4EPA Hazardous Waste Boilers and Industrial Furnaces (BIF) Inspection Workshop 1993 Participant's Manual Sponsored by: RCRA Enforcement Division Dffice of Waste Programs Enforcement ------- TABLE OF CONTENTS Section Page 1.0 INTRODUCTION TO THE WORKSHOP 1-1 2.0 REVIEW OF REGULATIONS AND TECHNOLOGIES 2-1 3.0 CASE STUDY #1 - XYZ CHEMICAL COMPANY 3-1 3.1 PREINSPECTION ACTIVITIES 3-2 3.2 ENTRANCE INTERVIEW 3-12 3.3 CONTROL ROOM INSPECTION 3-16 3.4 CEM CALIBRATION INSPECTION 3-19 3.5 HAZARDOUS WASTE TANK STORAGE INSPECTION 3-21 3.6 INSPECTION OF THE BOILER AND ANCILLARY EQUIPMENT ....... 3-23 3.7 INSPECTION OF THE AIR POLLUTION CONTROL EQUIPMENT AND RESIDUE MANAGEMENT 3-26 3.8 RECORDS REVIEW 3-28 3.9 CLOSING INTERVIEW 3-31 4.0 CASE STUDY #2 - ABC CEMENT COMPANY 4-1 4.1 PREINSPECTION ACTIVITIES 4-2 4.2 ENTRANCE INTERVIEW 4-12 4.3 CONTROL ROOM INSPECTION 4-14 4.4 DIRECT TRANSFER AREA INSPECTION 4-16 4.5 KILN AND ANCILLARY EQUIPMENT INSPECTION 4-18 4.6 AIR POLLUTION CONTROL EQUIPMENT AND RESIDUE MANAGEMENT SECTION 4-21 4.7 RECORDS REVIEW 4-23 4.8 CLOSING INTERVIEW 4-27 ------- Introduction to the BIF Workshop Participant Manual The purpose of this workshop is to enable you to conduct effective inspections of facilities operating boilers and industrial furnaces (BIF). Through your participation in this workshop, you will become familiar with the general procedures for conducting BIF inspections and you will acquire a knowledge of BIF technologies and regulations. The workshop will be conducted by an Environmental Protection Agency instructor over a period of one and one-half days. The workshop will consist primarily of 1) a review of BIF technologies and regulations, 2) a case study involving an inspection of a chemical manufacturing facility that is operating a boiler, and 3) a case study of an inspection of a cement manufacturing facility that is operating a cement kiln. For the two case studies, participants will be divided into work groups of from five to seven persons, so they will be able to collaborate during the case study activities. The case study activities will be presented in detail by the instructor and will include reading inspection scenarios, using documents that are needed for an inspection, determining potential problems with compliance with BIF regulations, and discussing the procedures and issues involved in BIF inspections. The format of this workshop is highly interactive, unlike one-way lecture formats. Such a format can greatly enhance the success of the workshop by allowing participants to share the broad base of experience they bring with them. Therefore, your questions, comments, and discussion are encouraged throughout the workshop. ------- 1.0 INTRODUCTION TO THE WORKSHOP Three Main Components of the Workshop Review of regulations and technologies Case Study #1: Evaluation of a chemical manufacturing facility that operates a boiler Case Study #2: Evaluation of a cement manufacturing facility that operates a cement kiln Notes: 1-1 ------- INTRODUCTION TO THE WORKSHOP AGENDA FOR THE BIF INSPECTION WORKSHOP First Dav 8:30 Introduction 9:00 Overview of Regulations and Technologies 10:30 Break 10:45 Case Study #1 12:30 Lunch 1:30 Case Study #1 (continued) 3:15 Break 3:30 Case Study #2 4:30 Adjournment 1-2 ------- INTRODUCTION TO THE WORKSHOP AGENDA FOR THE BIF INSPECTION WORKSHOP (continued) Second Day 8:30 9:45 10:00 11:00 11:15 12:00 Case Study #2 (continued) Break Case Study #2 (continued) Break Question and Answer Session Adjournment 1-3 ------- 2.0 REVIEW OF REGULATIONS AND TECHNOLOGIES Objectives of Reviewing Regulations and Technologies To familiarize the participant with the key portions of the BIF regulations that inspectors of facilities with BIFs should know. To familiarize the participant with major functions and components of BIF technologies. OUTLINE FOR REVIEW OF REGULATIONS AND TECHNOLOGIES BACKGROUND APPLICABILITY STANDARDS FOR MANAGEMENT OF WASTE BEFORE BURNING INTERIM STATUS STANDARDS PERMIT STANDARDS EMISSION STANDARDS EXEMPTIONS DIRECT TRANSFER REQUIREMENTS REGULATION OF RESIDUES OVERVIEW OF COMBUSTION AND AIR POLLUTION CONTROL TECHNOLOGIES 2-1 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES BACKGROUND ON THE BIF RULE Ť The BIF rule was promulgated on February 21, 1991 and became effective on August 21, 1991. The rule established regulations similar to those for incineration for burning hazardous waste for energy recovery. The rule regulates all forms of burning, including that for destruction, for energy recovery, and for materials recovery. Notes: APPLICABILITY OF THE BIF RULE (40 CFR 266.100) Most hazardous wastes burned in BIFs are subject to the rule. Certain hazardous wastes are not subject to the rule: conditionally exempt wastes used oil bumed for energy recovery gas recovered from landfills Notes: 2-2 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES APPLICABILITY OF THE BIF RULE (continued) Certain types of facilities are currently not subject to the BIF rule: coke ovens that burn only wastes generated from coke by-products including decanter tank tar sludge listed as K087, K141 through K14S, K147, and K148 (40 CFR 266.100(b)(4)) smelting, melting, and refining furnaces that process hazardous waste for metals recovery, (which are subject to only 40 CFR 266.101 and 266.112 (40 CFR 266.100 (c)). APPLICABILITY OF THE BIF RULE (continued) smelting, melting, and refining furnaces that process hazardous waste to recover precious metals, which are subject only to 266.112 provided they meet certain requirements (40 CFR 266.100(f)) Notes: 2-3 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES STANDARDS FOR MANAGEMENT OF WASTES BEFORE THEY ARE BURNED IN A BIF (40 CFR 266.101) Generators are subject to the requirements of 40 CFR Part 262. Transporters are subject to the requirements of 40 CFR Part 263. Storage facilities (except small quantity burners) are subject to applicable provisions in subparts A through L of 40 CFR Parts 264 and 265 and 40 CFR Part 270. Notes: INTERIM STATUS STANDARDS: QUALIFICATION FOR INTERIM STATUS To qualify for interim status, facilities that have BIFs must have been "in existence" on the date of the BIF rule as defined in 40 CFR 266.103(a)(l). The term "in existence" means that the owner or operator was burning hazardous waste on the effective date of the rule or both: had obtained permits to construct had begun construction, or entered into contracts for construction Notes: 2-4 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: REQUIREMENTS FOR INTERIM STATUS FACILITIES The facility should have submitted a Part A or a revised Part A permit application by August 21, 1991. The facility should have submitted a certification of precompliance by August 21, 1991. The facility should have submitted a certification of compliance by August 21, 1992. INTERIM STATUS STANDARDS: REQUIREMENTS FOR INTERIM STATUS FACILITIES (continued) Owners or operators may obtain an automatic, one-year extension that allows them to burn hazardous waste for a maximum of 720 hours to conduct compliance testing A facility can obtain an extension of the deadline for submitting the certification of compliance, with approval from the Director. 2-5 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: GENERAL REQUIREMENTS FOR INTERIM STATUS FACILITIES THAT HAVE BIFS (40 CFR 266.103 (a)(4)) 40 CFR Part 265 Subpart A B C D General General facility standards Preparedness and prevention Contingency plan and emergency procedures Section(s) 265.4 265.11-265.17 265.31-265.37 265.51-265.56 INTERIM STATUS STANDARDS: GENERAL REQUIREMENTS FOR INTERIM STATUS FACILITIES THAT HAVE BIFS (40 CFR 266.103 (a)(4)) (continued) 40 CFR Part 265 Subpart E G H BB - Manifest system, recordkeeping, and reporting Closure and postclosure Financial requirements Equipment leaks ".':""; '"' '.;' Section(s) . :; ^.. Ł.$ 265.71-265.77 265.111-265.115 265.141-143,265.147-150 All except 265.1050(a) Notes: 2-6 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: SPECIAL REQUIREMENTS FOR FURNACES OPERATING UNDER INTERIM STATUS Furnaces feeding hazardous waste for purposes other than solely as an ingredient and at locations other than the hot end must (40 CFR 266.103(a)(5)): feed wastes into an area that has a combustion gas temperature of at least 1800°F (unless complying with Tier I) determine and document that adequate oxygen is present in combustion gases INTERIM STATUS STANDARDS: SPECIAL REQUIREMENTS FOR FURNACES OPERATING UNDER INTERIM STATUS (continued) for cement kilns, wastes must be fed into the kiln (not into an ancillary device, such as the precaJciner) for cement kilns, meet the hydrocarbon monitoring requirements in 40 CFR 266.104(c) or 266.103(c)(5) upon certification of compliance, regardless of the carbon monoxide concentration achieved during the compliance test Notes: 2-7 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: SPECIAL REQUIREMENTS FOR FURNACES OPERATING UNDER INTERIM STATUS (continued) Wastes may not be burned for purposes other than solely as an ingredient when: the waste has an as-fired heating value of 5,000 BTU/lb or more the waste has a total concentration of nonmetal hazardous constituents of more than 500 ppm by weight Notes: 2-8 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: RESTRICTIONS ON BURNING HAZARDOUS WASTE THAT IS NOT A FUEL With limited exceptions, interim status facilities that have BIFs may not burn wastes having a heating value of less than 5,000 Btu/lb (these wastes cannot be defined as fuels because of their low heating value) before they obtain certification of compliance (40 CFR 266.103(a)(6)). INTERIM STATUS STANDARDS: RESTRICTIONS ON BURNING HAZARDOUS WASTE THAT IS NOT A FUEL (continued) Facilities are eligible for those limited exceptions when: they burn hazardous waste as an ingredient they burn hazardous wastes during compliance testing they qualify for certain exceptions detailed in 40 CFR 266.103(a)(6)(iii) (for example, the BIF is operating under the incinerator requirements in 40 CFR Part 265, Subpart O) 2-9 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: CERTIFICATION OF PRECOMPLIANCE Owners and operators were required to submit a certification of precompliance to demonstrate that, as determined by engineering judgment, the emissions limits of the following are not likely to be exceeded (40 CFR 266.103(b)(l)): paniculate matter INTERIM STATUS STANDARDS: CERTIFICATION OF PRECOMPLIANCE (continued) metals, including: antimony arsenic barium beryllium cadmium chromium lead