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Gossman Consulting, Inc.

GCI TECH NOTES©


Volume 1, Number 05                     A Gossman Consulting, Inc. Publication                                  May, 1995

1995 AWMA BIF CONFERENCE SUMMARY

Jim Woodford

The annual AWMA BIF conference has come and gone once again. The conference had a bit more of an international flavor this year thanks in part to the United Kingdom Blue Circle's Tom Lowe, who served as a session moderator and challenged presenters with incisive questions throughout the conference, and Bert Schipholt of ERAtech Environmental, Ltd. who was gracious enough to agree to be a luncheon speaker. Conspicuously and unfortunately absent this year was light weight aggregate kiln representation (Solite) or Dick Carnes of Four Nines presenting any Solite test data. Also conspicuously absent was Bob Holloway & Shiva Garg or any other USEPA Headquarters representation. AWMA did make an effort to include Bob Holloway and/or group head, Fred Shannania but they begged off citing work load and budgetary constraints. Region VII was well represented throughout the conference by John Smith, who served on the Technical Program Committee and served as a session chair. The conference once again provided ample opportunity for interaction between parties with similar or identical concerns and provided what appeared to be meaningful dialogue between industry and EPA representatives (Region VII).

Tuesday March 28, 1995

The 1995 AWMA BIF Conference was kicked off on Tuesday (March 28) morning with a keynote address from Dennis Grams, Regional Administrator for Region VII. Dennis talked about all the changes underway at EPA and how he thought this was a great time to be with EPA because of the possibility of seeing things changed the way they should be. Dennis talked about proposed rules which would impose stricter emission controls on dioxins/furans and metals; facility prioritizing which would emphasize permits; continuous emission monitors; a rule enhancing public involvement; and performing risk assessments on every facility permit which he referred to as "an extremely effective tool" in allaying public fears. Attendees learned that boilers are being excluded from additional regulatory attention at this time so that more time can be spent on the remaining thermal treatment industry. He also talked about enforcement, which he said "shouldn't be what drives us [EPA], it should be a tool." He stressed that EPA should emphasize compliance. One question from the audience concerned EPA Administrator Browner's obvious anti-combustion strategy and what it meant to the assembled BIF audience at the conference. Dennis Grams responded that if you could prove to Ms. Browner that incineration was the answer then she was willing to go with incineration. Another question from the audience concerned communication with the public citing the dioxin reassessment as an example. Grams sympathized with the question as Region VII was promoting incineration of Times Beach contaminated dirt when the dioxin reassessment was released. It was difficult to explain to the public. To enhance his theme of change within EPA, he did encourage interested parties to complete and return forms, which he provided, that would suggest improvements to existing regulations.

The first session of the conference was a panel discussion which was entitled, "New or Emerging Regulatory Policies." The panel discussion was preceded by a multi-participant presentation by Liz Mikols of Lehigh Portland Cement, Craig Campbell of CKRC and Ann Dougherty of the Portland Cement Association. Their joint presentation was on "A Cooperative Research and Testing Program on Hazardous Air Pollutants from Portland Cement Manufacturing Plants." Liz emphasized that the program was designed to provide data to EPA which would help them develop regulations right the first time. However, lest EPA begin to think that the industry was coming over to their side, she quickly pointed out that if EPA doesn't get it right, that "We'll [the cement industry] sue in a heart beat!" Specifically, she talked about metals, HCl, organics and PCDD/PCDFs. She didn't have much good to say about EPA's idea of activated carbon injection and pointed out that probably all of the HCl data that had been collected so far was wrong. Ann Dougherty of PCA talked about emission data review, formation mechanisms, stack test protocol validation, emissions testing during normal operations and control/cost critiques, especially as compared to EPA estimates. One example she gave was that the gas flows used by EPA were completely inappropriate. Craig Campbell of CKRC discussed the MACT pool facilities and how EPA was trying to put incinerators, cement kilns, LWA kilns and boilers all into one pool and then inappropriately impose the most stringent emissions technology on all types of combustors.

