guide to the code of practice for small incineratorsdefinitions all definitions in the epea and its...

Guide to the

Code of Practice for Small Incinerators

November 2012

Environment and Sustainable Resource Development

Guide to the Code of Practice for Small Incinerators November 2012

Alberta Environment and Sustainable Resource Development

ISBN Online: 978-1-4601-0562-7

Website: http://environment.gov.ab.ca/info/home.asp

Prepared by:

Tony Fernandes, P. Eng. Senior Technology Specialist Science, Evaluation, and Reporting Branch Alberta Environment and Sustainable Resource Development

For any questions on these guidelines contact:

Air, Land and Waste Policy Branch phone: 780 427 0600 email: [email protected] or

Alberta Environment Regional Offices at http://environment.alberta.ca/01549.html

http://environment.gov.ab.ca/info/home.asp

mailto:[email protected]

http://environment.alberta.ca/01549.html


GUIDE TO THE

CODE OF PRACTICE FOR SMALL INCINERATORS

TABLE OF CONTENTS

Page

1. Introduction …………………………………………… 1

2. Back-up Legislation ………………………………….. 2

3. Definitions ....………………………………………….. 4

4. To Whom Does the Code Apply? …..……………… 7

5. To Whom Does the Code Not Apply? ..……………. 10

6. Authorizations to Operate incinerators …………… 13

7. How to Register? ……………………………………. 14

8. Analyses Required …………………………………. 16

9. Design Requirements .…………………………….. 19

10. Operational Requirements ………………………… 22

11. Monitoring Requirements ………………………….. 24

12. Record Keeping and Reporting ………………….... 26

13. Amendment of the Code of Practice ……………….. 27

14. More Information on the Code of Practice ……...... 27

Appendix 1 Registration Template …………………… 28

Appendix 2 Frequently Asked Questions …………... 29



Important Notes

(1) This document provides additional information and clarifies the intent of the Code of Practice for Small Incinerators. For a more comprehensive perspective, the following legislation and related documents should be consulted:

Environmental Protection and Enhancement Act (EPEA or the Act) Oil and Gas Conservation Act (OGCA) Activities Designation Regulation (ADR) Waste Control Regulation (WCR) Substance Release Regulation (SRR) Code of Practice for Energy Recovery Code of Practice for Small Incinerators (the Code) The Alberta User Guide for Waste Managers (the User Guide) ERCB Directive 58

(2) Section numbers in this Guide do not reflect the Section numbers in the Code of Practice for Small Incinerators unless specifically expressed.

Acronyms

ESRD Environment and Sustainable Resource Development CSA Canadian Standards Association D&D Dioxins and dibenzofurans ERCB Energy Resources Conservation Board Guide Guide to the Code of Practice for Small Incinerators MOU Memorandum of Understanding MSW Municipal Solid Waste PICs Products of incomplete combustion SI Small Incinerator

Alberta Environment and Sustainable Resource Development 1

1. INTRODUCTION

This Guide provides supporting information for the Code of Practice for Small Incinerators (the Code) which specifies requirements for operating a small incinerator (SI) in Alberta as defined in the Activities Designation Regulation (ADR). The person responsible for a SI should be familiar with environmental legislation applicable to activities that include waste management thermal processes and require authorization under the Environmental Protection and Enhancement Act (EPEA). Drafts of the Code were circulated by Environment and Sustainable Resource Development (ESRD) and registrations issued by this Department since the mid nineties up to September 2005 when the current Code was published. Of the present 50 registrations, 24 were issued prior to the publication of the Code. Another 12 have been proposed recently. All of the current registrations are valid because they were issued in compliance with the ADR that imposes registration on the operation of a small incinerator (SI) whether an applicable Code of Practice has been published or not. Consequently, holders of registrations issued by ESRD prior to 2005 are not required to re-apply for a new registration provided that the operation meets all requirements of the current Code as required by the WCR. In addition to compliance with the Code provisions, the person responsible must comply with applicable requirements of the Act and Regulations, and all other relevant laws. The Code outlines mandatory emission limits, design and operating requirements for small incinerators. The Guide expands on definitions, identifies Alberta legislation applicable to incinerators, explains when and how the Code applies, and clarifies approval, operational, and record keeping requirements.



2. BACK-UP LEGISLATION

In addition to the Code, the person responsible for the operation of a SI should be familiar with the following legislation available at the Queen’s Printer website at: http://www.qp.alberta.ca:

Environmental Protection and Enhancement Act (EPEA)

o Section 38 backs up the Codes identified in the Regulations.

Activities Designation Regulation (AR 276/2003 consolidated up to AR 97/2011)

o Sections 2(1)(i.1), 3(1)(a.1), 3(1)(h) on the definitions of mobile incinerator, burning waste as fuel, and small incinerator.

o Section 5(2) on the designation of activities and approvals required.

o Clause (b) in Schedule 2, Division 1 identifies the operation of small incinerators as an activity that requires registration under EPEA.

o Section 6 on the Director’s powers to issue combined approvals or registrations.

o Clause (a) in Schedule 1 of Division 1 identifies the operation of fixed facilities including incinerators that treat more than 10 tonne per month of waste as an activity that requires EPEA approval.

o Clause (b) in Schedule 1, Division 1, Waste Management, identifies the operation of mobile incinerators that treat waste that contains: halogenated organic compounds in an amount of more than

1000 milligrams per kilogram of waste; polychlorinated biphenyls in an amount of more than 50

milligrams per kilogram of waste, lead in an amount of more than 100 milligrams per kilogram of

waste, or mercury in an amount of more than 2 milligrams per kilogram of

waste;

as an activity that requires approval under the EPEA.

Waste Control Regulation (AR 192/96 consolidated up to AR 31/2012)

o Section 11 or Section 18 on requirements for the storage of hazardous wastes or hazardous recyclables.

o Section 14 empowers all the Codes of Practice under EPEA and the WCR, links to Schedule 4, which identifies waste/recyclable Coded regulated activities, identifies the respective Code, addresses the status of current registration holders; and defines the scope of the Codes in relation to EPEA approvals.

o Schedule 4 in Column A imposes compliance with the Code of Practice identified in Column B.

http://www.qp.alberta.ca/



Substance Release Regulation (AR 124/93 consolidated up to AR 114/2006)

o Sections 4 and 8 on opacity and particulate matter apply when not covered by an approval or a Code of Practice.

Release Reporting Regulation (AR 117/93 consolidated up to 386/2003)

o Section 3 on quantities and accidental releases of specific substances into surface water, watercourses or groundwater.

