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Cifc S!fSIOHS. Jrc.
Sub11itted t o:
J.S. Environmental Protection Agency, Region I JFK Building
Boston, HA 02203
A ention: Technical Contact, Hs . Pat Hynea (1 copy)
TR-693-24
TECHNICAL EVALUATION REPORT ON THE CANNON !NGINE!RlNG COKPAHT
Work A11igaent Report
Work A..iaaent No.: 081393
Work Aalisnaent Title : Technicd Support for Cannon Enain..ring Ca.pany Haza rdou a Waate Site
ICAIR Life Systems, Inc.
24755 Highpoint Road Cleveland , OH 44122
March 8 , 1985
"' Section 1. 0
1,1
1.2
Section 2 . 0
2.1
2.2
2,3
2 . 4
Section 3.0
3,1
3,2'---' 3.3
Section 4. 0
4.1
4.2
4.3
4.4
Appendices
TABLE OF CONTENTS
Introduction • •• , .•.• •.•.•••.•• •• •• • ••••.•
Purpose .• • .. ,, •..••••....• ••• •••.• ••• •...
Basis ••.••.••• • • , ••..•• • • • • • • , ..••••. . •••
Incineration System, Equipment and Operating Procedures •••••• •••• • • •• • ••••••
General ••• ••• ••• • • , ••••• •• ••• , ••• ••• •••• •
Incinerator Description •• •••• •••• ••• , • •••
Incinerator Chronology • • • • , •• ••• • • , •••• •• 10
Incinerator Operations. , • • • •• • , •• , ••• ••• , 1 2
Incinerated Materials • • •• •• • • •••• ,, •• ••• • 13
Initiel Perm! t . . .• , , •• , . ... , , •. , .. • . , • • , • 13
Operations Through 1978 •• • • •• , •• •••• •••• , 13
Operationa from January 1979 • • • •• ••• ••••• 14
Evaluations and Analysis •••• • •••• • •• • • ••• 17
Incinerator Design and Capabilities•••• • • 17
Waste Incinerability and Limitations •••• • 18
Evolution of Operations •••••• • •••• • • ••• •• 20
Generator Identification •••••••••• • •••••• 23
1.0
1.1
1.2
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Introduction
Purpose
In general , the objective of this report is to evaluate an incineration system located at a Cannons Engineering Company (CEC) site in Bridgewater, Massachusetts. Specific attention is required relative to the capabilities and limitations of this incinerator for burning various waste materials . Such evaluation is intended to assist the U.S.EPA in formulating enforcement strategies for delineating waste ge nerators potentially responsible for illegal disposal activi t ies.
Basis
This report is based upon the following:
a. Extensive data provided by the EPA, including Lab Books, Operating Logs, sample waste lists and mani fests, en9ineering dravings and specifications and a Site Hiatory prepared by TechLaw, Inc .
b. Data provided by Anne Rogers, Assistant Attorney General , including various Special Receiver Reports filed with the Courts .
c . Data noted and copied from two seta of files in the Massachusetts OEQE Offices in Lakeville, Massachusetts. One set dealt with Department of Air Quality Permitting, which was completed prior to Receivership, and one set dealt with Hazardous Waste activitiea, as compiled after Receivership.
d . CEC site inspection and observations on March 1, 1985.
e . Miscellaneous data obtained from CEC office (trailer ) files during March 1, 1985 site inspection .
f. Data and information obtained through various telephone discussions with :
Coen Company, Inc. , the incineration system designer and manufacturer.
David Gerety, the Plant Manager responsible for CEC inc inerator operations du r ing 1980 and 1981.
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John Winkler and Robert Donovan, CEQE personnel involved with CEC activities and retainers of the pre and post Receivership files.
Patricia Hynes and James Ciriello, EPA Region I.
-- Anne Rogers, Assistant Attorney General.
-- Marnie Collier, TechLaw, Inc.
Dr . Glenn Williams , who provided incineration system eva lua tions during Receivership, was contacted . However, he was unable to recall any s pecific event s or activities during this period , i ncl uding the August 1 , 1981 test burn .
Dr. Xathleen Swa llow , who provided analytical evaluations during Recei vership, could not be located .
2.0 Incineration System, Equipment and Oeerating Procedures
2.1 General
The incineration system, or incinerator, is located at a facility once used for the treatment, storage and disposal of hazardous wastes and vaate oil by the cannons Engineering Corporation (CEC). The facility is located in an industrial park on Firat Street, Bridgewater, Massachusetts . The facility vas identified as the "Cannons Cyclube Plant." The incinerator vas installed in 1974. The entire CEC operations, includin9 the incinerator, vere terminated in 1981, primarily because of indictments for illegal vaste disposal activities and enforcement actions under CERCLA and RCRA.
2.2 Incinerator Description
2.2 .1 General Description
The incinerator is 9enerally classified as a liquid injection (LI) type unit. It was desi9ned and constructed for burning high heating value liquids through burner guns and injecting low heatin9 value, or aqueous, liquids into the burner flame for destruction. Combustion 9ases passed through a horizontal combustion, or retention, chamber to the stack from which they were discharged directly into the atmosphere. The incinerator was equipped with controls and instrumentation devices for re9ulatin9 combustion conditions and providing safe operations.