These presentations were followed by a panel discussion which included Jeff Denet, formerly with EPA and now representing the Waste Minimization & Combustion Industry, Melvin Keener of the Coalition for Responsible Waste Incineration and Kathryn Kelly of Environmental Toxicology International. The discussion was co-chaired by Dave Gossman of Gossman Consulting, Inc. and Bill Mills, an independent consultant. Bill pointed out that at first an AFRTT representative requested to be included in the panel but backed out at the last minute. Jeff Denet stressed bringing all of the combustion factions together and Melvin Keener talked about regulatory reform. A question from the audience concerned why the cement industry was so concerned about HCl instead of Cl2? Liz Mikols fielded this question and suggested that the EPA should be asked that same question. Bill Mills added to the response by stating that at the latest interaction with the Science Advisory Board, Bob Holloway and Fred Shanania were surprised to learn that combustion experts felt that HCl was orders of magnitude less important than Cl2. Kathryn Kelly & Craig Campbell later pointed out that at the latest ASME meeting, an EPA contractor was recommending that continuous emission monitors use a nine (9) hour average. Kathryn pointed out to the contractor that no such device existed and following a big debate on the whole issue, it all boiled down to public perception. Jeff Denet pointed out that cement kilns have good particulate control and metals emissions. It seemed to boil down once again to the all critical communication issue.

The luncheon speaker was Bert Schipholt of ERAtech Environmental, Ltd. from the U.K. His company's efforts are international in scope and his attendance at the conference marked the near completion of a worldwide industrial tour. Thirty years with DuPont set the stage for his current involvement/emphasis on cement kilns to manage waste around the world. His talk was entitled, "Chemical Waste Incineration and Cement Kilns Meeting Public Expectations." He relayed the story of his recent motel stay in San Francisco when a gasoline truck overturned on an exit ramp and exploded in an intense fireball. There was no public outcry. People have learned to live with gasoline and the occasional sensational accident. Had that had been a truck load of waste solvents then the public outcry would likely have been deafening. He charged the thermal treatment industry with the challenge of maintaining a perfect safety record. He also spoke of communication as a key to public understanding. And last but not least, he called for the joining together of the thermal treatment factions towards one common goal. He pointed out that divisiveness between thermal treatment types, which they are beginning to experience in the U.K. [and currently perpetuated by a small group of incinerators in the U.S.] is confusing the public at large and can only serve to damage the credibility of all thermal treatment.

The afternoon session was entitled, "Permitting and Regulatory Implementation Issues." The first speaker was Bill Schofield of DRE Environmental Services who spoke on "Designing Trial Burns to Provide PIC and BIF Metals Emissions Data for Comprehensive Risk Assessments." The focus of his presentation was the EPA June 2, 1994 draft guidance on Trial Burns. The criticisms were not unlike a similar critique by David Constans of Gossman Consulting, Inc. in a June 1994 HWF Notes. Bill's analysis of the guidance can be boiled down to his comment that he thought the guidance indicated that EPA had sat down with Greenpeace representatives and incorporated everything they wanted no matter how far fetched or conflicting in nature. A Region VII representative later responded to this accusation by pointing out EPA did not have to counsel Greenpeace but was fully capable of putting such a document together themselves. Bill responded with, "I'm sure that's true." Bill's overriding theme in his presentation was that EPA continually referred to certain required aspects within the Trial Burn guidance as "representative" when it was obviously worst case.

