Oklahoma department of environmental quality

SECTION III. PROCESS DESCRIPTION

The technical name for the deactivation furnace (DF) is “Ammunition Peculiar Equipment” (APE 1236) which performs the following functions:

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  Safely “demilitarize” munitions by burning so that valuable metals can be recovered
  
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  Reduce the workload at the Open Burn /Open Detonation (OB/OD) ground
  
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  Limit explosive noise and air emissions associated with explosives burning and explosives detonations.
  

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  Rotary kiln
  
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  Cyclone scrubber
  
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  Afterburner
  
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  Ceramic baghouse
  
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  Draft fan
  
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  Exhaust stack
  

The APE 1236M2 deactivation furnace was designed by the U.S. Army to destroy obsolete or unserviceable ammunition. The unit is capable of processing ammunition ranging from small arms through 20-mm rounds. Ammunition larger than 20-mm must be sectioned or disassembled prior to feeding to the unit. MCAAP deactivation facility includes a Munitions Cryofracture Demilitarization Facility (MCDF) that disassembles the larger munitions prior to feeding them to the furnace. The cryofracture process freezes, fractures, punches, and exposes the energetic material prior to delivering it to the incineration system.

Nominal Stack Parameters: Height 53 feet Diameter 20 inches

Temperature 600 ^oF Gas velocity 62 ft/sec Flow rate 225,000 dscf/hr
Compliance Demonstration

As previously stated, operations and emissions from the DF are primarily governed by the Hazardous Waste Combustor NESHAP (HWC). In accordance with 40 CFR § 63.1207(b)(1), the United States Army (U.S. Army) conducted an initial Comprehensive Performance Test (CPT) to demonstrate compliance with the emission standards and establish limits for the operating parameters provided by 40 CFR § 63.1209. The CPT was conducted in November 2004. Three test series were performed to demonstrate compliance with all of the applicable HWC NESHAP emission standards at the extreme range of normal conditions, which is consistent with the requirements of 40 CFR § 63.1207(g). The results of the CPT are presented below. The facility demonstrated compliance with all of the applicable HWC NESHAP emission standards during the CPT.

In accordance with 40 CFR § 63.1209, the U.S. Army has established the following operating parameter limits (OPLs) to demonstrate continuous compliance with the emission standards of the HWC NESHAP. All required continuous monitoring systems (CMS), including required continuous emission monitoring systems (CEMS), are installed, calibrated, and operated continuously.

In accordance with 40 CFR § 63.1206(c)(3), the incinerator is operated with a functioning system that immediately and automatically cuts off the hazardous waste feed when OPLs or emission standards are exceeded. An immediate and automatic cutoff is also triggered when the span value of any process monitor is exceeded. Any malfunctions of the CMS or the automatic waste feed cutoff system will also initiate an immediate and automatic cutoff of hazardous waste feed.

40 CFR § 63.1209(p) requires that facilities initiate procedures for controlling combustion system leaks and minimizing fugitive emissions. Combustion system leaks are controlled by maintaining negative pressure in the combustion chamber and enclosing the chamber in a metal shroud to contain any fugitive emissions that may occur. Fugitive emissions captured in the metal shroud are then routed back into the furnace.

40 CFR § 63.1206(b)(11) requires that the hazardous waste residence time be calculated and documented in the facility operating record. HWC NESHAP defines hazardous waste residence time as “the time elapsed from cutoff of the flow of hazardous waste into the combustor (including, for example, the time required for liquids to flow from the cutoff valve into the combustor) until solid, liquid, and gaseous materials from the hazardous waste, excluding residues that may adhere to combustion chamber surfaces, exit the combustion chamber.” (40 CFR § 63.1201) The hazardous waste residence time must be calculated, and the calculation must be included in the CPT Plan and the operating log.

In accordance with 40 CFR § 63.8(d)(2), the U.S. Army has prepared a CMS Performance Evaluation (PE) Plan to implement the CMS quality control program and specify how the source will maintain calibration of the CMS and minimize malfunctions. The CEMS Quality Assurance/Quality Control (QA/QC) Program required by the Appendix to 40 CFR Part 63 Subpart EEE is included in the CMS PE Plan.

