In
  o
25401-42

              £ffr
              53C?~
                         BACKGROUND  DOCUMENT
                      STANDARDS APPLICABLE TO OWNERS AND OPERATORS
                  OF HAZARDOUS WASTE TREATMENT,  STORAGE, AMD DISPOSAL
                    FACILITIES UNDER RCRA, SUBTITLE. 9, SECTION 3004
                                Incineration Standards
                            (40 CFR 264 and 265.  Subpart 0)
 Repository Material
Permanent Collection
  06           This document (ms. 1941. 35) provides background information
  06               and support for EPA's hazardous waste regulations
                                       .lecticn
                                         UBRARY
                                        US EPA
                           Headquarters and Chemical Libraries
                               EPA West Bldg Room 3340
                                    Mailcode 3404T
       EJBD                     1301 Constitution AveNW
       ARCHIVE                   Washington DC 20004
       EPA                           202-566-0556
       530-
       R-
       80-
       039                U.S. ENVIRONMENTAL PROTECTION AGENCY
                                    December 1980

-------
                                 CONTENTS


  I.    INTRODUCTION  AND  BACKGROUND  ..........................    1

       A.    Content  of the  Background Document ...............    1

       B.    Mandate  for  the Regulation .......................    4

       C.    Key Definitions ..................................    5

 II.    NEED TO REGULATE  INCINERATION .........................   11

       A.    Potential Damaqe Cases  from Unregulated
            Incineration .....................................   11

       B.    Damaqe Incidents from Improper Incineration ......   15

       C.    Other Federal Regulations ...................... . .   16

            1.   Clean Air Act ...............................   16

            2.   Toxic Substances Control  Act ................   1q

       D.    State Regulations ................................   20

III.    SUMMARY OF PROPOSED REGULATIONS .......................   22

 IV.    INTERIM STATUS STANDARDS ..............................   25

       A.    Introduction .....................................   25

       B.    Basis for the  Interim Status Standards ...........   25

       C.    Response to  Comments on  Interim Status Standards
            Promulgated  on May 19,  1980, Including December
            18,  1978 Proposal and Rationale for Interim
            Final ISS ........................................   30

       D.    Comments/Response to Comments on  Interim Final
            ISS ......... .....................................   s4
       E.   Final ISS
  V.   CONCEPT OF BEST ENGINEERING JUDGEMENT  (REJ)  IN GFNF.RAL
       ( PERMITTING)  STANDARDS ................................  67

       A.   Conceptual Approach to the  Final  Standards
            Incorporating BEJ ................................  67

-------
VI.   RESPONSE TO COMMENTS/RATIONALE  FOR THE  FINAL  STANDARDS  75



      A.   General  Issues	  75



      B.   Exemption of  lanitable Waste	  80



      C.   Exemption for Trial  Burns	  83



      D.   Destruction and  Removal  Efficiencv (ORE)	  84



      E.   Emissions of  Haloqens and  Metals	  107



      F.   Particulate Emissions	  117



      G.   Operating Standards  and  Performance  Monitorinq...  124



      H.   Oneratinq Practices  - Preheating of  Incinerators.  142



      I.   Operating Practices  - Fugitive Emissions	  143



      J.   Operating Practices  - Automatic Shutoff	  14^



      K.   Trial Burns	  159



      L.   Waste Analysis	  187



      M.   Instrument Monitoring and  Facility Inspections...  192



      N.   Closure	  197



 References	  198



 Appendices	  205

-------
I.   INTRODUCTION AND BACKGROUND




     A.   Con-tent, of the Background Document.




    This is one of a series of documents providing suoport and




background information for regulations issued under Section  3004




of the Resource Conservation and Recovery Act of  1976.  ^ach




Background Document describes a regulation as originally proposed,




summarizes and responds to comments received that relate to  that




original proposal, and indicates the Agency's rationale for




final  regulations.




    On December 18, 1978, the Agency proposed standards for




incineration of hazardous wastes  (43 FR, at 5900R).   As a  result




of that proposal,  extensive  comments were received.   The Agency




issued a limited  set of  Interim  Status  standards  on May 19,




1980,  and  responded to comments  relevant to the Interium Status




Standards.  Those standards,  Part  265,  Subpart  O  Incineration,




were  issued as  interim final standards,  subject to  comment.   A




limited number  of comments were  received on  Subpart O; and are




addressed  in  Section  IV  of this  document.   The  final  text  of the




Interim Status  Standards is  also presented  in that  section.




      The Agency has  now  promulgated the General Standards  for




incinerators.   These  are the major technical  requirements  which




provide the basis for  issuing permits  under  Part 129.  of the May




19,  1980 regulations.   This  background document summarizes the




rationale  for these  standards,  including response to  the  comments




received on the proposed regulations.
                                -1-

-------
     As presented in this document, the Phase II regulations

represent a shift in the conceptual approach to regulation of

incineration.  This shift was brought about largely due to

broad objection by commenters to the proposed regulations.  The

proposed regulations were based on detailed design and operating

requirements, along with relatively inflexible performance

requirements.  The final regulations rely on a basic performance

standard, with facility-specific operating conditions set to

attain the performance standard.

     The basis for predicting compliance with the performance

standard will usually be trial burns.  These burns demonstrate

operating conditions associated with achievement of the performance

standard.  These then become part of the permit and are the

basis for continuous compliance monitoring.  The engineering

judgement of the permitting offical is applied to define acceptable

ranges in these operating conditions and in the composition of

the wastes to which they may be applied.  When sufficient alter-

native data are available to make these same determinations, the

permitting offical may waive the requirement for a trial burn.

     In accord with the above approach and in response to other

comments, the major changes in the final standards as compared

to the proposed standards (December 18,  1978) are as follows:

     0  The proposed destruction efficiency of 99.99% has been
        replaced with a Destruction and Removal Efficiency  (DRE)
        of 99.99% to define incinerator performance.  Emission3
        can be measured at the point of release to the atmosphere,
        rather than in the combustion zone.

     0  Criteria have been specified which the Regional Admin-
        istrator will use to designate Principal Organic Hazardous
        Constituents (POHC's) in the waste feed.  EPA is also
                               -2-

-------
        proposinq a set of criteria for determininq combustion
        by-products formed in the incinerator.

        The uniform combustion efficiency performance standard
        based on C02 and CO concentrations in the stack qas  has
        been dropped.  Instead,  CO limits are to be specified in
        the permit on a case-by-case basis and CO emissions  are
        to be monitored during routine operation.

     0   The scrubber efficiency requirement of 99% removal of
        haloqens has been limited to hydroqen chlorides.
        EPA is also proposinq a procedure for settinq emission
        limits for other haloqens on a case-by-case basis.

     0   Trial burn requirements have been modified to allow
        waiver of trial burns if sufficient data is provided
        to demonstrate that the destruction efficiencv require-
        ments can be met and to identify the operatinq conditions
        necessary to achieve that performance.

     0   Waste analysis requirements have been specified to
        provide necessary information for the Reqional Adminis-
        trator's desiqnation of the Principal Orqanic Hazardous
        Constituents, for his determination of DRE durina a trial
        burn, and to ensure incinerator compliance with permit
        conditions durinq normal operation.

     *   Incineration of wastes which are hazardous due only to
        iqnitabilitv and which contain no constituents listed
        in 40 CFR Part 261 Appendix VIII, mav be exempted from
        the incinerator requlations if approved bv the Reqional
        Administrator.

     0   Trial burns  in an incinerator are requlated bv $122.27(b)5
        provisions for approval of trial burn plans.

    The Aqency believes that  incineration of orqanic hazardous

waste is the primary near term alternative to land disposal.

Incineration can provide safe destruction of these orqanic

wastes.  Larqe volumes of liquid orqanic wastes not suitable for

land disposal can be reduced  to safe qaseous emissions and smaller

amounts of residues  (ash, scrubber sludqes, etc).  Incineration

can minimize or eliminate the lonq term impact on human health

and the environment of many hazardous wastes.
                               -3-

-------
B.  RCRA Mandate for the Regulation

    The Congress of the United States, in  Section 3004 of

Subx-itle C of the Resource Conservation and Recovery Act (RCRA)

of 1976  (PL 94-580), required that the Administrator of the U.S.

Environmental Protection Agency:

     "...promulgate regulations establishing such performance
     standards, applicable to owners and operators of facilities
     for the treatment, storage, or disposal of hazardous waste
     identified or listed under this Subtitle, as may be necessary
     to protect human health and the environment.  Such standards
     shall include, but need not be limited to, requirements
     respecting -...

     (3)  treatment, storage, or disposal of all such wastes
         received by the facility pursuant to such operating
         methods, techniques, and practices as may be
         satisfactory to the Administrator;

     (4)  the location, design, and construction of such
         hazardous waste treatment, disposal, or storage
         facilities;"
         (emphasis added).

    .The term "treatment" is defined in Section 1004(34) of

the  Act to mean:

     "...any method, technique, or process, including
     neutralization, designed to change the physical, chemical,
     or biological character or composition of any hazardous
     waste so as to neutralize such waste or so as to render
     such waste non-hazardous, safer for transport, amenable
     for storage, or reduced in volume..."

     One objective of incinerating hazardous waste is normally to

change the physical form or chemical composition of the waste

so as to render it non-hazardous.  Incineration may also render

the  waste "safer for transport, amenable for recovery, amenable

for  st-orage, or reduced in volume."  Therefore, incineration

is a treatment process within the meaninq of the Act, and the

Agency is mandated to produce operating, location, design, and
                               -4-

-------
construction regulations for the incineration of hazardous waste




adequate to protect human health and the environment.




C.  Key Definitions




    The definitions given in Part 260 of the Regulations promul-




gated on May 19, 19QO (45 FR at 33066) should aid the reader in




understanding this document.  Some of those definitions are pro-




vided here for the readers' convenience.  Changes from the de^ini-




tions proposed on December 18, 1978  (43 FR at 5R946) are discussed




if they are relevant to the incineration standards.




     1.    "Facility" means all contiguous land, and  structures,




          other appurtenances and improvements on the land, used




           for treating, storing, or  disposing of hazardous waste.




           A facility may consist of  several treatment, storaae, or




           disposal operational units  (e.g., one or more landfills,




           surface impoundments, or combinations of them).




     2.    "Fugitive Emissions" means  air contaminant emissions




           from non-point emission sources, or other  than those




           from  stacks,  ducts, or vents.




     3.    "Hazardous Waste" means hazardous waste as defined in




           §261.3 of the Regulations  promulgated on May 19,  19RO




           (45 FR at 33119).




     4.    "Hazardous Combustion By-Products" are hazardous




           constituents  formed in an  incinerator from incomplete




           combustion of principal organic hazardous  constituents.




           Hazardous combustion by-products or products o^




           incomplete combustion (PIC's) will be designated bv




           the Regional  Administrator  based on either:






                               -5-

-------
    (1)    the  conduct of a trial burn (or review of



          alternate  data) performed under S12 2. 27 or




          §122.25,  respectively.



     (2)   or based  on the waste analysis performed in




          accordance with 264.13 and $122.25 or $122.27.




5.    "Incinerator"  means an enclosed device using high



     temperatures to combust hazardous waste organic con-




     stituents and  where the products of combustion are




     emitted directly to the atmosphere with or without gas



     cleaning  devices.  "Examples of incinerators are; rotary




     kiln, fluidized bed, liquid injection, molten salt,



     microwave discharqe and infrared incinerators.




    This definition has been modified from the proposed



    definition.  Several commenters urged that enerqv reco-



    very units (boilers or other facilities where the waste




    is used as fuel) should be excluded from coverage under




    these regulations since they were alleged to be more



    efficient  and have higher destruction efficiencies than




    incinerators.  Coramenters also suggested that the proposed



    rules would inhibit use of wastes as a resource (fuel).



    These commenters suggested that the Agency should exemot




    incinerators and furnaces which utilize the heating



    value of wastes in order to promote resource recovery



    and help abate  the energy crisis.  An additional commen-




    ter urged  similar treatment for furnaces which recover



    materials  from  hazardous wastes, for example, -furnaces




    which thermally regenerate spent activated carbon.






                          -6-

-------
     The Agency has no evidence that boilers and other



thermal devices which recover heat (or products) from




hazardous wastes inherently have higher destruction




efficiencies than incinerators designed to destruct




hazardous wastes.



     However, as defined in $261.6 of the regulations



promulgated on May 19, 19BO (45 FR at 33120) hazardous




waste which is beneficially used or reused or legitimately




recycled or reclaimed is subject only to Subparts A,



 B, C, D, and E of Part 264.  Thus, incineration of




 those wastes is not regulated at this time.  It follows,



 then, that facilities burning these materials primarily



 to recover the energy value inherent in them, such as




 utility boilers and cement kilns, are not now considered




 hazardous waste facilities.  Thus, boilers and cenent



 kilns have been removed from the list of examples of




 incinerators.  However, the Agency is further evaluating




 the  "beneficial use" exemption of §261.6 including the



 need to regulate burning of hazardous waste in such




 facilities.  The Agency expects to promulgate regulations



 to deal with specific types of hazardous waste recovery



 in the future if these investigations indicate a need




 to regulate such processes.




      One commenter  suggested that the definition be




 expanded to include facilities, other than those using



 flame combustion, that thermally degrade hazardous




 wastes.  Examples suggested were molten salt incinerators






                      -7-

-------
and pyrolysis units.  Incinerator regulations which




involve controls of air flow rate, temperatures, and



so on, are designed specifically to  relate to flane




oxidation units.  Other types of thermal treatment



facilities, which operate on different principles, do



not always meet and may not need to  meet the conditions




specified for flame combustion  in order for them to be



effective and protective of human health and the environ-



ment.  Examples include those suggested by the commen-




ter, as well as wet air oxidation (Zimmerman or ''limpro




process) and microwave plasma destruction.  The Agency



is developing a separate set of regulations for these




non-flame processes under Subpart £  Thermal Treatment.



     Another commenter felt that listing of examples



of incinerators placed an unfair stigma on units of the




same type (i.e., fluidized bed, Tciln, etc) which do



not burn hazardous wastes.  While some uninformed




people might attach such a stigma, the Agency is unable




to see the significance of it.  These rules do not



cover any facility which does not burn hazardous wastes.




It has been EPA's experience that as far as the public



is concerned, it is the fact that the facility nanaaes




hazardous wastes, not the type of facility, which




elicits the serious public concern about such facilities.




The Agency believes that,  for the sake of clarity, it




is important to give examples of the types of equipment




which met the definition.
                     -8-

-------
          One  commenter  urged that experimental  incinerators




     should  not be  covered  by the  definition since,  during




     experiments,  it is  not possible to guarantee that all of




     the  criteria  (temperatures, retention time,  etc.) mandated




     in the  proposed regulations will be met.  This  comment is




     discussed in  Part VI of this  document.  These units




     are  included  in the definitions of incineration,  however,




     conducting trial burns in incinerators is subject only




     to the  more limited requirements of §122.27(b)




6.    "Particulate  matter" means any finely divided solid or




     liquid  material, other than uncombined water, as




     measured by method  5 in 40 CFR §60.1 - Appendix A. or




     an equivalent or alternative method.  This definition




     is the  same as that in 40 CFR §60.2(v).




7.    "Principal Organic  Hazardous Constituents (POHC's)" are




     the one or more organic constituents in a waste to be




     incinerated to which the Destruction and Removal Effi-




     ciency (DRE)  standard in §264.343(a) applies.  POHC's




     will be designated by the Regional Adminstrator:




     (1)   based on the results of the waste analysis performed




          under §264.341, and




     (2)   utilizing the criteria  in  $264.342(b) of this




          Section.




8.    "Treatment" means any method, technique, or process,




     including neutralization, designed to change the




     physical, chemical, or biological character or compo-




     sition of any hazardous waste so as to neutralize






                          -9-

-------
      such waste or so as to render such waste non-hazardous,




      safer for transport, amenable for recover,  amenable




      for storage,  or reduced in volume.




 9.    "Treatment facility" means a plan or part of a plant



      where treatment (as defined in RCRA) is conducted.




10.    "Trial burn"  means a temporary experimental burn of a



      hazardous waste in an incinerator permitted under



      §122.27(b) and for the purpose of evaluation o* the




      capability of an incinerator of that design to achieve



      a specified performance (destruction and removal



      efficiency) and to establish the operating conditions



      (temperature, air flow, etc.) necessary to achieve  that




      performance for purpose of the incinerator permit.
                           -10-

-------
II.   NEED TO REGULATE INCINERATION




 A.   Po1.ent.ial for Damage from Unregulated Incineration




      The Agency encourages incineration in properly designed and




 operated facilities as a management technique which is preferable




 to land disposal of hazardous wastes.  Incineration is capable




 of destroying most of the hazardous nature of organic wastes,




 while simultaneously reducing the volume of remaining wastes.




 Tests conducted by EPA and others demonstrate that incineration




 of a broad range of hazardous wastes can be conducted safely




 using existing technology if proper incinerator design and ooerat-




 ing parameters are employed.(5)   (See discussion of DRK and




 in Part VI of this document.)




      However, incineration of hazardous waste also noses a




 potential threat to human health  if not properly conducted and




 controlled.  This threat stems primarily from the notential




 emissions of hazardous substances into the air during incinera-




 tion.  This potential exists because the flow of air into the




 incinerator for combustion purposes can carry out with it part




 of the unburned waste fed into the incinerator.  Unless captured




 in an emission control device, the waste will be discharged into




 the air.  Similarly, if combustion is incomplete, hazardous




 combustion by-products, or recombinants, may be fomed in the




 combustion zone and subsequently  emitted from the stack.




      The potential for damage to human health and the environment




 from these emissions is related to several factors:  the mass




 emission of hazardous substances  from the stack, the dispersion




 of these emissions and extent of  exposure of humans or other





                                -  11 -

-------
organisms to them, and the health impacts of these substances




due to exposure.  Each of these factors is discussed below,




beginning with the latter.



1.   Health impacts




     The range of potential emissions  from incinerators is at




least as large as and probably larger  than the range of wastes,



and includes thousands of different  substances.  The full extent



to which these substances are hazardous to human health is not




always known in most cases, but sufficient evidence exists to show




that hundreds of the substances cause  damage to human health.



In the regulations promulgated on May  19,  19RO  (45 PR at 33132^.




EPA included a list  (Appendix VIII in  Part 2ft!) of over 4OD




substances know to be hazardous under  certain circumstances.



     Many of these substances are likely to be present in wastes




which are incinerated.   For example, sludges from oil and solvent



recovery operations often contain heavy metals including lead,



chromium, and cadmium  (28),  Improperly controlled incineration




of these sludges could result in significant air emissions of




these hazardous heavy metal constituents, or other toxic chemical



compounds formed from them (U.




     Similarly, improperly controlled  incineration can allow



quantities of cancer causing compounds to be released to the



atmosphere.  Included in Appendix VIII are approximately ISO




suspected of being carcinogenic.  These materials are con-




stituents of many wastes; e.g., toxaphene used to control oests



on ovestock; 1, 1, 1,  - trichloroethylene, known to be in the




heavy distillation waste bottoms from many chlorinated hvdrocarbon









                                - 12 -

-------
manufacturing plants; benzene, a widely used chernical found in



wastes from paintinq and coating operations.



     When these known carcinogens are incinerated, if combustion



conditions are not properly maintained in the incinerator, Quan-



tities of these compounds will be emitted from the stack and mav



affect the health of those humans exposed to them.



     Also, halogens and hydrogen halides (Cl2, HC1, etc.) are



formed in combustion processes when halogenated orqanic compounds



are burned.  These compounds when released to the atmosphere



adversely effect human health and the environment.  Incinerators



which are operated without adequate air pollution control eauip-



ment or with inefficient devices can emit danaerous quantities



of these halogens and their compounds.



2.   Exposure



     Hazardous waste is generated near population centers and



incinerators are typically located near the point of generation.



Hazardous waste incinerators are currently located near maior



population centers such as Philadelphia, Pa., Baton Rouqe, La.,



Galveston, Tx. and many others.  Depending on local terrain,



meteorological factors, and population distribution, the number



of persons exposed and the concentrations to which they are



exposed can vary widely for any qiven emission level.  various



air dispersion models have been developed to Predict this exposure



and those models have been used extensively in regulations



promulgated under the Clean Air Act.



3.   Hazardous Emissions



     Finally, there is a potential that incineration will be






                               -13-

-------
conducted improperly, yielding stack emissions of hazardous



substances.  In the past, hazardous wastes have been burned in



open pits, in drums and in makeshift burners. (29*  Burninq often



has taken place without emission controls and with combustion



conditions inadequate to ensure proper destruction.



Incomplete combustion can often result.  This can occur because



the waste  is particularly difficult to destroy, because the



incinerator is not properly desiqned to burn the waste in cmestion,



or because combustion conditions or emission controls are inadequate.



     Appendix I illustrates the incinerability of the wastes



listed as  hazardous  in Part 261 (45 PR 33119, Mav 19, 1980).



The types of incinerator appropriate to these wastes are also



indicated.  The information in Appendix I  is intended to be an



indicator of the appropriateness of incineration for certain



wastes.  Actual conditions will vary for other wastes and from



case to case depending on a variety of factors related to the



waste and  incineration system.  However, this information lends



support to the concern that burning of hazardous waste can be



done improperly if wastes which are difficult to combust are



burned, or if wastes are burned in improperly desiqne^ incine-



rators.



     Even properly designed incinerators have limitations reqardinq



the kinds and characteristics of the hazardous materials thev



can safely treat (see Appendix C).  Significant amounts of water



or other noncombustible components of the waste can affect



incineration temperatures, appropriate feed rates, the amount



of auxiliary fuel necessary, and the adequacy of control equipment.






                               -14-

-------
Failure to respect these limitations increases the probability

of environmental and hunan health damage from incinerator emissions

and residues.  Part VI of this document, discussing destruction

and removal efficiency, further amplifies this Doint .

B.   Incidents Involving Improper Incineration

     Incineration of hazardous wastes has been less widely

practiced than land disposal, and stack emissions and ambient

air have seldom been monitored for many of the hazardous

constituents present in hazardous wastes.  Even  so, several

damage incidents and near incidents have come to the Agency's

attention.  A few, summarized below, serve to illustrate  the

potential problems associated with improper  incineration:

    1.   In  early 1974,  following  reports of  air  and ground
         water pollution caused by the  incineration of hazardous
         wastes, the  Air Compliance Division  of the Connecticut
         Department of  Environmental  Protection closed two
         organic solvent recovery  operations.  One  of the
         operations,  in Southington,  Connecticut, was con-
         taminating the air  with heavy  metals from  the
         incineration of solvent recovery sludges which  con-
         tained  lead  and zinc.   Additionally,  the company's
         operations contaminated the  soil and ground water
         in  the  area  and the company's  own well.   Incineration
         ceased  in early 1974.   In  Beacon Falls,  Connecticut,
         a similar ooeration was closed for  reasons of  air
         pollution  (3°).

    2.   An  incinerator in  Graf ton, Ohio, has been  the  target
         of  numerous  citizen complaints of unpleasant odors
         and air pollution.   Odors, which normally  signifv
         organic emissions,  are  a  common problem  at incinerators
         due to  the volatility of  many  of the wastes.   Release
         of  odoriferous materials  usually occurs  as a result of
         careless handling  of the  waste,  fugitive emissions, or
         incomplete combustion.  The  area surrounding the
         facility is  reported to have become  contaminated
         with  unburned  Kepone on one  occasion (31)e
     3.   An on-site investigation by TCPA officials at a closed
         hazardous waste facility in Seymour,  Indiana, revealed
         that a makeshift incinerator had been used to destrov
                                - 15 -

-------
        hazardous wastes.  The unit, was little more than an
        open burning operation with an air blower to supplv
        extra air (31).

    4.  An incinerator in Chicago, Illinois, was shut down
        in August 1976, after numerous violations of. stack
        emission standards.  The City of Chicago was able
        to close the facility down when three violations
        of air standards (particulates, opacity, and odors)
        occurred within a IRO-day period.  The facility has
        since reopened, after extensive modification of its
        air pollution control equipment.  To date, the City
        has issued permits allowing only a limited number of
        wastes to be burned  (32).

    5.  In April 1977, the State of New York shut down a liquid
        waste incinerator run by Pollution Abatement Services
        at Oswego, New York.  The facility was a constant
        source of odor complaints from local residents. The
        State Division of Air Resources sampled the incinerator
        stack several times  and found, in one case, a particulate
        level of 10 times the allowable limit.  After the
        facility was closed  the State of New York was left
        with a one-million gallon lagoon, four 50,000-qallon
        tanks and 8,500 drums of waste materials (32)e

The above cases illustrate potential for emissions of substances

which could cause damage.

C.   Other Federal Regulations

     The Agency has considered the extent to which existing

Federal regulations address  the potential problems associated

with incineration of hazardous wastes, and the extent to which

such regulations could provide inputs to further regulation,

if needed, under RCRA.

     1.   Federal Regulation - Clean Air Act

     The existing Federal Regulations most directly related to

the issue of hazardous waste incineration are those promulgated

under the Clean Air Act (CAA).   As discussed in Part iv of this

document,  comments received on the proposed regulations

suggested that incinerators should be regulated only under the


                              - j.6 -

-------
Clean Air Act..



     Under the Clean Air Act, EPA has promulgated National




Ambient Air Quality standards for ubiquitous pollutants such as




sulfur dioxide, and for certain hazardous air pollutants such as




lead.  Emission standards called National Emission Standards




for Hazardous Air Pollutants (NESHAPs), have been promulgated




for certain hazardous pollutants from specific sources.  However,




these Clean Air Act Standards do not apply to hazardous waste




incinerators in most instances.  Finally, Standards of Performance




for New Stationary Sources  (NSPS) have been promulgated, but do




not include hazardous waste  incinerators.




     None  of  these standards deal with the hundreds of toxic




chemicals  entitles which could be emitted as a result of imoroper




incineration  of the wide variety of  chemical  species that  make uo




"hazardous wastes".  While  national  standards under the Clean  Air




Act may be developed  for some  of these substances  in the future,




comprehensive  national  emissions standards would require nanv




years of  development  at best,  and as such, the CAA is  not  a




practical  option  for control of hazardous waste incineration at




this time.



     Current  Clean Air  Act  regulations and their  relationship




to hazardous  waste incineration  are  summarized in  general  terns




below:



     National Ambient Air Qualify Standards.   The  criteria




pollutants identified in current CAA regulations  include:




sulfur dioxide, nitrogen dioxide, ozone, hydrocarbons,  lead, and




total suspended particulates.  There are national  ambient  air









                                - 17  -

-------
quality standards for each of these pollutants.  Each State is



required to have a State Implementation Plan  (RIP) desianed to



achieve these standards within a specified time period.



     To the extent that any of these pollutants are emitted hv



hazardous waste  incinerators, they will come  under State review



as a part of the SIP.  In developing the  incinerator regulations



under RCRA, the Aqency considered the controls on criteria pollu-



tants under the Clean Air Act.



     National Emission Standards for Hazardous Air Pollutants.



 To date, regulations under the CAA have  addressed six hazardous



air pollutants directly.  These are mercurv,  lead, bervllium,



vinyl chloride, asbestos, and benzene.  These standards aoplv



only to specific sources named in the regulations.  Waste incine-



rators are identified as sources in only  two  of the standards.



The beryllium standard is applicable to incinerators and the



mercury standard is  applicable onlv to incineration of waste



water treatment sludge.



     Standards of Performance-for New StationarySources.



Regulations have been developed for certain stationarv sources



(currently about 28) with respect to certain  oollutants.  For



example, standards for fossil fuel combustion sources nlace



stack emission limits on particulates, SOX and NOX.  Similarlv,



standards for sulfuric acid plants place  emission limits on



sulfuric acid mist.



     Two types of incinerators are covered in these standards



- municipal solid waste incinerators and  sewage sludge incinera-



tors.   In both cases the standards include limits on particulates






                               -18-

-------
only.  Hazardous waste incinerators are not covered by




these standards.  The Agency has however proposed and has included




in the final regulations for hazardous waste incineration, the




same particulate emission standard applicable to municipal inciner-




ators.  (See discussion in Part VI of this document.^




     Prevention of Significant Deterioration fPSD) and New Source




Review.  Procedures established under the CAA amendments of




1977 require that all new sources be subjected  to a review process




designed to prevent any further air quality degradation  (by




requiring offsets) in areas which are in non-attainment  status




for any of the  criteria pollutants, and to ensure no  significant




deterioration in other areas.   In carrying out  this review,  a




state may be able to require  application of best available control




technology economically achievable  (RATEA) for  any emitted pollu-




tant which is anywhere regulated  under  the Clean Air  Act.




This provides a potential vehicle for  states to more  broadlv




regulate emissions  from new hazardous waste  incinerators, but




it applies only to new sources  and  its  effectiveness  in  practice




is not yet "known.




2.   Federal Regulations  -  Toxic  Substances  Control  Act




     The only federal regulations currently  in  effect which




relate specifically  to hazardous  waste  incineration  are  embodied




in EPA's PCS disposal regulations.^34^   These regulations require




that certain PCS wastes be  incinerated.  Land disposal is not




allowed  for these materials.   The regulation also  includes




destruction and combustion  efficiency requirements;  specifica-




tions  for temperature, retention  time,  and excess  air; require-

-------
ments for inspecting (monitoring) operating conditions; and for

automatic feed cutoff in the event of  a malfunction.  The PCB

regulations also call for formal test  burn procedures and for

the use of scrubbers.  The requirements parallel the proposed

RCRA regulations to a considerable degree, and were helpful

during development of the proposed regulations, orimarily in

suggesting alternative regulatory approaches  and ensuring com-

prehensiveness of coverage.  To ensure consistency in the regula-

tion of all hazardous wastes,  the Agency  intends to integrate

in the near future the regulation of PCB's under the Toxic Sub-

stances Control Act with the regulation of all hazardous wastes

under RCRA.

D.   State Regulation of Incinerators

     Some states have found it necessary  to control hazardous

waste incineration. The work done by these states in developing

their regulations and their experience in implementation were

reviewed by the Agency during  development of  these final regula-

tions .

     In the absence of regulations specifically addressing

emissions from incinerators burning hazardous waste, sone states

have restricted the operations of hazardous waste incinerators

by the authority of a general  protection  or "nuisance" rule.

The following general nuisance rule of the Wisconsin Department

of Natural Resources is typical:

    NR 154. Control of Hazardous Pollutants.  General Limitations

    No person shall cause, suffer, allow, or  permit emissions into
    the ambient air of hazardous substances in such quantity, concen-
    tration, or duration as to be injurious to human health, plant,

-------
    or animal life unless the purpose of that emission is for the
    control of plant or animal life. .Hazardous substances include,
    but are not limited to, the following materials, their mixtures,
    or compounds:   asbestos,  beryllium, cadmium, chlorine, fluorine,
    lead, mercury, pesticides, or radioactive material (35^

    While this type of rule provides no specific regulatory

guidelines, the general authority of similar statutes has been

used to impose a variety of emission restrictions on a case-by-

case basis in some states.

     Several states have recognized the importance of developing

more complete regulations  for hazardous waste incineration and

are actively pursuing development of additional regulations.

     However, in general the current regulation of hazardous waste

incineration by states does not provide the kind of comprehensive

regulation necessary to protect human health and the environ-

ment that RCRPs. requires.

-------
III.   SUMMARY OF THE PROPOSED REGULATIONS




       Given the Congressional mandate to protect "human health and



  the environment and the need for regulation of incineration to




  accomplish that objective as described in  Part II, the Aqency



  proposed regulations for incineration of hazardous wastes on




  December 18, 1978  (43 FR at 59008).  These regulations were



  proposed under 250.45-1 as standards applicable to the permitting




  of hazardous waste incinerators.  No interim  status standards



  were proposed for  incineration.  The proposed regulations contained




  the provisions summarized below:




  Trial burns



       Trial burns were required  for  each hazardous waste which was




  significantly different from wastes burned previously under equi-




  valent conditions.  The trial burns were to include:



       °    Analysis of wastes for halogens  and principal hazar-




            dous components



       °    Analysis of ash residues  and scrubber effluent for



            principal hazardous components




       °    Analysis of the exhaust gas for  principal hazardous




            components, hydrogen halides, CO, C02, O?, and parti-



            culates



       °    Identification of sources of fugitive emissions and




            their control




       °    Measurement of combustion temperature and residence




            time



       0    Computation of combustion efficiency and destruction




            efficiency
                                  -22-

-------
     °    Computation of scrubber efficiency in removinq haloqens.

Monitoring

     Monitoring of the following parameters were required in both

the trial burn and each operational burn:

     °    Combustion temperature on a continuous basis

     0    CO and 02 in the exhaust gas on a continuous basis

     °    Rate of hazardous waste, fuel, and excess air fed to

          the combustion system at intervals not exceedinq 15

          minutes.

Combustion Criteria

0    The incinerator was required to operate at greater than

     1000° C combustion temperature, qreater than 2 seconds

     retention time, and qreater than 2 percent excess oxvqen

     for all hazardous wastes except haloaenated aromatic

     hydrocarbons.

°    For halogenated aromatic hydrocarbons the incinerator had

     to operate at greater than 1200° C combustion temperature,

     qreater than 2 seconds retention time, and qreater than 3

     percent excess oxyqen.

°    The incinerator had to operate at a combustion efficiency

     (CE) of at least 99.9 percent defined as follows:
                                 100
          where CC02 and Cco are concentrations measured in the
          exhaust gas

     The incinerator had to have a device to automaticallv cut off

     feed to the incinerator when siqnificant chanqes occurred in

     combustion temperature, excess air, or scrubber water pressure
                               -23-

-------
The incinerator had to achieve a destruction efficiency (DE)

of 99.99 percent as defined by the  following equation:


                                  x 100
                      win

     Where:  ^in = mass feed rate of principal toxic
                   components of waste goinq into the
                   incinerator

            wout = mass emissions rate of principal toxic
                   components in waste in the incinerator
                   combustion zone

Incinerators burning waste containing more than 0. 5 percent

halogens had to be equipped with emission control equipment

capable of removing 99 percent of the halogens from the

exhaust gases.

The incinerator had to meet a particulate emission standard

of 270 milligrams per dry standard cubic meter at zero

excess air (0.08 grains per dry standard cubic foot at

12 percent CO2).

The incinerator had to be designed and operated to control

fugitive emissions of unburned hazardous waste and combustion

products.
                          -24-

-------
IV.   Interim Status Standards




     A.    Introduction




          This section discusses the interim status standards




     promulgated on May 19,  1980 and the modifications to those




     standards which are now being made as a result of comments




     received and need to make the interim status and general




     standards consistent.




          Paragraphs B and C discuss the interim status standards




     as promulgated on May 19, 19RO.  These standards were




     promulgated on an interim final basis and thus were subject




     to comment.  Paragraph C discusses the comments received




     and the subsequent changes which are now made.  Included




     in paragraph C are the modifications which the Agencv




     is making to the ISS to make them consistent with the




     general standards now being promulgated.  Paragraph D




     contains the final language of the interim status standards.




     B.   Basis for the Interim Status Standards




          1.   Interim Status Standards (ISS)
               As summarized in Part III of this document, the




          Agency proposed a full  set of standards  for inciner-




          ation on December IB, 197R in response to the Congres-




          sional mandate in Subtitle C of RCRA.  The proposed




          regulations included general standards used in issuing




          permits but no interim  status standards.  Interim




          Status Standards (ISS)  are applicable during the period




          of time between submittal of an application for a




          permit and the granting of a permit.





                                -25-

-------
     The Agency subsequently determined that it is




important to bring some additional control over incine-




ration and other thermal treatment by promulgating




additional interim status standards.  Such standards




for incinerators were promulgated 45 FR 33250, Mav 19,




1980.  This section of this document discusses those



regulations which are to be in effect during the interim




status period.  General regulations for incineration,



those which apply to permitting, are discussed in



Parts V and VI.



     The interim status standards have been organized




to bring together all of the regulations  from the



December IB,  1978 proposal that will most directly



affect hazardous waste incineration facilities durinq




the period between the time they apply for a permit



under the General Standards and the time  the Agency




completes action on that application.  Thus, the insnec-




tion and the waste analysis reguirenents  specific to



incinerators, which were separately listed in the 197Q




proposal, have now been listed in the ISR for incine-




rators.



     One requirement, not included in the December  13,




1978 proposal, has been included in the interim status




regulations.  This is a requirement that  waste be



burned only at proper operating temperatures.  ^his



requirement is consistent with the IRS criteria, an<^




was brought to the Agency's attention by  a comnenter

-------
asking for an operational variance during start-up
periods.  This comnenter made the Agency aware of a
serious potential for environmental hazards.  Thus,
the requirement of pre-heating to proper onerating
conditions before burning hazardous wastes was added
to the interim status standards.
     A commenter suggested that the proposed standards
for trial burns and operational emissions monitorinq
be made applicable during the ISS period.  Since such
an application does not meet the ISS criteria (outlined
below), the Agency has not done this.
2.   Criteria for ISS
     In general, the Agency used the following criteria
to indicate which regulations should be adopted during
the ISS:   (l) could reasonably be implemented by the
regulated community within the six-month period between
promulgation and the effective date of the TSS regula-
tions on Movember 19, 19RO;  (2) does not require large
capital expense for items which reguire approval and,
thus, might be altered as part of the permittinq
process; and  (3) can be implemented directly by the
regulated community with the need for minimal consul-
tation with, or interpretation by, the Agency.  The
rationale for these decision criteria is discussed in
the preamble to the Part 264 and 265 regulations
promulgated on May 19, 1930 and in the BacXqround
Document entitled "General Issues Concerning Interim
                      -27-

-------
Status Standards."  It should be understood, however,




that the Agency used the criteria only as guidance in




deciding which standards to require during interim




status.  They are not hard-and-fast rules.



     For incineration facilities, the proposed technical




performance and design requirements do not meet the




decision criteria and, thus, cannot readily be inoie-



mented during interim status.  The time required for




conducting trial burns and upgrading most existing



facilities could be considerable, and the designs will




require Agency approval during the permittina process.




The Agency has, however, develooed threshold standards




for incineration which can be implemented during the




interim status period.  These have been designed orinariiv




to improve operating procedures, i.e., to eliminate




the careless and sloppy practices which have resulted




in serious problems in the past.  They do meet the




criteria for ISS.



     Specifically, requirement $265.343, that the




incinerator be brought to its steady state oneratina



condition before hazardous wastes are introduced meets



the criteria because:  (1) it requires no KPA. aoproval



or interpretation, (2) any capital expenditures necessarv




to install auxiliary fuel capability are not lilcelv to



be a topic of disagreement during permittina activities,



and (3) it can be implemented with little lead time




needed to obtain and install equipment.
                      -28-

-------
     The requirement of $265.345, that off-site hazar-




dous wastes be analyzed before the owner or operator




treats them, meets the criteria because:  (1) it can be




implemented with no EPA. involvement, since the samnlina




and analytical procedures are largely left to the




owner or operator;  (2) it can commence as soon as any




necessary testing equipment  is delivered; and  (3) it




requires only limited expense for the purpose of pro-




curing  testing equipment  (often  already  available^.




      The requirement of  $265.34"? for instrument moni-




toring  and  inspection of  control equipment and emissions




meets the criteria  because:   (1)  it can  be begun by




incinerator operators  immediately,  (21  it  requires no




interpretation by the  Agency, and (3)  it requires  no




capital expenditures,  since only existing,  in-place




equipment and  instruments must be inspected.




      Finally,  the requirement §265.351,  that hazardous




waste and hazardous residues (including sludges,  ash,




etc.) be removed from the incinerator at closure will




be incorporated  as  part of the  closure plan required




by Subpart G (Closure and Post  Closure)  to be prepared




 during interim status.   This will be  subject to ^aencv




 review and approval before it is implemented.  Imple-




 mentation of these requirements will  not be necessary




 until closure which may be years in the future but




 they may require significant capital  expenditures.




 These rules are being promulgated despite the interim
                       -29-

-------
     status criteria because of the importance the Acrencv

     places on proper closure.  For further discussion of

     the closure requirements during interim status see the

     backqround document entitled "Closure and Post-Closure

     Care."

C.   Interim Status Standards Promulgated on Mav 19, 1980,
     "including Response to Comments on December 18, 1Q7H
      Proposal and Rationale for Interim Final ISS.

     Many of the comments received went to technical points

or issues that are resolved in the General Status (Phase II)

Regulations.  These are discussed in section VI.  Other

comments raised issues relevant to any RCRA regulation

of hazardous waste incineration.  These are discussed imme-

diately below.  Finally, comments specifically relevant to

the Interim Status Standards are discussed after the aeneral

issues raised.

     General Issues

     1.   Summary of Comments

          a.  Incineration should be regulated only in
              three ways:  emissions should be controlled
              by the Clean Air Act, effluents bv the NPDES
              system, and land disposal bv Subtitle D of
              RCRA.  Legislative historv does not indicate
              that Section 3004 "disposal" was intended to
              include incineration.

          b.  Desiqn and operation regulations are  a
              mistake.  The owner or operator should
              be allowed to determine how to ooerate
              the process so as to meet performance
              standards.

     2.    Analysis of and Response to General Issue Comments

          a.   Hazardous Waste Incineration Falls Within

          the RCRA Statute
                               -30-

-------
     The commenters" discussion of whether

hazardous waste incineration falls within the

Section 1004(3) definition of "disnosal" is

irrelevant.  The Agency is regulating inciner-

ation as "treatment" of hazardous \vastes.

Section 1004(34) defines treatment:

     The term  "treatment," when used in
     connection with hazardous waste, means
     any method, technique, or process,
     including neutralization, designed to
     change the biological character or
     composition of any hazardous waste so
     as to neutralize waste and render it
     non-hazardous, safe for transport,
     amenable  for  recovery, amenable for
     storage,  or reduced in volume.  Such
     term  includes any activity or proces-
     sing designed to change the physical
     form or chemical composition of hazardous
     waste so  as to render it non-hazardous.

     As a process  designed to render hazardous

waste non-hazardous and reduced in volume,  incin-

eration falls  squarely within this definition.

The  Agency's statutory mandate to reaulate  such

treatment processes is thus  found in Section  3004,

which requires that the Administrator promulgate

standards  for  the  treatment  of hazardous wastes.

This mandate also  serves the objectives of

the  statute, defined by Congress in Section

1003(4) as, among  other things, "regulating

the  treatment.  .  .of hazardous wastes which

have adverse effects on health and the environ-

ment."  In addition, incineration of hazardous

                  -31-

-------
wastes was discussed extensively in EPA.' s

1974 Report to Congress:  Disposal of Hazardous

Wastes, a document that  strongly influenced

Congressional development of RCRA.  The Admin-

istrator's authority in  this matter is made

even more clear later in Section 3004, which

says that standards set  by  the Agency "shall

include, but need not be limited to, require-

ments respecting—

     (3) treatment. .  .of all such wastes. . .
         pursuant to such operating methods,
         techniques, and practices as may
         be satisfactory to the Administrator."

     Some commenters suggested that the nroposed

regulations should be replaced bv, or were in

conflict with, the Clean Axr  Act.  Congress,

in  Section 1006(b), required  the Administrator

to  integrate RCRA with the  Clean Air Act, but

"only to the extent that it can be done in a

manner consistent with the  goals and policies

expressed in this Act.  . ."  It is significant

that Congress, in Section 1006(a), omitted the

Clean Air Act fron a list of  statutes that were

specified as unaffected  by  RCRA's provisions.

