vvEPA
               United States
               Environmental Protection
               Agency
Office of Research and
Development
Washington DC 20460
              The Inventory  of
              Sources  of Dioxin
              in the United States
EPA/600/P-98/002Aa
     April 1998
External Review Draft
               Draft
               (Do  Not
               Cite or
               Quote)
                                Notice
              This document is a preliminary draft. It has not been formally
              released by EPA and should not at this stage be construed to
              represent Agency policy. It is being circulated for comment on its
              technical accuracy and policy implications.

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                                                             EPA/600/P-98/002Aa
                                                               >       April 1998
 DO NOT QUOTE OR CITE                                -       External Review Draft
                      THE INVENTORY OF SOURCES OF
                       DIOXIN IN THE UNITED STATES
                                    NOTICE
THIS DOCUMENT IS AN EXTERNAL REVIEW DRAFT.  It has not been formally released by
the U.S. Environmental Protection Agency and should  not at this stage be construed to
represent Agency policy.  It is being circulated for comment on its technical accuracy and
policy implications.                                            ,            ,
                  Exposure Analysis and Risk Characterization Group
                   National Center for Environmental Assessment '
                        Office of Research and Development
                       U.S. Environmental Protection Agency
                               Washington, D.C.

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                                    DISCLAIMER
This document is an external review draft for review purposes only and does not constitute
U.S. Environmental Protection Agency policy. Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.

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                              TABLE OF CONTENTS
List of Tables . .	                        vjjj
List of Figures . .  .	                	     x::
Acknowledgements	 .  . .	....:........     	xiv

1.    INTRODUCTION	  ••:..../............:..........           1-2
      1.1.   DESCRIPTION OF DIOXIN-LIKE COMPOUNDS '. .  . ]'.'•'. '.  ••';'''''''' 1 3
      1.2   TOXICITY EQUIVALENCE FACTORS	 '. 1-4

2.    OVERVIEW OF SOURCES	                2-1
      2.1.   EMISSIONS INVENTORY METHODOLOGY ".'.'.'.'.'.'.'.'.'.'•"      	2-1
      2.2.   GENERAL FINDINGS OF THE EMISSIONS INVENTORY •'•"•.•••;•••• ^ ?
      2.3.   GENERAL SOURCE OBSERVATIONS	  2-10

3.    COMBUSTION SOURCES OF CDD/CDF: .WASTE INCINERATION                3-1
      3.1.   MUNICIPAL SOLID WASTE INCINERATION		  3-2
            3-1-1-   Descr'Ption of Municipal Solid Waste Incineration  Technologies  .  3-2
            3.1.2,   Characterization of MSWI Facilities in Reference Years 1995 and
                   1987	    3-7
            3.1.3.   Estimation of CDD/CDF Emissions from MSWIs	  3-8
            3.1.4.   Summary of CDD/CDF (TEQ) Emissions from MSWIs for 1995
                   and 1987	.....;		        .     3.^0
            3.1.5   Congener Profiles of MSWI Facilities	; .  3.11
           3.1.6   Estimated CDD/CDFs in MSWI Ash	 . ..........   .  3-11
           3.1.7   Current EPA Regulatory and Monitoring Activities  .            3-12
     3.2.  HAZARDOUS WASTE INCINERATION	]'m\'m  3.13
           3.2.1.   Furnace Designs for Dedicated Hazardous Waste Incinerators     3-14
           3.2.2.   APCDs for Dedicated Hazardous Waste Incinerators ........  3-16
           3.2.3.   Estimation of CDD/CDF Emission; Factors for Dedicated Hazardous
                   Waste Incinerators . . .	  3-17
           3.2.4..  Emission Estimates for Dedicated Hazardous Waste Incinerators  3-19
           3.2.5.   fndustrial Boilers and Furnaces Burning Hazardous Waste       3-21
     3.3.  MEDICAL WASTE INCINERATION		   m\ 3.22
           3.3.1.   Design Types,pf MWIs Operating in the United States . . ... . . 3-23
           3.3.2.   Characterization of MWIs for Reference Years 1995 and 1987 . 3-24
           3.3.3.  Estimation of CDD/CDF Emissions From MWIs	 . . 3 26
           3,3.4.  EPA/OAQPS Approach for Estimating CDD/CDF Emissions from
                  MWIs . . . ...	               3_27
                  3.3.4.1.  EPA/OAQPS Approach for Estimating Activity Level . 3-27
                  3.3.4.2.  EPA/OAQPS Approach for Estimating CDD/CDF
                           Emission Factors	          3-28
                                    HI

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                         TABLE OF CONTENTS (continued)


                    3.3.4.3.  EPA/OAQPS Approach for Estimating Nationwide
                             CDD/CDF TEQ Air Emissions  	  3-29
             3.3.5.  AHA Approach for Estimating CDD/CDF Emissions from MWIs .  3-30
             3.3.6.  EPA/ORD Approach for Estimating CDD/CDF Emissions from
                    MWIs	  3-31
                    3.3.6.1.  EPA/ORD Approach for Classifying MWIs and
                             Estimating Activity Levels	;  3.31
                    3.3.6.2.  EPA/ORD Approach for Estimating CDD/CDF Emission
                             Factors	„	  3-33
             3.3.7.  Summary of CDD/CDF Emissions From MWIs .....           3.34
       3.4.   CREMATORIA	      3.37
       3.5.   SEWAGE SLUDGE INCINERATION  .	3-38
       3.6.   TIRE COMBUSTION	.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'  3-40
       3.7.   COMBUSTION OF WASTEWATER SLUDGE AT BLEACHED CHEMICAL
             PULP MILLS	 .            3.42
       3.8.   BIOGAS COMBUSTION	 ............  3-43

4.     COMBUSTION SOURCES OF CDD/CDF: POWER/ENERGY GENERATION         4-1
       4.1.   MOTOR VEHICLE FUEL COMBUSTION			   4.-]
            4.1.1.  Tailpipe  Emission Studies	4.-)
            4.1.2.  Tunnel Emission Studies	  4.5
            4.1.3.  National Emission Estimates	              4.9
      4.2.   WOOD COMBUSTION	'.'.'.'.'.'.'.'.'.'.'.'.'.'.  4-15
            4.2.1.  Residential Wood Combustion	     4-16
            4.2.2.  Industrial Wood Combustion	                  4_19
      4.3.   OIL COMBUSTION	'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.  4-23
            4.3.1.  Residential/Commercial Oil Combustion	 . .	 .  4-23
            4.3.2.  Utility Sector and Industrial Oil Combustion 	             4-24
      4.4.   COAL COMBUSTION 	'.'.'.'.'.  4-25
            4.4.1.  Utilities and Industrial Boilers  	4_26
            4.4.2.'  Residential/Commercial Coal Combustion	4-28

5.     COMBUSTION SOURCES OF CDD/CDF:  OTHER HIGH TEMPERATURE
      SOURCES	                     g.., '
      5.1.   CEMENT KILNS  .	   5-1
            5.1.1.  Process Description of Portland Cement Kilns	5-1
            5.1.2.  Cement Kilns Burning Hazardous Waste	   5.3
            5.1.3.   Air Pollution Control Devices Used on Cement Kilns	 .   5-4
            5.1.4.   CDD/CDF Emission Factors for Cement Kilns . .	   5.4
            5.1.5.   National Estimates of CDD/CDF Emissions from Cement Kilns ...   5-7
            5.1.6.   Cement Kiln Dust  	                 5.9
      5.2.   ASPHALT MIXING PLANTS	      '	5 10
                                     IV

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                        TABLE OF CONTENTS (continued)


      5.3.   PETROLEUM REFINING CATALYST REGENERATION  .	; '.          5-12
      5.4,   CIGARETTE SMOKING	'....'.'.  5-15
      5.5.   PYROLYSIS OF BROMINATED FLAME RETARDANTS ......''. ]''. '. . . . .  5-18
      5.6.   CARBON REACTIVATION FURNACES  .....	 .	    5-19
      5.7.   KRAFT BLACK LIQUOR RECOVERY BOILERS  ... .  . . ..... ..... .    5-22
      5.8.   OTHER IDENTIFIED SOURCES . . . .	............. .". ...... .  5-24

 6.    COMBUSTION SOURCES OF CDD/CDF: MINIMALLY CONTROLLED AND
      UNCONTROLLED COMBUSTION SOURCES	 .	6-1
      6.1.   COMBUSTION OF LANDFILL GAS	!	  6-1
      6.2.   ACCIDENTAL FIRES . . ... .		  ... .'.'.'.'.]''.'.'.'.'.'.', 6-2
            6.2.1.   Soot/Ash Studies	 6-3
            6.2.2.   Fume/Smoke Studies . . . . . . . . .,.	 .	6-5
            6.2.3.   Data Evaluation	 .         6-6
      6.3.   LANDFILL FIRES  . . . .	..........!/.'..       6-8
      6.4.   FOREST AND BRUSH FIRES  	''.'.'.'.'.''.'.'.'.'.'.''.'. . . ""." '6_10
      6.5    BACKYARD TRASH BURNING ..............		  6-14
      6.6.   UNCONTROLLED  COMBUSTION OF POLYCHLORINATED BIPHENYLS
            (PCBS)	'.......	                6-15
      6,7.   VOLCANOES	 .,',.	..........  6-16

7.    METAL SMELTING AND REFINING SOURCES OF CDD/CDF  	. . . .	7-1
      7.1.   PRIMARY NONFERROUS METAL SMELTING/REFINING  ..........    7-1
      7.2.   SECONDARY NONFERROUS METAL SMELTING  . . . .	.........   7-2
            7.2.1.  Secondary Aluminum Smelters	 . . . .	*  7-2
            7.2.2.  Secondary Copper Smelters/Refiners  .	  7-5
            7.2.3.  Secondary Lead Smelters/Refiners	  7-7
      7.3.   PRIMARY FERROUS METAL SMELTING/REFINING . . , .	........ 7-10
            7.3.1  > Sinter Production	 . .	 7-10
            7.3.2 .  Coke Production	 712
            7.3.3   Electric Arc Furnaces	 '."	           7-13
      7,4    FERROUS FOUNDRIES	...*.....].... '. '.'.      7-14
      7.5.    SCRAP ELECTRIC  WIRE RECOVERY . .."......	 .  '.'. ...... 7-16
      7.6.    DRUM AND BARREL RECLAMATION FURNACES .........  . . . . . . ] . 7-18

8.    CHEMICAL MANUFACTURING AND PROCESSING SOURCES	..........  8-1
      8.1.   BLEACHED CHEMICAL WOOD PULP AND PAPER MILLS ........!!!!  8-1
      8.2.   MANUFACTURE OF CHLORINE, CHLORINE DERIVATIVES, AND METAL
           CHLORIDES	 ..	  8-5
           8.2.T.   Manufacture of Chlorine . . . .	.........'...  8-5
           8,2.2.   Manufacture of Chlorine Derivatives and Metal Chlorides  . . . . . .  8-6
                                   v

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                         TABLE OF CONTENTS (continiusd)


       8.3.   MANUFACTURE OF HALOGENATED ORGANIC CHEMICALS ....         8-7
             8.3.1.   Chlorophenols .	.8-7
             8.3.2.   Chlorobenzenes	            g_1Q
             8.3.3.   Chlorobiphenyls	           8-13
             8.3.4.   Polyvinyl Chloride	  8-16
             8.3.5.   Other Aliphatic Chlorine Compounds	  8-19
             8.3.6.   Dyes, Pigments,  and Printing Inks	~. ......  8-20
             8.3.7.   TSCA Dioxin/Furan Test Rule	       8-22
             8.3.8.   Halogenated Pesticides and FIFRA Pesticides Data Call-In        8-23
       8.4.   OTHER CHEMICAL MANUFACTURING AND PROCESSING SOURCES .  .  8-28
             8.4.1.   Municipal-Wastewater Treatment Plants	  8-28
             8.4.2.   Drinking Water Treatment Plants	  8-34
             8.4.3.   Soaps and Detergents	           8-34
             8.4.4.   Textile Manufacturing and Dry Cleaning	  8-36

9.     BIOLOGICAL SOURCES OF CDD/CDF	                   g.-,
       9.1.  BIOTRANSFORMATION OF CHLOROPHENOLS  ...     	  	9'-\
       9.2.  BIOTRANSFORMATION OF HIGHER CDD/CDFS	 . . . .' .' 9.4

10.   PHOTOCHEMICAL SOURCES OF CDD/CDF	                      10 •,
      10.1.  PHOTOTRANSFORMATION OF CHLOROPHENOLS	  	  101
      10.2.  PHOTOLYSIS OF HIGHER  CDD/CDFS	.'.'.'.'.'.'].'.' 10-3
            10.2.1  Photolysis in Water .	              10-3
            10.2.2  Photolysis on Soil	    10-4
            10.2.3  Photolysis on Vegetation	           10-6:
            10.2.4  Photolysis in Air	  1Q-6

11.    SOURCES OF DIOXIN-LIKE PCBs	 .                   -, -,  -,
      11.1.  GENERAL FINDINGS OF THE EMISSIONS INVENTORY	  111
      11.2  RELEASES OF COMMERCIAL PCBs 	'.'.'.'.['.  11-3
            11.2.1.  Approved PCB Disposal/Destruction Methods	  11-6
            11.2.2.  Accidental Releases of In-Service PCBs	'.'.'.'.'.'.  11-8
            11.2.3.  Municipal Wastewater Treatment	              11-11
      11.3.  CHEMICAL MANUFACTURING AND PROCESSING SOURCES	      11-13
      11.4.  COMBUSTION SOURCES  	!.'.'.'."'  11-13
            11.4.1.  Municipal Solid Waste Incineration .....'	  11-13
            11.4.2.  Industrial Wood Combustion	11-15
            11.4.3.  Medical Waste Incineration	      11-15
            11.4.4.  Tire Combustion   	    11-16
            11.4.5.  Cigarette Smoking	    11-17
            11.4.6.  Sewage Sludge Incineration	    11-18
                                    VI

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                       TABLE OF CONTENTS (continued)


      11.5. NATURAL SOURCES  ..	  11-18
           11.5.1. Biotransformation of Other PCBs	  11-18
           11.5.2. Photochemical Transformation oi Other PCBs	 . .  .  11-22

REFERENCES ......	 . ...	 . ....                 R.-,
                                   VII

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                                   LIST OF TABLES
 Table 1-1.    Toxicity Equivalency Factors (TEF) for CDDs and CDFs	 1-6
 Table 1-2.    Dioxin-Like PCBs  ........ :	      1-7
 Table 1-3.    Nomenclature, for Dioxin-Like Compounds	 1-8
 Table 2-1.    Confidence Rating Scheme for U.S. Emission Estimates	  2-12
 Table 2-2.    Dioxin-Like Compound Emission Inventory  for the United States
              (Reference Year 1995)	,,,2-13
 Table 2-3.    Dioxin-Like Compound Emission Inventory  for the United States
              (Reference Year 1987)	  2-16
 Table 2-4.    CDD/CDF TEQ Emission Factors Used to Develop National Emission
              Inventory Estimates of Releases to Air	     2-22
 Table 2-5.    Order of Magnitude Estimates of CDD/CDF Air Emissions from Sources
              Not Quantified in the National inventory (Reference Year 1995)  ......  2-24
 Table 2-6.    CDD/CDF. Air Emission Inventories for West Germany, Austria, The
              Netherlands, Switzerland, Belgium, and the United  Kingdom	  2-25
 Table 3-1.    Inventory of MSWIs in 1995 by Technology, APCD, and Activity Level  .  3-53
 Table 3-2.    Inventory of MSWIs in 1987 by Technology, APCD, and Annual Activity
              Level	3.55
 Table 3-3.    Dioxin TEQ Emission Factors (ng TEQ per kg waste) for Municipal Solid
             Waste Incineration	  3.57
 Table 3-4.   Annual TEQ Emissions (g/yr) From MSWIs Operating in 1995	'.'.  3-59
 Table 3-5.   Annual TEQ Emissions to the Air From MSWIs Operating in 1987	3-60
 Table 3-6.    CDD/CDF Emission Factors for Hazardous Waste Incinerators and Boilers  3-62
 Table 3-7.    Summary of Annual Operating Hours for Each MWI Type	  3-65
 Table 3-8.    OAQPS Approach:  PM Emission Limits for MWIs and Corresponding
             Residence Times in the Secondary Combustion Chamber	 3-66
 Table 3-9.    OAQPS Approach:  Estimated Nationwide CDD/CDF TEQ Emissions (g/yr)
             for 1995	                   3_67
 Table 3-10.   AHA Approach: TEQ Emission Factors Calculated for Air Pollution
             Control		... l	  3-68
 Table 3-11.   AHA Assumptions of the Percent Distribution of Air Pollution Control
             on MWIs Based on  PM Emission Limits	  3.59
 Table 3-12.   AHA Approach: Estimated Annual Nationwide CDD/CDF TEQ Emissions   3-70
 Table 3-13.   Comparison Between Predicted  Residence Times and Residence Times
             Confirmed by State Agencies from EPA/ORD Telephone Survey  	3-71
 Table 3-14.   EPA/ORD Approach: Annual TEQ Emissions from Medical Waste
             Incineration (MWI) for  Reference Year 1995	  3-72
 Table 3-15.   Summary of Annual TEQ Emissions from Medical Waste Incineration  (MWI)
             for Reference Year  1987 . . .	':...'              3.75
Table 3-16.   Comparisons of Basic Assumptions Used in the EPA/ORD, the EPA/OAQPS,
             and the AHA Approaches to Estimating  Nationwide CDD/CDF TEQ   '
             Emissions from MWIs in 1995	          3.75
                                       VIII

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                             LIST OF TABLES (continued)
  Table 3-17.   GDD/CDF Air Emission Factors for a Crematorium .... . .... .	 3.77
  Table 3-18.   CDD/CDF Emission Factors for Sewage Sludge Incinerators	 . 3.79
  table 3-19.   CDD/CDF Air Emission Factors for Tire Combustion .	 .  . '. . . 3-81
  Table 3-20.   CDD/CDF Emission Factors for Combustion of Bleached-Kraft Mill Sludge
              in Wood Residue Boilers		            • 3.33
  Table 4-1.    Descriptions and Results of Vehicle Emission Testing Studies for CDDs
              and CDFs	        ......           4 30
  Table 4-2.    Diesel-Fueled Automobile CDD/CDF Congener Emission Factors ".'.'.'.'. '. 4-31
  Table 4-3.    Diesel-Fueled Truck CDD/CDF Congener Emission Factors ...........  4-32
  Table 4-4.    Leaded Gasoline-Fueled Automobile CDD/CDF Congener Emission
              Factors		                        4-33
  Table 4-6.    Unleaded Gasoline-Fueled (With Catalytic Converters) Automobile
              CDD/CDF Congener Emission Factors	         4.35
 Table 4-7.    European Tunnel Study Test Results	"... '. ' '  4.39
 Table 4-8.    Baltimore Harbor TunnelStudy: Estimated Emission Factors for Heavy-Dutv
              (HD) Diesel Vehicles	              4.40
 Table 4-9.   CDD/CDF Concentrations in Residential Chimney Soot from Wood Stoves
             and Fireplaces	                 4-42
 Table 4-10.  CDD/CDF Concentrations in Residential Bottom Ash from Wood Stoves
             and Fireplaces .... .  ,	                   4-43
 Table 4-11.  CDD/CDF Concentrations in Chimney Soot (Bavaria, Germany)  . . . . . '.  .  4.44
 Table 4-12.  CDD/CDF Emission Factors  for Industrial Wood Combustors <......     4.4-5
 Table 4-13.  Estimated CDD/CDF Emission Factors for Oil-Fired Residential Furnaces  '.  4-47
 Table 4-14.  CDD/CDF Emission Factors  for Oil-Fired Utility/Industrial Boilers  ......  4-49
 Table 4-15.  CDD/CDF Concentrations in Stack Emissions from U.S. Coal-Fired
             Power Plants                                 '                   4-51
 Table 4-16.  Characteristics of U.S. Coal-Fired Power Plants Tested by DOE ....... 4-52
 Table 4-17.   CDD/CDF  Emission Factors  for.Coal-Fired Utility/Industrial Power " ' : "••
             Plants			 4-53
 Table 4.-18.   CDD/CDF  Emission Factors  from Residential Coal Combwstors ......    4-55
 Table 5-1.    CDD/CDF  Emission Factors  for Cement Kilns	 5-26
 Table 5-2.    CDD Concentrations in Japanese Cigarettes, Smoke and Ash	 5-29
 Table 5-3.    CDD/CDF Emissions in  Cigarette Smoke	       .    5.31
 Table 5-4.    CDD/CDF Concentrations in Cigarette Tobacco. ................'. 5.33
 Table 5-5.    CDD/CDF Emission  Factors for Black Liquor Recovery  Boilers  '. . . . .  '; '. . 5.35
 Table 5-6.     Concentrations of CDD/CDF in Candle Materials and Emissions ...... 5-37
 Table 6-1.     CDD/CDF Emission  Factors for a Landfill Flare ........  .-;.  .      .    6-18
 Table 6-2.     CDD/CDF in Dust Fall and Ashes from Volcanoes ............ . .  . ; . 6-20
 Table 7-1.     CDD/CDF Emission  Factors for Secondary Aluminum Smelters  '.'.'.'.'.'.'.. 7-21
 Table 7-2.     CDD/CDF Emission  Factors for a Secondary Copper Smelter .........  7-23
Table 7-3.     CDD/CDF Emission  Factors for Secondary Lead Smelters  ...  .....] . [  7-25
Table 7-4.     Operating Parameters for U.S.  Iron Ore Sinter Plants 	....'. '.  . . .  7-27
                                       IX

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                              LIST OF TABLES (continued)
  Table 7-5.   CDD/CDF Emission Factors for a Ferrous Foundry	  7-28
  Table 7-6.   CDD/CDF Emission Factors for a Scrap Wire Incinerator	  7-30
  Table 7-7.   Geometric Mean CDD/CDF Concentrations in Fly Ash and Ash/Soil at
              Meta| Recovery Sites	   7-32
  Table 7-8.   CDD/CDF Emission Factors for a Drum and Barrel Reclamation Furnace  .  7-33
  Table 8-1.   CDD/CDF Concentrations in Pulp and Paper Mill Bleached Pulp, Wastewater
              Sludge, and Effluent (circa 1988}	      8-40
  Table 8-2.   CDD/CDF Concentrations in Pulp and Paper Mill Bleached Pulp, Wastewater
              Sludge, and Effluent (circa 1996'	,	  8-44
  Table 8-3.   Summary of Bleached Chemical Pulp and Paper Mill Discharges
              of 2,3,7,8-TCDD and 2,3,7,8-TCDF			;	8-45
  Table 8-4.   CDD/CDF Concentrations in Graphite Electrode Sludge from Chlorine
              Production	        8-46
  Table 8-5.    CDD/CDF Concentrations in Metal Chlorides	  8-47
  Table 8-6.    CDD/CDF Concentrations in Mono- through Tetra-Chlorophenols	  8-48
  Table 8-7.    Historical CDD/CDF Concentrations in Historical and Current Technical
              Pentachlorophenol  Products  	          8-49
 Table 8-8.    Historical CDD/CDF Concentrations in Pentachlorophenol-Na	;'.'.'.  8-51
 Table 8-9.    Summary of Specific Dioxin-Containing Wastes That  Must Comply with
              Land Disposal Retrictions	            8-52
 Table 8-10.   CDD/CDF Concentrations in Chlorobenzenes	  ......  8-54
 Table 8-11.   Concentrations  of CDD/CDF Congener Groups in Unused Commercial
              PCB Mixtures	        8.55
 Table 8-12.   2,3,7,8-Substituted Congener Concentrations in Unused PCB Mixtures .  8-56
 Table 8-13.   Reported CDD/CDF Concentrations in Wastes from PVC Manufacture  ..  8-57
 Table 8-14.   CDD/CDF Measurements in Products  and Treated Wastewater from
              U.S. PEDC/VCM/PVC Manufacturers	  8-58
 Table 8-15.   CDD/CDF Concentrations in Dioxazine Dyes and Pigments (Canada)   . . .  8-59
 Table 8-16.   CDD/CDF Concentrations in Printing Inks (Germany	  8-60
 Table 8-17.   Chemicals Requiring TSCA Section 4  Testing Under the Dioxin/Furan Rule  8-61
 Table 8-18.   Congeners and Limits of Quantitation (LOQ) for Which Quantitation is
              Required  Under  the Dioxin/Furan Test Ruleand Pesticide Data Call-l ....  8-62
 Table 8-19.   Precursor  Chemicals Subject to  Reporting  Requirements Under TSCA
             Section 8(a)   . . .	        8-63
 Table 8-20.  Results of Analytical Testing for Dioxins and Furans in the Chemicals
             Tested To-Date	             8-64
 Table 8-21.  CDDs and CDFs in Chloranil and Carbazole Violet Samples Analyzed
             Pursuant to the  EPA Dioxin/Furan Test Rule  	  8-65
 Table 8-22.  Status of First Pesticide Data-Call-in:  Pesticides Suspected of  Having t
             the Potential to Become Contaminated with Dioxins if Synthesized under
             Conditions Favoring Dioxin Formation	  8-67
Table 8-23.  Status of Second Pesticide Data-Call-in: Pesticides Suspected of Being
             Contaminated with Dioxins	          8-71

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                             LIST OF TABLES (continued}


  Table 8-24.   Summary of Results for CDDs and CDFs in Technical 2,4-D and 2,4-D
              Ester Herbicides ...............................          8-74
  Table 8-25.   Summary of Analytical Data Submitted to EPA in Response to Pesticide
              Data Call-Ins	 .	   '        8 75
  Table 8-26.   CDD/CDF Concentrations in Samples of 2,4-D and Pesticide Formulations
              Containing 2,4-D	 . .	                  8-77
  Table 8-27.   Mean CDD/CDF Measurements in Effluents from Nine U.S. POTWs  .  . / 8-78
  Table 8-28.   CDD/CDF Concentrations Measured in EPA's National Sewage Sludge
           ... 'Survey	 . ...	 . ...	  8.79
  Table 8-29.   CDD/CDF Concentrations Measured in 99 Sludges Collected from ,75   '
              U.S. POTWs During 1994	          8-80
  Table 8-30.   Quantity of Sewage Sludge Disposed Annually by Primary, Secondary,
              or Advanced Treatment POTWs and Potential Dioxin TEQ Releases  ...  8-82
  Table 8-31.   CDD/CDF Concentrations in Swedish Liquid Soap, Tall Oil, and Tall Resin  8-83
  Table 11 -1.   Current  Dioxin-Like PCB Emission Estimates for the United States
              (Reference Year 1995)	          1 -j_24
  Table 11-2.  Current  Dioxin-Like PCB Emission Estimates for the United States "''...
             (Reference Year 1987)	"....•	              11-25
 Table 11 -3.  Weight Percent Concentrations of Dioxin-like PCBs in Aroclors, Clophens,
             and Kanechlors .".......-...!........	          'l 1-26
 Table 11-4.  Disposal Requirements for PCBs and PCB Items,....	  11-28
 Table 11-5.(  Off site Transfers of PCBs Reported in TRI (1988-1993)  .	  .  11-29
 Table 11-6.  Releases of PCBs Reported in TRI (1988-1993)	'....'.'.'.'.'.'.'.  11-30
 Table 11-7.  Aroclor Concentrations Measured in EPA's National Sewage Sludge
             Survey	  il-31
 Table 11-8.  Dioxin-Like PCB Concentrations Measured in 99 Sludges Collected from
             75 U.S.  POTWs During 1994	        11-32
 Table 1J-9.  Quantity of Sewage Sludge Disposed Annually by Primary, Secondary,
             or Advanced Treatment POTWs and Potential Dioxin-Like PCB TEQ
             Releases	•                     11.33
 Table 11-10.  PCB Congener Group Emission Factors for Industrial Wood Combustors   11-34
 Table 11-11.  PCB Congener Group Emission Factors for Medical Waste Incinerators
             (MWIs) ,	.v...		....	... n-35
 Table 11-12.  PCB Congener Group Emission Factors for a Tire Combustor ........ 11-36
 Table 11-13.  Dioxin-Like PCB Concentrations in Cigarette Tobacco ........ . . . . ; 11-37
 Table 11-14.  Estimated Tropospheric Half-Lives of Dioxin-Like PCBs with Respect to
             Gas-Phase Reaction with the OH  Radical  . . . .	   11-38
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                                   LIST OF FIGURES
 Figure 1-1.   Chemical Structure of 2,3,7,8-TCDD and Related Compounds  	, . .  1-4
 Figure 2-1.   Estimated CDD/CDF TEQ Emissions to Air from Combustion Sources in
              the United States (Reference Time Period: 1,995}  	  2-19
 Figure 2-2.   Estimated CDD/CDF TEQ Emissions to Air from Combustion Sources in
              the United States (Reference Time Period: 1987)  	  2-20
 Figure 2-3.   Comparison of Central Tendency Estimates of Annual TEQ Emissions to
              Air (grams/year) for Reference Years 1987 and 1995	  2-21
 Figdre 3-1.   Typical Mass Burn Waterwafl Municipal Solid Waste Incinerator	  3-45
 Figure 3-2.   Typical Mass Burn Rotary Kiln Combustor .	  3-46
 Figure 3-3.   Typical Modular Excess:Air Combustor	  3-47
 Figure 3-4.   Typical Modular Starved-Air Combustor with Transfer Rams	  3-48
 Figure 3-5.    Typical Dedicated RDF-Fired Spreader Stoker Boiler ....   	  3.49
 Figure 3-6.    Fluidized-Bed RDF Incinerator	3.50
 Figure 3-9.    Congener and Congener Group Profiles for Air Emissions from a Mass-Burn
              Waterwall MSWI, Equipped with a Dry Scrubber and Fabric Filter  . . .  . ;  3-61
 Figure 3-10.   Congener Profile for Air Emissions from Hazardous Waste Incinerators  . .  3-63
 Figure 3-11.   Congener and Congerier Group Profiles for Air Emissions fromBoilers
              and Industrial Fu	  3-64
 Figure 3-12.   Congener and Congener Group Profiles for Air Emissions  ...........  3-73
 Figure 3-13.   Congener and Congener Group Profiles for Air Emissions from Medical  . .  3-74
 Figure 3-14.   Congener and Congener Group Profiles for Air Emissions from a
              Crematorium	 3-78
 Figure 3-15.   Congener and Congener Group Profiles for Air Emissions from Sewage
              Sludge Incinerators	,	._ 3.30
 Figure 3-16.   Congener and Congener Group Profiles for Air Emissions from a Tire
              Combustor	 3_82
 Figure 3-17.  Congener and Congener Group Profiles for Air Emissions from Bleached
             Kraft Mill Combustors	 3-84
 Figure 4-1.   Congener and Congener Group Profiles for Air Emissions from
             Diesel-fueled Vehicles	 4-36
 Figure 4-2.   Congener and Congener Group Profiles for Air Emissions from Leaded
             Gas-fueled Vehicles	4-37
 Figure 4-3.   Congener and Congener Group Profiles for Air Emissions from Unleaded
             Gas-fueled Vehicles .'.	 . . . 4-38
 Figure 4-4.   Tunnel Air Concentrations	 4-41
 Figure 4-5.   Congener and Congener Group Profiles for Air Emissions from Industrial
             Wood Combustors	4.45
 Figure 4-6.   Congener Group Profile for Air Emissions from Residential Oil-fueled
             Furnaces	4-43
Figure 4-7.   Congener and Congener Group Profiles for Air Emissions from Industrial
             Oil-fueled Boilers	 4-50
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                             LIST OF FIGURES (continued)


 Figure 4-8.   Congener and Congener Group Profiles for Air Emissions from
            , Industrial/Utility Coal-fueled Combustors	  4-54
 Figure 4-9.   Congener Group Profile for Air Emissions from Residential  Coal-fueled
             Combustors .............. . . .	         4-56
 Figure 5-1.   Congener Profile for Air Emissions from Cement Kilns Burning Hazardous
             Waste	."....'.........:	  .......  5-27
 Figure 5-2.   Congener and Congener Group Profiles for Air Emissions from Cement
             Kilns Not Burning Hazardous Waste		; . .    5.28
 Figure 5-3.   CDD Profiles for Japanese Cigarettes, Smoke, and Ash	  5-30
 Figure 5-4.   Congener Group Profiles for Mainstream and Sidestream Cigarette
             Smoke	Jf	                5-32
 Figure .5-5.   Congener Group Profiles for Cigarette Tobacco from Various Countries  .  5 34
 Figure 5-6.   Congener and Congener Group Profiles for Air Emissions from Kraft
             Black Liquor Recovery Boilers  .		  5.35
 Figure 6-1.   Congener Profile for Landfill Flare Air Emissions .	  6-19
 Figure 7-1.   Congener and Congener Group Profiles for Air Emissions from Secondary
             Aluminum Smelters	  7-22
 Figure 7-2.   Congener Group Profile for Air Emissions from a Secondary Copper
             Smelter/Refiner	           7-24
 Figure 7-3.   Congener and  Congener Group Profiles for Air Emissions from Secondary
             Lead Smelters/Refiners  ...,;.	  7-26
 Figure 7-4.   Congener and  Congener Group Profiles for Air Emissions from a Ferrous
             Foundry		         _,  . ,  7.29
 Figure 7-5,.   Congener Group Profile for Air Emissions from a Scrap Wire Incinerator .  7-31
 Figure 7-6.   Congener Group Profile for Air Emissions from a Drum Incinerator  . . , . .  7-34
 Figure 8-1.   104-Mill Study Full Congener Analysis Results for Pulp ... . . .	  8-41
 Figure 8-2.   104-Mill Study Full Congener Analysis Results for Sludge .....  . . . . .  8-42
 Figure 8-3.   104-Mill Study Full Congener Analysis Results for Effluent  , ........ .  8-43
 Figure 8-4.   Congener and Congener Group Profiles for Technical PCP	  8-66
 Figure 8-5.   Congener Profile for 2,4-D (salts and esters)  .......;...........  8-76
Figure 8-6.   Congener Profiles for Sewage Sludge	  8-81
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                              ACKNOWLEDGEMENTS

       The National Center for Environmental Assessment (NCEA) within EPA's Office of
Research and Development was responsible for the preparation of this document.  General
support was provided by Versar Inc. under EPA Contract Number 68-D5-0051. Dave
Cleverly of NCEA served as the EPA Work Assignment Manager (as well as contributing
author) providing overall direction and coordination of the production effort as well as
technical assistance and guidance.
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                                  1. INTRODUCTION

        In 1992, the U.S. Environmental Protection Agency's (EPA's) Office of Research and
  Development (ORD) began an effort to reassess the exposure and health effects associated
  with dioxin. As originally conceived and drafted, the .exposure portion of the Reassessment
  did not include an emissions inventory component. ORD was concerned that there was
  inadequate test data to construct an inventory and that the time and resources needed to
  conduct  an extensive testing program was outside the scope of the Reassessment. In
  1992, special workshops were held to provide expert review and comment on early drafts
  of both the exposure and health components of the Reassessment.  Reviewers of these
  early drafts strongly urged  EPA to attempt an emissions inventory using the available data.
  Responding to this suggestion, an inventory was developed and first published in
  September 1994 as part of the overall draft Reassessment.
        The draft Reassessment underwent reviews by both the public and EPA's Science
  Advisory Board (SAB). The SAB supported the general approach used to produce the draft
  inventory, but suggested several changes. Most notably, the SAB recommended that the
  inventory be specific about the time:frame it represents:  The SAB did not suggest that any
  of the exposure chapters including the emissions inventory be resubmitted for SAB review.
        In addition to SAB comments, EPA received a number of public comments regarding
 the emission inventory.  In response to all of these comments and the availability of
 additional data,  a number of changes have been made to the inventory since the 1994
 draft.  These changes have resulted  in significant revisions to both the inventory structure
 and actual emission estimates.  Consequently, ORD has decided it would be prudent to
 conduct an additional round of peer review of the revised inventory before incorporating it
jinto the final Reassessment. The purpose of this document is to provide to the peer
 reviewers and interested members of the public, ORD's most recent estimates of dioxin
   ...-"•.                   .          -          .               /
 emissions for the years 1987 and 1995 along'with a detailed description of the analytical
 process and rationale that support these estimates. The peer review of the dioxin  emission
 inventory will be conducted by an expert panel at a meeting to be held June 3-4, 1998, in
 the Washington, D.C. area.  EPA will use the comments of the peer review  panel to help
 guide final revisions to the inventory which will be published as a part of the final
 Reassessment.                                                 .,'•••  u

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         The inventory is supported by an extensive emissions data base. This data base is
  available in conjunction with this report on a compact disk (CD). The data base includes all
  emission test data and activity level data used to derive the inventory.  Because of the
  complexity of this data base, ORD elected to have it independently audited for the accuracy
  of data inputs and calculations.

  1.1.   DESCRIPTION OF DIOXIN-LIKE COMPOUNDS
        This document addresses compounds in the following chemical classes:
  polychlorinated dibenzo-p-dioxins (PCDDs or CDDs), polychlorinated dibenzofurans (PCDFs
  or CDFs),  polybrominated  dibenzodioxins (PBDDs or BDDs), polybrominated dibenzofurans
  (PBDFs or BDFs}, and polychlorinated biphenyls (PCBs). The CDDs include 75 individual
  compounds, and CDFs include 135 different compounds. These individual compounds are
  technically referred to as congeners.  Likewise, the BDDs include 75 different congeners,
  and the BDFs include an additional 135 congeners.  Only 7 of the 75 congeners of CDDs or
  of BDDs are thought to have dioxin-like toxicity; these are ones with chlorine/bromine
  substitutions in, at least, the 2, 3, 7, and 8 positions.  Only 10 of the 135 possible
 congeners of CDFs or of BDFs are thought to have dioxin-like toxicity; these also are ones
 with substitutions in the 2, 3, 7, and 8 positions.  While this suggests 34 individual CDDs,
 CDFs, BDDs, or BDFs with dioxin-like toxicity, inclusion of the mixed chloro/bromo
 congeners substantially increases the number of possible congeners with dioxin-like
 activity. There are 209 PCB congeners. Only 13 of the 209 congeners are thought to
 have dioxin-like toxicity; these are PCBs with four or more chlorines with just one or no
 substitution in the ortho position. These compounds are sometimes referred to as coplanar,
 meaning that they can assume a flat configuration with rings in the same plane.  Similarly
 configured polybrominated biphenyls are likely to have similar properties; however, the data
 base on these compounds, with regard to dioxin-like activity, has been less extensively
 evaluated. Mixed chlorinated and brominated congeners also exist, increasing the number
 of compounds considered dioxin-like.
       The physical/chemical properties of each  congener vary according to the degree and
 position of chlorine and/or bromine substitution.  Very little is known about occurrence and
toxicity of the mixed  (chlorinated and brominated) dioxin, furan, and biphenyl congeners.
The chlorinated and brominated dibenzodioxins and dibenzofurans are tricyclic aromatic
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 structurally.  Certain PCBs (the so-called coplanar or mono-ortho coplanar congeners) are.
 also structurally and conformationally similar.  The most widely studied of these
 compounds is 2,3,7,8-tetrachlorodibenzo-p-dioxm (TCDD)..  This compound, often called
 simply dioxin, represents the reference compound for this class of compounds. The
 structure of 2,3,7,8-TCDD and several related compounds is shown in Figure  1-1.
         Figure 1-1. Chemical Structure of 2,3,7,8-TCDD and Related Compounds
            Cl
              2,3,7,8-Tetrachlorodibenzo-p-dioxin
                                              Cl
2,3,7,8-Tetrachlorodibenzofuran
            ci
                         o .
             1,2,3,7,8-Pentachlorodibenzo-p-dioxin
                                              CK
2,3,4,7,8-Pentachlorodibenzofuran
               ci
              3,3',4,4',5,5'-Hexachlorobiphenyl
3,3',4,4',5-Pentachlorobiphenyl
1.2    TOXICITY EQUIVALENCE FACTORS
       The dioxin-like compounds are often found in complex mixtures. For risk
assessment purposes, a toxicity equivalency procedure was developed to describe the
cumulative toxicity of these mixtures., This procedure involves assigning individual toxicity
equivalency factors (TEFs) to the 2,3,7,8 substituted CDD/CDF congeners.  These TEF
values have been adopted by international convention (U.S. EPA, 1989).  Subsequent to
the development of the TEFs  for CDD/CDFs, TEFs were also developed for PCBs {Ahlborg
et al., 1994). TEFs are estimates of the toxicity of dioxin-like compounds  relative to'the
toxicity of 2,3,7,8-TCDD, which is assigned a TEF of 1.0.  All other congeners have  lower
TEF values ranging from 0.5 to 0.00001,.  Generally accepted TEF values for CDD/CDFs
and PCBs are shown in Table 1-1 and Table 1j2, respectively.
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 TEF values ranging from 0.5 to 0.00001. Generally accepted TEF values for CDD/CDFs
 and PCBs are shown in Table 1-1 and Table 1-2, respectively.
        Calculating the toxic equivalency (TEQ) of a mixture involves multiplying the
 concentration of individual congeners by their respective TEF. The sum of the TEQ
 concentrations for the individual congeners is the TEQ concentration for the mixture.
        It should be recognized that revisions to the TEFs are periodically considered as new
 scientific information becomes available. If revisions in the TEFs are adopted, then it would
 be appropriate to adjust the TEQ release estimates calculated in the inventory.    '
       For purposes of this document, certain naming conventions have been adopted.  All
 quantities representing TEQs are labeled as TEQs. Unless specified otherwise, TEQ values
 refer to CDD/CDFs and not other dioxin-like compounds.  A complete list of abbreviations
 and naming conventions are presented in Table 1-3. The phrase  "dioxin-like compounds"
 technically would include all the 2,3,7,8 substituted chlorinated and  brominated dioxins and
 furans, the 2,3,7,8 substituted chlorobromo dioxins and furans, and the coplanar PCBs.  In
 this document, however, because of the extremely limited data on the bromo and
 chlorobromo compounds, this phrase refers only to the  2,3,7,8-substituted CDD/CDFs and
coplanar PCBs.
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           Table 1-1.  Toxicity Equivalency Factors (TEF) for CDDs and CDFs
                  Compound
 TEF
  Mono-, Di-, and Tri-CDDs
  2,3,7,8-TCDD
  Other TCDDs
  2,3,7,8-PeCDD
  Other PeCDDs
  2,3,7,8-HxCDD
  Other HxCDDs
  2,3,7,8-HpGDD
  Other HpCDD
  OCDD
  0
  1
  0
 0.5
  0
 0.1
  0
 0.01
  0
0.001
  Mono-, Di-, and Tri-CDFs
  2,3,7,8-TCDF
  Other TCDFs
  1,2,3,7,8-PeCDF
  2,3,4,7,8-PeCDF y
  Other PeCDFs
  2,3,7,8-HxCDF
  Other HxCDFs
  2,3,7,8-HpCDF
  Other HpCDFs
  OCDF
  0
 0.1
  0
 0.05
 0.5
  0
 0.1
  0
 0.01
  0
0.001
Source:  U.S. EPA (1989)
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                            Table 1 -2.  Dioxin-Like PCBs
IUPAC No.
77
105
114
, 118
123
126
156
157
167
169
170
180
189
Compound
3,3',4,4'-TCB
2,3,3',4,4'-PeCB
2,3,4,4', 5-PeCB
2,3',4,4',5-PeCB
2',3,4,4',5-PeCB
3,3',4,4',5-PeCB
2,3,3',4,4',5-HxCB
2,3,3',4,4',5I-HxCB
2,3',4,4',5,5'-HxCB
3,3',4,4',5,5'-HxCB
2,2',3,3',4,4',5-HpCB
2,2',3,4,4',5,5'-HpCB
2,3,3',4,4',5,5'-HpCB -
TEF
0.0005
0.0001
0.0005
0.0001
0.0001
0.1
0.0005
0.0005
0.00001
0.01
0.0001
0.00001
0.0001
Source:  Ahlborg et al. (1994)
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                 Table 1-3.  Nomenclature for Dioxin-Like Compounds
Term/Symbol
Congener
Congener
Group .
Isomer
Specific
Isomer
D
F
M
D ,
Tr
T
Pe
Hx
Hp
0
CDD
CDF
PCB
2378
Definition
f • • . • • -
Any one particular member of the same chemical family )e.g., there are 75 congeners of
chlorinated dibenzo-p-dioxins).
Group of structurally related chemicals that have the same degree of chlorination (e.g.,
there are eight congener groups .of CDDs, monochlorinated through octochlorinated).
Substances that belong to the same congener group (e.g., there are 22 isomers that
constitute the congener group of TCDDs).
Denoted by unique chemical notation (e.g:, 2,4,8, 9-tetrachlorodibenzofuran is referred to
as 2,4,8,9-TCDF). - •
Symbol for congener class: dibenzo-p-dioxin , •
Symbol for congener class: dibenzofuran
Symbol for mono (i.e., one halogen substitution)
Symbol for di (i.e., two halogen substitution) ,
Symbol -for tri (i.e., three halogen substitution)
Symbol for tetra (i.e., four halogen substitution)
Symbol for penta (i.e., five halogen substitution) .
Symbol for hexa (i.e., six halogen substitution)
Symbol for hepta (i.e., seven halogen substitution)
Symborfor octa (i.e., eight halogen substitution)
Chlorinated dibenzo-p-didxins, halogens substituted in any position
Chlorinated dibenzofurans, halogens substituted in'any position
Polychlorinated biphenyls
Halogen substitutions in the 2,3,7,8 positions
Source: Adapted from U.S. EPA (1989)
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                             2.  OVERVIEW OF SOURCES

        This report summarizes information on the release of CDD/CDFs and dioxin-like PCBs
 to the environment from known and suspected source categories. Where possible, national
 estimates have been made of annual releases from source categories in the United States.
 This collection of emission estimates is referred to' as the national inventory. The emission
 factors and other information used to support development of this inventory are contained
 in the comprehensive National Database of Sources of Environmental Releases of Dioxin-
 Like Compounds in the United States.  This is an electronic database using a spreadsheet
 format  developed by EPA specifically for this effort. The database addresses both
 combustion and non-combustion source categories.  For some source categories, emission
 factors are developed according tp type of technology and type of pollution control systems.
 employed. This electronic database has been published on a compact disk and is available
 as a companion to this document.
       This overview chapter explains the process used by EPA to derive these emission
 estimates and also summarizes general findings and  observations.  The remainder of the
 document discusses CDD/CDF and dioxin-like PCB emissions on a source category basis.
          '                  -                        ^
 2.1.  EMISSIONS INVENTORY METHODOLOGY
      In the United States, the major identified sources of environmental release have
 been grouped into the following classes for the purposes of this report:

      Combustion Sources: CDD/CDFs are formed in most combustion systems  These can
      include waste incineration (such as municipal  solid waste, sewage sludge, medical
      waste, and hazardous wastes), burning of various fuels (such as coal, wood, and
      petroleum products), other high temperature sources (such as  cement kilns),'and
      poorly controlled combustion sources (such as building fires).
•  ,   Metals Smelting and Refining Sources and Processing Sources: CDD/CDFs can be
      formed during various types of primary and secondary metals operations including
      iron ore sintering, steel production,  and scrap  metal recovery.
      Chemical Manufacturing: CDD/CDFs can be former! ** hy-prr>H.,V^ frnm the
      manufacture of chlorine bleached wood pulp,  chlorinated phenols (e.g.,
      pentachlorophenol - PCP), PCBs, phenoxy herbicides (e.g., 2,4,5-T), and chlorinated .
      aliphatic compounds (e.g., ethylene dichlpride).
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 *      Biological and Photochemical Processes: Recent studies have suggested that
        CDD/CDFs can be formed under certain environmental conditions (e.g., composting)
        from the action of microorganisms on chlorinated phenolic compounds.  Similarly,
        CDD/CDFs have been reported to be formed during photolysis of highly chlorinated
        phenols.

 •      Reservoir Sources:  Reservoirs are materials or places which contain previously
        formed CDD/CDFs or dioxin-like PCBs and have the potential for redistribution and
        circulation of these  compounds into the environment.  Potential reservoirs include
        soils, sediments, vegetation, and PCP-treated wood. Recently, CDD/CDFs have
        been discovered in ball day deposits. Although the origin of the CDD/CDFs in these
        clays has not been confirmed, natural occurrence is a possibility.

        For sources in each  of the above classes (with the exception of Reservoir Sources),

 emission estimates have been made in this report for air, land, water and products.  Only

 releases to the "circulating  environment" were included in the inventory. The system
 boundaries are further defined as follows:


 •      CDD/CDFs and dioxin-like PCBs in final products and waste discharges were
       included whereas CDD/CDFs and dioxin-like PCBs in  intermediate products or waste
       streams were excluded.  For example, the CDD/CDFs in a waste stream going to an
       incinerator would  not be included in the inventory but any CDD/CDFs in the stack
       emissions would be  included.

       CDD/CDFs and dioxin-like PCBs in waste streams applied to land in the form of "land
       farming" are included whereas those disposed in permitted landfills were excluded.
       Properly designed and operated landfills are considered to achieve long term isolation
       from the circulating environment.  Land farming, however, involves the application
       of wastes directly to land, clearly allowing for releases  to the circulating
       environment.

       Commercial products which  contain CDD/CDFs or dioxin-like PCBs and whose
       subsequent use may result in releases to the environment were included in the
       inventory. Examples include paper pulp, sewage sludge that is distributed/marketed
       commercially,  and certain pesticides.

       The EPA's Science Advisory Board (SAB) reviewed an earlier draft of the national
                                                                                r*
dioxin source emissions inventory and commented that the effort was comprehensive and

inclusive of most known sources (U.S. EPA,  1995f).  However, the SAB emphasized that

source emissions are time-dependant, and recommended that emissions be associated with

a specific time reference. In consideration of these comments, EPA has developed in this

report emission estimates for two years: 1987 and  1995.
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        1987 was selected primarily because, prior to this time, little empirical data existed
 for making source specific emission estimates. The first study providing the type of data
 needed for a national inventory was EPA's National Dioxin Study  (U.S. EPA, 1987a). The
 year 1987 also corresponds roughly with the time that significant advances occurred in
 emissions measurement techniques and in the development of high resolution mass
 spectrometry and gas chromatography necessary for analytical laboratories to achieve low
 level detection of CDD and CDF congeners in environmental samples.  Soon after this time,
 a number of facilities began upgrades specifically intended to  reduce CDD/CDF emissions.
 Consequently, 19871s also the latest time representative of the emissions occurring before
 widespread installation of dioxin-specific emission controls.
        1995 was selected as the latest time period that could practically be. addressed
 consistent with the time table for producing the rest of the document. The data collected
 in the companion document to this document on CDD/CDF and dioxin-like PCB levels in
 environmental media and food were used to characterize conditions in the mid-1990's.  So
 the>missiqns data and media/food data in these two volumes are  presented on a roughly
 consistent basis.
       A key element of  the inventory is the method of extrapolation from tested facilities
 to national estimates. Because only a few U.S. facilities in most source categories have
 been tested for CDD/CDF emissions, an extrapolation was needed  to estimate national
 emissions for most source categories.  Many of the national emission estimates were,
 therefore, developed using a "top down" approach. The first step  in this approach is to
 derive from the available  emission monitoring data an emission factor (or series of emission
 factors) deemed to be representative of the source category (or segments of a source
 category that differ in configuration, fuel type, air pollution control equipment, etc.) The
 emission factor relates mass of CDD/CDFs or dioxin-like PCBs  released into the environment
 per some measure of activity (e.g., kilograms of material processed per year, vehicle miles
 traveled per year, etc.).  The emission factor was then multiplied by a  national value for the
 activity level basis of the  emission factor (e.g., total kg of material  processed in the United
 States annually).
       Although no categories had  estimates developed from a true "bottom  up"  approach
 (i.e., estimates developed using site-specific emissions and activity data for all individual
sources in a category and then summed to obtain a national total),  existing facility-specific;

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 emissions testing and activity level data for some source categories (e.g., municipal solid
 waste incinerators) supported a semi- "bottom up" approach. In this approach, facility-
 specific annual emissions were calculated for those facilities with adequate data.  For the
 untested facilities in the class, a subcategory (or class) emission factor was developed by
 averaging the emission factors for the tested facilities in the class. This average emission
 factor was then multiplied by the measure of activity for the non-tested facilities in the
 class. Emissions were summed for the tested facilities and non-tested facilities. In
 summary, this procedure can be  represented by the following equations:


                            '-total = Z^i ^tested,! + 2-t ^untested,!
                          E total = 2~r ^tested,! + ^ \^'i * ^untested
 Where:       Etota, = annual emissions from all facilities (g TEQ/yr)
              ^tested,! = annual emissions from all tested facilities in class i (g TEQ/yr)
              ^untested,!  = annual emissions from all untested facilities class i (g TEQ/yr)
              Efj = mean emission factor for tested facilities in class i (g TEQ/kg)
              AJ = activity measure for untested facilities class i (kg/yr)

       Some source categories are made up of facilities that vary widely in terms of design
 and operating conditions. For these sources, as explained above, an attempt was made to
 create subcategories which grouped facilities with common features and then to develop
 separate emission factors for each subcategory.  Implicit in this procedure is the
 assumption that facilities with similar design and operating conditions should have similar
 CDD/CDF release potential.  For most source categories, however, the specific combination
 of features that contributes most to CDD/CDF or dioxin-like PCB release is not well
understood. Therefore, how to best subcategorize a source category was often
problematic.  For each subcategorized source category in this report, a discussion is
presented about the variability in design and operating conditions, what is known about
how these features contribute to CDD/CDF or dioxin-like PCB release, and the rationale for
subcategorizing the category.
       As discussed above, each source emission calculation required estimates of an
"emission factor" and the "activity level." For each emission source, the quantity and
                                          2-4
                                                                              April 1998

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                          DRAFT-DO NOT QUOTE OR CITE


 quality of the available information for both terms varies considerably.  Consequently, it is
 important that emission estimates be accompanied by some indicator of the uncertainties
 associated with their development.  For this reason, a confidence rating scheme was
                                                  1 •             I                ,-
 developed as an integral part .of the emission estimate in consideration  of the following
 factors:
       •      Emission Factor -  The uncertainty in the emission factor estimate depends
              primarily on how well the tested facilities represent the untested facilities. In
              general, confidence in the emission factor increases with increases in the
              number of tested facilities relative to the total number of facilities. Variability
              in terms of physical design and operating conditions within a class or
              subclass must also be considered. The more variability among facilities, the
              less confidence that a test of any single facility is representative of that class
              or subclass.  The quality of the supporting documentation also affects
              uncertainty;  Whenever possible, original engineering test reports were used.
              Peer reviewed reports from the open literature were also used for developing
              some emission factors.  In some cases, however, draft reports that had
              undergone more limited review were used.  In a few cases, unpublished
              references were used (such as personal communication with experts) and are
              clearly noted in the text.

       •      Activity Level - The uncertainty in the activity level estimate was judged
              primarily on  the basis of the extent of the underlying data.  Estimates derived
             from comprehensive surveys (including most facilities in a source category)
             were assigned high confidence.  As the number of facilities in the survey
             relative to the total decreased, confidence also decreased.  The "quality of the
             supporting documentation also affects uncertainty. Peer reviewed reports
             from the open literature (including government and trade association  survey
             data) were considered most reliable.  In some cases, however, draft reports
             that had undergone more limited review were used. In a few cases,
             unpublished  references were used (such as personal communication with
             experts) and are clearly  noted in the text.

       The confidence rating scheme, presented in  Table 2-1, provides criteria for assigning
a,"high," "medium," or "low"  confidence rating for both the emission factor and activity

terms. The first rating applies to the "activity" term, and the second rating applies to the

"emission factor" term.  In addition to the confidence rating,.the uncertainty in these
national release estimates is reflected  by presenting, where possible, for each source

category, both a central  or "best guess" value and a possible  range from a lower to upper

estimate.  These lower and upper estimates are riot intended to be absolute bounds, but

reasonable estimates of how much higher or lower the true value might be.  Insufficient
                                         2-5                                 April 1998

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                           DRAFT-DO NOT QUOTE OR CITE

  data were available to statistically derive these ranges; therefore, a judgement-based
  approach was developed. This approach uses the average or best guess estimate as the
  central value of a range. The range was determined by treating the central value as a
  geometric average of the end points of the range and determining those endpoints as
  follows:                                                                           ,

        *      Low confidence class:  Upper end of range is 10 times higher than lower end.
        *      Medium confidence class: Upper end of range is 5 times higher than lower
              end.
        *      High confidence class:  Upper end of range is 2 times higher than  lower end.

 The overall confidence rating assigned to an emission estimate was the lower of the
 confidence ratings assigned to the corresponding "activity" term and "emission factor"
 term.  It is emphasized that these ranges should be interpreted as judgements which are
 symbolic of the relative uncertainty among sources, not statistical measures.
        In some cases, sufficient information was available to make very preliminary
 estimates of emissions of CDD/CDFs or dioxin-like PCBs, but the confidence in the activity
 level estimates or emission factor estimates was so low that it was considered
 inappropriate to include emission estimates in the inventory.  These preliminary estimates
 are discussed in the text and summarized in Table 2-6.
       The emission factors developed for the emissions inventory are intended to be used
 for estimating the total emissions for a source category rather than for individual facilities.
 EPA has made uncertainty determinations for each of these emission factors based, in part,
 on the assumption that by applying them to a group of facilities, the potential for
 overestimating or underestimating individual facilities  will to some extent be self
 compensating. This means that in using these emission factors one can place significantly
 greater confidence in an emission  estimate for a class than can be placed on an emission
 estimate of any individual facility.   Given the limited amount of data available  for deriving
 emission factors, and the limitations of our understanding  about facility-specific conditions
that determine formation and control of dioxin-like compounds, the current state  of
knowledge cannot support the development of emission factors that can be used to
accurately estimate emissions on an individual facility-specific basis.

                                      ,  2"6-                                April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

  2.2.   GENERAL FINDINGS OF THE EMISSIONS INVENTORY
        Nationwide emission estimates for the United States inventory are presented in
  Tables 2-2 and 2-3 (emissions to air, water, land, and product) for the major known or
  suspeced sources that could have releases of dioxin-like compounds to the environment.
  The emission factors used to calculate these emission estimates were derived by setting
  "not detected (ND)" values in test reports as zeros. Because detection limits were not
  always reported in test reports, it was not possible to consistently develop emission factors
  on, any other basis (e.g., values set at one-half the detection limit) for all source categories.
  When detection limits were reported for all test reports for a given source category,
 emission factors Were calculated and are presented in this report for both ND equals zero
 and ND equals one-half the detection limit.
       Table 2-2 presents estimated annual  releases for the reference time period 1995.
 Table 2-3 presents estimated annual releases for the reference time period 1987. Table 2-
 4 lists the emission factors used to derive these  emission estimates. For each source listed
 in these tables, estimated emissions are presented where appropriate and where data are
 adequate to .enable an estimate to be made.  Figures 2-1  and 2-2 are charts that visually
 display the range of emission estimates to air that are reported in Tables  2-2 and 2-3,
 respectively. Figure 2-3 compares the ahnualmean TEQ emission estimates for the two
 reference years. Table 2-5 presents order of magnitude estimates of CDD/CDF emissions
 from suspected source categories not included in the inventory because uncertainty in the
 emission factor and/or activity level was deemed too great.
       Central estimates of re/eases of dioxin-like compounds to all environmental media
 (except products) were approximately 3,OOO g. TEQ in 1995 and 11,900 g TEQ in 1987.
 These estimates were generated by summing the emissions across all sources in the
 inventory.  Each of these estimates have an uncertainty range  around them which is
 derived from uncertainties in the estimates for  individual sources (for 1987 the range is
 5,000 to 29,100 g TEQ and for 1995 the range is 1,200 to 7,900 g TEQ).
      The decrease in estimated emissions of dioxin-like compounds between 1987 and
 1995 was due primarily to reductions in emissions from municipal and medical waste
incinerators. For both categories these emission reductions have occurred from a
combination of  improved combustion and emission controls and from the  closing of a
                                        2"7                                April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 number of facilities.  Regulations recently promulgated or under development should result
 in some additional reduction in emissions from major combustion sources.
        The environmental releases of dioxin-like compounds in the United States occur from
 a wide variety of sources, but are dominated by releases to the air from combustion
 sources.  The current (i.e.,  1995) inventory estimates that emissions from combustion
 sources are more than an order of magnitude greater than emissions from all other
 categories combined.
       Insufficient data are available to comprehensively estimate point source releases of
 dioxin-like compounds to water.  Sound estimates of releases to water are only available
 for chlorine bleached pulp and paper mills (356 g TEQ/yr for 1987 and 20 g TEQ/yr for
 1995). Other releases to water bodies which cannot be quantified on the basis of existing
 data include effluents from  POTWs and most industrial/commercial sources.
       Insufficient data are available to comprehensively estimate releases of dioxin-like
 compounds to land.  Contributions to land can occur in a variety of ways. One way is the
 intentional disposal of materials containing dioxin-like compounds in properly managed
 landfills where the potential for releases to the environment (i.e., groundwater or the
 atmosphere) is assumed to  be minimal. Sound estimates of such practices have only been
 made for the disposal of municipal waste incinerator ash (1,800 g TEQ in 1995), sewage
 sludge (194 g TEQ in 1995), and pulp  and paper mill wastewater sludge (21 g TEQ in
 1995).  Other materials containing dioxin-like compounds which are typically landfilled
 include dredge spoils and incinerator ash other than  municipal waste incinerator ash.  A
 second way is land application of sewage sludge (207 g TEQ/yr in 1995) and pulp and
 paper mill  wastewater sludges (1.4 g TEQ/yr in 1995).  In the past, a third way was the
 improper land disposal of chemicals and waste products containing dioxin-like compounds.
       The change over time in amounts of dioxin-like compounds being land disposed has
 not been well characterized. Some of the emission controls installed in recent years have
 reduced dioxin formation and others have removed more CDD/CDFs from air and water
 emissions  and transferred them to solid residues.  It  is unclear if the net effect of these
types of controls would lead to an increase or decrease in amount of CDD/CDFs in solid
residues.
                                                          •           I
      Data are available to estimate the amounts of CDD/CDFs and dioxin-like PCBs
contained in only a limited number of commercial products.  No systematic survey has been
                                        2-8
                                                                           .April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 conducted to determine.levels of dipxin-like compounds in commercial products. The
 available data does, however, allow estimates of the amounts of dioxin-like compounds in
 bleached pulp (24 g TEQ/yr in 1995), POTW sludge used in fertilizers (7.0 g TEQ/yr in
 1995), pentachlorophenol-treated wood (25,000 g TEQ/yr irr 1995), dioxazine dyes and
 pigments «1 g TEQ/yr in 1995) and 2,4-D (18.4 g TEQ/yr in 1995).
        The mixture of ODD and CDF congeners in the emission from a source category (i.e.,
 the "congener profile ") may serve as a source-specific signature for that category:
 Although uncertainties exist, these congener profiles may assist researchers in:
 (1) identification of specific combustion source contributions to near field air measurements
 of CDD/CDFs; (2) comparing sources in terms of discerning differences in the types and
 amplitude of CDD/CDF congeners emitted; and  (3) providing insights on formation of CDDs
 and CDFs in various sources and chemicals.
       The procedures and results of the U.S. inventory are consistent with the published
 national inventories for several European countries.  Table 2-6 presents CDD/CDF TEQ
                                                         /"       •          '      '
 source-specific air emission estimates reported for West Germany (Fiedler and Hutzinger,
 1992); Austria (Riss and Aichinger, 1993); The Netherlands (Koning et al., 1993; Bremmer
 et al., 1994); Switzerland (Scnatowitz et al., 1993); Belgium (Wevers and  DeFre, 1995);
 and the United Kingdom (Douben et al., 1995; UK Department of the Environment, 1995).
 The emission estimates for West Germany, Switzerland, the United Kingdom, and The
 Netherlands suggest that municipal waste incinerators and metal smelters/refiners are the
 largest sources of air emissions. In Austria, domestic combustion of wood is believed to be
 the largest source followed by emissions from the metallurgical industry. Although an
 emissions inventory for Sweden has not yet been published, Rappe  (1992a) and Lexen et
 al. (1993) have identified emissions from ferrous and nonferrous metals smelting/refining
 facilities as potentially the largest current source in Sweden.  It should  be noted that these
 emission inventories are expected to change over time due to changing industrial practices,
facility closures and .upgrades, and regulatory actions.
      Some investigators have argued that national inventories such as this one may be
underestimating emissions due to the possibility of unknown sources.  This claim has been
supported with mass balance analyses suggesting that deposition exceeds emissions
(Rappe et al., 1991; Harrad et al. 1992b; Brzuzy and Hites, 1995).  The uncertainty,
however, in both emissions and deposition estimates in the United States prevent the use
                                        2-9
                                                                           April 1998

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                          DRAFT-DO NOT QUOTE OR CITE


 of this approach for reliably evaluating this issue.  A variety of other factors do indicate,
 however, that the inventory could underestimate CDD/CDF emissions:


 •      A number of sources were not included in the inventory even though limited
        evidence exists (primarily from studies performed in Europe) indicating that these
        sources can emit CDD/CDFs. These sources include various components of the
        metals industries such as iron ore sintering and foundries. Table 2-6 presents rough
        estimates of what U.S. national emissions could be if the emission factors reported
        in these other studies are representative of emission factors for U.S. facilities.

 •      The possibility remains that truly unknown sources exist.  Many of the sources
       which are well accepted today were only discovered in  the past 10 years.  For
       example, CDD/CDFs were found unexpectedly in the wastewater effluent from
       bleached pulp and paper mills in the mid 1980s. Ore sintering is now listed as one
       of the leading sources of CDD/CDF emissions in Germany, but was first reported in
       the early 1990s.

 •      Another potentially important source which is not represented in'the inventory is  ,
       reservoirs.  In this context, reservoirs are places such as soils, sediments, vegetation
       or other media which contain dioxin-like compounds originally formed some time in
       the past and have the potential for current emissions. The dioxin-like compounds in
       these "reservoirs" can be re-released to the environment by  processes such as
       volatilization and particle resuspension. Such releases may (or may not) add
       significantly to the mass of dioxin-like compounds circulating in the environment and
       potentially contributing to human exposure.  Two of the largest potential reservoirs
       are soils and pentachlorophehol (PCP) treated wood. PCP contains low levels of
       CDD/CDFs and wood which has been treated with this pesticide represents a large
       reservoir of CDD/CDFs.  CDD/CDFs may be released from the PCP-treated wood to
       the air by volatilization or to surrounding soils by leaching. Although hypothesized
       to occur, no reliable measurements have been made. Similarly, no empirical evidence
       exists on the possible magnitude of reservoir emissions from soil to air.

2.3.    GENERAL SOURCE OBSERVATIONS

       Current emissions of CDD/CDFs to the U.S. environment result principally from
anthropogenic activities. Three lines of evidence support this finding:


•      Studies of sediment corings in lakes in the United States show a consistent pattern
       of change in CDD/CDF concentration in the sediments over time. The time period
       when increases are observed  in CDD/CDF levels in sediments coincides with the
       time period when general industrial activity began increasing rapidly.  CDD/CDF
       concentrations in sediments began to increase around the 1930s, and continued to
    ,   increase until the 1960s and 1970s.  Decreases appear to have occurred only during
       the most recent time periods (i.e., 1970s and 1980s). These trend observations are
       consistent among the dated sediment cores collected from over 20 freshwater and
       marine water bodies in various locations throughout the  United States and Europe.

                                       2-10                                April  1998

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                          DRAFT-DO NOT QUOTE OR CITE


        Levels of CDD/CDF in sediments from these lakes are considered to be a reasonable
        indicator of the rate of environmental deposition.  The period of increase generally
        matches the time when a variety of industrial activities began rising and the period
        of decline appears to correspond with growth in pollution abatement.  Some of
        these abatements may be linked with dioxih emissions (i.e., elimination of open
        burning, paniculate controls on combustors, phase out of leaded gasoline, and bans
        or restrictions on PCBs, 2,4,5-T, and PCP.

        No large natural sources of CDD/CDF have been identified.  EPA's current estimate
        of emissions from all sources of CDD/CDFs suggests that forest fires are a minor
        source of emissions compared to anthropogenic combustion activity. To date, no
        studies  have demonstrated formation of CDD/CDFs by volcanoes.  Recently
        CDD/CDFs  have been discovered in ball clay deposits in western  MS, KY and TN.
        Although the  origin of the dioxins in these clays may be natural, it has not been
        confirmed.   .
                                 1        >-      .        **      , *
        CDD/CDF levels in human tissues from  the general population in industrialized
        countries are higher than levels observed in less-industrialized countries. Human
        populations in Europe and North America have significantly  higher mean tissue levels
        (e.g., blood, adipose tissues and breast milk) than human populations in developing
       countries of Asia and South East Asia {Schecter, 1994).  In addition, tissues taken
       from preserved, 140 to 400 year old human remains show almost the complete
       absence of  CDD/CDFs, well below levels found in tissues of modern people (Tonq et
       al.,  1990).

       No clear evidence exists showing that the emissions of CDD/CDFs from known
sources correlate proportionally with general population exposures.  Although the emissions
inventory shows the relative contribution of various sources to total emissions, it cannot be

assumed that these sources make the same relative contributions to human exposure. It is
quite possible that  the major sources of CDD/CDF in food may not  be those sources .that

represent the largest fractions of total emissions in the United States.  The geographic
locations of sources relative to the areas from which much of the beef, pork, milk, and fish

is produced are  important to consider.  That is, the agricultural areas which produce much
of our food may not necessarily be located near or down wind of the major sources of
CDD/CDFs.
                                       2"1.1                               April 1998

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                        DRAFT-DO NOT QUOTE OR CITE
          Table 2-1.  Confidence Rating Scheme for U.S. Emission Estimates
 Confidence
   Rating
     Activity Level Estimate
     Emission Factor Estimate
High
Derived from comprehensive
survey
Derived from comprehensive survey
Medium
Based on estimates of average
plant activity level and number of
plants or limited survey
Derived from testing at a limited but
reasonable number of few facilities
belieyed to be representative.of
source category	
Low
Based on expert judgement or
unpublished estimates
                                               Derived from testing at only a few,
                                               possibly non-representative facilities
                                               or from similar source categories or
                                               foreign surveys where differences
                                               in industry practices may be likely
                                     2-12
                                                                         April 1998

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-------
           DRAFT-DO NOT QUOTE OR CITE

' Table 2-4. CDD/CDF TEQ Emission Factors Used to Develop National
          Emission Inventory Estimates of Releases to Air
II Emission Source
I Waste Incineration
jf Municipal waste incineration
|j Hazardous waste incineration
|| Boilers/industrial furnaces
|| Medical waste/pathological incineration
[J Crematoria
|| Sewage sludge incineration
|| I ire combustion
I Pulp and paper mill sludge incinerators
j bioQas combustion
1 Power/Energy Generation
I Vehicle fuel combustion - leaded13
j 	 - unleaded
1 - diesel
r— — — 	 — 	 . —
j wood combustion - residential
I - industrial
[ Coal combustion - residential
- industrial/utility
Oil combustion . residential
- industrial/utility
Other High Temperature Sources
Cement kilns burning hazardous waste
uement kilns not burning hazardous waste
Asphalt mixing plants
Petro. refining catalyst regeneration
Cigarette combustion
Carbon reactivation furnaces
Kraft recovery boilers *
Minimally Controlled or Uncontrolled Combustion
Combustion of landfill gas in flares
Landfill fires
Accidental fires (structural)
Accidental fires (vehicle)
Forest, brush, and straw fires
Backyard trash burning
Uncontrolled combustion of PCBs
TEQ-
Emission
Factor
a
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6.94
0.282
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1.7
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2
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Emission Factor Units

ng TEQ/kg waste combusted \
ng TEQ/kg waste combusted
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ng TEQ/body . ~1
ng TEQ/kg dry sludge combusted
ng TEQ/kg tires combusted


pg TEQ/km driven
pg TEQ/km driven
pg TEQ/km driven
ng TEQ/kg wood combusted 1
ng TEQ/kg wood combusted ||

ng TEQ/kg coal combusted
	
ng TEQ/L combusted
	 	
ng/kg clinker produced ||
ng/kg clinker produced


pg TEQ/cigarette
	
ng TEQ/kg solids combusted


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ng TEQ/kg biomass combusted II
II
1
                        2-22
                                                              April 1998

-------
                                 DRAFT-DO NOT QUOTE OR CITE

                      Table 2-4.  CDD/CDF TEQ Emission Factors Used to Develop National
                           Emission Inventory Estimates of Releases to Air (continued)
Emission Source
Metallurgical Processes
Ferrous metal smelting/refining
- Sintering plants
- Coke production
- Electric arc furnaces
- Ferrous foundries
Nonferrous metal smelting/refining
- Secondary aluminum smelting
- Secondary copper smelting
- Secondary lead smelters • •;
i
Scrap electric wire recovery
Drum and barrel reclamation
Chemical Manuf ./Processing Sources
Bleached chemical wood pulp and paper mills
Mono- to tetrachlorophenols
Pentachlorophenpl
Chlorobenzenes
Chlorobiphenyls (leaks/spills)
Ethylene dichloride/vinyl chloride
Dioxazine dyes and pigments ,
2,4-Dichloropherioxy acetic acid
Non-incinerated sludge
Tall oil-based liquid soaps
Biological Formation
Photochemical Formation
Reservoir Sources .
Emissions from chlorophenol-treated wood
TEQ
Emission
Factor

* *
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13.1
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NA
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#
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Emission Factor Units

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ng/kg scrap consumed
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a        Different emission factors were derived for various subcategories within this industry.
b        Included within total for Wobd Combustion - Industrial.        ,
         Some evidence exists suggesting that this category is a source of CDD/CDF emissions.  However, insufficient data
         are available for making a quantitative or qualitative emission estimate.
** Evidence exists suggesting that this category is a source of CDD/CDF emissions. Preliminary estimates of emissions foe
   reference year 1995 have been made (see Table 2-5), but the confidence in the emission factor estimates and/or activity
   level estimates are so low that the estimates are too uncertain to include in the inventory.

NA  = Not applicable.         -                                                             .   .
NEG = Expected to be negligible!(i.e., less than 1 ;gram per year) or non-existent.
                                                   2-23
                                                                                                  April 1998

-------
                           DRAFT-DO NOT QUOTE OR CITE

            Table 2-5. Order of Magnitude Estimates of CDD/CDF Air Emissions from
                       Sources Not Quantified in the National Inventory3
                                   (Reference Year 1995)
                                                               Estimated Emission to Air
                                                                      (g TEQ./yr)
Potential Emission Source
 1 -
Accidental Vehicle Fires
 Asphalt Mixing Plants
 Backyard Trash Burning
 Biogas Combustion
 Coke Production
 Combustion of Landfill Gas in Flares
Electric Arc Furnaces
Ferrous Metal Foundries
Landfill fires
Residential/Commercial Coal Combustion
Residential/Commercial Oil Combustion
Iron Ore Sintering
 Although some evidence exists that the following categories are sources of CDD/CDF emissions
 to air, the available data are insufficient for making even order of magnitude emission estimates:
 petroleum refining catalyst regeneration, uncontrolled combustion of PCBs, scrap electric wire
 burners, bleached wood pulp and paper mills, manufacturers of ethylene dichloride/vinyl chloride,
 accidental structural fires, photochemical formation, and chlorophenol-treated wood.
                                         2-24
                                                                                 April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
            3. COMBUSTION SOURCES OF CDD/CDF:  WASTE INCINERATION

        Incineration is the destruction of solid, liquid, or gaseous wastes through the
 application of heat within a controlled combustion system.  The purposes of incineration
 are to reduce the volume of waste that needs land disposal and to reduce the toxicity of
 the waste, making it more sterile.  In keeping with this definition, incinerator  systems can
 be classified by the types of wastes incinerated:  municipal solid waste incineration;
 medical and pathological waste incineration; hazardous waste incineration; sewage sludge
 incineration; tire  Incineration; and biogas flaring.  Each of these types of incinerators are
 discussed in this  chapter. The purposes of this chapter are to: characterize and describe
 waste incineration technologies in the United States and to derive estimates of annual
 releases of CDDs and CDFs into the atmosphere from these facilities for reference years
 1987 and 1995.
       Combustion research has developed three theories on the mechanisms involved in
 the emission of CDDs and CDFs from combustion systems:  (1) CDD/CDFs can be
 introduced into the combustor with the feed and pass through the system unchanged,
 (2) CDD/CDFs can be formed during combustion, or (3) CDD/CDFs can be formed via
 chemical reactions in the post-combustion portion of the system. The total CDD/CDF
 emissions are likely to be the net result of all three mechanisms; however, their relative
 importance is often uncertain. To the extent practical with the available data, the
 combustors in each source category were divided into classes judged to have  similar
 emission factors.  This classification effort attempted to reflect the emission mechanisms
 described above.  The emission mechanisms suggest that the aspects of combustor design
 and operation that could affect CDD/CDF emissions are furnace design, composition of the
 waste feed, temperature in the post-combustion zone of the system, and type of air
 pollution control device (APCD) used to remove contaminants from the flue gases.
Therefore, incineration systems that are similar in terms of these factors should have similar
CDD/CDF emissions. Accordingly, this chapter proposes  classification schemes that divide
combustors into a variety of design classes based on these factors. Design class/as used
here, refers to the combination of furnace type and accompanying APCD.
                                                                          April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
  3,1.   MUNICIPAL SOLID WASTE INCINERATION
        As discussed previously, CDD/CDF emission theory suggests that CDD/CDF
  emissions can be related to several factors, including furnace design, composition of the
  waste feed, temperature in the post-combustion zone of the system, and type of APCD
  used to remove contaminants from the flue gases.   Accordingly, this chapter proposes a
  classification scheme that divides municipal solid waste incinerators (MSWIs) into a variety
  of design classes based on those factors.  Some APCDs are operated at different
 temperatures; therefore, operating temperature is used to define some design classes.
 Because the theory also suggests that feed can  influence CDD/CDF emissions, the
 proposed furnace classification  system distinguishes refused-derived fuel from normal
 municipal solid waste (MSW). This section begins with a description of the MSWI
 technology and then proposes the design classification scheme. Using this scheme, the
 MSWI industry is characterized  for the reference years 1987 and 1995.  Finally, the
 procedures for estimating  emissions are explained, and results summarized.

 3.1.1. Description of Municipal  Solid Waste Incineration Technologies
       For purposes of this report, MSWI furnace types are divided into three major
 categories: mass burn, modular, and refuse-derived fuel.  Each of these furnace types is
 described below, followed with  a description of the APCDs used with these  systems.

 Furnace Types
       Mass Burn: Historically,  this furnace type derived its name because it burned MSW
 as received  (i.e., no preprocessing of the waste was  conducted other than removal of items
 too large to go through the feed system). Today, a number of other furnace types also
 burn unprocessed waste (as described below). Mass burn furnaces are distinguished from
 these others because they burn  the waste in a single stationary chamber.  In a typical mass
 burn facility, MSW is placed on a grate that moves through the combustor. The 1995
 inventory indicates that the combustion capacity of facilities ranges from 90 to 2,700
 metric tons of MSW per day.  Three subcategories of mass burn (MB) technologies are
described below:

      Mass burn refractory-walled  (MB-REF) systems represent an older class of MSWIs
      (generally built in the late 1970s to early 1980s) that were designed only to reduce
      the volume of waste in need of disposal by 70 to 90 percent. These facilities
                                        3-2
                                                                           April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
                                              *              -        t        \
        usually lacked boilers to recover the combustion heat for energy purposes.  In the
        MB-REF design, the MSW is delivered to the combustion chamber by a traveling
        grate and/or a ram feeding system.  Combustion air in excess of stoichiometric
        amounts (i.e., more oxygen is supplied than needed for complete combustion) is
        supplied both below and above the grate.

        Mass burn waterwall (MB-WW) facilities  represent enhanced combustion efficiency
        as compared with MB-REF incinerators. Although it achieves similar volume
        reductions, the MB-WW incinerator design provides a more efficient delivery of
        combustion air, resulting in sustained higher temperatures. Figure 3-1 is a schematic
        of a typical MB-WW MSWI. The  term 'waterwall ' refers to a series of steel tubes
        running vertically along the walls  of the furnace. The tubes  contain water, which '
        when heated by combustion, transfer energy from the heat of combustion to the
        water. The water reaches boiling temperature, and steam is produced.  The steam
        is then used to drive an electrical  turbine  generator or for other industrial needs.
        This transfer of energy is termed 'energy  recovery.'

        Mass burn rotary kiln combustors (MB-RC) use a water-cooled rotary .combustor
        which consists of a rotating combustion barrel configuration  mounted at a 15-20°
       angle of decline. The refuse is charged at the top of the rotating kiln by a hydraulic
       ram (Donnelly, 1992K  Preheated  combustion  air is delivered to the kiln through
       various portals.  The slow rotation of the  kiln (i.e., 10 to 20  rotations/hour) causes
       the MSW to tumble, thereby exposing more surface area for  complete burnout of
       the MSW.  These systems are also equipped with boilers for  energy recovery.
       Figure 3-2  is a schematic of a typical MB-RC MSWI.


       Modular incinerator:  This is the second general type of MSWI furnace used in the
United States. As with the  mass burn type, modular  incinerators burn waste without

preprocessing.  Modular MSWIs consist of two vertically mounted combustion chambers
(i.e., a primary and secondary chamber).  In the 1995 inventory, modular combustors'

combustion capacity ranged from 4 to 270 metric tons/day. The two major types of

modular systems,  "excess air"  and "starved air," are,described below.


      The modular excess-air system consists  of a primary and secondary combustion
      chamber, both of which operate with  air levels in excess of stoichiometric
      requirements (i.e., 100 to 250 percent excess air).  Figure 3-3 illustrates a typical
      modular excess-air MSWI.

      Starved (or controlled) air. is a newer type  of modular system, which is easier and
      less expensive to operate than the  excess-air systems.  In these systems, air is
      supplied to the primary chamber at sub-stoichiometric levels.  The products of ,
      incomplete combustion entrain in the combustion gases that are formed in the
      primary combustion chamber, then pass  into a secondary combustion chamber.
      Excess air is added to the secondary chamber, and combustion is completed by
      elevated temperatures sustained with auxiliary fuel (usually natural gas).  The high.

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                          DRAFT-DO NOT QUOTE OR CITE

        and uniform temperature of the secondary chamber,  combined with the turbulent
        mixing of the combustion gases, results in low-levels of particulate matter ancl
        organic contaminants being formed and emitted.  Therefore, many existing modular
        units lack post-combustion air pollution control devices. Figure 3-4 is a schematic
        view of a modular starved-air MSWI.


        Refuse-Derived Fuel (RDF):  The third major type of MSWI furnace technology is

 designed to combust refuse-derived fuel (RDF).  RDF is a general term that describes MSW

 from which relatively noncombustible items are removed, thereby enhancing the

 combustibility of the MSW.  RDF is commonly prepared by shredding, sorting, and

 separating out metals to create a dense MSW fuel in a pelletizecl form, having a uniform
 size. Three types of RDF systems are described below.

                 "                                          ''

 •      The dedicated RDF system burns RDF exclusively.  Figure 3-5 shows a  typical
       dedicated RDF using a spreader-stoker boiler. Pelletized RDF is fed into the
       combustor through a feed chute, using air-swept distributors; this allows a portion
       of the feed to burn in suspension and the remainder to burn out after falling on a
       horizontal traveling grate. The traveling grate moves  from the rear to the front of
       the furnace, and distributor settings are adjusted so that most of the waste lands on
       the rear two-thirds of the grate.  This allows more time to complete combustion on
       the grate. Underfire and overfire air are introduced to enhance combustion, and
       these incinerators typically operate at 80 to 100 percent excess air.  Waterwall
       tubes, a superheater, and an economizer are used  to recover heat for production of
       steam and/or electricity. The 1995 inventory indicates that dedicated RDF facilities
       range in total combustion capacity from 227 to 2,720 metric tons/day,

•      Cofired RDFs burn both RDF and normal MSW.

       The fluidized-bed RDF (FB-RDF) burns the waste in a turbulent and semi-suspended
       bed of sand.  The MSW may be fed into the incinerator either as unprocessed waste
       or as a form 'of RDF.  The RDF may be injected into or above the bed through ports
       in the combustor wall.  The sand bed Is suspended during combustion by introducing
       underfire air at a high velocity, hence the term  "fluidized."  Overfire air at 100
       percent stoichiometric requirements is injected above the sand suspension. Waste-
      fired FB-RDFs typically operate at 30 to 100 percent excess  air levels and at bed
      temperatures around 815°C (1,500°F). A typical FB-RDF is presented as Figure  3-6.
      Technology has two basic design concepts: (1) a bubbling-bed incineration unit and
      (2) a circulating-bed incineration unit. The 1995 inventory indicates that fluidized-
      bed MSWls have capacities ranging from 184 to 920 metric  tons/day. These
      systems are usually equipped with boilers to produce steam.
                                                                           April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
 Air Pollution Control Devices (APCDs)
        MSWIs are commonly equipped with one or more post-combustion APCDs to
 remove various pollutants prior to release from the stack (e.g., particulate matter, heavy
 metals, acid gases, and/or organic contaminants) (U.S. EPA, 1992d). These APCDs
 include:          :J                 .

              Electrostatic precipitator (ESP),
              Fabric filter (FF),                               ,
        •      Dry scrubber (DS),
              Dry sorbent injection (DSI), and
              Wet scrubber (WS)                   (   .
                                                                         i
        Electrostatic Precipitator:  The ESP is generally used to collect and control
 particulate matter that evolves during MSW combustion, by introducing a strong electrical
 field in the flue gas stream; this, in turn, charges the particles entrained in the combustion
 gases (Donnelly,  1992).  Large collection plates receive an opposite charge to attract and
 collect the particles. CDD/CDF formation can occur within the ESP at temperatures in the
 range of 150 to about 350°C. As temperatures at the inlet to the ESP increase from
 1 50 to 300°C, CDD/CDF concentrations have been observed to increase by approximately
 a factor of two for each 30°C increase in temperature (U.S. EPA, 1994f). As temperature
 increases beyond 300°C, formation rates decline. Although ESPs in this temperature range
 efficiently remove most particulates and the associated CDD/CDFs, the formation that
 occurs can result in a net increase in CDD/CDF emissions. This temperature, related
 formation of CDD/CDF within the ESP can be applied to distinguish hot-side ESPs from
 cold-side ESPS. For purposes of this report, ESPs are classified as follows:

       •     A cold-side ESP operates at or below 230°C.
   ••"'*     A hot-side ESP operates at an inlet temperature greater than 230°C.

       Fabric Filters (FF):  FFs are also particulate matter control devices, which remove
dioxins associated with particles and any vapors that adsorb to the particles. Six- to 8-inch
diameter bags, made from woven fiberglass material, are usually arranged 'in series. An
induction fan forces the combustion gases through the tightly woven fabric. The porosity
of the fabric allows the bags |o act as filter media and retain a broad range of  particles
                                        3-5                                 April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
  sizes {i.e., down to less than 1  micrometer in diameter).  The FF is sensitive to acid gas;
  therefore, it is usually operated in combination with spray dryer adsorption of acid gases.
        Dry Scrubbers (PS): DSs, also called spray dryer adsorption, involve both the
  removal of acid gas and paniculate matter from the post-combustion gases. By
                          •                                             ,          ,/
  themselves, these units probably have little effect on dioxin emissions.  In a typical DS
  system, hot combustion gases enter a scrubber reactor vessel. An atomized hydrated lime
 slurry (water plus lime) is injected into the reactor at a controlled  velocity (Donnelly, 1992).
 The hydrated lime slurry rapidly mixes with the combustion gases within the reactor. The
 water in the hydrated lime slurry quickly evaporates, and the heat of evaporation causes
 the combustion gas temperature to rapidly decrease. The neutralizing capacity of hydrated
 lime reduces the combustion gas content of acid gas constituents (e.g., hydrogen chloride
 gas, and sulfur dioxide gas) by greater than 70 percent. A dry product, consisting of
 particulate matter and hydrated lime, settles to the bottom of the reactor vessel. DS
 technology is used in combination with ESPs. The DS reduces ESP inlet temperatures to
 make a cold-side ESP. DS/FFs have achieved greater than 95 percent reduction and control
 of CDD/CDFs in MSWI emissions (U.S. EPA, 1 992d).
    Dry Sorbent Injection  (DSI):  DSI is used to reduce acid gas emissions. By themselves,
 these units probably have little effect on dioxin emissions.  DSI involves the injection of dry
 hydrated lime or soda ash either directly into the combustion  chamber or into the flue duct
 of the hot post-combustion gases. In either case, the reagent reacts with and neutralizes
 the acid gas constituents (Donnelly, 1992).
       Wet Scrubber (WS): WS devices are designed for acid gas removal, and are more
 common to  MSWIs in Europe'than in the United States. They should help reduce emissions
 of dioxin in both vapor and particle forms. WS devices consist of two-stage scrubbers.  The
 first stage removes HCI, and the second stage removes SO2 (Donnelly,  1992).  Water is
 used to remove the HCI, and caustic or hydrated lime is added to remove SO2 from the
 combustion  gases.
       In addition to the APCDs described above, some less common types are also used in
 some MSWIs. An example is the Electro Granular Bed  (EGB),  which consists of a packed
 bed of activated carbon. An electric field is passed through the packed bed; particles
entrained in the flue gases are given a negative charge, and the packed bed is given a
positive charge.  EGB systems function much like an ESP.  Particulate matter is collected
within the bed; therefore, they will remove dioxins associated with collected particles and

                                        3-6                                April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
 any vapors that adsorb to the particles. Only one facility in the United States currently
 employs the EGB system, a fluidized bed-RDF MSWI.

 Classification Scheme                                             .
        Based on the array of MSWI technologies described above, a classification system
 for deriving CDD/CDF emission estimates was developed. As discussed earlier, it is
 assumed that facilities with common design and, operating characteristics have a similar
, potential for CDD/CDF emissions.  The MSWIs operating  in 1987 and 1995 were divided
 according to the eight furnace types and seven APCDs described above. This resulted in
 17 design classes in 1987 and 40 design classes in 1995.  Because fewer types of APCDs
 were used in 1987 than in  1995, fewer design classes are needed for estimating emissions.
 This taxonomy is summarized in Figures 3-7 and 3-8.                      ,

 3.1.2. Characterization of MSWI Facilities in Reference Years 1995 and 1987
       Table 3-1  lists by design/APCD type, the number of facilities and activity level (kg
 MSW incinerated per year) for MSWIs in the reference year 1995. A similar inventory is
 provided for reference year  1987 in Table 3-2. This information was derived from four
 reports:  U.S. EPA (1987b), Sytems Applications International (1995), Taylor and Zannes
 (1996), and Solid Waste Technologies (1994). In general, these studies collected the
 information via telephone interviews with the plant operators.
       Using Tables 3-1  and 3-2, a  number of comparisons can be made between the two
reference years:
                                              '           "              )
       The number of facilities stayed about the same (113 in 1987 and 130 in 1995), but
       the amount of MSW  incinerated more than doubled (13.Bullion kg in 1987 and
       28.8-billion kg in 1995).                                              '
       The dominant furnace technology shifted from,modular in 1987 (57 units and 1.4-
       billion kg) to mass burn waterwall facilities in 1995 (57 units and 17-billion kg).
•      The dominant APCD technology shifted from hot-sided ESPs in 1987 (54 units and
       11-billion kg)  to fabric filters  in 1995 (55 units and 16-billion kg)'.
      The use of hot-sided  ESPs dropped from 54 facilities in 1987 (11 -billion kg) to 16
      facilities in 1995 (2.2-billion kg).
      The number of uncontrolled facilities dropped from  38 in 1987 (0.6-billion  kg) to 10
      facilities in 1995 (0.2-billion kg).  ,
                                                                           April 1998

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  3.1.3. Estimation of CDD/CDF Emissions from MSWIs
        Compared to other CDD/CDF source categories, MSWIs have been more extensively
  evaluated for CDD/CDF emissions. Within the context of this report, adequate emission
  testing for CDD/CDFs were available for 11 of the 113 facilities in the 1987 inventory and
  27 of the 130 facilities in the 1995 inventory. Nationwide CDD/CDF air emissions from
  MSWIs were estimated using a three-step process as described below.

  Step 1. Estimation  of emissions from all stack tested facilities. The EPA stack testing
  method (EPA Method 23) produces a measurement of CDD/CDF in units of mass
  concentration of CDD/CDF (i.e., nanograms per dry standard cubic meter of combustion gas
  [ng/dscm]) at standard temperature and pressure (20°C and one atmosphere), and adjusted
 to a measurement of 7 percent oxygen in the flue gas (U.S. EPA, 1995b). This
 concentration is assumed to represent conditions at the point of release from the stack into
 the air. Equation 3-1 below was used to derive annual emission estimates for each tested
 facility:

                              E     =  CxVx CFx H
                               TEQ         109 nglg
                                                           >,
 Where:
              —     Annual TEQ emission (g /yr)
       C     =     Combustion flue gas TEQ concentration (ng/dscm) (20°C, 1 atm;
                    adjusted to 7% O2)
       V     =     Volumetric flow rate of combustion flue gas (dscm/hour) (20°C, 1
                    atm; adjusted to 7% O2)
       CF    =     Capacity factor, fraction of time that the MSWI operates (i.e., 0.85)
       H     =     Total hours in a year (8,760 hr/yr)

After calculating annual emissions for each tested facility, the emissions were summed
across all tested facilities for each reference year.  [Note: many of the emission tests do
                                   ,  i"     ,        '        " ••         , ' '
not correspond exactly to these 2 years. In these cases, the equipment conditions present
at the time of the test were compared to those during the reference year to determine their
applicability.]

Step 2. Estimation of emissions from all non-tested facilities.  This step involves
multiplying the emission factor and annual activity level for each MSWI design class and

                                        3~8                                April 1998

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 then summing across classes.  The activity levels for reference years 1995 and 1 987 are
 summarized in Tables 3-1  and  3-2, respectively.'The emission factors were derived by
 averaging the emission factors across each tested facility in a design class. The emission
 factor for each facility was calculated using the following equation:

                                 EF     -  C X F*
              ,                  ,rmswi--• —~	                      (Eqn. 3-2)
 Where:
       £Fmsw> =     Emission factor, average ng TEQ per kg of waste burned
       c    '=     TEQ or CDD/CDF concentration in flue gases (ng TEQ/dscm) (20°C, 1
                    atm; adjusted to 7% O2)
       Fv •    ~  •   Volumetric flue gas flow rate (dscm/hr) (20°C, 1 atm; adjusted to 7%
       lw     =     Average waste incineration rate  (kg/hr)
       Example: A mass burn waterwall MSWI equipped with cold-sided ESP.
       Given:
       C    _=     10 ng TEQ/dscm (20°C, 1 atm; adjusted to 7% O2)
       Fv    =•     40,000 dscm/hr (20°C, 1 atm; adjusted to 7% O2)
       lw    =     10,000 kg MSW/hr                  "
                          =   10 ng     40,000 dscm         hr
                           EF      =     40/zg  TEQ
                             • MBWW     ~,   ,,CTI/—r	~
                                  .   .  -kg • MSW burned
       EPA was not able to obtain engineering test reports of CDD/CDF emissions for a
number of design classes. In these cases, the above procedure could not be used to derive
emission factors. Instead, the emission factors of the tested design class that was judged
most similar in terms of dioxin control was assumed to apply to the untested class. The
following logic was used to make this decision:
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  1.     The tested APCDs for the furnace type of the untested class were reviewed to see if
        any operated at a similar temperature.

  2.     If any operated at similar temperatures, the one with most similar technology was
        assumed to apply.

  3,     If none operated at a similar temperature, then the most similar furnace type with
        same control device was assumed to apply.

 Table 3-3 lists all design categories with no tested facilities and shows the class with
 tested facilities that was judged most similar.
        It should be understood that the emission factors for each design class are the same
 for both reference years.  This  is because the emission factor  is determined only by the
 design and operating conditions and is independent of the year of the test.

 Step 3. Sum emissions from tested and untested facilities. This step simply involves
 summing emissions from all tested and untested facilities.  This process is shown in Tables
 3-4 and 3-5 for the reference years 1995 and 1987, respectively.  The tables are organized
 by design class and show separately the emission estimates for the tested and .untested
 facilities. The calculation of emissions from untested facilities is broken out to show the
 activity level and emission factor for each design class.

 3.1.4. Summary of CDD/CDF (TEQ) Emissions from MSWIs for 1995 and 1987
       The activity level estimates (i.e., the amount of MSW that  is annually combusted by
 the various  MSWI technologies) are given a "high" confidence  rating for both 1987 and
 1995.  For both years, comprehensive surveys of activity levels were conducted by
 independent sources on virtually all facilities (U.S. EPA, 1987b; Systems Application
 International, 1995; Taylor and  Zannes, 1996; Solid Waste Technologies, 1994).
       The emission factor estimates are given a "medium" confidence rating for both
 1987 and 1995. A moderate fraction of the facilities were tested in both years: 11  of 113
facilities in 1987 (10 percent), and 27 of 130 facilities (21 percent)  in 1995. Moreover, the
tested facilities represent 21 and 27 percent of the total activity level of operating MSWIs
in 1987 and 1995, respectively. These tests represent most of the design categories
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  identified in this report.  The emission factors were developed from emission tests that
  followed standard EPA protocols, used strict QA/QC procedures, and were well
  documented in engineering reports. Because all tests were conducted under normal
  operating conditions/some uncertainty exists about the magnitude of emissions that may
  occur during other times (i.e., upset conditions, start-up and shut-down).
        These confidence ratings produce an overall "medium" confidence rating.  Using the
  procedures established for this report for a "medium" confidence rating, the best estimate
  of the annual emissions is assumed to be the geometric average of a range that varies by a
  factor of five between the low and high ends. For 1987, the central estimate of the^annual
  emissions is 7,915-g TEQ/yr, and the range is calculated to.be 3,540- to 17,698-g TEQ/yr.
  For 1995, the central estimate of annual emissions is 1,100-g TEQ/yr, and the range is
 calculated to be 492-to 2,460-g TEQ/yr.

 3.1.5 Congener Profiles of MSWI Facilities
       The TEQ air emissions from  MSWIs  are actually a mixture of CDD and CDF
 congeners.  These mixtures can be translated into what are termed 'congener profiles,'
 which represent the distribution of total CDDs and  CDFs present in the mixture. A
 congener profile may serve as a signature of the types of CDDs and CDFs associated with
 particular MSWI technology and APCD. Figure 3-9 is a congener profile of a mass-burn
 waterwall MSWI equipped with a dry scrubber and  fabric filter (i.e., the most common  type
 of MSWI and APCD design in use today). In general, the congener profile suggests that
 OCDD dominates total  CDD/CDF emissions. In addition,  every toxic CDD/CDF congener is
 detected in the emissions.

 3.1.6  Estimated CDD/CDFs in MSWI Ash
       Ash from MSWIs is required  to be disposed in permitted landfills. Based on
 protocols of this report, ash from MSWIs are, therefore, not considered environmental
 releases of CDD/CDFs and are not included  in the inventory. For background purposes,
 however, some information is presented below about the quantities of CDD/CDFs in ash
from MSWIs.
      An estimated 7-million metric tons of total ash (bottom ash plus fly ash) were
generated by MSWIs in 1992 (telephone conversation between J. Loundsberry, U.S.  EPA
Office of Solid Waste, and L.  Brown, Versar Inc., on February 24,  1993).  U.S. EPA

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 (1991b) indicated that 2- to 5-million metric tons of total ash were produced annually in the
 late 1980s from MSWIs, with fly ash comprising 5 to 15 percent of the total. U.S. EPA
 (1990c) reported the results of analyses of MSWI ash samples for CDDs and CDFs. Ashes
 from five state-of-the-art facilities located in different regions of the United States were
 analyzed for all 2,3,7,8-substituted CDDs and CDFs.  The TEQ levels in the ash (fly ash
 mixed with bottom ash) ranged from 106 to 466 ng/kg, with a mean value of 258 ng/kg.
 CDD/CDF levels in fly ash are generally much higher than in bottom ash. For example,
 Fiedler and Hutzinger (1992) reported levels of 13,000-ng TEQ/kg in fly ash.  Multiplying
 the mean TEQ total ash concentration by the estimated amount of MSWI ash generated
 annually (approximately 7-million metric tons in 1995 and 5-million metric tons in 1987)
 yields an estimated annual TEQ in MSWI ash of 1,800-g TEQ/yr in 1995 and  1,300-g
 TEQ/yrin 1987.
       Each of the five facilities sampled in U.S. EPA (1990c) had companion ash disposal
 facilities equipped with leachate collection systems or some means of collecting leachate
 samples.  Leachate samples were collected and analyzed for each of these systems.
 Detectable levels were only found in the leachate at one facility (TEQ = 3 ng/L); the only
 detectable congeners were HpCDDs, OCDD, and HpCDFs.

