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91
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ShirCo Infrared SystemsI n c o r p o r a t e d "
EPA Region 5 Records Ctr.
231432
[ P R E L I M I N A R Y
DEMONSTRATION PLAN
ROSE TWP. - DEMODE ROAD
EPA SITE PROGRAM
Submitted by:
Shirco Infrared Systems, Inc.
1195 Empire Central
Dallas, Texas 75247
July 1987
1 . SUMMARY
This plan has been developed in support of the proposeddemonstration of the Shirco Infrared Systems, Inc. (Shirco)thermal treatment process under the Environmental ProtectionAgency (EPA) Super fund Innovative Technology Evaluation(SITE) program. The primary purpose of the SIT̂ l program isto demonstrate and evaluate the use of innovative technolo-gies at Superfund sites as alternatives to land disposal.
The Superfund site selected for the Shirco demonstration isthe Rose Township Dump in Oakland County Michigan, approxi-mately 15 miles south of the City of Flint. The site islocated in an open 20-acre field where the dumping of indus-trial wastes is believed to have occurred in the late1960's. Analyses of soil samples taken at the site indicatethe presence of solvents, PCB's, oils and greases and otherorganic compounds as well as moderate levels of metals.
The Shirco Demonstration unit consists of an electric heatedprimary chamber, electric or fossil fuel heated secondarychamber, exhaust gas scrubber, data acquisition and controlsystems, and heating element power centers, all enclosedwithin a single 45 foot van.
The Shirco unit has been used times in the past to provideinformation on the economic feasibility, process performanceand environmental impact of destroying site-specific wasteswith infrared technology. A typical demonstration consistsof a limited test program designed to accomplish the follow-ing objectives:
o To provide direct experimental verification that theShirco thermal process technology meets all applica-ble and appropriate EPA and State environmentalstandards.
o To provide direct experimental verification byanalysis of the solid residues that contaminantdestruction is sufficient to allow delisting of theresidues as hazardous waste.
o To determine the process operating conditionsrequired to meet the first two objectives and theattendant operating cost of larger scale units undersuch conditions.
To meet these objectives, the following requirements areestablished for each test program:
o Only samples of hazardous waste-contaminatedsoils, sludges or liquids are tested.
o All sampling and analysis is performed in accord-ance with Environmental Projection Agency (EPA)and State Agency protocols.
o All test burn process data must conform, at aminimum, to the requirements of 40 CFR Part 264,Subpart 0 and appropriate State standards.
1 o Complete test results and relevant documentation• needed to verify compliance with environmental'• standards will be submitted after each test.
Records will be kept for three years.
The following Sections of this plan describe in detail theproposed activities for a two week period of testing at theRose Township Dump site. These descriptions include, butare not limited to, the Demonstration Unit description,proposed variations in operating conditions, operating andmonitoring procedures and a site specific health and safetyrequirements.
2. RESEARCH UNIT DESCRIPTION
2.0 General Description
The Shirco Mobile Demonstration unit is designed andfabricated by Shirco Infrared Systems, Inc. of Dallas,Texas. The system consists of a feed metering system,infrared primary chamber, supplemental propane-firedand infrared secondary chamber, exhaust gas scrubber,data acquisition and control systems, and heating ele-ment power centers, all enclosed in a 45 foot van. Abrief description of the Shirco thermal process ispresented below to familiarize the reader with thegeneral concept of the technology. Specific detailsof the Shirco Demonstration Unit design and operationare then presented in the following sub-sections. Thereader is referred to the Process and InstrumentationDiagrams (Drawing No. 03286D) and Portable Pilot Lay-outs (Drawing Nos. 03794D and 02868D) in Appendix Athis plan for a description of unit design.
Figure 2.1 presents a generalized schematic of theShirco technology. Waste material is fed to a hoppermounted over a metering conveyor belt. The conveyoris shrouded and equipped with rubber skirts to mini-mize infiltration of air or escape of furnace gases.An adjustable guillotine-type gate is provided at theconveyor discharge. The gate distributes the materialacross the width of the metering belt and assists infurnace sealing. Final feed area sealing is providedby an additional adjustable knife gate in the feedchute into the furnace. The metering belt is synchro-nized, with the furnace conveyor to control the mate-rial feed rate. Figures 2.2 and 2.3 present detailedprocess and component descriptions.
The thermal processor conveyor, a tightly woven wirebelt, moves the waste material through the insulatedheating modules (primary unit) where it is brought tocombustion temperature by infrared heating elements.Rotary rakes gently turn the material to ensure ade-quate mixing and complete burnout. When the residualmaterial reaches the discharge end of the furnace, itdrops off the belt through a chute and into an en-closed hopper. The material is then discharged bymeans of a screw conveyor to a sealed 55 gallon drum.
Combustion air is supplied to the primary unit througha series of overfire air ports at various points alongthe length of the chamber, and flows countercurrent tothe conveyed waste.
c
FIGURE 2.1
• S/i/rcu Incineration System
12
Illustration depicts one of many possible configurations of a typical waste disposal system.
No burners are required at any point in the process.
Process Description
Conditioned waste material is fed to the furnace by meansof a Waste Feed System 1. passes through the RotaryAirlock 2, and onto a Metering Conveyor 3. There the mate-rial is spread and leveled in the Metering Section 4 beforeentering the Incinerator Feed Module 5. The IncineratorConveyor 6 moves the waste material through Fiber Blanket7 insulated Heating Modules 8 where it is brought to com-bustion temperature by Infrared Heating Elements 9 andgently turned by Rotary Rakes 10. Ash (or processed mate-rial) passes from the Discharge Module 11 into the Ash
Discharge System 12 to a receptacle 13. A Blower 14 forcesair through a Combustion Air Preheater 15 to extract energyfrom the exhaust gases and enters the Discharge Module11. Exhaust gases exit the furnace through the exhaustduct 16. At this point, the gases may go to the SecondaryProcess Chamber 17 to incinerate any combustibles re-maining and on to a heat recovery device such as a Com-bustion Air Preheater 15 or Waste Heat Boiler (not shown).Gases are then cooled and cleaned in the Scrubber 18 andexhausted by a Blower 19 through the exhaust stack 20.
P FIGURE 2 .2
Component Description
1. Feed System Material may be fed to the incinerator by aonveyor, overhead hopper, drum shredder or other
thod.
2. Rotary Airlock Minimizes excess air infiltration into theincinerator.
3. Metering Conveyor This belt is synchronized with theincinerator belt to feed material at the desired rate.
4. Spreading/Leveling Devices Material is spread to thewidth of the incinerator belt and leveled to the optimumprocess thickness.
5. Feed Module This module contains the conveyor drive,access doors, and sightglass to observe the incinerationprocess.
6. Incinerator Conveyor A woven metal belt manufacturedfrom selected alloys is used to convey waste material
^ntly and at the desired rate for optimum processing.%»fovides uniform exposure to radiant energy.
7. Fiber Blanket Insulation The insulation system isimmune to thermal shock, a feature that allows rapid heat-ing and cooling of the incinerator, has superior insulatingproperties and contains no asbestos. Most competingdesigns must use firebrick or castable refractory.
8. Heating Modules These modules contain the incin-rator heating elements and Rotary Rakes. The number of
is determined by desired process feed rate andmaterial composition. The modular concept allows the fur-nace to be expandable and transportable. The heatingmodules are generally controlled in zones of increasingtemperature.
9. Electric Infrared Heating Elements Silicon carbide rodsthe heat source for the incinerator. They are located
the conveyor belt to heat the material directly with
infrared energy. The efficiency of the heating elementsis greater than 99% and they offer stepless adjustmentfor precise temperature control. Electric power signifi-cantly reduces both emissions and the size of scrubbingequipment.
10. Rotary Rakes Strategically located to gently stirthe material for maximum exposure to air and infraredradiation.
11. Discharge Module This module contains the dischargehopper, access doors and sightglasses. The processedmaterial exits the incinerator at this point.
12. Ash Discharge System Prevents air infiltration anddelivers the ash to receiving container.
13. Receptacle Container of customer's choice.
14. Blower Supplies combustion air to the system.
15. Air Preheater An energy recovery device that signifi-cantly lowers operating cost for the incinerator. A WasteHeat Boiler for producing steam is also available.
16. Furnace Exhaust Insulated with the same fiber blanketmaterial used in the incinerator.
17. Secondary Process Chamber Provides residence time,turbulence and supplemental energy, if required, todestroy gaseous volatiles from the incinerator.
18. Scrubbing Systems Selected for individual processrequirements.
19. Blower and Damper Controls system draft.
20. Exhaust Stack Provided with EPA sample ports.
FIGURE 2 .3
Exhaust gases exit the primary chamber near the feedmodule to a secondary chamber (afterburner), where apropane-fired burner is used to ignite any combustiblegases present in the exhaust stream, and burn them ata predetermined set-point temperature. Electricalheating elements may be used in lieu of the propaneburner in cases where set-point temperatures of1880° F and lower are selected. Secondary air issupplied to the afterburner to insure adequate excessoxygen levels for complete combustion. Exhaust gasesfrom the secondary chamber then pass through a venturiscrubber/spray tower to the exhaust stack.
2.1 Primary Chamber
The primary chamber design and operation is unique tothe Shirco technology. It is in this primary chamberthat the waste material (solids/sludges) is brought tocombustion temperature by infrared heating and con-veyed through temperature-controlled zones at a pre-determined rate.
The primary chamber consists of rectangular cross sec-tion "box" constructed of 1/4 inch A36 carbon steelinsulated with layers of ceramic fiber blanket insula-tion mounted on stainless steel studs, and retainedwith ceramic fasteners. The insulation is manufac-tured by Carborundum Co., and consists of an 85%silica/15% alumina asbestos-free blend which can sus-tain a continuous surface temperature of 2400°F. Theinsulation thickness is 7" on the chamber top, sidesand end plates, and 5" on the chamber bottom.
The material to be processed is conveyed through thefurnace on a woven wire belt which is supported onhigh-temperature alloy shafts. The shafts are, inturn, supported by external flangemount bearings. Afriction drive system is used to pull the belt throughthe furnace. The belt is woven from 16 gauge, 314stainless steel to a thickness of 0.25". The beltspeed is controlled via constant speed motor/variablespeed reducer, and can be adjusted to achieve wastematerial residence times of 6 to 60 minutes.
Infrared energy is provided by 18 transversely-mountedsilicon carbide heating elements mounted on 3.07" cen-ters at a height of 8.75" above the furnace belt.These 1.0" OD heating elements are manufactured byCarborundum Co. and are rated at 33.1 watts/in ofradiating surface with a maximum surface temperatureof 2000° F. The primary chamber is divided into two(2) temperature control zones, with nine (9) heatingelements serving each zone. The temperature in eachzone can be precisely controlled anywhere from 500 to1850° F. The maximum operating temperature of theprimary chamber zones is 1900° F.
Four (4) rotary rakes, transversely-mounted on I'-O"centers, are used to gently turn the material on thebelt to increase exposure. The rotary rakes consistof "L" shaped fingers (0.19" OD Inconel 601) welded to316 stainless steel shafts which rotates at a rate of1.8 revolutions per inch of belt travel. The shaftsare synchronized with the belt speed through a chainand sprocket drive system.
Combustion air is supplied to the primary chamberthrough a series of sixteen (16) 1.0" diameter over-fire air ports located 1.75" above the belt surface.Combustion air flow rate and distribution to eachgroup of four (4) ports (two groups per chamber side)are controlled by manual blast gate valves. The com-bustion air fan is manufactured by New York BlowerCo., and is rated at 185 scfm at a static pressure of0.25 inches water column (in WC). The combustion airsupply can be controlled to provide both oxidizing orreducing atmospheres.
2.2 Secondary Chamber (Afterburner)
The secondary chamber consists of a rectangular carbonsteel box, lined with 12" of Carborundum ceramic fiberblanket insulation on all interior walls. The insula-tion type is identical to that used in the primarychamber. The internal cross sectional area of thechamber is 1.56 ft2 and the internal volume is 28.9ft3. The unit is designed for 0-200% excess air oper-ation with a maximum continuous operating temperatureof 2300°F, and a minimum residence time of 4.3 secondsat maximum actual flow conditions.
Supplemental fuel firing is supplied by-a 375,000Btu/hr, forced air nozzle mixed burner manufactured byMaxon. The burner is equipped with a continuous pilotflame monitor, automatic fuel shut-off and purgesystem interlocked with secondary chamber temperature,and manual fuel control valve. Combustion air supplyto the burner is controlled by manually adjustable airregisters. Auxiliary fuel firing is supplied by a36,700 Btu/hr, forced air, premix gas burnermanufactured by North American.
Secondary combustion air (excess air) is supplied tothe afterburner through the two (2) 1.0" diameterports located at the top of the chamber, directed atthe interface of the burner flame pattern and theexhaust gas inlet flow. Secondary combustion air issupplied by the same fan used to supply the primarychamber combustion air. A splitter manifold withdampers at the fan outlet allows air distribution toboth chambers. Adjustment of air flow rate to thesecondary chamber is by means of a manual blast gatevalve.