As  a result, the Administrator has substantial

discretion to determine  the interplay between

RCRA and the Clean Air Act, so as to best effect

the purposes of both statutes.  Since incinera-


                  -32-

-------
tion of hazardous waste poses dangers that are



not adequately addressed in regulations promulgated




under the Clean Air Act, it is appropriate to




regulate such facilities under RCRA.  Also,



incinerator sites will be receiving manifested




hazardous wastes, temporarily storing hazardous




wastes, and (usually) generating hazardous




wastes in their ash and scrubber effluents.




Thus, some regulation under RCRA is essential in




any case.



     The Clean Air Act, as discussed above in



Part II, controls air contaminant  emissions  largely




on a pollutant-by-pollutant basis,  or  on  a pollu-




tant-facility basis.  Its regulations  include



area-wide  standards  for relatively ubiquitous



pollutants such as sulfur dioxide  and  lead,  and  for



certain hazardous air pollutants,  such as beryl-



lium and vinyl chloride  (examples  are:  parti-




culates  from  steam  fired  power  plants,  and



vinyl chloride emissions  from vinyl chloride




production plants).



     The toxic pollutants  which potentially  could



be emitted from  incineration  of hazardous wastes




number  at  least  in  the  hundreds.   RCRA has author-



ity to control emissions  through  performance



standards  and through  operating and design standards




These standards  can  be more effectively applied
               -33-

-------
to control the entire mix of pollutants treated




in each facility, than by attempting to develop a




national emission standard under the Clean Air




Act for each possible emission.  Thus, the Aaencv




has decided to regulate hazardous waste incinerators



and other thermal treatment devices directly




under RCRA.  Further discussion of the sufficiency



of Clean Air Act regulations is contained in Part TI




of this document.



     Affluent discharges to surface waters, however,



will require NPDKS permits.  These RCRA regulations




do not cover surface water discharges,  finally,



removal of ash or other residues generated by an




incinerator to landfills or other sites will have




to comply with RCRA hazardous waste regulations




for generators if the waste is hazardous.  The



RCRA/NPDES interface is clarified in the




Federal Register, November 17, 1980, 40 CFR,



Parts 122, 260,  264, 265 and 266.




     There are no provisions of regulations issued



by the Agency under the Clean Air Act or the



Clean Water Act which are incompatible with these



RCRA requirements.  It should be noted that the



interim status standards do not applv to the




incineration of PCB-containinq wastes.  These are



regulated under 40 CFR 761.40.  At a later time,




the Agency intends to integrate the PCR requirements






                -34-

-------
with these RCRA requirements, as discussed in




Part II of this document..




b.   Performance Standards are the Best Approach




     Commenters felt that desian and operating




standards are undesirable because they limit needed




flexibility on the part of the owner or operator.




They suggested that the owner or operator should




be allowed to determine how to operate so as to




meet performance standards.




     The Agency believes that performance




standards are desirable and, in fact, the




destruction and combustion efficiency require-




ments and the halogen removal requirements




which were proposed were types o* operational




performance standards.  The use of performance




standards tends to encourage innovative technol-




ogies and provides maximum cost-effectiveness




and flexibility to the owner and operator.




Specific design requirements, on the other hand,




may freeze technology.  The Agency does not




agree, however, that RCRA regulations should




depend solely and totally on performance standards.




     There are a number of "good management orac-




tices," which are currentlv routinely practiced




by the reputable and knowledgeable incinerator




operators, which the Agency believes should be




practiced by everyone, regardless of the waste and






                -35-

-------
     incinerator types  employed.  Some of these  "qood

     management practices"  have been included  in these

     interim status regulations.  These operating

     requirements are based on the belief that it is

     better to prevent injury to human health  through

     careful management than to take after-the-^act

     enforcement measures when poor management has led

     to an inevitable breach of a performance  standard.

     The issue of performance vs. operating standards

     is discussed further in Parts V and vi of this

     document.

Allowance of Variances During Startup Periods

1.   Synopsis of the Proposed Regulations

     The proposed regulations (Section 250.45-1(3))

required that incinerators operate at 1000CC with at

least a two-second residence time and at least two

percent excess air (except for halogenated aromatics

which required 1200°C for two seconds and at least

three percent excess air) whenever burning hazardous

wastes.  Similarly, a 99.9 percent combustion efficiency

and 99.99 percent destruction efficiency were required

whenever burning hazardous wastes.  These standards

are not requirements for the interim status period.

2.   Summary of Comments

     a.  Define a one-hour start-up period after
         wastes are introduced before destruction
         efficiency and combustion efficiency
         requirements are applied.
                     -36-

-------
     b.  Allowance should be made for excursions
         and operational variations durinq startuos
         and shutdowns.

3.   Analysis of and Response to Comments and Rationale

for the Interim Final Regulation

     The Agency cannot aqree with the reauest for a

variance durinq startup and shutdown times.  Such an

allowance would open the door to the possibility of an

incinerator beinq allowed to discharge siqnificant

quantities of hazardous wastes albeit over a short

time interval.

     Test burns and industry literature indicate that

it is qood manaqement practice, and entirely feasible,

to use auxiliary fuel to brinq the incinerator uo to

steady-state operatinq conditions before burninq hazar-

dous wastes.  When preheatinq to standard conditions

is coupled with careful control, danqerous temperature

and residence time deviations can be eliminated when

waste feed commences.(1'^).

     While there may be a  small  increase  in operatinq

costs caused by increased  reliance on auxiliary fuels,

that cost will be outweiqhed by  the human health

benefits of prooer incineration.  Such a  regulation,

as a side benefit, will prevent  unscrupulous owners

and operators from qaininq an economic advantaae

over reputable facilities.

     The Aqency agrees  that combustion condition

variations, with attendant deviations in destruction
                          -37-

-------
efficiencies and increased  emissions, are most likelv




to occur durinq startup periods.   If the practice



suggested by these  comments becomes widespread, signif-




icant health and environmental damages are likelv




to result.  Therefore, it is  reasonable and necessary




to require owners and operators of existing facilities




to achieve steady-state operating  conditions within




the  incinerators using auxiliary fuel before introducing



any  hazardous waste.  Reputable firms currently




practice this safeguard, regardless of the desian



capability of their incinerator.(36)




4.   Summary of the Interim Final  Regulations




     As a result of comments  received related to



combustion efficiency deviations during startun




periods, the Agency is requiring (Section 265.343)




all  incinerators during the interim status period




to achieve steady state temperature and air flow




conditions using auxiliary  fuel before addino any



hazardous waste.



Analysis of Wastes




1•   Synopsis of the Proposed Regulation




     In Section 250.43(g) of the proposed General



Facility Standards, the owner or operator of any




facility, including an incinerator, was required to



obtain a detailed analysis  of each hazardous waste



stream at least annually.    Also, owners and ooerators



were required (Section 250.43(h))  to sample each






                        -38-

-------
truckload of hazardous waste received and analyze it

for appearances, specific gravity, pH, and vanor

pressure.

     In the incineration section  (Section 250.4S-l(b)(1)

(i), (ii)/ and  (iii)), these requirements were proposed

to be extended  to trial burns by  requiring analysis

of:  (1) the waste for halogens and principal organic

hazardous components,  (2) ash and scrubber wastes for

principal hazardous components, and  (3)  exhaust gas

for halides, CO, CC>2,  09, and particulates.

2.   Comments Received

     Most of the general comments received on these

requirements are addressed  in the Background rtocument

entitled  "Waste Analysis."   ^he few  comments relating

specifically to incinerators can  be  summarized as follows

     a.   Required testing and analysis are unnecessary
          for certain  wastes, or are  too  expensive.

     b.   It is  not clear what is  to  be tested and
         what owners  and operators are to do with
         the information thus gathered.

     c.   Testing should not be required  except to:
          (a) identify waste as hazardous and  (b)
         provide necessary  information to the owner
         or operator  to allow him to  make decisions
          concerning safe management.

3.   Analysis and Response  to the Comments and Rationale

for the Interim Final Regulation

     The Agency based the proposed general requirements

for making a detailed chemical and physical analysis

of the wastes on the  belief that,  to  properly determine
                         -39-

-------
the adequacy of a facility  (incinerator, in this case>



to manage a given waste, the operator must know some-




thing about the waste  (compatibility, heating value,




primary pollutants, etc.)-  However, since the neces-



sary properties varied by facility type  (i.e., tanks,




incinerators, or landfills), the Agency did not specify




exactly what should be tested  for, except in the case




of incineration where analysis of haioqens and hazardous



components was mandated  for trial burns in order to




determine the efficiency of the incinerator for removing



the halogen and destroying  the principle hazardous



components.  A number of commenters on other sections




agreed with the second comnenter, i.e., that the stan-



dard did not adequately  spell out what is to be tested



and what is to be done with the information obtained.



The Agency agrees and has decided to require ail ^acilitv




owners and operators to  develop a waste analvsis plan



which will detail the characteristics of a waste which




he must know in order to adequately manaae the waste.



This plan is discussed in detail in the backaround



document entitled "Waste Analysis."  However, since




all owners and operators are not equally knowledgeable,



the Agency has decided to place minimum and more specific




analytical requirements within the facility regulation



sections.  This will guarantee that, as a nininum,



owners and operators will obtain at least rudimentary




information on a new hazardous waste which will enable
                        -40-

-------
them to evaluate the capability of their equipment and



techniques to manaqe it.



     The Aqency will not require trial burns for wastes



to be incinerated under ISS.  Trial burns are fully



useful only  in conjunction with the oermittinq process.



Nevertheless, reputable incinerator operators have



found it necessary to know certain waste charcteristics



prior to burninq wastes which thev have not previously



burned  (58,  59)t  Based on such industry experience,



the Aqency will require incinerator operators to  include



the followinq information on new wastes in their  waste



analysis plan durinq  interim status: heatinq value,



haloqens, sulfur, lead, and mercury.



     Heatinq value analysis is necessary to determine



adequate operatinq parameters, such as rate of auxiliary



fuel feed.   Hydroqen  chloride and  sulfur dioxide  are



commonly recoqnized air pollutants which result from



combustion of wastes  containinq chlorinated orqanic



compounds and sulfur  compounds.   In addition to their



effects on human  health,sulfur dioxide emissions  are



causative aqents  for  an increasinqlv  worrisome problem



- acid  rain. Also, hydroqen halides, Particularly HCL



and HP, can  cause sarious  corrosion problems in a



thermal treatment svstem.   This can  lead to  rapid



deterioration of  the  structural and operating  inteqritv



of the  thermal  treatment  system.
                           -41-

-------
     Lead is oxidized durinq combustion and is emitted



from uncontrolled incinerators as a particulate (^7)p



Lead has been found to produce an adverse effect on



public health.  The Criteria Document for lead which



served as a basis upon which the Administrator on



October 5, 1978 published a National Ambient Air Quality



Standard for lead summarizes the relationships between



airborne lead and its effects on man (38). Lead enters



the body principally throuqh inqestion and inhalation



with consequent absorption into the blood stream and



distribution to all body tissues.  Uncontrolled incine-



ration of waste containinq lead can be a siqnificant



lead emission source.  EPA set ambient air auality



standards for lead in 43 PR 46246.  They were affirmed



by the Court of Appeals for the D.C. Circuit.
Industries vs EPA, _ F.2d. _ ,  (June 21, 1980).



     Mercury compounds vaporize readily when heated and,



durinq combustion, may be emitted to the atmosphere.



Mercury has been found to cause or contribute to an



increase in mortality or an increase in serious irre-



versible, or incapacitatinq reversible illness.  On



March 31, 1971, the Administrator listed mercury as



one of three hazardous air pollutants for which he



intended to establish emission standards (39) %  The



publication entitled "Backqround Information on Develop-



ment of National Emission Standards for Hazardous Air



Pollutants; Asbestos, Beryllium and Mercury" describes






                          -42-

-------
the health criteria for these EPA standards for



mercury (4°).  Methyl mercury is considered to he



the most hazardous of mercury compounds.  The National



Emission Standard for Mercurv published under the



authority of Section 112 of the Clean Air Act on



October 14,  1975 is applicable to stationary sources



that incinerate wastewater treatment sludqe (4^).



     As more information is received, the Aqencv may



add to or modify minimum analysis requirements.  Also,



the qeneral  requlations discussed in Parts V and VI



contain additional waste analysis provisions.  During



interim status, (and nermanent status) facilities must,



of course, comply with relevant Clean Air Act limitations.



For example, 40 CFR 61.52 orescribes emission limits



for mercury  from incinerators of wastewater treatment



sludqes.  Also, 43 PR, 46246-46277 sets ambient air



standards for  lead which should not be exceeded as a



results of emissions from any stationarv source.



Most incinerator operators find it useful to obtain



additional information such as viscositv and solids



content, but the Aqency believes that certain tvoes



of facilities  would not need this information to ooerate



safely.  Therefore, viscosity and solids content analyses



are not required for all incinerators.  where they are



relevant  (e.g., liquid injection), they must be



included  in  the waste analysis plan.
                           -43-

-------
     ISS criteria will be  in effect  throughout the



interim status period.  The Aqency has decided that



the additional cost of these analyses will be warranted.



The dangers of not properly analyzing wastes prior to



incineration are too high  to be  tolerated throughout



the potentially lengthy ISS period prior to the issuance



of a permit.



     Thus, the Agency disagrees  with the first comment



that basic information which will allow an evaluation



of combustibility and pollutant  potential can be "too



expensive" or unnecessary.  The  Agency has dropoert the



requirement for annual reanalysis to reduce expense



for possibly unncessary analytical work.  Since the



requirement is for a one time  analysis, the cost,



using standard laboratory  analytical procedures, would



usually be less than S500  (41,42), Incinerator ooera-



tors can ask the generators to provide this information



or else analyze the waste  themselves and include the



cost in their charges to the generator (43,44),



4.   Summary of the Interim Final Regulation (S26S.345)



§265.341  Waste analysis



     In addition to the waste analyses required by



1265.13, the owner or operator must sufficiently analyze



any waste which he has not previously burned in his



incinerator to enable him to establish steady state



(normal) operating conditions  (including waste and



auxiliary fuel feed and air flow) and to determine the






                          -44-

-------
type of pollutants which miqht be emitted.  At a mini-

mum, the analysis must determine:

(a)  Heating value of the waste;

(b)  Haloqen content and sulfur content in the waste; and

(c)  Concentrations in the waste of lead and mercury,

     unless the owner or operator has written, docu-

     mented data that show that the element is not

     present.

[Comment;  As required by S265.73, the owner or opera-

tor must place the results from each waste analysis,

or the documented information,  in the operatinq

record of the facility.]

Instrument Monitoring and Facility Inspection

1.   Synopsis of the Proposed Regulation

     Durinq both trial and operatinq burns, the

followinq parameters  (§250.45-1(c)) were to be

monitored and recorded:

     a.  combustion temperature

     b.  exhaust qas CO  and  02  concentrations
         continuously, and


     c.  waste,  fuel, and excess air feed at
         least every  15  minutes.

     These requirements  were not oroposed for the

interim  status period.

2.   Summary  of  Comments

     a.  New  equipment  to monitor qas emissions
          (particularly CO) would be expensive.
                           -45-

-------
             b.  15-minute inspection of waste flows is
                 unnecessarily riqorous.

             c.  Points of measurement are unclear.

             d.  NOXf SOX, and CO2 should be added to the
                 list of monitored effluents.  One
                 commenter suggested they be included
                 during interim status.

        3.   Analysis of and Response to Comments and Rationale
               for the Interim Final Regulation

     The Agency believes it unwise to require soecific monitor-

ing equipment, such as the proposed continuous oxygen and carbon

monoxide instrumentation, during the interim status oeriod.

The first commenter is correct:  this equipment is expensive

and complex  (45)^  The design of these systems and sampling

requirements will be the subject of Agency review during the

permit process and, thus, it is unwise to require installation

before that  analysis can take place.  Also, lead time on ourchases

of instrumentation of this type can be lengthv.  Elapsed time

for  design  and installation would probably have exceeded

the available six months.  For similar reasons, the Agencv

does not believe that NOX, SOX, and C02 measurements

should be required during interim status, as was suggested

by one commenter.

     At this time, however, it appears that at least some of

the benefits of monitoring and inspecting can be realized

simply by requiring that combustion and emission control monitor-

ing equipment already in place be monitored on a reaular basis.

Also appropriate corrections should be made, if this will

ensure that  (within the design limitations of the existina

equipment) the combustion and emission control conditions will
                              -46-

-------
not be allowed to wander unmonitored and uncontrolled.  It



also seems reasonable and prudent to set uo routine insolation



schedules to observe visible emissions from the stack, as well



as leaks, spills, and inoperative alarm and control svstems.



As discussed in the Background Document for Inspections, routine



inspections can often detect a malfunction or onerator error



in advance of a possible human health or environmental incident.



     EPA disaqrees with the commenter who stated that a 15-



minute inspection frequency for waste flow is unnecessarily



rigorous.  The instruments  (or other devices) which measure the



combustion conditions (temperature, retention time, excess



air, and turbulence) should be monitored and corrections ma^e



as often as possible, continuously  and automaticallv  where



possible.  The relevant control points on which the combustion



conditions depend in most  incinerators  include waste  fee^ rate,



auxiliary fuel feed, and air flow.  Variations in  anv of  these,



or  in the heating value of  either the waste or the auxiliarv



fuel, can lead within minutes  to poor combustion conditions and



to  emission of  incompletely burned  wastes.  Some facilities



already  have  some of these  control  loops  (temperature via



auxiliary  fuel  flow, for example) operating on a continuous



basis  (36).   The Aqency encourages  such continuous control, but



will  insist that any such  controls  and, even more  importantlv,



any manual control  loops  (where  the operator makes the  correc-



tion) be monitored  or  inspected  at  least  everv 15  minutes.



      No  specific data base could  ever demonstrate  the wisdom  of



the precise  15-minute  frequency.   It  is based on the  Agencv's






                               -47-

-------
generalized engineering expertise and  the specific knowledge



of incinerator operations qained in the  1975 and 1976 test



burns.  In some cases, where combustion  conditions are subiect



to rapid variations arguments can be made that more frequent



monitoring and control is needed.  This  is, however, a facility-



specific situation and depends on design parameters, such as



the effectiveness of the instrumentation and the resnonse



period once control changes are made.  Also, the consequences



of incomplete combustion could be severe depending on the



type of hazardous waste being burned.  Thus, monitoring



frequency  is more appropriately treated  during the permittinq



process.   In develooinq the insoection schedule required in



§265.15, more frequent monitoring and  control activities should



be conducted where appropriate (see the  Inspection Backaronnd



Document for discussion of Inspection  Schedule development).



     The 15-minute schedule is a minimum.  The Aqencv does not



believe that control loops which affect  combustion conditions and,



thus, combustion efficiency should ever  be allowed to wander



out of control for longer than that period of time.  Even



where automatic control is installed,  it is necessarv to cheok



the instrumentation to ensure that it  is functioning.  The



15-minute minimum ensures that improoer  conditions do not



persist for longer than that period.   Because of the short



time interval between a malfunction and  possible emission of



hazardous materials, no incinerator of hazardous wastes should



operate unattended.
                              -48-

-------
     The Agency feels similarly about existing control loops



which might result in emissions or which could result in spills.



These could vary, depending on the design of the equinment,



but often include scrubber water flows, scrubber water PH



and, perhaps, level controls on tanks.  They must similarly



be inspected on a 15-minute basis.  All of these inspections



are to be part of the Inspection Schedule called for  in Section



265.15, and significant results are to be recorded in accordance



with the provisions of that section.



     In addition, stack emissions should be monitored hourly



and the entire facility inspected at  least daily for  leaks,



spills, fugitive emissions, odors, and smoke.  All of these



can result  in human health or  environmental  impacts  if  not



detected early.  Control  system alarms must  also be  insoected



daily  to be  sure they are functioning.   Again, no body  of  infor-



mation can  specifically support any given frequency.  Based



on  its own  experience, however, with  incinerator test burns,



the Agency  believes that  inspections  at  these  freauencies will



uncover problems  in time  to  prevent  serious  incidents.   Further,



the cost  impact  of conducting  these  inspections  is expected



to  be  small,  given the  fact  that  an  operator must be on duty



to  run an  incinerator anyway.   For  further discussion of  the



rationale  for routine  inspections,  the reader is  referred



to  the background  document on  inspections.



      4.   Summary of  the  Interim Final Regulations  ($265.347)



 §265.347   Monitoring  and  inspections



      The owner or operator must conduct, as  a minimum,  the
                               -49-

-------
following monitorinq and inspections when  incinerating hazardous



waste:



     (a)  Existinq  instruments which relate to combustion and



emission control must be monitored at  least every IS minutes.



Appropriate corrections to maintain steady state combustion



conditions must he  made immediately either automatically or bv



the operator.  Instruments which relate  to combustion and emission



control would normally include those measuring waste feed, auxi-



liary fuel feed, air flow, incinerator temperature, scrubber



flow, scrubber pH,  and relevant level  controls.



      (b)  The stack plume  (emissions)  must be observed visually



at least hourly for normal appearance  (color and ooacitv).  The



operator must immediately make any indicated corrections neces-



sary to return visible emissions to their  normal aopearance.



      (c)  The complete incinerator and associated eauipment



(pumps, valves, conveyors, pines, etc.)  must be insnecte^ at



least daily for leaks, soills, and fuqitive emissions, and all



emerqency shutdown  controls and system alarms must be checked



to assure proper operation.



Residue Management  and Closure Requirements



     1.  Synopsis of the Proposed Regulation



     In the proposed General Facility  Standards (S250.43(e))



regulations, the owner or operator of  any  facility (including



an incinerator) was required to consider anv residue generated



by the treatment (or storage) of a hazardous waste as a haz-



ardous waste.
                              -50-

-------
     2.  Summary of Comments

         1.  Requlations must specificallv address the disposi-
             tion of incinerator ash.

         2.  Regulations must protect human health and the
             environment from the leachate of hazardous waste
             ash which is temporarily stored.

         3.  The California State leachinq test should he used
             to determine the leachinq potential of ash from
             incineration of hazardous wastes.

     3.  Analysis and Response to Comments and Rationale for
           the Interim Final Regulatioli

     The Agency agrees with the first comment and in a comment

in the interim final regulations, has clarified the requirement

that waste from incineraton of a hazardous wastes is also haz-

ardous.  Section 261.3(c) should also address the concerns of

the second commenter since leachate discharged from the stored

ash resulting from incineration of a hazardous waste would

also be a hazardous waste unless either the leachate or the

ash had been tested and found not to be hazardous in accordance

with §260.22.  The Agency responded to these comments in this

way because of the difficulties in desiqnating toxic wastes.

These problems are outlined below.  For a fuller discussion,

see the background document entitled "Criteria for Listina/

Delisting."

     The Agency has determined that test procedures for identi-

fying if a waste is toxic by virtue of its being carcinogenic,

mutagenic, teratogenic, or bioaccumulative have not been suffi-

ciently developed for routine use bv waste generators in deter-

mining if their waste is subject to regulation.  Part 261 now

is limited to test procedures that focus on the concentration
                              -51-

-------
in the waste of those metals  and  pesticides  for which there



are National Primary Drinkinq Water  Standards.  These procedures



have been sufficiently developed  and will  he used hv waste



generators to determine  if  their  waste  is  a  toxic waste and



thus subject to regulation.   Despite the current Tack of suffi-



ciently developed test procedures the Aaencv has retained



comprehensive criteria for  listing other toxic wastes includina



those which are carcinogenic, mutaaenic, teratoaenic, and



bioaccumulative.  Thus,  many  wastes  are listed as hazardous



because data has shown that they  are carcinogenic or otherwise



toxic even though they do not meet the  characteristics in



Part 261.



     This anomaly (a waste  listed as hazardous for reasons



other than its meeting one  of the characteristic tests in



Part 261) leads to  some  potentiallv  troublesome loopholes.



For example, an owner or operator could suoerficiallv "treat"



a waste which is listed  because it is carcinogenic and claim



that the "treatment" has produced a  new waste.  And since



the new waste (residue from the "treatment") is not listed



and does not contain the heavy metals or pesticides which



would cause it to fail the  characteristic  for toxicity in



Part 261, it would  not be considered  hazardous and would he



unregulated.  It might, however,  be  just as carcinogenic as



the original waste.



     To close this  loophole, the  Agencv has added a requirement



(§261.3(c)) that "any solid waste that  is discharged, spilled,



or otherwise removed from a treatment, storage, or disposal






                              -S2-

-------
facility that contains any hazardous waste will continue to



be considered a hazardous waste..." unless it can be shown to



be nonhazardous in accordance with the delistinq procedures in



§260.22.  Thus, any residue (ash, scrubber water, scrubber



sludqe, precipitator dust, etc.) derivinq from incineration of



any hazardous waste, is a hazardous waste itself, unless it has



been delisted.  For a more complete analysis of these require-



ments, the reader is referred to the backqround document dealinq



with the definition of hazardous waste.



     The third comment suqqested reliance on the 30-dav



California leachinq test.  This test would be more severe



than EPA's Extraction Procedure promulqated under Part 261.



The Aqency's rationale for rejection of  the California test



is explained in the backqround document  entitled "Toxicity



Characteristic."  The Aqency  is unable to require that incinera-



tor ash residue from hazardous waste burns should be subiect



to a more severe test of hazard potential (the California test)



than other potentially hazardous wastes  which will he evaluated



using  EPA's Extraction Procedure.



     To be consistent with the format and requirements of the



other  facility specific requirements  (landfills, surface  impound-



ments,  etc.) and the closure  and post-closure requirements



(Subpart G), Section 265.351  has been reoriented to soecifv



what must be done with residues at  closure.  Section 265.114



of the general closure and post-closure  reauirements specifies



that equipment must be decontaminated and Section 265.113(a)



requires that  remaining hazardous  wastes must be removed.






                              -53-

-------
For incinerators, Section 265.351 amplifies  and  further defines

these requirements specifyinq that remaininq hazardous residues,

includinq ash, scrubber waters,  and  scrubber sludqes, must

be removed at closure.

     4.  Summary of  the Interim  Final  Regulation (S265.351)

§265.351  Closure

     At closure, the owner  or oeprator must  remove all hazardous

waste and hazardous  waste residues  (includina but not limited

to ash, scrubber waters, and scrubber  sludqes) from the incin-

erator.

 [Comment!  At closure, as throuqhout the  ooeratinq period,

unless the owner or  operator can demonstrate, in accordance

with §261.3(d) of  this Chapter,  that the  residue removed from

his incinerator  is not a hazardous waste,  the owner or operator

becomes a generator  of hazardous waste and must  manaqe it  in

accordance with  all  applicable requirements  of Parts 262 - ?66

of this Chapter.]

D.   Comments and  Response"to Comments on the Interim Final
       ISS

     1.  Operating Requirements

         a.  Summaryof the Interim  Final Regulation

             $265.343 - General  Operating Requirements requires

             that hazardous waste incinerators must he at  steadv

             state operatinq conditions before feedinq haz-

             ardous  wastes.

         b.  Comment on the Interim  Final  Regulation

             1.   Banninq the use of hiqh  BTU hazardous waste
                  to start-up incinerators is contrary to  sound
                  practice.  Wastes  which  contain onlv carbon,

                              -54-

-------
                  hydroqen and oxyqen should he allowed as
                  start-up fuel.  EPA has failed to recoqnize
                  deqree of hazard.

         c-   Response to Comments on the Interim Final S265.343
              and §265.34 0      ~~


     The Agency believes that use of clean auxiliary fuel such

as fuel  oil  or natural qas to start-up incinerators is a nrudent

and conservative requirement.  The Aqencv realizes that there

may be some  wastes which are hazardous due onlv to their flam-

mability and miqht well be suitable for start-up.

     Thus,  the Aqency has decided to add an exemption to S265.340

of the interim status standards to exclude wastes which are

hazardous due only to their iqnitability from the oreheatinq

requirement  in §265.343 (See Section VI of this document for a

complete discussion of this exemption).

     However, the Aqencv disaqrees with the comment that wastes

which have only hydroqen, oxyqen, and carbon in their structure

should be exempted from the preheatinq requirement.  An example

of such  a waste material is benzene which contains onlv hvdroqen

and carbon but which is hazardous due to its carcinoqenic

properties.   Thus, a waste containinq benzene would be a threat

to human health and the environment if it were not completelv

combusted in an incinerator.

     The Aqencv has modified the requirement for start-up so

that it  also includes shut-down.  The same health concerns

apply in either case.

         d.   Final•Interim-Status Standard

§265.340   Applicability

     (a)  The requlations  in this Subpart applv to owners or
                              -55-

-------
operators of facilities that treat hazardous  waste  in  incinerators



except as §265.1 and paraqranh  (b) of  this  Section  provide



otherwise.



      (b)  Incineration of wastes  which:



      (1)  Meet only the  iqnitabilitv characteristic under



          Part 261, Subpart C,  of this Chapter, or



     (ii)  Are listed in Part 261, Subpart D of this Chanter



          for iqnitability only (Hazard Code  I)),



may  be exempted  from the requirements  of this Suboart, excent



§265.351, if the owner or operator can document that the waste



feed would  not reasonably be exoected  to contain constituents



listed  in Part 261, Appendix VIII of this Chapter.  Such Docu-



mentation must be  in writinq and  must  be keot at the facilitv.



      Durinq start-up and shut-down of  an incinerator,  the owner



or operator must not feed hazardous waste unless the incinerator



is at steady state (normal) conditions of operation, includinq



steady state oepratinq temperature and air  flow.



§265.346   [Reserved]



      2.  Wa s t e Ana1 y s i s



         a.  Summary of the Interim Final Regulation ($265.345)



      As part of  the waste analysis plan  required bv 5265.13,



the  owner/operator must obtain  a  sample of  each new waste to



be incinerated and analyze it sufficiently  to establish normal



combustion  conditions and the potential  for emissions.  At the



minimum, this analysis must include heatinq value,  haloaen and



sulfur content,  and the concentrations of lead and  mercurv.
                              -56-

-------
         b.   Comments on the Interim Status Standards

             0    Waste analysis requirements place a heavy
                  burden on manufacturers whose total waste
                  stream will constantly varv.  The requirement
                  to constantly sample will be unmanageable.
                  Suqqest the requirement specify that analysis
                  is required onlv if needed to establish
                  steady state conditions.

             °    Heating value testing for on-site incinerators
                  which handle only a few wastes should not be
                  required.

             0    Amend 265.345(b) to read "organic halogen
                  content."  Inorganic haloaens are not
                  applicable to the emissions from hazardous
                  waste incineration.

             0    Add  "...unless the owner or operator has
                  written documented data that show that the
                  element is not present at a level which will
                  require post  incineration treatment to meet the
                  CAA  standardT"

         c.   Response  to Comments on the Interum Status
               Standards

     The comment on excessive testing when wastes are constantly

varyinq is addressed in §265.13(b)  (4).  That standard allows

the owner or operator  to develop a  samplinq plan which specifies

the frequency with which the analysis must be repeated alonn

with the other parts of 265.13(b) which allow the owner or

operator to determine  the parameters to be tested, test methods

and samplinq methods.  Thus, the Agency feels that owners or

operators should be able to develoo a testina program which is

both reasonable and still  provide  information for the safe

operation of  incinerators.

     The above argument also applies to on-site  incinerators

which will only receive a  few  relatively  uniform wastes.  To

completely exempt these  incinerators as suggested by  a commenter,
                               -57-

-------
from testing requirements such as heatinq  value  could allow



highly variable wastes to be fed to the  incinerator without



the owner or operator's knowledge.  The  resulting upsets would



cause unacceptable emissions from the  incinerator.



     The Agency feels that  the comments  regarding organic halo-



gens and reference to the Clean Air Act  are  relevant.  Further,



in developing  the general regulations  for  incineration the



Agency re-evaluated the type of performance  standards anoro-



priate to incinerators and  the waste analysis  required to support



those standards.  As discussed in Part VI, those waste analvsis



requirements do not single  out sulfur, lead, mercury, and haloqens



for analysis.  Further, the Agency considered  the extent to



which the analysis for these substances  would  be used durinq the



interim status period.  The primary use  apoeared to be to gather



information for possible regulations under the Clean Air Act.



The Agency feels that such  analysis can  be required as a



part of Clean  Air Act permit issuance  if it  is needed.



     In view of the above factors the  Agency has dropped the



specific requirements for analysis of  sulfur,  haloqens, mercury,



and lead from  the interim status requlation.   An analysis for all



potential toxic components  is included in  the  general standards



where it will  he used as a  basis for application of snecific



performance standards.



     The Agency is requiring an analysis of  maior hazardous



constituents.  This would include toxic  orqanic constituents,



including organic halogens  and any constituents for which the



waste is listed in Apoendix VII of Part  261.   An analysis for
                              -58-

-------
metals is relatively simple and inexpensive.  However, an
analysis for organics can he more complex.  The analysis is
required on a "one time" basis for each major waste or typical
waste mixture burned in the incinerator.  The basis for the
analyses is Appendix VII and as such very few orqanics are
beinq sought in wastes.  Sophisticated  cfc/ms analvsis for
organics are not generally required and more common gas
chromatoqraphy techniaues would normally be required.  This
is particularly true when a "historv" of waste constituent
have been developed for the wastes which the owner/operator
commonly handles.  These analyses are also  inexpensive.
     The Agency is requestinq this analvsis for two major
reasons.  First, the Agency feels that  in order to establish
conditions for proper and effective incineration, it  is impera-
tive that the owner or operator know the major hazardous consti-
tuents of a waste.  Also, such information  would be essential to
respond to citizen complaints and to assess the possible cause
of any damage to human health that mav  appear to be caused bv
the incinerator.  Secondly, the Agency  can  use such information
to establish priorities for issuing permits.  The information
obtained from the waste analysis will be necessary for the
permitting process anyway, so requirina the analysis  durina
interim status only moves up the timing of  getting the informa-
tion.  The ultimate burden on the owner or  operator is not
greatly increased.
         d.  Final Language-of the-Interim  Status Standard
§265.341  Waste analvsis
     In addition to the waste analyses  required bv S26S.13,

-------
the owner or operator must sufficiently analyze a waste which

he has not previously burned in his  incinerator to enable him

to establish operating conditions which will  effectively

destroy the waste and to determine the type of pollutants

which might be emitted.  At a minimum, the analysis must

determine:

     a)  the heating value of the waste,

     b)  the presence of haloqenated organics

     c)  the presence of any other hazardous  organic

         constituents for which the waste is  listed in

         Part 261, Appendix VII.

      [Comment;  As required by §265.73, the owner or operator
                must place the results from each waste analvsis,
                or the documented information, in the ooeratinq
                record of the facility.]

            3.  Monitoring and Inspection

         a.  Summary of the Interim Final Regulation

§265.347  The owner or operator must inspect  (monitor):

             1.  existing combustion and emission control
                 instruments and make appropriate corrections,
                 to maintain steady-state combustion conditions
                 at least every 15-minutes,

             2.  stack plume for normal appearance (onacitv
                 and color) at least hourly,  and

             3.  the entire unit, daily, for  leaks, spills,
                 fugitive emissions, odors, and smoke.

         b.  Comments on the Interim Final Regulation

             1.   Object to specifying minimum time Periods.
                  Revise the regulation to allow owners or
                  operators to establish monitoring and
                  inspection based on best management
                  practices, rather than previously defined
                  requ irements.
                              -60-

-------
             2.    Assure that 15-minute monitorinq allows
                  continuous instrument monitorinq.

         c.   Response to the Comments on Interim Final Regulation

     The Aqency disaqrees with the first comment.  No specific

data base can demonstrate the wisdom of the 15-minute frequency.

However, it is based on the Aqency's qeneralized enaineerinq

expertise and the specific knowledqe of incinerator operations

gained in test burns conducted in 1975 and 1976.  In manv

cases more frequent  inspections may be required  to detect and

make appropriate corrections.  The inspection  interval for anv

parameter should really be based on knowledqe  of the soecific

incinerator system and how rapidly chanqes can occur.  However,

in  interim status, when there will be  little contact between

the Aqency and the facility,  it  is necessarv to  have a clearlv

defined  time  period  which  sets a  threshold of  compliance.

     The regulation  allows  continuous  monitorinq as  suaqest^d

in  the  second comment.

     In view  of  these  factors, the Aqency decided  that chanqes

to  the  interim final regulation  was  not  required.

         d.   Final  Language of the  Interim Status Standard

§265.347   Monitorinq and  inspections

     The owner or operator must  conduct,  as  a  minimum, the

following  monitorinq and  inspections when incinerating hazardous
 waste:
      (1)  Existing instruments which relate to combustion and
          emission control must be monitored at least every 15
          minutes.  Appropriate corrections to maintain steady
          state combustion conditions must be made immediately
          either automatically or by the operator.  Instruments
          which relate to combustion and emission control would
                               -61-

-------
         normally include those measuring waste feed, auxiliarv
         fuel feed, air flow, incinerator temperature, scrubber
         flow, scrubber pH, and relevant level controls.

     (2) The stack plume  (emissions) must be observed visuallv at
         least hourly for normal appearance  (color and opacity).
         The operator must  immediately make anv indicated oner-
         ating corrections  necessary to return visible emissions
         to their normal appearance.

     (3) The complete incinerator and associated equipment
         (pumps, valves, conveyors, oipes, etc.) must be insnected
         at least daily for leaks, spills, and fugitive emissions,
         and all emergency  shutdown controls and svstem alarms
         must be checked  to assure proper operation.

     4.  Closure

         a.  Summary of the Interim Final Regulation 5265.3S1

     At closure all hazardous waste and their residues (ash,

scrubber water, scrubber  sludge, etc.) must be removed from

the incinerator.

         b.  Comments on  the Interim Final Regulation

             The Agency did not receive any comments on this

              section.

         c.  Response to Comments on the Interim Final
               Regulation

             None.

         d.  Final Language of the Interim Status Standard

[§§265.348 - 265.350 Reserved]

§265.351  Closure  [Interim  Final]

     At closure, the owner  or operator must remove all hazardous

waste and hazardous waste residues (including but not limited to

ash, scrubber waters, and scrubber sludges) from the incinerator.

     [Comment:  At closure, as throughout the operating period,
     unless the owner or operator can demonstrate, in accordance
     with §261.3(c) or (d) of this Chapter, that the residue
     removed from his incinerator is not a hazardous waste,
                              -62-

-------
     the owner or operator becomes a generator of hazardous
     waste and must manage it in accordance with all applicable
     requirements of Parts 262, 263, and 265 of this Chapter.1

     5.   Other Comments

     The Aqency received a limited number of comments durinq

the May 19, 1980 to July 19 comment period which addressed

issues not related to the specific requirements of the Suboart

- O interim status standards.  Since the interim final comment

period was only open to receive comment on the ISS standards

the Aqency has not responded to these comments here.  The

issues raised had been raised in comments on the December 18,

1978 proposed regulations and thus are adequately addressed in

Part VI.

E.   Text of Final Interim Status Standards

                    Suboart 0 - Incinerators

§265.340  Applicability

     (a)  The requlations in this Suboart apolv to owners or

operators of facilities that treat hazardous waste in incine-

rators, except as $265.1 and paraqraph  (b) of this Section

provide otherwise.

     (b) Incineration of wastes which:

         (1) Meet only the ianitabilitv characteristic under

             Part 261, Subpart C, of this Chapter, or

         (2) Are listed in Part 261, Subpart D, of this Chanter

             for iqnitability onlv  (Hazard Code I)),
                              -63-

-------
are exempted from the requirements of this Subpart, except

§265.351, if the owner or operator can document that the waste

feed would not reasonably be expected to contain constituents

listed in Part 261, Appendix VIII of this Chanter.  Such

documentation must be in writinq and must be kept at the

facility.

§265.341  Waste analysis

     In addition to the waste  analyses required bv 5265.13,

the owner or operator must sufficiently analyze a waste which

he has not previously burned in his incinerator to enable him

to establish operating conditions which will effectively destrov

the waste and to determine the type of pollutants which miaht

be emitted.  At a minimum, the analysis must determine:

     a)  the heatinq value of  the waste,

     b)  the presence of haloqenated oraanics

     c)  the presence of any other hazardous orqanic

         constituents for which the waste is listed in

         Part 261, Appendix VII.

     [Comment;  As required by §265.73, the owner or operator
                must place the results from each waste analysis,
                or the documented information, in the noeratinq
                record of the  facility.!

§§265.342 - 2654.344 [Reserved]
                              -64-

-------
§265.345  General operating requirements

     During start-up and shut-down of an incinerator, the owner

or operator must not feed hazardous waste unless the incinerator

is at steady state (normal) conditions of oneration, includina

steady state operating temperature and air flow.

§265.346   [Reserved]

§265.347  Monitoring and inspections  [Interim Final]

     The owner or operator must conduct, as a minimum, the

following monitoring and inspections  when incinerating hazardous

waste:

     (1)  Existing instruments which  relate to  combustion and
          emission control must be monitored at least everv
          15 minutes.  Appropriate corrections  to maintain
          steady state combustion conditions must be made
          immediately either automatically or by the operator.
          Instruments which relate to combustion and emission
          control would normally  include those  measurina
          waste feed, auxiliary fuel  feed, air  flow, incin-
          erator temperature, scrubber flow, scrubber oH,
          and relevant level controls.

      (2)  The stack olume  (emissions) must be observed visuallv
          at least hourly  for normal  aooearanee (color and
          opacity).  The operator must immediately  make anv
          indicated ooeratinq corrections necessarv to return
          visible emissions to their  normal appearance.
      (3)  The complete incinerator and associated equinment
           (pumps, valves,  conveyors,  pipes, etc.) must be
           inspected at least daily for leaks, snills, and
           fugitive emissions, and all emergency shut-down
          controls and system alarms  must be checked to
          assure proper operation.

 [§§265.348 - 265.350  Reserved]

 §265.351  Closure

     At closure, the owner or operator must remove  all hazardous

 waste and hazardous waste  residues  (includinq but not limited

 to ash, scrubber water, and scrubber  sludqes) from  the incinerator.
                               -65-

-------
     [Comment:   At  closure,  as  throuqhout the operatinq  period,
                unless  the owner  or  ooerator can demonstrate,
                in  accordance with §261.3(c) or (d)  of this
                Chapter,  that the residue removed from his
                incinerator  is  not a hazardous waste,  the
                owner or  operator becomes a qenerator  of hazard-
                ous waste and must manaqe it in accordance with
                all aoplicable  requirements of parts 2fi2,  263,
                and 265 of this Chapter.]

[§§265.352-265.369   Reserved]
                             -66-

-------
V.   CONCEPT OF BEST ENGINEERING  JUDGEMENT IN FINAL REGULATIONS

     A.   Conceptual Approach  -to  -the Final Standards Incorporating
           BEJ

     A number of the comments  on  the proposed regulations followed

a common theme, which resulted in a change in the basic approach

to the regulation of incineration.  Commenters opposed two basic

facets of the proposed  regulations as being too inflexible: 1^

universally applicable,  specific  design and operating requirements,

and 2) performance  requirements that did not allow variances.

As described in Part  III of this  document, the proposed regulations

included specific operating requirements for temperature, dwell

time  (burn time in  the  combustion chamber), and quantity of

excess air, as well as  performance requirements for combustion

and destruction efficiency and removal of halogens.  Addressing

one or more of these requirements, commenters consistent!v

argued that these  standards - particularly those  dealing with

operating  requirements - did not  provide  sufficient flexibility

to account for the many differences  in wastes and incinerator

designs.   The  performance standards  were  criticized as  not reflec-

ting  any difference in the character of v/aste being burned or

the design of the incinerator.

