Hazardous Waste Combustion Unit
Permitting Manual
COMPONENT 7
(Vol. 1 of 2)
How To Prepare Permit Conditions
U.S. EPA Region 6 Center for Combustion
Science and Engineering
Tetra Tech EM Inc.
-------
COMPONENT SEVEN
HO W TO PREPARE PERMIT CONDITIONS
JANUARY 1998
-------
7-iv
7-vi
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
CONTENTS
Section
ABBREVIATIONS AND ACRONYMS
BIBLIOGRAPHY
1.0 INTRODUCTION 7-1
1.1 THE TYPICAL PERMIT 7-3
1.2 THE PERMIT PROCESS 7-5
1.3 THE FOUR-PHASED PROCESS FOR NEW FACILITIES 7-8
1.4 THE PERMITTING TEAM 7-12
2.0 STANDARD PERMIT CONDITIONS 7-15
3.0 GENERAL FACILITY CONDITIONS 7-17
4.0 CONDITIONS APPLICABLE TO CONTAINERS AND TANKS 7-19
5.0 DEVELOPING PERMIT CONDITIONS 7-22
5.1 EVALUATING TRIAL BURN DATA 7-25
5.2 SELECTING THE PERMITTING APPROACH 7-29
5.3 DEVELOPING PERMIT LIMITS 7-34
5.3.1 Establishing Feed Rate Limits for Metals 7-36
5.3.2 Translating Trial Burn Results Into Permit Limits, Group A and B
Parameters 7-47
5.3.3 Establishing Operating Limits for Group C Parameters 7-50
5.3.4 Translating Risk Assessment Results Into Permit Conditions 7-52
5.3.5 Using Risk Burn Data to Set Risk-Based Permit Conditions for Operating
Parameters 7-55
6.0 COMBUSTION UNIT CONDITIONS 7-60
6.1 ROTARY KILNS 7-64
6.2 BOILERS 7-69
6.3 LIQUID INJECTION INCINERATORS 7-72
6.4 HALOGEN ACID FURNACES 7-74
7.0 AIR POLLUTION CONTROL SYSTEM CONDITIONS 7-81
7.1 QUENCH SYSTEMS 7-83
7.2 FABRIC FILTER BAGHOUSES 7-85
7.3 ELECTROSTATIC PRECIPITATORS 7-88
7.4 VENTURI SCRUBBERS 7-91
7.5 WET SCRUBBERS 7-94
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-i
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-ii
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
CONTENTS (Continued)
Section Page
8.0 MISCELLANEOUS CONDITIONS 7-97
8.1 MISCELLANEOUS UNITS 7-98
8.2 AIR QUALITY PERMIT CONDITIONS 7-100
9.0 CORRECTIVE ACTION REQUIREMENTS 7-101
10.0 CLOSURE AND FINANCIAL ASSURANCE REQUIREMENTS 7-103
11.0 CASE STUDY — CONSOLIDATED INCINERATION FACILITY 7-104
EXHIBITS
Exhibit Page
1.3-1 EXAMPLE TESTING AND TRIAL BURN SCHEDULE 7-11
5.0-1 PERMIT CONDITION RATIONALE AND BASIS 7-24
5.1-1 COMBUSTION TEMPERATURES OVER TIME 7-27
5.1-2 COMBUSTION TEMPERATURES CONTROL CHARTS 7-28
5.2-1 WASTE FEED CUTOFF LIMITS FOR AMERICAN EVIROTECH—SINGLE-POINT
APPROACH 7-31
5.2-2 MAXIMUM FEED RATES TO THE ANCDF LIQUID INJECTION INCINERATOR-
MULTIPLE POINT APPROACH 7-32
5.2-3 WASTE FEED CUTOFF LIMITS FOR ASH GROVE CEMENT—UNIVERSAL
APPROACH 7-33
5.3.1-1 MAXIMUM EXPOSED INDIVIDUAL 7-41
5.3.1-2 40 CFR PART 266 APPENDIX I, TABLE 1-A 7-42
5.3.1-3 40 CFR PART 266 APPENDIX I, TABLE 1-D 7-43
5.3.1-4 40 CFR PART 266 APPENDIX IV 7-44
5.3.1-5 40 CFR PART 266 APPENDIX V 7-45
5.3.1-6 40 CFR PART 266 APPENDIX VI 7-46
5.3.4-1 CALCULATION OF METALS EMISSIONS REDUCTION FACTORS 7-54
5.3.5-1 PARETO DIAGRAM FOR PIC EMISSIONS 7-57
5.3.5-2 PARETO DIAGRAM FOR METALS EMISSIONS 7-58
5.3.5-3 ORE AND RISK BURN PROCESS DATA SUMMARY 7-59
6.1-1 TXI MIDLOTHIAN PERMIT SECTION IV 7-66
6.4-1 HALOGEN ACID FURNACE PROCESS FLOW DIAGRAM 7-77
6.4-2 PARETO DIAGRAM FOR HAF OFF-GAS TREATMENT TRAIN OPERATING
CONDITIONS RELATED TO PIC EMISSIONS 7-78
6.4-3 PARETO DIAGRAM FOR HAF OFF-GAS TREATMENT TRAIN OPERATING
CONDITIONS RELATED TO PM, HC1, C12, EMISSIONS 7-79
6.4-4 PARETO DIAGRAM FOR HAF OFF-GAS TREATMENT TRAIN OPERATING
CONDITIONS RELATED TO METALS EMISSIONS 7-80
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-iii
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
ATTACHMENTS
Attachment
A ANMSTON CHEMICAL DEMILITARIZATION FACILITY FINAL RCRA PERMIT
B TEXAS INDUSTRIES, INC. DRAFT RCRA PERMIT
C U.S. EPA REGION 6 MODEL RCRA BOILER PERMIT
D U. S. EPA REGION 6 MODEL RCRA CEMENT KILN PERMIT
E U.S. EPA REGION 6 MODEL RCRA ROTARY KILN INCINERATOR PERMIT
F U.S. EPA REGION 6 MODEL RCRA HALOGEN ACID FURNACE PERMIT
G CONSOLIDATED INCINERATION FACILITY RADIOACTIVE MIXED WASTE
INCINERATION PERMIT
H NATIONAL CHEMICAL DEMILITARIZATION WORK GROUP
I TEXAS INDUSTRIES, INC. DRAFT RCRA PERMIT, GENERAL FACILITY
CONDITIONS
J ANNISTON CHEMICAL DEMILITARIZATION FACILITY FINAL RCRA PERMIT,
MODULE I, STANDARD PERMIT CONDITIONS
K ANNISTON CHEMICAL DEMILITARIZATION FACILITY FINAL RCRA PERMIT,
GENERAL PERMIT CONDITIONS
L ASH GROVE CEMENT COMPANY RCRA PERMIT, SECTIONS III AND IV
M ASH GROVE CEMENT COMPANY RCRA PERMIT, SECTION E
N PROCESS MONITORING DATA, RECENT TRIAL BURN
O ASH GROVE CEMENT COMPANY RCRA PERMIT, SECTION A. 15
P ANNISTON CHEMICAL DEMILITARIZATION FACILITY FINAL RCRA PERMIT,
SECTION VII. B
Q ANNISTON CHEMICAL DEMILITARIZATION FACILITY FINAL RCRA PERMIT,
CONDITIONS FOR THE BRINE REDUCTION AREA
R TEXAS INDUSTRIES, INC. DRAFT RCRA PERMIT, AIR QUALITY PROVISIONS
S TEXAS INDUSTRIES, INC. DRAFT RCRA PERMIT, CLOSURE AND FINANCIAL
ASSURANCE PROVISIONS
T ASH GROVE CEMENT COMPANY, PART II—EPA AUTHORIZATION UNDER THE
HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984
U TRADITIONAL VS. RISK-BASED PERMITTING APPROACH: PERMIT TO MANAGE
RISKS, BY DAVID WEEKS
V ENVIRONMENTAL APPEALS BOARD RULING ON THE ASH GROVE CEMENT
COMPANY RCRA PERMIT
W CONSOLIDATED INCINERATION FACILITY PERMIT CONDITIONS SCHEMATIC
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-iv
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
ABBREVIATIONS AND ACRONYMS
acfm actual cubic feet per minute
ADEM Alabama Department of Environmental Management
AEI American Envirotech, Inc.
APR Actual feed rate
AGC Ash Grove Cement
ANCDF Anniston Chemical Demilitarization Facility
AOC Area of concern
API American Petroleum Institute
APCS Air pollution control system
ASME American Society of Mechanical Engineers
AWFCO Automatic waste feed cutoff
BIF Boiler and industrial furnace
Btu British thermal unit
°C Degrees Celsius
CAA Clean Air Act
cfm cubic feet per minute
GIF Consolidated Incineration Facility
C12 Chlorine
CO Carbon monoxide
40 CFR Title 40, Code of Federal Regulations
DRE Destruction and removal efficiency
ESH Effective stack height
ESP Electrostatic precipitator
°F Degrees Fahrenheit
FRSL Feed rate screening limits
g/hr grams per hour
gpm gallons per minute
HAF Halogen acid furnace
HC1 Hydrogen chloride
HEPA High efficiency particulate air
HHV High heating value
HI Hazard index
HQ Hazard quotient
HRA Hourly rolling average
HSWA Hazardous and Solid Waste Amendments
°K Degrees Kelvin
KDHE Kansas Department of Health and Environment
kVA kilovolt amperes
Ib/hr pounds per hour
Ib/min pounds per minute
Ib/yr pounds per year
LIC Li quid injection incinerator
LHV Low heating value
ug/m3 micrograms per cubic meter
m3/sec cubic meters per second
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-v
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
MEI
NFPA
02
PCC
PCDD/PCDF
PIC
PLC
PM
POHC
ppmv
psia
psig
RAC
RCRA
RSD
SCC
SCDHEC
SWMU
TAESH
THC
TID
TNRCC
tph
TXI
U.S. EPA
w.c.
Maximum exposed individual
ABBREVIATIONS AND ACRONYMS
(Continued)
National Fire Protection Association
Oxygen
Primary combustion chamber
Poly chlorinated dibenzo(p)dioxin/poly chlorinated dibenzofuran
Product of incomplete combustion
Programmable logic controller
Particulate matter
Principal organic hazardous constituent
parts per million bay volume
pounds per square inch absolute
pounds per square inch gauge
Reference air concentration
Resource Conservation and Recovery Act
Risk specific dose
Secondary combustion chamber
South Carolina Department of Health, Environment, and Conservation
Solid waste management unit
Terrain adjusted effective stack height
Total hydrocarbon
Technical Implementation Document
Texas Natural Resource Conservation Commission
tons per hour
Texas Industries, Inc.
U.S. Environmental Protection Agency
Water column
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-vi
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
BIBLIOGRAPHY
U.S. Environmental Protection Agency (EPA). 1983. "Guidance Manual for Hazardous Waste
Incineration Permits."
U.S. EPA. 1986. "Technical Resource Document for the Storage and Treatment of Hazardous
Waste in Tank Systems." Office of Solid Waste. Washington, D.C. EPA/530-SW-86-044.
U.S. EPA. 1988. "Model RCRA Permit for Hazardous Waste Management Facilities." Washington,
D.C. Office of Solid Waste. EPA/530-SW-90-049.
U.S. EPA. 1988. "Permitting Hazardous Waste Incinerators." EPA/530-SW-88-024.
U.S. EPA. 1989. "RCRA Facility Investigation Guidance." EPA/530/SW-89-031.
U. S. EPA. 1989. "Handbook: Guidance on Setting Permit Conditions and Reporting Trial Burn
Results." Office of Research and Development (ORD). Cincinnati, Ohio. EPA/625/6-
89/019. January.
U.S. EPA. 1990. "Draft of Guidance of Incinerator Closure." Office of Solid Waste and Emergency
Response (OSWER). Washington, D.C. October 30.
U.S. EPA. 1991. "Guidance Manual for Hazardous Waste Incinerator Permits." Office of Solid
Waste. Revised Draft. August.
U.S. EPA. 1992. "Technical Implementation Document (TID) for EPA's Boiler and Industrial
Furnace (BIF) Regulations." OSWER. Washington, D.C. EPA-530-R-92-011. March.
U.S. EPA. 1992. "Seminar—Operational Parameters for Hazardous Waste Combustion Devices."
ORD. EPA/625/R-93/008. October.
U.S. EPA. 1994. "Combustion Emissions Technical Resource Document." OSWER.
Washington, D.C. EPA-530-R-94-014. May.
U.S. EPA. 1994. "RCRA Corrective Action Plan." OSWER. 9902.3-2A. EPA/520/R-94-004.
Weeks, David. 1997. "Traditional vs. Risk-Based Permitting Approach: Permit to Manage Risks,"
presented at the 1997 International Conference on Incineration and Thermal Treatment
Technologies.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous Waste Combustion
Facilities." Center for Combustion Science and Engineering, Multimedia Planning and
Permitting Division, U.S. EPA Region 6. Dallas, Texas. EPA-R6-098-002. January.
U.S. EPA. 1998. "Protocol for Screening Level Ecological Risk Assessment at Hazardous Waste
Combustion Facilities." Center for Combustion Science and Engineering, Multimedia Planning
and Permitting Division, U.S. EPA Region 6. Dallas, Texas. EPA-R6-098-003. January.
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-vii
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
1.0 INTRODUCTION
Regulations:
Guidance:
Explanation:
Check For:
Tittle 40 Code of Federal Regulations (CFR) Parts 124, 264.344, 270.1, 270.62,
and 270.66
No specific references are applicable to this section of the manual.
As part of the permit process, the permit writer must include the applicable set of
operating requirements specific to each type of hazardous waste that will be
burned and the operating modes of the combustion unit permit conditions. The
subsections of this introductory section address:
• The typical permit (Section 1.1)
• The permit process (Section 1.2)
• The four-phased process for new facilities (Section 1.3)
• The permitting team (Section 1.4)
The actual permit process followed depends on whether the permit is for a new
or existing hazardous waste combustion unit. For either case, the operating
requirements must reflect the range of conditions that have been successfully
demonstrated during the trial burn. Because the permits are for complex waste
management facilities, a diverse team of professionals is required to prepare the
operating permit.
The typical operating permit includes the following sections:
Q Module I—Standard Permit conditions
Q Module II—General Facility Conditions
Q Module III—Storage in Containers
Q Module IV—Storage in Tanks
Q Module V—Miscellaneous Units
Q Module VI—General Operating Requirements
Q Module VII—Specific Operating Conditions
Q Module VIII—Corrective Action
Q Module IX—Closure and Financial Assurance
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-1
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Sections 2.0 through 10.0 of this component discuss the various modules of an
operating permit. This component also includes an explanation of how to develop
permit conditions (Section 5.0) and a case study (Section 11.0).
Example Situation:
Example Action:
Lois and Clark receive a Part B permit application for a new hazardous waste
combustion unit. What do they do?
Because the ultimate goal of the combustion unit permitting process is the
development of a permit and operating permit conditions that satisfies the facility.
the regulatory agency, and the public; Lois and Clark review Component 7 to
ensure they understand the full scope of the information needed to prepare the
permit.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-2
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
1.1 THE TYPICAL PERMIT
Regulations:
Guidance:
Explanation:
Examples:
40 CFR Parts 264.344, 270.62, and 270.66
No specific references are applicable to this section of the manual.
No required format exists for a hazardous waste combustion system permit. The
permit must, however, designate a set of operating requirements specific to each
type of hazardous waste that will be burned in the unit. These operating
requirements must reflect the set of conditions that have been shown during the
trial burn to achieve applicable performance standards and operating
requirements of 40 CFR Parts 264.343 and 264.345. The permit may also
specify compliance schedules that require facilities to meet current operating
standards and stipulate corrective actions for existing solid waste management
units (SWMU) with documented releases.
Lois and Clark of Metropolis have been selected to prepare permit conditions for
several facilities including the following:
Anniston Chemical Demilitarization Facility, Anniston, Alabama
The Alabama Department of Environmental Management (ADEM) issued a final
Resource Conservation and Recovery Act (RCRA) permit in June 1997 (Permit
AL3 210 020 027, see Attachment A) for Anniston Chemical Demilitarization
Facility (ANCDF). ANCDF is an integrated hazardous waste management
system for chemical weapons and includes tank storage systems, several
evaporators, four different incinerators and furnaces, and associated air pollution
control systems (APCS). Lois and Clark organized the ANCDF draft permit as
follows:
Module I Standard Permit Conditions
Module II General Facility Conditions
Module III Container Storage
Module IV Tank Systems
Module V Miscellaneous Treatment Units
Module VI Incineration — Shakedown, Trial Burn, and Post-Trial
Burn
Module VII Incineration— Normal Operation
Module VIII Corrective Action for Solid Waste Management Units
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-3
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Texas Industries, Inc., Midlothian, Texas
The Texas Natural Resource Conservation Commission (TNRCC) in 1996 issued
a draft RCRA permit governing Texas Industries, Inc. (TXI), governing the
operation of hazardous waste storage tanks and waste-burning kilns at its cement
plant in Midlothian, Texas (see Attachment B). Lois and Clark organized the
TXI draft RCRA permit as follows:
Permit Section I - General Permit Conditions
Permit Section II - General Facility Conditions
Permit Section III - Storage in Containers
Permit Section IV - Storage and Processing in Tanks
Permit Section V - Office of Air Quality Provisions
Permit Section VI - Closure and Financial Assurance Requirements
Permit Section VII - Corrective Action Requirements
EPA Region 6 Model Permits
To provide guidance to permit writers regarding the format and content of
permits, EPA Region 6 has developed model boiler and industrial furnace (BIF)
Hazardous and Solid Waste Amendments (HSWA) permits for four types of
hazardous waste combustion systems: boilers, rotary kiln incinerators, cement
kilns, and halogen acid furnaces. These model permits are provided in
Attachments C, D, E, and F.
Notes:
U.S. EPA Region 6 7-4
Center for Combustion Science and Engineering
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
1.2 THE PERMIT PROCESS
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Parts 124 and 270.1
No specific references are applicable to this section of the manual.
There are prescribed processes for permitting new and existing hazardous waste
incinerators and BIFs. The permit for a new facility must be issued before
construction of that unit may begin. Existing facilities operating under interim
status will be issued a permit after completion of the trial burn test.
Whether the facility is new or existing, there are fundamental elements
associated with the permitting process. The following summarizes the process
elements common to both types of facilities.
New Facilities
Q Submit Part A permit application
Q Submit Part B permit application
Q Review permit application
Q Prepare draft permit
Q Public participation
Q Public Participation Rule notices and informal meeting
Q Public comment on draft permit
Q Public hearing or meeting (if requested)
Q Issue four-phased permit
Q Phase 1 - startup/shakedown
Q Phase 2 - trial burn
Q Phase 3 - post-trial burn operations
Q Phase 4 - final operating conditions
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-5
-------
Examples:
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Existing Facilities
Q Submit Part A permit application
Q Submit Part B permit application
Q Review permit application
Q Public comment on trial burn plan (optional)
Q Trial burn
Q Trial burn analysis and review
Q Prepare draft permit
Q Public participation
Q Public Participation Rule notices and informal meeting
Q Public comment on draft permit
Q Public hearing or meeting (if requested by public)
Q Issue permit
In preparing permit conditions for the following facilities, Lois considered
information generated during the following sequence of events. Lois is satisfied
that these events, and the order in which they occur, address all necessary
permitting process elements.
