4EPA
Hazardous Waste
Boilers and  Industrial
Furnaces (BIF) Inspection

Workshop
1993

Participant's Manual
Sponsored by:
  RCRA Enforcement Division
  Dffice of Waste Programs Enforcement

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                          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

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                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.

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           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

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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

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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

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 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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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:
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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

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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

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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

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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

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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:
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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

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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

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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

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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

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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

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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

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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

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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

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                           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

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                    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

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                            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

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      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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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        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

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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

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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

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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:

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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

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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:

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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:
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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

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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

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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

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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

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