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PROJECT
EXPERIENCE
Brief
descriptions of some Franklin Engineering projects are provided
below.
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SHORT MOVIE OF PICK AND PLACE ROBOT FOR HAZARDOUS MATERIAL
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HAZARDOUS
MATERIAL HANDLING SYSTEMS AND SPECIALTY MACHINERY
Industry:
Inorganic
Chemical Manufacturing
Project:
Phosphorus Recovery Plant
Large
amounts of elemental phosphorus were stored in water filled lagoons
at a former phosphorus manufacturing facility. Franklin Engineering
developed a process to recover the phosphorus-rich sediments and
concentrate the phosphorus for subsequent refining operations. We
performed bench scale testing and built a pilot plant from used
equipment to demonstrate the viability of the complete process.
The system employs dredging, size reduction, screening, classification,
and phase separation processes that operate under inert atmospheres.
The full scale production plant came on line in early 2000.
Industry:
Explosives Manufacturing
Project:
Propellant Strand Cutting
Propellant is
traditionally extruded into hundred foot long strands while in a
plastic state. Multiple strands are produced simultaneously and
the extrusion rate varies between strands. The strands are manually
fed into cutting machines that produce short lengths called grains.
This manual operation has a high labor cost and can expose the production
personnel to ether and nitroglycerine vapors. Franklin Engineering
developed an automated system to eliminate the cost and personnel
exposure associated with the manual operation. We first built a
device to process a single stand and prove the mechanical concepts
as well as the PLC and PC based control system. The single strand
unit was later scaled up to process nine strands simultaneously.
Industry: Inorganic Chemical Manufacturing
Project:
Automated Sediment Recovery Dredge
Franklin Engineering
designed a unique remote-controlled dredge to recover phosphorus-rich
sediments for neutralization in a slurry separation and treatment
plant. Once installed, access to this machine was very difficult
so reliability was critical to the project's success. The machine
utilized a sophisticated instrumentation and control system that
included radio telemetry and redundant controls.
Industry: Petrochemical Manufacturing
Project:
Bulk Liquid and Containerized Waste Storage System
A large chemical
manufacturer operates a captive incinerator for disposing of site-generated
waste. Recently promulgated state and federal regulations limited
the rate at which individual compounds could be burned so a precise
blending and tracking system was necessary to maintain incinerator
throughput. Franklin Engineering developed a blending and storage
plan to allow flexible operation of the entire bulk waste handling
system and then designed a storage tank and pumping system to meet
these needs. The system was designed to store and pump wastes with
a wide range of properties and blend these wastes for efficient
incinerator operation. We also designed an automated drum handling
system that included the same optimization program as the bulk waste
system.
Industry: Remediation/Emergency Response
Project:
Herbicide Spill Cleanup
Franklin Engineering
provided engineering support for a herbicide spill clean-up in the
Pacific Northwest that involved dredging and dewatering of contaminated
sediments. Our work began with a production and cost analysis of
the proposed dredging and slurry management system. Based on this
analysis, an alternative pump-down and dry excavation plan was developed
by the emergency response contractor to manage the majority of the
sediments. Franklin Engineering then evaluated the options for management
of the water from the dewatering and dredging processes. This evaluation
included the assembly of a pilot scale water treatment plant to
demonstrate candidate removal processes. The regulatory agencies
ultimately agreed to land application of this water and the client
was spared the cost of disposal at a commercial facility.
Industry: Organic Chemical Manufacturing
Project: Bulk Solid Waste and Ash Handling Systems for Incineration
Franklin Engineering was asked to evaluate the material handling
equipment and practices at a large incineration facility that burns
trash and other solid wastes. We were requested to consider safety,
operating and capital costs, and fugitive emissions control. Structural
and space constraints limited the available options, but several
viable concepts were developed along with preliminary equipment
specifications and drawings. The selected containerized solid feed
system consisted of a network of powered roller conveyors and turntables,
a scale for batch weighing of containerized solids, and an air lock
to introduce the material into the feed chute. The bulk feed system
consisted of a storage bin, grapple hook and auger feed system.
The same client asked Franklin to conduct a similar evaluation of
the ash handling system for the kiln. The existing system consisted
of a water seal that was dumped daily resulting in scheduled downtime,
production loss and frequent thermal cycling of the refractory.