Code of Practice for Energy Recovery

Code of Practice for Small Incinerators (the Code)

Oil and Gas Conservation Act [Sections 1(1)(w) on the definition of facility and 12.1 on requirement for approval]

Oil and Gas Conservation Regulations (Sections 1020.2 and 8.150)

Directive 058: Oilfield Waste Management Requirements for the Upstream Petroleum Industry (Section 17 specifically 17.3 and 17.4)

Interim Directive 2000-03 and MOU on the Harmonization of Waste Management



3. DEFINITIONS

All definitions in the EPEA and its Regulations, specifically the ADR and the WCR, apply to this Code of Practice. The Code includes the definitions relevant to the activities regulated in the document. The following includes additional definitions provided for further clarification.

3.1 “air curtain incinerator” means an open top box used to burn wood waste or similar debris that incorporates an air flow over the top of the box to increase burning efficiency and reduce the release of particulate matter and smoke.

3.2 “destruction and removal efficiency” or “DRE” is an indicator of the efficiency of the incinerator to destroy the organic fraction present in the waste being burned. It can be defined by the following equation:

DRE = {1 – (WCO)/[(WCO2) – WCO)]} x 100%

where WCO and WCO2 are the mass of carbon in the form of CO and CO2, respectively, present in the exhaust gas in grams per kilogram of exhaust gas. If applicable, the WCO must be adjusted accordingly to include any carbon-based PICs other than CO. i.e., all PICs have to be expressed in terms of WCO.

Note: The equation above was derived from the DRE for specific hazardous constituents present in a waste being incinerated and described in the US Resource Conservation and Recovery Act, Title 40: Protection of the Environment, Part O, §264.343 found at http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl.

3.3 “dioxin toxic equivalent” or “TEQ” [s 1.2(o), Code] means the dioxin toxicity equivalent respect to the following toxicity equivalent factors:

Congeners Toxicity Equivalency Factor

2,3,7,8-tetrachlorodibenzo-p-dioxin 1.000 1,2,3,7,8-pentachlorodibenzo-p-dioxin 0.500 1,2,3,4,7,8-hexachlorodibenzo-p-dioxin 0.100 1,2,3,6,7,8-hexachlorodibenzo-p-dioxin 0.100 1,2,3,7,8,9-hexachlorodibenzo-p-dioxin 0.100 2,3,7,8-tetrachlorodibenzofuran 0.100 1,2,3,7,8-pentachlorodibenzofuran 0.050 2,3,4,7,8-pentachlorodibenzofuran 0.500 1,2,3,4,7,8-hexachlorodibenzofuran 0.100 1,2,3,6,7,8-hexachlorodibenzofuran 0.100 1,2,3,7,8,9-hexachlorodibenzofuran 0.100 2,3,4,6,7,8-hexachlorodibenzofuran 0.100

Note: The international system expresses the toxicity of a substance containing various D&D congeners in terms of 2,3,7,8-TCDD toxic equivalent (TEQ). The dioxin toxicity equivalent factor (TEF) applies to each and every D&D congener present in the mixture and expressed in terms of TEF for 2,3,7,8 TCDD, which is taken as the unit. TEFs have been determined for 17 congeners. The WCR identifies the 12 most common of those congeners, only. The sum of all parcels [i.e., ∑(TEF x concentration of each D&D congener)] gives the total concentration of D&D in the mixture.

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl



3.4 “halogenated organic compounds” or “XOC” means any organic substance that has in its chemical composition any of the non-metallic halogen elements including fluorine, chlorine, bromine, iodine, or astatine. XOC relevant to environmental management include chlorofluorocarbons, polychlorinated byphenyls, and dioxins and dibenzofurans.

3.5 “mobile incinerator” [s 1.2(g), Code] – means a mobile unit that is not

affixed to any location and is not operated at any one location for a total of not more than 365 days in any two (2) consecutive calendar years.

3.6 “new location”, as it applies to Section 10.3 of the Code, means a new site where the registered unit is to be operated for the first time or, if it had been operated at that site before, some of the information has changed.

3.7 “open burning” means the burning of wastes by means of an open fire and includes air curtain incinerators.

Note: Open burning of prohibited debris conducted by using open fires or air curtain incinerators require an EPEA approval or Director‘s written authorization [ADR, Schedule 1, Division 1, clause (k)] or Section 176(b) of EPEA].

3.8 “PICs” or “products of incomplete combustion” means substances that are formed due to inefficient thermal destruction and are not present in the feed to the small incinerator.

3.9 “prohibited debris” means any combustible waste that, when burned, may result in the release to the atmosphere of dense smoke, offensive odours or toxic substances and includes but is not limited to:

(a) animal manure;

(b) pathological waste (currently included in the definition of biomedical waste in the WCR);

(c) non-wooden material;

(d) waste material from building or construction sites, excluding wooden materials that do not contain wood preservatives;

(e) combustible material in automobile bodies;

(f) tires;

(g) rubber or plastic, or anything containing or coated with rubber or plastic or similar substances, except rubber or plastic attached to shredded scrap steel;

(h) used oil; or

(i) wood or wood products containing substances for the purpose of preserving wood.

3.10 “small incinerator” or “SI” [s 3(1)(h), ADR, and s 1.2(n), Code] – means

(a) a mobile incinerator that by means of burning under controlled conditions treats waste that contains

(i) halogenated organic compounds in a concentration of not more than 1000 milligrams per kilogram,



(ii) polychlorinated biphenyls in a concentration of not more than 50 milligrams per kilogram of waste,

(iii) lead in a concentration of not more than 100 milligrams per kilogram of waste, or

(iv) mercury in a concentration of not more than 2 milligrams per kilogram of waste;

or [Note: Sections 1.2(n) and 3(1)(h) of the Code and the ADR, respectively, indicate in error the word “and”, instead. This error needs to be corrected. ]

(b) a fixed incinerator that treats no more than 10 tonnes of waste per month. A fixed incinerator or more generally a fixed facility is attached to a specific location or operated at any location for a total of more than 365 days in any two (2) consecutive calendar years;

but it does not include:

(c) an incinerator used by single-family detached house to burn household waste generated by that household;

(d) an incinerator used for burning kitchen camp wastes at a mining, construction, demolition, drilling or exploration site;

(e) a crematory used to burning human bodies at a crematory licensed under the Cemeteries Act; or

(f) an incinerator authorized under the Oil and Gas Conservation Act.

