GUIDANCE TO ATSDR HEALTH ASSESSORS · 2019-12-16 · GUIDANCE TO ATSDR HEALTH ASSESSORS PUBLIC...

GUIDANCE TO ATSDR HEALTH ASSESSORS

PUBLIC HEALTH OVERVIEW OF INCINERATION

AS A MEANS TO

DESTROY HAZARDOUS WASTES

Prepared by:Division of Health Assessment and Consultation

U.S. Department of Health and Human ServicesPublic Health Service

Agency for Toxic Substances and Disease Registry-Atlanta, Georgia 30333

February 1992

Incinerator Overview for ATSDR Public Health Assessors

FOREWORD

This document states the views and policies of the Agency forToxic Substances and Disease Registry (ATSDR) on use oftemporarily-sited incinerators to destroy hazardous wastes. Thedocument is intended for use by ATSDR's health assessors andregional staff when responding to questions about public healthimplications of the incineration of hazardous wastes. The viewscontained in the document are meant to address public healthissues sometimes voiced to ATSDR by state and local healthagencies and the general public in connection with incinerationof wastes. As such, the document is not meant to replace ormodify materials used by other government agencies charged withthe responsibility to determine actions on management ofhazardous wastes.

Although this document deals with incineration of hazardouswastes, the reader is cautioned that ATSDR's acceptance ofincineration of hazardous substances is contingent onconsideration of all remedial alternatives for a site. That is,each remedial alternative, including incineration of hazardouswastes/ must be evaluated for its potential to affect publichealth. Moreover, the selection of a particular remedial actionat a site resides with federal and state regulatory agencies thatmust consider public health implications along with other riskmanagement considerations.

Although ATSDR has public health authorities under both theComprehensive Environmental Response, Compensation, and LiabilityAct" (CERCLA), as amended, and the Resource Conservation andRecovery 'Act (RCRA), as amended, this document pertains only toincineration actions proposed or taken under CERCLA. Therefore,ATSDR's comments in this document pertain only to thetemporarily-sited incinerators that are to be used to remediatesites under CERCLA.


Table of Contents

Foreword.................................................... i

Introduction............................................... 1

Background................................................. 1

Incinerator Design and Operating Considerations............2

a. Principal Organic Hazard Constituents (POHCs)

b. Products of Incomplete Combustion (PICs)

c. Ash

d. Design Considerations

Regulatory Considerations.................................. 7

Other Considerations of Importance to Public Health........ 7

a. Training of Operators

b. Siting of an Incinerator

c. Storage of Materials

d. Transportation of Wastes to the Incinerator

e. Maintaining Good Performance

f. Community Right-to-Know

Summary of Public Health Considerations .................... 10

Table 1 - Summary of Public Health Considerations..........12

Table 2 - Pertinent Documents for Public Health............13Assessor Review

Table 3 - EPA Hazardous Waste Incineration Documents.......14

References................................................. 15


INTRODUCTION

The Agency for Toxic Substances and Disease Registry (ATSDR)receives questions from health professionals in state and localhealth agencies and from the public regarding human healthimplications of hazardous waste incineration. Because healthstudies of populations living near incineration facilities arefew, the Agency cannot answer many of those questions.1 Also,because incinerators are often located in industrial areas, itwould be difficult or impossible in many instances to attributeany observed health effects to one source of emissions. Forexample, there may be power plants, materials production plants,commercial cleaning facilities, or other establishments whoseToxic Chemical Release Inventory data suggest the facilities havethe potential to impact local air quality.

However, the better. Agency staff understand the characteristicsof a well-designed and properly operated hazardous wasteincinerator, the better ATSDR can provide informed advice aboutpublic health implications. The purpose, therefore, of thisdocument is to provide ATSDR staff an overview of the currentengineering practices of incineration and their relationship topublic health concerns regarding actual or potential contaminantreleases associated with the technology.

ATSDR's Division of Health Assessment and Consultation maintainsadditional materials to help public health assessment personnelevaluate the public health implications of hazardous wasteincineration. For a representation of the kinds of referencematerials maintained by ATSDR, see the references used for thisoverview and the list of Environmental Protection Agency (EPA)guidance documents in Table 3.

