RCRA PART B
MODEL PERMIT APPLICATION FOR
EXISTING INCINERATORS
PREPARED BY:
A. T. Kearney, Inc.
699 Prince Street
P.O. Box 1405
Alexandria, Virginia 22313
and
Bat telle Columbus Labs
505 King Avenue
Columbus, Ohio 43201
EPA Contract No. 68-01-6515
Work Assignment H00-013
U.S. Environmental Protection Agency
February 11, 1983
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FOREWARD
This model permit application has been provided to assist
owners and operators of hazardous waste incinerator facilities
in preparing their Part B permit applications required under the
Resource Conservation and Recovery Act of 1976 (RCRA). The
hypothetical facility described in this model application is an
existing facility with interim status authority to operate (i.e.,
it was in operation or under construction prior to November 19,
1981, complied with the Part A notification requirements of RCRA,
and was granted interim status by the U.S. Environmental Protec-
tion Agency). Although this model application is intended pri-
marily to guide interim status incineration facilities, several
sections of the model can be of assistance to other treatment,
storage and disposal facilities in preparing their Part B appli-
cations. With the exception of Section D, Process Information,
most Part B permit applications should resemble this model in
scope, content, and level of detail.
As shown in the Table of Contents, the information presented
in this model has been arranged into several topical sections
which do not necessarily follow the sequence of the Federal regu-
lations. Although applicants are free to arrange their Part B
submittals in any manner which is convenient, it is recommended
that the format contained in this model be followed, as it pro-
vides.a logical and uniform arrangement of the required informa-
tion and should serve to expedite the permitting process.
The detailed Table of Contents for this model application
contains many sections which have been marked "reserved" and are
not covered in the text of the model. For example, the hypothet-
ical facility stores hazardous wastes generated on-site in tanks
and drums but always incinerates those wastes in less than 90
days. Therefore, the tank and drum storage activities at the
facility do not require a RCRA permit. Information that would
be required for a RCRA storage permit, such as tank and container
management practices (Sections D-la(2) and D-2c) has not been
included in the model permit application, but the preferred loca-
tion for this information has been indicated in the Table of
Contents. It is requested that applicants use the same conven-
tions in preparing their Part B applications, i.e., follow the
model Table of Contents and delete sections that are not applic-
able to their facility.
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The guidance provided in this document does not necessarily
reflect Agency policies and does not in any way replace or alter
the Federal regulatory requirements to which hazardous waste
management facilities are subject. The mention of trade names
or commercial names in this document does not constitute
endorsement by the U.S. Government.
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RCRA PART B MODEL PERMIT APPLICATION
FOR EXISTING STATIONARY INCINERATORS
GENERAL TABLE OF CONTENTS
Section Contents
A - Part A Permit Applications
B - Facility Description
C - Waste Characteristics
D - Process Information
E - Ground Water Monitoring (Reserved)
F - Procedures to Prevent Hazards
G - Contingency Plan
H - Personnel Training
I - Closure and Post-Closure Plans and
Financial Requirements
J - Other Federal Laws
K - Certification
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MODEL INCINERATOR PERMIT APPLICATION
DETAILED TABLE OF CONTENTS
Section and Title Page
A PART A PERMIT APPLICATIONS A-l
B FACILITY DESCRIPTION B-l
B-l General Description B-l
B-2 Topographic Map B-l
B-3 Location Information B-2
B-3a Seismic Considerations B-2
B-3b Floodplain Standard B-2
B-3b(l) Demonstration of Compliance reserved
B-3b(2) Plan for Compliance reserved
B-4 Traffic Information B-2
C WASTE CHARACTERISTICS C-l
C-l Chemical and Physical Analyses C-l
C-la Containers reserved
C-lb Tanks reserved
C-lc Waste Piles reserved
C-ld Surface Impoundments reserved
C-le Incinerators C-5
C-le(l) Trial Burn C-5
C-le(2) Data in Lieu of Trial Burn reserved
C-2 Waste Analysis Plan C-5
C-2a Parameters and Rationale C-6
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DETAILED TABLE OF CONTENTS (Continued)
Section and Title Page
C-2b Test Methods C-7
C-2c Sampling Methods C-8
C-2d Frequency of Analysis C-8
C-2e Additional Requirements for Wastes
Generated Off-Site reserved
C-2f Additional Requirements for Facilities Hand-
ling Ignitable, Reactive or Incompatible Waste . C-9
C-2g Quality Assurance/Quality Control C-9
D PROCESS INFORMATION reserved
D-l Containers reserved
D-la Containers With Free Liquids reserved
D-la(l) Description of Containers reserved
D-la(2) Container Management Practices reserved
D-la(3) Containment System Design/Operation .... reserved
D-la(4) Removal of Liquids From Containment
System reserved
D-lb Containers Without Free Liquids reserved
D-lb(l) Test for Free Liquids reserved
D-lb (2) Description of Containers reserved
D-lb(3) Container Management Practices reserved
D-lb(4) Container Storage Area Drainage reserved
D-2 Tanks reserved
D-2a Description of Tanks reserved
D-2b Tank Corrosion and Erosion reserved
D-2c Tank Management Practices reserved
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DETAILED TABLE OF CONTENTS (Continued)
Section and Title Page
D-3 Waste Piles reserved
D-4 Surface Impoundments reserved
D-5 Incinerators D-l
D-5a Justification for Exemption D-l
D-5b Trial Burn D-l
D-5b(l) New Incinerator Start-up/Shakedown .... reserved
D-5b(2) Trial Burn Plan D-l
D-5b(2)(a) Detailed Engineering Description
of Incinerator D-2
D-5b(2)(b) Sampling and Monitoring Procedures . . D-9
D-5b(2)(c) Trial Burn Schedule D-18
D-5b(2)(d) Test Protocols D-18
D-5b(2)(e) Pollution Control Equipment
Operation D-22
D-5b(2)(f) Shutdown Procedures D-22
D-5b(2)(g) Post-Trial Burn Operation reserved
D-5b(2)(h) Quality Assurance/Quality Control . . D-22
D-5c Data in Lieu of Trial Burn reserved
D-5c(l) Engineering Description of Incinerator . . reserved
D-5c(2) Expected Incinerator Operation reserved
D-5c(3) Design and Operating Conditions reserved
D-5c(4) Previous Trial Burn Results reserved
D-5d Determinations D-22
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DETAILED TABLE OF CONTENTS (Continued)
Section and Title Page
E GROUND WATER MONITORING reserved
F PROCEDURES TO PREVENT HAZARDS F-l
F-l Security F-l
F-la Security Procedures and Equipment F-l
F-la(l) 24-Hour Surveillance System F-2
F-la(2) Barrier and Means to Control Entry .... F-2
F-la(3) Warning Signs F-2
F-lb Waiver F-3
F-lb(l) Injury to Intruder reserved
F-lb(2) Violation Caused by Intruder reserved
F-2 Inspection Requirements F-3
F-2a General Inspection Requirements F-3
F-2a(l) Types of Problems F-3
F-2a(2) Frequency of Inspection F-3
F-2b Specific Process Inspection Requirements .... F-5
F-2b(l) Container Inspection reserved
F-2b(2) Tank Inspection reserved
F-2b(3) Waste Pile Inspection reserved
F-2b(4) Surface Impoundment Inspection ...... reserved
F-2b(5) Incinerator Inspection F-5
F-3 Waiver of Preparedness and Prevention
Requirements F-5
F-3a Equipment Requirements F-5
F-3a(l) Internal Communications F-5
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DETAILED TABLE OF CONTENTS (Continued)
Section and Title Page
F-3a(2) External Communications F-6
F-3a(3) Emergency Equipment F-6
F-3a(4) Water for Fire Control F-6
F-3b Aisle Space Requirements F-6
F-4 Preventive Procedures, Structures and Equipment . . F-7
F-4a Unloading Operations F-7
F-4b Runoff F-7
F-4c Water Supplies F-7
F-4d Equipment and Power Failure F-7
F-4e Personnel Protection Equipment F-8
F-5 Prevention of Reaction of Ignitable, Reactive
and Incompatible Wastes F-8
F-5a Precautions to Prevent Ignition or Reaction
of Ignitable or Reactive Waste F-8
F-5b General Precautions for Handling
Ignitable or Reactive Waste and Mixing of
Incompatible Waste F-9
F-5c Management of Ignitable or Reactive
Wastes in Containers reserved
F-5d Management of Incompatible Wastes in
Containers reserved
F-5e Management of Ignitable or Reactive
Wastes in Tanks reserved
F-5f Management of Incompatible Wastes in Tanks . . . reserved
F-5g Management of Ignitable or Reactive
Wastes in Waste Piles reserved
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DETAILED TABLE OF CONTENTS (Continued)
Section and Title Page
F-5h Management of Incompatible Wastes
In Waste Piles reserved
F-5i Management of Ignitable or Reactive
Wastes in Surface Impoundments reserved
F-5j Management of Incompatible Wastes in
Surface Impoundments reserved
G CONTINGENCY PLAN G-l
G-l General Information . . . . G-l
G-2 Emergency Coordinators G-l
G-3 Criteria for Type and Severity of Incidents
Leading to Implementation of Contingency Plan . . . G-3
G-4 Emergency Response Procedures G-4
G-4a Notification G-4
G-4b Identification of Hazardous Materials G-7
G-4c Hazard Assessment G-8
G-4d Control Procedures G-9
G-4e Prevention of Recurrence or Spread of
Fires, Explosions or Releases G-ll
G-4f Storage and Treatment of Released Material . . . G-13
G-4g Incompatible Waste reserved
G-4h Post-Emergency Equipment Maintenance G-13
G-4i Container Spills and Leakage reserved
G-4j Tank Spills and Leakage reserved
G-4k Waste Pile Spills and Leakage reserved
G-41 Surface Impoundment Spills and Leakage reserved
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DETAILED TABLE OF CONTENTS (Continued)
Section and Title Page
G-5 Emergency Equipment G-13
G-6 Coordination Agreements G-20
G-7 Evacuation Plan G-21
G-8 Required Reports G-21
H PERSONNEL TRAINING H-l
H-l Outline of Training Program H-l
H-l a Job Titles and Duties H-l
H-lb Training Content, Frequencies and Techniques . . H-5
H-lc Training Director H-8
H-ld Relevance of Training to Job Position H-9
H-le Training for Emergency Response H-9
H-2 Implementation of Training Program H-10
I CLOSURE PLANS 1-1
1-1 Closure Plans 1-1
I-la Closure Performance Standard 1-1
I-lb Partial Closure and Final Closure Activities . . 1-2
I-lc Maximum Waste Inventory 1-2
I-ld Inventory Disposal; Removal or Decon-
tamination of Equipment 1-2
I-le Schedule for Closure 1-4
I-lf Request for Extension of Closure Time reserved
1-2 Post-Closure reserved
1-3 Notice in Deed reserved
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DETAILED TABLE OF CONTENTS (Continued)
Section and Title Page
1-4 Closure Cost Estimates 1-5
1-5 Financial Assurance Mechanism for Closure 1-11
1-6 Post-Closure Cost Estimates reserved
1-7 Financial Assurance Mechanism for Post-Closure . . reserved
1-8 Liability Requirements 1-18
I-8a Sudden Insurance 1-18
I-8b Nonsudden Insurance reserved
I-8c Financial Test for Liability Insurance reserved
1-9 State Financial Mechanism reserved
J OTHER FEDERAL LAWS J-l
K CERTIFICATION K-l
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Page A-l
WU-in t
tanvctdfortUa w». '2chanctan/incfil.
\
Form Aopt ortd QMS No. 158-R0173
FORM
QENEBAL
v>EPA
IU. INVIMNMIHTAL mtOTBCTtON «giltCY
GENERAL INFORMATION
ContotidMaO Ptmua Progrmn
I1Uad On 'Ctntrai liutntettoi—" btfort I farting.)
^ ^ ^
|ll. KAC(Urr N^MK^N,
'y.«Y,WVOv
I *' MAILING ADORES
\ \ \ \\ \
: PLACE LABEL IN THIS SPAC
I. EPA I.D. NUMBER
i i i i r
~F~|N J4 680 0 200 0 Ono
. INSTKUCTIOHi-
If » mn»lrn»d I(bet h» been provided, affile,
it In the iieilgnitart an. R»iiw the intern*
•dan carefully: If tny of It ii incorrect, croa
ttirough it and amar the correct data in the
appiuwata fflt—«i ana below. Ala. if any of
tha oreprintad dm ii abtam ftfce area to tft»
lift of ttM /a6ef mare liltI Ma informttton
tint dmutd wpeerj. plana provide it in tna
proper fill—in amiti balow. If tha labal <¦
complete and correct, you naad not complete
Itam I. Ill, V, and VI fareapr Vt-B wtiich
mat tm cumulimJ oprtml. Complata all
itama. If no labal haa bean provided. Refer to
tta IraBucdoia fof dmilad item flm t IP*
ttona and for ma lag* auttarladana- under
which thta data i* collected.
(L POLLUTANT CHARACTERISTICS .
INSTRUCTIONS: T*—» A ttnugbJ to dwinlw NfaHtar yott and 18 aitanit my (Mmit umllmlow hum*to ilia EPA If you rawer "y«" to any
you mutt Mbmrt thii farm aid tte wpieoMnafr fbm Itarf In tfcoperantfwieWJowrfng tf» quartan-In tha ba* In tha third column
It tha aiwiiwiwm fomi Ii ifhwt If yaa nw *W to weft quealon, ycu need rrataitenit «ny of tnmfamir Yau m»y war "na" if your activity
itaaduded from parait raquii emend, we Section C ot Uw iiuuuctlQM. Saa ato. Sad an Q of tha inwuctionc for dafliiiUont at brill faced Hmm
r"T
a ci pic nianam
MAffil !i'
A. !• ttili facility a
mrtiich raaalta iir a i
(FOHM2AI
X
C. Ii tha « faality which eurnntly muWin
to iietin of tha U3. othar than thoaa
3. Doaa or wiil thi« facility faftftar txMitg or pmftamd)
equatfs «fcnai pmeimluM facility which results in a
ofUMUjSk? (FORM 2B)
P. Ii thia a propoaad faolity fotftar than OtomatKrOuS"
In A or B tbemi which will rawit in a dieeherge to
ate« of th* OA? (FORM 2D>
X.
x
E. Ooaa or will thle faality treat, nan. or di
!¦¦¦!>¦¦ (FORM 3)
of
(a. do you or will you miact at tna reality any produced
wetar or othar fluidt which ara brought to tha nrfaca
in connactton with connonrionel oil or natural Qat pro-
duction. in fact fluidi mad for anhanead recovery of
oil or natural jat, or intact fluidi for noreaa of liquid
hydrocirbow? (FORM 4>
P. Do you ar will you intact at tfila fadJity indunrial or
municipal affluant balow tha ionarmoai stratum con-
taining, within on* quarter nttta of tha wall bora,
¦ ¦ '¦ —' ——i of drinUne watar? (FORM 4)
X
H. Oo you or will you intact at JWa faculty ftuld* for
cW procam udi aa mining of ailfur by tha FiaaUr
procaa, niutton mining of miiiaiala. In iitu con^iu*-
tlon of tail fuat, or lacowry of puUwiiiial anar?y7
(FORM 41
X
I. Ii tha taollty i iwopoad gaoooary «wa wnicn a
on* of tha 28 induerial mtagoilaa ilatad in tha in-
ttrurtoni and which will nominally «nit TOO ton*
par yaar of any air pollutant raquiatad undv tha
dean Air Aa and may affact or be located in an
ja«aa?jFORM91
J. la tha faaltty a
NOT one of the 28 induaerlal
which i
In th
par yaar a# any efr pollutant ngutand under tha Clean
Air Act md may effect or be taenad tot i
(FORM 8)
lit NAM8 OF FACILITY
I—I—I—I—I
UNIVERSAL WID.GE.T. CORPORATION
IV. FACILITY CONTACT
A. NAME » titu tumt. /Int. * tttw
I I I I I I I I I I I I I
VANESSA D E L.R.I .0 VICE PRESIDENT
i—i
9 8 8
7 2 2 2
V. FACILITY MAILING ADDRESS
2 5 00. INDUSTRIAL DR.IVE
0 7 18 0
n
TR.EEBROOK
VL FACILITY LOCATION
A. STRUT, HOUTt NO. OK OTHCR 1MCIPIC lOBNTinCK
2.5.0.0 TN.D U.S.TRIAL. .DRI V E
S.MTTHFTKTiD
F. COUNT1T COD*
If
0 7 18 0
TREEBROOK
EPA Fonn 3510-1 (S-80)
CONTINUE ON REVERSE
------- An error occurred while trying to OCR this image.
-------
Page A-3
fill—in mmnmaced for at its tyo». i.t.. 12 ehanctanfinchi.
FORM
3
RCRA
Form Aopromd OMB No. 1S9-S80004
4>EPA
U.S. SNVIRONMINTAb PROTECTION AOINCY
HAZARDOUS WASTE PERMIT APPLICATION
Conwtidet&d Permits Program
{Tht4 information it reQutred under Section 3005 of RCRA.)
FOR OFFICIAL USE ONLY ^2
APPLICATION I DATS RECEIVED
APPROVED I (yr . mo.. A dav>
I. EPA I.D. NUMBER
COMMENTS
II. FIRST OR REVISED APPLICATION
Place an "X'r m the appropriate box in A or 3 below (mirk one box only) to indicate whether this is the first application you are submitting for your facility or a |
revised application. If this is vour first application and you already know your facility's EPA I.D. Number, or if thit is a revised application, enter your facility's
EPA 1.0. .Number in Item I abov*.