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2. 2. 2 Detail Description
a. Manufacturer
The incinerator was designed, manufactured and installed by Coen Company, Inc., 1510 Rollins Road, Burlingame, California (Coen).
b. Model Number
The incinerator was designated by Coen as a "Special Purpose Liquid Waste Unit." It was provided under Coen Contract No. 1174.
The i ncinerator was generically termed a "Thermal Extractor" by Coen. Therefore, both "incinerator" and "thermal extractor" were used interchangeably in various correspondence.
c. Ratins and Capacity
The incinerator was rated for a thermal capacity of 75 million Btu' a per hour (MMBH).
The incinerator vas designed for firing waste oila with heating values ranging from 100 , 000 to 140,000 Btu's per gallon in a main burner gun. At a 75 MMBH rating, 100,000 Btu per gallon liquids could be fired at 12. 5 gallons per minute {GPM) or 750 gallons per hour {GPH) . The 140,000 Btu per gallon liquids could be fired at 8.9 GPM or 535 GPH.
The incinerator was also designed for injection of aqueous wastes into the main burner flame at a maximum rate of 5 GPM.
d. Main Burner System
The main burner system is a Coen Model No. 275 Fyr-Compak unit . This was basically a preengineered, shop assembled packaged burner with the following major components:
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One Coen No. 5 MA low pressure air atomizing waste oil burner gun:
This is an inside, or internal, mix type atomizer burner. Oil and atomizing air converge within an internal chamber and mixing is assisted via a Coen 11 spinner hub" assembly. The resultant oil/air mixture is injected into the combustion chamber through an atomizer noule. The nozzle was selected to inject an atomized oil to form a conical flame pattern .
Two coen No . 1 MA l ow pr essure air atomizing waste oil bur ner guns. These were i ns t a lled i n September 1980:
These are identical t o the Coen No . 5 MA burner , except each ha s about half the capacity for the equivalerit oi l and a i r s upply pressures. These were installed for burning 11clean" organics waste, or waste oil, and maintaining operating temperatures. The existing (Coen No . 5 MA) main burner was then intended to be used for burning 11 dirty 11
organic wastes.
Coen OAZ (Dual-Air-Zone)-30 circular air register:
The air register regulates the flow of combustion air through the burners a nd into the combustion chambe r .
The Coen air register system features two sets of concentric, opposed-bladed louvers, which are designed to maximize combustion turbulence, or mixing, as well a s control burner flame pattern , or shape.
Combustion air was supplied to t he register at about 8-in. water gauge (w.g . ). This pressure level would generally categorize the burner system as a low to medium pressure drop design .
e. Combustion Chamber
The combustion chamber is horizontally oriented and cylindrically shaped. The main burner system is located on the (front) end of the chamber. A primary purpose of this was to provide sufficient volume for combustion reactions to be completed under controlled
\:) conditions and before exiting the stack.
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The combustion chamber has an outside diameter (00) of about 8 feet, 7 inches and a total length of about 21 feet, 7 inches.
The front and rear ends (walls) have 12 inch linings of refractory. The side walls (or cylindrical sections) have 6 inch linings of refractory backed with 1. 5 inches of high temperature insulation.
The internal diameter (10) is about 7 feet, 6 inches and the overall, internal, length is about 19 feet, 6 inches. Total internal volume of the combustion chamber is approximately 860 cubic-feet.
f. Aqueous In1 ector Guns
These comprise four pressure atomizing nozzles, connected to a common header, for injecting aqueous wastes into the combustion chamber. Each nozzle is rated for delivering about 1.4 GPM with a liquid supply pressure of about 80 PSIG.
Before September 1980, the nozzles were located above the main burner, on the front end of the combustion chamber, and directed to fire approximately on the axial centerline of the combustion chamber.
In September 1 980, at the same time that the two No. 1 MA burners were added, the aqueous injector nozzles were relocated approximately to fire radially into the combustion chamber. They were located at about 7 feet from the front end of the chamber. Two nozzles fired horizontally on opposite aides of the chamber ( 90 degrees and 270 degrees), and two fired at 45 degrees from the top ( 45 degrees and 315 degrees). This modification was intended to provide better mixing and combustion of atomized aqueous droplets with less interference of the main burner flame.
The nozzle guns are connected with pneumatic cylinders for positioning them within the combustion chamber.
g. Forced Draft Fan
A Clarage Air Foil fan was provided for supplying combustion air to the burner windbox and air register. This fan was sized to deliver about 31,000 SCFM of air at 8-in. w.g.
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h. Forced Draft Fan Control Damper
A draft control damper was provided at the windbox connection from the forced draft fan. This was to control combustion air supply as waste oil heating values and firing rates varied during operations .
1 . Atomizing Air Blower
Atomizing air was supplied by a Schwitzer Model 4509 blower . This was sized to deliver about 575 SCFM of air at 15 PSIG,
j . Heavy Oil Pump and Heater Set
Heavy, or viscous, oil s were pumped from storage tank(s) to the burners by a Coen pump and heater set, Two DeLaval IMO pumps were provided and sized for Clelivering 12.5 GPM of oil at 150 PSIG. Steam heat exchangers were s ized for heating heavy oil to a viscosity of leas than 100 SSU. The set also includes a duplex auction strainer, pressure regulator and interconnecting piping, valves and fittings .
k. Light Oil PUIIp Set
Light , non-viscous oils were pumped from storage tank(s) to the burners by a Coen pump set. This comprises two OeLaval IMO pumps, each sized for delivering 12 .5 GPM of oil at 150 PSIG, a duplex auction strainer, pressure requlator and interconnecting piping, valves and fitt i ngs.
