MEMORANDUM 

TO: Toni Jones, Charlene Spells, Ketan Patel U.S. Environmental Protection Agency 

FROM: Brian Shrager, U.S. Environmental Protection Agency, Kristen James and Jason 

Huckaby, Eastern Research Group, Inc. 

DATE: April 14, 2010 

SUBJECT: Burn Off Oven Clarification Request Summary

 

1.0 Introduction

This memorandum summarizes the information collected in a follow up survey of 

Commercial and Industrial Solid Waste Incineration (CISWI) units classified as burn off 

ovens in the database. The purpose of this follow up survey was to obtain additional 

information in order to address concerns with testing these units. Attachment A provides 

a summary table of the facilities and their survey response. Attachment B includes the 

original response from each facility. 

2.0 Information Collection

CISWI facilities that identified themselves as the owner or operator of a burn off oven 

and received the EPA section 114 ICR letter requiring emissions testing by October 15, 

2009 were asked to respond to questions in a follow up email. An email from Brian 

Shrager with the Environmental Protection Agency (EPA) was sent to facilities on June 

25, 2009. Mr. Shrager requested that facilities answer the following questions for each 

oven for which the facility received a test request: 

1) What is the cycle time of the unit for which testing has been requested? 

2) Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum 

heat time, cool-down time). 

3) What size is the stack? 

4) What types of stack/platform modifications (just those that you know about now) 

would be required to complete the testing? 

5) Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is 

it a natural draft? 

6) Which test methods, if any, have emission test contractors expressed concerns about 

(regarding feasibility of testing, ability to sample isokinetically, other)? 

7) What are the estimated testing costs for your unit? 

8) In the Webinar, EPA indicated that for batch processes with short cycle times, the 

individual test runs do not need to span more than one batch cycle. How would that 

change the estimated testing costs? 
9) Do you know the composition of the materials that are "burned off" in the oven? If 

yes, do the materials contain metals or chlorine? 

10) What is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber? 

11) Are the materials that are removed from the parts/hooks/racks in the oven 

combusted? If not, is heat used to melt or break material bonds so that the materials fall 

off of the parts/hooks/racks and are collected and disposed of through another means? 

12) Please feel free to provide any other information that you believe may be pertinent to 

the feasibility of emission testing. 

EPA received a follow up response from 11 facilities contacted for this survey. 
FacilityID UnitID Contact What is the cycle time of the unit for which testing 

has been requested?

Please provide a breakdown of the 

cycle time (e.g., start-up time (hours), 

maximum heat time, cool-down time).

What size is the stack?

CNH -

 Burlington

IACNHAmerica

INC-1 Audrey Van 

Dyke

7 hrs (+ ramp time @ max ramp) Max ramp to 450oF, "soak" for one hour; 

max ramp to 550oF, "soak" for two hours; 

max ramp to 650o, "soak" for two hours; 

max ramp to 750o, "soak" for two hours.

Circular - 12 inches

CNH -

 Grand Island

NECNHAmericaGrandIsland

ID 7996 Audrey Van 

Dyke

3.25 hours Startup 0.75 hr, Bake 2 hr, Cool 0.5 hr 18 inches

CNH -

 New Holland

PACNHAmericaNewHolland

INC-1 Audrey Van 

Dyke

varies - typically 6-9 hrs. Startup 0.75 hr; bake 2-4 hr; cool down 

about 3-4 hr.

18 Inches

OHWhirlpoolClyde N001 Bob Karwowski 12 hour burn cycle typical. Only one cycle completed in a 

24 hour period. Wet paint processes can have lower 

cycle time of around 8 hours.

Start-up: 1 hour; full burn 2-4 hours; 

remainder of time polishing to complete 

pyrolysis.

Circular - 14 inches ID, 18 inches OD; 2 

inch ceramic lining

INWhirlpool Pyrolytic 

Oven #1

Bob Karwowski 5 hours typical, 6 hours max. Only one cycle is 

completed per day.

Start-up: 1 hour; full burn 1-2 hours; 

remainder of time polishing to complete 

pyrolysis.

Circular - 14 inches ID, 18 inches OD; 2 

inch ceramic lining

FLSolutia CP-L Roy Noble Varies - but typically operated overnight for about 14-16 

hours, not including cool down.

Heat up: 4 hours; max burn: 10-12 hours; 

cool down based on equipment being 

reclaimed

Two stacks approximately 25 ft above 

grade and 10-12 inch ID (16 inch OD 

with 2-3 inches of insulation)

Cooper Standard

KYCooperStandard

SN-17 Chris Massaro 8 hours Heat up: 90 minutes; 8 hours max burn; 

60 minutes cool down

10 inch ID, 14 inch OD, top of stack is 

93 inches above roof

Sealed Air Corporation

SCCryovac

FB01 Meredith 

Mangum

The fluidized bed’s (FB-01) cycle time is dependant upon 

the part being loaded and the level of 

assembly/disassembly. Traditional processing times for 

equipment loaded into FB-01 includes a two hour heating 

cycle. The temperature of the bed drops between 25 and 

50 degrees Celsius immediately after the cage of parts is 

loaded into the unit. During the first 20 minutes after 

loading the parts cage, a natural gas burner is fired to 

raise the bed to optimum temperature (approximately 

450oC) and stabilize bed conditions (air flow, 

temperature,). During the handling and cleaning of the 

metal parts, the sand bed is maintained at an 

elevated temperature for approximately 1 hour and 40 

minutes. The fluidized bed enclosure is then opened 

and the parts removed. The fluidized bed is maintained 

at temperature awaiting the loading of the next set of 

parts. Some larger extruder dies may require up to 4 

hours of immersion in the sand bed

Once heated, the parts/cage is placed in a separate 

water quench bath for approximately 15 minutes to 

drop the temperature of the equipment and remove any

 residual sand. The cooled parts are then dipped in an 

oil quench tank to coat the parts with a light oil to 

protect the equipment and 

assist in the re-assembly process. 

 A total of Four dies or batches may be processed 

each day (24 hour period).

Once the fluidized bed has reached to 

operating temperature, the cycling time 

is dependant upon the level of metal 

parts assembly/disassembly and the 

size of the die itself. Most die 

equipment at the Simpsonville plant 

take approximately 2 hours

To clean, while a couple of large units may 

take up to 4 hours.

In rare instances, the die is loaded into 

the fluidized bed intact (not 

disassembled). Since the sand does not 

directly contact all the parts, the die must 

remain in the heated bath for 

approximately 6 to 8 hours. This event is 

limited to the cleaning of R&D dies which 

may include confidential or patented 

applications.

From the roofline, a twenty-four (24) 

inch stack extends 28 feet above the 

die maintenance shop roofline. The air 

flow from two fans combine 

approximately 2 feet below the roofline.

VAQuadrantEPP Controlled 

Pyrolysis 

Cleaning 

furnace 

Model 

SCTR-9

David K Bowles 16 hours Furnace: Heat up: 4 hours; Max burn: 4 

hours; Cool down: 8 hours

Afterburner: Heat up 4 hours; max burn 4 

hours; cool down 8 hours

10 inch diameter with 17 ft straight duct 

through roof to rain shield

WabashNational

INWabashNational855

BO Andrew Frisbie 5 hours Heat up and completion of max burn 

cycle: 4 hours; Cool-down: 1 hour

30 inches

TXMadix Building C - 

Burn-off 

Oven

Barry Robinson 2- 3 hours total. (Answered: 30 minutes to 1 hour, but 

this was for max burn portion of cycle only)

Heat up: 1.5-2 hours; Max burn 30 

minutes to 1 hour, depending on whether 

hanging from rack or placed in a tub.

20 inch

Appendix A - SUMMARY OF INPUT FROM BURN-OFF OVEN RESPONDENTS
FacilityID UnitID Contact What types of stack/platform 

modifications (just those that you 

know about now) would be required 

to complete the testing?

Is the stack equipped with an 

induced draft fan? If not, is the draft 

forced by a fan or is it a natural 

draft?

Which test methods, if any, have emission test 

contractors expressed concerns about 

(regarding feasibility of testing, ability to 

sample isokinetically, other)?

