VERTAC CHEMICAL CORPORATIONJACKSONVILLE, ARKANSAS PLANT SITE

CLOSURE PLAN

Submitted To

Arkansas Department of PollutionControl and the Environment

JANUARY 1985

LIST OF FIGURES

Figure No. Title Page

1 Closure Schedule 52 Vertac Waste Storage Area 73 Simplified Schematic of Vertac

Waste Destruction System 94 Simplified Schematic of Vertac

Operations Plan 10

5 MWP-2000 Process Flow Diagram 126 Vertac Waste Destruction

System Layout 14

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TABLE OF CONTENTS

Title

IntroductionWaste InventoryClosure ScheduleWaste Storage LocationsStored Waste Destruction MethodOverview-Closure Operation DescriptionIncinerator Process DescriptionStack Emissions MonitoringAppendix A Health and Safety Plan

B Spill Prevention Controland Countermeasures Plan

C MKP-2000 Operations Manual

VERTAC CHEMICAL CORPORATIONJACKSONVILLE, ARKANSAS PLANT SITE

CLOSURE PLAN

INTRODUCTION

The following plan has been developed to meet the standards of theFederal Resource Conservation and Recovery Act and the ArkansasHazardous Haste Management Act. The plan identifies all steps that willbe necessary to close the Jacksonville. Arkansas 2.4-D and 2,4,5-Twaste storage areas.

This plan has been prepared to ensure that the closure operations areaccomplished in a manner which:

• Eliminates the need for further hazardouswaste storage site maintenance

• Eliminates a threat to human health and theenvironment, post-closure escape ofhazardous waste, hazardous waste

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constituents, leachate, contaminatedrainfall, or waste decomposition productsto the ground or surface waters or to theatmosphere.

WASTE INVENTORY

The following inventory is based on an inventory conducted on February12 , 1982. The plant has continued to produce 2,4-D since that date. Anestimate of the total 2,4-D waste on-hand is provided.

1. 2 , 4 , 5 - T Still Bottoms and miscellaneous trash -2,747 drums. Generalchemical composition:

1 percent methanol8 percent toluene3 percent Di and Trichlorobenzene18 percent Dichloro Dimethoxybenzene56 percent 2,4,5-Trlchloro Anisole

7 percent Sodium salt of 2,4,5-Trlchlorophenol7 percent Sodium salt of 2 , 4 , 5 - T2, 3 , 7 , 8 - T C D D , 15-50 ppn

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2. 2.4-D Still Bottoms-15,000 total drums estimated. 9,472 drums plustwo 20,000-gallon vessels generated prior to February, 1982. 2,578 of

these druns were generated prior to May 12 , 1980. General chemicalcomposition:

25 percent 2,4-Dlchlorophenoxyacetlc Acid20 percent Bis 2,4-Dichlorophenoxacetic Acid40 percent 2,6-Dichlorophenoxyacetic Acid10 percent Orthochlorophenoxyacetic Acid5 percent 2 , 4 ,6-Tnchorophenoxyacetic Acid

3. Hazardous Trash

7.728 cu ft of crushed drums and trash from theretired 2,4,5-T still bottom storage field

66 empty yellow drums and 47 empty black drumsthat had contained 2 . 4 , 5 - T still bottoms

Approximately 700 empty drums that had been

used to transfer and contain wet 2 , 4 . 5 - T

4. Trash (Declared hazardous by Vertac)

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347 drums containing filter paper contaminatedby 2,4-D within the process

45 drums of floor sweepings used for cleaning2,4-D process areas

13 drums of contaminated soil picked up from

the 2,4-D bottoms storage area

35 drums of insulation and trash contaminatedby chlorobenzenes

24 boxes of trash, each box containing 7 empty

methyl chloroproplonic acid sacks

645 cubic feet of flattened boxes that had'beenused to transfer and contain 2.4-D

CLOSURE SCHEDULE

The projected schedule for closure of the Vertac site is depicted In

Figure 1. Initiation of closure activities are scheduled to commence

____________————————————_____———————————__________ EHSCO—

VERTAC CLOSURE PROJECT SCHEDULE

,-)