New Facility
Parts A and B permit application prepared - January 1994
State agency review of permit application - April 1994
U.S. EPA review of permit application - June 1994
Draft permit issued - January 1995
Public notice of draft permit - January 1995
Public hearing - March 1995
Four-phased permit issued - July 1996
Four-phased permit revised - September 1996
Trial burn - October 1996
Final operating conditions (expected) - January 1997
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-6
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Existing Facility
Parts A and B permit application prepared - May 1995
U.S. EPA review of permit application - June 1995
Trial burn - November 1995
Draft permit issued - January 1996
Public comment - January 1996
Public hearings (two) - February 1996
Final permit issued - August 1996
Notes:
U.S. EPA Region 6 7-7
Center for Combustion Science and Engineering
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
1.3 THE FOUR-PHASED PROCESS FOR NEW FACILITIES
Regulations:
Guidance:
Explanation:
Required Phases:
40 CFR Part 270.62
No specific references are applicable to this section of the manual.
The permit for a new hazardous waste combustion unit covers four phases of the
facility's life cycle. The following is a discussion of the four phases. They are
further discussed in Component 1—How to Review a Trial Burn Plan, and
Component 6—How to Review a Trial Burn Report.
• Phase 1 - Startup/Shakedown. This phase allows limited waste burning
to help stabilize the new facility's operation. During startup and
shakedown, waste feed rates typically are limited to anticipated final
limits. In practice, startup and shakedown occur sequentially. The
startup period occurs after construction is complete, as shown on Exhibit
1.3-1 (see page 7-11). During startup, a team of construction and
operations personnel "systemizes" the new plant by conducting tests on
discrete subsystems (waste blending, waste feed, combustion, air
pollution control) using nonhazardous feed materials. Any firing during
this period involves either fossil fuels or surrogate waste forms. To
conclude startup, an integrated systems test is usually conducted—again
using only fossil fuels or surrogates. If the integrated test is a success,
the construction team turns the new plant over to operations and the
shakedown period commences.
During shakedown, the new plant is operated while burning hazardous
wastes. Generally, waste feed rates are low during the initial hours of
shakedown. Waste feed rates are gradually raised to anticipated final
limits over the duration of the shakedown.
The initial shakedown period is limited by regulation to a maximum of 720
hours while burning hazardous wastes. Shakedown testing may reveal
major problems in system design (improperly sized feed augers for solid
wastes or inadequate atomization of waste, for example). These
problems may require significant changes to the system. In such cases, it
may be impossible to complete shakedown testing in 720 hours. To
account for such possibilities, regulations allow the facility owner to
petition EPA for an extension of the shakedown period. Under current
regulations, EPA may grant the facility a single extension of no more
than 720-hours. EPA Region 6 policy allows for no more than two 720
hour shakedown periods.
• Phase 2 - Trial Burn. This phase allows waste burning for the duration
of the trial burn (usually several weeks or less) to monitor emissions and
process operations and to assess compliance with performance
standards. The trial burn is used to establish final permit limits for the
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-8
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
facility. Accordingly, waste feed rates during the trial burn are
100 percent of anticipated final limits.
• Phase 3 - Post-Trial Burn Operations. Under this phase, the combustion
unit system may operate under specified limits for several months while
trial burn results are reviewed. Permit writers normally constrain
post-trial burn operations to waste feed rates lower than were
demonstrated during the trial burn. Post-trial burn waste feed rates
commonly are 50-90 percent of the waste feed rates demonstrated
during the trial burn. TNRCC, for example, typically limits waste feed
rates to 90 percent during the post-trial burn period.
• Phase 4 - Final Operating Conditions. If the combustion unit system
meets performance standards, final permit conditions are issued
governing operations for a prescribed period (usually 10 years or less).
The feed rate limits imposed by the final permit typically are those
demonstrated during the trial burn. As described in Section 5.3.4,
however, final permitted waste feed rates may be reduced to account for
the results of the site-specific risk assessment.
Regarding the risk assessment, it is recommended that a screening risk
assessment based on engineering estimates of emissions be completed
early in the permitting process (before the trial burn) to provide some
basis for anticipated final permit limits. A comprehensive multipathway
risk assessment should then be conducted after the trial burn, using trial
burn results, to confirm final permit limits.
Examples: Consolidated Incineration Facility, Aiken, South Carolina
South Carolina Department of Health, Environment, and Conservation
(SCDHEC) issued a four-phased permit in November 1996 for Consolidated
Incineration Facility (GIF), a new radioactive mixed waste incineration facility
(see Attachment G). Clark included in permit conditions a requirement for the
facility to conduct a comprehensive trial burn, including extensive testing for
products of incomplete combustion (PIC) for risk assessment purposes. The trial
burn was completed in April 1997. SCDHEC expects to issue final permit limits
within 6 months. Refer to Attachment Q for Phase 3 (post-trial burn permit
conditions). The GIF permit is unusual in that the limitations on waste feed rates
in the shakedown, trial burn, and post-trial burn periods are the same.
U.S. EPA Region 6 7-9
Center for Combustion Science and Engineering
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Anniston Chemical Demilitarization Facility, Anniston, Alabama
ADEM, with the cooperation of the National Chemical Demilitarization Work
Group, prepared a four-phased permit for the chemical weapons incineration
complex to be constructed at Anniston, Alabama. Lois included in the permit
conditions a requirement for extensive PIC testing for risk assessment purposes.
See Attachment A for an advance copy of the final permit.
The permit for the Anniston incinerator is typical in that the permitted limits on
waste feeds during the shakedown period are the same as trial burn limits.
Limits for the post-trial burn period are initially 50 percent of the maximum and
phased up to 100 percent after the trial burn report and risk assessment are
submitted. Refer to Module VI, Section C.2 of the Anniston permit for specific
permit language (see Attachment A).
EPA Region 6 Model Permits
In the EPA Region 6 model permits, waste feed rates in the startup and
shakedown and post-trial burn periods have been reduced from anticipated final
permitted levels. This percent reduction is at the discretion of the permit writer.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-10
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 1.3-1
EXAMPLE TESTING AND TRIAL BURN SCHEDULE
ID
1
2
3
4
5
6
7
8
9
10
11
12
Task Name
COMPLETE CONSTRUCTION/PROJECT TURNOVER
START UP TESTING
SYSTEMS TEST
INTEGRATED SYSTEMS TEST
SHAKEDOWN TESTING
10% WASTE CAPACITY TEST
50% WASTE CAPACITY TEST
100% WASTE CAPACITY TEST
OPERATIONAL READINESS
TRIAL BURN
TRIAL BURN DATA EVALUATION/REPORT PREPARATION
TRIAL BURN REPORT SUBMITTAL
Duration
Id
91 d
60d
29d
24d
8d
8d
8d
Id
Ibd
88d
Id
start
Mon 11/3/97
Tue 11/4/97
Tue 11/4/97
Mon 1/5/98
Tue 2/3/98
Tue 2/3/98
Wed 2/11/98
Thu 2/19/98
Fri 2/27/98
Mon 3/2/98
Tue 3/1 7/98
Mon 6/15/98
Finish
Mon 11/3/97
Mon 2/2/98
Fri 1/2/98
Mon 2/2/98
Thu 2/26/98
Tue 2/1 0/98
Wed 2/18/98
Thu 2/26/98
Fri 2/27/98
Mon 3/16/98
6/12/98
Mon 6/15/98
November December January February March April May June
11/2 11/9 11/16 11/23 11/30 12/7 12/14 12/21 12/28 1/4 1/11 1/18 1/25 2/1 2/8 2/15 2/22 3/1 3/6 3/15 3/22 3/29 4/5 4/12 4/19 4/26 5/3 5/10 5/17 5/24 5/31 6/7 6/14
•f
~
^~
^~
+
+
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-11
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
1.4 THE PERMITTING TEAM
Regulations: No regulations are applicable to this section of the manual.
Guidance: No specific references are applicable to this section of the manual.
Explanation: The hazardous waste combustion process is normally one element of a complex
waste management facility that is being permitted. Preparation of a permit for
the facility will require a mix of project management, regulatory compliance,
technical, and public relations skills. Accordingly, most permits are written by a
diverse team of professionals. The following is a list of professional skills that
will be required to support the permit preparation process for combustion units.
Recommended Skills: • Public relations
• Environmental law
• Regulatory compliance
• Policy specialist
• Structural analysis
• Material science
• Fluid flow
• Material handling
• Combustion processes
• Stack sampling
• APCS operation and design
• Air dispersion and ground deposition modeling
• Ecological risk assessment
• Human health risk assessment
• Environmental remediation
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-12
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Example Situation:
Examples:
Lois and Clark are required to manage permit preparation for the following
facilities. Each facility has several units to be addressed in the permit.
Ash Grove Cement, Chanute, Kansas
Ash Grove Cement (AGC) operates two hazardous waste-burning cement kilns
at Chanute, Kansas. These kilns burn a variety of organic hazardous waste
liquids and solids received from off-site generators, including solvent still bottoms,
ink waste oils, and other materials. The facility is permitted to handle hazardous
wastes with more than 400 D, F, K, P, and U waste codes. The Kansas
Department of Health and Environment (KDHE) and EPA Region 7 issued final
permits for waste storage in tanks and containers and incineration in cement kilns
in 1996.
Additionally—like many newer permits—this permit contains requirements for
corrective actions. For the AGC permit, Lois included corrective action
provisions covering 24 SWMUs and several areas of concern (AOCs), including
tank farms, secondary containment basins, sumps, chemical storage areas,
landfills, and other units.
Anniston Chemical Demilitarization Facility, Anniston, Alabama
The ANCDF is an integrated treatment complex for chemical weapons located
at the Anniston Army Depot in Alabama. This facility is under construction.
When completed, it will house 12 different hazardous waste storage and
treatment units, including a liquid waste incinerator for bulk chemical agent; a
deactivation furnace for energetics; a brine (process wastewater) storage tank
system; two brine evaporators; two brine drum dryers; a metal parts furnace for
ordnance casings; a dunnage incinerator; a bulk chemical agent storage tank
system; a container storage building; and a tank system for spent
decontamination liquids.
Hazardous wastes to be managed at the facility include a variety of VX-, GB-,
HD-, and HT-based chemical weapons, including M55 rockets and artillery
shells.
To complete permit preparation, Lois and Clark, recognized that they would need
a team of professionals with various expertise. To complete a permit for each
facility, Lois and Clark assembled the following professionals for each facility.
Key personnel involved in writing the permits were as follows:
Ash Grove Cement, Chanute, Kansas
Tank and Container Systems
Two Engineers, KDHE
Incineration Systems
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-13
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Chemical Engineer, EPA
Corrective Actions
Civil Engineer, EPA
General Requirements
U.S. EPA legal counsel
Anniston Chemical Demilitarization Facility, Anniston, Alabama
Incineration Systems. ADEM
Engineer
National Chemical Demilitarization Work Group
See Attachment H
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-14
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
2.0
STANDARD PERMIT CONDITIONS
Regulations:
Guidance:
Explanation:
40 CFR Part 270.30
No specific references are applicable to this section of the manual.
These permit conditions are applicable to all facilities:
Duty to comply - compels the permittee to comply with all conditions of the
permit.
Duty to reapply - compels the permittee to reapply for a permit after the current
permit expires.
Need to halt or reduce activity not a defense - compels the permittee to halt or
reduce the permitted activity, if necessary, to maintain compliance with permit
conditions.
Minimize releases to the environment - compels the permittee to take steps to
minimize releases to the environment during a period of noncompliance with
permit conditions.
Proper operation and maintenance - requires the permittee to properly operate
and maintain the facility at all times.
Permit action - allows the regulatory agency to modify, revoke, reissue, or
terminate the permit for cause.
Property rights - no property rights or exclusive privilege are conveyed by the
permit.
Duty to provide information - requires the permittee to furnish to the regulatory
agency any requested, relevant information.
Inspection and entry - guarantees the regulatory agency entry, access, and
inspection to the facility.
Monitoring and records - requires the permittee to prepare and retain records
of all monitoring activities for at least 3 years.
Signatory requirements - requires the permittee to sign and certify all
applications, reports, or other documents submitted to the regulatory agency.
Reporting requirements - sets forth specific requirements for reporting planned
changes, anticipated noncompliance, transfers, monitoring results, compliance
schedules, 24-hour reports, manifest discrepancy reports, unmanifested waste
reports, biennial reports, and other information.
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-15
-------
Examples:
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Information repository - allows the regulatory agency to require the permittee
to establish and maintain an information repository.
Recording and reporting of monitoring results - specifies the installation and
use of monitoring equipment, and associated reporting requirements.
Texas Industries, Inc., Midlothian, Texas
Clark incorporated the above requirements in preparing draft standard permit
conditions for TXI (see Attachment I). The TXI draft RCRA permit exemplifies
the approach in which general permit conditions promulgated in regulations are
reiterated in the permit. The benefit of this approach is that all requirements are
clearly defined in the report. The primary drawback is that it produces a
voluminous permit. The TXI draft RCRA permit is an example of an approach in
which standard permit requirements promulgated in regulation are incorporated
into the permit by reference (see Permit Section I.F. in Attachment I) and
additional facility-specific conditions are stipulated in detail. This approach is
attractive because it makes the permit more concise and usable as a field
inspection/compliance tool. The drawback from this approach is that it requires
inspectors/auditors to refer back to the regulatory requirements if they are not
well-versed with the regulations.
Anniston Chemical Demilitarization Facility, Anniston, Alabama
These requirements comprise an integral portion of both draft and final permits,
and it is standard practice for these requirements to be included as permit
conditions (see Attachment J). Clark incorporated the above requirements in
preparing standard permit conditions for this facility.
The ANCDF permit illustrates the approach in which regulatory requirements are
reiterated verbatim. The benefit of this approach is that all requirements are
explicit. The primary drawback is the voluminous nature of the permit.
EPA Region 6 Model Permits
The approach recommended by EPA Region 6 is similar to that adopted by
TNRCC in the TXI draft RCRA permit. Regulatory requirements are
incorporated by reference and facility-specific conditions are stipulated in detail.
Refer to Attachments C, D, E, and F for examples.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-16
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
3.0
GENERAL FACILITY CONDITIONS
Regulations:
Guidance:
Explanation:
40 CFR 270.30
No specific references are applicable to this section of the manual.
These general permit conditions are applicable to all hazardous waste combustion
facilities:
Design and operation of facility - compels the permittee to design, construct,
and operate the permitted facility in accordance with engineering designs and
specifications and in a manner that minimizes hazards to human health and the
environment.
Restrictions on off-site wastes - places restrictions or prohibitions on the receipt
of wastes from off-site generators.
General waste analysis - compels the permittee to follow the requirements of
the approved waste analysis plan and prohibits the acceptance of waste for
storage or treatment that has not been completely characterized. A copy of the
approved waste analysis plan is typically attached to the permit.
Security procedures - compels the permittee to maintain fencing and security
and to prevent unauthorized entry to the site.
General inspection requirements - requires the permittee to implement an
approved inspection program. A copy of the approved inspection program is
typically attached to the permit.
Training plan - requires the permittee to implement a hazardous waste
management training program for personnel involved in the management of
hazardous waste.
Preparedness and prevention - compels the permittee to implement the
approved preparedness and prevention program, and maintain and repair
equipment to prevent hazards to human health and the environment.
Contingency plan - compels the permittee to follow its approved contingency
plan, and forbids the permittee from operating the facility following an incident
requiring contingency plan activation until all emergency equipment and resources
are again in place and functional.
Recordkeeping and reporting - requires the permittee to maintain a
written operating record and to file reports required under the regulations
and the permit.
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-17
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Examples:
Closure - requires the permittee to maintain an updated closure plan, including a
closure cost estimate, and to close the site according to the approved closure plan.
Financial assurance - requires the permittee to maintain financial assurance for
the facility.
Liability - sets forth specific requirements for maintaining liability insurance.
Risk assessment requirements - requires the permittee to conduct a risk
assessment, usually according to an approved risk assessment work plan, within a
specified period of time following completion of the facility's trial burn.
Air emission standards for equipment leaks - places limits on
emissions of hazardous waste constituents from storage vessels and
piping systems.
Waste minimization - compels the permittee to implement a program
designed to reduce the volume and toxicity of hazardous wastes.
Land disposal restrictions - requires the permittee to comply
with land disposal restrictions.
Lois incorporated the above requirements in preparing general permit conditions
for ANCDF, a hazardous waste combustion facility (see Attachment K). The
approach at ANCDF involved incorporating regulatory requirements by
reference (see Section II. c of Attachment K, for example) and stipulating
numerous facility-specific permit conditions. Regarding the latter, all of the
permit conditions listed are facility specific. The practice of incorporating
regulatory requirements by reference allowed the permitting authority to stipulate
all of the general permit conditions in 11 pages of text. Had the permitting
authority opted to reiterate regulatory requirements verbatim in the permit, the
length of this permit section would have increased substantially.
These requirements comprise an integral portion of both draft and final permits,
and it is standard practice for these requirements to be included as permit
conditions.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-18
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
4.0 CONDITIONS APPLICABLE TO CONTAINERS AND TANKS
Regulations:
Guidance:
Explanation:
40 CFR Parts 264 Subparts I, J, and CC; 270.15; and 270.16
No specific references are applicable to this section of the manual.
These permit conditions are applicable to container and tank systems located at
hazardous waste combustion facilities:
Containers
Permitted and prohibited wastes - the permit typically specifies by name and
waste code the list of wastes that can be managed in the container system and
wastes that are expressly prohibited.
Waste volume - the permit usually specifies the maximum quantity of waste that
may be placed in each storage or treatment unit at any one time.
Operation and maintenance - compels the permittee to operate and maintain
the containers in accordance with approved procedures, usually those presented
in Section D of the permit application, and to keep all containers closed during
storage.
Container condition - compels the permittee to store wastes only in containers
that are in good condition.
Waste compatibility - requires the permittee to use only containers that are made
of, or lined with, materials that are compatible with the wastes.
Containment system - requires the permittee to store containers filled with
wastes in containment systems that meet the retention volume and compatibility
requirements of 40 CFR Part 264.175, and to remediate and report spills.
Inspection program - requires the permittee to implement an approved program
of container inspections.
Recordkeeping - requires the permittee to place the results of waste analysis
and compatibility tests in the operating record and to maintain accurate written
inventories of wastes managed in containers.
Special requirements for ignitable or reactive wastes - requires the
permittee to store ignitable or reactive wastes at least 50 feet from the
property line and to implement procedures, usually those presented in
Section F of the permit application, to prevent fires and explosions
involving these materials.