CNH -

 Burlington

IACNHAmerica

INC-1 Audrey Van 

Dyke

Minor stack modifcations Natural draft The PM2.5 is a concern because of high stack 

temperatures (this is an in stack measurement 

using a filter that could be affected by high 

temperatures).

CNH -

 Grand Island

NECNHAmericaGrandIsland

ID 7996 Audrey Van 

Dyke

Minor stack modifcations forced burner fan The PM2.5 is a concern because of high stack 

temperatures (this is an in stack measurement 

using a filter that could be affected by high 

temperatures).

CNH -

 New Holland

PACNHAmericaNewHolland

INC-1 Audrey Van 

Dyke

Minor stack modifcations forced burner fan w/ draft damper in 

stack

The PM2.5 is a concern because of high stack 

temperatures (this is an in stack measurement 

using a filter that could be affected by high 

temperatures).

OHWhirlpoolClyde N001 Bob Karwowski Install two 4 inch sampling ports - $500 No induced draft fan. Forced burner 

fan (but manufacturer claims natural 

draft)

PM2.5 cyclone would not survive high stack temp 

(1400-1800 deg F). Glass probes may melt for 

metals test. High moisture levels of flue gas may 

affect methodology.

INWhirlpool Pyrolytic 

Oven #1

Bob Karwowski Would need to install a platform 10 feet 

tall for testing. Also require stack 

extension and 4 inch port ($450). 

Would need cyclone for PM testing.

No induced draft fan. Forced burner 

fan (but manufacturer claims natural 

draft)

PM2.5 cyclone would not survive high stack temp 

(1400-1800 deg F). Glass probes may melt for 

metals test. 

FLSolutia CP-L Roy Noble Will likely need to significantly modify 

stack to provide ports, heat shield for 

sampler protection, support structure for 

stack, build a sample platform, and 

removal of rain cap during testing.

No, natural draft. PM2.5 due to temperature limitations of method 

sampling apparatus.

Cooper Standard

KYCooperStandard

SN-17 Chris Massaro Add test ports No, natural draft. Stack temperature and flowrate are concerns. 

Process throughput measurements will be difficult 

since there are approximately 200-400 pounds per 

rack and less than 1 pound of material being 

burned off on each rack. It may take several 

weeks to run all of the tests.

Sealed Air Corporation

SCCryovac

FB01 Meredith 

Mangum

The roof for the fluidized bed building is 

a modestly sloped sheet metal roof with 

steel beam reinforcement. To facilitate 

stack testing, the facility has installed 

two sampling ports 90 degrees apart 

and more than 2 diameters of straight 

section downstream from the last 

interruption. Stack hangers are present 

to hold/secure testing equipment 

approximately 12 feet above the 

roofline. For a source tester to have 

adequate space and proper access to 

the sampling ports, at least four levels of 

scaffolding would be required.

Yes. The system is designed with two 

cyclones in parallel to capture heated 

sand particles and protect the 

induced draft fans from abrasion. As 

the air exists the cyclones, the exhaust 

temperature is reduced to 

approximately 225oF prior to exhaust.

The requested testing would require 4 hour test 

runs, while the batch process only operates two 

hours at a time. To perform the required testing 

the bed would have to be opened during the 

sampling run to change out parts. This would 

cause periods of no emissions during each test 

run as well as periods of process stabilization. 

Due to the short notice for testing, Sealed Air 

would be unable to hold or accumulate parts for 

longer test runs. Only two large dies are 

scheduled for processing in the next two months. 

Several small batches or short cycle times may be 

performed each day. Current equipment loads 

may not allow for continuous testing of the unit.

VAQuadrantEPP Controlled 

Pyrolysis 

Cleaning 

furnace 

Model SCTR9

David K Bowles Install two test ports and extend stack 

height to meet Method 1 requirements.

No, natural draft. Estimated flue gas 

rate of 450 - 650 acfm at 1600oF.

PM, PM2.5 and any isokinetic sampling will be 

problematic. Cycle time modifications may be 

necessary to sample, especially Method 23.

WabashNational

INWabashNational855

BO Andrew Frisbie Add sampling ports and perform 

sampling using a boom lift.

Natural draft To be determined

TXMadix Building C - 

Burn-off 

Oven

Barry Robinson Unknown, possibly a staged product 

burning not realistic to plant operations.

Natural draft Inaccurate or unable to get D/F readings, stack 

flow, a "less than" number for metals

Appendix A (cont.) - SUMMARY OF INPUT FROM BURN-OFF OVEN RESPONDENTS
FacilityID UnitID Contact What are the estimated testing costs for 

your unit?

In the Webinar, EPA indicated that for batch processes with 

short cycle times, the individual test runs do not need to 

span more than one batch cycle. How would that change the 

estimated testing costs?

Do you know the composition of the materials that are "burned off" in the oven? If 

yes, do the materials contain metals or chlorine?

CNH -

 Burlington

IACNHAmerica

INC-1 Audrey Van 

Dyke

$50,000 - $55,000 The batch cycle time was taken into consideration by the 

consultant when they developed the cost.

The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a 

review of environmental data sheets for 2008, the paint residue does not contain chlorine. 

Several low volume coatings contained HAP metals (cobalt, chromium and copper). Most of 

this would have been applied to our product and would not be on the hooks and racks that are 

cleaned in the oven.

CNH -

 Grand Island

NECNHAmericaGrandIsland

ID 7996 Audrey Van 

Dyke

$50,000 - $55,000 The batch cycle time was taken into consideration by the 

consultant when they developed the cost.

The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a 

review of environmental data sheets for 2008, the paint residue does not contain any HAP 

metals or chlorine.

CNH -

 New Holland

PACNHAmericaNewHolland

INC-1 Audrey Van 

Dyke

$50,000 - $55,000 The batch cycle time was taken into consideration by the 

consultant when they developed the cost.

The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a 

review of environmental data sheets for 2008, the paint residue does not contain chlorine. 

One low volume coating contained a HAP metal (a total of 1.74 lb cobalt compounds based on 

100 gallons of coating supplied to CNH). Most of this would have been applied to our product 

and would not be on the hooks and racks that are cleaned in the oven.

OHWhirlpoolClyde N001 Bob Karwowski Unknown, using EPA estimate of $52,000 Unknown - short process runs may require several days worth of 

testing to test for all pollutants.

Yes. No heavy metals or chlorine identified by paint and powder vendors. Facility is willing to 

run GCMS and ICPS analysis to verify these claims. Chlorine and fluorine present in small 

amounts in city water used in process. Two powder coatings contain <0.25% of fluorinated 

chemicals (PTFE).

INWhirlpool Pyrolytic 

Oven #1

Bob Karwowski Unknown, using EPA estimate of $52,000 Unknown - short process runs may require several days worth of 

testing to test for all pollutants.

Yes. No heavy metals or chlorine identified by paint and powder vendors. Facility is willing to 

run GCMS and ICPS analysis to verify these claims. Chlorine and fluorine present in small 

amounts in city water used in process. Two powder coatings contain <0.25% of fluorinated 

chemicals (PTFE).

FLSolutia CP-L Roy Noble $61,000 for one stack and $115,000 for two 

stacks if no sigificant issues with testing (this 

does not include stack/platform costs).

Costs are assumed based on three days of sampling, since each 

test run will require on batch cycle.

Yes, nylon 6,6. Some products contain phosphorous at 56 ppm. Manganese is added to one 

product at 8-14 ppm, but this product is less than 3% of annual production. Chromium may 

be present at less than 1ppm in the polymer. Sulfur, chlorine, and fluorine are not present at 

all in any nylon.

Cooper Standard

KYCooperStandard

SN-17 Chris Massaro $50,000 minimum (a month's worth of profit 

for this facility)

N/A Unknown, but unlikely to contain chlorine or metals.

Sealed Air Corporation

SCCryovac

FB01 Meredith 

Mangum

Analytical Testing Consultants, Inc. has 

proposed testing on similar sized units as part 

of the EPA 114 requests. Of their proposed 

efforts, sampling costs have ranged between 

$35,000 and $50,000 dollars. Another 

company has estimated testing to cost around 

$28,000.

Such an amendment should reduce costs slightly due to the 

overall time on-site being reduced, but the majority of the costs 

are fixed (equipment/prep).