A. FIRST APPLICATION (piace an "X" below and provide the appropriate data)
txiMtint" facility.
1X11 • existing FACILITY (See instructions for definition of 1
n Compiete item below.)
g
LSJ
a
$
Wh
FOR EXISTING PACIUTItS. PKOVIOC THE OATS (yr„ fllO.. & day)
OPERATION MOAN OR TNC OATI CONSTRUCTION COMMKNCIO
(use the boxes to the left)
HBViagBlrfcJeATia >N Iplace an "X" below and complete Item I above)
0\. PACIUrr HAS INT1HIM STATUS
S.NEW FACILITY (Complete item below.)
FOR NBW FACILJTTBS.
PROVIDB TH« OATS
(yr., mo., 6 day) opbra-
TION BtOAN OR 19
EXPECTED TO BCOfN
n n
L FACILITY HAS A RCRA PERMIT
III. PROCESSES - CODES AND DESIGN CAPACITIES
PROCESS CODE — Enter ths cods from tha lift of piwiw
entering coda*. If mom linea era needed, enter ths codefij in ths
describe the procaai OnduiUng ia dwprceosaty) in tha
t that best describes each proem to be used at ths facility. Ten lines arv provided for
»provtdsd. If a piocan wdl bs ussd that is not indudad in the list of codes befow„then
I on tha form iitrnn
B. PROCESS DESIGN CAPACITY — For each cods enmed in column A enter ths capacity of the process.
1. AMOUNT — Enter tha amount.
2. UNIT OF MEASURE — For each amount entared In column BO), entartha coda from tha lift of unit
msaurs used. Only tha umti of maamra that are listed berfow should be uad.
PRO- APPROPRIATE UNITS OF
CESS MEASURE FOR PROCESS
CntlC DESIGN CAPACITY
wneggg
Storaoa:
CONTAINER flwi'iJ. drain, etc.)
TANK
WASTE P1LS
SURPACS IMPOUNOMtKT
D booed:
INJECTION WSLL
LANDFILL
LAND APPLICATION
OCEAN DISPOSAL
SURPACS IMPOUNDMENT
below that describes the unrt of
PRO- APPROPRIATE UNITS OF
CESS MEASURE FOR PROCESS
COPP PESIfiM CAPACITY
sot GALLONS OR UTSRS
SOS OALLONS OR UTSRS
SOS CUBIC YARDS OR
CUBIC METERS
S04 OALLONS OR UTKRS
OTS QALiflNS OR LITERS
oso acre-feet (the volume that
ufotUd cover one acre to a
depth of one foot) OR
HSCTARB-MBTSR
DSf ACRES OR HECTARES
OSS OALLONS PER OAV OR
UTSRS PER OAT
MS OALLONS OR UTSRS
TANK
SURPACS tMKUNOMI
INCINERATOR
OTHER (Use for physical, chemical
thermal or bloiogteai treatment
processes not occurring in tanks,
surface impoundments or inciner*
afore. Describe the pnwi—i tn
t provided; Item UX-C.)
T01 OALLONS PER DAY OR
UTSRSPBR DAY
TQS OALLONS PBR OAY OR
LITSRS PBR OAY
Ttl TONS PBR HOUR OR
METRIC TONS PBR HOURl
OALLONS PBR HOUR OR
LITERS FBR HOUR
TO* OALLONS PER OAY OR
UTERSPSR OAY
UNIT OP MEASURE
UNIT OP
MEASURE
COPE
UNIT OP MEASURE
UNIT OP
MEASURE
COOS
UNIT OP MEASURE
UNIT OF
MEASURE
CODE
GALLONS
UTERS
CUBIC YARDS ....
CUBIC METERS . . .
OALLONS PER DAY
O UTSRS PER OAT V
L TONS PER HOUR O
Y MSTRIC TONS PBR HOUR. W
....... C GALLONS PER HOUR S
....... U UTSRS PER HOUR H
EXAMPLE FOR COMPLETING ITEM III (sftomtm line aumOen X-1 end X-2 tieiam): A fscility has two storage tanks, ana tank csn hold 200 gallons and the
other can hold 400 gallons. The faality also has sn imJiiaiami' that csn burn up to 20 gallons per hour.
ACRE-PSST. ....
HECTARE-METER.
ACRES
HECTARES
. A
. F
. a
. o
DUP
c
A
B. PROCESS DCS ION CAPACITY
B. PROCESS DESIGN CAPACITY
LINE
NUMBE
CESS
COOS
(from list
abooe)
1. AMOUNT
Itp*afy)
2. UNIT
OP MBA'
SURE
(inter
code)
FOR
OFFICIAL
USB
ONLY
LINE
NUMBEI
CSSS
COOg
(from list
abooe)
2. UNIT
OF MSA*
SURE
(enter
code)
FOR
OFPtCIAL
USE
ONLY
•
UL
i* • ia
I* IT
X-l
s
0
2
600
G
5
X-2
T
0
3
20
E
6
1
T
0
3
2.6
D
7
i.
8
3
9
4
10
IB
i* rr
if
X*
«• tJ
¦a
EPA Pom 38104 (6-001
PAGE 1 OF 9
CONTINUE ON REVERSE
-------
Page A-4
uoxitnuad tram tha front.
m. PROCESSES (continued) ^
C. IPA.CI POD »ODITim«L "NQCUI COOK! OR PON QIKKIIINa OTMIR PnOCUSU (COda POR EACH I
JNCbUOS DUION CAPACITY.
cut CHTSRBO MIIU
IV. DESCRIPTION OF HAZARDOUS WASTES
A. EM HAZARDOUS WASTE NUMBER - Emw"^
jit numoar from 40 GFH, iuocan 0 ror each luted nazaraout vwsta you will nandla. It you
hsardom «mw wMch an not I load In 40 CFH, Subpart 0. tntm tha four—dlgrt numCarfsi from 40 CFR. Sutxarr C that dascrtbaa tha character**-
tie* and/or tha tonic oomammamt of tha
a. EST1MATBO ANNUAL QUANTITY — Far aach DMd aMknand Ineotann A aolim tha quantity of that wan that w
tan. For aadi iti«aa»fcl
-------
Page A-5
Fvm Aeonmd OMS Ha. I39S30004
21 MP
4 6 3 3
2 0 0 0
DUP
IV. DESCRIPTION OF HAZAflDOPS WASTES (cmttrwdl
imDtW
D
150
TO
30
TO
D
TO
tt
1£
I !
150
TO
100
TO
235
TO
0 5
300
TO
T
TO
10
11
12
13
14
IS
16
17
18
19
20
21
22
T"T
24
1—P
-r-r
25
IT
MI
¦aiHtNti
.PJtnJ.
-a-. ~r. -o-. tm. i
.OP 9
COMTMUI ON UVIA88
-------
Page A-6
£ usfl THia S^AC^ Vo LOaY ADDITIONAL PROCESS cooes FROM ITEM 0( 11 ON PASS 3.
IV. DESCRIPTION OF HAZARDOUS WASTES (continued)
V. FACILITY DRAWING
taelitla mutt incfuda in tti» nae» prowdad on paoaSatcai* drawing of tha faality itmimruevom for men drmtl.
VL PHOTOGRAPHS
All existing fabliau must include photograph* (aerial or ground iatmil that dearly delineate all existing rtnjcturai; axisting storage,
ueaintem and disposal areas: and iitm of future storage, treatment or disposal areas (see instructions for more detail).
VTL FACILITY GEOGRAPHIC LOCATION
UATTTUOS I'd
, wrtnrt—i. A moomdsj
LONOrruoi fdetiwfc 4 waondij
$
&
£
0
X
£
0
7
4
2 0
0
1
0
Vffl. FACILITY OWNEB
Qa. It ttw facility
3. If thafaoHitr
I* no* the faculty
X. OWNER CERTIFICATION
certify under penalty of law cfrar / hare personalty examined and am familiar with the information suOmittad in this and all maenad
tocumenu, and that based on my inquiry of those individual* immediately letpanihhr for obtaining tha information, I believa that tha
ubmittad information it true, accurate, and complete. I am aware that tharm are significant penalties for submitting false information,
ndutUng tha possibility of finaand imprisonmem.
u mams (pfwi or type)
Richard Headley
C. OPERATOR CERTIFICATION]
canity under penalty of lam that! ham personally axaminad and am familiar with tha information submitted in this and ail artachad
acumants, and that bamd on my inquiry of thom indMduaia immadiataiy responsible for obtaining tha information, / beiieve that tha
jbmitted information is trua, aceurata, and eompiata. / am awara that than ara significant penalties for submitting false information,
tduding tha possibility of fina and imprisonment.
. mams (print or typ*t
Richard Headley
A Pom 38104 (MM
PAGE 4 OP 9
C. DATS UANCDf
'CONTINUB
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Page A-7
Continued from pag* 4.
Form Approved OMB No. 1S3-SS0004
V. FACILITY DRAWING (see page 4),
PROPERTY
BOUNOARY
PRODUCTION UNES
STORAGE
TO SEVER
(POTM)
RUN-ON DIVERSION
canal
OUTFALL
COMBINED
7 SEWER SYSTEM
200 ft
SCALE
HAP DATE: 9/10/81
EPA Fom 3810-3 (0-001
PAGE 3 OF 3
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Page B-l
SECTION B
FACILITY DESCRIPTION
This section provides a general description of the Universal
Widget hazardous waste incineration unit as required by 40 CFR
§122. 25(a). This description is intended to acquaint the permit
reviewer with facility operation. Complete details can be found
in other parts of this application.
B-l GENERAL DESCRIPTION
The UWC incinerator unit is located in the town of Treebrook,
New Jersey at the Corporation's manufacturing facility. The unit
is used to treat wastes generated at the facility during the
manufacture and refurbishment of widgets. Hazardous wastes are
generated by metal fabricating, cleaning, and plating operations.
These processes primarily generate waste solvents.
The incineration system consists of a rotary kiln, a secon-
dary combustion chamber and an air pollution control train.
Liquid wastes are fed to the oil-fired incinerator at a maximum
rate of 300 pounds per hour. Solid wastes are incinerated at a
maximum rate of 160 pounds per hour.
B-2 TOPOGRAPHIC MAPS
Figure B-l is a map showing the facility boundaries, build-
ings, waste storage areas, incinerator, and other details.
Figures B-2 and B-3 are topographic maps showing 5-foot contour
intervals of elevation at the facility and within 1,000 feet of
the facility boundaries, respectively. Figure B-4 shows the
100-year floodplain area. The incineration unit is not in the
100-year floodplain.
Figure B-3 also shows surrounding land-use areas. Other
industry is south of the facility; the rest of the surrounding
area is undeveloped.
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Page B-2
An annual wind rose of meteorological data collected from
1965 through 1974 at the nearest weather station, approximately
five miles west of the UWC facility, is shown in Figure B-5.
B-3 LOCATION INFORMATION
B-3a Seismic Standard
The UWC facility incinerator is located in Smithfield County,
New Jersey. The facility location is not listed in 40 CFR §264
Appendix VI; therefore, no further information is required.
B-3b Floodplain Standard
Figure B-6 is a 100-year floodplain map obtained from the
U.S. Federal Insurance Administration of the area surrounding
the facility. Facility boundaries have been drawn in on this
map. As shown in Figure B-4, all hazardous waste management
units at the facility lie outside the 100-year floodplain area,
demonstrating compliance with the floodplain standard.
B-4 TRAFFIC INFORMATION
Traffic routing and control at the facility, as shown in
Figure B-7, allows for the free and safe access of routine and
emergency traffic onto and about the facility and in the vicinity
of the hazardous waste incinerator and ancillary facilities.
Employees' cars are confined to the parking lot and entrance
road. Within the facility, traffic vehicles consist mostly of
front-end loaders and trucks. Semitrailer trucks enter the plant
each working day and front-end loaders are used throughout the
plant on a constant basis as needed.
No over-the-road movement of hazardous waste is anticipated
to occur at the facility. Hazardous wastes are pumped through
closed pipelines to the two 5,000-gallon storage tanks. The
load-bearing capacity of all access and site roads shown on
Figure B-7 is equal to or greater than 2,000 pounds per square
inch. All roads are constructed of blacktop pavement.
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Page B-3
PRODUCTION UNES
TO StttR A?
^(MSTW)
,/RUt-ON DIVERSION
\ /r CANAL
/T^commto
*fft SWER STSTPt
FENCE
200ft
SCALE
MAP OATE: 9/10/81
FIGURE B-l. FACILITY LAYOUT
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Page B-4
130
130
130
125
TO 5tW«^ JF
mpm)
Jtom-m oivtusiiM
K f CJWAl
125
125
f /Jr^cowintc
*>ltl VSTE*.
m
125
125
120
SCALE
|*p DATE: t/10/81
FIGURE B-2. SITE TOPOGRAPHY
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Page B-5
. » residential area
* Vd^STRIW 5 m.)
s. * c1V
INCINERATOR
STORAGE
TANKS
41 46'H
.• uwc
RURAL AREA
%
INDUSTRIAL
LAND USE
ACHE
ASPHAL1
PROPERTY
LINE
PARKING
BATCH
MfER
TACK
7 till LtMER CO
' (DOWSTREAfl 15 >1.)
AGGREGATE
TANKS
HAP DATE: 9/10/81
1 1n. • lOOOtt
FIGURE 3-3. AP.EA TOPOGRAPHY
AND LAND USE
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-*o>
00=225
*s'(*
°°^
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- 02/11/83
Page B-7
TREEBROOK, NEW JERSEY 29,216 OBSERVATIONS
1965-1974 7.1% CALM
WIND SPEED, knots
FIGURE B-5. WIND ROSE
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Page B-8
N
LEGAL BOUNDARIES
OF FACILITY
ZONE C
ZONE AO
V
ZONE AO
ZONE B
650 ft
SCALE
MAP DATE: 4/20/79
LEGEND
ZONE AO - AREA OF 100-rEAR FLOOD;
FLOOD ELEVATION OF
125 feet KSL.
ZONE B - AREA BETWEEN LIMITS OF
100-YEAR FLOOD AND 500-
YEAR FLOOD; OR AREAS
SUBJECT TO TOO-YEAR
FLOODING WITH AVERAGE
DEPTHS LESS THAN ONE
(1) FOOT OR WHERE THE
CONTRIBUTING DRAINAGE
IS LESS THAN ONE SQUARE
MILE. FLOOD ELEVATION
OF 130 feet KSL.
ZONE C - AREAS OF MINIMAL FLOODING.
FIGURE B-6. FIA FLOODPLAIN MAP
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Page B-9
a
&
&
cT
oN
,o.
^°/o
o
A
A.
\N
\©
i\ P
.VCIH6
0\
$
\\
%
u %
STOP SIGN
[lTuI loading/unloading area
FIGURE B-7. TRAFFIC ROUTING AND CONTROL
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Page C-l
SECTION C
WASTE CHARACTERISTICS
The wastes proposed for treatment are the wastes resulting
from the production and assembly of widgets at UWC's Treebrook,
New Jersey manufacturing facility. The waste quantities vary
according to UWC's production demands and operational schedule.
The magnitude and timing of the changes in the waste composition
make it impractical to store and blend wastes to yield a com-
pletely uniform, composite waste for feed to the incinerator.
The various wastes are blended to minimize short-term fluctua-
tions in feed composition.
This section consists of a description of the chemical and
physical nature of the wastes proposed for treatment by the UWC
incineration unit and the Waste Analysis Plan for sampling,
testing, and evaluating the waste to assure that sufficient in-
formation is available for its safe handling. This information
is submitted in accordance with 40 CFR §122.25(a)(2) and (3).
C-l CHEMICAL AND PHYSICAL ANALYSIS
Most of the wastes presently burned in the incinerator are
only partially characterized. Degreasing, solvent recovery,
metal heat treating, and several chemical treatment operations
are the sources of the wastes generated. The waste types and
estimated quantities incinerated during 1980 are identified in
Table C-l and are considered typical for the UWC facility.
A composite sample of the blended waste fed to the inciner-
ator was taken over a 30-day period as described in EPA Publica-
tion SW-846 (Section 1.1.4.1) using methods described in SW-846
(Section 1.2.1). The composite waste was analyzed by the methods
shown to give the results in Table C-2.
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TABLE C-l. WASTE TYPES, QUANTITIES, AND BASIS FOR
HAZARDOUS WASTE DESIGNATION FOR WASTES
GENERATED AT UWC
EPA Hazardous
Waste Number
Description (Ma.ior Constituents)
Basis for Hazardous
Waste Designation
Quantity
Generated
(ton/year)
F001
Spent halogenated solvents and sludges
{tetrachloroethy1ene, tr1chloroethy1ene,
1,1,l-tr1chloroethane)
Waste containing listed
toxic solvents
150
F002
Spent halogenated solvents and sludges
(tetrachloroethylene; 1,1,1-trlchloroethane)
Waste containing listed
toxic solvents
100
F003
Spent nonhalogenated solvents and sludges
(xylene)
Waste containing listed
ignitable solvents
235
F005
Spent nonhalogenated solvents and sludges
(methyl ethyl ketone)
Waste containing listed
toxic solvent
300
F010
Quenching bath sludges
Listed waste containing
reactive and toxic substance,
cyanide
3
DOOl
Ignitable waste
Tested flash point for waste
1s 110 F(a)
150
D002
Corrosive wastes
pH <1^b)
30
D006
Solid wastes from plating shop
EP toxic, cadmium
3
D0Q7
Solid wastes from plating shop
EP toxic, chromium
3
(a) As determined by ASTM Standard D-93-79.
(b) As determined by Method 5.2 in SW-846.
