UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APR I 2 I98C
MEMORANDUM
SUBJECT: Hazardous Waste
Distribution
FROM: Scott Parrish, Chiej
Guidance and EvaluaT^pn^-Branch
Office of Waste Programs Enforcement
TO: RCRA Branch Chiefs
Regions I-X
OFFICE OF
SOLID WASTC AND EMERGENCY RESPONSE
Inspection Manual
The purpose of this memo is to explain the rationale behind
the number of copies and the distribution of the Hazardous Waste
Incinerator Inspection (HWI) Manual that will be mailed to RCRA
state and regional inspectors.
Unlike past guidance documents developed by this office, the
HWI Manual concerns a technology currently concentrated in specific
geographical areas. Some Regions have a large number of hazardous
waste incinerators, while others have very few. Due to the
Regional differences in the demand for this guidance, combined with
cost-related printing limitations, EPA headquarters is distributing
the HWI Manual in proportion to the number of incinerators found
in each Region. To facilitate this distribution process, we have
mailed the manuals to the first names that appear on our inspector
mailing list, realizing that these inspectors are not necessarily
the ones performing the incinerator inspections, nor the ones'that
will attend the training courses scheduled throughout the summer.
Consequently, we are asking, via this memo, that the recipients of
the manuals contact you to determine who will be attending the
training course. There will be a limited number of manuals in
reserve at Headquarters, available upon request.
We appreciate your cooperation in implementing the allocation
of the manuals to the appropriate staff members in your offices.
If you have any questions, please pall Kate Anderson at FTS-475-
9313 of my staff.
cc: State and Regional Hazardous Waste Inspectors
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C 204GO
APR I 2 1989
urncL 01
SOLID WASTE AND EMEHGENCY BESPONSF
MEMORANDUM
SUBJECT: Hazardous Waste Incinerator Inspection Manual
FROM:
Adting Asistant Administrator
TO: Waste Management Division Directors
Environmental Services Division Directors
Regions I-X
Attached is the final Hazardous Waste Incinerator Inspection
Manual. The manual was written to guide EPA and State RCRA
inspectors in inspecting hazardous waste incinerators. This
manual is also intended to be used as the training manual for a
nationwide training course for inspectors to be held from May to
August, 1989. Its use is exclusively for RCRA compliance
personnel employed by or representing the U.S. Environmental
Protection Agency or comparable state regulatory agencies. In
addition, this document is not intended for public use and is
withholdable under the Freedom of Information Act. 5 U.S.C.
Section 552, Exemption (b)(7)(E).
The development of the Hazardous Waste Incinerator
Inspection Manual was assisted by representatives from 12 States
and 9 Regions, the Office of Enforcement and Compliance
Monitoring, the Office of General Counsel, and the Office of
Solid Waste. The HWI Inspection Manual will:
o provide inspectors with information on the current
regulations and the latest regulatory developments;
o serve as a resource for general overview of different
types of incinerators, their functions, designs, and
operation problems;
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o guide inspectors, step-by-step, using checklists to
prepare for upcoming inspections and actual on-site
inspections, as well as provide information on post-
inspection report preparations;
o instruct inspectors on the proper ways to interpret
monitoring eguipment; to perform various calculations
needed to determine compliance; and to identify
potential violations.
If you have any questions on the Hazardous Waste Incinerator
Inspection Manual or the upcoming training course, please call
Emily Chow (FTS-475-9329) or Kate Anderson (FTS-475-9313), RCRA
Enforcement Division.
Attachment
cc: Hazardous Waste Branch Chiefs, Regions I-X
RCRA Enforcement Section Chiefs, Regions I-X
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OSWER Directive No. 9938.6
HAZARDOUS WASTE INCINERATOR
INSPECTION MANUAL
APRIL 1989
FINAL
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WASTE PROGRAMS ENFORCEMENT
401 M STREET, SW
WASHINGTON, DC 20460
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OSWER Directive No. 9938.6
EXCLUSIVE USE OF THIS DOCUMENT
The policy and procedures set forth herein, and internal inspection
procedures adopted pursuant hereto, are intended solely for the
guidance of RCRA compliance personnel employed by or representing
the U.S. Environmental Protection Agency or comparable state
regulatory agency. They are not intended to nor do they constitute
rule-making by the Agency, and may not be relied upon to create a
right or benefit, substantive or procedural, enforceable at law or
in equity, by any person. The Agency may take any action at
variance with the policies or procedures contained in this
memorandum, or which are not in compliance with internal office
procedures that may be adopted pursuant to these materials.
This document is not for public use and is withholdable under the
Freedom of Information Act, 5 U.S.C. Section 552, Exemption
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OSWER Dlr. No. 9938.6
CONTENTS
List of Figures 1v
List of Tables vl
Abbreviations v11
I. Introduction 1-1
II. Background to Incineration II-l
A. Incinerators 11-2
B. Waste Feed Systems 11-23
C. Air Pollution Control Devices 11-26
0. Process and Emissions Monitoring
Instrumentation 11-57
III. Regulations and Permitting III-l
A. Introduction III-2
B. Regulatory Overview III-3
C. Permitting Overview III-8
D. Typical Permit-Limited Parameters III-9
IV. Inspection of Incinerators IV-i
A. Introduction IV-2
B. Preparing for Incinerator Inspection IV-4
C. The In-Depth Inspection IV-8
0. The Walk-Through Inspection IV-42
E. The Inspection Report IV-48
V. Identifying and Documenting Potential Violations V-l
A. Identifying Potential Violations V-2
B. Potential Violations of Numerical Limits V-3
C. Other Types of Potential Violations V-5
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OSWER Dlr. No. 9938.6
CONTENTS (Concluded)
VI. Follow-Up and Special Issues VI-1
A. Follow-Up to the Inspection VI-2
B. Special Issues VI-4
VII. References VI1-1
Appendices
A. RCRA Incinerator Inspection Checklist Package
B. Calculations
C. Draft Model Incinerator Permit
0. References and Guidance Documents for Hazardous Waste
Incinerators
E. Heat of Combustion Incinerability Ranking
F. Thermal Stability-Based IncinerabllHy Ranking
6. Checklist for Inspection of a New RCRA Incinerator
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OSWER 01r. No. 9938.6
LIST OF FIGURES
Number
II-l Combustor environmental releases II-6
11-2 Components of a hazardous waste incinerator 11-10
II-3 Schematic of a liquid injection incinerator... 11-16
II-4 Example rotary kiln incinerator system 11-18
II-5 Schematic of a fixed hearth incinerator 11-20
II-6 Schematic of a fluidized bed 11-22
I1-7 Side-charging and top-charging solid waste feed
system 11-25
11-8 Venturi configuration 11-30
II-9 Spray venturi with rectangular throat 11-31
11-10 Variable throat venturi with packed bed 11-32
11-11 Countercurrent packed tower absorber. 11-37
11-12 Cross-section of ionizing wet scrubber (IWS) 11-40
11-13 Components of a spray dryer absorber system
(Semiwet process) 11-44
11-14 Rotary atomizer dryer 11-45
11-15 Dual-fluid nozzle dryers 11-46
11-16 Slurry flow control system 11-49
11-17 Pulse jet baghouse 11-52
11-18 In situ versus extractive sampling systems 11-62
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OSWER D1r. No. 9938.6
LIST OF FIGURES (Concluded)
Number Page
11-19 Example extractive system 11-64
11-20 Schematic of p1tot-stat1c tube 11-70
11-21 Schematic of Annubar 11-71
IV-1 Example of a simplified process flow diagram IV-12
IV-2 Example of a labeled, multichannel strip chart IV-18
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OSUER Dir. No. 9938.6
LIST OF TABLES
Number Page
III-l Typical control parameters for hazardous waste
1 ndnerators 111-11
IV-1 Preparation for Incinerator inspections IV-9
IV-2 Example checklist page: essential information IV-11
IV-3 Example checklist page: permit operating parameters
(with preliminary information included) IV-14
IV-4 Example checklist page: permit operating parameters
(with inspector's observations included) IV-20
IV-5 Example checklist page: waste characterization (with
preliminary information included) IV-24
IV-6 Summary of activities—comparison of permit and
operating conditions IV-26
IV-7 Example checklist page: visual assessment IV-30
IV-8 Summary description of an in-depth incinerator
inspection IV-43
IV-9 Example checklist page: observed operations (for a
walk-through Inspection) IV-47
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OSWER D1r. No. 9938.6
ABBREVIATIONS
ARC—Air Pollution Control.
AWFCO—Automatic Waste Feed Cutoff.
CEM—Continuous Emission Monitor.
ORE—Destruction and Removal Efficiency.
ESP—Electrostatic Predpltator.
FBI—Flu1dized-Bed Incinerator.
.ID—Induced Draft.
IWS—Ionizing Wet Scrubber.
L/G--11quid/Gas Ratio.
PCC—Primary Combustion Chamber.
PIC—Product of Incomplete Combustion.
POHC—Principal Organic Hazardous Constituents.
SCC—Secondary Combustion Chamber.
SPA—Spray Dryer Absorber.
WC—Water Column.
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OSWER Dlr. No. 9938.6
CHAPTER I
INTRODUCTION
This manual was developed as a guidance document and training tool for
EPA, state, and local Inspectors who conduct Inspections of hazardous
waste incinerators permitted under the Resource Conservation and Recovery
Act (RCRA). A secondary audience is the incinerator permit writer, who
may learn more about the contents of an enforceable permit by under-
standing the needs of inspectors. The manual provides:
Background information on incinerators, air pollution control equip-
ment, and incinerator regulations and permits (intended for indi-
viduals with limited experience in any of these areas).
A descriptive approach for completing RCRA incinerator inspections.
Objectives and priorities for inspections via a series of detailed
checklists.
This manual serves as an incineration-specific supplement to The RCRA
Inspection Manual (EPA 1988a), and is not intended to cover all of the
general activities of a RCRA Compliance Evaluation Inspection. Although
the scope is limited to "incineration," as defined by RCRA, much of the
information and the approach presented in this manual could be useful in
planning inspections of other thermal waste treatment facilities, such as
hazardous waste boilers and industrial furnaces.
This manual reflects the current state-of-knowledge of the RCRA incinera-
tion program (as of January 1989). Regulations and guidance may change
as new knowledge and experience are gained. With only a few years'
experience in evaluating incinerators after they have been permitted, the
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OSUER Dir. No. 9938.6
RCRA Incineration program does not have extensive knowledge of "typical"
or "predictable" long-term operational and maintenance problems asso-
ciated with hazardous waste Incinerators. As more experience Is gained
1n this area, some changes In the approach to Incinerator Inspections may
become appropriate.
The reverse 1s true for the traditional air pollution control devices.
As a result of years of experience gained in the enforcement of air pol-
lution control programs, EPA has accumulated an extensive base of knowl-
edge of the long-term performance, maintenance, and reliability of
devices such as wet scrubbers and fabric filters. Some of this experi-
ence 1s reflected 1n this manual. However, one objective of this manual
1s to provide a balanced approach to Incinerator inspection that is in
accordance with the technical priorities of current RCRA permitting
guidance. Therefore, the inspection of air pollution control devices is
treated only at moderate length 1n this manual, even though more specific
Information 1s available from EPA sources than for other incinerator com-
pliance Issues.
The Inspection approach and activities developed in this manual rely
heavily on a tailored checklist to identify the specific needs of an
Inspection for a particular site and to establish the inspector's time-
use priorities. The contents of an Inspection are based on limits and
conditions established in a permit. However, a successful inspection
also requires an Inspector who can combine an inquisitive nature and a
knowledge base to make the judgments needed in the field to provide
clear, comprehensive documentation of the status of the incinerator's
compliance with the Interim status regulations or RCRA permit conditions.
Chapter II of this manual provides background Information of potential
use to Inspectors concerning incinerators and air pollution control
equipment. It reviews basic concepts and serves as a quick reference to
assist the inspector in understanding the function and potential problems
associated with key control and monitoring equipment.
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OSWER Dir. No. 9938.6
Chapter III provides an overview of hazardous waste incinerator regula-
tions and the permitting process. It also lists and describes the types
of permit-limited conditions that an inspector will be evaluating during
an inspection.
Chapters IV, V, and VI deal directly with conducting incinerator inspec-
tions. Chapter IV develops a step-by-step approach to planning and can-
ducting an inspection. Chapter V discusses the documentation of poten-
tial violations, and Chapter VI addresses follow-up activities to the
inspection and four special categories of incinerator inspections.
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OSWER Dir. No. 9938.6
CHAPTER II
BACKGROUND TO INCINERATION
INDEX
A. Incinerators II_2
A-l. Fundamental Properties of Hazardous Waste
Incineration 11-3
A-2. Environmental Releases From Incinerators II-5
A-3. Hazardous Waste Incinerator Components 11-9
A-4. .Major Classes of Incinerators 11-14
B. Waste Feed Systems 11-23
B-l. Liquid Waste Feed Systems 11-23
B-2. Solid Waste Feed Systems 11-24
C. A1r Pollution Control Devices 11-26
C-l. Introduction 11-26
C-2. Wet Scrubbers 11-27
C-3. Dry Scrubbers 11-42
C-4. Fabric Filters 11-50
D. Process and Emissions Monitoring Instrumentation 11-57
D-l. Temperature 11-59
D-2. Pressure 11-60
D-3. Oxygen Concentration 11-61
D-4. Carbon Monoxide 11-65
D-5. Waste Feed Rate 11-66
D-6. Combustion Gas Velocity and Airflow 11-69
D-7. pH Measurements 11-73
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OSWER 01r. No. 9938.6
CHAPTER II
BACKGROUND TO INCINERATION
LEARNING OBJECTIVES
Introduce the basics of hazardous waste Incineration Including;
Fundamentals and operating principles
• Major components
• Types of incinerators
Types of wastes that can be incinerated
Discuss the air pollution control devices used in hazardous waste
incineration facilities including:
• Types of devices
Basic principles
Potential problems
Provide background on the process and emissions monitoring equipment
used in hazardous waste incineration facilities.
A. INCINERATORS
A basic understanding of what incinerators are and how they work is a
prerequisite to effective inspection of hazardous waste incinerators and
enforcement of the RCRA regulations and permit requirements for those
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OSWER 01r. No. 9938.6
Incinerators. Key elements are an understanding of the objectives of the
Incineration system and the key operating principles that allow those
objectives to be met, a basic knowledge of the Incineration system com-
ponents and their function, and an understanding of indicators of poor
performance that can result in failure to meet regulatory requirements.
These factors are discussed briefly in the four subsections below. The
first subsection provides a survey of the fundamental properties of
hazardous waste Incineration. It outlines the objectives of the incin-
eration system and defines the scientific/engineering principles that are
keys to achieving these objectives. The second subsection addresses
environmental releases and potential failures that lead to releases that
are potential regulatory violations.
The third subsection provides an overview of the components of the com-
bustion system and briefly describes the function of each component. The
fourth subsection describes the four major classes of incinerators (or
combustion units). For each class of Incinerator, the basic design is
described, the types of wastes compatible with that design are iden-
tified, and key operating parameters are defined.
References for additional information on incinerators are provided on
page VI1-3.
A-l. Fundamental Properties of Hazardous Waste Incineration
A hazardous waste Incinerator is an enclosed, controlled flame combustion
device system that is used to treat primarily organic and/or aqueous
waste streams. The objectives of the incineration process are twofold.
First, the high temperature environment in the flame zone and post-flame
zone greatly reduces the hazardous characteristics of toxic, reactive,
and ignitable wastes. In a properly designed and operated incinerator
virtually all organic materials 1n the waste feed are decomposed into
carbon dioxide and water. Second, the incineration process greatly
reduces the mass and volume of waste material that must be disposed in
land-based facilities.
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OSWER D1r. No. 9938.6
While a properly designed and operated hazardous waste incinerator is an
environmentally sound treatment technique, poorly designed, or more fre-
quently, improperly operated incinerators can generate environmental
releases that are potentially harmful to human health and to the environ-
ment. A key function of the inspector is to assure that the incinerator
is operated in an environmentally acceptable manner. The paragraphs
below describe the key operating factors that affect incinerator perfor-
mance and identify points of environmental release from the process.
In principle, combustion of hazardous waste is a chemical process that is
equivalent to combustion of fossil fuels to recover energy. It is a
chemical reaction that involves rapid oxidation of the organic substances
in the waste and auxiliary fuels. This violent reaction releases energy
in the form of heat and light and converts the organic materials to an
oxidized form.
Efficient combustion is achieved only when the proper amount of air is
made available to the combustion chamber. Other factors influencing the
completeness of combustion are temperature, time, and turbulence. These
are sometimes referred to as the "three T's of combustion," and need to
be given careful consideration when incineration systems are evaluated.
Each combustible substance has a characteristic minimum ignition
temperature that must be attained or exceeded, in the presence of oxygen,
for the oxidation reaction to proceed at a rate that would be charac-
terized as combustion. Above the ignition temperature, heat is generated
at a higher rate than it is lost to the surroundings, and the elevated
temperatures necessary for sustained combustion are maintained.
Time is a fundamental factor in the performance of combustion equip-
ment. The residence time of a constituent in the high-temperature region
should exceed the time required for the combustion of that constituent to
take place. Residence time requirements establish constraints on the
size and shape of the furnace for a desired firing rate. Because the
reaction rate increases with increasing temperature, a shorter residence
time will be required for combustion at higher temperatures. Residence
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OSUER 01r. No. 9938.6
time can be calculated, but It 1s not measured directly; some Indicator
of combustion gas flow rate Is used as a surrogate.
Turbulence and the resultant mixing of organic materials and oxygen are
also essential for efficient combustion. Inadequate mixing of combus-
tible gases and air in the furnace can lead to emissions of incomplete
combustion products, even from an otherwise properly sized unit with suf-
ficient oxygen. Turbulence will speed up the evaporation of liquid fuels
for combustion in the vapor phase. In the case of solid fuels, turbu-
lence will help to break up the boundary layer of combustion products
formed around the burning particle. Under nonturbulent conditions, the
combustion rate is slowed by the decreased availability of oxygen to the
surface reaction. Although turbulence 1s an important factor in good
combustion, it cannot be monitored and an inspector generally will have
no way to assess turbulence. This issue is addressed within basic design
decisions.
A-2. Environmental Releases From Incinerators
The major concern of the inspector is to ensure that the incinerator is
operating within the conditions established in the facility's permit.
The limiting conditions are selected to minimize environmental releases.
A simplified schematic of a hazardous waste incineration facility is
shown in Figure II-l. This figure identifies key input streams to the
Incinerator and potential pathways of release. The waste stream
generally is -a complex mixture of organic and inorganic constituents.
As shown in the schematic, these constituents or their reaction products
can leave the incinerator via one of three pathways: (1) they can be
emitted to the atmosphere either through the stack or as fugitive emis-
sions from the incinerator or from handling operations; (2) they can
leave the facility as a solid residue in the form of bottom ash or as a
dry catch from the air pollution control equipment; and (3) they can be
discharged as a liquid effluent from the air pollution control system.
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CO PICs
HCI Metals
Fugitive
Emissions
Fugitive
Emissions
\
Fugitive Dust
Ash To
Disposal
Deposition
Control
Device
Parameters that
Affect Organic
Destruction
Parameters that
Affect Pollutant
Removal
Control Device
Effluents —
Paniculate Matter
Metals
Acid Gases
To Disposal
Figure II-l. Combustor environmental releases.
m
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OSWER Dir. No. 9938.6
Four major groups of compounds are of environmental concern—hazardous
organic constituents; hazardous metal constituents; acid gases generated
from combustion of halides, sulfur, and phosphorus; and particulate
matter. The potential pathways of each of these constituents through the
Incinerator are described in the following paragraphs.
Generally, waste streams are not fed directly to a combustor. They are
stored, at least temporarily, in a drum or tank and frequently undergo
one or more transfer operations before being fed to the combustor. If
the storage and handling equipment is not sealed perfectly, volatile
organic constituents in the waste can be emitted to the atmosphere as
fugitive emissions. Spills also can occur during handling and transfer,
and volatile organic constituents are emitted from this spilled material.
Wastes are fed from the storage source into the combustor. Under ideal
conditions, all of the organic material in the waste would be converted
to a completely oxidized form (C02, H20, and acid gases). However, since
combustion is never 100% complete, organic constituents present in the
waste or hazardous products of Incomplete combustion (PICs) of those
waste constituents are discharged from the combustion chamber via two
pathways. The most likely pathway is with the stack gas, but organic
constituents can be adsorbed on bottom ash. (The bottom ash is a haz-
ardous waste if 1t is "derived from" a listed hazardous waste or if it
exhibits any hazardous waste characteristics.) The materials that are
contained 1n the bottom ash can be disposed in a land disposal unit or
they can be emitted to the atmosphere during ash handling operations.
The materials that are exhausted from the combustion chamber with the
combustion gases are transported to the air pollution control system.
They can be collected by the control system and disposed with the residue
from the system, or they can penetrate the control systems and be dis-
charged to the atmosphere. Available information suggests that very few
air pollution control systems achieve significant removal of volatile
organlcs. Consequently, most organic constituents that are not destroyed
1n the combustor are emitted to the atmosphere from the stack. However,
significant control of some semi volatile PICs (i.e., dioxins and furans)
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OSWER 01r. No. 9938.6
has been demonstrated with dry scrubbers and wet scrubbers. Wet scrub-
bers have demonstrated significant control of low molecular weight
organic acids, aldehydes, and ketones.
Unlike organic constituents, metal constituents are not likely to be
emitted as fugitives during waste storage and handling, and they are not
"destroyed" during the combustion process. Rather they are partitioned
among the incinerator effluent streams. As with the "noncombusted"
organic constituents, metal constituents can leave the combustion chamber
as bottom ash or 1n the combustion gas. The relative distribution of the
metals between these streams is based on such factors as the chemical
form of the metals charged to the combustor, the localized reaction
atmosphere in the combustion chamber, localized chamber temperatures, and
localized chamber airflows.
Metals that leave the chamber as bottom ash ultimately can reach a land
disposal site or can be lost to the atmosphere as fugitive emissions.
Metals can leave the combustion chamber 1n the gas stream either as
entrained particulate or as a metal vapor. Again, the material can be
captured by the control system or can penetrate the control system and be
discharged to the atmosphere. The removal efficiency of the control
system depends on whether the metal is emitted as a particle or a gas.
Generally, air pollution control systems are ineffective in controlling
gas phase metals constituents. Dry scrubbers operating at sufficiently
low temperatures do collect significant amounts of volatile me Li's from
flue gases (e.g., 80% to 90% removal of mercury has been demonstrated).
If the gas stream is presaturated and cooled upstream of a venturi, then
a wet venturi will be able to collect the volatile metals constituents
that are condensible. The removal of metal constituents that enter the
control system as particulates depends on the particle size distribution
for each constituent as described in Section II-B. Any by-product of the
air pollution control system (i.e., catch from a control device, scrubber
effluent) is handled as hazardous waste if "derived from" a listed
hazardous waste or if it exhibits any hazardous waste characteristics.
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OSWER Dir. No. 9938.6
Elements such as chlorine, sulfur, and phosphorus, If present in the
waste, can react to form "acid gases" (acidic combustion gases). Since
many of the toxic organic compounds found in hazardous waste contain
chlorine, the formation and removal of hydrogen chloride gas from burning
chlorinated wastes is an important issue for hazardous waste
incinerators.
A-3. Hazardous Waste Incinerator Components
Each incineration facility contains the same basic types of equipment,
but no two facilities are exactly alike. At the heart of each facility
is at least one combustion chamber (i.e., combustor). Additional equip-
ment is necessary to bring the waste into the combustion chamber and to
deal with combustion products, as illustrated in Figure II-2.
The common elements of each incineration facility are:
Waste storage and handling system
Air/gas handling system
Combustion chamber(s)
Auxiliary fuel feed
Air pollution control system
Residuals handling system
Process instrumentation
Equipment used for waste storage and handling varies according to the
characteristics of the waste and the degree of flexibility required by
the incineration facility. Tanks are used to store liquid waste. An
on-site industrial facility may use flow-through tanks which serve pri-
marily to equalize waste production rates and waste destruction rates.
Commercial incineration facilities may use an integrated "farm" of tanks,
with some tanks used for storing each batch of waste received and some
used for blending similar types of waste together. Some facilities may
also use temporary storage tanks, such as railroad tank cars or tanker
trucks.
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Process Instrumentation
Waste Feed System
Waste
Storage
and
Handling
© © ©
Liquid
Waste
Tank
Air Pollution
Control
Equipment
Combustion
Air Blower
Scrubber
Effluent
Baghouse
Ash
Residuals Handling System
Stack
ID
Fan
KEY:
P = Pressure
T a Temperature
AP = Pressure Drop
V = Velocity
ID = Induced Draft
m
JO
Figure I1-2. Components of a hazardous waste Incinerator.
10
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OSWER 01r. No. 9938.6
A key feature of a feed tank 1s Us ability to mix the contents to avoid
layering either by stirring or by redrculating the contents. In some
cases the tanks are heated to keep the contents less viscous and to avoid
precipitating out less soluble constituents.
Many facilities handle solid waste via containers such as 55-gal steel
drums, combustible drums made of plastic or heavy cardboard fiber, or
cardboard boxes. A drum storage shed 1s an example of a storage facility
for containerized solid waste; handling facilities may Include scales,
conveyor belts, or drum shredders. Bulk sol Ids may be stored in a silo
or on a tipping floor.
The role of the waste feed system is to introduce waste to the incinera-
tor. The feed system will vary according to the physical state of the
waste. For example, it may include piping, pumps, and burner systems
with atomizing nozzles for liquids or conveyor belts and charging hoppers
for solids. This equipment will be described in more detail later in
this section.
The air or gas-handling system includes the fans or blowers that move the
Intake air and the combustion gases, and the motors that drive the
fans. Generally, one or more blowers are used to supply combustion air
to the incinerator at one or more points:
Induced draft (ID) fans use negative pressure (e.g., a vacuum) to
pull gases through the incinerator.
Forced draft fans provide positive pressure, pushing gases in.
The combustion chamber provides a high-temperature environment for the
desired gas retention time, typically in the range of several tenths of a
second to several seconds. The nominal gas temperature within the com-
bustion chamber may be.set anywhere from roughly 1100° to 2400°F, depend-
ing upon the design and application of the incinerator. Key design
factors include:
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OSWER Dir. No. 9938.6
Time (gas-phase retention time; also solids retention time for some
units).
Temperature.
Turbulence (how well-mixed the air, waste vapors or solids, and the
combustion gases are).
Oxygen level (e.g., excess oxygen systems or low-oxygen pyrolysis
systems).
Most combustion chambers consist of a steel outer shell, lined on the
inside with refractory such as fire brick. Refractory material assists
in maintaining a stable temperature within the combustor with minimum
energy loss and withstanding the stresses of heating up and cooling
down. The combustion chamber may be in the shape of a cylinder, or less
commonly, a rectangular box. Its orientation may be either horizontal or
vertical.
Many incinerators use two combustion chambers in series. The first
chamber is where most of the hazardous waste is fired, and is known as
the primary combustion chamber (PCC). The next chamber, positioned
directly downstream, is known as the afterburner or the secondary combus-
tion chamber (SCO; it typically fires fuel and/or high energy liquid
waste. The major purpose of a PCC is to partially combust organic mate-
rial and to heat up and convert any remaining organic solids/liquids into
a vapor form. The major purpose of a SCC is to subject vaporized waste
to a high enough temperature for a long enough time to ensure near-
complete destruction.
Incinerators require auxiliary fuel, such as fuel oil, natural gas, or
high-energy nonhazardous wastes, to bring each combustion chamber up to
the minimum combustion temperature required in the permit prior to
accepting hazardous wastes. In addition, a flow of auxiliary fuel may be
maintained to one or more combustion chamber during the combustion of
11-12
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OSWER Dir. No. 9938.6
those hazardous waste streams that do not provide adequate heat Input to
maintain the minimum combustion temperatures. Although some organic
waste streams may have high heating values and serve as fuel to the
Incinerator, some wastes, such as those with high water content or high
Inorganic content, may require supplemental fuel for adequate
Incineration.
The air pollution control system is designed to remove solid particulate
matter and add gases from the gases leaving the combustion chamber(s).
It will be discussed at length in the next section, and will only be
described as a general system in this section. Sometimes the stack is
considered to be part of the air pollution control system. Its main
function 1s to carry the combustion gases and any remaining pollutants
high enough Into the atmosphere that dilution will generally reduce any
hazard before the gases may reach ground level again.
The residuals handling system handles the solid and liquid by-product of
the incineration facility. Solids handling systems are used to remove
heavier, larger particles of bottom ash from the combustor or lighter,
smaller particles of fly ash that carry part way through the air pollu-
tion control devices. Some residual materials are removed In an aqueous
(water) stream by air pollution control scrubbers. The wastewater is
treated prior to discharge.
All of the important process functions of the incinerator, including the
waste feed system, the combustion system, the air pollution control sys-
tem, and the residuals handling system, need to be monitored using
appropriate instruments. The instrument sensors are usually located on
or within the incineration system itself, while the readout devices
(gauges, strip-chart recorders, etc.) are usually located in a central
control room. Instrumentation used for monitoring the process and
specific gases are described in the last section of this chapter.
11-13
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OSWER Dir. No. 9938.6
A-4. Major Classes of Incinerators
Generally no two incinerators look alike, but only four basic design
types are actually in use for most hazardous waste incineration applica-
tions. Each of these types will be discussed in the following para-
graphs. As of November 1988 there were 205 hazardous waste incinerators
on a permit track in the records of EPA's Office of Solid Waste. Most
are liquid injection incinerators or rotary kiln incinerators.
Many incinerators operate on a 24-hr/day, 7-day/week basis except for
periodic scheduled maintenance (e.g., annual or every 6 months) and
unscheduled repairs. This is particularly the case for commercial
Incinerators, industrial incinerators receiving continuous waste feeds
associated with a continuous manufacturing process, and industrial
incinerators receiving large-volume waste streams from multiple
operations. However, many smaller on-site industrial incinerators and
government facility incinerators may operate on a shift basis or on an
irregular basis, depending on the amount of waste feed available.
The subsections below describe four most common types of hazardous waste
incinerators. Each subsection identifies the type of wastes that are
compatible with the combustor, describes the system, and identifies key
operating parameters.
A-4-a. Liquid Injection Incinerators
The simplest type of hazardous waste incinerator is the liquid injection
incinerator, also known as the liquid-fired incinerator. These units can
handle only a limited range of waste feed types, including:
- Liquids
Pumpable slurries
Gases
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OSWER Dir. No. 9938.6
Liquids can Include organic wastes, which contribute some fuel value, or
aqueous wastes, which provide minimal fuel value and may tend to quench
(cool) the hot combustion gases. Slurries are liquids with a high sus-
pended sol Ids content. If a slurry can be transported with a pump, it
can generally be fed to the combustor using conventional types of liquid
waste firing equipment. Gases are sometimes fed to a liquid incinerator,
but usually only to on-s1te industrial incineration facilities that may
continuously ventilate a vessel in a chemical process and pipe the
ventilation gases directly into the incinerator. (It should be noted
that uncontained gases are not solid wastes as defined in Section 1004 of
RCRA, as amended.)
A liquid injection incinerator usually has only a single combustion
chamber, operated at high temperature (generally 1600° to 2000°F). The
combustion chamber may be oriented horizontally or vertically. Vertical
combustion chambers may have the waste introduced with an upward flame
(up-f1red) or with a downward flame (down-fired). Because liquid
incinerators do not handle sol Ids, they usually process wastes of lower
ash (inerts) content, and do not require as sophisticated an air pollu-
tion control equipment as other incinerator types. Some have only a
stack following the combustion chamber. An example of an up-fired,
forced draft system with no air pollution control devices is shown in
Figure II-3.
Key performance parameters for a liquid injection incinerator are
temperature, residence time, combustion air, and atomization of the waste
feed. Atomization involves breaking the liquid into tiny droplets that
have a high ratio of surface area to volume. The liquid then can be
vaporized quickly, and the turbulent action provides maximum exposure to
combustion air, thus allowing an active, high-temperature flame. The
effective atomization of wastes allows a liquid injection incinerator to
destroy wastes with typically only a single combustion chamber.
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OSWER Dir. No. 9938.6
Flow
Straightener
\
Air £=S
Steam ^
f Liquid A
V Waste #1 J
I
I
'
^
fe»
k"\
^J
^
j
it
^
r Steam
Natural x-^-x
Gas
Liquid
Waste #2
Vv^X
T^
Flgure II-3. Schematic of a liquid injection incinerator.
11-16
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Natural Gas
Liquid Waste
Waste Water
Natural Gas
Liquid Waste
Drummed Waste
Bulk Waste
00
Afterburner
Transition
Chamber
A
Quench
Ionizing
Wet Scrubber
Stack
/ \
To
Scrubber
-Effluent
Treatment
System
73
O
—j»
-J
Figure I1-4. Example rotary kiln Incinerator system.
VO
CO
00
•
Ok
-------
Liquid
Organic
Waste
Storage
r\>
o
Fuel Que?ch
Oil Sectlon
Ash
Makeup
Drag «•" Well
Chain I Bin I yVater
Caustic Added
As Needed
o
co
70
o
—to
-t
Figure I1-5. Schematic of a fixed hearth Incinerator.
VO
CO
00
•
en
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OSWER Dir. No. 9938.6
Pollution
Control
System
Figure II-6. Schematic of a fluidized bed.
11-22
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OSWER Dir. No. 9938.6
Key operating parameters Include:
- Airflow rate/distribution
Bed temperature
Bed condition
The bed condition 1s critical to the Incinerator's operation. The
quantity and type of ash present in the waste is important in maintaining
the bed properties. If the bed accumulates ash more rapidly than it is
lost, excess material must be removed through a tap valve. Other systems
may need additional sand or other material as loss occurs.
The bed condition is normally monitored by a series of thermocouples
placed around the periphery of the bed. The temperature is normally
uniform. A divergence in Indicated temperature by one thermocouple is an
indication of poor fluidlzation or buildups in that region.
The FBI provides good contact between waste and combustion air. As the
result of lower operating temperatures and lower excess air levels,
however, there are sometimes higher emissions of carbon monoxide (CO) and
hydrocarbon than with other Incinerators. As needed, an afterburner can
be used to reduce levels of these by-products in the stack gases.
B. WASTE FEED SYSTEMS
B-l. Liquid Waste Feed Systems
Liquid waste feed systems act to transport, mix, and atomize the waste.
Liquid wastes are normally fed to an incinerator using an atomizing
nozzle, which also may be called a waste feed gun. One or more nozzles
may be incorporated into a burner assembly that may also contain ports
for Injecting combustion air, and baffles for developing turbulence.
Liquids may be atomized in either of two ways, mechanically or by an
atomizing fluid. Mechanical atomizers involve some type of mixing motion
11-23
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OSUER Dir. No. 9938.6
to break up the liquid waste or fuel Into tiny droplets. Ultrasonic
systems may also be used for mechanical atomization.
Fluid atomized nozzles are more commonly used for incinerators than are
mechanical ones. The atomizing fluid (steam or air,.or sometimes nitro-
gen) provides the energy to break up the liquid into small droplets.
The key operating parameters for atomizing systems include:
Waste feed viscosity
Waste feed flow rate (turndown)
Atomizing fluid pressures
Solids concentration and size
All of these variables affect atomization. The turndown is a calculated
ratio of the nominal or maximum design flow rate to the actual monitored
flow rate for a particular nozzle.
In some cases liquids may be introduced via injection nozzles that are
not atomized, but such nozzles would normally be used in the primary
chamber of a two-combustor incinerator. Similarly, semisolid or sludge
wastes may be fed by screw augers or lances into a primary chamber.
B-2. Solid Waste Feed Systems
Solids may be fed to incinerators in batches, such as in drums. The
containers are transported by conveyor systems or manually, and are
introduced to a charging system that consists of a steel box with at
least two doors. To feed a container to the combustor, the outer door is
closed and the inner door is opened, and the charge is forced into the
combustor by either a mechanical ram or conveyor, or by gravity, in the
case of charging systems on the top of the combustor. This multiple door
system prevents gases from escaping the incinerator or unwanted air from
entering, and allows for more stable operation in the batch firing
mode. Side-charging systems or top-charging systems can be used. Exam-
ples of both systems are shown in Figure II-7.
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OSWER 01r. No. 9938.6
Some potential problems for solids-handling systems for Inspectors to
note Include uncertainty In the feed rate measurement, plugging of the
charging doors, and fugitive leaks.
C. AIR POLLUTION CONTROL DEVICES
C-l. Introduction
The purpose of this section 1s to supply the reader with the specialized
information needed for inspecting/evaluating air pollution control (ARC)
devices on hazardous w.aste Incinerators. This section provides RCRA
inspectors with a concise body of pertinent information, and includes
references for more detailed information on control technologies and
inspections.
The six most common types of APC technologies installed on HWIs will be
identified and discussed. Descriptions of their purpose, principle of
operation, and performance parameters are provided along with brief dis-
cussions of the use of instrumentation to assess/diagnose common perfor-
mance problems. The types of APC technologies described in the manual
include three wet scrubber designs (venturi, packed bed, and ionizing wet
scrubber); two dry scrubber designs (rotary atomization, and dual-fluid
nozzle atomization); and one fabric filter design (pulse cleaning).
(Another traditional APC technology, the electrostatic precipitator,
typically has not been applied to hazardous waste incinerators and is not
discussed in this manual.)
The six APC technologies discussed represent most of the conventional and
emerging technologies installed on incinerators requiring control of par-
ticulate and/or HC1 emissions. Most conventional APC technologies are
designed for and designated as either partlculate control or gaseous con-
trol. Some emerging technologies (e.g., ionizing wet scrubbers and dry
scrubbers) are designed to be effective for both particulate and gaseous
control by using components that are principally responsible for partlcu-
late or gaseous control.
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OSWER Olr. No. 9938.6
Either a quench chamber or waste heat boiler is needed to cool ("quench")
and control the incinerator gas stream from about 2000'F to about 450°F
for protection of the ARC equipment. Many incinerators use a quench
chamber with water sprays to cool and humidify the incinerator gas
stream. A quench chamber is popular because the humidification process
pretreats the gas stream for enhanced performance of the ARC equipment.
A waste heat boiler or heat exchanger is sometimes installed to reduce
and control the temperature of the incinerator gas stream. The heat
recovered from a boiler can be used for space or process heating.
The information on ARC technologies is intended to help prepare regula-
tory agency personnel to conduct an inspection on the types of ARC equip-
ment commonly found on RCRA incinerators. Permit conditions generally
are specified for the important parameters that affect air pollution
control equipment. The permit requires that the air pollution control
system be consistent with the limits on these parameters when hazardous
wastes are fed to the incinerator. Some permits require actuation of the
automatic waste feed cutoff when the ARC operating conditions move
outside specified ranges for the performance parameters. Specific
problems associated with ARC equipment on hazardous waste incinerators
may stem from variation with waste feed characteristics, combustion
conditions, particle size distribution and particulate concentration, and
acid gas concentrations. Regulatory agency inspection personnel need
specialized information on ARC technologies (a) to determine that the ARC
performance parameters are maintained on a continuous basis, and (b) to
certify that emission limits are not being exceeded.
C-2. Met Scrubbers
Wet scrubbing involves (in many cases) a quench for cooling and saturat-
ing the flue gas with water, followed by an inertial scrubber for partic-
ulate removal and a packed bed scrubber for acid gas removal. Venturit
packed bed, and ionizing wet scrubbers (IMS) are the common types of wet
scrubber systems used on hazardous waste incinerators. These three types
of wet scrubbers are addressed in this section.
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OSWER 01r. No. 9938.6
Many of the wet scrubber systems installed on incinerators consist of a
variable throat venturi followed by a packed bed tower and mist elimina-
tor. These systems are designed to operate at a pressure drop in the
range of 20 to 60 inches water column (in w.c.), depending on performance
or permit condition requirements. The variable throat venturi design
accommodates varying gas flow rates while maintaining a constant pressure
drop by changing the venturi throat area. A pH controller system,
including a pH electrode and transmitter, can be used to adjust the flow
of a caustic solution (e.g., sodium hydroxide, sodium carbonate) to the
scrubber system to respond to varying acid gas concentrations.
Several ionizing wet scrubber (IWS) systems are installed on RCRA incin-
erators. These systems consist of one or more modules that comprise an
ionizing section followed by a packed bed tower and mist eliminator sec-
tion. In IWS systems, the ionizing section(s) is responsible for charg-
ing the particles and the packed bed section(s) is responsible for remov-
ing the charged particles and acid gases from the exhaust gases. A pH
controller system, including a pH electrode and transmitter, can be used
to adjust the flow of a caustic solution to the scrubber in response to
varying acid gas concentrations.
Typical operation and maintenance problems for wet scrubbers include fan
imbalance, nozzle wear or plugging, pump seal leaks, pH controller
drifts, pH electrode fouling, and wet-dry interface buildup.
Any effluent from a scrubber system must be handled as a hazardous waste
if it is "derived from" a listed hazardous waste or if it exhibits any
hazardous waste characteristics. If the effluent is not a hazardous
waste, frequently the effluent'can be treated by an industrial wastewater
treatment facility or a public treatment plant.
