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Gossman Consulting, Inc

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Volume 4, Number 05                  A Gossman Consulting, Inc. Publication                    May, 1998

1998 A&WMA BIF Conference

Jim Woodford

Another BIF conference has come and gone. This year was fairly sedate in that no earth shattering regulations were looming on the horizon, and most cement kiln BIFs are well into their RCRA trial burn and final permit activities. Thanks this year in particular to Paul Peters of Lafarge Corporation in Fredonia, Kansas for being the Technical Program Chair (and special thanks to Horace Compton, plant manager at the Fredonia facility, for loaning Paul's services), plus Sue Honnegger of Lathrop & Gage and Fred Chanania of USEPA for being general conference co-chairs.

Following opening remarks, Fred Chanania and Bob Schreiber co-chaired the first session which included a panel discussion. Each panel member gave a brief (or not so brief) presentation followed by general question and answer time with attendees. Panel members included David Case of the Environmental Treatment Council, Art Spratlin, USEPA Region VII, Dave Hockey, USEPA Washington and Mike Benoit of the Cement Kiln Recycling Coalition.

David Case spoke first and gave an incinerator "rose colored glasses" rehashing of the historical issues associated with the currently proposed Hazardous Waste Combustor (HWC) rule. He reiterated the "level playing field" mantra of the incinerator industry by putting forth a claim of "equally protective defense of hazardous waste combustion" by both cement kilns and hazardous waste incinerators. He touched on Vice President Al Gore and WTI in East Liverpool, Ohio, CETRED, MACT pools and continuous emission monitors. He ended his presentation with a fairly timely analogy, the Titanic versus the Mars Sojourner. Are we arguing over a card game while the combustion ship is heading towards an iceberg?

Next presenter was Art Spratlin. He talked about the Regional role in regulatory compliance which he generally saw as diminishing as the state role increased. He particularly wanted to get Title V down to the state level. He also touted that fact (and well he should) that Region VII is the only region to have issued a BIF permit and he thought it was a good permit because everyone had a say in it.

Next presenter was Dave Hockey from the Office of Solid Waste (OSW). He gave a general overview of the status of the HWC. He expected an extensive OMB review and then Federal Register publication some time in December, 1998.

Mike Benoit, representing CKRC, spoke next. He talked of the criticisms of the EPA MACT database and emphasized how cement kilns were different from incinerators, despite Dave Case's "one big happy family" tone to his presentation. Mike applauded the improvements to the database and EPA efforts to do so. He voiced support for NSPS as MACT floor for PM, PM as a surrogate for metals and temperature control for D/F MACT floor. He opposed beyond the floor limitation efforts and MTEC/feed rate controls as MACT. He also came out in favor of a raw material variance. He also criticized how "somebody" ignored the science and decided that some of the MACT standards were too high (i.e. Pb) and that some of the old combustion strategy was still part of the MACT. He emphasized that science should drive the process not politics.

Before some of the highlights of the panel discussion are noted here it is of interest to point out that both Art Spratlin & Dave Hockey briefly mentioned raw material contribution in cement manufacturing. In fact it was one of the first questions from the conference attendees. Mike Benoit responded that CKRC has tried to keep that issue alive and Dave Hockey again stated that USEPA/OSW is fully aware of the raw material versus hazardous waste issue. Another question asked of Dave Case, referring back to his "we are one big happy family" presentation concerned the ETC web site. Some information on the web site is incorrect, plus they beat cement kilns over the head with an opposition interpretation of lead emissions. Dave Case was quick to respond about quibbling over web site content and then he followed up with a sports analogy. He is a wrestling coach and while two teams go out there and bang heads on the mat, that doesn't mean that they can't separate as friends. This editor would just add that this analogy only works when one of the competitors is not always out there bad mouthing the other competitor to whomever will listen. One of the more interesting questions of this session concerned the regional role in state settlements. Art Spratlin made it very clear that if USEPA did not agree with what the state had decided then the region would step in and make it right. This response sounded as if maybe Region VII wasn't so anxious for the state to take over responsibility after all.

