Great Lakes Binational Toxics Strategy
Report for External Review
PCDD (DIOXINS) AND PCDF (FURANS):
REDUCTION OPTIONS
Prepared for
U.S. EPA
Great Lakes National Program Office
Contract # 68-W-99-033
Prepared by
Battelle
SEPTEMBER 27,2000
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
U.S. EPA DISCLAIMER
This report was prepared under contract to an agency of the United States Government.
Neither the United States Government nor any of its employees, contractors, subcontractors, or their
employees makes any warranty, expressed or implied, or assumes any legal liability of responsibility for
any third parry's use of the results of or the results of such use of any information, apparatus, product,
or process disclosed in this report, or represents that its use by such third party would not infringe on
privately owned rights.
Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
BATTELLE DISCLAIMER
This is a report of research performed for the United States Government by Battelle. Because
of the uncertainties inherent in experimental or research work, Battelle assumes no responsibility or
liability for any consequences of use, misuse, inability to use, or reliance upon the information contained
herein, beyond any express obligations embodied in the governing written agreement between Battelle
and the United States Government.
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
TABLE OF CONTENTS
Page
1.0 INTRODUCTION AND REPORT OVERVIEW 1
2.0 BACKGROUND INFORMATION ON DIOXINS/FURANS 3
2.1 CHEMICAL DESCRIPTION AND HEALTH EFFECTS OF DIOXINS/FURANS 3
2.2 DIOXINS/FURANS SOURCES AND RELEASES OVERVIEW 4
2.3 SUMMARY OF EFFORTS TO CONTROL DIOXIN/FURAN RELEASES 7
3.0 IDENTIFYING DIOXIN/FURAN REDUCTION OPPORTUNITIES 9
3.1 DESCRIPTION OF THE GLBTS WORKGROUP'S SECTOR ANALYSIS
PROCESS FOR IDENTIFYING OPTIONS 9
3.2 FINDINGS OF THE SECTOR ANALYSIS 12
3.2.1 Municipal Waste Combustion (MWC) and Medical
Waste Incineration (MWI) 13
3.2.2 Backyard Trash / Open Burning 16
3.2.3 Residential Wood Combustion 18
3.2.4 Pentachlorophenol Treated Wood 20
3.2.5 Hazardous Waste Burning Cement Kilns 23
3.2.6 Iron Sintering 25
3.2.7 Steel Manufacturing Electric Arc Furnaces (EAF) 26
3.2.8 Secondary Copper Smelting 29
3.2.9 Landfill Fires 30
3.2.10 Other Smaller Sources 30
4.0 PROPOSED OPTIONS FOR ACHIEVING FURTHER DIOXIN/FURAN EMISSIONS REDUCTIONS . 33
4.1 STRATEGIC APPROACH 33
4.2 KEY PROPOSED ACTIONS 35
4.2.1 Municipal Waste Combustion (MWC) and Medical Waste
Incineration (MWI) Actions 35
4.2.2 Open Burning 36
4.2.3 Residential Wood Combustion 37
4.2.4 Pentachlorophenol Treated Wood 38
4.2.5 Steel Manufacturing (EAF) 39
4.2.6 Landfill Fires 39
4.3 NEXT STEPS 40
REFERENCES 41
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
LIST OF TABLES
Table 1. Revised Qualitative Confidence Rating Scheme Used in the Updated Draft U.S. Dioxin
Reassessment 5
Table 2. Major Sources1 of Dioxins/Furans in the Updated Draft U.S. Dioxin Reassessment .... 7
Table 3. Regulatory Overview of Dioxins and Furans in the U.S 8
Table 4. Overview of Major Non-Regulatory Programs Concerned With Dioxin Releases 9
Table 5. Sources Subjected to the GLBTS Dioxin Workgroup Decision Tree Analysis 11
Table 6. Overview of Results of the Decision Tree Analysis Process and GLBTS Priority
Assignments for Significant Dioxin/Furan Sources in the Great Lakes Basin 12
LIST OF FIGURES
Figure 1. Chemical structure of 2,3,7,8-TCDD and 2,3,7,8-TCDF 4
Figure 2. Draft Dioxin Decision Tree 10
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
1.0 INTRODUCTION AND REPORT OVERVIEW
Dioxins (polychlorinated dibenzo-para-dioxins, or PCDDs) and furans (polychlorinated
dibenzofurans, or PCDFs) are a group of toxic chemical compounds which are inadvertently generated
and released into the environment as by-products of various combustion and chemical processes. Due
to their toxicity, tendency to bioaccumulate, and persistence in the environment, dioxins and furans have
been the subject of ongoing public health and environmental concern. Despite existing controls, they
are distributed widely in the environment, sometimes at levels which may pose risk. For example,
dioxins/furans have been the cause of numerous fish consumption advisories in the Great Lakes region,
and the U.S. Environmental Protection Agency (EPA) has recently estimated that the risks for the
general population based on dioxin exposure could be as high as the range of a 1 in 100 to 1 in 1,000
increased chance of experiencing cancer related to dioxin exposure (USEPA, 2000b). In response,
various local, state, regional, and national efforts are focusing on achieving further reductions in dioxin
contamination. One of these efforts is the Great Lakes Binational Toxics Strategy (Binational Toxics
Strategy or GLBTS), which encompasses various activities and strategies being considered under the
guidance of a multi-stakeholder GLBTS dioxin/furan workgroup.
On April 7, 1997, Canada and the United States signed the Great Lakes Binational Toxics
Strategy: Canada-United States Strategy for the Virtual Elimination of Persistent Toxic
Substances in the Great Lakes. The Binational Toxics Strategy identified twelve bioaccumulative
substances having sufficient toxicity and presence in water, sediments, and/or aquatic biota of the Great
Lakes system to warrant concerted action to eliminate their input to the Great Lakes. They are called
"Level 1 substances". Dioxins/furans are one of the classes of Level 1 substances, and are the subject
of this report, which was prepared in response to the U.S. challenge goal for dioxins and furans written
in the GLBTS:
U.S. Challenge: Seek by 2006, a 75 percent reduction in total releases of dioxins and
furans (2,3,7,8-TCDD toxicity equivalents) from sources resulting from human activity.
This challenge will apply to the aggregate of releases to the air nationwide and of
releases to the water within the Great Lakes Basin, using the September 1994 draft
Dioxin Reassessment as an interim baseline. Once U.S. EPA has completed and
released its final Dioxin Reassessment, the Reassessment's 1987 emissions inventory
will be used as the challenge baseline.
To guide Environment Canada (EC) and the U.S. EPA, along with their partners, as they work
toward virtual elimination of the strategy substances, the GLBTS outlined a four-step analytical
framework:
1. Gather information
2. Analyze current regulations, initiatives, and programs which manage or control substances
3. Identify cost-effective options to achieve further reductions
4. Implement actions to work toward the goal of virtual elimination
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
In accordance with Step 3 of the four-step process, this report (the Step 3 report) documents
the analysis of available information on dioxin sources and regulations with the goal of identifying the
best options for further reductions. Specific goals of this report include the identification of
opportunities for new or modified approaches, pollution prevention programs, or other alternative
measures, which may accelerate the pace or increase the level of dioxin/furan reduction, while taking
into account cost-effectiveness.
First, this report provides a brief overview of dioxins for new readers, including major sources,
regulatory control, and non-regulatory programs and incentives. Additional information on dioxin/furan
sources and regulations used in this analysis was previously compiled (May 26, 2000) in the GLBTS
Step 1 & 2 report for dioxins, PCDD (Dioxins) and P CDF (Fur am): Sources and Regulations
(Draft Report) (USEPA, 2000a). The draft Step 1 & 2 report relied on EPA's 1998 peer reviewed
Draft Inventory of Sources of Dioxin in the United States (USEPA, 1998). Subsequently, a public
release of EPA's updated draft Dioxin Reassessment for external scientific review was provided on
EPA's website in June, 2000 (USEPA, 2000b). In addition, at the time of this report preparation,
EPA was in the process of implementing further revisions to the updated draft Dioxin Reassessment for
submission to EPA's Science Advisory Board (SAB) (USEPA, 2000c). Where applicable,
information from these updated draft Dioxin Reassessment documents, which includes revised inventory
estimates and information related to estimates of dioxins and furans releases that is not included in, or is
different from, that presented in the GLBTS Dioxin Step 1 & 2 report, is also reflected in this Step 3
report.
The remainder of this report discusses potential reduction opportunities for dioxins and furans,
with a primary focus on presenting the findings of the multi-stakeholder GLBTS dioxins/furans
workgroup. In 1999-2000, this workgroup, which included representatives from states, industry, and
environmental and other non-governmental organizations, evaluated the major sources of dioxin to
determine which pose the best opportunities for further reductions in the Great Lakes basin. As an
"options" paper, this document only explores potential ways to achieve additional dioxin/furan
reductions, with a primary focus on the Great Lakes region. It does not recommend a specific path of
action for EPA or EC on a national basis, or imply a commitment on the part of EPA or EC. In
addition, GLBTS goals do not address exposure issues. To address exposure issues, as well as dioxin
emissions, on a national basis, the Agency is in the process of developing the EPA Cross-Media Dioxin
Strategy. The national Dioxin Strategy will integrate EPA's diverse set of dioxin activities into a
comprehensive national program that is consistent with and responsive to the findings of the final Dioxin
Reassessment, once it is completed. This Step 3 report serves to identify options for achieving further
reductions in dioxin releases, with a primary focus on the Great Lakes region.
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
2.0 BACKGROUND INFORMATION ON DIOXINS/FURANS
2.1 CHEMICAL DESCRIPTION AND HEALTH EFFECTS OF DIOXINS/FURANS
Dioxins and furans are halogenated aromatic hydrocarbons which can have from one to eight
chlorine substituents. There are 75 individual chlorinated dioxins and 135 individual chlorinated furans.
Each individual dioxin and furan is referred to as a congener. Both the number of chlorine atoms and
their positions determine the physical and chemical properties, and therefore, the fate and toxicity of a
given congener. In addition to dioxin and furan congeners, coplanar polychlorinated biphenyls (PCBs),
a subset of PCBs, also exhibit dioxin-like toxicity due to their structural and conformational similarities
to dioxin compounds. Dioxins, furans, and dioxin-like PCBs are commonly found as complex mixtures
when detected in environmental media, biological tissues, or as releases from specific sources.
Generally, dioxins and related compounds are colorless crystals or solids that have a low water
solubility, high fat solubility (i.e., are lipophilic), and low volatility. They bind strongly to soils and
sediments and are extremely stable under most environmental conditions, making them persistent once
released in the environment. Because they are lipophilic, they also tend to bioaccumulate.
Only dioxin/furan congeners with chlorines attached at a minimum in the 2,3,7, and 8 positions,
as those shown in Figure 2-1, exhibit the high toxicity associated with dioxin. One compound, 2,3,7,8-
tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD), is the best studied of this class of compounds and serves
as the reference compound for assigning toxicity equivalence factors for related congeners. For risk
assessment purposes, estimates of the toxicity of sources which contain a mixture of PCDD and PCDF
congeners are often expressed as toxicity equivalents (TEQ). TEQ is calculated by multiplying
concentrations of each dioxin and furan congener present in a source with a toxicity equivalency factor
(TEF). The TEF is an estimate of each congener's toxicity relative to the toxicity of 2,3,7,8-TCDD.
The TEQ values for each congener are added together for the total TEQ concentration. Thus,
concentrations of dioxins and furans represented as a TEQ concentration provide a quantitative
estimate of toxicity as if all congeners present in the mixture are a toxic equivalent mass of 2,3,7,8-
TCDD. Thirteen of the total 209 PCB congeners are also thought to have dioxin-like toxicity, and are
often included in the calculation of dioxin/furan TEQs in toxicity assessments. Historically, various TEF
schemes have been defined and used to present results. The different TEF schemes, and a new uniform
TEQ nomenclature that clearly distinguishes between the different TEF schemes, are discussed in detail
in the updated draft Dioxin Reassessment (see USEPA, 2000b: Section 1.2 of the Integrated Summary,
or Part II of Chapter 9 "Toxicity Equivalence Factors (TEF) for Dioxin and Related Compounds"). In
the updated draft Dioxin Reassessment, the nomenclature I-TEQDF is used to denote the International
TEF scheme adopted by EPA in 1989, and TEQDF-WHO98 is used to refer to the 1998 WHO update
to the TEFs previously established by WHO for dioxins, furans, and dioxin-like PCBs (USEPA,
2000b). The I-TEQDF abbreviation is equivalent to the TEQs reported in the 1998 Draft Dioxin
Inventory (USEPA, 1998). For this reason in this Step 3 report, the calculations of the percent
contribution of a given source to the total inventory were performed based on I-TEQDF.
-------
Dioxin/Furan Reduction Options
9/27/00 External Review
2,3,7,8-Tetrachlorodibenzo-p-dioxin
2,3,7,8-Tetrachlorodibenzofuran
Figure 1. Chemical structure of 2,3,7,8-TCDD and 2,3,7,8-TCDF.
The latest data on exposure and health effects for dioxins and related compounds are provided
in detail in the multi-volume draft Health Assessment document included in the updated draft Dioxin
Reassessment (USEPA, 2000b). Current data (e.g., human and animal studies, mode of action
research) support a causal relationship between 2,3,7,8-TCDD exposure and cancer hazard in humans
(USEPA, 2000b). Other dioxin-like compounds (congeners) and mixtures are characterized by EPA
only as "likely" human carcinogens, primarily due to a lack of epidemiological evidence and congener-
specific toxicity data.
2.2 DIOXINS/FURANS SOURCES AND RELEASES OVERVIEW
Major sources and releases of dioxins, furans, and dioxin-like PCBs in the U.S. Great Lakes
basin have been discussed previously in the GLBTS Step 1 & 2 report for dioxin (USEPA, 2000a),
which relied on EPA's 1998 peer reviewed Draft Inventory of Sources of Dioxin in the United
States (USEPA, 1998). The subsequent release of the updated draft Dioxin Reassessment includes
updated release estimates for certain sectors, although these estimates are also still considered draft.
