GCI Tech Notes Library

GCI TECH NOTES ©

Volume 2, Number 6

A Gossman Consulting, Inc. Publication

June 1996

Continuous Monitoring Requirements BIF Versus HWC

Craig Cape

Since the Revised Standards for Hazardous Waste Combustors (HWC) was released in draft form to the public on or about March 21, 1996 many interested people have begun to review and prepare comments on this proposed rule. Among many significant questions about this rule was one which asks how does this set of regulations compare to those of BIF? The BIF rule, which significantly further regulated the burning of hazardous waste in boilers and industrial furnaces, was published as a final rule February 21, 1991. Subsequent to that publication, several amendments have altered some aspects of the rule, such as the removal of the alternative hydrocarbon Tier III compliance method. Now, with the release of the proposed HWC rules, not just amendments to BIF but very fundamental changes are being proposed for those same boilers and industrial furnaces as well as for most other hazardous waste burners.

One of the general areas of the proposed rule under review by GCI is that of assessing the change proposed to 40 CFR regulations. To summarize, the basic sections changed are found in Parts 60, 63, 260, 261, 264, 265, 266, 270, and 271. This article will focus more on some key aspects of the impact of Part 63. What is key about this Part is that subpart EEE replaces many of the most significant areas in Part 266 which establishes the BIF regulations. Of major importance is the change proposed to the continuous monitoring requirements which includes continuous emission monitoring (CEM) and other process monitoring systems.

To anyone who has read some or all of the published documents describing and supporting the HWC rules, it has become very clear that the proposed rule is at least very complex. To aid in solving some the complexity, GCI has prepared a table which makes a comparison of continuous monitoring systems (CMS) required by the BIF rules to the CMS requirements of the proposed HWC rules. This table will help with understanding the impact on some of the required compliance operating activities proposed in this rule. It can also provide a framework to begin to estimate the additional capital and operational costs as compared to the current monitoring costs. These issues should be relevant to those who will make official comment on these proposed rules as well as to those whose job is to manage and operate a facility potentially regulated by them.

Among the most significant impacts is that of the proposed use of CEMs for control of emissions not previously monitored on a continuous basis, such as particulate matter. Also significant is the fact that the proposed rule calls for different and additional averaging periods to the continuous monitoring requirements.

Some other issues from the table that concern CMSs, and are important to briefly discuss, are changes to the automatic waste fuel cut-off system (AWFCOs) and quality assurance/quality control (QA/QC) program. These two items were included in the BIF regulations, but have been expanded under the proposed rule. AWFCOs are being linked to more activities than under BIF, such as the monitoring of combustion zone pressures. AWFCOs which do occur are requiring much more documentation and reporting than under BIF. This includes a definition for excessive AWFCOs and a requirement to specifically report them to EPA. The appendix to Part 63, subpart EEE requires the development and implementation of a QA/QC program for the CMSs. It should be noted that the rule specifically includes any associated equipment (thermocouples, pressure transducers, etc.) along with the monitor for inclusion in the QA/QC program. QA/QC requirements under the proposed rule include by reference sections of part 63.8 in addition to those of the appendix. QA/QC requirements also include a linkage between routine QA/QC check activities and AWFCOs. This, in essence, requires an AWFCO for certain routine adjustments. All operators currently have some level of QA/QC that they use for their CMS now; but the issue is, will it conform with the proposed rule requirements?

These issues, those of reduced emission levels, and others which involve the routine monitoring activities should make this table a valuable resource in considering the impacts of the proposed rule. We encourage all that are impacted by this proposed rule to carefully evaluate it and comment to EPA.

