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GCI TECH NOTES©
Volume 9, Number 1 A Gossman Consulting, Inc. Publication February 2004
by
David Gossman, Gossman
Consulting, Inc.
The acceptance or rejection of individual
shipments or
drums of hazardous waste at hazardous waste fuel blending or burning
facilities
must focus on five key factors needed to ensure the success of a
project. This review of the parameters
associated
with each of these five areas will demonstrate the importance of
thorough
laboratory analysis of each shipment of waste received at the facility. Based on the relative consistency and
sources of other alternative fuels and raw materials (AFR) many of
these same
factors may be applied to other AFR programs as well.
The first and perhaps most obvious criteria
in the
acceptance or rejection of a shipment is whether or not the waste is a
fuel. Generally this requires a heat
content analysis. Many facilities have
added the criterion of total water content to this portion of the
evaluation as
well.
Product and process protection requires
analysis and control over a
wide variety of parameters. These include halogens, sulfur, selected
metals,
radioactivity and ash as examples that protect the kiln system and
clinker
product. There is also the need to protect the storage and feed system.
Incompatible wastes that can gel or react must be avoided, pH must be
controlled to prevent corrosion and viscosity may need to be controlled
to
maintain pumpability of liquid wastes. All of these parameters can be
tested
using high-speed methods of analysis. By implementing a system of data
quality
objectives (DQOs) it is possible to avoid analytical burdens that go
beyond
what is actually needed.
Protection of human health and safety is one
of the most important functions performed by the analysis of the waste
streams. Unfortunately, it is often the
most overlooked both by operators and regulatory authorities. Employees
involved in operating the hazardous waste fuel blending, storage and
feeding
systems as well as laboratory workers and samplers are the most
"exposed" and any program for controlling receipt of wastes must take
into account the worst case as well as normal exposure levels of these
individuals to the waste. It is for this reason that it is critical
that there
be an organic analysis of every waste stream prior to shipment to the
plant and
a second organic analysis upon receipt to confirm that there are no
compounds
or combinations of compounds that could result in either acute or
chronic toxic
exposure. Examples of wastes that have been received and potentially
endangered
employees at hazardous waste facilities are numerous. A few are listed
below:
Propylene glycol dinitrate - This is a
component in "Otto Fuel
II" which is torpedo fuel. In the mid 80s an incinerator in North
Carolina
receiving this waste allegedly caused the chronic poisoning of a number
of employees.
At low levels this compound is a chronic nerve toxin. It has an ACGIH
skin
exposure based TWA TLV of .05 ppm.
Toluene diisocyanate (TDI) - TDI is a common
industrial chemical used
in numerous chemical manufacturing processes including the production
of
polyurethane foams. It has an ACGIH TWA TLV of .005 ppm. A few years
ago it in
combination with other TDI production wastes and chlorobenzene was
involved in
the explosion of a rail car at a cement plant where it was being used
as waste
fuel. This material is highly water reactive and can react with itself
when
heated producing gas, heat and pressure. The resulting explosion caused
considerable damage at the plant.
Amines - As a general class there are many
amines with ACGIH TWA TLVs
of close to 1ppm. Further, amines can be involved in hazardous
polymerization
reactions with some compounds found in liquid hazardous waste fuels
such as
vinyl acetate. In one case amines were added to a tanker of hazardous
waste
fuel to adjust the pH of the material. It was then shipped to the
cement plant.
Upon arrival at the cement plant the increase in temperature that had
occurred
inside the insulated tanker created fumes that almost overwhelmed the
truck
sampler when he opened the truck hatch even though he was wearing a
full-face
organic cartridge respirator. The hot tanker required implementation of
the
facility's emergency response plan.
There are numerous other examples. Only
through thorough analysis of
the waste and expert review of the resulting data can these types of
incidents
be avoided. Our next issue will discuss
options for setting up a system to fully utilize the results of organic
analyses to protect employee health and safety.
Generally speaking if the process and product
are protected and the
individuals handling the waste are protected there are only a few
additional
concerns that need to be addressed relative to protecting the
environment. One
of these is mercury (Hg). Other semivolatile heavy metals such as
cadmium (Cd)
and lead (Pb) may also need controls beyond that required to protect
product
quality in order to protect the environment. As with all the analytical
requirements discussed, careful development of DQOs can significantly
reduce
the analytical burden and make the testing of every shipment of waste
received
a cost effective option for reducing costs attributable to actual and
potential
liability.