4
-------
Dioxin/Furan Reduction Options
9/27/00 External Review
These revisions, however, do not qualitatively or otherwise significantly affect the Step 1 & 2 report or
the past year's sector analysis by the GLBTS dioxin/furan workgroup because the source estimates
maintain the same relative ranking as the 1998 draft estimates. In addition, the updated draft
Reassessment does not affect the utility of the GLBTS workgroup's discussions or conclusions
regarding sources and reduction opportunities in the Great Lakes area, as these were developed in
tandem with EPA headquarters dioxin experts, and took into account the latest inventory information.
In addition to including revised emissions estimates, the updated draft Dioxin Reassessment
presents a revised qualitative confidence rating scheme. This scheme replaces the one used in the 1998
Draft Inventory which provided a numeric range of emissions to characterize uncertainty in the emission
estimates for the quantifiable sources and an "order of magnitude" estimate for the less well-
characterized sources. The new confidence rating scheme, presented in Table 1, uses qualitative
criteria to assign a high, medium, or low confidence rating to the emission factor and activity level for
those source categories for which emission estimates can reliably be quantified. The overall
"confidence rating" assigned to a quantified emission estimate was determined by the confidence ratings
assigned to the corresponding "activity level" and "emissions factor."
Table 1. Revised Qualitative Confidence Rating Scheme Used in the Updated Draft
U.S. Dioxin Reassessment (USEPA, 2000b)
Confidence
category
Confidence
rating
Activity level estimate
Emission factor estimate
Categories/media for which emissions can reasonably be quantified
A
B
C
High
Medium
Low
Derived from a comprehensive survey
Based on estimates of average plant activity
level and number of plants or limited survey
Based on data judged possibly
nonrepresentative
Derived from a comprehensive survey
Derived from testing at a limited but
reasonable number of facilities believed to bey
representative of source category
Derived from testing at only a few, possibly
nonrepresentative facilities or from similar
source categories
Categories/media for which emissions cannot be reasonably quantified
D
E
Preliminary
estimate
Not Quantified
Based on extremely limited data, judged to be
clearly nonrepresentative
No data
Based on extremely limited data, judged to be
clearly nonrepresentative
1) Argument based on theory but no data
2) Data indicating dioxin formation, but not in
form that allows developing an emission
factor
If the lowest rating assigned to either the activity level or emission factor terms is "high," then
the category rating assigned to the emission estimate is high (also referred to as "A"). If the lowest
rating assigned to either the activity level or emission factor terms is "medium," then the category rating
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
assigned to the emission estimate is medium (also referred to as "B"). If the lowest rating assigned to
either the activity level or emission factor terms is "low," then the category rating assigned to the
emission estimate is low (also referred to as "C"). For many source categories, either the emission
factor information or activity level information were inadequate to support development of reliable
quantitative release estimates for one or more media. For some of these source categories, sufficient
information was available to make preliminary estimates of emissions of dioxins/furans or dioxin-like
PCBs; however, the confidence in the activity level estimates or emission factor estimates was so low
that the estimates were not included in the sum of quantified emissions from sources with confidence
ratings of A, B, or C. These estimates were given an overall confidence class rating of D. For other
sources, some information exists suggesting that they may release dioxin-like compounds; however, the
available data were judged to be insufficient for developing any quantitative emission estimate. These
estimates were given an overall confidence class rating of E.
In the updated draft Dioxin Reassessment, EPA's revised best estimates of total national dioxin
and furan releases to all environmental media (products are not included) from reliably quantifiable
sources (i.e., those with confidence rating of A, B, or C as defined above) were approximately 12,400g
I-TEQDF (13,500 g TEQDF-WHO98) in 1987 and 2,600 g I-TEQDF (2,800 g TEQDF-WHO98) in
1995. In revisions made for the SAB submission (USEPA, 2000c), emissions from open burning were
upgraded to a confidence rating of C and therefore added to the quantifiable sources, while emissions
from forest, brush and straw fires were downgraded to a confidence rating of D and removed from the
quantifiable sources, as discussed in Section 3.2 below. Therefore, in the SAB submission, total
national releases from quantifiable sources are estimated as 12,800 g I-TEQDF (14,000 g TEQDF -
WHO98) in 1987 and 3,000 g I-TEQDF (3,300 g TEQDF -WHO98) in 1995.
EPA concluded in the updated Reassessment that quantifiable environmental releases of
dioxins/furans in the U.S. are dominated by releases to air from combustion sources, and are estimated
to be an order of magnitude greater than all other categories combined. Once finalized, the
Reassessment's 1987 emissions inventory will be used as the baseline for the GLBTS challenge goal of
a 75 percent reduction by 2006 in total releases of dioxins and furans from sources resulting from
human activity. Some of the larger sources of quantifiable dioxin/furan release included in the updated
inventory emissions estimates, as well as sources with preliminary estimates and suspected sources, are
listed in Table 2 below.
Of particular note in the updated draft Reassessment, new preliminary estimates of reservoir
source releases to water from urban runoff and rural soil erosion (190 and 2,700 g I-TEQDF in 1995,
respectively) suggest that, on a nationwide basis, total nonpoint/reservoir releases of dioxin-like
compounds to waterways (i.e., potentially leading to human exposure via consumption of contaminated
fish) are significantly larger than point source dioxin releases. The updated draft Reassessment also
supports the finding that the contribution of reservoir sources to human exposure may be significant.
-------
Dioxin/Furan Reduction Options
9/27/00 External Review
Table 2. Major Sources1 of Dioxins/Furans in the Updated Draft U.S. Dioxin
Reassessment (USEPA, 2000b)
Source Category
Combustion
(releases to air)
Metals smelting
and refining
(releases to air)
Chemical
manufacturing and
processing (releases
to water and land)
Reservoir Sources
Quantifiable Sources
municipal waste combustion, medical
waste incineration, hazardous waste
incineration, crematoria, sewage
sludge incineration, vehicle fuel
combustion, residential and industrial
wood combustion, industrial/utility oil
combustion, utility coal combustion,
cement kilns, and forest, brush and
straw fires2
iron sintering, and secondary
aluminum and copper smelting/refining
bleached chemical wood pulp and
paper mills (water), municipal
wastewater treatment sludge (land),
2,4- Dichlorophenoxy acetic acid
(land)
Sources with Preliminary
Estimates
biogas and landfill gas combustion,
residential oil combustion, industrial
and residential coal combustion,
asphalt mixing, landfill fires,
accidental fires, backyard barrel
burning3
coke production, electric arc ferrous
furnaces, ferrous foundries
municipal wastewater (water)
urban runoff and rural soil erosion
(water)
Unquantified / Suspected
Sources
uncontrolled combustion of PCBs,
agricultural burning
primary aluminum, primary nickel,
primary magnesium4
mono- to tetrachlorophenols,
pentachlorophenols, chlorobenzenes,
chlorobiphenyls (leaks/spills),
dioxazine, tall oil-based liquid soaps
air, sediments, water, biota, PCP-
treated wood
individually to release greater than 5 g l-TEQDF/yr in 1995.
2 Dioxin emissions from forest, brush and straw fires are expected to receive a lowered confidence rating of "D" in the revised Dioxin
Reassessment for SAB review (i.e., they will be considered preliminary estimates and will not be included in the total quantifiable inventory).
3 Backyard barrel burning is expected to receive a quantitative estimate with a confidence rating of "C" in the revised Dioxin Reassessment
for SAB review.
4 Primary magnesium is expected to receive a preliminary estimate in the revised Dioxin Reassessment for SAB review
2.3 SUMMARY OF EFFORTS TO CONTROL DIOXIN/FURAN RELEASES
Regulatory Efforts
EPA has pursued the control and management of dioxin through each of its major program
areas; collectively, these actions place regulatory controls on all of the major well-defined industrial
sources of dioxin. Dioxin releases to air are controlled under regulations promulgated by EPA under
authority of the Clean Air Act (CAA) and its amendments, which require emissions limits for dioxins
and other hazardous air pollutants based on "maximum achievable control technology" (MACT). With
full implementation of the MACT rules, the major categories of commercial and municipal waste
combustion are under direct regulation for their dioxin emissions. Dioxin releases to water are managed
through a combination of risk-based and technology-based tools established under the Clean Water
Act (CWA). Clean up of dioxin-contaminated lands is an important part of the EPA Superfund and
RCRA Corrective Action programs. Table 3 provides an overview of current federal regulation
7
-------
Dioxin/Furan Reduction Options
9/27/00 External Review
relevant to control of dioxin and related compounds in the Great Lakes basin. The regulatory programs
listed are described in further detail in the GLBTS Step 1 & 2 report for dioxin (USEPA, 2000a).
Table 3. Regulatory Overview of Dioxins and Furans in the U.S.
CM
§112(c)(6): Major
source categories
identified;
MACT standards
promulgated for
MWC (40CFR 60),
MWI (62 FR
48347), and HWC
(64FR 52827)
CWA
CWA Priority: Listed
priority pollutants
(40CFR423);
subject to NPDES
effluent limitations
under §304(b)
(40CFR122)and
general pretreatment
(40CFR 403)
CWA Biosolids Rule:
proposed standard of
300 parts per trillion
toxic equivalents for
dioxins in biosolids
(64 FR 72045)
Pulp and Paper Cluster Rule
(63FR 18504): Sets new NESHAPS/MACT
air standards specifically for the pulp and
paper source category (under CAA 1 1 2(b))
and water effluent limitations and
pretreatment standards for certain facility
subcategories (under CWA 304(b), 307)
SDWA
NPDWR/MCL:
30 pg/L
(enforceable)
MCL goal for
2,3,7,8-TCDD is
zero
RCRA
RCRA: Several
dioxin-bearing
wastes are F-listed
hazardous wastes,
and as such are
subject to land
disposal
restrictions
(40CFR261.31-
32)
Land disposal
restrictions for
certain dioxin-
containing and
wood-preserving
wastes
(40CFR 268.30-31
Subpart C)
Universal
treatment
standards for dioxin
levels in waste
(40CFR 268.48)
SARA/EPCRA
and CERCLA
CERCLA§103:
Spills of 2,3,7,8-
TCDD >1 Ib.
must be reported
to the National
Response Center
SARA §31 3:
October 29,1 999
Amendment adds
dioxins and dioxin-
like compounds to
those chemicals
subject to TRI
reporting
requirements, with
a threshold
reporting quantity
of 0.1 gram/year
(64FR 58666)
FIFRAandTSCA
FIFRA:SaleofSilvex
and 2,4,5-T canceled
for all uses (USEPA
1998);PCPuse
allowed only for
wood on restricted
basis (52FR 2282-
2293)
TSCA §4: Dioxin/
Furan Test Rule for
certain commercial
organic chemicals
(52FR 21412-
21452)
CAA: Clean Air Act
CERCLA: Comprehensive Environmental Response,
Compensation, and Liability Act (Superfund)
CWA: Clean Water Act
FIFRA: Federal Insecticide, Fungicide, Rodenticide Act
HMIWI: Hospital/Medical/lnfectious Waste Incinerators
HWC: Hazardous Waste Combustors
MACT: Maximum Achievable Control Technology
MCL: Maximum Contaminant Level (Drinking water standard)
MWC: Municipal Waste Combustors
NESHAPS: National Emissions Standards for Hazardous Air
Pollutants (HAPs)
NPDES: National Pollutant Discharge Elimination System
NPDWR: National Primary Drinking Water Regulations
PCP: Pentachlorophenol
RCRA: Resource Conservation and Recovery Act
SARA/EPCRA: Superfund Amendment Reauthorization Act /
Emergency Planning and Community Right-to-know Act
SDWA: Safe Drinking Water Act
TRI: Toxic Release Inventory
TSCA: Toxic Substances Control Act
Non-Regulatory Efforts
Table 4 presents an overview of some of the major non-regulatory programs, activities, and
efforts that may directly or indirectly address issues related to dioxins and furans in the Great Lakes.
-------
Dioxin/Furan Reduction Options
9/27/00 External Review
The programs listed are described in further detail in the GLBTS Step 1 & 2 report for dioxin
(USEPA, 2000a).
Table 4. Overview of Major Non-Regulatory Programs Concerned With Dioxin
Releases
International Programs
Great Lakes Binational Toxics Strategy; International Joint Commission Critical Pollutant; Great Lakes
Lakewide Management Plans; Remedial Action Plans (RAPs) for Great Lakes Areas of Concern (AOCs);
United Nations Environment Program (UNEP) Persistent Organic Pollutants (POPs) Initiative; United
Nations Economic Commission for Europe (UNECE) Long-Range Transboundary Air Pollution (LRTAP)
Initiative; NAFTA; Commission for Environmental Cooperation Tri-lateral North American Regional
Action Plan.
Domestic Programs
USEPA Persistent, Bioaccumulative, and Toxics (PBT) Initiative; Voluntary Advanced Technology
Incentives Program for pulp and paper mills, CAA 112(k) Urban Area Source Program - Integrated Urban
Air Toxics Strategy; Waste Minimization National Plan; Contaminated Sediment Management Strategy;
Wildland Fire Prevention/Education; Western Lake Superior Sanitary District (WLSSD) Pollution
Prevention Efforts and Zero Discharge Pilot Project (ZDP).
Industry Activities
Health Care Without Harm and other health care industry initiatives; wood-stove changeout programs
and workshops; voluntary paper industry program to limit dioxin concentrations in land- applied pulp and
paper sludge (during interim time before full implementation of the pulp and paper effluent guidelines);
voluntary industry agreements to restrict the levels of dioxin found in chloranil (used in the manufacture
of certain pigments and tires) and chlorinal-tire manufacturer agreement to import only low dioxin
chlorinal.
Programs Focusing on
Dioxin Exposure Reduction
National Fish and Wildlife Contamination Program and Fish Consumption Advisories;
Environmental Justice and Children's Health Initiatives; FDA Actions.
