Page 513 - Materials Chemistry, Second Edition

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484 Waste Management Practices: Municipal, Hazardous, and Industrial
15.4.8 OBTAINING THE RCRA PERMIT
A facility planning to operate a new hazardous waste incinerator is required to obtain a RCRA per-
mit before constructing the unit. The purpose of the permit is to allow the facility to establish incin-
eration conditions that will ensure the protection of public health and the environment. The incinerator
permit covers aspects of pretrial burn, trial burn, posttrial burn, and final operating conditions.
The pretrial burn phase of the permit allows the incinerator to initiate all parameters for conduct-
ing the trial burn. This may include setting charging rates, fuel and airflow rates, and installing air mon-
itoring equipment. During the trial burn, the incinerator is prepared for operation. Operating conditions
are monitored and adjusted, and gaseous emissions are measured. Test conditions are based on the
operating conditions specifically indicated by the permit application. The U.S. EPA establishes condi-
tions in the permit necessary to conduct the trial burn; in other words, the burn should represent the
expected incinerator operation. Physical and chemical analysis of the waste feed is also a necessary
component of the trial burn permit application. During operation, the waste must be analyzed to ver-
ify that its composition is within the limits specified in the permit. This analysis may include a deter-
mination of the content of hazardous constituents including POHCs and the heat value of the waste.
The posttrial burn period is devoted to completing the sampling, analysis and calculation of trial
burn results, and the submission of the results to the U.S. EPA. During this period the EPA evalu-
ates all data compiled during the trial burn. After reviewing the results, the EPA may modify the
permit conditions again to ensure compliance with incinerator standards and the protection of health
and the environment.

15.4.9 MONITORING AND INSPECTIONS
In order to ensure safe operations in compliance with all permit specifications, the operator must
perform the following during the routine incineration of hazardous waste (U.S. EPA, 2000):

● Monitor waste feed rate, combustion temperature, and combustion gas velocity on a con-
tinuous basis
● Monitor carbon monoxide emissions on a continuous basis at some point downstream of
the combustion zone and prior to release to the atmosphere
● Sample and analyze the waste and exhaust emissions to verify compliance with permit
operating requirements
● Conduct daily visual inspections of the incinerator and associated equipment (e.g.,
pumps, valves, and conveyors)
● Test the emergency waste feed cutoff system and associated alarms at least once weekly
(40 CFR Part 264.347)

15.4.10 MANAGEMENT OF RESIDUES
According to the Derived-From Rule, if an incinerator burns a listed hazardous waste, the ash gener-
ated is also considered a listed waste. The Derived-From Rule states that any solid waste generated
from the treatment, storage or disposal of a listed hazardous waste, including any sludge, spill
residue, ash, emission control dust, or leachate, remains a hazardous waste. The operator is also
required to determine whether the ash exhibits any characteristics of a hazardous waste. If a facility
incinerates a characteristic hazardous waste (ignitable, corrosive, reactive, and toxic), the operator
must determine whether the ash exhibits any of the four characteristics, using the procedures outlined
in 40 CFR Part 261. If an ash sample fails the test (i.e., exhibits a characteristic), it must be managed
as a hazardous waste.

15.4.11 CLOSURE
At the time of closure, the facility operator must remove all hazardous waste and hazardous residues
from the incinerator site. In addition, if the residues are hazardous waste, the operator becomes a