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Gossman Consulting, Inc. May, 1994
Wednesday, April 20, 1994
This year's BIF conference was kicked off by Bob Holloway who brought attendees up to date on the implementation of Carol Browner's combustion strategy. Bob talked about EPA's public outreach attempts through the roundtables being held, the interim final waste minimization program resulting in 35,000 letters requesting companies to make their plans public, all BIF Part Bs have been called, a new public involvement regulation expected at mid-year, a science and risk assessment draft addendum sometime this summer, stepped up enforcement actions including "two very public announcements" and new emission standards. The bulk of his talk concentrated on risk assessments and technology based standards. A rough time line is a proposed rule by 9/95 and promulgation by 12/96.
Bob discussed how there would likely be a generic risk assessment check for national standards with the option of a site specific risk assessment, however a risk assessment would only be used to lower emission limits, not raise them. An encouraging issue was the proposal of a screening methodology which would allow a facility to option out of the more comprehensive risk assessment. Bob also discussed maximum achievable control technology (MACT) and best operating practices (BOP) and whether standards should be specific to Clean Air or joint to Clean Air and RCRA. In general, EPA is leaning towards a generic standard for all waste combustors. Omnibus authority was also discussed, concerning dioxins and particulate matter (PM). In the interim between the combustion strategy and any final rule, permit writers will explain EPA concerns and how permits should incorporate the interim target levels of 30 ng/dscm for dioxin and .015 gr/dscf for PM.
A document is soon to come out which Bob referred to as CETRED (pronounced see tred) which would be a dynamic document as it would be ever changing. This document will identify BOP for emission levels. Bob cautioned that in comparing BOP with MACT, the MACT process was not strictly followed as economic impact was not considered. CETRED might also provide technical support for reinstating Tier III standards. There is more than one level of MACT and the one Bob discussed the most involved identifying the best 12% of the combustion facilities in the U.S. (at least five facilities) for establishing PM standards. BOP for dioxins was discussed as "good combustion practices", which would include minimizing dioxin precursors and less than 350oF at the APCD inlet. The current suggested generic dioxin standard is a toxic equivalent standard (TEQ) of 0.2 ng and total congeners of 9 to 14 ng. Discussion continues on all of these issues. As Bob pointed out, if anyone in the audience had heard his speech a week ago, they would have recognized that it was different at this conference. He also expected it to be different again the next time he gives his presentation.
A panel discussion on hazardous waste incineration issues was chaired by Bill Mills of Woodward Clyde later that morning which included Mike Benoit of CKRC, Bob Holloway of EPA, George Baggett, a citizen's representative who "didn't like anybody very much", Tom Emond from the Association for Responsible Thermal Treatment (AFRTT) and Craig Doolittle from Dow who was representing the Chemical Manufacturers Association (CMA). Unfortunately, Kathryn Kelly (author of All Fired Up) was delayed in her travel plans and unable to participate as expected and no mention was made as to the fate of Sonya Sassville from the EPA Office of Solid Waste (OSW), who heads up their combustion R & D. Also invited, but not in attendance was Jim Turpin from the Waste Minimization and Combustion Coalition. The issue that popped up time and again had to do with risk assessment, but in the absence of Kathryn Kelly, the issue did not get sufficiently addressed. In general, this panel discussion was not particularly revealing with the notable exception of Craig Doolittle from Dow. In his presentation, he explained that Dow has just about every type of BIF imaginable, including halogen acid furnaces (HAFs) and it was his opinion that cement kilns and incinerators were equally capable of successfully burning hazardous waste. He urged them to put their differences aside as their intra-technology bickering was giving the industry a bad name. He also mentioned that a well known Greenpeace representative was getting quite a kick out of an AFRTT lambasting of cement kiln technology at the recent EPA San Francisco Roundtable session. (GCI would add that while incinerators and cement kilns may not be on the same side or same level of the combustion technology ship, both will certainly go down if the combustion ship sinks.)
The luncheon speaker for the first day of the conference was David Pershing, the University of Utah Dean of the College of Engineering. His topic was the utilization of waste materials in cement kilns. His group did work in a laboratory scale kiln and confirmed some of what those in the cement industry have known all along. (A version of this presentation is found in the April issue of Rock Products.)
