Hazardous Waste Combustion Unit
Permitting Manual
COMPONENT 1
How To Review A Trial Burn Plan
U.S. EPA Region 6 Center for Combustion
Science and Engineering
Tetra Tech EM Inc.
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COMPONENT ONE
HOW TO REVIEW A TRIAL BURN PLAN
JANUARY 1998
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
CONTENTS
Section Page
ABBREVIATIONS AND ACRONYMS 1-iv
BIBLIOGRAPHY 1-vi
1.0 OVERVIEW OF TRIAL BURN PLAN 1-1
2.0 REVIEWING SECTION D-5a—JUSTIFICATION FOR EXEMPTION 1-5
3.0 REVIEWING SECTION D-5b—TRIAL BURN 1-7
3.1 REVIEWING SECTION D-5b(l)—TRIAL BURN PLAN 1-8
3.1.1 Reviewing Section D-5b(l)(a)—Engineering Description of the Combustion
Unit 1-9
3.1.1.1 Reviewing Section D-5b(l)(a)(l)—Description of Combustion Unit 1
3.1.1.2 Reviewing Section D-5b(l)(a)(2)—Nozzle and Burner Design . 1-14
3.1.1.3 Reviewing Section D-5b(l)(a)(3)—Auxiliary Fuel System
Description (Type/Feed) 1-17
3.1.1.4 Reviewing Section D-5b(l)(a)(4)—Description of Waste Heat
Recovery Unit 1-19
3.1.1.5 Reviewing Section D-5b(l)(a)(5)—Prime Mover Capacity ... 1-22
3.1.1.6 Reviewing Section D-5b(l)(a)(6)—Waste Feed System
Description 1-24
3.1.1.7 Reviewing Section D-5b(l)(a)(7)—Ash Handling System .... 1-27
3.1.1.8 Reviewing Section D-5b(l)(a)(8)—Automatic Waste Feed Cut Off
Description 1-29
3.1.1.9 Reviewing Section D-5b(l)(a)(9)—Stack and Continuous Emission
Monitoring Systems 1-35
3.1.1.10 Reviewing Section D-5b(l)(a)(10)—Air Pollution Control
Systems 1-39
3.1.1.11 Reviewing Section D-5b(l)(a)(ll)—Construction Materials .. 1-46
3.1.1.12 Reviewing Section D-5b(l)(a)(12)—Location and Description of
Temperature, Pressure, and Flow Indicators and Control
Devices 1-48
3.1.1.13 Reviewing Section D-5b(l)(a)(13)—Combustion Unit Start-Up
Procedures 1-51
3.1.2 Reviewing Section D-5b(l)(b)—Sampling, Analysis, and Monitoring
Procedures 1-53
3.1.2.1 Reviewing Section D-5b(l)(b)(l)—Sampling Locations and
Procedures 1-55
3.1.2.2 Reviewing Section D-5b(l)(b)(2)—Analytical Procedures .... 1-60
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-i
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
CONTENTS (Continued)
Section Page
3.1.3 Reviewing Section D-5b(l)(c)—Trial Burn Schedule 1-64
3.1.3.1 Reviewing Section D-5b(l)(c)(l)—Schedule 1-65
3.1.3.2 Reviewing Section D-5b(l)(c)(2)—Trial Burn Duration 1-69
3.1.3.3 Reviewing Section D-5b(l)(c)(3)—Quantity of Waste to Be
Burned 1-71
3.1.4 Reviewing Section D-5b(l)(d)—Test Protocols 1-73
3.1.4.1 Reviewing Section D-5b(l)(d)(l)—Waste Characterization ... 1-75
3.1.4.2 Reviewing Section D-5b(l)(d)(2)—Principal Organic Hazardous
Constituent Selection Rationale 1-78
3.1.4.3 Reviewing Section D-5b(l)(d)(3)—Operating Conditions 1-82
3.1.4.4 Reviewing Section D-5b(l)(d)(4)—Waste Constituents 1-87
3.1.4.5 Reviewing Section D-5b(l)(d)(5)—Combustion Temperature
Ranges 1-92
3.1.4.6 Reviewing Section D-5b(l)(d)(6)—Waste Feed Rates 1-94
3.1.4.7 Reviewing Section D-5b(l)(d)(7)—Combustion Gas Velocity
Indicator 1-96
3.1.4.8 Reviewing Section D-5b(l)(d)(8)—Waste Feed Ash Content . . 1-98
3.1.4.9 Reviewing Section D-5b(l)(d)(9)—Auxiliary Fuel 1-100
3.1.4.10 Reviewing Section D-5b(l)(d)(10)—Organic Chlorine Content 1-101
3.1.4.11 Reviewing Section D-5b(l)(d)(ll)—Metals 1-103
3.1.5 Reviewing Section D-5b(l)(e)—Pollution Control Equipment Operation 1-106
3.1.6 Reviewing Section D-5b(l)(f)—Shut-Down Procedures 1-109
3.1.7 Reviewing Section D-5b(l)(g)—Combustion Unit Performance 1-112
3.2 REVIEWING SECTION D-5b(2) - NEW COMBUSTION UNIT CONDITIONS 1-114
3.2.1 Reviewing Section D-5b(2)(a) and (b)—New Combustion Unit Startup/
Shakedown Performance 1-115
3.2.2 Reviewing Section D-5b(2)(c)—New Combustion Unit Post-Trial Burn
Operation 1-118
3.2.3 Reviewing Section D-5b(2)(d)—Combustion Unit Performances 1-120
4.0 REVIEWING SECTION D-5c—TRIAL BURN SUBSTITUTE SUBMISSIONS 1-121
5.0 REVIEWING SECTION D-5d—DETERMINATIONS 1-123
5.1 REVIEWING SECTION D-5d(l)—TRIAL BURN RESULTS 1-126
5.2 REVIEWING SECTION D-5d(2)—FINAL OPERATING LIMITS 1-129
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-ii
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBITS
Exhibit Page
3.1.1.4-1 PROCESS SCHEMATIC OF WASTE HEAT RECOVERY UNIT 1-21
3.1.2.1-1 SUMMARY OF PROCESS AND FUEL STREAM SAMPLING 1-58
3.1.2.1-2 SUMMARY OF PROCESS AND FUEL STREAM ANALYSES 1-59
3.1.2.2-1 PROPOSED WASTES 1-63
3.1.3.1-1 EXAMPLE OVERALL TRIAL BURN SCHEDULE 1-67
3.1.3.1-2 EXAMPLE DAILY TRIAL BURN SCHEDULE 1-68
3.1.4.3-1 EXAMPLE TEST OPERATING PARAMETERS 1-86
3.1.4.4-1 SUMMARY OF HAZARDOUS ORGANIC CONSTITUENTS IN LIQUID
WASTE FEED 1-90
3.1.4.4.2 SUMMARY OF ESTIMATED WASTE FEED CHARACTERISTICS 1-91
3.1.4.6-1 WASTE FEED RATES, HEAT INPUT, AND AVERAGE CHLORINE INPUT . 1-95
3.1.6-1 MONITOR AND CONTROL DEVICE SPECIFICATIONS 1-111
ATTACHMENTS
Attachment
A U.S. EPA REGION 6 GENERIC TRIAL BURN PLAN
B EXAMPLE PROCESS FLOW DIAGRAM AND PIPING AND INSTRUMENTATION
DIAGRAMS (P&ID)
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
ABBREVIATIONS AND ACRONYMS
acfm Actual cubic feet per minute
APCS Air pollution control system
ASTM American Society for Testing and Materials
AWFCO Automatic waste feed cutoff
BIF Boiler and industrial furnace
Btu/hr British thermal units per hour
Btu/lb British thermal units per pound
CEMS Continuous emissions monitoring system
CERI Center for Environmental Research Information
CKD Cement kiln dust
C12 Chlorine gas
40 CFR Title 40, Code of Federal Regulations
CO Carbon monoxide
COPC Contaminant of potential concern
CSA Cross sectional area
DRE Destruction and removal efficiency
dscfm Dry standard cubic feet per minute
EPA Environmental Protection Agency
ESP Electrostatic precipitator
FID Flame ionization detector
ft3 Cubic feet
°F Degrees Fahrenheit
g/hr Grams per hour
gpm Gallons per minute
HC1 Hydrogen chloride
HHV High heating value
HRU Heat recovery unit
HWF Hazardous waste fuels
HWDF Hazardous waste derived fuels
IWS Ionizing wet scrubber
kcal/kg Kilocalories per kilogram
kVA Kilovolt Amperes
kWh Kilowatt hour
Ib/hr Pounds per hour
Ib/min Pounds per minute
LHV Low heating value
MACT Maximum achievable control technology
MB Megabyte
MMBtu/hr Million British thermal units per hour
O2 Oxygen
OSWER Office of Solid Waste and Emergency Response
PCB Polychlorinated biphenyl
PCC Primary combustion chamber
PCDD/PCDF Polychlorinated dibenzo-p-dioxin/polychlorinated dibenzofuran
PFD Process flow diagram
U.S. EPA Region 6
Center for Combustion Science and Engineering
1-iv
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
PIC Product of incomplete combustion
ABBREVIATIONS AND ACRONYMS (Continued)
PM Participate matter
POHC Principal organic hazardous constituent
ppm Parts per million
ppmv Parts per million by volume
P&ID Piping and instrumentation diagram
PSD Particle size distribution
psig Pounds per square inch gauge
QA/QC Quality assurance/quality control
QAPP Quality assurance project plan
RBP Risk burn plan
RCRA Resource Conservation and Recovery Act
SCC Secondary combustion chamber
SDA Spray dryer absorbers
SOP Standard operating procedures
SRE System removal efficiency
SVOC Semivolatile organic compound
TBP Trial burn plan
TBR Trial burn report
THC Total hydrocarbon
TID Technical Implementation Document
TOC Total organic carbon
TOX Total organic halogen
U.S. EPA U.S. Environmental Protection Agency
VOC Volatile organic compound
WESP Wet electrostatic precipitator
U.S. EPA Region 6
Center for Combustion Science and Engineering
1-v
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
BIBLIOGRAPHY
Arthur D. Little, Inc. 1984. "Sampling and Analysis Methods for Hazardous Waste Combustion."
EPA-600-/8-84-002.
U.S. EPA. 1990. "Methods Manual for Compliance with BIF Regulations." Office of Solid Waste
and Emergency Response (OSWER). EPA/530/SW-91/010. December.
U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incinerator Permits." OSWER.
Washington, D.C.
U.S. EPA. 1986. "Practical Guide—Trial Burns for Hazardous Waste Incinerators." Office of
Research and Development (ORD). Cincinnati, Ohio. EPA/600/2-86/050. April.
U.S. EPA. 1987. "Permitting Hazardous Waste Incinerators." Seminar Publication. Center for
Environmental Research Information (CERI). Cincinnati, Ohio. EPA/625/4-87/017.
U.S. EPA. 1989. "Handbook: Guidance on Setting Permit Conditions and Reporting Trial Burn
Results." Volume II of the Hazardous Waste Incineration Guidance Series. ORD.
Cincinnati, Ohio. EPA/625/6-89/019. January.
U.S. EPA. 1989. "Handbook: Hazardous Waste Incineration Measurement Guidance Manual."
Volume III of the Hazardous Waste Incineration Guidance Series." OSWER. Washington,
D.C. EPA/530/R-89/019. June.
U.S. EPA. 1990. "Handbook: Quality Assurance/Quality Control (QA/QC) Procedures for
Hazardous Waste Incineration." CERI. Cincinnati, Ohio. EPA/625/6-89/023. January.
U.S. EPA. 1996. "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, (SW-
846)." Third Edition. December.
U.S. EPA. 1992. "Technical Implementation Document (TID) for EPA's Boiler and Industrial
Furnace Regulations." OSWER. Washington, D.C. EPA-530-R-92-011. March.
U.S. EPA. 1997. "Guidance on Structuring RCRA Trial Burns for Collection of Risk Assessment
Data." U.S. EPA Region 4. Atlanta, Georgia. September.
U.S. EPA 1997. "Generic Quality Assurance Project Plan (QAPP)." Center for Combustion Science
and Engineering, Multimedia Planning and Permitting Division, U.S. EPA Region 6. Dallas,
Texas. December.
U.S. EPA 1997. "Generic Trial Burn Plan (TBP)." Center for Combustion Science and Engineering,
Multimedia Planning and Permitting Division, U.S. EPA Region 6. Dallas, Texas. December.
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 1-vi
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-vii
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
1.0
OVERVIEW OF TRIAL BURN PLAN
Regulations:
Guidance:
Explanation:
Check For:
No regulations are applicable to this section of the manual.
No specific references are applicable to this section of the manual.
This section is not required by regulation and may not be a part of all trial burn
plans (TBP); however, inclusion of this section in a TBP is recommended (see
the U.S. EPA Region 6 generic TBP included as Attachment A). This section
should present general facility information, the purpose for submitting the TBP,
and the organization of the TBP.
General facility information should include the facility name, contact, address, and
telephone number; U.S. Environmental Protection Agency (EPA) identification
number; the name of the person responsible for trial burn; and his or her
company name, address, and telephone number.
The four most common purposes for submitting a TBP include the following:
• New facilities seeking a permit to operate hazardous waste
combustion units, such as an incinerator, cement kilns, or boiler
and industrial furnaces (BIF)
• Existing facilities operating under interim status
• Existing permitted facilities seeking permit modifications, and
• Existing facilities seeking renewal of hazardous waste permits
A TBP is a critical part of a Resource Conservation and Recovery Act (RCRA)
Part B permit application. Therefore, the remaining sections of this component
are referred to by their Part B Permit application section (for example,
Section D-5a—Justification for Exemption) as listed in the checklist for Review
of Federal RCRA Permit Applications included as Attachment B to Component 3
of this manual. These section listings also correspond to sections in the U.S.
EPA Region 6 generic TBP. A TBP is usually required to be submitted as a
stand-alone document. A stand-alone document is suggested because the TBP
may be revised more than once before it is finalized and it would be convenient
for both the applicant and the reviewer to be able to review the document
separately from the permit application. It would be useful, for example, that the
section, table, and figure numbering be independent from that of the permit
application. In addition, the TBP should contain all information associated with
the combustion unit and should not refer to other sections in the permit
application.
The reviewer of the TBP should check for the following information:
U.S. EPA Region 6
Center for Combustion Science and Engineering
1-1
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
General facility information
Q Facility name
Q Contact
Q Address
Q Telephone number
Q U.S. EPA identification number
Person responsible for trial burn operations
Q Company name
Q Address
Q Telephone number
Risk assessment information
Q Principal business and primary production processes
Q Normal and maximum production rates
Q Type of waste storage and treatment facilities
Q Type and quantity of wastes stored and treated
Q Type of air pollution control system (APCS)
Q Energy consumption and production rates (for example, British
thermal units per hour [Btu/hr], kilowatts per hour [kWh], cubic
feet of natural gas per minute, or pounds of steam per hour)
Purpose of the TBP
Q New facility seeking a permit to operate hazardous waste
combustion units, such as an incinerator, cement kilns, or BIF
Q Existing facility operating under interim status
Q Existing permitted facility seeking permit modifications
Q Existing facility seeking renewal of hazardous waste permit
Is the TBP a stand-alone document?
Does the TBP contain separate sections with the following information:
Q A detailed engineering description of the incinerator, cement kiln,
or BIFs for which the permit is sought, in accordance with Title
40 Code of Federal Regulations (CFR) Parts 270.62(b)(2)(ii)(A
through J) and 270.66(c) (see Section 3.1.1)
Q An analysis of each waste or mixture of wastes to be burned for
physical characteristics and chemical constituents that are
believed to be present in the wastes and for those listed in 40
CFR Parts 270.62(b)(2)(i)(A through D) and 270.66(c)(l) and
(2) (see Section 3.1.1.1)
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-2
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Example Situation:
Q A detailed description of sampling and monitoring procedures in
accordance with 40 CFR Parts 270.62(b)(iii) and 270.66(c)(4),
including sampling and monitoring locations in the system, the
equipment to be used, sampling and monitoring frequency, and
planned analytical procedure for sample analysis (see
Section 3.1.2)
Q A detailed test schedule for each test condition for which the trial
burn test is planned in accordance with 40 CFR
Parts 270.62(b)(iv) and 270.66(c)(5), including date(s), duration,
and type and quantity of waste to be burned (see Section 3.1.3)
Q A detailed test protocol for each test condition identified in
accordance with 40 CFR Parts 270.62(b)(v) and 270.66(c)(6),
including the temperature range, type of waste, waste feed rate,
combustion gas velocity, use of auxiliary fuel and any other
relevant parameters that will be varied to affect the destruction
and removal efficiency (DRE) of the combustion unit (see
Section 3.1.4)
Q A description of and planned operating conditions in accordance
with 40 CFR Parts 270.62(b)(vi) and 270.66(c)(7) for any
emission control equipment which will be used (see Section
3.1.5)
Q Procedure for rapidly stopping waste feed, shutting down the
combustion unit, and controlling emissions in the event of an
equipment malfunction in conformance with 40 CFR
Parts 270.62(b)(vii) and 270.66(c)(8) (see Section 3.1.6)
Q Any other information as the writer reasonably finds necessary
to approve the TBP in accordance with 40 CFR Parts 270.62(b)
(viii) and 270.66(c)(9)
A trial burn plan may also be submitted as a test plan for the collection of data
for—or in conjunction with—a risk assessment. In these cases, the TBP may be
referred to as a "risk burn plan" (RBP). Information that may be collected as
part of a risk assessment is identified throughout the combustion unit permitting
manual, and is described in detail in Section 2.10 of Component 3.
Lois and Clark of Metropolis were selected to review the TBP for XYZ
Chemicals (XYZ). As the initial step in the review process, Lois checks the
general facility information provided by XYZ as follows:
"XYZ Chemicals (XYZ), is located on Tennessee State Highway 79 North in
Pike County near the town of Clarksville, Tennessee. Appendix A shows the
location of the facility on the U.S. Geological Survey topographic map for
Pleasant Hill West, Tennessee/Kentucky. XYZ operates a wet process cement
kiln that uses hazardous waste-derived fuels (HWDF) to supplement the normal
coal/coke fuel. AB Company (ABC) functions as an on-site HWDF supplier.
Facility contact information is provided in the following table.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Example Action:
Facility Name
Facility Address
Facility Contact/Phone
HWDF Facility Name
HWDF Facility Address
HWDF Facility Contact
Phone
XYZ Chemicals
Highway 79 North
P.O. Box 67
Clarksville, Tennessee 37201
Mr. Bill Boom, Plant Manager
(615)555-1191
AB Company
Highway 79 North
P.O. Box 69
Clarksville, Tennessee 37201
Mr. Ted McMahon, Facility Manager
(615)555-1892
"XYZ currently operates as a RCRA interim status facility that complies with
BIF regulations outlined in 40 CFR Part 266 Subpart H. The purpose of the TBP
is to seek hazardous waste permit for the cement kiln at XYZ. The trial burn will
be conducted to demonstrate compliance with performance standards and to
provide data necessary to establish operating limits while feeding HWDF."
Lois reviews this section and finds useful information concerning the facility and
purpose of the TBP submittal. However, she does not find a discussion on how
the document is organized (by section) or a summary of section content. She
recommends inclusion of an organizational and content summary to facilitate
TBP review. Lois adds this item to the list requiring additional information from
the facility.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
1-4
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
2.0
REVIEWING SECTION D-5a—JUSTIFICATION FOR EXEMPTION
Regulations: 40 CFR Part 264.340(b) and (c)
40 CFR Part 266.100(b)(l-4)
40 CFR Part 270.19(a)
Guidance: U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incinerator
Permits." Office of Solid Waste and Emergency Response (OSWER).
Washington, D.C. July. Section 2.1.3, Pages 2-6 through 2-15.
U.S. EPA. 1987. "Permitting Hazardous Waste Incinerators." Seminar
Publication. Center for Environmental Research Information (CERI).
Cincinnati, Ohio. EPA/625/4-87/017. September. Pages 75 through 78.
U.S. EPA. 1992. "Technical Implementation Document (TID) for EPA's Boiler
and Industrial Furnaces (BIF) Regulations." OSWER. Washington, D.C.
EPA/530/4-92/11. March. Section 1.2.3, Pages 1-2 and 1-3.
Explanation: Facilities operating a hazardous waste combustion unit seeking exemption from
conducting a trial burn should provide justification for such exemption. Several
specialized exemptions and waivers are available for permits. These are
exemptions based primarily on combustion unit design, waste feed characteristics,
and the intent to burn hazardous wastes. Referenced guidance documents
discuss the various RCRA exemptions, waivers, and petitions for hazardous
waste combustion units. If the U.S. EPA Regional Office or authorized state
permitting agency determines a facility to be exempt, then a DRE trial burn will
not be required. However, it is current U.S. EPA Region 6 policy that facilities
will not be exempt from submitting a RBP and conducting a risk burn test.
Check For: The TBP reviewer should check for the following information:
Q Waste analysis information
Q Waste sampling and analysis method (SW-846)
Q Applicant's justification for seeking exemption
Q Hazardous wastes being burned exhibit one or more of the
following characteristics: ignitability, corrosivity, or reactivity
(combustion units burning wastes exhibiting toxicity
characteristics are not exempt).
Q Waste contains insignificant concentrations (less than 100 parts
per million [ppm]) of hazardous constituents listed in Appendix
VIII of 40 CFR Part 261.
Q Used oil is being burned for energy recovery.
Q Gas burned is being recovered from hazardous or solid waste
landfills for energy recovery.
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-5
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q Hazardous wastes being burned are exempted from regulation
under 40 CFR Parts 261.4 and 261.6(a)(3)(v-viii). These include
materials that are not solid wastes, nonhazardous solid wastes,
treatability study samples, and fuels produced from refining of
hazardous wastes.
Q Hazardous wastes being burned are subjected to special
requirements for conditionally exempt small quantity generators
under 40 CFR Part 261.5.
Q Coke ovens only burning decanter tar sludge from coking
operation (K087 waste).
Q Hazardous waste is being processed in smelting, melting, and
refining furnaces solely for metal recovery.
Q Small-quantity hazardous waste burners. Quantity limits are
established as a function of stack height under 40 CFR
Part 266.108.
Example Section: Lois and Clark review XYZ Company's Part B permit application and come
across a statement seeking exemption from conducting trial burn for one of the
boilers because it burns only ignitable wastes generated at the facility. Clark
reads the following section providing the justification for exemption:
"The boiler at XYZ Company is a captive unit, and it is used only for thermal
destruction of in-process wastes from the facility. In-process waste is
considered a listed waste solely because of its ignitability (Hazard Code I). In-
process waste contains insignificant concentrations (less than 100 ppm) of
Appendix VIII constituents."
Example Comments: Despite the facility's valid justification for exemption, Clark thoroughly reviews
the supporting documentation to verify whether the (1) combustion unit is used
for combustion of wastes other than in-process wastes; (2) waste sampling
procedures follow at least U.S. EPA's standard operating procedures (SOP), if
not more stringent procedures; (3) wastes burned in the combustion unit are
analyzed for all constituents that may potentially be present; and (4) U.S. EPA
analytical methods are used for waste analysis. Based on the review, Clark
determines that the XYZ Company has a valid justification for exemption from
conducting trial burn, however, he still sees the need for conducting a risk burn
test to ensure that operation of the unit will be protective of human health and the
environment. Clark notifies XYZ Company that a DRE test would not be
required but prepares a comment requesting the facility conduct a risk burn under
U.S. EPA Omnibus Authority, see 40 CFR Part 270.32(b)(2).
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-6
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.0
REVIEWING SECTION D-5b—TRIAL BURN
Regulations:
Guidance:
Explanation:
Check For:
Example Sections:
40 CFR Part 270. 19(b)
40 CFR Part 270.22(a)
No specific references are applicable to this section of the manual.
This section should summarize information presented in the following subsections.
This will provide the reader with an idea on the contents presented in the ensuing
sections. These sections include:
• New combustion unit start-up/shakedown performance
TBP
Although not required by the regulations, inclusion of this section is recommended
to facilitate the TBP review.
The TBP reviewer should check for the following information:
Q Subsections of Section 3.0 should be included in the TBP
Q TBP (see Section 3.1)
Q New combustion unit conditions (see Section 3.2)
The following subsections provide BIF startup/shakedown operating conditions
and an engineering description of the combustion system, and describe the testing
program designed to meet performance requirements of RCRA regulations and
U.S. EPA guidance.
Example Comment: Not applicable to this section of the manual.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1 REVIEWING SECTION D-5b(l)—TRIAL BURN PLAN
Regulations:
Guidance:
40CFRPart270.19(b)
40 CFR Part 270.22(a)
No specific references are applicable to this section of the manual.
Explanation: The following subsections summarize the information typically provided within a
TBP.
Check For:
Example Sections:
Refer to Subsections 3.1.1 through 3.1.7 for specific guidance.
Lois reads the following brief introductory paragraph provided in this section of a
TBP. The following TBP discusses engineering details of the XYZ Company,
combustion system and outlines trial burn operating conditions, sampling and
monitoring procedures, and analytical methods that will be used to establish
operating parameters for the final permit.
Example Comments: Lois notes that (1) this paragraph adequately introduces the information to be
presented and (2) all of the necessary subsections have been included in the
TBP. She continues with her review.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1 Reviewing Section D-5b(l)(a)—Engineering Description of the Combustion Unit
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 270.62(b)(2)(ii)
40 CFR Part 270.62(b)(2)(ii)(A)
40CFRPart270.66(c)(3)
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.1 through D-5.24.
This section should introduce Subsections 3.1.1.1 through 3.1.1.13. It should
generally contain, or refer to, written equipment specifications, process flow
diagrams (PFD) and piping and instrumentation diagrams (P&ID) (see
Attachment B), equipment arrangement, and process control logic diagrams.
If the unit is custom-designed to meet the requirements of the facility, the TBP
should provide the name and location of the companies that designed the process
and supplied equipment for the combustion unit. The TBP should also contain the
manufacturer's design and operations manual for the combustion unit. The TBP
should contain design basis calculations concerning size, heat release,
temperature, and APCS performance. The "Check For" items identified below
should be incorporated in the TBP. It is recommended that this information be
presented under this section heading.
The TBP reviewer should check for the following information:
Q Written equipment specifications
Q PFDs
a P&IDS
Q Equipment arrangements
Q Process control logic diagrams
Q Preparer of engineering diagram and specifications
Q Site development contractor
Q Contractor for construction and equipment installation
Q Date of installation
Q Manufacturer's operation and maintenance manuals
Q Fabricator shop drawings
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Q Construction quality assurance (QA) report from an independent
engineer
Q Design basis calculations
Q Size
Q Heat release
Q Temperature
Q APCS performance
Example Sections: Refer to the referenced sections of the U.S. EPA Region 6 generic TBP.
Example Comment: Not applicable to this section of the manual.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.1 Reviewing Section D-5b(l)(a)(l)—Description of Combustion Unit
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Parts 270.62(b)(2)(ii)(B) and (C)
40 CFR Parts 270.66(c)(3)(i-iii)
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science and
Engineering. Pages D-5.1 through D-5.24.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." EPA-R6-098-002. Section 2.2.2.
This section should include shape, orientation, dimensions, cross-sectional area,
and volume of the primary combustion chamber (PCC). If the combustion unit
has a secondary combustion chamber (SCC), the same information for the SCC
should be included. If burner, combustion, and cross-over sections of
combustion chambers are of varying dimensions and cross sections, each of
these sections should be described. Waste and gas residence time in combustion
chambers should be provided. For rotary kilns, rotational speed should be
included.
The TBP reviewer should check for the following information:
Q Shape (cylindrical or rectangular)
Q Outside diameter (feet or meters)
Q Inside diameter (feet or meters)
Q Thickness of refractory lining (inches or centimeters)
Q Length (feet or meters)
Q Height or width (feet or meters)
Q Cross-sectional area (CSA; square feet or square miles)
(inside diameter by length or height, or width by length)
Q Orientation (horizontal, vertical, or inclined)
Q Slope, if inclined (degrees or inches or feet)
Q Rotational speed (revolutions per minute) for rotary kilns
Q Volume (cubic feet or cubic meters)
Q Cooled surface area (cubic feet or cubic meters)
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Q Residence time (seconds)
Q When discussing residence times, the TBP should state the associated
gas flow or waste feed rates
Q Whether volume of cross-over duct, between the PCC and SCC, is
included in the calculation of SCC residence time
Q Information for risk assessment:
Q Summary of past operating data indicating the frequency and
duration of combustion unit leaks
Q Information regarding the probable cause of all combustion unit
leaks
Q Summary of procedures in place to monitor or minimize fugitive
emissions resulting from combustion unit leaks
Q Brief discussion of:
Q Wastes burned
Q Technique by which wastes are fired into the PCC and SCC
Q Ash handling
Q How combustion gases will be handled
Q Typical combustion gas flow rate
Q Safety measures observed during operation of combustion unit
Example Situation: Clark reads the Description of Combustion Unit section of the RBP as follows:
"The front-end feed train takes appropriate bulk solid wastes through weigh
hoppers into a rotary kiln by either a hydraulic ram or a drag feed unit. Nozzles
and burners on the faceplate of the kiln provide injection points for various
pumpable waste streams.
The kiln is designed to operate at a maximum heat release of 25 x 106 Btu/hr.
The hot ash conveyor is of the metallic-pan type. Inert ash residues are carried
up the conveyor for discharge into roll-off boxes.
The SCC is a vertical, refractory-lined afterburner. It has one SCC burner and is
designed to operate between 1,800°F and 2,400°F."
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Example feed end of a combustion unit, showing waste feed guns
Example Action:
The description of the combustion unit lacks detail. Neither dimensions nor
residence times are provided for the rotary kiln or the SCC. Kiln slope and
rotational speed are also not provided. Clark prepares a comment requesting the
facility revise this section to include dimensions, CSAs, volumes, kiln and SCC
residence times, kiln rotational speed and slope, and residence time calculations.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.2 Reviewing Section D-5b(l)(a)(2)—Nozzle and Burner Design
Regulations: 40 CFR Part 270.62(b)(2)(ii)(H)
Guidance:
Explanation:
Check For:
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science and
Engineering. Pages D-5.1 through D-5.24.
A combustion unit that burns liquid waste will typically either (1) use the waste as
a fuel through the burner (if the waste has a high heating value [HHV]), or
(2) atomize waste into a combustion chamber fired by a burner operating on an
auxiliary fuel (if the waste has a low heating value [LHV]). RCRA regulations
and guidance generally regard the heating value that separates these two is 5,000
Btu/lb. In some cases, this definition may be an oversimplification. Generally,
burner specifications, desired flame temperature, and desired flame shape will
determine the type of waste material fed through a certain type of burner.
Liquid fuel "burners" consist of devices ranging from plain liquid atomizers to
equipment that is designed to atomize and mix the atomized liquid with
stoichiometric amounts of air for combustion. Depending on the design, the
mixing in such system ranges from very poor to good. A HHV waste (greater
than 8,000 British thermal units per pound [Btu/lb]), can be burned easily in a
good burner or combustor that provides good liquid atomization and good mixing,
but it will be difficult to burn in a burner that cannot provide at least one of these
requisites.
Proper atomization of low heating value LHV waste into a high-temperature gas
stream containing adequate excess oxygen (O2) can oxidize hydrocarbons in the
steam. Atomization can be achieved by (1) pressure loss of the liquid across the
nozzle, known as mechanical atomization, or (2) the use of a second fluid (usually
air or steam) at pressure to provide atomizing energy.
Most nozzles designed to atomize viscous liquids use a pneumatic fluid steam,
compressed air, or nitrogen to properly break up the viscous stream into droplets
that can be carried into the combustion zone. Nozzle-type burners can
satisfactorily burn wastes with heating values of about 2,500 kilocalories per
kilogram (kcal/kg; equal to 4,500 Btu/lb) and above without auxiliary fuel.
The TBP reviewer should check for the following information:
Q PCC and SCC burner identification (manufacturer and model number),
specifications, and drawings (there is no need to identify burners that are
not used for waste injection).
Q PCC and SCC burner type
Q Burners location
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q Burner size (Btu/hr)
Q Atomizing fluid pressure (Provide explanation if different from design
specifications)
Q Type of atomizing fluid (steam, compressed air, or nitrogen)
Q Waste viscosity
(this information may be presented in the waste characteristics section)
Q Particle size and quantity of solids in waste
(this information may be presented in waste characteristics section)
Q Minimum heating value of PCC and SCC burners
Q Heating value of the waste (kcal/kg or Btu/lb)
(this information may be presented in waste characteristics section)
Q Heating value of auxiliary fuel (kcal/kg or Btu/lb)
Q Excess air levels used by burners (percent)
Q Burner pressure
Q Internal flow areas
Q Turndown ratio
Q Flame safety controls
Q Pilot mechanism
Example Situation: Lois reads the Nozzle and Burner Design section of the TBP as follows:
"Two liquid waste injectors in the lower (primary) combustion chamber
simultaneously inject high- and low-Btu liquids. Spraying Systems AE-5 dual
fluid nozzles, rated at 72 to 425 gallons per hour, are used for waste atomization.
Solids are fed to the lower chamber with a pneumatic ram feeder. The chamber
has a pneumatically operated, electrically interlocked airlock charging door."
Example Action:
Lois finds the description very brief and inadequate. Based on the information
provided, Lois cannot determine nozzle locations, whether they are internally or
externally atomized, the atomizing medium, and the range of viscosities under
which the nozzles can optimally atomize liquid wastes. Above all, she finds the
description lacking information related to size, atomization pressure, and the
design heating value for the burner. Based on the information, she cannot
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
determine if the Spraying Systems AE-5 represents the manufacturer or model
number. Lois asks the facility for a more detailed description of burner system
components and operations and lists the information required for a complete
review.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-16
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.3 Reviewing Section D-5b(l)(a)(3)—Auxiliary Fuel System Description (Type/Feed)
Regulations: 40 CFR Part 270.62(b)(2)(ii)(D)
Guidance:
Explanation:
Check For:
Example Situation:
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.1 through D-5.24.
Natural gas and fossil fuel are commonly used as auxiliary fuels in combustion
units. Auxiliary fuels are used in the PCC and SCC to compensate for the LHV
of the wastes. When wastes and auxiliary fuels are fired from a common burner,
the total heating value of the mixture should be above the minimum heating value
of the burner to maintain desired combustion conditions in combustion zones.
The TBP reviewer should check for the following information:
Q Auxiliary fuel type
Q Whether auxiliary fuel is used to heat the combustion chamber before
waste is introduced (if so, provide the desired preheat temperature)
Q Auxiliary fuel source
Q How the source auxiliary fuel supplies to the burners
Q Auxiliary fuel burner rating and capacity
Q Auxiliary fuel heating value
Q Whether the burner is dedicated to firing auxiliary fuel or also fires
wastes
Q Heating value of the wastes to be fired in the burner
(this information is also presented in the waste characteristics section)
Q Whether the combined heating value of the waste and fuel mixture
exceeds the minimum heating value of the burner (if the burner is used to
fire wastes and auxiliary fuel)
Q Whether the natural gas supply is adequately regulated to provide the
required ignition, pilot, and fuel gas
Q Whether each burner gas supply line is provided with independent
monitors, controls, interlocks, and fail-safe device, as required by the
National Fire Protection Agency (if more than one burner is used)
Clark reads Has Auxiliary Fuel System Description (Type/Feed) section of the
TBP as follows:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
"The rotary kiln contains a combination fuel oil/waste burner. This dual-purpose
burner is rated at 26 million Btu/hr (MMBtu/hr) and has a firing capacity of 3
gallons per minute (gpm) for fuel oil or 6 gpm for waste feeds. The burner does
not fire fuel oil and waste simultaneously. The kiln contains two pumpable sludge
lances that are interchangeably steam, air, or nitrogen atomized; however, no
sludge will be used during this trial burn.
"During permitted operating conditions (for example, temperatures above
1,600°F), waste liquid will be fired through the kiln burner. Fuel oil will be fired
during heat up and low temperature periods for operation. Fuel oil and waste
liquid feed rates are both continuously recorded.
"The SCC unit is equipped to burn either liquid waste or fuel oil through two
46 MMBtu/hr burners. Each burner is rated at a maximum of 150 pounds per
minute (Ib/min) waste feed. The minimum combustion temperature maintained in
the SCC will be 2,200°F while burning poly chlorinated biphenyls (PCB)."
Example Action:
Clark finds no design data for sludge lances in the kiln. Also, Clark discovers
that the sludge lances will not be used during the trial burn. In his letter to the
company, Clark requests that the facility provide design data for sludge lances
and conduct a sludge lance demonstration before lances are allowed to function
during normal operations.
Notes:
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Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.4 Reviewing Section D-5b(l)(a)(4)—Description of Waste Heat Recovery Unit
Regulations: 40 CFR Part 260.10
Guidance:
Explanation:
Check For:
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.1 through D-5.24.
If applicable, the TBP should include a description of the waste heat recovery
unit (HRU). An HRU may be an integral part of the combustion unit design—as
in the case of a boiler—or may be a secondary energy recovery device (such as
an economizer or air preheater). For a combustion unit to be defined as a boiler,
the PCC (or SCC) and HRU must be of integral design; that is, the combustion
chamber and the primary energy recovery section(s) (such as materials and
superheaters) must be physically formed into one manufactured or assembled
unit. Boilers are typically classified by either the method of heat transfer
(water-tube, fire-tube, or cast-iron boilers) or the fuel-firing system that is used
(stoker-fired or suspension-fired). Exhibit 3.1.1.4-1, see page 1-21, presents a
process schematic of a waste heat recovery unit attached to an incinerator.
The TBP reviewer should check for the following information:
Q HRU type
Q Manufacturer name and model number
Q Construction materials
Q Dimensions, CSA, and volume of the HRU
Q Brief description of HRU operations
Q HRU combustion gas residence time
Q Design and anticipated steam generation rates, if applicable
(Ib/hr and pounds per square inch gauge [psig] steam °F)
Q Design and anticipated air preheating capacity, if applicable (include air
flow rates and temperature gradient)
Q HRU design standards
Q Unit from which heat is recovered (PCC or SCC)
Q Combustion gas temperature at HRU entry and exit
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Center for Combustion Science and Engineering
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Example Situation:
Lois and Clark read the Description of Waste Heat Recovery Unit section of
the TBP as follows:
"The facility uses a forced-draft horizontal chamber combustion process fume
and liquid waste incinerator and waste heat boiler to thermally destroy vapor-
phase and liquid wastes generated in the production process. The process
operates 24 hours per day, 5 days per week. The incinerator and waste heat
boiler system operate continuously during the process.
"Combustion Engineers of Beverly Hills, California, supplied the incinerator and
boiler system in 1974. A waste heat boiler was incorporated into the process to
recover a portion of the energy content of the hot combustion gases.
"The incinerator and waste heat boiler are installed in series and are located
outdoors on an elevated platform.
"Crossover ducting connects the discharge end of the combustion chamber to the
waste heat boiler."
Example Action:
Lois and Clark note that this section lacks a general description of the boiler,
including its design, type, dimensions, steam production rate and pressure,
construction materials, and volume or gas-phase residence time. It fails to
describe the temperature of the gas entering or exiting the boiler. There is no
discussion on controls or emergency shutoff conditions, and this section mentions
only that the boiler is connected to the combustion chamber. Lois adds these
items to the list that requires additional information from the facility. Clark
becomes concerned about the gross inadequacies of the TBP and decides to
issue the facility an administrative order.
Notes:
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Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.1.4-1
PROCESS SCHEMATIC OF WASTE HEAT RECOVERY UNIT
LEGEND
A-COMBUSTION AIR
B - REACTOR FUMES
C-AQUEOUS WASTE
D-SOLVENT WASTE
E-PET TANK FUMES
F-ATOMIZING STEAM
G-VES EXHAUST
H - STACK EXHAUST
I-N.G. FUEL
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Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.5 Reviewing Section D-5b(l)(a)(5)—Prime Mover Capacity
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 270.62(b)(2)(ii)(E)
U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." OSWER. Washington, D.C. EPA-530-R-92-011. March. Pages
4 through 9.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science and
Engineering. Pages D-5.1 through D-5.24.
Combustion units can be fired under positive (forced-draft), negative
(induced-draft), or balanced (forced- plus induced-draft) pressures. Forced-draft
pressure is typically used unless the facility is equipped with an APCS. Because
high-efficiency APCSs often results in high-pressure drops, a balanced-draft
system is often used. This configuration prevents the PCC from operating under
excessive positive pressure, thereby overcoming flow restrictions in the APCS.
Maintaining the proper pressure in the chamber is important for equipment safety
and for controlling fugitive emissions.
Q Prime mover type (centrifugal fan or equivalent)
Q Mode of prime mover operation, such as induced-draft (negative
pressure), forced-draft (positive pressure), or balanced systems
Q Fan speed actual cubic feet per minute (acfm) (design and operating
conditions)
Q Air density (a function of gas temperature, absolute pressure, and
molecular composition)
Q Fan differential (total, velocity, and static)
Q Fan power
Q Prime mover capacity (vacuum pressure [inches of water column])
Q Prime mover horsepower
Q Volumetric flow capacity (acfm)
Q Gas temperature (°F)
Q Minimum combustion temperature and residence time
Q Amount and distribution of combustion air
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Example Situation: Clark reads the Prime Mover Capacity section of the RBP as follows:
"Downstream of the demister, two induced-draft fans (one for each scrubber
train) provide the draft needed to overcome the pressure drop through the
hydrochloric acid (HC1) scrubber and ionizing wet scrubber (IWS) units and
maintain the incinerator system at a slight negative pressure to prevent fugitive
emissions. The fans discharge into one 90-foot-high stack."
Example Action:
Notes:
An ionizing wet scrubber used to remove HC1
This section is inadequate. Clark asks that the facility indicate the manufacturer
of the prime mover and expand this section to include all pertinent information.
U.S. EPA Region 6
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.6 Reviewing Section D-5b(l)(a)(6)—Waste Feed System Description
Regulations:
Guidance:
40 CFR Part 270.62(b)(2)(ii)
40 CFR Part 270.66(c)(3)(iv) and (v)
U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." OSWER Washington, D.C. EPA-530-R-92-011. March.
Pages 4-4 and 4-5.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.1 through D-5.24.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." EPA-R6-098-002. Section 2.2.1.
Explanation: To ensure thorough review and evaluation of the proposed waste feed system,
this section should provide a complete, detailed description of the system and
operation. This information is also used to determine potential fugitive emissions
from the system for inclusion in the risk assessment. Wastes are fed into the
combustion unit in a batch or a continuous mode. Feed mechanisms are diverse.
Liquid wastes are often pumped into combustion units through a nozzle. A
conveyor or gravity system may be used to feed solid wastes in bulk or in
containers. The waste feed rate can be monitored in various ways, depending on
feed type encountered. Feed rates of constituents, such as metals, total chlorine
gas (C12) and HC1, and ash, are monitored by knowing the concentration of the
constituent in each feed stream and continuously monitoring the flow rate of each
feed stream.
Solid hazardous wastes are generally held and mixed in staging areas under
negative pressure. Exhaust gases from this area are either used as combustion
air in the combustion unit or passed through a carbon adsorption filter.
Check For: The TBP reviewer should check for the following information:
Q Type of waste material fed to the PCC, or SCC (HHV or LHV liquid
wastes, solid wastes, and sludge)
Q Continuous or batch mode
Q Waste source
Q Processes that generate wastes
Q Waste storage areas
Q Description of blending procedures, if applicable, before firing (mixers,
external recycling pumps, or air or steam spargers)
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q Methods used to manage vent gases from waste storage tanks
(exhausted to the incinerator chamber, treated separately, or released
directly to the atmosphere). This section should also identify the
following:
Q Number of vents
Q Estimated flow rate or emission rate from each vent
Q Methods for calculating flow or fugitive emission rates
Q Methods for controlling, monitoring, and verifying calculated flow
or emission rates
Q Identification of all components in the storage and feed system (tanks,
pump, mixers, piping, valves, and nozzles), including the following details
for each such device:
Q Number and location
Q Construction materials
Q Estimated fugitive emission rate
Q Method for calculating, controlling, and monitoring fugitive
emission rates
Q Measures taken to prevent blockage of nozzles used in firing wastes, if
liquid wastes are known to contain some solids
Q Pumps used to transport wastes from storage units to the combustion unit
(such as progressive-cavity, gear, or diaphragm pumps)
Q Construction material and size of pumps and ducts
Q Methods of monitoring waste feed rate
Q Method of transferring wastes from storage unit to combustion unit
Q Feed rate of each waste burned
Example Situation: Lois reads the Waste Feed System Description section of the TBP as follows:
"The front-end feed train takes appropriate bulk solid waste through weigh
hoppers into a rotary kiln by either a hydraulic ram or a drag feed unit.
Wastes—containerized in plastic, steel, or fiber drums or fiber boxes—are fed
into the kiln through a hydraulically activated side port on the ram feeder unit and
a gravity-fed auxiliary feed conveyor on the upper level of the ram feeder unit.
Maximum Btu content per charge will not exceed 2 million, and a maximum of
4,000 Ib/hr of containers will be fed during trial burn tests.
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Nozzles and burners on the faceplate of the kiln provide injection points for
various pumpable waste streams.
The heart of the system is the rotary kiln, which is designed to operate from
1,500 to 2,000 °F. All of the nonliquid and aqueous wastes and some of the liquid
organic wastes are combusted in the kiln.
The rotary kiln faceplate is provided with a variable flame-length burner equipped
with air atomization and combustion air nozzles. Other nozzles found on the
faceplate include those for high and low Btu and direct injection. The kiln is
designed to operate at a maximum heat release of 25 MMBtu/hr.
The SCC is a vertical, refractory-lined afterburner. It has one burner and is
designed to operate from 1,800 to 2,400°F. The SCC burner is designed to
release a maximum of 30 MMBtu/hr."
Example Action:
Lois notes that this section is inadequate and incomplete in many areas. For
example, the statement that nozzles and burners provide injection points for
"various" pumpable streams is too broad; it should define "pumpable stream" and
describe physical and chemical characteristics. This section should also provide
information on "direct injection."
She further notes that this section does not discuss waste storage areas, waste
blending practices, liquid storage tank vents, construction materials, or how
wastes are piped to the rotary kiln. It does not describe nozzles and burners,
drawings, maximum particle size in liquid streams, or flow meters, nor does it
discuss regulating the total flow of liquids or burner management. It also does
not discuss how waste feed rate is monitored to control temperature in the rotary
kiln or SCC.
Finally, this section mentions a burner but fails to discuss its type or how
temperature is maintained in the SCC. Although a figure in the plan indicates
that the SCC has a natural gas-fuel oil burner and a high-Btu organic liquid
burner, the text discussed neither. Lois asks that the facility revise this section
based on her review comments.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.7 Reviewing Section D-5b(l)(a)(7)—Ash Handling System
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 270.62(b)(2)(ii)
40CFRPart270.66(c)(3)
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.1 through D-5.24.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." EPA-R6-098-002. Section 2.2.1, Page 2-2.
Ash generated during the combustion process will exit the combustion chamber
as either bottom ash or particulate matter (PM). In the case of a cement kiln,
ash collected in the APCS is referred to as CKD. Because incinerators designed
to burn solids and cement kilns will generate significant amounts of bottom ash,
they are generally equipped with ash disposal chutes. Liquid injection
incinerators often produce very small amounts of bottom ash, which are usually
removed in the APCS. Although current RCRA regulations do not address the
quality of incinerator residue (the degree of complete combustion of ash leaving
the kiln), many state and local regulatory agencies require that combustion units
operate in a manner that prevents an ash disposal problem. To comply with state
and local regulations, facilities may be required to routinely analyze this ash prior
to its ultimate disposal.
One of the main concerns about the ash handling system is that fugitive emissions
will be generated during the removal of bottom ash from the combustion
chambers. The increased emission rate of chemicals of potential concern
(COPC) due to fugitive emissions needs to be estimated in order to complete the
risk assessment. Fugitive emissions should be minimized or eliminated by sealing
or tightly connecting the combustion chamber openings to the roll-off or other
containers used in collecting ash. In addition, the seals or connections should be
inspected regularly to identify leaking seals for potential fugitive emissions.
The TBP reviewer should check for the following information:
Q Description of ash handling system
Q Specific design details or precautions taken to control fugitive emissions
during ash discharge
Q Procedures for replacing roll-off containers
Q Whether the rotary kiln can be operated without interruption during
replacement of roll-off containers
Q Roll-off container capacity
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q Anticipated rate of ash generation based on total feed rate of ash in total
feed streams
Q Ash disposal as hazardous or nonhazardous waste
Q Estimated fugitive emission rate
Q Methods and frequency of monitoring fugitive emissions
Q Maximum ash feed rate
Example Situation: Lois and Clark read the Ash Handling System section of the TBP as follows:
"The solids furnace is a refractory-lined rotary kiln that operates at a typical
speed of 0.5 to 0.25 unit(s). It is normally maintained above a -0.2-inch water
column draft and has a minimum exit temperature of about 1,500°F. The actual
operating temperature will be determined during the trial burn. Solids contained
in 30-gallon fiber drums are loaded onto a conveyor that empties into the charge
end of the kiln by a chute equipped with a guillotine door. Ash is collected in bulk
bins in a concrete pit below the kiln and transferred for cooling before being
tested and approved for landfilling on site."
Example Action:
This section indicates that ash is collected in bulk bins in a concrete pit below the
kiln, but does not provide adequate information on operations and management of
the ash handling system. It does not indicate (1) bin size, (2) how fugitive
emissions are controlled during ash discharge from the kiln, (3) whether bins are
closed, (4) how often bins are replaced, (5) whether the kiln stops rotating during
bin replacement, and (6) ash generation rate (for example, in pounds per hour).
Lois and Clark ask that the facility to revise this section to include information
pertaining to operation and management of the ash handling system.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.8 Reviewing Section D-5b(l)(a)(8)—Automatic Waste Feed Cut Off Description
Regulations:
Guidance:
Explanation:
40 CFR Part 266.102(e)(2)(ii)(A,B,C)
40 CFR Part 270.62(b)(2)(ii)(F)
40 CFR Part 270.66(c)(3)(vi)
U.S. EPA. 1989. "Handbook—Guidance on Setting Permit Conditions and
Reporting Trial Burn Results." EPA/530/R-89/019. January. Table 2-1,
Page 11.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Sciences
and Engineering. Pages D-5.1 through D-5.24.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." Center for Combustion Sciences and
Engineering. EPA-R6-098-002. Section 2.2.3.
To ensure that out-of-compliance operations are kept to a minimum, combustion
units are required to have automatic waste feet cutoff (AWFCO) systems that
engage immediately when operating conditions deviate from those established
during the trial burn test. AWFCO systems should be in place during the startup-
shakedown phase, and trial burn. The facility should specify limits for various
parameters that would affect combustion operations during excursions, including
the following:
Q The purpose of the trial burn is to set and adjust operating limits.
The TBP requirements must include procedures for rapidly
stopping the feed of waste to the combustion unit so that the trial
burn will not present a hazard to human health or the
environment. AWFCO's are not specifically required to be
activated during a trial burn, but are an integral part of the
operating permit, and therefore need to be considered. AWFCO
limits in place during the trial burn may not be the same as those
used prior to or following testing.
Q Although AWFCO limits are necessary to minimize out-of-
compliance operations, its occurrence is undesirable, because it
may contribute to PIC emissions, safety problems, and increases
in fossil fuel use. Therefore, AWFCOs are minimized by using
prealarms on specified parameters followed by corrective actions
taken by operating personnel.
AWFCOs are typically established for a number of general and site-specific
parameters determined during the trial burn test; however, some regulatory
agencies may also establish AWFCOs based on monitoring and reporting
requirements. The facility may also propose additional AWFCO limits based on
equipment manufacturer specifications and recommendations.
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Check For:
The TBP reviewer should check for the following information:
Q Minimum and maximum temperature measured at each combustion
chamber exit
Q Maximum carbon monoxide (CO) emissions measured at the stack or
other appropriate location
Q Maximum flue gas flow rate or velocity measured at the stack or other
appropriate location
Q Maximum pressure in PCC and SCC
Q Maximum feed rate of each waste type to each combustion chamber
All facilities should establish limits for, and continuously monitor, the following:
Q Maximum production rate for BIFs
Q Maximum total hydrocarbon (THC) concentrations, if THC emissions are
monitored
Q Minimum differential pressure across particulate venturi scrubber
Q Minimum liquid-to-gas ratio and pH to wet scrubber
Q Minimum caustic feed to dry scrubber
Q Minimum kilovolt Amperes (kVA) settings for electrostatic precipitators
(wet/dry) and kVA settings for IWS
Q Maximum pressure differential across baghouse
Q Minimum flow rate of liquid to IWS
Facilities should establish limits for the following as they apply to the facility:
Q AWFCO testing frequency
Q How each parameter is monitored and how the AWFCO system is
triggered during an excursion
Q O2 levels for correcting CO measurements
Q Prealarm system operation and its relation to the AWFCO system
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(for example, parameters monitored, monitoring frequency, and
conditions under which prealarm system readings trigger the AWFCO
system [two or three consecutive, 15-second parameter readings that
exceed an established or permitted limit])
Q CO levels
a THC levels
Q O2 levels
Q Production capacity
Q Combustion chamber temperature
Q Hazardous waste feed flow rate
Q Flue gas flow rate
Q PM control device inlet temperature
Q Other APCS parameters
(these parameters are generally used as pre-alarm indicators)
Q Recognition of monitoring parameters and various groups recommended
by U.S. EPA for interlock with AWFCO and with records of operation
Q Process Upset Information
Q Historical operating data demonstrating the frequency and
duration of process upsets and the associated combustion unit
conditions or operating parameters at the time of the upset
Q Cause of each process upset
Q Estimates of process upset emission rates and background
information on each upset
Q Description of a reasonable process upset or failure (including
primary or secondary process and APCS controls and interlocks
to substantiate this scenario)
Q Description of typical operating procedures for the combustion
unit
Example Situation: In reviewing The Automatic Waste Feed Cutoff Description section of the TBP
for a preheater calciner cement plant, Clark reads as follows:
"To start and maintain hazardous waste feed flow to a kiln, the following
conditions must be met. The interlocks must remain satisfied, or shutdown of
hazardous waste fuel (HWF) flow to the kiln will occur.
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
• Kiln induced draft fan must be operating
• Kiln drive must be operating
Kiln feed V-ball must be open to "A" or "B"
• Total kiln feed rate must be less than 256 tons per hour
• Supplemental fuels flow rate must be less than 43 gpm
• Raw mill baghouse inlet temperature must be less than 366°F
• Alkali bypass baghouse inlet temperature must be less than 436°F
• Fourth-stage gas inlet temperature must be less than 1,691 °F
• Raw mill baghouse differential pressure must be greater than 6 inches of
water column
• Alkali bypass baghouse differential pressure must be greater than 2.95
inches of water column
• Stack exhaust gas opacity must be less than 20 percent
• Corrected CO must be less than 1,169 ppm by volume (ppmv)
• Corrected THC must be less than 20 ppmv
• Either the primary or backup continuous emissions monitoring system
(CEMS) must be "on line"
• Either the primary or backup THC monitor ignition must be lit
• Minimum combustion chamber temperature (for containers)
If any of the following conditions approach the present AWFCO limit, an alarm alerts the
control room operator of conditions that may lead to an AWFCO if left unattended.
These include the following:
• Total kiln feed rate
• Supplemental fuels flow rate
• Raw mill baghouse inlet temperature
• Alkali bypass baghouse inlet temperature
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Example Action:
• Fourth-stage gas inlet temperature
• Raw mill baghouse differential pressure
• Alkali bypass baghouse differential pressure
• Stack exhaust gas opacity
Corrected CO
Corrected THC"
Clark notes that this section, in large part, is incomplete; the following information
should be added:
• The total, maximum HWF rate should be specified. The TBP currently
specifies only the pumpable HWF rate. The total feed rate must include
the rate at which canisters will be injected into the kiln. Though the text
states elsewhere that the canisters represent less than 1 percent of the
total HWF rate, the maximum feed rate for these canisters should still be
specified.
• CO and THC concentration limits should be described as being on a dry
basis and corrected to 7 percent O2.
• A number of AWFCO parameters need to be specified, including:
The upper limit on combustion gas flow rate; direct measurement
of the gas flow should be provided, if possible,
The minimum combustion temperature,
The maximum combustion temperature, and
The maximum combustion chamber pressure.
• The preset points for the alarm system should be specified. Additionally,
specific corrective measures to be taken when the prealarm system is
triggered should be identified.
• An explanation of test procedures that will be implemented should an
AWFCO occur during the trial burn. This explanation should include, at
a minimum, the following:
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A statement that the minimum combustion chamber temperature
will be maintained during the AWFCO for as long as waste
remains in the kiln and information on how this will be achieved.
The logic that will be used to determine when a restart of waste
feed is appropriate after an AWFCO is caused by an
instantaneous parameter reading.
How the waste feed will be restarted. If the process is manual,
the text should state this and provide the step-by-step process for
restart. If the process is automated, the computer logic should
be outlined.
• A description of the relationship between the trial burn operating
conditions and the AWFCO settings during the trial burn. The
description should demonstrate that AWFCO settings are sufficiently
close to the operating envelope to prevent undue hazards to human health
and the environment, but far enough from the envelope not to produce
excessive AWFCOs during the trial burn.
• An explanation of how trial burn results will be used to establish
AWFCO set points following the trial burn.
• A description of AWFCO system preventative maintenance and testing
procedures.
Clark asks that the facility revise this section to include the requested parameters,
descriptions, procedures, and rationale.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.9 Reviewing Section D-5b(l)(a)(9)—Stack and Continuous Emission Monitoring Systems
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 60, Appendix A
40 CFR Part 266, Subpart H and Appendix IX
40 CFR Part 270.62(b)(2)(ii)(G)
40 CFR Part 270.66(c)(3)(viii)
U.S. EPA. 1992. "Technical Implementation Document for EP A' s BIF
Regulations." OSWER Washington, D.C. EPA-530-R-92-011. March.
Pages 4-1, 6-1, and 6- 2.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.1 through D-5.24.
CO and O2 (and, if applicable, THC) should be continuously measured during the
startup and shakedown phases and trial burn, as well as continuously thereafter.
Continuous emissions monitoring of CO and O2 must comply with performance
specifications in Section 2. 1 of Appendix IX to the BIF Rule. Performance
specifications provide criteria that the monitoring system must meet.
Requirements for daily calibrations are also addressed in performance
specifications.
The TBP reviewer should check for the following information:
Q Parameters continuously monitored (CO, O2, and sometimes THC)
Q CEM equipment or analyzer manufacturer name and model number
Q CO, O2, and THC monitoring method
Q Whether CEMS equipment will meet performance specifications
Q Most recent CEMS certification results
Q
CEMS functions
Q Continuous measurement
Q AWFCO system activation
Q Remote display of stack gas composition and CEMS operational
status
Q Automatic and manual calibration of sampling and analysis trains
Q Automatic recording and printing of stack gas composition
Q Alarm activation when there is a CEMS malfunction
Q Location of CEMS analyzers and system instrumentation
Q Description of degree of equipment redundancy, if applicable
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q Brief description of CEMS operations
Q Calibration procedures
Q Calibration frequency (daily, weekly)
Q Data corrections and reporting (concentrations of CO and THC in stack
gas must be continuously corrected to a dry gas basis and to 7 percent
02)
Q Monitoring of CO and O2 in the bypass duct (for process cement kilns
with preheaters or precalciners)
Example Situation: Lois and Clark read the Stack and Continuous Emission Monitoring Systems
section of the TBP as follows:
"CEMS probes are located in the duct between the bypass-induced draft fan
exhaust and the stack. CEMS equipment consists of several gas analyzers, a
supporting sample acquisition system, and a computer data display and reporting
system. This CEMS is supplied by AB Company and consists of:
• A probe with a heated external ceramic filter
• A temperature-controlled sample transport line
• A constant-volume gas sample pump
• A THC analyzer: there are two analyzers, one is always on line while
the other is in standby mode
• A gas conditioning system with condensate pumps
• A gas analyzer, infrared CO analyzer: there are two analyzers, one is
always on line while the other is in standby mode
• Data storage modules, Model DSM-3260
• A personal computer with 8 megabytes (MB) of random access memory
and a 500-MB hard drive
• An environmental data acquisition and reporting software
"CEMS - Process Description
"The sample probe extracts a gas sample from the bypass fan exhaust duct. This
probe is temperature-controlled to 325 °F. Gas is drawn down an electrically
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
heated sample transport line. A portion of the gas enters the THC analyzer. The
remainder of the gas is conditioned and any condensate removed. The resulting
dry gas flows into the CO and O2 gas analyzers. Raw data from each analyzer is
sent to the data storage module, and any required calculations are completed.
The resultant output goes to the display and data reporting computer, where it is
compared to appropriate present limits resulting in 'No action,' 'Alarm,' or
'shutdown of hazardous waste feed to kiln,' in accordance with applicable
restrictions."
Example Action:
The description of the CEMS equipment should
include the location and configuration of the
sampling probe located at the stack.
Lois and Clark realize that the CEMS equipment description is incomplete and
they note that the following should be included:
• Specific U.S. EPA method procedures associated with the operation of
each CEMS.
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
• For the parameters to be monitored, the following information, for each
instrument should be provided in a table: instrument type, manufacturer,
model number, range, accuracy, drift, reproducibility, response time, and
calibration frequency both prior to and during the trial burn.
• Specific reference to appropriate TBP sections that contain more details,
such as the equipment manual and drawings, on the CEMS equipment
and locations. This information should clarify whether the CEMS is
monitoring downstream of the points where the bypass duct rejoins the
main gas flow. If the CEMS is not located downstream of this point,
additional monitoring equipment will be required.
• Information on certification of analyzers and performance specification
tests required under 40 CFR Part 266, Appendix IX and 40 CFR Part 60,
Appendix B.
Lois also notes that the CEMS process description is both incomplete, unclear,
and that it should include the following:
• The frequency of parameter sampling and monitoring.
• A clearer description of the flow stream to the analyzers. A figure
supporting this description should be included.
• Specific references to the appropriate sections of the TBP that contain
more details on monitoring methods and control configuration.
Based on their review comments, Lois and Clark request that the facility revise
the CEMS equipment and process descriptions.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.10 Reviewing Section D-5b(l)(a)(10)—Air Pollution Control Systems
Regulations: 40 CFR Parts 266.102(e)(2), (3), (4), and (5)
40 CFR Part 270.62(b)(2)(ii)(G)
40 CFR Part 270.66(c)(3)(vii)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.1 through D-5.24.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." EPA-R6-098-002. Section 2.2.4.
Explanation: The APCS on a combustion unit removes acid gases (commonly HC1) and PM.
Because industrial waste streams vary, so do APCSs. APCSs are used either
independently or in combination, depending on whether it is necessary to control
PM, acid gas, or both. RCRA regulations require that any hazardous waste
combustion unit that emits HC1 at a rate greater than 1.8 kilograms per hour and
PM at a rate of 0.08 grains per dry square cubic foot be corrected to 7 percent
O2.
There are critical operating parameters that effect the efficiency of the device
for each of the devices listed below. These critical operating parameters are
aspects of the APCS that (1) can be continuously monitored and (2) are
indicators of pollutant removal efficiency. Some examples follow:
• Cyclones - pressure drop and gas velocity effect the collection and
removal efficiency of the device.
• Fabric filters - gas-to-cloth ratio affects the particulate removal
efficiency as does the differential pressure across the bags.
• Quench system - gas velocity effects quenching and large particle
removal, quench water temperature, and flow effects system efficiency.
• Gas conditioner - poor gas conditioning adversely effects the removal of
particulates and can cause emission violations.
• Venturi scrubbers - the differential pressure across the venturi
determines particle size removal efficiencies.
• Wet scrubbers - scrubber water pH determines acid gas neutralization
capability. Pressure drop across the scrubber determines contrast
potential of pollutants with scrubber media.
• Electrostatic precipitator (ESP) - gas flow rate and applied voltage are
critical to efficient operation and solids removal, as is the particle loading
rate.
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
• Induced-or forced-draft fan - the fan must be capable of inducing a draft
throughout the unit or of supplying sufficient combustion air for complete
oxidation of organic compounds.
A limit on maximum temperatures at the inlet to the APCS must be established
based upon operating conditions during both the dioxin and furan and metals
emissions testing. This maximum inlet temperature should be reproduced as
closely as possible during the PIC emissions testing.
Maximum inlet temperature to dry APCS is important for both metals and dioxin
and furan emissions. For metals, high inlet temperatures can cause poor
collection efficiency because a larger portion of the metals may be in the vapor
phase. For dioxins, high inlet temperature can cause an increase in surface
catalyzed dioxin and furan formation. At inlet temperatures between 450°F and
750°F, dioxin and furan emissions can increase by a factor of 10 for every 125°F
increase in temperature.
Check For: The TBP reviewer should check for the following information:
Q APCS type and components
Q Cyclones (used mainly as a prefiltering process for removing larger
particles)
Q Manufacturer name and model number
Q Cyclone device location in the APCS
Q Cyclone chamber shape (conical or cylindrical)
Q Construction material
Q Gas entry (tangential or axial)
Q Gas velocity
Q Pressure drop
Q Inlet gas temperature
Q Removal efficiency
Q Brief description of cyclone design and operation
Q Smallest particle that could be removed effectively
Q Inspection and maintenance procedures
(for wall corrosion, leakage, particle deposits, and plugging)
Q Fabric filters or baghouses
Q Manufacturer name and model number
Q Brief description of fabric filter design and operation
Q Housing dimensions and construction materials
Q Fabric specification (fabric type and weave)
Q Inlet gas temperature
Q Filter type and size
Q Gas velocity or flow rate
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Differential pressure
Gas-to-cloth ratio
Smallest particle that could be removed effectively
Filter cleaning procedure (pulse jet, shaker, sonic, or reverse air
systems)
Cleaning frequency
Inspection and maintenance
(for correct tensioning and conditions, such as tears, holes
resulting from abrasion, and dust accumulation on the surface)
A typical baghouse
Quench system
Q Manufacturer and model number
Q Purpose of quench system
Q Quench method
Q Removal efficiency (Latent heat)
Q Combustion gas velocity
Q Combustion gas inlet and outlet temperature
Q Quench water supply capacity
Q Quench water temperature
Q Water feed rate
Q Total recycle flow rate, if applicable
Q Management of condensate and excess water
Q Description (shape, dimensions, CSA, and volume) of quench
liquid collection system, if applicable
Q Quench liquid recycling procedures, if fluid is being recycled
Q Management of quench liquid recycling residues
Q Ultimate treatment and disposal of quench liquid
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Gas conditioner
Flue gas conditioning (cooling, humidification, and reagent injection) is
required before particle removal in low-temperature devices, such as
baghouses, cold ESP, and wet scrubbers.
Q Manufacturer name and model number
Q Conditioner purpose
Q Dimensions and CSA
Q Construction material
Q Gas conditioning technique (air dilution, heat exchanger, water
quench, and radiation and convection duct cooling)
Q Inlet and outlet gas temperature
Q Volumetric flow rate of flue gas
Q Air dilution technique
Dilution air volumetric flow rate
Dilution air blower capacity
Q Heat exchanger technique
Heat exchanger type (gas-to-gas or gas-to-liquid)
Cooling fluid (air or liquid)
Venturi scrubbers
Q Manufacturer name and model number
Q Scrubber purpose
Q Removal efficiency
Q Construction material
Q Gas inlet temperature
Q Scrubber water flow rate
Q Spent scrubber water management
Q Differential pressure across scrubber
Q Gas flow rate
Q Influent and effluent pH for scrubber solution
Q Liquid-to-gas ratio
Q Inspection and maintenance (for prevention of corrosion and
scaling on all scrubber internal surfaces, excessive dust buildup,
nozzle damage, plugging, and fluid leakage)
Q Scrubber blowdown frequency
Wet scrubbers
Q Manufacturer name and model number
Q Wet scrubber purpose
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Wet scrubber type (tray tower, packed tower, free jet, or
ionized)
Brief description of scrubber
Pressure drop across scrubber
Concentration and pH of scrubbing slurry
Liquid-to-gas ratio using gas and slurry flow rate
Solids accumulation within the scrubber
Induced-draft fan power
Reagent preparation system (slurry solution) operation
Inlet and outlet gas temperatures
Dewatering process
Spent scrubber solution management and disposal
Inspection and maintenance (for leaks, scaling, corrosion, and
erosion problems)
a ESP
Q Manufacturer name and model number
Q Brief description of ESP design and operation
Q ESP general configuration (wire or rod discharge electrode)
Q ESP type (tubular, wire-to-plate, or flat plate)
Q Gas volume flow rate
Q Particle loading
Q Gas temperature
Q Removal efficiency
Q Dimensions
Q Construction materials
Q Specific collection area
Q Aspect ratio (length-to-height)
Q Wire-to-plate spacing
Q Wire (or rod) diameter
Q Operating voltage
Q Current
Q Sparking rate
Q Particle dislodging procedure (mechanical rapping devices or
water)
Q Wet electrostatic preciptator (WESP) water flow rate
Q WESP volumetric flow rate of intermittent wash down sprays
used to remove material that adheres to collector surfaces
Q Performance monitoring (opacity meter)
Q Inspection and maintenance procedures (for cleaning carbon
deposits on plates, power supplies, monitors, electrode conditions,
and electrical connections)
Q Information required for the control of cement kiln dust (CKD)
Q CKD physical data, including PSD and density
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q CKD chemical data, including organic and inorganic analytical
tests similar to those used for sampling combustion gases
Q CKD recycling rate (to the process)
Q Ambient air monitoring data
Q CKD management, transportation, storage, and disposal methods
Q Contaminant procedures, including fugitive dust prevention
measures and the area of exposed CKD
Q Meteorological data, including wind speed, and precipitation
Induced- or forced-draft fan
a
a
a
a
a
a
Manufacturer name and model number
Fan purpose
Fan type
Construction materials
Dimensions
Design specifications
Volumetric flow rate
Temperature
Pressure
Horsepower
Stack
Q Stack dimensions and CSA
Q Construction materials
Q Description of stack gas recycling system, if applicable
Q Description of scrubber liquid recycling system
Example Situation: Lois reads the Air Pollution Control Devices section of the TBP as follows:
"The clinker exiting the kiln is about 2,300°F and falls into a grate-type cooler to
reduce its temperature. The temperature is reduced by blowing air through the
hot clinker. In turn, some of the hot air generated in this process is drawn
through the kiln to be used as combustion air. Gases produced during the
combustion process are drawn through the kiln and preheated by an induced draft
fan. As these gases leave the preheater, they are drawn by another fan through
the raw mill to heat and dry the raw feed of the mill. However, before they exit
the perimeter, hot gases pass through a spray tower, where the temperature is
regulated before it enters the raw mill (or main baghouse if the mill is bypassed).
After gases exit the raw mill, the dust-laden gas stream is cleaned by a Buell
baghouse, Model 56-RM-12, and contains a total cloth area of 173,000 square
feet. Collected dust is recycled back to the raw feed storage silos, and the
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
cleaned gas stream is exhausted first through the induced draft fan and then
through the main stack."
Example Action: Lois finds this discussion to be confusing and inadequate and believes that the
following items should be addressed:
• A more detailed description of flow streams and relationships between
the raw mill baghouse, the main baghouse, the spray tower, the main
stack, and any bypass stack. The purpose of the spray tower should be
defined. A PFD and P&ID should be included in the TBP to support
each of the items.
• A discussion of the effects of bypassing the raw mill on the overall
performance of the APCS. The flow configuration that will be used
during the trail burn also should be identified.
• Identification of operating parameters for the APCS, including gas flow
rates, gas inlet temperature, bag cleaning cycles (frequency and
duration), and pressure drop.
• A discussion of how test conditions represent worst-case conditions.
Additional information on the baghouse should be provided. This information
should include (1) air-to-cloth ratios; (2) bag-to-bag spacing; (3) bag length;
(4) number of separate compartments within the baghouse; (5) method of
compartment isolation; (6) method of cleaning and frequency; (7) source of any
compressed air used to clean the bags; and (8) bag fabric. To clarify and
complete the APCS discussion, Lois asks that the facility revise this section
based on her comments.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.11 Reviewing Section D-5b(l)(a)(ll)—Construction Materials
Regulations: 40 CFR Part 270.62(b)(2)(ii)(I)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science and
Engineering. Pages D-5.1 through D-5.24.
Explanation: To ensure thorough evaluation of the proposed combustion unit, this section
should provide a complete list of combustion unit components along with design
specifications and parameters for each component. Specifically, this section
should describe construction materials, thickness, and temperature ratings of shell
and internals for the following:
PCCs
SCCs
• Tertiary combustion chambers
• High-temperature ducting between PCCs and SCCs
• Quench tank
• Induced draft fan housing
APCS
Stack
• Induced draft fan wheel
• Other equipment associated with the combustion unit
Check For: The TBP reviewer should check for the following information:
Q Construction materials
Q Outer shell (ordinary steel or alloys)
Q Inner shell (refractory materials, such as fireclay, alumina, silica,
chromium, magnesite, and other oxides)
Q Thickness of outer shell and refractory
Q Refractory conductivity
Q Temperature ratings of shell and internals
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Example Situation: Clark reads the Construction Materials section of the TBP, as follows:
"Following is a list of major process equipment for the hazardous waste
incinerator and scrubber system, including:
Rotary Kiln
Manufacturer
Size
Heat Duty
Volume
Material
Bartlett-Snow
External: 12 feet diameter x 17 feet long
Internal: 10.5 feet diameter x 16.5 feet long
35 million BTU/hr
1,429 cubic feet (ft3)
Refractory-lined steel
Example Action:
Afterburner
Manufacturer
Size
Volume
Unit Capacity
Absorber/Cooler
Manufacturer
Height
Diameter
Material
Stack
Height
Lining
Diameter
Combustion Engineering, Inc.
13 feet wide x 14 feet high x 28.6 feet long
7,422.25 cubic feet (ft3)
131,000 ft3/min at 2,300°F
Ceilcote Co.
26 feet 4 inches
11 feet
Fiber-reinforced plastic
100 feet
Fiber-reinforced plastic
7 feet ID at base and 5 feet ID at discharge"
While this section provides a list of major process equipment and some
specification/parameter information, it does not provide the conductivity of the
refractory used in the PCC and SCC and temperature ratings of the outer and
inner shells. Clark asks that the facility revise this section to include this
information.
Notes:
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3.1.1.12 Reviewing Section D-5b(l)(a)(12)—Location and Description of Temperature,
Pressure, and Flow Indicators and Control Devices
Regulations: 40 CFR Parts 264.345(a) and (b)
40 CFR Part 270.62(b)(2)(ii)(J)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.1 through D-5.24.
Explanation: Combustion unit regulations require continuous monitoring of combustion
temperature, waste feed rate, combustion gas flow rate, and CO concentrations
in the stack gas. Monitoring of key process parameters should be continuous.
Temperature is usually monitored by using thermocouples protected in a
thermowell.
Thermocouple location in the combustion chamber significantly affects the
accuracy of temperature readings. Typically, thermocouples are located at the
gas exit in the chamber.
Combustion chamber pressure is monitored to ensure correct operation of the
combustion unit and to prevent fugitive emissions. Many combustion units are
operated under draft conditions (less than atmospheric pressure). This ensures
that combustion gases do not exit the chamber before passing through the APCS.
Instruments used to monitor pressure are known as differential pressure gauges,
differential pressure transducers, or draft gauges. Pressure gauges are usually
located across the hood of a rotary kiln. However, they can be located across
the entire combustion chamber or kiln. The gauges are accurate, and maintaining
draft conditions is normally not an operating problem.
Waste flow rate is monitored by using devices appropriate for the physical and
chemical nature of the waste. A mass flow meter is generally used for liquid;
these devices are typically very accurate, and require minimum maintenance.
Flow meters may be located anywhere between the waste feed tank and the
combustion unit; however, it is desirable to measure the flow rate in the feed line
as near as possible to the combustion unit and after any T's in the piping.
Positive displacement pumps are used when viscous wastes, such as sludges, are
pumped into the combustion chamber. Accuracy is affected by waste
characteristics and maintenance. Solids can be monitored as the weight of
discrete units pushed into the kiln or as solids fed by using a weigh-belt conveyor.
Weigh-belt conveyor accuracy is acceptable for most applications.
Combustion gas velocity is monitored after the scrubber. The device most often
used is an annubar, which must be calibrated frequently and is susceptible to
corrosion and plugging. Combustion gas flow rate, which is usually a permit
condition, is calculated using the gas velocity.
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Check For:
Example Situation:
Control devices could include items such as (1) valves in the feed line, (2) burner
blowers controlling combustion air, (3) steam valves used for steam atomization
of specific wastes, and (4) other devices used to control feed rates and ensure
safe operation.
The TBP reviewer should check for the following information:
Q Equipment description
Q Device locations
Q Equipment accuracy
Q Equipment maintenance
Q Equipment compatibility with use
Lois and Clark read the Location and Description of Temperature, Pressure,
Flow Indication, and Control Device section of the TBP as follows:
"Critical Process Measurements—The measurement and control of waste flows,
kiln and SCC outlet temperatures, combustion gas analysis, and velocity are the
parameters that are most critical to efficient, in-specification performance of the
incinerator train. Consequently, 'state-of-the-art,' yet field-proven instruments
are used to measure these process variables.
"Liquid waste flows are measured by using Coriolis mass flow transmitters.
These devices are relatively immune to variations in density, viscosity, and solids
content; therefore, they lend themselves well to this type of application.
"Kiln outlet temperatures are measured by using dual redundant narrow-band
infrared pyrometers, which send independent analog signals to the control
console. SCC outlet temperatures are measured by using dual redundant
thermocouples. The area supervisor uses a selector switch to select one of the
two signals to be used in the monitoring and control loop. Output signals from
both pyrometers are continuously monitored and compared. If there is a
sustained, significant difference between the two signals, an alarm will alert the
operator of potential failure of one of the pyrometers.
"Combustion gas is analyzed by using in-situ and extractive-type sensors. Optical
analyzers are used to monitor the opacity, and nondispersible infrared units are
used to analyze CO and HC1. A flame ionization detector (FID) is used to
monitor THC. A zirconium oxide cell is used to measure O2.
"Stack gas velocity is an indication of the gas residence time in the SCC, which is
critical to the complete thermal destruction of waste materials. Therefore, stack
gas velocity is measured by using dual redundant thermal dispersion flow
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transmitters. One signal is selected to be displayed and interlocked, but both
signals are continuously monitored and compared. A sustained, significant
deviation will cause an alarm to alert the operator of the possible malfunction of
one of the transmitters."
Example Action:
This section should present the optimum range of the liquid waste flow meter, in
addition to calibration data displaying error on both sides of optimum. It should
also present the type of thermocouples used and the temperature range in which
they are used. Lois finds the comment about a "sustained, significant difference"
to be unacceptable. If a difference exists of more than 2 to 3 percent in dual
redundant readings, something is wrong and it must be corrected immediately.
Clark makes a similar notation regarding "sustained, significant deviation" in the
stack gas velocity monitor. This is a permit condition that cannot be allowed to
exceed certain limits. Lois and Clark request that the facility revise this section
and specify a value for the difference between the two readings that will be
considered unacceptable.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.1.13 Reviewing Section D-5b(l)(a)(13)—Combustion Unit Start-Up Procedures
Regulations: 40 CFRPart 264.345(c)
40 CFR Part 270.62(b)(2)(viii)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.1 through D-5.24 and D-5.44.
Explanation: During startup and shutdown of a combustion unit, hazardous waste must not be
fed into the combustion unit unless it is within operating conditions (such as
temperature and air feed rate) specified in the permit.
Check For: The TBP reviewer should check for the following information:
Q Technique for bringing the combustion unit to full operating conditions
(firing fossil fuel, such as natural gas or pulverized coal)
Q Whether the hazardous wastes are being fed to the combustion unit
before it is brought to full operating conditions
Q Facility's definition of full operating conditions
Q Whether the unit is in compliance with all regulatory limits before it burns
hazardous wastes
Q Time required for startup
Q Startup sequence (the APCS should be started first, and the waste
system should be started last)
Q Specific procedures for startup of utilities, APCS, boiler system, SCC
train, and the rotary kiln
Q Discussion of how the combustion unit is brought up to permitted
operating conditions
Q Fuel source used for startup
Q Documented start-up procedures for ancillary equipment
Q Estimated time required to reach permitted operating conditions for
introduction of hazardous waste
Example Sections: See Section 3.2.1 of this component for specific example sections.