      The Agency concluded that these comments had merit.   The

differences in wastes and incinerator designs argue that operating

 requirements can be more effectively established on a  case-by-

 case basis than in a national regulation.   The  final  regulations

 no longer include  nationally  applicable design and operating

 standards, but rely instead on a performance standard.   The


                                  -67-

-------
performance standard will serve as a basis for setting operational



requirements on a case-by-case basis.




     Some flexibility to tailor operating or performance standards




on a case-by-case basis can better ensure protection of human




health and at the same time avoid overly protective requirements.




The determination of how to regulate that flexibility and nanaqe




its implementation through the permit program requires additional




analysis.  EPA is today proposing a procedure for allowing the




performance standard to be flexible by allowing for variances



in a proposed addition to the performance standard.  Applica-




tion of that variance, as well as design and operating require-




ments as proposed, will be determined on a case-by-case basis.



Thus, EPA anticipates establishing final standards which will




provide flexibility for case-by-case tailoring of regulatorv




requirements to the specific wastes and incinerator in question,



based on the best engineering judgement of the permittina official.




     Best engineering judgment, as used in the context of the




incineration standards, is little more than an acknowledge-




ment that case-by-case judgements, based on site-specific circum-



stances need to be applied in establishing the permitting require-



ments applicable to an incinerator.  This judgement is exercised




within the constraints of criteria described and factors specified



in the regulation.  In making such judgements the permitting




official should have as input comprehensive, up-to-date informa-




tion on incineration technology and the thermal destruction



characteristics of wastes,  as well as any process or site specific




information which he may require from the permit applicant.
                                -68-

-------
Along with the regulations guidance  manuals  are being  provided




for this purpose.  These include:   "Permit Writer Guidelines  for




Hazardous Waste Incineration"  and  "Engineering Handbook  for




Hazardous Waste Incineration".   Guidance  will be updated regularIv.
                                -69-

-------
B.   Application of Best. Engineering Judgement, in the Final
       Regulation

     The opportunity for a permitting official to exercise best

engineering judgement within the context of the incineration

regulations occurs primarily in five basic areas, each of which

is described more fully in Part VI of this document:

     (l)  Designation of the principal organic hazardous compo-

          nents in the waste stream(s), to which the 99,99% DR13:

          performance standard applies.  This determination will

          be based on data from waste analysis and trial burns,

          utilizing criteria established in the regulation.

     (2)  Designation of operating conditions in the permit,

          including CO level in the exhaust waste feed rate,

          combustion temperature, and air feed rate to the conbus-

          tion system, as well as acceptable variations in the

          composition of the waste feed.  The primary aspect of

          judgement is the determination of acceptable ranges

          for these parameters, since the basic operating condi-

          tions are determined in the trial burn based on the

          achievement of the performance standard.  Perhans the

          major area of judgement is the range of wastes that

          can be burned within a given set of permit conditions.

     (3)  Determination of whether to grant a waiver from the

          requirement for a trial burn.  This judgement is based

          on whether the data provided by the owner or operator

          in lieu of a trial burn is sufficient to determine

          compliance with the basic performance standard and to
                               -70-

-------
          establish operating conditions associated with meeting




          that standard.  This judgement is closely related to the




          judgement of the range of wastes that can be burned at



          a given set of permit conditions.




               The proposed additions to the final performance




          standards will require the additional application o^




          Best Engineering Judgement (see the background Docu-




          ment for the proposed additions to Rubpart O speci^i-



          cally 264.343 (d-g)).




     The timing and procedures for making each of these deter-




minations is described below in the sequence in which they occur




in the process of permit application and issuance.




Step 1 - Trial Burn Plan/Trial Burn Waiver




     Before a new permit can be issued or a permit modification




made for burning a waste either a trial burn must be conducted or




data in lieu of a trial burn must be submitted to the Regional




Administrator as a portion of Part R of the facility's permit



application by the owner or operator.  Thus, the owner or opera-




tor will submit either:




     1)   a trial burn plan, or




     2)   data in lieu of a trial burn plan that would provide



          substitute information to that normally obtained in




          the trial burn.




     In the case of unpermitted facilities, this infornaiton would




be submitted along with Part R of the permit application also.



For facilities already permitted the trial burn plan or data would




be submitted for approval, along with a request for a permit
                               -71-

-------
modification to be based on the trial burn  (or alternate data




submitted).  A trial burn permit in accordance with $122.27(b)




is required to conduct the trial burn.



     Either of these actions requires the engineerinq judaement




of the permit writer.  In making a judgement of the POHC's in



the waste, the permitting official will use as a data base the



detailed waste analysis submitted with either the trial burn




plan or the request for a waiver and will base a judgement on




the following criteria:



      (1)   For a listed hazardous waste in Part 261 one or more



           organic constituents specified in Part 261, ^npendix ^rr




           for which the waste is listed will be designated as a




           POHC.



      (2)   Others will be designated based on:




           (i)    The degree of difficulty of incinerating the



                 component.  Organic waste  constituents which




                 represent the greatest degree of difficulty of



                 incineration considering required temperature,



                 excess air, and other burn-related parameters




                 will be those most likely to be designated as



                 POHC's.




           (ii)   Quantity or proportion of a constituent in a



                 waste.  Constituents are more likely to be




                 designated as POHC's if they are present in



                 larger quantities or proportions.




     In addition to designation of POHC's the permitting official




must assess the adequacy of the test burn protocol (operating
                                -72-

-------
conditions, number and duration of burns), monitoring procedures,



and environmental controls.  The permitting official may use




guidance documents (Permit Writers Guidelines for hazardous




Waste Incineration; Engineering Handbook for Hazardous Waste




Incineration) to guide his assessment of the trial burn plan.




After requiring any necessary modifications, the trial burn



plan will be approved, and the burn can be performed without a



permit modification.




     If a trial burn waiver has been requested, the permitting



official will determine whether the performance standard of




§264.343 (99.99% ORE) can be met for the POHC's in the waste and



whether operating conditions necessary to meet that standard can




be defined and met.  This determination will be made bv assess-




ing the following information:




     (1)  Physical properties and chemical composition of the



          waste for which a waiver is requested, compared with




          other wastes for which documented trial or operational




          burn data are available.  The greater the similarity




          to a successful burn the greater the probability that




          a waiver will be granted.



     (2)  Design of the incinerator unit to be used compared




          to that for which comparative burn data are available




          including planned operating schedules, burning rates,




          engineering reports, and pertinent drawinas.  The




          greater the similarity, the greater the probability




          of a waiver.



     (3)  Existing incineration data for the  same or similar
                                 -73-

-------
          "hazardous waste (in terms of physical and chemical



          characteristics) for the same or similar incinerator,




          or from other sources (e.g., pilot-scale incinerator




          data) which miqht be applied to the owner or operator's




          incinerator to demonstrate compliance.  The data should




          identify the operating conditions required to achieve




          that performance.  Again, the greater the similarity,



          the greater the probability of a waiver.




     (4)  Such other information as the Regional Administrator



          finds necessary to determine compliance with $364.143



          or to specify operating requirements under S264.34S.




Step II — Trial Burn



     During the trial burn, monitoring of waste feed rate and




operating conditions, along with sampling and analysis of exhaust




gases and ash, produces data which the permitting official will




use to assess the performance of the incinerator.  From these




data direct calculations of the destruction and removal efficiency




(DRE) are possible, and the operating conditions associated with




it are directly measured.  In many cases, the operating conditions




will be varied during the trial burn to provide measurements of




DRE at different operating conditions.



     In addition to measuring POHC's in the exhaust gas, samples




of the exhaust gases will be analyzed for by-products, metals,



and hydrogen halides.  These data will provide the permitting




official with additional information with which to evaluate the



capability of the proposed system to consistently and ef fectivelv




meet the requirements of §264.343.






                                -74-

-------
VI.  RESPONSE TO COMMENTS/RATIONALE FOR THE FINAL  REGULATION

     The rationale for the final incineration regulation is

presented in this section.  The section is organized by subject,

each subject corresponding to a major provision of the final

regulation.  The subjects are presented in the order that these

provisions appear.  Each subject discussion has five Darts:   (11

a summary of the proposed standard  (if any) corresponding to,

or most closely associated with the final standard,  (21 comments

received on the proposed standard,  (3) response to the comments,

(4) rationale for the final standard, and  (5) final regulation

language.

     Preceding this provision-by-provision discussion of the  final-

regulation is a summary and discussion of the aeneral comments

received on the proposed regulations.

A.   General Issues

     1.   Summary of Comments

     General comments received on the proposed 52SO.45-1 regu-

lations are as follows:

     a.   Incineration should be regulated three  ways:  emissions
          should be controlled by the Clean Air Act, effluents
          by the NPDES system, and  land disposal  by  Subtitle  D
          of RCRA.  Legislative history does not  indicate that
          Section 30O4 "disposal" was intended to include
          in ci ne ra ti on.

     b.   Design and operating regulations are a  mistake.   The
          owner or operator should be allowed to  determine how
          to opereate the process in order to meet performance
          standards.

     c.   RCRA incinerator standards should be waived  ^or existing
          State permitted incinerators.
                                -75-

-------
     d.   EPA should allow incineration of many hazardous wastes
          if alternatives for treatment and disposal are econo-
          mically or technically infeasible or cost of transpor-
          tation is greater than incineration costs.

     e.   Cement kilns and industrial boilers should comply
          with incinerator standards.

2.   Analysis of and Response to General Issue Comments

     Hazardous Waste Incineration Falls Within the RCRA Statute.

The commenters1 discussion of whether hazardous waste incineration

falls within the Section 1004(3) definition of "disposal" is

irrelevant.  The Agency is regulating incineration as "treatment"

of hazardous wastes.  Section 1004(34) defines treatment:

          (34) The term "treatment", when used in connection
               with hazardous waste, means any method, tech-
               nique, or process, including neutralization,
               designed to change the biological character or
               composition of any hazardous waste so as to
               neutralize waste and render it non-hazardous,
               safe for transport, amenable for recovery,
               amenable for storage, or reduced in volume.
               Such term includes any activity or processing
               designed to change the physical form or chemi-
               cal composition of hazardous waste so as to
               render it non-hazardous.

     As a process designed to render hazardous waste non-hazardous

and reduced in volume, incineration certainly falls within this

definition.  The Agency's statutory mandate to regulate such

treatment processes is then found in Section 30O4, which requires

that the Administrator promulgate performance standards for the

treatment of hazardous wastes.  This mandate also serves the

objectives of the statute, defined by Congress in Section 1003(4)

as, among other things, "regulating the treatment...of hazardous

wastes which have adverse affects on health and the environment".

In addition, incineration of hazardous wastes was discussed
                                 -76-

-------
extensively in EPA's 1974 Report, to Congress;  Disposal of Hazar-

dous Wastes, a document that strongly influenced. Congressional

development of RCRA and in testimony before Congressional

Committees prior to passage of the 19RO amendments to RCRA.  The

Adminstrator1s authority in the matter is made even more clear

later in Section 3004, which says that standards set by the

Agency "shall include, but need not be limited to, requirements

respecting --

          (3)  treatment...of ail such wastes...pursuant to
               such operating methods, techniques, and
               practices as may be satisfactory to the
               Administrator."

     The Agency disagrees with those commenters who suggested

that the proposed regulations should be replaced by, or were in

conflict with, the Clean Air Act.  As discussed more fully in

Part II of this document, current CAA regulations address only a

fraction of the potential emissions from a hazardous waste incin-

erator.  The Clean Air Act is oriented toward control of emissions

on a pollutant-by-poliutant basis, and current regulations are

focused largely on wide-spread, large-volume, pollutants (parti-

culates, NOX, SOX, etc).  In contrast, the pollutants which could

be emitted from hazardous waste incinerators are more numerous

and diverse.  Many are acutely toxic or carcinoaenic.  ^ case-by-

case, chemical by chemical, regulatory approach under the Clean

Air Act is not practical in this situation.  RCRA provides autho-

rity to control emissions broadly through destruction and combus-

tion performance standards and direct operating and design standards

Such a regulatory approach is necessary in order to adequately
                                -77-

-------
protect public health as required by RCRA.  However, to the extent




that standards can be developed in the future under the Clean Air




Act to deal with specific hazardous air emissions, this may aid in




the taslc of regulating hazardous waste incineration.  Finally,




disposal of ash or other residues generated by an incinerator or



by other means must be done in compliance with RCRA regulations




     b.   Performance Standards are an Appropriate Approach




     The response to this issue was discussed in Part v of this



document, and is further discussed in response to some of the



more specific comments which  follow.  As these responses indicate,




the Agency agrees with the commenters and has incorporated a



performance, rather than an operating and design standard in the




final regulation.




     c.   Exempt Incinerators with State Permits




     There is no reason why existing incinerators which currently




hold State issued permits should be exempted from RCRA coverage.




On the contrary, Congress intended that EPA establish uniforn




national standards to protect human health and the environment.




All States which elect to run a RCRA hazardous waste program are




required by RCRA to have standards at least as strict as the



Federal Standards.  In States which do not implement the RCR?\




program, the RCRA regulations are independently enforceable by




EPA.  Thus, existing as well as new incinerators will have to



meet the new RCRA standards at a minimum.



     4.   Economic Considerations




          The RCRA requires that EPA promulgate regulations for




management of hazardous waste which will protect human health and
                                -78-

-------
the  environment.   Thus,  all regulations are desianed to accomplish



this objective.   It  is  a fact that the requirements do imoose sig-



nificant  costs which will affect the decision of hazardous waste



generators  in selecting  amonq the various treatment, storage and



disposal  options.   EPA  evaluates the costs of alternative manage-



ment approaches  as a part of the overall RCRA economic analvsis.



Incineration will  remain economically competitive with landfill.



This is true because the total costs of waste management includes



transport,  long  term maintenance of storage and landfill sites,



and  final disposal at the end of the useful life of landfills.



Incineration constitutes ultimate disposal.  Incineration of



hazardous wastes now is  clearly cheaper than incurring the long



 term costs  in  addition to unknown final disposal costs.  The



 decision  to incinerate hazardous waste versus applying other



 treatment,  storage, and disposal options will be UP to the



 generator or disposer within the constraints of technical and



• economic  feasibility.  However, each of the management options,



 as the RCRA statute mandates, will be required to meet the reouire-



 aents  of  the regulations to ensure protection of human health




, and the environment.



     5.  Cement Kilns and Industrial Boilers



          "Incinerator" is defined in Part 260  (45 PR  33074, Mav



i 19, 1980) as a device, "the primary purpose of which  is  to thermallv



 break down  hazardous waste."  Part 261  (45 FR 33120) snecifies



 that solid  wastes which are beneficially used or reused  or leqi-



 timately recycled or reclaimed  are not  regulated under the incine-



 ration provision of Part 264.   In most  cases cement kilns  and






                                -79-

-------
boilers would typically come within the exclusion defined in Part

261.  Thus, these facilities are not currently subject to reaula-

tion.  However, the Agency is further evaluating these to deter-

mine the need for regulation.  The Agency expects to promulgate

regulations to deal with specific types of hazardous waste recovery

in the future if these investigations indicate a need to reaulate

such processes.

B.   Exemption of Ignitable Waste

     1.   Summary of proposed regulation

          Ignitable wastes were given no special mention in the

     proposed incinerator regulations.

     2.   Comments on the proposed regulation

          o    Wastes which are hazardous due to only to ianita-
               bility should be exempt from the destruction
               efficiency and related requirements since they
               pose no toxicity hazard.  Some of these wastes
               could be used as auxiliarv fuel in burning other
               hazardous waste.

     3«   Response to comments

          The Agency agrees with the comment.  Incinerators

     burning wastes which are found to be hazardous based on

     ignitability only need not comply with Subpart 0 technical

     standards.  The "ignitability only" determination mav be

     based  (a) a listing is Part 261 Subpart D for ignitabilitv

     only, or (b) testing by the generator.

     4.   Rationale for the final regulation

          EPA has decided to provide an exemption from most of" the

     incineration regulations for wastes which are ignitable only

     if the permit applicant can demonstrate that these wastes do

     not contain hazardous constituents listed in Part 261, Appendix

     VIII.
                               -80-

-------
     The decision is based on two factors:

     (1)  materials meeting these definitions are expected
          to combust easily merely by introduction of suffi-
          cient heat to initiate combustion.  A verv hiah
          destruction and removal efficiency is expected;

     (2)  since they do not emit gases which are toxic,
          (otherwise they would be listed for toxicity)
          release of their combustion oroducts should be
          of minimal environmental or health concern.

This exemption is conditional on a oermit application

showing that hazardous waste constituents listed in Part 261,

Appendix VIII are not present.  A conditional exemption is

necessary because wastes could contain toxic constituents

even though they fail only the ignitability characteristic.

Since toxicity is not addressed in any of the hazardous

waste characteristics (except for six Pesticides included

in the EP toxocity test) a waste could fail only the ignita-

bility characteristic but still contain toxic organic

constituents.  Similarly, it is possible that specific

samples of a waste listed for ignitabilitv only, may contain

(at least in some instances) toxic constituents which were

not known to the Agency.

     Based on the waste listing in the May  19,  19HO regula-

tions  (45 FR at 33123) the variance should aoplv to the

following wastes when it can be demonstrated that thev contain

no Appendix VIII constituents:  the spent non-halogentated

solvents, xylene, acetone, ethyl acetate,  ethyl benzene,

ethyl ether, n-butyl alcohol, cyclohexanone, and the still

bottoms from the recovery of these solvents.
                          -81-

-------
          It should be noted that incinerators which qualifv under



     this exemption will still have to he permitted and comolv



     with all other parts of the hazardous waste regulations even



     though they are exempted from the technical recmirements



     of Subpart O.



     5.   Final regulatory language



§264.340  Applicability



     (a)  The requlations in this Subpart aoolv to owners and



operators of facilities that incinerate hazardous waste, except



as §264.1 provides otherwise.



     (b)  If the Regional Administrator finds, after an examination



of the waste analysis included Part B of the annlicants nermit



application, that the waste to be burned,



          (1)  is either (i) listed as a hazardous waste in Part



               261, Subpart D, of this Chaoter only because it is



               ignitable (Hazard Code I) or, (ii) that the waste



               has been tested against the characteristics of



               hazardous waste under Part 261, Subpart C, of this



               Chapter and that it meets onlv the ignitabilitv



               characteristic; and



          (2)  that the waste analysis included with Part R of



               the permit application includes none of the



               hazardous constituents listed in Part 261, Anoendix



               VIII,



then the Regional Administrator may, in establishing the oermit



conditions,  exempt the applicant from all requirements of this



Subpart except 5264.341 (Waste Analysis), and S264.351 (Closure).
                               -R2-

-------
     (c)   The owner or operator of an incinerator may conduct

trial burns,  subject only the requirements of §122.27(b)  (Trial

Burn Permits).

C.   Special  Requirements for Trial Burns

     1.    Summary of proposed regulations

          No  provisions in the proposed regulations indicated

     that incinerators were exempt from any parts of the  incine-

     rator standards during trial burns.

     2.    Comments on the proposed regulation

     0    It  may not be possible to meet the performance  and
          operating standards during a trial burn, since  the
          purpose of the burn is to establish the feasibility
          of  meeting those requirements.

     0    The full permitting process should not be required
          for a trial burn because it will require too much
          processing time and could stifle use of the incine-
          ration option.

     3.    Response to comments

          The Agency concurs with these comments.

     4.    Rationale for the Final Regulation

          It  was not the Agency's intent in the nrooosed  reaula-

     tions that trial burns comply with all of the incinerator

     standards, since as the commenter noted, the trial burn is

     intended to determine whether, and under what conditions,

     those standards can be met.  Further, the Agencv has decided

     that a formal permit action to conduct a trial burn is

     unnecessary and could delay effective hazardous waste incin-

     eration.  There are several reasons for this decision:

     a)    trial burns will be of short duration
                               -83-

-------
     b)    trial burn operating  conditions will he very closelv



          controlled and monitored



     c)    lengthy and costly permit procedures could delay



          prompt disposal of hazardous wastes



     d)    excessive trial burn requirements could discourage



          use of the incineration option for "new" wastes



          which had not previously been burned



     Nevertheless, the Agency believes that prior notice



     and approval is necessary for each trial burn.  The final



     regulations provide a mechanism for this approval bv



     requiring a trial burn plan prior to conduct of a burn (See



     paragraph L.).  Thus, the Agency has clarified both of these



     points in the final regulation.



     5.    Final Regulatory Language



     §264.344  New Wastes;  trial burns or permit modifications



          (a)  The owner or operator of a hazardous waste incine-



     rator may burn only wastes specified in his permit and onlv



     under operating conditions specified for those wastes under



     §264.345, except:



          (1)  In approved trial burns under Sl22.27(b) of this



               Chapter; or



          (2)  Under the exemptions created by S264.34Q.



D.   Destruction and Removal Efficiency



     1.    Summary of Proposed Regulations



     The proposed rules required that the incinerator be desianed,



constructed and operated to maintain a destruction efficiencv of



99.99 percent as defined in the followina equation:






                               -84-

-------
     DE =  *-in - gout.
           (  	M	)  x  100, where
                 in

     DE =  destruction efficiency

    win =  mass feed rate of principal toxic components of
           waste qoinq into the incinerator
    wout =  mass emissions rate of principal toxic components
            in waste in the incinerator combustion zone
2.   Comments on the Proposed Regulation

Calculations for DE are not possible because:

(a)  The operator may not know the mass feed rate of the
     principal toxic components,

(b)  Sampling of the incinerator combustion zone is not
     technically feasible.  In addition, time and space
     variations of the non-homoqeneous turbulence condi-
     tions in the combustion zone would preclude obtaining
     any statistically meaningful results.

The term wout should represent "Emissions to the Atmosphere"
(where they can be measured).

The DE equation is inapplicable to metals or other noncom-
bustible components which may also exit the combustion zone
in exhaust gases but still not be destroyed.

A 99.99% DE has not been demonstrated technologically
feasible for chemical waste incinerators.

To meet the unrealistically high DE level of 99.99%, many
wastes would have to be burned with 90% or more suople-
mentary fuel.

It is extremely difficult to obtain a DE of 99.99% while
incinerating aqueous wastes containing less than 5% organics.

In the definition of the terms which are used in the DE
calculation,  it is unclear whether "orincipal" refers to
weight, volume, or degree of hazard.

DE should not be set at an arbitrarily selected value of
99.99%, but should be variable and should bear some relation-
ship to the degree of hazard of a particular waste.

Excursions from the specified DE should be allowed for
operational variations.

EPA should develop test methods for W^n and
                          -85-

-------
0    DE must be performed on a statistical basis, specifvinq
     averages and appropriate confidence limits.  Presentlv
     the calculation permits a single sample under best
     operatinq conditions.

0    Mass emission levels should be set usinq OSHA standards
     for chemicals in the air.

"    The following comments were offered related to the EPA
     incinerator test work  (BPA-69-01-2966) program:
     1)   does not support proposed temperature and residence
          time criteria,

     2)   indicates that DE can be achieved when departing from
          the proposed combustion criteria,

     3}   indicates that specific emission control equipment
          may not be needed for cement kilns burning wastes,
          and
     4)   indicates pyrolysis methods may merit more study
          if DE is determined following the afterburner.

*    EPA must define combustion temperature and retention time
     to apply the time/temperature/excess oxyqen requirements.


     3.   Response to Comments

     Calculations of Destruction Efficiency.  The commenter who

said that destruction efficiency calculations are not possible

because the operator may not know the mass feed rate of principal

organic hazardous components is in error.  During normal operation,

the concentrations may not be known with precision, althouqh the

feed rate of the waste should be easily measured and the aporoxi-

mate concentrations of the principal hazardous components should

be known from the analysis of the waste required bv the regulations

However, the final regulations do not require that destruction

and removal efficiency be continuously monitored.  Instead it

is measured during a trial burn and, from the trial burn, inciner-

ator operatinq conditions are established which can be auicklv

and easily monitored during normal operation.  Subsequently, the


                               -86-

-------
operator must accurately know the feed rate of the principal

organic hazardous constituent s) (by measurement) in order to

compute the value of the DRE.  By laboratory analysis the con-

centration of POHC's in the waste to be burned will be known,

and the feed rate of that waste can be measured during the trial

burn and during normal operation with conventional equipment and

instruments.

     EPA agrees with the commenter that sampling of the qas in

the hot zone of incinerators  is difficult technically and could

lead to significant inaccuracies.  In response, the definition of

Wout in the final regulation  has been changed to specifv sampling

of incinerator gases after scrubbing and cooling and before emis-

sion to the atmosphere.  This change in definition of wout also

requires that Destruction Efficiencv be renamed Destruction and

Removal Efficiency  (DRE) to  reflect total removal of the principal

hazardous components in the  incinerator system.  This change in

definition allows sampling of emissions at a lower temperature

than the combustion zone and  simplifies samplinq and analvsis of

gaseous emissions.  The change  to DRE also satisfies the comment

that wout represent emission  to the atmosphere.  The chanae to the

use of  the DRE has  two major  advantages to owners and operators

of incinerators:

     1)   Sampling  to determine  compliance with  the DRE will be
          easier and less costlv, and

     2)   Credit for removal  of  any air pollultion control eguin-
          ment is included since the measurement is prior to
          release to the environment.
                                -87-

-------
     Destruction efficiency for metals.  EPA aqrees with the

comment that the destruction efficiency defined in the proposed

regulations, is not applicable to metals or other noncombustible

components.  Destruction and removal efficiencv could be appli-

cable to metals because it considers removal of waste constituents

in the air pollution control system.  Thus, metals which do not

combust, could be controlled to a qiven removal level.  (Waste

constituents which come out in the  incinerator bottom ash, as will

be the case with many metals, are also considered removed, since

they are not included in the term "^out" in the destruction and

removal efficiencv equation:
                    ORE  =    in,   „   ,„„
                                 v in
     Thus, conceptually, destruction and removal efficiencv

could be applied to metals.  However, the Aaencv is not now

applyinq the ORE standard to metals in the requlation at this

time.  Most importantly, this is because the Office of Solid

Waste has no test data to show that a 99.99% DRK or anv other

specific value can be achieved.  All of the Aqencv's incinerator

trial burn data focused on orqanic constituents.  Metals mav

exit an incinerator in the bottom ash, as particulates larqe

enough to be collected in particulate removal equipment, as

sub-micron size particulates which are not readilv removed, and

as vapors, in the case of some metals such as mercurv.  Thus,

although removal efficiency for metals could he established, the

Agency does not now know what level of removal is feasible for a

national requlation.  The Aqencv intends to undertake investiaat ion
                               -89-

-------
of this issue and specifically solicits comments and data on metal



removal efficiency.



     The definition of DRE in the final requlation has been changed



to specify the term *^in as "principal organic hazardous comno-



nent(s) in the waste stream feeding the incinerator."



     Destruction efficiency of 99.99%.  The comment that a 99.99%



DE has not been demonstrated is in error.  The achievabilitv of



a 99.99% destruction efficiency has been demonstrated and is a



major element in the Agency's rationale for including it in the



final regulation.  This is discussed thoroughlv in paragraph 4,



"Rationale", below.



     Supplementary Fuel.  The Agency realizes that supplementary



fuel will be required to destroy some wastes, includina "aqueous



wastes with 5% or less organics".  This would be the case regard-



less of the level of DRE.  The Agency believes that protection o^



human health requires that even wastes which have a verv low heat



value must be adequately destroyed, even when it increases operating



costs and fuel consumption.



     Definition of Principal component.  The Agency agrees with



the comment that the definition of "principal" mav have been



unclear.  The final regulations describe the criteria and oro-



cedures for selecting "principal" hazardous components.  The



decision identifying one or more principal organic hazardous



components will be made by applying the best engineering judgement



of the permit writer based on criteria specified in the regulation.



     DE should be variable.  The Agency agrees in theorv with the



comment that DE  (DRE) should be variable.  Such a variance however,
                               -89-

-------
would have to be based on a careful case-bv-case analysis.  The



Agency is today proposing a procedure which will allow the nerrait



writer to either increase or decrease the required DRE value based



on an assessment of the  impact on human health and the environment.



It should be made clear  that in the absence of convincinq evidence



that a lower level of DRE is safe, EPA will reauire that th^



owner or operator comply with the minimum DRE of 99.99%.



     Excursions from DE.  Because it would result in stack emissions



that could be hazardous, the Agency disagrees in principle with



the comment that excursions be allowed from the 99.99% DRE.  In



actual practice the DRE  will be directlv measured only during



trial burns or during occasional compliance testing.  However,



the operating conditions established in the permit for continuously



monitored incinerator operating parameters, i.e., temperature,



air feed rate, carbon monoxide in the stack, etc., are intended



to prevent significant deviations from the stipulated DRE.  Also



activation of alarm systems and automatic incinerator shutdown



is required if operating parameters exceed specified limits in



the permit.



     Calculation of DRE.  The Agency agrees with the comment



that a need exists to develop test methods for the determination of



Destruction and Removal  Efficiency.  In fact this effort is under



way and to date specific analytical techniques for waste analvsis



have been published in the EPA publication SW-846.  The develop-



ment of sampling methods for Wou^-, i.e., the stack, are continuina



as an overall Agency effort not confined to just hazardous waste
                               -90-

-------
incinerators.  Specific guidance on  currently  available tech-




niques being recommended by EPA. can  be  found in  the  Engineer-




ing Handbook for Hazardous Waste Incineration  (7^.   Discussion




for computation of the DRE is presented in  guidance  (5B).




     Statistical Basis for ORE.  EPA. agrees with the comment that




determination of performance standards  should  be statisticallv




based.  However, it is necessary to  provide the  most flexibilitv




in conducting trial burns and particularly  to  minimize the burden




of trial burns on owners and operators.  Additionally, earlv in




the regulatory history of implementing  Subpart O, there will be




very little data to support sophisticated statistical analyses.




The Agency is building a data base which is describe^ elsewhere




and plans to use the  latest statistical technigues to analyze




ail data as warranted by the character  and  guantity of available




data.




     Emission Limits  (TLV) .  EPA. agrees that  OSHA standards have




the potential to be used to set emission levels  from hazardous




waste incinerators.   The Agency has  thoroughlv explored this




approach and has developed  a proposed methodology to applv the




OSHA type threshold standards  to  incinerator  emissions.  'TThe




reader  is referred to the  Background Document  on Propose^




Variances T.O §264.343 Performance  Standards for a comprehensive




discussion of this approach.




     The EPA Test Program.  The Agency agrees with the four




comments made on the  results of its  test work under Contract




gg-01-2966.  The test results  do  not adeguately support the




proposed combustion criteria.   This  is  one  of several reasons
                                 -91-

-------
that the Agency decided to drop the combustion criteria from

the final regulations and establish the r>RE as the operatina

standard.  The second point is basically the same statement as

the first and the Agency also agrees.

     The Agency also agrees with the third comment that cement

kilns burning hazardous waste will not likely have to add anv

additional air pollution control equipment.  The Clean Air

Act currently provides emission standards for normal cement kiln

operation.  Also the current RCRA standards exempt cement kilns

burning hazardous wastes as a resource (heat value) recoverv

method.

     The use of pyrolysis as a hazardous waste treatment method

has merit and will certainly find its place in the range o*

waste management options.  The Agency will study pyrolysis

processes in the future and if a decision is made to regulate

such processes, appropriate standards will be developed.

4.   Rationale for the Final Regulation

     a)   Destruction and Removal ^fficinecy as a Conceptual
            Approach

     The regulations for incinerators proposed in the December I®,

1978 Federal Register included two basic types of controls: <1^

performance standards for destruction efficiencv and combustion

efficiency and (2) operating and desicin standards of minimum

operating temperatures, retention times,  etc.  Operatina require-

ments are included in the final regulation, but they are deter-

mined on a case-by-case basis and are derived from test data

based on achieving the DRK.   The rationale for droppinq temper-
                                -92-

-------
ature/time operating requirements is discussed  in  Part v and




also in paragraph G below.  As discussed in paragraph G, combus-




tion efficiency has been dropped in the final regulation.




     The Agency has found that destruction and  removal efficiency




is both a. necessary and a supported performance standard for  incin-




eration.  Other types of performance standards  were considered



and rejected during development of the proposed and final  incine-




ration regulations.  For example, reliance on combustion ef-^i-




ciency was rejected as being infeasible.  Establishing limits for




air emissions from the stack was rejected because, as discussed




in Part II of this document, it is infeasible to establish emission



limits for the large number and mixtures of hazardous substances



which could potentially be emitted.




     The Agency considered defining technology  requirements -




for example, "best available technology" or "best  oracticable



technology" as the terms are used in the Clean  Air Act and Clean



Water Act.  This concept in essence involves a  survey of all of




the technology being used to control a snecfic  pollutant or




emission.  The survey identifies the processes  which are most




advanced in meeting environmental goals.  The Agencv then nro-




mulgates a regulation which is based on across-the-board use of




this technology.



     The Agency has adopted in the ORE standard a  modified tyoe




of best available technology approach.  The o^.QO  percent destruc-




tion and removal efficiency represents a "best  available inciner-



ator performance" that can be achieved on a broa^  ranne of wastes
                                -93-

-------
using state-of-the-art technology and proper operatinq practices.



     Thus, the Agency  believes that  a combination of a "best




technology" performance standard of 99.99% DRE and if shown to




be feasible, a rislc assessment override to deal with exceptional



cases, provides a practical standard consistent with the RCRA




mandate to protect human health and the environment.



     b)   Achievability of 99.99% DRE




     The Agency has found that a destruction and removal ef^i-




ciency of 99.99% is an achievable standard for hazardous waste



destruction.  As shown in Table I, the Aqencv has identified 54




test burns carried out on a number of hazardous wastes.  Of these




54 test burns, 45 achieved a destruction efficiency f^E} of




99.99% or better.  Consideration was given to the additional




removal achieved by air pollution control equipment (now allowed




in the DRE calculation).  The nine test burns that did not consis




tently achieve a minimum 99.99% destruction efficiencv are




discussed below.




     1)   The first U.S. based burn by the M/T Vulcanus occurred



in 1974. (12)  This burn too"k place in the Gulf of Mexico with




chlorinated hydrocarbon waste from Shell Chemical Co.  The




destruction efficiency for the chlorinated hydrocarbons was 9Q




T.O 99.98 as shown in Table I.  This lower destruction efficiencv




was caused, as verified later, by an inefficient burner desian.




     2)   The destruction of solid DDT in the Palo Alto Multiple



Hearth Sewage Sludge Incinerator achieved a DE of >9Q.a7%. (14)




This work in 1975 demonstrated that a multiple hearth sewage
                                -94-

-------
                                          TABLE I


                    Suonary of  Incinerator Destruction "fficiency Teat Uorlc
WA3TP
Bnell Aldrin (204
granules)1
3hall Aldrita1
Atrasina - liquid1
Atrazina - oolidl
Para-ArsaniLic Acid2
Captan - solid'
Chiorjune 54 Juat3
IMCIHEIUTOR LOCATION
Multiple Chaaber Mldwaat Research
Multiple Chamber Midweat Research
Multiple Chamber Midweat Iteaearch
Multiple Chamber Midweat Research
Molten Salt Combuation. Rockwell Internat'l
Multiple Chamber Midweat Research
Liquid Injection TRW
OP PRINCIPLE CflMPrnfRf^Tfl *•
(PERCKNT)
Aldrin
Total Speciea
Aldrin
Total Spec lea
Atrazine
Total 3paciaa
Atrazine
Total Speeiea

Captan
Total Species
Chiordane
%% '•
>99-99
>99-99
VQQ "^Q
\ Qrt QO
>29-999
>99.99
>99.99
        , 72^ E.-nuloi-
jTiublj Concantruta
and !!o. 2 ?uel
Liquid Injection
                                                  TRW
                                                   C^lordane
                                                                                             >99-999
   WASTS
                           I.'ICINEnATOli
                                                     LOCATION
                                                                            OP
Chlorinated hydrocar-     Two high temperature
 bonu,  tr ichloropropiine,   incinerators
 ;richloroethana, and
 dichloroethane  predom-
                                                   M/T Vulcnnua Ocean
                                                     Coahuation Sarvicaa
                                                  Chlorinated
                                                  Hydrocarbons  q9'92
Cliloro for'n'-
                          Molton Salt  Combuation   Roolcwell Internat'l     Chloroform
-IJT 5:' Cll Solution'      Liquid Injection
                                                   TRW
ill) 7 (uol Id ) ' •<
D07, 1C< Duat '
2C.I OUT Oil Solution^
307 25'.< "nulolfiable
7h"r~>yt ' '-if'si/labla 	
Conooncruta1
Municipal Multiple City of Palo Alto >qq n7 n qo QH
iieurth Sewage Sludge DD™ .1^-1 .-in
I/ic inera tor
Multiple Chamber Midweat Reaearch DOT >qq.qq
Total Speciea >qq.qq
Liquid Injection T!)W „,., >0q qfl
Liquid Injection TOT >qq.Qci
DDT
Multiple Chamber Midvaet Raoenruh DDT >q9,qfl.>.79 9<
Total Species ><19. q«->99 .9!
^"hdre ;
                   X 100     '<«ic componanc
                                        e,ni3sl0n rata of the principle toxic co.npon.ne  in
                                               combustion, zone
                                             -95-

-------
                                         TA.ULE I (cont.)
    WASTE
                           IMCINEnATOH
                                                     LOCATION
                                                                           DESTRUCTION KPPICIKMCY
                                                                           OP PRIHCIPLE CnMPONF.HTS
                                                                                  (PSHC2!IT)
DDT Oil 20*
 emulsified DDT
 Waste Oil - 1.7*
 PCO'3
                         Thermal Oxidizer
                          Waata  Incinerator
                                                  General  Electric Co.
                                                                         JIDT

                                                                         PCS
                                                                                        qq.qqqq
                                                                                       >qg.qqq<5
DDT Powder4
                         Molten  Salt  Combustion  Rockwell Internat'l
                                                                         DDT
                                                                                         99.99H
Dioldrin  15* Enulai-    Liquid  Injection         TRW
 flable Concentrate?
                                                                       Dieldrin
                                                                                        >o,q.qqq
Dieldrin  -  15*
  Kaulalfiable Concen-
  irntan ai;d  72*
  Chlordane  Kaulairi-
  ublo  Concentrates
  (nixeci 1:3  ratlo)3
                          Liquid  Injection
                                                  TRW
                                                                       Dieldrin
Dlphenylaaine-HCl 2
Sthylene Manufacturing
• auto 5
CU {C,,H, 00.,P?)2
WAU7S
;'erb ic i'le Orange' 9
Hexachlorocyclopenta-
j lcnt, Solution
o' Ko pone°
Toledo Sludge t
Ke por\e CO-
lnclneration°
I,n:Ja;irf, 12* Eraulal-
fiublo Concentrate^
Malathxon^
:iali\thion, 25* Wet
Power i
Mnl.ithion 57* Eaulni-
fiabld Concentrate^-
Molten Salt Combustion
Liquid Injection
Molten Salt Combustion
IMCINKRATOn
Two Identical Re-
fractory-lined
furnaces
Liquid Injection
Rotary Kiln Pyrolyzar
. Rotary Kiln Pyrolyzer
Liquid Injection
Molten Salt Combustion
Multiple Chamber
Multiple Chamber
Rockwell Internat'l
Marquardt Co.
Hock veil Internat'l
LOCATION
Ocean Combustion
Services - M/T
Vulcan ua
Marquardt Co.
Midland - Ross
Midland - Roas
TIW
Rockwell Internat'l
Midwest Research
Midwest Research
Diphenylaraine
Waste Con-
stituents
Total
Organ lea
G3
°"^is
2,4,5-7-2,4,0
Waste Con- ]
aticuenta
Total
Organ lea
Kepone
Xepone
Lindane
H.l.tti,n
Mala thion
Total Spec lea
Malar.hion
total Speciea
>qq.qqq
99.96
>qq.qqqqqqfiq
PPICItiMRY
>99.999
99-985 -
>39.999
>99-9999
>99.9999
>,,,,
99*9998
>99."59
>99-99
>99-99
>99-90
                                                 -96-

-------
                                         CABLE  I  (cont.:
WASTE
Methyl Methacrylate
(MHA)5
0.3^ Mirex Bait1
Mustard^
III trochlorobenzena5
•11 troe thane^
Phenol Waste?
Picloraa1
Piolorara (Tor don
1CK pellets)1
?C3' j-
P''3 Cj.racitoro7
p<:?.4
Polyvinyl Chloride
Wasted
Toxaphene 2C# Dust'
Toxnnhone 60,i 2.-nulal-
1'lable Concentrate1
7r Ichlor ethane 2
i;ici;jf:nA?on
Pluirtlzecl heu
Multiple Chamber
Molten Salt Combustion
Liquid Injection
Molten Salt Combustion
PluiiUzed Bed
Multiple Chamber
Multiple Chamber
Rotary Kiln
Rotary Kiln
Cement Kiln
Rotary Kiln
Multiple Chamber
Multiple Chamber
Molten Salt Combustion
LOCATIOrl
3yatera3 Tech
Midwest Research
Ilockvell Internat
Rollins
Rockwell Internat
Systems Tech
Midwest Research
Midwest Research
Rollina
	 rasi'RTTcTTnfrp.pprrTTr.Mnv 	
n? PRINCIPLE CriMPOHRN'TS
fPRROKMT)
Waata Con- >99.999
a ti tuen ta
total Or panics 99-96 -
99-93
Mirex >98.21 -
39.98
Total Species >97.7Q -
99-96
'1 Mustard- >qq.999-999985
Waste Con- >99.99 -
gtituents 99-999
Total Or«anics 99-^'i -
99- H7
•1 Nit roe thane >99-993
Waste Con- >99-99
stituents
Total Organlca 99. Q^ -
99-95
Piclorara >99-99
Total Species >99-63 -
>99-99
Piclorara >:)9-99
Total Speclea >99-93 -
>99-99
3C3'3 >99.9999*^
>99- 999977
Rollins Waato Constituents 99. 5 -
99-999
Total Or«anics 99.9* -
59-58
Swedish Watar and Air ?C3's >99-339Q
Pollution Research
Ina ti tute
7 M Company
Midweat Research
Miiiweat Research
noclcwell Internat
Total Or^anics 59-30 -
99-65
Chlorinated Or*anics 99-99
Toxaphene >99-95
Toxaphene ^99 -9^
ij^ Trichlorethane >99-99
2,-i-U low
Liquid Injection
                                                                        2.4-0
                                                -97-

-------
             TABLE I (cont.)
UASTK IIICIMEIUTOH
2,-1.5-t (Weedon1") '4 Municipal Multiple
Itanrth ;iawaRe Sludge
Incinerator
2, 4,5-Tlu. iA Single Hearth Furnace
2.-I.5-T4 Single Hearth Purnace
2, 4,5-T'' Single Hearth Furnace
2,-t tJ-T11 3ln«ls Hearth Furnace
VX 'G! jllngOoPSfl) Molten Salt Combustion
( PERCENT)
City of Palo Alto, 2 4 5 - 99-990 -
California ' 99.996
Swedish Water find Air 99-995
Pollution Research . .
Institute 2.4.S-T
Swedish Water and Air 2^4 5 99.995
Pollution Research ' '
Institute
Swedish Water and Air 92.
Pollution Research 2.4.5-T
Institute
Swedish Water and Air 99-995
Pollution Research 2.4,5-T
Institute
Rockwell Internat'l Waste >99. 999989 -
Constituents 99-999^945
Multiple Chamber        Midwest R«nenrch        Zineb       >99-99
                   -98-

-------
sludge incinerator  is  not well  suited  for destruction of many




hard-to-burn hazardous materials.   Tt  is  now generally recog-




nized in the technical community  that  multiple hearth incinerators




are not well suited  for complete  destruction of hazardous wastes.