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  Ensure that, at all times, the incinerator, including the air pollution control equipment, is maintained in a manner consistent with safety and good air pollution control practices for minimizing emissions to the levels required by the standards;
  
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  Ensure that the U.S. Army is prepared to correct malfunctions as soon as practicable after their occurrence in order to minimize excess emissions of HAPs; and
  
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  Reduce the reporting burden associated with periods of startup, shutdown, and malfunction (by minimizing number of occurrences of excess emissions of HAPs), including corrective action taken to restore malfunctioning process and air pollution control equipment to its normal or usual manner of operation.
  

In accordance with 40 CFR § 63.1206(c)(7), the U.S. Army has prepared and at all times operates according to an Operation and Maintenance (O&M) Plan. The plan includes detailed procedures for operation, maintenance, and corrective measures for all components of the combustor, including associated air pollution control equipment, that could affect emissions of regulated HAPs.

In accordance with 40 CFR § 63.1209(c)(2), the U.S. Army has developed and implemented a Feedstream Analysis Plan (FAP). The FAP is used to determine the maximum allowable feed rate for each specific munition item to ensure compliance with the OPLs. The FAP relies on information from the Munitions Item Disposition Action System (MIDAS) that is a database containing the chemical constituent information for all ammunition, components and parts. Information in the database is based on military specifications and specific production records.

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  PEP content
  
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  Potential PM generation
  
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  Total chlorine content
  
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  Cadmium and lead content (SVM limit)
  
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  Arsneic, beryllium, and chromium contents (LVM limit)
  

In accordance with 40 CFR § 63.1206(c)(6), the U.S. Army has developed and implemented an Operator Training and Certification (OTC) Program. The OTC Program is designed to provide training to all personnel whose activities may reasonably be expected to directly affect the emission of HAPs from the incinerator. Control room operators are trained and certified in accordance with the requirements of 40 CFR § 63.1206(c)(6)(iii). One certified control room operator is on duty at the site at all times while the incinerator is in operation.

COMBUSTION EQUIPMENT

1. 
   *Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generations or for peaking power service not exceeding 500 hours per year.
   

2. 
   Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTUH heat input (commercial natural gas).
   

3. 
   Emissions from stationary internal combustion engines rated less than 50 hp output.
   

4. 
   Emissions from gas turbines with less than 215 kilowatt rating of electric output.
   

5. 
   *Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period
   

6. 
   *Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic liquids with a true vapor pressure less than or equal to 1.0 psia at maximum storage temperature.
   

7. 
   *Bulk gasoline or other fuel distribution with a daily average throughput less than 2,175 gallons per day, including dispensing, averaged over a 30-day period
   

8. 
   Gasoline and aircraft fuel handling facilities, equipment, and storage tanks except those subject to New Source Performance Standards and standards in 252:100-37-15, 252:100-39-30, 252:100-39-41, and 252:100-39-48
   

9. 
   *Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature
   

10. 
    Additions or upgrades of instrumentation or control systems that result in emissions increases less than the pollutant quantities specified in 252:100-8-3(e)(1). This activity may be conducted in the future.
    

11. 
    Alkaline/phosphate washers and associated burners
    

12. 
    Cold degreasing operations utilizing solvents that are denser than air.
    

13. 
    *Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per year of electrodes.
    

14. 
    Wood chipping operations not associated with the primary process operation.
    

15. 
    *Torch cutting and welding of under 200,000 tons of steel fabricated per year.
    

16. 
    Site restoration and/or bioremediation activities of <5 years expected duration. None listed but may be conducted in the future.
    

17. 
    Hydrocarbon-contaminated soil aeration pads utilized for soils excavated at the facility only.
    

18. 
    Emissions from the operation of groundwater remediation wells including but not limited to emissions from venting, pumping, and collecting activities subject to de minimis limits for air toxics (252:100-41-43) and HAPs (§112(b) of CAAA90). No groundwater remediation wells are operated on-site.
    

19. 
    *Non-commercial water washing operations and drum crushing operations (less than 2,250 barrels/year) of empty barrels less than or equal to 55 gallons with less than three percent by volume of residual material.
    

20. 
    Hazardous waste and hazardous materials drum staging areas.
    

21. 
    Sanitary sewage collection and treatment facilities other than incinerators and Publicly Owned Treatment Works (POTW). Stacks or vents for sanitary sewer plumbing traps are also included (i.e., lift station).
    

22. 
    Emissions from landfills and land farms unless otherwise regulated by an applicable state or federal regulation.