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--> 4 Systemization Environmental Performance Environmental performance of the Tooele Chemical Agent Disposal Facility (TOCDF) is controlled by compliance with the Resource Conservation and Recovery Act (RCRA) permit. This chapter describes the status of the permit and compliance testing relevant to its requirements. TOCDF Permitting Requirements The TOCDF operates under RCRA permit UT5210090002 issued pursuant to the delegation of authority to the Utah Division of Solid and Hazardous Waste (DSHW) under the Utah Administrative Code, section 315 (R315). Under the requirements of this permit, the incinerator system must demonstrate an ability to treat hazardous waste in a way that protects human health and the environment. Section 3004 of RCRA (1976) requires performance standards establishing the levels of environmental protection that hazardous waste treatment, storage, and disposal facilities must achieve and mandates the criteria against which applications for permits must be measured. The TOCDF has five incinerator systems that have been scheduled for surrogate testing. These incinerators include the deactivation furnace system, the metal parts furnace, two liquid incinerators (liquid incinerator #1 and liquid incinerator #2), and the dunnage furnace. The purpose of the surrogate trial burns to demonstrate the ability of each incinerator system to destroy selected compounds to a destruction removal efficiency (DRE) of 99.9999 percent (6-nines). The compounds are selected to meet criteria specified by the Utah DSHW. The surrogate trial burn for liquid incinerator #1 was conducted between June 30 and July 7, 1995. The deactivation furnace system surrogate trial burn took place in September 1995. Data from these tests must be analyzed and the 6-nines DRE demonstrated prior to initiation of agent incineration in these two incinerator systems. Surrogate trial burns for the remaining three incinerator systems are scheduled to coincide with the use of these systems in agent-destruction operations. Surrogate Trial Burns Liquid Incinerator #1 The surrogate compounds were selected to meet the criteria specified by the DSHW (Downs, 1994). For the surrogate trial burn of liquid incinerator #1, the principal organic hazardous constituents (POHCs) that meet the criteria specified are 1,2,4-trichlorobenzene and tetrachloroethylene. After the successful demonstration of the RCRA permit-required DRE of 99.9999 percent for the defined POHC mixture, the TOCDF will be allowed to incinerate other permitted liquid wastes in liquid incinerator #1. The Army had concerns about its ability to demonstrate simultaneously 99.9999 percent DRE for both compounds in a mixed feed for two reasons. First, little is known about the potential intermediate combustion products of either compound and their potential interferences. Second, the feed quantities are limited by the thermal capacity of the system, i.e., less of each compound can be fed into the system in a mixed feed than if each compound were fed in separately. Nevertheless, the Army believed that the liquid incinerator #1 system had the capability of demonstrating the DRE requirements for the POHC mixture. Thus, the surrogate trial burn was conducted with a two-POHC mixture being, fed into the incinerator system. The requirements of the surrogate trial burn are to meet or exceed the RCRA limits in 40 CFR 264.343 and to demonstrate DRE for single compounds (not DRE for a two-POHC mixture); if the mixed-feed surrogate trial burn had failed to demonstrate a DRE of 99.9999 percent for either 1,2,4-trichlorobenzene or tetrachloroethylene, a separate trial bum would have been initiated for each POHC that failed.
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--> Although only three successful demonstrations of destruction removal efficiency are required, the TOCDF conducted four POHC burns so that if one of the sample sets was lost or in any way comprised, or if the system operating conditions (including data collection) were not representative of steady-state operations, three valid runs would still be available for analysis. The liquid incinerator #1 system is designed to meet RCRA performance requirements (40 CFR Part 264). During the surrogate trial burn program, stack emission tests were conducted for oxygen, particulates, carbon monoxide, hydrochloric acid, chlorine, and POHCs. A heat content analysis was conducted on a composite POHC-feed sample once during each POHC burn. A scan of products of incomplete combustion (PIC) of the 40 CFR Part 266 Appendix VIII compounds is being made in place of a scan of POHCs for the supplemental fuel-only run. Tentatively identified compounds will be reported for the 20 largest peaks in the PIC scan. Four replicate trial burns were conducted. At the conclusion of the fourth run (before any of the results were analyzed) the test director was required to select three runs to be analyzed for the record. The samples from runs 1, 2, and 4 were chosen for analysis, although it is believed that all four runs were equally valid based on the operational data collected during the test. Samples from the third test run were not analyzed. Table 4-1 summarizes the particulate and hydrogen chloride emissions and DREs for the liquid incinerator #1 surrogate trial burns. The results indicated that the 99.9999 percent DRE was demonstrated and that particulate and HCl emission requirements were met during the test. The complete trial burn test report was submitted to the state of Utah, Department of Environmental Quality, for review and approval on August 25, 1995. The agent trial burn for liquid incinerator #1 will be done with chemical agents and must demonstrate DREs greater than 99.99 percent (DSHW requirement). Nevertheless, the Army is committed to meeting 6-nines (99.9999 percent) agent DRE for these incinerators. Deactivation Furnace System Surrogate Trial Burn The surrogate compounds for the deactivation furnace system surrogate trial burn were selected to meet criteria by the Utah DSHW (Downs, 1994). The POHCs that meet the criteria specified are monochlorobenzene (chlorobenzene) and hexachloroethane. Although only three successful demonstrations of DRE were required, the TOCDF conducted four POHC burns in the event that one of the sample sets might be lost or in any way compromised, or that the system operating conditions (including data collection) would not be representative of steady-state operations, in which case the affected burn would not be considered a valid, reportable burn. All analytical data from all valid runs were reported. No run was or could be invalidated solely because the target DRE was not achieved. The deactivation furnace system is designed to meet RCRA regulation performance requirements (40 CFR Part 264). During the surrogate trial burn program, stack emissions were tested for oxygen, particulates, carbon monoxide, hydrochloric acid, chlorine, and principal organic hazardous constituents. A heat content analysis Table 4-1 Summary of Results from the TOCDF Liquid Incinerator #1 Surrogate Trial Burn Test Run Parameter Requireda Baselineb 1 2 4 Particulates (gr/dscf) max. 0.08 0.0026 0.000415 0.000987 0.000531 HCl (lb/hr) max. 8.76 ND 0.00560 0.00156 0.00691 Tetrachloroethylene (DRE %) min. 99.9999 N/A 99.9999 980 99.9999 956 99.9999 955 1,2,4-Trichlorobenzene (DRE %) min. 99.9999 N/A 99.9999 984 99.9999 999 99.9999 940 a State of Utah. b JACADS.
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--> was conducted on a composite POHC-feed sample once during each POHC burn. A products of incomplete combustion (PIC) scan of the 40 CFR Part 266 Appendix VIII compounds was made in place of POHCs for the supplemental fuel-only run. Tentatively identified compounds were to be reported for the 20 largest peaks in the products of incomplete combustion scan. Following the deactivation furnace system surrogate trial burn, the Toxic Substances Control Act research and development trial burn will require a demonstrated DRE of 99.9999 percent or better of the polychlorinated biphenyls in the rocket shipping and firing tubes. The Toxic Substances Control Act trial burn was scheduled for late November or early December 1995.
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