     3) and 5) The  two test  results of DE = 99.93% for the destruc-




tion of a 20% DDT oil  solution  and  a 1?%  Dieidrin/"?2% Chiordane




concentrate mixture were performed  in  TRWs pilot scale incine-




rator  -~*>.  These test results  were obtained durinrr four pilot




incinerator runs where the incinerator temperatures were all below




1550° F (R45° C) or where less  than the stoichiometric anount o^




air required was supplied.   These results also reinforce the




point that adeguate temperatures  and sufficient excess air are




necessary to achieve high incinerator  destruction efficiencies.




     4)   In an evaluation of the test wor"k done on ?*>% TV)^ by




Midwest Research, 20 test runs  were made, with only one of the ?o




yielding an efficiency of less  than 99.9Q% for nnT1 destruction r ^ • .




The 20 experiments  were done to develop a rearession mo-^el to




predict. DDT destruction based on  varying  the injection rates of




DDT, excess air rates, temperature, and air turbulence.  'Hius ,




destruction efficiencies of  less  than 99.99% were expected as




part of the experiment.   It  is  interesting to observe from the




MRI work t_hat the one  result which yielded less than 9Q.Q9%




efficiency also had the  lowest  retention  time o* all the experi-




ments  except  for one run which  had an identical retention time




but a higher  combustion temperature.  Thus, this one experiment




out of  20 reinforces t_he point  that conditions must be adeguate
                               -99-

-------
and sufficient to ensure 99.99% DEf or higher, and when they are



adequate, 99.99% ORE can be achieved.



     6)   Later Vulcanus burns, monitored by the U.S. EPA durinq



1977 and 1978 demonstrated that the Vulcanus could achieve a



minimum of 99.99% destruction efficiency (ig).  The current



International agreement on Ocean Incineration requires a minimum



DE of 99.99%.



     7)   The report from Midwest Research Institute on the oilot



scale burn of Mirex bait formulation,  concluded that a higher



temperature was needed to effectively destroy the oesticide to



99.99% efficiency (1).  Gas temperatures of 590° C to 840" C were



measured during the ten test runs reported.  Mirex has a hiqhlv



chlorinated structure (Cioc3-12) which could indicate that a



higher combustion temperature (>1000°C) would adeauatelv destroy



the molecule.



     8)   One of the results reported for PCB containina capa-



citors burned at the Rollins Environmental Services incinerator



showed a PCB destruction efficiency of 99.5%.  The calculation



included PCB residue left in the incinerator ash.  The efficiencv



based on combustion qas sampling alone was in fact 99.999% (^.



The reason the ash contained siqnificant quantities of PCB's was



that the capacitors for the test burn were not crushed before



burning but were fed whole to the rotary kiln.  A second test



burn, using capacitors which were nreviouslv hammermilled,



yielded a DE of 99.999% for PCB's even when the ash residues



were considered in the calculation (^).
                              -100-

-------
     9)   The one low destruction efficiency of 92% for 2,4,5-T



reported by the Swedish Water and Air Pollution Research Labora-



tory occurred during an experiment with 2,4,5-T added to wood



chips and sawdust (4).  The report states that "However, when



wood chips with a very high water content were burned under



"open fire" conditions, the temnerature in the flue qas duct was



decreased temporarily to around 100° C and only 92% of I (2,4,5-T)



was destructed."(4)  This one test was conducted at a very low



combustion temperature and a low destruction efficiency would



thus be expected.  Other tests indicate that 2,4,5-T can be



adequately destroyed  (see Table 1).



     In a number of tests results reported in Table 1, the DE



of total organic species was less than the DE for the selected



toxic organic.  This would indicate that organic compounds (of



undetermined type) were present in the burned mixture in larger



quantity and were not destroyed to the same level as the selected



organic.  Complete analyses of the mixtures were not made to



determine the full range of notential POHC's and no selection



process was used to determine the most difficult constituents to



burn.  These are necessary steps reauired bv Suboart 0.



     These tests represent all the data currently available to



EPA through qovernment reports, contractor studies and a search



of the technical literature.  In addition, EPA requested test



data from a number of commenters and did receive a replv from



the American Society of Mechanical Engineers.  The ASME reply



suggested that a 99.99% DE was not consistently achievable.



However, the ASME data do support a ORE OF 99.99% (34).  The






                              -101-

-------
change from DE to DRE fortifies the achievability of the per-




formance standard because DRE now specifically allows the removal




obtained in air pollution control devices to be recognized in




the performance of incinerators.




     The data discussed above demonstrate the achievability of




a 99.99% DRE.  The test data in T'able  I do not include examples




of a complete array of all wastes and  waste mixtures which have




been, or may be, incinerated.




     In the final report which summarized the full  scale incinerator



test work conducted in 1975 - 197fi, the contractor  recommended




that additinal work be done on (1) organic phosphate compounds,




(2) Fluorinated organic compounds, and (3) organic  orthosilicate



compounds '^i.  These classes of compounds were identified as




being industrially important and potentially exhibiting different



behavior in incinerators than those for which tests were conducted.



     The Agency has been able to obtain test burn data on two




phosphorous type organic compounds, Malathion  -^',  and




VX(C^H2gC>2PSN)    .  Both of these compounds were  combusted in




a molten salt incinerator with destruction efficiencies exceeding




99.99 percent (see Table 1).
                               -102-

-------
     The chemistry of combustion is extremely complex.  The




kinetics and thermodynamics involved depend on the combustion




conditions and the physical/chemical properties  of the material(s^




being oxidized.  For wastes the chemistry is further complicated




by tfte variable compositions and matrices encountered.




     Some general conclusions can however, be drawn despite the




variations in composition and constituents that  will result




during combustion.  Within this essentially exhaustless field




of waste compositions there are specific substances which exhibit




remarkable thermal stability.  Polychlorinated biphenyls  (PCBs'l




are an example of a class of compounds  that are  difficult to




burn.  The PCB molecule is stable because of its aromatic character




The breakdown of chlorinated aromatics  form transition states




which in turn can lead to combustion by-products (products of




incomplete combustion).  The combination of these two  factors  so




affect the kinetics that combustion conditions ^ound to destrov




PCBs should be expected to destroy other industrial oraanic




chemicals.
                              -10 2a-

-------
     Since the results of the tests almost universally sunported



the achievabilitv of a 99.99 percent destruction efficiency, the



Aqency concludes that a 99.99% destruction and removal efficiencv



is a feasible standard to app.lv on a national level in the



regulation.  Wastes which cannot be destroyed to the 99.99%



ORE standard should not be burned.



     c)    Application of the ORE



     The proposed regulation stated that the destruction effi-



ciency was to be applied to the "principal toxic comnonents" in



the waste going to the incinerator.  As noted above, comments



were received questioning how this term was to be defined, and



questioning the validity of applying the destruction efficiency



requirement to metals.



     The Agency has addressed these concerns in the regulation.



First, the word "organic" has been added so that the term used



in the regulation  is  "principal organic hazardous component".



Conceptually, the change from DE  to DRE should have overcome the



concern about including  non-organics in the DRE eauation, since



even  if not combusted, materials, could be removed from the



system by  either being  incorporated into the bottom ash or  beina



collected  with the particulates in the stack aas.  The test burn



data  cited  above did  not include  a determination of metals  removal



The Agency  has not yet compiled data to support either 99.99% or



any other  removal  efficiency  for  metals.  Thus, the DRE applies




only  to organics in  the  regulation.



      In considering  how  to  define principal organic hazardous



components (POHC's),  the Agency concluded that  a case-bv-case






                               -103-

-------
determination based on specified criteria was the only reasonable

approach.  No single "across the board" definition stood up to

scrutiny; for example, "component of greatest concentration",

"component of greatest hazard", or "conponent most difficult to

thermally destruct".  These criteria were difficult to quantify

or mold into a simple formula.  Instead the Acrency has defined

appropriate criteria for application on a case-by-case basis bv

the permitting official using his best engineerina iudaement.

These criteria are  as follows:

     (i)  The degree of difficulty of incinerating the compo-
          nent.  Organic waste constituents which represent
          the greatest degree of difficulty of incineration
          considering required temperature, excess air, and
          other burn-related parameters will be those most
          likely to be designed as POHC's or hazardous by-
          products .

     (ii) Quantity  or proportion of a constituent in a waste.
          Constituents are more likely to be desianate^ as POHC'S
          or hazardous by-products if they are present in higher
          quantities or proportions.

     In the Agency's judgement, these criteria define the charac-

teristics of a waste component which relate to its Potential

t_o escape fron the  stack and cause damage to human health.

     The Agency considered the matter of degree of hazard -or

potential application in Rubpart O.  See the Background Document

on "Degree of Hazard", April 19PO which was prepare^ in support

of the May 19, 1980 promulgation.

     In the course  of defining criteria for identi^vina POHC's

the Agency recoqnized that during incineration some of the POWC'S

may be "destroyed"  by breaking down or recombining into bv-products.

The "Engineering Handbook for Hazardous Waste Incineration"

                                  -104-

-------
contains examples of this  phenomenon.   Some of these bv-products



could be of equal or areater hazard  than  the POHC's from which



they are formed.  Thus,  the Agency proposes to extend the appli-



cation of the destruction  and  removal  efficiencv to these by-pro-



ducts (See Background Document for Proposed Subpart 0 Standards).



    5.   Final Regulatory Language



$264.342  Principal Organic Hazardous  Constituents (POHCs)



    (a)  Principal Organic Hazardous  Constituents (POHCs) in



the waste feed must be  treated to the  extent required by the



performance standard of  §264.343.



    (b)  (1)  One or more POHCs will  be  specified in the faci-



lity's permit, from among  those constituents listed in Part 261,



ippendix VIII of this Chapter, for each waste feed to be burned.



Sis specification will  be based on  the degree of difficulty of



 incineration of the organic constituents  in the waste and their



 sncentration or mass in the waste feed,  considering the results



 if waste analyses and trial burns or alternative data submitted



 
-------
§264.343  Performance Standards

     An incinerator burning hazardous waste must be desiqned,

constructed, and maintained so that, when operated in accordance

with operating requirements specified under $264.345, it will

meet the following performance standards:

     (a)  An incinerator burning hazardous waste must achieve a

destruction and removal efficiency  (DRE) of 99.993; for each

principal organic hazardous constituent  (POHC) designated (under

§264.342) in its permit for each waste feed.  DRE is determined

for each POHC from the following equation:


                     DRE = .Win - woutt
                            	w.	  x 100%
                                win

Where:     win  =  Mass feed rate of one principal orqanic
                  hazardous constituent  (POHC) in the waste
                  stream feeding the incinerator, and

         wout  =  Mass emission rate of the same POHC present
                  in exhaust emissions prior to release to the
                  atmosphere.

     (b)  An incinerator burning hazardous waste containing more

than 0.5% chlorine must remove 99% of the hydrogen chloride from

the exhaust gas.

     (c)  An incinerator burning hazardous waste must not emit

particulate matter exceeding 180 milligrams per dry standard cubic

meter (0.08 grains per dry standard cubic foot) when corrected

for 12% C02, using the procedures presented in the Clean Air Act

regulations, "Standards of Performance for Incinerators", 40 CFR

60.50,  Subpart E.

     (d)  For purposes of permit enforcement, compliance with the

operating requirements specified in the permit (under §264.345)
                              -106-

-------
will be regarded as compliance with this Section.  However,

evidence that compliance with those permit conditions is insuffi-

cient to ensure compliance with the performance requirements of

this Section may be "information" justifying modification, revoca-

tion, or reissuance of a permit under Si 22.15 of this Chapter.

E.   Emissions of Halogens and Metals

     1.   Summary of the Proposed Regulation

     EPA proposed in 5250.45-1(e)(2) that a hazardous waste

incinerator used to destroy hazardous waste containing more

than 0.5 percent halogens must have an emission control device

to remove 99% of the halogen from the exhaust.  The proposed

regulation dealt with control of metals through the performance

requirement of 99.99 percent destruction efficiency.

     2.   Summary of Comments

          0  99% removal of haloaens is difficult and
             beyond the state-of-the-art particularly for
             hydrogen halides other than hydrogen chloride.
             A 95% removal is suaqested as a more reasonable
             level.

          0  A single value of scrubber efficiency  f^E) is
             not appropriate for all incinerators.  It does
             not take into account large variations of the
             mass rate of haloaen emissions, and possible
             impact on health or the environment.

          0  A more cost effective regulation would be based
             on a stack emission level which would  then deter-
             mine the technology needed.

          0  A case-by-case review in the  absence of an
             absolute removal requirement  will promote
             technology development.

             Although the technoloay for  99% removal mav
             exist, EPA should establish  a base  emission  rate
             below which the control of halogens is not
             necessary.
                               -107-

-------
          *  The 0.5% halogen limit should apply to the total
             waste stream, not just the hazardous portion.

             Hydrogen chloride is much more easily removed
             than other hydroqen halides in scrubbers.   The
             chemical forms of the halogens must be specified.

          0  Provide a variance to scrubber efficiency  if the
             owner or operator can demonstrate that haloqen
             emissions will not exceed levels promulqated in
             29 CFR 1910.100  (OSHA).

          e  Establish a base level emission rate for hydroaen
             halides below which controls are not necessarv.

          "  Higher combustion temneratures for haloqenated
             aromatic hydrocarbon's make removal of hydroqen
             halides more difficult.

     3.   Response to Comments

     There are a number of undesirable gaseous comnonents which

can occur in the exhaust qas  from a hazardous waste incinerator.

To a large extent the presence of these components will depend

on the composition of the wastes which are burned; to a lesser

extent, their presence will be dictated by combustion conditions

(chiefly, temperature, turbulence, residence time, and  excess

air).  The more  common undesirable qaseous components include

sulfur oxides, nitrogen oxides, hydroqen halides  (HCL,  HP,  etc.),

carbon monoxide  (CO), and elemental haloqens.

     Since a large proportion of qaseous, liquid, and solid

hazardous wastes are organic  compounds containinq chemically

bound chlorine,  gaseous hydroqen chloride  (HCL)  is a frequently

occuring component that may be present in relatively hiah

concentration  in incinerator  exhaust gases.

     Certain scrubbers, such  as packed towers, sieve plate

scrubbers or spray tower  are  qenerally quite efficient in remov-
                              -108-

-------
ing highly soluble or readily reactive qases, such as HC1.

HC1 is very soluble in water, and if the water is made alkaline

by the addition of calcium oxide, calcium hydroxide, sodium

hydroxide, sodium carbonate, etc., the removal abilitv of the

scrubber is enhanced.

     Scrubber efficiency for HC1 removal is defined as follows:

          Eff.   =     (  HClin - HClout)   x 100
     where HClin  = Ibs. or kqs. of HC1 enterina the scrubber
                    systems, oer unit time.
           HC1out = Ibs. or kgs. of HC1 in scrubber exhaust
                    gas, oer unit time.

     In the above definition for scrubber efficiencv the term

"scrubber svstem" is used, as opposed to the word "scrubber",

since many incinerator facilities have a scrubber svstem, and

rarely have only a single scrubber.  A scrubber svstem is

usually composed of a pre-scrubber quench section (to ore-cool

the hot qases, and prevent excess evaporation of water), and one

or more scrubbers installed in a series-flow arranaement.  In

some installations, the first is a venturi scrubber which

eliminates most oarticulates and some of the acid qases.  Sub-

sequent scrubbers remove acid qases as their orimarv function.

Residual water from the quench section is qenerallv recvcled

to the quench or to one of the scrubbers.  Thus, where the term

"scrubber efficiencv" is used, the acid qas removal efficiencv

of the whole scrubber system is usually the narameter beinq

considered.  The efficiency of individual scrubber units can

be determined, but the efficiency for the total scrubber svstem

is the fundamental parameter desired.

                              -109-

-------
     Since the qases exitinq the scrubber are qenerallv cool



(>180°F), samplinq and analysis of this qas is comparatively



easy and safe.  Sampling of the hot incinerator exhaust qases



is not simple and it may be a somewhat hazardous procedure.  A



more common basis for estimating "HCl-j^" is to base this Quantity



on the waste feed rate to the incinerator and on the averaae



orqanic chlorine analysis of this feed.  This method is acceptable



for purposes of Subpart 0.  This method may sliqhtly overstate



the true HC1 content of the unscrubbed exhaust qas.  Thus, the



calculated value for scrubber efficiencv mav also be s]iahtlv



overstated.  The sources of error in using a calculated "HClin"



value are as follows:



     a.   Some chlorine may react with alkaline metal components



          of the feed, and end uo in slaa or fly-ash.



     b.   Some chlorine may exit the combustion chamber in



          elemental form (Cl2).  Chlorine is not readily soluble



          in scrubber water, but some will react with alkaline



          components of scrubber liquid to form hvpochlorites.



          The remainder will exit the system via the stack.



Scrubber efficiency calculations should, therefore, take into



account any chlorine which escapes in elemental form or as



a metallic chloride.  Stack samplina and analysis procedures



found in quidance take this into account.
                              -110-

-------
Results of Industry Inquiries and Literature Search for
  Scrubber Efficiency Data

     EPA contacted a number of operators of commercial or indus-

trial hazardous waste incinerators to obtain scrubber effioiencv

data on removal of HC1 from incinerator exhaust qases.  In addi-

tion, EPA reviewed technical literature search was made for this

type of data for full-scale (as opposed to pilot-scale) incinera-

tors.  These data, plus data obtained from plant trips, or other

sources are presented in Table 2.

     Results of recent surveys are summarized in Appendix B.
                              -1 11-

-------
                               HAZARDOUS WASTK  INCINERATOR SCRUBHER EFFICIENCY FOR HC1 ABSORPTION
 Operator  Identity and
   facility  Location
      3M  Company
  Cottage  Grove,  MI
                        Incinerator Capacity,
                               lltu/hr.          Waste Composition  Scrubber System
                                                            Sc rubbe r liquid
                               90
to
I
                          72% 1120
                       28% Solids
                       (mostly PVC)
Quench Chamber
Venturl Scrubber
Sieve Plate Tower
   Water
                                                                               Efficiency of IIC1
   99.1%
   99.3%
   Rollins  Environmental
         Services,
   Deer  Park,  Texas   	
                              100-110
                           (or  22 to 24,000
                           gpd of wastea)
                       Highly variable
                      waste compositions
Quench Chamber
Venturl Scrubber
Single-tray Absorber
   Dilute lime
      Slurry
  99.65%
(Sept.  1980
test)
    Cincinnati  Liquid/Fluid
   Industrial Waste  Disposal
   Facility, Cincinnati,  OH
                                 142
                       Variable Waste
                       Compositions
Quench Chamber
Venturl Scrubber
Sieve Plate Scrubber
   (3 plates)
    Dilute Sodium         100%
    Hydroxide (NaOll) (no HC1 de-
                     tected In
                     stack gas dur-
   	ing trial burn)
Eastman Kodak Co.
 Rochester,  NY
          90           34 different solid  Quench Chamber
(Equivalent to 9x10^   wastes and also     Venturl Scrubber
 gal. of liquid waste  varied liquid
and 6x10" solid waste, wastes, HC1 load"
  per year)            Ing Is   100-
                       200 lb. /lir.
                         Water
                     (pH control using
                          NaOH)
                                                                                                                92-97%
   Shell  Chemical Co.
                                 NA
                       Liquids (65% Cl,
                       by wt.), plus
                         some vapors
3-stage Scrubber
         Water
                                                                                                                >99%
                                    NA
                              Two similar
                           Operating units
                                               Chlorinated Hydro- 2-stngu
                                               carbon vapors
                                                            Water In first stage
                                                              Dilute NaOH In
                                                              second stage	
                                                                                                                >99%
   Shell Chemical Co.
      Norco,  1A
                                NA
                       Combined liquid
                       and vapor wastes,
                       all chlorinated
                       hydrocarbons	
3-stnge Scrubbers
 Mississippi River
water In first &
third stages, dilute
NaOH in second stage
  >99%
                                   NA
                           Tills unit has a
                           complete, normally
                           not: operated back-up
                                               Chlorinated hydro- 3-atage Scrubbers
                                               carbon vapors
                                                              Mississippi River
                                                                   Water
                                           >99%

-------
99% removal  is  infeasible,  HCI  more easily removed than other
"halogens

    Based on the  above  discussion the Aaency disagrees that a

99% removal  efficiency for  HC1_  is  infeasible.   Three of the

incinerator  tests  performed in  the OSW 1975-1976 series, where

scrubber removal was determined, all yielded removal efficiencies

of 99% or better  (5).  Additional  inquiries and literature

articles indicate  to the Aqency that 99% removal efficiency

can and is being achieved (46,47,48).

    The Agency agrees that its data is primarlv on HCI removal

in scrubbers and that other halogens including elemental chlorine

jay not be removed  to such  a high  efficiencv.   The regulation

has been modified  to clearly indicate that the 99 percent removal

efficiency applies  only  to  hydrogen chloride.

    Stack emissions should be  determined case-bv-case based

an human health impact.   The Agency aarees that a single removal

efficiency for  all  situations will allow different actual mass

emission rates of  HCI.   While it still mav be  desirable to applv

the  best control  technology available, a more precise way of

controlling  halogen emission would be  to evaluate each case based

on human health impacts.  EPA is today proposing a variance

procedure to allow evaluation and  restriction where needed of

all incinerator emissions including hydrogen halide and haloqen

emissions.   The reader is referred to the background document on

the proposed variance for a complete discussion.

    The 0.5% halogen limit should apply to total waste.  The

Agency agrees with this  point and  this was the original intent.
                              -113-

-------
The final regulation has been clarified to state that the 0.53;




limit applies only to chlorine as a portion of total waste feed.




     Variance based on OSHA.  The Agency is considering whether




Threshold Limit Values  (TLV's) on which the OSHA standards are




based can be used if appropriately modified.  The use of TLVs




to evaluate and specify emission limits is fullv discussed in




the background document for today's proposed procedure to




vary the performance standards (5264.343).




Base Level Emission Rate



     The Agency agrees  in part with the comment suggesting a minimum




emission level of hydrogen halides below which air pollution



control equipment is not needed.  Such a standard would be desir-




able.  The problems with setting such a limit are:



     1)   The impact of a specific emission rate is different




          for each incinerator.  Factors such as stack




          height, wind  speed  and direction, population distances




          and densities, etc., affect the impact on >iuman health




          and the environment.




     2)   Current data  on exposure to hydrogen halides by the




          general population  are lacking, currently onlv work




          place exposure standards have been set.




     3)   In the final  regulation? the Aaency has instead chosen




          to trigger the requirements for air pollution control



          (APC) devices by an analvsis of tbe chlorine content




          of the waste  (0.5%).  The A^C device then must meet a




          99% removal efficiency which EPA has shown to be




          readily achievable.







                                  -114-

-------
     The 0.5% chlorine content limit is derived  from  the chlorine




content of coal.  The combustion of fossil fuels, particularly




coal, results in significant discharges of HCI to the atmosphere.




Discharges of HC1 fron coal combustion (e.g., power plants) will




be many times the quantity of HC1 expected from  the incineration




of hazardous wastes.  As already mentioned, ambient exnosure




limitations for HCi have not been established exceot  for the




workplace  (OSHA).  There is no compelling rationale to base a




limit on chlorine content which is  less than coal which will




be used in massive relative quantities.  Studies have been done




which conclude that the chlorine content of American  coal ranges




from 0.01 to 0.5% and father that ^3 to °i%% of the chlorine




was emitted as HCI in a series of controlled studies  (7Q^ .




     4.   Rationale for the Final Regulation




     The Agency has decided to retain  the Q9% removal efficiency




for HCI when the waste feed contains more than  0.5% chlorine.




EPA has determined that 99% removal is state-of-the-art  ?4^'




46,47,49).  The  final standard does now clearIv  indicate that




the performance  is determined on HCi  gas and not on other hvdroqen




haiides for which the Agency has little or no data.




     The  final  regulation  differentiates among  forms  of haloqen




emissions.  Organic haloaens are addressed throuah  the destruction




and  removal efficiency equation  or  may be  designated  as  POHCs.




Other  forms of halogens, such as metallic  salts  may be not  consid-




ered a  problem  because they are  non-toxic  and/or are  usually




found  in  the  incinerator ash.



     The  proposed  regulations  included toxic  metals  in the  destruc-






                                 -115-

-------
tion efficiency requirement.  Commenters objected on the basis



that non-organic components cannot be thermallv destructed and




that 99.99 percent removal in the fly as"h and bottom is not




feasible.




     Destruction and removal efficiency could be applicable to




metals because it considers removal of waste constituents in




the emission control system.  Thus, metals which exit as parti-




culates could be controlled in this way and thus included in




the destruction and removal efficiency calculation.  However,




the Agency elected not to apply the DR^ standard to metals




in the regulation because the Agency has no test data to indicate



what specific removal levels are achievable.  The Aqencv is




requesting comment on the feasibility of establishing specific



removal limits for metals in fhe regulation.



     The Agency also considered whether metals were adequatelv




addressed through standards developed under the Clean Air Act.



The only existing standard applicable to hazardous waste incinera-




tors addresses beryllium which is controlled throuah a National




Emission Standard for Hazardous Air Pollutants (NESHAPS).  A




NESHAPS standard for mercury applies to sludae incinerators




but not hazardous waste incinerators.  A National Ambient Air




Quality Standard has been established for lead.



     For metals other than beryllium, the Clean Air Act regula-



tions are inadequate afor hazardous waste incinerators.  T^PA




is today proposing that emission limits be set on a case-by-



case basis by assessing the risk to human health.  For metals




for which EPA has developed dose response models, health effect




                                 -116-

-------
assessments  using  those  models  would  be  made.

     5.    Final  Regulatory Language

     §264.343(b) - An  incinerator  burning  hazardous  waste  contain-

ing  more  than 0.5% chlorine must remove  99%  of  the hydrogen

chloride  from the  exhaust gas.

F.    Particulate Emissions

     1.    Summary  of the Proposed  Regulation

     The  Proposed  Rules  in $250.451  included the following stand-

ard  on  emissions of particulate matter:

     The  incinerator shall be operated  in  a  manner  that
     assures that  emissions of particulate matter do
     not  exceed  270 milligrams per dry  standard cubic
     meter (0.12 grains  per dry standard cubic  foot) at
     zero excess air.   Compliance  with  this  requirement
     may  be  achieved by  having particulate emissions
     which,  when corrected to 12 percent C(>2 by the
     formula below, are  less than  1RO milligrams oer
     standard cubic meter (0.08 grains  per dry  standard
     cubic foot).
     PEC = PEm x
                       Cm x 1.5
 flhere:
     PEC = corrected particulate emissions,

     PEm = measured particulate emissions, mg/m3

     Cs  = stoichiometric CO2 concentration, ppm

     Cm  = measured CC>2 concentration, ppm

     2.   Summary of Comments on the Proposed Regulation

          0  Use of the equation given in the Proposed Rules
             to normalize the particulate emissions to a
             12% C02 concentration in the exhaust gas <. is
             desirable •

          0  Use of the particulate correction equation is
             undesirable, since it will result in allowable
             emissions greatly in excess of existing stan-
             dards .

                              -117-

-------
          0  There is a need for a comprehensive definition
             of the term "participates" with respect to "haz-
             ardous waste incinerators.

          0  Question if new source performance standard
             of 0.08 is appropriate for existinq incinerators
             which would have to be retrofitted to meet the
             standard.

          0  0.09 is too stringent for small incinerators.  It
             becomes very expensive to remove the small amounts.

          0  Clean Air Act, State Implementation Plan standards
             should be used to set particulate limits anri
             scrubber efficiencies.

          0  Incineration of explosive waste should be exempt
             from the 0.03 standard.  Instead limit Particulates
             to 50 grains per pound of explosive waste and
             auxiliary fuel.

          0  Particulates for 1000'C to l^OO'C combustion
             are primarily inorganic salts or carbon that
             are not hazardous and should not be controlled
             any more stringently than any other sources of
             particulates.

          0  Use of the proposed 0.12 grains/DSCF is much
             greater than the N.Y. State Standard ^or Cement
             Kilns (0.05 grains/DSCF).

     3.   Response to Comments

     Concentration eguation.  The Agency agrees with the commenter

who questioned the validity of the eguation in the proposed

regulation.  The equation for correcting measured particulate

emissions for CO^ concentration has been dropped in the standard.

The current regulation refers the user to Clean Air Act Regula-

tions Subpart E, 40 CFR 560.50 - 560.54, "Standards of Performance

for Incinerators."

     Definition of Particulate.  The Agency is incorporating a

particulate standard which the Clean Air Act has applied to

municipal and sludge incinerators.  The Agency tias no basis

                                 -113-

-------
for altering the definition from that used in those requlations.





     Applicability to existing or small incinerators; relation-



ships to State SIPS.  Existing incinerators including small



incinerators should be required to comply with a particulate



requirement to a minimum level.  This is important because recent



data indicate that unburned hazardous waste components mav he



emitted as particulates (72).  While the proposed case-bv-case



determination of emission limits for metals addresses this



problem, a baseline level of control is needed particularly



in the absence of the variance procedure.  Particulate emissions



are controlled under the National Ambient Air Qualitv Standards



and thus are addresssed in State Implementation Plans (SIPS).



However, incinerators below a certain size may not be addressed



in State Implementations.  Any hazardous waste incinerator should



at least meet the basic particulate standard that applies to



other (municipal) incinerators.  With current technology this



standard is easily achieved, and many States already impose far



more stringent point source emission limits.(g°)



     Incineration of explosives.  Comments regarding particulate



limits when incinerating explosives are not relevant.  Waste



explosives mav be destroyed by open burning if the provisions of



§265.382 are followed.  If so, the particulate limit will not



be applicable.  The Agency is aware of specially designed incinera-



tors which can handle certain explosives.  Should such incinera-



tors came into commercial use, the Agencv will consider the



need for a variance from the particulate standards.
                              -119-

-------
     Nature of particulates.  The comment that particulates
resultinq form 1000 to 1200°C combustion are primarilv inorqanic
salts or carbon is wrong.  Examples exist where hazardous
materials have been emitted either as oarticles or absorbed on
particles (35,36).
     The New York Standard.  The Agency aqrees with the comment
on the more strinqent State particulate standard for cement
kilns, and has indicated in the rules for State oroqrams authori-
zation that State Standards may be more strinqent than Federal
Standards but not less stringent.  Thus if a state decides to
regulate cement kilns burning hazardous wastes it is free under
RCRA to enforce a more stringent standard.
     Also, at the present time EPA has excluded cement kilns
from regulation under the Subpart 0 standards due to resource
(heat value) recovery considerations.  Thus, the final particulars
standard for incinerators burning hazardous waste are not being
applied to cement kilns.
     4.   Rationale for the final regulation
     The Aqency decided that the proposed standard for oarti-
culates should be maintained in the regulation.  Particulates from  .
hazardous waste incineration may be hazardous (72,54)^  This stan-
dard is the only national emission standard established snecifica.llv
for incineration under the Clean Air Act.  Under the Clean Air
Act it applies only to municipal and sewage sludqe incinerators.
The Agency has decided that this standard represents the minimum
level for control of oarticulates from hazardous waste incineration.
     EPA's test work on full-scale incinerators supports the use
                              -120-

-------
of the existing CAA particulate standard for incinerators (D.
Table 3 summarizes the results of that test proaram.  Eleven of
the fifteen tests achieved particulate levels siqnificantlv
lower than the standard of 180 mg/m^.  These results aranqe from
a low of 3mq/m3 up to a maximum of 113 mg/m^.  Of the three
test results which exceeded the standard, the 196 Tnq/m3 from
the cement kiln test is hiqh because of the dustinq from the
cement process.  This was not unexpected since combustion of the
wastes containinq chlorine produces HC1 and Cl2 which react
with the alkali in the cement to form volatile alkali chlorides.
The particulate loading on the precipitator is therefore increased.
Also, condensed alkali chlorides tend to he fine and possess a
different resistivity which often means that thev pass throuqh
the precipitator more easily  (87).  Althouqh this higher
particulate level occurred during these tests, the New Source
Performance Standards for cement kilns under the Clean Air Act
are in the order of 0.03 qr/DSCF and therefore far more restrictive
than the 0.08 limit in these regulations.(?0^
     The other two results (1430 and 630 mq/m3) were from the
fluidized bed incinerator tests and these also are hiqh due
to the inherent particulate problem with this type of technoloqy.
The particulates, mostly sand, comprisina the fludized bed are
quite readily carried out of  the incinerator bv the hiqh velocity
of the combustion gases.  Maintaining the solid bed contents
 is one of the major operational problems with this technology.
 This technology would not be  approved for use on hazardous waste
                              -121-

-------
                                                                  TABLE XX


                                          Summary of K1>A  Tasting of Commercial  Sea la Incinerators
N)
NJ
I
Facility
b Type

Ma i qua i dt »5)
Liquid
III jection
Surface (5)
combustion
pyiolysia


Chtiin-tioi '5)
cement
kiln

1
Waste |
Tested

Ethyl eua
C-5, 6
.„_
API sep-
parator
bottoms
Styiena
Rubber
r
Chioi i-
natert
blend
_.. j
Above
with
PCS' a
Temperature Residence
OC Time
1
! n . 	
1349-1752 10.14-0. 19 aac.
1
"" 	 T 	 ' 	
1348-1378 |0.17-0.1fl aec.
1
1
r i
760 112.5 inin.
1
1
1
r " i
650-760 |l2.5 tnin.
1
1 	
760 |l5 min.
1
	 	 r '
1450 | 5-10 aec.
1
1
r p
1450 15-10 aec.
1
r 	 ~i
Deatructioii
Efficiency
0/0

1 	 " 	 . ' 1
> 99.99
1 "
> 99.999
r
N/A
N/A
N/A
, .. .
> 99.989
1
> 99.986
Combustion
Efficiency
0/0

1 	 1
99.98
99.98
N/A
r~ " i
N/A
N/A

~
Particulates
in stack
mq/m

20-25
36-113
23-flfl
28-43
9-14
196
178
1
Scrubber
Efficiency
o/o HCL
removed

N/A
>99
N/A
N/A
N/A
-
-

-------
                                                    TABLE XX  (Coti'd)

                                Summary of EPA Tasting of Commercial  Scale  Incinerators
1







1
h-1
to
OJ
1












" - - • - j
Systems (•*•)
Technology
Fluidized
Bed

"
Zimpro ( 5 )

Wet Air
Oxidation

3M (9)
Rotary kiln

Rollins (5>



Rotary
Kiln

T~ """
Rollins I5'
Liquid Injec-
	 •--- 	 1
Phenol 1

Methyl
Methacry-
late

Coke
plant
.
Amiben •

Poly vinyl
Chloride

PCB Ca-
pacitors,
Ha mine r -
milled
PCB Ca-
pacitors ,
whole
Nitro-
•
.. 	 _(
740-757 1

	 .... i
774-788



279 107 A+M

_
281 107 A+M

870 in kiln
900-1090 in
secondary zone
1252 in kiln

1331 in after-
burn
r *
1339 in kiln
1332 in after-
burn
r~ "
1307-1332


12-14 sec.

~1
12 sec.



1.15 hi.

._._ _
1.0 hr.

1 	
2-3 sec.


3.2 sec.



3.08 sec.


2. 3

1
k > 99.999

> 99.999


	 " " '
90

. _
90

> 99.996


> 99.999



...


> 99.999


> 99.96

> 99.97



N/A


N/A

> 99.97


> 99.98



> 99.98


99.99


1280-1430

560-630



3
"

11

71


35



53


14.16

1
N/A

N/A



N/A


N/A

99.1 - 99.3









99.8

Sources:   Facility Reports numbers one through  six,  Destroying Chemical
          Wastes in Commercial-Scale  Incinerators,  EPA Contract

          Burning Waste  Chlorinated Hydrocarbons  in a Cement Kiln.
          Re{K>rt  EPS  4-WP-77-2 Fisheries and Environment Canda,  (1977).   t ^

-------
unless all performance standards could he met ((5264.343).

     The 99.99% ORE may actually provide a hiqher level of

particulate control in those cases where a desiqnated POHC is

emitted as particulate matter, since the 99.99% D*E is on a

total mass basis, which includes participates.

     5.   Final regulatory language (5264.341)

          (c)  An incinerator burning hazardous waste must not

emit particulate matter exceeding 180 milligrams oer drv

standard cubic meter  (0.08 grains per dry standard cubic foot)

when corrected for 12% Cr>2, using the orocedures oresented in

the Clean Air Act regulations, "Standards of Performance for

Incinerators", 40 CFR 60.50, Subpart E.

G.   Operating Standards/Performance Monitoring

     1.   Summary of the Proposed Regulation.  The orooosed

regulation included several operating and monitoring requirements:

     *    §250.45-l(d)(1) required that thef incinerator ooera-
          tor at minimum conditions of lOOPC, 2 seconds reten-
          tion time, and 2 oercent excess oxvgen, excent that
          wastes containing halogenated aromatics were required
          to operate at minimums of 1220°C, 2 seconds reten-
          tion, and 3 percent excess oxvqen.

          §250.45-l(d)(2)  stipulated a combustion efficiency
          of 99.99% as a continuous operating and monitoring
          requirement.

     0    §250.45-l(c) required monitoring in both trial and
          operational burns of the following parameters:

          -  Combustion temperature

             Carbon monoxide and oxyaen in the exhaust gas

             Rate of hazardous waste feed, fule, an excess

             air to the combustion svstem at minimum inter-

             vals of 15 minutes.
                              -124-

-------
         Comments•on the proposed regulation Temperature,
           retent ion timef excess oxygen

         Comments cited the EPA study on pesticide destruc-
         tion where temperatures of 500°C to 900°C were used
         to completely destroy hazardous wastes  (pesticides).
         This inidcates that 100°C is unnecessary to destroy
         some hazardous waste.

         The criteria do not account for the effects of turbu-
         lance and mixinq in the incinerator.

         The majority of existing incinerators cannot meet
         these requirements.

         The requirements of 1200°C, 2  second and 3% excess
         oxygen will cause:

         a)  excess nitrogen oxides to  be formed

         b)  equipment life to be shortened,

         Use of flame temperature as the temperature criterion
         would be more uniform in the ability to accurately
         monitor  all incinerators.

         Time-temperature criteria may  be more approoriate
         for infectious waste.

         The regulations are not worded to require that qases
         be held  at temperature for two seconds.

         Suggest  that the time, temperature and  oxygen reauire-
         ments be made a "note", i. e. , only one of several.
         ways to  demonstrate compliance.
Combustion Efficiency
         The minimum  CE  should  be  reduced  from  99.99% because
         of the  lack  of  sensitivity  in monitoring CO.
         Suggested  values  for a new  CE ranaed from  98.6%
         to 99.8%.

         Compliance with a 99.9% CE  was  unreasonable or impossi-
         ble, especially with solid  wastes.

         The formula  to  calculate  CE is  not  the same as the
         one in  the PCB  incineration regulations.

         CE should  be deleted from the regulations  for various
         reasons, as  follows:

              CE is not  indicative of incinerator nerformance,
                              -125-

-------
          Specification of CE is beyond the scone of the
          regulations,

          It is not practical to specify both CE and DE
          because it is too restrictive, and

     -    CE does not take into account the total carbon
          in the fuel and waste feed.

Monitoring Requirements

0    Continuous monitoring of combustion temperature is
     helpful in insurinq proper ooeration of incineration,
     and the temperature measurement should be taken in
     the same place and manner in operating runs as in
     trial burns.

0    It is not clear where the combustion temperature
     is to be measured.  It could be the incinerator wall,
     the combustion zone, or the flame itself.  Recommend
     that the "flame temperature" be used as the control-
     ling criteria.

*    Equipment to monitor CO and 02 continuously is expen-
     sive and is beyond the state-of-the-art for a hiqh
     temperature corrosive exhaust qas.

*    It is difficult to obtain accurate CO measurement
     in certain ranges.  Monitoring "combustibles",
     including CO will provide more accurate results.

"    Why is  it necessary to measure C02, CO and excess
     oxygen?  Why not simoly measure CO and oxyqen onlv.
     If a significant presence of CO is detected, action
     can he taken to control incomplete combustion.  The
     presence of 02 in the qas leavinq the final after-
     burner, combined with CO measurement, will provide
     ample monitoring of combustion performance.

8    Continuous monitoring of CO and O2 in exhaust qases
     is difficult and expensive, and not of sufficient
     value to make the expense and manpower needed worth-
     while.

0    Monitoring at intervals not exceedinq 15 minutes
     should be required for trial burns and dav-to-dav
     operations for combustion temoerature, CO and 02
     content of water gases, and feed rates for hazardous
     wastes, fuel and excess air feed.
                         -126-

-------
     0     Monitoring requirements for each onerational burn
          should be enlarged to include a measure of the
          destruction efficiency of the burn and the con-
          stituents of the exhaust qas.

     0     Orsat stacTc gas analysis should be nade in accordance
          with EPA method 3 - qas analysis or carbon dioxide,
          oxygen, excess air and dry molecular weiqht.

     0     Delete continuous monitoring of CO if a trial burn shows
          sufficient excess air will assure efficient combustion.

     3.    Response to Comments

          Temperature, Retention Time, Excess Air

     As  discussed under Part V of this document the Aqencv

agrees  with the many commenters who felt that the proposed

incinerator operating conditions did not provide sufficient flex-

ibility to deal with the wide range of wastes and incinerator

desiqns.  Consequently, the Aqency will no lonqer apply these

proposed requirements on a uniform, nationwide, basis.  ^he

regulations now state that these operatinq conditions will be

defined in the permit on a case-by-case basis as the conditions

demonstrated as capable of meeting a performance requirement

of 99.99% DRE.

Combustion Efficiency

     The Agency agrees that the calculation of combustion

efficiency is cumbersome for the followinq reasons:

     1.    CO-2 is difficult to accurately measure on a continuous

bas^s;  it must be sampled before the combustion qases pass

through any wet scrubbinq process.

     2.    CO? is present at some level in the input air;

     3.    The CO/CO7 dynamics are constantly chanqinq in the

combustion zone.
                                -127-

-------
     Consequently, EPA. is no  longer  requiring the maintenance




of a minimum combustion efficiency or the  calculation  of a



combustion efficiency.  Instead,  a simple  limit of carbon mon-




oxide emissions will be specified in the permit issued in




accordance with Part 122.  This  limit will be defined  from trial




burn data or from information submitted in lieu of a trial burn.



The measurement of CO, however,  is practical  on a continuous




basis and can be used as a final  monitoring chec>. on the complete-



ness of combustion.




Monitoring



     The Agency believes that continuous monitoring of combustion




conditions is necessary in order  to  monitor compliance with the




9^.99% DRE.  This is essentially a substitute for the  monitor-




ing of DRE  on a continuous basis.   However,  such HRE  monitoring




is impractical because of the complexity  (and cost) of the




sampling and anlysis required.   Consequently,  combustion




conditions associated with that  performance will be determined



during the trial burn, specified  in  the permit, and monitored




to determine compliance.  Monitoring of such  conditions is both



technically and economically  feasible  (23, 25,35,50,*1,52,53^ .




