BELLS FLATS TR A BK 3 ALL - Conditional Use Permit (2)ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION
AIR QUALITY CONSTRUCTION PERMIT
Permit No. 0125-AC007 June 22, 2001
Brechan Enterprises, Inc.
HOT MIX ASPHALT PLANT
The Department of Environmental Conservation, under the authority of AS 46.03,
AS 46.14, and 18 AAC 50.315, issues an Air Quality Operating Peiinit to:
Operator:
• Brechan Enterprises, Inc.
2705 Mill Bay Road
Kodiak, AK 99615
Initial Location: Longitude: 1520 29.6 W
Latitude: 570 44.94 N'
The project consists of the installation of one AESCO/MADSEN model DM7228 drum
mix asphalt plant, with a rated capacity of 150 tons of asphalt processed per hour. An
AESCO/MADESEN wet venturi scrubber will control Particulate Matter emissions.
The Department authorizes the construction and statewide operation of the Brechan
Enterprises as described in the March 27, 2001 application under AS 46.14.120.
John F. Kuterbach, Manager
Air Permits Program
GAAWQ\Awq-Permits\AIRFACS\ BrechanTonstruction \Asphalt Plant\ finlpermitdoc
Standard Permit Conditions
(Please note that these are standard conditions taken directly from 18 AAC 50.345(a)(1.)-(10). Condition 10(a)
does not limit the Federal Credible evidence rule 62 FR 8314.
1. The permittee must comply with each permit term and condition. Noncompliance constitutes a violation of
AS 46.14, 18 AAC 50, and the Clean Air Act and is grounds for
a. an enforcement action,
b. permit termination, revocation and reissuance, or modification in accordance with AS 46.14.280, or
c. denial of an operating permit renewal application. [18 AAC 50,345(a)(1), 1/18/97]
2. It is not a defense in an enforcement action to claim that it would have been necessary to-halt or reduce the
permitted activity in order to maintain compliance with a permit term or condition.
[18 AAC 50.345(a)(2), 1/18/97]
3. Each pen-nit term and condition is independent, of the permit as a whole and remains valid regardless of a
challenge to any other part of the permit. [18 AAC 50.345(a)(3), 1/18/97]
4. Compliance with permit terms and conditions is considered to be compliance with those requirements that
are
a. included and specifically identified in the permit, or
b. determined in writing in the permit to be inapplicable
[18 AAC 50.345(a)(4), 1/18/97]
5. The permit may be modified, reopened, revoked and reissued, or terminated for cause. A request by the
permittee for modification, revocation and reissuance, or termination or a notification of planned changes or
anticipated noncompliance does not stay any operating permit condition.
[18 AAC 50.345(a)(5), 1/18/97]
6. The permit does not convey any property rights of any sort, nor any exclusive privilege.
[18 AAC 50.345(a)(6), 1/18/97]
7. The permittee shall allow an officer or employee of the department or an inspector authorized by the
department, upon presentation of credentials and at reasonable times with the consent of the owner or
operator, to
a. enter upon the premises where a source subject to the operating permit is located or where records
required by the permit are kept,
b. have access to and copy any records required by the permit,
c. inspect any facilities, equipment, practices, or operations regulated by or referenced in the permit, and
d. sample or monitor substances or parameters to assure compliance with the permit or other applicable
requirements. [18 AAC 50.345(a)(7), 1/18/97]
8. The permittee shall furnish to the department, within a reasonable time, any information the department
requests in writing to determine whether cause exists to modify, revoke and reissue, or terminate the permit or to
determine compliance with the permit. Upon request, the permittee shall furnish to the department copies of
records required to be kept. The department, in its discretion, will require the permittee to furnish copies of '
those records directly to the federal administrator.
[18 AAC 50.345(a)(8), 1/18/97]
9. The permittee shall certify all reports, compliance certifications, or other documents submitted to the
department under the permit as required by 18 AAC 50.205. [18 AAC 50.345(a)(9), 1/18/97]
10. The permittee shall conduct source testing as requested by the department and shall:
a. use the applicable test methods set out in 40 C.F.R. Part 60, Appendix A, and 40 C.F.R. Part 61,
Appendix B, to ascertain compliance with applicable standards and permit requirements,
2
b. submit to the department, within 60 days after receiving a request and at least 30 days before the
scheduled date of the tests, a complete plan for conducting the source tests,
c. give the department written notice of the tests 10 days before each series, and
d. within 45 days after completion of the set of tests, submit the results, to the extent practical, in the
format set out in Source Test Report Outline in Volume III, Section IV.3 of the State Air Quality Control
Plan, adopted by reference in 18 AAC 50.030(8). [18 AAC 50.345(a)(10), 1/18/97]
3
GP3 - General Permit Conditions
Aggregate Dryer or Drum Mixer
11 Opacity & Particulate Matter Emissions
11.1 A. Do not reduce visibility through the exhaust effluent by more than 20% measured as a six - minute
average. B. Monitor effluent and facility operation using the monitoring plan conditions Ml - M7, M10,
M12, and M14 — M20. C. Report using EE2, R3, RIO, R13, PI -P9.
[18 AAC 50.050(a)(4), 5/26/72; 18 AAC 50.055(a)(4), 1/18.97; 40 C.F.R. 60.92(a)(2), 10/6/751
11.2 A. Do not emit particulate !natter concentrations greater than 0.04 gr /dscf. B. Monitor emissions using
monitoring plan conditions M1 - M9, M14 -20 and P1 -P9. C. Report using EE2, R3, R11, R13, P1 -P9.
[18 AAC 50.050(b)(5), 5/26/72; 18 AAC 50.055(b)(5), 1/18.97; 40 C.F.R. 60.92(a)(1), 10/6/75]
11.3 A. Do not operate the facility for more than 6 hours in any 24 -hour period, if the facility can not perform
a Method 5 source test for particulate emissions within the time frame stated in the application. In
addition, do not operate the facility for more than 30 days in any calendar year.
If subject to this condition:
B. Monitor hours and operating days using MI, and
C. Report operating hours and days using RI I.
[18 AAC 50.050(a)(4), (b)(5), 5/26/72; 18 AAC 50.055(a)(4), (b)(5), 1/18.97; 40 C.F.R. 60.92(a)(1), (2), 10/6/75]
For facilities using a baghouse[40 C.F.R. 60.92(a)(1), (2), 10/6/75
18 AAC 50.050(a)(4), (b)(5), 5/26/72; 18 AAC 50.055(a)(4), (b)(5), 1/18.97]
11.4 A. Inspect the interior of the baghouse and complete required maintenance prior to equipment startup in a
new location or after shutdown periods lasting more than 5 days. Within two days of startup after
relocating the facility and every 30 days of operation at the same location, re- inspect the baghouse.
Replace any worn out or damaged bags within 72 hours. B. Monitor using M14 and M15. C. Report any
deviations using R3. 18 AAC 50.055(a)(1), (b)(1) & (3) 1/18/97 and 18 AAC 50.050(a)(1),(b)(1) &(3) 5/26/72
11.5 A. Operate the baghouse efficiently to control opacity and particulate matter. B. Monitor baghouse
operations using M4, M5, M16. C. Report any deviations using R3 and R13.
18 AAC 50.055(a)(1), (b)(1) & (3) 1/18/97 and 18 AAC 50.050(a)(1),(b)(1) &(3) 5/26/72
11.6 Inspect every component of the control device before the first operation each season and repair or replace
any component that shows signs of deterioration.
18 AAC 50.055(a)(1), (b)(1) & (3) 1/18/97 and 18 AAC 50.050(a)(1),(b)(1) &(3) 5/26/72
For facilities using a scrubber [40 C.F.R. 60.92(a)(1), (2), 10/6/75;
18 AAC 50.050(a)(4), (b)(5), 5/26/72; 18 AAC 50.055(a)(4), (b)(5), 1/18.97]
11.7 Inspect every component of the control device before the first operation each season and repair or replace
any component that shows signs of deterioration.
18 AAC 50.055(a)(1), (b)(1) & (3) 1/18/97 and 18 AAC 50.050(a)(1),(b)(1) &(3) 5/26/72
12 Sulfur -Oxide Emissions
12.1 A. Do not emit sulfur dioxide concentrations greater than 500 parts per million using a three hour average.
B. Monitor emissions and relevant operating parameters using monitoring plan conditions M21 and M22.
C. Report using EE2, R4 - R6, R8 and R9. [18 AAC 50.050(c), 5/26/72; 18 ARC 50.055(c), 1/18.97]
12.2 A. Do not bum fuel oil (or used oil mixed with fuel oil) with a sulfur content greater than 0.50% by
weight. Do not burn fuel oil with a sulfur content greater than 0.075% by weight while operating in the
Sulfur Dioxide Special Protection Area (18 AAC 50.025). B. Monitor using M21 and M22. C. Report
using EE2 and R4. [18 AAC 50.350(e)(2)(C), 1/18.97]
12.3 If used oil generated on-site is burned blend one part used oil with at least 3 parts fuel oil (25% used oil to
75% of fuel oil.) Report using R9. [18 AAC 50.050(c), 5/26/72; 18 MC 50.055(c), 1/18.97]
Diesel Engines that do not meet EPA's definition of a "nonroad" engine I /Insignificant Sources
13 Opacity & Particulate Matter Emissions
13.1 A. Do not reduce visibility through the exhaust effluent by more than 20% for a total of more than three
minutes in any one hour. B. Monitor emissions using monitoring plan conditions M25. C. Report using
EE2, RIO. [18 AAC 50.050(a)(1), 5/26/72; 18 AAC 50.055(a)(1), 1/18.97]
13.2 A. Do not emit particulate matter concentrations greater than 0.05 gr/dscf. B. Monitor diesel generators
using monitoring plan conditions M15 and M25. C. Report for diesel generators using EE2, R3, R13.
[18 AAC 50.050(b)(1), 5/26/72; 18 AAC 50.055(b)(1), 1/18.97]
14 Sulfur-Oxide Emissions
14.1 A. Do not emit sulfur dioxide concentrations greater than 500 parts per million. B. Monitor emissions and
associated operating parameters using monitoring plan conditions M21 and M22. C. Report using fuel
analysis or specification from the fuel supplier using EE2, R4 - R6.[18 AAC 50.050(c), 5/26/72; 18 AAC 50.055(c),
1/18.97]
14.2 A. Do not burn fuel oil (or used oil mixed with fuel oil) with a sulfur content greater than 0.50% by
weight. B. Monitor using M21 and M22. C. Report using EE2 and R4.
14.3 A. While operating in the Sulfur Dioxide Special Protection Areas defined in 18 AAC 50.025, the facility
may operate engines for purposes other than producing electricity (i.e., operating screw conveyors), but
these engines may not bum fuel oil with a sulfur content greater than 0.075% by weight. B. Report fuel
sulfur content using fuel analysis or specification from the fuel supplier using EE2. [AS 46.14,215, 6/25/93;
14.4 While operating in the Sulfur Dioxide Special Protection Areas defined in 18 AAC 50.025, do not use
diesel engines for electrical generation. The facility must use high line power for electricity. [AS 46.14.215,
6/25/9318 AAC 50.050(c), 5/26/72; 18 AAC 50.055(c), 1/18.97]
14.5 A. If used oil generated on-site is burned, blend one part used oil to 3 parts fuel oil (25% used oil to 75%
fuel oil) B. Monitor blending using M22. C. Report using R8 and R9. [18 Mc 50.050(c), 5/26/72; 18 AAC
50.055(c), 1/18.97]
Nonroad engines are defined in 40 CFR 89.2. See attachment 7 for the definition.
5
Facility
15 Dust [18 AAC 50.045(d), 1/18/97; 18 AAC 50.050(f), 5/26/72]
15.1 A. Take reasonable precautions' to prevent the release of airborne particulate matter from the following:
1. aggregate piles,
2. treated and untreated soil piles,
3. conveyors and elevators,
4. loading locations,
5. the rotary drum,
6. crushers,
7. screens,
8. baghouse ash discharge,
9. vehicle traffic within the facility boundaries, and
10. any other sources of fugitive dust.
B. Monitor emissions and associated operating parameters using monitoring plan conditions M8, M9,
M11. C: Report using R3, R12 and R13.
15.2 If requested by the department, submit a fugitive dust control plan by a date indicated and comply with
the new plan. The monitor and reporting requirements for this plan are included in Condition 15.1B and
15.IC.
16 Operation & Maintenance [40 C.F.R. 60.11(d), 3/26/87;
18 AAC 50.050(a)(1), (b)(1), 5/26/72; 18 AAC 50.055(a)(1), (b)(1), 1/18.97]
16.1 A. Submit an Operations and Maintenance Plan to the department to illustrate how the facility will be
operated and maintained in order to comply with the emission limits as specified in this permit. B.
Monitor the facility operations and maintenance using M15. C. Report deviations from the plan using
R13.
17 Air Pollution Prohibited [18 AAC 50.110, 5/26/72]
17.1 A. Do not allow any release of emissions in quantities or durations that are injurious to human health or
welfare, animal or plant life, or would unreasonably interfere with the enjoyment of life or property. Take
reasonable actions to address pollution complaints resulting from emissions at the facility. Maintain a log
of all facility complaints received regarding air emissions. The log includes the date and time compliant
received, description of the complaint and the corrective action taken by the facility Tarty. Address
pollution complaints by contacting the person initiating the compliant within 72 hours of the received
complaint. B. Monitor as described in M11. C. Report the contents of this log as required by R12.
18 Coastal Zone Management [18 AAC 50.350(d)(3), 1/18/97]
2 "Reasonable precautions" for asphalt plants include but are not limited to the following, as necessary to prevent
particulate matter from becoming airborne and leaving the facility boundaries:
0 installation and use of hoods, fans, and dust collectors to enclose and vent dusty materials;
0 other covers and enclosures to prevent generation or release of fugitive dust;
0 cleanup of loose material on work surfaces;
0 minimizing drop distances by adjusting conveyor heights or lowering loader buckets to be in contact with surface
of soil or ground before dumping; and
application of asphalt, water, or suitable chemicals to prevent generating fugitive dust.
18.1 If the facility plans to locate in the Aleutians West Coastal Resource Service Area (AWCRSA),
contact the local municipal or tribal officials, landowners, and the AWCRSA to get necessary local permits
or approvals and to find a preferred site for operations. AWCRSA consists of islands from Unalaska to
Attu./This is a state only requirement]
18.2 If the facility plans to locate in the AWCRSA and stores greater than 5,000 gallons of fuel oil, comply
with AWCRSA policies C-10 (storage of petroleum and petroleum products) and C-11 (spill containment and
cleanup equipment). [This is a state only requirement]
19 Location State only enforceable [AS 46.14.215, 6/25193]
19.1 Notify the department, using attachment 2, at least
30 days before tentative date of relocating as required by Alaska Statute Section 46.14.215, and follow-up
with the exact date before the equipment start-up by letter, fax, phone, or e-mail.
20 Fees [18 AAC 50.410; 1/18/97]
20.1 A. Determine the fuel consumed in the facility using monitoring plan condition M13. B. Report fuel
consumption using R7. C. Calculate the sulfur dioxide emissions using the sulfur dioxide formula listed in
Attachment 4.
20.2 Estimate the annual emissions for the period from July 1 to June 30 of the following year. Use the
formulas listed in Attachment 4, and submit to the department no later than August 1.
20.3 Pay the annual emission fees in accordance with the permit application using the formulas listed in
Attachment 4.
Equipment subject to Subpart 000 (40 CFR 60.670)
Equipment subject to Subpart 000 is at a fixed plant with a cumulative rating of all initial crushers greater
than 25 tons per hour; or at a portable plant with greater than 150 tons per hour cumulative ratings. The pieces
of equipment affected by the applicable conditions are rock crushers, grinding mills_screening operations,
bucket elevators, belt conveyors, bagging operations, storage bins, enclosed truck or railcar loading stations.
Please see NI.1-1.4 for requirements in order to replace parts of equipment subject to Subpart 000. Only the
pieces of equipment installed, reconstructed' or modified after August 31, 1983 are subject to Subpart 000.
21 Emission Points without Mechanically Induced Air Flow
Conditions 21.1 (A), (B) and (C) apply to emission points at a processing plant that do not have mechanically
induced airflow to capture or exhaust particulate matter. Performance tests are required.
21.1 A. Do not allow emissions to reduce visibility through the exhaust effluent by more than
a. 15 percent opacity from any crusher at which a capture system is not used, or
[40 CFR 60.672(c), 8/1/85]
b. 10 percent opacity .from each transfer point on a subject belt conveyor or from any other
subject source. [40 CFR 60.672(b), 8/1/85]
This condition does not apply to:
• transferring material from a belt conveyor to a stockpile, or
• truck dumping into any screening operation, feed hopper, or crusher.
13. Monitor operations using Condition M10, M23 and M24.
[40 CFR 60.671, 8/1/85]
[40 CFR 60.672(d), 8/1/85]
Initial crushers are defined as crushers that process some rock that has not been previously crushed.
4
Reconstructed is defined in 40 CFR 60.673.
7
C. Report operations using EE2, R3, and R12 and P1-P9
21.2 A. At all times, and to the extent practicable, maintain and operate their facility including air pollution
control equipment in a manner consistent with good air pollution control practices for minimizing emissions.
13. Monitor using M10. C. Report using R3. [40 CFR 60.11(d), 3/26/87]
21.3 Mark each piece of equipment that is subject to Subpart 000 with the letters "NSPS" that are plainly
visible and are at least 3 inches high, or with other clearly identifiable markings.
[18 AAC 50.350(d)(3), 1/18/97]
Subpart Kb Storage Tanks
22 Volatile Organic Compounds [40 CFR 60.116b(a), (b), 4/8/87]
Condition 22.1 applies to stational), fuel storage tanks that are:
• Constructed, reconstructed or modified after July 23, 1984; and
• Have a capacity:
- between 10,000 and 20,000 gallons;
- between 20,000 and 40,000 gallons and store fuels that exert an equilibrium partial vapor pressure
less than 2.2 psia; or
greater than 40,000 gallons and store fuels that exert an equilibrium partial vapor pressure less than
0.5 psia.
Stationary means the tank is not attached to a mobile vehicle or vessel.
22.1 Keep accessible records showing the dimensions of each storage vessel, its capacity, and the
calculations used to compute its capacity.
8
Compliance Monitoring Plan
Obtain the following records to determine compliance with the permit conditions. Keep these records accessible
for five years. [18 AAC 50.350(h), 1/18/97]
Daily Records
(if operating, keep the following records)
[18 AAC 50.350(d)(3), 1/18/97]
M1. Date: Start time: Stop time(if applicable):
M2. Tons of asphalt produced: tons
M3. Maximum hourly production rate: tons/hr
For a facility using a scrubber:
M4. Minimum pressure drop across the baghouse: inches of water
M5. Maximum pressure drop across the baghouse: inches of water
M6. Maximum differential pressure drop across the scrubber(gas side): inches of water
M7. Minimum scrubber water flow rate: gallons /hr
M8. ❑ Yes Li No Did the Department request a VOC and or dust plan?
