11, Number 11
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.
Economics and Competition for
Waste Fuel in Cement Kilns – The
David Gossman, Gossman Consulting, Inc.
In early 1980 the temporary facility set up by Systech at General
Portland Cement in Paulding, Ohio began routine operation shortly after
I was hired. I began the process of equipping and starting up an onsite
testing lab, staffing the facility and developing the analytical
testing methods. General Portland started construction of the permanent
facility and Systech hired Joe Durczynski to perform the marketing and
sales function on a full time basis. Joe and I worked closely with each
other and even cross-trained each other.
As part of the start-up of that project Systech had estimated that the
entire Midwest generation of hazardous wastes suitable for a cement
kiln fuel program was 10 million gallons of which we would target
getting 50%. The initial plan was a facility with 4 on-site employees
and one sales person providing 5 million gallons per year to the cement
plant – talk about underestimating a market!
The real struggle was with the market conditions during that start-up
phase when there were no waste combustor regulations. RCRA was just
coming into force and there was a huge energy recovery loophole built
into the EPA regulations. Prior to RCRA, materials that would
eventually become part of hazardous waste fuel programs were routinely
dumped or burned in open pits. Solvent recovery operations often had
pits on the “back lot” to accumulate still bottoms.
sometimes burned and other times simply covered up when they got full.
More than one facility eventually had to deal with the ground water
problems that these practices produced, and more than one of these
facilities burned to the ground with large and explosive fires sending
55-gallon drums exploding hundreds of feet into the air.
Even after the start of RCRA the better run solvent recycling
operations would take their still bottoms down to a high viscosity
paste consistency and load it hot into 55 gallon drums where it would
set up and then be land-filled. It took a lot of salesmanship to
convince them that it was a better idea to leave the bottoms more fluid
and send them to a cement plant.
Because of the loopholes in the RCRA regulations at that time a great
deal of hazardous waste was finding its way into outlets where the
waste was used instead of expensive fuel oil. The largest of these was
the Cadence program providing hazardous waste, labeled ChemFuel, to
steel mills in the Midwest. The Cadence program depended on quality
control performed at the blending facility. It was transferred directly
into heated tanks of No. 6 fuel oil at the steel mills where it was
burned in high temperature but reducing conditions in the steel
furnaces. In 1986, when EPA closed the energy recovery loophole in RCRA
the steel mills pulled out of the business and Cadence switched their
program to providing material to cement kilns. An EPA stack test
performed at one of the steel mills required the test crew to wear
supplied air systems because of the high levels of CO at the sampling
location. I have never been able to get EPA to release a copy of those
stack test results.
Other more illegitimate “blenders” were highlighted
in an evening news
cast of "20/20" as part of an investigative report. Cameras
showed hazardous waste being delivered to blending facilities and then
shipments of “fuel oil” coming out. The material
was tracked to boilers
heating apartment buildings in major cities and to boiler fuel being
used on ships. No wonder we had trouble getting some blenders to pay
our $.05-.10/gal processing fee! When asked about their testing program
one blender showed us how he always sampled each load, poured a small
amount out on the paved truck bay and lit it with a match to make sure
it burned and was “good fuel.”
In one of the more unusual competitive situations we ran into, the
Paulding facility on two occasions had low-level fly-bys of unmarked
black helicopters. They were close enough that we could see someone in
the cockpit taking pictures. Another “competitor”
Nebraska was making cat litter out of clay in a small old kiln
he was also burning hazardous waste as fuel. That was enough to make
twice about buying cat litter at that time. Other waste burning
operations included aggregate driers located at asphalt plants. It is
hard to imagine what the stack test results for such facilities might
have looked like had anyone bothered.
Even with the increased liability to generators and the beginning of
the superfund program to clean up old contaminated sites it was amazing
to sometimes hear what generators had to say about their
treatment/disposal options. One corporate level representative for a
big three auto manufacturer in Detroit said that they had dug up waste
before and they would dig up waste again – they would still
lowest bidder for getting rid of their waste.
Even after we moved out of the Midwest and started the first and only
facility to burn hazardous waste in California we ran into the same
competitive pressures from landfills. In California at that time liquid
organic hazardous wastes were disposed of by backing the truck up to a
municipal waste landfill, opening the valve and letting the material
pour out onto and soak into the “ground”
– and that was legal at the
time! It sure made it hard to compete and obtain the revenue to run a
good quality control program for hazardous waste fuel use in a cement
kiln. Of course, now all the hazardous waste fuel in California is
shipped all the way to Kansas or other Midwest locations.
It is sometimes hard to imagine all the changes that we have undertaken
in the hazardous waste fuel/cement kiln industry on the operations
side. It is even more hard to imagine the difficulty of selling the
early program to waste blenders and generators given the competitive
pressures that existed at that time. It certainly makes selling these
services today look a lot easier in comparison.