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:
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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:
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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:
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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)
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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:
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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.
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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:
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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:
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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:
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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:
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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:
4-24
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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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