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Permitting for Operation of VTD Unit at Clive, UT

Permitting for Operation of VTD Unit at Clive, UT. What is VTD?.

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Permitting for Operation of VTD Unit at Clive, UT

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  1. Permitting for Operation of VTD Unit at Clive, UT

  2. What is VTD? • Vacuum assisted Thermal Desorption is a physical process that separates volatile contaminants from a solid waste matrix. Thermal Desorption is accomplished by indirectly heating waste such that volatile contaminants are driven off and off-gases are collected for further processing.

  3. Background • VTD Unit located in Clive, Utah was designed, constructed and operated by TD*X Associates, LP. • TD*X has experience with thermal desorption since its inception in the early 1990’s. • TD*X has demonstrated they are knowledgeable in theoretical and practical application of the technology.

  4. VTD Unit Design Consists of Four Subsystems • Dryer • Off-Gas Treatment Train • Condensate Tank System • Process Waste Discharge System

  5. Type of Waste Applicable to VTD • Soils/Sludge's with High Organics or PCB’s • PCB Capacitors • Solvents and Filter Media • PCB Oils from Transformers • Waste requiring CMBST as technology based standard • Containerized Chemicals, oils, paint chips, etc. • Flammable Liquids • Tank Sludge's • Most of the waste you can find in Legacy Waste Populations

  6. High Oil Content Typical

  7. Sludge's

  8. PCB Large Capacitors

  9. Tank Liquids

  10. VTD Unit separates waste into two separate phases. • Organic Liquid Condensate • Solid Processed material

  11. How are we able to treat such diverse types of waste? • Robust VTD System • Permitted and Licensed • Demonstration Testing • Various Waste Types.

  12. Who Regulates and Issues Permits? • Federal EPA • Region 8 EPA • Utah Division of Solid and Hazardous Waste, UDSHW • Utah Division of Radiation Control, UDRC • Utah Division of Air Quality • South Carolina Department of Health and Environmental Control

  13. Permitting History • March 2003 State Issued Part B Permit was amended to include Thermal Desorption. • Dec. 2003 Shakedown testing of Equipment • Aug. 2004 Waste Family Demonstration Testing for VOC, SVOC and PCB’s. • March 2005 DSHW gave Interim Operations Approval, EPA approval was automatic upon submission of test data. • Oct. 2006 TD*X applied for RML in So. Carolina to allow for release of condensate to Hazardous Waste Incinerator.

  14. Feb 2007 RML issued to TD*X Technical Center in So. Carolina allowing Radiological Release of Condensate generated from VTD. • Dec 2007 EPA National Approval of Mobile TSCA Permit to TD*X • April 2008 CMBST Code Equiv Demonstration and Shredded PCB Capacitors Demonstration • June 2008 Published in 40 CFR 268.44 Site Specific Treatment Variance for Residues resulting from VTD of P- & U- Listed hazardous waste treated at ES Clive Facility that otherwise require CMBST as the LDR Treatment Standard. • Aug 2008 Volatile Metal Demonstration Performed to allow metals such as Elemental Hg to be processed through VTD without pre-treatment.

  15. Aug 2008 Interim Ops Approval for CMBST Code Equivalency Received. • May 2009 Interim Ops Approval for Treating Shredded PCB Capacitors up 162,733 ppm and up to 209,167 ppm with blending • Sept 2009 EPA Region 8 issued Fixed Facility TSCA Permit. • Nov 2009 Final Interim Ops Approval for Volatile Metals • July 2010 Demonstration for Shredded Capacitors up 1,000,000 ppm.

  16. Demonstrations • Waste Family • VOC, SVOC & PCB • Volatile Metals • CMBST Code Equivalence • PCB Capacitors • Condensate Release

  17. Waste Family Demonstration • Method of defining and justifying Operational Parameters for specific waste families. • Waste Families are wastes with similar separation characteristics (e.g. volatile organics, semi-volatile organics, PCB’s and volatile metals.)

  18. Volatile and Semi-volatile Organic Compounds and PCB’s • Determined if waste containing volatile, semi-volatile organic compounds are amenable to VTD. • Identify and justify which principal organic hazardous constituents (POHCs) will represent each waste family being demonstrated. • Demonstrate removal efficiencies (RE) of at least 99.99% are attained.

  19. Selected Treatment Efficiency

  20. Volatile Metals • Determine if feed material containing volatile metals are amenable to Thermal Desorption processing and that the processed material either meets the LDR standard for mercury or has a total mercury concentration below 260 mg/kg • Identify and justify representative volatile metallic compound (RVMs) to represent the volatile metals waste family. • Demonstrate for each RVM that RE of at least 99.99% is attained. • Demonstrate that the maximum achievable control technology (MACT) standards for an existing incinerator are met for metal emissions.

  21. Volatile Metals Demonstration Test Summary

  22. CMBST Coded Waste • Determined if the Thermal Desorption process provides adequate separation for the processing of wastes containing CMBST-codes. • Demonstrate that the processed material is LDR compliant for POHCs and that analyzable CMBST-coded contaminants are below the practical quantitation limit (PQL) of the analytical method for each specific contaminant. • Identify and justify representative POHCs for the entire range of CMBST-coded wastes. • Demonstrate for each POHC that removal efficiencies (RE) of at least 99.99% are attained.

  23. CMBST-Coded Waste Test RE Evaluation

  24. PCB Capacitors • Determine if feed material containing shredded capacitors are amenable to Thermal Desorption processing. • Identify and justify representative matrices to represent the waste family. • Demonstrate RE of at least 99.9999% is attained.

  25. PCB Large Capacitors Test Summary

  26. Condensate Release • Waste required to be treated through VTD Unit. • Each shipment of condensate must contain less than 100 millicuries total of all radionuclide. • DOT Exempt for radioactivity. • Waste profiled for disposal at hazardous waste incinerator and less than dose limit for acceptance at incinerator.

  27. Condensate Characteristics • pH 3.3 to 5.7 • Heating Value 16,500 to 13,100 btu/lb • Density 0.9 g/cc • Flash Point 80˚F • Chlorine 55,000 to 79,400 ppm • Sulfur 800 ppm • Metals trace • PCBs 40 to 157,000 ppm • Benzene 1,770 to 2,620 ppm • Trichloroethene 4,020 to 6,390 ppm • Tetrachloroethene 18,700 to 57,700 ppm • Xylene 20,300 to 68,700 ppm

  28. Wrapping it up…

  29. EnergySolutions has successfully demonstrated the effectiveness of the VTD unit to separate volatile contaminants from feed waste streams. Working with regulators to develop successful test plan has helped with permitting of treatment technologies utilized at Clive. These technologies have aided in managing various legacy waste streams throughout the DOE Complex. Permitting is time consuming, but patience and the ability to apply proven methods has allowed for successful demonstrations and successful waste management.

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