Introduction

During the last several months the Oak Ridge, TSCA incinerator has been the center of a raging controversy as to whether it is safe or whether it is the cause of the illnesses of several plant workers and a few nearby residents. The definition of the controversy is not clear. Those who are ill and their supporters allege that heavy metals and perhaps other unmeasured or unknown contaminants cause their illnesses by suppression of the immune system in unknown or unconfirmed ways. TSCAI and other workplace locations are alleged as sources of contaminants. On the other hand, DOE, LMES, and their supporters allege that the TSCAI emissions are less than one percent of the permitted levels, and are an improbable source of contaminants. A similar belief is held for the general workplace being well within the applicable standards. No one questions that these people are suffering from some health effects.

The differences are exacerbated by the accusations of a cover-up of the evidence, the manipulation of the local health care providers by LMES and DOE, shortcomings of the usual health care system, limitations of the workman's compensation system, a veil of secrecy imposed by privacy and just plain misunderstandings. A series of articles, perceived by many as biased and inflammatory, by the Nashville Tennessean has lead to the appointment of a Governor's Independent Panel to investigate the allegations and safety of TSCAI. Their independent consultant has issued a report. Threats of criminal lawsuits against individuals and the inception of civil lawsuits totaling $92.6 million of damages has not made things easier. A situation that demands trust on both sides finds nothing but distrust.

It is within this climate that TSCAI finds itself under assault: its data, its results and its motives questioned even by the governor of the state. Even the continued existence of TSCAI as a component of the DOE national environmental management program has been challenged. Early in the controversy, data was presented to show that TSCAI emissions were small compared to the permitted levels, and that transportation risks were small to modest. My review of this data indicated that TSCAI chemical emissions were about 0.6 percent of the permitted levels and about 2.4 percent of the permitted level of radiation (about 0.06 percent of the local background). These data are dismissed by opponents as being questionable due to the method of determination, i.e., based on test-burn destruction ratios and EPA approved methods, rather than on direct stack measurements in real time. There is also the constant undertone of fraud and cover-up, of increased waste burn rates during the night and other deceptions to increase throughput.

It is this controversy that prompted me to observe the CEM testing and at the same time the routine TSCAI operations. The CEM observations were accomplished by conversations with the manufacturer's personnel about the underlying physics of the method, the problems of adapting it to TSCAI, and the progress of the testing. The observations of routine TSCAI operations comprise a heavy dependence on informal conversations with TSCAI technical staff and more importantly with the shift operators as they go about their duties. There is very little dependence on formal interview but a use of informal inquiry while sitting in the control room. There has been no study of procedure books but much watching of the results of those procedures. There was little of asking for opinion but much listening to impromptu comments and exchanges among workers and between workers and supervisors. All of the foregoing is judged against several years experience as a chemical operator or supervisor of chemical operators. It took about 21 hours spread over several days.

The CEM Testing

There were three measurement methods under simultaneous testing at the same point in the TSCAI stack. The EPA Method #29 for heavy metals was also run as a reference method. In addition, the NESHAPS - National Emissions Standard for Hazardous Air Pollutants Sampling (for radionuclides) which is routinely and continuously run at the TSCAI was also running on a seven day schedule. The TSCAI was run on "normal" aqueous and secondary organic waste streams. The organic liquid waste was spiked continuously by four or five metered streams of heavy metals at three different levels. The spiking service was supplied by a consulting firm. The analytical devices of the methods are well established and the test is really for the effectiveness of the sampling interface to the very wet TSCAI stack.

The three CEM methods were:

1) ICP - Inductively Coupled Plasma by Thermo Jarrell Ash Corp. - This device comprises an iso-kinetic sampling mechanism and a conventional optical spectrometer using a plasma excitation of the heavy metals. The iso-kinetic sampling mechanism ensures that the stack sample presented to the spectrometer is truly representative of the stack flow. The excessively wet TSCAI stack presents a challenge to the sampling method that quite probably can be overcome by simple engineering changes.

2) LIBS - Laser Induced Breakdown by Sandia National Laboratory - This device comprises an intermittent, laser-induced plasma in the stack and a conventional optical, atomic emission spectrometer (AES) located adjacent to the stack. The actual readings represent the summation of several hundred individual readings. This eliminates the problems of iso-kinetic sampling but subjects the plasma to the stack environment where the excess water has a quenching effect on the plasma. This reduces the sensitivity of the method that in dry stacks takes advantage of the spectra from dry individual particles.

