APPLICATION FORCERTIFICATION TO INCINERATE

HAZARDOUS WASTES ^F020 THROUGH F028 ^

0

MAY 15. 1985

EXHIBIT "B"

€<ensco^environmental

servicesk 0330C035

TABLE OF CONTENTS

Page

A . I n t r o d u c t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . 1

B. Trial Burn Plan . . . . . . . . . . . . . . . . . . . . . . . . 3

1. Engineer ing D e s c r i p t i o n . . . . . . . . . . . . . . . . . . 3

, a. M a n u f a c t u r e r . . . . . . . . . . . . . . . . . . . . . 3

b. Type . . . . . . . . . . . . . . . . . . . . . . . . . 3

c. R o t a r y Xi In . . . . . . . . . . . . . . . . . . . . . . 7

C o n s t r u c t i o n M a t e r i a l s and Dimens ions . . . . . . . . 7

Waste Feed Sys tems . . . . . . . . . . . . . . . . . . 8 (^r--

Burner i\.nd Nozzles . . . . . . . . . . . . . . . . . . 9 ^

'Aux i l i a ry Fuel Sys tem . . . . . . . . . . . . . . . . . 9 —>

Ind ica to r and Control Devices . . . . . . . . . . . . 10 ^

A u t o m a t i c Waste Feed Cu t -o f f Controls . . . . . . . . 11

d. Secondary C o m b u s t o r . . . . . . . . . . . . . . . . . 15

Cons t ruc t ion M a t e r i a l s and Dimensions . . . . . . . . 20

Was te Feed System . . . . . . . . . . . . . . . . . . 21

Burner and N o z z l e . . . . . . . . . . . . . . . . . . . 21

Aux i l i a ry Fuel Sys tem . . . . . . . . . . . . . . . . 22

Indicator and Control Devices . . . . . . . . . . . . 22

A u t o m a t i c Waste Feed C u t - o f f Con t ro l s . . . . . . . . 24

e. A i r P o l l u t i o n Cont ro l Train . . . . . . . . . . . . . 24

Quench S y s t e m . . . . . . . . . . . . . . . . . . . . 25

Packed Tower . . . . . . . . . . . . . . . . . . . . . 27

Ejec te r Scrubber . . . . . . . . . . . . . . . . . . . 28

Stack . . . . . . . . . . . . . . . . . . . . . . . . 30.

0330C036

f . Contro l Room and Labora tory . . . . . . . . . . . . . 31

g. A u x i l i a r y C o m p o n e n t s . . . . . . . . . . . . . . . . . 32

W a s t e Heat Boi le r and Steam Drum . . . . . . . . . . . 32

Boi le r Make-L'p Wate r T rea tmen t System . . . . . . . . 33

Ash Removal System . . . . . . . . . . . . . . . . . . 33

E f f l u e n t N e u t r a l i s a t i o n and Concent ra t ion System . . . 33

Liqu id -Was te Feed and B l e n d i n g T a n k ( s ) . . . . . . . . 3-;

Clean Fuel Feed Tanks ( s ) . . . . . . . . . . . . . . . 34

Solid Waste Prepara t ion Systeir. . . . . . . . . . . . . 34

2. Test Protocol and Schedule . . . . . . . . . . . . . . . . 36

a. Purpose . . . . . . . . . . . . . . . . . . . . . . . 36

b. Test Burn R a t i o n a l e . . . . . . . . . . . . . . . . . 36

c. W a s t e Charac te r i s t i cs . . . . . . . . . . . . . . . . 39

d . Test Procedures - Test 1 . . . . . . . . . . . . . . . 41

e. Test P rocedures - Test 2 . . . . . . . . . . . . . . . 43

f . Sampling and Ana ly t i ca l Procedures . . . . . . . . . . 50

g. M a l f u n c t i o n Procedures . . . . . . . . . . . . . . . . 51

C . Pre-Trial Burn Plan . . . . . . . . . . . . . . . . . . . . . . 55

1. Pro-Trial Burns 1, 2 and 3 . . . . . . . . . . . . . . . . 55

2. Pre-Trial Burns 4 and 5 . . . . . . . . . . . . . . . . . . 58

3. Pre-Trial Burns 6 and 7 . . . . . . . . . . . . . . . . . . 58

D . C e r t i f i c a t i o n . . . . . . . . . . . . . . . . . . . . . . . . . 60

Appendix I - Stack E m i s s i o n s M o n i t o r i n g

Appendix I T - S ta tement , of W o r k fo r Stack Gas Test ing

A p p e n d i x of Separa te Set of Drc'.w'lp.gs

Srawin;;' 1 - Typical Ai':';ini;c:r.t!!iL of MWP-2000

Drawing 2 - Rotary Kiln - Pliin <ind Sect ions

Drawing 3 - P&ID - Rot;ii-y Kiln ;ind W.iste Feed Systems

Drawing 4 - Secondary Combustor - Plan and Sections

Drawing 5 - P&ID - Seccinilary Combustor and WasLy Feed Systems

Drawing 6 - Quench System and Packed Tower - Plan and Sections

Drawing 7 - Ejector Scrubber and Stack - Plan and SectionsDrawing 8 - P&ID - Air Pollution Control Train

Drawing 9 - Control Pup.el Layout

03SOCG38

A . INTRODUCTION«

This document is ?.." application for certification toincinerate, under 40 CFR 2 6 5 . 3 3 3 ( a ) , E?A Hazardous Wastes F020, F021,F022, F023, F026, . F027, and/or soils, wustewaters and other mixturescontaminated with these wastes in Ensco Environmental Services' Modular r--Waste Processor (MWP-2000) currently located at Ensco's hazardous waste ^

t-incineration facility at El Dorado, Arkansas. As required by 40 CFR Q2 G 5 . 3 8 3 ( b ) ( 1 ) , this application presents the information required by 40

CFR 2 7 0 . 1 9 ( b ) and 270.62 with respect to an engineering description of

the MWP-2000 and a trial burn plan to demonstrate this system. When thetrial burns described in this application are completed and test

results are available, Ensco Environmental Services (Ensco) will revise

this application to include the remaining information required by 40

CFR 2 7 0 . 1 9 ( b ) and 2 7 0 . 6 2 .This application also presents information required by 40 CFR

2 7 0 . G 2 ( c ) in order to obtain approval to conduct seven pre-trial burnsto verify the readiness of the MKP-2000 fur demonstration testing.These pre-trial burns will encompass less than 140 hours of burn time

w i t . ! ' , s i mnlu'l. cd w;.iste streams.

The MWP-2000 is a multi-unit waste incineration system

designed to be moved from site to site to perform on-site incineration

0

i 03200039

of PC3 wastes, including soi ls and other mate r ia l s coi . -aminated with

P C B ' s . Two such systems have been f ab r i ca t ed . The f i r s t system is

c u r r e n t l y in operation in Hi l l sborough C o u n t y , F l o r i d a , where it is

success fu l ly inc inera t ing o i l - con tamina l ed so i l s , sludges and waters

bein^ removed f r o m impoundments to clean up a non-hazardous-waste

contamina ted site. The second sys tem is c u r r e n t l y located at El Dorado,

Arkansas , where it is being reudied for a PCR demonstration burn when

such a burn can be scheduled wi th E R A .

Ensco be l ieves thaL the y.WP-2000 also is fu l ly capable of

inc ine ra t ing F020 through F027 wastes and m a t e r i a l s contaminated wi th

these wastes. Given that the amendments to the RCRA regulations \Qr--\opromulgated on January 14, 1985, provide the oppor tun i ty to establish

interim status for the system and seek a certification for the burning "^0

of these wastes, Ensco wishes to proceed with the trial burn o

demonstration requested in this application prior to proceeding with a

PCB demonstration trial burn. To perfect interim status and enableproceeding with this certification application, Ensco has filed a

notification for the MWP-2000 and will submit a Part A application forthe system before July 14, 1985.

Ensco's contact for communications with respect to thisapplication i s :

James H . Hicks

Ensco Environmental Services,

Pyrotech Division

First Tennessee Bunk, 3rd. FloorFranklin, Tennessee 37064615-794-1351

032CCC40

B . TRIAL BURN PLAN

1 . ENGINEERING DESCRIPTION

la. MANUFACTURER

The MWP-2000 has been designed and fabricated by the PyrotechDivision of Ensco Environmental Services (Ensco) at its facility atWhite Bluff, Tennessee.

!•"-0

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The MWp- 2000 is a modular incinerator system designed todestroy/detoxify s o l i d , ' semi-solid and/or liquid PCB wastes. Most ofthe components of the system are installed on flat-bed trailers tofacilitate the movement of the system from site to site to perform

on-site cleanup of contaminated soils and other wastes.Drawing 1 shows the general arrangement of the system as it

typically will be installed for an on-site cleanup job requiring theincineration of a combination of solid, semi-solid and liquid wastes.

Figure 1 shows a schematic diagram of the system as it will beconfigured for such jobs. As these figures show, the principal

components of the system are:

Rotary kiln and its waste feed systems.

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Secondary combustnr and its waste feed systems.

Air pollution control train consisting of a quench system,packed tower, ejector scrubber, and stack.

^Control room and laboratory.

Auxiliary components of the system are:

Waste heat boiler and steam d r u m .

Boiler make-up water treatment system.

Ash removal system.

Effluent neutralization and concentration system.

Liquid and sludge waste holding and blending system.

Clean fuel holding t a n k ( s ) .

Solid waste preparation system.

These auxiliary components are discussed and illustrated in this

section to provide a complete description of the system as it typicallywill be configured. It should be recognized that these components maybe varied to fit the peculia;-1ties of each j o b . For example, on some

jobs the solid waste preparation system may consist of a shredder; on

other j o b s , a drum opening and emptying system: and on still other

jo b s , no special system at all utiu.'r th.in a front-end loader to place

materials into the hopper or onto the conveyor of the solid waste feed

system. As another example, on some jobs the liquid and sludge wasteholding and blending system may be a series of tanks: some serving asholding tanks to segregate and hold different types nf wastes ( e . g . ,solvents, aqueous wastes and pumpabie sludges) and others serving asblending and/or day tanks. On other job s , the liquid and sludge wasteholding and blending system may be a single tank, a tank trailer or animpoundment. As a final example, many jobs will require the effluent

neutralization and concentration system to manage the acid effluentsproduced by the burning of highly chlorinated wastes. Other jobs will

not require such a system. In short, the modular design of the system

enables it to be tailored to the particular physical/chemical

characteristics of the waste to be incinerated.The modular design of the system also enables some variation

in the configuration of the principal components to match the special

characteristics of the j o b . For example, when only liquid wastes are to

be burned, the rotary kiln may not be used and all the wastes will befed to and incinerated in the secondary combustor. At the other

extreme, when the job involves detoxification of large volumes ofcontaminated soils, two rotary kilns mriy be used and be served by asingle secondary combustor and air pollution control train. On stillother j o b s , where large voluinf:s of fined-grained solids ( e . g . ,fine-grained sandy soils) are being burned in the rotary kiln, a

cyclone or other particulate remov.tl sysLem m.iy be installed between

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03SOC044

the rotary kiln and the secondary cumbustor to eliminate tlie carryoverof solids into the combustor.

The foregoing description of the flexibility of the MWP-2000is provided to indicate Chat the system may take on differentconfigurations for different jobs to perform each job in the mostefficient and effective manner. The configuration shown in thisdocument (see Figure 1 and Drawjng 1 ) is that which Ensco believes willbe required to incinerate accumulated wastes at the Vertac plant site.This same configuration will be used in the trial burn and thepre-trial burns described in this document.

1 C . ROTARY KILN AND WASTE FEED SYSTEMS

The rotary kiln is designed and intended to be used primarilyto burn solids wastes, including contaminated soils. However,non-chlorinated liquid wastes can be burned in the kiln by beinginjected as a fuel through the burner nozzle. Wastewater and pumpablesludges can be introduced through designated injection nozzles andthereby be burned in the kiln. Drawing 2 provides plan and sectionviews of the kiln and its solid waste feed system.

