DSHW-2024-007861

Tooele Chemical Agent Disposal Facil$mruD DELIVERED(rocDF)
,DEC f 32010
UTAH DIVISION OF
$0un & HAzARDous WASTE
Response to
DSHW COMMENTS CONCERNING MODIFICATION REQUEST
TOCDF-AI0-03-1092
Titted.,Install and operate Area 10 Liquid Incinerator'
DSHW Tracking Number: 2010.00067
lf REPLY TO
ATTENTION OF
DEPARTMENT OF THE ARMY
US ARMY CHEMICALS MATER}AL AGENCY
TOOELE CHEMICAL AGENT D]SPOSAL FACILITY
11620 STARK ROAD
STOCKTON, UT 84071
DEC 1 3 20t0
F{Aruffi [}ffiLNVffiFqEM
ffiHC $ S ?trItr
UTAH DIVI.$ION OF
SOLID & HAZART}OUS WASTE
Jo lo. 07wfr \
Tooele Chemical Agent Disposal Facility PM0902-10
Mr. Scott Anderson
Director, Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
P.O. Box 144880
195 North 1950 West
Salt Lake City, Utah 84114-4880
SUBJECT: Response to Division of Solid andHazardous Waste (DSHW) Comments
Conceming Tooele Chemical Agent Disposal Facility (TOCDF) Class 3 Permit Modification
Request Titled "Install and Operate Area 10 Liquid Incinerator", TOCDF-AI0-03-1092 DSHW
Tracking Number: 2010.00067, EPA ID: UT5210090002
Dear Mr. Anderson:
Please find enclosed the response to comments received from DSHW concerning Permit
Modification Request TOCDF-AI0-03-1092, which is titled "Install and Operate Area 10 Liquid
Incinerator". Also enclosed is a compact disk containing electronic files of the affected TOCDF
Resource Conservation Recovery Act (RCRA) Permit change pages incorporating DSHW
comments, where applicable, revised ATLIC performance test plans, revised drawings, and
enclosures which provide supporting information. A hard copy of the files included on the
compact disk is also provided.
Note the following:
o The ATLIC exhaust stack Near Real Time (NRT) agent monitor Automatic Waste
Feed Cut-Off (AWFCO) limit is revised from 0.5 and 0.4 Source Emission Limit
(SEL) for Agent GA and Lewisite, respectively to 0.2 SEL for each agent. The SEL
value for Lewisite remains at 0.03 milligrams per cubic meter (0.03 mg/m3).
o The ATLIC Surrogate Trial Burn (STB) Plan is revised to include the spiking of
the Spent Decon Solutions (SDS) with an organic compound (monochlorobenzene),
and add the collection of exhaust gas samples for semi-volatile organic compounds.
o Module IV and Attachment 2 are revised to increase the agent concentration limit
for SDS to be processed in the Secondary Combustion Chamber of the ATLIC from '
20 and 200 parts per billion for agent GA and Lewisite, respectively to 500 parts per
million (ppm) for each agent. The 500 ppm agent limit for spent decon feed to the
ATLIC Secondary Combustion Chamber is conservative and is proposed based on the
intended organic spiking rate to the Secondary Combustion Chamber (SCC) during
the ATLIC STB. TOCDF will spike monochlorobenzene to the ATLIC SCC during
r"'"
JJ
Printed "^ @
Recycred Paper
a
-2-
the STB at a rate that will result in a Spent Decon organic content of approximately
8,000 ppm (0.8 weight percent). The selected organic spike is more difficult to
incinerate than Agent GA or Lewisite.
o The SDS feed rate specified in the test plans is increased to account for the need
to spike the SDS with Phosphoric Acid to replicate during the STB the particulate
loading that will be experienced during the process of Agent GA.
o The ATLIC Agent Monitoring Plan is revised to use a Depot Area Air Monitoring
System as the confirmation method for Lewisite NRT monitor alarms rather than
second NRT monitor that is configured with a different analytical column.
.
o The ATLIC AWFCO system test frequency is revised from once every 30 days
and proposed to as once every 14 days when the ATLIC is feeding hazardous waste
for a period longer than 14 days. The basis for this proposal is provided in the
response to DSHW comment # 4.
o Module VI is revised to require TOCDF to conduct a Lewisite Mini-Burn which
will allow for the continued processing of Lewisite upon completion of the Lewisite
CPT. Data from this test will provide assurance that the ATLIC post-CPT Lewisite
processing complies with the TOCDF RCRA hazardous waste incinerator
performance standards
TOCDF intends to submit a revised Laboratory Quality Control Plan (LQCP) and revised
Laboratory Operating Procedures applicable to Agent GA and Lewisite analyses and monitoring
under separate cover. TOCDF is aware of the desire of the DSHW to include the revised LQCP
in the documents that will be evaluated during the second public comment period. A revised
LQCP is being prepared and will be submitted to the DSHW shortly after January l,20ll.
TOCDF respectfully requests a meeting to begin discussing any issues DSHW may have
with the enclosed comment responses on or before December 22,2010, so that we may begin to
work on those issues that appear to be the most concerning as soon as possible.
The points of coniact in this matter are Ms. Sheila R. Vance at [phone] or Mr. Trace
Salmon at [phone].
Sincerely,
G-k,try#
i&e
tCI
Gary ilV. McCloSkey
EG&S Defense Materi4ls,Inc.
*CERTIFICATION STATEMENT
Thaddeus A. Ryb a, lr.
TOCDF Site Project Manager
*C ERTIFICATION STATEMENT
Enclosure
* I cERTtFy uNDER pENALTy oF LAw ru,lt rgrs ootuMENT AND ALL ATTACHMENTS wERE pREPARED UNDER My DtREcrroN oR supERvIsIoN tN
ACCORDANCE WITII A SYSTEM DESIGNED TO ASSURE THAT QUALIFIED PERSONNEL PROPERLY GATHER AND EVALUATE THE INFORMATION SUBMITTED.
BASED ON MY INQUIRY OF THE PERSON OR PERSONS WHO MANAGE THE SYSTEM, OR THOSE PERSONS DIRDCTLY RESPONSIBLE FOR GATHERING THE
INFORJ|'IATION. THE INFORMATION SUBMITTED lS. TO THE BEST OF MY KNOWLEDGE AND BELIEF; TRUE, ACCURATE AND COMPLETE. I AM AWAR.E TttAT
TEENE ARE SIGNIFICANT PENALTIES FOR SUBMITTING FALSE INFORMATION, INCLUDING THE FOSSIBILITY OT FINE AND IMPRISONMENT FOR KNOWING
vlot-ATloNs.
HAND DELIVHHED
,0 l0 ,0 3il1
, DEC f'3 ACIl0
TOCDF Response to UTAH DlVlSloN 0F
DSHw ATLIC for GA and Lewisite Modification Cosrgl-H.qttzARDous wAsTE
Main Body of Permit Modification (General)
1. Please explain the management of spent nitric acid being shipped off-site for disposal
versus the rinse water treated in the incinerator.
Spent nitric acid is generated from rinsing out lewisite (L) Ton Container (TCs). After an
L TC has been drained of its agent fill, it is filled more than halfway with a three (3) molar
solution of nitric acid through the fill and drain valves. The lines are then detached from
the TC valves, and the TC is rotated for at least one hour. The acid is added to the TC to
both destroy any agent remaining in the TC and to dissolve the un-drainable solid heel that
was identified during the GA and L sampling effort.
After the TC is rotated for the required period of time (i.e., approximately one hour), the
drain line is attached to the TC and the spent nitric acid is transferred to NSF-Tank-8514
or LCS-Tank-8516 that are located in the Area 10 Liquid Incinerator (ATLIC) Igloo Toxic
Area.
A sample of the spent nitric acid is taken at the tank, which is screened for agent
concentration. If the L concentration in the spent nitric acid is greater than the Worker
Concentration Limit (WCL), an eight (8) molar solution of nitric acid is added to the tank
to destroy the agent. When the agent concentration in the spent acid is less than the WCL,
the spent acid is transferred to 90-day Pollution Abatement System (PAS)-Tank-8569,
which is located in the Environmental Enclosure, the same enclosure that houses the
ATLIC PAS. Note the tank's designation is assigned based on it physical location, it is not
associated with the ATLIC PAS.
The samples collected from PAS-Tank-8569 are analyzed for pH, total dissolved and total
suspended solids, and metals. The parameters of analysis are selected to support the
planned method of disposal of this waste stream, which is deep well injection.
Deep well injection is selected as the method of disposal because the spent nitric acid
waste stream will have high concentrations of both arsenic and mercury. The mercury
concentrations associated with this waste stream most likely will exceed the Land Disposal
Restriction (LDR) limits for high mercury (HMERC) wastes. There are no metal
concentration limits for wastes that are disposed of by deep well injection. The pH of this
waste stream is maintained intentionally low to minimize suspended solids.
2. Please explain the mechanism to pump liquids out of the glove boxes.
Liquids are added to and rernoved from TCs that are placed in the glove boxes through the
use of two multifunction 4-way and 5-way valves. A 4-way valve in each glove box, with
three lines coming into it and one line going out of it, is set to direct decontaminating
Page 1 of 107
solution (decon), process water, or nitrogen to the TC (the single line coming out of the 4-
way valve is attached to the higher of the two vertically-positioned TC f -inch valves).
A 5-way valve in each glove box, with one line coming into it and four lines going out of
it, is set to transfer GA to the ATLIC Primary Combustion Chamber (PCC), spent decon
to the Spent Decon Tank, lewisite to the Agent Holding Tank, or spent nitric acid to the
Spent Nitric Acid Holding Tanks. Liquids are transferred from the TCs in a line dedicated
to the specific liquid using a pump that is also dedicated to that type of liquid. See
drawing EG-22-D-8812.
3. Please provide narrative explaining the mechanism for injecting the carbon into the
exhaust gas stream.
The Pulverized Activated Carbon (PAC) system is a fully-automated system capable of
injecting carbon into the inlet of a baghouse. When the PAC system is in automatic
operation mode, carbon is injected into it, with the assistance of a blower, and.metered
constantly by adjusting the speed of a screw feeder, based on weight loss and the desired
injection weight. Carbon is hansferred from a bulk bag when the level in the screw feeder
hopper is below a low weight setpoint. A rotary valve feeds the screw feeder hopper.
