United States
Environmental Protection
Agency
Office of Information
Analysis & Access
Washington, DC 20460
EPA-745-B-00-021
December 2000
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
ACT-SECTION 313:
Guidance for Reporting Toxic Chemicals within the
Dioxin and Dioxin-like Compounds Category
Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA)
requires certain facilities manufacturing, processing, or otherwise using listed toxic chemicals to report
the annual quantity of such chemicals entering each environmental medium. Such facilities must also
report pollution prevention and recycling data for such chemicals, pursuant to section 6607 of the
Pollution Prevention Act 42 U.S.C. 13106.
TABLE OF CONTENTS
Section 1.0 INTRODUCTION 1
1.1 Background 1
1.2 Who Must Report? 2
1.3 What are the Reporting Thresholds? 3
1.4 What are Dioxin and Dioxin-like Compounds and Which Chemicals are
Included in the EPCRA Section 313 Dioxin and Dioxin-like Compounds
Category? 5
1.4.1. Formation of Dioxin and Dioxin-like Compounds During Combustion 7
1.5 What Activities are Covered by the Qualifier for the Dioxin And Dioxin-like
Compounds Category? 9
1.6 What Other Changes to the EPCRA Section 313 Reporting Requirements
Apply to the Dioxin and Dioxin-like Compounds Category? 12
1.6.1 DeMinimis Exemption 12
1.6.2 Form A Exclusion 12
1.6.3 Range Reporting 12
1.6.4 Data Precision 13
Section 2.0 GUIDANCE ON ESTIMATING ENVIRONMENTAL RELEASES OF DIOXIN
AND DIOXIN-LIKE COMPOUNDS 14
2.1 General Guidance 14
2.1.1 Approach 1 - Use Actual Facility-Specific Monitoring Data 17
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2.1.2 Approach 2 - Use Facility-Specific Emission Factors 17
2.1.3 Approach 3 - Use Facility-Specific EPA Default Emission
Factors 19
2.2 Consideration of Non-detects 20
Section 3.0 EXAMPLES OF CALCULATING EMISSIONS TO THE AIR, WATER, AND
LAND 21
3.1 Approach 1- Use Actual Facility-specific Release Data 21
3.1.1 Example of Air Releases Using Stack Monitoring Data 21
3.1.2 Example of Calculating Water Releases Using NPDES Monitoring
Data 22
3.1.3 Example of Estimating Releases to Land 23
3.2 Example of Estimating Releases Using Emission Factors 25
3.2.1 Example of Estimating Air Releases 25
3.2.2 Example of Estimating Water Releases 26
3.2.3 Example of Estimating Releases to Land 26
Section 4.0 FACILITY-SPECIFIC EPA DEFAULT EMISSION FACTORS 28
4.1 Pulp And Paper Mills And Lumber And Wood
Products 29
4.1.1 Applicability 29
4.1.2 Emission Factors for Releases to Water From Bleached
Chemical Pulp Mills 30
4.1.3 Emission Factors for Releases to Land From Bleached
Chemical Pulp Mills 31
4.1.4 Emission Factors for Releases to Air From Pulp Mill or Lumber
and Wood Products Facilities 32
4.2 Secondary Smelting And Refining of Nonferrous Metals 33
4.2.1 Applicability 33
4.2.2 Secondary Aluminum Smelters 34
4.2.3 Secondary Lead Smelters 37
4.2.4 Secondary Copper Smelters/Refiners 39
4.3 CementKilns 42
4.3.1 Applicability 42
4.3.2 Summary Description/Air Emission Factors 42
4.4 Utilities 45
4.4.1 Applicability 45
4.4.2 Description/Emission Factors for Coal-Fired Electric Utility Boilers 45
4.4.3 Description/Emission Factors for Oil-Fired Electric Utility
Boilers 46
4.4.4 Description/Emission Factors for Wood-Fired Electric Utility Boilers 47
4.5 Hazardous Waste Combustion 49
4.5.1 Applicability 49
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Section 5.0
Section 6.0
Section 7.0
4.5.2 Emission Factors for Commercial Boilers and Industrial Furnaces
Burning Hazardous Waste (Other than Cement Kilns)
4.5.3 Cement Kilns Burning Hazardous Waste as Supplemental Fuel . .
4.5.4 Hazardous Waste Incineration (HWI) Facilities
GLOSSARY
CONVERSION FACTORS .
REFERENCES
49
50
53
58
67
71
LIST OF TABLES
Table 1-1. Homoloques and Positional Isomers of CDDs, CDFs
Table 1-2. Members of the EPCRA Section 313 Dioxin and Dioxin-like Compounds Category
Table 4-1. Average Emission Factors (pg/L) for Estimating Wastewater Discharges of Dioxin and
Dioxin-like Compounds into Surface Water From Bleached Chemical Pulp Mills
Table 4-2. Average Emission Factors (ng/kg) for Land Disposal of Dioxin and Dioxin-like
Compounds in Wastewater Sludge From Bleached Chemical Pulp Mills
Table 4-3. Average Emission Factors (ng/kg) for Air Releases of Dioxin and Dioxin-like
Compounds From the Combustion of Wood Waste and Bark (as fired) at Pulp Mill or
Lumber and Wood Product Industry Facility Boilers
Table 4-4. Average Emission Factors (ng/kg scrap aluminum processed) For Estimating Air
Releases of Dioxin and Dioxin-like Compounds From Secondary Aluminum Smelters
Table 4-5. Average Emission Factors (ng/kg) For Estimating Air Releases of Dioxin and Dioxin-
like Compounds From Secondary Lead Smelters
Table 4-6. CDD/CDF Emission Factors (ng Dioxin and Dioxin-like Compounds per kg copper
scrap processed) For Secondary Copper Smelters
Table 4-7. Average Emission Factors (ng/kg cement clinker produced) For Estimating Air
Releases of Dioxin and Dioxin-like Compounds From Cement Kilns Not Combusting
Hazardous Waste as Supplemental Fuel
Table 4-8. Average Emission Factors (ng/kg coal combusted) For Estimating Air Releases of
Dioxin and Dioxin-like Compounds From Coal-Fired Utility Boilers
Table 4-9. Average Emission Factors (pg/L oil combusted) For Estimating Air Releases of Dioxin
and Dioxin-like Compounds From Oil-Fired Utility Boilers
Table 4-10. Average Emission Factors (ng/kg of wood combusted) For Estimating Air Releases of
Dioxin and Dioxin-like Compounds From Wood-Fired Electric Utility Boilers
Table 4-11. Average Emission Factors (ng/kg waste feed) For Estimating Air Releases of Dioxin
and Dioxin-like Compounds From Boilers and Industrial Furnaces Burning Hazardous
Waste (other than cement kilns)
Table 4-12. Average Emission Factors (ng per dscm) For Estimating Air Releases of Dioxin and
Dioxin-like Compounds From Cement Kilns Combusting Hazardous Waste as
Supplemental Fuel
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Table 4-13. Average Emission Factors (ng/kg waste feed) For Estimating Air Releases of Dioxin
and Dioxin-like Compounds From Hazardous Waste Combustion Facilities
LIST OF FIGURES
Figure 1. Chemical Structure of Dioxin-Like Compounds
Figure 2. Decision Tree for Selecting Emission Estimation Technique
LIST OF ABBREVIATIONS AND ACRONYMS
BACT
BADT
CAAA
CAS
CDDs
CDFs
dscf
dscm
EPCRA
ESP
g
kg
L
Ib
m3
MACT
ng
°C
°F
Pg
s
SIC
yr
Best Available Control Technology
Best Available Demonstrated Technology
Clean Air Act Amendments
Chemical Abstract Service
Chlorinated dibenzo-p-dioxins
Chlorinated dibenzofurans
dry standard cubic foot
dry standard cubic meter
Emergency Planning and Community Right-to-Know Act of
1986
Electrostatic precipitator
gram
kilogram
liter
pounds (avoir)
cubic meter
Maximum Achievable Control Technology
nanogram. 1 E-09 gram
Temperature in Celsius
Temperature in Fahrenheit
picogram. 1 E-12 gram
seconds
Standard Industrial Classification Code
year
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Section 1.0. INTRODUCTION
Section 1.1. Background
On October 29, 1999, the Environmental Protection Agency (EPA) promulgated a final rule
(64 FR 58666) adding a category of dioxin and dioxin-like compounds to the list of toxic chemicals
subject to the reporting requirements under section 313 of the Emergency Planning and Community
Right-to-Know Act of 1986 (EPCRA). The reporting threshold for the category was also established
as 0.1 grams manufactured, processed, or otherwise used. The category listing is:
Dioxin and dioxin-like compounds (Manufacturing; and the processing or otherwise use of
dioxin and dioxin-like compounds if the dioxin and dioxin-like compounds are present as
contaminants in a chemical and if they were created during the manufacturing of that chemical)
(40CFR372.65(c))
The purpose of this document is to provide guidance on the reporting requirements of EPCRA section
313 for the dioxin and dioxin-like compounds category. EPCRA section 313 covered facilities that
exceed the reporting threshold for the dioxin and dioxin-like compounds category are subject to the
EPCRA section 313 annual reporting requirements beginning with reporting year 2000, with the first
reports due by July 1, 2001.
This document explains the EPCRA section 313 reporting requirements, and provides guidance
on how to estimate annual releases and other waste management quantities of dioxin and dioxin-like
compounds to the environment from certain industries and industrial activities. Because each facility is
unique, the recommendations presented may have to be adjusted to the specific nature of operations at
your facility or industrial activity.
A primary goal of EPCRA is to increase the public's knowledge of, and access to, information
on the presence and release and other waste management activities of EPCRA section 313 toxic
chemicals in their communities. Under EPCRA section 313, certain facilities (see Section 1.2, below)
exceeding certain thresholds (see Section 1.3) are required to submit reports (commonly referred to as
Form R reports or Form A certification statements) annually. Reports must be submitted to EPA and
State or Tribal governments, on or before July 1, for activities in the previous calendar year. The
owner/operator of the facility on July 1 of the reporting deadline is primarily responsible for the report,
even if the owner/operator did not own the facility during the reporting year. EPCRA also mandates
that EPA establish and maintain a publicly available database consisting of the information reported
under section 313. This database, known as the Toxics Release Inventory (TRI), can be accessed
through the following sources:
• EPA's Internet site, www.epa.gov/tri;
• Envirofacts Warehouse Internet site;
www.epa.gov/enviro/html/tri s/tris_overview.html;
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• CD-ROM from the Government Printing Office (GPO);
• TRI Explorer, www.epa.gov/tri/triexplorer
• Microfiche in public libraries;
• Magnetic tape and diskettes from the National Technical Information Service; and
• EPA's annual TRI data release materials (summary information).
The objectives of this guidance document are to:
• List EPCRA section 313 reporting requirements for the dioxin and dioxin-like compounds
category;
• Promote consistency in the method of estimating annual releases and other waste
management quantities of dioxin and dioxin-like compounds for particular industries and
industrial classes;
• Reduce the level of effort expended by those facilities that prepare an EPCRA section 313
report for the dioxin and dioxin-like compounds category.
Section 1.2. Who Must Report?
A plant, factory, or other facility is subject to the provisions of EPCRA section 313, if it meets
all three of the following criteria:
It is included in the following Standard Industrial Classification (SIC) Codes: Metal
Mining, SIC Code 10 (except SIC codes 1011, 1081, and 1094); Coal Mining, SIC
Code 12 (except SIC code 1241); Manufacturing SIC Codes 20 through 39; Electric
Utilities, SIC Codes 4911, 4931, or 4939 (each limited to facilities that combust coal
and/or oil for the purpose of generating power for distribution in commerce); Commercial
Hazardous Waste Treatment, SIC Code 4953 (limited to facilities regulated under the
Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. section 6921 et seq.);
Chemicals and Allied Products-Wholesale, SIC Code 5169; Petroleum Bulk Terminals
and Plants, SIC Code 5171; and, Solvent Recovery Services, SIC Code 7389 (limited
to facilities primarily engaged in solvent recovery services on a contract or fee basis); and
It has 10 or more full-time employees (or the equivalent of 20,000 hours per year); and
• It manufactures (includes imports), processes or otherwise uses any of the toxic chemicals
listed on the EPCRA section 313 list in amounts greater than the established threshold
quantities.
In addition, pursuant to Executive Order 13148 entitled "Greening the Government Through
Leadership in Environmental Management," federal facilities are required to comply with the reporting
requirements of EPCRA section 313 beginning with calendar year 1994. This requirement is mandated
regardless of the facility's SIC code.
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Section 1.3. What are the Reporting Thresholds?
Thresholds are specified amounts of toxic chemicals manufactured, processed, or otherwise
used during the calendar year that trigger reporting requirements. The EPCRA section 313 dioxin and
dioxin-like compounds category consists of seventeen specific compounds (see Section 1.4, Table 1-2)
that are reported as a single chemical category. EPA regulations require threshold determinations for
chemical categories to be based on the total mass of all the chemicals in that category (40 CFR
372.25(d)). Reporting is required for the dioxin and dioxin-like compounds category:
• If a facility manufactures 0.1 grams of dioxin and dioxin-like compounds over the
calendar year.
• If a facility processes 0.1 grams of dioxin and dioxin-like compounds over the calendar
year. (See the category qualifier in section 1.5)
• If a facility otherwise uses 0.1 grams of dioxin and dioxin-like compounds over the
calendar year. (See the category qualifier in section 1.5
The terms manufacture, process, and otherwise use are defined at 40 CFR §372.3 as:
Manufacture means to produce, prepare, import, or compound a toxic chemical.
Manufacture also applies to a toxic chemical that is produced coincidentally during the
manufacture, processing, use, or disposal of another chemical or mixture of chemicals, including
a toxic chemical that is separated from that other chemical or mixture of chemicals as a
byproduct, and a toxic chemical that remains in that other chemical or mixture of chemicals as
an impurity.
