Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements (2007) / Chapter Skim
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2 Trial Burns, Compliance Testing, and Health Risk Assessments
2 Trial Burns, Compliance Testing, and Health Risk Assessments
Pages 21-35
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From page 21... ...
Some ash may be carried through the incinerator as small particles along with the gases. The EPA's principal measure of incinerator perfor- 1The RCRA permit life for the chemical agent disposal facilities mance is destruction and removal efficiency (DRE)
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From page 22... ...
. This resulted from an of allowing a hazardous waste incinerator to operate understandable desire to be conservative in managing following completion of the trial burn, and prior to any risks given the initial lack of experience with baseline final modifications of the permit conditions to reflect system incinerators, and the learning curve needed by the trial burn results, the agency may establish tempo- both the chemical agent disposal facility staff and the rary permit conditions.
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From page 23... ...
Sources can use any combination of con- To remove the duplicative air emission/combustion trol technologies to achieve the emission standards. requirements from a RCRA permit prior to its expira The MACT rule has more stringent emissions stan- tion and reissuance, a chemical agent disposal facility dards than RCRA for dioxins and furans, including would have to request a major RCRA permit modifica
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From page 24... ...
agency approval under either a permit application or Thus, all chemical agent disposal facilities with a permit modification application must contain the followbaseline system hazardous waste incinerator have com- ing (40 CFR 270.62) : pleted STBs and ATBs for each agent that has been or is currently being treated.2 The facility permits have been • A detailed description and analysis of each waste, • A detailed engineering description of the 2As explained in more detail in the following sections, an STB incinerator, uses a surrogate material to represent the chemical agent or sur • A detailed description of sampling and monitorrogate POHC.
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From page 25... ...
According to 40 CFR 63.1207(f) , a MACT CPT must include Trial Burn Phases • An analysis of each feed stream, including haz- The following information from the RCRA permit ardous waste and other fuels, for the Umatilla Chemical Agent Disposal Facility • A highly detailed treatment of certain organic (UMCDF)
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From page 26... ...
This is a lengthy process, and plete combustion, such as carbon monoxide, do in some instances, the disposal facilities have com not exceed the specified limit, pleted destroying a given chemical agent without • Establish maximum metal feed rates, and ever obtaining final approval for 100 percent feed rate • Establish maximum surrogate feed rates. operations.
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From page 27... ...
CHEMICAL AGENT DISPOSAL FACILITY ate at 50 percent of the ATB feed rate for 30-45 days. ExPERIENCE TO DATE WITH TRIAL BURNS ANCDF then operates at 75 percent of the ATB feed rate until the trial burn report is reviewed and approved, The committee obtained trial burn information for which takes about 6 months.
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From page 28... ...
Army's since conducted separate ATBs for each of the stockpile chemical agent disposal facilities. chemical agents stored at Deseret Chemical Depot.
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From page 29... ...
In other respects, the general conditions during operations as they were during the trial burn. governing the need for and conduct of trial burns at In contrast, at chemical agent disposal facilities, commercial incinerators and chemical agent disposal trial burns have been conducted whenever an operating facilities are quite similar.
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From page 30... ...
; 17 (actual) 10 3-17 Trial burn plan submittal to end of trial burn 15 8 6-10 End of trial burn to trial burn report submission 3 3 2-3 NOTE: CRWI, Coalition for Responsible Waste Incineration; and UMCDF, Umatilla Chemical Agent Disposal Facility.
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From page 31... ...
The Chemical Materials All commercial TSDFs and all chemical agent disposal facilities must adhere to permit operating Agency should vigorously pursue the application of the parameters, including feed rates, temperatures, and Resource Conservation and Recovery Act provision for other combustion criteria. In addition, all commercial using trial burn data from other similar chemical agent TSDFs and chemical agent disposal facilities must disposal facility incinerators in lieu of conducting trial meet both the RCRA and the MACT air emission burns for additional agents.
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From page 32... ...
Site-specific HRAs have been performed for the vast majority of commercial hazardous waste incinerators15 HEALTH RISk ASSESSMENTS and for all of the chemical agent disposal facilities. The HRAs are a means of estimating the potential for an data necessary to conduct an HRA are obtained from adverse effect on a select population upon exposure to trial burns (40 CFR 271.19, 264.342, and 264.343)
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From page 33... ...
Although the currently applicable Chemical Agent Disposal Facility are similar to the state of Indiana requirements for a risk assessment of gaseous emissions from a commercial PCB incin erator. These requirements, which are similar to EPA 16As mentioned earlier, if the HRA is to be developed prior to guidelines for health risk assessments, are a reasontrial burns at either industrial facilities or chemical agent disposal facilities, data from comparable facilities or the MACT standards able approach to assessing the health risk posed by the can used in the risk calculations.
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From page 34... ...
The commercial vehicle accident rate per chemical agent disposal facilities, a transportation risk ton-mile value was multiplied first by 0.59 and then analysis can lead to insights for increased risk mitiga- by 0.013 to account for the number of ton-miles for tion commensurate with the levels of residual agent for-hire commercial vehicles and for Class 6 poisons, contamination. Risk mitigation considerations include respectively.
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From page 35... ...
Army Newport (Indiana) Project: Executive Newport Chemical Agent Disposal Facility at the Newport Chemical Summary, March 3.
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