HOW TO PLAN AND CONDUCT AN RCRA PART B TRIAL

BURN TEST: FROM A PRACTICAL POINT OF VIEW

KUN-CHIEH LEE and GARY M. WHIPPLE

Union Carbide Corporation
South Charleston Technical Center
South Charleston, West Virginia

ABSTRACT Part B application contains the balance of the information

This paper discusses the practical factors that need to
be considered when planning and conducting a RCRA
Part B hazardous waste trial burn test. Topics to be
watched as analytical tasks are conducted are also dis­
cussed. This paper does not cover the detailed procedures
which can be found in the various EPA guidance manuals.
INTRODUCTION
The US EPA published incinerator standards for own­
ers and operators of hazardous waste incineration facilities
on January 23, 1981 (1] and a technical amendment to
the incineration regulation on June 24, 1982 under
authority of the Resource Conservation and Recovery Act
of 1976 (RCRA). Three performance standards were
specified for hazardous waste incinerators:
(a) 99.99 percent destruction and removal efficiency
of the designated principal organic hazardous constituents
(pOHC's).
(b) The particulate emissions must not exceed 180
milligrams per dry standard. cubic meter (0.08 grains per
day standard cubic foot), corrected to 7 percent oxygen
in the stack gas, and
(c) A 99 percent hydrogen chloride (HCI) scrubbing
efficiency or the HCI emission is less than 1.8 kg/h (4 lb/
hr).
A trial burn testes) is required to demonstrate that a haz­
ardous waste incinerator will comply with the above per­
formance standards.
The US EPA has divided the permit application into
two parts. The Part A application, which is relatively
brief, contains a general description of the facility. The
necessary to fully evaluate the facility performance and
reach a decision concerning issuance of a permit. Normal­
ly, a trial burn is required to collect the necessary in­
formation for a Part B application.
The general requirements for a Part B trial burn are
outlined.in the January 23,1981 and June 24, 1982 regu­
lations (1, and 2]. Detailed guidance on how to prepare a
trial burn plan is discussed in the "Guidance Manual for
Hazardous Waste Incinerator Permits" [3]. The suggested
sampling and analytical methods to be used for a trial
burn are listed in the ·E PA Publication SW-846, "Test
Methods for Evaluating Solid Waste; Physical Chemical
Methods" [5] and its Appendix, "Sampling and Analysis
Methods for Hazardous Waste Combustion" [6]. This
paper is intended to discuss some of the practical con­
siderations which are not discussed (or not discussed in
detail) in the cited EPA documents.
TRIAL BURN PLAN
The intent of a trial burn is to determine whether a
hazardous waste incinerator is capable of meeting the
three performance standards and to identify the operating
conditions which ensure that the performance will be met
during routine operation. The allowable range of the
operating parameters will be determined from the trial
burn data. Hence, careful and detailed planning of the
trial burn is crucial to the future operation of the in­
cinerator.
In its final form, the trial burn plan should represent
the interests of both the applicant and the permit writer.
The data and the information generated during the trial