The following material provides a general background on the types of wet
scrubbers that an inspector may expect to see installed at Incineration
facilities. Each subsection briefly describes the operating principles
of the scrubbing system and identifies important operating parameters
that inspectors generally will see addressed in permits. Typical opera-
tion and maintenance problems that an inspector might observe during an
inspection also are described.
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OSWER 01r. No. 9938.6
Inspectors should refer to other EPA references (see reference 11st) for
types of scrubbers not specifically discussed in this report.
C-2-a. Venturl Scrubbers
(1) Operating Principles for Venturi Scrubbers
(Note: Materials from EPA 1984, EPA 1982, Calvert, and Andersen 2000,
Inc. were used in the following discussion.)
A typical venturi scrubber is illustrated in Figure 11-8. The gas stream
enters the converging section and is accelerated approximately by a fac-
tor of 10. The liquor is injected just above the throat, and fine drop-
lets are formed from the shearing action of the high gas velocities.
Impaction of particles occurs on the droplets which are moving slower
than the gas stream. The gas stream is decelerated in the diverging
section. After the venturi section, the gas stream passes into a mist
eliminator or into a packed bed tower followed by a mist eliminator. The
function of the venturi is only to effect collision between the droplets
and the particles; and the removal of the particle laden droplets from
the gas stream only occurs in the mist eliminator.
There are a large number of variations to the standard venturi configura-
tion. Figure II-9 illustrates a rectangular throat design.
A popular variable venturi throat design is included in Figure 11-10
illustrating an adjustable cone-shaped baffle in the throat to increase
or decrease throat cross section without affecting scrubber geometry.
The conical baffle 1s actuated by manual, hydraulic, or electrically
driven mechanical linkages. The adjustable actuator is mounted
externally to the gas stream to allow maintenance without shutdown. The
variable venturi throat design allows a constant venturi throat gas
velocity and constant pressure drop to be maintained under highly
variable gas flow conditions, thereby maintaining constant particle col-
lection efficiency.
11-29
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OSWER Dir. No. 9938.6
Converging
section
— Throat
Diverging
section
Figure II-8. Venturi configuration.
11-30
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OSWER D1r. No. 9938.6
Liquid inlet
Figure II-9. Spray venturi with rectangular throat.
11-31
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OSWER ,
PACKED SECTION
UQUID DISTRIBUTOR
PACKED ABSORPTION
SECTION
PACKING SECTION
LIQUID DIVERTER
FLANGED
GAS OUTLET
ANTI-CREEP RING
"OPEN-
PACKING
SUPPORT
FLANGED
UQUID INLET
THROAT AREA
VARIABLE THROAT
EXPANDER
FLANGED
GAS INLET
PACKED SECTION
LIQUID COLLECTOR
ACCESS
MANWAY
PACKED
SECTION
LIQUID
DRAIN
TEFLON
PACKED
STEM
CYCLONIC
SEPARATQn
WETTED ELBOW
VARIABLE THROAT FLANGED
ACTUATOR LIQUID DISCHARGE
Figure 11-10. Variable throat venturl with packed bed.
11-32
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OSWER Dir. No. 9938.6
Some venturi designs Include provisions to reduce wear due to erosion and
abrasion of the section Immediately downstream of the venturi. The
momentum and abrasive nature of the particle-laden droplets produced in
the high velocity venturi section can erode the material downstream of
the venturi. The wetted elbow shown in Figure 11-10 allows the small
pool of water to absorb this abrasion, and thereby protects the elbow
material.
Impact1on 1s the primary particle collection mechanism in venturi
scrubbers. The effectiveness of impaction is related to the square of
the particle diameter and the difference in velocities of the liquor
droplets and the particles. The importance of particle size distribution
cannot be over-emphasized. For particles greater than 1 to 2 ym, impac-
tion is highly effective, and penetration (emissions) is negligible.
However, penetration of smaller particles, particularly those in the 0.1-
to 0.5-um range, is very high. Hazardous waste incinerators can generate
substantial concentrations of particulate matter in this submicron range
and these particles are difficult to remove from the exhaust gases.
(2) Performance Parameters for Venturi Scrubbers
In general, the overall particulate collection efficiency in a venturi
scrubber system increases as the static pressure drop increases. The
most sensitive performance parameter for Venturis is the static pressure
drop. The static pressure drop is a measure of the total amount of
energy used in the scrubber to accelerate the gas stream, to atomize the
liquor droplets, and to overcome friction. At high static pressure
drops, the difference in the velocities of the droplets and the particles
in the gas stream is high; also, a large number of small diameter drop-
lets are formed. Both of these conditions favor particle impaction into
water droplets.
Another important design and performance parameter is the liquid to gas
(L/G) ratio. Many venturi scrubbers are designed for L/G ratios between
5 and 12 gal per thousand actual cubic feet (gal/Macf). At L/G ratios
less than 3 gal/Macf, the liquid supply is inadequate to completely cover
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OSWER 01r. No. 9938.6
the venturi throat. L/G ratios above 10 gal/Macf are seldom justified
because they do not increase performance but do increase operating
costs. Typically, the L/G ratio has not been included as a permit condi-
tion for RCRA incinerators.
A scrubber is not an isolated piece of equipment. It is a system com-
posed of a large number of individual components. Because incinerators
produce fluctuating conditions of gas flow rate, gas temperature, par-
ticulate characteristics, and acid gas concentration, there are distinct
advantages for scrubber systems that are able to make operational adjust-
ments to compensate for the changes. A list of the major components of
commercial scrubber systems includes the following:
Venturi section
Spray nozzles
Liquor treatment equipment
Gas stream demister
Liquor recirculation tanks, pumps, and piping
Alkaline addition equipment
Fans, dampers, and bypass stacks
Controllers for venturi throat area, caustic feed, makeup water, and
temperature excursions
(3) Operating Problems for Venturi Scrubbers
Venturi scrubbers have been used to control emissions from a wide variety
of industrial and incineration processes. Normal operating problems that
reduce venturi performance have been derived from past experience and are
noted below. The normal problems are associated with maintaining the
required pressure drop level and liquid flow rate, along with solids
buildup at the wet-dry interface.
Maintaining a specified pressure drop level (and continuously monitoring
pressure drop) is a common permit requirement for venturi scrubbers.
There are several possible causes for a venturi operating at a reduced
pressure drop level. A problem can be caused by the adjustable throat
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OSWER D1r. No. 9938.6
being opened too far, and the result is a reduction in pressure drop and
throat gas velocity. Reduced pressure drop levels can also be caused by
a loss or reduction in the scrubber liquid supply. A drop in liquid flow
rate can result from scaling and pluggage in the nozzles, pipes, or
flowmeters. Pump failure or low liquid levels in the recirculation tank
can also be responsible for a loss or reduction in the liquid supply.
These problems are identifiable from routine record keeping and inspec-
tion, and can be resolved readily by maintenance.
The venturi throat can be damaged by erosion or abrasion caused by a high
level of suspended solids in the recirculated scrubbing liquid. Reducing
the suspended solids by increasing the blowdown rate in the system will
help solve erosion problems. Corrosion of internal parts can also be a
significant problem. Maintaining the pH of the scrubber liquid between
5.5 and 10 will help reduce corrosion problems.
Another common problem with venturi scrubbers is a solids buildup at the
wet-dry interface. The wet-dry interface is the transition region where
the gas stream changes from an unsaturated to a saturated condition. As
the hot gas stream comes into contact with the scrubbing liquid to cool
and saturate the gas stream, there is a tendency for the suspended par-
ti cu late to accumulate on the walls. Scrubber design can help reduce the
rate of solids buildup, but gradual accumulation of deposits will
occur. Routine maintenance involving removal of this buildup is typi-
cally the only solution. Sometimes a reduction in the suspended solids
content will reduce the rate of the buildup, but routine maintenance will
still be required at less frequent intervals. Inspectors should check to
verify if routine maintenance is performed in this area.
A properly designed venturi should have a quench system that pre-
saturates the gas stream ahead of the venturi. Presaturation will reduce
the buildup of solids and enhance the collection of fine particles. If
saturation occurs in the venturi throat, some pollutants may condense
after the throat, thus avoiding collection.
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OSWER 01r. No. 9938.6
C-2-b. Packed Bed Scrubbers
(Note: Materials from EPA 1984, EPA 1982, Calvert, and Andersen 2000,
Inc. were used in the following discussion.)
In a packed bed scrubber, gaseous pollutants, such as acid gas, are
removed from the gas stream via contact with a caustic scrubbing
liquid. This liquid is distributed over a bed of inert plastic or
ceramic packing material, manufactured in various shapes to produce a
high surface area for the liquid-gas contact area. The flue gas flows
through the scrubber countercurrent to the liquid flow. The liquid
leaving the scrubber is either recycled or passed on for further treat-
ment, and the clean gas leaving the system may pass through a demister
(for removal of moisture droplets) prior to exiting from a stack. A
clear water wash can be applied to the demister to minimize plugging. A
typical packed bed scrubber is shown in Figure 11-11.
Packed bed scrubbers generally are used for acid gas removal. The large
liquor surface area created as the liquor gradually passes over the pack-
ing material favors gas diffusion and absorption. Packed bed scrubbers
are not effective as stand-alone scrubbers for collection of fine par-
ticulate matter (less than 2.5 pm) because the gas velocity through the
bed(s) is relatively slow. However, some packed beds are effective for
the removal of particle-laden droplets or charged particles when used as
a downstream collector behind a venturi or an ionizing wet scrubber.
Some packed bed towers are designed with a tangential entry and a
cyclonic separator at the base of the tower to remove the entrained
droplets.
Packed beds can be designed either vertically or horizontally. Regard-
less of the orientation of the bed, the liquor is sprayed from the top
and flows downward across the bed. Proper liquor conditioning and
distribution is important for efficient removal of gases. The static
pressure drop is not a sensitive parameter for evaluation or inspection
of performance.
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OSWER D1r. No. 9938.6
Scrubbing Liquid
1
In
Packing
(Plastic, Ceramics)
Dirty Gas
In
Clean Gas
Out
Clear Water Wash
Demister
Hold Down Plate
Intermediate Packing
Support Plates and/or
Liquid Redistributor
Packing Support Plate
Liquid
Out
(To Recycle Sump
or Treatment Plant)
Figure 11-11. Countercurrent packed bed scrubber.
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OSWER 01r. No. 9938.6
(1) Operating Principles for Packed Bed Scrubbers
Absorption is the primary acid gas collection mechanism in packed bed
scrubbers. The effectiveness of absorption in packed beds is related to
the uniformity of the gas velocity distribution, the surface area of the
packing material, and the amount and uniform distribution of scrubber
liquid. The'rate of HC1 absorption is a gas film-controlled reaction,
where the solubility of HC1 in the liquid is an important factor.
Alkaline solutions such as sodium hydroxide (NaOH) or occasionally sodium
carbonate (Na2C03) are used with water to neutralize the absorbed acid
gases in a packed bed scrubber. These two soluble alkali materials are
preferred because they minimize the possibility of scale formation. For
the case of using NaOH as the neutralizing agent, the HC1 and S02 col-
lected in the scrubber react with NaOH to produce sodium chloride (NaCl)
and sodium sulfite (Na2S03) in an aqueous solution.
(2) Operating Problems for Packed Bed Scrubbers
One common problem is partial or complete pluqqaqe of the bed due to
deposition of the solids collected and/or precipitation of solids formed
by reaction of the neutralizing agent with acid gases. Another problem
is settling of the packing material which leaves an opening at the top of
the packed section. Both of these situations reduce the performance of
the scrubber by disturbing the uniform flow of the liquid and gas
streams.
Another common problem occurs when the p_H of the scrubbing liquid rou-
tinely falls outside the normal range of 5.5 to 10. Corrosion and ero-
sion of the packed bed vessel, gas ducts, and piping can occur when the
scrubber liquid is not in the range for which the system was designed.
(A specific minimum pH is often set in permits to assure adequate
scrubbing capacity for acid gases and protection from corrosion damage.)
Maldistribution of the scrubber liquid is also a problem. Liquid mal-
distribution problems can be caused by misalignment or corrosion/abra-
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OSWER Olr. No. 9938.6
s1on/eros1on of the spray nozzles or perforated pipes used for liquid
distribution.
C-2-c. Ionizing Met Scrubber
(Note: Materials from EPA 1979, EPA 1982, and Cellcote were used In the
following discussion.)
(1) Operating Principles for Ionizing Wet Scrubbers
Several ionizing wet scrubber (IMS) systems have been installed on RCRA
Incinerators because the IWS offers both participate and gaseous pollut-
ant control. More installations of this emerging control technology are
in the planning and design review process. The IWS system consists of an
Ionizing section and a packed bed section. The ionizing section charges
the particles for subsequent collection in the packed bed section, which
1s located Immediately downstream of the ionizer. In addition to the
normal components of a packed bed scrubber, the principle components of
an IWS Include:
High voltage transformer-rectifier (T/R)
Automatic voltage controller
Ionizing wire-to-plate assembly
Continuous spray system for ionizer plates and packed bed
Intermittent spray system for ionizing wires
Figure 11-12 presents a cross-sectional view of a single IWS module.
The IWS was developed to remove fine solid and/or liquid participate down
to 0.05 v and less at low energy levels and high collection efficien-
cies. The IWS simultaneously removes acid gases from the process stream
as well as coarse particulates. The IWS incorporates advantages of elec-
trostatic precipltators and wet scrubbers within one device by combining
the principles of electrostatic particle charging, Image force attrac-
tion, agglomeration, and inertia! impaction to increase particulate col-
lection efficiencies in the submicron range.
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OSWER D1r. No. 9938.6
Packed Bed
for Particulate
Collection
Ionizer Elements
Particle Charging
Section
Recycle Pump
for Scrubbing Liquid
Figure 11-12. Cross-section of ionizing wet scrubber (IWS)
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OSWER Dir. No. 9938.6
A high voltage Ionizer section is utilized to charge particles in the gas
stream before entering a packed bed scrubbing section. Particulate
matter is removed by inertial impaction or by the attraction of charged
particulate to neutral packing surfaces within the wet scrubber section
of the IWS. The collected particulate and gases are removed continually
from the stream by a liquid scrubbing medium which flows vertically down
through the packing.
For applications with high concentrations of particulate and gaseous pol-
lutants, the IWS can be employed as a multistage unit to increase collec-
tion efficiency. Actual field, laboratory, and operating experience
indicate that two or three stages linked in series can solve most prob-
lems associated with submicron particulates requiring high collection
efficiency.
The high voltage ionizing section electrostatically charges particles in
the flue gas similar to an electrostatic precipitator. High voltage
levels on the order of 30,000 volts or 30 kilovolts (kV) are designed to
be delivered to the small diameter discharge wires to produce corona and
ionization. Particles in the gas stream become charged by the ioniza-
tion. Voltage levels in the range of 12 to 15 kV are necessary to ini-
tiate ionization and particle charging. Voltage levels below corona
initiation do not effect any particle charging. In order to sustain the
design performance levels, the manufacturer recommends that the IWS be
serviced sufficiently to maintain a minimum voltage level of 25 kV. For
a typical IWS unit, a reduction of 5 kV in the operating voltage level
could result in the emission level doubling. For example, if an IWS were
operating at 90% efficiency at full voltage, it would operate at 80%
efficiency if the voltage were to drop off by 5 kV.
Spray systems are an integral part of an IWS unit. A flow of scrubbing
liquid continuously cleans the plate surfaces to ensure adequate particle
charging. A second spray system periodically rinses the wire-and-plate
assembly, reducing the accumulation of residual solids. An adjustable
timer is set to momentarily interrupt the high voltage at intervals of
1 to 10 hr for rinsing. The packed bed cross flow scrubber also has
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continuous sprays, and such operation has been described in the previous
section on packed bed scrubbers.
(2) Operating Problems for Ionizing Wet Scrubbers
Common problems that reduce IWS performance are associated principally
with the wir"e-and-plate assembly and are described below. Problems asso-
ciated with the packed bed section are typical of those described in the
packed bed section previously discussed. According to the manufacturer,
the most common problems include improper alignment of the wire-and-plate
assembly, wire breakage, scale (or solids) accumulation on the wires and
plates, and scale accumulation on the high voltage insulators. The
recommended tolerance for maintaining the alignment or centering the
wires between the plates is 1/16 in. Each of the above problems reduce
the operating voltage level and/or increase the sparking rate and con-
sequently reduce the performance level of an IWS unit.
C-3. Dry Scrubbers
(Note: Materials from EPA 1987, Sedman, and Kroll were used in the
following discussion.)
Dry scrubbing is a general term referring to the dry residue resulting
from a scrubber process to absorb pollutants in industrial gas streams.
The three categories of dry scrubbers are: (1) a spray dryer absorber
involving the atomization of a wet slurry, (2) a completely dry system
involving the injection of a dry sorbent, and (3) a combination spray
dryer and dry injection system. This section will only describe the
spray dryer absorber process because it is the most common on hazardous
waste incinerators.
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OSWER Dir. No. 9938.6
The principle components of a spray dryer absorber include:
Reagent storage and feed equipment
Slaker, agitator, and heater
Mixing tank and feed tank
Atomizer feed tank and atomizers
Spray dryer absorber
Solids discharge tank
Pumps, valves, piping, and controllers
Instruments for pH, flow, pressure, and temperature
Figure 11-13 presents a flow diagram and the components of a spray dryer
absorber system.
C-3-a. Operating Principles for Dry Scrubbers
An alkaline reagent, normally pebble lime (or hydrated lime) is stored in
a silo and fed into a slaker where it is mixed with water to form a
slurry containing 25% solids by weight. A small HWI unit may use
hydrated lime to offset the high costs of the slaker. The slurry is then
further diluted with water to a level containing 5% to 20% solids prior
to being pumped to the atomizers.
There are two types of atomizers; (1) rotary atomizers, and (2) dual-
fluid nozzles. Rotary atomizers typically consist of a motor with a
step-up gearbox which provides the high rotational speed of 10,000 to
20,000 revolutions per minute (rpm) for the atomizer wheel. Centrifugal
forces atomize the slurry into droplets ranging from 30 to 100 pm in
diameter. Dual-fluid nozzles use 70 to 90 psig compressed air to atomize
the slurry into droplets ranging from 70 to 200 ym. The spray cloud pro-
duced by the nozzle is narrower than that produced by the rotary atomizer
and thereby requires a smaller diameter spray chamber. Figures 11-14 and
11-15 depict the rotary atomizer and dual-fluid nozzle designs,
respectively.
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Atomizer Feed Tank
PARTICULATE
CONTROL
DEVICE
SPRAY
DRYER
ABSORBER
Pump
KEY:
Tl = Temperature Indicator
Fl = Flow Indicator
P = Pressure
A = Amperage
ID = Induced Draft
Figure 11-13. Components of a spray dryer absorber system
(Semiwet process).
o
i/i
m
xO
u>
oo
•
a\
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OSWER 01r. No. 9938.6
VANE RING
GAS DISPERSER
10-12
SECONDS
ATOMIZER
GAS
SOLIDS
Figure 11-14. Rotary atomizer dryer.
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WET
SLURRY-
COMPRESSED
AIR
PARALLEL
FLOW
INDIVIDUAL MIXING
J
I Mfl/lM 1
/ / V V V I \
f f A It A 1 1
.NOZZLES
10-12
SECONDS
10-12
SECONDS
Figure 11-15. Dual-fluid nozzle dryers.
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The chamber where the slurry is atomized is called the spray dryer
absorber (SDA), spray dryer chamber, or spray dryer reactor. Flue gas
enters the SDA at temperature levels ranging from 450° to 2000°F. The
spray cloud produced in the SDA cools and humidifies the flue gas along
with absorbing the acid gases. Treated flue gas exits the SDA at
temperatures ranging from 250° to 400°F, which is typically 90° to 180°F
above the saturation temperature. A gas residence time in the SDA of 10
to 12 sec must be provided to allow acid gas to be absorbed into the
droplets. The chemical reactions involving the acid gases (HC1, S02) and
the lime-based slurry in the SDA are the following:
Ca(OH)2 + 2HC1 * CaCl2 + 2H20
Ca(OH)2 + SO2 * CaS03 + H20
Ca(OH)2 -i- CO2 * CaC03 + H20
Other halides (such as HF) if present are involved in similar reactions.
The SDA has a cyclonic design to remove the large particles or solids
entering or formed in the SDA. The dried solids are collected from
heated hoppers below the SDA and consist of calcium chloride (CaCl2),
unreacted lime, and incinerator fly ash. These residuals must be managed
as hazardous wastes if "derived from" the incineration of listed
hazardous wastes or if they exhibit any hazardous waste characteristics.
Some spray dryers have problems with incompletely dried particulate
sticking to the walls. Some spray dryers are designed to remove larger
particles by gravitational settling, thus reducing the likelihood of wet
particles sticking to the walls.
Spray dryer performance parameters involve several incinerator flue gas
characteristics, including:
Inlet gas temperature
Outlet gas temperature
Acid gas concentration (HC1, S02)
Moisture concentration
Particulate concentration
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Spray dryer operating conditions that can be considered performance
parameters include:
Reagent feed rate
Slaker (if any) exit temperature
Mixing tank discharge rate
Feed tank discharge rate, pressure, pH, solids content
Atomizer feed rate
Atomizer operating characteristics
• (dual-fluid no2zle)~air pressure and flow rate
• (rotary atomizer)—motor power and atomizer wheel speed (rpm)
Figure 11-16 presents a schematic of a slurry flow controller system
using incinerator load level and HC1 effluent concentration as feedback
signals.
A fabric filter system is typically installed downstream of the SDA. The
fabric filter collects the small entrained particulate exiting the SDA,
and provides some additional acid gas removal. The unreacted lime
entrained in the SOA exhaust stream forms part of the cake on the bag
surface, allowing an additional 15% to 20% of the acid gas to be removed
by the fabric filter. More information on fabric filters is presented in
the following section.
C-3-b. Operating Problems for Dry Scrubbers
Although little Information is available on operating problems of dry
scrubber on RCRA incinerators, some information has been compiled from
dry scrubber experience on municipal waste incinerators.
Scaling and pluggage of the slurry feed line to the atomizer have been
reported to be common problems. Severe scaling of the line occurs
because of the relatively high pH of the slurry. The liquid flow rate of
the slurry to the atomizer is monitored usually by a magnetic flowmeter
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LOAD BIAS
INPUT
FEEDBACK FROM
HCL ANALYZER
LIME SLURRY
FROM SURGE
TANK
AGfTATOR
DILUTION
WATER '
FT = FLOW TRANSMITTER
FIG = FLOW INDICATING
CONTROLLER
S.P. = SETPOINT
CO
OVERFLOW
TO SLURRY
TANK
DILUTION
TANK
FEEDBACK FROM
SDA OUTLET -
TEMPERATURE
CONTROLLER
DILUTED SLURRY
TO ATOMIZER '
S.P.
10
to
CO
00
•
eft
Figure 11-16. Slurry flow control system.
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OSWER D1r. No. 9938.6
or another type of an internal flowmeter such as an orifice. These
meters are also vulnerable to scaling since the flow sensing elements are
installed within the pipe. This problem can be reduced by designing the
lines to be (1) well sloped with a minimum number of sharp bends, (2) not
to be adjacent to high temperature equipment, and (3) capable of being
flushed conveniently after outages.
Both the rotary and dual-fluid nozzle atomization equipment use abrasion-
resistant, expensive, and replaceable inserts to withstand the wear
caused by the action of the high velocity slurry stream. The performance
of the atomizers and consequently the dry scrubber is sensitive to these
replaceable inserts.
Corrosion can eventually present major problems for dry scrubbers because
of the corrosive nature of calcium chloride and hydrogen chloride.
The lime and atomizer feed preparation systems handle slurries with high
solids concentration. Settling of the solids will eventually lead to
accumulation and pluggage of the handling equipment. In particular,
screens or strainers need to be checked and cleaned frequently to mini-
mize pluggage problems.
C-4. Fabric Filters
(Note: Materials from EPA 1982, EPA 1987, Sedman, Kroll, and Roeck were
used in this compilation of information on fabric filters.)
Fabric filters have been used on a limited number of hazardous waste
incinerators to control particulate matter emissions. Fabric filters are
being used as stand-alone air pollution control devices as well as down-
stream collectors following dry scrubbers. They have some advantages
over wet scrubbers in that they are highly efficient at removing fine
particles if they are properly operated and maintained. However, their
performance can deteriorate rapidly in situations where poor operation
and maintenance result in improper bag cleaning, bag blinding, bag corro-
sion, or bag erosion.
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Generally, fabric filters are classified by the type of cleaning mech-
anism that is used to remove the dust from the bags. The three types of
units are mechanical shakers, reverse air, and pulse jet. To date, most
hazardous waste incinerators that have been identified as having fabric
filters use pulse jet units. The paragraphs below briefly describe the
design and operating characteristics of pulse jet filters and identify
key design parameters.
C-4-a. Operating Principles for Fabric Filters
A schematic of a pulse jet filter is shown in Figure 11-17. Bags in the
baghouse compartment are supported internally by cages or rings. Bags
are held firmly in place at the top by clasps and have an enclosed bottom
(usually a metal cap). Dust-laden gas is filtered through the bag,
depositing dust on the outside surface of the bag. The deposited dust
forms a porous layering on the bag that is referred to as the dust cake
or filter cake. The bag acts as a support for the dust cake and allows
the dust cake to become the filtering medium.
The dust cake is removed from the bag by a blast of compressed air
injected into the top of the bag tube. The blast of high pressure air
stops the normal flow of air through the filter. The air blast develops
into a standing or shock wave that causes the bag to flex or expand as
the shock wave travels down the bag tube. As the bag flexes, the cake
fractures and deposited particles are discharged from the bag.
The blast of compressed air must be strong enough for the shock wave to
travel the length of the bag and shatter or crack the dust cake. Pulse
jet units use air supplies from a common header which typically feeds
Into a nozzle located above each bag. In most baghouse designs, a
venturi sealed at the top of each bag is used to create a large enough
pulse to travel down and up the bag. (Some baghouses operate with only
the compressed air manifold above each bag.) The pressures involved are
commonly between 60 and 100 psig.
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TUBE SHEET
CLEAN AIR PLENUM
PLENUM ACCESS
BLOW PIPE
INDUCED FLOW
TO CLEAN AIR OUTLET
AND EXHAUSTER
DIRTY AIR INLET & DIFFUSER
Figure 11-17. Pulse jet baghouse.
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Most pulse jet filters use bag tubes that are 10 to 15 cm (4 to 6 in) in
diameter. Typically, the bags are 3.0 to 3.7 m (10 to 12 ft) long, but
they can be as long as 7.6 m (25 ft). Generally, these bags are arranged
1n rows, and the bags are cleaned one row at a time in sequence. Clean-
Ing can be Initiated by a- bag pressure drop level, or it may occur on a
timed sequence.
C-4-b. Performance Parameters for a Fabric Filter
The key design performance parameters for a pulse jet filter are the air-
to-cloth ratio, the bag material, and gas temperature. The key operating
parameters include gas temperature, pressure drop, bag cleaning pressure,
and bag cleaning cycle.
The air-to-cloth ratio is actually a measure of the superficial gas
velocity through the filter medium. It 1s a ratio of the flow rate of
gas through the fabric filter to the area of the bags and is usually pre-
sented 1n units of acfm/ft2 or ft/min. Generally, the air-to-cloth ratio
on HWI units is in the range of 1 to 5 ft/min.
Bag material (various types of synthetic fibers, sometimes with special
coatings) generally is based on prior experience of the fabric filter
vendor from a similar application. Key factors that are considered
are: cleaning method, abrasiveness of the particulate matter and
abrasion resistance of the material, expected operating temperature,
potential chemical degradation problems, and cost. To date, little
Information has been obtained on types of material typically used for
hazardous waste incinerator applications.
The operating temperature range of the fabric filter is of critical
Importance for various reasons. Since the exhaust gas will contain mois-
ture and may contain HC1, the unit should be operated at sufficiently
high temperatures to assure that no surfaces drop below the water or acid
dew points. Condensation of water will cause a condition where the bags
are blinded by the wet particulate resulting in excessive pressure drop
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levels. Condensation of HC1 will result in corrosion of the housing or
bags, and may also cause bag blinding. Gas temperatures should be main-
tained at about 150°C (300°F) to ensure that no surfaces are cooled below
the dew point. The site-specific dew point is determined by the content
of H20, HC1, and S03 in the gas stream. Above a maximum temperature that
is dependent on filter type, bags will degrade or in some cases fail
completely. Gas temperatures should be kept safely below the allowed
maximum.
Pressure drop in fabric filters generally is maintained within a narrow
range. For pulse jet filters the typical range is 3 to 8 inches water
column (in w.c.). Pressure drops below the minimum indicate that
either: (1) leaks have developed, or (2) excessive cleaning is removing
the base cake from the bags. Either phenomena results in reduced per-
formance. Pressure drops greater than the maximum indicate that either
(1) bags are "blinding," or (2) excessive cake is building on the bags
because of insufficient cleaning. A problem that typically results from
excessive pressure drop is reduced flow through the system.
C-4-c. Operating Problems with Fabric Filters
The two main indicators of operational problems associated with fabric
filters are high opacity and high pressure drop. Well designed,
operated, and maintained fabric filters will generally have a very low
opacity (between 0% to 5%), and the pressure drop will fall within a
general operating range for the particular fabric filter type (3 to 8 in
w.c. for pulse jet fabric filters). Opacity and/or pressure drop
deviations from the trial burn levels are indicators of fabric filter
performance deterioration. Higher or lower than normal inlet tempera-
tures can cause opacity and pressure drop problems. The inlet tempera-
ture should be monitored continuously.
Although not specifically required by RCRA, opacity measurements can be
useful in determining trends in the performance of the fabric filter.
Opacity can be measured by an optical-based instrument installed across
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the stack. Typically, the opacity level of a properly operated and main-
tained filter will be very low, except when a condenslble plume Is
present during severe weather conditions. In general, high opacity is a
good indicator of fabric failure. A consistently elevated opacity level
1s- an Indication of major leaks and tears in the filter bags. A puffing,
Intermittent opacity observed after cleaning is a good indication of pin-
hole bag leaks or over-cleaning. The factors that cause fabric failure
Include Improper filter bag Installation, high temperature, chemical
degradation, and bag abrasion.
Internal inspection of the unit conducted by trained personnel will
clarify the nature of any major problems. Visual observations will
determine the occurrence of improper bag installations, pinhole leaks,
bag tears, bag blinding, and bag cleaning system anomalies. Use of
commercially available fluorescent dye and an ultraviolet light during
Internal inspections will identify the specific bags with pinhole leaks,
tears, and any seal leaks due to improper bag installation.
Improper installation of filter bags can result in leaks around seals,
Improper bag tensioning, and damage to the bags. Lack of training of
maintenance personnel in filter bag replacement and poor access to-the
fabric filter housing are contributing factors to improper installation.
High temperatures are the result of process malfunction(s) upstream of
the fabric filter. Therefore, in the fabric filter design phase, a fab-
ric must be chosen on the basis of expected temperature range with an
adequate margin of error. In general, high temperatures shorten bag life
considerably. High temperature breaks the polymer chains in most com-
mercially available fabrics causing loss of strength and reduced bag
life. High temperature attacks the finish on fiberglass bags causing
Increased bag abrasion. Temperatures that are high enough can cause
filter bags to ignite. Some installations have an alarm system to warn
of high temperature excursion or automatic waste cutoff required by the
operating permit to prevent damage to the filter bags. Inspectors should
verify 1n the facility's records that waste feed to the incinerator was
shut off during any period that the baghouse was bypassed because of high
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temperature excursion, and should note the number and circumstances of
any such bypasses.
Filter bag abrasion can be caused by contact between a bag and another
surface (e.g., another bag or the walls of the fabric filter) or by the
impact of higher-than-average gas volumes and particulate loading on the
bags. Bag abrasion can also be a problem when the fabric filter experi-
ences a high pressure drop.
Condensation of moisture on filter bags is caused by temperatures in the
fabric filter below the dew point and reduces the porosity of the filter
cake. "Mudding" or blinding of the bags increases the resistance to flow
and occurs because the cleaning system cannot remove the dust. Condensa-
tion can be prevented by preheating the fabric filter during the startup
operation and by purging moist gases from the unit prior to shutdown.
During operation it is critical to maintain the operating temperature
above the dew point of the gas stream at all times and in all localized
areas.
Cleaning system failures in pulse jet systems are usually the result of
worn or undersized compressors, moisture or oil contamination in the
pressurized lines, and failed solenoids and/or timers. Compressor prob-
lems are indicated by a low compressed-air pressure. Because of the low
pressure, the system cannot clean the bags properly. An increased pres-
sure drop across the fabric filter results due to dust cake buildup.
Compressor capacity may be a problem and should be checked against the
needs of other systems that the compressor serves. Routine preventive
maintenance can prevent premature failure of the compressor and can pre-
vent worn compressor seals from passing oil into the filter bags. Both
reduced compressed-air pressure and bag blinding can cause an increase in
pressure drop. Failure of solenoids and/or timers can prevent the filter
bags from being cleaned at all. These systems require clean, dry
mountings to operate properly. Solenoid failures affect the only row of
filter bags that the solenoid services, while timer failures tend to
affect most, if not all, of the fabric filter system.
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An additional problem is associated with the pulse pipe that discharges
the compressed air Into the bags. Pulse pipes may be damaged by the
force of the compressed air. Consequences are ineffective cleaning and
pressure drop increase, improper pipe alignment that may blow holes in
the filter bags, or a loose pipe that may damage the interior of the
fabric filter. The sound of a loose pulse pipe is unmistakable because
it moves whenever compressed air is fired into the pipe.
An increase 1n pressure drop may indicate operation and maintenance prob-
lems that may be corrected. However, blinded bags resulting from conden-
sation or the accidental discharge of compressor oil into the fabric
filter will likely have to be replaced. An increase in pressure drop can
be prevented by the following:
Preheat the fabric filter prior to process operation.
Purge the fabric filter of moist air prior to shutdown.
Always maintain the temperature of the gas entering the fabric filter
above its dew point.
Perform preventive maintenance of the compressor system and
solenoid/timer system.
Make necessary repairs to pulse pipes as required.
0. PROCESS AND EMISSIONS MONITORING INSTRUMENTATION
Proper operation of incinerators depends to a large extent on certain
operating parameters that are commonly used to monitor the process and/or
to provide automatic control of process parameters. Inspectors will
review the monitored values and will check the effectiveness of the
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monitors as important elements of an Incinerator Inspection. Basic
parameters include:
Temperature
Pressure
Oxygen
- CO
Waste feed rate
Combustion gas velocity and airflow
Other parameters are monitored depending on specific situations and
needs. (The importance of these parameters in indicating adequate
performance of an incinerator is discussed in Chapter III.)
RCRA incinerators are required to be equipped with a system to auto-
matically shut off the flow of waste feed into the incinerator whenever
certain key operating conditions (e.g., temperature, combustion, gas
velocity) deviate from allowable levels. The automatic waste feed cutoff
system includes sensing devices (for each key condition), transmitters
that send the signals (i.e., reading) from sensing devices: A receiver/
signal processor that evaluates the signals and sends a cutoff signal
when limits are exceeded; and a cutoff device (e.g., a switch, valve,
etc.) that effectively shuts down the flow of waste materials going into
the incinerator.
More information on automatic waste feed cutoff systems and the operating
parameters that trigger its use is presented in Chapters III and IV of
this manual.
These key parameters are listed below and accompanied by descriptions of
the typical instrumentation used to monitor/control them, and a brief
discussion of its proper use and operation.
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0-1. Temperature
Typically, thermocouples are used to monitor temperatures In the combus-
tion chambers and the air pollution control system. The thermocouples
are always enclosed In a thennowell to protect the small thermocouple
wires and the critical thermocouple junction from direct exposure to the
combustion gases and entrained dust particles. Thermocouples are usually
located near the exit of the combustion chamber in order to provide a
representative temperature reading away from the flame zone, which can
otherwise cause erratic temperature readings as well as damage to the
thermocouple. Generally, thermocouples also are located upstream from
the air pollution control system to provide a warning or control
mechanism for high temperature excursions that could damage control
equipment.
Although thermocouples typically are very reliable, they can fail or give
erroneous readings. For example, the thermocouple junction or wire may
break after long exposure to high temperatures; typically dual thermo-
couples are used in close proximity to one another in the incinerator
chamber to compensate for these failures. However, a thermocouple can
give erroneous readifigs for reasons that are not as obvious as a broken
junction or wire such as recrystallization or contamination of the wires.
Dual thermocouples allow a comparison of readings to identify a faulty
thermocouple. The second thermocouple enables continued monitoring of
temperatures while the faulty thermocouple is being checked or replaced.
Failure of a thermocouple junction would reault in automatic waste feed
cutoff because of a temperature signal that would be below the permitted
minimum temperature.
The best maintenance procedure for thermocouple is periodic replacement
and routine checking of the thermowell for physical integrity and any
outer dust buildup. Because it is not practical to perform a high tem-
perature calibration of the thermocouple, only periodic replacement
ensures a properly operating thermocouple is in place. Inspectors should
check to see if the thermocouples are periodically replaced.
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Close monitoring of temperatures is essential to good incinerator opera-
tion. It is necessary, therefore, to identify possible thermocouple
problems because the temperature signal is usually the primary measure-
ment used for automatic control of auxiliary fuel burners and combustion
air flow.
0-2. Pressure
Combustion chamber pressure values can be measured 1n units of gauge
static pressure, but it is actually a measure of the differential pres-
sure (AP) between the inside of the chamber and the outside air.
Monitoring of AP can be done with a common U-tube manometer, but for
incineration systems, a differential pressure transmitter typically is
used. All of these instruments use the same basic method to monitor
incinerator draft. One side (the high-pressure side) of the instrument
is always open to the ambient air; the other (low-pressure) side is
connected by tubing or piping to the incinerator.
These types of monitors also are used to measure differential pressure
across air pollution control systems. The low-pressure side is connected
to a pressure tap in the ductwork downstream from the control device, and
the high-pressure side is connected upstream from the control device.
A differential pressure transmitter contains a diaphragm with two tubes
connected on each side of the diaphragm; the diaphragm moves or deflects
as a result of changes in pressure. The transmitter is designed so that
any change or deflection causes a change in an electrical output signal
from the transmitter. The electrical signal is sent to the monitor in
the control room that indicates the incinerator pressure or the pressure
differential across the control system.
Faulty pressure readings can be caused by damage to the sensor or to
other components of the system. Transmitters used to measure AP are sen-
sitive devices that can be damaged by excessive vibration or sudden
shocks. The tubing and its connections may also experience problems such
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as pluggage due to the severe environmental conditions within the com-
bustor or ARC system. Over time, tubing or piping is degraded by sun-
light and temperature changes. This degradation leads to leakage, which
results in erroneous readings, and ultimately system failure. Specific
calibration requirements may be defined 1n a permit to address these
concerns, and inspectors should review these procedures to ascertain
whether the requirements are being met.
D-3. Oxygen Concentration
Although not required by RCRA regulations, many incinerators are equipped
with oxygen analyzers to monitor the oxygen concentration in the com-
bustion gases from the combustion chamber. In some incinerators, the
oxygen levels measured by the monitor are used to moderate air feed rates
to control of the combustion process. The data from the oxygen monitor
also can be used to continuously correct the CO concentration value (pro-
duced by a CO monitor) to a 7% oxygen basis.
Oxygen monitors, like the CO monitors discussed later, may be of two
types: in situ or extractive. In situ merely means that the analyzer's
sensor is mounted in direct contact with the gas stream. In an extrac-
tive system, the gas sample is continuously withdrawn (extracted) from
the gas stream and directed to the analyzer, which may be located from
several feet to several hundred feet away. The monitor point may be in
the stack, at the combustion chamber exit, or at other locations within
the process (e.g., duct between air pollution control system and the
stack). These two types of sampling system are illustrated in
Figure 11-18.
In Situ Oxygen Analyzers provide rapid response to changes in the
oxygen content of the gas because the sensor is in direct contact
with the gas stream. Most in situ oxygen analyzers are equipped with
connections so that zero gas (nitrogen) or calibration gas (air) can
be flushed through the permeation tube and in contact with the
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In-Situ
Extractive
Source
Stack
Probe
I
Sample
Transport
Figure 11-18. In situ versus extractive sampling systems.
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sensing element. Flushing provides a means of zeroing and spanning the
analyzer, and also creates reverse flow of gas through the permeable tube
that helps to remove dust particles that eventually will clog the tube
and slow the detector's response time. Even so, the tube periodically
must be removed for cleaning or replaced if warranted. Manufacturers
recommend that the sensing element be replaced after several months of
service.
Extractive Oxygen Analyzers continuously withdraw a sample of gas to
the actual analyzer and Include a "conditioning system" for removal
of water, dust, and sometimes other constituents that would interfere
with operation of the analyzer. An example extractive system is
Illustrated in Figure 11-19. Shown are the moisture knockout for
removal of water vapor and the normal connections for zeroing and
calibrating the analyzer. Calibration gas should be injected as
close as possible to the stack probe and at or very near atmospheric
pressure.
The Integrity of the sample line and the conditioning system is
crucial to obtaining a representative sample for accurate results.
Calibration is performed by zeroing with an inert gas such as nitro-
gen (N2) and checking span with a gas of known oxygen concentration.
Span values, calibration drift, etc., may be included as performance
specifications in the permit. Oxygen analyzers are highly accurate
as long as the actual gas to be sampled reaches the analyzer (i.e.,
no pluggage or in-leakage of air occurs), the conditioning system, is
operating properly, and the instrument is calibrated.
