SECTION NINE
Observations and Lessons Learned
system should be performed. The review should draw upon the vast quantity of material handling
information and experience available within the combustion industry.
Whenever cost and space allow, redundant systems should be implemented in order to keep the
incinerator operational. The incinerator cannot physically operate without certain systems online
(e.g., drag conveyors or pumps) and the incinerator must not be allowed to operate if certain
equipment is not operational per permit requirements (e.g., Continuous Emission Monitors
[CEMs]). Incinerator downtime can be costly because site personnel must be paid and equipment
rental fees are incurred whether the incinerator is operating or not.
Performing a clean burn prior to feeding hazardous waste to the incinerator can have the
following benefits:
Serves as a mechanical shakedown of the system;
Provides an opportunity to do performance testing on the CEMs; and
Provides an opportunity to debug any programming or control systems without the risk of
any sort of a release or labor-intensive decontamination prior to correcting any problems.
During the incinerator optimization stage and the trial burn tests, the incinerator should be
operated under a wide range of operating conditions (e.g., varied feed rate, kiln rotation speed,
and combustion temperature) to ensure that the permit limits allow the desired level of operating
flexibility.
OTHER LESSONS LEARNED
The USACE and the state regulatory agency were involved with a proactive, USEPA-lead public
relations effort that was implemented from the beginning of the project. This was achieved by
developing a public relations plan in conjunction with the local community.
Ninety to one hundred twenty days was allowed for state review of permit equivalency
documents, including the Trial Burn Plan.
The RFP specifications delineated which activities were construction-related and which activities
were service-related. Difficulties can arise when personnel working side-by-side on the same
equipment are paid different wages.
Staffing requirements for an incineration project are greater than the typical USACE construction
project. Required staff included an on-site project chemist, thermal incineration experts, office
engineers, project engineers, quality assurance staff, and an on-site authorized contracting
officer's representative. In addition, the contracting officer's representative was given more
authority to process changes so the changes could be incorporated in a timely manner.
A Construction Management Plan was developed that included the roles and responsibilities of
the participating organizations and individuals.
9-2
Slippery Chemical OU 3 Final RA Report
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