|Gossman Consulting, Inc.|
GCI TECH NOTES©
The 1996 A&WMA BIF Conference was again held in Kansas City, Missouri. The Ritz Carlton Hotel is well suited for a conference and an area of diverse shops and restaurants called "The Plaza" is literally just down the block. The conference was kicked off by the General Conference Chair, Charlie Whitmore, with a local welcome from Kathryn Shields, Jackson County Executive. The keynote speaker was introduced by John Smith of Region VII, the Technical Program Chair. Fred Chanania, Project Director of Hazardous Waste Minimization & Combustion Strategy for USEPA, was the keynote speaker. Given that the MACT standards had just been released three business days earlier, participants were anxious to hear what he had to say.
Fred began with a general overview. The Revised Standards for Hazardous Waste Combustors (HWC) address 80% of combusted waste (3 million/3.6 million gallons) and intends to achieve 98% reductions in dioxin/furan emissions, 95% reductions in lead & Cadmium emissions and 80% reductions in mercury emissions. The standards cover 162 incinerators, 22 cement plants (43 kilns) and seven light-weight aggregate kilns. A Hot Line telephone number, (800)424-9346, was given for additional information. Fred also recommended that reviewers obtain a copy of the docket. It was pointed out that these standards were being issued under joint RCRA & CAA Authority and were based upon the maximum achievable technology standards. The HWC standards are being released in hopes of avoiding a separate RCRA risk assessment and providing a framework for coordinated RCRA & CAA permitting efforts. In Fred's opinion, these new standards did achieve the goal of one set of emission standards for incinerators and cement kilns. The USEPA also feels that they have set up the framework for coordination between local, state and regional authorities.
Fred Chanania then briefly discussed the general approach to the new standards which is based upon maximum achievable control technology (MACT). A floor level is determined which includes the identification of available technologies. Provisions are then included for the highest floor source plus some level of variability. There is also beyond the floor levels consideration which includes cost effectiveness and miscellaneous other factors. In the case of new facilities, they must use best controlled source or similar source technology. One thing that Fred did request was the submission of normal operating test data and comments along those lines. It was summarized at this point that USEPA felt some of the big pluses of the new rules was the allowance of highest floor source plus some variability, and specific control technologies were not being required. Fred also pointed out that USEPA believed 40-60% already meet single HAP standards, and these rules are comparable to the municipal waste combustors rule and European standards. Other significant issues raised included CEMs for mercury and particulates, various compliance issues such as a three year implementation period, comprehensive testing every three years, and dioxin/furan testing every 18 months.
Following the break for exhibition viewing, came an HWC panel discussion which dovetailed beautifully with Fred Chanania's keynote address. Panel members for the discussion of the new regulations included Craig Campbell of CKRC, Fred Sigg of WTI, Henry Winders of Continental Cement and Fred Chanania & Bob Holloway of USEPA. The session was chaired by Dave Gossman of Gossman Consulting, Inc. who also presented a hypothetical cement company executive list of concerns. The first presenter was Craig Campbell. He expressed hopes that this new set of regulations clarified what is expected of waste fuel burning cement kilns so that we could avoid the enforcement initiative fiasco that occurred with the BIF regulations. It is worth noting that Craig's overall tone was one of cooperation with USEPA as these proposed regulations are finalized.
Next to talk was Fred Sigg, who manages the most scrutinized hazardous waste incinerator in the country, thanks to Al Gore's election pledge back in 1992. Fred Sigg pointed out that in developing and building the WTI incinerator, BIF and European regulations had been taken into consideration, consequently, WTI is quite prepared for these new regulations. WTI already has a quarterly PCDD/PCDF testing program in place. He looked at comparisons of various combustion technologies and pointed out that dioxin control technology is not the whole story. WTI already meets the new regulation standards and is actually pushing for stricter hazardous waste incinerator limits.
Henry Winders was the third participant and he posed a number of concerns:
What about apparent conflicts between the new rule and the preamble?
Reduction of back-end temperature will likely require add-on technology at what cost?
EPA is touting 95% reduction in emissions but appears to be based upon worst case COC emissions data and realistic reductions are probably more like 20%.