Problems with oxygen analyzer systems may be difficult to discern
since they commonly are associated with slowly developing pluggage in
the system or small air in-leaks. The extractive systems should be
checked daily by the operator, and maintained and calibrated on a
weekly basis by the incinerator instrument personnel. Requirements
are typically specified 1n the permit; inspectors will be reviewing
the facility's response to these requirements during the inspection.
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Filter — y
Secondary
Combustion r
, Chamber |
^^^^^^
Back Flush -r-Kh
Purge Air T y
Er-\
Quench
! \~
1 1 |*WJ Nitrogen
L L '
^ ^ t Sample
Sample R
KTODe p nuiwcM W
rex 1
"pi » Air Cooled
/ Condenser
/ —&—\
^-Solenoid 1 Drain
Valve
Line
nrvfir ^ Anilir
; : t
t i i
i i
i i
1 !
Ver
zer
1
Strip
Chart
Microprocessor
Zero
Span
Low Mid
Level Level
Calibration Calibration
Data Logger
Figure 11-19. Example extractive system.
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D-4. Carbon Monoxide
Continuous monitoring of carbon monoxide (CO) emissions is required by
RCRA regulations to ensure that proper combustion conditions are main-
tained and to minimize emissions of products of incomplete combustion.
Carbon monoxide analyzers typically are not part of the automatic process
control system, but they are tied to the automatic waste feed cutoff
system. In general, high CO levels indicate some other problem in the
process and its control system (e.g., feed rate or temperature); low CO
levels tend to indicate proper combustion conditions.
Location of the CO sampling point may vary, although it is most commonly
1n the stack or at the exit of the combustion chamber. As with oxygen
monitors, CO analyzers can be affected upstream in-leakage of air, but
the relative error is usually less than with oxygen monitors. The permit
will normally require that the CO reading be corrected to 7% oxygen so
that factors such as in-leakage will not affect the CO reading.
Carbon monoxide analyzers also may be in situ or extractive, but by far
the most common type is extractive.
In situ CO monitors use an infrared signal that is transmitted across the
duct or stack to a receiver or reflector on the opposite side. The
change in the signal is processed by the analyzer system, and an output
signal as an equivalent CO concentration is provided. In situ CO moni-
tors are difficult to calibrate directly because the duct cannot be
filled with a gas of known concentration. Therefore, calibration is per-
formed using an optical filter that can be moved into the signal path, or
a calibration gas that can be put through a separate cell through which
the infrared signal can be sent. In most cases, in situ systems are
installed in the stack after pollution control devices have removed most
of the particulate matter.
Much of the previous discussion on extractive oxygen systems also applied
to extractive CO systems. In fact, the same extraction/conditioning
system often is used for both monitors. With both gases, plugging or
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in-leakage of air into the sample line is a more likely cause of problems
than the analyzer itself. However, for extractive CO analyzers removal
of the water vapor is of more importance. Therefore, daily checks of the
conditioning system should be made by the operator, with weekly mainten-
ance and calibration by the instrument personnel. EPA has developed
draft performance specifications for CO and 02 monitors installed on
hazardous waste incinerators permitted under RCRA. These or other
specifications may be included in the permit. (Information is provided
in EPA 1989b.)
D-5. Waste Feed Rate
The waste feed rate to an incinerator can be monitored in a variety of
ways, depending upon the types of feeds encountered. The feeds may be
free-flowing liquids, gases, solids, or sludges.
D-5-a. Liquid Feeds
Typical flowmeters used to monitor the liquid waste feed rate to incin-
erators are detailed below. The five basic types include those that
(1) measure velocity or flow rate indirectly via measuring pressure
differential across a restriction (differential pressure meters),
(2) measure velocity (velocity meters), (3) measure mass flow, (4) posi-
tive displacement meters, and (5) level gauges.
Differential Pressure Meters
Rotameter—This type of flowmeter is available for a wide range
of liquid viscosities including some lightweight slurries. It
is calibrated through using a fluid of known density.
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Orifice meter—This instrument is used with gases and low-
viscosity fluids. It involves a hole in a thin, flat sheet or
plate which is used to create a pressure head difference.
Abrasive particles may erode the opening, and plugging may
constrict the opening. Both factors affect accuracy of the
meters.
Venturi meter—A venturi meter is similar to an orifice meter,
but uses a less severe obstruction in the shape of a converging
and diverging core.
Vortex shedding meter—This device is applicable to low-
viscosity fluids and gases under turbulent flow conditions.
Velocity Meters
Acoustic flowmeter—This meter uses a pair of transducers on
either side of a pipe to transmit and receive high-frequency
(ultrasonic) sound waves through the moving fluid. These
meters are more commonly used for aqueous wastes (wastewater)
than organic wastes.
Magnetic flowmeter—In this type of meter, electricity is gen-
erated by moving a conducting medium (waste) through a magnetic
field. The voltage generated is proportional to the velocity.
Problems include interference from entrained gases, fouling of
electrodes by "greasy" fluids, and electromagnetic interference
from nearby electrical equipment.
Mass flowmeter—This instrument, also known as a Coriolis flowmeter,
may be used with liquids of widely varying viscosity and density and
most slurries. A U-shape tube is vibrated in a twisting motion at
its natural frequency by a magnetic device. The amount of twist is
proportional to the mass flow rate of the fluid flowing through the
tube. The twist is measured by magnetic sensors and converted elec-
trically into a mass flow rate.
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Positive displacement meter—This type of flowmeter 1s highly
accurate for viscous fluids. It cannot be used with multiphase
liquids, gases, or slurries of varying density.
Level meters—Level gauges or meters may also be used to measure a
change in the tank volume or mass of its contents. This method
includes manual checks with a dipstick, and meter operating on
mechanical, ultrasonic, nuclear, or radio frequency principle.
D-5-b. Gaseous Feeds
The best types of flowmeters for gases are the orifice meter and the
vortex shedding meter, discussed above under liquid feeds.
D-5-c. Solid/Sludge Feeds
Commonly used flow meters are described below.
(1) Volumetric Methods
These methods include calibrated augers and pumps, rotary feeders, and
belt conveyors. Most of these methods are based on a tachometer signal
that indicates speed of the process equipment. This speed must be
related to feed rate by performing calibration tests. These systems are
generally calibrated by the user for each particular feed material.
(2) Level Indicators
This category encompasses a variety of methods based upon mechanical,
ultrasonic, nuclear, and radio frequency principles of operation.
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(3) Stationary Weight Indicators
These methods, which include weigh hoppers/bins and platform scales,
determine the dead weight of material loaded into a hopper, bin, or con-
tainer. After they are weighed, the contents are then batched into the
process.
(4) Conveyor Weighing Systems
These methods include belt weighers, weigh belts/augers, and loss-in-
weight feeders. All conveyor weighing systems are fairly similar in
operation, mainly differing because of placement locations of the
weighing device.
D-6. Combustion Gas Velocity and Airflow
Many incinerators include instrumentation to monitor the various input
air streams (e.g., primary air and secondary air). All are required to
have instrumentation for monitoring an indicator of the combustion gas
velocity. Several types of instruments may be used to monitor gas flow,
but the most common are pitot tubes or Annubar flowmeters (see Fig-
ures 11-20 and 11-21). Both of these monitors consist of two tubes in
the air stream: one faces into the gas stream and is subject to velocity
pressure; a second is used to measure static pressure of the gas in the
duct. The difference between these two pressures provides a measure of
the velocity or flow rate of the air in the duct.
A pitot tube provides velocity for only a single point in the gas stream.
To obtain a complete velocity profile, a traverse of the duct that pro-
vides velocity readings in a variety of locations over the cross-section
is required. An Annubar is a modified form of pitot tube designed to
simulate a full velocity traverse, both simultaneously and continuously.
The Annubar itself is a single tube which spans the entire duct. Holes
are spaced along it in the same pattern as a pitot traverse. Impact gas
enters the tube through these holes and mixes along the tube, thereby
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; i i I I I I I I I I I I I I I ! I 1 J
Low-pressure
side
Pilot-static tube.
Figure 11-20. Schematic of pitot-static tube.
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Downstream
Sensor
Upstream
Sensor
Figure 11-21. Schematic of Annubar.
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"averaging" the velocity pressure. As with pitot tubes, velocity is
determined by comparing velocity pressure with the duct's static
pressure. Calibration factors for pitot tubes and annubars can be
determined prior to installation in a wind tunnel. Indirect monitoring
of changes in the calibration factor of pitot tubes and annubars
installed in an incinerator duct can be accomplished by monitoring
pressure drop across the tubes. Potential problems with Annubars and
pitot tubes are corrosion and particulate buildup over extended usage.
Two other types of flowmeters may be used—orifice plates and venturi
tubes. Both types are again based upon measuring a differential pres-
sure. An orifice plate is a thin-walled plate inserted into a pipe to
constrict flow. Gas flow through an orifice in the plate of known
diameter. Pressure readings are taken from taps located on either side
of the plate. Comparison of the two pressures fixes the gas velocity as
determined by pressure drop across the orifice. Problems occur when par-
ticulate matter erodes the plate. In addition, careful calibration of
these devices is required for compressible fluids.
A venturi tube is a contracting flow tube with pressure taps straddling
the smallest part, or throat, of the tube. Comparison of these pressures
determines the flow rate through the tube. Overall, venturi tubes are
less susceptible to fouling and corrosion than the other gas flow rate
measurement method. Their accuracy depends primarily upon the pressure
device and the calibration procedures.
Combustion gas flow measurement is typically performed at either of two
locations: (1) between the combustion chamber and quench zone, or (2) in
the stack. Exact location within these areas is chosen on a site-by-site
basis according to availability of an adequate length of straight duct,
expected gas temperatures, and access to the location.
In some incinerators, the indicator of combustion gas velocity is based
upon an indirect monitoring method. Indirect methods may measure fan
rotational speed, current draw, or excess 02 levels.
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D-7. pH Measurements
As discussed in the air pollution control section of this chapter, the pH
of scrubbing liquid may be continuously monitored to allow control of
potential corrosion problems. There are two types of pH sensors:
Immersion (dip-type) and flow-through. The immersion sensor is merely
inserted into a tank and can be removed for maintenance and calibra-
tion. A flow-through sensor depends upon a continuous flow in the sample
line. The pH measurement probe consists of a pH measuring electrode, a
reference electrode, and a high input impedence meter.
Calibration of a pH monitoring system is performed through the use of
known pH buffer (reference) solutions. Typically, pH 7 is used for cali-
bration, although pH 4 and pH 10 may also be used, depending upon the
expected ranges of scrubber operation. For greatest accuracy, buffer
solutions should be selected that are close to expected pH values. Since
the pH monitoring system electrodes may become fouled over time by dirt,
particulates, and bacteria, calibration checks usually are necessary
every few weeks.
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CHAPTER III
REGULATIONS AND PERMITTING
INDEX
A. Introduction 111-2
B. Regulatory Overview III-3
B-l. Terminology III-3
B-2. Performance Standards III-4
B-3. Waste Characterization Requirements 111-6
B-4. Operating Limits III-6
B-5. Monitoring and Inspection III-7
B-6. Exemptions III-8
C. Permitting Overview 111-8
D. Typical Permit-Limited Parameters III-9
D-l. Minimum Temperature 111-10
D-2. Maximum Waste Feed Rate 111-10
D-3. Maximum CO 111-10
D-4. Maximum Flue Gas Flow Rate/Velocity 111-12
0-5. Maximum Size of Containerized Wastes 111-12
D-6. Operating Parameters for Air Pollution
Control Devices 111-12
D-7. Waste Limitations for A1r Pollution Control
Devices 111-12
D-8. Maximum Combustion Chamber Pressure 111-13
D-9. Maximum Total Heat Input 111-13
D-10. Burner Settings for Liquid Injection 111-13
D-ll. Incinerability Limits for Organics 111-14
D-12. Other Potential Control Parameters 111-14
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CHAPTER III
REGULATIONS AND PERMITTING
LEARNING OBJECTIVES
Provide an overview of hazardous waste Incinerator regulations and
the permitting process.
List and describe the types of waste and operating parameters that
may be selected (by the permit writer) as permit-limited conditions.
A. INTRODUCTION
The regulations and permitting activities discussed in this chapter are
directed toward hazardous waste incinerators operating under RCRA. The
term incinerator applies to those enclosed, controlled flame combustion
devices that do not meet the regulatory definition of boilers, and are
not listed as industrial furnaces. The incinerators addressed directly
by this manual tend to be permitted units, operated primarily to destroy
waste materials, using controlled flame combustion.
As of press time for this manual (early 1989), new regulations were being
developed by EPA to expand the range of controls applicable to incinera-
tors. This chapter incorporates some of the concepts expected to be pro-
posed in 1989; some of these concepts have already been incorporated into
newer permits to address RCRA's broad goals of protection of health and
environment.
An important fact for inspectors to remember is that the incinerator
permit establishes the enforceable limits. The incinerator regulations
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primarily serve as the blueprint for the contents of the permit. Con-
sequently, incinerator inspectors will be using the individual incinera-
tor permits as the basis for inspections. The primary group of incin-
eration-specific regulations under RCRA is provided in 40 CFR Part 264
Subpart 0 (final status), Part 265 (interim status), and Part 270
(permitting). Interim status is described in Chapter VI.
The overview of incinerator regulations and permitting in this chapter is
intended to provide useful background information to inspectors. The
descriptions of typical permit-limited parameters at the end of this
chapter can serve as a quick reference for understanding the intent of a
specific permit limitation. Inspectors are encouraged to develop a
detailed understanding of the existing regulations and any newly proposed
regulations.
B. REGULATORY OVERVIEW
RCRA incinerator regulations establish performance standards; require-
ments for waste characterization, operations, monitoring, and inspection;
and the mechanism for permitting.
B-1. Termi no1ogy
An Inspector should know these basic regulatory terms:
Appendix VIII Constituent—one of the compounds listed in
Appendix VIII (40 CFR 261).
POHCs (Principal Organic Hazardous Constituents)~designated organic
compounds used to measure the organic destruction performance of an
incinerator. POHCs may be either normally present in the waste or
added to it for testing purposes.
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ORE (Destruction and Removal Efficiency)—An efficiency value cal-
culated for POHCs by conducting a series of performance tests. The
calculation is a comparison of the input feed rate and stack emission
rate of a POHC, expressed as a percentage value.
Trial Burn—a detailed test program conducted to measure performance
and to characterize the operations of the incinerator.
Inspectors should also be familiar with the term PIC (Product of Incom-
plete Combustion). PIC is a nonregulatory term that includes any by-
product of combustion including such compounds as CO, unburned constit-
uents from the feed material; and any other compounds formed as a result
of the combustion process (e.g., an organic constituent not present in
the waste feed .material). Although not directly regulated at present
under RCRA, permits may contain limits on CO and/or total hydrocarbons in
order to minimize PIC emissions.
B-2. Performance Standards
The incinerator performance standards under RCRA (as of January 1989)
are:
Particulate emissions < 180 mg/Nm3 (0.08 grain/dscf) corrected to 1%
02 (264.343(c)).
HC1 emissions < 1.8 kg/hr (4 Ib/hr) or 1% of HC1 in stack gas prior
to control device, whichever is less stringent (264.343(b)).
- ORE > 99.99* for most wastes (264.343(a)(l)).
- ORE > 99.9999% for dioxin surrogate (264.343(a)(2)).
The particulate standard is similar to the standards established prior to
RCRA under national and local air pollution control programs for new
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municipal solid waste incinerators, boilers, and other combustion
units. In addition to limiting particulate emissions, the particulate
standard provides an indirect limitation of metal emissions, since many
of the metallic species released by an incinerator are emitted as
particulate.
The HC1 standard limits the emission of the acid which is formed as a by-
product of the incineration of chlorinated wastes. In addition, a risk-
based HC1 standard series is being developed (in 1989) to be used as a
site-specific check to address concerns that the existing standard does
not provide an adequate degree of protection in all cases.
The ORE standard is applied to the POHCs evaluated in the trial burn.
The stricter standard of 99.9999% ORE is applied to POHCs that serve as
dioxin surrogates in a trial burn for incinerators that will be permitted
to incinerate wastes containing dioxins.
Expected Changes in regulations include:
Limits on toxic metals (As, Be, Cd, Cr, Sb, Ba, Pb, Hg, Tl, Ag)
Site-specific risk-based check on HC1 to be used in conjunction with
present performance standard
100 ppm limit on CO, otherwise continous monitoring of total
hydrocarbons (THC). THC emissions should not exceed risk-based
limits and a good operating practice level of 20 ppm.
The limits on metals and HC1 under consideration are based on conserva-
tive risk-based screening limits. Limitations would be provided from a
chart for either (1) input limits of HC1 and the metals, (2) emission
limits for each constituent, or (3) limits based on the results of site-
specific modeling.
The CO limit would be based on a 60-minute rolling average (i.e., an
average of the most recent 60- one minute readings corrected to dry basis
and 7% oxygen). CO would be limited as an indicator of efficient com-
bustion and, indirectly, as an indicator of minimal formation of toxic
organic PICs. Monitoring of and limits on total hydrocarbons are being
considered as a method to allow a variance from the 100 ppm CO limit.
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EPA has determined that the permit writers must consider instituting the
controls for PICs (and metals) using the omnibus provisions of Sec-
tion 3005(c)(3) of RCRA.
Except for the CO limit and possibly the HC1 limit, these performance
standards cannot be monitored on a continuous basis. Therefore, permit
limits are established for various waste characteristics, operations, and
monitoring activities so that compliance with the performance standards
can be reasonably assured on a continuous basis. It is important to note
that, according to §264.343(d), compliance with the permit operating
conditions is deemed to be compliance with the performance standards.
B-3. Waste Characterization Requirements
The RCRA Part B application must include a waste analysis plan. Waste
materials fed to the incinerator must be characterized (264.341) in terms
of chemical composition (e.g., the presence of Appendix VIII constitu-
ents) and any other waste characteristic that is critical to the perfor-
mance of the incinerator such as chlorine content, heating value,
viscosity, volatiles content, and solids content. (The exact parameters
to be characterized and the minimum frequency of waste analysis are
specified on a case-by-case basis in each facility's permit.)
B-4. Operating Limits
The operating limits for each incinerator are specified in the facility's
permit. However, the following items are required specifically by RCRA
regulations:
During start-up or shut-down, hazardous wastes must not be fed to the
incinerator unless operating conditions are met (264.345(c)).
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Fugitive emissions from the combustion zone (I.e., gaseous leaks)
must be controlled (264.345(d)).
Incinerators must be equipped with automatic waste feed cutoff
systems that stop waste feed to the Incinerator when conditions
deviate from permitted limits for CO, waste feed rate, temperature,
and combustion gas velocity indicator (264.345(e)). (Mote: the
permit writer may add other limiting parameters for this system in
the permit.)
Incinerators must not operate with hazardous wastes when any limits
in the permit are exceeded (264.345).
B-5. Monitoring and Inspection
Although specific instructions for monitoring and inspection (by the
operator) are listed in the permit, the following items are required
specifically by RCRA regulations:
Continuous monitoring of CO, combustion temperature, waste feed rate,
and an appropriate indicator of combustion gas velocity (264.347(a))
(additional parameters may be specified in the permit).
Daily inspections of incinerators for leaks, spills, etc.
(264.347(b)).
Weekly (or monthly) testing of automatic waste feed cutoff systems
and associated alarms (264.347(c)).
Monitoring and inspection data must be recorded in an operating log
(264.347(d)).
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B-6. Exemptions
The RCRA regulations (264.340(b)) provide an exemption from all
264 Subpart 0 requirements (except waste analysis and closure) for
Incinerators that receive hazardous wastes that are not toxic. These
wastes:
Are listed or classified as hazardous wastes solely because they
possess the characteristics of 1gnitab1lity, corrosivlty, and/or
reactivity.
If reactive, do not generate toxic gases.
Do not contain Appendix VIII constituents.
Incinerators which meet the first criterion and contain Appendix VIII
constituents, but at levels which are insignificant, may be similarly
exempted by the Regional Administrator under §264.340(c).
Incinerators qualifying for this exemption must be permitted under the
requirements of Part 270.
C. PERMITTING OVERVIEW
The major steps of the permitting process for hazardous waste incin-
erators typically include (in chronological order):
Submittal, review, and approval of the Part B permit application
(including trial burn plan).
Issuance of permit (for new facilities).
Completion and approval of trial burn (test and results).
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Issuance of permit (for existing facilities) or modification of
permit (based on results of trial burn for new facility).
The permitting of an incinerator is a very detailed and time-consuming
process for both the applicant and the assigned permit writer. In addi-
tion to the typical facility requirements for a RCRA Part B application
(e.g., facility descriptions, contingency, closure, training, etc.), an
incinerator application must contain (according to 270.19):
A detailed engineering description of the facility.
Specific information about facility operations, monitoring
procedures, and shut-down procedures.
A sufficiently detailed trial burn plan that (1) addresses all
sampling, analysis, and monitoring issues and (2) establishes the
basis for future operations.
Before issuing a permit, the permit writer must become well-versed on all
aspects of an incinerator facility, using the RCRA regulations, EPA
guidance (see Appendix 4 for a list of applicable guidance manuals),
available assistance from EPA sources or consultants, and best engineer-
ing judgment. The goal is a permit that is enforceable (e.g., specific,
clear, and comprehensive). A permit is written to ensure that the
performance standards will be met on a continuous basis (without
unnecessarily constraining operations).
D. TYPICAL PERMIT-LIMITED PARAMETERS
The allowable operating conditions of an incinerator are defined in a
permit in terms of reliably measured control parameters (e.g., tempera-
tures, pressures, flows, etc.). These control parameters are especially
important, since all of the RCRA performance standards (e.g., ORE and
particulate emissions) cannot be measured directly on a continuous basis
during normal operations.
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This section serves as a glossary of common control parameters that are
frequently included in a permit as a limiting condition to be monitored
continuously. (A draft model of the incinerator-specific parts of a RCRA
permit is presented in Appendix C.) The list of common parameters (sum-
marized in Table III-l and described in the following pages) is based on
1989 EPA guidance (EPA 1989a). Other parameters may be used in permits
due to unique needs or new guidance issues. Additional information is
provided in EPA, 1989a.
D-l. Minimum Temperature
Temperature often is considered to be the primary driving force in
incineration. The minimum temperature is usually the lowest mean
temperature that resulted in a successful trial burn test. Minimum
temperatures are specified for both primary and secondary combustion
chambers.
D-2. Maximum Waste Feed Rate
Limiting the waste feed rate to a rate proven during a trial burn tends
to (1) prevent a reduction in incinerator performance due to overloading
the combustion chamber, (2) keep residence time above the minimum level
required to destroy organic constituents, (3) limit the heat released per
unit volume, and (4) limit the ash and chlorine feed rates when used in
conjunction with limits on the ash and chloride content in the waste feed
in order to limit emissions of particulate and HC1.
D-3. Maximum CO
CO serves as an indicator of good combustion. By minimizing the emission
of CO, operators tend to minimize the potential emission of organic
products of incomplete combustion. Correcting the value to 7% oxygen
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Table III-l. TYPICAL CONTROL PARAMETERS FOR HAZARDOUS WASTE INCINERATORS
Parameters Related to Waste Destruction
Minimum temperature at each combustion chamber exit
Maximum feed rate of each waste stream to each combustion chamber
Maximum CO emissions
Maximum flue gas flow rate or velocity
Maximum size of containerized waste to primary chamber
Parameters for Air Pollution Control Devices
Minimum pressure drop for venturi scrubber
Minimum water flow rate (or liquid-to-gas ratio) and pH to absorber
Minimum/maximum nozzle pressure to scrubber
Minimum water/alkaline reagent flow to dry scrubber
Minimum particulate scrubber blowdown rate
Minimum KVA for Electrostatic Precipitator and KV for ionizing wet
scrubber (IWS)
Minimum liquid flow rate to IWS
Minimum and maximum pressure drop for baghouse
Maximum inlet gas temperature to air pollution control device
Maximum chloride and ash input 1n waste feed
Additional Parameters Based on Test Results or Design Limitations
Maximum pressure in primary and secondary combustion chambers
Maximum total heat input for each chamber
Liquid injection burner settings
viscosity (maximum)
turndown (maximum)
atornization pressure (minimum)
waste heating value (minimum)
solids (suspended solids, particle size) (maximum)
Incinerability limits for organics
Adapted from EPA 1989a.
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normalizes the data to a common base, recognizing the variation In
different combustion technologies and modes of operation.
D-4. Maximum Flue Gas Flow Rate/Velocity
Maximum limits for the selected indicator of gas velocity (e.g., flue gas
flow rate, etc.) tends to control (1) gas residence time in each chamber,
(2) gas throughput to minimize back pressure at joints and seals, and
(3) gas flow rate through air pollution control devices to assure that
they are not overloaded.
D-5. Maximum Size of Containerized Wastes
The size of containers is limited to minimize the effects of "puffing"
(a sudden release of heat and gas from a bursting drum). Releases from
oversized containers may temporarily overwhelm an incinerator's gas
handling system. The loading rate of volatile organic material may also
be limited to minimize puffing.
0-6. Operating Parameters for Air Pollution Control Devices
Most of the parameters listed on Table III-l for air pollution control
devices were described in Chapter II of this manual. The parameters in
the table reflect basic monitoring needs for each of the devices; the
needs at a specific facility for demonstrating adequate performance in
controlling particulate and HC1 emissions may justify permit limits and
continuous monitoring of additional key control parameters.
D-7. Haste Limitations for Air Pollution Control Devices
The Input rates of ash and chlorides (or halides) to an incinerator are
normally limited in the permit to a level that is justified by the trial
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burn results. These levels limit the potential for violating particulate
and HC1 emission standards.
D-8. Maximum Combustion Chamber Pressure
The draft or pressure in the chambers of an incinerator is limited 1n
order to minimize the release of partially burned organics or other
products of combustion as fugitive emissions from the primary combustion
chamber. Limits may be expressed for (1) incinerators designed to oper-
ate under positive pressure or (2) for negative pressure incinerators
(which rely on draft to control fugitive emissions).
D-9. Maximum Total Heat Input
The total heat input to an incinerator may be limited in a permit to pre-
vent operation outside of manufacturer design specifications.
D-10. Burner Settings for Liquid Injection
The burner operational settings for liquid injection should be within the
manufacturers design and operating specifications. The settings relate
to proper atomization of liquid waste and efficient mixing. Operating
above a maximum viscosity (of pumped waste), below a minimum atomization
fluid pressure, or above a maximum turndown (burner turndown is a ratio
of design burner flow rate to actual burner flow rate) may not allow
proper atomization and mixing. A minimum waste heating value may be
specified when a given waste provides 100% of the heat input to a given
combustion chamber. Maximum suspended solids and maximum particle size
may also be limited within the manufacturers design specifications.
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D-ll. Indnerab111ty Units for Organlcs
Limits are placed 1n the permit concerning the organic constituents that
can be fed to an Incinerator. Limits are based on 1nc1nerability hier-
archies, as described on page IV-22.
D-12. Other Potential Control Parameters
Some permits may 11st limits for minimum oxygen concentration, maximum
kiln speed, or other parameters based on unique needs.
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CHAPTER IV
INSPECTION OF INCINERATORS
INDEX
A. Introduction IV-2
B. Preparing for Incinerator Inspection IV-4
B-l. Preliminary Essential Steps IV-4
B-2. Making Arrangements IV-5
B-3. Obtaining Materials IV-7
B-4. Safety IV-7
B-5. Summary IV-8
C. The In-Depth Inspection IV-8
C-l. Listing Basic Information IV-10
C-2. Comparing Permit and Operating Conditions IV-10
C-3. Identifying Limiting Conditions IV-13
C-4. Logging Key Operating Parameters IV-13
C-5. Collecting Monitored Data on the Checklist IV-19
C-6. Collecting Waste Characterization Information... IV-21
C-7. Variations in Approach to Data Gathering IV-25
C-8. Visual Assessment IV-28
C-9. Auditing and Reviewing Documentation IV-33
C-10. Summary of an In-Depth Inspection IV-42
D. The Walk-Through Inspection IV-42
D-l. Listing Basic Information IV-44
D-2. Comparing Permit and Operating Conditions IV-45
D-3. Visual Assessment IV-46
D-4. Quick Audit of Performance IV-46
D-5. Summary of the Walk-Through Inspection IV-48
E. The Inspection Report IV-48
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CHAPTER IV
INSPECTION OF INCINERATORS
LEARNING OBJECTIVES
Describe the objectives of an on-site Inspection of a hazardous waste
incinerator.
Identify the activities to be completed by the inspector before the
inspection.-
Establish priorities via a checklist of the activities to be com-
pleted on site during the inspection.
Describe appropriate documentation of inspection activities.
A. INTRODUCTION
The only direct method of verifying the adequacy of the performance of a
hazardous waste incinerator is by conducting complex sampling and analy-
sis tests. However, the cost of such tests is typically quite high •
($30,000 to $100,000 or more), which makes frequent scheduled or
unscheduled compliance testing problematic. Such tests involve simul-
taneous sampling of waste feeds and stack emissions and several types of
analyses of the collected samples (a repeat of the "trial burn" testing
required to obtain a permit). Consequently, even if frequent testing
were feasible costwise, the complexity of planning and conducting the
tests and evaluating data from them makes short-term determination of
"real performance" impossible.
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As a workable alternative, an indirect method of verifying adequate per-
formance is used. The RCRA permitting program defines the adequate per-
formance of a permitted incinerator in terms of specific monitored
operating limitations that can be verified by an Inspector. In develop-
ing the permit, the RCRA permit writer establishes an "operating window"
of allowable operating conditions based on the results of trial burn
tests. By definition, operation of the incinerator within the permitted
operating window is equivalent to meeting the performance standards
required by RCRA. The window is defined by an appropriate combination of
parameters selected from a list such as the one shown 1n Table III-l.
The role of the inspector is to assess the performance of an incinerator
by comparing actual operations with permit conditions (i.e., the set of
limitations established in the permit). To make this comparison, Inspec-
tors will focus on the following types of activities:
Noting observable operating standards and conditions
Reviewing records
Making calculation checks
Conducting operational checks
Incinerator inspectors will use their limited time on site to log
readings of key operating parameters from screens, meters, and charts;
review waste characterization records; test automatic waste feed cutoff
systems; observe calibrations of key monitoring equipment; visually
assess operations, performance, and safety; and review operating
records. Advance preparation is essential because each incinerator (and
each incinerator permit) is unique.
Priorities for the inspection are established by the definitions of
"in-depth" and "walk-through" inspections and the checklists that
identify the objectives of these inspections.
The in-depth incinerator inspection typically involves 1 to 5 person-days
of effort (possibly a combination of on-site data gathering/investigation
and follow-up data analysis in the Agency office). This Inspection may
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be a stand-alone event or part of a more extensive, facility-wide
inspection. An in-depth inspection may include a significant effort in
evaluating records of past operations and auditing key instrumentation.
As a shorter alternative to the in-depth inspection, the walk-through
Incinerator inspection involves only 4 to 8 person-hours of inspection
time on site. The actual time needed depends on the type (commercial or
on-s1te industrial) and number of incinerators at the facility. The
walk-through incineration inspection can be a stand-alone event or part
of a more extensive facility-wide inspection.
The activities of these two types of inspections are outlined in a set of
checklists (Appendix A) and are discussed in this chapter.
The remaining sections of this chapter address the efforts involved in
planning, completing, and documenting incinerator inspections.
B. PREPARING FOR INCINERATOR INSPECTION
B-l. Preliminary Essential Steps
The key step in preparing for the inspection is to understand the limita-
tions established in the incinerator permit. Since compliance with the
operating conditions specified in the permit is regarded as compliance
with RCRA performance standards, the permit itself establishes the
criteria for the inspection.
Before going on site, the inspector must review and understand the per-
mit. Feel free to contact the permit writer or other appropriate Agency
staff to discuss any permit conditions that are unclear. In addition, if
time is available, a review of the permit application will provide addi-
tional background on the layout, design, and planned operating objectives
of the incineration facility. A review of past inspection reports (if
applicable) is necessary to provide additional background information.
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Check the enforcement files to Identify any current or past problems. If
available, waste manifest records will provide an additional preview of
the facility's operations.
Prior to inspection, a checklist should be prepared. The checklist pro-
vided in Appendix 1 provides a template; the requirements of a particular
facility's permit are added to the template checklist to produce a site-
specific checklist that identifies all of the permit limitations to be
verified during an inspection. (Development of the checklist is dis-
cussed in more detail later in this chapter.)
Ideally, the site-specific checklist will be prepared initially so that
it can be used in any subsequent inspection. The checklist can be pre-
pared by the permit writer (at the time of permit issuance) or by inspec-
tion staff (prior to the first inspection trip). Subsequent use of the
checklist will require only a check of any permit modifications imple-
mented since the most recent use of the checklist. Such a system mini-
mizes the time needed in preparing checklists for future inspections but
guarantees the completeness and accuracy of the checklist. State and EPA
personnel should develop a procedure for preparing checklists for
incinerators located in their region or state.
B-2. Making Arrangements
Arrangements to be made prior to the on-site inspection include a travel
itinerary, directions to the site, and related practical and procedural
activities as described in the RCRA Inspection Manual. However, addi-
tional special needs for an incinerator inspection may include discussing
planned activities in advance with facility staff, making any necessary
laboratory arrangements, and 1n some cases, obtaining data in advance.
If the Inspection is not a surprise inspection, advance discussion with
facility representatives concerning certain elements of the inspection
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will allow a more efficient use of the inspector's time on site. Con-
sider the following three examples:
a. The testing of the automatic waste feed cutoff systems by the
inspector can seriously interrupt operations at some facilities;
advance scheduling of this activity will allow operating staff to
plan accordingly and reduce untimely delays during the inspec-
tion.
b. Contacting the facility to determine when the incinerator will be
operating can minimize the possibility that the unit will be down
for scheduled maintenance or that a facility with limited incin-
eration needs will not have wastes needing treatment.
c. Instrument calibrations are typically performed by specialty
staff who may be available only at certain times; advance
scheduling can guarantee the availability of appropriate staff.
d. Data gathering will typically require conversations with managers
and laboratory staff who maintain records needed for review
during the inspection. Again, advance discussions with the
facility contact person will guarantee the availability of the
appropriate staff and the needed information.
However, some trade-offs are involved with preliminary notice. Although
appropriate staff and records will be available, equipment may be operat-
ing in an artificial mode with premium wastes. Problem equipment may be
shut down for the scheduled inspection. Whereas, a surprise inspection
may give the inspector a first-hand view of normal or representative
operations. Records not immediately available could be mailed to the
inspector. The inspector could take advantage of shutdown equipment by
inspecting the refractory or other areas which are inaccessible during
operation. State and regional personnel should determine what mix of
surprise and planned inspections is necessary to evaluate compliance with
permit conditions.
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If the scope of the inspections includes sample analysis, the inspector
should make advance arrangements with the Agency or contract laboratory.
As an optional activity, an inspector may ask for the advance submittal
of selected records (e.g., waste feed characterization, operation logs,
etc.) allowing the inspector to review selected information before
visiting the site. This tactic may be useful if the inspector's avail-
able time on site will be very limited or if a public complaint is being
investigated.
B-3. Obtaining Materials
An inspector may need to bring certain materials/supplies to the site,
such as safety equipment, audit materials (e.g., standard gas), and if
appropriate, check samples to be analyzed by the plant or containers for
bringing split samples back to the Agency or contract lab. Any special
needs for safety equipment should be discussed in advance with the
facility contact.
B-4. Safety
Although this manual does not address the safety issues involved with
inspections, inspectors should note that the traditional safety precau-
tions applied by EPA staff at hazardous waste sites definitely apply to
hazardous waste incinerators. Apply the procedures and policies pre-
sented in the safety training classes that are required for RCRA inspec-
tors. In addition, be alert to possible hot surfaces, hot ash and
residual liquors, liquids under pressure, and corrosive liquids. Main-
tain a strict hands-off policy (e.g., do not attempt to adjust valves or
controls yourself; ask facility staff if adjustments are needed).
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B-5. Summary
The importance of advanced preparation for an incinerator inspection
cannot be overemphasized. Table IV-1 summarizes the specific needs for
preparation.
C. THE IN-DEPTH INSPECTION
As implied by the name, an in-depth inspection is a very thorough evalua-
tion of an incinerator, incorporating such key activities as:
Detailed evaluation of operating conditions.
Observation of activities.
Audit of instrumentation.
Review and spot check of records.
All of these activities have a direct purpose. The inspector's detailed
evaluation of operating conditions provides a direct comparison of actual
operations with permit limitations. The observation of activities
includes a check of general facility conditions and the effectiveness of
the RCRA-required inspections that are conducted daily by the operator.
An audit of instrumentation checks the adequacy of key monitoring instru-
ments. A review of records provides both a check of compliance with
record-keeping requirements and a spot-check of past operations.
An in-depth inspection will require 1 to 5 person-days of on-site
inspection depending on the complexity of the facility's operations and
the needs of the Agency. A team of inspectors could perform an in-depth
inspection in 1 to 2 days. The time needed to inspect a commercial
incinerator that handles a variety of waste streams is significantly
longer than the time needed for an on-site industrial incinerator that
incinerates a limited number of waste streams.
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Table IV-1. PREPARATION FOR INCINERATOR INSPECTIONS
Preliminary:
1. Review and Understand Permit
2. Review Incinerator Descriptions in the Permit Application
3. Review Past Inspection Reports, if any
4. Prepare Checklist ("walk-through" or "in-depth") (fill in permit con-
ditions and essential information)
5. Review Enforcement File
6. Check Waste Manifest Records
Make Arrangements (as applicable);
1. Travel Arrangements and Directions to Site
2. Discuss Needs With Plant Including:
a. Scheduling of Cutoff System Tests (impacts plant operations)
b. Scheduling of Instrument Calibrations (availability of
appropriate staff)
c. Scheduling of Meetings With Managers and Laboratory Staff
3. Arrangements for Sample Collection and Laboratory Analysis
4. Ask for Advance Data (optional)
Obtain:
1. Safety Equipment
2. Audit Materials (standard gas, etc.)
3. Check Samples or Containers for Sample Splits
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The following pages describe the activities to be completed during an
in-depth inspection. The checklist package for an in-depth inspection is
contained in Appendix A and outlines the activities and priorities to be
incorporated into each in-depth incinerator inspection. Example pages of
the in-depth checklist are presented on the following pages accompanied
by a description of the activities.
C-l. Listing Basic Information
Before visiting the site, the inspector will document basic information
concerning the facility, the incinerator(s), the permit, and past records
on a checklist sheet as shown in Table IV-2.
Another useful piece of background information is a simple process flow
diagram of the types and arrangement of major equipment in the incinera-
tor. An example is shown in Figure IV-1. The diagram may be available
in the permit application or may need to be developed by the inspector,
either in advance from information in the permit application or during
the inspection based on field observations. Such a diagram is often
useful in planning, implementing, and documenting the inspection and
subsequent inspections. The diagram should be attached to the checklist
package.
C-2. Comparing Permit and Operating Conditions
A major part of each incinerator inspection is a comparison of actual
operating conditions with the limitations established in the permit. The
inspector will (1) evaluate actual operations at the time of the visit by
reading the various gauges, charts, and screens used to monitor key
parameters and (2) review recent and past operations by reading logs,
strip charts, and any other recorded information concerning key operating
parameters.
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Table IV-2. EXAMPLE CHECKLIST PAGE: ESSENTIAL INFORMATION
RCRA INCINERATOR INSPECTION
CHECKLIST NO. 1—PERMIT AND OPERATING CONDITIONS
I. ESSENTIAL INFORMATION
Facility EPA 10 No.
Address Facility Staff
Involved (and
Position)
Primary Contact
Phone No.
Names of Inspectors
(and Office)
Dates of Visit
Time of Arrival
Indnerator(s) Inspected
Permit Identification and Date of Issue
(Date of most recent modification _
Operational Status of Inclnerator(s)
Date of Last Inspection
(by State
(by EPA
Pending Enforcement Action
Previous Violations
Checklists Attached: No. 1 (number of sets )
No. 2
No. 3
(Attach additional pages If necessary)
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p
s
F
S
ackaged
olids
Kiln
eed from
olvent Tanks
Quench
Venturi
Scrubber
1
Packed Bed
Scrubber
Demister
I
Stack
Figure IV-1. Example of a simplified process flow diagram.
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C-3. Identifying Limiting Conditions
Since the permit itself establishes the criteria for the inspection, the
inspector needs to identify in advance all of the appropriate limiting
conditions to be verified during the Inspection.
Unless a complete inspection checklist has been prepared previously (by
the permit writer or for a previous inspection), the inspector will need
to prepare a checklist based on the permit before conducting the inspec-
tion. This will involve filling in the blanks of the checklist (in
Appendix A) for any limiting condition specified in the permit. For
example, Table IV-3 1s a checklist page indicating permitted limits for
minimum primary chamber temperature, maximum CO concentration, and maxi-
mum flue gas flow rate. All checklist pages are to be completed
accordingly.
Limiting parameters in an incinerator permit will vary with the specifics
of each individual facility. The checklist package (in Appendix A) is
designed to Incorporate a wide variety of possible permit limitations,
although all the possible limitations will not apply to any single
facility. Extra spaces are provided for any additional permit-limited
parameters. The inspector incorporates Into the checklist only the
parameters with limitations stated in the permit.