The afternoon session was entitled Permitting and Regulatory Implementation Issues and was chaired by Beth Rice of Midwest Research Institute, a company instrumental in putting this years conference together. Bill Schofield started things off with a particularly pointed overview/summary of EPA's new policy for hazardous waste combustion. He also introduced the regulatory time perspective of BB & AB (similar to but not to be confused with BC & AD), representing regulatory logic before Browner and after Browner.
The next paper addressed regional variances in the interpretation and implementation of the BIF regulations and was presented by Jim Woodford. This paper made it quite clear that the only mechanism within EPA that compelled facility feedback was the enforcement action and that there appeared to be a problem with communication between enforcement and permitting within EPA. A number of examples were cited. It was also pointed out that facilities too often learn of multi-million dollar enforcement action against their facilities on the evening news, but yet when the actions are settled for less than 10% of the original recommendation, little or no announcement is offered.
Dave Constans of GCI gave an interesting comparison of regulations for burning waste in cement kilns in the United Kingdom as compared to the United States. In short, the permitting representatives in the U.K. were technically knowledgeable and willing to work with the cement plants. One such situation took a burning project from the discussion stage to test burn within six months. Ruksana Mirza gave an informative talk about the development of guidelines for the use of hazardous and non-hazardous wastes as supplementary fuels by the Canadian Council of Ministers of the Environment. The end result of the process was that DRE was not required due to the determination that a particulate matter standard was protective of health and environment.
Two timely papers were presented later that afternoon by Ray Yarmak on an example of a Clean Air Act Title V operating permit application for a hypothetical cement plant burning hazardous waste fuel and by Ed Brookman on the significance of fugitive emissions in the Title V operating permit program for the portland cement industry. The deadlines are creeping up and compliance is looking to be tremendously complex. Jeff Evers was on the agenda due to a last minute cancellation and presented a paper demonstrating that the newest environmental concern buzzword of "environmental racism" should not be a problem at cement plants burning hazardous waste, largely because these facilities are rural and do not have an abundance of low income minorities.
Thursday, April 21, 1994
The second day of the conference began with a session entitled Solid Waste Management and Operational Practices. Carrie Yonley and Myron Black were session co-chairs. Suzanne Riney started the day and the session off by presenting a general overview of the cement kiln dust report to Congress. This paper was followed by a lightweight aggregate kiln presentation by Gregg Franklin. Gregg good naturedly pointed out that he felt like a force of one at the cement kiln dominated conference. His presentation was interesting and well received, however, most notably he fended off the attempted questioning attacks by cement kiln technology nemesis Ed Kleppinger. A paper about burning tires and the environmental effects was not given as the co-authors were not present at the conference. After the resulting unscheduled break, a gentleman from Europe gave a very rapid but somewhat informative brief talk about a tire (tyre) burning experience in Europe. There was also an interesting paper presented on co-firing industrial waste in a circulating fluidized bed power boiler in Europe. The required testing on this unit was much less stringent than that required by BIF. One of the more interesting papers presented at the conference involved the Passamaquoddy technology recovery scrubber-process presented by Gerry Young. This is a technology which allows for the reclaim of wasted cement dust piles by reprocessing/recycling the wasted dust as raw materials for the cement manufacturing process.
The second half of the morning concerned inorganic emissions evaluation and control and was chaired by Doug Sweeney. Co-chair Dan Willis was apparently away in Europe. Papers presented in this session addressed a retrofit fabric filter collection of submicron particulates, reduction of NOx emissions from cement kiln/calciner through the use of urea injection and HCl emissions from cement kilns. Dennis Flagout talked about the HCl emissions and pointed out that there did not appear to be any compliance problems with HCl and questioned why there seemed to be so much continued attention to the issue. He prefaced his comments with suggesting that he might be beating a dead horse but still didn't understand all the attention. An EPA official later agreed that he was in fact beating a dead horse. (Nevertheless, GCI believes this issue may become problematic as MACT standards are established.)
