PROJECT EXPERIENCE

Brief descriptions of some Franklin Engineering projects are provided below.

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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.


I
ndustry: 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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