The transformation of waste into energy through Energy Recovery Facilities (ERF) is a vital component of modern waste management strategies, aiming to reduce landfill usage and generate energy. However, this process also introduces significant environmental and health challenges, particularly concerning the generation and management of toxic substances like Chromium VI. This substance can be commonly found in dust settlements within ERF incinerators and can lead to exposures during refit outages that require controls and monitoring to be put in place.
This case study outlines the comprehensive approach taken by a leading UK-based energy recycling company, in collaboration with our industrial hygiene consultancy services, to mitigate the risks associated with Chromium VI Cr(VI) during maintenance and refit operations of incinerators.
Chromium VI: Formation and Risks
Cr(VI) is an oxidized form of chromium, known for its high toxicity and carcinogenic properties. It is not naturally found in significant amounts in biological organisms or the environment but is primarily produced by industrial processes, including the incineration of wastes containing various forms of chromium. Cr(VI) forms during the high-temperature combustion of waste materials and can sometimes be observed as a yellowish deposit (Chromium Trioxide or Sodium Chromate) on surfaces throughout the latter stages of the incinerator. Simple instantaneous test kits can be used to confirm its presence.

This formation process is influenced by several key factors:
The ERF incineration process involves a number of stages at which Chromium VI can be generated as follows, typically positive Chromium VI samples are detected in settlement dusts from the 2nd to 6th passes.
1st Pass: This is the initial section where the combustion of waste takes place. The flue gases generated here are at their highest temperature and contain the initial pollutants and residues from the combustion process.
2nd Pass: After the initial combustion, the flue gases move to the 2nd pass, where they begin to cool down. This pass often involves heat exchange processes to recover energy from the hot gases. Dust and residues can settle on surfaces in this pass, which may include materials like Inconel, a high-performance alloy resistant to high temperatures and corrosion.
3rd-6th Pass: These are subsequent stages where the flue gases continue to cool and additional energy recovery and cleaning processes occur. Each pass represents a further step in the cooling and treatment of the flue gases before they are released into the atmosphere. Dust and residues can also settle in these passes, and these stages are crucial for ensuring that pollutants are removed to meet environmental standards.
Chromium VI: Health Effects
The health risks associated with Cr(VI) are severe, including respiratory diseases, skin ulcers, and lung cancer when inhaled. Thus, workers and technicians involved in the operation, maintenance, and refit of incineration plants are at significant risk of exposure, especially during activities like welding, cutting, or when handling residues containing Cr(VI). Due to the sensitisation effect of Chromium VI and its carcinogenic nature exposures must be controlled and reduced not only to below the workplace exposure limit (WEL) but to as low as reasonably practicable (ALARP) under health and safety law.
Case Study: Energy Recycling Company’s Approach to Chromium VI
Our engagement with the energy recycling company involved a multi-faceted approach to managing Cr(VI) risks, focused on assessment, control, and continuous monitoring. Our monitoring services were pivotal in providing the client with detailed exposure control recommendations and identifying specific processes and work activities that generated elevated levels of Chromium VI.

Risk Assessment and Exposure Monitoring: We conducted a detailed risk assessment to identify potential sources of Cr(VI) exposure during the incinerator's maintenance. The robust monitoring program implemented included:
Regulatory and Compliance Framework
In response to the risk, strict regulatory standards have been set by the UK Health and Safety Executive (HSE). These standards define permissible exposure limits and mandate the implementation of safety measures to protect workers. The HSE specifies a legal exposure limit for Cr(VI) of 0.01 mg/m³ as an 8-hour time-weighted average (TWA) as described in EH40. Compliance with these regulations, particularly under the Control of Substances Hazardous to Health (COSHH) regulations, is crucial for ensuring the health and safety of employees. To put this level of exposure into context a full day's exposure to chromium VI at the legal limit of 0.01mg/m3 would equate to breathing in such a small quantity that it would only occupy 1/33rd of the space of a pinhead.

Biological Monitoring Guidance Values (BMGVs) and Monitoring
To complement the exposure limits, HSE has also established Biological Monitoring Guidance Values (BMGVs). For Chromium VI, the BMGV is set at 10 µmol chromium/mol creatinine in urine post shift. This value is instrumental in assessing whether the control measures in place effectively protect workers from excessive chromium exposure. BMGV monitoring involves collecting urine samples from workers at the end of their shifts to measure the levels of chromium compounds. This method provides an accurate indication of the amount of Cr(VI) that has been absorbed into the body, helping to assess whether safety measures are effectively preventing excessive exposure.
Implementation of Control Measures
A number of control measures were developed to reduce the overall risk of exposure to site operatives involved in the incinerator outage:
Our monitoring services provided the client with the assurance that they were effectively controlling exposure and meeting their legal requirements under COSHH regulations. The client was highly satisfied with the assistance provided for this specialist area of exposure monitoring, which ensured their operations remained safe and compliant.
Conclusion and Future Directions
Through the measures implemented, the company not only achieved compliance with health and safety regulations but also significantly enhanced the protection of workers from the dangers of Cr(VI). This case study serves as a model for similar facilities aiming to balance operational efficiency with stringent safety standards in the waste management industry.
For further advice call us on 0870 701970 or email: safetyexpert@euroenvironmental.co.uk
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