Issues of operation during a trial burn at a wet process kiln

摘要

Trial burns are a requirement under Section 40 CFR 270.22 and 270.66(g), in order to obtain a Part B Permit, yet their usefulness when applied to a cement kiln has to be questioned. The very features that make a cement kiln so good at thermal destruction, that of very high temperatures and a long residence time, and the fact that they must stay at those temperatures in order to make their product, I believe greatly diminishes, if not eliminates the need for many trial burn requirements. In addition, for many kilns, operating at conditions required of a trial burn can have a very costly consequence. A trial burn is something that I believe both the regulation agency and the HWDF industry as a whole should work to modify and better adapt to each particular industry. It needs to be done.