Temperature Monitoring



     From an operational viewpoint,  incinerator temperature is




the most important and easily determined indicator of  the




stabililty of hazardous waste combustion and  destruction.  ^PA.



definitely agrees with tne comment that combustion zone tempera-




ture measurements should be taXen in the same place and manner




in operational runs as in trial  burns.






                                  -128-

-------
     The precise location of temperature indicating devices

in the combusiton chamber of  an incinerator is a matter that

the EPA feels should be specified on a case-by-case basis by

the permitting official.  All three possible locations mentioned

by the commenter could be satisfactory as long as thev were

kept constant for both trial and operational burns and showed

a reasonable relationship to incinerator performance.  Some

operators install temperature indicating devices at more than

one location in an incinerator combustion chamber.  Contrary

to the comment regarding the difficulty and reliability of

temperature indication in a hot, corrosive environment such as

one containing halogens or hydrogen halides, a thermocouple

based on, for example, platinum/platinum-10% rohdium is accurate

and reliable (5>.

CO, CO?, 02 Monitoring

     The Agency disagrees with the comraenters who suggested that

CO monitoring is difficult, expensive, or technically infeasible.

The Agency feels that CO monitoring is feasible, practical,

and necessary for the following reasons:

     0    CO concentration in the exhaust gases is a nood indi-
          cator of the completeness of combustion.  Carbon
          Monoxide was monitored during the ^PA test burns
          with no significant difficulty and results were used
          to compute combustion efficiency  ' %fi4, 66, 6Q, 711 __

     0    Well developed, reliable and rugged instrumentation
          exists that can measure the concentration of CO in
          exhaust gases in a range from a very few parts-per
          million to a  100% basis  (49).

     0    Response time of the equipment is rapid  (l-^O) seconds,
          (depending on instrument) C^4'^5).

     0    Measurement of CO maintains its meaningful ness as an


                                 -129-

-------
          indicator of the completeness of combustion as the
          excess air is lowered toward stoichiometric, or as
          combustion temperatures are lowered.

     0     Instrumentation does not need to be mounted in the
          gas stream, and a non-sampling, non-contactinq
          methodology for measuring the CO content of a flowing
          gas stream can be utilized (49,54,55).

     0     The cost of the instrumentation (roughly $1500 - $3^00)
          is normal, considering the capital required to build
          a complete hazardous waste incinerator (56).

     The comment that "combustibles" in the exhaust gas should

be monitored because this measurement would produce more accurate

results than monitoring CO alone, is infeasible for several

reasons.  First, as noted above, CO monitoring instruments of

acceptable accuracy are readily available.  Second, EPA has not-

been able to identify a reliable, off-the-shelf instrument for

measuring total combustibles in the gas to the accuracv and

concentrations required (although instruments are available for

measuring gaseous combustibles)  (14).  Third, and most important,

EPA considers that data on the CO and particulate content of

exhaust gas, together with data on the combustion temperature,

and air flow rate provide an adequate indication of the deqree

of completeness of combustion of most organic wastes.  A qeneral

requirement for monitoring exhaust gas combustibles other than

CO is therefore unnecessary.

     With respect to comments recommending one set of parameters

monitored during a trial burn, and another set durinq opera-

tional burns, the same parameters should be monitored durinq

trial and operational burns, in order to insure comparahilitv.

There are no compelling reasons  to use different parameters.
                              -130-

-------
     A comment suggested that any monitoring of CO-> should be


at a point upstream of any scrubber due to the solubilitv of

                                             o
CO.., in water.  The Agency is not requiring CO  monitoring in


the regulation.


     In order to ensure that the incinerator is achieving a


99.99% DRE, monitoring of combustion zone temperature and of Co


is necessary whether or not sulfur, nitrogen or halogens are


elemental components of the waste being incinerated.  Similarly,


monitoring of waste feed rate, fuel, and total air  ^eed to an


incinerator in both trial and operational burns is  necessary


since these parameters are a requisite to establishing stable


operating conditions, and to assuring that the destruction and


removal efficiency is achieved.


     The comment that NOX, SOX, and CO^ be added  to the list of


monitored gases will not be followed.  The Agency is attempt-


ing to minimize monitoring requirements and only  specifv


those that have an impact on the destruction of hazardous com-


pounds in the incinerator.  *TOX can be an important pollutant


if many combustion sources are found in anv area, but it is


of secondary interest in the combustion of many highly toxic


or carcinogenic hazardous wastes.  The risk from  potential


emissions of these compounds, unburned or partially burned,


far exceeds the small addition to ambient NTOX  from  an incinera-


tor.  Further, NOX as well SOX is a criteria pollutant subiect


to the National Ambient Air Quality Standards  under the Clean


Air Act, and should be adequately controlled throuah those


standards.
                                  -131-

-------
     C02, as discussed in the section on CO monitoring, will



be absorbed to a significant degree through scrubbing, and thus



monitoring in the stack would be of little value.  If Orsat



stack gas analysis were used for CO monitoring then EPA Method



3, Gas Analvsis for Carbon Dioxide, Oxygen, Excess Air and Drv



Molecular Weight, should be used (52).  However, EPA doubts



that such a labor-intensive analyzer would be useful where



frequent analyses are needed, and good accuracy  is reguired



for low CO values.  The intent in continuous CO monitorinq is



to provide a rapid response readout to detect incinerator upset



conditions quickly and start either immediate remedial control



actions or a shutdown.



     EPA does not agree that CO monitoring should be deleted if



it can be shown during a trial burn that excess air will assure



99.99% ORE.  Such a change would not be in keening with KPA's



rationale for requiring continuous carbon monoxide monitorina.



EPA has determined that CO monitoring of the exhaust gases is



the simplest, most reliable method of detecting chanaes in inciner-



ator combustion conditions (i.e., temperature, excess air rates,



waste feed rates) which directly and immediateIv affect the



quality of the emissions of the incinerator.  Also it should he



pointed out that CO monitoring will immediatelv detect problems



with deficiences of air in the combustion process.



     4.   Rationale for the Final Regulation



     The regulation, in §264.343, establishes oerformance require-



ments for incinerators based on achieving a destruction and
                              -132-

-------
removal  efficiency (DRE) of 99.99% for both the principal orqanic



hazardous  constituents (PHOC's) in the waste and hazardous com-



bustion  by-products.   The Agency has adopted performance standards



in preference to soecification of national standards for onerat-



ing conditions such as temperature, retention time, and excess



air.   The  rationale for this decision is provided in oaragraoh



3 above  and in Part V of this document.



     However, the destruction and removal efficiency cannot he



monitored  on a continuous or frequent interval basis, because



the complexity, laq time for analysis, and cost of continuous



sampling and analysis required to determine the precise amounts



of POHCs and combustion by-products in the feed to, and exhaust



gas from,  the incinerator.  Because of this, it is necessary



to determine in the trial burn the critical operatino conditions



associated with meeting of this standard, to specifv limits



on those conditions in the permit, and then to monitor and



and enforce those operating conditions.



     EPA does reserve the right to verify the DRE directlv hv



direct sampling and analysis of the feed stream, residues and



the exhaust gas at any time durina normal operation.  This



enforcement monitoring  is expected to occur infrequently,



probably on a yearly basis.  However, if the Aaencv has sufficient



 reason to suspect that  an incinerator is not achieving the



 performance standards as specified in the permit, than more



 frequent sampling and analysis may be required.



     Continuous monitoring of  combustion conditions  is necessary



 and is both technically and economically feasible.   From  an






                               -133-

-------
operational viewpoint, incinerator temperature is an important




and easily determined indicator of the process integrity.  The



instruments (or other devices) which measure the combustion




conditions (temperature, excess air, etc.) should be monitored




and operational corrections made often continuously and automati-




cally where possible.  The relevant parameters on which the




combustion conditions depend, in most incinerators include waste




feed rate, auxiliary fuel, can lead to poor combustion conditions




and to emission of incompletely burned wastes.  Some facilities




already have some of these control looos  (temperature controll-



ing auxiliary fuel flow, for example) operating on a continuous



basis.  In fact, the available literature indicates that it



is not unusual to find continuous monitorinq  O « !9-» 1Q» ?3, ?%




36,49).  A number of highly accurate, continuouslv indicating




instruments are available for CO, CO?, and O, in exhaust qases



(50,5i,52)%  The technigues for using these instruments are




relatively simple, they are off-the-shelf items, and they are




not unduly expensive.



     The Operating Reguirements  ($264.345) which have been




specified in the regulation as critical to determining incinerator




performance are largely the same as those proposed.  The rationale




for selecting each is presented below:




CO level on the stack exhaust gas



     EPA will no longer reguire the maintenance o* a uniform




minimum combustion efficiency.   Instead,  a limit of carbon



monoxide emissions will be specified in the permit on a case-by-




case basis.  This limit will be determined from trial burn data





                                 -134-

-------
or from information submitted in lieu of a trial burn.

     The measurement of CO has been selected as a aporooriate

combustion-control parameter for the following reasons:

          CO concentration in the exhaust qases is a aood indi-
          cator of the completeness of combustion.

          Well develooed, reliable and ruqqed instrumentation
          exists that can measure the concentration of CO in
          exhaust qases in ranqe from a very few parts-ner-
          million to a 100% basis
          Response time of the equipment is rapid, 1-90 seconds,
          (dependinq on the instrument) (54,55).

     8     Measurement of CO maintains its meaninqf ulness as
          an indicator of completeness of combustion as the
          excess air is lowered toward stoichiometric, or
          as combustion temperatures are lowered.

     0     Instrumentation does not need to be mounted inside
          the qas stream, and a non-samplinq, non-contractinq
          methodology for measurinq the CO content of a flow-
          ing qas stream can be utilized (49, 54, 55) ^

     0     The cost of the instrumentation (S1500 - S3nnO) is
          nominal, considerinq the capital reauired to build
          a complete hazardous waste incinerator (56).

     Some continuous indicator of the combustion oerformance of

the incinerator is essential.  Combustion performance (like CO

level)  depends on operatinq parameters such as temnerature,

feed rate of waste, and air flow rate, but monitorinq those

operatinq parameters does not indicate what is actuallv beinq

accomplished in the incinerator.  Monitorinq CO levels in emissions

does give a continuous  (and almost instantaneous) assessment of

effectiveness of combustion.

     The Agency considered whether CO could be used as a sole

indicator for compliance with the ORE requirements, but reiected

this ootion.  Determination of a precise quantitative relation-
                              -135-

-------
ship between CO level and DRE under various brun conditions is

not feasible.  A literature review presented here illustrate

the wide range of CO values for different processes.

     CO Level,
pprn, in Exhaust Gas                      Source

     30-40               Most coal-burning utilitv boilers  ^3)

     > 1                 Commercial "hazardous waste
                         incinerator  \74)

     5-50                Trial burns of miscellaneous
                         hazardous waste several
                         test facilities (5,75)

     0-5200              Pilot plant test data  f-7fi)

     Thus, the final regulations specify both monitoring of

key operating conditions and monitoring of CO as in indicator

of incinerator performance.  The acceptable range of CO will

be determined from the trial burn.  A range will be soeci^ied

in the permit conditions based on the CO levels durina the trial

burn.  In this way, the range will be relevant  to the nerfornance

standards.

     Although monitoring of CO is more convenient in an exhaust

stack  (where teiroeratures are low) , measure of  CO at other points

within the system  (for example, in the take-off ducting im-

mediately after i_he combustion chamber, or afterburner) are

also acceptable.

Waste Feed Rate

     As stated above, waste feed rate is one of the critical

control parameters on which combustion conditions denend.   In-

cinerators are designed for a certain capacity, or total heat

input.  A feed rate of waste and fuel which exceeds the heat
                                 -136-

-------
capacity of the incinerator will generally result  in  incomplete




combustion.  The capacity limits, are directly  related to the




feed rate of the waste, the heating value of the waste, the




amount and heating value of auxiliary fuel, and the amount of




air fed.  Thus, the achievement of a Q9.<*9% DR^ will  be dependent




on the feed rate and it's relation to the other parameters



mentioned above.




Combustion Temperature




     Destruction efficiency is closely linked to combustion




temperature as discussed above.  This temperature  is  such a




critical and commonly accepted condition affecting incinerator




performance that the proposed regulations specified a minimum




temperature for burning all wastes.  It will now be set on a




case-by-case basis.




Air Feed to the Combustion System




     In order for combusiton to be complete there  must be suffi-




cient oxygen present to complete the oxidation of  the waste.  The




exact quantity required is referred to as "stoichiometric"




quantity.  Excess air (above the stoichiometric quantity,^ is




used to ensure adequate oxidation.  This parameter was also




specified in the proposed regulations.




     For an incinerator volume and configuration the  specification




of air feed rate and waste feed rate together define  the retention




time of waste in the combustion system, a parameter defined in




the proposed regulations but no longer uniformly required.




Instead, EPA is requiring case-by-case specification  of air feed




rate in the permit, based on the results of the trial burn.
                                 -137-

-------
Variation in Waste Composition




     The conditions (ranges) of temperature, waste feed rate, and



air feed rate required to achieve 99.Q93; DRF will be established




on a waste-by-waste basis, or on the basis of different waste




mixtures.  However, the feasibility of this approach depends




on being able to define ranges of waste composition that remain




subject to these same requirements, since waste feed compositions




cannot be expected to remain absolutely constant.  Composition




may change either because the concentration of principal ha-




ardous components in a given waste change or because different




"new" components are introduced through blendinq or mixing of



wastes.  Given conditions of temperature, waste feed, and air




feed should insure 99.99% DRK for a range of waste compositions.




Establishing this range will require the engineering judgement




of the permittinq official.  The guidance provided in the "Permit



Writer's Guidelines for Hazardous Waste Incinerators" will aid




in this  judgement.



     Importantly, the permit applicant also has significant




control  over these ultimate ranges.  If the applicant conducts




trial burns for wastes or waste mixtures which are very difficult




to destruct, for example haloqenated aromatic compounds, the




acceptable range of waste composition which can be burned at




those conditions may be relatively broad.  The trade-off from




the standpoint of the owner or operator is that he can incinerate



a broader range of waste composition at the conditions established




in the permit, if he is willing to operate at relatively strinqent



conditions.  In practice, owners or operators who burn a wide
                               -138-

-------
range of wastes or waste mixures are likely to want to conduct




trial burns and establish operating conditions for two or more




different groups of wastes, ranging from those which are difficult




to burn to those which combust relatively easily.




Incinerator Design and Operating Changes




     The permit will be written based on results of trial burn(s),




or data submitted in lieu of a trial burn and will be applicable




to the configuration of incinerator hardware used to gather




the data.  Changes to the hardware of the system could result




in different results even when burning  similar hazardous wastes.




Since the DRE is not monitored continuously during nornai day-




to-day operation, and since modifications to the incinerator




could result in failure to meet the DRE, permit conditions will




include provisions related to possible  significant system design




and operation factors.




     Examples of changes which could affect the r>RE include:




     1.   A change in the design of a liquid injector nozzle




          to reduce clogging could also change the mixing




          characteristics of the wastes and combustion air




          and potentially  reduce HRE.




     2.   A change in the  incline or speed of rotation of a




          rot-ary kiln can  greatly affect the time  for which




          solid materials  are retained  in the kiln and thus




          their exposure to the temperatures required to




          destroy them.



     3.   Movement of temperature sensing probes  to  a different




          location in the  incinerator which could  affect  the
                                 -139-

-------
          apparent temperature reading.  This chanqe could

          allow an incinerator to run at a lower real temoera-

          ture when instrument readouts were within the permit

          conditions.

Changes resulting from normal maintenance will not normallv he

included e.q., replacement of refactorv lininqs.

     5.   Final Regulatory Language

§264.345  Operating Requirements

     (a)  An incinerator must be operated in accordance with

operating requirements specified in the oermit.  These will he

specified on a case-by-case basis as those demonstrated (in a

trial burn or in alternative data as specified in S264.3d4(h)

and included with Part B of a facility's permit application) to

be sufficient to comply with the performance standards of (52*4.343.

     (b)  Each set of operating requirements will specify the

composition of the waste feed (including acceptable variations

in the physical or chemical properties of the waste feed which

will not affect compliance with the performance requirement of

§264.343) to which the operating requirements apply.  For each

such waste feed, the oermit will specifv acceptable operatina

limits including the following conditions:

          (1)  Carbon monoxide (CO) level in the stack exhaust aas;

          (2)  Waste feed rate;

          (3)  Combustion temperature;

          (4)  Air feed rate to the combustion svstem;

          (5)  Allowable variations in incinerator svstem desiqn
               or operating procedures; and
                              -140-

-------
          (6)   Such other operating requirements as are neces-
               sary to ensure that the Performance standards
               of §264.343 are met.

     (c)   During start-up and shut-down of an incinerator,

hazardous waste (except ignitable waste exempted in accordance

with §264.340) must not be fed into the incinerator unless the

incinerator is operating within the conditions of operation

(temperature,  air feed rate, etc.) specified in the permit.

     (d)   Fugitive emissions from  the combustion zone must be

controlled by:

          (1)  Keeping the combustion zone totally sealed
               against fugitive emissions; or

          (2)  Maintaining a  combustion  zone pressure  lower
               tha atmospheric pressure; or

          (3)  An  alternate  means  of  control demonstrated
                (with  Part B  of the permit  application)  to
               provide fuaitive emissions  control  equivalent
               to  maintenance  of  combustion  zone  pressure
                lower  than atmospheric pressure.

      (e)  An  incinerator  must  be  operated  with  a  functionina

 system to automatically  cut  off waste feed to  the incinerator

 when  operating conditions deviate from  limits  established

 under paragraph (a)  of this  Section.

      (f)  An  incinerator must cease  operation  when changes in

 waste feed,  incinerator  design,  or operating conditions exceed

 limits designated  in its permit.

 §264.346  [Reserved]

 §264.347  Monitoring and Inspections

      (a)  The owner or operator must conduct,  as a minimum, the

 following monitoring while incinerating hazardous waste:
                               -141-

-------
          (1)  Combustion temperature, waste feed rate, and air



               feed rate must he monitored on a continuous



               basis.



          (2)  CO must be monitored on a continuous basis at a



               point in the incinerator downstream of the



               combustion zone and prior to release to the



               atmosphere.



          (3)  Upon request by the Regional Administrator,



               sampling and analysis of the waste and exhaust



               emissions must be conducted to verify that the



               operating requirements established in the Permit



               achieve the performance standards of 5264.343.



     (b)  The incinerator and associated equipment (numos,



valves, conveyors, pipes, etc.) must be completely inspected at



least daily for leaks, soills, and fugitive emissions.  All



emergency waste feed cut-off controls and system alarms must



be checked daily to verify proper operation.



     (c)  This monitoring and inspection data must be recorded



and the records must be placed in the operating log required



by §264.73.



§§264.348 - 264.350   [Reserved]



H.   Operating Practices - Preheating of Incinerators



     (See discussion in interim status standards.)
                              -142-

-------
I.    Operating practices - fugitive emissions

     1.    Summary of proposed regulations

          The proposed regulations required in 5250.45-1(d)(4)

     that  fugitive emissions of unburned hazardous waste and

     combustion products be controlled.

     2.    Comments on the proposed regulations

             The primary combustion chamber should be monitored
             to insure negative pressure and thus prevent leakaae.

             The regulations should be stated as an achievable
             practical technology.

             Emissions are already regulated under the Clean
             Air Act.   The regulation violates the conaressional
             mandate to avoid duplication.

             Fugitive emissions cannot be eliminated.  Sources
             of fugitive emissions are:

             a.   Tank vents,

             b.   Maintenance disassemblv.

             c.   Pump seals that often requie that a definite
                  leak rate be maintained.

             d.   Purging of equipment for repairs,

             e.   Burner observation ports.

             f.   Rotary kilns must have openings to permit
                  thermal expansion and to allow cool air to
                  protect the metal retaining rings.

     3.    Response to Comment

     The definition of fugitive emissions (see definition Sec-

tion) illustrates the difficulty of measurina these from

typical  installations.  They originate from other than stacks

or vents.   Thev exit through holes, faulty seals, etc.  The  regula-

tory solutions proposed are therefore intuitively founded.   It
                              -143-

-------
is clear that a sealed combustion zone will control fugitive



emissions.  Similarly, in those cases where sealinq is not



possible, e.g. rotary kiln, maintaining a pressure in the com-



bustion zone which is lower than that outside (i.e., negative



pressure) will reduce emissions to the maximum practical extent.



Even though sudden surges in air flow can still cause fugitive



emissions (25), the Agency knows of no other solutions



which can insure that fugitive emissions are eliminated.



     A specific regulation, e.q., maintain 3 inches of water



negative pressure, is not possible because of the difficulty of



measuring small pressure differentials at high temperatures (77).



Additionally, maintaining a negative pressure mav not be appli-



cable to certain types of facilities.  For example, it mav



be  more appropriate to require a sealed burning zone in the



case of fluidized bed incinerators, which operate under positive



pressure.



     EPA agrees that all fugitive emissions cannot be completely



eliminated from incinerators and associated operations.  How-



ever they can be minimized.



     Maintenance, purging, etc., can be accomplished using



auxiliary fuel with hazardous waste input to the system shutof^.



     4.   Rationale for the final regulation



     Control of fugitive emissions from hazardous waste incinera-



tion is important because those emissions - which typically are



emitted from the combustion chamber - can contain cmantities



of the hazardous waste being burned or hazardous combustion



by-products (1).






                              -144-

-------
     The Agency realizes that fugitive emissions of hazardous
materials from the operation of an incinerator cannot be totally
eliminated.  Tank vents, leaks, pump seals, maintenance work,
and other associated operations are the source of manv fugitive
emissions.  However, the Agency in this regulation is concerned
with the hazards from the escape of incompletely burned gases
from the combustion zone of the incinerator, and feels that some
control is necessary.
     One solution to the problem of fugitive emissions is to
require that the incinerator operate at a negative pressure
(i.e., less than atmospheric).  This would minimize leakage from
the unit.  In fact, many incinerators do operate in this manner,
but sudden pressure surges can still cause fugitive emissions
(25).
     A second solution for systems which are not or cannot
be operated with a negative pressure, is to seal all leaks in
the combustion zone.  This may not be practical in all cases.
     In the final regulations the Agency has stated that incin-
erators may operate under a negative pressure, operate with a
sealed system or may use a system to control fugitive emission
which in the Administrator's best judgement will eliminate fugitive
emissions or reduce them to levels equivalent to negative pressure
controls.
     5.   Final regulatory language
§264.345
     (d)  Fugitive emissions from the combustion zone must be
controlled by:

                              -145-

-------
          (1)  Keepinq the combustion zone tota3.lv sealed

               aqainst fuqitive emissions; or

          (2)  Maintaininq a combustion zone pressure lower

               than atmospheric pressure; or

          (3)  Alternate means of control demonstrated (with

               Part B of the permit application) to provide

               fuqitive emissions control equivalent to main-

               tenance of combustion zone pressure lower than

               atmospheric pressure.

J-   Operating Practices— Automatic Cutoff

     1.    Summary of proposed regulations

          The proposed regulations required in  $250.45-1 (d) ("*)

     that an incinerator be equipped with a device to automati-

     cally cutoff waste feed when significant chanaes occur in

     critical operating Parameters.

     2.    Comments on the proposed regulations

          Comments received on 250.45-1(d)(3 ) are summarized as

     follows:

          0  EPA should require cutoff onlv of  the toxic waste
             stream but allow auxiliary fuel to keep firing
             the incinerator if desired.  This  recoqnizes that
             the fuel stream may be fuel oil or low-toxicitv
             material.

          0  The automatic cutoff should be based on significant
             changes in combustion efficiency, destruction
             efficiency or other combustion conditions.

          0  The "significant changes" are not defined relative
             to waste feed cutoff.

          0  The wording of the proposed cutoff standard defeats
             and eliminates the possibilitv of  asinq wastes-as-
             fuel.
                             -146-

-------
             It may be inadvisable to cutoff waste feed instan-
             taneously.  Instead, alarms should he used and
             not waste feed cutoff.  Leave the details of how
             to correct combustion conditions to the operator.

             EPA should exempt "low-toxicity" wastes from the
             cutoff procedure.

     3.    Response to Comments

     EPA agrees with the comment that the cutoff nrovision should

apply only to the hazardous waste stream and not necessarily to

a non-hazardous auxiliary fuel stream.  This approach was intended

to be followed in the proposed regulation 250.45-l(d) (3).  Bv

allowing continued or increased feeding of auxiliary fuel during

the cutoff of the hazardous waste feed, the incinerator will

not be subjected to rapid changes in temperature.  Thus,  two

purposes are served:  (1) maintenance problems associated with

thermal  expansion/contraction cycles of refractory lininqs will

be averted, and (2) ooerating problems which triqqered cutoff

of the hazardous waste stream can possiblv be corrected without

necessity for an expensive and time-consuming shut-down and

subsequent start-up.

     The Agency agrees in part with the comment that the  waste

cutoff should be based on changes in combustion efficiency,

destruction efficiency or other combustion conditions.  Adverse

changes  in combustion parameters such as temperature and  carbon

monoxide (CO) content of exhaust gases should triqger a waste

cutoff,  but so should other non-combustion problems such  as

break-downs in scrubber operation or in other air pollution

control  devices.  However, it should be realized that changes

in ORE cannot be shown until suitable analytical data are avail-
                              -147-

-------
able, which may be hours or days after an upset.  Therefore,



the use of ORE for this purpose is not practical.  Further,



for reasons discussed elsewhere in this document the Aqency has



decided not to utilize the concent of combustion efficiency,



but will base its judqement of stable combustion conditions on



the continuous monitorinq of CO in the exhaust qas.



     In the final regulation, the selection of the operatinq



parameters and the extent of any "s iqnif icant chanqes" in them



which will trigger the shut-down of the waste feed will be made



by the permit writer.  Also, the results of any trial burns



are expected to supply data to help in specifying the degree



of operatinq changes which will require an automatic shut-down.



Guidance is included in the "Permit Writer's Guidance Manual"



on ranges of waste properties, operatinq parameters and other



factors to aid the permit writer.



     The Agency does not aqree with the comment that the oronosed



regulation would eliminate the use of wastes as fuel.  First,



the burning of hazardous waste primarily for recovery of enerqv



is currently exempted from the RCPA standards.  Second, if a



high BTU waste were being burned in a permitted incinerator



to offset the low heating value of another waste, it would he



subject to the cutoff requirement.  However, a conflict between



energy recovery and environmental orotection is not a necessary



or inevitable part of the RCRA regulations.



     EPA agrees with the comment that an instantaneous cutoff



of waste feed in some cases, may not be the best operating



procedure.   In many incinerator operations the cutoff provisions






                              -148-

-------
may in reality be a phased approach with adequate warninq to



the incinerator operator before the activation of an automatic



cutoff valve.  It would seem prudent to provide an alarm on



the controllinq instruments to warn the operator that an ooerat-



ing parameter has gone out of the allowable range.  This alarm



would allow a reasonable amount of time for the ooerator to



attempt to correct the condition and/or provide time to brinq



up the feeding of auxiliary fuel before the automatic svstem cuts



off all waste feed.  The specification of these alarms and



the procedures and times allowed to respond before shut-down,



will be determined on a case-bv-case basis relying on the



judgement of the permit writer.



     The Agency agrees in part with the suggestion that some



wastes which are of "low toxicity" mav be exempted from the



cutoff procedure.  Wastes which are hazardous due only to their



ignitability are exempted from the final incinerator reaulation.



     In developing the final regulation the Agency has develooed



language which allows the permit writer to specify procedures



which must be taken in the event an incinerator parameter(s)



exceeds the range of value(s) specified in the permit.  Automatic



cutoff of hazardous waste feed is the primary shut-down procedure



but other types of procedures mav also be effective in protect-



ing human health and the environment.  These may either reolace or



modify automatic feed shut-off or affect some other operatina



parameter in an emergency situation.  The engineering ludqement



of the permitting official will determine what these procedures




must be.



                              -149-

-------
     4.   Rationale for the final regulation



     EPA believes that the waste cutoff systems to the incinerator



should be activated based on changes in critical combustion



conditions.  Changes in combustion parameters such as temperature



and carbon monoxide (CO) content of exhaust gases should trigger



a waste cutoff, but so should other combustion problems such



as break-downs in scrubber operations or in other air pollution



control devices.  However, changes in ORE cannot be proven until



suitable analytical data are available, which may be hours or



days after an upset.  Therefore, monitoring of DRE cannot be



used directly to trigger shut-down.



     The results of anv trial burns are expected to supplv



data to help in specifying the degree of operating changes



which will require an automatic shut-down, e.g., temperature



range for complete combustion.  In many incinerator operations



the cutoff provisions may in reality be a phased approach with



adequate warning to the incinerator operator before the activation



of an automatic cutoff valve.  It would seem prudent to provide



an alarm on the controlling instruments to warn the operator



that an operating parameter has dropped out of the allowable



range.   This alarm would provide a reasonable amount of time



for the operator to attempt to correct the condition and/or



provided time to activate the feeding of auxiliary fuel before



the automatic system cutoff of all waste feed.  This phased



approach can be used as long as no toxic or hazardous components



are discharged out of the stack i.e., DRE is not violated.  Bv



allowing continued or increased feeding of auxiliary fuel during






                              -150-

-------
the cutoff of the hazardous waste feed, the incinerator will



not be subjected to rapid chanqes in temperature.  Thus, two



purposes are served:



     (a)  maintenance problems associated with thermal expan-



          sion/contraction cycles of refractory lininqs will



          be averted, and



     (b)  operating problems which triqqered cutoff of the



          hazardous waste stream can possibly be corrected



          without the necessity of an expensive and time-



          consuminq shut-down and subsequent start-up.



     In developing the final regulation the Agency has develooed



guidance which allows the permit writer to specify procedures



which must be taken in the event an incinerator Parameter(s)



goes outside the range of value(s) specified in the oermit of



hazardous waste feed.



     Automatic cutoff is the primary shut-down procedure but



other types of procedures may also be effective  in protecting



human health and the environement which either replace or modi-fv



automatic feed shut-off or effect some other operating parameter



in an emergency situation.  Table 4 presents a summary of resoonses



to system malfunctions.
                              -1 51-

-------
                                                      TABLE 4

                                   HAZARDOUS WASTE INCINERATOR MALFUNCTIONS,  AND
                                          REMEDIAL OR EMERGENCY RESPONSES
   Nb.
Malfunction
     Type
Incinerator*
    Malfunction
    Indication
                                                                                             Response
          Partial or conplete stoppage
          of liquid waste feed delivery
          to all liquid burners:
                               L
                               C
          Partial or conplete stoppage
          of liquid waste to only one
          burner.

          Partial or complete stoppage
          of solid wastes feed to rotary
          kiln.
                               L
                               C
                              RK
                               C
              (a)
    Flow meter readings out
    of specified range.
(b)  Pressure build-up in
    feed lines
    Change in conbustion
    zone temperature
    Feed pump failure,
    zero amps.
                                                              (c)

                                                              (d)
              As in (a),  (b)  and (c),
              above
              (a)  Drop in RK combustion
                  temperature
              (b)  Power loss in waste
                  feed conveyor or other
                  feed system.
Halt waste feed, start
trouble-shooting and
maintenance in affected
systems.  Reinitiate or
increase auxiliary fuel
feed to maintain com-
bustion zone temperatures;
continue operation of air
pollution control devices
(APCD)

Halt waste feed to
affected burner, only.
                              As  in 1, above
*L = Liquid injection;  RK = rotary kiln;  C = Combination liquid injection and rotary kiln.
                                                           -152-

-------
                                     TABLE 4 (Continued)
ISb.
feIfunction
    Type
Incinerator*
Ma3. function
Irdication
Response
      "Puffing", or sudden occur-
      ance of fugitive eoissions
      from RK due to thermal
      instability or excessive
      feed rate of wastes to RK,
      or faij-ure of seals.
                              RK
                               C
      Failure of forced aix"
      supply to liq. waste feed
      or fuel burners
                               L
                              RK
                               C
             (a) Pressure surge in kiln
                 (rapid change in mano-
                 meter level)
             (b) Visible emission from
                 air seals at either end
                 of kiln
             (a) Flowmeter reading for
                 air supply off scale
             (b) Automatic flams detector
                 alarm activated.
             (c) Zero artps. or excessive
                 current draw on blower
                 nr)tor(s)
                          (a) Halt feedinq of
                              any solid waste to
                              kiln for 10-30 min,
                              but continue com-
                              bustion.
                          (b) Evacuate unneeded
                              personnel from
                              immediate vicinity
                              of kiln
                          (c) Reevaluate waste prior
                              to further incinera-
                              tion.

                          (a) Halt waste and fuel
                              feed immediately.
                          (b) Start trouble shoot-
                              ing immediately and
                              restart as soon as
                              possible.
                          (c) Continue operation
                              of APOD's but reduce
                              air Sow at induced
                              draft fan by "damping"
                              accessory.
                                                       -153-

-------
                                    TABLE 4 (Continued)
No.
Malfunction
    Type
Incinerator*
Malfunction
Indication
Response
      Ccntoustion temperature
      too high
                               L
                              RK
                               C
             (a) Temperature indicator(s)
                 at instrument control
                  panel
             (ta) Annunciator,  or other
                 alarm sounded.
      Coribustion temperature
      too low
                               L
                              RK
                               C
             (a) - as above
             (b) - as above
                          (a) Check fuel or waste
                              feed flow rates;
                              reduce if necessary.
                          (b) Check temperature
                              sensors.
                          (c) Check other indica-
                               tors in combustor,
                               if multiple sensors
                               used.
                          (d) Automatic or manual
                              activation of combus-
                              tion chamber vent
                              (sometimes called
                              an "emergency stack
                              cap")

                          (a) Check other indica-
                              tors in combustor,
                              if multiple sensors
                              are used.
                          (b) Check fuel or waste
                              feed flow rates;
                              increase if necessary
                          (c) Check sensor accuracy.
                          (d) Cease waste feed flov.
                                                    -154-

-------
No.
                         Malfunction
                                           Type
                                       Iticinerator*
    Ma]function
    Indication
             Sudden Loss of Integrity
             of Refractory lining
                                           L
                                          RK
                                           C
             Excess opacity of stack
             plume
 I
M
Ul

I
                                           L
                                          RK
                                           C
       10
CO in exhaust gas in excess
of normal CO values.
(a) Sudden loud roise
(b) Partial stoppage of
    air drawn into com-
    bustor, resulting in
    decreasing combustion
    temperatures, increased
    particulate emissions,
    and development of hot
    spots on external of
    corribustor shell.

Visual, or instrument
opacity readings Which
are above maximim allowable
operating point.
                                                                 CO indicator
                                                                                         Response
                                                                                        Shut down facility as
                                                                                        quickly as possible,
                                                                                        immediately cease waste
                                                                                        feed flow, secure feed
                                                                                        lines against leakage.
                                                                                        (a) Check combustion
                                                                                            conditions,  espe-
                                                                                            cially temperatures
                                                                                            09 (excess air)  and
                                                                                            Co monitor.
                                                                                        (b) Check APCD operation
                                                                                        (c) Check nature and
                                                                                            feed rates of wastes
                                                                                            being burned
                                                                                        fd) Check ESP rapping
                                                                                            interval, cycle
                                                                                            duration and in-
                                                                                            tensity.
                                                                                  Check and adjust  com-
                                                                                  bustion conditions,
                                                                                  especially temperature
                                                                                  and excess air  (O? in
                                                                                  stack gas),  and adjust
                                                                                  accordingly.

-------
                                            TABLtf 4 (Continued)
        Nb.
        11
            telfunction
Type
Incinerator*
Mai f 'notion
Irrlication
Response
Indication of or actual
failure of Induced Draft
 L
RK
(a)  Nbtor overheating
(b)  Excessive or zero cur-
    rent (amps)
(c)  Total stoppage of fan
(d)  Pressure drop across
    blower inlet and out-
    let
ui
CTi
         12
Increase in gas temper-
ature after quench
zone, affecting
scrubber operation
 L
RK
 C
(a) Partial or total loss
    of water supply to
    quench zone
(b) Increase of combustion
    tenperatures
(a) Switch to stand-
    by fan, if
    avail able
(b) If two induced draft
    fans are used in
    series, reduce oper-
   ational level s
    immediately,  stop the
    failing unit, and
    operate at reduced
    rate on one fan only,
    until maintenance can
    be completed.
(c) If there is only one
    fan, and the ^ari
    failure appears
    serious, shift into
    an emergency shut-
    down mole for entire
    incinerator.

(a) Check water flow
    to quench zone.
    Prepare for 1 imited
    operation rate until.
    water supply is
    restored
(b) Check combustion
    conditions,
    especially temper-
    ature .

-------
                                                    TABLE 4 (Continued)
        No.
Malfunction
    Type
Incinerator*
Malfunction
Iridication
 Response
        13    Partial or complete stoppage
              of water or caustic solution
              to scrubber(s).
                               L
                              RK
i
M
Ol
^J
I
             (a) Decrease in pressure
                 cross scrubber,  as in-
                 dicated by manometers,
                 or other instruments
             (b) Zero or increased amps
                 on water or solution
                 puiips
             (c) Flowmeter readings out
                 of specified range.
             (d) Large increase in acid
                 components in stack gas
                 as detected by NDIR or
                 other type instruments.
                         (a)
                                                                      (b)

                                                                      (c)


                                                                      (d)
   Halt waste feed,
    start trouble-
    shooting and main-
    tenance in affected
    system.
    Start up redundant
    pumps,  if available
    Check recycle water
    or solution tank
    levels.
    If using alkaline
    solution,  switch
    to water supply
    if available
(e)  Check for deposition
    of solids from
    recycled liquors
    in pump lines
    Ttee emergency
    (stand-by)  water
    supply which will
    water by gravity
    until the whole
    system can be shut-
    down
                                                                                                (f)
                                                                                                                      feed

-------
                                                 TABLE  4  (Continued)
       No.
        14
un
03
I
        15
        16
            Malfunction
    Type
Incinerator*
    Malfunction
    Indication
 Response
Deposition of solids
in scrubber from recycled
wastes or caustic solu-
tion, or from excess
solids emissions from
combustor.
    L
   RK
    C
pH of recycled scrubber
liquor not  in spec
    L
   RK
    C
Failure of demister
operation
    L
   RK
    C
(a) Build-uo of pressure
    across scrubber as
    indicated by manometers
    or other instruments.
(b) Increased hold-uo of
    liquor in packed or
    trav towers, UP to
    and including flooded
    condition.  This can
    also be detected by
    liquid level indicators.

(a) Continuous, or spot-
    checkinq pH indicator
    shows actual pH to be
    outside of desired
    ooeratinq ranqe.
(b) Drop in scrubber
    efficiencv with excess
    acid qas in stack qas.
Increased pressure as
measured bv manometer,
due to solids accumulation
in demister element.
This requires a shu
down to clean out th
tower and internals.
The shut-dow
scheduled if the
deposit build-up is
qradual and is
monitored.
(a) Check for adequate
    supply and meterinq
    of alkaline aqent
(b) Check accuracy of PH
    meter and alkaline
    solution meterinq
    numo associated with
    recvclinq of scrubber
    liqinr.

Rack-^wash element

-------
     5.   Final regulatory language

 §264.345

     (e)  An incinerator must he operated with  a  functioning

 system to automatically cut off waste  feed  to the  incinerator

 when operating conditions deviate  from limits established under

 pararaph (a) of this Section.

 Kt   Trial Burns

     1.   Synopsis of the Proposed Regulation

     In Section 250.45-l(b) of the proposed standards, EPA speci-

fied that owners and operators would  conduct a test to demonstrate

compliance with performance standards before a significantly

different hazardous waste could be  routinely incinerated.  The

standard spelled out certain measurements, testing, and calcula-

tions which could provide data to evaluate the oerforraance of

the incinerator.

     2.   Summary of the Comments

          0  Proposal is unclear as  to the  meaning of "princioal
             toxic component", whether weight,  volume or degree
             of hazard  is specified.  "Principal"  should refer
             to the highest degree of  hazard established bv EPA.

          0  The use of the term "significantly different" is
             too vague.

          8  EPA should not require  trial burns if data already
             exists.

          0  Trial burns would be  "unworkable"  for boilers and
             general purpose  incinerators since boiler opera-
             tions cannot be  interrupted and general ourpose
             incinerators would always need trial  burns since
             they burn  so many different wastes — an annual
             waste characterization  is suggested.

          0  Suggest air, ground,  and  water emission oermits
             instead of trial burns  for destruction effi-
             ciency, combustion efficiency, and sulfur emissions.
                               -159-

-------
           0  Test for CO, C02, and O2  in  the hot  zone exit
             qases prior to the emission  control  device.  Parti-
             culates should he measured in stack  after the
             emission control device.

             DE should be monitored  in routine burns as well
             as in trial burns.

             There is no specification of how manv trial burns
             will be required.

             Suqqest usinq a lab-scale, flowinq device to deter-
             mine iqnition temnerature, etc., to  classifv wastes
             into deqrees of severity and similarity.

             There is a problem for  those onerators who blend
             wastes - they would have to do a lot of trial burns.

           0  Trial burns can cost 550,000 - 570,000 for lab
             analysis, and over 5100,000  in total.  This is a
             biq burden which is unnecessary.  Suqqest RPA
             rely on judqement of experts.

           0  Suqqest determininq "qeneric cateqories" to reduce
             amount of trial burns, or "rankinq"  criteria.

             Trial burn results should be submitted to the Reqional
             Administrator. (Suqqested times for  submittal ranaed
             from 7 davs to 6 months.)

     3.   Response to Comments

          Principal Toxic Component.  This comment was discussed

under paraqraoh D.  It is now referred to as orincioal oraanic

hazardous component and will be specified by the oermit writer

on a case-by-case basis.

          Significantly different waste.   The Aqencv aqrees that

the term "siqnificantly different waste stream" fin terras of

when a trial burn may be required] is vaque and has clarified

this.  The requlation requires that variability of waste feed

be held within limits set in the permit,  and further states

that trial burns are required for a waste not covered in the
                              -160-

-------
permit for the facility.  This will define, "siqnificantly



different".   The variability limits will be based on the best



engineering judgement of the permitting offical.  To assist



in this judgement the Agency has developed a guidance manual



and an engineering manual, one function of which is to provide



guidance on this issue.



     Use of existing data.  EPA agrees with the comments that



if trial burn data and information already exist that are relevant



and sufficient to the problem at hand, then new trial burns are



not needed.   The regulation in this area allows the applicant to



submit information on whether or not trial burns are viewed as



necessary.  In a proposal to waive trial burns, the applicant



must furnish  detailed information to show that acceptable



Destruction and Removal Efficiency will be attained in the Pro-



posed incinerator.



     Boilers and multiple waste incinerators.  The Agency exempted



boilers from the hazardous waste  incineration requlations in



the May 19,  1980 regulations.  However the Agency is investi-



gating the tvpes and volumes of wastes which are disposed of



in boilers,  and expects to soon propose regulations for burn-



ing of certain wastes in boilers.  The Aqency agrees that



multiple waste, i.e., offsite, incinerators, will require a



number of test burns.  However, without such burns, there



would be no assurance of protecting human health.  The Aqency



believes that there are procedures which can minimize trial



burns.  See below "Trial Burns on Waste Blends".
                              -161-

-------
     Destruction efficiency; combustion efficiency, and




scrubber efficiency.  Comments relative to scrubber efficiency




and combustion efficiency are discussed in paragraphs F and




H respectively.  As discussed elsewhere in this document, air




emission limits for the large variety of hazardous emissions




from an incinerator can only be set on a case-by-case basis




based on a trial burn.




