[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
Re: medical waste incinerator stack testing
For better or worse, this is my area of expertise. While you'll find me
going toe-to-toe with Greenpeace on occasion, I am currently helping other
activist groups in similar situations.
>After a couple years of stalling, a local 25 ton per day medical waste
>incinerator is finally doing stack testing. The problem is that we have
>confidence in the regulatory agencies overseeing the testing and need to
>a better understanding of the testing procedures. As community activists
>have learned that while taking the air samples to test for organics and
>metals "the collected samples for the metals analysis were determined to be
>invalid by the observers and new samples will be collected"
A sample is considered invalid for several reasons:
a) the sampling system did not pass its post-test calibrations or the field
b) no documentation for shipping and analysis - chain of custody forms
c) the lab analysis does not pass its audit or calibration routines
d) the test team botched other parts of the testing, which can include field
blanks, thermocouple calibrations, etc. etc.
e) the analysis came back "non-detect" for all metals analyzed, which is
almost impossible for any mixed waste incineration system under current
>My question is this. Are there any scientific reasons to be suspect of the
>claim that they would have to retest for metals. Could it be that a
"typical >burn" would not be able to conform to both organics and metals,
>perhaps they had fine tuned the system to pass the organics, knowing they
>could retest (and re-tune?) for the metals?
There is a difference between not passing the compliance standards for
whatever metals were found (which would require evaluation, repair, and
retest); and just having to retest for the reasons I gave above. SOME state
agencies - not all - will just allow a source to retest if it does not pass
it initial compliance test that it meets certain emission limits. But a
test report would still be available show how bad it was. The only reason
to be suspect would be that the value for the metal emissions was so high
they (the state) considered it bogus - when in fact they could have been
actual emissions. Don't have enough information here to tell what the
>Additionally, A week before the testing someone had overheard the
Incinerator >owners, say that the testing should go well unless they have a
train". > Could someone explain the term glass train and why it would pose a
? > Is there any significance to their having to re-test for metals?
It is hard to tell you in the context without other sentences. A "train" in
sampling refers the overall sampling system: nozzle, probe, heated sheath,
pitot tubes, filter holder, filter chamber, glass impingers. All of the
sampling systems for metals, semi-volatiles, dioxins and VOCs are glass
trains with some stainless steel and Teflon fittings. Some of the probes
that go into the stack are made of quartz if the temp is too high, but for
the most part the probe, nozzle, filter holder, and impingers are all glass.
No significance in retesting for metals.
>Obviously we need lots of tech ( and perhaps legal) help. If you, or
someone >you know are familiar with the procedures for stack testing and if
>suspected shenanigans are common in the industry we would be most grateful
>for advice and guidance.
Feel free to email or call me. Can provide some help on and off. Are these
shenanigans? Can't tell yet. There are some really bad testing firms,
there are some unethical sources, there are some incompetent members of
state agencies. If the testing is a victim of one or several of these we
can figure it out with a little effort.
Director, En-Vision Inc.