Information Gathering
and Monitoring Efforts
Dioxin Exposure Initiative (DEI) Efforts; other sources and emissions research, exposure and effects
research, and routine monitoring efforts
3.0 IDENTIFYING DIOXIN/FURAN REDUCTION OPPORTUNITIES
3.1 DESCRIPTION OF THE GLBTS WORKGROUP'S SECTOR ANALYSIS PROCESS
FOR IDENTIFYING OPTIONS
In July 1999, the GLBTS dioxin/furan workgroup began the development of a process to
systematically evaluate the major sectors contributing to dioxin/furan releases in the Great Lakes basin,
with the intent of helping workgroup participants identify the top priorities for work group focus. This
eventually led to the adoption of a decision tree process, which allowed the workgroup to assign a
GLBTS priority level to each sector amongst the major targeted sectors. Priority level designation was
based on consideration of available source and release information, and regulatory and programmatic
frameworks. Primary goals of this ranking process were to define priority areas for initial workgroup
focus, and to determine if the GLBTS workgroup could potentially provide any added value (i.e., by
-------
Dioxin/Furan Reduction Options
9/27/00 External Review
designating a sector as high priority) to reduction processes already in place for a given sector. The
dioxin decision tree chart used by the workgroup in this process is attached below.
Is There a
Reliable Emission
Estimate for this
Source Category?
NO
Based on the
Existing Information,
Is It Likely That
This Category Is
Significant to
the Basin?
UNDETERMINED
1
Will Anyone
Determine the
Emission Estimate
For This Category?
YES
YES
NO
NO
Is This a Significant
Source Category to
the Basin?
YES
Are There
Regulations or
Programs That Exist,
or That Are Planned
for This Category?
NO
YES
Are There
Opportunities for
Further Reductions/
Elimination?
YES
NO
Figure 2. Draft Dioxin Decision Tree
Identify Potential P2 or
Voluntary Reduction
Projects
Identify Other Initiatives
in Place That May Affect
a P2 or a Voluntary
Reduction Project
Evaluate the Effects or
Potential of Existing
Initiatives on P2 or
Voluntary Reduction
Projects
Rank P2 or Voluntary
Reduction Projects
By Reduction Potential,
Difficulty, and Importance
to Other Work Groups,
etc.
e / /Big Bi
y/ / Hard Ea
» » _ ]•
Big
Easy
In the decision tree process, which the workgroup began to implement in November 1999, a
"source category" was defined as any source or sector identified in the EPA or EC dioxin inventories
for which emission estimates exist. A source category could also include other sources not included in
the inventories, but which were of concern to the work group participants. For example, although there
have been significant reductions in dioxin emissions from the quantifiable industrial sources, preliminary
order of magnitude estimates at the time of workgroup discussion suggested that some uncontrolled
combustion sources (e.g., landfill fires at 1,000 g I-TEQDF and backyard trash burning at I-TEQDF in
the 1998 Draft Inventory) may still be of significant concern (USEPA, 1998). For the initial ranking
process, a candidate "significant source category" to be subjected to the decision analysis was defined
as a source or sector whose dioxin emission estimates were equal to or exceeded 2% of the total 1998
Draft U.S. Inventory or the 1999 Ontario emission inventory, or a source or sector whose dioxin
emissions might otherwise be considered significant to the Great Lakes basin. If a source or sector had
only "order of magnitude" emission estimates from the 1998 Draft U.S. Inventory, then the "order of
magnitude" estimate was considered in determining the significance of the source category. The
rationale for picking 2% was the fact that in the inventories, the 2% cutoff appeared to separate major
10
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
sources accounting for the majority of emissions from a large number of minor sources responsible for
only a very small percentage of the total emissions. The final list of candidate sources that were
subjected to the decision tree analyses by the workgroup are listed in Table 5 below.
Table 5. Sources Subjected to the GLBTS Dioxin Workgroup Decision Tree Analysis
Combustion sources
municipal waste combustion ! landfill fires ! diesel fuel combustion
medical waste incineration ! forest fires
open burning ! wood waste combustion
residential wood combustion ! utility coal combustion
hazardous waste burning cement
kilns/hazardous waste incinerators
Metals smelting and refining
iron sintering ! steel manufacturing ! secondary copper smelting
electric arc furnaces (EAF)
Reservoir sources (anthropogenic structures)
pentachlorophenol treated wood
The decision tree analysis was used by the workgroup both to assign a priority ranking of high,
medium, or low to each candidate sector, as well as to identify significant information gaps that needed
to be filled before a final ranking could be assigned. This GLBTS priority ranking was meant to convey
the workgroup opinion about the significance of the reductions possible, taking into account the ease
with which the reductions could be obtained. Two important points about the process deserve mention.
First, the process was not intended to provide a numerical ordering of sources by priority, nor to
capture fine distinctions in priority status between sources. Rather, the process was intended to identify
a few obvious sources or sectors where there were opportunities for additional dioxin reduction efforts.
Second, the GLBTS analysis was focused on dioxin reduction opportunities that went beyond
programs or efforts that were already in place and expected to continue. For example, a source
coming under new MACT regulations may have significant reduction opportunities, but may have
limited opportunities for significant reductions over and beyond those expected from the established
MACT regulatory program. Therefore, in the GLBTS process, a sector could be designated as low
GLBTS priority on the basis of either a) minimal emissions or b) minimal reduction options for the
GLBTS.
The GLBTS decision tree analysis process and the prioritization of sources and sectors, was
conducted as an open process in which any interested stakeholder was given the opportunity to
participate. The workgroup had the input and participation of a wide variety of stakeholders, including
states, industry, and environmental and other non-governmental organizations.
11
-------
Dioxin/Furan Reduction Options
3.2 FINDINGS OF THE SECTOR ANALYSIS
9/27/00 External Review
Table 6 provides an overview of the findings of the sector analyses conducted by the GLBTS
dioxin/furan workgroup using the decision tree process described above. The priority level assignments
refer only to a sector's ranking relative to opportunities for the GLBTS dioxin/furan workgroup. For
the workgroup, the ranking did not preclude the pursuance of a project for any sector, nor was it
intended to define closure for the workgroup or indicate a national priority level for a given sector.
Candidate sectors will be periodically revisited by the workgroup participants as priority activities are
completed.
Table 6. Overview of Results of the Decision Tree Analysis Process and GLBTS
Priority Assignments for Significant Dioxin/Furan Sources in the Great Lakes
Basin.
Source / Sector 1
Municipal waste combustion (MWC)
Medical waste incineration (MWI)2
Backyard trash / open burning
Residential wood combustion
Dentachlorophenols (treated wood)
Cement kilns (hazardous waste burning)
Iron sintering
Steel manufacturing (EAF)
Secondary copper smelting
Hazardous waste incinerators
Wood waste combustion
Utility coal combustion
Diesel fuel combustion
Landfill fires
Forest fires
GLBTS Priority Designation
Low priority
Low (US) / medium (Canada) priority
High priority
High priority
Medium (US) / low (Canada) priority
Low priority
Low priority
No priority designation (US) due to lack of data / low priority (Canada)
Low priority (US) / no priority designation (Canada) due to lack of data
Low priority
Low priority
Low priority
Low priority
No priority designation due to lack of data
Low priority
1999 Ontario emissions inventories. These inventories represented the best information available at the time of workgroup discussions; values
presented in these inventories are currently under review and will potentially change in the final versions.
2 Shaded rows indicate candidate sectors for further GLBTS workgroup actions.
Following is documentation of the workgroup discussions and information sharing that led to the
priority designation for each sector.
12
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
3.2.1 Municipal Waste Combustion (MWC) and Medical Waste Incineration (MWI)
Emissions Estimates and Significance. In the U.S., MWC and MWI have historically been
the two largest industrial categories of dioxin releases to the environment, and quantifiable dioxin/furan
emissions estimates for MWC and MWI have been made. In the updated draft Dioxin Reassessment
(USEPA, 2000b), MWC has been given a confidence rating of "B", which indicates that the
characterization of MWC was judged to be adequate for quantitative estimation with medium
confidence in the emission factor and at least medium confidence in the activity level. MWI was given a
confidence rating of "C", which indicates that the characterization of MWI was judged to be adequate
for quantitative estimation, although with low confidence in either the emission factor and/or the activity
level. In Ontario, Canada, the reliability of MWC emissions is high (the largest emitter is tested
annually), with approximately 95% of the Ontario total originating from the Hamilton-Wentworth Solid
Waste Reduction Unit (SWARU) facility in Hamilton, Ontario. The Ontario MWI emissions estimates
are currently being revised, and are expected to increase significantly in an updated Canadian
dioxin/furan inventory due to be released soon. MWC and MWI comprised approximately 44 and 18
percent, respectively, of the total quantified releases to air in the U.S. in 1995 (USEPA, 2000b), and
19 and 3 percent, respectively, of the 1999 Canadian Ontario Inventory.
Regulations and Programs. There is relatively extensive regulatory control of air emissions
from MWC and MWI either in place or in development. U.S. EPA promulgated Maximum
Achievable Control Technology (MACT) standards in 1995 for municipal waste combustors, with a
1997 amendment calling for the exemption of small MWC units from coverage under the 1995
regulations. Although MWC facilities with capacities less than 35 tons/day are not currently subject to
regulation, the 1998 U.S. Inventory estimated that the larger MWCs were the source of the great
majority of emissions, with the 14 largest facilities estimated to account for 80% of all emissions. For
the large MWC facilities (>250 ton/day), a Federal Implementation Plan has been finalized, with a
compliance deadline of December, 2000. MACT rules specifically for small MWC facilities (35-250
ton/day) were proposed in 1999 and are planned to be finalized by 2001. For MWI, EPA finalized
MACT rules in 1997, with a compliance deadline of September, 2002. Some smaller combustion
facilities may also be covered by the emissions rules for Boilers and Industrial Furnaces (BIFs), which
should cover other types of facilities burning municipal waste not covered by MWC and MWI rules.
Details on the implementation and compliance status for the various facility categories and in the various
Great Lakes states are provided in the GLBTS Step 1 & 2 report for dioxin (USEPA, 2000a).
In Ontario, the development of Canada Wide Standards (CWS) is expected to reduce MWC
and MWI air emissions, with draft standards currently proposed and planned to be achieved by 2006
for existing facilities. Once CWS are finalized, provinces have the burden of implementation. Until
then, regulatory agencies can only encourage voluntary efforts (e.g., upgrading to carbon injection
systems) to reduce emissions. However, voluntary upgrades of control devices are predicted to be
unlikely to occur before 2005 because there are no incentives now in place. In addition, because the
municipality in which the SWARU facility is located is currently reviewing its waste management plan
and may be shining away from incineration, the municipality is hesitant to invest in upgrades.
13
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
Expected/Predicted Reductions. Overall, the decrease in estimated total releases of
dioxins/furans in the U.S. between 1987 and 1995 (approximately 80%) is primarily attributed to
reductions in air emissions from municipal and medical waste incinerators (USEPA, 2000b). This
decrease is thought to be the result of improved combustion and emission controls, as well as from the
closing of a number of facilities. Estimated decreases of MWC and MWI emissions across the
inventory's two reporting years (1987 and 1995) are considered fairly reliable estimates due to several
factors, including: a) half of the MWI emissions reductions are due to closing of facilities, and b) for
MWC, most of the reductions took place in the 14 facilities that accounted for about 80% of the
emissions from that source category. Because implementation and compliance regarding MACT rules
are an still underway, further emissions reductions are anticipated for both categories. EPA estimates
that when full compliance with the MACT rules for MWC (as applied to all new and existing
waste-to-energy plants and incinerators with the capacity to burn more than 35 tons of garbage per
day) is reached that the annual emissions resulting from municipal solid waste incinerators will decline
significantly to about 24 g TEQ/year (USEPA, 1998). EPA expects full compliance with MACT rules
for MWI to result in a decline of nationwide emissions from this source to about 6-7 g TEQ/year
(Winters, personal communication, 2000). As facilities demonstrate compliance with MACT standards
through stack testing, the reliability of emission estimates will also increase.
Given the existence of established regulatory controls and processes in the U.S. and Canada,
the key question for the dioxin/furan workgroup regarding MWC and MWI was whether further
reduction opportunities might exist after regulations. To comprehensively evaluate and determine a final
priority status for MWC and MWI, the workgroup also considered the potential for additional dioxin
reductions to be achieved through voluntary pollution prevention (P2) and waste management projects
(e.g., front-end separation and waste minimization), and discussed MWC/MWI ash disposal as an
aspect of these incineration sectors that may warrant future workgroup attention.
Issues and Potential Opportunities: Waste Management. In order to assess the potential
for dioxin reduction through changes to waste management practices at municipal and medical waste
combustion facilities, the workgroup discussed available information on the relationship between
chlorine content of the feedstock and the effectiveness of waste separation efforts on reducing
dioxin/furan emissions. This information included EPA research and a waste incineration study
conducted in the Western Lake Superior Sanitary District (WLSSD). Overall, workgroup assessment
indicated that the chlorine-dioxin relationship is not simple, with differences existing depending on
whether the combustion is poorly or well controlled. The discussion identified three ways in which
dioxin is released as a result of the combustion process: 1) dioxin is in the fuel to start with and is
released during the combustion process, 2) dioxin is generated as a result of incomplete combustion, or
3) although combustion is complete, dioxin is formed in the post-combustion environment via de novo
synthesis. If the temperature is above or below a certain range (i.e., 400 to 750 • F), dioxin formation
will not occur (USEPA, 1999). In general, there are three requirements for the formation of dioxin
during complete combustion: 1) appropriate temperatures for formation, 2) sufficient retention time, and
3) the presence of catalytic surfaces. At facilities with well controlled combustion and good pollution
controls, these three factors result in low levels of dioxin formation and release. When facilities are
14
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
operated according to the MACT standards, background concentrations of chlorine are adequate to
support the levels of dioxin formation occurring, and additional sources of chlorine (e.g., polyvinyl
chlorides) will generally not result in additional dioxin formation. Therefore, in well-controlled
combustion, the chlorine content of the feedstock is typically not a controlling factor in the magnitude of
dioxin formation. However, this may not be the case in instances where combustion is less well
controlled, and in some cases, chlorine in the feedstock may play a significant role in controlling dioxin
formation. The latest findings in the updated draft U.S. Dioxin Reassessment also support the
conclusion that, although chlorine is an essential component for the formation of dioxins/furans in
combustion systems, chlorine levels in feed are not the dominant controlling factor for rates of
dioxin/furan stack emissions. For any individual commercial-scale combustor, however, circumstances
may exist in which changes in chlorine content of feed could affect dioxin emissions (USEPA, 2000b).