Craig Campbell was the luncheon speaker and his topic was industry perspective on EPA's combustion strategy. It is probably safe to say that Craig's talk surprised a lot of the attendees. Some of the points were that industry credibility had been lost and would remain so until we choose to reclaim it. He seemed to fault those who would criticize the agency rather than work constructively to resolve the issues and the intra-technology bickering between cement kilns and incinerators was raised again. This bickering was portrayed as incinerator instigation and cement kiln defensive posturing. His one point about not doing enough to communicate pollution reduction efforts within the industry was later challenged by Kathryn Kelly (whom had managed to get out of Brazil and arrive at the conference). She felt that his comment implied that cement kilns were part of the problem rather than part of the solution. In her opinion, cement kilns have done and continue to do much to process hazardous waste in a safe and environmentally responsible manner and she was concerned that Craig was suggesting otherwise. If getting everyone's attention is the sign of a successful presentation, then Craig's talk was very successful.
Bob Schreiber chaired the afternoon session entitled dioxin/organic emissions evaluation and control. Rex Jameson presented a well received paper on the "not yet successful" hydrocarbon mid-kiln sampling at the Clarksville, Missouri Holnam facility. The whole mid-kiln sampling concept is quite an engineering marvel but unlike Elizabeth Taylor's seventh husband, who knew what he had to do but wasn't sure how to make it interesting, Rex claimed to be more like a teenager who was really interested but wasn't quite sure what to do. Work continues on the mid-kiln sampling program at Holnam. Brian McHenry then discussed dioxin testing performed at River Cement in Festus Missouri. His talk focused on the speciation work performed on the dioxins during the certification of compliance test and comparative work performed since the test. While work continues, this study presented some of the more detailed work currently being performed in the cement industry. No doubt more will be forthcoming from the industry as the dioxin issue heats up. The session chair, Bob Schreiber, then presented an industry overview of dioxin emissions largely based upon the Gossman Consulting, Inc. BIF report. No clear trends were indicated in the specific data presented. This paper was more or less tag-teamed with the next presentation by Craig Campbell. A lot of data was again presented with no clear indication of specific cause and effect relationships. Temperature did look like it was a pretty good candidate. More investigation will continue. Eric Hansen completed this particular session by talking about a study of the factors influencing dioxin/furan emission from Ash Grove's Chanute, Kansas cement facility. As usual, Eric razzled and dazzled the attendees with enough data to cover two presentations but managed to tie it all up into a neat little package demonstrating his conclusion of the relationship between dioxin/furans production and temperature.
The afternoon session was entitled testing and emissions measurement and was chaired by Helen Yoest of Entropy. Robert Schoenbarger presented metals data generated from several different analytical methods and concluded that different methods produce varying levels of metals concentration. Laura Kinner presented data generated from the use of FTIR and GC-MS as a continuous emissions monitoring system for a cement kiln. This was some truly interesting data and it will be interesting to see how this system develops. A method for the rapid semi-quantitative identification of hazardous organic constituents in liquid organic hazardous waste streams was presented by Dave Gossman. Gossman Consulting, Inc. personnel have had a hand in setting up over half the waste fuel facility labs in the United States and a version of this analytical method is in use at most of these facilities as well as some laboratories in the United Kingdom. Steve Schliesser then presented information concerning preliminary validation test results of 3M's semi-continuous metals emission and monitoring method. The final paper of the day was presented by Glenn Sprenger of B3 Systems, Inc. This paper covered compliance issues that are currently being performed.
