JUC'l ii£ 'yc. Lia:4b vt-RlH U'lL LUI-I I KHL i s. ^aiu r . l

IHCMESWIOH, OK

TAC SITE•RACTORS

hini VentureK ENVIRONMENTAL

SERVICES. INC.

DATE: ^- ^^-^^——

FACSIMILE TRANSMISSION

********************* ****************************************** A A*

TO; t^C^'r^.^ ^^L^^T'^___________

COMPANY: ________^/^4___________________________

ADDRESS t

PHONE N O . :FAX NO. :

FROM:COMPANY:ADDRESS;

^ / ^ Vi^p^' Z^.^^1^/VERTAC SITE CONTRACTORS

1302 North Marshall RoadPost Office Box 547Jacksonville, AR 72076

PHONE N O . :FAX NO. :

501/985-1514501/985-1917

NOTES;

TOTAL NUMBER OF PAGES SENT INCLUDING THIS COVER SHEET: ,_^_If you do not receive all pages in good condition, call us at(501) 985-1514.

P.O. Box 547, Jacksonville, Arkansas 72076 .Tel, (501) 985-1514. Fax (501) 985-1917

uUll L-L- -'.- U-'--t0 vl-rsin^.

OTATE OF ARKANSASDEPARTMENT OF POLLUTION CONTROL AND ECOLOGY

80(11 N A T I O N A L D R I V C , P .O. BOX 9913L I T T L E R O C K , A R K A N S A S ?32l9-8»U

PHONE: (501) f62.6f33FAX: (501) 5<2-4<>32

CERTIFIED MAIL ? »05 077 716June 19/ 1992Mr. Robert ApaSite ManagerVertac Site ContractorsP . O . Box 547Jacksonville, AR 72076RB; PRETSEATMENT OF D-WABTEDear Mr. Apa; 09Your information update of June 1 9 , 1 9 9 2 , is incorrect regarding the date^ofyour request for pretreatment. This request was actually dated June ^,1992i and not June 1, 1992, We received that request on June 16, 1992.^1had told you by phone that we would have to have review time for this roattQ-.It is unfortunate, but this appears to be another last minute crisis that teasresulted in VSC threatening another shut down.This self imposed shut down will not be a basis for stand by payment to VSC.It is very inappropriate for vsc to shutdown to avoid operating in a modethat it hafi done for months in tha past. suddenly/ this historic operatingmode must be changed for VSC to restart incineration, and VSC expects us toapprove this change without data necessary for reviewing it. VSC isauthorized to continue incineration as it has done in the past.The proposed change appears on the face of it to be a good proposal, but wecan not change it without knowledge of potential for safety hazards orregulatory compliance. Mark McC&rkle notified V5C of this need forinformation by phone on June 18, 1992.Sincerely,

Jerry Williams/ PEManager Technical BranchHazardous Waste Divisioncc: Wilson Tolefree, Deputy Director, ADPC&E

Mike Bates, Chief, HWDMark McCorkle, Engineer 11^ Air Division

vt-RlHL O.LIL i uli I KM^ I o. i^aalu r.o

STATE OP ARKANSASDEPARTMENT OF POLLUTION CONTROL AND ECOLOGY

8001 NATIONAL D R I V E , P .O. BOX 8913LITTtfi ROCK, A R K A N S A S 72219-8913

PHONE; ( 3 0 1 ) 562.7444F A X ; (501) 562-402

June 1$, 1992

M r . Robert P. Apa, site ManagerVertac Site ContractorsP . O . Box 547Jacksonville, AR 72076Re: Proposed Waste Solidification

YOUC Letter of June 15, 1992

Dear Mr. Apa:In the above-referenced letter, you indicated that VSC intended r"-to initiate a waste solidification strategy that would involve 0adding bags of lime to the waste being shredded. This would 3-presumably make the waste exiting the shredder easier to manage. QThis conditioning of the material would presumably reduce thepotential for workplace exposure to waste constituents byreducing the frequency of conveyor and feed system maintenanceand cleanup activities.The Departing; agrees with VSC's belief that this might result inimproved performance of the feed system but cannot approve thedescribed modification without additional information beingsubmitted and reviewed. Should you desire to pursue this statedintent> you must provide the following:An indication as to whether the lime to be added is carbonated orhydrated,An indication of the purity of the lime and the percentages o£identified impurities.while VSC has suggested that lime would be added to the wastewith a resulting mixture containing 5-7% lime, it is alsoindicated tha'c, based on operating experience, lime might beadded at higher ratios. An indication of the maximum proposedlime content is required. An estimate of the increase in ashvolume generated should also be provided.VSC has indicated that the lisne would be added to the drummedmaterial as it entered the shredder system. VSC has alsoindicated that, in pilot testing, "the lime/sludge mixturereacted within 5 minutes". VSC must provide informationregarding the reaction that took place between the lime and thewast®. If this is an exothermic reaction, the potential for