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-19
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Special requirements for incompatible wastes - requires the permittee to
segregate incompatible wastes and to implement procedures, usually those
presented in Section F of the permit application, to prevent commingling of these
materials.
Tanks
Design standards - requires that tanks comply with applicable design standards,
such as American Petroleum Institute (API) 650 or American Society of
Mechanical Engineers (ASME) Pressure Vessel Code Section VIII.
Permitted and prohibited wastes - the permit typically specifies by name and
waste code the list of wastes that can be managed in the tank system and wastes
that are expressly prohibited.
Waste volume - the permit usually specifies the maximum quantity of waste that
may be placed in each storage or treatment unit at any one time.
Operation and maintenance - compels the permittee to operate and maintain
the tanks in accordance with approved procedures, usually those presented in
Section D of the permit application, and to prevent spills, overflows, or other
types of releases from the tanks.
Response to leaks or spills - compels the permittee to take specific response
actions to leaks or spills, including reporting.
Waste compatibility - requires the permittee to place only those wastes that are
compatible with construction materials into tank systems.
Containment system - requires the permittee to maintain containment systems
that meet retention volume and compatibility requirements of 40 CFR Part
264.193.
Inspection program - requires the permittee to implement an approved program
of tank system inspections, including tank integrity assessments and certifications.
Recordkeeping - requires the permittee to place the results of waste analysis
and compatibility tests in the operating record and to maintain accurate written
inventories of wastes managed in the tank system
Special requirements for ignitable or reactive wastes - requires the
permittee to store ignitable or reactive wastes a protective distance from
the property line; to comply with National Fire Protection Association
(NFPA) requirements; and to implement procedures, usually those
presented in Section F of the permit application, to prevent fires and
explosions involving these materials.
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-20
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Special requirements for incompatible wastes - requires the permittee to
segregate incompatible wastes and to implement procedures, usually those
presented in Section F of the permit application, to prevent commingling of these
materials.
Examples: Lois incorporated the above tank and container requirements in preparing permit
conditions for the AGC facility (see Attachment L). In this case, EPA Region 7
elected to use the incorporation-by-reference approach. Referring to the
example, observe that nearly every paragraph begins with "The Permittee shall
operate and maintain the in accordance with 40 CFR 264, Subpart..." By
utilizing the approach, EPA Region 7 made this section of the permit
comprehensive, yet concise.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-21
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
5.0
DEVELOPING PERMIT CONDITIONS
Regulations:
Guidance:
Explanation:
Check For:
Example Situation:
40 CFR Parts 266.102 and 266.103
40 CFR Part 270.32
No specific references are applicable to this section of the manual.
Limits on operating conditions fall into three groups of parameters, as follows:
• Group A. Permit limits for control parameters that are critical to system
performance are established on the basis of trial burn results and are
interlocked with the automatic waste feed cutoff (AWFCO) system
• Group B. Control parameters for which permit limits are established on
the basis of trial burn results but are not interlocked with the AWFCO
system
• Group C. Control parameters for which permit limits are established on
design considerations, good engineering practices, and equipment
manufacturers' recommendations; some Group C parameters may be
interlocked with the AWFCO system
The following subsections, 5.1 through 5.3, explain how these conditions are
established.
Q Evaluating trial burn data
Q Permitting approaches
Q Developing permit limits
AGC burns hazardous wastes in two cement kilns at Chanute, Kansas. The
principal components of the waste combustion trains are feed systems, rotary
kilns, and electrostatic precipitators. In the AGC kiln permit, Clark included
operating limits for the following Group A, B, and C parameters (see
Attachment M):
Group A
• Carbon monoxide (CO) in stack gas
• Total hydrocarbons (THC) in stack gas
• Minimum combustion temperature
• Maximum combustion temperature
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-22
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• Maximum feed rate of pumpable hazardous waste
• Maximum total feed rate of hazardous waste
• Maximum feed rate of dry raw material (surrogate for maximum
production rate)
• Maximum stack gas flow rate
• Minimum electrical power to electrostatic precipitator (ESP)
• Maximum ESP inlet temperature
Example Action:
Group B
• Maximum metals feed rates
• Maximum chlorine (C12) feed rate
Group C
• Minimum kiln differential pressure
• Maximum firing hood pressure
In Exhibit 5.0-1, (see page 7-24), the rationale for stipulating the permit conditions
listed above (for example, "required by regulation" or "needed to maintain
process control") and the basis for the limits (trial burn results, engineer
judgment, regulatory mandate, manufacturers' recommendations) are provided.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-23
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.0-1
PERMIT CONDITION RATIONALE AND BASIS
Condition
Group A — Maximum CO in stack
gas
Group A — THC in stack gas
Group A — Minimum combustion
temperature
Group A — Maximum combustion
temperature
Group A — Maximum feed rate of
pumpable hazardous waste
Group A — Maximum total feed rate
of hazardous waste
Group A — Maximum feed rate of
dry raw materials
Group A — Maximum stack gas
flow rate
Group A — Minimum electrical
power to ESP
Group A — Maximum ESP inlet
temperature
Group B — Maximum C12 feed rates
Group B — Maximum metals feed
rates
Group C — Maximum kiln
differential pressure
Group C — Maximum firing hood
pressure
Rationale
Required by regulation
40CFR266.104(c)
Required by regulation
40CFR266.104(c)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Required by regulation
40CFR266.102(e)
Basis
Trial burn results
Trial burn results
Trial burn results
Trial burn results
Trial burn results
Trial burn results
Trial burn results
Trial burn results
Trial burn results
Trial burn results
Trial burn results
Trial burn results
Engineering j udgment
Engineering j udgment
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-24
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
5.1 EVALUATING TRIAL BURN DATA
Regulations:
Guidance:
Explanation:
Check for:
Example:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
The permit writer should thoroughly evaluate all trial burn data, including both
process emissions and operating conditions, before expending substantial time and
effort on developing permit conditions. This evaluation should be based on a
disciplined systems perspective and designed to accomplish two primary
objectives:
• Highlight underlying trends and variability in the trial burn data
• Uncover interdependencies and causal relationships between process
operating conditions and emissions
As a first step in this evaluation, the permit writer should plot all available process
operating and emissions data to provide visual insights into data trends, variations,
and relationships. There may be instances where the facility can provide these
data plots so that the permit writer need not be responsible for generating them.
This issue should be discussed and resolved as part of trial burn plan
deliberations.
It is recommended that data be plotted in as many formats as appropriate and as
time permits. For example, it may be beneficial to plot combustion chamber
temperature against time to evaluate temporal variation in that parameter and
against stack gas carbon monoxide to evaluate correlations between combustion
chamber temperature and PIC formation rates. Data plots should be checked
for:
Q Variations over time
Q Patterns or trends
Q Process stability
Q Relationships between parameters
Lois reviewed the trial burn report prepared by XYZ Chemical Co. for its waste
burning boiler. Lois plotted the combustion chamber temperatures measured
during the three runs of the risk burn as shown in Exhibit 5.1-1 (see page 7-27).
Upon reviewing the plots, Lois noted the following:
• Combustion temperature was relatively constant during Runs 1 and 2
• Combustion temperature trended steadily upward throughout Run 3
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-25
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Lois then constructed control charts as shown on Exhibit 5.1-2 (see page 7-28),
using plus or minus (+/-) 2 standard deviations as the upper and lower control
limits. Referring to these charts, Lois determined the following:
• All data points were within the control limits during Runs 1 and 2,
indicating the boiler process was "under control."
• Large segments of the data plot corresponding to Run 3 were outside the
control limits, indicating the boiler process was "out of control."
Lois speculated that the third run was not representative of "normal operations"
— an underlying requirement for the risk burn. As a follow-up, she examined
the boiler operators' logbook and noted that the operators experienced
problems with the programmable logic controller during the third run. Upon
interviewing operators and maintenance personnel, Lois was told that the
controller had been in service for 3 years and had never failed before. With all
of this information in mind, Lois concluded that the third run was not
representative of normal operations. She invalidated the third run and required
XYZ Chemical to repeat the third run of the risk burn.
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-26
-------
E-
3
W
I
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.1-1
COMBUSTION TEMPERATURES OVER TIME
RUN #1
fa 1700
1650
1600
fa 1700
E- 1650
1600
fa 1700
1650
1600
RUN #2
RUN #3
2 3
RUN TIME (Hours)
2 3
RUN TIME (Hours)
2 3
RUN TIME (Hours)
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-27
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
p 1650 -
W
oi
W
§ 1610 —
p 1650 -
w
2
D
P-,
W 1610 —
E-
(
1710 -
^ 1690 —
S 1670 —
E-; 1650 —
g 1630 —
CL,
S 1610 —
W
H 1590 -
1570 -
C
EXHIBIT 5.1-2
COMBUSTION TEMPERATURES CONTROL CHARTS
RUN #1 Mean - 1630" F
Std. Dev. = 8°F
^^"~~~ ~^\ ^^~~~ "~~\ ______ "^~~~X, rs^~~- -^ ^-— -^ /^^"^
LCL 1614°F
) 1 23 4 5
RUN TIME (Hours)
RUN #2 Mean = 1630° F
Std. Dev. = 8°F
^~~ /^\ --^" ^x ^^^^\ / \ /
) 1 23 4 5
RUN TIME (Hours)
RUN #3 Mean = 1655° F
Std. Dev. = 15°F /~
r~"
— ^~~~~~ — UCL 1685"F
^ ^> S- M ean
?/— LCL 1652°F
/^~~''"-.~/
/
/^'"•-^
/
12345
RUN TIME (Hours)
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-28
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
5.2 SELECTING THE PERMITTING APPROACH
Regulations:
Guidance:
Explanation:
Approaches:
Examples:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
Three basic permitting approaches exist for a hazardous waste combustion unit
facility. The approach is selected based on the complexity of the system being
permitted and the desired flexibility of operation.
The following is a discussion of three basic approaches.
Basic Permitting Approach
• Single Point. This approach, which is the least complex of the three, is
adopted when there is a single type of waste feed and a single set of
operating conditions is acceptable. This approach is used most
frequently for boilers and liquid-injection incinerators that have a single
waste feed stream or only a few chemically similar waste feed streams.
• Multiple Point. This approach is adopted when there are multiple types
of waste feeds and multiple operating conditions. This approach is used
frequently for rotary kiln hazardous waste incinerators and cement kilns
that are burning combinations of chemically dissimilar liquid and solid
wastes.
• Universal. This approach is adopted when there are multiple types of
wastes burned and a single set of operating conditions is appropriate.
Permit conditions under this approach are based on the results of testing
during the trial burn with "worst-case" waste mixtures and operating
conditions. This approach has been used to permit rotary kiln
incinerators, hearth furnaces, and other types of incinerators and BIF
units.
Single-Point Approach. In the American Envirotech, Inc. (A.I.) permit, Clark
included a schedule of AWFCO limits that are predicated on the single-point
approach (see Exhibit 5.2-1, see page 7-31). The A.I. incineration train,
consisting of a rotary kiln and a secondary combustion chamber (SCC), was
designed to burn a relatively homogeneous blended hazardous waste which, for
all practical purposes, is a single waste feed stream. Cutoff limits specified in
Exhibit 5.2-1 (see page 7-31) apply to that single waste stream.
Multiple-Point Approach with Rolling Averages. In the ANCDF draft permit,
Lois used a multiple-point permitting approach in the section dealing with the
liquid injection incinerator (PIC), which will burn six different liquid materials.
Exhibit 5.2-2 (see page 7-32) prescribes separate feed rate limits for each of
these materials.
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-29
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Universal Approach with Both Rolling Average and Instantaneous Limits. The
AGC kilns at Chanute, Kansas, burn a variety of solid and liquid hazardous
wastes. In the AGC permit, Clark included AWFCO limits that were formulated
using the universal approach (see Exhibit 5.2-3, see page 7-33). Note that the
limits do not discriminate between various liquid and solid wastes based on waste
codes, heat value, chemical composition, or other parameters.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-30
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.2-1
WASTE FEED CUTOFF LIMITS FOR AMERICAN
ENVIROTECH, INC.—SINGLE-POINT APPROACH
The following conditions will automatically cut off all waste feeds to this kiln and the secondary combustion chamber.
incineration train will work independently for cutoff purposes.
Each
Parameter
Cutoff Limit
Period*
Secondary combustion chamber
(SCC) exit temperature
< 1,800 degrees Fahrenheit (°F) rolling hourly average
< 1,750°F for any 60-second period
< 1,750°F rolling hourly average
< 1,700°F for any 60-second period
Loss of the flame in the SCC Both fire eyes indicating loss
Combustion zones
air pressure
SCC air pressure
> Atmospheric pressure for any
60-second period
< 2 inches of water for any 60 seconds
n
n
i, n, m
i, n, m
i, n, m
SCC differential
atomizing pressure
Air and
Steam
Volumetric flow rate
Carbon monoxide concentration
in the stack
Oxygen concentration in the stack
Quench chamber outlet gas
Temperature
Water flow rate
< 20 pounds per square inch gauge (pig) for any 60 seconds
< 20 pig for any 60 seconds
> 97,000 cubic feet per minute (cfm) at 185°F and 14.7 pounds
per square inch absolute (pia) measured at the stack for
Any 60 second period
> 100 parts per million by volume (ppmv) rolling hourly average
> 125 ppmv rolling hourly average
> 1,000 ppmv at any time
< 3 percent dry volume basis at any time
> 230°F at any time
< 100 gallons per minute (gpm) for any 60 seconds
I, II, HI
I, II, HI
i, ii, m
n
i, n, m
i, n, m
i, n, m
i, n, m
Crossflow scrubber
Flow rate
Inlet scrubber pH
< 100 gpm for any 60 seconds
< 5.0 for any 60 seconds
I, II, HI
I, II, HI
Tandem nozzle scrubber
Pressure drop
Flow rate
< 35 inches of water for 30 seconds
< 100 gpm for 60 seconds
I, II, HI
I, II, HI
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-31
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Natural gas pressure < 2 ounces I, II, HI
Notes: Period I = Shakedown
Period II = Trial burn
Period HI = Post-trial burn
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-32
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.2-2
MAXIMUM FEED RATES TO THE ANCDF LIQUID INJECTION INCINERATOR
MULTIPLE POINT APPROACH
Description of Hazardous Wastes
Surrogate
Chemical Agents:
VX
GB
HD
HT
Decontamination Solution and
Monitoring Support Building and
Laboratory,
Aqueous Liquid Wastes:
Surrogate
Chemical Agents:
VX
GB
HD
HT
Decontamination Solution and
Monitoring Support Building and
Laboratory,
Aqueous Liquid Wastes:
Shakedown/Maximum Post-Trial
Burn Hourly Rolling Average
1,015 Ibs/hour
675 Ibs/hour
1,015 Ibs/hour
1,290 Ibs/hour
1,175 Ibs/hour
2,000 Ibs/hour
Shakedown/Maximum Post-Trial
Burn One-minute Average
(Hourly/60)(l.l)
19 Ibs/minute
13 Ibs/minute
19 Ibs/minute
24 Ibs/minute
22 Ibs/minute
37 Ibs/minute
Trial Burn Hourly Rolling
Average
1,015 Ibs/hour
675 Ibs/hour
1,015 Ibs/hour
1,290 Ibs/hour
1,175 Ibs/hour
2,000 Ibs/hour
Trial Burn One-minute Average
(Hourly/60)(l.l)
19 Ibs/minute
13 Ibs/minute
19 Ibs/minute
24 Ibs/minute
22 Ibs/minute
37 Ibs/minute
Notes:
Ibs/hour = pounds per hour
Ibs/minute = pounds per minute
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-33
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.2-3
WASTE FEED CUTOFF LIMITS FOR ASH GROVE CEMENT—UNIVERSAL APPROACH
OPERATING
PARAMETER
Carbon monoxide
Total hydrocarbons
Combustion temperature
Combustion temperature
Pumpable hazardous waste
Total hazardous waste feed
Dry raw material feed
Stack flow
ESP power
Kiln differential pressure
Firing hood pressure
ESP inlet temperature
OPERATING
CONDITION
Greater than 600 ppmv
(HRA 7% Oxygen dry
basis)
Greater than 20 ppmv
(HRA, 7% dry basis)
Less than 1, 622 °F (HRA)
Greater than 2,052 °F
(HRA)
Greater than 5.1 tons per
hour (tph) (HRA)
Greater than 7.1 tph (HRA)
Greater than 65 or less than
42 tph (HRA)
Greater than 1.07 relative
flow (HRA)
Less than 44.1 kVA (HRA)
Greater than -1 .0 in. w.c.
Greater than 0.01 in. w.c.
Greater than 388°F (HRA)
RESPONSE TO
DEVIATION FROM
OPERATING
CONDITION
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
Immediate AWFCO
LOCATION OF
MONITORING DEVICE
Duct between ESP and
exhaust stack
Duct between ESP and
exhaust stack
Chain section gas inlet
temperature
Chain section gas inlet
Hazardous waste feed line
on burner floor
Hazardous waste feed line
on burner floor and container
feed
Raw material slurry feed line
Induced draft fan
ESP voltage controller
Pressure taps at feed end
and burner hood
Pressure tap at burner hood
ESP inlet
Notes:
AWFCO = Automatic waste feed cutoff
ESP = Electrostatic Precipitator
HRA = Hourly rolling average
kVA = kilovolt Ampere
w.c. = Water column
ppmv = parts per million by volume
°F = degrees Fahrenheit
tph = tons per hour
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-34
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
5.3
DEVELOPING PERMIT LIMITS
Regulations:
Guidance:
Explanation:
Permit Limits:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
Permit limits for control parameters may be established based on instantaneous
values, rolling average values, or combinations of both. The permit writer should
understand, however, that the use of rolling averages requires that the facility be
equipped with a digital process monitoring and recording system. Facilities that
use only pneumatic or other analog-type instrumentation may not be capable of
managing process monitoring data in a manner that permits rolling average
computation.
The following is a discussion of the three basic approaches to developing
permit limits.
• Instantaneous. Recommended for control parameters that are not
subject to fluctuations in excess of 10 percent of the mean value. Use of
instantaneous limits for control parameters with greater variations will
result in excessive AWFCO events. The pressure within the primary
combustion chamber (PCC) of a typical rotary kiln incinerator system is
an example of a control parameter suited to instantaneous limits.
• Rolling Average. Recommended for control parameters that experience
variations in excess of 10 percent of the mean values. Examples include
primary combustion zone temperature and CO concentrations in stack
gases. The most common averaging period is 1 hour, although 24-hour
and even yearly averages have been specified. Yearly averages are
especially useful in limiting emissions of contaminants of concern to the
indirect risk assessment (for example, carcinogenic metals and
polychlorinated dibenzo(p)dioxins and poly chlorinated dibenzofurans
[PCDD/PCDF]). When yearly averages are used to control risks, the
yearly average limits are imposed in addition to instantaneous or other
rolling average limits.
• Combinations of Instantaneous and Rolling Average. Occasionally, the
permit writer may elect to limit a control parameter on both an
instantaneous and rolling average basis. The charge rate and batch size
of solid waste fed to a rotary kiln is one parameter that is frequently
limited in this manner.