2.3 Emissions Control System
The emissions control system consists of a venturiscrubber and droplet separator tower. Water is usedas the scrubbing liquor. The venturi section andseparator tower are each equipped with two (2) waterspray nozzles. The maximum rated water flow rate is 2gpm and 10 gpm to the venturi and separator tower,respectively. The venturi section is equipped with amanually adjustable plumb bob to control gas phasepressure drop between 8 and 14 in WC and effect maxi-mum collection efficiency.
The scrubber is equipped with an integral 45 gallonsump tank, external 50 gallon holding tank, and recir-culation pump for effluent handling and disposal.Makeup water is supplied as required by a makeup waterpump to account for evaporative losses. Total scrub-ber water blowdown will be approximately 30 to 45 gal-lons per day.
In addition to removing particulate, the scrubbercools the gases from their incoming temperature(1000°F - 2300°F depending on system configuration) tosaturation temperature, usually about 180°F. Sub-cooling to a lower temperature can be performed asrequired, but consumes substantially more water thancooling to saturation temperature.
An induced draft fan, located downstream of the scrub-ber, exhausts the scrubbed gas to the stack. The fanis manufactured by New York Blower Co., and is ratedat 400 acfm at static pressure of 14 in WC.
Exhaust gases are vented to atmosphere through a 4.0"ID stack which extends through the roof of the trailerto an elevation of 23.6" above grade (10' - 0" abovetrailer roof). The stack is equipped with two (2)standard 3.0" ID sampling ports. Access to the sam-pling ports is from the trailer roof.
2.4 System Monitoring. Control, and Safety Interlocks
The objective of the thermal process monitoring andcontrol system is to ensure that the various processoperating conditions are within the appropriate rangefor effective thermal treatment of the waste, and toprovide a means to terminate waste feed in the eventthat any of the normal process operating conditionsdeviate appreciably from design set-points.
A description of the monitoring and control system ispresented below.
The Shirco Portable Demonstration Unit is fullyinstrumented to monitor the following process para-meters :
Temperature
Primary Chamber: Waste Feed Zone
Zone Al
Zone A2
Mid-zone
Zone Bl
Zone B2
Exhaust gas
Ash collection hopper
Secondary Chamber: Mid-chamber
Exhaust gas
Stack: Exhaust gas
Recorder:
Pressure
Combustion air fan outlet
Primary chamber draft
Primary chamber exhaust draft
Six-point continuousstrip chart
Secondary chamber draft
Secondary chamber combustion air
Scrubber differential pressure
Scrubbing liquor delivery pressure
Liquor Flow
Venturi scrubber liquor
Separator tower liquor
Exhaust Gas Analysis - Secondary Chamber Outlet
Continuous 0, monitor w/ strip chart recorderContinuous CO monitor w/strip chart recorderContinuous CO2 monitor w/strip chart recorder
A master control panel contains the following devicesfor process data monitoring, recording and control:
o Nine-point digital temperature display with rotaryselector
o Six-point temperature strip chart recordero Primary chamber power consumption totalizerso Primary chamber heat zone temperature controllerso Primary chamber belt speed controllero Annunciatoro Hand-off-auto switches for mechanical componentso Three-point strip chart recorder for continuous
emission monitors
The Shirco Demonstration is also equipped with safetyinterlocks to automatically correct abnormal processoperating conditions and maintain system performance.A description of the various interlock systems, cor-rective action, and corrective limits is presented inTable 2.4. The system is also equipped with an auto-matic waste feed cut-off system which will stop thewaste feed conveyor belt motion in the event of lowsecondary chamber temperature. The cutoff limit forthe waste feed shutdown control is adjustable.
TABLE 2.4
THERMAL PROCESSOR INTERLOCK SYSTEMS
INTERLOCK
Low primary chambertemperature
High primary chambertemperature
Low secondary chambertemperature
High secondary chambertemperature
Emissions control duringunit shutdown
Excessive stack gastemperature
Low secondary chamberexhaust 02
High secondary chamberexhaust CO
CORRECTIVE ACTION
Infrared heating element power centeron/Waste feed belt stop
Infrared heating element power centeroff
Propane burner on/Naste feed beltstop
Propane burner off
Secondary chamber temperature maintaineduntil primary chamber temperature dropsbelow action limits
Alarm (manual adjustment of scrubbingliqbor flow)
Alarm/Waste feed belt stop
Alarm/Waste feed belt stop
CORRECTIVE ACTION LIMIT INTERLOCK
1600°F
1850°F
1800°F
2300°F
400°F
200°F
4%
100 ppm
111, 112
11
17, 112
16
12, 13
18
TBD*
TBD*
*These interlocks have been installed but not yet identifiedon updated Process and Instrumentation diagrams.
2.5 Stack Emissions
Air pollutant emissions from the Shirco Demon-stration Unit will be minimal. The results ofthe previous waste tests performed on theShirco unit have already demonstrated thatthis technology can achieve DRE's in excess of99.9999% while incinerating PCB's, creosote/PCP/soil mixtures, and dioxin contaminatedsoils.
Similarly, the unit has already demonstratedthe ability to achieve the particulate emis-sion standard of 0.08 gr/dscf, corrected to 7%O2- Particulate emissions during all previouswaste tests ranged from 0.007 to 0.055gr/dscf, corrected to 7% 02«
Small quantities of other non-hazardous pollu-tants such as CO and NOX (normal by-productsof all combustion processes) will also beemitted. The oxidation reactions which con-vert CO to CO, occur at temperatures above1500 to 1600°F. Since the secondary chamberwill be operated at temperature in excess of1800°F and sufficient excess air will beavailable for the reaction, low CO levels(<100 ppm) will be maintained in the flue gas.The two-stage, controlled-air incinerationdesign will also inherently limit NOX emis-sions to extremely low levels (75-125 ppm).
2.6 General Test Conditions
o Primary Combustion Chamber Temperature
Testing of PCB-contaminated soils,creosote and pentachlorophenol-contaminated waste and dioxin-laden soil has verified thatdetoxification can be achievedwith a maximum primary chambertemperature of 1,600 degreesFahrenheit. In keeping with thesewaste tests, the control tempera-ture for the primary chamber shallbe varied from between 900 and1,600 degrees Fahrenheit for alltest conditions so to determinethe minimum required for detoxifi-cation. This will be the Zone Bset point. The Zone A set pointshall normally be 1,400 degreesFahrenheit. Temperature is regu-lated by a control loop whichincludes a thermocouple, propor-tional controller, and dedicatedpower center.
o Primary Chamber Residence Time
The primary chamber residencetimes are adjustable between 6 and60 minutes. These residence timesare based on a furnace effectivelength of 66.5 inches. Theresidence time shall be set byadjusting the furnace belt speed.
o Secondary Chamber Residence Time
- The previous testing of PCS,dioxin, creosote andpentachlorophenol wastes foundthat TSCA and RCRA destructionefficiencies were obtained withsecondary chamber temperaturebetween 1,800 degrees Fahrenheitand 2,200 degrees Fahrenheit. Asnoted on Table 2.7, temperaturesof 1,800 degrees Fahrenheit, and2,200 degrees Fahrenheit aregenerally tested to determine theminimum for required destruction.These temperatures will bemaintained by manual adjustment ofpropane or heating element powercenter output and air input to thesecondary chamber.
Primary and Secondary Chaiaber CombustionAir
- Combustion air input to the pri-mary and secondary chambers willbe adjusted based on chamber tem-perature and secondary chamberexhaust carbon monoxide and oxygencontent. As feed enters the pri-mary chamber, the operator willadjust air input to both chambersto maintain an oxygen level inexcess of 5% and a carbon monoxidelevel below 50 ppm in the sec-ondary chamber exhaust or lower,if necessary, to achieve a 99.9percent combustion efficiency.
Depending on the concentration ofmoisture and combustibles in thefeed material, the air to the pri-mary chamber will be minimized toprevent cooling of the set pointtemperature or increase of thattemperature heat of combustionabove 1,800 degrees Fahrenheit.Thus, if the combustible contentof the waste is high, a starvedair combustion process will pre-vail. In this case, air input tothe discharge end of the primarychamber will be adjusted to com-bust the maximum possible withoutexceeding 1,800 degrees Fahren-heit.
- In either case, the air flow tothe secondary chamber will beadjusted to maintain the set pointtemperature and produce an oxygenconcentration above 5 percent anda carbon monoxide concentrationbelow 50 ppm.
- With the steady feed expected,once combustion air adjustment hasbeen established, minimal ad just -
i ment will be required during theemissions sampling operation.
] o Waste Feed Rate•3
. - The waste feed rate to the primarychamber is controlled by the fur-nace belt speed setting and thegap opening of the feed conveyorguillotine gate. The speeds of
\ the feed conveyor and furnace con-1 veyor belts are synchronized.] Both are driven by the same drivej motor and are geared accordingly.1 The guillotine-to-belt gap shall\ normally be 1.5 inch. The feed| rate range for the system is' presented in Table 2.8.
o Furnace Draft
Both the primary and secondarychamber will be operated under aslight negative pressure to assureall contaminants are destroyedbefore being emitted into theatmosphere. The draft pressure inthe primary chamber will be main-tained at -.015 inches WC. at itshighest pressure point, which isabove the processed soil dischargechute. The draft on the system isinduced by the exhaust blower.The operator will adjust the posi-tion of four exhaust systemdampers to produce the desiredpressures in each system compo-nent. A damper between the pri-mary and secondary chambers allowsthe draft in each to be varied.The scrubber venturi damper willbe adjusted to maintain a desiredscrubber pressure drop. Finally,the exhaust blower outlet damperallows adjustment of the entiresystem. The position of eachdamper will be set by the operatorto obtain the desired conditions.
2.6.1 System Heat-Up
Heat-up will be initiated at least two hoursprior to initiating waste feed to the primarychamber. Temperature set points shall be usedfor both control zones. After the primarychamber has reached the desired temperature or1000 degrees Fahrenheit, whichever is greater,the secondary chamber heat-up will beinitiated. The propane flue flow rate will beset at the maximum to minimize time requiredto reach operating temperature. Once thesecondary and primary chambers have reacheddesign temperature conditions, feed maycommence.
2.6.2 Solid Waste Feed
Waste shall be transferred from the mixingarea to the furnace feed conveyor in nominal20-pound increments. The feed hopper con-tainer will be positioned on top of the feedconveyor hopper and the waste transferred tothe hopper. The feed hopper cover will be inposition except when depositing waste in thehopper. The designated data recorder willthen record the time and weight of feed.
2.7 Proposed Process Operating Parameters/Rose TWP.
Three principal operating conditions affectthe overall soil detoxification efficiency ofthe SHIRCO process. These are, in order ofimportance, the solid phase residence time(belt speed), the primary unit operating tem-perature and atmospheres, and the bedthickness. Since a portion of the organicconstituents present in the waste feed issimply volatilized in the primary chamber,overall system performance also depends on theefficient destruction of the constituents inthe afterburner. The primary variables whichaffect afterburner performance are afterburnertemperature, gas residence time, and oxygenlevels.
Furthermore, the characteristics of the wasteitself can influence overall system perfor-mance. The difficulty of thermal destructionof certain organic constituents, the presenceof organic species which are precursors toproducts of incomplete combustion, and theorganic concentration in the waste feed mustalso be addressed in each test burn.
Each test program is designed to evaluate theeffects of various process operating condi-tions and waste feed characteristics on over-all system performance. Table 2.7 presentsthe system operating conditions proposed forthe Rose Township test program. (The para-meters and control limits for typical PCBincineration programs are given in Table 2.8).
Shirco currently proposes to arrive at RoseTownship approximately three days prior to theinitiation of testing. This will allowsufficient time for a half-day public viewingof the unit at the Township Hall andmobilization/set-up of the unit on-site thefollowing day.
Day 1 of the test program will be utilized forsystem shakedown and checkout. The selectionof operating parameters during this day isbased upon previous experience decontaminatingPCB contaminated soils. These parameters havealso been tentatively selected for the three(3) replicate 8 hour runs to be conducted onDays 4, 8 and 10.
Day 2 of the program will consist of two (2) 4hour runs with an oxidizing atmosphere in theprimary chamber. The residence time in thefurnace will be varied to help determine theminimum time required for detoxification. Inaddition the secondary combustion chamber(SCC) temperature will be varied to obtaindata regarding optimization of utilityrequirements. Note that during one of theseproposed runs, the SCC will be heated byelectrical heating elements. Results ofprevious testing conducted with the Shircosystem have met EPA required destruction andremoval efficiencies for PCB's with SCCtemperatures of 1800° F.
Day 3 of the program will consist of three (3)runs, one of which will be run with a non-oxidizing atmosphere in the primary furnace todetermine the effect on lead fixation.Temperature in the SCC and furnace residencetime will again be varied for furtheroptimization of system operating parametersand material throughput. In addition, 2 ofthe runs will be conducted utilizing feedmaterial blended with 3 to 5% fuel oil. Thiswill provide data regarding maximization ofmaterial throughput as well as minimization ofutility consumption.
Day 5 of the program will consist of two (2)runs utilizing lower temperature in theprimary furnace to determine minimum operatingtemperature and the effect on metals presentin the feed. The atmosphere in the furnacewill again be varied to provide data on metalsfixation and the SCC temperature will belowered during one run to optimize utilityconsumption.