• / >D /»->'

FIG. 1- VERTAC CLOSURE SCHEDULE

ssr>0

~—-—-^^^ MONTH

ACTIVITY ^—^^^

SUBMIT PERMITAMENDMENT APPLICATIONS

REGULATORY REVIEW f,~1ayi

REGULATORY APPROVAL

LUUIrMUN 1 MUtWULA IIUn

SYSTEM START-UP

cininnmi

1-85

k*stftV^

2-8;

•

3-85 4-85 5-85

^

6-B5

———

7-85 B-6;

—

0

9-B5 10-8; 1 1 - 8 ; 12-8; 1-86

0

2-86 3-86 4-86 5-86 6-86 7-86

0 0 5 5 5 8

\\ \'. /January 2, 1986, subject to regulatory approval. \ \

WASTE STORAGE LOCATIONS

Stored wastes are located in three general plant locations as depictedIn Figure 2 , Stored Waste Locations. Stored 2,4,5-T wastes are locatedIn a 30000 sq ft shed In the northern portion of the plant site.Hazardous trash Is stored in a 10000 sg ft building adjacent to the2,4,5-T waste storage shed.

STORED WASTE DESTRUCTION METHOD

The potential hazards of transporting stored Jacksonville plant wastesdirects the use of an on-site disposal method. Due to the nature andtypes of stored wastes, thermal destruction is the method of choice forstorage site closure.

Vertac will use a mobile, high temperature Incinerator to destroy

stored 2,4-D and 2,4.5-T wastes. The incinerator was developed byPyrotech Systems, a wholly-owned subsidiary of ENSCO.

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OVERVIEW-CLOSURE OPERATION DESCRIPTION

A simplified schematic of the Vertac Waste Destruction System isdepicted in Figure 3. Wastes will be managed as follows:

2,4-D Wastes; The 2,4-D wastes are currently stored adjacent to theIncineration site in plastic, metal, and overpack drums. The 2,4-Dwaste will be injected into the incineration system at two points, theafterburner, and rotary kiln. The material balance and schedule of burnactivities is depicted in Figure 4. During the incineration of 2 , 4 , 5 - Twastes, Phase 1 . the 2,4-D wastes will serve as an auxiliary fuel inthe afterburner. Upon destruction of 2,4,5-T wastes, 2,4-D wastes willbe destroyed in both the rotary kiln and afterburner. Phase 2.

Preparing the 2,4-D wastes for use in the afterburner will require thede-heading of the drums and dumping of the solid still bottoms materialinto a heated blend/feed tank in order to liquify the material. Plasticdrums will be fed directly to the rotary kiln. Empty metal drums may bedecontaminated utilizing a solvent. Spent solvent will be blended with2,4-D waste in the blend/feed tank. Clean metal drums will be crushedand recycled. Sound overpack drums will be decontaminated utilizing a

solvent, accumulated, and used for ash containment prior to disposal.

2,4,5-T Wastes: The 2,4,5-T wastes are located in an area approximately1000 ft north of the Incinerator pad. A closed, capped landfill

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PLASTIC DRUMS

2 ,4 -D

W A S T E S

STEEL DRUM

DE- HEADING

BLEND/FEED

TANK

MWP-2000

SYSTEM

LIQUID WASTE

MANAGEMENT

SOLVENT ASH

STEEL DRUM

DECONTAMINATION

STEEL DRUMS ASHMANAGEMENTS

DISPOSAL

COMPACTEDDRUMS TO

STEEL RECYCLES

W A S T E S

TRANSPORTATIONTO

INCINERATORSITE

FIGURE 3 SIMPLIFIED SCHEMATIC OF VERTAC WASTE DISPOSAL SYSTEM

0 0 5 5 6 1

T- W A S T E S3000 DRUMS

1,500,000 Ibs.

23001b/hr.652hrs.

I^XIO^b.

> K I L N AFTERBURNER

D - W A S T E S10,000 DRUMS5 ,000,000 Ib.

