Superfund: EPA Could Further Ensure the Safe Operation of On-Site
Incinerators (Letter Report, 03/05/97, GAO/RCED-97-43).

Pursuant to a congressional request, GAO reviewed the Environmental
Protection Agency's (EPA) use of incineration at Superfund sites,
focusing on: (1) what safeguards EPA uses to promote the safe operation
of incinerators at these sites; and (2) whether EPA has fully
implemented its planned system of safeguards.

GAO noted that: (1) EPA relies upon four main methods to promote the
safe operation of incinerators used at Superfund sites; (2) these
methods are: (a) required site-specific standards for an incinerator's
emissions and performance; (b) engineering safety features built into
the incinerator's systems; (c) air monitoring to measure the
incinerator's emissions; and (d) on-site observation of the
incinerator's operations; (3) EPA sets standards after it studies each
site's characteristics; (4) each incinerator is designed with safety
features intended to stop its operation if it fails to meet the
specified operating conditions; (5) air monitors are placed in the
incinerator's stack and around the site's perimeter to measure the
incinerator's emissions; (6) at the three Superfund sites with ongoing
incineration projects at the time of GAO's review, EPA had arranged for
24-hour, on-site oversight from either the U.S. Army Corps of Engineers
or a state government to ensure that the incinerator was operating
properly; (7) in addition to the four methods discussed above, EPA
managers intended to use two other techniques, inspections and
applications of lessons learned, to encourage safe operations, but
neither was fully implemented; (8) first, EPA has not used inspectors
from its hazardous waste incinerator inspection program to evaluate the
operations of all Superfund incinerators as it required in a 1991
directive; (9) only one of the three incinerators GAO visited had
received such an inspection; (10) EPA regional staff responsible for
hazardous waste incinerator inspections were unaware that the Superfund
incinerators were supposed to be inspected, and EPA headquarters
officials were unaware that the inspections were not occurring; (11)
second, EPA managers did not follow through on their intention to
systematically apply the lessons learned from incineration at one site
to other sites; (12) they had intended to prepare documents describing
problems and solutions at each incineration project for use in designing
and operating other projects and to hold periodic conference calls with
the managers from incineration sites to discuss issues of common
interest; (13) both of these methods of transferring information were
dropped for various reasons; (14) GAO found that the lessons learned
from the problems experienced at the sites GAO visited could benefit ot*

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-97-43
     TITLE:  Superfund: EPA Could Further Ensure the Safe Operation of 
             On-Site Incinerators
      DATE:  03/05/97
   SUBJECT:  Hazardous substances
             Health hazards
             Waste management
             Waste disposal
             Safety standards
             Safety regulation
             Environmental monitoring
             Air pollution control
             Environmental policies
             Inspection
IDENTIFIER:  EPA National Priorities List
             Superfund Program
             Baird and McGuire Superfund Site (MA)
             Bayou Bonfouca/Southern Shipbuilding Superfund Site (LA)
             Times Beach Superfund Site (MO)
             EPA Hazardous Waste Incinerator Inspection Program
             
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Cover
================================================================ COVER


Report to Congressional Requesters

March 1997

SUPERFUND - EPA COULD FURTHER
ENSURE THE SAFE OPERATION OF
ON-SITE INCINERATORS

GAO/RCED-97-43

Superfund

(160357)


Abbreviations
=============================================================== ABBREV

  CERCLA - Comprehensive Environmental Response, Compensation, and
     Liability Act
  EPA - Environmental Protection Agency
  NPL - National Priorities List
  OECA - Office of Enforcement and Compliance Assurance
  RCRA - Resource Conservation and Recovery Act

Letter
=============================================================== LETTER


B-266331

March 5, 1997

The Honorable Jerry Lewis
Chairman
The Honorable Louis Stokes
Ranking Minority Member
Subcommittee on VA, HUD,
 and Independent Agencies
Committee on Appropriations
House of Representatives

The Honorable James M.  Talent
The Honorable Barney Frank
House of Representatives

The Environmental Protection Agency (EPA) has used incineration--that
is, controlled, high-temperature burning--to clean up some of the
most toxic forms of contamination at the nation's most severely
contaminated hazardous waste sites, known as Superfund sites. 
However, local community groups, concerned that incinerators could
emit hazardous substances, have often protested the choice of
incineration as a cleanup remedy.  EPA is responsible for ensuring
that incinerators used at these sites burn hazardous waste in a
manner that protects human health and the environment. 