CONSTRUCTION MATERIALS AND DIMENSIONS The rotary kiln is acarbon steel cylinder mounted horizontally on a flat-bed trailer. The

first ten feet of the kiln (flame zone) is lined with 2 1/4" ofinsulating brick and 6 " of fire brick. The remaining length of the kilnis lined with 6 " of fire brick. The resulting interior dimensions are:flame zone I . D . - 5 ' 3 3 / 4 " ; remaining I . D . - 5 ' 6 " ; length - 3 0 ' ;

effective volume - 697 c f . A 6 " high refractory dam is located at thedownstream end of the k i l n , at each 10' Interval upstream, and at theupstream end. However, the heif.ht and .location of these dams may bemodified to most effectively handle the particular physical properties

of the solid or sludge wastes being burned. The kiln is mounted so that

it carr be inclined from 2 to 6 degrees. It is rotated by an

hydraulically controlled trunjon mechanism that can rotate the kilnfrom 1/2 to 2 revolutions per minute. The burner and the solids andliquid-waste feed systems are located at the higher end of the kiln C\Jwhile the gas outlet and ash drop are located at the opposite lower CO

\Dend.

WASTE FEED SYSTEMS The solid-waste feed system consists of anenclosed chain-drag or belt conveyor (depending on the physical

properties of the waste being fed) which carries wastes from the

solid-waste preparation system to a sealed hopper which discharges to aram feed. The entire system is maintained under a slight negativepressure by a blower which exhausts into the kiln. The system is

designed to feed up to 8000 pounds/hour of solid wastes into the kiln,

depending on the particular physical properties of the wastes. The

leading face of the ra,"i is water cooled and has a shearing edge to

reduce jam-ups.

The wastewater feeii system consists of a flat-spray nozzle

which introduces wnstewater ( o r water for temperature control purposes)in a horizontal spray into the kiln so that it intersects the burnerflame within the combustion zone of the k i l n . This system can deliverup to 10 gpm of wastes or watfr-r into Lhc k i l n .

^00

03300046

Liquid combustible wastes also can be delivered into the kiln

as auxiliary fuel through the burner. This feed system is decribed in a

following subsection.

The sludge feed system consists of a sludge injection nozzle

which sprays pumpable sludges Into the kiln. This nozzle Is suppliedwith steam (as needed) to atomize the sludge being sprayed into thekiln. The nozzle is served by a progressive cavity pump that candeliver up to 6 gpm of sludge into the kiln.

BURNER AND NOZZLES The kiln is equipped with a single burner N^COthat is capable of producing 14 million BTU/hour of heat when using ^

either clean fuel or liquid wastes having heating values ranging from0

6000 to 19500 BTU/lb.. The burner nozzle is designed to use either 0steam or compressed air (as needed) to atomize the fuel or wastes'beinginjected. The nozzle is designed to handle dirty fuel or wastes having

particulate sizes up to 1/8" and produces a long flame cone up to15'long and 3 1/2' in diameter at the end of the cone. Combustion air

is supplied to the burner by a single stage centrifugal blower which

can deliver up to 3200 cfm at 30" we pressure.

AUXILIARY FUEL SYSTEM The kiln burner is served by two

fuel/'WcisiR feed systems (see the P&ID in Drawing 3 ) . One system

consists of a pair of pumps and strainers and interconnecting piping.

One sot of these pumps and strainers serves as standby equipment. Thissystem is capable of delivering low viscosity fuel or waste and is

LypJcaJly used to deliver clean fuel to the kiln during start-up andwhen needed during operation. The other system consists of a pair of

03SOC047

pumps and strainers, and interconnecting piping equipped with In-lineelectric heaters to enable the delivery of highly viscous fuels orwastes to the burner. One set. of these pumps and strainers serves asstandby equipment. This system is typically used to deliver combustibleliquid wastes to the kiln through the burner. Both systems tie into acommon feed line on which is installed Lhe flow measuring and controldevices described in the following subsection.

INDICATOR AND CONTROL DEVICES Drawing 3 provides a P&ID for' i-the rotary kiln and its fuel and waste feed systems. The following

paragraphs briefly describe the indicating and control devices shown on ^•^j-

this P&ID. All of the measuring devices ( e . g . , flowmeters and othermocouples) mentioned are located on the kiln or in its outlet ductand its fuel and waste feed systems. All of the indicating devices( e . g . , digital readouts and computer monitor) and controllers arelocated, except where otherwise noted, on the control panel in thecontrol room and laboratory trailer described in a following section.The data acquisition and control computer, located on the controlpanel, is used to acquire and store selected critical measurements.Some of these measurements are instantaneously displayed on thecomputer monitor and can be printed on the computer printer. Thiscomputer is programmed to perform automatic waste cut-off (seefollowing subsection) and can be programmed to control selectedoperating functions based on the information it acquires.

Drawing 9 provides a layout: of the control panel and shows thevarious indicatiny and controllc'r devjcKS described in the followingparagraphs.

0

100320C048

K i l n outlet t empera tu re is measured by redundant p l a t i n u m -

r h o d i u m thermocouples located in the ou t l e t duct of the rotary k i l n .

One of these thermocouples is connected to a d i g i t a l readout on the

control room panel . The other is connected to the data acquis i t ion and

control computer which d i sp lays readings on the computer m o n i t o r .

K i l n skin temperatures are measured by m e c h a n i c a l thermometers

magne t i ca l ly attached to the k i l n su r face at ten-foot ho r i zon ta l

In te rva l s . These the rmomete r s are not connec ted to the contro l piinel

readouts.

K i ln pressure is measured by a pressure t ransducer located on

the out le t duct of the k i l n . This t ransducer is conneci-ed Co the data

acqu i s i t i on and control computer which d i sp lays readings on the

compute r m o n i t o r .

The k i ln f l a m e and condi t ions inside of the ki ln are moni tored

by a remote TV camera which is connected to a TV screen on the control

panel .

Fuel and/or waste feed to the k i ln burner is measured w i t h a

mass f lowmete r which sends signals to ( 1 ) the data acquis i t ion and

control computer , ( 2 ) a digital readout which provides both an

instantaneous and to ta l i zed reading , (3 ) a strip-chart recorder, and

( 4 ) a control ler which controls an electric modulat ing valve on the

comn'.on f u e l / w a s t e l ine to the b u r n e r . The c o n t r o l l e r can be operated

m a n u a l l y or au toma t i ciil l y ( u s i n g pre-progranimed setpoints) to control

f u e l and/or was te feed ra te to tlie b u r n e r .

In a d d i t i o n , the f u e l / w u s t f feed system is equipped with a

n u m b e r of p re s su re and t e m p e r , i t u r e i n d i c a l o r s ( w i t h local r eadou t s ) and

w i t h seve ra l pressure r e y u i d t o r s . I t is equipped w i t h two solenoid

LH03^0^00

110320C049

valves which are operated by the data acquisition and control computer

to autoinaticalJy shut off waste feed and open clean fuel feed wheneither combustion efficiency, stack gas oxygen concentrations or

secondary combustor outlet gas temperature falls below set values (seefollowing subsection). The system also is equipped with an electricallyoperated valve which can be shut by a low pressure switch when feedpressure falls below a set l i m i t . Finally, the feed system is equippedwith another solenoid valve which is controlled by the flame supervisor

to shut off fuel/waste feed when there is a loss of flame in the kiln.Although not shown on Drawing 3 , this same solenoid valve can be

v0operated by the low-low liquid level switch on the steam drum to shut QQ

0^}-off fuel/waste flow to the kiln when water level in the drum falls

below 25%.

Combustion air flow to the kiln burner is measured by an

annubar flow measuring device in the combustion air supply duct. This

device sends a signal to ( 1 ) the data acquisition and control computerand ( 2 ) a controller which provides a digital readout and controls amodulating butterfly valve on the combustion air supply line. Thecontroller can be operated manually or automatically to controlcombustion air flow rate to the kiln burner. A differential pressureswitch in the combustion air supply line signals the flame supervisor

to shut off a solenoid valve to prevent fuel feed 1o the burner duringstart-up when combustion air pressure is below a set l i m i t .

Supplemental air to the k ; L". is I'L'guJ ai.ed by a locally

controlled butterfly valve in the supply duct delivering this air.Compressed air Lo I;IK kiln bnrp.f.'r for u tonij nation of highly

viscous wastes or fuels is regulated by a locally controlled butterfly

00

03SCCC5012

valve. Atomizing s..eam to the kiln burner is regulated by a pressure

regulator and controlled by a locally set valve. A pressure indicator(with local readout) measures the steam pressure being provided.

Wastewater ( o r water) feed to the kiln is measured by a massflowmeter which sends signals to ( 1 ) the data acquisition and control

computer, ( 2 ) a digital readout, and ( 3 ) a controller which controls anelectric modulating valve on the wastowuter feed line to the kiln. Thecontroller can be operated manually or automatically to controlwastewater injection into the kiln. The modulating valve can be closedby the data acquisition and control computer when combustion

efficiency, oxygen concentration in the stack gases or secondarycombustor outlet temperature falls below a set value. Although not aJ

\bshown on Drawing 3 , the same modulating valve also can be operated by '^j"

0( 1 ) the kiln or combusto" fla"ie supervisor to shut off wastewater flow —^

when there is a loss of flame in either unit, or ( 2 ) the low-low liquid

level switch on the steam drum to shut off wastewater flow wlien waterlevel in the drum falls felow 25°o. Finally, the wastewater feed system

is equipped with pressure indicators with local readouts and a pressureregulator.

Sludge feed to the kiln is measured and controlled, including

automatic waste feed shut-off, in a similar manner as described above

for wastewater feed. The flow is measured by a turbine-type flow meter

and the pump motor, rathe:- thnn an electrically controlled modulating

valve, is used to control flow.

Solid waste feed through the ram feeder is not measureddirectly. Solid waste feed rates to the kiln will be determined by

measuring or estimating the loading of such waste onto the feed

1 3 03300051

conveyor or into the hupper. Control of the solid waste feed rate is

accomplished by manually setting limiting switches on the ram feed. The

data acquisition und control computer is programmed to shut off the

hydraulic system that operates the ram feeder when any of the upset

conditions delineated in the following subsection occur. Operation ofthe solid waste feed system is monitored by a remote TV camera which isconnected to a TV screen on the control panel.

As shown on Drawing 9 , indicating lights and lighted manual

control buttons on the control panel report the status of allfuel/waste/wastewater pumps, hydraulic pumps and air blowers that servethe kiln. The on/off manual switches, plus the manually orautomatically operated controllers, provide the means of fully

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operating the kiln from the control panel. 00

«

AUTOMATIC WASTE FEED CL-T-OFF CONTROLS The data acquisition and

control compute:' is programmed to automatically switch feed to theburner from waste to fuel and to simultaneously and automatically cut

off wastewater and sludge flows to the wastewater and the sludge

injection nozzles and solid waste feed through the ram feed when any of

the following conditions occurs:

A . Combustion efficiency, as measured by 100XC02/(C02+CO),

falls below 9 9 , where CO and C02, respectively, are thecarbon monoxide and carbon dioxide concentrations in the

stack gases.

B . Oxygen concentration in the stack gases falls below 3°o.

C . Secondary combustor outlet gas temperature falls below 2150degrees F .

0320GG5214

These same condi t ions cause a simultaneous automatic waste-feed

s w i t c h i n g or was te c u t - o f f to tt ie secondary c o m b u s t o r . Figure 2

i l l u s t r a t e s t h i s control p rocedure .