Following the break, it was time for the second half of Session 1. Greg Rigo gave a presentation entitled Precision for Method 23 Sampling and Analysis. Greg's presentation was a variation on a theme that he has been pushing with a number of organizations as well as the EPA. There is a very real problem that EPA may be setting regulatory limits below precision capabilities of required analytical methodologies. Studies indicate that method 23 has high level imprecision which results in overall plant uncertainty.

The last presenter before the lunch break was Steve Schliesser of EER, with a talk entitled Evaluation of Particulate Matter Continuous Emission Monitors for Compliance Monitoring at Hazardous Waste Combustion Facilities.

The luncheon speaker was Brent Ahsmuhs of 3rd Millennium Consulting who started off by telling everyone that he did not want to be an alarmist as he talked about the Y2T (year 2000) problem and then proceeded to show alarmist overhead after alarmist overhead in his call to arms to fix the problem. Apparently we're all going to die.

The afternoon kicked off with Session 2, chaired by Craig Campbell (now of Lafarge Corp., formerly with CKRC) and Paul Peters of Lafarge. Norris Johnson, one of the most entertaining industrial/technical speakers that I have ever heard, kept us all awake following lunch. His talk was entitled Remnants of BIF in MACT. As usual, he also had some excellent technical points as well. For instance, looking at data for setting a minimum baghouse differential pressure can demonstrate the impracticality of such a requirement. If you take data points from three different days and the differential pressure gets set from the highest day, then what would happen to you when you were operating on the lowest of the three days. Obviously you are in violation. Coinciding data demonstrates that the kiln is functioning properly so you would end up out of compliance due to an unnecessary and arbitrary limit. Norris pointed out that differential pressure has little to do with proper bag house functioning anyway.

Norris also talked about burn zone temperature management under HWC/ MACT. It doesn't look like there is going to be any maximum temperature under MACT although the minimum temperature limit is still there. Norris pointed out that minimum temperature is a misnomer anyway. Cement kilns strive for steady temperature because that is the way the kiln operates best. He also pointed out that any minimum temperature in a cement kiln is hot enough to handle organics, consequently is too hot to measure and too hard to measure anyway. In other words, it is an unnecessary limit that is impractical to measure from a technology standpoint. He ended his talk with one of his entertaining and funny stories which is paraphrased as follows: A fella from back East had been driving around in the country for hours when he finally stopped to ask a good ole' boy for directions. As the good ole' boy leaned against the fence he provided some pretty detailed directions. About an hour later, the fella from the East came driving by the good ole' boy again. Again he stopped. "I followed your directions exactly and now here I am back again." The good ole' boy looked at him and said, "I wasn't about to waste my time giving you complicated directions until I was sure that you could follow simple directions."

Luther Gibson of Lockheed Martin Energy Systems spoke next about Evaluation of Candidate Monitoring Technologies for Multi-Metal Emissions from a U.S. DOE Mixed Waste Incinerator. This study examined three types of metals CEMs; Hazardous Element Sampling Train (HEST), Thermal Jarrell Ash ICP, and Laser Induced Breakdown Spectrometer (LIBS). The HEST system was only good for 9 of 15 target metals, the TJA ICP was only good for 8 of 15 and the LIBS was only good for 6 of 15 target metals. Definite progress is being made, but metals CEMs are not ready for prime time. It was generally thought that the Thermal Jarrell Ash unit at WTI in East Liverpool, Ohio was not yet fully functional either.

The next presenter was David Day of Auburn Environmental who talked about Advanced Tribioelectric Systems for Particulate Monitoring in BIF Applications. This paper discussed a particulate monitoring system that is described as having a high sensitivity for early warning of particulate emission problems. The paper described the unit in comparison with optical and beta gauge technologies. PM is detected when it contacts a probe and causes a change in a baseline current. It was described as being cost effective and cheaper than even optical systems. It was further described as having EPA approval for use in bag breakthrough detection applications.

Following the 3:00 p.m. break, the conference split up into concurrent sessions. Concurrent sessions make you choose between two presentations that in many cases are of equal interest. Concurrent sessions may be the only way to go at a huge conference like the annual A&WMA meeting but, in this author's opinion, they have no place at the small specialty conferences. I didn't find anyone last year who liked them, the first year that concurrent sessions were used, and certainly hope that we never see them again at any future BIF conference.

