On-Site Incineration at the
Baird and McGuire Superfund Site
Holbrook, Massachusetts

12


-------
Incineration at the Baird and McGuire Superfund Site
Holbrook, Massachusetts

Site Name:

Baird and McGuire Superfund
Site

Contaminants:

Dioxins, volatile organic
compounds (VOCs),
polynuclear aromatic
hydrocarbons (PAHs),
pesticides, and heavy metals,
including lead and arsenic

Period of Operation:

March 1995 to March 1997

Location:

Holbrook, Massachusetts

Cleanup Type:

Remedial action

Site General Contractor:

OHM Remediation Services
Corporation

16406 U.S. Route 224 East
Findlay, OH 45839
(419) 423-3526

Technology:

•	Removal of moisture from
soil using rotary dryer

•	Combustion of contaminants
in dry soil using rotary kiln

•	System designed to treat 25
tons of contaminated soil per
hour

•	Ash and flue gases
discharged from kiln

•	Residuals generated from
incinerator returned to
excavated areas on site

Cleanup Authority:

CERCLA

•	ROD signed in September
1986 (soil)

•	ROD signed in September
1989 (sediment)

•	U.S. Corps of Engineers
Lead

SIC Code:

2879 (Pesticides)

2841	(Soaps)

2842	(Floor Wax)
2869 (Solvents)

Point of Contact:

Chet Janowski
U.S. EPA Region 1
John F. Kennedy Building
One Congress Street
Boston, MA 02203

Waste Source:

Land disposal of process
wastes

Type/Quantity of Media Treated:

Soil (210,000 tons) and sediment (1,500 cubic yards)

Purpose/Significance of
Application:

Treats wide range of
contaminants in soil and
sediment, including dioxin,
VOCs, PAHs, and Pesticides

Regulatory Requirements/Cleanup Goals:

Destruction and Removal Efficiency (DRE) of 99.99% for principal organic hazardous constituents
(POHCs) as required by Resource Conservation and Recovery Act (RCRA) incinerator regulations in 40
CFR part 264, subpart 0

Results:

Trial burn data indicate that all DRE emission standards were met

13


-------
Incineration at the Baird and McGuire Superfund Site
Holbrook, Massachusetts

(Continued)

Description:

Between 1912 and 1983, the site was operated as a chemical mixing and batching company. During a
remedial investigation at the site, dioxin concentrations in the soil were measured as high as
27.8 /ig/kg. A Record of Decision (ROD) signed in 1986 specified on-site incineration as the selected
remedy for the contaminated soils at the site. A second ROD signed in 1989 specified on-site
incineration as the selected remedy for the contaminated sediments of the nearby Cochato River.

The incineration system included a rotary dryer for removal of moisture from the soil. The dried soil was
fed to the rotary kiln where the contaminants in the soil were volatilized and destroyed. From March
1995 through March 1997, the incinerator processed approximately 210,000 tons of contaminated soil
and 1,500 cubic yards of contaminated sediment. All of the residuals generated from the incineration
and subsequent ancillary operations, including ash and wastewater treatment sludge, were landfilled on
site. Treatment performance and emissions data collected during this application indicated that all
required performance standards and emissions requirements were achieved.

The total cost for remediation using the incineration system was approximately $133,000,000.	

14


-------
Baird and McGuire Superfund Site

Executive Summary

This report presents cost and performance data
for the application of on-site incineration of
contaminated soil at the Baird and McGuire
Superfund site (Baird and McGuire) in Holbrook,
Massachusetts. A rotary kiln incinerator was
operated from March 1995 through March 1997
as part of a remedial action. Contaminants of
concern in the soil were dioxins, volatile organic
compounds (VOCs), polynuclear aromatic
hydrocarbons (PAHs), pesticides, and heavy
metals, including lead and arsenic.

The Baird and McGuire site was operated as a
chemical mixing and batching company from
1912 to 1983. Some of the raw materials used on
site were stored in a tank farm and piped to on-
site laboratory and mixing buildings. Other raw
materials were stored in drums. During the
remedial investigation, dioxin concentrations in
the soil were measured as high as 27.8 /ig/kg.

A Record of Decision (ROD) signed in 1986
specified on-site incineration as the selected
remedy for the contaminated soils at the site. A
second ROD signed in 1989 specified on-site
incineration as the selected remedy for the
contaminated sediments of the nearby Cochato
River. Both RODs set standards requiring a
destruction and removal efficiency (DRE) of
99.9999% for principal organic hazardous
constituents (POHCs).

The remediation activities performed at Baird and
McGuire also included the construction and
operation of a groundwater treatment system.
Only issues relating to on-site incineration are
discussed in this report.