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Page C-3
TABLE C-2. COMPOSITE WASTE ANALYSIS
Parameter
Was te
Liquid
Solid
Me thod
Heat of
combustion
8000 Btu/lb 10
,000 Btu/lb
ASTM D240-76 or
D2015-77
Viscosity
360 cps
—
ASTW D2983-80
Chlor ine
10%
0. 2%
ASTM D808-81
Ash
5.1%
31%
ASTM D482-80 or
D3174-73
Flash point
140 °F
—
EPA SW-846-1010
Water
5%
2.1%
ASTM D4006-81 or
D3302-74
The hazardous organic constituents in the composite samples
were determined by screening analyses. Table C-3 identifies the
sampling and analytical methods used, while Table C-4 shows the
sampling results.
TABLE C-3. METHODS USED IN SCREENING ANALYSIS
Method Liquid Solid
Sample preparation EPA 3510, 3030 EPA 3050, 3060
Analysis EPA 5030, 8240, 3250 EPA 6010
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Page C-4
TABLE C-4. HAZARDOUS CONSTITUENTS CONTAINED
IN COMPOSITE WASTE
Was te
(%)
Parameter
Liquid
Solid
Di chlorome thane
2.1
<1
X
10-6
Di ch lor oe thane
0.5
<1
X
10-6
1,1,1-Trichloroethane
4. 2
<1
X
10-6
Tr ichloroethylene
0.7
<1
X
10-6
1,1, 2, 2-Te trachloroethylene
5.2
< 1
X
10-6
Toluene
3.1
<1
X
10-6
Methyl ethyl ketone
2.9
<1
X
10-6
Xylene
1.4
0.
10
Pentachlorophenal
0.002
0.
005
Cadmium compounds as Cd
<1 x 10-6
0.
11
Chromium compounds as Cr
<1 x 10-6
0.
06
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Page C-5
Pesticides and other high molecular weight organics were not
analyzed because the composition of the solvents and materials
used and the nature of the processes would preclude their forma-
tion. The small quantity of pentachlorophenol found has been
traced to some treated wood in the sample.
C-la Containers
Although some containers are used at UWC to manage hazardous
waste sludges, no drum storage for periods exceeding 90 days
occurs.
C-lb Tanks
This section is not applicable since the wastes are generated
on-site and are treated or removed within 90 days of generation.
C-le Incinerators
C-le(l) Trial Burn
The properties of the waste proposed for use in the Trial
Burn performance tests are identified and described in Section
D-5b(2)(d) of the Trial Burn Plan.
C-2 WASTE ANALYSIS PLAN
The Waste Analysis Plan describes the procedures that will
be used to obtain chemical and physical data on the wastes and
ensure proper treatment and disposal.
The responsibility for the implementation of the Waste Analy-
sis Plan, as described herein, will lie with the UWC's Waste
Management Supervisor.
Each of the waste streams generated at UWC's facility that
are to be treated by incineration will be initially characterized
as to the properties and hazardous constituents specified in
Section C-2a. Subsequent to this waste characterization, each
waste delivery to the incinerator will be subject to a full range
infrared (IR) scan. This scan essentially provides a fingerprint
of the waste, which, when compared to the initial IR scan, will
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Page C-6
provide an effective method for determining whether the organic
content of the waste is significantly different from samples
which will be taken of future wastes.
The Waste Analysis Plan, therefore, has the following
protocol:
• Initial waste characterization of wastes
(Section C-2a), with analyses repeated on
an annual basis.
• Fingerprinting future deliveries of wastes
by infrared analysis. If significant dif-
ferences are detected, the wastes will be
subject to further analyses, and will be
incinerated only if compliance with existing
permit conditions can be achieved.
C-2a Parameters and Rationale
The parameters for which the UWC wastes will be analyzed and
the rationale for analyses are identified below:
Vis cos ity - to ensure that the waste remains a pump-
able and burnable liquid.
Elemental Analysis (including Organic CI) - to deter-
mine potential acid gas generation.
Water Analysis - to determine water content and
incinerability of waste.
Heat Value - to check for significant variations in
the waste composition.
Percent Ash - to check for significant variations in
the waste composition that can lead to particulate
generation.
Heavy Metals - to evaluate variations in waste
composi tion.
Priority Pollutant Scan (volatile organics, acid
extracts, and base/neutral extracts - to check for
significant concentrations of hazardous components.
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Page C-7
Flash Point - to determine ignitability to properly
handle wastes.
C-2b Test Methods
The test methods which will be used to test the parameters
identified in 40 CFR §264.13(b)(1) are as follows:
Heat of Combustion - ASTM D-240-76
Viscosity - Brook field Viscometer, for methodology
refer to its operating manual.
Elemental Analysis - 1980 Annual Book of ASTM
Standards, Part 26 - Gaseous Fuels? Coal & Coke?
Atmospheric Analysis
Organic CI - ASTM D808-81
Percent Ash - ASTM D482-80
Water Analysis - ASTM D3173-73
Heavy Metals (RCRA) - Cd - EPA Method 7130, Cr - EPA
Method 7190
Organic Appendix VIII Constituents - EPA Methods 8010
and 8U15 or 8240 and 8250 and 8020.
Volatile Organics - EPA Methods 8240 and 8250 or 8010
and 8015
Acid Extract - EPA Method 3 530
Base/Neutral Extracts - EPA Method 3530
Flash Point - EPA Method 1010
Organics - Infrared Analysis Method in IERL-RTP,
Procedures Manual: Level 1 Environmental, Assessment
(2nd Ed.), October 1978 (EPA-600/7-78-201)
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Page C-8
C-2c Sampling Methods
Wastes are stored in a single, 5,000-gallon, horizontal,
above-ground tank prior to injection into the incinerator. (An
identical standby tank is available for storage if needed.) The
tank is 7-ft in diameter and 17-ft long. Samples are taken from
the tank using a weighted bottle as described in "Test Methods
for Evaluating Solid Wastes", EPA Publication No. SW-846.
One-liter samples are drawn from the top and bottom of the
tank and combined to form two similar one-liter samples for
analysis. A chain of custody form is initiated by the individ-
ual drawing the samples and accompanies the samples throughout
their transport to a laboratory and subsequent analysis. The
completed original forms are returned to UWC with the analytical
results from the sample analyses.
Sludges are sampled by using a split-tube thief sampler and
will represent a composite sample based on 3 grab samples from
the top, middle, and bottom of the drum in which they are held
(ASTM D346-5) .
C-2d Frequency of Analysis
Detailed waste analyses for the parameters in Section C-2b
will be conducted once a year to verify the consistency of the
waste stream. In addition, any time production changes or upsets
occur which could alter the characteristics of the waste stream,
the Production Supervisor will notify the Waste Management Super-
visor and waste analyses will be conducted.
The infrared analyses will be conducted for each batch of
wastes to be incinerated.
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Page C-9
C-2f Additional Requirements for Facilities Handling Ignitable,
Reactive, or Incompatible Wastes
All liquid wastes will be assumed to be (and handled as)
ignitable materials. The area around the feed tank will be
classified as semi-hazardous Class 1, Division 2, Group D under
NFPA.
No reactive or incompatible waste will be managed at the
Treebrook UWC facility.
C- 2g Quality Assurance/Quality Control (QA/QC)
UWC's QA/QC program for the laboratory serves to document the
quality (i.e., accuracy and precision) of generated data; main-
tain the quality of data within predetermined tolerance limits
for specific sampling and analysis procedures; and provide guide-
lines for corrective action if a procedure is not within control
limits. This program is currently being implemented and will be
effective for the trial burn and subsequent hazardous waste
analytical and sampling operations.
(1) Responsibility - Responsibility for management of the
QA/QC program rests with the QA/QC officer, who reports
directly to UWC's Vice President of Operations. In
addition to routine and random QA/QC checks, the QA/QC
officer reports on QA/QC related laboratory activities
on an annual bases to the corporate officers. The
laboratory activities, per se, are under the direction
of UWC's Laboratory Manager. The QA/QC officer has a
staff of three persons, each assigned to the separate
activities of sampling, analysis, and data management.
(2) QA Objectives - UWC's Laboratory objectives for QA are
summarized below:
Accuracy and Precision - To achieve accuracy goals,
reference materials of the highest available quality
are used for calibration and spiking. Errors due to
instrument response and incomplete preparation recover-
ies are controlled to the greatest extent possible so
that the uncertainty due to random errors does not ex-
ceed precision goals. Precision goals include calibra-
tion curve coefficients greater than 0.95, and results
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Page C-10
TABLE C-5. ACCEPTANCE LIMITS
FOR PRECISION OF ANALYTICAL DATA
Techniques or Parameter Sample Type Precision*
Proximate
(Ash, solids,
elemental content) Waste feed 10%
Survey
GRAV Waste feed, stack sample 10%
TCO Waste feed, stack sample 30%
IR Waste feed, stack sample 30%
Directed
GC/MS ** 30%
GC ** 30%
ICA/AAS ** 30%
IC ** 30%
*Precision is calculated as 100 times the standard deviation
divided by the mean.
**Waste feed, stack gas, scrubber water and bottom ash.
of replicate samples within the limits shown in Table
C-5. These goals will be maintained for all parameters
and techniques related to the incineration operations.
Completeness - Analytical results are obtained for at
least 90 percent of the collected samples.
Representativeness - Selection of sampling sites, fre-
quency, procedures, and sampling equipment are directed
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Page C-ll
at obtaining a representative sample and are based on
standardized laboratory practices.
Sampling and Analytical Procedures - Sections C and D of
this permit application detail the sampling and analyti-
cal procedure (by reference), frequency, and number of
replicate tests to be run (as appropriate) for the waste
feed, stack gas, and other effluent samples. These pro-
cedures are well-documented and will be kept on file
within the laboratory.
Sample Custody - Chain-of-custody procedures will be the
responsibility of the QA/QC officer. This individual
will act as the sample custodian at the laboratory,
authorized to sign for incoming samples and verify that
data is entered into the custody records. UWC has pro-
vision for a sample custody log, consisting of serially
numbered lab-tracking report sheets.
Calibration Procedures and Frequency - The calibration
procedures and frequency for sampling and analytical
instruments will be set according to manufacturers
specifications and the appropriate sampling/analytical
procedures. Calibration information is retained in
laboratory notebooks.
Data Reduction Validation - Validation of data integrity
from the raw data through the data reduction phases of
analysis is achieved by including frequent verification
of raw data storage in computer files and examination
and tracing of data through the final reported values.
In addition, all associated blank, standard, and QC
data are reported with analytical results to provide an
internal check on the reasonableness of results.
Internal Quality Control Checks - Replicate and spiked
QC samples and calibration standards will serve as
internal quality control checks. Blank samples (field,
method, and reagent and solvent blanks) are used to
assess possible contamination from the field and/or
laboratory. Analytical replicates serve to check on
the validity of analogous samples, while spiked samples
serve to check on the accuracy of sample preparation
and analysis procedures. Spiked samples using analyses
of the designated POHCs will be utilized by UWC both
during the trial burn and normal operations.
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Page D-l
SECTION D
PROCESS INFORMATION
D-5 INCINERATORS
D-5a Justification for Exemption
Of the wastes produced at the Treebrook UWC facility, one is
a waste stream consisting exclusively of waste mineral spirits
contaminated with oils and waxes. This material has been
analyzed for volatile and semivolatile organics and toxic metals
by EPA Methods 8240, 8250, and 6010. Analytical results indicate
that no Appendix VIII materials are present in the waste. These
results agree with UWC's evaluation based on the source and use
of the mineral spirits.
The material is not corrosive, reactive, or EP toxic accord-
ing to the published criteria (40 CFR §§261.22 - 261.24); how-
ever, it has a flash point of 110°F by EPA Method 1010. Conse-
quently, the material is hazardous because it is ignitable. UWC
proposes to use this material as a fuel supplement during start-
up and shutdown of the incinerator and that it be granted the
exemptions provided in 40 CFR §264.340.
D-5b Trial Burn
D-5b(2) Trial Burn Plan
D-5b(2)(a) Detailed Engineering Description of Incinerator
1. Manufacturer's name and model number of incinerator
The principal components of the UWI incineration system
were designed and fabricated by W.E. Burnit Company. It is a
unique design with no model designation.
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Page D-2
2. Type of incinerator
The incineration system consists of a rotary kiln, a
secondary combustion chamber (SCC), and an air pollution control
section.
3. Linear dimensions of the incinerator unit including
the cross-sectional area of combustion chamber
The rotary kiln is a roughly horizontal rotating
cylinder, sloped slightly toward the discharge end, and is 52-in
ID by 16-ft long. Combustion gases pass from the kiln through a
duct to a secondary combustion chamber (SCC). The SCC is 52-in
ID by 36-ft long. The calculated cross-sectional areas of both
the kiln and SCC are 14.8-sq. ft.
4. Description of the auxiliary fuel system
Two auxiliary fuel burners are located in the feed end
of the kiln firing axially down the kiln. Two other identical
burners fire tangentially into the inlet end of the SCC. The
location of these burners is shown in Figure D-l. These four
burners will be 4-in Maxon Multifire II burners (by Maxon Cor-
poration, Muncie, IN), or their equivalent. They are described
by the literature attached as Figure D-2. Briefly, they are air
atomized, forced draft oil burners. (There is a variety of
suitable fuels that can be used). Fuel oil for the burners is
supplied from the facility's 100,000-gallon oil tank. A piping
diagram of the system is shown in Figure D-3. The burners have
a combined capacity of 435 L/hr (1.92 gpm).
5. Capacity of prime mover
A single-stage 36-in diameter centrifugal fan powered
by a 150-hp variable-speed electric motor draws the combustion
gases through the system. This fan has a nominal capacity of
9100 cfm of flue gas saturated with water at 175°F when operating
at 3350 rpm and a 43-inch water column differential.
6. Description of automatic waste feed cut-off systems
Instrumentation is provided to monitor process condi-
tions, provide data for assuring compliance with regulatory
requirements, and assure appropriate process response and con-
trol, operational flexibility, and safety interlocking and
-------
4™
Burners
ir=H
Burner
_L
WATEI) UIJEC1I0H PORT
t
Burner
SOI ids nAU
UCU StSIEM
«u m piiive
[ H ««.
( ) f|n ii —
r— —
sunNcnsflo
fctlN
(tKft1) )fy
(l/WMCfoay)
t
.
V2
|*j< sa»fF|
BURNER
|RT. SIDE)
r'
1*1
! .1 J
KFT sioe
BoMMeR
- tK
H'O* (»»4»lOg^
¦ M»nn ftoOOMRb A4ie
TA>JCa«MllAU.*< HkMTflO
SECONDARY
COMBUSflON
CIIAMBEn
QUENCH El
FIGURE D-l. BURNER LOCATION
PJ
iQ
(D
0
1
to
to
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Revision 0 - 02/11/83
Page D-4
M AM© N
EZ
SEE
MULTIFIRE ®
Gas or Oil Burners
* * * *THIS BURNER OR ITS EQUIVALENT WILL BE IJSKD****
DESIGN DETAILS
MULTIFIRE Burners are of e nozzle-mix refractory block design capable of
on-ratlo firing over a broad range of operating conditions. They can be sup-
plied in either of two piping configurations, and can be installed in any "nor-
mal" mounting position.
Suitable Fuels
include natural
propane, light oils (up to #2), PLUS
methanol, low BTU gas, and many waste
gases. In some cases, minor burner
modifications are necessary. A special
version of the 6" burner may be fired
on heavier oils (up to #61.
Air Supply (combustion and atom-
izing) can be a single 16 ounce blower.
There is no need for high pressure
atomizing air supply.
Smaller Sizes 12", 3" and 4")
are designated as MJLTIFIRE II. A
unique nozzle design provides extreme-
ly clean combustion with gas or oil,
as well ason-ratio firing capabilities.
,ju>
\
2-
...
t-
-z-r1
$
Larger Sizes (6", en and io"> are
designated as MJLTIFIRE III. They may
be overfired if adequate secondary air
is avaiIabIe at the burner.
ACCESSORIES
u
*
OKrtft u®
4
"t ¦
Burner
with
Seal A
Support
Housing
1
---
Seal & Support Housings are
avaiIabIe to provide additional support
to burner block, giving longer life In
thin wall or soft wall installations.
Downfire Support Rings shou I d
be added to Seal & Support Housings
for roof-mounted burners.
Cooling Tee Sets can be supp I i ed
to facilitate delivery of purging air
to UV Scanner sighting port.
Maxon
MAKON HACKH A POllCr o* CONIINUOUl IMnOVfMtNT IN ITS MTODUCI OfUGNS AND CONSIIUCTtOM
II Rtlitvtl tM| aiOHl lO AlTCt S*«l»
-------
To Kiln Burners
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••fSSSS>-
vjrj
T-402
WTMt-itmrt r-\
>*«
SCC Burner Piping
Typical of Kiln
Auxi1Iary
Fuel Oil
Tank
Main Fuel
Oil Tank
FIGURE D-3. SCC BURNER PIPING TYPICAL OF KILN
(D
iQ
(D
U
I
Ul
33
fD
<
H-
01
H-
O
3
o
M
00
U)
-------
Revision 0 - 02/11/83
Page D-6
shutdown features. The safety interlocks and shutdown features
comprise a major portion of the control system.
Safety shutdown responses identified in Table D-l are
relayed to various equipment items when process limits are not
met. In general, the process parameters that alert and initiate
responses to alarm conditions are:
(1) Kiln temperature greater than 1900 °F or
less than 1400°F.
(2) Secondary combustion chamber temperature
greater than 2400 °F or less than 2060 °F.
(3) Secondary combustion chamber outlet oxygen
(C^) level less than 4%.