3) HEST - Hazardous Elements Sampling Train by Cooper Environmental Services - This device comprises an iso-kinetic sampler, a sample collector system of filters located beside the stack and a standard, x-ray fluorescence spectrometer remotely located. The sample turnaround time is about one hour. The condensation from wet stack gas can lead to modest sample line problems.

All manufacturers' personnel reported that the TSCAI provided an excellent, production environment test bed and were appreciative of the preparation and support given by the TSCAI personnel. They were particularly impressed that TSCAI was run in a stable configuration giving a reliable test of their equipment. Other than the usual minor problems arising from newly installed equipment the biggest problem was the effects of the very wet stack even though they had been aware of its existence. Everyone seemed optimistic about the outcome and was appreciative of the testing opportunity.

The TSCAI technical personnel were conversant about the methods being tested and the difficulties that might be expected from the wet stack. They were also conversant with other developments in the detection of heavy metals and other contaminants in both wet and dry stacks. They were paying a great deal of attention to the tests and made sure they were as effective as possible. The TSCAI operating staff was well aware of the significance of the tests and were determined to operate TSCAI as a stable test bed during the testing period.

Pending the comparison of the test data to the reference method results, it had all the appearances of a satisfactory test.

Inasmuch as all of the test personnel have had experience with many other incinerators as well as other thermal operations and stack emissions, I took the opportunity to turn the conversation to the operation of TSCAI. They all were of the opinion that TSCAI was a well-designed, well-run, conservatively fed incinerator that leaned over backwards to be safe.

The Routine Operation of TSCAI

On arrival at TSCAI, I received the obligatory visitor's tour of the installation. One is impressed by the cleanliness and orderliness of the actual operating area and the surrounding tarmac, building areas and ancillary equipment. Later, I toured the waste storage and handling areas and could view the waste storage tank farm. These too were close to spotless and were well organized. During the remainder of the week, I was free to wander anywhere outside of the areas restricted to protective clothing. I was introduced to the representatives of the testing organizations and received a brief description of their instruments. All invited me to return at any time, which I repeatedly did. I was then introduced to the technical staff, the shift operating staff, given a brief overview of the control systems and left in the control room to observe and wander. The operating staff was quick to make me welcome, answer any question and soon included me in their conversations. Tagging along, watching and listening reveal much about an organization.

The Control Room

The control room comprises the following:

1) Three large flow schematics with status lights representing the incinerator, the tank farm and sumps. Status changes are both visual and audible. Associated with these schematics are the remote buttons for the actual physical controls located on the equipment.

2) A bank of more than 50 electronic gauges and recording charts with set points, operating points and visual readout as necessary. These include temperatures, pressures, flow rates, pH measurements, % CO2, % O2 and ppm of CO. All the primary variables were at or extremely near the set points and the secondary variables were within about one percent of the set point.

3) Three video displays of the interior of the incinerator. One of these can provide a view of several locations, singly or in unison.

4) Three computer displays, two of which provided multiple screens appropriate to actual minute by minute operations and one of which logs current data and provides for the recall of several dozens of variables over selected time scales. The historic data can also be retrieved from disks and displayed. The computer system is impressive displaying the data in graphic as well as numeric form. Operators, technical personnel and managers look back through the data to overview the operations.

5) An on-line printer continuously logs many alarms, status points and status changes. Another printer is available for reports.

The range of information available to the operators is impressive, as is their ability to use the system. It has been suggested that in the dark of night, TSCAI has violated regulation by increasing throughput. Given the variety of recorded data, the ease with which it can be recalled and displayed, and the existence of mass balance data in the hands of other organizations, i.e., shippers, truckers and packers, it would be next to impossible to increase flow rates to dangerous levels in order to obtain throughput at the expense of emission safety. One would have to install a completely new software system, which falsified all recorded and displayed data. This would make operations almost impossible. Further it would be contrary to the ethic frequently expressed by many operators. Several operators remarked if you make a mistake on TSCAI, you may as well admit it because there is no way to hide it.