Stack gas analyzers In the con t ro l room and labora tory t ra i ler

cont inuous ly supply measurements of the concentrat ions of oxygen,

carbon monoxide and carbor d ioxide in the stack gases. These

measurements are t r a n s m i t t e d to the data acqu i s i t ion and control

compu te r w h i c h uses them to m o n i t o r cond i t ions A and B , above, and

e f f ec tua t e au tomat ic was te- feed s w i t c h i n g and shut-off through the

conto l devices described in the preceding subsect ion . The thermalcouple0^

in the combustor out le t duct provides the computer with the data to

m o n i t o r condi t ion C and e f f e c t a u t o m a t i c waste-feed swi tch ing and ^•

cut-off procedures. 00

The f l a m e superv isor serving the ki ln shuts off all -fuel

and/or waste f l o w s to the k i ln bu rne r when there is a loss of f l ame in

the k i l n . This automat ic shut-off procedure is i l lustrated in Figure 3.

The f l a m e supervisor serving the secondary conibustor switches

feed to the k i ln burner f rom waste to fue l and cuts off all other waste

feeds to the ki ln when there is a loss of f l a m e in the combustor .

S imu l t aneous ly , this supervisor shuts off all fue l and waste feeds to

the combus to r . This au toma t i c procedure is i l lustrated in Figure 4 .

The low-low J i q u i d level swi tch on the- s team drum sl iuts off

a l l fue l and was te feeds to the k i l n and secondary c o m b u s t o r when water

level in the d rum f c i J I s b e l o w 25°i. Th i s c i i i t o m a t i c procedure is

i l l u s t r a t e d in Figure 5.

Id . SECONDARY COMBL'STOR AND WASTE. FKED SYSTEMS

0320C05315

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VAnt rucL————i£i—«xFUEL———————————————»-AM———————————»•

r

1

—^

1^BURNER

1SECONDARYCDMBUSTOR

^

^ BUJLt-K

STEAMDRUM

^WALVaOW

AIR POLCDNLR

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N

AUTOMATIC SHUT-OFF AND FEED SWITCHING CONTROLSFOR LOSS OF DESIGNED THERMAL CONDITIONS

FIGURE 2

0 0 4 6 9 0

vArtc run-BURNER

SECONDARYCOMBUSTOR

AIR PDLUTIDNCONLRDL TRAIN

AUTOMATIC SHUT-OFT CDNTRDLSFDR LOSS DF FLAME IN RDTARY KILN

FIGURE 3

0 0 4 6 9 1

r~' -r—r •T'

WASTE VATCR-

It-UBa:-VM1E FUCL-rucL-AW

3URNER

L_ (nTM«*ULl(t[-( RAM FEEDERlagvc I '————————

KO-N

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BURNERSECONDARYCDMBUS'OR

AIR POLUTiaNCDNLRDL TRAIN

AUTOMATIC SHUT-DFF CDNTRDLSFDR LOSS DF FLAME IN SECONDARY CDMBUSTDR

FIGURE 40 0 4 6 9 2

——--^

nrwATCT-J»a———(K rua—l - - -

•L——————A—————-

K^^riRAM 1"

r

f-,

r-i

f-4————^-

~-i

i

BURNER

EEDER

r~ -- - .- - -

KILN

f—————————.

WMTEVATm—

w»ne "f^-g——•*•—»)————ntft •X.—————- BURNFRAM—————————————————-|

r—i

A

-- -- r--~ -—i

'!^t . 1

SECONDARYCDMBUSTDR

STEAMDRUM

BOILER

~~\

^]

AIR PDLUTIDNCDNLRDL TRAI

u<M

N

AUTOMATIC SHUT'-nFF CDNTRDLSFDR LDV LDV WATER LEVEL IN STEAM DRUM

FIGURE 5

————————————————————004693——————

The secondary combustor is designed to further burn the gases

discharged from the rotary kiln and to burn liquid wastes injected

through the burner of this u n i t . It also is capable of burning

wastewaters injected through a w.'istewater injection nozzle. Drawing 4provides plan and section views of this u n i t .

CONSTRUCTION MATERIALS AND DIV1:XS:ONS The secondary combustoris a carbon steel cylinder mounted horizontally on two supports on a

flat bed trailer. It is lined with 2 1/4" of insulating brick and 4 l:::*"C

1/2" of fire brick. The resulting interio" dimensions are: 79 1/2" \0rI . D . ; 4 1 ' 6 " length; unc'i 1400 cf effective volume. Gases from the kiln -

are delivered to the combustor through a carbon steel duct lined with —4" of castable refractory material and having a resulting 30" I . D . .

This duct is equipped with an expansion'alignment j o i n t , as well as a

slide gate which can be used to isolate the combustor when it is to beused alone to burn liquid wastes. The duct introduces gases into the

combustor tangentially through a 1 ' 9 " x 3 ' 6 " rectangular port on theupper right side of the inlet end of the combustor.

Gases exit the combustor and are carried to the waste heat

boiler through a carbon steel duct lined with 4" of castable refractory

matcriu] and having a resulting 4 6 " I . . D . . Although not shown onDrawing 1 , this duct will he equipped with an emergency vent which can

be opened to vent. arises away from the boiler when there is a loss of

water in the steam drum.Current opc'rating experience with the MWP-2000 in Florida

indiL'ci Les Ltml considerable quantities of fine solids can be carried

20

03200058

over into and dc^sited in the secondary combustor when fine-grained

solids are burned in the rotary k i l n . Because the secondary combustoris not equipped with a solids removal system, this carryovernecessitates the periodic shut down of the system to manually cleansolids deposits out of the combustur. To overcome this problem, Ensco

is currently designing ( 1 ) a cyclone system to be installed between therotary kiln and the waste heat boiler to remove solids from the kilnexit gases and reduce t-i'.eir downstream carryover into the secondarycombustor, and ( 2 ) a solids removal system to be Installed on the

secondary combustor. to enable removal of solids deposits duringoperation and without frequent shutdowns. Ensco intends to make and C

\0test these modifications on the system currently operating in Florida. < -If they prove to be effective, Ensco will make these same modificationsto the system being trial burned and described in this document.

Revised sections of this document will be transmitted as soon as this

decision is made.

WASTE FEED SYSTEMS Liquid combustible wastes as fuel are

introduced into the combustor through the auxiliary fuel feed system

described in a following subsection.The wastewater feed system introduces wastewater (or water for

temperature control) through a flat-spruy nozzle into the combustor.

Tills system is capable of feed rates up to 10 gp-n.

BURNER ANT NOZZLE The secondary coir.bustor is equipped with a

vortex burner which is capable of producing 24 million BTL'/hour of heatusing fuels and/or wastes huvjng heating values ranging from 6000 to19500 BTLVlb. The burner nozzle is designed to use steam as needed to

21

00

atomize the fuel and/or wastes bein^ injected and is equipped with aspecialized tip for handling higlily chlorinated wastes. The burner isdesigned to produce a short ( 4 f o o t ) , highly turbulent flame cone.Combustion air is introduced into the burner tangentially to create a

turbulent flame and is supplied by u blower capable of delivering 5460cfm at 35" we pressure.

AUXILIARY FLTL SYSTEM The secondary combustor burner is servedby two fuel/wastes feed systems (see the P&ID in Drawing 5 ) . One system

0consists of a pair of pumps and strainers and interconnecting piping. -

One set of the pumps and strainers serves as standby equipment. This \^^S-

system, which also serves the rotary k i l n , is typically used to deliver 00fuel to the combustor burner during start-up and when needed during

operation. The other system consists of a pair of stainless steel

pumps, a pair of strainers and interconnecting piping equipped with

in-line heaters. One set of the pumps and strainers serves as standbyequipment. This system is used to handle highly corrosive and/or highlyviscous wastes and is typically used to deliver combustible liquidwastes to the combustor burner. Both systems tie into a common feed

line on which is installed the flow measuring and control devices

described in the following section. However, this feed system is

currently being evaluated to allow the simultaneous and independentfeeding of fuel and wastes. Both feed systems will have identical

measuring and control devices.

INDICATOR AND CONTROL DEVICES Drawing 5 provides a PAID of thesecondary combustor and its fuel and waste feed systems. The following

22

paragraphs briefly describe the indicating and control devices shown onthis P&ID. The data acquisition and control computer and controllersand all of the indicating devices, except where otherwise noted, arelocated on the control panel of the control room and laboratorytrailer.

Drawing 9 provides a layout of the control panel and shows theindicating and control devices described in the following paragraphs.

Combustor gas outlet temperature is measured by a thermocouplelocated in the duct connecting the combustor to the waste heat boiler.

Signals are sent to a digital readout and to the data acquisition and ~C

control computer which displays readings on the computer monitor. \Qt0Combustor skin temperatures are monitored by three

thermocouples attached to the outside metal surface of the combustor. (—-•Combustor brick temperatures are monitored by five thermocouples

inserted in the fire brick lining of the combustor. Signals from all ofthese thermocouples are routed to a selector switch on the controlpanel which can be turned to produce a temperature reading from any one

of the thermocouples on a digital readout.The pressure drop across the secondary combustor is measured

by a differential pressure transducer connected into the inlet andoutlet ducts of the combustor. Transducer signals are routed to the

data acquisition and control computer which displays readings on thecomputer monitor. Manometers also are installed in the inlet and outletducts to provide redundant measurement of pressures. These manometersare not connected to indicating devices on the control panel.

The combustor flame and conditions inside of the combustor are •monitored by a remote TV camera which is connected to a TV screen on

23 0320CG61

the control panel.

Fuel and/or waste feed, combustion air flow and atomizingsteam flow to the burner of the secondary combustor are measured and

controlled in the same manner as described for the rotary kiln.Wastewater (or water) feed to the combustor is measured and

controlled in the same manner as described for the rotary kiln.As shown on Drawing 9 , indicator lights and lighted manual

control buttons on the controJ panel report the status of all of thefuel/waste/wastewater pumps and air blowers that serve the combustor.The on/off manual switches, plus the manually or automatically operated 0s

v0controllers, provide the mecins of fully operating the combustor from .the control panel .

iAUTOMATIC WASTE FEED CL'T-OFF CONTROLS The automatic wastewater

feed cut -off and waste- to- f u e l swi t ch ing cont ro ls for the secondary

combustor are those described p r e v i o u s l y .

le , AIR POLLUTION CONTROL TRAIN

The air po l lu t ion control t ra in consists of a quench system, a

packed tower , an ejector scrubber and a s tack. This equipment train is

designed to cool the gases, re.TiOve up to app rox ima te ly 1500 Ibs/hour of

H C 1 , and remove p a r t i c u l a t e in sizes grea te r than 0.3 micron . Ttie

quench system and packed tower are in s t a l l ed on the same flat-bed

t ra i l e r tha t holds the w a s t e heat b o i l e r . D r a w i n g 6 provides plan and

sect ion v iews of th is e q u i p m e n t . The ejector scrubber and stack are

i n s t a l l e d on a separate t r a i l e r , p lan and section views of which are

24

00

provided by Drawing 7 . A P&ID of the uir pollution control train isprovided in Drawing- 8 .

QL'ENCH SYSTEM This system consists of a quench sump and avertical 9C deg. quench elbow which conveys exit gases from the wasteheat boiler to the sump. Gases exit the quench sump and are conveyed tothe packed tower through a duct. The quench elbow contains severalno^zJes which spray recirculated water into the elbow to cool the gasesfrom a temperature as high as 600 deg. to a temperature of about 185 -

0degrees F . The elbow is fabricated of InconeJ to resist the corrosive \0

•^effects of Lhe acid vapors in the system when chlorinated wastes or .-..

su]fur-containing wastes or fuels are being burned. It has an initialinside diameter of 54" at the outlet of the waste heat boiler and afinal reduced diameter of 30" at the inlet into the quench sump.

The quench sump serves as a collection sump for excessrecirculation water from the entire air pollution control train andalso provides additional residence time for the cooling of gasespassing through the quench system. Excess recirculation water collectedin the sump is pumped to the effluent neutralization and concentrationsystem for treatment prior to ultimate disposal (although on some jobsneutralization and/or concentration of effluent may not be necessaryprior to ultimate disposal). The quench sump is fabricated of 3/8"

thick fiberglass reinforced plastic and is 8' long x 4 ' 6 " wide x 2 ' 6 "high. The outlet duct which conveys gases to the pncksd tower measures21" x 42" and also is fabricated of fiberglass reinforced phistic.