 3.1.7  Current EPA Regulatory and Monitoring Activities
       On December 19, 1995, EPA promulgated CDD/CDF emission standards for all
 existing and new MSWI units with aggregate capacities to combust greater than 35 metric
tons per day (Federal Register, 1995e). The specific emission standards (expressed as
ng/dscm of total  CDD/CDF - based on standard dry gas corrected to 7 percent oxygen) are
a function of the size, APCD configuration, and age of the facility as listed below:

             1995 Emission standard
             (ng total CDD/CDF/dscm)           Facility age, size, and APCD
                  60                         •  Existing; > 225 metric tons/day; ESP-
                                                based APCD
                  30                        •   Existing; > 225 metric tons/day; non-
                                                ESP-,based  APCD
                 125                        •   Existing; > 35 to ^225 metric
                                                tons/day
                  13                        •   New; > 35 metric tons/day
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       States have up to 3 years from promulgation of the Federal standards to submit
 revised State Implementation Plans to EPA for approval.  Once approved, States have the
 primary responsibility to implement the new standards.  This could occur as early as the
 year 2000.  As this date approaches, EPA's Office of air Quality Planning and Standards
 (OAQPS) estimates that the current estimate of national emissions of CDD/CDFs from
 existing MSWIs will decline from current levels.  OAQPS estimates full compliance by all
 MSWIs with the 1995 standards will result in an annual emission of about 24-g TEQ/yr
 (U.S. EPA, 1996d).

 3.2.   HAZARDOUS WASTE INCINERATION
       Hazardous waste inpineration (HWI) is the controlled pyrolysis and/or oxidation of
 potentially dangerous liquid, gaseous and solid waste. HWI is one technqlogy used to
 manage hazardous waste under RCRA and CERCLA (Superfund) programs.  As described
below, hazardous wastes are burned in a variety of situations and are covered in a number
             .                                                  -            /
of different sections in this report.

       Much of the hazardous waste is burned in facilities dedicated to burning waste.
       Most of these dedicated facilities are located "onsite" at chemical manufacturing
       facilities and only burn waste associated with their on-site industrial operations.
       Hazardous waste is also burned at dedicated  facilities located "offsite" from
       manufacturing facilities and accept waste from multiple sources. These fixed
       location facilities dedicated to burning hazardous waste at both on- and off-site
       locations are addressed in Sections 3.2.1 to 3.2.4.
       Hazardous waste is also burned in industrial boilers and furnaces that are permitted
      to burn the waste as supplemental fuel. These facilities have significantly different
    ,  furnace designs and operations than dedicated HWIs; therefore, they are discussed
      in Section 3.2.5.                            '
      A number of cement  kilns are also permitted to burn hazardous waste as auxiliary
      fuel; these are discussed separately in Section 5.1.
      Mobile HWIs are typically used for site cleanup at Superfund sites and operate for a
      limited duration at any given location.  These  units are 'mobile' in the sense that
      they can be transported from one location to another. Due to the transitory nature
      of these facilities, they are not included in this inventory.
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         The following subsections review the types of HWI technologies commonly in use in
  the United States, and present the derivation of emissions estimates of CDD/CDFs from all
  facilities operating in 1995 and  1987.

  3.2.1.  Furnace Designs for Dedicated Hazardous Waste Incinerators
         The four principal furnace designs employed for the combustion of hazardous waste
  in the United States are:  liquid injection, rotary kiln,  fixed hearth, and fluidized-bed
  incinerators (Dempsey and Oppelt,  1993).  The majority of commercial operations are of
  the rotary  kiln incinerator type.  On-site (noncommercial) HWI technologies are an equal mix
  of rotary kiln and liquid injection facilities, with a few additional fixed hearths and fluidized
  bed operations {U.S. EPA, 1996h).  Each of these MWI technologies is discussed below:

        Rotary Kiln HWI:  Rotary kiln incinerators consist of a rotating kiln, coupled with a
  high temperature afterburner.  Because these are excess air units designed to combust
  hazardous  waste in any physical form (i.e., liquid, semi-solid, or solid), rotary kilns are the
  most common type of hazardous waste incinerator used by commercial "off-site"
 operators.  The rotary kiln is a horizontal cylinder lined with refractory material.. Rotation'of
 the cylinder on  a slight slope provides for gravitational transport of the hazardous waste
 through the kiln (Buonicore, 1992a). The tumbling  action of the rotating kiln causes mixing
 and exposure of the waste to the heat of combustion, thereby enhancing burnout. Solid
 and semi-solid wastes are loaded into the top of the kiln by an auger or rotating screw.
 Fluid and pumpable sludges and wastes are typically introduced into the kiln through a
 water-cooled tube.  Liquid hazardous waste is fed directly into the kiln through  a burner
 nozzle.  Auxiliary fuel (natural gas or oil) is burned in the kiln chamber at start-up to reach
 elevated temperatures. The typical heating value of hazardous waste (i.e., 8,000 Btu/kg) is
 sufficient to sustain combustion without auxiliary fuel (U.S. EPA, 1996h). The  combustion
 gases  emanating from the  kiln are passed through a high temperature afterburner chamber
 to more  completely destroy organic pollutants entrained in the flue gases. Rotary kilns can
 be designed to operate at temperatures as high as 2,580°C, but more commonly operate at
 about  1,100°C.

       Liquid Injection HWI: Liquid injection incinerators (Llls) are designed to burn liquid
hazardous waste.  These wastes must  be sufficiently fluid to pass through an atomizer for
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  injection as droplets into the combustion chamber.  The Llls consist of a refractory-lined
  steel cylinder mounted either in a horizontal or vertical alignment.  The combustion
  chamber is equipped with one or more waste burners.  Because of the rather large surface
  area of the atomized droplets of liquid hazardous waste, the droplets quickly vaporize.  The
  moisture evaporates, leaving a highly combustible mix of waste fumes and combustion air
  (U.S. EPA, 1 99ph). Secondary air is added to the combustion chamber to complete the
  oxidation of the fume/air mixture.

        Fixed Hearth HWh  Fixed hearths, the third principal hazardous waste incineration
 technology, are starved air or pyrolytic incinerators, which are two-stage combustion units.
 Waste is ram-fed into the primary chamber and incinerated below stoichiometric
 requirements (i.e., at about 50 to 80 percent of stoichiometric air requirements).  The
 resulting smoke and pyrolytic combustion products are then passed though a secondary
 combustion chamber where relatively high temperatures are maintained by the combustion
 of auxiliary fuel.  Oxygen is introduced into the secondary chamber to promote complete
 thermal oxidation of the organic molecules entrained in the gases.

        Fluidized-bed HWI:  The fourth hazardous waste incineration technology is the
 fluidized-bed incinerator, which is similar in  design to that used in MSW incineration. (See
 Section 3.1 .)  In this configuration, a layer of  sand is placed on the bottom of the
 combustion chamber. The bed is preheated by underfire auxiliary fuel at startup.  During
 combustion of auxiliary fuel at start-up, the hot gases are channeled through the sand at
 relatively high velocity, and the turbulent mixing of combustion gases and combustion air
 causes the sand to become suspended (Buonicore, 1992a). This takes on the appearance
 of a fluid medium, hence the incinerator is termed a 'fluidized bed' combustor The
 incinerator  is operated below the melting point temperature of the bed material. Typical
 temperatures of the fluid  medium are within the range of 650 to 940°C.  A constraint on
 the types of waste burned is that the solid waste particles must be capable of being
 suspended within the furnace.  When the liquid or solid waste is combusted in the fluid
 medium, the exothermic reaction causes heat to be released into the upper portion of the
 combustion chamber.  The upper portion is typically much larger in volume than the lower
portion, and temperatures can reach 1,000°C  {Buonicore, 1992a). This high temperature is
sufficient to combust volatilized pollutants emanating from the combustion bed.
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 3.2.2. APCDs for Dedicated Hazardous Waste Incinerators
        Most HWIs use APCDs to remove undesirable components from the flue gases that
 evolved during the combustion of the hazardous waste. These unwanted pollutants include
 suspended ash particles ("particulate matter" or PM), acid gases, metal, and organic
 pollutants. The APCD controls or collects these pollutants and reduces their discharge from
 the incinerator stack to the atmosphere. Levels and kinds of these combustion byproducts
 are highly site-specific, depending on factors such as waste composition and incinerator
 system design and operating parameters (e.g., temperature and exhaust gas velocity). The
                         ,/ i      *     / •  „            i              i    •
 APCD  is typically comprised of a series of different devices that work  together to clean
 the exhaust combustion flue gas.  Unit  operations usually include exhaust gas cooling,
 followed by particulate matter and acid gas control.
       Exhaust gas cooling may be achieved using a waste heat boiler or heat exchanger,
 mixing with cool ambient air, or injection of a water spray into the exhaust gas. A variety
 of different types of APCDs are employed for the removal of particulate matter and acid
 gases.  Such devices include: wet scrubbers (such as venturi,, packed bed, and ionizing
 systems), electrostatic precipitators, and fabric filters (sometimes used in  combination with
 dry acid gas scrubbing). In general, the control systems can be grouped into the following
 three categories: "wet," "dry," and "hybrid wet/dry" systems.  The controls for acid gases
 (either dry or wet systems) cause temperatures to be reduced preceding the control device.
 This impedes the extent of formation of CDDs and CDFs in the post-combustion area of the
 typical HWI.  It is not unusual for stack  concentrations of CDD/CDFs at  a particular HWI to
 be in the range of 1- to 100-ng CDD/CDF/dscm (Helble, 1993), which is low in comparison
 to other waste incineration systems.  The range of total CDD/CDF flue gas concentrations
 measured in the stack emissions of HWIs during trial burns across the class of HWI
facilities, however, has spanned four orders of magnitude (ranging from 0.1 to 1,600
 ng/dscm) (Helble,  1993). The APCD systems are described below:

•      Wet Systems: A wet scrubber is used for both particulate and acid gas control.
       Typically, a venturi  scrubber and  packed-bed scrubber are used in a back-to-back
       arrangement. Ionizing wet scrubbers, wet electrostatic precipitators, and innovative
       venturi-type scrubbers may be used for more efficient particulate control. Wet
       scrubbers generate  a wet effluent liquid wastestream (scrubber blowdpwn), are
      relatively inefficient at fine particulate control compared to dry control techniques,

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        and have equipment corrosion concerns.  However, wet scrubbers do provide
        efficient control of acid gases and have lower operating temperatures (compared
       ; with dry systems), which may help control the emissions of volatile metals and
        organic pollutants.
  •      Dry Systems: In dry systems, a fabric filter or electrostatic precipitator (ESP) is used
        for particulate control. A fabric filter or ESP is frequently used in combination with
        dry scrubbing for acid gas control. Dry scrubbing systems, in comparison with wet
        scrubbing systems, are inefficient in controlling acid gases.
  •      Hybrid Systems: In hybrid systems, a dry technique (ESP or fabric filter) is used for
       particulate control, followed by a wet technique (wet scrubber) for acid gas control.
       Hybrid systems have the advantages of both wet and dry systems (lower operating
       temperature for capture of volatile metals, efficient collection of fine particulate,
       efficient capture of acid gases), while avoiding many of the individual
       disadvantages. In some hybrid systems, known as "zero discharge systems," the
       wet scrubber liquid is used in the dry scrubbing operation, thus minimizing the
      s amount of liquid  byproduct waste.
 *     Uncontrolled HWIs: Facilities that do not use any air pollution control devices fall
       under a separate and unique category. These are primarily liquid waste injection
       facilities, which burn low ash and chlorine content wastes; therefore, they are low
       emitters of PM and acid gases.                 ,

 3.2.3. Estimation of CDD/CDF Emission Factors for Dedicated Hazardous Waste
       Incinerators
       i                     .-":                   '            ,
       For purposes of estimating emission factors, this document considers subdividing
 the combustors in each source category into design classes judged to have similar potential
 for CDD/CDF emissions. As explained below, it was decided not to subdivide dedicated
 HWIs.                           ,-.'•'•
       Combustion research has identified three mechanisms involved in the emission of
 CDD/CDFs from combustion systems:  (IKCDD/CDFs can be introduced into the combustor
 with the feed and pass through the  system not  completely burned/destroyed; (2) CDD/CDFs
 can be formed by chemical reactions inside the  combustion chamber; and (3) GDD/CDFs
 can be formed by chemical reactions outside the combustion chamber. The total CDD/CDF
emissions  are likely to be the net result of all three mechanisms; however, the relative
                                  i^, .      .      •. •         •        .'.,••
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  importance of the mechanisms can vary among source categories.  In the case of HWIs, the
  third mechanism (i.e., post-combustion formation) is likely to dominate, because HWIs are
  typically operated at high temperatures and long residence times, and most have
  sophsiticated real-time monitoring and controls to manage the combustion process.
  Therefore, any CDD/CDFs present in the feed or formed during combustion are likely to be
  destroyed before exiting the combustion chamber. Consequently, for purposes of
  generating emission factors, it was decided not to subdivide this class on the basis of
  furnace type.
        Emissions resulting from the post-combustion formation in HWIs can be minimized
  through a variety of technologies:

  *      Rapid Flue  Gas Quenching: The use of wet and dry scrubbing devices to remove
        acid gases  usually results in the rapid reduction of flue gas temperatures at the inlet
        to the PM APCD. If temperature is reduced below 200°C, the low-temperature
        catalytic formation of CDD/CDFs is substantially retarded.
 *      Use of Particulate Matter (Pm) Air Pollution Control Devices:  PM control devices can
        effectively capture condensed and adsorbed CDD/CDFs that are associated with  the
        entrained particulate matter (in particular, that which is adsorbed on unburned
        carbon containing particulates).
 *      Use of Activated Carbon:  Activated carbon injection is used at some HWIs to
        collect (sorb)  CDD/CDFs from the flue gas.  This may be achieved using carbon beds
        or by injecting carbon and  collecting it in a downstream PM APCD.

       All of these approaches appear very effective in controlling dioxin emissions at
 dedicated HWIs, and insufficient emissions data are available to generalize about any minor
 differences. Consequently, for purposes of generating emission factors, it was decided not
 to subdivide this class on the basis of APCD type.
       EPA compiled a data base summarizing the  results of stack testing for CDDs and
 CDFs at 17 HWIs (U.S. EPA, 1996c). Most facilities were tested between 1993 and
 1996.  For purposes of this report, CDD/CDF emission factors were estimated based on
the results of the emission tests contained in this data base. The breakdown of furnace
types of tested  HWI facilities is as follows: 10 rotary kiln incinerators, 4 liquid injection
incinerators, 1 fluidized-bed incinerator,  and 2 fixed-bed.

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        As stated earlier, EPA/ORD decided not to subclassify the dedicated HWI designs for
  purposes of deriving an emission factor (EF). Instead, the EF was derived as an average
 .across all 17 tested facilties.  First, an average emission factor was calculated for each of
  17 HWIs with Equation 3-3.

 '                                EF    -   C  X ^
                                 *rhWi  ~       j—r                      (Eqn. 3-3)
                                     '•'
 Where:
        EFhwi  =    Emission factor(average ng TEQ per kg of waste burned).
        C           TEQ or CDD/CDF concentration in flue gases (ng TEQ/dscm) (20°C, 1
                    atm; adjusted to 7% O2j.
       ,F-V     =    Volumetric flue gas flow rate (dscm/hr) (20°C, 1 atm; adjusted to 7%
                    02^'  •       -•••/.•
        lw     =    Average waste incineration rate (kg/hr).

 After developing average emission factors for each HWI, the overall average congener-
 specific emission factor was derived for all 17 tested HWIs using Equation 3-4.
                                                                          (Eqn. 3-4)
       Where:
             EFHWI  = Average emission factor of 18 tested MWIs ng/kg
Table 3-6 presents the average emission factors developed for specific congeners, total
CDDs/CDFs, and TEQs for operating HWIs. The average congener emission profiles for the
17 HWIs are presented in Figure 3-10. The average TEQ emission factor for the 17 tested
HWIs is 3.8-ng TEQ/kg of waste feed (assuming not detected values are zero).

3.2.4. Emission Estimates for Dedicated Hazardous Waste Incinerators
       Although emissions data on a relatively high number of dedicated HWIs were
available (i.e., 17 of 162 have been tested), the emission factor estimate is assigned a
"medium" confidence rating due to uncertainties resulting from:

      Extreme heterogeneity of the waste feeds. The physical and chemical composition
      of the waste can vary from facility to facility and even within a facility.

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        Consequently, CDD/CDF emissions measured for one feed may not be representative
        of other feeds.

 •      Trial burns.  Much of the CDD/CDF emissions data were collected during trial burns,
        which are required as part of the RCRA permitting process and are used to establish
        Destruction  Rated Efficiency of principal hazardous organic constituents in the
        waste. During trial burns,  a prototype waste is burned, which is intended to
        maximize the difficulty in achieving good combustion. For example, chlorine,
        metals, and  organics may be added to the waste. The HWI may also be operated
        outside normal operating conditions. The temperature of both the furnace and the
        APCD may vary by a wide margin {high and low temperatures), and the waste feed
        system may be increased to maximum design load. Accordingly, it is uncertain how
        representative the CDD/CDF emissions measured during the trial burn will be of
        emissions during normal operating conditions.


        Dempsey and Oppelt (1993) estimated that up to 1.3-rnillion metric tons of

 hazardous waste were combusted in dedicated  HWIs during  1987.  The best estimate of
                 ,;           '            „.,!',      '             •»•           '
 the amount of hazardous waste combusted in 1995 is 1.5-million metric tons (Federal

 Register, 1996b). The activity level estimate for 1995 is assigned a "high" confidence

 rating,  because it is based on a thorough review of the various  studies and surveys

 conducted in the 1990s to assess the quantity and types of hazardous wastes being

 managed by various treatment, storage, and disposal facilities.  A confidence  rating of
 "medium" is assigned to the activity level estimate for 1987.
                                        •              '.  ,»:
       The annual TEQ emissions  for the reference years 1995  and 1987 were estimated
 using Equation 3-5.
                                                                         (Eqn. 3-5)
Where:
       EHW,  =    Annual emissions from all HWIs, tested and non-tested (g TEQ/yr)
             =    Mean emission factor for HWIs (ng TEQ/kg of waste burned)
             =    Annual activity level of all operating HWIs (million metric tons/yr)
       Applying the average emission factor for dedicated HWIs (3.8-ng TEQ/kg waste) to

these production estimates yields estimated emissions of 5.7-g TEQ in 1 995 and 5.0-g TEQ

in 1987 for HWIs.  The "medium" confidence rating assigned to the emission factor,

combined with the high confidence rating for the 1995 activity level and medium


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  confidence rating for the 1 987 activity level, yields an overall medium confidence rating for
  both years. Accordingly, the estimated range of annual emissions is assumed to vary by a
  factor of five between the low and high ends  of the range.  For 1 995, the range of TEQ
  emissions is estimated to be 2.6- to 12.8-g TEQ/yr,  For 1987, the range of TEQ emissions
  is estimated to be 2. 2- to  11. 2-g TEQ/yr.
        EPA/OSW has also developed estimates of the CDD/GDF emissions from dedicated
  HWIs as part of the development of the Hazardous Waste Incineration Rule (U.S.  EPA,
  1997d). Like ORD, OSW also  decided not to subdivide the dedicated HWIs on the basis of,
  design. Instead of an emission factor approach, OSW used an imputation method to
  estimate emissions at untested facilites. This  procedure involved randomly selecting
  measured CDD/CDF flue gas concentrations (ng/dscm) from the pool of tested HWI
  facilities and assigning them to the untested facilites. With this procedure, all non-tested
  HWIs have an equal chance of  being assigned  any flue gas concentration from the pool of
  measured values.  The flue gas concentrations were combined with flue gas flow rates for
  each facility to estimate the emission rate. A key difference in these approaches is that
  ORD uses waste feed rate directly in the calculation of emissions and the OSW approach is
 independent of waste feed rate. Both procedures are reasonable ways to deal with the
 broad range of uncertainties and both yield similar emission estimates.  ORD has not
 identified any inherent advantage of one approach over the other and elected to use the
 emission factor approach primarily because it is consistent with the methods used in this
 document to characterize CDD/CDF emissions from all other source categories.

 3.2.5. Industrial Boilers  and Furnaces Burning Hazardous Waste
       In 1 991 ,  EPA established rules that allow the combustion of some liquid hazardous
 waste in industrial boilers and furnaces  (Federal Register, 1991c).  These facilities typically
 burn oil or coal for the primary purpose  of generating electricity.  Liquid hazardous waste
 can only be  burned as supplemental (auxiliary) fuel, and usage is  limited by the rule to no
 more than 5 percent of the  primary fuels. These facilities typically use an atomizer to inject
 the waste as droplets into the combustion chamber and are equipped with particulate and  ;
 acid gas emission controls.   In general,  they are sophisticated, well controlled facilities,
 which achieve good combustion.                                         <
       The national data base contains congeneMspecific emission concentrations for two
tested boilers burning liquid  hazardous waste as supplemental fuel. The average congener
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  '"'         .       '              •        ii  ,    ,        ,
  and congener group emission profiles for the industrial boiler data set are presented In
  Figure 3-11.  The average congener and TEQ emission factors are presented in Table 3-6.
  The limited set of emissions data prevented subdividing this class for the purpose of
  deriving an emission factor. The equation used to derive the emission factor is the same as
  Equation 3-4 above. The average TEQ emission factor for the two industrial boilers is 0.64-
  ng TEQ/kg of waste feed.  This emission factor is assigned a "low" confidence rating,
  because it reflects testing at only 2 of the 136 hazardous waste boilers/furnaces.
        Dempsey and Oppelt (1993) estimated that approximately 1.2-billion kg of
  hazardous waste were combusted in industrial boilers/furnaces in 1987.  EPA estimates
  that in 1995  approximately 0.6-billion kg of  hazardous waste were combusted in industrial
  boilers/furnaces (Federal Register,  1996b).  The activity level estimate for 1995 is assigned
  a "high" confidence rating, because it is based on a thorough review of the various studies
  and surveys conducted in the 1990s to assess the quantity and  types of  hazardous wastes
  being managed by various treatment, storage, and disposal facilities (Federal Register,
  1996b). A confidence rating of "medium" is assigned to the estimated activity level for
  1987. The 1987 estimate was largely based on a review of State permits (Dempsey and
 Oppelt, 1993).
       Equation 3-5, used to calculate annual TEQ emissions for dedicated HWIs. was also
 used to calculate annual TEQ emissions for industrial boilers/furnaces. Multiplying the
 average TEQ emission  factor of 0.64-ng  TEQ/kg of waste feed by the total estimated kg of
 liquid hazardous waste burned in 1995 and 1987 yields the annual emissions in g TEQ/yr.
 From this procedure, the emissions from all industrial boilers/furnaces burning hazardous
 Waste as supplemental fuel are estimated as  0.38-g TEQ/yr in 1995 and 0.77-g TEQ/yr in
 1987. Because of th.e  low confidence .rating  for the emission factor, the overall confidence
 rating  is low for both the  1987 and 1995 emission estimates.  Accordingly,  it is assumed
 that the uncertainty range around the best estimate varies by a factor of 10 between the
 low and high ends of the range. Thus, the uncertainty ranges are 0.12- to 1.2-g TEQ/yr for
 1995 and 0.24- to 2.4-g TEQ/yr for 1987.

3,3.   MEDICAL WASTE INCINERATION
       Medical waste incineration (MWI)  is the controlled  burning of solid wastes generated
primarily by hospitals, veterinary, and medical research facilities.  The U.S. EPA defines
medical waste as any solid waste generated in the treatment, diagnosis, or immunization of

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  humans or animals, or research pertaining thereto, or in the production or testing of
  biologicals (Federal Register, 1997b).  The primary purposes of MWI are to reduce the
  volume and mass of waste in need of land disposal, and to sterilize the infectious materials.
  The following subsections review the basic types of MWI designs used to incinerate
  medical waste, review the distribution of APCDs used on MWIs, summarize the derivation
•  of dioxin TEQ emission factors for MWIs, and summarize the national dioxin TEQ emission
  estimates for reference years 1995 and 1987.

  3.3.1. Design Types of MWIs Operating in the United States
        For purposes of this document,  EPA has classified MWIs into three broad technology
  categories: modular furnaces using controlled-air, modular furnaces  using excess-air, and
  rotary kilns. Of the MWIs in use today, the vast majority are believed to be modular
 furnaces using controlled-air.  EPA has estimated that  97 percent are modular furnaces
 using controlled-air, 2 percent are modular furnaces using excess air, and 1  percent are
 rotary kiln combustors (U.S. EPA, 1997b).
       Modutar Furnaces Using ControHed-air:  Modular furnaces have two separate
 combustion chambers mounted in series (one on top of the other).  The lower  chamber is
 -where the primary combustion of the medical waste occurs. Medical waste is ram-fed into
 the primary chamber, and underfire air is delivered beneath the incinerator hearth to sustain
 good burning of the waste.  The primary combustion chamber is operated at below
 stoichiometric levels, hence the terms "controlled" or "starved-air."  With sub-
 stoichiometric conditions, combustion occurs at relatively low temperatures  (i.e., 760 tp
 985°C).  Under the conditions of low oxygen-and low temperatures, partial pyrolysis of the
 waste occurs, and volatile compounds are released.  The combustion gases pass into a
 second chamber. Auxiliary fuel (such as natural gas)  is burned to sustain elevated
temperatures (i.e., 985 to 1,095°C)  in this secondary chamber.  The net effect of exposing
the combustion gases to an elevated temperature is more complete destruction the organic
contaminants entrained in the combustion gases emanating from the primary combustion
chamber.  Combustion air at 100 to 300 percent in excess of stoichiometric  requirement is
usually added to the secondary chamber. Gases exiting the secondary chamber are
directed to an incinerator stack (U.S. EPA, 1997b; U.S. EPA, 1991d; Buonicore, 1992b).
Figure 3-12 displays a schematic of a typical modular furnace using controlled-air. Because
of their low cost and good combustion performance, this design has been the most popular
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  choice for MWIs and has accounted for more than 95 percent of systems installed over the
  past two decades (U.S.'EPA, 1990d; U.S. EPA, 1991d; Buonicore, 1992b).
        Modular Furnaces Using Excess-air:  These systems use the same modular furnace
  configuration as described above for the controlled air systems. The difference is that the
  primary combustion chamber is operated at air levels of 100 percent to 300  percent in
  excess of stoichiometric requirements. Hence the name 7excess-air."  A secondary
  chamber is located on top of the primary unit.  Auxiliary fuel is added to sustain high
 temperatures in an excess-air environment. Excess-air MWIs are typically smaller in
 capacity than controlled-air units and are usually batch-fed operations.  This  means that the
 medical waste is ram-fed into the unit and allowed to burn completely before another batch
 of medical waste is added to the primary combustion chamber.
       Rotary Kiln MWI: This technology is similar in terms  of design and operational
 features to the rotary kiln technology employed in both municipal and hazardous waste
 incineration. (See description in Section 3.1.)  Because of their relatively high capital and
 operating costs, few rotary kiln incinerators are in operation  for medical waste treatment
 (U.S. EPA, 1990d; U.S. EPA, 1991 d; Buonicore,  1992b).
       MWIs can be operated in three modes: batch, intermittent, and continuous. Batch
 incinerators burn a single load of waste, typically only once per day.  Waste is loaded, and
 ashes, are removed manually. Intermittent incinerators,  loaded continuously and frequently
 with small  waste batches, operate less than 24 hours per day, usually on a shift-type basis.
 Either manual or automated charging systems can be used, but the incinerator must be shut
 down for ash removal. Continuous incinerators are operated 24 hours per day and use
 automatic charging systems to charge waste into the unit in  small,  frequent batches.  All
 continuous incinerators operate using a mechanism to automatically remove the ash from
 the incinerator (U.S. EPA, 1990d; U.S. EPA, 1991d).

 3.3.2. Characterization of MWIs for Reference Years 1995 and 1987
       MWI remains a poorly characterized industry in the United States in terms of
 knowing the exact number of facilities operational over time, the types of APCDs installed
on these units, and the aggregate volume and weight of medical waste that is combusted
in any given year (U.S. EPA, 1997b). The primary reason for this is that permits were not
generally required for the control of pollutant stack emissions from MWIs until the early
1990s when State regulatory agencies began setting limits on emissions of particulate

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  matter and other contaminants (Federal Register, 1997b).  Prior to that timeframe, only
  opacity was controlled.
        The information available to characterize MWIs comes from national telephone
  surveys, stack emission permits, and data gathered by EPA during public hearings (Federal
  Register, 1997b). This information suggests the following:

       The number of MWIs in operation was approximately 5,000 in 1987 (U.S. EPA,
        1987) and 2,375 in 1995 (Federal Register, 1997b).
 •     The amount of medical waste combusted annually in the United States was
       approximately 1.43-billion kg in  1987 (U.S. EPA, 1987d) and 0.77-billion kg in 1995
       (Federal Register, 1997b).
 These estimates  indicate that, between 1987 and  1995, the total number of operating
 MWIs and the total amount of waste combusted decreased by more  than 50 percent.
 Certain activities caused this to occur, including more stringent air pollution control
 requirements by State regulatory agencies  and the development of less expensive medical
 waste treatment  technologies, such as autoclaving (Federal Register, 1997b).  Because
 many MWIs have small waste charging  capacity (i.e., about 50 metric tons per day), the
 installation of even elementary APCDs proved not to be cost effective. Thus, a large
 number of facilities elected to close rather than retrofit. .
       The actual controls used on  MWIs on a facility-by-facility basis in 1987 are
 unknown, and EPA generally assumes that MWIs were mostly uncontrolled (U.S.
 EPA,1987d). However, the modular design does cause some destruction of organic
 pollutants within the secondary combustion chamber.  Residence time within the secondary
 chamber is key to inducing the thermal destruction of the organic compounds.  Residence
 time is the time that the organic compounds entrained within the flue gases are exposed to
 elevated  temperatures in the secondary  chamber. EPA has demonstrated with full-scale
 MWIs that increasing residence time from 1/4 second to 2 seconds in the secondary
 chamber can reduce organic pollutant emissions, including CDD/CDFs, by up to 90 percent
 (Federal Register,  1 997b). In this regard, residence time can be viewed as a method of air
 pollution  control.
      EPA estimates that about two-thirds of medical waste burned  in MWIs in 1995 went
to facilities equipped with some method  of air pollution control (FederalRegister,  1997b).
The types of APCDs installed and the methods used on MWIs include: dry sorbent injection.
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 fabric filters, electrostatic precipitators (ESPs), wet scrubbers, and fabric filters combined
 with packed-bed scrubbers (composed of granular activated carbon).  Some organic
 constituents in the flue gases can be adsorbed by the packed bed.  Within the uncontrolled
 class of MWIs, about 12 percent of the waste were combusted  in facilities with design
 capacities of <200 Ibs/hr, with the majority of waste burned facilities >200 Ib/hr.  The
 estimated breakdown of controlled facilities is:  70 percent of the aggregate activity level
 are associated with facilities equipped with either wet scrubbers, fabric filters, or ESPs;
 29.9 percent are associated with facilities utilizing dry sorbent injection, combined with
 fabric filters, and less than 1  percent is associated with facilities having the fabric
 filter/packed-bed APCD (AHA, 1995; Federal Register, 1997b).

 3.3.3. Estimation of CDD/CDF Emissions From MWIs
       Only  1 percent of existing facilities (i.e., 24 MWIs) has been stack sampled for
 CDD/CDFs.  Consequently, most facilities have unmeasured emission levels of dioxin-like
                 il       "     H                 '    '   ' '    '!  "I" •  "'     '   ' •   , •      '
 compounds.  Because so few have been evaluated, the estimation of annual air emissions
 of CDD/CDFs from  MWIs is quite dependent on extrapolations, engineering judgement, and
 the use of assumptions.  In addition, the information about the activity levels of these
 facilities is also quite limited. With these data limitations, two approaches have been used
 in the past to estimate CDD/CDF emissions from MWIs, and a third is proposed here.
 These three approaches are as follows:

       1-    EPA/OAQPS Approach:  EPA's Office of Air Quality Planning and
             Standards used this approach in support of the promulgation of final
             air emission standards for hospital/medical/infectious waste
             incinerators (Federal Register, 1997b).,
      2.     AHA Approach: The American Hospital Association proposed an approach in
             its comments on 'drafts of this document and on the proposed MWI emissions
             regulations (AHA, 1995).
      3.    EPA/ORD Approach: In preparation of this document, EPA's Office of
             Research and Development (ORD) has developed a third approach.
Given the limitations with existing information,  both the EPA/OAQPS and AHA approaches
are reasonable methods for calculating annual releases of CDD/CDFs from MWIs.  Both
methods relied heavily on a series of assumptions to account for missing information. In
developing a third approach,  EPA/ORD built upon the other two approaches by utilizing the

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 most logical features of each.  Because of the uncertainties with existing data, it is
 currently hot known which approach gives the most accurate estimate of CDD/CDF air
 emissions from all MWIs, nationwide.  The three approaches yield different air emission
 estimates, but the estimates all agree within a factor of four.  As discussed below, the
 EPA/ORD approach used the strengths of the other two approaches, and represents"some
 improvement in estimating CDD/CDF emissions.

 3.3.4. EPA/OAQPS Approach for Estimating CDD/CDF Emissions from MWIs
       On September 15, 1997, EPA promulgated final standards of performance for new
 and existing MWIs under the Clean Air Act Amendments (Federal Register, 1997b).
 CDD/CDF stack emission limits for existing MWIs were  established as follows: 125
 ng/dscm of total CDD/CDF (at 7 percent O2, 1  atm), equivalent to 2.3 ng/dscm TEQ.  In
 order to evaluate emissions reductions that wil| be achieved by the standard, OAQPS
 estimated, as a baseline for comparison, nationwide annual CDD/CDF emissions from all
 MWIs operating in  1995.

 3.3.4.1.      EPA/OAQPS Approach for Estimating Activity Level
      As a starting point for deriving the national estimates, OAQPS constructed an
 inventory of the numbers and types of MWIs believed to be operating in 1995.  The
 inventory was based on ah inventory of 2,233  MWIs prepared by the American Hospital
Association (AHA,  1995), supplemented with additional information compiled by EPA. This
created a listing of  2,375 MWjs  in the United States. Next a series of assumptions were
used to derive activity level estimates, as follows:
                  . - .   j        i  ."       . •• •       .     •  • '       •       •-.••.
      1.    The analysis divided MWIs into three design types based on the mode of
            daily  operation: batch, intermittent, and continuous. This was done using the
            information from the inventory on design-rated annual incineration capacity of
            each  facility.  The smaller capacity units were assumed to be batch
            operations, and the others were classified  as either intermittent or
            continuous, assuming a ratio of three to one.

      2.     The activity level of each facility was estimated by multiplying the design-
            rated  annual incineration capacity of the MWI (kg/hr) by the hours of
        -    operation (hr/yr). The annual hours of operation were determined by
            assuming a capacity factor (defined as the fraction of time that a unit
            operates over the year)  for each design type of MWI (Randall, 1 995). Table
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                                1                 ' ''•,
              3-7 is a summary of the OAQPS estimated annual operating hours per IMWI
              design type.

 3.3.4.2.     EPA/OAdPS Approach for Estimating CDD/CDF Emission Factors
        Based on information obtained from AHA and  State regulatory agencies, one-third of
 the population of MWIs operating in 1995 was etimated to have had no APCDs (i.e., were
 uncontrolled), and two-thirds had some type of APCD.  CDD/CDF TEQ emission factors
 were then developed for uncontrolled and controlled MWIs.  The procedure was as follows:
        Estimating TEQ Emission Factors for Uncontrolled Facilities: The uncontrolled
 category of facilities was subdivided by residence time  of the secondary combustion
 chamber.  Based on tests at three MWIs, OAQPS concluded that stack emissions of
 CDD/CDFs from uncontrolled facilities were dependent on the residence time (i.e., the
 duration of time the compounds are exposed to elevated temperatures within the secondary
 combustion champer) (Strong, 1996). The tests demonstrated that when the residence
                N|" ,  '      ;       ,i   •                    .,,
 time in the secondary chamber was short (i.e., < 1 sec), the stack emissions of
 CDDC/CDFs would  increase; conversely, the longer the  residence time (i.e., > 1  sec),, the
 CDD/CDF emissions decrease. The emissions testing  at these MWIs provided the basis for
 the derivation of CDD/CDF TEQ emission factors  for residence times of 1/4-sec, 1-sec and
 2-sec.  Table 3-8 is a summary of the emission factors developed for each MWI type as a
 function of residence time.                                  ;
       The OAQPS  inventory of MWIs in 1995 did not provide residence times for each
 facility.  OAQPS overcame this data gap by assuming that residence time  in the secondary
 combustion chamber approximately corresponds with  the particulate matter (PM) stack
 emission limits established in State air permits. This approach assumed that the more
 stringent PM emission limits would require longer residence times in the secondary chamber
 in order to  further oxidize carbonaceous soot particles and reduce PM emissions.  Table 3-8
 lists the assumed residence times in the secondary chamber corresponding to various State
 PM emission limits.  State Implementation Plans (SIPs) were reviewed to determine the PM
 emission limits for incinerators, and from this review, both a residence time and a  TEQ
                             I ,  ' *   '    '        ' ',    '!'',"'  "I ,':
 emission factor were assigned to each uncontrolled MWI on the.inventory.
                 ,  '     ,               '   '       ;,   ' ',' i1'!1   i|h   • '    •   ' - •      '
       Estimating TEQ Emission Factors for Controlled MWIs:  Two-thirds of the MWI
 population were assumed to have some form of APCD.  AS previously discussed, APCDs
typically used by MWIs consist of one or more of the following: wet scrubber, dry scrubber,
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 and fabric filter combined with a packed bed.  The EPA/OAQPS approach also included the
 addition of activated carbon to the flue gases as a means of emissions control (i.e., dry
 scrubbers combined with carbon injection). TEQ emission factors were developed for these
 control systems based on incinerator emissions testing data gathered in support of the
 regulations (U.S. EPA, 1997b).  Because the inventory did not list the APCDs for all MWIs,
 State requirements for PM control were used to make assumptions about the type of APCD
  s     -,"'*•'',,
 installed on each facility in the inventory.  These assumptions are  summarized in Table 3-9.

 3.3.4.3.     EPA/OAQPS Approach for Estimating Nationwide CDD/CDF TEQ Air
             Emissions
       Annual TEQ emissions for each MWI facility were calculated as a function of the
 design capacity of  the incinerator, the annual waste charging hours, the capacity factor,
 and the TEQ emission faptor as shown in Equation 3-6.              -  •     -
                     Emnwi  =  (CxHx Cj )  x  F.
TEQ                   (Eqn. 3-6)
       Where-.
       Emmwi     =   Annual MWI CDD/F TEQ stack emissions (g/yr)
            C     =,  MWI design capacity (kg/hr)
            H     =   Annual medical waste charging hours (hr/yr)
           CT     -   Capacity factor (unitless)
         FTEQ     =   CDD/CDF TEQ emission factor (g TEQ/kg)

The annual TEQ air emission of all MWIs operating in 1995 is the sum of the annual
emissions of each of the individual MWIs. The following equation is applied to estimate
annualTEQ emissions from all  MWIs.                                       ' - -
                                                            Emmm,m >   (Eqn. 3-7)
      Where:
      Emmwi(nationw'de)   =    Nationwide MWI TEQ emissions (g/yr)
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  Table 3-9 is a summary of annual CDD/CDF TEQ emissions for 1995 estimated using the
  EPA/OAQPS Approach.

  3.3.5. AHA Approach for Estimating CDD/CDF Emissions from MWIs
        In 1995, the American Hospital Association (AHA) submitted written comments to
  EPA in response to EPA's request for public comment of the 1994 draft public release of
 this document (AHA,  1995). As part of these comments, the AHA attached an analysis of
 CDD/CDF emissions from MWIs prepared by Doucet (1995) for the AHA.  Doucet (1995)
 estimated the total number of MWIs operating in 1995,  the distribution of APCDs,
 CDD/CDF TEQ emission factors, and tfoe nationwide TEQ emissions. The following is a
 brief discussion  of the AHA inventory and the Doucet (1995) analysis.
        From a natipnal telephone survey of  member hospitals conducted between
 September and November 1994, the AHA developed what is generally considered as the
 first attempt to systematically inventory MWIs in the United States. Approximately 6
 percent of the hospitals with MWIs were contacted (AHA, 1997). The AHA survey showed
 that, as of December, 1994, 2,233 facilities were in operation.  Doucet (1995) subdivided
 the AHA MWI inventory into two uncontrolled categories on the basis of combustor design-
 rated capacity and two controlled categories on the basis of APCD equipment. Doucet
 (1995) then developed CDD/CDF emission factors for each category of MWIs. Test reports
 of 19 MWIs were collected and evaluated.  Average CDD/CDF TEQ flue gas concentrations
 (i.e.,  ng/dscm @7 percent O2) were derived by combining tests from several MWIs in each
 capacity range category and APCD. The average TEQ flue gas concentrations were then
 converted to average TEQ emission factors, which were in units of Ib TEQ/106 Ibs of
 medical waste incinerated (equation for conversion not given). Table 3-10 is a summary of
 TEQ emission factors calculated by Doucet (1995) for each level of assumed APCDs on
 MWIs.
       Similar to the EPA/OAQPS Approach (Section 3.3.4), the distribution of the APCD
 categories was derived by assuming that State paniculate emission  (PM) limits would
 indicate the APCD on any individual MWI (Doucet, 1995). Table 3-11 displays the AHA
 assumptions of air pollution control (APC) utilized on MWIs based upon PM emission limits.
       With the activity levels, the percent distribution of levels of controls, and the
 CDD/CDF TEQ emission factors having been calculated with existing data, the final step of
the AHA Approach was the estimation of annual TEQ emissions (g/yr) from MWIs,

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  nationwide, Although no equation is given, it is presumed that the emissions were
  estimated by multiplying the activity level for each MWI size and APCD category by the
  associated TEQ emission factor. The sum of these calculations for each designated class
  yields the estimated annual TEQ emissions for all MWIs, nationwide.  Doucet (1995)
  indicates that these computations are appropriate for TEQ emissions in 1995.  Table 3-12
  summarizes the nationwide annual TEQ emissions from MWIs using the AHA Approach.

  3.3.6. EPA/ORD Approach for Estimating CDD/CDF Emissions from MWIs
       Because of limitations in emissions data and on activity levels, the EPA/ORD
 approach used many of the logical assumptions developed in the EPA/OAQPS and AHA
 approaches. The discussion below describes the rationale for how these decisions were
 made, and presents the resulting emission estimates.

 3.3.6.1.     EPA/ORD Approach for Classifying MWIs and Estimating Activity Levels
       As with the  EPA/OAQPS and AHA approaches, the EPA/ORD approach divided the
 MWIs into controlled and uncontrolled classes.  The decisions about further dividing these
 two classes are described below:
       Uncontrolled MWIs:  For purposes of assigning CDD/CDF emission factors and
 activity levels to the uncontrolled class of MWIs, the EPA/OAQPS approach divided this
 class on the basis of residence time within the secondary combustion chamber. This
 approach has theoretical appeal, because it is logical to expect more complete combustion
 of CDD/CDFs with longer residence times at high temperatures.  Unfortunately/the
 residence times on a facility-by-facility basis are not known, making it difficult to assign
 emission factors and activity levels on this basis.  As discussed earlier, the EPA/OAQPS
 approach assumed that residence time would  strongly correlate with State PM stack
 emission requirements (i.e., the more stringent the PM requirements, the longer the
 residence time required to meet the standard). This PM method for estimating residence
 time resulted in the following distribution of residence times: 6 percent of the waste
 incinerated at MWIs with 1/4-sec residence time; 26 percent of the waste incinerated at
 MWIs with 1-sec residence time; and 68 percent of the waste incinerated at MWIs with 2-
sec residence time.  Thus, about two-thirds of the activity level within the uncontrolled
class were assumed in the EPA/OAQPS approach to be associated with facilities with the
longest residence time and the lowest CDD/CDF emission factor.

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        The AHA approach subcategorized the uncontrolled class on the basis of design-
  rated capacity. There is also theoretical support for this approach.  Smaller capacity
  operations (i.e., <200 Ib/hr) are likely to have higher emissions, because they are more
  likely to be operating  in a batch mode.  The batch mode results in infrequent operation with
  more start-up and shut-down cycles. Thus, the batch-operated MWI usually spends more
  time outside  of the ideal range of operating conditions.  In support of this approach, the
  AHA presented limited empirical evidence indicating that CDD/CDF emission factors
  calculated from emission test reports for the low capacity units were about a factor of two
  higher than the emission factors for the high capacity units (Doucet, 1995).
       Thus,  both the EPA/OAQPS and AHA approaches have a sound theoretical basis but
  lack strong supporting data. In order to decide which of the two approaches to use, ORD
 first tested the assumption that there is a strong relationship between State PM
 requirements  and residence time.  ORD conducted a limited telephone survey of regulatory
 agencies in four States where a large number of MWI facilities were in operation: Michigan,
 Massachusetts, New Jersey, and Virginia (O'Rourke, 1996). The results of the limited
 survey, summarized in Table 3-13, did not verify the existence of a strong dependent
 relationship between PM emission limits and residence time in the secondary chamber at
 MWIs.
       Next, the available emission testing data for small and high capacity units (i.e.,  less
 than and greater than 200 Ib/hr) were evaluated to determine if, as posited in the AHA
 approach, smaller capacity units have greater emission factors than large capacity units.
 This evaluation indicated a distinct difference in the emission factors between the two
 capacity categories, although the difference in the set of data evaluated was not as  great
 as the difference observed in the data set evaluated in the AHA approach. The EPA/ORD
 approach, therefore, adopted the subcategorization scheme used in the AHA approach.
       Controlled MWIs:  Both the EPA/OAQPS approach and the AHA approach
 subcategorized the controlled MWIs on the basis of APCD equipment. However,  the two
 approaches  differed in the subcategories developed. The AHA approach divided the
 controlled class into two  groups: facilities equipped with wet scrubbers (alone, with  an
 ESP, or with a fabric filter), and facilities equipped with dry sorbent injector and a fabric
filter (Doucet,  1995).  The EPA/OAQPS approach divided the controlled class into three
groups: facilities equipped with wet scrubbers, facilities equipped with dry scrubbers (with
or without carbon injection),  and facilities equipped with fabric filters and packed  bed

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  scrubbers. This third category is comprised of a few facilities primarily located in the
  Northeast United States (O'Rourke, 1996).  The EPA/ORD approach adopted the two
  subcategories of the AHA approach and the third subcategory of the EPA/OAQPS
  approach.  For 1995, ORD used the activity levels for each facility as determined by the
  EPA/OAQPS inventory; the activity levels were then summed across facilities for each
  APCD subclass.,
        For 1987, the EPA/ORD approach assumed that every MWI was uncontrolled on the
  basis of a EPA study of MWI incineration conducted at that time (U.S. EPA,  1987d).  This
  study indicates that MWIs operating in 1987 did not need controls, because they were not
  subject to State or Federal limits on either PM or organic pollutant emissions. The activity
  level estimates were derived from additional EPA studies (U.S. EPA,  1987d). this approach
  resulted in the following activity level assumptions for 1987: (3)  15 percent of the activity
 level (i.e., 0.2-billion kg medical waste) were incinerated/yr by MWIs with capacities less
 than or equal to 200 Ib/hr, and (b) 85 percent of the activity level (i.e., 1-billion kg/yr) were
 incinerated by facilities with capacities greater than 200 Ib/hr.

 3.3.6.2.     EPA/ORD Approach for Estimating CDD/CDF Emission Factors
       EPA/ORD collected the engineering reports of 24 tested MWIs.  After reviewing
 these test reports, 19 met the criteria for acceptability. (See Section 3.1.3 for further
 details on the criteria.) In some cases, CDD/CDF congener-specific data were not reported,
 ori values were missing.  In other cases, the protocols used in the laboratory analysis were
 not described; therefore, no determination of the adequacy of the laboratory methods could
 be made.   .
       The EPA stack testing method (EPA Method 23) produces a measurement of
 CDD/CDFs in units of mass concentration (i.e.,  nanograms per dry standard cubic meter of  "
 combustion gas (ng/dscm)) at standard temperature and pressure and one atmosphere and
 adjusted to a measurement of 7 percent oxygen in the flue gas (U.S. EPA, 1995b).  This
 concentration is assumed to represent conditions at the point of release from the stack into
the air, and to be  representative of routine emissions.  The emission factors were derived
by averaging the emission factors across each tested facility in a design class. The emission
factor for each tested MWIs was calculated using the following equation:
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                                        C  x  Fv
                             EFmwi  =  	J	                           (Eqri. 3-8)
                                            W                 .     '
        Where:
         EFmwi     -    Emission Factor per MWI (average ng TEQ per kg of medical
                         waste burned).
             C     =    Average TEQ  concentration in flue gases of tested MWIs (ng
                         TEQ/dscm) (20°C, 1 atm; adjusted to 7% O2).
            Fv     =    Average volumetric flue gas flow rate (dscm/hr) (20°C, 1 atm;
                         adjusted to 7% O2).
            lw     =    Average medical waste incineration rate of the tested MWI
                         (kg/hr).   '
 The emission faqtor estimate for each design class and the nurriber of stack tests used to
 derive it are shown in Table 3-14. Figures 3-12 and 3-13 present congener and congener
 group profiles for air emissions from MWIs lacking APCDs and for MWIs equipped with a
 wet scrubber/baghouse/fabric filter APCD system, respectively.  -

 3.3.7. Summary of CDD/CDF Emissions From MWIs
       Because the stack emissions from so few facilities have been tested (i.e., 19 test
 reports) relative to the number of facilities in this industry (i.e., 2,375 facilities in 1995 and
 5,000 facilities in 1987) and because several tested facilities are no longer in operation or
 have installed new APCD after testing, the EPA/ORD approach did not calculate nationwide
                 	<           , i    •.....•        .   ,      .    -
 CDD/CDF emissions by calculating emissions from the  tested facilities and adding those to
 calculated emissions for the non-tested facilities.  Rather, the EPA/ORD approach (as well
 as the EPA/OAQPS  and AHA approaches) calculated nationwide CDD/CDF emissions by
 multiplying the emission factor and activity level developed for each design class and then
 summing the calculated emissions for all classes.  Tables 3-14 and 3-15 summarize the
 resulting national TEQ air emissions for the reference years 1995 and 1987, respectively.
 In addition, the Tables indicate the activity level and the TEQ emission  factor used in
 estimating annual TEQ emissions!
       In estimating annual TEQ emissions in both reference years, a "low" confidence
 rating was assigned to the estimate of the activity level.  The primary reason for the low
 confidence rating is  that very limited information is available on a facility level basis for
characterizing  MWIs in terms of the frequency and duration of operation, the actual waste
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 volume handled, and the level of pollution control.  The 1987 inventory of facilities was
 based on very limited information.  Although the 1995 EPA/OAQPS inventory was more
 comprehensive than the 1987 inventory,  it was still based on a fairly limited survey of
 operating facilities (i.e., approximately 6 percent).
       The emission factor estimates were given a "low" confidence rating, because only
 the reports of 1.9 tested MWI facilities could be used to derive emissions factors
 representing the 2,375  facilities operating in 1995 (i.e., less than 1 percent of estimated
 number of operating facilities).  Even fewer tested facilities could be used to represent the
 larger number of facilities operating in  1987 (i.e., 8 tested facilities were used to represent
 5,000 facilities).  The limited emission tests available do cover all design categories used
 here to develop emission factors.  However, because of the large number of facilities in
 each of these classes, it is very uncertain whether the few tested facilities in each class
 capture the true variability in emissions.                       .

 •     Reference Year 1995: Based on the low confidence ratings  for both the activity
       level and  the emission factor, the estimated range of potential annual TEQ emissions
       from MWIs in 1995 is assumed to  vary by a factor of 10 (between the low and high
       ends of the range).  From Table 3-14, the central estimate of TEQ emissions in 1995
       is estimated to be 477 g/yr, with a range of 1 51 to 1,510 g  TEQ/yr.

 •     Reference Year. 1987: Based on the low confidence ratings for both the activity level
       and the emission factor, the estimated range of potential annual TEQ emissions from
       MWIs in 1987 is  assumed to vary by  a factor of 10 (between the low and high ends
      of the range). From Table 3-15, the central estimate of TEQ emissions in 19S7 is
      estimated to  be 2;470 g/yr,  with a range of 781 - to ,7,810-g TEQ/yr.

      As explained  above, the EPA/ORD approach to estimating national CDD/CDF TEQ
emissions is a 'hybridization' of the EPA/OAQPS and AHA approaches. Table 3-16
compares the main features of each of the three approaches. The 1995 TEQ emissions
estimated here (477-g TEQ/yr) are about 3.5 times higher than  those of QAQPS and AHA
(141- and 138-g TEQ/y,  respectively).  Most of this difference is due to differences in the
                            • , '                       '             '
emission estimates for the uncontrolled facilities (ORD% - 436-g TEQ/yr, OAQPS - 136-g
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                           DRAFT-DO NOT QUOTE OR CITE
  TEQ/yr, AHA - 120-g TEQ/yr). An analysis of the differences in how these groups
  estimated emissions from the uncontrolled facilities are presented below:

  •     Differences between the EPA/ORD and AHA Approaches: The ORD approach
        adopted the classification scheme of the AHA approach for the uncontrolled class
        and assumed  similar activity levels.  Thus, the difference in emission estimates is
        primarily due to  differences in the emission factors used. Both groups use similar
        emission factors for facilities with design capacities less than or equal to 200 Ibs/h,
        but the emission factor for MWIs > 200 Ibs/hr used in the EPA/ORD approach was
        higher than that used in the AHA approach by a factor of three. This results from
        the fact that the two approaches used different sets of emission tests to derive their
        emission factors.

 •      Differences between the EPA/ORD and EPA/OAQPS Approaches: Because the two
        approaches subcategorized the uncontrolled facilities into different classes, the
        activity levels  and emission factors cannot be directly compared.  Considering the
        class as a whole, however, both approaches used essentially identical activity levels.
        The EPA/OAQPS approach assigned 68  percent of the total activity to the class with
        the lowest emission factor (i.e., those with >2-sec residence time).  The emission
        factor for this  class, 74-ng TEQ/kg, is considerably lower than either emission factor
                  a'1           '   '  i    .    •     '             '
        used in the EPA/ORD approach (1,700- and 1,860-ng TEQ/kg).
                  11            ,     „ • '"     ;      -   , ( "      •     \   i
       Given the uncertain data base available for making these estimates,  it is difficult to
 know which of these  three estimation approaches yields the most accurate annual TEQ
 estimate. However, despite  the differences in methodologies and assumptions used, the
 three approaches yield annual TEQ estimates that are not fundamentally different; the
 estimates differ from each other by a factor of four or less.  Because the EPA/ORD
 approach was the last of the three to be developed, it has the benefit of being able to
 utilize the most logical and supportable features of the previously developed EPA/OAQPS
 and AHA approaches.
        Regardless of the approach taken to estimate what the CDD/CDF emissions from
2,375 MWIs were in 1995, the National Emission Standards promulgated by EPA in
September 1997 (Federal Register, 1997b) require substantial reductions of CDD/CDF air

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                          DRAFTS-DO NOT QUOTE OR CITE
  emissions from MWIs.  As a result of these standards, MWI emissions will be thoroughly
  assessed for purposes of compliance with the CDD/CDF standard.  Compliance testing will
  allow the development of a more comprehensive emissions data base and more accurate
  characterization of this industry.

  3.4.   CREMATORIA
        Bremmer et al'. (1994) categorized crematoria into two basic operating types: a
  "cold" type and a "warm" type.  In the "cold" type furnaces, the coffin is placed inside at a
 temperature of about 300°C.  Using a burner, the temperature of the chamber is increased
 to 800-900°C and kept at that temperature for 2 to 2.5 hours.  In the  "warm" type
 furnace, the coffin is placed in a chamber preheated to 800°C or higher for 1.2 to 1.5
 hours. The chamber exhausts from both furnace types are incinerated in an after burner at
 a temperature of about  850°C. Flue gases are then discharged to the atmosphere either:
 (a) directly without cooling;  (b) after mixing with ambient air using an air blast to a
 temperature of about 20Q-350°C; or (c) after mixing with ambient air as in "b," followed by
 further cooling to about 150°C in an air cooler and passage through a fabric filter.
        Bremmer et al. (1994) measured CDD/CDF emissions at two crematoria in The
 Netherlands. The first, a cold-type furnace with direct uncooled emissions/was calculated
 to yield 2.4-^g TEQ per body.  The second furnace, a warm type with cooling of flue gases
 to 220°C prior to discharge, was calculated to yield 4.9-//g TEQ per body. The higher-
 emission rate for the warm-type furnace was attributed by Bremmer et al. (1994) to the
 formation of CDD/CDF during the intentional cooling of the flue gases to 220°C.
       Jager et al. (1992) (as reported in Bremmer et al., 1994)  measured an emission rate
 of 28-^9 TEQ per body for a crematorium in Berlin, Germany. No operating process
 information was provided by Bremmer et al. (1994) for the facility.
       In the United States, CDD/CDF emissions were measured at one crematorium
 (GARB, 1990c)  classified as a warm-type facility using the criteria of Bremmer et al.
 (1994). The combusted material at this facility was comprised of the body, as well as 4
 pounds of cardboard, up to 6 pounds of wood, and ,an unquantified amount of unspecified
 plastic wrapping. The three emission tests conducted at this facility yielded an average
 emission factor, of 0.5-^g TEQ/body. Although this emission  factor is very similar to the
 emission factors reported by Bremmer et ai. (1994), a "low" confidence rating is assigned
to the factor, because it represents testing at only one U.S. facility. Table 3-17 presents
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                           DRAFT-DO NOT QUOTE OR CITE
  the congener-specific emission factors for this facility. Figure 3-14 presents CDD/CDF
  congener and congener group emission profiles based on these emission factors.
        In 1995, 1,155 crematories were reported in the United States (Springer, 1997).
  However, there are no readily available data on the number of "cold" versus "warm"
  crematoria furnaces.  In 1995, 21.1 percent of the deceased bodies were cremated (i.e.,
  488,224 cremations), and 15.2 percent of the deceased were cremated in 1987 (i.e.,
  323,371 cremations)  (Springer, 1997).  Cremations are projected to increase to 25 percent
  in the year 2000 and 37 percent in the year 2010 (Springer,  1997).  A high confidence
  rating is assigned to these activity level estimates, because they are based on recent  data
  provided by the Crematoria Association of North America.
        Combining the  emission rate of 0.5-yug TEQ/body with the number of cremations in
  1995 (488,224) yields an estimated annual release of 0,24-g TEQ per year.  Based on the
  low confidence rating  assigned to the emission factor of 0.5-^g TEQ/body, the estimated
  range of potential emissions is assumed to vary by a factor of 10 between the low and high
  ends of the range.  Assuming that the best estimate of annual emissions (0.24-g TEQ/yr) is
 the geometric mean of this range, then the range is calculated to be 0.07- to 0.75-g
 TEQ/yr. Combining the emission  rate of 0.5-^g  TEQ/body with the number of cremations in
 1987 (323,371) yields an estimated release of 0.16-g  (range  0.05- to 0.51-g TEQ/yr).

 3.5.  SEWAGE SLUDGE INCINERATION
                            ;' ''     i " '         ' • , •   ,       ,-.,,„'     •    '    .        ,
       The three principal combustion technologies used to incinerate sewage sludge in the
 United States are the multiple-hearth incinerator, fluidized-bed incinerator, and the  electric
 furnace (Brunner, 1992; U.S. EPA, 1995b). All of these technologies are "excess-air"
 processes (i.e., they "combust sewage sludge with oxygen in excess of theoretical
 requirements).  Over 80 percent of operating sludge incinerators are multiple-hearth design.
 About 15 percent are fluidized-bed incinerators, and 3 percent are electric incinerators.
 Other types of technologies not widely used in the United States are single-hearth
 cyclones,  rotary kilns, and high-pressure wet-air  oxidation (U.S. EPA, 1997b).
       Multiple-hearth Incinerator: This consists of refractory  hearths arranged vertically in
 series, one on top of the other.  Dried sludge cake is fed to the top hearth of the furnace.
 The sludge is mechanically moved from one hearth to another  through the length of the
furnace.  Moisture is evaporated from the sludge cake in the upper hearths  of the furnace.
The center hearths are the burning zone, where gas temperatures reach 871 °C. The
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  bottom hearths are the burn-out zone, where the sludge solids become ash. A waste-heat
  boiler is usually included in the burning zone, where steam is produced to provide
  supplemental energy at the sewage treatment plant.  Air pollution control measures
  typically include a venturi scrubber, an impingement tray scrubber, or a combination of
  both. Wet cyclones and dry cyclones are also used (U.S. EPA, 1995b).
                             "  '             •
        Fluidized-bed Incinerator: This is a cylindrical refractory-lined shell with a steel plate
  structure that supports a sand bed near the bottom of the furnace (Brunner, 1992). Air is
  introduced through openings in the bed plate supporting the sand. This causes the sand
  bed to undulate in a turbulent air flow; hence, the sand appears to have a .fluid motion
 when observed through furnace portals.  Sludge cake is added to the furnace at a position
 just above this fluid motion of the sand bed. The fluid motion promotes mixing in the
 combustion zone. Sludge ash exits the furnace with the combustion gases; therefore, air
 pollution control systems typically consist of high-energy venturi scrubbers.  Air pollution
 control measures typically include a venturi scrubber or venturi/impingement tray
 combinations (U.S. EPA, 1995b).
       Electric  Furnaces: Also called infrared furnaces, these consist of a long rectangular
 refractory-lined chamber.  A belt conveyer system moves the sludge  cake through the
 length of the furnace.  To promote combustion of the sludge, supplemental heat is added
 by electric infrared heating elements within the furnace that are located just above the
 traveling belt. Electric power is required to initiate and sustain combustion.  Emissions are
 usually controlled with a venturi scrubber or some other wet scrubber (Brunner, 1992;  U.S.
 EPA, 1995b).
       EPA measured CDD/CDF emissions at two multiple-hearth incinerators and one
 fluidized-bed incinerator as part of Tier 4 of the National Dioxin Survey (U.S. EPA, 1987a).
 The results of these tests include congener group concentrations in stack  gas, but lack
 measurement results for specific congeners other than  2,3,7,8-TCDD and  2,3,7,8-TCDF.  In
 1 995, the Association of Metropolitan Sewerage Agencies (AMSA) submitted to EPA the
 results of stack tests conducted at an additional 15 sewage sludge incinerators (Green  et
 alv, 1995).  Two of these data sets were considered not useable by EPA, because either
detection limits or feed rates and stack flow were not provided. The  average congener and
congener group emission factors are presented in Table 3-18 for the three facilities from
U.S. EPA (1987a) and the 13  AMSA facilities from .Green ef al. (1995). A wide variability
was observed in the emission  factors for the tested  facilities.  The total CDD/CDF emission
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  factor for the three U.S. EPA (1987a) facilities ranged from 90 to 3,400 ng/kg. For the 13
  facilities reported in Green et al. (1995), a similarly large variability in emission factors was
  observed.  Figure 3-15 presents the average congener and congener group profiles based
  on these data.
        The average TEQ emission factor based on the data for the 13 AMSA facilities is
  6,94-ng TEQ/kg of dry sludge combusted, assuming nondetected values are 0 and 7.19-ng
  TEQ/kg of dry sludge, assuming nondetected values are present at one-half the detection
  limit. Other countries have reported similar results. Bremmer et al. (1994) reported an
  emission rate of 5-ng TEQ/kg for a fluidized-bed sewage sludge incinerator, equipped with a
  cyclone and wet scrubber, in The Netherlands. Cains and Dyke (1994) measured  CDD/CDF
  emissions at two sewage sludge incinerators in the United  Kingdom.  The emission rate at
  an incinerator equipped with an electrostatic precipitator and wet scrubber ranged from
  2.75-ng TEQ/kg to 28.0-ng TEQ/kg. The emission  rate measured at a facility equipped
 with only an electrostatic precipitator was 43.0-ng  TEQ/kg.
        In 1992, approximately 199  sewage sludge  incineration facilities  combusted about
 0.865-million metric tons of dry sewage sludge (Federal Register, 1993b). No comparable
 data  are available for the 1987 and  1995 reference time periods.  For purposes of  this
 report, it is assumed that 0.865-million metric tons  of dry sewage sludge were incinerated
 during the two time periods.  Given  this mass of sewage sludge incinerated/yr, the estimate
 of TEQ emissions to air is 6.0-g TEQ per year, using the average AMSA TEQ emission
 factor of 6.94-ng TEQ/kg.
          in                    .   "  «   ;       -	   ,        ' „        „    ,  ,
       A "medium" confidence rating is assigned to the average TEQ emission factor for
 the AMSA facilities (6.94-ng TEQ/kg), because it was derived from stack testing at 13
 sewage sludge incinerators.  The activity level estimate is assigned a  "high" confidence
 rating, because it is based on an extensive EPA survey to support rulemaking activities.
 Based on these confidence ratings, the estimated range of potential annual emissions is
 assumed to vary by a factor of five between the low and high ends of the range. Assuming
 that the estimate of annual emissions (6.0-g TEQ/yr) is the geometric mean of this  range,
 then the range is calculated to be 2.7- to 13.4-g TEQ/yr.
3.6.  TIRE COMBUSTION
      Emissions of dioxin-like compounds from the incineration of automobile tires were
measured from a tire incinerator stack tested by the State of California Air Resources Board

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                           DRAFT-DO NOT QUOTE OR CITE
  (CARB, 1991 a). The facility consists of two excess air furnaces equipped with steam
  boilers to recovery the energy from the heat of combustion.  Discarded whole tires were
  fed to the incineration units at rates ranging from 2,800 to 5,700 kg/hr during the 3 test
  days. The furnaces are equipped to burn natural gas as auxiliary fuel.  The steam produced
  from the boilers is used to drive electrical turbine generators that produce 14.4 megawatts
  of electricity. The facility is equipped with a dry acid gas scrubber and fabric filter for the
  control of emissions prior to exiting the stack.
        Emission factors for CDD/CDF and TEQ in units of ng/kg of tires combusted were
  derived ,as average values from the one facility stack tested in California (CARB, 1991 a)'.
  Table 3-19 presents the congener-specific emission factors for this facility.  Figure 3-16
  presents CDD/CDF congener and congener group profiles based on these emission factors.
  From these data, the average emission factor is estimated to be 0.282-ng TEQ/kg of tires
  incinerated when all not detected values are treated as zero.  Cains and Dyke (1994)
  reported much  higher emission rates for two tire incinerators equipped  only with simple grit
  arresters in the United Kingdom, 188- and 228-ng TEQ/kg of combusted tire.
        EPA estimated that approximately 0.50 million metric tons of tires were incinerated
  in 1990 in the United States (U.S.  EPA, 1992a). This activity level estimate is given a
  "medium" confidence rating, because it is based on both published data and professional
 judgement.  The use of scrap tires'as a fuel was reported to have increased significgntly
 during the late 1980s;  however, no quantitative estimates were provided in U.S. EPA
 (1992a) for this period. In 1990, 10.7  percent of the 242-million scrap tires generated
 were burned for fuel.  This percentage is expected to continue to  increase (U.S. EPA,
 1992a).  Of the tires burned for energy recovery purposes, approximately 46 percent were
 utilized by pulp  and paper facilities, 23 percent were utilized by cement kilns, and 19
 percent were utilized by one tire-to-energy facility (U.S. EPA,  1995c).
       If it is assumed that 500-million kilograms of discarded tires are  incinerated annually
 in the United States, then, using  the emission factors derived from staqk data from the one
 tested facility, an average of 0.14 grams of TEQ per year are estimated to be emitted to
,, the air.  It must be noted that these may be underestimates of emissions from this source
 category, because the one facility tested in California is equipped with a dry scrubber
 combined with a fabric filter for air  pollution control. These devices are capable of greater
 than 95  percent reduction and control of dioxin-like compounds prior to discharge from the
 stack. It is  hot know to what extent other tire incineration facilities operating in the U.S.
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                          DRAFT-DO NOT QUOTE OR CITE
  are similarly controlled.  If such facilities are not so equipped, then the uncontrolled
  emission of CDD/CDF and TEQ could be much greater than the estimates developed above.
                                      1 ,' ' '   •   ' '"    ' ',   .  '    ' H'      '
  Therefore, the estimated emission factor of dioxin from tire incineration is given a "low"
  confidence rating.  Based on these confidence ratings, the estimated range of potential
  annual emissions is assumed to vary by a factor of 10 between the low and.high, ends of
  the range.  Assuming that the best estimate of annual emissions (0.14-g TEQ/yr) is the
  geometric mean of this range, then the range is calculated to be 0.04- to  0.45-g TEQ/yr.

 3.7.   COMBUSTION OF WASTEWATER SLUDGE AT BLEACHED CHEMICAL PULP MILLS
        Approximately 20.5 percent of the wastewater sludges generated  at bleached
 chemical pulp mills are dewatered and burned in the facilities' bark burners.  These sludges
 can contain CDD/CDFs and fairly significant levels of chloride.  However, the level of heat
 input from sludge in the mixed feed rarely exceeds 10 percent in most bark boilers (NCASI,
 1995).
        NCASI (1995)  provided congener-specific test  results for four wood residue/sludge
 boilers tested between 1987 to 1993.  The congener-specific emission factors derived from
 the stack test results obtained frpm one of these facilities (a spreader stoker equipped with
 an ESP) are presented in Table 3-20.  During testing, the  sludge feed rate  averaged 3,,2
 tons per hour, and the feed rate for wood residue averaged 30.3 tons per  hour. The
 average TEQ emission factors derived from the test results are O.OQ1 ng/kg of feed (i,,e.,
 sludge and wood residue), assuming nondetected values are 0 and 0.005 ng/kg of feed,
 assuming nondetected values are present at one-half the detection limit. The average  TEQ
 concentration in the stack gas reported for this facility by NCASI (1995) was 1.4E-04
 ng/dscsm (at 12 percent CO2). The results of testing  of stack emissions at the other three
 boilers burning sludge, wood residue, and coal were reported by NCASI (1995) to have
 significantly higher (i.e., factors of 41 to 207 times greater) average TEQ concentrations in
 the stack gases. However, reliable emission factors for these facilities could not be
 derived, because stack gas flow rates and sludge feed rates were not available.
       NCASI (1995) also presented stack emission test results for five other bark boilers,
at least one of which normally fires bark in combination with sludge and coal.  Although
stack gas flow rates were obtained during these tests, accurate measurements of the
amounts of bark/wood fired were not measured and thus had to be estimated by NCASI
(1995). The average congener and congener group emission factors derived from the test
                                       3-42
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              '  ;   .  '•     DRAFT-DO NOT QUOTE OR CITE
  results at these facilities are also presented in Table 3-20. Figure 3-17 presents the
  congener and congener group profiles based on these data. The average TEQ emission
  factor for these facilities is 0.4 ng/kg of feed or 80 to 400 times greater than the emission
  factor derived for the sole facility burning sludge and wood for which complete  test results
  and operating parameters are available.  This average TEQ emission factor is very similar to
  the average emission factor for industrial wood combustion derived in Section 4.2.2 of this
  report from testing by the  California Air Resources Board of four industrial wood
  combustors (0.82 ng/kg of feed).                     /
        The available emissions test results for combustion of bleached Kraft mill
  wastewater sludge are  not adequate to enable derivation of CDD/CDF emission factors
  specific to these bark/sludge combustors. However, the emissions test data presented in
  NCASI (1995), and discussed above, indicate that the CDD/CDF emission factors for
  bark/sludge combustors are similar to the emission factor developed in Section 4.2.2 for
  industrial facilities burning only wood residues/scrap.  Thus, based on this conclusion about
 the applicability of the industrial wood combustor emission factor, and the fact that wood
 residues comprise a far  greater fraction of the feed to these burners than does sludge, the
 national TEQ emission estimates derived in Seption 4.2.2 of this report for industrial wood
 burning facilities are assumed to include emissions from these bark/sludge combustion
 units.
 3.8.   BIOGAS COMBUSTION                        ,
       Schreiner et al. (1992) measured the CDD/CDF content of a flare combusting
 exhaust gases from an anaerobic sewage sludge digester in Germany: The CDD/CDF
 content at the bottom of the flare was 1.4-pg TEQ/Nm3, 3.3. pg TEQ/Nm3 at the top of the
 flare, and 13.1 pg TEQ/Nm3 in the middle of the flare. Congener-specific results were not
 reported.  Using the theoretical ratio of flare gas volume to digester gas volume combusted,
 78.6:1, and the average CDD/CDF content  of the three measurements, 5.9-pg TEQ/Nm3,
 an emission rate of 0.46-ng TEQ/Nm3 of digester gas combusted is yielded.
       During 1996, POTWs in the United States treated approximately 122-billion liters of
 wastewater daily (U.S. EPA, 1997c).  Although reliable data are not readily available,on the
amount of sewage sludge generated by POTWs that is subjected to stabilization by
anaerobic digestion, a reasonable approximation is 25 percent of the total sludge generated
(i.e., the sludge generated from treatment'of about^O-trillion liters per day of wastewater).
                                       3~43                      .          April 1998

-------
                           DRAFT-DO NOT QUOTE OR CITE
 An estimated 196 kg of sludge solids are generated for every million liters of wastewater
 subjected to primary and secondary treatment (Water Pollution Control Federation, 1990).
 Thus, multiplying 30-billion liters per day (i.e., 25 percent of  122-billion liters) by 196
 kg/million liters and 365 days/yr yields an annual estimate of 2-million metric tons of sludge
 solids that may be anaerobically digested  in POTWs annually.
        The volume of sludge digestor gas combusted in flares annually can be estimated
 using operation parameters for a "typical" anaerobic digestor system as described in Water
 Pollution Control Federation (1990).  Multiplying the annual amount of sludge solids of 2-
 million metric tons by the following parameters and appropriate conversion factors yields an
 annual flared digestor gas volume of 467-million Nm3:
                                                          'ii  ; • , "            ' .
        •      Fraction of total solids that are volatile solids = 75 percent;
        •      Reduction of volatile solids during digestion = 50 percent;
        •      Specific gas production = 0.94 m3/kg volatile solids reduced; and
        •      Fraction of produced gas that is flared = 66 percent.

       Because there are no direct measurements of CDD/CDF emissions from U.S.
 anerobic sludge digestor flares and because of uncertainties about the activity level for
 biogas combustion, no national emission estimate has been developed for inclusion in the
 national inventory. However, a preliminary order of magnitude estimate of the potential
 annual TEQ emissions from this source can be obtained by multiplying the emission factor
 of 0.46-ng TEQ/Nm3 of digestor gas flared by the estimated volume of gas flared annually
 in the United States, 467-million Nm3. This calculation yields an annual potential release of
 0.22 grams, which, when rounded to the nearest order of magnitude to emphasize the
 uncertainty in this estimate, results in a value of 0.1-g TEQ/yr. This estimate should be
 regarded as a preliminary indication of possible emissions from this  source category; further
                             '•.'.'.••   	    .         -         •  •
testing is needed to confirm the true magnitude of these emissions.
                                        3-44
                                                                             April 1998

-------
               DRAFT-DO NOT QUOTE OR CITE
Figure 3-1.  Typical Mass Burn Waterwall Municipal Solid Waste Incinerator




              Source: U.S. EPA (1997b)
                          3^45
                                                            April 1998

-------
        DRAFT-DO NOT QUOTE OR CITE
Figure 3-2.  Typical Mass Burn Rotary Kiln Combustor
                * i  ,,...'   •«,    ,/ • •
            Source: U.S: EPA (199?b)
                     3-46
                                                        April 1998

-------
       DRAFT-DO NOT QUOTE OR CITE
Figure 3-3. Typical Modular Excess-Air Combustor
            Source: U.S. EPA (1997b)
                   3-47
                                                   ApriU-998

-------
                     DRAFT-DO NOT QUOTE OR CITE
                                 ToStackcr
                                Waste Ha BAr
                Riray
             fed
             Qute
///////////// J
                                                   Secondary
                                                              Ssxndary
                                                              Charter
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                                                 o  o  o
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                                                 o  o  o
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    Figure 3-4.  Typical Modular Starved-Air Combustor with Transfer Rams
                 Source: U.S. EPA (1997b)
                                    3-48
                                                                             April 1998

-------
           DRAFT-DO NOT QUOTE OR CITE
      apaheeter
                                                             Safe
Figure 3-5.  Typical Dedicated RDF-Fired Spreader Stoker Boiler
                Source: U.S. EPA (1997b)
                        3-49
                                                          April 1998

-------
                 DRAFT-DO NOT QUOTE OR CITE
 Thermocouple
  Sludge
     Inlet
Fluidlzing
 Air Inlet
                                                 Exhaust and Ash
                                                      Pressure Tap
                                                       Sight
                                                       Glass
                                                          Burner
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m



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•— 	 S
1
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Pressure Tap
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  Preheat
  Burner
  for Hot
  Windbox
             Figure 3-6. Fluidized-Bed RDF Incinerator
                     Source: U.S. EPA (1997b)
                               3-50
                                                                     April 1998

-------
                            DRAFT-DO NOT QUOTE OR CITE
Watemall
-

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DS/FF

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-


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                                         Muncipal Solid Waste
                                          Incinerator Design
                                           Classes for 1987
I — •- 	 • 	 — 	 L- 	 , 	 : 	 	 	
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- \
Refute-Derived Fuel
i
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Key:    DS/FF = Dry Scrubber combined with a Fabric Filter
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       WS = Wet Scrubber
       UNO = Uncontrolled (no APCD)
       EGB = Electro Granular Activated Carbon Bed
       FF = Fabric Filter
                        Figure 3-7.  MSWI Design Classes for 1987
                                           3-51
                                                                                  April 1998

-------
                              DRAFT-DO NOT QUOTE OR CITE
                                           Muncipal Solid Waste
                                           Incinerator Design
                                            Classes for 1995


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        H-ESP - Hot-side Electrostatic Precipitator (Temperature at control device is
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        UNC  = Uncontrolled (no APCD)
        EGB = Electro Granular Activated Carbon Bed
                          Figure 3-8.  MSWI Design Classes for 1995
                                              3-52
                                                                                        April 1998

-------
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-------
                             DRAFT-DO NOT QUOTE OR CITE
              Table 3-4   Annual TEQ Emissions (g/yr) From MSWIs Operating in 1995
Municipal Solid Waste
Incinerator Design








Mass Burn Rotary Kiln

RDF Dedicated


!



'


Fluidized-bed RDF


Air Pollution
Control
Device
C-ESP
DS/C-ESP
DS/CI/FF
DS/FF
DSI/CI/H-ESP
DSI/FF ,
DSI/H-ESP
H-ESP

C-ESP
DS/C-ESP
DS/FF
DSI/FF
ws

C-ESP
DS/FF
DSI/C-ESP
DSI/FF

C-ESP
DS/C-ESP
DS/FF
DSI/FF
DSI/H-ESP
H-ESP
DS/FF/C-ESP

C-ESP
DSI/FF
H-ESP
UNC
WS
WS/FF
DS/DSI/C-
ESP

C-ESP
DS/FF
0SI/FF
DSI/H-ESP
H-ESP
UNC
WS/C-ESP

DS/FF
DSl/EGB
DSI/FF


Emissions
From Tested
Facilities
(gTEQ/yr)
0
2.09
0.635
2.01
2.12
0.279
0
163
170
39.8
21.6
0
0
- 0
61.4
0
0.245
0
5.29
5.54
32.5
0.321
0.0975
0
0
0
0
33
0
,0.000801
8.01
0
0
0
0
8.01
0.0643
0
0
0
2.32
0
0
2.39
0
0
0
0
280
Average TEQ
Emission
Factor
(ng/kg)
6.1
6.1
1.5
0.63
7.74
473

.-
0.63
1.91
236

47
0.646
47
47

231
0.527
0.24
231
231
1490
0.24

16
79
0.0247
16
16
16

16
. 16
0.0247
118
0.0247
16

0.63
0.63
0.63


.Activity Level
s* Non-Tested
Facilities
(kg/yr)
2.81e+09
1.88e + 09
7.44e + 08
5.98e + 09
o
0
4.22e + 08
1.79e + 08

0
0
2.68e + 08
1.136 + 08
2.04e + 08

2.00e+08
7.57e + 08
5.07e + 08
1.46e + 08

1.67e+09
1.14e + 09
1.58e + 09
4.22e + 08
2.00e + 08
4.22e+07
5.63e+08

1.25e + 08
0
8.03e + 07
1.87e + 08
4.90e+07
2.82e + 07
7.60e + 07

6.25e + 07
1.18e + 08
1.01e4-08
1.41e + 07
0
1.41e + 07
6.76e+07

1.69e + 08
1.13e + 08
8.45e + 07


Emissions From
Non-Tested
Facilities
(g TEQ/yr)
17.1
11.4
1.12
3.77
0
3.27
84.5
121
0
0
J 0.168
0.216
48.1
48.5
9.4
0.489
23.8
6.85
40.6
385
0.603
0.379
97.6
46.2
63
0.135
593
2
0
6.34
0.00463
0.785
0.451
1.22
10.8
1
1.9
0.00251
1.66
0,
0.000348
, 1 .08
5.64
0.106
0.0709
0.0532
0.231

Total
Emissions
From All
Facilities
(g TEQ/yr)
17.1
13.5
1 75
5.77
0.279
3.27
247
291
39.8
21 6
0.168
0.21 6
48.1
110
9.4
0.734
23.8
12.1
46.1
418
0.924
0.477
97.6
46.2
63
0.135
626
.0.000801
14.4
0.00463
0.785
0.451
1.22
18.8
1 07
1 9
0.00251
1.66
2 32
0.000348
1.08
8.03
0.106
0.0709
0.0532
0.231

Key:   DS/FF = Dry Scrubber combined with a Fabric Filter
       DSI/FF = Dry Sorbent Injection coupled with a Fabric Filter      " .
       DS/CI/FF = Dry Scrubber -Carbon Injection-Fabric Filter
       C-ESP = Cold-side Electrostatic Precipitator (Temperature at control device is below =;2300C)
       H-ESP = Hot-side Electrostatic Precipitator (Temperature at control device is >230°C)
       WS = Wet Scrubber
       UNC = Uncontrolled (no APCD)
       EGB = Electro Granular Activated Carbon Bed
       ng/kg = nanogram per kilogram
       kg/yr = kilograms per year    ,                                                  '
                                             3-59
                                                                                     April 1998

-------
                              DRAFT-DO NOT QUOTE OR CITE

             Table 3-5. Annual TEQ Emissions to the Air From MSWIs Operating in 1987
Incinerator Design
Mass Burn Waterwall
Mass Burn Refractory
Mass Burn Rotary Kiln
RDF Dedicated
RDF Cofired
Modular Starved-air




Pollution
Control
Device
DS/FF
H-ESP
Subtotal
DS/FF
H-ESP
WS
Subtotal
FF
H-ESP
Subtotal
H-ESP
WS
Subtotal
H-ESP
FF
H-ESP
UNC
WS
Subtotal
EGB
UNC
WS
Subtotal

Emissions
From Tested
Facilities
(g TEQ/yr)
0.0373
433
433
0
0
0
0
0
48.2
48.2
840
0
840
0
0
0.0643
0
0
0.0643
0
0
0
0

Average TEQ
Emission
Factor
(ng/kg)
473

0.63
473
236

47
285

1490
231

231
16
79
0.0247
16

0.0247
0.0247
16


Activity Level
Non-Tested
Facilities
(kg/yr)
0
3.27e + 09

1.41e + 08
2.00e + 09
9.01e + 08

1.58e+07
2.25e + 08

2.45e + 09
3.38e + 08

2.53e + 08
1.43e + 08
3.61e + 08
5.73e+08
5.30e + 07

6.76e + 07
4.17e + 07
1.27e + 08


Emissions From
Non-Tested
Facilities
(g TEQ/yr)
0
1550
1550
0.0887
944
212
1,160
0.741
64.2
65
. 3660
78.1
3730
58.6
2.29
28.5
0.0142
0.848
31.6
0.00167
0.00103
2.03
2.03

Total Emissions
From All
Facilities
(g TEQ/yr)
0.0373
1980
1980
0.0887
944
212
1,160
0.741
112
113
4500
78.1
4570
58.6
2.29
28.5
0.0142
0.848
31.7
0.001 67
0.00103
2.03
2.03

Key:    DS/FF = Dry Scrubber combined with a Fabric Filter'
        DSI/FF - Dry Sorbent Injection coupled with a Fabric Filter
        DS/CI/FF = Dry Scrubber -Carbon Injection-Fabric Filter
        C-ESP = Cold-side Electrostatic Prepipitator (Temperature at control device is below d230°C)
        H-ESP = Hot-side Electrostatic Precipitator (Temperature at control device is *230°C)
        WS - Wet Scrubber
        UNC  = Uncontrolled (no APCD)
        EGB *= Electro Granular Activated Carbon Bed
        ng/kg = nanogram per kilogram
        kg/yr  ~ kilograms per year        '
                                              3-60
                                                                                        April 1998

-------
                              DRAFT-DO NOT QUOTE OR CITE
                                    0.02
                                        (congener emission factor / total CDD/CDF emission factor)
                                                0.04
            2,3.7.8-TCDD
         1.2.3.7,8-PeCDD
       1.2.3.4,7.8-HxCDD
       1.2,3.6.7,8-HxCDD
       1.2.3.7.8,9-HxCDD
     1,2,3,4:6,7,8-HpCDD
     1,2,3,4,6,7.8,9-OCDD
            2.3.7.8-TCDF
         1.2,3,7.8-PeCDF
         2.3.4.7.8-PeCDF
       1.2.3.4.7,8-HxCDF
       1.2.3.6.7,8-HxCDF
       1.2.3,7.8.9-HxCDF
       2.3.4.6.7,8-HxCDF
     1.2.3.4,6.7.8-HpCDF
     1.2.3.4.7.8,9-HpCDF
     1.2.3,4.6.7.8.9-OCDF
                                                                                                  0.12
                       Ratio (congener group emission factor / total CDD/CDF emission factor)
                        °-05               0.1               0.15
Figure 3-9.  Congener and Congener Group Profiles for Air Emissions from a Mass-Burn
            Waterwall MSWI, Equipped with a  Dry Scrubber and Fabric Filter
                                              3-61
                                                                                          April 1998

-------
                             DRAFT-DO NOT QUOTE OR CITE
             Table 3-6. CDD/CDF Emission Factors for Hazardous Waste Incinerators and Boilers
I Congener/Congener Group





	
|| 2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1 1,2,3.4,7,8-HxCDD
1 1,2,3,6,7.8-HxCDD
1,2,3,7,8,9-HxCDD
| 1,2,3,4,6,7,8-HpCDD
I OCDD
I 2,3,7,8-TCDF
I 1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2.3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF '
I Total TEQ (nondetects = 0)
Total TEQ (nondetects =1/2 DL)
I Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF {nondetects = 0)
Total CDD/CDF (nondetects = 1/2 DL)
Incinerator Average
Mean emission factor
(17 facilities)
ing/kg feed)
Nondetects
Set to 1/2
Det. Limit
0.44
0.18
0.22
0.32
0.49
1.77
4.13
2.96
2.36
2.56
9.71
3.96
0.31
2.70
16.87
1.74
13.78
4 22









137.36
=• 	 L
Nondetects
Set to
Zero
0.14
0.14
0.18
0.28
0.48
1.75
3.74
2.69
2.33
2.51 .
9.71
3.95
0.29
2.70
16.68
1.71
13.46
3.83









137.36
- — . 	
Hot-Side ESP Boilers I
Mean emission factor |
(2 facilities)
(ng/kq feed) li
Nondetects
Set to 1/2
Det. Limit
0.10
0.11
0.15
0.20
0.22
1.17
5.24
0.81
0.38
0.52
0.83
0.37
0.08
0.56
1.04
0.18
0.70
0.78

0.77
1.15
1.67
2.34
5.24
5.47
. 5.50
4.04
1 94
0.70
28.83
Nondetects
Set to
Zero
0.00
0.04
0.08
0.18
0.20
1 17
5.24
0.81
0.38
0152
0,83
0.37
0.02
0.56
0.93
0.16
0.70
0.64

0.77
0.77
1.62
2.34
5:24
5.47
5.51
4.04
1 CIA
0.70
28.83
ng/kg - nanograms per kilogram
Source: U.S. EPA <1996c).
                                          3-62
                                                                                April 1998

-------
                        DRAFT-DO NOT QUOTE OR CITE
                              Ratio (congener emission factor/total CDD/CDF emission factor)
                    0                      0.05                     0.1                      0.15
       2,3,7,8-TCDD
    1,2,3,7,8-PeCDD
  1,2,3,4,7,8-HxCDD
  1,2,3,6,7,8-HxCDD
  1,2,3,7,8,9-HxCDD
 1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
       2,3,7,8-TCDF
    1,2,3,7,8-PeCDF
    2,3,4,7,8-PeCDF
  1,2,3,4,7,8-HxCDF
  1,2,3,6,7,8-HxCDF
  1,2,3,7,8,9-HxCDF \
  2,3,4,6,7,8-HxCDF
 1,2,3,4,6,7,8-HpCDF
 1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
     Figure 3-10. Congener Profile for Air Emissions from Hazardous Waste Incinerators
                                        3"63                                       April 1998

-------
                          DRAFT-DO NOT QUOTE OR CITE
                                Ratio (congener emission factor /total CZ3D/CDF emission factor)
                                       °-OS                0.1                 0.1S
       2.3.7.8-TCDD
     1,2,3,7,8-PeCDD
  1,2,3.4,7,8-HxCDD
  1.2,3,6,7,8-HxCDD
  1,2.3.7,8,9-HxCJDD
 1.2,3,4.6,7,8-HpCDD
1,2.3.4,6,7,8,9-OCDD
       2,3,7,8-TCDF
     1.2,3,7.8-P*CDF
     2,3,4,7,8-PeCDF
  1,2.3.4.7,8-HxCDF
  1,2,3,6.7.8-HxCDF
  1,2,3,7.8.9-HxCDF
  2,3.4,6.7,8-axCDF
 1,2.3,4,6,7.8-HpCDF
 1,2,3,4,7.8.9-HpCDF
1.2.3.4,6,7,8.9-dCDF
                                                                                                  O.2
                   Ratio (congener group emission factor / total CDD/CDF emission factor)
                    0-05                0.1                 0.15                0.2
                                                                                                 0.2S
          Figure 3-11. Congener and Congener Group Profiles for Air Emissions from
                   Boilers and Industrial Furnaces Burning Hazardous Waste
                                            3-64
                                                                                          April 1998

-------
                         DRAFT-DO NOT QUOTE OR CITE

              Table 3-7. Summary of Annual Operating Hours for Each MWI Type
" t -/
MWIType
Continuous
commercial
Continuous
onsite
Intermittent
Batch
Capacity Ranges <
«b/hr} -
> 1,000
501 - 1,000
> 1,000
^ 500
Case by case
Annual charging t
hours
• ' (hr/yrf ^
7,776
1,826
2,174
1 ,250
Case by case
i Maximum annual
charging hours
8,760
5,475
4,380

Capacity
0.89
0.33
0.40
0.29

Ib/hr = pounds per hour
hr/yr = hours per year
                                       3-65
                                                                          April 1998

-------
                   DRAFT-DO NOT QUOTE OR CITE

  Table 3-8.  OAQPS Approach: PM Emission Limits for MWIs and Corresponding
             Residence Times in the Secondary Combustion Chamber
MWIType
Intermittent and
Continuous
Batch
PM Emission Limit8
(gr/dscf }
2:0.3
0.16 to < 0.30
0.10 to <;0.16
;> 0.079
0.042 to < 0.079
0.026 to < 0.042
Residence Time in
2° Chamber
(seconds) ;:
0.25
1.0
2.0
0.25
1.0
2.0
TEQ Emission
Factor:*
(kg TEQ/kg waste)
3.96 e-9
9.09 e-10
7.44 e-1 1
3.96 e-9
9.09 e-10
gr/dscf = grains per dry standard cubic foot at standard temperature and pressure.
                                 3-66
                                                                     April 1998

-------
                           DRAFTS-DO NOT QUOTE OR CITE

    Table 3-9. OAQPS Approach: Estimated Nationwide CDD/CDF TEQ Emissions (g/yr) for 1995
[;MWI ; -
^ * 'Type M~V '
_1^ 	 * • <-•
Batch
Continuous
Continuous/
Intermittent
Intermittent
•Subtotal: , „
Uncontrolled - -*
Batch
Continuous
Intermittent
Subtotal: Controlled X
'W/Wet Scrubber
Continuous
Continuous
on-site/ Intermittent
Continuous
Continuous
on-site/ Intermittent
Subtotal: Controlled
w/Dry Scrubber
Intermittent
Total MWI v
Residence^
' ,- Tirne or - '"
'> '/APCD**7-
0.25 sec
1.00 sec
2.00 sec
0.25 sec
1 .00 sec
2.00 sec
0.25 sec
1 .00 sec
2.00 sec
0.25 sec
1 .00 sec
2.00 sec
v cV "*
''*'*•&-
Wet Scrubber
Wet Scrubber
Wet Scrubber
\ - s
Dry Scrubber
no carbon
Dry Scrubber
with no
carbon
Dry Scrubber
with Carbon
Dry Scrubber
with Carbon
-f *" s
Fabric Filter/
Packed Bed
s
, CDD/CDF
<~/rfo £F,iA f
1.94e + 05
4.45e + 04
3.65e + 03
1.94e + 05
4'.45e + 04
3.65e + 03
1.94e + 05
4.45e + 04
3.65e + 03
1.94e + 05
4.45e + 04
3.65e + 03
\
'< f »
4.26e + 02
4.26e + 02
4.26e + 02
H *? "%
3.65e + 02
3.56e + 02
7.00e + 01
7.00e + 01
!i~
3.34e + 04

^TEQ,'
'EF;/
3.966 + 03
9.09e + 02
7.40e + 01
3.96e + 03
9.09e + 02
7.40e + 01
3.96e + 03
9.09e + 02
7.40e + 01
3.96e + 03
9.09e + 02
7.40e + 01
i o
* „ „ ^ ' *
/
10
10
10
^ \ -,
7
7
2
2
"> 4s ^ #
ft ^ / /
3^1
6.81e + 02
•
*" ^Activity
~ Level * *
5.95e + 06
4.20e + 05
2.14e + 05
1.20e + 06
5.10e + 06
3.01e + 07
4.54e+06
4.24e + 07
9.79e + 07
4.18e + 06
1.83e + 07
NA '
2»53e-M)8
i^» « '
2.42e + 04
1.88e + 08
6.04e + 07
3.7le+08
'I
9.94e + 07
7.86e + 06
1.43e + 07
3.706 + 06
i:46e+j08'
7 v. '•
6.99e + 05

CDD/CDF^
s Emissions
1.15e + 03
1.876 + 01
7.82e-01
2.34e + 02
2.27e + 02
1.10e + 02
8.80e + 02
1.88e + 03
3.57e + 02
8.11e + 02
8.12e + 02
NA
>6.65e+O3
1 .OOe-02
8.01e + 01
2.58e + 01
1.58e+02
3.63e + 01
2.87
1.00
2.61e-01
4.80e+01
N ^
2.34e + 01

- TEQ
"" Emissions ^
2.35e + 01
3,82e-01
1.60e-02
4777
4.64
2.24
1,80e + 0,1
3.85e + 01
7.29
1. 656 + 01
1.66e + 01
NA
1.36e+02
2.00e-04
1 .90
6.11e-01
3.74 >
^
7.39e-01
5.80e-02
2.40e-02
6.00e-03
9.82e-O1 ' :
> „
4.76e-01

NA = Not applicable
ng/kg = nanograms per kilogram
kg/yr = kilograms per year
g/yr = grams per year
                                         3-67
                                                                               April 1998

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                           DRAFT-DO NOT QUOTE OR CITE


       Table 3-10. AHA Approach: TEQ Emission Factors Calculated for Air Pollution Control
ARC Category
Uncontrolled
MWIs up to 200 Ib/hr
MWIs > 200 Ib/hr
Wet scrubber/BHF/ESPb
Dry sorbent injection/Fabric Filter
TEQ Emission-Factor
(lb/1.06'lbs waste)
1.53e-03
5.51e-04
4.49e-05
6.95e-05
Number of MWI Test
Reports Used'8
4
13
11
8
       The same MW| may have been used more than once in deriving emission factors.

       Wet scrubbers-bag house filters-electrostatic precipitators.  Bag house is also called Fabric
       Filter.                              '
Source: Doucet (1995).
                                          3-68
                                                                                April 1998

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                            DRAFT-DO NOT QUOTE OR CITE


             Table 3-11.  AHA Assumptions of the Percent Distribution of Air Pollution
                         Control on MWIs Based on PM Emission Limits
* ~y * > ^
* '/''*• f * ^~ **
, ~ PM Emission Limits8 -
V, *•' "(gr/dSCf) ""?
2 : 0.10
0.08 to < 0.10
0.03 to < 0.08
< 0.03
, ,- Percent MWIs.:
~ + sUncohtroIIedb^"~f
'50%
25%
0%
0%
Percent-MWIs with Wet ,
!> ,-. ^Scrubbers/ -"
' " - "-rBHRs/ESPs6*'''" -
50%
75%
98%
30% ...
^ ^<-y
^Percent ,.,
0%
0%
2%
70%
	
       Paniculate matter (PM) emission limits at the stack, grains per dry standard cubic foot
       (gr/dscf).


       Uncontrolled means there is no air pollution control device installed on the MWI.


c      Scrubbers/BHFs/EDPs means wet scrubbers-bag house filters-electrostatic precipitators.

       DI/FF means dry sorbent injection combined with fabric filters.
                                           3-69
                                                                                  April! 998

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                            DRAFT-DO NOT QUOTE OR CITE
                  1 ,   Ih"  "        ,    *'»'     ' , "      , .                 i
        Table 3-12.  AHA Approach:  Estimated Annual Nationwide CDD/CDF TEQ Emissions

APCD8
Uncontrolled
Subtotal:
Uncontrolled
WS/BHF/ESP
DI/FF
Subtotal: Controlled

Total
MWI Capacity6
(Ib/hr)
<; 200
> 200

>200
>200
/


CDD/CDF TEQ
Emission Factor0
(g/kg waste)
1.54e-06
5.51 e-07

4.49 e-08
6.95 e-08



MWI Activity
. Leveld
(kg/yr)
2.28e + 07
1.54e + 08
1.77e+08
3.51 e + 08
2.60 e + 07
3.77e+08>v
.
"5,54 •e4-08;^':^'-:
Annual TEQ
Emissions
(g/yr)
3.51e + 01
8.48e + 01
1.20e+02
1.58e + 01
1.81
1.76&+01

1:38e+b2-^r't
       APCD = Air Pollution Control Device assumed by AHA.  Uncontrolled means there is no air
       pollution control device installed op the MWI. WS/BHF/ESP = Wet scrubber-bag house
       filter-electrostatic precipitator. DI/FF = Dry sorbent injection-fabric filter.

       MWI capacity is the design capacity of the primary combustion chamber.

c      TEQ Emission Factor derived from tested facilities.