June 19, 1992 2

Mr. Hobert P. Apa/ Site ManagerVertac Site Contractors

heating of the waste, and subsequent potential for volatilizingorganics that might be present in the waste must be discussed.There is no indication that VSC's pilot tests were designed todetermine these potentials. If these potentials appearsignificant, a series of tests designed to determine the averagereaction rate, heating potential, and offgas composition andvolume should be proposed. If the results of these tests,indicate the need, VSC will be required to demonstrate, by reviewof the design and operation of all af fected equipment, that theaddition of the lime to the waste in the shredder will not exceedthe design capacity of the fire and explosion prevention andprotection systems that are in place.

-~—'

VSC fflust provide written standard operating procedures, including 00contingency measures, for this practice. For example, if a 0maintenance activity required access fco the shredder before the . f-aixing and &olidification steps were completed, it night be ^necessary to take extra precautions. —

VSC's implementation of this proposed procedure is subject to theDepartment's discretion. VSC is not authorized to implement thisprocedure until such time as the writ ten approval of theDepartment is obtained. Please provide an indication of VSC'sintent at your earliest convenience.

Sincerely,

Mark McCorkleEngineer, Air Division

cc; Wilson TolefreeJerry WilliamsJohn GilletteRick Ehrhact - USEPA

JUi'1 Ctl 3t- da-40 '»'t_KIML ol.i.L ^UMI M-H-i o . i oHJ

-/INONEAAT10N. INC.

'AC SITE.CTORS

Ve/itwf, ENVIRONMENTALKAVICES. INC.

June 22, 1992

Arkansas Department ofPollution Control and EcologyPost Office Box 8913Little Rock, AR 72219-8913

S/N; VSC/ADPCE-0210

Attention: Mark McCorkleSubject: Vertac Site Thermal Destruction Contract 3810

Request for InformationADPC&E Letter of June 19, 1992Dear Mr. McCorkle;

CO0•

;

-oAttached to this letter is the information which the Department has Qrequested prior to allowing VSC to implement waste pretreatmentwith lime. Please contact me if you have questions or requirefurther information.Sincerely,Vertac Site Contractors

Robert P. ApaSite ManagerRPA/smAttachmentscc: Wilson TolefreeJerry WilliamsJohn GilletteRichard Ehrhart, US EPA

P.O. Pox 547, Jacksonville, Arkansas 72076 . Td. (501) 985-1514. Fax (501) 985-1917

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^ ^

LIME

Product: Calcium Hydroxide or Hydrated Lime

Formula; Ca (OH)^

Components;

Calcium Hydroxide: Ca(OH);

Magnesium Hydroxide Mg(OH)^

Calciua Sulphate CaSO^

Calcium Carbonate CaCO,

silicon Dioxide siOz

"Ferric Oxide FSaOa

A ) iJ i."'. .vm Oxide Al^O,

sulphur Trioxide 303

Carbon Dioxide CO^

Mechanical Moisture HaO

Arsenic As

Fluorine F

Lead Pb

95.0%

0.26t

0.02%

1.40t

0.60%

0.05%

0.24%

0.01%

0.70%

0.60%

0 - 1 ppffi

40 - 70 ppffi

1 - 5 ppm

NOTE: The potential amounts of arsenic and lead are abovedelisting requirements. The present kiln ash and salt isnot delistable due to heavy metals currently found in thewaste*

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PROPOSED MIXINGAMOUNT/REACTION

Anticipated Mixing:Observations:

A 5-7% wt line mixtures produced a solid material withminimal amount of residual liquids*A 10% wt lime mixture produced a solid material with somestrength and no free liquids.A 15% wt lime mixture produced a solid material with morestrength than the 10% and no free liquids. r i

ooObjective: 0,To produce a material easier to handle with the least ^amount of additive. 0

Initial Operation: 0Addition of lime in the 5% wt range. Based on averagebarrel weight after removal of liquids this will requirethe addition of approximately 25 Ibs of lime per barrelto the shredderIf the above percentage does not produce a firm enoughproduct, the next step will b® to increase lime rate to35 Ibs per barrel or approximately 7% wt.If material continues to exhibit a quantity of freeliquids, the next step will be to increase lime rate to50 Ibs per barrel or approximately 10% wt.

Maximum Ratio:At present a maximum amount of 10% wt lime isanticipated.