Notes: Off-site and mobile incinerators are subject to EPEA authorizations, only (approvals or registrations) regardless of the origin of the waste processed [i.e., oilfield, non-oilfield or both (mixed waste)]. On-site fixed incinerators, large or small, operating at OGCA facilities are approved by the ERCB (ID 2000-03 and section 17 in Directive 058).

3.11 “steady-state” means the operation conditions of an incinerator when the main variables describing the operation of the system (i.e., temperature, turbulence, and retention time) are independent of time. At steady-state conditions of the composition of the exhaust gases exiting the SI are not time-dependent.

3.12 “specified risk material” or “SRM” means:

(a) the skull, brain, trigeminal ganglia, eyes, tonsils, spinal cord and dorsal root ganglia of cattle aged 30 months or older, and

(b) the distal ileum of cattle of all ages. 3.13 “thermal desorber” [s 1.2(p), Code] means a SI that:

(a) uses indirect heat to separate volatile organic compounds from a substrate including wastes; and

(b) destroys these volatile organic compounds, under controlled conditions, in a combustion chamber.

Note: Thermal desorbers registered under the Code of Practice for Small Incinerators differ from thermal converters defined in the Code of Practice for Energy Recovery in that thermal desorbers do not produce a fuel but rather destroy the volatile constituents of a waste in a combustion chamber.



4. TO WHOM DOES THE CODE APPLY?

A registration is required under EPEA as indicated in the ADR [section 5(2) and Schedule 2, Division 1, clause (b)] and has to be obtained by those persons who construct, operate, or reclaim a small incinerator (SI) as defined in 3.10 above. The registration is unique in the sense that:

(a) it applies to the person responsible for the specific unit identified in the registration form (Section 4.3 of the Code); and

(b) it is valid during all of the operational life of the unit.

After starting to operate the SI the person responsible shall:

(c) provide written notice to the Director on the following technical and administrative changes within fourteen days of their occurrence (section 4.4 of the Code): (i) the maximum volume of wastes treated monthly, (ii) chemical characteristics that affect waste classification, (iii) changes on the name and coordinates of the registration holder, (iv) changes on the name and coordinates of the operator of the

small incinerator;

(d) collect data on the waste characteristics and emissions as often as there is a change on the nature of the waste burned (section 7.2 of the Code);

(e) notify the director when there is an interruption on the operation of the unit that exceeds 12 consecutive months [section 8.1(b) of the Code]; and

(f) prepare an information sheet prior to operating the mobile incinerator at a new location with all the information requested by sections 10.3 and 7.2 of the Code to ensure compliance with section 6.1, as applicable, and make it available to the Director, if requested.

With respect to (d) above and how it applies to mobile incinerators, the person responsible shall collect data on the waste characteristics not only when there is a change on the characteristics of the waste processed by the unit but also any time the unit operates at a new site. It is also emphasized that the occurrence of the events that trigger (e) and (f) do not require a new registration. Registration once obtained is valid for the operational life of the unit with updates as the information initially provided changes. 4.1 What is a small Incinerator?

The definition of “small incinerator” in section 3(1)(h) of the current Activities Designation Regulation (AR263/2003 with amendments up to AR 97/2011) is incorrect and needs adjustment. The same error occurs again in the equivalent section of the Code [section 1.2(n)]. In that section, after (i)(D) the word “and” should be replaced by “or”.



The rationale is that the first part of 3(1)(h), i.e., subsection (i), applies to mobile small incinerators that are not captured under second part of 3(1)(h), i.e., subsection (ii). This part applies to fixed small incinerators, only. Subsections (i) and (ii) apply alternatively and not simultaneously. The ADR and the Code of Practice must be amended on this regard. 4.2 Fixed small incinerators

These units are generally attached to a given location or, if portable, operated within a given plant site, only. These units are available in the market with different designs, may have one or two chambers, and are generally used to destroy small quantities of easily combustible wastes. These small incinerators normally operate on a batch basis and accept wastes with similar characteristics. Anytime there is a change on the chemical characteristics of the feedstock then new testing, or equivalent information, should be obtained as section 7.2 of the Code requires. 4.3 Mobile small incinerators

All mobile incinerators including thermal desorbers that burn organic waste or contaminated soils can be quite large in terms of nominal capacity and often are used in remediation projects. Regardless of their throughput and reflecting their intermittent operation, these units are subject to the Code, and as such require a registration under EPEA, unless the waste or soils processed contain mercury, lead, PCBs, or halogenated compounds at levels that exceed the limits indicated in the definition of SI in which case an EPEA approval is required (i.e., at levels greater than 2, 100, 50, or 1000 mg/kg, respectively). See Schedule 1, Division 1, Waste Management, clause (b) of the ADR.

Given the nature of the wastes processed, their size or the irregular timing of their operations, a SI is not generally designed for energy recovery. Waste-to-energy thermal units are generally large capacity units fed by homogeneous high heating value waste or residues required by industrial processes or combustion units including heat exchangers, furnaces or boilers. 4.4 Type of wastes

The effective destruction of the organic components of wastes in a SI depends on the incinerator design and operating variables at steady-state conditions of temperature, turbulence, and retention time. These variables are determined for each particular job to reflect the nature and demands of each waste and prevent the formation of products of incomplete combustion (PICs).

In addition to combustible regular waste other wastes suitable for dedicated small incinerators include prohibited debris, biomedical waste, SRM, liquid organic waste, and organic hazardous waste that do not exceed the limits stipulated in the ADR [Schedule 1, Division 1, clause (b)] and repeated in the Code’s definition of a small incinerator. Regardless of the type of waste, the unit design, operation, emissions control, and monitoring have to be such as to meet the requirements identified in sections 5, 6 and 7 of the Code.



The operating temperature of the secondary chamber or afterburner of small incinerators used to destroy specified risk material (SRM) suspected of harboring prions that cause Bovine Spongiform Encephalopathy (BSE) commonly known as mad cow disease (MCD) or the variant in humans, Creutzfeldt-Jakob Disease (CJD), must be at least 850 degrees Celsius with a minimum retention time of 2.0 seconds. Some of the wastes that can be safely destroyed in a SI and respective recommended operating conditions are identified in Table 1.