Otherwise use means any use of a toxic chemical, including a toxic chemical contained in
a mixture or other trade name product or waste, that is not covered by the terms
"manufacture" or "process." Otherwise use of a toxic chemical does not include disposal,
stabilization (without subsequent distribution in commerce), or treatment for destruction unless:
(1) The toxic chemical that was disposed, stabilized, or treated for destruction was
received from offsite for the purposes of further waste management; or
(2) The toxic chemical that was disposed, stabilized, or treated for destruction was
manufactured as a result of waste management activities on materials received from off-site for
the purposes of further waste management activities. Relabeling or redistributing of the toxic
chemical where no repackaging of the toxic chemical occurs does not constitute otherwise use
or processing of the toxic chemical.
Process means the preparation of a toxic chemical, after its manufacture, for
distribution in commerce: (1) In the same form or physical state as, or in a different form or
physical state from, that in which it was received by the person so preparing such
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substance, or (2) As part of an article containing the toxic chemical. Process also applies to
the processing of a toxic chemical contained in a mixture or trade name product.
The qualifier for the dioxin and dioxin-like compounds category places some limitations on what
is covered by the category and thus certain processing or otherwise use activities that may involve
dioxin and dioxin-like compounds are not reportable. See Section 1.5 for a detailed discussion of the
qualifier and its impacts on reporting.
The quantities of dioxin and dioxin-like compounds included in threshold determinations are not
limited to the amounts of these compounds released to the environment, they include all amounts of
dioxin and dioxin-like compounds manufactured, processed, or otherwise at the facility. For example,
some emission factors may include values for both before and after scrubbers, and while the after
scrubber values would apply to release estimates, the before scrubber values would apply towards
threshold calculations since this represents amounts that have been manufactured. Amounts estimated
to be removed by scrubbers should also be reported according to how they are handled (e.g., released
to land on-site, transferred off-site for disposal or destruction, etc.). If the only information that a
facility has concerning the manufacturing, processing, or otherwise use of dioxin and dioxin-like
compounds at the facility comes from emission factors, then those quantities can be used to determine
threshold quantities.
EPA regulations require threshold determinations, and release and other waste management
quantities for chemical categories to be based on the total mass of all the chemicals in the category (40
CFR 372.25(d)). Thus, in determining thresholds and release and other waste management quantities
the amounts of all members of the category must be summed and included in the calculations. As with
reporting for all EPCRA section 313 categories, one Form R is prepared for the dioxin and dioxin-like
compounds category that contains the total amounts of all members of the category. All reporting for
the dioxin and dioxin-like compounds category is to be in gram quantities (40 CFR 372.85), no
reporting in grams of toxic equivalents (TEQs) is allowed. It is important to remember that EPCRA
section 313 does not require any additional testing. As stated in EPCRA section 313(g)(2):
[i]n order to provide the information required under this section, the owner or operator
of a facility may use readily available data (including monitoring data) collected pursuant
to other provisions of law, or, where such data are not readily available, reasonable
estimates of the amounts involved. Nothing in this section requires the monitoring or
measurement of the quantities, concentration, or frequency of any toxic chemical
released into the environment beyond that monitoring and measurement required under
other provisions of law or regulation
While individual reporting of each member of the dioxin and dioxin-like compounds category
(see Table 1-2) is not required, the Form R does contain a section for reporting the distribution of
dioxin and each dioxin-like compound for the total quantity that the facility is reporting. This distribution
must be reported if the information is available from the data used to calculate thresholds, releases, and
other waste management quantities. The distribution shall either be the distribution that best represents
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the distribution of the total quantity of dioxin and dioxin-like compounds released to all media from the
facility or the facility's one best media specific distribution. For example, facilities with releases of
dioxin and dioxin-like compounds to several different media may wish to report a distribution that best
represents the distribution to all media while a facility with only or mostly air releases may wish to report
the distribution associated with those air releases. Each facility should determine the most appropriate
distribution to report. When using the default emission factors listed in Section 4.0 the distribution
associated with the emission factor should be reported unless the facility has a better or more
appropriate distribution available.
Section 1.4 of the Form R allows for the reporting of the distribution of each member of the
dioxin and dioxin-like compounds category. Section 1.4 is reproduced below:
1.4 Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category.
(If there are any numbers in boxes 1-17, then every field must be filled in with either 0 or some number between 0.01 and 100. Distribution
should be reported in percentages and the total should equal 100%. If you do not have speciation data available, check NA.)
123 456 7 8 9 10 11 12 13 14 15 16 17
IN* a ~i
The Form R instructions list all members of the dioxin and dioxin-like compounds category and each is
labeled with a number from 1-17 to be used in filling out the distribution for Section 1.4. Table 1-2 in
section 1.4 lists the 1-17 number labels for each member of the category.
Section 1.4. What are Dioxin and Dioxin-like Compounds and Which Chemicals are Included
in the EPCRA Section 313 Dioxin and Dioxin-like Compounds Category?
Polychlorinated dibenzo-para(p)-dioxins (CDDs) and polychlorinated dibenzofurans (CDFs)
constitute a group of persistent, bioaccumulative, toxic (PBT) chemicals that are termed 'dioxin-like.'
The term, 'dioxin-like' refers to the fact that these compounds have similar chemical structure, similar
physical-chemical properties, and invoke a common battery of toxic responses. An important aspect to
this definition is that the CDDs and CDFs must have chlorine substitution of hydrogen atoms at the 2, 3,
7, and 8 positions on the benzene rings.
A molecule of dibenzo-p-dioxin (DD) and dibenzofuran (DF) is a triple-ring structure consisting
of two benzene rings interconnected by a third oxygenated ring (i.e., a ring containing an oxygen atom).
In DD, the middle oxygenated ring contains two oxygen atoms that connect the benzene rings while in
DF, the oxygenated ring contains one oxygen atom that joins the benzene rings. The molecular
structure of DD and DF is depicted in Figure 1. As can be discerned in Figure 1, there is the possibility
of substituting hydrogen atoms with chlorine atoms (or other halogens) at eight substituent positions
along the DD and DF molecules (i.e., positions 1, 2, 3, 4, 6, 7, 8, or 9). This pattern of substitution
creates the possibility of 75 chlorodibenzo-p-dioxin and 135 chlorodibenzofuran compounds. These
individual compounds are technically referred to as congeners. Homologue groups are groups of
congeners that have the same number of chlorine atoms attached to the molecule, but substituted in
different positions as indicated by C^ and Cly in Figure 1. The prefix mono, di, tri, tetra, penta, hexa,
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hepta, and octa designates the total number of chlorines in the nomenclature of homologue groupings
(i.e., molecules with either 1, 2, 3, 4, 5, 6, 7, or 8 chlorine atoms attached to the carbons). Isomerism
is another important chemical descriptor, and refers to compounds with the same molecular formula
(e.g., the same number of carbon, hydrogen, and chlorine atoms) but that differ by the location of the
chlorine atoms on the benzene rings. Table 1-1 displays the total number of positional CDD and CDF
isomers that are possible within each homologue group. The compounds with chlorine substitution in the
2, 3, 7, 8-positions on the molecule are the most toxic and bioaccumulate in mammalian systems,
including humans.
Figure 1. Chemical Structure of Dioxin-Like Compounds
Dibenzo-p-dioxin Dibenzofuran
Table 1-1. Homoloques and Positional Isomers of CDDs, CDFs
Homologue
(vrefix)
Mono
Di
Tri
Tetra (T)
Penta (Pe)
Hexa (Hx)
Hepta (Hp)
Octa (O)
Chlorine
Atoms
1
2
3
4
5
6
7
8
Total oossible conseners
Isomers of Isomers of
CDDs CDFs
2
10
14
22
14
10
2
1
75
4
16
28
38
28
16
4
1
135
The EPCRA section 313 dioxin and dioxin-like compounds category consists of seventeen
specific CDD and CDF compounds. Only those CDD and CDF compounds with chlorine substitution
in the 2, 3, 7, 8-positions on the molecule are reportable under the EPCRA section 313 dioxin and
dioxin-like compounds category. Table 1-2 lists all of the members of the EPCRA section 313 dioxin
and dioxin-like compounds category by CAS number, name and abbreviated name. These are the only
CDD and CDF compounds that are reportable under the EPCRA section 313 dioxin and dioxin-like
compounds category. The term "dioxin," as in "dioxin and dioxin-like compounds" refers to the most
widely studied of these compounds, 2,3,7,8-tetrachlorodibenzo-p-dioxin (CAS No. 1746-01-6).
Throughout this document the phrase "dioxin and dioxin-like compounds" refers to the seventeen
chemicals listed in Table 1-2.
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Table 1-2. Members of the EPCRA Section 313 Dioxin and Dioxin-like Compounds Category
CAS No.
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
Chemical Name
CDDs
2,3,7,8-tetrachlorodibenzo-p-dioxin
1,2,3,7,8-pentachlorodibenzo-p-dioxin
1,2,3,4,7,8-hexachlorodibenzo-p-dioxin
1,2,3, 6,7,8-hexachlorodibenzo-p-dioxin
1,2,3, 7,8,9-hexachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin
1,2,3,4,6,7,8,9-octachlorodibenzo-p-dioxin
CDFs
2,3 ,7, 8-tetrachlorodibenzofuran
1,2,3, 7,8-pentachlorodibenzofuran
2,3,4,7,8-pentachlorodibenzofuran
1 ,2,3 ,4,7, 8-hexachlorodibenzofuran
1,2,3, 6,7,8-hexachlorodibenzofuran
1,2,3, 7,8,9-hexachlorodibenzofuran
2,3,4,6,7,8-hexachlorodibenzofuran
1,2,3,4,6,7,8-heptachlorodibenzofuran
1,2,3,4,7,8,9-heptachlorodibenzofuran
1,2,3,4,6,7,8,9-octachlorodibenzofuran
Abbreviated Name
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1, 2,3,4, 7,8-HxCDD
1, 2,3,6, 7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
# Label*
17
15
7
8
9
10
12
16
13
14
O
4
5
6
1
2
11
*For filling out the distribution of each member of the category in section 1.4 of the Form R.
Section 1.4.1. Formation of Dioxin and Dioxin-like Compounds During Combustion
More than a decade of combustion research has contributed to a general understanding of the
central molecular mechanisms that form CDDs and CDFs emitted from combustion sources. Current
understanding of the conditions necessary to form CDDs and CDFs were primarily derived from
studying full-scale municipal solid waste incinerators (MSWIs), augmented with observations involving
the experimental combustion of synthetic fuels and feeds within the laboratory. However, the formation
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mechanisms elucidated from these studies are generally relevant to most combustion systems in which
organic material is burned with chlorine. Intensive studies have examined MSWIs from the perspective
of identifying the specific formation mechanism(s) that occur within the system. This knowledge may
lead to methods that prevent the formation of CDDs and CDFs and their release into the environment.
Although much has been learned from such studies, how to completely prevent CDDs/CDFs from
forming during the combustion of certain organic materials in the presence of a source of chlorine and
oxygen is still unknown. The wide variability of organic materials incinerated and thermally processed
by a wide range of combustion technologies that have variable temperatures, residence times, and
oxygen requirements adds to this complex problem. However, central chemical events that participate
in forming CDDs and CDFs can be identified by evaluating emission test results from MSWIs in
combination with laboratory experiments.
CDD/CDF emissions from combustion sources can potentially be explained by three principal
mechanisms, which should not be regarded as being mutually exclusive. The first is that CDDs and
CDFs are present as contaminants in the combusted organic material, and pass through the furnace and
are emitted unaltered. The second is that CDD/CDFs ultimately form from the thermal breakdown
and molecular rearrangement of precursor ring compounds, which are defined as chlorinated aromatic
hydrocarbons with a structural resemblance to the CDD and CDF molecules. Ringed precursors
emanated from the combustion zone are a result of the incomplete oxidation of the constituents of the
feed (i.e., products of incomplete combustion). The third mechanism, similar to the second, is that
CDD/CDFs are synthesized de novo. De novo synthesis describes a pathway of forming CDD/CDFs
from heterogeneous reactions on fly ash involving carbon, oxygen, hydrogen, chorine, and a transition
metal catalyst. With these reactions, intermediate compounds having an aromatic ring structure are
formed. Studies in this area suggest that aliphatic compounds, which arise as products of incomplete
combustion, may play a critical role in initially forming simple ring molecules, which later evolve into
complex aromatic precursors. CDD/CDFs are then formed from the intermediate compounds. In both
mechanisms (2) and (3), formation occurs outside the furnace, in the so-called post-combustion zone.
Particulate bound carbon is suggested as the primary reagent in the de novo syntheses pathway.
Although chlorine is an essential component for the formation of CDD/CDFs in combustion
systems, the empirical evidence indicates that, for commercial scale incinerators, chlorine levels in feed
are not the dominant controlling factor for rates of CDD/CDF stack emissions. Important factors
which can affect the rate of CDD/CDF formation include the overall combustion efficiency, post-
combustion flue gas temperatures and residence times, and the availability of surface catalytic sites to
support CDD/CDF synthesis. Data from bench, pilot and commercial scale combustors indicate that
CDD/CDF formation can occur by a number of mechanisms. Some of these data, primarily from
laboratory and pilot scale combustors, have shown direct correlation between chlorine content in fuels
and rates of CDD/CDF formation. Other data, primarily from commercial scale combustors, show
little relation with availability of chlorine and rates of CDD/CDF formation. The conclusion that chlorine
in feed is not a strong determinant of CDD/CDF emissions applies to the overall population of
commercial scale combustors. For any individual commercial scale combustor, circumstances may
exist in which changes in chlorine content of feed could affect CDD/CDF emissions. For uncontrolled
combustion, such as open burning of household waste, chlorine content of wastes may play a more
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significant role in affecting levels of CDD/CDF emissions than observed in commercial scale
combustors. For a more detailed discussion of the mechanisms of formation and the role of chlorine in
the formation kinetics, the reader may refer to: Volume 2: Sources of Dioxin-Like Compounds in the
United States; Chapter 2: Mechanisms of formation of dioxin-like compounds during combustion
of organic materials; In: Estimating Exposure to Dioxin-Like Compounds. EPA/600/P-00/001Bb.