Days 6 and 7 will be utilized for preventivemaintenance on the pilot unit and preparationfor the following week's testing.
Day 9 of the program will consist of two (2)runs similar to those conducted on day 5,however, the SCC will be heated electricallyto further investigate the potentialminimization of utility consumption and thefurnace residence time will be reduced tomaximize throughput.
Day 11 of the program will consist of three(3) runs, again similar to those of days 5 and9, however, furnace residence time will bereduced further. In addition, one of the runswill be conducted utilizing feed blended withfuel oil to determine the effect on materialthroughput.
Day 12 of the program will consist of three(3) runs, all of which will be conducted withan non-oxidizing atmosphere and lowertemperatures in the primary furnace. Theprimary objective of these tests is to providedata on potential metals fixation with theShirco process.
In order to fully evaluate the effect ofproposed variations in process operatingparameters it will be necessary to obtaincomposite samples of feed, ash and scrubberblowdown water during each of the runs.
Upon completion of testing, Shirco personnelwill initiate decontamination procedures onthe pilot unit and prepare for demobilization15 days after arrival.
TABLE 2.7
PROPOSED TEST MATRIX
ROSE TOWNSHIP DEMONSTRATION
DAY
1
22
3
334
5
5
7/
8
99
10
111111
12
12
12
RUN
0*1
2
3
45
6
7
8
9
1011
12
13
1415
16
17
18
TIME
0900-1800
0900-13001400-1800
0900-1300
1400-1530
1600-1800
0900-1800
0900-1300
1400-1800
0900-1800
0900-13001400-1800
0*00-1800
0900-1300
1330-15301600-1800
0900-1300
1330-15301600-1800
OPERATINGFURNACE
1600
16001600
1600
1600
16001600
1200
1200
1600
1200
1200
1600
1200
12001200900
900
900
TEMPERATUREsec
2200
1800
2200'
18002200
1800
2200
2200
1800
2200
2200
1800
2200
2200
1800
1800
2200
1800
1800
(°F) APPROXIMATEWASTE FEED
(Ibs.)
40-60
35-50
40-60
50-75
60-90
50-75
40-60
35-50
35-50nnUINTTMF•-uuwiii int.--- —
. nnuwTfMF
40-60
40-6040-60
40-60
50-75
50-7550-75
35-50
40-60
40-60
FURNACERESIDENCE TIME
(min. )
202520
151015
20
25
25
20
20
20
20
15
1515
25
20
20
FURNACE MISC.ATMOSPHERE
OxidizingOxidizing A
Oxidizing
Oxidizing BOxidizingNon-Oxidizing B
Oxidizing
Non-Oxidizing
Oxodizing
Oxidizing
Non-Oxidizing
Oxidizing AOxidizing
Non-OxidizingOxidizingNon-Oxidizing B
Non-OxidizingNon-Oxidizing
Non-Oxidizing B
* - Formal sampling not proposed. System shakedown and checkout to be performed.A - Secondary Combustion Chamber to be heated electrically.B - Feed to be blended with 3 to 5% fuel oil.
Table 2.8
Test Parameters and Control Limits
for PCB Incineration
Parameter Anticipated Control RequiredValue Limits Value
Fuel/Waste FeedWaste feed rate (Ib/hr)PCB concentration in feed (ppm)
PCB feed rate (Ib/hr)
Auxiliary fuel feed rate (MMBtu/hr)Primary ChamberAfterburner
Combustion Conditions
Combustion air flow rate (acf/min)Residence time (sec)Destruction temperature (°F)Combustion gas oxygen (%)Combustion gas carbon dioxide (%)Combustion gas carbon monoxide (ppm)Combustion efficiency (%)
EmissionsCombustion gas NOx (ppm)HC1 removal (%)Particulate concentration (gr/dscf)PCB ORE (%)
Pollution ControlScrubber water flow (gpm)Scrubber water (pH)Venturi water flow (gpm)Venturi pressure drop (in. H2O)
50500
0.025
0.040.10
1258
2200610
) 2099.98
50Unknown
0.02>99.9999
97•110
25-150150-30,000
0.004-3
0.02-0.060.10-0.29
125-8302-8
1800-22005-10NA
<100>99.9
NANANANA
5-10NA1-28-15
NAa
NA
NA
NANA
NANANANANANA99.9
NANA*0.0899.9999
NANANANA
aNA (not applicable)* 99% as required by 40 CFR Part 264
-35-
3. WASTES DESCRIPTION/MATERIALS HANDLING
3.1 Wastes Description
The Shirco Mobile Demonstration Unit is designed to processsolid and semi-solid materials within the primary chamberand to process liquid wastes through a burner located in thesecondary chamber. Due to the nature of the waste conveyormechanism within the primary furnace, a woven wire meshbelt, the furnace is not designed to process liquids withouta solid carrier. The furnace is capable of handling a broadrange of contaminated soils and sludges, however, with largevariations in moisture content, inerts, volatile liquids andvolatile solids content, heating valve, and inorganic con-stituents. The secondary chamber is capable of handlingliquids within a broad range of waste feed net heatingvalves and feed rates.
Table 3.1 presents a range of solid/semi-solid waste charac-teristics suitable for processing in the Demonstration Unit.Also shown in Table 3.1 are the characteristics of wastematerials processed by the unit during previous demonstra-tion programs for comparison. For example, the wastehandling capabilities of the system range from a relativelydry, low organic content soil such as that experienced atTimes Beach, to a sticky, oily sludge typical of a wood pre-serving waste (creosote/pentachlorophenol). PCB-contami-nated soils and sludges also fall within this range. Wastecan also be preprocessed, if necessary, by dewatering, soilsblending, and/or lime addition prior to testing to ensure asolid/semi-solid matrix suitable to the process. Pure liq-uids can also be processed if blended with a suitable car-rier, such as soil or vermiculite, to form a semi-solidwaste matrix, or by direct injection into the secondary com-bustion chamber.
Extensive research and development is needed in the areas ofmaterials preparation and handling. Evaluation of variouspre-treatment measures needs to be conducted in order todetermine optimum material combinations and blends. Majorvariables to be investigated include moisture, density, BTUvalue, pH, and waste feed bed depth.
Moisture (% wt)
Inerts (% wt)
Volatile Liquid (% wt)
Volatile Solids (% wt)
Beating Value (Btu/lb)*Sulfur (% wt)
Chlorine (% wt)
Density (lb/ft3)
Form
fHazardous Constituent
Table 3.1
WASTE CHARACTERISTICS - GENERAL
Applicable PCP/CreosoteRanae
0-50
20-100
0-25
0-100
0-10,000
0-4
0-5
30-130
SolidSemi-solid
0-1,000,000
Test
10-50
30-50
5-23
15-55
2,700-6,200
0.2-1.0
0.1-3.4
55-75
SoilOily Sludge
100,000-250,000
Dioxin Tests
15-20
95
0
5
Nil
Nil
Nil
60-70
Soil
0.25
PCS Tes
1-20
30-80
0-15
3-50
0-4500
Nil
0.2
80-120
SoilOily Sludge
75-2,800
Based on the results of all previous testing, process per-formance is not dependent upon the concentration of haz-ardous constituents in the waste material. That is, the keyincineration parameters of residence time, temperature andatmosphere can be precisely controlled to completely oxidizeall hazardous constituents to innocuous products regardlessof concentration. The system, of course, is throughputlimited within the operating range for solid and semi-solidwaste streams shown in Table 3.1. Also, for liquid injec-tion into the secondary chamber, the system is throughputlimited to approximately 60 pounds/hr at a minimum residencetime of 2 seconds. Liquid feed characteristics of densityand net heating valve will dictate actual feed rate withinthe operating range of the burner.
The PCS tests conducted for Florida Steel were performed onsoils and sludges contaminated with PCBs at concentrationsranging from 75 to 2,800 ppm, however, Shirco has conductedadditional demonstration tests at higher PCB concentrationlevels (40,000 ppm) to expand the data base for this classof compounds.
In general, the quantity of waste intended for treatment forany one customer will depend on throughput of material basedon characteristics and system operating ranges. During atypical research burn, the average solid feed throughputinto the primary chamber is approximately 75 pounds perhour, or the equivalent of one (1) 55-gallon drum of solidwaste per day.
Analyses of soil samples taken at the Rose Township Dumpsite indicate the presence of solvents, PCB's, oils andgreases and- other organic compounds as well as moderatelevels of metals. Maximum levels of contaminates present onsite are presented below. An additional site samplingprogram will be conducted to locate and select specificmaterials for SITE testing.
PCB's - max. 980 ppm lead - max. 1,480 ppmtoluene - 4,700 ppm barium - max. 3,010 ppmxylene - max. 1,400 ppm chromium - max. 510 ppmpthalates (total) - 619 ppm zinc - max. 2,323 ppmchlorobenzene - max. 570 ppm tin - max. 46 ppmethylbenzene - max. 430 ppm cobolt - max. 148 ppmnaphthalene - max. 81 ppmpentachlorophenol - 32 ppm
3.2 Materials Sampling/Monitoring Procedures
3.2.1 General
Waste analysis of the sample material to betested at the Shirco facility will be suppliedby others. In addition to this analysis,representative samples of the waste feedstream are collected and analyzed for POHClevels during a typical trial burn of theShirco unit. This analysis is performed todetermine the overall environmental feasibil-ity of the system.
Each test program is designed to evaluate theeffectiveness of various incinerator operatingconditions and waste feed characteristics onoverall system performance. The test burnprogram will consist of eighteen (18) testruns. It is anticipated that two (2) to three(3) tests will be performed during each day ofthe program. However, three days will bededicated to 8 hour runs as described inSection 2 of this plan. For each of these 3
j replicate tests, samples will be collectedI from four process streams: waste feed, ash,
scrubber effluent and flue gas. For theremaining 15 tests, samples will be collectedfrom only waste feed, ash and scrubber waterprocess streams. Additional samples will beobtained from the primary and/or secondaryexhaust hot ducts to assist in full-scalepollution control system design. Monitoringand recording of key incinerator operatingparameters will also be conducted during eachtest. The specific sampling and analyticalapproaches for the waste feed are presentedelsewhere in this plan.
3.2.2 Monitoring Procedures
This section presents the sampling and moni-toring plan utilized during a typical trialburn of the Shirco Mobile Test Unit. Stackemissions monitoring is conducted during eachtrial burn for the following parameters:
Oxygen (02)Carbon Monoxide (CO)Carbon Dioxide (CO2)Oxides of Nitrogen (NO )Hydrochloric Acid (HC1)Total Chlorinated Organic Content (RC1)POHCsTotal Particulate Matter
In addition, the incinerator operator monitorsand records specific process parametersincluding waste feed rate and combustion tem-perature of the incinerator process.
Finally, representative samples of variousprocess streams including waste feed, inciner-ator ash and scrubber effluent are collectedand analyzed for POHC levels to determine theoverall environmental feasibility of the sys-tern.
3.2.2.1 Waste Feed
• The waste feed consists of contaminated soils.A grab sampling procedure is used to obtain arepresentative, time-averaged sample of thewaste feed. The waste sampling location isthe incinerator feed hopper. Grab samples,each 50 to 100 ml in volume, is obtained atfinite intervals throughout each test. Thesesamples are composited in a 1-liter wide mouthamber glass jar with teflon lined cap.
3.2.2.2 Ash Residue
A grab sampling procedure is used to obtain arepresentative, time averaged sample of theincinerator ash. The Mobile Test Unit isequipped with an ash sampling drawer locateddirectly above the ash discharge chute. A
[ portion of the ash which drops off the incin-erator conveyor belt into the ash dischargehopper is captured in the sampling drawer.
• The sampling drawer has a capacity of approxi-mately 50 ml, and is emptied at 15 minuteintervals throughout each test. These samplesare composited in a 500 ml wide mouth amber
i glass jar with a teflon lined cap.
'; 3.2.2.3 Scrubber Effluent
A grab sampling technique is used to obtain a; representative, time averaged sample of theI scrubber water effluent. 250 ml samples arej taken at finite intervals throughout the test' and composited in a liter wide mouth amber! glass jar with teflon lined cap.
3.2.2.4 Flue Gas Sampling
During each test, various flue gas emissionsand parameters are sampled and monitored by astack sampling contractor. A summary of thesampling and monitoring methodologies utilizedfor each trial burn is presented below.
Particulate. POHC. and HC1 Sampling
An EPA Method 5 sampling train is used to sam-ple simultaneously particulates and HC1.Appropriate sampling trains are designed andutilized to sample for the POHCs of interest,including the Modified Method 5 train for col-lection of semi-volatile species and the VOSTtrain for collection of volatile species.
A scaffold is set up along side the incinera-tor trailer to provide access to the stack foremissions sampling. The stack extends 10 feetabove the trailer roof and is equipped withtwo (2) standard sampling ports.
Total Chlorinated Organic Content (RC1)
EPA Method 450.1 is used for the determinationof total chlorinated organic content of theflue gas by carbon absorption and subsequentanalysis.
NOx
NOx emissions sampling is conducted in accor-dance with the procedures set forth in EPAMethod 7. Representative grab samples of fluegas for the NOx determination are collectedfrom the stack sampling port during each test.
