Gossman Consulting, Inc.
March 1992

GCI is dedicating this issue of HWF Notes to the recently completed Air and Waste Management (A&WMA) BIF conference held in Orlando, FL. Many of you no doubt attended the conference or had representatives from your company attend. It was informative and interesting, to say the least. Some may even say that it was also controversial.


Jim Woodford

First of all, compliments to Steve Stasko, Myron Black, Jim Estler and the many people who helped A&WMA put on a very worthwhile conference. A special thank you to Bob Holloway and Bob Mournighan from the EPA whose participation was invaluable. Our thanks as well to David Strauss, Staff Director, Environment and Public Works Committee, U.S. Senate who shed some light on re-authorization procedures for the uninitiated.

There were many informative papers presented at the conference. This issue of HWF will highlight some of the more broadly applicable presentations and discussions. Session 1, entitled "How the BIF Rules Have Changed the World", officially kicked off the paper presentations at the conference. One of particular interest was given by Michael Mac Naughton of Southwest Research Institute. While his presentation generated several questions, people will be especially interested in the findings of his study. You may recall that SRI is studying the Lafarge/Balcones situation and those findings will have far ranging effects throughout the cement industry.

A second paper with potentially wide ranging effects on trial burns was authored by Dr. Michael Von Seebach, Ros Simmons, Dr. F. M. Miller, Dr. Charles Lamb and David Gossman concerning monochlorobenzene as a POHC. In short, based upon the Dellinger rankings, MCB should be easily destroyed to the 99.99% level in cement kilns. Southdown has had problems with MCB and have determined that in fact, some of the benzene produced by the raw material is combining with the chlorine in the process and producing monochlorobenzene. Subsequent detection in the emissions incorrectly suggests insufficient MCB destruction.

The first panel discussion addressed what regulators have to say about BIF. Bob Holloway of the EPA gave a presentation about BIF guidance and general implementation issues. This presentation generated some good question and answer discussion and general clarification. One issue that was addressed concerned particulate matter (PM) emission limits and the monitoring of those metals that will clearly be in compliance due to that PM emission limit. Bob made it very clear that unless a facility chose to use the alternate metals emission control as detailed in Section 10 of the Guidance document, they could not take advantage of a metal emission limit that would exceed the PM emission limit. Specifically, this means that metals such as barium and silver must be monitored by plants which do not choose to use the alternate metals emission control. We also heard about the permitting and compliance side of BIF from Beth Antley from Region IV. It was evident from her presentation that all of the BIFs in Region IV can expect a BIF inspection by October of this year. She also talked about what a facility might expect from a BIF inspection, which would start with a team of people arriving unannounced at the plant. It would probably be a multi-disciplinary inspection which would include experienced incinerator inspectors. Judging by the feedback we have received from at least one Region IV BIF, this is an accurate description. She also pointed out that it would take 2 to 4 days to conduct the inspection. When asked for a copy of the checklist that Region IV is using, she explained that it was in draft form and would not be released until finalized. This makes one wonder if the actual BIF inspection will also be a draft (trial run), only requiring any kind of a response once the inspection form is finalized. Beth also pointed out that Region IV is issuing Notice of Violations (NOVs) rather than NODs since there is currently no NOD mechanism in BIF.

Session 2 addressed compliance. The moderator of this session was John Chadbourne who started off with comments that tied the preceding panel discussion together with the papers in his session. John did this in such a fashion as to elicit a verbal exchange between Bob Holloway and himself. This got session 2 off to a lively start.

While the presentations in this session were apropos to compliance, the most wide ranging presentation was concerning NODs. It is interesting to note that the slides in this presentation used identical wording found in some recently issued Region VII NODs, right down to the 5¼" diskette. In an informal discussion with the presenter later that day, the presenter clearly stated the opinion that the Agency could write an NOD for anything whether it was spelled out in the regulations or not. Time will certainly tell the tale, especially since, as Beth Antley from Region IV pointed out, there is currently not an official NOD process for BIF.

The second day began with session 3, which addressed hydrocarbons. This session was probably appropriately titled "Holy Hydrocarbons!" since when one sees the initials of BIF, they might easily think of "BOF" also. This is much like what was often plastered all across the screen in the old Batman serial during the fight with the bad guys. The moderators billed themselves as Batman and Catwoman.

Bob Holloway kicked things off with his presentation about a pending BIF technical amendment designed to address the fact that HC spikes are not currently allowed under baseline conditions. The technical amendment, which is expected to be out within the next thirty days, will establish a variability factor of 10 ppmv. Following a convoluted math lesson, it all boiled down to baseline plus 10 ppmv.

Eric Hanson razzled and dazzled the audience with an array of impressive information somehow condensed into a 20 minute presentation. He spoke of the Ash Grove experience in controlling hydrocarbon emissions from cement kilns. He demonstrated that if you gather enough information about kiln combustion, analyze the data and then make it available to the kiln burner, you can successfully control HC emissions. Bob Holloway expressed interest in Eric's presentation. It is interesting to note that several years ago, Eric contacted the EPA about the use of a cold probe HC monitor and they assured him that they would never stray from that guideline. Oh well, you know what they say about the best laid plans of mice and men.

Session 4 dealt with metals. While the papers in this session were interesting and timely, the presentation that held the greatest potential overall importance was a paper on metals spiking presented by Gregg Franklin. Gregg provided the rational for metal compound selection based on EPA guidance and the desirability of running the test under "worst case" conditions.

That afternoon, the second discussion panel was held dealing with communication of risk to employees, residents and regulatory officials with respect to burning hazardous waste in cement kilns. This session was chaired by Kathryn Kelly, who many of you may be familiar with through her presentation at the 27th International "Rock Products" cement seminar held in December of 1991. She is also the author of the recent publication All Fired Up.

Many of the attendees later wished that this session had been longer since community outreach is of such importance to all of you right now and will continue to be for the foreseeable future. While all the presentations were of interest, the one that rang the truest was given by Russ Wiles, a plant manager for Holnam in Mobile, AL. The underlying theme to Russ's presentation was trust and credibility. If you have good trust and credibility with your employees and with the community, then half the battle is won. Unfortunately, this panel did not get a chance to address damage control.

The presentation that drew the greatest attendance in session 5 was "Anatomy of a Disaster - ENSCO in Arizona". This presentation was of interest because, the original idea came from the State, the State covered many of the project expenses, and in the final analysis, the State buckled under to out of State pressures and bought the project out so they could kill it. It is also of interest to note that Kathryn Kelly expressed her disappointment with the speaker's presentation since it did not offer any suggestions on how to deal with that situation, but rather presented it as a humorous anecdote. While the crowd sentiment appeared to be with the speaker, Bob Mournighan of the EPA echoed Kathryn Kelly's concern that perhaps we all sit around and tell too many war stories, rather than band together and figure out how to deal more effectively with some of these situations.

Obviously, not all papers presented at this conference are covered in this issue of HWF Notes. For those who are interested in further information, proceedings for this conference are expected to be available by June of 1992. Please contact the Air & Waste Management Association, (412)232-3444 and ask for Publications in order to obtain a copy.