Because of the public's concerns about the use of incineration at
Superfund sites, you asked us to examine (1) what safeguards EPA uses
to promote the safe operation of incinerators at these sites and (2)
whether EPA has fully implemented its planned system of safeguards. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

EPA relies upon four main methods to promote the safe operation of
incinerators used at Superfund sites.  These methods are (1) required
site-specific standards for an incinerator's emissions and
performance, (2) engineering safety features built into the
incinerator's systems, (3) air monitoring to measure the
incinerator's emissions, and (4) on-site observation of the
incinerator's operations.  EPA sets standards, such as minimum
contaminant destruction levels and maximum emission levels, after it
studies each site's characteristics (e.g., the type and concentration
of contamination present).  In addition, each incinerator is designed
with safety features intended to stop its operation if it fails to
meet the specified operating conditions.  Air monitors are placed in
the incinerator's stack and around the site's perimeter to measure
the incinerator's emissions.  Furthermore, at the three Superfund
sites with ongoing incineration projects at the time of our review,
EPA had arranged for 24-hour, on-site oversight from either the U.S. 
Army Corps of Engineers or a state government to ensure that the
incinerator was operating properly. 

In addition to the four methods discussed above, EPA managers
intended to use two other techniques--inspections and applications of
lessons learned--to encourage safe operations, but neither was fully
implemented.  First, EPA has not used inspectors from its hazardous
waste incinerator\1 inspection program to evaluate the operations of
all Superfund incinerators as it required in a 1991 directive.  Only
one of the three incinerators we visited had received such an
inspection.  That incinerator had received two inspections, but one
was conducted when the incinerator was shut down for maintenance. 
EPA regional staff responsible for hazardous waste incinerator
inspections were unaware that the Superfund incinerators were
supposed to be inspected; and EPA headquarters officials were unaware
that the inspections were not occurring.  Second, EPA managers did
not follow through on their intention to systematically apply the
lessons learned from incineration at one site to other sites.  They
had intended to prepare documents describing problems and solutions
at each incineration project for use in designing and operating other
projects and to hold periodic conference calls with the managers from
incineration sites to discuss issues of common interest.  Both of
these methods of transferring information were dropped for various
reasons, including the demands of higher priorities.  We found that
the lessons learned from the problems experienced at the sites we
visited, such as how to prepare for storm-related power outages,
could benefit other sites.  EPA headquarters officials told us that
they encouraged Superfund project managers to share their experiences
with incineration but had not facilitated this exchange in a
structured way. 


--------------------
\1 Hazardous waste incinerators include commercial facilities in
business to burn hazardous waste from various industrial and other
sources as well as private facilities that industries use to destroy
their own waste. 


   BACKGROUND
------------------------------------------------------------ Letter :2

With the enactment of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) in 1980, the Congress
created the Superfund program to clean up the nation's most severely
contaminated hazardous waste sites.  The Congress extended the
program in 1986 and 1990 and is now considering another
reauthorization.  Under CERCLA, EPA investigates contaminated areas
and places the most highly contaminated sites on the National
Priorities List (NPL) for study and cleanup.  As of December 1996,
there were 1,210 sites on the NPL. 

After a site is placed on the NPL, EPA extensively studies and
evaluates the site to determine the appropriate cleanup remedy for
it.  The remedy selected depends upon the site's characteristics,
such as the types and levels of contamination, the risks posed to
human health and the environment, and the applicable cleanup
standards.  The site's cleanup can be conducted by EPA or the party
responsible for the contamination, with oversight by EPA or the
state. 

Through fiscal year 1995, the latest period for which EPA has data,
EPA had selected incineration as a Superfund cleanup remedy 43 times,
or in about 6 percent of the decisions on remedies it had reached
through that date.\2 At the time of our review, three incinerators
were operating at Superfund sites--the Bayou Bonfouca site in
Louisiana, the Times Beach site in Missouri, and the Baird and
McGuire site in Massachusetts.\3 As of October 1996, EPA planned to
use incineration at four additional sites. 

Incineration is the burning of substances by a controlled flame in an
enclosed area that is referred to as a kiln.  Incineration involves
four basic steps:  (1) wastes, such as contaminated soil, are
prepared and fed into the incinerator; (2) the wastes are burned,
converting contamination into residual products in the form of ash
and gases; (3) the ash is collected, cooled, and removed from the
incinerator; and, (4) the gases are cooled, remaining contaminants
are filtered out, and the cleaned gases are released to the
atmosphere through the incinerator's stack.  (See fig.  1.)

   Figure 1:  Typical Incinerator
   Processes, Rotary Kiln

   (See figure in printed
   edition.)

Source:  EPA. 

Incinerators may be fixed facilities that accept waste from a variety
of sources, or they may be transportable or mobile systems.  Fixed
facility hazardous waste incinerators are required by the Resource
Conservation and Recovery Act of 1976 (RCRA) to obtain an operating
permit from EPA.  RCRA regulates all facets of the generation,
transportation, treatment, storage, and disposal of hazardous wastes
in the United States.  RCRA requires that fixed facility hazardous
waste incinerators be operated according to EPA's regulations and be
inspected by EPA every 2 years. 