     Hot zone sampling.  The hot zone of an incinerator is




normally neither a safe nor an effective environment in which to




make accurate measurements of quantities such as the CO, CO9,




and C>2 levels present (see paragraph G discussion on monitor-




ing).  Such determination can be hazardous to the workers and




may yield results which are difficult to internret or use.




Sampling may also release fugitive emissions.  therefore, the




Agency has considered these arguments in the total scenario




for abandoning the destruction efficiency parameter in favor




of the new destruction and removal efficiency requirements.




Thus hot. zone sampling is no longer required.




     Monitoring of destruction efficiency.  Comments that destruc-




tion efficiency should be a requirement not only of the trial




burns but of the routine disposal operations were considered




carefully, but the Agency has determined that this is impractical.




Measurement of DRE requires stack sampling and testina.  While




such testing is possible it is expensive to conduct even on an




intermittent basis.  Further, in order to be effective for process




control, DRE would have to be monitored continuously and inter-



preted immediately.  This is not posssible with current technoloov.
                             -162-

-------
Instead,  the Agency believes the continuous monitoring of sur-




rogates  (e.g.,  temperature, CO level,etc.) will be more effective




and  practical.   This matter is discussed  further in paragraoh G.




     Number of trial burns.  The exact number of trial burns




required  was questioned.  It is difficult to make a genera-




lized statement applicable to all situations because of the




large number of incinerator/waste combinations possible.  T'he




Agency will examine each case on a individual basis.  It will,




however,  be the Agency policy to keep both the duration and




the  number of trial burns to a minimum, in order both to reduce




the  threat to human health and the environment in the event




that the  trial burns are characterized bv unacceptable destruc-




tion performance,  and to minimize the cost to incinerator owners




or operators.




     Lab-scale device to classify wastes.  The comment on use




of a laboratory-scale device to determine ignition temperature




and  other parameters relative to full scale operations is a




good one.  The Agency feels that the data can be useful in




guiding  subsequent testing at pilot  and full scale levels and




in limited cases could be used to guide full scale burnina deci-




sions.  Results from lab-scale burns may be submitted as oart




of the documentation called for by 2
-------
tion, types of constituents, etc. of wastes which can be fed to



the incinerator.  For many offsite incinerators the properties



of blended wastes are of primary concern rather than individual



wastes as they are received. It is likely that a facility operator



will blend wastes for storage and the number of different blends



will be far less than the number of individual wastes received.



The trial burns can themselves be conducted on blended wastes



since what is essential is the waste feed  to the incinerator.



The operator may even use blending as a operational tool to



achieve blend quality which is within specified permit limits.



The more storage tanks which are available at a facility, the



wider the range of flexibility for blending.  Thus, the need for



new trial burns can actually be reduced through the use of careful



blending.



     Trial burn costs.  The Agency disagrees with comments that



trial burn costs are typically in the range of $50,000 - $100,000.



Such cost estimates are overstated by including certain costs of



normal operation, personnel, fuels, administrative overhead,



etc.  Such costs are generally not incremental and therefore not



allocatable to trial burn costs.   Engineering estimates for



trial burn costs have been made by EPA and its contractors and



found to be in the order of 4- ^000 dollars per day including



analytical costs.(58,59)  jt would be very unusual for a



facility to be in a trial burn mode for more than a few days.



     Trial burns are essential to determine the incinerator



operating conditions required to meet a 99.99% ORE.  The com-



menter's suggestion that EPA make judgements in the absence





                              -154-

-------
of data, is unacceptable.  However, the regulations do provide




an option for data to be supplied without conducting a trial




burn.  The regulations allow other burn data  or  combustion data




from other incinerators burning the same or similar wastes to




be submitted in lieu of trial burn data, Provided  the data is




judged applicable and sufficient.  In  determining  the accepta-




bility of this alternative data, the  judgement of  the permitting




official, augmented by agency expertise, will be used.   The data




base will grow as burn experience  is  gained,  which will  reduce




the need for new trial burns over time.




     Incinerability Criteria.   The Agency  agrees with the




comment that "generic categories" or  a "ranging" svsten  should




be developed and does plan to  develop incinerability  criteria




for use in guiding permit writers.  This guidance  will he made




a part  of guidance documents prepared to accompany the  regula-




tion.   There are many Possibilities  for aporoachina such a




ranking  system.  Approaches  include molecular structure, heat




of combustion, molecular weight,  excess or activation energy,




auto -  ignition temperature  and many  others.   ^ven though  these




approaches are based on  characteristics of chemical  compounds




rather  than  wastes  or  waste  mixes,  a  useable approach would




help reduce  the potential  number of  trial  burns.  ""here are




several components  to  the  use  of incinerability data  to reduce




trial burn reguirements  and  serve as  the  basis for permits:




     1)    Previous  work  by EPA's office of Research and




           Development.   This will be continued in the future.




      2)   Development of a data base for cataloguing trial burn




                               -165-

-------
          data and information (actual data will confirm or



          deny previously developed theories related to a



          chemical basis for burnability).



     3)   Data gathered from many sources which will have been



          submitted in lieu of a trial burn plan by owners or



          operators desiring a permit.



     The reader is referred to a later portion for additional



discussion on these points in the rationale for the regulation.



     Submission of Trial Burn Results.  EPA agrees with the com-



menter who suggested that a requirement for submittal of the



trial burn results to the Regional Administrator be stated.



This requirement is important for two reasons:



     1 )   If excessive emissions occurred during the trial burn,



          then the permitting authority must be aware of the



          incident, and,



     2)   The development of the data base for permitting actions



          requires that trial burns that do not meet the perfor-



          mance standards be reported and made a part of the



          data base.   Knowledge of the failures are as important,



          if not more important,  than information obtained on trial



          burns which demonstrated full compliance with Suboart O



          performance standards.



     The Agency has added a requirement to the final trial burn



standards that all trial burn results must be submitted to the



Regional Administrator.



     4.   Rationale for the final regulation



     Trial burns are an essential part of the regulation of





                              -166-

-------
incinerators.  If a "new" waste were burned in an operational




incinerator without a trial burn, and the combustion conditions




were not sufficient to adequately destroy that waste, then




hazardous emissions could result which could damage hunan health




and the environment.  A. trial burn may be the only feasible way




of determining operating conditions necessary to meet a perfor-




mance standard - such as 99.99% destruction and removal effi-




ciency.  Destruction efficiency cannot be measured continuouslv




as a performance standard.  Thus, the trial burn serves the pur-




pose of defining those operating conditions - temperature, reten-




tion time, excess air - required to meet that performance  standard,




Those operating conditions then become the naramters monitored




and enforced regularly.




     Further, the Agency has stipulated that a trial burn  not




be conducted without prior approval of a trial burn  plan.  There




are two primary reasons  for this.  One is to provide reasonable




assurance that the  trial burn itself won't damage human health




and the environment.  The  second is to make  sure that  the  data




developed during the trial burn will be satisfactorv to support




a  decision on issuance of  a permit, and to define  the  conditions




of that permit.  This includes aareement on  the number, length,




and duration of burns required.  Therefore,  the  final  regulation




requires a trial burn plan, and  stipulates that the  plan  include




certain  information, such  as  the test  protocol,  the  composition




of the wastes to be burned, and  the  sampling procedures which




will be  used.
                               -167-

-------
     It. follows that the trial burn plan will  itself become  a




condition of the burn permit and will include  those determinations




which the Regional Administrator approves  in the  trial  burn




plan.  The final regulation lists certain  minimum determinations




of each trial burn.  These determinations  are  those necessary  to




assess compliance with the 99.99% DRE, and the oneratinq  conditions




associated with achievement of that standard.   It also  includes




analysis for hazardous combustion bv-products,  so that  the




permitting official can determine whether  these emissions veri-Fv




the DRE calculations made by other means.




     One of the key concerns of the Aqency regarding  trial burns




is that they not become an onerous burden  that would  dis-




courage or delay the progress of hazardous waste disoosal bv




incineration.  There are two concerns in this  reaard.   "^he ^irst




is that significant delays could result  if a  permit modifica-




tion  (or new nermit) were required prior to each trial  burn.




because of this concern the regulation provides that  trial




burns can be conducted in accord with special  short tern permit-




ting  requirements  under Part 122.27  (b).




      The second concern about the burden of trial burns is




i_hat.  they could potentially become  frequent events  at facilities




handling many  different wastes,  effectively tvinq un  siani-




fleant  capacity and adding  to  costs.   The regulation  attempts




in to avoid this problem.  Two  provisions  address this.  ^irst,




trial burns are required  only  for  wastes not covered  in the




oermit.  As discussed  in  section H,  acceptable variation in

-------
waste composition is a required condition of a permit.  Thus,
the regulations recoanize that the permit conditions applv not
only to the specific wastes for which trial burns have been
conducted, but also to variations of this waste or waste mixture,
if those variations will also meet the applicable performance
standards.  Secondly, the final regulation provides that a trial
burn need not be conducted if data can be supplied from other
trial or operational burns on similar waste in similar incinerators,
These points are elaborated below.
     The determination of acceptable variation in waste composi-
tion to be included in a permit is a judgement which the permit-
ting official must make.  If, for example, an incinerator is
currently burning waste A and the operator desires to burn
waste B, how different must the two be before it  is deemed that
either a modified permit is required or a new set of trial burns
required?
     The approach that the Agency finds is the most reason-
able is that of a "hierarchy of waste incinerability".  Candi-
date wastes will be grouped in categories, so that within each
category, the wastes will be approved for burning in the facility
provided the permit conditions remain the same.   An incinerator
may be approved for the destruction of any other  category which
is determined to be more readily "incinerable".   See additional
discussion in this section  (section K) on "Incinerabililtv
Criteria" .
     The permitting official will rely on engineering judgement
                               -169-

-------
t_o determine whether a trial burn is necessary,  and  on data

such as that developed by Lee  (57)_  r^g examined  the  thermal

degradation characteristics of fifteen compounds and develoned

a correlation of degradation temperature and  residence time

versus the following:

     1.   Number of carbon atoms

     2.   Aromatic compound or not

     3.   Existence of saturation

     4.   Presence of nitrogen in the molecule

     5.   Presence of oxygen in the molecule

     6.   Hydrogen/carbon ratio

     7.   Existence of a carbon double bond;  chloride

          interaction in the molecule

     R.   The auto-ignition temperature of  material.

     In addition to this work, the A.gencv has identified  other

criteria for waste similarity which may be  of benefit  to  the

permitting official:

     -    physical state, (e.g., solid, liquid,  siudqe1

     -    elemental composition, (e.g., oresence of  metals)

     -    hazardous components (e.g., dioxins)

     -    viscosity (relate to burning tyoe and  configuration)

     -    moisture content (percent water)

     -    heating vlue (RTJ content, notentiai  for biendina
          with other wastes)

     -    percent solids (e.g., burner design)

     -    ash content (residue handling)

     -    flash point (temperature limits)

     Specific limits and ranges of values for each of  the above

                              -170-

-------
parameters which are  judged i_o be  representative  of  similar

wastes are specified by the Agency in the  Permit  Writer's Guide-

lines (46).  This information should be  useful both  in  establish-

ing waste variability limits in the permit,  and in judging the

suitability of data supplied in lieu of  a  trial burn.

     Likewise, similarity between  two or more  incinerators must

be determined wherever data from a previous  incinerator is o^^ere

by the applicant for  a permit in lieu of a trial  burn,  or in

order to support the decision to use specific  test conditions

on a proposed trial burn.   In this case, the Agency  has identi-

fied seven items or characteristics of incinerators  which must

be similar or must meet  specified  limits:

     0    type of incinerator  (e.g., rotarv kiln, fluidized bed)

     0    combustion  zone temperature  (wide variations  will
          cause different destruction efficiencies'!

     0    excess air  or  ratio of air  feed  rate to waste feed
          rate (e.g., too low excess air can result  in  incom-
          plete combustion, too high  excess air  can  result in
          low temperature and incomplete combustion^

     0    components  and dimensions (e.g., burner design  and
          combustion  zone site and configuration)

     0    residence time (related  to  destruction  and removal
          efficiency)

     0    air pollution  control devices  (affects  removal
          efficiency)

     0    auxiliary  fuel use

     The Agency is requesting  various kinds of data  and informa-

tion in, a) trial burn  plans, b) reports of trial burns,  and

c) part R applications  for  permits.  All of this  information  is

related in one way or another  to the  ORE.   In some cases, the

                               -171-

-------
relationship is direct, e.g., measurement of the ^OHC in the




stack gas during a trial burn.  In other cases the relation-




ship is not as apparent or may be suspected, and direct relation-




snips may only be well defined after the experience of nanv trial



burns and full scale operational burns.  A.n example of an




indirect relationship is information on incinerator hardware.




Another example is products of incomplete combustion measured



during the trial burn.




     The Agency has recent information which indicates that




potentially hazardous products of incomplete combustion or




combustion by-products, may be found during incineration of haz-



ardous wastes and in other instances (13,6,11,17,72,73,79,00^81,



82,34).




     Chlorine - containing compounds can be dechlorinated and




free radicals formed in the combustion zone.  Chlorine is ^ormed




during this process.  The presence of chlorine makes nossibie




re-chlorination of certain other compounds.  A.n examoie of this



is formation of hexochlorobenze from benzene.  Biphenvl




(unchlorinated PCB) residuals could become chlorinated, thus




becoming in turn more difficult, to burn and perhaps more toxic.




Hundreds of reactions are possible in wastes containinn onlv




a few hazardous constituents.  To most effectively protect the




health and environment, as much as possible must be known




about:



     a)   the waste matrix - thus the requirement for waste




          analysis,



     b)   fuel - fuel may be the waste or constituents of the




                              -172-

-------
          waste, fuel for secondary combustion reactions might




          consist of DICs from primary reactions




     c)    oxidizer - oxygen supplied in air stream or chemicalilv




          bound




     d)    by-products of combusiton - related to efficiency




          of combustion, CO, CO^, other oraanics.




     The Agency is not regulating the discharge of nroducts of




incomplete combustion (PICs) at this tine because of a lack




of data related to attainable or expected destruction efficiency




under various burn conditions.  Regulations are being proposed




now however, to deal with this problem  (also see reference RT).




It is clear however, that based on preliminary, research the




formation of PICs is intimately related to the destruction of




and destruction efficiency of the compound from which they were




formed (79).  The chemistry of these interactions will become




better understood only  as more data are available.  ^ven now




however, the measurement of PICs will help in understandina and




verifying calculations  of DRE.  Additional details are also




provided on this matter in the permit writers guidance (->q»7Ch.




     Referring back to  the seven items, residence time should be




no less than 5% below and no more than  100% above that of the




previous incinerator.   The Agency is also developing data in




several other areas to  aid exercise of  engineering  judgement in




lieu of repetitive trial burns.  Specifically:




     (1)  The Agency has started a  recordkeeping  system to




          document all  test burn data which is currently avail-




          able  and which will be generated as new permits are




                              -173-

-------
     issued.   These data will be available to nermit writers,




     owners,  and operators of incinerators, the public,




     and equipment manufacturers to establish a svstem to




     rapidly disseminate trial burn results to all interested




     parties.  Techniques to use existing data for new




     incinerator/waste type combinations will be developed




     as part of EPA' s effort to better understand inciner-




     ation of "hazardous wastes.  The Agency has added




     a requirement that all data obtained during a trial




     burn conducted under an approved trial burn nlan




     shall be submitted to the Agency.  This requirement




     is needed to insure that the data base for develop-




     ment of best engineering judgement for each incin-



     erator is complete.  It will also hein to build a



     data base.  A trial burn which is unsucessful in meet-




     ing performance standards provides as much if not mor^




     information about incinerator operation as a sucess^ul




     trial burn.  Also, it is necessarv because incinerator



     owners and operators may be reluctant to reveal oerfor-




     mance results which do not meet the performance standards




     unless they are required too.



(2)   EPA's Office of Research and Development has developed




     and is currently using a laboratory method of studving



     the thermal decomposition of waste constituents.  '"his




     method,  called the "Thermal decomposition Analysis



     System", (TDAS)  allows the controlled studv of the
                         -174-

-------
          conditions under which  compounds  are  decomposed bv

          high temperature processes.   The  analysis of decomnosi-

          tion products is done by  either gas chromotography or

          gas chromotography-mass spectroscopy.

     The i.ypes of information generated by  the  TDA.S fall into

two broad categories.

     0    What, are the minimum residence time/temperature con-
          ditions needed t.o destroy a waste or  a "hazardous
          material?

     0    If the above minimum conditions are not  attained,
          what are the combustion by-products or products of
          incomplete combustion  (PIC) which could  form during
          the incineration process?

     (3)  ORD is also building a  pilot  scale  incinerator facility

          at Pine Bluff, Arkansas,  which will contain one or

          more small incinerators.   These units will be used

          to study the incineration processs to develon the

          basic engineering understanding of  the destruction

          of waste materials.  This facility will  also be

          available  to run tests  on wastes  which are of concern

          to the Agency to develop  data for full scaie/aonli-

          cations.

               Thus, anticipates  that the ability  to make engin-

          eering  judgements in lieu of  actual trial burn tests

          will develop rapidly over the next  five  year period.

          These efforts by the Agency will  reduce  the impact o^

          trial burn requirements on owners and operators of

          incinerators.
                               -175-

-------
     5.    Final regulatory language

§264. 344  New Wastes;  trial burns or permit modifications

     (a)  The owner or operator of a hazardous waste incinerator

may burn only wastes specified in his permit and only under

operating conditions specified for those wastes under 5264.34S,

except:

          (1)  In approved trial burns under $122.27(b) of
               Chapter; or

          (2)  Under exemptions created by $264.340.

     (b)  Other hazardous wastes may be burned only after

operating conditions have been specified in a new permit or a

permit modification as applicable.  Operating reauirements for

new wastes may be based on either trial burn results or alter-

native data included with Part B of a permit application under

§122.25(b)(5) of this Chapter.

§122.27 - Short Term Permits

     (b)  Trial burn permits.  For the purposes of determining

          feasibility of compliance with the incinerator

          performance standard of 5264.343 of this Chanter

          and of determining adequate incinerator operating

          conditions under $264.345 of this Chapter, the

          Director may issue a trial burn permit to a facility

          to allow short term operation of a hazardous waste

          incinerator subject to paragraphs (b)(1) - (5) of

          this Section.
                              -176-

-------
(1)  The trial burn must be conducted  in  accordance with a trial



    burn plan prepared by the applicant  and  approved bv the



    Director.  The trial burn plan  will  then become a  condition



    of the permit.  The trial burn  plan  will include the



    following information:



    (i)  An analysis of each waste  or mixture of wastes to be



         burned which  includes:



         (A)  Heat value of the  waste in the form and  composi-



              tion in  which it will be burned.



         (B)  Viscosity  (if applicable), or  description of



              physical form of the  waste.



         (C)  An  identification  of  any hazardous orqanic  consti-



              tuents listed in Part 261, Appendix VIII of this



              Chapter, which are present in  the waste  to  be



              burned,  except that the applicant need  not  ana-



              lyze  for constituents listed in Part 261, Appendix



              VIII, of this Chapter which would reasonably  not



              be  expected  to be  found in the waste.   The  consti-



              tuents excluded  from analysis  must be  identified



              and the  basis  for  their exclusion stated.   The



              waste analysis must rely on analytical  technicrnes



              specified  in EPA document  SW-846  (referenced  in



              40  CFR  Part  261,  Appendix  III), or their equivalent.



          (D)  An  approximate  quantification of the hazardous



              constituents identified in the waste,  within  the



              precision  producted by the analytical methods



              specified  in EPA document  SW-R46.






                              -177-

-------
       (E)   A quantification  of  those  hazardous constituents

            in the  waste  which may  he  designated as  POHC's

            based on  data submitted from other trial or

            operational burns which demonstrate compliance

            with the  performance standard in .5264.343 of

            this Chaoter.

 (ii)   A detailed engineering description of the incinerator

       for  which the  trial burn  oermit  is sought including:

       0    Manufacturer's name  and model number of  incine-
            rator  (if available).

       *    Type of incinerator.

            Linear  dimensions of the incinerator unit includino
            the cross sectional  area of combustion chamber.

       *    Description of automatic waste feed cut-off
            system(s).

       8    Stack gas monitoring and oollution control equio-
            ment.

       0    Nozzle  and burner design.

       0    Construction  materials.

       0    Location  and  description of temperature, nressure,
            and flow  indicating  and  control  devices.

(iii)   A detailed description of sampling and monitoring nroce-

       dures,  including samplina and monitorino locations in

       the  system,  the equioment to be  used, samoling and

       monitorina freauencv,  and olanned analvtical  Drocedure^

       for  sample analysis.

 (iv)   A detailed test schedule  for each waste for which the

       trial burn is  planned  includina  date(s), duration,

       quantity of  waste  to be burned,  and other factors
                           -178-

-------
         relevant to  the  Director's  decision  under oaraqraph



         (b)(4) of this Section.



     (v)  A detailed test  protocol,  including,  for each waste



         identified,  the  ranqes of temperature,  waste feed rate,



         air feed rate, use of auxiliary  fuel,  and any other



         relevant parameters that will  he varied to affect the



         destruction  and  removal efficiency of  the incinerator.



    (vi)  A description of, and planned  operatinq conditions for,



         any emission control equipment which will be used.



   (vii)  Procedures for rapidly stopoinq  waste  feed, shuttina



         down the incinerator, and  controllinq  emissions  in



         the event of an  equipment malfunction.



  (viii)  Such other information as  the  Director reasonablv finds



         necessary to determine whether to aoprove the trial



         burn plan in 1iqht of the  purposes of  this paraqraph



         and the criteria in paraqraoh  (b)(4) of this Section.



(2)   The Director, in  reviewinq the  trial  burn plan, shall evalu-



     ate the sufficiency of the information provided and may



     require the applicant to supplement this  information, if



     necessary, to achieve the purposes  of this  paraqraoh.



(3)   Based on the waste  analysis data in the trial burn plan, the



     Director will specify as trial  Principal  Oraanic Hazardous



     Constituents (trial POHC's), those  constituents for which



     destruction and removal efficiencies  must be calculated



     durinq  the trial  burn.  These trial POHC's  will be soecified



     by the  Director based on his estimate of  the difficulty of
                              -179-

-------
     incineration  of  the  constituents  identified  in  the  waste



     analysis,  the concentration or mass  in the waste  feed,  and,



     for  wastes listed  in Part  261 of  this Chapter,  the  hazar-



     dous waste constituent or  constituents identified in



     Appendix  VII  of  that Part  as  the  basis for listinq.



(4)   The  Director  shall approve a  trial burn  plan if he  finds



     that:



     (i)   The  trial burn  is likely to  determine whether  the



          incinerator performance  standardv required bv  $264.343



          of this  Chapter can be met;



    (ii)   The  trial burn  itself will not  Present  an  imminent



          hazard to human health or the environment;



   (iii)   The  trial burn  will help the Director to determine



          operating requirements to be specified  under 5264.345



          of this  Chapter; and



    (iv)   The  information sought in paragraphs  (b)(4)(i)  and (iii)



          of this  Section cannot reasonably be developed  through



          other means.



(5)   (i)   During each approved  trial burn (or as  soon  after  the



          burn as  is  practicable), the applicant  must  make the



          following determinations:



          (A)   A quantitative analysis of the trial  POHC's  in  the



               waste  feed to the incinerator.



          (B)   A quantitative analvsis of the exhaust  gas for  the



               concentration and mass  emissions of the trial POHC's,



               CC>2/ 02r and hazardous  combustion  by-products.
                              -180-

-------
      (C)  A quantitative analysis of the scrubber water (if



          any), ash residues, and other residues, for the



          trial POHC's.



      (D)  A total mass balance of the  trial POHC's in the



          waste.



      (E)  A computation of destruction and removal efficiencv



           (DRE),  in accordance with the ORE formula specified



          in  §264.343(a) of  this Chapter.



      (F)  If  the  waste feed  contains more than  0.5% chlorine,



          a computation of chlorine removal efficiency, in



          accordance  with  §264.343(b).



      (G)  A computation of particulate emissions, in accor-



          dance with  §264.343(c) of this Chanter.



      (H)  An  identification  of sources of fuqitive emissions



          and their means  of control.



      (I)  A measurement of averaqe, maximum,  and minimum



          temperatures, and  air  feed  rates.



      (J)  A continuous measurement of  CO  in the exhaust qas.



      (K)  Such other  information as the Director may specifv



          as  necessary to  ensure that  the trial burn will



          determine compliance with the performance standard



           in  §264.343 of  this Chapter  and to  establish the



          operating conditions required by  S264.345 of this



          Chapter as  necessary to  meet that performance




          standard.



(ii)   The applicant  shall  submit  to  the Director a certifi-



      cation that  the  trial burn  has been  carried out in






                          -181-

-------
          accordance with the approved trial burn plan,  and the



          results of all the determinations required in  nara-



          graph (b)(5)(1) of this Section.   To the extent possi-



          ble, this submission shall be made within 30 days of



          the completion of the trial burn, or sooner if the



          Director so requests.



   (iii)  All data collected during any trial burn must  be



          submitted to the Director following the completion



          of the trial burn.  The results of the trial burn



          must be included with Part B of the oermit aoplica-



          tion, if a permit application is submitted.



    (iv)  All submissions required by this paraaraoh shall he



          certified on behalf of the applicant by the signature



          of a person authorized to sign a permit application



          or a report under §122.6.



Part 122.25



     (5)  For facilities that incinerate hazardous waste, except



          as §264.340 of this Chapter provides otherwise, the



          applicant must fulfill the requirements of paraqraph



          (b)(5)(i),  (ii), or (iii) of this Section.



          (i)  When seeking exemption under $264.340(b)  (lonitable



               waste only):



               (A)  That the waste is either (1) listed  as a



                    hazardous waste in Part 261, Subpart D of



                    this Chapter, only because it is ignitable



                    (Hazard Code I) or, (2) that the waste has
                              -182-

-------
            been tested aqainst the characteristics of

            hazardous waste under Part 261, Suboart C of

            this Chapter, and that it meets only the

            iqnitability characteristic, and includes

            none of the hazardous constituents listed in

            Part 261, Aonendix VIII of this Chanter; or

 (ii)   Submit results of a trial burn conducted in accor-

       dance with $122.27(b) includinq all the determi-

       nations required by S122.27(b); or

(iii)   In lieu of a trial burn, the applicant mav submit

       the following information:

       (A)  An analysis of each waste or mixture of wastes

            to be burned includinq:

                 Heat value of the waste in the form and
                 composition in which it will be burned.

            0    Viscosity (if applicable), or description
                 of physical form of the waste.

                 An identification of any hazardous orqanic
                 constituents listed in Part 261, Appendix
                 VIII, of this Chapter which are present
                 in the waste to be burned, except that
                 the applicant need not analyze for consti-
                 tuents listed in Part 261, Appendix VIII,
                 of this Chapter which would reasonablv
                 not be expected to be found in the waste.
                 The constituents excluded from analysis
                 must be identified and the basis for their
                 exclusion stated.  The waste analvsis
                 must relv on analytical techniques speci-
                 fied in EPA document SW-846 (reference^
                 40 CFR Part 261, Appendix III) or their
                 equivalent.

            0    An approximate quantification of the
                 hazardous constituents identified in
                 the waste, within the precision produced
                 by the analytical methods specified in
                 EPA document SW-846.
                      -183-

-------
          A quantification of  those  hazardous
          constituents  in  the  waste  which may he
          designated  as POHC's based on  data
          submitted  from other trial or  operational
          burns which demonstrate  compliance with
          the  performance  standard  in $264.343
          of this  Chapter.

(B)   A detailed engineering description  of  the

     incinerator,  including:

     *     Manufacturer's name  and  model  number  of
          incinerator.

     *     Type of  incinerator.

     0     Linear dimension of  incinerator  unit
          including  cross  sectional  area of
          combustion chamber.

     "     Description of auxiliary fuel  system
          (type/feed).

     8     Capacity of prime mover.

     8     Description of automatic waste feed
          cut off  svstem(s).

     8     Stack gas  monitoring and pollution
          control  monitorina system.

     8     Nozzle and burner design.

          Construction  materials.

     0     Location and  description of temperature,
          pressure,  and flow indicating  devices
          and control devices.

(C)   A description and  analysis of the waste  to be

     burned compared with  the waste for  which  data

     from operations or trial burns are  provided

     to support the contention that a trial burn

     is not needed.   The data should include  those

     items listed in S122.25{b)(5)(iii)(A).  This

     analysis should specify the POHC's  which  the


               -184-

-------
     applicant has identified in the waste for

     which a permit is souqht, and anv differences

     from the POHC's in the waste for which burn

     data are provided.

(D)   The design and operating conditions of the

     incinerator unit to he used, compared with

     that for which comparative burn data are

     available.

(E)   A description of the results submitted from

     any previously conducted trial burn(s)

     including;

          Sampling and analvsis techniques used
          to calculate performance standards in
          §264.343 of this Chapter,

          Methods and results of monitorinq temoe-
          ratures, waste feed rates, air feed
          rates, and carbon monoxide,

     0    Identification of any hazardous combus-
          tion by-products detected,

          The certification and results required
          by §122.27(b) (5) (ii).

(F)   The expected incinerator operation information

     to demonstrate compliance with s §264. 34 3 and

     264.345 of this chapter including:

     0    Expected carbon monoxide (CO) level in
          the stack exhaust gas.

     0    Waste feed rate.

     0    Combustion zone temperature.

     0    Air feed rate.

     "    Expected stack gas volume, flow rate,
          and temperature.


               -185-

-------
           0     Computed residence time for waste  in
                the combustion zone.

           0     Expected hydrochloric acid  removal
                efficiencv.

           9     Expected fugitive emissions and  their
                control  procedures.

                Proposed waste feed  cut-off limits based
                on the identified significant  ooeratino
                parameters.

      (G)   Such supplemental information as the  Director

           finds necessary to achieve the purnoses of

           this paragraph.

      (H)   Waste analysis data, including that submitted

           in paragraph  (B)(5)(iii)(A), sufficient to

           allow the Director to specifv as permit

           Principal Organic Hazardous Constituents

           (permit POHC's) those constituents  for  which

           destruction and removal efficiencies  will

           be required.

(iv)   The  Director shall approve a permit application

      without a trial burn if he finds that;

      (A)   The wastes are sufficiently similar;  and

      (B)   The incinerator units are sufficientlv

           similar, and  the data from other trial

           burns are adequate to specify (under

           §264.345 of this Chapter)  operatinq condi-

           tions that will ensure that the  nerformance

           standards in §265.343 of  this Chapter will

           be met by the incinerator.



                     -186-

-------
L.   Waste Analysis

     1.   Summary of the Proposed  Regulation

          Section §250.45-1(b)(1)(i),  (ii),  and (iii)  required  as

          part of conducting a trial burn an analysis  of:   (1^  the

          waste for halogens and principal "hazardous conponents,

          (2) ash and  scrubber wastes  for principal "hazardous

          components,  and  (3)  exhaust  gas for halides,  CO,  CO^,

          C>2 and particulates .

     2.   Comments on  the  proposed regulation

          Most of the  general  comments received on these require-

          ments are addressed  in the  Background Document entitled

          "Waste Analysis."  The few comments relating specifically

          to incinerators  are  summarized as  follows:

          0  Required  testing  and  analysis are unnecessarv and  too
             expensive for certain wastes.

          0  It is not clear what  is  to be tested and  what owners
             or operators  are  to do with the information thus
             gathered.

          0  Site owners or operators  should be able  to rely on
             information in manifests, rather than duplicatina
             work done by  generators.

          0  Testing  should not be required  except to:  (a> identify
             waste as  hazardous, and (b) provide necessary infor-
             mation to the owner or operator to allow him to make
             decisions concerning  safe manaaement.

      3.      Response  to  comments

             Testing  unnecessary and expensive.  It  is impossible  to

          determine destruction efficiency during a  trial burn  with-

          out,  analyzing the wastes for most  of the proposed

          constituents.  Analysis  can be expensive,  but the detailed

          analysis  is  required only for trial burns,  and is essential
                              -187-

-------
to determining incinerator performance.




   Requirements unclear.  To the extent that "principal




hazardous component" was not defined, the Agency agrees




that the waste analysis requirements relating to then




were not clear.  This has been addressed in the regula-




tions by establishing criteria which the permitting




official  will use to define principal organic, hazar-



dous components (POHC).  However, this follows a waste




analysis designed to provide information on the waste




composition, which is necessary in order for the oermit-



ting official to malce the judgement on hazardous comnonents




The regulations define the type of preliminary analysis



required, and is provided to further define the required



analysis.




   Use manifest information; limit testing.
nation on the  manifest contains a qeneral identification




of the waste by DOT classification code.  This would




not provide sufficient information to safely conduct a




trial burn and determine destruction and removal




efficiency.  Testing must by sufficient to determine




compliance with the incinerator regulation, not lust




a general statment o* whether the waste is hazardous.




(See also discussion of waste analysis in Part TV).






   The Agency agrees with the comment that waste




analysis requirements should be limited to identi-




fication and disposal.  Both the oroposed regulations







                    -138-

-------
     and those being promulgated now have these two purposes




     as the basis.




4.      Rationale for the final regulation.




        Waste analysis required to meet the final inciner-




     ation regulations and thus to conduct incineration of




     hazardous wastes in a way which will protect human




     health and the environment consists of elements




     described in the previous section  (Section K) on




     trial burns and Part 122.27(b).




        Throughout operation  sufficient analysis o^ the




     waste being fed to the incinerator to determine




     whether  it is within the waste variability limits




     defined  in the permit would be required.




        Analysis of a waste for heatina value, metals




     listed in Appendix VIII, Part  261, and halogens  is




     relatively straight-forward.   However, the identi-




     fication of  hazardous organic  constituents in  the




     waste is more difficult  because  of the analytical




     chemistry involved.



        The Agency  expects  that the analysis  for  organic




     components will  involve  GC/MS  (gas  chromatoaraphv/




     mass  spectroscopy)  analytical  methods.   If the owner




     or operator  has  information on the  probable  waste




     content, the GC/MS  analysis can be simplified.   T-his




     should be the  case  in most instances.




         In order  to set  bounds on the universe of toxic




     constituents,  the Agency has  specified the  substances







                          -189-

-------
listed in Appendix VIII of Part 261 as those to be




identified (if present) in the waste.  To keen the




analytical task within practical bounds, the reaula-




tion provides that analysis need not be attempted




for any constituent(s) which the owner or operator



can show would not reasonably be expected to be




found in the waste.  For exaranle, previous analvses




on the same or similar wastes which have not shown




certain constituents constitutes a showing.




   Two tynes of GC/MR analytical procedure should be




discussed here in order clarify the regulatory require-




ment :



   a)  analysis of waste where the constituents are




       known (e.g., listed Appendix VIIIt



   b)  analysis where the constituents are unknown.




   The latter type of analysis usinq the GC/M-S tool




can be expensive because a complete search must be




made of computer libraries of available spectra for




the compounds being searched.  Confirmation of



compounds suspected to be present after initial



searches nust be nade using known reference samples




and analytical chemistry laboratory Procedures.




   Since the basis for the regulation  is a listing




in Appendix VII or Appendix VIII of Part 251, this



open-ended searching technique is not  required by




this regulation.   Instead the GC/MR analysis will




proceed using techniques for identifying known







                    -190-

-------
          constituents in the waste.




             It  would  be a rare case  indeed - namely one  in



          which  the waste composition was completely unknown  -



          where  a  complete scan for all  of the Appendix VIII



          constituents would be required.



             In  a  typical scenario no more than,  sav,  20  of



          the items listed in Appendix VIII miqht be chosen



          as  potential POHC's and subsequently, less than six



          might  be designated as POHC's  for purposes of the



          trial  burn.   Based on results  of the trial burn this



          number might be reduced even further for permitting



          purposes.



             During the trial burn itself and during normal



          operational  burns GC/MS technology is not required.



          Once the POHC's have been defined, gas chromatography,



          will, except  in special cases/ be adequate for monitor-



          ing purposes, including quantitative measurements.



             The costs for the limited application of  GC/MS



          technology during the preliminary waste analysis,



          and for  GC technology alone during the  later staaes



          is  expected  to be quite reasonable - in the  order



          of  several hundreds of dollars for a given waste,



          to  a maximum of a few thousand dollars in special



          cases.



5.    Final regulatory  language



§264.341   Waste  Analysis



     (a)   As  a portion of a trial burn plan required by §122.27(b)






                              -191-

-------
of this Chapter, or with Part B of his permit application, the

owner or onerator must have included an analysis of his waste

feed sufficient to provide all information required by 5122.27

(b)(2) or §122.25(b)(5) of this Chapter.

     (b)  Throughout normal operation the owner or operator must

conduct sufficient waste analysis to verify that waste feed to

the incinerator is within the physical and chemical composition

limits specified in his permit (under §264.345(b)).

M.   Instrument Monitoring and Facility Inspection

     1.   Summary of the Proposed Regulation

          During both trial and operating burns, the followino

     parameters (§250.45-1 (c)) were to be monitored and

     recorded:

     0    combustion temperature

     0    exhaust gas CO and 02 concentrations continuously,
          and

     0    waste, fuel, and excess air feed at least every 15
          minutes.

     2.   Comments on the proposed regulation

     *    New equipment to monitor gas emissions  (narticularlv
          CO) would be expensive.

          15-minute inspection of waste flows is unnecessarilv
          rigorous.

     *    Points of measurement are unclear.

     8    NOX, SOX, ND C02 should be added to the list of
          monitored effluents.

     3.   Response to comments

          Monitoring and inspection requirements were  included

     in the  interim status standards promulaated on Mav  19,
                               -192-

-------
1980.  Thus, comments on this  issue are addressed in Part II



of this document.  Monitoring  (but not inspection) is



also addressed in paragraph G.  However, since these regula-



tions have been modified from  those promulgated for interim



status, the full rationale for the final regulations is



presented here.



     The Agency partially agrees with the  first comment.



Gas emission monitoring on a continuous basis is a relatively



complex procedure involving continuous sampling techniques



and on-line monitoring instrumentation.  However, continuous



monitoring of CO is done routinely in power  plant combustion



systems (41).



     The Agency  in the final regulation has  dropped the



requirement to monitor C>2, but has retained  CO monitorina



as an  indicator of combustion  conditions.  EPA has deter-



mined  tht CO monitoring is not excessivelv expensive (R7)



and  its value as a direct measurement of the completeness



of combustion justifies its specification  as an operation



requirement  (see paragraph G).



     EPA disagrees with the comment that a 15-minute inspec-



tion frequencv for waste flow  is unnecessarilv riaorous.



The  Agency believes that the  instruments  (or other devices)



which  measure the combustion conditions  (temperature, reten-



tion time, and excess  air) should be monitored as often



as possible, continuously and  automaticallv  where possible.



The  relevant control  points on which  the combustion condi-



tions  depend in  most  incinerators include  waste feed rate,




                         -193-

-------
auxiiliary fuel feed, and  air  flow.   Variations  in anv of




these, or in the "heating value of  either  the  waste or  the




auxiliary fuel, can lead to  poor combustion conditions and



to emission of incompletely  burned wastes.  Some facilities




already have some of these control loops  (temperature  con-




trolling auxiliary fuel flow,  for  example) operatinq on a



continuous basis '47)^  r^^  Agency encourages such con-




tinuous control, but will  insist that such controls and,




even more importantly, manual  control loops (where the




operator makes the correction), be monitored  or  inspected



at least every 1*5 minutes.




     No specific data base can demonstrate the wisdon  of




the 15-minute frequency.   In some  cases,  where combustion



conditions are subject to  rapid swings, arauments  can  be




made that more frequent monitorina and control is  needed




expeciaily for highly toxic  wastes.   ^his is,  however,  a




facility specific situation  and depends on desian  para-




meters, such as the effectiveness  of  the  instrumentation




and the response period once control  chancres  are made.




Even where automatic control is installed, it. is necessary




to check the instrumentation to ensure that it is  -^unction-




ing.  The 15-minute minimum  ensures that  improper  conditions




do not persist for longer  than that period and ensures




that, the facility will not operate unattended.




     Similarly, control loops  which might affect emissions




or which could result in spills present similar  problems.




These could vary,  depending  on the design of  the equip-
                           -194-

-------
merit, but often include  scrubber water flows,  scrubber




water pH, and, oerhaps,  level  controls on  tanks.   T'hey




must similarly be  inspected  on a 15-minute basis.




     All of these  inspections  are to be part of the  Inspec-




tion Schedule and  significant  results  are  to be recorded




in accordance with the provisions of that  section.   Addi-




tionally, the Agency believes  the entire facility  should




be inspected at least daily  for leaks, spills, fuqitive




emissions, odors,  and  smoke.   These can result in  adverse




human health or environmental  impacts  if not detected early.




Control  system alarms  must also be inspected daily to be




sure they are functioning.  Again, there is no body of




information which  specifically supports any given  freguency.




Based on its own experience  with incinerator test  burns,




the Agency has decided that  inspections at these minimum




freguencies is necessary.



     The comment on points of measurement has  been addressed




in the revised regulation in $7.64.343.  This section speci-




fies that CO monitoring will occur in  the incinerator  stack




after any or all air  pollution control devices.




     The comment  suggesting  that NOX,  SOX, and CO2 be  added




to the list of monitored effluents is  an excessive burden




for  incinerators.   Although  SOX and NOX are air  pollutants




being regulated by EPA,  the  primary purpose of an  incinerato]




is to destroy toxic compounds and prevent their  release




to the environment.   Thus, EPA believes that  to  effectively




meet that primary  purpose and at the same time not nut






                          -195-

-------
excessive monitoring burdens on owners or ooerators of

incinerators, only continuous monitorinq of CO is iustifled.

4.    Rationale for the final regulation

     The need is obvious for monitorinq of those narameters

listed in §341.343(c) which are specified in the permit

as  necessary to meet a 99.99% DRE.  This monitorina is the

basis for determining whether the incinerator is in com-

pliance with the regulations, as is also discussed in

Section G.  The 15-minute interval is considered by the

Agency to be the most appropriate monitorinq interval, as

indicated in response to the comments above, and as described

in Part IV of this document.  The rationale for insnection

of incinerator equipment is described fully in Part IV.

5.    Final regulatory language

(5264.347  Monitorinq and Inspections

     (a)   The owner or operator must conduct, as a minimum,

the following monitoring while incinerating hazardous waste:

           (1)   Combustion temperature, waste feed rate,
                 and air feed rate must be monitored on a
                 continuous basis,

           (2)   CO must be monitored on a continuous basis
                 at a point in the incinerator downstream
                 of the combustion zone and prior to release
                 to the atmosphere.

           (3)   Upon request, by the Regional Administrator,
                 sampling and analysis of the waste and
                 exhaust emissions must be conducted to verify
                 that the operating requirements established
                 in the permit achieve the performance
                 standards of $264.343.
                         -196-

-------
          (b)   The incinerator and associated equipment (pumps,



     valves, conveyors, pipes, etc.) must be completelv inspected



     at least daily for leaks, spills, and fugitive emissions.



