4.4.1.6 Implementability -- Alternative 1 Implementation considerations for HTTD systems include technical feasibility, administrative feasibility, and availability of services and materials. Additional information is also needed to implement HTTD systems. These considerations are discussed below. Technical Feasibility The technical feasibility of implementing the HTTD technology depends on (1) operating experience and technical difficulties, and (2) system reliability. These considerations are discussed below. Operating Experience and Technical Difficulties HTTD systems have been widely used during the past 5 years to remediate hazardous waste sites containing organic contaminants. Therefore, a significant amount of knowledge concerning the operation of the systems has been gained. The systems are highly automated and automatically shut down when lower or higher than desired temperatures occur and when positive pressure occurs in the processor. Because of this automation, most HTTD systems are technically easy to control. However, heterogenous wastes containing various amounts of hydrocarbons, moisture, or material types may increase the difficulty of maintaining steady temperatures and pressures in the processor; therefore, contaminated materials should be blended or mixed with treated inert material for better control of the system. System Reliability During POP testing at the Waukegan Harbor Superfund site, the ATP system had problems meeting the site-specific requirement for the PCB DRE of 99.9999 percent and total dioxin and furan emissions requirement of 30 ng/dscm at 7 percent oxygen. Process modifications implemented in March 1992 resulted in improvements in ATP stack emissions. The process modifications included the following: The carbon bed depth in the stack was increased to 24 inches. The scrubber was taken out of service and converted to an adsorption unit by addition of two new carbon beds to the scrubber. The retort zone residence time was increased by reducing the amount of solids recycled from the combustion zone to the retort zone through the sand seal. Activated carbon beds were installed in the preheat and retort zone noncondensable vapor return lines to the burners. The burners were operated at their maximum capacity to maintain the combustion zone temperature at the maximum operating level. Possible leaks in the GAC adsorption system were sealed. These process modifications enabled the ATP system to meet the PCB DRE and dioxin and furan emissions requirements at the Waukegan Harbor Superfund site. On-line percentage, the percentage of time that a system operates, is one measure of the reliability of a treatment system. SoilTech reports achieving an on-line system percentage of 85 percent at the Waukegan Harbor Superfund site. Administrative Feasibility The administrative feasibility of HTTD depends primarily on the ability of an HTTD system to receive all necessary federal, state, and local permits. The HTTD system would have to be tested to evaluate whether the system can meet the required performance standard for PCB removal of 2 ppm. Availability of Services and Materials HTTD services and materials are readily available. Many companies offer preconstructed HTTD equipment. Most HTTD systems can be transported on trailers and be assembled at the site. Because HTTD systems have been used at a significant number of Superfund sites, many experienced operators are also available. Operation of many HTTD systems requires maintenance supplies and services such as welding supplies and tools, PPE, and leased equipment such as front-end loaders. An adequate supply of spare parts such as pumps, flow meters, and piping should also be available from an on-site supply or from a nearby industrial supply center. For hollow-auger heating systems, additional heating fluid should be kept on site to replenish minor losses in the heating system. Additional Information Needed to Implement High Temperature Thermal Desorption Additional information, especially additional waste characterization, is needed to evaluate the technical feasibility of implementing the HTTD technology to treat wastes from the six CD sites. For wastes that contain a large concentration of organics such as the solid waste and sludge, waste characterization studies should be conducted to determine the British thermal unit (Btu) content, ash content, and moisture content. An ultimate analysis should also be conducted to determine the elemental makeup of the solid waste and sludge. These parameters are important to evaluate the heating and cooling requirements for the HTTD system. The particle size distribution of all contaminated materials should also be determined to estimate the amount of fines in the contaminated materials.