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Dioxin / Furans

Stakeholders Meeting - July 6, 1999
Workgroup Teleconference Minutes

Workgroup Leaders:
Sandro Leonardelli, EC
Nan Gowda, EPA

Facilitator:
John Menkedick, Battelle

After a review of the objectives for the day, the meeting opened with several presentations on municipal waste combustion (MWC) and medical waste incineration (MWI).

Information Presentation

Status of Current Regulations

Sandro Leonardelli (EC) presented the status of current regulations for MWC/MWI in Canada.

Most of the regulatory authority in Canada is at the provincial level. The ban on new MWC facilities was removed in 1995, at which time a new guideline, A-7, was implemented to regulate all new municipal incinerators and for the expansion/modification of existing municipal incinerators.
The Ontario emission standard for MWC 0.14 nanograms/m3 TEQ. The Canadian Council of Ministers of the Environment (CCME) guideline, established in 1989, is 0.5 nanograms/m3 TEQ, making the Ontario standard stricter than the joint provincial guideline. In comparison, the USEPA standard is 0.14 nanograms/m3 TEQ and the European standard is 0.25 nanograms/m3 TEQ.
For hospital incinerators, the CCME standard is 0.5 nanograms/m3 TEQ. The Ontario A-1 guideline is also 0.5 nanograms/m3 TEQ. Since the A-1 guideline was established, no new incinerators have been added. Existing incinerators are “grandfathered” under the old guidelines and therefore are not subjected to the new guidelines unless they expand, change their process equipment or otherwise trigger the review of their provincial permit (i.e. Certificate of Approval). There are approximately 69 existing medical waste incinerators in the province with estimated emissions of 1.15 grams TEQ total. This ranks the MWI sector 6th overall in Ontario in terms of total emissions. In comparison, traffic-related combustion of diesel fuel (ranked 5th in Ontario) represent 3.1 grams TEQ. The Canadian Dioxins/Furans Inventory showed a mean concentration of 24.25 nanograms/m3 TEQ for Ontario MWI emissions, based on the testing of 6 hospital incinerator stacks. If one assumed that the Ontario MWI guideline was incorporated into the permits for each facility, then the mean concentration of emissions should be within the 0.5 nanograms/m3 TEQ. However, most (if not all) of the Ontario hospital incinerators are not yet subject to the A-1 guideline. Sandro raised a question regarding whether this is a also problem in the US (i.e. a standard exists, but it is not included in facility permits unless the facility expands, changes process equipment, of other trigger the review of their permit).
Sandro does not have information on the type or level of pollution controls on the existing MWI/MWC. He’s been talking to Dale Phenicie (Council of Great Lakes Industries) about redirecting a work proposal CGLI recently submitted to Environment Canada so as to determine which facilities are under the guidelines and which are not. Sandro will get back to Dale on whether there is a need for this word to be undertaken (data might already exist elsewhere).

Dwain Winters (USEPA) presented the status of US regulations.

US promulgated rules for MWC in 1995 and for MWI in 1997. Municipal incinerators are divided in to 4 classes based on total dioxins and furans instead of TEQs. The new MACT standards are applied at the state level. Implementation of a new standard is usually estimated to take 5 years.
For medical waste incinerators, in 1987 there were 2500 grams TEQ released to air from 5000 MWI facilities. By 1995 there were 477 grams TEQ released from 2500 facilities. The goal by the year 2000 is to reduce emissions to 5 grams TEQ from 2000 facilities. Much of the drop from 1987 to 1995 can be attributed to the closure of half the facilities as a result of individual state requirements.
For municipal waste combustors, in 1987 there were 8000 grams TEQ of dioxin released from 113 facilities. By 1995 there were 1100 grams TEQ released from 130 facilities. The goal for 2000 is to reduce emission to 65 grams TEQ from the 130 facilities. If all facilities were in full compliance with existing standards, OAQPS has estimated that total emissions would decrease to 24 grams TEQ. Currently, most of the dioxin/furan emissions from MWC originate from just a few facilities. For example, only 15 hot-sided electronic precipitator furnaces account for 85% of the total MWC emissions.
Jackie Hunt-Christensen (Institute for Agriculture and Trade Policy) and Guy Williams (National Wildlife Federation) asked about confidence in the estimates and the effect of small sample size. Dwain confirmed that many of these estimates are based on a small sample size, although they are still considered by the peer panel review to be the best estimates that current information will allow. Dwain noted that a compliance test will be required for MWC which should result in stack test results for all MWC in the future.
There was a concern about the MWI waste being diverted to MWC. Dwain reports that historically, hospitals have disposed of all waste, whether medical or non medical, via MWI because this method was considered cheaper than separating it. A significant reduction in MWI emissions was then seen when hospitals began separating medical waste from municipal waste. The decrease in emissions at MWI is therefore due in great part to a reduction in the volume of medical waste burned at MWI. MWC have much better combustion controls that MWI.
James Harvie (Santa Clara Center for Occupational Safety and Health) asked for a comment on the lawsuit on the MACT rules and how it would affect the standards. The lawsuit pertains to the categories and how they were developed. The lawsuit may lead to some adjustments and restructuring of the rule but should not change any levels. The MACT rules are demanding and require performance at least as well as the top 12% for the best available technology.

