GCI
TECH NOTES©
Volume
11, Number 6
A Gossman Consulting, Inc.
Publication June 2006
This
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
commercial
hazardous waste operation at a cement plant in early 1980.
Many
of the
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
storage, lab
testing methods, processing and the impact of HWF on cement product
quality and production.
by
David Gossman, Gossman Consulting, Inc.
Whether sampling from trucks or tanks the process of getting a representative sample of HWF today seems rather obvious. It was not always that way.
In
early 1980 the original test tank farm at the
Paulding, Ohio General Portland Cement plant consisted of a 12,000 and
an
18,000 gallon tank set up inside an old coal bin. There were no
sampling ports
on the tanks but there was a sampling port on the pump discharges and
another
one on the bottom of the basket filter used to filter truck transfers.
All
trucks came in with their own pumps for offloading. Lab testing was
done on an
after the fact basis at the Systech corporate office in Xenia, Ohio.
Early
samples were taken by drawing a portion of the sample from the bottom
of the
filter basket at the beginning, middle and end of the unloading
process. When I
started I also began pulling a dip sample from the top of the truck for
a
visual check. You can imagine the scene that I created when I rejected
one of
the early trucks simply because it did not “look
right”. It turned out to be a
truck full of mostly water – just a thin layer of solvent on
top. About six
years later I did the same thing with the first truck delivered to the
HWF
operation run by McKesson Envirosystems (which became part of
Safety-Kleen a
couple years later) at San Juan Cement in Puerto Rico. It was one thing
for the
facility manager in Paulding to reject a truck based only on a look
– it was
altogether different for the corporate marketing manager to do the same
thing
on a truck that was accompanied by a signed analysis from McKesson.
Again the
truck was mostly water. While it was sometimes claimed that I could
tell a
truck was bad by just looking at it – that was not the case
and the issue of
getting a representative sample that would allow us to predict in
advance the
contents of a tank became a critical project in Paulding as we geared
up for
compliance with the coming RCRA regulations.
As
the new tank farm was built in Paulding I
specified sampling ports spaced along the ladders up the side of the
tank so we
could sample at different levels to verify complete mixing and proper
agitation. Early tests demonstrated that it took about 30 minutes after
the
last transfer to a tank for the tank to be mixed adequately enough so
that the
a sample drawn from the bottom port on the tank was representative of
the
entire contents. Of course we also found out quickly about the critical
need to
flush the sampling port just prior to drawing the sample so that the
sample
would not come out disproportionately high in metals and ash.
The
much bigger challenge was obtaining a
representative sample of the truck for testing in the onsite lab prior
to
unloading the truck. EPA had specified in the early RCRA regulations
the use of
the COLIWASSA sampler for liquids with multiple phases. This sampler
was
designed for drums – not trucks. The early sampling tubes
delivered by the
engineers at the corporate Systech office were true to the EPA design.
They
were heavy, did not close well, did not drain well, and were impossible
to
clean. My staff and I did not have kind words for the engineers or EPA
at that
stage. The next step was to take the metal rod out of the center of the
tube
and stretch it down the side of the pipe with complicated hinges and
closing
mechanisms on both ends – an improvement but still very heavy
and a pain to
use. Getting a sample out of these tubes and into a sample can without
making a
mess was challenging – and they were still very heavy, long
and cumbersome to
handle on top of a tank at a time where there was no such thing as
sample
bridges or safety cables. (The most common early accident in HWF
operations was
someone falling off a truck while taking the sample.)
I
cannot take credit for the insight and invention
that led to the sampling tube that nearly everyone in the industry uses
to this
day. That credit must go to a young man whom I had hired straight out
of high
school to be our first process operator. Carl Laney deserves all the
credit for
that important development. As he struggled yet again with a new tube
provided
by the corporate engineers that consisted of pipe, two ball valves and
a
complex rod connecting the valves on both ends he came to me and asked
if he
couldn’t just use a ball valve on the end of a pipe and push
it shut against the
bottom of the truck. Craig Cape, my assistant manager, and I looked at
each
other in wonder at why we had not thought of the idea and gave him an
enthusiastic “Yes!” Of course at that time the
fastest way to spread the word
on anything in the industry was to tell a truck driver. I think within
1-2
months every facility in the country was using Carl’s design
as the word
spread.
So
the next time you or one of your people work with
that ball-valve-on-a-pipe sampler think of the fact that you could be
using an
EPA designed COLIWASSA to sample that truck and thank Carl for making
the job a
whole lot easier.