566
burn should be sufficient to allow the permit writer to
establish permit conditions that provide enough latitude
for the facility operator to accommodate some reasonable
variations in waste composition and incinerator operating
conditions. There are great variations in the incinerator
design and operating practice. There are also great varia­
tions in the waste feed properties and feed mechanisms.
Close communication and active discussion of the special
problems with the permit writers are strongly suggested
during the trial burn planning. So far, it is still a learning
process for the permit writer, the EPA's consultants and
the permit applicants. The application and review process
is complex, uncertain, and inherently subjective. Quite a
few people consider and interpret the Guidance Manual
[3] as the law. However, the Federal EPA has repeatedly
pointed out that the Guidance Manual "is not a major
regulation; it is a guidance document" [4]. Hence, ac­
tive participation in the RCRA Part B permitting process
by the applicant is important. In addition, the trial burn
plan itself and the associated correspondence should be
well-defined and well-documented.
The EPA has established five basic operating require­
ments which will be used to ensure performance compli­
ance during routine operation:
• Carbon monoxide level in the stack exhaust gas
• Waste feed rate
• Combustion temperature
• Combustion gas flow rate
• Acceptable variations in the waste feed composition
Other operating parameters may be used for specific cases.
The three performance standards and the above cited
operating requirements form the basis for a RCRA Part B
trial burn. The trial burn plan should also cover test pro­
cedures and schedules, and sampling and analytical proto­
cols. Some detailed discussion follows.
WASTES WHICH ARE REG ULATED UNDER 40 CFR
PART 264, SUBPART 0, HAZARDOUS WASTE
INCINERATION REG ULATIONS
A frequent mistake is to start with the Appendix VIII
compound list (40 CFR Part 261) to determine if a waste
falls under Subpart 0 regulations. The list of Appendix
VIII compounds should be used for selection of POHC's
(principal Organic Hazardous Constituents) which will be
used as an indicator to demonstrate DRE (Destruction
and Removal EffiCiency) of the incinerator. There are
two ways to determine if a waste is a legally hazardous
waste.
First, it can be a hazardous waste by reason of its
characte.ristics (40 CFR Part 261, Subpart C). Wastes
which fail one of the four characteristic tests are haz-
567
ardous wastes. Such wastes carry EPA hazardous waste
number DOOI for ignitable waste, D002 for corrosive
waste, D003 for reactive waste and D004 through DO17
for EP toxic waste. However, the ignitable wastes, cor­
rosive wastes and most of the reactive wastes are cur­
rently exempted from the 40 CFR Part 264, Subpart 0
regulations (Section 264.340 (b)) except for the waste
analysis (Section 264.341) and closure (Section 264.3 51)
requirements if the waste does not contain (or contains
insignificant amounts) those Appendix VIII compounds
which would reasonably be expected to be in the waste.
The second mechanism is by listing. All waste streams
which are listed in40 CFR Part 261, Subpart D are haz­
ardous unless the applicant· proves that they are not.
There are four lists; F, K, P, and U. Again, wastes which
are listed solely because they are ignitable, corrosive, or
reactive (in most cases), are exempted from the technical
standards of the Subpart 0 regulations.
After a waste is identified as a Subpart 0 hazardous
waste, and it is disposed of in an incinerator,the next step
is to prepare a trial burn plan. Communication with the
permit writer is suggested at this stage.
SELECTION OF THE WASTE STREAMS FOR THE
TRIAL BURN TEST
The Guidance Manual For Hazardous Waste Incinerator
Permits [3] provides enough general discussion of this
topic, so it will not be discussed in detail here. Some in­
cinerators may burn more than one type of waste and
more than one waste feed stream may be selected. It is
not necessary to use the actual waste for the trial burn
test; a synthetic waste feed is permitted. If the POHC
content in the test waste is low, it may be advantageous
to add POHC compounds to increase the concentration.
Due to some unknown reason (kinetics?,chemical eqUilib­
rium?, or field contamination?), test data has indicated
that there were problems achieving 99.99 percent DRE if
the feed POHC concentration is very low [7]. Under this
situation, the data may not represent real incinerator per­
formance. If the hazardous constituen�s concentration in
the waste feed is low, a 99 percent or 99.9 percent DRE
produces a lower actual stack emission rate than an in­
cinerator burning high concentration waste with a demon­
strated 99.99 percent DRE.
WASTE ANALYSES PLAN
The waste analysis plan should cover the sampling and
analytical methods to be used and the related Quality
Assurance/Quality Control (QA/QC) plan. The analysis
plan is suggested by the applicant and evaluated by the
