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W.R. (Bill) Schofield, PhD, PE
Project Manager & Sr. Consultant

 

Functional Summary:
Dr. Schofield has overall responsible for ESS projects from initial project definition; project cost estimating; proposal preparation; project planning including equipment selection; spiking materials specification and preparation; overall project scheduling; off-site technical & trouble-shooting support to ESS Technicians during on-site spiking efforts; and spiking data review and report preparation.

 

Qualifications Summary:
Dr. Schofield is a chemical engineer (BS & MS) and statistician (MS & PhD) with more than 34 years of experience in environmental engineering; operations, and plant support engineering; R&D, and product development; and marketing, primarily in the petrochemical and hazardous waste management industries. He has spent more than 22 years in the engineering and regulatory areas of hazardous waste combustion and more than 18 years experience in operating plants in the chemical manufacturing and hazardous waste management industries.


During his career, Dr. Schofield has:

  • Completed more than 1,500 technical, regulatory, operations, and economic reports/studies/plans which include feasibility; engineering; and regulatory compliance systems, plans, position papers, audits, and permitting applications; especially where economic, engineering, regulatory, and/or market issues interplay.
  • Conceived and developed or contributed to the development of several innovative spiking approaches which are standard practices in the industry today.
  • Served as session chair at various national and international hazardous waste combustion conferences, and has authored more than 35 publications in these areas;
  • Consistently Produced Industry Leading Studies and Documents and Developed a Wide Range of Innovative Solutions to Challenges He Has Encountered Throughout His Career; and
  • A Professional Engineer License in Texas and has been on the adjunct facility of the University of Houston-Clear Lake, and the University of Texas, School of Public Health, Houston Health Science Center where he has taught various courses on hazardous waste management in the postgraduate programs.

 

Education

PhD Statistics Virginia Tech Blacksburg, Virginia 1972
MS Statistics Virginia Tech Blacksburg, Virginia 1971
MS Chemical Engineering Clemson University Clemson, South Carolina 1969
BS Chemical Engineering Clemson University Clemson, South Carolina 1966



BSPE - 1995-Present
LaPorte, Texas.
Sr. Consultant


Responsibilities Include:
Providing specialized hazardous waste combustion related engineering and regulatory & testing services to the chemical and pharmaceutical manufacturing industries.


DRE Environmental Services, Inc. - 1995
Nashville, Tennessee
Vice President, Regulatory Affairs,


Responsibilities Included:

  • Principal in charge of health, safety, and environmental compliance for this firm which specialized in engineering and regulatory services for HWC units.
  • Responsible for developing and implementing a QA/QC program and staff training program to upgrade the quality of the firm's work products.
  • Provided senior consulting services to staff and clients on engineering and regulatory projects for the waste combustion industries.

 

DRE Southwest, Inc. - 1993-1995
Kemah, Texas
President


Responsibilities Included:

  • Opened, managed, and expanded this operation to 1995 billings of approaching $1.5 million.
  • (See following pages.)

 

Schofield Environmental Associates - 1991-1993
Kemah, Texas
Principal


Responsibilities Included:

Project management, primary author, and other lead roles for a number of BIF compliance, RCRA permitting/engineering projects for, among others, Olin Chemicals (now Arch Chemicals, CoPC, CTN/CTP, CoC tests and documents, WAP, etc.), Mobil Chemical (CoC document, test coordination), and Chemical Waste Management (economic analysis for a proposed RCRA storage/ processing facility). The Olin CoPC required RE estimates of all BIF constituents at each APCS-type unit in a multi-unit manufacturing operation which removed BIF constituents from the process gas stream.


Chemical Waste Management - 1986-1991
Port Arthur, Texas


Technical Manager (1987-1991), Regional Incineration Marketing Manager (1986-1987)


Responsibilities Included:

  • Was responsible for development of the initial financial analysis and marketing services for a world-scale commercial RCRA/TSCA incinerator.
  • Project managed RCRA and TSCA trial burns to demonstrate the performance of state-of-the-art combustion and air pollution control systems.
  • Held leadership role in successful and innovative effort to minimize impact of slagging on incinerator availability and through-put which produced a 10:1 benefit: cost ratio.
  • Held numerous project management roles including RCRA and TSCA trial burns, and LDR Certifications Program for treatment Residues.
  • Proposed and managed the development of a unique treatment process for managing 1.5 MM gallons of Dinoseb-contaminated water without incineration at an estimated savings of >$1.5 MM.
  • Established rigorous regulatory compliance system for all functions (no NOVs or regulatory discrepancies ever cited for responsibility area) and developed an innovative residual certification protocol which was adopted throughout the Chemical Waste Management incineration system with no regulatory questions and a savings estimated at >$1 MM/year/site.