Ash Volume Increase:Normal High Calcium lime has a bulk density between 25-35Ib/cu ft. Using the lowest bulk density:5% wt - volume increase of feed by 1 cu ft per barrel7% wt - volume increase of feed by 1.4 cu ft per barrel10 % wt - volume increase of feed by 2 . 0 cu ft perbarrelBased on the assumption that all of the calcium remainsin the kiln ash and the volume of the reacted material issimilar to that of the calcium hydroxide, the increase inkiln ash will correspond directly to the increase in feed

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volume. At the current average of 4 barrel per hour,this will amount to 4 cu ft per hour when feeding 51 wtof lime. This corresponds to approximately half a barrelper hour of additional kiln ash.

Laboratory Findings:VSC conducted a series of tests to determine the heat release whichoccurs when the line is added. The following table indicates theamount of temperature increase.

Sample

ID

A-5

B-5

C-5

D-5

E-5

A-10

B-10

C-10

D-10

E-10

1

+2

+2

+3

+6.2

+6

+5

+4

+4

+2

+4

Tempi

Min

.6

.3

.5

.4

.0

.5

.4

.1

.6

Brature

2 Min

+1.2

+0.1

+0.5

+0.7

+0.6

+1.5

+1.4

+1.2

+1.7

+3.2

Change i3 Min

+0.3

+0.6

+0.4

+0.3

+0.3

+0.5

+0.6

+0.4

+1.4

+1.2

n Degree

4 Min

-0.1

+0.1

+0.3

+0.1

-0.2

+0.2

+0.6

+0.8

+0.4

+0.2

t c From

5 Min

-0.1

-0.2

+0.2

-0.1

0.0

-0.2

+0.2

+0.2

+0.2

+0.2

Previous

10 Min

-1.0

-0.4

-0.5

-0.5

-0.6

-1.4

-0.4

-0.6

-0.6

-0.4

Reading

20 Min

•"0.7 CO

-0.9 °^

-1.0 00

-1.2

-1.2

-2.0

-1.6

-0.2

-2.0

-2.2

Potential for Volatilization of Organics:The maximum observed increase in temperature was 6.4°C orapproximately 11.5°F, While any increase in temperature will producesome additional volatilization of organics, it is felt that thisamount of increase is minimal and will not produce excessivevolatilization. The drums will have been super suclced prior to theaddition of lime, that is, as much free liquids vill have been removedas possible. In addition, a large volume of material is not beingmixed at any one tine. The shredder system is set up such that onlyone barrel at a time may be shredded. The barrel added to theshredder must be processed completely before another barrel can beadded to the system.

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Based on the low heat release, VSC has not preformed additional teststo quantify actual quantities of volatilization that may occur. Theamount of volume of material added to the shredder will beapproximately 7.5 cu ft. This is into a primary shredder volume of325 cu ft. The laboratory technician who mixed the lime and waste didnot observe a violent reaction, there was no bubbling or visibleescaping of gases. Based on this observation and the large ratiobetween waste volume and shredder volume, there is not expected to bea measurable amount of pressure increase in the shredder duringmixing.The shredder is purged with Nitrogen gas prior to any shreddingaction. The Nitrogen purge should prevent ignition of any flammablematerial. The shredder is also equipped with a halon fire suppressionsystem.There are explosion panels on the shredder. These are located at thetop of the shredder and will direct any pressure excursion upwards, LHThe building is vented to the kiln and the afterburner. Any gases ooproduced from a reaction which escaped into the building would be Qdiluted and then drawn into the kiln or afterburner. The building isan exclusion zone where personnel are on demand air at all times,therefor the personnel would not be exposed to additional fumes in °case of a violent release. 0Based on the above reasons VSC believes that the potential forsignificant volatilization is minimal.

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SOP NO. VSC-0407 DATE 06/22/92REV. NO. ___________ DATE________

CHANGE NO. __________ DATE.PAGE 5

WASTE PRETREATMEMT WITH LIME

PurposeThe purpose of this standard operating procedure is to establish theprotocol to be followed when pretreating waste. The procedure alsoidentifies the actions to be taken for entry into the shredder shouldmaintenance be required with a lime/waste mixture in the shredder*

0COResponsibilities ^

The Operations Coordinator or his designee will be responsible fordetermining the quantity of line to be added when premixing the waste0The supervisor of the Drum Handling Building will be responsible forinsuring that the proper amount of material is used. The laborerresponsible tor the elevator/shredder operation will insure that therequired amount of material is used.

Should entry into the shredder be required when there is a mixture oflime and waste in the shredder, the Manager of Health and Safety or hisdesignee will conduct a safety review meeting with particular emphasison the required actions as detailed in this procedure.

