These COC Test Burns each required hundreds of man-hours of work, thousands of airline and auto travel miles and repeated risk of exposure to toxic chemicals during sample collection, transportation and analysis. All of these metals are deemed by the EPA to be toxic. The EPA knew from its own testing prior to the promulgation of the BIF regulation that the cement kiln system capture efficiencies were quite high and that the levels of emissions would be well within the health-based limits set in BIF, even at significant metal input rates. It was this knowledge, after-all, that underlies the determination of the feed rate limits that are a part of the Precompliance Certification requirements, feed rate limits that could not be exceeded during the COC Testing. The requirement to spike some of these metals, however, exceeded even that descriptor.
Beryllium is especially toxic but extremely rare in combustible wastes.
Yet the BIF regulation resulted in adding 700 pounds of this toxic metal to the environment. A similar statement can be made regarding hexavalent chromium. Additionally, there are essentially no organic hexavalent chromium compounds and few inorganic hexavalent chromium compounds that do not react with organic fuel constituents resulting in much less toxic trivalent chromium compounds. Added to this is the fact that there is no analytical technique for determining hexavalent chromium concentration in organic matrices, rendering the concept of hexavalent chromium feed rate limitations moot. Nevertheless, implementation of the BIF regulation placed facility personnel and COC Test Burn contractors at risk in handling hexavalent chromium spiking solutions.