Table 1 – Small incinerator recommended minimum operating variables

Temperature) (oC) Waste Primary

chamber Secondary chamber

Retention time (s)

DE (%)

Non-hazardous 500 870 1.0 99.0 Specific organic hazardous1 500 870 1.0 99.0 Biomedical 500 870 1.5 99.9 Animal carcasses 500 870 1.0 99.0 SRM 500 870 2.0 99.9 Halogenated2 500 1100 1.5 99.9999

1 Organic wastes with no halogenated organic compounds in their composition. 2 Not to exceed 50 mg or 1000 mg of halogenated organic compounds (XOC) per kilogram of

waste depending on the type of incinerator or halogenated compound (see Sections 6.1 to 6.3 of the Code of Practice)



5. TO WHOM DOES THE CODE NOT APPLY?

Persons responsible for pyrolysis, gasification, thermal conversion, plasma units, or other technologies that produce fuels from waste or recyclables do not fall under the scope of the Code of Practice for Small Incinerators. Depending on their nature and size, operations based on these technologies may require an EPEA approval or registration. For details consult the Schedule 1 and 2 of the ADR, the Code of Practice for Energy Recovery and related guideline at www.qp.alberta.ca and http://environment.alberta.ca/02806.html, respectively. 5.1 Thermal activities

The Code of Practice for Small Incinerators does not apply to activities that use thermal units other than incineration in a SI. Thermal units that require authorizations under EPEA include:

(a) fixed incinerators that treat more than 10 tonnes per month of waste [clause (a), Schedule 1, Division 1, ADR];

(b) mobile incinerators that treat any quantity of waste that contains XOC, PCB, lead or mercury in concentrations that exceed 1000, 50, 100, or 2 milligrams respectively, of any one of these chemicals per kilogram of waste [clause (b), Schedule 1, Division 1, ADR];

(c) the open burning of prohibited debris including the burning using an air curtain incinerator. These activities require either an EPEA approval [clause (k), Schedule 1, Division 1, ADR] or the Director’s written authorization;

(d) thermal converters that process waste or recyclables into fuels which may require registration or approval under EPEA [clause (c) or (d) of Schedule 1 or 2, respectively, Division 1, ADR]; or

(e) the burning of waste as fuel registered under the Code of Practice for Energy Recovery [clause (d) of Schedule 2, Division 1, ADR].

5.2 Exempted small incinerator units

On the other hand, some small incinerators do not meet the definition of SI and are exempted under EPEA. These include:

(a) a small incinerator used by single-family detached house to burn household waste generated by that household;

(b) a small incinerator used for burning kitchen camp wastes at a mining, construction, demolition, drilling or exploration site;

(c) a crematory used to burning human bodies licensed under the Cemeteries Act by the Alberta Funeral Services Regulatory Board (information at http://www.afsrb.ab.ca); or

(d) a small incinerator authorized under the OGCA.



http://www.afsrb.ab.ca/



The exemptions (a) to (d) above do not constitute an authorization for on-site open burning of waste, prohibited debris, household hazardous waste, or any one or more of the wastes affected. The operation of exempted units still has to respect environmental sound management practices and comply with the SRR emission requirements, specifically, PM and opacity. Any unauthorized release from these units has to be reported as required by the Release Reporting Regulation. The Code exemptions are further discussed next.

5.2.1 Single-family detached dwelling

Small incinerators, often a modified open top metal drum, used by one single-family detached dwelling to burn household waste from that dwelling occur mostly at farmhouses or isolated rural homes. Household waste means waste that is generated by a residence where a social human unit lives together, but it should not include household hazardous waste, waste generated from the operation of a business or from an industrial activity. Small incinerators used by a multi-family dwelling such as an apartment building or complex need a registration and must comply with the Code of Practice. Some municipalities have backyard fire pits or waste related by-laws and should be contacted prior to the on-site burning of any debris, wood residues or wastes.

5.2.2 Temporary kitchen camps

Kitchen camp wastes from mining, construction, demolition, drilling or exploration sites are generally produced in limited amounts, on a temporary basis, and often at remote locations. Small incinerators, generally mobile units, used to manage suitable wastes from these camps are exempted from registration. 5.2.3 Crematoriums approved under the Cemeteries Act

An incinerator used only to burn human bodies as part of a crematory that is licensed under the Cemeteries Act does not require an EPEA authorization. However, human body crematories shall meet the air emissions limits stipulated in the Substance Release Regulation for opacity and particulate matter, 40% and 0.20 grams per kilogram of effluent, respectively. For additional detail consult Sections 4 and 8 of the SRR at www.qp.alberta.ca 5.2.4 Activity approved by the ERCB under the OGCA

Oil and gas exploration and production sites and related waste management activities are regulated by the ERCB. Fixed small or large incinerators operating at oil and gas sites are subject to ERCB approvals or exempt. Directive 058, Oilfield Waste Management Requirements for the Upstream Oil and Gas Industry details in section 17, and specifically 17.3 and 17.4 applicable to small units, the siting, design, and operational requirements as well as the emission standards applicable to fixed incinerators handling oilfield waste on-site. No EPEA registration is required for on-site small incinerators that burn oilfield waste.

Consequently, 5.2(d) above applies only to fixed units operating at facilities approved under the OGCA. Operators of these fixed incinerators have to respect the requirements set by the ERCB.




When the SI is a mobile unit operating at upstream oil and gas sites and burning oilfield waste other than kitchen camp waste then the unit is subject to EPEA as indicated in the first bullet of section 3.1(b) of the joint ESRD/ERCB Memorandum of Understanding MOU on the Harmonization of Waste Management (ID 2000-03). Depending on the quality of the waste burned, the unit may require registration or approval, as applicable.

Jurisdictional regulatory responsibilities are dealt with in ID 2000-03 and in the related MOU referred above. Both D058 and ID 2000-03 are available at http://www.ercb.ca/regulations-and-directives/directives 5.2.5 Incinerators that burn mixed waste

All off-site incinerators and other thermal treatment units, including mobile incinerators that treat any kind of waste regardless of their origin (i.e., oilfield, non-oilfield, or mixed waste) are subject to EPEA and require an approval or a registration from ESRD.

To clarify which regulator is the agency responsible for waste management activities, the two main organizations in this area, ESRD and the ERCB, have formalized their agreement in aforementioned MOU. This memorandum identifies principles, objectives, and responsibilities of the two agencies in terms of waste management under a policy based on “one regulator, one approval, one site” for the activities these agencies regulate

A facility receiving mixed waste requires approval from ESRD when the smaller fraction of the two different types of wastes received (i.e., oilfield or non-oilfield waste) exceeds 25%. Let us illustrate the concept: a facility or unit approved to receive oilfield waste may receive up to 25% of non-oilfield waste before being considered a mix waste facility and, as a result, requiring approval or registration under EPEA. See Section 2 of the MOU identified above. 5.2.6 More than one activity covered by one EPEA approval

ESRD issues authorizations that are as comprehensive as possible to cover all on-site activities undertaken at the same site regardless of their number and nature. These multiple activities that in isolation may each require an approval, registration, or notice can then be covered by just one ESRD authorization. The Director may combine in same approval one or more activities regardless their nature, number and the authorization needed. For example, a small incinerator does not require a registration number when it is operated as part of an industrial complex that has an EPEA approval to operate. This brings efficiency to regulation by reducing the number of approving documents required.