Incinerators used to clean Superfund sites are generally
"transportable," that is, they are transported to the site in pieces,
assembled, and removed when the cleanup is complete.  These
incinerators are constructed and operated by contractors.  CERCLA
exempts any portion of a cleanup action conducted entirely on-site,
including incineration, from the need to obtain any permit.  However,
CERCLA requires EPA to apply legally applicable or relevant and
appropriate environmental standards from other federal laws,
including RCRA, to Superfund cleanups.  Accordingly, EPA requires
incinerators at Superfund sites to meet RCRA's substantive
requirements, such as the act's standards for emissions. 


--------------------
\2 EPA derived the number of instances in which incineration was
selected as a remedy from an analysis of the remedy decision
documents for each Superfund site.  The decision documents contain
information only on the initial remedy chosen and do not reflect
later changes.  Consequently, the actual use of incineration at
Superfund sites probably falls somewhat short of the 43 instances
indicated by the documents. 

\3 During fiscal year 1995, EPA selected remedies for 110 sites. 


   EPA RELIES UPON A VARIETY OF
   METHODS TO PROMOTE THE SAFE
   OPERATION OF SUPERFUND
   INCINERATORS
------------------------------------------------------------ Letter :3

EPA relies on four principal methods to ensure the safe operation of
incinerators used to clean up Superfund sites.  These methods are (1)
setting site-specific standards for emissions and operations, (2)
incorporating safety features into an incinerator's emergency
systems, (3) monitoring emissions at the incinerator's stack and
along the site's perimeter, and (4) providing 24-hour on-site
oversight.  (See app.  I for more details on the safeguards at the
three incinerators in operation at the time of our review.)


      INCINERATOR'S OPERATING
      CONDITIONS ARE SET ON A
      SITE-SPECIFIC BASIS
---------------------------------------------------------- Letter :3.1

EPA establishes specific cleanup standards for each incinerator used
at a Superfund site.  These standards are based on studies of the
site's characteristics (e.g., the type and concentration of
contamination present) conducted during the incinerator's design and
construction.  Standards can be adopted from other environmental
programs or laws, such as RCRA or the Toxic Substances Control Act.\4
Typically, RCRA's standards for fixed facility hazardous waste
incinerators are applied.  RCRA's standards govern the extent to
which an incinerator must destroy and remove contaminants and set
limits on emissions from the incinerator. 

EPA establishes the operating parameters needed for the incinerator
to achieve the emissions standards and tests the parameters through a
"trial burn" required under RCRA.  The operating parameters can
include the temperature of the kiln, the minimum oxygen levels needed
to break down contaminants in the kiln, and the maximum carbon
monoxide levels that may be produced.  Although not required by EPA's
regulations, a trial burn plan was reviewed by a RCRA expert at all
the sites we visited to determine whether the proper operating
conditions were being tested.  According to EPA officials, if the
incinerator operates within the parameters established at the trial
burn, the incinerator will be operating safely. 


--------------------
\4 EPA has issued regulations governing the incineration of
polychlorinated biphenyls under the Toxic Substances Control Act. 


      INCINERATORS INCLUDE
      BUILT-IN SAFETY MEASURES
---------------------------------------------------------- Letter :3.2

Besides establishing standards for emissions and operations, EPA
requires engineering controls to prevent the standards from being
exceeded.  In addition, incinerators at the three sites we visited
had built-in safety features unique to each model to prevent
excessive emissions of contaminants in the event of an emergency
shutdown. 

RCRA's regulations, which EPA applies at Superfund sites, require
that incinerators have devices, called automatic waste feed cutoffs,
that will stop contaminated waste from being fed into an incinerator
when the operating conditions deviate from the required operating
parameters.  The waste feed would be cut off, for example, when a
change in pressure or a drop in temperature occurred that could
compromise the kiln's effective incineration of the contaminants. 
These cutoffs are set with a "cushion" so that the waste feed shuts
down before the incinerator operates outside the established
parameters.  The number and type of waste feed cutoffs will depend on
the requirements for each site.  According to EPA officials, some
cutoffs are routine, to be expected during the normal course of an
incinerator's operations, and a sign that the safety mechanisms are
working properly.  For example, cutoffs can be triggered by expected
changes in pressure within the kiln brought on by variations in the
waste input stream.  However, other cutoffs, especially repeated
cutoffs, can be signs of problems. 

At the three sites we visited, all of the incinerators had some
additional safety measures, not required by regulation, in the event
that a critical part of the incinerator failed.  At the Times Beach
and the Bayou Bonfouca sites, the incinerators have emergency systems
that fully shut down the incinerator and decontaminate the gases
remaining in the system at the time of the shutdown.  These systems
seal off the gases and expose them to a high-temperature flame to
destroy any residual contamination.  At the Baird and McGuire site,
the emergency system ensures that metals and particulates are removed
before gases are emitted from the kiln.  The most common reason for
activating the emergency systems at the three sites was a shutdown
caused by a power outage. 