Example Comments: See Section 3.2.1 of this component for specific example comments.
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Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.2 Reviewing Section D-5b(l)(b)—Sampling, Analysis, and Monitoring Procedures
Regulations:
Guidance:
Explanation:
40 CFR Part 266.62 (b)(2)(I)(A-D)
40 CFR Part 270.62 (b)(2)(iii)
40CFRPart270.66(c)(4)
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.24 through D-5.34.
To assist the reviewer to better evaluate the feasibility of sampling, analysis, and
monitoring procedures, this section should state the objectives of the proposed
sampling program. Generally, objectives of a trial burn sampling programs are to
collect analytical data that will allow the calculation of constituent feed rates;
estimate APCS removal efficiencies; document CO, O2, and other constituent
emission rates; and determine the fate of principal organic hazardous constituents
(POHC) fed to the system.
This section should also discuss whether the facility intends to spike wastes fed
into the combustion unit. Organic chlorine is spiked into waste feeds either to
maximize the volatility of metals or to demonstrate compliance with RCRA
emissions and removal efficiency requirements for HC1 and C12. Also,
compounds such as naphthalene and chlorobenzene may be spiked as POHC.
The concentration of the spiking compound in waste feed should be presented in
the TBP.
The TBP reviewer should check for the following information:
Q Sampling program objectives
Q Spiking compounds used, if any
Q Spiking purpose
Q Concentration of spiking compounds in waste feed
During the review of a TBP, Lois notes that the facility proposes to measure
POHC (carbon tetrachloride) DRE by (1) sampling the waste feed for total HC1
and C12, elemental analysis, density, heating value, and ash content; and
(2) collecting stack gas samples using U.S. EPA Methods 0050 for HC1 and C12
and U.S. EPA Method 0031 for volatile organic compounds (VOC).
Example Comments: This is not adequate. To measure DRE, the facility must propose waste feed
analysis that can quantitatively measure the concentration of each POHC in the
waste feed. The proposed sampling program will only qualitatively measure the
carbon tetrachloride in the waste feed by measuring total HC1 and C12. Lois
Check For:
Example Sections:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
requests that the facility include VOC analysis of the waste feed samples using
U.S. EPA Method 8260.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.2.1 Reviewing Section D-5b(l)(b)(l)—Sampling Locations and Procedures
Regulations: 40 CFR Part 270.62(b)(2)(iii)
40CFRPart270.66(c)(4)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.24 through D-5.34.
Explanation: This section should discuss sampling locations and procedures during the trial
burn test and normal operations. It should include sample types to be collected
(waste feed, scrubber blow down, combustion residues, and flue gas emissions),
frequency at which they are collected, sampling locations, and sampling
procedures. Sampling locations should be presented in a process flow diagram.
The location of temporary CEMS can be shown separately or as part of the
stack gas sampling for each auxiliary fuel source, a sampling location should be
identified. In lieu of sampling auxiliary fuels, a facility may rely on certified
analyses for these feed streams, if applicable, and if appropriate data is available
from the supplier.
Procedures for collecting samples at each location are usually summarized in a
table that also includes sampling frequency and reference methods. Process
grab samples for volatile organic analysis are collected and packaged separately
in the field. Samples for other analysis are composited in the field and shipped to
the laboratory. Waste feed samples should be collected at 15-minute intervals.
Reference should also be made in this section to the trial burn quality assurance
project plan (QAPP). Additional sampling procedure information is discussed in
Component 2 of this manual.
Check For: The TBP reviewer should check for the following information:
Q Sample types
Q Auxiliary fuels (for example, fuel oil or natural gas)
Q Raw materials (for example, slurries, raw mixes, or shale)
Q Waste feed
Q Scrubber blow down
Q Combustion residues
Q Flue gas emissions
Q Grab samples
Q Composite samples
Q Sampling locations
Q Sampling procedures and reference methods
Q Sampling frequency
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Q Sample storage conditions
Q Sample packaging and shipment
Example Situation: In reviewing the Sampling Locations and Procedures section of the TBP, Lois
and Clark read as follows:
"Five locations have been identified for the collection of process and fuel
samples. These locations include the slurry feed, HWDF, tire-derived fuels, coal
and coke, and CKD. These samples will be collected to (1) demonstrate
compliance with required performance standards, (2) prepare mass balance
incorporating stack gas emission data, and (3) calculate DRE and metals and
chlorine system removal efficiencies. Sampling points are described below:
"Slurry Feed: The sampling point is located at the 'test tank' at the feed point to
the kiln. The samples will be analyzed for metals, VOCs, and ash content.
"Coal and Coke: The sampling point is located at the feed belt to the coal/coke
mill. The samples will be analyzed for metals, VOCs, heating value, and ash
content.
"TDF: The sampling point is the TDF storage pile. The samples will be analyzed
for metals, heating value, and ash content.
"FfWDF-Liquid: The sampling point is located on the feed line to the kiln
downstream of the mass flow meter. The samples will be analyzed for metals,
heating value, and ash content.
"CKD: The sampling point is located in the bottom of the screw conveyor used
to transfer CKD from the bucket elevator to the waste storage bin. The samples
will be analyzed for metals and VOCs.
"All process samples will be collected by personnel trained in proper sampling
techniques and chain-of-custody procedures. Samples will be logged by time and
a unique identifying number. Process and fuel sampling will be overseen by a
process sampling coordinator. This individual will also be responsible for
compositing all process and fuel samples at the end of a given run and splitting
these composites into the proper sampling containers. This individual will also
interface with the stack gas sampling quality assurance and quality control
(QA/QC) coordinator.
"Exhibits 3.1.2.1-1 and 3.1.2.1-2 present process and fuel sampling frequency
and analysis."
Example Action: Lois notes several deficiencies in this section. The facility has proposed sampling
frequencies for kiln slurry, coal and coke, HWDF, CKD, and TDF that appear to
be arbitrary. Also, several of the proposed frequencies differ from the frequency
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recommended in the guidance (for example, every 15 minutes during each run of
the trial burn test). The TBP should discuss the relationship between sample
frequency and representativeness and demonstrate that sampling various feed
streams at proposed frequencies will adequately capture temporal variations in
composition, thereby ensuring representativeness of all samples. Alternatively,
frequencies should be changed to "every 15 minutes during each run of the trial
burn."
The sampling frequency for HWDF, specified as "four per hour," deviates
semantically from U.S. EPA guidance. To avert possible misinterpretations, this
frequency should be "every 15 minutes during each run."
In comparing table data, Clark discovers that the fuel stream sampling program
summarized in Exhibit 3.1.2.1-1, page 1-58, is inconsistent with the fuel stream
analytical program presented in Exhibit 3.1.2.1-2, page 1-59. Specifically, single
composite samples described in Exhibit 3.1.2.1-1 are not appropriate for multiple
analyses described in Exhibit 3.1.2.1-2. It is not standard practice to composite
volatiles samples in the field, as implied by Exhibit 3.1.2.1-1. Exhibit 3.1.2.1-1;
therefore, should be revised to include all of the discrete samples needed for
individual analyses identified in Exhibit 3.1.2.1-2. Clark asks that the facility
revise this table based on his comments.
The heading "Physical/Chemical Characterization" is ambiguous. Clark asks that
the facility revise the table to include the complete list of parameters comprising
the physical and chemical characteristics determinations (such as heating value,
specific gravity, and viscosity) and suggests that adding footnotes could
accomplish this revision.
The heading "Chlorinated Principal Organic Hazardous Constituents" is also
unclear. This does not specify an analytical method, but a type of compound.
Clark requests that the table be revised to specify the U.S. EPA-approved
analytical method that will be used to test each type of sample.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.2.1-1
SUMMARY OF PROCESS AND FUEL STREAM SAMPLING
Sampling
Location
1
2
3
4
5
Description
Kiln Slurry Feed
Coal and Coke
Hazardous Waste
Derived Fuel
Cement Kiln Dust
Tire-Derived Fuel
Sampling
Frequency
Hourly
Hourly
4 per hour
Hourly
Daily
Testing Frequency
Composite per test run
Composite per test run
Composite per test run
Composite per test run
Composite per test day
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EXHIBIT 3.1.2.1-2
SUMMARY OF PROCESS AND FUEL STREAM ANALYSES
Sampling
Location
1
2
3
4
5
Description
Kiln Slurry Feed
Coal and Coke
Hazardous Waste
Derived Fuel
Cement Kiln Dust
Tire-Derived Fuel
Chlorin
e
+
+
+
+
+
Metals
+
+
+
+
+
Physical
Chemical
Characteristic
s
+
+
+
Chlorinated
Principal
Organic
Hazardous
Constituent
+
+
+
+
+
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3.1.2.2 Reviewing Section D-5b(l)(b)(2)—Analytical Procedures
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 270.62(b)(2)(i)
40 CFR Parts 270.66(c)(l) and (2)
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.24 through D-5.34.
This section should present analyses planned for trial burn samples and analytical
methods to be used for laboratory analyses. A table should be included showing
various constituents to be analyzed for each sample matrix and type, analytical
method, and detection or practical quantitation limits. Methods used for analysis
should follow U.S. EPA protocols. This section should also identify laboratories
used for sample analysis.
Trial burn protocols for collection of risk assessment data will need to address
waste analysis and QA/QC procedures for completely characterizing the risk
burn wastes, fuel, raw materials, and spike materials. Data equivalent to, or
superior than, the following should be generated:
• Quantification of total metals feed rates for arsenic, beryllium,
cadmium, chromium, silver, barium, mercury, lead, antimony,
thallium, nickel, selenium, copper, iron, aluminum, and zinc
• Proximate analysis, or a comparable evaluation, to determine
physical properties including moisture, percent solids, as, heating
value, and viscosity or physical form, as well as to determine
approximate chemical properties including total organic carbon
(TOC), total organic halogens (TOX), and elemental composition
• Survey analysis, or a comparable evaluation for: (1) total organic
content; (2) organic compound class types; and (3) major organic
components
• Directed, quantitative analysis for POHC analysis to demonstrate
ORE
The TBP reviewer should check for the following information:
Q Sampling parameters for each sample collected
Q Analytical method for sample analysis (some common methods are
listed)
Q U.S. EPA Methods 6010 or 7000-series for metals (including
mercury)
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a
a
a
a
a U.S. EPA Method 8260 for target VOCs (U.S. EPA Method
5041 for target VOCs from the U.S. EPA Method 0031
emissions sampling train)
Q U.S. EPA Method 8270 for target semivolatile organic
compounds (SVOC) and PCBs
Q U.S. EPA Method 8290 for poly chlorinated dibenzo-p-dioxins
(PCDD) and polychlorinated dibenzofurans (PCDF)
Q U.S. EPA Method 9057 for HC1 and C12
Sample quantitation limit for each analyte
Name and address of laboratory conducting sample analysis
Metals analysis results
Proximate analysis results
Q Survey analysis results
Q Quantitation of POHC in waste streams
Example Situation: Lois reads the Waste Characterization section of the TBP as follows:
"Wastes proposed for the test burn represent the actual wastes that will be
burned. Because the incinerator is operated for commercial purposes, the
physical and chemical properties of wastes received for incineration vary
considerably from day to day.
Exhibit 3.1.2.2-1, see page 1-63, shows waste feed methods and properties of the
wastes to be used in the test burn. These represent the typical chemical and
physical properties of wastes that are incinerated. Essentially, all combustible
hazardous compounds listed in 40 CFR Part 261, Appendix VIII, may be
combusted during normal operations. Furthermore, any Appendix VIII
compound may be present in each type of waste shown in Exhibit 3.1.2.2-1.
Example Action:
Lois recognizes that general characteristics of waste streams presented in
Exhibit 3.1.2.2-1 are representative of waste stream variability anticipated during
normal commercial operations. For general characterization purposes, waste
characteristics identified are sufficient to determine whether the waste feed
stream proposed for the trial burn test are representative of normal waste feed.
Although it is difficult for a commercial facility to inventory enough waste to
conduct the trial burn test, Lois asks that the facility identify the specific waste
feed mixture that will be used during the trial burn test and provide a description
of how this waste stream is representative of worst-case (DRE test) or normal
(risk burn) operations. For testing of a captive combustion unit, waste
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characterization is much less complicated and the facility should provide detailed
analyses of each waste feed stream.
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.2.2-1
PROPOSED WASTES
Feed Method
Feed Rate (Ib/hr)
Type of Waste
Waste Description
Waste Properties
Heating Value
(Btu/lb)
Water (%)
Ash (dry basis) (%)
Chlorine
(wet basis) (%)
Heat Input Rate
(106 Btu/hr)
Cl Input Rate
(Ib/hr)
Ram feeder or
auxiliary
feeder
4,000
Containerized
solids
POHC and
solids
1,000 to 5,000
<20
30-80
3.5
3.0 to 15.0
140
Ram feeder or
drag feeder
9,000
Bulk solids
POHC and
solids
< 1,000
<20
>80
1.5
<12.0
135
High Btu liquid
to kiln
1,500
High Btu liquid
Organic liquid
-7,500
<20
10 to 50
3
11.25
45
High Btu liquid to
Secondary
Combustion
Chamber
2,000
High Btu liquid
POHC and
organic liquid
-9,500
<10
<5
3.5
14.25
52
Aqueous
injection
3,000
Aqueous waste
Contaminated
water
< 1,000
<90
<10
0
0
0
Notes: Btu British thermal unit
Ib/hr Pounds per hour
Btu/lb British thermal units per pound
POHC Principal organic hazardous constituent
< Less than
Approximately
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3.1.3 Reviewing Section D-5b(l)(c)—Trial Burn Schedule
Regulations: 40 CFR Part 270.62(b)(2)(iv)
40CFRPart270.66(c)(5)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.34.
Explanation: The trial burn schedule should project the timeline for activities to be conducted
before, during, and after the trial burn. The duration of trial burn activities is
important when considering oversight activities and personnel moving in and out
of the site. The quantity of waste needed for trial burn testing should be
presented, with an amount of waste specified as a contingency for unplanned
delays.
Check For: The TBP reviewer should check for the following information:
Q Daily activity schedule (see Section 3.1.3.1)
Q Total estimated duration of the trial burn (see Section 3.1.3.2)
Q Quantities of waste and spiking materials planned for testing (see
Section 3.1.3.3)
Example Sections: Sections 3.1.3.1, 3.1.3.2, and 3.1.3.3 reference a section from a RCRA TBP for
schedule, duration, and quantity.
Example Comments: Brief comments regarding this section are presented in Sections 3.1.3.1, 3.1.3.2,
and 3.1.3.3. The reviewer should verify that the schedule is reasonable, the
duration of each test does not exceed safe work conditions, and a sufficient
quantity of wastes is available.
Notes:
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3.1.3.1 Reviewing Section D-5b(l)(c)(l)—Schedule
Regulations:
Guidance:
Explanation:
Check For:
Example Sections:
40 CFR Part 270.62(b)(2)(iv)
40CFRPart270.66(c)(5)
U.S. EPA. 1985. "Practical Guide - Trial Burns for Hazardous Waste
Incinerators." Office of Research and Development. November. Section IV,
Pages 31 through 41.
U.S. EPA. 1987. "Permitting Hazardous Waste Incinerators. Seminar
Publication. " Center for Environmental Research Information. EPA/625/4-
87/017. September. Pages 18 and 19.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science and
Engineering. Page D-5.34.
During preparation of the TBP, it is difficult to firmly identify test dates; the
actual test date will be contingent on several factors, including the length of time
for regulatory agency review and approval of the plan, process and operating
schedules, weather conditions, and test team availability. However, the TBP
should provide a tentative timeframe for testing. To assist the reviewer in
evaluating the feasibility of the proposed trial burn date, the schedule should
contain the approximate time required for initial setup, actual trial burn testing,
and cleanup activities.
The TBP reviewer should check for the following information:
Q Schedule for setup, testing, and cleanup
Q Scheduled start and stop times for each sampling train and sampling run
Q Time required for setup
Q Time required for combustion unit preconditioning
Q Time required for testing or actual trial burn testing
Q Time required for sample cleanup after the trial burn
Q Time required for sample analysis and reporting of analytical data
Q Time required for preparation and submittal of final report
Lois reviews the following statement: "Exhibit 3.1.3.1-1, see page 1-67, presents
the overall schedule for the trial burn. Exhibit 3.1.3.1-2, see page 1-68, shows
daily activities conducted during a test run."
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Example Comments: Overall, Lois decides that the schedule provides a good framework under which
to operate. The overall schedule covers the important elements, including the
date for submittal of the final trial burn test report. However, although the daily
schedule includes time for setup, testing, and, sample cleanup, the information is
too generic. A daily schedule should include detailed start, stop, and duration
information for each sampling train and sampling run. Additionally, Lois notes
that this schedule is based on the assumption that the facility and test equipment
operate without significant difficulty or major equipment malfunction, and
therefore does not provide adequate contingency schedules. Lois notes that a
pretest meeting will have to be conducted daily to discuss important aspects of
the test, including acceptable working hours each day and the latest time during a
test day that a sampling run will be started. Experience has indicated that no
new runs should be started after sundown, unless multiple shifts are planned.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.3.1-1
EXAMPLE OVERALL TRIAL BURN SCHEDULE
Day Activity
+60 ptt Conduct mini-burn at elevated fume flow. Determine participate
emissions and general system performance.
30 ptt Conduct maintenance on entire system. Rebuild necessary components,
and install new refractory as wear requires; install new burner parts as
needed. Clean boiler tubes.
10 ptt Conduct pre-test site review with regulatory officials. Conduct
necessary performance specification tests on CEMs.
1 Test team arrives on site and scaffolding is set up. Sampling ports are
checked, and all sampling equipment is set up. Operations trailer is
established.
2
3
4
5
95
Risk Burn - Test Condition 1 - Runs 1 and 2
Risk Burn - Test Condition 1 - Run 3
DRE Burn - Test Condition 2 - Runs 1 and 2
DRE Burn - Test Condition 2 - Run 3; remove test equipment, prepare all
necessary chain-of-custody forms, and ship samples to analytical
laboratories. Exit site. Trial burn is complete.
Submit Trial Burn Report (TBR) to State Permitting Agency and U.S.
EPA Regional office (90 days after trial burn completion).
Notes:
ptt Pre-trial burn testing
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.3.1-2
EXAMPLE DAILY TRIAL BURN SCHEDULE
0600 - 0800
This is the pre-test equilibrium period. Feed prepared liquid waste with spiked POHC and vapors
at designated trial burn rates. Facility should have enough liquid waste available for at least 24
hours of consecutive operation at the proposed feed rates.
0800 - 1900
Maintain rates of waste feeds and POHC spike and begin test sampling. Conduct three sampling
regimes under each test condition.
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.3.2 Reviewing Section D-5b(l)(c)(2)—Trial Burn Duration
Regulations: 40 CFR Part 270.62(b)(2)(iv)
40CFRPart270.66(c)(5)
Guidance: U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." OSWER EPA-530-R-92-011. March. Page 5-3.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.34.
Explanation: A trial burn typically consists of a series of tests at one or more conditions. The
number of test conditions and number of runs for each test condition affect the
duration of the trial burn test.
A trial burn test (or combination of tests) should be conducted for each set of
operating conditions under which the facility requests to be permitted. Three
runs should be conducted for each test condition. All runs of a test condition
should be conducted under identical, nominal operating conditions. In general,
each run of a test condition should be passed for the test to be considered
successful—and for the facility to be permitted to operate at those conditions.
The duration of the test will be affected by the number of runs a facility proposes
to conduct each day. This may be one run per day for a test condition involving
multiple complicated stack sampling trains, or three runs per day for a test
condition where only an U.S. EPA Method 0050 train measures PM, HC1, and
C12. Other facilities may choose to sample continuously for 24 hours per day.
Facilities will often conduct multiple tests during the trial burn to develop all
applicable permit operating conditions. For example, facilities will usually
perform minimum and maximum temperature tests, because decreasing
temperatures tend to decrease organic chemical destruction, and increasing
temperatures tend to increase metals emissions because of an increase in
volatility. These tests, if successful, will determine temperature boundaries
between which the facility can operate in compliance with the standards for
DRE, and metal emissions standards. Facilities may also conduct risk burn
testing at conditions representative of normal operations. The test results
collected for these conditions may be used to conduct the risk assessment for the
facility. During a trial burn, a facility's general strategy is to operate under
conditions that will yield a broad range of permit operating conditions.
Check For: The TBP reviewer should check for the following information:
Q Number of test conditions
Q Number of trial burn runs planned at each test condition
Q Number of replicate sampling runs during each run
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q Sampling time during each sampling run
Q Anticipated time for establishing steady operation under process test
conditions
Q Total time for each test run under the proposed operating conditions
Example Sections: Lois and Clark review Exhibit 3.1.3.1-1, see page 1-67, which presents the
overall schedule for the trial burn. Exhibit 3.1.3.1-2, see page 1-68, shows daily
activities conducted during a test run.
Example Comments: Clark determines that Exhibit 3.1.3.1-1, see page 1-67, clearly presents the
overall planned trial burn duration and pretest activities. However, he believes
that the table should be more detailed and show the estimated sampling duration
for each sampling method used during the trial burn. He also notes that the table
does not show the different stack sampling methods to be used during the trial
burn and that the duration must always include at least three runs under each
condition. If testing becomes more complicated with long sampling times, one
run per day should be scheduled. Few combustion units typically plan more than
one run per day unless only a limited number of sampling trains—for example, an
U.S. EPA Method 0050 sampling train for PM, HC1, and C12 are all that is
required.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.3.3 Reviewing Section D-5b(l)(c)(3)—Quantity of Waste to Be Burned
Regulations:
Guidance:
Explanation:
Check For:
Example Sections:
40 CFR Part 270.62(b)(2)(iv)
40CFRPart270.66(c)(5)
U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." EPA-530-R-92-011. OSWER. March. Page 5-3.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.34.
To ensure that adequate supplies of waste and spiking compound are on hand,
the facility should evaluate the duration of sampling runs and the overall expected
duration of the trial burn. The facility should also estimate the quantity of waste
to be set aside as a contingency supply.
The TBP reviewer should check for the following information:
Q Estimated duration of waste feed during the trial burn
Q Waste feed rate (for each waste type)
Q Total volume of each waste required for the trial burn
Q Amount of POHC spiking compound required for the trial burn
Q Amount of ash surrogate required for trial burn
Q Safety factor in estimation of total waste feed
Q Methods of disposing of any wastes and spiking compounds remaining
after trial burn
The U.S. EPA Region 6 generic TBP included as Attachment A includes
examples of these calculations.
Clark reads the following table that presents an estimate of the quantity of liquid
and vapor waste required to conduct a trial burn based on 14 hours per test day
of feeding and 4 test days.
Stream
Aqueous
Solvent
Quantity Required
per Test Day
1,680 gallons
84 gallons
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Stream
Vapor — low flow
Vapor — high flow
Quantity Required
per Test Day
252,000 standard cubic feet
420,000 standard cubic feet
Example Comments: Clark notes that the proposed quantity of waste does not discuss contingency
material. If there is a delay in stack sampling or problems with plant operations,
the combustion unit should be kept operating at test conditions to maintain steady
state conditions. This requires that a contingency amount—generally 50
percent—of consistent waste material be readily available. For facilities where
the waste feed includes large amounts of liquid waste, such as the aqueous waste
in this example, storage for this contingency waste should also be addressed.
Clark requests that the TBP identify quantities of waste needed for both the
actual test and as a contingency. Without this discussion, a complete technical
review is difficult to conduct.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4 Reviewing Section D-5b(l)(d)—Test Protocols
Regulations:
40 CFR Part 270.62(6)(2)(v)
40CFRPart270.66(c)(6)
Guidance:
Explanation:
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.35 through D-5.41.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." EPA-R6-098-002. Section 2.3.1.
This section examines waste characteristics, POHC selection, operating
conditions, and other issues related to acceptable permit conditions. It also
discusses organic chlorine and feed metals and their removal by the APCS.
If the trial burn is conducted under only worst-case conditions (that is, a low and
high temperature test during which DRE and metals system removal efficiency
(SRE) are demonstrated, respectively), then emission rates used in the risk
assessment should be the lower of either (1) the maximum emission rate value
for all test runs or (2) the 95th percentile emission rate value for all test runs
conducted at the worst-case conditions. If those emission rates are determined
to be protective, the worst-case conditions should be established in the permit as
not-to-be exceeded minimum and maximum conditions.
If a risk burn test is conducted under normal operating conditions, then emission
rates used in the risk assessment should be the lower of either (1) the maximum
emission rate value for all test runs or (2) the 95th percentile emission rate value
for all test runs conducted at the normal conditions. If those emission rates are
determined to be protective, the normal operating conditions should be established
in the permit as baseline conditions around which the unit should operate a high
percentage of the time. See Component 7—How to Prepare Permit Conditions
for a discussion on using risk burn test results to set permit limits.
Overall, the facility should evaluate the impact on dioxin and furan formation
from each of the variables described in the following subsections. Specifically,
each TBP or RBP should include:
• A description of any combustion unit-specific operating
conditions that may contribute to the formation of dioxins
• Any information regarding background PCDD and PCDF
concentrations, and a comparison of these concentrations to
concentrations expected from the combustion unit, determined by
modeling or available sampling information
• Information regarding the concentration of sulfur, fluorine, and
bromine in the combustion unit feed materials
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Check For: See Subsections 3.1.4.1 through 3.1.4.11 of this component for specific "check
for" items.
Example Sections: For each of the subsections in this part of Component 1, an example section is
presented for the specific topic. All examples are from actual TBPs submitted to
U.S. EPA.
Example Comments: Comments on each topic covered by this section are presented in
Subsections 3.1.4.1 through 3.1.4.11 of this component.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.1 Reviewing Section D-5b(l)(d)(l)—Waste Characterization
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 270.62(b)(2)(i)
40 CFR Parts 270.66(c)(l) and (2)
U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incinerator
Permits." OSWER. July. Section 3.1, Pages 3-1, through 3-4.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.35 through D-5.41.
Waste characterization of the hazardous wastes to be treated in the combustion
unit are discussed in Section C of the Part B permit application (see Section 5.0
of Component 3 of the manual) and in the introduction to Section D-5 of the
TBP. The TBP should summarize relevant combustion parameters for wastes to
be treated during normal operation.
Trial burn protocols for collection of data will need to address waste analysis and
QA/QC procedures for completely characterizing the trial burn wastes, fuel, raw
materials, and spike materials. Data equivalent to, or superior than, the following
should be generated:
• Quantification of total metals feed rates for arsenic, beryllium,
cadmium, chromium, silver, barium, mercury, lead, antimony,
thallium, nickel, selenium, copper, iron, aluminum, and zinc
• Proximate analysis, or a comparable evaluation, to determine
physical properties including moisture, percent solids, heating
value, and viscosity or physical form, as well as to determine
approximate chemical properties including TOC, TOX, and
elemental composition
• Survey analysis or a comparable evaluation for: (1) total organic
content; (2) organic compound class types; and (3) major organic
components, using analysis for VOCs, SVOCs, PCBs, and
PCDD/PCDF using standard analytical methods
• Directed, quantitative analysis for POHCs to demonstrate DRE
Hazardous waste characterization should include the following parameter testing:
Q Btu content
Q Halogen content
Q Water content
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Q Ash content
Q Viscosity
Q Specific gravity
Q Sulfur content
Q Metals content
Q VOC, SVOC, PCB, and PCDD/PCDF analysis results
Q POHC content
Q Metals analysis results
Q Proximate analysis results
Q Survey analysis results
Q Quantitation of POHC in waste streams
Example Situation: Lois and Clark review the waste characterization discussion in the facility's TBP:
"The wastes proposed for the test burn have been selected to represent the
actual wastes that will be burned. Because the incinerator is operated for
commercial purposes, the physical and chemical properties of wastes received
for combustion vary considerably from day to day.
"Exhibit 3.1.2.2-1, see page 1-63, shows the waste feed methods and properties
of the wastes to be used in the test burn. These represent the typical chemical
and physical properties of wastes that are incinerated. Essentially, all
combustible hazardous compounds listed in 40 CFR Part 261, Appendix VIII,
may be combusted in normal operations. Furthermore, any Appendix VIII
compound may be present in each type of waste shown in Exhibit 3.1.2.2-1, see
page 1-63."
Example Action:
Is this a satisfactory discussion of waste characterization? In large part, yes.
Because this example is for a commercial operation, the general characteristics
of waste streams presented in Exhibit 3.1.2.2-1 are representative of waste
stream variability anticipated during normal operation. For general
characterization purposes, waste characteristics identified will be sufficient for
the reviewer to determine whether the waste feed streams, proposed for the trial
burn test are representative of normal waste feeds.
Although it is difficult for a commercial facility to inventory enough waste to
conduct the trial burn, Lois and Clark request that the facility identify the specific
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waste feed mixture that will be used during the trial burn test and descriptive of
how this waste stream is representative of worst case (DRE test) or normal
operations (risk burn).
For testing of an on-site hazardous waste combustion unit, waste characterization
is much less complicated, and the facility should provide detailed analyses of each
waste feed stream.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.2 Reviewing Section D-5b(l)(d)(2)—Principal Organic Hazardous Constituent Selection
Rationale
Regulations:
Guidance:
Explanation:
Check For:
40CFRPart270.62(b)(4)
40CFRPart270.66(e)
U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incinerator
Permits." OSWER. Washington, D.C. Section 3.1; Pages 3-1 through 3-4.
July.
U.S. EPA. 1989. "Handbook: Guidance on Setting Permit Conditions and
Reporting Trial Burn Results." EPA/625/6-89/019. January. Pages 22
through 23.
U.S. EPA. 1992. "Technical Implementation Document for EPA's Boiler and
Industrial Furnace Regulations." EPA-530-R-92-011. OSWER. March.
Pages 10-13 and 10-14.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.35 through D-5.41.
POHCs are compounds that the facility proposes for trial burn demonstration of
the required DRE, which is 99.99 percent for hazardous wastes and 99.9999
percent for dioxins and furans. The permitting authority provides input as to the
appropriateness of the proposed POHCs. Criteria for POHC selection are
discussed in detail in U. S. EPA 1989 Guidance in Setting Permit Conditions.
Historically, there has been confusion relative to the terms POHCs, PICs, and
organic chemicals. Recent guidance defines the term "PIC" to encompass any
organic species emitted from the stack, regardless of the origin of the
compounds. Risk assessments are generally concerned with the health risks
posed by emissions from the facility. It makes little difference with respect to
risk if the organic compound was formed from a compound specified as a
POHC, or if it formed from other materials added to the combustion device.
The TBP reviewer should check for the following information:
Q Compounds selected as POHCs
Q Basis for selecting POHCs
Q Degree of difficulty of destruction of organic constituents
Q Concentration or mass of 40 CFR Part 261, Appendix VIII
organics in the waste feed, based on waste analysis
Q Surrogate POHCs
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Q Whether POHCs selected can be measured by reliable and conventional
techniques
Q Whether POHCs are potential PICs of the fuels, hazardous wastes, or
other POHCs
Q Whether the operation or product of the facility might be upset
Q Feedable and meterable
Q Not dangerous to handle (for example, unstable or acutely toxic POHCs
are not typically recommended)
Example Situation: Lois and Clark read the POHC selection rationale section of the TBP as follows:
"The incinerator is operated for commercial purposes and burns a wide variety of
chemical wastes in solid and liquid form; therefore, a fully flexible permit is
preferable for this facility. Accordingly, the criteria for selection of POHCs for a
test burn should be based on the assumption that any Appendix VIII compound
may be fed into the incinerator. The criteria used in selection of the POHCs that
will demonstrate the incinerator's performance include incinerability and other
theoretical considerations that designate compounds on the basis of being difficult
to burn.
"The heat of combustion approach to POHC selection is based on equilibrium
theories that state that the primary concern in elevating the difficulty in destroying
a compound is the amount of energy needed to complete the combustion process
(with water, CO2, and, in some cases, an acid gas as final combustion products).
However, a POHC selection now exists that is based on thermal stability in
nonflame laboratory tests. This approach, which considers chemical structure
stability, is based on the assumption that the primary concern is a temperature at
a specified residence time required to achieve the DRE in laboratory tests.
Besides the incinerability rankings, the following additional criteria have been
considered in the selection of POHC:
• High relative abundance in the waste materials.
• Gases have been excluded, because the incinerator is not equipped to
feed gaseous waste feeds. However, it can feed aerosol cans as part of
the containerized solids.
• Compounds selected as POHCs are stable enough to allow for
conventional volatile organic sampling train or Modified U.S. EPA
Method 5 sampling and analytical techniques.
• Compounds selected as POHCs are sufficiently available to allow an
adequate quantity for trial burn demonstration purposes.
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"Because none of the waste types currently received is in a gaseous state at
ambient temperature, this criterion was excluded from further consideration in the
POHC selection process. Also, compound stability should not be a concern
because most of the hazardous constituents normally occurring in waste materials
received are sufficiently stable to allow the use of conventional sampling and
analytical methodologies.
"Availability can be a serious concern in POHC selection because (1) the
operation depends on its customers for its supply of waste materials, and (2) this
supply is far less consistent than is typical for an incineration facility intended to
handle wastes generated by only one source or company. Of the remaining
criteria, relative abundance is considered to be most important if selected POHC
are to be representative of actual hazardous compounds commonly found in
various waste streams received.
"Alternatively, if difficulty in destruction is considered to be most important, those
compounds that exhibit the highest ranking on the incinerability or kinetics list
should be selected as POHCs. These will most accurately demonstrate the
incinerator's ability to achieve a 99.99 percent DRE on the most difficult to
destroy. They will thereby demonstrate the incinerator's ability to destroy any of
the Appendix VIII compounds. Ideally, those compounds that are abundant in
the waste feed and have a relatively high ranking on the incinerability list should
reasonably satisfy both criteria and should, therefore, be selected as POHCs.
"As a result of discussions between the facility and regulators, POHC selection
for the test burn will meet the aforementioned criteria and will also address the
U.S. EPA's current concern regarding the incinerator's ability to demonstrate an
effective DRE on constituent compounds contained in the feeds.
"Target POHC selected for testing the incinerator should include one volatile
compound and two semivolatile compounds. These POHCs will be spiked into
the waste fed to the incinerator. Compounds selected are:
• Monochlorobenzene (volatile POHC)
• Hexachloroethane (semivolatile POHC)
• Naphthalene (semivolatile POHC)
"All selected POHCs can meet the abundance criteria. Hexachloroethane is
ranked sixth on the U.S. EPA incinerability list (based on heat of combustion).
Monochlorobenzene and naphthalene are ranked in Class I of the thermal stability
list. Other 'naturally occurring' Appendix VIII constituents that may be present
in any of the waste stream types are as follows:
• Dichloromethane
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
• Chloroform
• Trichloroethene
• 1,1,1-Trichloroethane
• Methyl ethyl ketone
• Methyl isobutyl detone
• Xylene
• Toluene
• Benzene
"A 99.99 percent DRE for selected POHCs will adequately demonstrate the
incinerator's ability to achieve a similar DRE for any of the Appendix VIII
compounds. The sampling and analytical methods are adequate to demonstrate
these DREs."
Both Lois and Clark are largely satisfied with this section. This section highlights
an important aspect regarding the two ranking schemes used by U.S. EPA.
While the heat of combustion approach is not as popular as in the past (because
the least incinerable compounds are now controlled by the Montreal Protocol and
are not available), this approach is still widely used. However, the TBP fails to
target native POHCs in waste streams routinely treated by the facility. Although
spiking injects target compounds into the incinerator, Lois asks the facility to
modify the TBP to target a few compounds native to the waste for demonstrating
DRE and characterizing normal emissions for the risk burn.
The TBP mentions nothing about metals addition or analysis. The permit writer
should address this on a case-by-case basis. The facility in this case stated that it
was not obligated to test for metals because it was not a BIF facility. Although
no clear regulations exist concerning metals for commercial incinerators, metals
analysis should be considered for each facility, in accordance with BIF
regulations.
Additionally, although the facility chose not to (or did not need to) describe the
availability of proposed waste feed streams, some facilities may present a
discussion regarding the economic availability of certain POHCs. This type of
issue should be addressed on a case-by-case basis for each facility because a
POHC should not cost an inordinate amount to obtain and use in a test burn.
Example Action:
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.3 Reviewing Section D-5b(l)(d)(3)—Operating Conditions
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 270.62(b)(2)(v)
40CFRPart270.66(c)(6)
U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incinerator
Permits." OSWER. July. Section 2.4.2, Pages 2-41 through 2-44.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.35 through D-5.41.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." EPA-R6-098-002. Section 2.4.2.
This section should discuss selection of combustion system operating conditions
during the trial burn. This section of the TBP is extremely important because the
conditions under which the combustion unit is operated during the trial burn will
become operating restrictions that will be a part of the final operating permit. The
intent of the facility should be to select conditions that provide a maximum degree
of flexibility for future operations. This flexibility is generally achieved by testing
under worst-case conditions; for example, (1) maximum expected waste feed
rate, (2) maximum expected POHC concentration, (3) maximum expected waste
ash content, (4) maximum expected waste chlorine content, and (5) minimum
expected combustion temperature. To fully demonstrate the combustion unit
DRE under a variety of conditions, it may be necessary to conduct more than one
series of tests during the trial burn.
Because a facility may not want to conduct a risk assessment based on these
worst case conditions, some facilities that treat very consistent, homogeneous
waste streams (for example, captive on-site units) may also choose to conduct a
risk burn at normal operating conditions in order to collect data to be used to
conduct the risk assessment (it is not anticipated that commercial hazardous
waste TSDFs will be eligible for this option, see Component 3). In this case the
facility should propose additional permit conditions that can ensure the facility
operates the combustion unit within a reasonable range surrounding the "normal"
conditions under which the risk assessment data were collected. See Component
7—How to Prepare Permit Conditions for further discussion on permit limits.
Information for the test condition demonstrating worst-case metals emissions
should include the following:
Q Maximum PCC temperature
Q Types of wastes (high Btu; low Btu; solid, sludge or liquid)
Q Waste feed rates to the PCC and SCC
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Q Maximum ash content in wastes
Q Maximum chlorine feed rate
Q Maximum metals feed rates
Q Worst-case APCS operating parameters
Q Maximum combustion gas velocity
Information for the test condition demonstrating DRE of PCC should include the
following:
Q Maximum liquid and waste feed rate in the PCC and SCC
Q Maximum ash content in liquid waste feed
Q Minimum PCC and SCC temperature
Q Maximum combustion gas velocity
Q Maximum organic chlorine content in waste streams
Q POHC fed to the PCC and SCC
Q Worst-case APCS operating parameters
Q PIC formation and emission rates
Information for normal operating test conditions (risk burn):
Q Average PCC temperature
Q Types of wastes (high Btu, low Btu, solid, sludge, or liquid)
Q Waste feed rates to the PCC and SCC
Q Ash content in wastes
Q TOC feed rate
Q PIC formation and emission rates
Q Average SCC temperature
Q Average combustion gas velocity
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Example Situation:
In reviewing the Operating Conditions section of the TBP, Clark reads as
follows:
"The purpose of the test is to demonstrate that all applicable emission limits can
be met by operating the unit under worst-case operation conditions.
"As presented earlier, two separate operating conditions are proposed for testing.
Day 1 is the higher temperature condition that should be used to evaluate metals
emissions. On Day 2, where lower operating temperatures are proposed, this
operating condition should provide a conservative estimate of DRE.
"Establishing approximate stabilization of metals and chlorine in the kiln is
important to the accuracy of the test. The operation does not return PM to the
kiln.
"About 2 to 3 hours prior to the start of testing on Day 1, the kiln system will be
stabilized with metals and chlorine. This will be accomplished by maintaining a
feed rate to the kiln prior to testing, which is equivalent to the feed rate of
chlorine and metals specified for testing. For DRE testing on Day 2, POHCs will
be fed to the kiln at the rates specified. Exhibit 3.1.4.3-1, see page 1-86
summarizes key process parameters, proposed feed rates, and the expected
operating parameters during the test period. Any deviations from the plan will be
noted and explained in TBRs.
"To assess chlorine and metals emissions from the kiln at elevated temperatures,
the test condition on Day 1 will fire 100 percent waste fuel as a worst-case
scenario. Waste fuel will be fired at the approximate rate indicated in
Exhibit 3.1.4.3-1. The company will collect data from the product discharge (hot
end 2,500 to 3,000 °F) of the kiln and the feed end (cold end 700 to 1,000°F) of
the kiln to determine which is the best indicator of combustion zone temperature.
Hot-end combustion zone measurement will be made with an optical pyrometer
that measures infrared emissions. Because an optical pyrometer is subject to
interferences "such as flame pattern variation or dust loadings," a thermocouple
will be installed at the kiln gas exit in the discharge duct work prior to any dilution
air introduction to concurrently measure kiln exit temperature. Because
thermocouples directly measure temperature, less fluctuation is expected to
occur. Based on a review of the final data, the company will determine which is
the best indicator of combustion zone temperature. The operating temperature of
the unit will be maximized at about 2,500°F at the hot end. All surrogate material
will be fed to the unit through the waste fuel line.
"To assess organic POHCs DRE from the kiln at lower operating temperatures,
the test condition on Day 2 will again use 100 percent waste fuel as a worst-case
scenario. The operating temperature of the unit, as measured in the wall, will be
minimized (1,800°F hot end). Other operating parameters are shown in
Exhibit 3.1.4.3-1. All spike material will be fed to the unit through the waste fuel
line."
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Example Action: Clark notes three major problems in this section: (1) no indication exists that
PCDD/PCDF testing will be conducted; (2) the proposal to conduct all three runs
of a test condition in 1 day is unreasonable; and (3) this discussion fails to
demonstrate that the proposed POHC feed rate will result in POHC emission
rates needed to calculate the projected 99.999 percent DRE (see
Exhibit 3.1.4.3-1). In addition, the acceptable combustion zone temperature
indicator will be the one that is acceptable to the permit writer and the relevant
regulatory agency, not just to the facility. Clark asks the facility to address each
of these issues and to provide more detail regarding the relationship of proposed
operating conditions to the overall test purpose and the type of information that
each test condition will provide to support proposed permit conditions.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-8
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.4.3-1
EXAMPLE TEST OPERATING PARAMETERS
Stream
Toluene
Tetrachloroethylene
1 ,2,4 Trichlorobenzene
Arsenic
Beryllium
Cadmium
Chromium VI
Lead
Waste Fuel
Maximum production
rate
Minimum production
rate
APCS temperature
Lime injection rate
Baghouse Delta P
Carbon monoxide
Units
Ib/hr
(DRE)
Ib/hr
(DRE)
Ib/hr
(DRE)
Ib/hr
Ib/hr
Ib/hr
Ib/hr
Ib/hr
Ib/hr
tons/hr
tons/hr
°F
Ib/hr
inches w.c.
ppm
Operating Conditions
Dayl
-
25.0
-
1.08
0.26
2.84
2.32
30.94
4,650.0
14
-
<450
<400
3.0
<100
Day 2
1,340
(99.999)
25
(99.999)
0.4
(99.999)
-
-
-
-
-
3,000
-
9
<450
<400
3.0
<100
Quantity for
Test (pounds)
28,070
1,049
8.4
22.6
5.4
59.5
48.7
649.7
160,650
NA
NA
NA
NA
NA
NA
Notes: APCS Air pollution control system
DRE Destruction and removal efficiency
°F Degrees Fahrenheit
Ib/hr Pounds per hour
NA Not applicable
ppm Parts per million
ton/hr Tons per hour
w.c. Water column
Not applicable
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.4 Reviewing Section D-5b(l)(d)(4)—Waste Constituents
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 270.62(b)(2)(i)
40CFRPart270.66(a)(4)
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.35 through D-5.41.
The waste feed must be sampled and analyzed in accordance with 40 CFR
Parts 264.13, 270.19, and 270.11(k). Specifically, waste feed must be analyzed
for heating value, viscosity (if liquid), and the hazardous organic constituents
listed in 40 CFR Part 261, Appendix VIII. Analysis is required for (1) any of the
300 constituents in Appendix VIII, which may be reasonably expected to be
present for waste characterization; or (2) selected constituents from the trial burn
list. There are many other parameters that may be useful to more fully
characterize the waste.
Physical analysis gives information on physical characteristics and general
chemical composition of the waste, including the following: heating value,
viscosity, ash content, TOC, moisture content, solid content, and elemental
composition.
RCRA regulations require waste characterization for heating value and viscosity.
Ash content is generally required as an indicator of inorganic loading and other
factors that may affect the amount of particulate generated. TOX is needed to
determine HC1 removal efficiency. Although other analyses are not required,
they may be of value to the combustion unit operator in characterizing waste feed
and operating the combustion unit.
A major objective of the trial burn is to measure the DRE of selected POHC. To
do this, the sampling and analysis program must measure the input and output
rates of the POHC. In addition to quantitating the native POHC in the
input/output streams, it is also necessary to conduct analyses for speciated VOCs
and SVOCs to determine (1) the feed rate Appendix VIII compounds fed to the
unit and (2) the potential emission rate for any PICs formed within the
combustion unit.
For combustion units with multiple feed mechanisms, it may not be possible to
maximize each waste feed type simultaneously during one test condition.
Therefore, more than one DRE, dioxins and furans, and PIC test conditions may
be needed to maximize different waste feed types during different test conditions.
The TBP reviewer should check for the following information:
Q American Society for Testing and Materials (ASTM) method for
physical parameters
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q U.S. EPA approved methods for organic analysis (many found in SW-
846)
Q Appendix VIII analytical results
Q POHC quantitation results
Q Regulated metals content of input streams and combustion gases
Q Ash content of input material
Q Chlorine/chloride content of input material
Q Analytical scan of hazardous constituents in feed and combustion gas for
risk burns
Q Viscosity of liquid feed materials
Q Heat content of feed materials
Q POHC content of ash, baghouse dust, and blowdown water
Q Metals content of ash, baghouse dust, and blowdown water
Example Situation: Lois reads the Waste Constituents section of the TBP as follows:
"The liquid waste feed for the combustion unit consists of condensed vapors from
the reactors. The fraction of these vapors that remain in the vapor state is also
burned in the combustion unit. This section (1) describes wastes to be
combusted, (2) identifies and quantitatively estimates any hazardous constituents
present in the waste, and (3) recommends POHCs to use in demonstrating
combustion unit performance.
"The liquid waste feed contains aqueous and organic phases. Hazardous
constituents that must be considered for a trial burn are specified in 40 CFR Part
261, Appendix VIII. Many of these constituents can be eliminated from further
consideration as POHCs based on knowledge of the waste feed composition and
process operations.
"The TBP presents results of analyses completed on samples of the liquid
aqueous waste and waste solvent. Exhibit 3.1.4.4-1, see page 1-90, presents
estimated concentrations of hazardous organic constituents in the mixed waste.
Of the hazardous organic constituents identified, seven compounds "acetones,
1,4-dioxane, phenol, chlorobenzene, allyl alcohol, acrolein, and styrene" were
found at concentrations exceeding minimum levels greater than 100 ppm. Exhibit
3.1.4.4-2, see page 1-91, summarizes characteristics of the mixed waste feed."
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Example Action: While generally pleased with this section, Lois asks that the facility provide
additional information regarding any POHC spiking that will be conducted during
the trial burn test, including (1) proposed storage containers (2) metering systems,
and (3) point of entry into the system. Lois finds the waste analysis presentation
in the tables to be acceptable; some facilities will resist analyzing test waste in
such detail. Although not presented here, the appendices present metal analyses,
most of which contain negligible values. This section; however, does not address
or identify the sampling and analytical methods used to identify the hazardous
constituents, nor is it clear whether the facility will conduct comprehensive
sampling and analysis for speciated VOCs and SVOCs. Lois asks that the
facility clarify these issues in the revised version of the TBP.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-92
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.4.4-1
SUMMARY OF HAZARDOUS ORGANIC CONSTITUENTS IN LIQUID WASTE FEED
Hazardous Organic
Constituent
1,4-Dioxane
Chlorobenzene
Acrolein
Acetone
Allyl alcohol
Phenol
Styrene
Toluene
Xylene
Ethyl benzene
Concentration (mg/L)
830 to 10,000
0 to 400
130 to 170
1,900 to 14,300
5,900 to 10,000
96 to 117
0 to 8,000
Oto 130,000
0 to 5,000
0 to 9,000
Heat of Combustion (kcal/g)
6.41
6.6
6.96
7.36
7.75
7.78
10.07
10.14
10.25
10.28
Notes: kcal/g kilocalories per gram
mg/L milligrams per liter
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.4.4-2
SUMMARY OF ESTIMATED WASTE FEED CHARACTERISTICS
Parameter
Value
Ultimate Analysis (weight percent)
Carbon
Hydrogen
Oxygen
Chlorine
Nitrogen
Phosphorus
Sulfur
5-7
9-11
79-83
<0.83
<0.30
<0.01
<0.02
Physical Parameters
Higher heating value (Btu/lb)
Viscosity (centipoise)
Ash content (weight percent)
Oto 1,300
1.0 maximum
negligible
Notes:
Btu/lb British thermal unit per pound
< Less than
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.5 Reviewing Section D-5b(l)(d)(5)—Combustion Temperature Ranges
Regulations: 40 CFR Part 270.62(b)(2)(v)
Guidance: U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incinerator
Permits." OSWER. July. Section 3.1; Pages 2-41 through 2-44.
U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." EPA-530-R-92-011. OSWER. March. Page 4-9.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.35 through D-5.41.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." EPA-R6-098-002. Section 2.4.2.
Explanation: The TBP should indicate anticipated operating temperature ranges in the PCC
and SCC for all tests. A maximum combustion chamber temperature must be
established during the metals test condition. Maximum combustion temperature
is an important parameter with respect to metal emissions. A minimum
combustion chamber temperature must be established during the POHC spiking
test. Minimum combustion temperature impacts organic compound destruction.
If a facility chooses to conduct a risk burn, the RBP should discuss the
combustion temperature range expected during the risk burn test, including a
demonstration of the representativeness and a detailed comparison of this
"normal" range to the maximum and minimum values.
Check For: The TBP reviewer should check for the following information:
Q PCC operating temperature range
Q Proposed minimum value
Q Proposed maximum value
Q Proposed normal value
Q SCC operating temperature range
Q Proposed minimum value
Q Proposed maximum value
Q Proposed normal value
Example Section: Lois reads the Combustion Temperature Ranges section of the TBP as follows:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
"This TBP will involve three test conditions, with three runs under each condition,
to establish organic DRE, metals emission rates, PIC formation, and the HC1 and
C12 emission rates. PM will also be measured as part of each run.
The three test conditions will be as follows:
1. Afterburner temperature—2,000°F (Metals SRE Condition)
Maximum heat release rate attainable at 2,000°F
Maximum solids loading attainable in the kiln with stack
opacity constraints
Constant air rate (based on induced-draft fan amps)
Maximum aqueous feed waste attainable at heat release
rate
2. Afterburner temperature— 1,800°F (DRE Test Condition)
Maximum system heat release attainable at 1,800°F
Maximum solids loading attainable in the kiln with stack
opacity constraints
Maximum solids heat release rate in the kiln
Constant air rate (based on induced-draft fan amps)
Maximum aqueous feed waste attainable at heat release
rate
3. Afterburner temperature—1,900°F (Risk Condition)
Maximum heat release rate attainable at 1,900°F
PIC emission rates
Average solids loading
Average air rate
Average aqueous feed waste, using worst-case waste"
Example Comment: This section makes it clear to Lois that the facility plans to conduct the trial burn
at three different afterburner temperatures. The higher temperature test will be
U.S. EPA Region 6
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
for metals emissions, the lower temperature will be for DRE testing, and the third
test will be used for the risk assessment.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-97
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.6 Reviewing Section D-5b(l)(d)(6)—Waste Feed Rates
Regulations: 40 CFR Part 270.62(b)(2)(v)
40 CFR Part 270.66(c)(3)(v)
Guidance: U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." EPA-530-R-92-011. OSWER. March. Pages 4 through 9.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.35 through D-5.41.
Explanation: The TBP should specify feed rates for each of the wastes that the facility
proposes to burn during and after the trial burn.
Check For: The TBP reviewer should check for the following information:
Q Solid waste feed rates
Q Liquid waste feed rates
Q Thermal capacity of the combustion unit to handle proposed feed rates
Q Ability of the APCS to meet HC1 and C12 emission rate limits based on
the proposed C12 feed rate
Q Other feed streams
Example Sections: Exhibit 3.1.4.6-1, see page 1-95, is an example of one table submitted to meet the
requirements of this section.
Example Comments: Exhibit 3.1.4.6-1, see page 1-95, presents the planned waste feed rates for the
two proposed test conditions. However, Lois determines that the TBP did not
explain why specific rates were chosen or used. Lois requests that this section
should describe (1) how the waste feed rates have been determined and (2) why
specific wastes were used. Lois asks that this information be included as
footnotes to the table or as a text discussion in Section D-5b(2)(e)(6).
Alternatively, this section can refer to this information if it is presented in
sufficient detail in another section of the TBP.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.4.6-1
WASTE FEED RATES, HEAT INPUT, AND AVERAGE CHLORINE INPUT
Waste Feed Rate
(Ib/hr)
Liquid injection blend
Liquid injection auxiliary blend
Aqueous
Secondary Combustion
Chamber blend
Kiln east blend
Kiln alkyls blend
Kiln sludge
Kiln solids
TOTAL ALL FEEDS
Waste Heat Input
(MMBtu/hour)
Blend
Aqueous
Sludge
Solids
TOTAL ALL FEEDS
Chlorine Input
Chlorine in Feed
Testl
3,332
3,078
10,228
632
1,232
1,078
NA
3,198
22,778
Testl
92.71
1.02
NA
0.84
94.57
Testl
10.24
Testl
2,228
3,600
4,560
7,772
366
574
1,002
7,182
20,284
Testl
68.29
0.46
8.49
18.00
95.24
Testl
12.91
Notes: MMBtu
NA
Ib/hr
Million British thermal units
Not Applicable
Pounds per hour
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.7 Reviewing Section D-5b(l)(d)(7)—Combustion Gas Velocity Indicator
Regulations: 40 CFR Part 270.62(b)(2)(v)
Guidance:
Explanation:
Check For:
Example Situation:
U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." OSWER. EPA-530-R-92-011. March. Pages 4 through 9.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.35 through D-5.41.
The TBP should specify the method and location of measuring combustion gas
velocity. Combustion gas flow rate measured at the stack is usually a good
indicator of combustion gas velocity. Other indicators that may be used include
combustion air feed rate and fan operating conditions.
Maximum combustion gas velocity must be demonstrated during the PM, metals,
and HC1 and C12 demonstrations to ensure maximum particulate and metals
carryover to the APCS and the greatest challenge for the APCS. Likewise,
maximum combustion gas velocity is needed during the DRE test condition to
ensure minimum residence time in the combustion chamber. Therefore, to the
extent possible, the facility should maintain the same maximum combustion gas
velocity during all of the performance standards and emissions demonstrations.
The TBP reviewer should check for the following information:
Q Indicator of combustion gas velocity
Q Measurement of gas flow rate at stack (direct method)
Q Measurement of restriction of pressure drop across flow, such as
venturi chamber or orifice plate (indirect method)
Q Combustion chamber pressure (indirect method)
Q Rate of combustion air feed to the combustion system
Q Induced draft fan operating conditions (indirect method)
Lois and Clark read the Combustion Gas Velocity Indicator section of the TBP
as follows:
"Stack gas velocity is an indication of the gas residence time in the SCC, which is
critical to complete thermal destruction of waste materials. Therefore, stack gas
velocity is measured with dual redundant thermal dispersion flow transmitters.
One signal is selected to be displayed and interlocked, and both signals are
continuously monitored and compared. A sustained, significant deviation will
cause an alarm to alert the operator of the possible malfunction of one of the
transmitters."
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Example Action:
Clark has identified several deficiencies in this section. This section provides no
manufacturer information or information on how the device works. Based on
trial burn results, there will be a maximum stack gas flow rate that is not to be
exceeded. When the transmitter senses that the gas flow rate is nearing this
limit, it should alarm the operator and be interlocked to the high-Btu liquid feed to
reduce the flow rate of this material. Stack gas flow rate is important in
developing a complete operating envelope and controlling operations. Another
control is to limit the induced-draft fan amps to the maximum level demonstrated
during the successful trial burn. The language in the example is weak, and alarm
settings—triggered by "sustained, significant deviation"—are too vague to be
technically reviewed. Clark asks that the facility revise this section to include a
complete discussion of (1) manufacturer information, (2) operating principles (for
example, how does the device calculate flow, what does it measure, what values
does it produce), (3) calibration information, (4) prealarm settings, and (5) system
interlocks.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.8 Reviewing Section D-5b(l)(d)(8)—Waste Feed Ash Content
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 270.62(b)(2)(v)
40 CFR Part 270.66(c)(3)(v)
U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incinerator
Permits." OSWER. July. Section 2.1.2, Pages 2-5 through 2-7.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.35 through D-5.41.
To assist in developing permit conditions, waste feed ash content should be
determined. The ash content of a waste is used to (1) evaluate potential slag
formation, (2) assess particulate removal requirements of the APCS, and
(3) determine whether the system is capable of handling ash. Ash content in
liquid wastes is minimal to none; therefore, ash surrogates, such as CaCl2, will be
added to the waste feed to establish permit conditions. This parameter does not
apply to cement kilns or lightweight aggregate kilns because the normal raw
materials fed to these devices have a high ash content.
To fully evaluate the impact of ash content on the system, the facility should
provide information regarding (1) ash variability in the waste feed, (2) potential
effects of ash on the combustion unit and APCS, (3) overall particulate emission
rates, and (4) soot blowing activities (boilers).
Permit limits on maximum ash feed rate will be established based upon the ash
feed rate during the PM emissions determination and during the dioxin and furan
testing. Ash feed rates should also represent reasonable
worst-case conditions during the PIC testing. Separate permit limits may be
established for and from atomizable feeds versus total ash feed rate.
The TBP reviewer should check for the following information:
Q Ash content of all waste streams and its variability
Q Surrogates used for establishing permit conditions with liquid waste
streams
Q Anticipated ash content permit conditions
Q Analytical method for determining ash content
Q Maximum ash feed rate
Q Soot blowing procedures and frequency
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Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Example Sections: Exhibit 3.1.2.2-1, see page 1-63, shows the ash content of each waste stream to
be used in the trial burn. These are ranges based on previous experience;
however, ash is a parameter that will be determined for each waste incinerated.
Example Comments: Exhibit 3.1.2.2-1 describes the ash content for each proposed waste stream.
Although ash is not a regulatory requirement, it is generally required as an
indicator of inorganic loading and other factors that may affect the amount of PM
generated. Ash content may also affect the operation of the combustion unit
burner or APCS. Additionally, the facility should ensure that ash content is
determined using only U.S. EPA and ASTM analytical methods.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering 1-103
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.9 Reviewing Section D-5b(l)(d)(9)—Auxiliary Fuel
Regulations: 40 CFR Part 270.62(b)(2)(v)
40 CFR Part 270.66(c)(3)(iv)
Guidance: U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incinerator
Permits." OSWER Washington, D.C. July. Section 4.1.2. Pages 4-5 through
4-11.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.35 through D-5.41.
Explanation: Auxiliary fuels are used to preheat PCCs to a desired operating temperature and
to supplement heating value for complete combustion of hazardous wastes.
Auxiliary fuels are also used to burn combustion gases in SCCs. Auxiliary fuels
that are generally used include natural gas, pulverized coal, and other fossil fuels.
Check For: The TBP reviewer should check for the following information:
Q Type of auxiliary fuel
Q Purpose of auxiliary fuel (such as preheating PCC and supplementing
heating value)
Q Source of auxiliary fuel
Q Auxiliary fuel feed rate
Q For natural gas, a certificate of analysis indicating the metal (particularly
mercury) and chlorine content of the fuel
Example Situation: Lois reads the Auxiliary Fuel section of the TBP as follows:
"Natural gas will be used as auxiliary fuel in the PCC and SCC. For the trial
burn, high-Btu liquid waste will be fired in the PCC and SCC. During normal
operation, natural gas may be fired in the PCC or SCC, if needed to maintain
temperature."
Example Action:
Although this section indicates that the facility will use natural gas and hazardous
wastes to generate the desired heating value, Lois notes that it does not specify
when hazardous wastes will be introduced. Hazardous wastes can only be
introduced after achieving optimum temperature; nonhazardous fuels can only be
used to preheat and achieve desired temperature. In addition, this section does
not identify auxiliary fuel source, location, feed rate, or certificate of analysis.
Lois asks the facility to revise this section based on her comments.
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Notes:
3.1.4.10
Regulations:
Guidance:
Explanation:
Check For:
Reviewing Section D-5b(l)(d)(10)—Organic Chlorine Content
40 CFR Part 266.102(e)(5)(I)(c)
40 CFR Part 270.62(b)(2)(v)
40 CFR Part 270.66(c)(l)(i)
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.35 through D-5.41.
To ensure efficient scrubber operation, C12 content should be determined by
sampling and analysis of the waste feed in accordance with the referenced
regulations. Analysis is performed for several parameters, but determination of
organic C12 content is important, because it affects the generation of acid gases.
These gases must be neutralized and/or removed before being discharged to the
atmosphere.
For DRE, PCDD/PCDF, and PIC determinations, chloride levels and other
halogens of concern in the waste feed (for example, bromine, fluorine, and
iodine) should be maintained at "worst-case" levels during trial burn tests and risk
burn tests
A high halogen content may locally deplete the available hydroxide radicals which
are necessary for complete destruction of organics and may lead to excessive
amounts of polyaromatic hydrocarbons or halogenated organics being formed in
addition to the possibility of C12 emissions. Generally, those halogenated organics,
which include PCDDs/PCDFs may represent the most toxic PICs.
The TBP reviewer should check for the following information:
Q Analytical results for total C12
Q Use of ASTM and EPA-SOET analytical methods
Example Situation:
Q Any QA/QC procedures associated with the analysis
Lois and Clark read the Organic Chlorine Content section of the TBP as
follows:
"The following table summarizes the frequency, number, type, size (or quantity),
and source (or collection point) of all samples to be collected during each test
burn. The test sample matrix presented in the table also lists proposed sampling
and analytical method(s) for each sample. It is organized by sample type and
analytical parameters. The matrix presented in this table represents the sample
U.S. EPA Region 6
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
collection scheme for one test run (that is, the number of samples collected
during one 2-hour test run only).
Waste Stream
High-Btu liquid
Aqueous waste
Containerized waste
Bulk solid waste
Kiln ash
Parameter
Total organic C12
Total organic C12
Total organic C12
Total organic C12
Total organic C12
Analytical Method
ASTM D808/D4327 or E442
ASTM D808/D4327 or E442
ASTM D808/D4327 or E442
ASTM D808/D4327 or E442
ASTM D808/D4327 or E442"
Example Action:
Lois and Clark agree that the text and table adequately address the requirements
for this section. Additional testing is not required, because information presented
in the waste characterization section of TBP indicates that other halogens are not
of concern at this facility.
Notes:
U.S. EPA Region 6
Center for Combustion Science and Engineering
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.1.4.11 Reviewing Section D-5b(l)(d)(ll)—Metals
Regulations: 40 CFR Part 266.102(e)(5)(I)(a)
40 CFR Part 270.62(b)(2)(v)
40 CFR Part 270.66(c)(l)(i)
Guidance: U.S. EPA. 1992. "Technical Implementation Document for EPA's BIF
Regulations." OSWER. EPA/530/R-92/11. March. Section 2.2, Page 2-2.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.35 through D-5.41.
Explanation: Facilities can use any one or a combination of three approaches to determine the
feed or emission rate for any regulated metal. These approaches, referred to as
"tiers," range from a simplified analysis based on conservative assumptions (Tier
I) to a site-specific analysis based on detailed facility information and air
dispersion modeling (Tier III). It is acceptable to use a combination of tiers to
comply with standards for individual metals.
The Tier I approach, which is the simplest but most conservative approach, limits
stack metals emissions based on the hourly feed rate of individual metals into the
combustion unit assuming all of the metals fed to the unit are emitted. The Tier
II approach limits stack emission rates of individual metals based on stack
emissions testing. The Tier III approach limits stack emission rates on the basis
of site-specific air dispersion modeling, stack sampling, and metals feed rates.
Compliance with Tiers II and III is confirmed by stack sampling. A combination
of Tiers I and III, referred to as adjusted Tier I, is used to back-calculate
maximum emission rates for individual metals. These emission rates then
become the adjusted feed rate limits, assuming that all metals fed to the
combustion unit partition to the exhaust gases (no removal).
Component 7 - How to Prepare Permit Conditions includes further discussion on
metals testing during the trial burn.
Check For: The TBP reviewer should check for the following information:
Q Tier I, Tier II, Tier III, adjusted Tier I evaluations
Q Approach followed in determining metals feed or emission rates
Q Feed rate for each metal
Q Metal solution concentrations have been correctly calculated and that the
proper valence for chromium is tested
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Example Situation: Clark reads the Tier III Metals section of the TBP as follows:
"The company proposes to meter lead, arsenic, beryllium, cadmium, and
hexavalent chromium into the HWF. Other BIF metals—mercury, antimony,
barium, silver, and thallium—have been assessed against Tier III dispersion
criteria and have been found not to exceed reference air concentrations
contained in BIF regulations, even when no removal is credited to the kiln
system.
"In accordance with EPA's Technical Implementation Document for BIF
Regulations (EPA 1992), metal compounds have been selected to be consistent
with the form of the metals in the HWF, whenever possible. HWF is typically a
blend of organic and aqueous wastes, coupled with high suspended solids content.
Metal sources in the HWF include (1) suspended inorganic paint pigment solids,
(2) organic metallic catalysts or viscosity modifiers, (3) inorganic metal containing
cleansing solutions, and (4) organic-based residual tank bottoms. Obviously,
organic and inorganic sources of metals are common in the HWF and may be
contained in aqueous or solid phases. The company has selected solution-based
metals to provide a conservative estimate of emissions because a greater
percentage will disperse to the flue gas of the unit.
"Metered quantities of metals are introduced most effectively for the purpose of
documenting precise feed rates by directly pumping organic or inorganic metal
solutions with the HWF. This technique assures greater accuracy than blending
of metals with the HWF before pumping. Pumping metal compounds—either
organic-based or water-soluble—at uniform rates while the compounds are
dispersed in the HWF supply line is considerably more reliable than mixing these
compounds in agitated storage tanks. Placing the compounds in storage tanks
may cause precipitation or sludging of one or more metals, thereby causing an
unreliable feed situation. Pumping them directly to the HWF supply line may
cause turbulence in the fuel line and burner assembly assures proper dispersion in
the flame zone. The selection process can be simplified by four criteria that are
considered to be important in evaluating a metal compound:
• Whether it is readily available commercially at a reasonable cost
and in the quantities required for the test.
• Whether the selected material is "manageable." It must not be
extremely corrosive, reactive, or flammable. The compound
should not pose significantly more potential health hazards than
the metal alone.
• Whether it is readily soluble in simple solvents, such as mineral
spirits, fuel oil, or water.
• If consistent with the criteria above, whether the compound has
the following specified properties:
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Organic-based,
If inorganic-based, the material can go into the solution at a
concentration that allows easy handling, or
Does not contain anions, in sufficient quantity, that might
interfere with or complicate the performance test protocol.
"The following organic- or inorganic-based compounds meet all of the criteria
and were selected for use:
"Cadmium - Cadmium acetate solution in methanol provides a workable
source of organically bound cadmium. Cadmium is usually present in
hazardous waste in pigments and petrochemical wastes.
"Lead - A mixture of lead 2-ethylhexoate and neodecanoate in a
petroleum distillate provides an excellent source of organically bound
lead.
"Arsenic - A sodium arsenate solution in water is frequently present in
hazardous wastes, because it is a commonly used fungicide and wood
preservative.
"Beryllium - Beryllium sulfate, 4-hydrate is very toxic. There is very
little beryllium in hazardous waste. Spiking rates are low. This
compound was chosen because it is relatively easy to manage and is
readily soluble in water.
"Chromium VI - Sodium chromate solution is an excellent source of
hexavalent chromium. This solution is also very easy to work with and
minimizes the potential hazard of hexavalent chrome."
Example Action: Clark notes that this discussion is sufficient to adequately address the
requirements of this section.
Notes:
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3.1.5 Reviewing Section D-5b(l)(e)—Pollution Control Equipment Operation
Regulations: 40 CFR Part 266.102(e)
40 CFR Part 270.62(b)(2)(vi)
40 CFR Part 270.66(c)(3)(vii)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. PageD-5.41.
Explanation: Regulations require a description of, and planned operating conditions for, any
emission control equipment that will be used. Typically, APCSs are designed to
remove PM and neutralize acid gases so the emissions of each remain within
standards.
Check For: The TBP reviewer should check for the following information:
Q APCS description
Q APCS design specification
Q Construction materials
Q Residue removal systems
Q Caustic control system
Q pH and temperature monitors
Q APCS operating conditions
Example Situation: Lois and Clark were reviewing the following description of an APCS:
"Section 1.0 Tempering Chamber - The tempering chamber is a refractory-lined,
vertical vessel equipped with water spray nozzles. Downflow combustion gases
are collected by water from spray nozzles to a set point temperature under
800°F. Gases then travel laterally and then upwardly through insulated ductwork
to a pair of vertical spray dryer absorbers.
"The abrupt change in direction of combustion gases causes additional solid
particulates to drop out of the gas stream into the bottom of the tempering
chamber. These solids are collected by a conveyor system at the base of a
tempering chamber.
"Section 2.0 Spray Dryer Absorbers - The spray dryer absorbers (SDA) are
insulated, vertical vessels equipped with overhead spray nozzles for the addition
of lime slurry to the gas stream. Lime slurry droplets react with acid gases to
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Example Action:
form dry calcium salts, which are removed by a conveyor system at the base of
the SDA.
"Section 3.0 Lime Slurry System - the lime slurry system consists of a dry lime
bin, a lim slurry mixing tank, and pumps. The lime-water blending is semibatch
and is process-controlled by level and density instrumentation. The lime slurry is
diluted and delivered as needed to spray nozzles in the SDAs.
"Section 4.0 Fabric Filters - the fabric filters are pulse jet-type baghouse with
insolatable compartments for on-stream maintenance. The particulate, which is
carried over from SDAs, will coat the exterior of the individual filter bag.
Periodically, an internal header directs a blast of air downwardly inside of these
bags. This blast causes the bag to flex, dislodging the built-up filter cake.
Filtered material drops to the bottom collecting chambers, and collecting
conveyors receive this material and transport it to a vacuum truck for disposal.
"Section 5.0 Collecting Drag Conveyors - Collecting drag conveyors transport
collected particulates, calcium salts, and unreacted lime from the SDAs and the
fabric filters to a mechanical conveyor system that discharges the materials into a
vacuum tanker. The material and air from this system discharges to a collecting
baghouse that discharges to the vacuum tanker. The air then passes through the
bulk solids storage baghouse prior to discharging to the atmosphere.
"The kiln ash, baghouse and spray-dryer-absorber residual, and SCC ash are all
considered to be hazardous and, after necessary analyses, are all disposed of at a
secure hazardous waste landfill.
"Section 6.0 Induced-Draft Fan - The induced-draft fan provides the motive
power for the entire incinerator train and APCS train. In so doing, the fan
produces a system wide negative pressure that prevents fugitive emissions.
"Section 7.0 Induced-Draft Fan Outlet Duct - The duct is insulated and includes
sampling nozzles and extractive continuous emissions monitoring.
"Section 8.0 Stack - The insulated stack is equipped with ports for U.S. EPA
isokinetic sampling and combustion gas flow monitoring instrumentation."
Lois and Clark noted several deficiencies in this section; some examples are
provided below:
This section, in its entirety, provides little information regarding construction
materials for components of the APCS. This information needs to be provided to
determine the potential for fugitive emissions and waste interaction with various
APCS components.
Section 1.0 This section provides information regarding the tempering chamber;
however, it does not identify the manufacturer. This information is needed to
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
determine the potential for fugitive emissions or maintenance problems caused by
a lack of readily available replacement parts.
Section 2.0 This section describes SDAs but not typical flow rates and basic
process flow information. Basic schematics should be a part of the stand-alone
TBP, not referenced to a document that the reviewer may not have.
Section 3.0 This section describes the lime slurry system but fails to discuss how
lime slurry is physically made and mixed. It is also unclear what is meant by
"process-controlled." A description of the entire system should be included.
Section 4.0 This section describes fabric filters. No information is presented
regarding (1) fabric material, (2) temperature limitations, or (3) pore size. This
section should be modified to include this information so that the permit writer
can determine if the bags are appropriate for the proposed system. This section
should also discuss bag durability and a potential maintenance and replacement
schedule (including a description of how bag leaks will be detected).
Section 6.0 This section describes the induced-draft fan; however, the maximum
capacity of the induced-draft fan or the fan curve are not included. This
information is needed so that the permit writer can review the adequacy of the
fan to maintain combustion pressure and prevent fugitive emissions.
Section 8.0 This section describes the combustion unit stack; however, it fails to
provide basic information such as diameter, height, and the location of sampling
ports and potential upstream and downstream disturbance. It mentions the
presence of "insulation;" however, it does not identify the type of insulation and
the potential for this insulation to be entrained in the stack gas and to affect
sampling results.
Lois and Clark ask the facility to revise this discussion based on their section-
specific comments.
Notes:
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3.1.6 Reviewing Section D-5b(l)(f)—Shut-Down Procedures
Regulations: 40 CFR Part 270.62(b)(2)(vii)
40CFRPart270.66(c)(8)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. PageD-5.41.
Explanation: The TBP must present procedures for rapidly stopping waste feed, shutting down
the combustion unit, and controlling emissions in the event of equipment
malfunction or failure. During normal operation, the combustion unit has specific
limits that must not be exceeded. If they are, the permit requires an AWFCO be
activated, and all waste feeds are instantaneously stopped. However,
combustion air, auxiliary fuel flow, and other combustion unit operations continue
(for example, kiln rotation), as does the operation of the APCS.
All facilities should have shut-down procedures and a contingency plan for
equipment malfunctions that require shutdown of the entire operating system.
SOPs for these actions should be included with the TBP.
Check For: The TBP reviewer should check for the following information:
Q Shutdown procedures discussion
Q AWFCOs presentation as permit limits during waste feed activities
Q Emergency power supply
Q Anticipated shutdown frequency, and historical records of shutdown
frequency (if existing unit)
Example Situation: Lois reads the Shutdown Procedures section of the TBP as follows:
"After certification of compliance, if operating conditions exceed the limits that
will be established during the trial burn, waste feeds to the kiln will be
automatically cut off. Following a cutoff, while hazardous waste remains in the
kiln, operating condition requirements will include maintaining minimum
combustion chamber temperature, operating the APCS in accordance with permit
requirements, and continuous monitoring of all parameters for which permit limits
will be established. Waste will not be fed to the kiln until the unit is operating
within the conditions specified in the permit. In addition, hazardous waste feed to
the kiln will be discontinued in the event of a failure of the induction fan, any
failure of the instrumentation listed in Exhibit 3.1.6-1, see page 1-111, or any
failure of the data collection and logging systems that would invalidate the data
necessary to evaluate compliance with cutoff parameters. During the trial burn,
cutoff limits listed above will be modified or established."
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Example Action: This description does not address rapid procedures for complete shutdown of the
unit resulting from a malfunction that might trigger an AWFCO. Generally, if a
boiler or cement kiln burner nozzle is plugged, the facility will stop flow only to
that nozzle, replace the waste fuel with a secondary fossil fuel, and conduct the
necessary maintenance while the unit continues to operate. A rapid shutdown
might occur during a severe storm in which there is a power outage. The backup
power must come on within a set period of time, usually 1 minute or less, and
keep the kiln rotating and the induced-draft fan on. In this way, any solids or
unburned material in the kiln are exposed to the surrounding temperature. The
induced-draft fan keeps a negative pressure on the system and controls fugitive
emissions. Lois asks the facility to revise this section to include a contingency
plan for a malfunction that results in complete shutdown of the unit.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
EXHIBIT 3.1.6-1
MONITOR AND CONTROL DEVICE SPECIFICATIONS
Operating
Parameter
Combined Waste
Feed Rate
Aqueous Feed Rate
Solvent Feed Rate
Auxiliary Fuel
Flow Rate
Fume Flow Rate
Atomization
Steam Pressure
Liquid Waste
Feed Pressure
Auxiliary Fuel
Pressure
Boiler Steam
Pressure
Combustion
Chamber Pressure
Burner Flame
Combustion
Temperature
Stack Gas Flow Rate
Stack Gas CO
Stack Gas O2
Units Measured
gph
gph
gph
SCFM
SCFM
psig
psig
psig
psig
psig
uv
°F
SCFM
ppm
%
Monitor/
Controller Type
Flow Meter
Pump
Pump
Control Valve
Flow Meter
Gauge
Gauge
Gauge
Gauge
Gauge
Sensor
Thermocouple
Meter
Probe
Probe
Manufacturer
Micromotion
Burks Pumps
Viking
Barber Colman
Annubar
Ashcroft
Ashcroft
Ashcroft
Ashcroft
Ashcroft
Honeywell
Honeywell
Annubar
Anarad
Teledyne
Model #'
RFT9712
737CTIME-55
LQ4125
_
ANR-75
N/A
N/A
N/A
N/A
N/A
C7035A
UDC300
ANR-75
AR-50-SM
9600
Calibration
Frequency
Monthly2
Monthly2
Monthly2
N/A
Quarterly
Inspected Daily,
Replaced quarterly3
Inspected Daily,
Replaced Quarterly3
Inspected Daily,
Replaced Quarterly3
Inspected Daily,
Replaced Quarterly3
Inspected Daily,
Replaced Quarterly3
N/A
Monthly2
Quarterly
Daily
Yearly Spec
Monthly
Yearly Spec
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Notes:
N/A = Not Available
1 = Or equivalent
2 = It is recommended, based on operating and manufacturer specifications, that this calibration frequency be
updated to quarterly
3 = It is recommended that gauges be replaced on a semi-annual basis
% = percent
CO = Carbon monoxide
°F = Degrees Fahrenheit
gph = Gallons per hour
SCFM = Standard cubic feet per minute
O2 = Oxygen
psig = Pounds per square inch gauge
ppm = Parts per million
uv = Ultraviolet
3.1.7 Reviewing Section D-5b(l)(g)—Combustion Unit Performance
Regulations: 40 CFR Part 266.102 and 103
40CFRPart270.62(a)
40 CRF Part 270.66(b)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.42.
Explanation: This section should state performance objectives of startup, shakedown, pretest,
and trial burn testing, as well as post-trial burn test activities. This section should
also include a detailed discussion of combustion activities, schedule, and changes
of combustion unit performance over the duration of the cleaning schedule.
Check For: The TBP reviewer should check for the following information:
Q Startup performance objectives
Q Demonstration of mechanical operation
Q Readiness of the combustion system to achieve optimum
operational capacity for a sustained period
Q Shakedown performance objectives
Q Adjusting and fine-tuning of combustion conditions, including
burner controls systems
Q Adjusting feed and APCS
Q Verification of CEMS operations
Q Pretest performance objectives. Pretest is a dry run that is conducted
for the trial burn at new combustion units but is not required by
regulations.
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Example Situation:
Q Confirmation of selected sampling and analytical methods
Q Operation of the system under full trial burn conditions
Q Demonstration of capabilities of the complete system and
individual components
Q Finalization of target operating conditions for the trial burn
Q Combustion unit performance characteristics over time
Q Cleaning schedule
Q Cleaning activities
Q Changes in performance
Lois and Clark read the Combustion Unit Performance section of the TBP as
follows:
"During the incinerator startup, all systems and subsystems will be tested under
"cold" conditions to determine integrity and operation. Electrical circuits will be
checked for continuity and response to signals from controllers, and control room
controller commands will be checked in the field for operational readiness.