(4) Flow in the quench, particulate scrubber,
or mass transfer scrubber less than
40 gpm, 8 gpm, or 100 gpm, respectively.
(5) Level in the quench, particulate scrubber,
or mass transfer scrubber sumps less than
5 in, 4 in, or 6 in, respectively.
(6) Gas temperature in the quench section
greater than 240 °F.
(7) Pressure at the induced-draft inlet
greater than -20 inches w.c.
(8) Vibration of the induced-draft fan greater
than 0.003 in.
(9) Atomizing air pressure less than 30 psi.
(10) Fuel oil or waste pressure less than 20
psi .
The fuel oil burner system includes an internal inter-
lock system that shuts down the burner system (i.e., fuel oil
flow) if: (1) a flame is detected during pre-ignition; (2) the
pilot fails to ignite; (3) the burners fail to ignite; or
(4) there is a loss of flame after ignition. A shutdown of the
burners automatically stops all waste feeds.
-------
Kiln Burners
SCC Burners
Emergency Vent
ID Fan
Quench Sump Pump
Kiln Ram Feed
Waste Oil Feed
PA«TI-
OUENCII
KILN
SCRUBBER
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
0
o
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Key:
X - Turns off
0 - Opens
Burner limits include air and fuel pressures.
TABLE D-l. PROCESS LIMITS/RESPONSE CHART
^0
(D
ft)
O
I
fD
<
H-
cn
H-
o
3
o
fo
to
K>
00
LO
-------
Revision 0 - 02/11/83
Page D-8
During an alarm condition, waste and fuel oil feeds are
immediately stopped. When required, the induced-draft fan is
shutdown and the emergency vent located between the quench sump
and scrubber opens. All recycle and makeup water flows are
maintained, if possible, to prevent overheating in the mass
transfer scrubber.
7. Stack gas monitoring and pollution control equipment
The stack gas will be analyzed for , and CO. A gas
sampling/conditioning assembly — a sample transport and calibra-
tion system and two gas analyzers controlled by a microproces-
sor — will be used. A description of the monitors is given in
Table D-2.
The hot flue gases leaving the SCC pass into a quench elbow
where they are cooled by a quench water spray system. The flow
gases then pass through an Anderson 2000 Cleanable High Effi-
ciency Air Filter (CHEAF), or equivalent, where the particulates
are removed as the gases pass through a wetted fiberglass mat.
A pressure differential of about 30-inches W.C. is maintained
across the mat. Design flow rates through the CHEAF are main-
tained by recycling gas from the ID fan discharge. Acid gases
are removed from the flue gases in a cross-flow scrubber. The
bed in this scrubber has a 3 5-sq. ft. cross-section and is 8-ft .
8-inches long. It is irrigated by a 190 gpm recycle stream of
alkaline scrubbing solution with a pH of about 8.8.
8. Nozzle and burner design
The waste oil and aqueous injection nozzles are air
atomized North American series 5622-01 oil atomizers, or their
equivalent. Details are shown in Figure D-4.
9. Construction materials
The kiln and SCC are steel cylinders lined with 6-inches
of Bailey Brick 30 refractory. The duct connecting the kiln to
the SCC and the transition assembly are made from Inconel 601.
The quench elbow and scrubber are made from Inconel 625. The
cross-flow scrubber packing is made from fiberglass reinforced
plastic. The ID fan has a 304 stainless steel" housing and an
Inconel 625 shaft and rotor.
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Revision 0 - 02/11/83
Page D-9
TABLE D-2. CHARACTERIZATION OF MONITORS
Component
*
Analyzer
Analysis Range
CO
NDIR
0-500 ppm
Hots tuff Model MIA1
® 2
Electrocatalytic
0-2 5 percent
Zippy Model 73
*The listed analyzer or an equivalent analyzer will be used.
10. Location and description of temperature, pressure,
and flow indicating and control devices
The control instruments described in Table D-3, or
their equivalents, will be used at the facility. (The location
of the sensors is shown in Figure D-5).
D-5b(2)(b) Detailed description of sampling and monitoring
procedur es
1. Sampling and monitoring locations
The gaseous and particulate emissions produced by the
combustion process will be monitored at the stack (Figure D-6) .
One 4-in port will be provided for the continuous monitoring of
combustion gases. This port is located 24-inches downstream
from the stack silencer section. The other sampling location on
the stack consists of five, 3-inch connections mounted on a
single face of the stack duct. The connections are spaced to
allow sampling for particulate matter in accordance with EPA
Methods 1 and 1-5 protocols. The centerline of these sample
ports is 72-inches downstream of the stack silencer.
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Revision 0 - 02/11/83
Page D-10
* *
**THIS BURNER OR AN EQUIVALENT WTT.T. RE TTRT?n
* ** *
North American
m«9 Co
Clavaland. OH14105 USA
OIL ATOMIZERS
Steam or Compressed Air
BULLETIN 55.22
5-30 56.23
Sanaa 5622 and 5S23 Nozzle Mixing Atomizer* produce 30° spray
angles and fairty long flames such as required for steel mill reheat fur-
naces, rotary dryers, and other long combustion chambers. The stainless
steel oil nozzle is concentric in the stainless steel nose, and flush with
it: so steam and oil pressures do not affect each other.
Combustion air must be supplied around the atomizer. To accomplish
this, the atomizers can be supplied as part of Luminous Flame Burners,
Refractory-Lined Burners, or Magna-Flame Burners. By specifying the
proper "L" dimension, a user can adapt the atomizers to existing burners.
For installations where adequate combustion air is provided. North
American can furnish a complete assembly consisting of atomizer,
mounting, mounting plate, and refractory tile as shown below. Special
nozzles to produce wider, shortet flames have been designed — consult
North American.
Cleaning. Strainers are recommended in both the steam and oil lines.
The oil nozzle of any of these atomizers is readily accessible for cleaning
(with steam or a wire) by removal of a pipe plug at the back which opens
a straight passage to the oil nozzle if the customer has piped the-unit as
shown dotted for 5622. The quick clean-out feature of Series 5S22
permits cleaning of the steam or air passage even dunng operation, simply
by pushing the oil tube forward against an internal stop, then returning
it to operating position. The outside diameter of the oil nozzle is sized
to efficiently clean the inside of the steam nozzle of any carbon deposits
resulting from shutdowns of steam before oil. The quick disconnect
feature of Series 5623 permits removal of the oil tube, opening a straight
passage to the steam or air nozzle.
The suggested oil valve is a North American Sensitrol (brass, rated
250 psi, 275 F). The oil pressure at the oil valve inlet should be at least
5 to 10 psi 'OK to use a Ratiotrol). The steam or compressed air valve
is a Series 1832 Globe Valve (bronze, rated 200 psigl.
Although the mountings for these atomizers provide a place for installing
a 4021-14 Pilot Tip, the ability of this pilot to light the oil flame cannot
be guaranteed because of the uncontrolled amount of air induced through
the register.
5 200
Whan using compressed air aa an atomizing madium. air consumption in scfm is one-lHird of lb steam/hr for the tame pressure.
Example: An 08 atomizer uses 285 Ib/hr steam with 75 psi steam pressure or 233/3 ¦ 95 scfm air with 75 pat air.
rru-s0-j : AOMMr'l
I PNJ-BH
¦ 1 -iV!—ir„ |
Tl» Mtg
y PfQ.2451-1
' Bunar Mtg.
PNA-199S-1
DnAM Hot*
' for I" fhkat
FN3-J31.:
tv,%- /
PN3-35I-3
4-H*
HC Softs
no-nit
MOUNTING (or -02 and <01 ATOMIZERS
MOUNTING for -0 and -1 ATOMIZERS
TOoening in furnace ihefl or outer wall must be * larger than tile dimension io allow for mounting plate ffHet and draft.
FIGURE D-4. DESIGN DETAILS OF OIL ATOMIZERS
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Revision 0 - 02/11/83
Page D-ll
DIMENSIONS
****THIS BURNER OR AN EQUIVALENT WILL BE USED*
03 Tybo PLm* InAtfiii
bodt Pta»» Pockmg Nwf
lj~
¦k ~ *
• NoztW
03
oa Tub* Poct*g ^ io9m
Dot»«d *©• fiftmgi not \ ?otkmQ Son*, I
Iwfrmnvd by North Awwkow \ « '
\.-v - ^ Hi'-rrrnT"
O
Stoe Coflor
./ Sor«*q Smi /3iLJ -:~-
OJ VoW«
Ov Netxw
»OKi»f Um
w
Series 5622 Atomizers
DtflMniioiit
in inches
I 5622-02-A & -02-8
-4>5422-01-A i -01-B
; 562 2-0-A & -0-8
° 5622-1-A & .1.0
tot • i«dm oo» thread 3308-1
3-3309-1
3-3306-1 3-3306-1 3-3301-1 3-3301-1
IR740-6360 IR740-6360 IR740-6390 IR740-6390
IH790-0115 IR790-0120
Dottod ports othor than pip* (ittuiqs or* lor mountinq atoouxsr
insida a burner. To raplae* thasa, specify port nam*, otomixor
s*ri*s, burn*r s«ri*s and sxz*.
Parts not listad for Sorias 5623 Alomizars ar* th* soma as Ear
Sarias 5622 Alomisars-
FIGURE D-4. (CONTINUED)
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Revision 0 - 02/11/83
Page D-12
TABLE D-3.
LOCATION OF SENSORS
Ins tr ument
Iden ti fication
Number
Type *
Kiln gas exit temperature
TIC 101
Type R Thermocouple
SCC gas exit temperature
TIC 201
Type R Thermocouple
Quench outlet temperature
TSH 336
Type J Thermocouple
Waste oil feed rate
FI 401
Pos . Displ. Meter
Quench water flow rate
FI 355
Ori fice
Particulate scrubber
solution flow rate
FI 355
Variable Area Meter
Scrubber solution flow rate
FI 375
Ori fi ce
Particulate scrubber
pressure differential
DPI 356
D/P Cell
ID fan inlet pressure
PI 376
Diaphragm Gage
Quench inlet pressure
PI 336
D/P Cell
*This type sensor or its equivalent will be employed.
-------
Purge Atomizing
Air
Waste
Waste
Feed
1-407
F-zOl
Blower
P-405
Waste Feed
C-202
C-102
Rotary Kiln
Elbow
C-301
Filtration
ledla
Burners C-201
Secondary Combustion
Chamber
Burners
C-30Z
Particulate
Scrubber
Propane Cylinders
for Start-up
V-201
Quench'Sump
C-305
Scrubbe
Shroud
T-103
Cool Ijin-
Ash Receive
F - 301
t.Dl Fan
V-301
Solution
StfTP
P-302
Scrubber
Recycle
Pusp
P-201
Caustic
T-402
Quench
fOOl
Solution
Recycle
PUTD
Recycle
Fuel Oil
Tank
P-4D1 I 2
Fuel Oil
Pump
To Sewer
Process Water
Aotolent Air Blower for
CooAustlon, Atomizing,
Pilot, and Tuyere
FIGURE D-5. INCINERATOR SYSTEM SENSORS AND CONTROLS
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Revision 0 - 02/11/83
Page D-14
5-3" ?orea for
XodilUd Machod 5
Sapling
Dl*di*r*«
30 ft. Abm
Ground Unl
4" Pore for
Continuous Suck
""" Boolcor
Sll<
3CC
tfZ. SGUJB3E2
FIGURE D-6. STACK GAS SAMPLING LOCATIONS
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Revision 0 - 02/11/83
Page D-15
Feed Sample Location. The Trial Burn test feeds will
be prepared in the standby waste storage tank. Prior to each
test, the feed material will be sampled according to the
procedures described in C-2c.
Scrubber and Ash Sample Locations. The combined
scrubber, particulate scrubber, and quench effluents will be
sampled after each test from the 5,900 gallon waste-water tank.
Ash samples will be collected from the ash discharge chute on
the end of the rotary kiln. Sample locations are shown on
Figure D-7.
2. Equipment to be used
Particulates, HC1, and H^O will be determined with a
Method 5 sampling train according to EPA Method 5, (40 CFR §60,
Appendix A) using 0.1N NaOH in the impingers in place of water;
POHCs will be determined by EPA Methods SW-846 (1.2.1.11) and
3710. Fixed gases in the flue gas will be analyzed by EPA
Methods 3 and 10. Waste feed and scrubber effluent .samples will
1 /
be taken in glass bottles according to Method S004=- . Inciner-
ator ash samples will be taken with a scoop according to EPA
Method SW-846 (1. 2.1.7). Most of the fine particulate matter
generated during the trial burn tests will be collected on the
disposable fiberglass filter mat in the particulate scrubber.
At the end of each test a portion of this mat, approximately
12-inches square, will be removed and placed in a cleaned glass
jar for analysis for POHCs. The sample portion of the mat will
be removed from the filter exposed during the end of the trial
burn tests to collect a sample representative of the steady-state
operation of the incinerator. The total area of filter media
used for each test will be measured to estimate the total parti-
culate matter collected.
3. Sampling and monitoring frequency
The sampling and analysis schedule during the trial
burn is indicated in Table D-4. Triplicate tests will be run
for each trial burn.
—^U.S. EPA, Sampling and Analysis Methods for Hazardous Waste
Incineration (First Edition), February 1982.
-------
Air
83
Haka-Up_
Vatar
Dlaaal Pual |
t
w
u
Vatar £
Mr }
10TARY L™
8BC0NDA1Y
G0HSU8TI0N
C1IAMBBB
Waata v
on 1 -1
KILN pM
ri
87
JJt—.t 1,—i
r>69
WW*
Aah
CUBAP
H
1
MI
8CBUBIEB
T~0
66
AUAI.INF
TANK
J
53 Waste Oil Feed Sample w
fD
54 Kiln Ash Sample <
55 Alkaline Feed Sample h-
o
S7 Stack Gas Sample 3
0
1
US
£) O
in m
(D \
H
D (-•
FIGURE D-7. IDENTIFICATION OF SAMPLE POINTS ^ \
CTl CO
-------
TABLE D-4, SAMPLING AND ANALYSIS SCHEDULE
Sample
Type
Method
Frequency
Preparation
Method
Analysis
Waste feed (liquid)
Grab
S004
30 min
Composi te
P001
POHC, CI, o
iQ K>
(D \
H
D (-1
I \
l-> 00
0J
-------
Revision 0 - 02/11/83
Page D-18
4. Planned analytical procedures for sample analyses
The standard sample preparation and analyses procedures
in Table D-5 will be used during the trial burn. Sampling
procedures are given in D-5b(2)(b)2.
Gas analyses for CO will be by EPA Method M-10, and for
C>2 and CO 2# by an Or sat analyzer.
D-5b(2)(c) Test schedule
1. Dates when trial burns are planned - Trial burns
are planned to begin on April 1, 1983 contingent upon receiving
the approval of the Trial Burn Plan. The schedule for the tests
is shown in Table D-6.
2. Duration of each trial burn - Each trial burn is
scheduled for one 8-hr day but this time frame may have to be
extended if problems are encountered.
3. Quantity of waste to be burned - Each test is
expected to last about 4 hours, plus about 2 hours of equilibra-
tion. For the planned 6 tests, this would amount to 36 hours of
operation using the test wastes. The consumption of test waste
is expected to be 13, 500-lb of liquid and 7, 200-lb of solids
allowing a 25 percent safety factor. The kiln will be operating
can normal wastes under interim status prior to and following the
tests. It is expected that the unit will be equilibrated at
test conditions with normal waste and switched to the test waste
about two hours prior to the start of each day's testing. At
the conclusion of the testing, normal waste will be fired until
the next test. A surplus of test waste will be prepared in case
operational problems require a longer testing period. Unused
waste will be incinerated at the conclusion of the tests.
D-5b(2)(d) Test protocol for each test
1. Waste constituents - F003 and F001 wastes will be
combined to achieve a mixture containing at least 12 percent
CI. If necessary, the amount of F001 can be reduced and the
mixture spiked with perchloroethylene to yield a mixture of
10 percent perchloroethylene by weight. This mixture will be
burned with plant trash and D006 waste.
-------
Revision 0 - 02/11/83
Page D-19
TABLE D-5. ANALYTICAL PROCEDURES
Sample
Matrix
Parameter
Analytical Method
Waste feed
Kiln ash
Scrubber purge
Stack gas
Liquid
Solid
Liquid
Sol id
Liquid
Sol id
Sol id
Liquid
Gas
Gas
M5 impingers
VOST
POHC
POHC, metals
CI
CI
aHc
AHc
POHC
POHC
CO
C02, 02
CI
POHC
8010, 8015, 8020
P0216, 8010, 8015,
8020, 6010
ASTM D 808-81
ASTM D 2361-66
ASTM D 240-76
ASTM D 2015-77
P0216, 8010, 8015,
8020
8020, 8015, 8020
EPA 10
Orsat
ASTM D 512-80
(AgN03)
3720, 8010, 8015,
8020
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Revision 0 - 02/11/83
Page D-20
TABLE D-6. TEST SCHEDULE
Test Duration, Combustion Performance Standard Tests
Date Day hr. Temp., F DRE Particulates HC1
1-1 1 4 1800 XX X
1-2 2 4 1800 XX X
1-3 3 4 1800 XX X
2-1 4 4 2000 XX X
2-2 5 4 2000 XX X
2-3 6 4 2000 XX X
-------
Revision 0 - 02/11/83
Page D-21
The make-up waste for the test will be stored in the
standby 5000-gallon feed tank. A portable mixer will be
installed for blending purposes. Sampling will be achieved by a
Coliwasa SW-846 (1 .2.1 .1). Sample analysis will be complete by
EPA Methods 8010, 8015, and 8020.