   EPA MONITORS AIR TO DETECT ANY
   RELEASE OF CONTAMINANTS
------------------------------------------------------------ Letter :4

EPA continuously monitors the air in the vicinity of an incinerator
to ensure that emissions from the stack and from areas where soil is
being excavated before being put into the incinerator do not exceed
the maximum permitted levels.  Air monitoring at the sites involves
measuring conditions in real time and performing detailed laboratory
analyses of samples that are collected over a longer period of time. 
For example, at the Baird and McGuire site, stack emissions are
monitored continuously to measure key indicators of combustion, such
as the oxygen levels in exhaust gases, to ensure that the incinerator
is operating properly.  For organic contamination,\5 a more detailed
laboratory analysis is carried out during the trial burn to provide
additional assurance that dioxin, a cancer-causing substance produced
by the burning of organic substances, is not excessively emitted. 
The Baird and McGuire site also has nine air monitors at its
perimeter, each of which is hooked up to alarms that sound if
emission levels approach the established parameters.  These monitors,
which are intended primarily to detect possible emissions from the
on-site excavation of contaminated soil, monitor and record data
every minute.  According to the incineration contractor's project
manager at the Baird and McGuire site, the air monitors picked up
elevated levels only once during an excavation, when a drum of
chemicals was removed.  In a situation such as this, the excavation
is slowed to bring emissions down to required levels.  According to
EPA's reports for the three sites we visited, emissions from the
incinerators' stacks never exceeded the permitted levels. 


--------------------
\5 Organic compounds are composed of carbon, hydrogen, and sometimes
other elements. 


      ON-SITE OBSERVATION OF
      INCINERATORS' OPERATIONS
      OCCURRED
---------------------------------------------------------- Letter :4.1

Although 24-hour oversight is not required by regulations or formal
EPA policy, Corps of Engineers or state officials continuously
observed the operations of the incinerator at each of the sites we
visited.  For the two cleanups that EPA managed (at the Baird and
McGuire and Bayou Bonfouca sites), EPA had contracted with the U.S. 
Army Corps of Engineers for on-site oversight, while at Times Beach,
where a responsible party was conducting the cleanup, a Missouri
state agency provided oversight.  At the time of our visit, these
sites had staff to cover operations 24 hours a day.\6 For example, at
Baird and McGuire, 12 Corps of Engineers staff were assigned to
monitor the incinerator's operations. 

On-site observation involves visual inspections and record reviews to
ensure that the incineration companies are meeting the operating
conditions specified by EPA.  At the sites we visited, Corps of
Engineers or state officials were responsible for checking the
operating parameters displayed on computer screens in the
incineration control rooms and inspecting measurement devices on
incineration equipment to verify that they were working properly. 
For example, at Times Beach, a state official monitored operations
from an on-site computer screen, while a state RCRA employee obtained
the computerized information from his office in the state capitol to
ensure that the conditions of the state's RCRA permit were being
met.\7 At Bayou Bonfouca, Corps officials examined operation log
books and talked to incinerator operators to look for any problems
and oversaw the procedures for testing and sampling emissions from
the incinerator.  The officials were also responsible for reviewing
the air-monitoring reports and operation summary reports required of
the incineration company and reporting their findings to EPA. 


--------------------
\6 In July 1996, the state agency cut back on-site oversight to about
12 hours per day at Times Beach. 

\7 This is the only Superfund site that has a RCRA permit, which
specifies specific operating conditions.  (See app.  I for further
information.)


   EPA HAS NOT IMPLEMENTED TWO
   PLANNED METHODS FOR PROMOTING
   THE SAFE OPERATION OF
   INCINERATORS
------------------------------------------------------------ Letter :5

In addition to the safeguards discussed above, EPA planned two
additional methods to promote the safe operation of Superfund
incinerators but never fully implemented them.  First, EPA issued a
directive requiring inspectors from its hazardous waste incinerator
inspection program to periodically evaluate Superfund incinerators. 
This requirement had not been followed at two of the three
incinerators operating at the time of our review.  Second, EPA has
not carried out its intention to systematically ensure that the
lessons learned about an incinerator's operations in one incineration
project are applied to subsequent projects.  EPA is relying upon
informal communication to transfer "best practices" from one
incineration project to the next. 