 

J. M. Huber Corporation 1982-1986
Borger, Texas


Manager, Marketing and New Product Development, and AER Pilot Plant Manager

  • Was sole author of RCRA and TSCA permit applications for Huber's prototype high temperature facility. Received RCRA permit within 16 months and TSCA permit within 12 months of application submission. The RCRA permit was the nation's first RCRA permit ever granted allowing dioxin treatment.
  • Obtained (in twelve months) the nation's fifth TSCA (PCB) permit.
  • Provided process engineering ideas and technical leadership which increased DRE values for Huber's process from 99% to 99.9999999% within three months.
  • Directed dioxin treatment demonstrations at Borger, TX (1984), Gulfport, MS (1985), and the world's first field demonstration of dioxin treatment at Times Beach, MO (1984).

 

1966-1982:

Additionally, Dr. Schofield has more than 14 years of engineering & operations experience with EPA and several major chemical manufacturers including Westinghouse, Eastman Chemicals, and Air Products and Chemicals.


Registration/Certification:

  • Registered Professional Engineer, Texas


Conference Chairs:

  • 2000, 1999, 1998, 1997, 1996, 1995, 1994, and 1993 Incineration Conferences, University of California, Chair/Co-Chair
  • 1993 AWMA Annual Conference, Co-Chair, Dioxin and Furan Formation and Control

 

Publications and Presentations (Partial List):
Schofield, W.R., Ron Bastian, and Terry Schomer, “Statistical Demonstration of Compliance with Feed Rate Limits,” Presented at the 2002 IT3 Conference in New Orleans, Louisiana.


Cudahy, James, Shelly Forbes, Carrie Wintersteen, and W. R. Schofield, “The HWC Phase II MACT and Waste Energy Recovery,” Presented at the 2002 AWMA BIF Specialty Conference.


Schofield, W.R., and Terry Schomer, “Statistical Demonstration of Compliance with HWC MACT Feed Rate Limits,” Presented at the 2001 IT3 Conference in Philadelphia, Pennsylvania.


Schofield, W. R., and Anthony R. Eicher, “Risk Burn/Risk Assessment Database-Early Results,” Presented at the 2000 IT3 Conference in . Third in a series of three papers presented at this conference in 1998, 1999, and 2000.


Schomer, T. L., W. R. Schofield, and D. Gonzales, An Innovative Approach for Meeting the HWC MACT Standards Utilizing the ‘Fast Track’ Regulations,” Presented at the 1999 IT3 Conference in .


Schofield, W.R. and Anthony R. Eicher, “Trends in Risk Assessment Results in Texas,” Presented at the 1999 IT3 Conference in .


Schofield, W.R. and Anthony R. Eicher, “Trends in Risk Assessment Results in Texas1,” Presented at the 1998 IT3 Conference in .


Schofield, W.R., “Conducting a BIF Certification of Compliance Test on an Integrated Multiple Combustor, Multiple Air Pollution Control Device,” Presented at the 1997 International Incineration Conference in Oakland, California.


Schofield, W.R., et al, “Conducting the Maximum Waste Feed Rate, Minimum Combustion Temperature Test Condition for Boilers Which Burn High BTU Wastes - A Case Study,” Presented at the 1997 Incineration Conference in Oakland, California.


Neuman, Barry S. and Schofield, W. R., “EPA’s Proposed Comparable Fuels Exemption under RCRA: Does It Spell Relief?” Bureau of National Affairs, Dec. 13, 1996 (0013-9211/96).


Schofield, W.R. and Barry S. Neuman, “EPA’s New Comparable Fuels Exemption,” Presented at the 1996 International Incineration Conference in Savannah, Georgia.


Schofield, W.R., Ron Copeland, James Leitheiser, and John Schroer, “EPA’s Evolving Guidance on Waste Testing Frequency and Its Impact on Selected BIF Units,” Presented at the 1996 International Incineration Conference in Savannah, Georgia.