Yes. The company primarily manufactures food packaging, thus nearly all materials used 

are approved for food contact. Furthermore, the company only allows for the cleaning of 

Sealed Air/Cryovac parts in the unit. The material “burned off” or gasified includes residual 

resin that could not be removed from the parts by hand during the

Die disassembly. These resins represent the raw materials or additives that are processed 

in the extruder to make a finished product or film. The fluidized bed itself is designed to 

accept a maximum of 30 pounds of resin per batch. The equipment could be damaged if 

more resin was introduced.

Sealed Air does not allow any dies or die parts that contact a chlorine containing resin 

from being cleaned in the fluidized bed.

Any such equipment is segregated and cleaned by hand or an alternate means. Other than 

trace contaminants not reported by the manufacturer, the only metals within the processed 

resins include titanium and zinc.

VAQuadrantEPP Controlled 

Pyrolysis 

Cleaning 

furnace 

Model SCTR9

David K Bowles Expect to cost over $65,000, including stack 

modifications, which is more than unit's value.

Unknown. Yes. No chlorine or metals are present in the products destroyed in this oven. 

WabashNational

INWabashNational855

BO Andrew Frisbie To be determined To be determined Yes, based on the MSDS of the powder coating. No chlorine or metals known.

TXMadix Building C - 

Burn-off 

Oven

Barry Robinson Verbal quote of $20,000, and written quote of 

$33,000

Unknown, but thinks it would reduce costs substantially. Yes. Powder coating hanging wires. Per 6/09 TCLP analytical results, ash from burn-off 

oven contains metals but not at hazardous levels. MSDS's of all coatings that might be 

removed via the burn-off oven can be provided.

Appendix A (cont.) - SUMMARY OF INPUT FROM BURN-OFF OVEN RESPONDENTS
FacilityID UnitID Contact What is the maximum operating temperature of the unit, 

or, in the case of multi-chamber units, the maximum 

operating temperature of each chamber?

Are the materials that are removed from the 

parts/hooks/racks in the oven combusted? If not, is 

heat used to melt or break material bonds so that the 

materials fall off of the parts/hooks/racks and are 

collected and disposed of through another means?

Any additional information provided?

CNH -

 Burlington

IACNHAmerica

INC-1 Audrey Van 

Dyke

Main chamber (750oF) and afterburner (1400oF) No. No.

CNH -

 Grand Island

NECNHAmericaGrandIsland

ID 7996 Audrey Van 

Dyke

1000oF (Main chamber) and afterburner (minimum 1400oF) No. No.

CNH -

 New Holland

PACNHAmericaNewHolland

INC-1 Audrey Van 

Dyke

Main chamber (800oF) and afterburner (1400oF minimum) No. No.

OHWhirlpoolClyde N001 Bob Karwowski 800o

F in oven chamber, and 1400oF to 1800oF in afterburner. 

Can peak at 880oF in oven and 2000oF in afterburner

Yes, but may not be true combustion. Heat is used in a 

moisture starved air atmosphere where material is 

decomposed into ash. The coating on the ware will smolder 

and the smoke that evolves will enter the afterburner 

chamber for final destruction. Consider this a controlled air, 

pyrolytic oven.

INWhirlpool Pyrolytic 

Oven #1

Bob Karwowski 800o

F in oven chamber, and 1500oF in afterburner. Can peak 

at 880oF in oven and 2000oF in afterburner

Yes. All organics are pyrolyzed at the end of the cycle. 

Only the inorganic materials remain, which would be 

titanium dioxide powder residue on the racks and carriage. 

These are washed off in an enclosed spray booth with a 

pressurized water wand. Consider this a controlled air, 

pyrolytic oven. Adds comment to consider testing of 

materials being burned off instead of stack testing.

Site is next to airport and may have limits on stack heights. If stack 

height must be increased to perform sampling, may need to clear 

with FAA beforehand. Suggest testing Clyde, OH unit instead of this 

one since processes are identical and OH site has higher throughput 

loading and no potential stack height concerns.

FLSolutia CP-L Roy Noble 900o

F in oven chamber, and 1550oF or greater in afterburner. Materials are combusted. A small amount of ash may be 

present at end of cycle.

The major use of this oven is during maintenance overhauls of 

continuous polymerization machines. Currently there are no 

overhauls planned within the testing window. Some minor use of the 

burn off oven does occur but is not representative of the primary use 

during overhauls.

Cooper Standard

KYCooperStandard

SN-17 Chris Massaro 800o

F in furnace chamber, and 1400-1600oF in afterburner. Organic material is vaporized and then combusted in 

afterburner. Inorganic material falls to floor and is swept up 

for disposal.

The process is very low volume running approx. 16-24 hours per 

week depending on customer volume. There may not be enough 

work to run all the tests needed, requiring multiple mobilizations of 

testers. The cost of this testing is prohibitive. This facility is an 

automotive OEM supplier, and the industry is in financial peril. 

Testing would be an enormous fiscal burden to this operation.

Sealed Air Corporation

SCCryovac

FB01 Meredith 

Mangum

The fluidized bed system is a single-chamber unit that is heated 

to 4500 C to heat and clean the metal die parts.

The small quantities of residual resins that are not 

removed during the equipment disassembly process will 

gasify at the elevated temperatures. A flame which 

extends over the surface of the bed causes the gaseous 

VOCs to be combusted.

Since the fluidized bed operations schedule is dependant on 

equipment maintenance schedules, it is very difficult to plan source 

testing events for large parts (or longer cycling times). Some large 

equipment is scheduled for processing once every ten years, while 

smaller parts are cleaned much more frequently.

The batch cycling times and the EPA method run times may cause 

difficulties in achieving the prescribed test run durations. 

Furthermore, the limitation on the parts to process and the number 

of batches per day may cause testing firms to remain onsite for

extended periods. Testing would necessarily include process 

startup/stabilization period. Normalized resin loading or approaching 

maximum capacity would be difficult based upon a tight maintenance 

schedule.

VAQuadrantEPP Controlled 

Pyrolysis 

Cleaning 

furnace 

Model SCTR9

David K Bowles 1100o

F in furnace chamber, and 1400-1600oF in afterburner. 

Range of furnace chamber is 900-1100oF, and afterburner is 

1400-1600oF.

The chamber pyrolyzes the plastics and the afterburner 

oxidizes the off gases.

In this case, materials cleaned in this oven are not "burned off" as 

EPA believes. Traditional burning off causes hot spots that may 

cause damage to materials (internal cracks), leading to loss of 

quality. A pyrolysis oven is an improved version of the burnout oven 

because parts are heated up in a more controlled way. Pyrolysis 

ovens prevent uncontrolled combustion of binding agents, preventing 

crack formation. The amount of material coated on tools being 

cleaned is an average 5.3 pounds/batch and represents less than 

1.5% on a BTU basis of input to process.

WabashNational

INWabashNational855

BO Andrew Frisbie 800o

F in main chamber, and 1500oF in secondary chamber. The powder coating completely bakes off and turns into a 

very fine ash.

TXMadix Building C - 

Burn-off 

Oven

Barry Robinson 815o

F in oven chamber, and afterburner is set to 1400o

F, with a 

high temperature setting for the stack at 1600oF.

Heat breaks the bond of the coating material from the 

hanging wires and oven ash is disposed of as class 2 

material through a landfill.

Appendix A (cont.) - SUMMARY OF INPUT FROM BURN-OFF OVEN RESPONDENTS
Appendix B – Original Survey Responses 
Burlington Grand Island 

INC-1 ID 7996 

What is the cycle time of the unit for which testing has been requested?

7 hrs (+ ramp time @ max ramp) 3.25 hours varies - typically 

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time).

Max ramp to 450oF, "soak" for one hour; max ramp to 550oF, "soak" for two hours; max ramp to 650o, "soak" for two hours; max ramp to 750o, "soak" for two hours.

Startup 0.75 hr, Bake 2 hr, Cool 0.5 hr Startup 0.75 hr; 

3-4 hr.

What size is the stack? Circular - 12 inches 18 inches 18 InchesWhat types of stack/platform modifications (just those that you know about now) would be required to complete the testing?

Minor stack modifcations Minor stack modifcations Minor stack mod

Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is it a natural draft?

Natural draft forced burner fan forced burner fan 

Which test methods, if any, have emission test contractors expressed concerns about (regarding 

feasibility of testing, ability to sample isokinetically, 

other)?