1. Aqueous Pump Set
Aqueous wastes were pumped from storage tank(s) to the aqueous injector nozzles by a Coen pump set . This comprises two OeLaval centrifugal pumps, each sized for delivering 5 GPM at 100 PSIG, a duplex suction strainer, pressure regulator and interconnecting piping, valves and fittings.
m. ~
The stack is located at the top, rear end of the combustion chamber. The original stack was about 30 feet high and had a top elevation of about 40 feet above grade. In September 1979, approximately 13 feet of additional stack were added.
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The original stack section has an 00 of about 7 feet and an ID of ~ about 6 feet. The stack extension section has an OD of about 5 feet, 6 inches and an 10 of about 4 feet, 6 inches . The original and extension sections both have refractory linings of about 6 inches.
Three guy wire cables are attached to each original and extended stack sections for structural stability.
The stack extension was provided with two 4 inch diameter ports, 180 degrees apart, for installation of a stack opacity monitor. The ports are located about 46 feet, 6 inches above grade , or about 6 feet, 6 inches below the stack outlet. The s tack extension was also provided with a platform for mounting and maintaining the opacity monitor. The platform extends about 215 degrees around the stack. It is located about 41 feet, 2 inches above grade or about 11 feet, 9 inches below the stack outlet. A caged acc~ss ladder was provided for access to the platform level.
n. Controls and Instrumentation Panel
Controls and instrumentation devices for operation of the incinerator and related components were mainly located in a free-standing central control panel. (Note: This panel was not on site during observations on March 1, 1985.) The panel contained the following:
-- Coen flame safeguard and program controller
-- Leeds & Northrop temperature indicator/controller
-- Leeds & Northrop (combustion control) electric power unit
-- Atomizing air blower start/stop switch
-- Light oil pump start/stop switches (2)
-- Heavy oil pump start/stop switches (2)
-- Aqueous waste pump start/stop switches (2)
-- Fuel select switch: heavy or light
-- Aqueous waste valve: closed or open
-- Fan control: on or auto
-B
o. Flame Safeguard System and Program Controller
The Coen flame safeguard system was complete with a Fireye UV flame detection scanner and relays for shutting off oil supply to the burners in the event of flame outage.
The Coen program controller, or burner management system, controlled burner operating sequences and timing . Settings were factory-set and not field adjustable.
p. Combustion Control Power Unit
A Leeds & Northrop power unit transmitted signals to a (Coen) Master Controller unit based upon input from a temperature indicator/controller in the combustion chalftber. The Master Controller is mechanically linked to the forced draft fan control damper, each air register louver ( 2), oil burner ( 3) s upply line and the atomizing air supply line. Correct settings and calibrations of this linkage maintained proper air-to-fuel ratios (A/F) and firing conditions as burning rates and heating values varied .
q. Safety Protective Devices and Limits
The following protective devices were provided:
Low Combustion Air Supply Switch
Pressure switch sensed forced draft air upstream of the forced draft control damper and was set to shut down incinerator if pressures dropped below minimum setting.
-- Low Atomizing Air Supply Switch
Pressure swi tch sensed atomizing air pressure and was set to shut down i ncinerator if pressures dropped below minimum setting.
-- High Combustion Chamber Temperature Switch
Thermocouple switch set to shut down incinerator if temperatures in combustion chamber exceeded maximum settings. Thermocouple located about midway in length of chamber. Normal setting was reportedly 1850°F.
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High Gas Temperature Switch
Thermocouple switch set to shut down incinerator if temperatures measured in the stack exceed maximum settings.
Low Oil Temperature Switch
Thermal switch set to shut down the incinerator if (heavy) oil supply temperatures fell below those required for proper atomization.
High Oil Temperatur e Switch
The r mal switch set to shut down the incinerator if (heavy ) oil supply temperatures exceeded maximum settings .
Low Oil Pressure Switch
Pressure switch sensed oil supply pressures and was set to shut down incinerator if pressures fell below those required for proper atomization .
-- Low Aqueous Waste Pressure Switch
Pressure switch sensed aqueous waste pressure and was set to shut off aqueous waste flow if pressures fell below those required for proper atomization .
r . Opacity Monitor
In January 1979, a Dynatron, Inc. Model 11 00 opacity monitor was installed in the stack. This was set to indicate stack clarity as percentages of opacity ; 0 percent opacity for a clear stack and 100 percent opacity for t ota l opaqueness.
s . I ncinerator Operations Building
A concrete block building about 35 feet long by about 15 feet wide housed the burner end of the incinerator, including about 4 feet of the combustion chamber, atomizing air blower, forced draft fan, pump and heater sets, control and instrumentation panel, an auxiliary heating boiler and a motor control center. The remainder of the combustion chamber, stack opacity monitor and aqueous injector nozzles are located outside and are uncovered.