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-35
-------
Check For:
Examples:
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
The following subsections, Section 5.3.1 through 5.3.5, explain how to develop
permit conditions for Group A, B, and C parameters using various types of limits:
Q Establishing feed rate limits for metals
Q Translating trial burn results into permit limits, Group A and B parameters
Q Establishing operating limits for Group C parameters
Q Translating risk assessment results into permit conditions
Q Using risk burn data to set risk-based permit conditions
Attachment N contains process monitoring data collected during three runs of a
recent trial burn. The recorded data are 60-second averages. Observe that the
PCC temperature was relatively steady throughout all three runs. Given that
observation, it would be appropriate to use these 60-second averages to
formulate permit limits for the primary combustion chamber temperature as
follows:
Minimum PCC temperature =
average of the lowest 60-second average
temperature recorded in each of the three runs.
2050.30 + 2045.5 + 2007
3
2034.26°F
The minimum permitted PCC temperature would thus be 2035 °F.
Maximum PCC temperature =
average of the highest 60-second average
temperature recorded in each of the three runs.
2146.50 or 2166.8+ 2126.3
3
2146.53°F
The maximum permitted PCC temperature would thus be 2146°F.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-36
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
5.3.1 Establishing Feed Rate Limits for Metals
Regulations: 40 CFR Parts 266.106
Guidance:
Explanation:
Example:
U.S. EPA, 1992. "Technical Implementation Document (TID) for EPA's BIF
Regulations." EPA-530-R-92-011, pp. 2-2 to 2-18 and 10-14 to 10-19.
A hazardous waste combustion unit is subject to feed rate limits for both
noncarcinogenic and carcinogenic metals. The first step in establishing feed rate
limits for metals is to comply with the metals emissions standards of 40 CFR
Part 266.106 using the Tier I, adjusted Tier I, Tier II, or Tier III approach. Tier I,
adjusted Tier I, and Tier III are more commonly used. Tier II is seldom used and
is not discussed further in this section.
Under the Tier I approach, all metal fed to the unit is assumed to be emitted from
the stack. No stack sampling for metals or dispersion modeling is required. Tier
I is normally used when low levels of noncarcinogenic metals are present in the
waste.
Adjusted Tier I assumes no metals removal by the system but requires site-
specific dispersion modeling that accounts for plume dispersion. No stack
sampling for metals is required. Adjusted Tier I is commonly used when
relatively high levels of metals are present in the waste.
Under Tier III, stack sampling for metals and site-specific dispersion modeling
are required. Predicted maximum ground level air concentrations of metals are
compared to health-based standards to demonstrate that acceptable ambient
levels are not exceeded. Tier III is used when high levels of carcinogenic metals
are present in the waste and the facility is not eligible for Tier I (narrow valley,
high terrain rise, or nearby large body of water, for example.). It should be noted
that facilities will frequently pursue a Tier I or Adjusted Tier I approach for
noncarcinogenic metals (antimony, barium, lead, mercury, nickel, selenium, silver,
and thallium) and a Tier III approach for carcinogenic metals (arsenic, beryllium,
cadmium, chromium).
The feed rate screening limits established using the approaches outlined above
are based on health standards that account only for inhalation risks. As such,
they may not be consistent with limits that account for multiple pathways of
exposure. To establish limits based on multipathway risks, the Tier I, adjusted
Tier I, Tier II, and Tier III feed rate limits are subjected to further evaluation as
described in Section 5.3.4
Metal Feed Rate Limits, XYZ Chemical Co.
Air
Natural Gas
Waste
Boiler
ID Fan
Stack
Boiler Flow Diagram
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-37
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Background: Noncarcinogenic metals in the waste feed are antimony, barium, lead, mercury,
silver, and thallium. Carcinogenic metals in the waste feed are arsenic, cadmium,
chromium, and beryllium.
Stack gas flow rate = 22,250 cfm =10.5 cubic meters per second (m3/sec)
Stack height = 66 feet ~ 20 meters
Stack gas temperature = 188°F ~ 360 degrees Kelvin (°K)
Surrounding terrain is flat (noncomplex)
Surrounding land use is urban
Scenario 1: XYZ is pursuing Tier I for noncarcinogenic and carcinogenic metals.
TIER I FEED RATE SCREENING LIMITS FOR
NONCARCINOGENIC METALS
Step 1 - Compute Effective Stack Height (ESH) and Terrain Adjusted Effective
Stack Heigh (TAESH)
ESH = Ta +Ti
Where Ta = actual stack height, 20m
Ti = plume rise
Ti, plume rise is obtained from 40 CFR 266 Appendix VI (see
Exhibit 5.3.1-6, page 7-46) (intersection of 10.5 m3/sec and 360°K) 10m
ESH = 20m + 10m = 30m
TAESH = ESH - Tr
Where Tr = terrain rise within 5 km
Tr = terrain rise - 0 (flat, noncomplex)
TAESH Tr = 30 m - 0 = 30m
Step 2 - Determine Feed Rate Screening Limits
refer to 40 CFR 266 Appendix I, Table 1-A (see Exhibit 5.3.1-3,
pages 7-43), feed rate screening limits (FRSL) are as follows:
Antimony 300 grams per hour (g/hr)
Barium 50,000 g/hr
Lead 90 g/hr
Mercury 300 g/hr
Silver 3,000 g/hr
Thallium 300 g/hr
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-38
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
TIER I FEED RATE SCREENING LIMITS FOR CARCINOGENIC METALS
TAESH remains 30m
from Table 1-D (see Exhibit 5.3.1-3, page 7-43) FRSL are as follows:
Arsenic 2.3 g/hr
Cadmium 5.4 g/hr
Chromium 0.82 g/hr
Beryllium 4.0 g/hr
but the sum of ratios of actual feed rates (APR) to FRSL must be less
than or equal to 1
E (AFR/FRSL,) < 1
see table below:
Scenario 2:
Metal
Arsenic
Cadmium
Chromium
Beryllium
AFR*
0.575
1.20
0.18
0.90
FRSL
2.30
5.40
0.82
4.00
Sum
AFR/FRSL
0.25
0.22
0.22
0.23
0.92
*The facility provided the actual feed rates.
XYZ Chemical Co. pursues Tier III limits for all metals.
Step 1 - Conduct trial burn, measure metals in waste feed and stack emissions.
Step 2 - Conduct dispersion modeling, determine dispersion coefficient, and
calculate ambient concentrations of metals at the maximum exposed individual
(MEI) (see Exhibit 5.3.1-1, page 7-41).
Noncarcinogenic Metals
Step 3 - Compare the predicted ambient concentrations of noncarcinogenic
metals to the reference air concentrations (RACs) in 40 CFR 266 Appendix IV
(see Exhibit 5.3.1-4, page 7-44).
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-39
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Step 4 - If ambient concentrations are less than RACs, feed rate limits for
noncarcinogenic metals are the metals feed rates measured during the trial burn
(see table below).
Metal
Antimony
Barium
Lead
Mercury
Silver
Thallium
Feed Rate
During Trial
Burn
(g/hr)
500
1,000
300
400
50
75
Ambient Air
Concentration
Predicted by Model
micrograms per cubic
meter
(Hg/m3)
0.050
1.200
0.010
0.005
0.200
0.001
RAC
jig/m3)
0.30
50.00
0.09
0.30
3.00
0.50
Tier III Feed
Rate Limit
(g/hr)
500
1,000
300
400
50
75
Carcinogenic Metals
Step 3 - compare the predicted ambient concentrations of carcinogenic metals to
the risk specific doses (RSDs) in 40 CFR 266 Appendix V (see Exhibit 5.3.1-5,
page 7-45).
Step 4 - feed rate limits for carcinogenic metals are the metals feed rates
demonstrated during the trial burn provided the sum of the ratios of ambient
concentrations to RSDs does not exceed 1 (see table below).
Metal
Arsenic
Beryllium
Cadmium
Chromium
Feed Rate
During
Trial Burn
(g/hr)
5
1
3
4
Ambient Air
Concentration
Predicted By
Model (fig/m3)
0.0005
0.0012
0.001
0.0001
RSD
(Hg/m3)
0.0023
0.0042
0.0056
0.00083
Sum
Ambient/
RSD
0.217
0.286
0.179
0.120
0.802
Tier III
Feed Rate
Limit
(g/hr)
5
1
3
4
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-40
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EPA guidance suggests that feed rate limits may be extrapolated or interpolated
from emissions measurements during the trial burn. If a facility, for example, did
not spike metals during the trial burn and measured emissions were several
orders of magnitude below the maximum levels allowed under Tier III (very low
ratios of predicted ambient air concentrations to RACs or RSDs), extrapolation
upward may be allowable. However, if a facility spikes metals during the trial
burn and the metals emissions are above Tier III limits, extrapolation downward
of metals feed limits is discouraged. The reader is referred to the BIF TID
guidance (pp. 10-14 through 10-19) for more information on extrapolation and
interpolation of trial burn emissions measurements.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-41
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.1-1
MAXIMUM EXPOSED INDIVIDUAL
PREVAILING WIND
POINT OF PREDICTED
MAXIMUM GROUND
LEVEL CONCENTRATIONS
OF HAZARDOUS CONSTITUENTS
MEI
300m
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-42
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.1-2
APPENDIX I, TABLE 1-A
APPENDIX I TO PART 266—TIER I AND TIER II FEED RATE AND EWSSIONS SCREENING LIMITS FOR METALS
TABLE 1-A—TiER I AND TIER II FEED RATE AND EMISSIONS SCREENING LIMITS FOR NONCARCINOGENIC METALS FOR FACILITIES IN NONCOMPLEX
TERRAIN
[Values for urban areas]
Terrain adjusted eff. stack hi, (m)
4
6
8 ,
10
12 „., ,
14 ,„. , , ,
16
18
20
22
24 ,
26
28 ,
30
35 , „
40
45
so ,...
55
60
65 .._
70 ,.....,» ,.„
75 „ _ , „
80
85 „
90
95 ,.
too
105
1 1 0 ,
1 1 5
120
Antimony (
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.1-3
APPENDIX I, TABLE 1-D
TABLE l-D—TIER I AND TIER II FEED RATE AND EMISSIONS SCREENING LIMITS FOR CARCINOGENIC METALS FOR FACILITIES IN NONCOMPLEX
TERRAIN
Values for use In urban areas
Terrain adjusted eff. stack ht, (m)
4
e
8 , , ,
10
12 ,
14 ......
16 ....
18
20
22
24
26 ,
28
30
35 „.,
40 ,
45
50 ,
55
60 ,
65
70
75 „ ,
80 ...
85
90
95
too
105
110
1 1 5
120
Arsenic (g/hr)
4 6E • 01
5.4E-01
6.0E-01
6.8E-Q1
7.6E-01
B.6E 01
9.6E-01
1.1E+OO
1 2E+00
1.4E+OO
1.6E+00
UE+OO
2.0E+00
2.3E+OG
3,QE-rtO
3.6E+00
4.6E+00
6.0E+00
7.6E+QQ
9.4E+QO
1.1E+01
1.3E-M31
1.5E-rt1
1.7E+01
1.9E+01
2.2E-f01
2.5E+01
2JE+01
3.2E+01
3.6E-M31
4.QE+01
4.6E+01
Cadmium (g/hr)
1 1E4-00
1.3E+00
1.4E+-00
1.6E+-00
1.8E+QO
2.1E+OO
2.3E+OQ
2.6E+00
3.0E+00
3.4E+OQ
3.9E+00
4.3E+QO
4.8E+QO
5.4E44W
6,8E-tOO
9.0E+QO
1.1E441
1.4E+«1
1.8E^1
2.2E+Q1
2.8E+01
3.1E+01
3.6E+01
4.0E+01
4.6Ert1
5.0E+01
5.8E+01
6.8E+01
7.6E+01
8.6E+01
9.6E+01
1.1E-rt2
Chromium (g/hr)
1 7E-01
1.9E-01
2.2E • 01
2.4E • 01
2.7E • 01
3.1 E 01
3.5E-O1
4.0E-O1
4.4E-01
S.OE-01
S.8E-01
6.4E-01
7.2E-01
B.2E-01
1.0E-i<30
LSE'fOO
1.7E+00
2.2E+00
2.7E+00
3.4E+00
4.2E+00
4.6E+00
5.4E+00
i.OE-i-00
6.BE-I-00
7.8E+00
9.0E-I4X5
1.0E+01
1.1E+01
13E+01
1.5E+01
1.7E-I431
Beryllium (g/hr)
82E-O1
9.4E • O1
1.1E+OO
1.2E+00
1.4E+00
1.5E+00
1.7E+00
2.0E+00
2.2E+OO
2.5E+OQ
2.8E+OO
3.2E+00
3.8E+00
4.0E+00
5.4E+00
6.8E4-00
e.eE+oo
1.1E-I-01
1.4E+01
1.7E4-01
2.1E4-01
2.4E4-01
2JEt01
3.0E-I-01
3.4E4-01
3.9E4-01
4.4E+01
5.0E+01
5.6E+01
6.4E*01
7.2E+01
8.2E+01
Arsenic (gftir)
2.4E-01
2.BE-01
3 2E • 01
3.6E-01
4.3E-01
5 4E • 01
6 8E • 01
8.2E-01
1.0E+OO
1.3E+OO
1.7E+QO
2.1E-I-00
2.7E-I-00
3.5E+00
5.4E+00
8.2E+CX3
1.1E+01
1.SE-I-01
2.0E-I-01
2.7E401
3.6E-t01
4.3E401
5.0E+01
6.0E+01
7.2E+Q1
8.6E+01
1.0E+02
1.2E+02
1.4E+02
1.7E402
2.0E4-02
2.4E-(-ffi
Cadmium (g/hr)
5 BE- O1
6.6E-01
7.6E - 01
8.6E • 01
1.1E+QO
1.3E+OO
1 6E+OO
2.0E4-00
2.5E-MM
3.2E-I
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.1-4
APPENDIX IV
[56 FR 32691, July 17, 1991]
APPENDIX IV TO PART 266—REFERENCE AIR
CONCENTRATIONS*
APPENDIX IV TO PART 266—REFERENCE AIR
CONCENTRATIONS*—Continued
Constituent
AcetakJehyde
Acetonitrite
Acetophenone
Acrolein „.,„„..„.,
Aldicarb ,
Aluminum Phosphide
Allyl Alcohol
Antimony .....
Barium
Barium Cyanide
Bromornethane ,
Calcium Cyanide .,
Carbon Disulflde
Chloral
Chlorine (free)
2-Cnloro-1 ,3-butadlene
Chromium lit
Copper Cyanide
Cresols
Cumene
Cyanide (free)
Cyanogen _
Cyanogen Bromide
Di-n-butyl Phthaiate „
o-Dichlorobenzene „
p-Dichlorobenzene
Dichlorotllfluoronnethane
2 4-Dicnlorophenol ...
Oiethyl Phthaiate ,
Dimetrioate
2,4-DinKrophenol
Dinoseb
Diphenylamine
Endosulfan
Endrin „
Fluorine „
Formic Acid ..,„ , ,.
Giycidyaldehyde
Hexachtorocyctopentadiene ........
Hexacntorophene .,..„., ,
Hydrocyanic Acid „.„
Hydrogen Chloride
Hydrogen Suifide
Isobutvl Alcohol
CAS No.
75-07-0
75-05-8
98-86-2
107-02-8
116-06-3
20859-73-8
107-16-6
7440-36-0
7440-39-3
542-62-1
74-83-9
592-01-8
75-15-0
75-87-6
126-99-8
16065-83-1
544-92-3
1319-77-3
98-82-8
57-12-15
460-19-5
506-68-3
84-74-2
95-50-1
106-46-7
7S_71_g
120-83-2
84-66-2
60-51-5
51-28-5
B8-85-7
122-39-4
115-29-1
72-20-8
7782-41-4
64-18-6
765-34-4
77_47_4
70-30-4
74-90-8
7647-01-1
7783-06-4
78-83-1
RAC (ug/
m3)
10
10
100
20
1
0.3
5
0.3
50
50
0,8
30
200
2
04
3
1000
5
50
1
20
30
80
100
10
10
200
3
800
0,8
2
09
20
005
0,3
50
2000
03
5
0,3
20
7
3
300
Constituent
Lead ,
Mateic Anyhdride
Mercury
Methacrylonitrile
Mothomy! „..„
Methoxychtor .....
Methyl Cfitorocarbonate
Methyl Ethyl Ketone
Methyl Parathton ,.,...,....
Nickel CyankJe .....
Nitric Oxide
Nitrobenzene
Pentachtorobenzens
Psntaehbrophenol
Phenol
M-Phenylenediamine .,
Phenylmercuric Acetate
Phosphide ,
Phthalte Anhydride
Potassium Cyanide
Potassium Silver Cyanide
Pyridtne
Setentous Acid
Selenourea ...
Silver
Silver Cyanide .,
Sodium Cyanide ...,.,
Strychnine
1 ,2,4,5-Tetrachtorobenzene
2,3,4,6-Tetrachtorophenol
Tetraethyl Lead
Tetrahydrofuran
Thallic Oxide
Thallium
Thallium (1) Acetate
Thallium (1) Carbonate
ThalBum (1) Chloride
Thallium (I) Nitrate
Thallium SelenRe
Thallium (1) Sulfate
Thiram
Toluene
1 ,2,4-Trichlorobenzene
Trfcnloromonofluoromethane
2,4,5-Trtehlorophenol
Vanadium Perrtoxide
CAS No.