mercury silver thallium hydrogen chloride (HC1) and chlorine gas Notes: 2-10 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: OPERATING CONDITIONS UNDER CERTIFICATIONS OF PRECOMPLIANCE (40 CFR 266.103(b)(3)) Feed rate of total hazardous waste Feed rate of pumpable hazardous waste (unless complying with Tier I or adjusted Tier I feed rate screening limits) INTERIM STATUS STANDARDS: OPERATING CONDITIONS UNDER CERTIFICATIONS OF PRECOMPLIANCE (40 CFR 266.103(b)(3)) (continued) Feed rate of each metal in total feed streams total hazardous waste feed total pumpable hazardous waste feed (unless complying with Tier I or adjusted Tier I) INTERIM STATUS STANDARDS: OPERATING CONDITIONS UNDER CERTIFICATIONS OF PRECOMPLIANCE (40 CFR 266.103(b)(3)) (continued) Total feed rate of chlorine and chloride Total feed rate of ash (except for cement kilns and lightweight aggregate kilns) Maximum production rate (unless complying with Tier I or adjusted Tier I) Notes: 2-11 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: MEASUREMENT OF FEED RATES AND PRODUCTION RATE FOR THE PRECOMPLIANCE PERIOD Determination of feed rates can be based on (40 CFR 266.103(b)(Sť: instantaneous limits hourly rolling average limits, using a continuous monitor that samples, evaluates the response at least once every 15 seconds, and computes the average at least once every 60 seconds Hourly rolling averages are the arithmetic mean of the one-minute averages over a 60-minute period. Notes: 2-12 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: EMISSION PARAMETERS FOR CERTIFICATIONS OF COMPLIANCE (40 CFR 266.103(c)) Owners or operators must conduct compliance testing to demonstrate compliance with emissions standards for: carbon monoxide paniculate matter metals HC1 and C12 INTERIM STATUS STANDARDS: EMISSION PARAMETERS FOR CERTIFICATIONS OF COMPLIANCE (40 CFR 266.103(c)) (continued) In certain cases, owners or operators also may be required to demonstrate compliance with emissions standards for: hydrocarbons dioxins and furans Notes: 2-13 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: EXTENSIONS OF THE TIME FOR CERTIFICATION OF COMPLIANCE (40 CFR 266.103(c)(7)) Facilities that did not submit a certification of compliance by August 21, 1992 should have: stopped burning hazardous waste on that date, or submitted a notification that the facility will limit burning of hazardous waste to a period of 720 hours for compliance testing (and submit a certification of compliance by August 23, 1993), or obtained an extension under 40 CFR 266.103(c)(7)(ii) Notes: INTERIM STATUS STANDARDS: COMPLIANCE TESTING At least 30 days before beginning the test, owners or operators must provide certain information, required under 40 CFR 266.103(c)(2), concerning the compliance test. Testing must be conducted under the operating conditions established under the certification of precompliance (40 CFR 266.103(c)(3)). Certification of compliance must be submitted within 90 days of the completion of the compliance testing (40 CFR 266.103(c)(4)). Notes: 2-14 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: REVISED CERTIFICATION OF COMPLIANCE Owners or operators may submit a revised certification of compliance if a new compliance test is conducted (40 CFR 266.103(c)(8)). Under this provision, the burning of hazardous waste outside the conditions of an existing certification of compliance must not exceed 720 hours. The owner or operator must provide certain information within 30 days of burning hazardous waste outside the conditions of the existing certification of compliance. INTERIM STATUS STANDARDS: REVISED CERTIFICATION OF COMPLIANCE (continued) Until a permit is issued, owners or operators must conduct a new compliance test and submit a revised certification of compliance at least once every three years. Notes: 2-15 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: AUTOMATIC WASTE FEED CUTOFF The waste feed to the BIF must be cut off if certain parameters are exceeded, including (40 CFR 266.103(g)): maximum concentration of CO (and, if applicable, concentration of HC) in the stack gas maximum production rate (unless complying with Tier I or adjusted Tier I) maximum feed rate of hazardous waste INTERIM STATUS STANDARDS: AUTOMATIC WASTE FEED CUTOFF (continued) maximum feed rate of pumpable hazardous waste (unless complying with Tier I or adjusted Tier I screening limits for feed rates of metals) Notes: 2-16 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: AUTOMATIC WASTE FEED CUTOFF (continued) The waste feed to the BIF must be cut off if certain parameters are exceeded, including: maximum temperature of the combustion chamber (unless complying with Tier I or adjusted Tier I) maximum temperature of flue gas entering a paniculate matter control device (unless complying with Tier I or adjusted Tier I) INTERIM STATUS STANDARDS: AUTOMATIC WASTE FEED CUTOFF (continued) limits on key operating parameters for the air pollution control system (see pages IV-23 and IV-24 of the BIF Inspection Checklist) Notes: 2-17 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: CONTROL OF FUGITIVE EMISSIONS (40 CFR 266.103(h)) Fugitive emissions must be controlled by one of the following procedures: keeping the combustion zone sealed maintaining the combustion zone at a pressure lower than atmospheric pressure Owners or operators may gain approval from the Director for alternative means of controlling fugitive emissions Notes: 2-18 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: MONITORING AND INSPECTION OF BIFS (40 CFR 266.1030)) Owners or operators must monitor the flow rates and composition of hazardous waste, fuels, and feed stocks, in addition to the feed rates of ash, metals, and total chloride and chlorine. Owners or operators also must monitor for carbon monoxide and, if necessary, hydrocarbons. Owners or operators .must maintain carbon monoxide and hydrocarbon monitors (where applicable) in accordance with Appendix IX to 40 CFR Part 266. INTERIM STATUS STANDARDS: MONITORING AND INSPECTION OF BIFS (40 CFR 266.1030)) (continued) When BIFs and associated equipment contain hazardous waste, owners or operators must conduct daily visual inspections of them for leaks, spills, fugitive emissions, and signs of tampering. Owners or operators must test the automatic waste feed cutoff system at least once every 7 days when burning hazardous wastes (owners or operators may be allowed to test the system as infrequently as once every 30 days, with approval from the Director). Notes: 2-19 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES INTERIM STATUS STANDARDS: RECORDKEEPING REQUIREMENTS FDR BITS (40 CFR 266.103(10) Until closure of the BIF, owners or operators must keep all information required under interim status requirements in the operating record for the facility. Owners or operators must record all monitoring and inspection data and the records must be placed in the operating log for the facility. Notes: INTERIM STATUS STANDARDS: CLOSURE OF BIFS AT INTERIM STATUS FACILITIES (40 CFR 266.1030)) At closure, owners or operators of BIFs must remove all hazardous wastes from the BIF. These facilities must meet the general closure requirements set forth in 40 CFR 265.111 through 265.115. Notes: 2-20 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES PERMIT STANDARDS: PERMIT REQUIREMENTS FOR BIFS (40 CFR 266.102(a)(2)) :40 CFR Part 264 Subpart A B C - D E F G H BB - General General facility standards Preparedness and prevention Contingency plan and emergency procedures Manifest system, recordkeeping, and reporting Corrective action Closure and postclosure Financial requirements Equipment leaks Section(s) 264.4 264.11-264.18 264.31-264.37 264.51-264.56 264.71-264.77 264.90,264.101 264.111-264.115 264.141-264.143, 264.147-264.151 All except 264.1050(a) 2-21 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES PERMIT STANDARDS: EMISSIONS STANDARDS FOR OWNERS OR OPERATORS OF PERMITTED BIFS Owners or operators of facilities seeking a permit for a BIF must demonstrate compliance with the following standards designed to control emissions (40 CFR destruction and removal efficiency for principal organic hazardous constituents carbon monoxide, and, if necessary, hydrocarbons dioxins and furans, if necessary standards for paniculate matter PERMIT STANDARDS: EMISSIONS STANDARDS FOR OWNERS OR OPERATORS OF PERMITTED BIFS (continued) toxic metals, including - antimony arsenic barium beryllium cadmium chromium - lead mercury silver thallium hydrogen chloride and chlorine gas Notes: 2-22 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES PERMIT STANDARDS: RELATIONSHIP OF PERMITTING AND INTERIM STATUS STANDARDS FOR FACILITIES WITH BIFS (continued) Many of the requirements for BIFs are similar between permitted and interim status facilities, including: control of fugitive emissions (40 CFR 266.102(e)(7)) monitoring and inspection requirements (40 CFR 266.102(e)(8)) PERMIT STANDARDS: RELATIONSHIP OF PERMITTING AND INTERIM STATUS STANDARDS FOR FACILITIES WITH BIFS (continued) recordkeeping requirements (40 CFR 266.102(e)(10ť ' closure requirements (40 CFR 266.102(e)(l 1)) Notes: 2-23 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES PERMIT STANDARDS: PERMITTING PROCESS FOR BIFS Owners or operators must submit all required information, as set forth in 40 CFR 270.22, which requires the submission of a trial burn plan and the conduct of a trial burn to demonstrate compliance with emissions standards. Owners or operators must submit a trial burn plan. PERMIT STANDARDS: PERMITTING PROCESS FOR BIFS (continued) Under 40 CFR 270.66, the permitting process for a BIF consists of four steps: pretrial burn period trial burn period posttrial burn period final permit period Notes: 2-24 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: REQUIREMENTS FOR CONTROL OF CARBON MONOXIDE EMISSIONS FROM BITS (40 CFR 266.104(b)) In general, the concentration of carbon monoxide in the stack gas of a BEF cannot exceed 100 parts per million vapor (ppmv) on an hourly rolling average basis, corrected to 7 percent oxygen on a dry-gas basis. Facilities in the permit process must demonstrate compliance with the CO standard during the trial burn; BIFs operating under interim status must demonstrate such compliance during the compliance test. EMISSION STANDARDS: REQUIREMENTS FOR CONTROL OF CARBON MONOXIDE EMISSIONS FROM BIFS (40 CFR 266.104(b)) (continued) Carbon monoxide and oxygen must be continuously monitored in accordance with procedures for