POHC designation will depend on the wastes available at
the time of the test. Perchloroethylene will be added to the
waste in quantities to assure that it is the highest concentra-
tion and most difficult to burn hazardous component present.
Potential POHCs include:
Cons ti tuent
Heat of Combustion
(kcal/gram)
Perchloroethylene
Methylene chloride
Trichloroethylene
Methyl chloroform
Ethylene dichloride
Methyl ethyl ketone
Toluene
1.19
1. 20
1.74
1.99
3.00
8.07
10.14
UWC recommends that perchloroethylene and methyl chloro-
form be designated as POHCs in this test.
2. Combustion temperature ranges - The combustion tem-
peratures for the tests will be 1800 °F and 2000°F, as indicated
in Table D-6. Combustion temperatures normally are controlled
to within 50 °F. It is expected that this range will prevail
during the test.
3. Waste feed rate - The waste feed rate for each test
will include 300 lb/hr of liquids and 160 lb/hr of solids, for a
total of 460 lb/hr.
4. Combustion gas velocity - The combustion gas flow
rate is calculated to be about 500 cfm at 2000 °F. Based on this
flow rate, the residence time in the secondary combustion chamber
would be 4.6 seconds. The combustion gas velocity in the SCC is
calculated to be 8.4 ft/sec.
Auxiliary fuel - Auxiliary fuel is available and
will be automatically burned in the unit if the combustion tem-
perature drops below a lower alarm point set at 50 °F below the
-------
Revision 0 - 02/11/83
Page D-22
temperature set point. Normally, the heating value of the fuel
burned is adequate to maintain temperatures and the auxiliary
fuel is used only for startup and shutdown. Auxiliary fuel is
not anticipated to be necessary during the tests.
D-5b(2)(e) Description and planned operating conditions for the
emissions control equipment
The emissions control equipment will be operated as
described in D-5b(2)(a)7.
D-5b{2)(f) Shutdown procedures
Procedures for shutting down the waste feed are de-
scribed in D-5b(a)6. These procedures will be in effect during
the tests. They are designed to rapidly and safely shut down
the equipment in case of a malfunction while minimizing the
emission of pollutants.
D-5b(2)(h) Quality assurance and quality control procedures
QA/QC procedures, as described in the waste analysis
plan in C-2g, will be used during the trial burn.
D-5d Performance test determination
Trial Burn results and determinations will be provided as
they become available but not later than 90 days after the com-
pletion of the test.
-------
Revision 0 - 02/11/83
Page F-l
SECTION F
PROCEDURES TO PREVENT HAZARDS
The information provided in this section is submitted in
accordance with requirements of 40 CFR §§122.25(a)(4), (5), (6),
(8), and (9). Other regulations addressed to complete this
section include 40 CFR §§264.14, 264.15, 264.17, 264.174,
264.194, and 264.254.
The following subject areas are addressed in this section:
security provisions, inspection requirements? preparedness and
prevention requirements? preventive procedures, structures and
equipment; and prevention of accidental ignition or reaction of
ignitable, reactive, or incompatible wastes.
F-l SECURITY
F-la Security Procedures and Equipment
Security for the UWC facility includes perimeter fencing
with gates and guards as discussed below. In addition, several
other features contribute to the safety and security of the
facility. Ample lighting is provided throughout the site and
guards are equipped with hand-held, two-way radios to report
upset conditions immediately. In addition, a base station for
the public address system is located in the plant manager's
office. A telephone system provides for communications both
within and outside the incinerator site.
Employees are required to show identification badges when
reporting for work, and visitors entering the site must sign a
log sheet, obtain visitor passes, and be accompanied by a UWC
employee at all times.
Although only required to provide either a 24-hour surveil-
lance system, or a barrier and means to control entry, the UWC
facility is constructed and operated to provide both.
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Revision 0 - 02/11/83
Page F-2
F-la(l) 24-Hour Surveillance System
Security at the UWC facility is maintained by a staff of
trained security guards, who primarily monitor entry and exit
from the site and provide security measures within the premises.
The main entrance gate to the facility is operated by remote
control from the guard house, which is occupied by guards,
24-hours a day, 7-days a week, except during holidays, at which
time the gates remain locked. Guards normally work 8-hour shifts
with a crew of 6 guards per day. During each shift, one guard
makes a walk-through of the site at scheduled intervals, while
the other remains in the guard house.
F-la ( 2) Barrier and Means to Control Entry
F-la(2){a) Barr ier
Except for parking areas, the entire facility is enclosed in
a 8-ft high chain link fence with 3 strands of barbed wire at
the top.
F-la(2){b) Means to Control Entry
As discussed in section F-la{l), entry to the UWC site is
controlled by a guard stationed at the main entrance gate.
Employees are required to show identification badges when report-
ing for work and visitors entering the site must sign a log
sheet, obtain visitor passes, and be accompanied by an employee.
F-la(3) Warning Signs
Warning signs, which are legible from a distance of 25-ft,
are posted at all security fence gates and several other fence
locations around the site. These signs are visible from all
angles of approach and bear the legend "Danger - Unauthorized
Personnel Keep Out". The legend is written in English and Viet-
namese, as there is a substantial Vietnamese community residing
in Treebrook. Also, "No Smoking" signs which are legible from
25-ft are located in the waste storage and handling areas.
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Revision 0
- 02/11/83
Page F-3
F-lb Waiver
No waiver of the security requirements is requested.
F-2 INSPECTION REQUIREMENTS
F-2a General Requirements
The UWC incineration system personnel conduct routine inspec-
tions of the incinerator and auxiliary equipment for malfunc-
tions, structural deterioration, operator errors, and discharges
that could cause or lead to the release of hazardous waste con-
stituents and adversely affect the environment or human health.
F-2a(l) Types of Problems
Table F-l presents the schedule for inspecting monitoring
equipment, safety and emergency equipment, security devices,
operating and structural equipment, and all auxiliary equipment.
The items listed in the table are considered important because
of their role in preventing, detecting or responding to environ-
mental or human health hazards. Provided with each item is a
list of problems which might be encountered.
F-2a(2) Frequency of Inspection
Also provided in Table F-l is the frequency of inspection
for each item.
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Page F-4
TABLE F-l. INSPECTION SCHEDULE
Item Procedure Frequency Conditions
Tanks
Visual
Mechanical
Each shift
Annual
Leaks, level
Wall thickness,
internal corrosion
Pumps
Visual
Mechanical
Each shift
Annual
Leaks, vibration
Bearing and seal
wear
F,ans
Visual
Mechanical
Each shift
Annual
Vibration
Bearings, balance
Instruments
Electromechanical
Electronic
Weekly
Monthly
Operability
Calibration
Process Equipment Visual
Visual, optical
Each shift
Annual
Conditions, oper-
abil ity
Refractory
condition
Safety Equipment Visual
Mechanical
Daily
Yearly
Seals intact
Inspect, recharge
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Page F-5
F-2b Specific Process Inspection Requirements
F-2b(5) Incinerator Inspection
The incinerator is normally operated seven days per week, 24
hours per day using 8-hour work shifts. The incinerator and
associated equipment are inspected visually once each shift for
leaks, noises, instrument readings, spills, fugitive emissions,
and signs of tampering. The inspection results are recorded for
evaluation by the foreman, who specifies corrective action if
necessary.
The emergency shutdown system and associated alarms are
tested once a week.
F-3 PREPAREDNESS AND PREVENTION REQUIREMENTS
UWC does not wish to request a waiver of the preparedness
and prevention requirements under 40 CFR §264, Subpart C.
F-3a Equipment Requirement
The UWC incinerator system site is provided with equipment
for internal and external communications, emergencies and fire
control.
Safety and fire protection programs have been implemented to
ensure that all activities are performed in a manner that pre-
vents personal injury and unauthorized discharges to the environ-
ment. Safety and fire protection training is conducted at
regular intervals for all operational personnel (described in
Section H of the UWC RCRA permit application).
F-3a(l) Internal Communications
Internal communications are provided by an internal telephone
system; hand-held, two-way radios in the possession of guards and
operators and; a public address/alarm system with a base station
in the shift supervisor's office. This system provides immediate
emergency voice and/or signal instructions to facility personnel.
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F-3a(2) External Communications
External communications are provided by a telephone system
connected to a local exchange. Emergency telephone numbers are
posted in the vicinity of each telephone. Back-up communications
also is provided by the hand-held, two-way radios carried by
guards and operators.
F-3a(3) Emergency Equipment
Fire control equipment is available on-site . Portable fire
extinguishers suitable for type A, B and C fires are the first
1 ine-of-de fense. Back-up fire control equipment can be provided
by the local fire department.
Spill control equipment is available on-site for use in re-
sponding to accidental spills.
An industrial hygiene program has been implemented requiring
personnel to wear protective equipment and clothing whenever
there is risk of accidental contact with hazardous materials. A
shower facility is provided for personal and equipment decontami-
nation for emergency as well as routine, daily use.
F-3a(4) Water for Fire Control
Water for fire control is available from 15 hydrants at the
site which are connected to the Treebrook municipal water system.
The hydrants are inspected annually by the Treebrook Volunteer
Fire Department to verify that adequate pressure and flow are
available.
F-3b Aisle Space Requirements
Adequate aisle space is provided to allow for unobstructed
movement of personnel, fire protection equipment and spill pre-
vention equipment to any area of the facility in the event of an
emergency.
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F-4 PREVENTIVE PROCEDURES, STRUCTURES AND EQUIPMENT
F-4a Loading/Unloading Operations
No waste loading/unloading operations are conducted at the
UWC facility.
F-4b Runo ff
All runoff from the hazardous waste management areas at UWC
is collected in sumps, blended with the wastes, and fired into
the incinerator. The waste storage area and the incinerator are
located on diked concrete pads and sloped to induce runoff to
flow to the sumps. Sump pumps are automatically activated by
the presence of 1-inch or more of liquid. Sump liquids are
pumped directly into the standby 5,000-gallon waste storage
tanks.
F-4c Water Supplies
No potential exists for contamination of water supplies with
hazardous waste or runoff during routine operations. Runoff is
controlled as stated above in F-4b-. All hazardous wastes are
retained in sealed tanks or pipes. In the event of an emergency
which threatens contamination of water supplies, Contingency
Plans specified in Section H of this application would be
instituted to prevent or control water supply contamination.
F-4d Equipment and Power Failure
Portable diesel-powered electric generators are kept on-site
and would be used to activate sump pumps, if necessary, during
power outages. The sump pumps are designed to connect quickly
to these standby power supplies.
Waste feed solenoid valves, which provide for automatic
cutoff of waste feed to the incinerator in the event of unaccept-
able process conditions, are of the normally-closed type and
will immediately stop waste flow to the kiln if power is lost.
As described in Section D-5, critical incinerator systems
and equipment are automatically monitored and their condition
displayed in the control room which is constantly staffed during
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incinerator operations. Equipment failures that could compromise
system performance either institute automatic control/corrective
procedures or alert the operator to the system problem. This,
coupled with the routine frequent inspections described in F-2,
serves to adequately mitigate the effects of virtually all
equipment failures.
F-4e Personnel Protective Equipment
Protective equipment available to plant personnel is
described in Section G-5 of the UWC Contingency Plan, as are the
procedures and conditions for utilizing that equipment. The
training which UWC personnel receive in the proper use of protec-
tive equipment is described in Section H of this application.
F-5 PREVENTION OF REACTION OF IGNITABLE, REACTIVE OR
INCOMPATIBLE WASTES
F-5a Precautions to Prevent Ignition or Reaction of Ignitable
or Reactive Wastes
On-site activities related to the operation of the incinera-
tion system will be limited to the handling/incineration of
ignitable (and toxic) wastes. No reactive or incompatible wastes
will be handled or incinerated at the site.
A safety program has been implemented to ensure that all
activities are performed in a manner that will prevent personal
injury, damage to equipment and unauthorized discharges to the
environment. Specific efforts have been made to minimize igni-
tion sources around ignitable or combustible waste materials.
Since the waste feed system is entirely closed, the risk of acci-
dental ignition is minimized. Smoking is not permitted in the
vicinity of the waste handling system; "NO SMOKING" signs are
posted in the area. Smoking and nonsmoking areas are established
and enforced. The system is grounded and no welding or other
spark-producing maintenance is done without first thoroughly
checking the area for potential leaks or the presence of flam-
mable vapors. Operating directives, safety directives and spill
prevention, control and collection and emergency contingency
plans have been developed to prevent situations which could
generate extreme heat, cause spontaneous ignition or cause elec-
trical, static or mechanical sparks. Special fire inspections
will be conducted at planned intervals during operations to
ensure that accidental ignition of the waste does not occur.
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F-5b General Precautions for Handling Ignitable or Reactive
Wastes and Mixing of Incompatible Waste
Reactive or incompatible wastes are not handled at the
facility site. General precautions for handling ignitable
wastes were discussed in F-5a.
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SECTION G
CONTINGENCY PLAN
The information contained herein is submitted in accordance
with the requirements for a Contingency Plan, as contained in
40 CFR § 122.25(a){7) and §264 Subpart D. A copy of the Contin-
gency Plan will be available at the Universal Widget Corporation,
along with strict operating directives, safety directives and
Spill Prevention and Control Counter measures (SPCC) plan.
G-l GENERAL INFORMATION
This Contingency Plan is for the Universal Widget Corpora-
tion, Inc. incinerator system, which is located at 2500 Indus-
trial Drive, Treebrook, New Jersey, 07180. UWC is owned by
Mr. Richard Headley who holds the offices of President and
Chairman of the Board.
The primary purpose of the incinerator unit is to provide a
facility for on-site destruction/detoxi fication of hazardous
substances that are generated on-site during the production and
refurbishment of widgets.
The UWC incineration system consists of a rotary kiln, a
secondary combustion chamber, and an air pollution control train
G-2 EMERGENCY COORDINATORS
If an emergency situation develops involving the UWC inciner-
ator, the discoverer will contact an Emergency Coordinator listed
in Table G-l. The primary Emergency Coordinator should be con-
tacted first and, if he is not available, the secondary Emergency
Coordinators should be called (in the order listed) until someone
is reached. The first of these individuals contacted becomes the
Emergency Coordinator.
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TABLE G-l. EMERGENCY COORDINATORS
Name
S. Hugh es
Respon-
sibility
Primary
Emergency
Coordinator
J. Henfield Secondary
Emergency
W. Machile
Coordinator
Secondary
Emergency
Coordinator
Home Address
925 West St.
Peacev ille,
New Jersey
87 Canter Ave.
Pea ceville,
New Jersey
Work
Phone Number
Home
Phone Number
(201) 998-7222 (201) 999-7999
Ext. 9989
(201) 998-7222 (201) 999-7314
Ext. 9987
2 5 Beston Road (201) 998-7222 (201) 999-712 3
Peaceville,
New Jersey
Ext. 9982
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The decision to implement the Contingency Plan depends upon
whether or not an imminent or actual incident could threaten
human health or the environment. It is the duty of the Emergency
Coordinator to determine if the Contingency Plan is to be imple-
mented and to direct and coordinate all activities undertaken if
the Plan is implemented. The Emergency Coordinator is authorized
to commit the resources of UWC, as needed, in implementing the
Contingency Plan.
G-3 CRITERIA FOR TYPE AND SEVERITY OF INCIDENTS LEADING TO
IMPLEMENTATION OF CONTINGENCY PLAN
The Contingency Plan will be implemented in any of the
following situations:
1. Fire and/or Explosion
a. A fire causes, or could cause, the release
of toxic fumes.
b. The fire spreads and could possibly ignite
nearby fuel oil or other liquid wastes, or
could cause heat-induced explosions.
c. The fire could possibly spread to off-site
areas.
d. Use of water or water and chemical fire
suppressant could result in uncontained
contaminated runoff.
e. An imminent danger exists that an explosion
could occur, causing a safety or health
hazard .
f. An imminent danger exists that an explosion
could ignite other hazardous waste at the
facility.
g. An imminent danger exists that an explosion
could result in release of toxic material.
An explosion has occurred.
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2. Spills or Material Release
a. The spill could result in release of
flammable liquids or vapors, thus causing a
fire or gas explosion hazard.
b. The spill could cause the release of toxic
vapors or fumes into the atmosphere in
concentrations higher than the Threshhold
Limit Values recommended by the American
Conference of Governmental Industrial
Hygienis ts.
c. The spill can be contained on-site, but a
potential exists for ground water or surface
water contamination.
d. The spill cannot be contained on-site,
resulting in a potential for off-site soil
contamination and/or ground or surface
water pollution.
G-4 EMERGENCY RESPONSE PROCEDURES
G-4a Noti fication
The first person becoming aware of an emergency shall imme-
diately notify the Emergency Coordinator and act as the Emergency
Coordinator until the Emergency Coordinator arrives on-site.
The Emergency Coordinator will assess the possible hazard to
human health or the environment that may result from the release,
fire, or explosion.
If the Emergency Coordinator determines that the facility
has had, or may have, an incident such as a spill, fire, or
explosion which could threaten human health or the environment,
he must report his findings as follows:
1. Alert site personnel by activating the public
address sirens or air horns. Short blasts
followed by pauses. The public address system
(located in the shift supervisor's office) or
the portable bullhorn is to be used to direct
personnel after alert is sounded.
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TABLE G-2. EMERGENCY CONTACTS
Emergency
In jury
Organization/Agency
Jersey Hospital
County Hospital
New Jersey Medical College
Poison Control Center
Emergency Number
911
Ambul: 201-555-1111
Infor: 201-555-1110
Infor: 201-565-2222
Ambul: 201-565-1222
Infor: 201-969-8000
Hotline: 201-911-9111
Fire/Explos ion
Jersey County Fire Dept .