Nonhazardous fuels will be used for hot startup to determine design capacity for
firing rates, air movement, and scrubber performance.
"During the incinerator shakedown phase, hazardous waste will be introduced
into the incinerator to (1) determine the combustion control system of the
operation, (2) develop fan curves, (3) conduct quench and scrubber water flow
rate requirements, (4) calibrate all CEMS, and (5) assess noise from the
incinerator. To determine readiness, personnel will operate the incinerator at or
near conditions planned for the trial burn.
"During the pretest, the incinerator will run one test under each planned trial burn
test condition to confirm that sampling and analytical methods are correct and to
make any necessary adjustments. During the pretest phase, the incinerator is
operated under conditions planned in the TBP and needed for the permit."
Lois notes that this section does not provide startup operations in a sequential
order; it is unclear whether operational readiness during the startup phase will be
determined from the waste feed end or the flue emissions stack. In addition,
Clark realizes that the section does not provide adequate discussion on
procedures to be used in determining incinerator design capacity. Lois and Clark
ask that the facility revise this section to include the criteria by which operational
readiness would be determined and that they provide a more detailed discussion
of incinerator design capacity.
Example Action:
Notes:
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3.2 REVIEWING SECTION D-5b(2) - NEW COMBUSTION UNIT CONDITIONS
Regulations:
Guidance:
Explanation:
Check For:
40CFRPart270.62(a)
40CFRPart270.66(b)
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science-
Engineering. Pages D-5.43.
The TBP for new combustion units covers four phases of operation:
• Phase one - startup testing
• Phase two - shakedown testing
• Phase three - trial burn testing
• Phase four - post-trial burn operation
Subsections 3.2.1 through 3.2.3 explain the goals of phases one, two, and four
and the type of information the permit writer should review. The determinations
drawn from the phases should be well supported.
The TBP reviewer should check for the following information:
Q A startup plan is a recommended attachment to the TBP
Q The shakedown test should be comprehensive and detailed
Q The proposed post-trial burn operating conditions should be justified
Example Situation: See Subsections 3.2.1 through 3.2.3 for specific example situations.
Example Action: See Subsections 3.2.1 through 3.2.3 for specific example actions.
Notes:
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3.2.1 Reviewing Section D-5b(2)(a) and (b)—New Combustion Unit Startup/Shakedown
Performance
Regulations:
Guidance:
Explanation:
Check For:
40 CFR Part 264.343
40 CFR Part 266.102(b)(4)(I)
40 CFR Part 270.62(b)(2)(vii)
40CFRPart270.66(b)(l)
U.S. EPA. 1989. "Handbook — Guidance on Setting Permit Conditions and
Reporting Trial Burn Results." ORD. EPA/625/6-89/019. January. Chapter 2.
U.S. EPA. 1992. "Technical Implementation Document for EPA' s Boiler and
Industrial Furnace Regulations (BIF)." OSWER. EPA-530-R-92-011. March.
Pages 10-8 and 10-9.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science and
Engineering. Pages D.5-44 and D.5-45.
U.S. EPA. 1998. "Protocol for Human Health Risk Assessment at Hazardous
Waste Combustion Facilities." EPA-R6-098-002. Section 2.5.
This section is usually required as part of the RCRA Part B permit application,
however, inclusion of this section in the TBP is recommended. The pretrial burn
or start-up and shakedown period establishes conditions for the purpose of
determining operational readiness following completion of construction. Permits
generally do not allow firing of hazardous wastes during the startup phase;
natural gas or other fossil fuels are burned to achieve full operating conditions,
such as desired temperature. However, permits may allow limited burning of
hazardous wastes during the shakedown phase to help stabilize the new
combustion unit and to prepare the unit for the trial burn. This pretrial burn phase
may last up to 720 operating hours and may be extended for an additional 720
operating hours when burning regulated hazardous waste. See Component
7 — How to Prepare Permit Conditions for additional discussion on these issues.
The TBP reviewer should check for the following information:
Q Fuel fired during startup phase (should be nonhazardous fuel)
Q Wastes to be burned during shakedown phase (can be hazardous or
nonhazardous)
Q Notification of the introduction of hazardous wastes in the combustion
unit (the facility should specify how much in advance the notification
would be provided to U.S. EPA or state agency)
Q Time required to achieve operational readiness after introduction of
hazardous wastes or initiation of shakedown phase
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Example Situation:
Q Operating conditions and their limits during start-up/shakedown phase
Q Group A parameters
Q Group B parameters
Q Group C parameters
Q Basis for establishing operating conditions
Q Information regarding proposed or anticipated emission rates during
startup, including a demonstration that these emission rates will be
protective of human health and the environment
Q Whether the AWFCO system will be operational during the shakedown
phase or the combustion of hazardous wastes
Clark reads the New Combustion Unit Startup/Shakedown Performance
section of the TBP as follows:
"The facility plans to test all incinerator operating components following a "cold"
test regiment that incorporates manufacturers' recommendations for (1) all
conveyors, rams, and blowers; (2) kiln rotation motors; (3) ash removal
mechanisms; (4) scrubber water and pH controls; (5) CEMS; and (6) the
induced-draft fan.
"Following successful operation of the system during cold testing, the facility will
combust either natural gas or fuel oil (virgin fuel or a synthetic blend may be
used) in the incinerator to cure the refractory, in accordance with manufacturers'
recommendations for time and temperature.
"After the refractory has been properly cured, the facility will introduce a 50/50
blend of ethylene glycol and isopropyl alcohol to each of the liquid injection
nozzles to test "hof'operations of the liquid injection system. Each nozzle will be
tested at design specifications.
"Following a successful demonstration of the liquid injection system, the facility
will introduce sand and excavated clean dirt to the solids feed chute and the
containerized solids feed conveyor. This test will be conducted while the
incinerator is firing either virgin fuel or the synthetic blend. A solids residence
time will be measured at various kiln rotation speeds and will be incorporated into
the operations log for future reference. This test is designed to ensure that all
safety mechanisms are functioning and that the system can properly feed solids
to the kiln without generating fugitive emissions.
"Following shakedown tests, a liquid synthetic blend of calcium chloride will be
added to produce ash content for scrubber removal efficiency testing. Scrubber
performance will be measured by stack sampling for PM using proposed
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Example Action:
maximum achievable control technology (MACT) standards for the target
emission limit.
"During testing activities of incinerator operations using hazardous waste feed,
the CEMS will be operating with CO being monitored on a 1-hour rolling average
basis. If the CO level exceeds the 100 ppm by volume rolling average, hazardous
waste feed will be shut off, and an engineering analysis will be conducted to
determine why combustion was producing high CO levels.
"Regulated hazardous waste feed will be introduced only when all system
components are performing up to design specifications and emissions are within
permitted limits. The clock will then start on the permitted 720 hours of pretrial
burn activity, which will be conducted by using wastes instead of synthetic
material. After these operations are concluded, the facility will inform the U.S.
EPA and state regulatory officials that it intends to perform the RCRA trial burn,
giving at least 14 days notice."
After reviewing this section of the TBP, Clark determines that this discussion is
unclear, incomplete, or inadequate in several ways. This section does not clearly
state whether startup and shakedown operations will establish conditions
necessary to determine operational readiness of the incinerator, nor does it
clearly indicate where startup ends and shakedown begins. Clark asks that the
facility clarify these issues.
No discussion exists concerning the operability of the AWFCO system during
startup and shakedown operations. The AWFCO system should be in operation
at all times during the combustion of hazardous wastes. Clark asks that the
facility revise this section to include a discussion on the AWFCO system and
conditions that would trigger the system.
This section also does not indicate whether regulatory agencies will be notified of
the introduction of hazardous waste into the incinerator during the pretrial burn or
shakedown phases. The facility should give at least a 2-week notice to
regulatory agencies concerning introduction of hazardous wastes. Clark asks
that the facility revise this section to discuss such notification.
Notes:
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3.2.2 Reviewing Section D-5b(2)(c)—New Combustion Unit Post-Trial Burn Operation
Regulations: 40 CFR Part 266.102(d)(iii)
40CFRPart270.62(c)
40CFRPart270.66(b)(3)
Guidance:
Explanation:
Check For:
Example Situation:
Example Action:
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.46.
This section should discuss whether and how the combustion unit will operate
during the interim periods—between completion of the trial burn and receipt of
final approval from U.S. EPA and the state agency. The combustion system
should operate within requested final permit limits and in compliance with all
federal requirements. See Component 7—How to Prepare Permit Conditions for
additional discussion on this issue.
The TBP reviewer should check for the following information:
Q Operating procedures during the interim period (facility should clearly
state federal requirements with which it will comply—such as 40 CFR
Parts 264, 266, and 270—and summarize the requirements)
Q How interim operating conditions will be documented
Q How AWFCO system integrity will be tested during interim operations
Q Checking signal path between the monitoring point and the
control system
Q Checking during calibration of combustion system monitors
Q Adjusting the trip point for each event that triggers AWFCO
system
In reviewing the New Incinerator Post-Trial Burn Operation section of the
TBP, Lois reads as follows:
"During the post-trial burn period, the facility will continue incinerating hazardous
wastes at operating conditions similar to those followed during the trial burn.
Because a Class I POHC was used during the trial burn, the facility believes that
it can accept and successfully destroy any organic compound on the new U.S.
EPA incinerability index. The facility will not accept or burn any dioxin or PCB
wastes. All waste feed shutoffs and interlocks that were in effect during the trial
burn will be in effect during the post-trial burn period for safety and
environmental protection."
Lois is dissatisfied with this section because it does not provide adequate
information pertaining to post-trial burn operations. It fails to discuss state and
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
federal requirements with which it would comply, procedures for documenting
operating conditions, and measures to check the integrity of the AWFCO system
during post-trial burn operations. Lois asks that the facility revise this section to
include this information.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
3.2.3 Reviewing Section D-5b(2)(d)—Combustion Unit Performances
Regulations: 40 CFRPart 270.62(a)
40CFRPart270.66(a)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.47.
Explanation: This section should summarize the rationale for the operating conditions proposed
for the startup, shakedown, and post-trial burn periods. Please see Section 3.1.7
of this component and Component —How to Prepare Permit Conditions for
further guidance.
Check For: See Section 3.1.7 of this component for specific "check for" items.
Example Situation: See Section 3.1.7 of this component for specific example situations.
Example Action: See Section 3.1.7 of this component for specific example actions.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
4.0
REVIEWING SECTION D-5c—TRIAL BURN SUBSTITUTE SUBMISSIONS
Regulations:
Guidance:
Explanation:
Check For:
40CFRPart270.19(c)
40CFRPart270.66(a)(6)
U.S. EPA. 1983. "Guidance Manual for Hazardous Waste Incinerator
Permits." OSWER. July. Section 3.1, Pages 3-1 through 3-4.
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Page D-5.48.
Facilities can submit performance data from a separate but similar combustion
unit in lieu of conducting a trial burn on each similar unit. U.S. EPA 1983
Guidance Manual for Hazardous Waste Incineration Permits provides criteria for
determining similarity of combustion unit and waste. Substitute data should
contain all data that was required as part of the TBP. Substitute data should also
include a comparison of the wastes, design, and operating conditions for the unit
to be used with that for which comparative burn data are available. Trial burn
substitute submissions are usually encountered for multiple similar units located at
the same facility (for example, multiple boilers).
The TBP reviewer should check for the following information:
Q Analysis of each waste or waste mixture (see Section 3.1 through 3.1.7
for list of items to be checked in reviewing this information)
Q Detailed engineering description (see Section 3.1 through 3.1.7 for list of
items to be checked in reviewing this information)
Q Description and analysis of wastes to be burned compared with the
waste for which data from operational or trial burns are provided to
support the position that a trial burn is not needed
Q Design and operating conditions of the combustion unit to be used,
compared with that for which comparative burn data are available
Q Description of the results submitted from previously conducted trial
burns, including sampling and analysis techniques and methods, and
results of operating parameters monitoring
Q Expected combustion unit operation information to demonstrate
compliance with 40 CFR Parts 264.243 and 264.345
Example Sections: Clark reviews the following section:
"The proposed combustion unit 12 will be identical in design, construction, and
operation to the permitted combustion unit II. Both the combustion units receive
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
waste from a common holding tank. The proposed combustion unit will be used
to burn wastes when there is an excess capacity of wastes.
"The facility has completed a trial burn for the existing combustion unit and
subsequently obtained a hazardous waste permit. The facility intends to operate
the proposed combustion unit at the permitted conditions for existing combustion
unit."
Example Comments: Clark determines the preliminary information provided in the section is adequate;
however, he requests that the facility provide detailed information regarding the
existing combustion unit's design and specifications. He also requests that the
facility provide a professional engineer's certificate that the units will be identical.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
5.0
REVIEWING SECTION D-5d—DETERMINATIONS
Regulations: 40 CFR Part 270.62(b)(6) through 270.62(b)(10)
40 CFR Parts 270.66(f)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.48 through D-5.57.
Explanation: Reporting requirements include a blend of facility operation, sampling and
analysis, and performance results. U.S. EPA policy also requires specific
results. Permit conditions for a hazardous waste incinerator should assure that
the unit always meets performance standards. This information should be
presented in the TBP to ensure that all of the data needed to support these
conclusions will be collected during the proposed test.
Details regarding the information contained in this section are explained in
Subsections 5.1, trial burn results, and 5.2, final operating limits.
The facility owner and operator are ultimately responsible for assuring that the
TBR provides data which support permit conditions that are acceptable to the
facility.
Check For: The TBP reviewer should check for the following information:
Q A description of how trial burn results will be presented
Q A description of proposed final operating limits to be determined
Q A description of how final operating limits will be determined based on
results of the trial burn test
Q A discussion of how the trial burn plan and trial burn test compare
Q A presentation of anticipated permit conditions based on trial burn test
results
Q Differences encountered during testing that varied from the plan
Q Failures encountered during testing
Q Presentation of test results with example calculations
Q Supporting documentation for certification and laboratory QA/QC
Q Obvious differences in numerical presentations
Example Situation: Clark reviews the following results outline for the TBR:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Example Action:
• Test method summary
• Waste feed results
• Particulate results
HC1 results
DRE results
• Dioxins, furans, and semivolatile results
The operational conditions for the three boilers tested are divided into Group A,
B, and C parameters per U.S. EPA guidance. Group A parameters are
continuously monitored and interlocked with the AWFCO system. Group B
parameters are established during the trial burn, but do not require continuous
monitoring and are not interlocked with the AWFCO system. Operating records
will be maintained by the company. Group C parameters are established based
on manufacturer specifications and are independent of the data collected during
the trial burn.
Group A Parameters
• Minimum combustion temperature
• Maximum induced draft fan flame
• Maximum liquid feed rate
• Maximum CO hourly rolling average
Group B Parameters
• Maximum ash feed rate
• Maximum chloride feed rate
Group C Parameters
• Minimum steam atomization pressure waste feed nozzle
Lois and Clark attempted to verify if everything proposed in the TBP and the
information needed to develop permit conditions will be included in the final
report. However, this brief outline does not provide a detailed description of
what type of data will be presented for each of the items identified. This section
should include examples of the tables to be used to present the data, as well as a
detailed description (or even a preliminary draft) of the text that will be used to
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
support proposed operating limits. This section should also identify appendices
that will be included with the TBR to support the information presented in this
section. Clark asks the facility to revise this section based on the deficiencies
noted.
Although listed as a Group A parameter, minimum combustion temperature was
not shown on the permit conditions for two of the three boilers. This is contrary
to controlling the operating envelope by establishing a minimum operating
temperature demonstrated during the trial burn where the required 99.99 percent
DRE was met.
In the TBP, the Group B feed rate parameters have a reported stack gas flow
rate of 2.054 in a summary table, but in the feed rate calculation, the rate is
expressed as 2,054 dry standard cubic feet per minute (dscfrn). The TBP should
be revised accordingly.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
5.1 REVIEWING SECTION D-5d(l)—TRIAL BURN RESULTS
Regulations:
Guidance:
Explanation:
Check For:
40CFRPart270.62(b)(6)
40 CFR Parts 270.66(d)(3), (4), and (5)
U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.48 through D-5.50.
After the trial burn has been completed, trial burn results will be submitted in a
format that is acceptable to U.S. EPA based on the format in the approved TBP.
Unless other arrangements are made, the report is due within 90 days after
completion of the trial burn. The TBR will be certified in accordance with the
requirements of 40 CFR Parts 270.62(b)(7) through 270.62(b)(9). See
Component 6—How to Review a Trial Burn Report for further guidance on
reviewing Trial Burn Reports.
Each TBP should propose a TBR section on the trial burn results that
presents the following information:
Q Quantitative analysis of combustion gas concentrations of POHCs,
metals, HC1, particulate, PCDD/PCDFs, PICs, O2, CO, and CO2
including the following:
Q Actual trial burn COPC emission rate values (including complete
detection limit values for nondetected compounds) in grams per
second
Q Adjusted COPC emission rate values (for the risk assessment, if
any) in grams per second
Q Justification and description of any proposed emission rate
adjustments for risk assessment purposes
Q Quantitative analysis of any scrubber water, ash residues, or other
residues (for use in estimating the POHC rate)
Q Computation of HC1 removal efficiency (if HC1 emission rate exceeds
4 Ib/hr)
Q Computation of particulate, HC1 and C12, metals, PIC, and PCDD/PCDF
emissions
Q Identification of fugitive emissions and their means of control
Q Maximum, minimum, average, and standard deviation of combustion
chamber temperatures
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q Maximum, minimum, average, and standard deviation of APCS operating
conditions
Q Maximum, minimum, average, and standard deviation of combustion gas
velocity
Q Continuous monitoring results of CO concentration in combustion gas
Q Other information specified in the TBP
Example Situation: Lois and Clark reviewed the following outline for the proposed TBR.
• Test Method Summary
• Waste Feed Results
• Participate Results
HC1 Results
DRE Results
• Dioxins, Furan, and Semivolatile Results"
All boilers achieved compliance with the standards specified in 40 CFR
Part 266.102 and the appropriate state regulations. A summary of the DRE,
particulate, and HC1 emissions are shown below for each boiler:
Standard
Particulate
HC1
DRE
Boiler 1
0.0057 gr/dscf
0.00024 Ib/hr
> 99.99 percent
Boiler 2
0.006 gr/dscf
0.002 Ib/hr
> 99.99 percent
Boiler 3
0.0010 gr/dscf
0.006 Ib/hr
>99.99 percent
Regulatory
Limit
0.08 gr/dscf
4 Ib/hr
99.99 percent
Due to the very low chloride content, there was no sampling and analysis for
PCDD/PCDFs. No boiler had a scrubber so all scrubber testing was waived.
Due to the low ash content, no particle size distribution (PSD) testing was
required. Parameters that were measured during the trial burn include:
• Combustion chamber temperature, for only 1 boiler
• Minimum residence time
• Burner and atomized settings
Example Comments: Lois determined that this outline is inadequate. The report should contain a
detailed description regarding all of the applicable information listed above. The
facility must also discuss how each of these items will be presented and how data
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
in the tables will be supported using appendices and example calculations. Lois
asks the facility to revise this section based on her comments.
Notes:
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
5.2 REVIEWING SECTION D-5d(2)—FINAL OPERATING LIMITS
Regulations: 40 CFR Part 270.62(b)(10)
40 CFR Part 270.66(f)
Guidance: U.S. EPA. 1997. "Generic Trial Burn Plan." Center for Combustion Science
and Engineering. Pages D-5.50 through D-5.58.
Explanation: If the DRE, metals, PM, HC1, PICs, and stack gas CO performance objectives,
(as described in the TBP) are achieved during the trial burn, the combustion unit
operating permit should allow the facility to use the combustion system to
incinerate RCRA hazardous solid and liquid wastes at rates and conditions
demonstrated in the trial burn. See Component 7—How to Prepare Permit
Conditions for further guidance on setting permit limits.
Check For: The TBP reviewer should check for the following information:
Q Group A parameters are continuously monitored and interlocked with the
AWFCO. Interruption of waste feed is automatic when specified limits
are exceeded. These parameters are applicable to all facilities.
Q Minimum temperatures measured at each combustion chamber exit
Q Maximum CO emissions measured at the stack or other appropriate
location
Q Maximum flue gas flow rate or velocity measured at the stack or
other appropriate location
Q Maximum pressure in PCC and SCC
Q Maximum feed rate of each waste type to each combustion
chamber
These parameters are specific to each facility based on the type of APCS
present.
Q Minimum differential pressure across particulate venturi scrubber
Q Minimum liquid-to-gas ratio and pH to wet scrubber
Q Minimum caustic feed to dry scrubber
Q Minimum kVA settings to ESP (wet/dry) and kVA for IWS
Q Minimum pressure differential across baghouse
Q Minimum liquid flow rate for IWS
Q APCS inlet gas temperature
Q Group B parameters do not require continuous monitoring and are thus
not interlocked with the waste feed cutoff systems. Operating records
are required to ensure that trial burn worst-case conditions are not
exceeded.
Q POHC incinerability limits
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
Q Maximum total halides and ash feed rate to the combustion unit
Q Maximum size of batches on containerized waste
Q Minimum particulate scrubber blowdown or total solids content
of the scrubber liquid
Q Group C parameters are set independently of trial burn test conditions.
Limits are based on equipment manufacturer's design and operating
specifications and are considered good operating practices. Parameters
do not require continuous monitoring and are not interlocked with the
AWFCO.
Q Minimum/maximum nozzle pressure to scrubber
Q Maximum total heat input capacity for each chamber
Q Liquid injection chamber burner settings:
Q Maximum viscosity of pumped wastes
Q Maximum burner turndown
Q Minimum atomization fluid pressure
Q Minimum waste heating value only if waste provides 100
percent heat input to chamber
Q Title 40 CFR Part 266.102 parameters are in addition to Group A, B, and
C parameters and apply to BIFs that use hazardous waste as a fuel
Q Minimum and maximum device production rate
Q Alternate CO standard and maximum THC limit
Q Sampling and analysis of metals in the hazardous waste and
other fuels with feed rate limits
Q Title 40 CFR Part 266.103(c) requires the owner operator to document
compliance with emissions standards that control production rate,
minimum waste Btu content, metals feed rate, chlorine feed rate, PM
emissions and, if applicable, facility risk assessments for pollutant
dispersion from the stack.
Example Situation: Lois and Clark reviewed the following summary of permit conditions:
"The trial burn is structured to obtain the data necessary to establish permit
conditions. We propose that the following conditions be established in the permit,
based on the successful demonstration of unit performance during the trial burn.
These limits apply to Unit 1 while hazardous waste is burned. Unit 2 will
continue to operate under its interim status conditions until its APCS is replaced
with a baghouse. The conditions are:
• Maximum total hazardous waste feed rate (measured during
Condition 1 of the trial burn, expected to be 5.9E06 grams per
hour [g/hr]).
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
• Maximum pumpable hazardous waste feed rate (measured
during Condition 1 of the trial burn, expected to be 5.9E06 g/hr).
• Maximum BIF metals feed rates equal to the levels measured
during Condition 1 of the trial burn for the Tier III metals
(arsenic, beryllium, cadmium, chromium, and lead) and equal to
the adjusted Tier I limits for antimony, barium, mercury, silver,
and thallium.
• Maximum total chlorine feed rate (measured during Condition 1
of the trial burn)
• Maximum combustion zone temperature (measured during
Condition 1 of the trial burn by an optical pyrometer)
• Minimum combustion zone temperature (measured during
Condition 2 of the trial burn by an optical pyrometer)
• Maximum secondary air temperature (measured during
Condition 1 of the trial burn as a measure of maximum
combustion zone temperature in the event of a pyrometer failure)
• Maximum baghouse inlet temperature (measured during
Condition 1 of the trial burn)
• Minimum baghouse pressure drop (measured during Condition 1
of the trial burn)
• Maximum flue gas flow rate (measured during Condition 1 of the
trial burn)
"The results of the boiler tests show the following anticipated operating limits:
• Minimum combustion chamber temperature—2,000°F in the
oxidizer and 1,600°F in the reoxidizer
• Maximum induced draft fan flow—3,608 standard cubic feet per
minute to produce the minimum residence time
• Maximum liquid waste feed rate—1,206 pounds per hour (Ib/hr)
• Carbon monoxide)—<100 ppmv hourly rolling average
Ash feed rate—0.71 Ib/hr
Chloride feed rate—3.89 Ib/hr
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COMPONENT 1—HOW TO REVIEW A TRIAL BURN PLAN
• Minimum steam atomization pressure for the waste feed
nozzle—85 psig"
Example Action: In accordance with U.S. EPA guidance, Lois and Clark suggest that the facility
summarize proposed operating conditions in a table (final operating conditions are
typically summarized in table format) and that the facility break down specific
process parameters as follows:
• Group A—Continuously monitored parameters that are connected to an
AWFCO system
• Group B—Parameters cannot be continuously monitored with
compliance based on operating records
• Group C—Parameters with limits that are set independently of the trial
burn
They also request that the facility provide detailed supporting calculations
indicating how each of the proposed values was determined. Because there is no
scrubber on the boiler, there are no scrubber related permit conditions. The
metals were analyzed in the waste and the results indicated the facility could
meet the Tier I metals limits.
Notes:
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ATTACHMENT A
U.S. EPA REGION 6 GENERIC TRIAL BURN PLAN
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The U.S. EPA Region 6 Generic Trial Burn Quality Assurance Project Plan is located in Attachment
A of Component 2 of the Hazardous Waste Combustion Unit Permitting Manual.
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CONTENTS
Section Page
ACRONYMS AND ABBREVIATIONS v
EXECUTIVE SUMMARY ES-1
INTRODUCTION 1-1
TRIAL BURN PLAN ORGANIZATION 1-1
WASTE TREATMENT SYSTEM PROCESS AND FEED DESCRIPTIONS 1-2
Waste Blending and Storage 1-3
Combustion Process 1-3
Heat Recovery System 1-4
Air Pollution Control System 1-4
Ash Handling System 1-5
Slowdown Treatment 1-5
WASTES TO BE TREATED 1-5
TRIAL BURN OBJECTIVES 1-6
TRIAL BURN APPROACH 1-8
PROPOSED TRIAL BURN PROGRAM 1-8
Test 1—High-Temperature Metals Burn 1-9
Test 2—Low-Temperature DRE Burn 1-10
Test 3—Risk Burn 1-10
TRIAL BURN SAMPLING AND ANALYTICAL PROTOCOLS I-11
FINAL PERMIT LIMITS 1-12
D-5 INCINERATORS D-5.1
D-5a JUSTIFICATION FOR EXEMPTION D-5.1
D-5b TRIAL BURN D-5.1
D-5b(l) TRIAL BURN PLAN D-5.1
D-5b(l)(a) Detailed Engineering Description of the Incinerator .... D-5.1
D-5b(l)(b) Sampling and Monitoring Procedures D-5.24
D-5b(l)(c) Trial Burn Schedule D-5.34
D-5b(l)(d) Test Protocols D-5.35
D-5b(l)(e) Pollution Control Equipment Operation D-5.41
D-5b(l)(f) Shutdown Procedures D-5.41
D-5b(l)(g) Incinerator Performance D-5.42
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CONTENTS (Continued)
Section Page
D-5b(2) NEW INCINERATOR CONDITIONS D-5.43
D-5b(2)(a) Startup D-5.44
D-5b(2)(b) Shakedown D-5.45
D-5b(2)(c) New Incinerator Post-Trial Burn Operation D-5.46
D-5b(2)(d) Incinerator Performance D-5.47
D-5c TRIAL BURN SUBSTITUTE SUBMISSIONS D-5.48
D-5d DETERMINATIONS D-5.48
D-5d(l) TRIAL BURN RESULTS D-5.48
D-5d(2) FINAL OPERATING LIMITS D-5.50
D-5d(2)(a) Group A Parameters D-5.51
D-5d(2)(b) Group B Parameters D-5.54
D-5d(2)(c) Group C Parameters D-5.57
REFERENCES D-5.59
FIGURES (ATTACHMENT A)
Figure Page
D-5.1 SITE PLAN A-l
D-5.2 WASTE TREATMENT SYSTEM FLOW DIAGRAM A-2
D-5.3 ROTARY KILN INCINERATOR SYSTEM BLOCK FLOW DIAGRAM A-3
D-5.4 COMBUSTION PROCESS FLOW DIAGRAM WITH SAMPLING LOCATIONS A-4
D-5.5 METHOD 0060 MULTI-METALS SAMPLING TRAIN A-5
D-5.6 METHOD 0061 HEXAVALENT CHROMIUM SAMPLING TRAIN A-6
D-5.7 METHOD 0050 HYDROGEN CHLORIDE, CHLORINE, AND PARTICULATE
MATTER SAMPLING TRAIN A-7
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FIGURES (ATTACHMENT A) (Continued)
Figure Page
D-5.8 METHOD 0031 VOLATILE ORGANIC SAMPLING TRAIN A-8
D-5.9 METHOD 0040 TEDLAR BAG ORGANIC SAMPLING TRAIN A-9
D-5.10 MODIFIED METHOD 5—SEMIVOLATILE PIC, PCDD AND PCDF, AND PAH
SAMPLING TRAIN A-10
D-5.11 METHOD 0011 ALDEHYDE AND KETONE SAMPLING TRAIN A-11
TABLES (ATTACHMENT B)
Table Page
D-5.1 INCINERATION SYSTEM WASTE ACCEPTANCE CRITERIA B-l
D-5.2 WASTE CHARACTERISTICS B-3
D-5.3 TARGET TRIAL BURN OPERATING CONDITIONS B-5
D-5.4 SUMMARY OF SAMPLING AND ANALYSIS PROGRAM B-7
D-5.5 ANTICIPATED INCINERATOR OPERATING LIMITS B-14
D-5.6 AUTOMATIC WASTE FEED CUTOFF SYSTEM SETTINGS STARTUP AND
SHAKEDOWN PERIOD B-19
D-5.7 DESIGN BASIS, MAJOR SYSTEMS B-21
D-5.8 INCINERATOR FEED SYSTEMS DESIGN INFORMATION B-23
D-5.9 AUTOMATIC WASTE FEED CUTOFF PARAMETERS, INSTRUMENTS, AND
SETTINGS B-24
D-5.10 CONSTRUCTION MATERIALS B-26
D-5.11 PROCESS MONITORING INSTRUMENTS B-27
D-5.12 PROCESS MONITORING INSTRUMENTS, CALIBRATION, AND PREVENTIVE
MAINTENANCE B-30
D-5.13 TRIAL BURN SCHEDULE B-32
iii
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D-5.14 POHC AND METAL SPIKING COMPOUNDS B-37
D-5.15 TRIAL BURN REPORT OUTLINE B-39
APPENDICES
Appendix
D-5.1 QUALITY ASSURANCE PROJECT PLAN
D-5.2 PROCESS FLOW DIAGRAMS, PIPING AND INSTRUMENTATION DIAGRAMS, AND
FACILITY LAYOUT
D-5.3 MANUFACTURERS' SPECIFICATIONS
D-5.4 WASTE FEED AND CHLORINE, METALS, AND POHC SPIKING INFORMATION
D-5.5 STARTUP PLAN
D-5.6 THERMAL RELIEF VENT OPERATION
D-5.7 SAMPLING STANDARD OPERATING PROCEDURES
D-5.8 POHC ORE SAMPLING TIME AND SPIKING CALCULATIONS
D-5.9 MAS S AND ENERGY BALANCE FOR TRIAL BURN
D-5.10 AIR DISPERSION MODELING REPORT
IV
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ACRONYMS AND ABBREVIATIONS
r|g/m3
acfm
APCS
API
ASME
AWFCO
BIF
Btu
CEM
CFC
cfm
CLP
DARS
DAS
DCS
DNPH
DQO
DRE
EPA
FDA
FID
FRP
GC
GCMS
gpm
gr/dscf
HHRA
hp
Micrograms per cubic meter
Nanograms per cubic meter
Actual cubic feet per minute
Air pollution control system
American Petroleum Institute
American Society of Mechanical Engineers
Automatic waste feed cut-off
Boiler or industrial furnace
British thermal unit
Continuous emission monitor
Certified-for-construction
Cubic feet per minute
Contract laboratory program
Data acquisition and recording system
Data acquisition system
Distributed control system
Dinitrophenylhydrazine
Data quality objectives
Destruction and removal efficiency
U.S. Environmental Protection Agency
Food and Drug Administration
Flame ionization detector
Fiberglass-reinforced plastic
Gas chromatograph
Gas chromatograph and mass spectrometry
Gallons per minute
Grains per dry standard cubic foot
Human health risk assessment
Horsepower
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ACRONYMS AND ABBREVIATIONS (Continued)
HWIGS
inwc
kVA
mL
MMT
N
NDIR
NFPA
NPDES
P&ID
PCB
PCDD
PCDF
PFD
PIC
PM
POHC
psig
QAPP
RCRA
SCC
T/R
TCL
TCLP
TCO
TDS
TEQ
TRY
Hazardous Waste Incineration Guidance Series
Inches water column
Kilovolt ampere
Milliliter
Multi-metals train
Normality
Nondispersive infrared
National Fire Protection Agency
National Pollutant Discharge Elimination System
Piping and instrumentation diagram
Poly chlorinated biphenyl
Poly chlorinated dibenzodioxin
Poly chlorinated dibenzofuran
Process flow diagrams
Product of incomplete combustion
Particulate matter
Principal organic hazardous constituent
Parts per million dry volume
Pounds per square inch per gallon
Quality assurance project plan
Resource Conservation and Recovery Act
Secondary combustion chamber
Transformer and rectifier
Target compound list
Toxicity characteristic leaching procedure
Total chromatographable organics
Total dissolved solids
Toxicity-equivalent quality
Thermal relief vent
VI
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ACRONYMS AND ABBREVIATIONS (Continued)
TSCA Toxic Substances Control Act
TSDF Treatment, storage, and disposal facility
TSS Total suspended solids
UPS Uninterruptible power supply
VOA Volatile organics analysis
VOST Volatile organic sampling train
WESP Wet electrostatic precipitator
WWTS Wastewater treatment system
vn
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Revision No.: 0
Revision Date: Month/Year
EXECUTIVE SUMMARY
This example trial burn plan is a guide for preparing the trial burn portion of a Resource Conservation and
Recovery Act (RCRA) permit application. This example trial burn plan is for a new incinerator train that
consists of a rotary kiln incinerator, a secondary combustion chamber (SCC), a boiler for energy
recovery, and a wet air pollution control system (APCS). The rotary kiln will be fired with solid wastes
and liquid wastes. Liquid wastes will be also fired in the SCC.
This example plan is intended to be generic from the standpoint that it can be modified to meet the
requirements of a particular system that differs in configuration or regulatory status from the example
rotary kiln incineration (such as an interim status boiler undergoing initial permitting or an existing
incinerator undergoing permit renewal). Specifically, portions of the plan that are not applicable may be
excluded, or the existing text may be modified to meet the unique requirements of a particular unit. For
example, a boiler using a liquid organic hazardous waste stream as fuel followed by a dry APCS (with a
spray dryer, partial quench, and baghouse), the sections relative to the rotary kiln can be excluded, the
sections on the SCC can be modified to reflect the combustion chamber portion of the boiler, the sections
on solid and sludge waste and aqueous waste can be excluded, and the APCS description can be modified
accordingly. The sampling and analytical protocols can be similarly modified to exclude or include
parameters specific to the performance objectives, the unit being tested, or the waste streams being
treated.
This example plan consolidates, into a single testing program, the traditional RCRA trial burn elements (for
example, two test conditions follow: (1) maximum metals feed rates at high temperature, and
(2) maximum organic waste feed rate at low temperature to demonstrate destruction and removal
efficiency [DRE]) with those for more contemporary risk burns performed under either worst-case or
normal operating conditions. This plan outlines a test program in which the risk burn is performed under
normal operating conditions. As such, it includes three test conditions: (1) high-temperature metals burn,
(2) low-temperature DRE burn, and (3) normal operating condition risk burn.
[NOTE TO USER: The risk burn may be performed under normal operating conditions only if the
facility burns wastes that have little temporal variation in chemical and physical properties, at
nearly constant rates, under operating conditions that do not fluctuate widely. Facilities that do
not meet these criteria, including most commercial hazardous waste combustion facilities and
captive facilities that burn highly variable wastes, must perform the risk burn under worst-case
conditions.}
This example plan contains generic language and, through the use of bracketed text, identifies necessary
user-specific text. Guidance is provided throughout this example trial burn plan to aid in making the
unit-specific modifications. This guidance appears in brackets and italics as [NOTE TO USER: ].
This example plan has been organized generally in accordance with the format recommended by the
U.S. Environmental Protection Agency (EPA) for a trial burn plan submitted with the RCRA Part B
permit application (EPA 1983). Some modifications to the format have been made to accommodate
newer permitting guidance. To facilitate the review of this example trial burn plan, independent of the
balance of the permit application, the format also includes a detailed introduction, which provides an
overview of the boiler or incinerator facility and the proposed trial burn program.
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INTRODUCTION
[NOTE TO USER: To orient the reviewer and thereby facilitate the overall review of the trial burn
plan, the inclusion of an introduction is recommended; it should be located at the beginning of the
trial burn plan. The introduction should provide for the reviewer a brief and condensed overview
of the entire plan and should include the following information:
• Facility identification
• Reasons for the trial burn plan submission (such as new application, permit
modification, or permit renewal)
• Organization of the trial burn plan
• General process description of the unit
• Description of the wastes to be treated in the unit
• Overview of the test program, including descriptions of metals, destruction and
removal efficiency (DRE), and risk burn test conditions
• Performance objectives to be demonstrated
• Sampling and analytical program to support demonstration of the performance
objectives
• Approach to establishing the final permit limits}
[Enter Company Name (Enter Company Acronym)} requests a Resource Conservation and Recovery
Act (RCRA) permit for the rotary kiln incineration system to be located at [Enter Facility Location}.
This trial burn plan is submitted as Section D-5 of the RCRA Part B permit application for a new rotary
kiln hazardous waste incineration system, hazardous waste storage tanks, and hazardous waste container
storage areas. This trial burn plan has been written following a format suggested in U.S. Environmental
Protection Agency (EPA) completeness checklists. EPA regulatory citations are given, as appropriate,
throughout the trial burn plan.
TRIAL BURN PLAN ORGANIZATION
This trial burn plan is a stand-alone document. The quality assurance project plan (QAPP) is provided in
Appendix D-5.1.
The balance of this introduction provides an overview of the trial burn plan, including, among other
information, the following:
• Process descriptions
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• Waste feed descriptions
• Trial burn objectives
• Trial burn approach
• Trial burn program
• Trial burn protocol
• Expected final permit conditions resulting from the trial burn
All figures and tables referenced in the text of this plan are presented in Attachments A and B,
respectively. Appendices follow the attachments. The first figure is Figure D-5.1; the first table is
Table D-5.1, and the first appendix is Appendix D-5.1.
Following the introduction, the trial burn plan adheres to the EPA-recommended format for trial burn
plans submitted as part of the RCRA Part B permit application.
[NOTE TO USER: The trial burn plan is suggested as a stand alone document because this portion
of the permit application typically undergoes at least one revision before it is finalized.}
WASTE TREATMENT SYSTEM PROCESS AND FEED DESCRIPTIONS
[REQUIREMENT: Provide a summary engineering description that encompasses the entire
treatment, storage, and disposal facility (TSDF), as follows: (1) waste blending and storage
operations, (2) combustion process, (3) heat recovery system, (4) APCS equipment, and
(5) combustion and air pollution control residues (such as ash or blowdown) treatment. In
describing these elements of the TSDF, indicate their design bases (such as codes, capacities,
temperatures, or pressures) and the normal ranges of operating conditions.}
[NOTE TO USER: The following process description is provided as an example only.}
The rotary kiln incinerator facility consists of five primary process areas: (1) waste blending and storage,
(2) incineration system, (3) heat recovery boiler, (4) APCS, and (5) ash handling system. The facility site
plan showing the locations of these areas is shown on Figure D-5.1.
This trial burn plan covers only the incineration, energy recovery, and APCSs. The descriptions of the
waste blending and storage and ash handling systems contained herein are provided only to facilitate an
understanding of their configuration relative to the balance of the waste treatment system. More details
on the waste storage and ash handling areas are provided in the permit application Sections D-l,
Containers, and D-2, Tank Systems.
The incineration process includes a rotary kiln with a secondary combustion chamber (SCC). The heat
recovery boiler is a radiant/convective unit. The APCS is a high-energy, venturi-type, scrubber system
with a wet electrostatic precipitator (WESP).
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The basic flow of materials through the TSDF is illustrated on Figure D-5.2. Descriptions of the discrete
TSDF components follow.
Waste Blending and Storage
All of the liquid hazardous wastes burned in the incinerator will be generated in on-site processes. These
liquids will be hard-piped from the generating processes to the hazardous waste tank farm. Storage of the
wastes will take place in four 50,000-gallon vertical stainless steel tanks that will be constructed to the
standards of American Society of Mechanical Engineers (ASME) Section VIII and American Petroleum
Institute (API) codes.
When each tank is filled, its inlet lines will be sealed by a valve, tagged, and locked. Samples of the liquid
will be collected and analyzed for conformance to the incinerator waste acceptance criteria (see
Table D-5.1). Once certified as acceptable for burning in the incinerator, the tank will be released to
incinerator operations for feeding to the kiln. Periodically, the contents of several tanks may be blended.
Refer to Section D-2 of the permit application for more details on the storage and blending of wastes in
the tanks.
Combustion Process
The kiln will be a Model No. [Enter Model Number] unit built by [Enter Manufacturer Name] in [Enter
Year]. The rotary kiln will be [Enter Dimension] feet long and [Enter Dimension] feet wide with a
slope of [Enter Slope] feet per feet and will be refractory lined. It will be rated for a maximum heat
release of [Enter Rating] million British thermal units (Btu) per hour and a solids processing rate of
[Enter Solids Capacity] tons per hour. A simplified block flow diagram of the rotary kiln combustion
process is provided on Figure D-5.3.
As shown on Figure D-5.4, the combustion fuels (waste liquids and natural gas) will be fed with
combustion air into the hot end of the kiln through the burner system. The fuel mixture will be burned,
producing flame temperatures between [Enter Low Temperature] and [Enter High Temperature] °F.
The induced draft fan will provide motive force to transport the combustion gas toward the cold end of the
kiln where it will exit at temperatures between [Enter Low Temperature] and [Enter High
Temperature] °F. The combustion gas flow rate typically will range from [Enter Low Flow Rate] to
[Enter High Flow Rate] actual cubic feet per minute (acfm).
Combustion gas exiting the rotary kiln will be treated thermally in the SCC. The SCC will provide high
temperature, residence time, and turbulent mixing for thermal destruction of any organic constituents that
may be present in the combustion gas from the rotary kiln. The SCC will be a vertical, cylindrical,
refractory-lined afterburner that will be fired with waste liquids and natural gas. It will be rated for a
maximum heat release of [Enter Heat Release Rating] million Btus per hour. Its design combustion gas
flow rate, operating temperature, and combustion gas residence time will be [Enter Flow Rate], [Enter
Temperature], and [Enter Residence Time], respectively. Under normal operations, combustion gas flow
rates will range from [Enter Low Flow] to [Enter High Flow] acfm; the SCC temperature will range
from [Enter Low Temperature] to [Enter High Temperature] °F; the combustion gas residence time in
the SCC will range from [Enter Low Residence Time] to [Enter High Residence Time].
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The solids will travel through the rotary kiln in the opposite direction (counter-current) from the
combustion gas flow. The solids will be conveyed into the rotary kiln through an enclosed auger-shredder
feed chute from the feed hopper. Under normal operations, the solids feed rate into the kiln ranges from
[Enter Low Feed Rate] to [Enter High Feed Rate]. The ash will gravity discharge to an enclosed rolloff
container. Ash production rates corresponding to the range of solids feed rates discussed above will vary
from [Enter Low Ash Rate] to [Enter High Ash Rate].
Heat Recovery System
Combustion gas exiting the SCC will pass through a waste heat recovery boiler. The waste heat recovery
boiler will be a Model No. [Enter Model Number] unit built by [Enter Manufacturer Name] in [Enter
Year]. The waste heat recovery boiler has approximate dimensions of [Enter Dimensions]. It will be
rated for [Enter Production Rate] pounds of steam per hour at a pressure of [Enter Pressure] pounds
per square inch, gauge (psig).
Under normal operating conditions, the waste heat recovery boiler will produce [Enter Production Rate]
pounds per hour of [Enter Pressure] psig steam. Combustion gases normally enter the unit at [Enter
Entrance Temperature] °F and exit at [Enter Exit Temperature] °F.
Air Pollution Control System
The APCS will be designed to remove acid gases, particulate matter, and metals from the combustion gas
prior to discharge to the atmosphere. The APCS has three major components: quench, high-energy
venturi scrubber, and WESP.
In the quench, the heat recovery boiler or SCC combustion gas will be cooled adiabatically by saturating
water sprays. The quench column will be an upflow design with a diameter of [Enter Diameter] and a
height of [Enter Height]. The column will be packed with [Enter Packing Material]. Under normal
operating conditions, a liquid to gas ratio of [Enter Number] gallons per minute (gpm) to [Enter Number]
cubic feet per minute (cfrn) will be maintained. The quench will be designed for a maximum inlet
temperature of [Enter Design Inlet Temperature] and a maximum outlet temperature [Enter Design
Outlet Temperature] °F. Typical gas inlet and exit temperatures will be [Enter Entrance Temperature]
and [Enter Exit Temperature] °F, respectively.
From the quench, saturated combustion gas will pass through the high-energy venturi scrubber where
high-pressure water sprays will create small droplets for efficient capture of small particulate. Under
normal operating conditions, a pressure drop of [Enter Pressure Drop] inches of water column will be
maintained across the venturi scrubber. The final portion of the high-energy venturi scrubber will be the
vane separator. The vane separator will contain multiple flat surface areas, or vanes, that will be rinsed
continuously with fresh water. The vanes provide a surface for water-droplet-entrained particulate to
collect.
Combustion gas exiting the vane separator will be ducted to the WESP, which will be used to remove
sub-micron particulate matter. Clean combustion gas from the WESP passes through the induced draft
fan. The combustion gas will then be vented to the atmosphere through the stack.
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An induced draft fan will be the combustion gas prime mover. The incineration system, boiler, and APCS
units will be interconnected and sealed (infiltration air-controlled) chambers. The induced draft fan will
maintain the combustion chambers and each unit of the APCS at less than atmospheric pressure to
facilitate the control of fugitive emissions. The high-pressure point in the system, the rotary kiln, will be
maintained typically at [Enter Vacuum Level} inches of water column vacuum.
[NOTE TO USER: In the case of boilers and thermal oxidizers (liquid waste incinerators), the
combustion zone and possibly the APCS may be operated with combustion chambers andAPCSs
greater than atmospheric (positive)pressure.]
Ash Handling System
The incinerator normally produces [Enter Production] pounds of ash per [Enter Time]. The typical ash
composition will be as follows: [Metal Oxide A at 12 Weight Percent], [Metal Oxide B at 10 Weight
Percent], and [Metal Oxide C at 8 Weight Percent]. The ash will be both a characteristic and a listed
hazardous waste that will be assigned EPA waste codes [Enter Waste Code], [Enter Waste Code], and
[Enter Waste Code].
The ash will be stabilized with Portland cement in the ash handling area prior to final disposal at an
off-site hazardous waste landfill. Refer to Sections D-l and D-2 of the permit application for more details
on the ash handling system.
Slowdown Treatment
The wet scrubber system typically will produce [Enter Production Rate] gpm of blowdown, which will
be treated in the on-site wastewater treatment system (WWTS) prior to discharge through the facility's
National Pollution Discharge Elimination System (NPDES) outfall. The blowdown normally will have a
pH of [Enter pH]. Total dissolved solids (TDS) and total suspended solids (TSS) will be [Enter TDS]
and [Enter TSS], respectively.
Section D-5b(l)(a) provides a more detailed engineering description of [Enter Company Acronym]?,
rotary kiln incineration system. Appendix D-5.2 contains the process flow diagrams (PFD) and piping and
instrumentation diagrams (P&ID). A general arrangement drawing for the rotary kiln incinerator system
process unit can also be found in Appendix D-5.2. Manufacturers' specifications for the rotary kiln
incinerator system components are included in Appendix D-5.3.
WASTES TO BE TREATED
[REQUIREMENT: Provide a general description of the waste to be treated by the combustion
system. Describe the processes that generate the waste and the quantities of the various wastes that
are burned each year. Specify the waste codes, main constituents, and constituent concentrations
of each waste. Detailed and complete waste characterization data must be presented (list of
chemical constituents and their concentrations, heat value, chlorine content, density, viscosity,
vapor pressure, percent solids, ash content, and other parameters). To justify the principal
organic hazardous constituents (POHC) selection, identify the Appendix VIII constituents of and
their nominal concentrations in the waste. The following waste description is provided as an
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example only. A general background on the wastes to be treated and their origin allows the permit
writer to understand the selection of the trial burn objectives that coincide with facility operational
requirements.]
[Enter Company Acronym] produces a variety of specialty chemicals used by numerous industries,
including pharmaceuticals and other health products. The wastes produced by [Enter Company
Acronym] include high-Btu organic solvents, like methanol, ethanol, and toluene; low-Btu aqueous
solutions containing low-level concentrations of solvents or products and filter media wetted with these
solvents and water; and contaminated packaging materials. These wastes, sludges from the facility
WWTS, and sludges removed during storage tank and process vessel cleaning operations will be burned in
the rotary kiln.
Most of [Enter Company Acronym]'s wastes will be RCRA-listed or characteristic wastes containing
constituents listed in 40 Code of Federal Regulation (CFR) 261 Appendix VIII. [Enter Company
Acronym] does not produce or handle any products containing poly chlorinated biphenyls (PCB) that
would be regulated under Toxic Substance Control Act (TSCA). [Enter Company Acronym] does not
generate any waste materials that are designated as F020, F021, F022, F023, F026, or F027 wastes (dioxin
waste codes).
The acceptance criteria for wastes to be burned in the incineration system are summarized in
Table D-5.1. [Enter Number of Waste Streams] different waste streams will be burned in the
incinerator. The wastes that will be burned in the incinerator will be generated in batches. The
composition of batches do not vary significantly. However, these wastes will be blended prior to burning
to produce three distinct waste feed streams: high-Btu liquids, low-Btu liquids, and solids. Descriptions,
including waste codes and annual quantities burned, of these waste streams are provided in Table D-5.2.
Refer to Section C, Waste Characteristics, of the permit application for additional information on the
"as-generated" wastes.
[Enter Company Acronym] has explored and continues to look for additional ways to recover and reuse
as much of its wastes as is practicable, especially the solvent wastes. The wastes intended to be burned
in the incinerator cannot be reused by [Enter Company Acronym], will not be marketable, or will not be
economically recoverable. [Enter Company Acronym] currently disposes of hazardous wastes at an
off-site commercial TSDF, at considerable cost. The proposed unit will provide [Enter Company
Acronym] with a more economically competitive method of disposal with the additional benefit of
providing supplemental steam for facility use.
[Enter Company Acronym] intends to process the feed streams described above as follows:
• The solid wastes will be burned in the rotary kiln.
• The high-Btu solvents will be atomized by steam through the dual fuel burners (natural
gas and waste liquids) and burned as fuels in the kiln and the SCC.
• The low-Btu liquid wastes will be atomized through waste nozzles by high-pressure air
into the rotary kiln and SCC.
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All combustion residues (such as ash and scrubber blowdown) will be handled as if they are derived from
RCRA wastes.
TRIAL BURN OBJECTIVES
[REQUIREMENT: Specify the trial burn objectives, including objectives dictated by 40 CFR 264,
266, and 761, as necessary, and those dictated by EPA (1998a and 1998b) for completing human
health and ecological risk assessments.]
[NOTE TO USER: The following list of trial burn objectives is provided as an example only and
reflects a very wide spectrum of requirements. The objectives for your trial burn may require
modification to address the state and EPA region-specific requirements, especially those related to
dispersion and deposition modeling and to human health and ecological risk assessments. ]
The objectives for the [Enter Company Acronym] trial burn are as follows:
• Demonstrate 99.99 percent DRE of the designated POHC chlorobenzene and carbon
tetrachloride.
• Demonstrate adequate control of fugitive emissions.
• Demonstrate control of carbon monoxide emissions to less than 100 parts per million dry
volume (ppmdv), corrected to 7 percent oxygen, on a 60-minute rolling average basis.
• Demonstrate control of particulate emissions to less than 0.08 grains per dry standard
cubic foot (gr/dscf) corrected to 7 percent oxygen.
• Measure the particle size of emitted particulate matter to facilitate site-specific air
dispersion modeling.
• Demonstrate maximum chlorine feed rate, and show that subsequent hydrogen chloride
and chlorine emissions total no greater than the larger of 4 pounds per hour or 1 percent
of their potential mass emissions prior to entering the APCS and that the resulting
emissions comply with 40 CFR 266 Tier III standards.
• Demonstrate that the emissions of the following metals are controlled to meet the 40 CFR
266 Tier III standards at their trial burn feed rates: arsenic, beryllium, cadmium, and
hexavalent chromium.
• Demonstrate that the feed rates of the following metals meet the 40 CFR 266 Adjusted
Tier I feed rate standards: antimony, barium, lead, mercury, selenium, silver, and thallium.
• Provide data regarding the emissions of metals, poly chlorinated dibenzodioxins and
poly chlorinated dibenzodifurans (PCDD and PCDF), and other products of incomplete
combustion (PIC) for use in performing site-specific human health and ecological risk
assessments.
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• Establish limitations on waste feed characteristics and process operating conditions in
order to ensure compliance with performance standards and risk-based emission limits.
[NOTE TO USER: The trial burn objectives for all units will include an assessment of DEE, carbon
monoxide, particulate, hydrogen chloride and chlorine, and metals to comply with the requirements
of 40 CFR 264 Subpart O and 40 CFR 266 Subpart H. Measurement of PIC emissions, including
PCDDs and PCDFs, will be required to conduct site-specific air dispersion modeling and human
health risk assessment (HHRA). Determination of particle-size distribution will be required to
conduct site-specific air dispersion modeling and to develop emission rates of contaminants of
potential concern. A preliminary site-specific dispersion model and an HHRA based on assumed
(or previously measured) stack parameters and emissions will be used to identify the potential
sampling and analytical requirements for hydrogen chloride and chlorine, metals, and PIC's.
Consult with your state regulatory agency and EPA regional office, and obtain approval of your
protocols before beginning any dispersion modeling or risk assessment work. ]
TRIAL BURN APPROACH
[REQUIREMENT: Specify which of the basic permitting approaches (such as Tier I, II, or III for
metals and chlorine in the metals and DRE burns, worst-case or normal-case for the risk burn, and
single- or multiple-point approach) are being pur sued. If an alternative approach is being used,
provide a detailed description. Cite any published guidance or literature upon which the
permitting approach has been grounded.}
[NOTE TO USER: Three basic approaches are available to establish the operating limits outlined
in Chapter 3 of Guidance on Setting Permit Conditions and Reporting Trial Burn Results (EPA
1989):
• Single waste/single operating condition—single-point approach
• Multiple wastes/multiple operating conditions—multiple-point approach
• Multiple wastes/single operating condition—universal approach
The user is advised to review this EPA guidance on the various approaches and consider the
approach that best suits the particular unit and waste stream(s). The third approach is the most
commonly used approach because it provides the most flexibility to the operator; the operator can
treat a variety of wastes under a single set of operating conditions established on the basis of trial
burn results. The first approach is most applicable to a unit treating only a single waste stream of
consistent character. The second approach may be advisable if the various wastes being treated
exhibit extreme variations in the character or quantity.]
The proposed trial burn testing program is based upon the universal approach outlined in Guidance on
Setting Permit Conditions and Reporting Trial Burn Results (EPA 1989). The universal approach
establishes one set of permit conditions or limits applicable to all modes of operation. This approach, as
proposed in the following section, will allow [Enter Company Acronym] to treat the variety of wastes
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produced by the [Enter Company Acronym] facility by confining the incinerator's operation to a
well-defined set of operating limits or an operating envelope.
Maximum waste feed rates for each stream will be specified in the permit. The incinerator operator will
thus have the flexibility to deal with a variety of wastes and waste combinations, while controlling the
overall combustion process within specific limits (including temperature, combustion gas velocity, and
thermal duty) that preclude maximizing the feed rates of all waste streams simultaneously.
PROPOSED TRIAL BURN PROGRAM
[REQUIREMENT: Describe the trial burn program and the information to be collected during
each test run under each test condition. If waste spiking is planned, describe the composition and
quantities of spiking compounds that will be used. Also describe the methods that will be used
either to inject the spiking compounds directly into the incinerator or to blend the spiking
compounds with the waste feeds. Correlate the information collected under each test condition to
the trial burn objectives (specifically, provide the linkage between test design and test objectives).}
The proposed trial burn testing program consists of three separate tests; each includes three replicate
runs. The rotary kiln and SCC operate during all three tests, incinerating a combination of liquid and solid
wastes. Tests 1 and 2 involve stack emission sampling at extremes of incineration operating temperatures
and waste feed rates in order to demonstrate compliance with the RCRA performance standards for
DRE, metals, particulate matter, carbon monoxide, hydrogen chloride, and chlorine emissions. Test 3
involves stack sampling at normal incineration process operating conditions to characterize stack
emissions to develop data for use in multi-pathway direct and indirect human health and ecological risk
assessments.
[Enter Company Acronym] intends to establish final permit limits based on adjusted Tier I values for
eight boiler and industrial furnace (BIF) metals (antimony, barium, lead, mercury, nickel, selenium, silver,
and thallium) and on Tier III values for four carcinogenic BIF metals (arsenic, beryllium, cadmium, and
chromium) and for hydrogen chloride and chlorine.
The target operating conditions for Tests 1, 2, and 3 are summarized in Table D-5.3 and outlined below.
The compositions and feed rates of the waste materials to be burned during the three tests are described
in Appendix D-5.4.
Test 1—High-Temperature Metals Burn
Test 1 will be a high-temperature test designed to establish permit conditions for maximum hourly rolling
average temperatures for the kiln and SCC and maximum hourly rolling average feed rate limits for
metals. Test 1 will be designed to demonstrate worst-case metals partitioning from the solid waste feed
to the combustion gas stream.
During Test 1, the following operating conditions will be maintained:
• Maximum combustion chamber temperatures (kiln and SCC)
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• Maximum metals feed rates
• Maximum chlorine feed rates
• Worst-case APCS operations (specifically, minimum venturi differential pressure,
minimum venturi and WESP recycle flow rates, minimum scrubber liquid pH, and
minimum WESP kilovolt amperes [kVa]).
Metals partitioning to the off-gas is a function of combustion chamber temperature and chlorine
concentration in the waste feed. In combination with the maximum metals feed rates, these operating
conditions present a maximum metals loading challenge to the APCS. The minimum differential pressure,
recycle flow rates, and pH operating conditions test the APCS's capabilities under conditions least
favorable for removing metals from the combustion gas.
Under Test 1, the solid and liquid wastes will be spiked with an organic chlorine compound
(perchloroethylene liquid) and organometallic liquid compounds of the four carcinogenic metals. These
compounds will be procured in sealed 55-gallon drums and will be metered into the solid and liquid wastes
directly from the drums using chemical feed pumps and injection manifolds. Injection points for the solid
waste will be located within the solid feed chute just upstream from its transition into the rotary kiln. The
injection points for the liquid waste will be in the feed lines just upstream from the waste injection nozzles.
Test 2—Low-Temperature DRE Burn
Test 2 will be a test of low combustion chamber temperatures and high mass feed rates to demonstrate
DREs of designated POHCs. Test 2 will demonstrate the permit limits for maximum hourly rolling
average waste feed rates and minimum combustion operating temperatures. POHCs and organic chlorine
will be metered to the solid waste feed and the liquid waste feed line(s) during Test 2, in the same manner
as described above for metals and organic chlorine.
The Test 2 operating conditions are designed to demonstrate worst-case operation of the rotary kiln
incineration system by testing its performance under the following conditions simultaneously:
• Minimum combustion chamber temperatures
• Maximum combustion gas velocity
• Maximum waste feed rates
• Maximum chlorine feed rates
• Minimum differential pressure, recycle flow rates, pH, and kVA in the APCS
Destruction of organics is a function of time, temperature, and turbulence, so the minimum combustion
chamber temperatures and maximum combustion gas velocity conditions of Test 2 challenge the capability
of the rotary kiln incineration system to destroy organics under conditions least favorable for organics
destruction (minimum time at minimum temperature). The maximum feed rate presents the maximum
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challenge for the waste feed systems to deliver waste feeds and the ash handling system to collect ash
residues. The maximum waste feed rates, in conjunction with maximum combustion gas velocity, also
present a maximum particulate loading challenge to the APCS. The maximum chlorine feed rates present
the maximum challenge for the rotary kiln incineration system's APCS to remove hydrogen chloride from
the combustion gas. The minimum differential pressure, recycle flow rates, and pH operating conditions
test the APCS's capabilities under conditions least favorable for removing particulate and acid gases from
the combustion gas.
Test 3—Risk Burn
Test 3 will be a test of normal operating conditions in order to develop data for the multi-pathway risk
assessment. During Test 3, measurements of stack emissions of particulate, particle-size distribution,
hydrogen chloride, chlorine, and PICs, including PCDDs and PCDFs, will be made while the incineration
system is operated at normal conditions.
[NOTE TO USER: The volatilization of metals from the solid wastes is a function of the
temperature and the presence of halogenated compounds that produce acid gases when combusted
and aid in the volatilization of the metals. A high-temperature test for assessing potential metals
emissions from solid wastes is counter to the establishment of minimum temperature limits for the
destruction and removal of oforganics. Hence, the reason for the first two tests in this example
trial burn plan: one to demonstrate maximum potential metals emissions and one to demonstrate
DRE. The third test involving either normal or worst-case operating conditions is needed to
develop data for risk assessment. This example uses normal operating conditions because the
facility is a captive waste burner with waste feed streams that are not highly variable in chemical
composition. Waste burners that have highly variable waste feed streams, especially commercial
hazardous waste combustion facilities, are not eligible for testing under normal operating
conditions and must test under worst-case conditions. In general, risk burn testing under worst-
case conditions will yield the most conservative risk assessment results and corollary risk-based
permit conditions. Many facilities that perform risk burn tests under worst-case conditions will
combine the DRE and risk burns into a single test.]
TRIAL BURN SAMPLING AND ANALYTICAL PROTOCOLS
The proposed trial burn sampling and analysis program is summarized in Table D-5.4. Sample locations
are shown on Figure D-5.4. Detailed sampling procedures are provided in the QAPP (see
Appendix D-5.1). The structure of this trial burn testing program is based on the previously stated trial
burn objectives.
During Test 1, the waste feeds will be spiked with controlled amounts of metals and organic chlorine
source chemicals. During Test 1, the stack will be sampled using the following methods:
Metals using the multi-metals train (MMT) (MMT 40 CFR 266 Appendix IX, and
SW-846 Method 0060) (see Figure D-5.5)
• Hexavalent chromium emissions using the hexavalent chromium sampling train
(Method Cr+6, 40 CFR 266 Appendix IX, and SW-846 Method 0061) (see Figure D-5.6)
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• Hydrogen chloride, chlorine, and participate emissions using the Method 0050 sampling
train (Method 0050, 40 CFR 266 Appendix IX and SW-846) (see Figure D-5.7)
DRE and maximum mass feed rates will be demonstrated during Test 2. The waste feeds will be spiked
with controlled amounts of the designated POHCs and organic chlorine source chemicals. The stack will
be sampled as follows:
• Hydrogen chloride, chlorine, and particulate emissions will be sampled using the Method
0050 sampling train (see Figure D-5.7).
• Volatile organics, including the POHCs chlorobenzene and carbon tetrachloride, will be
sampled using the volatile organic sampling train (VOST) (SW-846, Method 0031). An
illustration of the VOST is provided on Figure D-5.8.
• The semivolatile POHC naphthalene will be sampled using the Modified Method 5 train
(SW-846 Method 0010, see Figure D-5.10).
During Test 3, emissions of hydrogen chloride and chlorine, particulate, metals, PCDDs and PCDFs, and
other PICs will be measured. Particle-size distribution also will be measured. The stack will be sampled
as follows:
• Hydrogen chloride, chlorine, and particulate emissions will be sampled using the Method
0050 sampling train (see Figure D-5.7).
• Particle-size distribution will be measured using a [Enter Type] cascade impactor.
• Volatile organics will be sampled using two trains: (1) the volatile organic sampling train
(VOST) (SW-846, Method 0031), and (2) the Tedlar™ bag sampling train (SW-846
Method 0040). The VOST will be used to speciate volatile PICs in stack emissions. The
SW-0040 bag samples will be collected for on-site gas chromatograph (GC) analysis of
the low-molecular-weight PICs, with an emphasis on quantification of methane, ethane,
propane, butane, pentane, hexane, and heptane. Illustrations of the VOST and Method
0040 sampling train are provided on Figures D-5.8 and D-5.9, respectively.
• Semivolatile organics will be sampled using three variations (A, B, and C) of the Modified
Method 5 (MM5) train (MM5, SW-846 Method 0010) (see Figure D-5.10). The MM5A
train will be used to sample the stack emissions for speciated semivolatile PICs
identifiable using SW-846 Method 8270 and for PCDDs and PCDFs identifiable by high-
resolution gas chromatography and mass spectroscopy (GC/MS) SW-846 Method 8290.
The MM5B train will be used to sample the stack emissions for unspeciated semivolatile
and nonvolatile mass. The MM5C train will be used to sample the stack emissions for
polynuclear aromatic hydrocarbons (PAH).
• Aldehyde and ketone PICs will be sampled using the Method 0011 sampling train
(Method 0011, 40 CFR 266 Appendix IX and SW-846) (see Figure D-5.11).
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FINAL PERMIT LIMITS
[REQUIREMENT: Propose a methodology for establishing final permit conditions for the
incinerator system based on the results of the trial burn test.}
The anticipated permit operating conditions resulting from the trial burn testing are summarized in
Table D-5.5, which includes the proposed basis for each permit condition. The process parameters are
broken down by Group A, B, and C parameters, as established in the applicable EPA guidance
documents. Permit conditions for Group A and B parameters will be established on the basis of trial burn
results. Permit conditions for Group C parameters will be established on the basis of EPA guidance,
process design and safety considerations, or equipment manufacturers' recommendations.
Group A parameters will be continuously monitored process parameters, which will be tied to automatic
waste feed cutoffs (AWFCO). Group B parameters do not require continuous monitoring and will be not
interlocked with the AWFCO system; however, detailed operating records will be maintained to
demonstrate compliance with permitted operating conditions. Some Group C parameters will be
continuously monitored and interlocked with the AWFCO system.
Group C parameters will be established independently of trial burn results. For the most part, their
respective limits will be based on engineering considerations and good operating practices. For safety and
system performance purposes, the quench tower exit temperature and the differential pressure between
atomizing gas and waste feed will be monitored and recorded continuously and interlocked with the
AWFCO system.
During the shakedown period, the AWFCO settings for Group A and interlocked Group C parameters
will be those listed in Table D-5.6. During the trial burn, the interlocks for these Group A and C
parameters will remain operational at the limits listed in Table D-5.6.
Group B parameters will be monitored and recorded continuously during the trial burn but will not be
interlocked with the AWFCO system.
As indicated in Table D-5.5, [Enter Company Acronym] expects to establish final permitted operating
limits for Group A and B parameters based on the results of Tests 1, 2, and 3. The following list highlights
some of the limits that will be based on the results of Tests 1 and 2:
• The permit limit for maximum hourly rolling average rotary kiln combustion gas
temperature will be the mean of the highest hourly rolling average combustion
temperatures demonstrated during each of the three runs in Test 1, which will be the
worst-case for metals emissions.
• The permit limit for maximum hourly rolling average SCC temperature will be the mean
of the highest hourly rolling average SCC temperatures demonstrated during each of the
three runs in Test 1.
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• The permit limit for maximum hourly rolling average total metal feed rates will be the
mean of the highest hourly rolling average metal feed rate recorded during each run of
Test 1.
• The permit limit for maximum hourly rolling average metal feed rates for liquid wastes
(pumpable wastes) will be the mean of the highest hourly rolling average liquid waste
feed rate recorded during each run of Test 1.
• The permit limit for maximum hourly rolling average solid waste feed rate will be the
mean of the highest hourly rolling average solid waste feed rate recorded during each run
of Test 2.
• The permit limits for maximum hourly rolling average high-Btu and low-Btu liquid waste
feed rates to the kiln and SCC will be the means of the respective highest hourly rolling
average liquid waste feed rates recorded during each run of Test 2.
• The permit limit for minimum rotary kiln temperature will be the mean of the lowest
hourly rolling average temperatures demonstrated during the three Test 2 runs.
• The permit limit for the minimum hourly rolling average SCC temperature will be the
mean of the lowest hourly rolling average temperatures demonstrated during each run in
Test 2.
• The permit limit for maximum hourly rolling average combustion gas velocity will be the
mean of the highest hourly rolling average combustion gas velocities demonstrated during
Test 2.
• The permit limit for maximum organic chlorine feed rate limit will be the average chlorine
feed rate recorded in all runs under Tests 1 and 2.
• The permit limit for maximum liquid waste ash content limit (maximum ash mass feed
rate for any combination of liquid wastes) will be the average ash feed rate recorded in
the three runs under Test 1.
The following list identifies some of the risk-based permit limits expected to be established based on the
results of Test 3:
• The permit limit for maximum annual average rotary kiln combustion gas temperature will
be the mean of the highest hourly rolling average temperatures demonstrated during each
of the three runs in Test 3.
• The permit limit for minimum annual average rotary kiln combustion gas temperature will
be the mean of the lowest hourly rolling average temperatures demonstrated during each
of the three runs in Test 3.
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• The permit limit for maximum annual average SCC temperature will be the mean of the
highest hourly rolling average SCC temperatures demonstrated during each of the three
runs in Test 3.
• The permit limit for the minimum annual average SCC temperatures will be the mean of
the lowest hourly rolling average SCC temperatures demonstrated during each of the
three runs in Test 3.
• The permit limit for maximum annual average solid waste feed rate will be the mean of
the highest hourly rolling average solid waste feed rate recorded during each run of
Test 3.
• The permit limits for maximum hourly rolling average high-Btu and low-Btu liquid waste
feed rates will be the means of the respective highest hourly rolling average liquid waste
feed rates recorded during each run of Test 3.
• The permit limit for maximum annual average combustion gas velocity will be the mean
of the highest hourly rolling average gas velocities demonstrated during each run of
Test 3.
• The permit limit for maximum heat recovery boiler inlet temperature will be the mean of
the highest hourly rolling average inlet temperatures recorded during each run of Test 3.
A detailed discussion of the protocol for establishing these and other final permit limits based on the
results of the trial burn is provided in Section D-5d(2).
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D-5 INCINERATORS [40 CFR 264.340 through 264.351, 270.19, and 270.62]
This section of the trial burn plan is Section D-5 of the RCRA Part B permit application. The information
contained herein is intended to supersede all previous submittals of Section D-5. The format follows that
recommended by EPA for permit applications.
D-5a JUSTIFICATION FOR EXEMPTION [40 CFR 270.19(a)]
[NOTE TO USER: This section could be used by operators applying for an exemption based upon
data submitted in lieu of a trial burn [40 CFR 270.19(c)], characteristic waste exemption [40 CFR
264.340(b)], low-risk waste exemption (40 CFR 266.109), or DRE exemption (40 CFR 266.110).]
This section is not applicable. [Enter Company Acronym] is not seeking an exemption from any of the
incinerator or trial burn requirements.
D-5b TRIAL BURN [40 CFR 270.19(b)]
The following sections provide an engineering description of the incineration system and describe the
testing program to meet the performance requirements of the RCRA incinerator regulations and EPA
guidance.
D-5b(l) TRIAL BURN PLAN [40 CFR 270.19(b)]
The following trial burn plan discusses the current engineering configuration of the [Enter Company
Acronym] incineration system and outlines the proposed trial burn operating conditions, sampling and
monitoring procedures, and analytical methods that will be used to establish operating parameters for
inclusion in the final permit. As engineering changes encountered during construction, startup, and
shakedown necessitate revisions to this trial burn plan, any such changes will be coordinated with EPA
Region [Enter EPA Region] and the [Enter State Agency Acronym].
D-5b(l)(a) Detailed Engineering Description of the Incinerator [40 CFR
270.62fb)f2)fii)l
The following sections provide a detailed engineering description of the incineration system. A complete
set of PFDs, P&IDs, equipment arrangements, and process control logic diagrams is provided in
Appendix D-5.2. Specifications for major system components are provided in Appendix D-5.3. The
design bases for major components of the incinerator system are summarized in Table D-5.7. A
simplified process flow diagram is provided on Figure D-5.3.
The incineration system's engineering drawings and specifications were prepared by [Enter
Architect-Engineer]. Site preparations were performed by [Enter Site Development Contractor]. The
general contractor for construction and equipment installation will be [Enter Contractor's Name].
Construction will begin [Enter Date] and is expected to be completed by [Enter Date]. Project turnover
to [Enter Company Name] is expected to occur on [Enter Date].
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The [Enter Company Acronym] incinerator system was custom fabricated according to [Enter
Fabrication Company Name] Specification No. [Enter Number]. The certified-for-construction (CFC)
engineering designs and specifications were prepared by [Enter Process Design Contractor]. The
rotary kiln and SCC were fabricated by [Enter Fabrication Company Name], under Shop Order No.
[Enter Number]. The heat recovery boiler was fabricated by [Enter Fabrication Company Name]
under Shop Order No. [Enter Number]. The APCS was fabricated by [Enter Fabrication Company
Name] under Shop Order No. [Enter Number].
D-5b(l)(a)(l) Description of Rotary Kiln and SCC [40 CFR 270.62fb)f2)fu)fB) and fOl
The primary combustion chamber will be rotary kiln model [Enter Model Number] designed by [Enter
Design Company Name] (Drawing [Enter Drawing Number] in Appendix D-5.2). The rotary kiln
dimensions will be [Enter Dimension] feet outside diameter by [Enter Length] long. The inside diameter
will be [Enter Dimension]. The rotary kiln will be lined with [Enter Thickness] of refractory. Appendix
D-5.3 provides data sheets for the castable refractories.
The rotary kiln will be a controlled air, direct-fired, countercurrent (fuel and air added at the
high-temperature ash discharge end) unit. The kiln will be rated for a maximum heat release of [Enter
Maximum heat release] million Btus per hour. Design maximum liquid and solid waste feed rates will be
[Enter Liquid Capacity] and [Enter Solids Capacity], respectively.
High-Btu liquid wastes and natural gas will be fired through the rotary kiln burner to maintain the rotary
kiln operating temperature and provide high-temperature oxidation. Solid and sludge wastes will be fed
continuously from the auger-shredder through a feed chute into the rotary kiln. The ash from the rotary
kiln will be discharged to an enclosed rolloff container through a discharge chute below the burner
housing. Low-Btu (aqueous) wastes will be atomized into the rotary kiln combustion gas via a nozzle at
the burner end of the rotary kiln.
Solids residence time will vary from [Enter Residence Time Range] minutes. Typical solids retention
time will be [Enter Retention Time] minutes. Solids retention time in the rotary kiln is inversely
proportional to the rotary kiln rotational speed. Solids retention time can be calculated from the following
equation:
t = 2.28 L/DSN
where
t = mean retention time, minutes
L = rotary kiln length, feet
D = rotary kiln internal diameter, feet
S = rotary kiln slope, inch per feet
N = rotational speed, revolutions per minute
The installed slope of the rotary kiln will be [Enter Slope] inches per foot. If the rotary kiln is rotated at
[Enter Rotation Rate] revolutions per minute (rpm), the solids retention time will be [Enter Residence
Time] minutes. The expected range of rotation speeds will be [Enter Range] rpm.
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The effective gas volume of the rotary kiln combustion chamber will be [Enter Volume]. The expected
range of combustion gas flow rates will be [Enter Range] acfm. The expected combustion gas residence
time in the rotary kiln, calculated according to the following equation, will be [Enter Residence Time]
seconds:
([Enter Kiln Volume] ft3/[Enter Expected Flow Rate] acfm)*60 sec/min = [Enter Residence Time] sec
where
ft3 = cubic feet
acfm = actual cubic feet per minute
sec/min = seconds per minute
sec = seconds
Combustion gases will be discharged from the rotary kiln through a ventilation-duct into the SCC at a
temperature between [Enter Low Temperature] and [Enter High Temperature] °F.
The SCC (Drawing [Enter Drawing Number] in Appendix D-5.2) will consist of a steel cylindrical shell
lined with refractory material. The SCC will be rated for a maximum heat release of [Enter Maximum
Heat Release]. Its design capacity for liquid waste injection will be [Enter Liquids Capacity]. The
burner section of the SCC will be a specially designed combustion chamber that completes the combustion
of the gas from the rotary kiln by firing natural gas and high-Btu liquid wastes. Low-Btu (aqueous)
wastes will be atomized into the SCC combustion gas via a nozzle in the burner section of the SCC.
Combustion gases will be heated in the SCC to temperatures between [Enter Low Temperature] and
[Enter High Temperature] °F.
The SCC has an inside diameter of [Enter Inside Diameter] feet and an inside height of [Enter Height]
feet. The SCC will be lined with about [Enter Thickness] inches of high-temperature, acid-resistant,
insulating refractory material (refer to data sheets in Appendix D-5.3). The burner section will compose
the lower [Enter Length] feet of the SCC, followed by a [Enter Length] -foot-long combustion section
and a [Enter Length] -foot-long cross-over duct from the top. The thermal relief vent (TRY) will be
situated at the top of the SCC.
The total volume of the SCC combustion section will be about [Enter Volume] cubic feet. When the
refractory-lined cross-over duct is included, the overall volume will be about [Enter Volume] cubic feet
(Refer to Drawing [Enter Drawing Number] in Appendix D-5.2). The SCC volume will provide a
[Enter Residence Time] retention time at a gas flow rate of [Enter Volumetric Flow Rate] acfm, as
demonstrated by the following equation:
([Enter SCC Volume] ft3/[Enter Volumetric Flow] ft3/min)*60 sec/min = [Enter Residence Time] sec
where
ft3 = cubic feet
fWmin = cubic feet per minute
sec/min = seconds per minute
sec = seconds
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If the volume of the cross-over duct is included, the gas residence time increases to [Enter Residence
Time] seconds, as demonstrated by the following equation:
([Enter Volume] ft3/[Enter Volumetric Flow] ft3/min)*60 sec/min = [Enter Residence Time] sec
where
ft3 = cubic feet
fWmin = cubic feet per minute
sec/min = seconds per minute
sec = seconds
The typical SCC combustion gas flow rate is expected to be [Enter Volumetric Flow] acfm, and the
maximum flow is expected to be [Enter Volumetric Flow] acfm (trial burn heat and material balance).
The SCC combustion gas retention times for these flow rates will be [Enter Residence Time] and [Enter
Residence Time] seconds, respectively.
To provide for safe handling of wastes that will be present in the rotary kiln during a malfunction or
emergency condition, the SCC will be equipped with a TRY. The TRY will be a safety system designed
to provide a safe and controlled means of emergency venting combustion gas to bring about a controlled
shutdown of the incineration system. If an event, such as a power failure, were to occur, all waste feeds
to the rotary kiln and SCC will be discontinued. However, the combustion gas rising from the residual
solid and sludge wastes in the rotary kiln must be vented. The rotary kiln combustion gas will be diverted
through the SCC and TRY to the atmosphere. The TRY will remain open as long as solid and sludge
wastes are present in the rotary kiln. The TRY will be closed after the cause that initiated TRY has been
corrected or when all solid and sludge residuals have been processed through the rotary kiln and the
rotary kiln is shutdown. TRY operation is discussed in more detail in Appendix D-5.6.