New CEM requirements will require a great deal of maintenance, calibration & certifications.
What about pending cement facility 5-10 yr RCRA permits with the new requirement to test every three years no matter what?
Test methods are likely going to change; HCl test method doesn't work which USEPA air group recognizes but RCRA group does not; Continental experimented with carbon injection and it didn't seem to work [Henry commented that USEPA took a giant leap of faith by including carbon injection in the new regulations].
Dave Gossman then followed up Henry Winders with a general summary
what he thought might be concerns of a typical cement manufacturing
cost of rule may more significantly impact incinerators due to increased testing requirements
likely to be higher disposal rates to charge
may result in fewer competitors
on-site burners may send more off-site
immediate costs of rule analysis
additional testing costs
potentially face another round of aggressive enforcement actions
new requirements will result in additional downtime cutting into cement production
concerns over fuel supply enter into cost expenditure debate
Dave ended his presentation with the general question about application of the new rule to non-waste fuel burning cement kilns since the MACT process was applied? At this point, a presentation was made by Fred Chanania, essentially continued from his keynote address, and he was integrally assisted by Bob Holloway.
Fred began his talk by asking how should industry direct their efforts to help plug the gaps in this new rule? He pointed out that USEPA representatives "don't want to do something stupid and unachievable." The desire is to get on a rational, technical rule-making path. He reiterated an earlier comment by Dave Gossman alluding to approximately 200 requests for information in the preamble for the new rule. He made a number of points, a few of which are as follows: doesn't want to force raw material substitution; Lafarge has met with some success using carbon injection to reduce mercury emissions; wants to meet organics emission reductions without requiring site specific risk assessment (desires low PIC emissions); regarding the comparable fuels issue, if it looks like a fuel and quacks like a fuel then USEPA doesn't want to regulate it as a hazardous waste - he made a point to emphasize that it is not a "clean fuels" issue so don't confuse the two; and he requested cement production data in terms of economic impacts. He closed by briefly mentioning four key areas for cooperation: coordinated permitting process; CEM development; PIC testing; and communicating general impact. The panel, chaired by Dave Gossman, then entertained questions, although most were addressed to Fred Chanania & Bob Holloway.
Q: What about data submission cut-off date(s)?
FC: Difficult to say - 90 days?
BH: Will likely issue second data availability for CEM demonstrations, although some metals CEM data is available in the Washington D.C. docket.
Q: What about health risk considerations in the rule development?
FC: Risk evaluation in lengthy background documents - did not drive the process.
Q: What is the baseline criteria for comparable fuels?
FC: Had RCRA hat on for this one, coal is not used as a benchmark but did use # 2,4 & 6 fuel oil.
Q: Kathryn Kelly asked a detailed question concerning risk assessment revolving around the fact that the USEPA dioxin reassessment had been challenged big time; and since cement kilns are not a major source of PCDD/PCDFs, then all of this emphasis on reductions in these emissions do not improve health risks.
FC: Keep in mind that technology research is ongoing and that MACT is a statutory process compelled by law [whether or not it makes sense].
Q: What about the consideration of individual HAPs versus the overall congressionally intended approach?
BH: There is one cement kiln out there that can already meet every one of the new emission standards without spending a dime.
Q: It seems that there is going to be a string of pollution control equipment at the end of a given cement kiln, what technology string is recommended?
FC: Fabric filter, quenching, and carbon injection.
Q: Will the used carbon from the carbon injection technology have Bevill exemption?
BH: Good question, need to think about that one.
Q: Do the new CEM requirements remove the current BIF input limits?
BH: Yes, or at least it can.
DG: It will likely result in continuation of feed rate monitoring.
BH: Good point.
FC: But the new rule does at least provide that flexibility.
Q: USEPA once took the position of compliance with BIF indicating a safe operation, then came appearances by Administrator Browner on the McNeil/Lehrer news hour where she made unfounded accusations against waste fuel burning cement kilns. Will EPA ever take the "compliance indicates safe operation" position again?
FC: Regions will fall back on the permitting process.