CMS Comparison BIF Versus HWC

CMS Item	BIF Compliance Method	BIF Compliance Standard Setting	BIF Compliance Monitoring	HWC Compliance Methods	HWC Compliance Standard Setting	HWC Compliance Monitoring
PM	No Continuous Emission Monitoring of PM required			Continuous Emission Monitoring of PM Required
	Compliance/ Trial Burn Test: Emission Sampling	Standard by Rule: 180 mg/dscm per test sample		Two Methods: Compre. Perform. Test PM Standard CEM	Standard by Rule: 69 mg/dscm 2- hr. roll. ave.	none
				Site -Specific PM Limit (see SVM, LVM, and D/F) CEM	Standard Set by Test: (two limit values) ave. over all runs of max. 10 min. rolling ave. for each run ave. of all one min. ave. over all runs	10 min. rolling ave. hourly rolling ave.
	Operating Limits: max. production rate (tons/hour)	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	Operating Limits: None, specific for PM (PM is an operating limit under HWC)
	Total Haz. Waste Feed Pumpable Haz. Waste Feed	ave. over all runs of max. hourly rolling ave. for each run same as above	hourly rolling ave. same as above
	max. combustion chamber temp.	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.
PM (cont.)	max. temp. at APCD	see below	see below
	min. kVA for an ESP	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.
	max. flue gas flow rate	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.
	min. pressure drop for a baghouse	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.
Max. Combust chamber Pressure	No CMS required combustion zone pressure, or totally sealed combustion zone, or approved alternative	Standard by Rule: lower than atmospheric pressure	No requirement	CMS required max. combustion zone pressure, or totally sealed combustion zone, or approved alternative (must specify method in operating plan)	Standard by Rule: lower than ambient pressure	instantaneous monitor CMS/AWFCO
CO (Main Stack)	Compliance/Trial Burn Test CEM	Standard by Rule: 100 ppm	Hourly rolling ave.	Compre./Confir. Performance Test No CO required
CO (Main Stack) (Cont.) (Bypass Duct Only)	or CO alternative and (HC) CEM	Standard by Test: test ave. value ave. over all runs of max. hourly rolling ave. for each run (see HC)	hourly rolling ave. (see HC)
	Compliance/Trial Burn Test CEM	Standard by Rule: 100 ppm	hourly rolling ave.	Compre./Confir. Performance Test CEM	Standard by Rule: 100 ppm CO	hourly rolling ave.
	or CO (alternative) and (HC) CEM	Standard by Test: test ave. value ave. over all runs of max. hourly rolling ave. for each run (see HC)	hourly rolling ave. (see HC)	or (HC) CEM	Standard by Rule: 6.7 ppm HC	hourly rolling ave.
HC	Compliance/Trial Burn Test CEM	Standard by Rule: 20 ppm	hourly rolling ave	Compre./Confir. Performance test CEM	(for main stack) Standard by Rule: 20 ppm	hourly rolling ave.
O₂	Compliance/Trial Burn Test CEM	No standard monitor for O₂ correction	monitor for O₂ correction	Compre./Confir. Performance test CEM	No standard monitor for O₂ correction	monitor for O₂ correction
Max. temp. @ dry PM device (APCD)	Compliance/Trial Burn Test CMS	Standard by Test: test ave. value ave. over metal and chlorine runs of max. hourly rolling ave. for each run	hourly rolling ave.	Compre./Confir. Performance Test CMS	Standard by Test: test ave. values ave. over D/F runs of max. 10 min. rolling ave. for each run ave. level over all D/F runs	10 min. rolling ave. hourly rolling ave.
D/F	Conditionally required for Compliance or Trial Burn Test	Standard by Rule: Risk Assessment		Required for Compre./Confir. Performance Test	Standard by Rule: 0.2 ng/dscm, TEQ
	No CEM			No CEM
	Operating Limits (no specific limits beyond the risk assessment)			Operating Limits: max. temp. @ dry APCD	(see above)	(see above)
				min. combustion chamber temperature	ave. over all runs of the lowest 10 min. rolling ave. for each run ave. level over all runs	10 min. rolling ave. hourly rolling ave.
				max. flue gas flow, or production rate	ave. over all runs of the max. hourly rolling ave. for each run	hourly rolling ave.
				max. H.W. feedrate	ave. over all runs of the max. hourly rolling ave. for each run	hourly rolling ave.
				BATCH or CONTAINERS ONLY max. batch size	lowest mass batch fed during test	batch mas
				min. batch feeding frequency	longest interval between batch or container feedings during Comp. test	batch time interval
D/F (Cont.)				min. combustion zone O₂	highest instantaneous O₂ level for any batch or container fed during testing	O₂ concentration
				(Cks) hot end injec. Exempt but require documentation	container 1 gal. or less firing rate not to exceed rate during test	container 1 gal. or less firing rate not to exceed rate during test
				PM limit CEM Site-specific limits	test level 1. ave. over all runs of the max. 10 min. rolling ave. for each run 2. ave. of all one min. ave. over all runs	2-hour rolling ave. 10-min. rolling ave. hourly rolling ave.
