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GCI TECH NOTES©

Volume 11, Number 9           A Gossman Consulting, Inc. Publication       September 2006

As a manager of a hazardous waste fuel facility one of the last things you want to do to a waste generating customer or blender is to reject a shipment.  (The last thing you want is to have someone hurt.)  Today less than one percent of shipments are rejected.  Quality control by waste blenders and better control by waste generators keeps rejections low.  This was not always the case.  At the first HWF facility at a cement plant with full quality control on incoming shipments in the early 80’s we rejected about three percent of all incoming shipments.  Waste generators under pressure by EPA to get rid of years worth of accumulated hazardous waste and blenders with little or no testing facilities created an environment where higher shipment rejection rates were a necessity.  My first shipment rejection in Paulding, Ohio happened before the onsite lab was in place.  The truck was full of water with a thin layer of solvent on top – something that can be seen when taking a sample.  The VP in charge of sales was sure I was wrong but the lab confirmed my assessment.  It is quite possible I would have been fired had I been wrong.  I have always considered the cement plant burning the waste my first and most important customer – not all in the business have that attitude.  A little over five years later, after being hired as McKesson Envirosystems’ Marketing Manager I was asked to supervise the start up of their HWF program at San Juan Cement in Puerto Rico.  I personally sampled and rejected the first shipment delivered to the cement plant – proving that even a dedicated offsite blending facility could not be counted on for all quality control of HWF.  Again the issue was water – a problem to this day at HWF facilities.

Of course heat content and chlorine were also leading causes of shipment rejection – not enough of the former and too much of the latter.  After six years of fighting to have HWF chlorine under 2-3 percent imagine my pleasure in setting a minimum specification for a plant at four percent chlorine and the maximum at eight percent.  Even recently I suggested to one of my international cement plant clients that they find a waste fuel source containing chlorine – possibly PVC plastics – to improve the performance of their alkali bypass.  Chlorine is not always a bad thing in cement kilns – one just needs to pay attention to the process chemistry.

One leading cause for shipment rejection in the early years was PCB contamination.  In order to insure the success of the HWF program I had developed a procedure for performing accurate threshold testing of PCBs inside 30 minutes after the sample came into the lab.  Shortly thereafter Chemical Waste Management, trying to assert that they could not have prevented PCB contamination of the waste oil lagoon in Vickery, Ohio, claimed that shipment by shipment testing for PCBs would have taken to long and was therefore impractical.  The Ohio EPA personnel involved knew better – they had visited the HWF facility I was managing.  The result was the largest ever environmental fine at that time. – Over 10 million dollars to my recollection.  Another shipment was rejected for PCBs from a major pharmaceutical company.  Not only were the generators in denial but the state of Michigan was rather unhappy - the other half of the contaminated tank was blended by Nortru and shipped to the Cadence steel mill waste fuel program – our primary competition at the time.  The steel mills never did set up onsite testing of shipments.  Surprisingly shipments still get rejected for PCBs – nearly 30 years after manufacturing ceased.

Rejection of shipments for metal contamination was relatively rare.  I had set reasonably high and comfortable limits based on research into cement process chemistry and potential emissions and worker safety issues.  Most of the limits have changed since then.  That said I will never forget the shipment of waste paint from a toy manufacturer – over 1,000,000 ppm (mg/l) lead!  The rejected shipment went to an incinerator in Ontario, Canada – apparently they had no lead limits or testing program!  I immediately started testing all older painted toys in my house that my daughter might play with. 

Another example of rejections was based on shipment by shipment testing of volatile and semi volatile organics found in the fuel.  We rejected shipments with high levels of compounds that were more toxic than our PPE program allowed.  We also rejected the occasional shipment that would show up with a peak on the gas chromatograph we could not identify.  (No mass spectrometer to help at that time.)  One of the most persistent waste generators which we rejected shipments from (directly or indirectly through blenders) was the US Navy.  Navy torpedo fuel, called Otto Fuel II, contains a high concentration (over 50%) of propylene glycol dinitrate.  This is a potent nerve toxin with a TLV of 0.05 ppm.  It was implicated in a documented case of nerve damage among employees at a commercial incinerator in North Carolina during the mid 80’s.  If you are a hazardous waste fuel burner do you know that you are not receiving this waste?

Of all the hazards associated with using hazardous waste as fuel the issue of toxic organic exposure of employees and the need for shipment by shipment testing of individual organic constituents is the least regulated and most often overlooked.  Current GC-MSD technology makes this testing much easier than twenty years ago.  I continue to believe that this level of testing (and rejecting shipments if needed) is a critical component for any waste fuel blender or cement manufacturer using hazardous waste fuels to avoid long term liabilities.