The second presentation in this session was by Lenny Rosencrans of Continental Cement. His talk was, "Same-Day Analysis of Cement Kiln Dust for Hazardous Constituents." His presentation left very little room for any other CKD analytical regimen to lay claim to the title of "most sophisticated laboratory in the BIF business." The next presentation was on "The Added Risk to Health, Safety and the Environment Due to the BIF Regulations", which was given by Dave Constans of Gossman Consulting, Inc. Dave stressed the risks to health and safety, brought on by the BIF rules, due to the necessary toxic metals spiking. His numerical representations of 7.1 miles of 2" schedule 40 pipe (316SS), which could have been made from all the chromium spiked in 1992, and 24 million LD50 doses from all the beryllium spiked gave participants a more practical understanding of the BIF metals spiking require-ments. Dave's comment, "That ought to kill a lot of rats." following his revelation of 24 million LD50 doses from all the beryllium spiked in 1992 was oft repeated throughout subsequent conference presentations.

The final presentation before the break was rather interesting. Ginny Moore, Region VII attorney and Terry Satterlee, attorney for Lathrop & Norquist gave a joint presentation. Although normally on opposite sides of the negotiation table, obvious by their respective points of views in their joint presentation, they teamed up to examine "The Attorney's Role in Permitting, Compliance, and Enforcement." Following their presentation, numerous conference attendees praised Ms. Moore as one of the better Region VII attorneys to work with. With that praise in mind and with all due respect to Ms. Moore, since she can only work with what EPA provides, the crowd seemed perplexed by her reference to an "Interim Proposed Policy Statement" concerning self-auditing. This was in response to an audience question concerning internal auditing amnesty. Ms. Moore stated that "If and when issued, the policy is discretionary on a case-by-case basis." One of the more interesting items to come out of the joint presentation involved EPA compliance audits, the process that compliance audits sets into motion and the resulting enforcement actions. This writer waited patiently in line during the break to get clarification on this issue. When asked to clarify the statement that the left hand of EPA can find you in compliance and the right hand can sue you anyway, Ms. Moore responded, "That is correct."

Following the break, Suzanne Riney of Schreiber, Grana & Yonley presented a review of the Development of an Appropriate Sampling Strategy for BIF Compliance. Tom Johns of Lafarge Corporation and a Lafarge consultant then presented the Alpena experience for the Management of Cement Kiln Dust. A CKD management process was developed that reportedly provided low leachability of metals, resulted in low permeability and good compaction; all of which results in minimal effects to the environment. Charles Nichols of Ash Grove Cement followed with a rather unusual presentation on the "Thumper", "An Aid to CKD Management." A 1991 PCA study had revealed that CKD compaction resulted in a 50% volume reduction. Investigation of the PCA compaction techniques indicated that use of these techniques would be prohibitively expensive. Ultimately, getting hooked up with a South African company that routinely used compaction equipment lead to the cost manageable "Thumper" project.

Wednesday, March 29, 1995

Wednesday morning started off with a session entitled, "Non-Hazardous Fuels and Alternate Material Substitution." Nick Stiren of Holnam related the experience of Holnam's Seattle facility with respect to burning tires as substitute fuel. That project was encouraged and largely funded by the State of Washington. He stressed that tire chips need to be clean & uniform in size, locating the feed pipe at twelve o'clock to boost velocity and insure a more complete burn, and to install a line plug alarm. Burning tires reduced the length of their burn zone but made the clinker easier to grind. In addition, stack testing demonstrated a corresponding decrease in SO2. Charles Coles of St. Lawrence Cement then talked about a very involved approval process to burn refuse derived fuel at their Mississauga facility. Response to a question from the audience revealed that the detailed process had actually taken five years to complete. At any rate, stack testing demonstrated that emissions were less than 10% of regulatory limits in all cases and less than 1% in most cases and, yes, there is odor associated with processing garbage but that is manageable. Dave Watson from Blue Circle discussed the approval process and "The Use of Non-Hazardous By-Products in the Production of Portland Cement Clinker." The approval process involved review of MSDS sheets and chemistry considerations. Ultimately, all samples are sent to the Blue Circle laboratory in England for final approval. Stephen Enger of CH2M Hill finished the session by talking about "Non-hazardous Alternate Materials for Kiln Burning."