Franklin Engineering evaluated several system upgrades, including
ash drag chain conveyors and ash hoes that are typically used for
this service. Due to spatial constraints and kiln configuration,
the final design recommended by Franklin was a modification to the
existing system which consisted of adding a second gate that would
maintain the water seal during the dumping of ash, thus eliminating
the need to shut down.
Industry: Aggregate Production
Projects:
Dredge Engineering
Franklin Engineering
provides engineering services to one of the nation's largest aggregate
producers. This client operates three dredges that include dedicated
sand and gravel separation plants. Our work primarily involves pump,
cutter drive, bearing, power transmission, and structural engineering.
A typical assignment began when the client started to experience
recurring failure of a $20,000 hydraulic motor under certain dredging
conditions. We developed a bearing system that absorbed the high
cutter thrust loads and thereby eliminated the motor failure and
subsequent loss of production. This same system was later incorporated
in their other dredges.
Industry:
Munitions
Manufacturing
Project:
Phosphorus Tank Replacement
Franklin Engineering
teamed with an industrial contractor to replace a tank and associated
piping used for transferring phosphorus to existing manufacturing
lines. Franklin served as the technical expert for the contractor
on this project. Franklin developed the work plan for removal of
the existing equipment and the site specific training program specifically
identifying the hazards pertaining to phosphorus that the contractor's
personnel would encounter while performing the work. Franklin personnel
were on site to witness the initial line flushing conducted by the
operator of the facility and during demolition of the existing equipment
by the contractor. In addition, Franklin provided the engineering
and drafting resources required to revise the drawings associated
with the system (P&IDs, system isometrics, plan & elevation
drawings).
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AIR
POLLUTION CONTROL AND COMBUSTION SYSTEMS
Industry: Organic Chemical Manufacturing
Project:
Air Pollution Control System Upgrade for Three Hazardous Waste Incinerators
A
major international chemical manufacturer operates three hazardous
waste incinerators at its southeastern U.S. facility - two rotary
kilns and one liquid injection unit with a combined capacity of
150 million Btu/hr. These incinerators burn over 2000 liquid and
solid waste streams. All three incinerators are being upgraded to
meet the recently promulgated MACT standards for hazardous waste
combustors. The existing gas handling systems, which include a waste
heat boiler and venturi scrubber, are being replaced in order to
reduce emissions of particulate, certain regulated metals, and dioxins/furans.
The new air pollution control systems include rapid gas quenching,
gas absorption and subcooling, and two-stage wet electrostatic precipitation.
Franklin Engineering's role in this $45 million project included
concept design, process engineering, start-up support, and performance
testing.
Industry: Pyrotechnics Manufacturing
Project:
VOC Removal
Franklin Engineering
conducted feasibility studies to determine the most viable alternative
to remove hexane from several vent streams at a new grassroots flare
manufacturing facility. Selection of the best alternative was made
more difficult by the batch operation of the facility and the non-continuous
operating schedule. After evaluation of all options, a new 25,000
scfm activated carbon adsorption unit with carbon regeneration was
selected. The unit was specified to have a removal efficiency of
98% under design conditions. This system includes a distillation
unit to recycle recovered solvent. Franklin Engineering's responsiblities
in this on-going project include all aspects of the installation
design, procurement support, construction management, and start-up
support.
Industry: Petrochemical Manufacturing
Project:
Air Pollution Control System Upgrade for Chemical Waste Incinerator
A major international
chemical manufacturer operates an 80 million Btu/hr rotary kiln
incinerator at its Texas plant. This incinerator is RCRA-permitted
to burn a variety of liquid and solid hazardous wastes. The facility
is being upgraded to meet the recently promulgated MACT standards
for hazardous waste combustors. The original gas handling system
included a waste heat boiler, quench, multi-stage inertial impaction
scrubber, packed tower absorber, ID fan, and stack. This system
failed to meet the MACT emissions standards for particulate, certain
regulated metals, and dioxins/furans. Franklin Engineering has extensively
re-designed the gas handling system to reduce these emissions and
to improve reliability and on-stream time. Major changes include
removal of the waste heat boiler, replacement of the quench, addition
of a direct-contact condenser/absorber to subcool the gas and impart
flux force/condensation scrubbing effects, and modification of the
ID fan to increase scrubber pressure drop. The project also included
significant modifications to the liquid waste tank farm and automation
of the drum waste handling system. Total project cost is $12 million.
