10 June 2009

AE-17J
Mr. Frank Murray
Vice President and General Manager
Heritage-WTI, Inc.
1250 St. George Street
East Liverpool, Ohio 43920
RE:
Comprehensive Performance Test Plan for Heritage-WTI, Inc., East
Liverpool, Ohio
Dear Mr. Murray:
Heritage-WTI, Inc. ("WTI") owns and operates a hazardous waste incinerator
that is subject to emission standards and other requirements set forth in
the National Emission Standards for Hazardous Air Pollutants from
Hazardous Waste Combustors, 40 C.F.R. 63, Subpart EEE ("the HWC MACT").
On October 5, 2007, ENSR|AECOM submitted a comprehensive performance test
("CPT") plan and continuous monitoring system ("CMS") performance
evaluation test ("PET") plan on behalf of WTI. On April 2, 2008, the U.S.
Environmental Protection Agency sent its comments regarding the CPT plan
and CMS PET plan. On June 3, 2008, EPA and WTI held a teleconference to
discuss the Agencys comments. On August 11, 2008, WTI submitted a
revised CPT plan and CMS PET plan. On January 29, 2009, the Ohio
Environmental Protection Agency sent its comments regarding the CPT plan
and CMS PET plan. The original and revised CPT plans asked EPA to
determine that the Rotary Kiln and the secondary combustion chamber
("SCC") are one combustion chamber and to eliminate the need for a minimum
combustion chamber temperature operating parameter limit ("OPL") for each
combustion chamber. For the reasons stated below, EPA disapproves WTIs
request.
Facility Background
WTI operates a rotary kiln and a SCC to incinerate solid, liquid, and
gaseous hazardous wastes. The rotary kiln is 16 feet in diameter and
43 feet in length. The kiln is constructed of carbon steel with a
refractory inner lining.
The SCC is 18 feet, 2 inches wide, 18 feet, 7
inches long and 56 feet, 6 inches high. The SCC is refractory lined.
WTI contends that the rotary kiln and SCC constitute a single combustion
chamber because the SCC does not have any fuel burners or waste lances.
WTI can inject into the SCC pure oxygen to improve combustion or steam to
promote turbulence.
Because it is physically impossible to install a hard-wired temperature
measurement device ("TMD") inside the rotary kiln, WTI installed TMDs
TI4300A and TI4300B on the north and south walls, respectively, of the SCC
at the elevation of the rotational axis of the rotary kiln to measure the

rotary kiln temperature. WTI installed TMDs TI4310A and TI4310B on the
north and south walls, respectively, 9 feet above the rotary kiln TMDs to
measure the SCC temperature. WTI also installed TMDs TI4503A and TI4503B
in the roof of the SCC to measure the temperature of the flue gas near the
exit from the SCC.
During a December 2003 CPT, WTI established a rotary kiln temperature OPL
equal to 1760F as a 1-hour rolling average and a SCC temperature OPL
equal to 1795F. Pursuant to 40 C.F.R. 63.1206(c)(3)(vi)(A), WTI
reported two exceedances of the minimum rotary kiln temperature OPL and
108 exceedances of the minimum SCC temperature OPL occurring between
October 1, 2003, and April 4, 2009. The HWC MACT includes a total
hydrocarbon ("THC") emission standard of 10 parts per million by volume
over an hourly rolling average (monitored continuously with a continuous
emission monitoring system), dry basis, corrected to 7% oxygen and
reported as propane. Pursuant to 40 C.F.R. 63.1206(c)(3)(vi)(A), WTI
reported 530 exceedances of the THC emission standard between October 1,
2003, and April 4, 2009.1
Discussion
WTI asked EPA to determine that the Rotary Kiln and SCC are one combustion
chamber and to eliminate the need for a minimum combustion chamber
temperature OPL for each combustion chamber. WTIs argument focuses on
the fact that its SCC does not have any fuel burners or waste lances. The
HWC MACT defines "combustion chamber" to mean the area in which controlled
flame combustion of hazardous waste occurs. See 40 C.F.R. 63.1201. The
HWC MACTs definition of combustion chamber does not require that a
combustion chamber have a temperature control (such as a fuel burner or
waste lance) independent of an adjoining combustion chamber.2 Instead,
the HWC MACT definition focuses on whether "controlled flame combustion of
hazardous waste" is occurring in the chamber.
On July 24, 1995, the California Department of Toxic Substances Control
asked EPA to clarify the meaning of "controlled flame combustion." On
July 30, 1997, EPA stated, "Controlled flame combustion refers to a
steady-state, or near steady-state, process wherein fuel and/or oxidizer
feed rates are controlled." WTI cannot legitimately argue that the SCC at
its facility does not contain a steady-state, or near steady-state,
process wherein fuel, hazardous waste, and oxidizer (i.e., pure oxygen or
ambient air) feed rates are controlled, since the SCC is engineered to
allow WTI to feed pure oxygen or ambient air into the SCC to improve
combustion. EPA concludes that the SCC is an area in which controlled
flame combustion of hazardous waste occurs. Therefore, EPA disapproves
WTIs request in its original and revised CPT plans to determine that the
Rotary Kiln and the SCC are one combustion chamber and to eliminate the
need for a minimum combustion chamber temperature OPL.

Please direct any questions that you have on EPAs response to Charles
Hall of my staff, at (312) 353-3443.
Sincerely yours,

George Czerniak
Chief
Air Enforcement and Compliance Assurance Branch
cc:

Pam Korenewych, Ohio EPA Northeast District Office

1 WTI may have had more exceedances of the minimum rotary kiln and SCC
temperature OPLs and of the THC emission standard. However, WTI was not
required to report them pursuant to 40 C.F.R. 63.1206(c)(3)(vi)(A)
because WTI had several 60-day periods with less than ten OPL exceedances.
2 None of the preambles for the Federal Register notices pertaining to the
HWC MACT raise this question for discussion.
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