D-5b(l)(a)(2) Nozzle and Burner Design [40 CFR 270.62(bK2Kin(H)1
Nozzle and burner systems will be located in both the rotary kiln and the SCC. The rotary kiln will be
equipped with a single dual-fuel burner. The SCC will be equipped with two dual-fuel burners (startup
and main). Manufacturer's specifications for the rotary kiln burner and the two SCC burners have been
included in Appendix D-5.3. Drawings showing the locations of the waste burners in the kiln faceplate
and the SCC are included in Appendix D-5.2 as Drawings [Enter Drawing Numbers].
The rotary kiln burner will be a [Enter Manufacturer Name and Model Number] dual-fuel air burner
(or equivalent) rated at [Enter Btu Rating] million Btu per hour. It will be designed to burn either natural
gas or liquids with a minimum heat value of [Enter Minimum Heat Value] and viscosities less than
[Enter Maximum Viscosity]. The burner will have a continuous gas pilot with a capacity of [Enter Btu
Rating] million Btu per hour. The maximum turn-down ratio of the burner will be [Enter Maximum
Turn-Down Ratio]. It will be designed to produce a [Enter Flame Shape]-shaped flame and low
nitrogen oxide emissions. Internal parts will be fabricated of [Enter Material of Construction]. The
burner's refractory ring will be constructed of [Enter Refractory Material]. The burner will be
positioned within the rotary kiln firing hood at the treated material discharge end of the rotary kiln.
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The two SCC burners will be [Enter Manufacturer and Model Number] dual-fuel air burners (or
equivalent) rated at [Enter Btu Rating] and [Enter Btu Rating] million Btu per hour, respectively. The
smaller SCC burner (the startup burner) will have a continuous gas pilot with a capacity of [Enter Btu
Rating] million Btu per hour. The larger, main SCC burner will have a continuous gas pilot with a
capacity of [Enter Btu Rating] million Btu per hour. Both burners will be designed to burn either natural
gas or liquids with a minimum heat value of [Enter Minimum Heat Value] and viscosities less than
[Enter Maximum Viscosity]. The smaller burner will have a maximum turn-down ratio of [Enter
Maximum Turn-Down Ratio]. The larger burner will have a maximum turn-down ratio of [Enter
Maximum Turn-Down Ratio]. Both burner bodies will be fabricated of [Enter Material of
Construction]. Internal parts include [Enter Material of Construction] components and [Enter
Material of Construction] refractory rings.
Both SCC burners will be positioned at the bottom of the SCC near the discharge duct from the rotary
kiln. The main SCC air blower can provide up to about [Enter Volumetric Capacity] standard cubic feet
per minute (scfrn) of air for the burners and cooling air for the burner section of the SCC. The purge air
blower provides up to about [Enter Volumetric Capacity] scfm for localized cooling of sight ports and
other miscellaneous SCC equipment. The tertiary air blower provides up to about [Enter Volumetric
Capacity] scfm of combustion air for the combustion section of the SCC combustion.
All three waste burners in the kiln and the SCC will be equipped with [Enter Brand Name and Model
Number] flame scanners as part of the flame safety management system. These scanners continuously
monitor flame conditions and will be interlocked with the AWFCO to stop all waste feeds automatically in
the event of a flameout.
High-Btu and low-Btu liquid wastes incinerated in the rotary kiln system will be pumped from feed tanks
to the burner and nozzle systems. In-line strainers will be provided to prevent oversized solids from
entering and clogging the burners and nozzles. All liquid waste flow rates will be monitored continuously,
recorded, and controlled using flow meters. Steam and high-pressure air will be used for atomizing
high-Btu liquid wastes and low-Btu liquid wastes, respectively.
High-Btu liquid wastes can be fired in the dual fuel rotary kiln burner alone or in combination with natural
gas. Similarly, high-Btu liquid wastes can be fired in the dual fuel main SCC burner alone or in
combination with natural gas. The high-Btu liquid waste burner guns will be equipped for steam
atomization. A minimum differential pressure of [Enter minimum AP] between the atomizing steam and
the liquid waste will be maintained at all times to ensure proper atomization.
Low-Btu liquid wastes will be injected into the combustion zone through nozzles in the rotary kiln and
SCC. These nozzles will be constructed of [Enter Material of Construction]. The low-Btu liquid
nozzles will be equipped for high-pressure air atomization. A minimum differential pressure of [Enter
Minimum AP] between the atomizing air and the liquid waste will be maintained at all times to ensure
proper atomization. Low-Btu liquid wastes will be, in general, aqueous wastes with zero or negligible
heating value. The rotary kiln low-Btu liquid waste nozzle will be located in the burner face of the rotary
kiln. The nozzle can be used to inject low-Btu liquid wastes into the rotary kiln or to add process water to
the system for temperature control. The nozzle will have a [Enter Turndown Ratio] to 1 turndown ratio.
Similarly, the SCC low-Btu liquid wastes nozzle will have a [Enter Turndown Ratio] to 1 turndown ratio.
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The SCC will be equipped with separate quench water nozzles to add process water for temperature
control. These water nozzles will have a [Enter Turndown Ratio] to 1 turndown ratio.
D-5b(l)(a)(3) Description of the Waste Heat Recovery Boiler
The waste heat recovery boiler will be a Model [Enter Model Number] water tube-type economizer
manufactured by [Enter Manufacturer Name]. It will be rated to produce [Enter Production Rate]
pounds per hour of [Enter Pressure] psig steam at [Enter Temperature] °F. The boiler will be code
stamped under the ASME Boiler and Pressure Vessel Code. The boiler's overall dimensions will be
[Enter Dimension] high, [Enter Dimension] long, and [Enter Dimension] wide. The boiler's internal
components will be constructed of [Enter Construction Material]. Design drawings (Drawings [Enter
Drawing Numbers]) for the boiler are provided in Appendix D-5.2.
The waste heat recovery boiler uses the SCC combustion gas to generate steam for facility use.
Combustion gases will enter and exit the boiler at [Enter Entrance Temperature] and [Enter Exit
Temperature] °F, respectively. The heat recovery boiler will be equipped with a bypass duct to allow
continued operation of the rotary kiln incineration system when the boiler must be taken off-line for
maintenance.
The operating volume of the boiler radiant section will be [Enter Volume] cubic feet. In the radiant
section, water will be circulated through tubes in the boiler walls. Heat will be recovered in the radiant
section by radiant transfer through the boiler walls. The operating volume of the boiler convective section
will be [Enter Volume] cubic feet. In the convective section, water will be circulated through tube banks
suspended in the combustion gas stream. Heat will be recovered by convective transfer as the
combustion gas passes through the tube banks. The total boiler combustion gas residence time will be
[Enter Time Range]. The product steam will be typically [Enter Temperature] °F and [Enter Pressure]
psig. Boiler exit temperature will be typically in the range of [Enter Temperature Range] °F. Steam
production will be typically [Enter Production Rate] per hour.
D-5b(l)(a)(4) Description of the Auxiliary Fuel Systems [40 CFR 270.62(bK2Kin(D)1
Natural gas will be fired to heat both the rotary kiln and the SCC to the proper operating temperatures
prior to feeding any hazardous wastes. The natural gas and high-Btu liquid wastes can be used to
maintain the desired combustion conditions in the combustion zones while treating wastes.
Natural gas will be supplied to the rotary kiln through a supply line to the burner system. The burner
system will be equipped with independent monitors, controls, interlocks, and fail safe devices required by
the National Fire Protection Agency (NFPA). Natural gas will be supplied to the SCC through a large
supply line that splits to supply the SCC burner system. Each branch contains independent monitors,
controls, interlocks, and other safety devices.
D-5b(l)(a)(5) Capacity of Prime Mover [40 CFR 270.62(bK2KiO(E)1
The combustion gas prime mover will be a [Enter Manufacturer and Model Number] centrifugal fan or
equivalent that operates as an induced draft fan. Under normal conditions, the induced draft fan will
operate at [Enter Volumetric Flow Rate] acfm, [Enter Temperature]0?, [Enter Pressure] inches of
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water inlet vacuum, and [Enter Pressure] inches of water outlet pressure. The induced draft fan will be
rated at [Enter Volumetric Flow Rate] acfm at [Enter Temperature]0^ and static inlet pressure of
[Enter Pressure] inches of water. The induced draft fan will have a [Enter Horsepower] horsepower
(hp) totally enclosed fan-cooled motor.
D-5b(l)(a)(6) Description of Waste Feed Systems [40 CFR 270.62fb)f2)fu)fD)l
Typically, three types of waste materials will be fed to the [Enter Company Acronym] incineration
system:
• High-heat-value liquid wastes (high-Btu liquid wastes)
• Low-heat-value liquid wastes (low-Btu liquid wastes)
• Solid wastes
High- and low-Btu liquid wastes can be fed to either the rotary kiln or to the SCC. High-Btu liquid
(organic solvent) wastes will be fired through dual fuel (natural gas, liquid fuel, or both) burners in the
rotary kiln and SCC. The dual high-Btu liquid waste and natural gas burners will be equipped with steam
for atomizing the liquid wastes. Low-Btu liquid (primarily aqueous) wastes will be fed through nozzles in
both combustion chambers. The low-Btu liquid waste injection nozzles will be equipped for air
atomization. The liquid wastes will be fed from agitated liquid waste feed tanks. The liquid waste feed
lines will be equipped with filters to prevent oversized particles from clogging the burners and nozzles.
Nozzle and burner designs are described in Section D-5b(l)(a)(2). The feed rate capacities and other
design bases of the various liquid waste feed systems are presented in Table D-5.8.
Solid wastes (including solids and sludges) will be fed directly to the rotary kiln by an auger-shredder.
The auger-shredder hopper capacity will be [Enter Volume] cubic yards. The design basis of the
auger-shredder will be presented in Table D-5.8.
D-5b(l)(a)(7) Description of Ash Handling System [40 CFR 270.62fb)f2)fu)fD)l
Hot ash will be discharged from the rotary kiln directly through a discharge chute into an enclosed rolloff
container. The rolloff container cover and ash discharge feed chute have custom-designed connections to
provide a mated mechanical seal to the rotary kiln system. This mechanical seal allows the rolloff
container to use the rotary kiln draft to maintain a vacuum to control fugitive emissions. The ash
discharge chute will be equipped with a manually operated valve to isolate and provide a mechanical seal
so that a full rolloff container can be replaced without interrupting the operation of the rotary kiln. The
capacity of each rolloff container will be [Enter Volume] cubic yards.
D-5b(l)(a)(8) Description of Automatic Waste Feed Cutoff System [40 CFR
The primary function of the AWFCO system interlocks will be to prevent the feeding of hazardous waste
if incineration conditions are outside the RCRA permit limits. During startup and shutdown of the
incinerator or during process upsets, the interlock system will automatically stop hazardous waste feed
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systems and prevent their restart until the incinerator is at proper operating conditions, and the interlock
will be manually reset. As shown on the process control logic loop diagram (see Drawing [Enter
Drawing Number] in Appendix D-5.2), the process controller immediately will initiate auxiliary fuel feed
to the kiln and the SCC upon any AWFCO event in order to maintain the kiln and SCC temperatures until
all wastes and waste residues exit the combustion chambers.
Descriptions of the process monitoring instruments that will be interlocked with the AWFCO system and
their cutoff points are shown in Table D-5.9. P&IDs are included in Appendix D-5.2 as Drawings [Enter
Drawing Numbers]. The AWFCO system will be tested weekly before, during, and after the trial burn.
The final AWFCO parameter values for permitted operation under 40 CFR Subpart O are expected to be
negotiated between EPA Region [Enter EPA Region], the [Enter State Agency Acronym], and [Enter
Company Acronym] based on the results of the RCRA trial burn. A discussion of the AWFCO
parameters follows:
• High- and Low-Rotary-Kiln Combustion Gas Temperature—The rotary kiln gas
temperature will be monitored continuously at the exit of the rotary kiln by thermocouples
TE-[### and ###]. If the hourly rolling average rotary kiln exit gas temperature falls
below the permitted minimum temperature or rises above the permitted maximum, the
solid and liquid waste feeds to the rotary kiln will be stopped.
• High- and Low-SCC Exit Gas Temperature—The temperature of the SCC combustion
gas will be monitored continuously by multiple thermocouples TE-[###, ###, ### and
###]. If the hourly rolling average SCC exit gas temperature falls below the permitted
minimum temperature or rises above the permitted maximum, the solid feed and liquid
waste feeds to the rotary kiln and the liquid waste feeds to the SCC will be stopped.
• High-Rotary-Kiln Solid and Sludge Waste Feed Rate—The auger-shredder continuously
feeds solids to the rotary kiln. The auger-shredder feed rate will be based on the auger
shaft speed (rpm). A speed sensor (SS-[###]) continuously monitors auger shaft speed.
The auger-shredder shaft speed will be used by the control system logic to calculate the
mass feed rate, which will be reported by weight indicating controller (WIC-[###]) and
for the totalizer (WQI-[###]). Rotary kiln waste feed will stop automatically if the
auger-shredder rpm for the solids feed rate exceeds the permitted maximum value
established during the trial burn.
• High-Rotary-Kiln and SCC High-Btu Liquid Waste Feed Rate—High-Btu liquid wastes
will be fed from the feed tanks to the rotary kiln and SCC by pumps. The flow rates of
the high-Btu liquid waste to the rotary kiln and SCC burners will be monitored
continuously by flow meters (FE-[###] and FE-[###]). If the high-Btu liquid waste hourly
rolling average feed rate to either the rotary kiln or SCC exceeds its permitted rate, the
individual high-Btu liquid waste feed stream exceeding its permitted limit will be stopped
automatically.
• High-Rotary-Kiln and SCC Low-Btu (Aqueous) Liquid Waste Feed Rate—Low-Btu
liquid waste will be fed from the feed tanks to the rotary kiln and SCC by pumps. The
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flow rates of the low-Btu liquid waste to the rotary kiln and SCC lances will be monitored
continuously by flow meters (FE-[###] and FE-[###]). If the low-Btu liquid waste's
hourly rolling average feed rate to either the rotary kiln or SCC exceeds its permitted
rate, the individual low-Btu liquid waste feed stream exceeding its permitted limit will be
stopped automatically.
Low-Stack-Gas Oxygen Concentration — The oxygen concentration will be measured in
the stack by oxygen analyzer AIT- [###]. The oxygen AWFCO system will stop all
waste feeds to the incineration system whenever the hourly rolling average of the stack
gas oxygen concentration falls below the permitted value.
High-Stack-Gas Carbon Monoxide Concentration — Carbon monoxide concentrations will
be measured in the stack by carbon monoxide monitor AIT-[###] and AIT-[###]. The
carbon monoxide AWFCO system will stop all waste feeds to the incineration system
automatically if the hourly rolling average stack gas carbon monoxide concentration
exceeds the permitted value corrected to 7 percent oxygen, dry basis. The oxygen
correction factor will be calculated using the following equation:
CO = CO x -
m 21 -
where
Coc = the stack carbon monoxide concentration corrected to 7 percent oxygen
dry basis
Com = the measured stack carbon monoxide concentration, dry basis
O2m = the measured stack oxygen concentration, dry basis
• High-Stack-Gas Flow Rate — The flow sensor located in the stack (FE-[###]) will be
operating continuously and will be connected to the AWFCO interlock whenever wastes
are being fed to the incineration systems. All waste feeds will be stopped automatically if
the hourly rolling average stack gas flow rate exceeds the permitted maximum value.
• High-Rotary-Kiln Pressure — A negative pressure will be maintained in the rotary kiln to
control fugitive emissions. The pressure at the upstream end of the rotary kiln will be
monitored continuously by PIT-[###] and PIT-[###]. All waste feeds to the rotary kiln
will be stopped automatically if the hourly rolling average rotary kiln pressure exceeds the
permitted value.
• High-Heat Recovery Boiler Inlet Temperature — The combustion gas inlet temperature to
the boiler will be monitored continuously by TT- [###]. Any time that the hourly rolling
average temperature exceeds the set point, an AWFCO will be initiated.
• High-Quench-Outlet Temperature — High-quench-outlet temperatures could result in
failure of process equipment and a safety hazard to personnel. The waste feed will stop
automatically if the hourly rolling average quench outlet temperature, as measured at
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TE-[###] and TE-[###], exceeds the manufacturer's high-temperature limit for
downstream APCS equipment. High-quench-outlet temperature is indicative of the loss
of quench recycle flow or a plugged spray nozzle, which results in less than adequate
cooling of the combustion gas.
• Low-Venturi-Scrubber Liquid/Gas Ratio—The recirculating venturi scrubber liquid and
the stack gas flow rate will be monitored continuously. Whenever the hourly rolling
average liquid/gas ratio drops below the permitted value, the waste feeds will be stopped
automatically.
• Low-Venturi-Scrubber Differential Pressure—The venturi scrubber differential pressure
will be measured by PDIT-[###] and will be controlled at or above a minimum value to
ensure efficient particle collection. All waste feeds will be stopped automatically if the
hourly rolling average differential pressure falls below the minimum permitted value.
• Low-Venturi-Scrubber Sump pH—The pH of the venturi scrubber solution will be
monitored continuously by AE-[###]. If the hourly rolling average scrubber falls below
the permitted minimum, all waste feeds will be stopped automatically.
• Low-WESP kVA—The WESP transformer and rectifier (T/R) voltage and amperage
will be continuously monitored. If the hourly rolling average WESP T/R kVA falls below
the permitted minimum kVA, all waste feeds to the incineration systems will be stopped
automatically.
• Low-Scrubber Blowdown Flow—The scrubber system blowdown flow rate will be
monitored continuously by FIT-[###]. Whenever the hourly rolling average scrubber
blowdown flow rate drops below the permitted value, all waste feeds will be stopped
automatically.
• Low-WESP Liquid Flow—The liquid flow rate in the WESP will be monitored
continuously by FIT-[###]. If the hourly rolling average liquid flow rate drops below the
permitted value, all waste feeds will be stopped automatically.
• Flameout—Flame conditions in the rotary kiln and the SCC will be monitored
continuously. Whenever, a flameout is detected in either the kiln or the SCC, all waste
feeds will be stopped automatically.
• Thermal Relief Vent Opening—Any time that the thermal relief vent opens, the waste
feeds will be stopped automatically.
The control system will be designed to eliminate, insofar as possible, unnecessary AWFCO events, while
still maintaining a conservative position. As indicated in Table D-5.9, several instruments will be
redundant. For some parameters, the AWFCO will be activated when both redundant sensors detect
conditions beyond the set points. For other parameters, the AWFCO will be activated when only one
sensor detects conditions beyond the set points. In general, when one instrument fails, it usually will go
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out of range and create an alarm in the distributed control system (DCS) to alert the operator to the
problem.
The redundant rotary kiln exit gas temperature thermocouples, TE-[### and ###], will be designed to
initiate an AWFCO when both register low-low rotary kiln combustion gas temperature; thermocouples
TE-[### and ###] perform a similar function for low-low SCC combustion gas temperature. The
redundancy of these instruments will be designed to prevent unnecessary AWFCO events caused by the
following types of thermocouple failure:
• Complete Failure of the Junction—The system will be designed to cause the indicated
temperature to go to full scale if this occurs; TSH-[### or ###] or TSH-[###, ###, ###,
or ###] will alarm as an indication to maintenance that the thermocouple has failed and
must be replaced.
• Gradual Aging of the Thermocouple Material—In general, the millivoltage generated by
an aged thermocouple will be less than a new thermocouple. The indicated temperature
will therefore be lower over time. To avert unnecessary AWFCO events, the
thermocouples will be replaced during scheduled preventive maintenance. Consistent
with the manufacturer's recommendations, the elapsed time between replacements will
not exceed [Enter Manufacturer's Recommendation] days.
The carbon monoxide analyzers, AIT-[###] and AIT-[###], will be completely redundant, non-dispersive
infrared (NDIR) analyzers. As such, they will be calibrated automatically on a daily (two-point) and
weekly (three-point) basis. These devices will be expected to meet the 40 CFR 266 Appendix IX
calibration drift requirements. The carbon monoxide analyzers initiate an AWFCO whenever either
analyzer detects conditions beyond the set point.
The rotary kiln pressure indicators, PIT-[###] and PIT-[###], will be completely redundant pressure
transmitters. As such, they measure vacuum in the rotary kiln. Each transmitter will fail low; specifically,
a failure will result in a signal less than 4 milliamperes, and will result in a panel alarm for that transmitter,
indicating to operations that the transmitter requires replacement. The higher of the two transmitter
outputs will be selected for use in controlling the induced draft fan's speed and as the input to the
high-high rotary kiln pressure switch (PSHH-[###]), which initiates the AWFCO.
The quench combustion gas thermocouple and temperature transmitters, TE-[###] and TE-[###], will be
designed to protect the scrubber system from high-high temperature. Each transmitter will be configured
to go full scale upon thermocouple failure. The output from both transmitters must be high-high to initiate
an AWFCO. The signal transmitted by each transmitter will be recorded in the data historian. When the
transmitters are calibrated, historian's records will be examined, and the thermocouple that produced a
record at least 10 °F lower than the other will be replaced.
The remainder of the measurement devices that initiate an AWFCO will be sufficiently robust that their
accuracy and repeatability will not vary significantly between calibrations, except for AE/AIT-[###] pH
measurement. An AWFCO will occur if any of these measuring devices were to fail. The frequency at
which the pH device will require standardization and transmitter adjustment will be a function of the
severity of the service and will have to be determined by operational experience.
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D-5b(l)(a)(9) Stack Gas Monitoring [40 CFR 270.62(bK2KiiKG)1
Continuous emissions monitors (CEM) will be used to monitor stack gases continuously for carbon
monoxide and oxygen concentrations. The CEMs will meet all of the performance specifications detailed
in "EPA Methods Manual for Compliance with the BIF Regulations" (40 CFR 266 Appendix IX). Sample
ports for the CEM probes will be located above the stack gas recycle duct in the stack. Additional
sample ports exist for trial burn testing.
The carbon monoxide analyzer will be a [Enter Manufacturer Name and Model Number] NDIR
analyzer. The analyzer's specifications will be as follows:
• Range—[Enter Range of Instrument] ppm
• Accuracy—[Enter Accuracy as Percent of Full Scale]
• Drift—[Enter Drift as Percent of Full Scale] per week
• Reproducibility—[Enter Reproducibility as Percent of Full Range]
• Response time—[Enter Percent of Full Scale] in 10 seconds
The oxygen analyzer will be a [Enter Manufacturer Name and Model Number] paramagnetic analyzer.
The analyzer's specifications will be as follows:
• Range—[Enter Range of Instrument] ppm
• Accuracy—[Enter Accuracy as Percent of Full Scale]
• Drift—[Enter Drift as Percent of Full Scale] per week
• Reproducibility—[Enter Reproducibility as Percent of Full Range]
• Response time—[Enter Percent of Full Scale] in 10 seconds
The CEM system manufacturer's specifications are included in Appendix D-5.3. The primary functions
of the CEM system will be as follows:
• Continuously measure, display, and record the gas concentrations in the stack.
• Activate alarms, and interrupt waste feed when preset values are exceeded.
Other important functions of the CEM system will be as follows:
• Remotely display stack gas composition and CEM system operational status.
• Automatically and manually calibrate sampling and analysis trains.
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• Automatically record and print the stack gas composition.
• Activate alarms when a malfunction occurs in the CEM system.
All CEM system instrumentation will be located in a climate-controlled CEM building. The location of the
CEM building is shown on Drawing [Enter Drawing Number] (see Appendix D-5.2). The operation and
control logic of the CEM system are depicted on Drawings [Enter Drawing Numbers] (see Appendix D-
5.2).
The stack gas sample will enter the CEM train through a probe assembly located in the stack gas duct,
where the gas will be filtered to remove particulate. The sample then will be drawn through a heated line
to the sample conditioning system where it will be cooled and filtered to remove moisture and remaining
particulate matter. Next, the sample will be transferred by a sample gas pump through a final filter to the
distribution system where the sample flow will be regulated and delivered to the oxygen and carbon
monoxide analyzers.
A programmable logic controller (PLC) will be the primary control unit for the CEM system. The PLC
will be located in the CEM building. The PLC processor will be capable of performing independent data
logging, calculating, and reporting functions. The PLC will allow the performance of all extractive CEM
control functions, including the following:
• Automatically calibrate the gas analyzers at selected time intervals.
• Automatically back purge sample probes.
• Provide operating status of the sample conditioning and analyzer systems to the data
acquisition system (DAS).
• Provide input/output signal interfaces to the strip-chart recorders, the CEM DAS, and the
plant DCS.
The PLC will transmit data to the DCS, which will provide remote monitoring and recording of CEM
operations at the plant control room. All analog and digital input/output signals will be conditioned properly
to reduce noise and to isolate signals from voltage transients. The DCS will display and record the
uncorrected and rolling averages for the gas concentrations. The indication of all gas composition will be
updated at least every 15 seconds. The DCS also will activate alarms and initiate an AWFCO when high
carbon monoxide concentrations are in the stack gas or when the DCS experiences a loss of analyzer
signal.
The CEM system will be calibrated using a three-point calibration method. Span gases of [Enter Range
of Percentages], [Enter Range of Percentages], and [Enter Range of Percentages] of instrument span
will be used to calibrate the oxygen analyzer. Span gases of [Enter Range of Percentages], [Enter
Range of Percentages], and [Enter Range of Percentages] of instrument span will be used to calibrate
the carbon monoxide analyzer. Concentrations of these span gases will be injected sequentially into the
sampling system at the stack. Gases will be injected by opening the solenoid valve on each certified gas
standard cylinder to allow the reference gas to flow under pressure to the sample probe. The reference
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gas will be drawn through the sample transport, sample conditioning, and sample delivery system and will
be analyzed in the same manner as a stack gas sample. Calibration results will be stored and printed
through the DAS.
The concentrations of the reference gases will span the expected concentrations of the actual gas
samples. The CEM system will be calibrated daily with zero and span gases and weekly with zero,
medium, and span gases. The zero and span gas calibrations will be considered a verification of the
quality of data received from the monitors. If the data from the analysis show a span drift response
greater than 2 percent, a full calibration will be performed using all three reference gas concentrations.
The analyzer output signal will be received by the CEM DAS. The CEM DAS also receives and stores
calibration data, calculates the response factor, compares it with former reference data, and determines if
the current value is within preset limits. If the response factor is outside established limits, the controller
will activate a calibration alarm at the monitoring system status panel. If the response factor is within
established limits, the DAS adjusts the analyzer signals by the calibration response factor and stores the
corrected gas component concentration values on magnetic media.
D-5b(l)(a)(10) Air Pollution Control Equipment [40 CFR 270.62fb)f2)fu)fG)l
The APCS includes the following equipment:
• Quench
• Venturi scrubber
WESP
• Induced draft fan
Stack
Equipment design and shop drawings, process flow diagrams, and P&IDs for the APCS are provided in
Appendix D-5.2.
The quench system serves four primary purposes, as follows: (1) cool the boiler or SCC combustion gas
for protection of downstream APCS devices, (2) provide a contact chamber for particulate and acid gas
removal, (3) saturate the combustion gas to optimize the performance of the venturi scrubber, and
(4) rapidly remove free energy from the combustion gas to reduce PIC formation potential in the APCS.
The quench will be designed to cool the combustion gas from either the boiler or the SCC. The
combustion gas, regardless of whether it is from the boiler or directly from the SCC, will be ducted to the
quench system where it will be cooled to adiabatic saturation temperature (typically between 170 °F and
190 °F) via a high volume of scrubber water sprays.
Condensation and excess water will be collected in a sump just below the quench. The sump solution
contains particulate and salts. The quench liquid will be recycled through a system of strainers and
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hydroclones where large participate will be removed. The liquid then will be recycled back through the
quench.
The saturated combustion gas stream will exit the quench and enter the high-energy venturi scrubber,
which is designed for high-efficiency particulate and acid gas removal. The entrained scrubber solution
droplets will coalesce or combine in the venturi scrubber throat to help to remove sub-micron particulate
and acid gases.
After exiting the venturi scrubber, the combustion gas stream will flow through a second mixing tube and
then enter the vane separator. The vane separator will be a Chevron-type demister designed to remove
entrained water and particulate droplets from the cleaned gas stream before the gas enters the WESP.
An internal spray header with spray nozzles will provide an intermittent fresh-water spray to the separator
plates for cleaning.
The combustion gas exiting the vane separator will enter the bottom of the WESP tower and flow upward
through vanes or perforated plates whose function will be to distribute the flow across the entire
cross-section of the tower. This will provide uniform residence time in the collector section, which will
maximize performance. Scrubber solution from the WESP sump will be recycled continuously to the
conditioning nozzles to precondition the combustion gas before entering the WESP collection area.
The cooled gas will flow upward through electrically grounded tubes called collector electrodes. An
ionizer electrode maintained at high negative direct current (DC) potential will be mounted concentrically
in each collector electrode. The high-voltage differential between ionizer and collector electrodes will
produce an intense electromagnetic field called a corona. Particles passing through the corona will be
charged negatively and will be attracted to the collector electrode. Particles reaching the collector wall
will be captured in a water film and drain into the WESP sump.
The induced draft fan will be downstream from the WESP. The fan will be the primary mover of
combustion gases through the system. It will maintain a rough vacuum (negative pressure) in the rotary
kiln, SCC, boiler, and APCS.
Combustion gas from the induced draft fan will be ducted to the stack. Recycled stack gas will be used
to maintain a relatively constant gas flow rate through the venturi scrubber in order to maintain the desired
pressure differential. The cleaned gas will be discharged from a [Enter Stack Height]-foot stack to the
atmosphere. The gas composition will be monitored and recorded continuously by the CEM system.
Operating information for each of the APCS components follows:
• Quench—The quench will contain spray nozzles to cool and humidify combustion
products to adiabatic saturation. The gas outlet temperature will be between about
170 and 190 °F. The total recycle flow rate to all nozzles will be about [Enter Flow
Rate] gpm.
• Quench Sump—The quench sump will be [Enter Dimension] feet in diameter and
[Enter Dimension] feet high with a conical bottom.
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Quench Recycle—Recycled quench solution will be pumped through a system of
strainers and hydroclones to remove suspended solids. The cleansed effluent from the
hydroclones will be recycled back to the quench sump. A portion of this recycle stream
will be purged to the facility WWTS. The solids removed by the strainers and
hydroclones will be treated in the rotary kiln.
Venturi Scrubber—The venturi scrubber will be a [Enter Manufacturer Name and
Model Name or Number] with a vane-type gas and water separator. The housing will
be constructed of fiberglass-reinforced plastic (FRP). The vane separator will contain
[Enter Number] corrosion-resistant demister modules. The recycle flow rate to the
venturi quench will be about [Enter Volumetric Flow Rate] gpm. The differential
pressure across the venturi scrubber will be about [Enter Differential Pressure] inches
of water column. The scrubber solution to the venturi scrubber will be pH-controlled with
caustic. The pH set point will be maintained at [Enter pH].
The WESP will be an up-flow unit with a square surface dimension of [Enter
Dimension] feet by [Enter Dimension] feet. The WESP vessel shell will be made of
[Enter Construction Material] with a total collection area of [Enter Collection
Area] -square feet 1,000 acfm. The electrostatic section will be washed by a set of
co-current sprays at the collection inlet and a set of counter-current washing sprays at
the collector exit. Scrubber solution recycle flow to the washing header will be about
[Enter Volumetric Flow Rate] gpm. Furthermore, the intermittent washdown sprays will
be operated at about [Enter Volumetric Flow Rate] gpm to remove any material that
may adhere to collector surfaces.
Induced Draft Fan—The rotary kiln incineration system prime mover will be a [Enter
Manufacturer and Model Number] centrifugal fan or equivalent. The fan wheel will be
constructed of [Enter Construction Material] or equivalent, and the housing will be
constructed of FRP. The fan will be designed to maintain a negative pressure in the
rotary kiln incineration system and will handle an inlet gas flow of about [Enter
Volumetric Flow] acfm at [Enter Temperature] ° F with an induced draft of [Enter
Vacuum Rating] inches of water column. The fan will be driven by a [Enter
Horsepower] hp variable speed motor.
Stack Gas Recycle Duct—Clean stack gas can be recycled from the stack to the
transition duct upstream of the conditioner venturi scrubber. The stack gas will be
recycled to allow the rotary kiln incineration system to be operated at lower combustion
rates, hence lower stack flow rates, while maintaining the differential pressure across the
scrubber above the AWFCO set point.
Recycle Water Systems—The scrubber solution from each device in the APCS will be
recycled by a system of sumps and pumps. Fresh makeup water can be added to the
quench, vane separator, WESP, and venturi scrubber unit. The scrubbing solution will
cascade upstream through the scrubbers to the quench.
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D-5b(l)(a)(ll) Construction Materials [40 CFR 270.62fb)f2)fu)O)l
The construction materials for the incinerator system components are specified in Table D-5.10.
D-5b(l)(a)(12) Location and Description of Temperature, Pressure, and Flow Indicating and
Control Devices [40 CFR 270.62fb)f2)fii)f J)l
[NOTE TO USER: This section should include instrument numbers consistent with the P&IDs so
that the reviewer fully understands the operation of the unit.}
The locations of the process control instruments are shown on the following piping diagrams and P&IDs
provided in Appendix D-5.2: [List Drawing Numbers and Titles}.
This section provides a general description of temperature, pressure, flow, and other instrumentation
requirements necessary to ensure compliance with all permit conditions. A discussion of the major
controls of the rotary kiln incineration system that will be linked to the DCS is also provided. Table
D-5.11 shows the instruments that will be used to monitor plant operations and record data for the facility
operating record and the trial burn. Table D-5.11 also includes a listing of the alarm settings for key
process monitoring equipment.
The proper operation of this monitoring equipment will be necessary to ensure consistent compliance with
all permit conditions and safe and efficient operation of the rotary kiln incineration system. Although all
process monitoring instrumentation receive periodic maintenance, equipment critical to compliance with
permit operating conditions receives additional attention. Key issues associated with these instruments
include the following:
• Continuing and preventive maintenance
• Verification of instrument calibration
• Verification of AWFCO integrity
The preventive maintenance program will be augmented by information received from daily and periodic
inspections of the process and equipment. Instrument calibration and preventive maintenance will be
performed following the procedures and frequencies described in Table D-5.12.
The DCS will control the incineration system operation. The control loop logic diagrams are provided in
Appendix D-5.2. A description of the primary control loops follows.
Rotary Kiln Solid and Sludge Waste Feed Control
The solid and sludge waste feed introduced into the rotary kiln will be monitored constantly by means of a
speed sensor (SS-[###]) on the auger-shredder shaft (Z-[###]). The auger feed rate will be
factory-calibrated based on the auger speed (rpm) and a fixed feed density. A weigh recorder
(WR-[###]) and a weigh-indicating totalizer (WQI-[###]) will be installed in the DCS to maintain a
continuous record of the feed rate based on auger speed and calibrated control logic. The speed sensor
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(SS-[###]) sends a signal to the weigh-indicating controller (WIC-[###]), which controls the speed of the
auger shaft (Z-[###]), thereby controlling the waste feed rate discharged into the rotary kiln. A high-high
waste feed rate switch (WSHH-[###]) will be installed and will trigger an alarm (WAHH-[###]) and an
AWFCO if the hourly rolling average feed rate exceeds the maximum set point.
Rotary Kiln High-Btu Liquid Waste Feed Control
The flow of high-Btu liquid waste to the rotary kiln burner will be monitored constantly by means of a
flow meter (FE-[###]) on the high-Btu liquid waste feed line. A flow recorder (FR-[###]) and a
flow-indicating totalizer (FQI-[###]) will be installed in the DCS to maintain a continuous record of the
high-Btu liquid waste feed rate. The flow element (FE-[###]) will send a signal to the flow-indicating
controller (FIC-[###]) that will control the flow valve (FV-[###]) to the rotary kiln burner. A high-high
flow rate switch (FSHH-[###]) will be installed and will trigger an alarm (FAHH-[###]) and an AWFCO
if the hourly rolling average feed rate exceeds the maximum set point.
Rotary Kiln Low-Btu Liquid (Aqueous) Waste Feed Control
The flow of low-Btu liquid (aqueous) waste to the rotary kiln aqueous lance will be monitored constantly
by means of a flow meter (FE-[###]) on the low-Btu liquid waste feed line. A flow recorder (FR-[###])
and a flow-indicating totalizer (FQI-[###]) will be installed in the DCS to maintain a continuous record of
the low-Btu liquid waste feed rate. The flow element (FE-[###]) will send a signal to the flow-indicating
controller (FIC-[###]) that will control the flow valve (FV-[###]) to the rotary kiln. A high-high flow rate
switch (FSHH-[###]) will be installed and will trigger an alarm (FAHH-[###]) and an AWFCO if the
hourly rolling average feed rate exceeds the maximum set point.
Rotary Kiln Pressure Control
Rotary kiln pressure will be monitored constantly by means of redundant pressure transmitters
(PIT-[### and ###]) mounted on the rotary kiln ash discharge hood. A pressure recorder (PR-[###]) will
be installed in the DCS to maintain a continuous record of the rotary kiln pressure. A pressure controller
(PIC-[###]) will send a signal to the induced draft fan speed controller (SIC-[###]), which will adjust the
speed of the variable speed fan to control the rotary kiln pressure. A high-high rotary kiln pressure switch
(PSHH-[###]) will be installed and will trigger an alarm (PAHH-[###]) and an AWFCO if the hourly
rolling average rotary kiln pressure exceeds the maximum pressure set point.
Rotary Kiln Combustion Gas Temperature and Burner Controls
During normal operation, the rotary kiln combustion gas temperature will be controlled by modulating the
natural gas flow rate to the rotary kiln burner (G-[###]). A temperature controller (TIC-[###]) will
control the rotary kiln burner gas rate. The natural gas flow rate to the burner will be adjusted up or down
to maintain the rotary kiln combustion gas temperature. The burner will have a [Enter Number} to [Enter
Number} turndown ratio.
Temperature recorders (TR-[### and ###]) and temperature indicators (TI-[### and ###]) will be
installed in the DCS for continuous process monitoring. A low-low rotary kiln combustion gas
temperature switch (TSLL-[###]) will trigger an alarm (TALL-[###]) and an AWFCO if the hourly
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rolling average temperature falls below the minimum temperature set point. A high-high rotary kiln
off-gas temperature switch (TSHH-[###]) will trigger an alarm (TAHH-[###]) and an AWFCO if the
hourly rolling average temperature rises above the maximum temperature set point.
Secondary Combustion Chamber Gas Temperature and Burner Control
The SCC temperature will be maintained by measuring the SCC off-gas temperature in the cross-over
duct by means of redundant duplex thermocouples (TE-[###, ###, ###, and ###]). Temperature
indicators and recorders, including TIC-[###] and TR-[###], will be installed in the DCS for continuous
process monitoring. A low-low temperature switch (TSLL-[###]) will be installed to trigger an alarm
(TALL-[###]) and an AWFCO if the hourly rolling average SCC combustion gas temperature falls below
the minimum temperature set point.
The flow rates of high- or low-Btu liquid wastes to the SCC will be set normally to a fixed flow value.
Then the SCC temperature will be controlled automatically by the temperature controller (TIC-[###]),
which will send a signal and control the SCC main burner (G-[###]) natural gas flow rate. The natural
gas flow rate will be increased or decreased to maintain the SCC off-gas temperature. The SCC main
burner combustion air flow rate will be set via controller (FFIC-[###]) at a ratio to gas flow rate to
maintain a stable flame. The SCC main burner will have a turndown ratio of [Enter Number} to [Enter
Number}.
The desired oxygen content in the stack gas will be 3 to 5 percent. This oxygen level will be adjusted in
the SCC. The operator constantly monitors the stack gas oxygen concentration as described later in this
section. If the stack gas oxygen level continues to decrease after secondary and tertiary air blowers have
reached maximum output, the operator will have the option of making adjustments to the waste feed rates
and combustion air flows to the rotary kiln, as described previously, or by reducing or shutting off the
high- and low-Btu liquid waste feed rates to the SCC, or by increasing the combustion air to gas ratio to
the burners to allow more combustion air into the SCC.
If the SCC burner firing rate has been reduced to its minimum and the SCC combustion gas temperature
continues to increase, the operator can respond by making adjustments in the rotary kiln operation, or by
reducing or shutting off the high-Btu liquid waste feed rate to the SCC, or by increasing the low-Btu
(aqueous) waste or injecting process water to absorb the excess heat release.
SCC High-Btu Liquid Waste Feed Control
The flow of high-Btu liquid waste to the SCC main burner will be monitored constantly by means of a
flow meter (FE-[###]) on the high-Btu liquid waste feed line. A flow recorder (FR-[###]) and a
flow-indicating totalizer (FQI-[###]) will be installed in the DCS to maintain a continuous record of the
high Btu liquid waste feed rate. The flow element (FE-[###]) will send a signal to the flow-indicating
controller (FIC-[###]) that will control the flow valve (FV-[###]) to the SCC main burner. A high-high
flow rate switch (FSHH-[###]) will be installed and will trigger an alarm (FAHH-[###]) and an AWFCO
if the hourly rolling average feed rate exceeds the maximum set point.
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SCC Low-Btu Liquid Waste Feed Control
The flow of low-Btu liquid (aqueous) waste to the SCC aqueous lance will be monitored constantly by
means of a flow meter (FE-[###]) on the low-Btu liquid waste feed line. A flow recorder (FR-[###]) and
a flow-indicating totalizer (FQI-[###]) will be installed in the DCS to maintain a continuous record of the
low-Btu liquid waste feed rate. The flow element (FE-[###]) will send a signal to the flow-indicating
controller (FIC-[###]) that will control the flow valve (FV-[###]) to the SCC. A high-high flow rate
switch (FSHH-[###]) will be installed and will trigger an alarm (FAHH-[###]) and an AWFCO if the
hourly rolling average feed rate exceeds the maximum set point.
Quench Outlet Gas Temperature
The quench outlet gas temperature will be measured by means of two sets of duplex thermocouples
(TE-[### and ###]). Temperature recorders (TR-[### and ###]) and temperature indicators
(TI-[### and ###]) will be installed in the DCS for continuous process monitoring. If a high-high
temperature in the quench outlet gas is detected, the alarm (TAHH-[###]) will be activated. If the
maximum hourly rolling average quench exit temperature is exceeded, the control system will trigger an
AWFCO.
Quench Recycle Flow
The quench liquid recycle flow will be measured by means of a flow meter (FE-[###]). A flow indicator
(FI-[###]) and a flow recorder (FR-[###]) will be installed in the DCS for continuous process monitoring.
A low-low flow switch (FSLL-[###]) will be installed and will trigger an alarm (FALL-[###]) and an
AWFCO if the hourly rolling average flow rate drops below the minimum set point.
Venturi Scrubber Recycle Rate
Scrubbing liquid will be recycled into the venturi scrubber, and the flow rate will be measured by means of
the flow meter (FE-[###)]. The liquid flow rate will be monitored continuously in the DCS via the flow
indicator (FI-###) and recorded via the flow recorder (FR-[###]). A low-low flow switch (FSLL-[###])
will be installed and will trigger an alarm (FALL-[###]) and an AWFCO if the hourly rolling average flow
rate drops below a minimum set point.
Venturi Scrubber Sump pH
The pH of the venturi sump scrubbing liquid will be monitored by means of a pH analyzer (AE-[###]). A
recorder (AR-[###]) and an indicator (AIC-[###]) will be installed in the DCS for continuous process
monitoring. A transmitter (AIT-[###]) will send the pH signal to the controller (AIC-[###]) and adjust the
addition of caustic accordingly to maintain the desired pH. A low-low analyzer switch (ASLL-[###]) will
be installed and will trigger an alarm (AALL-[###]) and an AWFCO if the hourly rolling average pH falls
below the minimum set point.
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Venturi Scrubber Differential Pressure
The differential pressure across the venturi scrubber will be measured by means of a differential pressure
transmitter (PDIT-[###]). A recorder (PDR-[###]) and an indicator (PDIC-[###]) will be installed in the
DCS for continuous process monitoring. The indicating controller (PDIC-[###]) will send a signal to the
recycle gas flow controller (PDY-[###]) to adjust the amount of recycle gas to maintain the required
differential pressure. A low-low differential pressure switch (PDSLL-[###]) will be installed to trigger an
alarm (PDALL-[###]) and an AWFCO if the hourly rolling average differential pressure falls below a
minimum set point.
Scrubber Liquid Slowdown Rate
The scrubber liquid blowdown flow will be measured by means of the flow meter (FE-[###]). A flow
indicator (FI-[###]) and a flow recorder (FR-[###]) will be installed in the DCS for continuous process
monitoring. If a low flow is detected, the low-flow alarm (FAL-[###]) will be activated. If the hourly
rolling average blowdown flow drops below the minimum set point, an AWFCO will be triggered.
WESP Transformer/Rectifier kVA
The T/R control panel will have on and off switches (HS-[###] and HS-[###], respectively) with
indicators (HL-[###] and HL-[###], respectively). The control panel will display primary and secondary
voltage (£!-[###] and EI-[###], respectively) and primary and secondary amperage (!!-[###] and !!-[###],
respectively). The control panel will have high- and low-voltage alarms (EAH-[###] and EAL-[###]) and
a high-amperage alarm (IAH-[###]). The control panel will send voltage and amperage information to
the DCS, where the low-low kVA interlock will be initiated (YALL-[###]).
The transformer will have a high-high pressure switch and alarm (PSHH-[###] and PAFiH-[###]),
high-high temperature switch and alarm (TSHH-[###] and TAHH-[###]), and a low-low transformer
liquid-level switch and alarm (LSLL-[###] and LALL-[###]). The transformer pressure, temperature,
and liquid-level switches will activate automatically to shut off the WESP and will initiate an AWFCO if
the pressure exceeds the maximum set point.
WESP Liquid Flow Rate
The WESP liquid flow will be measured by means of the flow meter (FE-[###]). A flow indicator
(FI-[###]) and a flow recorder (FR-[###]) will be installed in the DCS for continuous process monitoring.
If a low flow is detected, the low-flow alarm (FAL-[###]) will be activated. If the hourly rolling average
blowdown flow drops below the minimum set point, an AWFCO will be triggered.
Stack Gas Oxygen Level
Stack gas oxygen level will be measured continuously by an oxygen analyzer (AIT-[###]). The oxygen
will be indicated and recorded continuously in the DCS by an indicating controller and recorder
(AIC-[###] and AR-[###], respectively). If the oxygen level is below the preset low-low level set-point,
oxygen level switch ASLL-[###] will be triggered. If the hourly rolling average stack gas oxygen
concentration drops below the set point, an AWFCO will be triggered.
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Stack Gas Carbon Monoxide Level
The stack gas carbon monoxide level will be measured by means of two redundant sets of carbon
monoxide analyzers (AIT-[###] and AIT-[###]). Redundant indicators (AI-[###] and AI-[###]) and
recorders (AR-[###] and AR-[###]) will be installed in the DCS for continuous process monitoring. If the
carbon monoxide level is above the preset high-high level set point, and either one of the redundant
high-high carbon monoxide level switches (ASHH-[###] and ASHH-[###]) is triggered, the corresponding
alarm will sound. An AWFCO will be triggered if the hourly rolling average carbon monoxide level rises
above 100 ppmdv.
Stack Gas Flow Rate
The stack gas flow rate will be measured by means of the Annubar™ flow meter (FE-[###]). A flow
recorder (FR-[###]) and a flow indicator (FI-[###]) will be installed in the DCS for continuous process
monitoring. A high-high flow switch (FSHH-[###]) will be installed and will trigger an alarm
(FAHH-[###]) and an AWFCO if the preset maximum hourly rolling average flow rate is exceeded.
D-5b(l)(a)(13) Incineration System Startup Procedures [40 CFR 270.62(bK2Kvii)1
The rotary kiln incineration system will be brought up to full operating condition while firing fossil fuel
(natural gas) before introducing any hazardous wastes to the rotary kiln or SCC. The phrase, full
operating condition, means that combustion temperatures are above the minimum for feeding waste, that
the rotary kiln is under vacuum, and that the unit is in compliance with all other regulatory limits. The
startup sequence will be, essentially, in reverse order of the direction that waste feed and combustion
products pass through the system, in that the APCS will be started first, and the waste feed system will be
started last. Before any of the rotary kiln incineration system processing equipment can be started, all
utilities and the control system must be operational.
The specific procedures for starting the rotary kiln incineration system and introducing waste feed to the
system follow. The typical period of time required for startup will be [Enter Hours] hours.
Rotary Kiln Incineration System Startup Procedures
A summary of the rotary kiln incineration system startup procedures follows.
Startup Utilities
1. Provide electrical power to the main switch gear, the motor control centers, and the control room.
2. Place the uninterruptible power supply (UPS) in operating mode.
3. Perform a pre-operational check of all systems to be used.
4. Place the emergency power generator in stand-by mode.
5. Start the DCS.
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6. Start the plant and instrument air systems.
7. Start the process water system.
8. Start the caustic system.
Startup APCS Train
9. Perform and check, as applicable, the following:
a. Fill and pressurize the quench emergency water tank.
b. Fill the scrubber and quench sumps.
c. Fill the clarifiers and thickener tanks and the clarifier overflow tanks.
10. Start the APCS train, as follows:
a. Start the scrubber and quench recycle pumps. Adjust recycle flow rates, as necessary.
b. Start the induced draft fan.
c. Start the wash water sprays to the vane separator. Adjust flow rate, as necessary.
11. Start the APCS wastewater treatment system:
a. Start the hydroclone recycle pump.
b. Adjust the hydroclone recycle pump.
c. Start the clarifier overflow pump.
d. Start the clarifier sludge pump.
e. Turn the grounding switch on the WESP T/R to the HV or ON position.
f Switch on the WESP hot-purge heater and blower, and allow them to operate for
15 minutes.
g. Start the WESP makeup water and WESP recycle pump.
Startup Boiler System
12. Start the boiler.
a. Start the boiler feed water system.
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b. Bring the water level in the boiler to the correct operating level.
c. Check that the steam vent valve is open.
Startup Secondary Combustion Chamber Train
13. Start the SCC.
a. Set combustion air flows and start the combustion air blower.
b. Start the SCC burner ignition purge air cycle.
c. After completing the purge cycle, start the pilot burner.
d. Start the cold start burner.
e. Gradually increase the cold start burner gas flow to raise the SCC temperature according
to the refractory heat-up schedule.
f. Start the main burner to provide additional heat. Adjust gas flow to bring the SCC up to
operating temperature.
g. Maintain or turn off the cold start burner, depending on the process requirements.
h. Start the tertiary air blower.
Adjust Boiler Operation
14. Perform boiler heatup tasks.
a. Monitor boiler heatup.
b. Close the stream drum vent when a good steam plume is evident.
c. Check that the safety valve is operable.
d. Check the water column for proper operation by blowing down the water column until a
low-water alarm sounds.
e. Blow down the water glass.
f. Open the service valve when the desired steam pressure is achieved.
g. Maintain the water level in the boiler.
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Startup Rotary Kiln
15. Start rotary kiln system.
a. Start the rotary kiln lubrication system.
b. Start rotary kiln combustion air fans. Flow controllers must have set points to permit
purge.
c. Start the rotary kiln purge cycle (rotary kiln will purge through TRY).
d. After completing the purge, start the burner pilot.
e. After the pilot flame has been established, start the burner on minimum fire. The burner
must be lit within 5 minutes of lighting its pilot. Otherwise, the pilot must be shut off, and
the rotary kiln must be re-purged.
16. Start heating the rotary kiln. After the rotary kiln has been purged and the burner has been
ignited, switch the rotary kiln combustion gas to the boiler and APCS by closing the TRY.
17. When the rotary kiln and SCC reach permitted minimum operating temperatures (refer to
Table D-5.6) and all waste feed parameters are satisfied, the rotary kiln is ready to receive
hazardous waste. Start the waste feed systems individually (high-Btu liquids first, low-Btu liquids
second, and solids third), and adjust feed rates to the desired set point, while maintaining rotary
kiln and SCC temperatures and other system-operating parameters.
D-5b(l)(b) Sampling and Monitoring Procedures [40 CFR 270.62Cb)(2)(iirH
The objectives of the trial burn are as follows:
• Calculate particulate mass emission rates during all tests.
• Determine particle-size distributions during Test 3.
• Calculate hydrogen chloride removal efficiency during Tests 1 and 2.
• Calculate metal feed rates, emission rates, and removal efficiencies during Test 1.
Calculate POHC DREs during Test 2.
• Confirm the fate of POHCs fed to the system during Test 2.
• Document metals, PCDDs and PCDFs, volatile and semivolatile PICs, PAH, aldehyde,
and ketone emissions in the stack gas that occur during destruction of hazardous waste
constituents during Test 3.
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• Document carbon monoxide and oxygen concentrations in the stack gas that occur during
destruction of hazardous waste constituents during all tests.
• Document the process operating conditions that will be used in establishing operating
permit conditions during all tests.
The sampling and analysis procedures included in this section were selected to accomplish the objectives
discussed above. The following sampling and analysis procedures are based on spiking carcinogenic
metals (specifically, arsenic, beryllium, cadmium, and chromium), ash, and organic chlorine in the waste
feeds in Test 1 and spiking chlorobenzene, carbon tetrachloride, and naphthalene as the POHCs, organic
chlorine, and ash in Test 2. No spiking is planned in Test 3.
The rationale for the selection of the POHCs is presented in Section D-5b(l)(d)(2). The waste spiking
program is described in Section D-5b(l)(d)(4).
PIC emissions data, including PCDDs and PCDFs, is being collected for use in performing the
site-specific HHRA.
The QAPP for the trial burn is included in Appendix D-5.1.
D-5b(l)(b)(l) Sampling Locations and Procedures
The locations at which solid, liquid, and gaseous samples will be collected from the incineration and
APCSs are shown on Figure D-5.4. The materials supplied to the incineration and APCS processes,
including solid and sludge waste feed, high-Btu liquid feed, low-Btu liquid feed, caustic, and process
water, will be sampled at locations 1, 2, 3, 16, and 17, respectively. Samples of processed solids residuals
(ash) will be collected at location 14. Scrubber blowdown water will be sampled at location 15. Gaseous
samples for determining POHCs, PICs, PCDDs and PCDFs, metals, hydrogen chloride and particulate
emissions, and combustion gas composition will be collected at locations 4 through 13. The carbon
monoxide and oxygen concentration of the combustion gas will be monitored continuously at location 18.
Natural gas and combustion air will not be sampled.
Sampling standard operating procedures (SOP) are provided in Appendix D-5.7. The sampling
procedures for collecting samples at each location are summarized in Table D-5.4. Sampling frequency
and reference methods also are included in Table D-5.4. The numbers following each heading refer to
the sampling location shown on Figure D-5.4 and in Table D-5.4.
Process grab samples for volatile organic analysis (VOA) will be collected and packaged separately in
the field and will be composited by the laboratory immediately before analysis. All other process grab
samples will be composited in the field and shipped to the laboratory as composite samples for analysis.
This method eliminates the potential loss of volatile organics from the process samples during compositing
in the field.
Additional details regarding sample locations, frequencies, and methods follow.
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D-5b(l)(b)(l)(a) Solid and Sludge Waste Feed (Location 1)
Wastewater treatment sludge or similar low-Btu, high-ash-content solid waste materials from the [Enter
Company Acronym] facility will be used as the solid feed during all three trial burn tests. Because the
generation rate of wastewater treatment sludge will be relatively low, it will be necessary for [Enter
Company Acronym] to stockpile wastewater treatment sludge to have sufficient quantities for trial burn
purposes. The sludge waste feed will be sampled at 15-minute intervals during each trial burn run under
all three test conditions.
During Test 1, precisely prepared solutions of metal salts will be metered continuously to the solid and
sludge feed via a tap on the auger-shredder feed chute, as described in Section D-5b(l)(d). Similarly,
organic POHCs will be metered continuously to the solid and sludge waste feed during Test 2. Solid and
sludge waste feed will be sampled before the addition of POHCs or metals.
Two of the selected POHCs, chlorobenzene and carbon tetrachloride, will be liquids. The third POHC,
naphthalene, will be a solid. The naphthalene will be dissolved in known proportions of mineral oil for
metering to the solid and sludge waste feed during Test 2. POHC and metal spiking compounds will be of
reagent-grade purity. Certified analyses of all POHC and spiking compounds will be obtained from the
suppliers before the trial burn. The POHCs and metal spiking solutions will not be sampled on site.
D-5b(l)(b)(l)(b) High-Btu Liquid Waste Feeds (Location 2)
Actual high-Btu liquid wastes will be used as the high-Btu liquid waste feed to the kiln and SCC during all
three trial burn tests. During Tests 1 and 2, the actual wastes will be blended with perchloroethylene to
create a high-Btu liquid waste blend with the required heat of combustion and organic chlorine content.
During all three trial burn tests, high-Btu liquid wastes will be fed to both the rotary kiln and the SCC from
the same blend/feed tank. Grab samples will be collected from a tap in the high-Btu feed recycle line
upstream of the point at which POHCs or metals solutions are introduced at 15-minute intervals during
each replicate test run and will be composited for the run.
Solutions of metal salts will be fed to the high-Btu waste feed line or the low-Btu waste feed line
immediately upstream of the combustion chamber injection point during Test 1. Grab samples of the
high-Btu liquid waste blend will be collected from a tap in the organic feed recycle line upstream of the
POHC or metals addition point at 15-minute intervals during each test sampling run.
During Test 2, the preparation of POHCs will be similar to the solutions described previously for solid and
sludge waste. The POHC solutions will be metered to the high-Btu liquid waste feed line or the low-Btu
liquid waste feed line, immediately upstream of the combustion chamber injection point, during Test 2.
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D-5b(l)(b)(l)(c) Low-Btu Liquid Waste Feeds (Location 3)
Actual low-Btu liquid wastes will be fed to the kiln and SCC during all three trial burn tests. During Tests
1 and 2, these actual wastes will be spiked with ash-particulate-producing material (copper sulfate) and
will be used as the low-Btu liquid waste feed during all tests. Metals solutions will be fed into the low-Btu
liquid waste feed line immediately upstream of the combustion chamber injection point, during Test 1.
POHCs also will be fed to the low-Btu feed line immediately upstream of the combustion chamber
injection point during Test 2. Grab samples will be collected from a tap in the low-Btu feed line, upstream
of the point where POHCs or metals solutions will be introduced, at 15-minute intervals, during each
replicate test run and will be composited for the run.
D-5b(l)(b)(l)(d) Stack Gas (Locations 4 through 13)
Samples of the particulate, acid gases, metals, POHCs, and PICs from the combustion gas will be
collected from the stack gas at locations 4 through 11 (shown on Figure D-5.4). The stack's sampling
ports will be designed for isokinetic sampling. Detailed procedures for the stack gas sampling methods
are located in Appendix D-5.7. DRE and metal sampling times are presented in Appendix D-5.8.
Hydrogen Chloride, Chlorine, and Particulate Train
The Method 0050 hydrogen chloride, chlorine, and parti culate isokinetic sampling train (Method 0050,
Figure D-5.7) will be used at location 6 to collect hydrogen chloride and chlorine samples during the three
trial burn tests. The total sampling time will be about 3 hours during each replicate sampling run. The
Method 0050 train will be operated concurrently with the other sampling train(s) to sample about 2 cubic
meters of stack gas. The Method 0050 procedure will include measurement of the stack gas flow rate
and temperature according to EPA Methods 1 and 2. About every 30 minutes, integrated samples of the
stack gas will be collected in gas bags for carbon dioxide and oxygen determinations by an Orsat analyzer
according to EPA Method 3. Stack gas moisture content will be determined by EPA Method 4.
[NOTE TO USER: The non-isokinetic hydrogen chloride and chlorine sampling train, Method
0051, may be used if the stack is a dry stack, i.e., contains no water droplets. This, however, will
require sampling paniculate using a separate Method 5 sampling train or performing particulate
analysis using the particulate filter from the MMT. However, the particulate filter from the MMT
may only be used for particulate analysis if sampling is not being done for mercury in the stack
gas.]
Particle-Size Distribution
Samples of stack gases will be collected at location 7 during Test 3 using a [Enter Type] cascade-type
impactor. Typically, these samples will be conducted over a [Enter Minutes]-minute period.
Multi-Metals Train
An MMT (MMT, Figure D-5.5) (40 CFR 266, Appendix IX, or SW-846, Method 0060) will be used at
location 4 for collection of metals from the stack gas during Tests 1 and 3. The sampling train impingers
will be charged with a solution of 5 percent nitric acid and 10 percent hydrogen peroxide to capture
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metals (i.e., antimony, arsenic, barium, beryllium, cadmium, total chromium, lead, mercury, nickel,
selenium, silver, and thallium) and acidified potassium permanganate (composed of 4 percent potassium
permanganate and 10 percent sulfuric acid) to capture any mercury that will be not captured by the nitric
acid and hydrogen peroxide solution. The total sampling time will be about 3 hours during each replicate
sampling run. The MMT will be operated concurrently with the other sampling train(s) to sample about 2
cubic meters of stack gas. The MMT procedure will include measurement of the stack gas flow rate and
temperature according to EPA Methods 1 and 2, carbon monoxide and oxygen determinations by an
Orsat analyzer according to EPA Method 3, and gas moisture content according to EPA Method 4. The
Method 0050 stack measurements of these parameters will be used for the MMT calculations.
[NOTE TO USER: If an Adjusted Tier I limit is satisfactory for mercury, the acidified potassium
permanganate impingers and mercury analysis may be deleted from the sampling and analytical
program. ]
Hexavalent Chromium Sampling Train
A hexavalent chromium sampling train (Figure D-5.6) (Method Cr+6, 40 CFR 266, Appendix IX, or
SW-846, Method 0061) sampling train will be used at location 5 for collection of hexavalent chromium
from the stack gas during Tests 1 and 3. The hexavalent chromium sampling train will be a recirculating
Teflon™ impinger train with a Teflon™ aspirator assembly and other components. The sampling train
impingers will be charged with potassium hydroxide to capture and preserve hexavalent chromium. The
total sampling time will be about 3 hours during each replicate sampling run. The hexavalent chromium
sampling train will be operated concurrently with the MMT to sample about 2 cubic meters of stack gas.
The hexavalent chromium procedure will include measurement of the stack gas flow rate and
temperature according to EPA Methods 1 and 2, carbon monoxide and oxygen determinations by an
Orsat analyzer according to EPA Method 3, and gas moisture content according to EPA Method 4. The
Method 0050 stack measurements of these parameters will be used for the MMT calculations.
[NOTE TO USER: The hexavalent chromium procedure specifies the use of 0.1 normality (N)
potassium hydroxide solution. To preserve the hexavalent chromium, it is critical that the pH of the
impinger solutions not drop below about 10. At a pH of 9 or less, hexavalent chromium is readily
reduced to trivalent chromium. Experience has shown that the use of potassium hydroxide
solutions that are as strong as 5 N may be necessary to ensure that the impinger pH is maintained
sufficiently high.
The hexavalent chromium sampling train uses a Teflon™probe and has Teflon™ components. Use
of the hexavalent chromium sampling train in a hot stack, such as a boiler or a combustion unit
with a dry ARCS, will require use of a water-jacketed sampling probe.}
Volatile Organic Sampling Train
A VOST (see Figure D-5.8) will be used at location 8 during Tests 2 and 3 to collect the POHC
chlorobenzene and volatile PICs from the stack gas on sorbent resin. The VOST will be configured in
accordance with SW-846 Method 0031 with two Tenax™ resin tubes and one Anasorb™ tube in series.
Because the VOST will be a non-isokinetic sampling train, it may share a sampling port with any of the
isokinetic sampling trains with no impact to the operation of either sampling train. The VOST will be
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operated concurrently with the other sampling trains to collect a total of four sets of VOST cartridges for
each test run. Three sets will be targeted for analysis, and the fourth set will serve as a back-up in the
event of tube breakage or damage during shipment and laboratory handling. About 20 liters of stack gas
will be sampled per set of VOST cartridges at 0.5 liters per minute for 40 minutes (slow-VOST
conditions). The VOST cartridges will be capped immediately upon removal from the train, wrapped in
aluminum foil, placed in glass tubes, and sealed. The Method 0050 stack parameter measurements will be
used for the VOST calculations.
Method 0040 Samples
In addition to the volatile organics sampling associated with the VOST during Test 3, other
low-molecular-weight PICs (such as methane, ethane, propane, butane, pentane, hexane, and heptane)
will be measured using SW-846 Method 0040 (see Figure D-5.9). Bag samples of the stack gas collected
in accordance with SW-846 Method 0040 at location 9 will be analyzed using an on-site GC (40 CFR 60,
Appendix A, Method 18). Approximately 30 liters of stack gas will be collected over a 120 minute period.
The Method 0050 stack parameter measurements will be used for the Method 0040 calculations.
Modified Method 5
Three MM5 sampling trains (see Figure D-5.10) will be used at locations 10, 11, and 12 for collecting
semivolatile PICs, PCDDs and PCDFs, PAHs, and unspeciated semivolatile organics from the stack gas
on sorbent resin during Tests 2 and 3. In all cases, the sorbent trap will contain XAD-2 resin to capture
organics, and the impingers will be filled with water. The total sampling time for all MM5 sampling trains
will be about 4 hours during each replicate sampling run. The MM5 sampling trains will be operated
concurrently with the other sampling trains to sample a minimum of 3 cubic meters of stack gas per
sampling train.
The MM5 procedure will include a measurement of the stack gas flow rate and temperature according to
EPA Methods 1 and 2, carbon dioxide and oxygen determinations by an Orsat analyzer according to EPA
Method 3, and gas moisture content according to EPA Method 4. The Method 0050 stack measurements
of these parameters will be used for the MM5 calculations.
The first type of MM5 sampling train, MM5A, will targeted for the POHC naphthalene sample in Test 2
and semivolatile PICs, including PCDDs and PCDFs, in Test 3. The samples will be analyzed for
identifiable semivolatile POHC and PICs by SW-846 Method 8270 and PCDDs and PCDFs by SW-846
Method 8290. The MM5A sampling train will be operated and recovered according to the procedures
described in SW-846 Methods 0010 and 3542 in Test 2 and Methods 0010, 3542, and 0023A in Test 3.
The QAPP (see Appendix D-5.1) provides descriptions of the data quality objectives (DQO) and
sampling surrogates for this train.
The second MM5 sampling train, MM5B, will be used to collect samples to determine the unspeciated
mass of semivolatile and nonvolatile organics during Test 3. The front and back halves of this sampling
train will be analyzed for total chromatographable organics (TCO) by GC and for non-chromatographable
nonvolatile organics gravimetrically. The QAPP (see Appendix D-5.1) provides a description of the
DQOs and surrogates to be used in this MM5 sampling train.
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The third MM5 sampling train, MM5C, will be used to collect stack gas samples for analysis for PAHs,
according to the procedures described in California Air Resources Board (CARB) Method 429. Analysis
of the extracts for PAHs will be performed using modified SW-846 Method 8290 and CARB-429 as
guidance.
Method 0011
The stack gas will be sampled at location 13 and analyzed for aldehyde and ketone PICs using a Method
0011 sampling train (see Figure D-5.11) during Test 3. Aldehydes and ketones are not quantified
adequately by other means because the analytical process can result in its degradation to other PICs. The
train will be operated isokinetically because the stack gas contains water droplets in which aldehydes and
ketones are soluble.
The Method 0011 sampling train will consist of a series of four impingers. The first and second impingers
will contain 100 to 200 milliliters (mL) each of a cleaned 2,4-dinitrophenylhydrazine (DNPH) solution,
while the third impinger will serve as a moisture knockout. The fourth impinger will contain a
pre-weighed amount of indicating silica gel.
The Method 0011 sampling train will be used at location 8 after the completion of hydrogen chloride,
chlorine, and particulate sample collection using the Method 0050 sampling train. The Method 0011
sampling train will be operated for about 2 hours during Test 3, concurrently with the other sampling
trains, in order to sample about 90 cubic feet of stack gas. In the Method 0011 procedure, the stack gas
flow rate and temperature are measured according to EPA Methods 1 and 2; carbon dioxide and oxygen
are determined by an Orsat analyzer according to EPA Method 3, and gas moisture content will be
determined according to EPA Method 4. The Method 0050 stack measurements of these parameters will
be used for the Method 0011 calculations.
D-5b(l)(b)(l)(e) Incinerator Ash (Location 14)
For tests during which solid wastes will be burned, grab samples will be collected from the ash discharge
every 30 minutes. Large and obviously inert pieces of ash will be discarded from each sample.
D-5b(l)(b)(l)(f) Scrubber Slowdown (Location 15)
Grab samples will be taken from a tap in the quench liquid discharge line. Before the test, two grab
samples will be collected 30 minutes apart and composited to provide a baseline sample. Grab samples
will be taken every 30 minutes during each replicate sampling run.
D-5b(l)(b)(l)(g) Process Water (Location 16)
Grab samples will be collected from a supply line tap every 60 minutes during each replicate sampling run.
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D-5b(l)(b)(l)(h) Caustic Solution (Location 17)
One sample will be taken from the feed tank after the batch is prepared and mixed. Caustic solution
samples will be retained (archived) for analysis, if needed.
D-5b(l)(b)(l)(i) Combustion Gas (Location 18)
A CEM system will be installed in the duct to the stack in order to monitor the carbon monoxide and
oxygen concentration of the incineration combustion gas. The carbon monoxide monitor will be an NDIR
device. The oxygen monitor will be a paramagnetic system. Details of the equipment installed are
included in Appendix D-5.3.
D-5b(l)(b)(2) Analytical Procedures
The analyses planned for the trial burn samples are listed in Table D-5.4. The standard methods cited for
density, TDS, TSS, viscosity, pH, heat content, metals content, ash content, elemental analysis, organic
chlorine, stack gas oxygen, carbon dioxide, and particulate are EPA-approved methods that require no
further explanation in this plan. Details on recovering metals, POHCs, PCDDs and PCDFs, and volatile
and semivolatile PICs from the samples for analysis follow.
D-5b(l)(b)(2)(a) Solid and Sludge Waste Feed and Incinerator Ash
The solid waste feed and ash samples will be screened to remove obvious pieces of inert material. For
POHC recovery and analysis, aliquots of the solid waste feed and ash samples will be dispersed in
methanol and analyzed by GC/MS procedures. Aliquots of well-mixed solid waste feed samples will be
prepared according to EPA procedures and analyzed for antimony, arsenic, barium, beryllium, cadmium,
total chromium, lead, nickel, selenium, silver, and thallium by SW-846 Method 6010, inductively coupled
argon plasma spectroscopy (ICP), or Method 6020, ICP/mass spectrometry (ICP/MS) and cold vapor
atomic absorption (CVAA) for mercury. Aliquots of well-mixed ash samples also will be prepared
according to EPA procedures and analyzed for metals by ICP or ICP/MS and CVAA.
D-5b(l)(b)(2)(b) High-Btu Liquid Waste Feed
Aliquots of well-mixed samples will be diluted in an appropriate solvent for analysis using GC/MS
procedures for POHCs. Aliquots of well-mixed samples will be prepared according to EPA procedures
and analyzed for antimony, arsenic, barium, beryllium, cadmium, total chromium, lead, nickel, selenium,
silver, and thallium by ICP or ICP/MS and CVAA for mercury.
D-5b(l)(b)(2)(c) Process Water. Caustic Solution. Low-Btu Liquid Waste Feed, and APCS
Scrubber Slowdown
For POHC analysis, all samples will be prepared and analyzed by GC/MS analyses. Aliquots of
well-mixed low-Btu liquid waste samples will be prepared according to EPA procedures and analyzed for
antimony, arsenic, barium, beryllium, cadmium, total chromium, lead, nickel, selenium, silver, and thallium
by ICP or ICP/MS, and CVAA for mercury. Aliquots of well-mixed APCS purge- and process-water
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samples will be prepared according to EPA procedures and analyzed for metals by ICP or ICP/MS and
CVAA. Caustic solution will not be analyzed for metals.
D-5b(l)(b)(2)(d) Method 0050 Hydrogen Chloride. Chlorine, and Particulate Sampling Train
Impingers
The particulate filter and front-half rinses from the Method 0050 sampling train will be dried and weighed
by EPA Method 5 to determine particulate emissions. The sulfuric acid and sodium hydroxide impinger
solutions will be analyzed separately for chloride ion by SW-846 Method 9057 (ion chromatography). The
corresponding concentrations of hydrogen chloride and chlorine will be calculated and reported for the
sampling train.
D-5b(l)(b)(2)(e) Particle-Size Distribution
The particle-size distribution will be determined gravimetrically by recovering and weighing the contents
of each of the [Enter Number] stages of the [Enter Type] cascade impactor.
D-5b(l)(b)(2)(f) Method 0060 Multi-Metals Train Samples
The filter will be digested by SW-846 Method 0060. Front half rinses will be digested by SW-846 Method
3050. For the metals antimony, arsenic, barium, beryllium, cadmium, total chromium, lead, nickel,
selenium, silver and thallium, the front half rinses and the particulate filter digestion solution will be
combined and analyzed by ICP or ICP/MS, while the 5 percent nitric acid and 10 percent hydrogen
peroxide impingers will be prepared by SW-846 Method 3010 and analyzed by ICP or ICP/MS for
mercury. CVAA will be used to analyze for mercury in the combined front-half rinse and filter digestion
conditions and in the impingers. The 4 percent potassium permanganate and 10 percent sulfuric acid
impingers and the 8N hydrochloric acid impinger rinses will be analyzed separately by CVAA for
mercury. The front-half and the nitric acid and 10 percent hydrogen peroxide impinger analyses results
will be added together to determine the total metals emission rate for the ICP or ICP/MS metals. The
front-half, the nitric acid and 10 percent hydrogen peroxide impinger, the 4 percent potassium
permanganate and 10 percent sulfuric acid impinger, and the hydrochloric acid glassware rinse analysis
results will be added together to determine the total mercury emission rate.
D-5b(l)(b)(2)(g) Method 0061 Hexavalent Chromium Train Samples
The rinses and impinger solutions that were collected and filtered in accordance with the hexavalent
chromium procedures, are refiltered through a 0.45-micron filter before analysis by ion chromatography
with a post-column reactor (IC/PCR). The results will be used to determine the hexavalent chromium
emission rate. The total chromium emission rate will be determined using the Method 0060 samples.
D-5b(l)(b)(2)(h) VOST Sorbent Tubes
The Tenax™ and Anasorb™ sorbent tubes will be recovered from the sampling train, desorbed thermally
to an analytical trap and analyzed by GC/MS according to the protocol detailed in Method 5041. VOST
sorbent tubes will be analyzed for the POHC chlorobenzene and the EPA contract laboratory program
(CLP) volatile target compound list (TCL) and the 20 largest unidentified GC/MS peaks (volatile PICs).
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The mass of the low-molecular PIC concentrations will be reported as total nanograms of organics per
cubic meter (rjg/m3). Next, this sum will be subtracted from the sum of the masses of all volatile organics
determined using the VOST, also reported in terms of (rjg/m3). The difference will be reported as
unspeciated mass. This unspeciated mass will be added proportionally to the concentrations of specific
volatile organics determined from the VOST samples.
D-5b(l)(b)(2)(i) MM5A Samples
The particulate filter and front-half rinses (acetone and methylene chloride only) recovered from the
MM5A sampling train will be Soxhlet-extracted using methylene chloride for 18 hours (SW-846 Method
3540). Semivolatile surrogates (Tests 2 and 3) and dioxin and furan isotope dilution internal standards
(Test 3 only) will be added to the samples at this stage of the sample preparation, as described in the
QAPP (see Appendix D-5.1).
The Test 2 extract samples will be analyzed for the semivolatile POHC naphthalene by SW-846 Method
8270.
In Test 3 only, a subsequent Soxhlet extraction will be conducted using toluene. After which a 50 percent
portion of the methylene chloride extract will be analyzed by SW-846 Method 8270 for semivolatile
POHCs and PICs. The remaining 50 percent of the methylene chloride extract will be combined with 50
percent of the toluene extract and analyzed by Method 8290 for PCDDs and PCDFs.
The XAD-2 resin tube and the solvent rinse of the back-half filter holder and coil condenser samples will
be handled in the same manner as the front-half samples, except that they will be prepared and analyzed
as a separate sample and will not be spiked with dioxin and furan surrogates because these surrogates will
have been applied to the XAD-2 resin before the trial burn.
A 1-liter portion of the back-half composite (impinger contents and glassware rinses) will be liquid-liquid
extracted using methylene chloride only, according SW-846 Method 3510. Sequential base-neutral, acid-
extractable extractions will be conducted. These extracts will be combined, reduced to a final volume of
5 mL and analyzed by Method 8270 for semivolatile POHCs and PICs.
D-5b(l)(b)(2)(j) MM5B Samples
The front half composite (XAD-2 resin, solvent probe rinse, particulate filter, and connecting glassware
rinses) from the MM5B sampling train will be Soxhlet-extracted using methylene chloride. Extraction will
proceed for 18 hours. Semivolatile unspeciated mass surrogates will be applied to the train components,
as described in the QAPP (see Appendix D-5.1). The composite sample will be liquid-liquid extracted
and volume-reduced in the same manner described for MM5A samples.
The MM5B samples will be analyzed in two parts: (1) for moderate boiling compounds (100 °F to 300 °F)
by capillary column GC and flame ionization detector (FID), and (2) high boiling compounds (greater than
300 °F) by the gravimetric (GRAY) method.
D-5b(l)(b)(2)(k) MM5C Samples
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The MM5C samples will be collected and recovered in the same manner as described above for the
Test 2 MM5A samples, except as follows:
• The front-half rinse, resin and back-half rinse, and condensate samples will be prepared
and analyzed as three separate samples.
• PAH-specific sampling surrogates, isotope dilution internal standards, and recovery
standards will be applied.
• Analysis of the extracts will be performed by high-resolution GC/high-resolution MS using
a modification of SW-846 Method 8290 and CARB 429 as guidance.
D-5b(l)(b)(2)(l) Method 0011 Samples
The Method 0011 sampling train components will be analyzed by SW-846 Method 8315 for aldehydes and
ketones. The sampling train components are analyzed in two parts: (1) the first impinger and (2) the
second and third impingers. The impingers are analyzed in two parts in order to evaluate analyte
breakthrough. The separate analyses will be added together and reported as a total catch for the
sampling train.
D-5b(l)(b)(2)(m) Method 0040 Samples
The Method 0040 bag sample will be analyzed for organics with boiling points less than 100 °C using a
field GC/FID. The condensate sample collected from the sampling train will be placed in a 40-mL septum
vial and analyzed for volatile organics using purge and trap GC/FID SW-846 Methods 5340 and 0040.
D-5b(l)(c) Trial Burn Schedule [40 CFR 270.62(bK2Kiv)1
The trial burn schedule is summarized in the following sections.
D-5b(l)(c)(l) Schedule
The trial burn will begin after [Enter Company Acronym] has received approval for the Part B trial burn
plan and has successfully completed startup, shakedown, and pretesting of the incinerator. The typical
test run schedule for the trial burn is shown in Table D-5.13. The test will span about 11 days: 1 day for
setup, 9 days of testing, and 1 day for cleanup.
D-5b(l)(c)(2) Duration of Each Trial Burn Test
Three trial burn tests are planned, each consisting of three replicate sampling runs. One run is expected
to be completed each day. Actual sampling time during each sampling run will last at least 8 hours. The
incinerator will be fed test wastes at least 1 hour before each sampling run to establish steady operation at
process test conditions. Therefore, total test time each day will be at least 9 hours. Assuming minimal
interruption of incinerator operation, the incinerator can be expected to operate on test waste feeds for up
to [Enter Hours] hours per day for about 9 days.
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D-5b(l)(c)(3) Quantity of Waste To Be Burned
Test waste liquids and solids will be fed to the incinerator for an estimated [Enter Product of Hours per
Day from Previous Paragraph Multiplied by 9 Days} hours. At the feed rates specified for the tests
in Table D-5.3, the quantities of high-Btu liquids, low-Btu liquids, and solids required for the trial burn will
be [Enter Quantity], [Enter Quantity], and [Enter Quantity], respectively. Allowing a 25 percent safety
factor, the consumption of test feed materials will be expected to be about [Enter Volume] gallons of
high-Btu liquid wastes, [Enter Volume] gallons of low-Btu liquid wastes, [Enter Weight] tons of solid
wastes.