Rotary valve operation stops when the screw feeder high weight setpoint is reached or
when the level probe is maintained for a set amount of time. The cycle continues until the
system is stopped.
A tapered bulk bag of PAC is placed (tapered end down) into a hopper using a hoist. The
tapered neck of the bag is positioned in the tapered bottom of the hopper. A bulk-bag
massager can be automatically pulsed to maintain the free flow of carbon from the bag. A
rotary valve directs this flow of carbon to a second smaller hopper that is used to measure
the feed rate of the carbon to the ATLIC PAS. Carbon in the second, smaller hopper is
metered into the process by adjusting the speed of a screw feeder. The screw feeder
transfers the carbon to a funnel. The verticallytapered exit of the funnel is joined to a
horizontally-oriented pipe through which air flows. The flowing air draws the carbon from
the funnel by venturi effect. The end of the pipe adjoins the ATLIC PAS. The PAC is' introduced into the PAS upstream of the Baghouse.
4.The AWFCO system associated with the ATLIC will need
every seven days.
to be manually tested
TOCDF initially proposed a 30-day test frequency for the ATLIC AWFCO System, which
is the longest frequency allowed by the regulations. Rather than this frequency TOCDF
request the DSHW to consider the following which is provided to justify a l4-day
AWFCO Systern testing frequency.
Groups of Operating Parameter Limits (OPLs) are specified for each component in a
Pollution Abatement System (PAS) train based on the equipment type. The ATLIC PAS
train includes multiple wet scrubbers, a venturi scrubber with a dedicated sump, a carbon
injection system, a baghouse, and a fixed bed carbon filter. The number of PAS train
components incorporated into the ATLIC PAS design res'ult in a larger AWFCO System
than that associated with any of the TOCDF incinerators.
Page 2 of 107
o
Because the limited amount of waste to be processed by the ATLIC and the resulting short
duration of ATLIC hazardous waste operations, the ATLIC AWFCO Systern will be tested
manually. The short operational period of the ATLIC does not justify the development of
automated AWFCO System testing software. Each test of the ATLIC AWFCO System is
therefore estimated to take about 8 hours. When including the time to organize and
coordinate the testing, each AWFCO test will take l2-hour, or one shift, during which
waste feed to the ATLIC will be suspended.
TOCDF is proposing an ATLIC AWFCO System test frequency of every 14 days, or
before hazardous waste feed is initiated for times when the ATLIC is idle (i.e., not
processing waste) for longer than 14 days.
The ATLIC will be idle for extended periods of time. The ATLIC is idled (i.e., no
hazardous waste processing) after completion of the Surrogate Trial Bum (STB) up until
the STB Preliminary Data is approved by the Executive Secretary. The GA Campaign is
expected to take 10 days.
The ATLIC is then idled from the end of the GA Campaign to the start of the shakedown
period associated with the Lewisite Comprehensive Performance Test (CPT), a period of
53 day per the current schedule. During this time the Lewisite Operation Readiness
Review (ORR) will be conducted.
The AWFCO system must be tested prior to the initiation of hazardous waste and after any
changes are made to the system. Considering the changes to the system needed to
accommodate "half feed rate" and AWFCO System operational status changes during time
when stack sampling is being conducted (i.e., during the performance testing when stack
sampling is being conducted), the proposed testing frequency would result in testing of the
system 6 times.
Considering the number of tests, the time required to conduct each test, and the estimaied
total ATLIC hazardous waste operating time (i.e., the time the ATLICis actually buming
hazardous waste, the proposed frequency of 14-day or prior to the beginning of hazardous
waste feed for idle period lasting longer than l4-days, the percentage of time required to
test the ATLIC AWFCO System would be similar to that for a "long term" hazardous
waste incineration system that was required to perform the testing every seven days ( 14
percent for the ATLIC as compared to once every seven day, or ll7 * 100: 14 percent).
Table 1 shows the estimated number of ATLIC hazardous waste operational hours. Table
2 shows the number of AWFCO test events based on the proposed frequency and
compares the percentage of time required to perform the testing for various tests
frequencies as compared to the total hours of ATLIC hazardous waste operations.
Page 3 of 107
Tahle 1. Tutal ATLIfl Hazariluns lYarte Feerl Opsratiun Tirne
ffA f,;unpaign
TC Seriel Nurrher Pounils ofAeent Prrocessiilg Ef,te ltrours ofPrucessing
GA TC D.2523 1325 1J0 lbs.ftu.9.5
GA TC D-3J248 1488 150 lb s./hr.11.0
GA TC D.29813 653 150 lb s.lhr.J.J
GA TC D.51365 636 150 lb s./tu.5.5
Each TC generate s 460 gallons
SDS (Approxitnate
3,83J lbs. of SDS
Each TC genere ates
345 gallons of SDS
( approximately 2,876lbs. of SD$
Each TC genere ates
345 gallons of SDS
( approximately 2,876lbs. of SD$
Totel hnur:s ofPncessing Agent l,s$,isite >1369
Totel ltrours ofPrueessilg SDS @ 450 Ih SDS/IIr ]639
TranrperEncy TC Prucocessing
Totel Hours ofPrucessng SDS @ 450 Ih SDS/Hr F | 63.9
Total llours Agent & SDS Prucessing ts 332.,2
Euiuelent Days ofprucessing @24llourslDey >14
Estiileteil llour oftlarardnus lUaste Operation tu I
Sr4port Surrrogate Trial Eurn enil Shakedrri'nl f fC
Perioil F
Total AlfrIC llnxerfuus lUastc Oueratins tlours ts I 4PB
Total llnurs ofPrucessing Asent GA ]
Totrl llnuns ofPmcessng SI]S @ 450 Ih SI]S/Hr >
TC Serial Nrunber
D-79705. & D-79711 150 th s./tn.
D-49?21. D-79697- & D-79701
150 lb s./tu.
150 lb s./tr.
150 lbs.flu.
Page 4 of 107
Table 2. Percentage of AWFCO System Testing Time Based on Total ATLIC Hazardous Waste Feed Operation Time
Event Estimated Date Purpose
S-Jul-11 AWFCO Test Test beforehazardous waste feed
Start Surrogate Shakedown 6-Jul-l I
Start Surrogate Trial Burn 13-Jul-11 AWFCOs Waived
for stack testingEnd Surrogate Trial Burn 18-Jul-l I
l2-Aug- l 1 AWFCO Test
Revise Waste Feed Rate to ll2 STB Demo'ed Rate, PCC
and SCC Low-Temp Limit and Exhaust Gas Max-Flow
Rate Limit to STB Demo'ed Rate and test AWFCOs to
ensure Jumper for STB is removed
Start GA Operations 13-Aue-l I
End GA Operations 23-Aue-11
l4-Oct-l I AWFCO Test
Revise Waste Feed Rate to LCPT Rate, Test all
AWFCOs nrior to resumins hazardous waste feed
Start Lewisite Shakedown l5-Oct-l I
27 -Oct-ll AWFCO Test Everv 14-dav AWFCO test
Start Lewisite CPT 28-Oct-11 AWFCOs Waived
for stack testing
End Lewisite CPT 3l -Oct-l I
l-Nov-l I AWFCO Test
Revise Waste Feed Rate to ll2 LCPT Mini-Burn
Demo'ed Rate, PCC and SCC Low-Temp Limit and
Exhaust Gas Max-Flow Rate Limit to STB Demo'ed
Rate and test AWFCO to ensure Jumper for LCPT is
removed
Start Post Test Lewisite Ooerations 2-Nov-I
End Lewisite Ooerations 3-Nov-I
4-Nov-I AWFCO Test Everv l4-dav AWFCO test
Start Transparency TC Processing 5-Nov-1
End Transparency TC Processing 9-Nov-I
ATLIC Hazardous Waste Operational Duratio 9-Nov-I
5-Jul-1
Days Spanning ATLIC Hazardous Waste
Operator t3i
No. AWFCO Tests @, everv 7-dav interval 20
No. AWFCO Tests @ everv 14-dav interval l0
No. AWFCO Tests @ l4-day interval or before
Haz. Waste Feed if idle longer than l4-days 6
Hours to perform AWFCO Tests @
everv 7-dav interval*23s 47"h
Percentage of AWFCO Testing
{ Time @ 498 Hqgrs ATLIC
Hazardous Waste Operations
Hours to perform AWFCO Tests @
every l4-dav interval*n7 240h
Hours to AWFCO Tests @ l4-day interval or
before Haz. Waste Feed il
idle loneer than l4-davs*
72 140
*AWFCO Testing will take approximately 8 hour l2-hr shift
There was no description of the secondary containment systems with calculations of
their capacities. The only mention made of this issue was that there was insufficient
capacity requiring installation of a "major spill collection tank" (see page 11 of the
Class 3 Modification request). It is unclear how this would fulfiIl the secondary
containment requirements as it is not one of those specified in 40 CFR S264.193(d).
It appears that it would serve the purpose of removiiig the leaked or spitted material
collected in a secondary containment system as described in 40 CFR $264.196. The
purpose of the secondary containment system is to hold the spilled or leaked material
until it can be collected and managed. Tank 8534 would not serve this purpose, as it
would not be collecting this material until after the leak was detected, hoses
connected, and the material was pumped to the tank. It is also confusing since
Page 5 of 107
6.
516.4.9.4 of Attachment 16 makes it appear that there is sufficient secondary
containment in the bermed area.
The ATLIC TOX secondary containment calculations demonstrating that the design is in
compliance with the applicable regulatory requirements can be found in Enclosure A.
Drawings EC,-22-G-8216,F,C'-22-G-8217, EG-22-G-8227, aind EG-22-C,-8228 show
various sumps. Please show on a floor plan where these sumps are located. Also,
please describe which secondary containment system each are associated.
A diagram showing the locations of the various sumps located in the ATLIC facility, and a
table listing the area that each sump supports, can be found in Enclosure A.
