11, Number 9
A Gossman Consulting, Inc.
is part of a
series of GCI Tech Notes focusing on the early
development of the hazardous waste fuels programs during the early
1980s. I was hired as the facility manager for the first
hazardous waste operation at a cement plant in early 1980.
developments in storage, processing, testing and use of hazardous waste
fuels were the result of work done at a handful of plants in the early
and mid 80’s. Look for issues to include topics on
testing methods, processing and the impact of HWF on cement product
quality and production.
David Gossman, Gossman Consulting, Inc.
a manager of a hazardous waste
fuel facility one
of the last things you want to do to a waste generating customer or
to reject a shipment. (The
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
under pressure by EPA to get rid of years worth of accumulated
and blenders with little or no testing facilities created an
higher shipment rejection rates were a necessity.
My first shipment rejection in Paulding, Ohio happened
onsite lab was in place. The
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
considered the cement plant burning the waste my first and most
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
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
specification for a plant at four percent chlorine and the maximum at
recently I suggested to
one of my international cement plant clients that they find a waste
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
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
testing of PCBs inside 30 minutes after the sample came into the
lab. Shortly thereafter
Management, trying to assert that they could not have prevented PCB
of the waste oil lagoon in Vickery, Ohio, claimed that shipment by
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
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
program – our primary competition at the time.
The steel mills never did set up onsite testing of
shipments still get rejected
for PCBs – nearly 30 years after manufacturing ceased.
of shipments for metal
relatively rare. I
had set reasonably
high and comfortable limits based on research into cement process
potential emissions and worker safety issues.
Most of the limits have changed since then. That said I will
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.
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
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
indirectly through blenders) was the US Navy.
Navy torpedo fuel, called Otto Fuel II, contains a high
(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
during the mid 80’s. If
you are a
hazardous waste fuel burner do you know that you are not receiving this
all the hazards associated with
waste as fuel the issue of toxic organic exposure of employees and the
shipment by shipment testing of individual organic constituents is the
regulated and most often overlooked.
Current GC-MSD technology makes this testing much easier
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
waste fuels to avoid long term liabilities.