     All emergency waste feed cut-off controls and system alarms



     must be checked daily to verify proper operation.



          (c)   This monitoring and inspection data must be



     recorded and the records must be placed in the operatinq



     loq required by §264.73.



N.   Closure



     This requirement was included in the interim status standards



and is discussed fully in Part IV of this document.  The final



regulations include the same requirement as the interim status



standards.



     Final regulatory language



§264.351  Closure



At closure the owner or operator must remove all hazardous waste



and hazardous waste residues  (including, but not limited to, ash,



scrubber waters, and scrubber sludges) from the incinerator site.



[Comment;  At closure, as throughout the operating period, unless



the owner or operator can demonstrate, in accordance with 5261.^(d)



of this Chapter, that the residue removed from the incinerator is



not a. hazardous waste, the owner or operator becomes a Generator



of hazardous waste and must manage it in accordance with applicable



requirements of Parts 262 - 266 of this Chapter.]



§§264.352 - 264.999  [Reserved.]
                              -197-

-------
                             References


 1.    Ferguson,  T.  L. ;  Bergman,  F.  J. ;  Cooper,  G.  R.;  Li, R. T. ;
      and Homea, F.  I.;  Determination  of incinerator operating
      conditions necessary for safe disposal of pesticides.
      EPA 600/2-75-041,  NTIS No. PB251-131/AS.

 2.    Josim,  S.  J.;  K.  M.  Barclay,  R.  L. Gav, and  L. F.  Grantham.
      "Disposal  of  hazardous wastes by molten salt combustion",:
      Presented  at  the  American Chemical Society (ACS) symnosium
      on 'The Ultimate  Disposal of  Hazardous Wastes',  April  1979.

 3.    Shin,  C. C.;  Tobias,  R.  P.; Clausen,  J. F. ;  and  Johnson,
      R.  I.  Thermal  degradation of  military standard pesticide
      f orm u 1a t i o n s.Washington, D.C.;  U.S. Armv Medical Research
      and Development Command; 1975 March 20, 287  P. Contract
      DADA 17-73-C-3132.

 4.    Ahling, Bengt, "Destruction of chlorinated hydrocarbons in
      a cement kiln."   Environmental Science and Technology.
      13(11), 1979 pp.  1377-1379.

 5.    Destroying chemical  wastes in commercial  scale incinerators,
      phase  iTI   Final  Report.   Was h i n g t o n  D. C. ,US>,PA;1 97 7,
      121 p.  Contract No.  68-01-2966.

 6.    Bell,  Bruce A.; Whitmore,  Frank  C.; Kegone incineration
      test program.   EPA-600/2-78-10S,  May  1978.

 7.    TRW Systems Group &  Arthur D. Little  Inc., Destroying
      chemical wastes in commercial scale incinerators,  Phase II
      Final  Report,  USEPA,  June 1977,  120 p. Contract  No. 68-01-2966.

 8.    The PCB Incineration  Test Burn made by Rollins Environmental
      Services at Deer  Park,  Texas.  November 12-16, 1979.   *V
      report  to  the  United  States Environmental Protection Agency,
      Region  VI, Dallas, Texas.

 9.    Destroying chemical  wastes in commercial-scale incinerators-
      facility report "57  USEPA, 1977.   Contract Mo. 68-01-2966.

10.    Ahling, Bengt, "A description of a test olant for combustion
      on a pilot scale."   Chemosphere,  No.  7, 1977, p. 437-442.

11.    Ahling/ Bengt, A.  Lindskog, B. Jannson, and  G. Sundstrom,
      "Formation of  polychlorinated dibenzo-p-d.toxins  and dibenzo-
      furans  during  the  combustion  of  a 2,4,5-T formulation,"
      Chemosphere, No.  8,  1977,  pp. 412-468.
                               -198-

-------
12.   Wastler, T. A.,  C.  K.  Offutt,  C.  K.  Fitzsiramons,  P.  E.  Des
     Rosiers.  Disposal  of  orqanochlori^ne wastes by incineration
     at sea.  EPA-430/9-75-01 4 ',' Washington,  D.C. , 227  n. "July
     1975.

13.   Feldman, John  B.;  Leiqhton, Ira W.;  Demonstrat ion ^ test  burn
     of DDT  in general  electric's liquid  Iniection^ incinerator.
     USEPA,  Region  I.                        ——

14.   A study of  pesticide disposal in a sewage sludge  incinerator.
     Whitmore and Durfee, Versar Inc.  Contract 68-01-1587.   1875.

15.   Ahling, B., "The Combustion of Waste Containinq DDT and
     Lindan," The Science of the Total Environment, 9, (1978)
     pp.  117-124.

16.   Ahlinq, Bengt  and Lindskog,  "Thermal Destruction of PCB and
     Hexachlorobenzene."  The Science of the Total Environment,
      10,  (1978)  pp.  51-59.

 17.   Jannson, B. and G. Sundstrom, "Formation of polychlorinated
     dibenzo-p-dioxins durinq combustion of chloroohenol formu-
      lations,"  The  Science of the Total  Environment,  10, (1978),
     pp.  209-217:                         —-

 18.    Personal contact, August  12,  1980,  James A. Heimbuch,
      Industrial Sales Manaqer,  Hazardous and Toxic Wastes,  Zimoro,
      Inc. Rothschild, Wisconsin  54474.

 19.    Ackerman,  P.  G. ; H. J. Fisher, R. J. Johnson,  R. *. ^Maddalone,
      B.  J. Matthews, E.  L.  Moon, K. H. Scheyer,  C.  C. Shih;  and
      R  F  Tobias.    At-sea  incineration  of herbicide  orange on-hoar^
      the m/t vulcanus":   EPA-600/2-78-086, April 1978, 263 o.

 20.   Fluidized-bed  incineration of  selected  carbonaceous  indus-
      trial  wastes,  Prepared by 'Battelle  Laboratories, Columbus,
      Ohio.   March  1972.

 21.   Acurex  Corp.,  Test  incineration  of  electrical capacitors
      containing PCB's,  FP-1207,4 Research  Proiect  1264-2, Electric
      Power  Research Institute,  1980 May.

  22    Destroying chemical wastes in commercial-scale incinerators-
      facility report 2.   USEPA 19/7,  Contract 68-01-2966.

  23.   ibid.,  facility report 3.   USEPA 1977,  Contract  68-01-2966.

  24.   ibid.,  facility report 4.  OSEPA 1977,  Contract  68-01-2966.

  25.   ibid., facility report 6.  USEPA 1977,  Contract  28-01-2966.

  26.   Emission  Testing at Continental Can Company;  Hopewell,
      Virginia,  USEPA,  October,  iy/o.


                                -199-

-------
27.    State-of-the-Art-Report:  Pesticide Disposal Research,
      Wilkinson, R. R.; Kelso, G. L.; and Hopkins, P. C.; EPA-
      600/2-78-183.

28.    Assessment of Hazardous Waste Practices in the Petroleum
      Refining Industry, NTI5 No. PB-259-097.

29.    Kaufman, H. B., Manaqer, Damage Assessment Proqram, USEPA
      to J. P. Lehman, Director, Hazardous Waste Management Divi-
      sion, USEPA, "Declaring Seymour Recyclinq Company Facility
      and Confines an Imminent Hazard under 7003 of the RCRA of
      1976", April 15, 1978.  Unpublished memo.

30.    Hegener, W. and J. Heidtman, Connecticut DEP, to A. Giles,
      Environmental Protection Specialist, USEPA, Personal
      Communication, February 1975.

31.    Kim, Y. J., USEPA Region V, to 3. Grumpier, Environmental
      Engineer,  USEPA, Personal Communication, November <*, 1979.

32.    Gallay, E., Chicago Dept. of Enerqy and Environmental Pro-
      tection, to E. Grumpier, Environmental Enaineer, USEPA,
      Personal Communication, December 6, 1979.

33.    Fancy, C., N.Y. Dept. of Environmental Conservation to E.
      Grumpier,  Environmental Engineer, USEPA, Personal Communi-
      cation, November 28,  1979.

34.    Polychlorinated Biphenyls, Criteria Modifications, 40 CFR
      761.40 Incineration,  May 31, 1979.

35.    Wisconsin  "Administrative Rules for Air Pollution Control",
      Act  250 of 1965 as amended and Act 348 of  1C>65 as amended.

36.    Moon, D.  K. , Rollins  Environmental Services,  Inc., to D. A.
      Oberacker,  Senior Mechanical Engineer, USEPA;  Personal
      Communication, November 8,  1979.

37.   Standard  Support and  Environmental Imoact  Statement,
      National  Ambient Air  Quality Standard  for  Lead Emissions,
      September, 1978, MTR  RPT No. 7525.

38.   Air  Quality Criteria  for Lead, PB-280  411/OBE,  1978.

39.   Federal Register Vol.  36,  No.  62, March  31,  1971,  5
-------
42.   Moon, D. , Rollins  Environmental Services,  Inc.,  to F,.
     Grumpier, Environmental  Engineer,  HSEPA,  Personal  Communi-
     cation,  January  10,  1980.

43.   Sernyake, R.,  Rollins  Environmental Services,  Inc.,  to n. A.
     Oberacker,  Senior  Mechanical Engineer,  USEPA;  Personal
     Communication, November  8,  1979.

44.   Trapp, J. ,  Citv  of Cincinnati to D. A.  Oberacker,  Senior
     Mechanical  Engineer USEPA,  Personal Communication, November
     8, 1979.

45.   Smith, J. ,  Teledyne Inc.,  to D.A.  Oberacker, Senior Mechanical
     Engineer, USEPA, Personal  Communication,  December  12,  1979.

46.   Cooper,  Doug;  Rollins  Environmental Services,  Inc.,  Deer Park,
     Texas, Personal  Communication to,  I. Frankel,  MITRE Corporation,
     McLean,  Va.  10/23/80.

47.   Mullins,  J.  A.,  Shell  Chemical Comoany, Houston, Texas;
     I. Frankel,  MITRE  Corporation, Personal Communication,
     McLean Va.,  10/24/80.

48.   Kemprev,  S.  K. ,  E. N. , Seiler, and D. H.  Bowman, Performance
     of Commercially  Available  Equipment in Scrubbing Hydrogen
     Chloride Gas^  Journal  of the "Air Pollution Control Assooiation,
     March 1970,  Vol. 20, No. 3.

49.   Unused.

50.   Beckman  Instruments, Inc.,  Process Instruments Division,
     Bulletin 4182A (for 02)  Bull.  4180 (NO/NOX),  Bull.   41Q6
     (particulates) ,  Bull.   41^9 (air nualitv), Bull.  411SA (HC),
     Bull.   4411  (HC),  Bull.   4176  (O2), Bull.   4203 (CO),  Bull.
     4166  (CO,C)2,  C6).

51.   Mine  Safetv Appliance Co.,  Instrument Division, Bulletin
     07-0002B (analyzers for  SO2, NO, CO, CO?,  HC,  0->,  H2,  and
     solvent  vapors).

52.   Sybron  Corporation, Taylor Instrument Companv, Bulletins on
     Process  Control, Analytical Svstems, and Oxygen Analysis.

53.   Lord, III,  H.C., In-Stack  Monitoring-of Gaseous Pollutants,
     Environmental  Science and  Technology, VoT.~~1 2,~ NoY ~3,
     March 1978,  264-269.

54.   Beckman  Instruments, Inc.,  Bulletin 4203,  Model 1867
     Infrared CO Analyzer.

55.   Instrument  Division, Mine Safety Appliances Companv, Data
     Sheet 07-0933  M.
                               -201-

-------
56.


57.
59.
60.
61.
62.
64.
65,
66.
67.
Santoler, J.J., Trane Thermal Comoany, to T. Fields,
Program Manaqer, USEPA, Unpublished letter, February 26, 1979,

Lee, K. C., J. L. Hansen, D. C. Macaulev, Predictive Model o^
the Time - Temperature Reauirements for Thermal
of p i1ute 0rq an ic Vapor s, 72nd Annual Meetinq of
Po11ution Con tr o 1 As soc i at io n, Cincinnati, Ohio, June
1979, Paper No. 74-10.1.
                                                De struct ion
                                                 the
                                                           Air
58.   Guidance Manual for Evaluatinq Permit Applications for the
      Operation of Incinerator Units; the MITRE Corp.
      1980 (DraftReport).
                                                21 Auqust
Velzy, C.O., American Society of Mechanical Engineer, to E.
Grumpier, Environmental Engineer,* U^EPA; Letter, Re;
Proposed Hazardous Waste Guidelines, January 18, 1980.
                                                       the
                                                         The
Bastian, R. E. and W. R. Seeman, 1978.  Proceedinas of t
Eighth Biennial Conference on National Waste Processing,
American Society of Mechanical Engineers, New York, NY,
pp. 557-568.

Frankel, I.  Report of Visit to Cincinnati Liquid/Fluid
Industrial Waste Disposal Facility, June 27, 19RO, The
MITRE Corporation, McLean, Virginia.

Frankel, I.  Report of Visit to Rollins Environmental
Services Industrial Waste Disposal Facility at Deer Park,
Texas, June 30, 1980, The MITRF, Corporation, McLean Virainia,
63.   Adams, J. W., et al., 1977.  Destroying Chemical wastes in
      Commercial Scale Incinerators (Facility Report•5),Final
      Report SC-122 c.4, Arthur D.Little,Inc., Cambridqe,
      Massachusetts for the U.S. Environmental Protection Aaencv.
Clausen, J.
No. 1 Tests	
Unpublished Report,
            F., and C. Zee,
            to be conducted
                    WJT.—
Analytical Plan for Facil.itv
at'Marauardt Corooration/
Adam, J. W.; J. C. Harris and P. L. Levins; Analytical Plan
for Facility No. 2, Tests to be Conducted at Surface
Combustion, Unpublished Report, 1974\

Clausen, J. F.; and D. A. Moore, Analytical Plan for
Facility No. 3, Test•to be Conducted at System Technology,
Unpublished Report,1975.

Adams J. W., J. C. Harris, P. L. Levins, K. E. Thrum and
J. L. Stauffer; Analytical Plan for Facility No. 4, Tests
to be Conducted at Zimoro, Unpublished Report,1975.
                               -202-

-------
68.    Ackerman  D.  G.  and J.  F. Clausen; Analytical Plan for
      Facility  No.  5, Test to be Conducted at Waste Management
      Services, Inc., Unpublished Report/1~9~7~5".

69.    Adams,  J. W.;  J.  C. Harris, P. L. Levins, K. E. Thrum, and
      J.  L.  Stauffer; Analytical Plan - for Facility No. 6, Tests
      to  be^Conducted at the 3M Company, Unpublished report, 197S.

70.    Zee, C. A. Analytical Plan for Facility No. 7 Tests
      Conducted at Hyon Pollution Services, Unpublished report
      1976.''

71.    Ackerman, D.  G.;  J. F. Clausen, Analytical•Plan for Facilitv
      No.  8  Tests to be Conducted at Rollins Environmental
      Services, Inc.   Unpublished Report,T976.

72.    Lustenhouwer,  J.  W. A., K. Olie; and O. Hatzoner, Chlorj--
      nated^  Dibenzo-p-dioxins and R.elated Compounds in Inciner"ator
      Effluents, In Press Chemosohere.

73.    Manny,  E. H. ,  "Reducinq No  Discharqes:  Easv as ARC"; Power
      Magazine, Auqust 19RO.

74.    Private Communication, I. Frankel, the MITRE Corporation,
      August 1980.

75.    Memsath,  K. H.  and Rinkers, F. G. Incineration - An Optimum
      Approach  to Liquid Waste Disposal, Surface Combustion Div.
      Midiand-Ross Corporation, Toledo, Ohio, April 1974.

76.    Kianq,  Y. H. ,  Incineration of Organic Wastes, Proceeding of
      the Ninth National Waste Processing, American Society of
      Mechanical Engineers May,  1980.   (Lecture notes.)

77.    Whitmore, F. C. Versar, Inc.? to  E. Grumpier, Environmental
      Engineer, USEPA Personal Communication, September  9,  19RO.

78.    Engineering Handbook for Hazardous Waste Incineration, USEPA,
      November 1980  (Draft report).

79.    Chlorine and Hydrogen Chloride, National Research Council,
      National Acade'mv of Sciences T Committee on Medical and
      Biological Effects of Environmental Pollutants, Washinqton,
      D.C.,  1976.

80.    J.  McGinnity, USEPA, to  E. Martin, Proqram Manaqer, USEPA,
      Personal communication,  December  22,  19RO.
                                -203-

-------
81.    Shin, C. ; D, Ackerman, L. Scinto, E. Moon, E. Pishnan;
      POM Emissions From Stationary Combustion Sources, with
      Emphasis on Pblychlorinated Compounds of DiBen?:o-p-nio"xin
      TPCDD'S), Biphenyl (PCB's), and DiRenzofaran (PCD*1), HSEPA,
      January, 19"80 (Uripublished Report").

82.    Golembiewski, M.A., Environmental Assessment of a waste-
      to-Energv Process, RDF Electric Power Roller, USEPA,
      February 1980, (Draft Report).

83.    Bumb, R.R. et al, Trace Chemistries of Fire,:  "A Source
      of Chlorinated Dioxins", Science, Vol. 210, October 24, 1QRO ,

84.    Dellinger, B.; C. Fortune; J. Lorrain, Results of Source
      Emissions Characterization at the Hempstead, NY Refuse Energy
      Recovery System, USEPA, AprilTTSO.   (Unoublished Reaort).

85.    FR, Vol. 45, No 197, Standards Applicable to Owners and
      Operators of Hazardous Waste Treatment Storage and
      Disposal Facilities, DP. 6681 £ - 66823, October R,'  1980.

86.    Durall, D.S., University of Dayton Research Institute to
      R.A. Carnes, October 12, 19"?9.  Tlnnublished MeTno.

87.    MacDonald, L.P.; D.J. Skinner; F.J. Hopton and G.H. Thomas;
      Burning Waste Chlorinated Hydrocarbons in a Cement  Kiln,
      Environment Canada, Report no.EPS-4-wp-77-2, March 1977,
      Ottawa, Ontario, Canada.
                               -204-

-------
APPENDICES

-------
APPENDIX  A

-------
TABLE  A"I  HAZARDOUS  WASTES  RATED AS GOOD. POTENTIAL, OR POOR  CANDIDATES
            FOR  INCINERATION  DY APPROPRIATE TECHNOLOGIES [1-0]
EPA hazardous
waste number
Generic
KOO I
F002
F003
F004
F005
F006
F007
FOOB
FOQ9
F010
FOU
F012
F013
F014
F01S
FOU
Hazardous waste
The spent halogenaled solvents used in decreasing, tetrachloroelhylene,
trichloroelhylcne, melhylene chloride, 1, 1, 1- Ir icliloi oellidiic. carbon
tetrachloride. and the chlorinated f luorocaibons; and sludges from the
recovery of these solvents in degicasinr] operations.
The spent halogenatcd solvents, tetrachlorocthylene, mctliylerie chloride,
trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-tri-
chloro-l,2,2-trif luoroe thane, o-dlchlorobenzene, tried lorof luoromethdiie
and Die still bottoms from the recovery of these solvents.
The. spent nonhalogenated solvents, xylene, acetone, ethyl acetate, ethyl
benzene, ethyl ether, n-butyl alcohol, cyclohexanone, and the still
bottoms from the recovery of these solvents.
The spent nonhdlogenated solvents, cresols and cresylic acid, nitrobenzene,
and the still bottoms from the recovery of these solvents.
The spent nonhalogenated solvents, methanol, toluene, methyl ethyl ketone,
carbon disulflde, isobutanol, pyridine and the still bottoms from the
recovery of these solvents.
Uastewater treatment sludges from electroplating operations
Spent plating bath solutions from electroplating operations
Flatimj bath sludges flora lite bottom of plating baths from electroplating
operations.
Spent stripping and cleaning bath solutions from electroplating operations.
Quenching bath sludge from oil baths from metal heat treating operations.
Spent solutions from salt bath pot cleaning from metal heat treating
operations.
Quenching waitevater treatment sludge* from metal heat treating operations.
Flotation tailings from selective flotation from mineral metals recovery
operations.
Cyanidation wastewater treatment tailing pond sediment from mineral metzls
recovery operations
Spent cyanide bath solutions from mineral metals recovery operations
Dewatered air pollution control scrubber sludges from coke ovens and
blast furnaces.
Wood preservation
KOOl Bottom sediment sludge from the treatment of wastewaters from wood preserv-
ing processes that use creosote and/or pentachloroiihenol
Inorganic picpnents
KU02 Waatewater treatment sludge from the production of chrome yellow and orange
pigments
K003 Mastewater treatment sludge from the production of molybdate orange
picynenti
K004. Waatewater treatment sludge from the production of zinc yellow pigments
Candidate
for incineration
Good Potential Poor
J
7
J
V
J
V
7
J
1
•1
V
V
V
V
V
V
V
J
Incinerator type
Liquid Rotary Kluidized
injection kiln ' bed
J "v 7
J 7 J. ...
J 7 7
7 7 7
7 7 7




7 7

                                                                                   (continued)

-------
TABLE A-l (continued)
EPA hazardous
waste number Hazardous waste
Inorganic pigments (conl'd)
KOOS Wastevater treatment sludge from the production of chrome green pigments
K006 Hastewater treatment sludge from the production of chrome oxide green
pi t^ne nt« (anhydious and hydraled)
K007 Wastewaler treatment sludge from the production of iron blue pigments
KOOB Oven residue from the production of chrome oxide green pigments
Organic chem
K009
KOIO
K011
KOI 2
KOI)
K0l4
KOI 5
K016
K017
KOI8
KU19
K020
K02I
K022
K02)
K024
K025
K026
K027
K02B
KU29
Icals
Distillation bottoms from the production of acelaldehyde from ethylene
Distillation side cuts from the production of acelaldehyde from ethylene
Bottom stream from the wastewaler stripper In the production of
acrylonitrile
Still bottoms from the final purification of acrylonitrile in the pro-
duction of acrylonitrile
Bottom stream from the acetonitrile column In the production of
acrvlonitrile
Bottoms from the acetronitrile purification column in the production of
acrylonitrile
Still bottoms from the distillation of benzyl chloride
Heavy end* or distillation residues from the production of carbon
letrachloride
Heavy ends (still bottoms) from the purification column in the
production of epichlorohydr in
Heavy ends from tract lonalion of ethyl chloride production
Heavy ends from the distillation of ethylene dlchloride in ethylene
dlchlor idr product Ion
Heavy ends from the distillation of vinyl chloride in vinyl chloride
monomer production
Aqueous spent antimony catalyst waste from fluot omelhanes production
Distillation bottom tars from the production of phenol/acetone from
c ume lie
Distillation light ends from the production of phthalic anhydride from
naphthalene
Diat illation bottoms from the production of phthalic anhydride from
naphthalene
Distillation bottoms from the production of nitrobenzene by the
nitration of benzene
Stripping still tails from the production of methyl ethyl pyrldines
Centrifuge icsidue from toluene dilsocyanate production
Spent catalyst from the hydrochlorinator reactor in the production of
1,1,1-tr ichloioethdiie
Waste from the piodiicl stream stripper in the production of
1,1, 1-trithloioelhane
Candidate
for incineration
Good Potential Poor
V
V
V
V
J
V
V
J
V
J
V
V
J
V
v1
V
Incinerator type
Liquid Rotary .Fluidized
injection kiln bed


V V V
f
V -1
J V
V V
V V
V V
J V
V V V
V V

                                                          (continued)

-------
                                                            TABLE  A-l   (continued)
EPA hazardous
waste number
                                              Hazardous waste
       Candidate
   for incineration
Good   Potential   Poor  'injection
                                                                                                                         Liquid
                                                                                                                               Incinerator type
                                                                                                                                   Rotary
                                                                                                                                    kiln
Fluidized
   bed
Organic chemicals (cont'd)
  K030          Column bottoms or heavy ends from the combined production of trichloro-
                  ethylene and perchloroethylene	
Pes'licidei
  KU31
  K032
  KU33
               Dy-products salts generated  in the production of MSHA and cacodyllc acid
               Hastcwater treatment sludge  from the production of chlordane
               Uastewaler and scrub water from the chlorination of cyclopentadienc In
 	the production of chlordane	
  K034Filter  solids from the  filtration of hexachlorocyclopenladiene in the
                  production of chlordane
  K035          Uastewaler treatment sludges generated  in  the production of creosote
  K036          Still bottoms fron toluene reclamation  distillation in the production

K037
K038
K039
K040
K041
K042
K043
of disulfoton
Wastewater treatment sludges from the production of disulfoton
Wastewater from the washing and stripping of phorate production
Filter cake from the filtration of diethylphosphorodithoric acid in the
production of pliorate
Wasteuater treatment sludge from the production of pliorate
Wastewater treatment sludge from the production of toxaphene
Heavy ends or distillation residues from the distillation of tetrachloro-
benzene in the production of 2,4.5-T
2,6-Dichlorophenol waste from the production of 2,4-D
V
V
V
V

v y
V
Explosives
  K044
   K04S
   K046
   MM
                Wasteuater treatment  sludges  from  the manufacturing and processing of
                  explosives
                Spent carbon from the treatment  of wastewater containing explosives
                Uastewaler treatment  sludges  from  the manufacturing,  formulation and
                  Inkling of l»A
-------
TABLE A-l (continued)
KfA hazaidous
waste number
Leather tanning
K054
KOSS
KOS6
KOS7
KU58
KOSS
lion and steel
K060
K061
KOr.2
K063
Primary copper
KU64
Primary lead
KObS
Primary zinc
K060
KUG7
KObU
Hazardous waste
finishing (conl.'d)
Chrome (blue) shavings generated by the following subcategorles of the
leather tanning and finishing industry! hair pulp/chrome tan/retan/
wet finish) hair save/chrome tait/retan/wet Finish; retan/wet finish)
no lieamltouse; through- the-bluei and shearling
Buffing dust generated by the following siihcategorlei of the leather
tanning and finishing Industry: hair pulp/chrome tan/retan/wet
fininh) hair save/chrome tan/retan/wet finish; retan/wet finish) no
beamhousej and throiujh-the-blue
Sewer screenings generated by the following suhcategories of the leather
tanning and finishing industry; hair pulp/chrome tan/relan/wet finish)
hair save/chrome tan/re tan/wet finish) retan/wel finish) no> beamhouse)
throuijh-lhe-hlue^ and shearling
Uatlewatet treatment sludges generated by the following subcategories of
the leather tanning and f InUliiiuj industry) hair pulp/chrome tan/relan/
wet finish) hair save/chrome lan/retau/wet finish; letan/wet finish,- no
bcamhouse) tin omjli-lhe -blue and shearling
Waslewatei treatment sludges generated by the following snfacategories of
the leather tanning and finishing industry: hair pulp/chrome tan/retan/
wet finish; hair save/chrome lan/retan/wet finish; and tlirouijli- thr-blue
Maslewater treatment sludges generated by the following sulicatcgory of
the leather tanning and finishing industry: hair save/nonchrome tan/
retan/wet finish
Ammonia still lime sludge from coking operations
Emission control dust/sludge from the electric furnace production
of steel
Spent pickle liquor from steel finishing operations
Sludge from lime treatment of spent pickle llcjuur fiom steel finishing
operation*
Acid plant bluwduwn slurry/sludge resulting from the thickening of
blowiluwn sluriy from prlm.iiy copper product Ion
Surface impouiiibient solids contained in and dredged from Mir face ira-
pouniknenta 4t primary lead smelt imj f.icililiea
Sludge from treatment of process wastewater and/or acid plant, blowdown
from primary zinc production
Electrolytic anode alimek/sludges from primary zinc production
Cadmium plant leach residue (lion oxide) from primary zinc pioducllon
Candidate Incinerator type
for incineration Liquid Rotary Fluidized
Good Potential Poor inlection kiln . bed
J
J
J
•i
J
J
V
J
5
V
V
•i
•i
7
                                                           (conlinurd)

-------
TABLE ~A-1  (continued)
EPA hazardous
visit i«w*">» Hazardous waite
Secondary
lead
tn<« ^
7
7 7
7

7 ; 7
} }
7
i J i
V 7 7
7 . V
V 7
J
7
7 	
V
7
7 ^ V
icrator type
Rotary fluidized
kiln bed
'
7
7
V

'
7
7
i
7
7
i
7
7

7
7
7
7
7

7
	 1 	
J
7
	 j 	
V


7
V
7
                                                               (continued)

-------
TABLE /\-l (continued)
EPA hazardous
wa»te n'w)>*r Hazardous uastt
Discarded conmerclal chemical products.
off-apecificolion species, containers.
and spill residues thereof (conl'd)
P041 O.O-Dlethyl phosphoric acid, 0-p-nltropltenyl ester
P042 3.4-Dihydro*y-alpha-(»ethylaralno)-methyl benzyl alcohol
P04J Dl-lsopropylfluorophosphate
P044 Dlnethoate
P045 3,3-Dimethyl-i-(i»ethylthio)-2-butanone-0-|(n.ethyl4iiUlobluret 	
POSO Endosulfan
P051 Endrln
POS2 Elhylcyanide
POS3 Etiiylenediamine
POS4 Cthylenelnine
POSS Ferric cyanide
POS6 Fluorine
POS7 2-Fluoroacetamld*
POSH Fliioroacetlc acid, sodium salt
P059 lieptachlor
endo-dinetlianoiiaphthalene
P062 llexaelhyl tetraphoaphate
P063 Hydrocyanic acid
P064 Isocyanlc acid, methyl ester
P06S Mercury fulminate
P0(>& Me thorny 1
P067 2-Methylazlrldlnc
P068 Methyl liydrazine
P069 2-Hetliyllactonitrlle
P070 2-Nethyl-2-(nelhylthlo)proplonaldehyde-o-(methylcarbonyl) oxlme
P071 Methyl parathion
l>072 l-Naphtliyl-2-thiourea
P071 Nickel carbonyl
P074 Nickel cyanide
P07S Nicotine and salts
P076 Nitric oxide
P077 p-Nltroaniline
P07B Nitrogen dioxide
POCO Nitrogen tetroxide
POOI Nitroglycerine
PUU2 N-Nitrusodimetliylamlne
P003 N-Nilroaodiphenylamine
Candidate Inci
for incineration Liquid
Good Potential Poor injection
*
V '
J V
i
v' i
J i
v }
v v
7
7 J
1 '
i . i
7
J 1
v v J
i j
] v
V
V ^ ' V
V
teritor
Rotary
Kiln
i
7
J
V
4
i
V
7
- \
•i
V
7
7
V
7
V
type
Fluidized
_ bed
V
v
' \ ••
J
V
V
V
V
j
V
V
V
7
V
V
V
                                                              (continued)

-------
                                                         TABLE ft-1  (continued)
V|
N
EPA hazardous
waste number
Hazardous waste
Discarded commercial chemical products,
off-specification species, containers,
and spill residues thereof (cont'd)
POQ4 N-Mltrosoinethylvlnylaoilne
POH5 Oc tame Ihylpyrophosphor amide
POU6 Oleyl alcohol condensed with 2 moles ethylene oxide
P007
pooa
P009
P090
P091
P092
P093
P094
P095
P096
P097
P090
P099
PlOO
P101
P102
P103
P104
P10S
P106
P107
PlOB
P109
PllO
nil
P112
P113
PI 14
PUS
rue
P117
PUB
P119
P120
P121
P122
U001
U002
U003
Osmium tetroxide
7-Oxabicyclo|2.2.1)heptane-2,3-diearboxylic acid
Parathion
Pentachlorophenol
Phenyl dichloroarslne
Phenylmercury acetate
N-Phenylthiourea
Phorate
Phosgene
Ptiosphine
Phosphorothiolc acid, 0,0-dimethyl ester, 0-«ster with N.N-ditnethyl benzene
sulfoti amide
Potassium cyanide
Potassium silver cyanide
1.2-Propanedlol
Propionitrlle
2-Propyn-l-ol
Selenourea
Silver cyanide
Sodium aside
Sodium cyanide
Strontium eulflde
Strychnine and salts
Tetraethyldlthiopyrophoaphate
Telraethyl lead
Tetravthylpyrophotphate
Te Irani Ironic thane
Thai lie oxide
Thallium selenite
Thallium (1) aulfate
Thiosemicarbazlde
Thluran)
Trlchloromethanethlol
Vanadlc acid, ammonium salt
Vanadium pentoxide
Zinc cyanid«
Zinc phosphide 	 	
Ace t aldehyde
Acetone
Acetonltrlle
Candidate
for incineration
Good Potential Poor
J
J
V
V '
V
V

v V
t
4 v
V
'• v
V
J
J
-1
V
V
V
V
Incinerator type
Liquid
injection
J


V
V
V
V


V



j
Rotary
kiln
V
7
V
|
V
V
V
V

7
V
i ...
V

V
Fluidized
bed
J
.V

|
V
V
j
v

J
i
,
i

r
                                                                                                                      (continued)

-------
TABLE fl-1 (continued)
(PA hazardous
waste number Hazardous waste
Discarded commercial cheMlcal product!,
off -specification specie*, containers,
and spill residues thereof (cont'd)
U004 Acetoplienone
U005 2-ActtylamlnoUourene
U006 Acetyl chloride
U007
UOOB
U009
uolo
U011
UOt 2
uolj
U014
U015
U016
0017
uoia
UOH
0020
11021
U022
U023
11024
U02S
U026
U027
U029
U030
U031
U032
U013
U034
U03S
U036
U037
U03B
U039
0040
11041
U042
U043
UU44
U045
Acrylamlde
Acrylic acid
Acrylonltrile
6-Ai»Jno-l,la,2,B,Ba,6b-he»nliyilro-0-(liyJro)iyroel!iyl)B-metlioxy-5-methylc«rli«-
nate azirlno(2' ,3' :3,4) pyrrolO(l.2-a)lndole-4, 7-dione (ester)
AmUrule
Aniline
Asbestos
Auranine
Azaserine
Benz|c)acridine
Bentat chloride
Benzene
Benzenesulfonyl chloride
Benzidine
Benzo|t|pyrene
Uenzolrichloride
l)ls(2-chloroethoxy)n>tltune
BU(2-chioroeihyi) ether
N,N-Bis(2-chloioethyl)-2-naphthylamine
Bis(2-chloroi9oj>ropyl) ether
Bromune thane
4-Browophenyl phenyl ether
n-Dutyl alcohol
Calcium clironale
Caibon^l fluoride
Chloral
Chlorambucll
Clilordiine
Chlorobenzene
Chlorohenzilate
p-Chloro-m-cresol
Chlorodibronone thane
l-Chloro-2.3-epOKypropane
Chloroelhyl vinyl ether
Chloroetheue
Chloroform
CMorome thane
Candidate
for incineration
Good Potential Poor
' J
4
4
V J
4
4
J v
J
1 i
)
4 J
•1
'
V
J
1
V
J
•J
tnciiicrft t or type
• Liquid Rotary F luldizecl
injection kiln bed
V
V
J

V
j
j
V
V
V
V
V
v
V
V
V
V
j
V
V
/
j
i
j
V
V
V
— J—
V
4
/
V
V
7
V
V
V
•J
V
4
•1
•1
J
,
{
V
V
V
L
J
V
i
V
V

V
V
V
                                                           (continued)

-------
                                                          TABLE A-I  (continued)
N.

BPA liazardou*
waste number Hazardous waste
Discarded commercial chemical products,
off-specification species, container*.
and spill residues (.hereof (cont'd)
U089 Oielhylstllbeitrol
UOOO Dihydro»aCroLe
U011 3,3'-Dimelhoxybenzldlne
U092
IW3
U094
U095
U096
U09T
U090
U099
U100
U101
U102
U10]
U104
U105
U106
U107
uioa
U109
U110
Ulll
U112
UllJ
U'M
U11S
U116
uui
una
U119
U120
um
1)122
U121
U124
um
U126
U127
U128
UI29
una
DimeUiylamine
p-Dimethylaminoazobenzene
7, 1 2 -Dl me tliylben?. J^a) anthracene
3,3'-Dimctliyll)ci)zidinc
a) pita -alpha -Dime lliylbenzylhydroperoxi.de
Dimethylcarbamoyl chloride
1, l-Oiraethylhydrazine
1,2-Dimethylhydrazine
Dimethylnitrosoamine
2,4-Oimethylphenol
Dimethyl phtiialate
Dimethyl sulfate
2,4-Dlnltrophtnol
2, 4 -Din Itro toluene
2, 6-Dinllro toluene
ol-ii-octyl phtlialate
1,4-Dioxane
1 , 2-Diphenylhy
-------
                                                    TABLE ft-1 (continued)
\
N.

EPA Itatacdout
wa*te number Hazardous waste
Discarded cotmerclal chemical products,
off-specification species, containers,
and spill residues thereof (cont'd)
0016 Chlormethyl methyl ether
0047 2-Chloroiiaptithaleiie
0048 2-Chlorophenol
U049
U050
U051
0052
0053
0054
0055
00 i6
U0'j7
uoso
0059
OObO
OOtil
00b2
006 J
0004
U06S
0066
U067
0060
0069
0070
0071
0072
0073
U014
00/5
UOV6
00/7
0071)
0079
ooao
ooai
00112
UOlll
00(14
00(15
oo»r>
110(17
UOIIO
4-ChIoro-o-toluidine hydrochloride
Gliryscne
Cresale
Cresols
Crolonaldehyde.
Cresylic acid
Cisnene
CyclohcKane
CycloheNanoiie
Cyclopliospliamide
Daununyc In
ODD
DOT
Diallatc
Dibenz (a, hi anthracene
Dibenzo|a,l)pyrene
D Ibromoclt lor one t Itanc
l,2-Dibrorao-3-chloropropane
1.2-bibromoethane
Dibromomelliane
Ol-n-butyl phthalate
1,2-Dichlorobenzene
, 3-Oichlorubenzene
,4-Dichlorobenzeue
.J'-Dichlorobenzidine
,4-Dlchloro-2-bulene
Ichtorodif liioroiurtliane
, l-Dlch)oroetliAiie
j 1-Dlchloroelbyjene
,2-traiis-dichloroethylene
DichloroMclliane
2,4-Oicl\loiopli*nol
2,6-Dichlorophenol
1 , 2-Dlchloi opropane
1^3-Dichloropropane
Oiepoxybiit.ine
l,2-Uletliylliyi)raziiie
0,O-Dietliyl!>-metliyl ester of pliosphorodithiolc aciil
Dlethyl plitliaUtc
for
Good
V
V
V
4
J



J





V
V
V
Candidate
incineration
Potential Poor
v
V


7
j
• J
V
j
7
J
J
V
V
V
J

Incinerator type
Liquid
Injection
V
J
V
j
j
J
7


v
J
V
V
v
7
1
V
Rotary
kiln
, -1
V
V
7
J
V
7
V
7
7
7.,.,,
7
7
7
7
7
7
7
7
V
1
7
Fluidized
bed
7
• 7
7
7
7
7
j
7
7

j
7
7
. i. . ..
7
7
(continued)

-------
                                                         TABLE ft-1  (continued)
71
X
EPA hazardous
waste number
Hazardous waste
Discarded commercial chemical products,
off-specification species, containers,
«nd spill residues thereof (cont'd)
UOU9 Ditlhylslilbestrol
U090 Diltydrosafrole
1100 1 3L3'-Diincllioxybenzidine
U092
U093
UO'M
U095
U096
U097
IJO'JH
ueiiz(a|anthracene
3.3'-Djmethylbenzidine
alpha- alpha-Dime thy Ibenzylhydroperoxlde
DimethylcarbAmoyl chloride
1, 1 -Dime thy Ihydrazi ne
1 ,2-Dlmethyihydrar.ine
D inie t hy 1 n i 1 1 osoain 1 ne
2,4-Dimethylpiienol
Dimethyl phthalate
Dimethyl sulfate
2,4-Dini tiopliciiol
2.4-Dinitiotolucne
2,6-Diniliotolucne
Di-n-ociyl phlhalate
1,4-Dioxane
1,2-Diphenylhydrazine
Dipropylamine
Dl-n-propylnllrosamlne
Ethyl acetate
Ethyl acrylate
Ethylenebisdithiocarbamate
Ethylene oxide
Ethylene thiourea
Ethyl ether
Ethylmethacrylnle
Ethyl methanesulfnnate
Fluoranthene
Fluorotr ichloroinetharie
Formaldehyde
Formic acid
Furan
Furfural
Glycidylaldehyde
llexachlorobeiizenc
llcxachloroliutadiene
llexachl»rocycluliex»ine
llexachlorocyclnpeiitadlene
for
Good
7
7
7
7

7

7

7
7
7
7
7
7
7
7

Candidate
incineration
Potential Poor

7 -
7
i
7
7
7
7
7
7
7
7
7

7
. 7
Incinerator type
Liquid
injection
7

7
7
7
7

7
7
7
7
7
7
7
7
7
7
7
7
7
Rotary
kiln
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
J
7
7
7
7
7
7
7
7
7
7
Muidized
bed
t>
7
7
7
. 7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
                                                                                                                     (continued)

-------
TABLE fl~l (continued)
EVA Uattrdoiift
Dl«c»ul«ctif Jc*l lY<>t» lull Id*
llyilranydlinetliy 1 arilne oxiJc
lni)«no(1.2,3-cd)pyrene
lodon«th«ne
Irott Ocxtcftn
Uobutyl «lcoliol
L«*ioc«rptiie
i.ff«i) «id>acet«te
Hnlcic •iiliydride
Mjteic hydtalide
H«tQilunttriU
He lphrtl*A
ttefctify
NttlunelMal
HetliA|>yrileiif
Hvthyi clilorocii*i>O[v&te
l-Ht:thy)clioliiiilhrene
4,4'-Metliyleiie-bU-(2-elilofo«iifliii«)
ttetliyl etliyl kctune
Mrtlivl ethyl fcetuot peroxidf
Hetltyl iBobiilyi tic tone
Methyl weUucryUte
U-Helltv } 'H* -oil ro^W-iil 1 rosoyi**ii»i<) Ji*e

("Ndplithy Irtwiiic
4'Nitroiiliciiol
W-Ni t f osoili -ii-l>ul y 1 «mln*
M-Hi ti'uaodit'Uiditol ami(^
C*ndid*t«
for iiiciiicrktii
Good Potential
\
1'
4
4
1

4
4
4

4
4
4
V 	 i 	
	 ^
V
V
^_
•i
4
InciuerAlor type
an lit)\i(d
Poor injection
•
7
	 Y
V
	 / . •
4
4
4
4
	 V _, 	
4
V .
j
V
	 -X 	
V

V
i
Houry
kiln
4
: 4.,
'
i
V

i
4
	 r 	 	
V
4
•I
V
•/
	 *— —
4
4
i
4
4
_....i— .
V
Fluidited
bed
y
7
- '
V
	 	 — -i 	
V

— ^ — «-»l. 	 —
V
	 . — , 	
4
4
— j-
V
J.
4
4
4
4.
J
                                                            (caul iimed)