Friday, April 22, 1994
The final half day of the conference covered a session entitled testing and emissions measurement and was chaired by Greg Holton of Industrial Complex, Inc.. Larry Holcomb began the day by discussing reproductive and development health risk from dioxin-like compounds: insignificant risk from cement kilns burning waste-derived fuels. Larry basically reported that there is no evidence to suggest that dioxins, at environmental levels or associated with emission of waste fuel burning cement kilns, have caused adverse effects in either wildlife or humans. In many cases, cited studies involved doses that were 100 to 1000 times higher than the normal background environmental doses. Gary Elliot presented information about a multi-pathway risk assessment for the National/Systech facility in California. Even though the facility had been granted a negative declaration concerning potential environmental impact twice before, the State finally decided that the political climate was not going to allow that again, resulting in the assessment. When all was said and done, it cost at least $450,000 for the study and they ultimately confirmed that in fact they should have had a negative declaration again. The next paper, an indirect pathway assessment paper was not presented as scheduled. Kathryn Kelly gave the next presentation. She modified her original presentation concerning indirect assessment and the incinerator permitting process due to the fact that the process has not been finalized. She did talk briefly about the current version of the risk assessment model and made the point that technology based standards are going to be a never ending battle of continually improving technology which is entirely unnecessary since we are already safe enough. Instead, she talked about the life cycle analysis process. She cited such examples as McDonalds considering styrofoam vs. paper for hamburger containers. In this case, she compared making cement using only coal as the fuel with making cement using only hazardous waste as fuel. Her study found that it was actually "safer" to make cement with hazardous waste fuel than with coal. It is of interest to note here however, that McDonalds actually found styrofoam to have the life cycle analysis advantage but went with public sentiment and chose paper anyway. The last paper before break critiqued the addendum to the methodology for assessing health risks associated with indirect exposure to combustor emissions. It was detailed enough that it is quite difficult to make any type of summary comments. It is interesting to note that EPA is ignoring its own research concerning vapor deposition on surrounding plants conservatively by one to two orders of magnitude.
After the break, Edmund Crusch discussed probabilistic risk assessment of combustor stack emissions. His model took into account what seemed to be every conceivable possible risk, but what it allowed him to do was more realistically estimate risk compared to the general defaults which greatly overestimate the risk potential. He also talked about how data can be manipulated by perfectly legitimate means to provide answers that appear quite different. Next, Bruce Pedersen presented a paper on the evaluation of chemical exposures in the hazardous waste industry. Systech was in the forefront of employee monitoring back in the early eighties and continues to stay on top of employee safety. The collected data has always indicated that employee exposure at hazardous waste facilities is lower than everyday activities such as a beauty salon or painting company. It was good to see this type of data finally get published. Bruce's paper was followed by John Stanley talking about human exposure to chemicals and the assessment of exposure and health risks. John presented quite a bit of EPA sponsored study data concerning exposure. One particularly interesting slide/overhead covered lipid levels of dioxins in white males since the early seventies. The graph demonstrated an unmistakable significant decline in those levels. He made a point to wonder out loud whether or not people were getting scared to death by unfounded media rhetoric when comparative data such as the lipid levels of dioxins in white males over the past 15 to 20 years indicate that exposures are obviously greatly improving. The last paper of the day and the conference as well was presented by Tom Murphy concerning medical surveillance and programs on industrial hygiene at RCRA facilities. Tom outlined many of the concerns associated with performing medical surveillance and the differences between other similar types of programs. As an industrial hygienist associated with a cement company burning hazardous waste, Tom is in an excellent position to bring things into perspective.
Numerous risk assessment presentations during this conference pointed out that Carol Browner's current obsession with dioxins and piling on ever more stringent requirements on top of BIF are not supported by the prevailing science. While technology based standards may be something the industry can currently hang their hats on, it will be an ever moving target and are unwarranted since cement kilns have already demonstrated operations that are protective of human health and the environment.
Industry needs to remain ever vigilant and integrally involved in any and all rule making activities. Political pressures need to be stepped up. The prevailing science will not be sufficient to carry the day. Certain instigating incinerator factions need to wake up and smell the coffee. Their public rhetoric campaigns are highly devisive to the thermal treatment industry and will backfire on them in the long run. Rumor has it that the AFRTT group came into being because there were HWTC members that refused to be a party to such tactics as the public has witnessed over the past several months. Hopefully, these companies will quickly come to their senses and realize that the torpedo holes they are inflicting on the cement manufacturing industry are simply on the opposite side of the same ship and we are all in danger of sinking.
An EPA official at the conference questioned the constructiveness of hammering on the lack of communication between permitting and enforcement within EPA or pointing out that the only mechanism compelling EPA feedback on regulatory compliance submittals is the enforcement action. It is important and constructive if for no other reason than the affect such actions have on the credibility of both the EPA and industry. EPA damages industry credibility by proposing outrageous fines and then in turn damages their own credibility by in effect admitting their fines were outrageous when they settle for less than 10% of the original proposed fine.