      EPA HAS NOT IMPLEMENTED ITS
      POLICIES FOR INSPECTING
      INCINERATORS
---------------------------------------------------------- Letter :5.1

In 1991, EPA issued a directive requiring that the same type of
inspections that are conducted at RCRA-permitted hazardous waste
incinerators be conducted at Superfund incinerators.  In 1993, EPA
issued interim guidance on how to perform these inspections at
Superfund incinerators.  This guidance required that inspectors in
EPA's regional offices review the operating records for Superfund
incinerators and examine the units to ensure that they were operating
within their established parameters.  Only one of the three
incinerators we visited had received such an inspection.  That
incinerator received two inspections, one of which was conducted
while the incinerator was shut down for maintenance.  EPA regional
staff we talked to were unaware of the directive and guidance on
these inspections.  EPA headquarters personnel told us that they were
unaware that the inspections were not taking place but confirmed with
the regions that only one region was inspecting Superfund
incinerators.  EPA officials attributed the lack of inspections to
the higher priority given to other enforcement demands and a
reorganization of enforcement functions, which muddied the
responsibility for inspecting the incinerators.  Headquarters
officials said they would encourage the regions to do the inspections
in the future. 

According to officials from EPA's Office of Enforcement and
Compliance Assurance (OECA), who are responsible for implementing the
inspection program, RCRA incinerator inspectors had visited Superfund
incinerators when the guidance was first issued in 1993.  However,
these inspectors said their inspections were hampered because they
did not have a site-specific document containing the requirements for
each incinerator's operations that they could use to evaluate these
operations.  At Superfund sites where transportable incinerators are
used, EPA may specify standards, operating parameters, emergency
controls, and requirements for air monitoring and on-site oversight
in various documents, such as a contract with the operator of the
incinerator, a court-approved consent decree with the responsible
party, or a work plan for the site.  In contrast, fixed facility
hazardous waste incinerators require a RCRA permit, which documents
the conditions under which an incinerator must operate.  Inspectors
use the conditions specified in the permit as criteria for evaluating
the incinerator's operations.  For Superfund incinerators, however,
an operating permit is not required.  The 1993 interim guidance for
inspecting Superfund incinerators recognized the need for a single
document specifying site-specific operating requirements and
procedures and stated that such a document would be developed. 
However, no such document was developed because, according to EPA
officials, other priorities intervened.  EPA officials attributed the
lack of recent Superfund incinerator inspections, in part, to the
lack of a consolidated list of requirements. 

The Superfund, RCRA, and OECA officials we interviewed on this
question agreed that Superfund incinerators should be inspected. 
They stated that experienced RCRA hazardous waste incinerator
inspectors in EPA's regional offices have knowledge and experience
that makes them well qualified to evaluate the operations of
Superfund incinerators.  These officials believed that an inspection
by an outside, independent inspector was important even if an
incinerator had on-site oversight.  RCRA officials told us that at
the few RCRA-permitted hazardous waste incinerators with on-site
inspectors, the inspectors are rotated every 6 months in order to
maintain their independence and objectivity.  In addition, they said
that experienced incinerator inspectors would have more expertise
than the Corps of Engineers or state staff assigned to oversee the
incinerators' operations.  Although these staff do receive training,
they are generally not experts on incineration. 


      EPA DOES NOT HAVE A FORMAL
      MECHANISM FOR SHARING BEST
      PRACTICES
---------------------------------------------------------- Letter :5.2

Because EPA site managers may work on as few as one or two projects
at a time and because incineration is not a common remedy at
Superfund sites, managers may have limited experience with
incineration.  However, EPA does not have any formal mechanism to
share the lessons learned about an incinerator's operations.  The
need for information-sharing is illustrated by experiences at two
sites we visited.  The Bayou Bonfouca site had a policy to stop
feeding waste to the incinerator during severe storms.  This policy
was adopted to reassure the public that the incinerator would not
suffer an emergency shutdown during a storm-related power outage. 
The Times Beach site, which was using the same incinerator model, did
not formally adopt this policy until after a severe storm had knocked
out the power at that incinerator, causing an emergency shutdown. 
The storm and power outage caused the emergency emissions system and
the perimeter air monitors to fail.  (See app.  I for details.) The
lessons learned from these problems could be applied to future
incineration projects to prevent similar problems from arising. 
However, EPA has no formal mechanism to ensure that other
incineration projects can benefit from the Times Beach experience. 

EPA officials agreed that they should be sharing the lessons learned
from each site.  According to officials, they had intended to do so
by issuing fact sheets, but the effort was dropped before any fact
sheets were issued.  The officials stated that the fact sheets were
not issued because of a fear that information on problems with
incinerators' operations could be used against them in litigation. 
In addition, they attempted to have monthly conference calls with all
of the managers of incineration sites, but the effort soon faded
away.  However, EPA officials told us that they do informally share
lessons learned through discussions with regional staff responsible
for incineration sites.  Also, they encourage site managers to visit
other incineration sites to learn from the experiences there;
however, they do not currently intend to revive their plans for
preparing fact sheets. 