September 2000. Draft Final Report.
Section 1.5. What Activities are Covered by the Qualifier for the Dioxin and Dioxin-like
Compounds Category?
The dioxin and dioxin-like compounds category has the following activity qualifier that
describes what must be reported under the category:
"Manufacturing; and the processing or otherwise use of dioxin and dioxin-like compounds if
the dioxin and dioxin-like compounds are present as contaminants in a chemical and if they
were created during the manufacturing of that chemical."
This qualifier states that if a facility manufactures dioxin and dioxin-like compounds then those quantities
must be applied towards the 0.1 gram manufacturing threshold and included in release and other waste
management calculations. Manufacture includes the coincidental production of dioxin and dioxin-like
compounds during any process (e.g., a combustion process, a chemical manufacture process). Note
that, as discussed in Section 1.3, the EPCRA section 313 definition of manufacture includes importing.
The qualifier also covers the processing or otherwise use of dioxin and dioxin-like compounds, but only
if the dioxin and dioxin-like compounds are present as contaminants in a chemical and if they were
created during the manufacturing of that chemical. This means that if a facility processes or otherwise
uses a chemical or mixture that contains dioxin and dioxin-like compounds that were created during the
manufacturing of that chemical or mixture, then the dioxin and dioxin-like compounds must be included
in threshold determinations and release and other waste management calculations. However, if the
dioxin and dioxin-like compounds were already present in a product being processed or otherwise
used and were not created during the manufacture of that product (such as at food processing plants
where dioxin and dioxin-like compounds may be present in the incoming raw materials) the dioxin and
dioxin-like compounds are not reportable and do not need to be included in threshold determinations or
release and other waste management calculations.
Examples of the impacts of the dioxin and dioxin-like compounds category qualifier on what is
reportable:
Example 1: A facility manufactures chemical A and in doing so, the facility also manufactures dioxin
or dioxin-like compounds. Because EPCRA section 313 defines "manufacturing" to
include production, the facility would have to include the dioxin or dioxin-like
compounds it produced in its threshold determinations and release and other waste
management calculations. This is true regardless of whether the compounds are present
as contaminants in chemical A since the chemical listing for dioxin or dioxin-like
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compounds contains no modifications to the term manufacture as defined under
EPCRA section 313.
Example 2: A facility processes or otherwise uses chemical A. Dioxin or dioxin-like compounds
are present in chemical A as contaminants. The dioxin or dioxin-like compounds
present in chemical A were created during the manufacturing of chemical A. In this
case, the facility would have to include the dioxin or dioxin-like compounds present in
chemical A in its threshold determinations and release and other waste management
calculations.
Note that if chemical A is processed into a different product but chemical A still exists
in that product (i.e., it has not been converted into a different chemical) then the dioxin
and dioxin-like compounds must be included in threshold determinations and release
and other waste management calculations.
Example 3: A facility processes or otherwise uses chemical B. Dioxin or dioxin-like compounds
are present in chemical B as contaminants. However, the dioxin or dioxin-like
compounds in chemical B were not created during the manufacturing of chemical B
(they were introduced from an environmental source or created during the manufacture
of a precursor to chemical B). In this case, because one of the two limitations in the
category qualifier was not satisfied, the facility would not have to include the dioxin or
dioxin-like compounds present in chemical B in its threshold determinations and release
and other waste management calculations.
Example 4: Dioxin or dioxin-like compounds are present in chemical A as contaminants. The
dioxin or dioxin-like compounds present in chemical A were created during the
manufacturing of chemical A. Facility X uses or processes chemical A to manufacture
chemical C. No new dioxin or dioxin-like compounds were created in the manufacture
of chemical C, but chemical C does contain the dioxin or dioxin-like chemicals that
were present in chemical A. Because facility X is using or processing chemical A,
which contains dioxin or dioxin-like compounds as contaminants that were created
during the manufacturing of chemical A, facility X would have to include the dioxin or
dioxin-like compounds present in chemical A in its threshold determinations and release
and other waste management calculations. This is true regardless of what facility X
does with chemical C (uses it on site, sells it, etc.)
Facility X then sells chemical C to facility Y. Although chemical C contains dioxin or
dioxin like compounds as contaminants, those compounds were not created during the
manufacture of chemical C (they were created during the manufacture of chemical A).
Because one of the two limitations in the category qualifier was not satisfied, facility Y
would not have to include the dioxin or dioxin-like compounds present in chemical C in
its threshold determinations and release and other waste management calculations.
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Example 5: Facility X imports chemical D into the country. Chemical D contains dioxin or dioxin-
like compounds. Because EPCRA section 313 defines "manufacturing" to include
importing, facility X would have to include the dioxin or dioxin-like compounds present
in chemical D in its threshold determinations and release and other waste management
calculations. This is true regardless of whether the compounds are present as
contaminants or when they were created since the chemical listing for dioxin or dioxin-
like compounds contains no modifications to the term manufacture as defined under
EPCRA section 313.
Facility X then sells chemical D to facility Y. Facility Y processes or uses chemical D
on site. Facility Y must determine if the dioxin or dioxin-like compounds present in
chemical D: 1) are present as contaminants, and 2) were created during the
manufacture of chemical D. If the answers to both questions are "Yes," then facility Y
would have to include the dioxin or dioxin-like compounds present in chemical D in its
threshold determinations and release and other waste management calculations. In
answering those questions, facility Y should use the best available information.
Example 6: A waste management facility accepts wastes that contain dioxin or dioxin-like
compounds for the purposes of on-site waste management. By accepting waste for on-
site waste management, the facility is otherwise using the dioxin or dioxin-like
compounds in that waste. The facility must determine if the dioxin or dioxin-like
compounds in the waste: 1) are present as contaminants, and 2) were created during
the manufacture of the waste or any chemicals in the waste. If the answers to both
questions are "Yes," then the facility would have to include the dioxin or dioxin-like
compounds present in the waste in its threshold determinations and release and other
waste management calculations. In answering those questions, the facility should use
the best available information.
There are several chemicals and/or products that EPA has identified as having the potential to
contain dioxin and dioxin-like compounds manufactured as by-products during the manufacturing
process for those chemicals. These chemicals include, but are not limited to:
CAS No. Chemical/Product Name
118-75-2 Chloranil
87-86-5 Pentachlorophenol (PCP)
107-06-2 Ethylene dichloride (EDC)
(manufactured by oxychlorination)
94.75.7 2,4-D
1928-43-4 2,4-D Ester Herbicides
Bleached chemical wood pulp
Typical Uses
dyes, pigments, pesticides
wood preserving, pesticides
vinyl chloride production, gasoline, paints and
varnishes, metal degreasing, scouring compounds,
organic synthesis, solvent, fumigant
pesticides
pesticides
white paper products
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Section 1.6. What Other Changes to the EPCRA Section 313 Reporting Requirements
Apply to the Dioxin and Dioxin-like Compounds Category?
EPA has also made modifications and/or clarifications to certain reporting exemptions and
requirements for the PBT chemicals that are subject to the lower reporting thresholds; this includes the
dioxin and dioxin-like compounds category. Each of the changes as they apply to dioxin and dioxin-
like compounds category is discussed in the following subsections.
Section 1.6.1. De Minimis Exemption
The de minimis exemption allows facilities to disregard certain minimal concentrations of non-
PBT chemicals in mixtures or other trade name products they process or otherwise use when making
threshold determinations and release and other waste management calculations.
EPA eliminated the de minimis exemption for the dioxin and dioxin-like compounds category
(40 CFR 372.38(a)). This means that facilities are required to include all amounts of dioxin and dioxin-
like compounds in threshold determinations and release and other waste management calculations
regardless of the concentration of the dioxin and dioxin-like compounds in mixtures or trade name
products.
Section 1.6.2. Form A Exclusion
The "TRI Alternate Threshold for Facilities with Low Annual Reportable Amounts," provides
facilities otherwise meeting EPCRA section 313 reporting thresholds the option of certifying on Form A
provided that they do not exceed 500 pounds for the total annual reportable amount for that chemical,
and that their amounts manufactured or processed or otherwise used do not exceed one million pounds.
EPA has excluded the dioxin and dioxin-like compounds category from the "TRI Alternate
Threshold for Facilities with Low Annual Reportable Amounts" (40 CFR 372.27(e)). Therefore,
submitting a Form A rather than a Form R is not an option for the dioxin and dioxin-like compounds
category.
Section 1.6.3. Range Reporting
For facilities with total annual releases or off-site transfers of an EPCRA section 313 chemical
of less than 1,000 pounds, EPA allows the amounts to be reported on the Form R either as an estimate
or by using ranges.
EPA has eliminated range reporting for the dioxin and dioxin-like compounds category (40
CFR 372.85(b)). This means that for those sections of the Form R for which range reporting is an
option, the option cannot be used when reporting on the dioxin and dioxin-like compounds category.
Thus facilities must report an actual number rather than a selected range.
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Section 1.6.4. Data Precision
Facilities should report for the dioxin and dioxin-like compounds category at a level of
precision supported by the accuracy of the underlying data and the estimation techniques on which the
estimate is based. However, the smallest quantity that needs to be reported on the Form R for the
dioxin and dioxin-like compounds category is 0.0001 grams (i.e., 100 micrograms).
Example: If the total quantity for Section 5.2 of the Form R (i.e., stack or point air emissions)
is 0.00005 grams or less, then zero can be entered. If the total quantity is between 0.00005
and 0.0001 grams then 0.0001 grams can be entered or the actual number can be entered
(e.g., 0.000075).
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Section 2.0. GUIDANCE ON ESTIMATING ENVIRONMENTAL RELEASES OF
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Section 2.1. General Guidance
EPA is providing the following guidance which may be used by facilities in estimating and
reporting annual releases and other waste management quantities for the dioxin and dioxin-like
compounds category. If you are not sure whether information in this guidance can be applied to the
situation at your facility, EPA recommends consultation with the Agency before using this guidance.
The EPA contact for the emission factors and other estimation methods contained in this document is
David Cleverly, National Center for Environmental Assessment (8623D), U.S. EPA, 1200
Pennsylvania Ave, NW, Washington, DC or e-mail at cleverly.david@epa.gov.
EPA supports the use of three different approaches for estimating annual releases of dioxin and
dioxin-like compounds from facilities subject to reporting:
1. Use of actual facility-specific monitoring data
2. Use of facility-specific emission factors
3. Use of facility-specific EPA default emission factors
In general EPA considers these three approaches to be hierarchical. In most situations,
monitoring or directly measured data obtained at your facility provides the best and most accurate
estimate of annual releases of dioxin and dioxin-like compounds. Note that, as discussed under Section
1.3, EPCRA section 313 does not require any additional monitoring or measurements beyond that
monitoring and measurement required under other provisions of law or regulation. Depending on the
adequacy and quality of the data in terms of sampling and laboratory methods used to ascertain the
data, monitoring data may or may not be a facility's best available data. To be representative of annual
releases of dioxin and dioxin-like compounds, the monitoring and sampling should have been taken
under conditions representative of the facility's general operating and/or production conditions. In the
absence of such monitoring data two additional approaches are recommended, which, to the extent
possible, should also be based on conditions representative of the facility's general operating and/or
production conditions.
First, facilities may use facility-specific emission factors that they believe are the best 'fit' to
their facility. This means that the facility may use emission factors developed from the sampling
and monitoring of dioxin and dioxin-like compounds at a similar facility. Reports of sampling
emission and effluent streams should be collected and reviewed from facilities that are most
similar in technology, design, operation, capacity, auxiliary fuels used, products produced, the
manufacturing process, waste products generated, Industrial Classification Code, feedstocks
used, air/water pollution control systems, etc. An important aspect in selecting an emission
14
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factor for a combustion process is temperature. A temperature inlet to the air pollution control
device that is below 200° Celsius or above 450° Celsius will result in minimal stack release of
dioxin and dioxin-like compounds. Therefore, in defining similarity of process, the facility
operator is encouraged to examine, and then match, the temperature reported at the facility
that you selected to be representative of potential emissions from your facility. Data from
similar facilities within the same industry sector compiled by industry technical organizations
may be a good source of facility-specific emission factors.
• Second, facilities that cannot use either of these approaches may estimate their annual releases
through the use of default emission factors provided by EPA in Section 4 of this guidance.
Selection of more site-specific emission factors are preferred.
The owner/operator of the facility should determine whether one of these three approaches
would provide an accurate reflection of the potential for releases of dioxin and dioxin-like compounds
from the facility or whether some other method would be more appropriate. Figure 2 is a 'decision
tree' highlighting the basic questions one should ask when selecting the appropriate emission factor
approach. The first step in the 'decision tree' is to determine whether your facility meets the reporting
requirements of EPCRA section 313, however, it is possible that before you can make a final
determination on whether your facility meets the EPCRA section 313 reporting requirements you may
have to go ahead and use one of the estimation methods to help determine if your facility will exceed
reporting thresholds.
When selecting the estimation method to be used, EPA recommends that the facility be able to
document the rationale employed in making the selection. When documenting the annual releases and
other waste management quantities of dioxin and dioxin-like compounds, EPA recommends that the
facility indicate which of these three approaches was used in deriving the estimate. The owner/operator
is encouraged to exercise 'best engineering judgement' when arriving at the decision on the most
appropriate approach to use. A more detailed explanation of each of these approaches follows.
15
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Figure 2. Decision Tree For Selecting Emission Estimation Technique
Are you required to
estimate releases of
Dioxin-like
compounds?
Yes
No
CZL
Is your facility required by
State or Federal law
to measure dioxin in effluents,
stack emissions, waste streams?
1
Yes
Use Approach 1
to estimate
emissions
J
T
Use Approach 2
Emission
Factors of your
choosing
No
Stop: No need to estimate
annual releases of Dioxin-like
compounds
Do you have
access to
emission factors
from a similar facility?