continuous emissions monitors (CEM) in Appendix IX to 40 CFR Part 266. Notes: 2-25 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: ALTERNATIVE CARBON MONOXIDE EMISSIONS STANDARD (40 CFR 266.104(c)> The concentration of CO in the stack gas of a BIF may exceed 100 ppmv if the concentration of hydrocarbons in the stack gas does not exceed 20 ppmv. The hydrocarbon limit must be established on an hourly rolling average basis, reported as propane, and continuously corrected to 7 percent oxygen on a dry gas basis. EMISSION STANDARDS: ALTERNATIVE CARBON MONOXIDE EMISSIONS STANDARD (40 CFR 266.104(c)) (continued) Facilities in the permit process must demonstrate compliance with the HC standard during the trial burn; BIFs operating under interim status must demonstrate such compliance during the compliance test. Hydrocarbons must be continuously monitored in accordance with procedures for CEMs set forth in Appendix IX to 40 CFR Part 266. Notes: 2-26 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: ALTERNATIVE HYDROCARBON EMISSIONS STANDARDS FOR INDUSTRIAL FURNACES (40 CFR 266.104 (0) Owners or operators of industrial furnaces (except certain cement kilns equipped with bypass ducts) that cannot meet the 20 ppmv hydrocarbon limit because of organic matter in normal raw materials may obtain approval from the Director for an alternative limit. EMISSION STANDARDS: ALTERNATIVE HYDROCARBON EMISSIONS STANDARDS FDR INDUSTRIAL FURNACES (40 CFR 266.104 (0) (continued) To obtain approval, owners or operators must conduct testing to establish baseline carbon monoxide and hydrocarbon levels when raw materials and fuels (no hazardous waste) are being burned. Owners or operators also must demonstrate that levels of hydrocarbons and carbon monoxide are not higher than the baseline levels when hazardous waste is being burned. EMISSION STANDARDS: ALTERNATIVE HYDROCARBON EMISSIONS STANDARDS FOR INDUSTRIAL FURNACES (40 CFR 266.104 (0) (continued) Cement kilns with bypass ducts are not eligible for this alternative limit if: hazardous waste is fired only in the kiln and is not fired at any location downstream from the kiln exit the bypass duct diverts at least 10 percent of kiln off-gas into the duct Notes: 2-27 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: CONTROL OF EMISSIONS OF PARTICULATE MATTER FROM BITS (40 CFR 266.105) A BBF may not emit paniculate matter (PM) in excess of 180 milligrams per dry standard cubic foot (0.08 grains per dry standard cubic foot, [gr/dscf]) after correction to a stack gas concentration of 7 percent oxygen. Owners or operators must use the procedures set forth in 40 CFR Part 60, Appendix A, Methods 1 through 5, to make this determination. Owners or operators of BIFs that meet the low-risk waste exemption in 40 CFR 266.109(b) are exempt from the PM standard. Notes: 2-28 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: CONTROL OF METAL EMISSIONS FROM BIFS (40 CFR 266.106) Owners or operators must comply with metals emissions standards if metals are detectable (using methods and detection limits established in SW-846) in the hazardous waste being burned. One or more of four approaches can be used to demonstrate compliance: Tier I: Uses conservative estimates concerning the composition of waste feed EMISSION STANDARDS: CONTROL OF METAL EMISSIONS FROM BIFS (40 CFR 266.106) (continued) Tier II: Uses emission limits to back calculate feed rate limits based on engineering assessments regarding the partitioning and removal in APCSs of hazardous waste constituents to flue gas and ash residues Tier III: Uses a risk assessment based on the results of emissions monitoring and dispersion modeling Notes: 2-29 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: CONTROL OF METAL EMISSIONS FROM BIFS (40 CFR 266.106) (continued) Adjusted Tier I: Uses a combination of information about the waste feed and dispersion modelling Owners or operators may use a combination of the tiers described above to set feed rate limits for metals and chlorine and chloride. Notes: 2-30 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: TIER I EMISSIONS CONTROLS FOR METALS (40 CFR 266.106(b)) Owners or operators must establish feed rate limits that meet requirements set forth in Appendix I to 40 CFR Part 266 and that are based on terrain and land use in the vicinity of the facility and the terrain-adjusted effective stack height. Feed rates for noncarcinogenic metals and lead must be based on instantaneous measurements of flow rate, hourly rolling averages, or, for lead, an averaging period from 2 to 24 hours. Feed rate limits are presented in Appendix I of 40 CFR Part 266. EMISSION STANDARDS: TIER I EMISSIONS CONTROLS FOR METALS (40 CFR 266.106(b)) (continued) Feed rates for carcinogenic metals must be based on measurements of flow rate on an instantaneous basis, or an hourly rolling average or an averaging period of from 2 to 24 hours. Feed rate limits are presented in Appendix I of 40 CFR Part 266. The total combined feed rates of carcinogenic metals is also regulated. The actual feed rate is divided by the feed rate limit for each metal The sum of these ratios cannot exceed 1.0. EMISSION STANDARDS: TIER I EMISSIONS CONTROLS FOR METALS (40 CFR 266.106(b)) (continued) Certain facilities are not eligible to use the Tier I approach and must use Tier III (see 40 CFR 266.106(b)(7)). Notes: 2-31 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: TIER II EMISSIONS CONTROLS FOR METALS (40 CFR 266.106(c)) Owners or operators must establish feed rate limits back-calculated from emission limits set forth in Appendix I to 40 CFR Part 266 using partitioning factors and removal efficiencies for APCSs. The emission limits are based on terrain and land use in the vicinity of the facility and the terrain-adjusted effective stack height. Feed rates must be measured on the same bases (for example, instantaneous limits or hourly rolling averages) as those for Tier I. EMISSION STANDARDS: TIER II EMISSIONS CONTROLS FOR METALS (40 CFR 266.106(c)) (continued) As in Tier I, the sum of the ratios for feed rates of carcinogenic metals cannot exceed 1.0. Certain facilities are not eligible to use the Tier II approach and must use Tier III (see 40 CFR 266.106(b)(7)). Notes: 2-32 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: TIER III EMISSIONS CONTROLS FOR METALS (40 CFR 266.106(d)) Owners or operators establishing feed rate limits under Tier III must: conduct emissions testing perform dispersion modeling, based on the results of emissions testing EMISSION STANDARDS: TIER III EMISSIONS CONTROLS FOR METALS (40 CFR 266.106(d)) (continued) The acceptable ambient levels for ground-level concentrations predicted by dispersion modeling are reference air concentrations (RAC) for noncarcinogenic metals and risk-specific doses (RSD) for carcinogenic metals; RACs and RSDs are found in Appendices IV and V to 40 CFR Pan 266, respectively. As in Tier I, the sum of the ratios for feed rates of all carcinogens must not exceed 1.0. Notes: 2-33 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: ADJUSTED TIER I EMISSIONS CONTROLS FOR METALS (40 CFR 266.106(e)) Feed rates for metals may be adjusted to account for the results of site-specific dispersion modeling. Owners or operators of BIFs may back-calculate the acceptable feed rate limits, based on RACs and RSDs listed in Appendices IV and V to 40 CFR Part 266, respectively. EMISSION STANDARDS: ADJUSTED TIER I EMISSIONS CONTROLS FOR METALS (40 CFR 266.106(e)) (continued) The feed rate limit for carcinogenic metals must be based on an instantaneous basis or an hourly rolling average or an averaging period of from 2 to 24 hours. As in Tier I, the sum of the ratios for feed rates of all carcinogenic metals cannot exceed 1.0. Notes: 2-34 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EMISSION STANDARDS: STANDARDS FOR THE CONTROL OF HYDROGEN CHLORIDE AND CHLORINE GAS EMISSIONS (40 CFR 266.107) To control hydrogen chloride and chlorine gas, owners or operators must use one of four approaches, similar to those allowed for controlling emissions of metals. Tier I feed rate screening limits specified in Appendix II to 40 CFR Part 266 Tier II feed rate screening limits specified in Appendix III to 40 CFR Part 266 EMISSION STANDARDS: STANDARDS FOR THE CONTROL OF HYDROGEN CHLORIDE AND CHLORINE GAS EMISSIONS (40 CFR 266.107) (continued) Tier HI feed rate screening limits not to exceed the RACs specified in Appendix IV to 40 CFR Part 266 Adjusted Tier I feed rate screening limits used to account for the results of site-specific dispersion modeling Notes: 2-35 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES EXEMPTIONS FROM CERTAIN STANDARDS IN THE BIF RULE Owners or operators may obtain exemptions from certain portions of the BIF rule; including: Small quantity burner (SQB) exemption (40 CFR 266.108) Low-risk waste exemption (40 CFR 266.109) Waiver of destruction and removal efficiency (DRE) trial burn requirements for boilers (40 CFR 266.110) Notes: 2-36 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES DIRECT TRANSFER REQUIREMENTS: REQUIREMENTS FOR DIRECT TRANSFER OPERATIONS (40 CFR 266.111) Owners or operators of BIFs must comply with several requirements for direct transfer equipment similar to those for tanks and containers. Direct transfer operations must: be conducted in equipment that is closed, except when waste is being added or removed not be conducted in a manner that will cause a rupture or a leak DIRECT TRANSFER REQUIREMENTS: REQUIREMENTS FOR DIRECT TRANSFER OPERATIONS (40 CFR 266.111) (continued) not be performed in a manner that will generate extreme heat; pressure; fire; explosion; violent reactions or uncontrolled toxic mists, fumes, dusts, or gases not affect the structural integrity of containers Notes: 2-37 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES DIRECT TRANSFER REQUIREMENTS: REQUIREMENTS FOR DIRECT TRANSFER OPERATIONS (continued) Owners or operators must comply with certain requirements for containers for direct transfer vehicles: containment requirements of 40 CFR 264.175 certain use and management of container requirements of 40 CFR Part 265, Subpart I DIRECT TRANSFER REQUIREMENTS: REQUIREMENTS FOR DIRECT TRANSFER OPERATIONS (continued) certain requirements in the National Fire Protection Association's "Flammable and Combustible Liquids Code," with which the owner or operator may comply in lieu of compliance with the requirements in 40 CFR 265.176 Direct transfer equipment must have secondary containment: for