The GLBTS dioxin workgroup also considered the waste-management-oriented efforts of
Health Care Without Harm (HCWH), which is a collaborative campaign for environmentally
responsible health care, including the reduction of dioxin (and mercury) emissions from medical waste
incineration. Historically, hospitals have disposed of all waste, whether medical or non-medical, via
MWI because this method was considered cheaper than separating it. HCWH discourages
unnecessary incineration of hospital waste materials, especially recyclable materials, with a focus on
eliminating the need to burn wastes. In addition, HCWH is also specifically concerned with products
made with polyvinyl chloride (PVC) plastic, due to the potential for PVC to release dioxin during its
manufacture and incineration. Activities HCWH has conducted include: meeting with hospitals to
encourage and discuss means for waste reduction (e.g., materials separation), encouraging the use of
non-PVC alternatives in hospitals (e.g., polyethylene IV bags), and encouraging non-incineration
alternatives to waste disposal. Significant reductions in MWI emissions were observed by HCWH
when hospitals began separating medical waste from municipal waste. These reductions were
attributed in part to reductions in the total volume of waste burned at MWI, which historically had
fewer combustion controls than MWC. Information gaps may still exist regarding the quantities of non-
medical/non-infectious waste being included in the MWI waste stream, and regarding the quantities of
waste being disposed of by incineration as compared to alternative methods. Additional information is
needed regarding the fate of waste diverted from closed facilities, particularly MWIs, in the Great
Lakes basin. U.S. state contacts revealed some transfer of medical waste to MWC or pyrolysis
facilities.
Issues and Potential Opportunities: Ash. MWC and MWI ash disposal issues were also
assessed by the GLBTS dioxin workgroup in an effort to prioritize these sectors. In the U.S.,
combustion ash is regulated as hazardous under RCRA only if it exhibits toxicity characteristics;
however, there are no toxicity characteristic thresholds for dioxin specifically. In addition, municipal
solid waste (and MSW ash) is specifically excluded from being a listed hazardous waste and may be
disposed of in a municipal landfill. Details on U.S. regulation pertaining to ash disposal are provided in
the GLBTS Step 1 & 2 report for dioxin (USEPA, 2000a). Nationally, ash from waste combustion
facilities is thought to be typically disposed of in a monofill where the ash is isolated from other
substances that might encourage the leaching of dioxin. Because dioxins and furans are extremely
15
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
hydrophobic chemicals, the absence of other carriers (an oil, for example) would greatly reduce the
leaching of dioxins from these landfills. Each state also usually has its own medical waste program,
including MWI ash disposal regulations. A better characterization of the specific land disposal
practices for MWC and MWI ash actually occurring within the U.S. Great Lakes watershed was
identified by the dioxin/furan workgroup as an information need.
In Canada, available information did not indicate that Canada had a monofill requirement for
MWC or MWI ash. Bottom ash is usually not considered toxic, and may be disposed of in a sanitary
landfill. Fly ash is considered toxic, although it may be combined with bottom ash prior to disposal,
which may affect disposal requirements. Some research is currently being conducted in Canada on
alternative technologies for destruction/reduction of dioxins and furans in ash. This research, however,
is primarily being driven by the expense of landfill disposal in Canada, rather than by exposure
concerns.
Workgroup Conclusions and GLBTS Priority Ranking. In summary, after assessing
available information regarding the various aspects of MWC and MWI in the U.S. and Canadian Great
Lakes basin, the GLBTS dioxin/furan workgroup concluded that, for air emissions, there was currently
substantial regulatory control of MWC and MWI in place or being developed in both the U.S. and
Canada, and that at this time, further reduction opportunities were generally limited. The group also
concluded that more information was needed on the management and disposal of fly and bottom ash
from waste incineration to determine significance regarding dioxin/furan releases. Acknowledging this,
the workgroup designated final priority levels for MWC and MWI based on air emissions only. For
MWC, a low priority assignment was made on the basis of significant reduction efforts for air emissions
already in place in both the U.S. (MACT standard implementation) and Ontario (Canada Wide
Standard development), with the caveat that progress in compliance would be assessed by the
workgroup periodically in both countries. For MWI, the low priority assignment in the U.S. was also
made on the basis of significant reduction efforts already underway with MACT standard
implementation, again with the condition that compliance would be monitored. In Ontario, although the
Canada Wide Standard development would also potentially reduce MWI air emissions, a medium
GLBTS priority level was assigned due to new data suggesting that stack emissions from MWI in
Ontario may be much greater than estimated in previous inventories.
3.2.2 Backyard Trash / Open Burning
Emissions Estimates and Significance. In the 1998 Draft Inventory (USEPA, 1998)
dioxin/furan releases from backyard trash burning were given an order of magnitude estimate of 1,000 g
I-TEQDF / yr. In the updated Dioxin Reassessment (USEPA, 2000b), they were assigned a preliminary
estimate of 1,125 g I-TEQDF released to air in 1995 with a confidence rating of
"D", which indicates that sufficient information was not available to include the estimate in the sum of
quantified emissions. However, these preliminary emissions estimates indicated to the workgroup that
uncontrolled trash burning has the potential to be a very significant source of dioxins (USEPA, 1998;
USEPA, 2000b). In revisions to the updated draft Dioxin Reassessment for SAB review, the
16
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
confidence rating for backyard burning will be upgraded to "C", and a quantitative emission estimate of
628 g TEQDF-WHO98 in 1995 will be included in the total inventory for dioxin/furan releases (USEPA,
2000c). Estimates of dioxin/furan emissions from open burning in Ontario are not included in the 1999
Ontario Inventory.
Other potential sources of concern within the open burning category include "teepee burning" in
Canada, which is characterized by low-tech, municipal-scale, uncontrolled burning of waste in areas
without landfill capability (e.g., Newfoundland), the combustion of garbage in residential fireplaces (e.g.,
cited as an occurrence in Minnesota), and agricultural burning. EPA's dioxin program intends to
expand its research on agricultural burning to include better characterization of stubble-field, grassland,
and silvicultural bums. Agricultural burning, however, differs in many way from open burning of trash in
that the burn cycle is often an integral part of certain ecosystems, such as grasslands and Douglas-fir
forests.
Regulations and Programs. Currently in the U.S., there is no uniform standard of regulatory
control of air emissions from open burning. Open burning is not federally regulated by the CAA.
Individual state, county, tribal, and local governments have various regulations that address open
burning. However, one of the problems related to open burning identified by the GLBTS dioxin/furan
workgroup is that the local regulations that are in place are not stringently enforced. Details on some
local regulation in the various Great Lakes states are provided in the GLBTS Step 1 & 2 report for
dioxin (USEPA, 2000a).
Issues and Potential Opportunities. To assess opportunities related to dioxin reductions
from open burning sources, the GLBTS dioxin/furan workgroup considered: a) recent EPA research on
factors influencing dioxin emission from open burning, b) a recent study conducted by the Western
Lake Superior Sanitary District (WLSSD) on the prevalence and public perceptions of open burning,
and c) the potential for voluntary actions such as outreach and educational campaigns.
EPA research has indicated that there are generally two main questions or unknowns in
determining dioxin emissions from open barrel trash burning, including: 1) the prevalence and
distribution of the practice, and 2) the emission factors and variables that affect dioxin emission levels
(e.g., burning practice, type of trash). Although the presence of chlorinated materials in waste is not the
most important factor in dioxin formation for many commercial-scale facilities, chlorine content of waste
may play a more significant role in the level of dioxin emissions for uncontrolled combustion, such as the
open burning of household waste (USEPA, 2000b). A better characterization of the prevalence and
distribution of open burning, in the Great Lakes basin specifically, was identified by the dioxin/furan
workgroup as an important information need.
A recent study conducted in Minnesota and Wisconsin to gain information on open burning
practices and perceptions, and in order to better target future outreach and education on reduction
options, was evaluated by the dioxin/furan workgroup (WLSSD, 2000). The study consisted of phone
surveys of 780 area residents, 380 each in Minnesota and Wisconsin. Questions asked focused on
17
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
public opnion regarding open burning, such as type and quantity of garbage burned, frequency of
garbage burning, reasons for burning, and other demographic information. Key findings of the study
showed that the most common reasons for burning garbage were convenience and to avoid the high
cost of garbage service in many areas. When asked about environmental and health concerns
associated with open burning, perceptions were that it was an important, but only moderate danger.
Fire danger was ranked in the survey as the number one concern associated with open burning of
garbage, and when asked about possible incentives for stopping open burning, many respondents said it
was likely that there was nothing that would convince them to cease the practice. In the WLSSD,
information collected in the study was planned to be used in putting together an educational campaign.
The dioxin workgroup considered voluntary efforts applicable to achieving reductions in dioxin
emission from open burning. Public education and outreach and the development of infrastructures to
provide alternatives to open burning were all identified as significant aspects of open burning that
needed attention to effect reductions. Local fire departments were mentioned as a resource that may
have potential for conducting successful communication efforts geared at encouraging the public to
reduce open burning, or to modify open burning practices to release less dioxins.
Workgroup Conclusions and GLBTS Priority Ranking. In summary, after assessing
available information regarding the various aspects of open burning in the U.S. and Canadian Great
Lakes Basin, the GLBTS dioxin/furan workgroup concluded that open burning should be designated as
high priority for workgroup actions. This decision was based on high (although uncertain) emissions
estimates in the U.S., and the presence of substantial opportunities to promote reductions (i.e., due to
the lack of regulatory control).
3.2.3 Residential Wood Combustion
Emissions Estimates and Significance. Quantitative emissions estimates for dioxin/furan
releases from residential wood combustion (RWC) have been made in the U.S. and Canada. In the
updated draft Dioxin Reassessment (USEPA, 2000b), residential wood combustion has been given a
confidence rating of "C", which indicates that the characterization of this source was judged to be
adequate for quantitative estimation, although with low confidence in either the emission factor and/or
the activity level. In Ontario, although the confidence in emissions estimates for residential wood
combustion is low (based on the EPA emission factor only), preliminary estimates indicate this source
may be a very important source of dioxin emissions in Ontario. This source comprised about 2.5%
percent of the total quantified releases to air in the U.S. in 1995 (USEPA, 2000b), and 26.3% of the
total 1999 Ontario Emissions Inventory.
Additional data on the nature of dioxin/furan releases from wood stoves is currently being
gathered in a Canadian wood stove testing program underway to assess the dioxin reduction potential
of EPA-certified stoves. The study will compare emissions from old conventional and new certified
wood stoves; in addition, it is hoped that the results of the study will help to determine if there is a
correlation between particulate matter (PM) and dioxins/furans in wood stoves. EPA-approved stove
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
technology has been shown to reduce paniculate matter emissions by up to 90%; therefore, determining
the relationship between PM and dioxins would allow inferences on dioxin reductions. Preliminary
results from the Canadian tests of certified stoves showed that dioxin and furan emissions from wood
stoves were predominantly in the gaseous phase. Final test results on the certified stoves are currently
being analyzed. There is no information yet on dioxin releases for conventional stoves, although testing
is underway.
Regulations and Programs. In the U.S., there is relatively little regulatory control of air
emissions from residential wood combustion. Although, under a 1988 New Source Performance
Standard (NSPS) ruling, EPA requires certification to control particulate matter for residential wood-
fired heaters manufactured after 1990, the phase-out of older wood-fired heaters that do not meet
EPA's PM limit is slow to take effect. In addition, because the exact nature of the association between
dioxins/furans and PM is unknown, the effects, if any, of PM control technology on dioxin/furan
emissions is also unknown. In the U.S., wood stove changeover pilot programs were conducted in
Traverse City, MI, and Green Bay, WI in February, 2000. The goal of these pilot projects was to
gauge the regional response and potential impacts of a wood stove changeover. Those turning in old
conventional wood stoves received a 15% rebate on the purchase of a new stove (as based on an
agreement between manufacturers and dealerships). Approximately one-third of switch-overs are to
gas units or liquid propane fuel. Other aspects of the project include: potential partnering with steel
industry groups to pick up the old stoves for use as scrap steel, and a certification of destruction
requirement from the scrap yard to verify that the old stoves are not being put back into service. Result
of the pilots to date showed that gas utilities, insurance companies, and fire departments may be
valuable partners in these changeover efforts in the future. Sponsors, including the Hearth Products
Association, are contemplating expanding the project, pending an assessment of the success in the two
pilots.
In Canada, wood stoves are a high priority sector, with previous and/or ongoing activities
including workshops, educational campaigns, a pilot changeout program in eastern Ontario in early
1999, and a National point-of-purchase campaign. In addition, the Final Canada-wide Standards
(CWS) for wood stoves are scheduled for 2001. Initial commitments under the CWS include: updating
the Canadian Standards Association standards for new wood-burning appliances; developing a national
regulation for new, clean-burning residential wood-burning appliances; conducting national public
education campaigns; and assessing the option to undertake a national woodstove upgrade or change-
out program.
Because RWC also accounts for a large proportion of the national benzo(a)pyrene (B(a)P)
emissions, the GLBTS B(a)P workgroup has been highly involved in the planning of future wood stove
changeover and other outreach campaigns.
Workgroup Conclusions and GLBTS Priority Ranking. In summary, after assessing
available information regarding the various aspects of residential wood combustion in the U.S. and
Canadian Great Lakes basin, the GLBTS dioxin/furan workgroup concluded that residential wood
19
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
combustion should be designated as high GLBTS priority for dioxin/furan workgroup actions. This
decision was based on high emissions estimates and the presence of opportunities to promote
reductions. Better information on the effectiveness of PM controls on dioxin/furan emissions from
wood stoves was also identified as a need. However, although the workgroup has a high interest in
residential wood combustion and wood stove reductions, after discussing the current activities, the
workgroup decided that at the present time (i.e., pilot project stage) leadership of the GLBTS actions
directed at RWC should remain with the B(a)P workgroup. The reason for this includes both the fact
that the B(a)P workgroup has coordinated GLBTS wood stove change-out support to date, as well as
the fact that the reductions in B(a)P emissions from wood stoves are better characterized for B(a)P at
this point than for dioxin. The workgroup agreed to revisit the wood stove issue after the results of the
Canadian emissions studies and other pilot projects are available, at which time they may be better able
to reassess potential coordination activities and appropriate reductions actions related to wood stoves.