Operating Staff Morale

An important component of safe operations is the morale of the shift operations staff and its associated dedication to observing all the rules. In perhaps fifteen hours of informal conversation with the operating staff and instrument maintenance staff, I observed many indicators of good morale and awareness of safety regulations. Some of these are as follows:

1. The willingness to talk freely with a stranger, to volunteer descriptions of what they do and how they do it, to admit there are small things that happen that are not completely understood, voluntary statement of respect for the abilities of their supervisors and managers.
2. Clean, neat and orderly work place, lunchrooms and change house.
3. Pride in their ability to shutdown operations if something doubtful is happening and secure in the knowledge they will be complimented for acting.
4. A recognition that they work with potentially hazardous materials but do it in a way that is safe to themselves and to others. A belief that they are legally responsible for safe operation and a pride that they can discharge that responsibility.
5. Pride in the fact that TSCAI is a safe, unique facility and they can make a difference in the safe disposal of waste.
6. Meticulous attention to detail: one member merely stepped into the personal protection change area to get a pair of safety glasses and came out with rad checking of shoes and hands, two independent rad checks of ash drums, no unnecessary movement of containers into restricted zones, two persons attending to tank truck unloading where one would suffice.
7. Freely admitting the "rubber" tent storage area needed a little "straightening up" after its recent use.
8. A cheerful sharing of the workload and the informal banter of people who like to work together.
9. A concern for the good reputation of TSCAI.
10. A belief that their job at TSCAI is the best and their appreciation for the opportunity.
11. There was discussion of the ongoing training provided.

There were many other small signals of good morale and good operations. There was also enough variation in opinion to suggest the comments were sincere and not a party line.

Technical Staff Observations

Less time, about three hours, was spent with the technical staff. However this was sufficient to learn that they were conversant in the technical aspects of the TSCA incinerator as well as what was going on in the industry. Many of their remarks and actions demonstrated the respect for safe operation and the need to demonstrate this to the public. They expressed a need to continue joint development efforts such as the CEM testing. The staff appeared to have high morale and to appreciate the value of the shift operations staff.

Management Staff

Having previously spent time with the management staff, I spent very little time in this sector. However, I did confirm that the staff respect was mutual and that the commitment to safe operations was universal. The few questions I needed to ask were answered without reservation. The brevity of this section is due to the mode of observation and not to any perceived deficiencies in the management staff.

Observations of Operational Events

I have previously discussed the occurrence of the thermal release event while feeding liquid waste. On this occasion, I had opportunity to observe the combustion of solid waste. A "hat box" containing about 25 pounds of spent filter carbon was being fed to the kiln every three minutes. After one minute of combustion, the emission of flame and smoke was essentially complete and the waste reduced to slag from which visible emissions were minimal. The emitted smoke appeared to be completely consumed before it left the kiln for further combustion in the secondary chamber. Under these circumstances and with the immediate cessation of feed, the kiln content will contribute about three minutes or less of un-scrubbed waste off-gas to a thermal relief event. In as much as thermal relief event occurs about twice a year, this is a negligible amount of particulates and heavy metals.

Feed Irregularities

There are minor liquid feed irregularities, primarily a drop in feed rates due to the presence of solids in the control systems. With or without operator intervention, the rate is restored with only minor overshooting or under shooting which about averages out over a few minutes. This minor problem demands more operator attention than other abnormalities. On many feeds, even this does not happen and operations are somewhat dull.

Changing feed streams requires that operators reset a few of the controlled parameters, which takes a few moments. None of this significantly affects the completeness of combustion as measured by the CO monitors. At no time did I see the CO above 2-3 ppm and usually 0-1 ppm when the cutoff is around 100 ppm.

Plume Observations

I had several occasions to observe the TSCAI plume under a variety of weather conditions. Even under the best of observing conditions there was no trace of a particulate plume remaining after the water vapor plume had evaporated. Nor was there ever an odor of a plume nor was the installation covered by the dust typical of particulate plumes.

Environmental Observations

There were stands of pine, close to TSCAI, which were exposed to the stack emissions and which showed no signs of pine beetle infestation although there was some evidence of past infestations in isolated areas. There was no evidence of environmental pollution in the form of odors or accumulation of dusts.

Conclusions

1. TSCAI is a well and safely run incinerator whose emissions are well under, i.e., less than 1-2 % of, the permitted levels.
2. The TSCAI staff is competent and dedicated to safe operation before production. The integrity of the TSCAI operations and staff should be preserved in the forthcoming contractor changes.
3. TSCAI is deserving of the name "national resource" and can serve as such in meeting the ORR waste treatment needs.
4. DOE should redouble its efforts to portray the true nature of TSCAI to the public and press.