I
I ,
Yes
J""
1
No
L:
Use Approac
EPA Defau
Emission
Factors
.]
h3
t
In the context of this guidance, the term "best engineering judgment" engenders one or more of the
following:
Knowledge of the manufacturing/industrial process and process flow;
Knowledge of the chemical feed stocks used in the manufacturing/industrial process
Knowledge of the feedstocks/fuels used in providing a source of energy for the process;
Knowledge of the water pollution control system/technology and contaminant removal
efficiencies used to treat industrial wastewater;
Knowledge of the waste products derived from operations and manufacturing;
Knowledge of the air pollution control equipment and contaminant removal efficiencies used to
control toxic air pollutants.
When applying 'best engineering judgement' to a determination of the appropriate emission factor
approach to use to calculate emissions and releases of dioxin-like compounds for your facility, it is
important to:
Obtain engineering test reports and/or literature references of dioxin emissions/releases from
facilities that are within your SIC code.
Compare your facility design, function and operations with other facilities that have been tested
or sampled for emissions of dioxin-like compounds. This will allow you to match the two
16
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processes and make the determination as to how representative these emission factors are to
your facility;
If you are unable to locate representative emission factors for your facility, then you may elect
to use EPA's default emission factors appropriate for your facility.
Section 2.1.1. Approach 1 - Use Actual Facility-Specific Monitoring Data
This approach allows the facility to estimate annual releases of dioxin and dioxin-like
compounds to the air, water and land, as well as other waste management quantities, based on
measured data derived at the facility. A facility may be required to perform monitoring under provisions
of the Clean Air Act (CAA), the Clean Water Act (CWA), the Resource Conservation and Recovery
Act (RCRA), or other regulations. If this is the case, then these data should be available for developing
release estimates. Data may have also been collected for your facility for compliance monitoring
purposes associated with a state or federal permit. If only a small amount of direct measurement data
are available or if you believe the monitoring data are not representative, you should determine if an
alternative estimation method would give a more accurate result. With regard to the manner in which
non-detects (ND) are reported, refer to Section 2.2.
Section 2.1.2. Approach 2 - Use Facility-Specific Emission Factors
Emission factors are the fundamental tools in this guidance for estimating releases of dioxin and
dioxin-like compounds. An emission factor is a representative value that is intended to relate the
quantity of dioxin and dioxin-like compounds released to the open environment with a measure of
industrial activity associated with the release. These factors are usually expressed as the weight of
pollutant divided by a unit weight, volume, or duration of the activity emitting the contaminant.
Examples of emission factors include: nanograms (ng) of dioxin and dioxin-like compounds emitted into
air per kilogram (kg) of coal burned; picogram (pg) of dioxin and dioxin-like compounds discharged
into surface water per liter (L) of wastewater; ng dioxin and dioxin-like compounds transferred to land
disposal per kg of sludge produced at your facility. Emission factors facilitate estimation of
environmental releases from various sources of releases of dioxin and dioxin-like compounds when the
annual activity level of the facility is known. Your emission factor should be assumed to be
representative of long-term averages for your facility. The general equation for emission estimation is:
Annual Release = Emission Factor x Annual Activity Level
R = EFxA
where:
R = annual release of dioxin and dioxin-like compounds, (i.e.,g/yr)
A = activity level or production rate, (e.g., kg of material processed per year)
EF = dioxin emission factor, (e.g., g dioxin released / kg material processed/time)
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EF is to represent the emission of dioxin and dioxin-like compounds into the open environment at the
'end-of-the-pipe'. The extent of completeness and detail of the emissions is determined by the
information available from published references. Emissions from some processes are better
documented than others. When electing to use this approach, EPA recommends that the facility
maintain documentation on the other facility (ies) engineering test reports or the source of the industry-
specific data compiled by technical organizations that were evaluated and used in deriving your emission
factors. The documentation should clarify why the other facility is a close analogy to your facility based
on similarity of design, operations, feed stocks, end products, SIC code, manufacturing process,
combustion process, and pollution control systems. Sources of information that may be helpful in
Approach 2 include:
G State Regulatory Agencies. In the development of regulatory requirements for specificities, it is
often the case that State environmental agencies have issued permits for the allowable discharge
of dioxin-like compounds to the environment from facilities similar to your own. The State
Agency may have reliable test reports information attendant to permitting such facilities. These
test reports are usually kept in the public record.
G Trade Associations. Several industries are represented by Trade Associations that function to
foster the interests of a particular industrial sector. Such trade associations are comprised of
member companies. Often member companies make engineering test reports available to the
Trade Association members.
G EPA Regulatory Dockets. EPA regulatory dockets are maintained as a central repository of
information EPA used in a rule making process. Such dockets and their contents are open to
the public for inspection and photo copying. The Federal Register preamble announcing
proposed or final rule under one of the statutory authorities of EPA will identify the location of
the regulatory docket and provide information as to how one may access information in the
docket. The docket does contain technical information, including test reports data, that was
used in the development of the regulatory requirements.
G EPA Internet Sites. The EPA maintains a central site on the Internet, i.e., http//www.epa.gov.
This home page provides a useful base from which to access EPA databases, reports and
studies, and to conduct searches by topic. Complete documents can be electronically accessed
from this site. An example of an EPA site having abundant information on air emission factors is
the Technology Transfer Network maintained by EPA's Office of Air Quality Planning and
Standards. This site has an URL: http://www.epa.gov/ttn.
G Engineering and Science Libraries. Public and private universities often times allow public
access to technical literature housed within university libraries. This is particularly true of
universities having schools of engineering and science.
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Section 2.1.3. Approach 3 - Use Facility-Specific EPA Default Emission Factors
With this approach, EPA is providing tables of emission factors for specific sources, that,
when multiplied by an appropriate measure of annual activity level at your facility, will result in an
estimate of annual releases of the sum of dioxin and dioxin-like compounds (i.e., the 17 compounds of
CDDs and CDFs) from your facility. Emission factors are used to calculate annual releases in
situations in which the facility has not measured CDDs and CDFs in its effluents or emission streams.
The EPA default emission factors were derived from the available monitoring data deemed to be
representative of the source category (or segments of the source category that differ in configuration,
fuel type, manufacturing process, feedstocks, pollution control systems, etc.). Implicit in the use of the
default emission factors is the assumption that facilities with similar design and operating characteristics
should have a similar potential for release of dioxin and dioxin-like compounds. The default emission
factors are more accurately applied to an entire source category, because it is representative of the
average emissions of all tested facilities in the category. This introduces a significant degree of
uncertainty when applying the average emission factor to an individual facility, namely, that a portion of
facilities within the industrial category will have emissions that are either above or below the average.
However, in the absence of either monitoring data from your facility, or more accurate site-specific
emission factors, EPA believes that these default emission factors can be used to make a reasonable
estimation of releases.
The CDD and CDF EPA default emission factors in this guidance were developed from three
primary references (available in pdf format at: http://www.epa.gov/tri/):
• EPA's Database of Sources of Environmental Releases of Dioxin-Like Compounds in
the United States. U.S. Environmental Protection Agency, National Center for
Environmental Assessment, Office of Research and Development, Washington, DC
20460, EPA/600/P-98/002B, September, 2000.
• The Inventory of Sources of Dioxin in the United States. U.S. Environmental
Protection Agency, National Center for Environmental Assessment, Office of
Research and Development, Washington, DC 20460, EPA/600/P-98/002Aa.
• Estimating Exposure to Dioxin-Like Compounds: Volume 2: Sources of Dioxin-Like
Compounds in the United States, EPA/600/)-00/001, Draft Final, September,
2000.
When researching emission factors in Approach 2 (above), the owner and operator of a reporting
facility may elect to use emission factors developed for sources other than those listed in this guidance,
for example, medical waste incinerators. The owner/operator of such a facility is encouraged to review
sources and releases of dioxin-like compounds contained in EPA's Database (listed above) in order to
assist in the selection of more appropriate emission factors.
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Section 2.2. Consideration of Non-Detects
When detected in emissions and effluents from facilities, dioxin and dioxin-like compounds are
found in minute quantities, e.g., one part-per trillion (1 ppt) or less, and as mixtures of dioxin and the
dioxin-like compounds. Detection is with high resolution gas chromatography combined with high
resolution mass spectrometry. For example, EPA Method 1613 (USEPA, 1994a) (used to quantify
CDDs and CDFs in wastewater, solids, air, and tissue samples) can reliably detect these compounds at
or below one part per trillion (i.e., 10 parts per quadrillion (ppq) in water; 1 ppt in solid waste). This
presents a challenge in terms of interpretation of results in which a CDD/CDF compound is reported by
the analytical laboratory as 'Not Detected' (shown as the abbreviation 'ND' on lab sheets).
Even with these extremely low levels of detectability with current laboratory methods, it is not
possible to know with certainty if 'not detected' (ND) is actually zero (i.e., that dioxin and dioxin-like
compounds are not present in the sample) or if dioxin and dioxin-like compounds really are present in
the sample at some concentration below the minimal detection limit (MDL). The monitoring data and
emission factors determined for your facility should be reported in a manner consistent with the methods
and procedures that EPA has developed for determining if these compounds are present in various
industrial processes. For example, EPA Method 1613 (USEPA, 1994a) indicates that laboratory
results below the minimum detection level should be reported as not detected (ND) or as required by
the regulatory authority. For purposes of threshold determinations and the reporting of releases and
other waste management quantities for dioxin and dioxin-like compounds under EPCRA section 313,
either with monitoring data, or by using the emission factor approach, non-detects are treated as 'zero'
if that is how the method being used treats non-detects (e.g., Method 1613, Method 23). However,
facilities should use their best readily available information to report, so if a facility has better information
than provided by these methods then that information should be used. For example, if a facility is not
detecting dioxin or a particular dioxin-like compound using a particular method but has information that
shows that they should be detecting them the facility should use this other information and it may be
appropriate to estimate quantities using one half the detection limit.
If the method being used by a facility to detect dioxin and dioxin-like compounds is not an
EPA approved method and the detection level being used is not as sensitive as those approved for use
under EPA methods then EPA's EPCRA section 313 guidance with regard to non-detects should be
followed. This guidance states that facilities must use reasonable judgement as to the presence and
amount of a listed toxic chemical based on the best readily available information. An indication that a
reportable chemical is below detection is not equivalent to stating that the chemical is not present. If the
reportable toxic chemical is known to be present, EPA recommends that a concentration equivalent to
half the detection limit be used. Facilities should not estimate releases solely on monitoring devices,
they should also rely on their knowledge of specific conditions at the plant.
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Section 3.0. EXAMPLES OF CALCULATING EMISSIONS TO THE AIR,
WATER, AND LAND
Environmental releases of dioxin and dioxin-like compounds occur to all media air, water and
land. Dioxin and dioxin-like compounds are not intentionally manufactured, they are inadvertently
formed during certain manufacturing and combustion processes. In this regard, dioxin releases cannot
be determined by a mass balance of your facility. Rather EPA recommends you use one of the three
approaches listed in Section 2.0, above (direct measurements, or the two emission factor approaches).
Section 4.0 gives EPA default emission factors for specific facilities falling within certain reporting
facility SIC codes. The purpose of this section is to give examples of calculating emissions to air, water
and land from your facility. In some examples the phrase "dioxin and dioxin-like compounds" may be
abbreviated to "D&DLC" to save space.
Section 3.1. Approach 1 - Use Actual Facility-specific Release Data
Section 3.1.1. Example of Calculating Air Releases Using Stack Monitoring Data
Example: Stack testing has determined that dioxin and dioxin-like compounds are
detected in the stack gases at your facility at a concentration of 10 E - 09 gper dry standard
cubic meter of gas (10 ng/dscm). The moisture content in the stack is typically 10%. The stack
gas velocity is typically 8.0 m/s. The diameter of the stack is 0.3 m. Calculate the annual air
release of dioxin and dioxin-like compounds from the stack of your facility.
Step 1. Calculate volumetric flow of stack gas stream.
Volumetric flow = (gas velocityJxunternal area of stack)
Volumetricflow = (gas velocity) x \(pi) x (internal stack diameter)2 + 4\
Volumetric flow = (8.0 m/ s) x \(pi) x (0.3m)2 + 4\
Volumetricflow = 5.7m3 / s
Step 2. Correct volumetric flow for moisture content in stack gas stream
Stack gases may contain large amounts of water vapor. The concentration of the
chemical in the exhaust is often presented on a 'dry gas' basis. For an accurate release rate,
correct the stack or vent gas flow rate in Step 1 for the moisture content in your facility's stack
gas. This is done simply by multiplying the Volumetricflow in Step 1 by the term (1 -fraction of
water vapor). The dry gas Volumetricflow rate can then be multiplied by the concentration of
dioxin and dioxin-like compounds measured in the stack gases (see Step 3).
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Dry volume tic flow = (volumetric flow) x(l - fraction of water)
Dry volume trie flow (corrected) = (5.7 m / s) x (1 -0.10) = 5.13 m / s
Step 3. Estimate annual stack emissions to air.
Vx CFx H x [units conversion factor}
Where:
Rair= Annual release of dioxin and dioxin-like compounds to air (g/yr)
C= Combustion flue gas concentration ofD&DLC (ng/dry standard cubic meter)
V = Hourly Volumetric flow rate of combustion flue gas (dscm/hour) (20°C, 1 atm;
adjusted to 7% OJ
CF= Capacity factor, fraction of time that the facility operates on an annual basis
(e.g., 0.85)
H= Total hours in a year (8,760 hr/yr)
(I0ng\ (5.13dscm
= ~v
dscmJ
Rair = 1.38 g/yr
x
V hr
8760 hr , ,
x x(0.85)x
V yr )
g
109ngJ
Section 3.1.2. Example of Calculating Water Releases Using NPDES Monitoring Data
Example: Your facility is subject to NPDES permits for the discharge of dioxin and
dioxin-like compounds into surface waters. You are required to conduct periodic monitoring of
the effluent discharge from your facility. In this example, quarterly samples were taken to be
analyzed for the content of dioxin and dioxin-like compounds. Each sample was an hourly,
flow rate-based composite taken for one day to be representative of the discharge for that day.