7439-92-1
108-31-6
7439-97-6
126-96-7
11752-77-5
72-43-5
79-22-1
78-93-3
298-00-0
557_1 9-7
10102-43-9
98-95-3
608-93-5
87-86-5
108-95-2
108-45-2
62-38-4
7803-51-2
85-44-9
151-50-6
506-61-6
110-86-1
7783-60-8
630-10-4
7440-22-4
506-64-9
143-33-9
57-24-9
95-94-3
58-90-2
78-00-2
109-99-9
1314-32-5
7440-28-0
563-68-8
6533-73-9
7791_12-0
10102-45-1
12039-52-0
7446-18-6
137-26-8
108-88-3
120-82-1
75-6M
95-95-4
1314-62-1
RAC (ug/
ma)
0.09
100
03
0 1
20
50
1000
80
0.3
20
100
08
08
30
30
5
0075
03
2000
50
200
1
3
5
3
100
30
0.3
0.3
30
0.0001
10
0.3
05
05
03
03
0.5
05
0075
5
300
20
300
100
20
UJ: EPA Region 6
Center for Combustion Science and Engineering
7-45
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.1-5
APPENDIX V
APPENDIX V TO PART 266—RISK SPECIFIC DOSES (10-5)
Constituent
CAS No,
Unit risk (m3/
ug)
RsD (ug/m3)
Acrylamide , , 79-06-1
Acrylonitrile 107-13-1
Aldrin 309-OO-2
Aniline 62-53-3
Arsenic 7440-38-2
Benz(a)anthraeene 56—55—3
Benxene 71-43-2
Benzidine 92-87-5
Benzo(a)pyrene , , SO—32-8
Beryllium , 7440-41-7
Bis{2-chloroelhyr)ether 111-44—4
Bis(chloromethyl)ether 542-88-1
Bis(2-ethylhexyl)-phthalate 117-81-7
1,3 Butadiene , 1O6-99-Q
Cadmium 744O—43-9
Carbon Tetrachloride 56-23-5
Chlordane 57—74-S
Chloroform 87-66-3
Chloromethane 74-87-3
Chromium VI 7440-47-3
DDT , 50-29-3
Dibenz(a,h)anUiracene 53—7O-3
1,2-Dibromo-3-chloropropane 96-12-8
1,2 Dibromoethane 106-93-4
1,1-Dlehloroethane 75-34-3
1,2-Diehloroethan* , 107-06-2
1.1-Dichloroethytene 75-35-4
t,3-Dtehloropropene 542—75—6
Dieldrin , 60-57-1
DiethylstUbestrol 56-53-1
Dimethylnitrosamine , 62-75-9
2,4-Dinttrotoluene 121-14-2
1.2-Diphenylhydrazine 122-66-7
1,4-Dioxane 123-91-1
Epichlorohydrin 1O6-89-8
Ethyleno Oxkto 75-21-8
Ethylene Dibromide 106-93-4
Formaldehyde 50-OO-O
Heptachlor 76-44-8
Heptachlor Epoxide 1024-57-3
Hexachlorobenzene 118—74—1
Hexachlorobutadiene 87-68-3
Alpha-hexachloro-cydohexane 319—84—6
Beta-hexachloro-cyctohexane 319—85—7
Gamma-hexachloro-cyclohexane 58—89—9
Hoxachlorocyclo-hoxane, Technical
HexacNorodibefixo-p-dioxin{1,2 Mixture)
Hexachloroethane 67-72-1
Hydrazine 302-01-2
Hydrazine Sulfate 302-01-2
3-Methyteholanthrene 56—49-5
Methyl Hydrazine 6O-34-4
Methylene Chloride 75-O9-2
4,4"-Metbytene-bis-2-en(oroantIine 101-14-4
Nickel 744O-02-O
Nickel Refinery Dust 7440-02-O
Nickel Subsulfide 12035-72-2
2-Nitropropane 79_4e_g
2,3,7,8-Tetrachtoro-dibenzo-p-dioxin 1746-O1-6
1,1,2,2-Tetrachtoroethane 79-34-5
Tetrachloroethylene 127—18—4
Thiourea 62-56-6
1,1.2-Trichloroethane 79-OO-5
Trichloroethytene 79-O1-6
2,4,6-Trictilorophenol 88-O6-2
Toxaphene 8OO1-35-2
Vinyl Chloride 75-O1—4
1.3E-03
6.8E-05
4.9E-O3
7.4E • 06
4.3E • 03
8.9E • O4
8.3E • O6
6.7E - 02
3.3E • 03
2.4E-03
3.3E-O4
6.2E-02
2.4E - 07
2.8E-O4
1.8E-03
1.5E-O5
3.7E • O4
2.3E-O5
3.6E-06
1.2E-O2
9.7E-05
1.4E-02
6.3E-03
2.2E-04
2.6E-05
2.6E • 05
5.0E-05
3.5E-O1
4.6E - O3
1.4E • 01
1.4E-02
8.8E • OS
2.2E-04
1.4E • 06
1.2E-06
1.0E-04
2.2E-04
1.3E • OS
1.3E-O3
2.6E-O3
4.9E-04
2.0E • OS
1.8E-03
5.3E-04
3.8E-O4
5.1E-O4
1.3E-I-0
4.OE-06
2.9E-O3
2.9E • 03
2.7E • 03
3.1E-04
4.1E-O6
4.7E-05
2.4E-O4
2.4E-O4
4.8E-O4
2.7E-O2
4.5E+O1
5.8E • O5
4.8E-O7
5.5E.O4
1-6E • OS
1.3E 06
5.7E • O6
3.2E - O4
7.1E-O6
7.7E-03
1 .5E - O1
2.OE-O3
1.4E+00
2.3E - 03
1.1E-02
1.2E+OO
1.5E-O4
3.0E • 03
4.2E-03
3.0E-02
1.6E-O4
4.2E+01
3.6E.02
5.6E - 03
6.7E-O1
2.7E-02
4.3E-O1
2.8E+OO
8.3E - O4
1.0E-01
7.1E-O4
1.6E-03
4.5E-O2
3.8E-01
3.8E - 01
2.OE - O1
2.9E-O5
2.2E-03
7.1 E- 05
7.1E-04
1.1E-O1
4.5E - O2
7.1E+OO
8.3E+OO
1.0E-01
4.5E-O2
7.7E-01
7.7E-03
3.8E.03
2.OE-O2
5.0E-O1
5.6E-03
1.9E-02
2.6E-O2
2.0E-02
7.7E.06
3.4E-O3
3.4E-03
3.7E • 03
3.2E-02
2.4E+OO
2.1E-O1
4.2E-02
4.2E-O2
2.1 E- O2
3.7E-O4
2.2E-O7
1.7E-O1
2.1E+O1
1.8E-O2
6.3E-O1
7.7E+OO
1 .8E+OO
3.1 E- O2
1 .4E-t-OO
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-46
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.1-6
APPENDIX VI
APPENDIX VI TO PART 266—STACK PLUME RISE
[Estimated Plume Rise (in Meters) Based on Stack Exit Flow Rate ami Gas Temperature]
Exhaust Temperature (K°)
Flow rate (m3/s)
<0,5
0.5-0.9
1.(M.9
2.0-2.9 , ,
3.0-3.9 ,
4.0-4.9 , ,.
5.0-7.4
7.5-9.9 , ,.
10.0-12.4
12.5-14.9
15.0-19.9
20.0-24.9
25.0-29.9
30.0-34.9
35.0-39.9
40.0-49.9
50.0-59.9
60.0-69.9
70.0-79.9
80.0-89.9
90.0-89,9 ,
100.0-1 19.9 .,
120.0-139.9
140.0-159.9
160.0-179.9
180.0-199.9
>199.9
<325
0
0
0
0
0
1
2
3
4
4
5
6
7
8
9
10
12
14
16
17
19
21
22
23
25
26
26
325-
349
0
o
0
0
1
2
3
5
6
7
8
10
12
14
16
17
21
22
23
25
26
26
28
30
31
32
33
350-
399
0
o
0
1
2
4
5
8
10
12
13
17
20
22
23
24
26
27
29
30
31
32
35
36
38
40
41
400-
449
0
o
0
3
5
6
8
12
15
18
20
23
25
26
28
29
31
33
35
36
38
39
42
44
46
48
49
450-
499
0
o
1
4
6
8
10
15
19
22
23
25
27
29
30
32
34
36
38
40
42
43
46
48
50
52
54
500-
599
0
o
1
4
7
10
12
17
21
23
24
27
29
31
32
34
36
39
41
42
44
46
49
51
54
56
58
600-
699
0
o
2
6
9
12
14
20
23
25
26
29
31
33
35
36
39
42
44
46
48
49
52
55
58
60
62
700-
799
0
o
3
6
10
13
16
22
24
26
27
30
32
35
36
38
41
43
46
48
50
52
55
58
60
63
65
800-
999
0
1
3
7
11
14
17
22
25
27
28
31
33
36
37
39
42
45
47
49
51
53
56
59
62
65
67
1000-
1499
o
1
3
8
12
15
19
23
26
28
29
32
35
37
39
41
44
47
49
51
53
55
59
62
65
67
69
>1499
o
•)
4
9
13
17
21
24
27
29
31
34
36
39
41
42
46
49
51
54
56
58
61
65
67
70
73
UJ: EPA Region 6
Center for Combustion Science and Engineering
7-47
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
5.3.2 Translating Trial Burn Results Into Permit Limits, Group A and B Parameters
Regulations:
Guidance:
Explanation:
Permit Limits:
40 CFR Parts 266.102 and 266.103
40 CFR Parts 270.32, 270.62, and 270.66
No specific references are applicable to this section of the manual.
Group A parameters are operating conditions of the combustion and APCS that
are critical to achieving of destruction and removal efficiency (DRE) and
emissions limits for CO, PICs, and metals emissions limits. These parameters are
continuously monitored and interlocked with the AWFCO system.
Group B parameters are operating conditions that are neither continuously
monitored nor interlocked with the AWFCO system.
Lists of Group A and B parameters provided below are typical but not
all-inclusive. Group A and B parameters may vary from facility to
facility.
Group A Parameters - May Be Established as Rolling Average or Instantaneous
Limits or Both
• Minimum PCC temperature. Ensures achievement of required DRE
• Maximum PCC temperature. Prevents excessive volatilization of metals
• Minimum SCC temperature. Ensures DRE achievement
• Maximum stack gas CO concentration. Ensures compliance with the
applicable regulatory standard
• Maximum combustion gas volumetric flow rate. Ensures achievement of
DRE
• Maximum hazardous waste feed rate. Ensures DRE achievement and
emissions limits compliance for particulate matter (PM), hydrogen
chloride (HC1), metals, and PICs
• Total pumpable hazardous waste rate. Ensures DRE achievement and
emissions limits compliance for particulate matter, HC1, metals, and PICs
• Maximum solid waste batch and container size. Ensures proper
combustion conditions
• Maximum stack gas THC. Ensures compliance with the applicable
regulatory standard
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-48
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Examples:
• Minimum and maximum device production rate. Ensures proper
combustion conditions
• Maximum flue gas temperature entering a participate matter control
device. Minimizes dioxin/furan formation within the device and ensures
proper participate removal
• Minimum wet scrubber blowdown rate. Ensures proper performance of
wet scrubber and compliance with limits on PM and acid gas emissions
Group B Parameters - May Be Established as Rolling Average or Instantaneous
Limits or Both
• Principal organic hazardous constituent (POHC) Incinerability. Restricts
waste feeds to materials that were represented during the trial burn and
as a result, ensures DRE achievement and emissions limits compliance
for PM, HC1, metals, and PICs
• Maximum chloride content of waste feed. Ensures compliance with
emissions limits on HC1
• Maximum ash content of waste feed. Ensure compliance with limits on
PM and metals emissions (except kilns)
Group A, Limits on Stack Gas Flowrate
The stack gas flowrate is a Group A parameter for which permit limits are
developed based on trial burn results. Upon examining the stack gas flowrate
data in Attachment N, it is apparent this parameter is subject to wide fluctuations.
In the second run, for example, the stack gas flow rate varied from 3,942 to
7,104 actual cubic feet per minute (acfm). This situation calls for a combination
limit, developed as follows:
Mean of 60-second averages in run 1 = 4,941.20 acfm
Mean of 60-second averages in run 2 = 4,926.10 acfm
Mean of 60-second averages in run 3 = 4,927.36 acfm
Average = (4,941.20 + 4,926.10 + 4,927.36)73 = 4,931.55 acfm
Highest 60-second flowrate in run 1 = 7,138.58 acfm
Highest 60-second flowrate in run 2 = 7,104.29 acfm
Highest 60-second flowrate in run 3 = 6,729.11 acfm
Average = (7,138.58 + 7,104.29 + 6,729.11)73 = 6,990.66 acfm
The permit conditions would read as follows:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-49
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
The hourly rolling average (HRA) of the stack gas flow shall not exceed 4,932
acfm. The instantaneous stack gas flow shall not exceed 6,991 acfrn at any time.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-50
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
5.3.3 Establishing Operating Limits for Group C Parameters
Regulations:
Guidance:
Explanation:
Permit Limits:
Examples:
40 CFR Parts 266.102 and 266.103
40 CFR Parts 270.32, 270.62, and 270.66
No specific references are applicable to this section of the manual.
To ensure that combustion system operations adhere to process design
specifications, operating limits for Group C parameters are based strictly on
design and equipment manufacturers' recommendations and not on trial burn
results.
Examples of Group C parameters include:
• Burner settings. Atomization fluid pressure, waste viscosity, and
turndown limits. The limits on these parameters are bounded by
manufacturers' specifications that are intended to ensure proper waste
fuel atomization and combustion.
• Total heat input. Maximum heat input to PCC and maximum
heat input to SCC. These limits are based on manufacturers'
recommendations that are intended to prevent damage to
refractory materials lining the combustion chambers.
• APCS equipment inlet gas temperature. Maximum temperature (for
facilities with wet APCS) of combustion gases entering the APCS.
These limits are based on manufacturers' recommendations which, in
turn, are usually based on the physical properties of the APCS
construction materials. NOTE: This will be an AWFCO for any facility
with a dry APCS.
Clark included Group C parameters in the BIF permit issued by SCDHEC for the
GIF are as follows. These parameters are also used to prevent dioxin formation
in the post-combustion chamber.
• Maximum thermal release from PCC. 22.43 million British thermal units
per hour (Btu)
• Maximum thermal release from SCC. 16.83 million Btu/hr
• Steam atomization pressure to high heating value (HHV) liquid burner.
minimum of 80 psig
• Steam atomization pressure to low heating value (LHV) liquid burner.
Minimum of 80 psig
• Maximum HHV burner turndown ratio. 4 to 1
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-51
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• Maximum LHV burner turndown ratio. 10 to 1
• Quench liquid flow rate. At least 150 gallons per minute (gpm)
• Maximum quench outlet temperature. 210°F
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-52
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
5.3.4 Translating Risk Assessment Results Into Permit Conditions
Regulations: 40 CFR Parts 266.106, 270.32, 270.62, and 270.66
Guidance:
Explanation:
Examples:
No specific references are applicable to this section of the manual.
Results of direct and indirect human health and ecological risk assessments can
affect the final permit. The permit writer has five options for translating risk
assessment results into permit conditions. These are: (1) reduce emissions with
process changes or emissions controls; (2) verification by sampling and
monitoring; (3) eliminating the risk pathway; (4) verifying assumptions in the risk
assessment; and (5) denying the permit if the facility fails the risk assessment and
the permit writer opts against using one or more of the four aforementioned
options.
The permit issued to a commercial hazardous waste incinerator facility contains
examples of the relationship between risk assessment and permit conditions and
the use of the first two options introduced above.
Commercial Hazardous Waste Incinerator
During data review for permit condition preparation, Lois noted that stack testing
during the trial burn in March 1993 indicated that dioxin levels were higher than
expected, although still below risk-based standards. To address this concern,
Lois used the following options:
Option 1—Reduce Emissions/Process Changes. Required the facility to install
an activated carbon injection system for PCDD/PCDF control and implement a
continuing program of performance testing for PCDD/PCDFs.
Option 2—Sampling and Monitoring. Under the performance testing program,
the facility conducted quarterly stack sampling for dioxins for 2 years and annual
sampling thereafter.
On reviewing the trial burn results for metals emissions, Lois became concerned
that the emissions of four metals (barium, mercury, silver, and thallium) may pose
an unacceptable risk to human health and the environment. Her approach to
evaluating this risk and developing protective permit limits was as follows:
Option 1—Reduce Emissions/Limit Feed. Lois used the results of multipathway
risk assessment to develop emission limits for metals in four steps (as
summarized in Exhibit 5.3.4-1, see page 7-54): Step 1, hourly feed rate limits
were calculated based on the direct exposure assessment methods prescribed
under 40 CFR Part 266.106 (see Section 5.3.1 of this component); Step 2,
dispersion, deposition, and bio-uptake modeling were used to determine cancer
risks and hazard indices (HI) based on "maximum permit limit emission"
scenarios presented by the limits derived in Step 1; Step 3 recommended
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-53
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
emissions reduction factors were calculated by reducing the values of the
ecological HI, human health HI, and cancer risks linearly to 1.0, 0.25, and Be-5,
respectively; and Step 4, annual limits on metals emissions were calculated using
reduction factors calculated in Step 2.
Ash Grove Cement, Chanute, Kansas
Clark noted that the indirect risk assessment conducted by a U.S. EPA
contractor indicated a hazard quotient (HQ) from mercury to the recreational
fisherman of 1.52. This HQ was an order of magnitude greater than the target of
<0.25. Aquatic sampling results, however, indicated that actual mercury
concentrations in sediments, water, and fish were not elevated.
Citing the discrepancy between risk assessment modeling and environmental
sampling results, Clark determined that additional controls on mercury emissions
from the cement kilns were not warranted but that he could use
Option 2—Sampling and Monitoring, to require continuing environmental sampling
for mercury. Consequently, Clark compelled AGC to conduct continuing
environmental sampling for mercury under conditions specified in Section A. 15 of
the final permit (see Attachment O).
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-54
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.4-1
CALCULATION OF METALS EMISSIONS REDUCTION FACTORS
Metal
Barium
Mercury
Silver
Thallium
40CFR
266.106 Feed
Rate Limit
(Ib/hr) (1)
473
0.146
15.9
2.65
Possible
Maximum
Emissions
pounds per
year
(Ib/yr) (2)
3,820,000
6,110
229,000
38,200
Ecological
Risk
Assessment
Hazard
Index (3)
41
4.1
5.2
4.250
Human
Health Risk
Assessment
Hazard
Index (4)
1,400
4.3
60
650
Human
Health Risk
Assessment
Cancer Risk
(5)
NA
NA
NA
NA
Reduction
Factor (6)
5,600
17.2
240
4,250
Revised
Emission
Limit (Ib/yr)
(7)
682
355
954
9
Penetration
Factor (8)
0.0023
1
0.0023
0.0023
Revised
Risk-Based
Annual Feed
Rate Limit
(Ib/yr) (9)
296,584
355
414,855
3,908
Notes:
1. Feed rate based on direct risk assessment procedures specified in 40 CFR 266.106 and developed in accordance with procedures
shown in Section 5.3.1 of this component.
2. Possible maximum emissions based on dispersion modeling using feed rate limits discussed above.
3. Indirect risk assessment ecological hazard index. Target <1.
4. Indirect risk assessment human health hazard index. Target <0.25. Target reduced below 1 to ascribe only 25 percent of the
human health risk to this single emissions source, per U.S. EPA 1998 Region 6 risk protocols.
5. Indirect risk assessment human health cancer risk. Target <1 E-5.
6. Reduction factor applied to possible maximum emissions that will reduce ecological and human health risks and cancer risks below
target levels defined above.
7. Possible maximum emissions divided by reduction factor
8. Empirically or theoretically determined metals penetration factor (1 - removal efficiency).
9. Revised emission limit divided by penetration factor.
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-55
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
5.3.5 Using Risk Burn Data to Set Risk-Based Permit Conditions for Operating Parameters
Regulations: 40 CFR Parts 270.30
Guidance:
Explanation:
No specific references are applicable to this section of the manual.
Hazardous waste combustion facilities are required to conduct testing for dioxins,
furan, other organic PICs, and metals to provide input data for multipathway risk
assessments. These data are collected during three runs of a risk burn that may
be conducted under either "worst case" operating conditions equivalent to those
of the traditional DRE burn, or "normal" operating conditions that reflect typical
plant operations.
If the facility elects to conduct the risk burn under normal conditions, the permit
for the facility must contain additional conditions to ensure that long-term
operations are consistent with those represented as normal during the risk burn.