permit writer. Methods listec;i in EPA Publication SW-846
[5] and its Appendix [6] should be used as much as
possible. Otherwise, the applicant may be required to
justify and supply the QA/QC data for an alternate meth­
od; this can prove to be very costly.
The Guidance Manual gives a detailed list of possible
analyses which should be considered. Some specific com­
ments are suggested for analytical tasks:
(a) Obtain representative sample: Chemical wastes
are typically nonhomogeneous, so extra care is needed
to obtain a representative sample. For example, placing
a drum in a drum shaker before taking a sample may be
unacceptable; the different phases of the waste may
separate the moment the drum shaker stops.
(b) Appendix VIII toxic compounds identification:
A GC-MS analysis followed by a computerized reverse
search is suggested when looking for Appendix VIII com­
pounds which are reasonably expected to exist. It should
be realized that no one GC column is good for all Ap­
pendix VIII compounds. The limitations of the GC
column used should be considered.
(c) POHC concentration: Chemical wastes normally
contain hundreds of compounds. Interference (two or
more compounds which have the same retention time or
co-elute in a GC-column) and retention time shifting
(retention time shifted due to the influence of other com­
pound(s» are two potential problems. GC-MS confirma­
tion can resolve the interference problem and pure com­
pound spiking can resolve the retention time shifting
problem.
Most chemical wastes are heterogeneous. It is suggested
that the waste sample be first dissolved in a good solvent.
E nough solvent should be used to obtain a homogeneous
sample matrix.
(d) Ash content: During the combustion process in
the ASTM 0482 analYSiS, the organically-bound inorganic
elements form submicron fume particles. The majority of
the fume particles may be lost in the flue gas. The ash
content measured according to ASTM 0482 may be in­
accurate. Some method development work is required in
this area.
(e) Organically bound chlorine anaiysis: If a combus­
tion method is used to digest the sample, special precau­
tions should be taken to make sure that all chlorine is
converted to the chloride rather than chlorine gas. When
the waste has a high chlorine content, a Significant portion
of the organically-bound chlorine may be converted to
chlorine gas and lost in the air.
(f) Thermal analyses: TGA (Thermogravimetric Anal­
ysis) and DSC (Differential Scanning Calorimetery) analy­
ses may be required for some wastes. Both techniques use
micro quantities of sample (around 30 mg). Most chemical
wastes are heterogeneous in nature, so it is very unlikely
568
that 30 mg of sample will be representative of the total
waste.
(g) Viscosity measurements: If viscosity at room tem­
perature is higher than 20 centistokes, viscosity measure­
ments at two or three temperatures are suggested. The
measured viscosity may be incorrect if there are emulsions
or suspended particles.
POHC SELECTION
It is up to the permit writer to decide what and how
many POHC's should be selected for the trial burn. How­
ever, the applicant should evaluate his own situation and
proposePOHC's for the permit writer's consideration. The
degree of' incineribUity and the concentration of each
organic hazardous constituent in the waste feed should
serve as the principal basis for selection of the POHCs.
However, the current understanding of the degree of in­
cineribility is quite limited. Although the Guidance
Manual suggests the use of heating value to rank incineri­
bility, laboratory tests indicate that heating values are an
inadequate predictor [8]. In order to avoid the possibil­
ity of repeating the trial burn test at a later time (as EPA
accumulates data regarding incineribility), it is suggested
that other incineribility hierarchies should also be con­
sidered when selecting POHCs. The two other hierarchies
which should be evaluated are autoignition temperature
[9, 10] and T99•99 from the University of Dayton Re­
search Institute's thermal oxidation study [11].
In some cases, the use of surrogate POHCs may be ad­
vantageous. In other cases, it .may be desirable to increase
the concentration of the POHC compounds in the trial
burn waste.
The following is a list of considerations which should
be evaluated before the final selection ofPOHCs.
• The compounds should be Appendix VIII com­
pounds.
• The compounds should be chemically stable.
• The compounds should not be a potential com­
bustion intermediate, or they will cause problems in
calculating DRE. Acids, aldehydes, naphthalene and
phenol, are some known combustion intermediates.
• The compounds should not be a potential impur­
ity in the working solvent (for example, methylene
chloride) used for sample work up if a MM-5 sampling
train is used. Toluene is such a potential impurity.
• The compounds should not be an internal con­
taminant of the Tenax-GC if a VOST sampling train is
used. Tenax-GC is an aromatic based resin; benzene,