The total effluent volume for that day was also recorded. Your facility operates 350 days/year.
The following data were collected on each sample day.
Quarter sample number
1
2
3
4
Discharge flow rate (106
gal/day)
20
20
40
100
Dioxin and dioxin-like
compounds concentration
(picograms per liter (pg/L))
10
10
10
10
22
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To calculate the amount of dioxin and dioxin-like compounds discharged on each sample day, the
concentration of dioxin and dioxin-like compounds in the discharge is multiplied by the discharge flow
rate for that day, as shown below for the first quarter sample.
Step 1: Calculate the amount of dioxin and dioxin-like compounds discharged per day from
each day of sampling
Amount of dioxin and dioxin-like compounds/day = (daily effluent flow rate) x (dioxin and
dioxin-like compounds concentration in effluent). From the table above, the calculation of daily dioxin
and dioxin-like compounds effluent discharge for the first sampling quarter is:
First Quarter Discharge = \—j\x
L }
1012pg
x
3.8 L} \20xl06 gal]
gal J day
First Quarter Discharge = 0.00076 g dioxin and dioxin-like compounds/ day
Step 2: Find the average amount of dioxin discharged in effluent/day
Using the same equation, the second, third and forth quarter dioxin and dioxin-like compounds
monitoring events are calculated to be 0.00076 g/day; 0.0015 g/day; and 0.0038 g/day, respectively.
Then the average daily dioxin and dioxin-like compounds discharge rate for all monitoring events at this
facility is:
f 0.00076 + 0.00076 + 0.0015 + 0.00381
Average daily discharge = < >g / day
[ 4 sampling periods }
Average daily dioxin and dioxin - like compounds discharge = 0.0017 g / day
Step 3 Calculate the annual discharge of dioxin to surface waters
Your facility operates 350 days/year. The estimated annual discharge of dioxin and dioxin-like
compounds is calculated as follows:
A ?r>- / fT^s>r^T^+ c f w + \350day\ \0.0017g\
Annual Discharge of D& DLL to Surface Water = < —\x< —>
[ yr J [ day J
Annual Dioxin and Dioxin-like Compounds Discharge to Surface Water = 0.6 g/ yr
Section 3.1.3. Example of Estimating Releases to Land
Under EPCRA section 313, the disposal of toxic chemicals in on-site landfills constitutes a
release to land. Waste contaminated with dioxin and dioxin-like compounds may be placed in a RCRA
23
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subtitle C landfill for disposal. The following is an example of calculating the annual quantity of dioxin
and dioxin-like compounds disposed in a RCRA subtitle C landfill.
Example: Land disposal of sludge. Your facility generates approximately 1 kg of dry
sludge per 4000 L ofwastewater treated at the facility's on-site industrial wastewater treatment
plant. The facility operations produce approximately 100 million L of wastewater per day.
Monitoring results indicate that the sludge, on average, contains approximately 3 ng dioxin and
dioxin-like compounds per kg dry sludge produced. All of the sludge from your facility is placed
in an on-site RCRA subtitle C landfill. The facility operates 350 days per year. What is the
annual amount of dioxin and dioxin-like compounds released to land from your facility as a
function of land disposal of the sludge contaminated with dioxin and dioxin-like compounds?
Step 1: Determine the amount of sludge produced per day from the wastewater treatment
process.
T.,c,, , r, . , J 1kg sludge \ f 1x1O8 L wastewater
lotal Sludge Generated = \ > x
° 4 r\r\r\ T ...... j .... ..j
4000]L wastewater j day
Total Sludge Generated = 25,000 kg / day
Step 2: Determine the amount of dioxin and dioxin-like compounds contained in the sludge
produced each day.
Total amount ofD&DLC in sludge =
Total sludge generated x average D&DLC concentration in sludge
Total amount of D&DLC in sludge =
125,000 kg sludge} \3ngD&DLC\ f g
( day ] ( kg of sludge J \109ng\
Total amount of dioxin and dioxin - like compounds in sludge = 0.000075 g / day
24
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Step 3 Calculate the annual release of dioxin and dioxin-like compounds to land based on
annual days of operation per year
Annual release of dioxin and dioxin-like compounds to land =
average daily D& DLC loading in sludge x total operating days per year.
Annual release of dioxin and dioxin-like compounds to land =
7.5xlO~5 gD&DLC\ \350 operating days]
day [ year J
Annual release of dioxin and dioxin - like compounds to land = 0.03 g/ yr
Section 3.2. Examples of Estimating Releases Using Emission Factors
You have either developed your own facility-specific emission factors or have decided to use
EPA's default emission factors (refer to Section 4.0; EPA Default Emission Factors) to estimate annual
releases of dioxin and dioxin-like compounds from your facility to air, land and water. Emission
factors (EF) relate potential release of dioxin and dioxin-like compounds to the activity level of your
facility. The units vary according to the units of measure of activity level, but usually are weight per unit
weight of production or weight per unit volume related to production. A common EF for combustion
processes is ng dioxin and dioxin-like compounds per kg material combusted, processed, or produced.
A common EF for point source effluent discharges into surface waters is pg dioxin and dioxin-like
compounds per L of wastewater discharged. A common EF for RCRA waste generated that will be
disposed is pg dioxin and dioxin-like compounds per kg of waste or sludge generated. The following
serve as examples of how to make calculations of annual releases of dioxin and dioxin-like compounds
using either your own chosen emission factors or EPA default emission factors. In either case, the
procedures are the same.
Section 3.2.1. Example of Estimating Air Releases
Example: The emission factor that best fits your facility is 10 ng dioxin and dioxin-like
compounds released from the stack per kg of materials processed. Each day your facility
processes 25,000 kg of materials, and your facility operates 350 days per year. The emission
factor is appropriate for your level of dioxin and dioxin-like compounds control. Estimate the
annual release of dioxin and dioxin-like compounds from the stack of your facility.
25
-------
Solution:
Rair = AxEF
Where:
Rair = annual release ofdioxin and dioxin-like compounds to air; (g/yr)
A = material processed annually; (kg/yr)
EF = dioxin and dioxin-like compounds emission factor; (ng/kg)
_. _
~
2 5, 000 kg materials} \350days\ \10ngD&DLC\
- "^ - "^ -
I " I I " I I " 1
day J [ year J [ kg materials J [10 ng
Rair = 0.09 g dioxin and dioxin - like compounds / year
Section 3.2.2. Example of Estimating Water Releases
Example: Your facility discharges 100 million gallons per day of 'treated wastewater into
surface water. The emission factor you have found to be most appropriate for your facility is 10
pg dioxin and dioxin-like compounds per liter of wastewater discharged. The emission factor
reflects the level ofdioxin and dioxin-like compounds control that is occurring at your facility.
Your facility operates 365 days each year. Estimate the annual release ofdioxin and dioxin-like
compounds to surface water.
Solution:
100 x 106 gal wastewater} \3.78L\ \365days
\ x < \ x <
day } [ gal } [ yr
{WpgD&DLC} g
X4 i-^ }• X
[ L wastewater J 1012pg
Rwater = 1.4 g dioxin and dioxin - like compounds / yr
Section 3.2.3. Example of Estimating Releases to Land
Example: In the example above, the wastewater treatment plant process generates 1 kg
of dry sludge per 5000 L of wastewater treated. The wastewater treatment process removes
50% of the dioxin and dioxin-like compounds from the wastewater prior to discharging
wastewater into surface water. All of the sludge generated at your facility is placed in an on-site
RCRA subtitle C landfill. Calculate how much dioxin and dioxin-like compounds are released to
land at your facility.
26
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Step 1. Determine the amount of sludge generated each day at your facility
Sludge generated = sludge generation rate per L wastewater x wastewater per day
_,, , , { 1kg sludge 1 \3.78 x 10s L wastewater]
Sludge generated = < > x \ >
[5000 L wastwater j [ day J
Sludge generated = 7.56x 104 kg /day
Step 2. Estimate the Emission Factor (EF) for dioxin and dioxin-like compounds in the sludge
If it is assumed that all the dioxin and dioxin-like compounds that are removed from the
wastewater during the treatment process are contained in the sludge generated from the wastewater
treatment process, then the EF for sludge can be calculated as a function of dioxin and dioxin-like
compounds removal efficiency from the wastewater. Thus the EF for dioxin and dioxin-like
compounds in wastewater times the removal efficiency gives an approximate indication of the dioxin
and dioxin-like compounds EF for sludge at your facility. In the following calculation, assume the
density of sludge = 500 g/ L.
EFsludge = \FFnastewater x [1 - fraction D&DLC removed] \ x density of sludge x units conversion factors
\10pg D&DLC} x 1 \ 1L } x \103g
} L wastewater J J [500 gj X [ kg
EFsllld = 10 pg dioxin and dioxin-like compounds / kg
Step 3. Calculate the annual release of dioxin and dioxin-like compounds to land
n f quantity sludge \ t „„ ) \ operating days\
R, = \ — x {EF, , \ x < — —^— >
land I day ) * "*»> [ year J
= \7.56xltf kg sludge} \10pgD&DLC} [ g } \365days}
land } day }*} kg sludge }X\1012pg\X} year }
Rland = 3 x Iff4 g dioxin and dioxin - like compounds / year
27
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Section 4.0. FACILITY-SPECIFIC EPA DEFAULT EMISSION FACTORS
EPA is providing default emission factors for facilities to use, at their discretion, in reporting
annual releases and other waste management quantities of dioxin and dioxin-like compounds. You are
encouraged, however, to use site-specific information on releases from your facility. EPA recognizes
that emissions and environmental release data are not available in most cases. This guidance is
providing a series of 'look-up' tables to assist you in meeting the requirements of annually reporting
releases of dioxin and dioxin-like compounds. Information is limited to those source categories for
which EPA believes sufficient information is available to develop default emission factors that can be
used to make reasonable estimations of releases. The documentation for the derivation of the emission
factors can be found in three EPA references (available in pdf format at: http://www.epa.gov/tri/):
• EPA's Database of Sources of Environmental Releases of Dioxin-Like Compounds in
the United States. U.S. Environmental Protection Agency, National Center for
Environmental Assessment, Office of Research and Development, Washington, DC
20460, EPA/600/P-98/002B, September, 2000.
• The Inventory of Sources of Dioxin in the United States. U.S. Environmental
Protection Agency, National Center for Environmental Assessment, Office of
Research and Development, Washington, DC 20460, EPA/600/P-98/002Aa.
• Estimating Exposure to Dioxin-Like Compounds: Volume 2: Sources of Dioxin-Like
Compounds in the United States, EPA/600/)-00/001, Draft Final, September,
2000.
In applying these default emission factors, you are encouraged to read the summary description
provided for the facilities that were used to derive the default emission factors. Facilities should use
those emission factors that match as closely as practical the class type and pollution control systems of
your facility. Although EPA's default emission factors are arithmetic averages of environmental releases
from tested facilities, EPA recognizes that these tested facilities may not be an ideal match to your
facility. The decision to use EPA default emission factors is best left to the operator of the facility. This
guidance is intentionally made to be flexible in the use and selection of emissions of dioxin and dioxin-
like compounds that are most representative of emissions from your facility. All of the emission factors
contained in the tables in this section are for controlled conditions.
In all of the emission factors tables the emission factor for the dioxin and dioxin-like
compounds category is equal to the sum of the emission factors for the 7 dibenzo-p-dioxins (CDDs)
covered by the category and the 10 dibenzofurans (CDFs) covered by the category. Thus,
• Dioxin and dioxin-like compounds = • CDDs + • CDFs
28
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Section 4.1. Pulp and Paper Mills and Lumber and Wood Products
Section 4.1.1. Applicability
The following SIC Codes are included within this category:
I. SIC Code 2611 Pulp Mills: Establishments primarily engaged in manufacturing pulp from wood or
from other materials, such as rags, linters, wastepaper, and straw. Establishments engaged in integrated
logging and pulp mill operations are classified according to the primary products shipped.
Establishments engaged in integrated operations of producing pulp and manufacturing paper,
paperboard, or products thereof are classified in Industry 2621 if primarily shipping paper or paper
products; in Industry 2631 if primarily shipping paperboard or paperboard products; and in Industry
2611 if primarily shipping pulp.
II. 2621 Paper Mills: Establishments primarily engaged in manufacturing paper from woodpulp and
other fiber pulp, and which may also manufacture converted paper products. Establishments primarily
engaged in integrated operations of producing pulp and manufacturing paper are included in this
industry if primarily shipping paper or paper products. Establishments primarily engaged in
manufacturing converted paper products from purchased paper stock are classified in Industry Group
265 or Industry Group 267.
III. 2400 Lumber and Wood Products. Except Furniture: Establishments primarily engaged in cutting
timber and pulpwood; merchant sawmills, lath mills, shingle mills, cooperage stock mills, planing mills,
and plywood mills and veneer mills engaged in producing lumber and wood basic materials. Also
included within this SIC code are establishments engaged in manufacturing finished articles made
entirely or mainly of wood or related materials. Major Group 24 includes Industry Groups 241, 242,
243, 244, 245, and 249. Furniture and office and store fixtures are classified in Major Group 25.
Woodworking in connection with construction, in the nature of reconditions and repair, or performed to
individual order, is classified in nonmanufcturing industries.
