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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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