       Activity Level is the annual amount of medical waste incinerated by each APCD class. '

Ib/hr = pounds per hour
g/kg = grams per kilogram
kg/yr = kilograms per year
g/yr «= grams per year
                                          3-70
                                                                                 April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

           Table 3-13. 'Comparison Between Predicted Residence Times and Residence
             Times Confirmed by State Agencies from EPA/ORD Telephone Survey
"- T State '%. x
- ;.-***/ \1
Michigan
Massachusetts
Virginia
New Jersey
x,Resldence?Time
^ Categories*^
\ ""
1/4 second
1 .0 second
2.0 seconds
1 /4 second
1 .0 second
2.0 seconds
1 /4 second
1 .0 second
2.0 seconds
1 /4 second
1 .0 second
2.0 seconds
Percentage of ~,
#-. Uncontrolled .JMWIs
Predicted by PM Method
2% (6/280 MWIs)
2% (5/280)
96% (269/280)
6% (6/94 MWIs)
0% (0/94)
94% (88/94)
1 1 % (6/56)
0 % (0/50)
89% (50/56)
0% (0/53 MWIs)
0% (0/53)
100% (53/53)
Percentage of .Uncontrolled
MWls 'Confirmed by State
96% (269/280 MWIs)
3% (9/280)
1% (1/280) '
Unknown
Unknown
4% (2/50)
4.5% (1/22)
91% (20/22)
4.5% (1/22)
Unknown
Unknown ,
Unknown
Source: O'Rourke (1996).
                                       3-71
                                                                           April 1998

-------
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                           DRAFT-DO NOT QUOTE OR CITE
                             Ratio (mean congener emission factor / total CDD/CDF emission factor)
                                             0.05
       2,3.7,8-TCDD
     1.2,3,7,8-PeCDD
   1.2.3.4,7,8-HxCDD
   1,2.3.6,7.8-HxCDD
   1.2,3,7.8.9-HxCDD
 1,2.3,4.6,7,8-HpCDD
1.2.3,4,6,7,8,9-OCDD
       2,3,7,8-TCDF
     1.2.3,7.8-PeCDF
     2,3.4.7,8-PeCDF
   1.2.3,4,7,8-HxCDF
   1,2.3,6,7,8-rixCDF
   1.2.3,7,8,9-HxCDF
   2.3.4.6.7,8-HxCDF
 1,2,3,4,6,7,8-HpCDF
 1,2.3,4.7.8,9-HpCDF
1.2,3.4.6.7,8.9-OCDF
                   Ratio (congener group emission factor / total CDD/CDF emission factor)
                   °-OS                0.1                o.lS             m
                                                                            0.2
                                                                                              0.25
         Figure 3-12.  Congener .and Congener Group Profiles for Air Emissions
                    from Medical Waste Incinerators without APCD
                                          3-73
                                                                                        April 1998

-------
                          DRAFT-DO NOT QUOTE OR CITE
                               Ratio (congener emission factor / total CDD/CDF emission factor)
                           0.01     0.02    0.03     0.04     O.OS     0.06    0.07     0.08
                                                                                               0.09
       2.3.7,8-TCDD
    1,2,3,7,8-PeCDD
  1,2,3,4,7.8-HxCDD
  1,2,3,6.7,8-HxCDD
  1,2,3,7.8.9-HxCDD
 1,2,3,4.6,7,8-fffCDD
1.2,3,4,6.7.8,9-OCDD
       2,3.7.8-TCDF
              :'\T.\ 1,
    1.2,3,7,8-PeCDF
    2,3,4.7.8-PeCDF
  1,2.3,4,7,8-HxCDF
  1.2,3,6,7,8-HxCDF
  1.2,3,7.8.9-HxCDF
  2,3,4.6,7,8-fixCDF
 1,2,3.4.6,7,8-HpCDF
 1,2.3.4.7,8.9-Hi)CDF
1,2,3,4.6,7,8,9-OCDF
                    Ratio (congener group emission factor / total CDD/CDF emission factor)
                         °-os                     0.1                     0.15
                                                                                                0.2
      Nondetects set equal to zero.
  Figure 3-13.  Congener and Congener Group Profiles for Air Emissions from Medical
     Waste Incinerators Equipped with a Wet Scrubber, Baghouse, and Fabric Filter
                                           3-74
                                                                                         April 1998

-------





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-------
                              DRAFT-DO NOT QUOTE OR CITE

    Table 3-16. Comparisons of Basic Assumptions Used in the EPA/ORD, the EPA/OAQPS, and the
        AHA Approaches to Estimating Nationwide CDD/CDF TEQ Emissions from MWIs in 1995
I Assumptions
Reference Year
Number of MWIs
Estimated Activity
Level
Percent of Activity
Level at Uncontrolled
MWIs
Percent of Activity
Level at Controlled
MWIs
Subcfassification of
Uncontrolled Class
Assumed Distribution
of Uncontrolled Class
APCDs Assumed for
Controlled Class
I Assumed Distribution
of Controls
Emission Factor
I Approach Used
I No. of Tested MWIs
Used to Develop
Emission Factors
Uncontrolled TEQ
Emission Factors
(ng/kg)
Controlled TEQ
Emission Factors
(ng/kg)
EPA/ORD Approach
1995
2,375
7.71 e + 08 kg/yr
33%
67%
Same as AHA
assumption
Same as AHA
assumption
WS/FF/ESP
DI/FF
FF/Packed Bed Scrub
Yes/ Analogous to
AHA method.
Yes
Uncontrolled: 8
Controlled: 1 1
1,865 = s200 Ib/hr
1,701 = >200lb/hr
f/ WS/FF/ESP: 72
g/ DSI/FF: 7
h/FF/PBS: 1,352

1995
2,375
7.71 e + 08 kg/yr
33%
67%
By residence times (RT) in
secondary chamber
By RT of 0.25, 1 .0 and 2.0
sec by State PM emission
limits
WS
DS-no Carbon
DS-Carbon
FF/Packed Bed Scrub
Yes/ Analogous to AHA
method
Yes
Uncontrolled: 10
Controlled: 23
a/ 3,960 = 0.25 s RT
b/ 909 = 1 .0 s RT
c/ 200 Ib/hr 74 =2.0sRT
/WS: 10
/ DS no carbon: 7
k/ DS with carbon: 2
/FF/PBS: 681

1995
2,233
5. 54 e + 08 kg/yr
32%
68%
By design capacity
By estimated annual
hrs of operation of <
200 Ib/hr and > 200
Ib/hr design capacity
WS/FF/ESP
DI/FF
Yes/ Based on survey
and State PM
emission limits
Yes
Uncontrolled: 13
Controlled: 12
d/ 1,540 =s200 Ib/hr
e/ 551= > 200 Ib/hr
ml WS/FF/ESP: 44.9
n/ DSI/FF: 69.5
WS - Wet Scrubber; FF = Fabric Filter; ESP = Electrostatic Precipitator; DSI = Dry Sorbent Injection; DS
Dry Scrubber; no carbon = without the addition of activated carbon; with carbon = with the addition of
activated carbon; PBS = Packed Bed Scrubber.
a       0.25 seconds residence time (RT) in the secondary chamber.
b       1.0 seconds residence time (RT) in the secondary chamber.
c       2.0 seconds residence time (RT) in the secondary chamber.
d       design capacities less than or equal to 200 Ibs/hr.
e       design capacities greater than 200 Ibs/hr.

Ib/hr « pounds per hour
kg/yr «  kilograms per year
                                             3-76
                                                                                      April 1998

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                        DRAFT-DO NOT QUOTE OR CITE
                Table 3-17. CDD/CDF Air Emission Factors for a Crematorium

Congener/Congener Group


2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD -
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1 ,2,3,7,8,9-HxCDF .
2,3,4,6,7,8-HxCDF '
1,2,3,4,6,7,8-HpCDF
t,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-GDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
TotalTCDF
Total PeCDF
Total HxCDF
Total HpCDF :
Total OCDF
Total CDD/CDF
=====!^======================s=========l
Mean Facility Emission Factor
Assuming
ND = zero
(ng/body)-
28.9
89.6
, 1 08
157
197
1,484
2,331
206
108
339
374
338
657
135
1,689
104
624
4,396-
4,574
501
554
860
2,224
3,180
2,331
4,335
2,563
4,306
2,030
624
23,007
Assuming
ND = 1/2 det limit
(ng/body)
28.9
89.6
108
157
197
1 484
t f^TU^T
	 	 2,331 	
206
117
349
374
338
657
135
1,813 '
112
624
r ,
4,396
4,725
508
554
860
2,224
3,180
2,331
4,335
2,563
4,306
2,154
624 II
23,131 I
ng/body = nanograms per body
Source: CARB (1990c)
                                    3-77
                                                                     April 1998

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                           DRAFT-DO NOT QUOTE OR CITE
                                Ratio (congener emission factor / total CDD/CDF emission factor)
                                0.02          p.04          0.06          0.08          0.1
                                                                                                  0.12
       2,3,7,8-TCDD
     1.2.3,7,S-PcCI>r>
  1.2,3.4,7.S-HxCDD
  1, 2.3,6,7. 8-HxCDE>
  1.2,3.7.8,9-HxCDD
 1,2,3.4.6,7,8-HpCbD
1.2.3.4,6,7,8,9-OCpD
       2,3,7,8-TCDF
     l,2,3.7,S-PeCDF
     2.3,4,7,8-PcCDF
  1,2,3.4.7,8-HjcCDF
  1^^.6.7.8-HxCDF
  2^,4,6.7,8-HxCDF
 1 ,2,3,4.6.7.S-HpCbF
 1 ^,3 .4.7,8,9-HpCDF
                   Ratio (congener group emission factor / total CDD/CDF emission factor)
                        °-05                     0.1                     0.15
                                                                                                 0.2
     Source: CARB (1990c); nondetects set equal to zero.
                 Figure 3-14. Congener and Congener Group Profiles for
                            Air Emissions from a Crematorium
                                            3-78
                                                                                          April 1998

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             Table 3-18.  CDD/CDF Emission Factors for Sewage Sludge,Incinerators

Congener


2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
11,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD •
Total TCDF
Total PeCDF
I Total HxCDF
Total HpCDF
Total OCDF
Total TEQ
Total CDD/CDF
1
U.S. EPA (1987a) - 3 facilities
Mean Emission Factor (ng/kq)
Nondetects
Set to
Zero
0.39
NR
NR
NR
NR
NR
46.2
179
NR
NR
NR
NR
NR
NR
NR
NR
109
37.6
2.66
16.6
53.9,
46.2
528
253
75.4
144
109
NR .
1,266
Nondetects
Set to
1/2 Det. Limit
0.44
NR
NR
NR
NR
NR
46.2
179
NR
NR
NR
NR
NR
NR
NR
NR
109
37.7
2.81
16.9
54.0
46.2
528
253
75.9
144
109
NR
. 1,268
=s==:====================
Green et al. (1995) - 13 facilities
Mean Emission Factor (nq/kq)
Nondetects
Set to
Zero
0.12
0.23
0.03
0.10
0.29
2.55
13.60
26.60
1.98
6.84
".' 2.17
0.79
0.03
1.26
~ 1 .46
0.17
1.22
35.80
6 82
1 .74
4.39
13.60
123.85
59.94
12.69
2.63
1 .22
6.94
257
======!=
Nondetects
Set to
1/2 Det. Limit
O"2"?
O ?9
O 1 1
O 1fi
O ^R
2 70
14.00
26.63
2 OR
6QQ
2 24
O 8^
0.08
1 4R
1 64
0.27
*1.62
37.81 ,
• 1 RQ
2.25
5.03
14.00
124.10
60.16
13.50
^19 I
1.62
7.19
263
=======£
ng/kg = nanograms per kilogram
NR = not reported
Sources: U.S. EPA (1987a); Green et al. (1995)
                                      3-79
                                                                         April 1998

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                              Ratio (congener emission factor / total CDD/CDF emission factor)
                               0.05          0.1         0.15          0.2          0.25
                                                                                               0.3
       2.3,7,8-TCDD
    1,2,3,7,8-PeCDD
  1,2,3,4,7,8-HxCDD
  1,2,3,6,7,8-HxCDD
  1,2,3,7,8,9-HxCDD
 1,2,3,4.6,7,8-HpCDD
1,2,3.4,6,7,8,9-OCDD
       2,3.7,8-TCDF
    1,2,3,7,8-PeCDF
    2,3,4,7,8-PcCDF
  1,2,3,4.7,8-HxCDF
  1^,3,6,7,8-HxCiDF
  1^,3,7.8,9-HxCDF
  2^.4,6,7.8-HxCDF
 1^,3,4,6,7,8-HpCDF
 1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
                   Ratio (congener group emission factor / total CDD/CDF emission factor)
                    0.1                 0.2                0.3                0.4
                 Figure 3-15.  Congener and Congener Group Profiles for
                     Air Emissions from Sewage Sludge Incinerators
                                           3-80
                                                                                        April 1998

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                Table 3-19. CDD/CDF Air Emission Factors for Tire Combustion
II
Congener/Congener Group


2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF '
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1 ,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD .
Total 2,3,7,8-CDF .
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF •
Total PeCDF
Total HxCDF '
Total HpCDF
Total OCDF
Total CDD/CDF ,
Mean Facility Emission Factor
Assuming
ND = zero
(ng/kg) ,
0.149
» 0.006
6.018
0.055
0.036
0.379
4.156
0.319.
0.114
0.086
0.103
0.059
0.036
0.100
0.000
0.027
0.756
4.799
1.600
0.282
0.153
0.032
0.391
0.695
4.156
1.204
0.737
0.710
0.119
0.756
8.953
Assuming
ND = 1/2 det limit
	 (ng/kg)
0.149
0.026
0,023
0.062
0.048
0.379
4.156
0.319
0.118
0.091
0.111
0.090
0.068S
0.148
0.166
0.095
0.756 	 	
4.843
1.962
0.310 	 	
0.153
0.0,32
0.391
0.695
4.156
1 .204
0.737
0.710
0.186 .
0.756

ng/kg = nanograms per kilogram
ND = not detected

Source: CARB (1991 a)
                                     3-81
                                                                       April 1998

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                               Ratio (congener emission factor / total CDD/CDF emission factor)
                                   0-1             '0.2             0.3              0.4
                                                                                                  0.5
       2,3,7,8-TCDD
     1,2,3,7,8-PeCDD
  1 ,2,3 ,4,7,8-HxCDD
  1,2.3,6,7,8-HxCpD
  1,2,3 ,7.8.9-HxCDD
 1.2,3,4.6,7,S-Hp
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                          DRAFT-DO NOT QUOTE OR CITE

             fable 3-20. CDD/CDF Emission Factors for Combustion of Bleached-Kraft
                            Mill Sludge in Wood Residue Boilers
Congener
12,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1 ,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1, 2,3,6, 7,8-HxCOF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
~1,2,3,4,6,7,8:HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
| Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total TEQ
Total CDD/CDF
'
- =^==^=r=:=
Sludge and Wood - 1 facility
Mean Emission Factors
(ng/kg feed)
; Nondetects
Set to
Zero
0
0
0
0
0
0
0.025
0.005
0
0
0
0
0
0
0
0
0
0
0
0
0
0.025
0.094
0
0 ;
-0
0
0.001
0.119
, Nondetects
Set to
1/2 Det. Limit
0.001
0.001
0.001
0.001
0.001
0.003
0.025
0.005
0.003
0.003
0.001
0.001.
0.001
0.001
0.001
0.000
0.001
0.002
0.001
0.002
0.003
0.025
0.094
0.003
0.001
0.001
0.001'
0.005
< 0.134
=^5=«— — — — — —
1 	 ' 	 	 "^
Wood Residue Only - 5 facilities
Mean Emission Factors
Nondetects
Set to
Zero
0.066
.0.110
0.179
0.191
0.522
0.635
1.317
0.707
0.145
0.159
0.108
0.071
0.064
0.015
0.072
0.017
0.049
1.628
1.958
1.792
1.120
1.317
4.532
1.548
0.536
0.111
0.049
0.401
14.593
Nondetects I
Set to
1/2 Det Limit I
0.068
0.112'
0.183
0.193
0.524
0.637
1.317
0.719
0.149
0.164
0.111
0.073
0.067
0.017
0.074
0.020
0.060
1.629
1.980
1.796
1.132
1.317
4.552
1.549
0.543
0.116
0.060
0 409
14.674
ng/kg = nanograms per kilogram
Source: NCASI (1995)
                                      3-83
                                                                         April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
                               Ratio (congener emission factor / total CDD/CDF emission factor)
                                       0.1                 0.2                 0.3
                                                                                                0.4
       2,3,7,8-TCDD
    1,2,3,7,8-PtCDD
  1.2,3,4.7.8-HxCDD
  1,2.3,6,7,8-HxCDD
  1.2.3,7.8.9-HxCDD
 1,2,3,4,6,7.8-HpCDD
1.2.3,4,6,7,8,9-OCDD
       2.3,7.8-TCDF
    1.2,3.7.8-PeCDF
    2.3,4.7.8-PeCDF
  1,2,3,4.7.8-HxCDF
  1,2,3.6.7,8-HxCDF
  1,2.3.7.8,9-HxCDF
  2,3,4,6,7.8-HxCDF
 1.2,3,4,6,7,8-HpCDF
 1.2,3,4,7,8,9-HpCDF
1.2.3.4,6,7.8,9-OCDF
                      Ratio (congener emission factor / total CDD/CDF emission factor)
                         O.I                      O.2                     O.3
                                                                                                O.4
                   Figure 3-17. Congener and Congener Group Profiles
                  for Air Emissions from Bleached Kraft Mill Combustors
                                           3-84
                                                                                         April 1998

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                         DRAFT-DO NOT QUOTE OR CITE
                                                                                 *

        4. COMBUSTION SOURCES OF CDD/CDF: POWER/ENERGY GENERATION

 4.1.   MOTOR VEHICLE FUEL COMBUSTION
       Ballschmiter et'al. (1986) reported detecting CDD/CDFs in used motor oil and thus
 provided some of the first evidence that CDD/CDFs might be emitted by the combustion
 processes in gasoline- and diesel-fueled engines. Incomplete combustion and the presence
 of a chlorine source in the form of additives in the oil or the fuel (such as dichloroethane or
 pentachlorophenate) were speculated to lead to the formation of CDDs and CDFs. The
                           ^  "  ' '   ""                           -'
 congener patterns found in the used oil samples were characterized by Ballschmiter et al.
 (1986) as similar to the patterns found in fly ash and stack emissions from municipal waste
 incinerators.
       Since 1986, several studies have been conducted to measure or estimate CDD/CDF
 concentrations in emissions from vehicles.  Although there is no standard approved
 protocol for measuring CDD/CDFs in vehicle exhausts, researchers have developed and
 implemented several measurement approaches for collecting and analyzing vehicle
 exhausts. Other researchers have estimated vehicle exhaust emissions of CDD/CDFs
 indirectly from studies of tunnel air.  The results of these two types of studies are
 summarized in chronological order in the following Section 4.1.1 and Section 4.1.2.
 Estimates of national annual CDD/CDF  TEQ emissions from on-road motor vehicles fueled
 with leaded gasoline, unleaded gasoline, and diesel fuel are presented in Section 4.1.3
 based on the results of these studies. National emission estimates have not been
 generated for off-road vehicles (i.e., construction and farm vehicles) or stationary sources
 using these fuel types because of lack of emission factor data.

4.1.1. Tailpipe Emission Studies
      Marklund et al.  (1987) provided  the first direct evidence of the presence of CDDs
and CDFs in car emissions based on tailpipe measurements on Swedish cars.
Approximately 20 to 220 pg of TEQ from tetra- and penta-CDD/CDFs were reported per
kilometer driven for four cars running on leaded gasoline.  For this study, an unleaded
gasoline was used to which was added tetramethyl lead (0.1 5 grams of lead per liter [g/L]
or 0.57 grams  per gallon) and dichloroethane (0.1 g/L as a scavenger). The fuel used may
not accurately  represent commercial fuels, which typically contain a mixture of chlorinated

     .  ,              .                   4-1                                 April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

and brominated scavengers (Marklund et al., 1990). Also, the lead content of the fuel used
(0.15 g lead/L), although the normal lead content for Swedish fuels at the time (Marklund
et al., 1990), was higher than the lead content of leaded gasoline in the United States
during the late 1980s (lowered to 0.10 g lead/gallon or 0.026 g lead/L effective January 1,
1986). Marklund et al. (1987) reported a striking similarity in the TCDF and PeCDF
congener profiles in the car exhausts and those found in emissions from municipal waste
incinerators.  For two cars running on unleaded gasoline, CDD/CDF emissions, were below
the detection limit, which corresponded to approximately  13 pg of TEQ per kilometer
driven.
       Table 4-1 presents a summary description of the results of the Marklund et al.
(1987) study and subsequent studies (presented  in chronological order) discussed below.
Tables 4-2 and 4-3 present the results of tailpipe emission studies reported for diesel-fueled
cars and trucks, respectively, table 4-4 presents the results of studies using leaded
gasoline-fueled cars, and Tables 4-5 and 4^6 present results of studies with cars fueled by
unleaded gasoline. Figures 4-1, 4-2, and 4-3 present congener and congener group profiles
from diesel-fueled vehicles, leaded gasoline-fueled vehicles, and unleaded gasoline-fueled
vehicles, respectively.
       Virtually no testing of vehicle emissions in the United States for CDD/CDFs has been
reported.  In 1987, the California Air Resources Board (CARB) produced a draft report on
the testing of the exhausts of four gasoline-powered cars and three diesel fuel-powered
vehicles (one truck, one bus, and one car) (CARB, 1987a).  However, CARB indicated to
EPA that the draft report should  not be cited or quoted to support general conclusions
about CDD/CDFs in motor vehicle exhausts because of the small sample size of the study
and because the use of low  rather than high resolution mass spectrometry in the study
resulted in high detection limits and inadequate selectivity in the presence of interferences
(Lew, 1993).  CARB did state that the results of a single sample from the heavy-duty diesel
truck could be reported, because congeners from most of the homologue groups were
present in the sample at levels that could  be detected by the analytical  method and there
were no identified interferences in this sample. This test was conducted under steady
state conditions (50 km/hrj for 6 hours with an engine with a fuel economy of 5.5 km/L.
The TEQ emission factor of  this  one sample was equivalent to 7,290 pg/L of fuel burned (br
1,300 pg/km driven) if nondetected values are treated as one-half the detection limit.

                                         4-2                                April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

  Treating nondetected values as zeros yields a TEQ concentration equivalent to 3,720 pg/L
  of fuel burned (or 663 pg/km driven) (Lew, 1996).
                                            ,"                -^          '  '
        Haglund et al. (1988) sampled exhaust gases from three different vehicles (two cars
  fueled with leaded and unleaded gasoline, respectively, and a heavy-duty diesel truck) for
  the presence of brominated dibenzb-p-dioxins (BDD) and  brominated dibenzofurans (BDF).
  The authors concluded that the dibromoethane scavenger added to the tested gasoline
  probably acted as a halogen source. TBDF emissions measured 23,000 pg/km in the car
  with leaded gasoline and 240 pg/km in the car with unleaded gasoline. TBDD and PeBDF
  emissions measured 3,200 and 980 pg/km, respectively, in the car with leaded gasoline.
  All BDD/Fs were below detection limits in the diesel truck emissions.
        Bingham et al. (1989) also analyzed 2,3,7,8-substituted CDD/CDFs  in automobile
  exhausts.  Four cars using leaded gasoline (0.45 g/JL tetramethyllead, 0.22  g/L
  dichloroethane, and 0.2 g/L dibromoethane) were tested, and one car using unleaded
  gasoline was tested.  Only HpCDD and OCDD were detected in the exhaust from the
  vehicle using unleaded fuel.  The total TEQ emission rate for this car, based on these
  detected congeners, was  1 pg/km; the detection limit for the other 2,3,7,8-substituted
  CDD/CDFs was a combined 28 pg TEQ/km. 2,3,7,8-TCDF was detected in the exhaust of
  two of four cars using leaded fuel.  OCDD was detected in the exhaust from three of the
  cars, and PeCDF and HpCDD were each detected in the exhaust from one car. TEQ
 emission  rates for the cars using leaded fuel, based on detected congeners  only,  were 5 to
 39 pg/km.
        Marklund et al. (1990) tested cars fueled with commercial fuels, measuring
 CDD/CDF emissions before and/or after the muffler of Swedish vehicles (including new and
 old vehicles). Three cars were tested using unleaded gasoline, and two cars were tested
 with leaded gasoline (0.15 g Pb/L and dichloroethane and dibromoethane scavengers).
 CDD/CDFs were not detected in the fuels at a detection limit of 2 pg TEQ/L, but were
 detected at a level of 1,200 pg  TEQ/L in the new semi-synthetic engine lube oil used in the
 engines.  The test driving cycle  employed (i.e.,  31.7 km/hr as a mean speed; 91.2 km/hr as
 a maximum speed; and 17.9 percent of time spent idling) yielded a fuel economy of
 approximately 9 to 10 km/L or 22 to 24 miles/gallon,  Marklund et al. (1990) reported the
"following  emission results  in units of pg TEQ/L of fuel consumed and also in units of pg
 TEQ/km driven during the test:                                                     .
                                        4-3
                                                                           April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

      •  Leaded gas/before muffler: 2.4 to 6.3 pg TEQ/km (or 21 to 60 pg TEQ/L of fuel
         consumed);                      _.
      •  Leaded gas/in tailpipe: 1.1 to 2.6 pg TEQ/km (or 10 to 23 pg TEQ/L);
      •  Unleaded gas/catalyst-equipped/in tailpipe: 0.36 pg TEQ/km (or 3.5 pg TEQ/L);
         and
      •  Unleaded gas/before muffler: 0.36 to 0.39 pg TEQ/km (or 3.5 pg TEQ/L).

The TEQ levels in exhaust gases from older cars using leaded gasoline were up to six times
greater when measured before the muffler than after the muffler. No muffler-related
difference in new cars running on leaded gasoline or in old or new cars running on unleaded
      „ "i      " '!   '       •            ''• '    '„,''"',
gasoline was observed.
      Marklund et al. (1990) also analyzed the emissions from a heavy-duty diesel-fueled
truck for CDD/CDFs. None were detected; however, the authors pointed out that the test
              "V    "      :     ".     ",   ;' '•' • •••''   '"'  ' :  ;   : ,'•  ;.•;       •
fuel was a reference fuel and may not be representative of commercial diesel fuel. Also,
due to analytical problems, a much higher detection limit (about 100 pg TEQ/L) was
employed in the diesel fuel test than in the gasoline tests (5 pg TEQ/L).  Further uncertainty
was introduced by the fact that diesel emission samples were only collected prior to the
muffler.
       Hagenmaier et al. (1990) ran a set of tests using conditions  comparable to the FTP-
73 test cycle on gasoline- and diesel-fueled engines for light duty vehicles in Germany.  The
following average TEQ emission rates per liter of fuel consumed were reported:
          *    ',             , :      -         •     , '      '   ' .   ' .
       •  Leaded fuel:  1,083 pg TEQ/L;
''          "    '!''       *              ,.'','    L,,  ' '
       •  Unleaded fuel (catalyst-equipped):  7 pg TEQ/L;
       •  Unleaded fuel (not catalyst-equipped): 51 pg TEQ/L; and
              ii!  '        '            ..,,''"'•        ',             i
       •  Diesel fuel: 24 pg TEQ/L.

       The major findings of a German study of emissions of halogenated dibenzodioxins
and  dibenzofurans from internal combustion engines running on commercial fuels were
published in 1991 (Schwind et al., 1991), and the full detailed report was published in
1992 (Hutzinger et al., 1992). The study was conducted by the Universities of Stuttgart,
Tubingen, and Bayreuth for the Federal Ministry for Research and Technology, the Research

                                         4-4                                April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

Association for Internal Combustion Engines, and the German Association for the Petroleum
Industry and Coal Chemistry. Tests were conducted using engine test benches and rolling
test benches under representative operating conditions. Tests were performed on leaded
gasoline engines, unleaded gasoline engines, diesel car engines, and diesel truck engines.
The reported range of GDD/CDF emission rates across the test conditions in units of pg
TEQ per liter of fuel consumed are presented below. The results from those tests
conducted under normal operating conditions with commercial fuels and for which
congener-specific emission results were presented in Hutzinger et al. (1992) are listed in
Tables 4-2 through 4-6.

       •_ Leaded fuel: 52 to 1,184 pg TEQ/L;
       • Unleaded fuel (not catalyst-equipped): 57 to  177 pg TEQ/L;
       • Unleaded fuel (catalyst-equipped):  15 to 26 pg TEQ/L;
       • Diesel fuel (cars):  10 to 130 pg TEQ/L; and
       • Diesel fuel (trucks):  70 to 81 pg TEQ/L.                      '..'.'

       Although no specific details on the methodology used were provided,  Hagenmaier
(1994) reported that analyses of emissions of a diesel-fueled bus run either on steady state
or on the "Berlin cycle" showed no CDD/CDF present at a detection limit of 1 pg/L of fuel
consumed for individual congeners.
       Gullett and  Ryan (1997) recently reported  the results of the first program to sample
diesel engine emissions for CDD/CDFs during actual highway and city driving. The exhaust
emissions from a 1991 Freightliner diesel tractor with a 10.3 L, 6-cylinder Caterpillar
                               i                         '  ;
engine, representative of the first generation of computerized fuel controlled vehicles
manufactured in the United States', were sampled during both highway and city driving
routes.  The average emission factor'for the three highway tests conducted (15.1 pg
TEQ/km; range 11.7-18.7 pg TEQ/km; standard deviation of 3.5 pg TEQ/km)  was a factor
of three below the average of the two city driving tests (49.9 pg TEQ/kg; range 3.0-96.8
pg TEQ/km).  Detection limits were considered  as zeros in the calculation of these emission
factors. The average of all five tests was 29.0 pg TEQ/km with a standard deviation of
38.3 pg TEQ/km; this  standard deviation reflects  the 30-fold variation in the two city
driving route tests.

          : -                     .        4^5                                April 1998

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                         DRAFT-DO NOT QUOTE OR CITE
   Hi    "               ,               '
 4.1.2. Tunnel Emission Studies
       Several European studies and one recent U.S. study evaluated CDD/CDF emissions
 from vehicles by measuring the presence of CDD/CDFs in tunnel air.  This approach has the
 advantage that it allows random sampling of large numbers of cars, including a range of
 ages and maintenance levels. The disadvantage of this approach is that it relies on indirect
 measurements (rather than tailpipe measurements), which may introduce unknown
 uncertainties and make interpretation of the findings difficult. Concerns have been raised
 that the  tunnel monitors are detecting resuspended particulates that have accumulated over
 time, leading to overestimates of emissions. Also, the driving patterns encountered in
 these tunnel studies are more or less steady state driving conditions rather than the
 transient driving cycle and cold engine starts that are typical of urban driving conditions and
 that may affect emission levels.  Each of these studies is summarized below in
 chronological order.
       Rappe et at. (1988) reported the CDD/CDF content of two air samples (60 m3 per
 sample)  collected from a tunnel in Hamburg, Germany, during January of 1986 to be 0.42
 and 0.58 pg TEQ/m3. Each sample was cojlected for a period of about 60 hours.  Rappe et
 at. (1988)  reported that the tunnel handles 65,000 vehicles per day of  which 17 percent
 were class'ified as "heavy traffic." The congener-specific results of the two samples are
 presented  in Table 4-7.  Rappe et al. (1988) concluded that the  results clearly show that
' traffic (with leaded gasoline and halogenated additives) is a source of CDD/CDFs in ambient
 air. Measurement of ambient air conducted in September of 1986 at a "nearby highway in
 Hamburg was reported to contain CDD/CDF levels two to six times lower than those
 measured  in the tunnel;
       Larssen et al. (1990) and Oehme et al. (1991) reported the results of a tunnel study
 in Olso,  Norway, performed during April/May of  1988. Oehme et al. (1991) estimated total
 vehicle emissions by measuring CDD/CDF concentrations in tunnel inlet and outlet air of
 both the uphill and downhill lanes. Emission rates for light-duty and heavy-duty vehicle
             1 • .,i,ii<  •       .,  ,  i  ,   • .  i ,' i, • • •  .,,   i ,,,,,,,',,  •:	•  ,1',, •, ,     •       i
 classes in  the uphill and downhill lanes  were estimated by counting the number of light-
 duty vs. heavy-duty vehicles passing through the tunnel on workdays and a weekend and
 assuming a linear relationship between  the percentage of the light- or heavy-duty traffic
 and the  overall emission rate.  Thus, the linear relationship for each emission rate was
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                                                       i     •               ,
 based on only two points (i.e., the weekday and weekend measurements).  The emission
 rates, in units of Nordic TEQ, estimated in this study are:

       • Light-duty vehicles using gasoline (approximately 70-75 percent using leaded
         gas): uphill  = 520 pg TEQ/km; downhill  = 38 pg TEQ/km; mean = 280 pg
         TEQ/km; and
       • Heavy-duty diesel trucks:  uphill  - 9,500 pg TEQ/km;  downhill = 720 pg
         TEQ/km; mean = 5,100 pg TEQ/km.
 The mean values are the averages of the emission rates corresponding to the two operating
 modes: vehicles moving uphill on a 3.5 percent incline at an average speed of 37  miles per
 hour and vehicles moving downhill on a 3.5 percent decline at an average speed of 42
 miles per hour. Although Oehme et al. (1991) reported results in units of Nordic TEQs
 rather than l-TEQs,,the results in I:TEQ should be nearly identical (i.e., about 3 to 6 percent
 higher), because the only difference between the two TEQ schemes is the toxic
 equivalency factor assigned to 1,2,3,7,8-PeCDF  (0.1 in Nordic and 0.05 in I-TEQ), a  minor
 component of the toxic CDD/CDFs measured in the tunnel air. Table 4-7 presents the
 congener-specific differences in concentrations between the tunnel inlet and outlet
 concentrations.                                              .
       Wevers et al. (1992) measured the CDD/CDF content of air samples taken during
 the winter of 1991 inside a tunnel in Antwerp, Belgium.  During  the same period,
 background concentrations were determined outside the tunnel.  Two to four samples were
 collected from each location with two devices: a standard high volume sampler with a
 glass fiber filter and a  modified two-phase high volume sampler equipped with a glass fiber
 filter and a polyurethane foam plug (PUF).  The TEQ concentration in the air sampled with
 the filter/PUF device was 74 to 78 percent of the value obtained with only the high volume
 sampler only device.  However, the results obtained from both sets of devices indicated
 that the tunnel air had a dioxin TEQ concentration about twice as high as the outside air
 (filter/PUF:  80.3 fg TEQ/m3 for tunnel air vs. 35  fg TEQ/m3 for outside air; filter only:  100 ,
 fg TEQ/m3 for tunnel air vs. 58 fg TEQ/m3 for outside air).  Wevers et al. (1992) presented J
the congener-specific results for only one tunnel air measurement; these results are
 presented in Table 4-7  From these data, Bremmer et al.  (1994) calculated an emission
factor of 65 pg TEQ/km driven for all road traffic collectively.

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       During October/November 1995, Gertler et al. (1996; 1998) conducted a study at
 the Fort McHenry Tunnel in Baltimore, Maryland, with the stated objective of measuring
 CDD/CDF emission factors from in-use vehicles operating in the United States, with
 particular emphasis on heavy-duty vehicles. The air volume entering and leaving the tunnel
 bore that services most of the heavy-duty vehicles (i.e., approximately 25 percent of the
 vehicles using the bore are heavy-duty) was measured, and the air was sampled for
                                          ii '        '   ' •           !
 CDD/CDFs during 7 sampling periods of 12-hour duration. Three of the samples were
 collected during daytime (i.e., 6 am to 6 pm) and four samples were collected during the
 night (i.e., 6 pm to 6 am).  The air volume and concentration measurements were combined
 with information on vehicle counts (obtained from videotapes) and tunnel length to
 determine average emission factors.  A total of 33,000 heavy-duty vehicles passed through
 the tunnel during the seven sample runs. Heavy-duty vehicles accounted for 21.2 to 28.8
 percent of all vehicles passing through the tunnel for the seven sample runs.  The emission
 factors calculated, assuming that all CDD/CDF emitted in the tunnel were from heavy-duty
 Vehicles, are presented in Table 4-8.  The average TEQ emission factor was reported to be
 172 pg TEQ/km. The major uncertainties in the study were tunnel air volume
 measurement, sampler flow volume control, and analytical measurement of CDD/CDF
 (Gertler etal., 1996; 1998).
       EPA's Office of Mobile Sources (QMS) has reviewed the Gertler et al, (1996) study
 (Lorang,  1996). Overall, QMS found  the study to be technologically well done,  with no
 major criticisms or comments on  the test methodology or protocol.  QMS found no reason
 to doubt the validity of the emission factor determined by the study. OMS did note that
 the particulate emission rate for heavy-duty vehicles measured in the study {0.32 g/mile)  is
 lower than the general particulate emission rate used by EPA (i.e., about 1" g/mile) and,
 thus, may underestimate CDD/CDF emissions under different driving conditions. OMS
 cautioned that the reported emission factor should be regarded only as a conservative
 estimate of the mean emission factor for the interstate trucking fleet under the driving
 conditions of the tunnel  (i.e., speeds on the order of 50 miles/hour with the entering traffic
 slightly higher and the exiting traffic slightly lower.
       Figure 4-4 graphically presents the results of the studies by Rappe et al. (1988),
 Oehme et al. (1991), Wevers et al. (1992), and Gertler et al.  (1996). The figure compares
the congener profiles (i.e.,  congener concentrations or emission factors normalized to total

                                        4-8                                April 1998

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concentration or emission factor of 2,3,7,8-substituted CDDs and CDFs) reported in the
four studies. The dominant congeners in the Rappe et al. (1988), Wevers et al. (1992),
and Gertleret al. (1996) studies are OCDD, 1,2,3,4,6,7,8-HpCDD, OCDF, and
1,2,3,4,6,7,8-HpCDF.'With the exception of OCDD, these congeners are also major
congeners reported by Oehme et al. (1991).  The Oehme et al. (1991) study also differs
from the "other two studies jn  that the total of 2,3,7,8-substituted CDFs dominates total
2,3,7,8-substituted CDDs (by a  factor of 2), whereas just the opposite is observed in Rappe
et al. (1988), Wevers et al.  (1992), and Gertler et al. (1996).

4.1.3. National Emission Estimates
       Estimates of national CDD/CDF TEQ emissions are' presented in this section only for
on-road vehicles utilizing gasoline or diesel fuel.  Because emission factors are lacking for
off-road uses (i.e., construction  vehicles, farm vehicles, and stationary industrial
equipment), no emission estimates could be developed at this time.

       Activity information: The U.S. Federal Highway Administration, as reported in U.S.
Department of Commerce (DOC) (1997), reports that 1,586-billion total vehicle miles
(2,552 billion km) were driven in the United States during 1994 by automobiles and
motorcycles.  Because 1994 is the last year for which data are available, these data are
used as a  surrogate for 1995  activity levels.  Trucks  accounted for 840-billion vehicle miles
(1,351-billion km), and buses  accounted  for 6.4-billion vehicle miles (10-billion km)
(U.S. DOC, 1997).  In 1992, diesel-fueled trucks accounted for 14.4 percent of total truck
vehicle km driven; gasoline-fueled trucks accounted for the remaining 85.6 percent (U.S.
DOC, 1995b).  Applying this factor (i.e.,  14.4 percent) to the 1994 truck km estimate (i.e.,
1,351-billion km) indicates that an estimated 195-billion km were driven by diesel-fueled
trucks in 1994. It is assumed that all other vehicle km driven (3,718-bilIion km) were those
of gasoline-powered vehicles.  It is further assumed that all of these km were driven by
unleaded gasoline-powered vehicles because in 1992, only 1.4 percent of the gasoline
supply were leaded  fuel (EIA,  1993); usage should have further declined by 1995, because
use of leaded fuel in motor vehicles for highway use  in the United States was prohibited as
of December 31, 1995 (Federal  Register, 1985a).
                            '"         '                 •'•
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           i                     ••,''"         '       •             '            '

       Similar information for 1987 is as follows.  An estimated 3,092-billion km were
 driven in the United States of which trucks accounted for 687-billion km (U.S. DOC,
 1995a). In 1987, diesel-fueled trucks accounted for 17.2 percent of total truck km driven
 {U.S. DOC, 1995b).  Applying this factor (i.e., 17.2 percent) to the 1987 truck km estimate
 (i.e., 887-billion km)  indicates that an estimated 153-billion km  were driven  by diesel-fueled
 trucks. It is assumed that all other vehicle km driven  (2,939-billion km) were those of
 gasoline-powered vehicles. Leaded gasoline accounted for 24.1 percent of the gasoline
 supply in 1987 (EIA, 1993). Thus, it can be estimated that 708-billion km (i.e., 24.1
 percent of 2,939-billion km) were driven by leaded gasoline-fueled vehicles. The remaining
 2,231-billion km are  estimated to have been driven by unleaded gasoline-fueled vehicles.
 These mileage estimates are given a "high"  confidence rating on the basis that they are
 based on recent U.S. Bureau of the Census transportation studies.

       Emission Estimates: Using the results of the studies discussed in Section 4,.1.1,
              I, •!;     •     ',  .     '  -,,','  .    ,  •'",•, i   J.: ..,':,•        ! '
 separate annual national emission estimates are developed below  for vehicles burning
 leaded gasoline, unleaded gasoline, and diesel fuel. Estimates are provided for the years
 1987 and 1995.  The emission estimates for reference year  1995 are based on activity
 data (i.e., kilometers driven) for calendar year 1994.
               -,'       , "   , •" '  " , '•	    ,'   ;  .    : .   •'••,   . '•   ,..-..
       Leaded Gasoline: Literature indicates that CDD/CDF emissions do occur from
 vehicles using leaded gasoline and that considerable variation occurs depending, at least in
 part, on the types of scavengers  used.  Marklund et al. (1987) reported emissions ranging
from 20 to 220 pg TEQ/km from four cars fueled with a reference unleaded fuel to which
 lead (0.5 gplg) and a chlorinated  scavenger were added.  Marklund et al. (1990) reported
 much lower emissions in the exhaust of cars (1.1 to 6.3 pg TEQ/km) using a commercial
 leaded fuel (0.57  gplg)  containing both dichloroethane and dibromoethane as scavengers.
 Marklund et al. (1990)  attributed the  difference in the emission measurements of the 1987
and 1990 studies to  the different mix of scavengers used  in  the two studies, which may
have resulted in preferential formation of mixed chlorinated and brominated  dioxins and
furans.  Hagenmaier  et al.  (1990) reported TEQ emissions of 1,083 pg/L of fuel (or
approximately 108 pg TEQ/km) from a car fueled with a commercial leaded  fuel (lead
content not reported).  Bingham et al. (1989) reported emissions from four cars using
                                                             I

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                    '                 i                  '          "          J
 gasoline with a lead content of 1.7 gplg in New Zealand to range from 5 to 39 pg TEQ/km.
 The German study reported by Schwind et al. (1991) and Hutzinger et al. (1992) measured
 emissions of 52 to 1,184 pg TEQ/L (or approximately 5.2 to 118 pg TEQ/km) for cars
 under various simulated driving conditions. The tunnel study by Oehme et al. (1991)
 estimated that emissions from cars running primarily on leaded gasoline (i.e., 70 to 75
 percent of the cars) ranged from 3.8 to 520 pg Nordic TEQ/km.
       As shown in Table 4-4, the average emission factor reported for the tailpipe
 emission  studies performed using commercial leaded fuel (i.e., Marklund et al., 1990;
 Hagenmaier et al., 1990; and Schwind et al., 1991) is 457 pg TEQ/L (or 45.7 pg/km
 assuming an average fuel economy of 10  km/L).  A "low" confidence rating is assigned to
 this factor because it is based on European fuels and emission control technologies, which
 may have differed from U.S. leaded-fuels and engine technology, and also because the
 factor is based is based on tests with only nine cars.
       Combining the average emission factor developed above (45.7 pg TEQ/km) with the
 estimate for km driven by leaded fuel-powered vehicles in 1987  (708-billion km) suggests
 that 32.4 g TEQ/yr were emitted from vehicles using leaded fuels in 1987.  Based on the
 low confidence rating assigned to the emission factor estimate, the estimated range of
 potential emissions is assumed to have varied by a factor of 10 between the low and high
 ends of the range. Assuming that the mean estimate of emissions in 1987 (32.4 g TEQ/yr)
 is the geometric mean of the actual range, then the range is calculated to be 10.2 to 102 g
 TEQ/yr. Although there likely was minor use of unleaded fuel in  1995, further use of
 leaded fuel in motor vehicles for highway use in the United States was prohibited as of
 December 31, 1995 (Federal Register, 1985a).

       Unleaded Gasoline: The literature documenting results of European studies indicates
 that CDD/CDF emissions are less from vehicles burning unleaded fuels than are the
 emissions  from vehicles burning leaded gas with chlorinated scavengers. It also'appears,
 based on the limited data available, that catalyst-equipped cars have lower emission factors
than noncatalyst-equipped cars. Marklund et al. (1987) did not detect CDD/CDF in
emissions  from two catalyst-equipped cars running on unleaded gasoline at a detection limit
of 13 pg TEQ/km. Marklund et al. (1990)  reported emission factors of 0.36 and 0.39 pg
TEQ/km for two noncatalyst-equipped cars and an emission factor of 0.36 pg TEQ/km for
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                                                                           April 1998

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one catalyst-equipped car. Hagenmaier et al. (1990) reported an emission factor of 5.1 pg
TEQ/km for one noncatalyst-equipped car and 0.7 pg TEQ/km for one catalyst-equipped
car. Schwind et al. (1991) and Hutzinger et al. (1992) reported emission factors of 5.7 to
17.7 pg TEQ/km for several noncatalyst-equipped cars tested under various conditions; the
reported emission factor range for catalyst-equipped cars was 1.5 to 2.6 pg TEQ/knn.
       All automobiles running on unleaded gasoline in the United States are equipped with
catalysts. As shown in Table 4-6, the average emission  factor reported for the tailpipe
emission studies performed on catalyst-equipped cars (i.e., Hagenmaier et al. 1990;
Schwind et al., 1991; and Hutzinger et al., 1992) is 17 pg TEQ/L (or 1.7 pg TEQ/km
assuming  an average fuel economy of 10 km/L). A "low" confidence rating is assigned to
,,1   '..        ,  •"' 	  ' , ' "     ''         '   "'     h   ' ' i     '     	 n      • j   •
this emission factor because the European fuels and emission control technology used may
differ from current U.S. fuels and technology and also because the emission factor range is
based on tests with;only three catalyst-equipped cars.
       Combining the calculated mean emission factor of 1.7 pg TEQ/km with the estimate
derived above for vehicle km driven in 1995 by unleaded gasoline-powered vehicles (3,718
billion km) suggests that 6.3 g of TEQ were emitted from vehicles using unleaded fuels in
1995.  Based on the low  confidence rating for the emission factor, the estimated range of
potential annual emissions is assumed to vary by a factor of 10 between the low and high
ends of the range. Assuming that the mean estimate of  annual emissions (6.3 g TEQ/yr) is
the geometric mean of the actual range, the range is calculated to be 2.0 to 20 g TEQ/yr.
       Applying the same emission factor (1.7 pg/km) to the estimate derived above for
Vehicle km driven in 1987 by unleaded gasoline-powered vehicles (2,231 -billion km),
      •        ' 'ft,  '    ,    '"'"' 	 '• ' '.','''   ; :'    , '..' ', ;  ••''  .  , l"';"' '•'''.';'
Suggests that 3.8 g of TEQ may have emitted in 1987.  Assuming that this estimate is the
            '  ".;':"  •   •'     •.    ,  ,.   "   '"'•:•  !V ''     *., '.' '  ' • . I
geometric mean of the actual range yields a range of 1.2 to 12 g TEQ/yr.
                        ""'  '  ;  '        \                 '•:: •
      Diesel Fuel: Few data are available upon which to base an evaluation of the extent
of CDD/CDF emissions resulting from diesel fuel combustion.  The limited data available
address emissions only from on-road vehicles; no emissions data are available for off-road
diesel uses (i.e., construction vehicles, farm vehicles, arid stationary equipment). Two U.S.
tailpipe studies  are available:  CARB (1987a) and Gullett and Ryan (1997). CARB (1987a)
reported a relatively high  emission factor of 663 pg TEQ/km (not detected values assumed
to be zero) for one tested heavy-duty truck with a fuel economy at 50 km/hr of 5.5 km/L.

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                                :                    . \           .             ,  .
 Gullett and Ryan (1997) reported a range of emission, factors for one diesel truck tested on
 six highway or city driving routes, 3.0 to 96.8 pg TEQ/km (mean of 29.0 pg TEQ/km).
       The results of several tailpipe studies conducted  in Europe have also been published.
 Marklund et al. (1990) reported no emissions at a detection limit of 100 pg TEQ/L (or 18 pg
 TEQ/km assuming a fuel economy of 5.5 km/L) for one tested truck. Schwind et al. (1991)
 and Hutzinger et al.  (1992) reported emission factors of 32 to 81 pg TEQ/L (or 6 to 15 pg
 TEQ/km assuming a fuel economy of 5.5 km/L) for a truck engine run under various
 simulated driving conditions.  Hagenmaier (1994) reported no emissions from a bus  at a
 detection limit of 1  pg/L of fuel consumed for individual  congeners.  For diesel-fueled cars,
 Hagenmaier et al. (1990) reported an emission factor of 24 pg TEQ/L (or approximately 2.4
 pg TEQ/km) for one tested car. Schwind et al.  (1991) and Hutzinger et al. (1992) reported
 emission factors of 5 to 13 pg TEQ/km for a car engine  run under various simulated driving
 conditions.                                                           ..  "  "   .
       The tunnel study by Oehme et al. (1991) generated an estimated  mean emission
 factor of 5,100 pg TEQ/km and a range of 720 to 9,500 pg TEQ/km (in units of  Nordic
 TEQ) for diesel-fueled trucks.  Insufficient information was provided in Oehme et al.  (1991)
 to enable an exact calculation of  emission in units of I-TEQ. However, based on  the
 information that was provided, the mean emission factor in units of I-TEQ is approximately
 5,250 to 5,400 pg l-TEQ/km.  These indirectly estimated emission factors are considerably
 larger than those reported from engine studies by Marklund et al. (1990), Schwind et al.
 (1991), and Hutzinger et .a I. (1992);  the CARB (1987a) diesel  truck emission factor falls  at
the low end of the range. Although  aggregate samples were collected in this study
representing several thousand heavy duty diesel vehicles, several characteristics  of this
study introduce considerable uncertainty with regard to using the study's results  as  a basis
for estimating emissions in the United States. These factors include: (1) heavy-duty
vehicles comprised only 3 to 19 percent of total vehicle traffic in the tunnel; (2) the
majority of the light-duty vehicles were fueled with leaded gasoline the combustion of
which, as noted above in Table 4-4,  can release considerable amounts of CDD/CDFs; and
(3) technology differences likely existed between the 1988 Norwegian and the 1987 and
1995 U.S. vehicle fleets.
       The recent tunnel study conducted in Baltimore, Maryland, by Gertler et al. (1996;
1998) has the same disadvantages shared by all tunnel studies relative to tailpipe studies.

                                        4-13                                April 1998

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Specifically, tunnel studies rely on indirect measurements (rather than tailpipe
measurements), which may introduce unknown uncertainties, and the emission factors
calculated from these studies reflect driving conditions by the vehicle fleet using the tunnel
and not necessarily the overall vehicle fleet under other driving conditions. However, the
Gertler et al. (1996; 1998) study does have strengths lacking in the Oehme et al. (1991)
tunnel study. Also, the Gertler et al. (1996; 1998) study has benefits over the two U.S.
diesel truck taipipe studies. These include:  (1) the study is a recent study conducted in
the United St.ates and thus reflects current U.S. fuels and technology; (2) virtually no
vehicle using the tunnel used leaded gasoline; (3) the tunnel walls and streets were cleaned
1 week prior to the start of sampling and, in addition, the study analyzed  road dust and
determined that resuspended road dust contributed only about 4 percent of the estimated
emission factors;  (4)  heavy-duty vehicles comprised, on  average, a  relatively large
percentage (25.7  percent) of vehicles using the tunnel; and (5) a large number of heavy-
duty vehicles, approximately 33,000, passed through the tunnel during the sampling period,
which generates confidence that the emission factor is representative of interstate trucks.
      In consideration of the strengths and weaknesses of the available emission factor
data from the tailpipe and tunnel studies, the mean TEQ emission factor reported by Gertler
et al. (1996; 1998), 172 pg TEQ/km, is assumed to represent the best current estimate of
the average emission factor for on-road diesel-fueled trucks.  Because it may not be
        .      i	         ,    , ,         .        :  .       11
representative of emission rates for the entire fleet of diesel-fueled trucks under the wide
array of driving conditions encountered on the road, this emission factor is assigned a
"low" confidence rating.
      Combining the calculated  mean emission factor from Gertler et al.  (1996; 1998)
with the above estimate for vehicle kms driven in 1995 in the United States by diesel-
fueled trucks (195-billion km) suggests that 33.5 g of TEQ were emitted from trucks using
diesel fuel in 1995.  Based on the "low" confidence rating assigned to this emission factor,
the estimated range of potential annual emissions is assumed to vary by a factor of 10
between the low and  high ends of the range. Assuming that the mean estimate of annual
emissions (33.5 g TEQ/yr) is the  geometric mean of the  actual range, then the range is
calculated to be 10.6 to 106 g TEQ/yr.
      Combining the same emission factor (172 pg TEQ/km) to the estimate derived above
for vehicle km driven in 1987 by diesel-fueled trucks (153-billion km) suggests that: 26.3 g

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of TEQ were emitted from diesel-fueled trucks in 1987; the range is calculated (8.3 to 83.2
g TEQ/yr).

4.2.   WOOD COMBUSTION
       In 1995, wood fuel provided about 2.6 percent (or 2,350-trillion Btu) of the total
primary energy consumed in the United States (EIA, 19975). During 1987, wood energy
consumption is estimated to have been 2,437-trillion Btu, or 3.2 percent of, total primary
energy consumed (EIA, 1997b). The industrial sector is the largest consumer of wood fuel,
accounting for almost 72 percent of total wood fuel consumption in 1995 and 65 percent
in 1987. The residential sector accounted for 25 percent of consumption in 1995 and 35
percent in 1987.  The electric utility sector accounted for less than 1 percent of total
consumption in both years. There are no accurate sources to provide reliable estimates of
commercial wood energy use; consumption is thought to be between 20- and 40-trillion
Btu, or 2 to 4 percent of total wood consumption (EIA, 1994; EIA, 1997b).
       These energy consumption estimates, however, appear to include the energy value
of black liquor solids. Which are combusted in recovery boilers by wood pulp mills. In 1,987
and 1995, the energy value of combusted black liquor solids were 950-trillion Btu and
1,078-trillion Btu, respectively (American Paper Institute, 1992; American Forest & Paper
Association, 1997). Subtracting these black liquor energy value estimates from the
national totals for wood fuel yields 1,487-trillion Btu in 1987 and 1,272-trillion Btu in
1995.  Assuming that 1 kg of oven-dried wood (i.e., 2.15 kg of green wood) provides
approximately  19,000 Btu  (EIA, 1994), then an estimated 66.9-million and 78.3-million
metric tons of  oven-dried wood equivalents were burned for energy purposes in 1995 and
1987, respectively. Of these totals, an estimated 31.4-million metric tons and 44.8-million
metric tons were consumed by the residential sector in 1995 and 1987, respectively.  An
estimated 35.5-million metric tons and 33.5-million metric tons were consumed by the
industrial sector in 1995 and 1987, respectively.
      The  following two subsections discuss the results of relevant emission studies for
the residential and industrial sectors and present annual emission estimates.     -
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4.2.1. Residential Wood Combustion
               !             i  ''  ' '  I  . i|. ,         _     .            i
       The measurement of CDDs and CDFs jn chimney soot and bottom ash from wood-
burning stoves and fireplaces has been reported by several researchers (Bumb et al., 1980;
Nestrick and Lamparski,  1982 and 1983; Clement et al., 1985b; Bacher et al., 1992; Van
Oostam and Wprd, 1995; and Dumler-Gradl et al., 1995a).  Two studies have provided
direct measurement of CDD/CDFs in flue gas emissions from wood stoves (Schatowitz et
al., 1993; Vikelsoe et al., 1993). The findings of each of these studies are summarized in
the following paragraphs.
       Bumb et al. (1980) detected TCDDs (ND-0.4 /^g/kg), HxCDDs (0.2-3 ,ug/kg),
HpCDDs (0.7-16 /zg/kg), and  OCDD (0.9-25 /ug/kg) in residues from the wall  of one home
fireplace and from the firebrick of another home fireplace; for lack of a suitable analytical
method, analysis was not performed for PeCDDs. Neither of the fireplaces sampled by
Bumb et al. (1980) had burned preservative-treated  wood.
       Nestrick and Lamparski (1982; 1983)  expanded the research of Bumb et al. (1980)
by conducting a survey of CDD concentrations in chimney soot from residential wood-
burning units in three different rural areas of the  United States.  Samples were collected
from the base of six chimneys in each of the three study areas.  Results of a pilot study at
one residential chimney site had determined that this location provided the highest CDD
concentrations in soot.  Samples were not collected from units where any type of treated
or manufactured wood had been burned. For lack of a suitable analytical method, analysis
was not performed for PeCDDs. The results of this,survey are summarized in Table 4-9.
There was wide variation in the results across soot samples with standard deviations for
congeners and congener groups often equal to or exceeding the mean value; however,
CDDs in each congener group were detected in the soot from almost all sampled  units.
Nestrick and Lamparski (1982; 1983) concluded that the-results do not appear to present
any easily discernible patterns with respect to geographic region, furnace operational •
parameters, or wood fuel type. Nestrick and Lamparski (1982; 1983) attribute the wide
variability  observed to differences in design of the different  units, which affected the
sampling point and/or the conditions at the sampling point, and/or possible contamination
of the fuel wood.
       Clement et al. (1985b) analyzed chimney soot and bottom ash from residential
              ' • f   '       •  .    , • '  .'  ' .       .,•,•>  ;.  . 	'
woodstoves and fireplaces in Canada. The CDD/CDF congener concentrations are

                                       4-16                               April 1998

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presented in Table 4-9v (soot) arid Table 4-10  (bottom ash). CDD/CDF congeners were
detected in all samples analyzed, although the relative amounts of the different congener
groups varied considerably and inconsistently within the type of wood burning unit and
between ash and soot samples from the same unit.
       Bacher et al. (1992) characterized the  full spectrum (i.e., mono- through octa-
substitution) of chlorinated and brominated dibehzo-p-dioxin and dibenzofuran congeners in
the soot from an old farmhouse in southern Germany. The chimney carries smoke from an
oven that had used untreated wood at the rate of about 5 m3 per year for more than 10
 *                   .                   ,             • ,
years,  the sample was taken during the annual cleaning by a chimney sweep. The only
BDF detected was mono-BDF (230 ng/kg).  No BDDs, BCDDs, or BCDFs were detected at a
detection limit of 20 ng/kg. The results for the tetra- through octa- CDDs and CDFs are
presented in Table 4-9. The results indicate that CDFs dominate the CDDs in each
congener group except octa.  Also, the lower chlorinated congener groups dominate the
         >
higher chlorinated congener groups for both the CDDs and CDFs.  The TEQ content of the
chimney soot was 720 ng/kg of which less than 30 percent was due to CDDs.
      Van Oostdam and Ward' (1995) analyzed soot from two  wood stoves in British
Columbia, Canada, and found TEQ concentrations of 86 and 335 ng TEQ/kg. The
congener-specific results  are presented in Table 4-9.  The soot from a wood stove burning
salt-laden wood in a coastal area was found to have a TEQ content of 7,706 ng TEQ/kg or
20 to 90 times greater than the concentrations found in the soot from the^other two tested
stoves.          ..'-;•
      Dumler-Gradl et al. (1995a) analyzed chimney soot samples collected by chimney
sweeps from 188 residences in Bavaria. The  summary results of the survey, the largest
published survey of its kind to date, are presented in Table 4-11.  As was observed by
Nestrick and Lamparski (1982; 1983) and Clement et al. (1985b), CDD/CDFs were
detected in all samples; however,  there was wide variability in total TEQ concentrations
within and across unit type/fuel type combinations.
      Schatowitz et al. (1993) measured the CDD/CDF content of flue gas emissions from
several types of wood burners used in Switzerland: a household stove (6 kW), automatic
chip furnaces (110 to 1,800 kW), and a wood stick boiler (35 kW).  The emissions from
combustion of a variety of wood fuels were measured (natural beech wood, natural wood
chips, uncoated chipboard chips, waste wood chips from building  demolition, and

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household paper and plastic waste).  The results from the testing o.f the household stove
are most relevant for assessing releases from residential combustion. The household stove
was tested with the stove door both open and closed.  The open door stove can be
assumed to be representative of fireplaces because both have an uncontrolled draft.
Although the congener/congener group analytical results were not reported, the following
emission factors (dry weight for wood; wet weight for household waste) and emission rates
{corrected to 13 volume% oxygen) for the household stove were reported by Schatowitz et
al. (1993):

       • Open door burn of beech wood  sticks:   0.77 ng TEQ/kg  (0.064 ng TEQ/Nm3);
       • Closed door burn of beech wood sticks:  1.25 ng TEQ/kg ' (0.104 ng TEQ/Nm3);
                                              and
       • Closed door burn of household waste:   3,230 ng TEQ/kg (114.4 ng TEQ/Nm3).

       Vikelsoe et al. (1993) studied emissions of CDD/CDF congener groups from
residential wood stoves in Denmark. The wood fuels used in the experiments were
seasoned birch, beech, and spruce, equilibrated to 18 percent absolute moisture.  Four
different types of stoves (including one experimental stove) were evaluated under both
normal and optimal (i.e., well controlled with CO emission as low as possible) operating
conditions. Widely varying total CDD/CDF emissions were found for the 24 different
fuel/stove type/operating condition combinations.  The emissions from spruce were about
twice as high as the emissions from birch and beech. Surprisingly, the "optimal" operating
 •i!             ,':,'',„    « ' v  "„, '    ' '   '. ' ii     ' , ' •   ,."''"  '!'   ' i    •'
condition led to significantly higher CDD/CDF emissions for two stove types, but not for the
other  stoves. The predominant congener group for all experiments was TCDF. The
weighted average (considering wood and stove types) emission rate and emission factor for
wood stoves were reported to be 1.9 ng  Nordic-TEQ/kg and 0.18 ng Nordic-TEQ/Nrn3,
respectively.  Because Vickelsoe et al. (1993) did  not measure congener levels, the
reported emission factor and emission rate were estimated by assuming the same congener
distribution in each congener group that had been found for municipal waste incinerators.
       Based on the results reported by Schatowitz et al. (1993) and Vickelsoe et al.
               ., i     , ' ".,;" '':''; t -  / . , "i , :'  •/  ,  ••'.' '.','• .'' '  ;'   ' ''. ""'', ,     "        "     .  '  ',
(1993), 2 ng TEQ/kg appear to be a reasonable average emission factor for residential
               : ':          l! • • f '     ,   '•'•   ':.' :":''•   , •   *'  '•.','..    ' i   '   '
wood burning.  A "low"  confidence rating was assigned to this estimate on the basis that  it

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is derived from only two direct measurement studies.  Although the studies were
conducted in Europe, residential wood burning practices are probably sufficiently similar to
apply to the United States.
       In 1987, 22.5-million households in the United  States burned wood (EIA, 1991). Of
these households, wood was used in 1987 as the primary heating fuel in 5-million
households and as a secondary source for aesthetic purposes (i.e., fireplaces) in 17.4-
miilion  households (EIA, 1991; EIA, 1997b).  Lower numbers were reported fpr 1995;
wood was reported to be used as the primary fuel in 3.53-million households (EIA, 1997b).
More rural low-income households consume wood as a primary heating fuel than do other
sectors of the population. The majority of these households use wood-burning stoves as
the primary heating appliance. Although fireplaces are the most common type of wood-
burning equipment in the residential sector, only 7 percent of fireplace users report use of
fireplaces for heating an entire home (EIA, 1991; EIA,  1994).
       Residential wood consumption in 1995 was 596-trillion Btu (31.4-million metric
tons), or 25 percent of total U.S. wood energy consumption (EIA, T997b).  In 1987,
residential wood consumption was 852-trillion Btu (44.8-million metric tons), or 35 percent
of total U.S. consumption (EIA, 1997b). These production estimates are given "high"
confidence  ratings because they are based on recent government survey data.
       Combining the best estimate of the emission factor (2 ng TEQ/kg wood) wjth the
mass of wood consumed,by residences in the years 1995 and 1987 indicates that the
annual  TEQ air emissions from this source were approximately 62.8 grams in 199.5 and
89.6 grams in 1987.  Based on the "low"  confidence rating assigned to the emission
                                                                           \
factor,  the estimated range of potential annual emissions is assumed to vary by a factor of
10 between the low and high ends of the range. Assuming that the best estimate of
annual  emissions in 1995 (62.8 g TEQ/yr) is the geometric mean of this range, then the
range is calculated to be 19.8 to 198 g TEQ/yr.  For 1987, the range is calculated to be
28.3 to 283 g TEQ/yr.
                           (                          '              *

4.2.2.  Industrial Wood Combustion
       Congener-specific measurements of CDD/CDFs in stack emissions from industrial   '
wood-burning furnaces were measured by the California Air Resources Board at four
facilities in  1988 (CARB, 1990b; CARB, 1990e; CARB, 1990f; CARB, 1990g).

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                           •••'',.      .it .           «'•''.,       •            .   '  ,i
Measurements of CDD/CDF congener groups and 2,3,7,8-TCDD and 2,3,7,8-TGDF were
reported for one facility by EPA (U.S. EPA, 1987a). the National Council of the Paper
Industry for Air and Stream Improvement (NCASI) (1995) presented congener-specific
emission factors for five boilers tested during burns of bark/wood residue. The average
congener emission factors derived from the four CARS studies are presented in Table 4-12.
Congener and congener group profiles are presented in Figure 4-5.
      In GARB (1990b), CDD/CDFs were measured in the emissions from a quad-cell
wood-fired  boiler used to generate electricity. The fuel consisted of coarse wood waste
and sawdust from nonindustrial logging operations. The exhaust gas passed through a
multicyclone before entering the stack.  From this study, average emission factors for total
CDD/CDF and total TEQ are calculated to be 48.1 and 0.64 ng/kg of wood burned,
respectively.
      In CARB (1990e), CDD/CDFs were measured in the emissions from two spreader
stoker wood-fired boilers operated in parallel by an electric utility for generating electricity.
The exhaust gas stream from each boiler is passed through a dedicated ESP after which the
gas streams are combined and emitted to the atmosphere through a common stack.  Stack
tests were  conducted both when the facility burned fuels allowed by existing permits and
when the facility burned a mixture of permitted fuel supplemented  by urban wood waste at
a ratio of 70:30. From this study, average emission factors for total CDD/CDF and total
TEQ are calculated to be 29.2 and 0.82 ng/kg of wood burned, respectively.
      In CARB (1990f), CDD/CDFs were measured in the emissions from a twin  fluidized
bed combustors designed to burn wood  chips for the generation of electricity.  The air
pollution control device (APCD) system consisted of ammonia injection for controlling
nitrogen oxides, and a multiclone and  electrostatic precipitator for controlling paniculate
matter.  During testing, the facility burned wood wastes and  agricultural wastes allowed by
existing permits. From this study, average emission factors for total CDD/CDF and total
                                    1 '    '       '',.''   '  ' ' ' •     I • •
TEQ are calculated to be 47.9 and 1.32 ng/kg  of wood burned, respectively.
      In CARB (1990g), CDD/CDFs were measured in the emissions from a quad-cell
wood-fired  boiler. During testing, the fuel consisted of wood chips and bark.  The flue
gases passed through a multicyclone and an ESP before entering the stack.  From this
study, average emission factors for total CDD/CDF and total TEQ are calculated to be 27.4
and 0.50 ng/kg of wood burned, respectively.

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        The facility tested by EPA was located at a lumber products plant that manufactures
  overlay panels and other lumber wood products. The wood-fired boiler tested was a three-
  cell dutch oven equipped with a waste heat boiler.  The feed wood was a mixture of bark,
  hogged wood, and green and dry planar shavings. Nearly all the wood fed to the lumber
  plant had been stored in sea water adjacent to the facility and, therefore, had a significant  >
  concentration of inorganic chloride. The exhausted gases from the boiler passed through a
  cyclone and fabric filter prior to discharge from the stack.  From this study, an average
  emission  factor for total CDD/CDF of 1,020 ng/kg of wood burned (range: 552 to 1,410
  ng/kg) was reported. An average emission factor for TEQ of 17.1  ng/kg of wood burned
  (range: 7.34 to 22.8 ng/kg) was estimated by EPA using measured congener group
  concentrations and concentrations of 2,3,7,8-TCDD and 2,3,7,8-TCDF. These emission
  factors from the burning of salt wood are significantly higher than those measured in the
  four CARB studies.  This finding was consistent with the conclusion of NCASI (1995) that
  CDD/CDF emissions from facilities burning salt-laden wood residue may be considerably
  higher than from those burning salt-free wood.
        NCASI (1995) presented stack emission test results for five boilers burning bark or
  wood residues. One of these facilities, equipped with a multicyclone, normally burns bark
  in combination with  sludge and coal. One other facility, equipped with an ESP, normally
                                                  ;                           '
  fires pulverized coal. The other three facilities were spreader stokers equipped with
  multicyclones or ESPs.  Although stack gas flow rates were obtained during these tests,
  accurate  measurements of the  amounts of bark/wood fired were riot made and had to be
  estimated .by~ NCASI (1995) from steam production rates. The average TEQ emission factor
  for these facilities was 0.4 ng/kg of feed.
        The mean of  the emission factors derived from the four CARB studies, 0.82 ng
  TEQ/kg wood (assuming nondetected values are zero), is used in this report as most
  representative of industrial wood combustion.  The results of the EPA study were not used
  in the derivation of this mean emission factor because congener-specific measurements for
  most 2,3,7,8-substituted congeners were not made. Because congener-specific test data
  were available for these four facilities and because the mean TEQ emission factor derived
                                           -.              f           ..-,',      ,
  from these test data is very similar to that estimated by NCASI (1995) for five wood-fired
.. boilers, this emission factor was assigned a "medium" confidence rating.
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       It should be noted, however, that this emission factor (0.82 ng TEQ/kg wood) may
 not be an appropriate emission factor to apply to the combustion of waste wood containing
 elevated chlorine content. Umweltbundesamt (1996) reported the results of stack gas
 testing at approximately 30 facilities of varying design type as well as type of wood fuel
 combusted. Elevated CDD/CDF emissions were observed when the combustion conditions
 were poor, as evidenced by elevated carbon monoxide emissions, and/or when the fuel
 contained elevated chlorine levels. Umweltbundesamt (1996) attributed the correlation
                     i    '        '   . •    ••       •,'        , . •  '.      ;
 between elevated CDD/CDF emissions and elevated chlorine content of the fuel to the fire
               i'      ,''•'''   '"     ;    ,'; .  V .  • V • |;I  '' '        •'  !
 retardant effects of chlorine, which may have inhibited complete combustion.  The chlorine
 content of untreated  wood and bark were reported to range from 0.001 to 0.01 percent by
 weight and 0.01 to 0.02 percent by weight, respectively. Chipboard can contain up to 0.2
 percent chlorine by weight because of binding agents used to manufacture the chipboard.
 Preservative-treated wood and PVC-coated wood were reported to contain chlorine
 contents as high as 1.2 and 0.3 percent by weight, respectively.
               "''   ,    '.      ' '   •    ''"'   ' : • .'''   '•'.••'.'   ,        ',
      As discussed in Section 4.2, industrial wood consumption in 1995 totaled 35.5-
 million metric tons. The majority of wood fuel consumed in the industrial sector consists of
 wood waste (i.e., chips, bark, sawdust, and  hogged fuel).  Consumption in the industrial
 sector is dominated by two industries: the "Paper and Allied  Products" industry - SIC  26
 and the "Lumber and Wood Products" industry - SIC 24 (EIA, 1994). A similar amount,
 33.5-million metric tons, was burned for fuel in industrial furnaces in 1987 (EIA, 1994).
 These activity level estimates are assigned a "high" confidence rating because they are
 based on recent government survey data.
      Applying the average TEQ emission factor from the four CARB studies (0.82 ng
TEQ/kg wood) to the estimated quantities of wood burned by industrial facilities in 1995
 and 1987 yields estimated TEQ emissions to air of  29.1 g TEQ in 1995 and 27.5  g TEQ in
 1987. Based on the  "medium" confidence rating given to the TEQ emission factor, the
 estimated range of potential annual emissions is assumed to vary by a factor of five
 between the low and high ends of the range. Assuming that the estimates of annual
emissions to air for these 2 years are the geometric means of the respective ranges, then
the ranges are calculated to be 13.0 to 65.0 g TEQ in  1995 and 12.3 to 61.5 g TEQ in
 1987.
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 4.3.   OIL COMBUSTION
       Two major categories of fuel oil are burned by combustion sources:  distillate oils
 and residual oils. These oils are further distinguished by grade numbers, with Nos. 1 and 2
 being distillate oils; Nos. 5 and 6  being residual oils; and No. 4 either distillate oil or a
 mixture of distillate and residual oils.  No.  6 fuel oil is sometimes referred to as Bunker C.
 Distillate oils are more volatile and less viscous than residual oils.  They have negligible
 nitrogen and ash contents and usually contain less than 0-3 percent sulfur (by weight).
 Distillate oils are used  mainly in domestic and small commercial applications. Being more
 viscous and less volatile than distillate oils, the heavier residual oils (Nos. 5 and 6) must be
 heated for ease  of handling and to facilitate proper atomization. Because residual oils are
 produced  from the residue remaining after the lighter fractions (gasoline, kerosene, and
 distillate oils) are removed from the crude  oil, they contain significant quantities of ash,
 nitrogen, and sulfur. Residual oils are used mainly in utility, industrial, and large commercial
 application (U.S. EPA,  1995b).

 4.3.1. Residential/Commercial Oil Combustion
       No testing of the CDD/CDF content of air emissions from residential/commercial oil-
 fired combustion units in the United States could be located.  However, U.S. EPA (1997b)
 has estimated CDD/CDF congener group and TEQ emission factors based on average
 CDD/CDF concentrations reported for soot samples from 21 distillate fuel oil-fired furnaces
 used for central  heating in Canada, and a paniculate  emission factor for distillate fuel oil
 combustprs (300 mg/L of oil) obtained from AP-42 (U.S. EPA, 1995b).  The TEQ emission
 factor estimate in U.S. EPA (1997b) was derived using the calculated emission factors for
 2,3,7,8-TCDD, 2,3,7,8-TCDF, and the 10  congener groups. These emission factors are
 presented in Table 4-13/and the congener group profile is presented in Figure 4-6.
       Because there are no direct measurements of  CDD/CDF emissions in stack gases
 from U.S. residential oil-fired combustors and because of uncertainties associated with
 using chimney soot data to estimate stack emissions, no national emission estimates for
this category are proposed at this time.  However,,a preliminary order of magnitude
estimate of national TEQ emissions from this source category can be derived using the
emission factor presented in Table 4-13 (150 pg TEQ/L of  oil combusted). Distillate fuel oil
sales to the residential/commercial sector totaled 39.7 billion liters in 1995  (EIA,  1997a).

                                         4-23              _.'                 April 1998

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Application of the TEQ emission factor of 150 pg TEQ/L to this fuel oil sales estimate
results in estimated TEQ emissions of 6.0 g TEQ in 1995, which, when rounded to the
nearest order of rnagnitude to emphasize the uncertainty in this estimate, results in a value
of 10 g TEQ/yr. This estimate should be regarded as a preliminary indication of possible
emissions from this source category; further testing is needed to confirm the true
magnitude of the emissions.

4.3.2. Utility Sector and Industrial Oil Combustion
       Preliminary CDD/CDF emission factors for oil-fired utility boilers developed from
boiler tests conducted over the past several years are reported in U.S. EPA (1995c).  The
data are a composite of various furnace configurations  and APCD systems. Table 4-14 lists
the median emission factors  presented in U.S. EPA (1995c; 1997b).  The congener and
congener group profiles based on these data are presented in Figure 4-7. The median TEQ
emission factor was reported to be 314 pg/L of oil burned.
       In 1993, the Electric Power Research Institute (EPRI) sponsored a project to gather
information of consistent quality on power plant emissions. This project, the Field
Chemical Emissions Measurement (FCEM) project, included testing of two cold side ESP-
equipped oil-fired power plants for CDD/CDF emissions (EPRI, 1994).  The averages of the
congener and congener group emission factors reported for these two facilities are also
presented in Table 4-14.  The average TEQ emission factor is 95.5 pg/L of oil burned when
nondetected values are treated as zero (170 pg/L when nondetected values are treated as
one-half the detection limit).
       The TEQ emission factor reported in EPRI (1994) is a factor of three less than the
median TEQ emission factor  reported in U.S.  EPA (1 995c; 1997b).  For purposes of this
assessment, an emission factor of 200 pg/L (i.e.,  the average of 95.5 and 314 pg/L)  is
assumed to be current best estimate of the average TEQ emission factor for
utility/industrial oil burning. This estimate is assigned a "low" confidence rating.
       TEQ emission factors an order of magnitude larger were reported by Bremmer et al.
(1994), based on measurements of CDD/CDF emission  from three stationary used oil
combustion units and from a ferry fired  with a blend of used and virgin oil. Flue gases from
a garage stove consisting of  an atomizer fueled by spent lubricating oil from diesel  engines
            •'  ',V - •'      "' '.         ; • '•    ''   " '', .V- - ""  '  *' "       '
(35 mg ClVkg) were reported to contain 0.1  ng TEQ/Nnrr (or 2 ng TEQ/kg of oil burned).

                                        4-24                                April 1998

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 The flue gases from a hot water boiler consisting of a rotary cup burner fueled with the
 organic phase of rinse water from oil tanks (340 mg Cl'/kg) contained 0.2 ng TEQ/Nm3 (or
'4.8 ng TEQ/kg of oil burned). The flue gases from a steam boiler consisting of a rotary cup
 burner fueled by processed spent oil (240 mg ClVkg) contained 0.3 ng TEQ/Nm3 (or 6.0 ng
 TEQ/kg of oil burned).  The emission rate from the ferry (heavy fuel oil containing 11 ng/kg
 organic chlorine) was 3.2 to 6.5 ng TEQ/kg of oil burned.  From these data, Bremmer et al.
 (1994) derived an average emission factor for combustion of used oil of 4 ng TEQ/kg of oil
 burned.
       Bremmer et al. (1994) also reported measuring CDD/CDF emissions from a river
 barge and a container ship fueled with gas oil (less than 2 ng/kg of organic chlorine). The
 exhaust gases contained from 0.002 to 0.2 ng TEQ/Nm3.  From these data, Bremmer et al.
 (1994) derived an average emission factor for inland oil-fueled vessels of T ng; TEQ/kg oil
 burned.                        .
       Residual fuel oil sales totaled 46.6-billion liters  in 1995 and 77.3 billion liters in
 1987 (EIA, 1992; 1997a).  Vessel bunkering was the  largest consumer (48 percent of
 sales) followed by electric utilities and the industrial sector.  A "high" confidence rating is
 assigned to these production estimates.  Application of the TEQ emission factor of 200
 pg/L to these residual fuel oil sales results in estimated TEQ emissions of 9.3 g TEQ in
 1995 and 15.5 g TEQ in 1987. Based on the "low" confidence rating assigned to the
 ejnission factors, the estimated range of potential emissions is assumed to vary by a factor
 of 10 between the low and high ends of the range. Assuming that the estimate of TEQ
 emissions in 1995 (i.e., 9.3 g TEQ) is the geometric mean of the range, then the range is
 calculated to be 2.9 to 29 g TEQ/yr.  For the year 1987, the range is calculated to be 4.9
 to 49 g TEQ/yr.

 4.4.   COAL COMBUSTION
       During 1995, coal consumption accounted for approximately 22 percent of the
 energy consumed from all sources in the United  States (U.S. DOC, 1997).  In 1995, 872-
 million metric tons of coal were consumed in the United States.  Of this total, 88.4 percent
 (or 771-million metric tons) were consumed by electric utilities,  1 T.O percent (or 96-million
 metric tons) were consumed by the industrial sector (including consumption of 30 million
 metric tons by coke plants), and 0.6 percent (or 5.3-million metric tons) were consumed by

                                        4-25          ;       .              April 1998

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residential and commercial sources (EIA, 1997b). Comparable figures for 1987 are:  total
consumption, 759-million metric tons; consumption by electric utilities, 651-million metric
tons; consumption by coke plants, 33.5-million metric tons; consumption by other
industries, 68.2-million metric tons; and consumption by the residential and commercial
sectors, 6.3-million metric tons (EIA,  1995c).  These production estimates are assigned a
"high"  confidence rating because they are based on detailed studies specific to the United
States.
       The following two subsections discuss the results of relevant emission studies for
the utility/industrial and residential sectors and present annual emission estimates.

4.4.1.  Utilities and Industrial Boilers
       Until recently, few studies had been performed to measure CDD/CDF concentrations
in emissions from coal-fired plants, and  several of these studies did not have the congener
specificity and/or detection limits necessary to fully characterize this potential source (U.S.
EPA, 1987a; NATO,  1988; Wienecke et al., 1992).  Recently, the results of testing of coal-
fired utility and industrial boilers have been reported for facilities in The Netherlands, the
United Kingdom, and the United States.
       Bremmer et al. (1994) reported the results of emission measurements at two  coal-
fired facilities in The  Netherlands.  The emissjon rate from a pulverized coal electric power
plant equipped with an ESP and a wet scrubber for sulfur removal was reported as 0.02 ng
TEQ/Nm3 (at 11 percent O2) (or 0.35 ng TEQ/kg of coal fired).  The emission rate for a
grass drying chain  grate stoker equipped with a cyclone APCD was reported to be 0.16 ng
TEQ/Nm3 (at 11 percent O2) (or 1.6 ng  TEQ/kg of coal fired). Cains and Dyke (1994)
recently reported an emission rate of  102 to 109 ng TEQ/kg of coal at a  small-scale  facility
in the United Kingdom that was equipped with an APCD consisting only  of a grit arrester.
Umweltbundesamt (1996) reported that the TEQ content of stack gases from 16 coal-
burning facilities in Germany ranged from 0.0001 to 0.04 ng TEQ/m3; the data provided in
this report did  not enable emission factors to be calculated.
       The U.S. Department of Energy sponsored a project  in 1993 to assess emissions of
hazardous air pollutants at coal-fired  power plants.  As part of this project, CDD/CDF stack
emissions were measured at seven U.S. coal-fired power plants. The preliminary results of
this project (i.e., concentrations in stack emissions) were reported by Riggs et al. (1995)
               1 jr        |            f  , ,    ,        , •  ,      ,
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                              • -    '          '. y     •      "  -          -  ' •
and are summarized in Table 4-15. The levels reported for individual 2,3,7/8-substituted
congeners were typically not detected or very low (i.e., ^0.033 ng/Nm3).  In general, CDF
levels were higher than CDD levels.  OCDF and 2,3,7,8-TCDF were the most frequently
detected congenersl'(i.e., at four of the seven plants). Table 4-16 presents characteristics
of the fuel used and APCD employed at each plant. Variation in emissions between plants
                              !        ~                •
could riot be attributed by Riggs et al. (1995) to any specific fuel or operational
characteristic.
      During the early 1990s, EPRI also sponsored a project to gather information of
consistent quality on power plant emissions. This project, the Field Chemical Emissions
Measurement (FCEM) project,.included testing of four cold-side ESP-equipped coal-fired
power plants for CDD/CDF emissions. Two plants burned bituminous coal and two burned
subbituminous coal. The final results of the DOE project discussed above were integrated
with the results of the EPRI testing and published in 1994 (EPRI, 1994).  The average
congener and congener group emission factors derived from this 11 facility data set, as
reported in EPRI (1994), are presented in Table 4-17. Congener and congener group
profiles for the data set are presented in Figure 4-8. The average TEQ emission factor,
assuming nondetected values are zero, is 0.087 ng/kg of coal combusted. The average
TEQ emission rate, assuming  nondetected values are one-half the detection limit, is 0.136
ng/kg of coal combusted.  A "medium" confidence rating is assigned to these emission
factors because they are based on recent testing at U.S. facilties.
      As stated above, consumption of coal by the U.S. utility and industrial sectors
(excluding consumption at coke  plants) was 837-million metric tons in 1995  and 719-
million metric tons in 1987. Applying the TEQ emission factor of 0.087 ng TEQ/kg of coal'
combusted to these production factors yields estimated annual emissions of 72.8 g TEQ in
1995 and 62.6 g TEQ in 1987.
      Based on the "medium" confidence rating assigned to the estimated TEQ emission
factor, the estimated range of potential emissions is assumed to vary by a factor of five
between the low and high ends of the range; Assuming that the estimated emissions
(assuming nondetected values are zero) of 72.8 g TEQ in 1995 and 62.6  g TEQ in 1987
are the geometric means of these ranges for these years, then the ranges are calculated to
be 32.6 to 163 g TEQ in 1995 and 28 to 140 g TEQ in 1987.
                                       4-27              •-  •     "    '     April 1998

-------
                         DRAFT-DO NOT QUOTE OR CITE

4.4.2. Residential/Commercial Coal Combustion
       Coal is usually combusted in underfeed or hand-stoked furnaces in the residential
sector.  Other coal-fired heating units include hand-fed room heaters, metal stoves, and
metal and masonry fireplaces.  Stoker-fed units are the most  common design for warm-air
furnaces and for boilers used for steam or hot water production. Most coal combusted in
these units are either bituminous or anthracite. These units operate at relatively low
temperatures and do not efficiently combust the coal.  Coal generally contains small
quantities of chlorine and CDD/CDF; therefore, the potential for CDD/CDF formation exists.
Typically, coal-fired  residential furnaces are not equipped with particulate matter or gaseous
pollutant control devices that may limit emissions  of any CDD/CDFs formed (U.S. EPA,
I997b).  No testing of the CDD/CDF content of air emissions from residential/commercial
coal-fired combustion units in the United States could be located.  However, several
relevant studies have been performed in European countries.
       Thub et al. (1995} measured flue gas concentrations of CDD/CDF from a household
heating system in Germany, fired either with "salt" lignite coal (i.e., total chlorine content
of 2,000 ppm) or "normal" lignite coal (i.e., total chlorine content of 306 ppm).  CDD/CDFs
were detected in the flue gases generated by combustion of both fuel types. (See
Table 4-18.) The congener profiles and patterns were similar for both fuel types, with
OCDD the dominant congener and TCDF the dominant congener group.  However, the
emissions were higher for the  "salt" coal  (0.109 ng TEQ/m3 or 2.74 ng TEQ/kg of coal) by
a factor of eight than for the "normal" coal  (0.015 ng TEQ/m3 or 0.34 ng TEQ/kg of coal).
                              1 '  ' i,    '             ' •    "j! ,;  '   •  :      '   '
       Eduljee and Dyke (1996) used the results of testing performed  by the Coal Research
Establishment in the United Kingdom to estimate emission factors for  residential coal
combustion units as follows:
       •  Anthracite coal:  2.1 ng TEQ/kg of coal;  and
       •  Bituminous coal: 5.7 to 9.3 ng TEQ/kg of coal (midpoint of  7.5 ng TEQ/kg).
                 ni             i  ;       •  _,.    ,,  „    ,• .. '" ,.i'i ii ,'„'.,';
       CDD/CDF emission factors for coal-fired residential furnaces were estimated in U.S.
EPA (1997b) based  on average particulate CDD/CDF concentrations from chimney soot
              	I1 i  '            ,      .    '•': ''•'.' ','.'.  '  ;•!": '   i   J.    ' , •
samples collected from seven coal ovens, and particulate matter emission factors specific
to anthracite and bituminous coal combustion obtained from AP-42 (U.S. EPA, 1995b).
The TEQ emission factors estimated in U.S. EPA (1997b) (i.e., 68.0 and 98.5 ng TEQ/kg of
anthracite and bituminous coal,  respectively) were derived using the calculated emission

                                        4-28                                April 1998

-------
                         DRAFT.-DO NOT QUOTE OR CITE

factors for 2,3,7,8-TCDD 2,3,7,8-TCDF, and the 10 congener groups.  U.S. EPA (1997b)
stated that the estimated factors should be considered to represent maximum emission
factors, because soot may not be .representative of the paniculate matter actually  emitted
to the atmosphere. These emission factors are presented in Table 4-18, and congener
group profiles are presented in Figure 4-9.
      Although the congener group profiles of the Thub et al. (1995) measurements and
the U.S. EPA (1997b) estimates are similar, the TEQ emission factors differ by factors of
175 to 289 between the two studies. The emission factors used by  Eduljee and Dyke
(1996) to estimate national annual emissions of GDD/CDF TEQs from residential coal
combustion in the United Kingdom fall in between those other two sets of estimates but
are still about one to two orders of magnitude greater than the estimated emissions factor
from industrial/utility coal combustors.
      Because there are no direct measurements of CDD/CDF emissions from U.S.
residential coal-fired combustors and because of uncertainties regarding the comparability
of U.S. and German and British coal and combustion units, no national emission estimate
for this category is proposed at this time.  However, a preliminary order of magnitude
estimate of national TEQ emissions from this source category can be derived using the
emission factors of Eduljee and Dyke (1996).  As noted above,  5.3 million metric tons of
coal were consumed by the residential/commercial sector in 1995 (U.S. DOC, 1997). U.S.
EPA (i 997b) reports that 72.5 percent pf the coal consumed by the residential sector in
                                                                       -j         •
1990 were bituminous and 27.5 percent were anthracite. Assuming that these relative
proportions reflect the actual usage in 1995, then application of the emission factors from
Eduljee and Dyke (1996) (i.e., 2.1 ng TEQ/kg of anthracite coal and 7.5 ng TEQ/kg of
bituminous coal) to the consumption value of, 5.3-million metric tons  results in an estimated
TEQ emission of 32.0 g TEQ in 1995, which,, when rounded to the nearest order of
magnitude to emphasize the uncertainty in this estimate, results jn.a  value of 10 g TEQ/yr.
This estimate should be regarded as a preliminary indication of possible emissions  from this
source category; further testing is needed to confirm the true magnitude of these
emissions.                           ,
                                        4-29                   '            April 1998

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                               DRAFT-DO NOT QUOTE OR CITE
          2,3.7,B-TCD1>
       1,2,3.7.8-plcDD
     l,2,3.4,7.8-Hx:CDD
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     1.2.3.4.7.8-HxCDF
     X.2.3.0.7.»-rixCDF
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   1.2.3.-4.O.7.B.O-OCDF
Ratio Ccono«n«r
  O.O5        O.I
                                                         n {actor / total ODD/CDF* •mission factor)'
                                                         O.15         O.2         O.2S         O.3
                                                                                                        0.35
                       Ratio (congener group emission factor / total CDD/CDF emission factor)
                   0.05           0.1           0.15           0.2           0.25           0.3
                                                                       0.35
                                            I Cars      li:...v •:.:.! Trucks
      N»u »«u4 u pr.nl4j ulenUud from raUjion Oeton (ND - 1/2 DL) from T>blu 4-2 ud 4-3.
Figure 4-1.  Congener and Congener Group Profiles for Air Emissions from Diesel-fueled Vehicles
                                                  4-36
                                                                  April 1998

-------
                              DRAFT-DO NOT QUOTE OR CITE
                                    Ratio (congener emission factor / total CDD/CDF emission factor)
                                        O.O1              O.O2             O.O3             O.O4 ,
                                                                                                              0.05
         2,3,7,8-TCDD
       1,2.3.7,8-PeCDD
    1,2,3,4,7,8-HxCDD
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    1,2.3 ,7,8,9-HxCDE>
  1,2,3,4,6,7,8-HpCDD
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       2,3 ,4,,7,8-PeCDF
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     1,2,3,6,7,8-HxCDF
     1.2.3,7,8.9-HxCDF
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  1.2,3,4,6,7,8,9-OCDF
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                    O.I               O.2               O.3          _     O.4               O.S
                                                                                                              O.6.
        i«d on pt»fil«M ••brauud from MBUatoB Awtan 
-------
                             DRAFT-DO NOT QUOTE OR CITE
                                   Ratio (congener emission factor / total CDD/CDF emission factor)
                                 O.O5        O.I        O.1S        0.2        O.2S         O.3
          2.3,7.8-TCDD
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     1,2,3,7,8.9-HxCDD
   1 ,2,3.4,6,7,8-apCDD
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        2,3,4.7.8-PeCDF
     1 ,2^.4,7,8-MxCDF
     1 ,2,3.6.7,8-HxCDF
     1,2^.7.8.9-HxCDF
     2,3,4,«.7.8-MxCDF
    1 ,2.3 ,4.6,7.8-HpCDF
    J Jt.3,4.7,8,9-iipCDF
   1^,3,4,6,7.8,9-OCDF
  Ratio (congener group emission factor / total CDD/CDF emission factor)
      0            O.OS           0.1           0.15           O.2           0.25
                                                                                          0.3
                                                                                                       0.35
                                       deaiUUOom Tabu,«.
Figure 4-3. Congener and Congener Group Profiles for Air Emissions from Unleaded Gas-fueled Vehicles
                                                 4-38
* A 998

-------
                              DRAFT-DO NOT QUOTE OR CITE
                             Table 4-7.  European Tunnel Study Test Results



Congener/Congener Group

2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1 ,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
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1 ,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF

Tunnel iAir
Germany
(Ref. A)
(pg/m3)
ND (0.01)
0.31
0.37
1.1,9
Q.44
1.9
6.3
6.17
0.40
0.19
0.26
0.16
ND (0.04)
0.12
1.2
ND(0.16)
ND(1.3)
. 10.51
2.50
0.58
0.23
2.5
7.8 ,
3.4
6.3
3.5
3.6
2.0
1.9 ,
ND(1.3)
31.2

Tunnel Air
Germany
(Ref . A)
(pg/m3)
0,06
0.28
ND(0.17)
0.66
ND(0.17)
2.0
6.4
0.72
0.36
NR
0.13
0.15
ND (0.05)
ND (0.05)
0.98
ND (0.17)
ND (1.0)
9.40
2.34
0.42
0.22
1.3
2.7
3.4
6.4
6.2
4.1
1.1
,1.2
ND(1.0)
26.6

Tunnel Air
Belgium
. (Ref.B)
(pg/mS)
0.002
0.025
0.025
0.042
0.030
0.468
2.190
0.013
0.143
0.039
0:073
0.093
0.143
0.004
0.499
0.074
0.250
2.782
1.330
0.096
NR
NR
NR
NR
/.MR
NR
NR
NR
NR
NR
NR
Tunnel Air
Norway
(workdays)3
1 (Ref/C)
(pg/m3)
0.02 '
0.18
0.06
0.29
0.25
1.41
0.10
0.58 .
0.83
0.78
0.79
0.62
0.04
0.74
1.78 '.
0.22
1.62
2.31
' 7.98
0.91
0.26
1.78
1.32
1.31
0.10
13.20
10.17
6.42 ,
2.62
1.62
38.80
Tunnel Air
Norway
(weekend)3
(Ref. C)
(pg/m3)
0.02
0.04
0.03
,, 0.03
0.06
0.16
0.50
0.07
0.75
0.58
0.34
0.31
0.03
0.13
0.93
0.14
2.54
0.84
5.82
0.48
0.16
0.41
0.12 .
0.23
0.50
1 .70
7.91
,2.08
1.41
2.54
17.06
ND = Not detected; value Fn parentheses is the detection limit.
                                                           /                       ' "~
Ref. A: Rappe et al. (1988)
Ref. B: Wevers et al. (1992)
Ref. C:Oehmeetal. (1991)                                        "..-....'''

3   Listed values are the differences between the concentrations at the inlet and outlet of the northbound tunnel
    lanes.                        ,    -                                             ,
                                               4-39
                                                                                          April 1998

-------

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                            DRAFT-DO NOT QUOTE OR CITE
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                         4   5   ,6   7   8   ,9   10  11   12   13  14   15  16   1-7
                                           Congener Number
       I Norway (Row 1)
                                  Germany (Row 2)
Germany (Row 3)
     • Belgium (Row 4)            •• Baltimore, USA (Row 5)

      Congener numbers refer to the congeners in order as listed in Table 4-7.
                             Figure 4-4.  Tunnel Air Concentrations
                                             4-41
                                                                                    April 1998'

-------
                                    DRAFT-DO NOT QUOTE OR CITE
                Table 4-9.  CDD/CDF Concentrations in Residential Chimney Soot from Wood Stoves and Fireplaces


Congener/Congener
Group
2,3,7,8-TCDD
1,2,3,7.8-PaCDD
1,2,3,4.7,8-HxCDD
1,2,3,6.7,8-HxCDD
1,2,3.7,8,9-HxCDD
1,2.3,4,6,7,8-HpCDD
OCDD
2.3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7.8-PeCDF
1,2,3,4,7,8-HxCDF
1. 2,3,6, 7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
U.S. East
Region
(Ref. A)
(ng/kg)
66
NR
250*
250*
208
1,143
2,033
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
3,450
NR
126
1,987
NR
2,183
2,104
2,033
NR
NR
NR
NR
NR
8,307
U.S. West
Region
(Ref. A)
(ng/kg)
13.3
NR
522*
522*
282
1,653
2,227
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
4,175
NR
112
269
NR
4,273
3,243
2,227
NR
NR
NR
NR
NR
10,012
U.S. Central
Region
(Ref. A)
(ng/kg)
66
NR
1,831*
1,831*
1,450
6,160
13,761
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
21,437
NR
459
1,511
NR
14,243
12,603
13,761
NR
NR
NR
NR
NR
42,118
German
Farmhouse
1 (Ref. B)
(ng/kg)
150
70
35
60
30
90
90
930
560
590
330
400
70
200
490
40
70
525
3,680
720
3,900
880
600
200
90
13,400
6,100
3,200
720
70
29,160
Canadian
Wood Stove
(Ref. C)
(ng/kg)
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
ND (10)
ND (10)
ND (50)
100
200
ND (10)
ND (10)
ND (50)
ND (50)
ND (50)
300
Canadian
Fireplace
(Ref. C)
(ng/kg)
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
• NR
NR
NR
NR
ND (10)
500
1,700
500
400
300
1,400
1,700
400
100
7,000
Canadian
Wood Stove
(Ref. D)
(ng/kg)
ND (12)
70
ND (10)
625
281
948
530
235
58
68
51
57
8
24
97
20
41
2,454
659
211
11
608
3,450
1,550
530
1,010
948
482
154
41
8,783
NR « Not reported.
*  x Analytical method could not distinguish between congeners; listed value is the sum of both congeners.

Ref. A: Nestrick and Lamparski (1982; 1983); mean values listed - six samples collected in each Region.
Ref. B.-Bacher et al. (1992)
Rof.C: Clement etal. (1985b)                                                              '
Ref. D: Van Oostdam and Ward (1995); mean of two samples - nondetected values assumed to be zero.
                                                       4-42
April A 998

-------
                              DRAFT-DO NOT QUOTE OR CITE
     Table 4-10.  CDD/CDF Concentrations in Residential Bottom Ash from Wood Stoves and Fireplaces



Congener/Congener Group
2,3,7,8-TCDD
1^,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpGDD
OCDD
2,3,7,8-TCDF
1 ,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
,1,2,3,4,7,8-HxCDF
1 ,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF .
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
Canadian
Wood Stove
(Ref. A)
(ng/kg)
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
ND (10)
ND (10)
ND (5.0)
300
2,600
9,100
2,200
1 ,000
700
ND (50)
15,900
.Canadian
Wood Stove
{Ref. A)
(ng/kg)
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
100
3,000
10,000
1,200
900
400
4,600
9,300
1,000
100
30,600
Canadian
Wood Stove
(Ref. A)
(ng/kg)
NR
NR
NR
NR
NR
NR
NR
NR
, NR
NR
NR
NR
NR
NR
NR
NR
' NR
NR
NR
NR
100
200
700
500
100
100
200
500
300
ND (50)
2,700
Canadian
Fireplace
(Ref. A)
(ng/kg)
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
ND (10)
Nd (10)
300
2,000
3,100
ND (10)
ND (10)
100
400
100
6,000
NR  = Not reported.
Ref. A: Clement et al. (1985b)
                                             4-43
                                                                                   April 1998

-------
                             DRAFT-DO NOT QUOTE OR CITE
                 Table 4-11. CDD/CDF Concentrations in Chimney Soot (Bavaria, Germany)
Unit Type
Oven
Tiled Stove
Heating System
Oven
Tiled Stove
Oven
Fuel Type
Wood
Wood
Wood
Wood/coal
Wood/coal
Wood, wood/coal,
waste
Number of
Samples
33
39
9
27
5
5
CDD/CDF Concentrations in Soot 
-------
                          DRAFT-DO NOT QUOTE OR CITE
           Table 4-12. CDD/CDF Emission Factors for Industrial Wood Combustors
•

Congener

2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1, 2,3,4,7, 8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7, 8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF -
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total TEQ
Total CDD/CDF -
Four facilities tested by CARB
Mean Emission Factors {ng/kg wood)
Nondetects
Set to
Zero
0.007
0.044
0.042
0.086
0.079
0.902
6.026
0.673
0.790
0.741
0.761
0.941
0.343
0.450
2.508
0.260
1.587
0.151
1.039
1 .748
2.936
6.026
4.275
9.750
7.428
3.747
1.588
0.82
38.69
_ Nondetects
Set to
1/2 Det. Limit
0.016
0.054
0.055
0.096
0.132
0.905
6.026
0.672
0.79d
0.741
0.768
0.941
0.350
0.491
2.749
0.344
1.590
0.154
1.039
1.748
2.936
6.026
4.275
9.750
7.428
3.988 .
1 .590
0.85
38.93
Sources: CARB (1990b); CARB (1990e); CARB (1990f); CARB (1990g)
                                       4-45
                                                                        April 1998

-------
                                 DRAFT-DO NOT QUOTE OR CITE
                                     Ratio (congener emission factor / total CUD/CDF emission factor)
                                                   O.OS                        O.I
                                                                                                          0.15
           2,3,7,8-TCDI>
        1.2,3.7,8-PeCDD
      1.2,3.4.7,8-HxCDD
      1.2,3,6,7.8-HxCr>E>
      1,2,3,7,8,9-HxCDD
    1.2.3,4.6,7,8-HpCDD
    l,2,3,4,6.7,8,9-6cbD
           2,3.7,8->T<::DF
        1.2.3,7.8-PcCDF
        2,3,4,7.8-PcCDF
      1.2,3,4.7.8-HxCDF
                  „  il,!"  " i
      1.2.3,6,7.8-HxCDF
      1,2.3.7,8,9-HxCDF
      2.3,4.6,7.8-HxCDF
    1.2,3,4.6,7,8-HpCDF
    1,2 ,3 !4,7,8.9-HpCDF
                      Ratio (mean congener group emission factor / total CDD/CDF emission factor)
                      O.OS             0.1              O.15              O.2             O.25
                                                                                                           O.3
Figure 4-5.  Congener and Congener Group Profiles for Air Emissions from Industrial Wood Combustors
                                                   4-46
                                                                                                AprU 1998

-------
                              DRAFT-DO NOT QUOTE OR CITE
           Table 4-13. Estimated CDD/CDF Emission Factors for Oil-Fired Residential Furnaces
Congener/Congener Group
2,3,7,8-TCDD
1 ,2,3,7,8-PeCDD
1 ,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF .
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF '
Total 2,3,7,8-CDD •
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
.Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF <
. Mean Facility
Emission Factor
(pg/Loil)
56
NR
NR
NR -
NR
NR
66
53
NR
NR
NR
NR
NR
NR
NR
NR
30
NR
NR
150
139
82
66
63
66
663
420
170
73
30
1,772
Source: U.S. EPA (19,97b)




NR  = Not reported.
                                              4-47
April 1998

-------
0
                       DRAFT-DO NOT QUOTE OR CITE
Ratio (congener group emission factor / total CDD/CDF emission factor)
      0.1                    0.2                    0.3
                                                                                        0.4
  Source: U-S, EPA (1995c)
 Figure 4-6. Congener Group Profile for Air Emissions from Residential Oil-fueled Furnaces
                                        4-48
                                                               April 1998

-------
                               DRAFT-DO NOT QUOTE OR CITE
               Table 4-14.  CDD/CDF Emission Factors for Oil-Fired Utility/Industrial Boilers

J *

Congener/Congener .Group
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1 ,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
U.S. EPA,(1997b)
Median
Emission Factor
(pg/L oil)
117
104
215
97
149
359
413
83
77
86
109
68
104
86
169
179
179
1 ,453
1,141
314
102
104
145
359
413
90
131
172
27
179
1,722
EPRI (1994)
Mean Emission Factor

ND = zero
(pg/L oil)
0
24.7
63.3
65.8
79.7
477
2055
- 0
64.1
49.3
76.5
35.4
0
23.8
1 64
0
0
2,766
414
95.5
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
3,179

ND = 1/2 DL
(pg/L oil)
26.6
43.1
108
79.3
102
546
2141
35.7
73.9
59.6
94.9
45.2
37.7
42.2
218
137
139
3,047
883
170
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
3,931
Sources:
       U.S. EPA (1997b) - number of facilities not reported.
       EPRI (1994) - based on two cold side ESP-equipped power plants.