If you answered Yes to M8, did the facility operation deviate from the dust or VOC control plan?
M9. ❑ Yes ❑ No If yes, please explain how and why you deviated from the plan.
Signature
Printed Name Title
Deviation from Permit Conditions
M10. Keep a list of all deviations from Conditions 11.1— 22.1. Include [18 AAC 50.350(d)(3), 1/18/97]
• The date;
• The equipment involved;
• The permit condition;
• A description of the deviation; and
• Actions taken to solve the problem.
Complaint Logs
Ml 1. Keep a written log of all [18 AAC 50.350(d)(3), 1/18/97]
• Air pollution complaints received;
• Dates of complaints;
• Investigations to determine the cause of the complaints; and
• Any actions taken to resolve the complaints.
Periodic Monitoring
[18 AAC 50.350(d)(3), 1/18/97]
M12. Conduct visible emission observations, in accordance with 40 C.F.R. 60, Appendix A, Method 9, within
two days of startup at a new location, at least once during a 30-day operating period at the same location, and
when facility starts up after a shut down period of more than 5 days. The test should occur when the facility is
operating at a load typical of the maximum operation during the reporting period. This requirement does not
apply to heaters and insignificant sources. Note the equipment production or operating rate at the time of the
Method 9 observation. Method 9 consists of at least 24 readings, one reading every 15 seconds.
M13. Record the amount of fuel used at the facility on a semiannual basis.
M14. Keep a maintenance log of all baghouse inspections and bag replacement.
M15. Keep a maintenance log of activities performed in accordance with the manufacturer's preventative
maintenance plan and the Operations and Maintenance Plan submitted to the department.
Continuous Monitoring
[18 AAC 50.350(d)(3), 1/18/97]
For facilities using a baghouse:
M16. Monitor the maximum baghouse exit temperature (°F) and differential pressure across the baghouse. Do
not exceed the parameters determined by "manufacturer's data" or source test.
For facilities using a scrubber:
M17. Monitor the minimum and maximum differential pressure across the scrubber (inches of water). Do not
exceed the parameters determined by "manufacturer's data" or 80-130% of source test.
M18. Monitor the water flow rate (gal/min). Maintain at least 80% of the flow used during the source test.
Once in permit
[18 AAC 50.350(d)(3), 1/18/97]
M19. If a source test was not submitted with the application or a previous source test is not on file with the
department, conduct a source test within the first 30 days of operation under this permit. Conduct a particulate
matter source test, in accordance with standard condition 10 within five years of last source test. If the results
for the most recent test for the asphalt plant are 0.036 gr/dscf or greater, conduct another source test within one
year. When conducting a source test, record the information included in Attachment 5. The source test must be
representative of the "typical" facility operation.
Continuously Monitor
M20. A. Do not operate the asphalt plant at a capacity greater than 10% above the maximum throughput
measured during a source test. B. Monitor using M3. C. Report deviations using R3.
[18 AAC 50.050(a)(4), (b)(5), 5/26/72; 18 AAC 50.055(a)(4), (b)(5), 1/18.97; 40 C.F.R. 60.92(a)(1), (2), 10/6/75]
10
Fuel & Used Oil Delivery
[18 AAC 50.350(d)(3), 1/18/97]
M21. Keep a delivery receipt for each shipment of fuel and used oil delivered to the facility. If using fuel oil
other than ASTM DI, D2, or comparable, test each shipment for the fuel oil using the applicable ASTM
Method. Acceptable methods include D975-84; D3120-92; D4152-90; D2622-91 and D4294-90. If using
ASTM D 1, D2, or comparable, keep copies of the fuel delivery records that indicate the ASTM fuel grade as
defined in ASTM 396-92
M22. if burning used oil generated off-site, test the sulfur content of each shipment of used oil that is generated
off-site and record the quantity of fuel accepted or keep supplier's sulfur content analysis. Test any fuel used to
fulfill the blending requirement using ASTM D2880-87 and record the quantity of fuel used in the blend.
Supplier certification is adequate as long as blending does not occur. Samples may be collected by the vendor
from batches prepared by the local supplier for delivery to permittee's facility, or by supplier for bulk shipment
not blended prior to delivery to the permittee's facility.
Subpart 000
M23. Inspect each emission point subject to Condition 21 using Method 9 of 40 C.F.R. 60, Appendix A at the
following times: (Use Attachment 1)
a. within 2 working days after startup at each new location
b. within 2 working days after startup after the processing plant has been shut down for
30-consecutive days; and
c. at least once in every 14 days of operation.
[18 AAC 50.350(d)(3), 1/18/97; 40 C.F.R. 60.675(c), 2/4/89]
M24 If a performance test was not included with the permit application conduct a performance test as
described by 40 C.F.R. 60.675(b)(1) and (2), within the first 60 days of operation under this permit. A
performance test includes a Method 9 to determine visible emissions. Use the form provided in Attachment 1.
Follow the requirements for a performance test given in P1, P3, P4 and P7. Conduct subsequent performance
tests within 5 years of the most recent test.
11
M25 Visible Emissions and Particulate Matter Inspections for diesel engines. [18 AAC 350(d)(3) 1 /18/97]
A flow chart contained in ATTACHMENT 8 illustrates this tiered monitoring approach.
A.1 Smoke /No smoke Inspection Period
Once a day for the first 30 operating days of this permit, observe each engine, boiler, and heater to determine the
presence or absence of smoke (a smoke /no -smoke inspection). If smoke, excluding water vapor, is seen during
the inspection, do one of the following supplemental actions:
• Do maintenance to eliminate the smoke, and repeat the smoke /no smoke inspection within 72 operating
hours; if no smoke is seen during the required repeat inspection, start a new 30 day inspection period; or,
• Within 10 calendar days, not operating days, of the initial inspection that showed smoke, do a visible
emission inspection that conforms to EPA Method 9 in 40 C.F.R. 60, Appendix A, three times, once every
two hours. See section B of this condition for more detail on the Method 9 test.
A.2 Monthly monitoring
• If no smoke is seen during the first 30 days of operation during the smoke /no smoke inspection, continue
smoke /no smoke inspections on a monthly basis to check for engine or combustion unit degradation.
If smoke is seen during any monthly inspection, start a new 30 -day smoke /no smoke inspection period or do
the Method 9 testing described in Section B of this condition.
A.3 How to perform the smoke /no smoke inspection
For each smoke /no smoke inspection, record the
• Date
• Engine or equipment number
• Load,
• Plume background, and
• Visible emission observation.
Do all inspections required by this condition at the highest load for that engine or combustion unit expected for
the month. If this is not practicable or the test is less than 80% of design load, please attach an explanation.
Exceptions:
The visible emission inspections are not required in a given month for a boiler or heater, if the rated input
capacity is less than 1,700,000 Btu/hr.
B. Method 9
If the facility is not able to eliminate visible emissions through maintenance then the facility is required to
perform an opacity test using EPA Method 9 within 10 calendar days of the initial smoke /no.smoke inspection
that showed smoke. The opacity test consists of three Method 9 tests, taken with minimum of two hours in
between each test.
If the results of each of the three Method 9 tests are zero, then the facility may begin a new 30 -day smoke /no
smoke inspection as described in section A or perform one Method 9 reading each subsequent month.
If the results of each of the three Method 9 reading are greater than zero but less than 20% opacity, perform one
Method 9 reading each subsequent month.
If any of the three - minute average of the method 9 readings are greater than 20 %, the facility is in violation of
the opacity standard.
If at any time the opacity readings are greater than 1 2% opacity, in addition to the requirements of this section,
please see section C conceming particulate emissions.
If the required monthly Method 9 opaci reading for three consecutive months is zero, the permittee can
continue performing Method 9 readings month or smoke/no smoke inspection as
described in section Al ofthis monitoring condition. 000smounisuueoouoog the 30-day test the permittee
may perform monthly smoke/no smoke inspections every month instead of Method 9 readings.
For each Method 9 inspection, use the form in Attachment 1 of this permit.
C. Particulate Matter
If the Method 9 readings required in "B" are greater than 12% but less than 20% opacity, then particulate matter
emissions may exceed the particulate matter standard. Perform a Method 5 or other EPA approved method
source test (within 30 days of Method 9 reading that exceeded 12%) to determine if the standard is maintained
and that the particulate emissions are less than 0.05 gr/dscf. Continue the Method 9 readings as described in
"B" Take Method 9 readings during the particulate matter tests in order to calculate an average opacity that
corresponds to the particulate matter emissions. Submit the test results to the Department within 30 days of the
testing completion. [18 AAC 350(d)(3) 1/18/97]
Performance Tests
(as required by 40 CFR 60.675 conducted as specified in 40 CFR 60.8)
P1 Perform performance tests within 60 days after achieving the maximum production rat of the
equipment subject to ufeduru\ standard but not later than 180 days of initial startup). The depunbucotaod/or
EPA may request additional performance test at their discretion. Please see M 19 for required perforrnance
testing for existing units. See 40 CFR 60.8(a).
P2 Conduct and report performance tests as specified in the particular Subpart unless the EPA has approved
an alternative testing and reporting. See 40 CFR 60.8(b).
P3 Perforrnance tests shall occur at the facility's representative operation. Submit information so tha the
department and/or EPA can determine the facility's representative operation. .See 40 CFR 60.8(c).
P4 Notify the department and EPA at leas 30 days prior to the start of the performance tests. See
40 CFR 60.8(d).
P5 Provide adequate sampling ports at appropriate locations as required by the applicable EPA method.
See 40 CFR 60.8(e).
P0 Perform the performance test using the applicable test method at leas 3 separate runs or as specified in
their app!icable subpart. If the one of the three runs are interrupted interrupted by circumstances beyon1 the 's
control then the EPA at their discretion may approve averaging only two runs. See 40 CFR 60.8(f).
P7 The initial opacity (visible emission) performance test must be at least 3 hours (30 six minute
during periods ofoperation. Iboonu6tv standard applies at all times except for startup, shutdown and
malfunction. See 40 CFR 60.11(b) and (c).
P8 At all times, and to the extent practicable, maintain and operate their facility including air pollution
control equipment iuumuuuoccouosteu1vvdb000duicnolbutinnuootnol practices for minimizing emissions.
See 4UCFR60.}1(d)
P9 Postmark all submittals required by federal standards by the date required by the department and EPA.
See 40 CFR 60.19(b)
13
Reporting Requirements
The department requires a facility operator using this general permit to perform four types of reports:
(1) reporting emissions that have the potential to violate a permit condition, (2) semiannual operating reports,
(3) notification of replacement of certain equipment, and (4) annual compliance certifications.
Reporting of Excess Emissions:
EE1. Potentially Injurious Emissions [18 AAC 50.350(i)(1), 1/18/97]
Notify the immediately upon discovery of any emission that has the potential to violate Condition 17, at one of
the following numbers:
Central Alaska 269-7500 Fax 269-7648
Northern Alaska 451-2121 Fax 451-2362
Southeast Alaska 465-5340 Fax 465-2237
Outside of normal business hours: 1-800-478-2237
Fax a completed Excess Emission Notification form (Attachment 6) within 24 hours to the Anchorage air
quality office at (907) 269-7508.
EE2. Opacity, Particulate Matter and Fuel Sulfur Violations [18 AAC 50.350(i)(1), 1/18/97]
Notify the department within two days of:
• Completion of a Method 9 inspection showing a violation of a visible emission requirement;
• Receipt of results of a Method 5 or Method 17 performance test that shows a violation of a particulate
matter standard; or
• Burning any fuel that exceeds 0.50% fuel sulfur or 0.075% fuel sulfur in a Sulfur Dioxide Special Protection
Area described in 18 AAC 50.025.
Immediate Reporting: [18 MC 50.350(i)(1), 1/18/97]
Rl. Notify the department within two days of a pollution-control equipment breakdown.
14
Semiannual Operating Reporting: [18 AAC 50.350(d)(3), 18 AAC 50.350(i)(5), 1/18/97]
R2. Submit the following information to the department :
Submit three copies, including the original, of this semi-annual operating report to:
Alaska Department of Environmental Conservation
Air Quality Maintenance Section
610 University Ave
Fairbanks. Alaska 99709
Facility Name Date:
A Semiannual Compliance Report from
(Select the correct operating period)
o 10/1/ - 3/31/ Due oil April 30
• 4/1/ - 9/30/ Due on October 30
R3. Did the facility deviate from any perMit requirements or a fugitive dust or VOC control plan?
O Yes
• No
If yes, explain (1) how you deviated from the plan, (2) the cause of the deviation, and (3) why it was necessary.
Attach:
(a) Copies of all visible emission reading results.
(b) Copies of all particulate matter performance test reports.
(c) A description of any complaints received, including:
• Date the complaint was received and the date the facility responded,
• Nature of the complaint,
• Results of the investigation, and
• Steps taken to resolve the complaint.
(d) A list of any deviations from permit conditions; include:
• The date or period
• Equipment involved
• The permit condition
• The nature of the deviation
Actions taken to solve the problem.
R4. List Fuel Delivery dates and grades:
Dates: Quantity: Fuel Grade: or Sulfur Content:
15
R5. List Off-Site Used Oil Delivery:
Dates:
Quantity: Sulfur Content:
R6. List Burned Used Oil (generated on-site):
Dates: Quantity: Sulfur Content:
R7. List the total amount of fuel used at the facility.
R8. If you blended fuel to meet the sulfur requirement, how did you ensure your facility blended the amount of
used oil burned to achieve a 0.5% Sulfur content by weight or less mix?
R9. How did you ensure your facility blended the amount of used oil generated on-site to achieve a 1 to 3 mix
(25% used oil to 75% fuel oil)?
R10. Attach copies of the visible emission readings taken at startup at a new location, 30 day at the same
location and restarting after 5 days of non operation.
R11. List the daily asphalt production rate, the total number of operation hours and peak hourly rate and percent
fines.
R12. Provide a copy of any complaints received, the nature of the complaint, and the steps taken to resolve the
complaint.
R13. Report any deviations from the facility's submitted Operations and Maintenance Plan..
Based on information and belief formed after reasonable inquiry, I certify that the facility meets the qualifying
criteria and that the statements and information in and attached to this document are true, accurate, and
complete.
Signature
Printed Name
Title
16
Replacing Equipment Used in Crushing and Grinding
Built Before August 31, 1983
At your processing plant, equipment that was not constructed, reconstructed, or modified after
August 31, 1983, is not subject to Subpart 000. Replacing certain parts of it with equipment that is
the same size or smaller does not make your plant subject to Subpart 000, unless you replace all
sources in a production line, but you must notify EPA and the department of the replacement.
If equipment is replaced with larger equipment, use Condition N2 to report.
Ni. Notifying the Department and EPA: Replacement of Equipment
[40 C.F.R. 60.676(a), 2/14/89; 18 AAC 50.200, 1/18/97]
Notify the department before replacing the following equipment. In addition to the information listed
in Conditions N1.1 — N1.4, give enough detail to identify the replacement equipment. Also list any
control device used to reduce particulate matter emissions from the equipment being replaced,. and all
other sources controlled by that control device.
N1.1. Before replacing a crusher, grinding mill, bucket elevator, bagging operation, or enclosed truck
or railcar loading station, send the department information describing
• the rated capacity (tons/hour) and age of the equipment being replaced, and
• the rated capacity (tons/hour) of the replacement equipment.
N1.2. Before replacing the screening operation, send the department information describing .
• the total surface area and age of the top screen from the existing screening operation, and
• the total surface area of the top screen of the replacement.
N1.3. Before replacing a conveyor belt, send the department information describing
• the width and age of the existing belt, and
• the width of the replacement belt.
N1.4. Before replacing a storage bin, send the department information describing
• the rated capacity (tons) and age of the existing storage bins, and
• the rated capacity (tons) of the replacement storage bins.
Send notifications for condition N 1 to:
Director of Emission Standards and.Engineering Division
(MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Air Quality Maintenance Section
Alaska Department of Environmental Conservation
610 University Ave
Fairbanks, AK 99709
17
New Equipment Subject to Subpart 000
N2. Notifying the Department and EPA: New, Reconstructed, or Modified Equipment
For a new or modified piece of equipment that becomes subject to Subpart 000, send the department and EPA
Region 10 any of the following information that applies during the life of this permit:
N2.1. The anticipated date of initial startup, postmarked between 30 and 60 days before anticipated startup.
[40 C.F.R. 60.7(a)(2), 12/13/90; 18 AAC 50.200, 1/18/97]
N2.2. The actual date of initial startup postmarked within 15 days after initial startup.
[40 C.F.R. 60.7(a)(3), 12/13/90; 18 AC 50.200, 1/18/97]
N2.3. For modification to an existing piece of equipment subject to NSPS Subpart 000, information describing:
• the precise nature of the change
• the present and proposed emission control systems
• the capacity before and after the change
• the expected completion date.
For this condition:
A modification is a change to the equipment that increases
• The surface area of an initial screen
• The width of a conveyor belt, or
▪ The rated capacity of any other equipment
This condition does not apply to
• Routine maintenance, replacement, and repair
• Increase in production rate accomplished without capital expenditure
▪ Increase in hours of operation
• Use of alternative raw material if the equipment is already designed to handle that raw material
• Addition or pollution control equipment
Postmark 60 days or as soon as practicable before the change.
[40 C.F.R. 60.7(a)(4), 12/13/90; 18 AAC 50.200, 1/18/97]
N2.4. The date of initial Method 9 observations, postmarked not less than 30 days before the date of the
observations. [40 C.F.R. 60.7(a)(6), 12/13/90; 18 AAC 50.200, 1/18/97]
Send notifications for condition N2 to:
Laurie Kral
EPA Region 10
1200 Sixth Ave
Seattle, WA 98101
Air Quality Maintenance Section
Alaska Department of Environmental Conservation
610 University Ave
Fairbanks, AK 99709
Annual Compliance Certification
Certify compliance annually by February 1 of each year for the period from January 1 to December 31 of the previo us year in accordance with the format
below. Submit two copies and the original to the ADEC, Air Quality Maintenance, 610 University Ave, Fairbanks, Alaska 99709.