In Tests 1 and 2, the test waste liquids and solids will be actual wastes spiked with POHCs, organic
chlorine, metals, and ash, as appropriate for the test condition. In Test 3, only actual wastes will be
burned. Spiking will not occur during Test 3. Descriptions of the spiking compounds required for this trial
burn are provided in Table D-5.14. The estimated quantities of POHC, organic chlorine, metals, and ash-
spiking materials required for the trial burn, including a 25 percent safety factor, will be as follows:
POHC
chlorobenzene, [Enter Quantity]
carbon tetrachloride, [Enter Quantity]
naphthalene, [Enter Quantity]
Organic Chlorine
Perchloroethylene, [Enter Quantity]
Metals
[Enter list of metal compounds], [Enter Quantities]
Ash
copper sulfate, [Enter Quantity]
The unit will be expected to reach equilibrium at test conditions with normal waste or auxiliary fuel and
will be switched to the test waste 1 hour before the start of each sampling run. POHC, ash, metals and
organic chlorine source chemical spiking will be started concurrently with the test waste feed. A surplus
of test waste will be prepared in case operational problems require a longer testing period. After the trial
burn program is completed, all remaining wastes or spiking materials will be fed to the incineration system
until combusted, used in the [Enter Company Acronym] facility, or returned to the vendor.
D-5b(l)(d) Test Protocols [40 CFR 270.62(bK2Kv)1
The test protocols are summarized in the following sections.
D-5b(l)(d)(l) Waste Characterization
The hazardous wastes to be incinerated in the rotary kiln are discussed in Section C and in the
introduction to Section D-5 of the permit application. Table D-5.2 summarizes the chemical and
thermodynamic property parameters for the blended wastes to be incinerated during normal operation and
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the trial burn. The information in Table D-5.2 is based on the requirements of 40 CFR 270.62(b)(2)(I)
and the Guidance Manual for Hazardous Waste Incinerator Permits (EPA 1983).
D-5b(l)(d)(2) POHC Selection Rationale
According to the EPA guidance, the selection of POHCs should be based primarily on three factors:
(1) heat of combustion, (2) thermal stability ranking, and (3) presence in, or representativeness of, the
actual wastes to be burned. Consistent with this guidance, [Enter Company Acronym] used the
following three criteria to select the POHCs for this trial burn:
• At least one POHC must be present as an Appendix VIII constituent in the actual
wastes.
• At least one POHC must have a high ranking as a Class 1 compound on the University of
Dayton thermal stability ranking list.
• At least one POHC must be combustible at a low heat.
In assessing representativeness and appropriateness of compounds for POHC selection, current waste
profile data were reviewed for those Appendix VIII compounds that will be the most prevalent in the
waste available for incineration. Based on this review, carbon tetrachloride was determined to be present
in the actual waste. Given that carbon tetrachloride also is combustible at a low heat, the compound was
selected as a POHC.
Chlorobenzene and naphthalene were selected as the second and third POHC, primarily because of their
high rankings as Class 1 compounds on the University of Dayton thermal stability index.
Because [Enter Company Acronym] feels it is important to obtain as flexible a permit as possible, [Enter
Company Acronym] proposes to use actual wastes spiked with high-ranking Appendix VIII constituents,
naphthalene, chlorobenzene, and carbon tetrachloride as the trial burn POHCs.
Because the POHCs include Class 1 compounds from the University of Dayton list and another
compound that is combustible at low heat, the trial burn should provide a significant challenge to the
incineration system's ability to destroy all of the constituents in the wastes it will burn. It is anticipated
that the final permit will allow for incineration of all wastes that meet the profiles considered for POHC
selection. Accordingly, successful incineration of these compounds at DREs of 99.99 percent or greater
during the trial burn tests should result in a permit that allows incineration of all Class 1 or lower
compounds.
D-5b(l)(d)(3) Trial Burn Protocol and Operating Conditions
The trial burn will consist of three tests. All three trial burn tests will include triplicate sampling runs. A
total of 9 sampling runs will be conducted.
Test 1 will be conducted to demonstrate worst-case metals emissions performance under the following
conditions:
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• Maximum rotary kiln temperature
• Maximum SCC temperature
• Maximum ash content in low-Btu liquid waste content
• Maximum total organic chlorine feed rate in the solid feed and in the liquid waste feed
• Maximum metals feed rates to the kiln and SCC (Tier III metals spiked to the rotary kiln
solid and sludge wastes and the SCC high- or low-Btu liquid waste feed line)
• Minimum venturi scrubber pressure drop, minimum venturi scrubber pH, minimum WESP
liquid flow rate, minimum WESP power input, and minimum scrubber liquid blowdown
rate
Test 2 will be conducted to demonstrate the DRE of the rotary kiln incineration system under the
following conditions:
• Maximum solid waste feed rate
• Maximum rotary kiln high-Btu liquid waste feed rate
• Maximum SCC high-Btu liquid waste feed rate
• Maximum rotary kiln low-Btu liquid waste feed rate
• Maximum SCC low-Btu liquid waste feed
• Maximum ash content in low-Btu liquid waste content
• Minimum rotary kiln temperature
• Minimum SCC temperature
• Maximum combustion gas velocity
• Maximum organic chlorine content in the solid and liquid waste feed streams
• POHCs fed to the rotary kiln in solids and low-Btu liquid waste feeds
POHCs fed to the SCC in low-Btu liquid waste feeds
• Minimum venturi scrubber pressure drop, minimum venturi scrubber pH, minimum WESP
liquid flow rate, minimum WESP power input, and minimum scrubber liquid blowdown
rate
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Test 3 will be conducted to develop emissions data needed to support the performance of direct and
indirect risk assessments. Test will be conducted under the following operating conditions:
• Normal solid waste feed rate
• Normal rotary kiln high-Btu liquid waste feed rate
• Normal SCC high-Btu liquid waste feed rate
• Normal rotary kiln low-Btu liquid waste feed rate
• Normal SCC low-Btu liquid waste feed
• Normal rotary kiln temperature
• Normal SCC temperature
The three trial burn tests will be performed to demonstrate and obtain permit limits that have the flexibility
to accommodate different types of wastes feed and process conditions. The objectives of the trial burn
will be as follows:
• Demonstrate that metal emission rates at metal feed rates proposed for the solid and
sludge and liquid waste feeds (at maximum rotary kiln temperature during Test 1) are in
compliance with Tier III limits.
• Demonstrate 99.99 percent or greater POHC DRE during maximum combined solid and
liquid waste feed rates and minimum rotary kiln and SCC temperatures during Test 2.
• Demonstrate hydrogen chloride emissions and removal efficiency during Test 2 with the
highest chlorine feed rate successfully demonstrated (less than 4 pounds per hour or
99 percent removal) as the permitted maximum.
• Determine that particulate emissions during all tests are less than 0.08 gr/dscf corrected
to 7 percent oxygen.
• Demonstrate maximum combustion gas velocity during Test 2.
• Determine the metals, PCDDs and PCDFs, volatile and semivolatile PIC, hydrogen
chloride, chlorine, and parti culate matter emissions in the stack gas during Test 3.
As recommended in the BIF Technical Implementation Document (EPA 1992), one run during each test
will capture all or part of a boiler soot blowing event. Parti culate emissions from trial burn runs (including
a soot blow) will be corrected for soot blowing, as follows:
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(ESBR~ ENO
SBR~ NOSB
x _I ] + ENOSB
where
'SBR
MsTi
A
B
S
R
Cn
Ct
"OSB
emission rate
average E of samples collected during test run with soot blowing corrected to
7 percent oxygen
average E of samples collected during test runs without soot blowing corrected to
7 percent oxygen concentration
hours of soot blowing during the test run with soot blowing
hours without soot blowing during the test run with soot blowing
normal number of hours of soot blowing per 24 hours
normal number of hours of operation per 24 hours
normal number of operating hours between cleaning cycles
number of operating hours between cleaning cycles during test
D-5b(l)(d)(4) Waste Constituents
The anticipated compositions of the actual wastes to be burned during the trial burn are summarized in
Table D-5.2. Under all three tests, actual wastes will be burned. During Test 1, the actual wastes will be
spiked with ash, organic chlorine, and metals. During Test 2, the actual wastes will be spiked with
POHCs, ash, and organic chlorine. No spiking will occur in Test 3. The actual wastes will be spiked with
chlorobenzene, naphthalene, and carbon tetrachloride as POHCs; perchloroethylene as a source of
organic chlorine; copper sulfate as a source of ash; and compounds of arsenic, beryllium, cadmium, and
chromium. The composition of the spiking compounds and their targeted spiking rates are provided in
Table D-5.14. Calculations of the quantities of spiking compounds required are provided in Appendix
D-5.4. Details on the spiking program follow.
D-5b(l)(d)(4)(a) Solid and Sludge Wastes
All three trial burn tests will include the incineration of solid and sludge wastes. Perchloroethylene and
solutions of the metal salts described in Table D-5.14 will be metered continuously to the solid waste feed
auger just upstream from the kiln feed chute during Test 1. Perchloroethylene and POHCs will be
continuously metered to the solid waste feed in the same location during Test 2. Spiking solution flow
meters will be equipped with data loggers that will record and integrate flow rates continuously. Drawing
[Enter Drawing Number] shows the spiking location and hardware (see Appendix D-5.2).
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D-5b(l)(d)(4)(b) High-Btu Liquid Wastes
During all three tests, high-Btu liquid wastes will be fired in the rotary kiln and SCC burners. To maintain
a steady flame in the burners, the liquid wastes fired must be well-blended and have a consistent heat
content. Metal spiking solutions, as described in Table D-5.14, will be metered into the high-Btu liquid
waste feed manifold just upstream from the waste burners during Test 1. During Test 2,
perchloroethylene and POHCs will be metered to the incineration system by injecting them into the
high-Btu waste feed manifold at the same location as the metal spiking solutions. Spiking solution flow
meters will be equipped with data loggers that will record and integrate flow rates continuously. Drawing
[Enter Drawing Number] shows the spiking location and hardware (see Appendix D-5.2).
D-5b(l)(d)(4)(c) Low-Btu Liquid Wastes
Low-Btu liquid waste will be injected into the kiln and the SCC during all three tests. This waste stream
will be spiked with ash-particulate-producing material, such as copper sulfate or a similar material, during
Tests 1 and 2. The copper sulfate will be added to the low-Btu liquid wastes as an ash surrogate to
demonstrate the particulate removal capability of the APCS. The dissolved copper sulfate will not be
removed by the waste feed line filters and will produce fine particulate when atomized into the
combustion gas. The copper sulfate particulate will present a significant particulate removal challenge to
the APCS. The quantity of ash spiking material fed to the combustion chambers will be tracked by adding
measured quantities of copper sulfate to measured volumes of low-Btu liquids in a mixing tank and
monitoring the feed rate of low-Btu liquids to the kiln and SCC, as described in Section D-5b(l)(a)(12).
The mixing tank will be agitated at all times to dissolve the ash material.
Perchloroethylene and metals solutions, as described in Table D-5.14, will be metered into the low-Btu
liquid waste feed line during Test 1. Perchloroethylene will be metered into the low-Btu liquid waste feed
during Test 2. Spiking solution flow meters will be equipped with data loggers that will record and
integrate flow rates continuously. Drawing [Enter Drawing Number] shows the spiking location and
hardware (see Appendix D-5.2).
Chlorobenzene, naphthalene, and carbon tetrachloride will be received in sealed 55-gallon drums. The
chlorobenzene and carbon tetrachloride will be pumped into the solid waste and liquid waste using
variable-speed chemical-metering pumps. Micromotion mass flow meters located in the pump discharge
lines will monitor the chlorobenzene flow rates continuously. The outputs from the flow meters will be
linked to a PC-based DAS that will support continuous recording of the chlorobenzene flow rates.
Naphthalene will be mixed batch-wise with mineral oil at a ratio of [Enter Number] to [Enter Number] in
a [Enter Gallons] -gallon portable tank equipped with an agitator. Quantities of naphthalene and mineral
oil added to each batch will be weighed to the nearest 0.1 pound using calibrated scales. Batch sizes of
[Enter Gallons] gallons will be prepared for each run. Typically, the batches will be prepared the day
before each run. The naphthalene and mineral oil solutions will be metered into the solid and liquid wastes
in the same manner as the chlorobenzene.
Perchloroethylene and metals spiking solutions will be received in sealed 55-gallon drums. The
perchloroethylene and metals spiking solutions will be metered into the liquid wastes in the manner
described previously for chlorobenzene.
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Copper sulfate will be received in 70 pound bags. Weighed amounts of copper sulfate will be added to
measured volumes of low-Btu liquids in an agitated 500-gallon blend tank to produce a spiked waste with
a known concentration of ash. The flow rate of the blended low-Btu liquid to the combustion chambers
will be monitored continuously with Micromotion mass flow meters.
D-5b(l)(d)(5) Combustion Temperature Ranges
The anticipated combustion chamber temperatures for the tests will be as indicated in Table D-5.3.
Based on experience with similar incineration systems, occasional excursions of ±50 °F will be possible in
the rotary kiln. If such temperature fluctuations occur in the kiln, the SCC will be likely to experience a
corresponding temperature variation.
D-5b(l)(d)(6) Waste Feed Rates
The planned waste feed rates for the trial burn tests are summarized in Table D-5.3.
D-5b(l)(d)(7) Combustion Gas Velocity Indicator
The measured indicator of combustion gas velocity during the trial burn will be the combustion gas flow
rate as measured by the stack-installed combustion gas velocity indicator.
D-5b(l)(d)(8) Waste Feed Ash Content
The liquid wastes that will be burned in the incineration system contain very little ash. To establish a
permit condition that allows liquid feed streams with high ash contents, an inert particulate material copper
sulfate will be added to the low-Btu liquid wastes before they are fed to the rotary kiln and SCC, as
described in Sections D-5b(l)(c)(3) and D-5b(l)(d)(4).
The solid wastes used will have an ash content greater than 85 percent. No ash spiking of the solid waste
will be necessary.
D-5b(l)(d)(9) Auxiliary Fuel
Natural gas will be used as required to maintain temperatures at maximum thermal duty in both the
primary and secondary combustion chambers. Natural gas also will be used as pilot burner fuel for both
the rotary kiln and the SCC.
D-5b(l)(d)(10) Organic Chlorine Content
The anticipated organic chlorine content of the trial burn feed material is shown in Table D-5.2. Waste
feeds will be spiked with organic chlorine, as described in Table D-5.14. Assuming that 100 percent of
the organic chlorine fed to the combustion chambers converts to hydrogen chloride, the maximum
hydrogen chloride entering the APCS of the rotary kiln during the trial burn will be about [Enter Mass]
pounds per hour.
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D-5b(l)(d)(ll) Metals
The proposed Tier III metals (arsenic, beryllium, cadmium, and chromium) feed rates are shown in
Table D-5.3. Adjusted Tier I feed rate limits are proposed for antimony, barium, lead, mercury, nickel,
selenium, silver, and thallium.
D-5b(l)(e) Pollution Control Equipment Operation [40 CFR 270.62(bK2KvQ1
Pollution control equipment is described in Section D-5b(l)(a)(10). The anticipated operating conditions
for the trial burn are summarized in Table D-5.3. Fluctuations in APCS temperatures, flow rates, and
pressures are expected to occur during the trial burn.
D-5b(l)(f) Shutdown Procedures [40 CFR 270.62(bK2Kvim
The AWFCO system and parameters for shutting down the waste feeds are described in Section
D-5b(l)(a)(8). AWFCOs for Group A and continuously monitored and interlocked Group C parameters
will be in operation during the trial burn. During the trial burn, the system's operation will be monitored
closely by the system operators. If the operation of the system during the trial burn should deviate
significantly from the desired range of operation or become unsafe, the operators will manually shut off
waste feeds to the system.
In the event of a major equipment or system failure, it may be necessary to shut down the combustion and
APCSs completely. A shutdown of this type will be performed in strict accordance with the facility's
standard operating procedures. Shutdown will be the reverse of the startup process described in Section
D-5b(l)(a)(13) and will involve shutting down subsystems in the following order:
• Rotary kiln
sec
• Heat recovery boiler
APCS
• Utilities
D-5b(l)(g) Incinerator Performance [40 CFR 270.62(a)1
[Note to User: In this section, a rationalization of the operating conditions selected for the trial
and risk burns should be provided. In particular, this section should demonstrate that the
performance standards of 40 CFR 264.343 will be met while operating under the proposed test
conditions.}
[Enter Company Acronym] believes that the conditions specified in Section D-5b(l)(d) for the trial burn
will be adequate to meet the performance standards of 40 CFR 264.343 while firing any combination of
feed materials for the following reasons:
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• Our experience with identical kilns and SCC burning similar liquid and solid wastes under
similar operating conditions at [Identify Locations of Similar Plants] shows that the
expected DRE will exceed 99.99 percent. In trial burn tests conducted at [List Facilities
with Similar Combustion andAPCSs], DREs of [List DemonstratedDREs] were
achieved.
• Our experience with identical kilns and SCC burning similar liquid and solid wastes under
similar operating conditions at [Identify Locations of Similar Plants] suggests that the
hydrogen chloride and particulate emissions will be less than 4 pounds per hour and 0.08
grains per dry standard cubic foot, respectively. In trial burn tests conducted at [List
Facilities with Similar Combustion andAPCSs], hydrogen chloride emissions of [List
Hydrogen Chloride Emissions] were measured. During these same tests, particulate
emissions of [List Particulate Emissions] were measured. In all of the cases, emissions
of hydrogen chloride and particulate were well below the respective performance
standards.
• Thermodynamic and finite element modeling performed by [List Engineering
Companies and Vendors] demonstrates that DRE will exceed 99.99 percent and
hydrogen chloride and particulate emissions will be below the performance standards of 4
pounds per hour and 0.08 grains per dry cubic foot.
• Maximum uncontrolled emissions of hydrogen chloride and particulate during testing have
been predicted to be [Present Estimates of Uncontrolled Emissions]. Certifications and
other information prepared by the vendors of the APCS equipment indicate that the
aggregate removal efficiencies of the APCS equipment for hydrogen chloride and
particulate will be [Provide Removal Efficiencies], suggesting maximum controlled
emissions of [Provide Estimates of Maximum Controlled Emissions]. These controlled
emissions are well below the performance standards.
• The range of operating conditions planned for the trial burn period are within the design
envelope of the combustion and APCSs (refer to the design basis in Table D-5.7).
• The combustion and APCSs will be tightly controlled by the DCS, and AWFCO systems
will be operational at all times during the trial burn period.
D-5b(2) NEW INCINERATOR CONDITIONS [40 CFR 270.62(a)]
[NOTE TO USER: Section D-5b(2) applies only to new units. Startup and shakedown should
proceed in a disciplined manner, according to a written plan. During startup, the system will be
tested while firing auxiliary fuel only in order to verify operational readiness for hazardous
wastes. Once successful startup testing has been completed, shakedown testing using hazardous
waste feeds will be performed to optimize system operations prior to the trial burn. The initial
shakedown period will be limited to 720 hours of operation while firing hazardous waste.
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Pretesting during the shakedown period is discretionary but recommended. A pretest may not be
warranted for an existing or interim status unit that has been previously tested and in which the
owner/operator has confidence in the unit's ability to meet the trial burn objectives. The pretest,
however, being a dry run for the trial burn, will aid the identification of any testing logistical
problems or sampling and analytical problems before the formal trial burn. Correction of these
problems will minimize the chances that a trial burn will have to be repeated, a costly and
potentially publicly embarrassing situation. The areas of chief concern are potential problems in
analyzing the waste feed matrices or stack sampling and analysis for POHCs, PICs, and metals.
Another and possibly more important reason for performing a pretest is that the pretest data can be
used as a basis for establishing the interim operating limits for the unit. Otherwise, the regulatory
authorities may limit the interim operation of the unit to limits substantially less than the trial burn
demonstrated limits.}
After construction, [Enter Facility Owner} will perform instrument debugging, instrument calibration,
process control simulations, and related preliminary systems testing before startup on auxiliary fuel. Once
this preliminary systems testing is complete, startup and shakedown will commence sequentially, as
described in Sections D-5b(2)(a) and (b). During the startup/shakedown period, the entire system will be
thoroughly tested to verify that the entire system conforms to design requirements and performs in a safe,
consistent, and predictable manner.
Preliminary systems, startup, and shakedown testing will proceed in accordance with the [Enter
Company Acronym} startup plan (see Appendix D-5.5). The startup plan defines all activities,
methodologies, standards, startup criteria, and compliance actions associated with the testing of the
system. The startup plan addresses 15 functional areas of system design, construction, and operational
readiness, as defined below:
1. Design
2. Construction
3. Organization and staffing
4. Standard operating procedures
5. Personnel and process safety
6. Environmental protection and permitting
7. Waste characterization and certification
8. Configuration management
9. Maintenance and monitoring
10. Fire protection
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11. Emergency preparedness
12. Training
13. Test requirements and acceptance
14. Information management
15. Nonconformance and issue management
As stated in the startup plan, operating conditions will be maintained within the envelope of anticipated
final operating limits defined in Table D-5.5 throughout the startup/shakedown period. These limits on
operating conditions will be based on good engineering practice and experience with similar hazardous
waste incineration systems and, as such, should comply with the requirements of 40 CFR 270.62(a)(l).
All of the limits on operating conditions specified in Table D-5.5 are based upon the anticipated
performance of the new incineration system. Because the suggested conditions are engineering
estimates, the numerical values should be considered to be approximate values to be confirmed or
modified as design, startup/shakedown, and pretesting progresses.
During the startup/shakedown period, hazardous wastes will not be fed to the system unless the conditions
described above are satisfied. The flow of hazardous waste to the incinerator will be stopped if operating
conditions deviate from the established limits. An AWFCO system, described in Section D-5b(l)(a)(8),
will be in operation at all times during the incineration of hazardous wastes. AWFCO settings during the
startup/shakedown period will be those specified in Table D-5.6. Individual AWFCOs for those
parameters that may cause total incinerator shutdown (such as auxiliary fuel, burners, or induced draft
fan) may be bypassed momentarily during routine calibrations.
D-5b(2)(a) Startup
The objectives of the startup period are as follows:
• [List Objectives of Startup Documented in the Startup Plan]
The startup phase will be used to test the rotary kiln incineration system subsystems, as appropriate,
without the introduction of actual hazardous wastes into the incineration systems. The startup test will be
performed by firing nonhazardous solid wastes and fossil fuels only. Fresh process water will be used in
the scrubber system.
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During the first startup tests, the natural gas burners in the rotary kiln will be fired to cure the refractories
and check out the prime air mover and system instrumentation under actual temperatures and pressure.
Next, [Enter Facility Operator] plans to feed nonhazardous surrogate solid wastes into the rotary kiln to
check out the solid waste feed system, the ash handling system, the APCS, and the process control
system. The SCC will be operated on natural gas during this test. During this test, the feed rate, heat
value, and moisture content of the solid waste will be adjusted to simulate the full range of expected solid
waste operation.
When the startup objectives have been satisfied, the startup period will be completed, and the shakedown
phase will commence.
D-5b(2)(b) Shakedown
The objectives of the shakedown are as follows:
• [List Objectives of Shakedown Documented in the Startup Plan]
During the shakedown phase, actual hazardous wastes will be introduced into incineration system in
accordance with 40 CFR 264.344(c)(l) to bring the unit to a point of operational readiness for the trial
burn. [Enter Company Acronym] will provide EPA Region [Enter Region] and [Enter State Agency]
with a 2-week notice before introducing hazardous wastes into the system.
This phase will take up to 720 hours of hazardous waste operation. If [Enter Company Acronym]
determines that additional time will be necessary to ensure operational readiness before the trial burn, an
extension of up to 720 additional hours of operating time will be requested.
During the 720-hour startup/shakedown period, [Enter Company Acronym] will conduct pre-trial burn
testing (pretesting) at the proposed trial burn conditions to verify incinerator performance before the
formal trial burn tests. [Enter Company Acronym] may request final modifications to the trial burn plan
based on the pretest results. Should changes to the trial burn plan be deemed necessary by [Enter
Company Acronym], such changes will be coordinated with EPA Region [Enter EPA Region] and the
[Enter State Agency Name (Enter State Agency Acronym)].
The shakedown testing program will involve a series of progressively rigorous tests, as described in the
shakedown plan (see Appendix D-5.5). The shakedown testing program will include pretesting using the
POHC, metal, and ash spiking materials and stack sampling methods proposed for the trial burn, as a dry
run for the trial burn. The pretest will consist of one run at each of the three test conditions. The pretest
objectives are as follows:
• Confirm that the selected sampling and analytical methods for the trial burn are
appropriate, and identify and correct any problems.
• Operate the system at full trial burn conditions.
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• Demonstrate performance capabilities of the complete system and its individual
components.
• Finalize target operating conditions for the trial burn.
While the sampling and analytical procedures used will be the same as the procedures used during the trial
burn, the level of quality assurance will be less. For example, split samples and audits will not be used
during the pretest. Verbal and preliminary data from the laboratories will be used to assess the pretest
results. About [Enter Days] days will be required to compile and evaluate the pretest results and compile
a brief summary report. Upon evaluation of the pretest results, the conditions for the actual trial burn will
be finalized.
D-5b(2)(c) New Incinerator Post-Trial Burn Operation [40 CFR 270.62(c)1
The interim period between completion of the trial burn and receipt of final approval from EPA Region
[Enter Region] and [Enter State Agency Name] for full operating authority could be several months.
During this time, [Enter Company Acronym] intends to continue operating the incineration system on a
full-time basis, operating under all federal requirements as per 40 CFR 264, 266, and 270. During this
period, [Enter Company Acronym] expects the incineration system to operate within the operating
envelope defined and demonstrated by the three trial burn tests, with the exceptions of high-Btu liquids,
low-Btu liquids, solids waste feed rates, and metals and chlorine feed rates, which shall be limited to
75 percent of the maximum levels demonstrated during the trial burn.
[NOTE TO USER: The operating limits for high-Btu liquids, low-Btu liquids, solids waste feed
rates, and metals and chlorine feed rates may range from 50 to 90 percent of the maximum levels
demonstrated during the trial burn.]
The incinerator will be inspected visually on a daily basis during operation for fugitive emissions, leaks,
and associated equipment spills and for signs of tampering, as per 40 CFR 264.347(b). All appropriate
operating records will be maintained for documentation of operating conditions.
The AWFCO system and associated alarms, as described in Section D-5b(l)(a)(8), will be functioning
any time hazardous waste is being introduced into the incinerator.
The proposed method for testing the AWFCO system includes a complete check of hardware, set point,
and software, not simply electronic verification of software. The integrity of the final elements (such as
valve and auger-shredder) will be proven by closing the waste feed block valves. The proposed method
of testing the AWFCO system is as follows:
• The control system will poll the individual monitors to the system continuously. If the
integrity of the signal path between the control system and the monitor is compromised or
fails, the fail-safe features of the control system will initiate a control system alarm and
AWFCO automatically for the affected parameter. This includes the failure of an input
module. The control system will ensure constant integrity of the AWFCO signal path
between the monitoring point and the control system. If the integrity of the signal path
between the control system and the final element fails, the fail safe features of the control
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system will initiate an AWFCO automatically for the affected waste stream. This will
include the failure of an output module because the control system does not use traces,
which can fail in the energized state.
• The incineration system monitors will be calibrated quarterly. Hazardous waste
processing will be stopped prior to this testing sequence. During the calibration sequence,
the field technician, in coordination with the control room operator, will test the integrity of
most AWFCOs. The field operator will send an artificial signal that will, normally, initiate
an AWFCO. The control room operator will verify that the signal alarm is received, and
the output closes the automatic liquid waste feed block valve(s) and stops the solid and
sludge waste feed.
• AWFCO testing will be performed weekly using simulations of off-normal operations.
An AWFCO test screen will be configured in the DCS for this purpose. Each week, one
of the events that results in an AWFCO will be simulated by adjusting the trip point for
that event in an appropriate direction to initiate shutdown of each of the waste feeds by
de-energizing the relay to the waste feed cut-off valve (valve fails closed). The
remainder of the AWFCO initiating events will be activated in a manner similar to the
first, and the de-energization of the relay that provides shutdown of the waste feed will be
demonstrated. During the testing period, the waste feed cutoffs will be operated using a
manual override. The control room operator will be responsible for manually initiating an
AWFCO, should actual operating conditions violate any of the AWFCO limits during
testing.
D-5b(2)(d) Incinerator Performance [40 CFR 270.62(a)1
[Note to User: In this section, a rationalization of the operating conditions selected for the startup,
shakedown, and post-trial burn operation should be provided. In particular, this section should
demonstrate that the performance standards of 40 CFR 264.343 will be met while operating the
unit during startup, shakedown, and post-trial burn operation.}
[Enter Company Acronym] believes that the conditions specified in Section D-5b(2) for the startup,
shakedown, and post-trial burn operation will be adequate to meet the performance standards of 40 CFR
264.343 while firing any combination of feed materials for the following reasons:
• Our experience with identical kilns and SCC burning similar liquid and solid wastes under
similar operating conditions at [Identify Locations of Similar Plants] shows that the
expected DRE will exceed 99.99 percent. In trial burn tests conducted at [List Facilities
with Similar Combustion andAPCSs], DREs of [List DemonstratedDREs] were
achieved.
• Our experience with identical kilns and SCC burning similar liquid and solid wastes under
similar operating conditions at [Identify Locations of Similar Plants] suggests that the
hydrogen chloride and particulate emissions will be less than 4 pounds per hour and 0.08
grains per dry standard cubic foot, respectively. In trial burn tests conducted at [List
Facilities with Similar Combustion andAPCSs], hydrogen chloride emissions of [List
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Hydrogen Chloride Emissions] were measured. During these same tests, particulate
emissions of [List Paniculate Emissions] were measured. In all of the cases, emissions
of hydrogen chloride and particulate were well below the respective performance
standards.
• Thermodynamic and finite element modeling performed by [List Engineering
Companies and Vendors] demonstrates that DRE will exceed 99.99 percent and
hydrogen chloride and particulate emissions will be below the performance standards of 4
pounds per hour and 0.08 grains per dry cubic foot.
• Maximum uncontrolled emissions of hydrogen chloride and particulate during shakedown
and testing have been predicted to be [Provide Estimates of Uncontrolled Emissions].
Certifications and other information prepared by the vendors of the APCS equipment
indicate that the aggregate removal efficiencies of the APCS equipment for hydrogen
chloride and particulate will be [Provide Removal Efficiencies], suggesting maximum
controlled emissions of [Provide Estimates of Maximum Controlled Emissions]. These
controlled emissions are well below the performance standards.
• The range of operating conditions planned for the startup, shakedown, and post-trial burn
periods are within the design envelope of the combustion and APCSs (refer to the design
basis in Table D-5.7).
• The combustion and APCSs will be tightly controlled by the DCS, and AWFCO systems
will be operational at all times during the startup, shakedown, and post-trial burn periods.
• Startup and shakedown will be conducted in a disciplined manner, according to the
written startup plan (see Appendix D-5.5).
D-5c TRIAL BURN SUBSTITUTE SUBMISSIONS [40 CFR 270.19(c)]
This section is not applicable. A trial burn will be conducted.
[NOTE TO USER: Previous interim status testing may be proposed as data in lieu of trial burn
data, subject to EPA and state regulatory agency approval]
D-5d DETERMINATIONS [40 CFR 270.62(b)(6)]
The required information for the trial burn determinations is summarized in the following sections.
D-5d(l) TRIAL BURN RESULTS [40 CFR 270.62(b)(7)]
The results of the trial burn test must be submitted in the report format specified in Table D-5.15. The
key elements that must be included in each section of the trial burn report are as follows:
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A summary of trial burn results describing any unusual process conditions (deviations
from the approved trial burn plan) or difficulties experienced with sampling, testing, or
analysis (Executive Summary)
A discussion of any inconsistencies in the data and assessment of, and/or justification for,
usability of the data (Executive Summary)
A summary of conclusions in meeting the trial burn plan objectives (Executive Summary)
A list of key project personnel (Section 1.0)
A detailed description of chemical and physical analysis of waste feed and process
samples (Section 2.0)
A concise description of the test program including reasons for testing, number and types
of tests, technical approach, test locations, sampling trains, and special equipment (Section
3.0)
A comparison of test conditions to planned conditions for all waste and fuel feed rate
information, waste generation rate information, and stack gas parameter rate information,
including at a minimum, the following (Section 4.0)
Maximum, minimum, average, and standard deviation of the solid, high-Btu liquid,
and low-Btu liquid waste feed rates
Maximum, minimum, average, and standard deviation of combustion chamber
temperatures
Maximum, minimum, average, and standard deviation of APCS operating
conditions
Maximum, minimum, average, and standard deviation of combustion gas velocity
A summary of test results and a comparison with permit or regulatory compliance limits,
including the following (Section 5.0)
Analytical results
Quantitative analysis of POHCs in waste feed
Stack gas concentrations (such as gr/dscf, pounds per dscf, ppmdv, milligrams per
liter) and stack gas emission rates (pounds per hour and gallons per second) of
POHCs, metals, hydrogen chloride, chlorine, particulate, PCDDs and PCDFs,
PICs, oxygen, carbon monoxide, and carbon dioxide
Computation of DRE
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Particle-size distribution
• A description of sampling methods, sample preparation, and analytical procedures
(Section 6.0)
• The method for determining the detection limit in the matrix for each analysis, and the
data and results of the detection limit determination (Section 7.0)
• A copy of the trial burn plan (Appendix A)
• A copy of the trial burn QAPP (Appendix B)
• A stack sampling report (Appendix C)
• A process sampling report (Appendix D)
• A quality assurance and quality control (QA/QC) report, including completed
chain-of-custody forms, analysis request forms, and a key relating laboratory sample
identification numbers to trial burn sample identification numbers (Appendix E)
• Instrument calibration records (Appendix F)
• Performance calculations, including the example calculations used in each determination
and all the raw data needed for traceability of the results calculated (Appendix G)
• Field logs (Appendix H)
• Analytical data packages (Appendix I)
Test data summary tables with raw and calculated data, including the associated
QA/QC results for all the data
A summary of the data validation procedures and criteria indicating how the data
met the data validation criteria and the QA/QC objectives stated in the approved
QAPP and approved methodology
Completed data validation checklists
It should be noted that all data must be submitted for all analysis conducted, including the
data from failed runs.
[Enter Company Acronym] will submit the trial burn report within 90 days after completion of the trial
burn. The trial burn report will be certified in accordance with the requirements of 40 CFR
270.62(b)(7-9).
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D-5d(2) FINAL OPERATING LIMITS [40 CFR 270.62(b)(10)]
[NOTE TO USER: This section is probably the most important section in the trial burn plan. Here
the performance objectives and the sampling and analysis programs come together to establish
operating limits for the unit. This is the permittee's opportunity to communicate to the permit writer
exactly how the test sampling and analysis data and the demonstrated operating conditions are
expected to be interpreted into final permit operating limits. This information should be repeated in
the trial burn report.]
If the DRE, metals, parti culate, hydrogen chloride, and PICs performance objectives set forth in Section
D-5b(l)(d)(3) are achieved during the trial burn, the RCRA incineration operating permit should allow the
incineration system to be used to incinerate RCRA hazardous solid and liquid wastes at the rates and
under the conditions discussed in this section.
The destruction of organics is a function of time, temperature, and turbulence. The minimum thermal
treatment temperature and maximum combustion gas velocity test the capability of the rotary kiln
incineration system to destroy organics under conditions least favorable for organics destruction (minimum
time at minimum temperature) and subsequent PIC formation. The maximum waste feed rates present
the maximum challenge for the particulate loading to the APCS. The Tier III metals feed rates present a
significant challenge for the rotary kiln incineration system's APCS to remove the metals from the
combustion gas. The high-chlorine feed rate and minimum recycle flow rates and pH operating conditions
test the APCS's capabilities under the least favorable conditions for removing hydrogen chloride from the
combustion gas.
The anticipated final operating conditions resulting from the trial burn are summarized in Table D-5.5.
Table D-5.5 was prepared following the hierarchy of process-control-related performance parameters, as
established by the Guidance on Setting Permit Conditions and Reporting Trial Burn Results (EPA
1989). Each anticipated rotary kiln incineration system final operating limitation is listed by process
parameter, target value during the trial burn, and anticipated manner by which the limit will be established.
In accordance with EPA guidance, the process parameters presented in Table D-5.5 are broken down by
Group A, B, and C parameters, as follows:
• Group A—These parameters will be monitored continuously and will be connected to an
AWFCO system. When a Group A parameter is exceeded, contaminated waste feed
must be discontinued immediately. Group A parameters will be established based on
demonstrated operating conditions during the trial burn.
• Group B—These parameters will not be monitored continuously. Compliance with these
parameters will be based on operating records to ensure that routine operation is within
the operational limits established by the trial burn.
• Group C—Limits on these parameters will be set independently of
trial-burn-demonstrated parameters. Instead, these limits will be based on EPA guidance,
equipment manufacturer's design and operating specifications, operational safety
considerations, and good engineering practices. Group C parameters include parameters
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monitored both continuously and periodically. Depending upon the particular Group C
parameter, a Group C parameter may or may not be an AWFCO parameter.
D-5d(2)(a) Group A Parameters
Establishment of permit limits for the Group A parameters is discussed in the following paragraphs.
• Maximum Hazardous Waste Feed Rates—Maximum waste feed rate will be a Group A
parameter. The maximum waste feed rates for high- and low-Btu liquids and solids will
be demonstrated during Test 2. The final, approved permit limit for each waste feed
stream will be based on the arithmetic mean of the highest hourly rolling average waste
feed rate demonstrated during the three Test 2 runs.
• Minimum Rotary Kiln Temperature—Minimum rotary kiln temperature limit will be
proposed as a Group A parameter related to meeting the DRE. Provided that
satisfactory DRE for the designate POHCs is obtained during Test 2, the final, approved
permit limit for minimum rotary kiln temperature should be based on the arithmetic mean
of the lowest hourly rolling average temperatures demonstrated during the three Test 2
runs.
• Maximum Rotary Kiln Temperature—Maximum rotary kiln temperature limit will be
proposed as a Group A parameter related to meeting the metals emission limits. Provided
that satisfactory metals emissions for the Tier III metals are obtained during Test 1, the
final, approved permit limit for maximum rotary kiln temperature should be based on the
arithmetic mean of the highest hourly rolling average temperatures demonstrated during
the three Test 1 runs.
• Maximum SCC Temperature—Maximum SCC temperature limit will be proposed as a
Group A parameter related to meeting the metals emission limits. Provided that
satisfactory metals emissions for the Tier III metals are obtained during Test 1, the final,
approved permit limit for maximum SCC temperature should be based on the arithmetic
mean of the highest hourly rolling average temperatures demonstrated during the three
Test 1 runs.
• Minimum SCC Temperature—Minimum SCC temperature limit will be a Group A
parameter related to DRE and will be demonstrated during Test 2. Test 2 will be
designed to demonstrate 99.99 percent or greater DRE on two POHCs. Provided that
satisfactory DRE results are obtained for the designated POHCs during the trial burn, the
final, approved permit limit for SCC temperature should be based on the arithmetic mean
of the lowest hourly rolling average temperatures demonstrated during the the three
Test 2 runs.
• Maximum Combustion Gas Velocity—Combustion gas velocity will be a Group A
parameter related to DRE and combustion gas treatment based on the trial burn
demonstrated stack gas flow. Combustion gas velocity in the stack will be an indicator of
combustion gas residence time in the SCC, the portion of the rotary kiln incineration
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system responsible for DRE. The final, approved operating condition should be based on
the arithmetic mean of the highest hourly rolling average stack gas flow rate, as
demonstrated during each of the three Test 2 runs.
Maximum Boiler Inlet Temperature—The maximum combustion gas inlet temperature to
the boiler will be a Group A parameter based on the results of the risk burn. The final
operating limit for this parameter is expected to be the mean of the highest hourly rolling
average inlet temperatures recorded during each of the three runs under Test 3.
Minimum Vane Separator Process Water Flow Rate—The minimum vane separator
process water flow rate will be based on the mean of the minimum hourly rolling average
flow rates recorded during each of the trial burn runs under Tests 1 and 2.
Minimum Venturi Scrubber Differential Pressure—The minimum differential pressure
across the venturi scrubber will be based on the mean of the minimum hourly rolling
average differential pressures recorded during each of the trial burn runs under Tests 1
and 2.
Minimum Venturi Scrubber Liquid To Gas Ratio—The minimum venturi scrubber liquid to
gas ratio will be based on the mean of the minimum hourly rolling average liquid to gas
ratios recorded during each of the trial burn runs under Tests 1 and 2.
Minimum Venturi Scrubber Recycle pH—The venturi scrubber solution pH will be
controlled to a minimum value during the trial burn, while the liquid to gas ratio will be
minimized. Provided that adequate hydrogen chloride control has been demonstrated at
high chloride feed rate, minimum liquid to gas ratio, and minimum pH during the trial burn,
the minimum venturi scrubber pH should be based on the arithmetic mean pH value
demonstrated during all runs of the trial burn under Tests 1 and 2.
Minimum Scrubber Blowdown Flow Rate—The permit condition for the minimum
scrubber blowdown flow rate is expected to be established as the mean of the lowest
recorded flow rates during each of the runs under Tests 1 and 2.
Minimum WESP Power Input—The WESP kVA will be controlled to a minimum value
during the trial burn while the combustion gas flow will be maximized. Provided that
adequate particulate and metals control has been demonstrated at high liquid waste ash
feed and maximum metals feed rates during the trial burn, the minimum WESP kVA
should be based on the arithmetic mean kVA value demonstrated during all runs of the
trial burn under Tests 1 and 2.
Minimum WESP Liquid Flow Rate—The WESP liquid flow will be controlled to a
minimum during the trial burn. Provided that adequate particulate and metals control are
demonstrated during the trial burn, the permit condition for minimum WESP liquid flow
rate should be based on the arithmetic mean of the lowest hourly rolling average flow
rates recorded during each of the six runs under Tests 1 and 2.
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• Maximum Carbon Monoxide Concentration in the Stack—Maximum carbon monoxide
concentration in the stack will be a Group A parameter related to PIC control and
normally will be established at the performance standard of 100 ppmdv corrected to
7 percent oxygen 60-minute. During all nine runs of the trial burn, compliance with this
performance standard will be demonstrated by controlling the carbon monoxide
concentration in the stack gas below this limit. When the 60-minute, rolling average
carbon monoxide concentration exceeds 100 ppmdv corrected to 7 percent oxygen, all
waste feeds will be stopped automatically. Waste feeds will not be resumed until the
rolling average concentration falls below the 100 ppmdv rolling average limit.
• Minimum Oxygen Concentration in the Stack—Minimum oxygen in the stack gas will be
a Group A parameter. The rotary kiln and SCC will be operated under oxidative
operating conditions to treat the waste feeds. The oxygen levels in the combustion
system will be controlled to result in a stack gas concentration of 3 to 5 percent oxygen.
The final operating limit for oxygen in the stack gas will be the mean of the lowest hourly
rolling averages recorded during each of the three tests runs.
D-5d(2)(b) Group B Parameters
Establishment of Group B parameter limits based on the results of Tests 1 and 2 is discussed in the
following paragraphs.
• Maximum Metals Feed Rate Limits—The feed rate of the metals to the combustion
process will be controlled Group B parameters. The Tier I metals feed rate limits for this
facility will be established on the basis of effective stack height, stack gas temperature
and stack gas flow rate. The Tier I metals feed rate limits, as calculated using the
procedures of 40 CFR 266 Appendix I, are as follows:
[List Tier I Metals and Feed Rate Screening Limits}
It is anticipated that the final permit will require that the feed rates of Tier I metals
(antimony, barium lead, mercury, nickel, selenium, silver, and thallium) be measured in the
waste feeds to demonstrate compliance with the Tier I limits. Tier I metals limit
compliance will be based on the operating records, which show that the feed rates of
these metals do not exceed the respective rates allowed in the final permit.
The Tier III emission limits and the underlying dispersion modeling based on the emissions
measurements made during the trial burn will be presented to EPA in a document, "U.S.
EPA Tier III Limits for Metals and Hydrogen Chloride for the Proposed Incinerator,
[Enter Company Name], [Enter Facility Location], [Enter Consultant Company
Name], [Enter Consultant Company Location], [Enter Day, Year]"
Provided that the emission rates of the Tier III metals are in compliance with the Tier III
allowable emissions limits, the final permit condition for maximum hourly rolling average
feed rates of arsenic, beryllium, cadmium, and chromium are expected to be based on the
feed rates of these metals demonstrated during Test 1. Separate feed rate limits will be
D-5.56
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Revision No.: 0
Revision Date: Month/Year
proposed for solid and sludge wastes and liquid wastes. Metals limits compliance will be
based on the operating records, which show that the feed rates of these metals do not
exceed the respective rates demonstrated during Test 1.
Maximum Chlorine Feed Rate—The feed rate of chlorine, which will be converted
primarily to hydrogen chloride and possibly to small amounts of chlorine in the combustion
process, will be controlled as a Group B parameter. The RCRA hydrogen chloride
performance standard [40 CFR 264.343(b)] requires either 99 percent hydrogen chloride
removal or less than 4 pounds of hydrogen chloride per hour stack emission during the
incineration of chlorinated hazardous wastes. BIF (40 CFR 266.107) regulates hydrogen
chloride and chlorine using a tiered approach similar to metals. Based on the waste
profile, [Enter Company Acronym] has determined that a 99 percent removal and Tier
III approach will be necessary. [Enter Company Acronym] requests that the permit
condition be based on the maximum pounds of organic chlorine per hour that will be fed
to the rotary kiln incineration systems and will be successfully removed as hydrogen
chloride to either the 99 percent removal or Tier III limits.
Because the source of hydrogen chloride, either as chlorinated liquid or solid and sludge
waste, is not relevant to the hydrogen chloride removal performance of the APCS
equipment, it is requested that the permit will allow any combination of chlorinated liquid
and solid and sludge wastes to be incinerated as long as the total organic chlorine rate
does not exceed the organic chlorine permit condition. The final permit condition for
maximum hourly rolling average feed rate of chlorine is expected to be based on the
maximum amount of chlorine fed during the Test 2 and for which effective acid gas
control will be demonstrated. The total feed rate of chlorine will include the chlorine
contributions from the combination of solid and sludge wastes, liquid wastes, spiked
organic chlorine source chemical, and spiked POHCs. Compliance will be demonstrated
based on the operating records, which show that the feed rates of chlorine in the waste
feeds do not exceed the limit.
POHC DRE—Effective demonstration of 99.99 percent or greater DRE of the three
designated POHCs, chlorobenzene, naphthalene, and carbon tetrachloride, spiked to the
waste feeds will be done during Test 2. Chlorobenzene and carbon tetrachloride, which
are Class 1 compounds on the University of Dayton Thermal Stability Ranking, will
provide a rigorous test of the rotary kiln incineration system's capability to treat the
[Enter Company Acronym] wastes. The final approved POHC DRE limits for the
rotary kiln incineration system should allow a treatment of any of the [Enter Company
Acronym] wastes at the maximum feed rates demonstrated during Test 2. [Enter
Company Acronym]s final permit should allow incineration of all 40 CFR 261 Appendix
VIII organic compounds, except hazardous wastes designated as F020, F021, F022, F023,
F026, and F027 or wastes containing greater than 50 ppm PCBs that are regulated by
TSCA, which will be prohibited.
Maximum Particulate Matter Emissions—The expected permit condition for this
parameter is 0.08 gr/dscf, the RCRA performance standard for incinerators and BIF
units. [NOTE TO USER: The air permit for the facility may contain a more
D-5.57
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Revision No.: 0
Revision Date: Month/Year
restrictive particulate matter emission limit than the RCRA standard cited above. If
so, cite the more restrictive limit here.]
• Maximum Ash Content of Waste—The solid and sludge waste used during the trial burn
will have an ash content greater than 85 percent. It is expected that there will not be a
permit condition related to the ash content of the solid and sludge wastes.
During all trial burn tests, ash-producing material will be added to the low-Btu liquid
wastes to provide significant challenge to the particulate removal capabilities of the
APCS. Particulate emissions will be measured during all trial burn tests. If the
particulate emissions are at or below those stated in the trial burn objectives
(0.08 gr/dscf), these tests should be considered as acceptable particulate tests for all solid
wastes, sludges, and slurries, regardless of the solids ash content. The maximum
permitted liquid waste ash content for liquid hazardous waste will then be based on the
mean of the ash contents in the liquid waste during the six runs under Tests 1 and 2.
• Maximum Emissions of Chlorine and Hydrogen Chloride—The expected permit condition
for this parameter is 4 pounds per hour, as required under 40 CFR 264.343(b).
Expected risk-based Group B permit limits are described below.
[Note to User: Risk-based permit conditions will be an outgrowth of the multi-pathway risk
assessment completed after the trial burn. Each facility will have unique risk factors, so it is
anticipated that the nature and extent of risk-based permit conditions will be highly variable. The
following permit conditions are presented as examples only.]
• Maximum Dioxin and Furan Emissions—The expected permit condition for this
parameter will be established on the basis of the site-specific risk assessment.
• Maximum Annual Average Hazardous Waste Feed Rates—Assuming that the
multi-pathway risk assessment results are favorable, the final approved permit limits for
maximum annual average hazardous waste feed rates is expected to be based on the
arithmetic means of the highest hourly rolling average waste feed rates demonstrated
during the three Test 3 runs.
• Minimum Annual Average Rotary Kiln Temperature—Provided the multi-pathway risk
assessment results are favorable, the final approved permit limit for the minimum annual
average rotary kiln temperature is expected to be based on the arithmetic mean of the
lowest hourly rolling average temperatures demonstrated during each of the three Test 3
runs.
• Maximum Annual Average Rotary Kiln Temperature—Provided the multi-pathway risk
assessment results are favorable, the final approved permit limit for the maximum annual
average rotary kiln temperature is expected to be based on the arithmetic mean of the
highest hourly rolling average temperatures demonstrated during each of the three Test 3
runs.
D-5.58
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Revision No.: 0
Revision Date: Month/Year
• Maximum Annual Average SCC Temperature—Provided that satisfactory multi-pathway
risk assessment results are obtained, the final permit limit for the maximum annual
average SCC temperature is expected to be based on the arithmetic mean of the three
highest hourly rolling average temperatures demonstrated during each of the three Test 3
runs.
• Minimum Annual Average SCC Temperature—Provided that satisfactory multi-pathway
risk assessment results are obtained, the final permit limit for the minimum annual
average SCC temperature is expected to be based on the arithmetic mean of the lowest
hourly rolling average temperatures demonstrated during each of the three Test 3 runs.
• Maximum Annual Average Combustion Gas Flow Rate—The final permit condition for
the maximum annual average combustion gas flow rate is expected to be based on the
arithmetic mean of the highest hourly rolling average stack gas flow rates demonstrated
during each of the three Test 3 runs.
D-5d(2)(c) Group C Parameters
Establishment of Group C parameters is discussed in the following paragraphs.
• CEM System Operation—CEM system operation will be a Group C parameter to comply
with EPA guidance that CEMs must be operational when the rotary kiln incineration
system is processing wastes. A loss of instrument signal from either the carbon
monoxide or oxygen CEM will result in an AWFCO.
• Maximum Rotary Kiln Pressure—Rotary kiln pressure is normally a Group C parameter
established based on EPA guidance for fugitive emissions control. Fugitive emissions
control will be a qualitative demonstration. Fugitive emissions from the rotary kiln will be
controlled by maintaining the pressure in the rotary kiln slightly below atmospheric
pressure. A limit of <0.08 inch of water column will be proposed for this AWFCO limit,
which will be in effect during the trial burn. When the rotary kiln pressure exceeds the
maximum pressure limit, all waste feeds to the rotary kiln will be stopped automatically.
• Maximum Quench Exit Temperature—Quench exit temperature will be proposed as a
Group C parameter based on the manufacturer's recommendations. The maximum
temperature limit proposed for quench duct exit temperature will be 210 °F to protect
temperature-sensitive FRP construction materials of the acid gas scrubbing system.
When the quench duct exit temperature exceeds the maximum limit, all waste feeds will
be stopped.
• Minimum Heating Value—[Enter Company Acronym] expects that the final permit will
specify minimum heating value permit conditions for the high-Btu liquid waste equal to
those recommended by the burner manufacturers, as follows:
Rotary kiln burner, [Enter Manufacturer's Recommendation]
D-5.59
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Revision No.: 0
Revision Date: Month/Year
Small SCC burner, [Enter Manufacturer's Recommendation]
Large SCC burner, [Enter Manufacturer's Recommendation]
[Enter Company Acronym] anticipates that the final permit will not specify a maximum
or minimum heating value for solid wastes or low-Btu liquid wastes. The minimum
heating value concept, while relevant to high-Btu liquid wastes, is not relevant to low
heating value solids such as sludges or slurries. As stated on page 4-22 of the Guidance
Manual for Hazardous Waste Incinerator Permits (EPA 1983),
"However, in the case of solids fed to rotary kilns, hearths and other
solids handling incineration equipment, a different approach to specifying
a heating value for waste is needed. Many solid wastes, by their very
nature, are subject to wide variations in heating value, and rotary kiln,
hearth, and similar incinerator designs attempt to deal with this problem.
Such designs provide for the volatiles in the solids to be vaporized and
subsequently destroyed in an afterburner or secondary combustion cham-
ber. Thus in specifying heating values for solid waste feeds, a lower
heating value limit may not be required if the incinerator is equipped and
operated to maintain sufficient temperature by addition of liquid waste or
auxiliary fuel."
Because the incineration system will have dual-fuel capability in both the rotary kiln and
SCC chambers, the rotary kiln should not have a heating value permit condition for the
incineration of solid wastes. The quoted information also will be applicable to the low-Btu
liquid wastes, which will not be used as burner fuel in either the rotary kiln or the SCC.
Maximum Liquid Waste Viscosity—An upper limit on the viscosity of liquid wastes will
be established at [Enter Viscosity] centipoise, commensurate with the recommendations
of the manufacturers of the liquid waste injection nozzles and burners.
Maximum Thermal Input to Kiln—An upper limit on the thermal input to the kiln will be
established at [Enter Btuper Hour], based on the recommendations of the kiln
manufacturer.
Maximum Thermal Input to SCC—An upper limit on the thermal input to the SCC will be
established at [Enter Btuper Hour], based on the recommendations of the SCC
manufacturer.
Maximum Solids Content of Liquid Wastes—An upper limit on the solids content of the
liquid wastes will be established at [Enter Percent Solids], based on the
recommendations of the burner and nozzle manufacturers.
Maximum Burner Turndown—An upper limit on the turndown ratio will be established
for each burner at [Enter Turndown Ratio], based on the recommendations of the
burner manufacturers.
D-5.60
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Revision No.: 0
Revision Date: Month/Year
Minimum Venturi Scrubber Nozzle Pressure—A lower limit on the pressure of the
scrubber liquid at the venturi nozzle will be established at [Enter Pressure] psig, based on
the recommendations of the venturi manufacturer.
Minimum WESP Nozzle Pressure—A lower limit on the pressure of the scrubber liquid
at the WESP nozzles will be established at [Enter Pressure] psig, based on the
recommendations of the WESP manufacturer.
Minimum Differential Pressure Between Atomizing Steam and High-Btu Liquid
Waste—A lower limit on the pressure diffential will be established at [Enter Pressure]
psig, based on the recommendations of the liquid waste burner manufacturer.
Minimum Differential Pressure Between Atomizing Air and Low-Btu Liquid Waste—A
lower limit on the pressure diffential will be established at [Enter Pressure] psig, based
on the recommendations of the liquid waste nozzle manufacturer.
D-5.61
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Revision No.: 0
Revision Date: Month/Year
REFERENCES
U.S. Environmental Protection Agency (EPA). 1983. "Guidance Manual for Hazardous Waste
Incinerator Permits." Office of Solid Waste. Washington, D.C. March.
U.S. EPA. 1989. "Guidance on Setting Permit Conditions and Reporting Trial Burn Results."
Hazardous Waste Incineration Guidance Series, Volume II. Office of Solid Waste.
Washington D.C. EPA/625/6-89/019. January.
U.S. EPA. 1992. "BIF Technical Implementation Document." Washington, D.C. EPA-530-R-92-011.
March.
U.S. EPA. 1996. "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods." Washington,
D.C. SW-846. Update III. December.
U.S. EPA. 1998a. "Protocol for Human Health Risk Assessment at Hazardous Waste Combustion
Facilities." EPA-R6-098-002. Center for Combustion Science and Engineering, Multimedia
Planning and Permitting Division, U.S. EPA Region 6. Dallas, Texas. January.
U.S. EPA. 1998b. "Protocol for Screening Level Ecological Risk Assessment at Hazardous Waste
Combustion Facilities." EPA-R6-098-003. Center for Combustion Science and Engineering,
Multimedia Planning and Permitting Division, U.S. EPA Region 6. Dallas, Texas. January.
D-5.62
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APPENDIX D-5.1
QUALITY ASSURANCE PROJECT PLAN
-------
APPENDIX D-5.2
PROCESS FLOW DIAGRAMS, PIPING AND INSTRUMENTATION DIAGRAMS,
AND FACILITY LAYOUT
-------
APPENDIX D-5.2
PROCESS FLOW DIAGRAMS, PIPING AND INSTRUMENTATION DIAGRAMS,
AND FACILITY LAYOUT
This appendix must include the following diagrams, as describe in this section:
• General arrangement
• Construction
• Piping and instrumentation
• Process control logic
General Arrangement Diagrams
General arrangement diagrams must be provided showing top and side views of entire incineration system,
including elevations.
Construction Diagrams
Construction diagrams for the following equipment must be provided with sufficient detail to show inside
and outside dimensions; varying refractory thicknesses; location and orientation of burners, nozzles, and
augers into chambers; and instrument locations (actual) and sample taps:
Kiln
• Secondary combustion chamber and thermal relief vent (including induced draft and
elevation)
• Kiln faceplate
• Auger feed system
• Ash-handling system
• Boiler
D-5.2-1
-------
• Quench
• Venturi
• Wet electrostatic precipitator
• Induced draft fan and stack (including port and monitor locations, inner diameter, and
elevations)
Piping and Instrumentation Diagrams
Piping and instrumentation diagrams must be provided with sufficient detail to show the following
elements:
• Tag numbers
• Locations
• Elements
• Indicating controllers
• Valves
• Switches
• Alarms
• Interlocks/cutoffs
Process Control Logic Diagrams
Process control logic diagrams must show the control logic for combustion, air pollution control, and
continuous emissions monitoring systems.
D-5.2-2
-------
APPENDIX D-5.3
MANUFACTURERS' SPECIFICATIONS
-------
APPENDIX D-5.3
MANUFACTURERS' SPECIFICATIONS
This appendix must include the following information:
• Burner nozzle specifications—for the kiln burner, kiln atomizer, secondary combustion
chamber (SCC) startup burner, SCC main burner, SCC atomizer, and SCC quench
nozzles—must be provided with sufficient detail to include the following information:
Type (internal or external mix)
Diagram
Capacity
Turndown ratio
Atomizing media and pressure
Fuel pressure
Viscosity range
Percent solids and size limits
Explanation of how atomizing media are controlled relative to feed rate changes
• Fan curve
• Instruments (such as thermocouples, flow meters, and annubars)
• Rotary kiln specifications and fabrication drawings
• SSC specifications and fabrication drawings
• Data sheets for castable refractories
• Specifications and fabrication drawings for air pollution control equipment
• Specifications for continuous emission monitors
• Specifications and fabrication drawings for waste feed systems
D-5.3-1
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D-5.3-2
-------
APPENDIX D-5.4
WASTE FEED AND CHLORINE, METALS, AND POHC SPIKING INFORMATION
-------
APPENDIX D-5.4
WASTE FEED AND CHLORINE, METALS, AND POHC SPIKING INFORMATION
Actual solid and liquid wastes will be burned in the incineration system during three tests. The liquid
wastes will be spiked with copper sulfate and perchloroethylene in Tests 1 and 2 to increase the ash and
chlorine feed rates to the desired levels. The liquid wastes also will be spiked with metals in Test 1 and
principal organic hazardous constitutents (POHC) in Test 2. The solid wastes will be spiked with
perchloroethylene and metals in Test 1 and perchloroethylene and POHCs in Test 2. No spiking will
occur in Test 3.
The expected composition of the high-British thermal unit (Btu) liquid waste that will be used in order to
formulate the waste feed for all three tests will be as shown in Table D-5.4-1. As shown therein, the
waste before spiking is expected to be 80 percent by weight ethanol and 20 percent by weight water.
The expected composition of the low-Btu liquid waste that will be used in order to formulate the waste
feed for all three tests will be as shown in Table D-5.4-2. As shown therein, the waste before spiking is
expected to be 100 percent by weight water.
The expected composition of the solid waste that will be used in order to formulate the waste feed to the
rotary kiln in all three tests will be as shown in Table D-5.4-3.
ORGANIC CHLORINE AND ASH SPIKING
The target feed rates for organic chlorine and ash in both Tests 1 and 2 are as listed in Table D-5.4-4.
Table D-5.4.5 shows the composition of the high-Btu liquid following spiking with perchloroethylene and
copper sulfate in order to raise the chlorine and ash feed rate to the target levels in Tests 1 and 2.
Table D-5.4.6 shows the composition of the low-Btu liquid waste following spiking with perchloroethylene
and copper sulfate in order to raise the chlorine and ash feed rates to the target levels in Tests 1 and 2.
D-5.4-1
-------
Table D-5.4.7 shows the composition of the solid waste following spiking with perchloroethylene in order
to raise the chlorine feed rate in that stream to the target levels in Tests 1 and 2.
The purity and composition of the perchloroethylene and copper sulfate spiking compounds used for the
trial burn will be certified by an independent party. These certifications will be included in the trial burn
report.
METAL SPIKING
The trial burn's metal sampling and analysis program includes spiking metals to the solid and liquid waste
feeds in the rotary kiln and secondary combustion chamber (SCC) during Test 1. For the trial burn,
[Enter Company Name] will use a contractor that specializes in providing metal spiking services for
incineration testing programs. The contractor's procedures and methods will be coordinated with U.S.
Environmental Protection Agency (EPA) Region [Enter Region Number] and the [Enter State Agency].
The metallic compounds proposed by the contractor for spiking the liquid and solid wastes are indicated in
Tables D-5.4-8 and D-5.4-9, respectively. The selection of these compounds has been based upon their
physical properties and availabilities. These compounds will not be substituted without approval from
EPA Region [Enter Region Number] and the [Enter State Agency].
Target Metal Feed Rates
The target metal feed rates for the trial burn were established as follows:
The minimum feed rate of each metal must result in a detectable amount in the stack gas.
The determination of the minimum feed rate of each metal was based on its analytical
method detection limit, the stack gas sample size, the anticipated dry stack gas flow rate,
and the anticipated air pollution control system (APCS) removal efficiency and
incineration system partitioning factor.
Once the minimum feed rate of each metal was determined, this value was then
compared to the metal's maximum expected feed rate in [Enter Company Name]s
waste materials. Whenever the metal feed rate corresponding to the minimum
detectable amount in the stack gas was found to exceed the expected maximum feed rate
of the same metal in [Enter Company Name]'s waste materials, the proposed feed rate
D-5.4-2
-------
was adjusted upward. In each case, the maximum feed rate of any metal was limited to
no more than 80 percent of its Tier III limit based on its anticipated APCS removal
efficiency and incineration system partitioning factor.
The results of this analysis are presented in Table D-5.4-10.
The metals arsenic, beryllium, cadmium, and chromium will be spiked to the waste feeds during Test 1 to
demonstrate compliance with the Tier III emissions limits for these metals at higher than Tier III feed
rates. The preliminary air dispersion modeling performed to support the development of the proposed Tier
III limits is provided in Appendix D-5.10. [Enter Company Name] will comply with Adjusted Tier I limits
(Tier III emission limits as permit waste feed rate limits with no credit taken for APCS removal) for
antimony, barium, lead, mercury, selenium, silver, and thallium.
The purity and compositions of the metals spiking compounds used for the trial burn will be certified by an
independent party. These certifications will be included in the trial burn report.
Metal Spiking to the Solid Wastes
Metals will be spiked to the solid waste feed by injecting solutions of metal salts. This metal spiking
method for the solid wastes gives a high degree of control to the actual quantity of metals being spiked.
The metal salts proposed for solids during Test 1 of the trial burn are indicated in Table D-5.4.8.
Metals Spiking to the Liquid Wastes
Solutions of metals will be added to the high- or low-Btu waste feed line during Test 1. The actual
amount of metal spiking solutions required for the liquid wastes will be determined by the metal's target
feed rate and the limitations of the spiking equipment available. The metal salts proposed for the liquid
wastes during Test 1 of the trial burn are indicated in Table D-5.4.9.
Anticipated Detection Limits
The values for the metal spiking rates are based on the stack detection limits in Table D-5.4-11.
D-5.4-3
-------
Sample Calculation for Metals of Concern
As an example, the calculation for beryllium follows:
Beryllium Tier III Limit/(l - APCS Removal Efficiency) = Theoretical Maximum Liquid
Metals Feed Rate = (0.00037 pound per hour [lb/hr])/(l - 0.95) = 0.0074 Ib/hr
Theoretical Maximum Liquid Metals Feed Rate x 0.80 = Maximum Proposed
Trial Burn Liquids Metal Feed Rate = 0.0074 Ib/hr x 0.80 = 0.006 Ib/hr
Spiking Rate in Liquids = Maximum Proposed Trial Burn Liquid Metals Feed
Rate - Expected Liquid Metals Feed Rate = 0.14 Ib/hr - 0.005 Ib/hr = 0.135 Ib/hr
POHC SPIKING
Appendix D-5.8 provides calculations of POHC spiking rates.
QUANTITY OF TRIAL BURN FEED MATERIALS
Assumed duration of waste burning during trial burn is as shown:
Test 1 = 27 hrs
Test 2 = 24 hrs
Test 3 = 39 hrs
High-Btu Liquid Wastes
The quantity of high-Btu liquid waste is calculated as follows:
Test 1 - 2,183 Ibs/hr x 27 hrs = 58,941 Ibs
Test2-2,1831bs/hrx24hrs = 52,392 Ibs
Test 3 - 1,800 Ibs/hr x 39 hrs = 70.200 Ibs
Subtotal = 181,533 Ibs
D-5.4-4
-------
Add 25 percent safety factor = 45.383 Ibs
Total = 226,916 Ibs
Low-Btu Liquid Wastes
The quantity of low-Btu liquid waste is calculated as follows:
Test 1 - 700 Ibs/hr x 27 hrs = 18,900 Ibs
Test 2 - 700 Ibs/hr x 24 hrs = 16,800 Ibs
Test 3 - 600 Ibs/hr x 39 hrs = 23.400 Ibs
Subtotal = 48,000 Ibs
Add 25 percent safety factor = 12.000 Ibs
Total = 60,000 Ibs
Solid Wastes
The quantity of solid waste is calculated as follows:
Test 1 - 4,883 Ibs/hr x 27 hrs = 501,841 Ibs
Test 2 - 4,883 Ibs/hr x 24 hrs = 117,192 Ibs
Test 3 - 4,000 Ibs/hr x 39 hrs = 156.000 Ibs
Subtotal = 48,000 Ibs
Add 25 percent safety factor = 775.033 Ibs
Total = 501,841 Ibs
Perchloroethylene
The quantity of perchloroethylene is calculated as follows:
Test 1-351 Ibs/hr x 27 hrs = 9,477 Ibs
Test 2-351 Ibs/hr x 24 hrs = 8,424 Ibs
D-5.4-5
-------
Test 3-0 Ibs/hr x 39 hrs = 0 Ibs
Subtotal = 17,901 Ibs
Add 25 percent safety factor = 74.475 Ibs
Total = 22,376 Ibs
Chlorobenzene, Carbon Tetrachloride, Napthalene, and Acetone POHCs
The quantity of chlorobenzene POHCs is calculated as follows:
Test 1 - 0 Ibs/hr x 27 hrs = 0 Ibs
Test 2-20 Ibs/hr x 24 hrs = 480 Ibs
Test 3-0 Ibs/hr x 39 hrs = 0 Ibs
Subtotal = 480 Ibs
Add 25 percent safety factor = 120 Ibs
Total = 600 Ibs
The quantity of carbon tetrachloride POHCs is calculated as follows:
Test 1 - 0 Ibs/hr x 27 hrs = 0 Ibs
Test 2-20 Ibs/hr x 24 hrs = 480 Ibs
Test 3-0 Ibs/hr x 39 hrs = 0 Ibs
Subtotal = 480 Ibs
Add 25 percent safety factor = 120 Ibs
Total = 600 Ibs
The quantity of napthalene POHCs is calculated as follows:
Test 1 - 0 Ibs/hr x 27 hrs = 0 Ibs
Test 2-60 Ibs/hr x 24 hrs = 1,440 Ibs
Test 3-0 Ibs/hr x 39 hrs = 0 Ibs
Subtotal = 1,440 Ibs
D-5.4-6
-------
Add 25 percent safety factor = 360 Ibs
Total = 1,800 Ibs
The quantity of acetone POHCs (for dissolving naphthalene) is calculated as follows:
Test 1 - 0 Ibs/hr x 27 hrs = 0 Ibs
Test 2-100 Ibs/hr x 24 hrs = 2,400 Ibs
Test 3-0 Ibs/hr x 39 hrs = 0 Ibs
Subtotal = 2,400 Ibs
Add 25 percent safety factor = 600 Ibs
Total = 3,000 Ibs
Metal Salts
Certified dispersions of the metal salts described in Tables D-5.4-8 and D-5.4-9 will be procured. The dispersions
will be formulated to permit the metal spiking rates identified in the referenced tables to be achieved by injecting
the dispersions into the liquid and solid wastes at low flow rates (less than 0.1 gallon per minute [gpm]). Required
quantities of metal dispersions will be as follows:
Test 1-0.1 gpm x 60 min/hr x 27 hr
Test 2-0 gpm x 60 min/hr x 24 hr
Test 3-0 gpm x 60 min/hr x 24 hr
Subtotal
Add 25 percent safety factor
Total
162 gallons
0 gallons
0 gallons
162 gallons
40 gallons
202 gallons
D-5.4-7
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TABLE D-5.4-1
EXPECTED COMPOSITION OF HIGH-BTU LIQUID WASTE COMPOSITION (BEFORE SPIKING)
Constituent
Ethanol
Water
High-Btu liquid
Wt.%
80
20
100
Btu/lb
11,943
0
9,554.4
Specific
Gravity
0.79
1.00
0.83
Density
Ob/gal)
6.59
8.34
6.92
%Ash
0.50
0.00
0.40
%Carbon
37.49
0
29.99
%Hydrogen
12.58
11.11
12.28
%Oxygen
49.93
88.89
57.72
%Water
0.00
100.00
20.00
%Chlorine
0.00
0.00
0.00
Notes:
Btu
Btu/lb
Ib/gal
Wt.%
British thermal unit
British thermal units per pound
Pounds per gallon
Weight percent
D-5.4-8
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TABLE D-5.4-2
EXPECTED COMPOSITION OF LOW-BTU LIQUID WASTE (BEFORE SPIKING)
Constituent
Water
Low-Btu liquid
Wt.%
100
100
Btu/lb
0
0
Specific
Gravity
1.00
1.00
Density
Ob/gal)
8.34
8.34
%Ash
0.00
0.00
%Carbo
n
0
0
%Hydrogen
11.11
11.11
%Oxygen
88.89
88.89
%Water
100.00
100.00
%Chlorine
0.00
0.00
Notes:
Btu
Btu/lb
Ib/gal
Wt.%
British thermal unit
British thermal units per pound
Pounds per gallon
Weight percent
D-5.4-9
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TABLE D-5.4-3
SOLID WASTE COMPOSITION (BEFORE SPIKING)
Constituent
Solids
Solids Feed
Btu/lb
224
224
%Carbon
0.66
0.66
%Hydrogen
0.26
0.26
%Oxygen
2.59
2.59
%Nitrogen
0.10
0.10
%Water
8.99
8.99
%Sulfur
0.03
0.03
%Chlorine
0.00
0.00
%Ash
30.70
30.70
Note:
Btu/lb =
British thermal units per pound
D-5.4-10
-------
TABLE D-5.4-4
TARGET FEED RATES FOR ORGANIC CHLORINE AND ASH (TESTS 1 AND 2)
Spiking Substance
Organic Chlorine
Ash
Feed Stream
High-Btu liquid
Low-Btu liquid
Solid waste
Total
High-Btu liquid
Low-Btu liquid
Solid waste
Total
Target Feed Rate (Ibs/hr)
100
100
100
300
50
50
1,500
1,600
Notes:
Btu
Ibs/hr
British thermal unit
Pounds per hour
D-5.4-11
-------
TABLE D-5.4-5
COMPOSITION OF HIGH-BTU LIQUID WASTE FOR TESTS 1 AND 2 (SPIKED WITH CHLORINE AND ASH)
Constituent
High-Btu liquid
Perchloroethylene
Ash (as copper sulfide)
Low-Btu liquid mix
Ibs/hr
2,183
117
40
2,340
Wt.%
94.02
5.00
1.71
100.00
Btu/lbs
9,554.4
~
0
~
Specific
Gravity
0.83
~
3.15
~
Density
(Ibs/gal)
6.92
~
26.27
~
%Chlorine
0.00
85.71
0.00
4.27
Chlorine
(Ibs/hr)
0.00
100.00
0.00
100.00
%Ash
0.40
0.00
100.00
2.14
Ash
(Ibs/hr )
10
0
40
50
Notes:
Btu
Btu/lbs =
Ibs/gal =
Ibs/hr =
Wt.% =
British thermal unit
British thermal units per pounds
Pounds per gallon
Pounds per hour
Weight percent
Not applicable
The test amount of liquid ash is as follows: 2,340 Ibs/hr (rotary kiln + secondary combustion chamber total) x 0.0214 = 50 Ibs/hr
The test amount of chlorine is as follows: 2,340 Ibs/hr (rotary kiln + secondary combustion chamber total) x 0.0429 =100 Ibs/hr
D-5.4-12
-------
TABLE D-5.4-6
COMPOSITION OF LOW-BTU LIQUID WASTE FOR TESTS 1 AND 2 (SPIKED WITH CHLORINE AND ASH)
Constituent
Low-Btu liquid
Perchloroethylene
Ash (as copper sulfide)
Low-Btu liquid mix
Ibs/hr
700
117
47
864
Wt.%
94.02
5.00
1.71
100.00
Btu/lbs
9,554.4
~
0
~
Specific
Gravity
0.83
~
3.15
~
Density
(Ibs/gal)
6.92
~
26.27
~
%Chloride
0.00
85.71
0.00
11.57
Chlorine
(Ibs/hr)
0.00
100.00
0.00
100.00
%Ash
0.40
0.00
100.00
5.79
Ash
(Ibs/hr)
3
0
47
50
Notes:
Btu
Btu/lbs =
Ibs/gal =
Ibs/hr =
Wt.% =
British thermal unit
British thermal units per pound
Pounds per gallon
Pounds per hour
Weight percent
Not applicable
The test amount of liquid ash is as follows: 864 Ibs/hr (rotary kiln + secondary combustion chamber total) x 0.0579 = 50 Ibs/hr
The test amount of chlorine is as follows: 864 Ibs/hr (rotary kiln + secondary combustion chamber total) x 0.1157 = 100 Ibs/hr
D-5.4-13
-------
TABLE D-5.4-7
COMPOSITION OF SOLID WASTE FOR TESTS 1 AND 2 (SPIKED WITH PERCHLOROETHYLENE)
Constituent
Perchloroethylene
Solids
Solids Feed
Ibs/hr
117
4,883
5,000
Wt%
2.34
97.66
100.00
Btu/lbs
~
224
~
%Chlorine
85.71
0.00
2.00
Chlorine
(Ibs/hr)
100
0
100
%Ash
0.00
30.70
29.98
Ash
(Ibs/hr)
0
1,500
1,500
Notes:
Btu
Btu/lbs =
Ibs/hr =
Wt.% =
British thermal unit
British thermal units per pound
Pounds per hour
Weight percent
Not applicable
The test amount of chlorine is as follows: 5,000 Ibs/hr solids feed x 0.02 = 100 Ibs/hr
The test amount of liquid ash is as follows: 5,000 Ibs/hr solids feed x 0.2998 = 1,500 Ibs/hr
D-5.4-14
-------
TABLE D-5.4-8
METALS SPIKING MATERIALS FOR SOLIDS
Metal
Arsenic
Beryllium
Cadmium
Hexavalent chromium
Form
Sodium arsenate (NagAsO4),
heptahydrate
(22.5 wt.% Arsenic)
Beryllium sulfate (BeSO4 ),
tetrahydrate
(5.1 wt.% Beryllium)
Cadium acetate
(Cd(C2H3O2)2),
dihydrate
(42.2 wt.% Cadmium)
Sodium dichromate
(NaAA,),
dihydrate
(34.9 wt.% Chromium)
Metal Target Feed Rate
(Ibs/hr)
0.28
0.12
0.043
0.048
Metal Salt Target Feed
Rate (Ibs/hr)
1.25
2.36
0.1
0.14
Notes:
Ibs/hr = Pounds per hour
wt.% = Weight percent
All values have been rounded to approximate values; actual values may vary.
D-5.4-15
-------
TABLE D-5.4-9
METALS SPIKING MATERIALS FOR LIQUIDS
Metal
Arsenic
Beryllium
Cadmium
Trivalent chromium
Form
Arsenic trioxide (As2O3),
(76.9 wt.% Arsenic)
Beryllium sulfate (BeSO4),
tetrahydrate
(5.1 wt.% Beryllium)
Cadium oxide (CdO),
(87.5 wt.% Cadmium)
Chromic oxide (Cr2O3),
(68.4 wt.% Chromium)
Metal Target Feed Rate
(Ibs/hr)
0.14
0.006
0.043
0.0024
Metal Salt Target Feed Rate
(Ibs/hr)
0.2
0.12
0.05
0.004
Notes:
Ibs/hr = Pounds per hour
wt.% = Weight percent
All values have been rounded to approximate values; actual values may vary.
D-5.4-16
-------
TABLE D-5.4-10
METALS OF CONCERN
Metal
Arsenic
Beryllium
Cadmium
Chromium
TierlH
Emission
Limif
(Ibs/hr)
0.0026
0.00037
0.0027
0.000074
Theoretical
Percent
Volatilization
in the
Kiln
(%)
50e
5"
100"
5"
Theoretical
Percent
APCS
Removal
Efficiency
(%)
98. 5C
95"
95"
97. 5C
Theoretical
Maximum
Liquid
Metals
Feed Rate
(Ibs/hr)
0.173
0.0074
0.054
0.0030
Maximum
Proposed
Trial Burn
Liquids
Metals
Feed Rate
(lbs/hr)d
0.14
0.006
0.043
0.0024
Expected
Metals
Feed Rate in
Actual
Liquid Waste
(Ibs/hr)
0.0052
0.00006
0.00006
0.0005
Theoretical
Maximum
Solids
Metals
Feed Rate
(Ibs/hr)
0.35
0.148
0.054
0.060
Maximum
Proposed
Trial Burn
Solids
Metals
Feed Rate
(lbs/hr)d
0.28
0.12
0.043
0.048
Expected
Metals Feed
Rate
in Actual
Solid Waste
(lbs/hr)d
0.09
0.0006
0.014
0.029
Notes:
APCS
Ibs/hr
= Air pollution control system
= Pounds per hour
"U.S. Environmental Protection Agency Tier III Limits for Metals and Hydrogen Chloride for the Proposed Incinerator, [Enter Company Name}, [Enter
City, State}" [Enter Consultant/Preparer}, [Enter Month Day, Year}.
"Guidance on Metals and Hydrogen Chloride Controls for Hazardous Waste Incinerators," U.S. Environmental Protection Agency (EPA), August 1989.
"Measurement of Particulates, Metals, and Organics at a Hazardous Waste Incinerator," Garg, S., EPA/530-SW-89-067, EPA, Office of Solid Waste,
Washington, B.C., November 1988.
Approximately 80 percent of the Tier IE limit is based on the assumed partitioning factors and removal efficiencies.