Note: Assumes a density for residual fuel oil of 0.87 kg/L.
                                               4-49
April 1998

-------
                                DRAFT-DO NOT QUOTE OR CITE
                     X%.*tio Factor Ccongeoer emission factor / total GDD/GI>F emission
                        O              O.OS              0.1             O.1S
          2.3.-7.S-TCDr>
       I.2,3.7.8-I>oCE>D
     1.2.3.6.7.8-HXCDD
               n    i|
     1.2.3.7.B.S>-Hx:CDr>
          2.3.7.B-TCDP
        1.2.3.7.»-PcCDF
        2.3,4.7.m-PeCr>F
     1 .2.3 .4.7.B-H3CCDF
     1,2,3.6.7.8-HxCDF
     1 ,2.3.7.S.S>-Hx:CDF
     2.3,-«.
-------




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                          DRAFT-DO NOT QUOTE OR CITE
           Table 4-16.  Characteristics of U.S. Coal-Fired Power Plants Tested by DOE
Plant
No.
1
2
3
4
5
6
7
Coal Type
Bituminous
Bituminous
Subbituminous
Subbituminous
Bituminous
Lignite
Bituminous
Coal
Chlorine
Content
(mg/kg)
800
1,400
300
390
1,400
400
r,ooo
Temperature (°C) at:
Pollution Control Device3
ESP
160
130
	
„
130
170
150
Bag
-_
™
150
70
	
. 	
—
FGD
—
—
	
130
120
170
—
Stack
160
130
150
75
40
110
150
8 ESP = Electrostatic precipitator. Bag = Baghouse, FGD = Flue gas desulfurization system.



Source:  Riggs et al.  (1995).
                                          4-52
ApvU A 998

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                           DRAFT-DO NOT QUOTE OR CITE
       Table 4-17. CDD/CDF Emission Factors for Coal-Fired Utility/Industrial Power Plants
. .
Congener/Congener Group
2,3,7,8-TCDD
1 ,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1 ,2,3,4,6,7,8-HpCDD ;
OCDD ,
2,3,7,8-TCDF
1 ,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF ,
1 ,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD ,
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF -
Total HpCDF
Total OCDF
Total CDD/CDF
Mean Emission Factor
ND = zero
(ng/kg coal)
0.007
0
0
0.005
0.005
0.216
0.517
0.109
0.008 ,
0.075
0.110
0.016
0.015
0.054
0.354
0.097
0.159
0.750
0.997
0.087
0.076
0.027
0.060
0.106
0.517
0.230
0.347
0.209
0.127
0.159
1.86

ND = 1/2 DL
(ng/kg coal)
0.020
0.018
0.038
0.031
0.039
0.241
, 0.648
0.117
0.025
0.085
• 0.136
0.031
0.043
0.075
0.385
0.126
' 0.281
1.035
1 .304 ,
0.136
0.078
0.029
0.060
0.120
0.648
0.250
0.223
0.209
0.133
0.281
2.03
Source: EPRI (1994) - 11 facility data set.
                                           4-53
April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
                               Ratio (congener emission factor / total CDD/CDF emission factor)
                           O.O1     O.OZ      O.O3     O.O4     O.OS     O.O6     O.O7     O.O8
     O.O9
       2,3.7.8-TCDD
    1,2.3,7.8-PeCDD
  1 ,2,3 ,4.7.8-fixCDr>
  I ^,3,6,7,8-HxCDD
  1.2.3.7,B,9-HxCr>D
 1,2,3,4.6.7.8-HpCDD
I,2,3,4,6.7.8.£-OCt>l>
       2,3.7.8-TCDF
    1,2.3,7.8-PeCDF
    2,3,4,7,8-PeCDF
   1.2,3,4.7.8-HxCDF
   145,3 ,6,7,8-HxCDF
  2,3 ,4,6,7.«-HxCbF
 1 ^^,4,6,7.8-HpCDF
 1 .2,3.4,7.8.9-iHpCDF
                    Ratio (congener croup emission factor / total CDD/CDF emission factor)  >
                0.05           0.1           0.15          0.2          0.25          0.3
      0.35
           Figure 4-8.  Congener and Congener Group Profiles for Air Emissions
                       from Industrial/Utility Coal-fueled Combustors
                                             4-54
April 1998

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                             DRAFT-DO NOT QUOTE OR CITE
                Table 4-18.  CDD/CDF Emission Factors from Residential Coal Combustors


Congener/Congener Group
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1 ,2,3,6,7,8-HxCDD
i,2;3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF .
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
total HXCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF '
"Salt" Lignite
Ref . A
(ng/kg coal)
0.58
0.73
0.63
0.60
0,40
3^24
16.19
2.49
2.24
2.09
0.38
1 .86
0:07
1:01
2.59
0.25
0.63
22.37
13.60
2,74
14.23
14.15
11,14
7.06
16.19
80.34
29.21
12.72
3.87
0.63
189.5
"Normal" Lignite
Ref. A
(ng/kg coal)
0.06
0.08
0.06
0.09
0.06
0.59
2.42
0.50
0.43
0.31
0.13
0.36
0.02
0.12
0.95
0.06
0.30
3.38
3.20
0.34
9.00
2.22
1.81
0.82
2.42
20.33
8.98 .
3.78
1.27
0.30
50.93
Anthracite
Ref. B
(ng/kg coal)
1.60
NR
, NR
NR
~NR
NR
77
42.0
NR
NR
NR
NR
NR
• NR
NR
NR
4.2
NR
NR
60.0
61.6
31
60
57
77
412
340
130
32
4.2
1,205
Bituminous
Ref. B
(ng/kg coal)
2.40
NR
NR
NR
NR
NR
120
63.0
NR
NR
- NR
NR
NR
NR
NR
NR
6.3
NR
NR
98.5
92.4
46
90 '
86
120
613
550
190 -
47
6.3
1,841
Sources:        Ref A:   Thub et al. (1995); listed results represent means of three flue gas samples.
               Ref B:   U.S. EPA (1997b); based on average particufate CDD/CDF concentrations from chimney
                       soot  samples collected from seven coal  ovens and particulate emission factors for
                       anthracite and bituminous coal combustion.

NR  = not reported.
                                               4-55
April 1998.

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                        DRAFT-DO NOT QUOTE OR CITE
                   Ratio (congenergroup emission factor/total CDD/CDF emission factor)
                        0.1                   0.2                  0.3
                                      0.4
             I Anthracite (U.S. EPA, 1997b)
Bituminous (U.S. EPA, 1997b)
Figure 4-9.  Congener Group Profile for Air Emissions from Residential Coal-fueled Combustors
                                          4-56
                                 April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

    5.  COMBUSTION SOURCES OF CDD/CDF:  OTHER HIGH TEMPERATURE SOURCES

5.1.   CEMENT KILNS
       This section addresses CDD/CDF emissions from Portland cement kilns. These
facilities use high temperature to convert mineral feed stocks into Portland cement and
other types of construction materials. For purposes of this analysis, cement kilns have
been subdivided into two categories:  those that burn hazardous waste and those that do
not.  Lightweight aggregate kilns are not addressed in this report. The following sections
describe cement kiln technology, review the derivation of TEQ emission factors for cement
kilns that do burn and do not burn hazardous waste as supplemental fuel, and derive annual
TEQ air emissions (g/yr) for 1995 and 1987.

5.1.1.  Process Description of Portland Cement Kilns
       In the United States,  the primary cement product is called Portland cement.
Portland cement is a fine, grayish powder consisting of a mixture of four basic materials:
lime, silica, alumina, and iron compounds.  Cement production involves heating
(pyroprocessing) the raw  materials to a very high temperature in a rotary (rotating) kiln to
induce chemical reactions that produce a fused material called clinker. The cement clinker
is further ground into a fine powder and mixed with gypsum to form the Portland cement.
The cement kiln is a large, rotating steel cylindrical furnace lined with refractory material.
The kiln is aligned on a slight angle, usually a  slope of 3° -  6°. This allows for the materials
to pass through the  kiln by gravity. The upper end of the kiln is known as the 'cold' end.
This is where the raw materials, or meal, is fed into the kiln.  The lower end of the kiln is
known as the "hot"  end.  The hot end is where the combustion of primary fuels (usually
coal and petroleum coke) transpires to produce a high temperature.  The cement kiln is
operated in a counter-current configuration. This means that the hot combustion gases are
conyected up through the kiln while the raw materials are passing down toward the lower
end. The kiln rotates about 50 to 70 revolutions per hour,  and the rotation  induces mixing
and the forward progress of mixed materials.  As the meal  moves through the cement kiln
and is heated by the hot combustion gases, water is vaporized and pyroprocessing of
materials occurs.
                                        5-1                                April 1998

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                      ,   DRAFT-DO NOT QUOTE OR CITE
                     «'. ,      •    ,•'••.  !•••     -I.   '   '' .'•''..    ; '        '
       When operating, the cement kiln can be viewed as consisting of three temperature
zones necessary to produce cement clinker. Zone 1 is at the upper end of the kiln where
the raw meal is added. Temperatures in this zone typically range from ambient up to
600°C. In this area of the kiln, moisture is evaporated from the raw meal.  The second  -
thermal zone is known as the calcining zone. Calcining occurs when the hot combustion
gases from the combustion of primary fuels dissociates calcium carbonate from the
                                                    i    ,      ' '  VI    ' ,„
limestone to form calcium oxide.  In this region of the kiln, temperatures are in a range of
600°C to 900°C.  The third region of the kiln is known as the burning  or sintering zone.
The burning zone is the hottest region of the kiln. Here temperatures in excess of 1,500°C
induce the calcium oxide tq react with silicates, iron and aluminum in the raw materials to
form cement clinker. The formation of clinker actually occurs near the lower end of the kiln
(close to the combustion of primary fuel) where temperatures are the hottest.  The
chemical reactions that occur here are referred to as pyroprocessing.
       The cement clinker that is formed and that leaves the kiln at the hot end is a gray-
       , '    .   j,           i   '   ,i  ' '' "'   ' ' " •'    ''";    .«' ' ,!'''        i
colored, glass-hard material comprised of dicalcium silicate, tricalcium silicate, calcium
aluminate, and tetracalcium aluminoferrite.  At this point, the clinker has a temperature of
about 1,100°C.  The hot clinker is then dumped onto a moving grate where it is  cooled by
passing under a series of cool air blowers.  Once cooled  to ambient temperature, the clinker
is ground into a fine powder and mixed with gypsum  to produce the Portland cement
product.
               <  •      •    \    •    i     .      - ., ,    ,	        •
       Cement kilns can be either wet or dry processes; In the wet process, the raw
materials are ground and mixed with water to form a slurry. The meal-water slurry is fed
into the kiln through a pump.  This is an older process. A greater amount of heat energy is
needed in the wet process than in other types of kilns. These kilns consume about 5 to 7
trillion BTUs per ton of clinker product to evaporate the additional water.
       In the dry process, a pre-heater is used to pre-dry the raw meal. A typical pre-
heater consists of a vertical tower containing a series of cyclone-type vessels. Raw,meal is
added at the top of the tower, and hot kiln exhaust flue  gases from the kiln operation are
used to preheat the meal prior to being loaded into the kiln. Pre-heating the meal has the
advantage of lowering fuel consumption of the kiln.  Therefore, dry kilns are now the most
popular cement kiln type. EPA estimates that Portland cement clinker  production in the
United States was  67.6-billion kg in 1995  and 52-billion kg in 1987 (U.S. DOC, 1996).

                                    .     5-2                                April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 5.1.2. Cement Kilns Burning Hazardous Waste
       The high temperatures achieved in cement kilns make cement kilns an attractive
 technology for combusting hazardous waste as supplemental fuel.  Sustaining the relatively
 high combustion temperatures (1,100°C to 1,500°C) that are needed to form cement
 clinker requires the burning of a fuel with a high energy output. Therefore, coal or
 petroleum coke  is typically used as the primary fuel source.  Because most of the cost of
 operating the cement kiln at high temperatures is associated with the consumption of fossil
 fuels, some cement kiln operators have elected to burn hazardous liquid and solid waste as
 supplemental fuel.  Currently about 75 percent of the primary fuel is coal. Organic
 hazardous waste may have a similar energy output as coal (9,000 to 12,000 Btu/lb for
 coal).  The strategy of combusting the waste as supplemental fuel is to off-set the amount
 of coal/coke that is purchased and burned by the kiln. The operator may .charge a disposal
 fee to the waste generator for the right to combust the hazardous waste at the kiln, which
 also offsets the  cost of kiln operation. Much of the high energy and ignitable wastes are
 primarily comprised of such diverse substances as waste oils, spent organic solvents,
 sludges from the paint and  coatings industry, waste paints and coatings from the auto and
 truck assembly plants, and  sludges from the petroleum refining industry (Greer et al.,
 1992).
       The conditions inherent in the  cement kiln mimic conditions of hazardous waste
 incineration.  For example, the gas residence time in the burning zone is typically three
 seconds while at temperatures in excess of 1,500°C (Greer et al., 1992). In addition, trial
 burns have consistently shown that 99.99 to 99.9999 percent destruction and removal
 efficiencies for the very stable organic wastes can be achieved in cement kilns {Greer et al.,
 1 992). Although the combustion of hazardous waste as supplemental or substitute fuel
 does have apparent advantages, only 16 percent of the Portland cement kilns (34 of the
 212 kilns) combusted hazardous waste in 1995 (Federal Register, 1996b). Other types of
 supplemental fuel used by these facilities include automobile tires, used motor oil, and
sawdust, and scrap wood chips.
      The method of introducing liquid and solid  hazardous waste into the kiln is a key
factor to the  complete consumption of the waste during the combustion of the primary
fuel. Liquid hazardous waste is either injected separately or blended with  the primary fuel
(coal).  Solid waste is mixed and burned along with the primary fuel.
                       • I

                                         5-3                                April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

 5.1.3. Air Pollution Control Devices Used on Cement Kilns
       The pyroprocessing of raw meal in a cement kiln produces fine participates.  This is
 referred to as cement kiln dust. Cement kiln dust is collected and controlled with fabric
 filters and/or electrostatic precipitators. Acid gases such as SO2 can be formed during
 pyroprocessing of the sulfur-laden minerals, but the minerals have high alkalinity which
 neutralizes SO2 gases. Most PM control devices used at cement kilns in 1995 and 1987
 were considered to be hot-side control devices. A hot side control device is one that
 operates at flue gas temperatures above 150°C (note that some EPA rules use different
 definitions for hot side devices for different industries). This has been identified as the
 critical temperature at or above which CDD/CDFs are formed.
 '   -   ,      '   i!'     '     i       '    -    ,,•',•' -.' ..' •'  "   ".",.'•' .
       Reducing the flue gas temperature in the PM control device is one factor shown to
 have a significant impact on limiting dioxin formation and emissions at cement kilns (U.S.
 EPA, 1997d). Recent emissions testing at a Portland cement ki.ln showed that CDD/CDFs
 were almost entirely absent at the inlet to a hot-sided ESP, but CDDs and CDFs were
 measured at the exit to the ESP (U.S. EPA, 1997d). This conclusively showed that dioxins
 were formed  within the hot-side ESP. Reducing the flue gas temperature in the PM control
 device to below 150°C has been shown to substantially limit CDD/CDF formation at
 cement kilns. This is believed to be due to preventing the post-combustion catalytic
 formation of CDD/CDFs.  Consequently a number of cement kilns have added flue gas
 quenching units upstream of the APCD to reduce the inlet APCD temperature, thereby
 reducing CDD/CDF stack concentrations. A quench usually consists of a water spray
 system within the flue duct.  Thus, cement kilns tested after 1995 have substantially
 reduced CDD/CDF emissions as compared to cement kilns used to derive emission
 estimates in this report.                                                   ;

 5.1.4. CDD/CDF Emission Factors for Cement Kilns
      The source emissions data base contains test reports of CDD/CDF emissions from
 12 cement kilns burning  hazardous waste and 11 cement kilns not  burning hazardous
waste (U.S. EPA,1996c)  The majority of stack emissions data from cement kilns burning
hazardous waste were derived during trial burns, and may overestimate the CDD/CDF
emissions that most kilns achieve during normal operations.  Stack emissions data from
kilns not burning hazardous waste were derived from testing during normal operations.

                  "                   '   5-4                               April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

       For purposes of deriving emission factors, the general strategy used in this
 document is to consider subdividing each source category on the basis of design and
 operation. However, cement kilns are relatively uniform in terms of kiln design, raw feed
 material, temperatures of operation, and APCDs. Therefore, no subdivisions were made on
 these bases. An important difference among kilns, however, is the whether or not
 hazardous waste is burned as a supplementary fuel.  The average TEQ emission factors are
 24.34 ng TEQ per  kg clinker produced and 0.29 ng TEQ kg  clinker produced for cement
 kilns burning and not burning hazardous waste, respectively. Accordingly, the average
 emission factor for kilns burning hazardous waste is about 80 times greater than that for
 kilns not burning hazardous waste.  As discussed in Section 5.1.6 (Cement Kiln Dust), a
 comparison of CDD/CDF concentrations in cement kiln dust samples from cement kilns
 burning and not burning hazardous waste show a similar relationship (i.e., the cement kiln
 dust from kilns burning hazardous waste had about 100 times higher CDD/CDF TEQ
 concentration than dust from nonhazardous  waste burning kilns).
       It is possible that differences other than the use of hazardous waste are contributing
 to the observed differences in emissions. Although the average emission factors for the
 two groups of kilns differ substantially, the emission factors for individual kilns in the two
 groups overlap. The five lowest emission factors for kilns burning hazardous waste span
 the same range as  the five highest emission  factors for kilns not burning hazardous waste.
 Accordingly, other  aspects of the design and operation of the kilns may be affecting
 CDD/CDF emissions.  Possibilities include procedures for preheating the meal, type of
 primary fuel, type of secondary fuel, and the characteristics of the raw meal. All tested
 kilns were operating with hot-side ESPs during the stack tests.
      Attempts to understand this  issue through parametric testing of cement kilns have
 yielded mixed results.  EPA conducted  a limited comparison of CDD/CDF TEQ stack gas
 concentrations (ng  TEQ/dscm) between cement kilns burning hazardous wastes and not
 burning  hazardous  wastes (U.S. EPA, 1997d). These comparisons were made at 14
 cement  kilns. Operating conditions  (e.g., APCD temperature), with the exception of the
fuel being burned, were the same or similar for each set of comparisons.  Baseline
conditions used coal as the on|y primary fuel.  The results of these comparisons showed:
                                        5-5                                April 1998

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                        DRAFT-DO NOT QUOTE OR CITE


      •      Seven kilns in which the baseline (i.e., no combustion of hazardous waste)
             CDD/CDF TEQ stack gas concentrations were about the same as that for .the
             burning of hazardous wastes;

      •      Two kilns in which the baseline CDD/CDF TEQ stack gas concentrations were
             about double that for the burning of hazardous wastes; and

      •      Five kilns in which the hazardous waste CDD/CDF TEQ stack gas
             concentrations were substantially greater (from 3 to 29 times greater) than
             that for the baseline operating conditions.


      Currently no satisfactory .explanation exists for the apparent differences in the

emission factors. Given the strong empirical evidence that real differences may exist,

EPA/ORD has decided to treat the kilns burning hazardous waste separately from those not

burning  hazardous waste for the purposes of developing a CDD/CDF emissions inventory.


      The average emission factor (EF) for each cement kiln was calculated using Equation

5-1.       '    '     ;     '         '    '       ^  ^   ^     ;   _  .'  '

                                           C  x  Fv
                                EFck  = •	                       (Eq. 5-1)
                                           •cl
Where:                             .'-.,.,
              . ,            • ;,     '    ,n  i '  '  '   '" '  '      / , '      . ,     ,
      EFck   =    Cement kiln emission factor (burning or not burning hazardous waste),
                   (ng TEQ per kg of clinker produced).
      C     =    TEQ or CDD/CDF concentration in flue gases (ng TEQ/dscm) (20°C, 1
                   atm; adjusted to 7% O2).
      Fv     =    Volumetric flue gas flow rate  (dscm/hr) (20° C,  1 atm; adjusted to 7%
                   02).
      lcl     =    Average cement kiln clinker production rate  (kg/hr).


After developing average emission factors for each tested cement kiln, the overall average
<,               y  '    "    •  • ..       •   •  .••',•'    'i •  • ' - ' '  •: .1 •  '
congener-specific emission factor was derived for all tested HWIs using Equation 5-2

below.
                          [EF    +  EFrfC  +  EFCK ......
                          L   CK        CK        CK* _ _          (Eq. 5-2)
                                        'N
                                         5-6                                April 1998

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                         DRAFT-DO NOT QUOTE OR CITE
       Where:
                                Average emission factor of tested cement kilns either
                                burning or  not burning hazardous waste as
                                supplemental fuel (ng TEQ/kg clinker)
                                Number of cement kilns tested
 The average emission factors representative of the cement kilns burning and not burning
 hazardous waste are summarized in Table 5-1.  Because the same test reports were used,
 the emission factors are the same for both the 1995 and 1987 reference years. Congener
 and congener group profiles for cement kilns burning hazardous waste are presented in
 Figure 5-1 and for cement kilns not burning hazardous wastes in Figure 5-2.

 5.1.5. National Estimates of CDD/CDF Emissions from Cement Kilns
       National estimates of CDD/CDF air emissions (grams TEQ per year) from all Portland
 cement kilns operating in 1995 and 1987 were  made by multiplying the average TEQ
 emission factor by the annual activity level (cement clinker produced) for cement kilns,
 burning and not burning  hazardous waste, respectively.
       Nonhazardous waste burning cement kilns produced 61.3-billion kg of cement
 clinker in 1995  (Heath,1995).  Since a totalof 67.6-billion kg of cement clinker were
 produced in the United States in 1995 (U.S. DOC, 1996), it follows that cement kilns
 burning hazardous waste produced 6.3-billion kg of clinker (or 9.3 percent of the clinker
 produced). Approximately 52-billion kg of cement clinker were produced in 1987 (U.S.
 DOC, 1996). If it is assumed that 9.3 percent of this total  clinker production was from
 hazardous waste burning kilns, then about 4.8 billion kg of  clinker were produced in
 hazardous waste burning kilns in 1987. These activity level estimates are given a "high"
 confidence rating, because they are based on recent survey data (U.S. EPA, 1996c).
       The TEQ emission factors are given a "low" confidence rating for both cement kilns
 burning and  not burning  hazardous waste. The TEQ EF for  nonhazardous waste burning
 kilns were given a low rating because only 11 out of 178 (6 percent^have been tested for
 CDD/CDF emissions. These data may not be representative of routine CDD/CDF emissions
from all kilns not burning hazardous waste. Emission factors for the 11 tested kilns ranged

                                        5-7                                 April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

from not detected up to a maximum of 2.6 ng TEQ/kg clinker.  Although a higher
                                               •           ^
percentage of the kilns burning hazardous waste had been tested (12 out of 34 or 35
percent of the kilns were tested in 1995) greater uncertainty exists about whether the
emissions are representative of normal operations due to trial burn procedures. Accordingly,
a low confidence rating was also assigned to the kilns burning hazardous waste.
       The low confidence rating for the emission factors and high confidence rating 'for
the activity levels combine to produce an overall low confidence rating. Accordingly, the
estimated ranges of potential emissions are assumed to vary by a factor of 10 between the
low and high ends of the range:
              1 '!( •  '  -      '    "      '.-. :  "i   ••::. ."  -.  • ,   "<,'.;.
       •      1995: For cement kilns not burning hazardous waste, the central estimate is
             17.8 g TEQ/yr with a range of 5.6 g TEQ/yr to 56.3 g TEQ/yr.  For cement
             kilns burning hazardous waste, the central estimate is 153 g TEQ/yr with a
             range of 48.4 g TEQ/yr to 484 g TEQ/yr.
       •      1987:  For cement kilns not burning hazardous waste, the central estimate is
             13.7 g TEQ/yr with a range of 4.3 g,TEQ/yr to 43.3 g TEQ/yr.  For cement
             kilns burning hazardous waste, the central estimate is 117 g TEQ/yr with a
             range of 37.0 g TEQ/yr to 370 g TEQ/yr.                    •

       An alternative way to estimate CDD/CDF emissions would be to make no distinction
between kilns burning and  not burning hazardous waste.  If the test data are combined to
develop a single emission factor for all cement kilns, the average emission factor would
then be 12.84 ng TEQ/kg of clinker.  Multiplying this average emission factor by the 67.6
billion kg of total cement clinker produced in  1995 would yield an emission estimate of 868
            -  "!•'  ;;    ,..•••,<  	:', .. ; :.',    ; :  ': . ••  '' ,.<:,'';:•,;:  •••  |   , .    '
g TEQ/yr. Applying the same procedure to the 52-billion kg of clinker produced in 1987
yields an emission estimate of 668 g TEQ/yr. The central estimates using this approach
exceed the upper estimates derived above using the approach of separating kilns burning
              '">  '    '.  '  " ;  '    .  ''•'    '' ' '  '' . '  "i  *',  '  •  '';'•    '              '
and not burning hazardous waste.
       On April 19, 1996,  EPA proposed revised emission standards for cement kilns and
lightweight aggregate kilns burning hazardous waste (Federal Register, 1996b). These
           < „   1       "  ' , ( 	   • .   .'., -, •'. • i,1,1,1 •	r  .: ' ,• I-'       i
standards, including emission standards for CDD/CDF (0.20 ng tEQ/dscm at 7 percent O2),
were proposed under joint authority of the Clean Air Act (CAA) and the Resource
         i    _   i: ?" i    ;       •  '      • •, . •      '•.•,">      '      :  '  .
               »"!J     '      "     '     '    ",   t  ' ' '  „  '' '       "
                III         '  '                 '      i ' ', "
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 Conservation and Recovery Act (RCRA). The proposed standards reflect the performance
 of Maximum Achievable Control Technologies (MACT) as specified by the CAA. These
 standards should lead to lower CDD/CDF emissions than those estimated above for 1995.
        '               -        -         i               ,
>5.1.6. Cement Kiln Dust
       EPA characterized cement kiln dust (CKD) in a Report to Congress (U.S. EPA,
 1993g).  The report was based in  part on a 1991 survey of cement manufacturers
 conducted by the Portland Cement Association (PCA). Survey responses were received
 from 64 percent of the active cement kilns in the United States.  Based on the survey
 responses, EPA estimated that in 1990 the U.S. cement industry generated about 12.9-
                               i     -             "          i                •
 million metric tons of gross CKD and 4.6-million metric tons of "net CKD," of which 4.2-
 million metric tons were land disposed.  The material collected by the APCD system is
 called "gross CKD" (or "as generated" CKD).  The gross CKD  is either recycled back into
 the kiln system or is removed from the system for disposal (i.e., "net CKD" or "as
 managed" CKD) (U.S. EPA, 1993g).
       Also in support of the Report to Congress, EPA conducted sampling and analysis
 during 1992 and 1993 of CKD and clinker. The purposes  of the sampling  andlanalysis
 efforts were: (1) to characterize the CDD/CDF content of clinker and CKD  ; (2) to determine
 the relationship, if any, between the CDD/CDF content of  CKD and the use of hazardous
 waste as fuel; and (3) to determine the relationship, if any, between the CDD/CDF content
 of CKD and the use of wet versus dry process cement kilns.  Clinker samples were
 collected from 9 kilns not burning  hazardous waste and 11 kilns burning hazardous  waste
 (U.S.  EPA, 1993g).
       CDD/CDFs were not detected in any cement kiln clinker samples. Tetra- through
 octa-chlorinated CDDs and CDFs were detected in the "gross  CKD" samples obtained from
 TO of the  11 kilns and in the "net  CKD" samples obtained  from 8 of the 11 kilns. The
 CDD/CDF content of "gross CKD"  ranged from 0.008 to 247  ng TEQ/kg and from 0.045 to
 195 ng TEQ/kg for "net CKD." Analyses for seven  PCB congeners were also  conducted,
 but no congeners were detected in any clinker or CKD sample. The mean  CDD/CDF
 concentrations in "net CKD" generated by the kilns burning hazardous waste  are higher (35
 ng TEQ/kg) than in "net CKD" generated by the facilities not burning hazardous waste
 (3.0E-02 ng TEQ/kg). These calculations of mean values treated nondetected values as

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zero.  If the nondetected values had been excluded from the calculation of the means, the
mean value for "net CKD" from kilns burning hazardous waste would increase by a factor
of 1.2, and the mean value for "net CKD" from kilns not burning hazardous waste would
increase by a factor of 1.7. One sampled kiln had a  "net CKD" TEQ concentration more
than two orders of magnitude greater than the TEQ levels found in samples from any other
                                        9        :        I ,          f-             ' .  ,
kiln. If this kiln was considered atypical of the industry {U.S. EPA, 1993g) and was not
included in the calculation, then the mean "net CKD" concentration for hazardous waste
burning kilns decreases to 2.9 ng/kg.
       AH CKD is normally disposed in engineered landfills and consequently not
categorized as an environmental release as defined in this emission inventory. The amount
of CDD/CDF associated with these materials is calculated for informational purposes.  The
estimate  of land:disposed CKD from the 1991 PCA Survey (4.2-million metric tons per year
Ibasis year is 19*90]) was divided among kilns burning hazardous waste (34 kilns) and those
              ,|   •          •••''.    ',      .•:  •,  ""    .'•',  ,  ;,•'.  >'     . '
that do not {1?| kilns) on the basis of the number of kilns in each category.  The average
TEQ concentration in the net CKD from kilns burning hazardous waste (including the high
value discussed above) was 35 ng TEQ/kg. For kilns that do not have hazardous waste,
the average concentration in the "net CKD" was 3.6E-62.  Multiplying these  average
concentrations by the annual "net CKD" production yields estimates of 24-g TEQ/yr for
kilns burning hazardous waste and 0.1-g TEQ/yr for  kilns not burning hazardous waste,
yielding a total of 24.1-g TEQ/yr for all kilns.
              ;;.!!:       ,  -   :   "   ' '  •   •• ,  .  •••  : •• '•.      v:'   ..!•••    / •
5.2.   ASPHALT MIXING PLANTS
       Asphalt consists of an aggregate of gravel, sand, and filler mixed with liquid asphalt
cement or bitumen. Filler typically consists of limestone, mineral stone powder, and
              1 '!:  ,  u •>,      , „  •    •  ,  • ,. , ,  : :  ,    ;  ,.-,   J , •   i. ,, , '
sometimes ash from power plants and  municipal waste combustors.  The exact
composition of an asphalt formulation depends on how it will be used. The components of
the aggregate are dried, heated, and mixed/coated with the bitumen  at an asphalt mixing
installation.  "Old" asphalt (i.e., asphalt from  dismantled bridges and roads) can be
disaggregated to its original components through heating and reused in the manufacture of
new asphalt.
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       No data are available on CDD/CDF emissions, if any, from U.S. asphalt mixing
operations.  However, limited data are available for facilities in The Netherlands and
Germany.
       Bremmer et al. (1994) measured CDD/CJJF content in air emissions from an asphalt
mixing plant in The Netherlands to be 47-ng TEQ per metric ton of produced asphalt.  No
congener-specific emission factors were reported by Bremmer et al. (1994). The tested
facility heated old asphalt in an individual recycling drum to about 150°C with flue gases
that were mixed with ambient air to a temperature of 300-400°C.  Parallel to this recycling
drum, the "main drum" dried and heated the aggregate (sand and gravel/granite chippings)
to a temperature of about 220°C. The flue gases leaving the recycling drum are led along
the main burner of the main drum for incineration.  The old asphalt, the minerals from the
main drum, and new bitumen from a hot storage tank (about 180°C) were mixed in a  mixer
to form new asphalt. Natural gas fueled the tested facility during the sample collection
period and used old asphalt as 46 percent of the feed.  The facility's APCD system
consisted of cyclones and a fabric filter.
       Umweltbundesamt (1996) reported lower emission factors for three tested facilities
in Germany that were also equipped with fabric filters. These three facilities were fueled
by oil and/or butane gas and>used old asphalt at usage rates ranging from 30 to 60 percent
of the/feed.  The emission factors calculated from the stack gas concentrations, gas flow
rates, and hourly thruputs for these three facilities  were 0.2, 3.5, and 3.8 ng TEQ/metric
ton of asphalt produced.
      Approximately 25-miIlion metric tons of asphalt bitumen were produced in the
United  States in 1992.  An identical quantity was produced in  1990 (U.S. DOC,  1995a).
Bitumen constitutes approximately 5 percent by weight of finished paving asphalt (Bremmer
et al., 1994).  Thus/an estimated 500-million  metric tons  of paving asphalt are produced in
the United States  annually.
      Because there are no direct measurements of CDD/CDF emissions from U.S. asphalt
plants and because of uncertainties regarding the comparability of U.S. and Dutch asphalt
plant technologies and feed materials, no national emission estimate for this category  is
proposed at this time. However, a preliminary order of magnitude estimate of the potential
annual TEQ emissions for U.S. production of asphalt can be obtained by averaging the  '
emission factors for the four facilities reported by Bremmer et al. (1994) and

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  Umweltbundesarnt (1996).  Applying this average emission factor (i.e., 14 ng TEQ/metric
  ton of asphalt produced) to the activity level of 500-million metric tons of paving asphalt
  produced annually yields an annual emission of 7 g TEQ/yr, which, when rounded to the
  nearest order of magnitude to emphasize the uncertainty in this estimate, results in a value
                             "',':'"  ' •  ' , •"    •     '  ' ' '    ii '  ''   '' ', ' '
  of 10 g TEQ/yr. This estimate should be regarded as a preliminary indication of possible
  emissions from this source category; further testing is needed to confirm the true
  magnitude of these emissions.

  5.3.   PETROLEUM REFINING CATALYST REGENEfcATION
         Regeneration of spent catalyst for use in the petroleum refinery reforming process is
  a potential source of CDDs and CDFs based on limited testing conducted in the United
  States (Amendola and Barna, 1989; Kirby, 1994), Canada (Maniff and Lewis, 1988;
  Thompson et al., 1990), and The Netherlands (Bremmer et al., 1994). The available data
  indicate that CDD/CDFs can be generated during the catalyst regeneration process.
  However, the available data indicate that releases to water (i.e., treated wastewater) and in
  solid waste are minimal.  Releases to air could result from untreated vented flue gases at
  some facilities, and the CDD/CDFs formed could possibly be reintroduced into other refining
  operations (e.g., the coker) and resulting products.  However, the available data are not
  adequate to support even order of magnitude release estimates for air and product releases.
  The following paragraphs summarize the catalyst regeneration process, relevant studies
  performed to date, and the status of EPA regulatory investigations of this source.
   s      '        	i;;     .      .•';..        • .    :;  '  .•••'-.   .'•' ,';>''..',
         Catalytic reforming is the process used to produce high octane reformates from
  lower octane reformates for blending of high octane gasolines and aviation fuels.  The
  reforming process occurs at high temperature and pressure and requires the  use of a
  platinum or platinum/rhenium catalyst. During the reforming process, a complex mixture of
  aromatic compounds, known as  coke, is formed and deposited onto the catalyst.  As coke
  deposits onto the catalyst, its activity is decreased.  The high cost of the catalyst
  necessitates its regeneration. Catalyst regeneration is achieved by removing the coke
  deposits via burning at temperatures of 750 to 8506F and  then reactivating the catalyst at
  elevated temperatures (850 to 1,000°F) using chlorine  or chlorinated  compounds  (e.g.,
" methylene chloride, 1,1,1-trichloroethane, and ethylene dichloride). Burning of the coke
  produces flue gases that can contain CDDs and CDFs along with other combustion
             t   ' ' ;!|                  '       ;i            'i     '" ',   '                • '
                 ii:,            '          '..,,,•'''.        •   ,         ,
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products.  Because flue gases, if not vented directly to the atmosphere, may be scrubbed
with caustic or water, internal effluents may become contaminated with CDD/CDFs (Kirby,
1994; SAIC, 1994).
      In 1988, the Canadian Ministry of the Environment detected concentrations of CDDs
in an internal wastestream of spent caustic in a petroleum refinery that ranged from 1.8 to
22.2 A*gL, and CDFs ranging from 4.4 to 27.6 //g/L (Maniff and Lewis, 1988).  The highest
concentration of 2,3,7,8-TCDD w,as 0.0054 ^g/L. CDDs were also observed in the
refinery's biological sludge at a maximum concentration of 74.5 ^g/kg, and CDFs were
observed at a maximum concentration of 125 yug/kg. The concentration of CDD/CDFs in
the final combined refinery plant effluent was below the detection limits.
      Amendola and Barna (1989) reported detecting trace levels of hexa- to octa-CDDs
and CDFs in untreated wastewaters (up to 2.9 pg TEQ/L) and Wastewater sludges (0.26 to
2.4 ng TEQ/kg)  at a refinery in Ohio.  The levels of detected total CDD/CDFs in the
wastewater and sludge were much lower «3 ng/L and < 1 /ug/kg, respectively) than the
levels reported by Maniff and Lewis (1988).  No CDD/CDFs were detected in the final
treated effluent (i.e., less than 0.2 ng TEQ/L).  The data collected in the study were
acknowledged to be too limited to enable identifying the source(s) of the CDD/CDFs within
the refinery. Amendola and Barna (1989) also present  in ah appendix to their report the
results of analyses of wastewater from the reformer catalyst regeneration process units at
two other U.S. refineries.  In both cases, untreated wastewaters contained CDDs and CDFs
at levels ranging from high pg/L to lo,w ng/L (results were reported for congener group
totals, not specific congeners). However, CDD/CDFs were not detected in the only treated
effluent sample collected at one refinery.
      Thompson et al. (1990) reported total COD and  CDF concentrations of 8.9 ng/m3
and 210 ng/m3, respectively, in stack gas samples from a Canadian petroleum refinery
reforming operation. Thompson et al. (1990) also observed CDDs and CDFs in the internal
wash water from a scrubber of a periodic/cyclic regenerator in the* pg/L to ng/L range.
      Beard et al. (1993) conducted a series of benchtop experiments to investigate the
mechanism(s) of CDD/CDF formation in the catalytic reforming process. A possible
                  -;                   .-                     •
pathway for the formation of CDFs was found, but the results could not expjain the
formation of CDDs. Analyses of the flue gas from burning coked catalysts revealed the
presence of unchlorinated dibenzofuran (DBF) in quantities up to 220 /ug/kg of catalyst.

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 Chlprination experiments indicated that dibenzofuran and possibly biphenyl and similar
 hydrocarbons act as CDF precursors and can become chlorinated in the catalyst
 regeneration  process. Corrosion products on the steel piping of the process plant seem to
 be the most likely chlorinating agent.
       In May 1994, EPA's Office of Water conducted a sampling and analytical study of
 catalytic reforming regeneration wastewater for CDD/CDFs at three petroleum refining
 plants (Kirby, 1994).  The study objectives were to determine the analytical method best
                          ,  ,,,    	   „  '  ,  *    ;   " ' r ' , , ,'F         i   '    1
 suited for determining CDD/CDFs in refinery wastewater matrices and to
 screen/characterize wastewater discharges from several types of reforming operations for
 CDD/CDFs. The report for this study (Kirby, 1994) also presented results submitted
 voluntarily to EPA by two  other facilities. The sampled untreated wastewaters and spent
 caustics were found to contain a wide range of CDD/CDF concentrations, 0.1  pg TEQ/L to
 57.2 ng TEQ/L. The study results also showed that 90 percent of the TEQ is contained in
 the wastewater treatment sludges generated during the treatment of wastewater and
 caustic from the regeneration process.
       EPA recently issued a notice of its proposed intent not to designate spent reformer
 catalysts as a listed hazardous waste under RCRA  (Federal Register, 1995b).  The primary
 oil/water/solids sludges at petroleum refineries are  listed as hazardous wastes  (K048,
 K051, F037,  and F038) (Federal Register, 1995b).  The Agency's assessment of current
 management practices associated with recycling reforming catalyst found no significant
 risks to human health or the environment. The Agency estimated that 94 percent of the
 approximately 3,600 metric tons of spent reformer catalyst generated annually are
 currently recycled for their precious metal content.  However, EPA made no determination
 of the "listability" of spent caustic residuals formed during regeneration of spent reforming
 catalysts. The Agency did identify potential air releases from the combustion  of the
 reforming catalyst prior to reclamation as possibly of concern.  The Agency requested
 comments on:  (1) opportunities for removing dioxin prior to  discharge of scrubber water
 into the wastewater treatment system;  (2) opportunities to segregate this wastestream;
 and (3) potential health risk associated with insertion of dioxin-contaminated media back
 into the refinery process (such as the coker). In this proposed rulemaking, EPA also noted
the possibility of dioxin releases to air during regeneration operations, but indicated that
 EPA is scheduled to assess the need for development of MACT standards under the CAA

                                      :  5-14                                April 1998

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 for petroleum refining refiner units in 1996. As part of its regulatory investigation under
 ,RCRA, EPA's OSW commissioned a study to analyze and discuss existing data and
 information concerning CDD/CDF formation in the treatment of catalytic reformer wastes.
 This report (SAIC, 1994) also identified potential process modifications that may prevent
 the formation of CDD/CDFs.

 5.4.   CIGARETTE SMOKING
    ••  Bumb et al. (1980) were the first to report that cigarette smoking is a source of
 CDD emissions. Subsequent studies by Muto and Takizawa (1989), Ball et al. (1990), and
 Lofroth and Zebiihr (1992) also reported the presence of CDDs as well as CDFs in cigarette
 smoke.  A recent study by Matsueda et al. (1994) reported  the CDD/CDF content of the
 tobacco from 20 brands of cigarettes from seven countries. Although a wide range in the
 concentrations of total CDD/CDFs and total TEQs were reported in these studies, similar
 congener profiles and patterns were reported. The findings of each of these studies are
 described in the following paragraphs.
       No studies published to date have demonstrated a complete and thorough mass
 balance, and it is not known whether the CDD/CDFs measured in cigarette  smoke are the
 result  of formation during tobacco combustion, volatilization of CDD/CDFs present in the
 unburned tobacco, or a combination of these two sources.  The, combustion processes
 operating during cigarette smoking are complex and could be used to justify both proposed
 source mechanisms. As  reported by Guerin et al. (1992), during a puff, gas phase
 temperatures reach 850°C at the core of the firecone, and solid phase temperatures reach
 800°C at the core and 900°C or greater at the char line.  Thus, temperatures are sufficient
 to cause at least some destruction of CDD/CDFs initially present in the tobacco.  Both solid
 and gas  phase temperatures rapidly decline to 200 to 400°C within 2 mm of the char line.
 Formation of CDD/CDFs has been reported in combustion studies with other media in this
 temperature range of 200 to 900°C. However, it is known that a process likened by
 Guerin et al.  (1992) to steam distillation takes place in the region behind the char line
 because of high localized concentrations of  water and temperatures of 200 to 400°C.  At
"least 1,200 tobacco constituents (e.g., nicotine, n-paraffin, some terpenes) are transferred
 intact  from the tobacco into the smoke stream by distillation in this area, and it is plausible
 that CDD/CDFs present in the unburned tobacco would be subject to similar distillation.

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                1 ,          ' '           ||I:|1  '      '<              '    i    :
       Bumb et al. (1980), using low resolution mass spectrometry, analyzed the CDD
content of mainstream smoke from the burning of a U.S. brand of unfiltered cigarette.  A
package of 20 cigarettes was combusted in each of two experiments. Approximately 20 to
30 puffs of 2 to 3 seconds duration were collected from each cigarette on a silica column.
Hexa-, hepta-, and octa-CDD were detected at levels of 6.004-0.008, 0.009, and 0.02-
0.05 ng/g, respectively.
       Muto and Takizawa (1989) employed a continuous smoking apparatusjo measure
                                   t
CDD congener concentrations in the mainstream smoke generated from the combustion of
one kind of filtered cigarette (brand not reported).  The apparatus pulled air at a constant
continuous rate (rather that a pulsed rate) through a burning cigarette and collected the
smoke on a series of traps (glass fiber filter,  polyurethane foam, and XAD-II resin). The
CDD content of the  smoke, as well as the CDD content of the unburned cigarette and the
ash from the burned cigarettes, were also analyzed using low-resolution mass
spectrometry. The results for all three media are presented in Table 5-2, and the congener
group profiles for the three media are presented in Figure 5-3. Table 5-3 and Figure 5-4
present the mainstream smoke results on a mass per cigarette basis to enable comparison
with the results pf other studies.  The major  CDD congener group found was HpCDD,
which accounted for 84  percent of total CDDs found in the cigarette, 94 percent of total
CDDs found in smoke, and 99 percent of total CDDs found in the ash. The 2,3,7,8-
HpCDDs also accounted  for the majority of the measured TEQ in the cigarettes and smoke;
however, none were measured in the ash. Although no PeCDDs were detected in the
cigarette, PeCDDs were  detected at low levels in the smoke, indicating probable formation
during combustion.  Based on the similarities in the congener group profiles for the three
media, Muto and Takizawa (1989) concluded that most of the CDDs found in the cigarette
smoke appear to be  the result of volatilization of CDD/CDFs present in the unburned
cigarette rather than resulting from formation during combustion.
       Ball et al. (1990)  measured the CDD/CDF content of mainstream smoke for the  10
best-selling German  cigarette brands.  The international test approach (i.e., 1  puff/min; puff
        ' •  '"   •:  :-f! '        ' ' '.'', '  ••" ':"'  ' ''.' •''"• '  (•'•''<'''• ' ' «:'"•,;!  ':'/:; ;' '  : ii«:^'.!     ; '            ••'',.
flow rate of 35 mL/2 sec) was employed with an apparatus that smoked 20 cigarettes at a
time in three successive  batches with a large collection device. The average TEQ content
in mainstream smoke for the 10 brands tested, normalized to a mass per cigarette basis,
was 0.09 pg/cigarette (i.e., 16.5 times less than the value reported by Muto  and Takizawa

                                       5-16                               April 1998

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           •             DRAFT-DO NOT QUOTE OR CITE

 (1989) for a Japanese cigarette brand).  However, the congener group profiles were similar
 to those reported by Muto and Takizawa (1989) with HpCDD and OCDD the dominant
 congener groups found.
       Lofroth and Zebiihr (1992) measured the CDD/CDF content of mainstream and
 sidestream smoke from one common Swedish cigarette brand.  The cigarette brand was
 labeled as giving 17 mg carbon monoxide, 21  mg tar, and 1.6 mg nicotine. The
 international test approach (i.e., 1 puff/min; puff flow rate of 35 mL/2 sec) was utilized,
 and the smoke was collected on glass fiber filters followed by two polyurethane plugs.  The
 analytical results for mainstream and sidestream smoke are presented in Table 5-3. The
 TEQ content in mainstream smoke> normalized to a mass per cigarette basis, was 0.90
 pg/cigarette (i.e.,  about 2 times less than the value reported by Muto and Takizawa (1989)
 and 10 times greater than the average value reported by Ball et al. 1990).. As was reported
 by Muto and Takizawa (1989) and^in Ball et al. (1990) study, the dominant congener
 groups were HpCDDs and OCDD; however, HpCDFs were also relatively high compared to
 the other congener group totals.  The sidestream smoke contained about 2-pg TEQ per
                                ^
 cigarette or twice that of mainstream smoke.
      Using high-resolution mass spectrometry, Matsueda et al. (1994) analyzed the
 CDD/CDF content of tobacco from 20 brands of commercially available cigarettes collected
 in 1992 from Japan, United States, Taiwan, China, United Kingdom, Germany, and
 Denmark.  Table 5-4 presents the study results.  The total CDD/CDF content and total TEQ
 content ranged from 109 to 1,136 pg/pack and from 1.4 to 12.6 pg/pack, respectively.
 The Chinese cigarette brand contained significantly less CDD/CDFs and TEQs than any
 other brand of cigarette. Figure 5-5 depicts the  congener group profiles for the average
 results for each country. A high degree of similarity is shown in the CDF congener group
 profiles between the tested cigarette brands. The Japanese and Taiwanese cigarettes
 show CDD congener group profiles different from the other countries' pigarettes.
      In 1995, approximately 487-billion cigarettes were consumed in the United States
 and by U.S. overseas armed forces personnel. In 1987, approximately 575-billion
 cigarettes were consumed.  Per-capita U.S. cigarette consumption, based on total U.S.
 population aged 16 and over, declined to 2,41 5  in 1995; the record high was 4,345 in
 1963 (The Tobacco Institute, 1995; USDA, 1997). These activity level estimates are
assigned a "high"  confidence rating.

                                       5-17                               April 1998

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      The available emission factor data presented above enable estimates of the amount
of TEQs that may have been released to the air in 1994 from the combustion of cigarettes
estimated by two methods. The confidence rating assigned to the emission factor is "low"
based on the very limited amount of testing performed to date. First, an annual emission
estimate for 1995 of 0.21-g TEQ is obtained  if it is assumed that: (1) the average TEQ
content of seven brands of U.S. cigarettes reported by Matsueda et al. (1994), 8.60
pg/pack (or 0.43 pg/cigarette) are representative of cigarettes smoked in the United States;
(2) CDD/CDFs are not formed, and the congener profile reported by Matsueda et al. (1994)
IS not altered during combustion  of cigarettes; and (3) all CDD/CDFs contributing to the
TEQ are released from the tobacco during smoking. The second method is to assume that
the TEQ emission rates for a common Swedish  brand of cigarette reported by Lofroth and
Zebuhr (1992) for mainstream smoke (0.90 pg/cigarette) and sidestream smoke (2.0
pg/cigarette) are representative of the emission rates for U.S. cigarettes.  This second
method yields an annual emission estimate of 1.41 g TEQ.  For 1987, the two methods
yield estimates of 0.25 g TEQ and 1.67 g TEQ.
      Because  of the "low" confidence rating assigned to the emission factor, the
estimated range of  potential air emissions is assumed to vary by a factor  of 10 between the
                                      . .  	-   ,p>     .   .
low and high ends of the range.  Assuming that the average of the annual emissions
estimated by the two methods for 1995 (i.e., 0.8 g TEQ) and 1987 (i.e.,  1.0 g TEQ) are
the geometric means of the ranges for these  years, the ranges are calculated to be 0.25 to
2.5 g TEQ for 1994 and 0.31 to 3.1 g TEQ for  1987. Although these emission quantities
are relatively small  when compared to the emission quantities estimated for various
industrial combustion source categories, these emissions assume significance because
humans are directly exposed to cigarette smoke.

5.5.   PYROLYSIS  OF BROMINATED FLAME RETARDANT8
    !  The pyrolysis and photolysis of brominated phenolic derivatives and polybroiminated
       '   •   ..  :l> ""  ,    i ''•:.'',      " " V  •'•  " f '.   ;•  .:• V  .'•,•••
biphenyl ethers  used as flame retardants in plastics (especially those used in electronic
devices), textiles, and paints can generate considerable amounts of polybrominated
dibenzo-p-dioxins (BDDs) and dibenzofurans (BDFs) (Watanabe  and Tatsukawa,  1987;
Thoma and Hutzinger, 1989;  Luijk et al., 1992).  Watanabe and Tatsukawa (1987)
observed the formation of BDFs from the photolysis of decabromobiphenyl ether.
                        )       '     • '•              '' , :'
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Approximately 20 percent of the decabromobiphenyl ether were converted to BDFs in
samples that were irradiated with ultraviolet light for 16 hours.                   ,
       Thoma and Hutzinger (1989) observed the formation of BDFs during combustion
experiments with polybutylene-terephthalate polymers containing 9 to 11 percent
decabromodiphenyl ether.  Maximum formation of BDFs occurred at 400 to 600°C, with a
BDF yield of 16 percent.  Although Thoma and Hutzinger (1989} did not provide specific
quantitative results for similar experiments conducted with octabromodiphenyl ether and
1,2-bis(tri-bromophenoxy)ethane, they did report that BDDs and BDFs were formed.
       Luijk et al.(1992) studied the formation of BDD/BDFs during the compounding/
extrusion of decabromodiphenyl ether into high-impact polystyrene polymer at 275°C.
HpBDF and OBDF were formed during repeated extrusion cycles, and the yield of BDFs
increased as a.function of the number of extrusion cycles.  HpBDF increased  from  1.5 to
9 ppm (in the polymer matrix), and OBDF increased from 4.5 to 45 ppm after four extrusion
cycles.
       Insufficient data are available at this time upon which to derive annual BDD/BDF
emission estimates from this source.

5.6.   CARBON REACTIVATION FURNACES
       Granular activated carbon (GAC) is an adsorbent that is widely used to remove
organic pollutants from wastewater and in the treatment of finished drinking  water at water
treatment plants.  Activated carbon is manufactured from the  heat treatment of nut shells
and coal under pyrolytic conditions (Buonicore, 1992a). The properties of GAG make it  -
ideal for adsorbing and controlling, vaporous organic and inorganic chemicals  entrained in
combustion  plasmas, as well as soluble organic, contaminants in industrial effluents and
drinking water.  The high ratio of surface area to particle weight (e.g., 600 -  1600 m2/g),
combined with the extremely small pore diameter of the particles (e.g., 15-25 Angstroms)
increases the adsorption characteristics (Buonicore, 1992a). GAC will eventually become
saturated, and the adsorption properties will significantly degrade.  When saturation occurs,
GAC usually must be replaced and discarded, which significantly increases the costs of
pollution control.  The introduction of carbon reactivation furnace technology in the rnid-
1980s created a method involving the thermal treatment of used GAC to thermolytically
desorb the synthetic compounds and restore,the adsorption properties for reuse (Lykins et

                                        5-19                                April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

a)., 1987). Large-scale regeneration operations, such as those used in industrial water
                                  ^      '       .            i.
treatment operations, typically utilize multiple-hearth furnaces.  For smaller-scale
operations, such as those used in municipal water treatment operations, fluidized-bed and
infrared furnaces are used.  Emissions are typically controlled by afterburners followed by
water scrubbers {U.S. EPA, 1995c; 1997b).-
       The used GAC can contain compounds that are precursors to the formation of
CDD/CDFs during the thermal treatment process.  EPA measured precursor compounds in
spent GAC used as a feed material to a carbon reactivation furnace tested during the
National Dioxin Study (U.S. EPA, 1987a).  The total chlprobenzene content of the GAC
ranged from 150 to 6,630 ppb. Trichlorobenzene was the most prevalent species present,
with smaller quantities of di- and tetra-chlorobenzenes detected, total halogenated
organics were measured to be about 150 ppm.
       EPA has stack tested two GAC reactivation furnaces for the emission of dioxin  (U.S.
EPA,  1987a; Lykins et al., 1987). One facility was an industrial carbon reactivation  plant,
  .       • : "  -, ' •'•;.   '      ;   •    ,"  •	 '      '    , :  ;•;'  "  ,: *. ...1  „     I  • ' •  . ;  i ,   '  •     .
and the second facility was used to restqre GAC at a municipal drinking water plant.  U.S.
EPA (1995c; 1997b) reported results of testing performed at a county water facility  in
California during 1990.
       The industrial carbon  regeneration plant processed 36,000 kg/day of spent GAC
used in the treatment of industrial wastewater effluents. Spent carbon was reactivated in
a multiple-hearth furnace, cooled in a water quench, and stored and shipped back to
primary chemical manufacturing facilities for reuse. The furnace fired natural gas, and
consisted of seven hearths arranged vertically in series. The hearth temperatures ranged
from 480 to 1,000°C. Air pollutant emissions were controlled by an afterburner, a sodium
spray cooler, and a fabric filter.  Te.mperatures in the afterburner were about 930°C.  From
 I, '             1, ,    '      '  , •   	|     ,  • ,  „  ' • i'     '• | .!.",•"'    ,  ,  '     ,i
the results of this testing, a TEQ emission factor of 2.98 ng TEQ/kg carbon processed  can
        "' '    ' ,''t       '  ",   >';   " '  '.'. • '  '   *   H.'.1  '  '   I,V' , "' ;. >   :  •       ',       '
be derived. The emission factor for total CDD/CDF was 58.6 ng/kg.
       The second GAC reactivation facility tested by EPA consisted of a fluidized-bed
furnace located at a municipal drinking water treatment plant (Lykins et al.,  1987).  The
furnace was divided into  three sections: a combustion chamber, a reactivation section, and
a dryer section. The combustion section was  fired by natural gas, and consisted of a
sfoichiometrically  balanced stream of fuel and oxygen. Combustion temperatures were
about 1,038°C. Off-gasses from the reactivation/combustion section were directed
               ,1,         '	       .         "   •'• ;  ';:V"  '  '  ';;       -':
               in"!      L  i     ;  ' i' »       '     ' '   ,i   ,iiij «      ; "
                                        5-20                                April 1998

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through an acid gas scrubber and high-temperature afterburner prior to discharge from a
stack. Although measurable concentrations of dioxin-like compounds were detected in the
stack emissions, measurements of the individual CDD/CDF congeners were not performed;
therefore, it was not possible to derive TEQ emission factors for this facility.  With the
afterburner operating, no CDD congeners below HpCDD were detected in the stack
emissions. Concentrations of HpCDDs and OCDD ranged from 0,001 to 0.05 ppt/v and
0.006 to 0.28 ppt/v, respectively. All CDF congener groups were detected in the stack
emissions even with the afterburner operating. Total CDFs emitted from the stack
averaged 0.023 ppt/v.     . '. .    :         :
      From the results of testing the regeneration unit at the county watervfacility reported
by U.S.  EPA (1995c; 1997b), a TEQ emission factor of 1.73 ng TEQ/kg of carbon
processed can be derived.  The emission factor for total CDD/tDF was 47 ng/kg.  The
report did not provide the configuration and type, of furnace tested. However, the report
did state that the emissions from the furnace were controlled by an afterburner and a
scrubber.                ,
      The industrial GAC reaction furnace test data indicate that an average of 2.98 ng
TEQ per kg of GAG may be released to the air during an industrial operation.  The TEQ
emission rate for the regeneration unit at the county water treatment facility was 1,73  ng
TEQ/kg carbon.  "Low" confidence ratings are given to these emission factors, because
only one industrial GAC reactivation furnace in each category was stack tested.
      The mass of GAC. that is reactivated annually in carbon reactivation furnaces is not
known.  However, a rough estimate, to which a "low" confidence rating is assigned, is the
mass of virgin GAC shipped each  year by GAC manufacturers. According to U.S. DOC
0 990c), 48,000 metric tons of GAC were shipped in 1987.  Data for 1995 are not yet
available for GAC shipments from U.S. DOC (1996).  However, U.S. EPA (1995c; 1997b)
reports water and wastewater treatment operations consumed 65,000 metric tons of GAC
in 1990. An estimated 50 percent of this volume Were used for industrial uses, and 50
percent  were  used for municipal uses. Industrial facilities potentially regenerated 24,000
metric tons and 32,500 metric tons of GAC in 1987 and 1990, respectively.  In 1 987 and
1990 municipal facilities potentially regenerated 24,000 metric tons and 32,500 metric
tons, respectively.
                                       5-21                                April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

       Applying the TEQ emission factor of 2.98 ng TEQ/kg of reactivated carbon to the
 estimates of potential GAC reactivation volume by industrial facilities yields annual release
 estimates of 0.072 g TEQ in 1987 and 0.097 g TEQ in 1990.  Using the TEQ emission
 factor of 1.73 ng/kg of reactivated carbon yields estimated annual emissions by municipal
 facilities of 0.042 g TEQ in 1987 and 0.056 g TEQ in  1990.  Based on the "low"
 confidence ratings assigned to the activity level and emission factors, the estimated range
 of potential annual emissions is assumed to vary by  a factor of 10 between the low and
 high ends of the range. Assuming that the total releases estimated for 1990 (i.e., 0.15 g
 TEQ) and for 1987 (i.e., 0.11 g TEQ) are the geometric means of the ranges for those 2
 years, the ranges are calculated to be 0.05 to 0.47 g TEQ in  1 990 and 0.03 to 0.34 g TEQ
 in 1987.
               '.'      .  •    .: '        '  .  . '   '    .  ' .      r •  .    ,        • ••
         '.  •    ;•;;.    •'.'  .';:'<'.•    • • '':i': •':   '.'•..••  •'•''.?   K         •    '
 5.,7.   KRAFT BLACK LIQUOR RECOVERY BOILERS
       Kraft black liquor recovery boilers are associated with the production of pulp in
 making of paper using the Kraft process. In this process, wood chips are cooked in large •
 vertical vessels called digesters at elevated temperatures and pressures in an aqueous
 solution of sodium hydroxide and  sodium sulfide (Someshwar and Pinkerton, 1992). Wood
 is broken down into two phases:  a soluble phase containing primarily lignin, and an
 insoluble phase containing the pulp.  The spent liquor (called black liquor) from the digester
 contains sodium sulfate and sodium sulfide that the industry finds beneficial in recovering
 for reuse in the Kraft process. In  the recovery of black liquor chemicals, weak black: liquor
 is first concentrated in  multiple-effect evaporators to about 65 percent solids.  The
 concentrated black liquor also contains 0.5 to 4 percent chlorides by weight (U.S.  EPA,
 1987a).  Recovery of beneficial chemicals is accomplished through combustion in a Kraft
 black liquor recovery furnace. The concentrated black  liquor is sprayed into a furnace
 equipped with a heat recovery boiler. The  bulk of the inorganic molten smelt that forms in
the bottom of the furnace contains sodium carbonate and sodium sulfide in a ratio of about
3:1 (Someshwar and Pinkerton, 1992). The combustion gas is usually passed through an
electrostatic precipitator that collects paniculate matter prior to" being vented out the stack.
The particulate matter can be processed to further recover and  recycle sodium  sulfate.
       In 1987, the U.S. EPA stack tested  three Kraft black liquor recovery boilers for the
emission of dioxin in conjunction with the National Dioxin Study (U.S. EPA, 1987a). The

                                        5-22                                April 1998

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 three sites tested by EPA were judged to be typical of Kraft black liquor recovery boilers at
 that time. Dry bottom ESPs controlled emissions from two of the boilers; a wet bottom
 ESP controlled emissions from the third.  The results of these tests include congener group
 concentrations but lack measurement results for specific congeners other than 2,3,7,8-
 TCDD and 2,3,7,8-TCDF.  NCASI (1995) provided congener-specific emission test results
 for six additional boilers tested  during the 1990 to 1993 time period.  Three boilers were of
 the direct contact type, and three were noncontact type. All were equipped with ESPs.
 The average congener and congener group emission factors are presented in Table 5-5 for
 the three facilities from U.S. EPA (1987a) and the six facilities from NCASI (1995).  Figure
 5-6 presents the average congener and congener group profiles based on the test results
 presented in NCASI (1995).
       The average TEQ emission factor based on the data for the six NCASI facilities with
 complete congener data  is 0.028 ng TEQ/kg of black liquor solids, assuming nondetected
 values are zero and 0.068  ng TEQ/kg and are present at one-half the detection limit.  The
 results for the three .facilities reported in U.S. EPA (1987a) were not used in the derivation
 of the TEQ emission factor, because congener-specific measurements for most 2,3,7,8-
 substituted congeners were not made in the study. A  "medium" confidence rating is
 assigned to these emission factors, because the emission factors were derived from the
 stack,testing of six Kraft black  liquor recovery boilers that were judged to be fairly
 representative of technologies used at Kraft  pulp mills in the United  States.
       The amounts of black liquor solids burned in Kraft black liquor recovery boilers in the
 United States during  1987 and  1995 were 69.8-million metric tons and 80.8-million metric
 tons, respectively (American Paper Institute, 1992; American Forest & Paper Association,
 1997). These activity level estimates are assigned a confidence rating of "high," because
 they are based on recent industry survey data. Combining the emission factor of 0.028 ng
 TEQ/kg of solids combusted with the activity level estimates of 69.8- and 80.8-mHlion
 metric tons in 1987 and  1995,  respectively, indicates that annual emissions from this
 source were approximately 2.0  grams in 1 987 and 2.3 grams in  1995. Based on the
 confidence ratings assigned to the emission factor and activity level estimates, the
 estimated  range of potential annual emissions is assumed to vary by a factor of five
 between the low and high  ends of the range. Assuming that the best estimate of annual
-TEQ emissions in 1987 (2.0 g TEQ/yr) is the geometric mean of this range, then the range

                                        5-23              '                  April  1998

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IS calculated to be 0.9 to 4.5 g TEQ/yr.  For 1995, the range is calculated to be 1.0 to 5.0
gTEQ/yr.

B.8.  OTHER IDENTIFIED SOURCES
      Several manufacturing processes are identified as potential sources of CDD/CDF
formation, because the processes use chlorine-containing components and/or involve
application of high temperatures.  However, no testing of emissions from these processes
has been performed in the United States, and only minimal emission rate information has
been reported for these processes in other countries.
      Burning of Candles - Schwind et al. (1995) analyzed the wicks and waxes of
uncolored candles,  as well  as the fumes of burning candles,  for CDD/CDF, total
              "" ,i!!' '         |   :    ,   ''''".    '     '!' ' ' ' ' '  „ ''• '     '»[•,'         '  '
chlorophenol, and total chlorobenzene content.  The results are presented in Table 5-6.  As
shown in Table 5-6, beeswax contained the highest levels of CDD/CDF and  total
chlorophenols. In contrast, the concentration of total chlorobenzenes in stearin wax was a
factor of 2 to 3 times higher than in paraffin or beeswax. The concentrations of the three
analyte groups were significantly lower in the wicks than jn the waxes.  Emissions of
CDD/CDF from all three types of candles were very low during burning.  In fact, comparison
of the emission factor to the original CDD/CDF concentration in the wax indicates a net
destruction of the CDD/CDF originally presented in the wax.
          '    •''' '!'iii •        ' ' •          . ' •    •     j,1   " •  •   :         :,   '  ,   •
      Information  is not readily available on the volume of candles consumed annually in
the United States.  However, the value of U.S. candle wholesale shipments  in 199.2 was
              "II' I"    . ,   '      .• '     ' '  ,    » i !•,.,(    ,   ,     |   ,
nearly $360 million (U.S. DOC, 1996). Assuming that average wholesale cost per kg of
candle is $1, then the volume of candles shipped was 360-million kg. If it is further
assumed that 75 percent of the candle volume are actually burned and that the CDD/CDF
emissions rate is 0.015 ng/kg, then a rough "what if" estimate of the annual emission from
combustion of candles is 4 mg TEQ/yr.
      Glass Manufacturing - Bremmer et al. (1994) and Douben et al. (1995) estimated
annual emissions of less that 1 gram TEQ/yr from glass manufacturing facilities in The
Netherlands and  the United Kingdom, respectively.  Glass is manufactured by heating to a
temperature of 1,400 to 1,650°C a mixture of sand and, depending on the  type of glass,
    1  ,        'V   '       " • '•'•'•"•  ,,!'..••     . •  .  • ' • •!,' . •  :  ,?,:.;,.'.-:''
lime, sodium carbonate, dolomite, clay,  or feldspar.  In addition, various coloring and
clarifying agents may be added.  Chlorine enters the process as a contaminant (i.e., NaCI)

                                        5-24           ,                    April 1998

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in sodium carbonate (Bremmer et al. 1994). However, the emission factors used by
Bremmer et al. (1994) and Douben et al. (1995) were not reported. Umweltbundesamt
(1996) reported relatively low emission factors  (approximately 0.002 and 0.007 ng TEQ/kg)
for two glass manufacturing facilities in Germany.
       Lime.Kilns - Annual emissions from lime  kilns in Belgium and the United Kingdom
have been reported by Wevers and DeFre (1995) and Douben et al. (1995), respectively.
However, the emission factors used to generate these estimates were not provided.
Umweltbundesamt (1996) reported low emissions (0.016 to 0.028 ng TEQ/kg) during tests
at two lime kilns in Germany.'
       Ceramics and Rubber Manufacturers - Similarly, Douben et al. (1995) estimated
annual emissions from ceramic manufacturers and rubber manufacturers in the United
Kingdom. Lexen et al. (1993) had previously detected high concentrations of CDD/CDF in
emissions from a ceramic manufacturer in Sweden, which occasionally glazed ceramics by
volatilization of sodium chloride in a coal-fired oven.  Lexen et al. (1993) also detected high
                   '.•'.,•'•       •      '             •                  >
pg/L levels of TEQ in the scrubber ;water from the vulcanization process at a Swedish
rubber manufacturer.
                                       5-25                               April 1998

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                            DRAFT-DO NOT QUOTE OR CITE
                          Table 5-1.  CDD/CDF Emission Factors for Cement Kilns




Congener/Congener Group



2.3,7.8-TCDD
1,2,3,7,8-PeCDD
1.2,3,4,7.8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7.8,9-HxCDD
1,2,3,4.6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7.8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1, 2,3,4, 7,8,9-HpCDF
OCDF
Total TEQ (nondetects - 0)
Total TEQ {nondetects = 1/2 DU
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF (nondetects = 0)
Total CDD/CDF (nondetects = 1/2 DL)
Kilns Burning Hazardous Waste
Mean Emission Factor
(12 facilities)
(ng/kg clinker produced)

Nondetects
Set to 1/2
Det. Limit
1.22
3.68
3.90
4.54
6.37
14.58
4.35
18.17
10.96
27.38
16.97
7.22
1.46
10.52
6.68
1.44
1.02

24.45
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR

* 1,443

Nondetects
Set to
Zero
1.21
3.67
3.89
4.54
6.36
14.58
4.34
18.17
10.87
27.26
16.84
7.18
1.43
10.45
6.68
1.42
1.00
24.34

NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
21,443

Kilns Not Burning Hazardous Waste-
Mean Emission Factor
(11 facilities)
(ng/kg clinker produced)

Nondetects
Set to 1/2
Det. Limit
0.020
0.050
0.044
0.058
0.067
0.471
0.751
0.793
0.118
0.253
0.211
0.067
0.021
0.094
0.168
0.022
0.281

0.32
2.14
2.26
6.50
0.92
0.75
7.22
2.13
0.64
0.27
0.28

23.11

Nondetects
. Set to
Zero
0.013
0.038
0.031
0.045
0.053
0.466
0.751
0.792
0.108
0.243
0.202
0.058
0.007
0.089
0.159
0.006
0.255
0.29

2.14
2.26
6.50
0.92
0.75
7.22
2.13
0.64
0.26
0.26
23.08

NR « Not reported



Source: U.S. EPA (1996c)
                                             5-26
April 1998

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                              DRAFT-DO NOT QUOTE OR CITE
                                   Ratio (congener emission factor / total CDD/CDF emission factor)
                        ,0    _          0.005              0.07              6.015              0.02
            2,3,7,8-TCDD
          1,2,3,7,8-PeCDD
        1,2,3,4,7,8-HxCDD
        1,2,3,6,7,8-HxCDD
        1,2,3,7,8,9-HxCDD
      1,2,3,4,6,7,8-HpCDD
      1,2,3,4,6,7,8,9-OCDD
            2,3,7,8-TCDF
        .  1,2,3,7,8-PeCDF
          2,3,4,7,8-PeCDF
        1,2,3,4,7,8-HxCDF
        1,2,3,6,7,8-HxCDF
        1,2,3,7,8,9-HxCDF
        2,3,4,6,7,8-HxCDF
      1,2,3,4,6,7,8-HpCDF
      1,2,3,4,7,8,9-HpCDF
      1,2,3,4,6,7,8,9-OCDF
                     Nondetects set equal to zero.
Figure 5-1.  Congener Profile for Air Emissions from Cement Kilns Burning Hazardous Waste
                                               5-27                                      April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
                    Ratio (congener group emission factor / total CDD/CDF emission factor)
                0.05          0.1          0.15    .      0.2          0.25          0.3
     0.35
       Nondetects set equal to zero.
                              Ratio (congener emission factor / total CDD/CDF emission factor)
                                    0.01               0.02               0.03
                                                                                            0.04
      2,3,7.8-TCDD
    1,2,3,7,8-PeCDD
  1.2,3.4.7,8-HxCDD
  1.2,3,6.7,8-HxCDD
  1.2,3, 7,8.9-HxCDD
 l,2.3.4.6.7,8-SipCDt>
1,2,3,4,6, 7,8.9-OCDD
       2,3.7,8-CDF
    2.3.4.7,8-PeCDF
  1.2,3,4,7,8-HxCDF
  1,2.3,6,7,8-HxCDF
  1,2,3. 7,8,9-HxCDF
  2,3,4,6.7,8-HxCDF
 1,2,3,4,6. 7.8-HpCDF
 1,2,3,4, 7,8,9-HpCDF
1.2,3,4.6, 7,8,9-OCDF
        Figure 5-2.  Congener and Congener Group Profiles for Air Emissions
                   from Cement Kilns Not Burning Hazardous VVaste
                                            5-28
April 1998

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                              DRAFT-DO NOT QUOTE OR CITE
                  Table 5-2. CDD Concentrations in Japanese Cigarettes, Smoke and Ash


Congener/Congener Group

2,3,7,8-TCDD
1 ,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxGDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF

Cigarette .
(pg/g)

ND(0.5)
ND(0.5)
' 2.01
a
a
1,343
257
~

'
:
—
,
•
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, ' —
i
1 ,602
.
13.88
44.9
ND{0.5)
13.41
1,629
257

-
.. "
—
- - •
1,944
Concentrations

Mainstream smoke

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                 DRAFT-DO NOT QUOTE OR CITE

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   TCDJD          PeCDD


   ^H Cigarettes (row 1)


   ^B Ash (row 3)
HxCDD          HpCDD          OCDD


   HH Mainstream Smoke (row 2)
     Figure 5-3. CDD Profiles for Japanese Cigarettes, Smoke, and Ash
                                   5-30
                                                                                 April \ 998

-------
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-------
                          DRAFT-DO NOT QUOTE OR CITE
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            HH Japanese Mainstream (row 1)       HI German Mainstream (row 2)


                Swedish Mainstream (row 3)        ^H Swedish Sidestream (row 4)
         Rgure 5-4. Congener Group Profiles for Mainstream and Sidestream Cigarette Smoke
                                          5-32
April 1998

-------
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                               DRAFT-DO NOT QUOTE OR CITE
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             TCDD  PeCDD  HxCDD HpCDD  OCDD   TCDF   PeCDF HxCDF  HpCDF  OCDF
               1HH China (column 1)



               \' LL Ji Germany (column 4)

  Source: Matsueda etal. (1994)
Fi»-.9M Denmark (column 2)




HIIH United Kingdom (column 5)
                                                                      \ Japan (column 3)
United States (column 6)
                Figure 5-5.  Congener Group Profiles for Cigarette Tobacco from Various Countries
                                                  5-34
                                                    April 1998

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                                DRAFT-DO NOT QUOTE OR CITE
                     Table 5-5.  CDD/CDF Emission Factors for Black Liquor Recovery Boilers


• '.
• • Congener


2,3,7,8-TCDD
1,2,3,7,8-PeCDD,
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1 ,2,3,4,6,7,8-HpCDD
OCDD
2',3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OGDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total TEQ
Total CDD/CDF
U.S. EPA (1987) - 3 Facilities
Mean Emission Factors
(ng/kg feed)
Nondetects
Set to
Zero
0
NR
NR
NR
NR
NR
4.24'
o.o4 ;
NR
NR
, NR ;'
NR
NR
NR
NR
NR '
0.35
• 0.21
0.27
0.80
2.05
4.24
0.95
0.64
1.16
1.05
0.35
NR
1 1 .71
Nondetects
Set to
1/2 Det. Limit
0.04
NR
NR
NR
NR
NR
4.24
0.06
:: NR
NR
NR
NR
NR
NR
NR
NR
0.35
0.36
0.13
1.02
2.05
4.24
1.00
0.77,
1.20
1.05
0^35
NR
12.17
NCASI 1(1995) - 6 Facilities
Mean Emission Factors
(ng/kg feed)
Nondetects
Set to
Zero
0
1 0
0.001
0.003
0.006
0.108
1 .033
0.040
0.030
0.033
0.007
0.012
0.005
0.010
0.024
0
0.040
0.106
0.013
0.104
0.252
1 .033
1 .270
0.370
0.102
0.024 -
0.040
0.028
3.314
Nondetects
Set to
1/2 Det. Limit
0.017
0.019
0.021
0.016
0.020
0.140
1.054
0.053
0.036
0.038
0.022
0.022
0.017
0.024
0.037
0.018
0.066
0.123
0.089
0.122
0.279
1.054
1.275
0.377
0.109
0.040
0.066
0.068
,3.535
Sources: U.S. EPA (T987a); NCASI (1995)
                                                5-3.5
April 1998

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                              DRAFT-DO NOT QUOTE OR CITE
        2,3,7,8-TCDD
     l,2.3.7,8-Pe>6DD
   1.2,3,4,7.8-HxCDD
   1,2,3.6.7.8-HxCDD
   1,2,3,7.8,9-HxCDD
 1,2,3,4,6,7,8-Hp GDD
 i.2,3.4,6,7,8.9-OCpD
        2.3,7.8-TCpF
     1.2.3,7,S-PeCDF
     2.3.4,7.8-PeCDF
   1,2,3,4.7,8-HxCDF
   1,2,3,6.7,8-HxCDF
   1.2.3.7.8,9-Hx6DF
   2.3,4.6.7.B-HxCDF
 1.2.3.4,6,7,8-HpCDF
 l,2.3.4.7.8.S-Hf>CDF
                               Ratio (congener emission factor I total CDD/CDF emission factor)
                                 0.05        0.1        0.1S         0.2         0.2S        0.3
         0.35
                  Ratio (mean congener group emission factor / total CDD/CDF emission factor)
                       0.1                  0.2                 0.3                  0.4
          0.5
             *: NCAS1 (JPffS};
                              *tt mqual to xiro.
Hgure 5-6.  Congener and Congener Group Profiles for Air Emissions from Kraft Black Liquor Recovery Boilers
                                                 5-36
April 1998

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                            DRAFT-DO NOT QUOTE OR CITE
            Table 5-6. Concentrations of CDD/CDF in Candle Materials and Emissions
Wax
Material
Paraffin
Stearin
Beeswax
Paraffin
Stearin
Beeswax
Candle
Component
Wax
Wax
Wax
Wick
Wick
Wick

CDD/CDF
(ng TEQ/kg)
0.59
1 .62
10.99
0.18
0.12
0.08
Concentration
ZChlorophenol
teg/kg)
14.8
32.3
256
1.23
0.94
0.74
ZChlorobenzenes
(/zg/kg)
130
330
120
0.67
0.34
0.35
Emission Factor
CDD/CDF
(ng TEQ/kg burnt wax)
0.015
0.027
0.004 .
. • '
Source:  Schwind et al. (1995)
                                           5-37
                                                                               April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

           6.  COMBUSTION SOURCES OF CDD/CDF: MINIMALLY CONTROLLED
                     AND UNCONTROLLED COMBUSTION SOURCES

 6.1.   COMBUSTION OF LANDFILL GAS
        The U.S. EPA recently promulgated emission standards/guidelines to control
 emissions of landfill gas from existing and future landfills under the Glean Air Act (Federal
 Register, 1996a). These regulations require the relatively largest landfills (i.e., largest on
 the basis of design capacity) in the United States (approximately 312 landfills) to
 periodically measure and determine their annual emission of landfill gas.  Those landfills
 that emit more than 50 metric tons of nonmethane organic compounds (NMOC) annually
 must collect landfill gas and reduce the NMOC content by 98 weight percent through use
 of a control device.  EPA estimates that when implemented, these controls will reduce
 NMOC annual emissions from existing landfills  by 77,600 metric tons. The cost analysis
 supporting this rulemaking based control device costs on open flares, because flares are
 applicable to all the regulated facilities. Assuming that this mass reduction is achieved by
 flares, the corresponding volume of landfill gas that will be burned is approximately
 14-billion m3/yr (based on an assumed default NMOC concentration in landfill gas of 1,532
 ppmv and a conversion factor of 3.545 mg/m3 of NMOC  per 1 ppmv of NMOC [Federal
 Register,  1993d]). EPA estimated that over 100 landfills had some form of collection
 and/or control systems in place in 1991 (Federal Register, 1991b).  Thus, a rough
 approximation of the volume of landfill gas that is currently combusted is 4.7-biIlion m3/yr
 (or 33 percent of future expected reductions).  This estimate is similar to the 2.0- to
 4.0-billion m3 of landfill gas that were estimated in EIA (1994) as collected and consumed
 for energy recovery purposes in 1992. EIA (1992) estimated that between 0.9- and
 1.8-billion m3 of landfill gas were collectedxand burned in  1990 for energy recovery
 purposes.
       Only one study of CDD/CDF emissions from a landfill flare was reported for a U.S.
 landfill (GARB, 1990d).  The TEQ emission factor calculated from the results of this study
 is approximately 2.4 ng TEQ/m3 of  landfill gas combusted. The congener-specific results of
this study are presented in Table 6-1. Figure 6-1  presents the CDD/CDF congener emission
profile based on these emission factors. Bremmer et al. (1994) reported a lower emission
factor, 0.4 ng TEQ/m3, from the incineration of untreated landfill gas in a flare at a facility
located in The Netherlands. No congener-specific emission factors were provided in

                                        6-1                                April  1998

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                         DRAFT-DO NOT QUOTE OR CITE

Bremmer et si, (1994). The average TEQ emission factor for the GARB (1990d) and
Bremmer et al. (1994) studies is 1.4 ng TEQ/m3 of landfill gas combusted.
Umweltbundesamt (1996) reported even lower TEQ emission factors for landfill gas burned
in engines or boiler mufflers rather than in a flare. The reported results for 30 engines and
mufflers tested in Germany ranged from 6.001 to 0.28 ng f EQ/m3 with most values below
0.1 ng TEQ/m3.  However, Bremmer et al. (1994) also reported an emission factor of 0.5
ng TEQ/m3 from a landfill-gas fired engine in The Netherlands.
       The limited emission factor data available were thus judged inadequate for
developing national emission estimates that could be included in the national inventory.
However, a preliminary order of magnitude estimate of the annual TEQ release from this
source category can be obtained  using the estimated volume of combusted gas and the
available emission factors. Combining the estimate of current landfill gas volume that is
combusted (4.7 billion m3/yr)  with the emission factor of 1.4 ng TEQ/m3 of flare-
combusted gas yields an annual emission estimates of 6.6 g TEQ, which, when rounded to
               ,"'|L    "  •   '   • '   »'  r  ',,'' '"• !  ' , "  •    ,   ,'•,','.'  1Ji'i ,   '    I   i
the nearest order of magnitude to emphasize the uncertainty in this estimate, results  in a
value of 10 g TEQ/yr. This estimate should  be regarded as a preliminary indication of
possible emissions from this source category; further testing is needed to confirm the true
magnitude of these emissions.
               ';         •    '•     •  '  "  '              '  l"'1       ' '
6.2.   ACCIDENTAL FIRES
       Accidental fires occurring  in buildings and vehicles are uncontrolled combustion
processes that typically result in  relatively high emissions of incomplete combustion
    .  .  .   •    ••:»   i     •    :.       , •.  ,;•  i' •' '     . ": !;    '   ;";	   •;]•..•
products because of poor combustion conditions (Bremmer et al., 1994). The incomplete
              I  |i  ' .'  i  '• ', i	-.', •, '.'.' '•''  ''.'"•,'. '• '!' . '    - :, ' '•    ' !  '''i'(..'>    '„  j '
combustion products can include CDDs and  CDFs.  Polyvinyl Chloride (PVC) building
              , .'• Ill '  "     ''  ,' '__  •   !   i', ,,  '• I '.  .  •:' ,  '"      . I	! , I  ' '  ' I
materials and furnishings, chloroparaffin-containing textiles and paints, and other
               ''ij	 .'  ,    :..''	i.. ,   •"."• '"  :     '•  •',; .' ,' . : '  ", :'.:,' '      , i '*.','       '  ,
chlorinated organic compound-containing  materials appear to  be the primary sources  of the
chlorine (Rotard, 1993).  Although the results of several studies demonstrate the presence
of CDD/CDF concentrations in soot deposits and residual ashes from such fires, few  direct
measurements of CDD/CDFs in the fumes/smoke of fires have been attempted.  The  results
of several of these studies are described below, followed by an evaluation of the available
data.
                                         6-2                  .              April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

 6.2.1. Soot/Ash Studies
     ,  Christmann et at. (1989b) analyzed the soot formed during combustion and pyrolysis
 of pure PVC and PVC cable sheathings in simple laboratory experiments designed to mimic
 the conditions of fires.  For the combustion experiments, 2 grams of a PVC sample were
 incinerated with a laboratory gas burner.  The combustion products were collected on the
 inner walls of a cooled gas funnel placed above the sample.  For the pyrolysis experiments,
 about 50 mg of the sample were placed in a quartz tutye and heated to about 950°C for 10
 minutes in either an air atmosphere or a nitrogen atmosphere. The combustion experiments
 yielded  CDD/CDF concentrations in soot of 110 /^g TEQ/kg for a low molecular weight PVC,
 450 /^g TEQ/kg for a high molecular weight PVC, and 270 //g TEQ/kg of PVC cable. The
 pyrolysis experiments in the air atmosphere yielded  lower CDD/CDF concentrations in soot:
 24.4 IIQ TEQ/kg for a low molecular weight PVC, 18.7  //g TEQ/kg for a high molecular
 weight PVC, and up to 41 //g TEQ/kg for PVC cable. In general, CDFs were predominantly
 formed  over CDDs. The lower chlorinated CDF congeners were dominant in the
 combustion experiments; however, the HpCDF and  OCDF congeners were dominant in the
 pyrolysis experiments. No CDD/CDFs were detected in pyrolysis experiments under a
                              '                          "•                       .
 nitrogen atmosphere. Also, no  CDD/CDFs were detected when chlorine-free polyethylene
 samples were subjected to the same combustion and pyrolysis conditions.
      Deutsch and Goldfarb (1988) reported finding CDD/CDF concentrations ranging from
 0.04 to 6.6 yug/kg in soot samples collected after a  1986 fire in a State University of New
 York lecture hall. The fire consumed or melted plastic furnishings, cleaning products
 containing chlorine, wood,  and  paper.
      Funcke  et al. (1988) (as  reported in Bremmer et  al., 1994 and Retard, 1993)
 analyzed 200 ash and soot samples from sites of accidental fires in which PVC was     .  ,
 involved. CDD/CDFs were detected in more than 90 percent of the samples at
 concentrations in the ng TEQ/kg to //g TEQ/kg range. Fires involving the combustion of
 materials containing relatively large amounts of PVC and other chlorinated organic
 substances resulted in the highest levels of CDD/CDFs with CDD/CDF concentrations
ranging from 0.2 to 110 A*g TEQ/kg of residue.
      Thiesen et al. (1989) analyzed residues from surfaces of PVC-containing materials
that were partially burned during accidental fires at sites in Germany that manufactured or
stored plastics. CDD/CDF concentrations in residues were reported as 0.5 /^g TEQ/kg for
            i                        •'              .                   "
                                        6-3            ,                   April 1998

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                         DRAFT-DO NOT QUOTE OR CITE
               , i,     ' ,     ' ,         ' ',  lr    "', '"','' V   ''   ' •'      "• '    ' '   '
 soft PVC, 4.6 /zg TEQ/kg for PVC fibers, and 28.3 /^g TEQ/kg for a hard PVC.  The ratio of
 total CDFs to total CDDs in the three samples ranged from 4 to 7. The dominant 2,3,7,8-
 substituted CDF and CDD congeners in all three samples were 1,2,3,4,6,7,8-HpCDF and
 1,2,3,4,6,7,8-HpCDD.
       Following an accidental fire at a Swedish carpet factory in 1987, 200 metric tons of
 PVC and 500 metric tons of PVC-containing carpet burned. Marklund et al.  (1989)
 analyzed snow samples within 1,500 meters downwind from  the fire site and found
 CDD/CDF concentrations in the top 2 cm ranging from 0.32 jug TEQ/m2 at 10 meters from
 the site to 0.01 #g TEQ/m2 at 1,500 meters downwind of the site.  Because of an
 atmospheric inversion  and very light wind at the time of the fire, the smoke  from the fire
  1         ' '   I •         ;'   ,'   •  . i . . . i ,  • • ••   .     .,i     '	 •     I'
                          1 "          '      ''     '"'' :i ' ' '' •  ''   piii  .''!,'
 remained close to the  ground. The soot deposited onto the snow was thus assumed  to be
 representative of the soot generated and released from the fire. Wipe samples of soot from
 interior posts of the plant (5 and 20 meters from the fire) contained EADON  TEQ
 concentrations of 0.18 and 0.05 ^g/m2.  On the  basis of these deposition measurements,
 Marklund et al. (1989) estimated the total CDD/CDF emission from the fire to be less than
 3 mg TEQ.
       Carroll (1996) estimated a soot-associated CDD/CDF emission factor  (i.e., does not
 include volatile emissions) of 28 to 138 ng TEQ/kg of PVC burned for this fire using the
 following assumptions: (1) the PVC carpet  backing was one-half the weight of the carpet;
 (2) the carpet backing  contained 30 percent by weight PVC resin; and (3) 20 to  100
 percent of the PVC and PVC carpet backing present in the warehouse actually burned.
 Carroll (1996) also estimated a similar soot-associated emission factor (48 to 240 ng
TEQ/kg of PVC burned) for a fire at a plastics recycling facility in Lengerich,  Germany.
 Carroll (1996) used the results of wipe samples collected at downwind distances of up to
 6,300 meters from the fire to estimate the emission factor.
       Fiedler et al. (1993) presented a case study of CDD/CDF contamination and
associated remedial actions taken at a kindergarten in Germany following a fire, which
destroyed parts of the roof, windows, and furnishings. Spot collected from  the building
contained CDD/CDFs at a concentration of 45 yug TEQ/kg (or 15 //g TEQ/m2). Fiedler et al.
 (1993) attributed the CDD/CDFs detected to the  combustion of plastic and wooden toys,
            '  Mi!  •   '   ''?  i";  ','' ' '    ,'',   :' :'i;1  '' , "'' :'.'''1' V"' "''?   " '•     .'  : '•••
floors, and furnishings; however, no information was provided on the quantities of these
materials that burned.

                                        6-4                                April 1998

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      Wichmann et al. (1993; 1995) measured the CDD/CDF content of ash/debris and
deposited surface residues that resulted from experimental test burns of two cars (a 1974
Ford Taurus and a 1988 Renault Espace), one subway car, and one railway coach in a
tunnel in Germany. Based on the measurements obtained from sampled ash/debris and
from soot collectors placed at regular spacing up to 420 meters downwind of the burn site,
the total amounts of CDD/CDF in the ash/debris and tunnel surface residues from each
vehicle burn experiment were estimated to  be: 1974 model car - 0.044 mg TEQ; 1988
model car - 0.052 mg TEQ; subway car - 2.6 mg TEQ; and railway coach - 10.3 mg TEQ.
Of these total amounts of TEQ,  73 to 89 percent were accounted for by the tunnel surface
residues and 11 to 27  percent by ash/debris. The average CDD/CDF content of the
ash/debris from each experimental burn was as follows: new car - 0.14 /zg TEQ/kg; old car
-0.30 /j.g TEQ/kg; subway car - 3.1 //g TEQ/kg; and railway coach - 5.1 tig TEQ/kg.

6.2.2. Fume/Smoke Studies
      Merk et a). (1995) collected fume/smoke generated during the burning of 400 kg of
wood and 40 kg of PVC in a closed building (4,500 m3 volume) over a 45-minute time
period.  The sampling device .consisted of dual glass fiber filters to collect particles greater
than 0.5 jum, followed by a polyurethane foam filter to collect vapor phase CDD/CDFs.  The
                                                              i
particulates and gas. phase showed the same congener pattern, decreasing  concentration
with increasing degree of chlorination, thus indicating no preferential sorption of higher
chlorinated  congeners to smoke particulates. However, the CDD/CDF found in  the gas
phase (about 5 ng TEQ/m3) accounted for more than 90 percent of the detected
CDD/CDFs. Merk et al. (1995) also reported that the soot deposited from this fire resulted
in surface contamination of 0.050 //g TEQ/m2.
      Dyke and Coleman (1995) reported  a four-fold increase in CDD/CDF TEQ
concentrations in the ambient air during "bonfire" night  in Oxford, England.  Bonfire night
(November  5) is an annual event in England during which it is customary to set off
fireworks and have bonfires to commemorate a failed plot.to overthrow the king in 1605.
Air concentrations before and after bonfire  night ranged from 0.15 to 0.17 pg TEQ/m3.
The air concentration during the bonfire night was 0.65 pg TEQ/m3. The dominant
congeners in all samples were the hepta- and octa- CDDs.  The study was not designed to
collect data that would enable calculation of an emission rate nor to differentiate the

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                          DRAFT-DO NOT QUOTE OR CITE

relative importance of the various materials combusted.  However, the results do indicate
that open burning of materials likely to be combusted in accidental fires (with the exception
               1 ,;                «       .  .   . .   .     .      .
of fireworks) results in the release of CDDs and CDFs.