The PM2.5 is a concern because of high stack temperatures (this is an in stack measurement using a filter that could be affected by high temperatures).

The PM2.5 is a concern because of high stack temperatures (this is an in stack measurement using a filter that could be affected by high temperatures).

The PM2.5 is a ctemperatures (th

using a filter that temperatures).

What are the estimated testing costs for your unit? $50,000 - $55,000 $50,000 - $55,000 $50,000 - $55,00

In the Webinar, EPA indicated that for batch processes with short cycle times, the individual 

test runs do not need to span more than one batch 

cycle. How would that change the estimated testing costs?

The batch cycle time was taken into consideration by the consultant when they developed the cost.

The batch cycle time was taken into consideration by the consultant when they developed the cost.

The batch cycle consideration by developed the co

Do you know the composition of the materials that are "burned off" in the oven? If yes, do the materials contain metals or chlorine?

The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a review of environmental data sheets for 2008, the paint residue does not contain chlorine. Several low volume coatings contained HAP metals (cobalt, chromium and copper). Most of this would have been applied to our product and would not be on the hooks and racks that are cleaned in the oven.

The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a review of environmental data sheets for 2008, the paint residue does not contain any HAP metals or chlorine.

The burnoff oven 

paint from metal 

review of environthe paint residue One low volume metal (a total of based on 100 gaCNH). Most of tto our product anand racks that a

What is the maximum operating temperature of the unit, or, in the case of multi-chamber units, the maximum operating temperature of each chamber?

Main chamber (750oF) and afterburner (1400oF) 1000oF (Main chamber) and afterburner 

(minimum 1400oF)

Main chamber (8(1400oF minimum

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means?

No. No. No. No. No. No.

Burn off oven questions

Unit requested to be tested
Burlington Grand Island 

INC-1 ID 7996

What is the cycle time of the unit for which testing has been requested?

7 hrs (+ ramp time @ max ramp) 3.25 hours 

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time).

Max ramp to 450oF, "soak" for one hour; max ramp to 550oF, "soak" for two hours; max ramp to 650o, "soak" for two hours; max ramp to 750o, "soak" for two hours.

Startup 0.75 hr, Bake 2 hr, Cool 0.5 hr

What size is the stack? Circular - 12 inches 18 inchesWhat types of stack/platform modifications (just those that you know about now) would be required to complete the testing?

Minor stack modifcations Minor stack modifcations Minor stack mod

Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is it a natural draft?

Natural draft forced burner fan

Which test methods, if any, have emission test contractors expressed concerns about (regarding 

feasibility of testing, ability to sample isokinetically, 

other)?

The PM2.5 is a concern because of high stack temperatures (this is an in stack measurement using a filter that could be affected by high temperatures).

The PM2.5 is a concern because of high stack temperatures (this is an in stack measurement using a filter that could be affected by high temperatures).

The PM2.5 is a ctemperatures (th

using a filter that temperatures).

What are the estimated testing costs for your unit? $50,000 - $55,000 $50,000 - $55,000 $50,000 - $55,00

In the Webinar, EPA indicated that for batch processes with short cycle times, the individual 

test runs do not need to span more than one batch 

cycle. How would that change the estimated testing costs?

The batch cycle time was taken into consideration by the consultant when they developed the cost.

The batch cycle time was taken into consideration by the consultant when they developed the cost.

The batch cycle consideration by developed the co

Do you know the composition of the materials that are "burned off" in the oven? If yes, do the materials contain metals or chlorine?

The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a review of environmental data sheets for 2008, the paint residue does not contain chlorine. Several low volume coatings contained HAP metals (cobalt, chromium and copper). Most of this would have been applied to our product and would not be on the hooks and racks that are cleaned in the oven.

The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a review of environmental data sheets for 2008, the paint residue does not contain any HAP metals or chlorine.

The burnoff oven 

paint from metal 

review of environthe paint residue One low volume metal (a total of based on 100 gaCNH). Most of tto our product anand racks that a

What is the maximum operating temperature of the unit, or, in the case of multi-chamber units, the maximum operating temperature of each chamber?

Main chamber (750oF) and afterburner (1400oF) 1000oF (Main chamber) and afterburner 

(minimum 1400oF)

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means?

No. No. No. No. No. No.

Burn off oven questions

Unit requested to be tested
See the following for the answers to the questions presented in your email of June 25, 

2009. These answers concern Unit CP-L at the Ascend Performance Materials LLC 

(formerly Solutia Inc.) Pensacola Plant. 

What is the cycle time of the unit for which testing has been requested? 

The cycle time varies depending on amount of equipment being reclaimed and amount of 

polymer. As there are no methods to determine a true “end of cycle” the burn off oven is 

typically operated overnight to ensure complete removal of nylon 6, 6. The estimated 

burn off rate is 60 pounds per hour. See following question for additional details. 

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat 

time, cool-down time). 

The typical cycle time consists of a 4 hour heat up period, 10 –12 hours maximum heat 

time to ensure complete burn off of the nylon 6, 6 and the cool down time varies based on 

the equipment being reclaimed. 

What size is the stack? 

Two (2) stacks approximately 25 feet above grade and 10 - 12 inch ID (16 inch OD with 

2 – 3 inches of insulation) 

What types of stack/platform modifications (just those that you know about now) would 

be required to complete the testing? 

The stacks are self supporting and constructed of insulation surrounded sheet metal, 

guyed to the roof of the shed and are not equipped for stack sampling. The stacks would 

need to be reconstructed to add sampling ports and additional support. A heat shield 

would also need to be installed to protect the stack samplers. The rain cap would need to 

be cut off to reduce positive pressure in stack during sampling and re-welded in place 

after testing. The shed roof is slanted and not rated to support personnel. A sampling 

platform(s) would need to be constructed to support personnel and equipment. 

Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is it 

a natural draft? 

Natural draft 

Which test methods, if any, have emission test contractors expressed concerns about 

(regarding feasibility of testing, ability to sample isokinetically, other)? 

There are concerns over the temperature of the gases in the stack and potential blockage 

of flow due to the small stack diameter. They believe that ports would need to installed at 

different planes. The testing firm specifically expressed concern over PM2.5 sampling 

due to the stack temperatures. While stack exhaust temperature profiles in the stacks are 

not known, the exit afterburner temperature is typically above 1500o F and with the 

relatively short stacks it is reasonable to assume that exit temperatures are above 500o F. 

OTM 27 section 1.6 states: "1.6 Limitations. You cannot use this method to measure 

emissions following a wet scrubber because this method is not applicable for in-stack 
gases containing water droplets. To measure PM10 and PM2.5 in emissions where water 

droplets are known to exist, we recommend that you use Method 5. This method may 

not be suitable for sources with stack gas temperatures exceeding 260°C (500°F). You 

may need to take extraordinary measures—including the use of specialty metals (e.g., 

Inconel) to achieve reliable particulate mass since the threads of the cyclones may 

gall or seize, thus preventing the recovery of the collected particulate matter and 

rendering the cyclone unusable for subsequent use." 

PM2.5 testing, even on a single stack, would require extraordinary measures. No 

alternate test methods are provided for this analyte. Additionally, as the unit is natural 

draft, the low variable flow rates and high exhaust temperatures may preclude valid flow 

measurements. 

What are the estimated testing costs for your unit? 

Estimated costs (based on one preliminary quote) were $61,000 for testing one stack and 

$115,000 for testing two stacks assuming no issues with the testing. This does not 

include any costs associated with redesigning, constructing and installing modified 

stacks and sampling platform(s). 

In the Webinar, EPA indicated that for batch processes with short cycle times, the 

individual test runs do not need to span more than one batch cycle. How would that 

change the estimated testing costs? 

The above cost estimate is based on 3 days of testing. Each test run would be for one 

batch cycle. 

Do you know the composition of the materials that are "burned off" in the oven? If yes, 

do the materials contain metals or chlorine? 

The burn off oven burns off nylon 6, 6. The nylon is not known to contain any of the 

constituents being sampled for with the following exceptions. Phosphorous may be 

added to the nylon at a target concentration of 56 ppm depending on the product. 