02. CO. C02
Continuous monitoring of the flue gas is con-ducted for 02, CO, and CO2. The samplinglocation for the Shirco continuous O,monitoring system is at the outlet or theincinerator afterburner. The samplinglocation for the continuous CO and CO,monitoring system is on the exhaust stack. Anadditional sampling location for O2, CO andCO2 is at the outlet of the afterburner. Thislocation is normally used by samplingsubcontractors for monitoring redundancy. Allmonitors are equipped with a sampleconditioning system and each is calibratedprior to and during use as required.
A summary of the sampling procedures for thewaste feed, ash, scrubber effluent and fluegas is presented in Table 3.2
Monitoring for fixed gases (O2, C02, and CO)and NOX is conducted on a continuous basisthroughout each test run performed. Samplesare extracted from an existing, threaded fit-ting located between the exit of the after-burner and entrance to the venturi scrubber.The sample is delivered to the monitors by asampling system that includes: a stainlesssteel probe equipped with a calibration fit-ting; a conditioning system consisting of anin-line filter and moisture condenser; and,leak-free sampling pump.
Table 3.2
Incinerator Sampling Procedure Summary
Waste Feed
Sampling Location:
Number of Samples perRun:
Incinerator feed hopper or liquid feed line.
Grab samples of approximately 50 to 100 mleach, composited into a 1-liter amber glassjar with Teflon lined cap, are collected atfinite intervals beginning with the start ofeach test.
Incinerator Ash
Sampling Location:
Number of Samples PerRun:
Ash sampling drawer located at entrance toash discharge chute.
Grab samples of approximately 50 ml each,composited into a 500 ml amber jar withTeflon lined cap, are collected at 15-minuteintervals beginning with the start of eachtest.
Scrubber Effluent
Sampling Location:
Number of Samples perRun:
Scrubber slurry recirculation tank drain.
Grab samples of approximately 250 ml each,composited into a 1 liter amber glass jarwith Teflon lined cap, are collected atfinite intervals beginning with the start ofeach test.
Flue Gas
Sampling Location:
Number and types:
(1) Sampling ports on 4" diameter stack(2) Sampling port on afterburner exhaust
duct(3) Sampling port on furnace exhaust duct
(1) Two sampling trains for collectionsamples of particulates, POHC, and HC1for each test run.
(1) Integrated time-averaged sampling forNOX and RC1.
(2) Continuous monitoring for CO, 02, andCO2.
Calibration of the monitors is conducted on adaily basis, prior to the start of and at thecompletion of sampling, using certified Proto-col I gases. Three point calibration curvesare developed for each monitor using a gasdilution system. The accuracy of the dilutionsystem and gas concentrations is verifiedusing the results of replicate Orsat analyses.
3.3.3 Process Monitoring
The Shirco Portable Pilot Test Unit is instru-mented to continuously monitor and record (viastrip chart recorder) process temperatures atthe following six (6) locations:
Primary Furnace
- Feed Zone A- Mid Zone A- Mid Zone B- Exhaust Gas
AfterburnerStack
In addition, the following process parametersare monitored via manual gauges and recordedat 30-minute intervals throughout the testprogram:
Scrubber
- venturi differential pressure- venturi water flowrate and pressure- separator water flowrate and pressure
Primary Chamber DraftAfterburner Draft
Waste feed is manually fed to the incineratorhopper via 5-gallon plastic buckets. Eachbucket of material is weighed an recorded andthe time of depositing the weighed materialinto the feed hopper. Samples of the feedmaterial is collected as previously describedand later analyzed for POHC concentration todetermine the POHC input rate to the incinera-tor for each test.
The designated Shirco operator maintains thesystem operating log presented in Table 3.3Data -is recorded at finite intervals for eachtest condition. Comments relative to changesin the system operations, interruptions, andpertinent observations are recorded as theyoccur.
4. INSPECTION PROCEDURES
The Portable Unit inspection schedule is outlined in Table4.1. The inspection procedure is verification that thePortable Unit, Hazardous Waste Containers, and Safety andEmergency Equipment are operating normally, or in the stateof standby readiness. Actual inspection checklists are pre-sented in Figures 4.1, 4.2, and 4.3.
TABLE 4.1
Shirco Portable Unit Inspection Schedule
Area/EquipmentSpecificItems
Types ofProblems Frequency
Entire Incinerator All process equip- Inadequate prepara- ^rior to start-ment procedures, tion to startup up at new loca-and adjacent areas facility tion or after
lengthy shutdown
Each shiftWaste feed system Loose or burnedbelt, inoperativedrive
Destruction system Deterioration of Weeklyprimary or secondarychamber
Inadequate scrubber Hourlydifferential pres-sure, low scrubberwater supply
Pollution ControlSystem
Annunciator Lights Inoperative
Fire Control
Each shift
Insufficient supply Weeklyof fire extin-guishers, noindependent supplyavailable
Storage Build- Container placement Inadequate aisle Each shifting (If Applicable) and stacking
Containers
Incinerator Trailer Pipes/transferlines
Operator Instru-ments
space, containersstacked too high
Leakage, physical Each shiftdamage, not labeledor sealed, spillage
Leakage, loose fit- Each shifttings
Malfunctioning orsuspected calibra-tion drift
Each shift
Operator log sheets Incomplete or miss- Each shifting data
Utilities Electric PowerSupply
Connections Secure, Each shiftJunction power linesproperly routed
TABLE 4.1
Shirco Portable Unit Inspection Schedule(cont.)
Area/Equipment
Monitoring Equip.
SpecificItems
Water supply
Types ofProblem's
Low pressure insupply line
Frequency
Each shift
Sampling/analyzers Only one system on- Each shiftline
Calibration/Utility gases
Inadequate supply Each shift
Calibration (daily) Unacceptable re- Each shiftsuits, not completed
Excess emissionreports
Wastewater Storage Scrubber blowdown
Inadequate oxygen Each shiftor excessive carbonmonoxide levelsduring actual samp-ling, not duringcalibration
Leakage, excessive Each shiftpressure differen-tial
Recirculation tank Leakage, excessive Each shiftpressure differen-tial .
Security
Spill Control
Trailer Unit
Facility Doors
Absorbent pad
Damage to entrance Each shiftareas
Structural damage, Each shiftegress routes block-ed
Low stock Each shift
Loose dry absorbent Low stock Each shift
Shovels Missing or damaged Each shift
Empty 55-gallon Low stock Each shiftdrums
Wrenches and tools Missing or damaged Each shiftfor tightening fitings
TABLE 4.1
Shirco Portable Unit Inspection Schedule(cont.)
Area/Equipment
Safety and Emer-gency Equipment
Safety and Emerg-ency Equipment(continued)
SpecificItems
Fire extin-guishers
Cartridge res-pirators
Full Face Respira-tors
Head protection andsteel toe boots
Gloves
Chemical resistantsuits
Eye Wash
Types ofProblems
Broken seal, inadequate pressure,access blocked
Inadequate supplyof new cartridges,damaged seals orstraps
Frequency
Weekly/afteruse
Daily
Inadequate supply, Dailydamaged or scratchedlenses
Inadequate supply,damaged
Inadequate supply,damaged
Inadequate supply,damaged
Low liquid level.accessibilityblocked
First aid supplies Low stock
Daily
Daily
Daily
Daily/afteruse
Daily/afteruse
; 5. SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN•j•i
] 5.1 Solid Spills
! Shirco Infrared Systems', Inc., primary concern withI spill prevention is to keep contaminated soil fromj mixing with non-contaminated soils. Shirco personnelj incorporate a thick (3-4 mil) plastic sheet to cover] the work area forming an impenetrable barrier. Thej seams of this barrier will be completely sealed using; duct tape. Any soils seen on top of the plastic bar-\ rier will be assumed to be hazardous. These soils• will be immediately collected and returned to a con-
•i tainer of hazardous waste. At the end of each day ofoperation the plastic will be swept with the productsecured in a hazardous waste container.
Upon initiation of testing, the solid waste is takenfrom the container(s) and placed directly into thesystem feed hopper. Any spillage of waste material onthe trailer floor is immediately removed and placedinto the hopper or back into the container for incin-eration or return to the generator. Incinerator ashdischarged into sealed receptacles, unused waste sam-ples and drummed scrubber blowdown water will remain
: on site.jjiJ 5.2 Liquid Spills
: Shirco will utilize loose absorbent material (i.e.,i absorbent pillows,sand, "oil dry", sawdust, etc.) in
the event a liquid spill occurs. Liquid spills mayoccur and pool on top of the plastic barrier. If thisoccurs, a loose absorbent barrier will be constructedon top of the plastic barrier. The liquid will thenbe pumped to a holding tank awaiting proper disposal.The loose absorbent will then be shoveled intocontainers for disposal.
The following steps will be taken upon discovery of aleak in the incinerator scrubber blowdownrecirculation tank:
1. Upon discovery of a leak, the emergency coor-dinator shall be notified immediately.
2. The incinerator shall be shut down and allfeeds into or out of the tank shall _e
1 stopped .
3. All blowdown water shall be removed andplaced in drums and the tank taken out of
service until repairs are completed.
4. All leakage shall be collected usingabsorbents or other clean up materials andeither drummed for later disposition orthermally processed on-site.
5. All leakage sites shall be decontaminated.All clean up equipment shall be decontami-nated and/or refit for future use beforeactivities are resumed.
Procedures for the prevention of and response tospills from drummed waste and incineration residuesare outlined in Section 6.
6. SAFETY PLAN
I. GENERAL INFORMATION
Site; Rose Township
Location: Oakland County, Rose Township, Michigan
Plan Prepared by; Mark L. deLorimier, Shirco InfraredSystems, Inc. in cooperation with Michigan Departmentof Natural Resources
Date; June 1987
Objective; To conduct an innovative technologyevaluation utilizing the patented Shirco InfraredThermal Treatment Process.
This Safety Plan has been developed by Shirco forproposed on-site activities with a pilot demonstrationunit. This plan is not intended to replace the DNR'smaster site safety plan, but instead incorporates keyaspects of the master plan.
Proposed Date of Demonstration; 1987
Overall Hazards; Moderate, Low
Background Review;
Waste- Types; Contaminated soils and groundwater
Characteristic(s): Toxic, potentially corrosive•,j
I Exposure Routes; Inhalation, dermal contact withjij solids and liquids and ingest ion
II. SITE/WASTE CHARACTERISTICS
.1Facility Description; The Rose Township site is inOakland County, Michigan, approximately 40 milesnorthwest of Detroit. It is located in an open fieldon the property of Mr. , 1065 Demode
j Road, and the adjacent property owner, Mrs. . The 12-acre field (approximately 950' x 550')| is bounded by woods to the west. Beyond the woods is| a low-lying marsh. The site is on a topographic high5 consisting of a glacial moraine material..
In a roughly triangular area at the southwest cornerof the site are seven mounds of contaminated soil,spoils from the excavation and removal ofapproximately 5,000 barrels from the site. It is thearea of most significant known contamination. Severalpools of water have been created by the excavation.
A 24-inch high pressure natural gas line owned byConsumers Power Company crosses the southern end ofthe site.
Approximately 75 feet from the site, on the slopedescending westward to the marsh, is a groundwaterseep. At least one other smaller groundwater seep islocated 150 feet southwest of the site.
Principal Disposal Method; An unknown number of tanktrucks possibly containing organics, PCBs were emptiedon the site. In addition, approximately 5,000 barrelswere left there. It is also possible that barrelswere opened, their contents dumped on the ground, andthe barrels recycled. By July of 1980, about 5,000barrels had been removed by the MDNR.
Status; Inactive
Unusual Features; A 24-inch high pressure natural gasline owned by Consumers Power Company crosses thesouthern end of the site.
Maximum levels of contaminants were generally found inthe soil mounds.
Approximately 75 feet from the site, on the slopedescending westward to the marsh is a groundwaterseep. At least one other smaller groundwater seep islocated 150 feet north. There is a small pond in thewoods 200 feet southwest of the site.
Data Limitations;
Areal extent of surface water contamination is notclearly defined. Sampling to date has not produceda clear understanding of contaminated waters andsediments or migration pathways.
Areal extent of contaminated soil. Data on soil islimited to the major disposal area and a fewsurrounding sites. The location of other "hot-spots" or are^- contaminated by surface erosion hasnot been clearly identified. Removal of some ofthe contaminated soil mounds during the State ofMichigan's cleanup activities may invalidateexisting data in the area of major contamination.
The extent of the contaminated groundwater plumehas not been fully defined, either horizontally orvertically.
It is not known if all buried drums have beenremoved .
The only known air quality measurements were recordedduring a site visit on December 13, 1982.Measurements were made with an HNU PhotoionizationDetector. Measurements of organic vapors two to fourtimes background levels were recorded on the sitethough no odors could be detected. The airtemperature was 25° F and the ground was frozen.Odors at the site have been reported by MDNRpersonnel, especially during the summer.
- Topographic data is limited to USGS 10-foot contourintervals and elevations at well heads.
The degree of contamination of stormwater runoffhas not been defined.
Bioaccumulation effects of contaminants on fish andwildlife has not been analyzed.
Study Area Characteristics; The study area isoutlined on the study map (Figure 1) .