6.2.3. Data Evaluation
       Structural Fires - The limited data avai|ab|e were judged inadequate for developing
national emission estimates that could be included in the national inventory. This
conclusion was also reached in national emission inventories developed for The Netherlands
(Bremmer et al., 1994) and the United Kingdom (UK Department of the Environment,
1995). Most cited studies involved situations (i.e., field and laboratory) where relatively
high loadings of PVC or plastics were combusted. The effects of different  mixes of
combusted materials, oxygen supplies, building configurations, durations of burn, etc. likely
to be found in accidental fires cannot be accounted for by the factors that can be derived
from these studies. Also, most of these studies addressed only soot and/or ash residues
           •  "J    "'  .. ; -  •'• '•  '' ••'•.•". •'  "".'';•'' .;•;,:•:  ,•'  i :"'- ?/"  ' "  !  ••'   : •  . . •• '   :  •, '
and did not address potential volatile emissions of CDD/CDFs which, according  to Merk et
a|. (1995), may represent 90 percent of the CDD/CDFs generated during burning of PVC.
           " :  ..•!•,  	    ., \   .. :': ', i ;i  '•  ':;' :, M  .- ' ;•,[••:;, ;<;"!  ;: '„,! v     • j   • J  ,
       Two recent reports (Carroll, 1996; Thomas and Spiro, 1995) attempted to quantify
CDD/CDF emissions from U.S. structural fires, and Lorenz et al. (1996) estimated emissions
         ,;  '   ':il;   •   .   • ':''  V, .•!'	  .  .,,•::  :.:•',,;;  	$• 'v-'f'-'   .:••"•
from structural fires in the Federal Republic of Germany.  The estimates derived in these
three studies are presented below, following a brief summary of the number of  accidental
fires reported annually in the United States.
       In 1995, approximately 574,000 structural fires were reported in the United States
(U.S. DOC,  1997).  Of these, 426,000 were reported for  residential structures, which
consist of 320,000 fires in 1 -2 family units, 94,000 fires  in apartments, and 12,000 fires in
             "I  .."I  .    •  • '.  "  ,    • . !     ""   ."  •  . •  .'     i  '. I  •'• •     I
"other" residential settings. The remaining  148,000 structural fires consist of 15,000 -
public assembly; 9,000 - educational; 9,000 - institutional; 29,000  - stores and offices;
29,000 - special structures; 39,000 - storage; and 18,000 - industry, utility, and defense.
        '  •    '  i£i    '  ' •',     '' ;      ' ' ' '•' ' , ' ' . I ''! ;  •" I; ''";''"  ""	"r';M .'•'! '. '  [
The latter two categories may be under reported  as some, incidents  were handled by private
fire brigades or fixed suppression systems, which do not report (U.S. DOC, 1997).
       Carroll (1996) estimated the total CDD/CDF content  of soot  and ash generated from
the 358,000 fires reported in U.S. DOC (I995a) for 1993 in 1-2 family unit residential
structural fires. The estimated soot/ash content ranged from 0.47 to 22.8 g TEQ with

                                         6-6                                 April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 0.07 to 8.6 g TEQ in soot and 0.4 to 14.2 g TEG. in ash.  Carroll {1996} then developed
 detailed estimates of the PVC content of typical homes (including plumbing, wiring, siding
 and windows, wallpaper, blinds and shades, and  upholstery), and, using statistical data on
 fire loss (i.e., dollar value), the typical loss per recorded fire (9.5 percent) was assumed to
 represent the typical percentage of PVC present that is burned. Extrapolating to all
 358,000 1-2 family unit fires yielded an annual mass of PVC burned of 2,470 metric tons.
 Carroll (1996) then developed TEQ emission factors from the results of Thiesen et al.
 (1989) and Marklund et al. (1989) using a soot emission factor (i.e., grams of soot
 produced per gram of PVC combusted) derived by Carroll (1996) based on assumptions
 regarding the surface area of the soot collection funnel used by Marklund et al. (1989) and
 the soot deposition rate on that funnel.  These TEQ emission factors were then applied by
 Carroll (1996) to the estimated 2,470 metric tons of PVC  burned annually in 1-2 family unit
 residential fires to obtain estimates of the annual  mass of TEQ that would be found in the
 soot and ash of  residential fires (I.e.,.0.48 to 22.8 g TEQ/yr). If the conclusion of Merk et
 al. (1995) that 90 percent of the' CDD/CDFs formed in fires are in the gaseous phase rather
 than paniculate  phase (i.e., greater than 0.5 //m diameter) is assumed, to be correct, then
 the volatile CDD/CDF emissions corresponding to  the range of soot/ash emissions estimated
 by Carroll (1996) total 4.3 to 205 g TEQ/yr.  There is very low confidence in these
 estimated emissions because of the numerous assumptions employed in their derivation.
       Thomas and Spiro (1995) estimated that 20 g of TEQ may be released annually to
 air from structural fires.  This estimate assumed an emission factor of 4 ng TEQ/kg.of
 material combusted (i.e., the emission rate for "poorly controlled" wood combustion), an
 assumed material combustion factor of 6,800 kg/fire, and 688,000 structural fires/yr.
       Lorenz et al.  (1996) estimated annual generation of CDD/CDF TEQs in the Federal
 Republic of Germany using data on the number of residential and industrial/commercial
 structural fires coupled with data on CDD/CDF content in soot and ash residues remaining
 after fires.  The potential annual TEQ generation was estimated to be 78 to 212 grams.
       Vehicle Fires - The limited data available were judged inadequate for developing
 national emission estimates that could be included in the national inventory.  However, a
preliminary order of magnitude estimate of the range of potential CDD/CDF emissions that
may result from vehicle fires can be estimated using'the results reported by Wichmann, et
al. (1993; 1995) for controlled vehicle fires in a tunnel (0.044 mg TEQ for an old  car to 2.6
                                        6'7                                April 1998

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                       .    DRAFT-DO NOT QUOTE OR CITE

 mg TEQ for a subway car). Although Wichmann et al. (1993; 1995) did not measure
 volatile CDD/CDFs (which were reported by Merk et al. (1995), to account for the majority
 of CDD/CDFs formed during a fire), the study was conducted in a tunnel, and it is likely
 that a significant fraction of the volatile CDD/CDFs sorbed to tunnel and collector surfaces
 arid were thus pleasured as surface residues. In 1995, approximately 406,000 vehicle fires
 were reported in the United States (U.S. DOC, 1997). If it is assumed that 99 percent of
 the 406,000 reported vehicle fires in 1995 involved cars and trucks (i.e., approximate
 percentage of in-service cars and trucks to .total of  all motor vehicles, U.S. DOC (1995a)
        • i.  .    ',;,*  "'      ;' ,    :, , "'-i, > •• ,i;' ,i."  i'v .. ••  : t V;  '"  •, '  i. ..;•   •  •       .
 and that the applicable emission rate is 0.044 mg/TEQ per incident, then the annual TEQ
 formation is 17.7 g TEQ.  The emission factor of 2.6 mg TEQ/fire is assumed to be
 applicable to the remaining 1 percent of vehicle fires, thus yielding an emission of 10.6 g
 TEQ/yr. The total TEQ annual emission is roughly estimated to be 28.3 g TEQ/yr, which,
 .when rounded to the nearest order of magnitude to emphasize the uncertainty in this
 estimate, results in a value of 10 g TEQ/yr.  This estimate sould be regarded as a
   ,'lli1 • , ,     '...'I1 ,11" fill'l!  ' .   '!    „ "  '.i	i   I! •' ' '-  ! '.III,;!'1 'M ', ' , "" I 	   ' ' ' ,'"! '- , '  , '  i!" ! ' ',       I '
 preliminary indication of possible emissions from this source category; further testing is
   f.l      ".  "•  " .-  	"i!!   	    ' !'T	! •-   •"•	"'  .':•.'•.   ' "I," ' ••:••, '!	•' ''  ,'. +, .  .      r.        a
         „       , "HI,!, " i „   ,    i,,, ,  n '   ,i ,'i f    ' ,, '     ! 'i    ''  ™i» '" '  ' "  ""         I
 needed to confirm the true magnitude of these emissions.
         '    .-•'   ^  .   ',  '•'. '  . >'•'  '•'•>•'••'•  '• '• '.' '  : ':     ; '.,  • •':^..'1  >'::"•.•     :
 6,3.   LANDFILL FIRES
         1 ' '  • ,  *"i:!'  '    •   . '.'' ]   •'••'•,  •., - .-:  ' >• / '• '  v -,; ... '''!: -'•;  ,;.i'. .''    .•!'•••
       In the late 1980s, two serious fires occurred in landfills near Stockholm, Sweden.
   	      •       	            •    •     •     ,  , ,    	 4,  ,   	        1
 The first involved a fire in a large pile of refuse-derived fuel.  Based on measurements of
 chjorpbenzenes  in the air emissions, it was estimated that 50 to 100 kg of chlorobenzenes
 were released,  COD/CDF emissions were estimated to be several 10s of grams based on
 the assumption  that the ratio of CDD/CDFs to chlorobenzenes in landfill fire emissions is
   »'i	   ,       , Hi!!!     ,    .  "  "|i '  ,,,'t, '. i  	„ • ,    !•,„••   	, ,,;- ,  ,•  i "	 , ,    ; ,
 similar to the ratio observed in stack gases of municipal waste incinerators.  In connection
 with the second fire, which occurred at a large conventional landfill, birch leaves were
 collected from trees close to the fire and at distances up to 2 km downwind of the fire, as
   .I.;!,,"     „     . •  jPfli'    '. •.',... ! '"V.:,": „" ':, ''  '' ," '.'"'.i "•'• . •' '• I' ' '''  ' ':'.'J	M • ',.''. '  :« , - : '..:i"  'j    ,'      '
 well as from nearby areas not impacted by smoke from the fire.  The discharge of CDD/CDF
 necessary to cause the CDD/CDF concentrations measured on the leaves was estimated to
   i.1;,    .  "' • "      ..i	 •,  '    ' • ' i ,  •;> '  .!•,.•   „ i, '  ' : •,: •.•' ' M:.'I«, "v.:.- ',, ."   s	r..,	, ,  ,       . '"'
 be several 10s of grams (Persson and Bergstrom, 1991).
       In response to these incidents, Persson and Bergstrom (1991) measured CDD/CDF
 emissions from experimental fires designed to simulate surface landfill fires and deep landfill
   .        .»     ..'I:1;.	  f  '   ,; i .  ; .',"  ' .y • „..  ./ .,,	„ :'  I'111."',:",  .','". i,	'.,w , •  , ' ,*''•'	 , . >      > •
fires. The experiments used 9-month old domestic waste. The tests showed no significant

                                         6-8                                 April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
                        -^'      "•                        '
 difference in CDD/CDF content of the fire gas produced by the simulated surface and deep
 fires. The average CDD/CDF emission rate was reported to be 1 ^g Nordic TEQ/kg of
 waste burned. Persson and Bergstrom (1991) and Bergstrom and Bjorner (1992) estimated
 annual CDD/CDF TEQ emissions in Sweden from landfill fires to be 35 grams.  The estimate
 was based on the emission rate of 1 ^g Nordic TEQ/kg waste burned, an assumed average
 density of landfill waste of 700 kg/m3, an assumed waste burn of 150 m3 for each surface
 landfill fire (167 fires in Sweden per year), and  an assumed waste burn of 500 m3 for each
 deep landfill fire (50 fires in Sweden per year).  The estimates of waste burn mass for each
 type of fire were the average values obtained from a survey of 62 surface fires and 25
 deep fires. The estimated number of fires per year was based on the results of a survey of
 all Swedish municipalities for fires reported during the years 1988 and 1989. Sweden has
 an estimated 400 municipal landfills (Persson and Bergstrom, 1991).
       Ruokojarvi et al. (1995) measured the ambient air concentrations of CDD/CDF in the
 vicinity of real and experimental landfill fires in Finland. The most abundant toxic
    f
 congeners were the hepta- and octa-CDDs and the penta-, hepta-, and octa-CDFs. The
 highest contributions to the measured TEQ were made by 1,2,3,7,8-PeCDD and 2,3,4,7,8-
 PeCDF. In Finland/annual CDD/CDF emissions  from landfill fires are estimated to be 50-70
 g  Nordic TEQ (Aittola, 1993 - as reported by Ruokojarvi et al., 1995).
       Although no U.S. monitoring studies are available, an emission  factor similar to the
 Swedish emission factor would be expected in the United States, because the contents of
 the municipal waste are expected to be similar between the United States and Sweden.
 However, because no data could be located on characterization of landfill fires in the United
 States (i.e., number, type, mass of waste involved), the limited data available were judged
 inadequate for developing national emission estimates that could be included in the national
 inventory. However, a preliminary order of magnitude estimate of  the potential magnitude
 of TEQ emissions associated with landfill fires in the United States can be obtained by
 assuming a direct correlation of emissions to population size for the United States and
 Sweden or by assuming a direct correlation between emissions and the number of landfills
 in  each county. Both countries are Western, industrialized countries. Although the per
 capita waste generation rate in the United States is nearly 1.5 times that of Sweden, the
 composition of municipal waste and the fraction of municipal waste disposed of in landfills
in the two countries are nearly identical (U.S. EPA, 1996b). The 1995 population of
                                        6-9
                                                                           April 1998

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    ,.  .     .     ;      •  •  ...	.    •:     .. .(.-'.-,       ,   ..   -  .  ••
                        .  DRAFT-DO NOT QUOTE OR CITE

 Sweden is 8,822,000 {U.S. DOC, 1995a). Thus, the per capita landfill fire-associated TEQ
 emission factor is 4.0 ^g TEQ/person/year (i.e., 35 grams/8,822,000 people). Applying
 this factor to the U.S. population (263,814,000) (US. DOC, 1995a) results in an estimated
 annual emission of 1,050 g of TEQ.  When rounded to the nearest order  of magnitude to
 emphasize the uncertainty in this estimate, the estimated annual emission is 1,000 g
 TEQ/yr. This estimate should be regarded as a preliminary indication of possible emissions
 from this source category; further testing is needed to confirm the true magnitude of these
 emissions. An annual emission of similar size is obtained if it is assumed that the ratio of
 annual TEQ emissions to number of landfills in Sweden, 87.5 mg TEQ/landfill (i.e., 35
 grarns/400 landfills), is applicable to the United States,  which has 3,558  landfills (U.S.
 EPA, 1996b). The resulting annual emission estimate is 311  g TEQ/yr.

 6.4.    FOREST AND BRUSH FIRES
        Because CDD/CDFs have been .{detected both in the soot from residential wood
 burning (Bumb et al.; 1980; Nestrick and Larnparski, 1982 and 1983; Bacher et al.,  1992),
 and in the flue gases from residential wood burning (Schatowitz  et al.; 1993; Vickelsoe et
 al., 1993)  [Section 4.2 contains details on these studies], it is reasonable to presume that
 wood burned in forest and brush fires may also be a source of CDD/CDFs.
       Only one study could be found that reported direct measurements of CDD/CDFs in
 the emissions from forest fires. This study, by Tashiro et al. '(1990), reported detection of
 total CDD/CDFs in air at  levels ranging from about 15 to 400 pg/m3. The samples were
 collected from fixed collectors 10m above the ground and from aircraft flying through the
 smoke. Background samples collected before and after the tests indicated negligible levels
 in the atmosphere.  These results were presented in a preliminary report;  however, no firm
 conplusions were drawn  about whether forest fires are a CDD/CDF source.  The final report
 on this study,  Clement and Tashiro (1991), reported total CDD/CDF levels in the smoke of
 about 20 pg/m3. The authors concluded that  CDD/CDFs are emitted during forest fires but
 recognized that some portion of these emissions could represent resuspension from
 residues deposited on leaves rather than newly formed CDD/CDFs.
                •..,j!',   i '' .•:'.'& ','•. 'iii;	! v1!]1'!", ' i''i'.'iLlii'.'i'.,!':'i':'"'''j'::i :'V'1'! '':V;i 'K  '""'kV; ;:  '.   i" '
      Although not designed to directly assess whether CDD/CDFs are formed during
               	 „ ',« '  !'.',,      " „ I'.,, „• ,'	 ,„ ,"j,,,,j,M., •„ „',. ,;,,',,'"..„!; '!', ',,  If  "V  Ij ,"111." •",,:,.! " i!'"., If '  .IS', i,,, , , ', '     !          *•'
brush fires, Buckland et ah (1994} measured the Cpp^CDF levels in soil samples from both
burnt and unburnt areas in national parks in New Zealand 6 weeks after large-scale brush
                u'lifliil.  : • '  ' •-.,,,  "h,,J," ' '     ,•,''''  '  ' • ,  ' "	 ".i  !''':''.' «   	   • '                  *
                .'"if • ''..'.   ; ••  i;-  :,    "6-10  .  ,	., ,	  t ^ ^.      t     ,   April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

  fires. Four 2-cm deep surface-soil cores were collected and composited from each of three
  burnt and three unburnt areas. Survey results indicated that brush fires did not have a
  major impact on the CDD/CDF levels in soil.  The TEQ content in the three unburnt area soil
  sample composites were 3.0 ng/kg, 8.7 ng/kg, and 10.0 ng/kg. The TEQ content in the
  three burnt area soil sample composites were 2.2 ng/kg, 3.1 ng/kg, and 36.8 ng/kg.  Total
  CDD/CDF content ranged from 1,050 to 7,700 ng/kg in the unburnt area soil samples and
  from 1,310 to 27,800 ng/kg in the burnt area soil samples.  OCDD accounted for 94 to 97
  percent of the total CDD/CDF content in all samples.
       Similarly, a survey of controlled straw field burning in the United Kingdom (Walsh et
  al., 1994) indicated that the straw burning did not increase CDD/CDF burden in the soil;
  however, a change in congener distribution was observed.  Soils from three fields were
 sampled immediately before and  after burning, along with ash from the fire.  The mean TEQ
 concentrations in the pre-burn soil, post-burn soil, and field burn ash were 1.79 ng/kg, 1.72
 ng/kg, and 1.81 ng/kg, respectively.  Concentrations of 2,3,7,8-TCDF were lower in the
 post-burn soils than in the pre-burn soils. Conversely, the concentrations of OCDD were
                                                                        \
 higher in the post-burn soils indicating possible formation of OCDD during the combustion
 process.
       Van Oostdam and Ward (1995) reported finding no detectable levels of 2,3,7,8-
 substituted CDD/CDFs in three soil samples and four ash samples following a forest fire in
 British Columbia. The detection limits on a congener-specific basis (unweighted for TEQ)
 ranged from 1  to 2 ng/kg.  Nondetected values were also reported by Van Oostdam and
 Ward (1995) for ashes at a slash and burn site; the soil contained about 0.05 ng TEQ/kg,
 whereas background  soil contained about 0.02 ng TEQ/kg.
      The concentrations presented by Clement and Tashiro (1991) cannot accurately be
 converted to an emission factor, because the corresponding rates of combustion gas
 production and wood consumption are not known. As a  result, three alternative
 approaches were considered to develop these emission factors:

 •     Soot-Based Approach:  This approach assumes that the level of CDD/CDFs in
chimney soot are representative of the CDD/CDFs  in emissions, and estimates the
CDD/CDF emission rate as the product of the soot level and the total particulate emission
rate; This involves first assuming that the CDD/CDF levels measured by Bacher et al.
                                       6-11                               April 1998

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                       .   DRAFT-DO NOT QUOTE OR CITE

 (1992) in chimney soot (720 ng TEQ/kg) are representative of the CDD/CDF concentrations
 of particles emitted during forest fires. Second, the total paniculate generation rate must
 be estimated.  Ward et al. (1976) estimated the national average paniculate emission factor
 for wildfires as 150 Ib/ton bipmass dry weight based primarily on data for head fires. Ward
 et al. (1993) estimated the national .average paniculate emission factor for prescribed
   • •      "     •  «•:,: •   ,    . : '.  , '",i  ' ".  . , '": .\f  i " ,. .1 •'. • •  ': .[  .-.	: : ',; ,,/;	• ; i;" . :.
 burning as 50 Ib/ton biomass dry weight.  Combining the total paniculate generation rates
 with the CDD/CDF levels in spot yields emission factor estimates of 54 //g of TEQ and
 18 (*g of TEQ/metric ton of biomass burned in wildfires and prescribed burning,
 respectively. This corresponds to a range of  54 to 18 ng TEQ/kg of biomass. This
 estimate is likely to be an overestimate, because the levels of CDD/CDF measured in
 chimney soot by Bacher et al. (1992) may represent accumulation/enrichment  of CDD/CDFs
 measured in chimney soot over time, leading to much higher levels than what is actually on
                                     *            •          '
 erpltted particles.

 •      Carbon  Monoxide (CO) Approach: CO is a general indicator of the efficiency of
 combustion and the emission rate of  many emission products can be correlated to the CO
 emission rate. The Schatowitz et al. (1993) data  for emissions during natural wood burning
 in open stoves  suggest ah emission rate of 10 A/g tEQ/kg of CO. Combining this factor
 with the CO production rate during forest fires (roughly 0.1 kg CO/kg of biomass - Ward et
 al. (1993)} yields an emission factor of 1,000 ng  TEQ/kg biomass.  This factor appears
                                              ,'               '  f
 unreasonably high, because it is even higher than the soot-based factor discussed above.
 Although the formation kinetics of CDD/CDF during combustion are not well understood, it
 appears that CDD/CDF emissions do not correlate well with CO emissions.
                                                        ,.,",,                 V
 •      Wood Stove Approach:  This approach assumes that the emission factor for
               ,  «•!:.  ;;' :  • ,   :  ••:-. •• •, <•:'• •' .^r .•, "   ••:• •,•<,.•.•"•• ;,	;.'  : ••••: ,'.,••     •
 residential wood burning (using  natural wood and open door, i.e., uncontrolled  draft) applies
 to forest fires.  As, discussed in  Section 4.2.1, this approach suggests an emission factor of
   '"i1    ,    ,     '!ii ,.:,|||'i  „  ''i  	 , 'I'll	" I ,ir !• il   ' „,','• ''• ! '. 'i ' .',""' ',! ' ii'j'lll'1''!!, '"' I I'! ', ,»'' '" in' : i !l!!i'''l"i: „' i" . I ;    I    '      '
 about 2 ng TEQ/kg of wood burned. This value appears more reasonable than  the factors
 suggested by the spot and CO approaches. However, forest fire conditions differ
 significantly from combustion conditions in wopd stoves.  For example, forest fire
 combustion does not occur in an enclosed chamber, and the biomass consumed in forest
fires is usually green anc| includes underbrush, leaves, and grass.  Given these differences
                                               '' ,  	   t	

                                        6-12                                April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

  and the uncertainties about the formation kinetics of CDD/CDF during combustion, it is
  difficult to determine whether CDD/CDF emissions would be higher or lower from forest
  fires than from wood stoves.  Thus, although an emission factor of 2 ng TEQ/kg appears to
  be the best estimate that can be made currently,  it must be considered highly uncertain;
  therefore, a "low" confidence  rating was assigned to this estimate.
        According to the Council on Environmental Quality's 25th Annual Report (CEQ,
  1997), 5-million acres of forest were lost to wildfires in  1987 and  7-million acres were lost
  in 1995. Estimates of the acreage consumed annually during prescribed burnings are not
  readily available for the reference years 1995 and 1997.  An estimated 5.1 -million acres of
  biomass were burned in 1989 during prescribed burns (Ward  et al., 1993). Prescribed
 burning is also known as managed or controlled burning and is used as a forest
 management tool under exacting weather and fuel conditions. This value of 5.1-million
 acres is assumed to  be an appropriate value to use for reference years 1987 and 1995.
       Combining these acreage estimates with biomass consumption rates of 9.43 metric
 tons/acre in areas consumed by wildfires (Ward et al., 1976)  and 7.44 metric tons/acre in
 areas consumed in prescribed burns (Ward et al., 1993), indicates that 47-million metric
 tons of biomass were consumed in  1987 by wildfires, 66-million metric tons of biomass
 were consumed in 1995 by wildfires, and 38-million metric tons of biomass were
 consumed in 1987 and in 1995 by prescribed burns.  These estimates were assigned a
 "medium" confidence rating, because they are based on a combination of estimates
 involving historical data on acres burned but less certain estimates  of biomass burned/acre.
       Combining the emission  factor developed using the "wood stove" approach (i.e., 2
 ng TEQ/kg biomass) with the amount of biomass consumed annually in wildfires and
 prescribed fires (total of 85-million metric tons in 1987 and 104-million metric tons in
 1995) indicates that the TEQ emissions from this source were 170  g in 1987 and 208 g in
 1995.  Based on the  low confidence rating given to the emission factor, the estimated
range of potential annual emissions is assumed to vary by a factor of 10 between the low
and high ends of the range.  Assuming that the best estimate  of emissions in 1987 (170 g
TEQ/yr) is, the geometric mean of this range, then the range is calculated to be 53.8 to 538
g TEQ/yr.  The range for 1995 is calculated to be 64.5 to 645 g TEQ/yr.
                                                                          April 1998

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 6.5    BACKYARD TRASH BURNING
        In many rural areas of the United States, disposal of residential solid waste may take
 place via open backyard burning in barrels or similar home-made devices. Although no
   	i,   •  	;;  f    "?_ ;     ,    .; '; ;   •  ,   \	:: _/":, :  :, '„ ,  , L, -,_,,:;;; , ^ ',,;. , iy:;'       •;       °
 national statistics on the prevalence of this practice have been reported, the results of a
 telephone survey conducted  in the early 1990s of residents in five central Illinois counties
 indicate that aboyt 40 percent of the residents  in a typical rural Illinois county burn
 household waste (Two Rivers Region Council of Public Officials and Patrick Engineering,
 1994). The survey also  found that, on average, those households that burn waste dispose
 of approximately 63 percent  of their household  waste through burning in barrels (Two
 Rivers Region Council of Public Officials and Patrick Engineering,  1994).
       The low combustion temperatures and oxygen-starved conditions associated with
 these devices may result in incomplete combustion and increased pollutant emissions
 {Lemieux,  1997). EPA's Control Technology Center, in cooperation with the New York
 State Departments of Health  (NYSDOH) and Environmental Conservation (NYSDEC),
 recently conducted a study to examine, characterize, and quantify emissions from the
 simulated open burning of household waste materials in  barrels {Lemieux, 1997). A
 representative waste to be burned was prepared based on the typical percentages of
 various waste materials disposed by New York State residents; hazardous wastes (i.e.,
 chemicals, paints, oils, etc.) were not included in the test waste.  A variety of compounds,
 Including CDD/CDFs, were measured in the emissions from the simulated open burning.
 The measured CDD/CDF  TEQ emission factor for waste,  which has not been separated for
 recycling purposes, was 0.14 ^g TEQ/kg of waste burned (setting not detected values
 equal to zero) and 0.3 jjg TEQ/kg (setting not detected values equal to one-half the
 detection limit).
                 "•I,.'', i '   n    " ,'  i ,  i 	  j  • "„,  ,!••'!    . "    , '• '.'  'i! • .   t "• '''i,::',  	    !i     ''.!'
       The limited emission faptprH and activity level data available were judged inadequate
   :   •!       . . 	'  !"* ;>  '  ' , "'.  ill'  'Vi'!ii  ;" :"'' '," '•: •-'.•••'.. ' -.'  :••; , > ; :  ' •>•	:, "•; J '.ff.'~ - '••' >:' ••.,,  i
for developing national emission estimates that could be  included  in the national inventory.
The number of households  nationwide burning waste in barrels is unknown. The emission
factor was developed on  the  basis of just two experiments.  The representativeness of the
trash  and burning conditions used in the experiments to rural conditions nationwide are
unknown.  However, combining the emission factor of 6.14//g TIEQ/kg of waste burned
with the following information/assumptions, allows a preliminary order of magnitude
                  Si •  •   i,-   ' •  '"";.    '   .. •    ,i;l ::'    .. r r.M^vj, ••  : :  i .'.;;•'.    i     ,,
                                        6-14
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\         '                        i           s                      .
  estimate to be made of potential national CDD/CDF TEQ emissions from backyard
  household trash burning.
        .'' i     - .        ,         •   '     -         -       - •           .
        -,  Forty percent of the rural population in the United States are assumed to burn
           tneir household waste in a barrel (Two Rivers Region Council of Public Officials
           and Patrick Engineering, 1994).           '   ,
        -   On average, each U.S. citizen generates 3.72 pounds of solid waste (excluding
           yard waste) per day (or 616 kg/person-yr) (U.S. EPA, 1996b).        ,
        -   On average, for those individuals burning household waste, approximately 63
           percent of waste generated are burned (i.e.,. 63 percent of 616 kg/person-yr =
           388 kg/person-year) (Two Rivers Region Council  of Public Officials and Patrick
           Engineering, 1994).

        -   In 1992, 51.8-million people lived in nonmetropolitan areas (U.S. DOC, 1997).
 Emissions    = (51.8 x 106 peoplej(40%)(388 kg/person-yr) (0.14 //g TEQ/kg)(1Q-6 q///q)
              = 1,125 g TEQ/yr ,
        When rounded to trie nearest order of magnitude to emphasize the uncertainty in
 this estimate, the estimate of 1,125 g  TEQ/yr  results in a value of  1,000 g TEQ/yr.  This
 estimate should be regarded as a preliminary indication of possible emissions from this
 source category; further testing is needed to confirm the true magnitude of these
 emissions.
 6.6.   UNCONTROLLED COMBUSTION OF POLYCHLORINATED BIPHENYLS (PCBS)
       The accidental combustion of PCB containing electrical equipment or intentional
 combustion of PCBs in incinerators and boilers not approved for PCB burning (40 CFR 761)
 may produce CDDs and CDFs.  At elevated temperatures, such as in transformer fires,
 PCBs can undergo reactions to form CDF and other by-products. More than 30 accidental
 fires and explosions involving PCB transformers and capacitors in the United States and
 Scandinavia, which involved the combustion of PCBs and the generation of CDDs and
 CDFs, have been documented (Hutzinger and Fiedler, 1991b; O'Keefe and Smith,  1989;
 Williams et al., 1985). For example, analyses of soot samples from  a Binghamton, New
 York, office building fire detected 20lyag/g of total CDDs (0.6 to 2.8  /^g/g of 2,3,7,8-TCDD)
 and 765 to 2,160 //g/g of total CDFs with 12 to 270 //g/g of 2,3,7,8-TCDF. At that site,
the fire involved the combustion of a mixture containing PCBs (65 percent) and

                                       •6-15                                April 1998

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                             DRAFT-DO NOT QUOTE OR CITE

   chlorobenzene (35 percent). Laboratory analyses of soot samples from a PCB transformer
   fire, which occurred in Reims, France, indicated total CDD and CDF levels in the range of 4
   to 58,000 ng/g and 45 to 81,000 ng/g, respectively.
          Using a bench-scale thermal destruction system, Erickson et al. (1984) determined
   the optimum conditions for CDF formation to be 675°C,  an excess oxygen concentration of
   1  * > '     i   , . •  • in , '	  .• .'.;  i" *  1  ' .', /I''.!!,;,: . ,-. (.•••>,,: ',•:.•!• • i-;rv 	•. »,;, , /,;,,, ,..,.[
   8 Percent:r anc? a residence time of Qf8 seconds or longer. Combusting mineral oil and
   s''?cone °'' c°.ntairjjng 5, 50, and 500 ppm of Aroclqr 1.254 at these conditions for 0.8
   seconds yielded PCB to CDF conversion efficiencies as high as 4 percent.  Up to 3 percent
   conversion efficiency was observed when an askarel (70 percent Aroclor 1260) was
   combusted  under the same conditions.
         The use of PCBs in new tr;ansfprrners in the United States is banned, and their use in
   existing transformers and capacitors is being phased out  under regulations promulgated
   under the Toxic Substances Control Act (TSCA).
         Because of the accidental nature of Jhese incidents, the variation in duration and
   intensity of  elevated temperatures, the variation in CDD/CDF content of residues, and
   uncertainty  regarding the amount of PCBs still in-service in electrical equipment EPA
     •'"''' '  "    ',  , i;'Ti  :'; •", v"':; J"''1''''",':!" ',••'•'•*• '•'' 'i1'"1;'1' i1"1""'1'"" /'" ''? '•  ''".i ;:';  "*;•''.•'   •  \.
  judged the available data inadequate to support even an order of magnitude estimate of
   annual CDD/CDf emissions.  However, Thomas and Spiro (1995) conservatively estimated
      v '"  •    .;•'•• '„,  .i':;  '.,•	 ' i.: :  ,ii;,'.';: n ;•:'•.  i! ..• ;v> i1 i' •:•"	•:•'),•: ;i i iiVi1'.'   ': ;;f • ;>:f' "    '!'•'.'•
  that about 15 g of TEQ may be generated annually from fires in commercial and residential
     j>: .:    •"     ' i"!"1]  '  ..,"'• :>'",ii,::v .'.ill'" ."i i ':'' :•': i-:," *•• t /'' !;. /''". •,"  ' i '"i,',v\'i •<:  ' , >E •„•>•'.,. : ,'  i  •
   buildings each year. This estimate is based on the following assumptions:  (1) a TEQ
  em'?sion rate of 20= -"9/k9 of PCB burned; (2) 74,000 metric tops of PCB are still in use in
  varipus  electrical equipment; and (3) 1 percent of the in-use PCBs is burned during the
  course of structural fires annually.

  6.7.  VOLCANOES
        To date, no studies demonstrating formation of CDD/CDFs by volcanoes have been
     1 '        , ,   'I'iiu n.| ""• "'. ,„ " , :	»„'!', :	If « 'i  ,:,.!• ' " •  n,;!i,, '.|•,'':« r i:" t K '!• ' 	 f „'",!	 ..   !!; ,.;„»,     , ,   • ,    . .
  published. Gribble (1994) summarized some of the existing information on the formation of
  chlorinated compounds by natural sources, including volcanoes.  Gribble (1994) reported
  that several studies had  demonstrated the presence of chlorqf luorocarbpns and simple
  halogenated  aliphatic compounds (one and two carbon chain length) in volcanic gases. In
  addition, several chlorinated monoaromatic compounds as well as three PeCB conaeners
i      ',„  '    ,   J   ..ilsil,11! •: i»	' •  ."'' ' i1''r i „;'lit	i/ in!'i!" „ ,,ii , i ,". • '•  'i'1!1 ,;,'  », u '< •• "?i:  " n lift' ',!,«' n, ,HI "i	"!,,ri  ,, /iHniih ., •	 : i      .  *3
  were reported as having been detected in the ash from the 1980 eruption of Mt. St
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 Helens. The formation of these PCB compounds was hypothesized by Gribble (1994) to be
 th.e result of rapid, incomplete high temperature combustion of chloride-containing plant
 material in the eruption zone.  However, Gribble (1994) presented no information indicating
 formation of CDD/CDFs by volcanoes.                       a'             ,
        Lamparski et al. (1990) analyzed groundfall ash samples collected at various
 distances and locations from Mt. St. Helens following the eruption in 1980. The findings of
 this study .indicate that volcanic particulate emissions were free of detectable PCBs and
 nearly free of detectable CDDs (0.8 ng/kg HpCDD detected) upon exiting the volcano and
 remained so throughout their period of deposition in the blast zone.  However, upon
 transport through the atmosphere, measurable and increasing levels of CDDs and PCBs
 were detected in deposited1 ash as the ash passed from rural to urban environments.  The
 authors hypothesized that CDDs and PCBs in the atmosphere became associated with the
 volcanic ash particulates through gas-phase sorption or particulate agglomeration.
       Takizawa et al. (1994) sampled the dust fall from the active volcano, Fugendake, as
 well as the volcanic ash from the active volcano, Sakurajima, for CDD and CDF congener
 group concentrations. The study was not designed to determine whether the  CDD/CDFs
 observed were formed by the volcanoes or were scavenged from the atmosphere by the
 falling dust and ash.  The dust fall was collected for 1 -month periods during July and
 October 1992; two samples of the volcanic ash were collected in 1992.  The results of the
 sample analyses for 2,3,7,8-substituted CDDs and CDFs, presented in Table 6-2, show that
 no 2,3,7,8-substituted congeners with less than 7 chlorines were detected; Takizawa et al.
 (1994), however, did report that npn-2,3,7,8-substituted congeners in the lower
 chlorinated congener groups were detected.
      Based on the available information from the studies discussed above, it is concluded
that volcanoes do not appear to be sources of CDD/CDF release to the environment.
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                 Table 6-1. CDD/CDF Emission Factors for a Landfill Flare
Congener/Congener Group
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1 ,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1 ,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF -
1,2,3,4,6,7,8-HpCDF
1 ,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
Mean Facility Emission Factor*
0.018
0.092
0.074
0 074
0.259
0.755
4.414
14.074
0.385
1.136
1 455
0.422
0.110
0.681
1.215
0 073
0.639
5.686
20.192
2.392
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Source: CARB (1990d)
          ''      "''!"'!  '     ' V i '. " ,':"" '"', ":' ;  .''. ', •'.•.  "  ;i'    " I,!1-1"1!  '.'i ''"''''  "'' ^'" •'•     ';  !-
   :     '  : ,  '  .  iij'i  ,j"  • •',    j:-; "it'-l '  J  ','',.' i? '.jf1 '','• '..'.'•'.. ' "•• ""	\:i •',"•'  '•'": '• J.'"•'r1'1* :.•  '  ',  •
* Assumes heat consent pf  1r86E-i-07 J/m3 for landfill gas  (Federal Register,  1996a),

NR = Not reported.
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                          Ratio (congener emission factor / total 2378-CDD/CDF emission factor)
                              0.1          0.2          0.3         0.4          0.5
0.6
      2,3,7,8-TCDD
 ,   1,2,3,7,8-PeCDD
  1,2,3,4,7,8-HxCDD
  1,2,3,6,7,8-HxCDD
  1,2,3,7,8,9-HxCDD
 1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
      2,3,7,8-TCDF
    1,2,3,7,8-PeCDF
    2,3,4,7,8-PeCDF
  1,2,3,4,7,8-HxCDF
  1,2,3,6,7,8-HxCDF
  1,2,3,7,8,9-HxCDF
  2,3,4,6,7v8-HxCDF
 1,2,3,4,6,7,8-HpCDF
 1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
                  Source: CARB (1990d).
           Figure 6-1.  Congener Profile for Landfill Flare Air Emissions
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              Table 6-2.  CDD/CDF in Dust Fall and Ashes from Volcanoes

2,3,7,8-Substituted
Congener Group
TCDD
PeCDD
HxCDD
HpCDD
OCDD
TCDF
PeCDF
HxCDF
HpCDF
OCDF
Dust Fall (mg/km2/month)a

July 1 992
<0.5
<0.5
<0.5
9.2
14
<0.5
<0.5
<0.5
1.9
4.2

Oct. 1 992
<0.5
<0.5
<0.5
5.2
11
<0.5
<0.5
<0.5
2.8
1.8
Volcanic Ash {ng/kg)b

Ash No. 1
<0.1
<0.1
<0.1
2.5
1.7
<0.1
<0.1
<0.1
1.2
<0.5

Ash No. 2
<0.1
<0.1
<0.1
1.8
2.2
<0.1
<0.1
<0.1
1.2
<0.5
Source: takizawa et al. (1994).




8     Dust fall measured from the active volcano, Fugendake.




b     Volcanic ash measured from active volcano, Sakurajima.
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               7.  METAL SMELTING AND REFINING SOURCES OF CDD/CDF

.7.1.   PRIMARY NONFERROUS METAL SMELTING/REFINING
        Nonferrous metals include copper, magnesium, nickel, and aluminum. The potential
 for formation and release of CDD/CDFs by primary copper smelters has been addressed by
 Environmental  Risk Sciences (1995). Although European investigators {Oehme et al.,
                                     r                . - - •               •
 1989; Lexen et al., 1993) have reported the presence of CDD/CDFs in the wastestreams of
 magnesium, nickel, and aluminum refining facilities, insufficient information is available for
 evaluating CDD/CDF emissions, if any, from the smelting/refining of these nonferrous
 metals in the United States. The findings of these studies are discussed in the following
 paragraphs.
       Environmental Risk Sciences (1995) recently prepared an analysis for the National
 Mining Association on the potential for dioxin emissions from the primary copper smelting
 industry.  The analysis included a detailed review of the process chemistry and technology
 of primary copper smelting, collection of operating conditions/and  process stream
 compositions from seven of the eight U.S. primary copper smelters, and stack testing for
 CDD/CDFs at two facilities.  The stack testing (Secor International, Inc., 1995a and 1995b)
 involved the principal process off-gas streams for copper smelters:   main stack, plant tail
 gas stack, and the vent fume exhaust.  The two tested facilities were assumed to be
 representative of the other facilities in, the industry due to similarities in process chemistry,
 process stream  composition, and process stream temperatures.
       The results of the analyses of the process chemistry/technology and the operating
 parameters and  process stream compositions indicated a very low potential for CDD/CDF
 emissions. The results of this conclusion are supported by the stack test data from the two
 tested facilities. CDD/CDFs were not detected in the emissions from either facility.  If it is
 conservatively assumed that all nondetected values were present at one-half the detection
 limits, the annual TEQ emission rate for the copper'smelting industry would be less than 1
gram  (g).        '.                                        , .
      Oehme et al. (1989) reported that the production of magnesium leads to the
formation  of CDDs and  CDFs. Oehme et al. (1989) estimated that 500 g of TEQ are
released in wastewater to the environment and 6-g TEQ are released to air annually from a
magnesium production facility studied in Norway; CDFs predominated with a CDF to CDD

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 concentration ratio of 10 to1. .The magnesium production process involves a step in which
 MgCI2 is produced by heating MgO/coke pellets in a pure chlorine atmosphere to about 700
 to 800°C. The MgCI2 is then eiectrolyzed to metallic magnesium and CI2. The CI2 excess
 from the MgCI2 process and the CI2 formed during electrolysis are collected by water
 scrubbers and discharged to the environment.
       Oehme et al. (1989) also reported that certain primary nickel refining  processes
 generate CDDs and CDFs, primarily CDFs. Although the current low temperature process
 used at the Norwegian facility studied is estimated to release only 1 -g TEQ per year, a high
 temperature NiCI2/NiO conversion process that had been used for 17 years at the facility is
 believed to have resulted  in much more significant releases based on the ppb levels of CDFs
 detected in aquatic sediments downstream of the facility (Oehme et al., 1989).
       Lexen et al. (1993) reported that samples of filter powder and sludge from a lagoon
 at the only primary aluminum production plant in Sweden showed no or little CDD/CDF.
                I'Jll!  "     "  .'. . !-  "'  '      '•:'..'    ' .'!'"' ' " '  ''  "'. .,''.'   !"

 7.2.   SECONDARY NONFERROUS METAL SMELTING
       Secondary smelters primarily engage in the recovery of nonferrous metals and alloys
 from new and used scrap and dross.  The principal metals of this industry both in terms of
 volume and value of product shipments are a|uminumvcppper, lead, zinc, and precious
 metals {U.S. DOC, 1990a). Scrap metal and metal wastes may contain organic impurities
 such as plastics, paints, and solvents. Secondary smelting/refining processes for some
 metals (e.g., aluminum, copper, and magnesium) utilize chemicals such as NaCI,  KCI, and
 other salts. The combustion of these impurities and chlorine salts in the presence of
 various types of rnetal during reclamation processes can result in the formation of CDDs
 and CDFs, as evidenced by the detection of CDDs and CDFs  in the stack emissions of
 secondary aluminum, copper, and lead smelters (Aittola et al., 1992; U.S. EPA,  1987a;
 U.S. EPA 1997b).
   ••'    '_  '".  '•.   >f' ' '.' v  i •1/.':•;;.'••' 'i'  '  '•>• '''':" ' .  •.'.'. ,''-'A. '.i-'1-' :. >• *'''•• : ;'  •     • '  : •  ',
 7.2.1. Secondary Aluminum Smelters
       Secondary aluminum smelters reclaim aluminum from  scrap containing aluminum.
This  recycling involves two processes — precleaning and smelting. Both processes may
produce CDD/CDF emissions.
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        Precleaning processes involve sorting and cleaning scrap to prepare it for smelting.
 Cleaning processes that may produce CDD/CDF emissions use heat to separate aluminum
 from contaminates and other metals; these techniques are roasting and sweating.  Roasting
 uses rotary dryers with a temperature high enough to vaporize organic contaminants, but
 not high enough to melt aluminum.  An example of roasting is the delacquering and
 processing" of used beverage cans. Sweating involves heating aluminum-containing scrap
 metal to a temperature above the melting point of aluminum,  but below the melting
 temperature of other metals such as iron and brass.  The melted aluminum trickles down
 and accumulates in the bottom of the sweat furnace and is periodically removed.
       After precleaning, the treated aluminum scrap is smelted and refined. This usually
 takes  place in a reverberatory furnace.  Once smelted, flux is  added to remove impurities.
 The melt is "demagged" to reduce the magnesium content of  the molten aluminum by the
 addition of chlorine gas. The molten aluminum is transferred to a holding furnace and
 alloyed to final specifications.
       CDD/CDF emission factors for secondary aluminum operations can be derived from
 results of testing performed in 1995 at four secondary aluminum smelters.  Three of the
 tests were conducted by EPA in conjunction with the Aluminum Association for the
 purpose of identifying emission rates from facilities with  potentially MACT-grade operations
 and APCD equipment.
       The first facility tested was a top charge melt furnace (Advanced Technology
 Systems, Inc., 1995).  During testing, the charge material to the furnace was specially
 formatted to contain no oil, paint, coatings, rubber, or plastics (other than incidental
 amounts). The CDD/CDF emissions from such a clean charge, 0.26-ng TEQ/kg charge
 material, would be expected to represent the  low  end of  the normal industry range.
       The second facility operates a sweat furnace to preclean the scrap and a
 reverberatory furnace to smelt the pre-cleaned aluminum (U.S. EPA, 1995h). Stack
 emissions are controlled by an afterburner operated at 1,450°  F. The TEQ emission factor
for this facility was 3.22-ng TEQ/kg aluminum produced..
       The third facility employs a crusher/roasting dryer as  a  precleaning step followed by
a reverberatory furnace (Galson Corporation, 1995). The emissions from the two units are
vented separately.  The exhaust from the crusher/dryer is treated with an afterburner and a
baghouse. The exhaust from the furnace passes through a baghouse with lime injection.
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   M  '    " '      I'M:        ,  '	'!"     i '. ' : ' • • ,   , ''    '        '.	   ',
  ' ,i "     	   '  	r      '   ' ' !', ;          „, "I1  '  . '!' ,:"", ,  '  ," :  ,  i'll ', ,   .   !
 Both stack exhausts were tested and the combined TEQ emission factor was 12.95-ng
 TEQ/kg aluminum produced.  Because the activity level  of the facility at the time of
 sampling was treated as confidential business information, the calculated emission factor
 was based on the reported typical production rates of the two operations, 26,000 Ibs/hr for
 the crusher/dryer and 6,700 Ibs/hr for the furnace.
       The fourth facility operates a scrap roasting dryer followed by a sidewell
 rei/erberatory furnace (Envisage Environmental, Inc., 1995).  The emissions from the two
 units are vented separately. Exhaust from the dryer passes through an afterburner and a
 lime-coated baghbuse. The exhaust from the furnace passes through a lime-coated
 baghouse. Both stack exhausts  were tested and the combined TEQ emission factor was
 36.03-ng TEQ/kg of charge material. Problems with the scrap dryer  were discovered after
 the testing was completed. Also, operating conditions during testing were reported to
 represent more worst case than typical operations.
       The congener and congener group emission factors derived from this testing are
 presented in Table 7-1.  The average congener and congener group profiles are presented in
 Figure  7-1. The average of the TEQ emission factors measured at the four facilities is
 13.1-ng TEQ/kg of scrap feed. [Note: Although the emission factors at two of the
  :.;     . ." :  ' \  ;"|S:   ,' :  />'; ;• . ;>;;B > :••..' ;;. "I••:!•:::; .•• n .;: •;.. ,i (';•:':.;[..:;• ,'f i,^< ••'•..    " j   , t
 facilities are based on the  output rather than input rate, the two rates are assumed, for
 purposes of this report, to be roughly equivalent.]  Although the testing was recently
  '•,       , " '.    iris   , ,     " ri.1'. ' i ;* '•'.',:; v, i >  " 	'•••-,.: '.'i'.'i'U ;'. ;",'n ,. : ,•	:;;ij,'
 conducted at U.S. facilities, a "low" confidence  rating is assigned to  this average emission
 factor, because it is  based on the results of testing at only four facilities, several of which
 may have more effective APCD than the other facilities  in the industry.  For example, two
 facilities tested by CARB in 1992 and reported in two confidential reports (CARB, 1992a,
 as reported in U.S. EPA, 1997b;  CARB, 1992b,  as reported in U.S. EPA, 1997b) were
 reported to have TEQ emission factors of 52.2- and 21.7-ng TEQ/kg  scrap aluminum
 consumed.
       Umweltbundesamt  (1996) reported stack testing results for 25 aluminum smelters/
foundries in Germany. Sufficient data were provided in  Umweltbundesamt  (1996) to
 enable calculation of TEQ emission factors for 11 of the tested facilities.  The calculated
emission factors ranged  from 0.01- to 167-ng TEQ/kg of scrap feed.  Three facilities had
                '";'l!jj.|||   	 ,,  ,  '"''!'„  ''  i  ' Hi '  '                               ,!   '  '     •      '
errtlssion factors exceeding 100-ng TEQ/kg, and two facilities had emission factors less
  !•• ,  '        ' " '.'•'	iiiiii   i. '• •'  ,    ;,..,"•...               I         |      (  f   , .,
than 1-ng TEQ/kg.  The  mean emission factor for the 11 facilities was 42-ng TEQ/kg,

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                         DRAFTS-DO NOT QUOTE OR CITE
                                i.                     :
 which is very similar to the mean emission factor for the two CARB studies {i.e., 37-ng
 TEQ/kg).
       A total of approximately 727,000 metric tons of scrap aluminum were consumed by
 67 secondary aluminum smelters in 1987 (U.S. DOC, 1995c), In 1995, consumption of
 scrap aluminum by the 76 facilities comprising the secondary aluminum smelting industry
 had nearly doubled to  a quantity of 1.3-million metric tons (U.S. Geological Survey, 1997a;
 The Aluminum Association, 1997). A "high" confidence rating is assigned to these
 production estimates,  because they are based on government survey data. Applying the
 TEQ emission factor of 13.1-ng TEQ/kg of scrap feed to these consumption values yields
 estimated annual emissions of 9.5-g TEQ in 1987 and 17.0-g TEQ in 1995.
       Based on the "low" confidence rating assigned to the estimated TEQ emission
 factor, the estimated range of potential emissions is assumed to vary by a factor of 10
 between the low and high ends of the range.  Assuming that the estimated emissions of
 9.5-g TEQ in 1987 and 17.0-g TEQ in 1995 are the geometric means of the ranges for
 these years, then the ranges are calculated to be 3.0- to 30.0-g TEQ in 1987 and 5.4- to
 53.8-gTEQin  1995.
       It should be noted that a significant amount of scrap aluminum is consumed by
 other segments of the aluminum industry. Integrated aluminum companies consumed  1.4-
 million metric tons of scrap aluminum in  1995, and independent mill fabricator? consumed
 0.68-million  metric tons (U.S.  Geological Survey, 1997a).

 7.2,2. Secondary Copper Smelters/Refiners
       Stack emissions of CDD/CDFs from a secondary copper smelter were measured by
 EPA during the National Dioxin Study (U.S. EPA, 1987a). The tested facility recovers
 copper and precious metals from copper and iron-bearing scrap and was chosen for testing
 by EPA because the process technology and air pollution control equipment in place were
 considered typical for the source category. The copper and iron-bearing scrap are fed in
 batches to a cupola  blast furnace, which produces a mixture of slag and black copper.
 Four to 5 tons of metal-bearing scrap were fed to the furnace per charge, with materials
typically being charged 10 to 12 times per hour.  Coke fueled the furnace, and represented
approximately 14 percent by weight of the total feed. During the stack tests, the feed
consisted of  electronic telephone scrap and other plastic scrap, brass and copper shot, iron-

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                          DRAFT-DO NOT QUOTE OR CITE

 bearing copper scrap, precious metals, copper bearing residues, refinery by-products,
 converter furnace slag, anode furnace slag, and metallic floor cleaning material. The
 telephone scrap comprised 22 percent by weight of the feed and was the only scrap
 component that contained plastic materials.  Oxygen  enriched combustion air for
 combustion of the coke was blown through tuyeres at the bottom of the furnace.  At the
 top of the blast furnace were four natural gas-fired afterburners to aid in completing
            : '   ;l:i';i ,'          -  i	  ; •: .„•  "	!' I ; , •  	i,,!, '.' '--I. .,'. :.  : „!/" '  .. ' . . I    •
 combustion of the exhaust gases.  Fabric filters controlled paniculate emissions, and the
,flue gas then was discharged into a common stack. The estimated emission factors
 derived for this site are presented in Table  7-2.  The emission factors are based on the total
 weight of scrap fed to the furnace. The TEQ emission factor estimated in U.S. EPA
   i-., •    •   ":, ,  s:c  "   '   • '!   	,; , •!  :• :•  '•;>•.•*, "i" r. ,'  ,;":<"';''' '..."•:' •'••'?;>. ',  ' •   I
 (1997c), based on the measured congener and congener group emission factors, is 779
 ng/kg of scrap metal smelted.  Figure 7-2 presents the congener group  profile based on
 , . •'•        "     ;•'!« :'-'       ,   •>:>  ,, ;"". • • '":•' i;' '. • •.   '•• .-'   ^ 'i;  . "•''  •
 these emission fgctors.
   1 i    '  '  ,„   	: „.''        '• S ' ,  ,,'  •,,  ' , ,  ' i    ,'•''•	   '    ,i
       Approximately 390,000 metric tons of scrap copper were consumed by U.S.
 secondary copper  smelters/refiners in 1987 {U.S. DOC, 1990a).'  In 1995, approximately
 695,000 metric tons of scrap copper were consumed by the 24 operating U.S. copper
 smelters,  refiners,  and  ingot makers (U.S. Geological Survey, 1997a). If the TEQ emission
 rate derived above (779 ng/kg of scrap consumed) is assumed to be representative of the
 24 copper facilities, then the estimated air  emissions of CDD/CDF TEQ by secondary
 copper operations  in the United States in 1987 were 304 grams, and the estimated TEQ
 emissions in 1995 were 541 grams. A "high" confidence rating is assigned to the
 production estimates, because they are based on government survey data.  A "low"
 confidence rating is assigned to the TEQ emission estimate,  because it is based on direct
 measurements at only one U.S. copper smelter.  Based on these confidence ratings,  the
 estimated range of potential annual emissions is assumed to vary by a factor of  10
 between the low and high  ends of the range.  Assuming that the estimates of annual
   "	   ,,   •   ;::,;? .-.••"'•'.•'•'•'. -^  ,   ':;;>-,;"f '.!:;ii'',;' ^	i v«v> ;:,•••  ': W^'  , •'. [•     : •.     '  :
 emissions (304-g TEQ in 1987 and 541-g TEQ in 1995) are the geometric means of these
 ranges for those years, then the ranges are calculated to be 96- to 960-g TEQ in 1987 and
   '.I1' ••       '  . .ini'i !   "     •  •.'.'. '-:,„  "  .:••.••,,!'!   ' ' '.." •"• •,!  i:	i',1 ,,"":; * •;  	M"; - ,;•. '          ,    .    •
 171-to  1,710-g TEQ in 1995.
      It should be noted that a significant  amount of  scrap copper is consumed by other
segments  of the copper industry.  In 1995, brass mills and wire-rod mills consumed
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                          DRAFT-DO NOT QUOTE OR CITE

 886,000 metric tons of copper-base scrap; foundries and miscellaneous manufacturers
 consumed 71,500 metric tons (U.S. Geological Survey, 1997a).
    \                           .                       - • -
                                                 i           =            •
 7.2.3. Secondary Lead Smelters/Refiners
        The secondary lead smelting industry produces elemental lead through the chemical
 reduction of lead compounds in a high temperature furnace (1,200 to 1,260° C).  Smelting(
 is performed in reverberatory, blast, rotary, or electric furnaces.  Blast and reverberatory
 furnaces are the most common types of smelting furnaces used  by the 23 facilities that
 comprise the current secondary lead smelting industry in the  United States.  Of the 45
 furnaces at these 23 facilities, 15 are reverberatory furnaces, 24 are blast furnaces, 5 are
 rotary furnaces, and 1 is an electric furnace.  The one electric furnace and 11 of the 24
 blast furnaces are co-located with reverberatory furnaces, and most share a common
 exhaust and emissions control system (U.S. EPA, 1994a).
       Furnace charge materials consist of lead-bearing raw materials, lead-bearing slag and
 drosses, fluxing agents (blast and rotary furnaces only), and coke.  Scrap motor vehicle
 lead-acid batteries represent about 90 percent of the lead-bearing raw materials at a typical
 lead smelter. Fluxing agents consist of iron, silica sand, and limestone or soda ash.  Coke
 js used as fuel in blast furnaces and as a reducing agent in reverberatory and rotary
 furnaces. Organic emissions from co-located  blast and reverberatory furnaces are more
 similar to the emissions of a reverberatory furnace than the emissions of a blast furnace
 (U.S. EPA, 1994a).
       Historically, many lead-acid batteries contained PVC plastic separators between the
 battery grids. These separators are not removed from the lead-bearing parts of the battery
 during the battery breaking and separation process. When the PVC is burned in the smelter
 furnace, the chlorides, are released as HCI, CI2, and chlorinated hydrocarbons (Federal
 Register, 1995d). The source of CDD/CDFs at secondary lead smelters is the PVC
 separator (U.S. EPA, 1995c).  In 1990, about  1 percent of scrap batteries processed at
 lead smelters contained PVC separators. In  1994, less than 0.1 percent of scrap batteries
contained PVC separators.  This trend is expected to continue because no U.S.
                                             .>           - •
manufacturer of lead-acid automotive batteries currently uses PVC in production (U.S. EPA,
 19956; Federal Register, 1995d).                                     ,         !
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   ,, i ,        '    ' i:   '   ,;,  ' i' , i "i, "'''.,,'"     7 "              ,               ,

        The total current annual production capacity of the 23 companies currently
   '.,: :   •  •       'Si'S,!  .'   ,„'   i .:'•  •'' "•   , , > • ''•': ,i i ' - v",'', • .'.' '  ',-,,:! .'  ,"  .' ' '"'"  i: :""" :      i1        ' .
 comprising the U.S. lead smelting industry is  1.36-million metric tons.  Blast furnaces not
   C';;,""   ,   -' i   ';;;:;! .; ," ,••  . .• /	,,   •:••;.:• , ^ v :',:•': v. • •" "; '•• "•,'•• •• • .?;.:•: ',:;'„	••• |.    •   •     • •   . • .
 co-located with reyerberatory furnaces account for 21 percent of capacity (or 0.28-million
 metric tons).  Reyerberatory furnaces and blast and electric furnaces co-located with
 reyerberatory  furnaces account for 74 percent of capacity (or 1.01-million metric tons).
 Rotary furnaces account for the remaining 5 percent of capacity (or 0.07-million metric
 tons).  Actual  production volume statistics by furnace type are not available.  However, if it
   ,,,""! '    ',  .,' .'.    ...jiii'i •  '• ,   .  ...,  ',	'.'  i  •: . i	  ....'•.. "  • -,::  i " '*, .. •• "i  •	!"• "/i " ..[ • • |  i  '..  .    •       ''
 is assumed that the total actual production volume of the industry, b.97-million metric tons
 in 1995 (U.S.  Geological Survey, 1997a) and 0.72-million metric tons in 1987  (U.S. EPA,
 1994a), are reflective of the  production capacity breakdown by furnace type, then the
   , i,,'"' i ,    '"      .i'lllTlli '• , ,  ' ".    ,i  ,.	\fi   T!	• K" IH!'!,:',',|, i  ,'i,  i, .',,1 ' '""hi ,'„ ,	,,"'•. -r ,«, , • V I1): „  , ' -  !  "" *  ' 'I
 estimated actual production volumes of blast furnaces (not cp-located), reverberatory and
 co-located blast/electric and reverberatory furnaces, and rotary furnaces were 0.20-, 0.72-,
 arid 0.p5-mi|!Jon metric tons, respectively, in  1995,  and 0.15-, 0.53-, and 0.04-million
 metric tons, respectively, in 1987. In  1987, the industry consisted of 24 facilities.
        CDD/CDF emission factors can  be .estimated for lead smelters based on  the results
 of emission tests recently performed by EPA at three smelters (a blast furnace, a co-located
 blast/reverberatory furnace, and a rotary kiln furnace) (U.S. EPA, 1992e; 1995d; 1995e).
 The air pollution control systems at the three  tested facilities consisted of both baghouses
   "" i' 4,           * ""lil !    'ii   • •	' •"', 'i:'•••,!	'   !•"'•'"!!,„ 1 :'• ' Wii; "" „' » :  r •  /, -	'."I1:f|1 ",  "'• a,, , j'li!,!.:!!1, ,ih:/,, i    ' r «• ••  ,
 and scrubbers. Congener-specific measurements were made at the exit points  of both
 APCD exit points at each facility.  Table 7-3 presents the congener and congener group
 erqission factors Irprri the baghouse and the scrubber for each site. Figure 7-3  presents the
.•  -i' • •   '  i..;1.  '  '; "iiiii1  •'"   '   '  i  "'         "    ''     	'     "'   >" '    ;"  !•. •;  •••„,        ,,  '
 corresponding  profiles for the baghouse emissions from the tested  blast furnace and
 reverberatory furnace.  Although all 23 smelters employ baghouses, only 9 employ scrubber
 technology.  Facilities that  employ scrubbers account for 14 percent of the blast furnace
 (not co-located) production capacity, 52 percent of the reverberatory and co-located
 furnace production capacity,  and 57 percent of the rotary furnace production capacity.
 From the reported data, TEQ  emission  factors (ng TEQ/kg lead processed) for each of the
   :  .      • • .   . >!iii'  -!; ,  ';'"  • ','"••• liS!1",;; !': i1 :: ,'i,:1"1";"!': .:,",•'', •.»"1: ; f'f,;,;,;';,;,;;,-.';,'' ;  i|;!',i"!';.'/:', •"••,!.';
 three furnace configurations are presented below as a range reflecting the presence or
 absence of a scrubber.
                " ,' "fl;1  •'    •  i. :,i";  ' ' '„   ii •   , ' ,    ' - '  '  ,:"'l ''i :,•',,  ", ,"' - ',•" •'"'.'•"'   . ! '

       Emission factors when nondetected values are set equal to zero:
       •      Blast furnace:  0.63- to 8.31 mg TEQ/kg lead  produced.

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        •      Reverberatory/co-located furnace:  0.051- to 0.41-ng TEQ/kg lead produced.
        •      Rotary furnace: 0.24- to 0.66-ng TEQ/kg lead produced.

        If it is assumed that these emission rate ranges are representative of the range of
 emission rates at the non-tested facilities with the same basic furnace configuration and
 presence or absence of scrubbers, then combining these emission rate ranges with the
 estimates derived above for secondary lead production volumes and the percents of each
 configuration type that utilize or do not utilize scrubbers yields the following estimated air
 emissions in units of grams TEQ per year:
Configuration
Blast furnaces w/scrubbers
Blast furnaces w/o scrubbers
Reverberatory furnaces w/ scrubbers
Reverberatory furnaces w/o scrubbers
Rotary furnaces w/ scrubbers
Rotary furnaces w/o scrubbers

Estimated Annual TEQ
Ref. Year 1 995
0,018
1.429
0.019
0.142
0.019
0.005
1 .632
Emissions (g TEQ) *
Ref. Year 1987
0.013
1.072
0.014
0.104
0.015
0.004
1.223
 *  Calculated using emission factors based on nondetected values set equal to zero.

       A "medium" confidence rating is ascribed to the emission factors derived above,
 because stack test data were available for 3 of the 23, smelters in the United States (of
 which only 16 were in operation as of December 1993), and the stack test data used
 represent the three major furnace configurations.  The activity level estimate has been
 assigned a "medium" confidence rating, because, although it is based on a U.S.
 Department of Commerce estimate of total U.S. production, no production data were
 available on a furnace type or furnace configuration basis.  ,                      ,
       Based on these confidence ratings, the estimated range of potential annual
emissions is assumed to vary by a factor of 5 between the low and high ends of the range.
Assuming that the estimates of annual emissions (1.63-g TEQ in 1995 and  1.22-g TEQ in
 1987) are the geometric means of these ranges for these years, then the ranges are
calculated to be 0.73- to 3.65-g TEQ in 1995 and 0.55- to 2.73-g TEQ in 1987.
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                                                                         ; April 1998

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    i  "    '      i, ." |'!,j         ,   .ii '    ,  • ' i ',,,:',   :.• . , ' , • ,i|  j, , i  ' .  .,
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  comparability of recycling practices at U.S. and European sinter plants has not been
  determined.
        Sinter plants in Sweden were reported to emit up to 3-ng TEQ/Nm3 stack gas or 2-
  to 4-g TEQ/yr per plant to the air (Rappe, 1992b; Lexen et al., 1993).  Bremmer et al.
  (1994) reported the results of stack testing at three iron ore sintering plants in The
  Netherlands. One facility equipped with wet scrubbers had an emission factor of  1.8-ng
  TEQ/dscm (at 11  percent O2).  The other two facilities, both equipped with cyclones, had
  emission factors of 6.3- and 9.6-ng TEQ/dscm (at 7 percent O2). Lahl (1993; 1994)
  reports stack emissions for sintering plants in Germany (after passage through mechanical
  filters and electrostatic precipitators) ranging  from 3- to 10-ng TEQ/Nm3.  A recent
  compilation of emission measurements by the German Federal Environmental Agency
  indicates stack emission concentrations ranging from 1.2- to 60.6-ng TEQ/m3 (at 7 percent
  O2); the majority of current emissions lie around 3-ng TEQ/m3 (Umweltbundesamt, 1996).
        In 1996, 11 sintering plants were operating in the United States, with a total annual
  production capacity of about 17.6-million metric tons (Metal Producing, 1996).  Over the
  past 15 years, the size of this industry decreased  dramatically. In 1982, 33 facilities
  operated with a combined total capacity of 48.3-million metric tons (U.S. EPA, 1982b).  Iri
,  1987, sinter consumption was 14.5-million metric tons (AISI, 1990); in 1994, consumption
  was 12.2-million metric tons (AISI, 1995) or approximately 77 percent of production
  capacity assuming that production capacity in 1994 was the same as in 1996.
        No testing of CDD/CDF emissions from U.S. sinter plants has been reported upon
 which to base an estimate of national emissions, and the comparability between dust/scrap
 recycling practices at U.S. and European sinter plants has not been determined.  The limited
 data available were thus judged inadequate for developing national emission estimates that
 could be included in the national inventory. However, a preliminary  order of magnitude
 estimate of potential TEQ annual emissions from U.S. sintering plants can be made using
 European emission test results and the following assumptions based on the data presented
 in Table 7-4:  (1) the total strand surface area of U.S. plants is 1,685 m2; (2)  on average,
 an estimated 5,877 m3 of exhaust gas are emitted per hour per m2 of strand; (3) on
 average, sinter plants are operating at 77 percent capacity for 350 operating days per year
 (i.e., 6,486 hrs/yr); and (4) the TEQ emission factor is about.4-ng TEQ/m3 of exhaust gas
 (i.e., the approximate midpoint of the emission factors reported by Rappe (1992b), Lexen et
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   ;• ' ,  	   •    '' in      •    •   .,     , " ' 	.:;. '   ;i :  . M " '   • ,;'   >'" : "     |
 al. (1993), Bremmer et al. (1994), Lahl (1994), and Umweltbundesamt, 1996)).  Applying
 these assumptions yields an estimated total annual current emission of 256-g TEQ/yr,
 which, when rounded to the nearest order of magnitude to emphasize the uncertainty in
 this estimate, results in a value of 100-g TEQ/yr.  This estimate should be regarded as a
 preliminary indication of possible emissions from this source category; further testing is
 needed to confirm the true magnitude of these emissions.

 7.3.2 Coke Production
       Coke is the principal fuel used in the manufacture of iron and steel.  Coke is the
 solid carbonaceous, material produced by the destructive distillation of coal in high
 temperature ovens.  No testing of CDD/CDF emissions from U.S. coke facilities has been
 reported. However, at a facility in the Netherlands, Bremmer et al. (1994) measured a
 CDD/CDF emission rate to air during the water quenching of produced hot coke of 0.23-ng
 TEQ/kg of coal consumed. Minimal CDD/CDF air emissions, 0.002-ng TEQ/kg of coal, were
 estimated by Bremmer et al.  (1994) for flue gases generated during charging and emptying
 the coke ovens.
       In 1995, an estimated 30-mjllion metric tons of qoaf were consumed by coke plants
 in the United, States (EIA, 1997b). No testing of CDD/CDF emissions from U.S. coke plants
 has been reported upon which to base an estimate of national  emissions. The limited data
 available were thus judged inadequate for developing national emission estimates that could
 be included in the national inventory. However, a preliminary order of magnitude estimate
 of potential TEQ annual emissions from U.S. coke plants can be made by combining the
 consumption  value of 30-million metric tons and the emission factor reported by Bremmer
 et al. (1994) for a Dutch coke plant (0.23-^g TEQ/kg of coke).  This calculation yields an
 annual emission of 6.9-g TEQ in 1995, which, when rounded to the nearest order of
   	    „   ,„   ..u !,,,,,  ,: :      ,h „ . : ,;   l:    „, :i |   „ " ,,  „    |S  , | ,, M|M   ,, ., M , ^    f j'V,
 magnitude to emphasize the uncertainty in this estimate, results in a value of 10-g TEQ/yr.
This estimate should be regarded as a preliminary indication of possible emissions from this
 source category; further testing is needed to confirm the true magnitude of these
emissions.
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 7.3.3  Electric Arc Furnaces
        Electric arc furnaces (EAFs) are used to produce carbon and steel alloys. The
 production of steel in an EAF is a batch process, and the input material is typically 100
            ^                                                           -            -
 percent scrap. Scrap, alloying agents, and fluxing materials are loaded into the cylindrical,
 refractory-lined EAF, and then carbon electrodes are lowered into the EAF.  The current of
 the opposite polarity electrodes generates heat between the electrodes and through the
 scrap.  A batch ranges from about 1.5 to 5 hours to produce carbon steel and from 5 to 10
 hours to produce alloy steel (U.S. EPA, 1995b).
       The melting of scrap ferrous material contaminated with metal working fluids and
 plastics containing chlorine provides the conditions conducive to formation of CDD/CDFs.
 Tysklind et al. (1989) studied the formation and releases of CDD/CDFs at a pilot 10-ton
 electric furnace in Sweden.  Scrap ferrous metal feedstocks containing varying amounts of
 chlorinated compounds (i.e., PVC plastics, cutting oils, or CaCI2) were charged into the
 furnace under different operational conditions (i.e., continuous feed, batch feed into the
 open furnace; or batch feed through the furnace lid).  During continuous charging
 operations, the highest emissions, 1.5-ng Nordic TEQ/dry Mm3 (i.e., after a bag house filter)
 were observed with a feedstock comprised of scrap metal with PVC plastics (1.3 g of
 chlorine per kg of feedstock). This emission equates to 7.7-ng Nordic TEQ/kg of feedstock.
 The highest emissions during batch charging also occurred when the scrap metal with PVC
 plastic was combusted (0,3-ng Nordic TEQ/dry Nm3 or 1.7-ng Nordic TEQ/kg of feedstock).
 Much lower emissions  (0.1-ng Nordic TEQ/dry Nm3 or 0.6-ng Nordic TEQ/kg of feedstock)
 were observed when scrap metal with cutting oils containing  chlorinated additives (04 g of
 chlorine per kg of feedstock) was melted.  Although these cutting oil-related emissions
 were not significantly different than the emissions observed from the melting of "no-
 chlorine" scrap metal, relatively high levels of CDD/CDF (i.e.,  110-ng Nordic TEQ/dry Nm3)
 were detected in flue gases prior to the bag house. The congener profiles of raw flue gas
 samples (i.e., prior to APCD) showed that CDFs, rather than CDDs, were predominant in all
three feedstock types.  The congener profile from the test burn with PVC-containing
feedstock showed a higher chlorinated congener content than was observed with the other
feedstocks.
      Eduljee and Dyke (1996) used a range of 0.7- to 10-rig TEQ per kg of scrap feed to
estimate national emissions for the United Kingdom.  The range was assumed to be
                                        7"13                                April 1998

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 representative of *no chlorine" and "high chlorine" operations.  However, little information
 was provided in Eduljee and Dyke (1996) on the supporting emission test studies (i.e.,
 tested facility operational materials, feed rates, congener-specific emission rates).
       Umweltbundesamt (1996) reported stack testing results for a variety of EAFs in
 Germany. Sufficient data were provided in Umweltbundesamt (1996) to enable calculation
 of TEQ emission factors for six of the tested facilities. Two facilities had emission factors
 exceeding 1-ng TEQ/kg of scrap processed, and two facilities had emission factors less
 than 0.1-ng TEQ/kg of scrap. The mean emission factor was 1.15-ng TEQ/kg of scrap.
 The TEQ concentrations in the stack gases at these facilities (corrected to 7 percent O2)
 ranged from less than 0.1- to 1.3-ng TEQ/m3.
       In 1995, electric arc furnaces accounted for 40.4 percent of U.S. steel production
 (or 38.4 of the total 95.2-million metric tons of raw steel produced) (Fenton, 1996). No
  • „ , ,     ..i, .  ' T1 • • •	ii  , i •	   •  „ •, „ hi . .   " ,  i" i,11"1." 'i , , i<  '',  , i1   ,!','•«,: i • ,! .,!'. ii'"!' i' h, ' »!!:,', , i; ,.i,     i        "     ,    i
  '«	, ,  ' i	 „, , •' : "" - ij	,11 '    i  '! " i',	  /,i"    • ' '	i Iv1', , ! ' , r !.,'"!: • '' :,''i(! "• .:, ",'K  , V „ it'iii » 'i,,, ", •. .  I,  , '•  :
 testing of CDD/CDF emissions from U.S. electric arc furnaces has been reported upon
 which to base an estimate of national emissions, and the limited European data available
 were thus judged inadequate for developing national emission estimates that could be
 included in the  national inventory.  However, a preliminary order of magnitude rough
 estimate  of potential TEQ annual emissions from U.S. electric arc furnaces can be made by
 combining the production estimate of 38.4-million metric tons and the average emission
  •P.i     "' 'i  ' '  '	Ml,'!  '„ 	 '  " ''„ " .1,' • • * , i, '' .',i „',,'"i.1'1,:i, » "' 	''',,,  •	Vi „'	 .  - / 'I'hi!"" ,, ,: I- • • .  I
 factor derived from the data reported in  Umweitbundesamt (1996) for six EAFs (i.e., 1.15-
 ng TEQ/kg scrap). This calculation yields an annual emission estimate of 44.3 g of TEQ in
 1995, which, when rounded to the  nearest order of magnitude to emphasize the
 uncertainty in this estimate, results  in a value of 10-g TEQ/yr. this estimate should be
 regarded  as a preliminary indication  of'possible emissions from this source category; further
 testing is needed to confirm the true magnitude of these emissions.
          '  -, •  N* '"     "•• "   „; ;' • •:'•.•    • "    i-  '  ''.'<'••''.'    •'.•'••'•     \
 7.4   FERROUS FOUNDRIES
       Ferrous foundries produce high strength iron and steel castings used  in industrial
 machinery, pipes,  and heavy transportation equipment.  Iron  and steel castings are solid
 Solutions of iron, carbon,  and various alloying materials.  Castings are produced by injecting
 or pouring molten metal into cavities of a mold made of sand, metal, or ceramic material.
 Metallic raw materials are pig iron, iron and steel scrap, foundry returns, and metal turnings
 (U,S. EPA, 1995b; 1997b).
                 !'     ,         (            , '   ,      '.  .    . • •

                                         '7-14                                 April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
                                                                           \
        . -           • /         -   -           '          '       •
        The melting process is performed primarily in cupola (or blast) furnaces and to a
 lesser extent in electric arc furnaces (EAF).  About 70 percent of all iron castings are
 produced using cupolas, while steel foundries rely almost exclusively on EAFs or induction
 furnaces for melting. The cupola is typically a vertical, cylindrical steel  shell with either a
 refractory-lined or water-cooled inner wall. Charges are loaded at the top of the unit; the
 iron is melted as it flows down the cupola, and is removed at the bottom. {EAFs are
 discussed in Section 7.3.3.)  Electric induction furnaces are batch type furnaces in which
 the charge is melted fay a fluctuating electromagnetic charge produced by electrical coils
 surrounding the unit (U.S. EPA, 1995b; 1997b).
       Iron and steel foundries, particularly those using EAFs, are highly dependent on iron
 and steel scrap.  Of the estimated 72-million metric tons of iron and steel scrap consumed
 by the iron and steel industry in 1995, 25 percent (or 18-miHion metric tons) were  used  by
 ferrous foundries. The other 75 percent were used by primary ferrous metal smelters
 (principally those using EAFs) (U.S. Geological Survey, 1997b). Thus, foundries face the
 same potential for CDD/CDF emissions as EAFs because of use of scrap containing
 chlorinated solvents, plastics, and cutting oils.  (See Section 7.3.3.) The potential  for
 formation and release of CDD/CDFs during the casting process (i.e., pouring of molten
 metal into molds and cores comprised of sand and various organic binders and polymers) is
 not known.
       The results of emissions testing have been reported for only  one  U.S. ferrous
 foundry (CARB, 1993a - as reported in U.S. EPA, 1997b).  The  tested facility consisted of
 a batch-operated, coke-fired cupola furnace charged with pig iron, scrap iron, scrap steel,
 coke, and limestone. Emission control devices operating during the  testing were an oil-fired
 afterburner and a baghouse. The congener and congener group emission factors derived
 from the testing are presented in Table 7-5.  The congener and  congener group profiles are
 presented in Figure 7-4. The calculated TEQ emission factor for this set of tests is  0.37
 ng/kg of metal charged to the furnace.
       Umweltbundesamt (1996) reported stack testing results  for a variety of ferrous
foundries in Germany. Sufficient data were provided in Umweltbundesamt (1996) to
enable calculation of TEQ emission factors for eight of the tested facilities. Three facilities
had emission factors exceeding 1 ng/kg of metal charge, and four facilities had emission
                                        7-15
                                                                            April 1998

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                       .   DRAFT-DO NOT QUOTE OR CITE

 factors less than 0.1 ng TEQ/kg of metal charge; the emission factors span more than four
 orders of magnitude.  The mean emission factor was 1,26-ng TEQ/kg of metal feed.
       Based on the wide range of emissions for the tested German foundries reported in
 Urnweltbundesamt (1996), the confidence in the degree to which the one tested U.S.
 facility represents the mean emission factor for the approximate 1,000 US. foundries is
 considered very low.  Therefore, the limited data available were thus judged inadequate for
 developing national emission estimates that could be included in the national inventory.
 However, a preliminary order of magnitude estimate of potential TEQ annual emissions from.
 U.S. ferrous foundries can be made by combining the mean emission factor derived from
 the data reported in Urnweltbundesamt (1996) for eight foundries (1.26-ng  TEQ/kg of metal
 feed) with an activity level for U.S. foundries. In 1995, U.S. shipments from the
 approximate 1,000 U.S. ferrous foundries were 13.9-million metric tons of which about 90
 percent were iron castings and 16 percent were steel castings (Fenton, 1996).  This
 calculation yields an annual emission estimate of 17.5 g of TEQ in 1995,  which, when
 rounded to the nearest order of magnitude to emphasize the uncertainty  in this estimate,
 results in a value of 10-g TEQ/yr.  This estimate should be regarded as a preliminary
 indication of possible emissions from this source category; further testing is needed to
 confirm the true magnitude of these emissions.

 7.5.   SCRAP ELECTRIC WIRE RECOVERY
       The objective of wire recovery is to remove the insulating material and reclaim the
 metal (e.g.,  copper, lead, silver, and gold) comprising the electric wire.  The reclaimed
 metal is then sold  by the recovery facility to a secondary metal smelter.  Wire insulation
 commonly consists of a variety of plastics, asphalt-impregnated fabrics, or burlap. In
ground cables, chlorinated organics are used to preserve the cable casing. The combustion
of chlorinated organic compounds in the cable insulation, catalyzed by the presence of wire
metals such as copper and iron can lead to the formation of CDDs and CDFs (Van Wijnen et
al., 1992).
  IIP'  !         '"  l|!."!' 'ISl '' '    ,                                    II        I' '
      Although in the past, scrap electric wire was commonly treated via thermal
processing to burn off the insulating material, industry and trade association representatives
state that current recovery operations typically no longer involve thermal treatment, but
Instead involve mechanical chopping the scrap electric wire into fine particles. The

                                        7-16                                April 1998

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 insulating material is then removed by air blowing and gravitational settling of the heavier
 metal fraction (telephone conversation between R. Garind, Institute of Scrap Recycling
 Industries, and T. Leighton, Versar, Inc. on March 2, 1993; telephone conversation
 between J. Sullivan, Triple F. Dynamics, and T. Leighton, Versar, Inc., on March 8, 1993).
        Dioxin-like compounds emitted to the air from a scrap wire reclamation incinerator
 were measured from a facility during EPA's National Dioxin Study of combustion sources
 (U.S. EPA, 1987a).  The tested facility was determined to be typical of this industrial
 source category at that time. Insulated wire and other metal-bearing scrap material were
 fed to the incinerator on a steel pallet. The incinerator was operated in a batch mode, with
 the combustion cycles for each batch of scrap feed lasting between 1 and 3 hours.
 Incineration of the material occurred by burning natural gas. Although most of the wire had
 a tar-based insulation, PVC-coated wire was also fed to the incinerator.  Temperatures
.during combustion in the primary chamber furnace  were about 570°C. The tested facility
 was equipped with a high temperature natural gas-fired afterburner (98O to 1,090°C),
 Emission factors estimated for this facility are presented in Table 7-6. The TEQ emission
 factor (based only on 2,3,7,8-TCDD, 2,3,7,8-TCDF, OCDD, and OCDF) is 2.5-ng TEQ/kg
 scrap feed. Figure 7-5 presents a congener group profile based on these emission factors.
       These emission factors from the U.S. EPA (1987a) study are in general agreement
 with those reported by Bremmer et al. (1994) for three facilities in The Netherlands, which
 have subsequently ceased operations. Emission rates at a facility burning underground
 cables and cables containing PVC ranged from 3.7-ng TEQ/kg to 14-ng TEQ/kg. The
 emission rate at a second facility ranged from 21-ng TEQ/kg of scrap (when burning copper
 core coated with greasy paper) to 2,280-ng TEQ/kg of scrap (when burning lead cable).
 The third facility, which burned motors, was reported to have an emission rate of 3,300-ng
 TEQ/kg of scrap.  Based on these measurements, Bremmer et al. (1994) used emission
 rates of 40-ng TEQ/kg of scrap and 3,300-ng TEQ/kg of scrap for estimating national,
 emissions in The Netherlands for facilities burning wires/cables and those burning motors.
       Although limited emission testing has been conducted~at one U.S. facility, the
 activity level for this  industry sector In reference years 1987 and 1995 is unknown;
therefore, an estimate of national emissions cannot be made.  It is uncertain how many
facilities still combust scrap wire in the United States.  Trade association and industry
representatives state that only minimal quantities of scrap wire are still burned by U.S.
                                        7-17
                                                                            April 1998

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                      .   DRAFT-DO NOT QUOTE OR CITE

scrap wire recovery facilities. However, a recent inventory of CDD/CDF sources in the San
 1 V ':. "" ..... ^ * '  ,   ' ',:..'- ............ i  V  1 I'v :i; :;;•!: Vt^ .:•'•.' ..... :,  \ ..... ••'•.;••.  ;  [              ..-  -,
Francisco Bay area noted that two facilities in the Bay area thermally treat electric motors
to recover electrical windings (BAAQMD, 1996).
       In addition to releases from regulated recovery facilities, CDD/CDF releases from
small-scale burning of wire at unregulated facilities and open air sites have occurred; the
current magnitude of small-scale, unregulated burning of scrap wire in the United States is
not known.  For example, Harnly et al. (1 995) analyzed soil/ash mixtures from three closed
metal recovery facilities and from three closed sites of open burning for copper recovery
near a California Insert town, the geometric mean of the total CDD/CDF concentrations at
the facility sites and the open burning sites was 86,000 and 48,500 ng/kg, respectively.
                           ........   ,   ......   , jj        ,  , , •  , ,     , ,
The geometric mean TEQ concentrations were 2,900- and 1,300-ng TEQ/kg, respectively.
A significantly higher geometric mean concentration (19,000 ng TEQ/kg) was found in fly
ash located at two of the facility sites.  The congener-specific and congener group results
from this study are presented in Table 7-7. The results show that the five dominant
congeners in the soil/ash  samples  at both the facility and open burning sites were OCDF,
1 ,2,3,4,6,7,8-HpCDF, 1 ,2,3,4,7,8-HxCDF, and 2,3,7,8-TCDF.  A slightly different profile
  ii!'1' ,     "     ' •' VHi'iili.     '  ,'.'",'.,',:,'  ,,i   i:,   „,,'.„•„" '; i 'I' ', '••'• ' ' 'Mi11,!,, '  ,.!,', ........ „.',.,'!   I
was observed  in the fly ash samples with 1,2,3,7,8-PeCDF and 1 ,2,3,4,7,8,9-HpCDF
replacing OCDD, and 2,3,7,8-TCDF as dominant congeners.
       Van Wijnen et al. (1992) reported similar results for soil samples collected from
Unpermitted former scrap wire and car incineration sites in The Netherlands.  Total
CDD/CDF concentrations in the soil ranged from 60 to  98,000 ng/kg, with 9 of the 1 5 soil
samples having levels above 1,000 ng/kg.  Chen et al.  (1986) reported finding high levels
of CpD/CpFs in residues  from Ppen air burning of wire in Taiwan, and Huang et al.  (1 992)
reported elevated levels in soil near wire scrap recovery operations in Japan. Bremmer et
al. (1 994) estimated an emission rate to air of 500-ng TEQ/kg of scrap for illegal,
unregulated burning of cables in The  Netherlands.

7.6.   DRUM AND BARREL RECLAMATION FURNACES
      1  ".  »                            ii     iii      i         r ;  •   • '
       Hiitzinger and  Fiedler (1 991 b) reported detecting CDD/CDFs in stack gas emissions
from drum and barrel reclamation facilities at levels ranging from 5 to 27 ng/m3.  EPA
measured dioxin-like compounds in the stack gas emissions of a drum and barrel
reclamation furnace as part of the National Dioxin Study (U.S. EPA, 1987a).

            ,   !;;!;  '""•• ,  ••••';:,'.;/  '.'  '..'   7-18'   i '/, ....... ' ..' ,'] ^.,"  '„   '  \         April 1998'
                                                        ii ;•;• t, 'Aiiiii1:1! » ......

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                         DRAFT-DO NOT QUOTE OR CITE

       Drum and barrel reclamation furnaces operate a Burning furnace to thermally clean
 used steel 55-gallon drums of residues and coatings.  The drums processed at these
 facilities come from a variety of sources in the petroleum and chemical industries.  The
 thermally cleaned drums are then repaired, repainted,  relined, and sold for reuse. The drum
.burning process subjects used drums to an elevated temperature in a tunnel furnace for a
 sufficient time so that the paint,  interior linings, and previous cpntents are burned or
 disintegrated. The furnace is fired  by auxiliary fuel. Used drums are loaded onto a
 conveyor that moves at a fixed speed.  As the drums pass through  the preheat and ignition
 zone of the furnace, additional contents of the drums drain into the furnace ash trough.  A
 drag conveyor moves  these sludges and ashes to a collection pit. The drums are air cooled
 as they exit the furnace.  Exhaust gases from the burning furnace are typically drawn
 through a breeching fan to a high-temperature afterburner.
       The afterburner at the facility tested by EPA operated at an average of 827°C during
 testing and achieved a 95 percent reduction in CDD/CDF emissions (U.S. EPA, 1987a).
 Emission factors estimated for this  facility are presented in Table 7-8.  Based  on the
 measured congener and congener group emissions, the average TEQ emission factor was
 estimated in U.S. EPA (1997b) to be 49.4-ng TEQ per drum.  The congener group profile is
 presented in Figure 7-6.
       Approximately  2.8- to 6.4-million 55-gallon drums are incinerated annually in the
 United States (telephone conversation between P. Rankin, Association of Container
Recbnditioners, and C. D'Ruiz, Versar, Inc., December 21, 1992). This estimate is based
on the following assumptions: (1) 23 to 26 incinerators are currently in operation;  (2) each
incinerator, on average, handles 500 to 1,000 drums per day; and (3) on average, each
incinerator operates 5  days per week, with 14 days downtime per year for maintenance
activities. The weight of 55-gallon  drums varies considerably; however, on average, a
drum weighs  38 Ibs (or 17 kg); therefore, an estimated 48- to 109-million kg of drums are
estimated to be incinerated annually.  Assuming that 4.6-milliori drums are burned each
year (i.e., the midpoint of the range) and applying the mean emission factor developed
above (i.e., 49.4-ng TEQ per  drum), the estimated annual emission of TEQ is 0.23 grams
per year of TEQ. No activity  level data are available that would enable annual emission
estimates to be made specifically for reference years 1987 and 1995.
                                       7-19
                                                                           April 1998

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                         DRA.FT-DO NOT QUOTE OR CITE

       A "low" confidence rating is assigned to the activity level estimate because it is
based an expert Judgement rather than a published reference. A "low" confidence rating is
also assigned to the emission factor, because it was developed from stack tests conducted
                    i              •
at just one U.S. drum and barrel furnace and, thus, may not represent average emissions
from current operations in the United States. Based  on these confidence ratings, the
estimated range of potential annual emissions is assumed to vary by a factor of 10
between the Tow and high ends of the range. Assuming that the best estimate of annual
emissions (0.23-g TEQ/yr) is the geometric, mean of this range, then the range is calculated
to be 0.07-to b.73-g TEQ/yr.
                                       7-20                               April 1998

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                           DRAFT-DO NOT QUOTE OR CITE
          Table 7-1.  CDD/CDF Emission Factors for Secondary Aluminum Smelters
Congener/Congener
Group

2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1 ,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD
1 ,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
, 1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDFV
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD '
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
Mean Facility
Emission Factor
(ng/kg scrap feed)
(Ref. 1)
<0.01
0.02 \
0.05

0.13 :
0.15
0.51
0.42
, 0.44
0.06
0.17
0.32
0.1 1
0.02
0.30
0.07
0.03
0.30'
0.26
NR
NR
NR
NR
0.42
NR
NR
NR
NR
0.30
NR
Mean Facility
Emission Factor
(ng/kg scrap feed)
(Ref. 2)
0.13
0.39
OOA
»^*r
0.86
1.26
7,67
14.97
0.74
1.51
2.44
2.44
2.69
1.02
3.82
11.39
5.50
30.40
3.22
3.30
4.91
1 1 .45
14,71
14.97
29.67
28.73
32.23
39.44
30.40
209.81
Mean Facility
Emission Factor
(ng/kg scrap feed)
(Ref. 3)
0.51
1.19
IOC
.ob
1.52
2.51
2.60
1.01
14.20
10.47-
1 1 .Q6
21.84
7.10
0.47
7.09
14.61
1.21
3.15
12.95
46.03 .
28.07
35.51
6.01
1.01
161.80
'* 222.75
1 1 5.32
39.94
3.15
659 60
Mean Facility
Emission Factor
(ng/kg scrap feed)
(Ref. 4)
2.17
3.84

2.88
5.39
7.22
1.8.01
NR .
47.12
20.01
29.60
52.32
16.31
1 .20
22.96
35.29
5.17
	 18.77 	
	 36.03 	
NR
NR
• NR
NR
NR
NR
NR
NR
NR
18.77
NR
NR = Not reported.

Sources: Ref. 1:  Advanced Technology Systems, Inc. (1995)
       Ref. 2:  U.S. EPA (1995h)
       Ref. 3:  Galson Corporation (1995)
       Ref. 4:-Envisage Environmental, Inc. (1995)
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,1	jj,
                                              DRAFT-DO NOT QUOTE OR CITE
                            2,3,7,8-TCDD
                          1,2,3.7.8-PcCDD
                        i.2,3,4,7,8-itxCDD
                        1,2,3,6,7,8-HxCDr>
                        1,2,3,7,8,9-HxCDp
                      1,2,3.4.6,7,8-HpCDD
                      1,2,3.4,6,7,8,9-OCDD
                            2,3.7,8-TCpF
                          1,2,3,7,8-PeCDF
                          2,3,4,7,8-PeCDF
                                •  I'llHB!  ':,'•'• I
                        1,2,3,4.7,8-HxCDF
                        1,2,3,6.7,8-HxCDF
                        1,2,3,7,8,9-HxCpF
                        2,3,4,6,7,8-HxCDF
                      1^^.4,6,7,8-HpCDF
                                                    Ratio (congener emission factor / total CDD/CDF emission factor)
                                                  0.01      0.02      0.03      0.04      O.OS      0.06      0.07
                                                                                                                     0.08
                                      Ratio (congener group emission factor / total CDD/CDF emission factor)
                                       0.05                0.1                 0.15                0.2
                                                                                                                  0.25
              OCDF
                       Sources: U.S. EPA (1995h); Galson Corporation (1995)
                               Figure 7-1., Congener and Congener Group Profiles for Air Emissions"
                                                from Secondary Aluminum Smelters
                                                                7-22
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                 Table 7-2.  CDD/CDF Emission Factors for a Secondary Copper Smelter
'•
Congener/Congener Group
2,3,7,8-TCDD ;
1,2,3,7,8-PeCDD
1 ,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF . '
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1 ,2,3,7,8,9-HxCDF "', '
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF ,
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD ;
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
Mean Facility Emission Factor3

127
NR
' NR
NR
NR
NR
1,350
2,720
NR
NR
NR
/ NR
NR
NR
NR
NR
2,520
NR
NR
779b
736
970
1,260
2,O8O
1,350
13,720
8,640
4,240
3,420
2,520
38 890
NR = Not reported.


a      No nondetected values were reported for 2,3,7,8-TCDD, 2,3,7,8-TCDF, or any congener group in the
       three test runs.


       Estimated in U.S. EPA (1995c) based on the measured congener and congener group emissions.

Source: U.S. EPA (1987a).
                                           7-23
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                         DRAFT-DO NOT QUOTE OR CITE
                                   '            '         •     "
                    Ratio (congener group emission factor / total CDD/CDF emission factor)
       Source: U.S. EPA (1987c)


          ! "
                                                        : •*.
Figure 7-2. Congener Group Profile for Air Emissions from a Secondary Copper Smelter/Refiner
                                                     , I"
                                        7-24
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                        Table 7-3.  CDD/CDF Emission Factors for Secondary Lead Smelters
Congener/Congener Group
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1 ,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD '
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1 ,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1 ,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF "
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ (nondetects = 0)
Total TEQ (nondetects = 1/2 DL)
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total f CDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF (nondetects = 0)
Total CDD/CDF (nondetects = 1/2 DL)
Blast Furnace (Ref. A)
(ng/kg lead produced)
before ,
scrubber
2.11
0.99
0.43
, 0.99
1 .55
2.06
1 .40
8.73
3.88
6.65
5.83
1.67
0.11
2.06
2.34
0.63
1.39
9.52
33.28
8.31
8.32
74.33
39.29
20.05
4.20
1.39
145.71
69.59
19.73
4.74
1.39
380.43
380.44
after
scrubber
0.25
0.03
0.00
0.03
0.03
0.08
0.39
0.93
0.43
0.36
0.37
0.11
0.00
0.11
0.19
0.06
0.18
0.82
2.74
0.63
0.71
7.39
1.73
0.81
9.72
0.18
17.34
3.45
1.02
0.11
0.18
41.92
42.27
Blast/reverb (Ref. B)
(ng/kg lead produced)
before
0.00
0.00
0.00
0.00
0.00
0.10
0.57
1 .46 -
0.24
0.31
0.63
0.19
0.00
0.15
0.48
0.00
0.29
0.68
3.75
0.41
0.44
0.97
0.15
0.14
0.09
0.57
8.21
3.07
1.14
0.72
0.29
15.36
15.36
after ,
0.00
0.00
0.00
0.00
0.00
0.06
0.55
0.49
0.02
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.61
0.51
0.05
0.10
1.58
0.16
O.O2
0.09
0.55
4.71
0.36
0.19
0.01
0.00
7.66
Rotary kiln (Ref. C)
before
0.10
0.01
0.00
.*0.00
0.00
0.00
0.24
0.40
0.14
0.14
0.11
0.02
0.04
0.00,
0.03
0.00
0.00
0.35
0.88
0.24
0.25
3.40
0.29
0.10
0.01
6.24
10.82
1.69
0.15
0.05
0.00
16.76
after
0.24
0.00
O.OQ
0.00
0.00
0.22
.2.41
1.20
0.40
0.46
0.27
0.10
0.13
0.00
0.13
0.00
0.00
2.87
2.68
0.66
0.69
7.90
0.27
0.23
0.29
2.41
28.57
5.04
0.73
0.14
0.00
45.57
Sources: Ref. A: U.S. EPA (1995e); Ref. B: U.S. EPA (1992e); Ref. C: U.S. EPA (1995d)




Note: Except where noted, emission factors were calculated assuming nondetected values are zero.
                                              7-25
                                                                                        April 1998

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                               DRAFT-DO NOT QUOTE OR CITE
                                    Ratio (congener emission factor / total CDD/CDF emission factor)
                               O.O1    O.O2    O.O3    O.O4    O.OS    O.O6     O.O7    O.QS    O.O9
                                                                                                     O.I
2.3.7.S-TCDD
1 ^,3,7,8-PcCDD
I ,2,3,4,7,8-HxC:DD
1,2,3,6.7,8-HxCDD
1.2.3,7,8.9-HxCDD
1 ,2,3,4.6.7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF

i, ' ' : 'e/'Ki, i 	 ' 	
2,3,4,7,8-PeCDF
1^2,3,4,7.8-H%CDF
1 ^Z^ ,«.7,8-HxCDF
2.3.4,6,7.8-HxCDF
1^,3,4,7.8.9-HpCDF

1
•
^———m ' ' —
«••••— ^-,
^^^^^^Hasj
•-^^^^
-fa
•

                       Ratio (congener group emission factor / total CDD/CDF emission factor)
                  .„	' q:il, ,  ,	', „„	 0.2	,	'/,...  :i,o.3,'"    '['	' . '.  i0.4,."",_'      '.;  0.5
0.6
                «1:	itialiii^fc&fr^i^^rti'Cri^^        |
               ^^H Blast furnace                   tS^-A Reverb/co-located furnace

        Source: U.S. EPA (1992e); U.S. EPA (1995d); U.S. EPA (199Se)
Figure 7-3.  Congener and Congener Group Profiles for Air Emissions from Secondary Lead Smelters/Refiners
                                                 7-26
                                                                                               April 1998

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                             DRAFT-DO NOT QUOTE OR CITE
                      Table 7-4. Operating Parameters for U.S. Iron Ore Sinter Plants
Company,
A.K. Steel Corp.
A.K. Steel Corp.
Bethlehem Steel
Bethlehem Steel
Geneva Steel
Inland Steel
LTV Steel.
U.S. Steel
Weirton Steel
Wheeling-Pittsburgh
Steel
WCI Steel
Location
/ '
Middleton, OH
Ashland, KY
Burns Harbor, IN
Sparrows Point, MD
Provo, UT
East Chicago, IN
East Chicago, IN
Gary, IN
Weirton, WV
East Steubenville, WV
Warren, OH
TOTALS
Capacity
(1,000
MT/yr)
9O7
816
2,676
3,856
816
1,089
1,270
3,992
1,179
519
477
17,597
<
Grate
Area
(sq. m.)
71.3'
75.0
187.7
353.0
113.7
124.9
124.9
361.2
163.9
49.7
59 9*
1,685
Waste Gas
Fan Capacity
(1,000 m3/hr)
517
289
1,160
3,398
805
748
NA
'722
668
340
NA

Volumetric
Flow Rate
(m3/m2-hr)
7,251
3,852
6,184
9,625
7,082
5,987
NA
1,999
4,074
6,837
NA

* =. Grate area for WCI Steel was calculated using the average ratio of capacity to grate area for the Geneva Steel
and Inland Steel facilities both of which were constructed by the same builder (i.e., Dwight Lloyd).

NA = Not avaiable.

Sources: Metal Producing (1991; 1996)
                                            7-27
                                                                                     April 1998

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                       DRAFT-DO NOT QUOTE OR CITE
             Table 7-5. CDD/CDF Emission Factors for a Ferrous Foundry
Congener/Congener Group
2,3,7,8-TCDD
1 ,2,3,7,8-PeCDD
1 ,2,3 ,4,7,8-HxCDD
1 ,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1 ,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1 ,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1 ,2,3,4,6,7,8-HpCDF
1 ,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
Mean Facility Emission Factor
(ng/kg scrap feed)
(CARB, 1993a)
0.033
0.086
NR
0.051
NR
0.093
NR
0.520
0.305
0.350
0.190
0.170
NR
0.101
0.193
NR
0.059
0.262
1 .888
0.372
3.96
1.76
0.55
0.19
NR
25.8
850
1.74
0.24
0.06
884.3
MR = Not reported.




Source: CARB (1993a) (as reported in U.S. EPA,J997b)
                                    7-28
                                                                    April 1998

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                           DRAFT-J)O NOT QUOTE OR CITE
                                Ratio (congener emission factor / total CDD/CDF emission factor)
                           O.O1    O.O2    O.O3   ' O.O4    O.O5    O.O6    O.O7    O.O8    O.O9
                                                                                                    O.I
       2,3,7,8-TCDD
     1,2,3,7,8-PeCDD
  1,2,3 ,4,7,8-HxCDD
  1,2,3 ,6,7,8-HxCDD
  •1,2,3,7,8,9-HxCDD
 1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8.9-OCDD
       2,3,7,8-TCDF
     1,2^,7.8-PeCDF
     2,3,4,7,8-PeCDF
  1.2.3.4,7,8-HxCDF
  1 Ji,3 ,6,7,8-HxCDF
  1^,3,7,8,9-HxCDF
 , 2,3,4,6,7,8-HxCDF
 1^,3,4.6,7,8-HpCDF
 1 ^,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
                  Ratio Ccongener group emission factor / total CDD/CDF emission factor)
                                 0.2 .             0.3     •         0.4              0.5
                                                                                                   0.6
   Source: CA.RB (,1993s.) (as reported in U.S. EPA, 1997b)
  Figure 7-4.  Congener and Congener Group Profiles for Air Emissions from a Ferrous Foundry
                                             7-29
                                                                                             April 1998

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                            DRAFT-DO NOT QUOTE OR CITE
                fable 7-6.  CDD/CDF Emission Factors for a Scrap Wire Incinerator
                 Jliisi!  , '>•     ••  I1'1,, .: '•"  . . ''•' . '.;•„"£:, '", C-'' ?'•'' , '": ' "• '' !"! '  ."  *••!• :••.••''  t


Congener/Congener Group
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1 ,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1 ,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
Mean Facility
Emission Factor a
(ng/kg scrap feed)
0.374
NR
NR
NR
NR
NR
1 ,000
2.67
NR
NR
NR
NR
NR
NR
NR
NR
807
NR
NR
NR
4.42
13.7
71.1
347
1 ,000
107
97.4
203
623
807
3,273
NR =• Not reported

 h, .            ' :",!,ii;;;.  .  "     ""  L '. "'i  .'; ; '   "   ; 	 »  i ' ,, '•   • ' "I1 »''• • •,.  .''  i ,i!!;  ''  „     i, .

*   No nondetected values were reported for 2,3,7,8-TCDD, 2,3,7,8-TCDF, or any congener group in

    the three test runs.  .                        •



Source: U.S. EPA (1987a)
                                            7-30
                                                                                    April 1998

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                    DRAFT-DO NOT QUOTE OR CITE
               Ratio (congener group emission factor / total CDD/CDF emission factor)
0          °-05        0.1         0.15         0.2         0.25    .     0.3
0.35
  Source: U.S. EPA (1987a)
Figure 7-5.  Congener Group Profile for Air Emissions from a Scrap Wire Incinerator
                                  7-31
                                                                         April 1998

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                               DRAFT-DO NOT QUOTE OR CITE
          Table 7-7.  Geometric Mean CDD/CDF Concentrations in Fly Ash and Ash/Soil at Metal Recovery Sites


Congener/Congener Group


2,3,7.8-TCOD
1,2.3,7,8-PeCDD
1.2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3.4,6,7,8-HpCDD
OCOD
2,3,7.8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PcCDF
1,2.3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1.2,3.7.8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7.8-HpCDF
1,2,3.4,7,8,9-HpCDF
OCDF
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDO
Total TCDF
Total PeCDF
Total HxCDF
Total HpCOF
Total OCDF
Total TEQ
Total CDD/CDF
Metal Recovery Facilities
Fly ash (2 sites)
Geom.
mean
teg/kg)
*
400
1,200
2,300
1,700
12,000
18,000
15,000
35,000
10,000
46,000
12,000
5,000
5,000
71,000
25,000
100,000
*
2,000
4,000
24,000
18,000
23,000
110,000
88,000
110,000
100,000
19,000
510,000
Relative %
of Total
CDD/CDF

0.1%
0.2%
0.5%
0.3%
2.4%
3.5%
2.9%
6.9%
2.0%
9.0%
2.4%
1.0%
1.0%
13.9%
4.9%
19.6%
.
0.4%
0.8%
4.7%
3.5%
4.5%
21.6%
17.3%
21.6%
19.6%


Ash/Soil (3 sites)
Geom.
mean
tog/kg)
*
0.24
0.25
0.49
1.3
2.6
7.2
6.4
2.9
.1-4
5.9
1.8
0.92
1.6
12
3
14
*
1.4
2.7
4.1
7.2
14
12
12
17
14
2.9
85
Relative %
of Total
CDD/CDF

0.3%
0.3%
0.6%
1.5%
3.1%
8.5%
7.5%
3.4%
1.6%
6.9%
2.1%
1.1%
1.9%
14.1%
3.5%
16.5%
.
1.6%
3.2%
4.8%
8.5%
16.5%
14.1%
14.1%
20.0%
16.5%


Open Burn Sites
Ash/Soil (3 sites)
Geom.
mean
(Atg/kg)
*
0.24-
0.13
0.33
0.39
1.2
3.4
1.7
0.58
0.66
2.7
0.76
0.66
0.49
4.3
0.71
6.6
*
2.8
0.98
2.0
3.4
5.6
7.0
7.6
7.4
6.6
1.3
48.5
Relative %
of Total
CDD/CDF

0.5%
0.3%
0.7%
0.8%
2.5%
7.0%
3.5%
1.2%
1.4%
5.6%
1.6%
1.4%
1.0%
8.9%
1.5%
13.6%
*
5.8%.
2.0%
4.1%
7.0%
11.5%
14.4%
15.7%
15.3%
13.6%


* «• Analytical method utilized had low sensitivity for TCDDs; results were not reported.



