xvEPA
Burning of Hazardous Waste
in Boilers and Industrial
Furnaces (BIF) Rule
Satellite Training Course
April 7, 1992
Sponsored by:
RCRA I on
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Table of Contents
Agenda
Biographies of Training Course Participants
BIF Rule Satellite Training Course Manual
List of Additional Information
Question Form
Evaluation Form
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BIF Rule Enforcement
Satellite Training Course
Washington, DC
April 7,1992
Agenda
11:00-11:05
11:05-11:10
11:10-11:40
11:40-11:55
11:55-12:10
12:10-1:25
1:25-1:40
1:40-2:40
2:40-4:10
4:10-4:30
4:30-5:00
Introduction
Susan Bromm, Director, RCRA Enforcement Division,
Office of Waste Programs Enforcement
Course Overview
The Regulations and Permit Requirements
(Bob Holloway and Sonya Sasseville)
Questions and Answers
Break
Technology Overview
(Catherine Massimino and Y.J. Kim)
Questions and Answers
Lunch
Enforcement
(David Nielsen, Emily Chow, Kate Anderson, John
Dombrowski, and Ken Gigliello)
Questions and Answers
Panel Discussion/Wrap-up
(Times are approximate and are in EST)
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Biographies
of the
Training Course Participants
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BIF Rule Enforcement Satellite
Training Course Manual
Biographies List
The Regulations and Permit Requirements
Bob Hollowav
(FTS/202) 308-8461
Mr. Holloway has a B.S. in Civil Engineering and a M.S. in Sanitary Engineering from
Virginia Polytechnic Institute and State University. He has worked on EPA's hazardous
waste combustion regulatory program since 1984. As Chief of the Combustion Section
in the Office of Solid Waste for the past five years, Mr. Holloway directed the
development of the Boiler and Industrial Furnace Rulemaking.
Sonya Sassesville
(FTS/202) 260-3132
Ms. Sasseville is the Chief of the Alternative Technology Section of the Permits and
State Programs Division in the Office of Solid Waste. Her section provides regulation
interpretations, guidance and technical support to the Regions related to hazardous
waste combustion permitting. She chairs the National Hazardous Waste Combustion
Permit Writers' Workgroup. This workgroup holds monthly conference calls and semi-
annual meetings to discuss permitting issues related to hazardous waste combustion
units (i.e., incinerators, BIFs, and Subpart X units). Sonya has been with EPA's Office
of Solid Waste for six years.
Technology Overview
YJ. Kim
(FTS/415) 744-2058
Mr. Kim is a chemical engineer who works as a permit writer for U.S. EPA Region IX.
His duties include issuing permits to hazardous waste incinerators and boilers and
industrial furnaces. He has been designated as a National Expert for Incineration of
Hazardous Waste. Prior to working at EPA, Mr. Kim spent approximately 20 years
working in the chemical and waste management industries, where he served in various
capacities, including chief process engineer, technical and engineering design director,
and manager of project engineering. He has invented, commercialized, and obtained
patents for two chemical processes involving insitu combustion and vacuum distillation
processes. Mr. Kim has an M.S. degree in Chemical Engineering from the University of
Notre Dame.
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BIF Rule Enforcement Satellite
Training Course Manual
Biographies List (continued)
Technology Overview
I
Catherine Massimino
(FTS/206) 553-4153
Ms. Massimino is the Senior RCRA/Superfund Technical Specialist of U.S.
Environmental Protection Agency (EPA) Region 10's Hazardous Waste Division. She
did her Bachelors and Graduate studies in Civil Engineering at New Jersey Institute of
Technology. She serves as an EPA Region 10 Hazardous Waste Division-wide
resource in the subject areas of thermal treatment and landfill covers and liners. She
provides expert technical and regulatory reviews on hazardous waste thermal treatment
permits, Superfund thermal treatment clean-up actions, and municipal incinerator and
landfill proposals. She has had twelve years experience in development and
implementation of the hazardous waste management regulatory program mandated by
the Resource Conservation and Recovery Act (RCRA); development and
implementation of the polychlorinated biphenyl (PCB) regulatory program mandated by
the Toxic Substances Control Act (TSCA); and the provision of technical assistance
involving the scientific and engineering aspects of hazardous waste management
associated with the above programs.
She has lectured at the government offices' of Sao Paulo, Brazil, University of
Washington, Western Washington University, and at the Air Pollution Control
Association's Annual Meeting on hazardous waste and PCB incineration, and was a key
lecturer and organizer for EPA Region 10's RCRA Core Hazardous Waste Program
Training. She received the Seattle Federal Executive Board's Federal Employee of the
Year Special Recognition Award for Scientific Achievement for 1988.
Enforcement
Kate Anderson
(FTS/202) 260-9313
Ms. Anderson is an Environmental Specialist with the U.S. Environmental Protection
Agency's Office of Waste Programs Enforcement (OWPE). Her responsibilities include
developing guidance and training for EPA and State personnel involved in hazardous
waste enforcement activities. Prior to joining EPA, Ms. Anderson was a section
manager for the RCRA/Superfund Hotline.
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BIF Rule Enforcement Satellite
Training Course Manual
Biographies List (continued)
Enforcement
John Dombrowski
(FTS/202) 260-7834
Mr. Dombrowski is an Environmental Engineer with the U.S. Environmental Protection
Agency's Office of Waste Programs Enforcement (OWPE). His responsibilities include
developing guidance and training for EPA and State personnel involved in hazardous
waste enforcement activities. Prior to joining EPA, John spent several years working for
a consulting firm, and holds a B.S. degree in Civil Engineering from West Virginia
University, and a M.S. degree in Water Resources Engineering from George
Washington University.
Emily Chow
(FTS/202) 260-9329
Ms. Chow is the Chief of the Training and Guidance Section (TGS) of the RCRA
Enforcement Division. She is a Chemical Engineer by training an is responsible for
overseeing the projects of TGS. TGS is involved in aiding in regulation development
and providing training and guidance on enforcement-related issues to the EPA Regions'
and States' enforcement personnel.
Ken Gigliello
(FTS/202) 260-8544
Mr. Gigliello began his EPA career in 1977 with the Region II Rochester Program Office
performing as a laboratory analyst. In 1978 he joined the Region II Environmental
Services Division Field Office where he functioned as an environmental scientist/field
investigator. He has worked in the Superfund, NPDES, TSCA, and the RCRA programs
performing inspections, participating in enforcement proceedings, and developing
inspector training programs. He left the agency in 1986 to work for a major corporation
in their corporate environmental auditing department. Since March, 1987, Ken has
worked in the RCRA Enforcement Division as an environmental scientist in the
Guidance and Evaluation Branch. Ken is currently the Branch Chief of the Guidance
and Evaluation Branch.
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BIF Rule Enforcement Satellite
Training Course Manual
Biographies List (continued)
Enforcement
David A. Nielsen
(FTS/202)260-1914
Mr. Nielsen is Chief of the Eastern and Southwestern Branch in the Office of
Enforcement's RCRA Division. He received a law degree form the University of
Virginia's School of Law and is also a graduate of the University of California, Berkley
with a B.S. in Environmental and Resource Economics. David has been with EPA for
4 1/2 years.
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BIF Rule Enforcement Satellite
Training Course Manual
Pages
Parti: The Regulations and 1 -29
Permit Requirements
Part II: Technology Overview 30 - 73
Part III: Enforcement 74-110
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Disclaimer
The policies and procedures established in this document are intended solely for the
guidance of employees of the U.S. Environmental Protection Agency. They are not
intended and cannot be relied upon to create any rights, substantive or procedural,
enforceable by any party in litigation with the United States. EPA reserves the right to
act at variance with these policies and procedures and to change them at any time
without public notice. This training manual is not a substitute for the Federal Register
published rule or subsequent amendments.
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PARTI
The Regulations and
Permit Requirements
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Notes:
Owners or operators of BBFs arc now
subject to the general facility standards for
TSDF.
