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______________________

Dioxin / Furans

Stakeholders Meeting - December 7, 1999
Workgroup Teleconference Minutes

Workgroup Leaders:
Sandro Leonardelli, EC
Anita Wong, EC
Nan Gowda, EPA

Facilitator:
John Menkedick, Battelle

The objectives for the day were to continue application of the decision tree process to the remaining targeted sectors, identify reduction projects for each priority sector, and discuss the status of outstanding action items.

At the open of the conference call, Sandro Leonardelli (EC) introduced Anita Wong (EC), who will be reassuming the EC co-lead position for Sandro, after her return from maternity leave. The next dioxin workgroup conference call (January 11) will be Sandro’s last call.

Discussion of the Biannual Meeting

The dioxin/furan breakout session of the November 18 Biannual BNS Stakeholder’s Meeting was briefly reviewed. Generally, attendance was excellent (22-25 workgroup members) and impressions of the meeting were favorable. At the November meeting, the workgroup discussed residential wood combustion (RWC) and open barrel burning using the decision tree process. Both sources of dioxin/furan emissions were tentatively classified as high priority for workgroup action, based on the facts that these sources have relatively little regulatory control and have high potential to be reduced by voluntary actions.

The workgroup also began discussion of Medical Waste Incineration (MWI) using the decision tree process, but had unresolved issues that they decided would require further discussion at following meetings. This led the group to resume discussions within the decision tree process.

Decision Tree Discussion

Medical Waste Incinerators (MWI)

The workgroup resumed discussion of unresolved issues regarding MWI, including:

the fate of medical waste from closed facilities in the U.S.
the impact/effectiveness of Canadian regulations given the grand-fathering of older facilities under old standards
the impacts and magnitude of land and water releases (e.g., fly ash)
opportunities for front-end separation and waste minimization

Most of the issues discussed centered around determining if, given existing regulations, there were any opportunities for further dioxin/furan reductions.

It was noted by Dwain Winters (EPA) that for MWI, the number of facilities closing and the higher than expected diversion of medical waste to autoclaving facilities may result in even higher dioxin/furan reductions that predicted in the MACT standard analyses.

Dwain cited two primary questions that remained of concern for MWI:

Are significant quantities of non-medical/non-infectious waste being included in the MWI waste stream?
What are the quantities of medical waste being disposed of by incineration as compared to alternative methods?

Discussion of which priority designation MWI should receive followed. Suggestions for major focus areas for actions included:

encouraging and gathering more information on the prevalence of proper waste separation
outreach to MWI facilities (it was noted that some workgroup members have experience in this area)
gathering information on how much dioxin is in incineration waste products (i.e., fly ash), and methods and potential impacts of fly ash disposal
gathering information on the potential effects of waste diversion to other disposal methods

Differences between the U.S. and Canada, in the types of actions possible and prioritization of actions, were discussed. For example:

in the U.S., because regulatory control is relatively effective, remaining reductions opportunities are both smaller and harder to achieve. Thus, activities for MWI in the U.S. might be considered “little / medium or hard”
in Ontario, as relatively little is being done at the present to control MWI (i.e., except for some fly ash management, most regulation targets only new facilities), activities for MWI in Ontario might be considered “little / easy”. Thus prioritization of these activities in Canada may be at least of medium priority.

A workgroup member suggested that for a particular sector, different efforts may be required in the U.S. and Canada. However, although the primary driver for action may reside in one country (e.g., MWI efforts in Canada), benefit may also be obtained in the other country.

The workgroup discussed setting aside MWI as fairly low priority. However, some workgroup members felt that MWI should be medium priority, especially in Canada.

It was agreed that more information on fly ash waste / management was needed to inform a decision regarding prioritization. Dale Phenicie (CGLI) volunteered to contact representatives involved in waste management in hospitals, and possibly arrange for participation in a later teleconference.
It was agreed that more information was needed on waste management practices in Ontario. Anita Wong (EC) volunteered to gather information on this.
It was tentatively decided that a distinction should be made between the U.S. and Canada in regards to prioritization: MWI would be designated as medium priority in Canada and lower priority in the U.S.

With a tentative decision regarding MWI, and also acknowledging that MWI would need to be revisited later, the workgroup moved on to discussion of municipal waste combustors (MWCs).

Municipal Waste Combustors (MWC)

Several primary questions regarding the prioritization of MWC were cited by the group:

How significant are the very small (<35 ton / day) MWC?
For MWC subject to upcoming MACT standards (i.e., large (>250 tons/day) and small (35-250 tons/day)), how soon will compliance be achieved, and how will we know if facilities are in compliance?
Are there types of facilities combusting municipal waste that have no existing or planned regulation (e.g., power plants burning municipal waste)?
Will new testing requirements under MACT regulation fill in the gaps in the emissions estimates?
Is more information needed on MWC releases to water and/or land (i.e., waste ash disposal)?