The quench system is served by a pair of pumps (one of whichis a standby pump) which recirculate water from the sump to the spruy

0320006325

nozzles in the queni... elbow. An in-line solids separ,- or between the

pumps and the spray nozzles removes particulates which otherwise couldplug the nozzles. Excess re-circulation water from the packed tower is

conveyed to a quench elbow nozzle. The quench sump is served by a raw

water -line which enables the adding of emergency make-up water to the

sump i f , for some reason, the water level in the sump falls below a

low-water- setpoint.Excess water in the quench sump can he pumped, by the

operating quench recirculation p u m p , to tlie neutralization and

concentration system.Quench system outlet gas temperature is measured by a

thermocouple in the outlet elbow which sends signals to ( 1 ) a digitalreadout and ( 2 ) the data acquisition and control computer on thecontrol panel. Quench system inlet temperature is provided by the

secondary cor.bustor outlet temperature, the measurement of which has

been described previously.Recirculation flows from the quench sump to the quench elbow

and from the packed tower to the quench elbow are measured byturbine-type flowmeters which transmit signals-to digital readouts on

the control panel.A pressure indicator (with a local readout) and a low pressure

switch, which signals a low pressure a l a r m , are installed on the

rocirculation line from the quench sump to the quench elbow. A

solenoid-activated dinphram valve, operated by a cycle tinier, controls

blowdown of solids from the solids separator in the quench

recirculation l i n e .The quench sump is equipped w i l ! i h i ^ h - h i g h , h i g h , low and

26 03300064

low-low water level indicators. The high-high and low-low Indicatorssignal light anil sound cilarms on the control punel. The high and lowindicators manage the flows of recirculation water from the packed•Lower to the quench elbow by operation of a solenoid valve. The quench

sump is equipped with a sight glass for buck-up monitoring of water

levels in the surap.

Current operating experience with the MWP-2000 in Floridashows the need to redesign the quench system to move quenching actionfurther downstream from the outlet of the waste heat boiler to avoid

corrosion and solids build-up problems on the outlet face of the —0boiler. This redesign is underway and a revision to this document ^

reflecting this modification will be submitted as soon as it is ^0

completed. This redesign, however, will not change the purpose or the 0fundamental design of the quench system, as described herein.

PACKED TOWER The packed tower is designed to remove 99?; of theHC1 (at a maximum HC1 loading of 1600 Ibs/hour) from the gases that

exit the quench sump. The gases flow upward through the tower and arescrubbed by a countercurrent flow of water recirculated from the packedtower sump and from the ejector scrubber sump. There is also a

capability to add make-up water to the system. Excess recirculation

water is pumped to the quench elbow.

The packed tower is fabricated of fiberglass reinforced

plastic, is 14'high and has u 6 ' I . D . . It is packed with a 6 ' depth of

2" diameter packing made of plastic material and contains a demister

pad above the packing.Recirculation w<itnr flows fi-fim tin: piickei.1 tower sump and

0330006527

ejector scrubber _ . i p , and muke-up water flows -ire measured by

turbine-type flowmcters which transmit signals to digital readouts onthe control panel.

The packed tower sump is equipped with high-high, high, lowand low-low water level indicators. The high-high and low-low

indicators signal light and sound alarms on the control panel. The highand low indicators manage the flow of recirculation water from the

ejector scrubber sump to the packed tower.

EJECTOR SCRUBBER The ejector scrubber is designed to removeadditional particulate and HCJ from the gases before they aredischarged through the stack. It is capable of removing 99?o of incoming QJparticulate in sizes greater than 0 . 3 micron and removing 9 9 ° ; of f-incoming HC1. Gases exiting from the packed tower are drawn through the ^

0ejector mixing tube by the force of steam delivered through a nozzle in Qthe mixing tube. The. turbulence created by the unique nozzle andmixing-tube design causes the agglomeration of submicron particulateand HC1 in the water vapor supplied by the steam. This agglomeratedmaterial is removed by the demister integrated into the scrubber.

The ejector scrubber also serves as the prime mover for the

entire system. The drawing of gases through the ejector mixing tubesproduces up to 15" we vacuum. This is sufficient vacuum to draw gases

through the rotary kiln, secondary combustor, wast-e heat boiler and air

pollution control train.All of the structural components of the ejector scrubber are

fabricated of fiberglass reinforced p i c i s t i c .

28 03300066

Condensed water removed by the demister and drainage f rom the

ejector scrubber dra in into the ejector scrubber sump. This water is

rec i rcula ted to the ejector scrubber and to the packed tower by a

rec i rcu la t ion p u m p . This r ec i r cu la t ion wa te r passes through a solids

separator to remove suspended sol ids . Standby rec i rcula t ion pumps and

solids ^ s e p a r a t o r s also are p r o v i d e d . Add i t i ona l ly , capabi l i ty is

provided to add make-up water to the e jector scrubber sump.

Al though no t shown on D r a w i n g 8, the sys tem is c u r r e n t l y being

m o d i f i e d to enable the i n j ec t i on of up to 10 gpm of 25% N'aOH at 75 psig

into the ejector s c rubbe r r e c i r c u l a t i o n l ine to provide increased KC1

removal cupaci i-y when needed in the air p o l l u t i o n control t ra in . A l s o , - ^0

a pH meter is c u r r e n t l y being ins ta l l ed in the scrubber sump to provide f~-^0

the data necessary to con t ro l the rate of NaOH in jec t ion .

Ejec tor scrubber i n l e t and ou t l e t t empera tu res are measured by ^

thermocouples located in- the i n l e t and ou t l e t d u c t s . These measurements

are t r ansmi t t ed to d ig i t a l readouts on the control panel and the out le t

tempera ture measurement is t r ansmi t t ed to the data acquis i t ion and

control compu te r .

Rec i rcu la t ion water f rom the ejector scrubber sump to the

ejector scrubber and make-up wa te r added to the ejector scrubber sump

are measured by turbine- type f l o w m e t e r s which send signals to digital

readouts on the cont ro l p a n e l . The nuike-up w. iLc- r f l o w measurement is

t ransmi t ted to the data d c q u i a j t i o n and control computer .

Pressure in the e j ec to r scrubber r ec i r cu l a t i on l ine is

measured by pressure i n d i c a t o r s w i t h loca l readouts . I.ow pressure is

de tec ted by a l ow-p re s su re s w i t c h w h i c h sounds an a l a r m on the cont ro l -

panel .

2903200067

Differential gas pressure across the ejector scrubber is

measured by a pressure transducer which transmits its measurements tothe data acquisition and control computer.

The temperature of the steam delivered to the ejector scrubberis measured by a thermocouple which transmits measurments to a digitalreadout, on the control panel and to the data acquisition and controlcomputer. The delivery stea^ line alsu is equipped with a pressureindicator (with local readout) and a low pressure switch which operatesan alarm on the control panel.

The ejector scrubber sump is equipped with high-high, high,^

low and low-low water-level indicators. The high-high and low-low Q1 -indicators activate light and sound alarms on the control panel. Thef-00

high and low indicators manage the delivery of make-up water to theejector scrubber sump. The samp is also equipped with a sight gla'ss toenable independent monitoring of the water level in the sump.

STACK The stack is fabricated of fiberglass reinforced plastic

and is 3 5 ' 6 " high. It has three sections. The lower section has a 3 6 "

I . D . and is 8 ' 1 0 " high. The reducer section is 50" high and reduces theI . D . from 3G" to 3 0 " . The upper section has a 30" I . D . and is 2 3 ' 6 "

high. Condensate formed in the stack drains to the ejector scrubbersump.

Stack outlet gas temperature is are measured by a thermocouple

which transmits measurments to a digital readout on the control panel.The stack .is equipped with a system to continuously collect gases whichare transmitted to the oxygen, carbon monoxide, carbon dioxide andoxides of nitrogen analysers in the control room and laboratory

0320006830

trailer. Gas analysis measurements are recorded on a strip chart on thecontrol panel and are transmitted to the data acquistion and controlcomputer which stores this information and uses it (except for oxides

of nitrogen data) Lo operate the automatic waste feed cut-off and

waste-to-fuel switching controls when required. A more detailed

description of the stack gas monitoring system is provided in AppendixI .

I f . CONTROL ROOM A\R LABORATORY

The control roon; and labora tory are located in a van trailer ino

(see Drawing 1) . The c o n t r o l room contains all of the indicator r-~• i-0readouts, controllers, control switches and the data acquisition and

control computer which are used to efficiently and effectively operate

the MWP- 2000. Most of. this instrumentation is installed on a control

panel. Drawing 9 provides a drawing of the control panel which showsthe installed instruments. The control room also houses the stack gasanalyzers that were discussed in the previous subsection.

The laboratory is fully equipped to enable chemical andheating value analyses of wastes to be burned and chemical analyses of

the residues (ash and effluent wastewaters) generated by the system.

The two major analytical instruments in the laboratory are a gaschromatograph equipped with both flame ioni^ation and electron capture

detectors, and an atomic absorption spectrophotometer equipped with

hydride and mercury vapor systems. Additional equipment in tlielaboratory include an adiabatic bomb calorimeter, an oven,a furnace, afume hood, an analytical balance, a pH meter, stirring and heating

3i 03200069

0

apparatus and general laboratory glassware and chemicals.

Ig. AUXILIARY COMPONENTS

WASTE HEAT 30ILER AND STEAM DRUM The waste heat boiler isdesigned to recover heat from the gases that exit the secondarycombustor to produce steam at- 250 psig for use in driving the ejectorscrubber, concentrating neutralized effluents, atomizing viscous fueland/or wastes being injected into the kiln and/or secondary combustorand other minor uses. The boiler is rated at 1 9 . 6 million BTU/hour. Itis located on the same flat-bed trailer which holds the quench system \0

0and the packed tower. Also located on this trailer, serving the waste ^heat boiler, are the deareator, a pair of boiler feed-water pumps (one

0of which is a standby p u " ; p ) . a chemical injector system to control the 0pK and oxygen of the boiler feed-water. A steam drum is located abovethe boiler. The boiler is designed to be operated so that tube metaltemperatures are maintained above 400 degrees F to avoid acid corrosionand so that high gas velocities are maintained through the boiler tubesto avoid fouling of the tubes by particulate deposits.

Gas inlet and outlet temperatures, steam pressure, temperatureand flow, steam drum water level, differential gas pressure across theboiler, and boiler make-up water flow are measured and recorded in the

data acquisition and control computer which displays this informationon the computer monitor. The steam drum is equipped with high-high,high, low and low-low switches. The high-high and low-low switchessignal alarms on the control panel. The high switch shuts off make-upfeed water to the steam drum. The low switch orders the addition of

32 03300070

make-up feed water. The low-low switch shuts off fuel and/or waste feedto the rotary kiln and the secondary combustor in order to preventdamage to the boiler.

BOILER MAKE-UP WATER TREATMENT SYSTEM A water softening systemis installed on a skid located near the waste heat boiler trailer (seeDrawing 1 ) to provide treated make-up water for the boiler. This systemhas a capacity of producing 47 gpm of zero-hardness water.

ASH REMOVAL 'SYSTEM Ash formed in the rotary kiln is dischargedr~-

into a bellows-sealed breeching at the lower end of the kiln. Ash falls —,from this breeching Into a ash receiving tank which is filled with *'"'

' 1-water to a height above the discharge lip of the breeching to provide a 0

0water seal. Ash is removed from the ash receiving tank by a chain drag

conveyor which transfers the ash into portable bins which are used to

transport the ash to ultimate disposal or to a transfer area foraggregation for transport to ultimate disposal.