Overview of the BIF Rule
Prior to the final rule, the burning of hazardous
wastes in BIFs was exempt from regulation. The
final rule has provisions to control emissions of:
- toxic organic compounds
- toxic metals
- hydrogen chloride
- chlorine gas
- paniculate matter
Notes:
Important Federal Registers Associated
with the BIF Requirements
Rule was published in the Federal Register on
February 21,1991 (effective on August 21,
1991)
Correction notice issued on July 17,1991
Correction notice issued on August 27,1991
Correction notice issued on September 5,1991
Regulations and Permit Requirements
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1 1
Notes:
Notes:
^k ^SSjSK.j.-.j.^iiiBBy f^f
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Applicability of the BIF Rule [40 CFR
266.100]
The BIF rule applies to two basic types of units
burning hazardous waste for energy recovery,
destruction, or materials recovery.
Rnilorc
- Industrial furnaces
^ J
r Exemptions and Exclusions ^
The final rule discusses several exemptions and
exclusions'
- small quantity burner (SQB) exemption
- potential exclusion of Bevill wastes
- exclusion of decanter tank tar sludge
- deferral for smelting, melting, and refining
furnaces
- low-risk waste exemption
- destruction and removal efficiency (ORE) trial
V burn waiver for certain boilers J
Regulations and Permit Requirements
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Small Quantity Burner (SQB) Exemption [40 CFR
266.1081
SQB exemption was developed under Section 3004
(q)(2)(B) of RCRA and exempts owners or operators from
emissions standards and permitting requirements of the
final rule, provided:
- The quantity of waste does not exceed the quantities
specified in the final rule
- Hazardous waste is not more than 1% of the total fuel
requirements
- Heating value of the waste is at least 5,000 Btu/lb
- Listed dioxin wastes are not burned
- The owner or operator must submit a one-time
notification of burning activities and maintain records to
document compliance with the conditions of the
exemption.
Notes:
Regulations and Permit Requirements
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Notes:
Management of Residues [266.112]
The rule focuses on residues that are excluded
from the definition of hazardous waste due to
the Bevill exemption, specifically:
- boilers burning primarily coal or other fossil
fuels
- industrial furnaces processing primarily ores
or minerals
- cement kilns processing primarily raw
materials
Notes:
BIFs must bum at least SO percent fossil
fuels, ores and minerals, or normal cement-
production raw materials to be eligible for
the Bevill exclusion.
Applicability of the Bevill Exclusion to
Wastes from BIFs
Section 3001 (b)(3)(A) of RCRA excluded from
regulation certain residues from the processing of
fossil fuels, ores and minerals, and cement kiln
dust waste pending the completion of studies by
EPA. This exclusion is potentially applicable to
- Boilers burning coal or other fossil fuels
- Industrial furnaces processing ores and
minerals
- Cement kilns
Regulations and Permit Requirements
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Notes:
Waste-derived residues that pass part 2 do
not need to pass part 1.
Applicability of the Bevill
Exclusion to Wastes from BIFs (Continued)
In order to be exempt under the Bevill exclusion
residues from the burning of hazardous wastes
must meet a two-part test to demonstrate that
they have not been significantly affected by the
co-combustion of hazardous waste
Notes:
Owners or operators should use the
procedures in 40 CFR 266.112 and
statistical methodology for Bevill residue
determinations.
Concentrations of non-metal constituents
must be compared to health-based levels in
Appendix VII of Part 266.
Concentrations of metal constituents in a
TCLP extract must be compared to health-
based levels in Appendix Vn of Part 266.
Two-Part Test for Applicability of the
Bevill Exclusion to Wastes from BIFs
Parti:
Waste-derived residue must not have
significantly higher concentrations of Part 261
Appendix VIII constituents than normal residues
Part 2:
Toxic constituents in the waste-derived residue
must not pose a threat to human health
Regulations and Permit Requirements
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Notes:
EPA has concluded that decanter tank tar
sludge
- does not significantly affect the
chemical composition of coke
- does not contain concentrations of
hazardous constituents that are
statistically different from those of coal
Exclusion of Decanter Tank Sludge
from Regulation
As a result of a petition from the American Iron
and Steel Institute, K087 that is mixed with coal
or coal tar in a coke oven is excluded from the
definition of solid waste.
Regulations and Permit Requirements
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Deferral for Smelting, Melting, and Refining
Furnaces
Owners or operators of smelting, melting, and refining
furnaces are eligible for a deferral from the standards of
the final rule provided the facilities are burning
hazardous waste for "legitimate metals recovery." The
criteria for this deferral include:
- Wastes may not contain more than 500 ppm toxic
organic constituents listed in Appendix VIII of 40 CFR
Part 261
- Wastes may not have a heating value of more than
5,000 Btu/lb
- Wastes must contain recoverable levels of metals with
the same or greater levels of metals as normal feed
stocks
Notes:
Wastes with greater than 500 ppm toxic organic constituents are deemed to be burned at least partially for
destruction; wastes with a heating value greater than 5,000 Btu/lb are deemed to be burned at least partially for
energy recovery.
Wastes must have "economically viable" amounts of metals to recover; the person recovering metals must be in
the business of producing metals for public sale.
For example, high-temperature metal recovery devices used to recover metals from emissions control dust
(K061) are eligible for this deferral.
Regulations and Permit Requirements
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Notes:
Notes:
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Alternate Criteria for the Deferral of Certain
Industrial Furnaces
The owner or operator of a lead or nickel-
chromium recovery furnace, or a metal recovery
furnace that burns baghouse bags to recover
metals must
- Provide a one-time written notice that he or
she is claiming the exemption
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Alternate Criteria for the Deferral of Certain
Industrial Furnaces (Continued)
Sample and analyze the waste and feedstocks
according to methods in SW-846
Maintain records for three years documenting
compliance wnn me exemption
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8
Regulations and Permit Requirements
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Notes:
The Regional Administrator or State
Director will make this determination based
on:
- The concentration and toxicity of
organic constituents in the waste
- The level of destruction of toxic
organics provided by the furnace
- Whether ambient air levels of organics
in Appendices IV and V of Part 266 may
be exceeded
Alternate Criteria for the Deferral of Certain
Industrial Furnaces (Continued)
EPA or authorized state may subject on owner
or operator of a facility exempt under the
alternative criteria to the requirements of the
BIF rule if the waste contains more than 500
ppm of organic constituents in Appendix VIII
of Part 261
Notes:
Emissions Standards
Emissions standards include:
- toxic organic compounds
- toxic metals
- hydrogen chloride
- chlorine gas
- particulate matter
9
Regulations and Permit Requirements
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1
ป T >
Notes:
The ORE standard does not apply to BIFs at
interim status facilities.
Notes:
These parameters are required to be
monitored because they are indicators of
combustion efficiency.
Destruction and Removal Efficiency (ORE)
The final rule requires a ORE of
- 99.9999% for listed dioxin wastes
- 99.99% for all other principal organic
hazardous constituents
c J
^Products of Incomplete Combustion (PICs)
Controls
The final rule indirectly controls emissions of
PIC by limiting flue gas concentrations of:
- carbon monoxide (CO)
- hydrocarbons (HC) (where applicable)
- dioxins and furans (where applicable)
V -J
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Regulations and Permit Requirements
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Tiered Approach for CO Emissions
The final rule allows a two-tiered approach for
demonstrating compliance.
- Under Tier I, CO emissions must be continuously
monitored to ensure they do not exceed 100 ppmv
(corrected to 7% oxygen) on an hourly rolling average
basis
- Under Tier II, HC emissions must be continuously
monitored to ensure that they do not exceed 20 ppmv
(corrected to 7% oxygen) as measured by a FID
detector and an unconditioned sample gas extraction
system, and CO emissions must not exceed a
maximum level established during a compliance test
Notes:
Cement kilns will frequently require use of Tier II to demonstrate compliance with the final rule.
11
Regulations and Permit Requirements
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Alternate HC Limit
The final rule allows facilities to establish an alternate
(higher) HC limit through the permit process if they cannot
comply with Tier I or Tier II regarding CO emissions. In
order to obtain this alternate limit, an owner or operator
must:
- demonstrate the BIF is designed to operate to minimize
HC emissions
- establish a "baseline" HC level based on normal
operating conditions
- conduct emissions testing to show that emissions do not
exceed the baseline when the unit bums hazardous
waste
- conduct dispersion modeling to demonstrate that ground
level concentrations of organic constituents do not
exceed health-based levels
Notes:
Interim status facilities that cannot immediately comply with the HC limit should request a time extension for
certification of compliance with the HC standards.