All of the material that was incinerated was
mechanically screened to remove debris
before incineration. The incineration system
included a rotary dryer for removal of
moisture from the soil. The dried soil was fed
to the rotary kiln where the contaminants in
the soil were volatilized and destroyed. Off-
gases from the rotary kiln were then routed to
a secondary combustion chamber (SCC).

The exhaust gas from the rotary kiln was
directed to an air pollution control system
(APCS) consisting of a baghouse for
particulate removal, a quench tower, a wet
scrubber for fine particulate removal.
Wastewater from the APCS was treated in an
on-site wastewater treatment system.

All of the residuals generated from the
incineration and subsequent ancillary
operations, including ash and wastewater
treatment sludge, were landfilled on site.

During two years of operation, the incinerator
processed approximately 210,000 tons of
contaminated soil, and 1,500 cubic yards of
contaminated sediment. Treatment
performance and emissions data collected
during this application indicated that all
performance standards and emissions
requirements were achieved.

The total cost for remediation using the
incineration system was approximately
$133,000,000.

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

15


-------
Baird and McGuire Superfund Site

Site

Identifying Information

Baird and McGuire Superfund Site
Holbrook, Massachusetts

CERCLIS # MAD001041987

ROD Date: September 30, 1986 (soil)

September 14, 1989 (sediment)

Background

Historical Activity that Generated
Contamination at the Site: Mixing, packaging
and distribution of pesticides, disinfectants,
soaps, floor waxes and solvents

Corresponding SIC Codes: 2879 - Pesticides,
2841 - Soaps, 2842 - Floor Wax, and 2869 -
Solvents

Waste Management Practice That Contributed
to Contamination: Land disposal of process
wastes

Site History:

The site operated from 1912 until its closure
in 1983. During this period, activities at the
site included mixing, packaging, storing and
distribution of various products, including
pesticides, disinfectants, soaps, floor waxes,
and solvents.

Treatment Application

Type of action: Remedial (on-site rotary
kiln incineration)

Period of operation: March 1995 - March
1997

Quantity of material treated: 210,000 tons
of contaminated soil and 1,500 cubic yards of
contaminated sediment.

The Baird and McGuire site is located
near the western bank of the Cochato
River in northwest Holbrook, Norfolk
County, Massachusetts. The site
consists primarily of coniferous
woodlands and wooded wetlands.
Approximately two-thirds of the site is
within the 100-year floodplain of the
Cochato River.

Contamination at the site has been
attributed to the direct discharge of
process wastes to soils, a nearby brook
and wetlands, and a former gravel pit, all
of which are within the current site
borders.

Soil and sediment at Baird and McGuire
was contaminated with dioxin, VOCs,
PAHs, other organic compounds,
pesticides, and heavy metals such as
lead and arsenic.

A site inspection was conducted in
January 1984 and a Remedial
Investigation (Rl) and a Feasibility Study
(FS) were conducted in 1985 and 1986
respectively.

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

16


-------
Baird and McGuire Superfund Site

Site Information (Cont.)

Background (Cont.l

The highest concentrations of contaminants
were under and around former process
buildings. In this area, soil sampling and
subsequent analysis did not show any
discernable decrease in contamination with
depth. Contamination was assumed to exist
to bedrock at a depth of approximately 15
feet. [3]

Elevated concentrations of contaminants
were also found in the area used as an on-
site disposal area for a removal action in
1983-1984. This area was fenced and
capped after EPA removed approximately
1,000 cubic yards of contaminated soil. [3]

Based on the results of an Rl and FS, a ROD
was signed on September 30, 1986
specifying excavation and on-site incineration
of contaminated soils at the site. Another
ROD was signed on September 14,1989
specifying excavation and on-site incineration
of contaminated sediment at the site.

It was estimated that 191,000 cubic yards of
soil would be excavated for incineration. This
quantity included only the "Hot Areas" which
were established such that the contaminant
concentrations in the remaining soils would
be one to two orders of magnitude less than
those to be excavated. [1]

Between 1995 and 1997, an on-site rotary
kiln incinerator was employed to remediate
the excavated soil and sediment.

During two years of operation, the
incinerator processed approximately
210,000 tons of contaminated soil and
1,500 cubic yards of contaminated
sediment.

Regulatory Context:

A ROD signed in September 1986 (soil)
and a ROD signed in 1989 (sediment)
specified on-site incineration as the
selected remedy for both contaminated
soil and contaminated sediment.

Compliance standards for the
incineration were set based on the
Resource Conservation and Recovery
Act (RCRA) regulations for incinerators
in 40 CFR part 264 subpart O.