Dwain Winters (EPA) was able to provide answers for some of these questions:

In the 1998 U.S. Inventory, there were 14 large hot-sided ESP facilities that accounted for approximately 80% of the emissions. It was determined in the inventory that the sum of emissions for all of the very small facilities did not approach the magnitude of the emissions from the large MWC facilities
The rule for Boilers and Industrial Furnaces (BIFs) should cover other types of facilities burning municipal waste.
With implementation of the MACT standards, facilities will be required to conduct initial compliance testing as well as more long-term, periodic stack test monitoring. Dwain volunteered to check on the details of the requirements and how compliance would be monitored. Some information on the operating parameters under the rule are also available on the USEPA Integrated Toxics Website [http://www.epa.gov/region5/air/toxics/index.html] and in the Federal Register. He also noted that because this testing will provide data on a facility by facility basis, the emissions estimates in the Inventory would be raised to a high level of confidence.
Dwain stressed the importance of fully implementing the MWC rule to achieve the estimated levels of reduction (~24 grams total / yr with full compliance). He noted that compliance does not occur all at once, but is based on a sequence of dates. Therefore, he also stressed the importance of the Agency having a means of systematic review to make sure compliance is maintained over time.

The workgroup continued to discuss the question of how close to full compliance MWC facilities would get in the near future.

Indications are that the large (>250 tons/day) facilities are already making fairly good progress with achieving compliance.
The small (35-250 tons/day) facilities are lagging in compliance upgrades (largely because the rules have not been finalized). The work group thought they needed more regulatory details on the status of small MWC.
Very small incinerators may not represent enough releases to merit significant actions. In conclusion, the workgroup identified a need for materials that would provide an overview of emissions associated with the different sizes of MWC facilities and the full set of compliance dates for the various stages in the implementation process. A table format was suggested. Dwain Winters will provide a table of the different regulatory classes (noting that the classes in the inventory are not exactly the same, but overlap somewhat).

This led to a general discussion of other information gaps that the group still felt existed. The group committed to compiling a list of remaining information gaps.

Dan Hopkins (EPA) announced that the BNS would be conducting an incineration workshop (focus on well-controlled sources) in May and that the dioxin workgroup might also want to pose some of their remaining questions to the government experts in this forum. The group decided to finish discussion of MWC and then move on to discussion of the Incineration Workshop in more detail.

The status of MWC regulatory control in Canada, within the context of Canada-wide Standards (CWS), was discussed. Sandro Leonardelli and Anita Wong gave an overview of MWC in Ontario:

There are currently 4 large MWC in Ontario, with 95% (6.3 g TEQ/yr) of the Ontario total originating from one facility in Hamilton (SWARU facility). SWARU’s emissions are also expected to increase with planned expansions in volumes of waste disposed of; this has caused many to voice opposition to the SWARU facility.
The SWARU facility is an older facility without up-to-date temperature control devices; emissions are controlled with a bag-house / hydrated lime injection system. The facility is currently meeting it’s existing permit requirements (based on downwind point-of-impingement concentrations). The SWARU facility is not subject to Ontario Guideline A-7 because the SWARU facility’s permit was renewed before Guideline A-7 was finalized.
MWC are planned to receive priority attention in the development of upcoming CWS, and will be finalized by Spring 2000. Once CWS are finalized, the province has the burden of implementation; at that time the provinces may be able to re-open existing permits if they choose.
Until then, regulatory agencies can only encourage voluntary efforts (e.g. upgrading to carbon injection systems) to reduce emissions. The Canadian government is actively encouraging SWARU to voluntarily upgrade its control devices, but this is unlikely to occur before 2005 because there are no incentives existing right now. In addition, because the municipality is currently reviewing it’s waste management plan and may be shifting away from incineration, the municipality is hesitant to invest in upgrades.

The development of incentives to encourage facilities to implement voluntary upgrades was cited as a possible activity for the workgroup.

The workgroup then turned to a more general / philosophical discussion of how to reconcile short-term goals (i.e., upgrades) with the long-term goal of virtual elimination (i.e., alternatives to incineration). Issues discussed included:

keeping focused on the challenge goals and not getting diverted
focusing on short-term goals but also keeping in mind building a platform for long-term goals (although it may not receive as a high a priority designation as the short-term efforts)
conducting efforts directed at long-term and short-term goals in parallel
not limiting workgroup efforts to regulatory efforts

It was proposed that the workgroup begin to compile a list of alternatives to incineration. Werner Braun (CGLI) also informed the group that the industrial sector is currently conducting a viability assessment of alternative technologies for incineration. The assessment report is expected to be complete towards the beginning of the new year.

