SQUIBB MANUFACTURING INCORPORATED
RCRA Incinerator Permit Application Update
EPA prepared this update as part of its commitment to facilitate public participation in the decision-making process for the Squibb Manufacturing incinerator permit application. The purpose of this update to keep the public informed of the current status and important issues related to the application.
Status of Trial Burn
Squibb submitted a permit application for operating three hazardous waste incinerators, namely Caloric 1, Caloric 2 and the Trane in September 1994. To qualify for an operating permit, Squibb must demonstrate that its incinerators meet current EPA incinerator performance standards.
EPA requires facilities to conduct a trial burn for this demonstration. The trial burn tests and incinerators ability to meet all applicable performance standards set by EPA regulations. During the trial burn, the performance of the incinerator is tested at high and low temperature conditions. Three "runs" are conducted for each temperature condition. All runs must meet performance standards for the test to be successful.
In December 1997, Squibb conducted trial burns for all three incinerators. The Trane incinerator, which is operating under an EPA permit, passed the trial burn for the waste that it currently burns. The results for the two Caloric incinerators were not completely successful. The Caloric incinerators passed at high temperature conditions. However at low temperature conditions performance standards were not met. As a result of this, EPA required the trial burn be repeated. The entire trial burn was again performed in August 1998. As with the initial trial burn, EPA personnel monitored the process on site. EPA received the results of that trial burn in December 1998 and is currently reviewing those results.
Status of Risk Assesment
In addition to meeting performance standards, EPA requires that emissions be protective of human health and the environment. The evaluation of health risk posed by the emissions is called a "Risk Assessment". The Risk Assessment process provides EPA with the information necessary to determine whether or not the treated gases released to the air by the operation of an incinerator could pose an unacceptable risk.
Squibb submitted a Risk Assessment, based on projected emission values. This assessment was reviewed by both EPAs in-house expert and contractor. EPA tentatively determined that the methodology and assumptions are appropriate and reasonable. A copy of the Risk Assessment is available in the public repository at Humacao Public Library. However, the Agency will not approve the Risk Assessment until Squibb revises it using actual trial burn data (following EPAs approval of the trial burn results). In addition, the final approval of the risk assessment will be contingent upon public notice and comment regarding the draft permit.
For those who are interested in knowing more detail about the decision-making process for Squibb permit application, please check out the Information Repository specifically created for this purpose at the Humacao Public Library in Humacao. The Repository contains all information related to Squibb incinerator permitting process including the full-version of Squibb incinerator permit application, the trial burn plans, and Risk Assessment. To make it easier for the interested public to understand the very complex RCRA permit application, a simplified version of the incinerator application in both English and Spanish is also available at the Repository.