This matter is dealt with in Section 14(3) of the WCR and Section 6 of the ADR.

http://www.ercb.ca/regulations-and-directives/directives



6. AUTHORIZATIONS TO OPERATE INCINERATORS

The authorizations required operating incinerators pursuant to EPEA, OGCA, or the Cemeteries Act are summarized in Table 2. The Table identifies fixed incinerators, mobile incinerators, and crematoria regulated by ESRD, the ERCB, or the Alberta Funeral Services Regulatory Board.

Table 2 – EPEA authorizations required for incinerators in Alberta

Incinerator Type Approval Registration Exempted

Fixed incinerators > 10 tonne/ month 10 tonne/month Oil & gas sites (any size)1

X - -

- X -

- - -

Mobile incinerators/desorbers Any size or any waste origin Waste with [Pb]2 > 100, or [Hg]2 > 2, or [XOC]2 > 1000, or [PCB]2 > 50

-

X

X -

- -

Crematoria Human bodies3 Pet crematoria

- -

- X

X -

Exempted small incinerators4

-

-

Yes

1 Fixed incinerators, large or small, operating at upstream oil and gas facilities regulated by the ERCB are subject to Directive 058. See section 5.2.4 of this Guide.

2 [Concentrations] in mg/kg; [XOC] means halogenated organic compounds. 3 Crematoria for human bodies/parts are regulated under the Cemeteries Act administered by

the Alberta Funeral Services Regulatory Board (http://www.afsrb.ab.ca). However, “pet crematoriums” are incinerators subject to EPEA. Their operation is under registration or approval, as the case might be.

4 Exempted small incinerators are identified in sections 3(1)(h)(iii) to 3(1)(h)(vi) of the Code.




7. HOW TO REGISTER? Except for the situations identified in Section 5, a person operating a small incinerator is required to apply for a registration from ESRD and Water. Small incinerators include:

(a) fixed incinerators that treat no more than 10 tonnes of waste per month. A fixed small incinerator is attached to a specific location or operated at any given location for a total of more than 365 days in two consecutive calendar years.

OR (b) mobile incinerators that burn any quantity of waste that does not

contain

(i) halogenated organic compounds in excess of 1000 milligrams per kilogram of waste,

(ii) polychlorinated biphenyls in excess of 50 milligrams per kilogram of waste,

(iii) lead in excess of 100 milligrams per kilogram of waste, or

(iv) mercury in excess of 2 milligrams per kilogram of waste Prior to obtaining an ESRD registration, the person responsible shall acquire any other authorization that may be needed. For example, local municipality’s special permits, proper zoning or operational restrictions may apply to the operation of small incinerators within their jurisdiction. 7.1 Application Form

The form in Schedule 1 of the Code is to be used when submitting an application for registration of the small incinerator. The application must include ALL the information identified in the Schedule. Subsection 4.2 of the Code requires that the information referred to in clause (f) of Schedule 1 be assessed, signed and stamped by a Professional Engineer, the manufacturer or the supplier of the unit. Delays in registration completion caused by missing information affect the operation start up. For more information on the registration process contact the respective ESRD regional office at http://environment.alberta.ca/01549.html. Completed applications for registration should be sent to the ESRD Regulatory Approvals Centre (RAC) at: Regulatory Approvals Centre

Main Floor Oxbridge Place Phone 780 427 6311 9820 106 Street Fax 780 422 0154 Edmonton Alberta T5K 2J6 Email [email protected]





When received at RAC, this office will record the application and forward it to the appropriate ESRD regional office for review and issuance of the registration number. For consistency and illustration purposes, an example of a registration template issued under the Code is attached as Appendix 2.



8. ANALYSES REQUIRED

The waste generator has the obligation of testing representative samples to properly characterize, classify, and manage the waste in compliance with applicable legislation and minimize liabilities (EPEA, WCR, and TDGR). The nature, characteristics, classification, and management options available dictate the type and extent of analytical protocol for a particular waste. Section 3 of the Code includes laboratory accreditation requirements familiar to most laboratories. The accreditation required from the Standards Council of Canada (SCC) includes those cases where a laboratory is accredited, for the specific parameter analyzed, by an organization designated for that purposes by the SCC. 8.1 What to test a waste for?

Table 3 illustrates three analytical protocols applicable to a specific industrial waste – API separator sludge from petroleum refining – that upon classification is intended for landfill disposal with or without further treatment. Like for any other waste, this particular one has to be properly characterized, classified, and managed to be in compliance with applicable legislation. Table 3 illustrates how classification and two potential alternative management options – incineration vs. landfill disposal – affect analytical protocols.

Table 3 – Analytical protocol for sludge from oil refinery

Parameter

Classification Thermal

Destruction

Landfill Disposal

pH X X X Chemistry1 - X - TCLP BTEX2 X X TCLP metals3 X X Total metals4 X Flash point X X X Heat value X

1 Comprehensive chemistry not required for this waste (see Table 4). 2 Toxicity Characteristic Leaching Procedure (TCLP) BTEX: benzene, toluene, ethyl benzene,

and xylenes in TCLP leachates. 3 Metals in TCLP leachate: As, Cd, Cr, Pb, and Hg 4 Total metals: As, Cd, Cu, Pb, Hg, Ni, and Zn. To assess the suitability of an organic waste for incineration it is critical to gather specific information on the origin, nature, chemical processes and chemistry of the waste. In this particular case, it appears that halogenated organic compounds (XOC) and polychlorinated organic compounds (PCB) are not parameters relevant to the assessment and as a result there are no reasons to believe that these compounds may be present in the waste. Each waste has to be addressed on their own merits in a comprehensive and integrated manner including taking into account the legal and economic options available for its management.