toluene and xylene are potential impurities.
The compounds should all have boiling points
•
°
either higher or lower than 100-120 C. Otherwise, two
sampling trains, MM-S and VOST, will have to be used
simultaneously.
• The compounds should be commercially available in
large quantities and at a reasonable cost.
• The compounds should be compatible with each
other and with the waste with which they are going to be
mixed.
• The compounds cannot already exist in the scrub­
bing water, since they will be stripped out of the scrub­
bing water.
POHC SAMPLING METHOD SELECTION
There are basically two sampling trains which can be
used to sample flue gas during a trial burn. The Modified
Method 5 (MM-S) sampling train should be used if the
POHCs selected have a boiling point higher than 1 00-
1 20°C but less than about 300°C. A sketch of a MM-S
train is shown in Fig. 1 .
If the POHCs selected have a boiling point less than
1 00-1 20°C, the Volatile Organic Sampling Train (VOST)
will be required. The VOST train is a newly developed
sampling technique with limited field experience. Many
problems have been reported by those who have evalu­
ated the system. A sketch of one of the VOST designs
is shown in Fig. 2 [12].
POHC ANALYTICAL METHOD SELECTION
As discussed previously under waste analyses, the of­
ficial EPA methods listed in EPA Publication SW-846 [5]
and its Appendix [6] should be used as much as possible
to avoid any potential verification problems.
As discussed under the Waste Analyses Plan, inter­
ference and retention time shifting are potential problems.
Spiking and GC-MS confirmation are suggested.
Combustion is a complicated process. Cracking, oxida­
tion, and polymerization occur simultaneously in the
combustion zone. Hundreds of trace organics with a wide
molecular weight range can be found in the flue gas. The
POHC compounds normally are a very small portion of
the organics found in the flue gas sample. The current
MM-S sample preparation method requires the concentra­
tion of the organic sample (originally in about 1 20-1 SO ft3
flue gas) to 1-1 0 cc of the working solvent (methylene
chloride if a FID detector is used). Even after the con­
centration process, the concentrations of the POHCs are
still very low in most cases. High GC attenuation is nor­
mally required to obtain a good GC peak. Due to the
combined effect of complex sample matrix and high GC
attenuation, the GC baseline is typically not straight. Most
of the time, the microprocessor in even state-of-the-art
569
GC, cannot handle an irregular baseline. The computer
may print a peak area which is totally erroneous. It is nec­
essary to carefully evaluate how the computer draws the
baseline for each peak of interest.
An ECD detector is normally specified for analysis of
chlorinated Appendix VIII compounds [5, 6]. Also,
methylene chloride is normally specified as a working sol­
vent for the MM-S sample work-up [6, 1 3, 1 4, and 1 5].If
an ECD detector is going to be used for the GC analysis,
the working solvent cannot be a chlorinated compound
such as methylene chloride. Some type of nonchlorinated
solvent, such as a mixture of hexane and acetone, may be
used. However, the current analytical guidance manuals
contain no procedures on how to conduct the sample
work-up tasks with such a nonchlorinated solvent. In
many cases, a FID detector may have to be used until the
EPA provides better guidance on how to conduct the
sample work-up procedures with nonchlorinated solvents
or a solvent mixture.
HCI AN D PARTICULATE SAMPLING
The sampling methods for HCl and particulate have
been used in the field for many years. Experienced per­
sonnel should be able to handle the tasks with no prob­
lems. Although a MM-S train is supposed to be designed
to handle HCl, particulate and organics simultaneously
[6], it is suggested that two separate trains should be used
in the field. A separate standard EPA Method 5 train
should be used for HCl and particulate �ampling; the cur­
rent EPA guidance manual (SW-846 and its Appendix)
gives no instructions on how to separate the three cate­
gories of samples if only a MM-S sampling train is used.
It should be noticed that a scrubber without a mist
eliminator may bias the HCl data [7]. The sampling train
will catch the scrubbing water droplets carry-over.
SCRUBBER SOLUTION, ASH AND OTHER RESIDUES
(FROM AIR POLLUTION CONTROL DEVICES)
These streams should be sampled to study the fate of
the selected PORCs. A composite sample should be ob­
tained. The influent scrubbing solution should be sam­
pled as well to check the background PORC levels and
contaminants. .
OPERATING CONDITIONS SELECTION
The Guidance Manual provides a detailed discussion
of factors which should be considered in selecting the
operating conditions for the trial burn. Since the fmal
permitted operating conditions are specified based on the
 Thermomeler
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Temperalura Sensor Slack Wall Sorbsnl Trap Thermomelar