Clearstream City Fire Dept.
USEPA-Region II Environ-
mental Response Branch
New Jersey Department of
Environmental Protection:
Business hours:
All other times:
Clearstream City Police Dept
A.U. Clean-up Inc.
888-5522
777-2291
201-548-8730
24 hours
609-292-5660
609-292-7172
777-2000
201-485-9378
Hazardous Material Jersey County Fire Dept.
Spill or Release
Clearstream City Fire Dept.
USEPA-Region II Environ-
mental Response Branch
888-5522
777-2291
201-548-8730
24 hours
(continued)
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TABLE G- 2. EMERGENCY CONTACTS (Continued)
Emergency
Organ ization/Agency
Hazardous Material New Jersey Department of
Spill or Release Environmental Protection;
(cont'd.) Business hours:
All other times:
A.U. Clean-up Inc.
Emergency Number
609-292-5660
609-292-7172
201-485-9378
If Spill Reaches
Navigable Water
National Response Center
U.S. Coast Guard
USEPA-Region II Environ-
mental Response Branch
New Jersey Department of
Environmental Protection:
Business hours:
All other times:
800-424-8802
24 hours
201-800-9000
201-548-8730
24 hours
60 9-292-5660
609-292-7172
Natural Disaster
Washington County Jersey
Emergency Management Agency
Clearstream City Police Dept
A.U. Clean-up Inc.
USEPA-Region II Environ-
mental Response Branch
New Jersey Department of
Environmental Protection:
Business hours
All other times
911 or 724-9999
777-2000
201-485-9378
201-548-8730
24 hours
609-292-5660
609-292-7172
Potential Flood
Army Corps of Engineers
72 5-9000
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2. If his assessment indicates that evacuation of
the work area may be advisable, he must imme-
diately sound the evacuation alert (see
Section G-7), stop the operation, and notify
appropriate local authorities (Table G-2). He
must be available to help appropriate officials
decide whether adjacent areas should be
evacuated.
3. Immediately notify the National Response Center
(1-800-424-8802), in the greater metropolitan
area of Washington, D.C. (202) 426-2675, and
other appropriate agencies listed in Table G-2.
The report must include:
1. Name and telephone number of reporter;
2. Name and address of facility;
3. Time and type of incident (e.g., release,
fire);
4. Name and quantity of materials or material
involved to extent known;
5. The extent of injuries, if any; and
6. The possible hazards to human health, or
the environment, and clean-up procedures.
G-4b Identification of Hazardous Materials
Safety Fact Sheets containing current data characterizing
the wastes stored and treated at UWC are kept by all Emergency
Coordinators in their offices, in the Shift Supervisor's office,
and in the plant Safety Office.
These Safety Fact Sheets contain pertinent data on the waste
chemicals at the site including:
• Identification of chemical components in
each waste stream;
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• Identification of wastes' "hazardous charac-
teristics (e.g., toxicity, reactivity, and
ignitability) ;
• Important chemical and physical properties
for which data are available, such as vapor
pressure, pH, and solubility in water;
• Fire control procedures (e.g., water or
chemical foam); and
• Appropriate procedures to counteract human
exposure (e.g., thorough washing with soap
and water in the event of dermal contact).
G-4c Hazard Assessment
The Emergency Coordinator will assess possible hazards to
human health or the environment that may result from the release,
fire, or explosion. The Emergency Coordinator will assess the
hazards posed by an incident through the following steps, as
appropr iate:
• First, identifying the wastes involved in
the incident;
• Second, consulting the appropriate Safety
Fact Sheets to determine the potential
effects of exposure/release, and appro-
priate safety precautions; and
• Third, identifying exposure and/or release
pathways and the quantities of wastes
involved.
This assessment will consider both the direct and indirect
effects of the release, fire, or explosion (e.g., the effects of
any toxic, irritating, or asphyxiating gases that are generated
or the effects of any hazardous surface water runoff from water
or chemical agents used to control fire and heat-induced
explos ions).
Based on this assessment, the Emergency Coordinator will
determine what risk is posed to plant workers and neighboring
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Pa ge G- 9
populations. If the incident cannot be controlled by plant
personnel without incurring undue risk, the Emergency Coordinator
will order the evacuation of all workers at risk and notify
appropriate other parties listed in Table G-2 of the situation
and the assistance required. If the Emergency Coordinator deter-
mines that any persons outside of the UWC facility are at risk
as a result of the incident, he will contact the appropriate
agencies and departments listed in Table G-2 and advise them of
the risk and the need or potential need to institute off-site
evacuation procedures.
G-4d Control Procedures
Potential accidents fall under two general classifications:
(1) fire and/or explosions and (2) spills or air material
release. The following sequence of events constitute the
specific responses and control procedures to be taken in the
event of a fire, explosion, or release of hazardous waste to
air, land or water.
The initial response to any emergency will be to protect
human health and safety, and then the environment. Secondary
response to the emergency will be identification, containment,
treatment, and disposal assessment.
Fire and/or Explosion
If fire or explosion appear imminent, or either have
occurred, all activity related to the incinerator unit will be
ceased.
The Emergency Coordinator will assess the severity of the
situation, and decide whether the emergency event is or is not
readily controllable with existing portable fire extinguishers
or site equipment and materials at hand. Firefighting will not
be done if the risk to UWC firefighters appears high.
The Emergency Coordinator will coordinate firefighting
activities until the fire department arrives. The Jersey County
and Clearstream City Fire Departments will be called in all
situations in which fires and/or explosions have occurred.
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If the situation appears uncontrollable, and poses a direct
threat to human life, a warning will be sounded to all personnel
to secure their emergency equipment and immediately evacuate the
incinerator area.
If the chances of an impending explosion are high, the entire
facility within a 2000-ft radius of the incinerator, or the fire
source, will be evacuated.
The Emergency Coordinator will alert all personnel when all
danger has passed, as determined by fire department.
All equipment used in the emergency will be immediately
cleaned and refurbished for use in the event of any future
emergency.
Spill or Material Release
If a hazardous waste spill or material release or process
upset resulting in probable vapor release is noted, the informa-
tion will be immediately relayed to the Emergency Coordinator.
The Emergency Coordinator will assess the magnitude and
potential seriousness of the spill or release by reviewing the
following information:
1. Safety Fact Sheets for the material spilled
or released
2. Source of the release or spillage of
hazardous material
3. An estimate of the quantity released and
the rate at which it is being released
4. The direction in which the spill or air
release is heading
5. Personnel who may be or may have been in
contact with material, or air release, and
possible injury or sickness as a result
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6. Potential for fire and/or explosion result-
ing from the situation
7. Estimate of area under influence of release.
If the accident is determined to lie within the UWC team's
emergency response capabilities, the Emergency Coordinator will
implement the necessary remedial action.
If the accident is beyond the capabilities of the team, the
Emergency Coordinator will notify the commercial spill clean-up
contractor identified in Table G-2 and the appropriate
governmental bodies.
In the event of an emergency spill or release, all personnel
not involved with emergency response activity will be evacuated
from the immediate area.
The area will be roped or otherwise blocked off. All waste
feed systems to the incinerator, and the incinerator unit will
have emergency shutdown procedures imposed.
The following evacuation guidance to allow for safe emergency
response activities will be employed:
• Large tank or pipeline rupture - initial
isolation of 100 feet in all directions.
• Small spills from incinerator, tanks,
containers or pipelines - evacuation of at
least 50 feet in all directions.
• Volatile materials spill, toxic vapor
cloud, incinerator large scale rupture -
down wind clearance of an area of at least
500 feet wide and 1,000 feet long.
G-4e Prevention of Recurrence or Spread of Fires, Explosions or
Releases
The UWC incinerator unit contains built-in standard operating
safeguards to control the incinerator during an emergency situa-
tion to ensure that fires, explosions, or releases do not recur
or spread to other hazardous wastes at the facility.
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The incinerator feed system is interlocked with the inciner-
ator safety controls so that the fuel and waste feed is automati-
cally stopped whenever a potentially hazardous situation occurs.
The interlock system must be manually reset after an upset condi-
tion to ensure proper incineration operation prior to addition
o f was te feed.
If the incinerator is shut down due to an emergency, the
waste feed and auxiliary fuel burners will be stopped and emer-
gency water will be sprayed into the quench elbow. If pressure
builds up in the system, an emergency vent stack will open to
relieve the pressure.
Actions to prevent the recurrence or spread of fires, explo-
sions or releases include stopping processes and operations,
collecting and containing released waste, and recovering or iso-
lating containers. The UWC Incinerator Training Manual addresses
the specific actions to be taken in an emergency. In addition,
if the incinerator stops in response to an emergency, the emer-
gency coordinator will monitor valves, pipes, and other equipment
for leaks, pressure build up, gas generation or ruptures. Tanks
containing hazardous wastes and fuel oil exposed to any heat as
a result of a fire or explosion will be cooled with water spray.
If ignitable waste is involved, all ignition sources will be
removed. Spark and explosion proof equipment and clothing will
be used in the containment and clean-up areas .
All other surrounding materials that could be especially
reactive with materials in the waste will be removed from the
area.
Absorbent pads, booms, earth, sandbags, sand, and other
inert materials to contain, divert and clean-up the spill will
be used if it has not been contained by a dike or sump. Most
spills contained within the dike or sump will be pumped back
into the appropriate storage tank or into drums.
If wastes reach a storm sewer, an attempt will be made to
try and dam the outfall to the Queen River by using sand, earth,
or sandbags. If this occurs, wastes in the storm sewer will be
diluted with large quantities of water. This material will be
pumped out into a temporary holding tank or drums as soon as
possible. If a spill enters the river or has entered a storm
drain, absorbent booms and sweeps around the outfall will be
used to contain and absorb water-insoluble organics.
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All contaminated containment and clean-up materials will be
placed in drums for proper disposal. All recovered liquid wastes
and contaminated soil will be placed in drums for removal to an
approved disposal site.
G-4f Storage and Treatment of Released Material
Immediately after an emergency, the emergency coordinator
will make arrangements for treatment, storage, or disposal of
recovered wastes, contaminated soil, surface water, or any other
contaminated materials. Recovered wastes will be incinerated
only if their characteristics are such that they are still
permitted for incineration under the incinerator permit issued
to UWC.
If the bases in the vicinity of the storage area or the
incinerator staging area are involved in the emergency and have
been contaminated, the clean-up crew will use a solvent on the
surface of the base and rinse it with hot soapy water. This pro-
cedure will be repeated until any residues are gone. Rinsings
will be collected and disposed of as hazardous wastes.
G-4h Post-Emergency Equipment Maintenance
After an emergency event, all emergency equipment listed in
section G-5 will be cleaned so that it is fit for use or it will
be replaced. Before operations are resumed, an inspection of
all safety equipment will be conducted as discussed in section
F-2. The Regional Administrator, state, and/or local authori-
ties, as appropriate, will be notified that post-emergency equip-
ment maintenance has been performed and operations will be
resumed.
G-5 EMERGENCY EQUIPMENT
In case of a fire, release of hazardous waste, or explosion,
the following list of firefighting, containment, and emergency
equipment is available at the incinerator staging area:
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1. Fire extinguishers - six dry chemical type A, B,
and C, 5 lb and 2.5 lb. Type A is capable of
extinguishing fires involving ordinary combust-
ible materials such as woods, cloth, paper,
rubber, and many plastics; Type B is capable of
extinguishing fires involving flammable liquids,
oils, greases, tars, oil base paints, lacquers,
and flammable gases; and Type C is capable of
extinguishing fires involving energized elec-
trical equipment. All extinguishers comply
with National Fire Code standards for portable
fire extinguishers.
2. Fire hydrants as indicated on plot plan (Figure
G-l). All hydrants will deliver approximately
500 gallons per minute of waste. Ten (10)
100-foot sections of fire hose and four (4)
spray nozzles are stored in the warehouse and
can be readily accessed, without a key, at any
time .
3. Spill or containment equipment located on the
site includes:
a. Foam dike packs - to contain contents of
ruptured tank or to block storm drain, etc.
b. Sawdust - this material stored in a spill
control equipment locker is to be used to
contain aqueous spills.
c. Oil spill absorbent pads - this equipment
stored in the spill control equipment
locker is to be used to absorb any oily
spilled material.
d. Shovels - wooden handle, steel type. This
equipment, also stored in a spill control
equipment locker, is to be used in the
physical containment of any released
hazardous constituents.
e. Vermiculite - Also stored in spill control
equipment locker to be used to absorb
spilled hazardous organic constituents.
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4
<
SCC
FE#>PCE
f£»sews
EWS
/
i
FH - FIRE HYDRANT
FE - FIRE EXTINGUISHER
FA - FIRST AID EQUIPMENT
EWS - EYE WASH AND SHOWER
SCC - SPILL CONTROL AND CLEANUP EQUIPMENT
PCE - PROTECTIVE CLOTHING AND EQUIPMENT
FIGURE G-l. LOCATION OF FIXED EMERGENCY
RESPONSE EQUIPMENT
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Page G-16
f. Wrenches and tools for tightening fittings
and valves . These are stored in the spill
control equipment locker.
g. Sandbags to dam the storm drain outfall to
the Queen River.
4. Emergency alarm systems.
a. Portable air horn. To be used to alert site
personnel to a hazardous situation.
b. Plant-wide public address system accessible
in the plant manager's office.
c. Portable public address system. To alert
site personnel to evacuation route and/or
ins tructions.
d. Walk ie talkies.
5. First aid supplies.
a. Bandage materials
band aids
— gauze pads and rolls
adhesive tape
butterfly bandages
b. Antibacterial ointments
c. Splints
d. Aspirin
e. Emetic - Syrup of Ipecac
f. Local and topical anesthetics
g. Eyewash bottle and solution
6. Emergency eyewash fountains and showers are
located at the incinerator staging area and the
waste storage area. Each unit consists of a
drench showerhead with "panic bar" operated
frost-proof valve and an eyewash with a dirt
cover and "panic bar" operated frost-proof
valve. A sign reading "EMERGENCY SHOWER AND
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EYEWASH FOUNTAIN" is posted at each unit. A
hose station used for washing isolated areas of
the body (i.e., feet, hand, etc.) is also
located near the eyewash/shower station at the
border of the incinerator staging area.
7. Protective Clothing and Equipment
a. Plastic aprons and gauntlets
b. Rubber and Neoprene rubber boots
c. Short and long Neoprene rubber gloves
d. Rain suits
e. Chemical-resistant suits (Tyvek)
f. Polyethylene gloves
g. Hard hats, steel-toed boots
h. Face shields and protective eyeglasses
i. Disposable respirators
j. Chemical cartridge respirators with car-
tridges for organic vapors and acid gases;
half- and full-face types
k. Chest-mounted gas mask cannistersr
self-contained breathing apparatus (SCBA)
operated in pressure-demand mode
8. Emergency clean-up equipment.
All of the equipment, material, and personnel
will be made available during an emergency
situation. Required resources that may not be
available at UWC will be obtained immediately
from local commercial sources. A detailed
listing of clean-up equipment kept on-site is
listed in Table G-3.
See Figure G-l for the location of fixed emergency equipment.
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TABLE G-3. MATERIALS AND EQUIPMENT FOR SPILL CONTAINMENT AND CLEAN-UP
Ma ter ial(s)/equipment
Quantity
Substances contained/
absorbed/cleaned up
Notes
Standard industrial
absorbents (Sorb-All,
Vermiculite, etc.)
A drum is placed in
all plant areas
where small spills
are suspect.
For small spills of oil,
solvents, aqueous mate-
rials. Do not use for
acids or caustics unless
first neutralized.
Each drum is accompanied with
broom (or shovel) and dustpan.
Sandbags 600 - 1,000 Sand is unreactive with Keep in readily accessible
most any chemical except area(s) near most concentrated
hydrofluoric acid. area(s) of tanks or drums.
Sand
50 - 100 yd"
Sand is unreactive with
most any chemical except
hydrofluoric acid.
Use primarily for containment
or large spills. Containment
and clean-up of small spills.
Also, kept in barrels in areas
where small spills may occur
more frequently. Keep covered
if outside.
Absorbent boom, 2
weighted or with
curtain or skirt
In water, most insoluble
or slightly soluble organ-
ics. Most materials on
land. Do not use for
acids.
Employ one boom around out-fall
discharge on permanent basis
and one for backup.
(con t inued)
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TABLE G-3. (continued)
Substances contained/
Mater ial(s)/equipment Quantity absorbed/cleaned up Notes
Absorbent pads
Carton (100 pads-
Conwed)
In water, most insoluble
or slightly soluble or-
ganics. Most materials
on land. Do not use for
acids.
Will float on water so are most
helpful in cleaning up mate-
rials contained within the boom
boundaries or in diked areas
where a chemical sheen has
formed on water collected with-
in. Also, place around equip-
ment or in areas where leakage
or spillage occurs frequently
(i.e., pumps, loading/unloading
areas).
Straw
15
20 bales
Petroleum, distillates,
oil, organic solvents.
Do not use for acids or
caus ti cs.
Can be used for diking and ab-
sorption for land spills. If
booms become saturated, can be
tied together and used to con-
tain and absorb water spills.
Since they sink party below
water surface, they are useful
for substances slightly heavier
than water.
Submersible pump 4
See manufacturers (Gould,
Flygt, Peabody) for
specifications on mate-
rial-handling capabili-
ties.
Can be used to remove diked
liquids, etc.
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G-6 COORDINATION AGREEMENTS
UWC has made the following arrangements to assist in response
to emergency situations.