ProcedureA. Mixing Ratio

1. The initial amount of premixing will initially be in the5% by weight range. The average barrel of waste feed tothe shredder after super sucking weighs approximately 500Ibs. Therefore 25 Ibs of lime will be the initial amountfed per barrel.

2. Should the initial ratio of lime to waste not produce thedesired reduction in liquid waste or produce a wastemixture which is controllable, the ratio of lime added to

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^

SOP NO. VSC-0407 DATE 06/22/92REV. NO. __________ DATE_______

CHANGE NO. _________. DATEPAGE 6

each barrel may be increased by the OperationsCoordinator or his designee.

NOTE: Any increase in ratio beyond 10% wt must receiveprior approval.

B. Lime PreparationThe lime may be in either 50 Ib sacks or in bulk. The limeT"will be placed into paper sacks which will permit insertion o£-the lime with the barrels into the shredder. Based on the -fact that the lime received is commercial grade and the bull?density should not vary dramatically, the lime will be place<Pinto a bucket which is marked for the proper amount of lime.The bucket will have been weighed with the proper amount oflitte on a scale and the level marked.

Personnel preparing lime will dress in proper attire topreclude lime from contacting the skin or entering into therespiratory tract.1. For 5% wt ratio

a) Bagged lime1) Open the sack and remove half of the line2) Place the lime into the sacks provided

b) Bulk lime1) Remove the lime from the storage hopper and

place into a marked bucket*2) Place the lime into the sack provided.

2. For other ratiosa) Bagged lime

1) Open the sack and remove the required amountby dumping into a marked bucket.

JUM c.c- ''^l- a'^bU Vt-K'IHL silt- L.U111 RhiL i s. ' oiLi

SOP MO. VSC-0407 DATE 06/25/92REV. NO. __________ DATE________

CHANGE NO. __________ DATE,PAGE 7

2) Place the proper amount into the sackprovided.

b) Bulk line1) Remove the lime from the storage hopper and

place into a marked bucket.2) Place the proper amount into the sack

provided.c. Lime Mixing co

1. Primary Mixing c0

The lime will be mixed into the waste by the shredder,^This will be accomplished by placing the prepared bags ofolime onto the top of the barrel prior to it being sent up >the elevator. The primary shredder, which operates inthe chop mode, should achieve some mixing while choppingthe barrel and sack.

2. Reaction TimeThe secondary shredder will be programmed to receive thewaste/lime mixture while in the stationary mode. Theshredder will remain stationary for 5 minutes to allowthe reaction to occur. After 5 minutes the secondaryshredder will shred the premixed waste.

D. Waste ObservationWhen waste pretreatment is being performed, personnel shallobserve the final product and make necessary adjustments toinsure that a controllable product is being produced. Thebest measure of success should be observed by the consistencyof the material as viewed by the kiln auger camera. Thesecond observation will be the amount of liquid beingcollected in the solid system liquid collection system, excessliquid will require adjustments.

SOP NO. VSC-0407 DATE 06/22/92REV. NO. __________ DATE________

CHANGE NO. __________ DATE.PAGE 8

SAFETY PRECAUTIONSShould the shredder malfunction and require entry when there is lime andwaste material in the shredder, the following procedure must befollowed.

A. NotificationThe Drum Handling Building supervisor will notify theOperations Coordinator and the Manager of Health and. Safety ortheir designees. c

B. Safety Meeting CQ

A safety meeting will be held prior to the issuance of a^.vessel entry permit. This is standard procedure with a vessel 0entry permit, however the steps to be taken will be outlined0and explained to the personnel responsible for accessing theshredder.

c. Entry Procedure1. Lock Out/Tag Out

The Lock: Out/Tag Out procedure will be followed.2 . Access to shredder

a) The access door of the shredder shall be openedslowly.

b) Visual observation of the material in the shredderwill be made.1) If the lime and waste has not been mixed, then

as much lime as possible will be removedwithout disturbing the waste.

2) If the lime and waste has been mixed, as muchmixed material as possible will be removedfrom the shredder.

NOTE: The requirements for obtaining a vessel entry permit willhave permitted ample time for any mixture to react prior topersonnel opening the shredder.

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SOP MO. VSC-Q407 DATE 06/2^/92REV. HO. __________ DATE_______

CHANGE NO. __________ DATEPAGE 9

0. WarningPersonnel accessing and removing the material in the shredderwill be instructed to prevent, as much as possible, the mixingof any unreacted lime with waste. Should this mixing occurthen personnel involved in the removal will allow the materialto sit undisturbed for a minimum of 15 minutes. This shouldpermit any reaction to be completed and allow safe removal ofthe material. 0

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