The next session got underway in the late morning. Suki Sidhu of Barry Dellinger's group at the University of Dayton (source of the widely used organic compound Incinerability Ranking) gave a presentation on "Organic Emissions from Cement Kiln Raw Meal." The presentation was interesting. Unfortunately, it was less significant than it could have been previous to the remanding of Tier III, and finally provides some definitive scientific support for organics in cement manufacturing raw material. Jacques Denizeau, of Lafarge, presented data concerning APCD temperatures and PCDD/PCDFs at the Lafarge Fredonia, Kansas facility, which was also the site of the facility tour conducted before the BIF conference got underway. Jacques talked about a water spray, which although a problem operationally, reduced the APCD inlet temperature and reduced PCDD/PCDFs. He concluded that surface catalyzed reactions between partially chlorinated hydrocarbons was the predominant source of PCDD/PCDFs in the Fredonia kiln and recommended that with a wet process kiln, such as the Fredonia kiln, that APCD inlet temperatures should be maintained below 380oF.

The luncheon speaker was George Harlow from Marine Shale. His topic was "How the Marine Shale Case Affects BIFs." Most attendees would agree that George was one of the most entertaining luncheon speakers in the history of the BIF conference. George's background, before working for Marine Shale, was over 30 years with the USEPA. He offered some interesting perspective on how the EPA went from an early position of being highly and openly supportive of hazardous waste use in BIFs to one of actually creating the hazardous waste incineration business and now favoring hazardous waste incineration to the near exclusion of other thermal treatment. His great sense of humor highlighted this presentation perfectly. All in all, George presented an informative and very enjoyable talk.

The session which followed the luncheon was a continuation of Session 4 on "Organics/Inorganic Emissions Evaluation and Control." Bob Schreiber of Schreiber, Grana & Yonley talked about dioxin emissions and cement kiln operations at the Continental Cement, Hannibal Missouri facility. PCDD/PCDF concentration in the wasted dust tended to track stack emission PCDD/PCDF concentrations. Sodium was injected in an attempt to control PCDD/PCDFs, and dioxins did seem to decrease but sodium carbonate injection was cost prohibitive. Use of activated carbon increased dioxins in the wasted dust. The data indicated that significant amounts of dioxins came into the kiln with the slurry and that concentrations were highly variable ( 0.08 ppt to 0.16 ppt TEQ). The next paper was presented by Floyd Pfeffer of DRE Environmental Services and addressed "Best Available Control Technologies (BACT)." The state of Texas imposed incinerator BACT on TXI Cement. The four general parameters investigated were PM, HCl, dioxins/furans and the BIF metals. While TXI argued that incinerator BACT was inappropriate for a cement kiln, TXI reportedly met incinerator BACT for all parameters except HCl. The final paper before the break was presented by Glenn Brinckman of W.L. Gore & Associates entitled, "Strategies in Controlling PM, Heavy Metals, Dioxins and Furans, and Mercury Using Fabric Filters". This paper presented all the technical information on fabric filters that you would ever want to know.

Session 5 entitled, "Testing and Emissions Measurement", united at the podium the former Systech/General Portland (Lafarge) team of Gossman, Cape and Woodford. David Gossman of Gossman Consulting, Inc., fresh from an exhaustive research on U.S. Thermal Treatment facility WAPs, presented "A Review of the Usefulness of Various ASTM and SW-846 Methods." His presentation was particularly informative for what Lenny Rosencrans of Continental Cement had earlier referred to as "lab rats". Jim Woodford, of Gossman Consulting, Inc., followed with a presentation entitled "The Effects of Process Differences on System Removal Efficiencies (SREs) and the Fate of Metals in Cement Kilns." This study was jointly performed with Holnam's Holly Hill South Carolina facility and incorporated data from 33 kilns that performed 1992 COC testing. Parameters examined and compared to metals SREs were chlorine input, Cl2 emissions, kiln exit temperature, particulate emissions and HCl emissions. No correlation was found to exist between SREs and any of the five parameters. Although hindsight in nature, the results of this study seriously question the relevance of using these parameters as BIF controls. The paper also concluded that the consistency of the cement kiln manufacturing system coupled with the extensive 1992 COC test data precludes the need for repeating metals testing for Recertification of Compliance tests in 1995 and 1996. The data in lieu of trial burn provisions of BIF are more than sufficient to address that issue. Craig Capewas the guest presenter on a paper entitled Continental Cement Trial Burn Strategy. Craig presented the regulatory justification for using data in lieu of a trial burn and the justification for proposing a two phase trial burn at Continental Cement. Woodford and Cape independently hammered pretty hard on the use of data in lieu of a trial burn. Following the presentations, a Region VII representative was heard to remark, "At least now I know that data in lieu of is legal." Pat Arnold, of Lafarge Corporation, and a Lafarge consultant ended the session and the day with a comparison between wet and dry continuous emission monitors at the Lafarge Fredonia, Kansas facility.