Industry Group 241
2411 Logging
Industry Group 242
2421 Sawmills and Planing Mills
2431 Millwork
2434 Wood Kitchen Cabinets
2435 Hardwood Veneer and Plywood
2436 Softwood Veneer and Plywood
Industry Group 244
2441 Nailed and Lock Corner Wood Boxes and Shook
2448 Wood Pallets and Skids
2449 Wood Containers
29
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Industry Group 245
2451 Mobile Homes
2452 Prefabricated Wood Buildings and Components
Industry Group 249
2491 Wood Preserving
2493 Reconstituted Wood Products
2499 Wood Products
Section 4.1.2. Emission Factors for Releases to Water From Bleached Chemical Pulp Mills
On April 15, 1998 and August 7, 1998, EPA promulgated final effluent standards (Federal
Register, 1998) under the Clean Water Act for pulp and paper mills (63 FR 18504-18751, and 63 FR
42238-42240). Mills subject to regulation are pulp mills and integrated mills (mills that manufacture
pulp and paper/paperboard), that chemically pulp wood fiber (using kraft, sulfite, soda, or
semi-chemical methods); that produce pulp secondary fiber; pulp non-woody fiber; and mechanically
pulp wood fiber. The regulations established dioxin discharge limits for bleached chemical pulp mills.
In reporting releases of dioxin and dioxin-like compounds to surface waters, the facility may use the
EPA default emission factors in Table 4-1, which were developed for bleached chemical pulp mills.
The data were generated at a series of eight bleached chemical pulp mills prior to promulgation of the
effluent standards.
30
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Table 4-1. Average Emission Factors (pg/L) for Estimating Wastewater Discharges of Dioxin
and Dioxin-like Compounds into Surface Water From Bleached Chemical Pulp Mills
CDD
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1, 2,3,4, 7,8-HxCDD
1, 2,3,6, 7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
• CDDs
• Dioxin and dioxin-
like compounds*
Mean Emission Factor
(Pg/L)
1.2
0
0
0
0
3.2
99.0
103.4 pg/L
105.7 pg/L
CDF
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
• CDFs
Mean Emission
Factor (pg/L)
2.3
0
0
0
0
0
0
0
0
0
2.3 pg/L
Source: Gillespie, 1997; *• Dioxin and dioxin-like compounds = • CDDs + • CDFs
Section 4.1.3. Emission Factors for Releases to Land From Bleached Chemical Pulp Mills
The conventional wastewater treatment of effluents results in the generation of wastewater
sludge. If your facility applies the sludge to land, or places it in a RCRA subtitle C landfill for disposal,
then the default emission factors for bleached chemical pulp mills in Table 4-2 apply. These emission
factors are based on data from a series of the same bleached chemical pulp mills referenced in section
4.1.2.
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Table 4-2. Average Emission Factors (ng/kg) for Land Disposal of Dioxin and Dioxin-like
Compounds in Wastewater Sludge from Bleached Chemical Pulp Mills.
CDD
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1, 2,3,4, 7,8-HxCDD
1, 2,3,6, 7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
CDDs
Dioxin and dioxin-like
compounds*
Mean Emission
Factor (ng/kg)
0.8
0
0.5
2.3
1.6
41.4
445.0
49 1.6 ng/kg
500 ng/kg
CDF
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
CDFs
Mean Emission
Factor (ng/kg)
6.2
0
0.5
0
0
0
0.5
1.2
0
0
8.4 ng /kg
Source: Gillespie, 1997; * Dioxin and dioxin-like compounds = Sum of CDDs + CDFs
Section 4.1.4. Emission Factors for Releases to Air From Pulp Mill or Lumber and Wood
Products Facilities
Wood waste and bark produced from processing timber at a pulp mill or lumber and wood
products facility are burned in the facilities' bark and/or wood-waste boilers (NCASI, 1995). This
wood waste can produce CDDs/CDFs during combustion. If your lumber and wood products industry
facility burns wood waste and bark, then the default emission factors in Table 4-3 apply.
32
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Table 4-3. Average Emission Factors (ng/kg) for Air Releases of Dioxin and Dioxin-
like Compounds from the Combustion of Wood Waste and Bark (as fired) at Pulp Mill
or Lumber and Wood Product Industry Facility Boilers.
CDD
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1, 2,3,4, 7,8-HxCDD
1, 2,3,6, 7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
CDDs
Dioxin and dioxin-like
compounds*
Mean Emission Factor
(ng/kg)
0.005
0.005
0.012
0.050
0.035
0.300
1.200
1.6 ng/kg
2.4 ng/kg
CDF
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
CDFs
Mean Emission
Factor (ng/kg)
0.104
0.022
0.020
0.070
0.043
0.036
0.004
0.274
0.081
0.187
0.84 ng /kg
Source: NCASI (1995); *Dioxin and dioxin-like compounds = Sum of CDDs + CDFs
Section 4.2. Secondary Smelting and Refining of Nonferrous Metals
Section 4.2.1. Applicability
SIC Code 3341, Secondary Smelting and Refining of Nonferrous Metals, include
establishments primarily engaged in recovering nonferrous metals and alloys from new and used scrap
and or in producing alloys from purchased refined metals. This industry includes establishments
engaged in both the recovery and alloying of precious metals. Plants engaged in the recovery of tin
through secondary smelting and refining, as well as by chemical processes, are included in this industry.
Establishments primarily engaged in assembling, sorting, and breaking up scrap metal, without smelting
and refining, are classified in Wholesale Trade, Industry 5093. Applicable facilities include:
Aluminum smelting and refining, secondary
Copper smelting and refining, secondary
Lead smelting and refining, secondary
Nonferrous metal smelting and refining, secondary
Recovering and refining of nonferrous metals
Secondary refining and smelting of nonferrous metals
33
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Section 4.2.2. Secondary Aluminum Smelters
Stack tests from five secondary aluminum facilities (described below) were used by EPA to
derive mean air emission factors of dioxin and dioxin-like compounds. Secondary aluminum smelters
reclaim aluminum from scrap containing aluminum. This recycling involves two processes — pre-
cleaning and smelting. Both processes may produce CDD/CDF emissions.
Pre-cleaning processes involve sorting and cleaning scrap to prepare it for smelting. Cleaning
processes that may produce CDD/CDF emissions use heat to separate aluminum from contaminates
and other metals; these techniques are roasting and sweating. Roasting uses rotary dryers with a
temperature high enough to vaporize organic contaminants, but not high enough to melt aluminum. An
example of roasting is the delacquering and processing of used beverage cans. Sweating involves
heating aluminum-containing scrap metal to a temperature above the melting point of aluminum, but
below the melting temperature of other metals such as iron and brass. The melted aluminum trickles
down and accumulates in the bottom of the sweat furnace and is periodically removed (U.S. EPA,
1997).
After pre-cleaning, the treated aluminum scrap is smelted and refined. This usually takes place
in a reverberatory furnace. Once smelted, flux is added to remove impurities. The melt is "demagged"
to reduce the magnesium content of the molten aluminum by the addition of chlorine gas. The molten
aluminum is transferred to a holding furnace and alloyed to final specifications (U.S. EPA, 1997).
CDD/CDF emissions to air have been measured at five U.S. secondary aluminum operations.
These facilities were tested in 1995. The tests were conducted by EPA in conjunction with the
Aluminum Association for the purpose of identifying emission rates from facilities with potentially
maximum achievable control technology (MACT)-grade operations and air pollution control device
(APCD) equipment.
The first facility tested in 1995 was a top charge melt furnace (Advanced Technology
Systems, Inc., 1995). During testing, the charge material to the furnace was specially formatted to
contain no oil, paint, coatings, rubber, or plastics (other than incidental amounts). The CDD/CDF
emissions from such a clean charge, 0.26 ng toxic equivalents (TEQ)/kg charge material, would be
expected to represent the low-end of the normal industry range.
The second facility operates a sweat furnace to preclean the scrap and a reverberatory furnace
to smelt the pre-cleaned aluminum (U.S. EPA, 1995). Stack emissions are controlled by
an afterburner operated at 1,450* F.
The third facility employs a crusher/roasting dryer as a pre-cleaning step followed by a
reverberatory furnace (Galson Corporation, 1995). The emissions from the two units are vented
separately. The exhaust from the crusher/dryer is treated with an afterburner and a baghouse. The
exhaust from the furnace passes through a baghouse with lime injection.
34
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The fourth facility operates a scrap roasting dryer followed by a sidewell reverberatory furnace
(Roy Weston, 1996). The emissions from the two units are vented separately. Exhaust from the dryer
passes through an afterburner and a lime-coated baghouse. The exhaust from the furnace passes
through a lime-coated baghouse.
The fifth facility is a dryer/delacquerer secondary aluminum facility tested by
Commonwealth Aluminum Corporation (1995). The results of this test were submitted to EPA as part
of the public comments by the industry in association with development of the MACT standard.
Table 4-4 summarizes average default emission factors (ng/kg scrap aluminum processed) for
estimating air releases of dioxin and dioxin-like compounds from secondary aluminum smelters. For
the default emission factor, EPA is recommending 44.55 ng dioxin and dioxin-like compounds emitted
per kg of aluminum scrap processed. This is based on an arithmetic average of the five tested facilities
presented in the Table. As an alternative to using this default emission factor, the owner or operator of
secondary aluminum facilities may review the individual test reports supporting the development of the
table (see references), and, based on good engineering judgement, decide the most appropriate
emission factors for your facility. Defaults are given here in the context of providing an option for
estimating air releases from secondary aluminum smelters.
35
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Table 4-4. Average Emission Factors (ng/kg scrap aluminum processed) for Estimating Air Releases of Dioxin and Dioxin-like
Compounds from Secondary Aluminum Smelters
Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1, 2,3,4 ,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
• Dioxin and Dioxin-
Like Compounds
Mean emission factors
of dioxin and dioxin-like
compounds
Mean Facility
Emission Factor
(ng/kg scrap feed)
(Ref. 1)
ND
0.02
0.05
0.13
0.15
0.51
0.42
0.44
0.06
0.17
0.32
0.11
0.02
0.30
0.07
0.03
0.30
3.1
44.55
Mean Facility
Emission Factor
(ng/kg scrap feed)
(Ref. 2)
0.13
0.39
0.24
0.86
1.26
7.67
14.97
0.74
1.51
2.44
2.44
2.69
1.02
3.82
11.39
5.50
30.40
87.47
Mean Facility
Emission Factor
(ng/kg scrap feed)
(Ref. 3)
0.51
1.19
1.35
1.52
2.51
2.60
1.01
14.20
10.47
11.06
21.84
7.10
0.47
7.09
14.61
1.21
3.15
101.89
Mean Facility
Emission Factor
(ng/kg scrap feed)
(Ref. 4)
0.25
0.75
0.53
0.65
1.29
2.84
NA
5.50
1.90
3.18
4.65
1.48
0.08
1.87
2.97
0.24
1.04
29.22
Mean Facility
Emission Factor
(ng/kg scrap feed)
(Ref. 5)
0.01
0.02
0.02
0.03
0.05
0.1
NA
0.08
0.07
0.12
0.16
0.06
0.01
0.08
0.17
0.04
0.06
1.08
TEQ calculations assume not-detected values are zero.
NA= Not available.
ND = Not detected (value in parenthesis is the emission at the detection limit).
Sources: Ref. 1: Advanced Technology Systems, Inc. (1995)
Ref. 2: U.S. EPA (1995h)
Ref. 3: Galson Corporation (1995)
Ref. 4: Roy Weston, Inc. (1996)
Ref. 5: Commonwealth Aluminum Corp (1995)
36
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Section 4.2.3. Secondary Lead Smelters
The secondary lead smelting industry produces elemental lead through the chemical reduction
of lead compounds in a high temperature furnace (1,200 to 1,260* C). Smelting is performed in
reverberatory, blast, rotary, or electric furnaces. Blast and reverberatory furnaces are the most
common types of smelting furnaces used by the 23 facilities that comprise the current secondary lead
smelting industry in the United States. Of the 45 furnaces at these 23 facilities, 15 are reverberatory
furnaces, 24 are blast furnaces, five are rotary furnaces, and one is an electric furnace. The one electric
furnace and 11 of the 24 blast furnaces are co-located with reverberatory furnaces, and most share a
common exhaust and emissions control system (U.S. EPA, 1994b).
Furnace charge materials consist of lead-bearing raw materials, lead-bearing slag and drosses,
fluxing agents (blast and rotary furnaces only), and coke. Scrap motor vehicle lead-acid batteries
represent about 90 percent of the lead-bearing raw materials at a typical lead smelter. Fluxing agents
consist of iron, silica sand, and limestone or soda ash. Coke is used as fuel in blast furnaces and as a
reducing agent in reverberatory and rotary furnaces. Organic emissions from co-located blast and
reverberatory furnaces are more similar to the emissions of a reverberatory furnace than the emissions
of a blast furnace (U.S. EPA, 1994b).
Flistorically, many lead-acid batteries contained PVC plastic separators between the battery
grids. These separators are not removed from the lead-bearing parts of the battery during the battery
breaking and separation process. When the PVC is burned in the smelter furnace, the chlorine atoms
are released as HC1, C^, and chlorinated hydrocarbons (Federal Register, 1995d). The source of
CDDs/CDFs at secondary lead smelters is the PVC separator (U.S. EPA, 1995c). In 1990, about 1
percent of scrap batteries processed at lead smelters contained PVC separators. In 1994, less than
0.1 percent of scrap batteries contained PVC separators. This trend is expected to continue because
no U.S. manufacturer of lead-acid automotive batteries currently uses PVC in production (U.S. EPA,
1995c; Federal Register, 1995d).
The total current annual production capacity of the 23 companies currently comprising the
U.S. lead smelting industry is 1.36 million metric tons. Blast furnaces not co-located with reverberatory
furnaces account for 21 percent of capacity (or 0.28 million metric tons). Reverberatory furnaces and
blast and electric furnaces co-located with reverberatory furnaces account for 74 percent of capacity
(or 1.01 million metric tons). Rotary furnaces account for the remaining 5 percent of capacity (or 0.07
million metric tons). Actual production volume statistics by furnace type are not available. However, if
it is assumed that the total actual production volume of the industry, 0.97 million metric tons in 1995
(U.S. Geological Survey, 1997a) and 0.72 million metric tons in 1987 (U.S. EPA, 1994a), are
reflective of the production capacity breakdown by furnace type, then the estimated actual production
volumes of blast furnaces (not co-located), reverberatory and co-located blast/electric and
reverberatory furnaces, and rotary furnaces were 0.20, 0.72, and 0.05 million metric tons, respectively,
in 1995, and 0.15, 0.53, and 0.04 million metric tons, respectively, in 1987. In 1987, the industry
consisted of 24 facilities.