BACKGROUND

As a matter of general public health policy, ATSDR supports wasteminimization, recycling, and reuse as the preferred methods forreducing the volume of hazardous wastes and associated publichealth hazards. However, the Agency recognizes that not allhazardous waste can be eliminated and that wastes need propermanagement and disposal. In some situations, such as the

'It should be noted that ATSDR has undertaken two healthstudies of communities near incinerators; one in Jacksonville,Arkansas, near an incinerator used for cleaning up a Superfundsite; the other in Lenoir, North Carolina, near an incineratorthat was closed by the local county health officer because ofalleged improper operation.

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remediation of hazardous waste at Superfund sites, a review ofall remedial technologies may indicate the use of mobileincinerators as the preferred method of permanently eliminatingor reducing potential public health hazards posed by thosewastes. ATSDR believes that a properly designed and operatedincinerator can effectively destroy certain kinds of hazardouswastes in a manner that is protective of public health.

The EPA is responsible for selecting and implementing remediesfor cleanup of Superfund National Priorities List (NPL) sites.EPA's selection of incineration as the remedy of choice for somesites has led to an increased number of requests to ATSDR forhealth information related to incineration. When selected as asite remedy, incineration should be conducted in a manner thatprotects human health.

ATSDR does not participate in the actual site remedy selectiondecision, or any engineering or monitoring decisions; however, itis ATSDR's responsibility to advise on the public healthimplications of the technology, as needed, when proposed for orused at NPL sites. Many of the requests for assistance ATSDRreceives are related to the transportable incinerators used forsite remediation. In response to such requests, it is ATSDR'spolicy to review site-specific design and operating detailsufficiently to assess actual and potential contaminant releasesposed by the facility. That policy is consistent with the sourceevaluation phase of the ATSDR public health assessment protocol.

Some of the information in this overview also may be applicableto other kinds of incinerators that public health assessors maybe required to review, i.e., permanent municipal and medicalwaste incinerators; however, ATSDR staff are strongly cautionedagainst applying the findings in this paper to other than CERCLAincinerators.

INCINERATOR DESIGN AND OPERATING CONSIDERATIONS

The goals of the modern hazardous waste incinerator are to reduceor destroy the organic contaminants, and to reduce the volume ofwaste materials, thus minimizing the amounts of potentiallyhazardous substances needing final disposal. To achieve thosegoals, the incinerator must be able to provide controlled burning(combustion) conditions that ensure the proper mixture of air,temperature, and gas, and time to allow thorough destruction oforganic constituents to take place. A deficiency in any of thoserequirements can result in incomplete combustion and theproduction of smoke and possibly harmful air emissions. Suchemissions are a potential public health hazard because nearbycommunities may be exposed to site contaminants via the airtransport pathway. It should also be recognized that human

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exposure to airborne incinerator contaminants can occurindirectly by consumption of animals or plants raised in areaswhere deposition of emissions takes place (1).

In addition to the potential health hazard to communities fromair emissions of hazardous substances, the design and operationof an incinerator have implications for the workers at thefacility. Inadequate work practices and poor industrial hygieneconditions at an incinerator have the potential to cause adversehealth effects in workers.

In striving for hazardous waste incineration performance thatprotects both human health and the environment, EPA hasestablished operating and performance standards based on researchand trial burn data. The EPA hazardous waste incinerationregulations are found in 40 CFR Part 264, Subpart 0. Thehazardous waste regulations developed under the ResourceConservation and Recovery Act (RCRA) are commonly called the RCRAregulations. The standards are designed to limit emissions ofcertain pollutants to EPA-specified acceptable levels. Emissionstandards have been set for particulates, hydrogen chloride, andprincipal organic hazard constituents (POKCs).

The EPA standards for particulates (0.08 grains per dry standardcubic foot corrected to 7% 02) and hydrogen chloride (4 poundsper hour or 99% removal) are generic and" apply uniformly to allhazardous waste incinerators. EPA has also developed a number ofguidance documents used by RCRA permit writers and by CERCLAstaff to evaluate hazardous waste incinerators (See Table 3}.Those documents specify how to apply the generic regulatorystandards on a site-specific basis. The more recent guidancedocuments recommend limiting emissions of certain metals,products of incomplete combustion, and carbon monoxide. Thepublic health assessor should obtain a copy of the operatingconditions specified by CERCLA, as well as any amendments tothose documents for the incinerator being evaluated. Thosedocuments can be used to determine and evaluate the operatingconditions and emission limits that have been applied to theincinerator during specific time periods.