Schofield, W.R., et. al., "De-bottlenecking an In-House Liquid Incinerator by Process Analysis and Miniburn Testing," Presented at the 1995 International Incineration Conference, Seattle, Washington.


Schofield, W.R., et. al., "Designing Trial Burns to Provide PIC and BIF Metals Emissions Data for Comprehensive Risk Assessments," Presented at the 1995 AWMA BIF Specialty Conference, Kansas City, Kansas.


Schofield, W.R., and Maynard Engler, "Designing Trial Burns to Minimize Ongoing Waste Analysis Cost," Presented at the 1995 International Incineration Conference in Seattle, Washington.


Schofield, W.R., and John Herron, "EPA's New Policy for Hazardous Waste Combustion - What Does It Mean To You?" Presented at the 1994 International Incineration Conference, Houston, Texas.


Schofield, W.R., "Forewarned is Forearmed: What You Can Do To Minimize Compliance Problems and Costs," Presented at the 1994 Combustion Policy Seminar sponsored by DRE Environmental Services, Inc., Houston and Austin, Texas.


Schofield, W.R., and L. Weitzman, "Metal Dispersion Spiking Systems for RCRA Trial Burns," Presented at the 1993 BIF Specialty Conference, Clearwater, Florida.


Schofield, W.R., et. al., "Metal Spike Approaches for Incinerator Trial Burns - A Comparative Analysis," Presented at the 1993 International Incineration Conference, Knoxville, Tennessee.


Schofield, W.R., John Lutzman, and Gene Patterson, "A Survey of Slag and Slag Avoidance Techniques with Emphasis on Methods to Control Melt Temperatures," Presented at the 1992 International Incineration Conference, Albuquerque, New Mexico.


Schofield, Bill, John Lutzman, and Gene Patterson, “The Use of Chemical Additives to Reduce the Impact of Slag Formation in Hazardous Waste Incineration,” Cover/featured article for Hazardous Materials Control Magazine, September/October 1992, Volume 5, Number 5.


Schofield, W.R., et. al., "The Use of Chemical Additives to Reduce the Impact of Slag Formation in Hazardous Waste Incineration - Four Case Studies," Presented at the 1991 AWMA BIF Specialty Conference.


Schofield, W. R., and John Kolopanis, “Certification Protocol for Meeting the [40 CFR 268 Land Ban] Organics Treatment Standards for Incineration Ash,” Presented at the 1991 International Incineration Conference in Knoxville, TN.


Schofield, W. R., John Kolopanis, and Teresa Johnson, “Certification Protocol for Meeting the [40 CFR 268 Land Ban] Organics Treatment Standards for Incineration Ash,” Presented at the AWMA 1991 Annual Meeting in Vancouver, British Columbia.


Schofield, W.R., W.V. Walls, and Thomas Jones, "The Effect of Kiln Temperature on DRE and Organics Concentrations in Incinerator Ash," Presented at 1991 Hazmat South, Atlanta, Georgia.


Schofield, W.R., J. Levy, and R. Vingris, “Additional Hazardous Waste Incineration Capacity Coming On-Line,” Presented at the 19901 Hazmat Conference , Washington.


Schofield, W. R., “Supply – Demand Analysis for US Based Commercial Hazardous Waste Incineration Capacity1,” presented at 19871 Hazmat1, Washington, DC.


Schofield, W. R., et. al., “Dioxin Destruction Demonstrations with the AER High Temperature Pyrolysis Process1,” presented at 1985 Hazmat Europa, Hamburg, West Germany.


Schofield, W.R., et. al., “The Use of the High Temperature AER Pyrolysis Process for Destroying Organic and Encapsulating Inorganic Hazardous Wastes1,” Presented at the 19851 Hazmat Conference1, Washington.
Schofield, W. R., et. al., “The Use of the High Temperature AER Pyrolysis Process for Destroying Organic and Encapsulating Inorganic Hazardous Wastes1,” AIChE Magazine, 19841.


Schofield, W.R., et. al., “The Use of the High Temperature AER Pyrolysis Process for Destroying Organic and Encapsulating Inorganic Hazardous Wastes1,” Presented at the 19841 Hazmat, Washington.