1. An agreement has been made with a regional
clean-up contractor to provide a tank truck
with a suction-pump within one hour on a
24-hour availability basis to UWC at the
Treebrook site .
2. Copies of the contingency plan are given to
the local police and fire departments, the
hospital, and the state and local Emergency
Response Teams. These agencies were asked
to review and comment on the plan and have
detailed the actions they will take in re-
sponse to any emergency. UWC has reviewed
their proposed response plans and all par-
ties are in agreement.
The following organizations have been sent copies of the
contingency plan and have responded as indicated above:
Dr. Margo Hemings
Jersey Hospital
888 State Avenue
Peaceville, NJ 07109
Dr. Sam Bernard
County Hospital
2777 Wilma Drive
Salena, NJ 08156
Mr. Jack Simpsen
Jersey County Fire Department
7777 Main Street
Jubilee, NJ 07018
Captain Jeff Simons
Clearstream City Police Department
8888 Main Street
Jubilee, NJ 07018
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Mr. Bill Williamson
Chief, Disaster Coordination Section
Washington County Jersey Emergency
Management Agency
8900 Sunnydale Place
Greenville, NJ 08120
G-7 EVACUATION PLAN
The Emergency Coordinator, when deeming that the site should
be evacuated, will either sound the public address siren or blow
the emergency air horn using three long blasts to signal the
evacuation by the primary route. However, if the secondary
evacuation route should be used, the siren or air horn will be
activated five times in long blasts. After all personnel have
left the site, the Coordinator or his designee shall make a head
count to insure that all personnel have vacated the site. Refer
to Figure G-2 for primary and secondary evacuation routes.
G-8 REQUIRED REPORTS
As required, any emergency event (e.g., fire, explosion,
etc.) that requires implementing the Contingency Plan will be
reported in writing within 15 days to the EPA Regional Admini-
strator. A reporting form for emergency events is shown in
Figure G-3.
In addition to these reporting requirements for state and
Federal authorities, UWC also has internal reporting require-
ments. The following incidents require that an incident report
be completed and returned to the safety director within 5
working days and made part of the operating record:
1. All fires
2. Rupture disc releases
3. Unusual gas or vapor releases
4. Chemical spills of more than 10 gallons (or
smaller volumes if highly toxic materials
are involved)
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SECTION
PROW*"
MUM*"
PRODUCTION UNES
TO ««"
(WHO
UN4N DIVERS M*
CANAL
ECU ON
STORAGE
TM1S
WJIfAll
J
COMBINED
SEUtR STSTEK
RALLY
SECTION 1 | SECTION
SCALE
MAP DATE: 9/10/81
FIGURE G-2. EVACUATION RALLY POINTS
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FIGURE G-3. REPORTING FORM FOR EMERGENCY EVENTS
Name, address, and phone number of owner or operator
Name, address, and phone number of facility
Date, time, and type of incident (e.g., fire , explos ion, etc. )
Name and quantity of mater ial(s) involved
Extent of injuries (if any)
Assessment of actual or potential hazards to human health or the
environment (if applicable)
Estimated quantity and disposition of material recovered from
the incident
Send to: (Name)
U.S. EPA, Region II
Regional Administrator (EPA)
26 Federal Plaza
New York, NY 10278
(Name)
Ch ief
Environmental Emergency Branch
U.S. EPA, Region II
26 Federal Plaza
New York, NY 10278
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5. All injuries except minor cuts and bruises
(all burns and chemical irritations)
6. All equipment damage due to malfunction or
operating error
7. All "near misses" of the above variety that
could have had serious consequences
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SECTION H
PERSONNEL TRAINING
The information contained in this section outlines the
personnel training program for UWC's incinerator unit in
accordance with the requirements of 40 CFR § § 122. 25(a ) (12) and
264.16.
H-l OUTLINE OF TRAINING PROGRAM
The Project Engineer, who is familiar with the incineration
system and with the overall plant facility, conducts all training
sessions. The sessions include safety, spill prevention and
control, and operation procedures. Operating directives, safety
directives, and the SPCC and Contingency Plans are reviewed by
all operating personnel. Files of these documents are always
available to operating personnel.
H-la Job Titles and Duties
The principal positions for field operation of the UWC Incin-
eration System consist of the following job titles: Project
Engineer, Foreman, and Operators. The following covers the
detailed description of the duties, responsibilities and other
qualifications of the selected individuals for each position.
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Position Title: Project Engineer
Name of Employee: Steven A. Hughes
Position Responsibilities and Duties:
• Emergency Coordinator for all hazardous waste
incineration activities.
• Consults with foreman on questions involving emer-
gency action.
• Responsible for overall supervision of incinerator
components and control systems.
• Resolves problems involving permits and licenses
from local, state, and Federal regulatory agencies.
• Conducts training of personnel in the proper
handling of hazardous wastes and in the use of the
incinerator.
• Reports to plant manager.
Experience and Qualifications:
• B.S. degree in Chemical Engineering. M.S. degree
in Industrial Hygiene.
• Fourteen years experience in industrial pollution
con tr ol .
• Five years experience in incineration of hazardous
was tes.
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Position Title: Foreman
Name of Employee: James B. Hendfield
Position Responsibilities and Duties:
• Supervises operators and reviews their performance.
• Oversees day-to-day operation and maintenance of the
incinerator components, and operational integrity of
the unit.
• Maintains facility compliance with RCRA regulations
and other permits.
• Maintains operating logs, monitoring records,
maintenance records, inspection records, personnel
training records, and all other required records.
• Notifies Project Engineer of problems with the
system, schedules all maintenance and repairs to
structures and equipment for the incineration unit.
• Trains operators in operational procedures, emer-
gency actions, and responds to emergencies
involving the UWC incinerator.
• Reports to Project Engineer.
Experience and Qualifications:
• Associate degree in mechanical engineering.
• Three years experience in plant operation.
• One year experience in hazardous waste incinerator
operation.
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Position Title: Operator
Names of Employees: Harrey Smith, Mary Hartman, Jim Jones,
Stephan Spielberg, Robert Plant,
Roscoe Col train, Chris Nicols
Position Responsibilities and Duties:
• Reports to foreman.
• Operates incinerator and ancillary systems.
• Monitors and logs operating conditions of inciner-
ator and ancillary equipment.
• Inspects incinerator and surrounding area for evi-
dence of leaks and spills, or potential problems.
• Inspects emergency equipment on a regular basis.
• Notifies foreman of incinerator operation problems.
• Carries out emergency response activities under
direction of Emergency Coordinator.
• Takes emergency actions or own authority in
accordance with established procedures.
Experience and Qualifications:
• High school education.
• One to three years experience in physical plant
operation, inspections, and quality assurance.
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H-lb Training Content, Frequency and Techniques
The program developed at UWC for training employees in the
safe incineration of hazardous wastes has been organized into a
Training Manual. Provisions are made for updating or revising
the text as necessary to ensure compliance with the terms of the
RCRA permit. Each employee has his or her own copy of the
manual. An outline of the training manual is presented in
Figure H-l. This training manual is kept on file at the inciner-
ator control room and is available to regulatory officials for
review. All operating personnel will complete two days of
classroom training. The initial training is reviewed annually.
During the training program, employees are instructed on the
following major topics: (1) the hazardous nature of chemicals
and chemical wastes in general, (2) the purpose of RCRA and im-
portance of maintaining compliance with RCRA regulations, (3) the
hazardous nature of the wastes being incinerated, (4) proper
handling and storage procedures for wastes, (5) emergency proce-
dures and the contingency plan related to the incineration
process, and (6) the operation of the incinerator and ancillary
equipment.
The manual is used as the basis for training UWC personnel
in proper operating procedures, and incineration processes and
equipment.
Other specific training topics include:
• Using appropriate personnel protective
equipment;
• Handling hazardous materials;
• System operating conditions;
• System safety and monitoring interlocks;
• Spill prevention and control.
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FIGURE H-l. OUTLINE OF UWC HAZARDOUS
WASTE INCINERATION TRAINING MANUAL
Preface
1.0 Introduction
1.1 Chemical hazards
1.2 The Resource Conservation and Recovery Act - RCRA
2.0 Incinerator Process Description
2.1 Waste description
2.2 Description of incinerator unit
2.3 Air pollution control facilities description
2.4 Key terms of the permit
2.5 Normal/routine operations
2.6 Waste analysis
2.7 Auxiliary fuel system
2.8 Recordkeeping requirements (carbon monoxide in
stack gas, waste feed rate, kiln temperature,
secondary chember temperature, excess oxygen)
2.9 Security
2.10 Inspections
3.0 Emergency Procedures and Contingency Plans
3.1 Emergency Coordinator
3.2 Emergency procedures
3.3 Emergency communications/phone numbers and alarms
3.4 Location, maintenance, inspections, use, and repair
and replacing facility emergency and monitoring
equipment
3.5 Procedures for waste feed cut-off systems
3.6 Procedures for auxiliary fuel cut-off systems
3.7 Spill control and response to groundwater
contamination incidents
3.8 Fires and explosions
3.9 Power interruption or failure
3.10 Tornadoes, hurricanes, and severe storms
Appendix A RCRA Regulations for Hazardous Waste Management
Appendix B Summary of Conditions Specific in UWC's RCRA Permit
Appendix C Training Programs in Hazardous Waste Management
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The training program is tiered in some areas to provide
training to personnel at levels that are relevant to their posi-
tions within the incinerator operation. On-the-job training is
used to provide the additional specialized training. (See
discussion in H-ld.)
For key personnel, UWC plans to supplement this training
with attendance at one or more technical seminars or training
programs on hazardous materials. A list of such seminars or
programs is included in the Appendix of the training manual.
A brief description of each section of the training manual
follows:
Section 1 - Introduction
This section of the manual introduces UWC employees to the
general classes and characteristics of chemicals and chemical
wastes that can be hazardous to health and property. In this
context, the terms toxicity, reactivity, corrosivity, and ignita-
bility are defined. It is UWC's policy that each employee
handling chemical substances respect them and be aware of these
potential hazards. The company's policy on the use of protective
clothing and safety equipment to prevent accidental worker expo-
sures and releases to the environment of hazardous chemicals and
wastes is discussed.
The authority for regulating hazardous wastes under RCRA also
is discussed. The regulatory framework for classifying hazardous
wastes, setting operational standards, and permitting procedures
and achieving compliance is explored. The RCRA permit for UWC
(once it is received) will also be studied to be sure that each
employee is familiar with its terms.
Section 2 - Incinerator Process Description
This section focuses on the types of hazardous wastes that
are incinerated by the incinerator, and procedures for main-
taining compliance with the RCRA permit (e.g., waste analysis,
recordkeeping, inspections, and security). A system diagram
showing the dimensions, capacity, and relative position of each
incinerator component is included.
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Training for normal or routine operating conditions includes
the following topics:
• Proper operation and maintenance of the
incinerator unit
• Scheduled inspections
9 Purpose and use of security and
communications systems
• Monitoring requirements for tracking and
recording the operation of the incinerator
uni t
• Recordkeeping requirements and procedures
Section 3 - Emergency and Contingency Plan
The third section of the training manual provides detailed
instruction on steps to be taken in the event of an emergency
such as a waste spill or fire, power outage, or damage from wind
and storms. The emergency coordinator is clearly identified, as
are emergency phone numbers and directions for locating and using
incinerator unit emergency equipment, alarms, and communications.
Contingency plans are also detailed; these plans are subject to
modification on a site-by-site basis.
This manual is used in classroom training for both introduc-
tory training and annual review. All personnel involved with
hazardous waste are required to complete 16 hours of classroom
training in addition to 6 weeks on-the-job training. Also per-
sonnel receive an 8-hour classroom review training session once
a year. This is supplemented with attendance by the project
engineer and foreman at seminars and conferences involving
hazardous waste management.
H-lc Training Director
The personnel training program is directed by Mr. Steven A.
Hughes, the Project Engineer. Mr. Hughes has been with UWC for
10 years. He received a B.S. degree in Chemical Engineering
from Princeton University, and his M.S. degree in Industrial
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Page H-9
Hygiene from John Hopkins University. He has been trained in
all aspects of Hazardous Waste Management and attended various
seminars on this subject. Records of his previous and ongoing
training are kept on file at the personnel office.
H-ld Relevance of Training to Job Position
All personnel receive the training outlined in Section H-lb.
In addition, on-the-job training is used to supplement this
training for two groups of employees. On-the-job training for
the operators consists of detailed training on: 1) proper safe
incineration operation procedures, and 2) procedures contained
in the contingency plan.
On-the-job training for the Foremen includes review of the
RCRA reporting, recordkeeping and permit requirements.
All on-the-job training is conducted by the training
director.
H-le Training for Emergency Response
This training program is designed to ensure that personnel
not only handle hazardous waste incineration in a safe manner
but also properly respond to emergency situations. The program
trains incinerator hazardous waste handling/management personnel
to maintain compliance under both normal operating conditions
and emergency conditions.
Training elements addressing nonroutine and emergency situa-
tions (unscheduled incinerator shutdowns and start-ups related
to storms, power outages, fires, explosions, spills) include:
• Procedures for locating, using, inspecting,
repairing, and replacing incinerator
emergency and monitoring equipment
• Key procedures for automatic waste feed
cut-off systems
• Emergency communication procedures and alarm
sys terns
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• Response to fires or explosions
• Response to ground water contamination
incidents and procedures for containing,
controlling, and mitigating spills
• Shutdown of operations and power failure
procedures
• Procedures for evacuation
H- 2 IMPLEMENTATION OF TRAINING PROGRAM
All existing personnel have gone through the training program
as outlined in Section H-l. All new operating personnel will be
required to go through the training program within six months
after the date of employment or assignment to the project, or to
a new position within the project. Employees will not work in
unsupervised positions until they have completed the training
outlined in H-l.
At a minimum, training reviews will be conducted at a fre-
quency not less than once a year. The subjects of these reviews
will include:
1) The status of incinerator operating conditions and
procedures, noting any areas where there are problems or poten-
tial for problems. Employees participate in developing effective
solutions.
2) The requirements contained in the RCRA permit,
noting any changes that have occurred during the past year.
Areas where maintenance of compliance is a problem are identified
and discussed, and effective solutions are sought.
3) Incidents that have occurred in the past year that
warranted use of contingency plans and/or emergency action.
This review focuses on the cause of the incident and identifi-
cation of steps to be taken to prevent or to ensure better
handling of such events in the future.
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Records documenting the job title for each position, job
descriptions, names of employees, and completed training programs
(both introductory and review) are kept in the personnel office
at the UWC incinerator facility. These records will be kept
until closure of the incinerator for current employees and for 3
years from the date of the individual employee's termination for
former employees.
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SECTION I
CLOSURE PLAN AND FINANCIAL REQUIREMENTS
1-1 CLOSURE PLAN
This Section is submitted in accordance with the requirements
of 40 CFR § 122. 25(a) (13) and §§264.111 through 115. This plan
identifies all steps that will be necessary to partially close
the Universal Widget Corporation (UWC) incinerator unit at any
point during its intended operating life and to completely close
the incinerator at the end of its intended operating life. The
plan also addresses the reasons why partial closure will not
occur. A post-closure plan is not required because this is not
a disposal facility and no hazardous wastes or residues will
remain at closure.
UWC will maintain on-site copies of the approved closure
plan and all revisions to the plan until the certification of
closure completeness has been submitted and accepted by the EPA
Regional Administrator. The UWC incinerator owner will notify
the Regional Administrator at least 180 days prior to the date
expected to begin final closure. Upon completion of closure,
the UWC owner will submit to the Regional Administrator a
certification by both the UWC owner and by a local independent
registered professional engineer that the UWC incinerator
operation has been closed in accordance with the specifications
in the approved closure plan.
I-la Closure Performance Standard
This closure plan for the incinerator is designed to conform
to the closure performance standard. Specifically, the plan
insures that the UWC incinerator will be closed so as to minimize
threats to human health and the environment, and eliminate post-
closure escape of hazardous waste, hazardous waste constituents,
leachate, contaminated runoff, or waste decomposition products
to the ground or surface waters or to the atmosphere. The
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following discussion describes in detail efforts to be made by
UWC to satisfy the closure performance standard.
I-lb Partial Closure and Final Closure Activities
Partial closure is not planned during the scheduled activity
of the UWC incinerator. Final closure of the UWC site is not
planned until the year 2 010.
I-lc Maximum Waste Inventory
The inventory of wastes stored at the UWC incinerator
facility will be limited to a maximum of 10,000 gallons (two
5/000 gallon tanks).
I-Id Inventory Disposal; Removal or Decontamination of Equipment
Final closure will be initiated at the start of the receipt
of the final batch of hazardous wastes to be processed in the
UWC incineration system. Closure will be completed within 180
days of this occurrence.
Clean-up and decontamination shall be performed under a shift
supervisor, with a Lead Engineer and at least two engineering
technicians present. Whenever the clean-up/decontamination per-
sonnel are handling materials containing toxics or irritants,
self-contained breathing apparatus will be worn. This is true
for collecting samples, disconnecting lines used to pipe
material, and cleaning spills. There will be a minimum of two
people performing any task that requires the use of self-
contained breathing apparatus.
Neoprene gloves and impermeable protective clothing will be
worn at all times during the clean-up decontamination process.
Prior to leaving the decontamination area, decontamination
of personnel protective clothing well be conducted by removing
all bulk material from the boots and spraying, washing and scrub-
bing with detergent solution all outside protective clothing
Materials. Personnel undergoing decontamination will stand in
drip pans to catch all rinsate and residues.