Principal Organic Hazard Constituents (POHCs)

Also as a part of the hazardous waste incinerator permittingprocess, certain constituents of the wastes, or POHCs, andoperating conditions are selected for trial burns. Trial burnsare conducted to demonstrate an incinerator's performance underthe worst conditions that would be allowed during future routineoperations. POHCs are selected based on their degree oftoxicity, their prevalence in the waste mix, and/or theirdifficulty to burn. A new incinerator must demonstrate, through

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trial burns, that it can successfully meet all emissionstandards. For POHCs, that standard is a destruction and removalefficiency (DRE) of at least 99.99%. That means that no morethan 0.01% of the selected POHC compounds fed into theincinerator may be emitted to the atmosphere. If polychlorinatedbiphenyls (PCBs) or dioxins are to be burned, the DRE requirementis 99.9999%.2 When individual states are authorized toadminister hazardous waste incineration regulations, suchregulations must be at least as stringent as those issued by EPA.

Products of Incomplete Combustion (PICs)

When hazardous waste or virtually any other material is burned,products of incomplete combustion (PICs) can be formed (2,3).PICs can be partial breakdown products from the waste beingburned, or they can be new species of compounds formed by therecombination of other breakdown products. PICs can berelatively harmless, or they can be even more toxic than theparent compounds of the waste fed to the incinerator.Benzo-a-pyrene and 2,3,7,8-tetrachlorodibenzo-p-dioxin areexamples of potentially harmful PICs that may be emitted if anincinerator is inadequately designed or improperly operated.

The public and the regulatory community alike are concerned aboutPIC emissions, particularly because they are difficult to predictand, therefore, to regulate. In an attempt to address thatconcern, EPA researched the formation of PICs during test burnsconducted at hazardous waste incinerators throughout the UnitedStates, and at incinerators used strictly for research. Testingwas done under steady-state (normal) and upset operatingconditions. Using test burn findings, EPA states that, if theincinerator is meeting the stack emission requirements,particularly the CO limit of 100 parts per million by volume,available field test data show that PIC emissions are limited toconcentrations that do not pose unacceptable risks (4). Thatposition is founded upon cancer-based health risk assessments foridentified PICs. It should be noted that although research hasnot identified all PICs, and other potential health outcomes(non-cancer) have not been thoroughly evaluated, the evaluationof cancer risks typically results in allowable exposure levels

2PCBs are regulated by EPA under the Toxic SubstancesControl Act (TSCA). Most PCS incinerators co-burn hazardouswastes; therefore, the other operating and performance standardsdiscussed in this section also apply to the incinerator. Itshould be noted, however, that, if the incinerator burns onlyPCBs, only the TSCA regulations apply, and the permit may not beas comprehensive as a RCRA permit. This overview does notaddress differences between RCRA and TSCA regulations.

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much lower than would be allowed for non-cancer health outcomes.Because there is no recognized threshold exposure level for thecancer health outcome, even extraordinarily low exposures tocarcinogenic substances are assumed to pose some risk of cancer.In order to keep that risk at an acceptable level (usually onecancer in a lifetime per 100,000, or one million, exposedindividuals), only very low exposure levels are allowed byregulatory agencies.

For organics of particular concern, or for inorganic contaminantssuch as metals, hydrogen chloride, or chlorine, emission limitscan be formulated specifically for the incinerator and thegeographic area of concern. The EPA guidance manuals recommendthat such limits be based on anticipated stack releases of theparticular contaminant (usually worst case), local meteorologicconditions, geographical site features, and proximity to localpopulations (4,5). It should be noted that such conditions havebeen included in RCRA guidance manuals only since the late 1980s.The public health assessor should review the CERCLA contracts, ineffect at each facility to determine what the potential emissionsmay be.

Another public health concern that citizens often raise abouthazardous waste incineration pertains to disposal of ashgenerated by the process (6,7). By definition, such ash isconsidered hazardous waste and must be managed as such in apermitted hazardous waste treatment, storage, or disposalfacility, such as a permitted hazardous waste landfill. If EPAcan be shown that the ash is nonhazardous, the ash can bedisposed 'of in a licensed municipal waste landfill. Minimally,evidence would have to be provided showing that the ash is notcorrosive, reactive, or flammable, and that it will not releasewater-soluble toxic substances, such as heavy metals, togroundwater or surface waters, at levels above EPA levels ofconcern.

