On-Site Incineration at the
Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts

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Incineration at the Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts

Site Name:

Rose Disposal Pit Superfund
Site

Contaminants:

Primary Contaminant Groups:

PCBs, volatile organic
compounds (VOCs) including
TCE, benzene, and vinyl
chloride

PCBs at were detected at
concentrations up to
440,000 mg/kg. The
average PCB concentration
was 500 mg/kg

Period of Operation:

February 1994 - July 1994

Location:

Lanesborough, Massachusetts

Cleanup Type:

Remedial action

Vendor:

Mark Phillips
Maximillian Technology
Pittsfield, MA
(413) 494-3027

Technology:

On-site incineration

Soil was pretreated with
crushing and shredding to
achieve a homogenized
incinerator feed
Incineration system
consisting of rotary kiln and
secondary combustion
chamber (SCC)
SCC temperatures
averaged 2000 °F
Ash was discharged, and
returned to the excavated
areas on site

Cleanup Authority:

CERCLA

ROD Date: 9/30/96,

11/21/89

EPA-lead

SIC Code:

NA

Point of Contact:

Pam Shields
U.S. EPA Region 1

Waste Source:

Disposal of manufacturing
wastes in an open trench

Type/Quantity of Media Treated:

Soil (51,000 tons)

Purpose/Significance of
Application:

Incineration of PCB-
contaminated soil

Regulatory Requirements/Cleanup Goals:

Destruction and Removal Efficiency (DRE) of 99.9999% for PCBs as required by Toxic Substances
Control Act regulations in 40 CFR part 761 subpart D

Results:

Treatment performance and air monitoring data collected during this application indicated that all
required performance and standards emissions were achieved.

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Incineration at the Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts

(Continued)

Description:

Between 1951 and 1959, the 14-acre residential lot received wastes from a nearby manufacturer. Soil
at the site was contaminated with PCBs as well as volatile organic compounds (VOCs). A Record of
Decision signed September 23, 1988 and November 21, 1989 specified on-site incineration as the
remedial technology for the soil and sediments. Site cleanup goals and DRE standards were specified
for constituents of concern.

On-site incineration began in February 1994 and was completed in July 1994. The treatment system
consisted of a rotary kiln and an SCC. Kiln ash was treated and stored and treated gas was exhausted
to a stack. Incineration has achieved the soil cleanup goals specified in the ROD.

No information was available on costs for the remedial action.

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Rose Disposal Pit Superfund Site

Executive Summary

This report presents cost and performance data
for the application of on-site incineration at the
Rose Disposal Pit Superfund Site (Rose Site) in
Lanesborough, Massachusetts. A rotary kiln
incinerator was operated from February 1994 to
July 1994 as part of a remedial action.

The Rose site is a 1.5-acre section of a 14-acre
residential lot located in Lanesborough,
Massachusetts. From 1951 through 1959 and
possibly later, wastes from a nearby
manufacturer were disposed of in an open trench
at the site. Soil at the Rose Site is contaminated
with PCBs, as well as volatile organic compounds
(VOCs) including trichloroethylene, benzene, and
vinyl chloride. Measured concentrations of PCBs
at the site were as high as 440,000 mg/kg.

In 1988, EPA signed a Record of Decision (ROD)
specifying on-site incineration as the selected
remedy for the contaminated soil at the Rose
Site. In 1989, EPA released an Explanation of
Significant Differences (ESD) which outlined
EPA's agreement with the responsible party to
conduct complete source remediation. To
achieve complete source remediation, the
responsible party excavated and incinerated a
greater volume of contaminated soil than that
specified in the ROD. The ROD set a Destruction
and Removal Efficiency (DRE) standard for
PCBs of 99.9999%.

The remediation activities performed at the Rose
Site also included the construction and operation
of a groundwater treatment system, However,
unless otherwise indicated, only issues relating to
on-site incineration are discussed in this report.

The excavated soil at the Rose Site was
crushed and blended before incineration.
The blended soil entered the rotary kiln at the
flame end via a screw auger and passed
through the kiln co-current with the exhaust
gas. Kiln ash was quenched in a water bath,
while the exhaust gases were directed to a
secondary combustion chamber (SCC) for
further destruction of contaminants in the
waste feed.