   CONCLUSIONS
------------------------------------------------------------ Letter :6

EPA employs a number of techniques to encourage the safe operation of
Superfund incinerators.  These techniques include mechanical
features, such as air monitors, as well as operational procedures,
such as 24-hour independent oversight.  However, residents of the
areas surrounding incinerators frequently desire an extra degree of
assurance that the incinerators are operating safely.  EPA has not
followed through on other opportunities to improve its oversight of
incinerators and thereby provide additional assurance to the public. 
First, EPA has not followed its own policy of having RCRA hazardous
waste incinerator inspectors inspect Superfund incinerators. 
Although these inspections would provide the public with independent
evaluations of the incinerators' compliance, they did not take place,
in part, because consolidated lists were not made available to
inspectors of the standards, design requirements, and operating rules
for each site where incineration is used.  Inspectors could use such
lists, just as they use the operating permits for fixed facility
hazardous waste incinerators, as an aid in evaluating compliance. 
Second, EPA's attempts to systematically share the lessons learned
from site to site were never fully implemented.  Because incinerators
are being used at relatively few Superfund sites, EPA project
managers may have little or no experience with them.  These managers
would benefit from the experiences of other managers of sites where
incinerators have been used.  At the sites we visited, operational
problems occurred that might be avoided at other incineration
projects if the knowledge gained was preserved and shared. 


   RECOMMENDATIONS TO THE
   ADMINISTRATOR, EPA
------------------------------------------------------------ Letter :7

To provide further assurance that incinerators at Superfund sites are
being operated safely, we recommend that the Administrator, EPA,

  -- implement the agency's guidance for having RCRA hazardous waste
     incinerator inspectors evaluate Superfund incinerators,
     including the development of a single document specifying
     site-specific operating requirements and procedures for these
     incinerators, and

  -- document the lessons learned about safe operation from the
     experiences of each Superfund site where incineration is used
     and institute a systematic process to share this information at
     other sites where incinerators are used. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :8

We provided copies of a draft of this report to EPA for its review
and comment.  On January 29, 1997, we met with EPA officials,
including a senior process manager from EPA's Office of Emergency and
Remedial Response and officials from EPA's Office of Enforcement and
Compliance Assurance and Solid Waste and Emergency Response, to
obtain their comments.  EPA generally agreed with the facts,
conclusions, and recommendations in the report.  However, while not
disagreeing that the lessons learned should be documented, EPA did
question the benefits of preparing voluminous site-specific studies
on lessons learned, given the decreasing use of incineration.  We
concur that the type of documentation should be concise and the
format useful.  EPA also provided technical and editorial comments,
which we incorporated in the report as appropriate. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :9

To examine EPA's oversight of incinerators at Superfund sites, we
visited the three Superfund sites with operating incinerators:  the
Baird and McGuire site in Massachusetts, the Bayou Bonfouca/Southern
Shipbuilding site in Louisiana, and the Times Beach site in Missouri. 
At these sites, we spoke with EPA, state government, U.S.  Army Corps
of Engineers, and contractor officials to determine how the
incinerators operate, what safety measures they employ to ensure safe
operation, and what oversight activities occur.  We also interviewed
EPA officials in regions I, VI, and VII and in the headquarters
offices of Solid Waste, Emergency and Remedial Response; Pollution
Prevention and Toxics; and Enforcement and Compliance Assurance.  In
addition, we obtained and analyzed documents and data from EPA and
from the relevant states, counties, and responsible parties when
necessary.  Our work was performed in accordance with generally
accepted government auditing standards from February through December
1996. 

As arranged with your offices, unless you publicly announce its
contents earlier, we will make no further distribution of this report
until 10 days after the date of this letter.  At that time, we will
send copies of the report to other appropriate congressional
committees; the Administrator, EPA; the Director, Office of
Management and Budget; and other interested parties.  We will also
make copies available to others upon request.  Should you need
further information, please call me at (202) 512-6520.  Major
contributors to this report are listed in appendix II. 

Stanley J.  Czerwinski
Associate Director, Environmental
 Protection Issues


THREE CASE STUDIES
=========================================================== Appendix I

We visited the three Superfund incinerators that were in operation at
the time of our review:  the Baird and McGuire site in Holbrook,
Massachusetts; the Bayou Bonfouca/Southern Shipbuilding site in
Slidell, Louisiana; and the Times Beach Superfund site near St. 
Louis, Missouri.  A brief description of the incineration project at
each site follows. 


   THE BAIRD AND MCGUIRE SUPERFUND
   SITE
--------------------------------------------------------- Appendix I:1

The Baird and McGuire site, approximately 14 miles south of Boston,
is a former chemical manufacturing facility that operated for 70
years until it was shut down in 1983.  This 20-acre site is
contaminated with approximately 200,000 pounds of chemicals and
metals, including creosote, herbicides and pesticides, arsenic, lead,
and dioxin.  Chemicals from the site have contaminated groundwater, a
nearby river, and a nearby lake. 