METAL DRUMS

MELT

2275 Ib./hr.652 hrs. '1.46 X lO6!!.

D-WASTES15,000 DRUMS

PLASTIC a METAL

D- W A S T E S5,000 DRUMS

2,500,000 Ib.PLASTIC DRUMS

25001b./hr.1000 hrs.

Z^XIO^b.

> K I L N

2275 IbYhr.1547 hrs.3.52 X lO^b.

AFT E R B U R N E R

FIGURE 4. SIMPLIFIED SCHEMATIC OF VERTAC OPERATIONS PLAN

0 0 5 5 6 2

separates the two sites. The 2,4,5-T wastes will be transported acrossthe landfill in order to avoid the use of public roads for transport.The drums of 2,4,5-T wastes will be fed directly to the rotary kiln viaa shredder and conveyance system.

Incinerator Ash: Incinerator ash will be stored in clean overpack drumsprior to disposal at a permitted hazardous waste landfill.

Liquid Wastes: Neutralized hydrochloric acid, brine will be transportedto ENSCO in El Dorado, Arkansas for final disposition.

INCINERATOR PROCESS DESCRIPTION

The mobile system is designed to incinerate both liquid and solidhazardous waste. Waste streams may include polychlorinated biphenyl( P C B ) , other chlorinated organics, RCRA class waste, sludges and soils.The system recovers the energy of the incineration exhaust via a wasteheat boiler to provide steam. A flow diagram is presented In Figure 5 .The fully Integrated system consists of six process modules on seven

trailers:

o Solids Incinerationo Liquid Incineration

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o Waste Heat Boilero Pollution Control and Prime Movero Liquid Fuel Handling and Blendingo Process Control/Chemical Laboratory

The facility layout is depicted in Figure 6 .

The solids Incineration module consists of a trailer mounted rotarykiln, solids preparation and charging equipment, a burner, an airblower, and an ash discharge system. The charging system Is comprisedof a belt conveyor and a charging hopper with integral ram feeder.During operation, contaminated solids are placed on the belt conveyorand fed into a feed hopper. An intermittently operated ram feedmechanism located in the feed chute pushes the material into the kiln.The rotary kiln is a refractory brick lined, carbon steel pipe mountedhorizontally on a trailer and is rotated by a trunnion drive mechanism.Solids residence time and kiln rotation insure complete mixing anddetoxification of the solids. Ash formed during Incineration isdischarged into the kiln end breeching where It falls into an ashdischarge chute. A water cooled screw conveyor subsequently carries theash to a storage bin where it Is sampled for potential contaminatesbefore being sent to a landfill.

The liquid incinerator/afterburner Is a large refractory brick-lined

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shell sized to provide a combustion gas residence time of 2 seconds ata temperature exceeding 2200 degrees F . The afterburner is mounted on acustom trailer with supporting mounts that allow for thermal expansion.Additional hazardous liquids may be destroyed In a primary burner thatcompletes the Incinerator/afterburner assembly. The liquids are burnedin a high temperature environment. The combustion gases approach theadiabatic flame temperature of the fuel. This burner has the capabilityto burn highly chlorinated material with low BTU value. The primarycombustion products mix with the kiln off gas and additional air in theafterburner. The design of the system allows a range of combinations ofkiln off gas, secondary waste, and contaminated water to be destroyed.The variations are governed by the thermal inputs imposed by thevarious potential waste streams.

A trailer mounted firetube boiler is provided to recover heat in theoff gas strear. In order to minimize HC1 corrosion, metal temperaturesare kept near 400 degrees F. The waste heat boiler provides-the steamrequired for the system prime mover. A boiler feed water treatmentpackage is Included to assure minimal boiler fouling and subsequentboiler maintenance. A deareator is provided for oxygen removal and feedwater heating. Off gases at 600 degrees F from the waste boiler aredrawn through an Inconel elbow where the hot gases are sprayed withquench recirculation water. The off gases are cooled to 185 degrees Fbefore reaching the exit of the quench elbow. A FRP sump box acts as a

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sump tank for quench reclrculation pumps and provides additionalresidence time for the gases to cool. Off gases from the sump tank arethen drawn through a countercurrent packed bed tower to remove acidgases. The packed tower Is designed to remove 99.5% of incoming acidgases thus ensuring that a concentrated acid stream is drawn out of thesystem for neutralization.