Table I Page 4 - The acetic acid was not discussed in the surrogate trial burn plan,
(Section 1.3.1) but NaOH was for GA. Please explain
The reference to acetic acid in Table 1 is an elror, a remnant from an early draft version of
the permit modification request when TOCDF was considering an acetic acid rinse for the
lewisite TCs. Bench scale testing using acetic acid to remove lewisite from metal coupons
showed that it did not dissolve the lewisite, but instead created slime that coated the metal
coupon. Acetic acid will neither be used in the processing of the lewisite TCs nor fed to
the ATLIC,.
Page 5 & 6 - Sampling in accordance with an approved sampling plan (2.2.1.3.3) must
be performed for both liquid and sludge materials. Please provide a sampling plan
for further sampling/characterization verification.
The TOCDF requests that DSHW reconsider the need for additional sampling and analysis
of the agent in the GA and lewisite TCs based on the following paragraphs from
Attachment 2 of the TOCDF RCRA Permit, which specify how the analysis of chemical
agent occurred during past TOCDF Agent Campaigns.
7.
8.
2.2.r.3.2.
2.2. 1 .3.3.
The Permittee shall analyze the chemical agent prior to each agent
campaign from bulk containers. Agent samples shall be collected from a
representative number of bulk containers agreed upon with the DSHW.
The containers shall be sampled and analyzed following an approved
sampling and analysis plan.
At the beginning of each munition or bulk container campaign, agent
samples shall be collected using a Sampling scheme that is approved by
the Executive Secret ary. The samples shall be analyzed as specified in
Table 2-0.
These conditions were added to the TOCDF RCRA Permit partway through the first
TOCDF agent campaign, which was for Agent GB; during the early stages of that
campaign, it became evident that there was insufficient existing analytical information
about the agents to establish incinerator metal feed rates through a single demonstration,
Page 6 of 107
which ideally occurs during the Agent Trial Bum (ATB). Two additional performance
tests were required during the Agent GB Campaign to increase incinerator metal feed rates
as metal analytical data for Agent GB became available. The above quoted paragraphs
were added to Attachment 2 of the TOCDF RCRA Permit to prevent having to perform
multiple metal feed rate demonstrations throughout an agent campaign.
Paragraph 2.2.1.3.2 discusses how "a representative number of bulk containers agreed
upon by DSHW" will be sampled. This is an important discussion point for an agent
stockpile comprised of thousands of TCs. For the GA and lewisite stockpiles, TOCDF
sampled every TC since there are only four GA and ten lewisite TCs.
Paragraph 2.2.1.3.3 specifies the parameters of analysis that, for the VX and Mustard
Campaigns, were Health Risk Assessment (HRA) metals and organic content, which
included agent purity. The metals analysis was performed on both liquid and solid phases
of the TCs if solids were present. For the GA TCs, a liquid sample was collected from
each TC and analyzed for organic content with the constituent of concern being the
monochlorobenzene; this compound is more difficult to incinerate than Agent GA. Each
sample was also analyzed for HRA metals using the same methods approved by DSHW
for agent metals analyses conducted at TOCDF.
Liquid and solid samples were collected from each lewisite TC. The liquid samples were
analyzed for organic content and the Ll concentration was quantified. TheLZ and L3
concentrations were estimated because calibration standards for these compounds are
unavailable. Both liquid and solid samples were analyzed for HRA metals.
The sampling/analysis efforts for the GA and L TCs resulted in generation of the same
data that would have been collected from an Executive-Secretary-approved
sampling/analysis plan. Al1TCs were sampled, samples of both solid and liquid fractions
were collected, and the parameters of analysis for the GA and L TCs were the same as
those in past approved plans (i.e., organics to include agent purity and HRA metals).
The GA and L TC sampling/analysis efforts provided TOCDF sufficient data to design and
develop the Surrogate Trial Burn (STB) and Lewisite Comprehensive Performance Test
(CPT) Plans to ensure that worst case demonstrations are made during the testing and to
avoid the past problems that were experienced during the TOCDF Agent GB Campaign.
Therefore, the existing GA and L TC analytical data fulfill the intent of the requirement
found in the above-referenced paragraphs from Attachment 2 of the TOCDF RCRA
Permit,
Additionally, the permit modification request made clear the proposal not to perform any
additional organic analyses of the GA and lewisite agent, or any additional metal analyses
of the Agent GA. Therefore, the public was provided with an opportunity to comment on
this proposal during the permitting process.
Note TOCDF is evaluating the possibility of collecting a GA sample for metals analysis. If
collected this sample(s) would be used to verify the results.presented in the GA and L Ton
Page 7 of 107
Container Sample Analysis Report which was submitted as Attachment 3 to the initial
ATLIC permit modifi cation requests.
9. Page 6 - Please provide justification why GA agent should be directly fed to the LIC
instead of a tank (see comment above concerning additional samplinglanalytical).
The Agent GA was proposed to be fed from the TCs directly to the LIC to minimize the
amount of equipment that would require decontamination during the agent campaign
change over from GA to lewisite. The transfer of GA to Agent Holding Tank LCS-Tank-
851l, and from this tank to the ATLIC Primary Combustion Chamber (PCC), would incur
having to decontaminate the agent transfer line between the glove box and the holding
tank, the holding tank, and the transfer line from the holding tank to the ATLIC PCC
before the Lewisite Campaign could begin. The spent decon solutions that were generated
from this decontamination process would also have to be heated in the ATLIC Secondary
Combustion Chamber (SCC) before the Lewisite Campaign could begin.
Furthermore, TOCDF plans to transfer the lewisite from the TC to the agent holding tank
before feeding it to the ATLIC to allow blending the lewisite from different TCs to create
an agent waste feed that has more consistent metal concentrations (i.e., the contents of the
Lewisite TCs with high metals concentrations will be mixed with the contents of TCs with
lower metals concentrations to create a feed with average metals concentrations). The
individual metals analytical results for the GA TCs show a much narrower range among
TCs; therefore, mixing the GA to create a more consistent waste feed in regards to metal
content is not required.
10. Page 6 - Please explain the mechanism for mixing the agent tank.
A recirculation line is incorporated into the design of the permitted lewisite, spent decon,
and spent nitric acid hazardous waste storage and treatment tanks. The drawings that were
submitted with the permit modification request show these lines. The liquid wastes are
drawn from the bottom of the tank and reenter the tank at approximately the vertical
midpoint. An eductor is located inside the tank on the end of the line. The eductor is
submerged in the liquid, and the flow of liquid through the eductor causes the surrounding
liquid to be pulled into and through the eductor, which multiplies the mixing efficiency.
11. Page 7 - All transparency tons will need to be treated the same and be processed
through an approved decontamination procedure of nitric acid rinses (3x) followed
by water rinse and it must be verified that all LlrLz and L3 are less than the waste
control limit. Spent decon must be analyzed for agent, metals, and organic content.
The agent content must be less than 20 ppb for GA and 200 ppb for Lewisite and the
demonstrated organic content. Metals must have been demonstrated in the SCC
prior to feeding to that chamber.
The TOCDF concurs with the request to process all Transparency TCs in a similar manner.
The original version of this permit modification request proposed to acid rinse only those
Transparency TCs for which there were head space monitoring results showing the
presence of lewisite. All other Transparency TCs would only undergo a water rinse.
o
Page 8 of 107
The TOCDF has revised the proposed Module VII Permit Conditions associated with
Transparency TC treatment to require each Transparency TC to undergo an acid rinse
followed by three water rinses. A single acid rinse is determined to be sufEcient for
Transparency TCs. The interior of each TC was inspected with a borescope. No solid
heels were found in any of the TCs. Additionally, afterbeing rinsed out, each TC will be
cut in half and monitored for agent before being transferred off-site as F999 hazardous
waste.
Concerning the need to analyze lewisite and lewisite-derived wastes for Ll, L2, and
. Analytical calibration standards are not available forL2 and L3. The presence of these
isomers of lewisite (Ll) can be determined, but they cannot be quantified because of
the lack of applicable calibration standards.
o The presence of L2 and L3 will be noted on the analytical reporting sheet and will be
reported in a similar manner as are the Tentatively Identified Compounds (TICs).
o All agent-derived wastes are required to be managed as F999 listed hazardous wastes.
The application of this waste code ensures that these wastes will be managed as listed
hazardous wastes.
Conceming the need to spike the ATLIC Secondary Combustion Chamber (SCC) waste
feed during the Surrogate Trial Bum (STB) with organics and metals:
o The TOCDF concurs with the need to spike STB SCC waste feed with an organic
compound. The STB Plan has been revised accordingly.
o The TOCDF does not concur with the need to spike the SCC waste feed with metals
since the metals spiked into the Primary Combustion Chamber (PCC) will travel
through the SCC. The SCC does not remove metals from the exhaust gas. The metal
feed rates demonshated during the STB, as derived from the metal spikes added to the
PCC, will be regulated as the total metal fed to the PCC and SCC during ATLIC
operations.
Note that spent decon generated from the actual rinsing of lewisite TCs will be fed during
the Lewisite Comprehensive Performance Test (CPT).
12.Page 8 - The temperature of scrubber solution will need to be monitored as a waste
feed cutoff (< 185" F). Waste collected in sumps must be analyzed for waste
characterization. Each PAS system needs temperature cutoffs. Where is the sump
sludge anticipated to be managed/treated?
As required by the current TOCDF RCRA Permit, each incinerators Automatic Waste
Feed Cutoff (AWFCO) system includes an AWFCO for High Quench Towdr Exhaust Gas
Temperature. This AWFCO was specified in the RCRA Permit'before the promulgation
of the Hazardous Waste Combustor Maximum Achievable Control Technology (HWC
MACT) regulations. These regulations specify the Operating Parameters (OPs) that are
Page 9 of 107
associated with the control of each emission standard, and the sample emission standards
are listed as Performance Standards in the RCRA Permit.
The HWC MACT regulations do not require that a High Quench Tower Exhaust Gas
Temperature Operating Parameter Limit be established to ensure compliance with the
ernission standards because this OP has no influence on the rernoval or control of
ernissions from incinerators, and is therefore not an indicator of compliant incinerator
operations in regards to the emission (i.e., performance) standards.