Manganese is added to one product at between 8 – 14 ppm. This product represents less 

than 3% of a typical year’s production. Chromium may be present at less than 1 ppm in 

the polymer. Sulfur, chlorine and fluorine are not present in any of the nylon 6, 6 placed 

into the burn off ovens. 

What is the maximum operating temperature of the unit, or, in the case of multi-chamber 

units, the maximum operating temperature of each chamber? 

The main chamber pyrolyzes the nylon 6, 6 at approximately 900 F and the off gases are 

passed through afterburners operating at greater than or equal to 1550 F. 

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If 

not, is heat used to melt or break material bonds so that the materials fall off of the 

parts/hooks/racks and are collected and disposed of through another means? 
In general the materials are combusted. A small amount of ash may be present at end of 

cycle. 

Please feel free to provide any other information that you believe may be pertinent to the 

feasibility of emission testing. 

The major use of this burn off oven is during maintenance overhauls of continuous 

polymerization machines. Currently there are no overhauls planned within the testing 

window. Some minor use of the burn off oven does occur but is not representative of 

the primary use during overhauls. 

Should testing be conducted during the initial heat-up cycle of the main chamber? 

Should you have any additional questions, please contact me at (850) 968-98721 or 

Roy.W.Noble@AscendMaterials.com. 

Roy Noble 
Please see below for answers to the requested information. Please let me know if you need additional 

information. 

What is the cycle time of the unit for which testing has been requested? 

The cycle time of the oven is 4 hours from start up till the time all material has been baked off. 

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down 

time). 

It may take an hour or less for it to cool down to where you can open the door. The materials are 

still hot for probably another hour. 

What size is the stack? 

Approximately 30 inches 

What types of stack/platform modifications (just those that you know about now) would be required to 

complete the testing ? 

We would need to add sampling ports and access ports via a boom lift. 

Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is it a natural draft? 

Natural Draft 

Which test methods, if any, have emission test contractors expressed concerns about (regarding feasibility 

of testing, ability to sample isokinetically, other)? 

To be determined 

What are the estimated testing costs for your unit? 

To be determined 

In the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do 

not need to span more than one batch cycle. How would that change the estimated testing costs? 

To be determined 

Do you know the composition of the materials that are "burned off" in the oven? If yes, do the materials 

contain metals or chlorine? 

We do know the composition based on the MSDS for the powder coating, none known. 

What is the maximum operating temperature of the unit, or, in the case of multi-chamber units, the 

maximum operating temperature of each chamber? 

800 F for the main chamber, 1500 for the secondary chamber 

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used 

to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and 

disposed of through another means? 

The powder coating completely bakes off and turns into a very fine ash. 

Thanks, 

Andrew Frisbie, Ph.D., CHMM 

ISO14001 EMS Management Representative 

Senior Environmental, Health and Safety Engineer 

Wabash National Corporation 

Phone (765) 771-5443 

Cell (765) 532-9985 
KYCooperStandard 

What is the cycle time of the unit for which testing has been requested? 8 hrs 

process time.

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum 

heat time, cool-down time). Warm up is 90 minutes, processing time of 8 hrs. and a 

cool down time of 60 minutes. 

What size is the stack? Stack has an OD of 14” and an ID of 10” The top of the 

stack is 93” above the roof surface.

What types of stack/platform modifications (just those that you know about now) 

would be required to complete the testing ? Test ports would need to be added.

Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan 

or is it a natural draft? Natural Draft 

Which test methods, if any, have emission test contractors expressed concerns about 

(regarding feasibility of testing, ability to sample isokinetically, other)? Stack 

temperature and Flow, Will also have difficulty measuring the process throughput 

due to the large weight of the racks and the small quantity of removable material. 

(Approximately 200-400 pounds for each of the racks, and less than a pound of 

material on each rack) There is a potential for the testers to have to remobilize for 

an additional week(s) to run all of the tests.

What are the estimated testing costs for your unit? $50,000 minimum, this is a 

month’s worth of profit for the facility.

In the Webinar, EPA indicated that for batch processes with short cycle times, the 

individual test runs do not need to span more than one batch cycle. How would that 

change the estimated testing costs? N/A.

Do you know the composition of the materials that are "burned off" in the oven? If 

yes, do the materials contain metals or chlorine? Contents are not directly known 

but are unlikely to contain metals or Cl2 

What is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber? Furnace is 

800° F the Afterburner is 1400°-1600° F 

Are the materials that are removed from the parts/hooks/racks in the oven 

combusted? If not, is heat used to melt or break material bonds so that the 

materials fall off of the parts/hooks/racks and are collected and disposed of through 

another means? Organic material is vaporized and then combusted in the 

afterburner. Any Inorganic material falls to the floor of the unit and is swept up for 

disposal. 
Please feel free to provide any other information that you believe may be pertinent 

to the feasibility of emission testing. The process is very low volume running 

approximately 16 to 24 hrs per week dependant on customer volume. There may 

not be enough work to run all the tests needed. This would result in multiple 

mobilizations by the testers. 

Please feel free to provide any other information that you believe may be pertinent to the 

feasibility of emission testing. The cost of this testing is very prohibitive. This facility 

is an automotive OEM supplier. The entire industry is in financial peril. Testing of 

this process would be an enormous fiscal burden to the operation.

When EPA concludes consideration of this issue, we will consider extension requests 

for units that are required to perform testing. 
What is the cycle time of the unit for which testing has been requested? 

The fluidized bed’s (FB-01) cycle time is dependant upon the part being loaded and the 

level of assembly/disassembly. Traditional processing times for equipment loaded into 

FB-01 includes a two hour heating cycle. The temperature of the bed drops between 25 

and 50 degrees Celsius immediately after the cage of parts is loaded into 

the unit. During the first 20 minutes after loading the parts cage, a natural gas burner is 

fired to raise the bed to optimum temperature (approximately 450oC) and stabilize bed 

conditions (air flow, temperature,). During the handling and cleaning of the metal parts, 

the sand bed is maintained at an elevated temperature for approximately 1 hour 

and 40 minutes. The fluidized bed enclosure is then opened and the parts removed. The 

fluidized bed is maintained at temperature awaiting the loading of the next set of parts. 

Some larger extruder dies may require up to 4 hours of immersion in the sand bed 

Once heated, the parts/cage is placed in a separate water quench bath for approximately 

15 minutes to drop the temperature of the equipment and remove any residual sand. The 

cooled parts are then dipped in an oil quench tank to coat the parts with a light oil to 

protect the equipment and assist in the re-assembly process. A total of Four dies or 

batches may be processed each day (24 hour period). 

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum 

heat time, cool-down time). 

Once the fluidized bed has reached to operating temperature, the cycling time is 

dependant upon the level of metal parts assembly/disassembly and the size of the 

die itself. Most die equipment at the Simpsonville plant take approximately 2 hours 

To clean, while a couple of large units may take up to 4 hours. 

In rare instances, the die is loaded into the fluidized bed intact (not disassembled). 

Since the sand does not directly contact all the parts, the die must remain in the heated 

bath for approximately 6 to 8 hours. This event is limited to the cleaning of R&D dies 

which may include confidential or patented applications. 

What size is the stack? 

From the roofline, a twenty-four (24) inch stack extends 28 feet above the die 

maintenance shop roofline. The air flow from two fans combine approximately 2 feet 

below the roofline. 

What types of stack/platform modifications (just those that you know about now) 

would be required to complete the testing ? 

The roof for the fluidized bed building is a modestly sloped sheet metal roof with steel 

beam reinforcement. To facilitate stack testing, the facility has installed two sampling 

ports 90 degrees apart and more than 2 diameters of straight section downstream from the 

last interruption. Stack hangers are present to hold/secure testing equipment 

approximately 12 feet above the roofline. For a source tester to have adequate space and 

proper access to the sampling ports, at least four levels of scaffolding would be required. 
Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan 

or is it a natural draft? 

 

Yes. The system is designed with two cyclones in parallel to capture heated sand 

particles and protect the induced draft fans from abrasion. As the air exists the 

cyclones, the exhaust temperature is reduced to approximately 225oF prior to exhaust. 

Which test methods, if any, have emission test contractors expressed concerns about 

(regarding feasibility of testing, ability to sample isokinetically, other)? 