Session 2 continued following the break with a presentation by Brian Hotchkiss concerning development of data acquisition and reporting systems. He talked about the vast amounts of data that need to be managed and how a system might be set up to do just that. The next talk was by Robert Barton of Midwest Research Institute who gave a presentation entitled, Prediction of Emissions from Liquid Combustion Systems. His presentation centered around optical monitoring of a burner flame. It did not seem particularly applicable to cement kiln BIFs. Session 2 adjourned at 4:30.

Session 3 started with Alternative Cement Kiln Dust (CKD) Management Options Under New CKD Management Standards given by Katherine Martin of RMT, Inc. The presentation described results of experimental work in handling and treating CKD by the addition of water. These experimental procedures are in response to expected new regulations that would require additional controls on CKD. The procedures involved assessing such things as the influence of using different moisture levels, the influence of temperature of the CKD when adding water, and the hydrolytic conductivity of the resulting material. The conductivity was an important factor if the resulting material could be reused as a landfill liner. Results of the work conclude that a number of CKD handling and disposal characteristics show improvements when mixed properly. A question on differences seen when waste derived fuel CKD was used was answered by describing that no differences were observed.

The next presentation was entitled Leaching Potential of CKD When Subjected to Standardized Leaching Procedures and to a Proposed Conditioned CKD Leaching Procedure (CCLP). Andy Wentzl of RMT, Inc. gave this next presentation of session 3 which examined CKD testing by TCLP methods and by a new proposed method. In the presentation, he described why current TCLP does not model real conditions for CKD. The presentation characterized the particular significance of the fact that CKD reacts to moisture by further solidifying which reduces the available surface area. He described the CCLP as simulating more closely actual environmental conditions by the use of rainwater or site specific water for the extraction steps. Also, by extracting the CKD as a block rather than as a finely divided dust.

The final presentation of Session 3 was given by Robert Schreiber of Schreiber, Yonley and Associates. In this presentation, some comparisons were drawn between the Clean Water Act (CWA) procedures for allowing reuse of sewage sludge and an approach that could be used for determining acceptable reuse of CKD. A few examples of CKD reuse applications were described such as a liming agent, which is similar to a sewage sludge application. The conclusion was that with proper handling and monitoring, procedures similar to the CWA could be used to provide for sound alternative and beneficial uses of CKD. In answering a question at the end of the presentation, even advantages of CKD over agricultural lime were described.

Thursday 4-16-98

The concurrent sessions began again first thing Thursday morning. Session 4 was chaired by Beth Antley of Region IV USEPA and Tom Johns of Rhodia, Inc. (formerly Rhone Poulenc).

Beth Antley herself kicked off Session 4 with a talk entitled Comments on the USEPA Trial Burn Guidance Document. She also referenced some Region VI guidance on ecological risk assessments. She began by talking about groups that had submitted comments on the guidance document. Some readers may be aware that Val dela Fuente gave a preliminary presentation last year and announced that the guidance was expected to be available by May 2, 1997. This did not occur. Copies could be obtained from EPA but it was never formally released in the Federal Register as had originally been announced. Instead, EPA took comments over a period of a few months and have been "tweaking" the document ever since. Her talk focused on an even earlier guidance, the June 1994 draft. Those that provided comments included ETC; trade groups such as CMA/ETC/CRWI/CKRC; and additional comments from CMA, CRWI & Gossman Consulting, Inc. It is anticipated that the updated version will be available in a May 1998 time frame. One of the questions asked was about metal surrogates and/or extrapolation. Beth explained that this had not been resolved in the updated trial burn guidance. It was also asked if the updated TBG was going to be compatible with guidance released out of Region VI. Her response was that it should be since it was done by the "same people."

The next presentation was by Dave Constans of Gossman Consulting, Inc. and was entitled BIF Testing - Is There Anything else to Learn? The short answer was, "no". The required format of COC and ROC tests and their expense precludes using the tests to acquire new information. Metals spiking is still required although there is sufficient data from kilns to calculate the emissions rates based on input. The cement COC and ROC testing requirements go well beyond that which is needed to demonstrate continued facility performance, indeed they are in some respects more stringent than trial burn requirements.