Industry: Inorganic Chemical Manufacturing
Project:
Phosphorus and Phosphine Gas Combustion and Scrubbing Systems
Franklin Engineering
served as design engineer for a $7 million prototype facility to
recover elemental phosphorus from tailing ponds. This facility included
a rotary combustor to remove residual phosphorus from inert tailings
and a thermal oxidizer to destroy phosphine gas generated in the
refinement process. The combustion gases from both units were treated
to remove submicron P2O5 particulate using a high-energy free jet
venturi scrubber.
Industry: Hazardous Waste Disposal
Project:
Wet Electrostatic Precipitator Installation
A Gulf Coast
operator of a commercial hazardous waste incinerator contracted
with Franklin Engineering to provide turnkey engineering and construction
services for the installation of a new WESP to satisfy MACT requirements.
Our scope of supply included specifying a new induced draft fan
and designed ductwork, piping, foundations, and structural support
for this new 50,000 acfm unit. The WESP was installed within a tight
schedule to fit into a scheduled plant turnaround. Start-up was
uneventful and on schedule.
Industry: Explosives Manufacturing
Project:
Air Pollution Control System Upgrade for Two Explosive Waste
Incinerators
Franklin Engineering
personnel performed a turnkey retrofit of the burners and air pollution
control systems for two explosive waste incinerators at a U.S. Army
propellant manufacturing facility. The retrofit involved installation
of an evaporative cooler/fabric filter system between the existing
afterburner and wet scrubber. The upgraded system effectively reduced
submicron particulate and lead emissions. Our personnel were responsible
for all aspects of this $2.5 million project from concept design
through detailed engineering, construction, startup, trial burn,
and permitting.
Industry: Pharmaceutical Manufacturing
Project:
Incinerator Retrofit for Liquid Waste Firing
This project
involved the retrofit of a fixed-hearth, controlled-air incinerator
burning solid waste to be capable of also burning liquid wastes
from pharmaceutical manufacturing operations. Franklin Engineering
personnel were responsible for the process and detailed engineering
design, start-up assistance, trial burn, and RCRA permitting.
Industry: Chemical Weapons Demilitarization
Project:
Process Modeling for Chemical Agent Incinerators
Franklin Engineering
has developed material and energy balance computer programs to model
the operation of the U. S. Army chemical agent demilitarization
incinerators and associated air pollution control equipment. These
programs have been used to plan operating conditions and satisfy
regulatory requirements for a series of trial burns involving surrogate
materials, chemical agents (GB, VX, and mustard gas), and secondary
waste.
Industry: Remediation/Emergency Response
Project:
Contaminated Animal Carcass and Vegetation Incinerator
Franklin Engineering
worked as part of a four-company team to develop a concept design
of a transportable incinerator for disposal of contaminated animal
carcasses and/or vegetation. The system included size reduction
equipment, rotary kiln/afterburner combustion units, two-stage gas
cooling, and provisions for air pollution control equipment as needed.
The system is intended to provide quick response to potential outbreaks
of disease or chemical/biological contamination.
Industry: Pharmaceutical Manufacturing
Project:
Startup Support for Incinerator Retrofit
Franklin Engineering
provided engineering support to a major pharmaceutical manufacturer
that was commissioning new air pollution control equipment to achieve
compliance with the HWC MACT regulations. This facility operates
two hazardous liquid waste thermal oxidizers (each rated at 75 million
Btu/hr), a rotary kiln for solid waste disposal, and a RTO system
for VOC control. Franklin Engineering assisted in the commissioning
of a new APC system for the thermal oxidizers that consisted of
a quench, condenser/absorber, multi-stage venturi scrubber and final
polishing scrubber. We also participated in various on-site activities
including approval of new wastes streams to be destructed in the
thermal oxidizers and rotary kiln, writing operating procedures
for the new equipment, operator training, factory acceptance testing
of the new control system, and commissioning activities for the
new equipment.