The requested testing would require 4 hour test runs, while the batch process only 

operates two hours at a time. To perform the required testing the bed would have to be 

opened during the sampling run to change out parts. This would cause periods of no 

emissions during each test run as well as periods of process stabilization. Due to the 

short notice for testing, Sealed Air would be unable to hold or accumulate parts for longer 

test runs. Only two large dies are scheduled for processing in the next two months. 

Several small batches or short cycle times may be performed each day. Current 

equipment loads may not allow for continuous testing of the unit. 

What are the estimated testing costs for your unit? 

Analytical Testing Consultants, Inc. has proposed testing on similar sized units as part of 

the EPA 114 requests. Of their proposed efforts, sampling costs have ranged between 

$35,000 and $50,000 dollars. Another company has estimated testing to cost around 

$28,000. 

In the Webinar, EPA indicated that for batch processes with short cycle times, the 

individual test runs do not need to span more than one batch cycle. How would that 

change the estimated testing costs? 

Such an amendment should reduce costs slightly due to the overall time on-site being 

reduced, but the majority of the costs are fixed (equipment/prep). 

Do you know the composition of the materials that are "burned off" in the oven? If 

yes, do the materials contain metals or chlorine? 

Yes. The company primarily manufactures food packaging, thus nearly all materials 

used are approved for food contact. Furthermore, the company only allows for the 

cleaning of Sealed Air/Cryovac parts in the unit. The material “burned off” or gasified 

includes residual resin that could not be removed from the parts by hand during the 

Die disassembly. These resins represent the raw materials or additives that are 

processed in the extruder to make a finished product or film. The fluidized bed itself is 

designed to accept a maximum of 30 pounds of resin per batch. The equipment could 

be damaged if more resin was introduced. 
Sealed Air does not allow any dies or die parts that contact a chlorine containing 

resin from being cleaned in the fluidized bed. 

Any such equipment is segregated and cleaned by hand or an alternate means. Other 

than trace contaminants not reported by the manufacturer, the only metals within the 

processed resins include titanium and zinc. 

What is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber? 

The fluidized bed system is a single-chamber unit that is heated to 4500 C to heat and 

clean the metal die parts. 

Are the materials that are removed from the parts/hooks/racks in the oven 

combusted? If not, is heat used to melt or break material bonds so that the 

materials fall off of the parts/hooks/racks and are collected and disposed of through 

another means? 

The small quantities of residual resins that are not removed during the equipment 

disassembly process will gasify at the elevated temperatures. A flame which 

extends over the surface of the bed causes the gaseous VOCs to be combusted. 

Please feel free to provide any other information that you believe may be pertinent 

to the feasibility of emission testing. 

Since the fluidized bed operations schedule is dependant on equipment maintenance 

schedules, it is very difficult to plan source testing events for large parts (or longer 

cycling times). Some large equipment is scheduled for processing once every ten years, 

while smaller parts are cleaned much more frequently. 

The batch cycling times and the EPA method run times may cause difficulties in 

achieving the prescribed test run durations. Furthermore, the limitation on the parts to 

process and the number of batches per day may cause testing firms to remain onsite for 

extended periods. Testing would necessarily include process startup/stabilization period. 

Normalized resin loading or approaching maximum capacity would be difficult based 

upon a tight maintenance schedule. 

If you have any questions or comments, please feel free to contact me as 

indicated below, or Meredith Mangum at (864) 967-1376. 

Bobby Cullom 

Global Environmental Engineer 

Sealed Air Corporation 

100 Rogers Bridge Road, Building A 

Duncan, South Carolina 29334 

Direct: (864) 433-2334 

Fax: (864) 433-2723 
TXMadix 

From: Shrager.Brian@epamail.epa.gov [ 

mailto:Shrager.Brian@epamail.epa.gov] 

Sent: Thursday, June 25, 2009 1:09 PM 

To: shrager.brian@epa.gov 

Subject: Burn off oven follow-up questions 

Please respond to this e-mail if you are the owner/operator of a burn off oven and 

received the EPA section 114 ICR letter requiring emissions testing by October 15, 2009. 

In order to address concerns with testing these units, we require additional information on 

the units. Your prompt response will facilitate EPA's consideration of these units. 

Burn off oven questions (please answer separately for each oven for which you received a 

test request) 

What is the cycle time of the unit for which testing has been requested? 30 minutes to 1 

hour depending upon placement of material to be burned. If hanging wires are on a rack, 

it will be 30 minutes. If placed in a tub it is extended to 1 hour. 

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat 

time, cool-down time). 1.5-2 hour warm up time then cycle starts and runs for 30 minutes 

or 1 hour. 

What size is the stack? 

20” 

What types of stack/platform modifications (just those that you know about now) would 

be required to complete the testing ? 

unknown, possibly a staged product burning not realistic to plant operations 

Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is it 

a natural draft? 

Natural draft 

Which test methods, if any, have emission test contractors expressed concerns about 

(regarding feasibility of testing, ability to sample isokinetically, other)? 

Inaccurate or unable to get D/F readings, stack flow, a “less than” number on metals 

What are the estimated testing costs for your unit? 

One verbal quote of $20,000 and one written quote of $33,000 

In the Webinar, EPA indicated that for batch processes with short cycle times, the 

individual test runs do not need to span more than one batch cycle. How would that 

change the estimated testing costs? Unknown. I would think it would reduce costs 

substantially Do you know the composition of the materials that are "burned off" in 
the oven? If yes, do the materials contain metals or chlorine? 

Yes. Powder coated hanging wires. Per 6/09 TCLP analytical results, ash from burn-off 

oven contains metals but not at hazardous levels. MSDS’s of all coatings that might be 

removed via the burn off oven can be provided. 

What is the maximum operating temperature of the unit, or, in the case of multi-chamber 

units, the maximum operating temperature of each chamber? 

It’s a one chamber over set to operate at 915 degrees. Afterburner is set at 1400 degrees 

F and stack high temp setting is 1600 degrees F. 

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If 

not, is heat used to melt or break material bonds so that the materials fall off of the 

parts/hooks/racks and are collected and disposed of through another means? 

Heat breaks the bond of the coating material from the hanging wires and oven ash is 

disposed of as class 2 material through a landfill. 

Please feel free to provide any other information that you believe may be pertinent to the 

feasibility of emission testing. 

When EPA concludes consideration of this issue, we will consider extension requests for 

units that are required to perform testing. 

Thanks! 

Brian Shrager 

Environmental Engineer 

U.S. EPA Office of Air Quality Planning and Standards 

Sector Policies and Programs Division/Energy Strategies Group 

D243-01 

Research Triangle Park, NC 27711 

(919) 541-7689 

Fax: (919) 541-5450 
Quadrant EPP USA, Inc. Page 1 of 4

2530 N. Fourth Street • Wytheville, VA 24382 

Telephone 276.228.0100 • Fax 276.228.0119 • www.quadrantepp.com

July 1, 2009 

BY EMAIL ONLY 

Mr. Brian Shrager 

Environmental Engineer 

U.S. EPA Office of Air Quality Planning and Standards Sector Policies and Programs Division/Energy 

Strategies Group D243-01 

Research Triangle Park, North Carolina 27711 

RE: Initial response to Section 114 Email questionnaire regarding Pyrolysis Ovens CISWI Standards 

Dear Brian, 

Attached is Quadrant Engineering Plastic Products, Wytheville, Virginia facility’s response to the Follow up 

survey in you email June 26, 2009. If we need to provide further clarification please let me know. 

We would appreciate the opportunity to discuss our process with you so that USEPA has a clearer 

understanding of the operation and the severity of the impact of such an increase in the CISWI standards 

would cause to our business. 

Please contact me should you have any questions. 

David K. Bowles 

Quadrant EPP 

2530 N 4th St 

Wytheville, Va. 24382 

cc. Alan Freeman 

Rick Frey
Quadrant EPP USA, Inc. Page 2 of 4

2530 N. Fourth Street • Wytheville, VA 24382 

Telephone 276.228.0100 • Fax 276.228.0119 • www.quadrantepp.com

Response to Section 114 Questionnaire regarding CISWI potentially regulated facilities

June 25, 2009 

Burn off oven questions (please answer separately for each oven for which you received a test request): 

Initial Comments: 

The unit in question is our Controlled Pyrolysis Cleaning furnace Model SCTR-9. 