Also submit a copy to: US EPA Region 10, Office of Air Quality, 1200 66 Avenue, M/S OAQ -107, Seattle, Washington 98101
Permittee: Facility Name: Certification Period:
Condition
Compliance Status
Continuous/Intermittent
Method used to determine compliance
1 — 6
These conditions place no certification obligation on permittee
7
0 In Compliance
❑ Not in Compliance
0 Not Applicable (attach
explanation)
❑ Continuous
❑ Intermittent
❑ Dates access granted, or not requested
0 Other (attach description & documentation)
8
0 In Compliance
❑ Not in Compliance
0 Not Applicable(attach
explanation)
❑ Continuous
0 Intermittent
0 Dates submitted
0 Other (attach description & documentation)
9
0 In Compliance
❑ Not in Compliance
O Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
'
❑ All reports /documents certified
❑ Dates excess emission reports suhmitted
10
❑ In Compliance
O Not in Compliance
❑ Not Applicable(attach
explanation)
0 Continuous
❑ Intermittent
0 Dates submitted, or source test requested
0 Other (attach description & documentation)
11.1
❑ In Compliance
O Not in Compliance
❑ Not Applicable(attach
explanation)
❑ Continuous
0 Intermittent
0 All records kept
❑ Other (attach description & documentation)
1 1.2
0 In Compliance
❑ Not in Compliance
0 Not Applicable(attach
explanation)
❑ Continuous
❑ Intermittent
0 All records kept
0 Other (attach description & documentation) .
1 1.3
0 In Compliance
0 Not in Compliance
❑ Not Applicable(attach
explanation)
0 Continuous
❑ Intermittent
❑ All records kept
0 Other (attach description & documentation)
11.4
0 In Compliance
❑ Not in Compliance
O Not Applicable(attach
explanation)
❑ Continuous
❑ Intermittent
❑ All records kept
0 Other (attach description & documentation)
11.5
❑ In Compliance
❑ Not in Compliance
0 Not Applicable(attach
explanation)
❑ Continuous
❑ Intermittent
0 All records kept
0 Other (attach description & documentation)
1 1.6
•
0 In Compliance
❑ Not in Compliance
0 Not Applicable(attach
explanation)
❑ Continuous
❑ Intermittent
❑ All records kept
❑ Other (attach description & documentation)
I I.7
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
❑ Intemtittent
❑ All records kept
❑ Other (attach description & documentation)
19
20
12.1
a In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
0 All records kept
0 Other (attach description & documentation)
12.2
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
0 All records kept
0 Other (attach description & documentation)
12.3
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
'
0 All records kept
0 Other (attach description & documentation)
13.1
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
.
0 All records kept
0 Other (attach description & documentation)
13.2
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
exp(anation)
• 0 Continuous
0 Intermittent
0 All records kept
0 Other (attach description & documentation) '
14.1
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
D Continuous
0 Intermittent
0 All records kept
0 Other (attach description & documentation)
14.2
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
Cl'All records kept
0 Other (attach description & documentation)
14.3
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
0 All records kept
q Other (attach description & documentation)
14.4
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
0 All records kept
0 Other (attach description & documentation)
15.1
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
0 All records kept
0 Other (attach descriptinn & documentation)
o
15.2
E3 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
.
E3 All records kept
0 Other (attach description & documentation)
16.1
0 In Compliance
0 Not in Compliance
0 Not Applicable(attach
explanation)
0 Continuous
0 Intermittent
0 All records kept
0 Other (attach description & documentation)
20
Based on information and belief formed after reasonable inquiry, certify that the facility meets the qualifying criteria and
that the statements and information in and attached to this document are true, accurate, and complete.
Signature
Printed Name
State of Alaska, City of
a,
Title
, Borough of
On this day of , 19 before me personally appeared
whose identity was proved to me on the basis of satisfactory evidence to be the person whose name is subscribed t this
instrument, and acknowledged that he (she) executed the same.
Notary Public
My Commission Expires on
21
17. I
❑ In Compliance
0 Not in Compliance
❑ Not Applicable (attach
explanation)
❑ Continuous
❑ Intermittent
❑ All records kept
❑ Other (attach description & documentation)
18.1
❑ In Compliance
❑ Not in Compliance
❑ Not Applicable (attach
explanation)
❑ Continuous
❑ Intermittent
0 All records kept
❑ Other (attach description & documentation)
18.2
❑ In Compliance
❑ Not in Compliance
0 Not Applicable (attach
explanation)
❑ Continuous
❑ Intermittent
-
❑ All records kept
❑ Other (attach description & documentation)
19.1
❑ In Compliance
❑ Not in Compliance
❑ Not Applicable(attach
explanation)
❑ Continuous
❑ Intermittent
❑ All records kept
❑ Other (attach description & documentation)
20.1
❑ In Compliance
❑ Not in Compliance
❑ Not Applicable(attach
explanation)
❑ Continuous
❑ Intermittent
❑ All records kept
❑ Other (attach description & documentation)
20.2
❑ In Compliance
❑ Not in Compliance
❑ Not Applicable(attach
explanation)
❑ Continuous
❑ Intermittent
❑ All records kept
❑ Other (attach description & documentation)
20.3
❑ In Compliance
❑ Not in Compliance
❑ Not Applicable(attach
explanation)
❑ Continuous
❑ Intermittent
-
❑ All records kept
❑ Other (attach description & documentation)
21.1
❑ In Compliance
❑ Not in Compliance
❑ Not Applicable (attach
explanation)
❑ Continuous
❑ Intermittent
❑ All records kept
❑ Other (attach description & documentation)
21.2
❑ In Compliance
❑ Not in Compliance
❑ Not Applicable (attach
explanation)
❑ Continuous
❑ Intermittent
0 All records kept
❑ Other (attach description & documentation)
22. I
❑ In Compliance
❑ Not in Compliance
❑ Not Applicable (attach
explanation)
❑ Continuous
❑ Intermittent
❑ All records kept
❑ Other (attach description & documentation)
Based on information and belief formed after reasonable inquiry, certify that the facility meets the qualifying criteria and
that the statements and information in and attached to this document are true, accurate, and complete.
Signature
Printed Name
State of Alaska, City of
a,
Title
, Borough of
On this day of , 19 before me personally appeared
whose identity was proved to me on the basis of satisfactory evidence to be the person whose name is subscribed t this
instrument, and acknowledged that he (she) executed the same.
Notary Public
My Commission Expires on
21
Attachment 1 -Visible Emissions Forms Page 1
When doing readings: Maintain a distance of at least 15 feet from the emission point; When p
to minimize interference between sources; If interference cannot be avoided between sources,
the sources involved: and If wet dust suppression is used, read the part of the plume where the
Certified Observer
Company
Location
Test No. Date
Asphalt Plant: Source
Production Rate:
Hrs. of observation:
Tons /hr
Clock Time
suw�
via
BOW:WA LAYOUT
Sun bcetioe
SKTCH
Paw
X Emtimien Point
Omervaa Po. ,o,
Line
Final
Observer location
Distance to discharge
Direction from discharge
Height of observer point
Clock Time
Initial'
Final
Observer location
Distance to discharge
Direction from discharge
Height of observer point
Background description
Weather conditions
Wind Direction
Wind speed
Ambient Temperature
Relative humidity
Sky conditions: (clear, overcast. %
clouds, etc.)
Plume description:
Color
Distance visible
Water droplet plume?
(attached or detached ?)
Other information
Use the procedures specified in 40 C.F.R. 60, Appendix A, Method 9 to perform this observation.
22
Visible Emissions Observation record
Part 2, Observations
Page of
Company Certified Observer
Test Number Clock time
A Minimum reading is 24, every 15 seconds for a total length of 6 minutes
Date:
Visibility reduction every 15
Seconds (Opacity)
Steam Plume
(check if applicable)
Comments
Hr
Min
0
15
30
45
Attached
Detached
Additional information:
Observer Signature
Average Opacity Summary
Set
Number
Time
Start—End
Opacity
Sum
Average
23
Attachment 2. Portable Facility Relocation/Operation Notification
Submit the information specified below to the Department's Air Quality Maintenance Section, thirty days before
tentative moving of the plant to any new location, and the exact date before startup by telephone, fax, e-mail or letter.
Name of Firm:
Equipment/Facility to be relocated
Contact Person:
Telephone:
New plant location (include site maps):
Approximate start-up and shut-down dates:
Comments:
I hereby certify that the information contained in this notification is to the best of my knowledge and belief, is true,.
complete, and accurate.
Signature: Printed Name:
Title: Telephone:
Submit this information to
Alaska Department of Environmental Conservation
Air and Water Quality Division - Air Permitting
610 University Avenue
Fairbanks, Alaska 99709 - 3643
24
Attachment 3. Citation Table
Condition #'s
Required By
Federal Citation
Incorporated by
reference in
Approved SIP
Citation
Current State
Regulation
1 -10
18 AAC 50.350(6)(3)
18 AAC 50.345(x)
18 AAC 50.350(d)(1)(C)
18 AAC 50.055(a)(4)
18 AAC 50.350(d)(3)
18 AAC 50.055(b)(5)
11
18 AAC 50.350(d)(I)(A)
40 C.F.R. 52.75
18 AAC 50.040(e)
18 AAC 50.050(a)(4)
18 AAC 50.350(d)(3)
18 AAC 50.050(b)(5)
.
18 AAC 50.350(d)(1)(A)
40 C.F.R. 60.92
18 AAC 50.040(a)
18 AAC 50.350(d)(3)
12.1
123
18 AAC 50.350(d)(1)(C)
18 AAC 50.350(d)(3)
18 AAC 50.055(c)
18 AAC 50.350(d)(1)(A)
40 C.F.R. 52.75
18 AAC 50.040(e)
18 AAC 50.050(c)
18 AAC 50.350(d)(3)
12.2
18 AAC 50.350(e)(2)(A)
18 AAC 50.350(d)(1)(C)
18 AAC 50.055(a)(1)
13.1
18 AAC 50.350(d)(3)
18 AAC 50.055(b)(1)
13.2
18 AAC 50.350(d)(1)(A)
40 C.F.R. 52.75
18 AAC 50.040(e)
18 AAC 50.050(a)(1)
18 AAC 50.350(d)(3)
18 AAC 50.050(6)(1)
18 AAC 50.350(e)(2)(A)
18 AAC 50.350(d)(1)(C)
18 AAC 50.055(c)
14
18 AAC 50.350(d)(3)
.
18 AAC 50.350(d)(1)(A)
40 C.F.R. 52.75
18 AAC 50.040(e)
18 AAC 50.050(c)
18 AAC 50.350(d)(3)
18 AAC 50.350 (0(3)
18 AAC 50.045(d)
15
18 AAC 50.350(d)(1)(A)
40 C.F.R. 52.75
18 AAC 50,040(e)
18 AAC 50.050(0
18 AAC 50.350(d)(3)
18 AAC 50.350(d)(1)(C)
18 AAC 50.055(a)(l)
16
18 AAC 50.350(d)(3)
18 AAC 50.055(b)(1)
18 AAC 50.350(d)(1)(A)
40 C.F.R. 52.75
18 AAC 50.040(e)
18 AAC 50.050(a)(1)
18 AAC 50.350(d)(3)
18 AAC 50.050(b)(l)
17
18 AAC 50.350(0(3
40 C.F.R. 52.75
18 AAC 50.040(e)
18 AAC 50.110
18 AAC 50.110
18
18 AAC 50.350(d)(1)(D)
18 AAC 50.350(0(3)
.
19
18 AAC 50.350(f)(3)
AS 46.14.215
20
18 AAC 50.350(c)
18 AAC 50.410(a)
18 AAC 50 420(a)
21
18 AAC 50.350(d)(1)(A)
40 C.F.R. 60.672(6), (c)
18 AAC 50.040(a)(2)(FF)
18 AAC 50.350(d)(3)
22
18 AAC 50.350(d)(1)(A)
40 C.F.R. 60.116b(a),
18 AAC 50,040(a)(2)(M)
18 AAC 50.055(a)(1)
18 AAC 50.350(d)(3)
(b)
18 AAC 50.350(d)(3)
Ml - M22
I8 AAC 50.350(g)
18 AAC 50.350(h)
M23
18 AAC 50.350(d)(1)(A)
40 C.F.R. 60.675(b), (c)
18 AAC 50.040(a)(2)(FF)
M24
18 AAC 50.350(d)(3)
M25
18 AAC 50.350(d)(1)(A)
40 C.F.R. 60.8
18 AAC 50.040(a)(1)
P1 - P9
18 AAC 50.350(d)(3)
40 C.F.R. 60.11
40 C.F.R. 60.19
EE1
18 AAC 50.350(d)(3)
EE2
18 AAC 50.350(i)
R1 -R13
18 AAC 50,350(d)(1)(A)
40 C.F.R. 60.676(a)
18 AAC 50.040(a)(2)(FF)
Nl
18 AAC 50.350(d)(3)
18 AAC 50.350(i)
18 AAC 50.350(0(3)
18 AAC 50.200
25
Attachment 4:
Emission Fee Calculations
For the Period July 1 of the previous year to June 30 of the current year. Emission
fees are due no later than August 1 of the current year.
18 AAC 50.350(d)(1)(A)
40 C.F.R. 60.7
18 AAC 50.040(a)(1)
0.0000345 for diesel fired batch mix 0.00017 for nat gas fired batch mix
0.000018 for diesel fired drum mix 0.000028 for nat gas fired drum mix
NOx TPY (C1) from diesel generators Multiply kW hours by 0.000020786 = C1
CO TPY (C2) from diesel generators Multiply kW hours by 0.000004479 = C2
18 AAC 50.350(d)(3)
Determine Total NOx A + C1 = X Determine Total CO B + C2 = Y
If either X or Y or D is less than 10 tons do not include in calculation below.
NOX (X) + CO (Y) + SO2 (D) = Total emissions in tons per year (TPY)
Total emissions (TPY) x $5.07 = Emission Fee in $
N2
18 AAC 50.350(i)
18 AAC 50.350(f)(3)
18 AAC 50.200
Attachment 4:
Emission Fee Calculations
For the Period July 1 of the previous year to June 30 of the current year. Emission
fees are due no later than August 1 of the current year.
NOx TPY (A) = tons of asphalt produced multiplied by
0.000085 for diesel fired batch mix 0.0000125 for nat gas fired batch mix
0.0000375 for diesel fired drum mix 0.000015 for nat gas fired drum mix
CO TPY (B) = tons of asphalt produced multiplied by
0.0000345 for diesel fired batch mix 0.00017 for nat gas fired batch mix
0.000018 for diesel fired drum mix 0.000028 for nat gas fired drum mix
NOx TPY (C1) from diesel generators Multiply kW hours by 0.000020786 = C1
CO TPY (C2) from diesel generators Multiply kW hours by 0.000004479 = C2
SO2 TPY (D) = gals of diesel burned for the year multiplied by 0.0000355
Determine Total NOx A + C1 = X Determine Total CO B + C2 = Y
If either X or Y or D is less than 10 tons do not include in calculation below.
NOX (X) + CO (Y) + SO2 (D) = Total emissions in tons per year (TPY)
Total emissions (TPY) x $5.07 = Emission Fee in $
26
•
ATTACHMENT 5
'Continuously monitor the following parameters and record the average value
❑ the asphalt production rate: tons/hour
❑ the fines percentage ( -200 mesh
❑ Method 9 readings during the Method 5 testing
For a facility using a baghouse:
❑ the baghouse exit temperature: °F
❑ the pressure drop across the baghouse: inches of water
For a facility using a scrubber:
❑ the pressure drop across the scrubber: inches of water
❑ water flow rate: gallons /minute
❑ particulate control: gallons /minute
❑ the fines percentage ( -200 mesh)
Obtain the following:
For a facility using a scrubber, record the following parameters:
❑ pond size:
❑ pond depth:
❑ type of liner used:
❑ is the water recycled CI Yes ❑ No
makeup water flow rate: gallons/hr
ATTACHMENT 6
Excess Emission Notification Form
Submit to: Facsimile: (907) 269-7508 Telephone: (907) 269-8888 Email: airredortseenvircon.state.ak.us
Company Name Facility Name
1. Event Information (Use 24-hour clock):
END Time: STARTTime: Duration (hr:min):
Date:
Date:
Total:
2. Cause of Event (Check all that apply):
0 START UP 0 UPSET CONDITION 0 CONTROL EQUIPMENT
CI SHUT DOWN 0 SCHEDULED MAINTENANCE 0 OTHER
Provide a detailed description of what happened. Attach additional sheets as necessary.
3. Sources Involved:
Identify each Emission Source involved in the event, using the same identification number and name as in the Permit.
List any Control Device or Monitoring System affected by the event. Attach additional sheets as necessary.
Source ID No. Source Name Description Control Device
4. Emission Standard Exceeded:
Identify each Emission Standard and Permit Condition exceeded during the event. Describe in detail, the extent to
which each Standard or Condition was exceeded. List ALL known or suspected injuries or health impacts. Attach
additional sheets as necessary.
Standard or Condition Limit Excee de n ce
5. Emission Reduction:
Describe in detail, ALL of the measures taken to minimize andlor control emissions during the event. Attach
additional sheets as necessary.
6. Corrective Actions:
Describe in detail, ALL of the corrective actions taken to restore the system to normal operation. Attach additional
sheets as necessary.
Based on information and belief formed after reasonable inquiry, I certify that the statements and information in and attached to
this document are true, accurate, and complete.
Printed Name
Signature Date:
28
ATTACHMENT 7.
[Code of Federal Regulations] [Revised as of July 1, 1997]
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR89.2]
TITLE 40-- PROTECTION OF ENVIRONMENT
CHAPTER I-- ENVIRONMENTAL PROTECTION AGENCY
PART 89 -- CONTROL OF EMISSIONS FROM NEW AND IN -USE NONROAD ENGINES- -Table of
Contents
Subpart A-- General
Sec. 89.2 Definitions.
The following definitions apply to part 89. All terms not defined herein have the meaning given the in the
Act.
Nonroad compression - ignition engine means a nonroad engine which utilizes the compression - ignition
combustion cycle.
Nonroad engine means:
(1) Except as discussed in paragraph (2) of this definition, a
nonroad engine is any internal combustion engine:
(i) in or on a piece of equipment that is self - propelled or serves a dual purpose by both propelling itself and
performing another function (such as garden tractors, off - highway mobile cranes and bulldozers); or
(ii) in or on a piece of equipment that is intended to be propelled while performing its function (such as
lawnmowers and string trimmers); or
(iii) that, by itself or in or on a piece of equipment, is portable or transportable, meaning designed to be and
capable of being carried or moved from one location to another. Indicia of transportability include, but are not
limited to, wheels, skids, carrying handles, dolly, trailer,
or platform.
(2) An internal combustion engine is not a nonroad engine if:
(i) the engine is used to propel a motor vehicle or a vehicle used solely for competition, or is subject to
standards promulgated under section 202 of the Act; or
(ii) the engine is regulated by a federal New Source Performance Standard promulgated under section 111 of
the Act; or
(iii) the engine otherwise included in paragraph (1)(iii) of this definition remains or will remain at a
location for more than 1.2 consecutive months or a shorter period of time for an engine located at a
seasonal source. A location is any single site at a building, structure, facility, or installation. Any engine
(or engines) that replaces an engine at a location and that is intended to perform the same or similar
function as the engine replaced will be included in calculating the consecutive time period. An engine
located at a seasonal source is an engine that remains at a seasonal source during the full annual
operating period of the seasonal source. A seasonal source is a stationary source that remains in a single
location on a permanent basis (i.e., at least two years) and that operates at that single location
approximately three months (or more) each year. This paragraph does not apply to an engine after the
engine is removed from the location.
[59 FR 31335, June 17, 1994, as amended at 61 FR 52102, Oct. 4, 1996]
29
ATTACHMENT 8
Visibility and Particulate Monitoring
Flow Chart
Do smoke /no smoke
inspection every day
Yes
Yes
Do maintenance to
remove smoke and
retest within 72 hours
of the smoke
inspection
Noy
After 30 days of
no smoke, do
inspections
once per month.