The Rose Township site is in a sparsely populatedrural woodland area. Generally, upland areas, such asthe woods next to the main disposal area, are coveredby a mixed hardwood forest.
III. HAZARD EVALUATION
The most significant threat to public health andsafety posed by the Rose Township site is thepotential contamination of residential wells bypollutants migrating in the groundwater. The presenceof pollutants in the groundwater up to 650 feetoffsite in sufficient concentration to be toxic orcarcinogenic has been documented. The full arealextent of contaminated groundwater has not beenidentified.
The contamination of surface water and soil also posesa threat to public health and safety. Contaminationof onsite surface water and the marsh 1,300 feet westof the site has been found. Onsite soil has also beenfound to be contaminated. The pollutants introducethe possibility of bioaccumulation of such substancesas PCS. Wildlife commonly hunted and fish caught insurrounding lakes may accumulate contaminants and passthem on to consumers.
People walking on or near the site could alsoencounter a health threat either directly fromcontaminated soil or from contaminants in the air.Walking on contaminated soil could cause direct skincontact with the contaminants or ingestion by handcontamination. Though the presence of toxic orcarcinogenic substances in the air has not beendocumented, contaminants from the soil, particularlyvolatile organics, could enter the air.
j The high pressure natural gas pipeline in the highly» contaminated area of the site is a potential public] safety problem. The pipeline could corrode and,< rupture because of soil contamination from the many••} industrial wastes that were disposed of onsite, many] of which are still unknown.,.!
; IV. ENVIRONMENTAL AND SOCIOECONOMIC FEATURES
j Environment
i Pollutants from the Rose Township site couldsignificantly affect aquatic and terrestrial life.Aquatic life in the nearby lakes is threatened by
j contaminants in the groundwater beneath the site and; by surface runoff carrying pollutants from the onsitei soil. PCBs and cadmium have been found in levels far] exceeding those harmful to aquatic life at the swampi 1,300 feet west of the site. PCBs have also been.j found at levels above aquatic life criteria in Cheese] Lake 3,000 feet northwest of the site and a marsh
4,000 feet southwest of the site although someuncertainty exists as to the validity of this result.
Terrestrial life may be adversely affected by drinkingcontaminated waters, feeding on vegetation or otheranimals that have become contaminated, or by directcontact with contaminated soil.
No adverse impacts on vegetation have been foundexcept for small areas where "tarry" substances have
'\ been found on bushes or where a hardened materialj covers the ground.3
Socioeconomics
Several socioeconomic impacts were identified in aSoutheast Michigan Council of Governments study.These are:
Lower property values or marketability of property.
Costs incurred for such things as laboratory testson water supplies, attorney's fees, purchase ofbottled water, telephone and auto mileage costs,and business liability insurance.
Psychological stress due to the uncertainty offuture contamination. Also the stress associatedwith the feeling of being unable to sell one's homeand move away.
The impacts can be expected to continue until publicfears and apprehensions are resolved.
V. SITE SAFETY WORK PLAN
1.0 Introduction
This safety plan is for the Shirco InfraredSystems, Inc. Portable Unit while it is beingoperated at the Rose Township location for thetesting of hazardous material. The PortableSystem will be operated by Shirco personnel. Theprimary purpose of the project is to evaluateShirco's patented infrared technology as a viablemeans in the destruction and decontamination of
' hazardous wastes under the U. S. EPA SITEProgram.
; Shirco Infrared Systems' activities are conductedin compliance with OSHA regulations (29 CFR 1910
I & 1926), EPA Recommendations (Occupational Safety'•:• & Health Guidance Manual for Hazardous Waste Site} Activities - N10SH #85-115, Standard Operatings Safety Guides - 1984, and others), and recognized1 professional safety principles.i| This Safety Plan is designed to assure the Safety] and the protection of health of all Shircoj personnel at a test site. The Company recognizesj the responsibility to conduct business in such a\ manner so as to not endanger anyone's health or1, safety.
2.0 Site Access Control
Only those persons authorized by Shirco InfraredSystems may have access to the Shirco Test Site.Anyone not meeting the medical surveillanceand/or personal protective equipment requirementswill be denied access to the Shirco controlledarea(s). The Chief Unit Operator or designee hasthe authority to prevent access by any person whodoes not meet the requirements as stated in thesite-specific Health & Safety Plan.
3.0 Emergency Coordination Agreements
Before operation of the Portable Unit, localpolice and fire departments, medical and localemergency response teams will be notified toprovide emergency assistance if required. A copyof the letter to be sent to local authorities isattached (Figure A).
A. Local Resources
Fire Department, Holly Fire DepartmentEmergency (313) 634-4311Routine (313) 634-8221
Police Department, Michigan State Police(Brighton Post) Emergency (313) 634-6700
Routine (313) 227-1051
j • Ambulancei _ Holly Volunteer Ambulance (313) 634-82211
\ Oakland County Office of Emergency Medical• Services and Disaster Centeri (313) 858-5300
! Huron Valley Hospital (313) 360-3300-.1
• Poison Control• Children's Hospital, Detroit.] (313) 494-5711 or 1 (800) 462-6642
B. Michigan DNR Contacts
Steve Luzkow, Project Administrator(517) 373-8448
Earle Latimer, Groundwater Division SafetyOfficer
(517) 373-4800
Pollution Emergency, Instate1 (800) 292-4702
Alerting System, Out-of-State(517) 373-7660
C. Emergency Routes
From the site to Huron Valley Hospital, takeDemode Road east to Rose Center, south(right) to White Lake Road, east to OrmondRoad, south (right) to State Route 59 (M-59),east (left) to Bogie Lake Road, south (right)to Commerce Lake Road, west (left) toHospital on left.
Travel time: 25 minutesDistance: 17 miles
4.0 Personnel Safety
A. Personnel Health Monitoring
Hazardous wastes often have distinct effectson the body: a skin effect and a toxicaction on the liver for instance. Contactwith some wastes can cause a skin lesionknown as chloracne, an often disfiguratingand persistent dermatologic disorder. Manywastes are also carcinogenic and can causethe formation of neoplasms (non-metastasizingabnormal or new growths) via oral exposure.
Physical Examination
Shirco personnel working on any suspected orconfirmed site must have completed a baselinephysical exam, meeting the guidelines listedbelow for hazardous waste work, within 12months prior to the site work. Personnel whohave not had such a physical will not beauthorized on the site.
Physical Examination Guidelines for HazardousWaste Work
Medical/Occupational QuestionnaireFull Physical Examination by PhysicianVitals (height, weight, blood pressure,pulse)Screening Audiometric Test with OtoscopicExam of WaxPulmonary Function Test (Spirometry)Resting ECG, Read by Board-CertifiedCardiologistChest X-ray (PA) Read by Board-CertifiedRadiologist (once per 2 years)Laboratory Analysis*Blood Chemistry ProfileComplete Blood Count with DifferentialUrinalysis with Microscopic Examination
'.i Zinc Protoporphyrinj Urinary Arsenic] Urinary Mercury•• Urinary Cadmium
• *Blood Chemistry Profile
Calcium Direct Bilirubin SGPTPhosphorus Indirect Bilirubin GGTGlucose Alkaline Phosphatase CreatinineBun LDH TriglyceridesUric Acid SCOT OsmolalityCholesterol Sodium Bun/
CreatinineRadio
Total Protein Potassium GlobulinAlbumin Chloride A/G RatioTotal Bilirubin cpk Beta
Cholester-Ol (LDL)
B. Personal Protective Equipment
Standards and decontamination procedures areestablished and enforced to minimize thepotential for exposure to a contaminant.
In site specific situations where othercontaminants may involve additionalscreening, monitoring services and equipmentare available. Where site history or fieldexperience indicates that problems may exist,specific guidance for upgrading personnelprotection is provided.
1. Respiratory Protection
Personnel within the operational area arerequired to use full face respirators inconformance to 29 CFR 1910.134 equippedwith combination organic vapor, highefficiency particulate cartridges orcanisters. Corrective vision inserts arerequired for those who normally wearglasses. No facial hair interfering withthe face to mask seal will be allowed.Personnel must pass qualitative fit testsfor their chosen masks.
2. Body Protection
Personnel within the operational area arerequired to wear full-body, one-piececoverall suit manufactured from saran-coated spun bonded olefin. Uncoated spunbonded olefin may be worn during certainconditions.
Glove to coverall seams and boot tocoverall seams will be sealed with ducttape to prevent dirt from entering atthose areas. In the event clothing isripped or torn, the clothing is to beremoved and replaced at once.
All clothing provided for on-site use isto be considered disposable and handledas contaminated trash before personnelmay leave the designated work area.
3. Hand Protection
All personnel working in the operationalarea are required to wear an inner gloveof light-weight PVC or latex accompaniedby an outer glove of buna nitrile rubber.External work gloves of cotton or leatherwhich provides additional thermalprotection, enhance a worker's grip, andprotect rubber gloves from physicaldamage may be used to meet individualpreference.
4. Foot Protection
All personnel in the operational willwear safety footwear which conforms toANSI Z41.1.
5. Head Protection
Hard hats, where required, conform to thelatest edition of ANSI Z89.1.
6. Eye/Face Protection
Eye and face protection, where required,conforms to the latest edition of ANSIZ87.1.
7. Personnel Protection Upgrading
• It is not anticipated that an upgradingto Level B protection will be requiredduring the Rose Township demonstration.However, periodic air surveillance willbe conducted with an OVA operated in thetotal readent mode. Should dial readingsindicate possible total vapor and gasconcentrations in excess of 5 ppm aboveback ground, work will be stopped untilsuch time that workers upgrade topositive pressure supplied air.
C. General First Aid
1. Skin Contact
In the event of direct skin contact, theaffected area is to be washed immediatelyand thoroughly with soap and water.
2. Eye Contact
Eyes are to be thoroughly flushed withwater and medical attention is given as aprecaution.
D. Heat Stress Monitoring
It is recommended that during site operationperiods where ambient daily maximum tempera-tures exceed 70 degrees Fahrenheit, theresearchers should implement measurements ofWet Bulb Globe Temperature Index (WBGT) asdescribed in Threshold Limit Values andBiological Exposure Indices for 1985 - 1986by the ACGIH. Due to the levels ofprotective clothing worn by all personnel,the researchers should calculate the WBGT at1 hour intervals whenever the daily maximumtemperature exceeds 70 degrees Fahrenheit.All measurements and calculations should berecorded. Where possible, work hours are tobe changed to cooler periods of the day toavoid unnecessary heat stress on personnel.
From the heat stress monitoring data that hasbeen collected during the summer investiga-tions, the following guidelines have beensuggested concerning the work/rest regimentfor workers wearing Level C protection:
1. With WBGT's from 75-85 degreesFahrenheit, workers shall not be allowedto work more than one hour without takingat least a 15 minute break.
2. With WBGT's from 85-95 degreesFahrenheit, workers should not be allowedto work more than 45 minutes without atleast a 15 minute break.
3. With WBGT's exceeding 95 degrees Fahren-heit, workers should not be allowed towork more than 15 minutes without atleast a 15 minute break.
4. Individuals definitely have variable lim-its as to the amount of heat they cantolerate. Employees should be informedthat they are responsible for their ownphysical well-being. Monitors judge heatstress only by what they see. Only theindividual knows how he feels and whathis limits are.
It is recommended that at the end of eachwork period the workers remove theirprotective clothing and do the following:
1. Take their oral temperature and proceedas below:
a. 99 degrees Fahrenheit - no action.
b. 99 degrees Fahrenheit to 99.7 - coolthem off with a water spray and donot allow a return to work unlesstheir temperature is 99 degreesFahrenheit at the end of the restperiod.
c. 99.7 degrees Fahrenheit to 100.4 -cool them off with a water spray,
! double their rest period, and do noti allow a return to work unless their: temperature is 99 degrees Fahrenheit! or below. If heat exhaustion or heatj stroke symptoms are present, seek: medical attention.';
\' ̂ "^ d. 100.4 degrees Fahrenheit - cool them; off immediately with a water spray,
begin standard first-aid procedures,. and seek medical attention.
• j
| 2. Take and record Blood Pressure•'.
j w a. Upper limit 140/90:i b. Low limit -/60••;:\ 3. Take and record Pulse Rate-i
-'1 a. greater than 120 beats per min.I b. less than 60 beats per min.•4-.' 4. Take and record body weight
a. weight loss greater than 5% bodyj weight. Skip rotation until weightI is replenished.
] 5. Check each worker carefully for symptomsj of heat illness and react accordingly.
i*~>~"\
6. Drink slowly, cool but not cold, eight(8) ounces of water, six (6) ounces ofwater plus two (2) ounces of a naturalunsweetened fruit juice, or eight (8)ounces of 0.1% saline solution.
Weather Variations: During cold weather,employees are provided with insulated safetyfootwear and oversized impervious suites tofacilitate additional clothing required forthermal protection.
5.0 Decontamination
Decontamination procedures are included as partof site-specific Health & Safety Plans. Theseare developed in accordance with NIOSHPublication #85-ll5-Occupational Safety & HealthGuidance Manual for Hazardous Waste SiteActivities (19851. The objective ofdecontamination efforts is to prevent personalcontact with hazardous materials and to preventtheir spread into "clean" areas. Throughsequential removal of protective clothing andequipment and disposal or cleaning of it, thisobjective is accomplished. The specific methodsare dependent upon the individual contaminantsand their physical forms.