Schofield, William R., and Krutchkoff, Richard G., “Stochastic Model of Dynamic Eutrophic Estuary,” Journal of the Environmental Engineering Division, ASCE, Vol. 100, No. EE3, Proc. Paper 10578, June, 1974, pp.613-628


Schofield, William R., and Krutchkoff, Richard G., “Stochastic Model for a Dynamic Ecosystem,” Bulletin 60, Water Resources Research Center, Virginia Polytechnic Institute and State University, Blacksburg, Virginia, 1973.


Schofield, William R., and Krutchkoff, Richard G., “Stochastic Model of BOD and OD in Segmented Estuary,” Journal of the Sanitary Engineering Division, ASCE, Vol. 98, No. SA5, Proc. Paper 9296, October, 1972, pp. 745-762.


Krutchkoff, Richard G., Schofield, William R., et. al., “Stochastic Models for Water Quality Management,” Water Pollution Research Series 16090 DUH 02/71, Stochastics, Inc., GPO, Washington, D.C., Stock No. 5501-0104, 1971.


SPIKING INNOVATIONS


Dr. Schofield conceived of and developed and/or contributed to the development of a number of specialized spiking techniques for unusual spiking circumstances and/or challenging waste applications. Several such techniques are briefly described here:


1. Spiking Waste Streams Containing Anhydrous HF:


The addition of even minor amounts of water to an anhydrous HF waste stream results in an extremely aggressive and corrosive material. Dr. Schofield developed an ash & metals spiking approach that did not involve addition of water (at greater than low ppm levels) to these streams; thus, avoiding expensive and potentially dangerous piping, valve, burner, etc. corrosion problems. This approach was successfully demonstrated in the test completed on behalf of Elf AtoFina (formerly Elf AtoChem) in Calvert City, KY circa 1993.


2. Spiking High Melt Point Waste Streams:


High melt point waste streams will freeze if spiked with high heat sink spiking materials such as aqueous solutions, resulting waste feed line plugging and/or burner tip blinding. In anticipation of this problem, Dr. Schofield successfully developed a spiking method which avoided “freezing” of high melt point wastes in 1993. This technique was successfully demonstrated in 1994 for Marathon Oil in Garyville, LA, and on several other occasions since, including several tests for Merisol (formerly MeriChem) in Houston, TX since 1996.


3. Spiking a Large Number of Different Metals:


Under the BIF Rule, which was frequently applied to incinerators under the Omnibus Provision, most commercial and a number of private facilities found it necessary to spike a large number of regulated metals in order to achieve workable feed rate limits for those metals. The established practice at that time was to utilize a number of spiking systems for spiking aqueous solutions of soluble metal salts-one system for each metal or group of solubility compatible metals (in order to avoid the possibility of metal precipitation due to the common ion or other solubility effects). In addition to operating complexity, unreliability, and high cost, this approach represented a significant risk to the environment should these highly mobile metal solutions be spilled. In 1990 and 1991, Dr. Schofield originated a method of feeding all necessary metals in one spiking system, each with a known feed rate, and in an immobile physical form. This approach has been successfully utilized on >100 commercial and private HWC facilities beginning in 1991 for Arch Chemical (formerly Olin Chemical) in Beaumont, TX and is now an industry standard.


4. Spiking Materials Designed to Meet a BTU Specification:


Numerous trial burn, RCoCs, and HWC MACT CPTs require spiking of a material with a controlled BTU content in order to achieve the desired test conditions. For example, metal spiking into a secondary combustion chamber frequently requires energetic material such as organic based dispersions instead of a zero BTU-content aqueous solution). Spiking aqueous metal solutions can result in an inability to reach the desired maximum combustion chamber temperature and failure to achieve sufficiently high combustion chamber temperature limits during the test. A lower than desired maximum combustion chamber temperature limit could result in an excessive number of AWFCO events during subsequent routine operations. Similarly, site-specific circumstances may exist which call for little of no BTU content in the spike material. From 1991 to 1994, Dr. Schofield with others developed a range of spiking materials to match a wide range of test BTU requirements.


5. Reologically Sensitive Applications


In some waste atomization cases, such as bio-sludge atomization, the addition of even a minor amount of an aqueous metal solution can cause undesirable viscosity and (potentially) other reological effects in the waste stream. For example, with bio-sludge the addition of a small amount of water causes the bulk biosludge to drop in mass from the feed device onto the combustion chamber hearth without atomization and thorough thermal treatment. Dr. Schofield assisted in the development process for using a metal dispersion to solve this problem. This technique was first demonstrated in full-scale testing during the mid-1990’s at Eastman Chemicals.