0
Do three Method 9
tests at a minimum
of two hours
between each test
to determine typical
operation.
Ef pacity is greater than
it is a violation of the
y standard. Particulat
atter test required.
Highest
Result
>0%
< =20%
Do a Method 9
reading once
per month to
monitor typical
operation
If Method 9 readings are
0% for three consecutive
months
Continue Method 9
readings once per month
Do a Method 5 particulate source
test to show this engine complies
with the 0.05 grains /dry standard
cubic foot
.0%
< =12%
>12%
>20%
30
A Citizen's Guide to Thermal Desorption Page 1 of 4
United States Environmental Protection Agency
Solid Waste and Emergency Response (5102G)
EPA 542 -F -96 -005 April 1996
EPA A Citizen's Guide to
Thermal Desorption
Technology Innovation Office Technology Fact Sheet
What is thermal desorption?
Thermal desorption is an innovative treatment technology that treats soils contaminated with
hazardous wastes by heating soils to temperatures of 200 - 1,000 °F so that contaminants with low
boiling points will vaporize (turn into gas) and, consequently, separate from the soil. (The other soil
contaminants, if any, are treated by other methods.) The vaporized contaminants are collected and
treated, typically by an air emissions treatment system.
Thermal desorption is a different treatment process than incineration. Thermal desorption uses heat to
physically separate the contaminants from the soil. The contaminants then require further treatment.
Incineration uses heat to actually destroy the contaminants.
A Quick Look at Thermal Desorption
• Heats soil at relatively low temperatures to vaporize contaminants and remove them.
• Is most effective at treating volatile organic compounds, semi- volatile organic compounds
and other organic contaminants, such as polychlorinated biphenyls (PCBs), and polyaromatic
hydrocarbons (PAHs) and pesticides.
• Is useful for separating organic contaminants from refining wastes, coal tar wastes, wood -
treatment wastes and paint waste.
How does thermal desorption work?
Typical thermal desorption systems (Figure 1) consist of three components: the pre - treatment and
material handling system, the desorption unit, and the post- treatment system for both the gas
(vaporized contaminants) and the solid (remaining soil).
Figure 1
The Thermal Desorption Process
Vapor
tr Errfi l n
Contro&&
Coadensor
Organic liquid or
Further Treatment
or Disposal
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A Citizen's Guide to Thermal Desorption Page 2 of 4
'
Pretreatment and Material Handling System
Pretreatment of contaminated material involves sifting it to remove large clods and foreign debris. If
the contaminated material is very wet or has a high level of contaminant, it may need to be blended
with sand or dried to make it a more uniform mass for treatment in the desorption unit.
Desorption Unit
The function of the desorption unit is to heat the contaminated soil to a sufficient temperature for a
sufficient period to dry it and vaporize the contaminants from the soil. A common design for the
desorber unit is a rotary desorber, which consists of a rotating cylindrical metal drum. In a direct -
fired rotary desorber, the material enters the rotating cylinder and is heated by direct contact with a
flame or the hot gases coming off a flame. In an indirect -fired rotary desorber, the contaminated soil
does not come into contact with a flame or combustion gases. Instead, the outside of the metal
cylinder is heated and the hot metal indirectly heats the soil tumbling inside. As the waste is heated,
the contaminants vaporize, and then become part of the gas stream of air and contaminated vapors
flowing through the desorber towards the post - treatment system. An inert, or non - reactive gas, such
as nitrogen, may be added to the gas stream to prevent the vaporized contaminants from catching fire
in the desorption unit and to aid in vaporizing and removing the contaminants.
Post - treatment System
"Offgas" from the desorber is typically processed to remove particulates that remained in the gas
stream after the desorption step. Vaporized contaminants in the offgas may be burned in an
afterburner, collected on activated carbon, or recovered in condensation equipment. Depending on the
contaminants and their concentrations, any or all of these methods may be used. All disposals must
meet federal, state, and local standards.
Treated soil from the desorber is tested to measure how well the process removed the target
contaminants. The performance of thermal desorption is typically measured by comparing the
contaminant levels in treated soils with those of untreated soils. If the treated soil is non - hazardous, it
is redeposited on -site or taken elsewhere to be used as backfill. If, however, the soil requires further
treatment (for example, the soil contained contaminants that did not respond to this process), it may
be treated with another technology or transported off -site for disposal.
Why consider thermal desorption?
Thermal desorption is effective at separating organics from refining wastes, coal tar wastes, waste
from wood treatment, and paint wastes. It can separate solvents, pesticides, PCBs, dioxins and fuel
oils from contaminated soil. The equipment available is capable of treating up to 10 tons of
contaminated soil per hour. Finally, the lower temperatures require less fuel than other treatment
methods.
Will it work at every site?
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A Citizen's Guide to Thermal Desorption
Page 3 of 4
Thermal desorption is not applicable to most metals, although mercury can be removed by the
process. Other metals will either remain in the treated soil, in which case the soil must be retreated, or
vaporize, in which case they may complicate the offgas treatment. The presence of metals and their
fate must be determined before the soil is processed.
Thermal desorption is not equally efficient at treating all types of soil. If the soil is wet, water will
vaporize along with the contaminants. Because of the additional substance (water) being vaporized,
more fuel is required to vaporize all of the contaminants in the wet soil. Soils with high silt and clay
content are also more difficult to treat with thermal desorption. When heated, silt and clay emit dust,
which can disrupt the air emission equipment used to treat the vaporized contaminants. In addition,
tightly packed soil often does not permit the heat to make contact with all of the contaminants.
Therefore, it is difficult for them to vaporize. Finally, thermal desorption would not be a good choice
for treating contaminants such as heavy metals, since they do not separate easily from the soil, and
strong acids, since they can corrode the treatment equipment.
What Is An Innovative Treatment Technology?
Treatment technologies are processes applied to hazardous waste or contaminated materials to
permanently alter their condition through chemical, biological, or physical means. Treatment
technologies are able to alter, by destroying or changing, contami-nated materials so they are less
hazardous or are no longer hazardous. This may be done by reducing the amount of contaminated
material, by recovering or removing a component that gives the material its hazardous properties or
by immobilizing the waste. Innovative treatment technologies are those that have been tested,
selected or used for treatment of hazardous waste or contaminated materials but lack well-docu-
mented cost and performance data under a variety of operating conditions.
Although thermal desorption is widely used, innovative variations are continually being developed.
It is still difficult to predict with certainty the time and cost to clean a site using thermal desorption.
For these reasons, it retains its "innovative" label as EPA continues to track its performance.
Where is thermal desorption being used?
Thermal desorption has been selected as a treatment method at numerous Superfund sites. For
example, thermal desorption was used at the TH Agriculture & Nutrition Company site in Albany,
Georgia. Thermal desorption was used at the site to treat 4,300 tons of oil contaminated with
pesticides (dieldren, toxaphene, DDT, lindane). The system ran from July to October 1993. Thermal
desorption met the cleanup goals, removing over 98% of the pesticides in the treated soil. Table 1
lists some additional Superfund sites where thermal desorption has been used or selected for use.
Table 1
Examples of Superfund Sites Using Thermal Desorption (all projects completed)*
Name of Site
Type of Facility
Contaminants
Re-solve, MA
Chemical reclamation
Volatile organic compounds (VOCs),
polychlorinated biphenyls (PCBs)
Metaltec/Aerosystems, NJ
Metal manufacturing
VOCs
Reich Farms, NJ
Chemical drum
storage/disposal
VOCs, semi-volatile organic
compounds (SVOCs)
American Thermostat, NJ
Thermostat manufacturing
VOCs
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A Citizen's Guide to Thermal Desorption
Page 4 of 4
U.S.A. Letterkenney SE
Area, PA
Munitions
manufacturing/storage
VOCs
Wamchem, SC
Dye manufacturing
Benzene, toluene, ethylbenzene &
xylene (BTEX), VOCs, SVOCs
Jacksonville NAS, FL
Fire training site
Polyaromatic hydrocarbons (PAHs)
Outboard Marine/Waulcegan
Harbor, IL
Marine products
manufacturing
PCBs
Pristine, OH
Industrial waste treatment
facility
BTEX, pesticides, herbicides, VOCs
Sand Creek Industrial, CO
Pesticide manufacturing
Pesticides, herbicides
For a listing of Superfund sites at which innovative treatment technologies have been used or selected
for use, contact NCEPI at the address in the box below for a copy of the document entitled
Innovative Treatment Technologies: Annual Status Report (7th Ed.), EPA 542-R-95-008.
Additional information about the sites listed in the Annual Status Report is available in database
foiniat. The database can be downloaded free of charge from EPA's Cleanup Information bulletin
board (CLU-IN). Call CLU-IN at 301-589-8366 (modem). CLU-IN's help line is 301-589-8368. The
database also is available for purchase on diskettes. Contact NCEPI for details.
* Not all waste types and site conditions are comparable. Each site must be individually investigated
and tested. Engineering and scientific judgment must be used to determine i fa technology is
appropriate for a site.
For More Information
The publications listed below can be ordered free of charge by calling NCEPI at 513-489-8190 or
faxing your request to 513-489-8695. If NCEPI is out of stock of a document, you may be directed to
other sources. You may write to NCEPI at:
National Center for Environmental Publications and Information (NCEPI)
P.O. Box 42419
Cincinnati, OR 45242
• Selected Alternative and Innovative Treatment Technologies for Corrective Action and Site
Remediation: A Bibliography of EPA Resources, EPA 542-B-95-001. A bibliography of EPA
publications about innovative treatment technologies.
• Physical/Chemical Treatment Technology Resource Guide, September 1994, EPA 542-B-94-
008. A listing of publications and other sources of information about thermal desorption
and other treatment technologies.
• Engineering Bulletin, Thermal Desorption, February 1994, EPA 540-S-94-501.
• Abstracts of Remediation Case Studies, March 1995, EPA 542-R-95-001.
• WASTECH ® Monograph on Thermal Desorption, ISBN #1-883767-06-7. Available for
$49.95 from the American Academy of Environmental Engineers, 130 Holiday Court,
Annapolis, MD 21401. Telephone 410-266-3311.
NOTICE: This fact sheet is intended solely as general guidance and information. It is not intended,
nor can it be relied upon, to create any rights enforceable by any party in litigation with the United
States. The Agency also reserves the right to change this guidance at any time without public notice.
http://www.clu-in.org/PRODUCTS/CITGUIDE/Thermdsp.htm 5/14/02
"'Then 'al Desorption Technology Web page
A Physical/ Chemical a Remediation Technology
Thermal Desorption
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Page 1 of 4
Thermal desorption is implemented by heating
and agitating soil while it is exposed to a carrier
gas or vacuum that transports volatilized water
and organic contaminants to the gas treatment
system. The bed temperatures and residence
times designed into these systems will volatilize
selected contaminants but typically will not
oxidize or destroy them. Thermal desorption is
a full-scale technology that has been proven
successful for remediating all types of soil.
Two common thermal desorption designs are the rotary dryer and thermal screw. Rotary
dryers are horizontal cylinders that can be indirect- or direct-fired. The dryer is normally
inclined and rotated. For the thermal screw units, screw conveyors or hollow augers are
used to transport the medium through an enclosed trough. Hot oil or steam circulates
through the auger to indirectly heat the medium. All thermal desorption systems require
treatment of the off-gas to remove particulates and contaminants. Particulates are
removed by conventional particulate removal equipment, such as wet scrubbers or fabric
filters. Contaminants are removed through condensation followed by carbon adsorption,
or they are destroyed in a secondary combustion chamber or a catalytic oxidizer. Most of
these units are transportable.
Status: Innovative'
,e.gmcf:
. 4,746;11t,‘ 4T�p f :the`
Contaminants
Media
Location
Treatment
Site
Secondary
Process
Halogenated VOC
Dredged
Sediment or
Excavated Soil
,
Ex
Situ
Off-gas treatment
Halogenated SVOC
and Pesticides
Dredged
Sediment or
Excavated Soil
Ex
Situ
Off-gas treatment
Nonhalogenated
SVOC (including
diesel fuel, JP-5 and
other heavy fuels)
Dredged
Sediment or
Excavated Soil
Ex
Situ
Off-gas treatment
Nonhalogenated
VOC (including
gasoline and JP-4)
Dredged
Sediment or
Excavated Soil
Ex
Situ
Off-gas treatment
http:// erb.nfesc.navy.mil/restoration/ technologies /remed/phys_chem/phc -3 6. asp
5/14/02
"Thermal Desorption Technology Web page
Dredged
Sediment or
PCB Excavated Soil
lEx
ISitu
Page 2 of 4
Off-gas treatment
The target contaminant groups for thermal desorption systems are halogenated and
nonhalogenated volatile organic compounds (VOCs). The technology can be used to treat
semivolatile organic compounds (SVOCs) and polychlorinated biphenyls (PCBs) when a
temperature near the high end of the normal operating range and long residence time is
used.
/I/Tit at 1. 0 n 4;060 bu... h.
The following factors may limit the applicability and effectiveness of the process:
• Site-specific feed size and materials handling requirements can affect applicability
or cost.
• High clay, humic material, or moisture content increases costs.
• Highly abrasive feed potentially can damage the processor unit.
• Dust and organic matter in the soil increases the difficulty of treating off-gas.
• Debris greater than 60 mm in diameter typically must be removed prior to
processing.
---wolar49,4, 04,
ur a tio rt
PA;
'Top or, the'
Thermal desorption is used to treat excavated soil, so the operation and maintenance
duration depends on the processing rate of the treatment unit and the volume of soil.
Processing typically would be performed on site in a mobile unit. The throughput of a
mobile unit is expected to range from 50 to 400 cubic yards per day.
vommiwt . .
. . Wropttr',, Pagc,-
4ot 40,
onrizazantnimizerzwc44.6rwoo
$10,000 to $20,000 fixed mobilization cost plus
$25 to 55 per cubic yard for petroleum-contaminated soil or
$95 to $195 per cubic yard for other organic contaminants
operating cost
The major cost items included in the cost estimate range for thermal desorption are
designated in the following table:
Pretreatment Activities Included in Cost
Screening to remove debris
Fixed Cost Items Included
Variable Cost Items Included
Crew and equipment mobilization
Soil excavation
Equipment leasing
http: / /erb.nfesc. navy.millrestoration/ technologies /remed/phys_chem/phc -3 6. asp
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'Thermal Desorption Technology Web page
Page 3 of 4
Treatment pad installation
Operating and maintenance labor
Utilities
Site supervision
Site quality assurance and health and
safety support
Sampling and analysis for process control
Residuals Management Activities Included in Cost
On-site disposal of treated soil, sediment, or sludge
Off-gas treatment
Comments
Indirect costs such as project management, design and engineering, vendor selection,
home office support, permit preparation and fees, regulatory interaction, site
characterization, treatability testing, performance bond, and contingencies are not
included in the estimated cost range.
Type
Title
Report
Application Guide for Thermal Desorption (Apr 1998) (256 pages)
Presentation
BADCAT Technologies: Electrokinetic Remediation of Metal-
Contaminated Soil / In Situ Thermal Desorption of PCBs in Soil (Oct
1998) (78 pages)
Tech Data Sheet
Demonstration of Hot Air Vapor Extraction for Fuel Hydrocarbon
Cleanup (Mar 1997)
Tech Data Sheet
Demonstration of In Situ Thermal Desorption Blankets and Wells (Sep
1997)
Tech Data Sheet
Demonstration of P01 mer Coa in on Contaminated Soil Piles
Article
Have Burners, Will Clean: A Study of Hot Air Vapor Extraction
Demonstrates Economical Remediation of Petroleum Constituents
(Oct 1996) (4 pages) Reprinted with permission from Soil &
Groundwater Cleanup Magazine.
Report
Hot Air Vapor Extraction Remediation of Petroleum Contaminated
Sites (May 1998) (9 pages)
Presentation
Low Temperature Thermal Desorption RITS Presentation (Jan 1997)
(73 pages)
Report
Overview of Thermal Desorption (Jun 1998) (33 pages)
Intro Page
Thermal Desorption
http://erb.nfesc.navy.mil/restoration/technologies/remed/phys_chem/phc-36.asp
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'Thennal Desorption Technology Web page
Page 4 of 4
Contact
Organization
Thermal Desorption POC
NFESC
Site Name / Provider / Description
Thermal Desorption Guidance Documents
Interstate Technology & Regulatory Cooperation (ITRC)
Guidance documents for thermal desorption of hydrocarbons, chlorinated organics, and
mercury and mixed waste.
http:// erb.nfesc.navy.mil/restoration/ technologies /remed/phys_chem/phc- 36.asp 5/14/02
ATSDR - PHA - BLOOMINGTON PCB SITES, BLOOMINGTON, MONROE COUNT.. Page 1 of 15
PUBLIC HEALTH ASSESSMENT
\.,
BLOOMINGTON PCB SITES
BLOOMINGTON, MONROE COUNTY, INDIANA
SPENCER, OWEN COUNTY, INDIANA
SUMMARY OF VOLUME II
The PCB-contaminated materials that are mixed with municipal and industrial landfill waste at the
Bloomington Consent Decree sites represent a wide range of heterogenous waste streams that are
difficult to characterize fully in terms of contaminants and concentrations to be treated, including
PCBs. Therefore, on the basis of the available data, it is difficult to determine the public health
implications of using incineration or non-incineration teclmologies for remediation of the
Bloomington PCB sites. Without the engineering design, operating plans, and results of site-specific
treatability testing, we can evaluate the public health implications of non-incineration remedial
technologies (NIRTs) only in general terms.
Fugitive emissions that are not properly monitored and controlled might pose a health threat to
workers and nearby residents. Excavation and handling of contaminated media, including such
preprocessing activities as blending, sizing, separating, shredding, and transportation, can be major
sources of fugitive emissions of contaminants. Use of any of the ex situ (away from the original
location) NIRTs for the Bloomington PCB landfill sites (except encapsulation technologies, such as
landfilling, vaulting, and solidification) would require significant pretreatment to meet the material
sizing requirements (less than one-eighth of an inch to a maximum of three-fourths of an inch,
depending on the specific technology). This pretreatment would increase the likelihood of fugitive
emissions.
If soil washing, solvent extraction, thermal desorption, or landfilling is selected as a treatment
technology, further treatment of PCBs might be appropriate. These technologies do not destroy
PCBs; except for landfilling, they concentrate PCBs. Non-incineration technologies other than
bioremediation and solidification/stabilization require treatment or disposal of non-PCB byproducts
and waste streams. Post-treatment waste streams and byproducts might create additional hazardous
substance exposure potential for workers and the community.
The Westinghouse permit applications for the proposed Bloomington, Indiana, incineration facility
appear to address many of the identified public health issues satisfactorily. However, it is not possible
to predict all public health implications of the emissions from the proposed Bloomington incinerators
because the proposed combination of wastes, i.e., municipal wastes; sewage treatment sludge; and
PCB-contaminated soils, sediment, and excavated landfill material (ELM), has neither been
sufficiently characterized nor previously treated in an incinerator. Few data on specific interactions of
the contaminants released from waste incinerators are documented in the scientific literature. Almost
all of our toxicologic data are from studies in which exposure levels greatly exceeded those typical of
incinerator releases.