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2. 3 Incinerator Chronology
To understand and evaluate the operations and capabilities of the incinerator, a chronology of significant events and modifications was tabulated, as follows:
-- August 14, 1 972 Application, Plans and Specifi cations for a Permit to Construct (Install) Incinerator ( "Coen 75 million Btu/hour Extractor") filed with the Massachusetts Department of Public Health (DPH)
-- December 17, 1973 Installation Approval granted by the DPH for a system (unit) to handle "not more than 535 gallons per hour of 140,000 Btu/gallon waste oil 11
-- February 4, 1974 Public Hearing conducted by the Town of Bridgewater Board of Health
-- February 13, 1974 Permit granted by Town of Bridgewater Board of Health
-- June 1974 Installation completed and system started
-- January 1, 1979 Permit No. 31 issued by Massachusetts Hazardous waste Board granting "Hazardous Waste Collection and Disposal License"
-- September 28 , 1979 DEQE laboratory ana l ysis determines that PCB contaminated wastes were being incinerated
Late 1979 through Mid 1981 Numerous smoke and odor
complaints reported a nd on file with DEQE
-- September 1979 Extended stack approximately 13 feet and added platform, caged ladder and ports for opacity monitor
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January 1 980 Opacity monitor installed
June 14 (or July 10), 1980 David A. Mills , of Mills &
Teague, appointed Special Receiver by the Plymouth Superior Court
September 15-30, 1980 Incinerator modified. Two small (Model l MA) burners added to register f ront alongside existing burner (Model SMA) . Al so , f our front a queous injector nozz l es r emoved and four new nozz l es , locat ed 7 f eet from the front wall and aimed to fire radially into the combustion chamber, were installed.
-- August 1 , 1 980 Test burn conducted under the auspices of Special Receiver and his technical representatives (Drs. Jt.C. Swallow and G.C. Williams) as well as per agreement with the DEQE.
-- October-November 1980 Procedure proposed by Special Receiver for incinerating stored wa stes.
-- November 17, 1980 "Notification of Hazardous Waste Ac tivity'• (Part A) application filed with U.S.EPA per Subti tle C of RCRA. EPA I.D. No . MAD079510780 .
-- February-June 1981 Correspondence a nd applications i nvo l ving SCA Services, Inc ., Coen Company, I nc. , a nd OEQE for modifying and expanding incineration facility .
-- Mid 1981 Incinerator operations terminated.
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2. 4 Incinerator Operations
2 .4. 1 Standard Operating Procedures
Standard operating procedures, or instructions, indicated by CEC in various correspondence are as follows:
a. Check properties and quantities of materials in tanks 10, 11 and 12 ("Ready Tanks 11 ). Chemist to provide burning instructions.
b. Check strainers, piping , nozzles and various settings for cleanliness, correctness and readiness.
c. Using clean oil, ignite auxiliary burners. (Note: Prior to September 1980, the main center burner was ignited,)
d. During warm-up, check stack for visible emissions. If they occur, re-adjust settings. If unsuccessful after two minutes, shut down burner and consult chemist .
e . Check flame characteriatica through eight porta. When flame appears stabilized, increase fuel until maximum temperature is reached. Do not increase over 1eso•F.
f. Auxiliary burners to modulate through temperature controller system. {Note: Prior to September 1980, the main center burner was modulated .)
g. When temperatures have been established and stabilized at about 1800°F, dirty waste oils can be fired through main (center) burner gun. Main burner gun iB not modulated. (Note: Prior to September 1980, the main center burner fired both clean and dirty waste oils.)
h. Aqueous injection could be started if combustion chamber was maintained above 1750°F for at least two hours.
L Start aqueous waste pump and set aqueous valve to "open" position. Guns automatically positioned. If pressure limits are correct and combustion chamber is above 1725°F, aqueous atomization starts.
j . Aqueous injection rate (manually) adjusted to maintain temperatures above 1725°F.
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2.4 . 2 Operating Periods
Thermal Extractor Opei:ating Log s indicate the incinerator was operated an average of about 20 days per month for about 6 to 8 hours per day.
2. 4. 3 Firing Rates
Thermal Extractor Operating Logs for the period of April 1979 through April 1980 indicate that organic firing rates averaged 480 GPH and aqueous firing rates averaged 180 GPH. As i ndicated , t he i ncinerator is rated for burning 535 GPH of waste oils of 14 0 , 000 Btu per gal l on and up t o 250 GPH of aqueous wastes .
3.0 Incine r a t ed Materials
3.1 Initial Permit
Permit applications were filed with the DPH in 1972 for the incineration of •waste oils." A Permit was granted in February 1973.
A December 19 , 1972 letter from CEC to the Board of Selectman of Bridgewater, Massachusetts indicated the following relative to wastes to be stored (and incinerated):
"Class II l i quids will be stored, such as but not limited to kerosene, diesel oil, and No. 3 heating oil, emulsified with varying percentages of water."
"(It is estimated) that ninety pe rcent of the liquids stored will be Class III liquids , such as Nos . 4, 5 a nd 6 residual fuel oils • •• (with) va r y ing per cent ages of wat e r i n emuls ion. •
3 . 2 Ope r ations Through 1978
Little data is available which i dentifies materials incinerated during the period from 1974 through the end of 1978. A (4 page ) "Mont hly Operation Report" filed with the Massachusetts Division of Water Pollution Control for December 1977 indicates that about 168,400 gallons of oils and wastes were incinerated. Of these, only about 3, 400 gallons, or about two percent of the totals, were identified as aqueous and the remainder were identified as hydrocarbons. Incinerated materials were identified as "waste oil", "solvent residues", "acetone" and "mixed flammables."