Q: The original BIF rules had HC/CO provisions for wet process cement kilns which turned out to be non-combustion related. When challenged, the courts agreed with the argument and then vacated that portion of the rule, leaving many kilns in worse shape than before the challenge. How can we help insure that this new set of proposed regulations will not suffer the same fate?
A: Industry needs to be forthcoming with comprehensive operations data before the rule is finalized.
Q: What if analysis of the newly proposed HWC regulations were to indicate that it was actually more harmful to human health and the environment than the existing regulation?
A: We are responding to legislative and policy issues with these
regulations, and can only address your technical issues.
The luncheon speaker for this first day of the conference (and the only luncheon speaker this year in order to incorporate as many papers as possible) was Bode Buckley from ASTM. Her talk focused on the role that ASTM plays in developing consensus methods. It is worth noting that many times SW-846 does not have approved methods for various waste fuels analysis while ASTM does. [Initial review of the Revised Standards for Hazardous Waste Combustors indicates that SW-846 is now required in order to comply with the new regulations, even though there are still some analyses for which there are no appropriate, approved methods.] Bode Buckley discussed how ASTM could be put to work for the boiler and industrial furnace universe and pointed out that OMB Circular A119, legislation that has become law, requires that "All Federal agencies and departments shall use technical standards that are developed or adopted by voluntary consensus standards bodies [e.g. ASTM], using such technical standards as a means to carry out policy objectives or activities determined by the agencies and departments."
The session following lunch was entitled "Permitting and Regulatory Compliance", chaired by John Iwanski of Trinity Consultants. The first presentation was by Bob Guest, DRE Technologies, entitled "Enhanced Techniques of Data Collection and Reduction for BIFs." As the title implies, the talk addressed continuous emissions monitor data collection and processing. The next paper was presented by Dave Gossman of Gossman Consulting, Inc. entitled "An Analysis of Potential Changes to Operations and Waste Analysis Requirements for Commercial Facilities Regulated Under EPA Proposed Hazardous Waste Combustor Regulations." This paper focused on some of the potential problems for waste combustors based upon a cursory initial review of the HWC regulations released just three business days before this conference. Two key issues raised was an alleged reason for proposing metals CEMs, elimination of metals spiking, and more frequent testing of CKD. Dave pointed out that the certification requirements for the metals CEMs would in fact result in more frequent metals spiking so that metals concentrations in the stack would be high enough to exceed the detection limits of the metals CEMs. The increased testing on CKD was challenged as being unnecessary and much more expensive. Several years of data already exists which strongly suggests that dust analysis require-ments could actually be reduced. Dave also pointed out some inconsistencies between the preamble and the actual regulation. One in particular was that the preamble very clearly gave the rationale for performing the normal three hour PCDD/PCDF stack testing, allowing non-detects to be counted as zero, versus the regulations which stated that six hours of testing must be performed in order to count non-detects as zero. This would mean three days of testing versus one day of testing. Dave also pointed out that the HWC rule appeared to require SW-846 analytical methods even though some methods are inappropriate. Also, he reiterated how ASTM could fill some gaps, given the legislation discussed by the luncheon speaker.
Frank Salter of Continental Cement was the next speaker and he talked about the "Identification and Quantification of Chemicals in Supplemental Fuels." His talk centered on Continental's use of Gas Chromatography/ Mass Spectrometry (GC/MS) for HWF analysis. The Continental waste fuel laboratory performs more analysis than any other waste fuel lab in the country. This includes daily TCLP determin-ations on CKD. Bill Qualls of Eastman Chemical was the last speaker before the break. His talk was entitled "Public Involvement in Hazardous Waste Permitting." With many BIFs going through the permitting process even as you read this conference summary, and the December 1995 finalized EPA expanded public participation and revisions to combustion permitting procedures, his talk was well received. Keeping the public informed tends to have a positive impact on the permitting process. But whether it works for your facility or not, EPA intends to make sure that there is a lot of it.