3.2.4 Pentachlorophenol Treated Wood
Emissions Estimates and Significance. Evidence suggests that significant amounts of dioxin
compounds are produced annually as a contaminant of pentachlorophenol (PCP), a wood preservative,
and are tied up in PCP-treated products (USEPA, 2000b). The only currently permitted use of PCP in
the U.S. is as a wood preservative in utility poles and crossarms. In addition, EPA's current
assessment of PCP indicates that the most significant mass of PCP is present in utility poles. EPA's
inventory estimates of the quantities of dioxins existing as a contaminant in manufactured
pentachlorophenol (8,400 g I-TEQDF / yr in 1995 [USEPA, 2000b]) are high (at more than three times
the total inventory of estimated releases to air). However, reliable emission estimates for dioxin/furan
releases to the environment from PCP-treated wood have not been made, and therefore, releases from
PCP-treated products are not included in the U.S. national dioxin inventory. EPA research suggests
that a minimal amount of dioxin is released from PCP manufacturing facilities and in-use utility poles. In
both the U.S. and Canada, uncertainty exists on whether the PCP (and dioxin contamination) present in
in-use utility poles actually poses an environmental risk, especially with respect to ultimate disposal.
Due to the limited information available at the time of decision tree analysis discussions, particularly
regarding pole disposal, the dioxin workgroup was unable to conclude that PCP-treated utility poles
were not a significant source in the Great Lakes basin. Therefore, because of the magnitude of the
mass of dioxins involved and the potential for this sector to be a source, PCP-treated utility poles
remained a medium GLBTS priority in the U.S. with a current focus on information gathering. In the
1999 Ontario Emissions Inventory, estimated releases of dioxins/furans to all media from PCP-treated
utility poles total about 1.7% of the entire inventory.
20
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
At the time of workgroup assessment of this sector, industry contacts reported that currently,
only 5% of the PCP used in Canada over the past 5 years has been used in Ontario, and that the
primary utility in Ontario (Ontario Hydro) uses copper chromium arsenate to preserve its utility poles.
In addition, wood preserving facilities which currently use PCP are reported to be very limited on the
U.S. side of the Great Lakes basin. On the other hand, a treated utility pole can be expected to last for
approximately 30 years. It is estimated that there are in excess of 120 million treated-wood utility poles
in place in the United States. Since PCP has been the dominant preservative used for the treatment of
utility poles in the last 25 years, many of these poles are treated with PCP. Assuming that 3% of the
existing poles are replaced every year, pole removals potentially constitute a significant volume of
material that must be either disposed of or recycled (AWPI, Penta Council).
Regulations and Programs. Details on regulations pertaining to PCP and PCP-treated wood
are provided in the GLBTS Step 1 & 2 report (USEPA, 2000a). Currently in the U.S., PCP is
regulated under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Based on a 1987
Settlement Agreement with PCP manufacturers, uses of PCP and its salts were limited to wood uses
only, and tolerance levels were set for amounts of certain dioxin contaminants in the material. EPA is
currently evaluating PCP for re-registration, which could impact the feasibility of various pollution
prevention and emission reduction options. Utility poles taken out of service are not necessarily
considered a waste and can be reused consistent with their intended end use. Although PCP is not a
RCRA-listed hazardous waste, PCP is on EPA's list of constituents that could cause a waste to be
classified as a hazardous waste through its Toxicity Characteristic Leaching Procedure. To evaluate
this possibility, the Electric Power Research Institute conducted testing of PCP-treated poles and
crossarms. In these tests, the average PCP level in the extracts was 1.92 ppm, well below EPA's 100
ppm threshold. The results of this testing confirm that PCP-treated wood is generally not a hazardous
waste under RCRA, and it may generally be disposed of as ordinary solid waste. Although PCP
treated wood is not a RCRA regulated waste, it may be a CERCLA liability if stockpiled or disposed
of improperly. Thus, industry indicated that potential liability associated with improper management
encourages proper management and disposal or re-use in the United States.
The Canadian Environmental Protection Agency (CEPA) has recently released a Strategic
Option Process (SOP) for the management of CEPA-toxic substances. Because PCP contains
dioxins, furans, and hexachlorobenzene, which are all CEPA-toxic substances, PCP treatment of wood
falls under this initiative. Implementation of this program has been planned through June 2006. The
program covers recommendations for reducing exposure to toxic substances during manufacture of the
preservative, application of the preservative, use of treated wood products, management of used
treated wood, transportation of both preservative chemicals and the treated products, and
contamination of sites. During dioxin workgroup discussion of the Canadian Wood Preservers SOP, it
was reported that the SOP on treated wood has greatly reduced the use and re-use of PCP treated
poles, largely due to increased awareness of potential liability. The SOP is also helping greatly with
gathering documentation on current management practices. The SOP is primarily voluntary. However,
if the voluntary approach of the SOP is not deemed successful, Environment Canada and Health
Canada will consider a regulatory approach.
21
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
Issues and Potential Opportunities: Life-cycle Management. For the utilities, there is a
viable market for re-use of utility poles taken out of service. Poles sold for re-use in the U.S. are
accompanied by a Materials Safety Data Sheet (MSDS) explaining the use restrictions. Industry
indicated that the MSDS consumer safety sheets which are distributed with reused poles identify
appropriate and inappropriate uses (e.g., PCP treated poles may not be used for residential burning).
In addition, after the secondary user is done with the poles, they become industrial solid waste which is
subject to disposal requirements in some cases. Poles that are no longer acceptable for carrying power
lines are often used for fence posts, landscape materials, or supports for vehicle shelters. If
PCP-treated poles must be disposed of, rather than reused or recycled, EPA recommends disposal in
municipal or industrial waste landfills properly permitted for the management of non-hazardous wastes
(AWPI, Penta Council). The utility that generates used PCP-treated utility poles is responsible for
determining the regulatory status of the used poles and ensuring that management and disposal are in
compliance with local, state, and federal regulations.
Another alternative for recycling is the use of PCP-treated wood for fuel in industrial or
commercial boilers or furnaces with capacities in excess of 20 million Btu/hr. There are a number of
facilities in the U.S. and Canada that have been permitted to combust PCP-treated wood (AWPI,
Penta Council). It was noted in workgroup discussions that the American Wood Preservers Institute
(AWPI) is working to get more penta-treated poles to be used as fuel. Regarding dioxin/furan emission
associated with incineration disposal (e.g., cement kiln fuel), EPA reported that cement kilns using PCP
treated wood as fuel generally do not have an impaired ability to meet MACT standards (i.e., as long
as quench technology is present). However, it was noted by the workgroup that local sensitivities
associated with burning certain types of fuel were also important.
The best available information at the time of workgroup discussions on the ultimate disposal fate
of utility poles taken out of service was taken from an unpublished report discussed at a February 1999
conference on utility poles in Florida. This information, which was based on a limited survey of
predominantly large utility companies in the southeastern United States, suggested that only about 50%
of utility poles currently have a controlled or known disposal fate. About 23% of the poles went into
landfills, about 14% were disposed of in incinerators, 31% were given away, and 18% were sold.
Although the survey covered all utility poles, not just PCP-treated poles, the survey can be considered
representative of PCP-treated utility pole fate. However, because smaller utilities, rural utilities, or
utilities in the western states were not included in the survey, national scale management of used utility
poles largely remains unknown.
Although the largest mass of known PCP is thought to be in treated utility poles, the workgroup
also considered the significance of other PCP sources, including those outside the basin. For example,
there are some geographically limited problems at manufacturing / wood preserving sites that will
require remediation. Acknowledging this, the dioxin workgroup identified the primary concern
associated with PCP in the Great Lakes basin as the fate / life-cycle management of the remaining
poles. In particular, the workgroup cited information on how many are being actively managed to the
end of their lives (e.g., via landfill disposal, as cement kiln/co-generation fuel) as a key information need.
22
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
In response to this information need, the Utility Solid Waste Activities Group (USWAG) is
planning to conduct a broad (nationwide) information gathering survey among its member companies on
the actual disposal and fate of utility poles that have been taken out of service. This effort is being
planned on an accelerated schedule, as possible. In addition, the Canadian Wood Preservers SOP is
promoting research on tracking the disposal fate of utility poles taken out of service in Canada under
several task management groups, including the guidance groups conducting life-cycle assessment /
impact studies, a waste management group working on an approved hierarchy of methods, and an
outreach group. Ontario Hydro is also currently conducting an assessment of remaining poles in
service.
Workgroup Conclusions and GLBTS Priority Ranking. Overall, the dioxin workgroup
concluded that Canada has less uncertainties than the U.S. with regards to PCP treated wood life-cycle
management because of the SOP. In the U.S., more information is needed on the fate of PCP treated
poles and on the regulatory drivers that may affect pole disposal. In addition, the question of whether
there is an infrastructure in place in the U.S. to trace these recycled/reused poles, and to assure that
they find an ultimate proper disposal was identified by the workgroup as a key information need.
Regarding the assignment of a GLBTS priority level to this sector, after assessing available information
regarding the various aspects of PCP manufacture and use in the U.S. and Canadian Great Lakes
basin, the GLBTS dioxin/furan workgroup concluded that PCP treated poles in the U.S. would be
designated as a medium GLBTS priority due to a lack of information on ultimate disposal fate of PCP-
treated utility poles. This priority designation will be revisited by the workgroup, dependent on more
information becoming available regarding de facto disposal. In Canada, PCP treated wood was
designated as a low GLBTS priority due to the controls and life-cycle analysis of PCP treated wood
that are underway through the Canadian Wood Preservers SOP.
3.2.5 Hazardous Waste Burning Cement Kilns
Emissions Estimates and Significance. Quantitative emissions estimates for dioxin/furan
releases from hazardous waste combusting (HWC) cement kilns have been made in the U.S. and
Canada. In the updated draft U.S. Dioxin Reassessment (USEPA, 2000b), HWC cement kilns have
been given a confidence rating of "C", which indicates that characterization of this source was judged to
be adequate for quantitative estimation, although with low confidence in either the emission factor
and/or the activity level. In the U.S., dioxin/furan emissions from cement kilns comprised about 5.8%
percent of the total quantified releases to air in 1995 (USEPA, 2000b). In Ontario, cement kilns
account for approximately 2.2% of the total inventory of emissions; these emissions estimates were
based on actual testing of 50% of Ontario kilns in 1997. There are a significant number of cement kilns
burning hazardous waste in the Great Lakes basin, including 26 on the U.S. side (none in WI or MN),
and 10 on the Canadian side (hazardous and non-hazardous waste burning facilities included).
Regulations and Programs. In the U.S., there is relatively extensive regulatory control of air
emissions from HWC cement kilns either in place or in development. Under the combined authorities
of the CAA (MACT standards) and the Resource Conservation and Recovery Act (RCRA), U.S.
23
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
EPA regulates dioxin emissions from facilities that burn hazardous waste. U.S. EPA finalized MACT
standards for new and existing Hazardous Waste Incinerators (including hazardous waste-burning
cement kilns) in 1999 with a compliance deadline of September, 2002. Details on the implementation
and compliance status for the various facility categories and in the various Great Lakes states are
provided in the GLBTS Step 1 & 2 report for dioxin (USEPA, 2000a). Hazardous waste combustion
ash carries the RCRA-listing of the hazardous waste burned and must be disposed of accordingly under
RCRA Subtitle C Land Disposal Restrictions, and Universal treatment standards for dioxin-containing
wastes. In 1999, EPA also proposed regulations limiting the dioxin content of cement kiln dust from
cement plants when these by-product materials are used as soil additives. Pollution control technology
is in place in Canadian cement kilns (e.g., electrostatic precipitators, baghouses), although with the
primary intention of controlling other pollutants (e.g., particulate matter), not dioxins and furans.
Expected/Predicted Reductions. To comprehensively evaluate and determine a final priority
status for HWC cement kilns, the dioxin workgroup considered the accuracy of predicted emission
reductions from cement kilns. EPA reports that current emissions from HWC cement kilns are
probably much lower than the 1995 estimates, due to significant technology upgrades (i.e., quench) that
have occurred since the time of the 1995 estimate. Therefore, because the 1995 emissions estimates
are likely not reflective of the technology in place today, emission levels after full MACT compliance
may also be lower than expected. In addition, in the process of reaching compliance with the RCRA
rules and in the MACT development process, a significant database of emissions data has been
complied by the cement kiln industry. Because there is now actual testing data, there will no longer be
a need to extrapolate emissions from emission factors; EPA is working on making new estimates.
Currently, EPA's Office of Solid Waste (OSW) has the most current, accurate data on cement kiln
emissions in the U.S. (obtained as a result of RCRA certification requirements), which represent real-
time data on all facility types.
Information gathered as a part of the MACT development process on current cement kiln
emissions and dioxin formation chemistry generally indicate that significant progress had already been
made in reducing cement kiln dioxin emissions. Between 1990 and 1997, EPA recognizes that cement
kilns have had about a 97% voluntary reduction in dioxin/furan emissions (e.g., by using quench
technology, inlet temperature controls, etc.). EPA research also supports the importance of
temperature control devices which cool combustion gases quickly through the temperature range of
about 400 to 750* F in limiting dioxin/furan formation at cement kilns (USEPA, 1999; USEPA, 2000b).
Issues and Potential Opportunities. In the priority assignment process, the dioxin
workgroup considered the influence of waste input and existing control technology, as well as cement
kiln dust disposal, as issues that may warrant future workgroup attention.
