conditions as well as expected performance. The worst case analysis is
based on an absolute failure mode (0% destruction of PCB contaminants, with
waste concentrations higher than reported analyses and maximum waste fuel
feed rate). The expected performance mode Is based on 99.9% PCB destruction.
and average PCB concentrations 1n the waste with mid-range feed rate of waste
fuel.
Dispersion model estimates, using local terrain and meteorological data,
predict a maximum downwind concentration of PCB of 16,000 nanograms per cubic
ineter (ng/m ) for worst case conditions, and 4 nanaograms per cubic meter for
expected performance. This can be compared to the OSHA standard limit value
for PCB's. The OSHA allowable for worker exposure on an 8-hour day, 40-hour
3
^eek basis 1s 1 million ng/m , so that worst-case conditions would produce
% concentration about 60 times lower than Industrial health standards.
/^solute failure would only be caused by combustion failure, which would be
detected and correc*ed if 1t happened during a verification burn.
The vicinity of the Seattle Rendering plant Is mixed Industrial-commer-
cial-residential. The nearest residential areas are Immediately west of the
41
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plant (about 100 meters), and about 400 meters north, on a bluff approxi-
mately 50 meters high. The maximum downwind concentrations are predicted to
occur 1n the prevailing wind direction, at the bluff 400 meters north from
the plant. Ambient monitoring of PCS concentrations at these nearby resi-
dential areas will be carried out during the verification burn.
No significant water or land contamination 1s expected from the
verification burn.
FUEL SAMPLING
Fuel samples will also be obtained and analyzed for PCBs, and the following
parameters: N, S, Cl, C, H, ash, water, sediment, and caloric value. The
fuel samples will consist of:
A trickle sample obtained during each run
t A sample of No. 6 oil normally used 1n the boiler
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