37
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CDD/CDF emission factors can be estimated for lead smelters based on the results of
emission tests performed by EPA at three smelters (a blast furnace, a co-located blast/reverberatory
furnace, and a rotary kiln furnace) (U.S. EPA, 1992e; 1995d; 1995e). The air pollution control systems
at the three tested facilities consisted of both baghouses and scrubbers. Congener-specific
measurements were made at the exit points of both APCD exit points at each facility. Table 4-5
presents the congener emission factors from the baghouse and the scrubber for each site. Although all
23 smelters employ baghouses, only 9 employ scrubber technology.
Table 4-5. Average Emission Factors (ng/kg) for Estimating Annual Releases of
Dioxin and Dioxin-Like Compounds from Secondary Lead Smelters
CDD/CDF
Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
• CDDs
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
• CDFs
• Dioxin and dioxin-like
compounds*
Blast Furnace
(ng/kg lead
produced)
before
scrubber
2.11
0.99
0.43
0.99
1.55
2.06
1.40
9.53
8.73
3.88
6.65
5.83
1.67
0.11
2.06
2.34
0.63
1.39
33.29
42.82
after
scrubber
0.25
0.03
0.00
0.03
0.03
0.08
0.39
0.81
0.93
0.43
0.36
0.37
0.11
0.00
0.11
0.19
0.06
0.18
2.74
3.55
Blast/ reverb
(ng/kg lead
produced)
before
scrubber
0.00
0.00
0.00
0.00
0.00
0.10
0.57
0.67
1.46
0.24
0.31
0.63
0.19
0.00
0.15
0.48
0.00
0.29
3.75
4.42
after
scrubber
0.00
0.00
0.00
0.00
0.00
0.06
0.55
0.61
0.49
0.02
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.51
1.12
Rotary kiln
(ng/kg lead produced)
before
scrubber
0.10
0.01
0.00
0.00
0.00
0.00
0.24
0.35
0.40
0.14
0.14
0.11
0.02
0.04
0.00
0.03
0.00
0.00
0.88
1.23
after
scrubber
0.24
0.00
0.00
0.00
0.00
0.22
2.41
2.87
1.20
0.40
0.46
0.27
0.10
0.13
0.00
0.13
0.00
0.00
2.69
5.56
*• Dioxin and dioxin-like compounds = • CDDs+« CDFs
38
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Facilities that employ scrubbers account for 14 percent of the blast furnace (not co-located) production
capacity, 52 percent of the reverberatory and co-located furnace production capacity, and 57 percent
of the rotary furnace production capacity. From the reported data, congener-specific CDD/CDF
emission factors (ng /kg lead processed) for each of the three furnace configurations are presented in
Table 4-5. The range reflects the presence or absence of a scrubber. Note that calculations using
emission factors before scrubbers would apply towards threshold calculations since this represents
amounts that have been manufactured. They can also be used to estimate the amounts that a scrubber
has removed and then the amounts removed, depending on how the scrubber material is handled,
should be reported in the appropriate section of the Form R.
As discussed earlier in this section, the PVC separators used historically in lead-acid batteries
are believed to be the source of the CDD/CDFs observed in emissions from secondary lead smelters.
PVC separators are no longer used in the United States in the manufacture of lead-acid batteries, and
less than 0.1 percent of the scrap batteries in 1994 contained PVC separators (U.S. EPA, 1995c;
Federal Register, 1995c). EPA predicts that by the time existing smelters demonstrate compliance in
1997 with the National Emission Standards for Hazardous Air Pollutants (NESFLAP) for secondary
lead smelters promulgated by EPA (Federal Register, 1995c), batteries containing PVC will only be
present in the scrap battery inventory in trace amounts, resulting at most, in only trivial amounts of HC1
or C12 air emissions.
Section 4.2.4. Secondary Copper Smelters/Refiners
Secondary copper smelting is part of the scrap copper, brass, and bronze reprocessing
industry. Brass is an alloy of copper and zinc; bronze is an alloy of copper and tin. Facilities in this
industry fall into three general classifications: secondary smelting, ingot making, and remelting. Similar
process equipment may be used at all three types of facilities, so that the distinguishing features are not
immediately apparent (U.S. EPA, 1994c).
The feature that distinguishes secondary smelters from ingot makers and remelters is the extent
to which pyrometallurgical purification is performed. A typical charge at a secondary smelter may
contain from 30 to 98 percent copper. The secondary smelter upgrades the material by reducing the
quantity of impurities and alloying materials, thereby increasing the relative concentration of copper.
This degree of purification and separation of the alloying constituents does not occur at ingot makers
and remelters. Feed material to a secondary copper smelter is a mixture of copper-bearing scrap
comprised of such scrap as tubing, valves, motors, windings, wire, radiators, turnings, mill scrap,
printed circuit boards, telephone switching gear, and ammunition casings. Non-scrap items like blast
furnace slags and drosses from ingot makers or remelters may represent a portion of the charge. The
secondary smelter operator uses a variety of processes to separate the alloying constituents. Some
purify the scrap in the reductive atmosphere of a blast furnace. The charge may be subsequently
purified in the oxidizing atmosphere of a converter. Other secondary smelters perform all purification
by oxidation in top-blown rotary converters or in reverberatory furnaces (U.S. EPA, 1994c).
39
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The ingot makers blend and melt scrap copper, brass, and bronze of various compositions to
produce a specification brass or bronze ingot. When necessary, the ingot makers add ingots of other
metals (e.g., zinc or tin) to adjust the metallurgy of the final product. The feed materials for ingot
makers contain relatively high amounts of copper. Examples of feed materials include copper tubing,
valves, brass and bronze castings, ammunition shell casings, and automobile radiators. "Fire-refined"
anode copper or cathode copper may also be charged. Items such as motors, telephone switchboard
scrap, circuit board scrap, and purchased slags are not used by ingot makers. The reductive step
(melting in a reducing atmosphere, as in a blast furnace) that some secondary smelters employ is not
used by ingot makers. Ingot makers do, however, use some of the other types of furnaces used by
secondary smelters, including direct-fired converters, reverberatory furnaces, and electric induction
furnaces (U.S. EPA, 1994c).
Remelting facilities do not conduct any substantial purification of the incoming feeds. These
facilities typically just melt the charge and cast or extrude a product. The feeds to a remelter are
generally alloy material of approximately the desired composition of the product (U.S. EPA, 1994c).
In 1991, stack testing of the rotary furnace stack emissions of a secondary smelter located in
Alton, Illinois (Chemetco, Inc.) was conducted by Sverdrup Corp. (1991). The Chemetco facility uses
four tap down rotary (i.e., oxidizing) furnaces. Furnace process gas emissions are controlled by a
primary quencher and a venturi scrubber. The feed is relative high purity copper scrap containing
minimal plastics, if any. The same manufacturing process and APCD equipment were in place in 1987
and 1995 (U.S. EPA, 1994c). This facility operated under oxidizing rather than reducing conditions
and processes relatively high purity scrap, the potential for CDD/CDF formation and release is
expected to be dramatically different than that of the two tested facilities reported above. The
estimated emission factors derived for this site from the results in Sverdrup (1991) are presented in
Table 4-6.
Although little research has been performed to define the CDD/CDF formation mechanism(s)
in secondary copper smelting operations, two general observations have been made (Buekens et al.,
1997). The presence of chlorinated plastics in copper scraps used as feed to the smelters is believed to
increase the CDD/CDF formation. Second, the reducing or pyrolytic conditions in blast furnaces can
lead to high CDD/CDF concentrations in the furnace process gases.
40
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Table 4-6. CDD/CDF Emission Factors (ng Dioxin and Dioxin-like Compounds per kg copper
scrap processed) for Secondary Copper Smelters
Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
• CDDs
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-BcCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-BcCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
• CDFs
• Dioxin and dioxin-like compounds*
Chemetco Smelting
(ng/kg scrap feed)
ND (0.05)
0.21
0.39
0.70
1.26
8.95
22.45
33.96
2.11
1.47
2.63
7.30
2.15
4.06
0.27
11.48
2.74
21.61
55.82
89.78
*• Dioxin and dioxin-like compounds = • CDDs + « CDFs
ND = Not detected (value in parenthesis is the emission at the detection limit).
Source: Sverdrup (1991).
It should be noted that a significant amount of scrap copper is consumed by other segments of
the copper industry. In 1995, brass mills and wire-rod mills consumed 886,000 metric tons of copper-
base scrap; foundries and miscellaneous manufacturers consumed 71,500 metric tons (U.S. Geological
Survey, 1997). As noted above, however, these facilities generally do not conduct any significant
purification of the scrap. Rather, the scrap consumed is already of alloy quality and processes
employed typically involve only melting, casting and extruding. Thus, the potential for formation of
CDDs/CDFs is expected to be much less than the potential during secondary smelting operations.
Table 4-6 is a listing of CDD/CDF default emissions factors for secondary copper smelters.
In choosing the appropriate emission factor, the owner/operator is encouraged to exercise good
engineering judgement to appropriately select the most suitable emission factors. Such judgement
requires first-hand knowledge of your process. EPA believes that the most appropriate default
emission factors are those derived from the stack testing of the Chemetco Smelting Facility as shown in
41
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Table 4-6. This is because the state-of-the-art involved in secondary copper smelting calls for the
mechanical removal of plastic material prior to smelting and refining, and to use copper-laden scrap that
is relatively free of organic contamination. Therefore, if your facility processes copper scrap containing
a relatively high amount of plastics, then the emission factors listed in Table 4-6 are not appropriate to
use as default emission factors.
Section 4.3. Cement Kilns
Section 4.3.1. Applicability
Kilns used in the pyroprosessing of Portland Cement clinker as defined in SIC Code 3241.
Section 4.3.2. Summary Description / Air Emission Factors
In the United States, the primary cement product is called Portland cement. Portland cement
is a fine, grayish powder consisting of a mixture of four basic materials: limestone, silica, alumina, and
iron compounds. Cement production involves heating (pyroprocessing) the raw materials (known as
raw meal) to a very high temperature in a rotary (rotating) kiln to induce chemical reactions that
produce a fused material called clinker. The cement clinker is further ground into a fine powder and
mixed with gypsum to form the Portland cement.
The cement kiln is a large, rotating steel cylindrical furnace lined with refractory material. The
kiln is aligned on a slight angle, usually a slope of 3» - 6». This allows for the materials to pass through
the kiln by gravity. The upper end of the kiln is known as the cold or back end and this is where the
raw materials, or meal, is generally fed into the kiln. The lower end of the kiln is known as the "hot"
end. The hot end is where the combustion of primary fuels (coal, petroleum coke, natural gas, etc.)
transpires to produce a high temperature.
The cement kiln is operated in a counter-current configuration. This means that the hot
combustion gases are convected up through the kiln while the raw materials are passing down toward
the lower end. The rotation of the kiln induces mixing and the forward progress of mixed materials. As
the meal moves through the cement kiln and is heated by the hot combustion gases, water is vaporized
and pyroprocessing of materials occurs.
When operating, the cement kiln can be viewed as consisting of three temperature zones
necessary to produce clinker. Zone 1 is at the upper end of the kiln where the raw meal is added.
Temperatures in this zone typically range from ambient up to 600* C. In this area of the kiln, moisture is
evaporated from the raw meal. The second thermal zone is known as the calcining zone. Calcining
occurs when the hot combustion gases from the combustion of primary fuels dissociates calcium
carbonate from the limestone to form calcium oxide. In this region of the kiln, temperatures are in a
range of 600* C to 900* C. The third region of the kiln is known as the burning or sintering zone. The
burning zone is the hottest region of the kiln. In this region, temperatures in excess of 1,500* C induce
42
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the calcium oxide to react with silicates, iron and aluminum in the raw materials to form clinker. The
formation of clinker actually occurs near the lower end of the kiln (close to the combustion of primary
fuel) where temperatures are the hottest. The chemical reactions that occur here are referred to as
pyroprocessing.
The clinker that leaves the hot end of the kiln is a gray-colored, glass-hard material comprised
of dicalcium silicate, tricalcium silicate, calcium aluminate, and tetracalcium aluminoferrite. At this point,
the clinker has a temperature of about 1,1OO C. The hot clinker is then transferred into the clinker
cooler. Once cooled, the clinker is ground into a fine powder and mixed with gypsum to produce
Portland cement.
Cement kilns are either wet or dry processes. In the wet process, the raw materials are
ground and mixed with water to form a slurry. The meal-water slurry is fed into the kiln through a
pump. A greater amount of heat energy is needed in the wet process to evaporate the additional water.
In the dry process, the raw meal is ground to a fine, dry powder prior to entering the kiln.
There are three types of dry processes: long-dry, preheater, and preheater/precalciner. Long dry kilns
are similar to wet kilns, with the exception of the dry state of the raw materials. In preheater kilns, the
raw material is heated prior to entering the kiln. This allows for a shorter kiln and lower combustion
fuel use. Precalciners take this a step further by heating the raw feed to a level at which partial
calcination takes place prior to entering the kiln. A typical preheater/precalciner kiln consists of a
vertical tower containing a series of cyclone-type vessels. Raw meal is added at the top of the tower,
and hot kiln exhaust flue gases from the kiln operation are used to preheat the meal prior to being
introduced into the kiln. Preheating and precalcining the meal has the advantage of lowering fuel
consumption of the kiln.
There are also two primary types of air pollution control devices (APCDs) for the kiln: fabric
filters and electrostatic precipitators (ESPs). Either of these can be used on any of the four process
types.