Source: Harnly et al. (1995)
                                               7-32
                                                                                          April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
         Table 7-8.  CDD/CDF Emission Factors for a Drum and Barrel Reclamation Furnace


Congener/Congener Group
2,3,7,8-TGDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1 ,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF , ,
Mean Facility
Emission Factor3
(ng/drum)
2.09
NR
NR
MR '
liHi
NR
NR
37.5
36,5
NR
NR
NR
NR
NR
NR
NR
NR
22.4,
NR
NR
49.4b
,50.29
29.2
32.2
53.4
37.5
623
253
122
82.2
22.4
1,303 >
NR = Not reported.                                                               .


a  No nondetected values were reported for 2,3,7,8-TCDD, 2,3,7,8-TCDF, or any congener group in.
   the three test runs.                                                           ,
   Estimated in U.S. EPA (1995c) based on the measured congener arid congener group emissions.

Source: U.S. EPA (1987a).
                                        7-33
                                                                            April 1998

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               ,  DRAFT-DO NOT QUOTE OR CITE
             Ratio (congener group emission factor / total CDD/CDF emission factor)
           0.1            0,2            0.3           0.4            0.5
0.6
Source: U.S. EPA (1987a)
 Figure 7-6. Congener Group Profile for Air Emissions from a Drum Incinerator
                                  7-34
                                                                         April 1998

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                           DRAFT-DO NOT QUOTE OR CITE

              8. CHEMICAL MANUFACTURING AND PROCESSING SOURCES

  8.1.   BLEACHED CHEMICAL WOOD PULP AND PAPER MILLS
        In March of 1988, EPA and the U.S. pulp and paper industry jointly released the
  results from a screening study that provided the first comprehensive data on formation and
  discharge of CDDs and CDFs from pulp and paper mills (U.S. EPA, 1988'a). This early
  screening study of five bleached kraft mills ("Five Mill Study") confirmed that the pulp
  bleaching process was primarily responsible for the formation of the CDDs and CDFs.  The
  study results showed that 2,3,7,8-TCDD was present in seven of nine bleach pulps, five of
  five wastewater treatment sludges, and three of five treated wastewater effluents.  The
  study results also indicated that 2,3,7,8-TCDD and 2,3,7,8-TCDF were the principal CDDs
  and CDFs formed.
      • To provide EPA with more complete data on the, release of these compounds by the
  U.S. industry, EPA and the U.S. pulp and paper industry jointly conducted a survey during
  1988 of 104 pulp and paper mills in the United States to measure levels of 2,3,7,8-TCDD
 and 2,3,7,8-TCDF in effluent, sludge, and pulp (U.S. EPA,  1990a).  This study, commonly
 called the 104-Mill Study, was managed by the National Council of the Paper Industry for
 Air and Stream Improvement, Inc. (NCASi) with oversight by EPA, and included all US.
 mills where chemically produced wood  pulps were bleached with chlorine or chlorine
 derivatives. The final study report was released in July 1990 (U.S.  EPA,  1990a).
       An initial phase of the 104-Mill Study involved the analysis of bleached pulp (10
 samples), wastewater sludge (9 samples), and wastewater effluent  (9 samples) from eight
 kraft mills and one sulfite mill for all 2,3,7,8-substituted CDDs and CDFs.  These analyses
 were conducted to test the conclusion drawn in the Five-Mill Study that 2,3,7,8-TCDD and
 2,3,7,8-TCDF were the principal CDDs and CDFs found in pulp, wastewater sludge, and
 wastewater effluent on a toxic equivalents basis.  Although at the'time of this study there
 were no reference analytical methods for many of the 2,3,7>8-substituted CDDs/CDFs, the
-data obtained were considered valid by  EPA for the purposes intended based upon the
 identification and quantification criteria  used, duplicate sample results, and limited matrix
 spike experiments.  Table 8-1 presents a summary of the results obtained in terms of the.
 median concentrations and the range of concentrations observed for each matrix (i.e., pulp,
                                                     /•                           i
 sludge, and effluent).  Figures 8-1  through 8-3 present congener profiles for each matrix
                                       .8-1
                                                                           April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 (normalized to total CDD/CDF and to total TEQ) using the median reported concentrations.
 Based on examination of the raw/, mill-specific data, EPA (1990a) concluded that the
 cdrigener profiles were fairly consistent across matrices within mills and that 2,3,7,8-TCDD
 and 2,3,7,8-TCDF account for the majority of TEQ in the samples. Using the median
 concentrations and treating nondetected values as either zero or the detection limit, EPA
 (1990a) demonstrated that 2,3,7,8-TCDD and 2,3,7,8-TCDF accounted for 92.8 to 99.0
 percent of the total TEQ found in pulp, 92.7 to 95.8 percent of the TEQ in sludge) and
 72.7 to 91.7 of the TEQ in effluent.
       A similar full-congener analysis study was reported by IMCASI for samples collected
 from eight mills during the mid-1990s {Gillespie, 1997). The results of these analyses are
 presented in Table 8-2.  The frequencies of detection of 2,3,7,8-TCDD and 2,3,7,8-TCDF
 were significantly lower than in the previous i£>88 study.  Therefore, deriving meaningful
 summary statistics concerning the relative importance of 2,3,7,8-TCDD and 2,3,7,8-TCDF
 to the total TEQ is difficult.  Treating all nondetected values as zero indicates that 2,3,7,8-
 TCDD and 2,3,7,f-TCDF may account for 91 percent of the total effluent TEQ, 46 percent
 of the total sludge TEQ, and 87 percent of the total pulp TEQ. Because of the high
 frequency of nondetects, treating all nondetected  values as the detection limits indicates
 that 2,3,7,8-TCDD and 2,3,7,8-TCDF account for only 12 percent of the total effluent
  V1!   : .'"' I-"' ii II  I  '"•'   \,r:;'.:; ',.J,i:';".":r:i •"•'•' IVi'  '''• •-,«ii1"re;:;f:.,*••'•. KW:(••'"'•  1'    . I
 TEQ, 14 percent of the total sludge TEQ, and 12 percent of the total pulp TEQ.
       In 1992, die pulp and paper industry conductedfits own NCASI-coordinated survey
 of 2,3,7,8-TCDD and 2,3,7,8-TCDF emissions. The collected data were summarized  and
 analyzed in a report entitled Summary of Data Reflective of the Pulp and Paper Industry
 Progress in Reducing the TCDD/TCDF Content of Effluents, Pulps, and Wastewater
 Treatment Sludges (NCASI, 1993). Ninety-four mills participated in the NCASI study, and
 NCASl assumed that the remaining 10 (of 104) operated at the same levels as measured in
the 1988 104 Mill Study.  All nondetected values were counted  as half the detection limit.
 If detection limits were not reported, they were assumed to be 10 ppq for effluent and 1
 ppt for sludge or bleached  pulp. The data used in the report were provided by individual
 pulp and paper companies  that had been requested by NCASI to generate the data using
the same protocols used in the 104-Mill Study.  NCASI (1993) reported that the pulp and
paper industry had taken numerous steps to reduce CDD/CDF releases since 1988, and that
                                                 .   .
                                        8-2                                April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 the 1992 survey results were more reflective of releases at the end of 1992 than the data
 generated in the 104-Mill Study.
       As part of its ongoing efforts to develop revised effluent guidelines and standards
 for the pulp, paper, and paperboard industry, EPA in 1993 published the Development
 Document for the guidelines and standards being proposed for this industry (U.S. EPA,
 1993d). The Development Document presents estimates of the 2,3,7,8-TCDD and 2,3,7,8-
 TCDF annual discharges in wastewater from the mills in this industry as of January 1,
 1993. EPA used the most recent information about each mill from four data bases (104-
 Mill Study, EPA short-term monitoring studies at 13 mills, ,EPA long-term monitoring studies
 at 8 mills,  and industry self-monitoring data submitted to EPA) to estimate these
 discharges. The 104-MHI Study data were used only for those mills that did not report
 making any process changes subsequent to the 104-Mill Study and did not submit any
 more recent effluent monitoring data.
       Gillespie (1994; 1995) reported the results of 1993 and 1994 updates, respectively,
 to the 1992 IMCASI survey. As was the case in the 1992 survey, companies were
 requested to follow the same protocols for generating data used in the 104-Mill Study.
 Gillespie (1994; 1995) reported that less than 10 percent of mills had  2,3,7,8-TCDD and
 2,3,7,8-TCDF concentrations in effluent above the nominal detection limits of 10 ppq and
 100 ppq, respectively.  Similar results were obtained in the short- and  long-term  sampling
 reported  for 18 mills  in U.S. EPA  (1993d); 2,3,7,8-TCDD was detected at four mills, and
 2,3,7,8-TCDF was detected at nine mills.  Gillespie (1994) reported that wastewater
 sludges at most mills (i.e., 90 percent) contained less than 31 ppt of 2,3,7,8-TCDD and
 less than 100 ppt of  2,3,7,8-TCDF.  GilJespie (1995) also reported that 90 percent of the
 mills reported 2,3,7,8-TCDD and 2,3,7,8-TCDF concentrations in sludge  of less than 17 ppt
 and 76 ppt, respectively, in 1994. U.S. EPA (1993d) reported similar results but found
 detectable levels of 2,3,7,8-TCDD and 2,3,7,8-TCDF in sludges from 64 percent and 85
 percent of the facilities sampled, respectively.  Giljespie (1994) reported that nearly 90
 percent of the bleached pulps contained less than 2 ppt of 2,3,7,8-TCDD and less than 160
 ppt of 2,3,7;8-TCDF. Gillespie (1995) reported that 90 percent of the  bleached pulps
contained 1.5 ppt or less of 2,3,7,8-TCDD and 5:9 ppt or less of 2,3,7,8-TCDF.  The final
levels in white paper products would correspond to levels in bleached pulp, so bleached
paper products would also be expected to contain less than 2 ppt of 2,3,7,8-TCDD.
                                       8-3                                April 1998

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                       .   DRAFT-DO NOT QUOTE OR CITE
   ;,;;'   ,     ,   lyjfiii1	  ,  . .  ',>  . .  •  ;..'.•• ' "'• "   ;, •:• ,'  •< '• :„ •••' • •' ' "a . .lij'	"' .; .   - i    »
 Overall, a 92 percent reduction in TEQ generation from 1988 to 1993 was reported by
 1  *;, i;    in,   ,   ;I_;JH  , ,. •  ••. • f' , ' . V .  ' • .   ..' jniciv/!1:  ;, •',"	.(••..'',':' '.' '• >; '• Lii'> ;;,;,' ,; •  j,;  ••  f
 Gillespie (1994), with an additional 2 percent reduction reported in 1994 by Gillespie
 (1995).
        Estimates of National  Emissions in 1987 and 1995 - The U.S. annual discharges of
 2,3,7,8-TCDD, 2,3,7,8-TCDF, and TEQs due to these two compounds are summarized in
 Table 8-3 for each of the five surveys discussed above.  The release estimates for 1994
 from Gillespie (1995) and 1988 from U.S. EPA (1990a) are believed to best represent
 emissions in the reference years 1995 and 1987, respectively.  During the period between
 the conduct of the 104-Mill Study and the issuance  of the U.S. EPA Development
   •i   '   •• ",    . "' i'!:..  i      t  I1;.. •  "i  "V LV,"  ,'i'r-  :'. ;,<•' i. i-;;: '•• <1'\ > !''•'• '• >  ,J!i	'",   .
 Document (U.S. EPA, 1993d), the U.S. pulp and paper industry reduced releases of
 CDD/CDFs primarily by instituting numerous process changes to reduce the formation of
 CDD/CDFs during the production of chemically bleached  wood pulp.  Details on the process
 changes implemented are provided in U.S. EPA (1993d) and Gillespie (1995).  Because
 most of the reduction between 1983 and 1994 can  be attributed to process changes of a
 pollution prevention nature, it should be expected that the percentage reduction observed in
 effluent, sludge, and pulp emissions over this time period should be very similar, which is
 indeed the case. Observed percentage reductions in emissions  are 92 percent, 89 percent,
 and 93 percent for effluent, sludge, and pulp, respectively.
       The confidence ratings for these release estimates were judged to be high based on
 the fact that direct measurements were made'at virtually all facilities, indicating a high level
 of confidence in both the production and emission factor estimates.  Based on these high
 confidence ratings, the estimated ranges of potential annual emissions for effluent,  sludge,
 and pulp are assumed to vary by a factor of 2 between the low and high ends of the
 ranges. Assuming that the best estimates of annual emissions in 1995 (i.e., the' 1994
 estimates presented in Table 8-3) are the geometric  means of the likely ranges, then the
 ranges are calculated to be 13.8- to 27.6-g TEQ/yr for effluent, 20.0- to 40.0-g TEQ/yr for
 sludge,  and  17.0- to 34.0-g TEQ/yr for pulp (i.e., TEQs that will enter the environment in
 the form of paper products).  Assuming that the best estimates of annual emissions in
 1987 (i.e., the 1988  estimates presented in Table 8-3) are the geometric means of the
 likely ranges, then the ranges are calculated to be 252-to 504-g TEQ/yr for effluent, 243-
to 485-g TEQ/yr forsludge, and'375- to 714-g TEQ/yr for pulp.
                                         8-4                  .              April 1998

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                           DRAFT-DO NOT QUOTE OR CITE

        In 1990, the majority of the wastewater sludge generated by these facilities was
 landfilled or placed in surface impoundments (75.5 percent), with the remainder incinerated
 (20.5 percent), applied to land directly or as compost (4.1 percent), or distributed as a
 commercial  product (less than 1 percent) (U.S. EPA,  1993e).  No more recent (i.e., 1995)
 or earlier (i.e., 1987) data on disposition of wastewater sludges are available.  Using  these
 statistics, the best estimate of TEQ applied to land (i.e., not incinerated or landfilled)  in
 1995 was 1.4 g  (i.e., 4.1 percent of 28.4 g), and the range is 1.0- to 2.0-g TEQ/yr.  The
 central estimate and range for 1987 are 14.1-g TEQ (i.e., 4.1  percent of 343 g) and  16- to
 20-g TEQ, respectively.

 8.2.  MANUFACTURE OF CHLORINE, CHLORINE DERIVATIVES, AND METAL CHLORIDES
       No testing of CDD/CDF emissions to air, land,  or water from U.S.  manufacturers of
 chlorine, chlorine derivatives, and metal chlorides have been reported upon which to base
 estimates of national emissions. Sampling of graphite electrode sludges from European
 chlorine manufacturers indicates high levels of CDFs.  Limited sampling of chlorine
 derivatives-and metal chlorides in Europe indicates low lever contamination in some
 products.

 8.2.1. Manufacture of Chlorine
       Chlorine gas is produced by electrolysis of brine electrolytic cells.  Until the late
 1970s, mercury cells containing graphite electrodes were  the primary type of electrolytic
 process used in the chloralkali industry to produce chlorine.  As shown in Table 8-4, high
 levels of CDFs have been found in several samples of  graphite electrode sludge from
 facilities in Europe.  The CDFs dominate the CDDs in these sludges, and the 2,3/7,8-
 substituted congeners account for a large fraction  of the respective congener totals (Rappe
 etal., 1990b; Rappe et al., 1991; Rappe, 1993; Strandell  et al., 1994).  During the 1980s,
titanium metal anodes were developed to replace graphite  electrodes (U.S. EPA, 1982a;
 Curlin and Bommaraju, 1991).  Currently, no U.S. facility.is believed to use graphite
electrodes in  the production of chlorine gas (telephone conversation between L. Phillips,
Versar, Inc., and T. Fielding, U.S. EPA, Office of Water, February 1993).
        Although the origin of the CDFs in graphite electrode sludge is uncertain,
chlorination of the cyclic aromatic hydrocarbons (such as dibenzofuran) present in the coal

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                          DRAFT-DO NOT QUOTE OR CITE

 tar used as a binding agent in the graphite electrodes has been proposed as the primary
 source (Strandell et a!., 1994).  For this reason, sludges produced using metal electrodes
 were not expected to contain CDFs.  However, Strandell et ai. (1994) reported the results
 of an analysis of a metal electrode sludge from a facility in Sweden, analyzed as part of the
 Swedish Dioxin Survey.  As with the graphite electrode sludge, this sludge contained high
 levels of CDFs {similar to those of the graphite sludge) and primarily nondetectable levels of
 CDDs. The sludge showed the same type of CDF congener pattern reported by Rappe et
 al. (1991) and  Rappe (1993). Strandell et al.  (1994) suggested that chlorination of PAHs
 present in the rubber linings of the electrolytic cell may have formed the CDFs found in the
 one sample analyzed.
       Although not regulated specifically for  CDD/CDFs, EPA issued restrictions under the
 Resource Conservation and Recovery Act (RCRA) on the land disposal of wastewater and
 sludges generated by chlorine manufacturers utilizing the mercury cell process and the
 diaphragm process (with graphite electrodes) (Waste Codes K071, K073, and K106) (40
 CFR 268). In addition, EPA is currently evaluating whether to regulate the chlorine
   ;/     '      . >1i;['    •   •., »' ,  x« "• •'•  • . n'S.v:;:,,,:•• :• ?/-.•• '>;I1:»",!':   :; • .'£ j'W i'-1 . •'... ' !   '  "
 manufacturing  industry as a major source of hazardous air pollutants (HAPs) under Section
 112(b) of the Clean Air Act (CAA). As part of this investigation, monitoring of air
 emissions for HAPs (including CDD/CDFs) is being performed; preliminary results of the
 investigation indicate no detectable emissions of CDD/CDFs (telephone conversation
 between G. Sch,W|er, Versar, Inc., and I. Rosario, U.S. EPA, Office of Air Quality Planning
 and Standards, April 11,  1996).

 8.2.2. Manufacture of Chlorine Derivatives and Metal Chlorides
       The limited sampling of chlorine-derivative products indicates that these products
 contain very low, if any, concentrations of CDD/CDFs. Rappe et al. (1990c) analyzed a
sample of chlorine bleach consisting of 4.4 percent sodium hypochlorite. Most of  the
2,3,7,8-substituted CDD/CDF congeners were below the limits of detection (0.3 to 7 pg/L
for all congeners, except OCDD and OCDF, which were 12 and 20 pg/L, respectively).  No
   	•          »  '.Mull"  i                           i      \            |  .  '     • j .
2,3,7,8-substituted CDDs were detected. Tetra-, penta-,  and hexa-CDFs were detected at
   (V ,   '••    „  "; :/*  '!;< . '  :   I                       ! I        " I       .}'';'.  '	  . . ;
leve|s of 13 pg/L or lower. The TEQ content of the sample was 4.9-pg TEQ/L.  Hutzinger
and Fiedler (1991 a) reported finding no CDD/CDFs at a detection limit of 4 jwg/kg in chlorine
                                         8-6                                April 1998

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                          DRAFT--DO NOT QUOTE OR CITE

 gas or in samples of 10 percent sodium hypochlorite, 13 percent sodium hypochlorite, and
 31-33 percent hydrochloric acid at a detection limit of 1 //g/kg.
       Hutzinger and Fiedler (1991 a) reported the results of analyses of samples of FeCI2,
 AICI3, CuCI2, CuCI, SiCI4, and TiCI4 for their content of HpCDF, OCDF, HpCDD, and OCDD.
 The sample of FeCI3 contained HpCDF and OCDF in the low //g/kg range, but no HpCDD or
 OCDD were detected at a detection limit of 0.02 .^g/kg.  One of the two samples of AICI3
 analyzed also contained a low ^g/kg concentration of OCDF.  The samples of CuCI2 and
 CuCI contained sub /^g/kg concentrations of HpCDF, OCDF, and OCDD.  The results are
 presented in Table 8-5,

 8.3.   MANUFACTURE OF HALOGENATED ORGANIC CHEMICALS
       Several chemical production processes generate CDDs and CDFs {Versar, 1985;
 Hutzinger and Fiedler, 1991 a)., CDDs and CDFs can be formed during the manufacture of
 chlorophenols, chlorobenzenes, and chlorobiphenyls {Versar,  1985;  Ree et al., 1988).
 Consequently, disposal of industrial wastes from manufacturing facilities producing these
 compounds may result in the release of CDDs and  CDFs to the environment. Also, the
 products themselves may contain these compounds,  and when used/consumed, may result
 in additional releases to the environment. CDD and CDF congener distribution patterns
 indicative of noncombustion sources have been observed  in sediments in southwest
 Germany and The Netherlands. The congener patterns found suggest that wastes from the
 production of chlorinated organic compounds may be important sources of CDD and CDF
 contamination in these regions (Ree et al., 1988).  The production and use of many of the
 chlorophenols,  chlorophenoxy herbicides, and PCB  products are banned or strictly regulated
 in most countries. However, these products may have been a source of the environmental
 contamination that occurred prior to the  1970s and may continue to be a source of
 environmental releases based on limited use and disposal conditions (Rappe, 1992a).

 8.3.1.  Chlorophenols
       Chlorophenols have been widely used for a variety  of pesticidal applications.  The '
higher chlorinated phenols (i.e., tetrachlorophenol and pentachlorophenol) and their sodium
salts have been primarily used for wood preservation.  The lower chlorinated phenols have
been used primarily as chemical intermediates in the manufacture of other pesticides.  For
                                       8"7                .  ,             April 1998

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                           DRAFT-DO NOT QUOTE OR CITE

 example, 2,4-dichlorophenol is used to produce the herbicides 2,4-Dichlorophenoxyacetic
 acid (2,4-D), 4-{2,4-Dichlorophenoxy)butanoic acid (2,4-DB), 2-(2,4-DichIorophenoxy)-
 propanoic acid (2,4-DP), Nitrophen, Genite, and Zytron, while 2,4,5-trichlorophenol was
 used to produce hexachlorophene, 2,4,5-T, Silvex, Erbon, Ronnel, and Gardona (Oilman et
 al., 1988; Hutzinger and Redler, 1991 a).  [See Sections 8.3.7 and 8.3.8 for information on
 EPA actions to control CDD/CDF contamination of pesticides (including pentachlorophenol
 and its salts) and to obtain additional data on CDD/CDF contamination of pesticides.]
       The two major commercial methods used to produce chlorophenols are: (1)
 electrophilic chlorination of molten phenol by chlorine gas in the presence of catalytic
 amounts of a metal chloride and organic chiorination promoters and stabilizers; and (2)
 alkaline hydrolysis of  chlorobenzenes under heat and pressure using aqueous methanojic
 sodium hydroxide.  Other manufacturing methods include conversion of diazonium salts of
 various chlorinated anilines, and chlorination of phenolsulfonic acids and benzenesulphonic
 acids, followed by the removal of the sulphonic acid group (Oilman et al.,  1988; Hutzinger
 and Redler, 1991 a).
       Because of the manufacturing processes employed, commercial chlorophenol
 products can contain  appreciable amounts of impurities (Oilman et ai.,  1988). During the
 direct chlorination of phenol, CDD/CDFs can form either by the condensation of tri-, tetra-,
 •  "r ; . .  I ;•  '/ , |ji||j' ' i A, , - ,	 |'i .;. ; :;i"; . ".• ;•' ,_;•";
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                           DRAFT-DO NOT QUOTE OR CITE

 2,3,4,5-tetrachlorophenol, no more recent data on concentrations of CDDs and CDFs could
 be found in the literature for the mono- through tetra-chlorophenols. Tables 8-7 and 8-8
 present summaries of several studies that reported CDD/CDF concentrations in PCP and in
 PCP-Na products, respectively. Many of these studies do not report congener-specific
 concentrations, and many are based on products obtained from non-U.S. sources.
        Regulatory Actions - Section 8.3.8 of this report describes regulatory actions taken
 by EPA to control the manufacture and use qf chlorophenol-based pesticides.
        In the mid-1980s, EPA's Office of Solid Waste promulgated land disposal
 restrictions on wastes under RCRA (i.e., wastewaters and nonwastewaters) resulting from
 the manufacture of chlorophenols (40 CFR 268). Table 8-9 lists all  wastes in which CDDs
 and CDFs are specifically regulated as hazardous constituents by EPA, including
 chlorophenol wastes (waste codes F020 and F021).  The regulations prohibit trie land
 disposal of these wastes until they are treated to a level  below the routinely achievable
 detection limits in the waste extract listed in Table 8-9 for each of the following congener
                          i       '           '              .                         *
 groups: TCDDs, PeCDDs, HxCDDs, TCDFs, PeCDFs, and HxCDFs.  Wastes from PCP-wood
 preserving operations (waste codes K001 and F032) are  also regulated as hazardous  .
, wastes under RCRA (40 CFR 261).
       EPA's Office of Water promulgated effluent limitations for facilities that manufacture
 chlorinated phenols and discharge treated wastewater (40 CFR 414.70).  These effluent
 limitations do not specifically regulate CDDs and CDFs; however, the treatment processes
 required to control the chlorinated phenols that are regulated (2-chlorophenol and 2,4,-
 dichlorophenol) are also expected to reduce releases of any CDDs and CDFs that may be
 present in the untreated wastewater. The effluent limitations for the individual regulated
 chlorinated phenols are less than or equal to 39 ^g/L for facilities that utilize biological end-
 of-pipe treatment.
      DCPs and TrCPs are subject to reporting under the Dioxin/Furan Test Rule, which is
discussed in Section 8.3.7 of this report.  On the effective date of that rule (i.e., June 5,
 1987) and since that date, only the 2,4-DCP isomer has been commercially produced (or
imported) in the United States, and as noted in Table 8-6, no CDD/CDFs were detected in
the product. Testing is required for the  other DCPs and TrCPs, if manufacture or
importation resumes.  Similarly, TeCPs were subject to reporting  under the Dioxin/Furan
Pesticide Data Call-In (DCI) (discussed in Section 8.3.8 of this report).  Since issuance of
                                        8~9                                 April 1998

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                           DRAFT-DO NOT QUOTE OR CUE

 the DCI, the registrants of TeCP-containing pesticide products have elected to no longer
•  ::vi f :  "ii ,. i " '	Ji1!1! ?;•'••  ' ••   '•• •'  •• ,•,•:   , ,.,: ';,"";' ,; i '.• ',4 •'•>*•'. >>ii'..'' .';•''• : '  .if";'1';1 ..••.. .. !   \  '• ,
 support the registration of their products in the United States.
        In January 1987, EPA entered into a Settlement Agreement with pentachlorophenol
 (PCP) manufacturers, which set limits on allowed uses of PCP  and its salts and set
 maximum allowable concentrations of 2,3,7,8-TCDD and HxCDDs effective in February
 1989. Section 8.3.8 discusses the 1987 PCP Settlement Agreement and estimates current
 releases of CDD/CDFs associated with use of PCP in the United States.
        Since the late 1980s, U.S. commercial  production of chlorophenols has been limited
 to 2,4-dichlorophenol (2,4-DCP) and PCP. As  noted above, disposal of wastes generated
 during the manufacture of chlorophenols  are strictly regulated  and thus releases to the
 environment are expected to be negligible. With regards to releases associated with the
 use of 2,4-DCP, no CDD/CDFs have been detected in 2,4-DCP. Releases associated with
  !K   .  •••'•' '., *"§\ i"   -: i" ':•''•'.;  \",\\ .  •[."'>•*'• &'?:'<.,?',!'/' ; , •'.:'.':,''>'•;'." \:: .'   .!';:•!>' •!    "i  ' •
 the use of PCP are presented in Sections 8.3.8.
          ,„''„";"    ,    ,   ,         \        "             ' ' '

 8.3.2. Chlorobenzenes
        Chlorobenzenes have been produced in the United States since 1909.  U.S.
         '.   '    	i'i	         u               i   11     ' .-']•    !; ..;
 production operations were developed primarily to provide chemical raw materials for the
   :'< •"  ' . •  •'     'il"i             '       '              '   i  !   J'     • •:•'  :: I   '  '
 production of phenol, aniline, and various pesticides based on the higher chlorinated
 benzenes. Due to changes over time in the processes used to  manufacture phenol and
 aniline, and to the phase-out of highly chlorinated pesticides such as DDT and
 hexachlorobenzene, U.S. production of Chlorobenzenes decreased in 1988 to  50 percent of
 the peak production level in 1969.
        Chjorpbeozenes can be produced via three methods: (1) electrophilic substitution of
 benzene (in liquid or vapor phase) with chlorine gas in the presence  of a metal salt catalyst;
 (2) oxidative chlorination of benzene with HCI  at 150-300°C in the presence of a metal salt
 catalyst; and (3) denydrohalogenation of  hexachlorocyclohexane wastes at 200-240°C with
 a carbon catalyst to produce trichlorobenzene, which can be further chlorinated to produce
    • i,,   '„!,"' " '   " , ,., illlllf! ' "     ."  HI! 11,:1'"	i IK  ." ,„ i !! i,'" !'"il •"'., .''i.Jr'ii, '•"', >i: 	i.!',"",,,!1 „ „ «"i,,!1!! ',i,l: ijii' i|> j ••' i ,1, ,  !»!'!'i »„'",":'      !.
  ;,ii!!,'i., „   !|    i.. ]|   •	i ;''»,',,  • •,. „ fi'iii1. "u	IK' , -',!	',,,!MI,I •:;"",•„• • ,;,!• •",•!•;/I.1'' ,'i, liirii"11;,1,,;,!",! i1 .i:1,1!   .i1-,.*, !:y,i,,,Y     i
 higher chlorinated benzenes (Ree et al., 1988; Hutzinger and Fiedler, 1991 a; Bryant, 1993).
       All Chlorobenzenes currently manufactured in the United States are produced using
 the electrophilic substitution process using liquid phase benzene (i.e., temperature is at or
 below 80°C).  Ferric chloride is the  most  ppmmon catalyst employed. Although this
 method can be used to produce mono- through hexachlorobenzene,  the extent of

                                          8-10                                 April 1998

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                           DRAFT-DO NOT QUOTE OR CITE

  chlorination is controlled to yield primarily MCBz and DCBz. The finished product is a
  mixture of chlorobenzenes, and refined products must be.obtained by distillation and
  crystallization (Bryant, 1993).
        CDD/CDFs can be inadvertently produced during the manufacture of chlorobenzenes
  by nucleophilic substitution and pyrolysis mechanisms (Ree et al., 1988). The criteria
  required for production of CDD/CDFs via nucleophilic substitution are: (1) oxygen as a
  nuclear substituent (i.e., presence of chlorophenols) and (2) production and/or purification
  of the substance under alkaline conditions. Formation via pyrolysis requires reaction
-i.                            •»_''•           ,           "
 temperatures above 150°C (Ree et al., 1988; Hutzinger and Fiedler, 1991 a).  The liquid-
 phase electrophilic substitution process currently used in the United States does not meet
 any of these criteria. Although Ree et al. (1988) and Hutzinger and Fiedler (1991 a) state
 that the criteria for formation of CDD/CDFs via nucleophilic substitution may be present in
 the catalyst  neutralization and purification/distillation steps of the manufacturing process,
 Opatick (1995) states that the chlorpbenzene reaction product in U.S. processes remains
 mildly acidic throughout these steps.
                                                                   » .
       Table 8-10 summarizes the very limited published information on CDD/CDF *
 contamination of chlorobenzene products. The presence of CDD/CDFs has been reported in
 TCBz, PeCBz, and HCBz.  No CDD/CDFs have been reported in monochlorobenzene (MCBz)-
 and DCBz. Conflicting data exist concerning the presence of CDD/CDFs in TCBz.  One
 study (Villanueva et al.,. 1974) detected no CDD/CDFs in one sample of 1,2,4-TCBz at a
 detection limit of 0.1 yug/kg. Hutzinger and Fiedler (1991 a) reported unpublished results of
 Dr. Hans Hagenmaier showing CDD/CDF congener group concentrations ranging from 0.02
 to 0.074 f^g/kg in a sample of mixed TCBz. Because the TCBz examined by Hagenmaier
 contained about 2 percent hexachlorocyclohexane, it is reasonable to assume that the
 TCBz was produced by dehydrohalogenation of hexachlorocyclohexane (a manufacturing
 process not currently used in the United States).
      Regulatory Actions - EPA has determined, as part of the Federal Insecticide,
 Fungicide/and Rodentjcide Act (FIFRA) Pesticide Data Call-In (discussed in Section 8.3.8),
that the 1,4-DCBz manufacturing processes used in the United States are not likely to form
CDD/CDFs.  MCBz, DCBz,  and TCBz are also listed as potential precursor chemicals under
the TSCA Dioxin/Furan Test Rule and are subject to reporting.  (See Section 8.3.7.) In
addition, a Significant New Use Rule (SNUR) was issued by EPA under Section 5(a)(2) of

                                        8-11                                 Aprjl 1998

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                           DRAFTl-Dd NOT QUOTE OR

 TSCA on December 1, 1993, with an effective date of January 14, 1994, for PeCBz and
 1,2',4,5-TeCBz (Federal Register, 1993c). this rule requires persons to submit a significant
 new use notice to EPA at least 90 days before manufacturing, importing, or processing
 either of these compounds in amounts of 10,000 pounds or greater per year per facility for
 any use.  All registrations of pesticide products containing HCBz were  cancelled in the mid-
 1980s {Carpenter etal., 1986).
       EPA's Office of Solid Waste promulgated land disposal restrictions on wastes (i.e.,
 wastewaters and nonwastewaters) resulting from the manufacture of chlorobenzenes (40
 CFR 268). Table 8-9 lists all solid wastes in which CDDs and CDFs are specifically
 regulated as hazardous constituents by EPA, including chlorobenzene wastes.  The
 regulations prohibit the land disposal of these  wastes until they are treated to  a level below
 the  routinely achievable detection limits in the waste extract listed in Table 8-7 for each of
   IJ!"	•   i ,, :  ii ,   'i' H,!|i|!|!  	, ' ,„ " „, ; i ' ' ,|i«|	 , v,   , Ji >•» • , „ . ,,|i,, !' ."" ,f t ',,!'„ i|.   •', '  , " .'  „ "lW,i "t \< „.,'"     | ,, , .      -   ,    i
 the following congener groups:  TCDDs, PeCDDs, HxCDDs, T CDFs, PeCDFs, and HxCDFs.
       EPA's Office of Water promulgated effluent limitations for facilities that manufacture
 ' • ''«*;.. ,•   """::   '•  li.  •l"; >.'•"• ;i:«",:: H! "'.'!•'':''''':'.•;;• i;iVi ''KiT'.O ::.'*'-y'<<•'&'•>•>:•/. ' M&'I'r"'•''"'" l.!l "•  .r .',.'.'  '.
 chlorinated benzenes and discharge treated  wastewater (40 CFR 414.70).  Although these
  , ": :"    ; ' /  •,'•<  u"f.it 'v»': •.  '>",'',;'. .*;-•;!;, .'.'..':,•!'.;',{'• v>: ."''i;-,!t •;•,•' i  .';"1^:-'1',';:;''.•'.)''"''•.;j;::(»"i   . ..i '  .  :  ''       •• . •
 effluent limitations do not specifically address CDDs and CDFs, the treatment  processes
 required to control the chlorinated benzenes that are regulated (chlorobenzene; 1,2-
 '"'„'.    „'   „ ', :X!nu i ..,  •  '' 1  " '.' • '  "« '''  • '".!• " "•• i ""V '!!'„'" .."i • '!!"•",  .• '. !" ',., M»"	'»!"  •",	''. ",, '.  », , I
 dichlorobenzene; 1,3-dichlorobenzene; 1,4-dichiorobenzene; 1,2,4-trichlorobenzene; and
 hexachlorobenzenej  are expected to reduce releases of any CDDs and CDFs that may be
 present in the untreated wastewater. The effluent limitations for the individual regulated
 chlorinated benzenes are less than or equal to 77 j^g/L for facilities that utilize biological
 end-of-pipe treatment and are less than or equal to 196 ^g/L for facilities that  do not
 employ biological end-of-pipe treatment.
       Since at least 1993,  U.S. commercial production of chlorobenzenes has been limited
             .,  , 'Vriii, . .. ,  ..' • •",;;; • -;: •• . T., : ; " >(.,,"	-..i  •  •> ».   ••	v	, ••  •> ••  r ir	: •   . .- P
to MCBz,  1,2-dichIorobenzene (1,2-DCBz), 1,4-dichlorobenzene (1,4-DCBz), and, to a much
 lesser extent, 1,2,4-trichlorobenzene (1,2,4-TCBz).  As noted above, CDD/CDF formation
 is not expected under the normal operating conditions of the processes currently used in
the United States tp produce these four chemicals.  No tetra-, penta-, or hexachlorinated
 benzenes are now intentionally produced or used in the United States (Bryant, 1993).
Thus, releases of CDD/CDFs from manufacture of chlorobenzenes in 1995 were estimated
as negligible.  Because the available information on CDD/CDF content of MCBz to PeCBz is
very limited and is based primarily on unpublished European data and because  information
                                         8-12                                 April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 on the chlorobenzene manufacturing processes in place during 1987 is not readily available,
 no emission estimates can be made for 1987.   .

 8.3.3. Chlorobiphenyls
        PCBs are manufactured by the direct batch chlorination of molten biphenyl in the
 presence of a catalyst followed by separation and purification of the desired  chlorinated
 biphenyl fractions.  During the manufacture of PCBs, the inadvertent production of CDFs
 also occurred. The purpose of this section is to address potential releases of CDD/CDFs
 associated with leaks and spills of PCBs.  CDFs have been shown to form when PCB-
 containing transformers and capacitors undergo malfunctions or are subjected to fires that
 result in accidental combustion of the dielectric fluid. This combustion source of PCB-
 associated CDFs is discussed in Section 6.6.  Section 11.2 addresses releases of dioxin-like
 PCBs.
   »    Production of PCBs is believed to have been confined to 10 countries. The total
 amount of PCBs produced worldwide since 1929 (i.e.,  the first year of known production)
 is estimated to total  1.5-billion kg.  Initially, PCBs were primarily Used as dielectric fluids in
 transformers.  After World War II, PCBs found steadily increasing use as dielectric fluids in
 capacitors, as heat-conducting fluids in heat exchangers, and as heat-resistant hydraulic
 fluids in mining equipment and vacuum pumps. PCBs also were used in a variety of  "open"
 applications (i.e., uses from which PCBs cannot be re-collected) including: plasticizers,
 carbonless copy paper, lubricants, inks, laminating agents, impregnating agents, paints,
 adhesives, waxes, additives in cement and plaster, casting agents, dedusting agents,
 sealing liquids, fire retardants, immersion oils,  and pesticides (DeVoogt and Brinkman,
 1989).                               ''•"';••..'-'
       PCBs were manufactured in the United  States from 1929 until 1977.  U.S.
 production peaked in 1970, with a volume of 85-million pounds.  Monsanto Corporation,
 the major U.S. producer, voluntarily restricted the use of PCBs in 1971, and annual
 production fell to 40-rnillion pounds in 1974.  Monsanto ceased PCB manufacture in  mid-
 1977 and shipped the last inventory in October 1977.  Regulations issued by EPA
 beginning in 1977, principally under TSCA (40 CFR 761), strictly limited the production,
 import, use, and disposal of PCBs. (See Section 4.1 for details on TSCA regulations.) The
estimated cumulative production and consumption volumes of PCBs in the United States
                                        8-13
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                       .   DRAFT-DO NOT QUOTE OR CUE

 from 1930 to 1975 were: 1,400-million pounds produced; 3-million pounds imported
 {primarily from Japan, Italy, and France); 1,253-million pounds sold in the United States;
  ' ,           i 'Mil. • " : ' '„'',''  : ' ', • i"11'   i. '.•!, ;. ,«, ' ' , , , ",  (',, . "'„ • :' i : ,•!•,;, ' ,": ,\|1, 'i. ";,!• •!' 4, v : ,i. •:,    , :\     "
 and 150-million pounds  exported (ATSDR, 1993; DeVoogt and Brinkman, 1989).
  "('-'  :    " ,, "	 ' -iTK: ,'   ;  • , • .  ','". !"	, •' •-;"  •',•", (	', -.,.•,.  , .:, •• ,V,; , ..f . •• ;•_;,.,:,, ].',! ,  ; ,  .    , •.    I
       Monsanto Corporation marketed technical grade mixtures of PCBs primarily under
 the trade name Aroclor. The Aroclors are identified by a four-digit numbering code in which
 the last two digits indicate the chlorine  content by weight percent.  The exception to this
 c6ding scheme is Aroclor 1016, which contains only mono- through hexachlorinated
 congeners with an average chlorine content of 41 percent.  Listed below are the
 percentages of total Aroclor production  during the years 1957 to 1977 by Aroclor mixture
 as  reported by Brown (1994).

                                               1957-1977
                                             U.S. Production
                   Aroclor                        (%)  	
  ;,:       ,  ,  '• | \-: . :' 1221	 ' •  ...'",.	P 90  '  •••	
                    i6i6"'"'      '     "; "'    :  '12.88	"'"  '   •!
  :,,  '  -,  '	.-  ''I   1232  ,,  '   , .,'. ,   , ...  „    ',  0.24  ',"„.  ,	  ,
                    1242                        51-^6
  :;"           •':/ ,  1248, ,;  ",  '."i.i.'"':,"!!:, .'   "6.76,1""',"',,"   ':''•'.
               '.•!T "'1254" " : """   '  '   ' '"'  ' '    "i:5l73 '"'"
                   1260                        10.61
            •   ;;li": :" 1262  "  ' :'          	o43"
                   1268                          0.33
  i'"':   '   !l.  ': ••" ;,;i :; 'i  •• ,' ,!"'• -• i                            • ,    '  . i  ' •  :        '•
       The trade names  of the major commercial PCB technical grade mixtures
manufactured in other countries included: Clophen (Germany), Fenclor and Apirolio (Italy),
Kanechlor (Japan), Phenoclqr and Pyralene (France), Sovtel (USSR), De/or and Delorene
{Czechoslovakia), and  Orophene (German Democratic Republic) (DeVoogt and Brinkman,
1989). The mixtures marketed under these trade names were similar in terms of chlorine
content (by weight percent and average number of chlorines per molecule) to those of
various' Aroclors.  Listed  below are comparable mixtures in terms of chlorine content
marketed under several trade names.
      Aroclor      Clophen     Pyralene     Phenoclor    Fenclor      Kanechlor
      1232
      1242         A-30
      1248         A-4Q
      1254         A-50
      1260         A-60

                                        8'14                               April 1998
2000
3000




DP-3
, 	 DP-4
PP-5
'.PP-01.. „"

42
	
' 	 ,,,',,54 ;,
64
200
300
400
500
600

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  '".  ••'.'.             DRAFT-DO NOT QUOTE OR CITE


       During the commercial production of PCBs, thermal oxidative cyclization under
 alkaline conditions resulted in the inadvertent production of CDFs in most of the
 commercial PCB mixtures (Brown et al., 1988; ATSDR, 1993).  Bowes etal. (1975a) first
 reported detection of CDFs in Arpclpr products; samples of unused Aroclors manufactured
 in 1969 and 1970 were found to have CDF (i.e., TCDF through HxCDF) concentrations
 ranging from 0.8 to 2.0 mg/kg.  Bowes et al. (1975b) employed congener-specific
 analytical methodology and detected 2,3,7,8-TCDF and 2,3,4,7,8-PeCDF at concentrations
 ranging from 0.11  to 0.33 mg/kg and 0.12 to 0.83 mg/kg, respectively, in unused samples
 of Aroclor 1254 and Aroclpr 1260.  The presence of CDDs in commercial PCB mixtures,
 although at much lower concentrations than those of the CDFs, was reported by
 Hagenmaier (1987) and Malisch (1994).  Table 8-11 presents the CDF and CDD congener
 group concentrations reported by Bowes et al. (1975a) and those reported in subsequent
 years for unused PCBs by Erickson (1986), ATSDR (1993), Hagenmaier (1987), and
 Malisch (1994).
       Several researchers reported concentrations of specific CDD/CDFs congeners in
 commercial  PCB mixtures (Bowes et al., 1975b; Brown et al. 1988; Hagenmaier, 1987;
 Malisch, 1994).  Only the Hagenmaier (1987) and Malisch (1994) studies, however,
 reported the concentrations of all 2,3,7,8-substituted CDDs and CDFs. Table 8-12
 presents the results pf these four studies. It is evident from the table that major variations
 are found  in the levels of 2,3,7,8-TCDF and 2,3,4,7,8-PeCDF in the Clophen mixtures
 reported by Hagenmaier (1987) and Malisch (1994) and the corresponding levels in the
 Aroclor mixtures reported by Bowes  et al. (1975b) and Brown et al. (1988).
       Brown et al. (1988) compared the levels of 2,3,7,8-TCDF, 2,3,4,7,8-PeCDF, arid
 1,2,3,7,8,9-HxCDF in unused samples and used samples (i.e., samples from previously
 used capacitors and transformers) of Aroclors 1016, 1242, 1254, and 1260.  The
 concentration ranges reported for the used and unused Aroclors were similar, leading
 Brown et al. (1988) to conclude that CDFs are not formed during the normal use of PCBs in
 electrical equipment.
       Estimates of the amounts  of CDD/CDF TEQ that may have been released to the
environment during 1987 and 1995 from spills and leaks can be made using the release
data reported by manufacturing facilities to EPA's Toxics Release Inventory (TRI). Table
 11-6 in Section 11.2.2 lists the amounts of PCBs reported to TRI to be released to the
                                      8-15                 •     .        April 1998

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 environment during the years 1988 through 1993.  These TRI data include emissions to the
 air, discharges to bodies of water, and releases to land. Based on these data, annual
 emissions of PCBs to air during 1988 and 1993 could have been as high as 2.7 kg and as
 lovy as 0 kg, respectively.  If it is further assumed that the ratio of TEQ to total PCB in the
 air emissions was 0.17:1,000,000 (i.e., the average of the TEQ contents for Clophen A-30
 and Clophen A-50 [i.e., 170 /^g/kg] reported by Hagenmaier (1987) and presented in Table
   i'" ,'"••'.   '!  :  'i ,,K       ' '  .,'•, ''"'    ; '•  . "M '" 'i|,.,"'  ",'"!,,., '   ,|i| "";:,!.. ''"'" ••'! '„ 'T ' " ";LI!PJI • ' I'M     !•
 8-12), then annual emissions of TEQs to air  in 1988 and 1993 could have been 0.5 and 0
 mg, respectively.  Similar assumptions for PCB releases to water of 4.5 kg in 1988  and 0
              .  ' !•',;'  '••   ••  '  ' • •!.:,;• ' , l 'ii, '.,*V ">";<•;!-";   •'••!•'• '".'^ •• •£ \ •:•' ',; »'!'!' i* i ':' '••  1' '   ;
 kg in 1993 yield estimated TEQ emissions during  1988 and 1993 of 0.8 and 0 mg,
 respectively.  For land releases of 341  kg in  1988 and 120 kg in 1993, estimated TEQ
 emissions during 1988 and  1993 are 58 and 20 mg, respectively. All  of these estimated
 releases are considered to be negligible (i.e., less than 1 gram per year).
   »'. |i,  ,      • ' ' , ' '',:,'''	|III! ' ,'!'   i  	 I ',  • '• ' II ' , ' '  , ,  .""','";  , .     ' ,i ,  ' • , ''»• ,|  ,|n,'',!!' "'',,,''*  I     !         .
 8.3.4. Polyvinyl Chloride
       Although it is recognized that CDD/CDFs are formed during the manufacture of
 ethylene dichloride (EDC) and vinyl chloride monomer (VCM),  polyvinyl chloride (PVC)
 manufacturers and environmental public interest groups disagree as to the quantity of
           . . '  '• .-!;  :,(i,',    ' •iM,;;:'X; ",; i i"! -:•:£';,'•. '* ••  '•  -'f;;t1-•••',.&.,.•, :i.^';i •.,.*•  i; •  • : .         •'•  .
 CDD/CDFs formed and released to the environment  in wastes and possibly PVC products.
 Insufficient information is available at this time to  enable EPA to make definitive release
 estimates. Although EPA regulates emissions from EDC/VC production facilities under the
 Clean Water Act (40 CFR 61), the Clean Air  Act (40 CFR 414), and RCRA (40 CFR 268 -
 Waste Codes F024, K019,  and KQ2Q), CDD/CDFs are not specifically regulated pollutants;
 as a consequence, monitoring data for CDD/CDFs  in emissions are generally lacking. The
 Interim Phase I Report addressing products and treated  wastewater was submitted to EPA
 in November  1996  (The Vinyl Institute, 1996). The  remainder of |his section summarizes
 the available information and presents the release  estimates made by various interested
   i.v     •;•" 	.,  , i/li .r':11  '•'.  ,-;.V,ri. >lV^,::'>ri:y.':f'^'"'>'\im^^i'^:^,^^'  •,!..'••
 parties.
       In 1993, Greenpeace International issued a report on dioxin emissions associated
 with the production of EDC/VCM (Greenpeace, 1993).  Greenpeace estimated that 5- to
 10-g TEQ are released to the environment (air, water, and ground combined) annually for
every 100,000 metric tons  of VCM produced.  This emission factor was based on data
gathered by Greenpeace on four European plants.  The Vinyl Institute responded with a
                                        8-16
                                                                            April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 critique of the Greenpeace report {ChemRisk, 1993).  Miller (1993) summarized the
 differing views of the two parties. According to Miller (1993), European PVC
 manufacturers claim the emission factor is 0.01- to 0.5-g TEQ/100,000 metric tons of
 VCM.  Although Greenpeace (1993) and ChemRisk (1993) used basically the same
 monitoring information to develop their emission factors, Greenpeace adjusted the emission
 factor to account for unquantified fugitive emissions and waste products containing
 unspecified amounts of CDD/CDFs.
        In 1995, Greenpeace issued another study reiterating the organization's concern
 that the generation and emissions of CDD/CDFs may be significant and urging  that further
 work be initiated to quantify and prevent emissions (Stringer et ah, 1995).  However, this
 study acknowledged that because EDC/VCM production technologies and waste
 treatment/disposal practices are very site-specific, the limited information currently
 available on CDD/CDF generation and emissions makes it difficult to quantify amounts of
 CDD/CDFs generated and emitted.
       Tiernan et al. (1995) reported the results of testing two samples of ethylene
 dichloride, two samples of vinyl chloride monomer, and two samples from each of two
 different batches of powdered PVC pipe resin. The PVC resin analyses were performed
 using an extraction procedure that results in complete dissolution of the PVC resin,
 followed by liquid-liquid  extraction of the dissolved material. With the exception of OCDD,
 no CDD/CDFs were detected in any of the samples at detection limits ranging from less
 than 1 ng/kg for the tetra- and hexa- congener groups and 0.5 to 4.6 ng/kg for hexa-
 through octa-CDDs and CDFs.  The OCDD levels detected (6 to 8 ng/kg) were of the same
 magnitude as the OCDD levels detected in the blank samples implying background
 contamination.
      Stringer et al. (1995) presented the results of analyses of three samples of
 chlorinated wastes obtained from U.S. EDC/VCM manufacturing facilities. The three
 wastes were characterized according to EPA hazardous waste classification numbers as
 follows: (1) an F024 waste (i.e., waste from the production of short chain aliphatics by free
 radical catalyzed processes); (2) a.K019 waste (i.e., heavy ends from the distillation of
ethylene from EDC production); and a probable KO20 waste (i.e., heavy ends from
distillation of VC in VCM manufacture).  Table 8-13 presents the analytical results reported
by Stringer et al. (1995). The reported CDD/CDF concentrations in the three wastes were

                                       8-17                                April 1998

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                           DRAFT-DO NOT QUOTE OR CITE
           . '-    '.!':'!  '          ''»  , :"    • 'I1 !•.;.••.•",     '   .    ;":',.•'•!'   ! •
 20-^g TEQ/kg, 5,928-pg TEQ/kg, and 3.2-^g TEQ/kg for the F024, KOI 9, and K020 waste,
 respectively.  Stringer et al. (1995) stated that the concentration found in the K020 waste
 was similar to levels found in comparable waste from a VCM manufacturing facility in the
 United Kingdom  (3.1 to 7.6/zg/kg).
  ;'•!' !    • :" '• ;; ':*!;! •'    '. ,'  :'.  .V  .';•. :•'•:" •'•'.>*••' ;.  '.'.•-•..."/...'A' •   ,' !'!'.• •  '.'. ,.  i ;       •        , "
        In response to the lack of definitive studies and at the request of EPA, U.S. PVC
 manufacturers initiated an extensive monitoring program to evaluate the extent of any
 CDD/CDF releases to air, water, land, as well as product contamination.  Emission and
  !;''('''!    ,'' : 'I:  " '"I1 '' < . •;V • !/" ";, . '':, -''.'l'^"!;'!'''I! !--!'-.'': "•• 'I ":H' I:'!,' •. ;'"• ' ', W-.V' ,.''!;.'
 product testing are being performed at various facilities representative of various
 manufacturing and process control technologies. An independent peer review panel has
  .|i|j!|N i i'i. i i,     "'  ,;   " ', TJiUjliii,  :     : IH !  'I, i , -' ' •,,, •;   . •.'  '.,1" Ill/;, , " 1 , • i. . '. ' i, , ,,,],;;*,:," ; AA!' ', 'i1 |1|;!!i,  	Vt'.t ' i' ,'«i ' i   'j '      ' '
 been formed and is reviewing the results of all monitoring studies prior to their public
  '!"?":,'     ,''•'•"    i'":l! !  "'  r""1"" /"!"  I-'' ":,''<'i':  "•*•"•*$';:. 'i: f.^'.'k,;'.'' V's1;'''~' I":1'" !• ' *tl~^'] •*!' . ;•  "i  '  •'' '  ;       '  '
 release, the Interim Phase I Report from this study has been submitted to EPA, and the
  ,'i	"  '   ,,  ,    gt'til   • . '• ":, "'''•":., -1"i	 "i • , """ > :   ' ••'	.iv1,! .','•.'•"''   •  ::'"', ii';,. I, A i1!!:,/"!1 , ,,i '«  ,,!.,!' 'a	.v1 :"^ I.L Oi, ',*•. ;., .iin •:,!.:!! ,,!i, ' „ •,.   i.
resins.  The results ranged from ND to 0.008-pg TEQ/g  (mean = 0.001-pg TEQ/g assuming
NDs =  0, and 6.4-pg TEQ/g assuming NDs  = 1/2 DL).  The method detection limit was 2
  •I'.," " :     '   ' •"  iffilllli 'i  , Hi" ... ii   i    ii      M            i        in i    - •, ••   l •    '    •
  i:'':           '   /	M „ •,,     < <          il        i     ii    i       i    " ,   '      "
pg/g for all congeners except OCDD and OCDF (4 pg/g). The Vinyl Institute (1996) also
presented results for 5 samples from 5 of the 15 U.S. facilities manufacturing EDC.
CDD/CDFs were detected in only one sample (0.03-pg TEQ/g).  The method detection limit
for all congeners was 1 pg/g.  Based on 1995 production data and the average TEQ

                                •        8-18   	               April  1998

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                          DRAFT-DO NOT QUOTE OR CITE

 observed for the samples analyzed, total releases of CDD/CDF TEQs from suspension/mass
 PVC resins, emulsion PVC resins, and "sales" EDC were estimated by The Vinyl Institute
 (1996) to be 0.0 to 3.0 grams, 0.004 to 0.1 grams, and 0.008 to 0.29 grams,
 respectively.
       The estimated PVC production in the United States during 1995 was 5.656-million
 metric tons per year (The Vinyl Institute, 1996). Applying the worldwide emission factors
 discussed above to the U.S. PVC industry, gives a range of dioxin emissions of 0 56- to
 28.3-g TEQ/yr (based on the ChemRisk (1993) emission factors) to 283- to 565-g TEQ/yr
 (based on the 1993 Greenpeace emission factors). It is anticipated that the Vinyl Institute
 will be completing and releasing the full report on PVC resin,' wastewater treatment solids,
 waste water, and incinerator stack releases in the spring of 1998. EPA anticipates that
 this information, along with the information from previously cited sources, should be
 adequate to make a reasonable emission estimate for this inventory.

 8.3.5. Other Aliphatic Chlorine Compounds
       Aliphatic chlorine compounds are used as monomers in the production of plastics, as
 solvents and cleaning agents, and as precursors for chemical  synthesis (Hutzinger and
 Fiedler, 1991a). These compounds are produced in large quantities.  In 1992> 14.6-million
 metric tons of halogenated hydrocarbons were produced (U.S. ITC, 1946-1994).  The
 production of 1,2-dichloroethane and vinyl chloride accounted for 82 percent of this total
 production.  Highly chlorinated CDDs and CDFs (i.e., hexa-to octachlorinated congeners)
 have been found in nanograde quality samples of 1,2-dichloroethane (55 ng/kg of OCDF in
 one of five samples), tetrachloroethene (47 ng/kg of OCDD in one of four samples),
 epichlprohydrin (88 ng/kg of CDDs and 33 ng/kg of CDFs in one of three samples), and
 hexachlorobutadiene (360 to 425 ng/kg of OCDF in two samples) obtained in Germany
 from Promochem (Hutzinger and Fiedler, 1991 a; Heindl and Hutzinger, 1987). No
 CDD/CDFs were detected in two samples of ally chloride, three samples of 1,1,1-
trichloroethane, and four samples of trichloroethylene (detection limit ranged from 5 to 20
 ng/kg)  (Heindl and Hutzinger, 1987). Because no more recent or additional data could be
found in the literature to confirm these values for products manufactured or used in the
United  States, no nationalestimates of CDD/CDF emissions are made for the inventory.
                                       8-19                               April 1998

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                        .   DRAFT-DO NOT QUOTE OR CITE

        EPA's Off|ce Qf Water promulgated effluent limitations for facilities that manufacture
 chlorinated aliphatic chlorine compounds and discharge treated wastewater (40 CFR
 414.70).  Although these effluent limitations do not specifically address CDDs and CDFs,
 the treatment processes required to control the chlorinated aliphatic compounds that are
 regulated  (e.g., 68 //g/L for 1,2-dichloroethane and 22 //g/L for tetrachloroethylene) are
   . .I11',  ,   °      'b iR    'i,     i1  ", '.» ,'„  .  i, \'." , " ,f ,. "i.  "„ si,'  	, w ':>* 	TI  	 i .„• .    .  i,    *
 expected to reduce releases of any CDDs and CDFs that may be present in the untreated
 wastewater. Similarly, EPA's Office of Solid Waste promulgated restrictions on land
 disposal of wastes generated during manufacture of many chlorinated aliphatics (40 CFR
• ,  "K1  ::   '• I '  •    I1":)'!!  !•    •  <'"  , •<:'t". \  •"•'  i. .i 'i.':'. I ' • •'  *"•• "'", '•'•'• ::>." •'• a .' EVi '.•' '
 268); however, these restrictions do not specifically regulate CDD/CDFs.

 8.3.6. Dyes, Pigments, and Printing Inks
        Several researchers analyzed various dyes,  pigments, and printing inks obtained in
 Canada and Germany  for the presence of CDDs and CDFs (Williams et al., 1992; Hutzinger
 and Fiedler,  1991 a; Santl et al., 1994c). The following paragraphs discuss the findings of
 these studies.
        Dioxazine Pyes and Pigments -  Williams et al. (1992) analyzed the CDD/CDF content
 in djoxazine dyes and  pigments available in Canada. As shown in Table 8-15, OCDD and
 OCDF concentrations  in the /zg/g range, and HpCDD, HxCDD, and PeCDD concentrations in
 the ng/g range were found in Direct Blue 106 dye (3 samples), Direct Blue 108 dye
 (1 sample), and Violet 23 pigments (6  samples) (Williams et al., 1992). These dioxazine
 pigments are derived from chloranil, which has been found to contain high levels of
 , • 'lull'!    f 	• ,	'  , ' if»jni'i  i , •;  , '•'':, ;:;,'"'!„ ,*' " '» i ',  ,. i1:".!.:!1 >,'"',, ' ", a '  "i.; • ""i  i ''',:•,'''".: ', ''n, ' i" .'•!, Si 'i1:1: i> Si"1    w i    i
 "i1, , ii1,;,	  '  ' ji' „  "'  „ "' 'i	l,Ki!l!!lii  , '  ,	 • ," ' 'i.  , '|i'"i', ,,1,1. ,' .  .':,!"' /i:,'! i.,.: n, ',,  ' „ "n "   • » '»!" Hi.1 "i:,	•• "'i i,, ,  ':» ifc!1"! "I1 !"	• '    . i'l, ,  •• •.
 CDD/CDFs and has been suggested as the source of contamination among these dyes
 (Christmann et al.,1989a; Williams et  ai., 1992; U.S. EPA, 1992b).  In May 1990, EF>A
 received test results showing that chloranil was heavily contaminated with dioxins; levels
 as high as 3,065-^p TEQ/kg were measured in samples from four importers (mean value of
 1,754-^g TEQ/kg) (U.S. EPA, 1992b; Remmers et al., 1992). (See Section 8.3.7 for   .
 analytical results.)
       In the early 1990s, EPA learned that dioxin TEQ levels in chloranil could be reduced
 by more than two orders of  magnitude (to less than 20 ,ug/kg) through manufacturing
 feedstock and process changes.  EPA's Office of Pollution Prevention and Toxics (OPPT)
 subsequently began efforts to complete an industry-wide switch from the use of
   ,.';;/ .  ' 	;  "  " , Ml! "*•"••.;	i       i                   f I        i      •,••'! •'..••
 contaminated chloranil to low-dioxin chloranil. Although chloranil is not manufactured in
    *        "     "'"        	     '  "  ' '    '      ' ' '  "
                                         8-20                ,                April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 the United States, significant quantities are imported. As of May 1992, EPA had
 negotiated agreements with all chloranil importers and domestic dye/pigment manufacturers
 known to EPA that use chloranil in their products to switch to low-dioxin chloranil.  In May
 1993, when U.S. stocks of chloranil with high levels of CDD/CDFs had been depleted, EPA
 proposed a significant new use rule (SNUR) under Section 5 of TSCA that requires industry
 to notify EPA at least 90 days prior to the manufacture, import, or processing, for any use,
 of chloranil containing total CDD/CDFs at a concentration greater than 20 ,ug/kg (Federal
 Register, 1993a; U.S.  EPA, 1993c).
       In 1983,  approximately 36,500 kg of chloranil were imported (U.S. ITC, 1984).  The
 U.S. International Trade Commission (ITC) has not published quantitative import data for
 chloranil since 1984.  If it is assumed that this import volume reflects actual usage of
 chloranil in the United States during 1987 and the CDD/CDF contamination level was
 1,754-Atg TEQ/kg, then the maximum release into the environment via processing wastes
 and finished products was 64.0 g of TEQ.  If it is assumed that the import volume in 1995
 was also 36,500 kg, but that the imported chloranil contained  10-yug TEQ/kg on average,
 then the total potential annual CDD/CDF release associated with,chloranil in 1995 was
 0.36 g of TEQ. Given the low confidence in the estimates of import volumes in  1987 and
 1995, the estimated range of potential annual emissions for both years is assumed to vary
 by a factor of 10 between the low and high ends of the range. Assuming that 64.0-g
 TEQ/yr was the geometiric mean of this range for 1987, then the range is calculated to be
 20- to 200-g  TEQ/yr.  Assuming that 0.36-g TEQ/yr was the geometric mean of this range
 in 1995, then the range is calculated to be 0.11- to 1.1-g TEQ/yr.
       Phthalocyanine Dyes and Printing Inks - Hutzinger and Fiedler (1991 a) found
 CDD/CDFs (tetra-, penta-, and hexachlorinated congeners) in the ^g/kg range in a sample of
 a Ni-phthalocyanine dye.  No CDD/CDFs were detected (detection limit of 0.1 to 0.5>g/kg)
 in two samples of Cu-phthalocyanine dyes and in one Co-phthalocyanine dye (Hutzinger
 and Fiedler, 1991 a).
       Santl et al. (1994c) reported the results of analyses of four printing inks obtained
from a supplier in Germany.  Two of the inks are used for rotogravure printing, and two are
used for offset printing. The  results of the analyses are presented  in Table 8-16. The TEQ
content of the inks ranged from 17.5 to 90.1 ng/kg.  Primarily non-2,3,7,8-substituted
                                       8'21                                April 1998

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 congeners were found.  The identities of the dyes/pigments in these inks were not
 repbrted.
   .[;!'', ; '  '- 	 ,  „',    :t\ " "'  	I'' , " ; ,  •' ;| .  ,:    :'• ",;.:'(< [ i.  '' !; , ' • ; ,  '	 ". . • I "\  •' ' :'!'•" V   , '|.  '     •     '; ,
 8.3.7. TSCA Dioxin/Furan Test Rule
       Based on evidence that halogenated dioxins and furans may be formed as by-
 products during chemical manufacturing processes (Versar, 1985), EPA issued a rule under
 Section  4 of TSCA that requires chemical manufacturers and importers to test for the
   ' fj	 , , II ""'»  '' !' ,  li !'" I'll!!; I,  "'   |,  I'l. ' 	 ' „"	 ..I '!,,' '', ,  ,',?>:"!,",,I1, . I,, I.'"!. ll!1',1,',  .'' Ill' 'I1'! '!,:,,	 '.I,',,"	II' .'	 '!''   I ,     ,    .-
 presence of chlorinated and brominated dioxins and furans in certain commercial organic
 chemicals (Federal Register,  1987c).  The rule listed 12 manufactured  or imported
 chemicals that required testing and 20 chemicals not currently manufactured or imported
 that would require testing if manufacture or importation resumed.  These chemicals are
 listed in  Table 8-17.  The specific dioxin and furan congeners that require quantitation and
 the target limits of quantitation  (LOQ) are specified in the Rule are listed in Table 8-18.
 Under Section 8(a) of TSCA, the final rule also required that chemical manufacturers submit
 data on manufacturing processes and reaction conditions for chemicals produced using any
 of the 29 precursor chemicals listed in Table 8-19.  The rule stated that subsequent to this
   •	 '     -  .    ::;!:»'  .•  >.  ,  ,•»,(>  -I-, i"' -, i ••.•'.i.'W:••'.'!,. •'.;•; ••;;•; v,»'.;:';!;"; .r(>  ;,*!• >><;•, < ••< " !• ,.' • "
 data gathering effort, testing may be proposed for additional chemicals if any of the
 manufacturing conditions used favored the production  of dioxins and furans.
       Sixteen sampling and analytical protocols and test data for  10 of the 12 chemicals
 that required testing were submitted to EPA (Holderman and Cramer, 1995).  Data from 1 5
 submissions were  accepted; one submission is under review. Manufacture/import of two
 substances (tetrabromobisphenol-A-bis-2,3-dibromopropylether  and tetrabromobisphenol-A-
   "i  '     ' '..-.,   '   ;i3iii  "!  ; '   '•,»..  '." :  . 'f  "•:	''i;* '	• . . :' '!.'" •  'i •: ' •'. '. • ' "	•„"  i! !"!>• "•'..'!    „
 diacrylate) have stopped since the test rule was  promulgated.  [NOTE:  All data and reports
 in the EPA TSCA Docket are available for public  review/inspection at EPA Headquarters in
 Washington,  DC.]
       Table  8-20  presents the results of analytical testing for dioxins and furans for the
 eight chemicals with data available in the TSCA docket.  Five of these  10 chemicals
 contained dioxin/fufans.  Positive results were obtained for: 2,3,5,6-tetrachloro-2,5-
 cyclohexadiene-1,4-dione (chloranil), pentabromodiphenyloxide, octabromodiphenyloxide,
decabromodiphenyloxide, and 1,2-Bis(tribromophenoxy)-ethane.  table 8-21 presents the
quantitative analytical results for the four submitted chloranil samples,  as well as the
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                          DRAFT-DO NOT QUOTE OR CITE

  results of analysis by EPA of a sample of carbazole violet, which is manufactured from
  chloranil.
        It should be noted that although testing conducted under this test rule for 2,4,6-
  tribromophenol indicated no halogenated dioxins or furans above the LOQs, Thoma and
  Hutzinger (1989) reported detecting BDDs and BDFs in a technical grade sample of this
  substance. Total TBDD, TBDF, and PeBDF were found at 84//g/kg, 12 fjg/kg, and 1 fjg/kg,
  respectively.  No hexa-, hepta-, or octa-BDFs were detected.  Thoma and Hutzinger (11989)
  also analyzed analytical grade samples of two other brominated flame retardants,
  pentabromophenol and tetrabromophthaljc anhydride; no BDDs or BDFs were detected
  (detection limits not reported).

 8,3.8. Halogenated Pesticides and FIFRA Pesticides Data Call-in
       In the late 1970s and early 1980s, attention began to focus on pesticides as
 potential sources of CDDs and CDFs in the environment. Up to that time, CDD and CDF
 levels were not regulated in end-use pesticide  products.  Certain pesticide active
 ingredients, particularly chlorinated phenols and their derivatives, were known or
 suspected, however, to  be contaminated with CDDs and CDFs (e.g., pentachlorophenol
 (PCP), Silvex,  and 2,4,5-T). During the 1980s, EPA took several actions  to investigate and
 control CDD/CDF contamination of pesticides.
       In 1983, EPA cancelled the sale of Silvex and 2,4,5-T for all uses  (Federal Register,
 1983).  Earlier, in 1979, EPA ordered emergency suspension of the forestry, rights-of-way,
 and pasture uses of 2,4,5-T; emergency suspensions of the forestry, rights-of-way,
 pasture,  home and garden, commercial/ornamental turf, and aquatic weed control/ditch
 bank uses of Silvex were also ordered (Federal Register,  1979; Plimmer, 1980). The home
 and garden, commercial/ornamental turf, and aquatic weed control/ditch bank uses of
 2,4,5-T had been suspended in 1970.
       EPA entered into a Settlement Agreement in  1987 with PCP manufacturers to allow
 continued registrations for wood uses (Federal  Register, 1.987a) under a restricted use basis
 but which set tolerance levels for HxCDD and 2,3,7,8-TCDD. TCDD levels were not
allowed to exceed 1.0 ppb in any product, and after February 2, 1989, (a gradually phased
in requirement), any manufacturing-use PCP released for  shipment could not contain
HxCDD levels that exceeded an average of 2 ppm over a monthly release  or a batch level of

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                       -    DRAFT-DO NOT QUOTE OR CITE
"  ",:      ';   v  •*'*  '/"""''':   V   !   ' .: •  , :;!:''ii';' :': ,;'";":;  '  ',,  ••<•':>:''. ••'.'   ! " • '•    • :  '  ''':
 4 ppm.  On January 21, 1987, EPA issued a Final Determination and  Intent to Cancel and
 Deny Applications for Registrations of Pesticide Products Containing Pentachlorophenol
 (Including but not limited to its salts and esters) for Nonwood Uses, which prohibited the
 registration of PCP and its salts for most nonwood uses (Federal Register, 1987b).  EPA
 deferred action on several uses (i.e., uses in pulp/paper mills,  oil wells, and cooling towers)
 • n,'   \   .'.- '/'i'", I'm  . •  •• '"  	j  i1 ••   ,'',-' .••':	"i >;„•',.:  :':• ';•'""''  ".'•""• f\< ;•:,' • ffvT, ,;}•": ".'',''''"! ''Ifilfi1'" •• :  '  ]'  '
 the ranges are calculated to be 17,766- to 35,400-g  TEQ for  1995 and 25,500 to 51,000
  11:'''   '  "    »' , •  •: "iii  "     , I.- ' •  •" •'  •, . ii •',' ''"•' ,•;« ij • /  ii,,.,; '	 '  ,'„j •": ,••;,.,  •,,   ", 'V r  ,'' •',» •, :  i
 for 1987.
       In addition to the pesticide cancellations and product standards, EPA's Office of
 Pesticide Programs (OPP) issued two Daia Call-ins (DCIs) in 1987.  Pesticide manufacturers
  |i!!'!: ; ""  i," i 'r, • "ii ' -  "'li'JI "i" If'1",*;! :,-. •: '! 't>, ''IjTiii!11'" ,'*.)'> ••?"' 'it i,;':'!'1'1 :          I     II      :  'I "•''•',
 are required  to register their products with EPA  in order to market them commercially in the
 United States. Through the registration process, mandated by FIFRA, EPA can require that
  ,,;,,i :; •• '.  ''   ""    'It  '   i    	                     I   i     I     - "' • I ,  . ' , "  •  i  ;
 the manufacturer of each active ingredient generate a wide variety of scientific data
  ,,,ui' !    ;   ,„  ', '   ,11	,/iii  r1  i 	•,' „•	 	jr.	,111, •  ,i "in" 	 :i. , .. ' i.'iip >|	 ,i,,« ,, " ,, i'"i,    ', "H.1 • i,'"','i II'i l,il	• , •;, i in"! 1.11 / 1l,,i •• i  , '  i
 through several mechanisms. The most common process is the five-phase reregistration

                                         8-24                                April 1998

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                           DRAFT-DO NOT QUOTE OR CITE

 effort to which the manufacturers (i.e., registrants) Of older pesticide products must
 comply. In most registration activities, registrants must .generate- data under a series of
 strict testing guidelines, 40 CFR 158-Pesticide Assessment Guidelines (U.S.EPA, 1988b).
• Some pesticide active, ingredients may require additional data, outside of the norm, to
 adequately develop effective regulatory policies for those products.  Therefore, EPA can
 require additional data, where needed, through various mechanisms, including the DCI
 process.
       The purpose of the first DCI (dated June and October 1987), Data Call In Notice for
 Product Chemistry Relating to Potential Formation of Halogenated Dibenzo-p-dioxin or
 Dibenzofuran Contaminants in Certain Active Ingredients, was to identify through an
 analysis of raw materials and process chemistry, those pesticides that may contain  '
 halogenated  dibenzo-p-dioxin and dibenzofuran contaminants. The list of 93 pesticides,(76
 pesticide active ingredients) to which this DCI applied, along with their corresponding
 Shaughnessey  arid Chemical Abstract code numbers, are presented in Table 8-22.  [Note:
 the Shaughnessey code is an internal EPA tracking system-it is of interest because
 chemicals with similar code numbers are similar in chemical nature (e.g., salts, esters, and
 acid forms of 2,4-D).]  All registrants supporting registrations for these chemicals were
 subject to the requirements of this DCI, unless their product qualified for a Generic Data
 Exemption (i.e., a registrant exclusively used a FIFRA-registered pesticide product(s) as the
 source(s) of the active ingredient(s) identified in Table 8-22 in formulating their product(s)).
 Registrants whose products did not meet the Generic Data Exemption were required to
 submit the types of data listed below to enable EPA to assess the potential for formation of
tetra- through hepta-halogenated dibenzo-p-dioxin or dibenzofuran contaminants during
manufacture. Registrants, however, had the option to voluntarily cancel their product or
 "reformulate  to remove  an active ingredient," described in Table 8-22, to avoid compliance
with the DCI.

       •      Product Identity and Disclosure of Ingredients: EPA required submittal of a
             Confidential Statement of Formula (CSF), based on the requirements
             specified in 40 CFR 158.108 and 40  CFR 158.120 - Subdivision D: Product
             Chemistry. Registrants who had previously submitted still current CSFs were
             not required to resubmit this information.
                                        8-25
                                                                             April 1998

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                           DRAFT-DO NOT QUOTE OR CITE

               Description of Beginning Materials and Manufacturing Process: Based on the
               requirements mandated by 40 CFR 158.120 - Subdivision D, EPA required
               submittal of a manufacturing  process description for each step of the.
               manufacturing process, including specification of the range of acceptable
               conditions of temperature, pressure, or pH at each step.
               Discussion of the Formation of Impurities: Based on the requirements
               manClated by 40 CFR 158.120 - Subdivision D, EPA required submittal of a
               	i'JSI ' • ,   '   " :, '•i.lri • •'••.•; • .," '	- • ;	"I'.,. :• J y.t I,''-- •-» •>' K' •'.•: '.'   -:  I :.',•,"
               detailed discussion/assessment of the possible formation  of halogenated
               dibenzo-p-dioxins and dibenzofurans.
        The second DCI (dated June and October 1987), Data Call-In for Analytical
 Chemistry Data on Polyhalogenated Dibenzo-p-Dioxins/bibenzofurans (HDDs and HDFs),
1 .i  "F.	,  ! .  ' "'  ;  '.;'!•  ' ,ii'linn!' „„;.'ii ,	 i 'i,; r • ' \ \,,,  ,', .'i1 s   •	,,' ;,',,. i,' ir ii.: »i,: •• •' r i, • ", \	',,',' 	»,'" 4:'":,,:;	•' „:: • "i.  ,>' • ' vTIn,"i •;	",!-,• i. '  • r  •  , '' •
 wfs issued for 68, pestiqides (16 pesticide active  ingredients) suspected to be contaminated
 by CDD/CDFs.  (See fable 8-23.) All registrants supporting registrations for these
 pesticides were subject to the requirements of this DCI, unless the  product qualified for
 various exemptions or waivers. Pesticides covered by the second DCI were strongly
 suspected by EPA to contain detectable levels of  HDD/HDFs.
        Under the second DCI,  registrants whose products did not qualify for an exemption
 or waiver were required to generate and submit the following types of data in addition to
 the  data requirements of the first DCI:

   •'•' ••;'   !    •  ' "Mil' .  .  • •.;. ;  rsl:   >:: ••'.. ::-<'&"•:•'.W.••• •' '."?>•.'[.!•'>•*!'  >,  Vli^ • \ '•.  ,: ,   '
        •      Quantitative Method For Measuring HDDs or HDFs: Registrants were required
              to develop an  analytical method for measuring  the HDD/HDF content of their
                 ':!,! i,i :'  '   '	!	i1 ,'„ i"; ,1.1,' l|"""!',;! ," Jj i '„  L, i'1 -  i'1,;1,!  >., j ij/t,,, '".'i; :\ j  ' „;, vifii,, i1;1' x '.'',   j
              products. The DCI established a regimen for defining the precision of the
              analytical method (i.e., for internal standard—precision within +/- 20 percent
              and recovery range of 50 to 150 percent, also  a signal to noise  ratio of at
    ,; "  .-''...    ",i;* ',•    ..•'••   "*'". /'•:•'>( ; &:.,?, •:'...•';•>'&:*;: i  Hu:,- '" '• " iislli1",1!.!!1,*;, -..• i >.S 'Bli,. • •'•'' '•  : • I
              least 10:1 was required).  Target quantification limits were established in the
              DCI for specific HDD and HDF congeners. (See Table 8-24.)
       •      Certification of Limits .Qf.HP.Ds.or.HDFs;. Registrants were required to submit
              a "Certification of Limits" in accordance with 40 CFR 158.110 and 40 CFR
   :;,     •     '   ;.:-!! ,;. ,  ••        '        i             i       i   i       1 •..'•''.'
              158,120 - Subdivision D. Analytical results were required that met the
              guidelines described above.

                                          8-26                      '           April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

        Registrants could select one of two options to comply with the second DCI. The
 first option was to submit relevant existing data, develop new data, or share the cost to
 develop new data with other registrants. The second option was to alleviate the DCI
 requirements through several exemption processes including a Generic Data Exemption,
 voluntary cancellation, reformulation to remove the active ingredient of concern, an
 assertion that the data requirements do not apply, or the application/award of a low-
 volume, minor-use waiver.
       The data contained in CSFs, as well as any other data generated under Subdivision
 D, are typically considered Confidential Business Information (CBI) under the guidelines
 prescribed in FIFRA,  because they usually contain information regarding proprietary
 manufacturing processes. In general, all analytical results submitted to EPA in response to
 both DCIs are considered CBI and cannot be  released by EPA into the public domain.
 Summaries based on the trends identified in that data,  as well as data made public by EPA,
 are summarized below.
       The two DCIs included 161  pesticides. Of these, 92 are no longer supported by
 registrants.  Based on evaluations of the probess chemistry submissions required under the
 DCIs, OPP determined that formation of CDD/CDFs was not likely during the manufacture
 of 43 of the remaining 69 pesticides; thus, analysis of samples of these 43 pesticides was
 not required by OPP. Evaluation of process chemistry data is ongoing at OPP for an
 additional seven pesticides. Tables 8-22 and 8-23 indicate which pesticides are no longer
 supported, those for  which OPP determined that CDD/CDF formation is unlikely, and those
 for which process chemistry data or analytical testing results are under review in OPP (U.S.
 EPA, 1995a).
       OPP required that analysis of production samples be performed  on the remaining 19
 pesticides.  (See Table 8-25.) The status of the analytical data generation/evaluation to
 date is summarized as follows:  {1) no detection of CDD/CDFs above the LOQs in registrant
 submissions for 13 active ingredients; (2) detection of CDD/CDFs above the, LOQs for  2,4-D
 acid (two submissions) and 2,4-D 2-ethyl hexyl acetate (one submission); and (3) ongoing
data generation or evaluation for four pesticides.
      Table 8-24 presents a summary of results recently obtained by EPA for CDDs and
CDFs in eight technical 2,4-D herbicides; these data were extracted from program files in
OPP. Because some  of these files contained CBI, the data in this table were reviewed by
                                        8"27                               April 1998.

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                       '-. DRAFT-DO NOT QUOTE OR CITE
                                    ',,''.,     '         ",.'..'!.        \
 OPP sfaff to ensure that no CBI was being disclosed (Funk, 1996).  Figure 8-5 presents a
 congener profile for 2,4-D, based on the average, congener concentrations reported in Table
 8-24.
       Schecter et al. {1997) recently reported the results of analyses of samples of 2,4-D
 manufactured in Europe, Russia, and the United States.  (See Table 8-26.)  The total TEQ
 concentrations measured  in the European and Russian samples are similar to those
 measured in the EPA DCI  samples; however, the levels reported by Schecter et al. (1997)
 for  U.S. samples are significantly lower.
       An estimated 26,300 metric tons of 2,4-D were consumed in the United States in
 1995, making it one of the top 10 pesticides in terms  of quantity used (U.S. EPA, 1997a).
 An estimated 30,400 metric tons were consumed during 1987 (U.S. EPA, 1988c). Based
 on the average CDD/CDF  congener concentrations in 2,4-D presented in Table 8-24 (i.e.,
 not including OCDD and OCDF), the corresponding TEQ concentration is 0.70 //g/kg.
 Combining this TEQ concentration with the activity level estimates for 1995 and 1987
 indicates that 18.4 g and  21.3 g of TEQ may have entered the environment in 1995 and
 1987, respectively.  These release estimates are assigned a H/H confidence rating
 indicating high confidence in both the production and emission factor estimates. Based on
   '",'  ',   ' • 	  rim  r,  '  "• - li1'".1" "I""	i.'1 •'•'.'!' i'fi,.".; i?-' <;	T<: >;.'•.•• I.1*1!1!"''i. ','..'*:  ,'miw;,;. ,i. • ; " i    •:  •  .
   ,„» vi,,' "   i   '.,„:„   • j'i	   „  ' .',,'! ."hi ,:;  '„ •''  •' -,,:1'!'1:,' >r! .' i  i 	"" .' ZFI, !;:'' .M!1; :'!,,! .>!r  «;:;;	     ::     'i '•
 this high confidence rating, the estimated range of potential release is assumed to vary by a
 factor of 2 between the low and high ends of the range. Assuming that the estimated
 releases  of 18.4 g and 21.3 g  of TEQ are the geometric means of these ranges, then the
 ranges are calculated to be 13.0- to 26.0-g TEQ in 1995 and 15.1- to 30.2-g TEQ in 1987.
   ;t	   . .   .';   	• \ -,.,vi  -i, •' '	•:  ., • ;" ••  .'',., ;  i. . i. :• i 'i ' :.•. : i '  :., «.. >. .; » i.-, T,:  ••    i  • °  .• . •
   •I ,      . . '•	•	 i'111 in  ,    	  •	, ..i ' r	'•  • •• i  •.'   ' . «' .'.•.	 •• 'f '•',»-,	•. •••.•. i.  i ••  , .          /
 8.4.   OTHER CHEMICAL MANUFACTURING AND PROCESSING SOURCES

 8.4.1. Municipal Wastewater Treatment Plants
       Sources - CDD/CDFs have been measured in nearly all sewage sludges tested,
although the concentrations and, to some extent, the congener profiles and patterns differ
widely. Potential sources  of the CDD/CDFs include microbial formation (discussed in
Chapter 9), runoff to sewers from lands or urban surfaces contaminated by product uses or
deposition of previous emissions to air, household wastewater, industrial wastewater,
" '»"'=   -    •"!'  < "    III         I        '        I        I             ,'•'. ,|' ,•:•,.-.•'
chlorination operations within the  wastewater treatment facility, or a combination of all the
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                          DRAFT--DO NOT QU0TE OR CITE

 above (Rappe, 1992a; Rappe et al., 1994; Horstmann et al., 1992; Sewart et al., 1995-
 Cramer et a!., 1995; Horstmann and McLachlan, 1995).
       The major source(s) for a given Publicly Owned Treatment Works (POT W) is likely to
 be site-specific, particularly in industrialized areas.  For example, Rieger and Ballschmiter
                                 ',  '    >              •
 (1992) traced the origin of CDDs and CDFs found in municipal sewage sludge in Ulm,
 Germany, to metal manufacturing and urban sources.  The characteristics of both sources
 were similar  and suggested generation via thermal processing. However, in a series of
 recent studies, Horstmann et al. (1992; 1993a; 1993b) and Horstmann and McLachlan
 (1994a;  1994b; 1995) demonstrated that wastewater generated by laundering and bathing
 could be the  major source at many, if not all, POTWs that serve primarily residential  •
 populations.  Although runoff from streets during precipitation events, particularly from
 streets with high traffic density, was reported  by these researchers to contribute
 measurably, the total contribution of TEQ from household wastewater was eight times
 greater than that from surface runoff at the study city.
       Horstmann et al. (1992) provided initial evidence that household  wastewater could
 be a significant source. Horstmann et al. (1993a) measured CDD/CDF levels in the effluent
 from four different loads of laundry from two different domestic washing machines. The
 concentrations of total CDD/CDF in the four samples ranged from 3,900 to 7,100 pg/L and
 were very similar in congener profile, with OCDD being the dominant congener followed by
 the hepta- and hexa-CDDs.  Based on the similar concentrations and congener profiles
 found, Horstmann et al. (1993a) concluded that the presence of CDD/CDF in washing
 machine wastewater is widespread.  A simple mass balance performed using the results
 showed that the CDD/CDFs found  in the four washing machine wastewater samples could
 account for 27 to 94 percent of the total CDD/CDF measured in the sludge of the local
 wastewater treatment plant (Horstmann and  McLachlan, 1994a).
       Horstmann et al. (1993a) also performed additional experiments that showed that
 detergents, commonly used bleaching agents, and the washing cycle process! itself were
 not responsible for the observed CDD/CDFs.  To determine if the textile fabric or fabric
finishing processes could account for the observed CDD/CDFs, Horstmann et al. (1993b),
Horstmann  and McLachlan (1994a; 1994b), and Klasmeier and McLachlan (1995) analyzed
the CDD/CDF content of eight different raw (unfinished) cotton cloths containing fiber from
different countries and five different white synthetic materials (acetate, viscose, bleached
                                       8-29
                                                                          April 1998

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                             DRAFT-DO NOT QUOTE ORCITE

   polyester, polyamide, and polyacrylic), as well as over 100 new textile finished products.
:  '   •'•>''' :   "-. '•.•'•:.  '".Bi :  "   , '•<>, •:':  '  '  .••'"^:'! ."vt •• i::x V i'!''" '•ii;< •',;'';' :.'i ;:,'. -' Uf'.''.•.'•• ,-i ' ©'(-';   " •"!.  •  •,
   neither unfinished new fabrics nor common cotton finishing processes can explain the  .
   CDD/CDF levels found in wastewater.  Rather, the use of CDD/CDF-containing textile dyes
   arid pigments and the use in some developing countries of pentachlorophenol to treat
   unfinished cotton appear to be the sources of the detected CDDs/CDFs.
          Horstmann and McLachlan (1994a; 1994b; 1995)  reported the results of additional
   experiments that demonstrated that the small percentage of .clothing items with high
   CDD/CDF levels could be responsible for the quantity of CDD/CDFs observed in household
   wastewater and sewage sludge.  They demonstrated that the CDD/CDFs  can be gradually
   removed from the fabric during washing, can be transferred to the skin, subsequently
:     It:-;   '.   , I  i.l ,   li'NS • !    	 ,"; . ,V ,  ,	  • 	• i." ..  . .      ,•!•••..  :; . .vi , ,' '. •    I
   transferred  back to other texfiles, and then washed out, or can be transferred to other
   textiles during washing and then removed during subsequent washings.
          Releases to Water - The presence of CDD/COFs in  sewage sludge suggests that
   CDD/CDFs may also be present in the wastewater effluent discharges of POTWs; however,
   few studies reporting the results of effluent analyses for CDD/COFs have  been published.
          Rappe et al. (1989a) tested the effluent from two Swedish  POTWs for all 2,3,7,8-
   substituted  CDD/CDF congeners. OCDD was detected in the  effluents from both facilities at
   concentrations ranging from 14 to 39 pg/L.  1,2,3,4,6,7,8-HpCDD and 1,2,3,4,6,7,8-
   HpCDF were detected in the effluent of one facility at concentrations of 2.8 and 2.0 pg/L,
   respectively. No 2,3,7,8-substituted tetra-, penta-, and hexa-CDDs and CDFs were
   detected  (detection limits of 0.2 to 20 pg/L).
         Ho and Clement (1990) reported the results of sampling during the late  1980s of 37
   POTWs in OntariOj Canada, for each of the five CDD/CDF congener groups  with four to
     ,'•'.'      .   ;'  'I,'1'"'"i"  •   ; '/'',.,.' ';•... >!';S, ";• :.v ''V'I'M'.I  •''.•''.'•.''':	"I: .!<, "'f. I.'.'J •, H'l;1.'    '  -
   eight chlorines.  The sampled facilities included 27 secondary treatment facilities, 7 primary
   treatment facilities, 1  tertiary plant, and 2 lagoons. The facilities accounted for about 73
   percent of the sewage discharged by POTWs in Ontario.  No CDDs/CDFs were detected
   (detection limit in (pw ng/L range) in the effluents from the lagoons and the tertiary
   treatment facility.  Only OCDD and tCDF were detected in the effluents from the primary
   treatment facilities (two and one effluent samples, respectively)  HpCDD, OCDD, TCDF,
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  and OCDF were detected in the effluents from the secondary treatment facilities (detected
  in four or fewer samples at levels ranging from 0.1 to 11 ng/L).
        Gobran et al. (1995) analyzed the raw sewage and final effluent of an Ontario,
  Canada, wastewater treatment plant for CDD/CDF congeners over a 5-day period.
  Although HpCDD, OCDD, HpCDF, and OCDF were detected in the raw sewage (12 to
  2,300 pg/L), no CDD/CDFs were detected in the final effluent at congener-specific
  detection limits ranging from 3 to 20 pg/L.
       The California Regional Water Quality Control Board (CRWQCB, 1996) reported the
  results of effluent testing at nine POTWs in the San Francisco area.  A total of 30 samples
  were collected during 1992-1995; 1 to 6 samples were analyzed for each POTW. Table 8-
  27 summarizes the sampling results. With the exception of OCDD, most 2,3,7,8-
 substituted CDD/CDF congeners were seldom detected.
       The CRWQCB (1996) data were collected to be representative of effluent
 concentrations in the San Francisco area; these data cannot be considered to be
 representative of CDD/CDF effluent concentrations at the 16,000+ POTWs nationwide.
 Therefore,  the data can only be used to generate a preliminary estimate of the potential
 mass of CDD/CDF TEQ that may be released annually by U.S. POTWs. Approximately 122-
 billion liters of wastewater are treated daily by POTWs in the United States (U.S. EPA,
 1997c).  Multiplying this value by 365 days/year and by the "overall mean" TEQ
 concentrations listed in Table 8-27 (i.e., 0.29 pg/L, assuming not detected values are zero,
 and 3.66 pg/L, assuming not detected values are one-half the detection limit) yields annual
 TEQ release estimates of 13 to 163 grams/year.
       Sewage Sludge Land Disposal - EPA conducted the National Sewage Sludge Survey
 in 1988 and 1989 to obtain national data on sewage sludge quality and management.  As
 part of this survey, EPA analyzed sludges from 174 POJWs that employed at least
 secondary wastewater treatment for more than 400 analytes including CDD/CDFs.
 Although sludges from only 16 percent of the POTWs had detectable levels of 2,3,7,8-
 TCDD, all sludges had detectable levels of at least one CDD/CDF congener (U.S. EPA,
 1996a).. TEQ concentrations as high as 1,820-ng TEQ/kg dry weight were measured. The
congener-specific results of the survey are presented in Table 8-28. If all nondetected
values found in the study are assumed to be zero, then the mean and median CDD/CDF
concentrations of the sludges from the 174 POTWs are  50- and 11.2-ng TEQ/kg (dry
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 weight basis), respectively. If the nondetected values are set equal to the detection limit,
   v :: ni :  •   . ,",    mu1;;  ,„ !•   •   " • :   »'   	,:».. 	i» "!•"; n; , „!	 ' . m  .• , i	 , • :• , it,1!;:1,, ,"• ,     i
 then the mean and median CDD/CDF concentrations are 86-and 50.4-ng TEQ/kg,
 respectively {U.S. EPA, 1996a; Rubin and White, 1992).
       Green et al, (1995) and Cramer et al. (1995) reported the results of analyses of 99
 samples of sewage sludge collected from 75 wastewater treatment plants across the
 United States during the summer of 1994.  These data are summarized in Table 8-29. For
 the calculation of results in units of TEQ, results from al! samples collected from the same
 facility were averaged  by  Green et al. (1995) to ensure that results were not biased
 towards the concentrations found at facilities from which more than one sample were
   ••Vi >./•  •'   , ' -  "JIS .'.  .'   • ;*. ;•!'..•,:•'£ i''1'1. '. •/	I'-i'")!;,1	''.',".",V;!'- 'l,.i'v, •,,,'.,! V*  'I"1'*1'	  ~  .:';  I
 collected.  If all nondetected values are assumed to be zero, then the POTW mean and
 median CDD/CDF concentrations were 47.7- and 30,0-ng TEQ/kg (dry weight basis),
 respectively (standard  deviation of 45.0-ng TEQ/kg).  If the nondetected values are set
 equal to the detection  limits, then the POTW mean and median CDD/CDF concentrations
 were 64.6- and 49.1-ng TEQ/kg, respectively (standard deviation of 50.6-ng TEQ/kg). The
 mean and median results reported by Green et al. (1995) and Cramer et al. (1995) are very
 similar in te.rms of Jptal TEQ to those reported by EPA for samples collected 5 years earlier
 (U.S. EPA, 1996a; Rubin and White, 1992).  The predominant congeners in both data sets
 are the octa- and hepta CDDs and CDFs. Although not present at high concentrations,
           .•,' ", . '  ifj-i1  !':;!!'  . • . •, •. '  i A  • f '   ' • •!:",;,: :' ' '<  -• ""., , , ij ' ••.*.. ,  " , „'.	 ..    i  ,  :.
 2,3,7,8-TCDF was commonly detected.
       The CDD/CDF concentrations and congener  group patterns observed in these two
 U.S. surveys are similar to the results reported for sewage sludges in several other Western
 countries.  Stuart et al. (1993) reported  mean CDD/CDF concentrations of 23.3-ng TEQ/kg
 (dry weight) for three sludges from rural  areas, 42.3-ng TEQ/kg for six sludges from light
 industry/domestic areas, and 52.8-ng TEQ/kg for six sludges from industrial/domestic areas
 collected during 1991-1992 in England and Wales'.  Naf et al. (1990) reported CDD/CDF
 concentrations ranging  from 31 - to 40-ng TEQ/kg (dry weight) in primary and digested
 sludges collected from  the POTW in Stockholm, Sweden, during 1989.  Gobran et al.
 (1995) reported an average CDD/CDF concentration of 15-7-ng TEQ/kg in anaerobically
digested sludges from an industrial/domestic POTW in Ontario, Canada.  In all  three studies,
the congener group concentrations increased with increasing degree of chlorination, with
OCDD the dominant congener.  Figure 8-6 presents congener profiles, using the mean
concentrations reported by Green et al. (1995).
       • •  ,   •    HI       .•;- ',:,;  i, .>,;•.•  - ,:«.!•  ••  * ..• ;• ;•   ,  :,<•:„;:,•, ;, •  ir;l,v ',  '   ':   •        . .  •

                                        8-32                 .               April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
        r         -     •        '          '              •    '      .        '
       Approximately 5.4-million dry metric tons of sewage sludge are estimated by EPA to
 be generated annually in the United States based on the results of the 1988/1989 EPA
 "National Sewage Sludge Survey (Federal Register, 1993b).  Table 8-30 lists the volume of
 sludge disposed annually by use and disposal practices.  No more recent comprehensive
 survey data to characterize sludge generation and disposal practices during 1995 are
 available.  For this reason, and because the median TEQ concentration values reported in
 the 1988/1989 survey (U.S. EPA, 1996a) and the 1995 survey (Green et al., 1995; Cramer
 et al., 1995) were nearly identical, the estimated amounts of TEQs that may have been
 present in sewage sludge and been released to the environment in 1987 and 1995 were
 assumed to be the same. These values, presented in Table 8-30, were estimated using the
 average (i.e., 50-ng TEQ/kg) of the median TEQ concentration values (nondetected values
 set at detection limits) reported by U.S. EPA (1996a) (i.e., 50.4-ng TEQ/kg) and by Green
 et al. (1995) and Cramer et al. (1995) (i.e., 49.1-ng TEQ/kg).  Multiplying this mean total
 TEQ concentration by the sludge, volumes generated, yields an annual  potential total release
 of 208 grams of TEQ for nonincinerated sludges. Of this 208 grams of TEQ, 3.6 grams
 enter commerce as a product for distribution and marketing.  The remainder is applied to
 land (105.5 grams) or is landfilled (98.8 grams).
       These release estimates are assigned a  H/H confidence rating indicating high
 confidence in both the production and emission factor estimates.  The high rating was
 based on the judgement that the 174 facilities tested by EPA (U.S. EPA, 1996a),  and the
 75 facilities tested by Green et al. (1995) and Cramer et al. (1995) were reasonably
 representative  of the variability in POTW technologies and sewage characteristics
 nationwide. Based on this high confidence rating, the estimated range of potential annual
 emissions is assumed to vary by a factor of 2 between the low and high ends of the range.
 Assuming that the best estimate of annual emission to land (105.5-g TEQ/yr) is the
 geometric mean of this range, then the range is calculated to be 74.6- to 149-g TEQ/yr.
 Assuming that the best estimate of 3.6-g TEQ  annual emissions in product (i.e., the
fraction of sludge that is distributed and marketed as a product) is the  geometric mean of
the range, then the range is calculated to be 2.5- to 5.0-g TEQ/yr.
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1	  '  -, ;.• [-'  . .•   • • ..  • t;  '.       ..•;    •. . ••     '!  :•,', ;; ' ' v ' ''•<' -.' , .  ;  , { • '.V ':, l •    • '
   8.4.2. Drinking Water Treatment Plants
          There is no strong evidence that chlorination of water for drinking purposes results
   in the formation of CDD/CDFs.  Few surveys of finished drinking water for CDD/CDF
   content have been  conducted. The few that have been published only rarely report the
i,  .   "<,	i  ;•.. -  	•,'•	.•• • . tit  ••     ,   ii'. "  ,"',  •.,	'    	Hi '  TI	i '.'.•.!•    i
   presence of any CDD/CDF even at low pg/L detection limits, and in those cases, the
   CDD/CDFs were also present in the untreated water.
          Rappe et al. (1989b) reported the formation of CDFs (tetra- through octa-chlorinated
   CDFs) when tap water and double-distilled water were chlorinated using chlorine gas.  The
     .I,::"!'!  i, 	 .  » ", "   p'iiii . r<:   ,,\   ',  : ,11. 	:  i':.j:Hr;;,» ' ,|J • ir''„" ' .1 ,,ii!|ii,l!!li;!i\ ;i"'':i" lii'ft- : "ii;/" ,,:„, ',     ';     u      •
   CDF levels found in the single samples of tap water and double-distilled water were 35- and
   7-pg TEQ/L, respectively.  No CDDs were detected at detection limits ranging from 1 to 5
   pg/L. However, the water samples were chlorinated at a dosage rate of 300 mg of chlorine
   per liter of water, which is considerably higher (by a factor of one to two orders of
   magnitude) than the range of dosage rates typically used to disinfect drinking  water.
   Rappe et al. (1989b) hypothesized that the CDFs or their precursors are present in chlorine
   gas.  Rappe et al. (1990a) analyzed a 1,500-liter samp|e of drinking water from a municipal
   drinking water treatment plant in Sweden.  Although the untreated water was not
   analyzed, a sludge sample from the same facility was analyzed.  The large sample volume
   ,;"''"' ;.    '  , •   i  'i,; i'jj!;;  :;•   ' '••  « '"', :, : ,m , • fl  ',';'[ , J"''.' ",,'•:' i'•' i 'i'1'"., V1 '   : "J; ""!•'' «" •'!', !Viii; •''  iifyfF''''''' ' '•,; , '•  :i  i1     ' •        •,
   enabled Rappe et al. (1990a) to detect CDD/CDFs at concentrations on the order of 0.001
   pg/L The TEQ content of the water and sludge was 0.0029-pg TEQ/L and 1.4 ng/kg,
   respectively.  The congener patterns of the drinking water and sludge sample were very
   similar, suggesting that the CDD/CDFs detected in the finished water were present in the
   untreated water.