12
Regulations and Permit Requirements
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\
Notes:
For cement kilns, the waste must be fed
into the kiln itself
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Restriction On Waste Feed Locations
During Interim Status
Owners or operators of industrial furnaces that
feed wastes at locations other than the "hot"
end must:
- Comply with the Tier II CO controls
(monitor HC)
- The combustion gas temperature must be
greater than 1 ,800ฐF where waste is fed
- Adequate oxygen must be present
Notes:
.
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Controls for Dioxins and Furans
Owners or operators of BIFs are required to
perform stack emissions testing and conduct
risk assessments when there is a high potential
for significant dioxin or furan emissions. These
procedures are required for:
- BIFs that operate a baghouse and that
operate between 450ฐF and 750ฐF
- Industrial furnaces operating under an
alternate HC limit
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13
Regulations and Permit Requirements
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1 1
Notes:
Ash feed rate limits do not apply to cement
kilns and lightweight aggregate kilns.
r ^\
Paniculate Matter (PM) Controls
Under the final rule, paniculate matter emissions
are limited to 0.08 gr/dscf, corrected to 7%
oxygen.
- Emissions are controlled by limiting the total
ash feed rate and controls on air pollution
control devices.
Owners or operators must comply with more
stringent NSPS or state PM controls.
c j
Notes:
This is the simplest, but also the most
conservative approach for owners or
operators to demonstrate compliance with
the metal emissions requirements
Feed rate of constituent , = [total feed rate]
x [concentration of constituent in total
feed]
r *\
Tier 1 for Control of Emissions of Toxic
Metals
The final rule allows tiered approach to
demonstrate that metals emissions do not pose
a significant risk
- Under Tier 1, facilities must comply with feed
rate limits in Appendix 1 of Part 266
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Regulations and Permit Requirements
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Notes:
Metals include:
5 noncarcinogenic metals
- antimony
- barium
- mercury
- silver
- thallium
S carcinogenic metals
- arsenic
- beryllium
- cadmium
- hexavalent chromium
Tier II for Control of Emissions of Toxic
Metals
Tier I feed rate limits are used.
Credit is allowed for metals partitioned to air
pollution control devices.
Owners or operators must conduct emissions
testing to demonstrate compliance with Tier II
emission limits.
Notes:
There are several scenarios listed in the BIF
rule that do not allow use of Tier I or
TierH.
Tiered Approach for Control of Toxic Metals
In the final rule, both the Tier I and Tier II
standards are listed as a function of:
- effective stack height
- terrain type
- land use classification (urban or rural)
15
Regulations and Permit Requirements
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Notes:
Emissions testing is not required for the
adjusted Tier I method.
Adjusted Tier I for Control of Emissions of
Toxic Metals
Owners or operators of facilities that need
additional flexibility in feed rates or emissions
may use either adjusted Tier I or Tier III limits.
- Under the adjusted Tier I scheme, facilities
conduct site-specific dispersion modeling to
determine allowable emissions levels; these
levels then become the allowable feed rates
Notes:
Under Tier HI, feed rate limits are set for
total and pumpable hazardous waste;
feed rates of metals in total feed streams,
total hazardous waste, and pumpable
hazardous waste; and feed rates of
chlorine in total feed streams.
Tier III for Control of Emissions of Toxic
Metals
Owners or operators must conduct site-specific
dispersion modeling to determine allowable
emissions levels.
- Facilities must conduct emissions testing to
determine if actual emissions under worst-
cases conditions do not exceed allowable
levels.
- Feed rate limits are established during the
trial bum or compliance test.
16
Regulations and Permit Requirements
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1 '
Notes:
Permit writers may incorporate these (or
other) permit procedures into the permit.
Notes:
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Special Requirements for Industrial
Furnaces that Recycle Emission Control
Dust
Facilities operating under interim status must do
one of the following:
- Conduct semi-continuous stack monitoring
Pre-condition the BIF system prior to
conducting the compliance test
- Follow the kiln dust monitoring procedures in
L Appendix IX of Part 266
/* ">
Emissions Controls for Hydrogen Chloride
and Chlorine Gas
In the final rule, emissions controls for hydrogen
chloride and chlorine gas are implemented
under a similar tiered approach as for metals
i ler i ana i ler 11 ieeo rate ana emissions rate
screening limits are given in Appendices II
and III, respectively, of Part 266
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Regulations and Permit Requirements
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Notes:
Wastes may not be fed into the unit until all
parameters are within their required limits.
Automatic Waste Feed Cutoffs
The final rule requires systems that automatically
cut off the waste feed if operating conditions
exceed limits established under the compliance
certification or permit. During a cutoff:
- temperature in the combustion chamber must
be maintained above a minimum level
determined in the compliance test or trial bum
- operating parameters must continue to be
monitored
Notes:
The low levels of non-metal constituents
allow the waste to be exempt from the DRE
standard; the low levels of hazardous
metals and nonmetals allow the waste to be
exempt from the paniculate matter
emissions standard.
Exemption of Low-Risk Wastes from the
DRE Standard
"Low-risk" wastes can be exempted from the
DRE standards. Low risk wastes are defined
as:
- wastes with low concentrations of non-metal
hazardous constituents
- wastes that meet the Tier I feed rate limits for
metals
18
Regulations and Permit Requirements
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Notes:
Eligibility for Low-Risk Exemption from
the DRE Standard
There are several conditions for the exemption:
- a minimum of 50% of the fuel fired must be a
"primary" fuel consisting of fossil fuels
- primary fuels must have a heating value of
8,000 Btu/lb
- hazardous wastes cofired with primary fuels
must have a heating value of 8,000 Btu/lb
- hazardous wastes must be fired into the flame
zone of the combustion chamber
Notes:
Eligibility for Low-Risk Exemption from
the DRE Standard (Continued)
- carbon monoxide in the stack gas cannot
exceed 100 ppmv
- wastes cannot contain or be derived from
listed dioxin wastes
- the owner or operator must demonstrate that
the BIF will not pose unacceptable risks to
human health
19
Regulations and Permit Requirements
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1 ^ 1
Notes:
Notes:
Eligibility for Waiver of Participate Matter
Standard
the owner or operator must qualify for the ORE
waiver
the BIF must operate under Tier 1 or adjusted
Tifir 1 metata feed rate screenino limits
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/* 1
Interim Status Requirements
Thpซ?fi facilities must
- certify compliance with emissions controls
- establish limits on operating parameters
- operate within emission controls and
operating limits throughout interim status
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20
Regulations and Permit Requirements
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Notes:
Facilities that were "in existence" on
February 21, 1991, but not in operation,
must still submit a certification of
precompliance
Notes:
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Certification of Precompliance
Owners or operators must certify by August 21 ,
1991 , that emissions from B IPs at the facility
are not likely to exceed metals, HCI, CI2, and
paniculate matter standards
- facilities must comply with the requirements of
the precompliance certification until a revised
one is submitted or a certification of
compliance is submitted
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Certification of Compliance
by August 21 1992 owners or operators of BIFs
must conduct compliance testing and submit a
certification of compliance for emissions
sianuaros ior noi, L>i2, meiais, panicuiaies, ana
CO, and where applicable, HC, dioxins, and
furans
V J
21
Regujations and Permit Requirements
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Notes:
Recertification Requirements
While operating under interim status, facilities
must recertify every three years
This includes performing subsequent
compliance tests
Notes:
These extensions are not available for
certifications of precompliance.
Extension of Compliance Dates for
Certification of Compliance
Interim status facilities that cannot comply with
any of the requirements of the final rule must:
- obtain an automatic 12-month extension that
limits burning of hazardous wastes to 720
hours
- obtain a case-by-case extension
- stop burning hazardous waste and begin
closure
22
Regulations and Permit Requirements
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Notes:
Permit Requirements
There are four categories of facilities
- newly regulated facilities
- existing interim status facilities
- existing permitted facilities
- new facilities
Notes:
Schedule for Submittal of Permit
Applications
Differs depending on the category of the facility
- newly regulated
- existing interim status
- existing permitted
23
Regulations and Permit Requirements
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Notes:
Facility must be considered "in existence"
on or before August 21,1991 in order to
obtain interim status.
Notes:
Newly Regulated Facilities
These facilities must obtain interim status by
August 21, 1991
- submit RCRA Section 3010 notificaions by
May 22,1991
- submit Part A permit applications by
August 21,1991
Existing Interim Status Facilities
These facilities must submit Part B permit
applications when requested ("called") by the
state or region
24
Regulations and Permit Requirements
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Notes:
Existing permitted facility = facility already
operating under a permit for a non-BIF
unit.