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3.3 Operations From January 1979
3.3. 1 Hazardous Waste Collection & Disposal License
A license was issued by the Massachusetts Hazardous Waste Board on January 1, 1979 which indicated approval for disposal (incineration) of the following:
11 Hydrocarbon Liquids
Motor Oils I ndust r ia l Oils a nd Emulsions Solvents , Lacque r s , etc . Organic Chemical s and Miscella neous •
"Aqueous Liqui ds
-- Organic Chemicals •
3.3.2 Price List Classification
In March 1979, CEC published a "Price List" which categorized wastes into four classes, as follows:
-- Class A
Flammable liquid waste with heating values above 135,000 Btu per gallon and capable of maintaining incinera tor above 1650°F. Viscosity s ufficient for a ir atomiza tion. Sus pended solids not sufficierit to cl09 filters and nozzles. No chlorina ted hydrocarbons.
- - Clas s B
Fl ammable liquid was t e with heating values less t han 135 , 000 Btu per gallon but high enough to maintain incineration temperatures sufficiently above 1650°F to prevent smoking odors. No chlorinated hydrocarbons .
Class c
Flammable liquid waste with heating values too low to maintain proper incineration temperatures without added fuel. High water content. May be injected through aqueous nozzles. Sludge and solids concentrations must be low. No chlorinated hydrocarbons.
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Class D
Liquids containing flammables contaminated with sludges and having h igh , nonseparable , water content. Processing required for incineration .
Class E
Non-processable solids. Landf ill disposa l on l y.
However, in Oc tobe r 1979, CEC r e v i&ed the above classif i ca tion in a new "Price List 11 a s f o llows;
- - Clas s A
Flammable liquid waste with sufficient heating value to maintain incineration temperature& above 1650°F with added fuel. Water typically 5-20 percent. No ealta, sulfur, nitrogen or chlorinated hydrocarbons. Sludge and dispersed solids concentrations must be low.
This new Class A combined Classes A and B described in the March 1979 Schedule.
Class B
Aqueous liquid waste which can be incinerated through the aqueous injection system. Includes high water content and low Btu wastes. No salts, sulfur, nitrogen or chlorinated hydrocarbons. Sludge and dispersed solids concentrations must be low.
This new Class 8 was basically equivalent to Class C described in the March 1979 Schedule.
Cla ss c
Liqui d s c~mtaining flamma bles cont ami na ted with s ludges a nd d i s persabl e s olids which must be processed pr ior to i ncine r a tion.
This new Class C was similar to Class D described in the March 1979 Schedule.
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3. 3. 3 Internal Corres pondence
A CEC memo of De c ember 6, 1979 indicated the following:
Materials incinerated through the main burner:
Hydrocarbons: Alcohols:
Ketones: Aldehydes•
Esters: Resins:
aromatics, aldehydes, olefine wide range; mostly methanol and
i&opropanol acetone, MEK, etc. low quantity; very little
formaldehyde wide range in solution ; vinyl acetate,
pol yesters , styrene, etc. 11
11 -- Materials incinerated through aqueous injector system:
Hydrocarbons: as above; water 20-80 percent Alcohols: as above; water 20-80 percent Ketones: as above; water 20-80 percent Eaters: as above; water 20-80 percent"
3.3.4 Chlorinated Hydrocarbons
Chlorinated hydrocarbons were found in waste samples intended for incineration by the DEOE in September 1979, and January 1980 . The September sample contained PCB's.
Chlorinated hydrocarbons were found in tank Nos. 9 through 12 in July 1980 by Or. K.C. Swallow under Receivership activities.
3. 3. 5 Part A Perm! t Application
A "Notice of Hazardous Waste Activity" (Part A) application filed by CEC on November 17, 1980 indicated a wide range of waste solvents and chemicals for incineration.
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4.0 Evaluations and Analysis
4., Incinerator Design and Capabilities
The incinerator was basically a well-designed system. The main and auxiliary burners were capable of providing good atomization of waste oils and solvents. The dualair-zone register likely provided excellent mixing, or turbulence, of combustion air and atomized wastes. The aqueous injector nozzles appear suitable to have provided good atomization of aqueous wastes without detrimental impingement on the main burner flame. The combustion control system appears to have been capable of maintaining optimum air/fuel ratios and combustion conditions over a wide range of firing rates and heating values. Safety protection and limiting devices appear to have been consistent with modern standards. In fact, this type of liquid waste incineration system, including many identical components, has reportedly been installed on several recent hazardous waste incineration projects in compliance with the RCRA Incinerator Standards . Furthermore, the August 1 , 1980 stack teat on the incinerator indicated a combustion efficiency greater than 99.95 percent .
A heat balance calculation at 75 MMBH input and 50 percent excess combuation air determined that the system was properly designed and sized for incinerating 12.5 GPM of oil and up to 5 GPM of aqueous waste. Without aqueous waste injection, excess air needs to be increased to about 75 percent in order to maintain 1800°F combustion temperatures.
If aqueous waste injection were increased above 5 GPM, 1 combustion temperatures would decrease.
Based upon heat balance analysis, proper incinerator operations were maintained when at least 2. 5 gallons of organic wastes, or waste oils, were fired per each gallon of aqueous waste ( 2. 5:1 ).
When firing 12.5 GPH of oil and 5 GPM of aqueous waste , 50 percent excess air, approximately 90,000 pounds per hour of flue gases are generated.
