RCRA PERMITTING OF A VACUUM THERMAL DESORPTION SYSTEM

摘要

Envirocare of Utah, Inc. (Envirocare) is in the final stages of permitting a vacuum thermalrndesorption (VTD) system as a Resource Conservation and Recovery Act (RCRA) miscellaneousrnunit. Vacuum thermal desorption is a process that removes volatile constituents from a wasternmatrix, leaving the solid processed material amenable to further metals treatment and/or directrndisposal in Envirocare's Mixed Waste Landfill Cell (MWLC). This paper documents thernpermitting process that began in mid-2002 and includes lessons learned throughout the endeavor.rnCooperation and continual communication with local regulatory authorities has been an integralrnpart of the permitting process. The VTD system is being permitted as a Subpart X miscellaneousrnunit in accordance with the requirements in the Code of Federal Regulations (CFR): 40 CFRrn264.600 through 264.603. The permitting process added several new attachments tornEnvirocare’s existing permit that describe operating conditions, shakedown operations, andrnDemonstration Testing for the VTD system. Shakedown operations were used to refine thernsystem and prepare for Demonstration Testing. Demonstration Testing is the term used for thernspecifically designed tests to ensure that VTD operations are protective of human health and thernenvironment, specifically assuring that adequate removal efficiencies (Res) are attained for thernprincipal organic hazardous compounds (POHCs) spiked into the feed. During shakedownrnoperations, Envirocare performed several preliminary demonstration tests using waste and cleanrnsand spiked with various spiking compounds. The data from these preliminary demonstrationrntests has been used to provide additional support of the permit required Demonstration Testingrndata and is being used to justify interim operations while the Demonstration Testing data is beingrnreviewed. Demonstration Testing was conducted between August 16 and September 8, 2004.rnDuring Demonstration Testing, Toxic Substance Control Act (TSCA) parameters were alsornexamined for a national TSCA permit that is being pursued at the same time. The permittingrnprocess shows how a regulatory agency and private company can combine resources to achievernthe most proactive solution for waste generators and local stakeholders.