Having prepared the checklist in advance, the inspector is prepared to
visit the incinerator site to gather information on present, recent, and
past operations.
C-4. Logging Key Operating Parameters
After arriving on site and holding introductory discussions with facility
contacts, the inspector should visit the incinerator control area for an
initial logging of key operating parameters (i.e., the operating
parameters limited as permit conditions). The observed values (and units)
are recorded on the checklist.
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Table IV-3.
EXAMPLE CHECKLIST PAGE: PERMIT OPERATING PARAMETERS
(WITH PRELIMINARY INFORMATION INCLUDED)
10 I
Oate
II. COMPARISON OF PERMIT AND OPERATING CONDITIONS
Date
Time Readings Began
Time Readings Ended
A. Permit Operating Parameters
1. Temperature measured at each
combustion chamber exit
a. Primary
b. Secondary
c.
d.
Permitted
Maximum
(units)
NA
NA
NA
NA
Permitted Observed
Minimum Reading(s) Calculated
(units) (units) Value
Koo'P
NA
NA
NA
NA
2. CO emissions measured at
the stack or other appro-
priate location
(location: STACK. )
• Does CO monitor automatically correct all readings to 7% 02 based on
actual Oz stack concentration? yes no
If no, does permit require 02 correction?
the correction factor to be used?
Date correction factor last determined
changes made In 02 correction factor.
If so, list It.
Does permit specify
Describe any
Permit-specified frequency for verifying 02 correction factor
• If a 60-m1nute rolling average Is required, does the observed reading
reflect a 60-m1hute rolling average?
no not applicable
If no, attach data and calculate the average.
3. 0, emissions (location):
4. Flue gas flow rate or
velocity measured at stack
or equivalent method:
ftT6V>TQP )
-o.so
|UCH«5
VJ.C.
NA
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The key operating parameters typically are:
Measured by instruments
Monitored by gauges, screens, etc.
Recorded in logs (manual and/or automatic)
Recorded continuously by strip charts
The permit writer selected the appropriate parameters to monitor based on
the specifics of the facility, the results of the trial burn test, EPA
guidance, and best engineering judgment. The permit writer's review and
approval of monitoring instrumentation included consideration of require-
ments for:
Technique/type
Specifications
Location
Data recording
Calibration
As a follow-up to the requirements established by the permit writer, the
inspector's activities include:
Logging the readings from gauges, charts, and screens.
Reviewing logs and strip charts.
Evaluating the accuracy/precision of some of the instruments.
Noting the replacement or modifications of any instrument.
(The last two items will be discussed later in this chapter.)
Although some older or smaller incinerator models may be operated from
control panels adjacent to the incinerator or from controls mounted on
the incinerator, most hazardous waste incinerators are operated and moni-
tored in a remote control room. Computerized control rooms, which are
gaining popularity, provide computerized set points for operation;
automatically record operating logs; and display a variety of operating
IV-15
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readings, trends, and data compilations on monitoring screens for the
operators. Less sophisticated incinerator control rooms provide infor-
mation to the operator on gauges, digital or analog readouts, meters, and
charts, and rely on manually operated switches for control of the
process. At most incinerators, inspectors can read values for permit-
limited parameters at two locations in the control room—from a readout
(digital or gauge) and from a data recording system (strip chart or
computer system).
Regardless of the type of monitoring station, the inspector must exercise
certain precautions in documenting the observed values of key operating
parameters on the checklist. Major precautions include the following:
Verify with the facility operator the exact identification of the
parameter and location of the sensor (e.g., combustion gas tempera-
ture at the exit of the primary combustion chamber) before listing a
value on your checklist. A parameter may have a similar name as the
permit-limited parameter or may be measured in multiple locations;
the permit should provide exact identification of the parameter and
sensor location.
Verify with the facility operator the units of each parameter. Be
sure to note correction factors if applicable. Often a correction
factor or multiplier factor may be taped to a meter or control
panel, e.g., "Reading x 0.357 = CFM." Strip charts may log values
as a percentage of full scale.
Note that plant operators may view different parameters as "key"
parameters for their purposes (e.g., fuel usage, excess air,
draft). These parameters may be different from the parameters
limited in the permit. It is possible that an operator may not be
familiar with a specific parameter that is limited by the permit.
For computerized logs and readouts, note the format of any readings
(e.g., instantaneous readings vs. time-averaged readings). Most
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permit limitations are based on instantaneous readings with specifi-
cation of any allowable time lags. However, certain permit limits
(e.g., CO) may incorporate a rolling average (e.g., an average of
the previous sixty 1-minute readings).
Readings from integrators require multiple readings to determine a
change over time (e.g., the change in total weight of an integrating
waste feed scale over the period of 1 hour). The display from an
integrator is typically a mechanical counter showing a four- to
six-digit number.
Readings from strip charts require special precautions. The
following aspects of the strip charts are important in interpreting
the readings and trends:
Note scale, orientation, units, possible multiple factors, and
zero offset
Note the color of ink (a limiting factor in making copies of
strip charts)
Identify the individual elements of multiple recorders
Verify time scale and labeling of dates
An example strip chart is shown in Figure IV-2. This chart displays
three different parameters (CO, oxygen, and a reserved channel marked
"spare"). This particular recorder automatically marks the date, time,
and parameter (by number) on the chart. Unfortunately, strip charts at
all facilities are not so sophisticated. Often the operator must
manually identify dates, daily time lines, and the type of parameter
labeled. The example demonstrates a common problem with multichannel
strip charts—overlap of peaks from different parameters.
IV-17
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OSWER Dir. No. 9938.6
:o
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Figure IV-2. Example of a labeled, multichannel strip chart.
IV-18
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Even in highly computerized facilities, strip charts are often used to
record the trends in operating conditions over time. The usefulness of
strip charts to the inspector is a function of the diligence of the
facility operators in maintaining the ink flow, paper orientation, chart
speed, and adequate chart labeling. Problems with any of these basic
record-keeping needs should be noted in the inspection report.
C-5. Collecting Monitored Data on the Checklist
The inspector observes readings for all of the permit-limited operating
parameters and enters the values (and units) in the appropriate blanks of
the checklist. An example of a completed checklist page is shown in
Table IV-4. Some of the observed readings will require a further calcu-
lation step before the value can be compared directly to the permit con-
dition. Any calculations should be attached to the checklist package.
Inspectors should become familiar with the types of calculations that may
be necessary, such as the example calculations provided in Appendix B.
For most of the limited parameters, completion of Part II-A of Checklist
No. 1 (provided in Appendix A) is fairly straightforward. (The typical
parameters were described in Chapter III.) However, notes are provided
below for selected parameters:
CO permit limits vary in format in response to changes in guidance
as the RCRA permitting program develops.
Older permits may be two tier: "Cutoff after Y minutes at
> X parts per million and immediately at > XXX parts per
million."
Newer permits may be one tier: "A 60-minute maximum rolling
average of 100 parts per million corrected to 7% oxygen." The
02 correction factor may be based upon continuous monitoring of
02 or upon a factor that must be revised at a specified time
interval.
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Table IV-4. EXAMPLE CHECKLIST PAGE: PERMIT OPERATING PARAMETERS
(WITH INSPECTOR'S OBSERVATIONS INCLUDED)
ID i
Date T-«r-
II. COMPARISON OF PERMIT AND OPERATING CONDITIONS
Date
Time Readings Began
Time Readings Ended
rroo
A. Permit Operating Parameters
1. Temperature measured at each
combustion chamber exit
Permitted Permitted Observed
Maximum Minimum Readlng(s) Calculated
(units) (units) (units) Value
a. Primary
b. Secondary
c.
d.
NA
NA
NA
NA
NA
NA
NA
2.
CO emissions measured at
the stack or other appro-
priate location
(location:
f(»e i»
Avj
• Does CO monitor automatically correct all readings to 7% 02 based on
actual Oj stack concentration? v^ yes no
If no, does permit require 0, correction?
the correction factor to be used?
Date correction factor last determined
changes made In 02 correction factor.
— If so, list It.
Does permit specify
Describe any
Permit-specified frequency for verifying 02 correction factor —
• If a 60-mlnute rolling average Is required, does the observed reading
reflecta 60-m1nute rolling average?
no not applicable
If no, attach data and calculate the average.
3. Oj emissions (location):
4. Flue gas flow rate or
velocity measured at stack
or equivalent method:
( ftfea,pr AT-
-0.30
We.
NA
10.
w.c.
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Flue gas flow rate/velocity may be measured by an alternative method
specified In the permit. The checklist should 11st the method and
contain the appropriate observed or calculated value.
Liquid Injection burner settings may be limited in terms of atomiza-
tion pressure and feed rate or turndown ratio. If a turndown ratio
is specified, the inspector must observe the flow rate to calculate
the observed burner turndown.
C-6. Collecting Waste Characterization Information
Another critical set of limiting factors that are specified in the permit
relate to the characteristics of the waste feed. Some limits may be
established for the combined waste feed (i.e., a total limit); other
limits may be specific to individual waste streams or Individual waste
feed locations (e.g., kiln solids feed, burner No. 3, etc.).
The inspector will compare permit limitations for the waste feeds with
actual operations. However, this activity will not be as straightforward
as the verification of process operating conditions for two reasons:
Characterization of waste feed materials typically is not a
continuous process. Wastes are reanalyzed typically on a minimum
periodic basis as required in a waste analysis plan (i.e., at least
once a year). The data collected by the inspector may be up to
1 year old.
The results of the waste characterization may not be in a form that
is directly usable. Reported results of analysis (e.g., a constit-
uent concentration value) may need to be multiplied by an observed
waste feed rate and any appropriate conversion factors (e.g., time,
volume, specific gravity conversions) to produce a directly usable
value. Total heat input values must also include the heat input of
any auxiliary fuel used in the incinerator. Example calculations
are provided in Appendix B.
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Permit limits are established by the permit writer on a case-by-case
basis for some or possibly all of the following:
Ash and chloride (pounds/hour or %)
Viscosity (maximum)
Heating value (minimum/maximum)
Metals
Organic constituents
Although these permit limits are usually self-explanatory, some addi-
tional explanation may be appropriate for metals and organic constituent
limitations:
Limits OTI metals may be specified individually for noncarcinogenic
metals [such as antimony (Sb), barium (Ba), lead (Pb), mercury (Hg),
silver (Ag), and thallium (Tl)] and as a total limit for carcino-
genic metals [arsenic (As), cadmium (Cd), chromium (Cr), and
beryllium (Be)]. Details on any applicable limits will be specified
in the permit.
Limits on organic constituents may be based on a hierarchy of com-
pounds rated in terms of incinerability (i.e., the degree of dif-
ficulty in incinerating the compounds). Two of the common ranking
criteria are:
• Heat of combustion index (e.g., allow the feeding of wastes
containing only organic compounds with a heat of combustion
exceeding a specified value). A list of hazardous organic
compounds ranked according to heat of combustion is included in
Appendix E. (The lowest values reflect the most difficult
compounds to incinerate.)
• Thermal stability index (e.g., allow the feeding of wastes con-
taining only organic compounds with a higher incinerability
ranking than a specified value or class). A list of hazardous
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organic compounds ranked according to thermal stability is
included in Appendix F. (The lowest ranking numbers reflect
the most difficult compounds to incinerate.)
The waste characterization data must be reviewed for waste constituents
that exceed allowable limits (e.g., organic constituents that are more
difficult to incinerate than the compounds or units specified in the
permit).
Prior to the inspection, the inspector should complete the waste charac-
terization section of the checklist (Checklist No. 1, Part II-B),
incorporating all permit limitations associated with waste feed materials
and fuels. An example checklist page is shown in Table IV-5.
During the inspection, the inspector will need to do the following, as
appropriate to the specific situation:
Collect the most recent analytical results for each of the waste
streams fed to the incinerator during observed operation periods of
the inspection visit.
Enter the applicable analytical results on the checklist.
Gather information on any conversion factors or supplemental data
needed to make comparison calculations (e.g., specific gravity, fuel
flow rate and heating value, etc.). All parameter values used in a
single calculation should be from the same time frame.
Complete any calculations needed to compare permit limits with
actual operations. (Example calculations are provided in Appen-
dix B.)
Compare the permit limitations for allowable organic constituents
with the results of analysis. Consult the appropriate
incinerability index (Appendix E or F) if necessary.
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Table IV-5. EXAMPLE CHECKLIST PAGE: WASTE CHARACTERIZATION
(WITH PRELIMINARY INFORMATION INCLUDED)
10 I Ex A* PUS.
Date
CHECKLIST NO. 1 (continued)
B. Characterization of wastes and fuels fed during the observation period
1. Organic* and physical characterization
Organic constituents
(limitations. ~ Heating Specific
compounds. Ash Chloride Viscosity*1 Value Gravity Other
etc.) (IblU Mb)K» ) ( cP ) (Btu/lb) i 1
(a) Combined waste stream Un r^.typT viiTH (>3O
limitations In permit
waste streams: A-'OCi
Chamber Waste Stream
(1)
(2)
(3)
(4)
(5)
(6)
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It is suggested that all calculations for this part of the inspection are
completed on site during the inspection. Otherwise, it is possible that
some piece of supplemental data (e.g., specific gravity) needed for a
calculation may be forgotten. Data needs may differ significantly for
each facility.
In reviewing analytical results, the inspector also should be looking for
the possible detection of compounds that are specifically prohibited in
the waste feeds by the permit (i.e., exclusive of an incinerability
index). For example, some permits may specifically prohibit PCBs,
dioxins, or other specific compounds from the waste feeds.
C-7. Variations in Approach to Data Gathering
The comparison of actual operating conditions with permit limitations is
a key part of a RCRA incinerator inspection. The preceding two sections
have described the activities (as summarized in Table IV-6) needed to
check operations at the time of the inspector's visit. Depending on the
time available for the inspection and the objectives of a particular
visit, the inspector will also dedicate time to conducting a spot check
of recent and past operation as part of an in-depth inspection. Three
options are described below.
Option A Select Two or More Points in Time for an In-Depth Spot-Check of
Operations
1. Obtain strip charts/review operator's logs for two different months
(e.g., 1 month prior and perhaps 3 or 5 months prior).
2a. Look at the strip chart of a single key parameter (i.e., secondary
combustion temperature, CO, or combustion gas velocity) and look for
extreme or abnormal operations periods, or
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Table IV-6. SUMMARY OF ACTIVITIES—COMPARISON OF PERMIT AND
OPERATING CONDITIONS
Preliminary
Prepare the checklist by filling in permit conditions.
During the Inspection
Collect observed readings for all operating conditions that are
limited in the permit. Carefully note values and units on the
checklist.
Review the most recent waste characterization information for the
wastes fed during the collection of readings. List values on the
checklist, and complete any calculations needed to compare the waste
characteristic with permit limitations.
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2b. Look at the operator's log for upsets, the feeding of unusual waste
materials, or other extreme or abnormal operating conditions, or
2c. Correlate data from records of upsets (e.g., for an excursion of low
combustion chamber temperature look for a corresponding change in CO
concentration).
3. Select one or more point(s) 1n time for each month to evaluate 1n
more detail (i.e., an abnormal operating period if possible).
4. Complete Checklist No. 1 for each selected time. Collect readings
for all permit-limited parameters from available strip charts, logs,
and records. Obtain and review waste characterization data for the
wastes that were fed to the incinerator at the selected times.
Option B Observe Operations During Different Time Periods of the
Inspection Visit
1. Complete Checklist No. 1 for each selected time.
2. Try to select observation times that involve variations in
operations if possible (e.g., different waste feed materials,
different feed rates).
Option C Conduct a Spot Check of Operations Prior to Arriving on Site
for the Inspection
1. Ask the plant to submit operating data for dates/times selected by
you.
2. Review the data (on Checklist No. 1) prior to your inspection.
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Priorities
Option A should be completed for at least two points in time in
every in-depth inspection.
Option B should be completed whenever an in-depth inspection
involves more than 1 to 2 days of on-site inspection time or for
Incinerators that operate under widely differing operating
scenarios.
Option C is probably most useful when the inspector's time on-site
will be very limited or if a public complaint is being
investigated.
C-8. Visual Assessment
The scope of an in-depth inspection also includes the more traditional
elements of a facility inspection, such as looking for leaks, spills,
potential malfunctions, and other issues potentially impacting environ-
mental health and safety. Although some of the objectives of the visual
assessment are direct response to RCRA regulations or permit conditions,
many of the evaluations are subjective, related to potential performance
problems and the general quality of the operation. For example:
RCRA regulations (264.347) require daily inspection of the
incinerator (and associated equipment) and that records of these
inspections be kept by the facility. An inspector should obtain
copies of the two most recent daily inspection reports prior to
conducting the visual assessment. The inspector can compare his/her
findings with the information contained in the operator's recent
inspection records.
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RCRA (264.345(d)) requires the control of fugitive emissions from
the incinerator combustion zone. During the visual assessment, the
Inspector will look for leaks from rotary kiln exit seals, air
pollution control equipment, instrument sensor fittings, and emer-
gency vent stacks in response to the regulatory requirements. The
inspector will also look for corroding gas ducts and signs of poor
maintenance that may indicate future problems with fugitive
emissions.
Table IV-7 is an example page from the in-depth checklist that addresses
visual assessment (Part I of Checklist No. 2 in the general checklist
package). In this part of the inspection, the inspector is (1) looking
for apparent malfunctions in the incineration facility, (2) searching for
any procedural problems with the facility operations based upon records,
operator function, and by-product/waste stream management practices, and
(3) subjectively evaluating the general quality of the operation in con-
junction with the broad objectives of RCRA.
The checklist serves as general guidance for the parts of an incinerator
system that yield useful information in meeting the objectives of the
inspection. Actual needs will vary with individual facilities and
situations. The inspector is highly encouraged to go beyond the scope of
the checklist, whenever appropriate, and to document findings via notes,
photos, copies, etc., as needed.
The first element of the visual assessment is the observation of
equipment/function. During a tour of the incineration facility, the
inspector looks for such problems as:
Leaks, fugitive emissions, problems with seals
Structural integrity issues (corrosion, etc.)
Improper function
Safety Issues
(There is a certain amount of overlap between these issues.)
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Table IV-7. EXAMPLE CHECKLIST PAGE: VISUAL ASSESSMENT
ID #
Date
CHECKLIST NO. 2—VISUAL ASSESSMENT AND AUDIT ACTIVITIES FOR
AN "IN-DEPTH" INSPECTION
I. VISUAL ASSESSMENT OF PERFORMANCE. OPERATIONS.
AND ENVIRONMENTAL SAFETY
A. Observation of Equipment/Function (1, etc. = Problem note (see below)]
Leaks/ Structural Proper Safety
Emissions Seals Integrity Function Issues
—Waste unloading
—Waste storage/blending
—Waste handling/piping
—Waste feed/fuel systems
—Combustion chambers/burners
—Kiln drive system
—Combustion air fans
—Connecting ducts
—Pollution control devices
•Absorber
•VentuM scrubber
•Ionizing wet scrubber
•Baghouse
—Emergency vent stack
(dump stack)
—Process Instrumentation
—Ash handling system
—Scrubber effluent handling
Notes
1.
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The checklist (as in Table IV-7) identifies typical parts of an incin-
erator system that potentially develop problems affecting performance and
environmental safety/health issues. Observe operations and ask the
operators about any reoccurring problems and how these have been
resolved. Through this part of the inspection, the inspector may note
basic performance problems that are not apparent in the control room or
may note future problems that can be avoided with proper response.
(Information on some possible problems is presented in Chapter II of this
manual.) Although waste-handling issues may overlap with the activities
of a general facility inspection, the inspector should also include waste
handling in any incinerator-specific inspection.
The second element of the visual assessment relates to observed
operations including:
General record keeping of all facets of the operations.
The general adequacy of the facility operators and their knowledge
of emergency/contingency procedures.
The handling, fate, and nature of the waste streams produced by the
incinerator (e.g., ashes, scrubber effluents, and stack
emissions).
Basic record-keeping problems may be noted during the first inspection of
a newly permitted facility. An inspector may need to suggest that more
information be provided for use or review, ease of access, or an adequate
level of detail to meet future inspection needs.
Trained and dedicated operating staff are an essential ingredient of a
properly functioning hazardous waste incineration facility. A subjective
evaluation of the operating staff by an inspector serves as a check upon
the training requirements of RCRA. By posing questions to the operators
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about normal operational problems and emergency/contingency plans, the
Inspector may be able to judge the preparedness of the operators for such
situations.
RCRA requires the proper management of any by-product of hazardous waste
Incineration. By-products "derived from" the incineration of listed
hazardous wastes retain the listed waste code. For incineration of only
characteristic wastes, any by-products should be classified as hazardous
if they exhibit any hazardous waste characteristics. Although specific
requirements may be provided in a facility's permit, in some cases a
requirement may be deferred to the provisions of other regulations (e.g.,
scrubber effluent treated by an industrial wastewater treatment
facility). As part of the in-depth inspection, the inspector should
investigate the handling and fate of any incineration by-products/wastes
and document the status of this activity.
In observing incinerator operations, an obvious activity of an inspector
1s to look at the appearance of stack emissions. Although RCRA regula-
tions do not include an opacity standard, a general rule-of-thumb is that
any visible emissions beyond a steam plume may tend to indicate a failure
to meet the RCRA particulate emissions standard. The presence of visible
emissions would tend to indicate a need for a more detailed inspection of
air pollution control equipment. Local air regulations may also apply.
(Steam plumes quickly dissipate to 0% opacity when cooled by ambient air;
particulate-enriched plumes will disperse before losing opacity; more
details on opacity measurement can be obtained from local, state, and EPA
air program staff who are certified visible emissions observers.)
A third element of the visual assessment addressed in the checklist 1s a
highly subjective evaluation of the general quality of operation
including such issues as odors and "housekeeping." Problems in this
category may serve as an indicator of problems in another segment of the
Inspection. For example, the presence of discarded equipment pieces
(corroded pipes, scrubber packing, torn bags from a fabric filter) may
Indicate maintenance problems; discoloration of concrete pads or other
surfaces may Indicate past spills.
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C-9. Auditing and Rsviewing Documentation
This part of the inspection effort focuses on (1) the adequate function
of selected monitoring and safety equipment and (2) additional documenta-
tion requirements that go beyond the review conducted in earlier phases
of the inspection. The priorities for this phase are summarized 1n
Part II of Checklist No. 2.
C-9-a. Audits of Equipment Function
Since certain permit-limited conditions are the primary indicators of
adequate incinerator performance, it is vital that key monitoring
equipment is functioning properly in an incineration facility. Also, the
required automatic waste feed cutoff system is an essential safeguard
when an incinerator's operations deviate from the allowable conditions.
Both of these issues are investigated by the inspector in a series of
functional audits. This part of the inspection can be time-consuming,
especially if the inspector has not prepared in advance for these
activities. Specifically, the inspector should list the permit limits
for the automatic waste feed cutoff system on Checklist No. 2, and
schedule the calibration and function checks in advance with the plant
contact to avoid delays. The inspector should also have available for
reference a list of any monitoring instrumentation calibration require-
ments stated in the permit.
The audits to be performed as part of an in-depth inspection include:
(1) Calibration Check of Continuous Emission Monitors
The inspector will observe a calibration check conducted by facility
staff of each continuous emission monitor (CEM) required in the permit.
(Note: All facilities must have a CO monitor; other requirements are
facility-specific.) The results of the check are listed in Checklist
No. 2.
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Most of the CEMs Installed at Incinerator facilities are extractive
CEMs. These have a fairly simple calibration procedure usually
involving:
A zero calibration—A reading of a calibration gas that does not
contain the monitored constituent. For example, a nitrogen gas may
serve as a zero calibration gas for an 02 CEM.
A span calibration—A reading of a calibration gas that contains the
monitored constituent in a concentration that is about 80% to 100%
of "full scale" of the instrument at the selected sensitivity scale,
e.g., a span gas of 245 parts per million CO for a CO CEM operating
in a 0- to 250-parts per million range.
Additional calibration at a midpoint between the "zero" and "span" points
may be required in a permit to determine calibration error. The inspec-
tor can add another check step by bringing an additional standard gas
on-site as an "unknown" calibration check. Results are documented on the
checklist.
A special case involves "in situ" CEMs that may be used at some facil-
ities. These units (described earlier in Chapter II) typically are not
as simple to calibrate by direct methods (e.g., with standard gases) as
extractive monitors. A check of the manufacturer's recommended procedure
may be necessary. Calibration methods for in situ monitors may
involve:
Indirect calibrations (optical, electrical).
Alternative calibrations (filling the stack with calibration gas).
Comparisons with other CEMs.
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The type of calibrations that can be checked during an Inspection (and
during normal operating periods) may be limited to the Indirect calibra-
tion methods. The use of an "unknown" calibration check is probably not
practical for an in situ monitor.
(2) Audit of the Automatic Waste Feed Cutoff System
The inspector will observe a test of the automatic waste feed cutoff
system to determine if the system functions properly when required by the
permit. Essentially, the inspector will test all of the sensors of the
system individually and will test the actual cutoff mechanism once. The
inspector's activities include:
Listing in advance on the checklist the permit limits (a value and a
time lag, if applicable) that trigger the automatic waste feed cut-
off system.
Observing the conditions that signal a cutoff.
Observing adequate function of the cutoff mechanism (i.e., that the
waste is actually cut off).
Testing of the automatic waste feed cutoff system can involve simulated
cutoffs and actual cutoffs. Simulated cutoff may involve:
Monitoring the cutoff signal received by a "dummy" receiver in
response to a cutoff condition.
Other indicators of cutoff activity that do not cause actual cutoff
(i.e., action on a valve or switch "stuck" in the open position for
the test).
Highly computerized systems usually have the capability of demonstrating
the reception of a cutoff signal and overriding or misdirecting the
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actual cutoff signal so that an actual cutoff is not completed. More
basic systems may require alternative methods to simulate cutoff or may
only be able to conduct actual cutoffs.
For an in-depth inspection, the inspector should observe a test of the
automatic waste feed cutoff system for all limiting parametars specified
in the permit. To minimize the disruption of the incinerator operations,
most of the testing can be based on simulated cutoffs. However, at least
one cutoff test should include an actual cutoff of the waste feed
system. (Note: On systems that are co-fired with a auxiliary fuel, it
is not a burden to cutoff the waste feed. The auxiliary fuel keeps
firing and the controllers maintain steady operation.)
Cutoff may be in response to:
Actual cutoff conditions (e.g., low temperature)
Simulated cutoff conditions (e.g., computer override, standard gas
connected to CEM)
Cutoff testing may occur during normal plant operations or during special
operating conditions (e.g., nonhazardous waste). Test conditions/schedule
should be mutually agreeable to the inspector and the plant, although the
needs of the inspection take precedence.
On the inspection checklist, the inspector records:
Parameter value signaling cutoff
Time lag
Simulated or actual cutoff
Notes should be taken concerning any difficulties, impacts from waste
feed cutoffs, or additional issues. Since a periodic check of the auto-
matic cutoff system is required in the RCRA regulations (40 CFR
264.347(c)), the operator should have in place a standard procedure for
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routinely testing the system. Inspectors will also review the documenta-
tion of tests of the cutoff system and cutoff episodes (as discussed on
page IV-41).
(3) Checks of Other Key Monitoring Instrumentation
Analogous to the calibration check of CEMs, the Inspector Is concerned
that key monitoring equipment 1s functioning properly for all of the
permit-limited operating parameters. Unfortunately, calibration proce-
dures for many of the monitoring systems are not as simple and well-
defined as the procedures for extractive CEMs.
Major elements of Instrument calibration are precision and accuracy.
Precision indicates agreement among a set of results without assumption
of any prior Information as to the true result. On the other hand,
accuracy means the nearness of a result to the true result. For instru-
mentation, measurement of accuracy involves standards or reference
materials. Multiple instrument comparisons can provide a related
measurement. Examples are shown below:
Accuracy Check Multiple Instrument Comparison
pH meter—measure pH Thermocouple—compare reading
of standard buffer solution with an alternate thermocouple
Feed scale—measure Liquid feed rate indicator— compare
a standard weight placed average reading over a time period
on scale with a measured volume change In the
feed tank over the same time period
As a practical issue, accuracy checks may not be possible for some
instruments. In situ installation may prohibit access of a reference
material to a sensor for an accuracy calibration, or a suitable reference
material may not be available. Typically, if the precision is known for
real-time measurements and measurement taken during test episodes (e.g.,
the trial burn test) that indicated adequate performance of the treatment
process, the inability to determine measurement accuracy is not a
problem. For example, the accuracy of a 25- to 35-psi pressure gauge
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reading during a trial burn may not be as important as the precision of
subsequent readings at that particular location, if that parameter is to
be monitored as a permit condition.
Calibration requirements for a key monitoring instrument will consider
the following:
Manufacturer's specification/recommendations
Procedure/frequency
Practical considerations (accessibility, disruptive nature)
Accuracy vs. precision
Ideally, the requirements for continuing calibration will be specified in
the permit. Otherwise, the inspector's assessment of key monitoring
instrumentation will be a case-by-case evaluation based largely upon pro-
cedures and frequency discussed with facility staff and noted in records.
As an example case, consider thermocouples which are commonly used for
monitoring the critical temperatures in an incinerator facility.
Typically, the word "calibration" when associated with thermocouples
means one or more of the following:
- "Checked" at factory
Compared with other thermocouples in situ (each combustion chamber)
Possible in situ electrical check
Replacement of malfunctioning (or suspect malfunctioning)
thermocouples
The most reasonable approach for an inspector would probably involve:
A comparison of readings of redundant (i.e., duplicate) installed
thermocouples.
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_ A review of temperature profile or trend across the system (I.e.,
highest temperatures In the combustion zone, lower temperatures
through the quench/heat boiler or heat exchanger, lowest In the ARC
devices).
A discussion with facility staff on the criteria used for replacing
suspect malfunctioning thermocouples.
A review of maintenance logs that document the installation of new
thermocouples.
Ideally, any calibration requirements related to the other permit-limited
parameters will be identified clearly in the permit (or will be
referenced in the permit). An inspector's review of other instruments
will vary significantly in approach and will depend on the specific
requirements established for each instrument. (General information about
some of these instruments is provided in Section II-D.) All observations
should be documented; additional assistance should be obtained if con-
cerns cannot be resolved adequately.
C-9-b. Additional Documentation Review
Documentation review, as approached in the earlier sections of the
inspection, focused on such issues as:
Operating conditions
Characteristics of the waste
Accessibility and completeness
Another group of objectives for the inspection includes a review of the
adequacy of waste characterization and handling records and a review of
other records required by permit (e.g., related to process upsets,
inspections by the operators, and maintenance). These activities are
listed in Checklist No. 2.
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(1) Audits of Waste Characterization and Handling
The objectives of this review Include evaluations of:
Waste Characterization
• Analysis of appropriate parameters
• Frequency of analysis
Adequate analysis documentation (subjective)
Waste Handling
Manifest/logs
"Fingerprint" analysis
• Blending/feeding logs
Specifications and limits for these items may be provided in the permit.
Objectives for analysis documentation may be specified in a Quality
Assurance (QA) Plan attached to the permit or incorporated 1n the permit
application. To conduct a thorough review of the facility's analytical
records 1n conjunction with the QA Plan, the inspector may need to obtain
assistance from an analytical chemist/QA expert. Such a review may be
appropriate for facilities that handle a wide variety of wastes or for
particularly sensitive inspection situations. Otherwise, a subjective
review by the Inspector may be appropriate.
Facilities that receive wastes from off site typically conduct certain
"fingerprint" analyses to verify the Identity of the wastes received.
Specific requirements for these analyses would be listed 1n the permit or
in the waste analysis plan incorporated into the permit and should be
verified by the inspector.
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Facilities that feed a variety of waste materials to an incinerator may
also have specific permit limits related to the blending of combined
waste streams to meet operating objectives (e.g., to maintain a particu-
lar heating value, satisfy chloride-loading limits). The inspector
should verify that any permit-required procedures are adequately
documented.
(2) Review of Other Records Required by the Permit
Permits may include documentation requirements for the following:
Issue
Dump stack (i.e., emergency
bypass stack) openings
Automatic waste feed cutoff
Inspection logs/calibration
records
Maintenance records
Objectives of Inspection
Openings, causes, and corrective
action documented
Temperature maintained during
openings
Minimum airflow maintained
during openings
Documentation of cutoffs and
testing of system
Note frequency of cutoff incidents
Complete
Adequate schedule
Note any recurring problems
Complete
Timely corrective action
Routine maintenance performed
on schedul'e
Recurring problems
Replaced equipment
In conjunction with the permit and Checklist No. 2, the inspector should
take notes on the status and adequacy of any of the above issues that are
required in the permit.
The collection of information about replaced equipment is an important
objective of the inspection. Inspectors need to provide the permit
writer information to evaluate the specifications of replaced equipment
(e.g., monitors) and to determine whether the replacement was allowable
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without a permit modification. The replaced equipment can potentially
affect the operating conditions of the incinerator.
C-9-c. Audit of Analytical Procedures (Optional)
A control agency may decide to conduct an audit of waste analysis con-
ducted by the incineration facility. Options for this audit may involve
the following:
Inspector provides check samples for analysis in facility lab, or
Inspector obtains sample splits for analysis in agency lab.
The responsibilities of an inspector for such an audit include:
Documenting the origin of samples
Transmitting details to labs
• Parameters and methods
• Handling/storage limitations
• QA/QC requirements
More details for laboratory inspections can be found in the RCRA
Laboratory Audit Inspection Guide Document (EPA, 1988c).
C-10. Summary of an In-Depth Inspection
The general effort for an in-depth incinerator inspection is summarized
in Table IV-8.
D. THE WALK-THROUGH INSPECTION
The walk-through inspection is an evaluation of a hazardous waste incin-
erator that incorporates activities such as:
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Table IV-8. SUhWARY DESCRIPTION OF AN IN-DEPTH INCINERATOR INSPECTION
Prepare a checklist in advance based on the permit.
Record actual observed values for all permit-limited operating
parameters.
Record the most up-to-date waste characterization data for the
wastes fed to the Incinerator during observation period(s).
Gather additional information on actual operating conditions
and waste characteristics for past points in time or from addi-
tional observations.
Conduct a visual assessment of the facility and its operations.
Conduct an audit of equipment function for the automatic waste
feed cutoff system and key monitoring equipment.
Conduct a detailed review of all records required by the
permit.
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Detailed evaluation of operating conditions at the time of the
visit.
General observation of activities.
Quick audit of selected Instrumentation.
Limited review of records.
This incinerator-specific inspection may require only 4 to 8 person-hours
of inspection time on site. The actual time needed depends on the type
of Incinerator and the number of incinerators at the facility. For
example, a walk-through inspection of a commercial incinerator will
probably require about 8 person-hours; an on-site industrial incinerator
burning a limited variety of wastes may require about 4 person-hours,
depending on the complexity of the facility and the permit. If addi-
tional incinerators are installed at the site, allow about four addi-
tional person-hours per incinerator for a walk-through inspection.
The walk-through inspection is designed to provide a detailed picture of
observed operations at the facility within a minimal on-site time
period. The priorities are established via checklists. In Appendix 1
(the checklist package), Checklists No. 1 and 3 are used 1n a
walk-through inspection.
The following pages describe the activities to be completed during a
walk-through Inspection. Frequent references are made to descriptions of
an 1n-depth Inspection when there is significant overlap between the two
types of inspection.
0-1. Listing Basic Information
The discussion of basic information on page IV-10 of this manual also
applies to walk-through inspections.
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D-2. Comparing Permit and Operating Conditions
The description on pages IV-10 through IV-28 also applies to walk-through
inspections. The comparison of operating conditions with permit limits
1s probably the key observation of any incinerator Inspection. In sum-
mary, the activities for this part of the inspection Involve the
following:
Prepare the checklist (Checklist No. 1) in advance by filling 1n
permit conditions.
Collect observed readings for all operating conditions that are
limited in the permit.
Review the most recent waste characterization information for the
wastes fed to the incinerator during the collection of readings.
List the values on the checklist, and complete any calculations
needed to compare the waste characteristics with permit limitations.
By definition, the walk-through inspection includes a review of only the
actual operating conditions noted during the inspector's visit (i.e., a
copy of Checklist No. 1 covering only one point in time). However, if
additional time is available, the inspector could go a step beyond the
walk-through format by reviewing operations documents for recent and past
operations as described on page IV-25 (Option A).
Although such a review can be time-consuming, this activity could serve
as a check of continuing compliance, thus increasing the value of a walk-
through inspection.
Option C (see page IV-27), which is a spot-check of operations conducted
prior to the inspection, is also a useful option for a walk-through
inspection.
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D-3. Visual Assessment
This part of the Inspection (as outlined In Section I of Checklist No. 3)
1s similar to the activities described on pages IV-28 to IV-32 for an In-
depth Inspection. The major activities of this portion of a walk-through
Inspection include:
The observation of equipment/function
Assessment of observed operations
Assessment of the quality of operation
Checklist No. 3 differs from the in-depth checklist in the priorities for
assessment of observed operations. This part of the inspection (see
Table IV- 9) looks at:
The general completeness of records required in the permit
A subjective evaluation of the facility operators
The appearance of stack emissions
The review of documents tends to be a cursory review in the walk-through
Inspection. A more detailed level of review is not practical within the
planned time frame of the walk-through inspection.
D-4. Quick Audit of Performance
The priorities established for the inspector to conduct a quick audit of
performance in Section II of Checklist No. 3 are:
A calibration check of each continuous emission monitor (CEM)
required in the permit.
Observation of the operation of the automatic waste feed cutoff
system in response to at least one upset condition.
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Table IV-9. EXAMPLE CHECKLIST PAGE: OBSERVED OPERATIONS
(FOR A WALK-THROUGH INSPECTION)
ID I
Date
CHECKLIST NO. 3 (continued)
B. Observed Operations [Give brief description of problem or reference a note below
(1, 2. etc.)l
Status/Comments
—Records of permit parameters
—Proper Identification of date, time,
and units on strip charts
—Records of automatic waste feed
cutoff (AWFCO)
• Documented
• Frequency of cutoff Incidents per month
or per day (average of days)
• Major causes for AWFCO
—Records of dump stack openings
• Openings documented: incidents since (date of last inspection)
or in last 12 months (reported to state or EPA)
• Temperature and airflow maintained
• Causes
--Records of waste acceptance
hand 11ng
characterization
--Log of inspections
calibrations
maintenance
--Staff knowledge of emergency procedures
contingencies
--Appearance of stack emissions
Notes
1.
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The CEM calibration check 1s conducted as described on page IV-33. The
feed cutoff observation is a shortened version of the activities
described on page IV-35. For both of these activities, the inspector's
observations are noted in Checklist No. 3.
D-5. Summary of the Walk-Through Inspection
This Inspection format essentially assembles the highest priority
Inspection activities of an in-depth incinerator inspection into two
checklists (Checklists No. 1 and No. 3) to be completed in about 4 to
8 person-hours on site. If more time is available to the inspector, a
spot-check review of recent and past operations (as described in Option
A, page IV-25) is highly recommended.
E. THE INSPECTION REPORT
Both the RCRA Inspection Manual (EPA, 1988a) and the RCRA Technical Case
Development Document (EPA, 1988b) provide detailed information on inspec-
tion reports. The RCRA Inspection Manual notes that "The adequacy of
follow-up to correct problems or deficiencies noted during an inspection
depends greatly on the report package the inspector prepares following
the inspection."
The report should contain:
Completed narrative (the factual record including descriptive detail
of items relating to potential violations and discrepancies)
Completed checklist pages and associated calculation sheets
Supporting documentation which may include:
• Log sheets/printouts
Copies of strip charts (with appropriate labeling)
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• Laboratory results
• Facility inspection/calioration/maintenance records
Specifications for any replaced equipment
Selected pages of the permit and previous inspection reports
Diagrams and photographs
• Correspondence
• Any other supporting documentation
Additional guidance on preparing inspection reports is provided in the
RCRA Inspection Manual and the RCRA Technical Case Development Guidance
Document.
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CHAPTER V
IDENTIFYING AND DOCUMENTING POTENTIAL VIOLATIONS
INDEX
A. Identifying Potential Violations V-2
B. Potential Violations of Numerical Limits V-3
C. Other types of Potential Violations V-5
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CHAPTER V
IDENTIFYING AND DOCUMENTING POTENTIAL VIOLATIONS
LEARNING OBJECTIVES
Encourage inspectors to identify potential violations while in the
field.
Describe the additional activities and documentation of potential
violations.
Discuss potential violations involving numerical limits and other
issues.
A. IDENTIFYING POTENTIAL VIOLATIONS
While conducting the inspection and comparing actual operations and
records with permit conditions, inspectors will be looking for potential
violations. In some cases identification of potential violations may be
very simple. (For example, an observation that a secondary combustion
temperature is operating 200°F below the allowable minimum temperature
while burning hazardous waste; or a facility is unable to provide records
of waste characterization data for a hazardous waste stream that was
incinerated in a previous month.)
For other cases an inspector may be unable to identify a potential
violation until a calculation can be completed, a discussion is held with
the permit writer, analysis results are received from the agency lab, or
other similar follow-up activities are completed. (For example, the per-
mit writer decides that a newly replaced CO monitor is not technically
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adequate for meeting RCRA monitoring requirements, or analysis results
from the agency lab Indicate a 100-ppm concentration of PCB in an
Incinerated waste stream, although the permit specifies that wastes
containing PCB cannot be fed to the incinerator.)
