SUCCESSFULLY DEMONSTRATING INCINERATOR PERFORMANCE WITH A PROBLEM POHC BY ACTIVE MANAGEMENT OF THE QUALITY ASSURANCE PROGRAM

摘要

Comprehensive performance tests (CPTs) employ the ratio of the amount of a chemical compound destroyed or removed to the waste feed rate of the same compound to demonstrate destruction and removal efficiency (DRE) using a strategically selected principal organic hazardous constituent (POHC). Among the factors considered in POHC selection are that the compound must be considered difficult to destroy, be reasonably available and safe to handle, and be measurable by defensible sampling and analytical techniques. EPA has published a "Problem POHC Directory" intended to provide details on the potential pitfalls inherent in several common chemicals that could be employed as POHCs. For example, methylene chloride is identified as a problem POHC in the directory because of its propensity to show up as a contaminant, its high volatility, and the difficulty of achieving conventional data quality objectives. Eli Lilly and Company (Lilly) selected methylene chloride as one of three POHCs to demonstrate the performance of a rotary kiln incinerator. To mitigate the acknowledged risks of using methylene chloride as a POHC, an actively-managed quality assurance program was implemented to train and monitor operator and contractor participant activities during the test. Lilly obtained outstanding methylene chloride DRE performance data and achieved all data quality objectives. The paper describes the detailed, upfront planning and active quality assurance management employed during that testing program as a guide for future use of methylene chloride and other similar problem POHCs.