The air pollution control train consisted of a
cyclone separator for removal of larger
particulate matter, a quench tower, a
baghouse for removal of finer particulate
matter, a second quench tower, and a wet
scrubbing system designed to remove
residual contaminants. Dust removed by the
cyclone separator and the baghouse was
discharged to the ash quench bath.
Wastewater from the quench towers and the
scrubbing system was also discharged to the
ash quench bath. All of the solid waste
generated by the system was removed with
the incinerator ash and landfilled on site.

During its five months of operation, the
incinerator processed approximately 51,000
tons of contaminated soil. Treatment
performance and air monitoring data
collected during this application indicated that
all required performance and standards
emissions were achieved.

U.S. ENVIRONMENTAL PROTECTION AGENCY
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Rose Disposal Pit Superfund Site

Site Information

Identifying Information

Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts

CERCLIS # MAD980524169

ROD Date: September 23, 1988 (ROD)
November 21, 1989 (ESD)

Treatment Application

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

Period of operation: February 1994 - July
1994

Quantity of material treated: 51,000 tons
of contaminated soil

Background

Historical Activity that Generated
Contamination at the Site: The site was used
for disposal of waste generated from many
different manufacturing processes.

Corresponding SIC Codes: NA

Waste Management Practice That Contributed
to Contamination: Disposal of manufacturing
waste in an open trench.

Site History:

The Rose Site is located on Balance Rock
Road in Lanesborough, Massachusetts
approximately 4 miles north of Pittsfield. The
site is bounded on the north and northeast by
the deciduous forest of Balance Rock State
Park, on the east and southeast by cropland
and pasture, on the west by mixed forest, and
on the southwest by a residential area.

The Rose Site is the location of a trench used
for disposal of manufacturing wastes
generated by the responsible party between
1951 and 1959. The wastes contained PCBs
and VOCs.

Between 1980 and 1982, EPA conducted the
preliminary assessment, site inspection, and
field investigation. All subsequent activities
at the site have been performed by the
responsible party.

A remedial investigation (Rl) was conducted
in 1983 and supplemented in 1986, and the
feasibility study (FS) was conducted in 1988.

Based on the results of the Rl and the FS, a
ROD was signed on

September 23, 1986 specifying
excavation and on-site incineration of
contaminated soils. The ROD specified
excavation of the contaminated soil to the
top of the saturated zone.

In 1989, EPA released an ESD which
outlined EPA's agreement with the
responsible party to conduct complete
source removal. Under this agreement,
the responsible party excavated
additional soil below the saturated zone.
Complete source removal allowed the
responsible party to avoid installing a
cover and establishing other long-term
institutional controls.

Approximately 51,000 tons of soil were
processed between February 1994 - July
1994. By July 1994 all of the cleanup
goals had been met for the contaminated
soil, and incineration had ceased.

Regulatory Context:

In 1984, the Rose Site was added to the
National Priorities List (NPL).

A ROD was signed in 1988 requiring the
responsible party to conduct remedial
activities at the Rose Site.

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Rose Disposal Pit Superfund Site

Site Information (Cont.)

Background (Cont.l

In 1989, EPA released an ESD which
outlined EPA's agreement with the
responsible party to conduct complete
removal; this action was more aggressive
then that associated with the goals set forth
in the ROD.

The DRE and ash residual standards were
established the provisions of the Toxic
Substance(s) Control Act (TSCA) and
associated regulations in 40 CFR part 761
subpart D.

The selected remedy is consistent with the
Comprehensive Emergency Response,
Compensation and Liability

Timeline

Tablet Timeline [1,2,3]

Date

Activity

1951-1959

Wastes are disposed of by the RP at the Rose Disposal Pit site.

1980-1982

Preliminary assessment, site inspection, and field investigation performed by EPA.

1983

A remedial investigation is conducted by responsible party.

1984

Site is listed on the NPL

May 1984

The responsible party secured the site and covered the disposal area in response to an
Administrative Order from EPA.

1986

A supplemental remedial investigation is conducted by responsible party.