For either type of situation, it is essential that the inspector provide
adequate documentation of the potential violation to satisfy the needs of
any enforcement case development activities. The most critical docu-
mentation often occurs during the inspection, at the time and place where
an Inspector can collect physical evidence and obtain direct information
from facility staff.
This chapter provides suggestions for inspectors on how to develop ade-
quate documentation for potential violations that have been identified
during the Inspection. The following sections address documentation for
potential violations of numerical limits and general documentation
activities for other types of potential violations. The RCRA Inspection
Manual (EPA, 1988a) and the RCRA Technical Case Development Guidance
Document (EPA, 1988b) also provide detailed information on identification
and documentation of potential violations.
B. POTENTIAL VIOLATIONS OF NUMERICAL LIMITS
As discussed previously in this manual, many of the critical permit
limits for hazardous waste incinerators are listed in each permit as
allowable minimum and maximum values for selected parameters. Inspectors
11st observed values or values recorded in facility records on site-
specific checklists and are able to identify potential violations, either
immediately or after completing any necessary calculations, by making a
quick comparison.
Whenever potential violations are noted, inspectors should take addi-
tional steps to document the validity of the suspect value as follows:
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1. Collect physical evidence of the suspect value.
a. Take notes of the time, location, origin, and value of the
reading/record. Note the length of the time period when
the value appeared to be outside of the allowable range.
Take readings from alternate sources if available (e.g.,
strip chart, computer log, duplicate, or stand-by
instrument).
b. Interview the operator to verify the value you have listed
is correct (correct units, location, interpretation,
etc.).
c. Obtain copies of logs and strip charts that record the
subject value.
d. Take a picture of the value reading 1f possible (i.e., if
the value is available on a readout or gauge).
2. Collect background information on operations at the time of the
observed/recorded suspect value.
a. Log on the checklist or in the inspection notes the values
of any other parameters that may have contributed to or
may have been affected by the suspect value (e.g., tem-
perature, waste flow rate, CO, gas velocity).
b. Take notes of the status of operations at the time the
suspect value (as observed or as recorded). Items of
interest may include the type of wastes fed to the unit,
staffing (operators and supervisors on duty), shutdowns
before/after the time of the suspect value, check for
upsets and equipment malfunction, etc.
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c. Document the condition of the instrument that provided the
suspect reading. Obtain a copy of calibration and mainte-
nance records for the instrument.
3. Discuss the suspect value with facility staff.
a. Identify your finding to the operator and ask for an
explanation. Take detailed notes (quote if possible).
b. Repeat the conversation with the engineer or supervisor
overseeing operations and take detailed notes (quotes).
4. Follow up within your agency (as discussed in Chapter VI of
this manual).
Because the most critical documentation in support of a potential viola-
tion is obtained on site, inspectors are encouraged to identify potential
violations during the inspection. For example, if time is available to
complete on-site any calculations needed to evaluate a permit limit,
potential violations of those particular limits can be identified during
the inspection. Then additional documentation can be gathered by the
inspector before leaving the site.
C. OTHER TYPES OF POTENTIAL VIOLATIONS
Aside from numerical issues, potential violations for a hazardous waste
incinerator may involve such issues as:
Insufficient records.
Maintenance problems (including calibrations).
Improper handling of residual wastes (ashes, scrubber effluents).
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Incomplete waste characterization.
Inadequate Inspections of equipment.
Insufficient training/qualifications of staff.
Visible emissions (that indicate potential performance problems).
Inoperable waste feed cutoff systems.
When inspectors identify these types of potential violations, the follow-
ing activities should be considered to provide adequate documentations:
1. Collect physical evidence of the suspected violation.
a. Take detailed notes of observations.
b. Obtain copies of any documents (logs, records, etc.) that
support the problem or indicate a lack of required action.
c. Take pictures if appropriate.
2. Discuss the suspected violation with facility staff.
a. Identify your concern with operating staff and facility
management. Take detailed notes (quote if possible).
b. Ask facility staff if any "missing" information is avail-
able from other individuals at the facility or in another
office.
3. Follow up within your agency (as discussed in Chapter VI of
this manual).
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For example, an inspector may note an apparent failure of a facility to
keep records of the testing of the automatic waste feed cutoff as
required in the permit. An inspector in this case may:
Take notes of the effort made to obtain the records.
Look at strip charts throughout a monthly period in conjunction with
the operations log to identify any shutdown periods caused by either
upset conditions or test conditions.
Discuss the missing information with the on-duty operator and the
facility operations engineer. Take notes of their responses.
Ask the facility manager if the test information may be retained by a
maintenance supervisor or another staff member.
Follow up within the agency after the inspection.
As another example, an inspector may notice during a review of records
that the facility has not conducted calibrations of a waste feed
measurement instrument on a semiannual basis as required in the permit.
An inspector in this case may:
Take notes of the effort made to obtain records of completing the
required activity (calibration).
Discuss the missing information with the on-duty operator and the
facility operations engineer.
Follow up within the agency after the inspection.
This type of an approach would also be appropriate for potential
violations involving incomplete waste characterization and inadequate
inspections of equipment.
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A different type of example may involve an inspector's observation that
the opacity of observed emissions (beyond the steam plume) indicates a
potential problem with adequate air pollution control. In such a case a
RCRA inspector*might proceed as follows:
Take notes of general observations and concerns.
Document the observed values of all monitored parameters associated
with the air pollution control equipment.
Discuss maintenance of air pollution control equipment with the
responsible staff.
Discuss observations with supervisor at the agency. Consider
requesting immediate assistance from air programs staff possibly
including a certified visible emissions observer and an air programs
Inspector who evaluates air pollution control equipment.
In this particular example the potential violation may involve an air
permit or ordinance and potentially the RCRA permit, depending on appli-
cable regulations and specific permit conditions. A similar approach
could be used for a potential violation related to improper handling of
residual wastes (ashes, scrubber, effluents). Such a situation may
involve other agency program areas (e.g., water programs).
Lastly, the inspectors are encouraged not to characterize any findings as
"violations" when debriefing facility staff unless absolutely certain. A
finding of violation is usually made by an enforcement official after
consideration of all facts and evidence regarding a potential violation.
It would be, at the very least, an embarrassment for the Agency to have a
facility spend money correcting a "violation" cited by an inspector, only
to find that upon further consideration that a violation did not exist.
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CHAPTER VI
FOLLOW-UP AND SPECIAL ISSUES
INDEX
Follow-Up to the Inspection VI-2
Special Issues VI-4
B-l. Inspection of Interim Status Incinerators VI-4
B-2. Inspection of a New Incinerator vi-5
B-3.. Inspection of Post-Trial Burn Operations at
an Incinerator VI-6
B-4. Inspection of "Exempt" Incinerators VI-7
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CHAPTER VI
FOLLOW-UP AND SPECIAL ISSUES
LEARNING OBJECTIVES
Identify potentially important follow-up activities to the
inspection.
Describe appropriate activities for four special inspection cases:
• Interim status incinerator
• New incinerators
Post-trial burn operations
"Exempt" incinerators
A. FOLLOW-UP TO THE INSPECTION
After completing the inspection, the inspector compiles information for
the inspection report. Additional calculations may need to be completed
back at the agency office, using information to be submitted by the
facility, or the issuance of the report may be delayed a few weeks await-
ing the results of analysis. After all of the final pieces are avail-
able, the inspector may still have some remaining questions or uncertain-
ties that should be resolved before issuing the inspection report.
The RCRA Inspection Manual (EPA 1988a) identifies the general usefulness
of follow-up discussions with the inspector's supervisors and the permit
writer as well as procedural discussions concerning federal/state juris-
diction. Discussions with Agency attorneys on these issues are very
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important. Additional specific follow-up discussions may be appropriate
after an Incinerator Inspection. Examples Include:
- Discussions With the Permit Writer
General/specific questions about the Incinerator design and
operation; permit conditions, etc.
Specific details concerning any replaced equipment and whether
the replacement requires permit modifications.
Potential violations identified by the inspector (e.g., Is this
actually a violation? How serious is this issue?).
(Ideally, the individual who wrote the incinerator permit has
the most experience to share. If this individual is no longer
with the Agency, another experienced incinerator permit writer
may possess the skills to answer most questions.)
Discussions with Technical Experts
Technical questions concerning air pollution control, chemical
analysis, quality assurance, instrumentation, etc.
Discussions with Representatives of Other Agency Programs
Concerns associated with gaseous emissions (air programs),
improper handling of effluents (water programs), etc.
In addition to providing a factual, comprehensive inspection report to
circulate to responsible agency staff and the inspection file, the
Inspector should verbally apprise selected agency staff of the nature of
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any findings that indicate a need for follow-up action. Reports and
memos may tend to pile-up on desks and not receive Immediate review or
action. The inspector should report verbally to appropriate staff any
findings judged to be of significant Importance.
B. SPECIAL ISSUES
This manual has addressed primarily the inspection of permitted incinera-
tors that are operating under permit conditions established from a suc-
cessful trial burn. There may be times when an inspector 1s involved
with facilities that do not fit into that general category. The follow-
ing pages outline inspection approaches for four special cases:
Interim status incinerators
New incinerators (not yet tested)
Post-trial burn operations
"Exempt" incinerators
B-l. Inspection of Interim Status Incinerators
The requirements under RCRA for interim status Incinerators (40 CFR 265,
Subpart 0) essentially are limited to the following:
Analysis of wastes not previously burned
• heating value
halogen content
• sulfur content
concentrations of lead and mercury
No hazardous waste feed during startup and shutdown
• steady-state airflow
• steady-state temperature
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Monitor emission/combustion control instruments every 15 minutes
waste feed
• auxiliary fuel
airflow
temperature
• scrubber flow and pH
Also, interim status incinerators may burn wastes containing dioxin only
if certification is obtained for meeting the applicable Part 264 perfor-
mance requirements.
The scope of an inspection for this kind of facility would probably be
limited to the general issues addressed in Section I of Checklist No. 3
(see Appendix A). A primary issue would be the adequacy of process moni-
toring.
B-2. Inspection of a New Incinerator
An inspector may become involved in inspecting a new RCRA incinerator
that has not yet completed a trial burn test. Major activities for such
an inspection will be based on the limitations established in the facil-
ity's permit. Basic inspection activities for this situation include:
Verify installation of monitoring equipment as specified in permit or
permit application.
Verify construction of the incinerator and support equipment in
accordance with the specifications in the permit or permit
application.
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Verify shakedown period requirements
No greater than 720 hours of operation with hazardous wastes
(or within limits in the approved extension agreement)
Operating parameters within permit limits for shakedown period
Verify adequate completion of compliance schedule (if any)
Appendix G provides a checklist for inspection of a new RCRA incinera-
tors. The checklist suggests the priorities and level of documentation
that are appropriate for this type of inspection.
B-3. Inspection of Post-Trial Burn Operations at an Incinerator
During the period of time immediately after the trial burn and until the
results of the trial burn have been incorporated as permit limits or per-
mit modifications, the incinerator is operating in a post-trial burn
period. Limiting conditions for operation of the incinerator in this
time period are established in:
The operating permit for a new facility, or
Part 265 standards for an interim status facility.
If an inspector's services are needed in this time period, the basis for
the inspection will be the limitations established by the permit or
Part 265 standards. Typically, the limitations.for a new facility are
similar to the operating conditions planned for the trial burn. However,
the allowable wastes to be fed to the incinerator after the trial burn
may be more restrictive. Inspectors may be able to use the walk-through
inspection checklists (i.e., Checklist Nos. 1 and 3 in Appendix A) as a
format for a post-trial burn inspection.
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B-4. Inspection of "Exempt11 Incinerators
Hazardous waste Incinerators that are exempt from most of the
requirements of 40 CFR 264, Subpart 0 (as described on p. II1-8) are
those permitted Incinerators burning waste that are classified as
"hazardous" solely based upon the regulatory definitions of corrosive,
Ignitable, and/or reactive wastes. If exempted under §264.340(b), an
Incinerator may not burn wastes with any Appendix VII constituents. If
exempted under §264.340(c), the waste may contain only those Appen-
dix VIII constituents allowed under the permit, and the concentrations of
those constituents must be below the "insignificant" levels specified in
the permit. Typically, the permit limitations of these incinerators are
fairly minor except for requirements of waste characterizations.
An inspection of a permitted exempt incinerator involves:
A thorough review of waste analysis results, including a review of
the possible presence (and if applicable, concentration) of Appen-
dix VIII constituents in the wastes.
A comparison of any specific permit limitations with actual
operations.
The inspection of permitted exempt incinerators may require the use of
only very limited sections of the RCRA incinerator inspection forms
package (e.g., waste characterization).
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CHAPTER VII
REFERENCES
AIR POLLUTION CONTROL
Andersen 2000, Inc., "Engineering Manual with Operating and Maintenance
Instructions," for Venturi Scrubbers, Prepared by Andersen 2000, Inc.,
306 Dividend Drive, Peachtree, Georgia.
Calvert, S. J., et al., Scrubber Handbook, PB 213 016, Prepared for U.S.
Environmental Protection Agency, August 1972.
"Ceilcote Ionizing Wet Scrubber Evaluation," Prepared for Industrial
Environmental Research Laboratory, U.S. Environmental Protection Agency,
EPA Publication No. EPA-600/7-79-246, November 1979.
Ceilcote IWS System, Bulletin 12-19, Prepared by The Ceilcote Company,
140 Sheldon Road, Berea, Ohio.
Kroll, P. J., and P. Williamson, "Application of Dry Flue Gas Scrubbing
to Hazardous Waste Incineration," Published Article in Journal of Air
Pollution Control Association, Volume 36, No. 11, pp. 1258-1262,
November 1986.
Roeck, D. R., and R. Dennis, "Fabric Filter Inspection and Evaluation
Manual," Prepared for Office of Air Quality Planning and Standards, U.S.
Environmental Protection Agency, EPA Publication No. EPA-340/1-84-002,
February 1984.
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Sedman, C. B., and T. G Bena, "Municipal Waste Incineration Field
Inspection Manual," Prepared for Stationary Source Compliance Division,
U.S. Environmental Protection Agency, Draft Report.
U.S. Environmental Protection Agency, "Control Techniques for Particulate
Emissions from Stationary Sources," Volumes 1 and 2, EPA Publication No.
540/3-81-005a,b, September 1982.
U.S. Environmental Protection Agency, "Wet Scrubber Inspection and
Evaluation Manual," Prepared for Office of A1r Quality and Standards, EPA
Publication No. EPA-340/1-84-002, February 1984.
U.S. Environmental Protection Agency, "Municipal Waste Combustion
Study - Flue Gas Cleaning Technology," Prepared for Office of Solid
Waste, EPA Publication No. EPA/530-SW-021d, June 1987.
INSPECTION
U.S. Environmental Protection Agency, "RCRA Inspection Manual," OSWER
D1r. No. 9938.2A, Office of Solid Waste and Emergency Response,
Washington, D.C., March 1988a.
U.S. Environmental Protection Agency, "RCRA Technical Case Development
Guidance Document," OSWER Dir. No. 9938.3, Office of Solid Waste and
Emergency Response, Washington, D.C., June 1988b.
U.S. Environmental Protection Agency, "RCRA Laboratory Audit Inspection
Guidance Document," OSWER Dir. No. 9950.4, Office of Solid Waste and
Emergency Response, Washington, D.C., September 1988c.
VII-2
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OSWER Dir. No. 9938.6
INCINERATORS—BACKGROUND
North American Manufacturing Company, North American Combustion Handbook,
Volume 1, Third Edition, Cleveland, Ohio, 1986.
Standard Handbook of Hazardous Waste Treatment and Disposal, H. M. Freeman
(Editor), McGraw-Hill, New York, 1989.
American Society of Mechanical Engineers, Hazardous Waste Incineration: A
Resource Document, New York, January 1988.
INCINERATORS—GUIDANCE
U.S. Environmental Protection Agency, "Guidance on Setting Permit Condi-
tions and Reporting Trial Burn Results," Office of Solid Waste and Risk
Reduction Engineering Laboratory, 1989a.
U.S. Environmental Protection Agency, "Guidance on PIC Controls for
Hazardous Waste Incinerations," Draft Report, Prepared for Office of
Solid Wastes by Midwest Research Institute, 1989b.
(Additional guidance manuals are listed in Appendix D.)
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APPENDIX A
RCRA INCINERATOR INSPECTION CHECKLIST PACKAGE
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RCRA INCINERATOR INSPECTION FORMS
Developed by Midwest Research Institute
for the U.S. Environmental Protection Agency
January 1989
I. Background
The attached set of forms identify activities appropriate for compliance
inspection of RCRA incinerators. The set of checklists includes:
- Checklist No. 1 - Permit and Operating Conditions
- Checklist No. 2 - Visual Assessment and Audit Activities for an "In-
Depth" Inspection
- Checklist No. 3 - Visual Assessment and Audit Activities for a "Walk-
Through" Inspection
The checklists are designed to be used for two types of inspection--a
"walk-through" inspection requiring about 3 to 4 hours and an "in-depth"
inspection requiring 1 to 5 days. The following checklists are suggested:
"Walk-through" Inspection "In-depth" Inspection
Checklist No. 1 Checklist No. 1
Checklist No. 3 Checklist No. 2
II. Notes on Individual Checklists
Checklist No. 1 is based on EPA guidance (January 1989 "Guidance on
Setting Permit Conditions and Reporting Trial Burn Results").
Blanks are included for additional parameters. Multiple sets of
Checklist No. 1 may be used to evaluate operations at various
selected times during a multi-day "in-depth" inspection or to
evaluate past operations at selected times using facility records.
All calculations must be documented in extra calculation pages.
Note in the checklist the page numbers of the documented
calculations.
Checklist No. 2 is for "in-depth" inspections only. Part I is
highly subjective, relying on judgment. Part II includes activities
that may require scheduling to avoid interferences with facility
operations (e.g., testing of automatic waste feed cutoff) and
arranged meetings with facility managers and laboratory staff.
Checklist No. 3 includes visual assessment and audit items of high-
est priority from Checklist No. 2. This checklist is intended for
"walk-through" inspections only. Activities may require scheduling
to avoid interferences with facility operations.
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III. General Instructions
Fill in permit conditions in advance; label units correctly.
Before conducting an inspection, review the most recent plant
inspection report.
Use calculation sheets if observed values must be converted to the
units of the permitted values.
Note ranges of values if significant fluctuations are noted during
the observation period.
Use extra pages as necessary.
Fill out all information as it is collected; don't depend on your
memory. If information is not available, indicate that on the form.
Document the sources of all information, especially if it pertains
to potential permit violations. For example, did someone tell you
something, did you personally observe it or did you read it in a
file?
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OSWER Dir. No. 9938.6
RCRA INCINERATOR INSPECTION
CHECKLIST NO. 1—PERMIT AND OPERATING CONDITIONS
I. ESSENTIAL INFORMATION
Facility EPA 10 No.
Address Facility Staff
Involved (and
Position)
Primary Contact
Phone No.
Names of Inspectors
(and Office)
Dates of Visit
Time of Arrival
Incinerator(s) Inspected
Permit Identification and Date of Issue
(Date of most recent modification
Operational Status of Incinerator(s)
Date of Last Inspection
(by State)
(by EPA
Pending Enforcement Action
Previous Violations
Checklists Attached: No. 1
No. 2
(number of sets )
No. 3
(Attach additional pages if necessary)
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OSWER D1r. No. 9938.6
Description of Incineration system (a block diagram showing the types and
arrangement of equipment 1s recommended).
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OSWER D1r. No. 9938.6
ID I
Date
II. COMPARISON OF PERMIT AND OPERATING CONDITIONS
Date
Time Readings Began
Time Readings Ended
A. Permit Operating Parameters
1. Temperature measured at each
combustion chamber exit
Permitted Permitted Observed
Maximum Minimum Reading(s) Calculated
(units) (units) (units) Value
a. Primary
b. Secondary
c.
d.
NA
NA
NA
NA
NA
NA
NA
NA
CO emissions measured at
the stack or other appro-
priate location
(location: )
• Does CO monitor automatically correct all readings to 7% 02 based on
actual 02 stack concentration? yes no
If no, does permit require 02 correction?
the correction factor to be used?
Date correction factor last determined
changes made in 02 correction factor.
If so, list it.
Does permit specify
Describe any
Permit-specified frequency for verifying 02 correction factor
• If a 60-minute rolling average is required, does the observed reading
reflect a 60-minute rolling average?
yes no not applicable
If no, attach data and calculate the average.
02 emissions (location):
4. Flue gas flow rate or
velocity measured at stack
or equivalent method:
NA
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OSWER Dlr. No. 9938.6
ID I
Date
CHECKLIST NO. 1 (continued)
Permit Operating Parameters
Permitted Permitted Observed
Maximum Minimum Reading(s) Calculated
(units) (units) (units) Value
5. Feed rate of each waste stream to each combustion chamber.
Containerized waste feeds covered under item 10? yes
Chamber Waste Stream
no
(Name or Identifier)
a.
b.
c.
d.
e.
f.
NA
NA
NA
NA
NA
NA
6. Pressure in primary chamber
7. Air pollution control:
a. Liquid flow rate (or NA
liquid/gas ratio) to
absorber
b. Nozzle pressure in
absorber
c. pH of liquid to
absorber
Differential pressure NA
across venturi scrubber
Differential pressure
across baghouse
kV values for ESP or NA
ionizing wet scrubbers
Current for ESP or NA
ionizing wet scrubbers
(minimum)
(minimum)
NA
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OSWER D1r. No. 9938.6
ID I
Date
CHECKLIST NO. 1 (continued)
Permitted Permitted Observed
Maximum Minimum Reading(s) Calculated
Permit Operating Parameters (units) (units) (units) Value
h. Liquid flow rate to NA
dry scrubber
1. Nozzle pressure to
dry scrubber
j. pH of liquid to NA
dry scrubber
k. Particulate scrubber NA
blowdown rate
1. Quench flow rate NA
m.
n.
8. Inlet gas temperature to air
pollution control devices
a. NA
b. NA
c. NA
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ID I
Date
CHECKLIST NO. 1 (continued)
9. Liquid Injection burner settings:
Permitted
Permitted Minimum Observed
Maximum Burner Observed Nominal Calculated Atom1zat1on Atomlzatlon
Feed Rate/ Burner Burner Burner Fluid Fluid
Chamber Burner No. Turndown Ratio Flow Rate Flow Rate Turndown Pressure Pressure
a.
b.
c.
e.
f.
g.
h.
1.
j.
k.
o
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CHECKLIST NO. 1 (continued)
10. Containerized waste feed system limitations:
Permitted Container Observed Container
Chamber Feed Rate Type and Size Type and Size
a.
b.
C.
d.
o
oo
30
o
—i*
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OSUER Dir. No. 9938.6
ID #
Date
CHECKLIST NO. 1 (continued)
Permitted Permitted Observed
Maximum Minimum Reading Calculated
Permit Operating Parameters (units) (units) (units) Value
11. Additional permit conditions
a.
b.
c.
d.
e.
f.
9-
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ID #
Date
CHECKLIST NO. 1 (continued)
B. Characterization of wastes and fuels fed during the observation period
1. Organics and physical characterization
Organic constituents
(limitations, Heating .Specific
compounds, Ash Chloride Viscosity Value Gravity Other
etc.) ( ) ( 1 i 1 (Btu/lb) i I
(a) Combined waste stream
limitations in permit
(b) Limitations in permit
for individual
waste streams:
Chamber Haste Stream
(1)
(2)
(3)
(4)
(5)
(6)
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ID I
Date
CHECKLIST NO. 1 (continued)
Organic constituents
(limitations,
compounds,
etc.)
(c) Analysis characteristics
of combined waste stream
(d) Characterization of
waste streams fed during
Inspection:
Chamber Waste Stream
(D
(2)
Ash
Heating Specific
Chloride Viscosity Value Gravity
( ) ( ) (Btu/lb) ( )
(Range of Dates of Analysis
Other
(3)
(4)
(5)
(6)
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2.
(a)
(b)
(1)
S 0
(3)
(4)
(5)
(6)
Metals
Combined waste stream
limitations In permit
Limitations 1n permit for
individual waste streams:
Chamber Haste Stream
CHECKLIST NO. 1 (continued)
Metals (Units
\
"Carcinogenic"
"Noncarclnoqenlc"
_
AsCdCrBeSbBaPbHa
Ag U
/O
O
ID
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ID »
Date
CHECKLIST NO. 1 (continued)
2. Metals (continued)
Metals (Units,
1
"Carcinogenic"
"Noncarclnogenlc"
AsCdCrBeSbBaPbHg.
AS n
(c) Analysis characteristics
of combined waste streams
(d)
(1)
(2)
Characterization of waste
streams fed during
Inspection:
Chamber Waste Stream
(3)
(4)
(5)
(6)
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CHECKLIST NO. 1 (concluded)
3. Auxiliary fuel and total heat Input:
a. Observed
Auxiliary Fuel Flow Rate Heating Value Heat Input from
Type of Fuel Chamber (units) (units) fuel (units)
b. Total heat Input
(units) 8
70
Permitted total heat input 2
Observed fuel heat input
Observed waste heat input ?
Observed total heat input f°
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OSUER 01r. No. 9938.6
ID #
Date
CHECKLIST NO. 2—VISUAL ASSESSMENT AND AUDIT ACTIVITIES FOR
AN "IN-DEPTH" INSPECTION
I. VISUAL ASSESSMENT OF PERFORMANCE, OPERATIONS,
AND ENVIRONMENTAL SAFETY
A. Observation of Equipment/Function (1, etc. = Problem note (see below)]
Leaks/ Structural Proper Safety
Emissions Seals Integrity Function Issues
—Waste unloading
—Waste storage/blending
—Waste handling/piping
—Waste feed/fuel systems
—Combustion chambers/burners
—K1ln drive system
—Combustion air fans
—Connecting ducts
—Pollution control devices
•Absorber
•Venturi scrubber
•Ionizing wet scrubber
•Baghouse
—Emergency vent stack
(dump stack)
—Process instrumentation
—Ash handling system
—Scrubber effluent handling
Notes
1.
A-17
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OSWER Dlr. No. 9938.6
ID #
Date
CHECKLIST NO. 2 (continued)
B. Observed Operations [Give brief description of problem, or reference a Note below
(1,2, etc.)]
Status/Comments
—Records of permit parameters
(complete, accessible)
—Proper identification of date, time,
and units on strip charts
—Records of waste acceptance
handling
characterization
—Log of inspections
calibrations
maintenance
--Subjective evaluation of operators
—Staff knowledge of emergency procedures
contingencies
—Handling/fate of residuals
•Primary chamber ash
•Scrubber effluent ( )
•Scrubber effluent ( )
—Appearance of stack emissions
Notes
1.
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OSWER D1r. No. 9938.6
ID #
Date
CHECKLIST NO. 2 (continued)
C. General Quality of Operation
Comments
—Odors
—Housekeeping
•Storage areas
•Waste feed areas
•Control room
•General facility
•Laboratory
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ID f _
Date _
CHECKLIST NO. 2 (continued)
II. IN-DEPTH AUDITS AND DOCUMENTATION REVIEW
A. Audits of Equipment Function
1. Continuous Emission Monitors (CEMS)
Observe a calibration check by facility staff of each CEM required 1n the permit. Note the
following:
a. Background information
Calibration
_ Instrument _ Extractive Frequency of Manual or automatic reference*
Parameter Manufacturer Model No. or in situ calibration calibration material
-
0 CO
•jo
o
—I.
-J
\o
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ID I
Date
b. Calibration
CHECKLIST NO. 2 (continued)
Instrument Reading
Certified Concentration
of Reference Material*
Parameter
CO
02
Date/Time of Std. Std. Std. Std. Std.
Observation "Zero" No. 1 No. 2 No. 3 Correction** No. 1 No. 2
Std.
No. 3
ro
* One reference for extractive monitors may be an "unknown" standard gas supplied by the Inspector.
** Provide details 1n the space below about any correction factors applied to the readings.
c. Modifications
Has any Instrument or sampling location been changed since the permit was issued/modified?
Provide details.
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ID #
Date
CHECKLIST NO. 2 (continued)
2. Observe the operation of the automatic waste feed cutoff system in
response to simulated upset conditions for each automatic cutoff
condition required in the permit [Note: At least one test must involve
an actual shutdown. *S = Simulated, A = Actual]:
Automatic Permit Limits Observed Adequate
Cutoff Conditions Value Time Lag ValueTime Lag S or A* Function?
• Minimum temperature
Chamber ( )
Chamber ( )
Chamber ( )
Maximum CO
Other CO limit
Maximum flue gas
flow rate/velocity
Maximum feed rate
(streams)
Pressure in primary
combustion chamber
Air pollution
control:
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OSWER Dir. No. 9938.6
ID #
Date
CHECKLIST NO. 2 (continued)
Automatic Permit Limits Observed Adequate
Cutoff Conditions Value Time Lag Value Time Lag S or A* Function?
Other automatic shutdown conditions in permit:
* Simulated (S) or actual (A) shutdown.
3. Review documentation of the most recent calibration of the monitoring
instrumentation for all permit operating parameters specified in the
permit. Discuss procedures used with the facility staff. (Provide
notes for each parameters—attach note pages as applicable.)
Note No.
• Temperature indicators (for each combustion chamber exit)
• Feed rate indicators (flowmeters, weigh scales)
• Combustion gas velocity Indicator
• Flowmeters in APCE
• Pressure indicators in combustion chambers and APCE
• pH meter
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OSWER 01r. No. 9938.6
ID #
Date
CHECKLIST NO. 2 (continued)
B. Audits of Waste Characterization and Handling [1, etc. =
Problem note (see below)]
Status
1. Review of Waste Characterization
a. Analysis of appropriate parameters
b. Frequency of analysis
c. Adequate analysis documentation (subjective)
2. Review of Waste Handling Documentation
a. Waste acceptance
- Manifest/Logs
- "Fingerprint" analysis
b. Blending/feeding logs
3. Review of on-site laboratory (optional)
a. Calibration records
b. Maintenance records
c. Availability of Analytical and QA/QC Procedures ^^^
C. Review of Other Records Required by the Permit
1. Records of Dump Stack Openings
- Openings documented: incidents since (date of
last inspection) or __^ in last 12 months (reported to
state or ~EPAl
- Temperature maintained during openings
- Minimum airflow maintained during openings
- Causes
- Corrective actions
2. Records of Automatic Waste Feed Cutoff (AWFCO)
- Documented
- Frequency of cutoff incidents
( per month or per day (average of days)
- Major causes for AWFCO
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OSUER D1r. No. 9938.6
ID #
Date
CHECKLIST NO. 2 (concluded)
3. Inspection Logs/Calibration Records
- Complete
- Adequate schedule
- Recurring problems
4. Maintenance Records
- Complete
- Timely corrective action
- Routine maintenance performed on schedule
- Frequency?
- Note any reoccurring maintenance problems
- List any equipment replaced since last inspection
(obtain manufacturer's specifications)
D. Audit of Waste Analysis (optional)
- Provide check samples for analysis by the facility lab or obtain
sample splits for return to agency labs (or agency contractor lab)
- Document the origin of each sample
- Identify the parameters for analysis, analysis methods, sampling han-
dling/storage limitations, and any essential QA/QC requirements to be
completed by the facility's lab and the agency lab (if applicable)
Notes:
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OSWER Dir. No. 9938.6
ID #
Date
CHECKLIST NO. 3--VISUAL ASSESSMENT AND AUDIT ACTIVITIES FOR
A "WALK-THROUGH" INSPECTION
I. VISUAL ASSESSMENT OF PERFORMANCE, OPERATIONS,
AND ENVIRONMENTAL SAFETY
A. Observation of Equipment/Function [1, etc. = Problem note (see below)]
Leaks/ Structural Proper Safety
Emissions Seals Integrity Function Issues
—Waste unloading
—Waste storage/blending
—Waste handling/piping
—Waste feed/fuel systems
—Combustion chambers/burners
—Kiln drive system
--Combustion air fans
—Connecting ducts
—Pollution control devices
•Absorber
•Venturi scrubber
•Ionizing wet scrubber
•Bag house
—Emergency vent stack
(dump stack)
—Process instrumentation
—Ash Handling System
—Scrubber Effluent Handling
Notes
1.
A-26
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OSWER Dir. No. 9938.6
ID #
Date
CHECKLIST NO. 3 (continued)
B. Observed Operations [Give brief description of problem or reference a note below
(1. 2, etc.)!
Status/Comments
—Records of permit parameters (complete,
accessible)
—Proper identification of date, time,
and units on strip charts
—Records of automatic waste feed
cutoff (AWFCO)
• Documented
• Frequency of cutoff incidents per month
or per day (average of days)
• Major causes for AWFCO
—Records of dump stack openings
• Openings documented: incidents since (date of last inspection)
or in last 12 months (reported to state or EPA)
• Temperature and airflow maintained
• Causes
• Corrective actions ZZZZHIZZ^^Z^^^^ZZ^^ZZIZZZZZZIZZIZZZZZ
—Records of waste acceptance
hand1i ng
characterization
—Log of inspections
calibrations
maintenance
—Staff knowledge of emergency procedures
contingencies
—Appearance of stack emissions
Notes
1.
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OSUER Olr. No. 9938.6
ID I
Date
CHECKLIST NO. 3 (continued)
C. General Quality of Operation
Comments
—Odors
—Housekeeping
•Storage areas
•Waste feed areas
•Control room
•General facility
--Laboratory
A-28
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10 I
Date
CHECKLIST NO. 3 (continued)
II. QUICK AUDIT OF PERFORMANCE
1. Continuous Emission Monitors (CEHS)
Observe a calibration check by facility staff of each CEH required 1n the permit. Note the following:
a. Background Information
Calibration
Instrument Extractive Frequency of Manual or automatic reference*
Parameter Manufacturer Model No. or 1n situ calibration calibration material
>
^ 0
vo
CO
2
o
s!
m
30
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o
ID i
Date
CHECKLIST NO. 3 (continued)
b. Calibration
Certified Concentration
Instrument Reading of Reference Material*
Date/Time of Std. Std. Std. Std. Std. Std.
Parameter Observation "Zero" No. 1 No. 2 No. 3 Correction** No. 1 No. 2 No. 3
CO
02
* One reference for extractive monitors may be an "unknown" standard gas supplied by the inspector.
** Provide details 1n the space below about any correction factors applied to the readings.
c. Modifications
Has any instrument or sampling location been changed since the permit was issued/modified? Provide
details.
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OSWER Dir. No. 9938.6
ID f
Date
CHECKLIST NO. 3 (concluded)
2. Observe the operation of the automatic waste feed cutoff system in response
to one or more simulated or actual upset conditions. At least one
observation should include an actual shutdown.
Permit Actual or Adequate
Parameter Demonstrated Limit Value Observed Value Simulated Function?
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OSWER Dir. No. 9938.6
APPENDIX B
CALCULATIONS
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OSWER Oir. No. 9938.6
This appendix contains calculations that inspectors may need to perform as
part of incinerator inspections. Inspectors may need to complete two types of
calculations in order to compare actual operating conditions/activities at an
Incinerator with limitations specified in the facility's permit.
The first type of problem is essentially a unit conversion. These will be
needed whenever permit-limited parameters are monitored and logged in units or
forms that differ from those specified in the permit. Conversions may
include:
English system/metric system conversions.
Mass/volume conversions.
Converting monitored conditions to standard conditions.
Calculating a ratio comparison of monitored and design conditions.
Other similar conversions.
These types of calculations are demonstrated in Problem Nos. 1 and 2 in this
appendix.
The second type of calculation involves waste characterization data. These
data are recorded typically as concentrations (mg/L) or in a similar form
(Btu/lb). Typically, inspectors will need to convert some of these values
into a loading rate (lb/hr, Btu/hr, etc.) to allow a direct comparison with
specified permit conditions. Problem Nos. 3 to 5 address this type of
calculation.
The conversion chart provided below lists factors that may be needed by
inspectors to complete calculations in the field:
Conversions
English Metric
1 Ib 454 g
1 atm 760 mm Hg
35.3 fts 1,000 L (or 1 m3)
1 gal 3.785 L
(°F-32) x 5/9 °C
Misc.
1 atm = 14.7 psi = 29.92 in Hg
Density of water = 62.4 Ib/fta or 8.34 Ib/gal (at 60°F)
= 1 g/cm3 at 0°F
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OSWER D1r. No. 9938.6
1. SPECIFIC GRAVITY AND DENSITY
• Density = mass per unit volume (p)
Ib/ft3
Ib/gal
g/cm3
Specific gravity = ratio of two densities with H20 being the
reference fluid (unitless)
* Specific gravity Compound A =
Key constants or conversion values
Density of H20 = 62.4 Ib/ft3 or 8.34 Ib/gal (at 60°F) or 1 g/cm3 (at 4°C)
1 Ib = 454 g
35.3 ft3 = 1 m3 = 1,000 L
Examples
a. What is the density of a liquid waste feed with a specific gravity of
0.86?
Density Waste = (Sp. Gr. Waste)(Density of H20)
= (0.86)(8.34 Ib/gal)
= 7.17 Ib/gal
b. A 55-gal drum contains a sludge with a specific gravity of 1.2. What is
the total weight of the contents (in Ib)?
Density Waste = (Sp. Gr. Waste)(Density of H20)
= (1.2)(8.34 Ib/gal)
= 10.0 Ib/gal
Weight = (Density)(Volume)
= 10 Ib/gal • 55 gal
= 550 Ib
B-3
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OSWER Dir. No. 9938.6
2. VOLUMETRIC FLOW RATES AND IDEAL GAS LAW
• Gas volumes typically measured at either standard conditions or
actual conditions. Permit limits may also be stated in either
standard or actual conditions.
Standard conditions:
~ SI T = 20°C
P = 1 atm
-- English T = 68°F
P = 29.92 in Hg
• Use ideal gas law to translate between actual and standard
conditions:
P v P v
r1V1 r2V2
PV = nRT or -y— = -=—
11 '2
P = absolute pressure (atm, psi, in Hg, in H20)
V = volume (fts, m3)
T = absolute temperature (K, °R)
n = number of moles
R = ideal gas law constant (appropriate units)
• Temperature conversions
o
F+460 = °R (degrees rankine)
°O273 = K (degrees kelvin)
Example
Convert a stack gas flow rate of 10,000 acfm at 200°F, 28.9 in Hg to
standard conditions.
p v P v
Kstdvstd m *actvact
Tstd Tact
p T
Vstd = act std vact
act std
200°F = 660°R
68°F = 528°R
_ (28.9 in Hq)(528°R)
(660°R)(29.92 in Hg)
= 7,700 cfm (standard conditions)
B-4
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OSWEr
3. HEATING VALUE
Higher heating value (HHV) = enthalpy change or heat released when a
fuel is stoichiometrically combusted at 60°F with final products at
60 °F and water in a liquid state.
Thermal input = mass feed rate x higher heating value.
For multiple feed streams:
n
Heat input = z M.xHHV. where
1-1 n n
M^ = mass feed rate of stream i (Ib/hr)
HHV1 = higher heating value of stream i (Btu/lfc)
Example
Waste stream A has a heating valj? :f
value of 850 Btu/lb, and auxiliary natura1 .,.>•-> dr o tv.at'.r.. -
1,100 Btu/fta. An incinerator burns 500 -c.'f; o: war,ts ^, ?30 \'
waste B, and uses 25,000 ft3/day of natural gas. What Is the -x
input to the incinerator?
Heat Input = MA x HHVA + MB x HHVB + MC x HM",.
= 500 Ib/hr x 5,000 Btu/lb - .'30 "b/hi- x S50 Btv/U- ->
25,000 ftVday x 1 day/24 ^ x \..i :, v\ • '.
= 4.27 x IDs Btu/hr
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OSUER Dir. No. 9938.6
4. HEATING VALUES AND BURNER TURNDOWN
Background; An on-site industrial facility has a liquid injection
incinerator dedicated to a particular process. Typically the facility
burns still bottoms from the process using three burners whose specifi-
cations are attached. The still bottoms have an average heating value of
6,500 Btu/lb and a specific gravity of 0.90. The burners have a nominal
rating of 15 gal/min and a permitted maximum turndown ratio of 3:1.
(Burner turndown is a ratio of design burner flow to actual burner flow
rate.) During the trial burn, the facility ran waste still bottoms
through all three burners at a rate of 11 gal/min. The incinerator is
rated at a maximum thermal capacity of 100 x 10« Btu/hr and that rated
level is established as a permit limit.
Problem; The plant has produced an off-spec product that has the same
Appendix VIII constituents as the still bottoms. This material is
ignitable and has a specific gravity of 0.87 and a heating value of
17,500 Btu/lb. The plant is disposing of the product in the incinerator
at the rate of 1,800 Ib/hr through one burner. The other two burners are
burning still bottoms at the rate of 12 gal/min.
—Is the plant in compliance with burner turndown limits?
—Is the plant in compliance with its maximum heat input limits?