EFFLUENT NEUTRALIZATION AND CONCENTRATION SYSTEM Excessrecirculation water from the air pollution control train is pumped fromthe quench sump to the effluent neutralization and concentrationsystem. The neutralization portion of this system consists of a lime

slurrying tank, an eductor to mix lime slurry with acid effluent, aretention tank to enable completion of the neutralization and fine pHadjustment and two small reagent holding tanks to hold the chemicalsused in fine-adjustment of p t i . The concentration portion of the systemconsists of a tank with internal steam heating coils which provide the

33

heat to evaporate water from the neutralized effluent. The

neutralization portion of the system will be used whenever the burning

of chlorie or sulfur-containing wastes or fuels produces an acidiceffluent which needs to be neutralized for ultimate disposal. The

concentration portion of this system will be used whenever it isimportant to reduce the volume of neutralized effluent that needs to bedisposed.

LIQUID AND SLL'RGE WASTE HOLDING AND BLENDING SYSTEM Depending

on the particular job being performed, one or more appropriately ,-Qdesigned portable waste holding tanks will be used to segregate and r---hold liquid combustible wastes, wastewaters and pumpable sludges for "^

0feeding into the rotary RiJn and/or the secondary combustor. On some o

«jobs one or more appropriately designed portable blending tanks may beused. These tanks will be placed in a containment area having the

capacity to hold the contents of the largest tank plus the rainfallfrom a 25-year, 24-hour storm event (unless the system is installed

under r o o f ) . Wastes will be pumped from this system by the waste,

wastewater and/or sludge pumps previously described.

CLEAN FUEL HOLDING TANKS Clean fuel to be used in the rotary

kiln and secondary combustor typically will be held in portable tanksor tank trailers supplied by the fuel supplier. These will be served by

the auxiliary fuel pumps previously described.

SOLID WASTE PREPARATION SYSTEM The solid waste preparation

system will be tailored to the job being performed. Often, this system

03300072

34

will be a shredder which discharges shredded wastes into a receivingbin from which the wastes will be picked up by the chain drag or beltconveyer of the solid waste feed system previously described. Thissystem also might Include drum opening and emptying equipment, solidsblending equipment and/or solids repackaging capabilities. On somejobs, no solid waste preparation may be necessary and wastes will bedelivered directly into the hopper or onto the conveyor of the solidwaste feed system.

35 03300073

2 . TEST PROTOCOL AND SCHEDULE

2a. PL-RPOSE

Two trial burns will be performed under this application. Thepurpose of the first trial burn will be to demonstrate that the MWP2000 can achieve 9 9 . 9 9 9 9 ° > DRE when burning the predominantly organicmanufacturing and formulating processing wastes that are included amongthe F020 - F027 wastes. The purpose of the second trial burn will be to

demonstrate that the MWP 2000 can achieve 9 9 . 9 9 9 9 % DRE when burningsoils and other predominantly inorganic solids contaminated with suchwastes.

•

2 b . TRIAL BL'RX RATIONALE

In the first trial burn, a formulated organic liquid mixturecontaining the following four POHC's will be simultaneously burned in

the rotary kiln and in the secondary combustor;5°. perchloroethylene ( 1 . 1 9 kcal/g)

65% trichlorophenol ( 2 . 8 8 kcal/g)20% trichlorobenzene ( 3 . 4 0 kcal/g)10% chlorobenzene ( 6 . 6 0 kcal/g)

Ensco believes that this mixture will be representative of the

most difficult-to-burn F020 - F027 wastes because:1 . it is 100°. organic2 . it is highly chlorinated (5 4 ° s )3 . it contains P O H C ' s , having different h-eats of combustion,

36 0320C074

in amounts which exceed the highest concentrations of

hazardous c o n t i t u e n t s having the same or higher

heats of combus t ions l i ke ly to be found in F020 - F027

wastes

4. it is a l iquid J i k e most F020- F027 wastes

For example , the 2 . 4 - D waste (F023 wastes) accumulated at the

Vertac plant in Jacksonvi l le , Arkansas , is essentially 100% organic and

has a ch lor ine content of a p p r o x i m a t e l y 35%. All of the constituents in

this waste have heats of combus t ion greater than 2 .72 kcal/g, and

approx ima te ly 85°o of the cons t i tuen t s in this waste have heats of

combust ion in the neighborhood of 3 .6 kca]/g. Similar ly , the 2 ,4 ,5-T

waste accumula t ed at the Vertac p l a n t is e s sen t i a l l y complete ly organic p .

and has a ch lor ine content of approximately 30*8. All of the0

const i tuents in this waste have hea ts of combus t ion greater than' 2 .72 0

kcal/g and approximately 70°o of the constituents have heats ofcombustion in the neighborhood of 2.87 kcal/g. Both of these wastes arepartially in a liquid state and partially in a solid state at ambienttemperatures. However, the solid-state waste melts at less than 200degrees C and therefore quickly becomes liquid when subjected toIncineration.

Although the trial burn mixture employed in the rotary kiln inthe first trial burn will be a liquid, Ensco believes that it willrepresent a solid or semi-solid waste having a melting point of 500degrees C or less. Such solid or semi-solid waste would be immediatelymelted and transformed into a liquid at approximately the same locationin the kiln that the trial burn mixture will be introduced through the •sludge injection nozzle.

37 0320C075

In the first trial burn, the trial burn mixture will be fed tothe rotary kiln at an approximate race of 1600 Ibs/hr and to the

secondary combustor at an approximate rate of 1000 Ibs/hr. These rateshave been choosen to utilize the full nominal thermal capacity of both

the rotary kiln and the secondary combustor (14 and 22 million BTU/hr,respectively) and the full nominal HC1 removal capacity of the airpollution control train (1500 Ibs/hr).

In the second trial burn, soil contaminated with 3 ° . , byweight, of each of the POHC's— carbon tetrachloride,

perchloroetheylene and trichloroethane--and oil will be burned in the

rotary kiln. Simultaneously, an oil mixture containing 25'*o of each

carbon tetrachloride, perchloroet.hylene, trichloroethane, and

uncontaminated fuel oil will be burned in the secondary combustor.Ensco believes that the kiln burn will represent the incineration ofsoils or other inorganic solids which are contaminated with the highestconcentrations of F020 -F023 wastes that likely will be found. Themixture of POHC's to be used in the soil has been chosen to represent

the most difficult-to-burn constituents that likely will be found in

inorganic solids contaminated with F020 - F023 wastes. Ensco furtherbelieves that the secondary combustor burn will represent the

incineration of oil or other liquid mixtures that are contaminated withthe highest concentrations of F020 - F023 wastes that likely will be

found. As in the kiln burn, the mixture of POHC's that will be used has

been chosen to represent the most difficult-to-burn constituents thatlikely will be found in liquid mixtures contaminated with F020 - F023

wastes.

In the second trial b u r n , the contaminated soil will be fed to

38 03300076

the kiln at an approximate rate of 6000 Ibs/hr, and the oil mixturewill be fed to the secondary combustor at an approximate rate of 2000Ibs/hr. These feed rates huve been chosen to demonstrate the fullnominal thermal capacities of the kiln and combustor and the fullnominal HC1 removal capacity of the air pollutionn control train (seeabove) ...

Taken togther, Ensco believes that the two trial burns willenable a demonstration of the MWP 2000 to adequately incinerate thewide range of F020 - F028 wastes and mixtures thereof that may existwithin the country.

2C. WASTE CHARACTERISTICS

The liquid mixture that will be used in the first trial burn

will be formulated from virgin commercial grade or recycled chemicalsof approximately 95% purity. The expected physical and chemicalcharacteristics of this mixture are given in Table I . This mixture willbe formulated in a rail tank car or blending tank and a compositesample will be taken after formulation and analyzed for the parameterslisted in Table I plus the POHC concentrations. During each of thethree trial burn tests, a composite sample will be taken of thismixture as it is fed into the kiln and into the secondary combustor.These composite samples will be analysed as described in Subsection2f.

The oil mixture that i v j i l be formulated for burning in thesecondary combustor and for contaminatiing the soil to be burned in thekiln during the second trin] burn will be prepared with virgin

TABLE IWASTE CHARACTERISTICS

TRIAL BURN 1

Parameter

Heat of 1 . 1 9combusLion (kcal/g)Chlorine 35.52content (% by w t .Specific;gravityMelting point(degrees C )Boiling point(degrees C )Viscosity( c p )

Perchloro- Tri- Tri- Chloro-ethylene chlorophenol chlorobenzene benzene1 . 1 9 2.88 3.40 6 . 6 0

35.52 53.87 58.62 31.50

1 . 6 3 1 . 4 9 1 . 5 6 1.107-22 67 17 -45

121 253 53 1310.80 "^

<;—r-~-•00

40 0320C078

commercial grade or recycled chemicals of approximately 95°; purity. The

expected physical and chemical characteristics of these mixtures areprovided in Table I I . This oil mixture will be formulated in blendingtanks, a rail tank car or truck -Lank trailers and, after formulation,will be analyzed for the parameters listed on Table II plus the

POHC concentrations.During each of the trial burn tests, a composite sample of the

oil mixture fed to the secondary combustor will be taken and analyzedas decribed in Subsection 2f.

As described later, the soil to be burned in the rotary kilnwill be contaminated with the oil mixture as it is being introduced

into the hopper discharging into the ram feed. This procedure will be 1"-employed to prevent the loss, by volatilization, of POHC's from the ^

0contaminated soil that otherwise would occur if the soil was Qpre-contaminated. Because it will not be possible to obtainrepresentative samples of the contaminated soil from the hopper or ramfeed during the trial-burn tests, a composite sample of the oil mixture

being added to the soil will be taken instead. This compoite sample

will be taken and aniyzed as described in Subsection 2f.The soil to be contaminated and burned in the kiln during the

second trial burn will be obtained from a local sand and gravel

supplier. This soil will be unwashed and unscreened s.indy soil.

2 d . TEST PROCEDURES - TRIAL BURN' 1

The first trial burn w i l l consist of three one day tests which

will be performed on consecutive days, barring any operational

41 03200079

TABLE II

WASTE CHARACTERISTICSFOR

T R I A L BL'RN 2

Parameter CarbonTetrachloride

Heat of 0.24combustion (kcal/g)Chlorine 9 2 . 1 9content •{*! . by wt. )Specific 1. 5 8 9gravityMelting point -23(degrees C )Boiling point 77(degrees C )Viscosity 0 . 9 6 9( c p )

Perchloro-ethylene1 . 1 985.521 . 6 3-22121

Trichoro-ethane1 . 9 979.721.338-33741 . 2

420320CC80

problems. The duration of each test will be approximately 8 hours, thetime necessary Co obtain adequate stack gas samples of the POHC's beingburned. Before the start of each test. both the rotary kiln and thesecondary combustor will be brought Co operating tempera Cures ( k i l noutjet temperatures of 1700 to 1800 degrees F anil co-nbustor outlettemperatures of 2200 to 2300 degrees F ) with the burning of clean fuel.All other components of the system also will be brought to operatingstatus. Following the conclusion of each t e s t , the kiln and combustorwill be operated at the above-stated operating conditions for at least60 minutes and the air pollution control train also will be maintainedat operating conditions for the same interval of t i m e . Thereafter, '~~

f--until start of heat-up for the next test, the system will be maintained ^at standby conditions (kiln outlet temperatures of 1400 degrees F andcombustor outlet temperatures of 1500 degrees F ) using clean fuel.

The liquid mixture to be used in the trial burn will have beenformulated in a rail tank car or blending tank. Complete mixing of thechemicals used in the mixture will have been achieved by use ofrecirculating pumps and air spargers as necessary and will have beenverified by multi-level specific gravity testing.