A High Quench Tower Exhaust Gas temperature alarm is included in the ATLIC control
system as a "Stop Feed" (i.e., an unregulated OP); it is included to protect equipment
rather than to confrol emissions. The ATLIC control system will stop: feed to the PCC
and SCC, the combustion air blowers, and the flow of fuel gas when the Quench Tower
Exhaust Gas temperature exceeds 250 "F to ensure equipment downstream of the quench
tower is not damaged.
This OP was not included as an AWFCO because the temperature of the quench tower
exhaust is not specified in the HWC MACT regulation as a surrogate measure of
compliance with any of the emission standards. Rather, it is used as a Stop Feed for best
managernent practice to protect equipment.
Therefore, TOCDF does not concur with including this OP as an AWFCO.
Concerning accumulated liquids in sumps; TOCDF concurs with the need to characteize
liquids accumulating in sumps. Liquids that accumulate in sumps that are connected to
SDS-Tank-8523 will be analyzed prior to being fed to the Secondary Combustion
Chamber (SCC) of eh ATLIC. The liquids that accumulate in the sumps that are not
directly connected to the SDS-Tank will be characteized prior to treatment. Sumps not
connected to the SDS-Tank are managed as 90-day accumulation tanks and because they
are not a permitted Hazardous Waste Management Unit (HWMU), and are not ancillary
equipment to a HWMU, these sumps are managed under the "Generator Rules". These
rules do not require a written waste analysis plan for wastes managed in tanks that are not
permitted HWMUs.
Concerning sump sludge management; TOCDF doe not expect to manage sump sludge
due to the shortness of the ATLIC operations.
L3. Page 8 describes the exhaust gas from the secondary combustion chamber entering
the quench tower at the bottom and flowing counter-current to the cooling water.
Drawing EG-22-D-821L, sheet I of 4, shows it entering the top. It also doesn't show it
exiting the quench tower and entering the first tower of the packed bed scrubber.
Please explain.
A review of the drawing shows the description on page 8 of the permit modification
request to be incorrect. The flow of exhaust gas is from the top to bottom of the Quench
Tower. Water is sprayed into the exhaust gas as it travels down the length of the tower.
Page 10 of 107
A review of the drawing also shows baffles in the Recirculation Tank (Tank 8912) which
direct the flow of exhaust gas exiting the quench tower to the first packed bed scrubber and
from the first packed bed scrubber to the second, and so forth. The baffles cause exhaust
gases flowing through the PAS to contact the packed bed scrubbers in series, and prevent
the parallel flow of exhaust gas through the three packed bed scrubbers.
14. Page 11 indicates that tanks 8514 and 85L6 are connected so that, ifnecessary, the
content of one tank can be transferred to the other. Drawings EG-22-D-8215 and
EC,-22-D-8216 show a connection to transfer from tank 8516 to 8514 but no piping is
indicated to transfer from tank 8514 to tank 8516. Please explain.
Revision (Rev) 5 of EG-22-D-8216 shows the capability to transfer wastes from tank 8516
to tank 8514, and from tank 8514 to tank 8516. A revised drawing package, to include this
drawing, is provided with submission.
15. Please provide utilities drawing EG-22-D-8221referenced on the drawings for
inclusion in the modification packet.
The referenced drawing is provided in this submittal
16. Please provide a description of all of the interlock functions in either a drawing,
table, matrix, or logic diagram. (It may be the matrix (ATLIC A&I MATRIX.XLS"
referenced in Note 4 of drawingBC,-22-D-8210.)
The ATLIC Alarm and Interlock (A&I) Matrix is provided as Enclosure B
17. Please explain how each of the follow issues will be handled for the carbon injection
system:
a. Ilandling the micronized carbon introduces problems associated with
housekeeping and poteltial respiratory problems in the event of a failure in a
filter element. This problem would be compounded because the carbon dust
would be contaminated with substances of potential concern (SOPCs). In
addition, finely divided activated carbon dust presents a fire and explosion
hazardl.
The ATLIC PAS Baghouse is equipped with 36 individual GORE-TEX filter
elements configured in six rows with each row containing six elements. A loss of
one of the filter elements inside the Baghouse will not result in contaminated
activated carbon escaping the PAS. The PAS is a sealed system that is operated
under negative pressure by the Induced Draft fan. However, it will result in a
higher exhaust gas particulate loading downstream of the Baghouse. Prior to the
exhaust gas release to the ambient air, these particulates will be removed by the
Fixed Bed Carbon Filter (FBCF), which is downstream from the Baghouse. The
FBCF design includes a High-Efficiency Particulate Air (HEPA) Filter at the back
end, which will capture any Pulverized Activated Carbon (PAC) in the exhaust gas
stream resulting from a loss of a Baghouse filter elernent. The pressure
measurement across the FBCF will increase as the HEPA filter becomes loaded,
Page l1 of107
which will eventually cause a Stop Feed with an associated alarm indicating that
there is a process problem.
Fires and explosions are prevented by the carbon being contained in the Bag during
handling, and the high exhaust gas ternperature limit imposed on exhaust gases
entering the baghouse by the MACT regulations.
The process requires that a layer of uniform thickness be built up on the bag
filter to provide uniform treatment for all of the gas. If the thickness varies,
gas will pass preferentially through the thinner sections. It was not clear how
uniform thickness would be achieved.
The filter elements used in the ATLIC PAS Baghouse are made of GOR-TEX and
do not require a filter cake to be deposited on their outer surfaces to efficiently
remove particulate to meet the particulate emission standard. Any filter cake
deposited on the bag would only minimally add to their particulate removal
efficiency.
More carbon consumption is required in the dry sorbent-injection design than
the fixed-bed design. Thin layers on bag filters would have to be replaced
frequently, during which breakthroughs would have to be avoided while
acceptable flow and pressure were maintained. How will this be
accomplished?
The ATLIC Baghouse includes six rows of six filter elements each. A reverse jet
of air is used to blow the filter cake off the elements to maintain a differential
pressure across the Baghouse. A single row of elements is cleaned at a time, and
the cleaning of individual rows of elements is controlled by a timer. At steady-
state operations, there would always be 30 elements with a layer of filter cake on
their outer surface and six elements without. However, as previously stated,
TOCDF has selected the most efficient filter elements available for this application.
"For dusts having a spherical shape, the reverse air jet also cleans out most of the
residual dust cake in the filter media. After each pulse there will be very large
penetrations of dust through the media until the cake reforms. The most effective
solution to this problem is to provide GORE-TEX@ which is a laminated media.
This laminated mernbrane provides what can be termed a very efficient artificial
cake that is not affected by the cleaning jet."r
18. The rinse water contaminants must be demonstrated during the surrogate trial burn
for feed of organics into the SCC.
See response to DSHW comment #11.
19. Page 13 - Table 4lists the waste streams treated and generated by the ATLIC
operations. There is no mention of the baghouse dust or the PAS blowdown. Please
update.
I Principles of Pulse Jet Fabric Filter and Cartridge Filter Performance, Dustex Corporation
Page 12 of 107
b.
c.
TOCDF concurs that these waste steams were not included in the Table 4 of the permit
modification request. However the table in the permit modification request is not included
for review during the Second Public Comment Period.
The PAS blow-down (i.e., spent scrubber brines) and baghouse dust (i.e., Spent Pulverized
Activated Carbon [PAC]) are included in Sections2.2.2.29 and2.2.2.31 of Attachment2,
respectively.
20. No written assessment, reviewed and certified by a qualified PE, attesting that the
tank systems have sufficient structural integrity and are acceptable for storing or
treating the waste as outlined in 40 CFR 5264.192 could be located. Please provide.
The above referenced certification was provided to the DSHW with the submission of the
Temporary Authorization Request to begin early construction of the ATLIC. A copy of
the Professional Engineer (PE) certification is provided as Enclosure C.
2l.Page L3 - Please add narrative concerning additional waste codes such as benzene,
dioxins, UTS, etc. that may apply.
A narrative discussing Land Disposal Restriction Universal Treatment Standards (UTS)
was not included for ATLIC waste streams because unlike the TOCDF Metal Parts
Furnace (MPF) which is a batch operation incinerator, the ATLIC is a Liquid Incinerator
(LIC). Wastes are metered into a LIC which results in a much more narow (i.e., steady-
state) operational envelope as compared to a batch incinerator. LIC combustion chambers
do not experience the momentary low oxygen concentration that are typical of batch feed
incinerators. Further the waste feed to a LIC is atomized as it enters the combustion
chamber which allows the oxygen present in the chamber to fully contact the waste
droplets.
TOCDF included UTS for MPF TC ash because this waste stream was generated inside a
punched TC. The low oxygen environment created by the configuration of the waste feed
to the MPF during Mustard TC processing (i.e., a large solid heel which was treated inside
a "punched" TC) created the potential for compounds for which UTS were specified to be
present in the ash generated inside the TCs. TOCDF therefore specified an analysis for
these compounds in the TOCDF RCRA Permit Waste Analysis Plan.
22.Page 13 - The ATLIC carbon will have decon solution added to it. What is the decon
solution and when is it added (type of container, etc.)? Please be specific.
TOCDF revised Attachment 2 to specify Spent ATLIC HVAC activated carbon to be
treated in the Autoclave. See Attachment2, Section 2.2.2.36. Note TOCDF is however
investigating other methods of Spent HVAC carbon treatment.
23. Table 4 - There were no listings of PAS brines and disposal method/codes in the
table. Please update.
Page 13 of 107
See response to DSHW comment # 19.
24.Page 14 - Spent decon from closure is listed, yet a closure plan was not submitted for
this unit. Please revise.
This permit modification request proposed to add a permit condition in Module II that
would require TOCDF to submit an ATLIC Closure Plan by a specific date. The proposed
Permit Condition reads:
II.K.2. The Permittee shall submit a permit modification requeit that updates Attachment
10 (Closure Plan) for ATLIC associated hazardous waste manasement units no
later than the frrst third quarter ofcalendar year 201 l.