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Any unloading or transfer lines that preceded the waste feed
tank will be flushed with fuel oil. The oil will be pumped
through these lines to the waste feed tank and fed directly
through the waste feed lines and burner nozzle. This will also
flush the lines and burner nozzles.
Each waste feed tank will be flushed three times with a
quantity of fuel oil equal to at least 10% of the volume of the
tank. The waste feed tanks will be sprayed with a portable
spray system to rinse the vessel internals. This oil will be
burned through the waste feed system.
The incinerator charging systems, conbustion chambers and
pollution controls devices will be inspected for contamination
by wipe tests. Cellulose pads will be used to collect surface
samples for extraction followed by GC/MS scanning analyses.
Comparison of these results to those from a scan of the fuel oil
will be used to detect the presence of contaminants that could
indicate incomplete decontamination. Incineration system equip-
ment decontamination will be repeated, if necessary.
During the cleaning and decontamination process, any evidence
of possible contamination on the concrete base will be treated.
The clean-up crew will use solvent (kerosene) on the surface and
rinse with hot soapy water. This procedure is repeated until
all visible residues are gone. IR analysis will be performed on
the rinsings to insure that the decontamination process has been
successf ul.
During closure operations the incinerator will be operated
at the conditions specified in its operating permit.
After the flushing oils and rinsates have been burned or
appropriately disposed and the incineration system shutdown, the
alkaline feed tanks will be neutralized and drained.
The entire quench and scrubber water system will be tested
as required for discharge by permit and drained. The system
will be thoroughly flushed with water.
Ash will be collected from the kiln ash hopper after inciner-
ation system shutdown and disposed of as hazardous waste together
with collected particulate matter.
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UWC will provide the Regional Administrator with certifica-
tion that the incinerator has been closed in accordance with the
specifications contained in the approved closure plan. An inde-
pendent professional engineer will also certify that closure
activities were performed in accordance with the approved
closure plan. The independent P.E. will be present during the
decontamination procedure.
I-le Schedule for Closure
The EPA Regional Administrator will be notified by UWC at
least 180 days before beginning closure at a site. The proposed
schedule for closure follows.
Closure Schedule for UWC Incinerator Unit
Scheduled Event
Days after Closure
Ini tiation
Incineration of final volume of
hazardous waste
0- 2
Flushing and decontamination of piping,
containment systems, unloading and
transfer lines and waste feed tanks
15-20
Final incineration of waste oil
flushings, and all combustible
decontamination residues
20-25
Receipt of analytical verification of
decontamination of incinerator system
60
Collection and sampling of all process
water, cooling water, sump liquids and
incinerator wastewater and ash residues
25
Review laboratory analysis results and
treat (if necessary) wastewater and
discharge. Dispose of solid wastes
60-90
Certify closure complete
180
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1-4 CLOSURE COST ESTIMATE
The latest cost estimate for conducting closure of the UWC
incineration unit is $28,845. The closure cost estimate is
based upon treatment by incineration of the maximum inventory of
hazardous wastes that will be collected on-site and stored for
incineration. The closure costs are summarized by activity in
Table 1-1.
The closure cost estimate will be kept at the UWC incinera-
tion unit. It will be revised whenever a change in the incin-
eration unit affects the cost of closure. The closure cost
estimate will be adjusted anually to reflect changes in closure
costs brought about by inflation. The Department of Commerce's
Annual Implicit Price Deflator for Gross National Product will
be used to make this adjustment. This "latest adjusted cost
estimate" will be retained at the incineration unit together with
the "latest cost estimate" throughout the life of the incinerator
unit and final closure of the facility.
The following pages present detailed calculations of closure
costs .
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TABLE 1-1 ESTIMATED CLOSURE COSTS
1. Incineration of maximum waste volume $ 9,702
2. Equipment decontamination and incinera-
tion of oily rinsates and residues 5,471
3. Wastewater treatment and disposal 3,254
4. Professional Certification 1,450
5. Administrative Costs 5,206
6. TOTAL 325,083
7. CONTINGENCIES (15% of line 6) 3,762
8. TOTAL COST 328,845
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INCINERATION OF FINAL WASTE VOLUME
Maximum "hazardous waste inventory at any time during facility
active life:
10,000 gallons liquid (71,000 pounds)
35,000 pounds solids
Required incinerator operating time:
Solids 35,000 lb/(160 lb/hr) = 219 hours
Liquids 71,000 lb/(300 lb/hr) = 237 hours
Fuel oil cost:
237 hrs x 12 gal/hr x $1.05/gal = $2,986
Labor cost:
Kiln operators - 2 x 237 hrs x $8.65/hr = $4,100
Foreman - 80 hrs x $12.50/hr = $1,000
Laborers - 30 hrs x $7.20/hr = $ 216
Total labor $5,316
Utilities and supplies:
Electricity - 10 days x $65/day = $ 650
Water - 10 days x $28/day = $ 280
Caustic - 10 days x $47/day = $ 470
Total utilities and supplies $1,400
Total cost to incinerate final volume of waste:
$2,986 + $5,316 + $1,400 = $9,702
This averages to an operational unit cost of $40.4l/hr.
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EQUIPMENT DECONTAMINATION AND
INCINERATION OF RINSATES; RESIDUES
The volume of fuel oil required for rinsing all lines three
times with fuel oil is estimated to be 1,000 gallons. The cost
would be:
1,000 gal x $1.05/gal = $1,005
The time required to incinerate the rinsings would be:
1,000 gal x (7.3 lb/gal)/(300 lb/hr) = 24 hrs
As calculated previously, operational costs for the inciner-
ator average $40.4l/hr. Including the time required to start up
the incinerator (about 2 hours), total operatioal costs would be:
26 hrs x $40.41 = $1,051
Incinerator piping decontamination is expected to require an
additional 16 hours of laborers' time, resulting in a cost of:
16 hrs x $7.20/hr = $ 115
The portable oil spraying system used in the refurbishment
of widget sprockets is available for use in tank decontamination
at no cost to UWC.
Analysis of 10 wipe-test pads and one fuel oil sample is
estimated to cost:
11 samples x $300/sample = $3,300
Total incinerator system decontamination costs are estimated
to be:
$1,005 + $1,051 + $115 + $3,300 = $5,471
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DISPOSAL OF PROCESS RESIDUES
Scrubber water and quench water will be treated and dis-
charged to the Treebrook WTP per UWC's NPDES permit.
Water treatment and discharge costs normally average $212/
day, resulting in an expected cost, for 263 hours ( 237 + 26) of
operation, of $2,323.
Ash and particulate disposal as hazardous wastes average
$85/day, resulting in an expected cost of $931 for solids
disposal.
Total residue disposal is estimated to cost:
$2,323 + $931 = $3, 254
EQUIPMENT PISPOSAL
As all incinerator related equipment will be decontaminated
during closure, no disposal will be required. It is expected
that the incineration system will be abandoned in place pending
eventual salvage.
PROFESSIONAL CERTIFICATION
An independent registered professional engineer will be
retained to certify closure. His time requirements are expected
to be 29 hours, calculated as follows:
Familiarization with closure plans - 8 hours
Inspection during decontamination - 16 hours
Review of analytical results - 4 hours
Preparation of certification - 1 hour
Total time
29 hours
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Total independent certification, at $50/hr, is estimated to
cos t:
29 hrs x $50/hr = $1,450
FACILITY SECURITY
Facility security will be maintained throughout the closure
period until closure is complete by means of the plant's fences
and gates. No cost is associated with maintaining security
during closure.
ADMINISTRATIVE COSTS
Approximately 120 hours of UWC administrative time will be
involved in managing and certifying closure at a fully-burdened
rate of $19.50 per hour resulting in costs of:
120 hrs x $19.50/hr = $2,340
Administrative costs on direct labor (including fringe bene-
fits, accounting, taxes, etc.) approximate 48 percent of the
employee labor costs, or:
0.48 ($5,316 + $540 + $115) = $2,866
Total administrative costs are estimated to be:
$2,340 + $2,866 = $5,206
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Attachment 1: Certification by the Chief Financial
Officer of UWC, Inc.
Attachment 2: The CPA's Report regarding UWC, Inc.'s
Fiscal Year 1982 Financial Statements.
Attachment 3: The CPA's Report verifying the Chief
Financial Officer's Certification.
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Attachment 1
Page 1 of 4
June 12, 1982
Ms. Jacqueline Schaffer
Regional Administrator
Region II
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10278
Dear Ms. Schaffer:
I am the Chief Financial Officer of:
UWC, Inc.
2500 Industrial Drive
Treebrook, NJ 07180
This letter is in support of this firm's use of the financial
test to demonstrate financial assurance, as specified in Subpart
H of 40 CFR Parts 264 and 265.
1. This firm is the owner or operator of the following
facilities for which financial assurance for closure or post-
closure care is demonstrated through the financial test specified
in Subpart H of 40 CFR Parts 264 and 265. The current closure
and/or post-closure cost estimates covered by the test are shown
for each facility:
Universal Widget Corporation, Inc.
2500 Industrial Drive
Treebrook, NJ 07180
EPA ID. No. NJ4680020000, Closure Cost Estimate $28,845.
2. This firm guarantees, through the corporate guar-
antee specified in Subpart H of 40 CFR Parts 264 and 265, the
closure or post-closure care of the following facilities owned
or operated by subsidiaries of this firm. The current cost
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Attachment 1
Page 2 of 4
estimates for the closure or post-closure c are so guaranteed are
shown for each facility:
NONE
3. In states where EPA is not administering the finan-
cial requirements of Subpart H of 40 CFR Parts 264 and 265, this
firm, as cwner or operator or guarantor, is demonstrating
financial assurance for the closure or post-closure care of the
following facilities through the use of a test equivalent or
substantially equivalent to the financial test specified in
Subpart H of 40 CFR Parts 264 and 265. The current closure
and/or post-closure cost estimate covered by such a test are
shown for each facility:
NONE
4. This firm is the owner or operator of the following
hazardous waste management facilities for which financial assur-
ance for closure or, if a disposal facility, post-closure care,
is not demonstrated either to EPA or a state through the finan-
cial test or any other financial assurance mechanism specified
in Subpart H of 40 CFR Parts 264 and 265 or equivalent or
substantially equivalent state mechanisms. The current closure
and/or post-closure cost estimates not covered by such financial
assurance are shown for each facility:
NONE.
This firm is not required to file a Form 10K with the
Securities and Exchange Commission (SEC) for the latest fiscal
year.
The fiscal year of this firm ends on February 28, 1983. The
figures for the following items marked with an asterisk are
derived from this firm's independently audited, year-end finan-
cial statements for the latest completed fiscal year, ended
February 28.
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Attachment 1
Page 3 of 4
Alternative I
1. Sum of current closure and post-closure
cost estimates $ 147,114
*2. Total liabilities 51,020,000
*3. Tangible net worth 17,600,000
*4. Net worth 23,300,000
*5. Current assets 18,980,000
*6. Current liabilities 10,800,000
*7. Net working capital (Line 5 minus Line 6) 8,180,000
*8. The sum of net income plus depreciation,
depletion and amortization 15,500,000
*9. Total assets in U.S. (required only if
less than 90% of firm's assets are located
in the U. S. ) All U. S.
Yes No
10. Is line 3 at least $10 million? x
11. Is line 3 at least 6 times line 1?
12. Is line 7 at least 6 times line 1? x
*13. Are at least 90% of firm's assets located
in the U.S.? If not complete line 14. x
*14. Is line 9 at least 6 times line 1? N/A
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Attachment 1
Page 4 of 4
Yes No
15.
Is
1 ine
2
divided
by
1 ine
4
less than 2.00
X
16.
Is
line
8
divided
by
line
2
greater than 0.15
X
17.
Is
1 ine
5
divided
by
1 ine
6
greater than 1.50
X
I hereby certify that the wording of this letter is identical to
the wording specified in 40 CFR 264.151(f) as such regulations
were constituted on the date shown immediately below.
'anessa Delrio
Pres iden t
Universal Widget Corporation, Inc.
June 12, 1982
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Attachment 2
(RUBIN, SMITH AND ASSOCIATES LETTERHEAD)
April 20, 1982
Ms. Vanessa Delrio
Pres ident
Universal Widget Corporation, Inc.
2500 Industrial Drive
Treebrook, NJ 07180
Dear Ms. Delrio:
We have examined the consolidated balance sheets of Universal
Widget Corporation, Inc., and subsidiaries as of February 28,
1982, and the related consolidated statements of income, share-
holder's equity, and changes in financial position for the year
then ended. Our examinations were made in accordance with
generally accepted auditing standards and, accordingly, included
such tests of the accounting records and such other auditing
procedures as we considered necessary in the circumstances.
In our opinion, the financial statements referred to above
present fairly the consolidated financial position of Universal
Widget Corporation, Inc. and subsidiaries as of February 28,
1982, the consolidated results of their operations and the
consolidated changes in financial positions for the year then
ended, in conformity with generally accepted accounting
principles applied on a cons is tan t basis.
Respectfully,
Gerry qubin
Certified Public Accountant
Rubin, Smith and Associates
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Attachment 3
(RUBIN, SMITH AND ASSOCIATES LETTERHEAD)
June 25, 1982
Ms. Vanessa Delrio
Pres ident
Universal Widget Corporation, Incorporated
2500 Industrial Drive
Treebrook, NJ 07180
Dear Ms. Delrio:
We have compared the data contained in your letter of April 20,
1982 to Ms. Jacqueline Schaffer, the USEPA Region II Admini-
strator, which you specify was derived from the independently
audited, year-end financial statements of Universal Widget
Corporation, Inc. as of February 28, 1982, with the amounts in
those financial statements.
In our opinion, the data contained in the letter, referred to
above presents fairly the consolidated financial position of
Universal Widget Corporation, Inc., and subsidiaries as of
February 28, 1982 and the consolidated results of their opera-
tions for the year then ended, in conformity with generally
accepted accounting principles applied on a consistant basis.
No matters came to our attention which caused us to believe that
the data in the letter referred to above should be adjusted.
Respect fully,
Certified Public Accountant
Rubin, Smith and Associates
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1-8 CERTIFICATE OF LIABILITY INSURANCE
UWC, Inc. has obtained a liability insurance policy covering
sudden accidents that many occur in association with the UWC
Incineration Unit. A copy of the certificate of liability insur-
ance is provided as Attachment 4.
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Attachment 4
HAZARDOUS WASTE FACILITY
CERTIFICATE OF LIABILITY INSURANCE
1. Peaceville Insurance Company, Inc. (the "Insurer"),
o f
85 Turnpike Ave.
Peaceville, NJ 07109
hereby certifies that it has issued liability insurance covering
bodily injury and property damage to Universal Widget Corpora-
tion, Inc. (the "insured"), of
2 500 Industrial Drive
Treebrook, NJ 07180
in connection with the insured's obligation to demonstrate
financial responsibility under 40 CFR 264.147 or 265.147. The
coverage applies at
EPA Facility No. NJ4680020000
Universal Widget Corporation, Inc.
2 500 Industrial Drive
Treebrook, NJ 07180
for sudden accidental occurrences. The limits of liability are
Each occurrence $1,000,000 (sudden)
Annual aggregate $2,000,000 (sudden)
exclusive of legal defense costs. The coverage is provided under
policy number EL-0074, issued on July 14, 1982. The effective
date of said policy is July 15, 1982.
2. The Insurer further certifies the following with
respect to the insurance described in Paragraph 1:
(a) Bankruptcy or insolvency of the insured shall
not relieve the Insurer of its obligations under the policy.
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(b) The Insurer is liable for the payment of
amounts within any deductible applicable to the policy, with a
right of reimbursement by the insured for any such payment made
by the Insurer. This provision does not apply with respect to
that amount of any deductible for which coverage is demonstrated
as specified in 40 CFR 264.147(f) or 265.147(f).
(c) Whenever requested by a Regional Administrator
of the U.S. Environmental Protection Agency (EPA), the Insurer
agrees to furnish to the Regional Administrator a signed dupli-
cate original of the policy and all endorsements.
(d) Cancellation of the insurance, whether by the
insurer or the insured, will be effective only upon written
notice and only after the expiration of sixty (60) days after a
copy of such written notice is received by the Regional Admini-
strator of the EPA Region in which the facility is located.
(e) Any other termination of the insurance will be
effective only upon written notice and only after the expiration
of thirty (30) days after a copy of such written notice is re-
ceived by the Regional Administrator of the EPA Region in which
the facility is located.
I hereby certify that the wording of this instrument is
identical to the wording specified in 40 CFR 264.151 (j) as such
regulation was constituted on the date first above written, and
that the Insurer is licensed to transact the business of insur-
ance, or eligible to provide insurance as an excess or surplus
lines insurer, in one or more States.
Simon Schiester
Vice President
Authorized Representative of
Peaceville Insurance Company, Inc.
85 Turnpike Avenue
Peaceville, NJ 07109
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SECTION J
OTHER FEDERAL LAWS
Information will be provided in accordance with the require-
ments of 40 CFR Part 122. 2 5 (a) ( 20) at the request of the EPA
Region II office. At this time, however, we believe this
facility is in compliance with the following Federal laws: Wild
and Scenic Rivers Act, National Historic Preservation Act of
1966, Endangered Species Act, Coastal Zone Management Act, and
the Fish and Wildlife Coordination Act.
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SECTION K
CERTIFICAT ION
I certify under penalty of law that I have personally
examined and am familiar with the information submitted in this
and all attached documents and that, based on my inquiry of
those individuals immediately responsible for obtaining the
information, I believe that the submitted information is true,
accurate and complete. I am aware that there are significant
penalties for submitting false information, including the
possibility of fine and imprisonment.
Universal Widget Corporation, Inc
R. F. Headley, President
Date
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