1988

Feasibility study conducted by responsible party

September 23, 1988

Record of Decision signed

November 21, 1989

Explanation of Significant Differences is issued

October 1993

Trial burn

February 1994

Interim operations of the incinerator began

April 1994-July 1994

Rotary kiln incinerator operational for full-scale treatment

Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization
Act of 1986 (SARA), and to the extent
practicable, the National Contingency Plan
(NCP) in 40 CFR part 300.

Remedy Selection: EPA determined that on-
site incineration was the only available
alternative that satisfied all of the criteria
established in the ROD, particularly
permanence, and that on-site incineration was
more cost effective than off-site incineration for
the Rose Site [1].

Site Loaistics/Contacts
Site Management: RP-lead
Oversight: EPA

Remedial Project Manager:

Pam Shields
U.S. EPA Region 1

State Contact:

Jay Naparstek

Massachusetts Department of Environmental

Protection

(617) 292-5697

Treatment System Vendor:

Mark Phillips
Maximillian Technology
Pittsfield, MA
(413) 494-3027

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

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Rose Disposal Pit Superfund Site

Matrix Description

Matrix Identification

Type of Matrix Processed
Through the Treatment System:

Contaminated soil excavated from the disposal
pit both above and below the saturated zone.

Contaminant Characterization

Primary Contaminant Groups: PCBs, volatile
organic compounds (VOCs) including TCE,
benzene, and vinyl chloride.

PCBs at were detected at
concentrations up to 440,000 mg/kg.
The average PCB concentration was
500 mg/kg.

Matrix Characteristics Affecting Treatment Costs or Performance

The matrix characteristics that most significantly affected cost or performance at this site and their
measured values are presented in Table 2.

Table 2. Matrix Characteristics of Soil f1,3J

Parameter

Value

Soil Density

1.6 g/cc

Heat content

290 Btu/lb

Ash

86%

Chlorine Content by weight

0.38%

Treatment System Description

Primary Treatment Technology

Supplemental Treatment Technology

Rotary kiln incineration system, including:
Waste feed handling system
Rotary kiln incinerator
Secondary combustion chamber

Air Pollution Control System, including:
Cyclone separator
Baghouse
Quench towers
Wet scrubbing system

System Description and Operation

The soil at the Rose Site was excavated and
transported to the crusher/shredder. The
crusher/shredder was used to reduce the
particle size of the soil feed to less than 0.75
inches. The crushed soil was transported to
the soil blending building where it was
blended before incineration to achieve a
homogenized incinerator feed. The soil
blending building was equipped with a vapor-
phase carbon filtration system designed to
reduce possible PCB or VOC emissions.

The soil feed entered the kiln at the flame
end and traveled through the kiln co-current

with the combustion gases. Ash and
exhaust gases were discharged from the
kiln.

Kiln ash was quenched in a water bath
and discharged to a storage area. The
solids in the ash quench bath were
allowed to settle and were continuously
removed.

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Rose Disposal Pit Superfund Site

Treatment System Description (Cont.)

System Description and Operation (Cont.l

The co-current rotary kiln was 110 feet long
with an internal diameter of approximately 8
feet. The kiln consisted of three refractory-
lined cylindrical sections bolted together at
flanged connections to function as one unit.
The kiln was designed for an optimal
throughput of approximately 50 tons of
contaminated soil per hour.

The kiln was fired with oxygen, fuel oil, and
excess air. The kiln-drive system employed a
200-hp motor.

The kiln exhaust gases were directed to a
cyclone separator for removal of larger
particulates. Exhaust gases entered the
cyclone separator tangentially allowing larger
particles to fall out. Particles separated from
the exhaust gas fell to the bottom of the
cyclone and were transported to the ash
quench bath.

The exhaust gas then entered the SCC which
provided further destruction of remaining
contaminants. The SCC was 52 feet long
and had an internal diameter of 11 feet. It
was lined with refractory brick and is fired
with oxygen, fuel oil, and excess air.

Exhaust gas from the SCC was cooled in a
quench tower from approximately 2,000 °F to
approximately 425 °F. Quench nozzles in
the tower spray atomized recycled water into
the gas stream.

The quenched exhaust gas was then
drawn into a baghouse. The baghouse
consisted of 1,020 woven fiberglass
bags. Each bag had a 6-inch diameter
and length of 10 feet for a surface area
of 16 square feet per bag. The total filter
area of the baghouse was approximately
16,300 square feet. The dust removed in
the baghouse was discharged to the ash
quench bath.