The steam from the boiler is used to drive a scrubber/ejector systemlocated on another trailer. The steam ejector scrubber acts not only asthe system prime mover, but also as a final pollution control device.The quenched particulate laden gases are drawn through the ejectornozzle- The turbulence created by the unique nozzle and mixing tubearrangement causes efficient particulate capture into the submicronrange. The water, after removal of agglomerated particulate, isrecycled to the steam ejector scrubber. The solids are collected,tested for potential contaminates and landfllled.

A chemical laboratory is provided with each system. The laboratory isprimarily used to provide chemical and heating value analysis of thewaste material to be Incinerated. Samples of the effluent waste streamsare also taken and analzyeri for contaitlnates via the laboratory's gaschromatograph and atomic absorption spectrophotometer. This verifiescomplete detoxification of the waste effluent streams prior tolandfllling or other disposal.

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A control room Is also located in the laboratory van. The Incineratorcombustion process and ancillary'processes are monitored and controlledby an integrated system of analog and digital readouts, single loopcontrollers, and a computer system. The computer system is employed ina multifunction role, providing data acquisition and display as well asoperational process control. Single loop controllers are utilized toregulate combustion air flow, fuel flow and boiler drum level. Singleparameter readouts, mounted on a graphic panel, are used to monitorprocess temperatures, waste water flow, quench water flow, and scrubberwater flow. The system has built-in signal conditioning electronicstherefore, measurement signals are directly wired to it. These signalsinclude thermocouple millivolts, pressure transmitter ml 11 lamps, andmilliamp/millivolt signals from the four combustion gas analysers.Signal scaling to engineering units is accomplished through digitalprocessing as directed by a portion of the software. Calculatedparameters such as combustion efficiency and gas flows' are alsogenerated, displayed, and logged by the computer.

STACK EMISSIONS MONITORING

The stack gas monitoring system consists of an extraction andconditioning system that feeds the conditioned stack gas to continuous

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monitors. These dedicated instruments continuously analyze theconditioned gas for carbon monoxide, carbon dioxide, oxygen, andnitrogen oxides. The coaputer system continuously monitors thesereadings. Print-out intervals are variable by the operator. If any ofthe critical parameters exceed the control limits, the computer willshut down the waste feed. Additionally, the readings from the oxygenand carbon monoxide monitors are continuously recorded by strip chartrecorder.

The stack gas sampling probe is located at a point greater than 8 stackdiameters downstream of the last bend and 2 stack diameters upstream ofthe stack exit. This stainless steel probe has a thermocouple readingthe temperature of the extracted sample. A coarse partlculate filterremoves some of the water droplets and larger particules before thesample enters the conditioning system. A calibration gas .port is at theexterior of the proble to allow injection of a certified calibrationgas into the probe to insure system integrity. A diaphragm pump withTeMon seals provides the prime mover of the gas sample to theanalyzers. This is done to keep the sample under a positive pressure sothat any leaks that may develop will not affect the readings of the

monitors.

The gas sample is pushed from the pump through an air-cooled Teflontube of about 10 feet long to allow the gas to begin cooling and

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condense the entrained moisture. The gas sample then passes through achilled condenser to remove the condenslble moisture from the gas. Thiscondenser consists of a 20 foot long stainless steel tubing with achilled water jacket. The cooling water is recirculated through achiller thermostated at 37 degrees F. The sample then passes through awater trap to remove the condensate. This trap has a float operateddrain to automatically expel the condensate under positive pressure.The condensate free gas then goes through a fine partlculate filerfollowed by a permeation type dryer.

In this dryer the gas sample flows through several selectivelypermeable membranes. A counter-current flow of dry compressed airallows water vapor to permeate the membrane, yielding a gas sample witha very low water contents. This clean dry gas sample goes to thecontrol room via Teflon tubing.