Probe_ Check Valve

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Aeversa·Typ. Pitot Tub.

Silica Gel
Pitot Manome.. r
Vacuum Una
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Thermometers
Implngera Ic. Beth
By·P.ss V.lv.
Orifice

Main Valv.

Drv Gas Meier Alr·Tight Pump

FIG.1 THE MODIFIED METHOD 5 (MM-5) TRAIN

trial burn test results, it is crucial to select operating con­
ditions that cover the potential future operation range. A
pre-trial burn test using both CO and THe continuous
monitoring instruments is suggested; the flue gas CO and
THe levels should be monitored as the incinerator oper­
ating conditions are varied. Those operating conditions
which result in elevated CO and THe levels should be ex­
cluded from the trial burn test plan.
It is strongly suggested that as many operating condi­
tions as possible be selected in one trial burn rather than
conducting two separate trial burns. To run two tests in
one trial burn may increase the trial burn cost by only
10 percent. To run two separate trial burn tests will
double the cost. This will be discussed in more detail
under the TRIAL BURN COST section.
In the use of any instruments, protection against Hel
corrosion should be considered. Two potential problems
in using a THe analyzer are sampling line loss and the
quench of the FID detector Signal by moisture in the
flue gas.
CO MON ITORIN G
The stack CO level is a very sensitive indicator of
change in the combustion process. A slight adjustment
made to the operating variables (in order to make the sys­
tem perform better) may produce a momentary CO spike.
The duration of the CO spike shown on the recorder has
normally been increased due to the long sampling line and
the large sample tube in an IR type CO analyzer. The ac­
tual CO spike duration in the incinerator lasts (normally)
for only a few seconds while the recorder may show an
one-minute spike. In negotiating the use of stack CO
level to actuate the emergency shut down device, it is
important to differentiate between the momentary CO
spike caused by the necessary operating parameter

570
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particulate

filter Teflon probe

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Indicator

f'" ...., Tenax � Tenax

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. Exhaust

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Stack IA adsorbent
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Pump
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FIG.2 THE VOLATILE ORGANICS SAMPLING TRAIN (VOST)

changes and the long term higher CO level due to system
malfunctions. Otherwise, frequent, unnecessary and dan­
gerous emergency shutdowns may result.
FIELD TEST
No two incineration systems are the same and no two
trial burns are the same. Each trial burn has to be planned
differently and each field test will have unique problems.
The following are some suggestions which should be con­
sidered in conducting a field test.
• Make a visit to the unit several weeks before the test
and make sure that the sampling points are accessible and
usable. Sometimes, a sampling point on the process flow
diagram is no more than a plug; the installation of tubing
and a shut-off valve will be needed. In some cases, the sys­
tem may have been modified and there is simply no place
to sample. Some shop order work may be required.
• Give detailed written instructions to the unit people
on electrical supplies, flue gas sampling ports and sampling
platform requirements. Make sure that there are enough
circuits to supply the electrical power which is needed for
the sampling job. Unfortunately, since trial burn tests are
temporary efforts, one long extension line with many
outlets is often used. Even if the circuit breaker does not
trip, the line voltage drop may be so large that both the
instruments and the sampling pumps malfunction.
• Traditionally, the Standard EPA Method-S train is
hung on a monorail at the stack for ease of conducting a
traverse. For Modified Method·S (MM·S) sampling, it is
suggested that a wooden bench of appropriate height be
provided so that the MM-S sampler -can slide on it during
the traverse.
•Both MM·5 and VaST trains are used for trace or­
ganics sampling. Minor field contamination can be a very
serious and Significant problem. A clean sample recovery
area which is close to the incinerator is required.
• Always carry "enough" spare glassware and equip­
ment. Each piece of glassware in the MM-5 and VaST
trains should have at least one spare.
• Make a dry run before conducting the actual test so
that you will not have unexpected problems during the
first day of the test.
• Prepare a responsibility chart on a block diagram of
the unit to show each person's responsibility. Also prepare
a sampling schedule for each person.
• Prepare detailed instruction sheets for each person
,
who is participating in the sampling job. The instructions
can never be too detailed. Oral instructions should be
avoided as much as possible.
• You can never make a perfect plah. At the end of
each day, ,a brief meeting should be held with the people
who participated in the sampling tasks to identify prob­
lems and to suggest improvements.

