SECTION SEVEN
Operations and Maintenance Activities
The Risk Assessment Report and associated risk analysis were complete in January 1998, at
which time the USACE notified H&S Consultants to prepare for the operation phase. In late
February 1998, a clean burn demonstration was performed to ensure that the thermal destruction
facility (TDF) was mechanically capable of performing during the Operations Phase. On March
4th, with the clean burn successfully complete, and with concurrence from USEPA and USACE,
the Operation Phase commenced.
With-in several days of the Operation Phase concerns were raised over whether dust was
entrained in the steam generated from the thermal process and whether, if entrained, it was
leaving the site boundary. Several members of the project team including USEPA, TNRCC,
USACE, and H&S Consultants inspected the process and determined that there was no dust
leaving the site boundary, but that modifications could be made to help alleviate the dust
concern. The first effort was to install a hood equipped with mist spray nozzles on the ash-
receiving bin. The use of mist nozzles in the ash-receiving bin knocked out dust that was
entrained in the steam. The second effort was to partially enclose the fly ash building. This
allowed additional residence time in the building for steam to settle. The first two efforts were
implemented immediately. The third effort included locating a steam scrubber that could be
installed as final precaution to scrub the steam of any entrained dust. By the end of April 1998, a
steam scrubber was mobilized to the site, modified for the site-specific application, and installed
in the ash-receiving bin.
In early April 1998, after preliminary kiln refractory brick repairs failed, a decision was made to
re-line the kiln with a castable refractory. Installation of the new refractory took place during the
last three weeks of April and the first week of May. The Operation Phase resumed during the
first week of May 1998.
As per the TNRCC Air Equivalency Document and the Trial Burn Plan, Operation Phase Stack
Testing was performed. Once per month for the first three months of operations stack testing
was performed for dioxin and Furan analysis. Once per quarter for the duration of the project
stack testing was performed for particulate and metals analysis.
During the Operation Phase several statistical operating goals were established. A "utilization
percentage" was calculated to illustrate performance of the TDF as compared to a benchmark
operating rate of 47 tons per hour. A "utilization average" was calculated to summarize the
performance of the TDF. An "availability percentage" was calculated to illustrate the time the
TDF was physically available to operate. An "availability average daily tons" was calculated to
summarize the TDF production during available operating hours. An "availability TPH" was
calculated to summarize the TDF production rate during available operating hours. The
percentage of ash requiring additional thermal treatment was calculated and compared to a
project goal. The following table summarizes the Operation Phase performance versus
established goals.
7-1
Slippery Chemical OU 3 Final RA Report
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