The exhaust gases from the baghouse
were then quenched in a second quench
tower similar to the one previously
described.

The filtered and quenched exhaust
gases were drawn through a packed-
tower-design wet scrubber. Scrubbing
was achieved by spraying caustic
solution over the packed bed as the
exhaust gas flowed up through the bed.
Scrubber wastewater was continuously
recycled, with a bleed stream discharged
to the ash quench bath.

Gases were forced out of the scrubber
and into the exhaust stack which was
mounted on top of the scrubber. The
stack released gas to the atmosphere at
approximately 200 °F. The internal
diameter of the stack was 4.5 feet and
the height above the ground was 66 feet.

The solids in the quench bath included
all of the residuals from the air pollution
control units as well as the ash from the
incinerated soil. These solids were
sampled and analyzed using the TCLP
and eventually returned to the excavated
areas on site.

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Office of Solid Waste and Emergency Response
Technology Innovation Office

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Rose Disposal Pit Superfund Site

Treatment System Performance

Cleanup Goals/Standards

The cleanup goals and standards were	• The required DRE was 99.9999% for

specified in the ROD. The DRE was set	PCBs.

based on TSCA regulations 40 CFR part 761

subpart D. [1]	• The maximum concentration of PCBs in

the residual ash was set at 2 mg/kg.

The soil cleanup level was 13 mg/kg for
PCBs. This corresponds to a 1 x 10 5 excess
lifetime cancer risk level for the average
case.

Treatment Performance and Compliance

A trial burn conducted at the Rose site was
designed to operate the incineration system
at conditions that would reflect worst-case
destruction and removal of all constituents of
concern.

PCBs were determined to be present in the
soil at sufficient concentrations such that
spiking with PCBs or principle organic
hazardous constituents (POHCs) was not
necessary.

The AWFCOs limits during the operation
of the incinerator are shown in Table 4.
Information about the frequency of
AWFCOs was not available. The values
of various operating parameters as
measured during the trial burn are shown
in Table 5; information on actual values
of these parameters during operation
was not available.

The average concentration of PCBs in
the residual ash was 0.0618 mg/kg.

Table 3 Average Destruction and Removal Efficiencies from Compliance Testing

Contaminant

Average
Contaminant Feed
Rate in Soil (Ib/hr)

Average Contaminant
Rate in Stack Gas
Emissions (Ib/hr)

Average Contaminant
Rate in Residuals

DRE(%)

PCB

742.5

9.4 x 10"4

NA

99.99987

Table 4. Automatic Waste Feed Cutoffsa

Parameter

Cutoff Limit

Maximum pressure kiln at entry

-0.05 w.c.

Minimum afterburner gas exit temperature, instantaneous

1,915°F

Minimum afterburner residence time, instantaneous

2 seconds

Minimum pH at scrubber sump

5

Minimum flow scrubber recirculation line

450 gpm

Maximum CO (7% 02)

100 ppmv

Minimum 02 (dry volume)

3%

Minimum combustion efficiency

99.9%

Maximum temperature quench #1 gas exit

500 °F

Maximum temperature scrubber entry

300 °F

"Recommended limits from Trial Burn Report.

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Rose Disposal Pit Superfund Site

Treatment System Performance (Cont.)

Table 5 Operating Parameters [3]

Parameter

Trial Burn Value

SCC Exit Gas Temperature

2,100 °F

Soil Feed Rate

51.8 tons/hour

PCB Feed Rate

740 Ib/hr

Kiln Fuel Oil Feed Rate

1,734 Ib/hr

Kiln Pressure

-0.6 inches w.c.

Quench #1 Exit Temperature

394 °F

SCC Residence Time

4.8 seconds

Scrubber Entry Temperature

208 °F

Scrubber Recirculation Flow

575.8 gpm

Scrubber pH

7.5 s.u.

Stack Gas Carbon Monoxide (60-Minute Rolling
Average)

9.9 ppmv

Stack Gas Oxygen (Dry Basis)

9.0 vol %

Secondary Draft

-0.71 inches w.c.