Within the control room is the instrumentation to monitor the stackgas. The Instruments are contained in an Instrumentation cabinet withthe plumbing and controls for analysis. The stack gas is manifolded toeach analyzer with an individual flow meter for each instrument. Alsoincluded are the controls for the dry air flow to the permeation dryerand the calibration gas. Each of the continuous analyzers has a 4-20nillllamp output which Is Interfaced with the micro-computer system fordata handling and storage.

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The oxygen content of the stack gas Is continuously monitored by anoxygen analyzer. This analyzer utilizes a fuel cell to measure theconcentration of oxygen. This cell Is specific to oxygen, has anabsolute zero. and produces a linear output from zero through 100percent oxygen. The oxygen cell is a sealed electrochemlcal transducerwith no electolyte to change or electrodes to clean. When the cellreaches the end of its useful life, it is replaced with a fresh cell.The analyzer has a choice of three ranges aballable; 0-5 X , 0-25t, and0-lOOti oxygen. This Instrument has a sensitivity of 0.5^ of full scaleand accuracy is +/-2X of full scale. The monitor has a 4-20 nllliampoutput which is relayed through a shielded pair wire to the computerfor data handling and storage.

The carbon dioxide content of the stack gas is continuously monitoredby a carbon dioxide analyzer. This analyzer is a dual-beam,nondispersive infared gas analyzer designed for the measurement ofcarbon dioxide. The system compares the infrared transmittance of twoidentical optical paths, one through the sample gas and the otherthrough the reference path. The difference in optical- transmittancebetween these paths then is a measure of the optical absorption.Circuitry processes the non-linear output signal and linearizes it toprovide a linear output signal. This Instrument has two rangesavailable; 0-5 and 0-50t carbon dioxide. The monitor has a 4-20•llllamp output which is relayed through a shielded pair wire to thecomputer for data handling and storage. The sensitivity of thisinstrument Is 0.5X of full scale and accuracy is +/-!» of full scale.

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The carbon monoxide content of the stack gas is continuously monitoredby a carbon monoxide analyzer. This analyzer operates on thenondisperslve Infrared absorption principle. Twin beans of Infraredradiation are projected through parallel cells; one beam traverses thesample cell, the other bean the comparison cell. Carbon monoxideabsorbs (and reduces) the radiation reaching the detector via thesample beam. The detector converts this into an electrical signalproportional to the concentration of the carbon monoxide. Thisinstrument has a linear 4-20 milliamp output over the range 0-500 ppmof carbon monoxide. The output is relayed through a shielded pair wireto the computer for data handling and storage. The sensitivity of thisInstrument is 1% of full scale and accuracy is ^ / - W , of full scale.

The nitrogen oxides content of the stack gas is continuously monitoredby a chemiluminescent NO/NOx analyzer. The chemiluminescent reaction ofNO and 03 provides the basis for this analysis. Light emission resultswhen electronclally excited N02 molecules revert to their ground state.To measure No concentration, the gas sample to be analyzed is blendedwith ozone in a reaction chamber. The resulting cherailuminescence ismonitored through an optical filter by a high-sensitivityphotomultlplier positioned at one end of the chamber. Thefllter/photomultiplier responds to light In a narrow-wavelength bandunique to the reaction. The output from the photomultipller Is linearly

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proportional to the NO concentration. To measure NOx concentrations,the sample gas flow is diverted through a N02 - to - NO converter. Thechemlluminescent response in the reaction chamber to the convertereffluent is linearly proportional to the NOx concentration entering theconverter. This Instrument has eight ranges available from 0 - 2.5 upto 0 - 10,000 ppm NO/NOx. The 4-20 Bllllamp output is linear throughall ranges and is relayed through a shielded pair wire to the computerfor data handling and storage. The sensitivity of this instrument is0.5% of full scale and accuracy is +/-1X of full scale.

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APPENDIX AHEALTH AND SAFETY PLAN

( B Y REFERENCE)

APPENDIX BSPILL PREVENTION CONTROLAND COUNTERMEASURES PLAN

( B Y R E F E R E N C E )

8-1 -

APPENDIX CMMP-2000 OPERATIONS MANUAL

( B Y REFERENCE)

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