Trial Bums

RCRA incinerator regulations include adrninistrative as weU as performance standards. Administrative standards include procedures for waste analysis, inspection of equipment, monitoring, and facihty security. Steps needed to meet adrninistrative standards are outlined ia the permit apphcation performance standards are demonstrated during a trial bum. Trial bum operating conditions are included in the permit to assure ongoing compliance with the performance standards. Performance standards include destmction and removal efficiency (DRE), particulate emissions limits, products of incomplete combustion emission limits, metal emission limits, and HCl and Cl emission limits (see Exhaust CONTROL, INDUSTRIAL). 

Products of Incomplete Combustion Emission Limits. Products of iacomplete combustion typically are not directly measured duting the trial bum. Instead, levels of carbon monoxide (qv) emissions are used as an iadication of combustion efficiency. High combustion efficiencies are assumed to result ia acceptable levels of products of incomplete combustion. If carbon monoxide emissions are measured at less than 100 ppmv dry basis, the standard is met. However, if emissions are greater than 100 ppmv, no more than 20 ppmv of total hydrocarbons (qv) are allowed at the iaciaerator stack duting the trial bum. 

Note that U.S. EPA regulations (under the RCRA) for hazardous waste incineration require that particulate emissions be no more than 180 mg/m3 and that hydrogen chloride removal efficiency from the exhaust gas can be no less than 99%. Therefore, trial bums to determine the maximum ash and chlorine content that a waste can handle are needed prior to issuance of a permit. 

Each time a CERCLA incinerator is relocated, ATSDR recommends that it be retested. A less rigorous trial bum may be appropriate if the incinerator has successfully passed a full trial burn on similar wastes at another site. 

Trial bums, with appropriate stack sampling and analysis, and subsequent continuous emissions monitoring are conducted to demonstrate that the incinerator performs as specified. 

The purpose of a hazardous waste incinerator permit is to allow a new hazardous incinerator to establish conditions including, but not limited to, allowable waste feeds and operating conditions that will ensure adequate protection of human health and the environment. The incinerator permit covers four phases of operation pretrial bum, trial bum, posttrial burn, and final operating conditions. 

The trial burn can be seen as the test drive of the incinerator. It is the time when the owner/ operator will bring the unit up to operational readiness, monitor the key operating conditions, and measure the emissions. The trial burn test conditions are based on the operating conditions proposed by the permit applicant in the trial bum plan submitted to U.S. EPA for evaluation. U.S. EPA establishes conditions in the permit necessary to conduct an effective trial bum, meaning that the burn will be representational of the incinerator s intended day-to-day operation and will yield meaningful data for analysis. 

The posttrial bum period is the time for U.S. EPA to evaluate all of the data that were recorded during the incinerator s trial burn. To allow the operation of a hazardous waste incinerator following the completion of the trial bum, U.S. EPA establishes permit conditions sufficient to ensure that the unit will meet the incinerator performance standards. This posttrial burn period is limited to the minimum time required to complete the sampling, analysis, data computation of trial bum results, and the submission of these results to U.S. EPA. 

In addition, the trial bum process for interim status incinerators is different from that discussed previously in this chapter. As interim status units were already in operation on the effective date of the regulations, the facility would submit their trial bum plan for approval without ceasing operation. Once this plan is approved, the facility would conduct the trial bum test (or submit data in lieu of the trial bum) and continue operating under interim status until the final permit is issued. 

The pretrial burn phase of the permit allows the BIF to achieve the state of operational readiness necessary to conduct the trial burn. The pretrial burn permit conditions are effective for the minimum time (not to exceed 720 h) required to bring the BIF to a point of operational readiness to conduct a trial bum. This phase is often referred to as the shakedown period. 

Interim status furnaces are required to comply with all of the performance standards with the exception of the DRE. In addition, U.S. EPA established special interim status requirements for industrial furnaces to ensure adequate combustion of hazardous waste until more stringent, permitted conditions could be established through completion of the facility s trial bum. These conditions include minimum temperatures, assurance of adequate oxygen, and continuous hydrocarbon monitoring. 

C2-022 Performance of halogenated-plastics trial bum April 2000 Approved... 

Comparison of the 1992 and 1999 Trial Bum Results, 9 Processing of 4.2-Inch HD Mortar Shells Through the MPF, 10 Observations Based on HD Operations at JACADS, 10 Findings and Recommendations, 12... 

More than 95,000 mustard projectiles were successfully processed in the MPF at JACADS. A 1999 trial bum of the JACADS MPF demonstrated a DRE of 99.9999 percent for agent. This suggests that the modified baseline process, in which munitions are charged to the MPF, can destroy the mustard agent munitions at Pueblo Chemical Depot if the MPF can be shown to handle frozen projectiles safely and effectively. The MPF is a crucial component of the modified baseline process, and its design and size will be critical it has been expanded from the three-zone configuration used at JACADS to a four-zone configuration for Pueblo. 

In the 1999 trial bum with mustard munitions at JACADS, emissions of mercury and cadmium exceeded regulatory standards. Newer facilities are equipped with a PFS, which would also be used at Pueblo. This system may be sufficient to bring the emissions to regulatory levels. Tests of such a system are planned in the near future. 

As Table 2-1 shows, the treatment of the mustard agent (HD) resulted in stack concentrations, DRE, operating temperatures, carbon monoxide concentrations, stack particulate concentrations, and hydrogen chloride emissions that were all within required limits for all four test mns. At the time the trial bum report was prepared, no limits had been established for metals. However, the report notes that the measured concentrations were very close to the detection limits in all cases (U.S. Army, 1992). It is not clear whether the low concentrations were due to low metals content in the agent stream or to the effective removal of metals during processing. 

TABLE 2-1 Summary of 1992 Trial Bum Tests for the Treatment of HD Ton Containers in the MPF at JACADS... 

The principal differences between the 1992 and 1999 trial bums were the rates of agent loading and the types of containers processed. In 1992, agent was introduced to the MPF in a single ton container that had been punctured in 1999, agent was introduced in a tray of 96 projectiles filled to... 

TABLE 2-4 Results of the 1999 Trial Bum of Mustard-containing Projectiles at JACADS... 

TABLE 2-5 Comparison of Limits from the JACADS RCRA Permit and Results of 1992 and 1999 Trial Bums... 

Emission Parameter 1998 Permit Limit 1992 Trial Bum 1999 Permit Level... 

TABLE 2-6 Comparison of Selected Emissions (including those exceeding permit limits) for JACADS Trial Bums... 

NOTE 1992 trial bum data were reported in micrograms per dry standard cubic meter (dscm) of stack gas. 1998 standards and 1999 trial bum data were reported in grams per second. 1999 stack gas volume was reported, after computation, at 3.96 dscm per second. 1992 stack gas volume, after computation, was reported to be 2.90 dscm per second. To facilitate comparison, 1992 micrograms per dscm were multiplied by 1999 stack gas volume per second times E-06. This converts the 1992 unit contaminant levels to total grams per second for die 1999 stack gas volume. 

Exceeds 1998 limits. The analytical data are the averaged results from four different trial bums conducted in 1999. For both mercury and cadmium, in three of die four analyses, die levels were below the detection limit. However, in one case for each metal, die measured levels were above the detection limits and in excess of die MACT standard. 

Emissions of cadmium and mercury in excess of standards were measured during the 1999 JACADS trial bum. 

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