Combustion Efficiency

99.991

w.c. = Water column
s.u. = Standard pH units

Table 6. TCLP Comparison for Residual

Constituent

Regulatory Threshold (mg/L)

Average TCLP Concentration (mg/L)

1,4-Dichlorobenzene

7.5

0.010

2-Methylphenol (o-cresol)

200.0

0.010

m-cresol/p-cresol

200.0

0.021

Hexachloroethane

3.0

0.010

Nitrobenzene

2.0

0.010

Hexachlorobutadiene

0.5

0.010

2,4,6-Trichlorophenol

2.0

0.010

2,4,5-Trichlorophenol

400.0

0.010

2,4-Dinitrotoluene

0.13

0.010

Hexachlorobenzene

0.13

0.010

Pentachlorophenol

100.0

0.021

Pyridine

5.0

0.010

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Rose Disposal Pit Superfund Site

Treatment System Performance (Cont.)

Table 6. TCLP Comparison for Residual

Constituent

Regulatory Threshold (mg/L)

Average TCLP Concentration (mg/L)

Arsenic

5.0

<0.138

Barium

100.0

0.846

Cadmium

1.0

<0.0066

Chromium

5.0

0.0137

Lead

5.0

0.124

Mercury

0.2

<0.0070

Selenium

1.0

<0.0219

Silver

5.0

<0.0133

Vinyl Chloride

0.2

<0.011

1,1-Dichloroethene

0.7

<0.011

Chloroform

6.0

<0.011

1,2-Dichloroethane

0.5

<0.011

2-Butanone (MEK)

200.0

<0.011

Carbon Tetrachloride

0.5

<0.011

Trichloroethene

0.5

<0.011

Benzene

0.5

<0.011

Tetrachloroethene

0.7

<0.011

Chlorobenzene

100.0

<0.011

gamma-BHC (Lindane)

0.4

<0.1

Endrin

0.02

<0.005

Methoxychlor

10.0

<1.0

Toxaphene

0.5

<0.1

Heptachlor

0.008

<0.003

Heptachlor Epoxide

0.008

<0.003

Chlordane

0.03

<0.01

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Rose Disposal Pit Superfund Site

Observations and Lessons Learned (Cont.)

Performance Data Quality

According to site personnel the QA/QC
program used throughout the remedial action
met all EPA requirements. All monitoring
was performed using EPA-approved
methods, and the vendor did not note any
exceptions to the QA/QC protocols. [3]

Treatment System Cost

Procurement Process

According to site personnel the responsible
party contracted with Clean Berkshires, Inc.
(CBI) To provide design/remedial services
at the site. CBI used several
subcontractors to implement specific
aspects of the operation. [3]

Cost Data

Information on the costs of on-site
incineration was not available.

Observations and Lessons Learned

Observations and Lessons Learned

The incinerator was constructed during the
winter of 1992. Heavy snowfalls and low
temperatures hampered the progress of
workers.

Cold weather also affected incinerator
startup, which occurred in January 1994.
The extreme temperatures caused
various problems with water used for
cooling. In addition, valves cracked,
solenoids remained closed or open, and
air lines froze.

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Technology Innovation Office

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Rose Disposal Pit Superfund Site

Observations and Lessons Learned (Cont.)

Public Involvement

Citizens expressed concern that the
incineration and excavation process would
create excessive noise. EPA worked with
local officials to minimize the adverse
impacts of the site remediation activities. [1]

Many public meetings were held, and EPA
and state personnel met individually with
local officials and residents to discuss
specific concerns. Neighborhood residents
formed a group that worked with EPA to
address public concerns.

The RP setup a neighborhood network
that used volunteer neighbors to
periodically distribute fact sheets
regarding the site incineration project.

References

1.	Superfund Record of Decision. Rose
Disposal Pit Site, Lanesborough,
Massachusetts, September 23, 1988.

2.	Memorandum - Explanation of Significant
Differences. Rose Disposal Pit Site,
Lanesborough, Massachusetts, November
21, 1989.

3.	Trial Burn Report for the Clean
Berkshires. Inc. High Temperature
Incinerator (HTh System. Rose Disposal
Pit Superfund Site, Lanesborough,
Massachusetts, December, 1993.

4.	Remedial Action Completion Report.
F.T. Rose Superfund Site, September
1994.

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

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