Operator Training for Hazardous Waste Incinerators:
Preparing for Compliance
Arnold Feldman
JJDS Environmental
Rick Ullrich, P.E.
WastePro Engineering
The original Hazardous Waste Combustor Maximum Achievable Control Technology (MACT) rule prescribed the need for, among other things, certified training of those who operate and manage hazardous waste incinerators. The rule was first published on September 30, 1999.
Legal challenges aimed at the rule’s shortcomings and ambiguities were almost immediately mounted, and the courts vacated the original rule. However, the Environmental Protection Agency (EPA), in an agreement with the various litigants, put the rule back in place while they work out the final details of the MACT operating parameters.
While the interim agreement delays the implementation of certain provisions by a year, companies with hazardous waste combustors (incinerators, hazardous waste burning cement kilns, and hazardous waste burning lightweight aggregate kilns) must have an operator training and certification program in place by September 30, 2003.
This paper reviews the current state of evolving regulations and describes an option that will help companies facing the compliance deadline in 2003.
The Original Rule
One of the key provisions of the original Hazardous Waste Incinerator MACT rule [40 C.F.R. §63.1206(c)(6)] specified the need for the training and certification of all personnel involved in incinerator operation. (64 FR 5282853077, September 30,1999)
The original rule allowed little or no flexibility in the certification program requirements. There were only two options:
- A state-approved program
- The ASME program
As the EPA acknowledged, no states have yet developed or endorsed an approved certification program. Thus, the original rule’s two options boiled down to only one.
The Proposed Amendment
In the Proposed Amendment of July 3rd, 2001 (66 FR 3512635155), the EPA would have allowed three options:
- A state-approved program
- The ASME program
- A site-specific program
The amendment reads as follows:
"(6) Operator training and certification.
(i)You must establish training programs for all categories of personnel whose activities may reasonably be expected to directly affect emissions of hazardous air pollutants from the source. Such persons include, but are not limited to, chief facility operators, control room operators, continuous monitoring system operators, persons that sample and analyze feedstreams, persons that manage and charge feedstreams to the combustor, persons that operate emission control devices, and ash and waste handlers. Each training program shall be of a technical level commensurate with the person's job duties specified in the training manual. Each commensurate training program shall require an examination to be administered by the instructor at the end of the training course. Passing of this test shall be deemed the “certification” for personnel, except that, for control room operators, the training and certification program shall be as specified in paragraphs (c)(6)(iii) through (c)(6)(vi) of this section.
(ii)You must ensure that the source is operated and maintained at all times by persons who are trained and certified to perform these and any other duties that may affect emissions of hazardous air pollutants. A certified control room operator must be on duty at the site at all times the source is in operation.
(iii)Hazardous waste incinerator control room operators must:
(A)Be trained and certified under a site-specific, source-developed and implemented program that meets the requirements of paragraph (c)(6)(v) of this section; or
(B)Be trained under the requirements of, and certified under, the American Society of Mechanical Engineers Standard Number QHO-1-1994 (incorporated by reference--see Sec. 63.14(e)). If you choose to use the ASME program:
(1) Control room operators must, prior to the compliance date, achieve provisional certification, and must submit an application to ASME and be scheduled for the full certification exam. Within one year of the compliance date, control room operators must achieve full certification;
(2) New operators and operators of new sources must, before assuming their duties, achieve provisional certification, and must submit an application to ASME, and be scheduled for the full certification exam. Within one year of assuming their duties, these
operators must achieve full certification; or
(C)Be trained and certified under a State program."
It was not clear how many states, if any, planned to develop or endorse a training and certification program. And for many companies, the ASME option is a generic solution to a set of unique problems, a very demanding program that offers little significant improvement in operator performance of a specific operating unit.
The requirements for a site-specific program in (c)(6)(v) included the following elements:
"(A) Training on the following subjects:
(1) Environmental concerns, including types of emissions;
(2) Basic combustion principles, including products of combustion;
(3) Operation of the specific type of combustor used by the operator, including proper startup, waste firing, and shutdown procedures;
(4) Combustion controls and continuous monitoring systems;
(5) Operation of air pollution control equipment and factors affecting performance;
(6) Inspection and maintenance of the combustor, continuous monitoring systems, and air pollution control devices;
(7) Actions to correct malfunctions or conditions that may lead to malfunction;
(8) Residue characteristics and handling procedures; and
(9) Applicable Federal, state, and local regulations, including Occupational Safety and Health Administration workplace standards; and
(B) An examination designed and administered by the instructor; and
(C) Written material covering the training course topics that may serve as reference material following completion of the course."