Industry:
Conventional Weapons Demilitarization
Project:
Evaluation of Operating Strategies for Ordnance and Explosive Waste
Incinerator
Franklin Engineering
conducted a feasibility study for a client that operates a rotary
kiln and batch furnace to destroy outdated munitions and other explosives-contaminated
solid wastes. Current operating strategies involved operating only
one combustion unit at a time. Franklin Engineering developed heat
and material balances for various modes of operation and determined
that the two systems could be operated simultaneously if the batch
furnace was operated in a starved air mode. Franklin developed process
flow diagrams (PFDs) and piping and instrumentation diagrams (P&IDs)
of the combined system operation to define the controls and interlocks
required for simultaneous operation of the two combustion systems.
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CHEMICAL
PROCESS AND OTHER MANUFACTURING PLANTS
Industry:
Inorganic Chemical Manufacturing
Project:
General Engineering Services
Franklin
Engineering served as design engineer for a facility to recover
elemental phosphorus from tailing ponds. The full-scale production
plant came on line in early 2000. Franklin Engineering continues
to provide general engineering support. Our responsibilities include
process capacity optimization and de-bottlenecking, engineering
and design services for new system installations, process and controls
system troubleshooting, and upkeep of plant drawings and other facility
documentation.
Industry: Explosives Manufacturing
Project:
Chemical, Mechanical, and Electrical Engineering Support
This client
manufactures propellant for commercial and military applications.
Franklin Engineering supplements the in-house engineering staff
for capital project work on a regular basis. We are able to provide
whatever engineering discipline the project requires on an as-needed
basis. This arrangement eliminates the need for the client to keep
several specialists on staff and allows the client to capitalize
the cost of our services.
Industry: Synthetic Gypsum Recovery
Project:
General Engineering Services
This client
recovers large quantities of calcium sulfate from coal fired power
plant flue gas desulfurization (FGD) scrubber slurry and reprocesses
this material into synthetic gypsum for use as wallboard manufacturing
raw material. Franklin Engineering provides ongoing engineering
and design services for multiple existing plants and new plant projects.
Our responsibilities include process development to complement the
client's in-house process engineering, ongoing process optimization,
equipment specification, plant layout, piping design, instrumentation,
purchasing support and construction support activities including
preparation of construction specification packages, specifications,
contracts, and contract bidding, and construction oversight.
Industry:
Solid Waste Recycling
Project:
Plastic Bottle Recycling
Franklin Engineering
designed the electrical power and control systems for a large high-speed
plastic bottle reprocessing center. Our work included complete specification
and design of the motor control center and PLC-based control system
as well as programming and commissioning of the system. The system
was integrated into an existing operating facility, which required
an extensive mechanical and electrical interface program.
Industry: Powdered Metal Processing
Project:
General Engineering Services
This client
receives recycles scrap metal and produces powdered metals for use
in castings. This process involves melting scrap in an electric
arc furnace and producing powdered metal using high-pressure water
blasting of the molten metal stream. Franklin Engineering provides
general engineering services including the design of a mezzanine
floor expansion, load capacity analysis of existing platform structures,
and process material hopper volume calculations and level calibration
charts.
Industries: Thin-Film and Rubber Products Manufacturing
Projects:
PSM Support
Two well established
local manufacturers needed updated plant drawings to satisfy Process
Safety Management requirements. Franklin Engineering prepared manufacturing
floor drawings, piping and instrumentation diagrams (P&IDs),
and utility surveys for these clients.
Industry: Organic Chemical Manufacturing
Project:
Pumping, Piping, and Control System Upgrades
We provide mechanical
and electrical support to a local chemical manufacturer that operates
several unique batch processes. Our work includes pumping and piping
systems as well as instrumentation and control systems designed
for the explosive atmosphere inside the manufacturing facility.
