Re: medical waste incinerator stack testing

["Sam McClintock" <scmcclintock@ipass.net>]

  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
  lost
  >confidence in the regulatory agencies overseeing the testing and need to
  have
  >a better understanding of the testing procedures.  As community activists
  we
  >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
  audit
  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
  analytical methods.
  
  >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,
  and that
  >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
  answer is.
  
  >Additionally, A week before the testing someone had overheard the
  Incinerator >owners, say that the testing should go well unless they have a
  "glass
  train". > Could someone explain the term glass train and why it would pose a
  problem
  ? > 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
  such
  >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.
  
  Sam McClintock
  Director, En-Vision Inc.
  mac@ensanity.com
  (919) 847-3688