"The Behavior of Arsenic in a Rotary Kiln," Robert C. Thurnau, EPA, Cincinnati, Ohio, and Donald Fournier, Jr., Acurex Corporation, Jefferson,
Arkansas, Journal of the Air and Waste Management Association, Vol. 42, No. 2, February 1992.
D-5.4-17
-------
TABLE D-5.4-11
ANTICIPATED DETECTION LIMITS
Metal
Arsenic
Beryllium
Cadmium
Total
Chromium
Stack Detection
Limit
(g/m3)3
2 x 10-6
7 x 10-8
3 x ID'7
7 x 10-7
Back-Half Detection Limit
(Mg/L or ppb)b
3
0.1
0.5
1
Front-Half Detection Limit
Og/L or ppb)c
30
1
5
10
Notes:
g/m3
Mg/L
ppb
Grams per cubic meter
Micrograms per liter
Parts per billion
3 Based on a 3-cubic-meter dry gas sample
b Based on a 2,000-milliliter sample size
0 Based on a 25-milliliter sample size
D-5.4-18
-------
APPENDIX D-5.5
STARTUP PLAN
-------
APPENDIX D-5.5
STARTUP PLAN
This appendix contains the startup plan for the incineration system. The startup plan will address the
15 functional areas described in Section D-5b(l) of the trial burn plan.
D-5.5-1
-------
APPENDIX D-5.6
THERMAL RELIEF VENT OPERATION
-------
APPENDIX D-5.6
THERMAL RELIEF VENT OPERATION
This appendix must include the following information:
• Identification of all conditions that might cause a thermal relief vent opening
• Documentation that a fault-tree analysis was performed to determine the effect of
reliabilities of individual system components on the frequency of failure
• Based on the fault-tree reliability analysis, identification of the components that should be
redundant to reduce frequency of failure
• Continuous data recorder to document openings and duration of openings
• Procedures to cut off waste and minimize emissions
• Calculations to prove bypass height will cause sufficient natural draft to keep negative
pressure at the front of the kiln
• Reporting requirements, including cessation of waste burning if the thermal relief vent
opens for reasons not specified in the permit
• Emission estimates and dispersion modeling to factor into risk assessment, unless
openings are very infrequent
D-5.6-1
-------
APPENDIX D-5.7
SAMPLING STANDARD OPERATING PROCEDURES
-------
APPENDIX D-5.7
SAMPLING STANDARD OPERATING PROCEDURES
CONTENTS
No. Title Page
01 Low-Btu Liquid Waste Feed Sampling Procedure D-5.7-1
02 High-Btu Liquid Waste Feed Sampling Procedure D-5.7-4
03 Solid Waste Feed Sampling Procedure D-5.7-7
04 Incinerator Ash Sampling Procedure D-5.7-9
05 Caustic Solution Sampling Procedure D-5.7-11
06 Air Pollution Control System Purge Water Sampling Procedure D-5.7-13
07 Air Pollution Control System Makeup Water Sampling Procedure D-5.7-16
08 Sampling Procedure for Metals in the Stack Gases D-5.7-18
09 Sampling Procedure for Hexavalent Chromium in the Stack Gases D-5.7-22
10 Sampling Procedure for Volatile Organics in the Stack Gases D-5.7-26
11 Sampling Procedure for Semivolatile Organics and Dioxins and Furans in the
Stack Gases D-5.7-30
12 Sampling Procedure for Polynuclear Aromatic Hydrocarbons in the Stack Gases D-5.7-35
13 Sampling Procedure for Semivolatile and Nonvolatile Unspeciated Mass in the
Stack Gases D-5.7-40
14 Sampling Procedure for Volatile Unspeciated Mass in the Stack Gases D-5.7-45
15 Sampling Procedure for Formaldehyde in the Stack Gases D-5.7-48
16 Sampling Procedure for Hydrogen Chloride, Chlorine, and Particulate in the
Stack Gases D-5.7-52
17 Sampling Procedure for Carbon Monoxide in Stack Gases by CEM D-5.7-55
18 Sampling Procedure for Oxygen in Stack Gases D-5.7-57
19 Sampling Procedure for Total Hydrocarbon in Stack Gases D-5.7-59
20 Sampling Procedure for Carbon Dioxide in the Stack Gases D-5.7-61
21 Sampling Procedure for Sulfur Dioxide in the Stack Gases D-5.7-63
22 Sampling Procedure for Nitrogen Oxides in the Stack Gases D-5.7-64
23 Sampling Procedure for Oxygen and Carbon Dioxide in Stack by Orsat D-5.7-65
24 Sampling Procedure for Opacity in the Stack Gases D-5.7-66
25 Density Measurement D-5.7-67
26 Viscosity Measurement D-5.7-68
27 Heat Content (Btu) Analysis D-5.7-69
28 Total Chlorine Analysis D-5.7-70
29 Ash Content Analysis D-5.7-71
D-5.7-1
-------
CONTENTS (Continued)
No. Title Page
30 Elemental Analysis D-5.7-72
31 Total Dissolved Solids and Total Suspended Solids Analysis D-5.7-73
32 Stack Moisture Content D-5.7-74
33 Analysis of Semivolatile PICs and Dioxins and Furans in MM5 Samples D-5.7-75
34 Analysis of Polynuclear Aromatic Hydrocarbons in MM5 Samples D-5.7-78
35 Analysis of Semivolatile and Nonvolatile Unspeciated Mass in MM5 Samples D-5.7-80
36 Analysis of Formaldehyde in MM5 Samples D-5.7-82
37 Analysis of Metals in Liquids and Solid Waste D-5.7-83
38 Analysis of Multi-Metals Train Samples D-5.7-85
39 Analysis of POHCs in Liquids, Solid and Ash Samples D-5.7-87
40 Analysis of Volatile PICs in Volatile Organic Sampling Train (VOST) Samples D-5.7-88
41 Analysis of Hydrogen Chloride, Chlorine, and Parti culate Train Samples D-5.7-89
42 Analysis of Hexavalent Chromium Samples from the Cr+6 Train D-5.7-91
43 Analysis of Volatile Total Chromatographable Organics in SW-0040 Samples D-5.7-93
44 Analysis of Semivolatile Total Chromatographable Organics D-5.7-95
45 Analysis of GRAV in Organic Extracts D-5.7-97
46 Analysis of Volatile Total Chromatographable Organics in SW-0040 Samples D-5.7-99
D-5.7-ii
-------
APPENDIX D-5.7
SAMPLING STANDARD OPERATING PROCEDURES
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Locations:
Sampling and
Health and Safety Equipment:
01
Low-Btu Liquid Waste Feed Sampling Procedure
Low-Btu liquid waste feed
Field sampling specialist
The sample tap will be located on the liquid waste feed line upstream of
the spiking input points of the metal, principal organic hazardous
constituents, and ash.
Glass sample collection bottles (1-gallon Wheaton jug and 1-liter
Boston-round glass bottles) with Teflon™-lined lids, pre-cleaned glass
graduated cylinders, 40-milliliter) volatile organic analysis (VOA) vials
with Teflon™-lined septa, full face respirator (if required), safety glasses
(if respirator is not required), and latex gloves
Sample Collection Frequency: A grab aliquot will be taken at the beginning of testing and at 15-minute
intervals for the duration of each test run.
Sampling Procedures:
The nonvolatile parameter samples will be collected by building a master
composite sample of the liquid waste feed in the 1-gallon Wheaton jug.
At the completion of the run, subsamples of the master composite will be
collected for the ultimate, proximate, british thermal unit (Btu) output, ash
content, viscosity, and density analyses. The 1-gallon sample will be
shaken vigorously before pouring off subsamples.
Sampling for Nonvolatile Parameters—Purge the sampling tap by
allowing at least three tap volumes of liquid to flow into a waste
container. Next, collect a measured grab volume of sample
(approximately 200 mL) at each 15-minute interval. Add each grab
volume to a numbered, prelabeled 1-gallon Wheaton jug to build the final
composite. Grab portions will be stored on ice during the implementation
of the sampling run. On the sample collection sheet, record the date and
time that each grab sample was taken and the approximate volume of the
final composite sample.
At the conclusion of the test run, shake the 1-gallon composite sample
vigorously to provide good mixing, and fill a numbered and prelabeled
1-liter Boston-round bottle from the composite. On the sample collection
D-5.7-1
-------
Sample Preservation:
Documentation and
Record-keeping:
Quality Assurance and
sheet, document that the aliquot was removed from the original
composite. The 1-liter sample will be used for proximate analyses. The
balance of original composite sample is retained for other nonvolatile
analyses. Check the label and number of both composite samples for
sample tracking quality assurance.
VOA Sampling—Concurrent with nonvolatile sampling at each
15-minute interval, collect a pair of 40-mL VOA vials so as to exclude
headspace bubbles. Label and number each pair of VOA vials with
sample numbers for individual VOA pair tracking. Record the date and
time that each VOA pair was taken on the sample collection sheet.
Volatile sample compositing will be conducted in the controlled
environment of the laboratory.
Note that liquid samples that contain mostly solvents or an organic
compound form a convex meniscus at the top of the VOA vial. Under
these conditions, a headspace free sample cannot be obtained. This
information will be recorded on the sample collection sheets.
The nonvolatile liquid waste feed sample portions require storage on ice
throughout testing and sample transport to the laboratory. If residual
chlorine is expected in these samples, volatile samples in VOA vials will
be prepreserved by adding four drops of 0.008 percent sodium thiosulfate
to each VOA vial before sampling commences and also will be stored on
ice during and after the test run. When the samples are shipped to the
laboratory, they will be shipped with a sufficient amount of ice so as to
arrive at the laboratory cold (4 °C + 2 °C).
Caution: The liquid waste feed samples will be stored on ice in an area
away from the sample trailer where train samples are being handled,
away from other trace-analyte-containing samples and away from the
sample container supply area.
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, the date, and the time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the low-Btu waste
feed. The time that each aliquot of the waste stream is collected will be
logged as it is collected. The sample collection sheet will provide a place
to record the sample number, project name, the run number, the
sampler's name, the sample type, sample description, sample source, the
bottle type, and the date and time of each grab collection. The sampling
coordinator also will record all samples collected into a field logbook.
This logbook will serve as the master document listing of all of the trial
burn samples collected.
D-5.7-2
-------
Quality Control: The required number of analyses for these samples is defined in Table
10-1 of the quality assurance project plan. The laboratory is required to
analyze separately all of the field samples, field quality control samples,
and laboratory quality control samples specified in Table 10-1.
Method References: Method S004, EPA-600/8-84-002 [S004 is a tap sampling method
appropriate for sampling liquid wastes in pipes or process lines]. Taken
from Harris, J.C.; Rechsteiner, C.E.; Larson D.J.; Thrun, K.E.;
Combustion of Hazardous Wastes, Sampling and Analysis Methods',
Noyes: New Jersey, 1985.
"Practice for Manual Sampling of Petroleum and Petroleum Products."
ASTM D-4057-88. Taken from Annual Book ofASTM Standards.
D-1989-93. American Society for Testing and Materials; ASTM:
Philadelphia, PA, 1996.
D-5.7-3
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Locations:
Sampling and
Health and Safety Equipment:
02
High-Btu Liquid Waste Feed Sampling Procedure
High-Btu liquid waste feed
Field sampling specialist
The sample tap will be located on the liquid waste feed line upstream of
the spiking input points of the metal, principal organic hazardous
constituents, and ash.
Glass sample collection bottles (1-gallon Wheaton jug and 1-liter
Boston-round glass bottles) with Teflon™-lined lids, pre-cleaned glass
graduated cylinders, 40-milliliter (mL) volatile organic analysis (VOA)
vials with Teflon™-lined septa, full-face respirator (if required), safety
glasses (if respirator is not required), and latex gloves
Sample Collection Frequency: A grab aliquot will be taken at the beginning of testing and at 15-minute
intervals for the duration of each test run.
Sampling Procedures:
The nonvolatile parameter samples will be collected by building a master
composite sample of the liquid waste feed in the 1-gallon Wheaton jug.
At the completion of the run, subsamples of the master composite will be
collected for the ultimate, proximate, british thermal unit (Btu) output, ash
content, viscosity, and density analyses. The 1-gallon sample will be
shaken vigorously before pouring off subsamples.
Sampling for Nonvolatile Parameters—Purge the sampling tap by
allowing at least three tap volumes of liquid to flow into a waste
container. Next, collect a measured grab volume of sample
(approximately 200 mL) at each 15-minute interval. Add each grab
volume to a numbered, prelabeled 1-gallon Wheaton jug to build the final
composite. Grab portions will be stored on ice during the implementation
of the sampling run. On the sample collection sheet, record the date and
time that each grab sample was taken, and the approximate volume of
the final composite sample.
At the conclusion of the test run, shake the 1-gallon composite sample
vigorously to provide good mixing, and fill a numbered and prelabeled
1-liter Boston-round bottle from the composite. On the sample collection
sheet, document that the aliquot was removed from the original
composite. The 1-liter sample will be used for proximate analyses. The
balance of original composite sample is retained for other nonvolatile
analyses. Check the label and number of both composite samples for
sample tracking quality assurance.
D-5.7-4
-------
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
VOA Sampling—Concurrent with nonvolatile sampling at each
15-minute interval, collect a pair of 40-mL VOA vials so as to exclude
headspace bubbles. Label and number each pair of VOA vials with
sample numbers for individual VOA pair tracking. Record the date and
time that each VOA pair was taken on the sample collection sheet.
Volatile sample compositing will be conducted in the controlled
environment of the laboratory.
Note that liquid samples that contain mostly solvents or an organic
compound form a convex meniscus at the top of the VOA vial. Under
these conditions, a headspace free sample cannot be obtained. This
information will be recorded on the sample collection sheets.
The nonvolatile liquid waste feed sample portions require storage on ice
throughout testing and sample transport to the laboratory. If residual
chlorine is expected in these samples, volatile samples in VOA vials will
be prepreserved by adding four drops of 0.008 percent sodium thiosulfate
to each VOA vial before sampling commences and also will be stored on
ice during and after the test run. When the samples are shipped to the
laboratory, they will be shipped with a sufficient amount of ice so as to
arrive at the laboratory cold (4 °C + 2 °C).
Caution: The liquid waste feed samples will be stored on ice in an area
away from the sample trailer where train samples are being handled,
away from other trace-analyte-containing samples and away from the
sample container supply area.
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, the date, and the time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the low-Btu waste
feed. The time that each aliquot of the waste stream is collected will be
logged as it is collected. The sample collection sheet will provide a place
to record the sample number, project name, the run number, the
sampler's name, the sample type, sample description, sample source, the
bottle type, and the date and time of each grab collection. The sampling
coordinator will also record all samples collected into a field logbook.
This logbook will serve as the master document listing of all of the trial
burn samples collected.
The required number of analyses for these samples is defined in Table
10-1 of the quality assurance project plan. The laboratory is required to
analyze separately all of the field samples, field quality control samples,
and laboratory quality control samples specified in Table 10-1.
D-5.7-5
-------
Method References: Method S004, EPA-600/8-84-002 [S004 is a tap sampling method
appropriate for sampling liquid wastes in pipes or process lines]. Taken
from Harris, J.C.; Rechsteiner, C.E.; Larson D.J.; Thrun, K.E.;
Combustion of Hazardous Wastes, Sampling and Analysis Methods;
Noyes: New Jersey, 1985.
"Practice for Manual Sampling of Petroleum and Petroleum Product."
ASTM D-4057-88. Taken from Annual Book ofASTM Standards.
D-1989-93. American Society for Testing and Materials; ASTM:
Philadelphia, PA, 1996.
D-5.7-6
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Locations:
Sampling and Health and
Safety Equipment:
03
Solid Waste Feed Sampling Procedure
Solid waste feed
Field sampling specialist
The sample will be located in the ram feeder operations or conveyor belt
delivery area (solid feed). A sample of the solid waste feed will be taken
upstream of the addition of any chlorine source chemical ash spiking or
metals spiking materials.
Sampling scoop, glass sample collection jars (1-liter [L] wide-mouth
powder glass jar, 120-milliliter [mL] glass, 250-mL wide-mouth glass)
with Teflon™-lined lids, latex gloves, and eye protection
Sample Collection Frequency: One grab aliquot will be collected at the beginning of testing and at
15-minute intervals for the duration of each test run.
Sampling Procedures:
Sample Preservation:
Documentation and
Record-Keeping:
Three grab samples of the solid waste feed material will be collected at
the beginning of the test run: a 250-mL wide-mouth sample collection jar
for the proximate-type analysis, a full-120 mL wide-mouth sample
collection jar for volatile analysis, and a 1-L glass sample collection jar
for other nonvolatile analyses. All jars will be sealed with Teflon™-lined
lids. The 120-mL volatile sample jar will contain as little headspace as
possible. Record the date and time that the grab samples were taken on
the sample collection sheet. At the conclusion of sampling, check the
label and number of each sample for sampling tracking quality assurance.
All samples of the incinerator solid waste feed will be stored on ice
throughout testing and sample transport to the laboratory. When the
samples are shipped to the analytical laboratory, they will be shipped with
a sufficient amount of ice so as to arrive at the laboratory cold
(4°C±2°C).
Caution: The solid waste feed samples will be stored on ice in an area
outside of the sample trailer where train samples are being handled,
away from other trace analyte containing samples and away from the
sample container supply area.
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, the date, and the time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the solid waste
D-5.7-7
-------
Quality Assurance and
Quality Control:
Method References:
feed. The time that each aliquot of the waste stream is collected will be
logged as it is collected. The sample collection sheet will provide a place
to record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will also record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in Table
10-1 of the quality assurance project plan. The laboratory is required to
analyze separately all of the field samples, field quality control samples,
and laboratory quality control samples specified in Table 10-1.
Method S007, EPA-600/8-84-002 [S007 is a trowel or scoop sampling
method appropriate for sampling solid waste materials such as soil or
ash]. Taken from Harris, J.C.; Rechsteiner, C.E.; Larson D.J.; Thrun,
K.E.; Combustion of Hazardous Wastes, Sampling and Analysis
Methods', Noyes: New Jersey, 1985.
"Practice for Manual Sampling of Petroleum and Petroleum Products."
ASTM D-4057-88. Taken from Annual Book ofASTM Standards.
D-1989-93. American Society for Testing and Materials; ASTM:
Philadelphia, PA, 1996.
D-5.7-8
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Locations:
Sampling and Health and
Safety Equipment:
04
Incinerator Ash Sampling Procedure
Incinerator ash
Field sampling specialist
The sample will be located in the rotary kiln ash discharge or conveyor
belt delivery area.
Sampling scoop, glass sample collection jars (1-liter [L] wide-mouth glass
powder jar, 120-milliliter [mL] wide-mouth glass powder jar, 250-mL
wide-mouth glass powder jar) with Teflon™-lined lids, aluminum foil,
latex gloves, and eye protection
Sample Collection Frequency: Grab aliquots will be collected at the beginning of testing and at
30-minute intervals for the duration of each test run.
Sampling Procedures:
The nonvolatile parameter and proximate-type samples will be collected
by building a master composite sample of the incinerator ash. At the
completion of the run, subsamples will be collected for the
proximate-type analyses.
Samples for Nonvolatile Parameters—Collect grab samples
(approximately 100 mL each) of the incinerator ash at 30-minute
intervals. Composite each grab sample into a 1-L wide-mouth powder
jar over the course of each run. On the sample collection sheet, record
the date and time that each grab sample was taken and approximate
volume of final composite sample. At the end of the test run, use the
sampling scoop as a mixing tool and the aluminum foil as a working
surface to blend the ash grab samples thoroughly. Alternately, if the
sample can be mixed sufficiently by agitation, then shaking can be done.
Collect an aliquot of the blended ash material in a 250-mL wide-mouth
powder jar for proximate-type analysis. Retain the balance of the ash
composite in the 1-L wide-mouth powder jar for other nonvolatile
analyses. Seal all jars with a Teflon™-lined lids. On the sample
collection sheet, document that the aliquot was removed from the original
composite. Check the label and number of both composite samples for
sample tracking quality assurance.
VOA Sampling—Concurrent with the non-VOA sampling, collect a full
120-mL sample in a wide-mouth powder jar at the beginning and at each
30-minute interval for volatile analysis. Label and number each 120-mL
sample with sample numbers for individual sample tracking. On the
sample collection sheet, record the date and time that each VOA sample
D-5.7-9
-------
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Method References:
was taken. Volatile sample compositing will be conducted in the
controlled environment of the laboratory.
All incinerator ash samples will be stored on ice throughout testing and
sample transport to the laboratory and will be stored away from the
sample container supply area. Samples will be shipped with a sufficient
amount of ice so as to arrive at the analytical laboratory cold (4 °C ±
2 °C).
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, the date and the time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the incinerator ash.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
Method S007, EPA-600/8-84-002 [S007 is a trowel or scoop sampling
method appropriate for sampling solid waste materials such as soil or
ash]. Taken from Harris, J.C.; Rechsteiner, C.E.; Larson D.J.; Thrun,
K.E.; Combustion of Hazardous Wastes, Sampling and Analysis
Methods; Noyes: New Jersey, 1985.
"Practice for Manual Sampling of Petroleum and Petroleum Products."
ASTM D-4057-88. Taken from Annual Book ofASTM Standards.
D-1989-93. American Society for Testing and Materials; ASTM:
Philadelphia, PA, 1996.
D-5.7-10
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Location:
05
Caustic Solution Sampling Procedure
Caustic solution
Field sampling specialist
The sample will be located at the tap on the caustic feed supply line.
Sampling and
Health and Safety Equipment: Amber glass sample collection jar (1-gallon Wheaton jug with
Teflon™-lined lid), 40-milliliter (mL) volatile organic analysis (VOA)
vials with Teflon™-lined septa, latex gloves, and eye protection
Caution: The pH of this sample will be greater than 12. Care will be
taken to avoid spilling or splashing this sample when it is collected. Skin
or eye contact with this sample matrix will cause severe burns.
Sample Collection Frequency: One grab sample will be taken per sampling run.
Sampling Procedures:
Sample Preservation:
Documentation and
Record-Keeping:
A sample of the caustic solution will be collected and analyzed for each
sampling run. Caustic solution samples will be collected from the sample
tap location on the caustic solution supply line.
Samples for Nonvolatile Parameters—Collect approximately 1 gallon of
caustic solution in the 1-gallon amber glass Wheaton jug, and seal with a
Teflon™-lined lid. Check the label and number of the sample for sample
tracking quality assurance. Record the date, time, and sample number on
the sample collection sheet.
VOA Samples—Collect samples in one pair of 40-mL VOA vials so as
to eliminate headspace bubbles. Check the label and number of the pair
of VOA vials for sample tracking quality assurance. Record the date,
time, and sample number on the sample collection sheet.
The caustic solution samples will not be chilled with ice during or after
collection if precipitation of solids is observed during the chilling of the
sample. Chilling may cause precipitation of solid sodium hydroxide from
the caustic solution. Also, volatile samples in VOA vials will not be
preserved if precipitation occurs. Caustic solution samples will be shipped
to the analytical laboratory without ice if precipitation occurs.
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, the date and the time of sampling. The sampler will fill out a
D-5.7-11
-------
Quality Assurance and
Quality Control:
Method References:
sample collection sheet for every sample collected of the caustic solution.
The time that each sample of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
Method S004, EPA-600/8-84-002 [S004 is a tap sampling method
appropriate for sampling liquid wastes in pipes or process lines]. Taken
from Harris, J.C.; Rechsteiner, C.E.; Larson D.J.; Thrun, K.E.;
Combustion of Hazardous Wastes, Sampling and Analysis Methods;
Noyes: New Jersey, 1985.
"Practice for Manual Sampling of Petroleum and Petroleum Products."
ASTM D-4057-88. Taken from Annual Book ofASTM Standards.
D-1989-93. American Society for Testing and Materials; ASTM:
Philadelphia, PA, 1996.
D-5.7-12
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Locations:
Sampling and
Health and Safety Equipment:
06
Air Pollution Control System Purge Water Sampling Procedure
Scrubber purge water
Field sampling specialist
The sample will be located at the sample tap on the scrubber purge water
recirculation line.
Glass sample collection jars (1-gallon Wheaton jug, and 1-liter [L]
Boston-round glass jars) with Teflon™-lined lids, pre-cleaned glass
graduated cylinders, 40-mL volatile organic analysis (VOA) vials with
Teflon™-lined septa, full face respirator (if required), safety glasses (if
respirator not required), and latex gloves
Sample Collection Frequency: A grab aliquot will be taken at the beginning of testing and at 30-minute
intervals for the duration of each test run.
Sampling Procedures:
Samples for Nonvolatile Parameters—The nonvolatile parameters will be
collected by building a master composite sample of the purge stream. At
the completion of the run, subsamples of the master composite sample
will be collected for the proximate analyses. Purge the tap by allowing at
least three tap volumes of liquid to flow into a waste container. Collect a
measured grab volume of sample (approximately 400 mL) at each time
interval to build a final composite sample of approximately 1-gallon. Add
each grab to a numbered, prelabeled 1-gallon Wheaton jug to build the
final composite. Grab portions are to be stored on ice during the
implementation of the sampling run. On the sample collection sheet,
record the date and time that each grab sample was taken and
approximate volume of the final composite sample.
At the conclusion of the test run, shake the 1-gallon composite sample to
provide good mixing, and fill a numbered and prelabeled 1-L
Boston-round jar from the composite. On the sample collection sheet,
document that the aliquot was removed from the original composite. The
1-L sample will be used for total solids, total suspended solids, and total
dissolved solids analyses. The balance of original composite sample is
retained for other nonvolatile analyses. Check the label and number of
both composite samples for sample tracking quality assurance.
Caution: The scrubber purge water master composite sample may
contain a relatively high amount of solids. Subsampling will require
thorough shaking of the composite samples followed by immediate
pouring of the subsample.
D-5.7-13
-------
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Method References:
VOA Sampling—Concurrent with non-VOA sampling at each time
interval, collect a pair of samples in 40-mL VOA vials so as to minimize
headspace bubbles. Label and number each pair of VOA vials with
sample numbers for individual sample tracking. On the sample collection
sheet, record the date and time that each VOA sample was taken.
Volatile sample compositing will be conducted in the laboratory.
Note: The scrubber purge water may be sampled from a location in the
recirculation line that delivers hot sample material. Hot sample that is
placed into VOA vials will cavitate when cooled. The scrubbeer purge
water in these sample vials either will have to be "topped off after they
have cooled, or will have to be chilled before delivery to the VOA vials.
The nonvolatile purge stream sample portions require storage on ice
throughout testing and sample transportation to the laboratory. If residual
chlorine is suspected in these samples, then volatile samples in VOA vials
will be prepreserved by adding four drops of 0.008 percent sodium
thiosulfate to each VOA vial before sampling commences. Samples in
VOA vials also will be stored on ice during and after the test run.
Samples will be stored away from the sample container supply area.
When the samples are shipped to the analytical laboratory, they will be
shipped on ice and will arrive at the laboratory cold (4 ° C + 2 °C)
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, the date and the time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the purge stream.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in Table
10-1 of the quality assurance project plan. The laboratory is required to
analyze separately all of the field samples, field quality control samples,
and laboratory quality control samples specified in Table 10-1.
Method S004, EPA-600/8-84-002 [S004 is a tap sampling method
appropriate for sampling liquid wastes in pipes or process lines]. Taken
from Harris, J.C.; Rechsteiner, C.E.; Larson D.J.; Thrun, K.E.;
Combustion of Hazardous Wastes, Sampling and Analysis Methods;
Noyes: New Jersey, 1985.
D-5.7-14
-------
"Practice for Manual Sampling of Petroleum and Petroleum Products."
ASTM D-4057-88. Taken from Annual Book ofASTM Standards.
D-1989-93. American Society for Testing and Materials; ASTM:
Philadelphia, PA, 1996.
D-5.7-15
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Locations:
Sampling and
Health and Safety Equipment:
Sample Collection Frequency:
Sampling Procedures:
07
Air Pollution Control System Makeup Water Sampling Procedure
Makeup water
Field sampling specialist
The sample will be located at the sample tap on the makeup water line.
Glass sample collection jars (1-gallon Wheatonjug and 1-liter [L]
Boston-round glass jars) with Teflon™-lined lids, precleaned glass
graduated cylinders, 40-mL volatile organic analysis (VOA) vials with
Teflon™-lined septa, full-face respirator (if required), safety glasses (if
respirator not required), and latex gloves
A grab aliquot will be taken at the beginning of testing and at 30-minute
intervals for the duration of each test run.
The nonvolatile parameter samples will be collected by building a master
composite sample of the makeup water. At the completion of the run,
subsamples of the master composite sample will be collected for analysis
of any non-principal organic hazardous constituent (POHC) that may be
required on this sample (such as metals).
Samples for Nonvolatile Parameters—Purge tap by allowing at least
three tap volumes of liquid to flow into a waste container. Collect a
measured grab volume of sample (approximately 400 mL) at each time
interval to build a final composite sample of approximately 1 gallon. Add
each grab to a numbered, prelabeled 1-gallon Wheatonjug to build the
final composite. Grab portions are to be stored on ice during the
implementation of the sampling run. On the sample collection sheet,
record the date and time that each grab sample was taken and the
approximate volume of the final composite sample.
At the conclusion of the test run and if special additional parameters
have been required, shake the 1-gallon composite sample to provide good
mixing, and fill a numbered and prelabeled 1-L jar from the composite.
Disregard this step if the makeup water is being analyzed only for
POHCs. Document that the aliquot was removed from the original
composite on the sample collection sheet. The balance of original
composite sample is retained for other analyses. Check the label and
number of both composite samples for sample tracking quality assurance.
D-5.7-16
-------
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Method References:
VOA Sampling—Concurrent with nonvolatile sampling at each time
interval, collect a pair of 40-mL VOA vials so as to minimize headspace
bubbles. Label and number each pair of VOA vials with sample
numbers for individual sample tracking. On the sample collection sheet,
record the date and time that each VOA sample was taken. Volatile
sample compositing will be conducted in the laboratory.
The nonvolatile makeup water sample portions require storage on ice
throughout testing and sample transport to the laboratory. If residual
chlorine is expected in these samples, then volatiles samples in VOA
vials will be prepreserved by adding four drops of 0.008 percent sodium
thiosulfate to each VOA vial before sampling commences and also will
be stored on ice during and after the test run. When the samples are
shipped to the analytical laboratory, they will be shipped with a sufficient
amount of ice and will arrive at the laboratory cold (4 °C + 2 °C).
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, and the date and time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the makeup water.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
Method S004, EPA-600/8-84-002 [S004 is a tap sampling method
appropriate for sampling liquid wastes in pipes or process lines]. Taken
from Harris, J.C.; Rechsteiner, C.E.; Larson D.J.; Thrun, K.E.;
Combustion of Hazardous Wastes, Sampling and Analysis Methods;
Noyes: New Jersey, 1985.
"Practice for Manual Sampling of Petroleum and Petroleum Products."
ASTM D-4057-88. Taken from Annual Book ofASTM Standards.
D-1989-93. American Society for Testing and Materials; ASTM:
Philadelphia, PA, 1996.
D-5.7-17
-------
D-5.7-18
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Location:
Sampling and
Health and Safety Equipment:
08
Sampling Procedure for Metals in the Stack Gases
Stack gas multi-metals train (MMT)
Stack sampling engineer
The sample will be located at the stack sampling platform.
Note: Blank corrections will not be allowed on data from this train.
Sample containers can be a significant source of a metal's background,
so only U.S. Environmental Protection Agency (EPA) Level III bottles
will be used to collect samples. The narrow neck style (Boston round) is
recommended because it is designed to seal in liquids, whereas a
wide-mouth design (Packer bottles) is prone to leak and can cause
contamination of the sample at the lid by allowing solutions to get behind
the Teflon™ insert; therefore, Packer bottles are not allowed. The
narrow neck style has built-in seals in the lids. Bottles and petri dishes
will be made of glass and cleaned by the glassware cleaning procedure.
The cleaning procedure requires that all glassware be soaked in a
10 percent nitric acid solution for 4 hours.
EPA Method 5 MMT, glass petri dish with particulate filter and impinger
chemical reagents, glass sample containers with Teflon™-lined lids, and
latex gloves
Sample Collection Frequency: Samples will be collected continuously for the duration of each sampling
run. Typically, the stack gas sample volume will be 2 cubic meters
sampled at a sampling rate not to exceed 0.75 cubic meter per hour.
Sampling Procedures:
The sampling train is assembled with a particulate filter; an empty first
impinger to knockout moisture; 100 milliliters (mL) of a 5 percent nitric
acid and 10 percent hydrogen peroxide solution in the second and third
impingers; an empty fourth impinger; 100 mL of a 4 percent potassium
permanganate and 10 percent sulfuric acid solution in the fifth and sixth
impingers, and indicating silica gel in the seventh impinger. The fourth
impinger is intentionally left empty to prevent carryover of any reagents.
The impinger containing the indicating silica gel will be weighed initially to
the nearest 0.5 gram.
An initial traverse will be made with a pitot tube at each sample port
following EPA Methods 1 and 2 to establish the stack velocity profile,
temperature, and flow rate, and to check for cyclonic air flow. Sample
point location will be in accordance with EPA Method 1. The total
sampling time during a run will be approximately 3 hours with a nominal
D-5.7-19
-------
2 dry standard cubic meters of sample collected. EPA Method 5
procedures are followed for pre-test and post-test leak checks, isokinetic
sampling rate, filter change-outs (if needed), port changes, and data
recording.
Sample Recovery—The probe section of the sampling train will be
removed after the final leak check has passed the required criteria. The
probe filter assembly and impinger box of the sampling train are
transferred intact to the cleanup area for sample recovery as follows:
• The participate filter is removed from its holder and carefully
placed into its original glass petri dish, which is sealed with
Teflon™ tape and sealed in a Ziplock™ bag for shipment.
Note: The acetone probe rinsing procedure will be eliminated if
the determination of particulate emissions is not part of the
MMT.
• The internal surfaces of the nozzle, probe, and front half of the
filter holder are cleaned by repeated rinsing with acetone and
brushing with a nonmetallic brush. The acetone rinsates are
collected together into a prelabeled, numbered sample collection
container. The same train components are then rinsed with a
0.1 normality (N) nitric acid solution, brushed, and given a final
nitric acid rinse. These nitric acid rinsates are collected together
in a separate, prelabeled, numbered sample container.
• The volumetric contents of the first three impingers (1,2, and 3)
are measured to the nearest 0.5 mL individually and delivered
into a single, numbered, prelabeled sample container. The
impingers are then rinsed with a 0.1N nitric acid solution, which
is then added to the sample collection bottle.
• Note: The final volume (or weight gain) of these three
impingers is required for moisture gain calculations. The final
volume including rinse volumes must also be recorded also in
order to calculate the target metals' train total content. This note
applies to all impinger catches from this train.
• The volumetric contents of impinger 4 (which began empty) is
measured to the nearest 0.5 mL using a graduated cylinder and
delivered to a single, numbered, pre-labeled sample container.
The fourth impinger is then rinsed with a 0. IN nitric acid solution
and added to the sample container. This sample will be analyzed
separately for mercury.
D-5.7-20
-------
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
• The volumetric contents of the fifth and sixth impinger catches
are measured individually to the nearest 0.5 mL and delivered
into a single, numbered, prelabeled sample container. The
impingers are then rinsed with the 4 percent potassium
permanganate and 10 percent sulfuric acid solution and followed
by a rinse with 100 mL of deionized water, which is then added
to the same sample collection bottle. Each 100-mL portion is
sufficient to afford three rinses of each impinger. This sample
composite will be analyzed separately for mercury.
• If no visible deposits remain after the water rinse, then no further
rinse is needed. However, if the impinger surfaces have
remaining deposits or coloration, rinse all surfaces of the fifth and
sixth impingers with 25 mL of 8N hydrogen chloride, taking care
to contact all sides of the glassware. Finally, deliver the 25 mL
of acid to a separate, numbered, prelabeled sample container.
This sample composite will be analyzed separately for mercury.
• The indicating silica gel contents of the seventh silica gel
impinger are weighed to the nearest 0.5 gram to determine the
amount of moisture collected. Note the color of the indicating
silica gel, and make a notation of its condition.
When the samples are shipped to the analytical laboratory, they will be
shipped with a sufficient amount of ice and will arrive at the laboratory
cold(4°C±2°C).
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, and the date and time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the makeup water.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in Table
10-1 of the quality assurance project plan. The laboratory is required to
analyze separately all of the field samples, field quality control samples,
and laboratory quality control samples specified in Table 10-1.
D-5.7-21
-------
A complete multi-metals blank train will be prepared once during the test
burn series and will be located near the base of the stack in a manner
similar to the actual MMT. All associated leak checks will be conducted
on the blank train. The blank train will remain sealed with its filter box
and probe heated to the required temperature at that location during one
test run. The blank train samples will be recovered using the same
procedures as those described for the actual sampling trains.
Note: Blank corrections will not be allowed for any of these blank
samples. Blanks demonstrate that sampling equipment, technique, and
handling do not contaminate these samples.
The glassware for performing the MMT metals emissions tests is prone
to display memory effects for several metals unless it is carefully
prepared before testing. MMT glassware for the actual testing and for
the blank train (including spare parts, bottles, and petri dishes) will be
prepared by the following metals removal procedure:
• Wash and rinse all glassware with hot soapy water and regular
tap water. Soak all glassware in a 10 percent nitric acid solution
(approximate) for 4 hours. Rinse thoroughly with deionized
water, followed by acetone, and finally leave to air dry. Brushes
and probe rams will be nonmetallic and receive the same
cleaning as glassware.
Reagent blanks for each of the following solutions or sampling media will
be collected as individual samples and submitted to the laboratory for
analysis:
0. IN nitric acid
Particulate filter
5 percent nitric acid and 10 percent hydrogen peroxide
4 percent potassium permanganate and 10 percent sulfuric acid
8N hydrogen chloride
All bottles containing liquid samples will be marked on the outside of the
container to show the height of fluid level so that leakage during shipment
can be demonstrated not to have occurred.
Method References: "Test Methods." 40 CFR 60 Appendix A, EPA Methods 1, 2, 3, and 5.
D-5.7-22
-------
"Method 0060 - Determination of Metals in Stack Emissions." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method 0060, Third Edition, September 1986. Final
Update I (July 1992), Final Update IIA (August 1993), Final Update II
(September 1994), Final Update IIB (January 1995), and Final Update III
(December 1996). U.S. Environmental Protection Agency, Office of
Solid Waste and Emergency Response, Washington, D.C. 20460.
D-5.7-23
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
09
Sampling Procedure for Hexavalent Chromium in the Stack Gases
Stack gas hexavalent chromium recirculatory train
Stack sampling engineer
Process Sample Location: The sample will be located at the stack sampling platform.
Sampling and
Health and Safety Equipment:
U.S. Environmental Protection Agency (EPA) hexavalent chromium
recirculatory sampling train, equipped with a peristaltic pump, Teflon™
fittings and connecting tubes for recirculation, Teflon™ impingers with
Teflon™ connectors, and 0.1 normality (N) to l.ON potassium hydroxide
impinger solution, deionized water, and indicating silica gel; glass sample
bottles with Teflon™-lined lids; nitrogen purge system and nitrogen
pressure filtration system; and latex gloves
Sample Collection Frequency: Samples will be collected continuously for the duration of each sampling
run; typically, the stack gas sample volume will be 2 cubic meters
sampled at a rate not to exceed 0.75 cubic meters per hour. Three runs
will constitute a test.
Sampling Procedures:
Note: Typically, the 0. IN potassium hydroxide specified in the method
is not concentrated enough to maintain the pH greater than or equal to
8.5 throughout the test. If the first impinger falls below pH 8.5, the
hexavalent chromium will convert to trivalent chromium, and the test run
will be invalid. Therefore, a more concentrated potassium hydroxide
impinger solution is recommended. Increases in strength to l.ON
potassium hydroxide is advised.
Train Preparation—Prior to the on-site sample collections, all
components of the sampling train and filtration apparatus will be cleaned
according to the method specifications. The stack gas sampling
collection equipment will be calibrated in accordance with SW-846
Method 0061 and Method 5 standard protocols.
The sampling train is assembled as specified in the SW-846 Method
0061. The first impinger will be charged with 150 milliliters (mL) of the
0. IN potassium hydroxide impinger solution, and approximately 75 mL of
potassium hydroxide impinger solution will be placed in the second and
third impingers. The fourth impinger will be a stack gas condensate
knockout trap and will remain empty. The fifth impinger will contain
indicating silica gel weighed to the nearest 0.5 gram.
D-5.7-24
-------
Sample Train Operation—An initial traverse is made with a pitot tube at
each sample port following EPA Methods 1 and 2 to establish the stack
velocity profile, temperature, and flow rate and to check for cyclonic air
flow. Sample point location will be in accordance with EPA Method 1.
The total sampling time during a run will be approximately 4 hours with a
nominal 3 dry standard cubic meters of sample collected. EPA Method 5
procedures are followed for pretest and post-test leak checks, isokinetic
sampling rate, port changes, and data recording.
Immediately before sample collection, a thorough check of the
recirculation system of the first impinger to the probe will be performed,
and then the system will be started. The potassium hydroxide
recirculating system will be cooled in an ice bath during sample
collection.
Hexavalent Chromium Train Sample Recovery—The entire hexavalent
chromium train will be moved intact to the cleanup area for sample
recovery as follows:
• With the sample train intact and the impinger 4 outlet opened, a
nitrogen cylinder purge system will be connected to the input of
the impinger of the hexavalent chromium train. The recirculation
line will be capped. Next, the potassium hydroxide impingers of
the train will be purged with ultra-clean nitrogen gas at a delivery
rate of approximately 10 liters per minute for 30 minutes.
• Impingers 1 through 4—The pH of impinger 1 is checked using
pH strip paper and recorded on the sample collection sheet. The
pH of this solution will be greater than 8.5. If the pH is less than
8.5, the sampling train is invalid. The impinger catches for each
impinger (1 through 4) will be measured volumetrically and
combined into a single collection bottle. The glass nozzle,
aspirator (or pump), all connecting tubing, and impingers will be
rinsed four times using deionized water, and the rinses will be
added to the sample bottle.
• The final pre-rinse volume of impingers 1 through 4 before
rinsing is required to calculate moisture gain in the train. The
final volume of impingers 1 through 4 inclusive of the system
rinses is also required in order to calculate the total hexavalent
chromium in the train for an individual sampling run.
• The entire impinger train sample will be filtered through a
0.45 micrometer acetate or Teflon™ filter in a filtration device
equipped with nitrogen pressure connectors. Then, the filtration
D-5.7-25
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Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
device will be washed with deionized water, and the rinses will
be added to the sample.
• The silica gel impinger will be weighed to the nearest 0.5 gram to
determine the amount of moisture gained during sampling.
When the samples are shipped to the analytical laboratory, they will be
shipped with a sufficient amount of ice and will arrive at the laboratory
cold(4°C±2°C).
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, and the date and time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the makeup water.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
A blank potassium hydroxide recirculatory train will be set up during one
run of the trial burn. The blank train will be placed at the base of the
stack, leak checked, and left in the sampling environment for the same
length of time as the actual stack gas sampling train. At the conclusion
of the stack sampling, a final leak check will be performed on the blank
train, and sample recovery will be performed using the same procedures
as for the actual stack gas sampling trains. Reagent blanks will be taken
of the stack potassium hydroxide impinger solution and the deionized
water used for rinses.
The holding times for hexavalent chromium samples will be 24 hours
unless the on-site matrix spikes are performed at the time of sample
recovery (Method 7199). All samples will be preserved on ice to (4 °C +
2 °C). The first impinger of the train will be checked for pH greater than
8.5. At any time during the test or during sample recovery that the pH is
determined to be below 8.5, the test will be considered invalid. The
impinger may be checked halfway through the test at port change in
order to anticipate the adequacy of the potassium hydroxide strength in
finishing the test.
D-5.7-26
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In lieu of administering the analytical program on a 24-hour holding time,
the hexavalent chromium impinger composite sample will be divided into
3 (100-mL) aliquots. Two of the three samples will receive spikes (at the
time of sample recovery) of hexavalent chromium in the following
concentrations:
• 2 times the expected native hexavalent chromium concentration
• 5 times the expected native hexavalent chromium concentration
One of the aliquots is maintained as the original sample. Each aliquot will
be placed in individually numbered sample bottles and submitted for
separate hexavalent chromium analysis.
A 200-mL reagent blank will be collected of the 0.1N potassium
hydroxide reagent source during one run of the test burn. Additionally, a
deionized water rinse solution will be sampled as a reagent blank.
Method References: "Determination of Hexavalent Chromium Emissions from Stationary
Sources." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method 0061, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). U.S. Environmental
Protection Agency (EPA), Office of Solid Waste and Emergency
Response (OSWER), Washington, D.C. 20460.
"Determination of Hexavalent Chromium in Drinking Water,
Groundwater and Industrial Wastewater Effluents by Ion
Chromatography." Taken from Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods. SW-846 Method 7199, Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Test Methods." 40 CFR 60 Appendix A, EPA Methods 1, 2, 3, and 5.
D-5.7-27
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Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Sampling Locations:
10
Sampling Procedure for Volatile Organics in the Stack Gases
Stack volatiles organic sampling train (VOST)
Stack sampling engineer
The samples will be located at the incinerator or boiler stack sampling
platform.
Sampling and
Health and Safety Equipment: VOST, Tenax™ and Anasorb™ 747 resin cartridges, glass culture tubes
with screw-top caps, aluminum foil, glass 40-milliliter (mL) volatile
organic analysis (VOA) vials with screw-top caps and Teflon™-lined
septa, dry ice, and latex gloves
Note: SW-846 Method 0031 is a three-tube configuration of the VOST
system. Two Tenax™ resin tubes are required in addition to an
Anasorb™ 747 resin tube as the third tube. Tenax™/charcoal resin
tubes are no longer allowed. Except for field blanks and trip blanks,
VOST samples will be analyzed by running the two Tenax™ resin tubes
together and running the Anasorb™ 747 as a separate sample. Field
blanks and trip blanks can be run as a one sample set.
Sample Collection Frequency:
Sampling Procedures:
Samples will be collected continuously during the sampling run with
replacement of resin cartridges pairs after each 40 minutes of sampling.
Each pair of tubes will be used to sample a nominal 20 liters of stack gas.
The VOST condensate is to be measured volumetrically and collected
once at the end of each sampling run in 40-mL VOA vials.
Four sets of resin cartridges will be collected during the run. Three of
the sets will be analyzed, and one set will serve as a back-up set to be
analyzed in the event of breakage or sample loss from the other sets.
The preparation of VOST glassware, probes, condensers, and connecting
glassware will include a thorough rinsing of these components with an
ultrapure grade of methanol. Subsequently, glass components will be
baked in an oven at 100 °C. Teflon™ tubing will be cleaned after each
test in a similar fashion or replaced.
Resin Tube Preparation and Handling—The laboratory will prepare or
purchase the resin tubes and deliver them to the field sampling crew
before the sampling event. The procedures for preparing, handling,
storing, and analyzing the tubes will be those described in the SW-846
Method 0031. For the trial burn, a batch of resin tubes will be prepared.
Recycled VOST tubes that have been used on other trial burn projects
D-5.7-28
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are not allowed. Two complete sets of tubes from this batch of VOST
tubes will be spiked with the surrogate compounds and the target
compounds and will be analyzed by the analytical laboratory as spiked
resin blanks. The Tenax™ tubes will be analyzed separately from the
Anasorb™ 747 tubes. Analysis of the spiked resin blanks before the trial
burn demonstrates that the resin batch is clean and will reversibly
recover the volatile spikes placed on them before analysis.
Persons handling VOST tubes and train components will wear latex
gloves. Fresh gloves will be worn during every resin tube change out.
VOST samples must be stored and handled in a separate trailer or
laboratory space. Persons handling the Modified Method 5 (MM5) train
samples will not participate in the sampling or handling of VOST samples
at any time because MM5 train sample recoveries require the open use
of acetone, methylene chloride, and toluene. These solvents will
cross-contaminate the VOST samples unless deliberate care is taken to
prevent exposure.
The resin tubes will be protected from contamination by placing them in
glass culture tubes during shipping and storage. These tubes will contain
clean charcoal as a fugitive contaminant scavenger. For shipment to the
site, the tubes will be packed separately and kept at less than or equal to
4 °C on ice in insulated storage containers that are dedicated to VOST
tube storage. Dry ice is recommended in order to purge the storage
coolers constantly with the carbon dioxide subliming from the solid.
Regular ice also is acceptable. VOST tubes must be stored and handled
in an area isolated from the probe rinse solvents used for the MM5
trains.
At the test site VOST handling area, the tubes will be stored on ice until
needed. Before each replicate sampling run, the sample coordinator will
supply prelabeled resin tubes, including a prelabeled field blank set, to the
stack sampling engineer conducting the VOST sampling. Samples or
blank tubes that remain on the stack sampling platform will be stored in a
dedicated cooler that contains ice.
At the end of each run, the sample coordinator will recover the tubes and
a VOST sample collection sheet from the stack samplers. VOST
samples will then be repacked on ice and prepared for shipment, via
overnight delivery to the analytical laboratory. The VOST shipment will
be accompanied by the sample documentation.
VOST Operation—The sample collection procedures will be as
described in the standard EPA protocol (EPA-600/8-84-007). The dry
gas meter will be calibrated before arriving at the test site, and the
D-5.7-29
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Sample Preservation:
Documentation and
Record-Keeping:
sample train will be cleaned and assembled before installing the resin
tubes. The end caps of the tubes will be stored in each tube's
corresponding clean glass culture tube while the Tenax™ tubes are in
the train. The train will be leak-tested near 10 inches mercury in such a
manner as to prevent exposure of the train components to the ambient
air. Leak tests will be conducted before and after the sampling interval
for each resin set.
Before sampling is commenced, ice water will be circulated through the
condensers. The temperature exiting the first condenser will be less than
10 °C in order to provide conditions at the Tenax™ resin that will
effectively capture low boiling organic components (products of
incomplete combustion) in the stack gas. The ice water will be
monitored regularly during the test to replenish the ice for maximum
cooling capacity. The probe will be inserted into the sampling port and
purged with stack gas. The probe will be heated from 138 °Cto 150 °C
(280 °F to 302 °F). The stack will be sampled at a rate of 0.5 liter (L)
per minute for 40 minutes to collect a nominal sample volume of 20 L for
each set of tubes.
The sample collection data shown in the reference method will be
recorded for each tube set. Also, a sample collection entry for VOST
will be logged in the field logbook.
After collecting the samples, the tube pair will be removed from the
VOST, the end caps will be replaced, and they will be returned to their
culture tubes and stored in coolers on ice.
At the conclusion of the sampling run, the volume of the condensate
water will be measured and recorded on the sample collection sheet. The
condensate will be collected in a VOA vial with no headspace.
Organic-free deionized water will be added, if needed, to top off the
VOA vial if less than 40 mL of condensate is collected. If more than 40
mL of condensate is collected, only one VOA vial will be filled, and the
excess condensate will be discarded.
When the samples are shipped to the analytical laboratory, they will be
shipped with a sufficient amount of ice (option of dry ice is available) and
will arrive at the laboratory cold (4 °C + 2 °C).
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, and the date and time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the makeup water.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
D-5.7-30
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Quality Assurance and
Quality Control:
Method References:
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
During the sampling run, the end caps will be removed from the field
blank tube set to simulate the handling of the test sample tubes. The
tubes will remain open for approximately 10 minutes. The tubes will be
placed in the train, and a leak check will be conducted. After the leak
check, the resin tubes will be removed from the train and returned to
their culture tubes. This procedure approximates the handling and the
amount of time that the sample tubes are exposed to ambient conditions
during a tube exchange. Longer periods are acceptable.
For each sample shipment to the laboratory, a VOST tube set will be
removed from storage, assigned a sample number, and logged in as the
VOST trip blank set. This set will remain sealed during the test and
during shipment of associated samples.
Samples will be placed on dry ice in clean coolers, which will be stored in
an area away from other samples and potential contamination sources.
The VOST condensate sample will be stored and shipped in a separate
cooler and preserved by chilling to less than or equal to 4 °C with ice.
VOST samples may be shipped daily by overnight service to the
laboratory.
Field blank sets of VOST samples will be collected during each sampling
run. Trip blank sets will be collected with each shipment of samples to
the preforming laboratory. The corresponding Tenax™ and Anasorb™
747 tubes from a field blank set can be analyzed together. Two spiked
resin blanks will be prepared and analyzed before the trial burn. A
VOST audit will be conducted during the trial burn project, if required by
the officiating agency.
"Protocol for the Collection and Analysis of Volatile POHCs Using
VOST." EPA-600/8-84-007. U.S. Environmental Protection Agency
(EPA), Washington, D.C. 20460.
D-5.7-31
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"Sampling Method for Volatile Organic Compounds (SMVOC)." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method 0031, Third Edition, September 1986. Final
Update I (July 1992), Final Update IIA (August 1993), Final Update II
(September 1994), Final Update IIB (January 1995), and Final Update III
(December 1996). EPA, Office of Solid Waste and Emergency
Response, Washington, D.C. 20460.
D-5.7-32
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Procedure Number:
Procedure Title:
11
Sampling Procedure for Semivolatile Organics and Dioxins and
Furans in the Stack Gases
Sample Name: Modified Method 5 (MM5) semivolatile sampling train
Sampler: Stack sampling engineer
Process Sample Location: Samples will be collected at the stack sampling platform.
Sampling and
Health and Safety Equipment: MM5 sampling train, using an XAD-2 resin tube (containing
approximately 30 grams XAD-2 resin), participate filter, organic-free
deionized water, aluminum foil, glass sample bottles with Teflon™-lined
lids, and latex gloves
Sample Collection Frequency: Samples will be collected continuously for approximately 3 hours until at
least 3 cubic meters (m3) of stack sample is collected for each run; the
sampling rate will be less than or equal to 0.75 m3 per hour. Three runs
will constitute a test.
Sampling Procedures:
This MM5 train will be used to sample semivolatile, dioxin, and furan
emissions in the stack gas. As such, the train requirements are a
combination of specifications from SW-846 Method 0023 A and Method
0010. Also included are the requirements for separate train components
from SW-846 Method 3542 and Method 0023A. Probe rinse solvents
will be acetone, methylene chloride, and toluene. The use of a 50:50
mixture of methanol and methylene chloride will be abandoned.
XAD-2 Tube Preparation—The laboratory will prepare the XAD-2 resin
tubes and deliver them to the sampling team for use during the project.
During the resin preparation, a 100-microgram (//g) spike C
carbon-13-labeled naphthalene (or alternate labeled semivolatile
compound) will be applied to each XAD-2 resin tube. The five Method
0023A sampling surrogates also will be spiked onto the XAD-2 resin
tube. This labeled naphthalene spike will serve as a semivolatile
sampling surrogate to indicate analyte loss due to the sampling process.
The procedures for preparing, handling, storing, and analyzing the tubes
are those described in EPA SW-846 Method 0010. As described in the
method, the XAD-2 resin material will be cleaned by Soxhlet extraction
and dried. Precleaned XAD-2 resin also is commercially available
(Supelco). Two XAD-2 resin tubes using the prepared or purchased
resin will be spiked with a matrix spike mixture and analyzed as
laboratory resin blanks to confirm that the resin is free from significant
D-5.7-33
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background contamination and to assess recovery of the analytes from
the resin.
For storage and transport to the field, the resin tubes will have their ends
sealed with Teflon™ tape, wrapped in aluminum foil, sealed in Ziplock™
bags, and packed in a clean sample cooler. In the field, the cooler will be
stored in the sample recovery trailer and resin tubes are removed only
when ready for labeling and installation in the sampling train.
Before each sampling run, the sampling coordinator will supply a XAD-2
resin tube and a field blank tube to the stack sampling engineer who will
operate the MM5 train. At the end of each run, the sample coordinator
will recover the XAD-2 resin tubes and other train components and
prepare the sample documentation. The MM5 stack samples will be
stored on ice at approximately 4 °C in insulated coolers in a storage area
away from sources of fugitive contamination.
MM5 Train Operation—The MM5 train components will be provided by
the stack sampling team. With the exception of the necessary
modification for installing and recovering the resin tubes, the sampling
procedures will be as specified in U.S. Environmental Protection Agency
(EPA) Methods 1 and 2 for stack flow measurements and Method 4 and
5 for moisture content and particulate. An initial traverse is made with a
pitot tube at each sample point following Methods 1 and 2 to establish the
stack velocity profile, temperature, and flow rate and to check for
cyclonic air flow. Sample point location will be in accordance with
Method 1. The sampling team will record the data as recommended in
EPA Method 5.
Note: The sampling rate for this train will not exceed 0.75 m3 per hour.
Faster rates can lead to a low bias in the semivolatile compounds
(particulates of incomplete combustion) with relatively low boiling points
and relatively high vapor pressures. Lowered removal efficiency and
desorbing of organics by stripping are potential problems at the higher
sampling rates.
The sampling equipment will be calibrated before and after the test. The
pretest calibrations will be available for agency review before testing
commences.
The first impinger will be an empty condensate knockout impinger. The
MM5 train will be charged with 100 milliliters of organic-free deionized
water in the second and third impingers. The fourth impinger will contain
indicating silica gel that is tare weighed to the nearest 0.5 gram.
D-5.7-34
-------
The sampling train will be leak tested according to EPA Method 5
protocols. An activated charcoal filter will be placed on the end of the
probe to ensure that no ambient contaminants are allowed to enter the
train during leak checks.
MM5 Train Sample Recovery—The samples will be recovered from the
MM5 train, as follows:
• Participate Filter - The filter will be removed from its holder and
placed carefully in its original, labeled petri dish; sealed with
Teflon™ tape, and sealed in a Ziplock™ plastic bag for shipment
to the laboratory.
• Solvent Probe Rinse - The nozzle, probe, and the front half of the
filter holder will be brushed and rinsed three times with acetone
followed by brushing and rinsing three times each with methylene
chloride. The rinses will be combined and placed in a labeled
sample collection bottle with a Teflon™-lined lid.
• Toluene Probe Rinse - The nozzle, probe, and front half of the
filter holder will be brushed and rinsed three times with toluene.
The rinses will be combined and placed in a separate, labeled
sample collection bottle with a Teflon™-lined lid.
• Back-Half Filter Holder and Coil Condenser Solvent Rinse - The
back half of the filter holder, coil, condenser, and connecting
glassware will be rinsed three times with acetone and three times
with methylene chloride. These rinses will be placed in a
separate, labeled sample container with a Teflon™-lined lid.
• Back Half Filter Holder and Coil Condenser Toluene Rinse - The
back half of the filter holder, coil, condenser, and connecting
glassware will be rinsed three times with toluene. The
condenser rinse will be placed in a separate, labeled sample
container with a Teflon™-lined lid.
• XAD-2 Resin Tube - The XAD-2 resin tube will be removed
from the sampling train, and its ends will be sealed with Teflon™
tape. It will be wrapped in aluminum foil, sealed in a Ziplock™
bag, and stored for shipment to the laboratory.
• Condensate Impinger Composite and Solvent Rinses - The
contents of each impinger (1 through 3) will be volumetrically
measured to the nearest milliliter, and combined into a glass
sample bottle with a Teflon™-lined lid. The total volume before
rinsing is required to calculate the moisture gain for this train.
D-5.7-35
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Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Each impinger and connecting glassware will be rinsed three
times each with methylene chloride. A toluene rinse will not be
performed because an analysis for dioxins and furans in the
impinger contents is not necessary. Solvent rinses will be placed
into the same container as the aqueous condensate. Before the
solvent rinses are added to the sample, but after the deionized
water rinses are completed and added to the sample, the total
aqueous sample volume will be measured volumetrically to the
nearest milliliter and recorded on the sample collection sheet. All
three impingers are included in this sample because carryover of
moisture and organic compounds is entrained into impingers 2
and 3.
• Indicating Silica Gel - The silica gel impinger will be reweighed
to the nearest 0.5 gram, and the weight gain is calculated as
moisture gain in the train.
When the samples are shipped to the analytical laboratory, they will be
shipped with a sufficient amount of ice and will arrive at the laboratory
cold(4°C±2°C).
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, and the date and time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the makeup water.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
A complete MM5 blank train will be prepared once during the test burn
series, set up near the base of the stack similar to the actual MM5
sampling train, and will apply an equivalent number of associated leak
checks. The train will remain sealed with the filter holder and probe
heated to the required temperature at that location for a period equivalent
to one test run. The blank train samples will be recovered using the
same procedures described above for the actual train samples.
D-5.7-36
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All of the MM5 sample components will be assigned unique sample
tracking numbers and labeled with the date and test run number. The
samples will be recovered by the sample coordinator and the stack
sampling engineer, and the sample collection documentation will be
recorded. The sample coordinator will record the appropriate data in the
field logbook and pack the samples on ice in a storage cooler.
• An XAD-2 field blank will be collected once during each run.
The field blank XAD-2 tube will be opened in the field for the
same length of time as is required to assemble the MM5 train.
Field blanks will be analyzed for the same analytical parameters
as the actual test samples.
• An XAD-2 trip blank will be collected at least once for each
shipment of samples. The trip blank will be transported from the
laboratory to the sampling site, stored at the sampling site with
the other XAD-2 samples, and transported back to the laboratory
with the samples. Trip blanks will be analyzed for the same
analytical parameters as the actual test samples.
• Reagent blanks of the probe rinse solvents, particulate filter, and
deionized water will be collected once during the trial burn.
Method References: "Modified Method 5 Sampling Train" [appropriate for sampling stack gas
for semivolatiles]. Taken from Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods. SW-846 Method 0010, Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). U.S.
Environmental Protection Agency (EPA), Office of Solid Waste and
Emergency Response (OSWER), Washington, D.C. 20460.
"Extraction of Semivolatile Analytes Collected Using Method 0010
Modified Method 5 Sampling Train." Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846
Method 3542, Third Edition, September 1986. Final Update I (July
1992), Final Update IIA (August 1993), Final Update II
(September 1994), Final Update IIB (January 1995), and Final Update III
(December 1996). EPA, OSWER, Washington, D.C. 20460.
"Sampling Method for Poly chlorinated Dibenzo-p-Dioxins and
Poly chlorinated Dibenzofuran Emissions from Stationary Sources,"
[appropriate for sampling stack gas]. Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846
Method 0023A, Third Edition, September 1986. Final Update I (July
1992), Final Update IIA (August 1993), Final Update II (September
D-5.7-37
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1994), Final Update IIB (January 1995), and Final Update III (December
1996). EPA, OSWER, Washington, D.C. 20460.
"Method 5 - Determination of Particulate Emissions from Stationary
Sources" [appropriate for sampling stack gas isokinetically]. 40 CFR 60
Appendix A, July 1990.
D-5.7-38
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Procedure Number:
Procedure Title:
Sample Name:
Sampler:
12
Sampling Procedure for Polynuclear Aromatic Hydrocarbons in the
Stack Gases
Modified Method 5 (MM5) semivolatile sampling train
Stack sampling engineer
Process Sample Location: Samples will be collected at the stack sampling platform.
Sampling and
Health and Safety Equipment: MM5 sampling train, using an XAD-2 resin tube (approximately
30 grams XAD-2 resin), particulate filter, organic-free deionized water,
aluminum foil, glass sample bottles with Teflon™-lined lids, and latex
gloves
Sample Collection Frequency: Samples will be collected continuously for approximately 3 hours until at
least 3 cubic meters (m3) of stack sample is collected for each run; the
sampling rate will be less than or equal to 0.75 m3 per hour. Three runs
will constitute a test.
Sampling Procedures:
This MM5 train will be used to sample polynuclear aromatic hydrocarbon
(PAH) emissions in the stack gas. As such, the train requirements are a
combination of specifications from U.S. Environmental Protection
Agency (EPA) SW-846 Method 0010 and California Air Resources
Board (CARB) Method 429. Also included are the requirements for
separate train components from SW-846 Method 3542. Probe rinse
solvents will be acetone and methylene chloride. The use of a 50:50
mixture of methanol and methylene chloride will be abandoned.
XAD-2 Tube Preparation—The laboratory will prepare the XAD-2 resin
tubes and deliver them to the sampling team for use during the project.
During the resin preparation, a spike of carbon-13-labeled PAH sampling
surrogates will be applied to each XAD-2 resin tube. The three sampling
surrogates will be spiked onto the XAD-2 resin tube. These sampling
surrogate spikes will indicate analyte loss due to the sampling process.
The procedures for preparing, handling, storing, and analyzing the tubes
are those described in EPA SW-846 Method 0010. As described in the
method, the XAD-2 resin material will be cleaned by Soxhlet extraction
and dried. Precleaned XAD-2 resin also is commercially available
(Supelco). Using the prepared or purchased resin, two XAD-2 resin
tubes will be spiked with a matrix spike mixture and analyzed as
laboratory resin blanks to confirm that the resin is free from significant
background contamination and to assess recovery of the analytes from
the resin.
D-5.7-39
-------
For storage and transport to the field, the resin tubes will have their ends
sealed with Teflon™ tape. They will be wrapped in aluminum foil,
sealed in Ziplock™ bags, and packed in a clean sample cooler. In the
field, the cooler will be stored in the sample recovery trailer, and resin
tubes will be removed only when ready for labeling and installation in the
sampling train.
Before each sampling run, the sampling coordinator will supply a XAD-2
resin tube and a field blank tube to the stack sampling engineer who will
operate the MM5 train. At the end of each run, the sample coordinator
will recover the XAD-2 resin tubes and other train components and
prepare the sample documentation. The MM5 stack samples will be
stored on ice at approximately 4 °C in insulated coolers in a storage area
away from sources of fugitive contamination.
MM5 Train Operation—The MM5 train components will be provided by the
stack sampling team. With the exception of the necessary modification for
installing and recovering the resin tubes, the sampling procedures will be as
specified in U.S. Environmental Protection Agency (EPA) Methods 1 and 2
for stack flow measurements and EPA Method 4 and 5 for moisture content
and particulate. An initial traverse is made with a pitot tube at each sample
point following Methods 1 and 2 to establish the stack velocity profile,
temperature, and flow rate and to check for cyclonic air flow. The sample
point location will be in accordance with Method 1. The sampling team will
record the data as recommended in Method 5.
Note: The sampling rate for this train will not exceed 0.75 m3 per hour.
Faster rates can lead to a low bias in the semivolatile compounds (PAHs)
with relatively low boiling points and relatively high vapor pressures.
Lowered removal efficiency and desorbing of organics by stripping are
potential problems at the higher sampling rates.
The sampling equipment will be calibrated before and after the test. The
pretest calibrations will be available for agency review before testing
commences.
The first impinger will be an empty condensate knockout impinger. The
MM5 train will be charged with 100 milliliters (mL) of organic-free
deionized water in the second and third impingers. The fourth impinger
will contain indicating silica gel that is tare weighed to the nearest
0.5 gram.
The sampling train will be leak tested according to EPA Method 5
protocols. An activated charcoal filter will be placed on the end of the
probe to ensure that no ambient contaminants are allowed to enter the
train during leak checks.
D-5.7-40
-------
MM5 Train Sample Recovery—The samples will be recovered from the
MM5 train, as follows:
• Participate Filter - The filter will be removed from its holder and
carefully placed in its original, labeled petri dish. It will be sealed
with Teflon™ tape; and sealed in a Ziplock™ plastic bag for
shipment to the laboratory.
• Solvent Probe Rinse - The nozzle, probe, and front half of the
filter holder will be brushed and rinsed three times with acetone
followed by brushing and rinsing three times each with methylene
chloride. The rinses will be combined and placed in a labeled
sample collection bottle with a Teflon™-lined lid.
• Back-Half Filter Holder and Coil Condenser Solvent Rinse - The
back half of the filter holder, the coil, condenser, and connecting
glassware will be rinsed three times with acetone and three times
with methylene chloride. These rinses will be placed in a
separate, labeled sample container with a Teflon™-lined lid.
• XAD-2 Resin Tube - The XAD-2 resin tube will be removed
from the sampling train, and its ends will be sealed with Teflon™
tape. It will be wrapped in aluminum foil, sealed in a Ziplock™
bag, and stored for shipment to the laboratory.
• Condensate Impinger Composite and Solvent Rinses - The
contents of each impinger (1 through 3) will be measured
volumetrically to the nearest milliliter and combined into a glass
sample bottle with a Teflon™-lined lid. The total volume before
rinsing is required in order to calculate the moisture gain for this
train. Each impinger and connecting glassware is rinsed three
times each with methylene chloride. Solvent rinses will be
placed into the same container as the aqueous condensate.
Before the solvent rinses are added to the sample, but after the
deionized water rinses are completed and added to the sample,
the total aqueous sample volume will be measured volumetrically
to the nearest milliliter and recorded on the sample collection
sheet. All three impingers are included in this sample because
carryover of moisture and organic compounds are entrained into
impingers 2 and 3.
• Indicating Silica Gel - The silica gel impinger will be reweighed
to the nearest 0.5 gram and the weight gain will be calculated as
moisture gain in the train.
D-5.7-41
-------
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
When the samples are shipped to the analytical laboratory, they will be
shipped with a sufficient amount of ice and will arrive at the laboratory
cold(4°C±2°C).
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, and the date and time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the makeup water.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
A complete MM5 blank train will be prepared once during the test burn
series; it will be set up near the base of the stack similar to the actual
MM5 sampling train and will apply an equivalent number of associated
leak checks. The train will remain sealed with the filter holder and will
be probe heated to the required temperature at that location for a period
equivalent to one test run. The blank train samples will be recovered
using the same procedures described above for the actual train samples.
All of the MM5 sample components will be assigned unique sample
tracking numbers and labeled with date and test run number. The
samples will be recovered by the sample coordinator, and the stack
sampling engineer and the sample collection documentation will be
recorded. The sample coordinator will record the appropriate data in the
field logbook and pack the samples on ice in a storage cooler.
An XAD-2 field blank will be collected once during each run. The field
blank XAD-2 tube will be opened in the field for the same length of time
as is required to assemble the MM5 train. Field blanks will be analyzed
for the same analytical parameters as the actual test samples.
An XAD-2 trip blank will be collected at least once for each shipment of
samples. The trip blank will be transported from the laboratory to the
sampling site, stored at the sampling site with the other XAD-2 samples,
and transported back to the laboratory with the samples. Trip blanks will
D-5.7-42
-------
be analyzed for the same analytical parameters as the actual test
samples.
Reagent blanks of the probe rinse solvents, particulate filter, and
deionized water will be collected once during the trial burn.
Method References: "Modified Method 5 Sampling Train" [appropriate for sampling stack gas
for semivolatiles]. Taken from Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods. SW-846 Method 0010, Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). U.S.
Environmental Protection Agency (EPA), Office of Solid Waste and
Emergency Response (OSWER), Washington, D.C. 20460.
"Extraction of Semivolatile Analytes Collected Using Method 0010
Modified Method 5 Sampling Train." Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846 Method
3542, Third Edition, September 1986. Final Update I (July 1992), Final
Update IIA (August 1993), Final Update II (September 1994), Final
Update IIB (January 1995), and Final Update III (December 1996).
EPA, OSWER, Washington, D.C. 20460.
"Determination of Poly cyclic Aromatic Hydrocarbon (PAH) Emissions
from Stationary Sources," State of California Air Resources Board
Method 429. Adopted September 12, 1989.
"Method 8290 - Poly chlorinated Dibenzodioxins (PCDDs) and
Poly chlorinated Dibenzofurans (PCDFs) by High Resolution Gas
Chromatography/High Resolution Mass Spectrometry (HRGC/HRMS)."
Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-847 Method 8290, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Method 5 - Determination of Parti culate Emissions from Stationary
Sources" [appropriate for sampling stack gas isokinetically]. 40 CFR 60
Appendix A, July 1990.
D-5.7-43
-------
Procedure Number:
Procedure Title:
13
Sampling Procedure for Semivolatile and Nonvolatile Unspeciated
Mass in the Stack Gases
Sample Name: Modified Method 5 (MM5) semivolatile sampling train
Sampler: Stack sampling engineer
Process Sample Location: The samples will be collected at the stack sampling platform.
Sampling and
Health and Safety Equipment: MM5 sampling train, using an XAD-2 resin tube (approximately
30 grams XAD-2 resin), particulate filter, organic-free deionized water,
aluminum foil, glass sample bottles with Teflon™-lined lids, and latex
gloves
Sample Collection Frequency: Samples will be collected continuously for approximately 3 hours until at
least 3 cubic meters (m3) of stack sample is collected for each run; the
sampling rate will be less than or equal to 0.75 m3 per hour. Three runs
will constitute a test.
Sampling Procedures:
This MM5 train will be used to sample for unspeciated mass emissions in
the stack gas. As such, the train requirements are a combination of
specifications from the prepared method for total chromatographable
organics (TCO) and gravimetric (GRAY) analysis and U.S.
Environmental Protection Agency (EPA) SW-846 Method 0010. Also
included are the requirements for separate train components from SW-
846 Method 3542. Probe rinse solvents will be acetone and methylene
chloride. The use of a 50:50 mixture of methanol and methylene chloride
will be abandoned.
XAD-2 Tube Preparation—The laboratory will prepare the XAD-2 resin
tubes and deliver them to the sampling team for use during the project.
The procedures for preparing, handling, storing, and analyzing the tubes
are those described in EPA SW-846 Method 0010. As described in
Method 0010, the XAD-2 resin material will be cleaned by Soxhlet
extraction and dried. Precleaned XAD-2 resin also is commercially
available (Supelco). Using the prepared or purchased resin, two XAD-2
resin tubes will be spiked with a matrix spike mixture and analyzed as
laboratory resin blanks to confirm that the resin is free from significant
background contamination and to assess recovery of the analytes from
the resin.
For storage and transport to the field, the resin tubes will have their ends
sealed with Teflon™ tape. They will be wrapped in aluminum foil,
D-5.7-44
-------
sealed in Ziplock™ bags, and packed in a clean sample cooler. In the
field, the cooler will be stored in the sample recovery trailer, and resin
tubes will be removed only when ready for labeling and installation in the
sampling train.
Before each sampling run, the sampling coordinator will supply a XAD-2
resin tube and a field blank tube to the stack sampling engineer who will
operate the MM5 train. At the end of each run, the sample coordinator
will recover the XAD-2 resin tubes and other train components and
prepare the sample documentation. The MM5 stack samples will be
stored on ice at approximately 4 °C in insulated coolers in a storage area
away from sources of fugitive contamination.
MM5 Train Operation—The MM5 train components will be provided by
the stack sampling team. With the exception of the necessary
modification for installing and recovering the resin tubes, the sampling
procedures will be as specified in EPA Methods 1 and 2 for stack flow
measurements and EPA Methods 4 and 5 for moisture content and
particulate. An initial traverse is made with a pitot tube at each sample
point following Methods 1 and 2 to establish the stack velocity profile,
temperature, and flow rate, and to check for cyclonic air flow. Sample
point location will be in accordance with Method 1. The sampling team
will record the data as recommended in Method 5.
Note: The sampling rate for this train will not exceed 0.75 m3 per hour.
Faster rates can lead to a low bias in the semivolatile compound (TCOs)
with relatively low boiling points and relatively high vapor pressures.
Lowered removal efficiency and desorbing of organics by stripping are
potential problems at the higher sampling rates.
The sampling equipment will be calibrated before and after the test. The
pretest calibrations will be available for agency review before testing
commences.
The first impinger will be an empty condensate knockout impinger. The
MM5 train will be charged with 100 milliliters of organic-free deionized
water in the second and third impingers. The fourth impinger will contain
indicating silica gel that is tare weighed to the nearest 0.5 gram.
The sampling train will be leak tested according to EPA Method 5
protocols. An activated charcoal filter will be placed on the end of the
probe to ensure that no ambient contaminants are allowed to enter the
train during leak checks.
MM5 Train Sample Recovery—The samples will be recovered from the
MM5 train, as follows:
D-5.7-45
-------
• Participate Filter - The filter will be removed from its holder and
carefully placed in its original, labeled petri dish. The dish will be
sealed with Teflon™ tape and sealed in a Ziplock™ plastic bag
for shipment to the laboratory.
• Solvent Probe Rinse - The nozzle, probe, and the front half of the
filter holder will be brushed and rinsed three times with acetone
followed by brushing and rinsing three times each with methylene
chloride. The rinses will be combined and placed in a labeled
sample collection bottle with a Teflon™-lined lid.
• Back-Half Filter Holder and Coil Condenser Solvent Rinse - The
back half of the filter holder, coil, condenser, and connecting
glassware will be rinsed three times with acetone and three times
with methylene chloride. These rinses will be placed in a
separate, labeled sample container with a Teflon-lined lid.
• XAD-2 Resin Tube - The XAD-2 resin tube will be removed
from the sampling train, and its ends will be sealed with Teflon™
tape. It will be wrapped in aluminum foil, sealed in a Ziplock™
bag, and stored for shipment to the laboratory.
• Condensate Impinger Composite and Solvent Rinses - The
contents of each impinger (1 through 3) will be measured
volumetrically to the nearest milliliter and combined into a glass
sample bottle with a Teflon™-lined lid. The total volume before
rinsing is required in order to calculate the moisture gain for this
train. Each impinger and connecting glassware is rinsed three
times each with methylene chloride. Solvent rinses will be
placed into the same container as the aqueous condensate.
Before the solvent rinses are added to the sample, but after the
deionized water rinses are completed and added to the sample,
the total aqueous sample volume will be measured volumetrically
to the nearest milliliter and recorded on the sample collection
sheet. All three impingers are included in this sample because
carryover of moisture and organic compounds are entrained into
impingers 2 and 3.
• Indicating Silica Gel - The silica gel impinger will be reweighed
to the nearest 0.5 gram, and the weight gain will be calculated as
moisture gain in the train.
Sample Preservation: When the samples are shipped to the analytical laboratory, they will be
shipped with a sufficient amount of ice and will arrive at the laboratory
cold(4°C±2°C).
Documentation and
D-5.7-46
-------
Record-Keeping:
Quality Assurance and
Quality Control:
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, and the date and time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the makeup water.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
A complete MM5 blank train will be prepared once during the test burn
series, set up near the base of the stack similar to the actual MM5
sampling train, and will apply an equivalent number of associated leak
checks. The train will remain sealed with the filter holder and will be
probe heated to the required temperature at that location for a period
equivalent to one test run. The blank train samples will be recovered
using the same procedures described above for the actual train samples.
All of the MM5 sample components will be assigned unique sample
tracking numbers and labeled with date and test run number. The
samples will be recovered by the sample coordinator and the stack
sampling engineer, and the sample collection documentation will be
recorded. The sample coordinator will record the appropriate data in the
field logbook and pack the samples on ice in a storage cooler.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
An XAD-2 field blank will be collected once during each run. The field
blank XAD-2 tube will be opened in the field for the same length of time
as that required to assemble the MM5 train. Field blanks will be
analyzed for the same analytical parameters as the actual test samples.
An XAD-2 trip blank will be collected at least once for each shipment of
samples. The trip blank will be transported from the laboratory to the
sampling site, stored at the sampling site with the other XAD-2 samples,
and transported back to the laboratory with the samples. Trip blanks will
be analyzed for the same analytical parameters as the actual test
samples.
D-5.7-47
-------
Reagent blanks of the probe rinse solvents, particulate filter, and
deionized water will be collected once during the trial burn.
Method References: "Modified Method 5 Sampling Train," [appropriate for sampling stack
gas for semivolatiles]. Taken from Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods. SW-846 Method 0010, Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). U.S.
Environmental Protection Agency (EPA), Office of Solid Waste and
Emergency Response (OSWER), Washington, D.C. 20460.
"Extraction of Semivolatile Analytes Collected Using Method 0010
(Modified Method 5 Sampling Train)." Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846
Method 3542, Third Edition, September 1986. Final Update I (July 1992),
Final Update IIA (August 1993), Final Update II (September 1994), Final
Update IIB (January 1995), and Final Update III (December 1996).
EPA, OSWER, Washington, D.C. 20460.
"Method 5 - Determination of Parti culate Emissions from Stationary
Sources" [appropriate for sampling stack gas isokinetically]. 40 CFR 60
Appendix A, July 1990.
