BOX 2-1

Definition of Destruction and Removal Efficiency

DRE = 100 × [(Feed rate − Emission rate) /Feed rate]


where emission rate is the rate at which the selected POHC exits the process in the exhaust gas stream. The DRE thus focuses on air emissions.

hazardous wastes slated to be treated in the hazardous waste incinerator. Based on the waste analysis data in the trial burn plan, the state regulatory agency will specify the POHCs for which DREs must be calculated during the trial burn. POHCs are selected based on their high concentration in the waste stream to be processed or the greater difficulty of destroying them in comparison to other waste stream constituents. If the unit achieves the required DRE for the POHCs, it is presumed that it will achieve the same or better DRE for all other easier-to-burn organics in the waste streams covered in the trial burn plan. At least one POHC is selected for each waste stream.

After completing the trial burn in accordance with the trial burn plan, a hazardous waste facility submits the results along with all data collected during any trial burn. Based on the results of the trial burn, the state agency sets the incinerator’s operating parameters in the final (or modified) RCRA permit. For the purposes of allowing a hazardous waste incinerator to operate following completion of the trial burn, and prior to any final modifications of the permit conditions to reflect the trial burn results, the agency may establish temporary permit conditions. These conditions may include, but are not limited to, setting waste feeds and operating conditions (such as feed rates) that allow operation prior to issuance of the final permit.

The RCRA permits for all baseline system chemical agent disposal facilities prohibit the incineration of any chemical agent or any waste containing chemical agent for which treatment has not been successfully demonstrated through a trial burn. An individual trial burn plan for each different chemical agent must be submitted by the facility’s management for each of its incinerators and is considered as a request for a major permit modification. Agent-specific trial burn plans must be approved by the state agency prior to the start of the shakedown period for the respective trial burns. RCRA permit conditions preclude chemical agent disposal facilities from feeding more than one agent at a time into the incinerators. Thus, unlike a commercial treatment, storage, and disposal facility (TSDF), which can obtain approval to process many different waste streams in one trial burn, at the chemical agent disposal facilities, a separate trial burn is conducted for each individual agent.

Under RCRA regulations, performance data from one incinerator can be submitted in lieu of conducting a trial burn on a second incinerator. The permit submittal to accomplish this is similar to that described above and requires the following (40 CFR 270.19(c)):

  • A detailed engineering description of the proposed incinerator and the incinerator from which previous trial burn data are being provided,

  • An analysis of each waste,

  • A detailed description of sampling and monitoring procedures,

  • A description of the results of the previous trial burn from which data are being provided,

  • Planned procedures for normal and off-normal operating conditions, and

  • Any other relevant information.

The Chemical Materials Agency (CMA) and the state regulators have not used the data-in-lieu-of-a-trial-burn mechanism provided for by RCRA, with the exception of twice at the Tooele Chemical Agent Disposal Facility (TOCDF). This resulted from an understandable desire to be conservative in managing risks given the initial lack of experience with baseline system incinerators, and the learning curve needed by both the chemical agent disposal facility staff and the state regulatory staff. Most regulators told the committee they would consider such an approach and, in at least one case, said they anticipated such an approach would be pursued.

Toxic Substances Control Act

The EPA has issued a “national permit” to the U.S. Army’s chemical agent disposal facilities that governs the disposal of polychlorinated biphenyls (PCBs) under TSCA. The EPA’s regional administrator or the director of the National Program Chemical Division may determine that a trial burn must be conducted based



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