Design Considerations

To minimize the public's potential exposure to site emissions, anincinerator must be designed and operated properly. Whatconstitutes a state-of-the art, well designed, and properlyoperated incinerator? The incinerator must be designed to burnwaste materials thoroughly (8) . The combustion chambers must beof a size and arranged in a way to provide adequate time for thegases produced by burning waste to mix with proper amounts ofcombustion air, and to maintain the high temperatures needed toensure that the burning is completed. When an incinerator isdesigned, the waste to be burned must be characterized for such

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properties as heat content (fuel value), percent moisture,chlorine content, metals content, and physical characteristics.The size and physical layout of the incinerator should be basedon those waste properties.

The incinerator must be designed and operated in a manner thatminimizes production of non-stack, fugitive emissions. That canbe accomplished by ensuring proper seals at all systemconnections, maintaining negative gas pressures throughout thecombustion gas flow path, and by limiting the waste feed toprevent excessive and rapid releases of volatile compounds.Careful attention must also be given to the design and operationof waste handling systems to minimize fugitive emissions. ATSDRpublic health assessors have found that excavation and handlingof soils at some Superfund sites, and waste unloading andrepackaging operations at some RCRA facilities, have been majorsources of airborne contaminants that have resulted in exposureof workers and/or nearby residents.

Another critical part of the incinerator design is the pollutioncontrol system (9). Pollution control systems directly influencethe levels and kinds of pollutants that are released and that canpotentially reach the public. Most modern hazardous wasteincinerators are designed with extensive air pollution removalsystems. For example, a common pollution control system mightinclude a system that cools or "quenches" gases produced byburning waste, followed by a system that reduces acid gasemissions, and ultimately followed by a particulate removalsystem such as fabric filters (baghouses), electrostaticprecipitators, venturi scrubbers, and others.

Finally, 'current design of hazardous waste incinerators includesvarious safeguards, such as process monitoring devices (tomonitor parameters such as temperature, air flow, and operatingpressures); continuous emissions monitoring systems (to measureair emissions of carbon monoxide, gas flow rates, and possiblyother combustion, performance indicators); and automatic wastefeed shutoff devices (AWFSOs). AWFSOs, as required by RCRAregulations (40 CFR 264.345(e)), automatically stop the wastefeed to the incinerator when specified monitoring parametersexceed or fall below limits specified in the permit. Theparameters that trigger the AWFSOs are established based onsuccessful trial burns. AWFSOs are critical to ensuring that theincinerator cannot operate in an improper condition -- withattendant increased air emissions -- for extended periods of time(10) .

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REGULATORY CONSIDERATIONS

Automatic waste feed shutoffs, continuous emissions monitors, anddestruction and removal efficiencies are set by regulatoryauthorities depending on the type of wastes being incinerated andthe regulatory authority of the involved state. If theincinerator burns hazardous waste, it is regulated as a hazardouswaste incinerator subject to federal or state hazardous wasteregulations. Federal hazardous waste regulations pertaining toincineration are administered under the Resource Conservation andRecovery Act of 1976 as amended (RCRA), 42 U.S.C. 9621(e)(l),which is the major legislation that applies to all facets ofgeneration, transportation, treatment, storage, and disposal ofhazardous wastes in the United States. Some states, which havepassed hazardous waste regulations at least as restrictive asthose specified under RCRA, may be authorized by EPA toadminister their own regulations. In such cases, a state'srequirements may exceed those imposed under RCRA.