Guidance for Total Organics. Second Edition, Proposed. Prepared by
Eastern Research Group, Inc., Morrisville, North Carolina, for EPA
National Exposure Research Laboratory, Air Measurements Research
Division, Methods Branch, Research Triangle Park, North Carolina.
D-5.7-48
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Location:
14
Sampling Procedure for Volatile Unspeciated Mass in the Stack
Gases
Stack Gas Sampling for Volatile Unspeciated Mass Determination
Stack sampling engineer
The samples will be collected at the stack sampling platform.
Sampling and
Health and Safety Equipment: Method 0040 probe, participate filter, ice bath, condenser, condensate
impinger, Tedlar™ bag, control console, and latex gloves
Sample Collection Frequency: An integrated sample will be collected over a 2-hour period during the
test. The stack gas will be samples at a rate of 0.25 liters (L) per minute
for 120 minutes to yield a nominal sample volume of approximately 30 L.
Sampling Procedures:
Method 0040 is a draft method that was originally intended for use in the
sampling and analysis of specific compounds. It has been adopted as
part of the draft U.S. Environmental Protection Agency (EPA) guidance
for unspeciated mass and will be used to quantify the low boiling (less
that 100 °F) compounds in the CrC4 range.
The sampling train consists of a heated probe, condensing ice bath,
moisture knockout impinger, Tedlar™ bag container and sample bag, and
control console. Because the stack gas flow will be determined on as
many as four other concurrently operated trains, it does not have to be
determined on this train.
In this method, a representative sample will be drawn from a source
through a heated sample probe and filter. Then, the sample will pass
through a heated three-way valve and into a condenser where the
moisture and condensable components will be removed; then it will be
collected in a Tedlar™ gas held in a rigid opaque container. Next, the
dry gas sample will be analyzed on site. The condensate will be analyzed
off site using a laboratory gas chromatograph. The total amount of the
analyte in the sample will be determined by summing the individual
amounts in the bag and the condensate. The particulate catch will not be
analyzed or archived.
Sampling will begin after a pretest leak check and system purge (at least
10 minutes). The probe will be placed at a location in the stack that
provides two options for sampling proportional and constant. Because
the stack gas flow is not expected to vary more than 20 percent, constant
D-5.7-49
-------
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
sampling will be employed. The sampling will coincide with the isokinetic
total chromatographable organics (TCO) and gravimetric (GRAY)
samples being collected during the same period. The average stack gas
flow rate and properties from the other concurrently operated isokinetic
trains may be used for data reduction.
The condensate sample will be recovered by removing the condensate
trap, the condenser and the sample line (from the trap to the bag) from
the sample train. The contents of the condensate trap will be poured into
a clean graduated cylinder. The condenser, the condensate trap, and the
sample will be rinsed three times with 10 milliliters of high-performance
liquid chromatogtrapy grade water, and the rinsate will be added to the
measuring cylinder containing the condensate. The final volume of the
condensate and rinse mixture will be recorded on the field sampling data
form. Septum volatile organic analysis vials must be used to recover the
sample, providing for zero headspace.
Tedlar™ bags should not be placed on ice.
Before sampling is commenced, each bottle and Tedlar™ bag will be
labeled with a specific sample number, the project name, the run number,
the sample description, and the date and time of sampling. The sampler
will fill out a sample collection sheet for every sample collected of the
makeup water. The time that each aliquot of the waste stream is
collected will be logged as it is collected. The sample collection sheet
will provide a place to record the sample number, the project name, the
run number, the sampler's name, the sample type, the sample description,
the sample source, the bottle type, and the date and time of each grab
collection. The sampling coordinator also will record all samples
collected into a field logbook. This logbook will serve as the master
document listing of all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
Three train sample sets will be collected during a trial burn. One
Tedlar™ bag will be filled in the Method 0040 setup per run. One field
blank per run will be collected and analyzed. Two trip blanks will be
collected and analyzed during the test. Every bag sample will be
analyzed in duplicate. A field spike of the target compounds will be
performed during every run. One blank spike and one blank spike
duplicate will be collected during the test.
D-5.7-50
-------
Method References: "Sampling of Principal Organic Hazardous Constituents from Combustion
Sources Using Tedlar™ Bags." Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846
Modified Method 0040, Third Edition, September 1986. Final Update I
(July 1992), Final Update IIA (August 1993), Final Update II (September
1994), Final Update IIB (January 1995), and Final Update III (December
1996). EPA, Office of Solid Waste and Emergency Response
(OSWER), Washington, D.C. 20460.
"Guidance for Total Organics, Final Report" [Uniform flame ionization
detector response for varying compound classes is assumed in this
methodology. Compounds found with retention times prior to the C4
retention time are quantified with an appropriate response factor and the
value is reported as C4 with the other organic result]. March 1996.
Prepared for the U.S. Environmental Protection Agency (EPA).
Washington, D.C. 20460.
"Guidance for Total Organics, Final Report." March 1996. Prepared for
Atmospheric Research and Exposure Assessment Laboratory Methods
Research and Development Division Source Method Research Branch,
EPA, Washington, D.C. 20460.
"Nonhalogenated Organics Using GC/FID." Taken from Test Methods
for Evaluating Solid Waste, Physical/Chemical Methods. SW-846,
SW-8015, Third Edition, September 1986. Final Update I (July 1992),
Final Update IIA (August 1993), Final Update II (September 1994), Final
Update IIB (January 1995), and Final Update III (December 1996).
EPA, OSWER, Washington, D.C. 20460.
D-5.7-51
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Location:
Sampling and
Health and Safety Equipment:
Sample Collection Frequency:
Sampling Procedures:
75
Sampling Procedure for Formaldehyde in the Stack Gases
Method 0011 aldehyde and ketone sampling train
Stack sampling engineer
The samples will be collected at the stack sampling platform.
Method 0011 sampling train, 2,4-dinitrophenylhydrazine (DNPH) solution,
organic-free deionized water, aluminum foil, glass sample bottles with
Teflon™-lined lids, and latex gloves
The samples will be collected continuously for approximately 2 hours
until at least 2 cubic meters (m3) of stack sample is collected for each
run; sampling rate will be less than or equal to 0.75 m3 per hour. Three
runs will constitute a test.
This Method 0011 train will be used to sample aldehyde (and ketones, if
required) emissions in the stack gas. As such, the train requirements are
specifications from U.S. Environmental Protection Agency (EPA)
SW-846 Method 0011. Also included are the requirements for separate
train components. Probe rinse solvents will be deionized water and
methylene chloride.
Before each sampling run, the sampling coordinator will supply the train
reagent and field blank reagents to the stack sampling engineer who will
operate the Method 0011 train. At the end of each run, the sample
coordinator will recover the train components and prepare the sample
documentation. The Method 0011 stack samples will be stored on ice at
approximately 4 °C in insulated coolers in a storage area removed from
sources of fugitive contamination.
Method 0011 Train Operation—The Method 0011 train components will
be provided by the stack sampling team. With the exception of the
necessary modification for installing and recovering the train reagents,
the sampling procedures will be as specified in EPA Methods 1 and 2 for
stack flow measurements and EPA Methods 4 and 5 for moisture
content and particulate. An initial traverse is made with a pitot tube at
each sample point following EPA Methods 1 and 2 in order to establish
the stack velocity profile, temperature, and flow rate and to check for
cyclonic air flow. Sample point location will be in accordance with
Method 1. The sampling team will record the data as recommended in
Method 5.
D-5.7-52
-------
Note: The sampling rate for this train will not exceed 0.75 m3 per hour.
Faster rates can lead to a low bias in the aldehydes caused by lower
scrubbing efficiency at the higher sampling rates.
The sampling equipment will be calibrated before and after the test. The
pretest calibrations will be available for agency review before testing
commences.
The first impinger will be an empty condensate knockout impinger. The
inclusion of an empty knockout impinger is optional but will be considered
when stack gas with a high moisture content is being tested. A knockout
impinger prevents high levels of dilution of the reagents in the impingers.
The train will be charged with 100 milliliters of freshly prepared DNPH
solution in the second and third impingers. If additional capacity is
required for high expected concentrations of formaldehyde in the stack
gas, 200 milliliters of DNPH per impinger may be used. The fourth
impinger will remain empty during the test. The fifth impinger will
contain indicating silica gel that is tare weighed to the nearest 0.5 gram.
The sampling train will be leak tested according to EPA Method 5
protocols. An activated charcoal filter will be placed on the end of the
probe to ensure that no ambient contaminants are allowed to enter the
train during leak checks.
Method 0011 Train Sample Recovery—The samples will be recovered
from the Method 0011 train as follows:
• Solvent Probe Rinse - The nozzle, probe liner, and connecting
glassware will be brushed and rinsed three times with water,
followed by brushing and rinsing three times each with methylene
chloride. The rinses will be combined and placed in a labeled
sample collection bottle with a Teflon™-lined lid.
• Condensate Impinger Composite and Solvent Rinses - The
contents of each impinger (1 through 3) will be volumetrically
measured to the nearest milliliter, and the contents of the first
(empty at start) and second impingers will be combined into a
glass sample bottle with a Teflon™-lined lid. The contents of the
third and fourth impingers will be combined into a separate
sample bottle. The total volume of all four impingers before
rinsing is required in order to calculate the moisture gain for this
train. Each impinger and connecting glassware is rinsed three
times each with methylene chloride. Solvent rinses will be
placed into the same sample container as their respective
aqueous condensate and DNPH solutions. Before the solvent
D-5.7-53
-------
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
rinses are added to the sample, but after the deionized water
rinses are completed and added to the sample, the total aqueous
sample volume will be volumetrically measured to the nearest
milliliter and recorded on the sample collection sheet.
• Indicating Silica Gel - The silica gel impinger will be reweighed
to the nearest 0.5 gram and the weight gain will be calculated as
moisture gain in the train.
Each of the Method 0011 sample components will be assigned unique
sample tracking numbers and labeled with date and test run number. The
samples will be recovered by the sample coordinator and the stack
sampling engineer and the sample collection documentation will be
recorded. The sample coordinator will record the appropriate data in the
field logbook and pack the samples on ice in a storage cooler.
The empty knockout impinger and the first impinger containing DNPH
will be analyzed separately from the second and third impingers to
demonstrate relative breakthrough in the train and recovery efficiency.
When the samples are shipped to the analytical laboratory, they will be
shipped with a sufficient amount of ice and will arrive at the laboratory
cold(4°C±2°C).
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, and the date and time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the makeup water.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
A complete Method 0011 blank train will be prepared once during the
test burn series, set up near the base of the stack similar to the actual
Method 0011 sampling train, and will apply an equivalent number of
associated leak checks. The train will remain sealed with the probe
D-5.7-54
-------
heated to the required temperature at that location for a period equivalent
to one test run. The blank train samples will be recovered using the
same procedures described above for the actual train samples.
Field spikes will be applied to aliquots of samples in the field as a quality
demonstration of accuracy and recovery efficiency.
Reagent blanks of the methylene chloride probe rinse solvents, DNPH
impinger solution, and deionized water will be collected once during the
trial burn.
Method References: "Method 0011- Sampling for Formaldehyde Emissions from Stationary
Sources." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-0011, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). U.S. Environmental
Protection Agency (EPA), Office of Solid Waste and Emergency
Response (OSWER), Washington, D.C. 20460.
"Formaldehyde by High Performance Liquid Chromatography." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method SW-8315, Third Edition, September 1986.
Final Update I (July 1992), Final Update IIA (August 1993), Final
Update II (September 1994), Final Update IIB (January 1995), and Final
Update III (December 1996). EPA, OSWER, Washington, D.C. 20460.
"Method 5 - Determination of Particulate Emissions from Stationary
Sources" [appropriate for sampling stack gas isokinetically]. 40 CFR 60
Appendix A, July 1990.
D-5.7-55
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
16
Sampling Procedure for Hydrogen Chloride, Chlorine, and
Paniculate in the Stack Gases
Method 0050 hydrogen chloride, chlorine, and participate sampling train
Stack sampling engineer
Process Sample Location: The samples will be collected at the stack sampling platform.
Sampling and
Health and Safety Equipment:
Method 0050 sampling train, petri dish with tare-weighed participate
filter, impinger reagents, glass sample collection bottles with
Teflon™-lined lids, wide-range pH strips, and latex gloves
Sample Collection Frequency: The samples will be collected continuously for approximately 3 hours
during each sampling run. The sampling volume will be 3 cubic meters
(m3) at a rate not to exceed 0.75 m3 per hour.
Sampling Procedures:
Particulate Filter Preparation—A set of quartz fiber filters will be
prepared individually by weighing to a constant weight on a calibrated
analytical balance capable of measuring 0.0001 gram. The filter will then
be sealed with Teflon™ tape in a numbered, clean, glass petri dish for
transport to the field.
Hydrogen Chloride. Chlorine, and Particulate Train Operation—The
sampling train will be assembled with a tare-weighted participate filter
with a heated glass probe and empty first impinger for the collection of
condensate. If a large amount of condensate moisture is expected, the
first impinger volume will be large such that bumping of the contents of
impinger 1 into impinger 2 is avoided. The accumulation of condensate in
impinger 2 affects the pH of the sulfuric acid solution by dilution. The
second and third impingers will contain 100 milliliters (mL) each of
0.1 normality (N) sulfuric acid. The fourth impinger will remain empty in
order to protect the 0. IN sodium hydroxide impingers from carryover of
the sulfuric acid, which would neutralize it. The fifth impinger and sixth
impinger will contain 100 mL of 0. IN sodium hydroxide. A seventh
impinger is a indicating silica gel moisture trap that is pre-weighed for the
purpose of moisture gain. The impinger train will be connected to a
control box, which contains flow controls, thermocouple readouts, and a
dry gas meter capable of accurately measuring the gas sample volume.
After assembly, the train will be leak checked prior to and following each
sampling run according to Method 0050 criteria.
D-5.7-56
-------
An initial traverse is made with a pitot tube at each sample port following
U.S. Environmental Protection Agency (EPA) Methods 1 and 2 to
establish the stack velocity profile, temperature, and flow rate and to
check for cyclonic air flow. Sample point location will be in accordance
with Method 1. The total sampling time during a run will be
approximately 4 hours, and a nominal 3 dry standard cubic meters (dscm)
of stack will be sampled. EPA Method 5 procedures are followed for
pre-test and post-test leak checks, isokinetic sampling rate, filter
changeouts (if needed), and data recording.
Hydrogen Chloride. Chlorine, and Particulate Train Sample
Recovery—The impinger section of the sampling train is moved intact to
the cleanup area for sample recovery, as follows:
The particulate filter is removed from its holder and placed carefully into
its original glass petri dish, which is then sealed with Teflon™ tape and
further sealed in a Ziplock™ bag. The internal surfaces of the nozzle,
probe, and front half of the filter holder are cleaned by thoroughly rinsing,
brushing, and final rinsing with acetone. These acetone rinsates are
collected together into a prelabeled, numbered, sample 250-mL glass
collection bottle. The samples will be recovered from the sampling train
by disconnecting the first four impingers, volumetrically measuring their
individual moisture catches, and transferring the catches into a single
glass sample bottle with a Teflon™-lined lid. The moisture gain is
recorded for these impingers. The impingers will be then rinsed with
0. IN sulfuric acid and this rinse will be combined with the impinger
sample. The total sulfuric acid impinger sample and rinse volumes will
be recorded on the sample collection sheet. The pH of the final sample
also will be measured using appropriate pH test strips and recorded on
the sample collection sheet. The samples will be packed and shipped to
the laboratory where they will be analyzed for chloride by ion
chromatography. The impingers containing the 0. IN sodium hydroxide
will be volumetrically measured and transferred to a separate, numbered,
pre-labeled sample bottle. The pH of the final sample, before the
addition of rinses, also will be measured using appropriate pH test strips
and recorded on the sample collection sheet. These impingers will be
rinsed with 0. IN sodium hydroxide and the rinsate will be combined with
the sodium hydroxide impinger sample. The total sodium hydroxide
impinger sample and rinse volume will be recorded on the sample
collection sheet. If the pH of the final sample, before rinses are added, is
below pH 8.5, then the impinger capacity to capture chlorine gas has
been exceeded. Under these conditions, the chlorine sampling is invalid.
The samples will be packed and shipped to the laboratory where they will
be analyzed for chloride by ion chromatography.
D-5.7-57
-------
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Method References:
When the samples are shipped to the analytical laboratory, they will be
shipped with a sufficient amount of ice and will arrive at the laboratory
cold(4°C±2°C).
Before sampling is commenced, each bottle will be labeled with a
specific sample number, the project name, the run number, the sample
description, and the date and time of sampling. The sampler will fill out a
sample collection sheet for every sample collected of the makeup water.
The time that each aliquot of the waste stream is collected will be logged
as it is collected. The sample collection sheet will provide a place to
record the sample number, the project name, the run number, the
sampler's name, the sample type, the sample description, the sample
source, the bottle type, and the date and time of each grab collection.
The sampling coordinator also will record all samples collected into a
field logbook. This logbook will serve as the master document listing of
all of the trial burn samples collected.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
All equipment, including the thermocouples, the rotameters, and the dry
gas meter will be calibrated before the tests, and their calibrations
verified after the completion of each test run.
Reagent blanks will be collected once during the trial burn for the
particulate filter, the acetone probe rinse solvent, the 0. IN sulfuric acid
solution, and the 0.1N sodium hydroxide solution.
"Test Methods." 40 CFR 60 Appendix A, EPA Methods 1, 2, 3, 4 and
5.
"Isokinetic HC1/CL2 Emission Sampling Train." Taken from Test
Methods for Evaluating Solid Waste, Physical/Chemical Methods.
SW-846 Method 0050, Third Edition, September 1986. Final Update I
(July 1992), Final Update IIA (August 1993), Final Update II (September
1994), Final Update IIB (January 1995), and Final Update III (December
1996). U.S. Environmental Protection Agency, Office of Solid Waste
and Emergency Response, Washington, D.C. 20460.
D-5.7-58
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
17
Sampling Procedure for Carbon Monoxide in Stack Gases by CEM
Stack continuous emission monitoring for carbon monoxide
Monitoring system operator
Process Sample Location: The samples will be collected at the stack.
Sampling and
Health and Safety Equipment: TECO Model 200 extractive prove, TECO Model 48 ambient carbon
monoxide analyzer, and a Odessa Model DSM3260 data acquisition
system
No specific health and safety equipment required.
Sample Collection Frequency: The samples will be collected continuously for the duration of each
sampling run.
Sampling Procedures:
TECO Model 200 will extract a sample, diluting it approximately 100 to 1
using clean, dry-compressed air (scrubbed of carbon monoxide). This
sample will be delivered to TECO Model 48, which is capable of reading
carbon monoxide concentrations as low as 0.01 parts per million (ppm).
The sample will be "wet," that is, it still will contain all of the moisture
that is present in the combustion gases. The Model 48 will be
programmed to analyze in two ranges at once, the 0 to 2 ppm range and
the 0 to 20 ppm range. The analyzer is digital and will update the carbon
monoxide reading approximately every 6 seconds. Both analyzer output
signals (0 to 2 ppm range and 0 to 20 ppm range) will be sent to the data
acquisition system (DAS) where they are corrected for dilution ratio,
combustion gas oxygen, and moisture concentrations using a
programmed algorithm. Dilution ratio correction will be accomplished by
multiplying the Model 48 signals by 100. Moisture concentration will be
assumed to be a fixed value, while oxygen concentration will be
measured real-time, and the oxygen analyzer output signal will be sent to
the DAS for use in the algorithm. The 0 to 2 ppm range carbon
monoxide input signal will be corrected to 0 percent moisture and 7
percent oxygen and will be transformed into a 0 to 200 ppm range value.
This signal will be used within the DAS to generate 1-minute averages,
which will then be used to compute a rolling hourly average (RHA). The
RHA will be computed by summing the last 60 1-minute averages and
dividing by 60.
The instrument will be prepared and operated during the test using the
procedure provided by the manufacturer. The monitor will be calibrated
D-5.7-59
-------
before each sampling run using a zero and three span gases that
approximate the actual stack concentrations of carbon monoxide. The
calibration of the instrument also will be verified following each test run.
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Method References:
No specific holding times apply to this procedure.
Documentation of data recorded by the computer.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
During the testing program, the quality assurance measures specified in
the referenced methods will be performed. The quality assurance
project plan lists the specific protocols associated with determining
continuous emission monitoring system performance.
"Specifications and Test Procedures for O2 and CO2 Continuous
Emission Monitoring Systems in Stationary Sources." 40 CFR 60
Appendix B, Performance Specification 3, July 1990.
Federal Register, Vol. 54, No. 206, October 1989.
"Performance Specifications for Continuous Emission Monitoring of
Carbon Monoxide and Oxygen for Incinerators, Boilers, and Industrial
Furnaces Burning Hazardous Waste." Taken from EPA Methods
Manual for Compliance with the BIF Regulations Burning
Hazardous Waste in Boilers and Industrial Furnaces. USEPA 530-
SW-91-010, U.S. Environmental Protection Agency, December 1990,
and 40 CFR 266 Appendix IX, Part 2.1, July 1, 1994.
D-5.7-60
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
18
Sampling Procedure for Oxygen in Stack Gases
Continuous emission monitoring for oxygen
Monitoring system operator
Process Sample Location: The samples will be collected at the stack.
Sampling and
Health and Safety Equipment: Thermox™ Model CV-1 analyzer
No specific health and safety equipment required.
Sample Collection Frequency: The samples will be collected continuously for duration of each sampling
run.
Sampling Procedures:
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
The CV-1 oxygen sensor uses convection to pull a sample of process gas
through a protective porous filter on its probe. The sample passes into
the analyzer, up and around the sensing house, and back into the process.
The convection flow is caused by the temperature differences between
the cell housing and the return tube. The analyzer produces an analog
electronic signal that is input to the data acquisition system, where it is
corrected to 0 percent moisture and then used to correct the carbon
monoxide readings to a standard 7 percent oxygen concentration.
The instrument will be prepared and operated during the test using the
procedure provided by the manufacturer. The monitor will be calibrated
before each sampling run using a zero and three span gases that
approximate the actual stack concentration of oxygen. The calibration of
each instrument also will be verified following each test run.
No specific holding times apply to this procedure.
Documentation of data recorded by the computer.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
During the testing program, the quality assurance measures specified in
the referenced methods will be performed. The quality assurance
D-5.7-61
-------
project plan lists the specific protocols associated with determining
continuous emissions monitoring system performance.
Method References: "Specifications and Test Procedures for O2 and CO2 Continuous
Emission Monitoring Systems in Stationary Sources," 40 CFR 60
Appendix B, Performance Specification 3, July 1990.
Federal Register, Vol. 54, No. 206, October 1989.
"Performance Specifications for Continuous Emission Monitoring of
Carbon Monoxide and Oxygen for Incinerators, Boilers, and Industrial
Furnaces Burning Hazardous Waste." Taken from EPA Methods
Manual for Compliance with the BIF Regulations Burning
Hazardous Waste in Boilers and Industrial Furnaces. USEPA 530-
SW-91-010, U.S. Environmental Protection Agency, December 1990,
and 40 CFR 266 Appendix IX, Part 2.1, July 1, 1994.
D-5.7-62
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample location:
19
Sampling Procedure for Total Hydrocarbon in Stack Gases
Stack total hydrocarbon (THC)
Stack sampling specialists
The samples will be collected at the stack.
Sampling and
Health and Safety Equipment: Stainless steel probe, heated Teflon™ sample transfer line, and flame
ionization detector (FID) THC analyzer heated to 300 ° to 350 °F.
The probe will contain a pump system to introduce calibration gases
(propane) and zero gas (less than 0.1 parts per million (ppm)
hydrocarbon air) into the monitoring system. The FID fuel gas will be a
mixture of 40 percent H2 and 60 percent helium or 40 percent hydrogen
and 60 percent nitrogen.
No specific health and safety equipment required.
Sample Collection Frequency: The samples will be collected continuously for the duration of each
sampling run.
Sampling Procedures:
Sample Preservation:
The gas stream will be drawn from the stack through a heated sampling
line that is maintained above 220 °F to prevent condensation of water in
the sampling line. The THC analyzer's output will be recorded on a strip
chart recorder and by a data logger. The data logger will be used to
report the hourly rolling averages, whereas the strip chart will report
instantaneous results.
The instrument probe will be placed in the stack stream as specified in
the referenced methods. The unit will be prepared and operated during
the test using the procedure provided by the manufacturer. The monitor
will be calibrated before each sampling run using a zero and three span
gases consisting of three concentrations of propane. The range of the
calibration gases will approximate the actual stack THC concentration.
The calibration of the instrument also will be verified following each
sampling run.
Because the THC analyzer will be calibrated against propane standards,
the results of the analyzer will be reported as "THC as ppm propane."
No specific holding times apply to this procedure.
D-5.7-63
-------
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Method References:
Documentation of data recorded by the computer.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
During the testing program, the quality assurance measures specified in
the referenced method will be performed. The quality assurance project
plan lists the specific protocols associated with determining the THC
continuous emissions monitoring performance.
Federal Register, Vol. 54 No. 206, October 1989.
"Performance Specifications for Continuous Emission Monitoring of
Carbon Monoxide and Oxygen for Incinerators, Boilers, and Industrial
Furnaces Burning Hazardous Waste." Taken from EPA Methods
Manual for Compliance with the BIF Regulations Burning
Hazardous Waste in Boilers and Industrial Furnaces. USEPA 530-
SW-91-010, U.S. Environmental Protection Agency, December 1990,
and 40 CFR 266 Appendix IX, Part 2.1, July 1, 1994.
D-5.7-64
-------
Procedure Number:
Procedure Title:
20
Sampling Procedure for Carbon Dioxide in the Stack Gases
Sample Name: Continuous emission monitoring for carbon dioxide
Sampler: Monitoring system operator
Process Sample Location: The samples will be collected at the stack.
Sampling and
Health and Safety Equipment: Stainless steel sonic orifice eductor probe, gas transport lines to
instrument, infrared gas analyzer with strip chart recorder
No specific health and safety equipment required.
Sample Collection Frequency: The samples will be collected continuously for the duration of each
sampling run.
Sampling Procedures:
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
The gas steams drawn into the probe are heated and continuously
transported to the analyzer.
The instrument will be placed in the stack gas steam as specified in the
referenced methods. It will be prepared and operated during the test
using the procedure provided by the manufacturer. The monitor will be
calibrated before each sampling run using a zero and three span gases
that approximate the actual stack concentration of carbon dioxide. The
calibration of the instrument will also be verified following each test run.
No specific holding times apply to this procedure.
Documentation of data recorded by the computer.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
During the testing program, the quality assurance measures specified in
the referenced methods will be performed. The quality assurance
project plan lists the specific protocols associated with determining
continuous emissions monitoring system performance.
D-5.7-65
-------
Method References: "Specifications and Test Procedures for O2 and CO2 Continuous
Emission Monitoring Systems in Stationary Sources." 40 CFR 60
Appendix B, Performance Specification 3, July 1990.
Federal Register, Vol. 54, No. 206, October 1989.
"Performance Specifications for Continuous Emission Monitoring of
Carbon Monoxide and Oxygen for Incinerators, Boilers, and Industrial
Furnaces Burning Hazardous Waste." Taken from EPA Methods
Manual for Compliance with the BIF Regulations Burning
Hazardous Waste in Boilers and Industrial Furnaces. USEPA 530-
SW-91-010, U.S. Environmental Protection Agency, December 1990,
and 40 CFR 266 Appendix IX, Part 2.1, July 1, 1994.
D-5.7-66
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Location:
21
Sampling Procedure for Sulfur Dioxide in the Stack Gases
Continuous emission monitoring for sulfur dioxide
Monitoring system operator
The samples will be collected at the stack.
Sampling and
Health and Safety Equipment: Stainless-steel probe; heated Teflon™ sample transfer line; and
nondispersive infrared, ultraviolet, or fluorescence analyzer with strip
chart recorder
No specific health and safety equipment required.
Sample Collection Frequency: The samples will be collected continuously for the duration of each
sampling run.
Sampling Procedures:
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Method Reference:
The instrument will be placed in the stack gas steam, as specified in the
referenced methods. It will be prepared and operated during the test
using the procedure provided by the manufacturer. The monitor will be
calibrated before each sampling run using a zero and three span gases
that approximate the actual stack concentration of sulfur dioxide. The
calibration of the instrument also will be verified following each test run.
No specific holding times apply to this procedure.
Documentation of data recorded by the computer.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
During the testing program, the quality assurance measures specified in
the referenced methods will be performed. The quality assurance
project plan lists the specific protocols associated with determining
continuous emissions monitoring system performance.
"Determination of Sulfur Dioxide Emissions from Stationary Sources
(Instrumental Analyzer Procedure)." 40 CFR 60 Appendix A,
Method 6C, July 1, 1991.
D-5.7-67
-------
D-5.7-68
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Location:
22
Sampling Procedure for Nitrogen Oxides in the Stack Gases
Continuous emission monitoring for nitrogen oxides
Monitoring system operator
The samples will be collected at the stack.
Sampling and
Health and Safety Equipment: Stainless-steel probe; heated Teflon™ sample transfer line; and
nondispersive infrared, chemiluminescent analyzer with strip chart
recorder
No specific health and safety equipment required.
Sample Collection Frequency: The samples will be collected continuously for the duration of each
sampling run.
Sampling Procedures:
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Method Reference:
The instrument will be placed in the stack gas steam as specified in the
referenced methods. It will be prepared and operated during the test
using the procedure provided by the manufacturer. The monitor will be
calibrated before each sampling run using a zero and three span gases
that approximate the actual stack concentration of nitrogen oxides. The
calibration of each instrument also will be verified following each test
run.
No specific holding times apply to this procedure.
Documentation of data recorded by the computer.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
During the testing program, the quality assurance measures specified in
the referenced methods will be performed. The quality assurance
project plan lists the specific protocols associated with determining
continuous emission monitoring system performance.
"Determination of Nitrogen Oxides Emissions from Stationary Sources
(Instrumental Analyzer Procedure)." 40 CFR 60 Appendix A, Method
7E, July 1, 1991.
D-5.7-69
-------
D-5.7-70
-------
Procedure Number:
Procedure Title:
23
Sampling Procedure for Oxygen and Carbon Dioxide in Stack by
Orsat
Sample Name: Stack oxygen and carbon dioxide by Orsat.
Sampler: Stack sampling specialists
Process Sample Location: Samples will be collected at the stack.
Sampling and
Health and Safety Equipment: Orsat apparatus, Tedlar™ gas bags
No specific health and safety equipment required.
Sample Collection Frequency: One integrated sample collected from each isokinetic stack sampling
train.
Sampling Procedures:
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
Method Reference:
Collect an integrated sample of approximately 1 cubic foot in a clean
Tedlar™ bag using EPA Method 3.
Analyze after the sampling run for oxygen, and carbon dioxide by
instructions provided with the Orsat apparatus.
No specific holding times apply to this procedure.
Documentation of data recorded by the computer.
The required number of analyses for these samples is defined in Table
10-1 of the quality assurance project plan. The laboratory is required to
analyze separately all of the field samples, field quality control samples,
and laboratory quality control samples specified in Table 10-1.
"Gas Analysis for the Determination of Dry Molecular Weight."
40 CFR 60 Appendix A, Method 3, July 1, 1991.
D-5.7-71
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler:
Process Sample Location:
Sampling and
Health and Safety Equipment:
Sample Collection Frequency:
Sampling Procedures:
Sample Preservation:
Documentation and
Record-Keeping:
Quality Assurance and
Quality Control:
24
Sampling Procedure for Opacity in the Stack Gases
Stack gas continuous emissions opacity monitoring
Stack sampling specialists
Samples will be collected at the stack.
In situ, continuous monitoring system for opacity, calibration attenuators
No specific health and safety equipment required.
The samples will be collected continuously for the duration of each
sampling run.
The opacity monitor is a 2-pass, in situ monitor with an internal reference
cell, automated calibration , and continuously cleaning analyzer optics.
The monitor has a peak and mean spectral response between 500 to 600
nanometers with an angle of view of less than 5 °C and an angle of
projection of less than 5 °C.
The instrument will be prepared and operated during the test using the
procedure provided by the manufacturer. The monitor will be calibrated
before each sampling run using three calibration attenuators with an
absorbance approximating the opacity range of the stack gas. The
calibration of the instrument will also be verified following each test run.
No specific holding times apply to this procedure.
Documentation of data recorded by the computer.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
During the testing program, the quality assurance measures specified in
the referenced methods will be performed. The quality assurance
project plan lists the specific protocols associated with determining
continuous emission monitoring system performance.
D-5.7-72
-------
Method Reference:
"Specifications and Test Procedures for Opacity Continuous Emission
Monitoring Systems in Stationary Sources." 40 CFR 60 Appendix B,
Performance Specification 1, July 1, 1991.
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
25
Density Measurement
High-British thermal unit (Btu) liquid waste feed
Low-Btu liquid waste feed
None, perform in a timely manner (generally within 30 days).
A measured volume of the liquid waste feed material will be weighed to
the nearest 0.1 gram on a calibrated analytical balance. All graduated
cylinders will be calibrated with Type II water at the specified
temperature in the method.
Solid volumes will be determined by displacement.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Standard Test Method for Specific Gravity and Density of Semi-Solid
Bituminous Material." ASTM D-70-82. Taken from Annual Book of
ASTMStandards. D-1989-93. American Society for Testing and
Materials, ASTM: Philadelphia, PA, 1996.
"Standard Test Method for Specific Gravity of Soils." ASTM D-854.
Taken from Annual Book of ASTM Standards. D-1989-93. American
Society for Testing and Materials, ASTM: Philadelphia, PA, 1996.
"Test Method for Specific Gravity of Liquid Industrial Chemicals."
ASTM D-891 -89. Taken from Annual Book of ASTM Standards.
D-1989-93. American Society for Testing and Materials, ASTM:
Philadelphia, PA, 1996.
"Test Method for Specific Gravity of Water and Brine." ASTM
D-1429-86. Taken from Annual Book of ASTM Standards. D-1989-
93. American Society for Testing and Materials, ASTM: Philadelphia,
PA, 1996.
D-5.7-73
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method Reference:
26
Viscosity Measurement
High-Btu liquid waste feed
Low-Btu liquid waste feed
None, perform in a timely manner (generally within 30 days).
The time necessary for a fixed volume of sample to pass through the
viscometer will be measured. The temperature will be recorded and the
viscosity will be determined in accordance with the procedures specified
in the apparatus manual.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Test Method for Kinematic Viscosity of Transparent and Opaque
Liquids (and the Calculation of Dynamic Viscosity)." ASTM D-445.
Taken from Annual Book of ASTM Standards. D-1989-93. American
Society for Testing and Materials, ASTM: Philadelphia, PA, 1996.
D-5.7-74
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
27
Heat Content (Btu) Analysis
High-British thermal unit (Btu) liquid waste feed
Low-Btu liquid waste feed
Solid waste feed
None, perform in a timely manner (generally within 30 days).
A weighed sample aliquot will be mixed thoroughly and prepared. A
sample aliquot will be burned in an adiabatic bomb calorimeter.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Standard Test Method for Gross Calorific Value of Solid Fuel by
Adiabatic Bomb Calorimeter." ASTM D-2015-77. Taken from Annual
Book of ASTMStandards. D-1989-93. American Society for Testing
and Materials, ASTM: Philadelphia, PA, 1996.
"Standard Test Method for Heat of Combustion of Liquid Hydrocarbon
Fuels by Bomb Calorimeter." ASTM D-240-92. Taken from Annual
Book of ASTM Standards. D-1989-93. American Society for Testing
and Materials, ASTM: Philadelphia, PA, 1996.
D-5.7-75
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
28
Total Chlorine Analysis
High-British thermal unit (Btu) liquid waste feed
Low-Btu liquid waste feed
Solid waste feed
None, perform in a timely manner (generally within 30 days).
An aliquot of the sample will be prepared by Parr bomb combustion.
Next, the bomb washings will be analyzed for total chlorine by silver
nitrate titration or ion chromatography detection methods.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Standard Test Method for Chlorine in New and Used Petroleum
Products (Bomb Method)." ASTM D-808-81. Taken from Annual
Book of ASTMStandards. D-1989-93. American Society for Testing
and Materials, ASTM: Philadelphia, PA, 1996.
"Standard Test Method for Chlorine, Bromine, or Iodine in Organic
Compounds by Oxygen Flask Combustion." ASTM E-442-74. Taken
from Annual Book of ASTM Standards. D-1989-93. American
Society for Testing and Materials, ASTM: Philadelphia, PA, 1996.
D-5.7-76
-------
Procedure Number:
Procedure Title:
Sample Name:
Sampler Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method Reference:
29
Ash Content Analysis
High-British thermal unit (Btu) liquid waste feed
Low-Btu liquid waste feed
Solid waste feed
Ash spike
None, perform in a timely manner (generally within 30 days).
An aliquot of a well-mixed sample will be transferred to a prepared
crucible and weighed.
The sample will be dried to constant weight at 103 °C.
The dried sample will be ashed to constant weight in muffle furnace at
900 °C.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Test Method for Ash from Petroleum Products." ASTM D-482-87.
Taken from Annual Book of ASTM Standards. D-1989-93. American
Society for Testing and Materials; ASTM: Philadelphia, PA, 1996.
D-5.7-77
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
30
Elemental Analysis
High-British thermal unit (Btu) liquid waste feed
Low-Btu liquid waste feed
None, perform in a timely manner (generally within 30 days).
This procedure (ASTM D-3176) incorporates several American Society
for Testing and Materials (ASTM) methods for analysis including
determination of carbon and hydrogen (ASTM D-3178), nitrogen (ASTM
D-3179), ash (ASTM D-3174), moisture (ASTM D-3173), and oxygen
by difference.
The analysis of nitrogen involves converting nitrogen to ammonium salts
with a hot catalyzed mixture of concentrated sulfuric acid and potassium
sulfate. These salts are decomposed subsequently in a hot alkaline
solution from which the ammonia is recovered by distillation and finally
determined by alkalimetric or acidimetric titration. Ash is determined by
weighing the residue remaining after burning the sample under rigidly
controlled conditions of sample weight, temperature, time, atmosphere,
and equipment specifications. The moisture is determined by drying to a
constant weight. Carbon and hydrogen are analyzed by burning a
weighed quantity of sample in a closed system and fixing the products of
combustion in an adsorption train (carbon dioxide absorption bulb and
water absorption bulb) after complete oxidation and purification from
interfering substances.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Practices of Elemental Analysis of Coal and Coke." ASTM D-3176.
Taken from Annual Book of ASTM Standards. D-1989-93. American
Society for Testing and Materials; ASTM: Philadelphia, PA, 1996.
ASTM D-3173. Taken from Annual Book of ASTM Standards. D-
1989-93. American Society for Testing and Materials; ASTM:
Philadelphia, PA, 1996.
ASTM D-3174. Taken from Annual Book of ASTM Standards. D-
1989-93. American Society for Testing and Materials; ASTM:
Philadelphia, PA, 1996.
D-5.7-78
-------
D-5.7-79
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method Reference:
31
Total Dissolved Solids and Total Suspended Solids Analysis
Scrubber Purge Water
Analysis will be done within 7 days of collection.
The volume of a sample aliquot is determined, well mixed, and filtered
through a standard glass fiber filter. Sample filters will be Reeve Angel,
type 934-AH; Gelman, type AE; or equivalent. The filtering apparatus is
tare weighed prior to testing.
Total dissolved solids is determined by evaporating and drying the liquid
passing through the filter to a constant weight at 180 °C. The results are
reported as milligrams per liter of total dissolved solids.
Total suspended solids is determined by drying the residue on the filter to
a constant weight at 103 °C to 105 °C. The results are reported as
milligrams per liter of total suspended solids.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Method 160.1 - Residue, Filterable (Gravimetric, Dried at 180 °C),
Method 160.2 - Residue, Non-filterable (Gravimetric, Dried at 103 °C to
105 °C), and Method 160.3 - Residue, Total (Gravimetric, Dried at
103 °C to 105 °Q." EPA 600 - Method 160. Taken from Methods for
Chemical Analysis of Water and Waste. EPA-600/4-79-020. U.S.
Environmental Protection Agency, Environmental Monitoring and
Support Laboratory, Cincinnati, OH, 1979.
D-5.7-80
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method Reference:
32
Stack Moisture Content
Multi-metals train
Method 5 hydrogen chloride, chlorine, and particulate train
Modified Method 5 trains
None, it will be performed upon collection.
An increase in volume of impinger water will be measured by weighing
to nearest 0.1 gram.
An increase in weight of indicating silica gel will be measured to nearest
0.1 gram.
Stack moisture content will be calculated using equations provided in the
method referenced.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Determination of Moisture Content in Stack Gases." 40 CFR 60
Appendix A, Method 4, revised July 1, 1996.
D-5.7-81
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
33
Analysis ofSemivolatile PICs and Dioxins and Furans in MM5
Samples
The samples from the modified method 5 train for semivolatile principal
organic hazardous constituents (POHC) and products of incomplete
combustion (PIC) and dioxins and furans analysis will be analyzed under
the three sample portions:
• Particulate Filter, Front Half of the Filter Holder and Probe
Solvent Rinses
XAD-2 Resin Tube, Back Half of the Filter Holder, and Coil
Condenser Solvent Rinses
• Impingers 1, 2, and 3 Composite and Glassware Solvent Rinses
Extraction will be done within 14 days, and analysis will be done within
40 days from extraction.
Parti culate Filter. Front Half of the Filter Holder and Probe Solvent
Rinses—These components will be sequentially Soxhlet extracted using
methylene chloride followed by a separate extraction using toluene. The
acetone and methylene chloride solvent rinses will be extracted with the
methylene chloride (first Soxhlet extraction). The toluene solvent rinses
will be extracted in with the toluene (second Soxhlet extraction). The
extracts will be concentrated being blown down. Fifty percent of the
methylene chloride extract will be analyzed for semivolatile POHCs and
PICs by Method 8270. The other 50 percent of the methylene chloride
extract will be combined with 50 percent of the toluene extract and
analyzed by Method 8290 for dioxins and furans (2,3,7,8 isomers and
totals). The second portion of the toluene extraction will be archived.
XAD-2 Resin Tube. Back Half of the Filter Holder and Coil Condenser
Solvent Rinses—These components will be sequentially Soxhlet
extracted using methylene chloride followed by a separate extraction
using toluene. The acetone and methylene chloride solvent rinses will be
placed in the Soxhlet extractor during the methylene chloride extraction
(first Soxhlet extraction) and the toluene will be placed in the extractor
during the toluene extraction (second Soxhlet extraction). The extract
splitting and analytical schemes for semivolatile POHCs, PICs, dioxins,
and furans are the same as the particulate filter fraction. The extracts
will be concentrated because they will be blown down. Fifty percent of
the methylene chloride extract will be analyzed for semivolatile POHC
and PICs by Method 8270. The other 50 percent of the methylene
D-5.7-82
-------
Quality Assurance and
Quality Control:
Method References:
chloride extract will be combined with 50 percent of the toluene extract
and analyzed by Method 8290 for dioxins and furans (2,3,7,8 isomers and
totals). The second portion of the toluene extraction will be archived.
Impinger 1. 2. and 3 Composite and Glassware Solvent Rinses—These
components will be extracted using a liquid-liquid extraction (Method
3510). The total volume of the impinger composite will be recorded at
the beginning of the extraction so that total analyte masses can be
calculated. A 1-liter portion of the impinger composite and the total
amount of glassware solvent rinses will be extracted as base neutral and
acid extractable fractions. The final combined extract will be blown
down and analyzed for semivolatile POHC and PICs using Method 8270.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Method 3510 - Separatory Funnel Liquid-Liquid Extraction." Taken
from SW-846 Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-3510, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). U.S. Environmental
Protection Agency (EPA), Office of Solid Waste and Emergency
Response (OSWER), Washington, D.C. 20460.
"Method 3540 - Soxhlet Extraction." Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846
Method SW-3540, Third Edition, September 1986. Final Update I (July
1992), Final Update IIA (August 1993), Final Update II (September
1994), Final Update IIB (January 1995), and Final Update III (December
1996).EPA, OSWER, Washington, D.C. 20460.
"Method 3542 - Extraction of Semivolatile Analytes Collected Using
Method 0010 (Modified Method 5 Sampling Train)." Taken from Test
Methods for Evaluating Solid Waste, Physical/Chemical Methods.
SW-846 Method SW-3542, Third Edition, September 1986. Final
Update I (July 1992), Final Update IIA (August 1993), Final Update II
(September 1994), Final Update IIB (January 1995), and Final Update III
(December 1996). EPA, OSWER, Washington, D.C. 20460.
"Method 8270 - Semivolatile Organic Compounds by Gas
Chromatography/Mass Spectrometry (GC/MS): Capillary Column
Technique." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-8270, Third Edition,
D-5.7-83
-------
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Method 8290 - Poly chlorinated Dibenzodioxins (PCDDs) and
Poly chlorinated Dibenzofurans (PCDFs) by High Resolution Gas
Chromatography/High Resolution Mass Spectrometry (HRGC/HRMS)."
Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-8290, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
D-5.7-84
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
34
Analysis of Polynuclear Aromatic Hydrocarbons in MM5 Samples
Particulate Filter, Front Half of the Filter Holder, and Probe Solvent
Rinses
XAD-2 Resin Tube Back Half of the Filter Holder and Coil Condenser
Solvent Rinses
Impingers 1, 2, and 3 Composite and Glassware Solvent Rinses
Extraction will be done within 14 days, and analysis will be done within
40 days from extraction.
Parti culate Filter. Front Half of the Filter Holder and Probe Solvent
Rinses—These components will be Soxhlet extracted using toluene. The
toluene extract will be blown down, and analyzed by Modified Method
8290/California Air Resources Board (CARB) Method 429 for the target
analyte list of polynuclear aromatic hydrocarbons (PAH).
XAD-2 Resin Tube. Back Half of the Filter Holder and Coil Condenser
Solvent Rinses—These components will be Soxhlet extracted using
toluene. The acetone and methylene chloride solvent rinses and the
toluene will be placed in the extractor during the toluene extraction
(second Soxhlet extraction). The toluene extract will be blown down and
analyzed by Modified Method 8290/CARB 429 for the target analyte list
ofPAHs.
Impinger 1. 2. and 3 Composite and Glassware Solvent Rinses—These
components will be extracted using liquid-liquid extraction (Method
3510). The total volume of the impinger composite will be recorded so
that total analyte masses can be calculated. A 1-liter portion of the
impinger composite and the glassware solvent rinses will be extracted as
base-neutral and acid-extractable fractions. The final, combined extract
will be blown down and analyzed by Modified Method 8290/CARB 429
for the target analyte list of PAHs.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Method 3510 - Separatory Funnel Liquid-Liquid Extraction." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method SW-3510, Third Edition, September 1986.
D-5.7-85
-------
Final Update I (July 1992), Final Update IIA (August 1993), Final
Update II (September 1994), Final Update IIB (January 1995), and Final
Update III (December 1996). U.S. Environmental Protection Agency
(EPA), Office of Solid Waste and Emergency Response (OSWER),
Washington, D.C. 20460.
"Method 3540 - Soxhlet Extraction." Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846
Method SW-3540, Third Edition, September 1986. Final Update I (July
1992), Final Update IIA (August 1993), Final Update II (September
1994), Final Update IIB (January 1995), and Final Update III (December
1996). EPA, OSWER, Washington, D.C. 20460.
"Method 3542 - Extraction of Semivolatile Analytes Collected Using
Method 0010 (Modified Method 5 Sampling Train)." Taken from Test
Methods for Evaluating Solid Waste, Physical/Chemical Methods,
(SW-846 Method SW-3542, Third Edition, September 1986. Final
Update I (July 1992), Final Update IIA (August 1993), Final Update II
(September 1994), Final Update IIB (January 1995), and Final Update III
(December 1996). EPA, OSWER, Washington, D.C. 20460.
"Method 8290 - Poly chlorinated Dibenzodioxins (PCDDs) and
Poly chlorinated Dibenzofurans (PCDFs) by High Resolution Gas
Chromatography/High Resolution Mass Spectrometry (HRGC/HRMS)."
Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Method 429 - Determination of Poly cyclic Aromatic Hydrocarbon
Emissions from Stationary Sources." CARE 429. State of California,
Air Resources Board. September 12, 1989.
D-5.7-86
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
35
Analysis of Semivolatile and Nonvolatile Unspeciated Mass in MM5
Samples
Participate Filter, Front Half of the Filter Holder and Probe Solvent
Rinses
XAD-2 Resin Tube Back Half of the Filter Holder, and Coil Condenser
Solvent Rinses
Impingers 1, 2, and 3 Composite and Glassware Solvent Rinses
Extraction will be done within 14 days, and analysis will be done within
40 days from extraction.
Particulate Filter. Front Half of the Filter Holder and Probe Solvent
Rinses—These components will be Soxhlet extracted sequentially using
methylene chloride and toluene. The acetone and methylene chloride
solvent rinses will be extracted in with the methylene chloride (first
Soxhlet extraction). The toluene solvent rinses will be extracted with the
toluene (second Soxhlet extraction). The extracts will be blown down.
Fifty percent of the methylene chloride extract will be analyzed for
semivolatile principal organic hazardous constituents (POHC) and
products of incomplete combustion (PIC) by Method 8270. The other 50
percent of the methylene chloride extract will be combined 50 percent of
the toluene extract and analyzed by Method 8290 for dioxins and furans
(2,3,7,8 isomers and totals).
XAD-2 Resin Tube. Back Half of the Filter Holder and Coil Condenser
Solvent Rinses—These components will be Soxhlet extracted
sequentially using methylene chloride followed by toluene. The acetone
and methylene chloride solvent rinses will be placed in the Soxhlet
extractor during the methylene chloride extraction (first Soxhlet
extraction) and the toluene will be placed in the extractor during the
toluene extraction (second Soxhlet extraction). The extract splitting and
analytical schemes for semivolatile POHCs, PICs, dioxins, and furans
will be the same as for the particulate filter fraction.
Impinger 1. 2. and 3 Composite and Glassware Solvent Rinses—These
components will be extracted using liquid-liquid extraction (Method
3510). The total volume of the impinger composite will be recorded so
that total analyte masses can be calculated. A 1-liter portion of the
impinger composite and the glassware solvent rinses will be extracted as
base neutral and acid extractable fractions. The final, combined extract
D-5.7-87
-------
will be blown down and analyzed for semivolatile POHC and PICs using
Method 8270.
Quality Assurance and
Quality Control:
Method References:
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Method 3510 - Separatory Funnel Liquid-Liquid Extraction." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method SW-3510, Third Edition, September 1986.
Final Update I (July 1992), Final Update IIA (August 1993), Final
Update II (September 1994), Final Update IIB (January 1995), and Final
Update III (December 1996). U.S. Environmental Protection Agency
(EPA), Office of Solid Waste and Emergency Response (OSWER),
Washington, D.C. 20460.
"Method 3540 - Soxhlet Extraction." Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846
Method SW-3540, Third Edition, September 1986. Final Update I (July
1992), Final Update IIA (August 1993), Final Update II (September
1994), Final Update IIB (January 1995), and Final Update III (December
1996). EPA, OSWER, Washington, D.C. 20460.
"Method 3542 - Extraction of Semivolatile Analytes Collected Using
Method 0010 (Modified Method 5 Sampling Train)." Taken from Test
Methods for Evaluating Solid Waste, Physical/Chemical Methods.
SW-846 Method SW-3542, Third Edition, September 1986. Final
Update I (July 1992), Final Update IIA (August 1993), Final Update II
(September 1994), Final Update IIB (January 1995), and Final Update III
(December 1996). EPA, OSWER, Washington, D.C. 20460.
"Method 8270 - Semivolatile Organic Compounds by Gas
Chromatography/Mass Spectrometry (GC/MS): Capillary Column
Technique." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-8270, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
D-5.7-*
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
36
Analysis of Formaldehyde in MM5 Samples
Method 0011 stack gas samples for aldehydes
Analysis will be done within 30 days of collection.
Samples will be analyzed for formaldehyde and other aldehydes by
high-performance liquid chromatography (HPLC) Method 8315. The
following procedures will be used during analysis:
Sample Preparation—The samples will be extracted using methylene
chloride and concentrated to 10 milliliters.
Sample Analysis—The samples will be analyzed by HPLC following
Method 8315. HPLC conditions will be set up that provide separation of
the target carbonyl compounds in the extract. Ultra-violet-visible
detection will be used to measure derivatized samples; the wavelength of
the detector will be set at 360 nanometers.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Method 0011 - Sampling for Formaldehyde Emissions from Stationary
Sources." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-0011, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). U.S. Environmental
Protection Agency (EPA), Office of Solid Waste and Emergency
Response (OSWER), Washington, D.C. 20460.
"Formaldehyde by High Performance Liquid Chromatography." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method SW-8315, Third Edition, September 1986.
Final Update I (July 1992), Final Update IIA (August 1993), Final
Update II (September 1994), Final Update IIB (January 1995), and Final
Update III (December 1996). EPA, OSWER, Washington, D.C. 20460.
D-5.7-89
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
37
Analysis of Metals in Liquids and Solid Waste
Organic liquid
Aqueous liquid
Solid waste feed
Metals spike solution(s)
Analysis will be performed by Method 6010 within 6 months of the date
of collection, and by Method 7470 or 7471 for mercury within 28 days.
An aliquot of the composite sample will be prepared by total metals
digestion prep Method 3050 for liquid and solid samples. Analysis will be
done by Method 6010 (ICAP) or 6020 (ICP-MS) for antimony, arsenic,
barium, beryllium, cadmium, chromium, lead, silver, nickel, selenium, and
thallium and by Method 7470 or Method 7471 (CVAA) for mercury.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Method 3050 - Acid Digestion of Sediments, Sludges, and Soils." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method SW-3050, Third Edition, September 1986.
Final Update I (July 1992), Final Update IIA (August 1993), Final
Update II (September 1994), Final Update IIB (January 1995), and Final
Update III (December 1996). U.S. Environmental Protection Agency
(EPA), Office of Solid Waste and Emergency Response (OSWER),
Washington, D.C. 20460.
"Method 6010 - Inductively Coupled Plasma-Atomic Emission
Spectroscopy." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-6010, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Method 6020 - Inductively Coupled Plasma-Mass Spectroscopy."
Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-6020, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
D-5.7-90
-------
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Method 7470 - Mercury in Liquid Waste (Manual Cold-Vapor
Technique)." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-7470, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Method 7471 - Mercury in Solid or Semisolid Waste (Manual
Cold-Vapor Technique)." Taken from Test Methods for Evaluating
Solid Waste, Physical/Chemical Methods. SW-846 Method SW-7471,
Third Edition, September 1986. Final Update I (July 1992), Final Update
IIA (August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
D-5.7-91
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
38
Analysis of Multi-Metals Train Samples
The samples from the MMT will be analyzed separately as the following
sample types: Probe rinse (0. IN nitric acid and acetone), particulate
filter (glass fiber), impingers 1, 2, and 3 catches (5 percent nitric acid and
10 percent hydrogen peroxide), 4th impinger (empty at start), 4 percent
potassium permanganate and 10 percent sulfuric acid impingers and
8N hydrogen chloride rinse
Analysis will be performed within 6 months from date of collection and
28 days from collection for mercury.
The nitric acid probe rinse sample will be added to the acetone sample
residue (if collected) and parti culate filter. The composite will be
digested with hydrofluoric acid and nitric acid (Methods 3050 and 0060
modified to include hydrofluoric acid).
The digestate is then analyzed by inductively coupled plasma-atomic
emission spectroscopy (ICAP) (Method 6010) or inductively coupled
plasma-mass spectroscopy (ICP-MS) (Method 6020) for the following
metals: antimony, arsenic, barium, beryllium, cadmium, chromium, lead,
silver, nickel, selenium, and thallium and by Method 7470 (manual
cold-vapor technique) for mercury.
Back Half Sample Preparation—The composited back half impinger
sample is prepared by digestion Method 3050/0060. The sample is then
analyzed by ICAP (Method 6010) or ICP-MS (Method 6020) for the
following metals: antimony, arsenic, barium, beryllium, cadmium,
chromium, lead, silver, nickel, selenium, and thallium. A portion of the
digestate will be analyzed for mercury by cold vapor atomic absorption,
Method 7470.
Each of the remaining train portions will receive separate preps and
separate analyses for mercury by Method 0060/Method 7470.
For each of the metals analyzed, a total multi-metals train content will be
reported by summarizing the total micrograms (//g) in the front-half and
the total //g in the back-half samples.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
D-5.7-92
-------
Method References: "Method 3050 - Acid Digestion of Sediments, Sludges, and Soils." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method SW-3050, Third Edition, September 1986.
Final Update I (July 1992), Final Update IIA (August 1993), Final
Update II (September 1994), Final Update IIB (January 1995), and Final
Update III (December 1996). U.S. Environmental Protection Agency
(EPA), Office of Solid Waste and Emergency Response (OSWER),
Washington, D.C. 20460.
"Method 6010 - Inductively Coupled Plasma-Atomic Emission
Spectroscopy." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-6010, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Method 6020 - Inductively Coupled Plasma-Mass Spectroscopy."
Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-6020). Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Method 7470 - Mercury in Liquid Waste (Manual Cold-Vapor
Technique)." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-7470). Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
D-5.7-93
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method Reference:
39
Analysis ofPOHCs in Liquids, Solid and Ash Samples
High-British thermal unit (Btu) liquid waste feed
Low-Btu liquid waste feed
Scrubber purge water
Solid waste feed
Incinerator ash
Makeup water
Caustic
Analysis will be done within 14 days from date of collection.
Grab samples will be syringe composited to form one representative
sample in the laboratory. Solids will be composited by combining portions
of equal weight in the laboratory. Internal standards and surrogates will
be added.
The analysis will proceed per reference method. The method involves
analysis of composite samples for volatile principal organic hazardous
constituents (POHC) using purge and trap gas chromatography and mass
spectroscopy following Method 8260.
Caustic samples may be neutralized with sulfuric acid before analysis, if
necessary, to demonstrate method performance.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Method 8260 - Volatile Organic Compounds by Gas
Chromatography/Mass Spectrometry (GC/MS): Capillary Column
Technique." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-8260, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). U.S. Environmental
Protection Agency, Office of Solid Waste and Emergency Response,
Washington, D.C. 20460.
D-5.7-94
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
40
Analysis of Volatile PICs in Volatile Organic Sampling Train
(VOST) Samples
Volatile organic sampling train (VOST) sorbent resins (Tenax™ and
Anasorb™ 747), VOST condensate
Analysis will be done within 14 days.
VOST tubes will be spiked with the appropriate surrogate and internal
standard compounds before analysis.
Tubes will be desorbed thermally by using a Nutech desorption apparatus
or equivalent.
The two Tenax™ resin tubes and the Anasorb™ 747 sample tubes will
be analyzed separately for volatile principal organic hazardous
constituents and products of incomplete combustion following Method
8260/5041. Field blank and travel blank tubes may be analyzed as a
sample sets.
VOST condensate samples will be analyzed by Method 8260.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Method 5041 - Analysis of Desorption of Sorbent Cartridges from
Volatile Organic Sampling Train (VOST): Capillary GC/MS Technique."
Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-5041, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). U.S. Environmental
Protection Agency (EPA), Office of Solid Waste and Emergency
Response (OSWER), Washington, D.C. 20460.
"Method 8260 - Volatile Organic Compounds by Gas
Chromatography/Mass Spectrometry (GC/MS): Capillary Column
Technique." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-8260). Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
D-5.7-95
-------
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
41
Analysis of Hydrogen Chloride, Chlorine, and Particulate Train
Samples
Particulate sample
Impinger catches (0.1 normality [N] sulfuric acid solution and
0. IN sodium hydroxide solution)
Particulate—none, but analysis will be performed in a timely manner.
Impingers—analysis will be done within 28 days of sample collection.
Particulate Sample—The acetone probe rinse sample will be evaporated
to near dryness, and the residue will be prepared by oven drying at
105 °C for 24 hours. The dried residue will be weighed to a constant
weight on a calibrated analytical balance capable of weighing to the
nearest 0.0001 gram.
The particulate filter sample will be conditioned by oven drying for
24 hours at 105 °C, followed by 2 hours of desiccation. Replicate
weighings of the filter will be conducted every 6 hours while continuing
to desiccate between weighings until a constant weight has been
achieved. The filter sample will be weighed using a calibrated analytical
balance capable of weighing to the nearest 0.0001 gram.
Impinger Samples—The 0. IN sulfuric acid and the 0. IN sodium
hydroxide impinger samples will be analyzed separately for chloride using
an ion chromatograph. Results will be reported as hydrogen chloride and
chlorine catches, respectively.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Isokinetic HC1/C12 Emission Sampling Train." Taken from Test
Methods for Evaluating Solid Waste, Physical/Chemical Methods.
SW-846 Method 0050, Third Edition, September 1986. Final Update I
(July 1992), Final Update IIA (August 1993), Final Update II (September
1994), Final Update IIB (January 1995), and Final Update III (December
D-5.7-96
-------
1996). U.S. Environmental Protection Agency (EPA), Office of Solid
Waste and Emergency Response (OSWER), Washington, D.C. 20460.
"Method 9056 - Determination of Inorganic Anions by Ion
Chromatography." Taken from Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods. SW-846 Method 9056, Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
"Method 9057 - Determination of Chloride from HC1/C12 Emission
Sampling Train (Methods 0050 and 0051) by Anion Chromatography."
Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method SW-9057, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
D-5.7-97
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
42
Analysis ofHexavalent Chromium Samples from the Cr+6 Train
Probe wash, glassware rinses, and impinger catch (0.1 normality [N]
potassium hydroxide and deionized water) sample
A 24-hour holding time applies unless field spikes are applied. If field
spikes are applied, then analysis will be done within 30 days from
sampling initiation.
Samples will be analyzed for hexavalent chromium by ion
chromatography and post-column reactor (IC/PCR) using a
spectrophotometric detector (Method 7199). The following procedures
will be used during analysis:
Sample Preparation—The samples will be nitrogen purged and filtered
on site before shipment. The total volume of the 0. IN potassium
hydroxide solution will be recorded in order that total hexavalent
chromium can be calculated.
Sample Analysis—The filtered samples will be injected into the 1C
sample loop and introduced to the column. The 1C eluent will be a
solution of 250 millimoles (mM) of ammonium sulfate and 100 mM of
ammonium hydroxide. The 1C will use a guard column (Dionex lonPac
NG1) to remove organics, followed by a separator column (Dionex
lonPac AS7), which is a high-capacity ion-exchange resin column. In
the post-column reactor, hexavalent chromium will be derivatized with a
2 mM diphenylcarbazide and 10 percent methanol solution, forming a
colored chromium complex. This colored complex will be quantitated
spectrophotometrically at 520 nanometers using a low volume,
flow-through cell equipped with an ultraviolet-visible lamp detector. The
detector and 1C will be connected to an integration unit for data
recording.
Note: a preconcentrator column preparation will be added to the
analysis procedure, if required, to achieve a lower method detection limit.
Data Reporting—The anticipated detection limit of the method is
1 micrograms per liter (parts per billion). Data will be reported in units of
micrograms per liter on the certificates of analysis and will be multiplied
by the total sample volume of the original sample in the final report.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
D-5.7-98
-------
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
Method References: "Determination of Hexavalent Chromium Emissions from Stationary
Sources." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method 0061, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). U.S. Environmental
Protection Agency (EPA), Office of Solid Waste and Emergency
Response (OSWER), Washington, D.C. 20460.
"Determination of Hexavalent Chromium in Drinking Water,
Groundwater and Industrial Wastewater Effluents by Ion
Chromatography." Taken from Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods. SW-846 Method 7199, Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
D-5.7-99
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
43
Analysis of Volatile Total Chromatographable Organics in SW-0040
Samples
Method 0040 train volatile unspeciated mass
Field samples will be analyzed within 2 hours following collection and not
more than 4 hours following collection.
Samples will be analyzed for hexavalent chromium by ion
chromatography and post column reactor (IC/PCR) using a
spectrophotometric detector (Method 7199). The following procedures
will be used during analysis:
Sample Preparation—The samples will be nitrogen purged and filtered
on site before shipment. The total volume of the 0.1 normality (N)
potassium hydroxide solution will be recorded in order that total
hexavalent chromium can be calculated.
Sample Analysis—The filtered samples will be injected into the 1C
sample loop and introduced to the column. The 1C eluent will be a
solution of 250 millimoles (mM) of ammonium sulfate and 100 mM of
ammonium hydroxide. The 1C will use a guard column (Dionex lonPac
NG1) to remove organics followed by a separator column (Dionex
lonPac AS7), which is a high-capacity ion-exchange resin column. In
the post-column reactor, hexavalent chromium will be derivatized with a
2 mM diphenylcarbazide and 10 percent methanol solution, forming a
colored chromium complex. This colored complex will be quantitated
spectrophotometrically at 520 nanometers using a low volume,
flow-through cell equipped with an ultra-violet-visible lamp detector. The
detector and 1C will be connected to an integration unit for data
recording.
Note: A preconcentrator column preparation will be added to the
analysis procedure, if required, to achieve a lower method detection limit.
Data Reporting—The anticipated detection limit of the method is
1 microgram per liter (parts per billion). Data will be reported in units of
micrograms per liter on the certificates of analysis and will be multiplied
by the total sample volume of the original sample in the final report.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
D-5.7-100
-------
Method References: "Determination of Hexavalent Chromium Emissions from Stationary
Sources." Taken from Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 Method 0061, Third Edition,
September 1986. Final Update I (July 1992), Final Update IIA (August
1993), Final Update II (September 1994), Final Update IIB (January
1995), and Final Update III (December 1996). U.S. Environmental
Protection Agency (EPA), Office of Solid Waste and Emergency
Response (OSWER), Washington, D.C. 20460.
"Determination of Hexavalent Chromium in Drinking Water,
Groundwater and Industrial Wastewater Effluents by Ion
Chromatography." Taken from Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods. SW-846 Method 7199, Third
Edition, September 1986. Final Update I (July 1992), Final Update IIA
(August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
D-5.7-101
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
44
Analysis of Semivolatile Total Chromatographable Organics
MM5 Train Semivolatile Unspeciated Mass
Samples must be extracted within 14 days following collection, and
analyzed within 40 days of extraction.
The total chromatographable organics (TCO) method will be used to
quantify compounds with boiling points between 100 °C and 300 °C
using a gas chromatograph (GC) with a flame ionization detector (FID).
The TCO procedure will be done by analysis of a dichloromethane
extract (a combination of the extracts from the two major components of
the sampling train). The analysis will be performed in the laboratory
after extraction and compositing of the extracts of the individual
components of the Method SW-0010 sampling train.
The front half will be extracted following SW-3540 using Soxhlet
extraction, and the back half will be extracted using a separatory funnel
technique, SW-3510. No spikes or internal standards will be added other
than boiling point markers described below.
The TCO method is a capillary GC/FID method quantifying
chromatographable material in the 100 °C to 300 °C boiling point range.
An aliquot of the Method SW-0010 dichloromethane extract from Train
C will be injected onto a capillary GC column with an FID detector, and
the peak areas are summed over the retention time window that
encompasses the TCO boiling point range. The entire analysis window
will be established by injecting n-heptane and N-heptadecane as the
reference peaks between which the TCO integration will occur. As
described in the method, heptane and heptadecane will be used as
retention time referenced peaks for boiling point.
The TCO value will be determined from the calibration standard curve,
generated with hydrocarbon standards which fall within the TCO range,
specifically decane, dodecane, and tetradecane. An integrator or GC
data system will be used to record the data points as they are obtained
from the injections of calibration standards and samples. The organics
identified in the prescribed boiling point range will be quantified and
summed (totaled) to obtain the TCO portion of the total organics number.
Analysis may be performed using a capillary (preferred) or packed
column GC. A non-polar or slightly polar column will be used to provide
adequate resolution and analysis in a total run time of approximately
45 minutes. A 15- to 30-meter, nonpolar, wide-bore column
D-5.7-102
-------
Quality Assurance and
Quality Control:
Method References:
(0.32 millimeter) has been found to be effective for TCO analysis. As a
capillary or packed column procedure, the GC/FID will be operated in a
manner consistent with the manufacturer's recommendations for gas
flow, temperature zones, and injection volume. Analysis will be
performed most easily using a GC with a liquid autosampler, so that
calibrations and sample injections can be performed in a consistent and
automated fashion. The GC used for TCO analysis will be calibrated
using specific hydrocarbon standard. A multipoint calibration of at least
three different concentrations in duplicate will be required for this
procedure. After calibration has been performed, a daily quality control
check sample will be run to verify that the GC is performing correctly.
The GC check sample will be run with a standard in the middle of the
working range of the GC calibration standards.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Guidance for Total Organics, Final Report." March 1996. Prepared for
Atmospheric Research and Exposure Assessment Laboratory Methods
Research and Development Division Source Method Research Branch,
U.S. Environmental Protection Agency.
"Method 3510 - Separatory Funnel Liquid-Liquid Extraction." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method SW-9057, Third Edition, September 1986.
Final Update I (July 1992), Final Update IIA (August 1993), Final
Update II (September 1994), Final Update IIB (January 1995), and Final
Update III (December 1996). U.S. Environmental Protection Agency
(EPA), Office of Solid Waste and Emergency Response (OSWER),
Washington, D.C. 20460.
"Method 3540 - Soxhlet Extraction." Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846
Method SW-3540, Third Edition, September 1986. Final Update I (July
1992), Final Update IIA (August 1993), Final Update II (September
1994), Final Update IIB (January 1995), and Final Update III (December
1996). EPA, OSWER, Washington, D.C. 20460.
"Modified Method 5 Sampling Train" (MM5) appropriate for sampling
stack gas for semivolatiles. Taken from Test Methods for Evaluating
Solid Waste, Physical/Chemical Methods. SW-846 Method 0010,
Third Edition, September 1986. Final Update I (July 1992), Final Update
IIA (August 1993), Final Update II (September 1994), Final Update IIB
D-5.7-103
-------
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
D-5.7-104
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
Quality Assurance and
Quality Control:
Method References:
45
Analysis of GRAY in Organic Extracts
Modified Method 5 Train Nonvolatile Unspeciated Mass
Extraction will be done within 14 days following collection, and analysis
will be done within 40 days following extraction.
The method will determine the total organic compounds with boiling
points of 300 °C and higher, after extraction, and drying to constant
weight. The procedure will involve gravimetric (GRAY) determination
following extraction and drying of sample to constant weight.
The front half will be extracted following SW-3540 using Soxhlet
extraction, and the back half will be extracted using the SW-3510
separatory funnel technique.
The GRAY method will quantify nonvolatile organic material with a
boiling point greater than 300 °C. A carefully measured aliquot of the
Method SW-0010 dichloromethane extract will be placed in a precleaned
aluminum weighing pan and allowed to dry in air at room temperature,
then will come to complete dryness in a room temperature desiccator,
while exposure to dust and contaminants will be minimized. The residue
in the pan will be weighed accurately, and the mass will be recorded to
determine the GRAY value. For this procedure, two individual
dichloromethane extracts from Method SW-0010 will be pooled and
reduced to a final volume of 5.0 mL. A volume of 1 milliliters (mL) of
the pooled extract is used for the GRAY determinations, which are
performed in duplicate. Other final extract and GRAY aliquot volumes
may be used, but the sample extraction and concentration procedures will
be followed closely to avoid loss of more volatile organics. The GRAY
organics in the greater than 300 °C range will be measured on an
analytical balance and recorded for the GRAY portion of the total
organics number.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Guidance for Total Organics, Final Report." March 1996. Prepared for
Atmospheric Research and Exposure Assessment Laboratory Methods
Research and Development Division Source Method Research Branch,
U.S. Environmental Protection Agency (EPA).
D-5.7-105
-------
"Method 3510 - Separatory Funnel Liquid-Liquid Extraction." Taken
from Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods. SW-846 Method SW-3510, Third Edition, September 1986.
Final Update I (July 1992), Final Update IIA (August 1993), Final
Update II (September 1994), Final Update IIB (January 1995), and Final
Update III (December 1996). EPA, Office of Solid Waste and
Emergency Response (OSWER), Washington, D.C. 20460.
"Method 3540 - Soxhlet Extraction." Taken from Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods. SW-846
Method SW-3540). Third Edition, September 1986. Final Update I (July
1992), Final Update IIA (August 1993), Final Update II (September
1994), Final Update IIB (January 1995), and Final Update III (December
1996). EPA, OSWER, Washington, D.C. 20460.
"Modified Method 5 Sampling Train" [(MM5) is appropriate for sampling
stack gas for semivolatiles]. Taken from Test Methods for Evaluating
Solid Waste, Physical/Chemical Methods. SW-846 Method 0010,
Third Edition, September 1986. Final Update I (July 1992), Final Update
IIA (August 1993), Final Update II (September 1994), Final Update IIB
(January 1995), and Final Update III (December 1996). EPA, OSWER,
Washington, D.C. 20460.
D-5.7-106
-------
Procedure Number:
Procedure Title:
Sample Name:
Sample Holding Time:
Analytical Procedures:
46
Analysis of Volatile Total Chromatographable Organics in SW-0040
Samples
Method 0040 Train Volatile Unspeciated Mass
Field samples will be analyzed within 2 hours following collection, and not
more than 4 hours following collection. Condensate samples shall be
analyzed within 14 days following collection.
Two portions (bag sample and condensate) of this stack gas sample will
be analyzed separately and reported separately.
Bag Sample—This sample will be analyzed by field gas chromatography
using a flame ionization detector (FID) to determine compounds in the Q
to C7 hydrocarbon range. Species eluting in the specified boiling range
are quantified as n-alkanes.
Compounds with boiling points below 100 °C will be sampled and placed
into Tedlar™ bags and will require on-site gas chronographic analysis of
the collected sample. The range of applicable compounds will be very
large. If a packed column is used to perform all of the gas
chromatographic analysis, a very judicious selection of phases and
analytical conditions will be made in order to achieve simultaneous
chromatographic resolution for methane and a total analysis time limited
to no more than 15 to 20 minutes.
The field GC may use two chromatographs, one with an appropriate
column and conditions for Q to C4, and the second with an appropriate
column and conditions for the C4 to C6 range. A capillary column will be
required to perform the analysis over the entire volatility range with
adequate resolution. A capillary column with a length of 60 meters may
be required to provide adequate resolution for the C2 hydrocarbon
isomers. The gas chromatographic analysis will be primarily the
separation of compounds on the basis of boiling points, but the separation
also will be influenced by the polarity of the compounds in some cases.
Numerous chromatographic conditions, such as column temperature,
ramp for temperature programming, duration of isothermal hold, and
temperature of any transfer line, will have to be optimized for the best
chromatographic results. An FID will be required to perform the
analysis.
Condensate Sample—This sample will be analyzed by field
chromatography using an FID and employing purge-and-trap techniques
D-5.7-107
-------
to determine compounds in the Cl to C7 hydrocarbon range. Species
eluting in the specified boiling range are quantified as n-alkanes.
Note: A pre-trial burn survey may be required to set up calibration
ranges, GC column, and temperature programming.
Compounds with boiling points below 100 °C will be sampled by
SW-0040 into the condensate head of the Tedlar™ bag. This
condensate requires purge and trap gas chromatographic analysis of the
collected sample water. A gas chromatograph with an appropriate
column and conditions for the C5 to C7 range will be required. A
capillary column with a length of 60 meters may be required to provide
adequate resolution for smaller organic and hydrocarbon isomers. An
FID will be required to perform this analysis.
The purge and trap GC must be calibrated for quantitative analysis with a
normal hydrocarbon curve. The curve will be prepared using liquid
alkane standards containing the n-alkanes from C5 to C7. A multipoint
calibration of at least three points (in duplicate) will be required. The
alkane mixture will be used to calibrate the GC, and a point
approximately in the middle of the calibration range will be analyzed at
least once per day as a calibration check. The multipoint calibration will
be achieved through the use of serial dilutions of the primarily stock
standard mixture in methanol solution.
After full calibration, sample analysis will be initiated when an aliquot of
the water sample in the volatile organic analysis (VOA) vial is
transferred to the purge flask. The purge gas will be activated, purging
the vapor with an inert gas to the sorbent trap (VOCOL, VOCARB, or
equivalent). When the sample is sufficiently purged from the vessel into
the trap, the valve will be actuated, and the trap contents will be
desorbed by rapid heating onto the head of the GC column with the FID
detector. The temperature programmer and the integrator/data system
data acquisition will be started. Chromatograms and integrator/data
system output will be collected.
The gas chromatograph must be calibrated for quantitative analysis with
a normal hydrocarbon curve. The curve will be prepared using certified
cylinders containing the n-alkanes from Q to C6. A multipoint calibration
of a least three points (in duplicate) will be required. Calibration for
methane must be performed carefully so that the quantity of methane can
be determined accurately. Methane will be found in significant quantities
when combustion stacks are sampled, and it will be essential to be able to
identify the compound correctly and provide an accurate quantitative
measurement because the quantity of methane is a key parameter in risk
assessment evaluation of unspeciated mass. The certified Cl to C6
D-5.7-108
-------
Quality Assurance and
Quality Control:
Method Reference:
standard gas mixture will be used to calibrate the field gas
chromatograph, and a point approximately in the middle of the calibration
range will be analyzed at least once per day as a calibration check. The
multipoint calibration will be achieved either through the use of multiple
cylinders at different concentrations or by the use of sample loops of
varying sizes.
Note: A pre-trial burn survey may be required to set up calibration
ranges, GC column, and temperature programming.
After full calibration, sample analysis will be initiated when the sample
container (the Tedlar™ bag) is connected to the sampling valve and the
sample gas is drawn through the valve and sample loop. When the valve
is sufficiently purged, the valve will be actuated, and the contents of the
loop will be injected into the chromatograph. Simultaneously with the
injection of the sample, the temperature programmer and integrator/data
system data acquisition will be started. Chromatograms and
integrator/data system output will be collected. Retention times and
responses must agree to within 5 percent relative standard deviation with
the calibration curve. Uniform FID responses for varying compound
classes will be assumed in this methodology. The resulting quantitative
results therefore tend to be biased low for compounds that are not
n-alkanes. In many, if not most, cases the species present will not be
identical to those used for calibration of the on-site chromatograph; an
exact correspondence between standard peaks and the peaks observed
in the sample chromatograph will not be achieved.
Uniform FID responses for varying compound classes will be assumed in
the methodology. Compounds found with retention times prior to the C4
retention time will be quantified with an appropriate response factor and
the value reported as C4 with the other organic results.
The required number of analyses for these samples is defined in
Table 10-1 of the quality assurance project plan. The laboratory is
required to analyze separately all of the field samples, field quality control
samples, and laboratory quality control samples specified in Table 10-1.
"Guidance for Total Organics, Final Report." March 1996. Prepared for
Atmospheric Research and Exposure Assessment Laboratory Methods
Research and Development Division Source Method Research Branch,
U.S. Environmental Protection Agency.
D-5.7-109
-------
APPENDIX D-5.8
POHC DRE SAMPLING TIME AND SPIKING CALCULATIONS
-------
APPENDIX D-5.8
POHC DRE SAMPLING TIME AND SPIKING CALCULATIONS
Purpose
The purpose of this appendix is to confirm that 99.99 percent destruction and removal efficiency (DRE)
can be validated using the proposed sampling times and analytical methods for the DRE portion of the trial
burn. The principal organic hazardous constituents (POHC) to be sampled are chlorobenzene, carbon
tetrachloride, and naphthalene. The stack gas will be sampled using the volatile organic sampling train
(VOST, Method 0031) to identify any chlorobenzene and carbon tetrachloride POHCs. The stack gas
will be sampled for the POHC naphthalene using the Modified Method 5 sampling train (MM5, Method
0010).
A minimum of 10 nanograms (r|g) of chlorobenzene and 10 r|g of carbon tetrachloride per VOST Tenax
tube is required for analysis. A maximum of 1,000 r|g is required for analysis of these compounds. A
minimum of 20 micrograms (ug) of naphthalene per XAD-2 resin tube and 100 ug for the MM5 train is
required for analysis. The following calculations confirm that the amount of POHCs spiked will satisfy
this requirement.