Bob Schreiber then talked about Defining Upset Conditions and Malfunctions of Cement Kilns Burning Hazardous Waste and Their Impacts on Emissions. Bob defined an upset as a deviation from the Set Point while a malfunction is when equipment does not work as it should. He then talked about how upset conditions in an incinerator can lead to immediate emission problems whereas upset conditions in a cement kiln can still lead to successful manufacturing of the cement clinker product and destruction of all organics. And even in the case of an APCD failure, resulting in an increase of PM & metals, the increased emissions still are not likely to exceed any health limits.

The final presentation before the break was presented by Mike Milaszewski of Rhodia and was entitled Case Study, Comparison of Trial Burn Results from Similar Sulfuric Acid Regeneration Plants. The comparison was made between two Rhodia (Rhone Poulenc) facilities with slightly different permit limitations (due to local requirements); however the emissions were quite comparable. The comparison was for trial burn data from the Houston, Texas and Hammond, Indiana facilities. In the end, meeting the BIF emission requirements was not particularly difficult.

Session 5 was concurrent with Session 4 and was chaired by Richard Pleus of Intertox and Jim Woodford of Gossman Consulting, Inc. David Greenspan of CKRC kicked off Session 5 with an animated presentation entitled Effectively Communicating with the Public. He addressed the many aspects of effective communication with the public and used examples of some of the attendees as model programs. His basic points were, dialogue & feedback; honesty & openness; starting early; and assessing the situation & planning accordingly. One model program in particular was the Holnam facility in Clarksville, Missouri with Stan Ehinger, the facility plant manager, in attendance of this presentation. Stan added some personal comments as well.

The next presentation was given by Dave Gossman of Gossman Consulting, Inc. and addressed Community Relations via the World Wide Web. Dave spent his time talking about what can be done in a proactive sense and used a site developed for Continental Cement Company as his example. That web site can be accessed at http://continentalcement.com if you care to perform a more detailed examination.

The next paper was presented by the co-chair, Rick Pleus, and was entitled, Assessing Risks and Costs Related to Environmental Issues, Case Studies of Management Responses to Community Discontent. He presented a fairly detailed decision tree analysis of a particular situation with which he had been involved. This decision tree took into account the estimated financials involved to respond thoroughly, by performing studies etc. compared to other options and how decisions are made for particular approaches.

Michael Blumenthal of the Scrap Tire Management Council gave the next presentation on public communication. His basic message was to communicate early & often and definitely involve the people already working at the facility in question. He also thanked Dave Greenspan for priming his presentation.

The final presentation of Session 5 was also presented by co-chair Rick Pleus of Intertox. This time he talked about an Odor Investigation of a Portland Cement Plant. This presentation was pretty interesting as he discussed the various upwind and downwind locations that were sampled to pin down the source of the odor and the ultimate findings, which did not necessarily heavily implicate the cement plant. In the end, working with the community worked out for the best because a project to raise the stack height, which had previously been voted down by the town, was approved and the problem was resolved by and large. The morning break occurred at approximately 10:30.

The afternoon sessions were sparsely attended, as is often the case on the afternoon of the final day but this sparse attendance was perhaps a little more severe than usual. Nonetheless, Session 6 again ran concurrent with Session 7. Session 6 was chaired by Bruce Pedersen of Systech and Bob Nichols of USEPA Region VII.

To begin Session 6, Robert Nichols of USEPA Region VII presented An Evaluation of Cement Kiln Laboratories Testing Hazardous Waste Derived Fuels. This evaluation was conducted using a three person team and involved auditing five plants. The general results of the audits found most facilities to be competent although with some needed improvements. In the presentation, Mr. Nichols pointed out that in some cases the waste analysis plans were followed closely, especially for burn tanks. A number of examples of lab practices were noted as not following standard practices, such as the use of a pH probe for nonaqueous solutions. Other areas where some problems were detailed include recordkeeping, quality control and safety.