Permitted Facilities
must have submitted a Class 1 permit
modification by August 1, 1991
must submit a Class 3 permit modification
request within 180 days of the effective date
(February 17,1992)
Notes:
New facilities are those that were not "in
existence" on or before August 21,1991
New Facilities
must obtain in a permit before burning
hazardous waste.
25
Regulations and Permit Requirements
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Notes:
26
Regulations and Permit Requirements
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Notes:
27
Regulations and Permit Requirements
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Notes:
28
Regulations and Permit Requirements
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Notes:
29
Regulations and Permit Requirements
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PART II
Technology Overview
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,
Notes:
Hydrocarbons present in the waste react
with oxygen from the air when supplied
with thermal energy at temperatures in the
range of 300 to 2200ฐ F to form carbon
dioxide and water.
Notes:
Oxygen may not be available in sufficient
quantities or optimum conditions may not
be present for complete combustion to take
place.
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Technology Overview
Combustion process
- Proper temperature is required for
combustion to occur
- Residence time of waste in the combustion
chamber
- Turbulence required in combustion chamber
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Products of Incomplete Combustion
Carbon monoxide
Hydrocarbons (HC)
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30
Technology Overview
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Time
Turbulence
Temperature
Three TV of combustion
Notes:
31
Technology Overview
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Notes:
Boilers [40 CFR 260.10]
An enclosed device that uses controlled flame
combustion to produce steam or hot water to
generate electricity for on-site use
The unit must have equipment to recover
and export thermal energy in the form of
steam, heated fluids, or heated gases.
The combustion chamber and primary
energy recovery section must be of
integral design.
The unit's thermal recovery efficiency
must be at least 60 percent
At least 75 percent of the recovered
energy must be exported annually. This ^
means that the recovered energy
calculations do not include energy used internally in the device to preheat combustion air or fuel, or to drive
combustion air fans or feed-water pumps.
Notes:
Universe of Boilers
Approximately 925 boilers were burning
hazardous waste prior to the rule
About 600 boilers are conditionally exempt as
small quantity burners of hazardous wastes.
100-200 boilers may stop burning hazardous
waste
100-200 boilers may be subject to interim status
or permit requirements
32
Technology Overview
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Flue Gas
Steam
Output
Fuel/Hazardous
Waste Feed
Source: US EPA, 1991
Combustion Air
Section view of simplified flow diagram of a boiler
(Note: This diagram is not to scale)
33
Technology Overview
-------
Breakdown of Boilers by EPA Region
Region
1
2
3
4
5
6
7
8
9
10
Total
Number of Boilers*
9
10
34
26
20
49
4
2
1
3
158
Those that have submitted a certification of precompliance as of
November, 1991
Notes:
34
Technology Overview
-------
Notes:
Fuels for Boilers
Coal
Oil
Natural gas
Nonconventional fuelswood, bagasse,
municipal and industrial solid wastes (including
hazardous wastes)
Notes:
Fuel-Firing Mechanisms for Boilers
Stoker-fired for burning solid fuels (e.g., coal)
Suspension-fired for burning gas, oil, pulverized
coal
- Use burners mounted on the side or on top of
the combustion chamber to burn feed
materials
35
Technology Overview
-------
Notes:
Notes:
Types of Boilers
Watertube
Firetube
Cast iron (sectional boilers)
Watertube Boilers
Hot combustion gases flow around heat transfer
tubes containing water
Heated water/steam exits the tubes into common
channels
Heating capacities from 10 million Btu/hour to
250 million Btu/hour
36
Technology Overview
-------
Convection
Tubes
Water Wall
Tubes
To
Stack
Burners
(Waste Feed
With Primary
Fuel)
Ash
Source: Babcock and Wilcox. 1978.
Section view of water-tube boiler
(Note: This diagram is not to scale)
Technology Overview
-------
Combustion Chamber
Burners
(Waste Feed
With Primary
Fuel)
Stream Drum
Water Tubes
Mud Drum
Source: U.S. EPA, 1991
Schematic of a simple water-tube boiler.
(Note: This diagram is not to scale)
Notes:
38
Technology Overview
-------
Notes:
Notes:
Watertube Boilers (Continued)
Used to produce high-pressure (up to 1750
pounds per square inch) and high-temperature
(up to 1,000ฐ F) steam
Can produce steam or hot water at rates ranging
from 10,000 pounds/hour to 250,000 pounds per
hour
Firetube Boilers
Hot combustion gases pass through tubes
surrounded by water or another fluid
Thermal input is limited to 30 million Btu/hour
Pressure of steam produced ranges from 165 to
265 pounds per square inch
39
Technology Overview
-------
Steam Outlet
t
Water Inlet
Fuel Grate
(Also Waste
Feed Point)
Fire Tubes
Combustion
Chamber
Section View of a fire-tube boiler, Scotch Marine type
(Note: This diagram is not to scale)
Notes:
40
Technology Overview
-------
Notes:
Cast Iron Boilers
Irregularly shaped heat exchangers in which
combustion gases transfer heat through metal
walls to water or other fluids in adjacent
passages
Maximum thermal input of 10 million Btu/hour.
Used to produce low-pressure steam or hot
water
Notes:
Typical types of dry scrubbers include dry
filters and viscous filters.
Typical types of wet scrubbers include
venturi scrubbers and orifice scrubbers.
Air Pollution Control Equipment on Boilers
Scrubbers often are used by boilers, including
- Wet scrubbers - contaminants are removed
by counter-current washing with a liquid, and
the solids are removed as a slurry
- Dry scrubbers - use dust-free air to force
contaminants through filters
41
Technology Overview
-------
Slurry Feed
Liquid .
Recycle
Clean Gas Outlet
Source: Chemical Engineers Handbook, 1973
Venturi scrubber, wet-approach type
(Note: This diagram is not to scale)
42
Technology Overview
-------
Clean Gas Outlet
Entrainment
Separator
Plates
Primary
Entrainment
Separator
Gas Contract
Region
Gas Inlet
1
Water Inlet
Source: Chemical Engineer Handbook, 1973
Schematic of an orifice scrubber
(Note: This diagram is not to scale)
43
Technology Overview
-------
Notes:
Participates are removed mechanically,
either by washing or vibrating the plates.
Notes:
Air Pollution Control Equipment on Boilers
(Continued)
Precipitators use differences in physical
properties to remove paniculate matter from
exhaust gases
The most common type is the electrostatic
precipitator
Exhaust gases are passed throug h two
oppositely-charged plates, are ionized, and
migrate to a grounded plate
Monitoring of Boilers
Owners or operators of boilers must demonstrate
compliance with emission standards for carbon
monoxide, metals, chlorine gas, hydrogen
chloride, particulate matter, and, in some cases,
hydrocarbons
They must do this by monitoring process feed
rates, combustion temperature, and stack
emissions
44
Technology Overview
-------
Discharge System
Support Insulator
High Voltage Cable
Predprtator Plate Cover
Collecting
(Positive)
Plates
D.C. Output
Clean Gas
Outlet
Direction
of Gas Row
Collecting ! . _ .
; (Positive) Plates | A.C. Input
Source: Coulson, Richardson, Sinnot, 1983
Electrostatic precipltator
(Note: This diagram Is not to scale)
45
Technology Overview
-------
Notes:
Monitoring of Feed Rate
Solid and sludge feeds are measured using
- Volumetric methods
- Level indicators
- Stationary weight indicators
- Conveyer weighing systems
- Momentum flowmeters
Notes:
Monitoring of Feed Rate (Continued)
Liquid feeds are measured using
- Rotameters
- Orifice meters
- Vortex shedding meters
- Positive displacement meters
- Mass flowmeters
46
Technology Overview
-------
Notes:
Notes:
Monitoring of Feed Rate (Continued)
Gaseous feeds are measured using
- Orifice meters
- Vortex shedding meters
Carbon Monoxide, Oxygen, and
Hydrocarbon Monitoring
Owners or operators must use continuous
emissions monitoring
- continuously sample regulated parameter
without interruption
- evaluate detector response at least once
every 15 seconds
47
Technology Overview
-------
Notes:
Temperature Monitoring
The temperature in the combustion chamber is
measured using
- Thermocouples
- Optical pyrometers
Notes:
Ash and solid residuals may be land
disposed either onsite or offsite (hazardous
wastes must meet applicable requirements
under the land disposal restrictions).