Information provided in the proposed incineration facility applications indicates that the estimated
stack emission levels of contaminants would not reach levels of public health concern. However,
there are few data to support those estimates. Better evaluation of the potential public health impacts
of the stack emissions would require analysis of stack emissions from a full-scale or pilot-scale
incinerator--similar to the proposed incinerator--that is incinerating the proposed combinations of
wastes.
If the consent decree parties decide to proceed with incineration of the PCB-contaminated ELM,
http://atsdrl.atsdr.cdc.gov/HAC/PHA/bloom2/b12._pl.html 5/14/02
ATSDR - PHA - BLOOMINGTON PCB SITES, BLOOMINGTON, MONROE COUNT.. Page 2 of 15
fl
preliminary projections of the potential stack emissions would, at a minimum, require additional
analysis of the waste feeds. The Waste Analysis Plan and Trial Burn Plan should then be revised to
address additional constituents of public health concern and to provide for burning the maximum feed
rate of PCBs that will be allowed in the facility permit. Protection of the off -site community,
including first responder personnel and the public at large, is not addressed adequately in the existing
contingency plans for the incineration facility and the ash landfill. Contingency plans for excavation
and other activities at the individual PCB sites are not yet available.
ATSDR has recommended the following actions relative to technologies that might be used to
remediate the Bloomington PCB sites:
1. Determine the potential public health implications if a non - incineration technology is selected for
use at any of the Bloomington PCB sites. ATSDR is available to conduct a comprehensive review of
the remediation design and operating plans and specifications of any non - incineration clean -up
alternative proposed for implementation at the Bloomington sites. The Agency will work with
representatives of EPA, the state of Indiana, the city of Bloomington, and the public to evaluate
public health issues that might be associated with other specific remedial options.
2. Monitor and sample ambient air throughout the material handling and treatment processes to
ensure that fugitive emission controls are effective.
3. Before building the proposed incinerator, test the planned combination of excavated landfill
material, municipal solid wastes, and sewage sludge first in another similarly designed full -scale
incinerator (if one exists) or at a pilot -scale facility to determine whether stable operating conditions
are possible, what the stack emissions will be, and the concentrations of constituents of public health
concern in the residuals.
4. Evaluate the preconstruction stack testing data for potential public health implications before
construction of the facility.
5. Revise the Waste Analysis Plan and the Trial Burn Plan to address additional constituents of public
health concern.
6. If the decision is made to dispose of the residuals in the proposed landfill in the Bloomington area,
evaluate the landfill operating procedures for potential public health impacts from the management of
ash and residuals.
7. Integrate on -site contingency plans more effectively with the local emergency contingency plans.
Conduct preplanning and hold meetings with the first responder community and emergency medical
care providers -- including firefighters, hazardous materials teams, emergency medical technicians,
and hospital emergency room physicians and nurses - -to ensure that both on- and off -site personnel
fully understand each group's training, capabilities, and responsibilities. Make the community aware
of the possible site - related emergencies that would result in their notification and possible shelter -in-
place or temporary relocation.
8. Revise the facility Contingency Plan to address the six items listed in Volume II, Section V.E. of
this PHA.
9. If funds are available, ATSDR should conduct or fund health studies of potentially affected
residents before and after remediation of the six consent decree sites to evaluate the public health
implications of the selected remedial technology or technologies.
I. INTRODUCTION
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This document responds to a request from Sen. Richard Lugar and Rep. Frank McCloskey for an
evaluation of possible public health implications of a proposed incineration system and of public
health considerations of other feasible treatment technology alternatives. This volume of the Public
Health Assessment (PHA) for Bloomington PCB Sites examines public health issues regarding the
selection and implementation of a remediation technology including excavation and transportation,
waste characterization, an assessment of feasible non - incineration remedial technologies, a review of
the proposed incineration facility, and community concerns related to site remediation.
Site Description and History
During the years 1958 through 1977, Bloomington was the location of a large manufacturer of
electrical capacitors containing polychlorinated biphenyls (PCBs). PCBs entered the environment
when capacitors not meeting manufacturer's specifications and containing PCB fluids were hauled to
and discarded in local landfills, limestone quarries, and dumps. PCBs also entered the environment at
elevated levels via the discharge of contaminated fluids into the city sewer system, which resulted in
the contamination of the Winston - Thomas Sewage Treatment Plant and the creek adjacent to it.
The consent decree for these sites requires that the approximately 650,000 cubic yards of PCB -
contaminated soil and material from six sites be remediated. See the Introduction in Volume I for
additional information about the consent decree. The first phase of the consent decree required
removal and remedial measures to contain the six sites until the extensive excavation of PCB -
contaminated materials begins. The second phase of the consent decree involves the permitting,
construction, and operation of a municipal solid waste - fueled, high temperature incinerator that will
incinerate the PCB - contaminated materials from all six consent decree sites. In the spring of 1994, all
parties to the consent degree agreed to reevaluate the Bloomington sites to identify site - specific data
gaps, remediation needs, and alternatives to using incineration as the method of remediation.
II. WASTE CHARACTERIZATION
Environmental sampling /waste characterization has several different purposes and many different
uses. For any hazardous waste site, sampling is conducted (1) to evaluate public health impact; (2) to
determine the extent and mobility of the contamination in the environment; (3) to identify the most
appropriate technology to remediate the contamination; (4) to ensure that the technology is designed
for the site - specific situation; (5) to assure that, while the technology is in operation, it is not
producing emissions or byproducts that affect public health adversely; (6) to assess worker health and
safety; and (7) to ensure that the site has been adequately remediated.
The PCB - contaminated material at the six Bloomington sites is difficult to characterize. Most of the
material (estimated volume of 650,000 cubic yards) is mixed with other landfill wastes. The sites
have received an assortment of municipal, commercial, and industrial wastes. Food wastes; paper;
cardboard; plastics; textiles; leather; yard wastes; wood; glass; tin cans; aluminum; other metals;
leaves; consumer electronics; white goods (stoves, refrigerators, dishwashers, and clothes washers
and dryers and commercial and industrial appliances); batteries; oil; tires; household hazardous
wastes; construction debris, such as wood, steel, concrete, and dirt; agricultural wastes; industrial
process wastes (from light and heavy manufacturing and from fabrication and chemical plants); and
water and wastewater sludges might have been deposited at the facilities.
A local manufacturing company's electrical capacitors that did not meet quality control specifications
were discarded at five landfills in Monroe County. PCBs were used as dielectric insulating fluids in
those capacitors and were not drained before the disposal of the capacitors. The types of landfill
waste material listed above are likely mixed with the PCB - contaminated waste. Some portions of the
landfills might contain very high concentrations of PCBs, while other areas might have little or no
contamination present.
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(--
Interim remedial measures have been taken at each of the landfill sites. Exposed capacitors and
stained soils at certain locations have been removed and taken to the Interim Storage Facility. Many
of the capacitors and related parts have been disposed of at an off-site incinerator. Although some
post-remedial samples have been taken, they might not indicate the extent of the remaining PCB
contamination. The samples indicate a range from non-detect to 22 parts per million (ppm) total PCB
concentration. The samples did not identify concentrations of heavy metals or other organic
compounds. It is difficult to characterize fully any landfill matrix (mixture of wastes). For example,
core sampling might indicate the concentration of a discrete batch of non-PCB-contaminated waste
material that was deposited at that location, which could yield a non-detect upon analysis for PCBs.
Similarly, a sample might also indicate that an intact capacitor was penetrated during the boring
operation for the sample collection process, yielding an extremely high concentration of PCBs.
Neither sample could be used to determine an average representative concentration of the PCB-
contaminated material. Because there was no known consistent distribution of industrial wastes and
PCB-contaminated material in the landfills, it is unlikely that core sampling and analysis information
would be helpful in the remedy-selection process. Sampling during any excavation and pretreatment
activities would assess the waste characteristics and treatment requirements better and more
practically. In addition, sampling during excavation and treatment is required to ensure the protection
of worker health.
The landfill matrix represents a wide range of heterogenous (different) waste streams. The PCB-
contaminated material might include heavy metals, flammable materials, oil and grease, or other
hazardous organic compounds that could interfere with the operation of a system designed primarily
for PCB treatment. Most hazardous waste treatment systems are better able to treat a fairly uniform
waste stream in a homogeneous (uniform) matrix.
The PCB-contaminated material at the Winston-Thomas Treatment Plant could represent a more
homogenous matrix. Soil-boring at the on-site abandoned lagoon showed total PCBs ranging from
less than 1 to 290 ppm. The tertiary lagoon sludge samples showed ranges from 119 to 2,400 ppm.
The Interim Storage Facility includes excavated material from the Anderson Road Landfill and
sediment from the adjacent pond, along with sediments from stream sites designated for cleanup.
Table 1 indicates the estimated quantities of the remaining materials to be removed at the five other
PCB sites. Current concentrations of PCBs and other contaminants that might be present in the
Interim Storage Facility are not available. Additional sampling would help characterize the material
in the Interim Storage Facility. The concentrations of contaminants at the storage facility might be
representative of those found at other area landfills.
It is difficult to characterize PCB contamination in such wide-ranging matrices as those found at the
Bloomington sites. Because the performance and effectiveness of PCB remediation treatment systems
might be influenced by concentration and matrix, it is likely that extensive treatability and pilot
testing would be needed before selection and implementation of a treatment strategy. Once a
technology is selected, the technology design, work plans and sampling plans should be shared with
public health agencies to ensure that public health is being protected.
TABLE 1
SITE MATERIALS TO BE REMOVED*
Site
(ranked by
priority)
Estimated
Quantity
of Material
for
Excavation
(yd3)
Approximate
Area
for
Excavation
(acres)
Material for Excavation and
Removal
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1. Neal's
320,000.
17.6
All solid waste; 2 ftb of soil below solid waste; up to
Landfill
2,000 yd3 from 5 sinkholes
2. Lemon
Lane
Landfill
176,000ax
9.3
All solid waste to approximate 1958 contour level;
remaining material and soil to where PCBs are found
at less than 50 ppm and then 3 ft below this level
3.
Bennett's
Dump
55,000'
4.6
b of All solid waste; 2 ft or soil below solid waste; no
large quarried limestone blocks
4. Neal's
Dump
5.
Winston-
Thomas
Facility
14,000
50,000
0.5
19.7
All solid waste; 2 ftb of soil below solid waste
Tertiary lagoon--all liquid and 6 inches of sludge and
soil on bottom and sides; sludge drying beds--all
sludge and 2 ft of soil below beds; abandoned lagoons-
-all sludge and 2 ft of soil below lagoons; digesters and
piping--all sludge and flushing water; trickling-filter
rock media--all loose organic material
a This volume includes the clay cap installed because of the Consent Degree
b Or to bedrock, if less
Estimated minimum
Source: Consent Degree; Engineering-Science (Atlanta, Georgia) and the Ralph M. Parsons
Company (Pasadena, California). Waste Material Excavation; Transportation, Storage and
Reprocessing-Bloomington Project: Phase 1 - Preliminary System Screening. February 1986.
*From Westinghouse Electric Corporation. Application for Incinerator Certificate of Environmental
Com atibilit Volume 1: Part 1 throu h Part 13 .. 1-7. Pittsburil : Westin house Jul 1991.
III. MATERIAL HANDLING
A. Excavation
ATSDR public health assessors have found that excavation and handling of soils at some Superfund
sites and waste loading and repackaging at some Resource Conservation and Recovery Act of 1976
(RCRA) facilities have caused the release of airborne contaminants, resulting in exposure of workers
and/or nearby residents (ATSDR, 1992). Inhalation of airborne contaminants is the most likely route
of exposure for off-site populations during excavation and waste-handling. A less likely exposure
route could be incidental ingestion of contaminated particulate material (dust) that settled onto
surfaces off site. Depending on the contaminant(s) and site safety practices, on-site workers could be
exposed via inhalation, dermal contact, and ingestion.
PCBs appeared in several samples of air taken from the Bloomington area sites in the early 1980s,
before interim actions were taken. No PCBs were detected in samples taken around the perimeter of
the Anderson Road Landfill from September 1986 through October 1987, before the landfill's
excavation. No information on sampling locations and methodologies was provided. PCBs and
volatile organic compounds were not reported above detection limits (detection limits not provided)
during quarterly air sampling at the Winston-Thomas site from April 1988 to February 1993. Air
sampling data was not available for the Bennett Stone Quarry site. Tables 2 through 4 summarize
findings of the PCB air sampling and analyses conducted on and around the other Bloomington sites
(ISDH, 1994).
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0
TABLE 2
PCB AMBIENT AIR SAMPLING FOR NEAL'S DUMP
(Interim Action 12/83)
Date
Location
8-hr. Low Volume
(IIW )
24-hr. High Volume
(4ug/m3)
6 to 7/83
A (on-site hotspot)
1
23
13 (on-site hotspot)
61
61
Upwind off site
--
1
Downwind off site
--
<1
7/84
A (on-site former hotspot) 1
3
TABLE 3
PCB AMBIENT AIR & SOIL GAS SAMPLING FOR LEMON LANE LANDFILL
(Interim Action 5/87-9/87)
Date
Location
8-hr. Low Volume
(pg/m3)
24-hr. High Volume
(ug/m3)
Ambient Air Sampling Before Interim Action
6 to 7/83
A (on site)
30 - 89
43 - 45
B (on site)
60 - 194
ND
C (on site)
6-20
13 - 34
1 (downwind
off site)
NA
0.3 - 1
2 (downwind
off site)
NA
NA
Upwind off site
<1
<1
Soil Gas
4/87
23 samples
15 locations
ND
Ambient Air Sampling During Interim Action
6 to 9/87
personal
1 - 30
perimeter
1 - 21
,ug/m3= micrograms per cubic meter
ND = not detected (detection limit not provided)
NA = not analyzed
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TABLE 4
PCB AMBIENT AIR SAMPLING FOR NEAL'S LANDFILL
(Interim Action 12/83)
Sampling
Location
Type of
Sampling
Pre - Cleanup (1983)
Concentration Range
(fig /m3)
Post - Cleanup (1985)
Concentration Range
(fig /m3)
A
8 -hrLV
5 -11
0.4 -1
2cm
550 - 1050
2 - 3
30 cm
56 -120
1 -2
60 cm
30 -49
0.9 -1
120 cm
10 -23
0.7 -1
180 cm
6 -13
0.4 -0.6
C
8 -hrLV
5 -12
2 -3
24 -hr LV
5 - 14
3 - 5
2cm
941 -1108
12 -21
30 cm
111 -157
4 -6
60 cm
40 -62
2 -5
120 cm
15 -21
2 -3
180 cm
9 -16
2 -3
E
8 -hrLV
7 -18
ND - <0.04
D -2
24 -hr HV 0.8 - 2
1 - 1.4
D -3
24 -hr HV
0.8 - 2
0.8 - 1.2
D -4
24 -hr
0.3 - 0.7
0.4 - 0.6
U
24 -hr HV 0.08 - 0.09
0.2 - 0.3
jug/m3= micrograms per cubic meter
ND = not detected (detection limit not provided)
LV = low volume air sampler
cm = centimeters above the ground
HV = high volume air sampler
Results of air samples collected after interim actions were completed indicate that the interim
measures reduced or eliminated PCB emissions into the air. If excavation or other activity removes or
breaches the caps or covers, the opportunity for exposure will again be present. Excavation activities
will disturb the soil and uncover contaminated areas, further increasing the potential for fugitive
emissions from the sites.
Other contaminants might be present in old municipal waste landfills, as described in the waste
characterization section, and might also become airborne via particulate transport or volatilization.
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The potential for off-site exposure to PCBs or other contaminants depends on the amount of
contaminated material present, the location of the nearest receptor population, and the precautions in
place to reduce or avoid air emissions. On-site workers could be exposed if they do not use proper
personal protective equipment.
Excavation and handling of contaminated soils and other matrices can be conducted safely. Control
measures that can be used include any or all of the following: dust suppression methods for
particulate-borne contaminants (e.g., spraying and fogging); vapor suppression foam for volatile
compounds; and building an enclosure over the area to be excavated and treating the exhaust air to
remove contaminants. However, additional obstacles that could pose safety hazards and cause
contamination of areas near the sites come along with these control measures. For example, using
foam, water, or other liquid might result in slippery work conditions that could cause worker injury,
work slowdown, or contaminant migration off site via water runoff. Safety hazards associated with
excavation projects inside enclosures include temperature extremes, levels of airborne contaminants
unsafe for workers (inhalation hazards along with flammable/explosive hazards), and visibility
problems.
An air monitoring and air sampling program must be employed throughout the excavation and
material handling process to ensure effective control of fugitive emissions. Ideally, air monitoring
should provide real-time infoimation on which to base decisions on whether work should be
continued, stopped while additional emission suppression techniques are effected, or stopped
completely while on-site personnel and/or nearby residents are relocated. Air sampling and
subsequent laboratory analyses should be used to confirm the results of real-time sampling.
As discussed in the Waste Characterization section, old landfills that contain municipal and industrial
wastes could contain a variety of solid and liquid wastes. Some of these wastes might pose a worker
safety and health problem, and some might pose a public health concern. Excavation of these types of
landfills might result in air releases of pressurized materials, venting of methane gas, fires, and
explosions. Because there is limited information about most older landfills that contain municipal and
industrial wastes, it is difficult to predict what materials will be encountered and determine what
contaminants to monitor for in the air, and, therefore, to ensure that nearby communities will be safe.
B. Material Handling and Storage
Dry, dusty materials should be kept damp with a water spray or otherwise stored or enclosed in a
manner that will prevent windborne transport of contaminated particulates. Wastes containing
volatile organic compounds should be stored under conditions that safely collect and remove gases
released from the wastes. Wet wastes or process effluents should be stored in chemically compatible,
leak-resistant containers. Storage areas for such liquid-bearing materials should have dikes or be
designed to contain leakage.
Preprocessing of wastes (e.g., blending, sizing, separating, and shredding) or post-treatment of waste
streams and byproducts (e.g., quenching, stabilizing, further treatment on site, and preparation for
transport off site), might cause releases of fugitive emissions. These emission sources should be
adequately considered, and waste processing areas should be designed to minimize the potential
exposure to workers on site as well as to people living or working nearby (ATSDR, 1992).
The application for the Bloomington incineration permit indicates that pretreatment will include
material sizing (via shredding) to 2 inches (Westinghouse, 199 lb). Other ex situ technology
categories generally require material sizing prior to treatment as follows: dechlorination (one-fourth
to one-half inch), soil washing (less than one-eighth inch), solvent extraction (less than one-fourth
inch), and thermal desorption (one-fourth to two-thirds of an inch) (ATSDR, 1994). Although not
specified in the Expert Panel Report, it is expected that sizing requirements for bioremediation and
stabilization technologies would also fall within the one-eighth to three-fourths of an inch range.
Fugitive air emission control requirements will most likely vary depending on the technologies used
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for screening, shredding, and sizing. As the size requirement decreases, the likelihood that there will
be fugitive emissions increases. Moisture content and types of debris will also greatly impact the
ability to size and process materials.