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OSWER Dir. No. 9938.6
Solution to "Heating Value and Burner Turndown" Problem
1. Calculate the density of the off-spec liquid
Density liquid = specific gravity x density H20
= 0.87 x 8.34 Ib/gal
= 7.26 Ib/gal
2. Calculate the liquid flow rate in gal/min
Q (gal/min) = L3MJ* ,
= 4.1 gal/min
3. Calculate turndown ratio
Turndown = Nominal flow
Actual flow
= IL. = 3.7:1
4.1
* Hence the flow is outside limits
4. Calculate density of bottoms
Density bottoms = specific gravity x density H20
= 0.9 x 8.34 Ib/gal
= 7.51 Ib/gal
5. Calculate heat inputs
Heat input bottoms = 24 gal/min x 7.51 Ib/gal x 6,500 Btu/lb x 60 min/hr
= 70.3 x IQs Btu/hr
Heat input off-spec materials = 1,800 Ib/hr x 17,500 Btu/lb
= 31.5 x 106 Btu/hr
Total heat input = 70.3 x 106 + 31.5 x 106
= 101.8 x 10« Btu/hr
* Hence the heat input exceeds the permit limit
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OSWER Oir. No. 9938.6
5. ASH AND CHLORIDE INPUT RATES
A small liquid injection incinerator has only a packed-bed scrubber for
air pollution control. The scrubber has been found to be only about 90%
efficient for HC1 control. Consequently the chloride input rate is
limited to 30 Ib/hr and ash input to the incinerator is limited to
2.5 Ib/hr. A review of the records show that over a 2-week period the
plant burned waste A at the rate of 2.5 gal/min and waste B at the rate
of 10 gal/min. These wastes had the following properties:
Type Waste A Organic Waste B Aqueous
Heating value (Btu/lb) 15,000 600
Organic chlorine 3.2% 0.1%
Ash content 0.06% 0.05%
Specific gravity 0.9 1.0
Was the system in compliance with the ash and chloride limits in the
permi t?
B-8
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OSWER Dir. No. 9938.6
Solution to "Ash Chloride Input Rates" Problem
1. Calculate densities of feeds
Density A = 0.9 x 8.34 Ib/gal = 7.51 Ib/gal
Density B = 8.34 Ib/gal
2. Calculate mass- feed rates
•
MA = 2.5 gal/min x 7.51 Ib/gal x 60 min/hr = 1,130 Ib/hr
•
MB = 10 gal/min x 8.34 Ib/gal x 60 min/hr = 5,000 Ib/hr
3. Calculate chloride input rates
. *C1A • %C1B
C1total = MA TOO" + MB TOO"
= 1,130 (0.032) + 5,000 (0.001)
= 41 Ib/hr
* Hence the chloride input exceeds the permit limit
4. Calculate ash input rates
Ash total .
= 1,130 (0.006) + 5,000 (0.0005)
= 3.2 Ib/hr
* Hence the ash input exceeds the permit limit
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OSWER D1r. No. 9938.6
APPENDIX C
DRAFT MODEL INCINERATOR PERMIT
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OSWER Oir. No. 9938.6
September 1988
MODULE IX(A) - INCINERATION
[Note: This module, plus Module IX(B) for Short-Term Incineration,
covers the four major phases of incineration operation: (1) shakedown;
(2) trial burn; (3) post-trial burn operation; and (4) final operation.
This module provides the conditions for final operation for both existing
and new incineration units. The Short-Term Incineration Module covers
the shakedown, trial burn, and post-trial burn operating phases for new
incineration units only. These phases of operation are discussed in 40
CFR 264.344(c).l
[Note: This module is not used for incineration units that qualify for
an automatic exemption under 40 CFR 264.340(b). These units must comply
only with the waste analysis and closure requirements. For units that
are granted an exemption under 40 CFR 264.340(c), parts of this module
may be appropriate to use on a case-by-case basis. The Permit Writer
should document the basis for granting exemptions in the Administrative
Record for this facility.]
[Note: For facilities with more than one incineration unit, a separate
permit module should be used for each unit.]
[Note: Waste analysis requirements (40 CFR 264.13) and closure
requirements (40 CFR 264.197) for incineration units are generally
contained as attachments to the Permit in the Waste Analysis Plan and
Closure Plan. The Waste Analysis Plan and Closure Plan must cover the
requirements of 40 CFR 264.341 and 40 CFR 264.351, respectively, in
accordance with 40 CFR 264.340(b).]
[Note: For new incinerators, some permit conditions will initially be
tentative and will need to be finalized after the trial burn results have
been evaluated. In this module, the conditions that may be subject to
change for new incinerators are marked with an asterisk (*). In crafting
actual permit conditions, the Permit Writer should mark tentative
conditions with an asterisk, or other designation, and include a note
such as the following. . .*The number in this permit condition is tentative
and will be made final after the trial burn results have been evaluated.
In the case of maximums, EPA reserves the right to specify any number
less than this value as the shut-off limit. In the case of minimums, EPA
reserves the right to specify any value higher.]
[Note: The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions. See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]
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o No hazardous constituents shall have a heat of
combustion less than that of
[POHC] ( BTU/lb).
[Note: Using the heat of combustion method of
incinerability ranking, the specified POHC
should be the facility's POHC with the lowest
heat of combustion. It should be noted that
other methods of incinerability ranking, such as
thermal stability at low oxygen are available.
(See preamble to proposed incineration
amendments. Summer 1988.) Use of another
ranking system in addition to, or instead of,
heat of combustion would require modification of
this model condition.]
o The ash content of the waste shall be no greater
than percent by weight.*
o The total halide content of the waste shall be
no greater than percent by weight.*
o The physical state of the waste feed shall be
. [specify solid or liquid]
o No waste, or combination of wastes, with a
heating value of less than BTU/lb [or
other appropriate unit of measure], shall be fed
to the secondary chamber of the incinerator [or
( in the case of a single chamber liquid
injection incinerator) to the incinerator]
unless fed in conjunction with auxiliary fuel.
o The viscosity of waste fed to the secondary
chamber [or incinerator, in the case of single
chamber liquid injection incinerator] burner
number shall not exceed cp.
IX(A).B.2. [Option 2 - On-Site Facility] The Permittee may
incinerate only the following hazardous wastes:
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Hazardous Waste No. Description Feed Rate
[Example:
D003, D004, D008 Freezon 123b reactor (Specify rate of input
bottoms ('Tars') in appropriate units--
Ib/hr)
DOOl Freezon 122b rich (Specify rate of input
liquid in appropriate units--
lb/hr)]
[Note: The Permit Writer may impose other limitations, such as those
under Option 1 above, on the waste feed, as necessary, to ensure
compliance with the performance standards of 40 CFR 264.343. All such
limitations, however, should be derived from the results of the trial
burn or from the data submitted in lieu of a trial burn, or for
conditions such as waste feed viscosity, from the burner manufacturer's
specifications.]
IX(A).B.3. Throughout operacion, the Permittee shall conduct
sufficient analysis in accordance with the Waste
Analysis Plan, Permit Attachment II-l. to verify that
waste fed to the incinerator is within the physical
and chemical composition limits specified in this
Permit.
[Note: The Permit Writer may also include here a list of specific
wastes or materials that are prohibited. ]
IX(A).C. CONSTRUCTION. INSTRUMENTATION. AND OPERATIONAL PERFORMANCE
REQUIREMENTS
[Note: Permit Condition IX(A).C.l. applies only to new facilities;
Permit Condition IX(A).C.2. applies only to existing facilities.]
IX(A).C.l. The Permittee shall construct and maintain the
incinerator in accordance with the design plans and
specifications contained in Permit Attachment IXfA)-
2.. The Permittee shall not feed hazardous wastes to
the incinerator until Permit Condition I.E. 12
(Certification of Construction or Modification) has
been complied with.
IX(A).C.2. The Permittee shall maintain the incinerator in
accordance with the design plans and specifications
contained in Permit Attachment IX(A)-2.
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[Note: 40 CFR 264.345(b)(5) requires that the Permit
specify any allowable variations in system design
during the operation of the incinerator. The Permit
Writer should develop additional conditions, as
necessary, to cover these variations and/or provide a
description of these variations as an attachment to
the Permit. Permit Attachment IXOO-3.J
IX(A).C.3. The Permittee shall install and test all
instrumentation in accordance with the design plans,
performance specifications, and maintenance
procedures contained in Permit Attachment IX(A)-2
prior to handling hazardous wastes in the incinerator
unit.
The Permittee shall [design, construct, and] maintain the
incinerator so chat when operated, in accordance with the operating
requirements specified in this permit, it will meet the performance
standards specified in Permit Conditions IX.(A).C.4. through
IX.(A).C.6. [40 CFR 264.343]
IX(A).C.4. The incinerator shall achieve a destruction and
removal efficiency (DRE) of 99.99 percent for each of
the following principal organic hazardous
constituents (POHC) for each waste feed. The ORE
value shall be determined using the method specified
in 40 CFR 264.343(a)(1). [40 CFR 264.343(a)(1)]
[Note: Any incinerator burning hazardous wastes
F020, F021, F022, F023, F026, or F027 must achieve a
DRE of 99.9999 percent for each designated POHC.
These POHCs, designated by the Permit Writer, must be
more difficult to incinerate than tetra-, penta-, and
hexachlorodibenzo-p-dioxins and dibenzofurans. ] [40
CFR 264.343(a)(2)]
Waste Feed POHCfs)
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IX(A).C.5. The Permittee shall control hydrogen chloride (HC1)
emissions, such that the rate of emissions is no
greater than the larger of either 1.8 kilograms per
hour (4 pounds/hour) or one percent of the HC1 in the
stack gas, prior to entering any pollution control
equipment. [40 CFR 264.343(b)]
IX(A).C.6. The incinerator shall not emit particulate matter in
excess of 180 milligrams per dry standard cubic meter
(0.08 grains per dry standard cubic foot) when
corrected for the amount of oxygen in the stack gas,
in accordance with the formula specified in 40 CFR
264.343(c). [40 CFR 264.343(c)]
[Note: The Permit Writer should add the appropriate
correction procedure to this condition in cases where
a facility operates under conditions of oxygen
enrichment. [40 CFR 264.343(c)]
[Note: 40 CFR 264.345(b)(1)-(4) requires the Permit Writer to establish
operating limits for carbon monoxide, waste-feed rate, combustion
temperature, and a combustion gas velocity indicator. Permit Conditions
IX(A).C.7. through IX(A).C.10. cover those.requirements. 40 CFR
264.345(b)(6) requires the Permit Writer to establish any other operating
requirements (conditions) necessary to ensure compliance with the
performance standards. Permit Conditions IX(A).C.ll. through IX(A).C.22.
are example permit conditions that serve this purpose. These permit
conditions incorporate the list of key operating parameters provided by
the EPA Guidance on Trial Burn Reporting and Setting Permit Conditions.
This guidance should be consulted for assistance in determining which of
these conditions apply for a specific facility and the specific method of
setting each condition, given the design and operation of the facility
and the results of the trial burn or data in lieu of a trial burn. ]
Except during the periods specified in the Permit Conditions for Short-
Term Incineration under the Shakedown Period, Trial Burn Period, and
Post-Trial Burn Period, the Permittee shall feed the wastes described in
Permit Condition IX(A).B. to the incinerator only under the following
conditions: [40 CFR 264.345]
IX(A).C.7. Carbon monoxide concentration in the stack exhaust
gas, monitored as specified in Permit Condition
IX(A).E., and corrected for the amount of oxygen in
the stack gas, shall not exceed ppm over a one
hour rolling average [or under the alternative format
for CO limits, ppm at any time, or ppm for
more than minutes in any clock hour].*
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IX(A).C.8. The Permittee shall be limited to the following waste
feed rates in the following locations:
[Note: The Permit should specify the feed rate of
each waste stream type (i.e., solid waste, organic
liquid waste) to each combustion chamber. The
following are example conditions. The Permit Vriter
shall select the condition(s) that are most
appropriate for the Permit being prepared.]
(a) Maximum primary chamber organic liquid waste
feed rate of lb/hr.*
(b) Maximum primary chamber aqueous waste feed rate
of lb/hr.*
(c) Maximum primary chamber solid waste feed rate of
lb/hr.*
(d) Maximum secondary chamber organic liquid waste
feed rate of lb/hr.*
(e) The size of waste containers fed to the primary
chamber shall not exceed gallons of
capacity.*
IX(A).C.9. Combustion temperature, monitored as specified in
Permit Condition IX(A).E., shall be maintained at
"F (or QC) or greater.*
[Note: For dual-chamber incinerators, a minimum
temperature should be set for each chamber.]
IX(A).C.10. Combustion gas velocity, monitored as specified in
Permit Condition IX(A).E., shall be no greater than
ft/s.*
IX(A).C.ll. The mass feed rates of toxic metals to the
incinerator shall not exceed:
Arsenic:
Barium:
Chromium:
Beryllium:
Cadmium:
(grams/min) Antimony:
(grams/min) Lead:
(grams/min) Mercury:
(grams/min) Silver:
(grams/min) Thallium:
(grams/min)
(grams/min)
(grams/min)
(grams/min)
(grams/min)
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[Note: An option to Permit Condition IX(A).C.ll.,
which would be more straightforward to enforce, is to
set the limit on the actual concentration of metals
in the waste feed. Then only the concentration value
is required to determine compliance, rather than the
concentration and waste feed rate at a specific point
in time. However, this approach provides the
Permittee with less flexibility to feed higher
concentrations of metals when operating the
incinerator at low feed rates.
IX(A).C.12. Atomization fluid pressure (e.g., steam, air) shall
be no less than psig.
IX(A).C.13. The turndown ratio for the waste burner shall be no
greater than .
[Note: Permit Conditions IX(A).C.14. through IX(A).C.16 relate to
ensuring compliance with the HC1 emission standard in 40 CFR
264.343(b). The Permit Writer must determine which conditions are
appropriate for a specific facility depending on the control devices
present.]
IX(A).C.14. The ^ ratio to the absorber, monitored as specified
G
in Permit Condition IX(A).E., shall be maintained at
no less than [sometimes expressed as gals per
thousand cubic feet though usually dimensionless].*
IX(A).C.15. The scrubber effluent pH, monitored as specified in
Permit Condition IX(A).E., shall be maintained at a
minimum pH of .*
IX(A).C.16. The scrubber water delivery (nozzle) pressure,
monitored as specified in Permit Condition IX(A).E.,
shall be maintained at no less than psig.
[Note: Permit Conditions IX(A).C.17. through IX(A).C.22. relate to
ensuring compliance with the particulate emission standard in 40 CFR
264.343(c). Note, however, that most facilities will not have all
of the devices mentioned. The Permit Writer must determine which
conditions are appropriate for a specific facility.]
IX(A).C.17. Pressure drop across the venturi scrubber, monitored
as specified in Permit Condition IX(A).E., shall be
maintained at no less than psi.*
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IX(A).C.18. The scrubber blowdown rate shall be maintained at no
less than gpm.*
IX(A).C.19. The power to the electrostatic precipitator,
monitored as specified in Permit Condition IX(A).E.,
shall be maintained at no less than kVA.*
IX(A).C.20. The voltage applied to the ionizing wet scrubber,
monitored as specified in Permit Condition IX(A).E.,
shall be no less than kV.*
IX(A).C.21. Pressure drop across the baghouse, monitored as
specified in Permit Condition IX(A).E., shall be no
less than psi, nor greater than psi.*
[Note: The Permit Writer may require the Permittee
to specify in the Contingency Plan, provisions for
maintaining and replacing bags.]
IX(A).C.22. The Permittee shall control fugitive emissions from
the combustion zone of the incinerator by maintaining
the pressure in the primary combustion chamber,
monitored as specified in Permit Condition IX(A).E.,
to not exceed inches of mercury. [40 CFR
264.345(d)]
[Note: The Permit Vriter may specify another method
for controlling fugitive emissions. The method must
be demonstrated in the Part B Permit Application;
this information should be attached to the Permit,
Permit Attachment IX(A)-4. and referenced.]
IX(A).C.23. Compliance with the operating conditions specified in
Permit Conditions IX(A).C.7. through IX(A).C.22. will
be regarded as compliance with the required
performance standards in Permit Conditions IX(A).C.4.
through IX(A).C.6. However, evidence that compliance
with these operating conditions is insufficient to
ensure compliance with the performance standards, may
justify modification, revocation, or reissuance of
the Permit pursuant to 40 CFR 270.41. [40 CFR
264.343(d)]
[Note: It must be understood, by both the Permit
Vriter and Permittee, that violation of the permit
operating conditions can give rise to an enforcement
action. If the Permittee complies with the permit
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operating conditions, but it is later shown that the
performance standards are not being achieved, the
permit may be modified or revoke and reissued, but
enforcement actions are not available. Thus, each
set of operating conditions should directly relate to
achieving the performance standards in 40 CFR
264.343.]
IX(A).D. INSPECTION REQUIREMENTS
The Permittee shall inspect the incineration unit in accordance with the
Inspection Schedule, Permit Attachment II-3. and shall complete the
following as part of these inspections:
IX(A).Dil. The Permittee shall thoroughly, visually inspect the
incinerator and associated equipment (including
pumps, valves, conveyors, pipes, etc.) for leaks,
spills, fugitive emissions, and signs of tampering.
[40 CFR 264.347(b)]
IX(A).D.2. The Permittee shall thoroughly, visually inspect the
instrumentation for out-of-tolerance monitored and/or
recorded operational data.
IX(A).D.3. The Permittee shall test the emergency waste feed
cut-off system and associated alarm at least weekly
to verify operability, as specified in Permit
Condition IX(A).E.l. [40 CFR 264.347(c)]
[Note: If the Permittee demonstrates to the Regional
Administrator that the weekly inspections referred to
in Permit Condition IX(A).D.3 will unduly restrict or
upset operations and that less frequent inspection
will be adequate, the Permit Writer should specify
that inspection frequency in the permit condition.
At a minimum, operational testing must be conducted
at least monthly.]
IX(A).E. MONITORING REQUIREMENTS
IX(A).E.l. The Permittee shall maintain, calibrate, and operate
monitoring equipment and record the data while
incinerating hazardous waste, as specified below:
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System Monitor Location Recording Calibration
Parameter Type, Process Frequency
Instr.
No.
Examples
(1) Com-
bustion
Tempera -
(2) Pres-
sure drop
Type K
Thermo >
couple
TIC- 900
Pressure
Sensor
[Us
design
drawing
numbers
to show
the loca-
tion]
[ Indicate
whether
continuous
or not]
[ Frequency
at which the
unit is
calibrated
across PDIC-
scrubber 1220
venturi
[Note: At a minimum, this condition must specify monitoring systems that
meet the requirements of 40 CFR 264.347(a)(1) and (2). Permit Condition
IX(A).E.l. contains example specifications for various operating
parameters that must be monitored. Specific parameters should be
addressed in the above table. If the Part B Permit Application contains
the above information on monitoring practices, in a conveniently
organized way and adequately detailed, then the Permit Writer may attach
this information, Permit Attachment IX(Al-5. to the Permit instead of
using a table in this permit module, and reference the attachment.]
IX(A).E.2 Upon request of the Agency, the Permittee shall
perform sampling and analysis of the waste and
exhaust emissions to verify that the operating
requirements established in the Permit achieve the
performance standards. [40 CFR 264.347(a)(3)]
IX(A).F. WASTE FEED CUT-OFF REQUIREMENTS
IX(A).F.l. The Permittee shall construct and maintain the
systems specified below to automatically cut off the
hazardous waste feed to the incinerator at the levels
specified below. Hazardous wastes shall be fed to
the incinerator only when all instruments required by
this condition are on line and operating properly.
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Test
Parameter Cut-Off Limits Frequency
Operating [Level at which [Frequency at
parameters waste feed will which opera-
te be Inter- be cut off] tlonal readiness
locked to is checked]
automatic
waste-feed
cut off i.e..
SCC temper-
ature]
[Note: 40 CFR 264.345(e) requires such systems to be constructed to
ensure that the operating conditions specified in the Permit are not
exceeded. Host cut-off systems are composed of multiple parameters.
They include monitors for the operating conditions presented in Permit
Condition IX(A).C. along with power failure and flame-out. If the Part B
Permit Application adequately provides the above information regarding
the automatic waste-feed cut-off system in an organized way and
adequately detailed, then the Permit Writer may attach this information.
Permit Attachment IX(A)-6. to the Permit, in lieu of using a table in
this permit module, and reference the attachment.]
IX(A).F.2. In case of a malfunction of the automatic waste feed
cut-off systems, the Permittee shall perform manual
shut downs in accordance with the approved procedures
in Permit Attachment IX(A)-7. The Permittee shall
not restart the incinerator until the problem causing
the malfunction has been located and corrected.
IX(A).G. CLOSURE
The Permittee shall follow the procedures in the Closure Plan, Permit
Attachment II-9. [40 CFR 264.351]
IX(A).H. RECORDKEEPING
IX(A).H.l. The Permittee shall record and maintain, in the
operating record for this permit, all monitoring and
inspection data compiled under the requirements of
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this Permit (see Permit Condition I.E.9.O.). [40 CFR
264.73 and 40 CFR 264.347(d)]
IX(A).H.2. The Permittee shall record in the operating record
for this permit the date and time of all automatic
waste feed shut-offs, including the triggering
parameters, reason for the shut-off, and corrective
actions taken. The Permittee shall also record all
failures of the automatic waste feed shut-offs to
function properly and corrective actions taken.
IX(A).I. COMPLIANCE SCHEDULE
[Note: The Permit Writer should include this condition if the Permittee
is required to complete specific steps within a specific time period,
beyond those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit. Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee,
before the Permit is issued, are deferred for good cause until after
permit issuance. Compliance schedules included in the Part B Permit
Application should be attached to the Permit. If the application does
not include a compliance schedule, the Permit Vriter should prepare one
and attach it to the Permit. Each compliance schedule should have at
least two columns - one identifying the activity and one identifying the
milestone or completion dates. The following is an example of a
condition that may apply for incineration units.]
The Permittee shall provide the following information to the Regional
Administrator:
Item Date Due to the Regional Administrator
[Example:
1. Documentation that May 12, 1989
thermocouple No. TC 2
was installed as shown
on Drawing No. 960,
dated March 18, 1987
2. As-built construction February 13. 1989]
drawings for installation
of Pressure Sensor No. PS 4
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PERMIT ATTACHMENTS REFERENCED IN MODUTJg TYfA) - INCINERATION
This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions. The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual Permits.
Permit Attachment No.
II-l
II-3
II-9
IX(A)-2
IX(A)-3
IX(A)-4
IX(A)-5
IX(A)-6
IX(A)-7
Plan or Document
(from the Part B Permit Application)
Waste Analysis Plan
Facility Inspection Schedule
Closure Plan
List of Allowable Wastes
Design Plans and Specifications, and
Maintenance Procedures
Description of Allowable Variations in
System Design
Description of Procedures for
Controlling Fugitive Emissions
Description of Monitoring Systems
Description of Automatic Waste Feed
Cut-Off Systems
Description of Manual Waste Feed Cut-
Off Systems
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MODULE IXfB) - SHORT-TERM TEST INCINERATION
[Note: This permit module is applicable to facilities that perform a
trial bum and presents conditions that, during the periods specified,
supersede certain conditions found in Permit Module IX(A) . 40 CFR 270.62
and 264.344(c) requires that a permit establish conditions necessary to
meet the requirements of 40 CPU 264.345 during the shakedown, trial burn,
and post trial burn periods.]
[Note: The purpose of this module is to provide permit conditions for the
operation of a new incineration unit prior to the long-term operation
period in order to:
1. Determine operational readiness following completion of
physical construction;
2. Test compliance with the performance standards;
3. Determine adequate operating conditions to ensure that the
performance standards will be maintained; and
4. Control operating conditions after the trial burn and prior to
any final modifications of the operating conditions in the
long-term portion of the permit to reflect the results of the
trial burn.]
[Note: The Permit Writer should refer to the RCRA Permit Quality
Protocol for additional guidance in developing or reviewing permit
conditions. See discussion of the RCRA Permit Quality Protocol in the
Introduction to this Model Permit.]
IX(B).A. MODULE HIGHLIGHTS
[The Permit Writer should include a general discussion of the activities
covered by this module. The discussion may include some or all of the
following information: type of incineration system; types of air
pollution control equipment used; system capacity in terms of either heat
rate or mass flow rate; key operating conditions, such as combustion
temperature (and whether these conditions were based on trial burn
results, or data in lieu of a trial burn); a general description of the
automatic waste feed cut-off system; the types of waste that may be
burned; the principal organic hazardous constituents selected and the
rationale for this selection; any unique or special features associated
with the operation; and a reference to any special permit conditions.]
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IX(B).B. SHAKEDOWN PHASE
During the shakedown phase (the period beginning with the initial
introduction of hazardous wastes into the incinerator and ending with the
start of the trial burn) the Permittee shall comply with the following
conditions:
IX(B).B.l. DURATION OF THE SHAKEDOWN PHASE
The shakedown phase shall not exceed hours of operation when burning
hazardous wastes. [40 CFR 264.344(c)(l)]
[Note: The duration of the first shakedown phase cannot exceed 720
hours. The Permittee may petition the Agency for one extension of the
shakedown phase for up to 720 additional hours. The Agency may grant the
extension when good cause is demonstrated in the petition. The Permit
Writer should modify the Permit as necessary to reflect the extension.
The modifications may be considered minor modifications. The Permit
Writer's justification for granting an extension should be included in
the Administrative Record for this Permit.] [40 CFR 264.344(c)(l) and 40
CFR 270.62(a)]
IX(B).B.2. ALLOWABLE WASTE FEED
During the shakedown phase, the Permittee may feed only the following
wastes to the incinerator, at the following feed rates, and subject to
the requirements of Permit Conditions IX(B).B.3.:
[Note: The Permit Writer should identify which waste feeds the Permittee
is allowed to incinerate during the shakedown phase and specify their
respective feed rates. Any limitations to these waste feeds should also
be specified. In some cases, an incinerator may accept only wastes that
are always chemically and physically uniform. Identification may then
simply be the process name of the waste or some other equivalent
identifier. Other facilities may accept waste feeds whose chemical and
physical properties vary. Any limitations, and the allowable range of
variations for these waste feeds should be specified. Determining these
conditions must be based on the Permit Writer's judgment that the
facility will meet the performance standards of 40 CFR 264.343. The
Permit Writer may choose to limit the waste feed to easily incinerable
materials during this period, or to limit the amount of harder to
incinerate waste that can be burned during this period. The options
presented in Permit Condition IX(A).B. of the module for long-term
incineration [Module IX(A>] should be considered by the Permit Writer.]
IX(B).B.3. INSTRUMENTATION AND OPERATIONAL PERFORMANCE REQUIREMENTS
[Note: For each of the waste feed streams specified in Permit Condition
IX(B).B.2., the Permit Writer must establish operating conditions that,
in the Permit Writer's judgment, ensure compliance with the performance
standards of 40 CFR 264.343.]
IX(B)
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[Note: 40 CFR 264.345(b)(l)-<4) requires the Permit Writer to establish
operating limits for carbon monoxide, waste-feed rate, combustion
temperature, and a combustion gas velocity indicator. Permit Conditions
IX(B).B.2. and IX(B).B.3.a. through IX(B).B.3.c. cover those
requirements. 40 CFR 264.345(b)(6) requires the Permit Writer to
establish any other operating requirements (conditions) necessary to
ensure compliance with the performance standards. Permit Conditions
IX(B).B.3.d. through IX(B).B.3.n. are example permit conditions that
serve this purpose. These permit conditions incorporate the list of key
operating parameters provided by the EPA Guidance on Trial Burn Reporting
and Setting Permit Conditions. This guidance should be consulted for
assistance in determining which of these conditions apply for a specific
facility and the specific method of setting each condition, given the
design and operation of the facility or from data submitted in lieu of a
trial burn.]
During the shakedown phase, the Permittee shall feed the wastes described
in Permit Condition IX(B).B.2. to the incinerator only under the
following conditions:
IX(B).B.3.a.
IX(B).B.3.b.
IX(B).B.3.c.
Carbon monoxide concentration in the stack exhaust
gas, monitored as specified in Permit Condition
IX(B).B.5.F and corrected for the amount of oxygen in
the stack gas, shall not exceed _____ ppm over a one
hour rolling average [or under the alternative format
for CO limits, ppm at any time, or ppm for
more than minutes in any clock hour] .
Combustion temperature, monitored as specified in
Permit Condition IX(B).B.5.F shall be maintained at
°F (or °C) or greater.
[Note: For dual-chamber incinerators, minimum
temperature should be set for each chamber.]
Combustion gas velocity, monitored as specified in
Permit Condition IX(B).B.5.( shall be no greater than
ft/s.
IX(B).B.3.d. Atomization fluid pressure (e.g., steam, air) shall
be no less than psig.
IX(B).B.3.e. The turndown ratio for the waste burner shall be no
greater than .
[Note: Permit Conditions IX(B).B.3.f. through IX(B).B.3.h. relate
to ensuring compliance with the HC1 emission standard in 40 CFR
264.343(b). The Permit Writer must determine which conditions are
appropriate for a specific facility depending on the control devices
present.]
IX(B) - 3
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September 1988
IX(B).B.3.f.
IX(B).B.3.g.
IX(B).B.3.h.
The I* ratio to the absorber, monitored as specified
G
in Permit Condition IX(B).B.S., shall be maintained
at no less than __ [sometimes expressed as gals per
thousand cubic feet though usually dimensionless].
The scrubber effluent pH, monitored as specified in
Permit Condition IX(B).B.5., shall be maintained at a
minimum pH of .
The scrubber water delivery (nozzle) pressure,
monitored as specified in Permit Condition
IX(B).B.5., shall be maintained at no less than
psig.
[Note: Permit Conditions IX(B).B.3.i. through IX(B).B.3.n. relate
to ensuring compliance with the particulate emission standard in 40
CFR 264.343(c) . Note, however, that most facilities will not have
all of the devices mentioned. The Permit Writer must determine
which conditions are appropriate for a specific facility.]
Pressure drop across the venturi scrubber, monitored
as specified in Permit Condition IX(B).B.5., shall be
maintained at no less than psi.
The scrubber blowdown rate shall be maintained at no
less than gpm.
The power to the electrostatic precipitator,
monitored as specified in Permit Condition
IX(B).B.5., shall be maintained at no less than
kVA.
The voltage applied to the ionizing wet scrubber,
monitored as specified in Permit Condition
IX(B).B.5.f shall be no less than kV.
Pressure drop across the baghouse, monitored as
specified in Permit Condition IX(B).B.5., shall be no
less than ___ psi, nor greater than _____ psi.
[Note: The Permit Writer may require the Permittee
to specify in the Contingency Plan, provisions for
maintaining and replacing bags.]
The Permittee shall control fugitive emissions from
the combustion zone of the incinerator by maintaining
the pressure in the primary combustion chamber,
monitored as specified in Permit Condition
IX(B).B.5., to not exceed inches of mercury.
[40 CFR 264.345(d)]
IX(B).B.3.k.
IX(B).B.3.m.
IX(B).B.3.n.
IX(B) - 4
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OSWER Dir. No. 9938.6
September 1988
IX(B).B.3.o.
IX(B).B.4.
[Note: The Permit Writer may specify another method
for controlling fugitive emissions. The method must
be demonstrated in the Part B Permit Application;
this information should be attached to the Permit,
Permit Attachment IXfB)-l. and referenced.]
Compliance with the operating conditions specified in
Permit Conditions IX(B).B.3.a. through IX(B).B.3.n.
will be regarded as compliance with the required
performance standards 40 CFR 264.343. However.
evidence that compliance with these operating
conditions is insufficient to ensure compliance with
the performance standards, may justify modification,
revocation, or reissuance of the Permit pursuant to
40 CFR 270.41. [40 CFR 264.343(d>]
[Note: It must be understood, by both the Permit
Writer and Permittee, that violation of the permit
operating conditions can give rise to an enforcement
action. If the Permittee complies with the permit
operating conditions, but it is later shown that the
performance standards are not being achieved, the
permit may be modified or revoke and reissued, but
enforcement actions are not available. Thus, each
set of operating conditions should directly relate to
achieving the performance standards in 40 CFR
264.343.]
INSPECTION REQUIREMENTS
The Permittee shall inspect the incineration unit in accordance with the
Inspection Schedule, Permit Attachment II-3. and shall complete the
following as part of these inspections:
IX(B).B.4.a.
IX(B).B.4.b.
IX(B).B.4.c.
The Permittee shall thoroughly, visually inspect the
incinerator and associated equipment (including
pumps, valves, conveyors, pipes, etc.) for leaks,
spills, fugitive emissions, and signs of tampering.
[40 CFR 264.347(b)]
The Permittee shall thoroughly, visually inspect the
instrumentation for out-of-tolerance monitored and/or
recorded operational data.
The Permittee shall test the emergency waste feed
cut-off system and associated alarm at least weekly
to verify operability, as specified in Permit
Condition IX(B).B.5. [40 CFR 264.347(c)]
IX(B) - 5
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[Note: If the Permittee demonstrates to the Regional
Administrator that the weekly inspections referred to
in Permit Condition lX(B).B.4.c. will unduly restrict
or upset operations and that less frequent inspection
will be adequate, the Permit Writer should specify
that inspection frequency in the permit condition.
At a minimum, operational testing must be conducted
at least monthly.]
IX(B).B.5. MONITORING REQUIREMENTS
IX(B).B.5.a. The Permittee shall maintain, calibrate, and operate
monitoring equipment and record the data while
incinerating hazardous waste, as specified below:
System Monitor Location Recording Calibration
Parameter Type, Process Frequency
Instr.
No.
R-gampl^s Type K
(1) Com- Thermo -
bustion couple
tempera- TIC -900
Cure
(2) Pres- Pressure
sure drop Sensor
across PDIC-
scrubber 1220
venturi
[Use [Indicate
design whether
drawing continuous
numbers or not]
to show
the loca-
tion]
[ Frequency
at which the
unit is
calibrated
[Note: At a minimum, this condition must specify monitoring systems that
meet the requirements of 40 CFR 264.347(a)(1) and (2). Permit Condition
IX(B).B.5.a. contains example specifications for various operating
parameters that must be monitored. Specific parameters should be
addressed in the above table. If the Part B Permit Application contains
the above information on monitoring practices, in a conveniently
organized way and adequately detailed, then the Permit Writer may attach
this information. Permit Attachment IX(B)-2. to the Permit instead of
using a table in this permit module, and reference the attachment.]
IX(B).B.5.b. Upon request of the Agency, the Permittee shall
perform sampling and analysis of the waste and
exhaust emissions to verify thac the operating
requirements established in the Permit achieve the
performance standards. [40 CFR 264.347(a)(3)]
IX(B) - 6
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IX(B).8.6. WASTE FEED CUT-OFF REQUIREMENTS
IX(B).B.6.a. The Permittee shall construct and maintain the
systems specified below to automatically cut off the
hazardous waste feed to the incinerator at the levels
specified below. Hazardous wastes shall be fed to
the incinerator only when all instruments required by
this condition are on line and operating properly.
Test
Parameter Cut-Off Limits Frequency
Operating [Level at which [Frequency at
parameters waste feed will which opera-
te be inter- be cut off] tional readiness
locked to is checked]
automatic
waste-feed
cut off i.e.,
SCO temper-
ature]
[Note: 40 CFR 264.3A5(e) requires such systems to be constructed to
ensure that the operating conditions specified in the Permit are not
exceeded. Most cut-off systems are composed of multiple parameters.
They include monitors for the operating conditions presented in Permit
Condition IX(B).B.3. along with power failure and flame-out. If the Part
B Permit Application adequately provides the above information regarding
the automatic waste-feed cut-off system in an organized way and
adequately detailed, then the Permit Writer may attach this information.
Permit Attachment IX(B>-3. to the Permit, in lieu of using a table in
this permit module, and reference the attachment.]
IX(B).B.6.b. In case of a malfunction of the automatic waste feed
cut-off systems, the Permittee shall perform manual
shut downs in accordance with the approved procedures
in Permit Attachment IX(B)-4. The Permittee shall
not restart the incinerator until the problem causing
the malfunction has been located and corrected.
IX(B).B.7. RECORDKEEPING
IX(B).B.7.a. The Permittee shall record and maintain, in the
operating record for this permit, all monitoring and
IX(B) - 7
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September 1988
inspection data compiled under Che requirements of
this Permit (see Permit Condition I.E.9.b.). [40 CFR
264.73 and 40 CFR 264.347(d)]
IX(B).B.7.b. The Permittee shall record in the operating record
for this permit the date and time of all automatic
waste feed shut-offs, including the triggering
parameters, reason for the shut-off, and corrective
actions taken. The Permittee shall also record all
failures of the automatic waste feed shut-offs to
function properly and corrective actions taken.
IX(B).B.8. COMPLIANCE SCHEDULE
[Note: The Permit Writer should include this condition if the Permittee
is required to complete specific steps within a specific time period,
beyond those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit. Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee,
before the Permit is issued, are deferred for good cause until after
permit issuance. Compliance schedules included in the Part B Permit
Application should be attached to the Permit. If the application does
not include a compliance schedule, the Permit Writer should prepare one
and attach it to the Permit. Each compliance schedule should have at
least two columns - one identifying the activity and one identifying the
milestone or completion dates. The following is an example of a
condition that may apply for incineration units.]
The Permittee shall provide the following information to the Regional
Administrator:
Item Date Due to the Reeional Administrator
[Example:
1. Documentation that May 12, 1989
thermocouple No. TC 2
was installed as shown
on Drawing No. 960,
dated March 18, 1987
2. As-built construction February 13, 1989]
drawings for installation
of Pressure Sensor No. PS 4
IX(B) - 8
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September 1988
IX(B).C. TRIAL BURN PHASE
IX(B).C.l. CONFORMITY TO TRIAL BURN PLAN
The Permittee shall operate and monitor the incinerator during the trial
burn phase as specified in the Trial Burn Plan, Permit Attachment IXfB^-
5. The Trial Burn Plan shall be revised and resubmitted by the Permittee
six (6) months prior to conducting the trial burn or a performance test
required under Permit Condition IX(A).E.2. of this permit. The revised
Trial Burn Plan must include all applicable EPA-approved test methods and
procedures in effect at the time of the resubmittal.
[Note: The Trial Burn Plan oust meet the requirements of 40 CFR
270.62(b)(2). The operating and monitoring requirements specified in the
plan must be adequate to meet the requirements of 40 CFR 270.62(b)(2) (v) .
Additional conditions should be established, if necessary, to establish
operating conditions which will ensure compliance with the performance
standards of 40 CFR 264.343.]
IX(B).C.2. TRIAL POHCs
The principal organic hazardous constituents (POHCs) for which DREs must
be determined are:
Waste Feed POHCfs)
[Note: If the Permittee or Permit Writer wishes to establish different
operating conditions for various hazardous waste feeds, then POHCs must
be selected for each feed or feed group. For example, a facility may
wish to designate two (2) waste feeds. Number one waste feed may be a
combination of several waste streams that is relatively "easy" to burn
based on its POHCs. Number two feed may consist of several waste streams
that are "difficult" to burn based on their POHCs. The incinerator
operating conditions for these two feeds may be different.]
[Note: Before selecting POHCs for the trial burn, the Permit Writer
should review the EPA "Guidance Manual for Hazardous Waste Incinerator
Permits' (SW-966), Guidance on Trial Burn Reporting and Setting Permit
Conditions, and other appropriate guidances.]
IX(B).C.3. TRIAL BURN DETERMINATIONS
During the trial burn (or as soon after the trial burn as practicable),
the Permittee shall make the determinations required by 40 CFR
270.62(b)(6)(i)-(ix).
IX(B) - 9
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Sepcember 1988
[Note: Any other determinations that the Permit Writer finds will be
needed to ensure that the trial burn will determine compliance with the
performance standards should be described as required by 40 CFR
270.62(b)(6)(x).]
IX(B).C.4. TRIAL BURN DATA SUBMISSIONS AND CERTIFICATIONS
The Permittee shall submit a copy of all data collected during the trial
burn to the Regional Administrator upon completion of the burn. The
Permittee shall submit to the Regional Administrator the results of the
determinations required by Condition IX(B).C.3 within ninety (90) days of
the completion of the trial burn. All submissions must be certified in
accordance with 40 CFR 270.11. [40 CFR 270.62(b)(7) and (9)]
[Note: The Regional Administrator may approve longer time periods for
trial burn data submittal for good cause.] [40 CFR 270.62(b) (7) ]
IX(B).D. POST-TRIAL BURN PHASE
During the post-trial burn phase (the period starting immediately
following the completion of the trial burn and ending when the final
operating permit is effective), and for the minimum period sufficient for
the Permittee to analyze samples, compute data, and submit trial burn
results, and for the Agency to review the trial burn results and make any
modifications necessary to the Permit, the Permittee shall comply with
the following conditions.
IX(B).D.I. ALLOWABLE WASTE FEED
During the shakedown phase, the Permittee may feed only the following
wastes to the incinerator, at the following feed rates, and subject to
the requirements of Permit Conditions IX(B).D.2.:
[Note: The Permit Writer should identify which waste feeds the Permittee
is allowed to incinerate during the shakedown phase and specify their
respective feed rates. Any limitations to these waste feeds should also
be specified. In some cases, an incinerator may accept only wastes that
are always chemically and physically uniform. Identification may then
simply be the process name of the waste or some other equivalent
identifier. Other facilities may accept waste feeds whose chemical and
physical properties vary. Any limitations, and the allowable range of
variations for these waste feeds should be specified. Determining these
conditions must be based on the Permit Writer's judgment that the
facility will meet the performance standards of 40 CFR 264.343. The
Permit Writer may choose to limit the waste feed to easily incinerable
materials during this period, or to limit the amount of harder to
incinerate waste that can be burned during this period. The options
presented in Permit Condition IX(A).B. of the module for long-term
incineration [Module IX(A)] should be considered by the Permit Writer.]