Scrubber water is either treated onsite and
discharged to a POTW or sent offsite for
treatment or disposal.
Residuals Generated from Operating
Boilers
Residuals from air pollution control devices can
be solids, sludges, or liquids
- Particulate matter removed from stack gases
- Scrubber water or sludges from wet scrubbers
that remove halogens in exhaust gases
- Bottom ash similar to incinerator ash
48
Technology Overview
-------
Notes:
Notes:
Industrial Furnaces [40 CFR 260.10]
Enclosed devices that are an integral
component of a manufacturing process, and use
thermal treatment to recover materials and/or
energy
Units that burn materials that function solely as
an ingredient for a manufacturing process are
not regulated because the material being burned
is not a solid waste [40 CFR 261.2(e)]
Industrial Furnaces Include 12 Types of
Devices:
1. Cement kilns
2. Lime kilns
3. Aggregate kilns, including light-weight
aggregate kilns
4. Phosphate kilns
5. Coke ovens
49
Technology Overview
-------
\
Notes:
Notes:
f A
Industrial Furnaces (Types of Devices)
Continued:
6. Blast furnaces
7. Smelting, melting, and refining furnaces
8. Titanium dioxide chloride process oxidation
reactors
9. Methane reforming furnaces
1 0. Pulping liquor recovery furnaces
^ J
( >
Industrial Furnaces (Types of Devices)
Continued:
1 1 . Combustion devices used in the recovery of
sulfur values from spent sulfuric acid
1 2. Halogen acid furnaces
1 3. Other furnaces designated by the
Administrator based on the criteria outlined in
the final rule
L J
50
Technology Overview
-------
Universe of Industrial Furnaces That
Submitted a Part A and Certification of
Precompliance*
Region
1
2
3
4
5
6
7
8
9
10
Total
*- As of November, 1991
Notes:
Industrial Furnaces
1
4
15
13
9
22
9
4
6
1
84
51
Technology Overview
-------
Notes:
Cement Kilns
Cement kilns are internally fired, rotating
cylinders lined with refractory material.
Cement kilns are usually positioned ho^ontally
with a slight inclination to aid the flow of feed
material through the combustion zone.
Notes'.
Types of Cement Production Processes
Wet Process
Dry Process
52
Technology Overview
-------
Continuous
Emissions
Monitors
Hot Air
to Preheater
Temperature |
Monitors '
Preheater/
Pyroclone
Source: U.S. EPA, 1991
Process flow diagram of cement kiln with a precalclner
(Note: This diagram is not to scale)
-------
Notes:
Wet Process for Cement Manufacture
Limestone and shale are ground, mixed with
water, and fed into the kiln in a slurry form.
Wet process kilns are longer than dry process
kilns to facilitate the evaporation of water. Their
length can range to 450 feet.
Notes:
Calcination involves heating the limestone
to 1,650ฐ F to drive of carbon dioxide.
Dry Process for Cement Manufacture
Raw materials, including limestone and shale,
are ground (without the addition of water) and
then precalcined in a preheater or precalciner
before being fed into the kiln.
Dry kilns are typically more thermally efficient
than wet kilns.
54
Technology Overview
-------
Continuous \ r
Emissions I | . I
Monitors I 1 ,1
Exaust To
Atmosphere
Temperature Monitors
Exhaust To
Feed Rate Atmosphere
Monitors
vWWv
vuv>'vv v ^'
n
ฉ I
jk f-!Sl.***v
...:::-:!-:=::':-:--. 1
[AVvy//.v\vvy^v-pVv..-.-..
j
0
!
It
>
(i
k
ฎ|
p
f-
~*
Wv
Source: U.S EPA, 1991
1 -Kiln
2 - Slurry Feed
3 - Precipitator
4 - Precipitator Dust Screw
5 - Dust Return
6 - Fuel/Hazardous Waste Feed
7 - Clinker Cooler
8-Clinker
9 - Filter
Schematic of a wet process cement kiln
(Note: This diagram is not to scale)
55
Technology Overview
-------
Exaust To
Atmosphere
(1)
I
Exhaust
To
Atmosphere
Partioulates
(Recycle)
Continuous
-Emissions
Monitors
1 Raw Meal Feed
2 Stage I
3 Stage II
4 Stage III
5 Stage IV
6 Kiln
7 Clinker Cooler
8 Clinker
9 Fuel/Hazardous Waste Feed
A Filter
B Precipitator
C By-Pass
Exaust To
Atmosphere
Feed Rate
Monitors
Water
Scrubber
Water
v@rn
'' il" w" %1* -j* 'I,' .!" " ".*
\
Schematic of a dry process cement kiln with four-stage suspension pre-heaters
(Note: This diagram is not to scale)
56
Technology Overview
-------
Notes:
Hie feed material is subjected to
progressively higher temperatures as it
travels down the kiln.
Cement Manufacturing Process
Raw materials, including limestone and shale,
are fed at the upper end of the inclined kiln and
travel down while combustion gases from the
low end of the kiln travel upwards (i.e., counter
to the flow of feed material).
Notes:
Cement Manufacturing Process (Continued)
The raw materials finally fuse at temperatures
between 2,230 and 2,700ฐ F to form "clinker".
Clinker is removed from the kiln, cooled, ground
to a small size, and mixed with other materials
such as gypsum to form portland cement.
57
Technology Overview
-------
Notes:
Fabric filters are generally made of woven
felted clothes or synthetic fibers.
Baghouses consist of a series of bags
supported on a frame in a large chamber.
Notes:
Controls for Particulate Emissions from
Cement Kilns
Combustion gases leaving the cement kilns
contain 6 to 30 percent of feed solids as dust.
Particulate emissions are controlled by
electrostatic precipitators and fabric filters
(baghouses).
Collected dust is often recycled with the feed.
By-Pass Duct for Cement Kilns Using Dry
Process
5 to 30 percent of kiln off-gases in a dry process
are diverted to a by-pass duct.
Gases from the by-pass duct go to the air
pollution control system for the removal of
particulates.
58
Technology Overview
-------
Front View
Side View
Vibro Motor -
Vibro Frame
Access Door-
Compartment
Isolated for
Bag Cleaning
Oust Laden
Gas Inlet
Clean Gas Outlet
Access Door
Dust Discharge "i!p
Source: Coulson, Richardson, Sinnott, 1983
Multi-compartment baghouse
(Note: This diagram is not to scale)
59
Technology Overview
-------
"
Notes:
Notes:
^sSiiE^
^^^^f^S&jsSESj^r
<" A
By-Pass Duct for Cement Kilns Using Dry
Process (Continued)
Removal of participates from the system is
necessary to prevent accumulation of metal
salts in the combustion chamber that can
adversely aneci ine production piuucoo.
L -J
f ^
Residuals from Cement Kilns
RpQidtiafo frnrn thp^p unit<> include collected
particulate matter from
- Baghouses
- Electrostatic precipitators
v J
60
Technology Overview
-------
Notes:
Monitoring of Cement Kilns
Owners or operators of cement kilns must
monitor for
- Carbon monoxide (and hydrocarbons, if an
alternative CO limit is allowed)
- Combustion temperature (and flue gas
temperature if an air pollution control system
is used)
- Total feed rates of hazardous waste and other
raw materials and fuels
Notes:
Hazardous Waste is Burned to Serve as
Fuel in a Cement Kiln
Operators of cement kilns have been able to
replace up to 50 percent of the kilns' normal
fossil fuel requirement.
Containers of liquid waste have been fired into
the upper end and the midpoint of the kiln.
61
Technology Overview
-------
Notes:
Notes:
Light-Weight Aggregate (LWA) Kilns
Light-weight aggregate is material with a specific
gravity much less than that of sand and gravel.
Light-weight aggregate is used to produce
insulation and nonstructured and light-weight
concrete.
Light-Weight Aggregate Production Process
Light-weight aggregate is produced like cement,
but is made from special clays, pumice, scoria,
shale, or slate.
62
Technology Overview
-------
Notes:
Notes:
Burning of Hazardous Wastes in LWA Kilns
LWA kilns are configured like cement kilns.
They typically burn liquid hazardous wastes.