Site activities were conducted under the
authority of the Comprehensive
Environmental Response Compensation,
and Liability Act of 1980 (CERCLA), as
amended by the Superfund
Amendments and Reauthorization Act of
1986 (SARA) and the National
Contingency Plan (40 CFR part 300).

Remedy Selection: On-site incineration was
selected as the remedy for contaminated soil
and sediment at the Baird and McGuire
Superfund site because it was a cost-
effective alternative that was protective of
human health and the environment. [1,2]

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

17


-------
Baird and McGuire Superfund Site

Site Information (Cont.)

Timeline

Tablet Timeline [1,2,10]

Date

Activity

1912-1983

Chemical mixing and batching occurs at Baird and McGuire site

May 1981

Site Investigation

March 1983

EPA-initiated immediate removal action. Removal of approximately 1,000 cubic yards of
contaminated soil and construction of a clay cap

July 1985

Site sampling and analysis revealed the presence of dioxin.

May 1985 - August 1986

Remedial Investigation/Feasibility Study

September 1986
September 1989

Records of Decision signed

January 1995

Trial burn

March. 1995 - March 1997

Rotary kiln incinerator ODerational

Site Loaistics/Contacts

Site Management: United States Army Corps of
Engineers-lead

Oversight: United States Environmental
Protection Agency

Remedial Project Manager:

Chet Janowski
U.S. EPA Region 1
John F. Kennedy Building
One Congress Street
Boston, MA 02203

Matrix Description

Matrix Identification

Type of Matrix Processed Through the
Treatment System: Soil and sediment

Treatment System Vendor:

OHM Remediation Services Corporation
16406 U.S. Route 224 East
Findlay, OH 45839
(419) 423-3526

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

18


-------
Baird and McGuire Superfund Site

Matrix Description (Cont.)

Contaminant Characterization

Primary Contaminant Groups: Dioxin, VOCs
PAHs, other organic compounds, pesticides, and
heavy metals such as lead and arsenic.

The contaminant of greatest concern
was dioxin. The maximum
concentration detected was 28.7 |jg/kg
in the soil beneath the process
buildings. [3]

Matrix Characteristics

The matrix characteristics that most significantly affect cost or performance at this site and their
measured values are presented in Table 2. The results of these measurements were obtained based
on the analysis of contaminated soil incinerated during the trial burn.

Table 2. Matrix Characteristics of Soil [ 10]

Parameter

Value

Moisture Content

9%

Heat Content

430 BTU/lb

Ash Content

97%

Chloride Total

0.06 %

Total Chromatographical Organics (TCO)

5,600 mg/kg

Treatment System Description

Primary Treatment Technology	Supplemental Treatment Technology

Rotary Kiln Incinerator, including:	Pre-treatment (soil): Screened and dried

Rotary dryer

Rotary kiln incinerator	Post-treatment (air): Air Pollution Control

Secondary combustion chamber	System, including:

High temperature baghouse
High energy wet scrubbing system
Quench tower

Post-treatment (water): On-site wastewater
treatment for treatment of wastewater from
wet scrubbing and quenching.

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

19


-------
Baird and McGuire Superfund Site

Matrix Description (Cont.)

System Description and Operation

The excavated soil was mechanically
screened to remove debris prior to
incineration. The excavated sediment was
placed into specially designed containers and
trucked to the incinerator. Feed soils and
sediments were dried in a rotary dryer before
being processed in the incinerator.

A flow diagram of the incinerator system is
presented as Figure 1.

The dried material was fed to the rotary kiln
via a drag-chain conveyor. The organic
contaminants were volatilized and partially
destroyed in the kiln chamber.

The kiln was manufactured by OHM
Remediation Services Corporation and had a
length of 40 feet and an inside diameter of 8
feet. The kiln was lined with high-density
castable refractory brick and was designed
such that the optimal throughput of
contaminated soil was approximately 25 tons
per hour.

The kiln was rated at 32 million BTU/hr. The
kiln drive system employed a 40 hp motor
and rotated at a maximum rate of 120
revolutions per hour.

Kiln ash was quenched in a water bath and
discharged to a storage area. Settled solids
were continually removed from the ash
quench bath by a drag-chain conveyor.

The exhaust gas from the rotary kiln was
routed through the rotary dryer to provide
heat for soil drying. After passing through the
dryer, the exhaust gas entered the baghouse
through an internal, 180-degree bend
knockout chamber. The exhaust gas then
passed through 456 bag modules.