Sandro Leonardelli (EC) summarized the workgroup’s discussion on MWC: As there are no real reductions initiatives other than MACT in the U.S., the dioxin workgroup intends to focus on alternatives, incentives, and gathering information on any emission reductions that could occur for those facilities not currently covered through regulation (i.e., small, very small, and Canadian facilities). These activities would receive fairly high priority for the workgroup, at least over the next several months.

Sandro suggested that the workgroup may want to identify a detailed pilot scale project that would address available alternatives and waste reduction efforts, and economic and other incentives and/or barriers.

This led to discussion of incineration issues and the BNS Incineration Workshop.

BNS Incineration Workshop Discussion

Ideas for possible dioxin workgroup input at the BNS Incineration Workshop were discussed, including:

presentations on alternative technologies to incineration
presentations on P2 and other front-end / voluntary efforts (MACT only focuses on total volume of waste; waste separation is not required)
proposing the preparation of technical informational materials on alternatives (including information on upgrading, materials separation, and non-incineration technologies) that industries could use in decision-making.

It was suggested that a subgroup should be formed to lead the process for getting dioxin/furan workgroup input into the Incineration Workshop, and that it was important that the dioxin workgroup’s input be conveyed to the BNS Integration Group leaders of the workgshop. This subgroup could gather information on and draft materials articulati g dioxin workgroup viewpoints on non-incineration alternatives and front-end efforts

It was also noted that information on upgrading operating conditions is also important. For example, a facility which was the largest dioxin emitter in Quebec reduced its emissions from 61.8 g TEQ / yr to about 0.5 g TEQ / yr with end-of-pipe upgrades (carbon injector).

It was decided that the workgroup would defer the majority of work on preparing the incineration workshop to the beginning of January.

Summary Review of Status in the Decision Tree Process

Discussion turned to a brief review of the workgroup’s current status in the decision tree process and a discussion of action items:

Open burning and residential waste combustion were discussed and designated as high priority for workgroup actions. This decision was based on high (although uncertain) emissions estimates and the presence of opportunities to promote reductions (i.e., due to the lack of regulatory control).

Medical waste incineration (MWI) was discussed and tentatively designated as low to medium priority in the U.S. and medium priority in Canada. The discussion on MWI is not yet resolved and is to be revisited at a later date.

Municipal waste combustion (MWC) was discussed and tentatively designated as high priority, at least until further information on the smaller sized facilities could be gathered. The discussion on MWC is not yet resolved and is to be revisited at a later date.

Discussion followed on how the workgroup might handle the implementation of future actions after all of the sectors are discussed and prioritized.

A suggestion was made that subgroups could be formed for each priority sector to specifically define a plan for actions, which would then be reviewed by the whole workgroup.
A comment was made that when defining actions, the workgroup organizers needed to make a best effort to solicit participation from the experts / key players for a given sector.

Many workgroup members felt that it was a good idea to eventually form subgroups for each priority sector, but that the workgroup needed to finish discussing and prioritizing all of the targeted sectors using the decision tree process first.

Action Items and Next Steps

Minutes from the December 7 conference call and the November 18 Stakeholder Meeting will be drafted and distributed
Anita Wong (EC) volunteered to investigate and report back on current activities being conducted by the B(a)P and HCB workgroups on residential wood combustion / wood stoves.
More information will be gathered on small MWC facilities (emissions, regulatory details, etc.)
Dwain Winters (EPA) volunteered to check on the procedure for monitoring incinerator compliance over time and the associated stack test requirements
A table will be drafted to organize sector information, including emissions data, regulatory classes, and details on compliance dates for each size class of facility.
Dale Phenicie (CGLI) volunteered to make contacts to gather more information on waste management in hospitals.
EC volunteered to gather more information on waste management at MWI facilities in Ontario.
A list of information gaps remaining for the workgroup will be compiled
Werner Braun will keep the workgroup updated on the progress of the industry report on assessment of alternative incineration technologies.
Workgroup meeting organizers will develop a process and put forth an ongoing effort to solicit participation from experts / key players where appropriate for a given sector.

The workgroup will continue work on current action items identified in the action item update. The next conference call is scheduled for January 11, 2000.

Participant Roster

Werner Braun, Council of Great Lakes Industries
Tracey Easthope, Ecology Center of Ann Arbor
Nan Gowda, USEPA Region 5
Dan Hopkins, USEPA
Mark Johnson, Weyerhauser
Sandro Leonardelli, Environment Canada
John Menkedick, Battelle
Dale Phenicie, Council of Great Lakes Industries
Jamie Skimming, Dofasco
Guy Williams, National Wildlife Federation
Dwain Winters, USEPA
Anita Wong, Environment Canada
Maureen Wooton, Battelle