new equipment, before it is put into service for existing equipment, by August 21, 1993 Notes: 2-38 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES DIRECT TRANSFER REQUIREMENTS: REQUIREMENTS FOR DIRECT TRANSFER OPERATIONS (continued) For existing equipment that does not have secondary containment, an equipment integrity assessment should have been conducted by August 21, 1992. Owners or operators must visually inspect operations that involve the transfer of hazardous waste from the transport vehicle to the BIF at least once each operating hour; equipment to be inspected is: DIRECT TRANSFER REQUIREMENTS: REQUIREMENTS FOR DIRECT TRANSFER OPERATIONS (continued) overfill/spill control equipment aboveground portions of direct transfer equipment monitoring (for example, temperature gauges) and leak detection equipment Owners or operators must maintain records of inspections in the operating record for the facility for at least three years from the date of the inspection. Notes: 2-39 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES REGULATION OF RESIDUES FROM BIFS (40 CFR 266.112) To qualify for the "BevUl exclusion" set forth in 40 CFR 261.4(b)(4), (7), and (8), residues must be those from a BIF that is burning the following materials: for a boiler, at least 50 percent coal, determined on a basis of a total heat input or mass input for an ore or mineral furnace, at least SO percent by weight normal, nonhazardous raw materials REGULATION OF RESIDUES FROM BIFS (40 CFR 266.112) (continued) for a cement kiln, at least 50 percent by weight normal cement- production raw materials If residues from a BIF are to be excluded, the owner or operator, in addition to meeting the feed rate requirements stated above, must complete one of the two following procedures: conduct a statistical comparison of normal residue with waste- derived residue and demonstrate that the concentrations of Appendix VIII (40 CFR Part 261) constituents in waste derived residue are not significantly higher than those in the normal residue. Notes: 2^0 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES REGULATION OF RESIDUES FROM BIFS (40 CFR 266.112) (continued) conduct a comparison of levels of hazardous constituents in the waste-derived residue with health-based levels Owners or operators comparing the concentrations of hazardous constituents in normal residue with that of waste-derived residue must analyze at least 10 samples of the normal residue that represent at least 10 days of operation. REGULATION OF RESIDUES FROM BIFS (40 CFR 266.112) (continued) Owners or operators comparing the concentrations of toxic constituents in the waste-derived residue with health-based levels must: for nonmetai constituents, determine the concentrations of the constituents of concern and show that they do not exceed their health-based limits set forth in Appendix VII of 40 CFR Part 266 or the detection limits in SW 846, whichever is higher. Notes: 2-41 ------- REVIEW OF REGULATIONS AND TECHNOLOGIES REGULATION OF RESIDUES FROM BIFS (40 CFR 266.112) (continued) for metal constituents, compare the concentration of metals in an extract obtained through the use of the toxicity characteristic leaching procedure with the levels set forth in Appendix VII to 40 CFR Part 266 Notes: 2^2 ------- TECHNOLOGY SLIDES Types of technologies that will be discussed Water tube boiler Water tube boiler being fed hazardous waste and producing steam and generating combustion .gases Fire tube boiler Firetube boiler producing steam 2-43 ------- TECHNOLOGY SLIDES (continued) Schematic of a cement kiln Schematic of a cement kiln with a suspension preheater Precalciner for a cement kiln Cement kiln with a preheater arrangement Graphic of a venturi scrubber 2-44 ------- TECHNOLOGY SLIDES (continued) Graphic of a fabric filter Graphic of a baghouse showing the flow of combustion gases through the bags Graphic of an electrostatic precipitator 2-45 ------- 3.0 CASE STUDY #1 - XYZ CHEMICAL COMPANY Participant materials: participant manual BIF rule and its updates Certification of Compliance for XYZ Chemical Company (handout during Section 3.1) BIF inspection checklist (handout during Section 3.1) Inspection plan (handout during Section 3.1) flow rates and waste analysis information for XYZ Chemical Company (handout during Section 3.8) Sample calculation of feed rates for XYZ Chemical Company (handout during Section 3.8) Answers to feed rate calculations for XYZ Chemical Company (handout during Section 3.8) Description of Case Study #1 - XYZ Chemical Company Case Study #1 involves XYZ Chemical Company, a chemical manufacturing facility that has a firetube boiler that burns hazardous waste generated on site. Throughout the case study, you (participant) will read the section and then, in your workgroup, complete the various exercises. Purpose of Case Study #1: The purpose of Case Study #1 is to familiarize you with the operations, instruments, and equipment typically associated with a boiler, with the general procedures for BIF inspections, and with identifying potential problems that may occur at a facility operating a boiler. 3-1 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY 3.1 PREEVSPECTION ACTIVITIES Purposes of Preinspection Activities To identify the documents that should be reviewed during preinspection and inspection activities. To identify the pertinent sections of the BIF inspection checklist. To prepare appropriate questions for the on-site inspection. To prepare an inspection plan for the facility. Notes: 3-2 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Documents an Inspector Might Review Before an Inspection BIF inspection checklist BIF regulations Certification of precompliance (COP) Information in the notification compliance test Certification of compliance Permit applications and permits RCRA inspection reports and inspection reports prepared by Regional or state air offices Notes: 3-3 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Required Contents of a Certification of Compliance General information on the facility identification number of the facility name of the contact at the facility dates of compliance tests descriptions of BIFs Notes: Required Contents of a Certification of Compliance (continued) Compliance test information purpose of test summary of test results comparison of actual emissions with emissions established under the COP determination of operating limits, based on instantaneous limits, or based on an hourly rolling average or on a 2- to 24-hour rolling average Notes: 3-4 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Required Contents of a Certification of Compliance (continued) feed rate limits for metals, total chloride and chlorine, and ash Statement of Certification of Compliance Notes: 3-5 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY FACT SHEET FOR XYZ CHEMICAL COMPANY The facility produces acrylonitrile at a 500-acre site in Galveston, Texas. The facility's identification number: EPA TXD 000 000 000 XYZ operates a firetube boiler on site and burns acetonitrile (waste code U003) hydrogen cyanide (waste code P063) absorber off-gas (nonhazardous) The facility submitted a certification of precompliance on August 21, 1991 and a certification of compliance on August 20, 1992. The facility has a permit for storage of acetonitrile and hydrogen cyanide in two 10,000-gallon tanks; the contents of these tanks are sent to the boiler to be burned. Before waste is introduced into the boiler, the facility collects samples monthly from valves at the bottom of each 10,000-gallon tank. XYZ analyzes the acetonitrile and hydrogen cyanide for the BIF metals, total chlorine and chloride, and ash content. XYZ has a permit from the state of Texas for the storage of hazardous waste in tanks; the facility operates a boiler under interim status requirements. XYZ has been cited for violations of hazardous waste management regulations, including exceeding time limits established under the terms of its permit for the storage of hazardous waste in tanks (1989) and failure to maintain adequate training of personnel, as required under 40 CFR 265.16 (1989). 3-6 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY I Purpose of the BIF Inspection Checklist To aid the inspector in determining the BIF requirements that apply to the facility and in determining the information that should be collected during the BIF inspection. Notes: 3-7 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Content of the BIF Inspection Checklist Applicability of BIF standards User's guide Preinspection checklist Interim status facilities certification of precompliance certification of compliance Permitted facilities Direct transfer requirements Content of the BIF Inspection Checklist (continued) Management of residues (Bevill exclusion) Exemption for smelting, melting, and refining furnaces Exemption for small quantity burners Exemption for low-risk waste Alternative metals approach Appendix conversion factors Notes: 3-8 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Content of an Inspection Plan The inspection plan consists of an outline in the proper order of steps to be taken in inspecting a facility. The inspection plan should provide for the collection of: Information about the BIF and its ancillary equipment (for example, piping, valves, and gauges) Records of monitoring data and other general facility data (for example, flow rate, emissions, leak monitoring, and visual inspection data) Notes: 3-9 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Overview of BIF Operating Parameters for XYZ Chemical Company Boiler operates under Adjusted Tier I feed rate limits for metals and chlorides. The facility has established a maximum feed rate for ash. The facility also has established the following operating conditions: maximum concentration of carbon monoxide in the stack maximum flow rate of hazardous waste Notes: 3-10 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: In the space provided below, develop a list of elements that might be included in a BIF inspection plan for XYZ Chemical Company: INSPECTION PLAN FOR XYZ CHEMICAL COMPANY Conduct an Entrance Interview: Conduct a visual inspection of: Conduct a closing interview: Facility operating conditions: 3-11 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY 3.2 ENTRANCE INTERVIEW Purposes of the Entrance Interview To explain the purpose of the inspection To confirm information about the facility that was discovered during preinspection activities