The baghouse was rated for a grain loading
of treated exhaust gas less than or equal to
0.02 grains per dry standard cubic foot (dscf).
The air to cloth ratio was 4.40 to 1. The
design operating conditions for exhaust gas
flow rate and exit temperature were 24,000

actual cubic feet per minute (acfm) and
350 °F.

Dust removed by the baghouse was
treated in an indirect-fired rotary
chamber. Exhaust gas from this unit was
fed back to the rotary dryer.

Exhaust gas leaving the baghouse
entered the downflow quench tower then
passed through 3 levels of quench
sprays. The gas was directed by a
contactor tube to impact sump water at
the base of the quench tower. [10]

The gas then passed into a 23.5-foot-
long mobile mounted, two-stage Hydro-
Sonic Scrubber where chemical (caustic)
and particulate scrubbing occurred. [10]

Exhaust gas from the scrubber was
routed to the SCC for further combustion
of volatilized contaminants. The SCC
operated at approximately 1,950°F. The
exhaust gas residence time in the SCC
was a minimum of 2 seconds.

Combustion gas was drawn through the
incinerator by an induced draft fan
(resulting in a constant negative pressure
throughout the system) and was
exhausted through a 100-foot stack.
Stack gas flow rate was 44,435 acfm and
the stack exit temperature was
approximately 175°F.

All of the residuals generated from
incineration and subsequent operations
were returned to the excavated areas on
site. This included the quenched ash
from the rotary kiln, ash from the
incineration of baghouse dust, and
wastewater treatment sludge.

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

20


-------
Baird and McGuire Superfund Site

Matrix Description (Cont.)

Figure 1. Incineration Flow Diagram, Baird & McGuire Superfund Site, Holbrook, Massachusetts

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office


-------
Baird and McGuire Superfund Site

Matrix Description (Cont.)

Table 3. Summary of Operating Parameters

Parameter

Value

Residence Time

Not Available

System Throughput

25 tph

Kiln Discharge Temperature

1,233°F

Treatment System Performance

Cleanup Goals/Standards

The cleanup goals and standards were
specified in the RODs. Compliance
standards for the incineration were
established based on the RCRA incinerator
regulations in 40 CFR part 264 subpart O.
[1,2]

The RODs required a DRE of 99.9999% for
principal organic hazardous constituents
(POHCs).

No quantitative soil cleanup standard was
set. The limits of excavation were
established such that contaminant
concentrations in remaining soils were one to
two orders of magnitude lower than the
concentrations in the excavated soils.
According to the findings of a risk
assessment performed for the site, the
remaining areas of contamination after
excavation presented an excess lifetime
cancer risk between 1x 10~4 and 1x 10"7.

Incineration performance requirements
included:

99% removal of HCI;

- 99.99% DRE of all POHCs;

particulate emissions less than 180

mg/dscm (corrected)

99.9999% DRE of dioxin surrogate [10]

Site-specific criteria for arsenic and lead
were developed by USACE based on the
results of site-specific air modeling. The
requirements specify a maximum stack
emission rate for arsenic and lead of
0.00793 g/s and 0.00231 g/s, respectively.
[10]

Treatment Performance and Compliance

A trial burn was conducted from January 24,
1995 through January 26, 1995. The trial
burn was conducted at conditions that would
reflect worst-case destruction and removal of
all constituents of concern. Naphthalene and
monochlorobenzene were selected as the
POHCs. 1,2,4,5-tetrachlorobenzene (TeCB)
was selected as a surrogate for dioxin.
Naphthalene and TeCB were spiked into the
waste feed soil as solids and
monochlorobenzene was spiked as a liquid.
The spiking occurred as the waste feed
entered the dryer. The data for the DREs is
included in Table 4.

The incinerator operated within the
operating limits established during the trial
burn, signifying that all cleanup
requirements were met. The AWFCOs
limits that were used during the operation
of the incinerator are shown in Table 5.
Information regarding the frequency of
AWFCOs was not available. Trial burn
operating parameters are shown in Table
6. (Information regarding actual values for
operating parameters was not available.)

The residual ash was tested for each of the
POHCs. These data are presented in
Table 7.

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

22


-------
Baird and McGuire Superfund Site

Treatment System Performance (Cont.)

Table 4. Average Destruction and Removal Efficiencies from Trial Burn [10]

Contaminant

Average Contaminant Feed
Rate in Soil (Ib/hr)

Average Contaminant Stack Gas
Emission Rate (Ib/hr)

DRE(%)

Naphthalene

205.21

1.0 x 10 5

99.999951

Vlonochlorobenzene

16.3

3.4 x 10"5

99.99979

1,2,4,5-Tetrachlorobenzene

203.7

1.8x10"5

99.999991

Table 5. Automatic Waste Feed Cutoffs [10]

Parameter

Cutoff Limit

Maximum Average Feed Rate (one hour rolling average)

52,840 Ibs/hr

Maximum Instantaneous Feed Rate (one minute average)

59,080 Ibs/hr

Minimum Kiln Discharge Temperature

1170°F

Minimum Kiln Exit Pressure

<-0.1 inch w.c.