Chlorine in the Feedstock / Combustion Chemistry

Dwain Winters (USEPA) provided information on chlorine in combustion chemistry.

The relationship between chlorine and dioxin is not simple. There are differences depending on whether the combustion is uncontrolled or well-controlled. There are 3 ways dioxin is released in combustion:
1. Dioxin is in the fuel to start with and is released during the combustion process.
2. Dioxin is generated as a result of incomplete combustion
3. Although combustion is complete, dioxin is formed in the post-combustion environment via de novo synthesis.
It was noted that in Minnesota, de novo synthesis is typically the most important process resulting in releases of dioxin. Emissions do result from incomplete combustion, but the amount is reduced if the temperature is raised.
A further discussion of complete combustion was presented. If the temperature is above or below a certain range, then dioxin formation will not occur. In general, there are 3 requirements for the formation of dioxin during complete combustion:
1. Appropriate temperatures for formation.
2. Sufficient retention time.
3. The presence of catalytic surfaces.

At facilities with well controlled combustion and good pollution controls, these three factors result in low levels of dioxin formation and release. When facilities are operated according to the CAA Maximum Available Control Technology (MACT) standards, background concentrations of chlorine are still adequate to support dioxin formation, and additional sources of chlorine (e.g., PVCs) will generally not result in additional dioxin formation. Therefore, in well-controlled combustion, the chlorine content of the feedstock is typically not a controlling factor in the magnitude of dioxin formation. However, this may not be the case in instances where combustion is less well controlled, and in some cases, chlorine in the feedstock may play a significant role in controlling dioxin formation.

P2 and Material Separation Issues

Joe Stepun (WLSSD) presented information on the Western Lake Superior Sanitary District. The WLSSD facility is no longer a municipal combustion facility, as their waste is now being landfilled. However, he provided results from a past comparison study of refuse derived fuels (RDFs). The results of the comparison were as follows:

In 1987 there were 8 nanograms/m³ total dioxins/furans for the normal RDF waste stream.
In 1992 there were 14 nanograms/m³ total dioxins/furans for the normal RDF waste stream.

They also conducted controlled burns with feedstock containing reduced chlorine

In 1992 there were 4.2 nanograms/m³ total dioxins/furans with a wood chip burn.
In 1996 there were 6 nanograms/m³ total dioxins/furans with a plastic free paper burn.

As evidenced by these tests, Joe concluded that there is no significant difference when plastic and chorine free fuels are used in the presence of well-controlled combustion. However, there can be significant increases with poorly-controlled combustion, high particulates and high capacity. For example, in 1993, total dioxin/furan concentrations of 43 nanograms/m³ were observed as a result of an instance of non-optimal combustion of RDFs. Later that year, however, when the facilities’ operating performance was corrected to sustain well-controlled RDF combustion, total dioxin/furan concentrations were back to 3 nanograms/m³.

A question was posed regarding scrubber efficiency. An efficient scrubber is able to effectively eliminate dioxin resulting from the combustion process. Ash removed from a wet scrubber at the WLSSD was observed to have dioxin concentrations ranging from 24 - 321 nanograms/kilogram TEQ (versus 0-2.05 ng/kg TEQ in the WLSSD incinerator ash). Thus, the ash must go to a monofill or hazardous waste landfill. Originally, MWC were excluded from hazardous waste rules. Dwain cited an estimate of 7 million tons of municipal ash disposed of yearly with 1800 grams TEQ of dioxin in that ash.