Raw material is crushed and introduced at the
upper end of a rotary kiln.
Temperature of the kiln is 1,900 to 2,100ฐF.
Heat provided by burners at the lower end of the
kiln where aggregate is discharged.
Air Pollution Control Devices for LWA Kilns
LWA kilns are equipped with wet scrubbers,
fabric filters, or electrostatic precipitators
(ESPs).
Dry systems (fabric filters, ESPs) reduce the
cost of residue management.
Recycling of collected particulates to the kiln is a
common practice.
63
Technology Overview
-------
Notes:
Scrubber water generated from these units
is usually treated in tanks on site and either
(1) discharged to a POTW or (2) sent off
site for treatment or disposal.
Residuals from Light-Weight Aggregate
Kilns
Residuals from these units include
- Collected particulates from fabric filters and
electrostatic precipitators
- Scrubber water from wet scrubbers
Notes:
Monitoring Requirements for Light-Weight
Aggregate Kilns
Because the process is similar to that of cement
kilns, the monitoring requirements are the same
- Carbon monoxide, oxygen, and hydrocarbons
(if necessary)
- Combustion and flue gas temperature (if
necessary)
- Feed rates of hazardous waste, metals,
chlorine, and chlorides
64
Technology Overview
-------
Notes:
Notes:
Halogen Acid Furnaces (HAFs)
HAFs are typically modified firetube boilers.
HAFs that generate steam are regulated as
boilers. HAFs that do not generate steam are
regulated as industrial furnaces.
HAFs generate a halogen acid by scrubbing
chlorine or bromine from combustion gases or
by processing secondary wastestreams
containing 20 to 70 percent chlorine or bromine.
Halogen Acid Furnaces (Continued)
The acid product from a HAF must be fed into a
manufacturing process and the feed should
contain a minimum halogen acid content of 3
percent.
65
Technology Overview
-------
Notes:
Notes:
Designation of HAFs as Industrial Furnaces
HAFs have been designated as industrial
furnaces in response to DOW's petition that they
are furnaces and not incinerators.
HAFs are integral components of the
manufacturing process and are not used to
destroy wastes as is the case with incinerators.
Designation of HAFs as Industrial Furnaces
(Continued)
HAFs are used to recover materials by
reclaiming secondary materials to produce
ingredients for an industrial process that
manufactures a product.
66
Technology Overview
-------
1 1
Notes:
\
>
Notes:
"'"
r N
Designation of HAFs as Industrial Furnaces
(Continued)
HAFs also rscovftr enprnv A tvnireil HAF hiirnQ
wastes with heating values of approximately
9,000 Btu/pound.
v J
r N
Air Pollution Control Systems for Halogen
Acid Furnaces
HAFs US6 wet ^crubhpr^ to naoturp halonpn^
from stack gas to produce a halogen acid.
L j
67
Technology Overview
-------
Notes:
The scrubber water from a halogen acid
furnace is required to be a product acid and
cannot be a waste such as scrubber water
from an incinerator.
Residuals from Halogen Acid Furnaces
Halogen acid furnaces are typically part of a
process and do not usually generate significant
quantities of residuals. However, certain
feedstreams, when burned, may generate a
bottom ash.
Notes:
Unlike cement kilns and LWA kilns,
owners or operators of halogen acid
furnaces may have to monitor ash content
in the feed to their units.
Monitoring Requirements for Halogen Acid
Furnaces
These units are subject to many of the same
monitoring requirements as cement kilns and
light-weight aggregate kilns.
68
Technology Overview
-------
Notes:
Notes:
Smelting, Melting, and Refining Furnaces
Smelting, melting, and refining furnaces are
primarily designed to recover metals.
Scrap metal is used as feed to these furnaces.
Organic emissions are generally not a problem
because typically organics are not present in the
feed.
Examples of Smelting, Melting, and
Refining Furnaces
These units include pyrometallurgical devices
such as cupolas, sintering machines, roasters,
smelters, and foundry furnaces. These units do
not include cement kilns, LWA kilns, and HAFs.
69
Technology Overview
-------
Notes:
70
Technology Overview
-------
Notes:
71
Technology Overview
-------
Notes:
72
Technology Overview
-------
Notes:
73
Technology Overview
-------
PART III
Enforcement
-------
Enforcement Overview
Notes:
Key Dates Associated With Implementation
of the BIF Rule
May 22,1991: Owners or operators of facilities
with BIFs must have submitted a RCRA ง3010
notification (if they had not already done so)
August 21,1991: Facilities "in existence" on
August 21,1991 must have submitted a Part A
permit application and a certification of
precompliance
74
Enforcement
-------
Notes:
Notes:
The non-BIF provisions are effective in an
authorized stale when the state adopts them
as part of their regulations.
>^gppr
r >
Key Dates Associated With Implementation
of the BIF Rule (Continued)
August 21 ,1 991 Facilities with a permit for one
or more non-BIF units on February 21,1991
must have submitted a Class I permit
moaiiiCauon
February 17,1992: Permitted facilities must
submit Class II or Class III permit modifications
August 21, 1992: Interim status facilities must
V^ submit a certification of compliance J
r x
State Authorization Issues Under the BIF
Rule
Because the BIF rule was promulgated primarily
under HSWA authority, most of its provisions
are effective immediately in all states
the only exceptions are the non-BIF
provisions dealing with sludge dryers, carbon
regeneration units, infrared incinerators, and
plasma arc incinerators
C J
75
Enforcement
-------
J
Notes:
Notes:
These procedures are described in more
detail in a guidance memorandum issued
by OWPE on January 22, 1992.
ฑ^Jฃz'*S$' "m
f "\
Major Requirements of the BIF Rule for
Interim Status Facilities
Certification of precompliance-certify that
emissions of metals, HCI, CI2, and participates
are not likely to exceed allowable limits
f^ar+ifi nafrirtn r\f ofMnnlianno-Portifv f^nrnnlisinPP
with emissions standards for metals, HCI, CI2,
CO, and where applicable, HC and dioxins/
furans
^ J
S ">
Enforcement Responses for Facilities That
Submit an Inadequate Certification of
Precompliance
Issue a RCRA Section 3007 letter for minor
omissions or inadequacies
Issue a NOV for major deficiencies
Pnssihlv ordpr closure of the BIF if no resoonse
is received to the two options above
V ->
76
Enforcement
-------
Notes:
Two exceptions to the policy are
- wastes burned for testing purposes
(40 CFR 266.103 (a)(6))
- wastes burned solely as an ingredient
Applicability of the Sham Recycling Policy
to the BIF Rule
A policy issued March 16, 1983 (48 FR 11157)
stated that wastes with a heating value less than
5,000 Btu/lb were being incinerated when
burned.
This policy remains in effect until owners or
operators submit a certification of compliance;
after a certification of compliance is submitted, a
BIF may burn wastes for any purpose, including
for destruction.
Notes:
These priorities are consistent with the
recommendations of the RCRA
Implementation Study conducted in 1990.
Enforcement Priorities
Inspectors and enforcement officials should
target violators who
- Fail to submit a Part A permit application
- Fail to submit a certification of compliance
77
Enforcement
-------
Notes:
Waste Minimization Opportunities Under
the BIF Rule
Inspectors and enforcement officials should look
for opportunities to obtain commitments from
owners or operators to implement waste
minimization measures.
78
Enforcement
-------
Notes:
79
Enforcement
-------
Notes:
80
Enforcement
-------
Inspections
Notes:
Inspection Types
Inspections will be conducted for facilities
operating under:
- precompliance certifications
- compliance certifications
- permits
- small quantity burner exemption
- smelting, melting, and refining exemption
81
Enforcement
-------
Notes:
General Requirements for BIFs
Owners or operators of BIFs must comply with:
- TSDF standards - Parts 264 and 265,
Subparts A - L, BB
- If hazardous waste is stored before burning,
the owner or operator must comply with Parts
264 and 265, Subpart I and/or Subpart J.
82
Enforcement
-------
Direct Transfer Operations
Notes:
EPA encourages facilities to use permanent
storage areas and allows changes during
interim status for this purpose.
Units exempt (e.g., small quantity burners)
under the rule are not required to meet
these standards.
Storage Before Burning in BIFs
The final rule regulates direct transfer operations
in 40 CFR 266.111.
- Rule includes standards for areas where
transport vehicles and ancillary equipment are
located.