Thursday, March 30, 1995

The final half day of the conference dealt with "Risk Assessment and Communication." The session was appropriately chaired by Kathryn Kelly of Environmental Toxicology International, Inc. (ETI), author of the publication All Fired Up and cement industry risk assessment guru. The first presentation was by Suellen Pirages of Risk Communication International, who talked about all of the different types of "official" risk assessment guidance currently available. There are four different EPA risk assessment guidance documents, three of which came from the same office within EPA and not one of the documents agrees with any of the other documents. She pointed out that risk assessment is totally dependent upon chosen assumptions and then the risk assessment value only indicates a probability, not a certainty. It was also of interest to note that the current Science Advisory Board recommenda-ions for dioxin risk assessment toxicities is 16 fold less potent that what EPA has chosen to use. The next presentation was by Bob Schreiber and addressed "Food Chain Pathway Analysis for CKD at Continental Cement, Hannibal, Missouri." The study at Continental investigated actual dioxin levels around the cement plant (e.g. the MEI location) and compared those to what EPA predicted. Needless to say, the actual levels were several orders of magnitude less than what EPA predicted.

The final three papers of the morning and the conference were presented by ETI representatives. The first was by Angele Liegeois who talked about "Alternate Approaches to Multi-pathway Risk Assessment." She focused on the importance of wet deposition, land use and particle size/density to indirect risk assessments. The next presentation was by Benjing Sun who spoke about "Results of Recent Multi-pathway Risk Assess-ments for Hazardous Waste Combustion Facilities." He has developed a computer model which he touted as fast, user-friendly, integrated, modular, statistical-driver linked, and easily modified. Some attendees informed this writer that Benjing's computer runs were indeed incredibly fast. The final paper of the conference was by Gary Pascoe who talked about "Use of Multimedia Environmental Monitoring to Enhance the Accuracy of Risk Assessment for Cement Plants Burning Hazardous Waste." He compared modeled concentrations against measured concentrations. For example, the modeled concentration factor for mercury was 16.2 while the factor based upon measured concentrations was 0.038. This resulted in a modeled bio-accumulation factor of 130,000 L/kg as compared to a measured bio-accumulation factor of 69 L/kg, quite a difference.

The conference proceedings will have complete transcripts for all papers presented at the conference. If it is handled as in other years, proceedings will be available within the next two to six months. Papers are also available from the authors that presented them. Hopefully, the rumored soon-to-be-released BIF Two will not monkey up the works for the Recertification of Compliance (ROC) test plans and/or Trial Burns planned for the 1995/1996 BIF compliance season. May all of your compliance efforts be successful and as painless as possible.

As I sat in my speaker's breakfast meeting bright and early before the start of that particular conference day, I became mesmerized by speaker instructions so thoroughly and completely conveyed by Adrianne Carolla of A&WMA. It occurred to me as I sat there and listened that there is so much to do to organize a conference, and so much that can go awry once it has started. Congratulations to all that helped make this conference happen; but especially to Doug Sweeney of Ash Grove.