To familiarize the facility representatives with your inspection plan To request the data that you will need while you are conducting the inspection of the equipment Purposes of the Entrance Interview (continued) To search for additional data that may not have been covered in the COC additional waste streams not accounted for different operating conditions for the boiler To inform facility representatives of the level of assistance required for the inspection (for example, the environmental coordinator may be needed to host the inspection) Notes: 3-12 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Purpose of the Entrance Interview (continued) To ask facility representatives to provide a verbal overview (with schematics, .if available) of the facility's waste management and other operational practices Notes: 3-13 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY ENTRANCE INTERVIEW SCENARIO Having developed an inspection plan and completed your preinspection checklist, you establish a date for the inspection. On the morning of the inspection, you arrive unannounced at the facility and show your credentials. The guard, although curious about what you will be doing, is cooperative and calls for the facility's environmental coordinator. Next, you drive through the gate and to the facility's administration building. When you arrive there, you are greeted by the facility's environmental coordinator and its senior engineer. After you have fully explained the purpose of your visit, you then ask the facility representatives to provide you with an overview of the facility's manufacturing process and waste generating and waste management practices. The environmental coordinator begins by telling you that the facility manufactures acrylonitrile and that the manufacturing process produces two forms of by-products: hydrogen cyanide, and acetonitrile. The senior engineer next explains that the boiler burns hydrogen cyanide and acetonitrile for energy recovery and that both are hazardous wastes. Absorber off- gas (AOG) and natural gas also are burned in WOB 1 for energy recovery. The hazardous wastes are conveyed to WOB 1 through two distribution manifolds. At the manifolds, hydrogen cyanide and acetonitrile remain as products and are delivered to customers. They are branched off to WOB 1 to be burned for energy recovery if there is a surplus of either by-product. The acetonitrile is stored in a 10,000-gallon tank, and the hydrogen cyanide is stored in another 10,000-gallon tank. The flow from the two 10,000-gallon tanks then are sent to the boiler. The absorber off-gas is sent from the process directly to the boiler. After ignition in the burner, combustion gases travel to the firebox where boiler feed water is heated and converted into high- pressure steam. The steam eventually is used in the plant as a source of thermal energy. The environmental coordinator then explains the waste analysis procedures the facility employs as part of its BIF operations. He states that, before they are burned, wastes exiting each of the 10,000-gallon tanks are analyzed for total chlorine, the BIF metals, and ash content. The wastes are sampled monthly from valves located at the bottom of each 10,000-gallon tank. Once you have completed the entrance interview and obtained information concerning the facility's BIF operations, you inform the facility representatives of the details of your proposed inspection plan. You next present the facility representatives with a list of the information to be gathered while you and the facility representatives are conducting the inspection, including flow rates and monitoring data for specific dates. You then leave the administration building and go to the control room to begin the inspection. 3-14 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: In the space provided below, develop a list of questions to ask the facility representatives to help identify potential problems with the waste analysis procedures: 3-15 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY 3.3 CONTROL ROOM INSPECTION Purposes of the Control Room Inspection Familiarize participants with the types of monitors that might be found in the BIF control room Through a visual inspection of the control room, identify information that can be obtained there CONTROL ROOM INSPECTION SCENARIO The first stop in the visual inspection is the control room for the boiler. You first look at the instrumentation associated with the continuous emissions monitoring equipment operated by the facility. At first, you are overwhelmed by the complexity of the control room, but after examining it for a few minutes and asking several questions, you begin to gain an overall understanding of how XYZ monitors the flow rates of fuel and hazardous waste to the boilers, as well as boiler emissions. You see that information pertaining to CO and O2 emissions is displayed continuously on computerized controls. Control room operators record the average flow rates for each hour in operating logs (however, there are no computerized records or strip charts that document instantaneous measurements of flow rates). Satisfied that you now understand the way data are recorded, you ask to see records of the CO and O2 emissions data and the operating log (for flow rate data) from that morning. 3-16 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Types of Monitors Found in Control Rooms Carbon monoxide Oxygen Flow rates of feedstreams to the boiler Temperature Other monitors for compliance with other regulations, such as those under the Clean Air Act or state requirements Types of Data Recorders Found in Control Rooms (continued) Strip charts Computer Manual log Notes: 3-17 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: In the space provided below, develop a list of data to collect and questions to ask facility representatives to help determine if die facility is in compliance with the feed rate limits and emissions limits established under the BIF rule: Activity: Identify potential problems that may be discovered in die control room inspection: 3-18 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY 3.4 CEM CALIBRATION INSPECTION Purposes of the CEM Inspection To familiarize inspectors with proper procedures and frequency for the calibration of carbon monoxide and oxygen CEMs To identify the types of information that should be collected to discover potential problems Notes: CEM CALIBRATION SCENARIO After you have gathered enough information to determine the facility's compliance with certain aspects of the emissions and monitoring requirements, you ask the facility representatives to explain how they calibrate the facility's CEM. The senior engineer responds that the CEMs are calibrated three times a week, on Mondays, Wednesdays, and Fridays. A standard sample gas supplied by a vendor is introduced into the CO and O3 monitors, and the calibration drift and calibration error then are evaluated for both the upper and lower concentration limits for each CEM. The senior engineer adds that the results are recorded in the facility's operating log. Notes: 3-19 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: In the space provided below, develop a list of data to collect and questions to ask facility representatives to help determine whether XYZ is calibrating its CEMs in accordance with the BIF rule: Activity: Identify potential problems that may be discovered in the CEM calibration inspection: 3-20 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY 3.5 HAZARDOUS WASTE TANK STORAGE INSPECTION Purpose of the Hazardous Waste Storage Tank Inspection To ensure that inspectors pay attention to key non-BIF elements of RCRA during BIF inspections. Notes: HAZARDOUS WASTE STORAGE TANK INSPECTION SCENARIO Once you have completed your inspection of the control room, you next look at the area where XYZ stores hazardous wastes in tanks. The facility representatives first lead you the two 10,000-gallon tanks. The environmental coordinator tells you that the tanks have a permit from the state of Texas for the storage of hazardous waste. The first tank, the senior engineer explains, is used to store an acetonitrile stream from the acrylonitrile manufacturing process. He then informs you that the second tank is used to store hydrogen cyanide generated from the same process. He states that the wastes in the tanks are pumped on a semicontinuous basis into the boiler. As you look at the tanks, you see that they share a common secondary containment structure that consists of a four-foot-high concrete dike on a concrete foundation. The concrete appears to be in good condition. When you ask about the age of the containment, the environmental coordinator tells you, "We just had it installed last year; it has chemical-resistant waterstops around the joints. It's a state-of-the-art containment system." In accordance with your inspection plan, you then collect a sample from the valves at the bottom of each 10,000-gallon tank. Notes: 3-21 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: In the space provided below, develop a list of data to collect and questions to ask facility representatives to help determine if the facility is in compliance with the BIF rule in the operation of the tank storage area: Activity: Identify potential problems that may be discovered in the tank storage inspection: 3-22 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY 3.6 INSPECTION OF THE BOILER AND ANCILLARY EQUIPMENT Purposes of the Boiler and Ancillary Equipment Inspection To determine the presence of fugitive emissions, leaks, and miscellaneous equipment malfunctions To identify the applicable requirements of the BIF rule, as well as requirements of Subpart BB. Notes: 3-23 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY BOILER AND ANCILLARY EQUIPMENT INSPECTION SCENARIO After examining the tank storage area, you and the facility representatives begin to inspect the boiler. You explain to the environmental coordinator that you would like to inspect the sensor locations and the valves for the automatic waste feed cutoff systems and any ancillary equipment, such as piping and pumps, associated with the boiler. You also inform the facility representatives that, at the end of the inspection, you would like to inspect records related to waste feed cutoffs. The environmental coordinator responds by stating that the records are kept in the control room and offers to take you back there at the end of the inspection. You also ask the