Concerns with direct transfer include the
potential for fires, explosions, and spills and the
ability of the burner to consistently provide
efficient combustion of the waste.
83
Enforcement
-------
Notes:
Requirements for Direct Transfer Areas
The requirements for direct transfer areas
include:
- structural integrity
- containment
- leak detection
- response to leaks and spills
- design and installation of new direct transfer
equipment
- closure
Notes:
Enforcement personnel should arrange a
visit to the facility so they can witness a
direct transfer operation.
Inspection of Direct Transfer Operations
Inspectors should focus on requirements for:
- managing incompatible wastes
- spill prevention controls
- automatic waste feed cutoffs
- applicable Subpart I and Subpart J
requirements
- inspection requirements
- integrity of equipment
84
Enforcement
-------
Inspection and Recordkeeping Requirements for
Facilities with Direct Transfer Operations
Direct transfer operations should be inspected hourly for
leaks and other potential problems. Facilities should
inspect:
- overfill and spill control equipment
- direct transfer equipment
- monitoring equipment
- cathodic protection systems
Records of inspections must be maintained in the operating
record
Notes:
Facilities must document these inspections.
85
Enforcement
-------
Integrity Assessments for Direct Transfer Areas
Owners or operators of direct transfer equipment without
secondary containment must perform an integrity
assessment of the equipment. The assessment must
consider design standards, hazardous characteristics of
wastes, corrosion protection, age of equipment, and results
of leaks tests.
Notes:
The integrity assessment must be certified by a registered professional engineer.
86
Enforcement
-------
Notes:
Notes:
Standards for New Direct Transfer
Equipment
New direct transfer equipment must meet the
design and installation standards for tank
systems, and include:
- backfill requirements
- tightness tests
- equipment support and protection
requirements
- corrosion protection
- certification of construction
Response to Leaks or Spills*
When a leak or spill occurs, the owner or
operator must:
- cease feeding of waste
- inspect direct transfer equipment
- remove wastes from the system
- determine cause of release
- notify the Regional Administrator
- certify major repairs
* same as for tanks 40 CFR 265.196 (Subpart J)
87
Enforcement
-------
Precompliance
Notes:
Inspection Preparation*
Prior to an inspection, inspectors should:
- review the certification
- become familiar with the types of units at the
facility (draw process flow diagrams)
- obtain checklists (if available)
These preparation activities are important for
any inspection
88
Enforcement
-------
Notes:
Key Operating Parameters for Which Precompliance
Limits Must Be Established
Total feed rate of all pumpable hazardous wastes* and total feed
rate of all hazardous wastes.
Feed rate of each of the 10 BIF-regulated metals in:
- Total feed streams**,
- Total hazardous waste feed streams, and
- Total pumpable hazardous waste feed streams.*
* Total feed rate of chlorine and chlorides in total feed streams.
Total feed rate of ash in total feed streams, except for cement and
light-weight aggregate kilns.
Maximum production rate.
* Not applicable if complying with the Tier I or adjusted Tier I metals
feed rate screening under ง266.106(b) or (e)
** Not applicable for industrial furnaces recycling paniculate matter
complying with ง266.103(b)(4)
89
Enforcement
-------
Facilities that Recycle Particulate Matter
Feed rates of metals may need to be adjusted because
this recycling may lead to a gradual increase in metals
concentrations within the unit.
Facilities must
- Specify concentration limits for metals in collected
particulate matter;
- Sample the stack gas for metals; or
- Condition the furnace prior to precompliance or
compliance testing
Notes:
90
Enforcement
-------
Notes:
Effect of Selected Tier on Inspections
Under Tier I or adjusted Tier I, a facility will not
have limits on feed rate of pumpable hazardous
waste or feed rate of each metal in the total
pumpable hazardous wastestream.
- Inspectors should examine only total
hazardous waste feed rates.
- Conservative hazardous waste feed rates are
found in Appendix I to the rule.
Notes:
Feed Rate Limits for Cement Kilns and
Light-Weight Aggregate Kilns
These units have no feed rate limit for ash
91
Enforcement
-------
Notes:
Inspectors should refer to the
"Implementation Document for the BIF
Rule" and the "Handbook on QA/QC
Procedures for Hazardous Waste
Incinerators" for additional guidance on
testing and sampling requirements
Waste Analysis and Sampling
Inspectors should check documentation
associated with waste characterization,
especially the waste analysis plan
- identification of waste streams
- parameters to be tested
- frequency of analysis
- sampling and analytical methods
Notes:
Waste Analysis and Sampling (Continued)
Other important information
- date samples are obtained
- name of laboratory conducting the analysis
- sample preparation and analysis methods
- date the analysis was performed
- results (data)
- analytical QA/QC results
92
Enforcement
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1 \
Notes:
Inspectors should examine operating and
inspection logs for feed rates; concentration
of metals, chlorine, and ash; and schedules
for inspecting monitors.
Frequency of Monitoring
Owners or operators must monitor operating
parameters on either an instantaneous or hourly
rolling average basis:
- concentrations of metals, total chlorine and
chlorides, and ash in each feed stream
- other relevant operating parameters
Notes:
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Instantaneous Limit
A value that may not
be exceeded at any time
93
Enforcement
-------
Notes:
Notes:
Hourly Rolling Average
Arithmetic mean of the 60 most recent 1-minute
average values recorded by a continuous
monitoring system
Continuous Monitor
continuously samples and evaluates detector
response once every 15 seconds
computes and records the average value at
least every 60 seconds
94
Enforcement
-------
1 \
Notes:
Notes:
Inspectors should review logs, strip charts,
and printouts to verify that monitoring is
conducted and that results are maintained
in the operating record once monitors are
installed.
Monitors must be installed at the time of
the certification of compliance
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Determining Proper Function of Monitoring
Equipment
conduct visual inspection
ask operators questions
review inspection log
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Additional Monitoring Requirements
Once monitoring equipment is installed and
operating correctly, facilities operating under a
certification of precompliance are required to
conduct continuous monitoring for:
- carbon monoxide
- hydrocarbons (in certain cases)
- combustion chamber temperature
- other parameters as dictated by the type of air
pollution control system used
V J
95
Enforcement
-------
Compliance Certification
Notes:
Additional Operating Parameters for Which
Compliance Limits Must Be Established
CO concentration and where required, HC
concentration in the stack gas
maximum combustion chamber temperature*
maximum flue gas temperature entering the PM
control device*
limits for other specified ARCS operating parameters
_(40CFR 266^l_q^(c)(2)[ix-xiii))
* Not applicable if complying with the Tier I or adjusted
Tier I metals feed rate screening limits under 40 CFR
266.106(b) or (e) j
96
Enforcement
-------
1 1
Notes:
This includes:
- daily calibration checks for each
monitor,
- daily system audits;
- quarterly calibration error tests; and
- annual performance specifications tests
Notes:
The stack gas concentrations of carbon
monoxide may exceed 100 ppm for certain
industrial furnaces provided that stack gas
concentrations of hydrocarbons do not
exceed 20 ppmv.
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Continuous Emissions Monitors Operation
and Maintenance
CO, HC, and oxygen monitors must be installed,
operated, and maintained per Appendix IX of
Part 266
records of operation and maintenance must be
maintained in the facilities operating record
^ j
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Compliance Monitoring Requirements
Facilities operating under a certification of
compliance must conduct continuous emissions
monitoring to ensure compliance with the
following in the stack gas:
- carbon monoxide -100 ppm; corrected to 7
percent oxygen on a dry basis
- carbon monoxide and oxygen must be
monitored on a continuous basis at the same
location
c -J
97
Enforcement
-------
Notes:
Inspectors should examine logs and/or strip
charts to verify compliance and to ensure
that thermocouples or pyrometers are
adequately maintained and operated.
Interviews with key facility personnel
should also be conducted to verify
procedures.
Temperature Monitoring Requirements
Owners or operators must continuously monitor
combustion chamber temperature to ensure
temperature limits are met.
- Temperature must be monitored as close to
combustion zone as possible and upstream of
any quench water injection.