8.2 Frequency of analysis of wastes and emissions

More generally, and in relation to Section 7.2 of the Code, the frequency of testing wastes and exhaust gases for purposes of compliance with 6.1 and 6.2 is dictated by the nature of the waste, changes over time to its chemistry, and how this chemistry affects the composition of the exhaust gases. As a rule only a significant change would trigger re-testing. By significant we mean a change in the chemical make up, a different waste, or concentration of key constituents of the waste. The following examples illustrate these triggers:

a SI that is changing from processing hydrocarbon contaminated soils to soils containing wood preservatives such as creosote, pentachlorophenol, or copper-chromium-arsenic;

a SI that burns spent activated carbon containing BTEX and then receives a batch of paint residue with PCBs; or

a SI that routinely receives oily rags and produced water filters and wants to expand to lead-based wastes such as pipe dope, greases, or sensing tape.

The parameters to be analyzed on wastes and exhaust gases when operating a small incinerator include those identified in Sections 6 and 7 of the Code. These should be adjusted as needed to reflect the chemistry of the waste being burned. The testing required on wastes/soils parameters, frequency, and the operational and emission limits is summarized in Table 4.



Table 4 – Analytical parameters and testing frequency for SI

Limits

Analysis

Parameters

Frequency Primary chamber

Secondary chamber

Waste/Soils

Chemistry1 PCB XOC2 Pb Hg2 Heat value

Prior to & during operation

Waste changes

New location

- 50 mg/kg 50 mg/kg 100 mg/kg 2 mg/kg

- 50 mg/kg 1000 mg/kg 100 mg/kg 2 mg/kg

Stack sample

Particulates HCl NOx SOx CO CO2 D&D2 Hg2 Opacity3 Metals

Within 6 months upon starting operations

or

As request by the Director

50 mg/Rm3 75 mg/Rm3

- -

57 mg/Rm3 -

80 pg/Rm3 20 μg/Rm3

20% -

One-chamber batch SI Two-chambers SI Thermal desorber

Temperature Temperature Temperature

Not continuously Continuously Continuously

≥ 500 oC ≥ 500 oC

> Tb4

- 870 oC 870 oC

1 Chemistry may include pH, C, O, N, H2O, S, halogens, ash content, and specific parameters defined on a case-by-case basis such as heavy metals, XOC, PCB, TOC, organic fraction, state, viscosity, heat value, etc.

2 Apply only when burning waste with XOC, lead, or mercury in which cases the exhaust gas may have D&D or Hg that exceeds the limits indicated

3 Opacity is determined by a visible emissions reader, not as part of a manual stack survey. 4 Tb is the boiling point temperature, in degrees Celsius, of the least volatile chemical in the

waste or soils being processed.



9. DESIGN REQUIREMENTS

Section 5 of the Code identifies minimum design requirements for either a single chamber or a dual chamber SI. The Code of Practice sets out operational criteria (summarized in Table 1 of this Guide) and identifies emission limits for small incinerators but does not set out detailed design criteria. The design has to be such as to incorporate the necessary features in terms of incinerator capability for measuring and recording operational data referred to in Section 5 of the Code and include appropriate flue gas control systems that ensure compliance with emission criteria identified in Section 6.2. 9.1 Flue gas treatment systems

In addition to the mandatory features identified in Section 5 of the Code, it is the operator’s responsibility to decide on the type of flue gas treatment system(s) required to achieve the parameters set out in 6.2 of the Code. Most operators will choose these systems based on the type of waste to be burned. For example, an emissions control system to curb acid gases from the flue gas could be a wet scrubber or a dry scrubber. A wet scrubber would usually be operated in a manner that maintains the pH of the scrubbing solution at greater than 7. In conditions where that pH cannot be maintained, a system such as a dry scrubber could be utilized.

A particulate emission control system, such as a wet scrubber, electrostatic precipitator or a baghouse, could be used to remove particulates from the flue gas. If a wet scrubber or a baghouse is used, the following are suggestions on how they could be installed, maintained, and operated: 9.1.1 Wet Scrubbers

A wet scrubber is an air pollution control device that removes PM and/or other unwanted pollutants from a gas stream, in this case the SI exhaust gas, by bringing the target PM or compounds with the liquid scrubbing solution. The scrubbing liquid may be simply water or solutions with defined reagents that specifically target certain constituents of the exhaust gas.

(a) A small incinerator using a wet scrubber to control particulate emissions should include:

(i) a water pump of sufficient size that will provide circulation capacity for proper scrubber operation, and

(ii) a pressure gauge, capable of reading the pressure at the outlet of the scrubber water supply pump to the nearest 50 kPa.

(b) The scrubber water return system of a small incinerator equipped with a wet scrubber should be operated to ensure that there is sufficient retention time in the system to settle out collected dust and sediments.



(c) When operating a wet scrubber it is important to inspect it daily and record the following: (i) date of operation, (ii) hours of operation, (iii) amount of settlement in the scrubber water measured (mg/L), (iv) pump pressure, (kPa), (v) conditions of hoses/couplings (leak or no leak), (vi) opacity condition of the plume (visual observation), (vii) name(s) of operator who made observations for log, and (viii) signature of person responsible for the measurements.

(d) A person operating a small incinerator equipped with a wet scrubber, may also want to, at least once per calendar year:

(i) conduct a pump capacity test on the outlet of the scrubber water supply pump, and

(ii) measure for and record the following: (A) date of test, (B) name of operator responsible for the measurements, (C) container capacity, (D) test run number (make a total of three runs), (E) time to fill, (minutes), and (F) average flow rate for each test run.

9.1.2 Baghouses

A baghouse is an air pollution control device or facility in which a gas stream from industrial processes including combustion or incineration is obliged to pass through a fabric filtering media to remove particulate matter from the gas stream. A person operating a SI equipped with a baghouse should:

(a) inspect, measure, and record each operating day the following: (i) date of operation, (ii) hours of operation during that day, (iii) evidence of dust on the outlet (clean) side of baghouse

(yes/no), (iv) opacity condition of the plume (visual observation), (v) name(s) of operator responsible for observations for that date

of observation, and (vi) signature of operator responsible for observations.

(b) A person operating a SI equipped with a baghouse system should

also test the baghouse system using fluorescent tracer dust (i) within the first week of commencement of operation in each

calendar year, (ii) once every 200 operating hours, and (iii) when the small incinerator is moved to a new location,

(c) When conducting a test of the baghouse system using fluorescent tracer dust, it is important to measure and record the following: (i) date of tracer dust test,



(ii) location of injection of tracer dust, (iii) amount of tracer dust injected, (iv) type of tracer dust used, (v) evidence of tracer dust observed on the outlet of the baghouse

(yes/no), (vi) name of operator responsible for tracer dust test, and (vii) signature of operator responsible for tracer dust test.