At 1800°F, the resultant flue gas volume flow would be about 1400 cubic-feet per second. The combustion chamber volume of about 860 cubic-feet provides about 0.6 seconds of retention time for this flue gas generation rate.
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4.2 Waste Incinerability and Limitations
Identifying which waste types and properties could or could not have been incinerated is a difficult issue. The problem basically relates to defining an incineration standard with which to compare or evaluate performance . For example, in 1981 the EPA promulgated hazardous waste incinerator performance standards ( 40 CFR Part 261, SubPart 0. ). These standards generally define incinerator performance in terms of hazardous waste des truction and removal efficiencies (ORE). They also s pecify particulate and HCl emission limitations, monitoring requirements and specific testing (Trial Burns) to demonstrate compliance with the regulatory standards. However, the CEC incinerator was shut down before these standards went into effect.
When evaluating CEC' s incinerator performance and waste incinerability, there appear to be no applicable regulatory standards dealing specifically with waste destruction, detoxification or degradation. The only applicable standards at the time of incinerator operations dealt with stack emissions. The incinerator was permitted and required to comply with General Laws (Section 142B, Chapter 111) regarding emissions of carbon monoxide, particulate, smoke, oxidants, sulfur dioxide and non-methane hydrocarbons.
Stack emisaions standards, in themselves, are difficult to relate to waste incinerability . For example, assuming the incinerator was properly adjusted and operated, virtually any waste which could be pumped to and atomized through the burners and/or aqueous injector nozzles could have been "incinerated" to some degree, and possibly without visible or odorous emissions. The difficulty lies in the distinction between injecting waste liquids into an incinerator and "incinerating 11 waste liquids.
Waste types and properties which may have affec ted incinerator performance are as follows:
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4.2. 1 Heating Values
The incinerator was designed for handling wastes with heating values ranging from zero to upwards of 140,000 Btu per gallon. Organic wastes, or oils, with heating values in excess of about 100,000 Btu per gallon were to be fired through the air atomizing burner guns for maintaining proper combustion temperatures. Low Btu and aqueous wastes were to be fired through injector nozzles for combustion in the flame of the burner guns. If excessive aqueous waste quantities or insufficient organic waste quantities were fired , combustion chamber temperatures woul d have dropped. Tempe r atures less t han about 1400 °F would probably have resulted in smoke and odorous emissions . As noted , the r atio for maintaining proper temperatures was approximately 2. 5 ga llons of organics per gallon of aqueous was te .
4 . 2.2 Wa ter Content
Water content is directly related to heating value. Organic wastes typically have 5 to 40 percent water. Aqueous wastes could have from 40 to more than 95 percent water . As discussed above, the key to proper combustion appeared to be the maintenance of proper organic/aqueous ratios.
4 . 2.3 Viscosity
To be atomi zable through the burner nozzles, the organic liquids r equired a maximum viscos ity of 100 SSU . A hea vy oil pump and hea ter set mainta ined this viscosity level . Liquids wi th higher viscosities could most likely not have bee n pumped to the i nc inera t or burners.
4 . 2. 4 Suspended Solids
Suspended solids in the! waste streams could have plugged t he supply lines as well as burner and aqueous injector nozzles . Such pluggage would have affected waste atomi.zation and possibly caused poor combustion and smoke. Duplex filters were provided at the pump set suction lines and strainers were provided in the oil and aqueous supply lines for removal of most suspended solids before reaching the nozzles.
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4 .2. 5 Salts
Dissolved salts in the wastes could have caused visible emissions and possible pluggage o! the burner and aqueous injector nozzles. Resultant poor atomization would have probably caused poor combustion and smoke. As a minimum, the nozzles would have required changing or cleaning to correct the problem.
4.2.6 Chlorinated Hydrocarbons
If injected through the proper nozzles, depending on heating values , these should have had minimal affect on incinerator performance. Of course, since the system had no scrubber for emission control, virtually all chlorine would have been discharged from the stack in the form of HCl or other int e rmediate compounds (Products of Incomplete Combustion - PIC's). If concentrations were significant, odors may have been detectable .
4.3 Evolution of Operations
AI discussed, the incinerator was initially designed and pemitted for burning waste oils and aqueous wastes. The manufacturer installed, adjusted and calibrated the system and controls for these apecific waste types. For the first four years of operation, combustion, amoke and odor problems were apparently infrequent and minor . However, during this period, was te oils were in abundance. This is evidenced by the CEC Monthly Report of December 1 977 showing that about 98 percent of incinerated liquids were organic.
In late 1977 an Arab Oil Embaryo went into effect and caused fossil fuel oil prices to more than double. As a direct result, many industries no longer considered waste oils, solvent residues and similar organics as candidates for disposal. To offset fuel oil costs, they began firing these materials in their own boilers and process furnaces. Con~equently, off-site disposal firms, such as CEC, saw less and less organic wastes.
) -21
On the other hand, in about 1978 the U. S.EPA began drafting hazardous waste treatment, storage and disposal regulations under RCRA Subtitle c. Proposed Hazardous Waste Guidelines and Regulations appeared in the December 18, 1978 Federal Register. As a direct result of this activity, many industries began seeking established and permitted offsite disposal firms to handle their hazardous wastes. Through 1981, the CEC incinerator was the only facility in New England of sufficient capacity to dispose of s ubstanthl waste quantities.