This small furnace is used to remove small amounts of Nylon and Polyacetal resins 

that accumulate on screws and Extrusion dies. The unit has been in operation for 

more than 10 years and represents an integral part of the cleaning process of 

various equipment. Without this equipment, significant cost increases and 

increases in solid waste generation will be expected. 

What is the cycle time of the unit for which testing has been requested? 

The total Cycle time typically is 16 Hours.

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat 

time, cool-down time). 

Furnace chamber Afterburner

4 Hour Heat- up from Ambient to 1000 o F 4 Hours from Ambient to 1600 F 

4 Hour Cleaning Cycle @ 1000 o F 4 Hours @ 1600 F 

8 Hour Cool down to Ambient 8 Hours 1600 o F to Ambient

What size is the stack? 

The stack is 10 Inch Diameter with a total of 17 Ft Straight ducting thru the roof to a 

Chinese Hat covered vent. 

What types of stack/platform modifications (just those that you know about now) would be 

required to complete the testing? 

The stack would require the installation of 2 test ports at 90 degrees to each other, 

either below the roof-line, or above the roof. It would be considerable expense to 

establish the required stack height in order to meet EPA Method 1. In addition, the 

diameter of the stack may preclude any compliance with stack testing protocols due 

to its ten inch diameter.
Quadrant EPP USA, Inc. Page 3 of 4

2530 N. Fourth Street • Wytheville, VA 24382 

Telephone 276.228.0100 • Fax 276.228.0119 • www.quadrantepp.com

Is the stack equipped with an induced draft fan? No. If not, is the draft forced by a fan or 

is it a natural draft? 

The stack has only induced draft. The maximum exit gas volume is estimated at 450 

to 650 ACFM at 1600 degrees F. 

Which test methods, if any, have emission test contractors expressed concerns about 

(regarding feasibility of testing, ability to sample isokinetically, other)? 

PM10, PM2.5 and any of the isokinetic sampling protocols are expected to be 

problematic for measuring emissions from this system. Further with the large 

number of potential facility locations which stack testing may be required we have 

been advised that testing may not be able to be achieved by the October 2009 

deadline. Particulate emissions have not been seen nor expected due to the lack of 

forced velocity. Monitoring for either PM10 or PM2.5 would be not be expected to 

yield significant results. Sample time required for these tests are a minimum of 4 

hours, which would impact the entire cycle of cleaning which this unit is currently 

programmed. The Method 23 protocol would have to be modified, and possible 

extrapolated for a 4 hour burn time. Excess O2 may also be a problem since this is a 

pyrolysis oven which is naturally operated in a low O2 environment. 

What are the estimated testing costs for your unit? With the modifications to the stack 

height (if diameter is acceptable), we expect testing to cost over $65,000 which may 

exceed the value of the oven. 

In the Webinar, EPA indicated that for batch processes with short cycle times, the 

individual test runs do not need to span more than one batch cycle. How would that 

change the estimated testing costs? Unknown.

Do you know the composition of the materials that are "burned off" in the oven? Yes. If 

yes, do the materials contain metals or chlorine? NO. In this case, materials cleaned in 

this oven are not” burned off” as EPA believes. In the process of traditional 

burning-out of materials, the binding agents (e.g. varnish, resin, paint and plastic) 

will combust (due to the high oxygen content), so that the heating of the materials 

will not be equal. This unequal heating (hot spots) may cause damage to materials 

(internal cracks), leading to loss of quality. This tended to be a problem with 'burnoff' ovens. A Pyrolysis Oven can be said to be the improved version of a standard 

“burnout” oven. The degree of control is much better as the parts are heated up in a 

more controlled way. Pyrolysis Ovens are capable of decomposing larger amounts 

of binding agents in comparison with the traditional burnout ovens, since no 

combustion can take place in a low-oxygen environment, allowing the temperature 

control to remain optimal. A review of all raw materials and final products do not 
Quadrant EPP USA, Inc. Page 4 of 4

2530 N. Fourth Street • Wytheville, VA 24382 

Telephone 276.228.0100 • Fax 276.228.0119 • www.quadrantepp.com

indicate that metals or chlorine containing precursors are present in the products 

destroyed in this oven. Further, the amount of material coated on the tools being 

cleaned is an average 5.3 pounds per batch, and represents an estimate less than 

1.5% on a BTU basis of the amount of BTUs utilized in the process.

What is the maximum operating temperature of the unit, or, in the case of multi-chamber 

units, the maximum operating temperature of each chamber? 

The furnace Chamber maximum temperature is 1100 F. with a range 900 to 1100o f 

The afterburner Maximum temperature is 1600 o F with a range from 1400 o F to 

1600o F. 

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If 

not, is heat used to melt or break material bonds so that the materials fall off of the 

parts/hooks/racks and are collected and disposed of through another means? 

The Primary chamber is a low oxygen environment pyrolyzes the plastics and the 

Afterburner Oxidizes the off gasses.
Dear Mr. Shrager: 

RE: CISWI 

Whirlpool Corp 

The Whirlpool Clyde & Evansville facilities received EPA’s request on 

providing stack sampling information for the NSPS Commercial, Industrial 

Solid Waste Incinerators (CISWI). Whirlpool is always willing to assist 

EPA in their requests for data. However, per our earlier discussion on 

Whirlpool’s stack sampling, please consider the elimination of one of 

Whirlpool’s sites for testing. 

As explained during our call, both of Whirlpool’s “burn-off oven” 

processes are identical (See equipment manufacture’s letter attached) 

and testing for both systems would not be productive. Whirlpool is 

requesting that the Evansville IN site be removed from the list. We 

feel the Clyde OH facility would represent a more suitable data point in 

that its hook loading rates are higher that Evansville’s. 

Further, the Evansville facility is adjacent to an airport, and stack 

heights are restricted. If a stack height increase is needed to reduce 

temperatures for PM2.5 sampling, it may not be allowed by FAA rules. 

If you need anymore information or have any questions, please give me a 

call at 269/923-3614. 

A "hard copy" of this request will also be submitted. 

Thank You., 

Robert J. Karwowski 

Director, NAR Environmental, Health & Safety 

Phone - 269-923-3614 

Fax - 269-923-5768 
Please respond to this e-mail if you are the owner/operator of a burn off oven and 

received the EPA section 114 ICR letter requiring emissions testing by October 15, 

2009. In order to address concerns with testing these units, we require additional 

information on the units. Your prompt response will facilitate EPA's consideration 

of these units. 

Burn off oven questions (please answer separately for each oven for which you 

received a test request) 

Location: Whirlpool Corporation 

 119 Birdseye St. 

 Clyde, OH 43410 

Contact: Gary Jaeger, Environmental Engineer 

Corporate Contact: Bob Karwowski 

What is the cycle time of the unit for which testing has been requested? 

Typically, we have a twelve hour burn cycle followed by a cool-down period, 

unloading, oven cleaning, and a reloading process. Normally only one cycle is 

completed in a 24 hour period during each work day. Most often, the unloading, 

cleaning and reloading is done the following day. 

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum 

heat time, and cool-down time). 

The total burn cycle is typically a twelve hour process for powdered paint 

tooling. Tooling from the wet paint processes normal have a much lower coating 

build-up and the full burn cycle can be less (Possibly as low as eight hours). 

Start-up time and temperature ramp-up takes approximately 1 hour. Maximum heat 

(strong burn) cycle time is between two to four hours dependent on the loading. 

The remaining polishing cycle time is utilized to complete the pyrolysis process. 

What size is the stack? 

The stack is circular in shape with a measured inner diameter of 14 inches, outer 

diameter of 18 inches, with a two inch ceramic fiber lining. 

What types of stack/platform modifications (just those that you know about now) 

would be required to complete the testing? 

If the sampling train can be set-up similar to a previous test sequence we ran 

back in Dec 2002 for PM, we would merely set up the sample train at approximately 

4.5 foot above the roof level. Stack modifications with two four inch sampling 

ports will cost approximately $ 500.00.
Is the stack equipped with an induced draft fan? 

No 

If not, is the draft forced by a fan or is it a natural draft? 

A natural draft is created by the lower chamber burner and the after-burner. 