IX(B) - 10
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September 1988
IX(B).D.2.
INSTRUMENTATION AND OPERATIONAL PERFORMANCE REQUIREMENTS
[Note: For each of the waste feed streams specified in Permit Condition
IX(B)-D.l., the Permit Writer must establish operating conditions that,
in the Permit Writer's judgment, ensure compliance vith the performance
standards of 40 CFR 264.343.]
[Note: 40 CFR 264.345(b)(l)-(4) requires the Permit Writer to establish
operating limits for carbon monoxide, waste-feed rate, combustion
temperature, and a combustion gas velocity indicator. Permit Conditions
IX(B).D.l. and IX(B).D.2.a. through IX(B).D.2.c. cover those
requirements. 40 CFR 264.345(b)(6) requires the Permit Writer to
establish any other operating requirements (conditions) necessary to
ensure compliance with the performance standards. Permit Conditions
IX(B).D.2.d. through IX(B).D.2.n. are example permit conditions that
serve this purpose. These permit conditions incorporate the list of key
operating parameters provided by the EPA Guidance on Trial Burn Reporting
and Setting Permit Conditions. This guidance should be consulted for
assistance in determining which of these conditions apply for a specific
facility and the specific method of setting each condition, given the
design and operation of the facility and the results of the trial burn or
from data submitted in lieu of a trial burn. ]
During the shakedown phase, the Permittee shall feed the wastes described
in Permit Condition IX(B).D.l. to the incinerator only under the
following conditions:
IX(B).D.2.a.
IX(B).D.2.b.
IX(B).D.2.c.
IX(B).D.2.d.
Carbon monoxide concentration in the stack exhaust
gas, monitored as specified in Permit Condition
IX(B).D.4., and corrected for the amount of oxygen in
the stack gas, shall not exceed ppm over a one
hour rolling average [or under the alternative format
for CO limits, ppm at any time, or ppm for
more than minutes in any clock hour].
Combustion temperature, monitored as specified in
Permit Condition IX(B).D.4., shall be maintained at
°F (or °C) or greater.
[Note: For dual-chamber incinerators, minimum
temperature should be set for each chamber.]
Combustion gas velocity, monitored as specified in
Permit Condition IX(B).D.4., shall be no greater than
ft/s.
Atoraization fluid pressure (e.g., steam, air) shall
be no less than
IX(B) - 11
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OSWER Dir. No. 9938.6
IX(B).0.2.e.
September 1988
The turndown ratio for the waste burner shall be no
greater than .
IX(B).D.2.g.
IX(B).D.2.h.
[Note: Permit Conditions IX(B).D.2.f. through IX(B).D.2.h. relate
to ensuring compliance with the HC1 emission standard in 40 CFR
264.343(b). The Permit Writer must determine which conditions are
appropriate for a specific facility depending on the control devices
present.]
IX(B).D.2.f. The ^ ratio to the absorber, monitored as specified
G
in Permit Condition IX(B).0.4., shall be maintained
at no less than __ [sometimes expressed as gals per
thousand cubic feet though usually dimensionless].
The scrubber effluent pH, monitored as specified in
Permit Condition IX(B).D.4., shall be maintained at a
minimum pH of .
The scrubber water delivery (nozzle) pressure,
monitored as specified in Permit Condition
IX(B).D.4., shall be maintained at no less than
psig.
[Note: Permit Conditions IX(B).D.2.i. through IX(B).D.2.n. relate
to ensuring compliance with the particulate emission standard in 40
CFR 264.343(c). Note, however, that most facilities will not have
all of the devices mentioned. The Permit Writer must determine
which conditions are appropriate for a specific facility.]
Pressure drop across the venturi scrubber, monitored
as specified in Permit Condition IX(B).D.4., shall be
maintained at no less than psi.
The scrubber blowdown rate shall be maintained at no
less than gpm.
The power to the electrostatic precipitator,
monitored as specified in Permit Condition
IX(B).D.4., shall be maintained at no less than
kVA.
IX(B).D.2.J.
IX(B).D.2.k.
IX(B).D.2.m.
The voltage applied to the ionizing wet scrubber,
monitored as specified in Permit Condition
IX(B).D.4.. shall be no less than kV.
Pressure drop across the baghouse, monitored as
specified in Permit Condition IX(B).D.4., shall be no
less than psi, nor greater than psi.
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IX(B).D.2.n.
IX(B).D.2.o.
IX(B).D.3.
September 1988
[Note: The Permit Writer may require the Permittee
to specify in the Contingency Plan, provisions for
maintaining and replacing bags.]
The Permittee shall control fugitive emissions from
the combustion zone of the incinerator by maintaining
the pressure in the primary combustion chamber,
monitored as specified in Permit Condition
IX(B).D.4., to not exceed inches of mercury.
(40 CFR 264.345(d)]
[Note: The Permit Writer may specify another method
for controlling fugitive emissions. The method must
be demonstrated in.the Part B Permit Application;
this information should be attached to the Permit,
Permit Attachment IX(B)-1. and referenced.]
Compliance with the operating conditions specified in
Permit Conditions IX(B).D.2.a. through IX(B).D.2.n.
will be regarded as compliance with the required
performance standards 40 CFR 264.343. However,
evidence that compliance with these operating
conditions is insufficient to ensure compliance with
the performance standards, may justify modification,
revocation, or reissuance of the Permit pursuant to
40 CFR 270.41. [40 CFR 264.343(d)]
[Note: It must be understood, by both the Permit
Writer and Permittee, that violation of the permit
operating conditions can give rise to an enforcement
action. If the Permittee complies with the permit
operating conditions, but it is later shown that the
performance standards are not being achieved, the
permit may be modified or revoke and reissued, but
enforcement actions are not available. Thus, each
set of operating conditions should directly relate to
achieving the performance standards in 40 CFR
264.343.]
INSPECTION REQUIREMENTS
The Permittee shall inspect the incineration unit in accordance with the
Inspection Schedule, Permit Attachment II-3. and shall complete the
following as part of these inspections:
IX(B).D.3.a.
The Permittee shall thoroughly, visually inspect the
incinerator and associated equipment (including
pumps, valves, conveyors, pipes, etc.) for leaks,
spills, fugitive emissions, and signs of tampering.
[40 CFR 264.347(b)]
IX(B) - 13
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IX(B).D.3.b.
IX(B).D.3.c.
IX(B).D.4.
September 1988
The Permittee shall thoroughly, visually inspect the
Instrumentation for out-of-tolerance monitored and/or
recorded operational data.
The Permittee shall test the emergency waste feed
cut-off system and associated alarm at least weekly
to verify operability, as specified in Permit
Condition IX(B).D.4. [40 CFR 264.347(c)]
[Note: If the Permittee demonstrates to the Regional
Administrator that the weekly inspections referred to
in Permit Condition IX(B).D.3.c. will unduly restrict
or upset operations and that less frequent inspection
will be adequate, the Permit Writer should specify
that inspection frequency in the permit condition.
At a minimum, operational testing must be conducted
at least monthly.]
MONITORING REQUIREMENTS
IX(B).D.4.a.
The Permittee shall maintain, calibrate, and operate
monitoring equipment and record the data while
incinerating hazardous waste, as specified below:
System Monitor
Parameter Type,
Instr.
No.
Location Recording
Process
Calibration
Frequency
Examples
(1) Com-
bustion
tempera-
ture
(2) Pres-
sure drop
across
scrubber
venturi
Type K
Thermo-
couple
TIC-900
Pressure
Sensor
PDIC-
1220
[Use
design
drawing
numbers
to show
the loca-
tion]
[ Indicate
whether
continuous
or not]
[ Frequency
at which the
unit is
calibrated
[Note: At a minimum, this condition must specify monitoring systems that
meet the requirements of 40 CFR 264.347(a) (1) and (2). Permit Condition
IX(B).D.4.a. contains example specifications for various operating
parameters that must be monitored. Specific parameters should be
addressed in the above table. If the Part B Permit Application contains
the above information on monitoring practices, in a conveniently
IX(B) - 14
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September 1988
organized way and adequately detailed, then the Permit Writer may attach
this information. Permit Attachment Ixm-2. to the Permit instead of
using a table in this permit module, and reference the attachment.]
IX(B).D.4.b. Upon request of the Agency, the Permittee shall
perform sampling and analysis of the waste and
exhaust emissions to verify that the operating
requirements established in the Permit achieve the
performance standards. [40 CFR 264.347(a)(3)]
IX(B).D.5. WASTE FEED CUT-OFF REQUIREMENTS
IX(B).D.5.a. The Permittee shall construct and maintain the
systems specified below to automatically cut off the
hazardous waste feed to the incinerator at the levels
specified below. Hazardous wastes shall be fed to
the incinerator only when all instruments required by
this condition are on line and operating properly.
Test
Parameter Cut-Off Limits Frequency
Operating [Level at which [Frequency at
parameters waste feed will which opera-
to be inter- be cut off] tional readiness
locked to is checked]
automatic
waste-feed
cut off i.e..
SCC temper-
ature]
[Note: 40 CFR 264.345(e) requires such systems to be constructed to
ensure that the operating conditions specified in the Permit are not
exceeded. Most cut-off systems are composed of multiple parameters.
They include monitors for the operating conditions presented in Permit
Condition IX(B).D.2. along with power failure and flame-out. If the Part
B Permit Application adequately provides the above information regarding
the automatic waste-feed cut-off system in an organized way and
adequately detailed, then the Permit Writer may attach this information,
Permit Attachment IX(B)-3. to the Permit, in lieu of using a table in
this permit module, and reference the attachment.]
IX(B) - 15
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September 1988
IX(B).D.5.b. In case of a malfunction of the automatic waste feed
cut-off systems, the Permittee shall perform manual
shut downs in accordance with the approved procedures
in Permit Attachment IX(B)-4. The Permittee shall
not restart the incinerator until the problem causing
the malfunction has been located and corrected.
IX(B).D.6. RECORDKEEPING
IX(B).D.6.a. The Permittee shall record and maintain, in the
operating record for this permit, all monitoring and
inspection data compiled under the requirements of
this Permit (see Permit Condition I.E.9.b.). [40 CFR
264.73 and 40 CFR 264.347(d)]
IX(B).D.6.b. The Permittee shall record in the operating record
for this permit the date and time of all automatic
waste feed shut-offs, including the triggering
parameters, reason for the shut-off, and corrective
actions taken. The Permittee shall also record all
failures of the automatic waste feed shut-offs to
function properly and corrective actions taken.
IX(B).D.7. COMPLIANCE SCHEDULE
[Note: The Permit Writer should include this condition if the Permittee
is required to complete specific steps within a specific time period,
beyond those covered by other conditions of the Permit, as a criteria for
retaining this operating Permit. Compliance schedules are generally used
in cases where requirements that are supposed to be met by the Permittee,
before the Permit is issued, are deferred for good cause until after
permit issuance. Compliance schedules included in the Part B Permit
Application should be attached to the Permit. If the application does
not include a compliance schedule, the Permit Writer should prepare one
and attach it to the Permit. Each compliance schedule should have at
least two columns - one identifying the activity and one identifying the
milestone or completion dates. The following is an example of a
condition that may apply for incineration units.]
The Permittee shall provide the following information to the Regional
Administrator:
IX(B) - 16
C-31
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OSWER Dir. No. 9938.6
September 1988
Item Date Due to the Regional Administrator
[Example:
1. Documentation that May 12, 1989
thermocouple No. TC 2
was installed as shown
on Drawing No. 960,
dated March 18, 1987
2. As-built construction February 13, 1989]
drawings for installation
of Pressure Sensor No. PS 4
IX(B).E. REPORTING NON-COMPLIANCE DURING THE TRIAL BURN
If based upon the analytical results of the trial burn and before
submitting the required trial burn results, the Permittee determines that
the incinerator failed to achieve any of the performance standards
specified in 40 CFR 264.343, the Permittee shall notify the Regional
Administrator within twenty-four (24) hours of making the determination.
Upon the request of the Regional Administrator, the Permittee shall cease
feeding hazardous waste to the incinerator. The Permittee may apply to
the Regional Administrator for a permit modification pursuant to 40 CFR
270.41 and for a new trial burn pursuant to 40 CFR 270.62(b).
IX(B) - 17
C-32
-------
OSWER Dir. No. 9938.6
September 1988
PERMIT ATTACHKEHTS REFEPPMCKn IN MODUT-E IXfB) - SHORT-TERM
TEST INCINERATION
This list is provided to assist the Permit Writer in checking that all
Permit Attachments referenced in this module are attached to the Permit.
The purpose of the numbering scheme used here is to facilitate cross-
walking with the model permit conditions. The Permit Writer may select
other numbering schemes, as appropriate, when preparing actual Permits.
Permit Attachment No.
II-3
IX(B)-2
IX(B)-3
IX(B)-4
IX(B)-5
Plan or Document
(from the Part B Permit Application)
Facility Inspection Schedule
Description of Procedures for
Controlling Fugitive Emissions
Description of Monitoring Systems
Description of Automatic Waste Feed
Cut-Off Systems
Description of Manual Waste Feed Cut-
Off Systems
Trial Burn Plan
IX(B) - 18
C-33
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OSWER Dir. No. 9938.6
APPENDIX 0
REFERENCES AND GUIDANCE DOCUMENTS FOR
HAZARDOUS WASTE INCINERATORS
D-l
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OSWER Dir. No. 9938.6
References and Guidance Documents for Hazardous Waste Incinerators
1. "Guidance Manual for Hazardous Waste Incinerator Permits," USEPA,
PB84-100577, July 1983.
2. "Sampling and Analysis Methods for Hazardous Waste Combustion," A Report
Prepared by A. D. Little, Inc. for USEPA, PB84-155845, February 1984.
3. "Permit Writers- Guide to Test Burn Data—Hazardous Waste Incineration,"
USEPA, EPA/625/6-86/012, September 1986.
4. "Practical Guide—Trial Burns for Hazardous Waste Incinerators," A Report
Prepared by Midwest Research Institute for EPA, PB86-190246, April 1986.
5. "Guidance on PIC Controls for Hazardous Waste Incineration," MRI, Draft,
1989.
6. "Hazardous Waste Incineration Measurement Guidance Manual," MRI, Draft,
1988.
7. "Guidance on Metals and Hydrogen Chloride for Hazardous Waste Inciner-
ators," Versar, Draft, 1989.
8. "Trial Burn Observation Guide," Prepared by Midwest Research Institute for
EPA, 1988.
9. "Guidance on Setting Permit Conditions and Reporting Trial Burn Results,"
Acurex/EER/MRI, 1989.
10. Engineering Handbook for Hazardous Waste Incineration, U.S. EPA, SW-889,
September 1981.
D-2
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OSWER 01r. No. 9938.6
APPENDIX E
HEAT OF COMBUSTION INCINERABILITY RANKING
E-l
-------
TABLE 2-4
RANKING OF INCINERABILITY OF ORGANIC HAZARDOUS CONSTITUENTS FROM
APPENDIX VIII. PART 261 ON THE BASIS OF HEAT OF COMBUSTION
Hazardous Constituent
Heat of
Combustion
kca I/gram
Hazardous Constituent
Heat of
Combustion
kcaI/gram
TrIchIoromonofIuoromethane
Tri bromomethane
DIchIorodi fIuoromet hane
Tetrachloromethane (Carbon Tetrachlonde)
Tetranitromethane
Hexachloroethane
Oibromofliethane
Pentachloroethane
Hexachloropropene
Chloroform
Chloral(trichloroacetaldehyde)
Cyanogen bromide
TrichIoromethanethioI
HexachIorocycIohexane
Tetrachloroethene (Tetrachloroethylene)
Cyanogen chloride
Formic acid
lodomethane
Tetrachloroethane, N.O.S.
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
1,2-Oibromoethane
1,2-Dibromo-3-chloropropane
Pentachloroni trobenzene
Bromomethane
Dichloromethane
TrichIoroethene (Tr i chIoroethyIene)
HexachIorobenzene
0.11
0.13
0.22
0.24
0.41
0.46
0.50
0.53
0.70
0.75
0.80
0.61
0.64
1.12
1.19
1.29
1.32
1.34
1.39
1.39
1.39
1.43
1.48
1.62
1.70
1.70
1.74
1.79
Bis(chloromethyl)ether
1,1,1-TrichIoroethane
I,1,2-Trichloroethane
PentachIorobenzene
PentachIorophenoI
HexachIorocycIopentad i ene
HexachIorobutadiene
Kepone
2,3,4,6-Tetrachlorophenol
Dichlorophenylarsine
DecachIorobi pheny I
Endosulfan
Nonachlorobiphenyl
Toxaphene
1,2,4,5-Tetrachlorobenzene
Bromoacetone
Dichloroethylene, N.O.S.
1,1-Dichloroethylene
Chlordane
Heptachlor epoxide
Pheny(mercury acetate
Octachlorobiphenyl
Acetyl chloride
Trichloropropane, N.O.S.
1,2,3-Trichloropropane
Dichloropropanol, N.O.S.
Dimethyl sulfate
2,4,5-T
1.97
1.99
1.99
2.05
2.09
2.10
2.12
2.15
2.23
31
31
33
50
50
2.61
2.66
70
70
71
71
71
72
77
2.81
2.81
2.84
2.86
2.87
to
vo
CO
CO
•
en
-------
TABLE 2-4 (Continued)
Hazardous Constituent
Heat of
COD bust Ion
deal/gran
Hazardoua Constituent
Heat of
COBbunt Ion
kcal/gran
2.4.S-Trlchlorophenol 2.88
2.4,6-Trlchlorophenol 2.88
N-Nltroso-N-nethylurea 2.89
lleptachloroblphenyl 2.98
1.1-Dlchloroethane 3.00
1,2-Dlchloroetliane 3.00
trdns-l,2-Dlchloroethane 3.00
Phenyl dlchloroarslne 3.12
N-NltrosoarcoBlna 3.19
A/aserlne 3.21
2-FluoroacetaBlde 3.24
CuloromuLhane 3.25
Uexachloroblphenyl 3.28
Blu (2-chlocoethyl) ether 3.38
1.2.3.4.10.10-Hexacliloro-1.4.4a.5.7.aa- 3-38
hexaliydro-l,4:5,8-endo, endo-
d laet hanonapht ha lene
Bensenearsonlc acid 3.40
Nalelc anhydride 3.40
1,2.4-Trlchlorohenzene 3.40
TCDD 3.43
Dlchloropropcne, N.O.S. 3.44
1,3-Dlchloropcopene 3.44
Endrlu 3.46
Chloronethyl methyl ether 3.48
2,4-Dlnltrophenol 3.S2
Nitrogen mustard N-oxlde and hydrochlorlde 3.56
ualc
Parathlon 3.61
2,4-1) 3.62
Pentachloroblphenyl
1,3-Propane suitone
Methyl nathanosulfonata
Aldrln
Nitroglycerine
2,4-Dlchlorophenol
2,6-Dlchlorophenol
Hexactilorophene
Trypan blue
BenzotrIchlorIda
Cycaaln
N-Mltroso-N-ethylurea
Cyc lophoaphanlde
Dlchloropropane, N.O.S.
1,2-Dlchloropropana
Kethylparathlon
Uracll Bustard
Aaltrole
Dlmethoata
Tetraethyl lead
4,6-Dlnltro-o-cresol and salts
N-Hethyl-N -nltro-N-nltrosoguanldlne
Mistard gaa
Halelc hydraslde
Dlnltrobenzene, N.O.S.
N-Nltroso-N-aethylurethane
1.4-Dlchloro-2-butene
Nitrogen mustard and hydrochlorlde salt
Tetrachloroblphenyl
3.66
3.67
3.74
3.75
3.79
3.81
3.81
3.82
3.84
3.90
3.92
3.92
3.97
3.99
3.99
4.00
4.00
4.01
4.02
4.04
4.06
4.06
4.06
4.10
4.15
4.18
4.27X
4.28
4.29
O
to
o
•
to
00
-------
TABLE 2-4 (Continued)
Hazardous Constituent
Heat of
Combust Ion
kcal/gran
Hazardous Constituent
Heat of
Con bust Ion
fecal/gran
Hydraclne 4.44
Vinyl chloride 4.45
Formaldehyde 4.47
Saccharin 4.49
3-Chloroproplonltrlle 4.50
DOT 4.51
Thlourea 4.51
l-Acetyl-2-thlourea 4.55
Thloaemlcarbazlde 4.55
Dlchlorobencene, N.O.S. 4.57
Ethyl cyanide 4.57
Bis (2-chloroethoxy) methane 4.60
2,4-Dlnltrotoluene 4.68
Isocyanlc acid, methyl ester 4.69
7-Oxablcyclo (2.2.1) heptane-2,3-dlcarboxyllc 4.70
acid
Ethyl carbaoate 4.73
S-(Aalnoacthyl)-3-lsoxazolol 4.78
Methylthlourac11 4.79
4.4>-Methylene-bls-(2-chloroanlllne) 4.84
Bis (2-chlorolsopropyl) ether 4.9]
4-Nltrophenol 4.95
DDE 5.05
Dlmethylcarbamoyl chloride 5.08
p-Chloro-m-cresol 5.08
Olchloromethylbenzene 5.09
Trlchloroblphenyl 5.10
ODD 5.14
Dlmcthylnltrosoanlne 5.14
N-NltroBodloutliyldulne 5.14
Dlethylarslnu 5.25
Phthallc anhydride 5.29
l-(o-chlorophenyl) thlourea 5.30
2-Methyl-2-(methylthlo) proplonaldehyde-o- 5.34
(methylcarbonyl) oxlme
2-sec-Butyl-4,6 dlnltrophenol (DNBP) 5.46
p-Nltroanlllne 5.50
Chlorobenzllata 5.50
Oleldrln 5.56
2.4,5-TP 5.58
Hethoxychlor 5.59
4-Nltroqulnollne-l-oxlde 5.59
Olallate 5.62
Oaunomycln 5.70
EthylenebUdllhlocarbamate 5.70
3,3'-Dlchlorobi:nzldlna 5.72
Pronamlde 5.72
Af latoxins 5.73
Dlsulfoton 5.73
4,6-Dlnltrophunol 5.74
Olepoxybutane 5.74
Dimethyl phthalate 5.74
Clycldylaldehyde 5.74
Acrylamlde 5.75
3,3-Dlmethyl-l-(netliylthlo)-2-butsnone-0- 5.82
(methylamlno)carbonyl oxlme
4-Bronophenyl phenyl ether 5.84
Thluram 5.85
Huihanethlol 5.91
Tolylene dllsocyanatc 5.92
Chloraubucll 5.93
Tliloaceiaolde 5.95
o
-?
•
o
•
«£>
CO
00
cr>
-------
(conninueuj
Hazardous Constituent
Heat of
Combust Ion
kcaI/gram
i
en
Ethylenethlourea
Hdlononltrlle
5-Nltro-o-tolu LJIne
Nitrobenzene
3,4-Dlhydroxy-dlplia-(inethylaialno)niil.hyl
benzyl alcoliol
Benzoqulnone
N-Nltrosomethylethylanlne
p-Chloroanlllne
Benzyl chloride
Resorclnol
Propylthlouracll
Paraldehyde
Dlchloroblphenyl
Dlethyl phtlialatii
Dloxane
2-Methyllactonltrlle
H-N It rosopy c rol Idone
Hethyl oethacrylate
Chlorobenzene
o-Toluldlne hydrochlorlde
N.II-Bls (2-chloroethyl)-2-naplitliylaDine
2,6-Olnltrotoluene dl-n-octyl phtlialate
Reaerplne
Methyl hydrazlne
Cyanogen
Ethylene oxide
N-N Itroaod let liy lamlne
2-Chloroplieno 1
N-Phenyltklourea
Acroleln
5.98
5.98
5.98
6.01
6.05
6.07
6.13
6.14
6.18
6.19
6.28
6.30
6.36
6.39
6.41
6.43
6.43
6.52
6.60
6.63
6.64
6.67
6.70
6.78
6.79
6.86
6.86
O.H9
6.93
6.96
Hazardous Constituent
Meat of
Coo bust Ion
kcal/grao
2-Butanone peroxide 6.96
p-Dlaethylanlnoazobenzcne 6.97
1,4-Naphthoqulnone 6.97
3-(alpha-Acetonylbenzyl)-4-hydroxycouaarln 7.00
and salts (Warfarin)
N-Nltroaodlethanolanlne 7.02
N-Nltrosoplperldlno 7.04
N-Nltrosonornlcotlne 7.07
Fhenacetln 7.17
Ethyl nethacrylate 7.27
Dl-n-butyl phthalate 7.34
3.3'-Dlinethoxybenzldlne 7.36
Acetonltclle 7.37
4-Amlnopyrldlne 7.37
2-Chloronaphthalene 7.37
2 Propyn-1-ol 7.43
l-Naphthyl-2-thlourea 7.50
Isosafrole 7.62
Dlhydroaafrole 7.66
Safrole 7.68
Auranlne 7.69
CrotonaIdehyde 7.73
Allyl alcohol 7.75
Monochloroblphcnyl 7.75
Phenol 7.78
Phenylenedlaolne 7.81
Dl-n-propylnllrosoamliiu 7.83
Pyrldlne 7.83
Ethyleneiolne 7.86
l.l-Dlmutliylhydrazlne 7.87
1,2-Dlmethylhydrazlne 7.87
O
CO
O
.J.
-J
CM
-------
TABLE 2-4 I Continued)
Hazardous Constituent
Heat of
Combustion
kcal/gran
Hazardous Constituent
Heat of
Combustion
kcal/graa
N-Nltrosomethylvlnylanlne
2-Acet ylanlnofluorIne
Acrylonltrlle
Hetliapyrllene
Strychnine and salts
Methyl ethyl ketone (MEK)
Creayllc acid
Creool
Toluene dlamina
Acetophenone
Butyl benzyl phthalate
Ethyl cyanide
Bla (2-ethylhexyl) phthalate
Benzenetlilol
N-Nltrouudl-N-Uitylaalne
2,4-Ula«itliylphi:nol
liiilciiol (1,2,3-c.d) pyrene
DlethyUtllbeatrol
1-NaphthylumliiB
2-Naplithylonlna
Hethacrylonltrlle
laobutyl alcohol
1,2-Dluthylhydrazlne
2-Plcollne
Aniline
1,2-DlphenylhydrazIne
7.91
7.82
7.93
7.93
8.03
8.07
8.09
8.18
8.24
8.26
8.29
8.32
8.42
8.43
8.46
8.31
8.52
8.54
8.54
8.54
8.55
8.62
8.68
8.72
8.73
8.73
3,3'-DlaethoxybenzIdIne
711-Dlbenzo tc,g) carbazols
Benz (c) acridIne
Nicotine and salts
4-Aalno blphenyl
Dlphenylanlne
2-Hethylazlrldlne
BenzIdIne
Benzo (b) fluorantnene
Benzo (J) fluoranthene
Benzo (a) pyrene
Dlbenzo ta.e) pyrene
Dlbenzo (a,h) pyrene
Olbenzo (a,l) pyrene
Fluoranthene
Benc (a) anthracene
Dlbenz (a,h) anthracene (Dlbenzo (a,h)
anthracene)
Olbenz (a,h) acridIne
Dlbenz (a.J) aclrdlne
alpha, alpha-Dlmethylphenethylamlne
3-Hethylcholanthrene
n-Propylanlne
7,12-Dlnethylbenz (a) anthracene
Naphthalene
Benzene
Toluene
8.81
8.90
8.92
8.92
9.00
9.09
9.09
9.18
9.25
9.25
9.25
9.33
9.33
9.33
9.35
9.39
9.40
9.53
9.53
9.54
9.57
9.58
9.61
9.62
10.03
10.14
CO
•
a\
-------
OSWER D1r. No. 9938.6
APPENDIX F
THERMAL STABILITY-BASED INCINERABILITY RANKING
F-l
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OSWER Dir. No. 9938.6
Table 0-1. Principal Hazardous Organic Constituent Thermal Stability Index
Principal Hazardous Organic Constituent Rank
CLASS 1
CYANOGEN (ETHANEDINITRILE) 1
HYDROGEN CYANIDE (HYDROCYANIC ACID} [2] 2
BENZENE [2] 3
SULFUR HEXAFLUORIDE [3] 4
NAPHTHALENE [2] 5
FLUORANTHENE (BENZOli,k)FLUORENE} 6
BENZOUJFLUORANTHENE (7.8-BENZOFLUORANTHENE) 7
BENZO[b]FLUORANTHENE {2,3-BENZOFLUORANTHENE} 8
BENZANTHRACENE (1.2-) {BEN2[a]ANTHRACENE} ~9
CHRYSENE {1,2-BENZPHENANTHRENE} 10
BENZO[alPYRENE (1,2-BENZOPYRENE) 11
DIBENZ[a,h]ANTHRACENE {1,2,5,6-DIBENZANTHRACENE} 12
INDENO(1.2.3-cd)PYRENE (1.10-(1,2-PHENYLENE)PYRENE} 13
DIBENZO[a.h)PYRENE {1,2.5.6-DIBENZOPYRENE} 14
OIBENZO(a,i]PYRENE {1,2,7,8-DIBENZOPYRENE} 15
DIBENZO[a,e]PYRENE (1,2,4,5-OIBENZOPYRENE} 16
CYANOGEN CHLORIDE (CHLORINE CYANIDE} 17-18
ACETONITRILE (ETHANENITRILE} [2] 17-18
CHLOROBENZENE [21 19
ACRYLONITRILE {2-PROPENENITRILE} [2] 20
DICHLOROBENZENE (1,4-OICHLOROBENZENE} 21-22
CHLORONAPHTHALENE (1-) [2] 21-22
CYANOGEN BROMIDE (BROMINE CYANIDE} 23-24
DICHLOROBENZENE (1,2-DICHLOROBENZENE} [2] 23-24
DICHLOROBENZENE (1,3-DICHLOROBENZENE} [2] 25
TRICHLOROBENZENE (1,3,5-TRICHLOROBENZENE) [2] [4] 26-27
TRICHLOROBENZENE (1,2,4-TRICHLOROBENZENE) [2] 26-27
TETRACHLOROBENZENE (1,2,3,5-TETRACHLOROBENZENE) [2] [4] 20
CHLOROMETHANE (METHYL CHLORIDE} [2] 29-30
TETRACHLOROBENZENE (1.2.4.5-TETRACHLOROBENZENE) 29-30
PENTACHLOROBENZENE [2] 31-33
HEXACHLOROBENZENE [2] 31-33
BROMOMETHANE (METHYL BROMIDE} [2] 31-33
TETRACHLOROOIBENZO-p-OIOXIN (2.3,7.8-) (TCDD} 34
CLASS 2
TOLUENE {METHYLBENZENE} [2] 35
TETRACHLOROETHENE [2] 36
CHLOROANILINE {CHLOROBENZENAMINE} 37
DDE(>.1 -OICHLORO-2.2-BIS(4-CHLOROPHENYLETHYLENE} 38
FORMIC ACID {METHANOIC ACID} 39-40
PHOSGENE (CARBONYL CHLORIDE} 39-40
TRICHLOROETHENE [2] 41
DIPHENYLAMINE (N-PHENYLBENZENAMINE) 42-44
DICHLOROETHENE (1,1-) [2] 42-44
FLUOROACETIC ACID 42-44
DIMETHYLBENZ[alANTHRACENE (7,12-) 45
ANILINE {BENZENAMINE} 46-50
FORMALDEHYDE (METHYLENE OXIDE} 46-50
MALONONITRILE (PROPANEDINITRILE} 46-50
METHYL CHLOROCARBONATE (CARBONOCHLORIDIC ACID. METHYL ESTER} 46-50
F-2
-------
OSWER D1r. No. 9938.6
Table O-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Pnncipal Hazardous Organic Constituent Rank
METHYL ISOCYANATE {METHYLCARBYLAMINE} 46-50
AMINOBIPHENYL (4-) {[1,1'-BIPHENYLl-4-AMINE} 51
NAPHTHYLAMINE (1 -) 52-53
NAPHTHYLAMINE (2-) 52-53
OICHLOROETHENE (trans-1,2-) [2] 54
FLUOROACETAMIDE (2-) 55-56
PROPYN-1 -OL (2-) (PROPARGYL ALCOHOL} 55-56
PHENYLENEDIAMINE (1.4) {BENZENEDIAMINE} 57-59
PHENYLENEDIAMINE (1,2-) {BENZENEDIAMINE} 57-59
PHENYLENEDIAMINE (1.3-) {BENZENEDIAMINE} 5"7~- 5 9
BENZIDINE {[1.1'-BIPHENYL]-4.4'DIAMINE} 60-64
ACRYLAMIDE {2-PROPENAMIDE} 60-64
DIMETHYLPHENETHYLAMINE (alpha, alpha-) 60-64
METHYL METHACRYLATE {2-PROPENOIC ACID, 2-METHYL-. METHYL ESTER} 60-64
VINYL CHLORIDE (CHLOROETHENE) 60-64
DICHLOROMETHANE {METHYLENE CHLORIDE} [2] 65-66
METHACRYLONITRILE {2-METHYL-2-PROPENENITRILE} [2] 65-66
DICHLOROBENZIDINE (3.3*-) 67
METHYLCHOLANTHRENE (3-) 68
TOLUENEDIAMINE (2.6-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (1,4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (2.4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (1.3-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (3.5-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (3.4-) {DIAMINOTOLUENE} 69-77
CHLORO-1.3-BUTADIENE (2-) {CHLOROPRENE} 69-77
PRONAMIOE {3,5-OICHLORO-N-[1.1-OIMETHYL-2-PROPYNYL] BENZAMIDE} 69-77
ACETYLAMINOFLUORENE (2-) {ACETAMIDE.N-{9H-FLUOREN-2-YLJ-} 69-77
CLASS 3
DIMETHYLBENZIOINE (3.31-) 78
n-PROPYLAMINE{1-PROPANAMINE} 79
PYRIDINE [2] 80
PICOLINE (2-) {PYRIDINE. 2-METHYL-} 81-84
DICHLOROPROPENE (1,1 -) [2] 81-84
THIOACETAMIDE {ETHANETHIOAMIDE} 81-84
1,2,2-TRICHLORO-l, 1,2-TRIFLUOROETHANE [2] [3] 81-84
BENZ(c]ACRIDINE {3.4-BENZACRIDINE} 85-88
DICHLORODIFLUOROMETHANE [2] 85-88
ACETOPHENONE {ETHANONE, 1-PHENYL-} [2] 85-88
TRICHLOROFLUOROMETHANE [2] 85-88
DICHLOROPROPENE (trans-1.2-) 89-91
ETHYL CYANIDE {PROPIONITRILE} [2] 89-91
BENZOQUINONE {1,4-CYCLOHEXADIENEDIONE} 89-91
DIBENZ[a.h]ACRIDINE {1,2.5.6-DIBENZACRIDlNE} 92-97
DIBENZ[a.j]ACRIDINE {1,2.7.8-OIBENZACRIDINE} 92-97
HEXACHLOROBUTADIENE (trans-1,3) [2] 92-97
NAPHTHOQUINONE (1,4-) {1.4-NAPHTHALENEDlONE} 92-97
DIMETHYL PHTHALATE [2] 92-97
ACETYL CHLORIDE {ETHANOYL CHLORIDE} [2] 92-97
ACETONYLBENZYL-4-HYDROXYCOUMARIN (3-alpha-) {WARFARIN} 98-99
MALEIC ANHYDRIDE {2.5-FURANDIONE} 98-99
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OSWER Dir. No. 9938.6
Table 0-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Principal Hazardous Organic Constituent Rank
PHENOL (HYDROXYBENZENE) 100-101
DlBENZO[c.g]CARBAZOLE (7H-) {3.4.5.6-DIBENZCARBAZOLE} 100-101
CHLOROPHENOL (2-) 102
CRESOL (1,3-) {METHYLPHENOL} 103
CRESOL (1,4-) {METHYLPHENOL} [2] 1 04-1 05
CRESOL (1,2-) {METHYLPHENOL} 104-1 05
ACROLEIN {2-PROPENAL} 106-107
DIHYDROXY-ALPHA-(METHYLAMINO]METHYL BENZYL ALCOHOL (3,4-) 106-107
METHYL ETHYL KETONE {2-BUTANONE} [2] 108-109
DIETHYLSTILBESTEROL 1 08-10 9
BENZENETHIOL {THIOPHENOL} [2] 110
RESORCINOL {1,3-BENZENEDlOL} 111
ISOBUTYL ALCOHOL {2-METHYL-1-PROPANOL} [2] 112
CROTONALOEHYOE {2-BUTENAL} [2] 113-115
DICHLOROPHENOL (2.4-) 113-115
OICHLOROPHENOL (2,6-) 113-115
METHYLACTONITRILE (2-) {PROPANENITRILE.2-HYDROXY-2-METHYL} 116-118
ALLYL ALCOHOL {2-PROPEN-1 -OL} 116-118
CHLOROCRESOL {4-CHLORO-3-METHYLPHENOL} 116-118
DIMETHYLPHENOL (2,4-) 119
CLASS 4
CHLOROPROPENE 3-{ALLYL CHLORIDE} [2] 120
DICHLOROPROPENE (cis-1.3-) 121-125
DICHLOROPROPENE (trans-1.3-) 121-125
TETRACHLOROETHANE (1,1,2,2-) [2] 121-125
TRICHLOROPHENOL (2.4,5-) 121-125
TRICHLOROPHENOL (2.4,6-) 121-125
CHLOROETHANE (ETHYL CHLORIDE) [4J /5/ 126
DICHLOROPROPENE (2.3-) 127-130
HYDRAZINE (DIAMINE) [51 127-130
BENZYL CHLORIDE {CHLOROMETHYLBENZENE} [2] 127-130
DIBROMOMETHANE {METHYLENE BROMIDE} [2] 127-130
DICHLOROETHANE (1,2-) [2] 131
MUSTARD GAS {bis(2-CHLOROETHYLI-SULFIDE} 132-1 34
NITROGEN MUSTARD 132-134
N.N-BIS(2-CHLOROETHYL)2-NAPHTHYLAMINE {CHLORNAPHAZINE} 132-134
DICHLOROPROPENE (3.3-) 135
DICHLORO-2-BUTENE (1,4-) 136-140
TETRACHLOROPHENOL (2.3.4.6-) 136-1 40
TETRACHLOROMETHANE {CARBONTETRACHLORIDE} [2] 136-140
BROMOACETONE {1-BROMO-2-PROPANONE} 136-140
HEXACHLOROPHENE {2.2'-METHYLENEbis[3.4,6-TRICHLOROPHENOL]} 136-140
DIOXANE (1.4-) {1,4-OIETHYLENE OXIDE} [2] 141
CHLORAMBUCIL 142
NITROBENZENE [2] 143
CHLOROPROPIONITRILE (3-) {3-CHLOROPROPANENITRILE} [2] 143-1 44
DICHLORO-2-PROPANOL (1,1-) 145-146
ODD {DICHLORODIPHENYLDICHLOROETHANE} 145-146
DICHLORO-2-PROPANOL (1.3-) 147
PHTHAUC ANHYDRIDE {1,2-BENZENEDICARBOXYLIC ACID ANHYDRIDE} 148-150
METHYL PARATHION 148-150
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OSWER Oir. No. 9938.6
Table D-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Pnncipal Hazardous Organic Constituent flank
NITROPHENOL (4-) 148-1 50
CHLOROOIFLUOROMETHANE [2] [4] 1 51 -1 S3
PENTACHLOROPHENOL - 151-153
HEXACHLOROCYCLOHEXANE (LINDANE) [2] 151-153
DICHLOROFLUOROMETHANE [2] [4] 154-157
DINITROBENZENE(1,3-) 154-157
NITROANIUNE {4-NITROBENZENAMINE} 154-157
PENTACHLOROETHANE [2] 154-157
DINITROBENZENE (1,4-) 158-1 61
OINITROBENZENE (1,2-) 15r-1 61
TRICHLOROETHANE (1,1,2-) [2] 158-161
TRICHLOROMETHANE {CHLOROFORM} [2] 158-161
OIELORIN 162-164
ISODRIN 162-164
ALORIN 162-164
DICHLOROPROPANE (1,3-) IS] 165
NITROTOLUIDINE (5-) {BENZENAMINE.2-METHYL-5-NITRO-} 166-167
CHLOROACETALDEHYOE 166-167
TRICHLOROPROPANE (1,2,3-) [2] 168-173
DINrmOTOLUENE (2,4-) 168-173
DINITROTOLUENE (2,6-) 168-173
HEXACHLOROCYCLOPENTADIENE 168-1 73
BENZAL CHLORIDE {ALPHA, ALPHA-OICHLOROTOLUENE} [2] 168-173
DICHLORO-1 -PROPANOL (2.3-) 168-1 73
ETHYLENE OXIDE {OXIRANE} (5J 174
DICHLOROETHANE (1,1-) (ETHYL1DENE DICHLORIDE} [Sj 175-1 78
DIMETHYLCARBAMOYLCHLORIDE 1 75-1 78
GLYCIDYALDEHYDE {1-PROPANOL-2.3-EPOXY} 1 75-1 78
ODT {DICHLORODIPHENYLTRICHLOROETHANE} 175-1 78
DICHLOROPROPANE (1,2-) {PROPYLENE DICHLORIDE} {51 179
AURAMINE 180-181
HEPTACHLOR 180-181
DICHLOROPROPANE (1,1-) (5} 182
CHLORO-2.3-EPOXYPROPANE (1-) {OXIRANE.2-CHLOROMETHYL-} 183-1 86
OINJTROPHENOL (2,4-) 183-1 86
bis(2-CHLOROETHYL)ETHER [2] 183-186
TRINITROBENZENE {1,3,5-TRINITROBENZENE) 183-1 86
BUTYL-4.6-OINITROPHENOL (2-sec-) {DNBP} 187-188
CYCLOHEXYL-4.6-DINITROPHENOL (2-) 187-188
bis(2-CHLOROETHOXY)METHANE 189-192
CHLORAL {TRICHLOROACETALDEHYOE} 189-1 92
TR1CHLOROMETHANETHIOL 189-192
OINITROCRESOL (4,6-) {PHENOL.2.4-OINITRO-6-METHYL-} 189-192
HEPTACHLOR EPOX1DE 193
DIEPOXYBUTANE (1.2,3,4-) {2.2'-BIOXlRANE} 194
CLASS 5
BENZOTRICHLORIDE {TRICHLOROMETHYLBENZENE} 195-1 96
METHAPYRILENE 195-196
PHENACET1N {N-[4-ETHOXYPHENYL|ACETAMIDE} 197-198
METHYL HYDRA2INE [51 197-198
DIBROMOETHANE (1.2-) {ETHYLENE DIBROMIOE} 199
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OSWER Dir. No. 9938.6
Table 0-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Principal Hazardous Organic Constituent Rank
AFLATOXINS 200
TRICHLOROETHANE (1,1,1-) {METHYL CHLOROFORM} [2] 201
HEXACHLOROETHANE [2] 202-203
BROMOFORM {TRIBROMOMETHANE} [2] 202-203
CHLOROBENZILATE 204-207
ETHYL CARBAMATE (URETHAN) {CARBAMIC ACID. ETHYL ESTER} 204-207
ETHYL METHACRYLATE (2-PROPENOIC ACID. 2-METHYL-.ETHYL ESTER} 204-207
LASIOCARPINE 204-207
AMITROLE {1H-1.2.4-TRIAZOL-3-AMINE} 208-209
MUSCIMOL {5-AMINOMETHYL-3-ISOAZOTOL} 208*209
IOOOMETHANE (METHYL IODIDE} 210
DICHLOROPHENOXYACETIC ACID (2.4-) {2.4-D} 211-213
CHLOROETHYLVINYLETHER (2-) {ETHENE,[2-CHLOROETHOXY]-} [2] 211-213
METHYLENE BIS(2-CHLOROANILINE) (4.4-) 211-213
DIBROMO-3-CHLOROPROPANE (1,2-) 214
TETRACHLOROETHANE (1,1,1,2-) [2] 215
DIMETHYLHYDRAZINE (1,1-) (SI 216-217
N.N-OIETHYLHYDRAZINE {1,2-OIETHYLHYDRAZINE} 216-217
CHLOROMETHYLMETHYL ETHER {CHLOROMETHOXYMETHANE} 218-220
DIMETHYL-1 -METHYLTHlO-2-8UTANONE.O-((METHYLAMINO)-CARBONYL] 218-220
OXIME (3.3-) {THIOFANOX}
OIMETHYLHYDRAZINE (1.2-) 218-220
CHLORDANE (ALPHA AND GAMMA ISOMCRS) 221
biS(CHLOROMETHYL)ETHER {METHANE-OXYbis(2-CHLORO-j} 222-223
PARATHION [5] 222-223
DICHLOROPROPANE (2,2-) [5] 224
MALEIC HYDRAZIDE {1.2-DIHYDRO-3.6-PYRIDAZINEDIONE} 225
BROMOPHENYL PHENYL ETHER (4-) (BENZENE. 1-BROMO-4-PHENOXY-} 226
bis(2-CHLOROISOPROPYL)ETHER 227-228
DIHYDROSAFROLE (1.2-METHYLENEDIOXY-4-PROPYLBENZENE} 227-228
METHYL METHANESULFONATE (METHANESUFONIC ACID, METHYL ESTER} 229
PROPANE SULFONE (1.3-) (1.2-OXATHIOLANE.2.2-DIOXIDE} 230
SACCHARIN (1.2-BENZOISOTHIAZOLIN-3-ONE. 1.1-DIOXIDE} 231
METHYL-2-METHYLTHIO-PROPIONALDEHYDE-O-(METHYLCARBONYL)OXIME(2-) 232-233
METHYOMYL 232-233
HEXACHLOROPROPENE (2] 234
PENTACHLORONITROBENZENE {PCNB} 235-239
DIALLATE (S-(2.3-OICHLOROALLYL)DIISOPROPYL THIOCARBAIWVTE) 235-239
ETHYLENEIMINE {AZIRIDINE} 235-239
ARAMITE 235-239
DIMETHOATE 235-239
TRICHLOROPHENOXYACETIC ACID (2,4,5-) {2.4.5-T} 240-241
TRICHLOROPHENOXYPROPIONIC ACID (2,4.5-) {2.4.5-TP} {SILVEX} 240-241
tris(2.3-OIBROMOPROPYL)PHOSPHATE 242
METHYLAZIRIDINE (2-) {1,2-PROPYLENIMINE} 243-244
METHOXYCHLOR 243-244
BRUCINE {STRYCHNIOIN-10-ONE.2.3-DIMETHOXY-} 245-246
KEPONE 245-246
ISOSAFROLE {1.2-METHYLENEDIOXY-4-ALLYLBENZENE} 247-249
SAFROLE {1.2-METHYLENE-4-ALLYLBENZENE} 247-249
tns(l-AZRIDINYL) PHOSPHINE SULFIDE 247-249
DIMETHOXYBENZIDINE (3.3'-) 250
DIPHENYLHYDRAZINE (1.2-) 251
O.O-DIETHYLPHOSPHORIC ACID.O-p-NITROPHENYL ESTER 252
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OSWER Dir. No. 9938.6
Table D-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Principal Hazardous Organic Constituent Rank
CLASS 6
n-BUTYLBENZYL PHTHALATE [2] 253
0.0-DIETHYL-O-2-PYRAZINYL PHOSPHOROTHIOATE 254
DIMETHYLAMINOAZOBENZENE 255
DIETHYL PHTHALATE 256-257
O.O-DIETHYL-S-METHYL ESTER OF PHOSPHORIC ACID 256-257
O.O-DIETHYL S-{(ETHYLTHIO)METHYL]ESTER OF PHOSPHORODITHIOIC ACID 258-259
CITRUS RED No. 2 {2-NAPHTHOL.1-{(2,5-DIMETHOXYPHENYL)AZO]} 258-259
TRYPAN BLUE 260
ETHYL M6THANESULFONATE (METHANESULFONIC ACID. ETHYL ESTER) 26T--265
DISULFOTON 261-265
DIISOPROPYLFLUOROPHOSPHATE {DFP} 261-265
O.O.O-TRIETHYL PHOSPHOROTHIOATE 261-265
Di-n-BUTYL PHTHALATE 261-265
PARALDEHYDE {2,4,6-TRIMETHYL-1,3,5-TRIOXANE} [51 266
Oi-n-OCTYL PHTHALATE [2] 267
OCTAMETHYLPYROPHOSPHORAMIDE {OCTAMETHYLDIPHOSPHORAMIDE) 268
bis(2-ETHYLHEXYL)PHTHALATE 269-270
METHYLTHIOURACIL 269-270
PROPYLTHIOURACIL 271
CLASS 7
STRYCHNINE {STRYCHNIDIN-10-ONE} 272
CYCLOPHOSPHAMIDE 273-276
NICOTINE {(S)-3-[1-METHYL-2-PYRROLIDINYL]PYRIDINE} 273-276
RESERPINE 273-276
TOLUIDINE HYDROCHLORIDE (2-METHYL-BENZENAMINE HYDROCHLORIDE} 273-276
TOLYLENE DIISOCYANATE {1,3-DIISOCYANATOMETHYLBENZENE} 277
ENDRIN 278
BUTANONE PEROXIDE (2-) {METHYL ETHYL KETONE. PEROXIDE) 279
TETRAETHYLPYROPHOSPHATE 280
NITROGLYCERINE {TRINITRATE-1.2.3-PROPANETRIOL} [51 281
TETRAETHYLDITHIOPYROPHOSPHATE 282
ETHYLENEbisDITHlOCARBAMIC ACID 283
TETRANITROMETHANE [51 284
URACIL MUSTARD (5-[bis(2-CHLOROETHYL)AMINOlURACIL) 285
ACETYL-2-THIOUREA (1-) (ACETAMIDE.N-fAMINOTHIOXOMETHYLl-) 286-290
CHLOROPHENYL THIOUREA (1-) (THIOUREA,[2-CHLOROPHENYLI-) 286-290
N-PHENYLTHIOUREA 286-290
NAPHTHYL-2-THIOUREA (1 -) {THIOUREA, 1-NAPHTHALENYL-) 286-290
THIOUREA {THIOCARBAMIDE) 286-290
DAUNOMYCIN 291-292
ETHYLENE THIOUREA {2-IMIDAZOLIDINETHIONE) 291-292
THIOSEMICARBAZIDE {HYDRAZINECARBOTHIOAMIDE) 293-294
MELPHALAN {ALANINE,3-[p-bis(2-CHLOROETHYL)AMINOlPHENYL-.L-) 293-294
DITHIOBIURET (2.4-) {THIOIMIDODICARBONIC DIAMIDE) 295-296
THIURAM {bis(DIMETHYLTHIOCARBAMOYLlDISULFIDE) 295-296
AZASERINE {L-SERINE.DIAZOACETATE[ESTER]) 297
HEXAETHYL TETRAPHOSPHATE 298
NITROGEN MUSTARD N-OXIDE 299-300
NITROQUINOLINE-1-OXIDE (4-) 299-300
CYCASIN {beta-D-GLUCOPYRANOSIDE.[METHYL-ONN-AZOXY]METHYL-) 301
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OSWER Dlr. No. 9938.6
Table 0-1. Principal Hazardous Organic Constituent Thermal Stability Index (continued)
Principal Hazardous Organic Constituent Rank
STREPTOZOTOCIN 302
N-METHYL-N'-NITRO-N-NITROSOGUANIDINE 303-31 8
N-NITROSO-OI-ETHANOLAMINE-{[2.2'-NITROSOIMINO]bisETHANOL} 303-31 8
N-NITROSO-OI-N-8UTYLAMINE {N-BUTYL-N-NITROSO-1-BUTANAMINE} 303-31 8
N-NITROSO-N-ETHYLUREA {N-ETHYL-N-NITROSOCARBAMIDE} 303-31 8
N-NITROSO-N-METHYLUREA {N-METHYL-N-NITROSOCARBAMIDE} 303-31 8
N-NITROSO-N-METHYLURETHANE 303-318
N-NITROSODIETHYLAMINE {N-ETHYL-N-NITROSOETHANAMINE} 303-31 8
N-NITROSODIMETHYIAMINE {DIMETHYLNITROSAMINE} 303-31 8
N-NITROSOMETHYLETHYLAMINE {N-METHYL-N-NITROSOETHANAMINE} -303X31 8
N-NITROSOMETHYLVINYLAMINE (N-METHYL-N-NITROSOETHENAMINE) 303-31 8
N-NITROSOMORPHOLINE 303-318
N-NITROSONORNICOTINE 303-31 8
N-NITROSOPIPERIOINE {HEXAHYDRO-N-NITROSOPYRIOINE} 303-31 8
N-NITROSOSARCOSINE 303-318
NITROSOPYRROUDINE {N-NITROSOTETRAHYDROPYRROLE} 303-31 8
DI-n-PROPYLNITROSAMINE {N-NITROSO-OI-n-PROPYLAMINE} 303-31 8
OXABICYCLO[2.2.1 JHEPTANE-2.3-DICARBOXYUC ACID (7-) {ENDOTHAL} 319
ENOOSULFAN 320
FOOTNOTES:
1. UNITS OF TEMPERATURE ARE DEGREES CELSIUS.
2. BOLDFACE INDICATES COMPOUND THERMAL STABILITY IS' "EXPERIMENTALLY EVALUATED"
(RANKING BASED ON UDRI EXPERIMENTAL DATA COUPLED WITH REACTION KINETIC THEORY).
3. NON-APPENDIX VIII COMPOUND.
4. N.O.S. LISTING: RANKING IS PRESENTED BASED ON EITHER UDRI OR LITERATURE EXPERIMENTAL
DATA COUPLED WITH REACTION KINETIC THEORY.
5. ITALICS INDICATE COMPOUND THERMAL STABILITY IS RANKED BASED ON LITERATURE
EXPERIMENTAL DATA COUPLED WITH REACTION KINETIC THEORY.
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OSWER Dir. No. 9938.6
Table D-2. Principal Hazardous Organic Constituent Thermal Stability Index • Alphabetized
Principal Hazardous Organic Constituent Rank
ACETONITRILE (ETHANENITRILE) [2] 17-18
ACETONYLBENZYL-4-HYOROXYCOUMARIN (3-alpha-) (WARFARIN) 98-99
ACETOPHENONE {ETHANONE, 1-PHENYL-} [2] 85-88
ACETYL CHLOHIDE (ETHANOYL CHLORIDE} [2] 92-97
ACETYL-2-THIOUREA (1-) (ACETAMIDE,N-[AMINOTH1OXOMETHYL]-} 286-290
ACETYLAMINOFLUORENE (2-) (ACETAMIDE.N-[9H-FLUOREN-2-YL]-) 69-77
ACROLEIN {2-PROPENAL} 106-107
ACRYLAMIDE (2-PROPENAMIDE) 60-64
ACRYLONITRILE {2-PROPENENITRILE} [2] 20
AFLATOX1NS 2lQO
ALDRIN 162-164
ALLYL ALCOHOL (2-PROPEN-1 -OL} 116-118
AMINOBIPHENYL (4-) {[1,1' BIPHENYLJ-4-AMINE} 51
AMITROLE {1H-1.2.4-TRIAZOL-3-AMINE} 208-209
ANILINE (BENZENAMINE) 46-50
ARAMITE 235-239
AURAMINE 180-181
AZASERINE {L-SERINE.DIAZOACETATE[ESTER]} 297
BENZAL CHLORIDE {ALPHA, ALPHA-DICHLOROTOLUENE} [2] 168-1 73
BENZANTHRACENE (1,2-) {BENZ[aJANTHRACENE) 9
BENZENE [2] 3
BENZENETHIOL {THIOPHENOL) [2] 110
BENZIDINE {[1.1'-BIPHENYL]-4,4' DIAMINE) 60-64
BENZOQUINONE {1.4-CYCLOHEXADIENEDIONE) 89-91
BENZOTRICHLORIOE {TRICHLOROMETHYLBENZENE} 195-196
BENZO[a)PYRENE {1.2-BENZOPYRENE) 11
BENZO[b)FLUORANTHENE {2.3-BENZOFLUORANTHENE} 8
BENZO{j]FLUORANTHENE {7,8-BENZOFLUORANTHENE} 7
BENZYL CHLORIDE {CHLOROMETHYLBENZENE) [2] 127-130
BENZ[c]ACRIDINE {3.4-BENZACRIDINE} 85-88
bis(2-CHLOROETHOXY)METHANE 189-192
bis<2-CHLOROETHYL)ETHER [2] 1 83-1 86
bis(2-CHLOROISOPROPYL)ETHER 227-228
biS(2-ETHYLHEXYL)PHTHALATE 269-270
bis(CHLOROMETHYL)ETHER {METHANE-OXYbis[2-CHLORO-]) 222-223
BROMOACETONE {1 -BROMO-2-PROPANONE) 136-140
BROMOFORM {TRIBROMOMETHANE) [2] 202-203
BROMOMETHANE (METHYL BROMIDE) [2] 31-33
BROMOPHENYL PHENYL ETHER (4-) (BENZENE. 1-BROMO-4-PHENOXY-) 226
BRUCINE (STRYCHNIDIN-10-ONE.2.3-DIMETHOXY-) 245-246
BUTANONE PEROXIDE (2-) (METHYL ETHYL KETONE, PEROXIDE) 279
BUTYL-4.6-OINITROPHENOL (2-sec-) (DNBP) 187-188
CHLORAL (TRICHLOROACETALDEHYDE) 1 89-1 92
CHLORAMBUCIL 142
CHLORDANE (ALPHA AND GAMMA ISOMERS) 221
CHLORO-1.3-BUTADIENE (2-) (CHLOROPRENE) 69-77
CHLORO-2.3-EPOXYPROPANE (1 -) {OXIRANE,2-CHLOROMETHYL-} 183-186
CHLOROACETALDEH YDE 166-167
CHLOROANILINE (CHLOROBENZENAMINE) 37
CHLOROBENZENE [2] 19
CHLOROBENZILATE 204-207
CHLOROCRESOL (4-CHLORO-3-METHYLPHENOL) 116-118
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OSWER Dir. No. 9938.6
Table 0-2. Principal Hazardous Organic Constituent Thermal Stability Index - Alphabetized (continued)
Principal Hazardous Organic Constituent Rank
CHLOROOIFLUOROMETHANE [2] [4] 151-153
CHLOROETHANE (ETHYL CHLORIDE) [4J [5] 126
CHLOROETHYLVINYLETHER (2-) (ETHENE,[2-CHLOROETHOXY]-} [2] 211-213
CHLOROMETHANE (METHYL CHLORIDE} [2] 29-30
CHLOROMETHYLMETHYL ETHER {CHLOROMETHOXYMETHANE} 218-220
CHLORONAPHTHALENE (1 -) [2] 21-22
CHLOROPHENOL (2-) 102
CHLOROPHENYL THIOUREA (1-) {THIOUREA,[2-CHLOROPHENYL]-> 286-290
CHLOROPROPENE (3-) {ALLYL CHLORIDE) [2] 120
CHLOROPROPIONITRILE (3-) {3-CHLOROPROPANENITRILE} [2] 143* 1 44
CHRYSENE (1,2-BENZPHENANTHRENE) 10
CITRUS RED No. 2 {2-NAPHTHOL.1-{(2.5-DIMETHOXYPHENYL)AZO]} 258-259
CRESOL (1,2-) {METHYLPHENOL} 104-1 05
CRESOL (1,3-) {METHYLPHENOL} 103
CRESOL (1,4.) {METHYLPHENOL} [2] 104-1 05
CROTONALDEHYDE {2-8UTENAL} [2] 113-115
CYANOGEN BROMIDE {BROMINE CYANIDE} 23-24
CYANOGEN CHLORIDE {CHLORINE CYANIDE} 17-18
CYANOGEN {ETHANEDINITRILE} 1
CYCASIN {beta-D-GLUCOPYRANOSlDE.[METHYL-ONN-AZOXY]METHYL-} 301
CYCLOHEXYL-4.6-OINITROPHENOL (2-) 187-188
CYCLOPHOSPHAMIDE 273-276
DAUNOMYCIN 291-292
ODD {DICHLORODIPHENYLDICHLOROETHANE} 145-1 46
DDE{1,1 -OlCHLORO-2.2-BlS(4-CHLOROPHENYLETHYLENE} 38
DDT {DICHLOROOIPHENYLTRICHLOROETHANE} 175-178
Di-n-BUTYL PHTHALATE 261-265
Di-n-OCTYL PHTHALATE [2] 267
DI-n-PROPYLNITROSAMINE {N-NITROSO-DI-n-PROPYLAMINE} 303-31 8
DIALLATE {S-(2.3-DICHLOROALLYL)DllSOPROPYL THIOCARBAMATE) 235-239
DIBENZOfa.ejPYRENE {1.2.4.5-DIBENZOPYRENE} 16
DIBENZO[a,hlPYRENE {1.2.5.6-OIBENZOPYRENE} 14
DIBENZO[a,i]PYRENE {1,2.7.8-OIBENZOPYRENE} 15
DIBENZO[c.g]CARBAZOLE (7H-) {3.4.5.6-OIBENZCARBAZOLE} 100-1 01
DIBENZ[a,h]ACRIDINE {1,2.5,6-OIBENZACRIDINE} 92-97
DIBENZ[a.h]ANTHRACENE (1,2,5,6-DIBENZANTHRACENE) 12
DI8ENZ[a.|]ACRIDINE {1,2,7,8-DIBENZACRIDINE} 92-97
DIBROMO-3-CHLOROPROPANE (1,2-) 214
DIBROMOETHANE (1,2-) {ETHYLENE DIBROMIDE} 199
DIBROMOMETHANE {METHYLENE BROMIDE} [2] 127-130
DICHLORO-1-PROPANOL (2.3-) 168-1 73
DICHLORO-2-BUTENE (1,4-) 136-1 40
DICHLORO-2-PROPANOL (1,1-) 145-1 46
DICHLORO-2-PROPANOL (1.3-) 147
DICHLOROBENZENE {1,2-OICHLOROBENZENE} [2] 23-24
DICHLOROBENZENE {1,3-OICHLOROBENZENE} [2] 25
DICHLOROBENZENE {1,4-DICHLOROBENZENE} 21-22
DICHLOROBENZIDINE (3,3'-) 67
DICHLORODIFLUOROMETHANE [2] 85-88
DICHLOROETHANE (1,1~) (ETHYLIDENE DICHLORIDE} (51 175-178
DICHLOROETHANE (1,2-) [2] 131
DICHLOROETHENE (1,1-) [2] 42-44
F-10
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OSWER Dir. No. 9938.6
Table D-2. Principal Hazardous Organic Constituent Thermal Stability Index • Alphabetized (continued)
Principal Hazardous Organic Constituent Rank
OICHLOROETHENE (trans-1,2-) [2] 54
OICHLOROFLUOROMETHANE [2] [4] 154-157
DICHLOROMETHANE (METHYLENE CHLORIDE) [2] 65-66
DICHLOROPHENOL (2.4-) 113-115
DICHLOROPHENOL (2.6-) 113-115
DICHLOROPHENOXYACETIC ACID (2,4-) {2.4-O} 211-213
DICHLOROPROPANE (1,1 •) [5] 182
DICHLOROPROPANE (1,2-) {PROPYLENE DICHLORIDE} (51 179
DICHLOROPROPANE (1,3-) {SJ 165
DICHLOROPROPANE (2,2-) {5] -224
OICHLOROPROPENE (1,1-) [2] 81-84
DICHLOROPROPENE (2.3-) 127-1 30
OICHLOROPROPENE (3,3-) 135
DICHLOROPROPENE (cis-1,3-) 121-125
DICHLOROPROPENE (trans-1,2-) 89-91
DICHLOROPROPENE (trans-1.3-) 121-125
DIELDRIN 161-163
DIEPOXYBUTANE (1.2,3,4-) {2,2'-BIOXIRANE} 194
DIETHYL PHTHALATE 256-257
DIETHYLSTILBESTEROL 108-1 09
DIHYDROSAFROLE {1.2-METHYLENEDIOXY-4-PROPYLBENZENE} 227-228
DIHYDROXY-ALPHA-IMETHYLAMINOIMETHYL BENZYL ALCOHOL (3,4-) 1 oe-107
DIISOPROPYLFLUOROPHOSPHATE {DFP} 261-265
DIMETHOATE 235-239
DIMETHOXYBENZIDINE (3.31-) 250
DIMETHYL PHTHALATE [2] 92-97
DIMETHYL-1 -METHYLTHIO-2-BUTANONE.O-{(METHYLAMINO)-CARBONYL) 218-220
OXIME (3.3-) (THIOFANOX)
DIMETHYLAMINOAZOBENZENE 255
DIMETHYLBENZIDINE (3.31-) 78
DIMETHYLBENZ[a|ANTHRACENE (7.12-) 45
DIMETHYLCARBAMOYLCHLORIDE 175-1 78
DIMETHYLHYDRAZINE (1,1 •) [SJ 216-217
DIMETHYLHYDRAZINE (1.2-) 218-220
DIMETHYLPHENETHYLAMINE (alpha, alpha-) 60-64
DIMETHYLPHENOL (2.4-) 119
DINITROBENZENE (1,2-) 158-161
DINITROBENZENE(1,3-) 154-157
DINITROBENZENE (1,4-) 158-161
DINITROCRESOL (4,6-) {PHENOL.2.4-OINITRO-6-METHYL-} 189-192
DINITROPHENOL (2.4-) 183-186
DINITROTOLUENE (2,4-) 168-173
DINITROTOLUENE (2,6-) 168-1 73
DIOXANE (1,4-) {1,4-OIETHYLENE OXIDE} [2] 141
DIPHENYLAMINE {N-PHENYLSENZENAMINE} 42-44
DIPHENYLHYDRAZINE (1,2-) 251
DISULFOTON 261-265
DITHIOBIURET (2.4-) {THIOIMIDODICARBONIC DIAMIDE} 295-296
ENDOSULFAN 320
ENDRIN 278
ETHYL CAR8AMATE {URETHAN} {CARBAMIC ACID, ETHYL ESTER} 204-207
ETHYL CYANIDE (PROPIONITRILE} [2] 89-91
ETHYL METHACRYLATE (2-PROPENOIC ACID. 2-METHYL-.ETHYL ESTER} 204-207
F-ll
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OSWER Dir. No. 9938.6
Table 0-2. Principal Hazardous Organic Constituent Thermal Stability Index • Alphabetized (continued)
Principal Hazardous Organic Constituent Rank
ETHYL METHANESULFONATE {METHANESULFONIC ACID. ETHYL ESTER) 261-265
ETHYLENE OXIDE {OXIRANE} [5] 174
ETHYLENE THIOUREA {2-IMIDAZOLIDINETHIONE} 291-292
ETHYLENEbisOITHlOCARBAMIC ACID 283
ETHYLENEIMINE {AZIRIDINE} 235-239
FLUORANTHENE {BENZO[j,klFLUORENE} 6
FLUOROACETAMIDE (2-) 55-56
FLUOROACETIC ACID 42-44
FORMALDEHYDE {METHYLENE OXIDE} 46-50
FORMIC ACID (METHANOIC ACID} 3"9^- 4 0
GLYCIDYALDEHYDE (1 -PROPANOL-2.3-EPOXY} 175 -1 7 8
HEPTACHLOR 180-181
HEPTACHLOR EPOXIDE 193
HEXACHLOROBENZENE [2] 31-33
HEXACHLOROBUTAOIENE (trans-1,3) [2] 92-97
HEXACHLOROCYCLOHEXANE {LINDANE} [2] 151-153
HEXACHLOROCYCLOPENTADIENE 168-1 73
HEXACHLOROETHANE [2] 202-203
HEXACHLOROPHENE {2,2'-METHYLENEbis[3,4.6-TRICHLOROPHENOL]} 136-140
HEXACHLOROPROPENE [2] 234
HEXAETHYL TETRAPHOSPHATE 298
HYDRAZINE (DIAMINE) 127-130
HYDROGEN CYANIDE {HYDROCYANIC ACID} [2] 2
INDENO(1,2.3-cd)PYRENE {1,10-(1.2-PHENYLENE)PYRENE} 13
IOOOMETHANE {METHYL IODIDE} 210
ISOBUTYL ALCOHOL {2-METHYL-1 -PROPANOL} [2] 112
ISODRIN ' 162-164
ISOSAFROLE {1.2-METHYLENEDIOXY-4-ALLYLBENZENE} 247-249
KEPONE 245-246
LASIOCARPINE 204-207
MALEIC ANHYDRIDE {2.5-FURANDIONE} 98-99
MALEIC HYDRAZIDE {1.2-OIHYDRO-3.6-PYRIDAZINEDIONE} 225
MALONONITRILE {PROPANEDINITRILE} 46-50
MELPHALAN {ALANINE.3-{p-biS(2-CHLOROETHYL)AMINO]PHENYL-.L-} 293-294
METHACRYLONITRILE {2-METHYL-2-PROPENENITRILE} [2] 65-66
METHAPYRILENE 195-196
METHOXYCHLOR 243-244
METHYL CHLOROCARBONATE {CARBONOCHLORIDIC ACID, METHYL ESTER} 46-50
METHYL ETHYL KETONE {2-BUTANONE} [2] 108-109
METHYL HYDRAZINE [5J 197-198
METHYL ISOCYANATE {METHYLCARBYLAMINE} 46-50
METHYL METHACRYLATE {2-PROPENOIC ACID. 2-METHYL-. METHYL ESTER} 60-64
METHYL METHANESULFONATE {METHANESULFONIC ACID, METHYL ESTER} 229
METHYL PARATHION 148-150
METHYL.2-METHYLTHIO-PROPIONALDEHYDE-O-(METHYLCARBONYL)OXIME(2-) 232-233
METHYLACTONITRILE (2-) {PROPANENITRILE,2-HYDROXY-2-METHYL} 116-118
METHYLAZIRIDINE (2-) {1,2-PROPYLENIMINE} 243-244
METHYLCHOLANTHRENE (3-) 68
METHYLENE BIS(2-CHLOROANIUNE) (4,4-) 211-213
METHYLTHIOURACIL 269-270
METHYOMYL 232-233
MUSCIMOL {5-AMINOMETHYL-3-ISOA20TOL} 208-209
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OSWER Dlr. No. 9938.6
Table 0-2. Principal Hazardous Organic Constituent Thermal Stability Index - Alphabetized (continued)
Pnncipal Hazardous Organic Constituent Rank
MUSTARD GAS {bis[2-CHLOROETHYLl-SULFIDE}
N.N-BIS(2-CHLOROETHYL)2-NAPHTHYLAMINE{CHLORNAPHAZINE}
N.N-OIETHYLHYDRAZINE {1.2-DIETHYLHYDRAZINE}
n-BUTYLBENZYL PHTHALATE [2]
N-METHYL-N'-NITRO-N-NITROSOGUANIDINE
N-NITROSO-OI-ETHANOLAMINEC[2.2'-NITROSOIMINO]bisETHANOL}
N-NITROSO-DI-N-BUTYLAMINE {N-BUTYL-N-NITROSO-1-8UTANAMINE)
N-NITROSO-N-ETHYLUREA{N-ETHYL-N-NITROSOCARBAMIDE}
N-NITROSO-N-METHYLUREA{N-METHYL-N-NITROSOCARBAMIDE}
N-NITROSO-N-METHYLURETHANE
N-NITROSODIETHYLAMINE{N-ETHYL-N-NITROSOETHANAMINE)
N-NITROSODIMETHYLAMINE {DIMETHYLNITROSAMINE}
N-NITROSOMETHYLETHYLAMINE{N-METHYL-N-NITROSOETHANAMINE}
N-NITROSOMETHYLVINYLAMINE{N-METHYL-N-NITROSOETHENAMINE)
N-NITROSOMORPHOLINE
N-NITROSONORNICOTINE
N-NITROSOPIPERIDINE{HEXAHYDRO-N-NITROSOPYRIDINE}
N-NITROSOSARCOSINE
N-PHENYLTHIOUREA
n-PROPYLAMINE (1-PROPANAMINE}
NAPHTHALENE [2]
NAPHTHOQUINONE (1.4-) {1,4-NAPHTHALENEDIONE}
NAPHTHYL-2-THIOUREA (1-) (THIOUREA. 1-NAPHTHALENYL-}
NAPHTHYLAMINE(I-)
NAPHTHYLAMINE (2-)
NICOTINE {(S)-3-{ 1 -METHYL-2-PYRROLIDINYLJPYRIDINE}
NITROANILINE (4-NITROBENZENAMINE)
NITROBENZENE [2]
NITROGEN MUSTARD
NITROGEN MUSTARD N-OXIDE
NITROGLYCERINE {TRINITRATE-1,2,3-PROPANETRIOL} (51
NITROPHENOL (4-)
NITROQUINOLINE-1-OXIDE (4-)
NITROSOPYRROLIDINE{N-NITROSOTETRAHYDROPYRROLE}
NITROTOLUIDINE (5-) {BENZENAMINE.2-METHYL-5-NITRO-}
O.O.O-TRIETHYL PHOSPHOROTHIOATE
O.O-DIETHYL S-((ETHYLTHIO)METHYL]ESTER OF PHOSPHORODITHIOIC ACID
O.O-OIETHYL-O-2-PYRAZINYL PHOSPHOROTHIOATE
O.O-OIETHYL-S-METHYL ESTER OF PHOSPHORIC ACID
O.O-OIETHYLPHOSPHORIC ACID,O-p-NITROPHENYL ESTER
OCTAMETHYLPYROPHOSPHORAMIDE{OCTAMETHYLDIPHOSPHORAMIDE}
OXABICYCLOI2.2.11HEPTANE-2.3-DICARBOXYUC ACID (7-) {ENDOTHAL}
PARALDEHYDE {2,4,6-TRIMETHYL-1,3,S-TRIOXANE} [51
PARATHION [51
PENTACHLOROBENZENE [2]
PENTACHLOROETHANE [2]
PENTACHLORONITROBENZENE {PCNB}
PENTACHLOROPHENOL
PHENACETIN {N-(4-ETHOXYPHENYL]ACETAMIOE}
PHENOL {HYDROXYBENZENE}
PHENYLENEDIAMINE (1.2-) {BENZENEDIAMINE}
PHENYLENEDIAMINE (1.3-) {BENZENEDIAMINE}
132-134
132-134
216-217
253
303-318
303-318
303-318
303-318
303-318
303~-318
303-318
303-318
303-318
303-318
303-318
303-318
303-318
303-318
286-290
79
5
92-97
286-290
52-53
52-53
273-276
154-157
143
132-134
299-300
281
148-150
299-300
303-318
166-167
261-265
258-259
254
256-257
252
268
319
266
222-223
31-33
154-157
235-239
151-153
197-198
100-101
57-59
57-59
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OSWER Oir. No. 9938.6
Table 0-2. Principal Hazardous Organic Constituent Thermal Stability Index - Alphabetized (continued)
Principal Hazardous Organic Constituent Rank
PHENYLENEDIAMINE (1,4) {BENZENEDIAMINE} 57-59
PHOSGENE {CARBONYL CHLORIDE) 39-40
PHTHALIC ANHYDRIDE {1,2-BENZENEDlCARBOXYLIC ACID ANHYDRIDE) 148-1 50
PICOLINE (2-) {PYRIDINE. 2-METHYL-) 81-84
PRONAMIDE {3.5-OICHLORO-N-{ 1.1 -DIMETHYL-2-PROPYNYLl BENZAMIDE) 69-77
PROPANE SULFONE (1.3-) {1,2-OXATHIOLANE.2.2-DlOXIDE) 230
PROPYLTHIOURACIL 271
PROPYN-1 -OL (2-) {PROPARGYL ALCOHOL) 55-56
PYRIDINE [2] 80
RESERPINE " ^ 73V2 7 6
RESORCINOL {1,3-BENZENEDIOL) 111
SACCHARIN {1.2-BENZOISOTHIAZOLIN-3-ONE. 1,1-DIOXIDE) 231
SAFROLE {1.2-METHYLENE-4-ALLYLBENZENE} 247-249
STREPTOZOTOCIN 302
STRYCHNINE {STRYCHNIDIN-10-ONE} 272
SULFUR HEXAFLUORIDE [3] 4
TETRACHLOROBENZENE (1,2,3,5-TETRACHLOROBENZENE) [2] [4] 20
TETRACHLOROBENZENE (1,2,4,5-TETRACHLOROBENZENE) 29-30
TETRACHLORODIBENZO-p-DIOXIN (2,3,7,8-) {TCDO} 34
TETRACHLOROETHANE (1,1,1,2-) [2] 215
TETRACHLOHOETHANE (1,1,2,2-) [2] 121-125
TETRACHLOHOETHENE [2] 36
TETRACHLOROMETHANE {CARBONTETRACHLORIDE) [2] 136-140
TETRACHLOROPHENOL (2,3,4,6-) 136-140
TETRAETHYLDITHIOPYROPHOSPHATE 282
TETRAETHYLPYROPHOSPHATE 280
' TETRANITROMETHANE {51 284
THIOACETAMIDE {ETHANETHIOAMIOE} 81-84
THIOSEMICARBAZIDE {HYDRAZINECARBOTHIOAMIDE} 293-294
THIOUREA {THIOCARBAMIDE) 286-290
THIURAM {bis{D1METHYLTHIOCARBAMOYLlDISULFIDE} 295-296
TOLUENE {METHYLBENZENE} [2] 35
TOLUENEDIAMINE (1,3-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (1,4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (2,4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (2.6-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (3,4-) {DIAMINOTOLUENE} 69-77
TOLUENEDIAMINE (3,5-) {DIAMINOTOLUENE} 69-77
TOLUIDINE HYDROCHLORIOE {2-METHYL-BENZENAMINE HYDROCHLORIDE) 273-276
TOLYLENE DIISOCYANATE {1.3-DllSOCYANATOMETHYLBENZENE} 277
TRICHLOROBENZENE (1,2,4-TRICHLOROBENZENE) [2] 26-27
TRICHLOROBENZENE (1,3,5-TRICHLOROBENZENE) [2] [4] 26-27
TRICHLOROETHANE (1,1,1-) {METHYL CHLOROFORM} [2] 201
TRICHLOROETHANE (1,1,2-) [2] 158-161
TRICHLOROETHENE12] 41
TRICHLOROFLUOROMETHANE [2] 85-88
TRICHLOROMETHANE {CHLOROFORM} [2] 195-196
TR1CHLOROMETHANETHIOL 189-192
TRICHLOROPHENOL (2,4,5-) 121-125
TRICHLOROPHENOL (2,4.6-) 121-125
TRICHLOROPHENOXYACET1C ACID (2,4,5-) {2.4.5-T) 240-241
TRICHLOROPHENOXYPROPIONIC ACID (2,4,5-) {2,4.5-TP} {SILVEX} 240-241
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OSWER Dir. No. 9938.6
Table D-2. Principal Hazardous Organic Constituent Thermal Stability Index • Alphabetized (continued)
Principal Hazardous Organic Constituent Rank
TRICHLOROPROPANE (1,2,3-) [2] 168-1 73
TRICHLORO-(1.2.2)-TRIFLUOROETHANE (1.1,2) [2] [3] 81-84
TRINITROBENZENE {1.3.5-TRINITROBENZENE} 183-1 86
tns(l-AZRIDlNYL) PHOSPHINE SULFIDE 247-249
tns(2.3-DI8ROMOPROPYL)PHOSPHATE 242
TRYPAN BLUE 260
URACIL MUSTARD {5-[bis(2-CHLOROETHYL)AMINO]URACIL> 285
VINYL CHLORIDE (CHLOROETHENE) 60-64
FOOTNOTES:
1. UNITS OF TEMPERATURE ARE DEGREES CELSIUS.
2. BOLDFACE INDICATES COMPOUND THERMAL STABILITY IS "EXPERIMENTALLY EVALUATED"
(RANKING BASED ON UDRI EXPERIMENTAL DATA COUPLED WITH REACTION KINETIC THEORY).
3. NON-APPENDIX VIII COMPOUND.
4. N.O.S. LISTING; RANKING IS PRESENTED BASED ON EITHER UDRI OR LITERATURE EXPERIMENTAL
DATA COUPLED WITH REACTION KINETIC THEORY.
5. ITALICS INDICATE COMPOUND THERMAL STABILITY IS RANKED BASED ON LITERATURE
EXPERIMENTAL DATA COUPLED WITH REACTION KINETIC THEORY.
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OSUER 01r. No. 9938.6
APPENDIX G
CHECKLIST FOR INSPECTION OF A NEW RCRA INCINERATOR
G-l
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OSWER Dir. No. 9938.6
CHECKLIST FOR INSPECTION OF A NEW RCRA INCINERATOR
A. Verify installation of monitoring equipment as specified in permit/permit
application.
Type of Location
Parameter Instrument of Sensor Specifications
1. Temperature
a. Primary Chamber
b. Secondary Chamber
c.
d.
2. CO Emissions
3. 02 Emissions
4. Flue Gas Flow Rate
or Velocity or
Equivalent Method:
G-2
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OSWER Dir. No. 9938.6
Type of Location
Parameter Instrument of Sensor Specifications
5. Feed Rate of Each
Waste Stream to Each
Combustion Chamber
Chamber/Waste Stream
d.
e.
6. Pressure in Primary
Chamber
7. Air Pollution Control
a.
b.
c.
d.
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OSWER Oir. No. 9938.6
Type of Location
Parameter Instrument of Sensor Specifications
8. Inlet Gas Temperature
to Air Pollution
Control Devices
b.
c.
9. Additional Key
Parameters
a.
b. _
c.
d. _
e.
f. _._
9- _
G-4
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OSWER Dir. No. 9938.6
B. Verify construction of the Incinerator and support equipment in
accordance with the specifications in the permit application. Develop a
11st of specifications to be verified.
C. Shakedown Period Requirements
1. Verify no greater than 720 hr of testing with hazardous wastes, or
2. Verify testing with hazardous wastes did not exceed the limits
provided In the approved extension to the shakedown period.
3. Verify compliance with operating conditions during shakedown period.
0. Compliance Schedule Requirements
Adequate
Summary List of Compliance Schedule Items* Response?
* U.S. GOVERNMENT PRINTING OFFICE: 1989—617-003/04913
* Use additional pages if necessary.
G-5
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NOTES t
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NOTES;
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