List of First of Their Kind Innovations and Industry Leading Studies by WRS:

 

  1. Discovered (in 1968) a previously unexpected linear, Log-Log relationship between the most economically significant measure of cellulose acetate fiber spinning efficiency, e.g., Bleb (B) & Interruption (I) rates [Log(B/I Per Day)] versus fiber diameter expressed as denier per filament [Log(D/F)].
  2. Developed (in 1967) the first practical, production-scale, continuous viscometer for extremely viscous cellulose acetate in acetone solutions.
  3. Designed and constructed (in 1968) a unique, bench-scale, variable agitation speed, differential-bed, catalytic reactor for measuring catalytic activity in the absence of inter-phase heat and mass transfer effects. Designed a temperature control system for the reactor which controlled reactor temperature within a fraction of a F degree despite the presence of significant thermal lag and inertia due to the thick metal reactor walls. This reactor produced reaction rate versus temperature data with R2>0.995 when plotted as an Arrhenius Diagram (e.g., Reaction Rate vs. 1/T).
  4. Advanced the state of the art in stochastic modeling of DO, BOD, Etc. in an estuarine environmental (from 1970 to 1972). Advanced stochastic models from a simple model with two (2), first order, ordinary differential equations with parameters, boundary conditions, and driving functions which were constant with respect to time and position to a model with a coupled set of twelve (12), second order, partial differential equations with parameters, boundary conditions, and driving functions which varied with respect to time and position. The 12 equations were coupled in their respective chemical and biological kinetics terms.
  5. Completed a study (in less than one man-week during 1974) of the US DOC, ICC, Department of Pipeline Safety’s records on pipeline breaks which demonstrated that some pipeline companies had pipeline break rates which were at least an order of magnitude better (or worse) than the national average. Made contact with the companies with the best records and bartered a copy of this study for their pipeline design and installation specifications which were adopted by the corporation’s design team.
  6. Recognized (10 1974) the potential of an early-stage, adiabatic rarification wave measuring device for detecting pipeline ruptures. Verified the systems functionality in tests conducted on full scale, high pressure pipelines. When a pipeline breaks suddenly, adiabatic rarification waves move in both directions out from the break at the speed of sound (at pipeline conditions). Was able to demonstrate detection of a pipeline break as small as 1/2” diameter hole at a distance of more than 10 miles even at a very early point in the technology development cycle.
  7. Was the sole author (in 1974) of a state of the art risk analysis study for a CO pipeline which was being considered from Air Product’s, La Porte, synthesis gas plant to Monsanto’s (now Sterling) HAc plant in Texas City, Texas. As a result of the study’s result (which indicated a once in 10,000 year chance of 1,800 people being killed in Texas City), the project was cancelled.
  8. Developed (in 1974) a dynamic model of a first-of-its-kind, full-scale HNO3 production plant. The model included the effects of chemical kinetics, flow dynamics through the process equipment, aerodynamics and thermodynamics of four (4) un-coupled turbo-compressors (prime movers), and the technology provider’s process control system. Simulations with the model indicated that the process with the existing control system would not function as designed, but would instead encounter surge in the third stage compressor prior to reaching nameplate capacity. Six (6) months of start up efforts confirmed this result. Developed and tested a control system using the model. The HNO3 plant first met nameplate capacity during the initial run with the recommended control system. Received a US patent for the control system.
  9. Developed (in 1982) the first ever chemical equilibrium model for the full-scale production of carbon black.
  10. Provided the process engineering concepts and technical leadership (in 1983) for increasing the DRE of the J.M. Huber AER Process from 99% to 99.99999999+% within three (3) months.
  11. Conducted (in 1987) the market study which justified the CWM commercial incinerator facility in Port Arthur, Texas. Was the first to predict (in 1987) that the then severe commercial incineration capacity shortfall would end in 1991 or 1992 (the shortage actually ended in the summer of 1991). All market condition, market size, and pricing aspects of this study proved to be accurate. Described by the President of the parent company as the best market study ever done within the entire company.
  12. Designed, justified and supervised construction; staffed; equipped; and supplied a state of the art analytical laboratory for a commercial incinerator facility (from 1988 to 1990). The lab was designed to complete the full suite of waste analysis parameters including all BIF metals and target volatile & semi-volatile organic compounds within three (3) days of sample receipt. The capabilities of this lab were such that it subsequently became the regional lab including D/F analytical capabilities without the need for structural expansion. Facility was described by the frugal Corporate Chief Financial Officer as “a bargain.”
  13. Conceived, developed, and successfully implemented (in 1990) a streamlined Landban Certification system for treatment residuals at the CWM Port Arthur commercial incinerator facility. This system was ultimately adopted at the CWM incinerator facilities at Sauget and Chicago, Illinois. This system reduced the average residual certification time at the Illinois facilities from more than 60 days to less than 14 days and resulted in system-wide savings estimated at more than $3 million/year.
  14. Developed and implemented (in 1990) a chemical process for purifying more than 1.5 million gallons of Dinoseb contaminated brine in two (2) weeks at a total development & implement cost of less than $10 K making the anticipated incineration of this material unnecessary and resulting in a savings of more than $1.5 million.
  15. Implemented numerous slag control measures (in 1990) with significantly improved through-put and on-stream time. These measures in aggregate had a 10:1 benefit: cost ratio.
  16. Originated, developed; and/or contributed to the development of several HWC spiking materials/methods (from 1991 to 1994) which are considered to be “standard practice” or “best practices” within the industry today.
  17. Designed and managed a miniburn on a captive incinerator (in 1993) which demonstrated (in less than 8 hours of testing) operating capacity which was >220 % above the previous maximum operating capacity and >75 % more capacity than the technology provider thought was possible.
  18. Completed (in 1994) a state of the art study of a modern municipal waste incinerator which established the fate and emission rates of 189 HAPs from the existing full scale process.
  19. Developed (from 1994 to 2002) several innovative statistical methods for demonstrating compliance with feed rate and emission limits for commercial and captive HWC facilities. The most recent suggestion for an alternative approach to the HWC MACT 80% UCL requirement was described by a senior EPA headquarters staff member as “near brilliant”.