If, as in most cases involving mobile incinerators, the hazardouswaste incinerator is used as a remedy for an on-site cleanup of aSuperfund site, "no Federal, state, or local permit shall berequired." That provision is made in the ComprehensiveEnvironmental Response, Compensation, and Liability Act of 1980(P.L. 96-510), as amended by the Superfund Amendments andReauthorization Act of 1986 (P.L. 99-499) . However, the CERCLAincinerator must comply with all the technical requirements thatwould be applied to a permitted hazardous waste incinerator. Inother words, all technical requirements of a RCRA-regulatedincinerator would apply to a Superfund remediation incinerator,except that a specific permit would not be issued for theSuperfund incinerator. That provision was made to expediteremediation of this nation's Superfund sites by eliminating thevery long period, sometimes several years, required to obtainpermits for hazardous waste treatment. The Superfund program isstill obligated to ensure that relevant provisions of theapplicable laws or statutes are being met. This approach, asapplied to CERCLA waste incinerators, is important to help ensurethat certain regulatory provisions protective of public healthare addressed even when the incinerator is not a RCRA-permittedfacility.

OTHER CONSIDERATIONS OF IMPORTANCE TO PUBLIC HEALTH

Training of Operators

Even with all the proper design features, skilled operators areessential for a safe, effective incineration program. Operatorsshould understand the principles of good combustion and be

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thoroughly familiar with all major and support systems at theirplants. Careful attention to proper waste burn rates and wasteblending, as needed, helps to ensure that the combustion systemsare not overloaded and that the AWFSOs are not activatedexcessively. Routine maintenance, inspection, and instrumentcalibrations should be conducted and recorded. Safety andemergency response plans that thoroughly address likely failurescenarios (including power, systems, and operational failures)must be in place, documented, and shared with local officials.Emergency "release" drills should be conducted periodically withthe knowledge and involvement of local emergency responsepersonnel. In addition, all employees should be adequatelytrained in appropriate health and safety procedures for the safeday-to-day operation of the incinerator.

Siting of the Incinerator

Another consideration relevant to public health and frequentlyraised by the public is the location of the incinerator withrespect to the community. More specifically, what are thepossible health impacts associated with living or working in thepath of incinerator emissions? To address those concerns, whenreviewing the location of an incinerator, regulatory agencies usegenerally accepted air dispersion models in conjunction withlocal meteorologic data to determine the permit conditionsnecessary to protect human health and the environment. Suchmodelling results can be particularly helpful in identifyingprevailing wind transport patterns and their effect on downwindpollutant concentrations. Ideally, the site should not be wheremodeled high ground-level concentrations of stack emissionscoincide with population centers. Dispersion models can alsohelp evaluate the need for, and the location of, off-site airmonitors used to detect fugitive emissions associated withincinerator operations and related hazardous materials-handlingactivities. If there is concern about the impact of incinerationon a specific major food resource, such as a fish hatchery, andATSDR has data regarding the uptake of the contaminants ofconcern by the particular food chain species, dispersionmodelling can serve to estimate the concentration of emissionsthat would be available at ground level for food chain uptake.Finally, it should be noted that there is little flexibility inselecting a site for a Superfund incinerator, except with regardto where it is placed within the boundaries of the actual site.However, modelling as mentioned here is still useful in reviewingwhether or not to use incineration for cleanup of a particularsite.

Storage of Materials

In addition to the aforementioned issues regarding the

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incineration process, other concerns of relevance to publichealth need to be addressed. For example, hazardous waste to befed to the incinerator and process effluents resulting from theincinerator should be stored in a manner that does not allow foruncontrolled environmental releases of potentially harmfulsubstances. Dry, dusty materials should be enclosed or otherwisestored to prevent windborne transport of contaminatedparticulates. Wastes containing volatile organic compoundsshould be stored under conditions that safely collect and removegases released from the wastes.

Similarly, wet wastes or process effluents should be stored inchemically compatible, leak-resistant containers. Storage areasfor such liquid-bearing materials should have dikes or bedesigned to contain leakage. Processing of wastes, such asblending or shredding operations, may provide opportunities foraerosolization of contaminants. Such conditions should beadequately considered and waste-processing areas designed tominimize the potential exposure to workers on-site, as well as topeople living or working nearby.

Transportation of Wastes to the Incinerator

Finally, the means of transporting hazardous waste into theincinerator plant should be carefully considered. Routes ofaccess should be selected to minimize accident (release)potential and to avoid residential and play areas if possible.For the remediation of Superfund sites, for which no over-the-road hauling is required, care is still needed to avoid spillsand releases when transporting the wastes on site.