EPA reports that although studies show some inconsistencies, results tend to indicate that
cement kiln dioxin emissions are more a result of the combustion process rather than the type of waste
inputs, and that the burning of hazardous waste in cement kilns generally does not have an impact on
dioxin/furan emissions. For example, this has been observed in the case of the Fast Track Rule, in
24
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
which waste control measures (such as waste minimization or separation) did not have the same effect
after technology upgrades occurred. Therefore, in regards to dioxin emissions, efforts geared towards
control of the waste fuel were probably more effective as pre-regulation interim control. It was noted
that the primary motivation for burning hazardous waste at a cement kiln facility is to drive down
auxiliary fuel costs; the disposal of hazardous waste may provide extra revenue.
Regarding ash from HWC cement kilns (i.e., cement kiln dust), industry reported that because
facilities are controlling dioxin stack emissions by preventing formation in the first place, this type of
strategy also prevents the accumulation of dioxins/furans in the ash. Cement kiln dust is generally
considered a useful product, and may be put back into the cement product, or is sometimes used as a
soil amendment similar to lime. In proposed land application restrictions, EPA reported that
dioxin/furan limits are set low enough so that the resulting soil concentrations will not be altered
significantly. In the U.S., cement kiln dust is also sometimes put into landfills.
Workgroup Conclusions and GLBTS Priority Ranking. In summary, after assessing best
available information regarding the various aspects of hazardous waste burning cement kilns in the Great
Lakes basin, the GLBTS dioxin/furan workgroup concluded that there was currently strong regulatory
control of this source in place in the U.S., low emissions in Ontario, and that at this time, further
reductions opportunities existing after regulations were generally limited. Acknowledging this, the
workgroup reached agreement that cement kilns should be assigned a low GLBTS priority status,
based on progress already made in emission reductions, voluntary activities by the industry, and
adequate management that will be in place regarding cement kiln dust.
3.2.6 Iron Sintering
Emissions Estimates and Significance. In the updated draft U.S. Dioxin Reassessment
(USEPA, 2000b), emissions estimates for dioxin/furan releases from iron sintering facilities have been
made, as based on new quantitative testing data from two facility types. These emissions estimates
have been given a confidence rating of "B", which indicates that characterization of this source was
judged to be adequate for quantitative estimation with medium confidence in the emission factor and at
least medium confidence in the activity level. The previous inventories only had order of magnitude
estimates due to a lack of test data available for iron sintering. EPA indicated that although it would be
ideal to have even more testing data (i.e., a broader range of facilities), the database now was much
better than several years ago and additional testing would probably not fall into a high priority
designation. In Ontario, there were two iron sintering plants: one plant (Algoma) shut down, and the
remaining plant (Stelco) is the single largest point source remaining in Ontario. In 1998, Stelco re-
conducted emissions testing and results showed dioxin emissions of 5.7 to 6 g TEQ / yr. Therefore,
although iron sintering emissions have been estimated to be relatively low in the U.S. (i.e., about 1% of
the total quantified releases to air in 1995 [USEPA, 2000b]), this sector did meet the GLBTS criteria
for a candidate significant source category in Canada, comprising about 16.3% of the total 1999
Ontario Emissions Inventory.
25
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
Regulations and Programs. Currently in the U.S., there is relatively little regulatory control of
air emissions from the iron sintering sector. The Iron and Steel Foundry category MACT standard is
scheduled to be issued by the year 2000, although the effects of this ruling on dioxin emissions are
unclear. In contrast, efforts to reduce emissions from the iron sintering sector are relatively extensive in
Ontario. The Iron and Steel SOP and Canada Wide Standards (CWS) pollution prevention programs
are in place or are being developed. New testing data have been presented in the CWS process, and
technology options are currently being researched under the SOP. Industry representatives reported
that the Stelco facility has been working on the development of reduction options, with a goal of a 50%
reduction in dioxin/furan emissions by 2005. They are also currently designing new equipment (e.g.,
considering using a pretreatment nozzle system before the scrubber).
Workgroup Conclusions and GLBTS Priority Ranking. In summary, after assessing
available information regarding iron sintering in the U.S. and Canadian Great Lakes Basin, the GLBTS
dioxin/furan workgroup concluded that opportunities for further reductions from this sector were
generally limited at this time; therefore, the iron sintering sector was given a low GLBTS priority level
assignment, dependent on the success of the Canadian reduction mechanisms. From the U.S.
perspective, the low GLBTS priority designation was a result of consideration of new data which
indicate that iron sintering emissions are low (relative to the total U.S. inventory). From the Canadian
perspective, the designation was due to the fact that there was probably limited value to be added by
the GLBTS to the Iron and Steel SOP and the CWS process for iron sintering already underway in
Canada. The workgroup emphasized that the low priority designation, in the future, would be
dependent on the success of the Canadian reduction mechanisms (CWS) already underway.
3.2.7 Steel Manufacturing Electric Arc Furnaces (EAFs)
Emissions Estimates and Significance. The U.S. does not currently have sufficient
emissions data available on steel manufacturing (EAF) to include a quantitative estimate in the dioxin
emissions inventory. In the updated draft Dioxin Reassessment (USEPA, 2000b), steel manufacturing
(EAF) was given preliminary release estimates to air with a confidence rating of "D", which indicates
that sufficient information was available to make preliminary estimates; however, the confidence in the
activity level estimates or emission factor estimates was so low that the estimates cannot be included in
the sum of quantified emission from sources with confidence ratings of A, B, and C. One of EPA's
concerns with the available test data is that the measurements may not reflect start-up conditions,
particularly in light of concerns that higher emissions may occur during start up. Based on preliminary
estimates, this source would likely not meet the GLBTS criteria of a "significant" source category, at an
estimated 44.3 g I-TEQDF /yr released to the air in the U.S. in 1995 (USEPA, 2000b). Although steel
manufacturing emissions have been estimated to be relatively low in the U.S., this sector does meet the
GLBTS criteria of a "significant" source category in Canada, comprising about 12.1% (-4.25 g TEQ /
yr) of the total 1999 Ontario Emissions Inventory. There are five steel EAF facilities in Ontario.
Information on the number of steel EAF facilities in the U.S. Great Lakes basin was unavailable at the
time of this report preparation.
26
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
Regulations and Programs. Currently in the U.S., there is relatively little regulatory control of
air emissions from the steel manufacturing sector. The Iron and Steel Foundry category MACT
standard is scheduled to be issued by the year 2000, although the effects of this ruling on dioxins
emissions are unclear. In Canada, the Iron and Steel SOP and CWS pollution prevention programs
are being developed (see iron sintering discussion) and will apply to steel EAF.
Issues and Potential Opportunities: Data Quality and Additional Testing. At the time of
workgroup assessment of this sector, the key discussion point regarding steel EAF, as well as the
limiting factor in reaching closure on a GLBTS priority level assignment, was the accuracy and
availability of emissions data. Both the U.S. and Canada have used a European emission factor to
develop current emissions estimates, although new testing data in Canada has indicated that the
Canadian facility's emission factor is significantly lower than the European factor. Possible reasons for
differences in the North American and European emissions estimates were considered by the
workgroup, including infrastructure differences, differences in scrap quality, and age of facility. For
example, in some cases Europe does not have the infrastructure in place to dispose of wastes such as
chlorinated solvents, and as a result, these materials may be incorporated into the scrap pits.
Furthermore, North American facilities may use cleaner scrap, which comes from in-house recycled
sources as well as purchased scrap (mostly from automobiles). However, the workgroup also
acknowledged that some European studies had shown that the quality of the scrap does not affect
dioxin emissions as long as the fuel system is properly operating and has proper cool-down (i.e.,
quench) technology in place to prevent dioxin formation.
Regarding additional data gathering efforts in Canada, the Dofasco EAF facility has recently
conducted testing, and remaining Canadian data gaps will be addressed with additional testing that is
being pursued at other facilities, including stack testing planned at Courtice and Gerdau Steel. The
Council for Great Lakes Industries (CGLI) is coordinating with EC in the development of a voluntary
stack testing guidance document.
Recent testing conducted at the Canadian Dofasco facility, which indicated that the European
emission factor (previously used in generating emissions estimates) was significantly higher than the
Dofasco emission factor, was discussed by the workgroup. Testing of the Dofasco EAF was
representative of a full operation cycle, including all cycle process (i.e., charging, initializing batch,
refining, etc.). Although Dofasco is a very new facility, and it may not be representative of the entire
sector, industry representatives explained that it is the design of the fuel system, not the age of the
facility, that determines level of emissions. This discussion led the workgroup to conclude that
additional information gathering was especially important in light of the fact that there is such variety in
steel EAF fuel systems. Generally, representatives from the Canadian steel industry and EC agreed that
significant new testing data was forthcoming for EAF, and that it would be sufficient to assess whether
this sector should be a high, medium, or low priority for the GLBTS in Canada.
Regarding U.S. activities to gather more information on steel EAF dioxin emissions, no
additional testing is currently planned. EPA is in the initial stages of defining its highest priority testing
27
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
needs, although no schedule for testing is yet in place. The workgroup examined the issue of whether
this sector met the criteria (i.e., likely to be a significant source in the basin) to warrant additional
information gathering efforts. Industry representatives thought that the preliminary data available
indicated that steel EAF facilities were not likely to be a significant source in the basin and did not merit
putting a high priority on further testing. However, others in the workgroup cited the high variability in
EAF emissions and the need for additional test data from a wide variety of facilities to accurately
estimate steel EAF emissions and provide conclusive data on which to base a final conclusion.
Industry representatives cited the high expense of testing and lack of incentives as barriers to
voluntary industry efforts towards obtaining additional data. In addition, EPA does not have a
framework or guidance available for industries developing testing programs. The workgroup assessed
available information on the expense associated with industrial emissions testing. It was estimated that
at the time of this report the cost for a single test run would be approximately $30,000 to $35,000.
This cost would include sampling and dioxin/furan analysis; however, this price would not include any
additional expenses such as setting up sampling platforms and probe stations. An EAF industry
representative noted that many facilities do not have actual stacks, but rather roof vents, as part of their
design; therefore, modifying sampling procedures to account for this may also result in additional
expense.
Although workgroup participants agreed that there is little data on steel EAF in the U.S., steel
industry representatives expressed doubt that U.S. EAF facilities would volunteer to conduct testing in
the absence of EPA funding because many facilities had no current budget for testing. Furthermore,
due to economic burdens, mandated testing for dioxins might possibly have the result of dampening
industry willingness to participate in other voluntary activities, such as the voluntary mercury reduction
and PCB phase out activities underway at Indiana steel mills. One possible solution suggested was for
EPA to provide financial assistance for facilities that are voluntarily conducting testing, similar to the
assistance EC provides industries for voluntary testing programs. It was unknown whether EPA is in a
position to assist steel mills in financing dioxin testing, although it was suggested that the steel EAF
sector is a good candidate for combining GLBTS information gathering efforts, i.e., testing for other
GLBTS substances such as mercury. This discussion emphasized the importance of using a sector-
based approach and fully understanding the potential ramifications of activities being considered on
other reductions/monitoring efforts.
The workgroup also discussed the potential for the U.S. to use new Canadian emissions factor
data to revise emissions estimates for U.S. steel EAF facilities. Discussion included consideration of the
likelihood that U.S. data would be similar to Canadian data. In general, the raw materials and
processes used in U.S. and Canadian facilities were reported to be similar. For example, while some
European facilities accept municipal solid waste, most U.S. and Canadian facilities use only pure scrap.
However, although EAF facilities are all similar process-wise, they often are quite unique with regards
to the system configuration (e.g., fuel delivery, gas cooling systems).
28
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
Workgroup Conclusions and GLBTS Priority Ranking. In summary, after assessing
available information regarding steel manufacturing in the U.S. and Canadian Great Lakes Basin, the
GLBTS dioxin/furan workgroup concluded that, in the absence of any identified testing currently being
conducted or planned in the U.S., efforts to promote additional testing were needed. This information
need applies to U.S. steel EAF facilities only, because current information gathering efforts in Ontario
are sufficient with regards to steel EAF. In addition, new testing data forthcoming for steel EAF in
Canada will be sufficient to assess whether this sector should be designated as a high, medium, or low
priority for the GLBTS in Ontario. In the U.S., the workgroup did not assign a GLBTS priority level to
steel manufacturing EAF due to the lack of test data, and acknowledging this, suggested that ideas for
encouraging additional testing should be developed.
3.2.8 Secondary Copper Smelting
Emissions Estimates and Significance. Quantitative emissions estimates for dioxin/furan
releases from secondary copper smelting in the U.S. have been made. In the updated draft U.S. Dioxin
Reassessment (USEPA, 2000b), estimates from secondary copper smelting have been given a
confidence rating of "C", which indicates that characterization of this sector was judged to be adequate
for quantitative estimation, although with low confidence in either the emission factor and/or the activity
level. Secondary copper smelting was not included in the 1999 Ontario Emissions inventory, but
assessment of this sector is currently underway in Canada. While Canadian emissions are unknown,
this source comprised about 10.6% of the total quantified releases to air in the U.S. in 1995 (USEPA,
2000b). However, more current EPA data indicates that all of the high emission facilities in the U.S.
have closed and that there are only two secondary copper smelters remaining. EPA reported that the
dioxin/furan emissions from these two remaining facilities were estimated to be about 10 to 20 g I-
TEQ/yr maximum, and possibly as low as 5g I-TEQ/yr (Winters, personal communication, 2000).
In general, the previously high estimates of dioxin/furan releases were largely a result of
emissions from the old Franklin secondary copper smelters, in which copper wire encased in insulation
material was processed to liberate the copper. Indications are that this industry has undergone
significant consolidation in recent years, i.e., all of the high emission facilities have closed down, and that
the feed scrap is now cleaner.
Regulations and Programs. Currently there is relatively little regulatory or other control of air
emissions from secondary copper smelting. In the U.S., although there are currently no regulations
under the CAA controlling dioxin air emissions from the secondary copper smelting industry, this sector
is on the list of additional source categories EPA intends to include under CAA 112(k). Comment is
still under request for this source category (63FR 49249).
Workgroup Conclusions and GLBTS Priority Ranking. In summary, after assessing
available information regarding secondary copper smelting in the U.S. and Canadian Great Lakes basin,
the GLBTS dioxin/furan workgroup concluded that few opportunities exist for this sector at this time.