Risk, as defined by the multipathway risk assessment, is a function of the
emission rates of metals and organic constituents from the stack. To determine
the operating parameters that must be subjected to additional risk-based controls,
the permit writer should first, review process information contained in the trial
burn report or permit application, and second, construct Pareto ("fish-bone")
diagrams similar to those shown on Exhibits 5.3.5-1 (see page 7-57) and 5.3.5-2
(see page 7-58) to illustrate correlations and causal relationships between
processing operating parameters and emissions of metals and organic PICs. In
these diagrams, the length of the line is proportional to the known or perceived
strength of the correlation. For example, in Exhibit 5.3.5-2 (see page 7-58), the
emission rate of metals is shown to be strongly correlated to combustion
temperature. The third step is to set risk-based permit conditions for the strongly
correlated parameters based on the risk burn data.
The additional risk-based limits may encompass the following parameters:
• Waste feed rates
• Combustion chamber temperature
• Stack gas velocity
These limits and related permitting approaches are further discussed in
Attachment U, Traditional vs. Risk-Based Permitting Approach: Permit to
Manage Risks, by David Weeks.
One of the areas of focus in the Environmental Appeals Board ruling on the Ash
Grove Cement, Chanute, Kansas, permit supports establishing risk-based
operating limits in the permit. The ruling is included as Attachment V to this
component.
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-56
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Examples:
The risk burn for a boiler was conducted under normal operating conditions. The
combustion temperature, waste feed rate, and stack gas flow rate during the risk
burn were significantly different than those measured during the DRE burn, as
shown in Exhibit 5.3.5-3 (see page 7-59). Referring to the Pareto diagrams in
Exhibits 5.3.5-1 (see page 7-57) and 5.3.5-2 (see page 7-58), Clark decided that
risk-based annual rolling average limits would be imposed on the waste feed rate,
combustion temperature, and stack gas velocity. Annual rolling averages are
defined as the arithmetic mean of all 60-second HRAs in the calendar year.
These additional limits were computed as follows:
Annual Rolling Average Waste Feed Rate
Maximum = arithmetic mean of the highest HRAs recorded in each of the three
risk burn runs
= (16.1 +17.0 + 15.3 lb/min)/3 = 16.1 Ib/min
Annual Rolling Average Combustion Chamber Temperature
Minimum = arithmetic mean of the lowest HRAs recorded in each of the three
risk burn runs
= (1,635 + 1,643 + 1,636 °F)/3 = 1,638°F
Annual Rolling Average Stack Gas Flow Rate
Maximum = arithmetic mean of the highest HRAs recorded in each of the three
risk burn runs
= (22,250 + 22,390 + 21,999 acfm)/3 = 22,213 acfm
The permit writer is referred to the generic permits contained in Attachments C
through F for examples of corresponding permit language.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-57
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.5-1
PARETO DIAGRAM FOR PIC EMISSIONS
PIC Emissions
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-58
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.5-2
PARETO DIAGRAM FOR METALS EMISSIONS
Metals Emissions
// f/ V
r^1/ ^ / */
v v //
V<> \°0 x
\% \\
\* \%
\ /A \ vjl
\ «• \ 0
x ^ \ z
$
Q /
^ /
3i /
V /
\«P0
\ \\
\ V \ V
\ o \
\^
\ %
\ Y
L
\
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-59
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 5.3.5-3
DRE AND RISK BURN PROCESS DATA SUMMARY
PARAMETER
Waste Feed Rate (Ib/min)
Combustion Temperature (°F)
Stack Gas Flow Rate (acfm)
TEST
DRE
DRE
DRE
Risk
Risk
Risk
DRE
DRE
DRE
Risk
Risk
Risk
DRE
DRE
DRE
Risk
Risk
Risk
RUN
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
MIN
22.3
22.5
22.4
13.2
12
11.9
1585
1586
1585
1635
1643
1636
30632
30589
30461
21530
21469
20857
MAX
22.6
22.5
22.4
16.1
17
15.3
1590
1589
1586
1641
1644
1644
3122
31542
31874
22250
22390
21999
AVERAGE
22.5
22.5
22.4
16
15.6
13.8
1586
1586
1586
1640
1643
1643
31111
31099
31258
22201
22254
21865
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-60
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
6.0 COMBUSTION UNIT CONDITIONS
Regulations: 40 CFR Parts 264.345, 266.102, 266.103, 270.21, 270.32, 270.62, and 270.66
Guidance: No specific references are applicable to this section of the manual.
Explanation: To ensure continued compliance with performance standards for DRE and
metals, PM, C12, and HC1 emissions; and to maintain risks to human and
ecological receptors below accepted thresholds, regulations require that the
permit for a hazardous waste incineration facility, or BIF system, specify limits on
key operating parameters. In addition to key operating parameters, the permit
should include requirements for calibration, inspection, and maintenance.
The following subsections, Sections 6.1 through 6.4, describe key limits for the
following units:
• Rotary kilns
• Boilers
• Li quid injection incinerators
• Halogen acid furnaces
Typical Parameters: Operating parameters that are typically addressed and recommended, unless it is
inappropriate for the system or specifically exempted in the permit, are as
follows.
Q Monitoring and inspection procedures
Q AWFCO system testing procedures
Q Waste analysis procedures
Q Allowable waste feed compositions
Q Allowable waste feed rate
Q Allowable chlorine and metals feed rates
Q Device production rate
Q Combustion chamber temperature
Q Combustion gas flow rate
Q Destruction and removal efficiency
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-61
-------
Example:
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Q CO concentration in stack gas
Q Hydrocarbon concentration in stack gas
Q HC1, C12, and metals emissions rates
Q Participate matter emissions rates
Q Maximum flue gas temperature entering a particulate matter control
device
Q Various APCS operating procedures
Q Controls on the firing system
Q AWFCO system settings
Q Calibration of process monitoring instruments
Q Allowable variations in system design or operating procedures
Q Fugitive emissions
In the final permit issued by U.S. EPA in August 1996 for the AGC cement kilns,
Clark included permit conditions for the following operating parameters:
Kiln No. 1
DRE, 99.99 percent
• HC1 emissions from both kilns combined less than 7.79 Ib/hr
• C12 emissions from both kilns combined less than 0.18 Ib/hr
• PM emissions less than 0.08 grains per dry standard cubic foot (gr/dscf)
• Lead emissions from both kilns combined not to exceed 3.18 Ib/hr
• Hexavalent chromium emissions from both kilns combined not to exceed
0.0167 Ib/hr
• Cadmium emissions from both kilns combined not to exceed 0.103 Ib/hr
• Arsenic emissions from both kilns combined not to exceed 0.00962 Ib/hr
• HRA limits on feed rates of C12, arsenic, beryllium, cadmium, chromium,
and lead
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-62
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• Other limits on the composition of waste feed materials
• Annual average feed rates for arsenic, beryllium, cadmium, chromium,
mercury, and thallium
• Maximum HRA of CO in the stack gas not to exceed 600 ppmv
• Maximum HRA concentration of total hydrocarbons in the stack gas not
to exceed 20 ppmv
• Chain section inlet gas temperature not less than 1,622°F and not greater
than 2,052°F on an HRA basis
• Dry raw mix feed rate not to exceed 65 tph on an HRA basis
• Pumpable hazardous waste feed rate not to exceed 5.1 tph on an HRA
basis
• Power to the ESP not less than 44.1 kilovolt ampere (kVA) on an HRA
basis
• ESP inlet gas temperature not more than 388°F on an HRA basis
• Differential pressure between raw material feed hood and firing hood not
greater than 1 inch water column (w.c.) on an instantaneous basis
• Differential pressure to atmosphere at the firing hood not greater than
0.01 inches w.c. for more than 60 continuous seconds
• Relative flue gas flow rate not more than 1.07 on an HRA basis
• AWFCO to activate immediately any time the above operating conditions
are not met while hazardous wastes are present in the kiln
Kiln No. 2
ORE 99.99 percent
• HC1 emissions from both kilns combined less than 7.79 Ib/hr
• C12 emissions from both kilns combined less than 0.18 Ib/hr
• PM emissions less than 0.08 gr/dscf
• Lead emissions from both kilns combined not to exceed 3.18 Ib/hr
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-63
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• Hexavalent chromium emissions from both kilns combined not to exceed
0.0167 Ib/hr
• Cadmium emissions from both kilns combined not to exceed 0.103 Ib/hr
• Arsenic emissions from both kilns combined not to exceed 0.00962 Ib/hr
• HRA limits on feed rates of chlorine, arsenic, beryllium, cadmium,
chromium, and lead
• Other limits on the composition of waste feed materials
• Annual average feed rates for arsenic, beryllium, cadmium, chromium,
mercury, and thallium
• Maximum HRA of CO in the stack gas not to exceed 600 ppmv
• Maximum HRA concentration of total hydrocarbons in the stack gas not
to exceed 20 ppmv
• Chain section inlet gas temperature not less than 1622°F and not greater
than 2052 °F on an HRA basis
• Dry raw mix feed rate not to exceed 65 tph on an HRA basis
• Pumpable hazardous waste feed rate not to exceed 5.1 tph on an HRA
basis
• Power to the ESP not less than 71.0 kVA on an HRA basis
• ESP inlet gas temperature not more than 3 64 °F on an HRA basis
• Differential pressure between raw material feed hood and firing hood not
greater than 1 inch w.c. on an instantaneous basis
• Differential pressure to atmosphere at the firing hood not greater than
0.01 inches w.c. for more than 60 continuous seconds
• Relative flue gas flow rate not more than 0.98 on an HRA basis
• AWFCO to activate immediately any time the above operating conditions
are not met while hazardous wastes are present in the kiln
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-64
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
6.1 ROTARY KILNS
Regulations: 40 CFR Parts 266.102, 266.103, and 264.345
40 CFR Parts 270.32, 270.62, and 270.66
Guidance: No specific references are applicable to this section of the manual.
Explanation: Rotary kilns are commonly used to incinerate hazardous wastes. Experience
with rotary kilns indicates that several control parameters are critical to
achievement of performance standards. These control parameters typically are
addressed as Group A parameters in the permit.
Control Parameters: Common Control Parameters
• Kiln temperature. Maintained high enough for destruction of POHC and
to minimize the formation of PICs, yet low enough to prevent excessive
volatilization of metals
• Kiln pressure. Maintained at negative pressure relative to atmosphere to
prevent kiln fugitive emissions
• Combustion gas velocity. Controlled to ensure proper combustion gas
residence time and destruction of POHC
• Waste feed rate. Controlled to avoid overloading, over-pressuring, and
depleting kiln oxygen (O2) that is critical to POHC destruction
• CO and THC combustion gas concentrations. Monitored to ensure
satisfactory kiln operation and to minimize PIC formation
• Minimum and maximum production rate. Controlled to ensure complete
combustion
• Hazardous waste firing system controls. Controlled to ensure proper
AWFCO operation
• Allowable design. Controlled to ensure complete combustion
• Operating variability. Controlled to ensure trial burn results remain
representative
Potential Control Parameters
• O2 level at kiln exit. Controlled to ensure complete combustion
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-65
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• Kiln solids residence time. Controlled by kiln rotation speed, usually
between 0.5 and 1.5 hours, to ensure that the waste spends enough time
in the kiln to be thoroughly treated
• Kiln solids and combustion air mixing. Good mixing is promoted to assure
that volatiles are completely combusted
Examples: TXI and Ash Grove Permits - In the draft permit for the TXI cement kiln at
Midlothian, Texas, Lois included permit conditions for many of the above-
mentioned control parameters (see Exhibit 6.1-1, page 7-66).
Developing permit limits from trial burn data - The minimum SCC temperature is
a Group A parameter. In a recent trial burn at a rotary kiln incinerator system,
the run average SCC temperatures were as follows:
Run 1—2,145 °F
Run 2—2,345 °F
Run 3—2,360°F
The permit limit was calculated as the mean of the three run averages as follows:
Permit limit = 2.145 + 2.345 + 2.360 = 2,283 °F
3
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-66
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 6.1-1
TXI MIDLOTHIAN PERMIT
SECTION IV
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-67
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
PERMIT NO. HW-50316-001
NAME: TXI Operations, LP
PERMIT SECTION IV - CEMENT KILN REQUIREMENTS
A. CEMENT KILN AREA OPERATIONAL REQUIREMENTS
1. The permittee shall feed wastes to a permitted cement kiln unit only when that unit meets the following
conditions:
a. During startup and shut-down of a permitted cement kiln, waste shall not be fed into the device
unless the device is operating within the parameters specified in this permit.
b. The combustion gas temperature measured by the thermocouple located at the feed end of the
kiln (feed end temperature) is maintained above 433°F, which is considered to be representative
of the minimum required kiln temperature demonstrated during testing.
c. The temperature of the combustion gas by the thermocouple located at the feed end of the kiln
(feed end temperature) is maintained below 530°F, which is considered to be representative of
the maximum required kiln temperature demonstrated during testing.
d. The maximum velocity head differential pressure through the cement kiln stack shall not exceed
0.1915 inches of H20 as measured at the stack.
e. The combustion gas concentration of carbon monoxide (CO) continuously measured at the stack
shall not exceed 365 parts per million by volume (ppmv) when corrected to 7 percent oxygen,
dry basis, in the stack gas.
In addition, the total hydrocarbons (THC) at the stack shall not exceed 20 ppmv when corrected
to 7 percent oxygen, dry basis, in the stack gas. Both the CO and the THC Continuous
Emission Monitoring Systems (CEMS) shall meet the data quality requirements of Provision
IV.C.
f Total emission rates of metals and chlorine while burning wastes are limited to those listed in
Attachment H, entitled "Emission Sources - Maximum Allowable Emission Rates", which is
hereby made a part of this permit. Each cement kiln is limited to the emissions specified in that
attachment.
g. The total power to the electrostatic precipitator measured on the secondary side of each
transformer and totaled shall be no less than 93 kilovolt-amperes (kVA).
h. The permittee maintains and operates an automatic waste feed cut-off system which shall
activate under the conditions listed in Attachment I. entitled, "Waste Feed Cut-Off Systems."
I. While feeding hazardous waste, the maximum production rate of the kiln shall not exceed 71.1
tons/hr as total raw material dry feed. While feeding hazardous waste, the minimum production
rate of the kiln shall not be less than 8 tons/hr as total raw material dry feed.
j. The flue gas entering the particulate matter control device shall have a maximum temperature of
423°F.
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-6
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
PERMIT NO. HW-50316-001
NAME: TXI Operations, LP
B. LIMITATIONS ON WASTES BURNED
1. The feed rate of total wastes to a cement kiln shall not exceed 257 pounds per minute (Ib/min). The total
pumpable waste feed rate to the a cement kiln shall not exceed 257 Ib/min. The feed rate of waste as
quench water shall not exceed 166 Ib/min.
2. The total feed rate of metals and chlorine to each cement kiln shall not exceed the limitations set out in
Attachment J, entitled "Maximum Constituent Feed Rates", at any time.
C. OTHER CEMENT KILN MONITORING, TESTING AND INSPECTION REQUIREMENTS
1. The permittee shall monitor and record the parameters listed in Attachment K, entitled "Other Kiln
Monitoring Systems."
2. Stack oxygen and carbon monoxide concentrations shall be measured using Continuous Emission
Monitoring Systems (CEMS) which sample from essentially the same location in the exhaust gas stream.
The CEMS shall be certified for use by meeting the design and performance specifications and passing the
field tests in 40 CFR Part 266, Appendix IX, Section 2.1. Oxygen concentrations shall be quantified and
reported as percent by volume (%) on a dry basis. Carbon monoxide concentrations shall be quantified
and reported as parts per million by volume (ppmv), corrected to 7 percent by volume oxygen, on a dry
basis.
3. The permittee shall continuously monitor the exhaust gas stream for total hydrocarbons (THC) while
feeding waste to the cement kiln.
a. The THC CEMS shall meet the design and performance specifications, pass the field tests,
meet the installation requirements and the data analysis and reporting requirements of 40 CFR
Part 266, Appendix IX, Section 2.2.
b. The THC concentrations shall be reported in ppmv (dry basis) corrected to 7 percent oxygen
on an hourly average basis and in pounds per hour.
4. The continuous emission monitoring systems for CO, THC and Stack Oxygen shall be zeroed and
spanned daily for each monitoring range on those days when the cement kiln system is in service.
Corrective action shall be taken when the 24-hour span drift exceeds two times the amount specified in 40
CFR Part 266, Appendix IX. Each calendar quarter, monitor accuracy shall be certified using a cylinder
gas audit (CGA) as described in 40 CFR Part 60, Appendix F, Procedure 1, Section 5.1.2. Reference
method testing can be substituted for cylinder gas audits if preferred by the permittee. Corrective action
shall be taken when the CGA or reference method testing exceeds +15 percent accuracy. Each CO, THC
and Stack Oxygen CEMS shall operate at a minimum of 90 percent uptime, based on a 24-hour period.
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-69
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
PERMIT NO. HW-50316-001
NAME: TXI Operations, LP
5. The waste feed cut-off system and associated alarms for each kiln shall be tested weekly to verify
operability. TXI will maintain a "fail safe" valve (i.e., remains in the closed position in event of failure)
on each kiln. System testing will be accomplished with an electronic loop test for the components of the
system, including sensors, which test the operability of the circuit without actually closing the "fail safe"
valve. The waste feed cut-off valve shall be activated once during the weekly inspection. A check of
every input to the waste feed cut-off system does not have to activate the waste feed cut-off. If the
waste feed cutoff system "trips" (i.e., waste feed is cut off due to a process operations excursion from
specified limits) during the 7-day period prior to testing, the actual trip will satisfy the need to test the
valve. In addition, a complete inspection and function test shall be performed on all system alarms and
emergency control devices at least annually.
6. The monitoring and inspection data collected in Provisions IV.D.1.-6. shall be recorded and the records
shall be placed in the operating log as required by 40 CFR §266.102(10). In addition to the specific
requirements of that paragraph, the permittee shall also record:
a. All occasions when waste is being fed to the cement kiln unit and the operating limits specified
in Provision IV.B. are exceeded and/or;
b. All occasions when waste feed is cut off by the automatic waste feed cut-off system, including
the date, time and parameter that triggered the cut-off.
7. The permittee will continue to maintain the voluntary real time electronic data link with the TNRCC
Region 4 Office. The link will provide access to the following operational data: THC, ppm, corrected to 7
percent O2; CO, ppm, corrected to 7 percent O2; SO2, ppm, corrected to 7 percent O2; NOX, ppm,
corrected to 7 percent O2; Stack Opacity, percent; Stack Temperature, °F; Stack Velocity, in. H2O; and
kiln O2, percent. In addition, the system will indicate whether hazardous waste or quench water is being
fired. The permittee may upgrade the components of this system or add additional parameters with
concurrence with the TNRCC Region 4 Office. TXI will not be held responsible for loss of the linkage
due to weather, or other reasons beyond TXI control.