During each test, the formulated liquid mixture will besimultanKously and continuously fed to the rotary kiln and thesecondary combustor at the following rates:

- between 1400 and 1800 Ibs/hr to the kiln through the sludge

injection nozzle, and- between 900 and 3100 Ibs/hr to the combustor through the

burner nozzle.The sludge yv.ir.pir.y, system serving the kiln. and the fuel/waste system

43 03200081

00

serving the burner of the combustor (see decrlptlons in previous

section) will be used to feed the mixture to the kiln and combustor,respectively. The other operating conditions delineated in Table III

will be maintained during each test.

The quantities of the liquid mixture, clean fuel and cooling

water delivered to each the kiln and combustor during each test will bemeasured with the flowmeters and totalizing indicators (see descriptionin previ.ous section) in the respective sludge, fuel/waste andwastewater feed lines serving the kiln and combustor. The chemical

characteristics of these streams as delivered to each the kiln andcombustor during each test will be determined by the sampling and ~

f-~analytica] procedures described in Subsection 2f. '^}-

Measurement of the concentrations of POHC's and other chemicalcharacteristics of the stack gass-s will be performed by an independent

contractor in accordance.with procedures described in Subsection 2 f .Additionally, composite samples of all ash, scrubber solids

and scrubber effluent generated during each test will be taken and

analyzed, as described in Subsection 2 f , to ascertain the quality of

the residues generated during the trial burn.Records of the critical operating conditions listed in Table

IV will be kept during each test by the data acquisition and control

co.T.puter. A back-up record of the same conditions will be kept

manually.

Any ash generated during the trial burn in the rotary kiln orsecondary combustor will be shipped to a RCRA permitted or interimstatus landfill for disposal. All scrubber effluent and solids removedby the solid separators in the air pollution control train will be

00

44 03300082

TABLE IIIOPERATING CONDITIONS FOR TRIAL BURNS

Parameter Target Condition Operating RangeKILNFuel Feed Rate

Waste Feed RateFirst trial burnSecond trial bur".

Outlet TemperatureWater

VacuumAir Flow Rate

SECONDARY COMBL'STORWaste Feed RateFirst trial burnSecond trial burr.

Outlet TemperatureWater Feed Rate

Air Flow Rate

Fuel Feed Rate

IdOO Ib/hr6000 Ib./hr

( 3 ° ; POHCs contaminated:1800 degrees F

0 . 5 inches W . G .

1000 Ib/hr1500 Ib/hr2300 degrees F

As needed to maintainthermal loading of 12million to 14 million BTU/hrand outlet gas temperaturegreater than 1GOO degrees F1400 - 1800 Ib/hr5500 - 6500 Ib/hr( 2 . 5 - 3 . 5 ° . POHCs)

1600 - 1800 degrees FAs needed to control kilnoutlet temperature0.25 - 0.45 inches W . G . 0">As needed to maintain \—stoichiometric ratio of 1.5^,

•^t-0

900 - 1100 Ib/hr °1350 - 1650 Ib/hr2150 - 2400 degrees FAs needed to controlsecondary combustor outlettemperatureAs needed to maintainstoichiometric ratio of 1 . 5As needed to maintainthermal loading of 18-20million BTU/hr. and outletgas temperature greater than2150 degrees F

BOILEROutlet TemperatureSteam PressureSteam Drum LevelSteam Flow RateBoiler Diff. Press.

500 degrees F250 psig50 "s full14,000 Ib/hr8 inches W . G .

450 - 600 degrees F150 - 250 psig40 - 55 % full6,000 - 14,000 Ib/hr6 - 1 0 inches W . G .

A I R POLLLTICN CONTROL T R A I NFr^sh W i J t e r Make-up

Quench O u t l e t Temp. 165 degrees FScrubber D i f f . Press . 13 inches W . G .

As needed to make upoperational losses andeffluent discharges155 - 190 degrees F10 - 15 inches W . G .

45 03200083

TABLE III ( c o n t . )

STACKExcess 02 8 %Carbon Monoxide 15 ppmCombustion Efficiency 9 9 . 9 %

5 - 10 %5 - 2 5 ppm>99%

46 03COC084

TABLE IVOPERATING CONDITIONS

RECORDED BY DATA ACQUISITION COMPUTER

PROCESS

ROTARY XILN

SECONDARY COMBL'STOR

BOILER

QUENCH & SCRUBBER

CONDITION

Fuel FlowCombustion Air FlowGas Temperature, Kiln OutletGas Pressure, Kiln OutletWastewater Flow to KilnSludge Flow to KilnFuel FlowCombustion Air FlowGas Outlet TemperatureWastewater Flow RateWaste FlowGas Inlet TemperatureGas Outlet TemperatureSteam PressureSteam Drum Water LevelSteam FlowSteaa TemperatureBoiler Makeup Water FlowBoiler Differential Pressure

Scrubber Makeup Water FlowQuench Outlet Gas TemperatureQuench Differential PressureScrubber Differential Pressure

UNITS

Ib/minIb/mindeg Finches w . g .Ib/minIb/min

Ib/minIb/mindeg FIb/minIb/mindeg Fdeg FPSIG

a/0Ib/mindeg FIb/mininches WCD

gal/mindeg Finches WCDinches WCD

STACK Carbon MonoxideCarbon DioxideExcess OxygenCombustion Efficiency

ppm

47 0320C085

conveyed to the scrubber e f f l u e n t i m p o u n d m e n t at. Ensco ' s El Dorado

f a c i l i t y for u l t i m a t e d i sposa l .

2e. TEST PROCEDURES - TRIAL BL'RN 2

The second trial burn also w i l l consist of three one day tests

which wi l l be performed on consecut ive days , barr ing any operat ional

p rob l ems . The dura t ion of each test w i l l be app rox ima te ly 8 hours , the

t ime necessary to obta in adequate stack gas samples of the P O H C ' s being

burned . The rotary k i l n , secondary c o m b u s t o r and air po l lu t ion control

train wi l l be brought to operating condi t ions before each test and

m a i n t a i n e d at operating and then s tandby condi t ions a f t e r each test in C\Jf-~

the same manner as described for the f i r s t trial bu rn . i^j-

The oil mixture to be burned in the secondary combustor and to

be used to contaminate, the soils to be burned in the rotary kiln will

have been prepared in the same manner as described for the liquidmixture to be used in the first trial burn.

The contaminated soil to be burned in the kiln will beformulated as the soil is being fed into the solid waste feed systemserving the kiln. This will be acheived by feeding soil into the hopperof the system via the conveyor and spraying the pre-formulated oilmixture onto the soil just before it drops from the conveyor into thehopper. The oil mixture w i l ] be delivered from the tank in which it hasbeen formulated to the spray noz/.les in the hopper b y ' a

flowmeter-controlled pump. The rnt.e of feed of sni] rind oil mixture tothe hopper will be synchronized to achieve the soil contamination leveldesigned for the trial burn. The huppe;- and conveyor will be enclosed

48 03200086

00

by hoods and a negative pressure will be maintained in this enclosedequipment by a blower which will discharge exhaust air into the kiln.This procedure is designed to prevent the loss, by volatilization, ofthe POHC's in the oil mixture used to contaminate the soil.

During each test, the con tarn mated soil and the oil mixturewill be simultaneously and continuously fed to the kiln and thecombustor, respectively, at the following rates:

- between 5500 and 6500 Ibs/hr of contaminated soil to thekiln through the ram feeder, and

- between 1350 and 1650 Ibs/hr of oil mixture to the combustorthrough the fuel/waste feed to the combustor burner. K

C\JThe other operating conditions delineated in Table III will be f—

^maintained during each test. .^During each test, the quantity of soil delivered to the hopper

of the solid waste feed system will be determined by pre-weighing thesoils fed onto the conveyor, and the quantity of oil mixture sprayedonto the soils will be measured by a flowmeter with a totalizingindicator in the feed line to the spray nozzle. The quantities of oilmixture delivered to the combustor and the clean fuel and cooling waterdelivered to each the kiln and combustor will be measured by theflowmeter and totalizing indicators in each of the respective feedlines. The chemic;.il characteristics of the oil mixture used to

contaminate the soils, the oil mixture fed to the combustor and the

Clean fuels delivered to the kiln and combiistnr during each test willbe determined using the sampling and analytical procedures described inSubsection 2f.

Measurement of the concentrations of POHC's and other chemical

49

0

characteristics of the stack gases, measurement of the constituentscontained in the residues and recording of the operating conditionsmaintained during each test w i l l be accomplished in the same manner asdescribed for the first trial burn.

Ash, scrubber effluent and separator solids generated duringthe trial burn will be disposed of in the manner described for thefirst trial burn,

2f. SAMPLING AXD A.VALYTICAL PROCEDURES

^Table V delineates the samples that will be taken during each ^

r-test of the two trial burns and . indicates the sampling location, t-periodicity and method, sample size and method for analyzing each 0

0sample. Ensco personnel will take all of the samples of tlie liquidmixtures and fuel fed to the kiln and secondary combustor or used tocontaminate the soil burned in the second trial burn. Ensco personnelalso will take all of the samples of ash, scrubber water and scrubbersolids generated during each trial burn. Except for the ash samples,all of these samples will be immediately composited with the previoussamples taken of the same material during the test. These compositesamples will be kept in closed iced chests to keep them cool and out ofthe light. They will be delivered to the system's laboratory foranalyses at the end of the t e s t . A composite sample of the ash removedfrom the kiln and dischargee! i n ? o ci receiving bin will be taken aftereach test: when the ash has cooled.

Ensco personnel will opcr.'.ite the continuous stack gas monitorswhich collect data on concentrations of oxygen, carbon monoxide, carbon

50 03200088

dioxide and oxides of nitrogen in the stack gases. Finally, Ensco

personnel will keep records of ( 1 ) the quantities of the materials fedto the kiln and the combustor and the residues generated during each

test and ( 2 ) the operating conditions maintained during each test (seeTable I V ) .

An independent contractor will bn retained to collect andanalyze stack gas samples for particulule, KC1, POHC's and othercharacteristics as delineated in the Statement of Work provided in

Appencix I . The contractor will be required to use those sampling and

analytical methods set forth in the Statement of Work or such other inmethods as may be required and approved by EPA or ADPCE. (^

r--• 1-

2g. YiALFUNCTION PROCEDURES 0

0

Five types of malfunction have bren envisioned and provided

for in the design of and operating procedures for the system. These aredescribed in the following paragraphs. Controls for the first four of

these situations are described in Section B . I . and illustrated in

Figures 2 , 3 , 4 and 5 .One, when combustion efficiency drops below 99''; and/or excess

oxygen in the stack gases drops below 3%, the data acquisition and

contro] computer will switch feed to the rotary kiln and secondary

combustor burners from waste to clean fuel and will cut off all other

waste feeds to both units. The system will be operated on clean fueluntil the operator can ascertain the cause of the malfunction andsafely re-initiate the feeding of wastes.

Two, when there is a loss of flame in the kiln, the flame

03CCC089c.^

supervisor serving the kiln will cut off all fuel and waste feed tothat u n i t ; operation of the secondary combustor will be maintained atnormal operating conditions. The operator will proceed to re-light theflame with clean fuel. When operating conditions are re-established inthe kiln, the operator will re-initiate the feeding of wastes to thatunit. -

Three, when there is a loss of flame in the secondarycombustor, the flame supervisor serving that unit will ( 1 ) cut off allwaste and fuel feed to that un i t , ( 2 ) switch feed to the kiln burnerfrom waste to fuel, and ( 3 ) cut off all other waste feed to the kiln. ^The operator will proceed to re-light the flame and will maintain the L

r-kiln at normal operating conditions. When normal operating conditions '•^

0are re-estabJished in the combustor with the burning of clean fuel, the Qoperator will re-initiate waste feed to both the kiln iind the

combustor.

Four, when the water level in the steam drum falls below 25"o ,the low-low liquid level switch on the steam drum will shut off allwaste and fuel feed to the kiln and combustor and will sound an alarmin the control room. Upon hearing the alarm, the operator will ( 1 )cut-off steam flow to the ejector scrubber, ( 2 ) open the emergency venton the secondary combustor outlet duct and ( 3 ) begin pumping make-upwater into the steam drum. The operator then will ascertain the causeof the low water problem and will re-start the system only aftersuivin^ the problem.