(d) Usually fluorescent tracer dust tests are conducted by:

(i) putting fluorescent tracer dust into the inlet side of the baghouse, and inspecting the baghouse to determine whether any fluorescent tracer dust bypasses the baghouse, or

(ii) if access to the outlet of the baghouse is impractical, installing an access hatch near the inlet to the draft air fan.



10. OPERATIONAL REQUIREMENTS A small incinerator has to be designed in a manner that its operational variables – temperature, retention time, and turbulence - may be adjusted as required to reflect the nature of the waste, the different conditions that may arise, and to ensure that the destruction removal efficiency identified in Table 1 of this Guide is being achieved. 10.1 Wastes that cannot be burned in a small incinerator

A small incinerator that has only a primary chamber cannot burn the type of wastes identified in Section 6(1) of the Code. The prohibitions against burning these substances in this type of small incinerators have been set to prevent the release of smoke, odors or toxic substances to the atmosphere. The person responsible for a two chamber small incinerator that burns wastes with concentration in excess of the limits indicated in Section 6.1 of the Code has to complete a manual stack survey as per Section 7.2 of the Code. 10.2 Operational data

Critical operational data has to be provided with the application for registration or collected and recorded during normal operations to ensure compliance with the Code requirements. These data includes the following in addition to the operational information required in the application form in the Schedule:

Waste characteristics (Section 6.1), and

Expected or actual emission data (Section 6.2)

The data shall be collected prior to filing the application for registration and, thereafter, as often as there is change on the nature of the waste in terms of halogenated organic compounds, lead or mercury. Similarly, changes to the actual emission data resulting from design modifications or waste quality should be measured and recorded as per Section 7.2. 10.3 Collection of the technical data

Often, the same model of a small incinerator is provided to many users. In these cases, the technical data regarding registration information, design features, operating conditions, and emission data are generally collected, assessed, and gathered in a user’s guidance document provided by the manufacturer of the equipment. Copies of relevant data, equipment service, and contacts of the professional involved in designing and assessing this equipment and technical information are available from these companies instead of the user (often small service companies, small operations, or farmers).

In these situations and for purposes of compliance with Section 4.2 of the Code and in relation to the complex data required by Sections 4, 5, and 6 of the same document, ESRD and its Directors are prepared to accept legitimate manufacturer/supplier data for purpose of compliance with the Code of Practice.



10.4 The presence of halogens, lead or mercury

The limits for halogens, lead and mercury in Section 6.1 of the Code have been established to prevent pollution by limiting the burning in small incinerators of D&D-forming compounds and to limit the concentration of low boiling point metals in the flue gas. These restrictions bound the total amount of pollutants that may be released and facilitate Alberta’s compliance with the CCME Canada Wide Standards for D&D and Mercury.



11. MONITORING REQUIREMENTS

A person responsible for one-chamber SI shall not burn waste that exceeds the following limits:

Halogenated organic carbon > 50 mg/kg Lead > 100 mg/kg Mercury > 2 mg/kg

A person operating a two-chamber SI burning waste that exceeds the limits indicated above shall conduct a manual stack survey within six months after starting burning that type of wastes. At the Directors’ discretion, a manual stack survey may not be required when equivalent and credible compliance data is available from previous treatability, performance, and/or auditing testing conducted in another jurisdiction and that work is acceptable to the Director.

The person responsible for the two-chamber small incinerator shall conduct a manual stack survey within six months of the date on which the unit started to burning waste that contains any one or more of the relevant constituents in excess of the limits indicated in Section 7.3 of the Code or when the Director so requests in writing. The Director’s discretionary stack test requirement applies to small incinerators either with one or two chambers. Factors that may be considered by the Director in determining whether a stack test is required, include:

the location, the type and quantity of waste to be burned, non-compliance issues, and the small incinerator demonstrated design performance.

As per Section 7 of the Code of Practice, stack testing samples only need to be analyzed for the parameters that characterize the exhaust stack emissions (see Table 3). However, it is critical to be able to correlate those test results with the corresponding chemistry of the wastes (surrogate or not) being burned. The manual stack survey has to be representative of the waste being burned and enable evaluation of the incinerator performance at that time. This requires knowledge of the concentration of the critical constituents of the waste (XOC, lead, and mercury) being processed. The information requested in clause (f)(ix) of the Code’s application form in Schedule 1 and the data to be collected for compliance with 7.2 on monitoring requirements needs some clarification. The first is to be provided once prior to registration and operation of the unit. It is constituted by “information on the source, quantity, and chemical characteristics of wastes or contaminated soils expected to be processed”. It is general in nature and should reflect the type, design and capability of the small incinerator. The second, also related by reference to 6.1, is collected for compliance purposes represents specific “data on the waste characteristics, including the



concentrations of halogenated organic compounds, lead, and mercury when these chemicals are present or suspected of being present in the waste or contaminated soil”. This data is to be collected as part of the on-going operations for compliance purposes prior to burning different waste streams and/or, in the case of mobile units, when it moves to a different location. It is the operator’s responsibility to obtain enough analytical information on the characteristics of the waste to satisfy Section 6.1 of the Code.



12. RECORD KEEPING AND REPORTING

Section 7 of the Code of Practice specifies the information that must be recorded and maintained for the operation of a small incinerator, such as all stack test results. It is not necessary to submit the records for the small incinerator to ESRD on a regular basis; however the records must be kept for a minimum of five years from the date that the information was recorded. Section 8 of the Code of Practice specifies requirements for reporting information to the Director or inspector, including:

any contravention of the Code of Practice, information requested by an inspector, results of stack testing within 60 days of the completion of the test, and an information sheet with respect to a mobile incinerator.

The notification requirements in Section 6 of the Code of Practice for SI ensure that ESRD has up-to-date information on small incinerators operating and ceasing operations within Alberta.