D. CEMENT KILN SAMPLING REQUIREMENTS
1. The permittee may conduct additional trial burn testing in accordance with a trial plan approved by the
Executive Director. The results from the additional trial burn testing shall be used for the purpose of
determining the feasibility of compliance with the performance standards of 40 CFR §§266.104 through
266.107 and of determining adequate operating conditions under 40 CFR §266.102(e). The permittee may
request a permit modification or amendment pursuant to 30 TAC §305.69 or §305.62 based on these
additional trial burn results.
2. Upon request of the Executive Director of the TNRCC, additional sampling and analysis of the waste and
exhaust emissions shall be conducted to verify that the operating requirements of Provisions IV.B. and
IV.C. of this permit achieve the performance standards of 40 CFR §§266.104 through 266.107 as
referenced in this permit.
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-70
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
6.2 BOILERS
Regulations: 40 CFR Parts 266.102 and 266.103
40 CFR Parts 270.32 and 270.66
Guidance: No specific references are applicable to this section of the manual.
Explanation: Boilers are commonly used to incinerate liquid hazardous wastes. Boilers come
in a variety of sizes, configurations, and designs. Common types of boilers
include fire tube, water tube, and stoker-fired.
Control Parameters: Common Control Parameters
• Combustion chamber temperature. Maintained at the maximum
temperature to minimize PIC formation, yet low enough to prevent
excessive metals volatilization
• Combustion chamber pressure. Maintained at negative pressure relative
to the atmosphere to prevent fugitive emissions
• Combustion gas velocity. Controlled to ensure proper combustion gas
residence time and POHC destruction
• Waste feed rate. Controlled to avoid overloading, over-pressuring, and
depleting O2 that is critical to the POHC destruction
• CO and THC combustion gas concentrations. Monitored to ensure
satisfactory boiler operation and to minimize PIC formation
• Feed rates of the BIF-regulated metals. Controlled below levels that
could pose unacceptable risks to human and ecological receptors
• Feed rates of chlorine and chloride. Controlled below levels that could
pose unacceptable risks to human and ecological receptors
• Feed rates of ash. Controlled below levels that could lead to excessive
PM emissions
• Maximum flue gas temperature entering the PM control device.
Controlled below levels that could deteriorate PM collection efficiency.
Controlled below levels that are conducive to dioxin and furan formation
• Other Combustion and APCS Control Parameters. Controlled as needed
to ensure adequate DRE and reduce risks posed by emissions of metals
and PICs
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-71
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• Minimum and maximum production rate. Controlled to ensure complete
combustion
• Hazardous waste firing system controls. Controlled to ensure proper
AWFCO operation
• Allowable design. Controlled to ensure complete combustion
• Operating variability. Controlled to ensure trial burn results remain
representative
Potential Control Parameters
• Excess O2 level in combustion chamber. Controlled to ensure complete
combustion
• Waste feed solids content. Controlled below levels that could deteriorate
burner performance
• Waste feed viscosity. Controlled below levels that could deteriorate
burner performance
• Atomizing fluid pressure. Maintained at a prescribed differential above
that of the waste feed to ensure proper waste feed atomization
• Steam production rate. Maintained below maximum levels and above
minimum levels demonstrated in certification tests and trial burns
Examples:
• Emissions rates of metals. HC1 and Ck Controlled below levels that
could pose unacceptable risks to human and ecological receptors.
• Feed rates of auxiliary fuels. Controlled within a range that optimizes
combustion and minimizes PIC formation.
U.S. EPA has not yet written a final permit for a boiler; however Lois and Clark
will address the above parameters in developing facility-specific permit
conditions.
During a recent trial burn at a boiler, the differential pressure between the
atomizing fluid (steam) and the waste liquid feed was measured and recorded as
shown in the table below.
Run Number
1
2
Differential Pressure
(pounds per square inch gauge)
Mean
45.0
45.0
Maximum
45.0
45.0
Minimum
45.0
45.0
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-72
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
3
4
5
6
45.0
45.19
45.90
45.87
45.0
45.0
45.0
45.0
45.0
46.0
46.0
46.0
The atomizing fluid differential pressure is a Group C parameter for which permit
limits (in this case a minimum) are based on manufacturers' recommendation.
The manufacturer of the burner system recommended a minimum differential
pressure of 15 psig. The trial burn data show that this recommendation was met
during all six runs. The permit limit will be a minimum of 15 psig, even though a
much higher differential pressure was demonstrated.
During the same trial burn, steam production rates were as follows:
Run
Number
1
2
3
Steam Production
(pounds per hour)
Average
207,120
206,730
205,770
Minimum
202,500
200,000
205,000
Maximum
210,000
210,000
210,000
The permit limit for maximum steam production was calculated as follows:
Limit = 207.120 + 206.730 + 205.770 = 206,540 Ib/hr
3
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-73
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
6.3 LIQUID INJECTION INCINERATORS
Regulations: 40 CFR Parts 270.32 and 270.62
Guidance: No specific references are applicable to this section of the manual.
Explanation: Liquid injection incinerators are commonly used for incinerating liquids, slurries,
and sludges. Highlighted parameters are commonly included in liquid injection
incinerator permits.
Control Parameters: Common Control Parameters
• Combustion chamber temperature. Maintained at the maximum
temperature to minimize PIC formation, yet low enough to prevent
excessive metals volatilization
• Combustion chamber pressure. Maintained at negative pressure relative
to the atmosphere to prevent fugitive emissions
• Combustion gas velocity. Controlled to ensure proper combustion gas
residence time and POHC destruction
• Waste feed rate. Controlled to avoid overloading, over-pressuring, and
depleting O2 that is critical to POHC destruction
• CO and THC combustion gas concentrations. Monitored to ensure
satisfactory boiler operation and to minimize PIC formation
• Feed rates of the BIF-regulated metals. Controlled below levels that
could pose unacceptable risks to human and ecological receptors
• Feed rates of chlorine and chloride. Controlled below levels that could
pose unacceptable risks to human and ecological receptors
• Feed rates of ash. Controlled below levels that could lead to excessive
PM emissions
• Maximum flue gas temperature entering the PM control device.
Controlled below levels that could deteriorate PM collection efficiency
controlled below levels that are conducive to dioxin and furan formation
• Other Combustion and APCS Control Parameters. Controlled as needed
to ensure adequate DRE and reduce risks posed by emissions of metals
and PICs
Potential Control Parameters
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-74
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Excess O2 level in combustion chamber. Controlled to ensure complete
combustion
Waste feed solids content. Controlled below levels that could deteriorate
burner performance
Waste feed viscosity. Controlled below levels that could deteriorate
burner performance
Atomizing fluid pressure. Maintained at a prescribed differential above
that of the waste feed to ensure proper waste feed atomization
Emissions rates of metals. HC1 and Ck Controlled below levels that
could pose unacceptable risks to human and ecological receptors
Feed rates of auxiliary fuels. Controlled within a range that optimizes
combustion and minimizes PIC formation
Example:
Lois included the above control parameters in developing incinerator permit
conditions for ANCFD (see Attachment P, Section VII.B).
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-75
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
6.4 HALOGEN ACID FURNACES
Regulations: 40 CFR Parts 270.32 and 270.62
Guidance: No specific references are applicable to this section of the manual.
Explanation: The halogen acid furnace (HAF) is a special form of liquid injection incinerator
that produces an aqueous acid "product" in the off-gas treatment system. A
typical process flowsheet for a HAF is shown on Exhibit 6.4-1 (see page 7-77).
The HAF is a unique form of hazardous waste combustion system because acid
is recovered from the off-gas for reuse or sale. From a systems viewpoint,
however, the HAF is basically a liquid injection incinerator with a multi-stage wet
scrubber system. Therefore, it should be possible to develop permit conditions
for the HAF based on the concepts presented in Sections 6.3 (Liquid Injection
Incinerators) and 7.5 (Wet Scrubbers). The wet scrubber system in the HAF,
however, is operated to produce an acidic liquid with economic value. To this
end, it may not be appropriate to impose limits on all of the control parameters
identified in Section 7.5 for each stage of the wet scrubber system. In particular,
it may be necessary to waive permit conditions for liquid-to-gas ratios and
pressure drops in the absorber sections of the off-gas treatment train to permit
the facility to optimize its acid recovery process and to impose such limits only on
the final off-gas cleaning stages.
Control Parameters: The control parameters for the combustion process should be similar to those for
a liquid injection incinerator as listed below:
Common Control Parameters
• Minimum and maximum combustion chamber temperature
• Maximum combustion chamber pressure
• Maximum combustion gas velocity
• Maximum waste feed rate
• Maximum feed rates of ash, metals, chlorine, and chloride
• Maximum emissions of PM, metals, chlorine, and chloride
• Maximum CO and hydrocarbon levels in the stack gas
Potential Control Parameters
• Minimum excess oxygen level in combustion chamber
• Maximum waste feed solids content
• Maximum waste feed viscosity
• Minimum atomizing fluid pressure
• Other parameters as needed to ensure DRE and control
emissions of metal and PICs
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-76
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Example:
When crafting permit limits for the off-gas treatment train, the permit writer
should concentrate on control parameters that have the greatest effect on the
following emissions rates:
PM, HC1, and chlorine
• Metals
PICs
To determine which control parameters have the greatest effect on the above
emissions rates, it is recommended that the permit writer construct Pareto
diagrams, as introduced in Section 5.3.5.
A trial burn was recently conducted at a HAF. The process flow diagram for
this facility is shown on Exhibit 6.4.1 (see page 7-77). Lois and Clark determined
that the control parameters for the combustion subsystem of the HAF should be
as follows:
• Minimum combustion chamber temperature to ensure DRE
• Maximum combustion chamber temperature to minimize metals
volatilization
• Maximum combustion chamber pressure to minimize fugitive
emissions
• Maximum combustion gas velocity to ensure DRE
• Maximum waste feed rate to ensure DRE
• Maximum feed rates of ash, metals, chlorine, and chloride to
control emissions of PM, metals, chlorine, and chloride
• Maximum emissions of PM, metals, chlorine, and chloride to
ensure compliance with regulatory performance standards and
control risks to human health and the environment
• Maximum CO level in the stack gas to ensure compliance with
the regulatory performance standard and minimize the emissions
of PICs
• Minimum excess oxygen level in combustion chamber to ensure
DRE
• Maximum waste feed solids content to prevent plugging of the
waste feed nozzles
• Maximum waste feed viscosity to ensure proper atomization of
waste feed and DRE
• Minimum atomizing fluid pressure to ensure proper atomization
of waste feed and DRE
Lois constructed the Pareto diagrams shown on Exhibits 6.4-2 (see page 7-78),
-3 (see page 7-79), and -4 (see page 7-80) as a first step in establishing the list of
off-gas treatment train control parameters that will be subject to permit limits.
Based on Lois's work, it was determined that the following off-gas treatment
control parameters would be subject to permit limits:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-77
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• Minimum liquid-to-gas ratio in the vent scrubber and the final
scrubber to optimize particulate and acid gas capture and control
emissions of PICs and metals
• Maximum off-gas flowrate entering the vent scrubber and the
final scrubber to optimize particulate and acid gas removal and
control emissions of PICs and metals
• Minimum pH of scrubber liquid entering the final scrubber to
ensure adequate acid gas and metal removal
• Minimum blowdown rate from the final scrubber to ensure
control of PM and acid gases
Based on information contained in the equipment manufacturer's operations
manual for the off-gas treatment train, Clark imposed the following additional
Group C permit limits:
• Maximum combustion gas temperature entering the primary
absorber to prevent damage to downstream equipment in the
APCS train.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-78
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 6.4-1
HALOGEN ACID FURNACE PROCESS FLOW DIAGRAM
so)—(FT)
Waste Feed
Atomizing Air
(^ Natural Gas
(rr}-(sD)
Combustion Air
k
Combustion
Chambe
(2)
W
-J
w
{
Spray
r
//
Chamber
(2)
^-
^-
Acid
Storage
CO
— (Vr) Combustion Chamber Temperature
Exhaust / \
Stack
Quencher ,—, ^-x
P res s u re ( 5 pHcq)—
i
i
i
V
| 1
Primary
Absorber
(2)
| 1
->>
4
Secondary
Absorber
,
(
1 — 1
L^
Tertiary
Absorber
4
-^^>
Exhaust
Blower
^>O^~
Vent
Scrubber
.
>^
J^-
>».
*^
— (pH>-
— @(-
y
-1
\
y
Final
Scrubber
(SD)
-CQ-
<+
<*
^
^ Caustic
( Reducing Agent
(so) Effluent Stream
Slowdown
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-79
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 6.4-2
PARETO DIAGRAM FOR HAF OFF-GAS TREATMENT TRAIN OPERATING CONDITIONS RELATED TO PIC EMISSIONS
PIC Emissions
//
//
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-8
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 6.4-3
PARETO DIAGRAM FOR HAF OFF-GAS TREATMENT TRAIN OPERATING CONDITIONS RELATED
TO PM, HC1, C12 EMISSIONS
PM, HCI, CI2 Emissions
/ //
*/ «v
o / ^» /
\ cp \ f
\ \
^ \\
AV <} «?'
*y / «^
fa / ^f ^i /
0? /
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
EXHIBIT 6.4-4
PARETO DIAGRAM FOR HAF OFF-GAS TREATMENT TRAIN OPERATING CONDITIONS RELATED
TO METALS EMISSIONS
tF / •$' / A
<
&• /
Metals Emissions °
\
oV
\
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-82
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
7.0 AIR POLLUTION CONTROL SYSTEM CONDITIONS
Regulations:
Guidance:
Explanation:
Approaches:
40 CFR Parts 266.102 and 266.103
40 CFR Part 270.32
No specific references are applicable to this section of the manual.
APCS at hazardous waste combustion facilities generally serve two
purposes—control of particulate emissions and organic and acid gases.
APCS generally consist of two types—wet and dry. Wet systems are
predominant among older incinerators; dry systems are common at BIF units,
particularly cement kilns and newer incinerators.
Wet APCS are typically comprised of several combinations and configurations of
the following types of units: quench chambers, packed-bed scrubbers, venturi
scrubbers, and mist eliminators. Dry APCS typically consist of a mechanical
collector (for example, cyclone) followed by either a fabric filter baghouse and
ESP or a spray-drying absorber.
Most hazardous waste combustion systems are equipped with APCS. These
APCS range in complexity from simple ESPs at some of the older hazardous
waste burning cement kilns to more sophisticated systems that include quench
columns, venturi scrubbers, demisters, and fabric filter baghouses at modern
commercial incineration plants.
On the other hand, many hazardous waste burning boilers have no APCS. This
is due mainly to the very low ash content of the wastes being burned. As a
result, the potential for PM emissions is low.
The specification of operating conditions for APCS typically involves a
combination of Group A, B, and C parameters. Specification of operating
conditions frequently requires balancing equipment manufacturers'
recommendations with the results of trial burn tests. The specification of
operating conditions depends on the manner in which the parameter is monitored
and recorded. In addition to operating conditions, the permit writer should specify
requirements for calibration, inspection, and maintenance of the APCS.
The following subsections describe control parameters for various APCS:
Q Quench systems (Section 7.1)
Q Fabric filter baghouses (Section 7.2)
Q Electrostatic precipitators (Section 7.3)
Q Venturi scrubbers (Section 7.4)
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-83
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Q Wet scrubbers (Section 7.5)
Examples: Specific examples are provided in Sections 7.1 through 7.4.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-84
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
7.1 QUENCH SYSTEMS
Regulation: 40 CFR Part 270.32
Guidance: No specific references are applicable to this section of the manual.
Explanation: Quench systems are common components of combustion unit systems. They
serve to rapidly cool combustion gases exiting the PCCs and SCCs. By
facilitating rapid cooling of combustion gases, they play a key role in inhibiting the
postcombustion formation of dioxins, furan, and other undesirable PICs and
protecting downstream air pollution control equipment from damage caused by
excessive combustion gas temperature.
Control Parameters: The following control parameters are recommended for inclusion in the permit.
• Combustion gas inlet temperature. Maintained below maximum levels
specified by the manufacturer to ensure that the unit's thermal rating is
not exceeded
• Combustion gas flow rate. Maintained below maximum levels specified
by the manufacturer and demonstrated in trial burns to ensure that the
residence time of the combustion gas within the quench system is
sufficient to produce adequate cooling
• Combustion gas exit temperature. Maintained below maximum levels
specified by the manufacturers of downstream APCS equipment and
demonstrated in trial burns to ensure proper operation of downstream
APCS equipment
• Quench water flow rate. Maintained high enough to ensure adequate
cooling of combustion gases
• Quench water inlet temperature. Maintained low enough to ensure
adequate cooling of combustion gases
• Quench water pH. Maintained within range recommended by the
manufacturer to ensure proper operation
• Quench water total suspended solids. Maintained below levels that could
negatively affect unit performance
Examples: Consolidated Incineration Facility
The APCS for the GIF incinerator consists of a quench chamber, a steam-
atomized free-jet scrubber (venturi-type), a cyclone separator, a mist eliminator, a
reheater, and a high efficiency participate air (HEPA) filter.
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-85
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
The operating limit and corresponding AWFCO set point for the GIF quench
system are examples of Group C parameters that are interlocked with the
AWFCO system. The operating limit and AWFCO set point were based on the
manufacturer's recommendations, independent of trial burn results.
The permit for the GIF incinerator specifies the following operating limits for the
quench system:
• "The total quench liquid flow rate, monitored as specified in
permit condition IIIE4.G, shall not be less than a minimum of 150
gpm
• The maximum outlet temperature from the quench chamber shall
be 210°F, monitored as specified in permit condition IIIE4.G.
• The total dissolved solids in the liquid provided to the
quench...shall not be greater than 10 percent by weight.
• The total suspended solids in the liquid provided to the
quench...shall not be greater than 3 percent by weight.
In the GIF permit, Clark included the requirement that the quench liquid flow rate
be interlocked with the AWFCO to initiate cutoff of all waste feed streams in the
event that the flow rate drops below 150 gpm.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-8
-------
7.2
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
FABRIC FILTER BAGHOUSES
Regulations:
Guidance:
Explanation:
40 CFR Parts 266.102 and 266.103
40 CFR Part 270.32
No specific references are applicable to this section of the manual.
Fabric filter baghouses are used to remove suspended PM from combustion
gases.
There are different kinds of baghouses; however, they all provide the same basic
function and require similar operating limits.
A Pulse Jet Baghouse
Control Parameters: Common Control Parameters
• Combustion gas inlet temperature. Maintained above the dew point of
the combustion gas but below temperatures that are conducive to dioxin
formation (for example, usually maintained below 400°C).
• Pressure drop across the filter. Maintained in the range that
optimizes PM removal (for example, 1 to 6 inches w.c.).
Potential Control Parameters
• Gas-to-cloth ratio. Maintained in the range recommended by the
manufacturer to optimize particulate matter removal (usually 2 to
5 acfm per square foot of fabric).
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-87
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• Cleaning frequency. Filters are cleaned periodically based on
useage rate and manufacturers recommendations to ensure
proper unit operation.