   8.4.3. Soaps and Detergents
         As discussed in Section 8.4.1, CDD/CDFs were detected in nearly all sewage .
   sludges tested whether obtained from industrialized areas  or rural areas.  Because of their
   ubiquitous presence in sewage sludge, several studies have  been conducted to determine
  the spurce(s) of the CDD/CDFs.  A logical category of products to test because of their
  widespread usage are detergents, particularly those that contain or release chlorine during
  use (i.e., hypochlorite-containing and dichloroisocyanuric acid-containing detergents). The
"•   '  'v;:  ,     ""   • "' "\'>S , T  •..'  • "'••"-.'' '  ;:  .'',•' ". •)'	•»'',;:": i ''•')'.<':i v/.ilwr'^Kf!:1'':1'1.1'.'.'Ki.'/.' '  ,.  ''if1'   <    '•'•'',•
  results of studies conducted to date, which are summarized below, indicate that CDD/CDFs
     	     	    iii!:!!!! •<,•',   : •'-.'• i'-':-.' '"":,', • '• >' ' i •. •,';.>>iii,-1.' ivitm .'jJ..m.«.,!*'flOT •«•»:'ii', «'*>;:'' *. ' •   i, •   .\   •       .
              •   ' ,c HiJiiniii!! :t ,  ',   ," :•'•  c  ',  /", 	 i1"! '"-V'';  i:1:', .li,,,11,,, ' I!iii111;!"li:ifljl,lw;	i1!" \ vt i-1 .iipiii'.1111,,, .ii     i"   ,"i
  are not formed during use of chlorine-free detergents, chlorine-containing or chlorine-
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                       .   DRAFT-DO NOT QUOTE OR CUE

 releasing detergents, and chlorine bleach during household bleaching operations. Although
 few results of testing of detergents for CDD/CDFs were reported, low levels of CDD/CDFs
 were reported only in a sample of a Swedish dichloroisocyanurate-containing detergent.
 CDD/CDFs were also detected in. a sample of a Swedish "soft soap," manufactured from
 tall oil.
       Sweden's Office of Nature Conservancy (1991) reported that the results of a
 preliminary study conducted at one household indicated that CDD/CDFs may be formed
 during use of dichloroisocyanurate-cbntaining dish  washing machine detergents. A more
 extensive main study was then conducted  using standardized food, dishes, cutlery, etc. and
 multiple runs. Testing of laundry washing, fabric bleaching, and actual testing of the
 CDD/CDF content of detergents was also performed.  The study examined:
 (1) hypochlorite- and dichloroisocyanurate-containing dish  washing machine detergents; (2)
 sodium hypochlorite-based bleach (4.4 percent NaOCI) in various combinations with and
 without laundry detergent; and (3)  sodium  hypochlorite-based bleach, used at a high
 enough concentration to effect bleaching of a pair  of imported blue jeans  CDD/CDFs were
 nondetected in either the chlorine-free detergent or the detergent with hypochlorite; 0.6-pg
 TEQ/g was detected in the detergent containing dichloroisocyanurate.  The results  of all
 dish and laundry washing machine tests showed very low  levels of CDD/CDFs, often
 nondetected values. There was no significant difference between the controls and test
 samples.  In fact, the control samples contained higher TEQ content  than some of the
 experimental samples.  The drain water from the dish washing machine tests contained
 < 1.0- to <3.0-pg TEQ/L (the water only control sample contained <2.8-pg TEQ/L).  The
 CDD/CDF content of the laundry  drain water samples ranged from <1.1-to <4.6-pg TEQ/L
 (tjie water only control sample contained <4.4-pg  TEQ/L).
       Thus, under the test conditions examined by Sweden's Office of Nature
 Conservancy (1991), CDD/CDFs are not formed during dish washing and  laundry washing
 nor during bleaching with hypochlorite-containing bleach.   No definitive reason could be
found to explain the difference in results between the preliminary study and the main study
for dish washing with dichloroisocyanurate-containing detergents.  The authors, of the study
suggested that differences in the foods used and the  prewashing procedures employed in
the two studies were the likely causes of the variation in the results.
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        Hagenmaier and Brunner {1993) also conducted a laundry study in Germany and
  ,,'"IN h "  '    , "    'i, "'!!,I,,1'  I •	•  :" , , ' " ,. ™ !,i"!  "•  , ' , ' ,!"°'i IN ,ii,iu! "  '•>' ' "'" 'J1" i, •' ,'. f ""',1' ' , •;, • »!;!' !l';"'	 ,i,;!i|lili!1 ': '"i'l1,     J „
 obtained results similar to those reported by Sweden's Office of Nature Conservancy
 (1991) main study. Hagenmaier and Brunner  (1993) used a popular detergent with bleach
 and one without bleach. The total volume of  laundry wastewater (approximately 85 to 90
 L) from the experiment with the bleach-containing detergent contained 390 ng of total
  '!.';•'.. ,    'i '.  •• i /Sis  :  /  ,  ''•  •..;•,.'  ' •; ','. • :'}:'":~i'"i	',>  r- \ ::: :-;i!' ;«! «l;i: .J'iiji'HA i.'ltoY',1,'.1'•'••  •      ';!
 CDD/CDF, while the bleach-free wastewater contained 460 ng.
        Rappe et al. (1990c) analyzed a sample of a Swedish commercial soft soap, as well
 as  a sample of tall oil and a sample of tall resin for CDD/CDF content.  Tall oil and tall resin,
 byproducts of the pulping industry, are the starting materials for the production of soft,
 liquid soap. Crude tall oil, collected after the Kraft pulping process, is distilled under
 reduced pressure at temperatures of up to 280-290°C, yielding tall  oil and tall resin. The
 measured TEQ content of the liquid soap was 0.447-ng TEQ/L.  PeCDDs were the dominant
;  *v ' "    "' '•"',;,' "''ill .'•'  "  • .'" "''i,	••	"i I  .'. ',:':",  '"'"; ivi";,'  !•'.'•", '' .*• / "!>  ,':.!'•	;'•'<" • .Jr™ .•'•'' ", .'   i;'  ;j
 congener group followed by HpCDDs,  HxCDDs,  PeCDFs, and OCDD with some tetra- CDFs
 and CDDs also present. The TEQ content of the tall oil (9.5 rig/kg)  and, tall resin (200
  •:•:.; i, I     '    	iXittiiJ  !,   •, " ,"  '' i,'1	 , t.'fK v  •                  J        I        •• I
 ng/kg) was significantly higher than the level found in the liquid  soap. The tall oil contained
  i •;'      i "' •'  i/iii'  ,«  ,   ,"•! :!'"  '"	!'" '                         I          " f,   ','
 primarily tetra- and penta- CDDs and CDFs, while the tall resin contained primarily HpCDDs,
                ii;.i,l"'!i!l!l ' » '  ' - '' "1|1,, • «• 'i i11' " • lu|i , • i                          5         I '  ' • :"
 HxCDDs, and  OCDD. Rappe et al.  (1990c) compared the congener patterns of the three
 samples and noted  that although the absolute values for the tetra- and penta- CDFs and
  : ,,'  „   '••       Vliiii'!! ;,|  ,, IN|1 ' '  • . , "n, :  • , 	 • „ ,• ,  , . , ,;,",|i,,'.,i , 	•,  •	 • 'ij'.r .IIMI'II,	,,i!i,M, :,, i  •	!;:,	'«,:, 	 - ,  i,
 CDDs differed bejween the tall oil/tall resin and liquid soap samples, the same congeners
 wete present  in the samples.  The congener patterns for the more chlorinated congeners
 were very similar. Table 8-31 presents the results reported by Rappe et al. (1990c).
       In 1987, 118-million liters of liquid household soaps were shipped  in the United
States (U.S. DOCf1990b); shipment quantity  data are not available for  liquid household
soap in the 1992 O.S.  Economic Census (UlS. DOC, 1996).  Because only one sample of
liquid soap has been analyzed  for CDD/CDF content (Rappe eit'aC 1990c), only a very
preliminary estimate of the annual release of CDD/CDF TEQ from liquid soap can be made.
  '•••'"'• ;';l    •'•  .'.•   i!jl!i -:-.'  •. •-'•:,'.i1:lt „"&• ''• -vi .;••• :vy--'!!":-i  i<.;.r^i.*-ivjnij-'(..';.''':;:»:,'' '«> •>  : ":'
If it is assumed that an average 118-million liters of liquid soap contain 0.447-ng TEQ/L,
then the resulting estimate is 0.05-g TEQ/yr.

8.4.4.  Textile  Manufacturing and Dry Cleaning
       As discussed in Section 8.4.1, CDD/CDFs have  been detected in nearly all sewage
sludges tested whether obtained from industrialized areas or rural areas.  To determine if

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                ' -        '      •  ' f •              -                •      '
  the textile fabric or fabric finishing processes could account for the observed CDD/CDFs,
  several studies were ponducted in Germany.  These studies/summarized in the following
  paragraphs, indicate that, although some finished textile products do contain detectable
  levels of CDD/CDFs and that these CDD/CDFs can be released from the textile during
  laundering or dry cleaning, textile finishing processes are typically not sources of CDD/CDF
  formation.  Rather, the use of CDD/CDF-containing dyes and pigments and the use in some
  countries of pentachlorophenol to treat unfinished cotton appear to be the sources of the
  detected CDD/CDFs.
        Horstmann et al. (1993b) analyzed the CDD/CDF content of eight different raw
  (unfinished) cotton cloths containing fiber from different countries arid fiye different white
 synthetic materials (acetate, viscose, bleached polyester, polyamide, and polyacrylic).  The
 maximum concentrations found in the textile fabrics were 30 ng/kg in the cotton products
 and 45 ng/kg in the synthetic materials. Also, a potton finishing scheme was developed
 that subjected one of the cotton materials to a series of 16 typical cotton finishing
 processes; one sample was analyzed following each step.  The fabric finishing processes
 showing the greatest effect on CDD/CDF concentration were the application of an
 indanthrene dye and the "wash and wear" finishing process, which together resulted in a
 CDD/CDF concentration of  about 100 ng/kg. Based on the concentrations found, the
 authors concluded that neither unfinished new fabrics nor common cotton finishing
 processes can explain the CDD/CDF levels found in laundry wastewater.
       Fuchs et  al. (1990} reported that dry cleaning solvent redistillation residues collected
 from 12 commercial and industrial dry cleaning operations contained considerable amounts
 of CDD/CDFs. The reported TEQ content ranged from 131 to 2,834 ng/kg with the
 dominant congeners always OCDD and the HpCDDs. Towara et al. (1992) demonstrated
 that neither the use of chlorine-free solvents nor variation of the dry cleaning process
 parameters lowered the CDD/CDF content of the residues.
      Umlauf et al. (1993) conducted a study to characterize the mass balance of
 CDD/CDFs in the dry cleaning process.  The soiled clothes (containing 16-pg total CDD/CDF
 per kg) accounted for 99.996 percent of the CDD/CDF input. Input from indoor air       '
 containing 0.194 pg/m3 accounted for the remainder (i.e., 0.004 percent). The dry
 cleaning process removed 82.435 percent of the CDD/CDF in the soiled clothing. Most of
the input CDD/CDF (82.264 percent) was found in the solvent distillation residues.  Air
                                       8"37                                April 1998

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                       .   DRAFT-DO NOT QUOTE OR CITE

 erriissions (at 6.041 pg/m3) accounted for 0.0008 percent of the total input, which is less
 than the input from indoor air. The fluff (at a concentration of 36 ng/kg) accounted for
 0.1697 percent, and water effluent (at a concentration of 0.07 pg/L) accounted for
 0.0000054 percent.
       Horstmann and McLachlan (1994a;  1994b; 1995) analyzed 35 new textile samples
 (primarily cotton products) obtained in Germany for CDD/CDFs.  Low levels were found in
 most cases (total CDD/CDF less than 50 ng/kg).  The dominant congeners found  were
 OCDD and the HpCDDs.  However, several colored T-shirts from a number of clothing
 producers had extremely high levels, with concentrations up to 290,000 ng/kg. Because
 the concentrations in identical T-shirts purchased at the same store varied by up to a factor
 of 20, the authors concluded that the source of CDD/CDFs is not a textile finishing process,
 because a process source would have resulted in a more consistent level of contamination.
 Klasmeier and McLachlan (1995) subsequently analyzed  68 new textile products  obtained
 in Germany for OCDD and OCDF.  Most samples had nondetectable levels (42 samples
 <60 ng/kg). Only four samples had levels  exceeding 500 ng/kg.
       Horstmann and McLachlan (1994a,-  1994b) reported finding two different  congener
 group patterns in the more contaminated of the 35 textile products. One pattern agreed
 well with the congener pattern for PCP reported b'y Hagenmaier and Brunner (1987), while
 the other pattern was similar to that reported by Remmers et al. (1992) for chloranil-based
 dyes. The authors hypothesize that the use of PCP to preserve cotton, particularly when it
 is randomly strewn on bales of cotton as a  preservative during sea transport, is the likely
 source of the high levels occasionally observed. As discussed in Section 8.3.8, the use of
 PCP for nonwood uses was prohibited in the United States in 1987. However, Horstmann
 and McLachlan (1994a) comment that PCP is still used in developing countries, especially
to preserve cotton during sea transport.
       Horstmann and McLachlan (1994a; 1994b)conducted additional  experiments that
demonstrated that the small percentage of clothing items with high CDD/CDF levels could
be responsible for the quantity of CDD/CDFs observed in household wastewater.  They
demonstrated that the CDD/CpFs can be gradually removed from the fabric during washing,
can be transferred to the skin, and subsequently transferred back to other textiles and then
  I"'.1" '   •    ... iiiiC  ;'  ''•'"•.':';: '!!".':.',»'<•' I'1 I,'!-.	,.' il; Mi';"'i !	'.''.•', v",r	,1. "IF I1,	."',!	•. ., iiiHMi f  ",. • • I    .
washed out, or can be transferred to other textiles during washing and then removed during
subsequent washings.
   ,„       '     .«!"•!" i  •    ."   •  ,   - / ' i  , ".I. ,h	,' ' ' •    ;  . :'i	-I ' 	  ' '	 ." „      ,

                                        8-38                                April 1998

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                                      April 1998

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                                     C "O
                                     ID 
-------
                             DRAFT-DO NOT QUOTE OR CITE
                                      . Ratio (median congener cone. / total CDD/CDF cone )
                                      0-1             0.2              0.3              0.4
        2,3,7,8-TCDD
      1,2,3,7,8-PeCDD
    1,2,3,4,7,8-HxCDD
    1,2,3,6,7,8-HxCDD
    1,2,3,7,8,9-HxCDD
  1,2,3,4,6,7,8-HpCDD
 1,2,3,4,6,7,8,9-OCDD
        2,3,7,8-TCDF
      1,2,3,7,8-PeCDF
      2,3,4,7,8-PeCDF
    1,2,3,4,7,8-HxCDF
    1,2,3,6,7,8-HxCDF
    1,2,3,7,8,9-HxCDF
    2,3,4,6,7,8-HxCDF
  1,2,3,4,6,7,8-HpCDF
  1,2,3,4,7,8,9-HpCDF
 1,2,3,4,6,7,8,9-OCDF
          Source: Uedicn eoncmntunu f
                                                                                                        0.5
                                       Ratio (median congener TEQ concVtotal TEQ cone )
                               0-1        0.2       0.3       0.4        0.5        0.6
                                                                                            0.7
                                                                                                      0.8
       2,3,7,8-TCDD
     1,2,3,7,8-PeCDD
  1,2,3,4,7,8-HxCDD
  1,2,3,6,7,8-HxCDD
  1,2,3 ,7,8,9-HxCDD
 1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
       2,3,7,8-TCDF
     1,2,3,7,8-PeCDF
     2,3,4,7,8-PeCDF
  1,2,3,4,7,8-HxCDF
  1,2,3,6,7,8-HxCDF
  1,2,3,7,8,9-HxCDF
  2,3,4,6,7,8-HxCDF
 1,2,3,4,6,7,8-HpCDF
 1 ^,3 ,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
         Source: Uadion con
                           from U.S. BPA (199O»); nondaucu «« eqa»l to 1/2 dM»ctio& «™t*
         Figure 8-1.  104-Mill Study Full Congener Analysis Results for Pulp
                                               8-41
                                                                                               April 1998

-------
:,, i"'
                                                  NOT QUOTE OR CITE
                                           Ratio (median congener cone. / total CDD/CDF cone.)
                                          O.I              0.2              0.3              O.4
                                                                                                              0.5
           2,3.7.8-TCDD
         1^,3.7,8-PeCDD'
      1,2,3.4.7,8-HxCDD
      1,2,3,6,7,8-HxCDP
      1,2.3,7,8,9-HxCpp
    1,2,3,4,6,7,S-HpCDD
    1 ,2.3.4,6.7.8,9-6CDI>
           2,3,7,8-fCDF
         1,2,3,7.8-PeCDF
         2,3.4,7.8-PcCDF
      1 A3 ,4.7,8-HxCDF
      lA3,6,7,S-HxCI>F
      1,2,3,7.8,9-HxCDF
      2,3.4,6,7,8-HxCDF
    lA3,4,6,7.S-HpCDF
    1.2,3,4,6.7,8,9-dCDF
             «~»«: M.<1.. «»n
                                      HPA F
      2,3,4,6,7.8-HxcbF
    l,2,3,4.6V7.8-HpCDF
    1,2.3,4.7.8,9-HpCDF
   1^^.4,6,7,8,9-OCDF
             «nn*:U«l>
                                   0.1
 Ratio (median congener TEQ concVtotal TEQ cone.)
*	.Pfg.	...i,,,.,,	 '..M,,,,	.,'	, .:,	M	.,	 &,S,	 , .   0.6  .
                                                                                                   O.7
                                                                                                             0.8
                            idoo« firen U.S. BPA (199O«); nondatMt* Mt •
                                                         l ta IB .Uuctim limit.
           Rgure 8-2.   104-Mill Study Full Congener Analysis  Results for Sludge
                                                    8-42
                                                                                                      April 1998

-------
                             DRAFT-DO NOT QUOTE OR CITE
                                        Ratio (median congener cone./totnl CDJD/CDF cone.)
                                0-1        0-2        0.3        0:4        0.5    '    0.6
         2,3,7,S-XCDr>
    1.2,3 ,.4.7,8-HxCDD
    1,2,3,6.7.8-HxCDD
    1.2,3.7.8 ,9-HbcCr>r>
  1,2.3,4,6,7,8-HpCDD
  l,2.3,4,6.7.8,9-OCI>r>
         2,3,7.8-TCDF
      1 ,2.3 ,7.8-PeCDF
      2.3.4,7.8-P-eCDF
    1 .2.3 ,4,7,8-HxCDF
    1 ^2.3 ,6,7.8-HxCDF
    1^,3.7,8.9-HxCDF
    2,3.4,6.7,8-HxCDF
  1,2,3.4,6,7,8-HpCDF
       .4.7.8.9-HpCDF
                                      Ratio (median congener TEQ concVtotal TEQ cone.)
                                           0.2         0.3         0.4        0.5         0.6
       2,3,7,8-TCDD
     1,2,3,7,8-PeCDD
  1^^,4,7,8-HxCDD
  1^,3,6,7,8-HxCDD
  1^,3,7,8,9-HxCDD
 1,2,3,4,6,7,8-HpCDD
1^,3,4,6,7,8,9-:OCDD
       23,7,8-TCDF
     1,2,3,7,8-PeCDF
     2,3,4,7,8-PeCDF
  1,2,3,4,7,8-HxCDF
  1^,3,6,7,8-HxCDF
  1^,3,7,8,9-HxCDF
  2,3,4,6,7,8-HxCDF
 li2,3,4,6,7,8-HpCDF
 1,2,3,4,7,8,9-HpCDF
1^,3,4,6,7,8,9-OCDF
         Scarce: Mediin concontmioni from U.S. EPA (1990m); nondetccu let equal to 1/2. dctecnra limit.
       Figure 8-3;  104-Mili Study Full Congener Analysis Results for Effluent
                                              8-43
                                                                                             April 1998

-------
              DRAFT-DO NOT QUOTE OR CITE
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                          8-44
                                                        April 1998

-------
                            DRAFTr-DO NOT QUOTE OR CUE
        Table 8-3.      Summary of Bleached Chemical Pulp and Paper Mill Discharges
                       of 2,3,7,8-TCDD and 2,3,7,8-TCDF
Matrix
Effluent
Sludge11
Pulp
Congener
2,3,7,8-TCDD
2,3,7,8-TCDF
TEQ
2,3,7,8-TCDD
2,3,7,8-TCDF
TEQ
2,3,7,8-TCDD
2,3,7,8-TCDF
TEQ
1988
Discharge3
(g/year)
201
1,550
356
210
1 ,320
343
262
2,430
505
1992
Discharge11
(g/year)
22
99
32
33
118
45
24
124
36
1992
Discharge0
(g/year)
71
341
105
NR
NR
100
NR
NR
150
1993
Discharge15
(g/year)
19
76
27
24
114
35
22
106
33
1994
Discharge13
(g/year)
14.6
49.0
19.5
18.9
95.2
28.4
16.2
78.8
24 1
 NR = Not reported.
                                                      V

 a   104-Mill Study (U.S. EPA, 1990a):  Total discharge rate of congener or TEQ (based only on
    2,3,7,8-TCDD and 2,3,7,8-TCDF concentration) summed across all 104 mills.
    NCASJ 1992 Survey (NCASI, 1993), 1993 Update (Gillespie, 1994), and 1994 Update (GiUespie.
    1995):  Total discharge rate of congener or TEQ (based only on 2,3,7,8-TCDD and 2,3,7,8-
    TCDF concentration) summed across all 104 mills. The daily discharge rates reported in NCASI
    (1993), Gillespie (1994), and Gillespie (1995) were multiplied by a factor of 350 days/yr to   *
    obtain estimates of annual discharge rates.

c   The discharge in effluent was estimated in U.S. EPA (1993d) for January 1, 1993.  The TEQ
    discharges in s|udge and pulp .were estimated by multiplying the 1988 discharge estimates for
    each by the  ratio of the 1993 and 1988 effluent discharge estimates (i.e., the estimate of the
    reduction in  1988 discharges achieved by pollution prevention measures taken by the industry
    between 1988 and 1993).

    Approximately 20.5  percent of the sludge generated in 1990 were incinerated. The remaining
    79.5 percent were predominantly landfilled (56.5 percent) or placed in surface impoundments
    (18.1 percent); 4.1 percent were land-applied directly or as compost, and 0.3 percent were
    distributed/marketed (U.S. EPA,  1993e).

g/year = grams  per year
                              T        ' .              ....
Sources: Gillespie (1995); Gillespie (1994); NCASI (1993); U.S. EPA (1993d); U.S. EPA (1993e).
                                          8-45
                                                                                April 1998

-------
                            DRAFT-DO NOT QUOTE OR CITE
                 Table 8-4. CDD/CDF Concentrations in Graphite Electrode Sludge
                                  •from Chlorine Production

Congener/Congener Group
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD*
TotaJ 2,3,7,8-CDF*
Total TEQ*
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF*
Sludge 1
teg/kg)
ND (0.006)
ND (0.007)
ND (0.018)
ND (0.012)
ND (0.016)
0.095
0.92
26
25
12
32
7
1.3
0.87
9.1
8.1
31
1.015
152.37
13.5
ND (0.006)
ND (0.070)
ND (0.046)
0.22
0.92
64
75
68
24
31
263.14
Sludge 2
Cug/kg)
ND (0.009)
ND (0.009)
ND (0.026)
ND(0.016)
ND (0.022)
0.21
2.0
56
55
25
71
16
2.8
1.9
19
19
76
2.21
341.7
30.2
ND (0.009)
ND (0.009)
ND (0.064)
0.48
2
150
240
140
53
76
661.48
Sludge 3
Ug/kg)
ND (0.009)
ND (0.009)
ND (0.029)
ND (0.019)
ND (0.025)
0.25
2.2
57
56
24
73
15
2.6
2.0
19
20
71
2.45
339.6
30.2
ND (0.009)
ND (0.009)
ND (0.074)
0.56
2.2
140
240
140
54
71
647.76
Sludge 4
Ug/kg)
ND
ND (0.033)
ND (0.49)
ND (0.053)
ND (1.2)
0.055
0.65
52
55
27
44
12
1.7
1.3
15
14
81
0.705
303
27.7
NR
NR
NR
NR
0.65
NR
NR
NR
NR
81
NR
ND s Nondetected (values in parentheses are the reported detection limits)
NR =3 Not reported
*  ii Calculated assuming not detected values were zero.
M9/kg = micrograms per kilogram
   ;::!; ^ •     ' ••':-''.li-:ffl.;l''''.1.^i;;.'|;.'f? '';'.i;"y;?  '.;'
Spurces:  Rappe et at  (1991); Rappe (1993)
                                           8-46
                                                                                  April 1998

-------
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                             8-47
                                                                 April 1998

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                         8-50
                                                    April 1998

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                                 DRAFT-DO NOT QUOTE OR CITE
                        Table 8-8. Historical CDD/CDF Concentrations in Pentachlorophenol-Na


Congener/Congener Group

2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1 ,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1 ,2,3,4,6,7,8-HpCDD
OCDD .
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF
1 ,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CpD*
Total 2,3,7,8-CDF»
Total TEQ*
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF*
PCP-Na
(Ref. A)
(1969)
teg/kg)
	
- -
•' -
-
—
__
3,600
	
-
— ,
^_

„
	
—
— .
. -
	
-
-
	
—
17,000
9,600
3,600
- , -
-
' " —
—
- •
-.
PCP-Na
(Ref. B)
(1973)
teg/kg)
	
-
-
-
-

._ ,
	
• —
- '
m

	

—
• -
-
_ .
~
—
140
40
,140
1,600
4,000
ND (20)
60
1,400
4,300
4,300
15,980
PCP-Na
(Ref. C)
(1973)
teg/kg)
	
• -
T-
. -'
-

_
..
—
• —
. 	

•

~ -
—
-
~ . .
—
—
50
ND(30)
3,400
38,000
110,000
ND (20)
40
11,000
47,000
26,500
235,990
PCP-Na
(Ref. D)
(1987)
fcg/kg)
0.23
18.2
- 28.3
2,034
282
9,100
41,600
1.8
8.2
6.6
48
- 69
ND (1)
87
699
675
37,200
53,063
38,795
452
27
213
3,900
18,500
41,600
82
137
3,000
13,200
37,200
117,859
PCP-Na
{Ref. E)
(1987)
teg/kg)
0.51
3.2
13.3
53.0
19.0
3 800
32,400
0.79
1.9
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197
36 -
4,250
35,289
4,499
79.5
52
31
230
5,800
32,400
12
27
90
860
4,250
43,752
PCP-Na
(Ref. F)
(1992)
(^g/kg)
0.076
18.7
96
4,410
328 -
1 7>? Ann
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9,650
2,080
114,600
1,059,253
126,492
3,374
3.6
142.7
9,694
260,200
879,000
,10.1
88.4
9,082.3
75,930
114,600
1,348,751
PCP-Na
(Ref. G)
(1980s)

ND (1.4)
/ 28.3 ,
ND(6.1)
4,050
ND (1.4)
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149
319
324
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154
36,000 '
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43,841
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1.9
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•: 81,000
1200
6400
49,000
91,000
.36,000
378,742
ND = Not detected; value in parentheses is the detection limit.
— = Not reported.
*  = Calculated assuming not detected values are zero.
A/g/kg = micrograms per kilogram.

Sources:
Ref. A: Firestone et al. (1972); mean of two samples of PCP-Na obtained in the United States between 1967 and 1969.
Ref. B: Buser and Bosshardt (1976); mean of five samples of "low" CDD/CDF content PCP-Na received from Swiss commercial
    sources.                                      •
Ref. C: Buser and Bosshardt (1976); sample of "high" CDD/CDF\content PCP-Na received.from a Swiss commercial source.
Ref. D: Hagenmaier and Brunner (1987); sample of Dowicide-G purchased from.Fluka; sample obtained in Germany.
Ref. E: Hagenmaier and Brunner (1987);  sample of Preventol PN (Bayer AG); sample obtained in Germany.
Ref. F: Santl et al. (1994c); 1992 sample of PCP-Na from Prolabo, France.
Ref. G: Palmer et al. (1988); sample of a PCP-Na formulation collected from a closed sawmill in California in the late 1980s.
                                                   8-51
                                                                                                 April 1998

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                          DRAFT-DO NOT QUOTE OR CITE
      Table 8-13. Reported CDD/CDF Concentrations in Wastes from PVC Manufacture
	 ! — —
Congener/Congener Group
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8-HxCDF78

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpGDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF '
Total HpCDF
Total OCDF
I Total CDD/CDF
F024 Waste
fag/kg)
0.37
0.14
0.30
0.14
0.11
4.20
• , 1 5.00
0.91
9.5
1.6
110
24.0
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3.1
250
51.0
390

20,3
849.6
19.98
3.1
3.6
1.3
5.0
15.0
15.0
65.0
300
450
390
1,248
K019Waste
(//g/kg)
260
890
260
330
620
920
1 ,060
680
975
1 ,050
10,100
9,760
21,800
930
13,400
1,340
43,500

4,340
103,535
5,928
1,230
3,540
3,950
1,270
1 ,060
20,600
45,300
63,700
16,600
43,500
200,750
K020 Waste
f^g/kg)
0.06
0.05
0.08
0.06
0.07
0.89
3.00
6.44
1.80
0.58
11.0
2.4
1 .3
0.89
38.0
6.0
650

4.21
712.4
3.19
1.9
1.7
NR
1.7
3.0
6.0
11.0
27.0
58.0
650
760.3
NR - Congener group concentration reported in, source is not consistent with reported
      congener concentrations.     ,     .               , '                ,
/^g/kg = micrograms per kilogram

Source: Stringer et al. (1995)
                                      8-57
                                                                        April! 998

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                                              8-59
                                                                                      April 1998

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                           :    CRAFT-DO NOT QUOTE OR CITE



                      Jable 8-16. CDD/CDF Concentrations in Printing Inks (Germany)


Congener/Congener Group
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ »
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
Rotogravure
(2-color)
(ng/kg)
ND (1)
8
19
325
155
2,770
5,810
2.5
ND (2)
ND (2)
4
ND{3)
ND{3)
ND (3)
40
ND (4)
129
9,087
175.5
90.1
4
58
2,679
5,630
5,810
5.5
13
29
64
129
14,422
Rotogravure
(4-color)
(ng/kg)
ND (1.5)
ND (4)
ND (5)
310
105
1,630
2,350
14
ND (4)
ND (4)
7
ND (5)
. ND (5)
ND(5)
14
ND (7)
ND (10)
4,395
35
66.2
ND (2)
145
2,485
3,460
2,350
28
ND (4)
45
14
ND (10)
8,527
Offset
(4-color)
(ng/kg)
ND (2)
15
16
82
42
540
890
7
ND(4)
ND (4)
27
ND(5)
ND (5)
ND(5)
315
11
960
1,585
1320
38.2
77
35
660
1,100
890
90
340
95
566
960
4,813
Offset
(4-color)
(ng/kg)
ND (2)
6
11
21
14
240
230
7
ND (3)
ND (3)
35
ND (5)
ND (5)
ND (5)
42
ND (6)
165
522
249
17.5
38
25
246
445
230
35
110
94
63
165
1,451
ND =   Nondetected; value in parenthesis is the detection limit.
—   •*   Not reported.
*   =   Calculation of JEQ values assumes npndetected congeners are present at half of their detection limits.
ng/kg = nanograms per kilogram.
                   •i;):'  	 _ .    ;;  :   ' "i '   ,   •  l * :,..••  •   ,,,."',   ;-_ ,,• ,  _«; "  '.•.,-•  |..
Source: Santi et al. (1994c).
                                               8-60
                                                                                         April 1998

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                             DRAFT-DO NOT QUOTE OR CITE
          Table 8-17.  Chemicals Requiring TSCA Section 4 Testing Under the Dioxin/Furan Rule
 CAS No.
  Currently Manufactured or imported as of June 5, 1987a

   Chemical Name
 79-94-7
 118-75-2
 118-79-6
 120-83-2
 1163-19-5
 4162-45-2
 21850-44-2
 25327-89-3
 32534-81-9
 32536-52-0
 37853-59-1
 55205-38-4
  Tetrabromobisphenol-A
  2,3,5,6-Tetrachloro-2,5-cyclohexadiene-1,4-dione
  2,4,6-Tribromophenol
  2,4-Dichlorophenol
  Decabromodiphenyloxide
  Tetrabromobisphenol-A-bisethoxylate
  aTetrabromobisphenol-A-bis-2,3-dibromopropylether
  Allyl ether of tetrabromobisphenol-A
  Pentabromodiphenyloxide
  Octabromodiphenyloxide
  1,2-Bis{tribromophenoxy)-ethane
  aTetrabromobisphenol-A-diacrylate	•
CAS No.
Not Currently Manufactured or Imported as of June 5, 1987b

  Chemical Name
79-95-8
87-10-5
87-65-0
95-77-2
95-95-4
99-28-5
120-36-5
320-72-9
488-47-1
576-24-9
583-78r8
608-71-9
615-58-7
933-75-5
1940-42-7
2577-72-2
3772-94-9
37853-61-5
  Tetrachlorobisphenol-A
  3,4',5-Tribromosalicylanide
  2,6-Dichlorophenol
  3,4-Dichlorophenol
  2,4,5-Trichlorophenol
  2,6-Dibromo-4-nitrophenol
  2[2,4-(Dichlorophenoxy)]-propanoic acid
  3,5-Dichlorosalicyclic acid
  Tetrabromocatechol
  2,3-Dichlorophenol
  2,5-Dichlorophenol
  Pentabromophenol                    "
  2,4-Dibromophenol
  2,3,6-Trichlorophenol
  4-Bromo-2,5-dichlorophenol
  3,5-Dibromosalicylanide
  Pentachlorophenyl laurate
  Bismethylether of tetrabromobisphenol-A
  Alkylamine tetrachlorophenate
  Tetrabromobisphenol-B
  Tetrabromobisphenol-A-bis-2,3-dibromopropylether and tetrabromobisphenol-A-diacrylate are no longer
  manufactured in or imported into the United States (Cash, 1993).

  As of August 5, 1995, neither manufacture nor importation of any of these chemicals had resumed in the
  United States (Holderman, 1995).
                                            8-61
                                                                                      April 1998

-------
                             DRAFT-DO NOT QUOTE OR CITE
              Table 8-18.  Congeners and Limits of Quantitation (LOQ) for Which
                        Quantitation is Required Under the Dioxin/Furan
                             test Ru|e and Pesticide Data Call-In
Chlorinated Dioxins
and Furans
2,3,7,8-TCDD
1, 2,3,7, 8-PeCDD
1 ,2,3,4,7,8-HxCDD
1 ,2,3,6,7,8-HxCDD
1 ,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1 ,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1 ,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
Brominated Dioxins
and Furans
2,3,7,8-TBDD
1 ,2,3,7,8-PeBDD
1 ,2,3,4,7,8-HxBDD
1,2,3,6,7,8-HxBDD
1,2,3,7,8,9-HxBDD
1 ,2,3,4,6,7,8-HpBDD
2,3,7,8-TBDF
1,2,3,7,8-PeBDF
2,3,4,7,8-PeBDF
1,2,3,4,7,8-HxBDF
1,2,3,6,7,8-HxBDF
1,2,3,7,8,9-HxBDF
2,3,4,6,7,8-HxBDF
1,2,3,4,6,7,8-HpBDF
1,2,3,4,7,8,9-HpBDF
LOQ
(/^g/kg)
0.1
0.5
2.5
2.5
2'.5
100
1
5
5
25
25
25
25
1 ,000
1 ,000
fig/kg » microgram per kilogram.
                                                      .'"'I	I'.; V,1" ..(•;'.
                                                       "y.'..;;t'f' '.. V   ,'-
                                                                                   April 1998
                                                       :,iT L"i!'i,t •,>!:,•. liJ',1'1  ,i! '.•

-------
                   DRAFT-DO NOT QUOTE OR CITE
Table 8-19.   Precursor Chemicals Subject to Reporting
             Requirements Under TSCA Section 8(a)
         CAS No.
               Chemical Name
         85-22-3
         87-61-6
         87-84-3
         89-61-2
         89-64-5
         89-69-0
         92-04-6
         97-74-6
         94-81-5
         95-50-1
         95-56-7
         95-57-8
         95-88-5
         95-94-3
         95-50-7
         99-30-9
         99-54-7
        106-37-6
        106-46-7
        108-70-3
        108-86-1
        108-90-7
        117-18-0
        120-82-1
        348-51-6
        350-30-1
        615-67-8
        626-39-1
        827-94-1
 Pentabromoethylbenzene
 1,2,3-Trichlorobenzene
 1,2,3,4,5-Pentabromo-6 chlorocyclohexane
 1,4-Dichloro-2-nitrobenzene
 4-Chloro-2-nitrophenol
 2,4,5-Trichloronitrobenzene
 2-Chloro-4-phenylphenol
 4-Chloro-o-toloxy acetic acid
 4-{2-Methyl-4-chlorophenoxy) butyric acid
 o-Dichlorobenzene
 o-Bromophenol
 o-Chlorophenol
 4-Chlororesorcinbl
 1,2,4,5-Tetrachlorobenzene
 5-Chlbro-2,4-dimethoxyaniline
 2,6-Dichloro-4-nitroaniline
 1,2-Dichloro-4-nitrobenze,ne
 Dibromobenzene
 p-Dichlorobenzene
 1,3,5-Trichlorobenzene
 Bromobenzene
 Chlorobenzene
 1,2,4,5-Tetrachloro-3-nitrobenzene
 1,2,4-TrichIorobenzene
o-Chlorofluorobenzene     ;
3-Chloro-4-fluorohitrobenzehe
Chlorohydroquinone
 1,3,5-Tribromobenzene
2,6-Dibromo-4-nitroaniline
                                8-63
                                                                    April 1998

-------
         Table 8-20.
                                    DRAFT-DO NOT QUOTE OR CITE
Results of Analytical Testing for Dioxins and Furans in the
Chemicals Tested To-Date Under Section 4 of the Dioxin/Furan Test Rule
CAS
Number
79-94-7
118-75-2
118-79-6
120-83-2
1163-19-5

25327-89-3
32536-52-0

378-53-59-1
32S34-81-9

4162-45-2
«
Chemical Name
Tetrabrornobisphenol-A
2,3,5,6-Tetrachloro-2,5-
cyclohexadiene-
1,4-dione (chloranil)
2,4.6-Tribromophenol
2.4-Diohlorophenol
Decabromodiphenyl oxide

Ally! ether of
tetrabromobisphenol-A • ,
Octabromodiphenyl oxide

1 ,2-Bis(tribromo-phenoxy(-
ethane
Pentabromodiphenyl oxide

Tetrabromobisphenol-A-
bisethoxylate
No. of
Chemical
Companies
That Submitted
Data
3
4
1
1
3

1
3

1
2

1
No. of
Positive
Studies
0
4
0
0
3

0
3

1
2

0
Congeners Detected
(detection range: #g/kg)
NDa
See Table 8-21
NDa
NDa
2,3,7,8-PeBDD (ND-0.1)
1 ,2,3,4,7,8/1 ,2,3,6,7,8-HxBDD (ND-0.5)
1 ,2,3,7,8,9-HxBDD (ND-O.76)
1,2,3,7,8-PeBDF (ND-0.7)
1 ,2,3,4,7,8/1 ,2,3,6,7,8-HxBDF (ND-0.8)
1 ,2,3,4,6,7,8-HpBDF (17-186)
NDa
2,3,7,8-TBDD (ND-0.71)
1, 2,3,7,8-PeBDD (ND-0.1)
2,3,7,8-TBDF(ND-12.6)
1,2,3,7,8-PeBDF (ND-6.3)
2,3,4,7,8-PeBDF (ND-83.1)
1 ,2,3,4,7,8/1 ,2,3,6,7,8-HxBDF (ND-67.8)
1,2,3,7,8,9-HxBDF (ND-56.0)
1,2,3,4,6,7,8-HpBDF (ND-330)
2,3,7,8-TBDF (ND-0.04)
1 ,2,3,4,7,8/1 ,2,3,6,7,8-HxBDF (ND-0.03)
1,2,3,4,6,7,8-HpBDF (ND-0.33)
1, 2,3,7,8-PeBDD (ND-5.9)
1 ,2,3,4,7,8/1 ,2,3,6,7,8-HxBDD (ND-6.8)
1 ,2,3,4,7,8/1 ,2,3,6,7,8-HxBDD (ND-6.8)
1,2,3,7,8,9-HxBDD (ND-0.02)
2,3,7,8-TBDF(ND-3.1)
1,2,3,7,8-PeBDF (0.7-10.2)
2,3,4,7,8-PeBDF (0.1-2.9)
1 ,2,3,4,7,8/1 ,2,3,6,7,8-HxBDF (1 5.6-61 .2)
1,2,3,4,6,7,8-HpBDF (0.7-3.0)
ND"
•  No 2,3,7,8-substituted dipxins and furans detected above the Test Rule target limits of quantitation (LOO). (See Table 8-18.)
b  Third study is currently undergoing EPA review.
0  Study Is currently undergoing EPA review.
pg/kg - micrograms per kilogram
Source: Holderman and Cramer (1995).
                                                    8-64
                                                                                               April 1998

-------
                                DRAFT-DO NOT QUOTE OR CITE


                    Table 8-21.  CDDs and CDFs in Chloranil and Carbazole Violet
                    Samples Analyzed Pursuant to  the EPA Dioxin/Furan Test Rule
Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1 ,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
TOTAL TEQ*

Importer
nd (1)
nd{2)
nd (3)
nd{3)
nd (1)
110
240,000
nd(1)
nd(1)
nd(1)
35
nd (5)
6
nd (5)
33
nd (15)
18,000
263 	
Concentration fag/kg) in Chloranil
Importer
2
nd (1)
nd{2)
nd'(10)
75
48
8,200
180,000
nd (2)
ndd)
ndd)
nd (860)
nd (860)
nd (680)
nd (680)
240,000
nd(100)
200,000
2,874
Importer
3
nd (2)
nd (5)
nd (5)
nd (5)
nd (5)
390
760,000
nd(1)
nd (3)
nd (3)
nd (4)
nd (4)
nd (4)
nd (4)
36
ndd 5)
50,000
814'
Importer
4
nd (2)
'nd (6)
nd (3)
.6
9
2,300
71,000
nd (2)
nd(5)
nd (5)
5,600
nd (600)
nd (600)
nd (600)
230,000
nd (400)
110,000
3,065
Concentration
U/g/kg) in ,
Carbazole
Violet
nd (6.8)
nd (0.5)
nd (1.2)
nd (1.2)
nd (1.2)
28
1 ,600
nd(1.6)
nd (0.9)
nd (0.9)
nd (20)
nd (20)
nd (20)
nd (20)
1 5,000
nd (20)
59,000
211
Source: Remmers et al. (1992).

nd = nondetected; minimum limit of detection shown in
fj.g/kg = micrograms per kilogram.

* = Calculated assuming not detected values are zero.
parenthesis.
                                             8-65
                                                                                    April 1998

-------
       2,3,7.8-TCDD
     1,2,3,7,8-PcCDD
   1.2,3.4,7,S-HxCDr>
  1,2,3,7,8,9-HxCDD
 1 ,2,3,4,6,7,8-HpCDp
I,2,3,4,6,7,S,9-OCI>I>
        2,3,7,8-TCDF
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     2,3,4,7,8-PeCDF
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   1,2,3,6,7,8-HxCDF
   1^,3,7,8.9-HxCDF
  2,3,4,6.7.8-HxCDF
 1,2,3,4,6.7,8-HpCpF
 1.2,3,4,7.8»9-Hi>CDF
1,2,3,4,^,7.8.9-OCDF
                                DRAFT-DO NOT QUOTE OR CITE
                                     Ratio (congener concentration / total CDD/CDF concentration)
                                   0.1        '  O.2;,^ [,.',,.." Ol.3i '/  ,  i  .."O.4  „ '  ,    O.S  "        O.6
O.7
                       Ratio (congener group concentration / total CDD/CDF concentration)
                       '   '   '  '  6=2'; '!	'   0.3             Q.4., ."  .:    "	0,5
0.7
        d Ml data tffotui m Table 1-7; aea&aecu to. equal to
                  Figure 8-4. Congener and Congener Group Profiles for Technical PCP
                   'jiiii    '.   '  i    i1  '.'. "•  , '.-'   '• •  .:   , '• ','!' '•   ' ^•'\V!.i"l '/'' .".' "'•'::' f':"
                   •^   •    •   •   •   •.,•••	8-66
                                                                                                   April 1998

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                                          8-73
                                                                                    April 1998

-------
                                   DRAFT-DO NOT QUOTE OR CITE
                              Table 8-24.  Summary of Results for CDDs and CDFs in

                                    Technical 2,4-D and 2,4-D Ester Herbicides
Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
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OCDD
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2,3,4.6,7,8-HxCDF
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OCDF
EPA LOQa
(#g/kg)
0.1
0.5
2.5
2.5
2.5
100
—
1
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25
25
25
1000
1000
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Total
Number of
Technicals
8 '
8
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8
8
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8
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LOQ
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0
0
0
	
0
0
0
0
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Maximum
Concentration
0/g/kg)
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2.6
0.81
0.77
0.68
1.5
«
0.27
0.62
0.73
1.6
1.2
1.4
1.1
8.3
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Average
Concentration
(Aig/kg)
0.06
0.78
0.31
0.39
0.24
0.21
.
0.07
0.38
0.07
0.36
0.11
0.16
0.14
2.17
0.18

5.60 (0 70 TEQ)
Source:  U.S. EPA Office of Pesticide Program file



a   Limit of quantitation required by EPA in the Data Call-In.



    Average of the mean results for multiple analyses of four technical 2,4-D and/or 2,4-D ester products for which

    detectable CDD/CDF congener concentrations less than the LOQs were quantified; not detected values were

    assumed to be zero.
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fig/kg *•  mterograrns per kilogram.
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                                                   8-74
                                                                                              April 1998

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                               Ratio (mean congener cone. / mean total 2378-CDD/CDF cone.)
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1A3,4,6,7,8,9-OCDF
         Source: Bued on mean concentrations rcDoned in Table 8-24; nondetccts set equal to zero.
                   Figure 8-5.  Congener Profile for 2,4-D (salts arid esters)
                                           8-76
                                                                                        April 1998

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                              DRAFT-DO NOT QUOTE OR CITE
              Table 8-27.  Mean CDD/CDF Measurements in Effluents from Nine U.S. POTWs



Congener/Congener
Group





2,3,7,8-TCDD
1.2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF


b
No.
Detections/
No. Samples




0/30
0/30
0/30
0/30
0/30
3/30
13/30
1/27
1/30
1/30
1/30
1/30
1/30
1/30
2/30
0/30
1/30



4/27
0/27
1/30
3/30
13/30
2/30
1/30
1/30
2/30
1/30



Range of
Detection
Limits





0.31 - 8.8
0.45 - 1 5
0.43 - 9.8
0.81 - 10
0.42 - 9.7
0.75- 18
6.2 - 57
0.74 - 4.4
0.64 - 9.4
0.61 - 14
0.25 - 6.8
0.23 - 6.8
0.57- 10
0.25 - 7.9
0.36 - 6.9
0.19-11
0.86 - 28



1.2-8.8
0.62 - 200
0.84 - 1 1
0.75-18
6.2 - 57
0.39 - 6.8
0.64 - 25
0.93- 17
0.36- 19
0.86 - 28

Range of Detected
Concentrations
{POTW mean basis)

Minimu
m
Detects
d
Cone.
(pg/L)
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd
nd

Maximum
Detected
Cone.
(pg/L)


nd
nd
nd
nd
nd
5.0
99.75
1.3
2.0
2.8
2.4
1.5
2.0
nd
4.6
nd
3.2
99.75
16.6
2.32
9.7
nd
1.7
8.4
99.75
25.0
20.0
13.0
4.6
3.2
99.75


Overall Means*

Mean
Cone.
(ND = 0)
(pg/L)


0.00
0.00
0.00
0.00
0.00
1.06
29.51
.0.14
0.22
0.31
0.27
0.17
0.22
0.00
0.68
0.00
0.36
30.57
2.37
0.29
1.23
0.00
0.19
1.83
29.51
6.61
2.22
1.44
0.68
0.36
42.00

Mean
Cone.
(ND = 1/2D
L)
(pg/L)

0.98
1.32
1.38
1.42
1.31
3.61
37.95
0.98
1.58
1.68
1.22
0.97
1.72
0.93
1.83
1.18
3.40
47.98
15.49
3.66
2.61
6.27
1.93
4.77
37.95
7.70
4.72
3.43
2.41
3.40
71.96
nd = not detected.
* =» The "overall means" are the means of the individual POTW mean concentrations.
pg/L = picograms per liter.

Source:  California Regional Water Quality Control Board (1996).
                                             8-78
                                                                                     April 1998

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                                     8-79
                                                                             April 1998

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                        DRAFT-DO NOT QUOTE OR CITE
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                                           8-80
                                                                                             April 1998

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                              DRAFT-DO NOT QUOTE OR CITE
        2,3,7,8-TCDD
   1,2,3,4,7,8-HxCDD
   1,2,3,6,7,8-HxCDD
   1,2,3,7,8,9-HxCDD
 l,2,3,4,6,7,8-HpCDI>
 1.2,3,4,6,7,8,9-OCDD
        2,3,7,8-TCDF
      1,2,3,7,8-PeCDF
      2,3,4,7,8-PeCDF
   1,2,3,4,7,8-HxCpF
   1,2,3,6,7,8-HxCDF
   I ,2,3,7,8,9-HxCDF
   2,3,4,6,7,8-HxCDF
 1,2,3,4,6,7.8-HpCDF
 1^,3.4,7.8,9-HpCDF
      ,4,6,7.8.9-OCDF
                               o.i,
                Ratio (mean congener cone. / total 2378-CDD/CDF cone.)
                  0-2	0-3   _   0.4      . 0.5      0.6       O.7
L
                                                                                                  O.8
                                                                                                   I
                                                                                                           O.9
                                      Ratio (mean congener cone. / total 2378-CDD/CDF cone.)
                               0-1	0.2       0.3      0.4       0.5      O.6       O.7
                                                                                                 0.8
                                                                                                           0.9
        2,3,7,8-TCDD
     1^,3,7,8-PcCDD
   1^,3,4,7,8-HxCDD
   1,2,3,6,7,8-HxCDD
   1,2,3,7,8,9-HxCDD
 1,2,3,4,6,7,8-HpCDD
1 ^,3,4,6,7,8,9-OCDD
        2,3,7,8-TCDF
     1^,3,7,8-PeCDF
     2,3,4,7,8-PeCDF
   1,2,3,4,7,8-HxCDF
   1 ^,3,6,7,8-HxCDF
   1^,3,7,8,9-HxCDF
   2,3,4,6,7,8-HxCDF,
 1,2,3 ,4,6,7,8-HpCDF
 1,2,3,4,7,8,9-HpCDF
1,2,3 ,4,6,7,8,9-OCDF
        Somca: On«a«tBl. (1995),
                         Figure 8-6.  Congener Profiles for Sewage Sludge
                                                8-81
                                                                                                  April 1998

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                               DRAFT-DO NOT QUOTE OR CITE
         Table 8-30.  Quantity of Sewage Sludge Disposed Annually by Primary, Secondary,
                        or Advanced treatment POTWs and Potential Dioxin TEQ Releases
Use/Disposal Practice
Land Application
Distribution and Marketing
Surface Disposal Site/Other
Sewage Sludge Landfill
Co-Disposal Landfills8
Sludge Incinerators and Co-
Incinerators6
Ocean Disposal
TOTAL
Volume Disposed (thousands
of dry metric tons/year)
1,714
71
396
157
1,819
865
(336)d
5,357
Percent of
Total
Volume
32.0e
1.3
7.4
2.9
33.9
16.1
(6.3)d
100.0
Potential Dioxin
Release0
{g of TEQ/yr)
85.7
3.6
19.8
7.8
91.0
(f)
(0)d
207 9
' Landfills used for disposal of sewage sludge and solid waste residuals.
c     Potential dioxin TEQ release for nonincinerated sludges was estimated by multiplying the sludge volume
      generated {i.e., column 2| by the average of the median dioxin TEQ concentrations in sludge reported by
      Rubin and White (1992) (i.e., 50'i4-ng/kg dry weight) and Green'et' al. (1995) and Cramer et al  (1995)
      (i.e., 49.1-ng TEO/kg).
d     The Ocean Dumping Ban Act of  1988 generally prohibited the dumping of sewage sludge into the ocean
      after December 31, 1991.  Ocean dumping of sewage sludge ended in June 1992 (Federal Register,
      1993b).  The current method of  disposal of the 336,000 metric tons of sewage sludge that were
      disposed in the oceans; inij 9881 has not been determined.
8     includes 21.9 percent applied to  agricultural land, 2.8 percent applied as compost, 0.6 percent applied to
      forestry land, 3.1 percent applied to "public contact" land, 1.2 percent applied to reclamation sites, and
      2.4 percent applied in undefined  settings.
'      ^ee Section 3-6,;5 for estim£ltes $CPD/9DF.rS!e^es to ?!f.f£°m Sewa9e Slud9e incinerators.

Sources: Federal Register (1990); Federal Register (1993b); Rubin and White (1992);  Green et al.  (1995);
Cramer et al, (1995).
                                               8-82
                                                                                         April 1998

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                               DRAFT-DO NOT QUOTE OR CITE
             Table 8-31. CDD/CDF Concentrations in Swedish Liquid Soap, Tall Oil, and Tall Resin
Congener/Congener Group
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1 ,2,3,4,8-71 ,2,3,7,8-PeCDF '
2,3,4,7,8-PeCDF
1 ,2,3,4,7,8/9-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total 2,3,7,8-CDD
Total 2,3,7,8-CDF
Total TEQ
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total OCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
Total OCDF
Total CDD/CDF
Liquid Soap
(ng/L)
ND (0.009)
0.400
ND (0.020)
0.320
0.180
1 .900
1.000
0.620
0.290
0.200
0.013
ND (0.004)
ND (0.004)
ND (0.004)
ND (0.005)
ND (0.010)
NA
3.8
1.123
0.447
0.120
15.000,
3,400
3.600
1 .000
1.000
1.300
0.150
ND (0.010)
NA
25.57
Tall Oil
	 (ng/kg) 	
3.6
5.3
ND (2)
ND (2)
ND (2)
ND(1)
5.3
17
4.2
1.9
1 .4
0.7
ND (0.7)
ND (0.5)
ND (O.8)
ND (2)
NA
14.2
25,2
9.5
31
380
3.3
ND(1)
5.3
;'-.-. 26
41
4.9
ND (2)
NA

Tall Resin
(ng/kg)
ND (1)
1 "IU/ 1 1 /
3.1
ND (4)
i«l_r \Tf
810
500
5,900
	 6,000
ND (2)
fltu' \f-l
ND (0.4)
ND (05)
• •IP' \\Jt\Jf
' 24

ND (1)
t W I I /
r ND (0.7)
10
9.0
	 NA
13213.1
43
200
ND (1)
•"«* \ * 1
25
6,800
11,000
6,000
ND (2)
ND (0.5)
56
19
	 NA

Source: Rappe et al. (1990c).

ND  = Nondetected; value in parenthesis is the detection limit.
NA  = Not analyzed. '
     = Not reported.          -
ng/kg = nanograms per kilogram.
                                              8-83
                                                                                        April 1998

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.  ii



"  ViSi

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                     •'. .  DRAFT-DO NOT QUOTE OR CITE

                        9. BIOLOGICAL SOURCES OF CDD/CDF

        Recent laboratory and field research studies demonstrate that biochemical formation
  of CDD/CDFs from chlorophenol precursors is possible and that, under certain conditions,
  some CDD/CDFs can be biodegraded to form less chlorinated congeners.  Both of these
  formation routes are discussed in this chapter.
        Also, CDD/CDFs were recently discovered in ball clay deposits. The origin of these
  CDD/CDFs is not yet determined, and natural occurrence is still considered a possibility.

.9.1.   BIOTRANSFORMATION OF CHLOROPHENOLS
        Several researchers demonstrated under laboratory conditions that biochemical
  formation of CDD/CDFs from chlorophenol precursors is possible. These studies are
  described below. However, the extent to which  CDD/CDFs are formed in the environment
  via this mechanism cannot be estimated at this time.
        In 1991, Lahl et al. (1991) reported finding CDD/CDFs in all 22 samples of various
 types of composts analyzed. The hepta- and octa-substituted CDDs and CDFs were
 typically the dominant congener groups found.  The TEQ content of the composts ranged
 from 0.8- to 35.7-ng TEQ/kg. Similarly, CDD/CDFs are frequently detected in sewage
 sludges.  (See Section 8.4.1.} The CDD/CDFs found in compost may primarily be the result
 of atmospheric deposition onto plants which are subsequently composted and also by
 uptake of CDD/CDFs from air by the active compost (Krauss et al., 1994). The CDD/CDFs
 found in sewage sludge  may primarily be due to the sources identified in Section 8.4.1.
 However, laboratory studies with solutions of trichlorophenols and pentachlorophenol (PCP)
 in the presence of peroxidase enzymes  and hydrogen peroxide (Svenson et al., 1989; Oberg
 et al., 1990; Wagner et al.,  1990; Oberg and Rappe, 1992; Morimoto and Kenji,  1995) and
 with sewage sludge spiked with PCP {Oberg  et al., 1992) indicate that biochemical
 formation of CDD/CDFs, particularly the higher  chlorinated congeners, from chlorophenol
 precursors is possible.
       Peroxidases are common enzymes in nature. For example, the initial degradation of
 the lignin-polymer by white- and. brown-rot fungi is peroxidase catalyzed (Wagner et al.,
 1990).  The actual conversion efficiency of chlorinated phenols to CDD/CDFs observed in
 these studies was low, however.  In the solution studies,  Oberg and Rappe (1992) reported
                                        9-1
                                                                          April 1998

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                       .    DRAFT-DO NOT QUOTE OR CITE

 a conversion efficiency of PCP to OCDD of about 0.01 percent; Morimoto and Kenji (1995)
   "" n       '      n 	°mr   , ', „  , ' , '     ',     , ,  „" '',,,'.               "'-'
 reported a conversion efficiency of PCP to OCDD of 0.8 percent; and Wagner et al. (1990)
 reported a conversion efficiency of trichlorophenol to HpCDD of about 0.001 percent.
 Oberg et al. (1996) reported a conversion efficiency of trichlorophenols to CDD/CDFs of
 about 0.001 percent. In the sewage sludge study (Oberg et al. 1992), a conversion
 efficiency of PCP to total CDDs of 0.0002 to 0.0004 percent was reported.
       Several researchers recently conducted both laboratory and field studies in an
   1       ,  ; •   *  " :- •"'..;.' '.:;'?.'' !;! '':v'. i":i •,•>.•', <"• '•	•;'•.:':; -j'i ^Wv'v ^i'^'S'1 • I1    ..    , ••':  "  ;  ' .
 attempt to better understand the extent and factors affecting the fate and/or formation of
   '•:'•     ' -  •:••   !'!;;-i  "•:. ; ,.^"-\'.\$ W'Vv^Tik'S,.''•;<'•. $ *'"*•}'• •.•,.-j-t. *..?•:•,   r , •,,        .  -
 CDD/CDFs in composts and sewage sludges.  The findings of several of these studies are
 discussed in the following paragraphs.  The findings are not always consistent in terms of
 the congener profiles/patterns detected and the extent, if any, of CDD/CDF "formation,"
 which may be due in part to variations in the compost materials studied, experimental or
   ,",!„,     .     ,i   ' .'Kill! 'I    " ,' ,' I',,11, ,i,' ,„'! , ''  .,	  . ''	 ';•'" ,  !'/,' 	;:'„,. 	= ' „ .,  !l!	 «",!!:: ,,:1: ,	  ,i
 field composting design, and duration of the studies.
       Harrad et al. (1991) analyzed finished composts and active compost windrows from
 a  municipally-operated yard waste^composting facility in Long Island, New York.
   '.''::•••   ,  :•  "'' ;"  'siiEi  ;'  i, ;•  -';	/i,; "", >i • ' • :  ;',,'',/.." ::V''.'•>.'- *•;].:.;;<;.,{>•"•,,'. J,:•,'•'.' V'W, i1,'.;'   • 1     •   ,• ;
 Concentrations measured in 12  finished  composts ranged from 14- to 41-ng TEQ/kg (mean
 of 31-ng TEQ/kg).  the concentrations in the five active compost samples (1 to 30 days in
 age) ranged from 7.7- to 54-ng TEQ/kg (mean of 21-ng TEQ/kg). The observation that
 CDD/CDF concentrations measured in two soil samples from  the immediate vicinity of the
 composting (1.0- and  1.3-ng TEQ/kg) facility were significantly lower than the levels found
in the composts, suggested to the authors that the source(s) of CDD/CDFs in the composts
   	' •  > •  •  , • '  -,  SKI  i1, ••: i,',1 •,., :• ,i:. ••	;:  •,  =« y. i	to?, ;• : ,;•.,	;	s, • iv;:i ;i '.Ui,1 ,,";' .••' '..  i,.  ,' ;  .•'   '    •  ',
was different than the source(s) affecting local soils. A strong similarity between the
congener profiles observed in the composts with the congener profile of a PCP formulation
(i.e., predominance of 1,2,4,6,8,9-HxCDF and 1',2,3,4,6,8,9-HpCDF in their respective
   ,;ti"  : •.    .• •  . "   • •!•«'• ' :	   •.: i:,.•".. •', •<,   •'  " "	;'";."' : •• r.1 ;:•„•' '	(d1  ;>i, :":. i- •. !,!'.. i •:,>.•  :   !"i
   ;;,    . .     •    •',!(;,, i  ..  ''•:.• i  .:.  ,,(,"!, i  «„  '':."!,;,!,	• M-i ,. '•  [••  ,. ..•• -,-; ..•;;, ,.,. .  !•„!,", •;,;. •    |    ' ,  • ,
congener groups) indicated to the authors that leaching of CDD/CDFs from PCP-treated
wogd in the compost piles was the likely source of the observed CDD/CDFs. The levels of
PCP in the 12 finished composts ranged from 7 to 190 //g/kg  (mean of 33 /^g/kg), and the
   •;	        • "   „ »i, i "if!  •  • ..'" ,""'f»	i	!'.,»	a   ,'',;  -! i'T1 , ••  f \: •"  :,; >! >• • ••	,, ',i:''!'i i1",,1, „",•!, n,	,•>, ' • ,•!,!;:,:"!•!•' '•>	  r
PCP levels in the active compost samples ranged from 17.to 210 y^g/kg (mean of 68
   ',„'"„ "   "  • '  •    	INI,,      ,;• i'   „, if'u! ;• fti'i:1   	  ;. "j »,"!',,.;;! ..i,;!!,,' ,' • :;;!,. •'! • "'t  'LIK.*!! • ^ i,. ,„!' „, t i	 fl,,,,.',	:,, "i,," ,  „,  I  '  , '
j"g/kg).  The PCP level in both soil samples was 1.5 ^g/kg.
       Goldfarb  et al. (1992) and Malloy et al. (1993) reported the results of testing of
composts at three municipal yard waste composting facilities  (5- to 91-ng TEQ/kg; mean of
30-ng TEQ/kg), two municipal solid waste composting facilities  (19- to 96-ng TEQ/kg;
   , '  "   '     '   ,1'ill ' ""::          I I   '                    I            'I  •'•!•'•
                 '!, Ill ' '           I                                      I    '
                                          9-2   ,                .    .          April  1998

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                         DRAFT-DO NOT QUOTE OR CITE

 mean of 48-ng TEQ/kg), and one municipal facility composting solid waste and dewatered
 sewage sludge (37- to 87-ng TEQ/kg; mean of 56-ng TEQ/kg).  All facilities were located in
 the United States. Two general trends were observed. First, an increase was observed in
 analyte levels, with an increasing degree of chlprination for each compound type (i.e.,
 CDDs, CDFs, chlorophenols, and chlorobenzenes). Second, an increase in concentration of
                   i                             '      , •'  •
 each congener or homologue group, with a progression from yard waste to solid waste to
 solid waste/sewage sludge composts, was observed. As noted above, TEQ concentrations
 showed this same trend, which was primarily due to increasing  levels of 1,2,3,4,6,7,8-
 HpCDD and OCDD. The mean PCP concentrations in the three compost types were 20
 M9/kg (yard waste), 215 ^9/kg (solid waste), and 615 vg/kg (solid waste/sewage sludge).
 Comparison of congener profiles by the authors indicated that the CDD/CDF residue in PCP-
 treated wood in the compost feedstock was a major, but not the exclusive contributor of
 the observed CDD/CDFs.  The authors postulated that biological formation of HxCDDs,
 HpCDDs, and OCDD from chlorophenols (tri-, tetra-, and penta-) in the compost could be
 responsible for the elevated levels of these congener groups relative to their presence in
 PCP.
       Oberget al. (1993) measured the extent of CDD/CDF formation in three
 conventional garden composts; two were spiked with PCP, and  one was spiked with
 hexachlorobenzene. The two PCP-spiked composts were monitored for periods of 55 days
 and 286 days, respectively. A significant increase in the concentrations of the higher
 chlorinated congeners, particularly the HpCDDs, OCDD, and, to.a lesser extent, OCDF,
 were  observed. Similar results were reported  for the hexachlorobenzene-spiked compost,
 which was monitored for a period of 49 days. Oberg et al. (1993) state that for a "typical"
 composting event, a two- to threefold increase in TEQ content corresponds to an elevation
 by 0.2- to 0.5-ng TEQ/kg dry weight.
      Weber (1995) subjected sewage sludges from two German communities to
 anaerobic digestion in laboratory reactors for 60 days.  The two sludges were spiked with
 2,3,5-trichlorophenol (10 to 25 mg/kg), a mixture of 2,3,5-trichlorophenol and
dichlorophenols (2.5 to 25 mg/kg), or a mixture of di-, tri-, and tetra-chlorqbepzenes (4 to
40 mg/kg). In nearly all of the digestion experiments, the addition of these precursors did
not lead to  any significant changes in CDD/CDF concentrations.  The initial CDD/CDF
concentrations in the two sludges were 9- and 20-ng TEQ/kg. The only exceptions were

                                        9-3                                April 1998

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                       .   DRAFT-DO NOT QUOTE OR CITE

 increased 2,3,7,8-TCDF concentrations in the mixed chlorophenol experiments and
 decreased 2,3,7f8-TCDF concentrations in the mixed chlorobenzene experiments.
 However, the same increases or decreases for this congener were also observed  in the
   , • .    •  .  	.•	  „•, •,  . .   	    . ,-	 . • •   i  ... ..  I '." .  , r, .- .< . •'.	 ,'. .'  •  •  I
 controls (i.e., no precursors added).
                "' ' '      "    "   "     "  '   	    ' '    '   '    '  "      /
 9,2,   BIOTRANSFORMATION OF HIGHER* CDD/CDFS
        Several recent studies examining the fate of a range of CDD/CDF congeners in pure
 cultures, sediments, and sludges indicate that under  certain conditions some CDD/CDF
 congeners will undergo biodegradation to form less chlorinated (and possibly more toxic)
  ,!:•',  !i '   , '"   ' '   !'!'iil ill ('i '" ' ''. , '! ,  , "i  	  ,,'il,, ', " ." •'!, I,' ,|. I, :•:, •':• ,|, " ' 1 • , ,h ' ,1	'' ' '	I'» JV ,N: ' «', ' 'i. In!  , MB1	l,i' ''I ,   • ,  I' ,
 CDD/CDFs.  However, the extent to which more toxic CDD/CDFs are formed in the
 environment via this mechanism cannot be estimated at this time. The following
 paragraphs discuss those studies that examined the products of biodegradation in
 sediments, compost, and sewage sludge.
        Several recent reports indicate that CDDs and CDFs may undergo microbial
 dechlorination in anaerobic sediments. Adriaens and Grbic-Galic (1992; 1993) and
 Adriaens et al.  (1995) reported the results of a series of microcosm studies utilizing Hudson
 River sediment (contaminated with Aroclor 1242) and aquifer material (contaminated with
 CDDs) from Pensacola, Florida.  Both types of substrates were spiked  with several CDDs
 (1,2,3,4,6,7,8-HpCDD; 1,2,3,4,7,8-HxCDD; and 1,2,4,6,8,9-/1,2,4,6,7,9-HxCDD) arid
 CDFs (1,2,3,4,6,7^8-HpCbF and 1,2,4,6,8-PeCDF) and monitored over a 16-month period,
 at an incubation temperature of  30°C. The Hudson River sediment was spiked with 144
  !»  ' '  • . '.j , ." '  '- li'MJi.  ',>.'  • 	':; i. T"V , :.i,,  :. .;..., 	.if','•]•)•;,' .'•,..,*	••;,„.•,,'"i1  ,„:;, '.i'l, ,'.i ,;""?v; i ...  	 !•  •  f
 ^g/kg of each congener, and  the Pensacola aquifer material was spiked with 63 yug/kg of
 each congener.
       All of  the congeners, with the exception of 1,2,3,4,6,7,8-HpCDF, showed a slow
    i 	 :• ;  ,.'  • tyiJl  i"1'1  •.  •••  •!•,,:•,;'if'  yvf,1	',;l!,>:'.', i.'«?!:•••(' ••-, : i in1, ••.",':'',;:-'! i tf'jvj ;•'•}.'     i./1
 decrease in concentration over time, attributed to biologicaliy mediated reductive
 dechlprination,  with net disappearance rates ranging from 0.0031 wk"1 to 0.0175 wk"1
             ,,	ii   "'''"" ,'• .!•„  • •  "'••'•, n'"ii" •'!	, 'i ' : , '«,: 'I:1"1' /'vi,.F : ii',,,: '',"i,,, •,:, > i \ .'•wiii' .."w •'' •"' •'" i»  •<•< '' ». '  ' ' ' •   >
 (i.e., half-lives of approximately  1 to 4 years).  However, Adriaens et al. (1995) conclude
that the actual half-lives may be orders of magnitude higher. The experiment with
 1,2,3,4,6,7,8-HpCDD yielded formation of two HxCDD (1,2,3,4,7,8- and 1,2,3,6,7,8-).
Thus, removal of the peri-substituted (1,4,6,9) chlorines was favored, with enrichment of
2,3,7,8-substituted congeners.  No lesser chlorinated congeners were identified from
incubations with the other tested congeners.  1,2,4,6,8-PeCDF was also  examined in

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                       /                     '                              •
 dichlorophenol-enriched cultures.  After 6 months incubation, several TCDFs were
 identified, which also indicated that peri-dechlorination was the preferred route of
                                     1           '       .   '
 reduction.                                                    ,
       Barkovskii and Adriaens (1995; 1996) reported that 2,3,7,8-TCDD (extracted from
 Passaic River sediments) was susceptible to reductive dechlprination when incubated at
 30°C under methanogenic conditions in a mixture of aliphatic and organic acids inoculated
 with microorganisms obtained from Passaic River sediments. The initial concentration of
 2,3,7,8-TCDD (20 ± 4 ^g/L) decreased by 30 percent to 14 ± 2 ^g/L over a period of 7
 months with the consecutive appearance and disappearance of tri-, di-, and mono-CDDs.
 Experiments were also conducted  by spiking the sediment with HxCDDs, HpCDDs, and
 OCDD. Up to 10 percent of the spiked OCDD were converted to hepta-, hexa-,  penta-,
 tetra-, tri-, di-, and monochlorinated isomers, but the reaction stoichiometry was not
 determined.  Two distinct pathways of dechiorination were observed:  the peri-
 dechlorination pathway of 2,3,7,8-substituted hepta- to penta-CDDs, resulting in the
 production of 2,3,7,8-TCDD, and the per/-lateral dechiorination pathway of non-2,3,7,8-
 siibstituted congeners.
       Several studies reported that CDD/CDFs can be formed during composting
 operations through biological action on chlorophenols present in the compost feed material.
 The results of studies that specify likely involvement of ehlorophenols are described in
 Section 9.1.  Another possible formation mechanism was suggested by Vickelsoe et al.
 (1994), who reported that higher chlorinated CDD/CDF congeners are formed  when humic
 acid is reacted with a peroxidase enzyme, hydrogen peroxide, and sodium chloride.  It is
        f             ,                             .          .           ' •
 expected that some organic material in compost and sewage sludge has a humic-like
 structure.  Several additional studies are described below in which the potential
 involvement of chlorophenols could not be assessed, because chlorophenoi concentrations
 in the composts  were not reported.
       Schafer et al. (1993) monitored the seasonal changes in the CDD/CDF content, as
 well as the extent of CDD/CDF formation, in the composts from a vegetable and garden
 waste compost operation in Germany. Finished compost samples were collected and
 analyzed every 2 months for 1 year.  An annual cycle was observed in TEQ concentrations,
 with peak concentrations in the summer (approximately 8.5-ng TEQ/kg) that were 2.5
times higher than the lowest concentrations observed in the winter (approximately 3.5-ng
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                           DRAFT-DO NOT QUOTE OR CITE
  TEQ/kg). No seasonal source was apparent that could explain the observed differences in
  seasonal levels. The CDD/CDF contents of the starting waste materials for two compost
   	i'li1, ,' , ,   , " „• "  ,  I'flMif1 ", ," 	" ,", "T i'1 , n 'mi"  ; !• ' .," , 's, 'l!''||, ",,i f ',i'.',i :'„   , ' U{. ,  	  „.,••,.,,,,', i, |   ,     ,  «*
  cycles (March and September) were measured to monitor the extent, of CDD/CDF formation
  during composting. For the March cycle sample, most 2,3,7,8-substituted CDD/CDF
  congeners decreased in concentration during composting. Four CDF congeners showed a
   P: "I, ,  •',,, "'  ; i : ' ' ,,  ' Ml"! ,,!',;"' ' „, ii „» „• ,i,[. A, • i,, "|	i ,:'"','„, ,  „ " '"'IHH1 I, ,„'  i/ I  > ":„"'.; . ,,, , • , , ^ •, "'P!,,'1- ,,:",',•,'' ..,''!  :           • ,;
  slight increase in concentration  (i.e., less than 10 percent).  For the September cycle
  sarnple, OCDD andIHpCDD concentrations increased 300  percent during composting.  Less
 than 10 percent increases, were, observed  for HxCDDs and PCDF; all other 2,3,7,8-
 substituted CDD/CDF congeners showed decreases in concentrations during composting.
        Krauss et al. (1994) measured the  extent of  CDD/CDF formation during the
 composting of household waste using a laboratory compost reactor.  After 11 weeks, the
 • » ,,,i!'',,,	: ":  " ,. . , .  ' ,n   ji'-iTjiiiim ; i ;, ;  ."Hi.' „•• .,,', „ .i;	f  '. ;,; 	 ,, "",:;„ d HxCDD showed no change in mass content.  All CDF congener groups showed
 decreases in mass content; however, the concentrations in both the starting and finished
 conipost were close to the analytical "detection limits.
       Oberg et al. (1994) reported the results of monitoring of two household waste
   >."1 i      :''  . "   Klttl '"   .-"'.'.. "'r •'•.'. I ' is, : , ', i'1'"  V ,"•[','/: ''' l.f.'l  '	; Mil;") i" ?,",: ';"  ,;;!-'  •'	 	 I, '
 composts and two garden composts.  For  the two household  waste composts, total
 CDD/CDF content decreased in fcjqth composts over the  12-week test period.  Total CDD
   Pi'i'iill-! „ • ,   •' „'„  „'!: ' , 3	IJii'1! I,"".;. T' • ,- : 'i", .• ,!„•'• '  'i'ii , ; • i "i; i1  ,,•:. V :•• !	,«. "• •, M.J. ',., i	i,,,',r, ,,.,l''r, '.!,,'!,'. ' iif,:|1 ,' ,' 'i! ,„,   • i  ,  , ,
 content and PCB content decreased, but total  CDF content increased in contrast to the
   i'i	r'l.,   ," . . '•"	f1 ,  ii'SB :,',  .,'.''	i  , "'',' a£i I1;' 'ft, 	.".',,;' j;"1, ';,"!•,)!,' ,;-, '•, •;1i;|1 ; i'l <;• i i	' .'ll-'t. i'i'i ,;  '' 'I'.
 findings of Krauss et al. (1994).  A small increase in OCDD content in both composts,
 how/ever, was observed. The two garden  composts were  monitored bv Oberq et al. (1994)
 :• • ;'.!».•'. '.   i '>'  :•'..- >, :'ja '.< v •. - ••  '' 	':; ,.W."  •.'.'•' " i,11-. .!•';  ' (•,.::! - :.,>.•  ,;'•";:	 .t >•  • • .1	'!;..• r.-< . • > t  s     •      •
 for a 60-week period.  Total CDD/CDF concentration increased, with the largest increases
 observed for OCDD and HpCDDs.  The lower chlorinated CDFs decreased in concentration.
       As a followup to a preliminary study (Hengstmann et al., 1990) that indicated
 CDD/CDF concentrations may increase and congener profiles may  change during anaerobic
   .•;. •    i	•   	              '                       ii              F	       •   •    •
 digestion of sewage sludge, Weber  et al. (1995) subjected sewage sludges from two
  • ',i,   '   '• '-. i . i.1 ii          i     '             "   i   i i            .,,, t  •  .-'    . '  '.
 German cprnmunities to anaerobic digestion and aerobic  digestion  in laboratory reactors for
  • •>;•,      ;  ' '    ii         '         •       I       I	i     I        . I  .'• '    •• .  .   •
 60 days and 20 days, respectively.  The initial  average TEQ concentrations in the raw
   fV '     '  '!•!,    ll'l                       I i    i      i         i        .'.i     ,   ,   . •  . .
sludges were 20- and 200-ng TEQ/kg.  No significant increase or decrease in total
CDD/CDF content or congener group content was observed with either  sludge.  In contrast,
a significant decrease in CDD/CDF content was observed in the aerobic digestion

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experiments on both sludges. The greatest percentage decreases in congener group
concentrations (i.e., greater than 40 percent) were observed for TCDF, PeCDF, HxCDF,
TCDD, and PeCDD in the sludge initially containing 20-ng TEQ/kg and for TCDF, TCDD,
HpCDD, and OCDD in the initially high content sludge. The greatest percentage decreases
in congener concentrations (i.e., greater than 40 percent) were observed for non-2,3,7,8-
substituted congeners.
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                     10.  PHOTOCHEMICAL SOURCES OF CDD/CDF
                 r              " '    '              '                   '   ' -.
 10.1. PHOTOTRANSFORMATION OF CHLOROPHENOLS
       Several researchers demonstrated that CDD/CDFs can be formed via photolysis of
 pentaehlorophenol (PCP) under laboratory conditions.  These studies are described below.
 However, the extent to which CDD/CDFs are formed in the environment via this mechanism
 cannot be estimated at this time.
       Lamparski et al. (1980) conducted laboratory studies to determine the effect of
                   • '     ,   \
 simulated summer sunlight on the formation of OCDD, HpCDDs, and HxCDDs in wood that
 was pressure treated in the laboratory with PCP.  In the first set of experiments, wood
 veneers (Southern pine), treated with purified PCP or with Dowicide EC-7 using methylene
 chloride as the PCP carrier, were exposed to light for 70 days. The PCP concentration in
         i                     ,                           ''
 the treated wood was 5 percent by weight, which approximates the concentration in the.
                                *                        •
 outer layer of PCP-treated wood utility poles. Photolytic condensation of PCP to form
 OCDD was observed, with the OCDD concentration increasing by a maximum factor of
 3,000 for the purified PCP and by a factor of 20 for EC-7 at about day 20 before leveling
 off.  HpCDD and HxCDD were also formed apparently by photplytic degradation of OCDD
 rather than by condensation of PCP and tetrachlorophenols.  The HxCDD concentration
 increased by a factor of 760 for the purified PCP and by a factor of 50 for EC-7 over the
 70-day exposure period. The predominant HpCDD congener formed was 1,2,3,4,6,7,8-
 HpCDD due to an apparen^ preferential loss of chlorine at the peri position (i.e., positions 1,
 4, 6, and 9).
       In a second set of experiments conducted by Lamparski et al. (1980), a hydrocarbon
 oil (P-9 oil)  was used as the carrier to treat the wood.  The increases observed in the
 OCDD, HpCDD, and HxCDD were reported to be much lower relative to the increases
 observed in the first set of experiments, which utilized methylene chloride as the carrier.
       j               •                     ,      . "       , '
 Results were reported only for OCDD.  The OCDD concentration increased by a maximum
factor of 1.5 for EC-7 and technical PCP, and by a factor .of 88 for purified PCP. The
results suggested to the authors that the oil either reduced condensation of PCP to OCDD
or accelerated degradation to other species by providing a hydrocarbon trap for free-radical
species.    .           "•:.-,.
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                  Vollmuth et al. (1994) studied the effect of irradiating laboratory water and landfill

            seepage water containing PCP under conditions simulating those used to purify water with

            ultraviolet (UV) radiation (i.e., 5-hour exposure to 254-nm radiation from low pressure

            mercury lamps). The three solutions tested contained  approximately 1  mg/L of PCP or PCP-

            Na. before irradiation, but the CDD/CDF content varied  drarriatjcajly (1.5-, 2066-, and 2071-

            pg" TEQ/L). Irradiation resulted in nearly total destruction of PCP (greater than 99 percent

            Joss) in all three experiments. An overall net increase in TEQ content was observed in the

            initially low TEQ content water, but a net decrease was observed for the two  initially high
             v;:. ;•    	•            -.I1' ; ';;:'; ::';.,''."' •'•'    i                   u,     •:" I. •   ,.    • :•     .• ,-
           TEQ content waters.

                  •      Irradiation of laboratory water containing purified PCP showed an increase in
                        TEQ concentration from  1.5 pg/L to 214.5 pg/L.  The increase in TEQ was
                        due entirely to the formation of 1,2,3,4,6,7,8-HpCDD, OCDD, and
                        1,2,3,4,6,7,8-HpCDF. Formation of non-2,3,7,8-substituted HpCDDs and
                        HpdDFs was also observed.  The ratios of the concentrations of these non-
                        2,3,7,8-congeners to the concentrations of the 2,3,7,8-congeners were 0.6
                        for HpCDDs and 5.0 for HpCDFs.  The HpCDD and HpCDF congeners formed
                        indicated that the operative mechanism is photoinduced dechlorination of
                        OCDp  at a peri position and dechlorination of OCDF at only the  1 - and 9-peri
              ;;  ,,      ;,; positions.	'
                                                             ,"„«'
                        Irradiation of water containing technical PCP-Na (Dowicide-G) resulted in a
                        net loss in CDD/CDF TEQ content from 2,065.5 pg/L to 112.7 pg/L. The
                        only 2,3,7,8-substituted congener showing an increased concentration was
                        1 '2c3,6,7,8-HxCDb.  ^he other congeners originally present in the technical
                        PCP-Na showed reductions of 80.6 to 100 percent.
                           I'lllll'llil  il.'i'	Ill, ' ',>' ';  'HI',|! I]!!1 UN'ilill
                 *      The TEQ content of seepage water from a landfill (2,071 pg TEQ/L) was
                        reduced by a factor of two to  1,088 pg TEQ/L  However, several 2,3,7,8-
                        substituted congeners did increase in concentration (1,2,3,6,7,8-HxCDD;
                        1 ,2,3,4,6,7,8-HpCDD; 1 ,2,3,4,6,7,8-HpCDF; and OCDF).


                 Waddell et al. (1 995) also studied the effect of irradiating distilled laboratory water
I             !,:',,:,  ••.. ""' ........ ,• '  ..-I!' "':" .•  '. • ,:«,',", vji«il •".'(•";* ''''.i"!1. id;,' r tliOiVi ,'•' ;•"•!; • .'ii'.f •.;'•„  aw • v • i>    •:•
          containing PCP under conditions simulating those used to purify water with UV radiation.

          The results obtained were similar to those of Vollmuth et al. (1994). Analytical grade PCP

          at a cphcentration of ,1 6  mg/L was exposed for 1 2 minutes to 2ob-300-nm radiation from a

          medium pressure mercury lamp.  All CDD/CDF congener groups increased in concentration

          over jhe 12-minute exposure period, with the greatest increases observed for OCDD (75
'HI'' ..... .'I ! , «. !  , "'  j'li- ' . t  ' ,  ,"             I ll   I |      I  I    II   I   I I             • '' I  .I   '  ',        '  •  '
          fold increase) and HpCDDs  (34-fold  increase).  The TEQ content of the solution increased
[ "ii"1 ' "         '_', '    '   '                                           , ............  \
          from 4.2-pg TEQ/L to  137-pg TEQ/L over the 12-minute period. The dominant congeners
........... ,  .       1. 1 '    i        i-:1!"  ', ....... '  :\ ......... ...... :.j." ,  •'• , ••   "- • • ;• ••  -, ..... -,•,;,, ..... ; ii/t -,,",'• ..... ..'... • M-I > •.••     i        a     .  .
                                                  10-2
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 formed in terms of both concentration and contribution to TEQ were 1,2,3,4,6,7,8-HpCDD,
 OCDD, and 1,2,3,7,8,9-HxCDD.

 10.2. PHOTOLYSIS OF HIGHER CDD/CDFS
       Photolysis appears to be one of the few environmentally significant degradation
 mechanisms for CDD/CDFs in water, air, and soil. Although, in most studies, good mass
 balances were not obtained and the photolytic pathways, for CDD/CDFs were not fully
 identified, a major photolysis pathway appears to be photodechlorination, resulting in
 formation of lower chlorinated CDD/CDFs. A preferential loss of chlorines from the peri
 positions (i.e., chlorines at the 1, 4, 6, and 9 positions) rather than from the lateral
 positions {i.e., chlorines at the 2, 3, 7, and 8 positions) was reported for some  congener
 groups when irradiated as dry films, sorbed to soil, and as gas-phase CDD/CDFs (Choudry
 and Webster/ 1989; Kieatiwong et al., 1990; Sivils et al., 1994 and 1995; Tysklind et al.;
 1992). Several researchers reported that carbon-oxygen cleavage and other mechanisms
 may be similarly or more important pathways for CDD/CDFs containing four or  fewer
.chlorines.
       Because of the difficulties inherent in controlling experimental variables  for
 nonvolatile and highly lipophilic compounds like CDD/CDFs, few photolysis studies have
 been performed with natural waters, on soil, or particulate matrices, and in the gas phase
 to examine the rates and products of photolysis under environmentally relevant conditions.
 Thus, it is not possible at this time to quantitatively estimate the mass of various CDD/CDF
 congeners formed in the environment annually via photolytic mechanisms. The following
 paragraphs summarize the key findings of recent environmentally significant studies for the
 water, soil, and air media.

 10.2.1       Photolysis in Water
       Numerous studies demonstrate that CDD/CDFs will undergo photodechlorination
 following first order kinetics in organic solution, with preferential loss of chlorine from the
 lateral positions.  Photolysis is slow in pure water, but it increases dramatically when
 solvents serving as hydrogen donors such as hexane, benzene, methanol, acetonitrile,
 hexadecane, ethyl oleate, dioxane,  and isooctane are present. However, only a few studies
 have examined the photolysis of CDD/CDFs using natural waters and sunlight.

                                        10-3                                April 1998

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                        ,    DRAFT-DO NOT QUOTE OR CITE

         Choudry and Webster (1989) experimentally determined the sunlight photolysis half-
  life of 1,3,6,8-TCDD in pond water to be 3.5 days (i.e., more than 10 times greater than
   ,,,,.;      >i;r  ,    ||,;|	U , ,	,' '	  I'; |,\ ,.». ,I]	 •! .,-' ' . ',' , J|  "i  1, i ',•  lili,'  l»K 1V' , '  ,' " ,. '' i     ,
  the half-life predicted by laboratory experiments using a water/acetonitrile solution).  The
  •,',„;  ,   , Hi,  '"-,   ,,	nilii '  •  " ;,,' ',,i	, i ' • ".,, I*, / ' •„ Min'i,,  , 'i1!'11'.!.,:!!' , „ t	V "'•: '" '•• .••!",! ' • •• 'r i .".I'i'.•"'i4,:"'i A,	'• n  , . I   '• •
  authors attributed this significant difference in photolysis rates to the light
  screening/quenching  effects of dissolved organic matter.
        Friesen etal. (1990) examined the photolytic behavior of 1,2,3,4,7-PeCDD and
  1,2',3,4,6,7,8-HpCbp In watenacetonitrile (2:3, v/v) and in pond water under sunlight at 50
  degrees north latitude.  The observed half-lives of these two compounds in the
  watenacetonitrile  solution were 12 and 37 days, respectively, but much shorter in pond
  water, 0.94 and 2.5 days, respectively. Similarly, Friesen et al. (1993) studied the
  phptodegradation of 2,3,7,8-TCDF and 2,3{4,7,8-PeCDF by sunlight using
  water:acej;oi3itri|e;|2:3,  v/y) and lake water.  The obseryed half-liyes of the  2,3,7,8-TCDF
  and 2,3,4,7,8-PeCDF in the watenacetonitrile solution were 6.5 and 46 days, respectively,
   iiFII" •'•     I      i I I          i •                                        i , .   '  .
 and 1.2 and 0.19 days in lake water, respectively.  The significant differences between the
 n^iy^' water and watenacetonitrile solution results were attributed to  indirect or  sensitized
 photolysis due to the  presence of naturally occurring components in the lake and pond
 water.
   :i-':ll  '"          nil           i . "    '    il1'       '      '      ;' ' i  .'
        Dung and p'Keefe (1992), in an investigation of aqueous photolysis  of 2,3,7,8-
 TCDF and 1,2,7,8-TCDF, reported findings similar to those of Friesen et al.  (1993).  The
 Photolysis rates of .the two TCDF congeners observed in the river and lake water (half-lives
 of about 4 to 6 hours) were double the rates observed in pure water (half-lives of  about 8
   "'ilpy,,  i,1   , ",, • ,„, •• , WIl'i , ', ' " 	,,'i ,„ ;,,'„ ' :	 ."Jl1  ,:	? ',, ';, 'iri11",1'; !,'•''"":•: •,!'.' !\i",\,ii«1', '»i."i''i', „'•»;,. r1- '"'.I ":"'', • "'M!1'",,  i, ::  , • r   . "' -      i
 to11  hours).  Dung and O'Keefe (1992) attribute the difference in rates to the presence of
   N | |i • •   , I'.n   ,.,  •   H'H'iN"1!!	'''"  ' i  'I	•' ,i"p •  •„ " ' ji1 , vii'l" 	 '!	i .;  I1,, .i M I1'i, JiM',,"1, ""',,1'1' ..,,'i"|i ',,,'» ,,•!,!»: :„'',„ ,"',„, ,;':!,
 natural organics in the river and  lake water that may be acting as sensitizers.  .

 10,2.2     ' ."Photolysis on Soil  ""'	....•-.     >         .
       Photolysis of CDD/CDFs on soil has not been well characterized.  Based on the data
 generated to date,  however, photolysis is an operative degradation process  only in the near-
 surface soil where  UV light penetrates (i.e., the top few millimeters or less of soil), and
   ',::!":   ,   .: . i  .  ','M ,?, •:  :• .,• tl 	fiis .  ..' : -.•,•,•. .;"vi'e.(,!i: i-(| wv;	'; \-t	-i	,,i/m\-.t. ., «  ,f\,r  v  ,-, i -  •    '
 dechlorination of peri-substituted chlorines appears to occur preferentially.
       Miller et al.  (1989) studied the CDD degradation products resulting from irradiation
 of 13C-labeled OCDD on two soil types using sunlamps. Approximately 38 to 42 percent of
the OCDD were degraded by day 5 of the experiment; no significant further loss of OCDD
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                                                                               April 1998

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 was observed over the following 10 days. Although determined not to be the dominant
 photolysis pathway, photodechlorination was observed in both soils; approximately 10 to
 30 percent of the lower chlorinated congeners were produced from the immediate higher,
 chlorinated congeners. The HpCDD and HxCDD congeners observed as degradation
 products were present in approximately similar proportions  to the number of congeners in
 each congener group. However, Miller et al. (1989) found that 2,3,7,8-TCDD and
 1,2,3,7,8-PeCDD were observed in greater yields than would be expected on the basis of
 the number of potential TCDD and PeCDD congeners.  One-fifth to one-third of the total
 yield of PeCDDs was 1,2,3,7,8-PeCDD, and one-half of the total yield of TCDDs was
 2,3,7,8-TCDD.  .
       Kieatiwong et al. {1990) performed similar experiments to those of Miller et al.
 (1989) using natural sunlight rather than sunlamps for irradiation of 13C-labeled OCDD on
 soils. Photodechlorination was estimated to account for approximately 10 percent of the
 loss of OCDD. One-third to one-half of the total yield of PeCDDs was 1,2,3,7,8-PeCDD,
 and one-half of the total yield of TCDDs was 2,3,7,8-TCDD. The findings of Miller et al.
 (1989) and Kieatiwong et al.  (1990) indicate that the  2,3,7,8-substituted TCDD and PeCDD
 congeners were either preferentially formed or were phptochemically less reactive than the
 other congeners that were formed.
      Tysklind et al. (1992)  studied the sunlight photolysis of OCDD on soil and reported
 results in good agreement with those of Miller et al. (1989) and Kieatiwong et al. (1990).
 Photodechlorination was observed with production of  HpCDDs,  HxCDDs, PeCDDs, and
 TCDDs over the 16-day irradiation period.  Photodechlorination at the peri-substituted
 positions was the preferred photodechlorination mechanism; the proportions of 2,3,7,8-
 substituted congeners present in the soils after 16 days for each congener group were as
follows: HxCDD - 65 percent; PeCDD - 40  percent; and TCDD - 75 percent.  The sunlight
photolysis of OCDF on soil was also studied by Tysklind et al. (1992).  Photodechlorination
was observed. However, unlike the case with OCDD, photodechlorination of the lateral-
substituted positions was found to be the dominant photodechlorination mechanism
resulting in a relative decreasing proportion of 2,3,7,8-substituted congeners during the
irradiation period.  2,3,7,8-TCDF was not observed in  any of the irradiated samples.
                                       10-5                               April 1998,

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  10.2.3       Photolysis on Vegetation
         Photolysis of CDD/CDFs sorbed on the surface of vegetation has not been well
   ii;'•''••.  '  ,	.,     "', I'iii •:' ;•»•','  ',-.';, :• * '!'::«».'i •'..•', it,. 11 •.'. .:,-:, >: j.-.V1 ,• ,' •  *••/''. ivi ' "=" ''.««'•  "'    ' 1   ;i
  characterized, and the findings to date are somewhat contradictory.  McCrady and Maggard
  (1993) reported that 2,3,7,8-TCDD sorbed on the surface of reed canary grass (Phalaris
  arundinacea L.) undergoes photolytic degradation with a  half-life of 44 hours in natural
  sunlight. In contrast, Welsch-Pausch et al. (1995) found little difference in the CDD/CDF
  congener patterns between grass (Lolium multiflorum) grown on an outdoor plot and grass
  grown in a greenhouse (i.e., UV-light transmission blocked). In an attempt to clarify this
  contradiction, Welsch-Pausch and McLachlan (1995) studied the photodegradation of
  CDD/CDFs on pasture grass (Arrhenatherion elatioris) during two growing cycles (summer
  and autumn) using two greenhouses.  One greenhouse was constructed of glass that
  blocks UV transmission, and the other was constructed of plexiglass (4 mm) with an UV-
  light transmission of greater than 50 percent in the 280-320 mm range. In both the
  summer and.autumn exposure periods, the concentrations of CDD/CDFs (on a congener
   ,->!  '..,•   " ",   ' , •'. sin, (•• .'/•.'.,' :;!:i ;.»• „;«:!?"; "•	i's'.'1. ..,"iu t •!;..• •*.!''A	»	'•• :. .j .',•>•:' .;••     I
   .i",  '    . .  - *  .s-i'!  '   ••:, . .  ' ,.v •:,  "• •  ,"!-"/:,   • "'  ,  ..;::„'" I ',.'•. ( ."•„•   i
  10.2.4       Photolysis in Air
   :,!,!,'„' '   ,';: '  , '  ' W\  !; .:•<• •• ," •& 	iV,' !. '-,;!';	:'::,: \ .'-.  '-. " ',.:• >  :•'• V 0'	 Vit!',;." .    ,|   -,    .    ,  •    ,':
        Photolysis of CDD/CDFs in the atmosphere has not been well-characterized.  Based
 on the data generated to date, however, photolysis appears to be a significant mechanism
 for degradation  (i.e., principally dechlorination of the  peri-substituted chlorines) of those
 CDD/CDFs present in the atmosphere in the gas phase. For airborne CDD/CDFs sorbed to
 particulates,  photolysis appears to proceed very slowly, if at all.  Because of the low
   W-> ' '   "•.'••:". :»  ';Si ''," ''• ';.; ./".:' !;":; ,'!  "!'! '"'"' >."f. ; i,^, ;'!•' ",' •;'i'.w''." ^-"•',•{ '.'•  '• < ,:".•.'."• '  ;l', ,  '' .
 volatility of CDD/CDFs, few studies have  been gttempted to measure actual rates of
 photodegradation of gaseous-phase CDD/CDF, and only recently studies have examined the
 relative importance of^photolysis  to particulate-bound^CDD/CDFs.
,,,    '• ,„    '    , ," '  'i11''!1"!"!,!,! " :•' •    •  " ,;:i',' , ". •  iS! " "    I                 I  J«        "'',',,
        Sivils et al. (1994; 1995)  studied the gas phase photolysis of several CDDs (2,3,7-
   : i:   .  '..    ":  "  iiiis  . .  ' ,'r • :. '>• ',:.  ;: ' "'     i             '  i   '        '  '.' '•! •       •   •
 TrCDD; 2,3,7,8-TCDD; 1,2,3,4-TCDD; 1,2,3,7,8-PeCDD,  and 1,2,4,7,8-PeCDD) by
   ,,' ll',         :   jjeii.  • ' 	i •. ' ;,,' ^  >i • .,;..      II              I          ''',!.     '    '
 irradiating the effluent from  a gas chromatograph with broadband radiation in the UV/visible
 region for periods of time up to 20 minutes. The irradiated sample was then introduced

             1 ,  -Hi;    '.i       , ,  •  •  : ••• .V"." ;.:: ••.':"  -, '.••. iV.r'V " •'•,'V::  ' .•   ••: i
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 into a second gas chromatograph to measure the extent of dechlorination.  The results
 showed that degradation followed first order kinetics and that an inverse relationship exists
 between the degree of chlorination and the rate of disappearance. Although the lack of
 photoproducts prevented an independent confirmation of the preferential loss mechanism,
 the results indicated that laterally-substituted congeners (i.e., .chlorines at the 2,3, 7, and
 8 positions)  degrade at a slower rate than the peri-substituted congeners (i.e., chlorines at
 the 1, 4, 6, and 9 positions). Although the rate constants were not presented in Sivils et
 al. (1994), the degradation rate for 2,3,7,8-TCDD (30 percent loss in 20 minutes) was
 reported to be slower than the rates for all other tested CDDs.  Also, 1,2,4,7,8-PeCDD
 (with 2 peri-chlorines)  degraded significantly faster than 1,2,3,7,8-PeCDD (with only 1 peri-
 chlorine).
       The photolysis of 2,3,7,8-TCDD sorbed onto small diameter fly ash particulates
 suspended in air was studied by Mill et al. (1987).  The results indicated that fly ash
 appears to confer photostability on 2,3,7,8-TCDD.  Little (8 percent) to no loss was
 observed on  the two fly ash samples after 40 hours of illumination.  Similar results were in
 photolysis studies with fly ash reported by Tysklind and Rappe (1991) and Koester and
 Hites (1992). Tysklind and Rappe (1991) subjected fly ashes from two German
 incinerators under various simulated environmental conditions. The fraction of
 photolytically degradable CDD/CDF after 288 hours of exposure was in the range of 20 to
 40 percent of the extractable CDD/CDF.  However, a  10 to 20 percent reduction was also
 observed in the darkened control samples. With the exception of HpCDD and HpCDF, the
 concentration of all other congener groups either increased or stayed the same during the
                                        •                       .    •          '
 exposure period from hour 144 to hour 288.  Koester and Hites (1992) studied the
 photodegradation of CDD/CDFs naturally adsorbed to five fly ashes collected from
 electrostatic precipitators. No significant degradation was observed in 11 photodegradation
 experiments performed on the ashes for periods ranging from 2 to 6 days. Koester and
 Hites (1992)  concluded that: (1) the absence of photodegradation was not due to the
 absence of a  hydrogen-donor organic substance; (2) other molecules or the ash,  as
 determined by a photolysis experiment with an ash extract, inhibit photodegradation either
 by absorbing  light and dissipating energy or by quenching the excited states of the
 CDD/CDFs; and (3) the surface ,of the ash itself may hinder photolysis by shielding the
CDD/CDFs from light.
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                          11. SOURCES OF DIOXIN-LIKE PCBs
                              t

        The purpose of this chapter is twofold: (1) to identify sources that release dioxin-
 like polychlorinated biphenyls  {PCB) congeners into the environment and (2) to derive
 national estimates for releases from these sources in the United States. PCBs have been
 found in all media and all parts of the world.  PCBs were produced in relatively large
 quantities for use in commercial products such as dielectrics, hydraulic fluids, plastics, and
 paints. They are no longer commercially produced in the United States, but continue to be
 released to the environment through the use and disposal of these products. PCBs may
 also be inadvertently produced as by-products during the manufacture of certain organic
 chemicals and also as products of the incomplete combustion of some waste materials.