C. Transportation of Waste
The means of transporting hazardous waste to the treatment facility should be carefully considered.
Routes should be selected to minimize the potential for a traffic accident and a subsequent
contaminant spill and should avoid residential and play areas if at all possible. Care is also needed to
avoid spills and releases of contaminants during on-site transportation (ATSDR, 1992).
The application for the incineration permit includes discussions of primary and preferred or
secondary haul routes and the identification of chosen routes for transporting waste material from
each of the consent decree sites to the incinerator location (Westinghouse, 1991a). The individual
haul routes from each site to the incinerator location were well researched; selection criteria included
speed limit, road width, number and width of lanes, shoulder types and widths, side slopes, drainage
features, and surface conditions. Also taken into consideration were surrounding population and
property use (e.g., agricultural, commercial, or residential); future roadway improvements; estimated
population increase; and likely subsequent construction. When locations with sensitive populations
(e.g., day-care centers, schools, and recreational facilities) were found along primary and preferred
routes, additional investigation was conducted before transportation routes were selected
(Westinghouse, 1991a).
The application also specifies that there will be no transportation of waste material on roadways
during peak traffic hours (generally between 6:30 and 8:30 am and between 4 and 6 pm). Daily haul
schedules will minimize encounters with school buses, and haul drivers will be instructed to practice
caution around school buses. The application also addresses vehicle maintenance (although no
maintenance schedule is outlined), weather condition evaluation, and worker training (although no
specific training course is outlined) (Westinghouse, 1991a).
Locations of the nearest firefighters, emergency medical technicians (EMTs), and hospitals have been
identified. If a waste hauling vehicle accident or a waste material spill occurs, contingency plans will
be implemented to mitigate further contaminant migration and to avoid human exposure to the waste
material contaminants (Westinghouse, 1991a).
D. Waste Streams and Residuals
The same considerations for material handling and transportation as discussed for the Bloomington
PCB-contaminated waste will be given to the residuals (ash) produced by the incinerators
(Westinghouse, Sep 1991). Similarly, if a non-incineration remedial technology is selected, material
handling considerations should be addressed for concentrated PCB end products, solvents, and other
materials if they contain levels of contamination that are of public health concern.
IV. NON-INCINERATION REMEDIAL TECHNOLOGIES (NIRTs)
This section includes a brief description of each of the technology categories, general information on
whether they have been used to treat PCB-contaminated media, and information on data that will be
needed for accurate assessment of the potential public health impact of each technology category.
Because site-specific technologies have not been selected for the Bloomington PCB sites, it is not
possible to prepare site-specific discussions of each technology category. If, after revisiting a site, the
consent decree parties select a non-incineration technology for remediation, ATSDR can help review
the technology work plan and provide comments and recommendations to ensure public health
protection. For additional information and references on the technology categories and on
technologies within the categories, see the Non-Incineration Remedial Technologies section in the
report Proceedings of the Expert Panel Workshop To Evaluate the Public Health Implications of the
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Treatment and Disposal of Polychlorinated Biphenyls- Contaminated Waste (ATSDR, 1994).
A. Bioremediation
This technology category involves the use of microorganisms to degrade chlorinated organic
chemicals. Bioremediation treatment can occur in situ, or the contaminated material can be excavated
and treated ex situ. Refer to Section III of this report for a discussion of the possible public health
impacts of excavating and handling contaminated media.
Sequential anaerobic - aerobic biological treatment appears to offer promise for treating PCB -
contaminated material. The following soil and matrix characteristics might inhibit the effectiveness
of the microbiological processes: (1) low bioavailability; (2) the presence of co- contaminants, such as
heavy metals or oil and grease; (3) the presence of unknown compounds that are toxic or inhibitory to
microorganisms; and (4) nutrient limitations. It is not generally possible to predict whether
bioremediation can work effectively at a particular site. That determination requires treatability
studies to determine whether microorganisms capable of dechlorinating and/or degrading the PCBs
already exist in the waste material. It is also necessary to determine whether anaerobic dechlorination
and/or aerobic degradation can occur in the waste matrix.
Data gaps for bioremediation typically include the need for identification of microorganisms capable
of dechlorinating PCBs, limited volatile emissions data, a lack of data on the ranges of PCB
concentrations that can be dechlorinated (although concentrations up to 5,000 milligrams per
kilogram [mg/kg] of PCBs in sediment samples have been treated at bench scale), final end product
concentrations based on performance history, established procedures to control the process, and
estimates of treatment rates and costs. The bioremediation of PCBs has been extensively researched
over the past 6 to 8 years; however, data from site - specific field applications are quite limited. To
determine whether human exposures to hazardous substances could occur, emissions, residuals, and
byproducts should be fully characterized during treatability studies, pilot -scale tests, and full -scale
operations.
B. Chemical Dechlorination
Chemical dechlorination technologies involve the destruction or transformation of PCBs by removing
chlorine atoms from the PCB molecule. Certain processes in this treatment technology category have
proven effective for dechlorination of PCBs in soils. No known applications of this technology
category exist for PCB - contaminated municipal solid waste material or for sewage treatment sludges.
It would be necessary to excavate all of the material to be treated, reduce its size (usually to around
one -fourth to one -half inch) and suspend it in a liquid phase. Refer to Section II of this report for a
discussion on the possible public health impacts of excavating and handling of the contaminated
media.
Data gaps for the dechlorination technologies include air emission data, information on toxicity of
any remaining chlorinated compounds, and performance history data. Without information on the
potential for air emissions and residual contamination, it is not possible to predict possible human
exposures to site- and process - related contaminants. To determine whether human exposures to
hazardous substances could occur, emissions, residuals, and byproducts should be fully characterized
during treatability studies, pilot -scale tests, and full -scale operations.
C. Soil Washing
This technology category uses a water -based process that scrubs soils mechanically to remove
contaminants. One process removes contaminants from soils and sediments by either dissolving or
suspending them in the wash solution. Another process uses physical separation techniques to
concentrate the contaminants by particle size. Soil washing concentrates contaminants and reduces
their volume. It has potential for treatment of PCB - contaminated soils and sediments.
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Because of the high levels of organic material (humic acid, organic carbon, etc.) in the sludges and
municipal solid waste (MSW), soil washing might not be applicable. In addition, if the PCB-
contaminated media in Bloomington consist of fine-grained soil or sediment or contain more than
30% silt or clay, soil washing might not be feasible, since the PCBs will bind to the organic material
under those conditions. Soil washing is an ex situ treatment requiring excavation of the contaminated
media. Pretreatment requires sizing to less than one-eighth of an inch. Refer to Section II of this
report for a discussion of the possible public health impacts of excavating and handling the
contaminated media.
The following data gaps that might affect public health have been identified for this technology
category: air emissions data, performance history information, and the selection criteria for soil
washing scavengers. Because this technology does not destroy the contaminant either on site or off
site, treatment of the concentrated contaminant waste stream is required. Sampling and analyses of
emissions, residuals, and byproducts should be performed during treatability studies, pilot-scale tests,
and full-scale operations to evaluate the potential for human exposures to hazardous substances.
D. Solvent Extraction
Like soil washing, solvent extraction concentrates the contaminant and reduces the volume of
contaminated material. This technology uses solvents to extract contaminants from a matrix. Solvent
extraction technologies have been used on a pilot scale; commercial-scale applications to treat PCB-
contaminated soils should be available within the next few years. This technology is also applicable
to sediments and some types of sludges. It is in commercial use for extracting PCB from oils, making
it a good technology for cleaning transformers and capacitors. Solvent extraction becomes less
efficient if the waste has any of the following characteristics: elevated levels of organic matter, too
much moisture, and too high a concentration of volatile organic contaminants.
The contaminated material would require excavation. Pretreatment also requires reducing material
size to less than one-fourth of an inch. Refer to Section II of this report for a discussion of the
possible public health impacts of excavating and handling the contaminated media.
Data gaps that might affect public health include air emissions, performance history information,
residual and byproduct characterization, and the selection criteria for solvents. Because this
technology does not destroy the PCBs, it is necessary to treat the concentrated end product further.
Sampling and analyses of emissions, residuals, and byproducts should be performed during
treatability studies, pilot-scale tests, and full-scale operations to evaluate the potential for human
exposures to hazardous substances.
E. Thermal Desorption
Thermal desorption or thermal separation is a process that uses temperatures high enough to
volatilize or vaporize organic compounds from contaminated media but not to destroy them. Thermal
desorption, another contaminant concentration and volume reduction process, is available for
commercial treatment of PCB-contaminated soils. The technology has been used to treat PCB-
contaminated soil and sediment. It has not yet been proven for treatment of PCB-contaminated
biological sludges, municipal solid waste, or PCB-contaminated capacitors. Too much moisture
reduces the desorption efficiency. With proper treatability studies and pretreatment, thermal
desorption might be applied to waste from municipal landfills.
All of the contaminated material would require excavation and reduction to one-fourth to three-
fourths of an inch. See Section II of this report for a discussion on the possible public health impacts
of excavating and handling the contaminated media. Additional characterization of the Bloomington
PCB sites is necessary to determine whether the use of thermal desorption technologies is
appropriate.
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The most significant data gap is air emissions. Along with emissions, residuals and byproducts
should be fully characterized during treatability studies, pilot-scale tests, and full-scale operations to
evaluate the potential for human exposures to site- and process-related substances.
F. Solidification/Stabilization
Solidification/stabilization makes hazardous waste less soluble and less mobile. Solidification
involves encapsulating waste into a solid material of high structural integrity. This process does not
necessarily form a chemical bond between the solidification additive and the contaminant; it might
form a mechanical bond. Stabilization chemically converts the contaminants to a less mobile, less
soluble, or less toxic form. Cement, lime, and binders are examples of materials used as
solidification/stabilization additives.
This technology is used to stabilize contaminated materials for acceptance into a landfill or for
acceptance back to the site of excavation. The process increases the volume of contaminated
materials 25% to 30%. Historically, solidification/stabilization has been used to treat metals and other
inorganic compounds. With currently available technology, stabilization of inorganic compounds is
generally more successful than stabilization of organic compounds.
The uncertainty of the effectiveness of the technology for contaminants in organic waste, including
PCBs, is a data gap. Risks of contaminants leaching into the environment at very low levels still
exist. The potential for leaching should be determined in a treatability study before pilot or full-scale
implementation of this technology. Additional bench- and pilot-scale investigations are needed to
determine the suitability of the technology for treatment of PCB-contaminated material.
G. Landfilling
Landfilling of PCB-contaminated material is regulated under the Toxic Substances Control Act
(TSCA). Landfills must be authorized by the Environmental Protection Agency to receive PCB
waste. One of the permitted facilities, located in Emelle, Alabama, is owned and operated by
Chemical Waste Management Inc.; another landfill is in Model City, New York.
The following factors influence site selection for a landfill: (1) waste characteristics, (2) topography,
(3) subsurface geology and hydrogeology, (4) site access, (5) land use, (6) environmental sensitivity,
and (7) cost. Leachate and gas emissions create potential for contamination of air, surface soil,
subsurface soil, and groundwater, among other media, if engineering controls are not provided.
Therefore, some primary long-term considerations for landfills are the sufficiency and longevity of
containment systems (flexible membrane liners, clay liners, etc.); leachate and gas collection and
management systems; and monitoring.
Data gaps for landfilling and other land disposal or storage techniques include accessibility and
geologic suitability of a proposed site, long-term performance data of the containment system(s), and
possible leachate and air releases that might bypass or break through the contaminant collection
systems.
H. General Considerations of NIRTs
Table 5, taken from the report Proceedings of the Expert Panel Workshop To Evaluate the Public
Health Implications of the Treatment and Disposal of Polychlorinated Biphenyls-Contaminated
Waste (ATSDR,1994), summarizes the stages of development of the various non-incineration
technology categories with respect to the treatment of PCB-contaminated media. The table outlines
the possible Bloomington PCB site non-incineration treatment options. For example, contaminated
material associated with the Winston-Thomas site is categorized as sewage treatment sludge.
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Landfilling is the only proven non - incineration PCB treatment technology for this waste matrix. The
table shows that solvent extraction works on a field or pilot scale, but it has not been used on a
commercial or full -scale basis. PCB - contaminated media in the Anderson Road Landfill (now located
in the Interim Storage Facility), Bennett Stone Quarry, Lemon Lane Landfill, Neal's Dump, and
Neal's Landfill could contain soil, sediment, and municipal solid waste. Therefore, single or multiple
technologies could be considered or necessary for treatment. Without more detailed site
characterization and information on treatability and pilot -scale testing, this table should not be
used as proof that a technology is applicable - -or not applicable - -to a Bloomington PCB site.
Table 6, also from the proceedings of the expert panel workshop, summarizes the general material
handling or treatment requirements of a non - incineration remedial technology category. Except for
bioremediation, all treatment technologies that have shown promise or have been proven to remediate
PCBs require that the contaminated material be excavated. Except for landfilling, all technologies
require material sizing. The technologies under consideration usually require sizing materials from
less than one - eighth inch to a maximum of three - fourths of an inch, depending on the specific
technology. Compared to the 2 -inch shredding requirement for incineration (see the Incineration
section of this PHA), this is a significant pretreatment step.
TABLE 5
NIRT TREATMENT CAPABILITIES OF DIFFERENT PCB - CONTAMINATED WASTE
MATRICES
Technology Category
Matrix
Oil
Soil
Sediment
Municipal Solid
Waste
Sewage
Treatment
Sludge
Bioremediation
U
E
E
E
E
Dechlorination
P A/P
E
U
U
Soil Washing
NA A
E
N
N
Solvent Extraction
P
A
E
N
A
Thermal Desorption
NA
P
E U
U
Solidification/Stabilization
N
E
U
U
U
Landfill
N
P
P
P
P
N = not generally feasible
NA = not applicable
U = unproven
E = emerging technology (bench- or pilot -scale testing phase of development; performance data
available)
A = applied technology (field demonstration phase of development, additional performance data
and cost data available)
P = proven technology (technology developed to the point of commercialization)
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)
TABLE 6
NIRT PCB TREATMENT REQUIREMENTS
Technology Category
Treatment Requirement
In
situ/Ex
situ
Material
Sizing
Other
Pretreatment
Post-
Treatment
(PCBs)
Post-
Treatment
(Other)
Bioremediation
JJE
Y (Ex situ)
M
N
N
Dechlorination
E
Y
N
N
Soil Washing
E
Y
N
Y
Y
Solvent Extraction
E
Y
N
Y
Y
Thermal Desorption
E
Y
M
Y
M
Solidification/Stabilization
IIE
Y
M
N
N
Landfill
1
N
N
Y
Y
I = in situ treatment
E = ex situ treatment
Y = yes
N = no
M = depends on waste matrix and process
If soil washing, solvent extraction, thermal desorption, or landfilling is selected as a treatment
technology, further treatment of PCBs might be appropriate. These technologies do not destroy
PCBs; except for landfilling, they concentrate PCBs. Non-incineration technologies other than
bioremediation and solidification/stabilization require treatment or disposal of non-PCB byproducts
and waste streams. Post-treatment waste streams and byproducts create additional hazardous
substance exposure potential for workers and the community.
I. Public Health Considerations of NIRTs
Any or all of the technologies discussed might be applicable to several or all of the Bloomington
PCB sites. If additional characterization of the sites occurs and a non-incineration remedial
technology is selected, public health considerations can be better addressed at that time. It is not
possible to determine public health implications of a technology without evaluating a minimum of
the engineering design and the results of the treatability tests. Very few of the technologies have
significant enough performance histories for treating PCB-contaminated matrices to allow ATSDR to
predict the human exposure pathways or the contaminants of health concern. The same is true for the
amount of available air sampling data. While many technology vendors report that air emissions are
"below detection limits" or "insignificant," they do not report information about the sampling and
analysis methodologies and the analytical detection limits. The information they present does not
help to determine potential public health implications of a technology.
The most likely exposure routes that would result from use of any of the technologies would be the
inhalation pathway and ingestion of or dermal contact with any residuals that might remain in the
treated material. ATSDR is not implying that air emissions, byproducts, and residual contaminants
that will occur with any of the technologies are necessarily of public health concern. The most
significant sources of exposure might indeed be the excavation and the handling of the waste to be
remediated. However, unless these potential hazards are considered and investigated from the
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treatability test through the full -scale operation, it will be impossible to determine the public health
impacts of any of the remedial technologies.
The following table summarizes the key factors that ATSDR considers when evaluating a non -
incineration remedial technology.
TABLE 7
SUMMARY OF PUBLIC HEALTH CONSIDERATIONS
FOR NON - INCINERATION REMEDIAL TECHNOLOGIES
Next Section
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TECHNICAL REQUIREMENTS
FOR
ON -SITE LOW TEMPERATURE THERMAL TREATMENT
OF
NON- HAZARDOUS SOILS CONTAMINATED WITH PETROLEUM/ COAL TART GAS PLANT WASTES
Final -
May 29, 1996
Prepared by
The Interstate Technology and Regulatory Cooperation
Low Temperature Thermal Desorption Task Group
Overview
Low Temperature Thermal Desorption (LTTD) is a treatment technology which removes contaminants
from solid media (e.g., soils) by volatilizing them with heat, but without combustion of the media . LTTD
has been widely used in treating petroleum contaminated wastes and is being used increasingly in the
cleanup of manufactured gas plant (MGP) wastes and hazardous constituents, notably chlorinated
solvents and pesticides.
Goals of the LTTD Task Group were:
to produce a standard set of technical requirements which could serve as a model to allow the LTTD
technology to move from state to state, without unnecessary redevelopment of technical requirements;
to improve market conditions for LTTD technology providers by providing a degree of consistency and
predictability in technical requirements for implementation of the technology for cleanup;
to develop a viable, repeatable process for interstate cooperation directed toward enhancing
implementation of innovative technologies and innovative application of existing technologies to site
cleanup;
to provide a framework for states which have no specific regulatory requirements for LTTD should they
choose to develop those requirements and to provide a gauge for states which do have requirements to
assess those requirements in Tight of the common requirements of other states;
to provide a template of technical requirements which could be used as a model for other technologies for
all functions presented above.
Approach
The LTTD Task Group began the technical requirements development process by addressing treatment
of non- hazardous soils because they felt the effort would be relatively straightforward. The task group
intends for the next version of the LTTD technical requirements document to address treatment of
hazardous waste, specifically soils contaminated with chlorinated constituents. They plan to use firsthand
experience gained from the Rocky Flats LTTD DOIT Demonstration, as well as expertise of
knowledgeable vendors who are beginning to deploy LTTD in the field for the cleanup of hazardous
waste.
Although agreement was reached for aH of the technical issues presented in this document, the group
found that, even for the "simple" case, achieving consensus on technical requirements was a painstaking
and time consuming effort. It should be recognized that a certain level of effort is inherent to the
stakeholder involvement process and additional effort was expended as part of the learning process as
the group members moved forward in their pursuit of interstate cooperation.