The session continued following the break. The next presentation was given by Michelle Lusk of CKRC. Michelle presented data gathered from CKRC members and the National Association of Solvent Recyclers (NASR). Data from 1993 through 1996 confirmed that waste fuels with lower metals and higher BTUs were being sent to cement kilns and the higher metals, lower BTU materials were sent to incinerators. Data was also presented from E.I. Digest demonstrating that the volume of waste processed at cement kilns remained fairly steady between 1989 through 1994. CKRC member data from 1992 through 1995 demonstrated that the BTUs remained fairly constant as well, around 12,000 BTUs/lb. The next paper was presented by Michael Blumenthal of the Scrap Tire Management Council. The basic message, probably not new to most of you, is that tire burning in cement kilns is a growing business and is already the largest market for scrap tires with approximately 30 kilns currently burning scrap tires. Michael also talked briefly about the "burning used tire road" in the Northwest. Briefly, the road fill used was much deeper than the Tire Council recommends, there was a lot of flooding which then seeped down into the tire fill which then started evaporating and heating up, sending off fumes which the increasing heat ignited, hence the burning roads. Michael also explained that he had nearly been late for his presentation because he had been on a telephone interview with National Public Radio. Perhaps some of you caught the interview. Michael's paper ended Session 2.
The next to the last paper of the day was given by Jim Woodford of Gossman Consulting, Inc. entitled "A Comparison of Normal and Worst Case Cement Plant Emissions." Metals emission data from an October 1995 Lone Star Industries, Cape Girardeau, Missouri trial burn was examined. A normal operations test day was included since that would be more representative of cement plant emissions in terms of any risk assessment. The data indicated that not all metals worst case SREs were exhibited on the so-called worst case test day and there was no across the board volatility or spiking factor. This is obviously quite different than what is predicted by assumptions in the BIF regulations. The final paper of the day was presented by John Caine entitled "Process Dust Collectors: A Comparison of Jet Pulse and Reverse Air Units for Process Applications."
Interestingly enough, Session 3, which started late on Day 1, also kicked off the beginning of Day 2. Bob Schreiber was again the chair for the rest of the session, entitled "Organic/ Inorganic Emissions and Operational Issues." The first paper continued in the vein of technological control with a paper presented by Bob Taylor entitled "Operating Air Pollution Control Equipment & Its Effect on Overall Operations." Bob Taylor talked about greatly increasing air pollution control efficiency at Suez Cement. His paper was very well presented. Bob Schreiber himself presented the next paper entitled "Comparison of Criteria Pollutants for Cement Kilns Burning Coal and Hazardous Waste Fuel." Bob Schreiber also had an interesting presentation with lots of data; but if I could boil Bob's paper down to a single concluding sentence it would probably be that, overall, there are less pollutants emitted by some cement kilns when they are using hazardous waste fuel (HWF) than when they are not burning HWF. Scott Klamm of Midwest Research Institute presented the last paper before the break, entitled "POHC Selection and Method Validation Using a Bench Scale Gas Simulator." The work had been performed for a hazardous waste incinerator and the paper examined rather elaborate investigations into how to get the best recoveries of selected POHCs with regard to use of volatile or semi-volatile methods. This paper also ended Session 3.
Session 4 began after the break and was entitled "Testing and Continuous Emission Measurement", chaired by George Cobb of Air Source Technologies. Robert Barton of Midwest Research Institute gave a paper entitled "Advanced Monitoring Concept for BIFs." This presentation compared the manual metals emission test method with a metals CEM still in the developmental stages. It is of great interest to note that the new HWC regulations are proposing metals CEMS as one compliance option even though "a CEMS is not commercially available for LVMs (low volatile metals) and SVMs (semi-volatile metals) at this time, and the Agency is uncertain whether a CEMS that could meet the proposed performance specifications...would be available at promulgation of the final rule."[Part V: Implementation, II. Selection of Proposed Monitoring Requirements, C. Compliance Monitoring Requirements, 4. Semivolatile Metals (SVM) and Low Volatile Metals (LVM), a. Evaluation of Monitoring Options - HWC Preamble]. The next presentation, entitled "Alternative Technologies to Optical Opacity Monitoring Systems Relating to Regulatory Compliance (Title V)", was presented by Mark Santchi of BHA Company, Inc. and addressed particulate monitoring equipment. The project involved installation of an ESP on a Mexican preheater kiln. A five month EPA Method 5 comparison yielded a correlation coefficient of 0.999.