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ENVIRONMENTAL
ENGINEERING AND PERMITTING
Industry:
Organic Chemical Manufacturing
Project:
Miscellaneous Organic NESHAP Compliance Strategy
Franklin
Engineering is working with a specialty organic chemical manufacturing
facility to develop a compliance strategy for the Miscellaneous
Organic NESHAP (MON). This project includes evaluation of treatment
alternatives for Group 1 wastewater streams from several batch miscellaneous
organic chemical processing units (MCPUs). Preliminary testing for
utilization of the existing wastewater treatment system as the control
technology for Group 1 wastewaters has been completed. Additional
testing is planned to assure compliance at various organic loadings
and aeration basin operating conditions. Evaluation of control alternatives
for the Group 1 batch process vents will also be conducted as part
of this project as well as implementation of other MON requirements.
Industry:
Organic Chemical Manufacturing
Project:
Trial Burn Plan and Human Health Risk Assessment for RCRA Permitted
Boilers
Franklin Engineering
provided a trial burn plan for seven coal-fired boilers co-firing
hazardous waste and wastewater treatment plant biosludge. These
boilers are regulated as hazardous waste treatment units (BIFs)
under RCRA, and will be subject to the proposed final HWC MACT standards
for solid-fired boilers. The trial burn plan was developed to meet
the requirements of RCRA, while simultaneously meeting the requirements
of the HWC MACT standard. The trial burn plan included a detailed
review of the waste materials handled at the facility, a test protocol
that ensures the establishment of workable permit limits, and a
detailed evaluation of past test data to determine optimum operating
conditions and feedrates which would allow the facility to meet
the HWC MACT emission standards. A separate "Risk Burn"
test plan was prepared and executed for risk assessment data collection
purposes. A quality assurance project plan (QAPP) was also developed
for the Trial Burn and Risk Burn sampling and analytical programs.
In conjunction with the revised trial burn and risk burn plans,
Franklin Engineering prepared a risk assessment work plan that detailed
the protocols to be used for the risk assessment. The risk assessment
will be conducted to evaluate the risk to human health from a large
number of quantified volatile and semi-volatile organic chemicals,
including dioxins/furans, PCBs, heavy metals, and polynuclear aromatic
hydrocarbons. The health effects of heavy metals, including arsenic,
cadmium, lead, chromium, nickel, and mercury, will also be evaluated.
The health effects will be modeled using EPA recommended protocols
and multiple exposure pathways.
Industry:
Pyrotechnics Manufacturing
Project:
Permitting and Environmental Compliance Program Development
Franklin Engineering reviewed site assessment documentation, developed
the air construction permit, and developed the construction stormwater
management plan for a new pyrotechnics manufacturing facility located
at an existing U.S. Army ammunition plant. This project involved
negotiation with the site operator and state regulatory personnel
to facilitate an expedited approval of the permit to meet the proposed
construction schedule. Additionally, Franklin Engineering is developing
the environmental compliance program for the new facility. This
includes Title V permitting and developing procedures for compliance
with the Miscellaneous Organic NESHAP (MON), negotiating a sewer
user agreement with the site operator for wastewater discharges,
complying with the RCRA hazardous waste regulations (generator and
disposal), development of a spill prevention, containment and countermeasure
(SPCC) plan, and developing procedures for meeting SARA and EPCRA
reporting requirements. A stormwater pollution prevention plan (SWPPP)
for industrial discharges was prepared for this facility and subsequently
approved by the State. All these procedures are being developed
to accommodate eventual ISO 14001 certification.
Industry: Organic Chemicals Manufacturing
Project:
HWC MACT Compliance and Human Health and Ecological Risk Assessments
The facility
operates an on-site hazardous waste incinerator, which is subject
to the HWC MACT standard. Franklin Engineering performed an initial
performance test (miniburn) to determine the compliance status of
the facility and recommended areas for improved emissions control.
Subsequent miniburn testing was performed to prove the efficacy
of the upgraded air pollution control equipment. Franklin Engineering
developed the compliance strategy, HWC MACT comprehensive performance
test (CPT) plan, and other recordkeeping and reporting documentation
required by the HWC MACT standard. Franklin Engineering managed
the CPT and prepared the CPT report. The CPT successfully demonstrated
compliance with the interim HWC MACT standards for all pollutants.
The facility is also required to perform a human health risk assessment
and screening level ecological risk assessment for RCRA compliance.