Maintaining Good Performance

Some considerations relevant to public health concerns aboutmodern and effective incineration systems have been described.However, local health officials and citizens of communities withhazardous waste incinerators have expressed to ATSDR theirconcern that they may not be able to judge a good operation, orthat, once the initial trial burns and inspections are completed,the system may not be operated in the same manner as during thetesting phase. Citizens also have expressed concerns thatburning rates will be exceeded or monitoring systems will beoverridden. What can be done to guard against such conditions?

ATSDR believes one way to ensure that the system continues tooperate in a manner consistent with operating conditionsspecified in the CERCLA contract, is for EPA to conduct frequent,random, unannounced facility inspections and to routinely providethe results to the public. Under some circumstances, permanenton-site inspectors might be advisable.

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Another way to ensure continued satisfactory operation is toretest the incinerator periodically. This would be appropriateif the CERCLA incinerator operates at the site for an extendedperiod of time, or there are other indications that it may not beoperating properly.

Each time a CERCLA incinerator is relocated, ATSDR recommendsthat it be retested. A less rigorous trial burn may beappropriate if the incinerator successfully passed a full trialburn on similar wastes at another site.

Community Ricrht-to-Know

ATSDR also strongly recommends that information and dataconcerning an incinerator's design, testing, operation, andmonitoring be shared with the public. The Agency endorses thatapproach as being consistent with the community right-to-knowrequirements already in place for industries that use and storehazardous substances in the community.

SUMMARY Q? PUBLIC HEALTH CONSIDERATIONS

Public health assessors should be aware of the generallyrecognized good practices listed in Table l when examining thepublic health acceptability of a proposed or existing hazardouswaste incinerator. Most of the considerations described in Table1 are already a part of the EPA RCRA and CERCLA oversightprocess.

As reliance on incineration as a remediation technologyincreases, ATSDR will collaborate with EFA in a number of areasto further broaden the data-base used in regulatory decision-making and in evaluation of health implications associated withincinerator technology. Public health assessors are advised tocontact the Division of Health Assessment and Consultation to getmore information.

With careful attention to design and proper operation of thefacility, significant quantities of hazardous waste can bereduced to smaller volumes of material that can be managedsafely. With the vigilance of the regulatory community and theinvolved citizenry, the facility can operate as specified in theCERCLA operation and maintenance plan.

It is hoped that this overview provides public health assessmentprofessionals with a general understanding of the keyconsiderations and concerns related to hazardous wasteincineration technology. As noted throughout this document, EPAplays a leading role in selecting or permitting, implementing,testing, and overseeing such technology. Most of the

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documentation needed by the public health assessor to evaluate aspecific incinerator can be obtained from EPA. Table 2 containsa list of typical site-specific documents of interest to thepublic health assessor. In addition, Table 3 lists EPA guidanceand resource documents that will be of assistance to the publichealth assessor. As a final caution, it must be remembered thateach site is unique, and must be carefully evaluated individuallyand not by generic extrapolation of data from other sites orstudies.

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. OF PUBLIC HEALTH. CONSIDERATIONS

The ;; following items .should be considered when -evaluating' ' "'" '' '

t'e chndl ogy : :us ed'. vpr\'.pf ppo s e d t o be ••• ;'uis epV:;:;;ia t • •• /a :; ; s i t e^^. -^® i- -PP oP ia-t e • : f or r:;-- and'W tbmpat ibl e

•'in;;;;selecting.j-:;a.:::::'sits . for a .CERCLA; incinerator,proximity to residential and other populations andlocal meteorologic conditions is considered toensure a. location that minimizes prevailing windtransport;of air, emissions to affected populations;

recognized, acceptable, and- when .possible, EPA-approved air modeling is used': to help screen andidentify potentially impacted areas as mentionedpreviously;

trial burns, with appropriate stack, sampling andanalysis, L: and subsequent continuous •':,'• emissionsmonitoring:;:are. conducted to demonstrate:; that the:;incinerator;;;perf orms ;as: specified;:;: • > :; :-:, ' ' "

adequate ':-':training, is provided to incineratoroperators to ensure that,the incinerator is operatedin a manner that does not adversely affect theoperators' or the community's health;

an active inspection program is instituted/

where the; incinerator must be at a site close to• neighboring -populations/'^local ambient; air monitorsiAare used:;to;..'detect possible site releasesv'.'to the air§requiring: jcprreqliiv^ act ion, •••:•'.;; :;".£••.-•;..;.-;.-'. '

|;prpperv''management v::of '-"residual•:.;;,ash2;'is .•:.part :;of ..•'. the:t:-:djiisig .;a ^ incinerator;;.;: and,;;;";: . ;