EPA chose to incinerate soil and other contaminated material on-site
because it judged that this remedy would be the most protective of
human health and because complicating factors made other remedies,
such as covering the contaminated areas with a clay cap,
inappropriate.  These factors included the location of part of the
site in a 100-year flood plain, the existence of wetlands on the
site, and the potential for the contamination to spread farther (via
groundwater) if the site was not effectively treated.  In addition,
dioxin is present at the site, leaving few off-site treatment
possibilities because regulations limit the locations at which
dioxin-contaminated material can be treated.\8

The operation of the incinerator at the Baird and McGuire site began
in June 1995 and is expected to be completed in April 1997.  The
incinerator was designed specifically to remediate the high levels of
metal contamination at the site.  (See fig.  I.1.) It is configured
to capture the metals (which cannot be destroyed by the incineration
process and may be present in the gases produced by the burn) in a
pollution control device before they are emitted into the atmosphere. 
The incinerator has 13 automatic waste feed cutoffs.  In case the
incinerator is totally shut down, a diesel backup system will keep
filtration systems running to prevent the release of hazardous
emissions.  Emissions from the site are monitored continuously from
the incinerator's stack and from nine locations along the site's
perimeter. 

   Figure I.1:  Kiln at Baird and
   McGuire

   (See figure in printed
   edition.)

Oversight is carried out by 12 staff from the U.S.  Army Corps of
Engineers, who receive technical assistance from an engineering
consulting firm.  According to a Corps engineer at the site, the
Corps staff complete inspection reports detailing on-site events 2 to
3 times per day and provide weekly summary reports for EPA's review. 


--------------------
\8 For further information see Superfund:  EPA has Identified Limited
Alternatives to Incineration for Cleaning Up PCB and Dioxin
Contamination (GAO/RCED-96-13, Dec.  29, 1995). 


   THE BAYOU BONFOUCA/SOUTHERN
   SHIPBUILDING SUPERFUND SITE
--------------------------------------------------------- Appendix I:2

The Bayou Bonfouca site includes 55 acres of sediment and surface
water that were contaminated with wood-treating chemicals from an
abandoned creosote works plant.  The main threats to human health at
this site included direct contact with contaminated groundwater, the
potential for contamination to spread to a nearby waterway during
flooding, and the potential for direct contact with concentrated
hazardous material at the unsecured site.  From February 1992 through
September 1995, EPA incinerated contaminated soil and other material. 

After incinerating the waste from the Bayou Bonfouca site, EPA began
to use the incinerator to burn similar wastes from the nearby
Southern Shipbuilding Superfund site.  (See fig.  I.2.) This site was
contaminated with 110,000 cubic yards of sludge, containing mostly
polycyclic aromatic hydrocarbons that were left from barge cleaning
and repair operations.  Polycyclic aromatic hydrocarbons are
chemicals formed during the incomplete burning of coal, oil, gas,
refuse, or other organic substances. 

   Figure I.2:  Incinerator at
   Bayou Bontouca

   (See figure in printed
   edition.)

In addition to 15 automatic waste feed cutoff parameters to prevent
the incinerator from operating outside the regulatory limits, the
incinerator has an emergency stack venting system that further treats
the gases from the kiln if the incinerator is totally shut down.  In
case of a power outage or another event that would cause the major
functions of the incinerator to fail, this emergency system draws the
kiln gases\9 into an emergency stack where a flame further destroys
contaminants.  According to an incineration contractor official at
the Bayou Bonfouca site, this emergency system prevents the release
of kiln gases that exceed emission regulations. 

Oversight at the Bayou Bonfouca site is carried out by a team of nine
Corps of Engineers inspectors.  These inspectors check the computer
screens in the incinerator's control room every 2 hours to ensure
that the incinerator is operating within the regulatory parameters
set during the trial burn.  The Corps team also inspects the
incinerator's machinery, is present for all sampling and testing done
by the incineration company, and documents all of the automatic waste
feed cutoffs.  Corps officials review monthly, quarterly, and yearly
reports from the incineration contractor.  Air monitoring at the site
includes continuous monitoring from the stack, the excavation site,
and other areas of the site, and samples are taken daily for more
complete chemical analysis.  According to Corps officials, emissions
have never exceeded regulatory levels.  In addition, EPA Region VI
had two RCRA inspections completed at the Bayou Bonfouca site. 
However, the incinerator was shut down for maintenance at the time of
one of the inspections.  This Bayou Bonfouca/Southern Shipbuilding
project was completed in November 1996. 


--------------------
\9 The gases from the kiln are one of two residual products (ash is
the other) resulting from the incineration process.  Although most of
the contamination is destroyed in the kiln under normal operating
conditions, the kiln gases would go through a secondary combustion
chamber for further treatment.  This emergency system provides
additional treatment when the incinerator shuts down and the
secondary combustion chamber is not operating. 