Franklin Engineering prepared the risk assessment protocols and
"risk burn" test plan to collect emissions data for input
to the risk model. The assessment protocols were approved by the
state agency, with minimal changes required. Franklin Engineering
has also provided process engineering support to the facility for
evaluating the emissions control and incineration equipment, developing
recommendations for improving system performance and throughput,
and ensuring compliance with the HWC MACT requirements for control
systems and recordkeeping.
Industry: Surface Coating / Small Parts Manufacturing
Project:
Clean Air Act Title V Operating Permit and Recordkeeping System
Franklin Engineering
staff prepared the Title V operating permit application for a facility
that manufactures small metal garment fasteners. This facility is
classified as a major source under the Clean Air Act for emissions
of volatile organic compounds (VOCs) and hazardous air pollutants
(HAPs). The facility utilizes a variety of surface coating processes
including electroplating, lacquer coating, and painting, as well
as utilities such as boilers and wastewater treatment equipment.
As part of the permitting process, a facility-wide emissions inventory
was developed and estimates of emissions of regulated pollutants
from all affected air pollution sources were calculated. Existing
construction and operating permits were updated to reflect current
operations, and the Title V Permit application was compiled to include
all air permit requirements in one consolidated document. Franklin
Engineering developed a new environmental recordkeeping system for
the facility that included a complex computerized database. The
custom database program calculates the VOC and HAP emissions from
paints, based on paint usage data and chemical composition of the
pigments, solvents, and other components of the paint. The database
maintains the most current color formulations by tracking the usage
of several hundred paint pigments, which can be combined into several
thousand different color combinations.
Industry: Explosives Manufacturing
Project:
RCRA Part B Permit Renewal, Trial Burn, Risk Assessments, and HWC
MACT Compliance
As part of a
RCRA permit renewal, Franklin Engineering was retained to review
existing permit documentation and to develop a RCRA trial burn plan
and other Part B permit application documents. Franklin also developed
protocols and conducted both a multi-pathway human health risk assessment
and screening level ecological risk assessment based on EPA's 1998
Human Health Risk Assessment Protocol guidance and the 1999 Screening
Level Ecological Risk Assessment Protocol for Hazardous Waste Combustion
Facilities guidance. Franklin Engineering was successful in executing
both human health and ecological risk assessments that met all applicable
exposure guidelines, resulting in no additional risk-based RCRA
permit limits for the facility. Franklin Engineering was responsible
for the subsequent coordination and on-site execution of the RCRA
trial burn. The RCRA trial burn plan was designed to accomplish
both trial burn and risk assessment emissions testing goals. Franklin
Engineering also developed the HWC MACT compliance strategy for
this facility that included partial utilization of the RCRA trial
burn results as data in lieu of conducting an initial comprehensive
performance test (CPT). A mini-burn was conducted to verify that
emissions goals could be met at the desired operating conditions.
The trial burn resulted in a larger operating temperature window
and significantly higher waste feedrates for the two incineration
units at this facility. Franklin Engineering continued to support
the facility in the development of required HWC MACT plans including
startup, shutdown and malfunction plan, automatic waste feed cutoff
plan, and continuous monitoring system quality assurance plan. Franklin
also developed the comprehensive performance test plan for those
components not covered by the data-in-lieu document and the documentation
of compliance (DOC).
Industry: Large Appliance Manufacturing
Project:
Clean Air Act Title V Operating Permit Renewal
Franklin Engineering
provided regulatory support to a large appliance manufacturer during
the facility's Title V permit renewal. The support included confirmation
that required monitoring and recordkeeping (per the existing permit)
were being conducted properly; identification of changes to facility
operations since issuance of the original permit; identification
of new and future regulatory requirements that were potentially
applicable (particularly the Large Appliance Manufacturing MACT);
and assisting in preparation of the required documentation necessary
for the Title V re-permitting effort.
Industry: Chemical Weapons Demilitarization
Project:
Agent Trial Burn Execution and HWC MACT Compliance
Franklin Engineering
provided comprehensive VX and Mustard agent trial burn planning
and engineering support to a US Army facility that operates four
incinerators for the destruction of chemical warfare agents and
decontamination of munitions. Extended on-site engineering support
was provided to prepare and execute a VX trial burn for each incinerator.
