Sludge from a Sinclair refinery

Thermaldyne proposes to process both oil bearing hazardous secondary refinery sludge and liquid materials in Port Allen. Our company, TD*X Associates, has processed over 370,000 tons of the same exact petroleum refinery waste, using the same thermal desorption technology, since 1989.

These refinery materials contain hazardous chemicals, including Anthracene, Benzene, Benz(a)anthracene, Benzo(a)pyrene, Benzo(g,h,i)perylene, bis(2‐ Ethylhexyl)phthalate, o‐Cresol, m‐Cresol, p‐Cresol, Carbon disulfide, Chrysene, 2,4‐ Dimethylphenol, Dibenz(a,h)anthracene, Di‐n‐butylphthalate, Ethylbenzene, Fluorene, Indeno(1,2,3,‐cd)pyrene, Naphthalene, Phenanthrene, Phenol, Pyrene, Toluene, Xylenes, Cyanides, Antimony, Arsenic, Chromium, Lead, Nickel, Mercury and Vanadium among others.

Many of these chemicals are known carcinogens. Thermaldyne’s variance request indicates that it will process these sludge and liquid materials using centrifuges and a thermal desorption unit.

The LDEQ Draft variance does not require the thermal desorption unit to operate at a minimum treatment temperature, which it should.

The variance also classifies the solids generated by the TDU as a newly generated waste, which means the materials will NOT be tested for the chemicals identified above.

If the TDU partially treated solids are not characteristically hazardous for benzene, they will be disposed of in industrial landfills in the Baton Rouge area and likely contain elevated levels of the chemicals listed above at levels EPA has determined are unsafe for disposal even in highly regulated hazardous waste landfills.

The centrifuges Thermaldyne indicates it will operate on oil bearing hazardous secondary liquid materials will generate oily solids. The LDEQ draft variance does not require the centrifuge solids to be processed through the thermal desorption unit. The variance states that these centrifuge solids are also a newly generated waste and will NOT be tested for most of the chemicals identified above.

These solids also will be able to be disposed of at local industrial landfills in the Baton Rouge area in a similar un-protective manner as the thermal desorption solids. There are over ten commercial facilities in the gulf coast that are processing these exact same materials under more stringent regulations that safely manage their solid residuals, waste water discharge and toxic air emissions.

Three essentially identical facilities are processing these materials in strict adherence to the exact regulations Thermaldyne seeks to avoid. A fourth facility located 120 miles from Thermaldyne in Lake Charles is scheduled to start processing these exact same materials in the fourth quarter of 2018 and is also adhering to stringent and appropriate hazardous waste regulations.

None of these four facilities proposes to operate in a manner that allows the treated residuals to be partially treated and disposed of in local industrial landfills.

Thermaldyne claims to be a recycling facility. However, the draft variance has no requirements for how much material must be reclaimed.

In a meeting attended by LDEQ staff, the permit writer stated that minimal or negligible reclamation was OK. Approximately 95% of the revenue from the facility will come from gate receipts to manage the discard of these refinery wastes. Only 5% may come from the sale of recovered oil, depending on how much Thermaldyne decides to recover.

In fact, based on our decades-long experience, we believe that Thermaldyne will likely combust more energy than the TDU will generate, giving the proposal a negative energy value. Why should such a facility qualify for a recycling variance?

TDX and others in this industry have invested a lot of money to meet the most stringent toxic pollution control standards. Our permits require complete and expensive testing of each load.

If Thermaldyne is allowed to operate without such equipment, and without such complete testing, it will un-level the playing field and encourage other operators with equally deficient pollution controls. Government should not pick winners and losers in this way, particularly at the cost of public health.

[Reference public comments from LDEQ public record, “TD*X Associates, Comments at Thermaldyne Public Meeting, Gregg S. Meyers, September 20, 2018]

For TDX Associates,

Gregg Meyers

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