-------
                                                         TABLE A-1  (continued)
X
V/4
EPA hatardout
waste muivlier Hazardous waste
for
Good
Discarded connercial chemical products,
off-specification species, containers,
anil spill residues thereof (cont'd)
U174 «-Nitrosodiclhylamiiie
U175 H-llilrosodi-n-propylamine
UI76 H-Nitioso-n-ethyJuiea
U177
U170
Ul/9
U1UO
U1BI
UIU2
uiai
U104
HI US
U106
U1U7
UlUtl
UlO'J
U1DO.
UI'Jl
U)'J2
Ul'JJ
U1
-------
                                                        TABLE fl-1 (continued)
S
\
KI'A hazardous
watt* number
Hazardous waste
Discarded commeici.il chemical products.
off-specification species, containers.
and spill residues thereof (cont'd)
0220 Toluene
0221 Toluenediamine
0222 o-Toluldlne hydrochloride
U22J
0224
0225
0226
0227
0220
0229
0230
0231
0232
0233
U234
0235
U236
0237
0230
0239
Other hazardous
SIC code number
2865
2865
2065
2065
2069
20C9
2069
2069
2009
2RC9
20(,9
2IK.9
2flf.9
2295
2069
Toluene diisocyanale
toxaphene
Tribromome thane
1,1,1 -Trlcliioroe thane
1,1,2-Trlchloroetlune
Trlcliioroe the|)l*dieiie and cyclopeiitadlene
Still bottom tiom production of lui final
Unrecovere
-------
TABLE  fl-1  (continued)


Candidate Incinerator type
EPA hazardous
waste number
Other hatardous
SIC code number
2069
21)69
2822
2069
2869
2S69
2069
2069



3333
3339
3339
3339
3339
3341
Hazardous waste
wastes (cont'd)
Process clean out sludges from production of 1, 1, 1- trichloroethane
Heavy ends and light ends from the production of methyl acrylate
Polyvinyl chloride sludge from the manufacture of polyvinyl chloride
Still bottoms from the purification of fluoromethanes in the production
of fluorome thanes
Heavy ends and light ends from the production of ethyl acrylate
Heavy ends from the production of glycerine from allyl chloride
Heavy ends from the distillation of acetic anhydride in the production
of acetic anhydride
Light ends from tiie distillation of acetaldehyde in the production of
acetic anhydride
• Reactor cleanup wastes from the chlorination, dehydrochlorlnatlon or
oxychlorination of aliphatic hydrocarbons
• Fractionation bottoms from the separation of chlorinated aliphatic
hydrocarbons
• Distillation bottoms from the separation of chlorinated aliphatic
hydrocarbons
• Reactor cleanup wastes from the chlorination or oxychlorination of
cyclic aliphatic hydrocarbons
• Fractionation bottoms from the separation of chlorinated cyclic
aliphatic hydrocarbons
• Distillation bottoms irom the separation of chlorinated cyclic
aliphatic hydrocarbons
• Batch residues from the batch production of chlorinated polymers
• Solution residues from the production of chlorinated polymers
• Reactor cleanup wastes from the chlorination of aromatic hydrocarbon
• Fractionation bottoms from the separation of chlorinated aromatic hydro-
carbons
• Distillation bottoms from the separation of chlorinated aromatic hydro-
carbons
Zinc production: oxide furnace residue and acid plAnt sludge
Ferromanganese emissions control: baghouse dusts and scrubualer solids
Ferrochroaie silicon furnace emission control dust or slud.je
Ferrochrome emissions control: furnace baqhouse dust, and ESP
Primary antiinony-pyrometalluiglcal blast furnace slag
Secondary lead, scrubber sludge from S02 emission control, soft lead
production
for incineration • Liquid
Good Potential Poor injection
, ,
7
J
7 7
7 V
7 7
7 7
7 7
7 7
7 7
7 7
7 7
7 7
7
7
7
7
Rotary
kiln
7
7
7
7
7
7
7
7
7
7


Fluidlzed
bed
7
7
7
• 7
7
7
7
7
7



                                                             (continued)

-------
TABLE fl-i (continued)
EPA hazardous
waste number
Other hazardous
8IC code number
3)41
3)41
3)41
3141
3341
3691
369 1
3691
3691
3691
3692
2016
2819
2034
2051
2051
201,9
2869
2669
3312
3322
3331
3312
3339
33)9
1094
1099
1475
2074
2819-2874
2012
2012
Hazardous waste
wastes (cont'd)
Secondary lead-whit* metal production furnace dim I
Secondly copper-pyromelaUurgical . blast furnace slag
Secondly cojiper-eleclrolytlc refining wailewaler treatment sludge
Secondary aluminum dross smelting-high nail slag plant residue
Zinc-cadmium metal reclamation, cailmitin plant re a i due
Lead acid storage battery production wastewater treatment sludges
Lead acid a tor age battery production cleanup wastes from cathode and anode
paste product Ion
Nickel cadmium battery production wastewater treatment sludges
Cadmium silver oxide battery production waslewater treatment sludijes
Mercury cadmium battery production uastewater treatment sludges
Hagnesium catbon battery production chromic acid waatewAler treatment sludges
Ash from Incinerated still bottoms (paint and plcjnent production)
Arsenic bearing waitewater treatment sludges from production of boric acid
Arsenic or organo-arsenlc containing wastewater treatment sludges frost pro-
duction of veterinary Pharmaceuticals
Wastewaler treatment sludges from point production
Air pollution control sludges from paint production
By-product salts in production of MSMA
By-product salts in production of cacodylic acid
Leaf) slay from ) id alkyl production
Steel finishing) Alkaline cleaning waste
• Haste pickle liquor
• Cysnlde-bearliul wastes from electrolytic coating
• Chronate and dichromate wastes from chemical treatment
• Descaling acid
Lead/plienollc sand-casting waste from malleable iron foundries
Primary copper smelting and refining electric furnace slag, converter dust,
acid plant sludge, and icverberatory dual (T)
Primary lead bloat furnace dust
Primary antimony-electrolytic sludge
Primary tungsten-digestion residue
Haste rock and overburden front uranium mlnituj
Chlorlnator residues and clarlfier sludge from zirconium extraction
Overburden and slimes from phoiiphate surface mining
Haste gypsum from phouphoric acid production
Slag and fluid bed prills from elemental pliosphorun production
Sodium calcium sludge- from production of chlorine by Doun Cell process
Mercury bearing brine purification muda from mercury cell process in
chlorine production
Candidate Incinerator lyjir
fur incincral Ion Liquid Rol.iry Kluidizcd
fiood Potimtial Poor injection kiln bed
*
V
V
J
1
J
V
J
1 —
V
j
V
V
V
V
i
7
V
V
7
J
1
V
J
V
V
V
                                                          (continued)

-------
                                                                         TADLE  A-I   (continued)
I
V
N
EPA hazardous
waste number
                                                                                                                 Candidate
                                                                                                             for incineration
                                                                                                                              Incinerator type
                                                          Hazardous watte
               	               Rotary   Fluidized
Good   Potential   Poor   injection     kiln	bed
                                                                                                                       Liquid
Other hazardous wastes  (cont'd)

SIC code nunJjer
  2016          Mercury bearing vasteuater treatment sludges from the production of
                  mercuric  sulfide pigment
  2816          Chroralun bearing wastewater treatment sludges from the production
                  of TiOj plynent by the chloride process
  2816          Arsenic bearing sludges from purification process in the production
                  of antimony  oxide
  2016          Kntinony bearing wastewater treatment sludge from production of
                  antimony  oxide
                                                                                                                             V
                                                                                                                             V
                3312
                             Iron making:   Ferromaganese blast  furnace dust
                             • Ferromanganeae blast  burnace  sludge
                             • Electric furnace dust and sludcje
               Use this  table for Indicative guidance only.   For  decision making, read the material presented in  the  text.

-------
APPENDIX B

-------
Telecon                                             10/23/80
  w/Doug Cooper
  Rollins E. S.
  Deer Park, Tx.


Texas Air Control Bd. requires  at  least  1  stack  test/yr. - thus

far in 198.0 there have been  4-5 such  tests,  for  various reasons.

All tests show 99+% on HC1 recovery in scrubber.   Latest test

  September 80 showed 99.95% recovery of HC1.


Texas Air Control Board  requires maximum emissions of  10#/hr.,

HC1 or 40#/hr. CI.2  from  any  incinerator.   Knowing  nature of

wastes to be handled in  southern Texas,  Rollins  installed scrubber

via management decision.


Also, TRW report is  incorrect in that dil.  lime  slurry was used

in test burns run @  Rollins, not water.

-------
Telseon                                               10/23/80
  w/John Trapp
  Cincinatti Munic. Incin.
EPA tests run   2 months ago.


Had difficulty in stack gas analysis, using Bendix detector

tubes.


No HC1 or Cl, detected in stack gas although waste feed analyzed

2.5% Cl (organic Ci).   Pre-scrubber gas analysis showed HC1

but below theory predicted by waste analysis.  Sampling and

test work by Pollution Control Sciences, Inc.


DE on organics was 99.5%.


Desires good HC1 method if any known.??


Planned scrubber installation on basis of waste expected to be

burned but there was and is no leqal requirement.


To work w/a Mr. Freeman of EPA. (Cinn.) on a dry run exercise

for obtaining an EPA permit to operate the Cincinatti L/F I

Waste Disposal facility.

-------
Telecon                                       Date:  10/24/80
  George Thomas
  Eastman Kodak
  716-722-2363
  Engr. & Envir. Tech.  Services
  Rochester, N.Y.

Unit has a large capacity, hi-energy  (60"  HC0    P) venturi

scrubber.  "E" never  tested across  scrubber, but stack gas con-

sistently shows < 7.5 Ib/hr Cl, which is N.Y. State require-

ment.  Waste loading  is equivalent  to 100-200 ppH of HC1.  (Thus,

E = 92-97%)  They have  not, and do  not know how  to sample for

HC1 in the hot zone.   They use EPA  Method  5 for  stack samplings,

with dilute NaOH in the gas impingers of the anal, equipment.

There are small, but  unknown  quantities of Br &  I in the stack,

but there are no limitations  on these emissions.  E.K. is

working with the state  on possible  12 and  Br2 emission limits.

The venturi scrubber  uses a dilute  NaOH scrubbing medium.

-------
Telecon                                         10/24/80
  Jim A. Mullins
  Shell Chemical Co.
  Houston, Texas
  713-241-2723

AM   Shell has operations in Tx and La which require scrubbers.

The Tx operation have one older incinerator which handles liquid

chlorinated HC wastes (and which can accept gaseous wastes also),

and two newer units which operate only on gaseous wastes from

chlor. HC operations such as VC.  The vapor units have scrubbers

which are composed of 2 sections.  Each lower section uses water

as the scrubbing medium, and each upper (cleanup) section uses

dii. caustic soda.  *(See p. 5.)  There have been some concerns

by Shell regarding free Cl2 which has also been detected.  How-

ever, the principal concern in the past was that of opacity of

stack plume.  The plant complex also emits NH3 qas and amines,

and any free HC1 combines with these compounds to form an objec-

tionable and visible air pollutant.  Thus, Shell tries to

operate with HC1 emissions of no greater than 5 ppn.  Shell's

permit  from T.A.C.B. requires BAT for the units, but total HC1

and Cl2 emissions are regulated from their complex  (sort of a

"bubble" concept), as opposed to an individual emission

requirement.


In La., there are 2 incin. units:  one for combined liq and vapor

wastes  from chlor. HC operations, and one for vaoor wastes, only.

The vapor unit has a complete back-up unit, so that the chem.

process operations will not be shut down by an incin. failure.

La.  has no HCi emission reqmts., and each unit has to pass

-------
the state permitting  authority.   However,  U.S.  regulations on

VCM emissions do apply and override.   BAT  is  specified.  All La.

units use Mississippi river  water (which happens  to be slightly

alkaline) as scrubber medium.   **(See p.  5.)


Mr. Mullins will call again  in answer to my questions, re:

     (a)  Scrubber  E.

     (b)  Any problems of sampling for HC1 in hot zone prior
          to scrubber.

     (c)  Reliability and method of HC1 analysis.

     (d)  Any difference between hot zone, HC1 analysis, and
          estimated cone.  HCi based on waste feed analysis.

-------
2nd Call From Muilins                               10/24/80






* Correction to p. 2.  The liq. incin. in Tx has a 3-stage



scrubber, each stage using H2O.






** The liq. incin, in La. has a 3-stage quench, which uses:



(a) H2O, (b) dil. caustic soda, and (c) Miss, river water.



This incin. had been giving off considerable mist, and the



demister did not work well.  The 3rd staqe scrubber,  usinq river



water, was then installed as a demister.  It utilizes large



quantities of water and does demist, satisfactorily.






Thermodynaraic equilibrium calculations show   1000 ppm Ci^ in



gases from the incinerator, and Cl2 is therefore removed in the



La. liq. unit, and in all vapor units usinq proprietary tech-



nology.  Licensed technology is used to remove Cl2 at the Tx



liq. unit.






A.11 scrubbers have 99% E or better.  Calculations for E are based



on Cl analysis of feed to the units, and there is no hot gas



sampling.  On a recent test of the Tx liq. unit, stack gases



analyzed 40-50 ppm Cl2 and 22 ppm Hcl.  Feed to this  unit is 6S*



Ci, by weight.






A comment was also made that HCi emission seems to correlate with



escape of metal particulates.

-------
                        Scrubber    Data  from
                   "Destroying  Chemical  Wastes  in
                   Comraercxal-Scale Incinerators"
                       Facility Report No.  5
                            USEPA   1977

                        by A. D. Little  Co.


Test runs made on  Chemolite Inc.  System at 3 M Co.  0 Cottage

Grove, Minn.  System  consists  of  rotary "kiln,  secondary combus-

tion chamber, quench  elbow  and quench chamber,  hi  energy venturi

scrubber, sieve tower,  demister,  500 hp fan, and stack.  Wastes

burned were from PVC  plants, and  consisted of  2Q%  solids (mostly

PVC) and 72 H2O.   Btu rating of the unit is  90 x 106 Btu/hr.


HC1 in the combustion gas analyzed 14R5-1660 mg/m-^.  Water  is

scrubber liquor.   In  two closely  monitored runs, scrubber

efficiency was 99.1%  and 99.3%.
                                           I.  Frankei
                                           11/14/flO

-------
APPENDIX C

-------
           UN.TED STATES ENViRONMENTAL PROTECTION AGENCY
                          WASHINGTON. D.C. 20450
                             June  5,  1980
                                                       OFFICE OF
                                                     GENERALCOUNSEU
MEMORANDUM

SUBJECT:  Regulating Hazardous Waste  Incineration
FROM:     Michael Dworkin
          Attorney         /"
          Water and  Solid  Waste  Division  (A-131)

TO:       Ed Martin
          Program Manager
          Hazardous  &  Industrial Waste Division  (WH-565)
     I have attached  the  consent  decree  in the Rollins' incinerator
case.  The technical  details  begin at the end of page 3.   They in-
clude, temperature/  waste lists,  inflow and temperature  recording
criteria, monitoring  and  alarm requirements, and automatic cut off
devices.  They are  all significant, but  I am especially interested
in the  list  of  "priority waste".  How  does that compare  to  Walt
Barber's idea for specific  listed wastes?   The decree was sent to
me by Bill  Freeman in Region IT'S Enforcement  Division.   He  sug-
gested that  Mike Pucchi  was  the  engineer  who had  developed the
technical standards.

     Steve Silverman  has  given me the names  of two people who  were
very helpful  to  him  in  predicting the  health  consequences  of in-
complete or  partial  combustion  of various  toxic wastes.   One  is
Forrest Mixon, (919)  541-5917.    Silverman thinks he works for
Research Triangle  Institute (?),   an  EPA contractor.   The other is
Dr. Dwayne  Nichols   (919)  541-6155  in   Raleigh,  North  Carolina.
Both of them have apparently  worked with Walt Barber in the past on
predicting and modeling air effects of hazardous waste incineration.


Attachment

-------
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
                                    x
UNITED STATES OF AMERICA            :    JUDGMENT ON CONSENT
                                         Civil Action No.
       Plaintiff,                   :

   v.                               :

ROLLINS ENVIRONMENTAL SERVICES  (NJ) :
   INC.

        Defendant.                  :

	  x


     WHEREAS, pursuant to Sections 10S and 109 of the Clean Air

Act ("the Act), 42 U.S.C. $$7409, the Administrator of the U.S.

Environmental Protection Agency  ("EPA") has established air

quality criteria for specified pollutants, and promulgated national

ambxent air quality standards for pollutants for which such

criteria were established; and

     WHEREAS, pursuant to Section 107 of the Act, 42 U.S.C. $7407,

axr quality control regions have been designated throughout the

country; and

     WHEREAS, Section 110 of the Act, 42 U.S.C. $7410, mandates

that state implementation plans shall be promulgated to provide

for the implementation, maintenance and enforcement of air quality

standards in each air quality control region (or portion thereof^

within each state, and the New Jersey State Implementation Plan

("SIP") has been promulgated to comply with the mandate of

Section 110; and

-------
     WHEREAS,  a  regulation setting emission standards for inciner-




ators, modified  in Title 7,  Chapter 27,  Section 11.3(b)(2)  o*




the New Jersey Administrative Code (N.J.A.C. 7:27-11. 3(b) (2))




has been promulgated and is part of the SIP and is applicable to




the air quality  control region in which Defendant Rollins Envi-




ronmental  Services (NJ) Inc.'s ("Rollins") Bridgeport,  New Jersey




facility is  located; and




     WHEREAS,  The EPA issued a Notice of violation on June 9, 1977




pursuant to  Section 113(a)(l)  of the ACT:, 42 U.S.C. §7413 (a)(l)




finding an incinerator operated by Rollins at its Bridgeport, New




Jersey facility  ("the incinerator") to be in violation of N.J.A.C




7:27-11.3(b)(2); and




     WHEREAS,  pursuant to Section 113(a)(4) of the Act, 4? U.S.C.




§7413(a)(4),  conferences were held on September 23, 1977 and April




5,  1978 between  representatives of Rollins and EPA concerning the




above-cited  alleged violation; and




     WHEREAS,  on November 28, 1978, EPA  and Rollins entered  into




a Consent  Order  (Index No. 70131) pursuant to  Section 113 (a) (1)




of the  Act,  42 U.S.C.  §7413(a)(1), wherein  Rollins acknowledged




that  it was  in violation of the requirements of N.J.A.C. 7:27-




ll(b)(2)  on April 7,  1977 and for a period  extending beyond




thirty  (30)  days after its receipt of the above-mentioned Notice




of Violation,and wherein  Rollins  consented  to  the issuance of




said  Consent Order  and to its terms; and



      WHEREAS, the above-mentioned Consent Order  set  forth certain




requirements tnat were reasonably calculated to  ensure that

-------
emissions from Rollins' Bridgeport incinerator would comply with




the requirements of N.J.A.C. 7:27-11.3(b)(2); and




     WHEREAS, the above-mentioned Consent Order required that




Rollins submit monthly reports to EPA containing temperature data




on its incinerator and certain other information on the operation




of its inicnerator; and



     WHEREAS, Rollins' above-mentioned monthly reports indicated




that during the months of February, March, April, May, June, July




and August, 1979, operations at Rollins'  incinerator were in




violation of certain requirements of the  above—mentioned Consent




Order from time to time; and



     WHEREAS, at all times Rollins' representatives have comported




themselves in a forthright manner, and have  demonstrated a will-




ingness to cooperate with EPA in arriving at a prompt and equi-




table resolution of these proceedings; and



     WHEREAS, Rollins' Bridgeport incinerator is a "major station-




ary source" as that term is defined in Section 302(j) of the




Act, 42 U.S.C. §7602(j); and



     WHEREAS, pursuant to Section 113(b)  of  the ^ct, 42 U.S.C.




§7413(b), the Administrator of EPA (or his delegate) is mandated




to commence a civil action for appropriate relief whenever the




owner or operator of a major stationary  source violates any order




issued under Section  113(a) of the Act,  42 U.S.C. $7413(a); and




     WHEREAS, any action under Section 113(b) of the Ac-c, 42




U.S.C. §7413(b), is to be brought in the district court of the




United States for the district in which  the  violation occurred

-------
or in which the defendant resides or has his principal  place  of



business, 42 U.S.C.  §7413(b);  and




     WHEREAS, the  above-cited  violation occurred in the judicial




dxstrict over which  this  Court has jurisdiction; and



     WHEREAS, the  parties to this action believe that the  terms




of this Judgment will,  in combination with actions  taken and  to



be taken by the New  Jersey Department of Environmental  Protection,




have the effect of preventing  hazards to health or  the  environ-




ment attributable  to improper  incineration at the Rollins  facility;




and



     WHEREAS, EPA.  and Rollins, by their respective attorneys, have



each consented to  the making and entering of this Judgment perma-



nently enjoining and restraining defendant as specified herein,




assessing a civil  penalty as provided herein, and establishing a




scheme for liquidated penalties for any future violations  of  the



terms of this Judgment,  and the Court, without trial or adjudica-




tion of any issues of fact or  law, has considered the matter  and




has been advised,  it is  hereby



     ORDERED, ADJUDGED AND DECREED as follows:



     I.   This Court has jurisdiction of the subject matter of




this action and of the parties hereto.  This action arises under



Section  113 of the Acr 42 U.S.C. S7413, and 28 U.S.C. $$1331,



134 and  1355.  The complaint filled in this action states  a claim




uon which relief can be granted.



     II.  By  no later than thirty days after the date of this



Judgment, Rollins  shall pay by cashier's or certified check

-------
payable to the Treasurer, United States of America/ a civil




penalty in the amount of sixty five thousand dollars (S65,000.00)




in full satisfaction of all liabilities which "have been incurred




by defendant for the violation of the above-mentioned Consent




Order which occurred prior to the date of this Judgment.  Such




payment shall be remitted to the Assistant Attorney General,




Division of Lands and Natural Resources, U.S. Department of




Justice, Washington, D.C.  20530.



     III. The above-mentioned adminsitrative Consent Order  (Index




No. 70131) is hereby superseded by the following provisions of




this Judgment:



          Immediately upon the date of entry of this Judgment,




and at all times thereafter, Rollins shall conform its inciner-




ation operations at the Bridgeport, Mew Jersey facility to the




following requirements:



          (A)  When the incinerator temperature is below 600° F




as measured at the hot duct, no wastes shall be incinerated.



      600" F only commercially-available  fuel shall be incinerated.




          (B)   "Priority Wastes" are hereby defines as follows:




                (1)  Any wastes, waste mixture, or waste stream




                    containing a concentration of greater than  1.03



                    (in the aggregate) of the following substances:




                Aromatic .Amines




                Halogenated Hydrocarbons




                Benzene



                Cyano Wastes  (both  organic and inorganic)

-------
                Cydohexane




                Dimethyl Terephthalate



                Ethyiene Amine




                Herbicides




                Pesticides




                Polycyclic Aromatics



                1,4 Dioxane




                (2)  All wastes,  waste mixtures or waste streams




                     fed to the incinerator which "have not been




                     analyzed using gas chromatography-mass spec-




                     troscopy and shown to contain less than 1.0%



                     by weight (in the aggregate) of the substances



                     or classes of substances listed in Subparagraph



                     (1) of this  Paragraph, above.




                (3)  The contents of all drums and other bulk



                     material fed to the kiln.




           (C)   Priority Wastes shall be incinerated only at temper-




atures above  1800° F (or such other higher temperature as shall




be required by  the New Jersey Department of Environmental Protection),




with a dwell  time  of two seconds or greater, as calculated in accor-




dance with EPA  Sampling Methods  and Analytical Procedures Manual



for PCB Disposal,  Interim Report, February 10, 1978,  Section 4.2.



                However, during the period specified in Paragraph




(A) of Sectio IV of this Judgment, below, it shall not be considered




a violation of  this Judgment on  Consent if Priority Wastes are



incinerated;  for no more than ten minutes duration at temperatures




1750° F and 1800"  F,  or for no more than five minutes duration at

-------
less than 1750" F.  Nor shall it be considered a violation of




this Judgment if Priority Wastes are incinerated for no more than




three minutes duration at less than 1800° F thereafter.  Provided




however, that in no event shall Piority Wastes be used to bring




the temperature in the hot duct up to 18008 F during start-up or




following a temperature drop condition, for which purposes only




commercially-available fuel or non-Priority Wastes may be used.




               Priority Wastes nay be introduced only into the




loddby, kiln or afterburner of the incinerator.




          (D)  The Court may upon application by either party




(after notice to the other party), modify the list set out in




Subparagraph (B)(l) of this Section, above, by the addition or




subtraction of specified wastes or classes of wastes.  A.fter a




waste or class of wastes has been added to the above list, the




concentration of said waste shall be taken into account in calcu-




lating the aggregate concentration of wastes for purposes o€ deter-




mining whether any waste mixture is to be considered a Priority




Waste.  Inclusion of a waste or class of wastes in this list shall




not excuse Rollins from complying with more stringent federal or




state requirements for the incineration of particular wastes or




classes of wastes, and shall not be deemed to authorize incinera-




tion of any wastes for which further federal or state approvals




are necessary.  Specifically, the terns of this Judgment shall not




be deemed to authorize the incineration of polychlorinated biphenyls,



which compound may only be incinerated at a site aporoved by E




pursuant to 40 CFR §751.40.

-------
           (S)   Rollins shall install sensors which indicate whether



there is a flow in  each line used to feed waste streams  into the




incinerator.   Rollins shall also install sensors which indicate




whether the conveyor belt is feeding drums and/or other  bulk



material to the incinerator.




           (F)   Rollins shall install sensors to monitor  the tempe-



ratures in the  hot  duct,  the kiln exit gas, the loddby (at  the




point where wastes  exit from the loddby) and the target  wall of the




incinerator at  all  times that the incinerator is in operation.



           (G)   Rollins shall install containuous recorders  and




strip charts to record all of the information required to be



monitored by the terms of Paragraphs (13) and (F) of this Section,




above.  Such continuous recorders shall be subject to the following




specifications:



                (1)   Each strip chart which contains either  an



                     indication of whether there is a flow of wastes



                     to the incinerator through any given feed line,




                     or whether or not the conveyor belt  is  feeding




                     drums and/or other bulk material to the inciner-



                     ator shall also contain a continuous recording




                     of the hot duct temperature, so as to enable



                     one examining each such chart to determine  the



                     existence of feed of Priority Wastes in relation




                     to incinerator temperature at anv given instant.




                (2)   The continuous recorder utilized to record  the



                     information required by Subparagraph (1), above

-------
                    shall "be operated at a chart speed of at least



                    one inch per 30 nriinutes.




               (3)  The chart referred to in Subparagraph (1), above




                    shall contain either a printed or handwritten




                    designation of the date and the hour for each




                    hour that the incinerator is in operation, so




                    that the date and tine fo all recordings on the



                    chart can be ascertained.




               (4)  The chart referred to in Subparagraph (1),




                    above, shall be annotated to show which waste




                    streams being fed to the incinerator contain




                    non-Priority Wastes while the incinerator is



                    operating at a temperature below 1900° F.




          (H)  Rollins shall install automatic feed shut-off valves




on all lines which feed Priority Wastes to the incinerator and an




automatic shut-off on the conveyor belt which feeds drums of waste




and bulk material to the incinerator.  Rollins shall further install




mechanisms to cause the shut-off of Priority Wastes streams beincr




fed to the incinerator whenever the temperature in the Tiot duct of




the incinerator falls below 1800° F.



          (I)  Rollins shall install an automatic audible alarm




which will sound whenever Priority Waste streams are being fed to




the incinerator and the temperature in the hot duct of the




incinerator falls below 1800° F.  This alarm shall be audible in




the incinerator control room and within a radius of 50 yards  from




the control room.

-------
           (J)  At all  times  that the incinerator is  in  operation,



a Rollins  employee  shall  remain in the incinerator control roo^n.



Such employee shall coritainuously monitor the incineration of




wastes, and the temperature  at which wastes  are incinerated, and




shall notify the appropriate person(s) so as to effectuate the




requirements of Paragraph (K)  of this Section,  below.   Provided



that, should there  be  no  violations of the provisions of  this




Judgment for a period  of  one year following  installation  by  Rollins




of a programmable control system for its incinerator, then Rollins



shall be relieved of the  duty to maintain an employee in  the




incinerator control room  at  all times.



           (K)  In the  event  that the hot duct temperature shall



fall below 1800° F  during the incineration of Priority  Wastes, and




any of the automatic feed shut-off valves referred  to in  Paragraph




(H) of this Section shall fail to function properly, then the



operator shall manually shut off flow of all Priority Wastes




immediately.



           (L)  Rollins shall analyze the contents of each storage




tank of non-Priority Wastes  that is to be or may be incinerated




at temperatures of  less than 1800° F.  Records of each  analysis



required by the terms  of  this Paragraph shall provide at  a minimum




the  following  information:



                (1)   the date and time the analysis was  performed;




                (2)   the name of the person performing the analysis;



                (3)   the analytical results which show the tank



                     contents to be non-Priority wastes;

-------
               (4)  the date(s) and time(s) at which the contents




                    were incinerated.




          (M)  Rollins shall maintain an incinerator operating log




in which is noted the following information on an hourly basis




during ail times that the incinerator is in operation:




               (1)  the date and time of entry;



               (2)  the name of the incinerator operator;




               (3)  the numbers assigned by Rollins to the waste




                    blends that were incinerated in the previous




                    hour;



               (4)  the storage tank number(s) from which wastes




                    were directed to the incinerator within the




                    previous hour;



               (5)  an indication of whether any non-Priority



                    Wastes were incinerated during the previous




                    hour at temperatures below 1800" F, and the



                    tines when non-Priority Waste incineration was




                    begun and was ended during that hour;




               (6)  the hot duct temperature at the time of the




                    recording;



               (7)  the kiln exit gas temperature at the time of




                    recording;



               (8)  the  loddby temperature at  the time of recording;




               (9)  the target wall  temperature at the tine of




                    recording;

-------
               (10)   the  temperature at which the automatic shut-off



                     referred to in Paragraph (J) of this Section,



                     above,  is set.




The operator shall  sign  or  initial the operating log during his



tour of duty.




           (N)   Rollins shall submit a monthly report to EPA by




the tenth of each month  containing the following information



concerning operation of the incinerator during the previous month.




                (1)   The  original copies of the strip charts for



                     each day during the previous month showing



                     the  hot duct,  kiln, loddby, and target wall




                     temperatures,  and indicating whether there is




                     a flow of wastes to the incinerator, and whether



                     the conveyor belt is feeding drums and/or other



                     bulk material to the incinerator, as reguired




                     by Paragraph  (G) of this Section, above.  The



                     original copies of these strip charts shall




                     be returned by EPA to Rollins with 60 davs of




                     their receipt.  These originals shall then be



                     maintained  for a minimum of two years by Rollins,




                     The strip charts reguired to be compiled by



                     paragraph  (G)(l), above, shall be submitted in




                     color,  or shall employ such other method so



                     as to clearly show each individual waste stream.




                (2)   Copies of the records of analysis required to



                     be compiled in Paragraph  (L) of this  Section,




                     above.

-------
(3)   Copies  of all incinerator operating logs  required




     to be compiled in Paragraph (M)  of  this Section,




     above.




(4)   A. report of any instances during the previous




     month where the automatic feed shut-off valves




     referred to in Paragraph (H)  of this Section,



     above,  or the automatic audible alarm referred




     to in  Paragraph (I)  of this Section, above,




     have failed to function properly, with a brief




     analysis of the probable reasons for the failure,




     and an  explanation of any setps that were taken




     to correct the problem.



(5)   A. hot  duct temperature variance report




     indicating:



     (a)  the date and time of all instances in the



          previous month when the hot duct tempera-




          ture fell below 1300° F during the inciner-




          ation of Priority Wastes;



     (b)  the name of the shift supervisor on duty



          during the instances referred  to in Sub-




          paragraph (a), above;



     (c)  a brief description of the reason, or



          probable reason, for t_he temperature drops




          referred to in Subparagraph (a), above,




          and;

-------
                     (d)   a description of the corrective action

                          taken subsequent to the instances  referred

                          to in Subparagraph (a), above;

The monthly report  required by this Paragraph shall be submitted  to:


                     Chief
                     Air and Environmental Applications Section
                     Permits Administration Branch
                     U.S. Environmental Protection Agency
                     26 Federal Plaza
                     New York,  New York  10007


           (O)   Nothing in this Judgment shall relieve Rollins of

•che responsibility  for complying with the requirements of any

other regulation, statute, or permit concerning operation of its

incinerator,  including, but not limited to the provisions of

Title 7, Chapter 27, Subchapter II, of the New Jersey Administra-

tive Code, relating to the operation of incinerators, unless specific

exemptions are granted to Rollins by the New Jersey Department of

Environmental Protection, and (if necessary) approved by KPA.

Neither  shall Rollins violate any other provisions for the New

Jersey Implementation Plan, promulgated pursuant to Section 110 of

the ACT., 42 U.S.C.   §7410.  Furthermore, nothing in this Judgment

shall relieve Rollins of  liability it may have under  federal or

state law  for additional penalties as a result of violations not

covered  by t_his Judgment.  Rollins acknowledges that  it "has been

notified that it may be subject ot penalties under Section 120 of

the Act,  42  U.S.C.   §7420, but reserves the right to contest the

assessment and attempted  collection of noncompliance  penalties

under that section  or seek exemption  from said  noncompliance

-------
penalties.  Nothing contained in this Judgment shall be construed




to prevent or limit the application of the provisions of Section



303 of the Act, 42 U.S.C. §7603.




     IV.  EPA shall monitor Rollins' complaince with this Judgment.




Upon discovery by EPA. of what the Agency believes to be a violation




of -che terns of this Judgment, EPA shall ntoify the Court and




Rollins in writing.  Where the violation is one covered by the




penalty provisions of this Section, below, Rollins shall pay by




cashier's or certified check payable to the Treasurer, United States




of America, the liquidated peanlty required by this Section, unless




Rollins shall request a hearing on the factual basis for the vio-




lation, in which case the Court shall evaluate all evidence and




shall decide whether Rollins has violated the terns of this Judg-




ment.  The remittance of liquidated penalty or the request for a




hearing must be made within fifteen days of Rolins receipt of




notification of the violation.



          Rollins shall pay the following liquidated penalties




in the event of any violation of the requirements of Section III




of this Judgment:



           (A)  Immediately upon the date of the entry of this




Judgement on Consent until either eleven months after said entry




or four months after the installation by Rollins of a programmable




control system for its incinerator, whichever is sooner, the




following  schedule shall apply:



               (1)  Whenever the temperature in the hot duct of




                    Rollins' incinerator falls below 1QOO" during




                    the incineration of Priority Wastes, should

-------
    Rollins fail to shut off the feed of



    Wastes (either manually or automatically^




    within five minutes of the time that the hot




    duct temperature falls below 1800° F, then




    Rollins shall pay a liquidated penalty of one




    thousand five hundred dollars  (51,500.00) for




    exceeding the intial five-minute period, and




    one thousand five hundred dollars  (SI,500.00)




    for each additional five-ininute period that




    the time period is exceeded, up to a maximum



    of twenty five thousand dollars  (225,000.00)




    for any sinqle calendar day of violation.



    Provided that, should the hot  duct tempera-



    ture, upon  falling below 1800° F,  remain between




    1750° F and 1300° F for  less than  ten minutes,



    and then be raised above 1800° F,  no penalties



    shall accrue.  Should the hot  duct temperature,




    upon falling below  18008 F, remain between



    1750° F and 1800° F  for  ten minutes  or  longer,



    (as described  in  the proceeding  sentence) then




    penalties  shall begin  to accrue  after the



    initial ten minute  period,  and shall  continue



    to  accrue  for  as  long  as the  temperature remains




    below  1800" F.



'2)  Whenever  the temperature in the hot  duct of



    the incinerator  shall  fall  below 600°  F for




    more  than five minutes during the incineration

-------
     of non-Priority Wastes,  Rollins shall pay a



     liquidated penalty of five hundred dollars




     ($500.00)  for exceeding  the initial five-minute



     period,  and five hundred dollars (S500.00) for




     each addxtional five-minute period up to a



     maximum of twenty five thousand dollars




     ($25,000.00) for any single calendar day of




     violation.




(3)   Whenever records are not provided by Rollins



     for any period during which the incinerator




     is operating, Rollins shall pay liquidated




     penalties  as indicated below:




     (a)  during incineration of Priority Wastes,




          hot duct temperature is not provided -




          a penalty of one thousand five hundred




          dollars (SI,500.00) shall accrue if the




          information is not  provided for an initial




          period of five ninutes, and an additional




          penalty of one thousand five hundred




          dollars ($1,500.00) shall accrue for each




          additional five-minute period for which




          the information is  not provided, uo to  a




          maximum of twenty five thousand dollars




          ($25,000.00) for any single calendar day




          of violarion;



     (b)  during incineration of Priority Wastes,




          when the hot duct temperature falls below

-------
     1800°  F,  an indication of the stoppaae  of



     Priority  Waste feed (through  feed lines




     and/or by way of conveyor belt)  is not



     provided  - penalty as provided in Subpara-




     graph (a), above, up to a maximum of



     twenty five thousand dollars  (525,000.00)




     for any single calendar day of violation?



(c)   during the incineration of non-Priority



     Wastes, hot duct temperature is not provided -



     a penalty of five hundred dollars (S500.00")




     shall accrue if  the  information is not



     provided  for an  initial period of five




     minutes,   and an  additional penalty of  five



     hundred dollars  (S500.OO) shall accrue




     for each  additional  five-minute period for




     which  the information is  not provided, UP



     no a  maximum of twenty five  thousand



     dollars  (S25,000.00) for any single calen-




     dar  day  of violation;



Provided  that,  should the strip chart  referred



to  in  Paragraph (G),  of Section  III,  above, fail



to  function at any time because of a  mechanical




problem,  Rollins may provide for  the  manual



recording, at fifteen-minute intervals,  of  all



information required by Subparagraph (N)(l),  of



Section III,  above, for a period of not more  than




forty-eight hours, without the accrual of penal-

-------
                    ties cited in this Subparagraph (3).  Provided




                    also that, should any failure of the strip chart




                    occur during the incineration of Priority Wastes




                    while the temperature is below 600° F, then the




                    penaltxes provided by -chis Subparagraph shall




                    accrue whether or not manual recordings are made.




No penalties or combination of penalties provided for under this




Paragraph shall accumulate to more than twenty five thousand dollars




($25,000.00) for any single calendar day of violation.




          (B)  Commencing either eleven months after the entry of



this Judgment, or four months after the installation by Rollins




of a programmalbe control system for its incinerator,  whichever




is sooner, the following schedule shall apply:




               (1)  Whenever the temperature in the hot duct of




                    Rollins' incinerator falls below 1800° F




                    during the incineration of Priority Wastes,




                    should Rollins fail to shut off the feed of




                    Priority Wastes (either manually or automati-




                    cally) within three minutes of the time that




                    the hot duct temperature falls below 1800° F,




                    then Rollins shall pay a liquidated penalty



                    of one thousand five hundred dollars (51,500.00)




                    for exceeding the initial three-minute period,



                    and one thousand five hundred dollars (51,500.00)




                    for each additional three-minute period that the



                    time period is exceeded, up to a maximum of

-------
     twenty-five thousand dollars ($25,000.00) for




     any single calendar day of violation.



(2)   Whenever the temperature in the hot duct of




     the incinerator shall fall below 600° F for




     more than three minutes during the incineration




     of non-Priority Wastes, Rollins shall pay a



     liquidated penalty of five hundred dollars




     (S500.00) for  exceeding the intial three-minute




     period that the time period is exceeded, up to




     a maximum of twenty five thousand dollars




     ($25,000.00) for  any single calendar day of




     violation.



(3)  Whenever records  are not provided by Rollins




     for any period during which the incinerator is



     operating, Rollins  shall pay  liquidated  penal-




     ties as indicated below:



     (a)  during  incineration of  Priority Wastes, hot



          duct temperature  is not  provided  -  a




          penalty of  one thousand  five hundred



          dollars ($1,500.00) shall  accrue  if the



          information is not provided  for an  initial




          period  of three minutes,  and  an additional



          penalty of  one thousand five  hundred  dollars




           ($1,500.00)  shall accrue for  each addi-




          tional  three-minute period for which  the



           information is not provided,  up to  a



          maximum of twenty five thousand dollars

-------
     ($25,000.00) for any single calendar day



     of violation;




(b)  during incineration of Priorty Wastes,




     when the hot duct temperature falls below




     1800° F, an indication of the stoppage of




     Priority Waste feed (through feed line




     and/or by way of conveyor belt) is not



     provided - penalty as provided in Subpara-




     graph (a), above,  up to a maximum of



     twenty five thousand dollars (S25,OOO.OO)




     for any single calendar day of violation;




(c)  during the incineration of non-Priority




     Wastes,  hot duct temperature is not provided




     - a penalty of five hundred dollars (S50O.OO)




     shall accrue if the information is not




     provided for an initial period of three




     minutes, and an additional penalty of five



     hundred dollars (S500.00) shall accrue for




     each additional three-minute period for




     which the information is not provided, up




     to a maximum of twenty five thousand




     dollars ($25,000.00) for any single calendar




     day of violation.



Provided that,  should the strip chart referred




to in Paragraph (G), of Section III, above,




fail to function at any time because of a mechan-



ical problem, Rollins may provide for the manual

-------
                     recording,  at fifteen-minute intervals,  of all



                     information required by Subparagraoh (N)(l),  of




                     Section III,  above, for a period of no more than




                     forty-eight hours,  without the accrual of penal-



                     ties cited  in this  Subparagraph (3).  Provided



                     also that,  should any failure of the strip




                     chart occur during  the incineration of Priority



                     Wastes while the hot duct temperature is  below



                     1800° F,  or during  the incineration of non-



                     Priority Wastes while the temperature is  below



                     600° F, then the penalties provided by this




                     Subparagraph shall  accrue whether or not  manual



                     recordings  are made.



No penalties or  combination of  penalties provided for under  this



Paragraph shall  accumulate to more than twenty five thousand



dollars  ($25,000.00)  for any single calendar day of violation.




Penalties for  other  violations  of the provisions of this Judgment



shall be at the  discretion of this Court.




     V.   The  provisions of this Judgment shall apply to and  be




binding  upon Rollins,  as well as its successors and assignees.



     VI.  Jurisdiction is retained by this Court for the purpose




of enabling either party to apply to the Court at any time for



such futher orders and directions as may be necessary or appro-



priate for the construction and effectuation of this Judgment,



for the  modification or termination of  this Judgment or any  of




its terms, or  for  the punishment of violations thereof.

-------
     VII. The provisions of Section IV, above, of this Judgment,



and those provisions of Section III of tliis Judgment, above, which



do not relate to the installation of equipment by Rollins, shall



terminate at the time (if ever) that Rollins is issued a final



administrative permit (not interim status) for the operation of



its incinerator, pursuant to Section 3005 (c) of the Resource



Conservation and Recovery Act, 42 U.S.C. §6925(c).  All other



provisions of this Judgment shall remain in effect until and unless



expressly terminated by this Court.



     VIII. Each party shall bear its costs in this matter.








Dated:              	      , 	 	       , New Jersey
                                    UNITED STATES DISTRICT JUDGE

-------
    The undersigned hereby  consent to the entry of the foregoing
-dgnent without further  notice.
                                    JAMES W. MORRMAN,  Esq.
                                    Assistant Attorney General
                                    Land and Natural Resources Div.
                                    U.S. Department of Justice
                                    ROBERT J. DEL TUFO
                                    United States Attorney for the
                                      District of New Jersey
                                    By:
                                    Assistant U.S. Attorney
                                    ROLLINS ENVIRONMENTAL
                                    (NJ)INC.
                                    By:	
                                       Robert C. Gregory,
                                       Vice President

-------