It appears obvious that the 1977 oil embargo and 1978 hazardous waste regulatory activities substantially and abruptly changed CEC's waste streams. Total waste quantities most likely increased but the percentages of clean organics decreased dramatically. For example, a cursory review of CEC "Liquid Waste Reports" indicates that organic wastes typically comprised no more than about 20 percent of total wastes delivered to the facility in October through December 1979.
Odor and smoke complaints filed with the DEOE are in direct correlation with CEC's changing waste streams. No complaints appear on file prior to 1978. However, numerous complaints and OEQE inspection reports were filed from late 1978 until the incinerator was shut down in 1981.
Smoke and odor conditions are undoubtedly reflective of poor combustion in the incinerator. Likely causes are as follows:
4. 3.1 Improper or Inadequate Combustion Control Adjustments
As indicated, the incinerator system and controls were initially set by the manufacturer for burning waste oils. It is likely that the combustion control settings were never properly reset for the different was t e streams handled by CEC after 1978. It is also possibl e that the controls were inadequate for the widely fluctuating waste types and properties, or that the incinerator operators were not capable of making daily or hourly adjustments to the control settings.
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4.3.2 Excessive Nozzle and Filter Pluqgage
It is likely that after 1978, dirtier waste streams were considered more and more acceptable by CEC. Such wastes would have caused burner and aqueous injector nozzles and line filters to clog more frequently. Possibly such occurrences were too excessive to be handled by the i ncinerator operators . It is also possible that such occurrences were overlooked or often disregarded.
4.3.3 Excessive Aqueous Feed Rates
I.
As ind i cated , proper combu s tion t emper a tures are maint ained with at l ea s t 2 . 5 gallons of organics a r e injected per each gal l on of a queous wastes . Howe ve r, 11Thermal Ex tractor Operating Logs " indicate that aqueous feed rates were often excessive . On at least several days, aqueous feed quantities exceeded organic feed quantities . Smoke and odors were almost certain under such conditions.
4. 3. 4 Changed Control settings and Limits
It is possible that combustion control temperature settings and limits were changed, modified or by-passed by the incinerator operators in order to increase aqueous throughputs. This is evidenced by a DEQE inspection report of September 28, 1979 indicating incinerator operating temperatures maintained in the range of 1200 to 1400°F. Such low incinerator temperature s would probably have resulted in smoke and odor problems.
4. 3.5 Inadequate Waste Stream Data
As r eported by Dr . K. C. Swa llow in an October 1, 1980 Memora ndum to t he Special Rece iver, the CEC labora tory was i nadequat ely equipped , seldom used and had "ver y limited capabilities ." Most tests we r e i nadequate a nd subject to errors . The chemist was "not proficient in ana l ytical chemistry." The bomb calorimeter ( for heating value determinations) was only "brand new. 11 The outside laboratory used by CEC for some tests utilized questionable procedures with results often erroneous. In addition, waste manifests were neither double-checked nor monitored. Under such conditions, it seems likely that wastes were often injected incorrectly or under improper conditions. Furthermore, it would seem nearly impossible to maintain proper combustion control system adjustments.
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4.4 Generator Identiffcation
It has been estimated that approximately 1, BOO waste generators contracted CEC disposal services. Apparently reports were falsified such that reportedly incinerated wastes were disposed illegally at other, remote locations. In order to delineate potentially responsible parties , it would be desirable to identify specific waste types or properties which could not have been incinerated. However, as discussed above , this does not appear feasible.
I n addition , there appears to be no way of correlating specific waste streams to the times which they were reportedly incinerated. Most wastes were apparently in s torage for long periods of time and mixed with other wastes before incineration . Therefore, it also appears infeasible t o identi fy specific wastes which may have either caused poor incinerator operations or which were injected when the incinerator was being improperly Operated .
However, a good possibility exists that groups of· generators, whose wastes could not have been incinerated, can be identified . This possibility relates to the required incineration ratio of organics to aqueous wastes. As diacuased , about 2.5 gallons of organics were required per gallon of aqueous (2.5 : 1 ) . Review of Operating Logs for the period of April 1979 through April 1980 indicates that the average monthly ratio ranged from about 1 . 9:1 to 4. 2:1, with a 13 month average of about 2. 7:1.
As an example of how this ratio data could be utilized, consider the "Liquid Waste Report" tabulations prepared by CEC. Assuming that "A" and "B" wastes are organics and 11 C11 and "D" are aqueous (Per the CEC March 1979 Price List) approximately 840,000 gallons of organic wastes and approximately 2 . 5 million gallons of aqueous wastes were received by CEC from March through November 1979. The organic/aqueous incineration ratio logged during this same period averaged about 3:0. Therefore, the 840,000 gallons of organic wastes could have been utilized for incinerating no more than about 280,000 gallons of aqueous wastes.
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Consequent ly, on the order of 2, 2 million gallons of aqueous wastes required storage during this 8 month period, Obviously, at a certain period(s ) in time, CEC's storage capacity would have been exhausted and s pecific wastes 11 delivered" beyond s uch time( s ) could neither have been stored nor incinerated.
With respect to the above, it may be possible to analyze waste records from as far back as 1978 and develop a month-by-month (or even day-by-day?) tabulation which relates specific delivered wastes with actual CEC storage availability over a time continuum . Incinerator usage and organic/aqueous ratios would be key factors in such an analysis. On this basis, many waste generators could possibly be identified in relation to illegal disposal activities.