senior engineer to provide you with information concerning monitoring equipment for the boiler. He obliges and shows you the location of the carbon monoxide monitors and temperature monitors. He tells you that the carbon monoxide monitors are extractive, continuous emissions monitors and that a thermocouple is used to monitor the temperature. You then ask the senior engineer how the flow rates in the boiler are measured. He tells you that a gas turbine meter is used to measure the flow rate of natural gas into the boiler. He also tells you that the flow from each of the two 10,000-gallon tanks is measured using positive displacement meters. He notes that the flow rates are measured each hour and recorded in the facility's operating log. The senior engineer shows you the valve for the automatic waste feed cutoff system that is used to stop the flow of waste into the unit if a waste feed cutoff is necessary. He continues, informing you that the automatic waste feed cutoff system can be triggered by a number of conditions in which the value of an operating parameter exceeds the parameters tied to the automatic waste feed cutoff system. The operating limits specified in XYZ's certification of compliance include high flow rates of hazardous waste, high concentration of carbon monoxide, and low temperature in the combustion chamber. You tell the senior engineer that you would like to inspect flow rate data for the days on which the waste feed was cut off. Next, the environmental coordinator leads you through an inspection of the ancillary equipment for the boiler. You inspect a variety of piping, pumps, valves, flanges, and other equipment in the area near the boiler and do not see any obvious signs of releases from the equipment. Although there are no obvious signs of releases, the equipment bears no markings or other indications that the equipment contains hazardous waste. You ask the environmental coordinator if this equipment is inspected or monitored. He tells you that all equipment that contains hazardous waste is inspected weekly, but no records are kept of these inspections. 3-24 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: In the space provided below, develop a list of data to collect and questions to ask facility representatives to determine whether XYZ's boiler and ancillary equipment operation is in compliance with BIF regulations: Activity: Identify potential problems that may be discovered in the boiler and ancillary equipment inspection: 3-25 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY 3.7 INSPECTION OF THE AIR POLLUTION CONTROL EQUIPMENT AND RESIDUE MANAGEMENT Purposes of Air Pollution Control and Residue Management Inspection To determine whether air pollution control equipment is properly installed, operated, and maintained To determine whether residues are properly tested and managed by the facility INSPECTION OF AIR POLLUTION CONTROL EQUIPMENT AND RESIDUE MANAGEMENT SCENARIO After you have inspected the majority of the operations associated with the boilers, the environmental engineer asks you if you would like to see anything else. Because this is your first BIF inspection, you want to make sure you do not miss anything, so you review your inspection plan. About halfway through it, you notice a reference to the air pollution control equipment. The environmental engineer confirms your observation, made during preinspection activities, that there is no air pollution control equipment at the facility. You subsequently ask the environmental engineer to show you the procedures involved with the management of any residues from its operation. He informs you that the boiler generates a bottom ash that is removed during shutdowns and collected in 55-gallon drums. He continues, telling you that the toxicity characteristic leaching procedure (TCLP) is used to test the waste to determine whether it exhibits the toxicity characteristic. You recognize that this is a residue derived from burning a listed hazardous waste. The waste then is disposed of as the test results indicate is appropriate, either at an off-site hazardous waste landfill or at an off-site nonhazardous solid waste landfill. Notes: 3-26 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: ID the space provided below, develop a list of data to collect and questions to ask facility representatives to determine whether XYZ's procedures concerning air pollution equipment and management for residues are in compliance with BIF rules: Activity: Identify potential problems that may be discovered in this inspection scenario: 3-27 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY 3.8 RECORDS REVIEW Purposes of Records Review To perform calculations of feed rates using waste analysis and flow rate data. To identify potential violations of BIF regulations associated with the calculation of feed rates. To review general RCRA records related to the operation of BIFs. RECORDS REVIEW SCENARIO Satisfied that your review of the relevant hazardous waste management operations is complete, you inform the facility representatives that you would like to conduct a thorough examination of the facility's records for the dates indicated in your inspection plan. The environmental coordinator says that your request is not a problem. You return to the administration building with the two facility representatives. On your way there, you inform them that you would like to inspect the facility's waste analysis plan and associated sampling and analysis data; inspection logs; and other general facility information, such as personnel training records, leak detection and monitoring records, and contingency plans, as that information concerns BIF operations at the facility. Once you arrive at the administration building, you ask the environmental coordinator to explain the sampling and analysis that is performed at the facility. He explains to you that XYZ analyzes the wastes exiting the two 10,000-gallon tanks for total chlorine, the BIF metals, and ash content. He tells you that the analysis is performed monthly. When you ask the environmental coordinator what is done with the waste if it is deemed unacceptable for burning in the boiler, he tells you that such wastes are sent off site to be burned for energy recovery. Notes: 3-28 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: In the space provided below, complete calculations of feed rates of parameters assigned to your work group. Determine if there are potential problems in compliance with the feed rate limits established under the facility's COC: 3-29 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: Develop a list of data requirements and questions to help determine if potential problems, other than exceedances of feed rate limits, exist regarding records review. 3-30 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY 3.9 CLOSING INTERVIEW Purpose of the Closing Interview To develop a list of potential problems in compliance with BIF regulations detected during an inspection of a facility that has a BIF CLOSING INTERVIEW SCENARIO Once you have completed the records search, you conduct a closing interview with the facility representatives to discuss some preliminary findings of your inspection. You inform the facility representatives that you will be doing some work at your office to determine XYZ's compliance status with regard to applicable BIF regulations. At the conclusion of the closing interview, you thank the facility representatives for their time, and you leave the administration building. You check out with the security guard and begin your drive home. During your return drive to the office, you already are thinking about a number of issues associated with XYZ. Notes: 3-31 ------- CASE STUDY #1 - XYZ CHEMICAL COMPANY Activity: In the space provided below, summarize the major areas of potential problems in Case Study #1: 3-32 ------- 4.0 CASE STUDY #2 - ABC CEMENT COMPANY ^H Participant Materials: participant manual BIF rule and its updates Certification of Compliance for ABC Cement Company (handout during Section 4.1) BIF inspection checklist (handout during Section 4.1) Inspection plan (handout during Section 4.1) Waste analysis and flow rate information for ABC Cement Company (handout during Section 4.7) Sample calculation of feed rates for ABC Cement Company (handout for Section 4.7) Answers to feed rate calculations for ABC Cement Company (handout for Section 4.7) Description of Case Study #2 - ABC Cement Company: Case Study #2 involves ABC Cement Company, a cement manufacturing facility that accepts hazardous waste from off-site generators and burns it in a cement kiln. Throughout the case study, you will read sections of the participant manual and then complete various exercises. Purpose of Case Study #2: The purpose of Case Study #2 is to familiarize you with the instruments and equipment typically associated with a cement kiln, with the general procedures for BIF inspections, and with identifying potential problems that may occur at a cement kiln facility. 4-1 ------- CASE STUDY #2 - ABC CEMENT COMPANY 4.1 PRE3NSPECTION ACTIVITIES Purposes of Preinspection Activities To identify the documents that should be reviewed during the preinspection and inspection process. To identify the pertinent sections of the BIF inspection checklist. To prepare appropriate questions for the on-site inspection. To prepare an inspection plan for the facility. 