Carbon Filtration for Reducing Emissions from Chemical Agent Incineration (1999) / Chapter Skim
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2 Trace Gaseous Emissions from Agent Incineration
2 Trace Gaseous Emissions from Agent Incineration
Pages 11-19
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From page 11... ...
Because ground-level atmospheric concentrations are related to stack concentrations through site-specific dispersion modeling, the BIF Rule effectively created emissions standards for all regulated trace organic and inorganic emissions. However, they establish a common ambient impact for specified emissions constituents rather than a constant emitted concentration standard for each source, which results in different localized ground-level concentrations.3 This has led to considerable confusion and charges that facilities regulated under the BIF Rule may not be equipped with the best available control technologies, thus exposing some areas to more pollution than others.
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From page 12... ...
. Total hydrocarbon and carbon monoxide limitations were proposed to act as surrogates for the other trace organics listed as hazardous air pollutants in Clean Air Act Section 112.
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From page 13... ...
emissions at JACADS and the TOCDF have also been analyzed for the following substances: · other halogen-containing (C1 and F) gaseous species · 22 elements, including all 11 elemental hazardous air pollutants covered in the Clean Air Act 204 trace organics, including the three agents being destroyed, 54 organic compounds classified as hazardous air pollutants by the Clean Air Act, and 147 other organic chemicals light and total nonvolatile hydrocarbons (i.e., hydrocarbons with boiling points lower than 100°C (212°F)
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From page 14... ...
The concentrations of emittants in the stack gas listed in Appendix B of this report for JACADS and TOCDF incinerators are among the lowest reported for all hazardous waste incinerators in the database of hazardous waste combustion emissions maintained by the EPA's Office of Solid Waste and Emergency Response (EPA, 19976~. The EPA's graphical summaries consistently show that TOCDF results either set the lower bound or are among the lowest in emissions of dioxins, mercury, semivolatile metals (cadmium and lead)
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From page 15... ...
For example, when the separate components of a volatile organic compound sampling train are analyzed, seven pairs of sorbent tubes and two condensate samples 16 individual samples all produce results. For typical laboratory detection limits (10 ng for each of the 14 sorbent tubes and 80 ng for each condensate trap)
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From page 16... ...
These estimates can be derived from the existing emissions test data, including the observed below detection limit concentrations from JACADS and the TOCDF. EMISSION RATES The JACADS and TOCDF incineration systems have been extensively tested, and the results have con sistently shown that emissions of materials regulated under Sections 111 (as criteria pollutants)
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From page 17... ...
For chemical agents (which have never been detected in any emissions test at a baseline system 7EPA Region IT} has published similar guidelines for the treatment of nondetects in stack tests for risk assessments used to establish permit limits.
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From page 18... ...
SUMMARY Trial burns have been performed at JACADS and the TOCDF to test the incinerators at each site, as well as the combustion of the various agents~although not all agents were tested with all incinerators. The reported emission concentrations are among the lowest for all hazardous waste incinerators in the EPA's Hazardous Waste Combustor Emissions Database.
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From page 19... ...
Yet the concentration used in the HRA analyses for Tooele, Anniston, and Umatilla, based on the JACADS test data, was 8,700 ng/dsm3. This can be compared to the average value derived from the trial burn detection limit of 115 ng/dsm3.
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