Power point presentation-Incineration

BEM 3701, Hazardous Waste Management 1

Course Learning Outcomes for Unit IV Upon completion of this unit, students should be able to:

3. Describe various types of hazardous wastes, their impact on the environment, and respective environmental control and public health remedies.

4. Evaluate relevant regulatory compliance requirements in the industrial environment.

8. Evaluate safety and health efforts related to hazardous waste workers.

Reading Assignment Chapter 14: Treatment, Storage, and Disposal Facility Requirements Chapter 15: Incineration of Hazardous Waste

Unit Lesson Treatment, Storage, and Disposal Facility Requirements In Unit III, you learned about how hazardous waste is regulated from its creation through its transportation. Ultimately, our hazardous waste must reach its final destination. It must be treated to make it less hazardous and/or disposed of in a safe way. RCRA regulations for Treatment, Storage, and Disposal Facilities (TSDFs) are even more extensive than those for generators and transporters (Pichtel, 2014). These regulations are found in 40 CFR 264-165 Subparts A through G. “Treatment”, “Storage”, and “Disposal” all have specific definitions that are covered in 40 CFR 270.2. Subpart A Subpart A of the regulations cover general issues, such as exclusions from 40 CFR 264 and 265. There are a variety of exclusions, including farmers disposing of waste pesticides from his or her own use, a totally enclosed treatment facility, and a generator accumulating waste on-site. If a facility does not fall under exempt status as outlined in Subpart A, the facility is subject to Subpart B. Subpart B Subpart B covers general facility standards including recordkeeping requirements, personnel requirements, and safety requirements. TSDFs must obtain a site-specific Environmental Protection Agency (EPA) ID number. Before any waste can be treated or disposed of, the facility must obtain a thorough chemical analysis of a sample of the waste. A waste analysis plan (WAP) must outline the process and include information such as the sampling methods used, the procedures used for testing, and the frequency of waste re-evaluation (EPA). Subpart B also requires a TSDF to have specific security in place at the facility, including a 24-hr surveillance system and barriers surrounding the active portion of the facility (Pichtel, 2014). The facility also must inspect the facility on a regular basis. The frequency of inspection varies with the facility and the type of equipment used, as well as the likelihood of an incident if a malfunction were to occur. RCRA specifies inspection frequencies for certain types of TSDF equipment. For example, loading and unloading area should be inspected daily, and containment buildings should be inspected weekly (Pichtel, 2014).

UNIT IV STUDY GUIDE

Treatment Storage and Disposal Facilities (TSDFs) and Incineration of Hazardous Waste

BEM 3701, Hazardous Waste Management 2

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A TSDF is often dealing with ignitable and reactive waste. Subpart B requires that precautions be taken to avoid ignition or reaction of these wastes. Compliance must be documented through testing, citation of scientific literature, waste analysis, or documentation of results of similar treatment processes. Lastly, Subpart B requires that facility employees are trained and that training records are kept. Occupational Safety and Health Act (OSHA) regulations require that all employees at permitted TSDFs undergo at least 24 hours of training before they perform any function that might expose them to hazardous waste (Pichtel, 2014). Subpart C Subpart C covers preparedness and prevention for TSDFs. TSDFs cannot be located near earthquake- sensitive areas or in floodplains. To ensure the stability of disposal areas, a construction quality assurance (CQA) program is required for surface impoundments, waste piles, and landfill units (Pichtel, 2014). Subpart C also contains facility design and operation requirements. The design of TSDFs must minimize the possibility of fires, explosions, or other waste release. Although there are some exceptions, RCRA requires facilities to contain such precautions as alarm systems that can provide immediate emergency instruction, a means for contacting police departments, fire departments, or emergency response teams, and enough water and water pressure to supply hoses, sprinklers, and foam-producing equipment in the event of a fire. Facilities must also have arrangements with local authorities in case of a facility emergency. The TSDF is responsible for familiarizing local police, fire, and emergency responders with the facility layout, the chemical characteristics of the waste at the facility, the hazards associated with that waste, the general location of employees at the facility, the entrances and exits, and evacuation routes (Pichtel, 2014). Subpart D Subparts A-C focus on preventing an incident and preparing for an incident. What are the requirements for a facility when, despite prevention, an incident occurs? A TSDF must have a contingency plan on-site at all times. The plan must describe the arrangements with local authorities and list the contact information of the people who are the designated emergency coordinators. In the event of an emergency, the emergency coordinator is responsible for activating alarms and contacting authorities and advising them of the specific nature of the emergency, as well as actions to be taken. Subpart E Subpart E covers the requirements of the TSDF regarding the manifest system, record keeping, and reporting. As part of the cradle-to-grave tracking system, when a transporter delivers waste to a TSDR the facility owner/operator. The transporter receives a copy of the document, and the TSDF must provide a copy to the generator within 30 days, completing the tracking loop. If manifest discrepancies cannot be reconciled with the generator/transporter within 15 days, the TSDF is responsible for notifying the state regulatory agency. Subpart E also contains specific requirements for the records that must be maintained by the TSDF, including descriptions and quantities of the hazardous waste received, the waste treatment methods, reports of incidents, records of inspection, and other documentation of the facilities operation. The records must be available for inspection by state and federal representatives (Pichtel, 2014). Subpart F RCRA Subpart F covers actions to be taken should a release occur at a TSDF. They include standards for specific contaminants, monitoring requirements, groundwater quality detection, and corrective action programs implemented by the delegated State Agency. Subpart G Subpart G includes the requirement s for closure of a TSDF site. Various, conditions must be met to close a TSD, thus ensuring that the area is free of residual contamination and all closure activities have been effectively completed.

BEM 3701, Hazardous Waste Management 3

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Incineration of Hazardous Waste Two major sets of regulations apply to hazardous waste incinerators: RCRA and the Clean Air Act (CAA). During combustion, solid materials are transformed into solid residues and gasses. When considering combustion, the key is controlled combustion and maintaining the 3 T’s - temperature, time (length of time of burn), and turbulence (mixing of the waste). Some of the advantages of incineration are:

 Almost complete destruction organic materials

 Significant volume reduction when comparing waste to ash

 Significant reduction of hazard comparing waste to ash

Disadvantages are as follows:

 Emission of pollutants (as mentioned above)

 Inorganic materials (metals) are not destroyed

 Ash must be disposed of (The author notes that incinerator ash is subject to RCRA regulations with and may require further treatment)

A permit must be obtained in order to operate incinerators. During the permitting process, the operating conditions of the incinerator must be defined and tested. Also, there are requirements on testing of the waste itself with regard to its constituents. Test burns are controlled tests of the incinerator to demonstrate critical operating parameters and maximum efficiency regarding the combustion process, thus reducing emissions. Some key parameters are waste feed rate, operating temperature, mixing, and waste composition in addition to design factors. In certain cases, industrial boilers can be allowed to burn hazardous waste without going through the extensive permitting requirements. However, these facilities are still subject to EPA Clean Air Act requirements (Pichtel, 2014).

Reference Pichtel, J. (2014). Waste management practices: Municipal, hazardous, and industrial (2nd ed.). Boca Raton,

FL: CRC Press.