4-2 ------- CASE STUDY #2 - ABC CEMENT COMPANY Documents an Inspector Might Review Before an Inspection BIF inspection checklist BIF regulations Certification of precompliance Information in the notification of compliance test Certification of compliance Permit applications and permits RCRA inspection reports and inspection reports prepared by Regional or state air offices Notes: 4-3 ------- CASE STUDY #2 - ABC CEMENT COMPANY Required Content of a Certification of Compliance General information on the facility identification number of the facility name of the contact at the facility dates of compliance tests descriptions of BIFs Required Content of a Certification of Compliance (continued) Compliance test information purpose of test summary of test results comparison of actual emissions with emissions established under the COP determination of operating limits, based on instantaneous limits or based on an hourly rolling average or on a 2- to 24-hour rolling average Required Content of a Certification of Compliance (continued) feed rate limits for metals and total chloride and chlorine Statement of Certification of Compliance Notes: ------- CASE STUDY #2 - ABC CEMENT COMPANY FACT SHEET FOR ABC CEMENT COMPANY The facility produces Portland cement in two cement kilns on a 200-acre facility in Akron, Ohio. The facility's identification number is EPA OHD 000 000 000 ABC burns hazardous waste as a fuel for its cement kiln, including a variety of spent solvents from off-site sources. Before accepting wastes from off site, ABC requires that generators produce "fingerprint analysis" for total chlorine and chloride, Btu content, and viscosity. ABC operates a cement kiln under interim status requirements; the facility accumulates hazardous wastes in containers for less than 90 days; ABC has a permit for an incinerator. The facility submitted a certification of precompliance on August 21, 1991 and a certification of compliance on August 19, 1992. On February 21, 1992, the facility submitted a request for a Class III permit modification for an alternative HC limit, and submitted a supplement to that request on August 4, 1992. ABC has been cited for violations of hazardous waste management regulations, including failure to maintain adequate financial assurance for liability requirements for nonsudden occurrences, in accordance with the requirements of 40 CFR 265.147 (1991), and failure to maintain an adequate contingency plan as required under 40 CFR 265.52 (1991). 4-5 ------- CASE STUDY #2 - ABC CEMENT COMPANY Purpose of the BIF Inspection Checklist To aid the inspector in determining applicable BIF requirements and in determining the information that should be collected during the BIF inspection. Notes: ------- CASE STUDY #2 - ABC CEMENT COMPANY Content of the BIF Inspection Checklist: Applicability of BIF standards User's guide Preinspection checklist Interim status facilities certification of precompliance certification of compliance Permitted facilities Direct transfer requirements Content of the BIF Inspection Checklist (continued) Management of residues (Bevill exclusion) Exemption for smelting, melting, and refining furnaces Exemption for small quantity burners Exemption for low-risk waste Alternative metals approach Appendix conversion factors Notes: 4-7 ------- CASE STUDY #2 - ABC CEMENT COMPANY Content of an Inspection Plan The inspection plan consists of an outline in the proper order of steps to be taken in inspecting a facility. The inspection plan should provide for the collection of: Information about the BIF and its ancillary equipment (for example, piping, valves, and gauges) Records of monitoring data and other general facility data (for example, flow rate data, emissions data, leak monitoring data, and visual inspection data) Notes: 4-8 ------- CASE STUDY #2 - ABC CEMENT COMPANY Overview of BIF operating parameters for ABC Cement Company The kiln operates under Adjusted Tier I feed rate limits for antimony, barium, mercury, silver, and thallium. The kiln operates under Tier III feed rate limits for arsenic, beryllium, cadmium, chromium, lead, and total chlorine and chloride. The facility also has established the following operating conditions: maximum combustion zone temperature 4-9 ------- CASE STUDY #2 - ABC CEMENT COMPANY Overview of BIF operating parameters for ABC Cement Company (continued) maximum concentration of carbon monoxide in the stack maximum flow rate of hazardous waste maximum flow rate of pumpable hazardous waste maximum production rate minimum electrical power to the electrostatic precipitator (ESP) Overview of BIF operating parameters for ABC Cement Company (continued) maximum flue gas temperature at inlet to ESP maximum flue gas flow rate Notes: 4-10 ------- CASE STUDY #2 - ABC CEMENT COMPANY Activity: In the space provided below, develop a list of elements that might be included in a BIF inspection plan for ABC Cement Company: INSPECTION PLAN FOR ABC CEMENT COMPANY Conduct an entrance interview: Conduct a visual inspection: Conduct a closing interview: Facility operating conditions: 4-11 ------- CASE STUDY #2 - ABC CEMENT COMPANY 4.2 ENTRANCE INTERVIEW Purposes of the Entrance Interview To explain the purpose of the inspection To confirm information about the facility that was discovered during preinspection activities To familiarize the facility representatives with your inspection plan To request the data that you will need while you are conducting the inspection of the equipment Purposes of the Entrance Interview (continued) To search for additional data that may not have been covered in the COC: additional waste streams not accounted for different operating conditions for the kiln To inform facility representatives of the level of assistance required for the inspection (for example, environmental coordinator(s) needed to host the inspection) Purposes of the Entrance Interview (continued) To ask the facility representatives to provide a verbal overview (with schematics, if available) of the facility's waste management and other operational practices. Notes: 4-12 ------- CASE STUDY #2 - ABC CEMENT COMPANY ENTRANCE INTERVIEW SCENARIO On the morning of the inspection, you drive to the facility. When you arrive there, you go to the facility's administration building and sign in. After you have waited in the lobby for a few minutes, the environmental coordinator and the manager of the facility arrive, greet you, and take you to a conference room. You explain your role and tell the facility representatives that you are conducting an evaluation of the facility's compliance with the BIF rule. You ask the facility manager to explain the processes employed at the facility. The environmental coordinator begins by telling you that ABC operates two rotary kilns to produce approximately 500,000 tons of cement clinker each year, using a wet-feed system. The facility mixes raw materials, such as sand, clay, limestone, and mill scale; crushes them; and places them in the kilns. The crushed raw materials are gravity-fed through a preheating system before they are fed into the high (cold) end of the kiln. The clinker generated from the process then is mixed with gypsum to produce Portland cement. The environmental coordinator continues, explaining that coal and liquid hazardous waste provide thermal energy that is needed to produce clinker from raw materials in the kiln. Pulverized coal is used to fire the preheater. .Pulverized coal also is used to bring the kiln to its operating combustion temperature at which time liquid hazardous wastes are introduced into the kiln. The liquid hazardous wastes are pumped directly from tanker trucks and rail-car tankers parked outside the kiln building. The environmental coordinator tells you that the kiln is used to burn spent solvents from painting operations. The environmental coordinator also tells you that the spent solvents either are (1) listed as waste codes F001, F002, F003, F004, or F005 or (2) exhibit the characteristics of ignitability (D001) or toxicity for cadmium P006) or lead (D008). The spent solvents, she explains, are used as a supplementary fuel for the kiln. The kiln first is heated to 1,850 °F, with pulverized coal as fuel; after the kiln has reached that temperature, the hazardous waste is introduced as a fuel. The environmental coordinator also explains the facility's waste analysis procedures. She explains that ABC requires generators to perform an analysis of the spent solvents for BIF metals and total chlorine and that ABC itself performs fingerprint analysis including analysis for total chlorine, Btu content, and viscosity to verify the generators' initial waste characterizations before the facility accepts wastes from off-site sources. She also notes that ABC samples and analyzes the pulverized coal and other raw materials for BIF metals and total chlorine. The results of analysis are not obtained for a month because the waste must be analyzed for BIF metals. The waste is fed to the kiln as soon as it can be fired in the kiln. 4-13 ------- CASE STUDY #2 - ABC CEMENT COMPANY 4 J CONTROL ROOM INSPECTION Purposes of the Control Room Inspection To familiarize participants with the types of monitors that might be found in the BIF control room Through a visual inspection of the control room, identify information that can be obtained there CONTROL ROOM INSPECTION SCENARIO After hearing the explanations offered by the facility representatives, you inform them that you would like to proceed according to your inspection plan. When you show the plan to the environmental coordinator and the facility manager, they agree that the inspection would be accomplished most easily in the manner you had planned. Feeling confident that you understand the facility's processes and waste management procedures, you ask to begin by looking at the control room for kiln #2. The facility representatives then take you to the kiln #2 control room. Having recently completed an inspection at XYZ Chemical Company, you now are considerably more familiar with the operation of a control room for a BIF. You request a printout of current operating conditions, if available; otherwise, you note down the operating conditions of each of the parameters regulated under the BIF rule. These include the hazardous waste flow rate, raw material flow rate (which may also be the production rate in this case), combustion temperature, electrical power being supplied to the ESP, flue gas flow rate to the ESP, flue gas temperature at the inlet to the ESP, and hydrocarbons, and oxygen concentrations in the stack gases. You note one of the burning zone temperature zone readings of 2,000°F. You also note the operating limits set by the facility personnel for each of the BIF-regulated parameters. The results of monitoring are displayed on computerized controls and are recorded as computer printouts. Notes: 4-14 ------- CASE STUDY #2 - ABC CEMENT COMPANY Activity: In the space provided below, develop a list of data to collect and questions to ask facility representatives to help determine whether all applicable parameters are being measured according to BIF regulations: Activity: Identify potential problems that may be discovered in the control room inspection: 4-15 ------- CASE STUDY #2 - ABC CEMENT COMPANY 4.4 DIRECT TRANSFER AREA INSPECTION Purpose of the Direct Transfer Area Inspection To ensure that the transfer equipment and the operations for transfer of hazardous wastes are in compliance with all applicable BIF regulations. Notes: DIRECT TRANSFER AREA SCENARIO You next ask the facility manager to lead you to the direct transfer