UnitM SIMM
               Environment*! Protection
     SEPA
             Off
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PARTS 264—265 SUBPART 0 — INCINERATOR
DOC: 9488.07(85)
Incineration, POHCs, DRE
Effect of Water—Stripped POHCs on Incinerator DRE
Roland W. Schrecongost, Acting Director, Hazardous Waste
Management Divison, Region III
John H. Sk1nner, Director, Office of Solid Waste
i 9488.O7(85)
6—26—85
The memo provides Headquarters’ guidance regarding the calculation of DRE
for a RCRA incinerator using plant process water in its scrubbers.
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
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9488.07 (85)
MEMORANDUM
SUBJECT: Effect of Water—Stripped POHCs on
Incinerator DRE
FROM: John H. Skinner
Director
Office of Solid Waste (WH—562)
TO: Roland W. Schrecongost
Acting Director
Hazardous Waste Management Division, Region III
(3 HWO 0)
In your memorandum of June 11 (attached), you requested
Headquarter8’ guidance regarding the calculatton of Destruction
and Removal Efficiency (DRE) for a RCRA incinerator using plant
procesa water in its scrubbers. As was discussed in the Inciner-
ator Workgroup conference call held on June 18, we agree with
your opinion that: (1) toluene and acrylonitrile, found in the
process water, are suitable POHCs for Union Carbide’s unit; and
(2) all POHCa in the exhaust gases, including any POHCs stripped
from the scrubber, should be included in the DRE calculation.
Please contact Pablo Vaquer of my staff on FI’S_382_1 535 if you
have further questions regarding this issue.
Attachment
cc: Permit Branch
Incinerator Permit Writers’ Workgroup
Pablo II
Control No. OSW—107
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