Selected Projects Which Were Successfully Completed at DRE Southwest:

  • Preparation and/or QA/QC review of CTN documents, RCoC tests and/or preparation of RCoC documents for various BIF facilities, including Mobil Chemical, Arizona Chemical, Mallinckrodt Chemical, Rexene, Fina Oil & Chemicals, and Natural Gas Odorizing (NGO). Prepared Waste Analysis Plans for Arizona Chemicals, 3V, Inc., and Fina Oil and Chemicals.
  • RCRA incinerator permit application and NSR/BACT analysis, and NOD response for LaPosta Recycling Center (a joint venture of W. R. Grace and Canonie).
  • BIF and CAA audits (and audit follow-up, as needed) for Mobil Chemicals, Fina Oil & Chemicals, Mallinckrodt Chemicals, and Riley Industries.
  • Completed feasibility study and RCRA incinerator permit renewal application for McDonnell Douglas, including the evaluation of various types of combustion and APC devices suitable for client’s applications.
  • Prepared the Waste Analysis Plan for the RCRA Part B permit application for FTMI (a proposed commercial incinerator owned by joint venture including Hughes Electronics).
  • Primary author of the following selected engineering and/or regulatory-based reports:
    • The Fate of CAA Title III Hazardous Air Pollutants (HAPs) in a Modern Municipal Waste Incinerator. The effort involved detailed collection of removal efficiency information to predict concentration of 189 HAPs exiting the combustion chamber and collected at each step in the air pollution control system. This was a pioneering effort to predict the fate of a wide range of HAPs in the combustion and APC systems and defined the state-of-the-art in this industry at the time the report was issued.
    • Engineering Evaluation of a Proposed Commercial Hazardous Waste Incinerator (separate reports on the waste handling, site-wide computer control/information management system and incinerator sections of the facilities).
  • Miniburn Test Plan to establish DRE/RE values for an existing hazardous waste incinerator at proposed trial burn feed rate, combustor temperature, and APCS conditions; as a result of this test, the maximum waste feed rate was increased from approximately 800 lb/hr to 1700+ lb/hr. RCRA Trial Burn Plan, Waste Analysis Plan, process optimization (including optimization of the APCS), risk assessment, etc., for Elf Atochem’s Calvert City, Kentucky facility.

 

 

 
 
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