In the U.S., secondary copper smelting was designated a low GLBTS priority, due to new data
29
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
indicating very low emissions from remaining facilities, and dependent on the high emission facilities
remaining closed. Secondary copper smelting in Canada, however, received no priority designation
due to a lack of information.
3.2.9 Landfill Fires
Emissions Estimates and Significance. The U.S. does not currently have sufficient
emissions data available on landfill fires to include a quantitative estimate in the inventory. In the
updated draft Dioxin Reassessment (USEPA, 2000b), preliminary release estimates to air indicate that
landfill fires have the potential to be a very large source category. To date, emissions estimates have
been made with a confidence rating of "D", which indicates that sufficient information was available to
make preliminary estimates; however, the confidence in the activity level estimates or emission factor
estimates was so low that the estimates cannot be included in the sum of quantified emission from
sources with confidence ratings of A, B, and C. Based on the magnitude of the preliminary U.S.
emission estimate, 1,050 g I-TEQDF /yr released to the air in the U.S. in 1995 (USEPA, 2000b), this
source was considered a candidate significant source category. The U.S. inventory used a Swedish
emission factor in deriving the U.S. inventory estimate for landfill fires, of which there are two types:
accidental and underground methane fires. Estimates of dioxin/furan emissions from landfill fires in
Ontario are not included in the 1999 Ontario Inventory.
Regulations and Programs. At the time of workgroup assessment, no verifiable information
was available on regulatory or other control of air emissions from landfill fires. Current regulations
regarding landfills were of interest to the workgroup (e.g., permits, reporting requirements, management
plans), but details were unknown. The workgroup noted that older landfills not under RCRA may be
important, and that in past years (pre-regulation), landfill fires were often set intentionally.
Workgroup Conclusions and GLBTS Priority Ranking. In summary, after assessing
available information regarding landfill fires in the U.S. and Canadian Great Lakes basin, the GLBTS
dioxin/furan workgroup concluded that information is needed on both emission factors and on the
frequency of landfill fires in both the U.S. and Canada. Higher priority was placed on the need for
frequency information, i.e., the activity level is more uncertain than the emission factor. However, even
with a limited occurrence, the emission factor indicates that landfill fires have the potential to be a very
large dioxin/furan source. In addition, information is needed on current regulations regarding landfills.
At the time of this report preparation, landfill fires received no GLBTS priority designation in the U.S.
or Canada due to a lack of information.
3.2.10 Other Smaller Sources
Forest Fires. A quantitative emissions estimate for dioxin/furan releases from forest, brush,
and straw fires of 208 g I-TEQDF in 1995 was made in the 1998 Draft Inventory (USEPA, 1998) and
in the updated draft Dioxin Reassessment (USEPA, 2000b). As this represented approximately 8% of
the total quantified releases to air in the U.S. in 1995 in these versions of the inventory, this source was
30
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
evaluated as part of the decision tree process by the workgroup. However, in revisions to the updated
draft Dioxin Reassessment for SAB review (USEPA, 2000c), dioxin emissions from forest, brush and
straw fires are expected to receive a lowered confidence rating of "D". As a result, they will be
considered preliminary estimates and will not be included in the total quantifiable inventory.
Currently, other agencies, including the U.S. Forest Service and Department of Interior, have
the primary lead on wildland fire management in the U.S., although EPA issued an Interim Air Quality
Policy on Wildland and Prescribed Fires in 1996 in an effort to control particulate matter emissions
from prescribed burning. Generally, other issues and concerns have a greater influence on fire
management policy than dioxin/furan emissions. Therefore, in light of the current program structure, the
workgroup concluded there are limited opportunities for dioxin/furan reductions from forest fires.
Acknowledging that the GLBTS decision tree ranking process is intended to identify the most
obvious or important sources for workgroup focus, forest fires did not qualify, per the GLBTS
workgroup's assessment, as a high GLBTS priority at this time. The rationale for this low GLBTS
priority designation was based on the limited reduction opportunities for the workgroup. The
workgroup designated forest fires as a low GLBTS priority with the condition that the open burning
subgroup would look further into the significance of agricultural burning.
Diesel Fuel Combustion. Quantitative emissions estimates for dioxin/furan releases from
diesel fuel combustion have been made in the U.S. and Canada. In the updated draft U.S. Dioxin
Reassessment (USEPA, 2000b), diesel fuel combustion has been given a confidence rating of "C",
which indicates that the characterization of diesel fuel combustion was judged to be adequate for
quantitative estimation with low confidence in either the emission factor and/or the activity level. This
source marginally meets the GLBTS criteria of a "significant" source category, comprising about 1.3%
percent of the total quantified releases to air in the U.S. in 1995 (USEPA, 2000b), and 8.9% of the
total 1999 Ontario Emissions Inventory.
Acknowledging that the GLBTS decision tree ranking process is intended to identify the most
obvious/important sources for workgroup focus, diesel fuel combustion did not qualify, per the GLBTS
workgroup's assessment, as a high GLBTS priority at this time. The rationale for this low GLBTS
priority designation was based on limited reduction opportunities for the workgroup, and the fact that
this sector represents a relatively minor source (i.e., it has relatively low emissions estimates compared
to the other sectors that have been discussed). Estimated emissions from diesel fuel combustion in the
U.S. were below the 2% cutoff point for prioritization consideration. In Canada, although dioxin/furan
releases from diesel fuel combustion are a larger percent of the total Ontario inventory (-8.9%), diesel
fuel is in the process of being addressed by EC under new authority granted in April, 2000. EC will
now have authority to regulate both engine emissions and fuel content for vehicle engines, which used to
be solely regulated by the Ministry of Transportation.
Utility Coal Combustion. Quantitative emissions estimates for dioxin/furan releases from
utility coal combustion have been made in the U.S. and Canada. In the updated draft Dioxin
31
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
Reassessment (USEPA, 2000b), utility coal combustion has been given a confidence rating of "B",
which indicates that characterization of this source was judged to be adequate for quantitative
estimation with medium confidence in the emission factor and at least medium confidence in the activity
level. Quantitative emissions estimates, based on stack testing of six of 29 Canadian facilities, have also
been made in Ontario. This source marginally meets the GLBTS criteria of a "significant" source
category, comprising about 2.4% of the total quantified releases to air in the U.S. in 1995 (USEPA,
2000b), and about 2% of the total 1999 Ontario Emissions Inventory.
There are currently no federal or state restrictions on dioxin emissions from coal-fired utilities,
and EPA has been congressionally required to defer regulation until the findings of a National Academy
of Science (NAS) Report is completed (July 2000). The Agency also announced on April 25, 2000
that national non-hazardous waste standards under RCRA Subtitle D are needed for coal combustion
wastes disposed in surface impoundments and landfills and used as minefilling. Therefore, it was
concluded that there are limited opportunities for further dioxins/furans reductions from the utility coal
combustion sector at the time of this report preparation.
Utility coal combustion was designated as a low GLBTS priority at this time, based on limited
reduction opportunities for the workgroup, and the fact that this sector represents a relatively minor
source (i.e., it has relatively low emissions estimates compared to the other sectors that have been
discussed). In addition, estimated emissions from utility coal combustion (at 2.6% of the U.S. inventory
and 2% of the Ontario inventory) are very close to the 2% cutoff point below which this sector would
not even enter the GLBTS prioritization consideration.
Wood Waste Combustion. In the U.S., wood combustion is regulated via New Source
Performance Standards (NSPS) for particulates, fuel restrictions, and boiler specifications. It was
determined in workgroup investigation that salt-laden wood (which can result in elevated dioxin
emissions) was not included in the wood waste combustion category in the Ontario Inventory, because
this was associated only with the west coast of Canada. Alternatives for wood waste disposal were
considered in workgroup analysis of this sector. Currently, the different types of facilities that may burn
waste wood products include pulp and paper mills, sawmills, and general forestry product operations.
The potential for land application as a means of disposal for wood waste was considered because,
although this waste has value as fuel, it is not hazardous and in theory could be put back into areas
where clear cuts had occurred. However, in the U.S., logistics and economics were identified as
important limiting factors in implementing this alternative. For example, hauling costs may be elevated
due to the different types of trucks that are required to haul wood waste. In addition, because the
wood scrap material is light, the cost of transportation per ton greatly increases. Wood waste also has
preferred value as a fuel source or as a mulch / landscaping product (wood material mixed with soil,
etc. is often composted because it is unsuitable for burning in industrial boilers). Additionally, in the
U.S., a large quantity of the harvested timber comes from private lands and these areas generally do not
want the wood waste back. In Canada, on the other hand, private lands are not an issue because
about 99% of the logged lands are government owned.
32
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
The wood waste combustion sector was designated as a low GLBTS priority at this time. The
rationale for this low GLBTS priority designation was based on limited opportunities for the
workgroup, and the fact that this sector represents a relatively minor source (i.e., it has relatively low
emissions estimates compared to the other sectors that have been discussed). In addition, estimated
emissions from wood waste combustion (at <2% of the U.S. inventory and 2% of the Ontario
inventory) are very close to the 2% cutoff point below which this sector would not even enter the
GLBTS prioritization consideration.
Hazardous Waste Incinerators. Quantitative emissions estimates for dioxin/furan releases
from hazardous waste incinerators have been made in the U.S. and Canada. In the updated draft U.S.
Dioxin Reassessment (USEPA, 2000b), hazardous waste incineration has been given a confidence
rating of "B", which indicates that characterization of hazardous waste incineration was judged to be
adequate for quantitative estimation with medium confidence in the emission factor and at least medium
confidence in the activity level. Quantitative emissions estimates, based on stack testing of both
Canadian facilities, have also been made in Ontario. While this source does not meet the GLBTS
criteria for a candidate significant source category based on U.S. emissions (at 0.2% of the total
quantified releases to air in the U.S. in 1995), it marginally meets the GLBTS criteria at 2.1% of the
total 1999 Ontario Emissions Inventory.
In the U.S., hazardous waste incinerators are subject to same regulatory controls (under CAA
and RCRA) as hazardous waste burning cement kilns. In Canada, the CWS process to establish
reduction targets is underway with draft standards currently proposed. CWS are predicted to result in
reductions of as much as 97% nationally.
Hazardous waste incineration was designated as a low GLBTS priority at this time. The
rationale for this low GLBTS priority designation was based primarily on the fact that this sector
represents a relatively minor source (i.e., it has relatively low emissions estimates compared to the other
sectors that have been discussed). In addition, estimated emissions from hazardous waste incinerators
are very close to the 2% cutoff point below which this sector would not even enter the GLBTS
prioritization consideration.
4.0 PROPOSED OPTIONS FOR ACHIEVING FURTHER DIOXIN/FURAN EMISSIONS
REDUCTIONS
4.1 STRATEGIC APPROACH
Based on the results of the decision tree analysis, the GLBTS dioxin/furan workgroup has
designated four sectors for initial priority focus in pursuing the GLBTS goal of achieving additional
reductions in anthropogenic sources of dioxin emissions in the Great Lakes basin. These sectors
include medical waste incineration (in Canada only), backyard trash/open burning, residential wood
combustion, and pentachlorophenol (PCP) treated wood (in the U.S. only). In addition, the
workgroup has not assigned a priority level to steel manufacturing (EAF) in the U.S., secondary copper
33
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
smelting in Canada, or landfill fires in either country due to insufficient data available to fully characterize
the significance of these sources in the Great Lakes basin. Better information on ash management from
municipal and medical waste incineration was also identified as a follow-up issue for the workgroup.
Therefore, reduction options identified by the workgroup focus on these priority sectors and
information needs. In looking across the proposed options discussed below, certain common elements
can be identified which form the basis of a unifying strategic approach towards implementation of cost-
effective reduction options. These strategic elements are to:
! Conduct coordinated outreach efforts
! Address key information gaps
! Periodically assess progress and success of programs in place and re-evaluate potential for
further reductions, and
! Coordinate with the National Strategy and Dioxin Exposure Initiative
Conduct Coordinated Outreach Efforts
Outreach efforts will focus on increasing public awareness concerning sources of dioxins and
the steps the public can take to help reduce dioxin and furan releases. These efforts will be coordinated
as possible with other workgroup efforts and broader PBT outreach efforts. For example, outreach
efforts to reduce open burning may provide an opportunity to coordinate with other GLBTS
workgroups, as well as with an integrated GLBTS effort to build awareness of strategy goals and
opportunities for public involvement.
Address Key Information Gaps
Additional information was identified as a need for several targeted sectors, including: waste
incineration (ash disposal), backyard trash/open barrel burning (prevalence and factors), residential
wood combustion (dioxin emissions from wood stoves), PCP treated wood (disposal fate of utility
poles), steel EAF (emissions in the U.S.), secondary copper smelting (emissions in Canada), and landfill
fires (activity levels). In certain cases (i.e., steel manufacturing, secondary copper smelting, and landfill
fires), these information gaps precluded the assignment of a GLBTS priority level to a given sector.
Therefore, addressing these information needs will be a key focus area for the dioxin workgroup.
Periodically Assess Progress and Success of Programs in Place and Re-evaluate
Potential for Further Reductions
Efforts directed towards dioxin/furan sources that were considered by the workgroup and
designated as low GLBTS priority (on the basis of either low emissions or limited potential for further
reductions beyond existing programs) will not be a key workgroup focus at this time. For these
sectors, however, the workgroup recognizes the need for and commits to periodic workgroup review
of progress and/or continued success of regulatory and non-regulatory mechanisms in place for these
sectors. For example, the workgroup will periodically assess progress in compliance with dioxin air
34
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
emission reduction programs for the incineration sectors, including MACT standard implementation in
the U.S. and Canada Wide Standard development in Ontario. To conduct this review in the U.S., the
workgroup will utilize the improved centralized database currently being developed by EPA to hold
information being collected on control technology compliance, including emissions from MWCs,
MWIs, hazardous waste incinerators, cement kilns, and the pulp and paper industry. This data is being
collected as part of MACT and Best Available Technology (BAT) regulations and compliance testing
reports.
The workgroup also recognized the need for periodic reassessment of new information that
might indicate the need to reconsider a source's priority designation.