As in the case of the other TSTG's, the LTTD task group was open to any ITRC member. Participants
with expertise and ongoing L7-7O projects in their elected to join this task group and contributed
consistently to the development of this work product. Most of the practical experience of these state
regulators was in the realm of treating petroleum and MGP soil contamination. In addition, two individuals
from the United States Environmental Protection Agency (US EPA) and one individual representing the
public participated as often as they could in group conference calls and draft product review. An industry
consultant was retained to provide the industry perspective during one ITRC meeting.
Although all members of the ITRC were invited and actively encouraged to provide input into the LTTD
work products, the group found that active participants were primarily primari(y those regulators who saw a specific
need for the technology in their respective states. A few technology vendors who saw a viable market for
their technology were willing to comment on draft documents. This natural tendency for participants to
focus atmost exclusivety in their areas of interest should be taken into account when initiating future
efforts for interstate cooperation.
Product and Process Evaluation
It is useful at this point to make a distinction between the initial work product and the process used to
develop the product when evaluating the success and lessons learned from the LTTD effort. The initial
work product is a document which blends diverse state technical requirements for a proven technology
used for treatment of non-hazardous soils. The LTTD task group considered requirements from nine
states to develop their draft document and circulated the document for review and comment to all
member states of the ITRC.
This document as a detiverabte provides benefits at severat levels:
This document provides a basetine of technicat requirements for implementation of LTTD for cleanup of
petroleum and MGP contaminated soils. \AThile the use of LTTD for petroleum oqntam|nationisbocominQ
more routine, the use of LTTD for gas plant sites is less well established.
This document will serve as a template for the group's development of technical requirements for the
more challenging case of soils contaminated with chlorinated solvents and pesticides.
This docurnent can serve as a template for technical requirements for promising new technologies still in
the demonstration and testing phase.
The entire document outline is generally transferable to other "relatively mature" technologies. The
following sections of the document may be directly transferrable to other technologies:
-Approach to established baseline requirements, allowing for flexibility to address site specific and
technology specific variables
- Analytical Methods
^ Sample QA/QC
- Water Discharge Requirements
- Operations Record Keeping
- General QA/QC
- Health and Safety
Strong Iessons were learned in terms of process development. K8emberaofthaLTTDbaskgroup
developed the draft document during weekly facilitated conference calls and during breakout sessions at
ITRC meetings. They produced successively modified versions of the document based upon feedback
and input from the entire ITRC. Group members were exceptionally successful in circulating the draft
LTTD document within their respective states and obtaining comments from various divisions of their
organizations. A few additional states provided valuable and thoughtful comments.
The iterative process worked well for the LTTD group for their first revisions, because the individual group
members were wilting and able to invest the effort needed to follow-up with their colleagues.
The LTTD group reallzed greatest efficiency in having a core group of five to seven experienced people
froni different states produce the draft product.
A facilitator helped to keep their discussions focused and handled the actual document revision and
production work.
Public stakeholder comment was solicited from stakeholder representatives of the ITRC. In concert with
the full ITRC, the ixrD group adopted the recommended "A Guide to Tribal and Community Involvement
in Innovativ Technology Assessment". This guide o|eadypointaoutthedaaineondneedfor"nneoningfu|
community involvement" at the site implementation level .
The members of the group recognized the need for stakeholder involvement but had difficulty with
determining the appropriate approach to stakeholder involvement. Their struggle centered around trying
to incorporate site-specific stakeholder needs into their generic technical requirements document. The
group fee!s this is a cross cutting issue and recommends that the fult ITRC pursue a viable approach.
Additional stakeholder feedback was solicited by sending out the document for full ITRC review and
comment, presenting the document at ITRC meetings and asking for feedback during facilitated breakout
and full group sessions, and finally by asking for feedback directly from technology vendors. Overall, state
representatives who did not respond to the LTTD group's original written request for comments also did
not offer much feedback during ITRC meetings. Twelve vendors verbally committed to providing
evaluation and feedback, but only a limited number actually provided comments.
In this case, a great deal of effort was expended to generate a marginal amount of feedback. An inherent
limitation of the process is the lack of time for participants bzpnov|dethoroughoonsideretiontotheother
subgroups' work products, while trying to produce work products of their own. Thus, thoughfful
consideration needed to understand all of the implications of these work products, in some cases,
apparently has been deferred until individual state "sign off' for the documents is requested.
It is possible that the efficiency of the feedback/revision loop could be improved by taking more time up
front to identify stakeholders who are likely to provide the needed feedback and concentrate efforts there.
However, the group must still genuinely attempt to give all stakeholders an opportunity to voice their
concerns.
Communication between the LTTD Task Group and the Full ITRC
The chair of the LTTD Task Group, as well as the chairs of the other TSTGs.also served as members of
the ITRC Steering Committee. As a result, ITRC overarching requirements and expectations were clearly
communicated to the LTD Task Group. The group was allowed and encouraged to develop the LTID
work product autonomously, while keeping the ITRC mission in mind. Requests from the LTTD group for
ITRC support were fulty accommodated in the form of facilitation, ull group sessions and breakout
sessions on LTTD. The cross-Iinked structure between the LTTD Task Group and the ITRC
enhanced the flow of information and fostered communication in both directions.
0[RC Acceptance of the LTTD Work Product
The UTTD group members began and will continue to follow steps of the November 1, 1995 "ITRC
Decision Making Process" as they seek to gain acceptance by the ITRC members of their work product.
States have been asked to indicate their level of acceptance and commitment to implementation (full
acceptance, acceptance of indicated sections of the document, acceptance with reservations or noted
exceptions, non-acceptance). ITRC members are working within their respective state agencies to obtain
letters describing level of acceptance at the appropriate level within their organizations.
Even though existing laws/regulations may make it impossibe for some states to accept and imptement
provisions of the LTTD document in its entiret , the process is providing value in that:
Acceptance to the extent possible is being documented, bringing a level of consistency and predictability
to implementation LTTD in the field
Specific impediments to acceptance and implementation are being identified for future resolution
The initial effort to ascertain ITRC states level of acceptance occurred during the March through May
1996 time frame. A summary of state concurrence efforts to date, along with copies of concurrence letters
received to date, are provided in Appendix B. Table B-1 shows that ten states already have submitted
letters to indicate their evel of acceptance and commitment to use of this document.
The LTFD subgroup plans to continue to work with the remaining ITRC states to document their level of
acceptance of this work product. In order to maximize response, the members of the LTTD TSTG
recommend that the governors of the ITRC states ask their environmental health agencies to designate
an appropriate individual to carefully and thoughtfully consider the work product produced by this group
and to report back to their respective gOvernors on the level of acceptance and implementation they can
recommend.
Outstanding Issues
Initial efforts of the LTTD group involved taking a diverse set of existing requirements from several states,
attempting to resolve differences and identifying those areas which could not be reconciled. In several
instances, the group hound that existing federal or state statutes/regulations conflict with one another. As
a result, the full ITRC was not able to reach consensus on certain issues. The interim solution was either
to pass the overarching issues on the full ITRC or to relegate these issues to a state by state (or case by
case) resolution. As yet, several technology specific and overarching issues remain unresolved. Major
concerns include:
How to effectively involve the public in this process
Whether an LTTD unit and/or its afterburner is classified as an incinerator
The number and nature (discrete vs. composite) of verification samples to be collected
Whether field analytical methods can be used in place of offsite laboratory sample analysis
How to deal with time delays and costs associated with permitting requirements for Resource
Conservation and Recovery Act (RCRA) hazardous waste sites
PREFACE
The Interstate Technology and Regulatory Cooperation Work Group (ITRC) is exploring mechanisms for
interstate cooperation which may decrease the amount of time it takes for new technologies to become
widely accepted and integrated into the site cleanup process. ITRC Technology Specific Task Groups
(TSTG's) are focusing on several technologies, one of which is Low Temperature Thermal Desorption
(UTTD). In preparing this document, the LTTD Task Group used the following "basic assumptions" :
For purposes of this document, the term "non-hazardous" takes the federal definition as defined in 40
CFR.
The LTTD group has elected to produce baseline technical requirements which should be followed for all
LTTD applications. Because of the wide diversity of thermal treatment technologies, the group feels it is
not feasible to establlsh a detai!ed test plan appropriate for all sites.
These technical requirements were developed to provide stakeholders (including vendors) with some
degree of predictability and consistency of requirements from state to state. Howevar, states reserve the
right to go beyond these requirements, but should have a rationale for doing so.
Alternatives to these requirements may also be acceptable, on a case specific basis, but there should be
a technical basis for the alternative.
Because of the wide variability among states, the technica requirements do not include any emission
criteria for air, or cleanup criteria for soil or water.
ACKNOWLEDGMENTS
The members of the Interstate Technology and Regulatory Cooperation (ITRC) Low Temperature
Thermal Desorption (LTTD) Task Group wish to acknowledge the individuals, organizations and agencies
that contributed to this technical requirements document.
The LTTD affords, as part of the broader ITRC effort, is funded primarily by the US Department of Energy
and US Department of Defense. The US Environmental Protection Agency and Association of State and
Territorial SoIid Waste Management Officials are providing technical support and the Western Governors
Association is staffing the working group.
The Task Group also wishes to recognize the efforts of its participating members. State regulatory
representatives who developed this document included Mr. Brian Sogorka (NJ) who chaired the group,
Mr. Tom Conrardy (FL), Mr. Tom Douglas (FL), Mr. Ted Dragovich (IL), Mr. Jim Harrington (NY), Mr. Bal
Lee (CA), and Mr. Matt Turner (NJ). Representatives from EPA, Mr. Jim Cummings and Mr. Paul
dePencin. provided s valuable federal perspective. Stakeholder participation and review was provided by
Ms. Anne Callison of Lowry AFB RAB. Ongoing group facilitation and technical support was provided to
the group by Ms. Chris Renda of Environmental Services Network. A beneficial industry perspective was
provided by Mr. Jim Cudahy of Focus Environmentat, Inc.
In addition the group would like to thank representatives of ITRC member states and federal agencies
who provided thoughtful comments on the various draft documents. Written responses were received
from the states of California, Colorado, Florida, Illinois, Louisiana, Massachusetts, New Jersey, New York,
Pennsylvania, Texas, and U.S. Department of Energy Headquarters (EM-50). The LTTD group also
wishes to thank the technology vendors whose comments provided a needed industry perspective:
Electric Power Research Institute (EPRI), K8oxynniUian Technologies, Midwest Soil Remediation, Inc..
Vaimont Industries, RUST Geotech of the DOE Grand Junction P ject Office and Kaiser-Hill - Integrating
contractor of the Rocky Flats Environmental Technology Site.
Special appreciation is extended to Mr. Chris McKinnon of the Western Governors' Association and Ms.
Ginger Swartz of Swartz and Associates for their guidance throughout the writing of this document.
TABLE OF CONTENTS
PROCESS FINDINGS
PREFACE
&CK0O0/LE0GK8E0TS
1.0 Introduction
1.1 Background
1.2 Status of LTTD Use for Petroleum and MGP Waste Contaminated Soils
1.3 Scope of Documen 2
1.4 The Need for Fiexibility and Variances
1.5 The Need for PubIic Involvement
1.6 Cost and Performance Reporting Requirements
2.0 Pre-treatment Soil Sampling
2.1 Sample Parameters
2.2 Analytical Methods
2.3 Sample Quality Assurance/Quality Control (QA/QC)
3.0 Feed SoiI Limitations
4.0 Soll Treatment Verification Sampling
4.1 Sample Parameters
4.2 Sample Frequency
4.3 Analytical Methods
4.4 Sample QA/QC
5.0 Soil Handling and Stockpiling
6.0 System Operating Requirements
6.1 Primary Unit Operations
6.2 Afterburners
6.3 Monitoring Parameters
6.4 Automatic Shutdown Provisions
6.5 Fugitive Emissions Control
7.0 Air Emissions Monitoring Requirements
7.1 Emission Monitoring - Stack Testing
7.2 Emission Monitoring - Continuous Emission Monitors (CEM)
7.3 Sampling and Analyticat Methods
7.4 Sample QA/QC
8.0 Water Discharge Requirements
9.0 Operations Record Keeping
10.0 General QA/QC
11.Q Health and Safety
12.0 References
APPENDIX A - Outline of Cost and Performance Reportfor LTTD
APPENDIX B Summary of State Acceptance of LTTD Work Product
TECHNICAL REQUIREMENTS FOR
ON.SITE LOW TEMPERATURE THERMAL TREATMENT OF
NON-HAZARDOUS SOILS CONTAMINATED WITH
PETROLEUM/ COAL TAR/ GAS PLANT WASTES
1.0 INTRODUCTION
1.1 Background
The legal and regulatory uncertainties surrounding the cleanup of waste sites discourages the testing and
use of innovative technologies and innovative applications of accepted technologies. Technology
developers have difficulty gaining regulatory approval for the use of new technologies. Their difficulties
are compounded by the requirement for developers to demonstrate a technology's performance in each
state targeted for technotogy deptoyment.
In response to this concern, the Western Governors' Association convened a meeting of western regional
regulators during the summer of 1994 to discuss ways to increase cooperation among states on the
review, parnlitt|n0, and evaluation of promising new remediation technologies. This gnoup, now called the
Interstate Technology and Regulatory Cooperation (ITRC) Working Group, has been expanded to states
outside the region and includes federal, industry, tribal and public advisors as well.
Under direction from western governors, participating regulatory agencies which are cooperating with the
ITRC will report to those governors in June 1996. The agencies will recommend mechanisms to be
incorporated into state policy to facilitate interstate cooperation in order to shorten the time it takes
technologies to go from demonstration to widespread application. One of the mechanisms under review is
the development of baseline regulatory requirements and standardized protocols for verifying a
technology's cost and performance.
During subsequent meetings of the ITRC Working Group, initial areas of technical focus were chosen and
subgroups began work on establishing reporting and demonstration protocols for specific technologies.
The Low Temperature Thermal Desorption (LTTD) Task Group (regulators from California, Florida,
Illinois, New Jersey, New York and EPA) developed a preliminary plan to provide a set of composite
LTTD regutatory requirements for alt participating states. However, early work confirmed a suspected
limitation — most states have not yet established generic regulatory requirements but rather have
established requirements on a site specific basis. The objective of the LTTD Task Group therefore
became the development of a baseline of technical requirements which might be acceptable to several
state regulatory agencies. If successful, this reduction of regulatory impediments should help to lower the
cost of permanent remedies for contaminated sites.
1.2 Status of LTTD Use for Petroteum and MGP Waste Contaminated Soils
The use of LTTD has advanced to the point where many states have nmltipleLTTD
units for petroleum contaminated soil. LTTD treatment costs appear to be decreasing as a resutt of
competition among LTTD technologies and other types of treatment. Some states are in the process or
have recently permitted LTTD units to treat MGP wastes. This trend is expected to continue as regulators
and the public become more comfortable with LTTD treatment of MOP wastes.
The recent trend for low temperature thermal treatment facilities is towards larger fixed facilities as
opposed to mobile facilities. This trend is likely due to economies of scale, public acceptance issues, and
site size restriction. Fixed facilities have the cost advantage of going through the public acceptance
process once. Mobile facilities may face time constraints and economic difficulties when public
acceptance must be obtained each time their unit 15 moved to a new site.
1.3 Scope of Document
The LTTD Subgroup elected to begin with the case of requirements for non-
hazardous soils contaminated with petroleum hydrocarbon contaminants, coal tar, and other
manufactured gas plant (MGP) contaminants and defer discussion on more problematic contaminants
such as chlorinated compounds. This document deals with contaminants including gasoline, mineral
spirits, kerosene, jet fuel, fuel oil, crude oil and cutting oil, coal tars, tar soils, purifier box waste, purifier
box waste contaminated soll and a combination of alt of these contaminants. A future version is planned
which will atso address soils contaminated with hazardous wastes such as polychlorinated biphenyls
(PCB's), chlorinated solvents, and pesticides.
Because of the wide range of variations from state to state, this document does not address media
cleanup criteria (soil, water, air) or waste classification sampling requirements. This document does not
attonopthooddreaovvhetheronyportiou|arLTTDunitorafterburner|oc|000ifiedasmnincinaratocThot
debermina1iun, alorig with associated nequimsrnonto, will be made by individual states.
In addressing areas of agreement among states, the LTTD Task Group has chosen to lay out technical
requirements, as opposed to guidance or recommendations, for implementation of LTTD because it is a
fairly well developed technology. In keeping with the objective of providing requirements, the word "shall"
is used throughout this document, rather than softer words such as "should."
1.4 The Need for Ftexibility and Variances
The LTTD subgroup recognizes that on some sites, states may choose to go beyond this set of
requirements. It is incumbent upon operators to find out from regulators whether there are additional or
alternate requirements applicable; and it is in the states' best interest to allow variances from these
technical requirements based on specific technology applications. Variances also should be provided to
allow for the use of appropriate alternative sampling or analytical methods.
tn order to provide flexibility in the technical requirements, variances for alternate sampling, analytical,
waste processing ar monitoring methods may be used if:
1. The method has previously been used successfully under similar site conditions, as documented by a
regutatory agency; or
2. The method has been tested successfully by independent, non-regulatory verification entity; or
3. The method is a proved by the agency, baseduponoiteopecifi000nditionoorheohmo|ogy
modifications; the foltowing criteria shoutd be considered:
a. waste stream homogeneity (e.g., verification sample frequency could be decreased or a highly
homogeneous waste stream, and increased for a heterogenous waste stream);
b. contaminant concentration in waste stream (e.g., verification sampte frequency coutd be decreased for
a waste stream that is only moderately contaminated, and increased for a heavily contaminated waste
stream);
c. automatic shut-down conditions (e.g., shut-down condition based on soil exit temperature cou|dbe
eliminated based on a higher verification sample frequency);
d. receptor proximity (e.g., fugitive dust contro requirements could be relaxed based on receptor
proximity).
1.5 The Need for Public Involvement
The LTTD Task Group recognizes the need for stakeholder involvement when selecting new technologies
for the cteanup of contaminated sites. In keeping vviththefuU|T0C.theyhovo adopted the concepts in
principal put forward in "A Guide to Tribal and Community Involvement in Innovative Technology
Assessment". This guide clearly points out the desire and need for "meaningful community involvement"
at the site imptementation tevet.
Although emphasis is placed on public and tribal involvement at the site specific level, technology
developers need to be aware of the types of information the community will require for their decision
making process. The guide can be used as a "checklist" by technology developers and regulators
Examples of concerns which can be considered in a generic sense include noise levels, air emissions,
risk to the public, permanence of the remedy and cost.
1.6 Cost and Performance Reporting Requirements
The ITRC has adopted the "Guide to Documenting Cost and Performance for Remediation Projects" as a
model to standardize cost and performance reporting. The LTTD group further recommends that the data
and information found in the Cost and Performance Report for the T H Agriculture & Nutrition Company
Superfund Site (TH Ag Report) is appropriate for use in documenting applications of LTTD. Routine
applications of LTTD may not need to be documented using the cost and performance format. The EPA
Technology Innovation Office (TIO) has agreed to determine which LTTD applications need to be
documented using the cost and performance format.. A standardized outline of a cost and performance
report for LTTD is provided in Appendix A of this report.