Actual stack gas flow rates and required POHC feed rates will be determined during the
startup and shakedown period for the incinerator. The [Enter State EPA Name] ([Enter State EPA
Acronym]) and the U.S. Environmental Protection Agency (EPA) will be notified at least 30 days before
the trial burn of any necessary modifications to the test protocol or sampling methods.
POHCs spiked during trial burn Test 2 are for DRE demonstration. During trial burn Tests 1 and 2,
perchloroethylene will be spiked to the solid wastes and high-British thermal unit (Btu) liquid wastes to
provide chlorine loading only. No DRE sampling and analysis will be performed for perchloroethylene
during Tests 1 and 2.
D-5.8-1
-------
Chlorobenzene and Carbon Tetrachloride Sampling
The following stack gas concentration is the minimum required to achieve the minimum loading required:
(10 r|g/tube)(2 tubes/tube set)(l,000 L/m3)/(20 L sample per tube set) = 1,000 r|g/m3
Anticipated approximate stack gas flow rate = 4,300 dscf/min
= 122 dscm/min
where
r|g = nanograms
L/m3 = liters per cubic meter
L = liter
rjg/m3 = nanograms per cubic meter
dscf/min = dry standard cubic feet per minute
dscm/min = dry standard cubic meters per minute
The minimum spiking rate to demonstrate DRE is as follows (with the stated assumptions):
99.99% DRE,
(1,000 r|g/m3)(122 m3/min)(60 min/hr)(lxlO-9g/r]g)/(l-0.9999) = 73.2 g/hr
0.1611b/hr
99.999% DRE,
(1,000 r|g/m3)(122 m3/min)(60 min/hr)(lxlO-9g/r]g)/(l-0.99999) = 732 g/hr
1.61 Ib/hr
99.9999% DRE,
(1,000 r|g/m3)(122 m3/min)(60 min/hr)(lxlO-9g/r]g)/(l-0.999999=) 7,320 g/hr
16.11b/hr
D-5.8-2
-------
where
r|g/m3 = nanograms per cubic meter
m3/min = cubic meters per minute
min/hr = minutes per hour
g/rjg = grams per nanogram
g/hr = grams per hour
Ib/hr = pounds per hour
Using the following assumptions, the amount of POHC per VOST tube set can be calculated:
DRE of 99.9999 percent
• Nominal feed rate of 20 pounds per hour for each volatile POHC
• Collection of 0.5 liter per minute of stack gas for 40 minutes (slow VOST) for a total of
20 liters of stack gas
The amount of POHC collected per VOST tube set is estimated to be as follows:
(20 Ib/hr feed)(l-0.999999)(453.6 g/lb¥lx!09r|g/g¥20 L/tube set) = 25r|g
(122 m3/min)(60 min/hr)(1000 L/m3)
where
Ib/hr = pounds per hour
g/lb = grams per pound
rjg/g = nanograms per gram
L = liter
m3/min = cubic meters per minute
min/hr = minutes per hour
L/m3 = liters per cubic meter
r|g = nanograms
Naphthalene Sampling
The following stack gas concentration is the minimum required to achieve the minimum naphthalene
loading required:
D-5.8-3
-------
(100 ug/train)/(3 m3 sample size) = 33.3 ug/m3
Anticipated approximate stack gas flow rate = 4,300 dscf/min
= 122 dscm/min
where
ug/train = micrograms per train
m3 = cubic meters
ug/m3 = micrograms per cubic meter
dscf/min = dry standard cubic feet per minute
dscm/min = dry standard cubic meters per minute
The minimum spiking rate to demonstrate DRE is as follows (with the stated assumptions):
99.99% DRE,
(33.3 ug/m3)(122m3/min)(60min/hr)(lxlO-6g/^g)/(l-0-9999) = 2,440 g/hr
5.38 Ib/hr
99.999% DRE,
(33.3 ug/m3)(122m3/min)(60min/hr)(lxlO-6g/^gy(l-0-99999) = 24,400 g/hr
53.8 Ib/hr
99.9999% DRE,
(33.3 ug/m3)(122m3/min)(60min/hr)(lxlO-6g/^gy(l-0-999999) = 244,000 g/hr
538 Ib/hr
where
ug/m3 = micrograms per cubic meter
m3/min = cubic meters per minute
min/hr = minutes per hour
g/ug = grams per microgram
g/hr = grams per hour
Ib/hr = pounds per hour
D-5.8-4
-------
Using the following assumptions, the amount of napthalene per MM5 train can be calculated:
DRE of 99.999 percent
• Nominal feed rate of 60 pounds per hour for naphthalene
• 3 cubic meters of stack gas collected
The amount of naphthalene collected per MM5 train is estimated to be as follows:
(60 Ib/hr feed)(l-0.99999)(453.6 g/lb¥lxl06r|g/g¥3 m3 sample)
(122 m3/min)(60 min/hr)
112 r,g
where
Ib/hr
g/lb
m3
m3/min
min/hr
pounds per hour
grams per pound
nanograms per gram
cubic meters
cubic meters per minute
minutes per hour
nanograms
D-5.8-5
-------
APPENDIX D-5.9
MASS AND ENERGY BALANCE FOR TRIAL BURN
-------
APPENDIX D-5.9
MASS AND ENERGY BALANCE FOR TRIAL BURN
This appendix must include a complete mass and energy balance for each trial burn test condition and
normal operation showing, at a minimum, the following information:
• Mass flow rates, temperatures, and pressures of all process input streams
• Mass flow rates, temperatures, and pressures of all process output streams
• Mass and energy inputs and outputs at each discrete unit operation within the overall
process (such as rotary kiln, secondary combustion chamber, quench, and wet scrubber)
• Operating conditions (such as temperature and pressure) of each unit operation
D-5.9-1
-------
APPENDIX D-5.10
AIR DISPERSION MODELING REPORT
-------
APPENDIX D-5.10
AIR DISPERSION MODELING REPORT
The preliminary air dispersion modeling report used to develop proposed Tier III limits should be provided
in this appendix.
D-5.10-1
-------
GENERIC TRIAL BURN PLAN
ATTACHMENT A
FIGURES
-------
ATTACHMENT A-l
FIGURE D-5.1
SITE PLAN
-------
TEXAS HIGHWAY AB
TEXAS HOME
ASSISTANCE CENTER
VINYL CHLORIDE
MONOMER
PRODUCTION
METHYL ETHYL KETONE
PRODUCTION
ADMINISTRATION
ACETONITRILE
PRODUCTION
VINYL ACETATE
PRODUCTION
WASTE
BLENDING AND
STORAGE
AIR POLLUTION
CONTROL
INCINERATION ASH
WASTEWATER
TREATMENT
HANDLING
HEAT
RECOVERY
0 1000 2000
SCALE IN FEET
FACILITY NAME
CITY, STATE
FIGURE D-5.1
SITE PLAN
A-l
-------
ATTACHMENT A-2
FIGURE D-5.2
WASTE TREATMENT SYSTEM FLOW DIAGRAM
-------
HAZWASTE FROM
ON-SITE
PROCESSES
SOLID AND LIQUID
V HAZWASTE
STORAGE AND
HANDLING
COMBUSTION AIR
AND AUXILIARY
FUEL
LIQUID
HAZWASTE
SOLID AND LIQUID
HAZWASTE
ROTARY KILN
SECONDARY
COMBUSTION
CHAMBER
COMBUSTION
GAS N»
STEAM TO
ON-SITE
PROCESSES
COMBUSTION
GAS
HEAT
RECOVERY
BOILER
ASH
WATER
COMBUSTION
GAS
TO EXHAUST
STACK
SCRUBBER
SYSTEM
ASH
HANDLING
WATER AND
CAUSTIC
LIQUID
SLOWDOWN
TO WASTEWATER
TREATMENT
ASH (STABILIZED)
OFF-SITE
HAZWASTE
LANDFILL
NOTE:
HAZWASTE HAZARDOUS WASTE
FACILITY NAME
CITY, STATE
FIGURE D-5.2
WASTE TREATMENT SYSTEM
FLOW DIAGRAM
A-2
-------
ATTACHMENT A-3
FIGURE D-5.3
ROTARY KILN INCINERATOR SYSTEM BLOCK FLOW DIAGRAM
-------
ATOMIZATION STEAM
-
HIGH-BTU LIQUIDS
N, ,
\
ATOMIZATION AIR
\
LOW-BTULIQUIDS
STACK GAS RECYCLE
THERMAL RELIEF BOILER WATER
VENT FEED STEAM
NATURAL GAS
SOLID AND SLUDGE WASTE
PROCESS WATER
^{O/
^^
INDUCED DRAFT
FAN
/ CAUSTIC /
NOTES:
BTU BRITISH THERMAL UNIT
WESP WET ELECTROSTATIC PRECIPITATOR
FACILITY NAME
CITY, STATE
FIGURE D-5.3
ROTARY KILN INCINERATOR SYSTEM
BLOCK FLOW DIAGRAM
A-3
-------
ATTACHMENT A-4
FIGURE D-5.4
COMBUSTION PROCESS FLOW DIAGRAM WITH SAMPLING LOCATIONS
-------
PROCESS
WATER
VENTURI
AND WET
ELECTRO-
STATIC
PRECIPITATOR
LIQUID
BLOWDOWN
TO WWTS
NOTES
REFER TO TABLE D-5.4 FOR A SUMMARY OF SAMPLING
AND ANALYSIS PROGRAM.
ID INDUCED DRAFT
SCC SECONDARY COMBUSTION CHAMBER
WWTS WASTEWATER TREATMENT SYSTEM
SAMPLE LOCATION
o
FACILITY NAME
CITY, STATE
FIGURE D-5.4
COMBUSTION PROCESS FLOW DIAGRAM
WITH SAMPLING LOCATIONS
A-4
-------
ATTACHMENT A-5
FIGURE D-5.5
METHOD 0060—MULTI-METALS SAMPLING TRAIN
-------
. TEMPERATURE READOUT
THERMOCOUPLE
' PROBE AND NOZZLE
PITOT TUBE
MANOMETER
INSET
Sample port
(typical 2 places)
Stack wall
Isokinetic sampling points
NOTE: Nozzle and probe are inserted through sample
ports and operated at isokinetic points determined
according to Method 1.
NOTES:
HN03
H202
KMnO4
H2S04
NITRIC ACID
HYDROGEN PEROXIDE
POTASSIUM PERMANGANATE
SULFURIC ACID
UMBILICAL CORD
4% KMnO4/10% H2SO4 IMPINGERS
INDICATING SILICA GEL
CONTROL BOX CONTAINS DRY GAS METER,
PUMP, FLOW CONTROLS, AND HEAT CONTROLS
FACILITY NAME
CITY, STATE
FIGURE D-5.5
METHOD 0060 — MULTI-METALS
SAMPLING TRAIN
A-5
-------
ATTACHMENT A-6
FIGURE D-5.6
METHOD 0061—HEXAVALENT CHROMIUM SAMPLING TRAIN
-------
. TEFLON T-UNION
— TEFLON IMPINGERS
NOZZLE
RECIRCULATING
LIQUID
PERISTALIC
PUMP
INSET
Sample port
(typical 2 places)
Stack wall
UMBILICAL CORD
150 mL 0.1 KOH
75mL0.1KOH
Isokinetic sampling points
NOTE: Nozzle and probe are inserted through sample
ports and operated at isokinetic points determined
according to Method 1.
CONTROL BOX CONTAINS DRY GAS METER,
PUMP, FLOW CONTROLS, AND HEAT CONTROLS
NOTES:
mL MLLILITER
KOH POTASSIUM HYDROXIDE
FACILITY NAME
CITY, STATE
FIGURE D-5.6
METHOD 0061 — HEXAVALENT
CHROMIUM SAMPLING TRAIN
-------
ATTACHMENT A-7
FIGURE D-5.7
METHOD 0050—HYDROGEN CHLORIDE, CHLORINE, AND PARTICULATE MATTER
SAMPLING TRAIN
-------
TEMPERATURE READOUT
THERMOCOUPLE
PROBE AND NOZZLE
PITOT TUBE
MANOMETER
INSET
Sample port
(typical 2 places)
Stack wall
Isokinetic sampling points
NOTE: Nozzle and probe are inserted through sample
ports and operated at isokinetic points determined
according to Method 1.
NOTES:
N
H2SO4
NaOH
NORMALITY
SULFURIC ACID
SODIUM HYDROXIDE
UMBILICAL CORD
0.1NH2SO4IMPINGERS
0.1N NaOH IMPINGERS
INDICATING SILICA GEL
CONTROL BOX CONTAINS DRY GAS METER,
PUMP, FLOW CONTROLS, AND HEAT CONTROLS
FACILITY NAME
CITY, STATE
FIGURE D-5.7
METHOD 0050 — HYDROGEN CHLORIDE,
CHLORINE, AND PARTICULATE
MATTER SAMPLING TRAIN
A-7
-------
ATTACHMENT A-8
FIGURE D-5.8
METHOD 0031—VOLATILE ORGANIC SAMPLING TRAIN
-------
CARBON FILTER
GLASS WOOL
PARTICULATE
FILTER
HEATED PROBE
THERMOCOUPLE
TENAX
CONTROL BOX CONTAINS DRY GAS
METER, PUMP, FLOW CONTROLS,
AND HEAT CONTROLS
ISOLATION VALVE
CONDENSERS
WATER RECIRCULATION
PUMP
CONDENSATE
TRAP
FACILITY NAME
CITY, STATE
FIGURE D-5.8
METHOD 0031 — VOLATILE ORGANIC
SAMPLING TRAIN
A-8
-------
ATTACHMENT A-9
FIGURE D-5.9
METHOD 0040—TEDLAR BAG ORGANIC SAMPLING TRAIN
-------
PROBE
3-WAY
VALVES
CHARCOAL TUBE
NOTE:
T THERMOCOUPLE
QUICK CONNECT
FILLINGS
TO CONSOLE
RIGID LEAKTIGHT BOX
FACILITY NAME
CITY, STATE
FIGURE D-5.9
METHOD 0040 — TEDLAR BAG ORGANIC
SAMPLING TRAIN
-------
ATTACHMENT A-10
FIGURE D-5.10
MODIFIED METHOD 5—SEMIVOLATILE PIC, PCDD AND PCDF, AND PAH SAMPLING
TRAIN
-------
- TEMPERATURE READOUT
-THERMOCOUPLE
"PROBE AND NOZZLE
PITOT TUBE
MANOMETER •
INSET
Sample port
(typical 2 places)
Stack wall
Isokinetic sampling points
NOTE: Nozzle and probe are inserted through sample
ports and operated at isokinetic points determined
according to Method 1.
NOTES:
UMBILICAL CORD
ICE BATH-
EMPTY
DISTILLED WATER
SAME BASIC CONFIGURATION FOR
MODIFIED METHOD 5A, 5B, AND 5C TRAINS
T THERMOCOUPLE
INDICATING
SILICA GEL
CONTROL BOX CONTAINS DRY GAS METER,
PUMP, FLOW CONTROLS, AND HEAT CONTROLS'
FACILITY NAME
CITY, STATE
FIGURE D-5.10
MODIFIED METHOD 5 — SEMIVOLATILE
PIC, PCDD AND PCDF, AND PAH
SAMPLING TRAIN
A-10
-------
ATTACHMENT A-11
FIGURE D-5.11
METHOD 0011—ALDEHYDE AND KETONE SAMPLING TRAIN
-------
. TEMPERATURE READOUT
THERMOCOUPLE
PROBE AND NOZZLE
V
PITOT TUBE
MANOMETER
UMBILICAL CORD
INSET
Sample port
(typical 2 places)
Stack wall
Isokinetic sampling points
NOTE: Nozzle and probe are inserted through sample
ports and operated at isokinetic points determined
according to Method 1.
ICE BATH
100-mL DNPH
200-mL DNPH
EMPTY MOISTURE KNOCKOUT IMPINGER
INDICATING
SILICA GEL
CONTROL BOX CONTAINS DRY GAS METER,
PUMP, FLOW CONTROLS, AND HEAT CONTROLS
NOTES:
DNPH
mL
DINITROPHENYLHYDRAZINE
MILLILITER
FACILITY NAME
CITY, STATE
FIGURE D-5.11
METHOD 0011 — ALDEHYDE AND
KETONE SAMPLING TRAIN
A-ll
-------
GENERIC TRIAL BURN PLAN
ATTACHMENT B
TABLES
-------
ATTACHMENT B-l
TABLE D-5.1
INCINERATION SYSTEM WASTE ACCEPTANCE CRITERIA
-------
TABLE D-5.1
INCINERATION SYSTEM WASTE ACCEPTANCE CRITERIA
Parameter
Heat Value
• Solids
• Liquids
Chlorine Content (all
wastes)
PCB Content (all
wastes)
Viscosity (liquid waste
streams only)
Total Suspended Solids
(liquid waste streams
only)
Nitrogen Content (all
wastes)
Noncarcinogenic
Metals Content (all
wastes)
Limit or Constraint
[###] - [###] Btu/lb
[###] - [###] Btu/lb
[###] ppm
Prohibited
[###] centipoise
[###] ppm
[###] ppm
Antimony [###] ppm
Barium [###] ppm
Chromium [###] ppm (total)
Lead [###] ppm
Mercury [###] ppm
Nickel [###] ppm
Selenium [###] ppm
Silver [###] ppm
Thallium [###] ppm
Basis
Ensures proper
combustion chamber
temperature
Tier III limit
Unit is not permitted under
TSCA
Ensures proper burner
performance
Higher levels could
damage or plug burners
Air permit limitations on
NOX
Tier I limit
Notes
May change as a
result of trial burn
testing
May change as a
result of trial burn
testing
Will not change as
a result of trial
burn testing
Will not change as
a result of trial
burn testing
because it is a
Group C parameter
Will not change as
a result of trial
burn testing
because it is a
Group C parameter
Will not change as
a result of trial
burn testing
(This acceptance
criteria is driven by
an air permit.)
Will not change as
a result of trial
burn testing
(Constraints on
metal
concentrations are
backcalculated
from Tier I
emissions limits,
which are
independent of
trial burn testing.)
B-l
-------
TABLE D-5.1
INCINERATION SYSTEM WASTE ACCEPTANCE CRITERIA
Parameter
Carcinogenic Metals
Content (all wastes)
Ash Content (liquid
wastes only)
Limit or Constraint
Arsenic [###] ppm
Beryllium [###] ppm
Cadmium [###] ppm
Hexavalent chromium [###] ppm
15wt. %
Basis
Tier III limit
Ensures compliance with
PM standard
Notes
May change as a
result of trial burn
testing
May change as a
result of trial burn
testing
Notes:
Btu/lb
NOX
PCB
PM
ppm
TSCA
wt. %
British thermal units per pound
Nitrogen oxide
Poly chlorinated biphenyl
Particulate matter
Parts per million
Toxic Substances Control Act
Weight percent
B-2
-------
ATTACHMENT B-2
TABLE D-5.2
WASTE CHARACTERISTICS
-------
TABLE D-5.2
WASTE CHARACTERISTICS
Waste Stream
Low-Btu liquid
wastes
High-Btu liquid
wastes
Solid Wastes
Heat Value
(Btu/lb)
5,000 to 8,000
8,000 to 14,000
5,000 to 11,000
Constituents and Other Characteristics
Water, 40 to 70 wt. %
Methanol, 10 to 30 wt. %
Acetone, 0 to 20 wt. %
Chlorides, [###] to [###] wt. %
Various metals in ppm concentrations
Viscosity, [###] to [###] centipoise
Solids content, [###] to [###] wt. %
Water, 0 to 10 wt. %
Methanol, 10 to 70 wt. %
Acetone, 10 to 60 wt. %
Benzene, 5 to 50 wt. %
Chlorides, [###] to [###] wt. %
Various metals in ppm concentrations
Viscosity, [###] to [###] centipoise
Solids Content, [###] to [###] wt. %
Water, 30 to 50 wt. %
Fibrous filter and packaging media, 10 to 30 wt. %
Diatomaceous earth, 20 to 30 wt. %
Plastics, 5 to 25 wt. %
Chlorides, [###] to [###] wt. %
Metals and organics contained in liquid streams at
ppm levels
40 CFR 261 Appendix
VIII Constituents
[List Appendix VIII
Constituents and Their
Concentrations in the
Waste]
[List Appendix VIII
Constituents and Their
Concentrations in the
Waste]
[List Appendix VIII
Constituents and Their
Concentrations in the
Waste}
Quantity Burned
per Year
[Enter Quantity to
be Burned]
[Enter Quantity to
be Burned]
[Enter Quantity to
be Burned]
Waste Codes
F003,D001,
D004, D009,
D011
F003, F005,
D001,D004,
D005, D008,
D018
F003, F005,
D004, D005,
D008, D009,
D011,D018
B-3
-------
TABLE D-5.2 (Continued)
WASTE CHARACTERISTICS
Notes:
Btu
Btu/lb =
CFR
ppm
wt. % =
British thermal unit
British thermal unit per pound
Code of Federal Regulations
Parts per million
Weight percent
B-4
-------
ATTACHMENT B-3
TABLE D-5-3
TARGET TRIAL BURN OPERATING CONDITIONS
-------
TABLE D-5.3
TARGET TRIAL BURN OPERATING CONDITIONS
Parameter
Rotary kiln combustion zone temperature (°F)
SCC temperature (°F)
Solid hazardous waste feed rate to kiln (Ib/hr)
Liquid hazardous waste feed rate to kiln (Ib/hr)
Natural gas feed rate to kiln (cfh)
Total heat input to kiln (Btu/hr)
Liquid hazardous waste feed rate to SCC (Ib/hr)
Natural gas feed rate to SCC (cfh)
Total heat input to SCC (Btu/hr)
Total metals feed rates to kiln and SCC (Ib/hr)
Total chlorine feed rate to kiln and SCC (Ib/hr)
Total ash feed rate to kiln and SCC (Ib/hr)
Boiler inlet temperature (°F)
Combustion gas stack velocity (ft/sec or cfm)
Vane separator liquid flow rate (gpm)
Venturi scrubber differential pressure (inches of
water column)
Venturi scrubber pH
Venturi liquid/gas ratio
Scrubber liquid blowdown rate (gpm)
WESP liquid flow rate (gpm)
WESP power input (kVA)
Stack gas excess oxygen (vol. %)
Stack gas carbon monoxide (ppm, corrected to
7% oxygen)
Testl
High Temperature
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Test 2
Low Temperature
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Test3
Risk Burn
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
B-5
-------
TABLE D-5.3 (Continued)
TARGET TRIAL BURN OPERATING CONDITIONS
Notes:
Btu/hr = British thermal units per hour
cfh = Cubic feet per hour
cfm = Cubic feet per minute
ft/sec = Feet per second
gpm = Gallons per minute
kVA = Kilovolt amperes
Ib/hr = Pounds per hour
ppm = Parts per million
SCC = Secondary combustion chamber
vol. % = Volume percent
WESP = Wet electrostatic precipitator
B-6
-------
ATTACHMENT B-4
TABLE D-5.4
SUMMARY OF SAMPLING AND ANALYSIS PROGRAM
-------
TABLE D-5.4
SUMMARY OF SAMPLING AND ANALYSIS PROGRAM
Sample No./Type
1 /Solid waste feed
2/High-Btu Liquid
Waste
Parameters
Metals
Ash
Chlorine and hydrogen chloride
Organics
Heat value
Elemental analysis
Density
Metals
Ash
Chlorine and hydrogen chloride
Organics
Heat value
Elemental analysis
Density
Viscosity
Sampling Method
Grab, 250 mL, collected
at each sample interval
(One composite
prepared for each run.)
Grab, 250 mL, collected
at each sample interval
(One composite
prepared for each run.)
Sample Frequency
Every 15 minutes;
each run; test
conditions 1, 2, and
3
Every 15 minutes;
each run; test
conditions 1, 2, and
3
Field QA/QC Samples
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
Analytical Methods
ICP, SW-3050/3051, 6010/6020
Mercury by CVAA (SW-7470/7471)
ASTM D-482
ASTM D-808, E-442, D-4327-88
Volatile POHCs by SW-8260, semivolatile
POHCs by SW-3550 and -8270
ASTM D-2015, D-2382, D-240
ASTM D-3 176
ASTM D-70/D-854
ICP, SW-3050/3051, 6010/6020
Mercury by CVAA (SW-7470/7471
ASTM D-482
ASTM D-808, E-442, D-4327-88
Volatile POHCs by SW-8260, semivolatile
POHCs by SW-3550 and -8270
ASTM D-2015, D-2382, D-240
ASTM D-3 176
ASTMD-70/D-891
ASTM D-445
B-7
-------
TABLE D-5.4 (Continued)
SUMMARY OF SAMPLING AND ANALYSIS PROGRAM
Sample No./Type
3/Low-Btu Liquid
Waste
4/Stack gas metals -
MMT
5/Stack gas hexavalent
chromium sampling
train
6/Stack gas hydrogen
chloride, chlorine, and
particulate matter -
M0050 sampling train
Parameters
Metals
Ash
Chlorine and hydrogen chloride
Organics
Heat value
Elemental analysis
Density
Viscosity
Ag, As, Ba, Be, Cd, Cr, Hg, Ni,
Pb, Sb, Se, Tl
Hexavalent chromium
Hydrogen chloride and chlorine
Particulate matter
Sampling Method
Grab, 250 mL, collected
at each sample interval
(One composite
prepared for each run.)
Method 0060, MMT,
isokinetic sample
Method 006 l,Cr+6
sampling train, isokinetic
sample
Method 0050, isokinetic
sample
Sample Frequency
Every 15 minutes;
each run; test
conditions 1, 2, and
3
180 minutes, each
run; test conditions
1 and 3
180 minutes, each
run; test conditions
1 and 3
180 minutes, each
run; test conditions
1,2, and 3
Field QA/QC Samples
None
None
None
None
None
None
None
None
Reagent blanks (filter,
probe rinse solution)
Reagent blank (KOH
impinger solution)
Reagent blanks (H2SO4
and NaOH impinger
solutions)
None
Analytical Methods
ICP (SW-3050/3051, 6010/6020)
Mercury by CVAA (S W-7470/747 1
ASTM D-482
ASTM D-808, E-442, D-4327-88
Volatile POHCs by SW-8260, semivolatile
POHCs by SW-3550 and -8270
ASTM D-2015, D-2382, D-240
ASTM D-3 176
ASTM D-70/D- 1429
ASTM D-445
Digestion, ICP (SW-0060, 6010/6020)
Mercury by CVAA (SW-7470)
IC/PCR (Method 2 18.6, SW-0061)
Ion chromatography (SW-9056/9057)
Gravimteric
-------
TABLE D-5.4 (Continued)
SUMMARY OF SAMPLING AND ANALYSIS PROGRAM
Sample No./Type
7/Stack gas particulate
size distribution
8a/Stack gas volatile
organics (speciated) -
VOST
8b/Stack gas volatile
organics
(unspeciated) - M0040
Parameters
Particle size distribution
Volatile organics
Volatile organics
Sampling Method
Anderson cascade
impactor
Method 0031, VOST
train, 4 tube pairs
Method 0040, Tedlar™
bag sample
Sample Frequency
120 minutes; each
run; test condition 3
160 minutes; each
run; test conditions
2 and 3
120 minutes; each
run ; test condition
3
Field QA/QC Samples
None
One condensate trip
blank
One pair VOST tube trip
blank
One set field blank tubes
(four pairs each) per test
condition
One set (four pairs)
VOST audit sample
Three field blanks
Two trip blanks
Three field spikes
1 train blank
Analytical Methods
Gravimetric
Purge and trap (SW-0031, 8260/5041)
On-site GC/FID
-------
TABLE D-5.4 (Continued)
SUMMARY OF SAMPLING AND ANALYSIS PROGRAM
Sample No./Type
Parameters
Sampling Method
Sample Frequency
Field QA/QC Samples
Analytical Methods
10/Stackgas
semivolatiles
(speciated),
PCDDs/PCDFs -
MM5A
Semivolatile organics (Test 2
and 3), PCDDs/PCDFs (Test 3)
Combined Method
0010/0023 A
240 minutes; each
run; test conditions
2 and 3
One field blank per test
condition
One train blank per test
condition
One trip blank resin tube
One deionized water
reagent blank
Soxhlet extraction, GC/MS (semivolatiles by
SW-3542, 3540, 8270, PCDDs/PCDFs by SW-
8290, 0023A)
11/Stack gas
semivolatiles (total) -
MM5B
Semivolatile and nonvolatile
organics (unspeciated)
Method 0010
240 minutes; each
run; test condition 3
One field blank per test
condition
One train blank per test
condition
One trip blank resin tube
One deionized water
reagent blank
Semivolatiles
Front-half Soxhlet extraction, GC/FID
(SW-3540, 8015)
Back-half liquid-liquid extraction, GC/MS
(SW-3510, 8015)
Nonvolatile s
Front-half Soxhlet extraction, Gravimetric
(SW-3540/EPA 160.3)
Back-half liquid-liquid extraction, Gravimetric
(SW-3510/EPA 160.3)
B-10
-------
TABLE D-5.4 (Continued)
SUMMARY OF SAMPLING AND ANALYSIS PROGRAM
Sample No./Type
12/StackgasPAHs
13/Stack gas aldehyde
and ketone - MO 1 1
14/Incinerator ash
15/Scrubber
blowdown
16/Process water
Parameters
PAHs
Aldehyde and ketone PICs
volatile organic s
semivolatile organics
TDS/TSS
volatile organics
organics
metals
volatile organics
organics
Sampling Method
Method 00 10
Method 00 11
Grab, 100 grams
Grab, 250 mL, collected
at each sample interval
(One composite
prepared for each run.)
Grab, 250 mL, collected
at each sample interval
(One composite
prepared for each run.)
Sample Frequency
240 minutes; each
run; test condition 3
120 minutes; each
run; test condition 3
Once per run, test
conditions 1, 2, and
3
Every 15 minutes
during each run;
test conditions 1,2,
and 3
Every 15 minutes
during each run;
test conditions 1,2,
and 3
Field QA/QC Samples
One field blank per test
condition
One train blank per test
condition
One trip blank resin tube
Reagent blanks (DNPH
impinger solution,
methylene chloride,
deionized water)
None
None
None
None
None
None
None
None
Analytical Methods
Front-half Soxhlet extraction, GC/MS
(SW-3540, 8290, GARB 429)
Back-half Soxhlet extraction, GC/MS
(SW-3540, 8290, GARB 429)
Impinger composite liquid-liquid extraction,
GC/MS (SW-3510, 8290, GARB 429)
SW-846 Method 83 15, SW-001 1
Purge and trap, GC/MS (SW-8260)
Sonication, extraction, GC/MS (SW-3550,
8270)
Gravimetric (EPA 600- Method 160)
Purge and trap, GC/MS (SW-8260)
Liquid-liquid extraction, GC/MS (SW-3510,
8270)
ICP(SW-60 10/6020)
Purge and trap, GC/MS (SW-8260)
Liquid-liquid extraction, GC/MS (SW-3510,
8270)
B-ll
-------
TABLE D-5.4 (Continued)
SUMMARY OF SAMPLING AND ANALYSIS PROGRAM
Sample No./Type
17/Caustic
1 8/Stack gas carbon
monoxide and oxygen
Parameters
volatile organic s
semivolatile organics
carbon monoxide
oxygen
Sampling Method
Grab, 250 mL, collected
at each sample interval
(One composite
prepared for each run.)
Continuous, extractive
Continuous, extractive
Sample Frequency
Every 15 minutes
during each run;
test conditions 1,2,
and 3
Continuous during
each run; test
conditions 1, 2, and
3
Continuous during
each run; test
conditions 1, 2, and
3
Field QA/QC Samples
None
None
None
None
Analytical Methods
Purge and trap, GC/MS (SW-8260)
Liquid-liquid extraction, GC/MS (SW-3510,
8270)
NDIR
Paramagnetic
Notes:
Ag
As
ASTM
Ba
Be
Btu
CVAA
Cd
Cr
Cr+6
DNPH
GC/MS
GC/FID
Silver
Arsenic
American Society for Testing and Materials
Barium
Beryllium
British thermal units
Cold vapor atomic absorption
Cadmium
Chromium
Hexavalent chromium
2,4 -dinitropheny Ihy drazine
Gas chromatography and mass spectroscopy
Gas chromatography and flame ionization detector
B-12
-------
TABLE D-5.4 (Continued)
SUMMARY OF SAMPLING AND ANALYSIS PROGRAM
Hg = Mercury
H2S04 = Sulfuric acid
ICP = Inductively coupled argon plasma spectroscopy
IC/PCR = Ion chromatography with a post-column reactor
KOH = Potassium hydroxide
mL = Milliliter
MOO 11 = EPA Method 0011
M0040 = EPA Method 0040
M0050 = EPA Method 0050
MM5 = Modified Method 5
MMT = Multi-metals train
NaOH = Sodium hydroxide
NDIR = Nondispersive infrared
Ni = Nickel
PAH = Polynuclear aromatic hydrocarbon
Pb = Lead
PCDD = Dioxin
PCDF = Furan
PIC = Products of incomplete combustion
POHC = Principal organic hazardous constituents
QA/QC = Quality assurance and quality control
Sb = Antimony
Se = Selenium
TDS = Total dissolved solids
TSS = Total suspended solids
Tl = Thallium
VOST = Volatile organic sampling train
B-13
-------
ATTACHMENT B-5
TABLE D-5.5
ANTICIPATED INCINERATOR OPERATING LIMITS
-------
TABLE D-5.5
ANTICIPATED INCINERATOR OPERATING LIMITS
Parameters
Value
Basis
Group A
Maximum solid hazardous waste
feed rate to kiln
Maximum high-Btu liquid
hazardous waste feed rate to kiln
Maximum low-Btu liquid hazardous
waste feed rate to kiln
Maximum high-Btu liquid
hazardous waste feed rate to SCC
Maximum low-Btu liquid hazardous
waste feed rate to SCC
Minimum rotary kiln temperature
Maximum rotary kiln temperature
Maximum SCC temperature
Minimum SCC temperature
Maximum combustion gas velocity
Maximum boiler inlet temperature
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] °F, hourly rolling average
[###] °F, hourly rolling average
[###] °F, hourly rolling average
[###] °F, hourly rolling average
[###] cfm, hourly rolling average
[###] °F, hourly rolling average
Mean of the highest hourly rolling
average waste feed rates recorded
during each run of Test 2
Mean of the highest hourly rolling
average waste feed rates recorded
during each run of Test 2
Mean of the highest hourly rolling
average waste feed rates recorded
during each run of Test 2
Mean of the highest hourly rolling
average waste feed rates recorded
during each run of Test 2
Mean of the highest hourly rolling
average waste feed rates recorded
during each run of Test 2
Mean of the lowest hourly rolling
average combustion zone
temperatures measured during the
three runs in Test 2
Mean of the highest hourly rolling
average combustion zone
temperatures measured during the
three runs in Test 1
Mean of the highest hourly rolling
average SCC temperatures measured
during the three runs in Test 1
Mean of the lowest hourly rolling
average SCC temperatures measured
during the three runs in Test 2
Mean of the highest hourly rolling
average combustion gas velocities
measured during each run of Test 2
Mean of highest hourly rolling
average temperatures measured
during each run of Test 3
B-14
-------
TABLE D-5.5 (Continued)
ANTICIPATED INCINERATOR OPERATING LIMITS
Parameters
Minimum vane separator process
water flow rate
Minimum venturi scrubber
differential pressure
Minimum venturi scrubber liquid to
gas ratio
Minimum venturi scrubber recycle
pH
Minimum scrubber blowdown flow
rate
Minimum WESP power input
Minimum WESP liquid flow rate
Maximum carbon monoxide
concentration in the stack
Minimum oxygen concentration in
the stack
Value
[###] gpm, hourly rolling average
[###] inches water column, hourly
rolling average
[#:#] hourly rolling average
[###] pH, hourly rolling average
[###] gpm
[###] kVA, hourly rolling average
[###] gpm
[###] ppm at 7 % oxygen, dry basis,
hourly rolling average
[###] vol. %, dry basis, hourly
rolling average
Basis
Mean of the lowest hourly rolling
average differential pressures
recorded during each of the six runs
of the Tests 1 and 2
Mean of the lowest hourly rolling
average differential pressures
recorded during each of the six runs
of the Tests 1 and 2
Mean of the lowest hourly rolling
average liquid to gas ratios recorded
during each of the six runs of Tests 1
and 2
Mean of the lowest hourly rolling
average pH recorded during each of
the six runs of the Tests 1 and 2
Mean of the lowest hourly rolling
average flow rates recorded during
each of the six runs of Tests 1 and 2
Mean of the lowest hourly rolling
average kVA recorded during each of
the six runs of the Tests 1 and 2
Mean of the lowest hourly rolling
average flow rates recorded during
each of the six runs of Tests 1 and 2
Statutory limit
Mean of the lowest hourly rolling
average oxygen recorded during each
of the three runs under Test 2
Group B
Maximum antimony feed rate
Maximum total arsenic feed rate
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
Tier I limit
Mean of the highest hourly rolling
average feed rates measured during
the three runs of Test 1
B-15
-------
TABLE D-5.5 (Continued)
ANTICIPATED INCINERATOR OPERATING LIMITS
Parameters
Maximum pumpable arsenic feed
rate
Maximum barium feed rate
Maximum beryllium feed rate
Maximum pumpable beryllium feed
rate
Maximum cadmium feed rate
Maximum pumpable cadmium feed
rate
Maximum chromium feed rate
Maximum pumpable chromium feed
rate
Maximum lead feed rate
Maximum mercury feed rate
Maximum selenium feed rate
Maximum silver feed rate
Maximum thallium feed rate
Maximum chlorine feed rate
Value
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
[###] pounds per hour, hourly
rolling average
Basis
Mean of the highest hourly rolling
average feed rates measured during
the three runs of Test 1
Tier I limit
Mean of the highest hourly rolling
average feed rates measured during
the three runs of Test 1
Mean of the highest hourly rolling
average feed rates measured during
the three runs of Test 1
Mean of the highest hourly rolling
average feed rates measured during
the three runs of Test 1
Mean of the highest hourly rolling
average feed rates measured during
the three runs of Test 1
Mean of the highest hourly rolling
average feed rates measured during
the three runs of Test 1
Mean of the highest hourly rolling
average feed rates measured during
the three runs of Test 1
Tier I limit
Tier I limit
Tier I limit
Tier I limit
Tier I limit
Mean of the highest hourly rolling
average feed rates measured during
the six runs of Tests 1 and 2
B-16
-------
TABLE D-5.5 (Continued)
ANTICIPATED INCINERATOR OPERATING LIMITS
Parameters
POHC DRE
Maximum participate matter
emissions
Maximum ash content of waste
Maximum emissions of chlorine and
hydrogen chloride
Maximum dioxin and furan
emissions
Maximum annual average solids
waste feed rate
Maximum annual average low-Btu
liquids feed rate
Maximum annual average high-Btu
liquids feed rate
Minimum annual average rotary kiln
temperature
Maximum annual average rotary
kiln temperature
Maximum annual average SCC
temperature
Minimum annual average SCC
temperature
Maximum annual average
combustion gas flow rate
Value
99.99 %
0.08 gr/dscf
[###] %, hourly rolling average
41bs/hr
0.20 ng/dscm TEQ
[###] tph
[###] Ib/hr
[###] Ib/hr
[###] °F
[###] °F
[###] °F
[###] °F
[###] acfm
Basis
Statutory requirement
Statutory limit
Mean of the ash contents measured
during the six runs under Tests 1 and
2
Statutory limit
Proposed standard
Mean of run-average feed rates in
three runs under Test 3
Mean of run-average feed rates in
three runs under Test 3
Mean of run-average feed rates in
three runs under Test 3
Mean of the lowest hourly rolling
average temperatures recorded during
the three runs under Test 3
Mean of the highest hourly rolling
average temperatures recorded during
the three runs under Test 3
Mean of the highest hourly rolling
average temperatures recorded during
the three runs under Test 3
Mean of the lowest hourly rolling
average temperatures recorded during
the three runs under Test 3
Mean of highest hourly rolling
average flow rates recorded during
the three runs under Test 3
Group C
CEM system operation
The CEM system must be operating
whenever hazardous wastes are
being fed to the kiln or SCC
Regulatory requirement
B-17
-------
TABLE D-5.5 (Continued)
ANTICIPATED INCINERATOR OPERATING LIMITS
Parameters
Maximum rotary kiln pressure
Maximum quench exit temperature
Minimum heating value
Maximum liquid waste viscosity
Maximum thermal input to kiln
Maximum thermal input to SCC
Maximum solids content of liquid
wastes
Maximum burner turndown
Minimum venturi scrubber nozzle
pressure
Minimum WESP nozzle pressure
Minimum differential pressure
between atomizing steam and
high-Btu liquid waste
Minimum differential pressure
between atomizing air and low-Btu
liquid waste
Value
[###] inches of water column
vacuum, instantaneous limit
[###] °F, instantaneous limit
(interlocked with AWFCO)
[###] Btu per pound
[###] centipoise
[###] million Btu/hr
[###] million Btu/hr
[###] % solids
[#:#]
[###] psig
[###] psig
[###] psig, instantaneous limit
(interlocked with AWFCO)
[###] psig, instantaneous limit
(interlocked with AWFCO)
Basis
Mean of the highest hourly rolling
average kiln pressures recorded
during each of the nine runs of the
trial burn
Manufacturer's recommendations
Calculated on the basis of heat
balance
Manufacturer's recommendations
Manufacturer's recommendations
Manufacturer's recommendations
Manufacturer's recommendations
Manufacturer's recommendations
Manufacturer's recommendations
Manufacturer's recommendations
Manufacturer's recommendations
Manufacturer's recommendations
B-18
-------
TABLE D-5.5 (Continued)
ANTICIPATED INCINERATOR OPERATING LIMITS
Parameters Value
Notes:
acfm = Actual cubic feet per minute
AWFCO = Automatic waste feed cutoff
Btu = British thermal unit
DRE = Destruction and removal efficiency
gpm = Gallons per minute
gr/dscf = Grains per dry standard cubic foot
kVA = Kilovolt amperes
Ibs/hour = Pounds per hour
ng/dscm = Nanograms per dry standard cubic meter
POHC = Principal organic hazardous constituent
ppm = Parts per million
psig = Pounds per square inch gauge
SCC = Secondary combustion chamber
TEQ = Toxicity-equivalent quality
vol. % = Volume percent
WESP = Wet electrostatic precipitator
Basis
B-19
-------
ATTACHMENT B-6
TABLE D-5.6
AUTOMATIC WASTE FEED CUTOFF SYSTEM SETTINGS STARTUP
AND SHAKEDOWN PERIOD
-------
TABLE 5-6
AUTOMATIC WASTE FEED CUTOFF SYSTEM SETTINGS
STARTUP AND SHAKEDOWN PERIOD
Parameter
Maximum solids waste feed rate to kiln (hourly rolling average)
Maximum high-Btu liquids waste feed rate to kiln (hourly rolling average)
Maximum low-Btu liquids waste feed rate to kiln (hourly rolling average)
Maximum high-Btu liquids waste feed rate to SCC (hourly rolling average)
Maximum low-Btu liquids waste feed rate to SCC (hourly rolling average)
Minimum rotary kiln combustion zone temperature (hourly rolling average)
Maximum rotary kiln combustion zone temperature (hourly rolling average)
Minimum SCC temperature (hourly rolling average)
Maximum SCC temperature (hourly rolling average)
Maximum combustion gas velocity (hourly rolling average)
Maximum heat recovery boiler inlet temperature
Minimum vane separator water flow rate (hourly rolling average)
Minimum venturi scrubber liquid to gas ratio (hourly rolling average)
Minimum venturi scrubber differential pressure (hourly rolling average)
Minimum venturi scrubber liquid pH (hourly rolling average)
Minimum scrubber blowdown flow rate (hourly rolling average)
Minimum WESP liquid flow rate (hourly rolling average)
Minimum WESP power input (hourly rolling average)
Maximum rotary kiln pressure (instantaneous)
Maximum carbon monoxide in stack gas (hourly rolling average)
Minimum oxygen in stack gas (hourly rolling average)
Maximum quench tower exit temperature (hourly rolling average)
Minimum differential pressure between atomizing gas atomization and liquid
waste fuel feed (hourly rolling average)
Setting
[###] tph
[###] Ib/hr
[###] Ib/hr
[###] Ib/hr
[###] Ib/hr
[###] °F
[###] °F
[###] °F
[###] °F
[###] cfm or ft/sec
[###] °F
[###] gpm
[#:#]
[###] inches of water column
[###] standard units
[###] gpm
[###] gpm
[###] kVA
[###] inches of water column
vacuum
[###] ppm, dry basis, at 7 %
oxygen
[###] vol. %, dry basis
[###] °F
[###] psig
B-19
-------
Notes:
Btu
cfm
CO
ft/sec
gpm
kVA
Ib/hr
ppm
psig
SCC
tph
TRV
vol. %
WESP
TABLE 5-6 (Continued)
AUTOMATIC WASTE FEED CUTOFF SYSTEM SETTINGS
START-UP AND SHAKEDOWN PERIOD
Parameter
Flameout
TRV opening
Setting
Immediately upon detection
Immediately upon detection
British thermal unit
Cubic feet per minute
Carbon monoxide
Feet per second
Gallons per minute
Kilovolt amperes
Pounds per hour
Parts per million
Pounds per square inch gauge
Secondary combustion chamber
Tons per hour
Thermal relief vent
Volume percent
Wet electrostatic precipitator
B-20
-------
ATTACHMENT B-7
TABLE D-5.7
DESIGN BASIS, MAJOR SYSTEMS
-------
TABLE D-5.7
DESIGN BASIS, MAJOR SYSTEMS
System
Purpose
Design Basis
Rotary kiln
Volatilization and combustion of organic constituents of
hazardous waste feed streams
Length: [###] feet
Diameter: [###] feet
Installed slope: [###] feet per feet
Maximum thermal input: [###] Btu/hr
Maximum solid waste feed rate: [###] tons per hour
Design combustion gas residence time: [###] seconds
Secondary combustion chamber
Destruction of organic vapors
Width: [###]feet
Height: [###] feet
Length: [###] feet
Maximum thermal input: [###] Btu/hr
Design combustion gas flow rate: [###] acfm
Design combustion gas residence time: [###] seconds
Design combustion gas inlet temperature: [###] °F
Design combustion gas exit temperature: [###] °F
Heat recovery boiler
Recovery of waste heat from combustion gases via the
production of steam
Design steam generating capacity: [###] Ib/hr
Design steam pressure: [###] psig
Design steam temperature: [###] °F
Design gas flow rate: [###] acfm
Design gas inlet temperature: [###] °F
ASME Boiler and Pressure Vessel Code, Section VIII
Quench tower
Rapid reduction of combustion gas temperature and
saturation of combustion gases
Height: [###] feet
Diameter: [###] feet
Adiabatic cooling capacity: [###] Btu/hr
Design inlet gas flow rate: [###] acfm
Design inlet gas temperature: [###] °F
B-21
-------
TABLE D-5.7 (Continued)
DESIGN BASIS, MAJOR SYSTEMS
System
Venturi scrubber and vane separator
Wet electrostatic precipitator
Induced draft fan
Process exhaust stack
Purpose
Control of emissions of particulate matter and acid
gases
Control of particulate emissions
Primary mover of combustion gases
Atmospheric dispersion of process exhaust gases
Design Basis
Gas volume: [###] acfm
Particle loading: [###] grains per cubic foot
Particle-size distribution: [###] to [###] microns
Particle removal efficiency: [###] %
Acid gas removal efficiency: [###] %
Gas volume: [###] acfm
Particle loading: [###] grains per cubic foot
Particle-size distribution: [###] to [###] microns
Particle removal efficiency: [###] %
Design capacity: [acfm] at [###] °F and [###] inches of
water column discharge head
Design gas flow rate: [###] acfm
Design gas temperature: [###] °F
Stack height (to tip): [###] feet
Stack diameter (at tip): [###] feet
Stack diameter (at gas inlet): [###] feet
Notes:
ASME =
acfm =
Btu/hr =
cfm =
psig
American Society for Testing and Materials
Actual cubic feet per minute
British thermal units per hour
Cubic feet per minute
Pounds per square inch gauge
B-22
-------
ATTACHMENT B-8
TABLE D-5.8
INCINERATOR FEED SYSTEMS DESIGN INFORMATION
-------
TABLE D-5.8
INCINERATOR FEED SYSTEMS DESIGN INFORMATION
Type
Solid waste
High-Btu
liquid waste
Low-Btu
liquid waste
Capacity
[###] cubic yard
hopper, [###] tph
auger-shredder
[###] Ib/hr
[###] Ib/hr
Maximum
Specific
Gravity
[###]
[###]
[###]
Maximum
Viscosity
—
[###] centipoise
[###] centipoise
Maximum Ash
Content (%)
—
[###]
[###]
Maximum
Particle Size
[###] inches
[###] microns
[###] microns
Maximum
Moisture
Content (%)
[###]
[###]
[###]
Heat Value
(Btu/lb)
[###] to [###]
[###] to [###]
[###] to [###]
Notes:
Btu
Btu/lb =
Ib/hr
tph
British thermal units
British thermal units per pound
Pounds per hour
Tons per hour
Not applicable
B-23
-------
ATTACHMENT B-9
TABLE D-5.9
AUTOMATIC WASTE FEED CUTOFF PARAMETERS, INSTRUMENTS, AND SETTINGS
-------
TABLE D-5.9
AUTOMATIC WASTE FEED CUTOFF PARAMETERS,
INSTRUMENTS, AND SETTINGS
Parameter
High rotary kiln combustion zone temperature
Low rotary kiln combustion zone temperature
High SCC temperature
Low SCC temperature
High solids waste feed rate
High high-Btu liquid waste feed to kiln
High high-Btu waste feed to SCC
High low-Btu liquid waste feed to kiln
High low-Btu waste feed to SCC
Minimum differential pressure between atomizing
steam and high-Btu liquid wastes
Minimum differential pressure between atomizing
air and low-Btu liquid wastes
High stack gas carbon monoxide
Low stack gas oxygen
High combustion gas velocity
High boiler inlet gas temperature
High rotary kiln pressure
Instrument Tag No.
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Cutoff
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Type
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Make and Model
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Range
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Accuracy
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
B-24
-------
TABLE D-5.9 (Continued)
AUTOMATIC WASTE FEED CUTOFF PARAMETERS
INSTRUMENTS AND SETTINGS
Parameter
High quench tower outlet temperature
Low venturi liquid to gas ratio
Low venturi scrubber differential pressure
Low venturi scrubber pH
Low vane separator water flow
Low scrubber blowdown flow rate
Low WESP liquid flow rate
Low WESP power input
Flameout
TRY Opening
Instrument Tag No.
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Cutoff
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Type
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Make and Model
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Range
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Accuracy
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
[###]
Notes:
Btu
SCC
TRY
WESP =
British thermal unit
Secondary combustion chamber
Thermal relief unit
Wet electrostatic precipitator
B-25
-------
ATTACHMENT B-10
TABLE D-5.10
CONSTRUCTION MATERIALS
-------
TABLE D-5.10
CONSTRUCTION MATERIALS
Component
Solids hopper
Solids shredder-auger system
Rotary kiln
High-temperature ducting
Secondary combustion chamber
Heat recovery boiler
Quench
Quench sump, induced draft fan housing, all other
APCS equipment, and stack
Venturi scrubber and vane separator
WESP
Induced draft fan wheel, wetted metal parts in
scrubbers
Construction Materials
[Enter Materials of Construction]
[Enter Materials of Construction of Shredder, Feed
Screw, and Housing]
[Enter Construction Materials and Thicknesses of
Shell and Refractory]
[Enter Construction Materials and Thicknesses of
Shell and Refractory]
[Enter Construction Materials and Thicknesses of
Shell and Refractory]
[Enter Construction Materials and Thicknesses of
Shell and Internals]
[Enter Construction Materials and Thicknesses of
Shell and Internals]
[Enter Construction Materials and Thicknesses of
Shell and Internals]
[Enter Construction Materials and Thicknesses of
Shell and Internals]
[Enter Construction Materials and Thicknesses of
Shell and Internals]
[Enter Construction Materials and Thicknesses of
Shell and Internals]
Notes:
APCS = Air pollution control system
WESP = Wet electrostatic precipitator
B-26
-------
ATTACHMENT B-ll
TABLE D-5.11
PROCESS MONITORING INSTRUMENTS
-------
TABLE D-5.11
PROCESS MONITORING INSTRUMENTS
Parameter
Solid waste feed
rate
High-Btu liquid
waste feed rate
Low-Btu liquid
waste feed rate
Rotary kiln
pressure
Rotary kiln
combustion gas
temperature
SCC temperature
SCC excess oxygen
Heat recovery
boiler inlet
temperature
Location
Solid waste
feed auger
Rotary kiln
burner system
SCC burner
system
Rotary kiln
burner system
SCC burner
system
Rotary kiln
Rotary kiln
SCC exit
plenum
SCC exit
plenum
Inlet plenum
Instrument
Number(s)
SS[###]
FE[###]
FE[###]
FE[###]
FE[###]
PIT[###]
and
PIT[###]
TT[###]
TT[###]
AIT[###]
TT[###]
Type of
Instrument
Speed sensor
Micromotion
Micromotion
Micromotion
Micromotion
Pressure
transmitter
TypeK
thermocouple
TypeK
thermocouple
Extractive
paramagnetic
type
TypeK
thermocouple
Instrument Range
[###] to [###] rpm
0 to [###] Ib/mm
0 to [###] Ib/mm
0 to [###] Ib/mm
0 to [###] Ib/mm
-5 to +5 inches of
water
0 to 2000 °F
0 to 2500 °F
0 to 25 % dry
0 to 2000 °F
Expected Operating
Range
[###] to [###] rpm
[###] to [###] Ib/mm
[###] to [###] Ib/mm
[###] to [###] Ib/mm
[###] to [###] Ib/mm
[###] to [###] inches
of water
[###] to [###] °F
[###] to [###] °F
[###] to [###]%
[###] to [###] °F
Accuracy
+/. [###] %FS
+/-[###] %FS
+/-[###] %FS
+/-[###] %FS
+/-[###] %FS
+/-0.5 %FS
+/- 1.8 °F
+/- 1.8 °F
+/- 1 %FS
+/- 1.8 °F
Alarm Conditions
High: [###] Ib/hr,
High-high: [###] Ib/hr
High: [###] Ib/hr,
High-high: [###] Ib/hr
High: [###] Ib/hr,
High-high: [###] Ib/hr
High: [###] Ib/hr,
High-high: [###] Ib/hr
High: [###] Ib/hr,
High-high: [###] Ib/hr
High: [###] inches of water vacuum
High-high: [###] inches of water
vacuum
High: [###] °F,
High-high: [###] °F
Low: [###] °F,
Low-low: [###] °F
Low: [###] %,
Low-low: [###]%
High: [###] °F,
High-high: [###] °F
B-27
-------
TABLE D-5.11 (Continued)
PROCESS MONITORING INSTRUMENTS
Parameter
Quench tower
outlet gas
temperature
Venturi scrubber
liquid flow
Venturi scrubber
differential
pressure
Venturi scrubber
pH
Scrubber
blowdown flow
WESP liquid flow
WESP power input
Stack gas oxygen
Stack gas carbon
monoxide
Location
Quench outlet
Venturi liquid
inlet
Across venturi
scrubber
Venturi
scrubber sump
Venturi liquid
inlet
Venturi liquid
inlet
Power feed
Stack
Stack
Instrument
Number(s)
TT[###]
FE[###]
PIT[###]
AR[###]
FE[###]
FE[###]
EI[###],
!![###]
AIT[###]
AIT[###]
Type of
Instrument
TypeK
thermocouple
Foxboro
mass flow
meter
Differential
pressure
transmitter
Electrometric
pH
Foxboro
mass flow
meter
Foxboro
mass flow
meter
Voltmeter,
ammeter
Extractive
paramagnetic
type
NDIR type
Instrument Range
0 to 1000 °F
0 to [###] gpm
[###] to [###]
inches of water
[###] to [###]
standard units
0 to [###] gpm
0 to [###] gpm
[###] to [###]kVA
0 to 25 % dry
dual range: 0 to
200 ppmv (dry) / 0
to 3000 ppmv (dry)
Expected Operating
Range
[###] to [###] °F
[###] to [###] gpm
[###] to [###] inches
of water
[###] to [###]
standard units
[###] to [###] gpm
[###] to [###] gpm
[###] to [###] kVA
[###] to [###] %
[###] to [###] ppmv
(dry)
Accuracy
+/- 1.8 °F
+/-[###] %FS
+/-0.5 %FS
+/-0.1
standard units
+/-[###] %FS
+/-[###] %FS
+/-0.1%FS
+/- 1 %FS
+/-1 %FS
Alarm Conditions
High: [###] °F,
High-high: [###] °F
Low: [###]gpm,
Low-low: [###] gpm
Low: [###] inches of water,
Low-low: [###] inches of water
Low: [###],
Low-low: [###]
Low: [###]gpm,
Low-low: [###] gpm
Low: [###]gpm,
Low-low: [###] gpm
Low: [###]kVA,
Low-low: [###]kVA
Low: [###] %,
Low-low: [###]%
High: [###]ppm,
High-high: [###] ppm
B-28
-------
TABLE D-5.11 (Continued)
PROCESS MONITORING INSTRUMENTS
Parameter
Stack gas flow rate
Location
Stack
Instrument
Number(s)
FE[###]
Type of
Instrument
Annubar
Instrument Range
[###] to [###] acfm
Expected Operating
Range
[###] to [###] acfm
Accuracy
+/-1 %FS
Alarm Conditions
High: [###]acfm,
High-high: [###] acfm
Notes:
acfm
AIT
AR
Btu
El
FE
FS
gpm
II
kVA
Ib/hr
Ib/min
NDIR
PIT
ppmv
rpm
SCC
SS
TT
WESP
Actual cubic feet per minute
Attribute indicator transmitter
= Attribute recorder
= British thermal unit
= Element indicator
= Flow element
Full scale
Gallons per minute
Amperage Indicator
Kilovolt amperes
= Pounds per hour
= Pounds per minute
= Nondispersive infrared
= Pressure indicator transmitter
Parts per million by volume
Revolutions per minute
Secondary combustion chamber
Speed sensor
Temperature transmitter
Wet electrostatic precipitator
B-29
-------
ATTACHMENT B-12
TABLE D-5.12
PROCESS MONITORING INSTRUMENTS, CALIBRATION, AND PREVENTIVE
MAINTENANCE
-------
TABLE D-5.12
PROCESS MONITORING INSTRUMENTS, CALIBRATION,
AND PREVENTIVE MAINTENANCE
Parameter
Solid waste feed rate
High-Btu liquid waste feed rate
Low-Btu liquid waste feed rate
Rotary kiln pressure
Rotary kiln combustion gas
temperature
SCC temperature
SCC excess oxygen
Boiler inlet temperature
Quench tower outlet gas
temperature
Venturi scrubber liquid flow
Venturi scrubber differential
pressure
Location
Solid waste feed auger
Rotary kiln burner
system
SCC burner system
Rotary kiln burner
system
SCC burner system
Rotary kiln burner
system
Rotary kiln
SCC exit plenum
SCC exit plenum
Boiler inlet plenum
Quench outlet
Venturi liquid inlet
Across venturi
scrubber
Instrument
Number(s)
SS[###]
FE[###]
FE[###]
FE[###]
FE[###]
PIT[###] and
PIT[###]
TT[###]
TT[###]
AIT[###]
TT[###]
TT[###]
FE[###]
PIT[###]
Calibration
Procedure
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
Calibration
Frequency
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
Preventive
Maintenance
Procedure
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
Preventive
Maintenance
Frequency
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
B-30
-------
TABLE D-5.12 (Continued)
PROCESS MONITORING INSTRUMENTS, CALIBRATION,
AND PREVENTIVE MAINTENANCE
Parameter
Venturi scrubber pH
Scrubber blowdown flow
WESP liquid flow
WESP power input
Stack gas oxygen
Stack gas carbon monoxide
Stack gas flow rate
Location
Venturi scrubber sump
Scrubber effluent line
WESP liquid inlet
Power feed
Stack
Stack
Stack
Instrument
Number(s)
AR[###]
FE[###]
FE[###]
El[###],
!![###]
AIT[###]
AIT[###]
FE[###]
Calibration
Procedure
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
Calibration
Frequency
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
Preventive
Maintenance
Procedure
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
[Enter Procedure]
Preventive
Maintenance
Frequency
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
[Enter Frequency]
Notes:
AIT = Attribute indicator transmitter
AR = Attribute recorder
Btu = British thermal unit
El = Element indicator
FE = Flow element
II = Amperage indicator
PIT = Pressure indicator transmitter
SCC = Secondary combustion chamber
SS = Speed sensor
TT = Temperature transmitter
WESP = Wet electrostatic precipitator
B-31
-------
ATTACHMENT B-13
TABLE D-5.13
TRIAL BURN SCHEDULE
-------
TABLE D-5.13
TRIAL BURN SCHEDULE
Day
1
2
3
4
4 (Cont.)
Test/
Run
—
1/1
1/2
1/3
1/3
(Cont.)
Activity
Set-up
Process stabilization
Multi-metals sampling
train - M0060
Hexavalent chromium
sampling train - MOO 1 3
PM, hydrogen
chloride, and chlorine
sampling train - M0050
Sample recovery
Process stabilization
Multi-metals sampling
train - M0060
Hexavalent chromium
sampling train - MOO 1 3
PM, hydrogen
chloride, and chlorine
sampling train - M0050
Sample recovery
Process stabilization
Multi-metals sampling
train - M0060
Hexavalent chromium
sampling train - MOO 1 3
Total Activity
Duration (minutes)
480
30
300
300
240
60
30
300
300
240
60
30
300
300
Start
Time
0800
0800
0900
0900
1300
1700
0800
0900
0900
1300
1700
0800
0900
0900
Finish
Time
1600
0900
1300
1300
1700
1800
0900
1300
1300
1700
1800
0900
1300
1300
Notes
—
60-minute stabilization on
hazardous waste feed
180 minutes for sampling,
60 minutes for port changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
180 minutes sampling, 60 minutes
for port changes and leak checks
-
60-minute stabilization on
hazardous waste feed
180 minutes for sampling,
60 minutes for port changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
-
60-minute stabilization on
hazardous waste feed
180 minutes for sampling,
60 minutes for port changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
B-32
-------
TABLE D-5.13 (Continued)
TRIAL BURN SCHEDULE
Day
5
6
7
Test/
Run
2/1
2/2
2/3
Activity
PM, Hydrogen
chloride, and chlorine
sampling train - M0050
Sample recovery
Process stabilization
Semivolatile POHC -
MOO 10
Volatile POHCs -
VOST
PM, hydrogen
chloride, and chlorine
sampling train - M0050
Sample recovery
Process stabilization
Semivolatile POHC -
MOO 10
Volatile POHCs -
VOST
PM, hydrogen
chloride, and chlorine
sampling train - M0050
Sample recovery
Process stabilization
Semivolatile POHC -
MOO 10
Total Activity
Duration (minutes)
240
60
30
240
200
240
60
30
240
200
240
60
30
240
Start
Time
1300
1700
0800
0900
0900
0930
1330
0800
0900
0900
0930
1330
0800
0900
Finish
Time
1700
1800
0900
1400
1220
1330
1430
0900
1400
1220
1330
1430
0900
1400
Notes
180 minutes for sampling,
60 minutes for port changes and
leak checks
-
60-minute stabilization on
hazardous waste feed
240 minutes for sampling,
60 minutes for port changes and
leak checks
160 minutes for sampling,
40 minutes for tube changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
-
60-minute stabilization on
hazardous waste feed
240 minutes for sampling,
60 minutes for port changes and
leak checks
160 minutes for sampling,
40 minutes for tube changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
-
60-minute stabilization on
hazardous waste feed
240 minutes for sampling,
60 minutes for port changes and
leak checks
B-33
-------
TABLE D-5.13 (Continued)
TRIAL BURN SCHEDULE
Day
8
8 (Cont.)
Test/
Run
3/1
3/1
(Cont.)
Activity
Volatile POHCs -
VOST
PM, hydrogen
chloride, and chlorine
sampling train - M0050
Sample recovery
Process stabilization
Multi-metals sampling
train - M0060
Hexavalent chromium
sampling train - MOO 1 3
Semivolatiles and
PCDD/PCDF sampling
train (speciated) -
MOO 10/0023 A
Semivolatiles sampling
train (unspeciated) -
MOO 10
PAH sampling train -
MOO 10
Aldehyde and ketone
sampling train - MOO 1 1
Volatile bag sampling
train - M0040
VOST
Total Activity
Duration (minutes)
200
240
60
60
300
300
240
240
240
180
150
200
Start
Time
0900
0930
1330
0800
0900
0900
0900
0900
1000
1000
1130
1130
Finish
Time
1220
1330
1430
0900
1300
1300
1400
1400
1500
1300
1400
1450
Notes
160 minutes for sampling,
40 minutes for tube changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
--
60-minute stabilization on
hazardous waste feed
180 minutes for sampling,
60 minutes for port changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
240 minutes for sampling,
60 minutes for port changes and
leak checks
240 minutes for sampling,
60 minutes for port changes and
leak checks
240 minutes for sampling,
60 minutes for port changes and
leak checks
120 minutes for sampling,
60 minutes for port changes and
leak checks
120 minutes for sampling,
30 minutes for leak checks
160 minutes for sampling,
40 minutes for tube changes and
leak checks
B-34
-------
TABLE D-5.13 (Continued)
TRIAL BURN SCHEDULE
Day
9
9 (Cont.)
Test/
Run
3/2
3/2
(Cont.)
Activity
PM, hydrogen
chloride, and chlorine
sampling train - M0050
Cascade impactor
Sample recovery
Process stabilization
Multi-metals sampling
train - M0060
Hexavalent chromium
sampling train - MOO 1 3
Semivolatiles and
PCDD/PCDF sampling
train (speciated) -
MOO 10/0023 A
Semivolatiles sampling
train (unspeciated) -
MOO 10
PAH sampling train -
MOO 10
Aldehyde and ketone
sampling train - MOO 1 1
Volatile bag sampling
train - M0040
VOST
PM, hydrogen
chlorine, and chlorine
sampling train - M0050
Total Activity
Duration (minutes)
300
120
60
60
300
300
240
240
240
180
150
200
300
Start
Time
1330
1330
1830
0800
0900
0900
0900
0900
1000
1000
1130
1130
1330
Finish
Time
1730
1530
1930
0900
1300
1300
1400
1400
1500
1300
1400
1450
1730
Notes
180 minutes for sampling,
60 minutes for port changes and
leak checks
120 minutes for sampling
--
60-minute stabilization on
hazardous waste feed
180 minutes for sampling,
60 minutes for port changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
240 minutes for sampling,
60 minutes for port changes and
leak checks
240 minutes for sampling,
60 minutes for port changes and
leak checks
240 minutes for sampling,
60 minutes for port changes and
leak checks
120 minutes for sampling,
60 minutes for port changes and
leak checks
120 minutes for sampling,
30 minutes for leak checks
160 minutes for sampling,
40 minutes for tube changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
B-35
-------
TABLE D-5.13 (Continued)
TRIAL BURN SCHEDULE
Day
10
10
(Cont.)
Test/
Run
3/3
3/3
(Cont.)
Activity
Cascade impactor
Sample recovery
Process stabilization
Multi-metals sampling
train - M0060
Hexavalent chromium
sampling train - MOO 1 3
Semivolatiles and
PCDD/PCDF sampling
train (speciated) -
MOO 10/0023 A
Semivolatiles sampling
train (unspeciated) -
MOO 10
PAH sampling train -
MOO 10
Aldehyde and ketone
sampling train - MOO 1 1
Volatile bag sampling
train - M0040
VOST
PM, hydrogen
chloride, and chlorine
sampling train - M0050
Cascade impactor
Sample recovery
Total Activity
Duration (minutes)
120
60
60
300
300
240
240
240
180
150
200
300
120
60
Start
Time
1330
1830
0800
0900
0900
0900
0900
1000
1000
1130
1130
1330
1330
1830
Finish
Time
1530
1930
0900
1300
1300
1400
1400
1500
1300
1400
1450
1730
1530
1930
Notes
120 minutes for sampling
--
60-minute stabilization on
hazardous waste feed
180 minutes for sampling,
60 minutes for port changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
240 minutes for sampling,
60 minutes for port changes and
leak checks
240 minutes for sampling,
60 minutes for port changes and
leak checks
240 minutes for sampling,
60 minutes for port changes and
leak checks
120 minutes for sampling,
60 minutes for port changes and
leak checks
120 minutes for sampling,
30 minutes for leak checks
160 minutes for sampling,
40 minutes for tube changes and
leak checks
180 minutes for sampling,
60 minutes for port changes and
leak checks
120 minutes for sampling
--
B-36
-------
TABLE D-5.13 (Continued)
TRIAL BURN SCHEDULE
Day
11
Test/
Run
-
Activity
Demobilization
Total Activity
Duration (minutes)
480
Start
Time
0800
Finish
Time
1600
Notes
-
Notes:
MOO 10
MOO 13
M0050
M0060
PAH
PCDD
PCDF
PM
POHC
VOST
EPA Method 0010
EPA Method 0013
EPA Method 0050
EPA Method 0060
Polynuclear aromatic hydrocarbon
Poly chlorinated dibenzodioxin
Poly chlorinated dibenzofuran
Particulate matter
Principal organic hazardous constituent
Volatile organic sampling train
Not applicable
B-37
-------
ATTACHMENT B-14
TABLE D-5.14
POHC AND METAL SPIKING COMPOUNDS
-------
TABLE D-5.14
POHC AND METAL SPIKING COMPOUNDS
Spiking Compound
Rationale for Selection
Spiking Rate (Ib/hr)
POHCs Spiked During Test 2
Chlorobenzene, [###] purity, certified analysis
Napthalene, [###] purity solid, certified analysis,
dissolved in mineral oil
Carbon tetrachloride, [###] purity, certified
analysis
Class 1 compound
Class 1 compound
Low heating value
[###] Ib/hr total
[###] Ib/hr to solid waste
[###] Ib/hr to liquid waste
[###] Ib/hr total
[###] Ib/hr to solid waste
[###] Ib/hr to liquid waste
[###] Ib/hr total
[###] Ib/hr to solid waste
[###] Ib/hr to liquid waste
Organic Chlorine Spiked During Tests 1 and 2
Perchloroethylene, [###] purity, certified analysis
Readily available material
High chlorine content
[###] Ib/hr total
[###] Ib/hr to solid waste
[###] Ib/hr to liquid waste
Metals Spiked During Test 1
Arsenic [###], [###] % solution in petroleum
distillate, certified analysis
Beryllium [###], [###] % solution in petroleum
distillate, certified analysis
Readily available material
Chemically similar (that is,
organically based) to the form of
arsenic in actual wastes
Acceptable from a fire safety and
health hazard aspect
Readily available material
Chemically similar (that is,
organically based) to the form of
arsenic in actual wastes
Acceptable from a fire safety and
health hazard aspect
[###] Ib/hr to liquid waste
only
[###] Ib/hr to liquid waste
only
B-37
-------
TABLE D-5.14 (Continued)
POHC AND METAL SPIKING COMPOUNDS
Spiking Compound
Rationale for Selection
Spiking Rate (Ib/hr)
Cadmium [###], [###] % solution in petroleum
distillate, certified analysis
Readily available material
Chemically similar (that is,
organically based) to the form of
arsenic in actual wastes
Acceptable from a fire safety and
health hazard aspect
[###] Ib/hr to liquid waste
only
Chromium [###], [###]% solution in petroleum
distillate, certified analysis
Readily available material
Chemically similar (that is,
organically based) to the form of
arsenic in actual wastes
Acceptable from a fire safety and
health hazard aspect
[###] Ib/hr to liquid waste
only
Notes:
Ib/hr
POHC =
Pounds per hour
Principal organic hazardous constituents
B-38
-------
ATTACHMENT B-15
TABLE D-5.15
TRIAL BURN REPORT OUTLINE
-------
TABLE D-5.15
TRIAL BURN REPORT OUTLINE
Section
TABLE OF CONTENTS
CERTIFICATION FORM
EXECUTIVE SUMMARY
1.0
2.0
3.0
4.0
4.1
4.2
4.3
4.3.1
4.3.2
4.3.3
4.3.4
4.3.5
4.3.6
4.4
5.0
5.1
Description
~
~
Summary Presentation of Stack Gas Parameters and Emission Rate
Results
Summary of Key Process System Parameters and Results
Summary of Problems, Solutions, and Deviations from the Approved
Trial Burn Plan and Quality Assurance Project Plan (QAPP)
Conclusions Regarding the Success in Meeting the Trial Burn Plan's
Objectives
INTRODUCTION
PROCESS DESCRIPTION
TESTING PROGRAM OVERVIEW
TEST OPERATING CONDITIONS
WASTE AND FUEL FEED RATE INFORMATION
WASTE GENERATION RATE INFORMATION
STACK GAS PARAMETER RATE INFORMATION
Stack Gas Carbon Monoxide
Stack Gas Flow Rate
Stack Gas Oxygen Concentration
Dry Air Pollution Control Equipment (APCE) Inlet Gas Temperature
Combustion Unit Temperature
APCE Control Parameters
SOURCES OF FUGITIVE EMISSIONS AND MEANS OF THEIR
CONTROL
PROCESS AND STACK GAS SAMPLING
SUMMARY OF SAMPLING LOCATIONS AND METHODS
B-39
-------
TABLE D-5.15 (Continued)
TRIAL BURN REPORT OUTLINE
Section
5.2
5.3
5.3.1
5.3.2
5.3.3
5.3.4
5.3.5
5.4
5.4.1
5.4.2
5.4.3
6.0
6.1
6.2
7.0
7.1
7.1.1
7.1.2
7.2
8.0
8.1
8.2
Description
SUMMARY OF WASTE AND FUEL FEED SAMPLING
SUMMARY OF AIR POLLUTION CONTROL SYSTEM
GENERATED WASTE SAMPLING
Principal Organic Hazardous Constituent (POHC) Feed Rate
Ash Feed Rate
Chlorine Feed Rate
Hazardous Metal Feed Rate
Combustion Unit Heat Input Rate
SUMMARY OF STACK GAS SAMPLING
Summary of Sampling Methods
Data Tables for Stack Gas Characteristics
Data Tables for Emission Rates of Constituents of Potential Concern
LABORATORY PROCEDURES
SUMMARY OF ON-SITE ANALYTICAL PROCEDURES
SUMMARY OF OFF-SITE ANALYTICAL PROCEDURES
QUALITY ASSURANCE AND QUALITY CONTROL (QA/QC)
RESULTS
SUMMARY OF ON-SITE QA/QC RESULTS
Stack Gas Samples
Process Samples
SUMMARY OF OFF-SITE QA/QC RESULTS
TRIAL BURN RESULTS SUMMARY AND PROPOSED PERMIT
LIMITS
DESTRUCTION AND REMOVAL EFFICIENCIES
CONTINUOUS EMISSION MONITORING SYSTEM RESULTS
B-40
-------
TABLE D-5.15 (Continued)
TRIAL BURN REPORT OUTLINE
Section
8.3
8.3.1
8.3.2
8.3.3
8.3.4
8.3.5
8.3.6
8.3.7
8.4
8.5
8.6
8.6.1
8.6.2
8.6.3
8.7
Description
STACK GAS EMISSION RATE RESULTS
Participate Matter Emission Rate Results
Hydrogen Chloride and Chlorine Gas Emission Rate Results
Metal Emission Rate Results
POHC Emission Rate Results
Product of Incomplete Combustion Emission Rate Results
Total Organic Emission Rate Results
Poly chlorinated Dibenzodioxin and Poly chlorinated Dibenzofuran
Emission Rate Results
PROPOSED PROCESS LIMITS
PROPOSED WASTE FEED LIMITS
PROPOSED AUTOMATIC WASTE FEED CUTOFF LIMITS
Parameters for Combustion Units
Parameters for APCE
Parameters for Other Associated Equipment
PROPOSED DATA FOR USE IN THE RISK ASSESSMENT
APPENDICES
A
B
C
TRIAL BURN PLAN
TRIAL BURN QAPP
STACK SAMPLING REPORT
Method 0010 Field Data Sheets and Emission Rate Calculations
Method 00 10/0023 A Field Data Sheets and Emission Rate Calculation'
Method 0060 Field Data Sheets and Emission Rate Calculations
Method 0061 Field Data Sheets and Emission Rate Calculations
B-41
-------
TABLE D-5.15 (Continued)
TRIAL BURN REPORT OUTLINE
Section
D
E
F
G
H
I
Description
Method 0031 Field Data Sheets and Emission Rate Calculations
Total Organics Field Data Sheets and Emission Rate Calculations
Method 0050 Field Data Sheets and Emission Rate Calculations
PROCESS SAMPLING REPORT
Raw Data
Data Summary Calculations
QA/QC REPORT
Field Sampling QA/QC Report
Laboratory Data Summary Report
Chain of Custody Forms
INSTRUMENT CALIBRATION RECORDS
Calibration Records for Process Monitoring Equipment
Calibration Records for Process Control Equipment
Calibration Records for Continuous Emission Monitoring Equipment
Calibration Records for Stack Gas Sampling Equipment
Calibration Records for Field Analytical Equipment
PERFORMANCE CALCULATIONS
FIELD LOGS
ANALYTICAL DATA PACKAGES
B-42
-------
ATTACHMENT B
EXAMPLE PROCESS FLOW DIAGRAM AND PIPING
AND INSTRUMENTATION DIAGRAMS
-------
WATER FROM
TREATMENT
PLANT
NATURAL GAS
HAZARDOUS WASTE
FUELS FROM TANK
.
JKS/^
ATOMIZING STEAM
FIREBOX
FABRIC FILTER BAGHOUSE
BOILER
INDUCTION FAN
STEAM TO
PLANT USERS
-DUST-
STACK GAS TO
ATMOSPHERE
DUST TO DISPOSA\
EXAMPLE
BOILER PROCESS
FLOW DIAGRAM
-------
GENERAL INSTRUMENT SYMBOLS
o
CONTROL
SYMBOLS
o
SELF-ACTUATED VALVES ft DEVICES
ACTUATORS
|
VALVE SYMBOLS
dS—
TYPICAL PIPING ABBREVIATIONS
AFT.
lj- • HTirKi'"."' "i'%r
ij-'M'ji ILL 'A'
Q. I"MFHT B'l1
PIPING LINE DESIGNATIONS
LI
LINE SERVICE:
I-' • H v L!- u.- L "•• Fit- ij ••'• L L
;> - L.C , HI i--.A.'j
•- , j_|_] n_,|_>y,HI
-1 - IVvl'jI!...«,fi'_H'.VAILW
.!:r,. f, T n -• .j r P A n if " n s w*"' F P
F •: T P. i' T I" I'J --. F. . .'-i T F ''
PIPING MATERIALS:
'• . ' ''_.-•- 'L .. L _•. IJ
rn'Tl. F I»"M
HI*.- rp\s",' r-'i =*-•. FUF
II'-•••' LLVj '¥ P'.L 't" "' -iHL " .UN;
I-1'. L' Vl\ '_ '. "LiJ-'L'L ilJILLU__ Ut
PIPING LINE TYPES
EQUIPMENT TYFE DESCRIPTIONS
A . Aii:- " Ti. FT F",!ir™.'F
R , FI ri','_F»
r . - -.MPPF^.'P
r * s * s • •• s * s
1 , ,™! t L.
L "L-"'" l'-i, ll-M.-L-'
1 " i.IL-'
P . rnvf
rpri 'F:7,^ HSIT
CABLE - CONDUIT DESISf4ATIONS
-AB.t '.".Nl'.ll "il •=
TYPICAL PIPING SYMBOLS
- 3
T
o>
LU'-L' 1 _'">I4.-L
~.u,-, - -f4--,P"T F "Tl\
-•=r.ir=|7
All 11 MI Let
,-F Ti ::,ri i. - FMFr4T MF "rP
FIGURE 1
EXAMPLE PROCESS AND
1NSTURMENTATION DIAGRAM LEGENI
l-B-2
------- |