The TOCDF has also submitted a Class 3 Permit Modification Request to revise the
RCRA Permit Closure Plan (see modification request TOCDF-ATT10-03-1111). The
ATLIC closure should be addressed in Closure Plan after it is modified through Permit
Modification Request TOCDF-ATTI0-03-111 1. Changes to the TOCDF RCRA Permit
Closure Plan caused by this modification request will not be incorporated into the TOCDF
'--- permit until some time in second quarter 2011.
Zl.Page 18 - Please explain why DAAMS tubes aren't being used for the stack. Some
narrative indicates they will be used.
The revised Agent Monitoring Plan included rvith this submittal specifies the use of
DAAMS as the confirmation method for lewisite Near-Real Time (NRT) alarms.
26.Page20 & 2l - The Surrogate Trial Burn Plan should address the high metals
loading in the Lewisite and not just address the GA components.
The TOCDF discussed this issue with DSHW prior to the development of the ATLIC
Class 3 Permit Modification Request. It was determined that two separate trial burns
would be submitted. A Surrogate Trial Burn (STB) would be conducted to demonstrate
successful treatment of GA and lewisite organic constituents by dernonstrating the ability
of the ATLIC to burn surrogate organic compounds that are more difficult to incinerate
than either agent. Further, GA contains monochlorobenzene, which is one of the
surrogates selected for use during the STB.
The TOCDF decided to conduct a Lewisite Comprehensive Performance Test (CPT)
because of the inability to spike the surrogate with a-suffrcient amount of arsenic to allow
for the desired feed rate of lewisite.' The solubility of arsenic compounds in the required
surrogates (monochlorobenzene being one of them) is limited. The selected arsenic-
'containing compound that will be used during the STB is soluble in the surrogate to a
concentration that results in an overall arsenic feed concentration of 100 parts per million
(ppm). To feed more arsenic to the ATLIC PCC would require either that the arsenic be
spiked as an arsenic oxide, which is a solid, or that the arsenic-containing compound be
fed as an additional separate feed to the PCC at the same time the surrogate is fed (as
accomplished during the TOCDF Liquid Incinerator (LIC) Mustard Agent Trial Burn).
Page 14 of 107
If arsenic oxides were used as a metal spike, they would need to be suspended in the liquid
surrogate. To support lewisite processing, the oxides would need to be suspended in the
liquid surrogate such that the arsenic content of the blend is 35 weight percent (the same
arsenic weight percent as lewisite). At this high a weight percent, the suspended arsenic
oxides would have a high probability of falling out of solution in the feed line and feed
tank before they reached the ATLIC PCC feednozzle tip. This would result in a
questionable and unverifiable arsenic feed rate demonstration.
To feed a separate arsenic-containing solution to the ATLIC at the same time as the
surrogate would require TOCDF to cut back on the surrogate feed rate since there is a limit
as to how much heat content can be fed to the PCC. The spiking solution that was used to
deliver the arsenic spike to the LIC PCC during the Mustard ATB was primarily ethylene
glycol. The energy fed to the ATLIC PCC as spiking solution would limit the amount of
surrogate that could be fed since all incinerators have heat input limits.
Therefore, it was determined that the best waste feed to demonstrate the effectiveness of
the ATLIC to control high and low-volatile metals emissions was lewisite.
27.Page 20 - All transparency tons must go through an approved decontamination
process.
See response to DSHW comment #11.
28. Page 23 - The 507o feed rate after the trial burn may not be feasible for both agent or
spent decon. If successful, may need to start at 20o/o feed rate.
The proposed series of Module VI permit conditions associated with the ATLIC post-trial-
burn waste feed rate are more restrictive then those proposed in the past for TOCDF
incinerators. The sequence of conditions also ensures compliance with the TOCDF RCRA
Permit Performance Standards as required by the 40 CFR 270.62(c), which reads:
For the purposes of allowing operation of a new hazardous waste incinerator
following completion of the trial burn and prior to final modification of the permit
conditions to reflect the trial burn results, the Director may establish permit
conditions, including but not limited to allowable waste feeds and operating
conditions sufficient to meet the requirernents of 9264.345 of this chapter, in the
permit to a new hazardous waste incinerator. These permit conditions will be
effective for the minimum time required to complete sample analysis, data
computation and submission of the trial bum results by the applicant, and
modification of the facility permit by the Director.
And 40 CFR 63.1206 (bXsXi)(C)( 2 ), which reads:
You may petition the Administrator to obtain written approval to burn hazardous
waste in the interim prior to submitting a Notification of Compliance for purposes
other than testing.or pretesting. You must specify operating requirements,
including limits on operating parameters that you determine will ensure compliance
with the emission standards of this subpart based on available information. The
Page 15 of 107
Administrator will review, modiff as necessary, and approve if warranted the
interim operating requirements.
The series of conditions proposed by TOCDF that would be applicable to the ATLIC post-
trial-burn feed rate ensure compliance with the emission standards as follows:
Waste feed is suspended pending availability, review, and submission of trial burn
exhaust gas sample results and a determination as to whether results show compliance
with the RCRA Permit Performance Standards for Destruction and Removal Efficiency
(DRE); volatile, semi-volatile, and low-volatile metal emissions; chlorine and
hydrogen chloride emissions; particulate emissions; and dioxin emissions.
Agent GA and associated spent decon feed do not resume until the Executive Secretary
approves the STB preliminary results (preliminary data results provide the information
to make the determinations discussed in the previous bullet).
The GA feed rate to the ATLIC Primary Combustion Chamber (PCC) is limited to half
the PCC Principle Organic Hazardous Constituent (POHC) feed rate demonstrated
during the STB and the spent decon feed rate to the Secondary Combustion Chamber
(SCC) is limited to half the SCC organic feed rate demonstrated during the STB.
These wastes are fed to the ATLIC at the limited rates while the operations of the
ATLIC are maintained within the operational envelope used during the STB which is
the same operating envelope that resulted in performance-standard-compliant
incinerator operations, as demonstrated by preliminary data results, at twice the waste
feed rates, for metal, and chlorine feed rates.
The post Lewisite Comprehensive Performance Test (CPT) waste feed of lewisite and
spent decon is limited to half the feed rates specified in the approved Lewisite CPT
Plan. TOCDF is required to perform a Lewisite Mini-Bum during which the lewisite
and spent decon feed rates are also limited to 50o/o and 100% of the approved CPT Plan
approved rates, respectively. Post test ATLIC lewisite operations are therefore assured
to be in compliance with the performance standards based on exhaust gas sample
results obtained during the required mini-burn and result obtained during the STB.
Lewisite and associated spent decon feed are proposed to resume after completion of the
Lewisite CPT at rates demonstrated during the Lewisite Mini-Burn because:
Compliance with the DRE standard for lewisite is ensured by results of the STB during
which more difficult to incinerate organics were fed to the ATLIC than during the
Lewisite CPT (provided the Executive Secretary approved the STB results).
Compliance with the chlorine and hydrogen chloride emission standard is ensured by
the results of the STB during which the feed rate of chlorine was higher than during the
Lewisite CPT (provided the Executive Secretary approved the STB results).
Compliance with the metal emission standards are ensured by results of the Lewisite
Mini-Bum and by limiting the feed rate of Lewisite to the mini-bum feed rate, which
is limited to half the design feed rate of the ATLIC.
Note that TOCDF's past experience with preliminary data submissions associated with
trial burns and demonstration tests have proven to be consistently accurate.
Page 16 of 107
In addition, the DSHW maintains the authority to require TOCDF to suspend waste feed
and penalize TOCDF if DSHW review of the preliminary data determines that the
emission standards were exceeded during the time between the submission of the data and
the completion of the DSHW review.
29.Page 23 - When is the mini-burn planned?
The performance of a mini-burn is not required by regulation. Mini-bums are performed
at the discretion of the owner, and are conducted to ensure a successful trial burn.
The ATLIC is designed to treat the worst-case chemical agent, which is lewisite. To allow
treatment of Agent GA, the STB will be conducted using metal spiking concentrations.
The STB metal spiking rates are so low, relative to the capabilities of the ATLIC PAS, that
TOCDF is confident that the STB results will show compliance with the TOCDF
Performance Standards necessary for a successful STB. The resulting STB metals feed
rates will be substantially lower than those expefienced during lewisite processing.
TOCDF desires to continue the processing of lewisite after completion of the CPT and is
therefore proposing to include a condition that if approved would required TOCDF to
perform a Lewisite Mini-Bum. The feed rates of lewisite and spent decon during the
Mini-Burn would be limited to 50Yo and 100% of the rates in the approved CPT Plan,
respectively. These feed rates will produce a sufficient metals feed rates to allow the
performance of the ATLIC PAS to be evaluated. Post Lewisite CPT ATLIC operations
are assured to be in compliance with the performance standard based on the results of the
Mini-Bum and by limiting the feed rate to rates demonstrated during the Mini-Bum, which
for Lewisite are half the design feed rate and for spent decon 100% of the design feed rate.
Note the post-CPT feed rate of spent decon is proposed to be 100% design rate (i.e., the
rate specified in the approved CPT plan) because the spent decon is primarily water and
spent decon is used to cool the SCC.
The Lewisite Mini-Burn will occur shortly after the beginning of Lewisite operation
because there is a proposed permit condition that limits the number and mass of Lewisite
that can be used during the Lewisite CPT shakedown period.
30.Page24 -a. The permit requires that the Executive Secretary approve the sampling and
analysis plan prior to implementation. This was not performed. Sampling
prior to approval was at TOCDF's own risk.
See response to DSHW comment #8.
b. The High Quench Tower Exhaust Gas Temperature will still be required for
the hazardous waste permit even though MACT may also require the sample
OPL.
See response to DSHW Comment #12
Page 17 of 107
c. The testing will be performed weekly as specified by the regulations. Since this
is a new incinerator system, which will only be operating for about six months,
this requirement is not unduly restrictive.
See response to DSHW Comment #4
d. A closure plan for this unit has not been provided.
See response to DSHW Comment #24
e. The Source hmission Limit for GA 0.0003 mdm3 x0.2:0.00006 mg/m3 10.2
SEL). For Lewisite, the GPL'/WPL/STEI/VSL value of 0.003 mg/m3 x 0.4:
0.0012 g/m3 should be used for the SEL. The stack limit is based on earliest
detection. of.an upset condition.