Coordinate with the National Strategy and Dioxin Exposure Initiative
Using the U.S. Dioxin Reassessment and emerging scientific understanding of dioxin sources,
fate and transport, levels of human exposure, and toxic effects on humans and other animals, EPA is in
the process of reviewing its national dioxin control efforts to determine if, collectively, they adequately
address dioxin risks, and to determine if redirected or additional action is needed. The result of this
multi-program dioxin review will be a draft EPA Cross-Media Dioxin Strategy that will be released
concurrent with the final EPA Dioxin Reassessment scheduled for completion in early 2001. Although
the Cross-Media Dioxin Strategy is broader in focus than the GLBTS (e.g., addressing exposure
reduction), close coordination between the GLBTS to achieve further reductions in anthropogenic
dioxin emissions and the Cross-Media Dioxin Strategy is essential to an effective national strategy.
4.2 KEY PROPOSED ACTIONS
4.2.1 Municipal Waste Combustion (MWC) and Medical Waste Incineration (MWI)
Gather Information on Ash Management. The primary GLBTS opportunity related to
waste incineration at the current time is to further examine the issue of ash management. In the
assessment process, the GLBTS dioxin workgroup concluded that, although these sectors were
deemed a low GLBTS priority in the U.S., a more systematic inventory was needed on the
management and disposal fate of fly and bottom ash from waste incineration. In particular, an
information gap was identified on the land disposal practices actually occurring within the Great Lakes
watershed. The gathering of disposal information for MWCs is predicted to be relatively easy because
there are a limited number of facilities in the basin. On the other hand, because there are many more
MWI facilities in the basin, gathering information on medical ash disposal might be more challenging.
Proposed steps in the development of the ash disposal information include:
1. Assess available information and determine whether the information on ash disposal is
already adequately available (e.g., state reports to federal government, state agencies/solid
waste authorities, and industry experts), or if it requires new data collection. This
35
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
investigation would include an assessment of data accessibility and the quality of reporting
records.
2. If additional data are needed, design a plan for additional data collection (e.g., determine
whether to conduct a full inventory or representative sampling).
3. Implement the data collection plan.
4.2.2 Open Burning
As a high GLBTS priority area, the dioxin/furan workgroup has already initiated an open
burning subgroup to address key identified opportunities, discussed below, for this dioxin source.
Although the subgroup is in the early stages of planning, an initial task the subgroup has considered is
conducting a complete assessment of regulations related to open burning in the Great Lakes region, and
considering options for outreach. The subgroup has also discussed the potential for conducting
educational outreach on open burning, possibly as an extension of a Duluth, Minnesota, open burning
outreach campaign that is already planned.
Overall, there are three main categories of opportunity that are being considered for achieving
dioxin reductions from open burning. These are:
! Strengthening and/or enforcement of local regulatory mechanisms,
! Public education and outreach, and
! Development of the necessary infrastructures to allow practical alternatives to open burning.
In addition to these opportunities, further examination of reduction potential related to
agricultural burning also represents a GLBTS workgroup opportunity. Recognizing data gaps related
to the significance of agricultural burning in the Great Lakes basin, the workgroup has identified
research on this issue as a primary initial goal.
Regulatory Mechanisms. Although federal regulation of open burning does not exist, open
burning is often banned or limited by many local governments. However, enforcement of these local
regulations has been identified as a key weakness in achieving reductions in open burning. For
example, in Wisconsin, although open burning laws require permits for burns, there is no effective
mechanism in place to penalize violators. Therefore, a major challenge regarding open burning is to
encourage the strengthening of enforcement of local regulatory mechanisms. Specific opportunities for
the dioxin workgroup in this area have not yet been identified.
Public Education and Outreach. Recognizing current limitations of regulatory mechanisms for
controlling open burning, a major GLBTS opportunity for achieving dioxin reductions from open
burning lies in public education and outreach to help change behavior. Proposed components of this
effort include:
! Developing and distributing information on the general prevalence of open burning
36
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
! Understanding why people engage in backyard burning where alternatives do exist and
other factors which affect the extent of open burning
Defining cost-effective options for outreach
Preparing informational pamphlets and other outreach material on open burning (public
education materials with alternatives)
! Conducting a basinwide campaign, possibly in coordination with other GLBTS
workgroups.
Potential methods discussed for future efforts that may be conducted by interested stakeholders
to quantify the prevalence of backyard burning include surveys, or possible comparison of per-capita
waste generation in rural areas to the quantity of waste that is disposed in landfill or other municipal
collection. A survey similar to that conducted by the Western Lake Superior Sanitary District
(WLSSD) (see discussion in section 3.2) to assess opinions and determine motives for open burning,
but focused on those who are actively practicing open burning, was also identified by the workgroup as
having potential use in this information gathering effort.
In addition, EPA and EC support sector-based approaches that address multiple GLBTS
chemicals where applicable, and encourage the coordination of reduction activities, as possible, with
other GLBTS workgroups. Outreach and education related to open burning may represent a potential
opportunity for coordination with other GLBTS workgroups, particularly the GLBTS benzo(a)pyrene
(B(a)P) workgroup.
Assessment and Support of Infrastructure Needs. Early indications from surveys such as
the WLSSD survey suggest that infrastructure changes may be required to obtain significant reductions
in open burning. The cost of local waste collection services, the proximity of recycling or drop-off
centers to most residences, storage of waste at both the residential and community level, and health
concerns associated with waste storage and management all represent community infrastructure realities
that will influence the feasibility of achieving reductions in open burning. The first step is to understand
the key infrastructure issues that affect the practice of open burning. The next step is to explore
feasible, cost-effective options for creating an infrastructure that will support reductions.
4.2.3 Residential Wood Combustion
Based on high emissions estimates and the presence of opportunities to promote reductions
(i.e., due to the lack of regulatory control), the GLBTS dioxin/furan workgroup concluded that
residential wood combustion should be designated as a high GLBTS priority for dioxin/furan
workgroup actions. Pending additional information on the extent to which the newer EPA-certified
wood stoves reduce dioxin emissions, the dioxin workgroup may consider future coordination with the
GLBTS B(a)P workgroup on voluntary reduction initiatives such as wood stove changeovers. Efforts
aimed at residential wood combustion have already been initiated by the B(a)P workgroup, and consist
of pilot projects to gauge the regional response and potential impacts of wood stove changeover (i.e.,
37
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
to EPA-certified, etc.). These pilot projects consist of outreach to communities and coordination with
industry sponsors.
Wood stove changeover programs promote the replacement of older wood stoves with newer,
EPA-certified wood stoves with PM control technology, as well as natural gas stoves and log sets. The
newer EPA-certified stoves are known to reduce particulate matter (PM) emissions and B(a)P, but the
exact nature of the association between dioxins/furans and PM is currently unclear. Changeovers to
gas and liquid propane heating units, however, are known to be effective in reducing dioxin/furan
emissions. Additional research on the nature of dioxin/furan releases from wood stoves is currently
being finalized in the Canadian wood stove testing program, with the goal of assessing the dioxin
reduction potential of EPA-certified stoves. The study will compare emissions from conventional and
new certified wood stoves and will help to determine effectiveness of particulate matter (PM) controls
on dioxin/furan emissions from wood stoves. Following assessment of this forthcoming research on
dioxin emissions from wood stoves, the workgroup can more accurately assess the extent to which they
should coordinate on wood stove changeovers with the B(a)P workgroup, and if necessary, develop
additional proposed actions that will result in emission reductions from RWC.
4.2.4 Pentachlorophenol Treated Wood
Based on the large amount of dioxin contained in PCP-treated wood and the lack of
information on the ultimate disposal fate of PCP-treated utility poles, the GLBTS dioxin/furan
workgroup concluded that PCP treated poles in the U.S. would be designated as a medium GLBTS
priority. This priority designation will be revisited by the workgroup, dependent on more information
becoming available regarding de facto disposal. Although the data identified on PCP pole disposal
(i.e., information presented at the February 1999 utility pole conference in Florida which showed that
about 50% of poles taken out of service did not have controlled disposal) are not definitive, it is the
best information currently available for use by the workgroup for default assumptions until new
information surfaces. Due to the large mass of PCP involved, the workgroup concluded that a burden
of proof is required to confirm the degree to which used poles are disposed of properly. The key
opportunity for immediate workgroup focus is to verify that all PCP treated utility poles (recycled poles
included) are being properly managed to the end of their useful life. In contrast to some of the other
dioxin sources, which are being primarily addressed with emissions reductions efforts, efforts directed
towards PCP-treated poles will focus on preventing potential releases of dioxins from a large reservoir
source existing as man-made products.
As a first step in the information gathering process, the Utilities Solid Waste Activities Group
(USWAG) is currently planning an information gathering effort on the disposal and fate of utility poles in
the Great Lakes basin. When finalized, the results of the USWAG information gathering survey will be
assessed by the workgroup and used to focus future priority actions and identify any other information
needs. For example, because the USWAG survey will focus only on utilities, the secondary reuse
market fate may still remain an unknown and require additional research. Once information from the
survey is available, a re-assessment of the importance of this source will be considered.
38
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
Additional information needs pertaining to PCP-treated poles have also been identified by the
dioxin workgroup, including: details on the regulatory drivers that may affect pole disposal in the U.S.,
and information on whether there is an infrastructure in place to trace these recycled/reused poles.
Although PCP treated wood was designated as a low GLBTS priority in Canada due to
significant controls and a life-cycle analysis study of PCP treated wood that is underway through the
Canadian Wood Preservers SOP, progress under the SOP will be assessed by the workgroup as it
develops, including results of the life-cycle analysis study for utility poles/railroad ties and the
development of best management options.
4.2.5 Steel Manufacturing (EAF)
Because the dioxin workgroup was unable to determine a priority designation for steel
manufacturing EAF due to a lack of testing data, the key proposed opportunity for future workgroup
focus is to determine whether dioxin/furan testing is feasible at U.S. steel EAF facilities, and if so, to
explore how to conduct this testing. Proposed steps and support efforts for dioxin/furan testing at U.S.
steel EAF facilities include:
! Determine whether there are any U.S. steel EAF facilities interested in conducting voluntary
testing
! Identify incentives to help encourage voluntary testing by the steel industry
! Determine any opportunities for financial support for testing
! Coordinate with steel industry trade associations on voluntary testing
! Develop EPA guidance for testing (e.g., hand-in-hand testing), or provide EPA peer review
of industry-conducted testing.
Alternatively, forthcoming Canadian data may be evaluated relative to its potential use for developing
U.S. estimates, if stack emissions testing of U.S. steel facilities is not feasible.
In addition, the steel EAF industry represents a likely candidate for coordination of multiple
monitoring activities (i.e., multiple GLBTS chemicals). For example, with the increased interest in
mercury emissions (e.g., from auto scrap use at EAF), opportunities to combine mercury and
dioxin/furan monitoring may exist. As a first step, the key workgroup opportunity regarding
coordination is to discuss the issue with other GLBTS workgroup co-leads, and to follow up on the
issue with the GLBTS Integration Group.
4.2.6 Landfill Fires
Landfill fires received no GLBTS priority designation in the U.S. or Canada due to a lack of
information. Reduction opportunities depend on information regarding the frequency and nature of
landfill fires. Primary focus areas for information gathering efforts that were identified by the dioxin
workgroup include:
39
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
! Frequency of landfill fires in both the U.S. and Canada (i.e., activity level estimates are
needed)
! Current regulations regarding landfills
! Factors associated with the outbreak of landfill fires
! Emission factors for landfills.
Potential information sources on the frequency of landfill fires identified by the workgroup include:
! Operating permits (all landfill fires must be reported under the conditions of a facility's
operating permit)
! States and/or solid waste authorities who issue landfill permits
! The possibility of a central repository (e.g., of state reports) within the federal governments.
4.3 NEXT STEPS
Next steps for the dioxin workgroup will be to develop detailed plans for implementing
reduction and/or information gathering projects for the sectors designated high or medium priority or
identified as needing additional data in this GLBTS Step 3 analysis. The plans will be implemented as
Step 4 of the GLBTS four-step process: Implementing actions to work toward the goal of virtual
elimination.
40
-------
Dioxin/Furan Reduction Options 9/27/00 External Review
REFERENCES
AWPI. American Wood Preservers' Institute http://www.awpi.org and the AWPI Penta Council,
http ://www. awpi. org/pentacouncil/home.html
USEPA. 2000a. PCDD (Dioxins) and PCDF (Furans): Sources and Regulations (Draft Report).
Prepared by Battelle for U.S. Environmental Protection Agency, Great Lakes National Program Office.
May 26, 2000.
USEPA. 2000b. Exposure and Human Health Reassessment of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin
(TCDD) and Related Compounds (Peer Review Draff). [Part I (Estimating Exposure): EPA/600/P-
00/001Ab; Part H (Health Assessment): EPA/600/P-00/001Ae; Part HI (Integrated Summary):
EPA/600/P-00/001Ag]. National Center for Environmental Assessment, Office of Research and
Development, U.S. Environmental Protection Agency. Washington, DC. Access:
www.epa.gov/ncea/dioxin.htm. June, 2000.
USEPA. 2000c. Exposure and Human Health Reassessment of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin
(TCDD) and Related Compounds (SAB Review Draff). National Center for Environmental
Assessment, Office of Research and Development, U.S. Environmental Protection Agency, [as
conveyed by Dwain Winters, OPPT, 9/19/00]
USEPA. 1999. Final Technical Support Document for HWC MACT Standards, Volume IV:
Compliance with the HWC MACT Standards. Office of Solid Waste and Emergency Response, U.S.
Environmental Protection Agency. Washington, DC. July, 1999.
USEPA. 1998. The Inventory of Sources of Dioxin in the United States (External Review Draft).
EPA/600/P-98/002Aa. April, 1998.
WLSSD. 2000. Increased Awareness: Insight into Public Patterns and Perceptions - A Survey of
Residents of Northeast Minnesota & Northwest Wisconsin (Summary Report). Prepared by Zenith
Research Group for the Western Lake Superior Sanitary District (WLSSD). January 18, 2000.
Winters, Dwain. 2000. U.S. Environmental Protection Agency, Office of Pollution Prevention and
Toxics, personal communication.
41
------- |