There was some discussion as to whether it is part of the mission of the workgroup to be concerned with materials being deposited in landfills. From previous efforts on other workgroups, some members were under the impression that this goes beyond the scope of the workgroup. Most participants on the call felt that the work group should be concerned if the ash does not go for proper disposal.

Proposed Method for Getting Reduction Commitments

Werner Braun (CGLI) presented a potential method for use in tackling decisions in the dioxin workgroup. He noted that the decision tree is currently being used by the BNS Octachlorostyrene (OCS) workgroup, however, prefaced his presentation with the remarks that the decision tree should also be regarded as a work in progress. Therefore, he proposed that the decision tree be used as a template or starting point to guide workgroup members on how to proceed and not as the ‘best’ way to do things. He credited Dale Phenicie (CGLI) for his efforts in developing the decision tree process. The structure of this particular decision tree utilizes the following questions:

Is this current technology?
Is this technology used in the basin?
Is this a significant source?
Is there environmental release potential?
Is environmental release significant?

After asking each question, there is either a yes or no response. A yes responds leads to the next question. A no response leads to a stop. This is done until one either comes to a stop or reaches the end of the decision tree by answering yes to all the questions. A yes for all the questions results in a commitment to appropriate reductions.

Discussion included positive comments on the decision tree approach:

the approach was perceived as a useful tool that provides a good screening technique
the tree provided a helpful prioritization scheme, and would be useful to help the group focus
the tree could potentially be used to come to closure on sources or sectors

Concerns regarding this approach were also expressed, including:

the approach should not preclude voluntary actions towards virtual elimination
the tree was better suited for setting priorities than reaching closure
simple yes/no answers might be difficult; some of the questions still seem obscure
questions may need to be customized for different chemicals and perhaps even different sectors.

Discussion

In addition to discussion directly related to the information presentations, several other issues were raised and discussed by the workgroup. These included:

The need for more information related to compliance with MWC/MWI regulations. This includes: what compliance testing will be required, the timing and mechanisms for making the information available, and the schedule for and likelihood of compliance.
The need for public dissemination of information (emissions estimates, uncertainty characterization, and compliance issues) in a way that is readily accessible in “laymen’s” language.
Addressing major information gaps for dioxin. This includes both the issue of clarifying uncertainties in emission estimates as well as determining whether there is sufficient information for action. This was reflected in a suggestion that the workgroup should offer commentary on the government inventory estimates and in a suggestion that the workgroup consider the quality of information in directing its limited resources.

Action Items and Next Steps

Minutes will be drafted from the July 6 conference call.
A subgroup will continue discussion of adaptation of the decision tree process to the dioxin group. Werner Braun (CGLI), Sandro Leonardelli (EC), Dwain Winters (EPA) and Nan Gowda (EPA5) volunteered to work on this.

The workgroup will focus on current action items identified in the work group timeline and action item update. The group agreed not to address the issue of accidental fires involving PVC at the next conference call but rather to wrap up the discussion of MWC/MWI and to focus on what actions can be taken now that the major source/sectors have been discussed during the last three meetings of the workgroup. The next conference call on August 3 will focus on these issues. Other topics to be discussed include:

a short presentation on the uncertainties associated with these MWC/MWI emission estimates by Dwain Winters, and
a profile of Health Care Without Harm by Jackie Hunt-Christensen

Participant Roster

Werner Braun, Council of Great Lakes Industries
Jackie Hunt-Christensen, Institute for Agriculture and Trade Policy and Health Care Without Harm
Hugh Eisler, Canadian Chlorine Coordinating Committee
Nan Gowda, USEPA Region 5
James Harvie, WLSSD
Sandro Leonardelli, Environment Canada
Jeffrey Lynn, International Paper
John Menkedick, Battelle
Fardin Oliaei, Minnesota Pollution Control Agency
Dale Phenicie, Council of Great Lakes Industries
Joseph Stepun, Western Lake Superior Sanitary District
Guy Williams, National Wildlife Federation
Dwain Winters, USEPA Headquarters