Examples: A pulse jet baghouse has been installed to control particulate emissions from a
boiler. Design specifications are as follows:
Total Cloth Area—3,667 feet2
Air-to-Cloth Ratio—4.5:1 maximum
Pressure Drop—0.5 to 6 inches w.c.
Bags—Nomex felt, service to 375 °F maximum
Test data from three
summarized below.
Run No.
1
2
3
nB^bfJtise iriytburn
Temperature
(°F)
328
316
313
are provided in A
Gas Flow
(acfrn)
15,480
15,404
15.227
ttadMaieMiahd
Pressure
(inches w.c)
0.53
0.52
0.56
Based on the trial burn data, the inlet temperature was observed to be within the
service temperature of the bags. The air-to-cloth ratio was as follows:
15.370 acfm = 4.19:1
3,667 feet2
This ratio is within the design specifications.
The average differential pressure was 0.54 inches w.c., also within the design
specifications.
Permit conditions related to baghouse operations normally are Group C
parameters established on the basis of the design specification, although dioxin
formation considerations enter into the process when temperatures higher than
400°F are encountered. In this case, the permit writer has three basic options
when developing permit conditions:
(1) Stick with the design specifications.
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-8
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
(2) Use the trial burn results to set all of the permit limits.
(3) Use a combination of design specifications and trial burn results.
Based on engineering judgment, the permit writer chose the third option and
wrote the permit limits as follows:
Maximum baghouse inlet temperature= 319°F (trial burn data)
Maximum air-to-cloth ratio = 4.19:1 (trial burn data)
Minimum differential pressure = 0.5 inches w.c. (design specifications)
Maximum differential pressure = 6 inches w.c. (design specifications)
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-89
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
7.3
ELECTROSTATIC PRECIPITATORS
Regulations:
Guidance:
Explanation:
40 CFR Parts 266.102 and 266.103
40 CFR Part 270.32
No specific references are applicable to this section of the manual.
ESPs are commonly found at hazardous waste-burning cement kilns. The designs
and control logics for ESPs vary widely. Some systems are controlled on the
basis of electrical amperage or power consumption in one or more chambers.
Others are controlled only on the basis of applied secondary voltage. Still others
are controlled by modern programmable logic controllers (PLC) that employ
"fuzzy" logic that flip-flops between all of the above control schemes.
Most ESPs are limited in terms of the maximum gas inlet temperature
based on manufacturers' recommendations and dioxin formation
considerations.
No single method exists to prescribe operating limits for ESPs. Limits should be
established only after consideration of recommendations by U.S. EPA, ESP
control system manufacturers and plant operators, and on trial burn results.
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-90
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Large ESP at an Electric Utility Facility
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-91
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Control Parameters: Common Control Parameters
• Combustion gas flow rate. Controlled within the specific collection area
of the unit
• Inlet gas temperature. Controlled to maximize metals removal and
minimize dioxin/furan formation
• Power input or applied secondary voltage (kVA). Controlled within the
range that optimizes particulate matter collection
Potential Control Parameters
• Rapper intensity. Controlled to minimize the re-entrainment of collected
particles
Examples:
Ash Grove Cement Company, Chanute, Kansas
Lois elected to limit ESP operation on the two kilns at the AGC on the basis of
power consumption, inlet gas temperature, and flue gas flow rate. The resulting
permit conditions for Kiln No. 1 are as follows:
• "The power to the ESP, monitored as specified in Permit Condition E.8
shall not be less than 44. 1 kVA on an HRA basis, as defined in 40 CFR
266.102(e)(6)(I)(B).
• The maximum ESP inlet gas temperature monitored as specified in
Permit Condition E.8 shall not be more than 388 °F on an HRA basis, as
defined in 40 CFR 266.(e)(6)(I)(B).
• The relative flue gas flow rate, monitored as specified in permit Condition
E.8, shall not be more than 1.07, on an HRA basis, as defined in 40 CFR
In the permit, Lois required that the three parameters discussed above be
interlocked with the AWFCO system.
Three features of these operating limits deserve further discussion. First, the
limits are based on HRAs, primarily because these parameters experience
substantial variation under normal operations. Second, flue gas flow rate is
measured indirectly; this is common. Last, most facilities use one or more of the
following types of instruments to determine stack gas velocities or volumetric
flow rates:
Orifice place — differential pressure is an indicator of velocity
Pitot tubes — differential pressure is an indicator of velocity
Annubars — provide velocity indication
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-92
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Fan power or speed—provides indication of volumetric flow rate
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-93
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
7.4
VENTURI SCRUBBERS
Regulation:
Guidance:
Explanation:
40 CFR Parts 266.102 and 266.103
40 CFR Part 270.32
No specific references are applicable to this section of the manual.
Venturi scrubbers are the most common type of scrubber used for particulate
control. Venturi scrubbers are also used occasionally for the control of acid
gases or metal emissions downstream of an ESP or fabric filter baghouse.
Venturi Scrubber at a Chemical Manufacturing Facility
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-94
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Control Parameters: Common Control Parameters
• Scrubber gas flow rate. Controlled in proportion to scrubber liquid flow
rate to optimize venturi performance
• Scrubber liquid flow rate. Controlled in proportion to scrubber gas flow
rate to optimize venturi performance
• Minimum liquid to gas ratio. Controlled to optimize particulate and HC1
removal
• Minimum Scrubber Slowdown or Maximum Total Solids Content of
Scrubber-Liquid. Controlled to optimize particulate and HC1 removal.
• Pressure drop. Maintained above a minimum to optimize particle capture
and HC1 removal
• Scrubber liquid pH. Controlled within a range that prevents corrosion of
the device at the low end of the range and scaling at the high end of the
range. When used for acid gas control, maintained above a
predetermined value to ensure acid gas neutralization
Potential Control Parameters
• Scrubber inlet gas temperature. Maintained below a maximum value to
prevent scrubber liquid evaporation
Examples: In the XYZ Company incinerator permit, Clark includes Group C operating limits
for a high-energy venturi scrubber. The pertinent permit section reads as
follows:
• "Each incineration train shall be equipped with a high energy venturi
scrubber which shall be used for the control of PM in the combustion
gases during the incineration of waste. No waste material shall be
incinerated in either incineration train if the venturi scrubber associated
with that train is not operational.
• Each venturi scrubber shall be designed and operated so as to achieve at
all times a minimum of 99 percent efficiency in the removal of PM and a
minimum of 99 percent efficiency in the removal of metals except
mercury.
• The scrubber liquid injection rate to the venturi scrubber
measured immediately prior to injection shall be
maintained at an average of 900 gallons per minute
(gpm) on an hourly basis and shall not go below 500 gpm
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-95
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
at any time. The scrubber injection rate shall be
monitored on a continuous basis [sic] and shall be
recorded continuously.
• The overall pressure drop across each venturi scrubber
shall be greater than 55 inches of w.c. at all times during
the incineration of waste. The pressure drop across the
inlet and outlet scrubber [sic] shall be monitored on a
continuous basis and shall be recorded continuously.
The scrubber liquid injection rate in this case is limited on both average and
instantaneous bases.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-96
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
7.5 WET SCRUBBERS
Regulation:
Guidance:
Explanation:
40 CFR Parts 266.102 and 266.103
40 CFR Part 270.32
No specific references are applicable to this section of the manual.
Wet scrubbers are commonly used for controlling emissions of PM, acid gases,
and metals. Wet scrubber designs are diverse and include packed columns, plate
towers, and Venturis. Some wet scrubber designs also include ionizing sections.
Gas out
Liquid in
Liquid distributor
Packing restrainer
Shell
Random packing
Liquid
redistributes
Packing support
Gas in
—*• Liquid out
Schematic of a Packed Bed Wet Scrubber
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-97
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
Control Parameters: Common Control Parameters
• Scrubber gas flow rate. Controlled in proportion to scrubber liquid flow
rate to optimize scrubber performance
• Scrubber liquid flow rate. Controlled in proportion to scrubber gas flow
rate to optimize scrubber performance
• Minimum liquid to gas ratio. Controlled to optimize PM and HC1 removal
• Scrubber blowdown. Controlled above a certain rate to ensure control of
PM and acid gases.
• Suspended solids. Controlled below a certain level to ensure optimum
scrubber performance.
• Scrubber liquid pH. Controlled within a range that prevents corrosion of
the device at the low end of the range and scaling at the high end of the
range. When used for acid gas control, pH is maintained above a
predetermined value to ensure acid gas neutralization
Potential Control Parameters
• Scrubber inlet gas temperature. Maintained below a maximum value to
prevent evaporation of the scrubber liquid
• Pressure drop. Maintained above a minimum to optimize particle capture
Examples: In the permit for the XYZ Company, Lois includes operating limits for primary
and secondary packed-bed scrubbers. The relevant permit language is as follows:
• "The primary packed scrubber associated with each incineration train
shall achieve at all times a minimum of 99 percent efficiency in the
removal of HC1 from the effluent gas stream.
• The solvent stream flow rate through each primary scrubber measured at
the inlet to each scrubber shall be maintained at a minimum of 3,500 gpm
in each absorber on a rolling hourly average and shall not go below 3000
gpm at any time. The solvent stream flow rate shall be monitored on a
continuous basis and shall be continuously recorded.
• The temperature of the outlet gas from each primary packed bed
absorber measured at the gas outlet from the primary packed bed
scrubber shall not exceed 135 °F at any time. This temperature shall be
monitored on a continuous basis and shall be continuously recorded.
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-98
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
The secondary packed scrubbers on each train shall achieve at all times a
minimum of 99 percent efficiency in the removal of HC1, a minimum of 99
percent efficiency in the removal of sulfur oxides, and a minimum of 85 percent
efficiency in the removal of oxides of nitrogen from the effluent gas stream.
• The solvent stream flow rate through the secondary scrubbers measured
at the inlet of each stage of the secondary scrubber shall be maintained
at a minimum of 2,000 gpm in each stage, on a rolling hourly average,
and shall not go below 1,500 gpm at any time. The solvent stream flow
rate shall be monitored on a continuous basis and shall be continuously
recorded.
• Sodium hydroxide shall be added to the solvent fed to the second and
third stages of each secondary scrubber so as to maintain a pH of 8 and
11, respectively, on an hourly average. The pH of these feed streams
shall be monitored on a continuous basis and shall be continuously
recorded.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-99
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
8.0 MISCELLANEOUS CONDITIONS
Regulation: 40 CFR Parts 264 Subpart X, 270.23, and 270.27; Clean Air Act (CAA)
Guidance: No specific references are applicable to this section of the manual.
Explanation: In some instances, miscellaneous units that are regulated under 40 CFR Part 264
Subpart X may be collocated with integrated hazardous waste combustion
facilities. Also, it is sometimes desirable to consolidate the RCRA and air
pollution permitting tasks. In these instances, a joint RCRA/CAA permit is
issued.
Check For: The following subsections describe various miscellaneous conditions:
Q Miscellaneous units (Section 8.1)
Q Air quality permit conditions (Section 8.2)
Example Situation: Not applicable to this section of the manual.
Example Action: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-100
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
8.1 MISCELLANEOUS UNITS
Regulations: 40 CFR Parts 264 Subpart X, 270.23, and 270.27
Guidance: No specific references are applicable to this section of the manual.
Explanation: Types of miscellaneous units commonly associated with hazardous waste
combustion facilities include drum shredders and waste feed preparation devices
(such as pug mills). The following is a discussion of typical permit conditions for
miscellaneous units.
Permit Conditions: Regulations for Subpart X units provide that the units conform to performance
standards that are protective of human health and the environment and the same
basic closure, postclosure, and financial assurance requirements applicable to
other units at the site.
Typical permit conditions for miscellaneous units are as follows:
• Permitted and prohibited waste identification. A list of
acceptable and prohibited wastes is provided
• Design and construction requirements. Compel the permittee to
design and build the facility in accordance with applicable design
standards and approved engineering drawings and specifications
• Operation and maintenance requirements. Compel the permittee
to operate and maintain the facility in accordance with approved
procedures, usually those provided in Section D of the permit
application
• Performance standards. The U.S. EPA specifies the
performance standards, including waste treatment efficiencies
and emissions limits
• Performance test. Requires the permittee to test the unit to
demonstrate compliance with approved performance standards
• Waste Feed Limitations. Restricts the rates at which the
permittee may feed wastes to the unit
• Operating conditions. Compels the permittee to maintain certain
operating parameters within finite limits
• Monitoring requirements. Specifies the manner in which the
permittee must monitor and record process operating and
emissions data
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-101
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• Waste feed cutoff requirements. Compels the permittee to
install and operate a system that automatically interrupts waste
feed in the event that certain operating conditions deviate from
set points prescribed by U.S. EPA
• Financial assurance for corrective action. Requires the
permittee to maintain financial assurance for the corrective
action
Example Situation: The ANCDF facility operates a brine reduction area—comprised of two
evaporators, a heat exchanger, and two drum dryers—as part of the combustion
unit APCS system (see Attachment Q). These units are not typical of hazardous
waste combustion units and need special permit conditions.
Example Comment: In the ANCDF permit, Clark includes permit conditions for these units (see
Attachment Q).
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-102
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
8.2 AIR QUALITY PERMIT CONDITIONS
Regulations:
Guidance:
Explanation:
Permit Conditions:
Example:
Notes:
40 CFR Parts 270.23 and 270.27
No specific references are applicable to this section of the manual.
In some instances, a joint RCRA and CAA permit may be issued. An example
might include a boiler that requires a RCRA permit to burn hazardous waste and
a CAA permit to satisfy Title V permit requirements for major sources regulated
by a New Source Performance Standard.
It is important for the permit writer to review existing or proposed air permits and
to consult with regional offices, field offices, inspectors, toxicologists, stack
testers, and other permit writers for air to reduce the potential for conflicts
between the RCRA permit and the CAA permit.
The specification of permit conditions is coordinated with cognizant air quality
personnel. Typical permit conditions for CAA portions of the permit are as
follows:
• General air quality conditions. Specify for regulatory
requirements (air quality) for unit design, construction, and
operation.
• Emissions limits. Specify for limits on emissions of PM, acid
gases, and other hazardous air pollutants.
• Sampling and monitoring requirement. Compels the permittee to
implement a prescribed program of air emissions sampling and
monitoring.
• Recordkeeping and reporting requirements. Require the
permittee to record sampling and monitoring data in a specific
manner and mandates that certain types of data be reported to
U.S. EPA according to a prescribed schedule.
Refer to Section V of the TXI draft RCRA permit (see Attachment R).
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-103
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
9.0 CORRECTIVE ACTION REQUIREMENTS
Regulation: 40 CFR Parts 264.101(b), 264.552, and 264.553.
Guidance: No specific references are applicable to this section of the manual.
Explanation: U.S. EPA is required to specify corrective actions for SWMUs in the permit.
The complexity of permit conditions for corrective action is entirely site-specific.
The U.S. EPA 1994 guidance RCRA Corrective Action Plan assists in
developing site-specific requirements for permitting. It provides an overall model
for the corrective action process, but the information should not be considered
boiler plate language. The model scopes of work should be modified with site-
specific information, and only the information that is necessary for the
subject facility should be required to minimize the number and length of
submissions and corresponding agency reviews.
It is a good idea, when possible, to specify in the permit what the performance
standard will be for the facility. This may be source removal, on-site stabilization
of all ground water releases, elimination of off-site releases, or control of other
possible exposures to affected populations. This should be coupled with a time
frame for reaching the goals (for example, 2 years or 30 months).
Permit Conditions: Required permit conditions related to corrective action include the following:
• Authority. Provides a citation of statutory and regulatory authorities
completed in accordance with 40 CFR Parts 264.552 and 264.552.
• Financial assurance for corrective action. Requires the permittee to
maintain financial assurance for completing the corrective action
• Schedules. Requires the permittee to include schedules of compliance
for corrective actions; unless actions can be completed prior to issuance
Possible permit conditions related to corrective action include the following:
• Identification of SWMUs. Presents a SWMU listing from a site-wide
perspective
• Stabilization or emergency removal. Compels the permittee to conduct
stabilization or emergency removal in the event that imminent dangers to
human health or the environment are encountered
Example:
In the AGC permit, Lois included comprehensive permit conditions for corrective
actions covering 24 SWMUs and four AOCs (see Attachment T). Lois made
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-104
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
sure that the permit conditions included performance standards and specific
schedules to implement these performance standards.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 7-105
-------
COMPONENT 7— HOW TO PREPARE PERMIT CONDITIONS
10.0 CLOSURE AND FINANCIAL ASSURANCE REQUIREMENTS
Regulations:
Guidance:
Explanation:
Permit Conditions:
Examples:
Notes:
40 CFR Part 264 Subpart G
U.S. EPA. 1990. "Draft of Guidance of Incinerator Closure." OSWER
October 30. Pages 1 through 8.
The permittee is required to close the facility at the end of its useful life, in
accordance with the approved closure plan, and to maintain financial assurance
for closure throughout its active life and the closure and postclosure periods. In
certain instances, for example with boilers or cement kilns, these units may be
closed by decontaminating the units and certifying closure, after which they can
be operated using fossil fuels or nonhazardous wastes.
Possible permit conditions related to closure and financial assurance include the
following:
• Financial assurance. Requires the permittee to maintain a specified
amount of financial assurance.
• Closure schedule. Describes when closure must begin and the
timeframe in which it must be completed.
• Closure notice and certification requirements. Requires the permittee to
provide written notice of closure commencement and to certify that
closure proceeded in accordance with the approved closure plan.
• Closure requirements. Specify performance standards and technical
aspects of the required closure for various hazardous waste management
units at the facility.
In the TXI draft RCRA permit, Clark included comprehensive permit conditions
for closure and financial assurance at a hazardous waste-burning cement kiln
(see Attachment S).
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-106
-------
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
11.0 CASE STUDY—CONSOLIDATED INCINERATION FACILITY
Background:
Permit Conditions:
Example:
GIF is a new incineration complex designed to burn a variety of liquid and solid
radioactive mixed wastes. The design includes the following systems:
• A tank farm for liquid waste storage and blending
• A container storage area for solid wastes
• Feed systems for liquid and solid wastes
• A rotary kiln incinerator (PCC)
A SCC
• Quench chamber
• Free-jet scrubber
• Cyclone separator
• Mist eliminator
• Off-gas reheater
Bank of HEPA filters
• Three induction fans
• Exhaust stack
• Ash solidification system
The process is controlled by a computerized distributed control system.
Permit conditions for process operating parameters required by SCDHEC in the
four-phased permit for this facility have been superimposed on the process
schematic (see Attachment W).
In the GIF permit (see Attachment G), Lois and Clark included Group A, B, and
C parameters, as follows:
Group A
• HHV waste feed rate
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-107
-------
Notes:
COMPONENT 7—HOW TO PREPARE PERMIT CONDITIONS
• LHV waste feed rate
• PCC temperature
• SCC temperature
Group B
Metals feed rates
Group C
PCC pressure
SCC pressure
PCC heat release
SCC heat release
U.S. EPA Region 6
Center for Combustion Science and Engineering
7-108
------- |