Trial burn

USATHAMA) completed a trial burn of explosive, contaminated soil in a rotary kiln (Noland, 1984). Soil contaminated from red and pink water lagoons was successfully burned. A transportable rotary kiln yrstem was set up. The technology by Therm-All, Inc., had been used in industry for destruction of solid wastes. The normal screw feed system was not used, due to fear of a soil explosion during the extruded plug feed process. Therefore, the soil was placed in combustible buckets and individually fed by a ram into the incinerator. The feed rate was 300 to 400 Ib/hr and the operational temperature was 1200° to 1600°F in the kiln and 1600° to 2000°F in the secondary chamber. 

Some considerations relevant to public health concerns about modern and effective incineration systems have been described. However, local health officials and citizens of communities with hazardous waste incinerators have expressed to ATSDR their concern that they may not be able to judge a good operation, or that, once the initial trial burns and inspections are completed, the system may not be operated in the same manner as during the testing phase. Citizens have also expressed concern that burning rates will be exceeded or monitoring systems will be overridden. 

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. 

The pretrial bum phase of the permit allows the incinerator to achieve a state of operational readiness necessary to conduct the trial burn. The pretrial bum permit conditions are effective for the... 

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. 

After reviewing the results of the trial burn, U.S. EPA will modify the permit conditions again, as necessary, to ensure that the operating conditions of the incinerator are sufficient to ensure compliance with incinerator standards and protection of human health and the environment. Owners/ operators of incinerators must comply with the final permit conditions for the duration of the permit, or until the permit is modified. 

While most incinerators must undergo a trial burn, it is possible for a facility to submit extensive information in lieu of the trial burn. U.S. EPA believes that most combustion units will need to conduct trial burns in order to develop operating conditions that ensure compliance with the performance standards. Data submitted in lieu of the trial burn, therefore, must originate from a unit with a virtually identical design that will burn wastes under virtually identical conditions (i.e., located at the same facility). 

During operation, the owner/operator of an incinerator must conduct sufficient waste analyses to verify that the waste feed is within the physical and chemical composition limits specified in the permit. This analysis may include a determination of a waste s heat value, viscosity, and content of hazardous constituents, including POHCs. Waste analysis also comprises part of the trial burn permit application. U.S. EPA stresses the importance of proper waste analysis to ensure compliance with emission limits. 

The BIF must achieve a DRE of 99.99% for each POHC in the hazardous waste stream during the unit s compliance test, known as the trial burn.5 This means that for every 10,000 molecules entering the unit, only one molecule of the POHC is released to the atmosphere. In addition, due to an increased threat to human health and the environment from dioxin, the required DRE for POHCs in dioxin-bearing wastes has been established at 99.9999%, or one released molecule for every 1 million burned. It is important to note that this DRE standard applies only to permitted units. 

An owner/operator wishing to operate a new hazardous waste BIF is required to obtain an RCRA permit before beginning construction of the unit. The purpose of this permit is to allow the new BIF to establish operating conditions that will ensure adequate protection of human health and the environment. The BIF permit process consists of four operational phases pretrial burn, trial burn, posttrial burn, and final operating conditions. 

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. 

While most BIFs must undergo a trial burn, it is possible for a facility to submit extensive information in lieu of the trial burn. U.S. EPA believes that most combustion units will need to conduct... 

Until U.S. EPA calls in the facility s Part B permit application, where precise permit conditions will be established through a trial burn, owners/operators of interim status BIFs must ensure compliance with emission standards by showing certification of precompliance and certification of compliance. As the deadlines for these certifications have already passed, all interim status BIFs, except for possible extenuating circumstances, should be in the compliance stage. 

As mentioned above, interim status BIFs must be operated much in the same way as those facilities with permits. As with permitted BIFs, owners/operators of interim status BIFs must comply with all applicable TSDF regulations in Part 265. In addition, because interim status facilities have not yet conducted trial burns to ensure compliance with the standards, U.S. EPA has placed some restrictions on their use and what types of hazardous waste these facilities may burn. These restrictions are discussed below. 

Ananth, K. P. Gorman, P. Hansen, E. Oberacker, D. A. "Trial Burn Verification Program for Hazardous Waste Incineration," Proc. 8th Annu. Res. Symp. Incineration and Treatment of Hazardous Waste, EPA-600/9-83-003, 1983. 

The capital cost for construction and initial testing of a single 25,000 ton a year transportable AER is approximately 4 million, not including permits and trial burns. With six units, it would require approximately 3.5 years to treat 382,000 m of sediment. Including dredging and transport for treatment and redeposition or treated sediments the overall cost estimate would equal 829 to 942/m2 (D13468J, p. 53). 

In 1993, the vendor estimated procurement and construction costs of a full-scale (1000 kg/hr) PHP system for the treatment of mixed and hazardous wastes would be approximately 2 million. The largest development costs are associated with U. S. Environmental Protection Agency (EPA) quality trial burn testing and radioactive demonstration testing. Permitting costs are expected to be similar to that required for an incinerator system (D12887U, pp. 5-6). 

The analytical data in Table 2-4 are the averaged results from four different trial burns conducted in 1999. For both mercury and cadmium, in three of the four analyses, the levels were below the detection limit. However, in one case for each metal, the measured levels were above the detection limit and in excess of the MACT standard, which is probably the reason the EPA showed noncompliance. 

U.S. Army. 1999b. JACADS Metal Parts Furnace 4.2-inch HD Mortar Projectiles Trial Bum Report. Vol. I, Exhibit 1. MPF Agent HD Trial Burn... 

Amtest. State of Washington, Department of Ecology. Rubber Tire Chip Trial Burn. Holnam Incorporated Industries. Stack Testing and Chemical Analysis. October 15-19, 1990. 

Anniston Trial Burn Experience, 27 Pine Bluff Trial Burn Experience, 27 Umatilla Trial Burn Experience, 27 Tooele Trial Burn Experience, 28... 

Comparison with Trial Burn Experience in Commercial Industry Operations, 28 Health Risk Assessments, 32... 

Typical Trial Burn Critical Emissions and Performance Standards, 25... 

Completed and Still-Scheduled Trial Burns Across Operating Chemical Agent Disposal Facilities, 27... 

Trial Burn Data for Certain Industrial Facilities and CMA in the 1990s, 29... 

Comparison of Trial Burn Experience at Industrial Facilities and UMCDF, 30... 

The committee was also asked to evaluate the trial burn practices at the incineration-based facilities and compare them with similar practices in industry. Each Chemical Materials Agency (CMA) incineration facility has several types of incinerators and each has been required, by permit, to carry out a surrogate burn on all of its furnaces after start-up and before feeding any agent. A surrogate trial burn is required to demonstrate the ability of the unit to achieve a 99.9999 percent ( six nines ) destruction and removal efficiency and unit operability. They have then been required to carry out a trial burn with each agent. After the trial burn, the feed rates are reduced to 50 percent until the trial burn data... 

While industrial practice requires a trial burn and a facility may not operate until the data are accepted, industrial facilities obtain approval to process many different waste streams based on a single trial burn. In special situations, particularly with toxic materials such as polychlorinated biphenyls, both a surrogate burn and a trial burn would be required. RCRA regulations offer the option of allowing the use of data from another facility, under certain conditions, in lieu of a trial burn. However, industry has used this mechanism at only a few sites with similar units. It has been used twice by the CMA for the Tooele, Utah, disposal facility. The CMA should pursue this mechanism with the respective regulatory authorities. The committee believes that chemical agent disposal facilities are treated similarly to industrial facilities with respect to the conduct of trial bums. 

---