571
 QUALITY ASSURANCE/QUALITY CONTROL
At 99.99 percent destruction efficiency, there are
really only traces of the POHCs left in the stack flue gas.
Hence, the RCRA trial burn test is an effort to sample and
to analyze traces of organics (POHCs). Significant effort
is involved in the pre-test preparation in order to have a
clean, contaminant-free sampling system. For example,
the XAD-2 resin to be used in the MM-5 train is extracted
with water for 8 hr, then extracted with methyl alcohol
for 22 hr and then extracted twice with methylene chlo­
ride for 22 hr each. The cleaned XAD-2 resin needs to be
purged with pure, clean nitrogen for 24 to 48 hr to re­
move all the methylene chloride. Even more complex
tasks are required in the post-test sample recovery and
preparation. One can never over-emphasize the impor­
tance of the QA/QC efforts in the RCRA trial burn test.
The QA/QC requirements include record keeping (every­
thing should be documented, dated and signed), chain of
custody records, maintenance and instrument verification,
method verification, calibration schedule, data confrrma­
tion procedure, quality control samples, field blanks,
method blanks, spiked samples, replicated analyses, repli­
cated sampling, etc.
For the MM-5 train, a discussion of the pre-test prepa­
ration task(s) requirements and the post-test sample re­
covery, preparation and recovery tasks with the associated
QA/QC requirements can be found in Ref. [5]. A more
detailed discussion of those tasks can be found in Refs.
[13-15]. Since the VOST train is relatively new, there
are no detailed procedures published yet at this writing.
In working up the MM-5 samples, the use of glass dis­
tilled grade methylene chloride is required. However,
after concentrating 500·1000 ml glass distilled methylene
chloride to 1·10 ml for analysis, the impurities in the
solvent can be a serious problem. Based on our experi­
ence, we have not seen two bottles of glass distilled
methylene chloride which contain the same type or the
same amount of impurities. It is important that the field
blank and method blanks for each of the field samples be
obtained from the same bottle of solvent.
TRIAL BURN C OST
In the traditional stack sampling job, field sampling
cost is a major item. On the contrary, in a RCRA trial
burn test, field sampling cost is just a minor item. Many
people do not and cannot understand why a RCRA com­
pliance test costs between $1 00,000 and $1 50,000. A
large portion of the cost is spent in the pre-test prepara­
tion and the majority of the cost is spent in the post-test
sample recovery, preparation and analyses. The associated
QA/QC efforts in either the pre-test or the post-test tasks
572
are also costly. All of those costs are basically laboratory
related costs rather than field costs.
Most of the costs related to laboratory efforts are fixed
costs which are more-or-Iess independent on the number
of runs conducted in the field. For example, it takes
about one week elapsed time to prepare and clean the
XAD-2 resin for the field test and it takes about another
week to do a QA/QC check onthe quality of the cleaned
XAD-2 resin. Approximately the same amount of time
will be required to prepare enough XAD-2 resin for just
one run as that required for three or four runs, and not
much more adiitional time would be required to prepare
enough XAD resin for nine runs.
A similar situation exists for the post-test sample prep­
aration tasks. Several extraction and concentration de­
vices can be set-up simultaneously so that preparation
efforts for multiple samples will not be too much more