TOCDF has revised the ATLIC exhaust stack agent NRT monitor alarm setpoint to be
0.2 SEL for agents GA and L, with the L SEL value remaining at 0.03 mglm3. These
setpoint will be evaluated during systemization to determine if the frequency of false
positives alarms caused by use of a0.2 SEL alarm (i.e., AWFCO) setpoint is too great
to allow efficient ATLIC operations. TOCDF will submit a Temporary Authorization
Request with supporting documentation to revise the setpoints if a revision to the
ATLIC exhaust stack agent NRT monitor alarm setpoints is required. The following is
provide in support of the 0.03 mg/m3 SEL value for L and the use of the 0.5 and 0.4
SEL exhaust stack NRT monitor alarm setpoint for GA and L should the 0.2 SEL
setpoint prove unworkable
o Module I of the TOCDF RCRA Permit includes reporting requirements for when
incinerator agent exhaust gas emission concentrations are confirmed to exceed I
SEL. The TOCDF is aware that MINICAMS exhibit a negative bias when
monitoring for lewisite, and studies show that a MINICAMS result of 0.4 SEL is
actually equal to 1.0 SEL. Compliance with the following condition would be
difficult to demonstrate were NRT monitors to also be used as a confirmation
method for ATLIC lewisite operations, particularly if the AWFCO setpoint were
established at0.4 SEL with a SEL equal to 0.03 mg/m3.
Any release to the atmosphere from the combined stack for the two Liquid
Incinerators, the Deactivation Furnace, and the Metal Parts Furnaceg
ATLIC stack if the confirmed stack emission level, as defined in
Attachmentg 22 and22A (Agent Monitoring Plan 4g!3!MeSeen!
Monitorins Plail. iesoectivelv), exceeds the maximum e$enrable*taek
identified for each individual
agent in Table 1 of this Permit. The Permittee shall orally report, as
specified in Condition I.U.l., to the Executive Secretary.
o
o
I.,[f.1.c.
Since the initial submission of the ATLIC Class 3 Permit Modification Request,
TOCDF has developed a DAAMS method that will be used to confirm and
quantiff lewisite exhaust gas concentrations. Therefore, the confirmation and basis
of the lewisite emission concentration will be performed through DAAMS analysis
Page 18 of107
and not by the MINICAMS result. Use of a DAAMS to confirm and quantifu
lewisite exhaust gas onissions provide assurance that the requirement of Permit
Condition I.U.1.c can be complied with when using an ATLIC exhaust stack
MINICAMS AWFCO setpoint of 0.4 SEL with the SEL equal to 0.03 mglm3.
The SEL values, which are applicable to agent incinerator exhaust gas emissions
for all of the chemical agents is set higher than the GPLAMPL/STELNSL values
because of the presence of interferents in the exhaust gas that are absent in ambient
air. An AWFCO setpoint that borders the detection limits of the agent monitors
will result in numerous false positive alarms and intemrptions in waste feed. The
potential exist that the false positive alarms could be so frequent that they would
have an impact on the Lewisite Comprehensive Performance Test (CPT) results.
The MINICAMS will be used to monitor for lewisite in the ATLIC exhaust gas.
These monitors detect lewisite using a halogen-specific detector that responds to
the chlorine in the lewisite. Halogenated compounds are present in the process
water used by the TOCDF incinerator PAS because the chlorinated well water is
used for process water.
The basis for the selection of the ATLIC agent exhaust gas concentration AWFCO
setpoints proposed by TOCDF was to minimize false positive alarms. The effect of
ATLIC exhaust gas matrix interferents on the ability of the monitors to accurately
detect agent at concentrations near the monitor's detection limit will not be known
until completion of the 28-day Baseline Studies, during which time the monitors
will be arralyzingthe actual ATLIC exhaust gas matrix.
The TOCDF implemented agent exhaust gas AWFCO setpoints at0.2 SEL for the
TOCDF Common Stack during the GB, VX, and Mustard Campaigns. There were
numerous false positive alarms at the beginning of the GB Campaign that were
investigated and eventually attributed to the mercaptan that is added to natural gas
to give it an odor. The low AWFCO setpoint of 0.2 SEL also contributed.
Throughout the agent campaigns, beginning inl996 to date, the TOCDF Common
Stack agent exhaust gas concentration AWFCO setpoint has been 0.2 SEL.
Throughout this same time period, there was one Common Stack agent exhaust gas
concentration AWFCO alarm that was confirmed as caused by the presence of
agent and 800 false positive alarms. Through 14 year of agent campaign
experience with TOCDF incinerator exhaust gas matrix effects, the monitoring
staff has minimized the occurrence of false positive Common Stack agent alarms.
The ATLIC will process agents GA and lewisite for less than approximately 200
hours. The operational time of the ATLIC is not sufficient to develop NRT agent
monitoring (by ACAMS and MINICAMS) methods that would be reliable at the
detection limits of the instruments.
Dispersion modeling results do not support an exhaust gas AWFCO setpoint for
GA or lewisite that is lower than proposed. For worst-case atmospheric conditions
(i.e., most stable conditions), the minimum ATLIC exhaust gas agent concentration
required to produce a ground level agent concentration equal to I STEL is 370 SEL
Page l9 of 107
(this for lewisite with the SEL equal to 0.03 mdm3). For Agent GA, the minimum
ATLIC exhaust gas agent concentrations required to produce a ground level GA
concentration of I STEL is 1,200 SEL. This information is provided in Enclosure
D.
Therefore, the proposed ATLIC agent exhaust gas concentration AWFCO values
of 0.5 SEL for GA and 0.4 SEL for lewisite, with a lewisite SEL equal to 0.03
m7lm3,provides protection to site workers and will provide a sufficient margin to
alert the operator to take corrective actions before there is a risk ofexposure at
ground level.
Comparisons of arsenic mass emission rates based on the SEL and environmental
regulations do not support the imposition of a more restrictive lewisite SEL value
or an AWFCO setpoint that is less than 0.4 SEL. The table below compares the
mass emission rate of arsenic from the ATLIC based on a SEL value of 0.03 mylm3
to the arsenic mass emission rate based on the HWC MACT Low-Volatile Metal
(LVM) New Source Emission standard of 23 micrograms per dry standard cubic
meter corrected to 7 percent oxygen. Arsenic is included in the LVM grouping.
Arsenic (As) Emission Rates Comparison @ the SEL and RCRA Permit Performance Standard
Exhaust Gas Flow Rate (scfin 834 834 Exhaust Gas Flow Rate (scfm)
Exhaust Gas Temperature ("F)230 3.5 Exhaust Gas Moisture Content (%)
Pressure (psia 12.2 6.6 Exhaust Gas 02 Conc (%)
ATLIC Stack Exhaust Gas Flow Rate
(acfin)905 782.5 Exhaust Gas Flow Rate (dscfin@ 7oh Oz
ATLIC Stack Exhaust Gas Flow Ratr
(acrn/min 25.6 22.2
Exhaust Gas Flow Rate
(dscm/min @7% Oz)
Lewisite SEL mg/m3 0.03 23
As Emission Standard
(ug/dscm@ 7% C,2)
Lewisite Emission Rate @ SEL (mg/hr)46.12
Lewisite As weight Fraction (%)36.14
As Emission Rate @ SEL (rng/hr)16.7 30.6 As Emission Rate @, STD (mg/hr)
The above table shows that the mass ernission rate of arsenic allowed by the HWC
MACT LVM New Source Emission Standard is almost twice the rate that would
result if the ATLIC lewisite exhaust gas ernission concentration were maintained
just below the I SEL, with the lewisite SEL value taken at 0.03 ^d^t.
It is reasonable to compare differences in Arsenic mass emission rates rather than
Lewisite emission rates because inorganic Arsenic is a Group A carcinogen.
There is only anecdotal evidence for the potential carcinogenicity of
Lewisite. However, the data are not definitive and do not support
classifying Lewisite as a suspected carcinogen. The chronic exposure risk
Page20 of 107
relative to ATLIC Lewisite processing is the inorganic Arsenic oxides
generated from the combustion of the Lewisite and the environmental
exposure and remediation concern related to the arsenic component of its
degradation products rather than the Lewisite that may survive the
incineration process.
http ://www.nap. edu/openbook.php?record_i d:9 644 &p age:27 5
The ATLIC and associated PAS train incorporate three separate units that control
organic emissions: 1) the Secondary Combustion Chamber,2) the Pulverized
Activated Carbon (PAC) Injection System, and 3) the Fixed Bed Activated Carbon
Filter System. Most commercial hazardous waste incinerators are equipped with
Secondary Combustion Chambers, or Afterbumers. Some are equipped with either
a PAC Injection Systern or Fixed Bed Carbon Filter Systern. The TOCDF is
unaware of any commercial hazardous waste incinerators that are equipped with
both activated carbon systems.
The DSHW proposed SEL value for Lewisite is 0.003 mdm3. A 0.03 mg/m3 SEL
value for Lewisite is supported by the Center for Disease Control (CDC). This
value was published by the CDC on March 8, 1988. A copy of the publication is
provided in Enclosure E. The publication includes the justification for the
selection of the lewisite SEL value.
31. I.U.4.b - The acronym "ATLIC" should be added after "TOCDF."
The TOCDF concurs with this comment; the condition is revised as proposed.
32. I.U.S.a.ii - The acronym "ATLIC" should be added with 66TOCDF" and '(I)CD."
The TOCDF concurs with this comment; the condition is revised as proposed.
33. I.U.6 - The acronym "ATLIC" should be added after "TOCDF" on the first line.
The TOCDF concurs with this comment; the condition is revised as proposed.
34.11.8.4 - This condition needs to readr "...until the TOCDF and ATLIC a;re,.."
The TOCDF concurs with this comment; the condition is revised as proposed.
35.II.F.2 - Same comment as above.
The TOCDF concurs with this comment; the condition is revised as proposed.
36. II.G.2 - This condition needs to read, "...at the TOCDF and ATLIC..."
The TOCDF concurs with this comment; the condition is revised as proposed.