5.1 Procedures For Level C Decontamination
Station 1:
Station 2:
Station 3
Station 4:
Exit trailer and deposit equipmentused (tools, sampling devices andcontainers, etc.) on plastic dropcloth. During hot weatheroperations, a cool down station maybe set up within this area.
#3 galvanized wash tubs at station(one with soapy water and one withrinse water). Scrub boots and outergloves with detergent and water;rinse using copius amounts of waterin rinse tub.
Remove tape around boots and glovesand dispose of in 55-gallon drum.
Remove outer gloves and dispose of in55 gallon drum.
Station 5: Remove Tyvek suit and dispose of in55-gallon drum. Suit must be rolledinside out when removed or torn off.
Station 6: Remove safety boots and store infinal decontamination area.
Station 7: Plastic wash tubs at station (onewith detergent and water and one withrinse water). Wash inner gloves indetergent and water and rinse withwater.
Station 8: Remove face mask and clean as needed.Deposit mask in plastic liner. Avoidtouching face with fingers.
Station 9: Remove inner gloves and dispose of in55-gallon drum.
Station 10: Wash hands and face.
6.0 Emergency Plan
A. Emergency Coordinators
Title Local Address Local Phone
Site Manager * *
Shift Supervisor
Chief Operator
Process Engineer
*Local addresses and phone numbers will be provided at thestart of testing procedures.
B. Emergency Cleanup Equipment
All of the equipment, material, and personnelwill be available during an emergencysituation. Required sources that may not beavailable at the site will be obtained fromlocal commercial process.
Emergency Equipment
In case of a fire, or release of hazardouswaste, the following fire fighting,containment, and emergency equipment isavailable at the process staging area:
1. Fire extinguishers - 5# and 2.5# - drychemical type ABC, capable ofextinguishing fires involving ordinarycombustible material such as wood, cloth,paper, rubber, and many plastics; firesinvolving flammable liquids, oils,greases, tars, oilbase paints, lacquers,and flammable gases; and fires involvingenergized electrical equipment. Allextinguishers comply with National FireCode standards for portable fireextinguishers.
2. A dedicated water source with sufficientwater pressure will be accessible for afoam delivery system provided by localfire department.
3. Spill or containment equipment located onthe site includes:
a. Loose dry absorbent (e.g., sawdust,vermiculite, or multi-purposesorbent) - this material will bestored on-site and available to beused to contain and absorb spills.
b. Shovels with wooden handle, steeltype. This equipment, also storedon-site, is to be used in thephysical containment of any releasedhazardous constituents.
c. Wrenches and other tools fortightening fittings and valves.These will be readily available foremergency use.
4. Emergency Alarm Systems
Due to the small size of the PortableUnit, voice communications will be themeans of emergency alarm.
First Aid Supplies
a. Bandage material
- Band aids
- Gauze pads and rolls
- Adhesive tape
- Butterfly bandages
b. Antibacterial ointments
c. Splints
d. Aspirin
e. Emetic - Syrup of Ipecac
f. Local and topic anesthetics
g. Eyewash bottle and solution
Emergency eye, face and body wash. Aneye wash unit and a shower will belocated in the staging area.
Protective Clothing and Equipment
a. Rubber and neoprene rubber boots.
b. Short and long neoprene rubbergloves.
c. Chemical-resistant suits (Tyvek)
d. Viton gloves
e. Hard hats, steel-toed boots
f. Face shields and protectiveeyeglasses
g. Chemical cartridge respirators withcartridges for organic vapors anddust; half and full-face types.
Post-Emergency Equipment Maintenance
After an emergency event, all emergencyequipment will be cleaned so that it isserviceable for use or it will be replaced.Before operations are resumed, an inspectionof all safety equipment will be conducted.The Regional Administrator, state and/orlocal authorities, as appropriate, will benotified that post-emergency equipmentmaintenance has been performed and operationscan be resumed.
C. Emergency Response Procedures
1. Notification
If the Emergency Coordinator determinesthat the facility has had an uncontrolledsituation, such as a spill or fire whichcould threaten human health or theenvironment, he must report his findingsas follows:
a. Alert site personnel by voicecommunications and/or telephonepaging system. Due to the small sizeof the Portable Unit, voicecommunication will be used to directpersonnel after any alert is sounded.
b. If his assessment indicates thatevacuation of the work area may beadvisable, he must immediately soundthe evacuation alert, stop theoperation and notify the Local FireDepartment, Ambulance Service, andPolice Department. He must be avail-able to help appropriate officialsdecide whether adjacent areas shouldbe evacuated.
2. Implementation of the Emergency Plan
The Emergency Coordinator must assesspossible hazards to human health or theenvironment that may result from anyemergency situation. This assessmentmust consider both direct and indirecteffects of the incident (e.g., theeffects of toxic, irritating, orasphyxiating gases that are generated, orthe effects of any hazardous surfacewater runoffs from the water used tocontrol fires).
The Emergency Plan will be implemented inany of the following situations:
a. Fire
1) A fire causes, or could cause,the release of toxic fumes.
2) The fire could possibly spread tooff site areas.
3) Use of water, or water andchemical fire suppressants, couldresult in uncontainedcontaminated runoff.
b. Spills or Materials Release
1) The spill could cause the releaseof toxic vapors or fumes into theatmosphere in concentrationshigher than the Threshold LimitValues recommended by theAmerican Conference ofGovernmental and Industrial
•jj Hygienists.
I 2) The spill can be contained on-! site, but a potential exists for! ground water or surface wateri contamination.•j] 3) The spill cannot be contained on| site, resulting in a potentialI for off-site soil contamination1 a..5/or ground or surface water] pollution.
c. Severe Weather Conditions RequiringEmergency Shutdown
1) A tornado has been sighted in thearea.
2) A tornado warning is in effectfor the area.
3) A lightning storm is underway inthe area (storm center less than5 miles away).
1 3. Emergency Coordinators
] If an emergency situation develops while'* the Portable Unit is processing material,
the first person becoming aware of theemergency will contact an EmergencyCoordinator in the order listed in FigureB.
a. Identification of Hazardous Materials
The Emergency Coordinator willimmediately identify the character,exact source, amount and extent ofany release. The initialidentification method will be toutilize visual analysis of thematerial and location of the release.If for some reason the releasedmaterial cannot be identified, actualsamples will be taken for analysis.
b. Hazard Assessment
The Emergency Coordinator will assesspossible hazards to human health orthe environment that may result fromthe release, fire, or severe weatherconditions. The EmergencyCoordinator will assess the hazardsposed by an incident through thefollowing steps, as appropriate:
- First, identifying the materialinvolved in the incident;
Second, consulting the appropriateSafety Data Sheets to determinethe potential effects ofexposure/releases, and appropriatesafety precautions; and
Third, identifying exposure and/orrelease pathways and thequantities of materials involved.
This assessment will consider boththe direct and indirect effects ofthe release, fire, or severe weatherconditions (e.g., the effects of anytoxic, irritating, or asphyxiatinggases that are generated or theeffects of any hazardous surfacewater runoff from water used tocontrol fire and heat-inducedexplosions).
Based on this assessment, the**0 Emergency Coordinator will determine
what risk is posed to workers andneighboring populations. If theincident cannot be controlled byoperating personnel without incurringundue risk, the Emergency Coordinatorwill order the evacuation of allworkers at risk and notifyappropriate response agencies of the
""*"'' situation and the assistancerequired. If the EmergencyCoordinator determines that anypersons outside of the ShircoPortable Unit area are at risk as aresult of the incident, he willcontact the appropriate agencies and
<^ department and advise them of therisk and the need or potential needto institute off site evacuationprocedures.
The health effects of contaminantspresent at- the Rose Township site arepresented in the Master Safety SitePlan prepared by the MichiganDepartment of Natural Resources.This information will summarize thepossible direct and indirecteffect(s) of the material beingtested on human health and theenvironment, and will aid theEmergency Coordinator in hisassessment.
c. Control Procedures
Potential accidents fall under threegeneral classifications: (1) fire(2) releases to the atmosphere, soiland/or surface waters and (3) severeweather conditions such as tornadoand lightning storms. The followingsequence of events constitute thespecific responses and controlprocedures to be taken in the eventof a fire, or release of hazardouswaste to air, land or water.
E. Response
The initial response to any emergency will beto protect human health and safety, and thenthe environment. Secondary response to theemergency will be identification,containment, treatment, and disposalassessment.
1. Fire
When an uncontrolled fire outside theunit appears imminent or has occurred,all activity related to the system willcease.
The Emergency Coordinator will assess theseverity of the situation and decidewhether the emergency event is or is notreadily controllable with existingportable fire extinguishers or siteequipment and materials at hand. Firefighting will not be done if the risk tooperating personnel appears high. TheFire Department will be called in allsituations in which fires have occurred.
If the situation appears uncontrollable,and poses a direct threat to human life,a warning will be sounded to allpersonnel to secure their emergencyequipment and immediately evacuate thetesting area.
The Emergency Coordinator will alert allpersonnel when all danger has passed, asdetermined by fire department personnel.
All equipment used in the emergency willbe immediately cleaned and refurbishedfor use in the event of any futureemergency.
2. Spill or Material Release
If a hazardous waste spill or materialrelease is noted, the information will beimmediately relayed to the EmergencyCoordinator.
The Emergency Coordinator will assess themagnitude and potential seriousness ofthe spill or release by reviewing thefollowing information:
a. Safety Data Sheets on the materialspilled or released.
b. Source of the release of spillage ofhazardous material.
c. An estimate of the quantity releasedand the rate at which it is beingreleased.
d. The direction in which the spill orair release is moving.
e. Personnel who may be or may have beenin contact with material, or airrelease, and possible injury orsickness as a result.
f. Potential for fire resulting from thesituation.
g. Estimate of area under influence ofrelease.
If the accident is determined to liewithin the on-site emergency responsecapabilities, the Emergency Coordinatorwill implement the necessary remedialaction.
If the accident is beyond thecapabilities of the operating crew, theEmergency Coordinator will notify theappropriate governmental agencies.
In the event of an emergency spill orrelease, all personnel not involved withemergency response activity will beevacuated from the immediate area.
The area will be roped or otherwiseblocked off. All waste feed systems tothe incinerator, and the incineratorsystem will have emergency shutdownprocedures imposed.
The following evacuation guidance, toallow for safe emergency responseactivities, will be employed:
Incident: Small spills from theincinerator, drums,containers.
Action: Evacuation of at least 50 feetin all directions.
Incident: Volatile material spill, toxicvapor cloud, large rupture ofthe incinerator.
Action: Downwind clearance of an areaof at least 500 feet wide and1,000 feet long.
3. Severe Weather Conditions RequiringEmergency Shutdown
When a tornado is sighted in the area,when a tornado warning has been issued,or when a lightning storm occurs, theinformation will be immediately relayedto the Emergency Coordinator.
The Emergency Coordinator willimmediately institute emergency shutdownprocedures in the case of a tornadosighting, and all personnel shall proceedindoors after completing appropriateshutdown procedures. In the case of atornado warning, or lightning storm,waste feed shall be stopped, and allpersonnel shall standby for emergencyprocedures. When the storm passes, theEmergency Coordinator will inspect all ofthe on-site equipment to insure itsreadiness of operation. If any emergencyequipment, or equipment which affects theprocess interlocks or vessel integrityhas been damaged, the system will not berestarted until the equipment has beenrepaired or replaced.
If the Emergency Coordinator's inspectionindicates a fire or release has occurredas the result of a severe weathercondition, he will follow the proceduresoutlined above.
F. Storage and Treatment of Released Material
Immediately after an emergency, the EmergencyCoordinator will make arrangements for treat-ment, storage, or disposal of recoveredwastes, contaminated soil, surface water, orany other contaminated materials. Recoveredwastes will be processed only if theircharacteristics are such that they arepermitted under the Permit issued.
If the concrete in the vicinity of thestorage area or the staging area is involvedin the emergency and has been contaminated,the clean-up crew will use high pressurewater sprays on the surface of the pad. Thisprocedure will be repeated until any residuesare gone. Rinsings will be collected anddisposed of as hazardous wastes.
Inert material to contain, divert and cleanupthe spills will be used if they have not beencontained by a dike or sump. Spillscontained within the dike or sump will bepumped back into the appropriate storagedrums.
All contaminated containment and cleanupmaterial will be placed in drums for properdisposal. All recovered liquid wastes andcontaminated soil will be placed in drums forprocessing in the Portable Unit or return thegenerator.
G. Prevention of Recurrence or Spread of Fires,Explosion or Releases
', The Portable Unit contains built-in standard} operating safeguards to control the systemj during an emergency situation to ensure that; fires, or releases do not recur or spread to* other hazardous wastes at the facility.j\
1.0 Evacuation Plan
The first person recognizing an emergency sit-uation that threatens human health or theenvironment shall notify the Emergency Coordi-nator, who will initiate a site evacuation. Theevacuation plan consists of:
A. The signal to evacuate will be by voicecommunication.
B. Leave the area quickly by the nearest safeexit. Operating personnel are to escortvisitors out of the immediate area.Personnel are to take note, before leaving,of where the emergency situation exists sothey do not jeopardize their safety bywalking into that area.