expensive than that for a single sample. The cost for
setting-up the analytical instruments and the associated
QA/QC efforts is also insensitive to the number of samples.
If planned carefully, several sets of samples may share
the same field and method blanks. This will also reduce
the cost for multiple tests.
However, if a trial burn is repeated at a later time, the
cost will double. It is strongly suggested that all the neces­
sary tests be conducted as part of a single trial burn.
REFERENCES
[1) US EPA, "Incinerator Standards for Owners and Opera­
tors of Hazardous Waste Management Facilities j Interim Final
Rule and Proposed Rule," Federal Register, Friday, January 23,
1981, pp. 7666-7690.
[2) US EPA, "Standards Applicable to Owners and Opera­
tors of Hazardous Waste Treatment, Storage and Disposal Facili­
tiesj Consolidated Permit Regulationsj and the Hazardous Waste
Management Sy stem " Federal R egiste r, Thursday, June 24, 1982,
,
pp 27516 27535
.
-
.
(3) US EPA and Mitre Corp., "Guidance Manual for Haz­
ardous Waste Incinerator Permits," March,1983.
(4) US EPA, "Hazardous Waste Incinerators, Evaluating
Permit Applicationsj Availability of Manual," Federal Register,
Friday, August 12, 1983, p. 36582.
(5) US EPA, "Test Methods for Evaluating Solid Waste;
Physical/Chemical Methods," Publication SW-846, 2nd Edition,
July,1982.
(6) Harris, J. D., et aI., "Sampling and Analysis Methods for
Hazardous Waste Combustion," A. D. Little,Inc.,To be published
by EPA as Appendix of EPA Publication SW-846.
(7) Trenholm, A., et aI., "Emission Test Results for a Haz­
ardous Waste Incineration RIA," Midwest Research Institute and
US EPA, paper presented at the Ninth Annual Research Symposi­
um, Land Disposal, Incineration and Treatment of Hazardous
Waste, Ft. Mitchell, Kentucky, May 24, 1983.
(8) Seeker, W. R., et al., "Laboratory-Scale Flame Mode
Study of Hazardous Waste Incineration," Energy and Environ­
mental Research Corporation and US EPA, paper presented at
the Ninth Annual Research Symposium, Ft. Mitchell, Kentucky,
May 2-4,1983.
[9] Lee, K. C., et al., "Revised Model for the Prediction of
the Time-Temperature Requirements for Thermal Destruction of
Dilute Organic Vapors and its Usage for Predicting Compound De­
structibility," paper presented at the 7 5th Annual Meeting of the
Air Pollution Control Association,New Orleans,June,1982.
[10] Cudahy, 1. J., Stroka, L., and Troxler,W.,"Incineration
Characteristics of RCRA Listed Hazardous Wastes," I. T. Environ­
science,Inc.,EPA Contract No. 658-03-2568, July,1981.
[11] Dellinger, B., et al., "Factors Affecting the Gas-Phase
Thermal Decomposition of Chlorinated Aromatic Hydrocarbons,"
University of Dayton Research Institute and US EPA, paper pre­
sented at the Ninth AMual Research Symposium, Ft. Mitchell,
Kentucky,May 2-4,1983.
(12] "System Removes Volatile Organics from Stack Gas,"
p. 41,Chemical and Engineering News, February 28,1983.
[13] Lentgen, D. E., et aI.,"EPA-IERL-RTP Procedures Man­
ual: Level 1 Environmental Assessment," Second Edition, Re­
search Triangle Institute,NTIS PB-293795,October,1978.
[14] Harris, J. C., et al., "EPA-IERL-RTP Procedures for
Level 2 Sampling and Analysis of Organic Materials," Arthur D.
Little,Inc.,NTIS PB-293800,February,1979.
[IS]' Hamersma, J. W., et al., "Emission Assessment of Con­
ventional Stationary Combustion Systems: Methods and Proce­
dures Manual for Sampling and Analysis," TRW Systems Group,
NTIS PB-294675,January 1979.

Kay Word.: Hazardous • Incineration • Performance •

Regulations. Sampling Methods. Testing

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