area. He informs you that tanker trucks and rail cars containing solvents are emptied by vacuum hoses and that their contents are fed into the kiln by two centrifugal pumps. When you arrive at the direct transfer area, you notice that it is paved with concrete but that the area has no berms or other form of containment. You do not see any evidence of releases in the area, and the concrete under the area where the direct transfer occurs appears to be in good condition. You ask the facility manager if this area is inspected, and he in turn asks the environmental coordinator. The environmental coordinator responds that she believes the area is inspected once a week. Notes: 4-16 ------- CASE STUDY #2 - ABC CEMENT COMPANY Activity: In the space provided below, develop a list of questions to ask facility representatives to help determine whether ABC's procedures in the direct transfer area are in compliance with BIF regulations: Activity: Identify potential problems that may be discovered in the direct transfer inspection: 4-17 ------- CASE STUDY #2 - ABC CEMENT COMPANY 4.5 KILN AND ANCILLARY EQUIPMENT INSPECTION Purposes of the Kiln and Ancillary Equipment Inspection To determine the presence of fugitive emissions, leaks, and miscellaneous equipment malfunctions To identify the applicable requirements of the BIF rule, as well as requirements of Subpart BB. Notes: 4-18 ------- CASE STUDY #2 - ABC CEMENT COMPANY KILN AND ANCILLARY EQUIPMENT INSPECTION SCENARIO After looking at the direct transfer area, you ask to see kiln #2. In evaluating kiln #2, you have determined that you want to inspect equipment associated with the kiln, including the valve on the hazardous waste feed line linked to the automatic waste feed cutoff system, and other ancillary equipment, such as piping and pumps. At your request, the environmental coordinator shows you the ancillary equipment associated with the kiln, starting with sensors for hazardous waste flow rate linked to the automatic waste feed cutoff system. The environmental coordinator shows you two valves that are used to control the flow of liquid hazardous wastes into the kiln and tells you that the valves will close automatically when certain parameters are found to be outside the range of those listed in the certification of compliance for the kiln. You then ask her how the automatic waste feed cutoff system works. She replies that process control equipment at the facility will send a signal that stops the pumps when the parameters linked to the system are outside the ranges established in the certification of compliance. You ask her what parameters will trigger a waste feed cutoff, and she informs you that the system is linked to a maximum combustion temperature, maximum flow rates of total hazardous waste and pumpable hazardous waste, minimum electrical power supply to the ESP, maximum flow rate of flue gas to the ESP, maximum flue gas temperature at the inlet to the ESP, high concentrations of hydrocarbons in flue gas emissions, and maximum production rate for the kiln. You tell the environmental coordinator that, at the end of the inspection, you wish to see information that documents any waste feed cutoffs. You then begin to look at the kiln and its ancillary equipment. You do not see any obvious signs of leaks from the kiln or its equipment, although you do see two small, circular holes, each approximately one foot wide, at the bottom of the kiln. You ask the environmental coordinator if the equipment and the kiln are inspected or monitored. She replies that the kiln and its ancillary equipment are inspected daily and monitored monthly for leaks. Notes: 4-19 ------- CASE STUDY #2 - ABC CEMENT COMPANY Activity: In the space provided below, develop a list of data to collect and questions to ask facility representatives to help determine whether ABC is meeting BIF requirements for inspection, monitoring, and testing of the kiln and its ancillary equipment: Activity: Identify potential problems that may be discovered in the kiln and ancillary equipment inspection: 4-20 ------- CASE STUDY #2 - ABC CEMENT COMPANY 4.6 AIR POLLUTION CONTROL EQUIPMENT AND RESIDUE MANAGEMENT SECTION Purposes of the Air Pollution Control and Residue Management Inspection To determine whether appropriate air pollution control equipment is properly installed, operated, and maintained To determine whether any residues are properly analyzed and managed by the facility AIR POLLUTION CONTROL AND RESIDUE MANAGEMENT INSPECTION SCENARIO The environmental coordinator then tells you about the air pollution control equipment for the kiln and describes the manner in which the facility manages residues generated from its operation. She states that an electrostatic precipitator associated with the kiln is used to collect kiln fly ash. She explains that the fly ash is disposed of in an on-site landfill. You remember that you learned during your inspection of the control room that ABC monitors the inlet temperature to the ESP, and you ask if any other monitoring is conducted. The environmental coordinator correctly lists all required monitoring performed for the ESP. When you ask the environmental coordinator if the fly ash is sampled and analyzed, the environmental coordinator replies that she does not think that the facility conducts any sampling and analysis of the fly ash. She continues, stating, "It is excluded from regulation. We dispose of it in our on-site landfill, which has extensive controls, under the terms of a solid waste disposal permit from the state water commission." Notes: 4-21 ------- CASE STUDY #2 - ABC CEMENT COMPANY Activity: In the space provided below, develop a list of data to collect and questions to ask facility representatives to help determine whether ABC's procedures concerning air pollution equipment and management of residues are in compliance with BIF regulations: Activity: Identify potential problems that may be discovered in this scenario: 4-22 ------- CASE STUDY #2 - ABC CEMENT COMPANY 4.7 RECORDS REVIEW Purposes of Records Review To perform calculations of feed rates using facility records of waste analyses and flow rate measurements. To identify potential violations of BIF regulations associated with the calculation of feed rate. To identify other violations associated with RCRA records requirements. Notes: 4-23 ------- CASE STUDY #2 - ABC CEMENT COMPANY RECORDS REVDZW SCENARIO After you have completed the visual site inspection of the facility, you ask the environmental coordinator to explain ABC's sampling and analysis procedures. She tells you that ABC requires generators that ship wastes to the facility to provide a complete analysis of those wastes, including analysis for the BIF metals and total chlorine for the first shipment that each generator sends, and that ABC requires that such analysis be repeated annually. After such initial or annual waste characterizations, ABC establishes acceptance criteria in the form of ranges of values for certain parameters. The environmental coordinator informs you that all waste shipments are analyzed by means of a fingerprint analysis that measures the parameters of concern, including viscosity, total chlorine, and Btu content. If the results of fingerprint analysis are outside the ranges established by ABC, the waste will not be accepted unless ABC or the generator can determine that the waste in question will not cause ABC to exceed its feed rate limits for total chlorine. The environmental coordinator also states that the raw feed to the kiln and the pulverized coal used as fuel are sampled daily and composited weekly for analysis. The composite samples then are analyzed for the BIF metals and total chlorine. You inform the facility representatives that you would like to review the waste analysis plan and sampling and analysis data for the dates mentioned during the entrance interview, along with the other facility records requested during the entrance interview. The environmental coordinator tells you that all such information is readily available in the administration building. As you walk to the administration building, you examine your agenda to refresh your memory about the information you wish to see. After doing so, you inform the environmental coordinator that you would like to see information in the facility's operating record concerning flow rates for raw materials, fuels, and hazardous wastes; results of monitoring for hydrocarbons and oxygen; and results of temperature monitoring. You ask to see the calibration data for monitors and the leak detection and repair information for the dates mentioned in the entrance interview. You also ask to see the inspection logs for the kiln and its associated equipment. Once inside the building, the environmental coordinator points to two large stacks of paper that have been removed from the facility's files and indicates that all the information you are requesting should be in those documents. Notes: 4-24 ------- CASE STUDY #2 ABC CEMENT COMPANY Activity: In the space provided below, complete calculations of feed rates of parameters assigned to your work group. Determine if there are potential problem in compliance with the feed rate limits established under the facility's COG: 4-25 ------- CASE STUDY #2 - ABC CEMENT COMPANY Activity: Develop a list of data requirements and questions to help determine if there are potential problems, other than exceedances of feed rate limits. 4-26 ------- CASE STUDY #2 - ABC CEMENT COMPANY 4.8 CLOSING INTERVIEW Purpose of the Closing Interview To develop a list of potential problems with compliance with BIF regulations detected during an inspection of a facility with a kiln CLOSING INTERVIEW SCENARIO Once you have completed the records search, you conduct a closing interview with the facility representatives to discuss some preliminary findings of your inspection. You inform the facility representatives that you will be doing some work at your office to determine ABC's compliance status with regard to applicable BIF regulations. At the conclusion of the closing interview, you thank the facility representatives for their time, and you leave the administration building. You check out with the security guard, and begin your drive home. During your return drive to the office, you already are thinking about a number of issues associated with ABC. Notes: 4-27 ------- CASE STUDY #2 - ABC CEMENT COMPANY Activity: In the space provided below, summarize the major areas of potential problems for Case Study 12: 4-28 ------- |