Minimum SCC Gas Temperature

1880 °F

Draft Average SCC Exit Pressure

<-0.1 inch w.c.

Minimum Exhaust Gas Oxygen

>3%

Maximum Exhaust Gas Carbon Monoxide Concentration

199 ppm

Minimum Scrubber Nozzle No. 1 Recycle Flow Rate

40 gpm

Minimum Scrubber Nozzle No. 2 Recycle Flow Rate

32 gpm

Minimum Scrubber Pressure Drop

35 inch w.c.

Minimum Scrubber pH

6.0

Maximum Stack Gas Flow Rate

50,000 acfm

w.c.- Water column

Table 6. Operating Parameters [ 10]

Parameter

Trial Burn Value

Waste Feed Rate

5,194 Ibs/hr

Kiln Discharge Temperature

1233 °F

Secondary Temperature

1951°F

Secondary Oxygen

7.24 %

Kiln Draft

-1.42 inches w.c.

Baghouse Pressure Drop

3.71 inches w.c.

Scrubber Pressure Drop

46.8 inches w.c.

Scrubber pH

6.69

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

23


-------
Baird and McGuire Superfund Site

Treatment System Performance (Cont.)

Table 6. Operating Parameters [ 10]

Parameter

Trial Burn Value

Stack Temperature

174.8 °F

Stack Flow Rate

44435 acfm

Secondary Draft

-0.71 inches w.c.

Dryer Discharge Temperature

309.1 °F

Baghouse Quench

1514 gpm

Secondary Combustion Chamber Retention Time - calculated

2.51 seconds

w.c. - Water column

Table 7. Contaminant Concentration in Residual [ 10]

Spiked POHCs

Concentration in Ash (mq/kq)

Naphthalene

<0.316

Monochlorobenzene

<0.810

1,2.4.5-Tetrachlorobenzene

<0.422

Performance Data Quality

According to the site personnel, the QA/QC
program used throughout the remedial action
met all EPA requirements. All monitoring
and sampling analysis was performed using
EPA-approved methods, and the vendor did
not note any exceptions to the QA/QC
protocols.

Treatment System Cost

Procurement Process

USACE contracted with OHM Remediation
Services to acquire and operate the
incinerator at the site. OHM Remediation
Services used several subcontractors to
implement specific aspects of the operation.
[10]

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

24


-------
Baird and McGuire Superfund Site

Treatment System Cost (Cont.)

Cost Data

The estimated cost for operating the
incinerator at the site was $133,000,000 [11].
A total of 248,000 tons of soil and sediment
were incinerated. This corresponds to a total
unit cost for incineration of $540 per ton. A
detailed breakdown of these costs was not
available.

Observations and Lessons Learned

Observations and Lessons Learned

Under certain unusual weather conditions,
the steam plume from the incinerator stack
touched down on nearby residences. In
response to the public concern that was
generated, USACE added 50 feet to the
height of the incinerator stack. According to
EPA officials, there were no public health
reasons for this action. [8]

References

1.	Superfund Record of Decision. Baird and
McGuire Site, Holbrook, Massachusetts,
September 29, 1986

2.	Superfund Record of Decision. Baird and
McGuire Site, Holbrook, Massachusetts,
September 14, 1989.

3.	Remedial Investigation Report. Baird and
McGuire Site, Holbrook, MA, May 22, 1985.

4.	Feasibility Study Report. Baird and McGuire
Site, Holbrook, MA, July 18, 1986.

5.	Final Addendum Report: Remedial
Investigation Phase II. Baird and McGuire
Site, Holbrook, MA, June 27, 1986.

6.	EPA Supplement to the Baird and
McGuire Feasibility Study Report of July.
1986.

7.	EPA Environmental News. October 2,
1985.

8.	EPA Environmental News. March 16.
1995.

9.	Superfund: Progress at National Priority
List Sites. 1997 Update. Massachusetts:
Baird and McGuire Site. January, 1997

10.	Trial Burn Report for the Baird and
McGuire Superfund Site. Holbrook. MA.
March 10, 1995.

11. Engineering News-Record. McGraw-Hill
Companies, July 14, 1997.

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste and Emergency Response
Technology Innovation Office

25


-------