2.0 PRE - TREATMENT SOIL SAMPLING
2.1 Parameters Sample
For purposes of this document, the objective of pretreatment sampling is to identify the range of soil types
and contaminant concentrations expected on the site. This information is necessary in order to select the
appropriate soil for the thermal treatment test runs and to insure that the most heavily contaminated
samples are selected for the test run. It is assumed that the site has been adequately characterized
during a remedial investigation. Therefore, sample frequency requirements are not addressed in this
document.
Pre - treatment soil sampling for petroleum contaminated or coal tar /MGP wastes and contaminated soils
shall include the parameters for the contaminant source outlined in Tables 1 and 2, respectively. Pre-
treatment soil sampling parameters shall also include any additional contaminants of concern associated
with the soil. (See Section 3. Feed Soil Limitations). Recommended methods for the various sampling
parameters are presented in Section 2.2. Sample data collected during an investigation of the site may be
substituted for the following requirements, as appropriate.
TABLE 1. Soil Sampling Parameters for LTTD Treatment of
Petroleum Contaminated Soils
Gasoline, Mineral Spirits
Kerosene, Jet Fuel
Fuel Oil No. 2, Diesel Fuel
Fuel Oil Nos. 4 & 6, Hydraulic Oils, Cutting Oil,
TPHC, PAH 4
Crude Oil, Lubricating Oil TPHC, PAH
Table Footnotes
1. Environmental Protection Agency (EPA) target compound list volatile organic (VO) or priority pollutant
VO scans including xylene with a gas chromatograph/ mass spectrometer (GC /MS) library search for the
ten highest peaks.
2. Lead analysis required for leaded gasoline sources. Soil may have elevated metals prior to petroleum
spills occurring. However, metals other than lead, are not typically parameters of concern for petroleum
spills. Operating temperatures are usually low enough to prevent significant volatilization of metals.
3. Naphthalenes, including naphthalene, methyl naphthalenes, di- methyl naphthalenes; may be analyzed
in base /neutral +15 (B /N +15) fraction or in VO fractions; if analyzed in VO fraction, instrument shall be
calibrated for these analytes. Quantitation of all isomers found shall be performed against at least one
methyl naphthalene standard and at least one di- methyl naphthalene standard.
4. Polynuclear Aromatic Hydrocarbons (PAH) as per EPA Priority Pollutant List.
TABLE 2. Soil Sampling Parameters for LTTD Treatment
of Coal Tar /Gas Plant Wastes and Contaminated Soils
CONTAMINANT
NALYTICAL PARAMETERS
Coal Tar and Coal Tar Contaminated Soils BTEX1, PAH, TPHC2 , Metals3, BNA4
Purifier Box Waste and
Box Waste Contaminated Soils
Metals3, Total Cyanide, Total and Reduced Sulfur
Combined Coal Tar and Box Wastes or
;Contaminated Soils
BTEX1, PAH, TPHC2', Metals3, BNA4, Total
Cyanide, Total and Reduced Sulfur
Table Footnotes
1. BTEX compounds consist of benzenes, toluenes, ethyl benzenes and xylenes.
2. TPHC - Total petroleum hydrocarbons.
3. Metals - At MGP sites, certain metals (e.g. arsenic, cadmium, chromium, copper, lead and nickel) could
be present at elevated levels, typically up to several hundred parts per million. However, operating
temperatures are usually low enough to prevent significant volatilization of metals.
4. BNA compounds are base /neutral /acid extractables. This includes PAH compounds.
2.2 Analytical Methods
EPA/ASTM methodologies shall be utilized for all parameters. The specific methodologies are presented
in Table 3.
TABLE 3. Nlethods of Analysis for LTTD sites
Parameter
BTEX, V0+10
PAH
PHC
Metals
BNA
otal Cyanide
~
Sulfur
Method of Analysis
SVVB4G824O (Packed Column) or826O(Capillary
Column)
SVV846 8270
GVV8488015B
SVV846 6010
SVV84O827O
SVV8489010 (mnanua|) or9012(outommated)
STM 3176, 3177 methods 427C, 428A
2.3 Sample Quality Assurance/Quality Control (QAIQC)
AH QAIQC required by the analytical method shall be completed. completed. Lab QAIQC summary documentation
(including non-conformance summary report and chain of custody ) shall be submitted with analytical
results. Full QA/QC deliverables as specified by the analytical method shall be maintained and shall be
available upon request for at least three years. Ultimate responsibility for QA/QC documentation belongs
with the responsible party of a site or the vendor conducting a demonstration. However, the responsible
party may contract with another entity, such as an analytical laboratory, to house the actual QA/QC data.
3.0 FEED SOIL LIMITATIONS
The generator of the soll shall certify, based upon site history or , that
halogenated organic compounds (including PCB's) are not contained in the soil to be treated. As an
added precaution, to prevent inadvertent treatment of chlorinated contaminants, soil shall be pre-tested
for total organic halogen (TOX), using EPA SVV846 Method 9020. T[)){ analysis is not required if site soils
have been anaiyzed for chlorinated volatile organics, pesticides and PCB's. (The LTTD Task Group is
drafting a separate document which specifies requirements for treating soils contaminated with
chlorinated constituents.) If there is any doubt as to the nature of constituents, sampling is required.
Soil contaminated with elevated Ievels of heavy metais shall not be treated untess the air permit
specifically aliows treatment of the material.
The foltowing soll conditions require or a test run to ensure the technology will be effective
1. soil moisture >35%
2. material > 2" diameter
3. soil has high plasticity
4. soil has high humus content 2
5. for petroleum contaminated media only - either soil TPHC >20,000 ppm
or greater than 25% LEL in gas in desorption chamber
6. for coal tar contaminated media only - coal tar product > 2%
4. SOIL TREATMENT VERIFICATION SAMPLING
4.1 Sample Parameters
Soil treatment verification sampling for petroleum or coal tar /MGP contaminated soils shall include the
parameters outlined in Table 1 and Table 2. BTEX may be eliminated from verification sampling of coal
tar contaminated soils because PAH compounds are surrogate for BTEX. In addition, any other site
specific
contaminants of concern for the treated soil shall be included in the parameter list. Verification sampling is
not required for any contaminants which will be unaffected by thermal treatment, including metals.
4.2 Sample Frequency
Post - treatment soil sampling will require one (1) composite sample for each one hundred (100) cubic
yards or one hundred and forty (140) tons of treated soil, using method ASTMC702 -87. Each composite
shall be comprised of five (5) discrete samples.
As an alternative to composite samples, five (5) discrete samples for each one hundred (100) cubic
yards or one hundred and forty (140) tons of treated soil may be collected. On a case by case basis,
based upon documented efficiency of the treatment system, the post- treatment sample frequency may be
reduced. This situation may be particularly applicable to high throughput units.
Special consideration is required for volatile organics sampling. Samples for volatiles shall be collected
using specialized sampling techniques to minimize Toss of volatile contaminants.
4.3 Analytical Methods
EPA/ASTM methodologies presented in Table 3 shall be used. For verification sampling, gas
chromatography methods with a mass spectrometer detector system are required for analysis of
volatile /semi - volatile contaminants. Mass spectrometer methods are not required if:
1. Contaminant identity is known;
2. The contaminant chromatographic peak is adequately resolved from any other peak; and
3. At least 10% of the sample analyses (minimum of one sample) are confirmed using the appropriate gas
chromatograph /mass spectrometer detection system.
4.4 Sample QA/QC
All QA/QC required by the analytical method shall be completed. Lab QA/QC summary documentation
(including non - conformance summary report and chain of custody ) shall be submitted with analytical
results. Full QA/QC deliverables as specified by the analytical method shall be maintained and shall be
available upon request for at least three years. Ultimate responsibility for QA/QC documentation belongs
with the responsible party of a site or the vendor conducting a demonstration. However, the responsible
party may contract with another entity, such as an analytical laboratory, to house the actual QA/QC data.
5.0 SOIL HANDLING AND STOCKPILING
Pre - treatment soil stockpiles shall be stored on a surface such as concrete or an impermeable liner of
appropriate thickness. The stockpile shall be covered by a secured plastic cover of appropriate thickness
or stored within the confines of a building. At a minimum, the staging area for the stockpiles shall be
constructed to prevent surface water and precipitation from entering the area and to collect leachate. All
soil stockpiles shall remain covered to prevent the generation of dust. Water spray or equivalent shall be
utilized as necessary to prevent dust generation. Monitoring shall be provided to ensure that
unacceptable levels of dust generated from the movement and handling of soil do not migrate from the
site.
Post - treatment soil shall be stored in the same manner as pre- treated soil until analytical testing has
confirmed that the soil has successfully been treated. A physical barrier, such as a curb or a wall, shall be
maintained to separate the pre- treatment from the post- treatment stockpiles. All areas shall be restored,
to the extent practicable, to pre - remediation conditions with respect to topography, hydrology and
vegetation, unless an alternate restoration plan is approved by the governing agency.
6.0 SYSTEM OPERATING REQUIREMENTS
6.1 Primary Unit Operations
Unit shall be operated within the operating envelope created during site specific test runs, conducted to
optimize system performance. Operating conditions such as minimum temperature range, residence time
and airflow in primary units and afterburners shall be determined during the test runs .
If conditions warrant (e.g. wide variation in soil type on site), this test shall include separate runs for
treatment of coarse and fine soil contaminated with specific petroleum products or coal tar /MGP wastes.
For example, if treating diesel contamination, two runs would be required: one with coarse soil and one
with fine soil. If any adverse feed soil conditions as listed in Section 3.0 (e.g. high TPHC, high plasticity,
humus) exist, soils exhibiting these conditions shall be treated during an appropriate number of test runs.
The maximum soil processing rate shall be based on amount of contaminant treated per unit time
(contaminant concentration x soil feed rate) as demonstrated during the test.
Soil test runs at each new site are generally expected, unless a previous site with similar soil
characteristics and contaminant levels has been successfully remediated. See Section 7.1 for stack
testing requirements.
6.2 Air Emission Control Unit Operations
An afterburner or equally effective air pollution control device is required in order to insure adequate
hydrocarbon control. To insure adequate particulate control, a baghouse or equally effective air pollution
control device is required. Operating conditions (temperature and duration) will be determined during the
test run, subject to individual state approval.
6.3 Monitoring Parameters
The following parameters shall be monitored and recorded during operation of the unit:
1. exit soil temperature
2. baghouse pressure drop
3. soil processing rate
4. afterburner temperature (if applicable)
5. exit air temperature from the desorption chamber
6.4 Automatic Shutdown Provisions
The following shall trigger automatic shutdown of contaminated soil feed:
Conditions Shutdown
1 Primary burner failure Instantaneous shutdown
2. Outlet soil temperature below set point 10 minute delay
which is based on type and amount of
contamination, soil type, and test run.
Afterburner temperature (if applicable)
below set point used in test run.
4. Blower failure or positive
pressure at the desorber.
Bag house pressure drop (if applicable)
outside the operating envelope
determined during test run.
6.5 Fugitive Emissions Control
30 second to 2 minute delay
Instantaneous shutdown
Instantaneous shutdown
Fugitive emissions control is required. Fugitive emissions control shall be accomplished by
maintaining negative pressure in equipment designed to operate at negative pressure. Controls to
9
ITRC Technical Requirements for On-Site Low Temperature Thermal Treatment of
Non - Hazardous Soils Contaminated with Petroleum/Coal Tar/ Gas Plant Wastes
March 12, 1996
- FINAL-
limit fugitive dust emissions at the treated soil outlet shall be in place. Treated soil shall be
moisturized within the enclosed soil discharge conveyor to minimize dust generation.
7.0 AIR EMISSIONS MONITORING REQUIREMENTS
From a state's point of view, air emissions levels are a major factor in determining whether a process
can be permitted. This section will focus on emission monitoring requirements, frequency of
monitoring and parameters. Air emissions criteria are not addressed because these are determined
by individual states.
7.1 Emission Monitoring - Stack Testing
Stack testing is required fora new unit or if new equipment is added to a previously tested unit;
it is not needed each time an approved unit is set up and operated in a manner which is shown to be
similar to previous test runs. Stack testing is required each time a new type of soil contamination is being
treated.
Initial stack testing parameters shall include:
total hydrocarbons
particulates
carbon monoxide (CO)
oxygen
sulfur oxides (SOx) - if box waste is treated
PAH's as sampled with EPA Modified Method 5 (coal tar only)
applicable metals
Sites with soils having elevated background or metals from other sources shall undergo risk screening for
metals emission. In this case, samples representing the highest concentration of metals shall be collected
from the site for the screening.
7.2 Emission Monitoring - Continuous Emission Monitors (CEM)
CEM's shall include oxygen and carbon monoxide (CO).
7.3 Sampling and Analytical Methods
EPA methodologies shall be as specified in 40 CFR Part 60, Appendix B.
7.4 Sample QA /QC
All QA/QC required by the analytical method shall be completed. Lab QA/QC summary documentation
(including chain of custody and summary of any deviation from the QA/QC specified by the method) shall
be submitted with analytical results. Ultimate responsibility for QA/QC documentation belongs with the
responsible party. However, the responsible party may contract with another entity, such as an analytical
laboratory, to house the actual QA/QC data.
8.0 WATER DISCHARGE REQUIREMENTS
The operation of some treatment equipment may generate various types of water. Possible sources of
water generation include, condensate from the treatment system, storm water runoff, non - contact cooling
water, soil stockpile leachate. All such water shall be collected; such water shall be treated, recycled or
discharged in accordance with applicable regulations. If process water is used to re- moisturize soil,
treatment verification sampling shall occur after re- moisturization. Any excess water which is generated
shall be disposed in accordance with individual state requirements. In general, water can be disposed at
a permitted off -site commercial facility, a publicly owned treatment works (POTW) or on -site in
accordance with a National Pollution Discharge Elimination System (NPDES) permit.
9.0 OPERATIONS RECORD KEEPING
The following records shall be maintained on site or at other approved location:
rTh
Summary of soll treatment verfflcation sample results
Operating Iogs, including
CEM records or logs
Shutdown events incuded in Section 6.4
Monitoring parameters included in Section 6.3
Documentation on the retreatment or disposal of failed batches
10.0 GENERAL Q8/QC
An independent certified la is required for all ana!ytical testing for environmental media including
air, soil and water. An in-house cedifiodlaboratory may be used ifsd least 1DY6of the samples are
verified by an independent certified laboratory. These provisions apply to both mobile and fixed
laboratories.
11.0 HEALTH AND SAFETY
A writte Health and Safety PIan shall be developed and implemented in accordance with Occupation
Safety and Health Administration (OSHA) regulations 20 CFR 1910.120, the Hazardous Waste
Operations and Emergency Response Rule. The plan shall address the following elements:
Key Personnel Air Monitoring
Health and Safety Risks Site Contro
Training Decontamination
Protective Equipment Emergency Response
Medical Survelllance Confined Space Entry
Spill Containment System Operation Safety
System Maintenance Safety
12.0 REFERENCES
1. Federal Remediation Technologies Roundtable, March 1995. Guide to Documenting Cost and
Performance for Remediation P jects: EPA-542-B-95-002.
2 Participants of the DO/T Tribal and Public Forum 0O Technology and Public Acceptance, May 1995. A
Guide to Tribal and Community Involvement in Innovative Technology Assessment.
3 U.G. Environmental Protection Agency, November 1993. Innovative Site Remediation Technology,
Thermal Desorption, Volume 6: EPA 542-B-93-001.
4. U.G. Environmental Protection Agency, October 1994. How to Evaluate Alternative Clean-up
Technologies for Underground Storage Tank Sites (A Guide for Corrective Action Plan Reviewers.): EPA
510-8-94-003.
5. U.G. Environmental Protection Agency, January 27, 1995. Cost and Performance Report, Thermal
Desorption at the T H Agriculture and Nutrition Company Superfund Site, Albany, Georgia..
O. Lae, Ba, 1091. Draft Engineering BuHetin: Treatment of Manufactured Gas Plant (MGP) SoHs,
California Enviror,mental Protection Agency Department of Toxic Substances Control, Aternative
Technology Division.
APPENDIX A
Outline of
Cost and Performanc Report
for LTTD
OUTLINE of
COST and PERFORMANCE REPORT
for LTT
1. Executive summary
2. Site information
3. Background
a. Contaminant Location and Geologic Profile
b. Contaminant Characterization
c, Soll/waste characteristics affecting treatment cost or performance
4. Treatment System Description
a. Therrnal desorption system description and operation
- Detailed Description
- Automatic Feed-Cutoff Conditions
b. Operating parameters affecting treatment cost or performance
c. Project timelirie
5. Treatment System Performance
a. - Cleanup Goats/Standards
b. - Treatment Performance Data
- Test Run Data Summary
-FuU-oca|aGuato|ned Run Data Summary
c. - Performance Data Assessment
d. - Performance Data Completeness
e. - Performance Data Quality
6. Treatment System Costs
a. - Procurement Process
b. - Cost Data Quality
c. - Treatment Cost Elements
d. - Before Treatment Cost Elements
e. - Post Treatment Cost Element
7. Observations and Lessons Learned
a. Cost Observations and Lessons Learned
b. Performance Observations and Lessons Leamed
8. References
9. Appendix
A. Treatabillty Study Results (if applicable)
- Objectives
- Test Description
- Performance Data
- Lessons Learned
- Full Scale Treatment Activity (soil data)
B. Tes Run Data
C. Full Scale Treatment Activity Soil Data
APPENDIX B
Summary of
State Acceptance of
LTTD Work Product
TABLE B-1
Summary of VerbailWritten ndicatioas of State Coacurrence
as of May 29, 1996
We agree that the requirements are appropriate and commit to using them to the maximum extent
feasible;
(b) We agree that the requirements are appropriate; however, have an organizational, nsQu|obzry, policy,
or statutory conflict. (Ptease indicate what the conflict is).
(c) We agree conceptually with the requirements and will use and evaluate them in a test mode; or
(d) We do not believe the requrements are appropriate. (Please indicate the reasons why.)
1- Quality
otal
Documen
STATE 'Level A"
Others -
"Level A"
M ixed for
specified
ections
otal
Document
'Level B"
Nonconcurrence
otal or one or more
Document"L ections
evel C"
tatus of
concurrence
process
Letter
Submitted
Letters
ubmitted
I CO
Letter
ubmitted
In mid-process
In mid-process
Related Links:
• For Further Information on a Variety of Thermal Treatment Technologies click here for an EPA
Summary Report of Demonstrations.
FROM :SOILPRO
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FAX NO. :9072749295 May. 07 2002 10:10AM P4
MANE TARSIER
ARCA
(monmum o' FIR*
PROCESSOR)
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SEE FlOORE 3 FOR DETAILS
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SOIL PROCESSING INC.
20 7 E. NOKTHenm umers BLVD.. SUIT 1 OSA
micHORAck AK P4503
1=271-32a1 vFAX: ESN) 214-92IS
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FIGURE 2
SITE PLAN
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