The site specific program also requires an annual review or refresher course covering the prescribed topics in order to maintain the certification.
Final Rule
Under the negotiated settlement as a result of the Courts decision, EPA issued a Final rule on February 14th, 2002 (67 FR 6968) that includes the items in the July 3rd, 2001 Proposed Rule for Operator Training and Certification.
A well-designed, site-specific approach allows you to meld your normal, ongoing training with instruction that meets your compliance requirements.
A Tailor-made Solution
JJDS Environmental and WastePro Engineering recently completed a successful Hazardous Waste Combustor Operator Training and Certification program for FMC/Astaris, in Pocatello, Idaho. The certification program met the requirements of the Hazardous Waste Combustor MACT rule. Even more significant, it was approved by Region 10 of the EPA, one of the most demanding regional staffs in the country.
The program developed for Astaris was a site-specific program that followed the ASME QHO Certification for Hazardous Waste Incinerator Operators standard. On this project, JJDS Environmental and WastePro Engineering:
- Developed an outline of the training and certification programs for the Pocatello facility.
- Evaluated the existing Astaris training program and prepared a gap analysis.
- Provided supplemental, site-specific training.
- Prepared a certification program for EPA approval.
- Prepared and conducted an operator certification refresher course.
- Prepared the certification examinations.
- Conducted certification testing.
What Can We Do For You?
JJDS Environmental and WastePro Engineering can help you proactively prepare for and meet this impending compliance requirement. Several options are possible. We can:
- Evaluate your current state of readiness and recommend an approach that will bring full compliance.
- Develop a complete, site-specific training and certification program for you
- Develop the necessary certification testing for you, based on your own training program
- Conduct certification testing for you as an independent and objective entity
For companies concerned about the need to come quickly and effectively into regulatory compliance, we bring a number of strengths to the table:
- A broad and deep background in environmental engineering and hazardous waste combustion
- A presence on the ASME’s Certification Committee and the Subcommittee on Testing
- The experience of having successfully developed an effective and compliant program
- The ability to leverage that experience to meet your company’s needs
For Further Information
Contact either of us for more information about how we can assist you.
- Arnold Feldman:1-267-880-2325 or
- Rick Ullrich: 1-610-444-9358 or
Biographies
Arnold Feldman earned a Bachelor of Science in Chemical Engineering at New Mexico State University in 1969. Before beginning environmental work, he held a variety of engineering and production positions at industrial facilities. In 1980, Mr. Feldman became the Environmental Manager at a large chemical plant in Illinois, where he was responsible for overall plant compliance. Since then, he has held numerous positions in the environmental field, with a heavy concentration on hazardous waste compliance monitoring and assistance. In 1999, Mr. Feldman set up JJDS Environmental, a company dedicated to helping clients cost effectively comply with environmental laws and regulations.
Mr. Feldman has developed a number of environmental training tools and compliance assistance programs. He served on numerous industry trade association committees: he was a reviewer of the Chemical Manufacturer's Association RCRA Subpart CC compliance manual, developed in association with EPA, and co-authored and edited CMA's Responsible Care® Pollution Prevention Code compliance manual. Mr. Feldman is a ViceChair of the ASME Codes and Standards Committee on Qualification & Certification of Hazardous Waste Incinerator Operators and Chair of the Subcommittee on Testing and Certification.
Rick Ullrich, P. E., is a 1977 graduate of Rensselaer Polytechnic Institute, where he earned his degree in Chemical Engineering. He has broad process engineering experience in the chemical processing industry, with particular emphasis on hazardous waste combustion. He held various engineering positions before joining Rollins Environmental in 1993, where he served as internal consultant to their operating facilities on all aspects of incinerator operation. Mr. Ullrich was involved in general technology outreach for the company, assessing opportunities and new technologies.
In 1997, he founded WastePro Engineering, a small consulting firm specializing in combustion and waste management processes. Some of the key projects he has been involved with include eliminating the bottlenecks in a liquids incinerator, effectively doubling its capacity; tuning up and improving the capacity of various fume incinerators; and planning and coordinating trial burns for many rotary kiln and liquid incinerators.
Operator Training for Hazardous Waste Incinerators1
July 2002