SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

r wastes (such as animal carcasses and cage litter). It also burns WHAT IS DHS' ROLE? mixed wastes such as low level radioactive wastes.The existing LLNL incinerator is not a commercial incinerator that burns off-site As with all RCRA permit applications in California, the waste for a profit.Only waste generated from the facility's operations Department of Health Services(DHS)provided significant technical have been burned in this unit. and administrative support to EPA in making decisions. DHS is not on the same schedule constraint as EPA. However, DHS is WHY IS THE PERMIT BEING DENIED? preparing a supplemental Draft Environmental Impact Report under the California Environmental Quality Act and has not yet issued its The facility did not provide sufficient information to allow for an own decision on this application. adequate permit application review. Furthermore,there were design deficiencies that makethe facility less protective of human health and WHAT WERE THE TRIAL BURN RESULTS the environment than is appropriate. FROM THIS INCINERATOR? The major information deficiencies are an inadequate Part A(basic facility information)and failure to submit a health risk assessment. As one part of the permit application process, facilities must conduct a trial burn to ensure that their incinerator meets the State The major design deficiencies include an inadequate secondary and Federal regulatory performance standards. As they apply to containment system for wastes, a deficient closure plan, and failure LLNL,these standards are as follows: to conclusively demonstrate that the incinerator performs adequately: LLNL submitted inadequate trial burn results(Please see"What were Emissions of hydrogen chloride(HCI)less than 4 pounds the trial burn results?"). per hour(Ib/h.). WHY HAS THE FACILITY BEEN OPERATING Emissions of particulates less than 0.08 grains per dry WITHOUT A PERMIT UNTIL NOW? standard cubic foot(gr/dscf)of exhaust gas. The RCRA regulations were implemented in 1980, and allowed Destruction and removal of 99.99/0 of the principle organic existing hazardous waste treatment,storage,and disposal facilities hazardous constituents(POHCs)that are representative of (e.g., landfills, surface impoundments, incinerators) to continue the waste being fed to the incinerator. operating under"Interim Status"until EPA issued or denied a final LLNL failed to meet DRE performance standards and lacked RCRA permit. Since 1980, the California Department of Health air pollution control devices to ensure added protection if Services(DHS)and EPA have conducted periodic inspections,and operating conditions change. LLNL conducted a trial burn from the facility has been subject to State and Federal interim status March 1988,to June 1988, under observation by representatives of regulations. LLNL submitted their first application in 1983, and has EPA and DHS. Based on limited review of the data, it was submitted several revisions since then in response to agency requests. In 1984, Congress enacted the Hazardous and Solid determined that the incinerator failed to demonstrate compliance Waste Amendments which mandated that all existing hazardous with the 99.99% Destruction and Removal Efficiency (DRE) waste lstandard. Most importantly, the reported destruction efficiency for November 8, 1989s have EPA permit decisions completed by formaldehyde ranged from 99.965%to 99.994%, and the reported destruction efficiency for formic acid ranged from 99.97% to 99.988%. After design modifications were made, a second trial burn was conducted in February 1989, also under observation by THE PERMIT PROCESS representatives of EPA and DHS. However, LLNL was unable to conclusively demonstrate sufficient destruction efficiency for the POHC formaldehyde. There also remained a number of additional Submittal of a permit application concerns with the trial burns that questioned whether the incinerator would perform satisfactorily. Administrative review of the The facility did pass the particulate limit by a narrow margin permit application during the trial burn. However, there is reason to believe that its performance could be less reliable during normal operations when it is not burning synthetic wastes. If permitted,this incinerator would Preparing the draft permit have been allowed to burn a wider variety of wastes than any other or denial facility being considered for permitting in California without the presence of an airollution p control system. �fllncaellpztling cing public comment and WHY IS A RISK ASSESSMENT NEEDED? the permit or denial As part of their permit application,LLNLwas requested to prepare a risk assessment to estimate the risk posed by the incinerator and other LLNL hazardous waste management operations to the Modifying, malntalning, and terminating surrounding community.EPA does not issue permits unless the risk e Permit assessment methodology is approved and the conclusions are found to be acceptable. LLNL proposed to do a risk assessment in phases. Phase I,covering only the incinerator,would be submitted on November 6, 1989; Phase II,covering waste management units Continued on Page 3 - 2