The second presentation of Session 6 was given by Aurora Shields of KDHE. This presentation was entitled The Future of Environmental Laboratory Accreditation. This presentation described the progress toward accreditation of environmental laboratories and some features of the National Environmental Lab Accreditation Conference (NELAC) such as their purpose and procedures. She described some of the efforts in her state, Kansas, to achieve accreditation for their laboratories and some of the difficulties in dealing with reciprocity from states. A note of significance is that efforts for national standards or accreditation is more for the commercial laboratory than for industrial laboratories. More can be learned by accessing the NELAC web site at http://www.dep.state.fl.us/biology/qa/ nelac.htm. If this does not work, use the Yahoo! search engine to search for NELAC.

Fred Anderson of Analytical Standards, Inc. gave the third presentation of Session 6. His presentation, Laboratory Selection Through Performance Evaluation, was aptly described by his overhead title "Laboratory Analysis - Getting What You Pay For." He gave a detailed presentation about how to conduct external and internal evaluations of laboratory performance. This is done by preparing standards which, when run through both administrative and analytical procedures, can accurately determine the performance of the analytical laboratory system. This can go as far as actually setting up a dummy customer with samples to analyze to test all aspects of the operation. The end result allows the identification of problem areas throughout a sample analysis process.

Following the break, Jim Woodford talked about selected NOD issues which are related to waste analysis plans. Gossman Consulting, Inc. has been involved in the writing, implementing and auditing of waste analysis plans all around the country. Most recently, GCI had been involved in client responses to Regional USEPA review of WAPs as part of the final Part B process. The presentation focused on how to make your final WAP comply with regulations but still be practical.

Craig Cape of GCI gave the next presentation entitled, Practical Quality Assurance/Quality Control in the Commercial Thermal Treatment Facility Laboratory. This was an important topic with some excellent suggestions. A copy of the paper can be obtained from Gossman Consulting, Inc. The final presentation of the day was by Dion Tsourides of Spectro. He spoke about The Analysis of Chlorine by ICP-AES in Waste Oils and Waste Fuels.

Session 7 was co-chaired by Carrie Yonley of Schrieber, Yonley & Associates and Rick Pleus of Intertox. David Weeks gave the first presentation of the Session entitled Ecological Risk Assessment at Hazardous Waste Combustion Facilities. Attendees of last years conference may recall that David Weeks had made a presentation at last year's BIF Conference on behalf of Region VI. Walter Greer had opened up a permitting discussion on his Chanute, Kansas facility by referring to some EPA regulators as "jack-booted thugs." David Weeks then introduced himself as a "jack-booted thug" from Region VI. His presentation then was on some health risk guidance coming out of Region VI. This year he magically became a consultant and was presenting a risk assessment paper from the other side of the fence. His presentation was much more mellow this year and he lightheartedly let everybody know that his "tapes had been working" and that was why we were seeing a kinder gentler David Weeks this year.

The next paper was entitled Current Issues that Effect the Estimate of Cancer Risks and Non-Cancer Hazards in Multi-pathway Risk Assessments for BIF facilities and was presented by Dina Johnson, a colleague of Rick Pleus.

Potentially, one of the better papers of the day was presented by Phil Goad of the Center for Toxicology and Environmental Health (the new company for David Weeks also) entitled An Assessment of Potential Environmental Impacts of CKD in Kilns Co-fired with Hazardous Waste Fuels. To make a very long story short, they looked at corn grown in various locations and one sample grown in CKD and found no significant difference in the metals uptake from background expectations. The presentation was obviously more complex than this, but that is what it boiled down to for this editor.

The afternoon portion of Session 7 included a presentation by Scott Kellerman of SY&A concerning Factors Influencing the Partitioning of Organic Constituents Between the Gas and Sold Phases, a presentation by Carrie Yonley on The Necessity for a Practical Approach to Address Organic Emissions from Cement Kilns, a presentation by Jeff Stevens of Rust Environmental on a 3M Corporate Incinerator Environmental Monitoring Study and Risk Analysis and the final presentation of the session, again by Jeff Stevens entitled Incinerator Thermal Release Valve Risk Assessment.

One final note concerns the Region VI guidance referred to in the Beth Antley question and answer period. Gossman Consulting, Inc. had learned about this guidance just before the BIF conference. This is the guidance referenced last year by David Weeks. This guidance amounts to 3,500 pages and has only recently been made available on the internet. This document has received no review outside the regulatory agencies and is already being used to review trial burn plans and other phases of the permitting process. A review and comment period would certainly seem to be in order.