37. II.I.1.c - The acronym "ATLIC" needs to be added after "TOCDF."
Page 2l of 107
The TOCDF concurs with this comment; the condition is revised as proposed.
Module II
38. Page 4 - Please change 1.0 SEL to 0.2 SEL (the HVAC is at 1.0 VSL).
The TOCDF does not concur with the proposed revision that would change the value of
the ATLIC NRT monitor stack alarm point at which worker are required to mask from 1.0
SEL to 0.2 SEL; this would cause the ATLIC Control Room to mask the site and workers
at other Area 10 locations. The proposed permit condition is similar to an existing permit
condition applicable to TOCDF Common Stack agent alarms.
Additionally, TOCDF has revised the ATLIC stack exhaust gas agent concentration
AWFCO setpoints to 0.2 SEL as recorlmended by DSHW. With this change, the
management of incinerator exhaust stack agent alarms for both the ATLIC and TOCDF in
regard to actions taken to protect worker are identical. Each has the same initial alarm
setpoint (i.e., 0.2 SEL) and the same masking criteria (i.e., workers mask if exhaust gas
agent concentration reported by both staggered NRT monitors equals or exceeds 1.0 SEL).
39. Page 4 - There is a typo, it should read Attachment 22A instead of Attachment22.
Please change ACAMS references to NRT. (ACAMS or MINICAMS)
Corrections were made on Pages 3 and 4 of Module II to add the phrase'NRT monitors
(ACAMS or MINICAMS)" and to note that the ATLIC agent monitoring requirements are
in Attachment22A.
40.11.J.2.t - A closure plan must be provided for the secondary waste that could be
processed in the Autoclave (provided the autoclave has demonstrated that agent
waste stream prior to closure).
See response to DSHW comment #24
41. II.J.5 - Please add ATLIC and Autoclave Closure Plan to closure plan attachments.
See response to DSHW comment#24.
42.11.J.6: Please verify that the DVS and DVSSR are included in the closure plan if
referenced here.
Condition II.J.6 reads:
The Permittee shall provide certification statements that each TOCDF and Area 10
hazardous waste management unit has been closed in accordance with the applicable
specifications in Attachment 10 (Closure Plan), as required by R3l5-8-7.
The reference to Area 10 hazardous waste management units include the Autoclave; ATLIC; Drum
Ventilation Syglem (DVS); and Drum Ventilation System Sorting Room (DVSSR); and Igloos
1632,1633,1634,1635, and 1636 (all of which are located in Area 10 and managed by TOCDF).
Page22 of 107
To differentiate between TOCDF- and DCD-managed Area 10 Hazardous Waste Management
Units (HWMUs), the proposed condition is revised to read:
The Permittee shall provide certi{ication staternents that each TOCDF and TOCDF
manased Area 10 hazardous waste management unit has been closed in accordance with
the applicable specifications in Attachment 10 (Closure Plan), as required by R315-8-7.
Additionally, Class 3 Permit Modification Request TOCDF-ATT10-03-1111, which was
submitted in June 2010 to comply with existing Permit Condition II.K.1, revised the
TOCDF Closure Plan (Attachment 10 of the TOCDF RCRA Permit). A1l TOCDF-
managed Area 10 HWMUs are addressed in the revised Closure Plan except the ATLIC.
The TOCDF proposes to incorporate ATLIC closure requirements during the Second
Public Comment Period associated with TOCDF-ATTI0-03-I1I I.
Also see response to DSHW commerrt#Z4.
43,II.K.I - Please add Autoclave, DVSSR/DVS, CAMDS Attachment and ATLIC.
Permit Condition II.K.I was proposed to be revised to read:
The Permittee shall submit a permit modification request that updates Attachment
10 (Closure Plan) for TOCDF associated hazardous waste manaeement units in the
second quarter ofcalendar year 2010.
In addition, TOCDF proposed a new Condition 11.K.2., which reads:
The Permittee shall submit a permit modification request that updates Attachment
10 (Closure Plan) for ATLIC associated hazardous waste manaqement units no
latsr than the f,rst third quarter of calendar year 2011
Also see response to DSHW comment#24.
Module IV
44,Table on page 2 - ttre LCS tanks are allowed to contain Lewisite miscellaneous liquid
and decon solution during closure. Please add the word Lewisite to text.
The proposed change has been incorporated into the revised Module IV that is included
with this response.
45. Page 2 - Please separate out NSF-TANK-8514 and LCS-TANK-8516.
The proposed change has been incorporated into the revised Module IV that i, i*frrara
with this response.
46.1Y.8.2 - A subparagraph should be added to this permit condition for the SDS sumps
in the ATLIC facility. Adding them to this paragraph adds an additional waste code
to ALL of the sumps in the MDB as well as the ATLIC.
Page 23 of 107
A subparagraph to Condition IV.B.2 has been incorporated into the revised Module IV that
is included with this response.
41.lY.G.l - The only hazardous waste allowed in LCS-TANK-8511 is liquid Lewisite
chemical agent and Lewisite spent decontamination solutions (l8o/o NaOH Solutions)
from closure activities.
Condition IV.G.I was revised to include (i.e., match) the wastes that are specified in the
table starting on page 2 of Module [V. See response to DSHW comment #44.
48. IV.G.3. - The word 6feet' should be deleted prior to 667.5 inches.'
The correction has been incorporated into the revised Module IV, which is included with
this response.
49.1Y.H.2. - The word "each'prior to *NSF-TANK-8514'needs to be deleted as well as
the word "feett' after "67.5.)'
The correction has been incorporated into the revised Module IV, which is included with
this response.
50. A paragraph similar to IV.I.4 should be added in IV.H for tanks NSF-TAI\K-8514
and NSF-TANK-8516 since the waste from these tanks is being shipped off-site for
deep well injection.
The TOCDF concurs; Condition IV.H.4 was added to address this comment.
51. IV.J.I- This condition should require that tank LCS-TANK-8534 be empty at all
times, not just when chemical agent is being processed or stored. This tank is the
secondary containment for the area and secondary containment should never have
anything in it untdss there is a spill or release of some kind.
The TOCDF concurs; Condition IVJ.l was revised to read:
The Permittee shall maintain LCS-TANK-8534 free of waste when liquid wastes are
nresent in the ATLIC Processins Bav or Toxic Area. This tank shall be used in the
event of a major spill as a result of a tank. ancillary equipment. or ton container failure.
52.1Y.L.2.- The reference to Condition IV.M.I should be IV.L.l.
The correction has been incorporated into the revised Module IV, which is included with
this response.
53. IV.l - Please specify the concentration of the decon nitric acid solutions.
Condition IV.H.3 was revised to specify the concentration of the nitric acid solution that
will be added to NSF-TANK-8514 and LCS-TANK-8516 at 50 %.
Page 24 of 107
54. IV. - TOCDF specifies two decon solutions, NaOII and sodium hypochlorite. Please
provide narrative describing the decon used for each agent.
The only decontamination solution that will be added to LCS-TANK-8523 is sodium
hydroxide. Sodium hydroxide will be used to treat spent decontamination and GA TC
rinse solutions that accumulate in LCS-TANK-5823 to agent concentrations below the
Waste Control Limit of 20 ppb. It will also be used to treat solutions that are generated
during lewisite processing and accumulated in LCS-TANK-8523 to lewisite
concentrations less than 200 ppb.
Condition [V.I.l was revised accordingly.
55. IV.J.6 - Please specify the primary combustion chamber for all treatment. Please
also specify which hazardous waste management unit is referenced.
The intent of the proposed condition was to not specify how wastes that are stored in the
major spill tank will be treated because the'major spiil.tank, as a contingency, may store
any liquid waste generated at the ATLIC. If a major.spill of agent occurs, the spilled agent
will be fed to the ATLIC Primary Combustion Chamber (PCC). If a major spill of spent
nitric acid occurs, it will be captured in the major spill tank and transferred to an off-site
Subtitle C Treatment Storage and Disposal Facility (TSDF). Spent nitric acid cannot be
fed to the LIC because buming the acid would generate excessive nitrogen oxides.
Condition IV.J.6 was revised to read:
Waste stored in LCS-TANK-8534 shall be treated in the combustion chamber or
Hazardous Waste Manaeernent Unit soecified for the waste stream beine stored in
Conditions IV.G.I IV.H.l. IV.L15 or IV.K.I. A,qenfGA Specifically, chemical
agents shall be treated in the Prim
Spent Nitric Acid Solutions shall be transferred to an off-site Subtitle C TSDF.
Spent Decontamination Solutions shall be treated in the Secondarv Chamber
of the ATLIC LIC.
56. IV.O - Please add ATLIC to the closure section.
Condition IV.Q.2 was revised to read:
-IV.MQ.2. The Permittee shall close the TOCDF and ATLIC Tank Systems in
accordance with Attachment 10 (Closure Plan):
Module V
57.Y.4.g.2 - Please provide details for the proposed NRT monitoring configuration
which TOCDF has determined will be the best configuration and will best determine
if there has been a release. Are the MINICAMS and DAAMS able to detect Lewisite
in an incinerator stack environment?
Page25 of 107
Condition V.A.1.g.2 was proposed to account for the possibility of using either a second
NRT or a DAAMS as a confirmation method for ATLIC Agent Exhaust Gas Automatic
Waste Feed Cutoff (AWFCO) alarms. A "single-cycle" DAAMS method for lewisite was
not available at the time the ATLIC permit modification request was submitted.
Since that time a DAAMS method has been developed and tested that is suitable for use as
a confirmation method for lewisite exhaust gas MINICAMS AWFCO alarms. Proposed
Condition Y.A.2.9.2 should be revised to read:
V.A.1.e.2. When processine Lewisite the Permittee shall rnaintain and operate €ithtr
DAAMS tubes and staggered MINICAMS monitors on the ATLIC Stack
L!}
it
tih,".
/nl lt
,rE ! .'
.." J -q'
J' ,r'.
L/
as specified in Attachments 19 flnstrumentation and Waste Feed Cut-
offTables) and 22 (Aqent Monitorinq Pl$n).ffi
with Ci$similor anolytieal eo
Note the MINICAMS and "single-cycle" DAAMS methods that have been developed for
'lewisite are capable of detecting this agent in the ATLIC exhaust stack. The methods were
developed based on a lewisite Source Emission Limit of 0.03 mg/m3 and a MINICAMS
sample/analysis cycle of seven minutes.
