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Gossman Consulting, Inc.

Gossman Consulting, Inc.


Organic Emissions

- 99.99% DRE on POHCs.

- 99.9999% DRE on POHCs if dioxin listed wastes are burned.

- CO limit of 100 ppm @ 7% O2.


- A combined hydrocarbon limit of 20 ppm @ 7% O2 and a CO limit established during the compliance testing.


- An alternative hydrocarbon and CO limit for kilns with organics in raw materials based on baseline testing that includes substantial testing to identify organic emissions and perform risk analyses. Kilns with an alkali by-pass are not eligible for this option.

- The 20 ppm hydrocarbon limit is mandatory for kilns feeding at other than the hot end, except perhaps under a Part B permit. It will then be up to the permit writer.

- Kilns that have ESPs or baghouses with entrance temperatures of 450 F - 750 F must perform emission tests for dioxins and dibenzofurans as well as associated risk analysis to verify that risk based limits are met.

Particulate emissions - .08 grains per dry standard cubic feet.

Metal emissions - plant by plant risk based limits.

- Non-carcinogenic metals - individually controlled - includes antimony (Sb), barium (Ba), lead (Pb), mercury (Hg), thallium (Tl), and silver (Ag).

- Carcinogenic metals - controlled on a weighted average basis - arsenic (As), beryllium (Be), cadmium (Cd) and chromium (Cr).

- Tier I limits assume all metals entering both with waste and raw materials, will be emitted.

- Tier II limits allows stack testing to verify capture efficiencies, but assumes a worst case dispersion model.

- Tier III limits allows stack testing and site specific dispersion modeling to establish risk based limits.

- Chromium is assumed to be 100% hexavalent chromium unless a provided hexavalent specific stack test is performed.

HCl and Cl2 emissions - plant by plant risk based limits.

- Tier I, II and III risk based limits like those previously described for metals.


Requirements to be met at or before the effective date of the rule (August 21, 1991).

"In existence" test must be met -- either burning or construction of ancillary facilities has commenced.

Part A or modified Part A documents must be filed.

Compliance with Part 265 standards including new Air Emission Standards (sub-part BB).

For kilns burning hazardous waste at other than the hot end of the kiln, gas temperatures must be verified as 1800 F at the point of hazardous waste introduction unless the waste is an "ingredient".

- An "ingredient" is:

a) 5,000 BTUs/lb.

b) 500 ppm total organics listed in part 261 Appendix VIII.

For kilns burning hazardous waste at other than the hot end of the kiln, a system must be in place to verify that adequate oxygen is present to insure complete combustion. This documentation must be included in the facility record.

Direct firing of hazardous waste into a precalciner or any point other than in the kiln is prohibited unless the waste is an "ingredient".

Certification of pre-compliance. This certification of pre-compliance will likely require:

- Comprehensive metal, ash, and chlorine determinations on all feed streams.

- Estimated removal efficiencies for the above parameters.

- A completed dispersion analysis (Tier III).

- Comprehensive metal concentration data on kiln dust.

Establishment of feed rate limits on the following parameters:

These became operating limits.

- Hazardous Waste

- Metals in total feed streams, except for kilns recycling dust where special metals in dust monitoring program is optional.

- Metals in hazardous waste feed.

- Total feed rate of chlorine and chloride in total feed streams.

Limits on maximum clinker production rate.

This becomes an operating limit.

Continuous monitoring of the above limits via feed stream concentration and flowrate rate determinations.

Public notice of hazardous waste fuel burning activity.


No direct transfer is allowed from an open top container.

Direct transfer equipment must be closed.

Spill prevention controls such as check valves are required.

Automatic waste fuel cutoff systems are required if a spill occurs from transfer equipment.

Secondary containment is required for tankers, containers and transfer equipment.

The system must be inspected hourly while in use and records of those inspections must be kept.


Testing must be completed prior to 18 months after promulgation, by August 21, 1992.

A notice of compliance testing must be submitted to the agency 30 days prior to testing.

Must include stack test data demonstrating compliance.

- The compliance test must be performed at maximum input rates of all parameters to be limited as a result of compliance testing, i.e., chlorine, metals, hazardous waste.

- The test must be conducted at maximum clinker production rates, maximum gas temperatures entering the baghouse or ESP, and maximum combustion zone temperature all of which subsequently become operating limits.

- For ESPs, the test must be conducted at minimum KVA to the precipitator plates and maximum gas flow rates both of which subsequently become operating limits.

- For baghouses, the test must be conducted at the minimum pressure drop which subsequently becomes the operating limit.

- Compliance testing must be performed for metal limits, HCl/Cl2 limits, particulate limits, CO and hydrocarbon limits.

- Compliance testing and risk analysis calculations must be performed on dioxins and dibenzofurans if gasses entering ESPs or baghouses fall within the range of 450 F - 750 F.

- Test must be performed in each operating mode of the kiln.

Must also include miscellaneous information, such as facility description, dates, times, contact names, etc.

The completed certification of compliance testing with results of stack testing and operating limits, as mentioned above, must be submitted within 90 days after the testing is completed.

Comprehensive recertification must be conducted and submitted within 3 years after submitting the prior certification.


(A) A series of 10 stack tests for metals over 14 days must be performed to produce enrichment factors relative to metal concentrations in kiln dust. Once enrichment factors are determined, CKD samples must be taken every 8 hours, composited into daily samples and analyzed for metals within 48 hours. This data is then compared to a series of statistically determined limits based on the test burn results. This same procedure must be followed prior to compliance testing based on estimated enrichment factors. Subsequent to the compliance test, quarterly stack tests to verify the enrichment factors must be performed.


(B) Stack emission testing must be performed for six hours every day while burning hazardous waste. This option does not require compliance testing and would be applicable under interim status both before and after compliance testing.


(C) Stack emission testing must be performed during the compliance test only after steady state conditions have been reached with respect to metal emissions. Under this option, both before and after compliance testing, all feed streams into the kiln must be monitored for metals with sufficient frequency to prevent violation of metal feed limits previously established.


Test CKD while burning maximum levels (fuel rate) and concentrations of metals in hazardous waste, for metals, Appendix VIII, part 266, constituents and Appendix VIII, part 261, constituents which might be in the fuel.

If measured levels exceed health based standards listed in Appendixes VII and VIII of part 266, then perform baseline testing of CKD while not burning hazardous waste in order to make a statistical comparison.

Records demonstrating that CKD is not significantly affected by hazardous waste burning must be maintained for 3 years.