13. AMENDMENT OF THE CODE OF PRACTICE

The Code of Practice may be amended from time to time to address issues and problems that are identified, as well as changes to technology and standards. To assist in these amendments, persons with concerns and comments can provide their comments and concerns in writing to Director. 14. MORE INFORMATION ON THE CODE OF PRACTICE More information about this Code of Practice for SI can be obtained through any regional office of ESRD. Regional and District offices located in Calgary, Red Deer and Peace River can be contacted toll free by dialing 310-0000 and asking the operator to put you through to the regional office closest to you at the telephone numbers listed below. Northern Region District Offices

Northern Region - Peace River District Bag 900-5, Provincial Bldg Peace River, Alberta T8S 1T4 Telephone: 780-624-6167 Fax: 780-624-6335 Contact Peace River District

Northern Region - Edmonton District 111, 4999 - 98 Avenue Edmonton, Alberta T6B 2X3 Telephone: 780-427-5296 Fax: 780-427-7824 Contact Edmonton District

Central Region District Offices

Central Region - Spruce Grove District Suite 1, 250 Diamond Avenue Spruce Grove, Alberta T7X 4C7 Telephone: 780-960-8600 Fax: 780-960-8605 Contact Spruce Grove District

Central Region - Red Deer District 3rd Floor, 4920 - 51 Street Red Deer, Alberta T4N 6K8 Telephone: 403-340-7052 Fax: 403-340-5022 Contact Red Deer District

Southern Region District Offices

Southern Region - Calgary District 2938 - 11 Street NE Calgary, Alberta T2E 7L7 Telephone: 403-297-7602 Fax: 403-297-6069

Southern Region - Lethbridge District 200 - 5 Ave South, Provincial Bldg Lethbridge, Alberta T1J 4L1 Telephone: 403-381-5322 Fax: 403-382-4428







APPENDIX 1

REGISTRATION TEMPLATE

REGISTRATION

PROVINCE OF ALBERTA

ENVIRONMENTAL PROTECTION AND ENHANCEMENT ACT

R.S.A. 2000, c.E-12, as amended

999999-00-00 REGISTRATION NO.

001-999999 APPLICATION NO. May 23, 2012 EFFECTIVE DATE: CleanBurn Ltd. REGISTRATION HOLDER

REGISTRATION IS ISSUED FOR THE FOLLOWING ACTIVITY:

the construction, operation and reclamation of a small incinerator located at Hwy 111 - P.O. Box 11, Small Valley, Alberta W0Z 8Y8, for <<a mobile small incinerator>>

IS SUBJECT TO THE CODE OF PRACTICE FOR SMALL INCINERATORS, SEPTEMBER 2005, AS AMENDED

Viriathus Terror Romanorum Designated Director under the Act

May 23, 2012 Date Signed



APPENDIX 2

FREQUENTLY ASKED QUESTIONS

1. Are Alberta Environment and Sustainable Resource Development (ESRD) registrations to operate a small incinerator issued from 1993 to 2005 still valid?

Yes, they are. These registrations to operate a small incinerator were issued by ESRD as required by Section 5 of the ADR and in compliance with drafts of Code of Practice for Small Incinerators circulated by ESRD though the regulated community for that purpose. As from September 2005 on, the holders of those registrations have to operate their units in adherence to the current Code of Practice for Small Incinerators as mandated by the WCR. 2. Is the operation of a human body crematory subject to this Code of

Practice?

No. Specifically, these units are exempt from registration pursuant to this Code of Practice. However, this Code might be useful as a reference. Human body crematories are regulated under the Cemeteries Act and the Crematory Regulation administered by the Alberta Funeral Services Regulatory Board (AFSRB). The burning (incineration) of human bodies at a crematory requires a license issues by this Board. Authorization from the local municipality is also required. More specific information and application forms for a license can be obtained by contacting the AFSRB at http://www.afsrb.ab.ca. 3. Is the operation of a human body crematory subject to emission

standards set in the Substance Release Regulation?

Yes. In terms of emission standards, the design, construction, and operation of a crematory must respect the emission standards set in the Substance Release Regulation for PM and opacity. This regulation as well as this Code is available at http://www.qp.alberta.ca . To obtain information with respect to consultants qualified to conduct an assessment of the crematory emission versus environmental requirements as set in the SRR contact the Environmental Services Association of Alberta toll-free at 1800 661 9278 or visit their web site www.esaa.org. 4. Do small incinerators used to burn dead animals or other animal

wastes require a registration under the Code?

Yes. Small incinerators used at farms or elsewhere to burn dead animals, parts of dead animals, or other animal waste, under controlled conditions, are not exempt and require compliance with this Code of Practice. The management of dead animals is also subject to the requirements of the Destruction and Disposal of Dead Animals Regulation under the Livestock Diseases Act. This legislation is available at http://www.qp.alberta.ca.



http://www.esaa.org/




5. Does a crematory burning pets require registration under the Code?

Yes, if the pet crematory meets the definition of small incinerator. A small incinerator burning pets or other animal waste is not a crematory as defined in the Cemeteries Act. 6. Does the registration holder of a small mobile incinerator have to

apply for a new registration each time the unit starts to operate at a different location?

No. However, every time that a small mobile incinerator, moves to a different location, the registration holder has to gather, record, and keep the information required under the following Sections:

(a) 6.1 and 6.2 as specified in Section 7.2 on the waste and emissions characteristics, if the waste to be processed is different from previously processed wastes, and

(b) 10.3 on registration information as it applies to the new site. 7. Does a mobile small incinerator require ESRD registration if it

operates at a drilling camp incinerating kitchen and camp wastes only?

No. Small incinerators burning kitchen and camp waste are exempt from registration under the Code. Even upstream oil and gas operators of this type of units are exempt from ERCB approvals. However, they have to meet Section 17 of ERCB Directive 58. 8. Can a small incinerator destroy specified risk material (SRM) waste?

Yes, if the following operational variables under steady-state conditions respect the following requirements which are consistent with the Canadian Food Inspection Agency standards:

(e) the operating temperature in the secondary chamber exceeds 850 degrees Celsius,

(f) the retention time exceeds 2.0 seconds, and

(g) appropriate turbulence in the primary and secondary chambers is maintained.

9. May a small incinerator burn PCB waste?

Only if the unit is a fixed small incinerator that meets Sections 6.1, 6.2, 6.3, and 7.3 of the Code. PCB waste is defined as waste that contains PCBs at a concentration of 50 milligrams or more of PCB per kilogram of waste. Mobile incinerators cannot process PCB waste unless the person responsible holds an EPEA approval. Note that these requirements are consistent with the ADR, the Code, and federal PCB Regulations. 10. Are all mobile incinerators subject to registration or approval

depending on the waste they burn?



Not necessarily. See section 5.2.4 of this Guide.

An interesting situation arises when the mobile incinerator operates at oil and gas sites and burns kitchen camp waste, only. These incinerators are exempted pursuant EPEA and the OGCA but consideration should be given to provisions 17.3 and 17.4 of Directive 058 and compliance with the standards set by the Substance Release Regulation for opacity and particulate matter (PM). Opacity and PM at steady-state operating conditions shall not exceed 40% and 0.60 grams per kilogram of effluent, respectively.

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