C. Assembly in the area designated by the ShiftSupervisor during the tailgate safety meetingfor head count and further instructions.
D. The Emergency Coordinator will further directactions as necessary and initiate the propernotification procedures for the agenciesinvolved. No one is to return to the siteunless so instructed by the EmergencyCoordinator or until the EmergencyCoordinator or other recognized official incharge issues an "all clear."
The test unit is totally enclosed with a tractortrailer and such small quantities of waste arehandled during testing, that any release couldimmediately be contained and cleaned up. If afire was to occur, it would most likely becontained within the trailer. If a fire couldnot be contained within the trailer, anevacuation of the general area would take place.In the case of unit system(s) failure, waste feedto the unit is automatically stopped via aninterlock system.
8.0 Reports
A. Local Report
The Emergency coordinator's report to localauthorities must include:
; 1. Name and telephone number of reporter;
2. Name and address of facility;
3. Name and type of incident (e.g. release,^r fire) ;
•A ^̂
] 4. Name and quantity of materials or•]- material involved to extent known;
5. The extent of injuries, if any;; -6. The possible hazards to human health or^ the environment, and cleanup procedures.
B. Project Reports
: The Emergency Coordinator must note in the• operating record the time, date, and details
of any incident that requires implementing| the emergency plan. Within five days after1 the incident, he must submit a written report: on the incident to the Project Manager.
.i The report must include:
'< 1. Date, time, and type of incident (e.g.,< fire, explosion, etc.);
2. Name and quantity of material(s)involved;
j 3. The extent of injuries, if any;
4. An assessment of actual or potentialhazards to human health or the envi-ronment, where this is applicable;
5. Estimate quantity and disposition ofrecovered material that resulted from theincident;
6. Actions taken during the situation;
7. Evaluation of the cause;
8. Recommendations for corrective actions;and
9. Identification of modifications to thesystem operating procedures or the spillplan.
Within 15 days of the incident, the ProjectManager must submit a written report of theincident to the EPA Regional Administrator.
Figure A
Dear:
As (company officer, title, company name, location) Iam requesting your assistance in the event of an emergencyat our Portable Thermal Process Site located at (processingsite).
The Portable Unit will be used to demonstrate thermalprocessing of limited (pilot) amounts of (waste) generatedat (processing location). Please review the attached layoutmap and facility drawing for our location and indicate yourorganization's intent and ability to provide assistance ifrequired.
Please provide written response (or site visit) to thisletter within 30 days. We appreciate your efforts in thismatter.
Sincerely,
Company OfficialTitle
Enclosure
7.0 TRAINING
The information contained in this section outlines the per-sonnel training program for the Shirco Portable Unit.
7.1 Outline of Training Program
The test coordinator who is familiar with the PortableUnit and with the overall plant facility, will beresponsible for directing the training program. Theproject will be accomplished by on the job trainingand include safety, spill prevention and control, andoperation procedures. Operating directives, safetydirectives, and Contingency Plans are reviewed by alloperating personnel. Files of these documents arealways available to operating personnel.
7.1.1 Job Titles and Duties
The organization of personnel associated withthe Portable Unit is shown in Figure 7.1.
7.1.2 Training Content. Frequency and Techniques
During the on-the-job training program (Figure7.2 Training outline), employees areinstructed on the following major topics: (1)the hazardous nature of chemicals and chemicalwastes in general, (2) the purpose of theToxic Substance Control Act (TSCA) and theResource Conservation and Recovery Act (RCRA)and importance of maintaining compliance withTSCA and RCRA regulations, (3) the hazardousnature of the wastes being tested, (4) properhandling and storage procedures for wastes,(5) emergency procedures and the safety planrelated to the process, and (6) emergency pro-cedures and the continency plan. Other spe-cific training topics include:
- Appropriate personnel protective equipment,levels A, B, C & D;
- Hazardous materials handling procedures forPCB's and RCRA wastes;
- Hazards of hazardous wastes;
- System operating conditions;
- System safety and monitoring interlocks;
- Spill prevention and control,
Figure 7.1
Portable Unit Organization
Test Coordinator - Ken Johansen
Operators - Wayne Crutcher
Operators - Don Pickett
Operators - Mike Russell
Operators - David Stone
Operators - Arnold Walley
Position Title: Test Coordinator
Position Responsibilities and Duties:
- Emergency Coordinator for all hazardous waste testingactivities.
- Directs Shirco Personnel in areas involving emergencyaction.
- Responsible for direct supervision of unit components andcontrol system.
- Supervises the maintenance of operating logs, monitoringrecords, maintenance records, inspection records, trainingrecords, and other required records.
- Regularly inspects facilities for status of air, water,and solid/hazardous waste emissions and controls.
- Notifies proper authorities in emergency situations.
- Directs training of personnel in the proper handling ofhazardous wastes and in the use of the demonstration unit.
- Drafts and submits to site manager, all required reportsto EPA or the State.
Position Title: Operators
Position Responsibilities and Duties:
- Reports to Test Coordinator.
- Operates demonstration unit and auxiliary systems.
- Monitors and logs operating conditions of they system andauxiliary equipment.
- Inspects the unit and surrounding area for evidence ofleaks and spills, or potential problems.
- Notifies test coordinator of process operation problems.
- Carries out emergency response activities under directionof Test Coordinator.
- Takes emergency actions on own authority in accordancewith established procedures.
Figure 7.2 OUTLINE FOR SAFETY TRAINING PROGRAM
1. Policy
1.1 General Policy, Purpose and Importance of RCRA andTSCA
1.2 Management Responsibility1.3 Individual Responsibility
2. General Safe Work Practices
3. Personnel Protective Equipment
Head, eyes, feet, skin, respiratory
4. Safety Meetings, Inspections, and Record Keeping
4.1 Meetings - pre-startup and tailgate4.2 Inspections - pre-startup and daily4.3 Record KeepingMeetings, inspections, forms, accidents/illness, train-ing industrial hygiene/medical surveillance
5. Equipment Safety
5.1 Mechanical Equipment Safety5.2 Electric Equipment Safety5.3 Cylinder and Drum Handling5.4 Sight Glass, Feed, Discharge, Surface Temperatures
6. Chemical Safety and Industrial Hygiene
6.1 Types of Dangers - toxic/corrosive6.2 Specific Material being tested6.3 Sampling Protocols - solids, liquid, gases
7. Hazard Recognition
8. Emergency Equipment and Procedures
8.1 Equipment - description and use8.2 Personnel Emergency Procedures (eye wash, etc.)8.3 Alarm Procedures8.4 Evacuation Procedures8.5 Summoning Emergency Assistance
9. Spill Prevention, Cleanup, and Waste Disposal
Figure 7.2 OUTLINE FOR SAFETY TRAINING PROGRAM
10. First Aid/Fire Training, Equipment LocationThe training program is tiered in some areasto provide training to personnel at levelsthat are relevant to their positions withinthe system operation. On-the-job training isused to provide the additional specializedtraining.
7.1.3 Training Director
The personnel training program is directed byMr. Ken Johansen. Mr. Johansen has been withShirco for 7 years. He received a B.S. degreein Mechanical Engineering from Oklahoma StateUniversity. Records of his previous experi-ence and ongoing training are kept on file bythe Vice-President of Personnel ShircoInfrared Systems, Inc., 1195 Empire Central,Dallas, Texas 75247 (630-7511).
All on-the-job training is supervised by theTraining Director.
7.1.4 Training for Emergency Response
The emergency response training program isdesigned to ensure that personnel not onlyhandle hazardous waste testing in a safe man-ner but also properly respond to emergencysituations. The program trains incineratorhazardous waste handling management personnelto maintain compliance under normal operatingand emergency conditions.
Training elements addressing non-routine andemergency situation (unscheduled process shut-downs and start-ups related to storms, poweroutages, fires, explosions, spills) include:
- Procedures for locating, using, inspecting,repairing, and replacing emergency and moni-toring equipment
; - Emergency communication procedures and alarm•, systemsJ
1 - Response to fires or explosions•*
j - Response to ground water contamination inci-•=] dents and procedures for containing, con-j trolling, and mitigating spills•i
j - Procedures for evacuation
7.2 Implementation of Training Program
All program personnel will have successfully completedthe training program as outlined in Section 7.1 beforeoperation of the demonstration unit on hazardouswastes. All new operating personnel will be requiredto success-fully complete the training program uponassignment to the project, or to a new position withinthe project. Employees will not work in unsupervisedpositions until they have completed the training out-lined in Figure 7.2.
As a minimum, on-the-job training reviews will be con-ducted at a frequency not less than once a year. Thesubjects of these reviews will include:
(a) The status of process operating conditions andprocedures, noting areas where there are problemsor the potential for problems. Employees partic-ipate in development of effective solutions.
(b) The requirements contained in the RD&D permit,noting any changes that have occurred during thepast year. Areas where compliance was a problemare identified and discussed; and effective solu-tions are sought.
(c) Incidents that have occurred in the past yearthat warranted use of safety plans and/or emer-gency action. This review focuses on the causeof the incident and identification of steps to betaken to prevent or to ensure better handling ofsuch events in the future.
8.0 PREVIOUS TEST DATA
Shirco has previously demonstrated its equipment capabilityin several on-site hazardous waste test burns utilizing thePortable Demonstration Unit. Three test burns directlyapplicable to this permit application included an on-sitedioxin contaminated soils test burn performed in July 1985at Times Beach, Missouri, a pentachlorophenol/creosote -contaminated soils test burn performed for InternationalPaper Company at their Joplin, Missouri wood treating facil-ity in November 1985 and a PCB-contaminated soils test burnperformed for Florida Steel Corporation at their Indiantownmill in May 1986. During all programs, Shirco had fullresponsibility for all process operations and overall pro-gram safety. The success of these programs clearly demon-strates the efficacy of the technology from the standpointof both personnel safety and environmental protection.
Test results of the Times Beach program are presented inTable 8.1. As shown, the Shirco Portable Demonstration Unitachieved dioxin destruction and removal efficiencies (DRE's)well above the 99.9999% standard required under RCRA. Inaddition, residual dioxin in the soil was non-detectable ata level of 33 to 38 parts per trillion (ppt). Equallyimpressive results were achieved during the InternationalPaper pentachlorophenol/creosote tests as shown in Tables8.2 and 8.3. Note that the DRE's for pentachlorophenol,which is more difficult to destroy than any of the PCB iso-mers, based on the incinerability hierarchy, were in excessof 99.9999%. A summary of the Florida Steel PCB testresults are presented in Table 8.4. These test resultsdemonstrate1that the Shirco technology can meet the TSCArequirements for PCB incineration and reduce PCB con-centrations in treated soils and sludges to non-hazardouslevels.
'*; ShircoP'a-- infrared
><>'• SystemsI n c o r p o r a t e d
SUMMARY OF PERFORMANCE DATA
ON-SITE INCINERATION TESTING ON SHIRCOPORTABLE PILOT TEST UNIT
TIMES BEACH DIOXIN RESEARCH FACILITYTIMES BEACH, MISSOURI
During the period of July 8-12, 1985, the Shirco Infrared Systems Portable Pilot Test Unit was inoperation at the Times Beach Dioxin Research Facility operated by the Missouri Department ofNatural Resources (DNR). The purpose of the testing was to demonstrate the Shirco technology'scapability to successfully decontaminate soil laden with 2, 3, 7, 8, tetrachloro-dibenzo-p-dioxin(TCDD). Equipment set-up, preliminary operation, test operation, decontamination, and equipmentremoval were performed in this period. Operation of the furnace and discharge streams wasaccomplished on July 10 and 11. The DNR Environmental Division coordinated the site prepara-tion. Emissions sampling and final analysis was performed by Environmental Research &Technology, Inc. (ERT) while laboratory analysis of the emissions and soil samples was performedby Roy F. Weston, Inc. Shirco Infrared Systems prepared the test protocol and operated thefurnace system.
Results of the testing performed by Shirco Infrared Systems using the Portable Test Unit haveproven the infrared process and technology to be a successful method of decontaminating thedioxin-laden soil present at Times Beach, Missouri. Presented below is a summary of the results ofthe testing performed. An expanded report may be obtained from Shirco Infrared Systems, Inc.,1195 Empire Central, Dallas, Texas 75247-4301, (214) 630-7511.