F i v e , when there is a power outage, the standby generator willautomatically start. The operator will ( 1 ) assure that all waste feedsto the kiln and combustor have been cut off, ( 2 ) restart the

52 03 00090

recirculation pumps in the air pollution control train, ( 3 ) restartrotation of the kiln. ( 4 ) restart the combustion air blowers, and ( 5 )re-light the burners in both the kiln and combustor, all tore-establish normal operating conditions in the kiln and combustor withthe burning of clean fuel. I f , after re-establishment of operatingconditions, power is restored, the operator will re-initiate waste feedto the kiln and combustor. I f , after normal operating conditions havebeen re-established and maintained for one hour, power has not beenrestored, the operator will begin a normal shut-down of the system.

53

C. PRE-TRIAL BL'RN PLAN

Ensco would like to conduct five pre-trial burns, each ofapproximately 8 hours duration, prior to Initiating the first trialburn demonstration described in Section B . The purpose of the firstthree of these pre-trial burns will be to verify the HC1 removalcapacity of the air pollution control train. The purpose of the other

COtwo pre-trial burns will be to verify the readiness of the system for QJ

r-~performance of the first trial burn. ^Additionally, Ensco would like to conduct two pre-trial burns, 0

0also each of approximately 8 hours duration, prior to initiating thesecond trial burn demonstration previously described. The purpose ofthese pre-trial burns will be to verity the readiness of the system forperformance of the second trial burn.

1 . PRE-TRIAL BURNS 1 , 2 AND 3

In each of these burns, liquid trichlorobenzene will be burnedin the secondary combustor and the rotary kiln . Total feed rates of1700, 2150 and 2300 Ibs/hr will be employed in burns 1 , 2 and 3 ,respectively, in order to load the air pollution control train at 1000,1200 and 1500 Ibs/hour of HC 1 . Trichlorobenzene will be fed from a tankor tank trailer into the combuslor burner through the fuel/waste feedline and into tlie kiln through the sludge feed line. The system will beoperated at the conditions delineated In Table V I . The quantity of

0320C09255

TABLE VI

OPERATING CONDITIONS FOR PRE-TRIAL BURNS

Parameter Target Condition Operating RangeKILNFuel Feed Rate

Waste Feed RatePre-Trial Burn »1Pre-Trial Burn ?2Pre-Trial Burn *3

Outlet TemperatureWaterVacuu.T.Air Flow Rate

900 Ib/hr1200 Ib/hr1800 Ib/hr1800 decrees F

0 . 5 inches W . G .

As needed to maintainthermal loading of 1 2million to 14 million 3~L'/hrand outlet gas temperaturegreater than 1600 degrees F

800 - 1000 Ib/hr1050 - 1350 Ib/hr1600 - 2000 Ib/hr1600 - 1 S O O degrees FAs needed to control kilnoutlet temperature0 .25 - 0 . 4 5 inches W . G .As needed to maintainstolchionetric ratio of 1 . 5

COMBL'STORRateBurn *1Burn ?2

SECONDARYWaste FeedPre-TrialPre-TrialPre-TrialOutlet TemperatureWater Feed Rate

Air Flow Rate

Fuel Feed Rate

800 Ib/hr930 Ib/hr50.0 Ib/hr2300 degrees F

700 - 900 Ib/hr800 - 1100 Ib/hr450 - 550 Ib/hr2150 - 2400 degrees FAs needed to controlsecondary combustor outlettemperatureAs needed to maintainstoichiometric ratio of 1 . 5As needed to maintainthermal loading of 18-20million BTL'/hr. and outletgas temperature greater than2150 degrees F

BOILEROutlet TemperatureSteam PressureSteam Drum LevelSteam Flow RateBojlor Diff. Prps:,

500 degrees F250 psig-50 "o full14,000 Ib/hr8 inchfs W . G .

450 - 600 degrees F150 - 250 psig40 - 55 % full6,000 - 14,000 Ib/hr6 - 1 0 inches W . G .

0320009356

TABLE VI ( c o n t . )

AIR POLLUTION CONTROL TRAINFresh Water Make-up

Quench Outlet Temp. 165 degrees FScrubber Diff. Press. 13 inches W . G .

STACKExcess '02 3 %Carbon Monoxide 15 pp.T.Combustion Efficiency 9 9 . 9 "o

As neeiJcd to make upoperat ional losses ande f f luen t discharges155 - 190 degrees F10 - 15 inches W . G .

5 - 10 %5 - 2 5 ppir.>39°.

57

trichlorobenzene delivered 'LO each of the sludge feed to the kiln andto the combustor burner during each burn will be measured by theflowmeters and totalizing indicators In the feed lines. Compositesamples of these feeds will be taken during each burn in the samemanner as described for liquid waste feeds in Table V . These compositesamples will be analyzed for BTL' value, chlorine content andtrichlorobenzene concentrations. Stack gas samples will be taken withthe Modified Method 5 sampling train and analyzed for HC1 andtrichlorobenzene. HC1 emission concentrations, HC1 removal efficienciesand DRE's for the three burns will be determined from the data taken.

2 . PRE-TRIAL BURNS 4 AND 5

Each of these burns will be a replicate of the first trialburn described In Subsection 2 d , except that pre-trial burn 4 will beconducted with liquid mixture feed rates to both the kiln and thesecondary combustor of 73% of the feed rates specified for the firsttrial burn. All other operating conditions and sampling and analyticalprocedures will be the same as described for the first trial burnexcept that ( 1 ) Ensco personnel will conduct the stack sampling, ( 2 )sampling and analysis of clean fuel and residues will not be performed,

and ( 3 ) stack gas samples w i 1 ! be analysed only for POHC's and HC1.

3 . PRE-TRIAL BURNS 6 AND 7

Each of these bu;'ns w i l J be ;i replicate of tlie second trialburn described in Subsection 2 v . except that pre-trial burn 6 will be

58 03300095

conducted with contaminated soil and oil mixture feed rates to the kilnand secondary combustor, respectively, of 75°o of those rates specifiedfor the second trial burn. All other operating conditions and allsampling and analytical procedures will be the same as for the secondtrial burn except that ( 3 ) Ensco personnel will conduct the stacksampling, ( 2 ) sampling and analysis of clean fuel and residues will notbe performed, and ( 3 ) stack gas samples will be analyzed only for POHCsand KC1.

59

D . C E R T I F I C A T I O N

; certify under penalty of law that I have personally examinedand. ar. familiar with the information submitted in this document and allattachments and that, based on my inquiry of those individualsimmediately responsible for obtaining the information, I believe thatthe information is true, accurate, and complete. I am aware that thereare significant penalties for submitting false information, includingthe possibility of fine and imprisonment. ^

[^r"~-^00

Gary N . Dietrich, PresidentEnsco Environmental Services

60

APPENDIX I

STACK EMISSIONS MONITORING

The stack gas monitoring system consists of an extraction andconditioning system that feeds the conditioned stack gas to continuousmonitors. These dedicated instruments continuously analyze theconditioned gas for carbon monoxide, carbon dioxide, oxygen, andnitrogen oxides. The analytical results are continuously monitored by rthe data acquisition and control system and can be used by the computer F"-< rto effect automatic waste feed shut-down when abnormal conditions ^—,occur. Additionally, the readings from the oxygen and carbon monoxide "monitors are continuously recorded by strip chaurt recorders.

The stack gas sampling probe is located at a point greaterthan 8 stack diameters downstream of the last bend and 2 stackdiameters upstream of the stack e x i t . This stainless steel probe has athermocouple reading the temperature of the extracted sample. A coarseparticulate filter removes some of the water droplets and largerparticulates before the sample enters the conditioning system. Acalibration gas port is at the exterior of the probe to insure systemintegrity. A diaphragm pump with Teflon seals provides the prime moverof the gas sample to the analyzers. This is done to keep the sampleunder a positive pressure so that any leaks that may develop will notaffect the readings of the monitors.

The gas sample is pushed from the pump throueh an air-cooled .Teflon tube of about 10 feet long to allow the gas to begin cooling and

condense the en,. .dined aols ture . The gas sample then passes through a

Chi l led condenser to remove the condens lb l e m o i s t u r e f r o m the gas. This

condpnser cons i s t s of a 20 foot long stainless steel tub ing wi th a

chi l led wa te r jacket . The cool ing water is rec l rcula ted through a

c h i J J e r the rmos ta ted at 37 degrees F. The sample then passes through a

water t rap to remove the condensa te . This trap has a f loat operated

dra in ' to a u t o m a t i c a l l y expel the condensate under posit ive pressure.

The condensate free gas then goes through a f ine par t icu la te f i l t e r

fo l lowed by a permeation type dryer .

In th is dryer the gas sample f lows through several selectively t-npermeable membranes . A countercurrent f low of dry compressed air al lows r"-

•water vaper to permeate the m e m b r a n e , y ie ld ing a gas sample with a very -~

low water content . This clean dry gas sample then goes to the control

room via Tef lon t u b i n g .

W i t h i n the control room is the ins t rumen ta t ion to monitor the

stack gas. The i n s t r u m e n t s are contained in an ins t rumen ta t ion cabinet

ivlth the p l u m b i n g and controls for ana lys i s . The stack gas is

m a n i f o l d e d to each ana lyzer w i t h an individual f l ow control for each

i n s t r u m e n t . Also included are the controls for the dry air f low to the

p e r m e a t i o n dryer and the ca l ib ra t ion gas. Each of the continuous

analyzers has a 4-20 m i l l i a m p output which is interfaced with the

m i c r o - c o m p u t e r system for data h a n d l i n g and storage.

The oxygen content of the stack ga.s j s c o n t i n u o u s l y moni tored

by a Te ledyne ^326 oxygen a n a l y z e r . This analyzer u t i l i z e s a fuel cell

to measure the concen t ra t ion o f - oxygen. This cel l is spec i f i c to

oxygen, has an a b s o l u t e z e r o , and p roduces a l inear o u t p u t f r o m 2ero

through 100 percen t oxygen. The oxygen cell is a scaled el L-cl . rochemical

03COOG99

0

transducer with no electrolyte to change or electrodes to clean. Whenthe cell reaches the end of its useful l i f e , it is replaced with afresh c e l l . This analyzer has a choice of three ranges available; 0-5°..

0-25°o. and 0-100% oxygen. This instrument has a sensitivity of 0.5% of

full scale and accuracy is +/-2°. of full scale. The monitor has a 4-20

mill lamp output which is relayed through a shielded pair wire to thecomputer for data handling and storage.

The carbon dioxide content of the stack gas is continuouslymonitored by an Infrared Industries IR-703 carbon dioxide analyzer.This analyzer is a dual-beam, nondispersive infrared analyzer designed ^

mfor the measurement of carbon dioxide. This system compares the p-

t^

infrared transmittance of two identical optical paths, one through the 0sample gas and the other through the reference path. The difference in 0optical transmittance between these paths then is a measure of theoptical absorption -due to the concentration of the carbon dioxide.

Circuitry processes the non-linear output signal and linearizes it toprovide a linear output signal. This instrument has two ranges

available; 0-5 and 0-50% carbon dioxide. The monitor has a 4-20milliamp output which is relayed through a shielded pair wire to thecomputer for data handling and storage. The sensitivity of thisinstrument is 0 . 5 ° ; of full scale and accuracy is ^/-\% of full scale.