58. VA.l.H.ii - Please explain why the API-3000EM was specified. Is this type of
monitor exclusive to TOCDF and ATLIC operations?
The API-300EM CO CEMS was specified because it has internal components that are
different from the other CEMS. Major and minor repairs and the recertification
requirement associated with them are different for this model of CEMS.
The model's high range span limit of 5,000 ppm is preferable over a CO CEMS having a
lower range because of the requirement in the Hazardous Waste Combustor Maximum
Achievable Control Technology (HWC MACT) to use a default value of 10,000 ppm in. the hourly rolling average exhaust gas CO concentration calculation for each minute that
an operator's CO CEMS reports a maximum span value.
,_
59. V.A.2.a - Please be advised that the DRE performance standards will be the same as
was performed at TOCDF - a DRE of 99.999.9Yo for both surrogate and agent trial
burns in the [,ICs.
The TOCDF concurs with increhsing tire ATLIC Destruction and Removal Efficiency
(DRE) Performance Standard for99.99 percent to 99.9999 percent for the selected
surrogates. Section ll.4.l of Appendix A (Quality Assurance Project Plan) to the ATLIC
Surrogate Trial Burn (STB) Plan shows that a "six-9s" DRE is mathematically possible.
The revised Module V, which is included with this qubmission, incorporates the proposed
change in the DRE requirement which will be demonstrated during the ATLIC STB.
Page 26 of 107
60. V.A.4.a.i - The GA action level will be 0.2 SEL. Note 5 is not consistent with the
narrative that appears in operations. The SEL for Lewisite should be 0.003 mdm3.
See response to DSHW comment #30.e. The alarm setpoint for the ATLIC stack NRT
agent monitors was revised from 0.5 and 0.4 SEL for GA and lewisite, respectively,to 0.2
SEL for each agent.
Note 5 was revised as follows because DAAMS will be used as a confirmation method for
Lewisite.
s' GA D.AAMS beqome historical when Lgwisite is the only asent being processed
by the ATLIC.
witheifferq* an*ytieet eet m*@
61. V.A.4b - Please explain if only MINICAMS was used for Lewisite.
See response to DSHW Comment #57.
62.Y.A.4.g- The Lewisite monitoring level should be 0.003 mg/m3 and the action
leveUalarm level should be 0.0012 mglm3.
See response to DSHW comment #30.e, and #60. No change was made to this condition.
63. V.E.3.c - See comment above.
The TOCDF concurs with the need to test the ATLIC AWFCO System more frequently
than every 30 days and proposes a 14 day testing frequency. Additionally because the
ATLIC system will experience periods of extended idle where it will remain at operating
temperature, without processing waste while performance test results are being reviewed
and approved, TOCDF requests that testing of the AWFCO system be required either
every 14 days or prior to resuming waste feed for idle periods lasting longer than 14 days.
See revised condition below and responses to DSHW comment #4.
V.E.3.c. 'The Permittee shall perform a waste feed cut-off function test no
less than once every 39 fourteen (14) days. No waste shall be fed
to the ATLIC during the function test. If the ATLIC is not
operational (i.e.. Shut down) or idlinq for loneer than 14 davs. the
Permittee shall derforfir the function test when the ATLIC becomes
operational. or priorio waste feed.'
:hhu#deu# A:,cgpy of each function test shall be olaced in the
64. V.E.l.a - Spent decon may be burned in the primary chamber if it is below the
demonstrated concentrations.
Page 27 of 107
There is no intent to feed spent decon to the Primary Combustion Chamber of the ATLIC.
Upon completion of each agent campaign, a solvent will be used to flush the agent feed
lines. The solvent that is selected will conform to the requirements specified in Permit
Conditions V.E. 1.b through V.E. 1.h.
65. V.E.l.a.ii - Please provide characterization of the anticipated composition of the
miscellaneous agent contaminated waste stream.
The miscellaneous agent-contaminated waste stream refers to the solvent that will contain
chemical agent as it will be used to flush the agent line upon completion of each agent
campaign.
66. V.E.l.d - Please specify the anticipated chlorine feed rate.
The maximum chlorine feed rate to the ATLIC will be demonstrated during the Surrogate
Trial Burn and is 192 pounds per hour, or 2,304 pound per 12 hours.
67. Please provide documentation that the viscosity of the waste to be pump is
compatible with equipment.
A report documenting the capabilities of the PCC waste feed lance nozzleis provided in
Enclosure F.
68. V.E.l.g - The sampling plan for verification of waste must be approved and
performed.
The TOCDF does not concur with the need to perform additional analysis of the chemical
agents. See response to DSHW comment # 8.
69. V.E.l.h - Please delete 'oeach."
The correction to Condition V.E.l.h has been incorporated into the revised Module V
provided with this submission.
70.Y.e.2.b - Please replace short term condition at half (or 20%) feed rate instead of
TBD.
Historically, Module V has not included short-term incineration conditions, which are
included in Module VI. Module V is titled Long Term Incineration, which begins after the
performance test results (as presented in the submitted test reports) are reviewed by
DSHW. The term To Be Determined (TBD) was used throughout Module V for this
reason (i.e., the operating parameter limits are determined from performance test results,
and the tests have not yet been performed).
Therefore, no change was made to the condition.
71. V.E.3.b - If the system is automatic, the word manual should not be necessary.
o
Page 28 of 107
This condition required the operator to manually stop feed if there were a failure of the
AWFCO system. This condition is verbatim from the conditions in Module V that are
specified for each TOCDF incinerator.
Therefore, no change was made to the condition.
72.Y.8.3.c - Please be advised that waste feed cut-offs will be every seven days instead of
every 30 days.
See response to DSHW comments tA and#63.
73. Table Y.4 - The values are too high based on the processing feed rates of the agent.
The values in Table V.4 for High and Low-Volatile metals are based on the metal feed rate
associated with L since L is in excess of 30 weight percent arsenic. The value for the
Semi-Volatile Metal feed rate is based on the planned lead feed rate during the ATLIC
STB ([325 lb surrogateftr] * [001b lead/106 lbs surrogate] * l2hr: 0.39 lb semi-vol
metalll2-hr) Enclosure G provides a spread sheet that calculates metals, chlorine, and ash
feed rates associated with L feed. The Semi-Volatile metal feed rate associated with STB
is provided above.
Module VI
74. Module VI proposes to feed GA at 50oh of the demonstrated trial burn feed rate
during the post-trial burn after the Executive Secretary has approved the
preliminary results. However, for Lewisite, it proposes a 507o feed rate after the
preliminary results are submitted and a75Yo rate after the Executive Secretary
approves the preliminary results. Why the differenee? It also proposes to increase to
l00oh of the trial burn feed rates without any regulatory approval (iust submittal of
the NOC and trial burn reports). Approval of the trial burn reports will need to be
done before full operations can commence.
The precedent set by permit conditions applicable to past post-trial-bum feed-rate
limitations applicable to the TOCDF incinerators that were established through permit
modifications was to: l) feed at 50 % of the trial-burn-demonstrated rate immediately
after completion the trial burn; 2) feed at75 Yo of the demonstrated rate after approval of
preliminary data (as defined in the RCRA Permit ) by the Executive Secretary; and 3) feed
at 100 %o of the demonstrated rate upon submission of the NOC and trial burn reports, and
review by the Executive Secretary of the trial burn report Executive Summary.
The feed rate increases discussed above were applicable to TOCDF incinerators during the
final agent campaign, after multiple trial burns had been performed on each TOCDF
incinerator.
Because the ATLIC is a new incinerator, TOCDF proposed to suspend feeding of
hazardous waste (i.e., agent) following completion of the ATLIC Surrogate Trial Burn
(STB) until the Executive Secretary had approved the preliminary data. A review of the
data by the Executive Secretary prior to proceeding with GA processing is deemed prudent
Page 29 of 107
because. the STB would have been the first time a performance test was conducted on the
ATLIC.
The TOCDF also proposed to require the performance of a Lewisite Mini-Burn at a
reduced lewisite feed rate to allow for the processing of lewisite after completion of the
Lewisite CPT because the ATLIC is a new incinerator with no prior performance test
result dataavailable to document the ability of the incinerator to comply with the metal
emission standard associated with lewisite processing because of its high arsenic and
mercury content. Note metals feed rates are allowed under the HWC MACT regulations
to be extrapolated up based upon a review of trial burn data conducted by EPA which
found a linear relationship between metal feed rates and metal emission concentrations.
75.V1.4.2.a.i - The Executive Secretary must approve the Lewisite and GA monitoring
for all areas, including the staclg prior to approval of the mod (the LQCP, CDRL 24
and Table l2-2wrllbe updated in this modification).
The TOCDF concurs with the need for the Executive Secretary to approve the Laboratory
Quality Control Plan (LQCP) prior to ATLIC hazardous waste operations. A revised plan
will be submitted.
76,Y1.A.2.a.i.b - GA will be 0.2 SEL for process upsets.
See responses to DSHW comment # 30.e, last paragraph
77.Yl.A.z.b.ii - Please delete "agent operation.'
The condition is revised to read:
VI.A.2.b.ii. The Shakedown Period associated with ATLIC Surrosate Trial Bum shall not
exceed 720 hours ofa*ent hazardous waste operations.
78. VI.A.2.b.iii - Characterization of the feed will need to be sampled and analyzed form
the tank prior to feeding the waste during shakedown.
See response to DSHW comment # 8.
79. VI.A.3.a.i - Please be advised that the DRE will need to be 99.9999Yo for surrogates
and agents as required for all other TOCDF agents and surrogates. The Lewisite
monitoring level will be 0.003 mdm3.
See response to DSHW comments #30.e and #59.
80. Vl.A.4.a.iii.a.1 and,2- If any monitor fails, then waste feed stops immediately.
Condition Vl.A.4.a.iii.a and associated sub-conditions have been revised to read as follows:
VI.A.4.a.iii.a
Page 30 of 107