Our responsibilities included planning the detailed logistics required
for munitions handling and agent processing, preparing trial burn
management plans and operating procedures, executing mini-burns
to demonstrate metal emissions compliance, detailed planning and
over-sight during execution of the trial burn, evaluation of planned
feeds and potential emission issues, and evaluation of air pollution
control system performance related to emissions of mercury, other
metals, and particulate matter. Franklin Engineering also developed
the strategy for facility compliance with the existing RCRA permit
and the Interim HWC MACT standard. The following documents were
prepared for the incinerators to support permit compliance for Agent
VX and Mustard processing: VX agent trial burn reports, Mustard
trial burn plans for RCRA compliance , Mustard HWC MACT comprehensive
performance test (CPT) plans, HWC MACT data-in-lieu reports based
on VX trial burn data.
Industry: Light Weight Aggregate/Cement Manufacturing
Project:
OSHA Process Safety Management
Franklin Engineering
performed PSM applicability determinations, reviewed existing PSM
documentation, and developed additional related information for
two separate hazardous waste fuel blending facilities, one of which
was located at a light weight aggregate manufacturing facility.
This information included process descriptions, process safety information,
and process hazard analysis (PHA). Information pertaining to the
process and the safety information was compiled and placed into
accessible reports and a PHA was conducted. Action items were identified
and the PHA was documented in a formal report. As part of this process,
Franklin Engineering also developed as-built P&IDs for one facility
and electrical area classification drawings for both facilities.
Industry: Organic Chemical Manufacturing
Project:
RCRA Comparable Fuels Exemption/Exclusion
Franklin Engineering
performed a preliminary applicability determination for a waste
product using historical analyses and process chemistry information.
The client wished to obtain a comparable fuels exclusion so that
the waste material could be reused or sold as a fuel. Preliminary
review determined that the waste could meet exclusion specifications.
Follow-on work involved development of a sampling and analysis plan,
coordination of sampling and analysis activities, and final incorporation
of all process knowledge, sampling and analytical protocols, and
laboratory results into a waste analysis plan (WAP), according to
the requirements of 40 CFR 261.38.
Industry: Light Weight Aggregate/Cement Manufacturing
Project:
Clean Air Act Risk Management Program Audits
Franklin Engineering
performed RMP compliance audits for three separate hazardous waste
fuel blending facilities related to light weight aggregate and cement
manufacturing. The audits included a site visit, review of the existing
RMP for each facility, and review of the RMP-required records at
each facility. As part of the audits, sections of the RCRA permits
and/or PSM documents were reviewed for RMP applicability and consistency.
Upcoming changes to facility operations which could potentially
affect the RMP were identified for inclusion in the RMP. The reports
on the audits included recommendations for recordkeeping and other
RMP-related items.
Industry: Commercial Hazardous Waste Disposal
Project:
HWC MACT Compliance Plans
This facility
operates three incinerators, which are subject to the HWC MACT standard.
Franklin Engineering worked closely with the facility's operations,
maintenance, engineering, and environmental personnel to develop
the plans, procedures, and recordkeeping program for ongoing compliance
with the HWC MACT requirements. These plans and procedures included
a Startup, Shutdown, and Malfunction Plan (SSMP), Operation and
Maintenance Plan, Quality Assurance Procedures for the Continuous
Emissions Monitoring System, Automatic Waste Feed Cutoff Plan, Emergency
Safety Vent Operating Plan, and Continuous Monitoring System Quality
Assurance Program. The plans and procedures were developed with
the goal of minimizing the compliance burden, while still meeting
the letter and intent of the requirements. To this end, existing
facility procedures and practices were utilized to the extent possible.
Industry: Light Weight Aggregate/Cement Manufacturing
Project:
RCRA Subpart CC Tank Inspections
Concurrent with
the requirements of 40 CFR 265.1085, Franklin Engineering performed
inspections on hazardous waste storage tanks with Level 1 and Level
2 controls. As part of these inspections, determinations were made
regarding visual defects and organic vapor leaks. Following the
visual inspections and vapor monitoring, Franklin Engineering prepared
reports to document the inspections, according to the requirements
in the Subpart CC regulation. Franklin Engineering has performed
these annual inspections for a number of facilities for several
consecutive years.
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