;;pr o ceciu r;e af ;c: ons i;s t exit ' ;;w |if t he.:';:. communi t y,1 r i gh t -1 o -' ' •>::V;::::;.-. : ;

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TABLE 2. PERTINENT DOCUMENTS FOR PUBLIC HEALTH ASSESSOR REVIEW

DOCUMENT*

I. Trial Burn Plan andTrial Burn Report

2. QA/QC Plan andSampling Plan

Remedial Design-Plan orEngineering/Design Plan

4. Site Health & Safety PlanContingency Plan

Operation & MaintenancePlan and InspectionSchedules

RELEVANCE TO PUBLIC HEALTHASSESSMENT

• provides data on the typicaland/or worst case emissionsunder specific operatingconditions, for use in airpathway analysis

• permits review of datacollected to see that they are ofadequate quality to assess thehealth impact on the community

• permits review of containment andmaterial flow provisions toassess the potential for releasesto air, water and soil pathways;also permits review of processmonitoring and safeguards against

describes how emergency releasesof contaminants are monitored andhow the community is safeguarded

specifies the routine checks ofequipment, waste storage areas,etc., and calibration ofmonitoring equipment to minimizeopportunity for process upset orunplanned hazardous materialreleases; useful in assessing thepotential for releases.

Names of the documents described here may vary.

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TABLE 3. EPA HAZARDOUS WASTE INCINERATION DOCUMENTS

Hazardous Waste Incineration Guidance Series:

Volume I: Guidance Manual for Hazardous Waste IncineratorPermits, July 1983.

Volume II: Guidance on Setting Permit Conditions andReporting Trial Burn Results, January 1989.

Volume III: Hazardous Waste Incineration Measurement GuidanceManual, June 1989.

Volume IV: Guidance on Metals and Hydrogen Chloride Controlsfor Hazardous Waste Incinerators, August 1989.

Volume V: Guidance on PIC Controls for Hazardous WasteIncinerators, April 1989.

Volume VI: Proposed Methods for Measurement of CO, 0:, THC,HCL, and Metals at Hazardous Waste Incinerators.

Other Useful EPA Resource Documents:

Quality Assurance/Quality Control (QA/QC)Procedures for Hazardous Waste Incineration.

Engineering Handbook for Hazardous WasteIncineration. September 1981.

Trial Burn Observation Guide. 1988.

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:NCESiethodology for assessing health risks associated with.ndirect exposure to combustor emissions. Washington, DC::PA, Office of Health and Environmental Assessment, 1990;:PA publication no. EPA/600/6-90/003.

Experience in incineration applicable to Superfund siteremediation. Cincinnati, Ohio: EPA, Risk ReductionEngineering Laboratory, 1988; EPA publication no. EPA/625/9-38/008.

)p_ It ET. Incineration of hazardous waste: a criticalreview. Journal of the Air Pollution Control Association_987;37(5) :558-586.

Guidance on PIC controls for hazardous waste incinerators:/olume V of the hazardous waste incineration guidanceseries. Washington, DC: EPA, Office of Solid Waste, 1989.

Guidance on metals and hydrogen chloride controls forHazardous waste incinerators: volume IV of the hazardouswaste incineration guidance series. Washington, DC: EPA,Office of Solid Waste, 1989.

Bowser LR, Liberati MR. Upfront delisting of incineratorash. In Proceedings of the 1989 Incineration Conference.Knnxville: 1989:8.2.1-8.2.6.

Carroll GJ, Oberacker DA. Characteristics of pilot- andfull-scale hazardous waste incinerator ash. In Proceedingsof the 1989 Incineration Conference. Knoxville: 1989:8.3.1-8.3.6.

Cheremisinoff P. Waste incineration pocket handbook.Northbrook IL: Pudvan Publishing Co., 1987:203.

Brunner CR, Incineration systems: selection and design.New York: Van Nostrand Reinhold Company, 1984:315-356.

Boomer BA, Trenholm AR. Common deficiencies in RCRA Part Bincinerator applications. Journal of the Air PollutionControl Association 1987;37(3):275-277.

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