TABLE 8.1TEST RESULTS SUMMARY
EPASTANDARD
30 MINUTERESIDENCE
15 MINUTERESIDENCE
Composite feed soil2, 3, 7, 8 TCDD Concentration 227 ppb 156 ppb
Composite discharge soil2, 3, 7, 8 TCDD Concentration
Particulate emissions at 7% 02
Gas phase ORE of 2, 3, 7, 8 TCDD
<J1 ppb
.08 gr/dscf
& 99.9999%
Not detectedat 38 ppt
0.001 gr/dscf
\> 99.999996%
Not detectedat 33 ppt
0.0002 gr/dscf
> 99.999989%
; Sh/rco>*• Infrared>*• Systems
/ n c o r p o r a t e d
TABLE 8.2ON-SITE PILOT TEST RESULT
WOOD PRESERVING WASTE
POHC DESTRUCTION AND REMOVAL EFFICIENCY
TEST1
Afterburner Temperature: 2200°F
TEST 2
Afterburner Temperature: 1800°F
Cc mpound
Acenapthene
Anthracene
Benzo (a) anthracene
Carbazole
Chrysene
Fluoranthene
Fluorene
Penthachlorophenol
Phenanthrene
Pyrene
WasteConcentration
(ppm)
1.700
4.600
470
2,700
720
4,000
2,400
12,000
8.000
2.200
Flue GasORE
> 99.99996
> 99.99998
t> 99.99985
> 99.99997
> 99.99990
> 99.99998
O 99.99997
> 99.99999
99.99998
> 99.99997
WasteConcentration
(ppm)
4,200
11.000
1.300
5.400
2,200
14.000
4.600
11.000
22,000
7,400
Flue GasORE
> 99.99996
> 99.99998
t> 99.99998
> 99.99997
> 99.99993
99.99997
> 99.99997
t> 99.99998
99.99996
> 99.99998
ShlrcoInfraredSystems
I n c o r p o r a t e d
TABLE 8.3ON-SITE PILOT TEST RESULT
WOOD PRESERVING WASTE
ASH QUALITY
TEST1
Primary Chamber Temperature: 1650°FSolid Phase Residence Time: 15 min.
TEST 2
Primary Chamber Temperature: 1650°FSolid Phase Residence Time: 25 min.
Compound
Acenapthene
Anthracene
Benzo (a) anthracene
Carbazole
Chrysene
Fluoranthene
Fluorene
Penthachlorophenol
Phenanthrene
Pyrene
WasteConcentration
(ppm)
AshConcentration
(ppb)
WasteConcentration
(ppm)
AshConcentration
(PPb)
1,700
4.600
470
2,700
720
4.000
2.400
12.000
8.000
2.200
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4.200
11.000
1.300
5,400
2,200
14.000
4.600
11.000
22.000
7.400
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND = Not detected at an average detection limit of 30 ppb.
J; Shlrco;•• Infrared*: Systems
I n c o r p o r a t e d
TABLE 8.4PCB CONTAMINATED SOIL
DEMONSTRATION TEST SUMMARY
TEST
OPERATING PARAMETERS:
Average Process Temp. (°F)
Average Oxygen (%)
Particulate Cone. @ 7% 02 (gr/dscf)*
Waste Feed Rate (Ib/hr)
PCB Concentration (ppm) Feed
Ash"
Destruction and Removal (%)
1603
12.20
0.055
61.5
2790
ND
!> 99.9999
1573
8.58
0.023
61.5
2560
ND
t> 99.99992
1471
9.49
0.017
79.8
2840
ND
0 99.99991
* Federal Standard .08 (gr/dscf)
** Not Detectable at 5 ppb
9.0 OPERATIONAL PLAN
This section presents the operational plan which will befollowed for equipment setup at the site, start-up, normalshutdown, and Emergency Shutdown Procedures. A sample oper-ations data log sheet is presented in Figure 9.1.
9. 1 Portable Unit Setup
1. Chalk and level the trailer.
2. Connect 480V/60hz 175 amp supply wire to the Heat-ing Element Power Center (HEPC) distributionpanel.
3. Connect 120V/60hz 20 amp supply wire to the heaterterminal panel if weather requires trailer heat-ing.
4. Loosen the transformer mounting in the heatingelement power centers which were secured fortransport.
5. Connect a 1-inch supply water line capable of 20gpm at 25 tp 30 pounds per square inch (psi) tothe scrubber connection through the bottom of thetrailer.
6. Connect a 1-inch drain line to the scrubber con-nection through the wall of the trailer.
7. Install heating elements in furnace and lightbulbs in the trailer.
8. Replace the temperature recorder, timers, andrelays removed for transport.
9. Install exhaust stack.*
10. Assure the scrubber shutdown drain port isplugged.
11. Using a flashlight, inspect the thermocouple (T/C)protection tubes (if applicable) for breakage dur-ing transport. If any are broken, disconnect theT/C and allow the tube to be carried by the fur-nace belt to the discharge chute. If a corrosivematerial is to be processed, have the broken tubesreplaced.
12. Inspect combustion and exhaust blowers for trans-port damage and wheel blockage.
13. Connect a propane gas source with regulator to thesecondary combustion chamber burner supply line atthe right side of the trailer. The source shouldbe 20-gallon capacity minimum. Normally theburner will use 1.3 gallons per hour.
14. Inspect material feed inlet for obstructions, andopen the feed gate *-.o give a 1/8 inch gap betweenit and the furnace belt.
15. Check all furnace and HEPC electrical connectionsfor tightness. Also verify power wires to theHEPCs are undamaged from shipping or overheating.
16. Assure the belt tensioning device is moving freelyand the belt is centered in the furnace.
17. Assure all furnace and exhaust duct access portsare secure.
18. Verify the ash collection hopper is clean.
19. Assure all wireway covers are secure.
20. Measure the incoming voltage to the HEPC distribu-tion panel, and connect the incoming power to eachHEPC continuing to the appropriate primary tap.Magnetics drawing KD-4470-2 presents the primarytap voltages. The tap used should be that closestto the measured voltage.
9.2 Test Unit Startup
The following procedure will produce an automatic startupof the furnace system and prepare it to process material:
1. Switch the system main breaker at the power dis-tribution panel to the "ON" position.
2. Switch the breaker handles on the Zone A and BHEPC to the "ON" or "UP" position.
3. In the breaker cabinet doors, switch the followingbreakers to the "ON" position.
- Scrubber exhaust blower
- Furnace primary and secondary chamber combustionair blower
- Furnace belt drive
- wireway cooling drive blowers
4. Open the secondary combustion chamber fuel valveone-third. Solenoid valves upstream will openwhen the furnace temperature reaches 400 degreesFahrenheit.
5. Adjust furnace belt speed control on the EURODRIVEto 50 percent.
6. Press "Control Panel Power" to the "ON11 position.This provides power to the control circuitry only.
7. Turn on the following components to assure theircorrect operation. Turn each "Hand-off-Automatic"(HOA) switch individually to "Hand."
- Furnace beltCombustion air blowerExhaust gas blowerScrubber water pump
8. Turn all the HOA switches to the "Auto" position,including:
- Furnace belt- Zone A HEPC- Zone B HEPC
Wireway cooling blowersSecondary combustion chamber HEPC (if used)
- Scrubber water pump (Quench water)- Secondary combustion chamber burner (if used)- Combustion air blower— Exhaust gas blower
9. Set temperature set points as follows:
- Primary furnace chamber Zone A - 1600 degreesFahrenheit
- Primary furnace chamber Zone B - 1600 degreesFahrenheit
- Second combustion chamber - 1800 degreesFahrenheit
10. Close all primary furnace combustion air jets andthe main damper.
11. Open the secondary combustion air damper one-half.
12. Press furnace power "ON" button.
At this time, the furnace begins a heat-up cycle.The operator should inspect to see that the fol-lowing are "ON" and operating correctly:
Furnace belt- Zone A - HEPC- Zone B - HEPC
Wireway cooling blower
When either the Zone A or Zone B temperaturereaches 400 degrees Fahrenheit, the followingoccurs:
- Furnace exhaust blower turns "ON"Combustion air blower turns"ON"After a 2-minute purge, the pilot, then theburner lights to the SCC.Scrubber water
13. Adjust the exhaust blower damper and the scrubberwater and the secondary combustion chamber combus-tion air blower to maintain a zero pressure in thefurnace and adequate exhaust from the afterburner.
14. Adjust the burner input gas as required to main-tain the desired secondary combustion chamber tem-perature .
15. When the primary furnace temperature has reached 1400 degrees Fahrenheit in Zone A, the operator maycommence feed.
9.3 Normal Shutdown Procedures
To initiate a normal shutdown of the Portable Unit, thefollowing sequence is used:
1. Feed hopper empty2. All product off belt3. Gas burner switch off4. HEPC Secondary Combustion Chamber off (if applicable)5. HEPC Zone B off6. HEPC Zone A off7. Feed motor off8. HEPC Zone A Disconnect Off9. HEPC Zone B Disconnect Off10. Propane bottle valve closed11. Loosen belt tension
Allow unit to cool down slowly from operating temperature to1100 F. Utilize the final control settings used duringoperation to assure a slow rate of cooling.
When the furnace temperature reaches 1100°F:
12. Open combustion air gates to primary chamber13. Balance draft throughout system to -0.015 inch we in
furnace14. Loosen belt tension
When the furnace temperature reaches 800°F:
15. Open site glasses on furnace16. Remove cover on feed hopper17. Open afterburner damper fully18. Maximize flow through venturi19. Loosen belt tension
When the furnace temperature reaches 400°F:
20. Recirculation pump off21. Feed conveyor off22. Exhaust blower off23. Combustion blower off24. Furnace belt off25. Furnace control power off26. Panel control power off27. Main power disconnect off28. Drain stack condensate29. Slowdown scrubber water30. Leave trailer fan on31. Trailer lights off32. Secure trailer doors33. Secure discharged product in waste storage facility
9.4 Emergency Shutdown Procedures
1. Sound Evacuation Alarm2. Main power disconnect into "off" position.3. Exit trailer4. Activate Safety Plan Section 6.0.
10. PUBLIC INVOLVEMENT
Shirco Infrared Systems strongly supports public involvementboth in the permitting process and during the planning andtesting phases of all research and demonstration projects.Shirco is uniquely able to participate in equipment and pro-cess demonstrations due to the existence of its mobiledemonstration unit. In addition, other test facilities areavailable at Shircos Dallas, Texas, headquarters where small(100 grams or greater) samples of waste materials can beanalyzed for material response to thermal treatment. Inthis manner, several questions/issues of concern to communi-ties, individuals, and other interests can be addressedprior to the presence of on-site research and demonstrationtesting.
Shirco respects the right of individuals and communities tohave concerns about the safety and environmental impacts ofon-site thermal treatment. Shirco believes that itspatented infrared process offers a degree of safety andeffectiveness exceeding what is available from other exist-ing technologies; and, is fully ready to demonstrate this inthe openness of an active public involvement program.
Shirco operates within the following guidelines when partic-ipating in public involvement activities:
1) Shirco will work with designated public involvementcoordinators. Shirco will not manage the publicinvolvement process as this may be viewed as biasing thedemonstration process.
2) Shirco will work with officials of both government andprivate party clients.
3) Shirco will provide printed informational literatureincluding equipment and process descriptions, testresults, test specific data and plans. In addition,slides and audio-visual tapes -are available uponrequest.
4) Shirco personnel are normally available to attend publicmeetings, other organized informational workshops, andconferences held for technology oriented purposes.
5) Shirco employs a full-time Communications Coordinatorwho serves as a focal point for public involvementactivities. This individual is Mr. Ralph Morrison(telephone number 214/630-7511).
11.0 CLOSURE PLAN
11.0 Introduction
Closure procedures will be the responsibility ofShirco's test coordinator and the clients' representa-tive on-site. The three areas involved in closing asite are:
j o Decontamination of Portable Demonstration Unitij o Site clean-up activities relating to Shirco's? Portable Demonstration Unit
% \& o Relinquishing responsibility of on-site wastes
j 11.1 Decontamination of Portable Demonstration Unitji| Decontamination activities commence after the finalj demonstration condition is complete. With no feedj entering the primary chamber, the primary chamber tem-J perature will be held at 1600°F and the secondary
chamber temperature will be at 1800°F for a minimumof four hours. During this four-hour "bakeout," all
j residual hazardous compounds accumulated inside thei furnace will be destroyed.
•i Decontamination of the trailer and outside skin of the! furnace system will be performed on a thick plastic] sheet-. The plastic sheet will entrap all the liquid] „_ ^ and solid wastes which all will be displace while
cleaning. The cleaning procedures will consist of asoap and water scrub followed by a high pressure steamrinse. The trailer will be sloped so the decontamina-tion waters will channel out through the back doorswith collection in a sump. Visual inspection of thetrailer will confirm the decontamination process suc-cessful, releasing the trailer to a "clean" area fordrying.
The support equipment used during the demonstrationthat was contaminated will then be placed on the thickplastic sheet and decontaminated following the samesequence used in decontaminating the trailer's sur-faces. Following a confirming visual inspection, the
3 support equipment will be moved into a clean area for| dryi"7. Examples of support equipment: shovels,
propane burner hose, stairs, etc.
11.2 Site Clean-Up Procedures
All containers containing hazardous or potentiallyhazardous compounds will be relinquished to theclient. Shirco will secure, clean the outsides of anyvisual waste, and label each container. Shirco chainof custody forms relinquishing Shirco's responsibilityof any wastes will be kept with the job file under thetest coordinator's custody.
11.3 Waste and Waste Residues
Shirco's shift of site responsibility will be completewith the signing of the job file by Shirco's TestCoordinator and the client's representative personnel.The signing of the job file will act as a binder ofShirco's relinquishing responsibility of on-site test-ing for specific wastes at a specific waste location.
APPENDIX A
Process and Instrumentation Diagrams
and Portable Pilot Layout Diagrams