 11.1. GENERAL FINDINGS OF THE EMISSIONS INVENTORY
       Tables 11-1 and 1.1-2 present emission estimates for the major known or suspected
 sources that could release dioxin-like PCBs to the environment.  Table 11-1 presents
 estimated  annual releases for the time period  1990 to 1995.  Table 11-2 presents
 estimated  annual releases for the time period  1985 to 1989.  For each source listed in
 Tables 11-1 and  11-2, estimated emissions to air, water, land, and product are listed  where
 appropriate and  where data are adequate to enable an estimate  to be made. The term
 "product"  in Tables 11-1 and 11-2 is defined to include substances or articles (e.g., sewage
 sludge that is distributed/marketed commercially) that are known to contain dioxin-like
 PCBs and whose subsequent use may result in releases to the environment.
       Releases  of "old" dioxin-like PCBs (i.e., dioxin-like PCBs manufactured prior to the
 ban) to the environment can occur from ongoing use and disposal practices. Prior to
 regulations enacted beginning in the late 1970s that  limited the  manufacture/use/disposal
 of PCBs, significant quantities of PCBs were released to the environment in association
 with: {1) the manufacture of PCBs; (2) the manufacture of products containing PCBs; and
 (3) the use and disposal of products containing PCBs, as well as materials that may have
 been contaminated with trace levels of PCBs from prior PCB use or disposal.  Following the
 ban on PCB production, releases from these first two categories ceased to exist.  The third
type of releases, those associated with product use and disposal, will continue in  at least
three ways:                                   •                       •  >   .   .
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 •     Products containing greater than 2 pounds of PCBs (e.g., dielectric fluids in
       transformers and large capacitors) are controlled by disposal regulations that have
       minimized environmental releases;
 •     Disposal of products containing  small quantities of PCBs (e.g., small capacitors,
       fluorescent lighting fixtures) or trace quantities of PCBs (e.g., wastepapers) are
       subject to disposal as municipal  solid  waste but may result in some release to the
       general environment;
 •...    Leaks and spills of still in-service PCBs; and
 •     Illegal disposal of PCBs.

       Although no estimates of emissions of "old" dioxin-like PCBs from reservoir sources
 (i.e., soils and sediments) have been made, the widespread occurrence of PCBs is most
 likely due to the re-release of these compounds from reservoir sources. Sediments act as a
 reservoir whereby dioxin-like PCBs can  become resuspended in the water column and
 volatilize from the water body into the atmosphere. Soils act as a reservoir accumulating
 dioxin-like PCBs from aerial deposition and then reintroducing them to the atmosphere
  ':'".•  •   ' >  : '' ?il»-i, "  .  " ' ''"' .'I; '"I|IJ!  s  ."  ''•'••'•I, ; ' |'."'rl  V  "'"'i1'1",11 "t.',;"'"   'P','••',     •<••.•
 through windblown soil or as vapors. It is reasonable to assume that the quantities of
 dioxin-like PCBs available for, release from reservoir sources are significantly larger than the
 quantities of dioxin-like PCBs available for release from current use and disposal of dioxin-
 like PCB-containing material.
       Insufficient information is currently available to enable a determination as to whether
  ,('•>,: .if1   ',,""  ,'.' ' i ' ie'iiiii ..   ", >.'..'',t:i -,. 'if •,'	>; ' ••'," - i1,'',,ri,,, ij	.„(•,'	:* v ;:« li-r'if "in;!'",:,' i:<. nxii ,' 'S MI,;, ';•,.', "i,  i  ,  ,\ (    .   '  :
 arty significant release of newly formed dioxin-like PCBs is occurring in the United States.
 Unlike CDD/CDFs, PCBs were intentionally manufactured in the United States in large
 quantities from 1929 until production was banned in 1977. Although -no strong evidence
 exists that the dioxin-like PCBs are produced in other than trace quantities as byproducts
  'i ' ,lf I'  . '"    '"!,   " ll'lif't'i   ','.."                                  II       'nil"1,,
 during combustion or chemical processes, most research on formation of dioxin-like
 compounds  has, to date,  focused on CDD/CDFs rather than PCBs. Thus, there are
  >;	•;•  .: •  -  ! m  :  '  '••.-.••*  , >  '           '       >   '   i ,'!   ,n      ;, .;|. •  •,   ••
 currently insufficient empirical data upon which to estimate emission factors  for any
potential source category. Congener-specific measurements in discharges from potential
sources are  needed.
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                          -'  ,               *            .        v            -
 11.2   RELEASES OF COMMERCIAL PCBs
        PCBs were commercially manufactured by the direct batch chlorination of molten
 biphenyl with anhydrous chlorine in the presence of a catalyst, followed by separation and
 purification of the desired chlorinated biphenyl fractions. The degree of chlorination was
 controlled by the chlorine contact time in the reactor.  Commercial PCBs production is
 believed to have been confined to 10 countries. Total PCBs produced worldwide since
               <                   -               •
 1929  (i.e., the first year ,of known production) has been estimated to total 1.5-million
 metric tons. Initially, PCBs were primarily used as dielectric fluids in transformers. After
 World War II, PCBs found steadily increasing use as dielectric fluids in capacitors, as heat-
 conducting fluids in heat exchangers, and as heat-resistant hydraulic fluids in mining
 equipment and vacuum pumps. PCBs also were used in a variety of "open" applications
 (i.e, uses from which PCBs cannot be recollected) including: plasticizers, carbonless copy
 paper, lubricants, inks, laminating agents, impregnating agents, paints, adhesives, waxes,
 additives  in cement and plaster, casting agents, dedusting agents, sealing liquids, fire
 retardants, immersion oils, and  pesticides (DeVoogt and Brinkman, 1989).
       PCBs were manufactured in the United States from 1929  until 1977.  U.S.
 production peaked in 1970 with a volume of 39,000 metric tons. In 1971, Monsanto
 Corporation, the major U.S. producer, voluntarily restricted the sales of PCBs to all
 applications with the exception of "closed electrical systems," and annual production fell to
 18,000 metric tons in 1974.  Monsanto ceased PCB manufacture in mid-1977 and shipped
 the last inventory in October 1977.  Regulations issued by EPA beginning in 1977,
 principally under the Toxic Substances Control Act (TSCA) (40 CFR 761), have strictly
 limited the production, import, use, and disposal of PCBs.  The estimated cumulative
 production and consumption volumes of PCBs in the United States from 1930 to 1975
 were:  635,000 metric tons produced; 1,400 metric tons imported (primarily from Japan,
 Italy, and  France); 568,000 metric tons sold in the United States; and 68,000 metric tons
 exported {Versar, 1976). The reliability of these values is +5 percent and -20 percent
 {Versar, 1976).
       Monsanto Corporation marketed technical grade mixtures of PCBs primarily under
the trade name ArocJor.  The Aroclors are identified by a four-digit numbering code in which
the last two digits indicate the chlorine content by weight percent.  The exception to this
coding scheme is Aroclor 1016, which contains only mono- through hexa-chlorinated

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 congeners with an average chlorine content of 41 percent. From 1957 until 1972,

 Monsanto also manufactured several blends of PCBs and polychlorinated terphenyls (PCTs)
 under the trade names Aroclor 2565 and Aroclor 4465; manufacture and sales volumes are
  ,]["      '" "'  , "i;,"1,  '„   ,  "" ""  , ' „"   '	  ' i',1,	Jl1	~~  , i j , , -" ,'. i '*f"',  , '   \
 not available for these blends.  Listed below are the percentages of total Aroclor production
 during the years 1957 to 1977 by Aroclor mixture as reported by Brown (1994).
  ::;/  .'.  . ... , '  •;,,•;  .'.'., .  ."•;;;  "!  .'  '              1957-1977      ' '.  j
                                             U.S. Production
                    Aroclor                       ..(%)  	
                    1016	   " "	l"2.8g	,
                    1221                          0.96
                    1232                          0.24
  V'i      :.:  •  - i'f!   1242   ,	   ,	P1'76	        .    '.
  ;"  :"    '':/" !::i   1248  '  "       	   	"6.76""""'	
  .::;  '..  --. •'•   ;;:;.•• 1254   ;  ".'         .."    , "".15.73'"".  "_i	
                    1260                         10.61
  :-t  •  •  •;• ••   i't1  ,',126(2..    ;;     ,     ..  '.:.;   ,', p.83	
  . ••:  :,  '   : ,   ' !'i;  : 1268,  ..';', _   i    .  "	  '''" 0.33  .. ;'

           .:• •; ,a;i  '•;' ,•  •.• . •; i  >'•..	::' .-,.••, ;.• :. •• ,; >• .,\\~:	.•!•'.;,••'., •: \'.-. - ,f .  >'  ••'.'!
       The trade names of the major commercial PCB technical grade mixtures
 manufactured in other countries included:  Clophen  (Germany), Fenclor and Apirolio (Italy),
   i'    '•',. "••  i.'                                           i   n      '•'!•..,
 Kanechlor (Japan), Phenoclor and Pyralene (France), Sovtel (USSR), Delor and Delorene
  , "J '   "  , '" '  I',,  , "                                                  ' , '  '' -  ' ' .   , "     ' '
 (Czechoslovakia), and Orophene (German Democratic Republic) (DeVoogt and Brinkman,
 1§89). The mixtures marketed under these trade names had similar chlorine content (by
 weight percent and average number of chlorines per molecule) to those of various Aroclors.
 Listed below are comparable mixtures in terms of chlorine content marketed under several

 trade names.
       Aroclor       Clophen      Pyralene     Phenoclor    Fenclor      Kanechlor
       1232                        2000                                  200
       1242    '"'"'    A-30:'""  ''""."36bS'	"••'"'•'^.-3•••'••'	•"'"•42 "  '     "   300
       1248          A-40                       DP-4                      400
       1254          A-50                       DP-5         54           50°
       1260          A-60                       DP-6         64           600
       Major advances in analytical separation and resolution techniques during the 1980s

and 1990s enabled various researchers to identify and quantify ,PCB congeners present in

Aroclors, Clophens, and  Kanechlors (Albro and Parker, 1979; Huckins et al., 1980; Albro et

al., 1981; Duinke'f" and Hillebrand, 1983; Kannan et al.7 1§87; fanabe et al., 1987; Duinker

                                        11-4                                April 1998

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 et a!., 1988; Schulz et al., 1989; Himberg and Sippola, 1990; Larsen et al., 1992; deBoer
 et al., 1993; and Schwartz et al.,  1993). Schulz et al. (1989) were the first to identify and
 quantify all PCB congeners present in a series of Aroclors and Clophens.  Frame (1995)
 reported preliminary results of a nearly completed round robin study, one goal of which was
 to determine the distribution of all PCB congeners above 0.05 weight percent in various
 Aroclors (1221, 1016, 1242, 1260, and 1262) using  18 state-of-the-art gas
 chromatography/mass spectrometry (GC-MS) or electron  capture detector (GC-ECD)
 systems.
       Table 11-3 presents mean summary statistics on the concentrations of the dioxin-
 like PCBs in each mixture group (i.e., Aroclor 1248, Clbphen A-40, and Kanechlor 400
 comprise one mixture group) reported by these researchers.  Table 11 -3 also presents
 calculation of the corresponding mean TEQ concentration of each congener in each mixture
 group as well as the total mean TEQ concentration in the mixture group.  For each mixture
 group, the congeners detected were generally similar.  There was, however, wide variability
 in the concentrations reported by some researchers for some congeners.  Brown et al.
 (1995) compiled similar statistics using  a somewhat different set of studies and derived
 significantly lower mean concentrations of some congeners in several Aroclors. Frame
 (1995) and Larsen (1995) attribute such differences either to potential limitations in the GC
 columns used by various researchers to separate similar eluting congeners or to actual
 differences in the congener concentrations in the Aroclor, Clophen, and Kanechlor  lots
 analyzed by various research groups.  Because of the wide variability in the reported
 results, the uncertainty associated with the mean concentrations reported in Table 11 -3 is .
 very large.                        '
       In the environment, PCBs also occur as mixtures of congeners, but their composition
 will differ from the commercial mixtures.  This is because after release to the environment,
the composition of PCB mixtures changes over time, through partitioning, chemical
transformation, and preferential bioaccumulation (U.S. EPA, 1996g).  Dioxin-like PCB
 congeners differ by up to one to two orders of magnitude in their water solubilities, vapor
 pressures, Kow values, and Henry's Law constants. Thus, although all the dioxin-like PCB
congeners are poorly soluble  in water and have very low vapor pressures, they will
                   /      •    -          '    -         "            • '
volatilize and leach at different rates.  Similarly, because the congeners differ somewhat in
their rates of biodegradation, bioaccumulation, and photodegradation, the congener
               ' *
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 patterns found in environmental media and biota will vary from those found in commercial
 mixtures.
       Although environmental mixtures are often characterized in terms of Aroclors, this
 characterization can be both imprecise and inappropriate.  Qualitative and quantitative
 erfofs can arise from judgements in comparing GC/MS peaks for a sample with the
 characteristic peak patterns for different Aroclors, particularly for environmentally altered
 patterns {U.S. EPA, 1996g). For the same reason, it can be both imprecise and
   :'':,•'.'  • ...'•.'•,,:.  m I;1  /••';.  '..?:•• ':•&, ::-\! •,>"',•:''j;iii;lh;iJ1Vii:!':i:'>.)J>l.i'ii!w. ;•"'.** i«	"i   'fl ;v  '••  •:     '         •• •
 inappropriate to infer concentrations of dioxin-like PCB congeners in an environmental
 sample based on characterization of the sample's Aroclor content and knowledge of the
 dioxin-like congener content in the commercial Aroclor.  Safe (1994) wrote, "Regulatory
 agencies and environmental scientists have recognized that the composition of PCBs in
 most environmental  extracts does not resemble the compositions of the commercial
 product."  Similarly, ATSDR (1993) stated, "It is important to recognize that the PCBs to
 which people may be exposed are likely to be different from the original PCB source
 because of changes in congener and impurity composition resulting from differential
    'i,,:11  .  ,,   •"  •'•':,  '"'"I'll"1!  I'1 ' / "'", " " ' '".jjiv ',,; ii;"'1 • , ,"" 'i..!,1:',",1"1 ".;!'. "', 'i'11,,«, !• \« ,f'"f«^  ' 'i • .;••"!, ''si,',"'"1!;1""1!1. '"< • •• i!"!:1^1"1!'/111'     •• '•       '•
 partitioning and transformation in the environment and differential  metabolism and
 retention."

 11.2.1.       Approved PCB Disposal/Destruction Methods
       In 197P/ EPA began regulating the disposal of PCBs and PCB-contaminated waste
 under the TSCA, PL 94-469. The disposal regulations^ publishedI in the Code of Federal
 Regulations,  40 CFR, Part 761, state that the preferred disposal method is incineration at
 1,200°C or higher.  If the waste contains material that can not be destroyed by
 incineration,  EPA clearance must be obtained to dispose of the waste in a chemical waste
 landfill, or in  another approved manner.
       The PCB disposal regulations describe disposal  of three distinct types of PCB waste:
 PCBs, PCB articles (i.e., items containing PCBs), and PCB containers. Within these
 categories  of PCB waste, further distinctions are made based on the PCB concentration in
the waste. The acceptable disposal methods are based on the PCB concentrations in the
specific waste to be destroyed. The acceptable disposal methods are:  Annex I
incinerators, high-efficiency boilers, Annex II chemical waste landfills, and other approved
methods.  The foljowing subsections and Table .11 -4 provide brief descriptions of these
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  disposal methods.  More complete descriptions of the specific methodologies are provided
  in the Code of Federal Regulations, 40 CFR, Part 761.
        Approved Incinerators/High Efficiency Boilers - PCB Annex I incinerators must meet
  the specific technical standards and criteria listed in Annex I of EPA's PCB regulations. The
  minimum operating requirements for disposal of liquid wastes are 2 seconds at 1,200°C
  (2,190°F) with 3 percent excess oxygen (measured in the stack gas), or 1.5 seconds at
  1,600°C (2,910°F) and 2 percent excess oxygen (measured in the stack gas).  Monitoring
  requirements, approval conditions, and trial burn requirements are prescribed in Annex I,
  Commercial or industrial incinerators intending to destroy liquid PCB wastes must
  demonstrate compliance with the Annex I requirements through a comprehensive trial burn
  program. Annex I incinerators operating at optimum performance level should destroy
'  99.997 percent of liquid PCB waste with a resulting maximum emission factor of 0.03
  grams per kilogram (g/kg).
        Criteria for Annex I incinerators were established for the destruction of liquid PCB
  wastes;  however, these incinerators also may be used for disposal of nonKquid  PCB items
  (such as capacitors), provided that a destruction and removal efficiency of 99.9999 percent
  and a maximum emission factor of 0.001  g/kg are met.
        High-efficiency boilers may be used to destroy PCBs and PCB-contaminated waste
  with PCB concentrations not exceeding 500 ppm. Conventional industrial and utility boilers
  may be designated as high-efficiency boilers, if they are operated under the prescribed
  combustion conditions defined in the PCB disposal regulations.  The PCB regulations do not
  specify a minimum PCB destruction efficiency for high-efficiency boilers; however, EPA-
  approved boilers operated according to the regulations have reported destruction
  efficiencies in excess of 99.9 percent, with a corresponding emission factor of 0.1 g/kg
  (U.S. EPA, 1987c).
        Approved Chemical Waste Landfills - Approved chemical waste landfills can be used
  for the disposal of some, but not all, PCB wastes.  PCB-contaminated materials acceptable
  for land disposal in an approved landfill include PCB mixtures (e.g., certain PCB-
  contaminated soil/solid debris, PCB-contaminated dredged materials, and PCB-contaminated
  municipal sewage sludge), PCB articles that cannot feasibly be incinerated (e.g., drained
  and flushed transformers), and drained PCB containers. EPA must issue written approval to
  landfill PCB articles other than transformers.  PCB-contaminated materials not acceptable

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                          DRAFT-DO NOT QUOTE OR CITE

 for land disposal in an approved landfill include nonliquid PCB mixtures in the form of
 contaminated soil; rags, or other solid debris, and sealed capacitors.  Typically, PCBs
 disposed in these landfills are placed in sealed containers, thereby, minimizing any PCB
 emissions.      ^     	i     :   _	•
       Other Approved Disposal Methods - Other thermal and nonthermal destruction
 techniques may be approved by EPA Regional Administrators, if these processes can effect
 destruction of PCBs equivalent to that of incinerators or boilers.  Subsequent to April 29,
 1983, all other PCB disposal technologies  (thermal and nonthermal) that are to be used in
 more than one EPA Region must be approved by EPA Headquarters.  Examples of thermal
 technologies approved for commercial-scale use or for research and development projects
 include a pyrolysis process to treat contaminated soils, a fluid wall reactor, a cement kiln, a
 diesel engine, a steam-stripping operation, an aluminum melting furnace, and a molten salt
 process. Examples of approved nonthermal processes include chemical dechlorination
 processes, physical/chemical extraction techniques, and biological reduction methods. The
 physical/chemical techniques extract the PCBs from transformers or capacitors and
 concentrate them for  disposal; they do not destroy the PCBs.
       Emission Estimates - Table 11-5 lists the amounts of PCBs reported in EPA's Toxics
 Release Inventory (TRI) as transferred pffsite for treatment, energy recovery, or disposal
 during the years 1988 through 1993. These quantities do not necessarily represent entry
 of PCBs into the environment.  If it is assumed that ail transferred PCBs are incinerated in
 high-efficiency boilers with a destruction and removal efficiency of 99.99 percent, then
 annual emissions of PCBs to air during 1988 and 1993 could have been as high as 2(3,422
 kg and 4,635 kg, respectively.  Because no stack testing data are available for dioxin-like
 PCBs, it is not possible to estimate what fraction of these potential PCB releases would
 have been the dioxin like congeners.

 11.2.2.      Accidental Releases of In-Service PCBs
   i1' i !'"    '"   '.   Ill              "I     I II  I I   I             II        r     •   •
   	            I          I        ill                           i     :
       EPA banned. PCB production and use in open systems in 1977. Subsequent to the
 1977 ban, releases of cpmmercjajiy produced PCB to the environment (aside from minimal
  "'"',!' ]  '            i          i   i      I  II  II I     I    III I  I  I   II    I       I          •
 releases occurring during approved disposal and/or destruction) have  been limited to   .
accidental release of in-service PCBs (U.S. EPA,  1987c).  Accidental  releases are the result
  :-	 "' •'  	'•', •      Ill          II   I     | I II          I  I	Ill 11       I    -  .      .    .
of leaks or spills during failure/breakage of an existing piece of PCB-containing equipment,
  ;, ' '             I                             '     I     1   II                " '
   ,.                                                II               '
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                          DRAFT-DO NOT QUOTE OR CITE                        '

 or incomplete combustion occurring during accidental fires involving PCB-cbntaining
 equipment. These two types of accidental releases are discussed in this section.
       Leaks and Spiffs - PCBs that remain in active service at this time are those contained
 in "closed system" (i.e., those pieces, of electrical equipment that completely enclose the
 PCBs and do not provide direct atmospheric access of the PCBs during normal use). This
 equipment includes PCB transformers, capacitors, voltage regulators, circuit breakers, and
 reclosures. With the exception of PCB transformers and probably small PCB capacitors, the
 majority of the PCB-containing electrical equipment in-service during 1981 was owned by
 the electrical utility industry. Approximately 70 percent of the estimated 140,000  PCB
 transformers in-service in  1981 were owned by nonutilities.  No information was available
 on the relative distribution of small PCB capacitors (Versar, 1988).
       The number of each of these items owned by the utility industry, the quantity of
 PCBs each contains, and an estimate of the annual quantity of PCBs leaked and/or  spilled
 were investigated by the Edison Electric Institute and the Utility Solid Wastes Activity
 Group (EEI/USWAG) for EPA in 1981. The findings of this investigation were reported in
 the April 22, 1982, Federal Register relative to a proposed modification to the PCB
 regulations (Federal Register, 1f982a). The findings indicated that over 99 percent of the
 total quantity of PCBs contained in utility-owned electrical equipment in 1981 (73,700
 metric tons) were in 40,000 PCB transformers (those containing > 500 ppm of PCBs) and
 large  PCB capacitors (those containing > 3 Ibs of PCBs). An upper bound estimate of the
 mass of PCBs that leached or spilled from this equipment in 1981 was 177  metric tons.
 Approximately 95 percent of the estimated releases were the result of leaks from large PCB
 capacitors (Federal Register, 1982a).  Leaks/spills typically occur in transformers when the
 gasket joining the top to the body corrodes, tears, or physically fails. PCBs  can then leak
 past this failed section and potentially spill onto the surrounding ground.  PCB capacitors
typically fail by rupturing, exposing the contained PCBs to the environment.   Failure is
caused by environmental and weathering effects  (e.g., lightning) or material'failures (e.g.,
metal fatigue).
      As of mid-1988, the total population of in-service PCB transformers and large PCB
capacitors was estimated to have decreased from 140,000 to 110,000 and from 3.3
million to 1.9 million, respectively (Versar,  1988).  PCB transformers  have normal operating
lifetimes of 30 years: and 40 years, respectively.  The  accelerated retirement rate over this
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                              DRAFT-DO JSTOT QUOTE OR CITE

     7-year time period was attributed to EPA's PCB Electrical Use Rule (Federal Register,
     1982b), which required the removal of 950 food/feed industry transformers by 1985 and
     removal of 1.1 -million unrestricted-access large PCB capacitors by October 1 988. In
     addition, EPA's PCB Transformer Fires Rule (Federal Register, 1985b) required the removal
     by 1990 of 7,600 480-volt network transformers. More recent inventories of PCB-
;,.  •  ' ii"!!!1'1 !.  -';.;:,.  yi ':'  iSiii ' .•• •:'•"' '	/jji	,'i1 ,•!>,!  ;*,/:•'•• ,»."JAi ['' "' rWi1 / • ' i.,1 '.\  ::',.  'i'.jf™^1, •  .  !••   •     '•     :•
    'containing electrical equipment are not available.  However, a recent Information Collection
     Request submitted by EPA to the Office of Management and Budget for information on
     uses, locations, and conditions of PCB electrical equipment estimated that  there may be
     150,000 owners of PCB-containing  transformers used in industry, utilities,  government
     buildings, and private buildings (Federal Register, 1997a).  It is expected (and is
     demonstrated by the reported  PCB transfers in TRI - See Table 11-5) that many owners of
     PCB electrical equipment have removed PCB-containing equipment to eliminate potential
     liability.
          The proportion of spilled PCB that enters the atmosphere, runs off to surface water,
   ,,  i«i .;  \ •:. f	 /"Sill!  	„•,',	",:«,!' «:: •	;,  |,'i -.:,! ffci, . ,<(' .,	•• ;	i," <; VI >'• "!••• •:'' ;  iii, '!'•.•'.  'I  '  • •
    or remains in or on the  surface depends on a variety of factors including the porosity of the
            I    ,   .»'!!llf  .i : T  ,  	 il'-;  Hi ,  '""  I, 'i :'i| ">' i'  » • JV " M'   ' I'1-'.)'!	, ',    „	ij,,,,'!,,, - „, r  '!! •"!    ~      '
    surface onto which the PCBs are spilled (concrete, soil), the PCB isomers that are spilled,
     $ .      ", ,'< ••'  f'lfi  i •'•: • ;<:<  •", •:!;.,' ( v. i.  ::;; •.s'ji.;;,: <••*•• "-i: ••  	:'i:<'  i1.1*. ''A&M' •"•••    'i
    ambient conditions (i.e., temperature, wind speed, precipitation), and the cleanup schedule.
    The number and diversity of factors  affecting PCB emissions from spills and leaks make
    estimation of an emission factor difficult. A rough approximation of the annual amount that
    may be released to the  environment from spills and leaks can be made using the release
    data reported by manufacturing facilities to EPA's TRI. Table 11-6 lists the amounts of
    PCBs reported in TRI to be released to the  environment during 1988 through 1993. These
    data include emissions to the air, discharges to bodies of water, releases at the facility to
    land, as well as  contained disposal into underground injection wells.
          Based on these TRI data, annual emissions  of PCBs to air during 1988 and 1993
    could be as high as 2.7 kg and 0 kg, respectively.  For purposes of deriving a preliminary
    rough estimate of potential releases of dioxin-like PCBs, it can be assumed that the ratio of
   TEQ to total PCB in the air emissions was 84:1-million (i.e., the average of the estimated
   mean TEQ contents for  Aroclors 1242 and 1254 presented in Table 11 -3).  Based on this
   assumption, annual emissions of PCB TEQs in 1988 and 1993 could have been  0.2 and 0
   grams, respectively. Similar assumptions for releases to water  listed in Table 11-6 yield
   estimated TEQ emissions during 1988 and  1993 of 0.4 and 0 grams, respectively. For
                                           11-10                                April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

 land, estimated TEQ emissions during 1988 and 1993 could have been 29 and 10 grams,
 respectively.                            .
       Accidental Fires - The available information is not adequate to support an estimate
 of potential annual releases of dioxin-like PCBs from accidental electrical equipment fires.
 For fires involving PCB transformers or capacitors, the amount of PCBs released is
 dependent upon the extensiveness of the fire and the speed at which it is extinguished.  A
 number of these fires are documented.  A New York fire, involving 200 gallons of
 transformer fluid containing some 65 percent by weight PCBs, resulted in a release of up to
 1,300 pounds of PCBs.  A capacitor fire that burned uncontrolled for 2 hours in Sweden
 resulted in the destruction of 12 large utility capacitors containing an estimated 25 pounds
 of PCBs each, for a total potential release of 300 pounds. However, data are incomplete
 on the exact amount of  PCBs released as a result of these two fires.
       EPA has imposed reporting requirements to ensure that the National Response
 Center is informed immediately of fires involving PCB transformers (40 CFR 761).  The
 reeordkeeping requirements are used to  document the  use, location, and condition of PCB
 equipment. Responses are mandatory, but may be claimed by the submitter to be
 confidential information. The annual number of, PCB transformer fires is estimated at
 approximately 20 per year; the number of PCB capacitor fires is unknown (U,S. EPA,
 1987c).  As these PCB items reach the end of their useful lives and  are retired, their
 susceptibility to fires will be eliminated,  and the overall number of PCB transformer and
 capacitor fires will be reduced.

 11.2.3,      Municipal Wastewater Treatment
      EPA conducted the  National Sewage Sludge Survey in 1988 and 1989 to obtain
 national data on sewage sludge quality and management.  As part of this survey, EPA
 analyzed sludges from 175 publicly owned treatment works (POTWs) that employed at
 least secondary wastewater treatment for more than 400 analytes including 7 of the
 Aroclors. Sludges from 19 percent of the POTWs had  detectable levels of at least one of
the following Aroclors: 1248, 1254, or 1260; none of the other Aroclors were detected in
any sample (detection limit was typipally about 200-yug/kg dry weight) (U.S. EPA,  1996a).
Analyses were not performed for dioxin-like PCB congeners.  The Aroclor-^specific results of
the survey are presented in Table 11-7.  Gutenmann et-al. (1994) reported similar results in

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                       ;.  DRAFT-DO NOT QUOTE OR CITE

 a survey of sludges from 16 large U.S. cities for Aroclor 1260 content. At a detection limit
 of 250-/zg/kg (dry weight), GutenmannetaL (1994) detected Arpdpr 1260 at only one
 facility (4,600 /^g/kg). These results indicate that PCBs are not likely to be formed at
 POTWs, but rather are present because of disposal of PCB products or recirculation of
 previously disposed PCB.
       Although PCBs, measured as Aroclors, were not commonly detected in sewage
 sludge at/zg/kg levels by U.S. EPA (1996a) and Gutenmann et al. (1994), the presence of
 dioxin-Iike  PCB congeners at lower concentrations may be more common. Green et al.
 (1995) and Cramer et al. (1995) reported the results of analyses of 99 samples of sewage
 slydge for  PCB congener numbers 77, 126, and 169. The sludge samples were  collected
 from 75 wastewater treatment plants across the United States during the summer of 1994.
 These data are summarized in Table 1.1-8. For the calculation p| results in units  of TEQ,
 results from all samples collected from the same facility were averaged by Green et al.
 (1995) to ensure that results were not biased towards the concentrations found  at facilities
 from which more than one sample were collected. If all nondetected values are  assumed to
 be zero, then the POTW mean and median dioxin-Iike PCB TEQ concentrations were 47.5-
  Ili,:1" 'i"  Jv;	'i11'" iSis;" , • ':	-.,'»,",-'",,!':;»  i	•,•»	»»•;:•/'. n ."Vi .>* 	:iiiK!r	i . •»• i.iji|:,( ,ia,,,.    . ••  .•
 and 22.6-ng TEQ/icg (dry weight basis), respectively (standard deviation of 89.4-ng
 TEQ/kg). If the nondetected values are set equal to the detection limits, then the POTW
 mean and median TEQ concentrations were 48.1- and 23.9-ng TEQ/kg, respectively
 (standard deviation of 89.2-ng TEQ/kg).
       Approximately 5.4-million dry metric tons of sewage sludge are estimated by EPA to
 be generated annually in the United States based on the results of the 1988/1989 EPA
 National Sewage Sludge Survey (Federal'Register, 1993b). Table 11-9 lists the volume of
 sludge disposed annually by use and disposal practices.  Table  11 -9 also lists the estimated
 amount of dipxin:like PCB TEQs that may be present in sewage sludge and potentially be
 released to the environment. These values were estimated using the mean/median (i.e.,
 about 48-ng TEQJk'g) TEQ concentration reported by Green et a\. (1995) and Cramer et al.
 (1995). Multiplying this TEQ concentration by the sludge.volumes generated, yields an
annual potential total release of 200 g of TEQ for nonincinerated sludges.  Of this 200 g of
TEQ, 3.4 grams enter  commerce as a product for distribution and marketing.  The
reminder is applied to land (101.3 grams) or is landfilled (94.8 grams).
                                       11-12                               April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

       These release estimates are assigned a H/M confidence rating indicating "high"
 confidence in the production estimate and "medium" confidence in the emission factor
 estimates. The "medium" rating was based on the judgement that, although the 75
 facilities tested by Green et al. (1995) and Cramer et al. (1995) may be reasonably
 representative of the variability in POTW technologies and sewage characteristics
 nationwide, the sample size was still relatively small, and not all dioxin-like PCB congeners
 were monitored. Based on this confidence rating, the estimated range of potential annual
 emissions is assumed to vary by a factor of 5 between the low and high ends of the range.
 Assuming that the best estimate of annual emission to land (101-g TEQ/yr) is the geometric
 mean of this range, then the range is calculated to be 45.2- to 226-g TEQ/yr. Assuming
 that the best estimate of 3.4-g TEQ annual emissions in product (i.e., the fraction of sludge
 that is distributed and marketed as a product) is the geometric mean of the range, then the
 range is calculated to be 1.5- to 7.5-g TEQ/yr.

 11.3.  CHEMICAL MANUFACTURING AND PROCESSING SOURCES
       In the early  1980s, EPA investigated the extent of inadvertent generation of PCBs
 during the manufacture of synthetic organic chemicals (Hammerstrom, et al., 1985).  For
 example, phthalocyanine dyes and diarylide pigments were reported to contain PCBs in the
 mg/kg range. EPA subsequently issued regulations under TSCA (40 CFR 761.3)  that
 banned the distribution in commerce ;of any products containing an annual average PCB
 concentration of 25 mg/kg (50-mg/kg maximum concentration at any time). In addition,
 EPA required  manufacturers with processes inadvertently generating PCBs and importers of
 products containing inadvertently generated PCBs to report to EPA any process or import
 for which the PCB concentration is greater than 2 mg/kg for any resolvable PCB gas
 chromatographic peak.

 11.4.  COMBUSTION SOURCES
 11.4.1.      Municipal Solid Waste Incineration
       Municipal solid waste incinerators have long been Identified as potential PCB air
emission sources.  Stack gas concentrations of PCBs for three incinerators were  reported in
U.S. EPA (1987c), and the average test results yields an emission factor of 18-/^g PCBs/kg
refuse. Stack gas emissions of PCBs from the three  incinerators were quantified without

                                    •11-13                               April 1998

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                       .   DRAFT-DO NOT QUOTE OR CITE

 determining the incinerator's PCB destruction efficiency.  The PCB content of various
 consumer paper products was analyzed as part of the study.  This study indicates that
 paper products such as magazine covers and paper towels contained up to 139 micrograms
  'j :: h      .      ''i'1:! A,, "          i                   , 'i1:1  l; ...» .'   '" j:1" v'.'...., i'  ' ' .!    ''
 of PCB per kilogram of paper (/zg/kg). These levels, which were reported in 1981, were
 attributed to the repeated recycle of waste paper containing  PCBs.  For example,
 carbonless copy paper manufactured prior to 1971 contained PCB levels  as high as 7
 percent. This copy paper then became a component of waste paper, which was recycled.
   '•i , i   •  i      ;';ifi! ',,••'	j'" '' 'i.'''If '",' iiv  •• : '\.>.v. ..'H./5 ;' ti- t ?;',;•  ;'... '.'I.,  ,":'' ;.;. • v it. .ii,'- , •''•..  |. , .
 The PCBs inevitably were introduced into other paper products, resulting in continued
  .'"..!'    ' '  ;•..  1 .'"' •  :,-'-,!S[^H;E: U1''1	n^t^ii'^ if.?j';.:•>>•'-,• j.1 ^.^,:'••••;!  }••••..•:. •   •••  .  • ,
 measurable levels in municipal refuse some 4 years after the PCB manufacturing ban was
 imposed. Refuse-Derived Fuel (RDF) manufactured from these paper products had PCB
 levels of 8,500 A*g/kg, indicating that this fuel could be a source of atmospheric PCBs.
 Therefore, it was assumed in U.S. EPA (1987c) that municipal refuse does contain
 detectable levels of PCBs, arid that some of these PCBs may enter the atmosphere when
 the refuse is incinerated.
       Shane et al. (1990) analyzed fly ashes from five municipal solid waste (MSW)
 incinerators for PCB congener group content. Total PCB levels ranged  from 99 to 322
jug/kg in these ashes with the tri-, tetra-, and penta-congener groups occurring in the
  :"'s: ,    " "  * •;•' m !;/          11      '   '   i          i     •        :•.!•• .'••   .
 highest concentrations. Shane et al. (1990) also analyzed seveh bottom ashes and eight
  	I ' .  ...   	  '  	I'llMI ,,                        I                         I           **
                I'l'ltJl
            	 II   «!	'I!
bottom ash/fly ash mixtures for total PCB measured as Aroclor 1254. The detection limit
for this Aroclor analysis was 5 /ug/kg. Aroclor 1254 was detected in two of the seven
bottom ash samples (26 and 8 //g/kg) and in five of the eight fJy ash/bottom ash mixtures
(range of 6 to 33 #g/kg).
       The development of more sensitive analytical methodologies has enabled researchers
in recent years to detect dioxin-like PCB congeners in the stack gases and fly ash from full-
scale and pilot-scale MSW incinerators (Sakai et al., 1993a; Sakai et al., 1993b; Boers et
al.j 1993; Schoonenboom et al., 1993; Sakai et al., 1994). Similarly, the advances in
  \']' i   ,, •'      I                                                  • ;j '  ; "
analytical techniques have enabled researchers to determine that dioxin-like PCBs can be
formed during the oxidative  solid combustion phase of incineration presumably due to
dimerization of ch[orobenzenes.,/J..iabprlatpry-slcale studies have also recently demonstrated
that dioxin-like PCBs can be formed from heat treatment of fly ash in air (Schoonenboom et
al., 1993; Sakai et al., 1994).  However, the available data are not  adequate to support
                                        11-14                 .               April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

 development of a quantitative estimate of a dioxin-like PCB emission factor for this source
 category.

 11.4.2.      Industrial Wood Combustion
        Emissions of PCB congener groups, not individual congeners, were measured during
 stack testing of two industrial wood burning facilities by the State of California Air
 Resources Board {CARB, 1990e; 1990f).  Table 11-10 presents the average of the
 congener group (i.e;, mono- through decachlorobiphenyl) emission factors for these two
 facilities. No tetra- or more chlorinated congeners (i.e., the congener groups containing the
 dioxin-like PCBs) were detected at either facility at detection limits corresponding to
 emission factors in the low ng/kg of wood combusted range.
        In CARB (1990e), PCBs were measured in the emissions from two spreader stoker
 wood-fired boilers operated in parallel by an electric utility for generating electricity. The
 exhaust gas stream from each boiler is passed through a dedicated ESP after which the gas
 streams are combined and emitted to the atmosphere through a common stack.  Stack
 tests were conducted both when the facility burned fuels allowed  by existing permits and
 when the facility burned a mixture of permitted fuel supplemented by urban wood waste at
 a ratio of 70:30.
       In CARB (1990f), PCBs were measured in the emissions from twin fluidized bed
 combustors designed to burn  wood chips to generate electricity. The APCD system
 consisted of ammonia injection for controlling nitrogen oxides, and a multiclone and
 electrostatic precipitator for controlling paniculate matter.  During  testing, the  facility
 burned wood wastes and agricultural Wastes allowed by existing permits.

 11.4.3.      Medical Waste Incineration
       As discussed in Section 3.3, EPA recently issued nationally applicable emission
 standards and guidelines for medical waste incinerators (MWI) that address CDD/CDF
 emissions.  Although PCBs are not addressed in these regulations,  the data base of stack
test results at MWIs compiled for this rulemaking does contain limited data on  PCB
congener group emission factors.  Data are available for two MWIs lacking add-on APCD
                    ,          '         '       »    '        -
equipment and for two MWIs with add-on APCD equipment in place. The average
congener group emission factors derived from these test data are presented in  Table 11-11.

                                       11-15                               April 1998

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                            .   DRAFT-DO NOT QUOTE OR CITE

     Because datg are available for only 4 of the estimated 2,400 facilities that comprise this
:'...    , ?"*;„, •"','"  , "•.'  .V , ' i;if  '''» '; - '• .,•:•••'':", !i;i •;,; >	li; ;•' ' i.., " • • ••( *i «l:"! i 1 '••!'.";':" "; >•, ••".' : ":•' .''': < ,: ,£'F." V '•' •.':' ' [  ' •  •  >    '   '  '
     Industry and because these data do not provide congener-specific emission factors, no
'•'•:;  •;  *'!.' '•'.,.., r. ••'•. 'iiiii  :•-•, •l:^3:l:f!^  .':•'.-<••$¥,	livfe'''.•'•'.'.!-*	•'  •.'•••'•'•;; .:i;ii'^ :'••:'   i -.  v,     -
     national estimates of total PCB or dioxin-like PCB emissions are being made at this time.

•':'    11.4,4.,.  ,  , Tire Combustion	r .  ,.    :	 	'  .	  :	  *
           Emissions of PCB congener groups, not individual congeners, were measured during
     stack testing of a tire incinerator by the State  of California  Air Resources Board (CARB,
     1991 a). The facility consists of two excess air furnaces equipped with steam boilers to
,i   . • ..'>!. •;  . t> ;  ....  '  lisi; ...,: ,  ...i,; n •; • f	'.v-';  .!". 	 ;i>;.! .!;•;:. |;i./::,,;;	•;>.-!••.	;:; •',;.. 7'i	r.ir.U'.;.".,". <•;    ]	  ' -.
     recovery the energy from the heat of combustion. Discarded whole tires were fed  to the
     incineration units at rates ranging from 2,800 to 5,700 kg/hr during the  3 testing days.
     The furnaces are equipped to burn natural gas  as  auxiliary fuel. The steam produced from
     the boilers drives electrical turbine generators that produce 14.4  megawatts of electricity.
     The facility is equipped with a dry acid gas scrubber and fabric filter for the control of
      M1; ' ' • ? •' ', '"'"''i;11 ' JHIIiirli  .[	',' '' ,' '. IKi^r,/.!, j',i i' " ..'"' .: lhi."' ,ii, 'I!	y 	 i I'1  ', "",'' .ni.iiiif'H. ,.y '1:1  'r'Hilil" „  ,;ii|,illi:i»',i,	' ' ,' ,  I , ' '. '' ' 'i ' "
     errifssions prior to exiting the stack. Table 11-12 presents the congener group (i.e., mono-
      Illi.1!!'!! v	, :  " r " ' Will1 "i "•','. i" , ,i« 	'-I'*', I	? "ill  " "<• 	 	:  • '" '  - ."•'••' . iVi ' . I .'"..•.'• "!l  : 	ii"	'.. - '  «•   >'   •  i.
     processed.
           EPA estimated^ that approximately 0.50-miilion metric tons of tires were incinerated
      " '   \ '        !	™'   	!.	 ••ii^.   .    .   *	    ...     	_.	
     in1990 in the United States {U.S. EPA,  1992a).  This production estimate is given a
     "medium" confidence rating, because it  is based on both published data  and professional
    judgement.  The use of scrap tires as a fuel increased significantly during the  late 1980s;
     however, no quantitative estimates were provided in U.S. EPA (1992a) for this period. In
     1990,  10.7 percent of the 242-million scrap tires generated were burned for fueh  This
    percentage is expected to continue to increase (U.S. EPA, 1992a).  Of the tires burned for
    energy recovery purposes, pulp and paper facilities used approximately 46 percent; cement
    kilns, 23 percent; and one tire-to-energy facility, 19 percent (U.S. EPA, 1997b).
           If it is assumed that 500-million kg of discarded tires are incinerated annually in the
                                                                    i  •  .•
    United States, then, using the sum of the average emission factors for the total tetra-
    through hepta-chlorinated congener groups (1.2-yug/kg tire processed) derived from stack
    data from the one tested facility, yields a total  emission of 610 g per year. However, it is
    not known what fraction of this emission is dioxin-like PCBs.
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  11.4.5.      Cigarette Smoking
        Using high-resolution mass spectrometry, Matsueda et al. (1994) analyzed tobacco
  from 20 brands of commercially available cigarettes collected in 1992 from Japan, the
  United States, Taiwan/China, the United Kingdom, Germany, and Denmark for the PCB
  congeners 77, 126, and 169. Table 11-13 presents the results of the study.
        However, no studies have been reported which examined the tobacco smoke for the
  presence of these congeners.  Thus, it is not known whether the PCBs present in the
  tobacco are destroyed or volatilized during combustion, or whether PCBs are formed during
  combustion.  The combustion processes operating during cigarette smoking are complex
  and could be used to support either of these potential mechanisms.  As reported by Guerin
                                                                                )
  et ah (1992), during a puff, gas phase temperatures reach 850°C at the core of the
  firecone, and solid phase temperatures reach 800°C at the core and 900°C or greater at
  the char line. Thus, temperatures are sufficient to cause at least some destruction of
  CDD/CDFs initially present in the tobacco.  Both solid and gas phase temperatures rapidly
  decline to 200 to 400°C within 2 mm of the char line. Formation of dioxin-Iike PCBs has
  been reported in combustion studies with other media in this temperature range (Sakai et
  al., 1994). However, it is known that a process likened by Guerin et al.  (1992) to steam
 distillation takes place in the region behind the char line because of high  localized
 concentrations of water and temperatures of 200 to 400°C. At least 1,200 tobacco
v constituents (e.g., nicotine, n-paraffin, some terpenes) are transferred intact from the
 tobacco into the smoke stream by distillation in this area, and it is plausible that PCBs
 present in the unburned tobacco would be subject to similar distillation.
       In 1995, approximately 487-billion cigarettes were consumed in the United States
 and by U.S. Armed Forces personnel stationed overseas. Per-caplta U.S. cigarette
                                         ...•'••     •            (
 consumption in 1995, based on total U.S. population aged 16 and over, declined to 2,415
 from a record high of 4,345 in 1963. In 1987, approximately 575-billion cigarettes were
 consumed domestically (The Tobacco Institute, 1995; USDA, 1997).
       A preliminary rough estimate of potential  emissions of dioxin-Iike PCBs can be made
 using the following assumptions:  (1) the average dioxin-Iike PCB TEQ content of seven
 brands of U.S. cigarettes reported by Matsueda et al. (1994), 0.68 pg/pack (or 0.034
 pg/cigarette) is representative of cigarettes smoked  in the United States; (2) dioxin-Iike
 PCBs are neither formed nor destroyed, and the congener profile reported by Matsueda et

      '                                 11-17                .              April 1998

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                       ...  DRAFT-DO NOT QUOTE OR CITE

  L;,	" jv  /;  ,  i:  , JiUi .'!••.'••  .;. i  "•  , •',', ""!' .•.•'. :••• , i-:!';"'1'  :..•> :.'•.•„ •'.;.• :••.•	«< •• •  • :h' •, '•'••,>. • '  -i    '
 al. (1994) is not altered during combustion of cigarettes; and (3) all dioxin-like PCBs
 contributing to the TEQ are released from the tobacco during smoking.  Based on these
 assumptions, the calculated  annual emissions would be 0.020-9 TEQ and 0.016-g TEQ for
 reference years 1987 and  1995, respectively.
  :• il,   - " . .      'Ivii'Ki  '  "  .,"'"• ,„ '!:''  „ ' ,i , • '''I ''i  ' " i	 , ,  '  ,  , 4   c " | ,,'
 11.4.6.       Sewage Sludge Incineration
       U.S. EPA (1996f) derived an emission factor of 5.4 ^g of total PCBs per kg of dry
  ,Jk	 • •  "'     'III              M                               <<"•.•. ' \~  \:'   '
 sludge incinerated.  This emission factor was based on .measurements conducted at five
 multiple hearth incinerators controlled with wet scrubbers. In 1992, approximately 199
 sewage sludge incineration facilities conbusted b.865-miilion metric tons of dry sewage
 sludge (Federal Register, 1993b). Given this mass of sewage sludge incinerated, the
 estimated  annual release of total PCBs to air annually is 4,670 g.  However, it is not known
 what fraction of this annual emission is dioxin-like PCBs.             '

 11,5. NATURAL SOURCES
 11.5.1.       Biotransformation of Other PCBs
       Biologically mediated  reductive dechJorination under anaerobic conditions to less
 chlorinated congeners followed by slow anaerobic and/or aerobic biodegradation is believed
 to be a major pathway for  destruction of PCBs in the environment.. Research reported to
 date and summarized below indicates that  biodegradation should result in a net decrease
 rather than a net increase in the environmental load of dioxin-like PCBs.
       Laboratory studies (e.g., Bedard et al., 1986; Pardue et al., 1988; Larsson and
 Lemkemeier, 1989; Hickey, 1995; and Schreiner et al., 1995) have revealed that more than
two dozen strains of aerobic  bacteria and fungi, which are capable of degrading most PCB
  ;,VT"', 	 .  'J, ,, .';	 ': ipjiiijljl P,'" I" ,,.'	 I'W!1"!1'1	.; y, , t& ,'"!"! 	 •• ,,; , ;, " rj:',, •.•.ul"l:'.'<>•!*.'!	 -:»  i't \ -'i i!',:"'1, v"':"'", i'.*1'!,^.'^ ";" t  "'./"'Si1 "' ';    '. i1 ' ,
these organisms are of the genus Pseudomonas or the genus Alcajigenes.  The major
  ;,.' „ j, I,,  .   ;	  
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                         DRAFT-DO NOT QUOTE OR CITE

 chlorination. The half-lives for biodegradation of tetra-PCBs in fresh surface water and soil
 are 7 to 60+ days and 12 to 30 days, respectively.  For penta-PCBs and higher chlorinated
 PCBs, the half-lives in fresh surface water and soil are likely to exceed 1 year.  RGBs with
 all or most chlorines on one ring and PCBs with fewer than two chlorines in the ortho
 position tend to degrade more rapidly. For example. Can and Berthouex (1994} monitored
 over a 5-year period the disappearance of PCB congeners applied to soil with sewage
 sludge.  Three of the tetra- and penta-chlorinated dioxin-like PCBs (IUPAC Nos] 77, 105,
 and 118) followed a first-order disappearance model with half-lives ranging from 43 to 69
 months. A hexa-substituted congener {IUPAC No. 167) and a hepta-substituted congener
                                                                  /"
 (IUPAC No.  180) showed no significant loss over the 5-year period.
       Until recent years, little investigation  focused on anaerobic microbial dechlorination
 or degradation of PCBs even though most PCBs eventually accumulate in anaerobic
 sediments (Abramowicz, 1990; Risatti, 1992).  Environmental dechlorination of PCBs via
 losses of meta and para chlorines has been reported in field studies for freshwater,
 estuarine, and marine anaerobic sediments including those from the Acushnet Estuary, the
 Hudson River, the Sheboygan River, New Bedford Harbor, Escambia Bay, Waukegan
 Harbor, the Housatonic River, and Woods Pond (Brown et al., 1987; Rhee et al., 1989; Van
 Dort and Bedard, 1991; Abramowicz, 1990; Bedard et al., 1995; and  Bedard and May,
 1996).  The altered  PCB congener distribution patterns found in these sediments (i.e.,
 different patterns with increasing depth or distance from known sources of PCBs) have
 been interpreted as evidence that bacteria may dechlorinate PCBs in anaerobic sediment.
       Results of laboratory studies reported recently confirm anaerobic degradation of
 PCBs.  Chen et al. (1988) found that "PCs-degrading" bacteria from the Hudson River
 could significantly degrade the mono-, di-, and tri-PCB components of  a 20-ppm Aroclor
 1221  solution within 105 days. These congener groups make up 95 percent of Aroclor
 1221.  No degradation of higher chlorinated congeners (present at 30  ppb or less)  was
 observed, and a separate 40-day experiment with tetra-PCB also showed no degradation.
       Rhee et al. (1989)  reported degradation of mono- to penta-substituted PCBs in
contaminated Hudson.River sediments held under anaerobic conditions in the laboratory (N2
atmosphere) for 6 months,at 25°C.  Amendment of the test samples with biphenyl resulted
in greater loss of PCB. No significant decreases in the concentrations  of the more  highly
chlorinated (i.e., more than five chlorines) were observed.  No evidence of degradation was

                                      11-19                               April 1998

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                             DRAFT-pq NOT QUOTE OR CITE

    observed in samples incubated in CO2/H2 atmospheres. Abramowicz (1990) hypothesized
    that this result could be an indication that, in the absence of CO2, a selection is imposed
    favoring organisms capable of degrading PCBs to .obtain CO2 and/or low molecular weight
    metabolites as electron receptors.
           Risatti (1992) examined the degradation of PCBs at varying concentrations (10,000
    ppm, 1,500 ppm, and  500 ppm) in the laboratory with "PCB-degrading" bacteria from
    Waukegan Harbor. After 9 months of incubation at 22°C, the 500-ppm and 1,500-ppm
    samples showed no change in PCB congener distributions or concentrations, thus indicating
     K'!,  '„  '  '. •	   «,'	m.  i"   ,.,,;,',, i1'" !•:,•;;;;•     i            i  j   i   *        M    '"        •  •
    a Jgck of degradation.  Significant degradation was observed in the 10,000-ppm sediment
     W ,J   - ''-I. .,'"	''  "lili'•"i'1	 '. " -. •" •!(•> .'ii'.i'., ••;          i        i i 1       i       ' ."i • , .  :',     .   .  . •
    with at least 20 congeners ranging from TrCBs to PeCBs showing decreases.
           Quensen et al. (1988)  also demonstrated that microorganisms from PCB-
    cbhtaminated sediments (Hudson River) dechlorinated most tri- through hexa-PCBs in
""',,, I               I         I                                         |
    Aroclor 1242 under anaerobic laboratory conditions. The Aroclor 1242 used to spike the
    sediment contained predominantly tri- and tetra-PCBs (85 mole percent). Three
    concentrations of the Aroclor, corresponding to 14-, 140-, arid 700-ppm on a sediment dry-
    weight basis,  were used.  Dechlorination was most extensive at the 700-ppm test
    conceptrajion; 53 percent of the total chlorine were removed in16 weeks, and the
    proportion of TeCBs through HxCBs decreased from 42 to 4 percent. Much less
    degradation was observed in the 140-ppm sediment, and no observable degradation was
    found in the 14-ppm sediment. These results and those of Risatti  (1992) suggest that the
    organisrn(s) responsible for this dechlorination may require relatively high levels of PCB as a
    terminal electron acceptor to maintain a growing population.
          Quensen et al. (1990) reported that dechlorination of 500-ppm spike concentrations
     ,,. ;!' . 'I    	 •' "'I    "filli'fhl i1?1	  i •  j"1!!	'"	, ill*1	, .1 ", • > i.	 ' i!!;* +• ' , •[. .'Nil;.!', ": ',„'• , ' ,, :,' "	 I:"'1!,;""»!,' I ,• '!' "I ri'ililMii.ii"1^ "    ' '   ,
    of Aroclor 1242, 1248, 1254, and 1260 by microorganisms from PCB:contaminated
    sediments in the Hudson River and Silver Lake occurred primarily at the meta- and para-
    positions; ortho-substituted mono- and di-PQBs increased in concentration.  Significant
    decreases over the up to 50-week incubation period were reported for the following dioxin-
    like PCBs: 156, 167, 170, 180 and 189. Of the four dioxin-like TeCBs and PeCBs detected
    in the Aroclor  spikes (i.e., IUPAC Nos. 77, 105, 114, and 118), all decreased significantly
    in concentration, with the possible exception of PeCB 114 in the Aroclor 1260-spiked
    sediment.
                                             -20                            *  April 1998

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                          DRAFT-DO NOT QUOTE OR CITE

        Nies and Vogel (1990) reported similar results with Hudson River sediments
 incubated anaerobically and enriched with acetone, methanol, or glucose.  Approximately
 30O ppm of Aroclor 1242 (31-mole percent TeCBs, 7-mole percent PeCBs, and 1-mole
 percent HxCBs) were added to the sediments prior to incubation for 22 weeks under an N2
 atmosphere. Significant dechlorination was observed, with dechlorination occurring
 primarily at the meta- and para-positions on the more highly chlorinated congeners (i.e.,
 TeCBs, PeCBs, and HxCBs), resulting in the accumulation of less-chlorinated,  primarily
 ortho-substituted mono- through tri-substituted congeners. No significant dechlorination
 was observed in the control samples (i.e., samples containing no added organic chemical
 substrate and samples that were autoclaved).
      v Bedard and May (1996) also reported similar findings in the sediments  of Woods
 Pond, believed contaminated with Aroclor 1260. Significant decreases in the sediment
 concentrations of PCBs 118, 156,  170, and 180 (relative to their concentrations in Aroclor
 1260) were observed.  No increases or depreases were reported  for the other dioxin-like
 PCBs.
       Bedard et al. (1995) demonstrated that it is possible to stimulate substantial
 microbial dechlorination of the highly chlorinated PCB mixture Aroclor 1260 in situ with a
 single addition of 2,6-dibromobiphenyl. Bedard et al. (1995) added 365 g of 2,6-
 dibromobiphenyl to 6-fpbt diameter submerged caissons containing 400-kg sediment (dry
 weight) and monitored the change in PCB congener concentrations for a period of 1 year.
 At the end of the observation period, the hexa- through mono-chlorinated PCBs decreased
 74 percent in the top of the sediment and 69 percent in the bottom. The average number
 of chlorines per molecule dropped 21 percent from 5.83 to 4.61, with the largest reduction
 observed in meta-chlorines (54 percent reduction) followed by para-chlorines (6 percent).
 The  dechlorination  stimulated by 2,6-dibromobiphenyl selectively removed meta-chlorines
 positioned next to other chlorines.
       The findings of these  latter studies are significant, because removal of  meta- and
 para-chlorines from the dioxin-like PCBs should reduce their toxicity and bioaccumulative
potential and also form less chlorinated congeners that are more  amenable to aerobic
biodegradation.
       Van Dort and Bedard (1991) reported the first experimental demonstration of
biologically-mediated ortho-dechlorination of a PCB and stpichiometric conversion of that

                                       11-21      '                         April 1998

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                       .    DRAFT-DO NQT QUOTE OR CITE

 PCB congener (2,3,5,6-TeCB) to less chlorinated forms... In that study, 2,3,5,6-TeCB was
 incubated under anaerobic conditions with unacclimated methanogenic pond sediment for
  "*\\ .   i  ,  '",",",  tsK't  f: ," , „/	!" .([. it'K ••':•. n v -if: '4; ::•,:;'', I- ;\'-fa.i '• .'« i . •'.', ., ,  •'  :•; .,;ii \" ' '  | '      • .'•   - '
 37 weeks, with reported dechlormation to 2,5-DCB (21  percent); 2,6-DCB (63 percent);
  ii H'  „ •. • ". •  !,mi  " iLiiiii ~  i,'   ,,:, ,	M. i: ,	  ,.  • • ",  :	IK v •• •! • . «•• ',•„ ,•   •  •> ,. * , t. \  ,  .i n . , m .   ,. .  i ,. •
 and 2,3,6-TrCB (16 percent).
  r, „'  '  ' !!  '',,   «  "l'!j.'"|  ! ' "  T ''n||l '„ ,,, ,',,,'  	 •!.',, ^ ;.||  , '!,,. ' '   	,M  , , " ' v "  |, ,/; ,  '  ' '  |

 11.5.2.       Photochemical  Transformation of Other PCBs
  	*'  i "           I'i             "                                '•••'•• '\ .•••'•      .'•'-
       Photolysis and photo-oxidation may be major pathways for destruction of PCBs in
  'V !!"' ' '            I                 I                             \> ,     I    •'""  .
 the environment. Research reported to date and summarized below indicates that ortho-
  ii:,iii'i  i    —'' /': ;  'ii,,-.!!i  ' »;T • : .  i,  '.i,:»iV' u| M, "  r .-'i	|!|1" ,/ ,*.,<>,^	 i  ::>'i'» > « ij*  : •  "|"1' •     '
 substituted chlorines are more susceptible to photolysis than are meta- and para-substituted
 congeners. Thus, photolytic formation of more toxic dioxin-like PCBs may occur.
 Oxidation by hydroxyl radicals, however, apparently occurs preferentially at the  meta- and
 para-positions thus resulting in a net decrease rather than a net increase  in the
 environmental load of dioxin-like PCBs.
  > -   • ', :'' " ': .'   I HI           * j                            I            | '
       Based on the data available in 1983, Leifer et al. (1983) concluded that all PCBs,
 especially the more  highly chlorinated congeners and those that contain two or more
  ii*!: \  '  'i  ' ' .' '  I II"                       I                     I       '! ' '  ' '  ' '
 chlorines in the ortho-position, photodechlorinate.  In general, as the chlorine content
 increases, the photolysis rate increases. More recently, Lepine et al. (1992)  exposed dilute
 solutions  (4 ppm) of Aroclor 1254 in cyclohexane to sunlight for 55 days in December and
 January.  Congener-specific analysis indicated that the amounts of many higher  chlorinated
 congeners, particularly mono-ortho-substituted congeners decreased, while those of some
 lower chlorinated congeners increased.  The results for the dioxin-Jike PCBs indicated a
 43,5 percent decrease in the  amount of PeCB  114; a 73.5 percent decrease in the amount
 of HxCB 156; and a 24.4 percent decrease in the amount of  HxCB 157.  However, TeCB
 77 and PeCB 126 (the most toxic of the dioxin-like PCB congeners), which were not
 detected in unirradiated Aroclor 1254,  represented 2.5 percent and 0.43 percent,
  !"'"'••  '";  ",i '* i!  ••  :\'-''^•.!'£!'•.'•»•:'•  fM-''^'.-'  :•'•'.'•.*<  ••"•il•.•:*:;*  '•   ••;•..  ! '   ;'     ,
 respectively, of the irradiated  mixture.
       With regard to photo-oxidation,  Atkinson (1987) and Leifer et al. (1983), using
 assumed steady-state atmospheric OH  concentrations and measured oxidation rate
  ';;•  .    '"•: '; ;  ii!  !•.•'•. .- /.,';,;,;„'::/ l;1-:l-1,j;;;^;•••.,	4fti^Y''»»<«! •im.M?'  , ':;:'! '  i
constants for biphenyl and monochlorobiphenyl, estimated atmospheric decay rates  and
  i:i,!ixi         '  • ,i,, ',, : r  	::"; :>\  • ,«" ,,'ii1,,,;,;1 ,;	;h:',./':!;:"ii: :|n;» 1,1,iii	"jriiv.'!! I'l1. ".iiii''!:!'!"'!.;!!" '"."i    ' I „
  ;	:i,  '     ,..    : -ii\m .T'-II  • '.' •,...••'',"• :••  	 . • " ':t i1-; n. <^ v t-'r	^••i!i,i,^i(.1 v(r> ;••$	;	hVi      i    i
half-lives for gaseous-phase PCBs.  Atmospheric transformation was estimated to proceed
most rapidly for those PCB congeners containing either a small  number of chlorines or those
containing all or most of the chlorines on one ring.  Kwok et al. (1995) extended the work
         ',  	:ft  ; :-i.'-'  '	 • f.    r   .;;.',:;:•. • .•(!".'• $•'.•• •••• \f\ m	!':;:':!"' .;  'M:'•;•''•  .     '   ." '
      •   •'     •  •;«!  : • i >  . :• :!li   I    '  J ~ • •.  :;,,! o'  '• -"-'t	i''''.^ '{"••• ('"!"V~'''"      i
                                         11-22                                 April 1998

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                         DRAFT-DO NOT QUOTE OR CITE

 of Atkinson (1987) by measuring the OH radical reaction rate constants for 2,2'-, 3,3'-, and
 3,5-dichlorobiphenyl.  These reaction rate constants, when taken together with the
 measurements of Atkinson (1987) for biphenyl and monochlorobiphenyl and the estimation
 method described in Atkinson (1991), were used to generate more reliable estimates of the
 gas-phase OH radical reaction rate constants for the dioxin-like PCBs.  The persistence of
                                                       * v                      /"
 the PCB congeners increases with increasing degree of chlorination. Table 11-14 presents
 these estimated rate constants and the  corresponding tropospheric lifetimes and half-lives. •
       Sedlak and Andren (1991) demonstrated in laboratory studies that OH radicals,
 generated with Fenton's reagent, rapidly oxidized PCBs (i.e., 2-monp-PCB and the DiCBs
 through PeCBs present in Aroclor 1242) in aqueous solutions. The results indicated that
 the reaction occurs via addition of a hydroxyl group to one  nonhalogenated site; reaction
 rates are inversely related to the degree of chlorination of the biphenyl. The results also
 indicated that meta- and para-sites are more reactive than ortho-sites due to stearic
 hindrance effects.  Based uport their kinetic measurements and reported steady-state
 aqueous system OH concentrations or estimates of OH radical production rates,  Sedlak and
Andren (1991) estimated environmental half-lives for dissolved PCBs (mono-through octa-
PCB) in fresh surface water and in cloud water to be 4 to 11 days and 0.1 to 10 days,
respectively.                                                   .
                                         -23
                                                                            April 1 998

-------
              DRAFT-DO NOT QUOTE OR CITE
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          11-25
                                      April 1998

-------
           ,    DRAFT-DO NOT QUOTE OR CITE
Table 11-3. Weight Percent Concentrations of Dioxin-like PCBs in Aroclors, Clophens, and Kanechlors


Dtoxra-Lflce PCS Congener
AROCLOR 1016
3.3',4,4'-TCB
2.3,3',4,4'-PeCB
2,3,4,4'.5-PeCB
2,3',4,4',5-PeCB
2',3,4,4',5-PeCB
3,3',4,4',5-PeCB
2,3,3',4,4',5-HxCB
2,3,3',4,4',5'-HxCB
2,3',4,4',5,5'-HxCB
3,3'.4.4',5,S'-HxCB
2,2',3,3',4,4',5-HpCB
2,2',3,4,4',5,5'-HpCB
2,3.3',4,4',5,S'-HDCB

AROCLOR 1221
3,3%4,4'-TCB
2,3,3' ,4,4'-PeCB
2,3,4,4',5-PttCB
2.3',4,4',5-PeCB
2',3,4,4%5-PcCB
3,3',4,4%5-PeCB
2,3,3*,4,4',S-HxCB
2,3,3',4,4',5'-HxCB
2.3',4,4',5,5'-HxCB
3,3',4.4',5.5'-HxCB
2,2',3,3',4,4',5-HpCB
2^',3,4,4't5,5>-HpCB
2.3,3' ,4,4' .S.S'-HpCB

AROCLOR 1242, Clophen A-30.
and Ktoechlor 300
3,3',4,4'-TCB
2.3,3'.4,4'.PeCB
2,3,4,4',5-PeCB
2,3',4,4',5-PeCB
2%3,4,4',5-PeCB
3.3',4,4',5-PeCB
2,3,3',4,4',5-HxCB
2,3.3',4,41,5'-HxCB
2,3',4.4'^4'-HxCB
3,3',4,4',S.5'-HxCB
2.2',3.3'.4,4'.5-HpCB
2,2',3.4,4'.S,S'-HpCB
2,3,3',4,4'4,5'-HpCB

AROCLOR 1248, Clophen A-40.
«xJKaj*cchJor400
3,3'.4.4'-TCB
2,3,3' .4,4'-PeCB
2.3,4,4',5-PeCB
2,3',4,4',5-PeCB
2',3,4,4',S-PeCB
3,3',4,4',5-PeCB
2,3,3%4,4',5-HxCB
2,3.3',4,4'.5'-HxCB
2.3',4,4',5,5'-HxCB
3,3',4,4',5,5'-HxCB
2,2',3,3',4,4',5-HpCB
2,2'.3.4.4'.S,5'-HpCB
2,3,3',4,41,5,5'-HpCB


IUPAC
Number .

77
105
114
118
123
126
156
157
167
169
170
180
189


77
105
114
118
123
126
156
157
167
169
170
180
189



77
105
114
118
123
126
156
157
167
169
170
180
189



77.
105
114
118
123
126
156
157
167
169
170
180
189

Number of.
Samples
Analyzed

2
1
1
1
1
1
1
1
1
2
1
1
1


1
1
1
1
1
1
1
1
1
1
0
0
1



12
8
5
6
6
11
6
5
5
11
3
2
4



10
6
4
5
4
8
5
4
4
9
2
1
3


Number of
Detections

0
0
0
0
0
0
0
0
0
0
0
0
0


1
0
0
1
0
0
0
0
0
0
—
-
0



12
8
2
6
4
8
5
1
1
2
2
1
0



10
6
3
5
4
6
5
3
2
' 3
2
I
1

Mean Cone.
(ND = 0)
(g/kg>

0
0
0
0
0
0
0
0
0
0
0
0
0
Total TEQ =

4.00
0
0
4.50
0
0
0
0
0
0
-
-
0
Total TEQ =


3.14
3.66
1.55
8.26
1.53
0.06
0.48
0.004
0.004
0.00002
0.38
0.30
0
Total TEQ =


4.56
7.83
5.05 .
20.01
2.12
0.15
1.41
0.33
0.25
0.01
2.05
2.60
0.004
Total TEO =
TEQ Cone.
(ND = 0)
(mg/kg)

0
0
0
0
0
0
0
- 0
0
0
0
0
0
0

2.00
0
0
0.45
0
0
0
0
0
0
~
-
0
2.45


1.57
0.37
0.77
0.83
0.15
6.29
0.24
0.002
0.00004
0.0002
0.04
0.003
0
10.26


2.28
0.78
2.53
2.00
0.21
14.51
0.70
0.16
0.002
0.13
0.21
0.03
0.0004
23.54
Mean Conc.a TEQ Cone.3
(ND = 1/2DL) (ND = 1/2DL)
(g/kg) (mg/kg)

0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
Total TEQ = 0

4.00 2.00
0 0
0 0
4.50 0.45
0 0
0 0
0 0
0 0
0 0
0 0
— —
..
0 0
Total TEQ = 2.45


3.14 ' 1.57
3.66 0.37
1.66 0.83
8.26 0.83
1.58 0.16
0.11 11.29
0.52 0.26
0.11 0.06
0.11 0.00
0.05 0.54
0.46 0.05
0.43 0.004
0 0
Total TEQ = 15.94


4.56 2.28
7.83 0.78
5.06 2.53
20.01 2.00
2.12 . 0.21
0.18 18.26
1.41 , 0.70
0.34 0.17
0.26 0.003
0.05 0.47
2.05 0.21
2.60 0.03
0.10 0.01
Total TEO = 27.65
                               11-26
April 1998

-------
                                             DRAFT-DO NOT QUOTE OR CITE

                      Table 11-3. Weight Percent Concentrations of Dioxin-like PCBs in Aroclors, Clophens, and Kanechlors (continued)

Dioxin-Like PCB Congener
AROCLOR 1254, Cloohen A-50.
and Kanechlor 500
3,3',4,4'-TCB
2,3,3 ',4,4'-PeCB
2,3,4,4', 5-PeCB
2,3',4,4',5-PeCB
2',3,4,4',5-PeCB
3,3',4,4',5-PeCB
2,3,3 ',4,4', 5-HxCB
2,3,3',4,4',5'-HxCB
2,3',4,4',5,51-HxCB
3,3',4,4',5,5'-fLxCB
2,2',3,3',4,4',5-HpCB
2,2',3,4,41,5,5'-HpCB
2,3,3',4,4',5,5'-HpCB

AROCLOR 1260. Cloohen A-60.
and Kanechlor 600
3,3',4,4'-TCB
2,3,3',4,4'-PeCB
2,3,4,4',5-PeCB
2,3',4,4',5-PeCB
2',3,4,4',5-PeCB
3,3',4,4',5-PeCB
2,3,3',4,4',5-HxCB
2,3,3',4,4',5'-HxCB
2,3',4,4',5,5'-HxCB
3,3',4,4',5,5'-HxCB
2,2',3,3',4,4',5-HpCB
2,2',3,4,4',5,5'-HpCB
2(3,3',4,41,5,5'-HpCB


IUPAC
Number


77
105
114
118
123
. 126
156
157
167
169
170
180
189



77
105
114
118
123
126
156
157
167
169
170
180
189

Number of
Samples
Analyzed •


12
9
6
8
5
11
7
6
7
11
5
'4
4



12
8
6
8
5
11
8
5
7
11
5
4
5


Number of
Detections


9
9
3
8
5
9
7
5
6
6
5
4
1



6
8
3
7
1
7
8
5
6
5
5
4
5

Mean Cone.
(ND = 0)
(g/kg)


0.59
26.67
15.98
66.33
5.35
1.23
11.22
1.49
2.47
0.10
5.80
6.63
0.07
Total TEQ =

~
0,16
1.56
1.00
11.14
0.00
2.30
7.53
2.28
3.23
0.21 .
28.98
' 66.30
2.16
Total TEQ =
TEQ Cone.
(ND = 0)


0.30
2.67
7.99
6.63
0.53
122.95
5.61
0.75
0.02 •
1.01
0.58
0.07
0.01
149.12


0.08
0.16
0.50
1.11
0.00
230.22
3.77
1.14
0.03
2.09
2.90
0.66
0.22
242 87
Mean Cone."
(ND = 1/2DL)
(g/kg)


0.64
26.67
;J-
16.08
66.33
5.35
1.26
11.22
1.53
2.47
0.15
5.80
6.63
0.21



0.21
1.56 "•
1.10
11.14
. 0.11
2.33
7.53
2.28
3.23
0.24
28.98
66.30
2.16
Total XEO —
TEQ Cone.3
(ND = 1/2DL)


0.32
2.67
8.04
6.63
0.53
125.68
5.61
0.77
0.02
1.50
0.58
0.07
0.02
152.44

,
0.10
' 0.16
, . ' ' • 0.55
1.11
0.01
233.27
3.77
1.14
0.03
2.37
2.90
0.66
0.22
246 29
          Calculated for a congener only when at least one sample contained detectable levels of .mat congener.

 References:                              ,   - „
 Schuizetal. (1989)
 Duinker and Hillebrand (1983)
 deBoer et al. (1993)
 Schwartz et al. (1993)
 Larsen, et al. (1992)                                     : :
 Kannan et al. (1987)
 Huckins etal. (1980)
 Albro and Parker (1979)                                                             •
 Jensen etal.  (1974)
. Albroetal. (1981)                                   •
 Duinker etal. (1988)
 Tanabeetal. (1987)        •                ,            '
 Himberg and Sippola (1990)      •

 g/kg = grams per kilogram.
 mg/kg = milligrams per kilogram.                                  '
                                                               11-27
                                                                                                                 April 1998

-------
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               11 -28
                                                  April 1998

-------
                       DRAFT-DO NOT QUOTE OR CITE
             Table 11-5. Offsite Transfers of PCBs Reported in TRI (1988-1993)
Year
1993 -
1 992
1991
1990
1989
1988
No. of TRI
Forms Filed
16
20
26
NA
,NA
122
Reported Transfers (kg)
Transfers
to POTWs
120
0
0
0
0.5
113
Transfers for
Treatment/
Disposal
463,385
766,638
402,535
1,181,961
2,002,237
2,642,133
TOTAL
TRANSFERS
463,505
766,638
402,535
1,181,961
2,002,237
2 642 246
kg = kilograms.

POTWs = publicly-owned treatment works.


Sources: U.S. EPA (1993h); U.S. EPA (1995g)
        i •                   •  .

NA = Not available.
                                      11-29
                                                                    April 1998

-------
        DRAFT-DO NOT QUOTE OR CITE
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-------
                        DRAFT-DO NOT QUOTE OR CITE
  Table 11-7.  Aroclor Concentrations Measured in EPA's National Sewage Sludge Survey
Aroclor
1016
1221
1 232
1242
1248
1254
1260
Any Aroclor (total)
Percent
Detected
0
0
0
0
9
8
10
19
Maximum
Concentration
(ng/kg)
—
'
• • __'
__
5.20
9.35
4.01
14.7
Median Concentration (ng/kg)
Nondetects
Set to
Det. Limit

—
„
~
0.209
0.209
0.209
1 .49
Nondetects
Set to
Zero
0
0
0
0
0
0
0
0
Source: U.S. EPA (1996a); for POTWs with multiple samples, the pollutant concentrations
were averaged before the summary statistics presented in the table were calculated.  All
concentrations are in units of nanograms per kilogram (ng/kg) dry weight.
                                     11-31
                                                                        April 1998

-------
                       DRAFT-DO NOT QUOTE OR CITE
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                                       11-32
          April 1998

-------
                           DRAFT-DO NOT QUOTE OR CITE
                  Table 11-9. Quantity of Sewage Sludge Disposed Annually by
                      Primary, Secondary, or Advanced Treatment POTWs
                          and Potential Dioxin-Like PCB TEQ Releases
Use/Disposal Practice
Land Application
Distribution and Marketing
Surface Disposal Site/Other
Sewage Sludge Landfill
Co-Disposal Landfills3
Sludge Incinerators and Co-
Incinerators1'
Ocean Disposal
TOTAL
Volume Disposed
(thousands of dry metric
tons/year)
1,714
71
396
157
1,819
865
(336)d
5,357
Percent of
Total
Volume
32.0e
1.3
7.4
2.9
33.9
16.1 '
(6.3)d
100.0
Potential TEQ
Release0
(gofTEQ/yr)
82.3
3.4
19.0
7.5
87.3
(f)
(0)d
199 5
a
b
c
     Landfills used for disposal of sewage sludge and solid waste residuals.
     Co-incinerators treat sewage sludge in combination with other combustible waste materials.
     Potential PCB TEQ release for nonincinerated sludges was estimated by multiplying the sludge
     volume generated (i.e., column 2) by the average of the mean dioxin TEQ concentrations in
     sludge reported by Green et al. (1995) and Cramer et al. (1995) (i.e., 48:ng TEQ/kg).
d    The Ocean Dumping Ban Act of 1988 generally prohibited the dumping of sewage sludge into
     the ocean  after December 31, 1991. Ocean dumping of sewage sludge ended in June 1992
     (Federal Register, 1993b).  The current method of disposal of the 336,000 metric tons of
     sewage sludge that were disposed in the oceans in 1988 has not  been determined.
e    Includes 21.9 percent applied to agricultural land, 2.8 percent applied as compost, 0.6 percent
     applied to  forestry land, 3.1 percent applied to "public contact" land, 1.2 percent applied to
     reclamation sites, and 2.4 percent applied in undefined settings.
f    See Section 11.4.6 for for a discussion of dioxin-like PCB releases to air from sewage sludge
     incinerators.                     ;

Sources: Federal Register (1990); Federal Register (1993b);  Green  et al. (1995); Cramer et al.
(1995).
                                          11-33
                                                                                 April 1998

-------
                         DRAFT-DO NOT QUOTE OR CITE
       Table 11-10, PCB Congener Group Emission Factors for Industrial Wood Combustors
Congener Group
Monochlorobiphenyls
Dichlorobiphenyls .
Trichlorobiphenyls
Tetrachlorobiphenyls
Pentachlorobiphenyls
Hexachlorobiphenyls
Heptachlorobiphenyls
Octachlorobiphenyls
Nonachlorobiphenyls
Decachlorobiphenyls
Number
of
Sites
2
2
2
2
2
2
2
2
2
2
Number
of
Detections
1
1
1
0
0
0
0
0
0
0
Maximum
Concentration
Detected
(ng/kg wood)
32.1
23.0
19.7
•
	
	
	
	
	
—
Mean Concentration
(ng/kg)
Nondetects
Set to
Det. Limit
39.4
50.9
42.3
22.7
17.6
17.0-
17.9
15.8
25.0
36.3
Nondetects
Set to
Zero
16.0
11.5
9.8
..
__
»«.
_„
-„
...
...
ng/kg = nanograms per kilogram.
  i'1"'" I' >.    , ,.i  . ,  ',:,iH"P!|i'|    .1,,
Source: CARB (1990e; 1990f)
                                       11-34
                                                                           April 1998

-------
                          DRAFT-DO NOT QUOTE OR CITE
     Table 11-11. PCB Congener Group Emission Factors for Medical Waste Incinerators {MWIs)
Congener Group
Monochlorobiphenyls
Dichlorobiphenyls
TrichlOrobiphenyls
Tetrachlorobiphenyls
Pentachlorobiphenyls
Hexachlorobiphenyls
Heptachlorobiphenyls
Octachlorobiphenyls
Nonachlorobiphenyls
Decachlorobiphenyls
Mean Emission Factor (ng/kg)
(2 MWIs without APCD)
Nondetects
Set to
Det. Limit :
0.059
0.083
0.155
4.377
2.938
0.238
0.155
0.238
0.155
0.155
Nondetects
Set to
Zero
0.059
0.083
0.155
4.377
2.938
0.238
0.155
0.238
0.155
0.155
Mean Emission Factor (ng/kg)
(2 MWIs with APCD)
Nondetects
Set to
Det. Limit
0.311
0.340
0.348
1.171
17.096
1 .286
0.902
0.205
__
0.1 17
Nondetects
Set to
Zero
0
0
0
0
9.996
1.078
0
0

0
 APCD = Air Pollution Control Device
 ng/kg = nanograms per kilogram!
'— =' Not reported.

 Source: See Section 3.3 for details on tested facilities.
                                        11-35
                                                                             April 1998

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                        DRAFT-DO NOT QUOTE OR CITE
           Table,11-12.  PCB Congener Group Emission Factors for a Tire Combustor
Congener Group
Monochlorobiphenyls
Dichlorofaiphenyls
Trichlorobiphenyls
Tetrachlorofaiphenyls
Pentachlorobiphenyls
Hexachlorobiphenyls
Heptachlorobiphenyls
Octachlorobiphenyls
Nonachlorobiphenyls
Decachlorobiphenyls
Number
of
Samples
3
3
3
3
3
3
3 .
3
3
3
Number
of
Detections
0
1
1
0
2
1
1
0
0
0
Maximum
Concentration
Detected
(ng/kg)
—
34.8
29.5
„
2,724
106.5
298.6
	
	
—
Mean Emission Factor
(ng/kg)
"Noridetects
Set to
Det. Limit
0.04
11.7
11.8
10.0
1,092
55.9
107.7
20.9
17.7
41.9
Nondetects
Set to
Zero
-
- 11.6
9.8
...
1,092
35.5
99.5
_
_
--
ng/kg = nanograms per kilogram.



Source: CARB {1991 a)
                                     11-36
                                                                        April 1998

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                                                             April 1998

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                          DRAFT-DO NOT QUOTE OR CITE


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       "80-197.™  '".  /  ...... ;  .".;    ..',..."....,..!..'!'.',"!,'  , V...," ......... ",  .  ..,   !   .    ,    . .   . '
   III  i  ' ' , i1 •.'''  'iiiiitil ' k ><•   :'••'.• , ji'.'J.. j,;'! '" . "' i :ii  ; j.'.'.ilhi'1 :'.'. iVKi,'1 ...... T' ' 'i'li':' " .'•  :'';<•' ' llil -'I'v; ,i    i1'     ,   , ' '  -
  Federal Register  (1 979)  Decision and emergency order suspending registrations for certain
   ''     uses of £4,5-T and Silvex.  ^

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  "'       "''             """      '" "' ..... '' .......... ..... ..... ' ...... "" "" ....... '
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        distribution in cprnmerce and use prohibitions; use in electrical equipment.  F.R.
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 Federal Register (1 985a)  Regulation of fuels and fuel additives; Gasoline lead content: final
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        9408.

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        registrations.  F.R. (January 2) 52:140-148.

 Federal Register (1987b)  Final determination and intent to cancel and deny applications for
        registrations of pesticide products containing pentachlorophenol  (including but not
        limited to its salts and esters) for non-wood uses'.'  F.R. (January 21) 52:2282-2293.

 Federal Register {1987c) Polyhalogenated dibenzo-p-dioxins/dibenzofurans; testing and
        reporting requirements; final rule. F.R. (June 5)  52:21412-21452.

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        47856.
  vV  '",",,,.'-  ;:	,  ii'ijjiJ! , ..,,. !,..', •,, ""i.,.:;;,  i'i'.v •.;.'';;',:. ,J.f. '»• j-,.;;'.,!.[«' }',,, ';\,\	i, !•.•:'<" |!:, ,'.>. .5?';, r/ ,;   !"'•'•'  ,"
 Federal Register (1990) National sewage sludge survey: availability of  information and
  *!•, |  (i , ,, /   :'" i ', iii'mi'lBII i, '' .I11"'!1!!11	 'it „,• '''"' i ' I'M!.. '''. "V,1 ii!!'1! 'i ' '"'i.l I'1'!' '"",i,:i /fii1'11	"i I • n i1"^!1 iii'ini, ii. '!. ' I",ill!1:	MT, *	11,.>;	i	,, r	" n'linimiiiiiLii1;	'i*• . ,  ? f    ' .;•
        data, and anticipated impacts on proposed regulation. F.R. (November 9)
        55:47210-47283,
"  'i'1"!!'!' i "    i   , „  i .'"fliii!1 ' ;. . i1 " '"• ' •' '.,», ',„   n" :i i                ill     in  j,      . i  i

 Federal Register (1991 a) Standards of performance for  new stationary sources and final
        guidelines for municipal waste combustors. F.R.  (February 11) 56:5488-5527.
                                          R-1P

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                          DRAFT-DO NOT QUOTE OR CITE


  Federal Register (1991 b) Standards of performance for new stationary sources and
        guidelines for control of existing sources:  municipal solid waste landfills: proposed
        rule and guideline. F.R. (May 30) 56:24468.

  Federal Register (1991 c) F.R. (February 21) 56:7134.

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        significant new use of a chemical substance. F.R. (May 12). 58:27980-27986.

  Federal Register (1993b)  Standards for the use or disposal of sewage sludge- final rules
        F.R. (February 19) 58:9248-9404.                                  •

  Federal Register (1993c) Chemicals; toxic chemical release reporting; community right-to-
        know; significant  new use rule.  F.R. (December 1)58:63500-63518.

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        guidelines for control of existing sources: municipal solid waste landfills  F R (June
        21)  58:33790-33792.

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       and emission guidelines for existing sources: medical waste incinerators  F R
        (February 27) 60:10654-010691.

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     .  of hazardous waste: petroleum refining process wastes; land disposal restrictions
       for newly identified wastes; and CERCLA hazardous substance designation and
       reportable quantities.  F.R. (November 20) 60:57747-57800.

 Federal Register (1995c)  National emission standards for hazardous air pollutants from
       secondary lead smelting:  final rule.  F^R. (June 23) 60:32587-32601.

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       (NESHAP); secondary lead smelters; PVC in feedstock: proposed rule; amendments
       F.R. (April 19) 60:19556.

 Federal Register (1995e) Standards of performance for new stationary sources and
       emission guidelines for existing sources:  municipal waste combustors, final rule.
       F.R. (December 19) 60:65387-65436.

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       guidelines for control of existing sources: municipal solid waste landfills:  final rule
       and guideline.  F.R. (March 12) 61:9905-9944.

Federal Register (1996b) Revised standards for hazardous waste combustors: proposed
       rule. F.R.  (April 19) 61: 17357-17536.

Federal Register  (1997a)  Toxic chemicals;  PGBs; submission of IRC No. 1000 to OMB;
       information collection activities.  F.R. (January 21) 62:3035-3036.


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                          DRAFT-DO NOT QUOTE OR CITE
                    J             i

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                          DRAFT-DO NOT QUOTE OR CITE


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             *                                                       "
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                                    /;,   R-22      ,	   ^ •  ,.   	,           April 1998

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                          DRAFT-DO NOT QUOTE OR CITE


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       i                            •                          •              .

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                       .                R'23                               April 1998

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       Cincinnati, OH:  Center for Environmental Research information.  EPA/625/4-
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 U.S. Environmental Protection Agency  (1992a) Markets for scrap tires. Washington,  DC:
       Office of Solid Waste arid Emergency Response. EPA/530-SW-90-074A.

 U.S. Enyirqnrnenlgl Protection Agency  (1992b) Industry agrees to switch to low-dioxin
       chloranil from contaminated chloranil.  Chemicals in Progress Bulletin 12(2):23.  ,

 U.S. Environmental Protection Agency  (1992c) 1990 National census of pulp, paper,  and
       paperboard manufacturing facilities.  Response to 308 questionnaire. Part A:
       Technical Information, Washington, DC: Office of Water.
  HI , H. ,  n ' ',,    „ '"  ,,,,i i	infill'1!1! • , •   i"   i ' " ,,, "• ',„ • 'iHil'"1 i,,.:i' I;,1; . 'I'll.11, ',,"r' '"'./"i!!1,,:1 „ '! \|i i ', '	!": 	i'i,!'' !'• : , '	f ';;"' '  'In 'JT ! "",   ,   I

 U.S. Environmental Protection Agency (1992d) Economic impact and preliminary regulatory
       impact analysis for proposed MACT-based emission standards and guidelines for
       municipal wastecbmbustgrs. Research TrianglePark, 8VIC: Off ice of Air Quality
       Planning and Standards. EPA-450/3-91-029.

 U,S. Environmental Protection Agency  (1992e) Secondary lead smelter emission test
       report, East Penn Manufacturing, Lyon Station, Pennsylvania.  Research Triangle
       Park, NC: Office of Air Quality Planning and Standards, Emission Measurement
       Branch. EMB Report No. 92-SLS-3.
  : ' '     i> " :"'.  i:'w '!';     ,:•  .""  :;;,   ,=;; v :-,"-j':i',"..  :.":.,",.;.. ,  '•,.,:. "-:•, '.:   . :*'";:!      r
   /,  i     :  -;   .aji: ';,,	i-, .vi.'i |i) Jin, •''. ;•, •'..'; Mci'ii,:-,,"	•. vx:'.";/7  ,'rs '•*•'{.'• •   " :!i >•:,*	 ' •'  si ;
 U.S. Environmental Protection Agency  (1993a) 1992 Needs survey report to Congress.
       Washington, DC: Office of Water.  EPA-832-R-93-002.

 U.S. Environmental Protection Agency  (1993b) States support efforts on forming
       voluntary agreement on pulp and paper mill sludge!  Chemicals in Progress Bulletin
  ':=  y 14(3):2Q.   ,   . ,V  "]'.'  '  ,..  ..'.'''.!.'"!' ."  .7! "  "' ..'  '..'.,.'.	, !     '  .'
  :	.Si- ]',   "'"'  '',':.  fill ,!,,'-,. •"! •'" -.'iv' i-ilS:;' i! •':,.»;; :'^.f" .';.:.i*':- ;i;'!;i-;  y,"l ,,'!':'..if.:'~.  -lii"'":'1''1  •••  ; "\ ...   •'
 U.S. Environmental Protection Agency  (1993c) EPA publishes proposed rule for chloranil.
  ;!|il;' '     <  . ;, '   	S5T !•• i,  !,;:"!,„ f.' .,..' ''	-S 	 ' , , .,	; 	 .•..  	' 	  .  'R> .,. ,: ..-,•,>. 	, mi,-,  ". • .:", i .  .
       Chemicals in Progress Bulletin 14(2):26.
                         ,i, ', '„,,,„IT1,,, ' I'll1"	i
U.S. Environmental Protection Agency (1993d)  Development document for proposed
       effluent limitations guidelines and standards for the pulp, paper and paperboard point
       source catlgdryl  Washington, DC: Office of Water EPA-821-R-93-019.
  11    „  i. '  '    i1,!,11!'1!!;!.'!  'ii.  •  '  i  . ',  »' ,: ,  ,,i! ,' 	i| ' '!,', i,1,, i ,. ,,!„ : .."'.'	i, ti U'T	Wl '/ ,.!«!' ,• .'JW.Ii,:!!1 . , ' "' • . ' •  I ,
U.S, Environmental Protection Agency  (1993e) Economic analysis of impacts of integrated
       air/water regulations for the pulp and paper industry on disposal of wastewater
  ,,' |!i , '  •   ''  '  '  Him ,, »i,  , ,< 	,  i,:.i v, a  'i  , ,«!	 ,,i ",;i	«,!i " !L !' UK, "iv'„,I1 M, , ;:i'.!",'i i[il'i1 J|	"hi>,li'ill, 'in '<	ii "H"'  'I'1	•	H1 Jlr "I' '"I   " ..' I
       sludge. Washington, DC: Office of Pollution Prevention and Toxics, Regulatory
       Impacts Branch.

U.S. Environmental Protection Agency  (1993f)  Press advisory: EPA terminates special
       review of non-wood pesticide uses of pentachlorophenol.  Washington, DC:  Office
       of Pesticide Programs. January 8, 1993.
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 U.S. Environmental Protection Agency (1993g) Report to Congress on cement kiln dust:
        Washington, DC: Office of Solid Waste.  December 1993.

 U.S. Environmental Protection Agency (1993h) 1991 Toxics release inventory - public
        data release. Washington, DC: Office of Pollution Prevention and Toxics  EPA-
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 U.S. Environmental Protection Agency (1994a) Secondary lead smelting industry:
        background information document for proposed standards.  Final report.  Research,
        Triangle Park, NC: Office of Air Quality Planning and Standards.  EPA-450/R-94-
        024.

 U.S. Environmental Protection Agency (1994b) Pesticide industry sales and usage: 1992
        and 1993 market estimates.  Washington, DC: Office of Prevention, Pesticides and
        Toxic Substances. EPA 733-K-94-001.

 U.S. Environmental Protection Agency (1994c)  Medical waste incinerators background
        information for proposed standards and guidelines:  Industry profile report for new
        and existing facilities.  Research Triangle Park, NC: Office of Air Quality Planning
        and Standards.  EPA-453/R-94-042a.

 U.S. Environmental Protection Agency (1994d)  Medical  waste incinerators-background
       information for proposed standards and guidelines: Environmental impacts report for
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       Planning and Standards. EPA-453/R-94-046a.

 U.S. Environmental Protection Agency (1994e)  Universe of hazardous waste combustion
       facilities.  Washington, DC:  Office of Solid Waste and Emergency Response  EPA-
       530-F-94-030.

 U.S. Environmental Protection Agency (1994f)  Combustion emissions technical resource
       document (CETRED).  Washington, DC:  Office of Solid Waste and Emergency
       Response.  Draft Report. EPA/530-R-94-014.

 U.S. Environmental Protection Agency (1995a)  SRRD's  dioxin/furan status report.
       Washington, DC: Office of Pesticide Programs, Special Review and Reregistration
       Division. September 12, 1995.

U.S. Environmental Protection Agency  (1995b)  Compilation of air pollutant emission
       factors. 5th edition. Research Triangle Park, NC:  Office of Air Quality Planning and
       Standards.

U.S. Environmental Protection Agency  (1995c)  Locating and estimating air emissions from
       sources of dioxins and furans.  Draft final report.  Research Triangle Park, NC:
       Office of Air Quality Planning and Standards.  Contract No. 68-D2-0160.
                                       R'33                               April 1998

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                                     DRAFT-DO NOT QUOTE OR CITE
                                        i t'Si!1-"
            U.S. Environmental Protection Agency (1995d)  Final emission test report, HAP emission
                   testing on selected sources at a secondary lead smelter, Tejas Resources, Inc.,
                   Terrell, Texas. Research Triangle Park, NC:  Office of Air Quality Planning and
                   Standards, Emission Measure'ment Branch.  EMB Report No. 93-SLS-1 .
              j'ifi '  ;„'" ' "'! ™ ,! ;'  , ...... .  s1::1::,!! "" ' ...... /         I   i              > /!:>  of -.; " .' • . nfi, ,: ? V  :'   \    \ •      ,  >• j
            U.S. Environmental Protection Agency (1 995e)  Final emission test report, HAP emission
                   testing on selected sources at a secondary lead smelter, Schuylkill Metals
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                   Plannipg and Standards, Emission Measurement Branch.  EMB Report No. 93-SLS-2.
              "if!- .'/ .. •. "*"•.:••  v...,  it in             ii        1 1          I     ill   i     I', •''.;'.,•!'.
            U.S. Environmental Protection Agency (1995f)  An SAB report: A second look at dioxin.
                   Review of the Office of Research and Development's reassessment of dioxin and
                   dioxin-like compounds by the Dioxin Reassessment Review  Committee.  Science
                   Advisory Board (1460) September 'fSfd'Si  EPA:SAB-EC-95-()2l .

            U.S. Environmental Protection Agency (1995g)  199i3 Toxics release inventory - public
                   data release. Washington, DC:  Office of Pollution Prevention and Toxics.  EPA-
                               '   "                         '       '
            U.S. Environmental Protection Agency  (1995h) Secondary aluminum plant emission test
                  report:  Rochester Aluminum Smelting Corporation. Research Triangle Park, NC:
                  Office of Air Quality Planning and Standards. EMC Report 95-SAL-01.

            U.S. Environmental Protection Agency  (1996a) Percentile estimates used to develop the
                  list of pollutants for round two of the Part 503 Regulation.  Washington, DC: Office
                  of Science and Technology.  EPA Contract No. 68-C4-0046.
1 ||| i  / . •   ,li,     ,„;;]!'  i  i , • '';• ''in,!,,!  " f |'!i ill,,) I  '' ''',' '  ,( l! Si!,",,' ,'", i I'lyi'1 Mfti*  i',	 ,	'i M ,»' 	 , 'i',,,, "i • i" II..IH i,« i 	iii" i ,, ii  , 	 , i.iii .', 11 if	  i  i

            U.S. Environmental Protection Agency  (1996b) Municipal solid waste factbook, version
                  3.0. Wasnlngton, DC: Office of Solid Waste.

            U.S. Environmental Protection Agency  (1996c) EPA OSW hazardous waste combustion
                  data base.  Washington, DC: U.S. EPA, Office of Solid Waste.

            U.S. Environmental Protection Agency  (1996d) National dioxin emission estimates from
                  municipal waste combustors. Research Triangle Park, NC:  U.S. EPA, Office of Air
                  Quality Planning and Standards. June 1996.

            U.S. Environmental Protection Agency  (1996e) National dioxin emissions from medical
                  wastei incinerators.  Research Triangle Park, NC:  Office of Air Quality Planning and
                  Standards. Docket #A-91-61, Item IV-A-007.

            U.S. Environmental Protection Agency  (1996f)  Emissions inventory of Section 112(c)(6)
                  pollutants:  polycyclic organic matter (POM), 2,3,7,8-tetrachiprodibenzo-p-dioxin
                  {TCbDJ^^S^jS-tetrachlorodibenzofuran IJQQP^  pojychlorinated biphenyl
                  compounds (PCBsj,  hexachlorobenzene, mercury, and alkylated lead.  Research
                  Triangle Park,  NC: Office of Air Quality Planning and Standards.  September  1996.
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  U.S. Environmental Protection Agency  (1996g)  PCBs: Cancer dose-response assessment
        and application to environmental mixtures.  Washington, D.C.: Office, of Research
        and Development.  EPA/600/P-96/001.

  U.S. Environmental Protection Agency  (1996h)  Draft technical support document for
        hazardous waste combustpr MACT standards.  Volume I: Description of source
        categories. Washington, DC:  Office of Solid Waste and Emergency Response.
        February 199,6.

  U.S. Environmental Protection Agency  (1997a)  Pesticide industry sales and usage:  1994
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 U.S. Environmental Protection Agency (1997c)  1996 Clean Water Needs Survey Report to
        Congress. Washington, DC:  Office of Water.

 U.S. Environmental Protection Agency (1997d)  Draft technical support document for
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       Emergency Response.  April 1997.

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       1                                                                    \
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''" !'"     I'SI'lf ' 'I  ,l'  '' ,'l""   ' ' ' '  1.1*'III1  I ! ',  '"Illll                                    I      '1,1
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;.:>   •  i	  •  ', .. i        ill                      I                    I     > .,  I   > '  ,   •
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                                           R-36                               April 1998
                                            '•'• •'•''' • •  •'' :"; •'  •     ••'   '              •

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                          DRAFT-DO NOT QUOTE OR CITE


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       25(12):1889-1895.
                                                                         -April 1998

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                         DRAFT-DO NOT QUOTE OR CITE
Williams, 'C.H.; Prescott, C.L.; Stewart, P.B.; Choudhary, G. (1985)  Formation of
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  ,!!"' I!     " , , '  '    •;„ ,     „     , ,     ,   *   ,  , ,' ......  ......   ,   ......      ,        .  ,
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                •li! " .
                	I
                                         R-38
April 1998

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