   THE TIMES BEACH SUPERFUND SITE
--------------------------------------------------------- Appendix I:3

The Times Beach Superfund site is a 0.8-square-mile area, 20 miles
southwest of St.  Louis, that was contaminated with dioxin.  The
contamination resulted from spraying unpaved roads with
dioxin-tainted waste oil to control dust.  EPA decided to incinerate
soil from Times Beach and 26 other nearby sites that were
contaminated in the same way.  (See fig.  I.3.) EPA believed that
incineration was the best remedy for the large volumes of
dioxin-contaminated soil and the large pieces of contaminated debris
to be treated.  The incineration project at Times Beach began in
March 1996 and is expected to be completed in March 1997. 

   Figure I.3:  Dioxin
   Contaminated Soil From Times
   Beach

   (See figure in printed
   edition.)

The Times Beach site is unusual because EPA obtained a RCRA permit to
operate the incinerator.  A permit is generally not required at
Superfund sites, and the process of obtaining it resulted in some
delays in beginning operations.  However, EPA regional officials
obtained the permit to provide nearby residents with additional
assurance that the incinerator would operate safely and would be
removed after the project was completed, rather than being kept in
place to burn contaminated material from other sites.  As required by
the permit, the Times Beach incinerator has 17 automatic waste feed
cutoffs.  In addition, the incinerator includes the same emergency
system that is used at Bayou Bonfouca. 

Oversight at Times Beach is handled primarily by the Missouri
Department of Natural Resources.  State officials monitor operations
on-site and via computer in the state capitol.  Three on-site state
employees originally provided oversight 24 hours a day.  Currently,
the state has oversight officials at the site 11-1/2 hours each
weekday and 9 hours a day on the weekend.  In addition, they conduct
unannounced random visits to the site during off hours. 

To supplement the state's oversight, St.  Louis County inspects
operations and tracks the results of air-monitoring testing to ensure
that the incinerator's emissions are in compliance with the limits
set in the county's air pollution permit.\10 According to a county
official, although formal inspections are required about once every 2
years, the county informally monitors the site more frequently.  As
with the other sites, Times Beach has two levels of air monitoring: 
continuous monitoring and a more detailed laboratory analysis. 
According to EPA officials, emissions from the incinerator have never
exceeded the permissible levels. 

Despite extensive monitoring at the Times Beach site, incidents have
occurred.  Once, when an unexpected storm interrupted electrical
power and caused a shutdown, the emergency system failed to fire. 
High winds had blown out the pilot lights on this treatment system,
which should have fired after the power to the incinerator had been
lost.  Without the firing, the emergency system did not further treat
the kiln gases as it was designed to do.  Although EPA concluded that
the event caused no significant health effects, the agency could only
estimate emission levels during the shutdown because the
air-monitoring equipment that would have recorded the actual emission
levels was on the same circuit as the incinerator and, therefore, was
not operating during the event.  To prevent future emergency
shutdowns from storm-related power losses, the incineration
contractor hired local weather forecasting services to improve storm
warnings and formally adopted a standard operating procedure to stop
the waste feeds during severe weather.  (This standard operating
procedure had already been in force at the Bayou Bonfouca/Southern
Shipbuilding Superfund site when the event occurred.) In addition,
other measures were taken to prevent the emergency system's pilot
lights from being blown out and to decrease the number of power
outages. 

Improper handling of the emission samples taken during a dioxin stack
test was alleged following the discovery that the test samples were
taken by a company that is a subsidiary of the incineration
contractor.  EPA maintains that the incinerator operator followed all
required procedures for testing the samples.  EPA has no regulation
that prohibits the incineration contractor or one of its subsidiaries
from taking, transporting, or analyzing the test samples.  In
addition, the time taken to deliver the samples to the laboratory was
questioned--8 days from the time the samples left the site until they
arrived at the laboratory.  According to EPA officials, the samples
are stable, making the time taken to get them to the laboratory
unimportant.  State officials reviewed the testing and determined
that the results were valid.  However, in December 1996, the EPA
Ombudsman issued a report on the allegations and recommended that a
new stack test be conducted to ensure public confidence in the
cleanup.  EPA agreed to implement the Ombudsman's recommendation. 


--------------------
\10 EPA is also responsible for ensuring that the operating
parameters are in compliance with the emission levels specified by
the RCRA permit. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

James F.  Donaghy, Assistant Director
Jacqueline M.  Garza, Staff Evaluator
Richard P.  Johnson, Attorney Adviser
William H.  Roach, Jr., Senior Evaluator
Paul J.  Schmidt, Senior Evaluator
Magdalena A.  Slowik, Intern
Edward E.  Young, Jr., Senior Evaluator


*** End of document. ***