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APPENDICES
-- Table 1: Partial Summary of CEC Operations
-- Telephone Call Summary
-- Photographs
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T'ABLB 1 PARTIAL SU~Y OF CEC OPERATIONS
Incinerator Operating Data Su..ary (11
Operational Period
Total Operating
~
Organic• Burned
(1000 Gall
Aqueou• Burned
(1000 Gall
Organic: Aqueous ·Rat io
April 1979 146.5 63.7 21 .3 3.0
May 1979 216.4 96.7 31 ·" 3.1
June 1979 188.7 96.8 32 . 9 2.9
July 1979 138.7 70 .9 34.7 2.0
August 1979 202.5 106 . 3 35.5 3. 0
September 1979 181 .4 96.5 23.2 4.2
October 1979 268.5 132.3 51..2 2.6
November 1 979 100 .7 .-!!:..2 .!.!,.! L.!
MONTHLY AVERAGES 180 . 4 89.0 30.5 2.9
( 1 } From "Thermal Extractor Operating Loqa"
( 2 1 From CEC "Liquid Waste Report" Tabulation
Total Wastes
Organics (1 000 Gall
62.9
132.6
115.3
119.5
79.0
94.5
142 . 3
94.2
105.0
.)
Received (2)
Aqueous (1000 Gal)
248.0
218.6
277 . 8
173.5
297.3
352.0
616.3
lQhl
311 .6
~......, ""',.aoon aAUVUBIIIDiav ItA~ ..... " ....(liUYUDCIIU) DIIIliDliiDD IIOIIJiv:> lilA ............. ..
, .... IIIU IMA II 'J:IWIII
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r1•""(f .I.. "~I Telephone Call Summary .'rr'•Work Assignment No. 081393 Technica l Support for CEC Litigation ,..,.( '~'·By: Lawrence G. Doucet, P . E.
Doucet 6o Mainka, P . C.
Dates of callsPersons Called
l. Blanchard, Robert 3/6, 3/ 8 Coen Co. Representative 201-879-7750
2. Brown, Richard 3/8 Coen Co., Burlingame , CA 415-697-0440
3. Ciriello, James 2/19, 2/21 , 2/25, 2/ 26. 2/28 EPA- Region I 617-227-1946
4 . Collier, Marnie 3/13 TechLaw, Inc. 703-352- 4516
5. Donovan, Robert 2/ 19. 2/25, 3/ 7 DEQE- Lakeville 617-227-1946
6 . Gerety, David 3/7 (2) Former CEC Plant Manager 617-849-1800 ' 617-344-2510
7 . Gould, Jeffery 2/26. 2/27 DEQE- Boston 617-292-5827
8. Hynes, Patricia 3/11, 3/ 13, 3/14 (2) EPA- Reg ion I 617-223-4909
9. Owens , Tim and Tanner, Charles 2/ 13. 2/14. 2/18. 2/2 6. Life Systems , Inc. 3/ 4, 3/5, 3/ 11 216-464-3291
10. Rogers, Anne 2/13, 2/15, 2/26, 3/4 Assistant Attorney General 617-727-2265
Telephone Ca ll Summary Page 2
11. Williams, Glenn 3/4 MIT- Receivership Consultant 617-253-4587
12. Winkler, John 2/13 OEQE- Lakeville 617-947-1231
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12.
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PIJOTOGRAPH IDENTlFICATlON LlST
Site Visit Observation and Inspection of March 1, 1985 Cannons Engineering Corporation (CEC) Facility
Bridgewater, Massachusetts
Description
Fence around Cannons Cyclube Plant from First Street Looking towards incinerator. Stack visible above building.
Inside CEC facilities. Incinerator operations building on right. Stack visible . Fuel oil tank in front of stack. "Ready tank" building behind stack.
Front of incinerator operations building. "Ready tank 11
building doors on right. Red propane tank for incinerator pilot ignition.
Side of incinerator operations building .
Incinerator front end and burner system . Yellow circle (•iddle) incorporates three burner gllns . Red (center) ia main gun (Coen · 5 MA); small (Coen 1 MA) burners on each aide. Master controller linked to waste valves, register and combustion air damper is {green) box on right of burner front.
MaBter controller on lower right. Linkage arm vertical in center .
Coatbustion air fan on left . Duct, flexible connection and forced draft fan damper at vindbox connection .
Forced draft damper on left. Burner system on right.
Heavy oil pump and heater set in background . Heaters in yellow. Atomizing air blower on right. Atomizing air piping across top - from right to left.
Heavy oil pump and heater set. Duplex suction strainer {red) at lower right.
Back right side of incinerator operations building. Two aqueous injector nozzles and connecting header on combustion chamber.
Two aqueous injector nozzles. Connecting header (blue). Pneumatic insertion cylinders visible.
.•,
CEC Facility PHOTOGRAPH IDENTIFICATION LIST Page 2
~ Description
13. Left rear side of combustion chamber - towards operations building.
14. Right rear side of combustion chamber - towards operations building ,
15. Stack from right Bide of incinerator . Extension, platform and caged ladder visible.
16. Stack from rear of incinerator. Extension, platform, caged ladder and opacity monitor visible. Guy wires vi•ible .
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Copies of Extra Photographs
Originals Submitted to Patr icia Hynes U.S.EPA, Region I
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Original Photographs Submitted to Patricia Hynes U.S. EPA, Region I
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