Notes:
Automatic Waste Feed Cutoff System
The following operating parameters must be
connected to the automatic waste feed cutoff
system
- maximum CO concentration in the stack gas
- maximum HC concentration in the stack gas
- maximum production rate
- maximum total feed rate of hazardous waste
98
Enforcement
-------
Automatic Waste Feed Cutoff System (Continued)
- minimum combustion chamber temperature
- maximum feed rate of pumpable hazardous waste*
- maximum combustion chamber temperature*
- maximum flue gas temperature entering a paniculate
matter control device
- limits of key ARCS operating parameters
* does not apply to facilities complying with Tier I or
adjusted Tier I feed rate screening limits
Notes:
99
Enforcement
-------
Automatic Waste Feed Cutoff System (Continued)
After a cutoff:
- Monitoring of all parameters must continue
- Wastes cannot be fed back into the unit until operating
conditions again meet terms of the certification of
compliance.
- Minimum combustion chamber temperature that
occurred during the compliance test must be
maintained while waste remains in the combustion
chamber
- When the unit is operational, the system must be
tested once every 7 days, unless the owner or
operator can demonstrate that less frequent testing is
appropriate. However, the system must be tested at
least every 30 days.
Notes:
Inspectors should examine the operating record to determine compliance with these provisions. Inspectors
should also have the facility demonstrate that the automatic waste feed cutoff system works (if possible).
100
Enforcement
-------
Requirements for Air Pollution Control Equipment
Monitoring requirements for air pollution control devices
include:
For wet scrubbers (including wet ionizing scrubbers):
- minimum liquid to flue-gas ratio
- minimum scrubber blowdown or maximum
suspended solids content of scrubber waste
- minimum pH level of the scrubber water
For venturi scrubbers:
- minimum differential gas pressure across the venturi
Notes:
101
Enforcement
-------
Requirements for Air Pollution Control Equipment
(Continued)
For dry scrubbers:
- minimum caustic feed rate
- maximum flue gas flow rate
For wet ionizing scrubbers or electrostatic precipitators:
- minimum electrical power to the precipitator plates
- maximum fuel gas flow rate
For fabric filters or baghouses:
- minimum pressure drop across the unit
Notes:
102
Enforcement
-------
Notes:
Notes:
Obtaining Compliance Information
fill out certified values on checklist prior to
inspection
verify correct value
verify units
determine if instantaneous versus hourly rolling
average
Strip Charts
scale, orientation, units, and zero offset
color of ink and number of different parameters
time scale and dates
recordkeeping problems
103
Enforcement
-------
Notes:
Computerized Printouts
readable and understandable format
meaning of numbers presented
completeness
Notes:
Additional Sources of Information for
inspections
Inspectors can obtain more information concerning
a particular facility by:
- attending the compliance test burn or trial
burn (inspectors may want to attend the burn
with the permit writer for the facility)
- taking courses on combustion technologies
and air pollution control systems
- accompanying an experienced inspector on
several inspections
104
Enforcement
-------
1 \
Notes:
Notes:
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Specialized Hazardous Waste Combustion
Inspectors
New initiative in which EPA Regions are
participating
* Cr M cvclllUdliy WUUIU WNo Sidle IllVUIVclIlcril
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Inspections at Permitted Facilities
The requirements for an interim status facility
operating under a certification of compliance
and a permitted facility are nearly the same.
However, permitted facilities must
demonstrate a 99.99% destruction and
removal efficiency requirement for toxic
organics and a 99.9999% destruction and
ItMIlUVal clilOlciloy IUI UlUXIIIo. I 1 llo lo UUIlc
during the trial burn.
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105
Enforcement
-------
Inspections for Small Quantity Burners
There are several conditions for obtaining the small
quantity burner exemption:
- Applies only to BIFs burning hazardous waste at the
same facility where the waste was generated.
- Hazardous waste cannot constitute more than 1 % of
the total heat input or mass of the feed.
- Hazardous waste must have a minimum heating
value of 5,000 Btu/pound.
- Hazardous waste cannot contain any F-listed dioxin
wastes.
Notes:
Inspectors should examine notifications submitted by facilities and records documenting compliance with the
exemption. These documents include information concerning:
- quantities of hazardous waste and other fuels per bum
- heating value of the hazardous waste
106
Enforcement
-------
Notes'.
Smelting, Melting, and Refining Deferral
Notification
Sampling and analysis
Records to document compliance
107
Enforcement
-------
Notes:
108
Enforcement
-------
Notes:
109
Enforcement
-------
Notes:
110
Enforcement
-------
Notes:
111
Enforcement
-------
Additional Information
1.
2.
Implementation Document for BIFs (available Spring 1992)
Hazardous Waste Incinerator Inspection Manual
- OSWER Directive No. 9938.6 (April 1989)
- Available from State or Region
Hazardous Waste Incinerator Inspection Video
- Available from Regional RCRA Training Coordinators
Region I:
Region II:
Region III:
Region IV:
Region V:
Region VI:
Region VII:
Region VIII:
Region IX:
Region X:
Georgie Bishop
Margarite Halley
Judy Lee
Margaret Mears
Alan Lang
Donna Smith
Gary Bertram
Charles Brinkman
Eve Levin
Susan Hutcherson
FTS-835-3393or617-
FTS-264-9593or212-
FTS-597-7938or215-
FTS-257-2234 or 404-
FTS-353-2775or312-
FTS-255-6700or214-
FTS-270-7533or913-
FTS-330-1489or303-
FTS-484-2110or415-
FTS-399-2852 or 206-
565-3393
264-9593
597-7938
347-2234
353-2775
655-6700
551-7533
293-1489
744-2110
553-2852
Federal Registers:
February 21,1991 (56 FR 7134)
July 17,1991 (56 FR 32688)
August 27,1991 (56 FR 42504)
- Available from the RCRA Docket: 202-260-9327
-------
Additional Information
5. Handbook on Hazardous Waste Incineration Measurement Guidance Manual
(EPA/625/6-89/021)
- Available from ORD Publications: FTS-684-7562 or 513-569-7562
6. Schedule of Air Pollution Training Courses
- Available from: Air Pollution Training Institute
Environmental Research Center- MD17
Research Triangle Park, NC 27711
*U.S GOVERNMENT PRINTING OFF1CI: 1992 -6J17- ooy.7085
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BIF Rule Satellite Training Course
April 7,1992
Do you have a question?
ซ/ JL
(One question per card, please)
Question directed to:
Topic:
Question:
Name of panelist
Name and
viewing location:
Your name
Affiliation
Office Location
Phone
Question directed to:
BIF Rule Satellite Training Course
April 7,1992
you nave i
(One question per card, please)
Name of panelist
Topic:
Question:
Name and
viewing location:
Your name
Office Location
Affiliation
Phone
-------
Name:
Address:
Phone Number: (_
BIF Satellite Training Course
Evaluation Form
April 7,1992
Affiliation:
I. Is this your first satellite training? Yes
No
Please use the following key to respond to the following statements:
SA - strongly agree,
A - agree,
U - undecided,
D - disagree, and
SD - strongly disagree.
1) "Regulations" Session
a) The pace of the presentation was adequate.
b) The level of detail of the information was appropriate.
c) The length of the question and answer session was adequate.
d) The questions were handled professionally.
2) Technology Overview" Session
a) The pace of the presentation was adequate.
b) The level of detail of the information was appropriate.
c) The length of the question and answer session was adequate.
d) The questions were handled professionally.
3) "Enforcement" Session
a) The pace of the presentation was adequate.
b) The level of detail of the information was appropriate.
c) The length of the question and answer session was adequate.
d) The questions were handled professionally.
4) The training site setting (i.e. room size, temperature, brightness)
was good.
5) The reception (audio/video) was good.
6) The site facilitator was helpful.
7) Manuals/handouts were available and useful.
8) The training provided me with an adequate understanding of the
topic.
9) The information and ideas presented will help me on the job.
10) The video segments were well produced and helped me to
understand the topic.
SA A U D SD
D D D D D
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D D D D D
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III. Was the length of the training adequate?
IV. Did your question get asked over the telephone? Yes No
V. Did this training meet your expectations? Yes No
VI. Do you think this satellite training was as successful as a face-to-face training?
Yes No Why?
VII. Describe the strengths of this satellite training.
VIII. Describe the weaknesses of this satellite training.
IX. Comments or suggestions:
Return evaluation forms to:
Kate Anderson
U.S. Environmental Protection Agency
OWPE - RCRA Enforcement Division
401 M Street, SW(OS-510)
Washington, D.C. 20460
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