Each burner has an integral forced air feed blower for combustion air. The 

Manufacturer refers to this as a natural draft system. The pyrolytic ovens are 

designed to operate under starved air (pyrolytic) conditions 

Which test methods, if any, have emission test contractors expressed concerns about 

(regarding feasibility of testing, ability to sample isokinetically, other)? 

We do not have a contractor on board at this time. The contractor we used back 

in 2002 indicated the in-stream PM 2.5 cyclone would not survive the stack 

temperature. Typical stack temperatures are between 1400 F and 1800 F. 

Temperatures can peak above 2000°F under a full load, but this is not a normal 

operational practice. 

Various testing contractors have also mentioned concerns with probes used for the 

metals test. Glass sample probes may melt. Air cooled or water cool probes may 

suffice. Water moisture levels do run higher in these ovens by design and can 

have an effect on test methodology.

What are the estimated testing costs for your unit? 

The cost is unknown at this time. We are in the process of learning what the 

scope of work entails and preparing the RFQ for the contractors. EPA estimates 

for sampling and analysis was $52,000. 

In the Webinar, EPA indicated that for batch processes with short cycle times, the 

individual test runs do not need to span more than one batch cycle. How would that 

change the estimated testing costs? 

Unknown - Due to short process runs, it may take several days to perform all the 

required testing. This would have a tendency to increase costs. 

Do you know the composition of the materials that are "burned off" in the oven? 

Yes 

If yes, do the materials contain metals or chlorine? 

No heavy metals or chorine have been identified by the paint & powder vendors. 

Whirlpool is willing to run GCMS and ICPS analysis on the paint and powder 

fragment to verify the case. Chlorine and fluorine can be found present in low 

levels in the city water which is used in the process. Two powder coating 

products contain <0.25% concentration of fluorinated chemicals (PTFE). 
What is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber? 

The oven chamber normally is held at 800°F once it reaches its standard operating 

temperature. It can peak to 880°F. The afterburner is normally set to operate 

from 1400°F to 1800°F, but can peak above 2000°F. 

Are the materials that are removed from the parts/hooks/racks in the oven combusted? 

Yes, but this may not be considered a true combustion process. Heat is used in a 

moisture starved air atmosphere where the material is decomposed into an ash. 

The coating on the ware will smolder and the smoke that evolves will enter the 

afterburner chamber for final destruction. 

Please note that this type of process may not be actually considered as 

“incinerators”, but are rather controlled air, pyrolytic ovens. They are a 

unique breed. The primary oven has minimal turbulence and maximum temperature 

control. Any organics that volatilize continue into the afterburner and are 

consumed at temperatures above 1,400°F.

If not, is heat used to melt or break material bonds so that the materials fall off 

of the parts/hooks/racks and are collected and disposed of through another means? 

Please feel free to provide any other information that you believe may be pertinent 

to the feasibility of emission testing. 

When EPA concludes consideration of this issue, we will consider extension requests 

for units that are required to perform testing. 

Thanks! 

Brian Shrager 

Environmental Engineer 

U.S. EPA Office of Air Quality Planning and Standards 

Sector Policies and Programs Division/Energy Strategies Group 

D243-01 

Research Triangle Park, NC 27711 

(919) 541-7689 

Fax: (919) 541-5450 
Please respond to this e-mail if you are the owner/operator of a burn off oven and 

received the EPA section 114 ICR letter requiring emissions testing by October 15, 

2009. In order to address concerns with testing these units, we require additional 

information on the units. Your prompt response will facilitate EPA's consideration 

of these units. 

Burn off oven questions (please answer separately for each oven for which you 

received a test request) 

Location: Whirlpool Corporation 

 5401 U.S. Highway 41 North 

 Evansville, IN 47727 

Contact: Greg Kissel, Environmental Engineer 

Corporate Contact: Bob Karwowski 

 

What is the cycle time of the unit for which testing has been requested? 

A five hour burn cycle is typical (longest cycle time would be 6 hours). Upon the completion of the cycle, the oven 

cools overnight, followed by unload, cleaning, and reload process. Since this is a one shift operation, only one batch is 

completed in a work day. 

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum 

heat time, and cool-down time). 

The total burn cycle is typically a five hour process. Start-up time and temperature ramp-up takes approximately 1 hour. 

Maximum heat (strong burn) cycle time is between one to two hours. The remaining cycle time is utilized to complete 

the pyrolysis process. 

What size is the stack? 

The stack is circular in shape with a measured inner diameter of 14 inches and an outer diameter of 18 inch. The annulus 

contains two inches ceramic fiber insulation. 

What types of stack/platform modifications (just those that you know about now) 

would be required to complete the testing? 

A platform approximately ten feet tall would be required for stack testing. A stack extension with four inch ports would 

be necessary for stack testing (cost approximately $450). A cyclone for PM testing would also be required. 

Is the stack equipped with an induced draft fan? 

No 
If not, is the draft forced by a fan or is it a natural draft? 

A natural draft is created by the lower chamber burner and the after-burner. Each burner has an integral forced air feed 

blower for combustion air. The Manufacturer refers to this as a natural draft system. The pyrolytic ovens are designed 

to operate under starved air (pyrolytic) conditions 

Which test methods, if any, have emission test contractors expressed concerns about 

(regarding feasibility of testing, ability to sample isokinetically, other)? 

We do not have a contractor on board at this time. There is a concern regarding the in-stream PM 2.5 cyclone would not 

survive the stack temperature. The stack operates at 1500 F at full load. There are also concerns with probes used for 

the metals test. Air jacketed or water jacketed probes may have to be considered. 

What are the estimated testing costs for your unit? 

This is unknown at this time. Clyde, Ohio facility is in the process of learning what the scope of work entails and 

preparing the RFQ for a contractor. EPA estimates for sampling and analysis indicated approximately $51,000. 

(Original purchase price of the Evansville oven was approximately $20,000) 

In the Webinar, EPA indicated that for batch processes with short cycle times, the 

individual test runs do not need to span more than one batch cycle. How would that 

change the estimated testing costs? 

Due to short process runs, it may take several days to perform all the required testing. This would have the tendency to 

increase overall costs. 

- 

Do you know the composition of the materials that are "burned off" in the oven? 

Yes 

If yes, do the materials contain metals or chlorine? 

No heavy metals or chorine have been identified by the paint vendor. Whirlpool is willing to run GCMS and ICP 

analysis on the paint to verify the case. It is noted that potable water is utilized in the process to help control the 

temperature in the primary chamber (sprayed onto the ware). The potable water may have small levels of chlorine and 

fluorine that is added at the drinking (potable) water plant. It is not well understood if this would have any impact on the 

stack constituents. 

What is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber? 

The oven primary chamber normally is held at 800 F once it reaches its standard operating temperature. The afterburner 

is normally set to operate from 1500 F. Due to the limited loading of paint on the hooks, temperatures are fairly stable. 
Are the materials that are removed from the parts/hooks/racks in the oven combusted? 

Yes. All organics are pyrolyzed at the end of the cycle. Only the inorganic materials remain, which would be titanium 

dioxide powder residue on the racks and carriage. These are washed off in an enclosed spray booth with a pressurized 

water wand. 

Please note that this type of process may not be actually considered as 

“incinerators”, but are rather controlled air, pyrolytic ovens. They are a unique 

breed. The primary oven has minimal turbulence and maximum temperature control. 

Any organics that volatilize continue into the afterburner and are consumed at high 

temperatures (1,500 F). These are generally converted to water vapor and carbon 

dioxide prior to exiting the stack. 

Also, as mentioned earlier, it would be in our best interest to determine if metals 

and halogens are in the materials being consumed by testing of the materials versus 

the high cost and effort involved in stack testing. Other federal regulations allow 

knowledge or testing of the materials to preclude regulation. Please consider this 

option. 

If not, is heat used to melt or break material bonds so that the materials fall off 

of the parts/hooks/racks and are collected and disposed of through another means? 

Please feel free to provide any other information that you believe may be pertinent 

to the feasibility of emission testing. 

When EPA concludes consideration of this issue, we will consider extension requests 

for units that are required to perform testing. 

Thanks! 

Brian Shrager 

Environmental Engineer 

U.S. EPA Office of Air Quality Planning and Standards 

Sector Policies and Programs Division/Energy Strategies Group 

D243-01 

Research Triangle Park, NC 27711 

(919) 541-7689 

Fax: (919) 541-5450