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GCI TECH NOTES©

Volume 11, Number 11           A Gossman Consulting, Inc. Publication       November 2006

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. These were 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” we ran into in 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 you think 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 use the 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.