John Powell of CPS Environmental Services gave the next talk entitled "Hot-Wet Instrumental Hydrogen Chloride (HCl) Emissions Quantification Using GFCIR." The study offered some good comparative data to add to the debate of HCl in cement plant emissions. The paper concluded that they did find free HCl in cement kiln exhaust even though John had gone into the project quite skeptical. He challenged the audience to poke holes in his data, and they did. One question concerned the investigation of NH3 as compared to Cl, which they had not investigated, and then the potentially killer question was concerning whether or not the study had actually measured HCl as a decomposition product rather than actual free HCl. John answered that this was certainly possible. The study did provide some good data for the debate however. The next two presentations were by Roland Zepec of VEREWA GmbH in Germany. His first talk concerned a mercury CEM that has been running since 1988, although it is not in operation on any cement kilns. EPA is requiring Hg CEMs as part of the proposed HWC rule. His second paper, entitled "Automatic Extractive Emission Dust Monitoring -Absorption Technology", addressed particulate monitoring in stack gases. The conference then adjourned for lunch.
Following an unusually brief luncheon break, without a luncheon speaker, the conference resumed again with the fifth and final session entitled "Risk Assessment and Commun-ication", chaired by Suellen Priages of Risk Communications Intl. The first paper of the session was given by Sorell Schwartz of Georgetown University Medical Center entitled "Assumptions and Structures of Risk Models." He contrasted issues between the assessors of risk and the managers of risk. In particular, Sorell discussed eleven risk management policy assumptions which he described as very conservative. His talk reiterated what most in the audience already knew, EPA risk assumptions are so conservative as to cross the border into the absurd. The next paper was presented by Ron Gots, a physician with the National Medical Advisory Service. His talk was entitled "Public vs. Private Risks" and was also very well received. He spoke about an indignation index which ranged from "None" through "Annoyance" and "Anger" to "Outrage." He pointed out that indignation is unrelated to the extent of the actual health hazard. He also contrasted various personal health messages: we just don't know; science is uncertain; cancer causer/carcinogen; probably not a human carcinogen; a possible carcinogen, but a weak one; the studies show the following...; and considering the nature of this chemical and the amount of your exposure, there is almost no risk to you. He pointed out that all of these statements were true but which one you choose can make a big difference on how you come across. He left the audience with two risk axioms: Life is a sexually transmitted disease which is uniformly fatal; and Fastening seatbelts increases the risk of dying of cancer. The final paper before break was entitled "Applications of Risk Management to Waste Combustion in Boilers and Industrial Furnaces."
The third from the final paper of Session 5, and the day, was presented by Suellen Pirages, the session chair, entitled "Dioxin Reassessment: Assumptions and Interpretation of Risk." Suellen did an overall presentation of the Science Advisory Board's findings concerning the EPA dioxin reassessment. She had sat in on the meetings, re-read the transcripts and had read the report. In general, the report was an excellent review of the literature, but EPA risk conclusions were not supported by the data they reviewed and the report was sent back to them for significant revision. [However, that has not stopped EPA from citing the dioxin study numerous times in the proposed HWC regulations.] The next paper was presented by Loren Lund of the Texas Natural Resources Conservation Commission (TNRCC), entitled "Addressing Community Concerns about Industrial Emissions and Burning of Hazardous Waste In Cement Kilns: A Summary of Environmental Data." This was a fairly technical presentation which elaborated upon what has recently been in the press over the past several months. The study was multi-year and was conducted in and around Midlothian, Texas where three cement kilns operate and two have historically burned hazardous waste. Briefly, the study found that adverse health effects are not expected from dioxins; are not expected as a result of exposure to emissions from the major industries in Midlothian; and are not likely to be caused by cement kilns.
The final paper of the conference was also presented by a TNRCC representative, Lucy Frasier. The paper was entitled "Case Studies in Risk Assessment for Hazardous Waste Burning in Cement Kilns." This was another part of the Midlothian study and revealed, among other things, that a 1 in 100,000 risk was negligible and the evaluation even included five dairy farms. Both of these studies are available through TNRCC in Austin, Texas. Call (512) 239-0028 and ask for Documents # AS-71, 72, 72A and 72B.