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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
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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
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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
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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.
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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
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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.
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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
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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:
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(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.
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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
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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.
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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
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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.
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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
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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
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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
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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.
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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
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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
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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
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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
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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-
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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,
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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.
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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
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° 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
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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.
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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.
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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
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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
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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.
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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
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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
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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
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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-
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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
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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
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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
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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.
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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
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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
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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
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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
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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.
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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
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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.
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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
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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.
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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
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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
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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.
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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
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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.
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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
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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-
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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.
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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,
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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
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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.
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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,
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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
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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.
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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
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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,
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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)),
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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]
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§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.
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[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]
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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
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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.
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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.
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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
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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
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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
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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
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"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.
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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.
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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
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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
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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
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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
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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.
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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.
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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).
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(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
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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:
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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
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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
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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.
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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
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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,
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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
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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
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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-
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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
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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-
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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-
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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-
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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
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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-
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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-
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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 (^).
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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
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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).
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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-
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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-
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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"
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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-
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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-
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* 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-
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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-
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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-
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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.
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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-
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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-
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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-
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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-
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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-
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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-
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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-
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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-
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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
-
-
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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-
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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,
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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.
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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.
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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.
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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
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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.
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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.
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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
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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
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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
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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-
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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
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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.
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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
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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
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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
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(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:
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(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.)
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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
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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).
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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:
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(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.
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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-
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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
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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.
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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
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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.
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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.
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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.
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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.
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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
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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.
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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
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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".
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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.
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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.
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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.
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(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.
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(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
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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
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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.
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(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
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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
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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.
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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
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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.
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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.
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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
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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
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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
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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
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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)
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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.
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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.
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(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;
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(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
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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
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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
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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
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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-
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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
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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
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($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
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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.
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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
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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
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