				Confirmatory Performance Test 17-19 months after Comprehensive Test Normal operating condition determined by the ave. value of prev. 18 months of one min. averages	.
D/F (cont.)				(optional) Carbon Injection Carbon Bed Catalytic Oxidizer Inhibitor Feedrate
Hg	Compliance/Trial Burn Test	Standard by Site-Specific Conditions		Comprehensive Performance Test	Standard by Rule: 50 ug/dscm
	No CEM			CEM		10-hour rolling ave.
	Operating Limits: max. total feedrate of Hg	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	or (Waiver of CEMs) determine max. possible Hg emission from max. Hg feed	<50 ug/dscm Hg emissions based on total input	analysis of all feeds (no ave. period given)
	max. total feedrate of Hg for haz. waste max. total feedrate of Hg for pumpable haz. waste	ave. over all runs of max. hourly rolling ave. for each run ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave. hourly rolling ave.	min stack gas flow rate or surrogate	Not given.	connected to AWFCs
	max. total feedrate of HCl/Cl₂	see SVM & LVM	see SVM & LVM	No requirement.
	max. prod. rate	see SVM & LVM	see SVM & LVM	No requirement.
	max. combustion chamber temp.	see SVM & LVM	see SVM & LVM	No requirement.
	max. flue gas temp. at the APCD	see SVM & LVM	see SVM & LVM	No requirement.
	ESP min. kVA	see SVM & LVM	see SVM & LVM	No requirement.
Hg (Cont.)	baghouse min. pressure drop	see SVM & LVM	see SVM & LVM	No requirement.
SVM (Cd, Pb)	Compliance/Trial Burn Test	Standard by Site-Specific Conditions (separate metals)		Comprehensive Performance Test:	Standard by Rule: 57 ug/dscm combined
	No CEM			CEM		10-hour rolling ave.
	Operating limits: No PM limit			or Operating Limits: PM limit CEM Site-Specific CEM	(see PM #1) (see PM #2)	(see PM #1) (see PM #2)
	max. total feedrate of separate metals	ave. over all runs of highest hourly rolling ave. for each run	hourly rolling ave.	max. total feedrate of Cd, Pb combined	ave. feedrate over all runs	12-hour rolling ave.
	max. total feedrate of HCl/Cl2	ave. over all runs of highest hourly rolling ave. for each run	hourly rolling ave.	max. chlorine feedrate	ave. feedrate over all runs	12-hour rolling ave.
	max. production rate	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	min. gas flow rate or surrogate	ave. over all runs of lowest hourly rolling ave. for each run	hourly rolling ave.
	max. combustion chamber temp.	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	No requirement
	max. flue gas temp. at the APCD	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	No requirement
SVM (Cd, Pb) (Cont.)	ESP min. kVA	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	No requirement
SVM (Cd, Pb) (Cont.)	Baghouse min. pressure drop	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	No requirement
LVM (As, Be, Cr, Sb)	Compliance/Trial Burn Test	Standard by Site-Specific Conditions (separate metals)		Comprehensive Performance Test:	Standard by Rule: 130 ug/dscm combined
	No CEM			CEM		10-hour rolling ave.
	Operating Limits: No PM Limits			or Operating Limits: PM limits CEM Site-Specific CEM	(see PM #1) (see PM #2)	(see PM #1) (see PM #2)
	max total feedrate of separate metals	ave. over all runs of highest hourly rolling ave. for each run	hourly rolling ave.	max. total feedrate of As, Be, Cr, and Sb combined max. feedrate of As, Be, Cr, and Sb from pumpable feedstream	ave. feedrate over all runs ave, feedrate over all runs	12-hour rolling ave. 12- hour rolling ave.
	max total feedrate of HCl/Cl₂	ave. over all runs of highest hourly rolling ave. for each run	hourly rolling ave.	max. chlorine feedrate	ave, feedrate over all runs	12-hour rolling ave.
	max. production rate	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	min. gas flow rate or surrogate	ave. over all runs of lowest hourly rolling ave. for each run	hourly rolling ave.
LVM (As, Be, Cr, Sb) (cont.)	max. combustion chamber temp.	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	No requirement
	max. flue gas temp. at the APCD	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	No requirement
	ESP min. kVA	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	No requirement
	Baghouse min. pressure drop	ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave.	No requirement
HCl/Cl₂	Compliance/Trial Burn Test:	Standard by Site-Specific Conditions		Comprehensive Performance Test:	Standard by Rule: 630 ppm combined
	No CEM			CEM		hourly rolling ave.
	Operating Limits: total HCl/Cl₂ feedrate max. production rate	ave. over all runs of max. hourly rolling ave. for each run ave. over all runs of max. hourly rolling ave. for each run	hourly rolling ave. hourly rolling ave.	or Operating Limits: total HCl/Cl₂ feedrate max. flue gas flow rate or production rate	ave. feedrate over all runs ave. over all runs of max. hourly rolling ave. for each run	12-hour rolling ave. hourly rolling ave.