The carbon monoxide content of the stack gas is continuouslymonitored by a Horiba PIR-2000 carbon monoxide analyser. This analyzer

operates on the nondispersive infrared ribsurption principle. Twin beamsof Infrared radiation are projected through parallel cells; one beamtraverses the samplf; c e i l . the other benm the comparison cell. Carbonmonoxide absorbs (and reduces) the r a d i ; i t ; . o : i reaching the detector via

03F00100

the sample beam. The detector converts th is in to an electr ical signal

propor t iona l to the concen t r a t i on of the carbon monoxide . This

ins t rument has a l inear 4-20 m i l l i a m p ou tpu t over the range 0-500 ppm

of carbon m o n o x i d e . The o u t p u t is relayed through a shie lded pair wire

to the computer for data h a n d l i n g and storage, as wel l as to an

independent s t r ip char t recorder. The s e n s i t i v i t y of th is i n s t r u m e n t is

l°o of f u l l scale and accu racy is +/-2". of f u l l scale.

The ni trogen oxides con t en t of the stack gas is con t inuous ly

moni to red by a Thermo Elec t ron Model 10 chemiluminescent XO/NOx

ana lyze r . The chemi luminescen t reaction of NO and 03 provides the basis | ~^for this analysis . Light emiss ion resul ts when electronical ly excited ^

N02 molecules revert to the i r ground state. To measure NO ' )"0

concen t ra t ion , the gas sample to be analyzed is blended wi th ozone in a Q

reaction chamber . The resul t ing chemiluminescence is monitored through

an optical f i l te r by a h igh-sens i t iv i ty photomul t ip l ie r positioned at

one end of the chamber . The f i l t e r / p h o t o m u l t i p l i e r responds to light in

a narrow wavelength band un ique to the reaction. The output f rom the

p h o t o m u l t i p l i i e r is l inear ly propor t iona l to the NO concentra t ion. To

measure NOx concentra t ions , the gas sample flow is diverted through a

N02 - to - NO converter . The chemi luminescen t response in the reaction

chamber to the converter e f f l u e n t is l inear ly proport ional to the total

•\0x concen t r a t i on entering the conve r t e r . This i n s t r u m e n t has eight

ranges avai lable f rom 0-2.5 up to 0 -30 ,000 ppm \ '0/NOx. The 4-20

m i l l i a m p output is l inear th rough a l l ranges and is re layed through a

shielded pair wire to the c o m p u t e r f o r data h a n d l i n g and s torage. The

s e n s i t i v i t y of this i n s t r u m e n t is 0.5°o of f u l l scale and accuracy is

^/-\% of f u l l sca le .

03300101

These stack monitors are calibrated by flowing thestandardised calibration gases to the calibration port on the stackprobo. This flow rate must be 1 . 5 times the total sampling rate of thestack monitoring system to insure that there is no dilution of the

calibration gas by the stack sample ( n o m i n a l l y , about 30 cubic feet perh o u r ) . This flow rate expels the excess calibration gas through theprobe and into the stack, a]lowing the sampling system to only extract-

the desired calibration gases. This certified gc;s then goes through theentire sampling system and to the continuous monitors as if it werestack gas. The controls Co regulate this calibration gas are contained QO

^withjn the control room to allow flagging of the data as it is storedby the computer system. ^

0Each monitor undergoes a four point calibration cycle at least 0

once a week, more often if the daily checks indicate the need. Thesefour points consist of a zero gas, full scale within 25%, half of fullscale */- 2 5 ° ; , and one point within 25°o of the normal reading of theinstrument during the incineration of the waste, based upon historicaldata. At least once a day, this last calibration gas is used Co checkthe response of each analyser, along with a zero gas. The zero gas istypically pure nitrogen, although the calibration gas for anotheranalyzer may be used if the gas is free of any impurities that might

have an effect. For economy and ease of operation, the calibrationgases for C O , C02, and 02 are combined since these are not mutuallyreactive, only limited by the partial pressure of the C02 gas. Thecalibration gases fur NOx must be stored separately from the others.

The data from the daily and weekly checks is recordedautomatically by Llio cunpute:- for the rcadin'Js from the monitors.

03300102

Additionally, a separate calibration record is maintained. Theinstruments are not adjusted any during the daily checks, merely thedata recorded to attempt to determine ciny drift or other variation thatmay occur. Tlv instruments are; only adjusted during the full four pointcalibration cycle. All calibration and daily checks are examined everytwo t.o four weeks to attempt to identify any maintenance or operationalproblems that may be occurring. Whenever these are identified, they are

added to the manufucturcir' s recommendations for that analyzer duringthe course of that particular clean-up, unless they are identified asbeing a cont inuing p r o b J e m . During the weekly four point calibration y\

t^\cycle, all filters and traps throughout the sampling system are r~-examined and replaced or cleaned as necessary. '

00

03300103

APPENDIX II

STATEMENT OF WORKFOR

STACK GAS TESTING

The contractor must provide the necessary personnel andequipment to perform the stack gas testing program described hereinduring two trial burns of the MWP-2000 modular incinerator at El <

•^-Dorado, Arkansas to be scheduled during the period June 15 through July r-~-

•^15, 1985. All sampling and analytical methods used by the contractor in 00the testing program must have the approval of the Regional

Administrator for Region V I , U . S . Environmental Protection Agency

( E P A ) . Arkansas Department of Pollution Control and Ecology ( A D P C E ) ,and Ensco Environmental Services ( E n s c o ) .

Two separate trial burns are to be conducted. Subject Co

approval by EPA and ADPCE, the first trial burn will be scheduled for

either the week of July 8 or the week of July 1 5 , 1985, and the second

trial burn will be scheduled for the week of July 15, July 2 2 , or theweek of July 2 9 , 1985. Each trial burn will consist of three one-daydemonstration burns with the operatlni; conditions during each burn tobe held as similar as possible. After completion of the first trial

burn, the MWP-2000 will be prepareii for the second trial burn. Duringthis t i m e , the contractor will begin analysis of the samples takenduring the first trial burn and prepare l.he equipment for the second

trial burn. The testing program for each trial burn will be identicalexcept that (during the second trial burn) it will not be necessary tosample and analyze for the dioxins, furans, or chloro-phenols and theirderivative's. The POHCs that will be burned in the first trial burn willbe perchloroethylene, trichlorophenol. trichlorobenzene, andchlorobenzene. The POHCs that will be burned in the second trial burnwill be of carbon tetrachloride, perchloroethylene, andtrichloroethane.

The contractor must collect and analyse representative samplesof stack gas emissions during each of the three tests during each ofthe trial burns in order to determine the concentrations of thefollowing parameters In the stack gas emissions; ~

-a . Excess oxygen, 02 0

0b . Carbon monoxide, COc . Carbon dioxide, C02

d . Oxides of nitrogen, NOxe . Total particulate matter and attendant parameters,i.e. ,

flow rate, moisture, e t c .f . Hydrochloric acid, HC1g . Perchloroethylene, trichlorophenol, trichlorobenzene, and

chlorobenzene during the first trial burn, and carbontetrachloride, perchloroethylene, and trichloroethaneduring the second trial burn

h . Total chlorinated orgnnlcs, RC1i . 2 , 3 , 7 , 8 - T C D D , tetra-, penta-, hexa-, and hepta-chlorinated

dibenzo-p-dioxins during the first trial burn onlyj . Tet.ra-, pent.-i-, hexa-, and hepl.a-clurinated

03300105

dibenzo-p-furuns during the first trial burn onlyk . Tri-, tetra-, total chlorinated phenoJs and thRir

chlorophenoxy derivatives ( a c i d s , esters, ethers, amines,and other salts) during the first trial burn only

The contractor must split such samples with EPA and/or ADPCEas may be required by these agencies. The contractor will allow EPAand/or ADPCE to " s p i k e " selected collected samples and will analyzesuch blind samples as EPA and ADPCE may submit.

Ensco will provide the sampling ports, ladders, lights,andpower required for the installation and operation of the contractor's (M

^t-sampling equipment . [-~-

< -oEnsco will approve the use of the following sample collection

and analytical methods, provided that the contractor obtains approval ^>

of EPA and ADPCE for the use of Lhese methods before initiation of thetrial burns.

o Pan icu la te /Hydrochlor ic acid

o Use of un EPA Method 5 sampling train to

i sok ine t i ca l ly sample the par t icula te and HC1

emissions f r o m the stack. Use of the procedure

speci f ied in 40 CFR 60, Appendix A , Method 5

except t h a t sodium hydroxide wi l l be used in the

impingers L"o t r ap hydroch lor ic acid emiss ions , o

L'se of { .he proL-cdure in Method 5 to analyze for

to ta l p a r t i c u l u c e m a t t e r and a t t e n d a n t

p;ira.'n(;t.L'rs .

03300106

o Use of the procedure "Mercuric Nitrate Method"from Standard Methods for the Examination ofWater and Wastewater to analyze the impingercatch for total chlorides.

o Non-Volatile Chlorinated Organicso Use of an EPA Method 5 sampling train modified

to accommodaLe organic absorbent traps for thecollection of non-volatile chlorinated organics.o Use of GC/EIMS for the analysis of extracts todetermine total RC1, POHCs, and tri-, tetra-, andtotal chlorophenols and their chlorophenoxy

m• i-r-~•^

derivatives, to a detectability level of 1 ppm (or 00

less) in the stack gas.o Use of high resolution gas chromatographry/high

resolution electron impact mass spectrometry for

the analysis of extracts to determineconcentrations of tetra-, penta-, hexa-, andhepta- isomers of polychlorinated dibenzo -p-dioxins and furans and 2,3,7,8-TCDD to adetectibility limit of 1 ppb in the stack gas.

o V o l a t i l e C h l o r i n a t e d Organjcs

o Use of the sampl ing t r a i n f o r volat i le

f;i!.!ori.".ci',.fd o ryc in ics as desc r ibed w i t h i n "Protocol

fo r C o l l e c t i o n and A n a l y s i s of Vo la t i l e POHCs

L'sin^ -a V o l u m e Ory.-inJc S ; impl ing Train ( V O S T ) " ,

03200107

March, 1984, EPA 600/8-84-007.

o Use of GC/MS after thermal desorption andextraction of this absorbent for volatile

chlorinated organics as described within thisdocument. The major identifiable peaks must be

quantified and the results reported from this

analysis. The total level of each PCHC found must

be reported separately.

o Inorganic Gases

o Use of "Lhe procedure described within 40 CFR 6 0 , ^Appendix A , .Method 7 for sampling and analysis of ("-

toxides of nitrogen. Four flasks will be sampled Qduring each day of testing.

o Use of the procedure described within 40 CFR 6 0 ,

Appendix A , Method 3 for sampling and analysis of

carbon dioxide, oxygen, and nitrogen.

o Use of the procedure described within 40 CFR 6 0 ,

Appendix A , Method 10 for sampling and analysis ofcarbon monoxide.

o A gas chromatograph may be used to perform the

analysis uf these samples instead of the

a n n J y U c ; ! . ; procedures contained within the

referenced procedures.

The contractor must submit, a report within 30 days after

completion of . .e sampling. Such report must ..resent the followingdata:

a . Stack gas flow rate - ACFM and dscfm (20 C and 1

atmosphere)

b . Stack gas temperature - F and C

c . Combustion gas analysis - % by volume C02, 02, C O , and N2.

d . Stack gas moisture - °i by volumee . Partlculate concentration - gr/dscf corrected to standard

conditions and In Ib/hr

f . POHC concentration - nanograms/dscf and Ib/hrof each of the POHCs found within the stack emissions

g. HC1 - ppm and Ib/hr lnl -

h . XOx - ppm and Ib/hr f"-« -

1 . Total chlorinated organlcs ( R C 1 ) - both volatiles and Q

c o n d e n s i b l e - r.ar'.ogra'r./dscf and Ib/hr

j . D i o x i n s and f u r a n s - nanograms/dscf and parts per b i l l i o n

of t u t a l unci the t e t ra - , pen ta - , hexa- , hepta- Isomers and

poly c h l o r i n a t e d d ibenzo-p-d loxins and fu rans and

2 , 3 , 7 , 8 - T C D D .

k. Total c h l o r i n a t e d p h e n o J s and der iva t ives - nanograms/dscf

and parts per m i l l i o n

03300109

0