Cement manufacturing is an energy intensive manufacturing process. Fossil fuels are the
primary sources of fuel. In addition, 15 cement plants in the U.S. currently supplement their fuel needs
through the use of energy-bearing hazardous waste. For the last ten years, these facilities have been
regulated by the Resource Conservation and Recovery Act's (RCRA) Boiler and Industrial Furnace
(BIF) rules. As a result, a database has been developed characterizing emissions from these facilities.
Testing and additional studies have contributed significantly to our understanding of dioxin formation in
cement plants.
In developing Maximum Achievable Control Technology (MACT) standards for cement
plants, EPA "considered both hazardous waste burning cement kiln and non-hazardous waste burning
cement kiln data together because both data sets are adequately representative of general dioxin/furan
behavior and control in either type of kiln. This similarity is based on our engineering judgement that
43
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hazardous waste burning does not have an impact on dioxin/furan formation, dioxin/furan is formed
post-combustion." (See 64 FR 52876) APCD air inlet temperature (and the time that the air takes to
enter the device) in conjunction with other site-specific elements is the determining factor.
On June 14, 1999, EPA published a National Emission Standard for Hazardous Air Pollutants
(NESHAP) for the Portland cement industry in the Federal Register (64 FR 31898). In addition, on
September 30, 2000, EPA published a National Emission Standard for Hazardous Air Pollutants
(NESHAP) for hazardous waste combustors (including cement kilns that recover energy from
hazardous wastes) in the Federal Register (64 FR 52828). These rules require, among other things,
that all cement plants periodically conduct dioxin/furan testing.
The EPA source emissions data base contains test reports of CDD/CDF emissions from 15
cement kilns not burning hazardous waste. The average CDD/CDF emission factors displayed in Table
4-7 are derived as an average from these test data. These default emission factors are more
appropriate for facilities tested in 1998, and do not reflect changes that have occurred since that time.
As an operator/owner of a facility, you may elect to use more current information in the development of
an emission factor, or you may elect to use the EPA default. If you elect to use more current emission
factors, then you will be using Approach 2 (Section 2.1.2) to derive your emission estimate appropriate
for your facility.
44
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Table 4-7. Average Emission Factors (ng/kg of cement clinker produced) for Estimating Air
Releases of Dioxin and Dioxin-like Compounds from Cement Kilns Not Combusting
Hazardous Waste as Supplemental Fuel
CDD Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1, 2,3,4, 7,8-HxCDD
1, 2,3,6, 7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
• CDDs
• Dioxin and dioxin-like
compounds*
Emission
Factor
(ng/kg clinker)
0.012
0.034
0.028
0.042
0.048
0.426
0.692
1.28
3.05
CDF Congener
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
• CDFs
Emission
Factor
(ng/kg clinker)
0.729
0.102
0.224
0.185
0.054
0.007
0.082
0.146
0.005
0.234
1.77
*• Dioxin and dioxin-like compounds = • CDDs+« CDFs
Section 4.4. Utilities
Section 4.4.1. Applicability
This applies to SIC Codes 4911, 4931, and 4939 Electric Services. This guidance is for
electric power utility boilers burning coal, wood and oil for the expressed purpose of producing steam
to operate a steam generator, which, in turn, generates electricity.
Section 4.4.2. Description/Emissions Factors for Coal-Fired Electric Utility Boilers
In 1993, the U.S. Department of Energy (DOE) and the Electric Power Research Institute
(EPRI) collaborated on assessing stack emissions of hazardous air pollutants at coal-fired power plants.
As part of this project, CDD/CDF stack emissions were measured at seven U.S. coal-fired power
plants (utility boilers). The levels reported for individual 2,3,7,8-substituted congeners were typically not
detected or very low (i.e., • 0.033 ng/Nm3). In general, CDF levels were higher than CDD levels.
OCDF and 2,3,7,8-TCDF were the most frequently detected congeners. Variation in emissions
between plants could not be attributed by Riggs et al. (1995) to any specific fuel or operational
characteristic. The Electric Power Research Institute (EPRI) has published the results of the DOE/EPRI
45
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cooperative testing of a total of eleven plants (EPRI, 1994). The average congener emission factors
derived from this eleven facility data set, as reported in EPRI (1994), are presented in Table 4-8.
Table 4-8. Average Emission Factors (ng/kg of coal combusted) for Estimating Air Releases
of Dioxin and Dioxin-like Compounds from Coal-Fired Electric Utility Boilers
CDD Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
• CDD
• Dioxin and dioxin-like
compounds*
Emission Factor
(ng/kg coal)
0.005
0
0
0.004
0.004
0.216
0.517
0.75
1.71
CDF Congener
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
• CDF
Emission Factor
(ng/kg coal)
0.109
0.007
0.074
0.098
0.014
0.013
0.043
0.354
0.087
0.158
0.96
*• Dioxin and dioxin-like compounds = • CDDs + • CDFs. Assumes non-detects = 0.
Source: EPRI (1994) -11 facility data set.
Section 4.4.3. Description/Emissions Factors for Oil-Fired Electric Utility Boilers
Preliminary CDD/CDF emission factors for oil-fired utility boilers developed from boiler tests
conducted over the past several years are reported in U.S. EPA (1995c). In 1993, the Electric Power
Research Institute (EPRI) sponsored a project to gather information of consistent quality on power plant
emissions. This project, the Field Chemical Emissions Measurement (FCEM) project, included testing
of two cold side ESP-equipped oil-fired power plants for CDD/CDF emissions (EPRI, 1994). Table
4-9 presents CDD/CDF congener-specific emission factors (ng/L oil combusted) for oil-fired utility
boilers.
46
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Table 4-9. Average Emission Factors (pg/L oil combusted) for Estimating Air Releases of
Dioxin and Dioxin-like Compounds from Oil-Fired Utility Boilers
CDD
Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
• CDD
• Dioxin and dioxin-like
compounds*
Emission Factor
(pg/L oil)
0
24.7
63.3
65.8
79.7
477
2055
2,765.5
3,178.6
CDF
Congener
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-
OCDF
• CDF
Emission Factor
(pg/L oil)
0
64.1
49.3
76.5
35.4
0
23.8
164
0
0
413.1
*• Dioxin and dioxin-like compounds = • CDDs + « CDFs
Source: EPRI (1994) - based on two cold side ESP-equipped power plants.
Calculation of emission factors assumes density of oil of 0.87 kg/L.
Section 4.4.4. Description/Emissions Factors for Wood-Fired Electric Utility Boilers
Congener-specific measurements of CDDs/CDFs in stack emissions from wood-fired electric
utility boilers were measured by the California Air Resources Board at four facilities in 1988 (CARB,
1990b; CARB, 1990e; CARB, 1990f; CARB, 1990g). In CARB (1990b), CDDs/CDFs were
measured in the emissions from a quad-cell wood-fired boiler used to generate electricity. The fuel
consisted of coarse wood waste and sawdust from non-industrial logging operations. The exhaust gas
passed through a multicyclone before entering the stack. In CARB (1990e), CDDs/CDFs were
measured in the emissions from two spreader stoker wood-fired boilers operated in parallel by an
electric utility for generating electricity. The exhaust gas stream from each boiler is passed through a
dedicated electrostatic precipitator (ESP) after which the gas streams are combined and emitted to the
atmosphere through a common stack. Stack tests were conducted both when the facility burned fuels
allowed by existing permits and when the facility burned a mixture of permitted fuel supplemented by
urban wood waste at a ratio of 70:30. In CARB (1990f), CDDs/CDFs were measured in the emissions
from a twin fluidized bed combustors designed to burn wood chips for the generation of electricity. The
APCD system consisted of ammonia injection for controlling nitrogen oxides, and a multiclone and
47
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electrostatic precipitator for controlling paniculate matter. During testing, the facility burned wood
wastes and agricultural wastes allowed by existing permits.
In CARB (1990g), CDDs/CDFs were measured in the emissions from a quad-cell wood-fired
boiler. During testing, the fuel consisted of wood chips and bark. The flue gases passed through a
multicy clone and an ESP before entering the stack. The mean of the emission factors derived from the
four CARB studies is used in Table 4-10 as most representative of industrial wood combustion.
Table 4-10. Average Emission Factors (ng/kg of wood combusted) for Estimating Air Releases
of Dioxin and Dioxin-like Compounds from Wood-Fired Electric Utility Boilers
CDD/CDF
Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3, 4,7, 8-HxCDF
1,2,3, 6,7, 8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
• CDDs
• CDFs
• Dioxin and dioxin-like
compounds*
Emission Factor
ng/kg wood
(drywt)
0.007
0.044
0.042
0.086
0.079
0.902
6.026
0.673
0.790
0.741
0.761
0.941
0.343
0.450
2.508
0.260
1.587
7.19
9.05
16.24
Emission Factor
ng/kg wood
(wet wt)
0.006
0.037
0.036
0.069
0.076
0.852
5.367
0.768
0.676
0.867
0.789
0.862
0.341
0.420
2.550
0.222
1.366
6.44
8.86
15.30
*• Dioxin and dioxin-like compounds = • CDDs + • CDFs
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Section 4.5. Hazardous Waste Combustion
Section 4.5.1. Applicability
This category applies to SIC Code 4953. In particular, this guidance is applicable to
commercial hazardous waste combustors (RCRA Permitted Facilities), and to boilers and industrial
furnaces (BIFs) burning hazardous waste. This also includes cement kilns burning hazardous waste as
supplemental fuel (SIC Code 3241), and Utilities (SIC Codes 4911, 4931, and 4939) that burn
hazardous waste as supplemental fuel in the boiler.
Section 4.5.2. Emissions Factors for Commercial Boilers and Industrial Furnaces Burning
Hazardous Waste (Other than Cement Kilns)
In 1991, EPA established rules that allow the combustion of some liquid hazardous waste in
industrial boilers and furnaces (Federal Register, 1991). These facilities typically burn oil or coal for the
primary purpose of generating electricity. Liquid hazardous waste can only be burned as supplemental
(auxiliary) fuel, and usage is limited by the rule to no more than 5 percent of the primary fuels. These
facilities typically use an atomizer to inject the waste as droplets into the combustion chamber and are
equipped with particulate and acid gas emission controls. In general, they are sophisticated, well
controlled facilities, that achieve good combustion. Congener-specific emission concentrations for two
tested boilers burning liquid hazardous waste as supplemental fuel are available (U.S. EPA, 1998). The
average congener specific emission factors are presented in Table 4-11. These emission factors reflect
testing at 2 of the 136 boilers/furnaces known to combust liquid hazardous waste as supplemental fuel.
These facilities reflect emissions of dioxin-like compounds in 1995.
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Table 4-11 Average Emission Factors (ng/kg waste feed) for Estimating Air Releases of
Dioxin and Dioxin-like Compounds from Boilers and Industrial Furnaces Burning Hazardous
Waste (other than cement kilns)
CDD Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
• CDD
• Dioxin and dioxin-like
compounds*
Emission Factor
(ng/kg waste feed)
0.00
0.04
0.08
0.18
0.20
1.17
5.24
6.91
12.2
CDF Congener
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
• CDF
Emission Factor
(ng/kg waste feed)
0.81
0.38
0.52
0.83
0.37
0.02
0.56
0.93
0.16
0.70
5.28
*• Dioxin and dioxin-like compounds = • CDDs + « CDFs
Section 4.5.3. Cement Kilns Burning Hazardous Waste as Supplemental Fuel
The high temperatures achieved in cement kilns make cement kilns an efficient technology for
combusting hazardous waste as supplemental fuel. Sustaining the relatively high combustion
temperatures (1,100* C to 1,500* C) that are needed to form cement clinker requires the burning of a
fuel with a high energy output. Therefore, coal or petroleum coke is typically used as the primary fuel
source. Because much of the cost of operating the cement kiln at high temperatures is associated with
the consumption of fossil fuels, some cement kiln operators have elected to burn hazardous liquid and
solid waste as supplemental fuel. Facilities that burn hazardous waste for energy recovery must comply
with both RCRA and CAA regulations that specifically regulate this practice. Currently about 75
percent of the primary fuel is coal. Organic hazardous waste may have a similar energy output as coal
(9,000 to 12,000 Btu/lb for coal). The strategy of combusting the waste as supplemental fuel is to off-
set the amount of coal/coke that is purchased and burned by the kiln. Much of the high energy and
ignitable wastes are primarily comprised of such diverse substances as waste oils, spent organic solvents,
sludges from the paint and coatings industry, waste paints and coatings from the auto and truck assembly
plants, and sludges from the petroleum refining industry (Greer et al., 1992). The conditions inherent in
the cement kiln mimic conditions of hazardous waste incineration. For example, the gas residence time
in the burning zone is typically three seconds while at temperatures in excess of 1,500* C (Greer et al.,
50
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1992). In addition, trial burns have consistently shown that 99.99 to 99.9999 percent destruction and
removal efficiencies for the very stable organic wastes can be achieved in cement kilns (Greer et al,
1992). Although the combustion of hazardous waste as supplemental or substitute fuel does have
apparent advantages, only 16 percent of the Portland cement kilns (34 of the 212 kilns) combusted
hazardous waste in 1995 (Federal Register, 1996b), as of 2000 only 15 plants (32 kilns) were burning
hazardous waste. Other types of supplemental fuel used by these facilities include automobile tires, used
motor oil, and sawdust, and scrap wood chips. The method of introducing liquid and solid hazardous
waste into the kiln is a key factor to the complete consumption of the waste during the combustion of the
primary fuel. Liquid hazardous waste is either injected separately or blended with the primary fuel
(coal). Solid waste is mixed and burned along with the primary fuel. The pyroprocessing of raw meal in
a cement kiln produces cement as fine particulates. At some facilities, cement kiln dust, which is an even
finer particulate, is collected and controlled with fabric filters and/or electrostatic precipitators. Acid
gases such as SO2 can be formed during pyroprocessing of the sulfur-laden minerals, but the minerals
have high alkalinity which neutralizes SO2 gases.
Emission factors (ng/kg clinker produced) for Portland cement kilns burning hazardous waste
as supplemental fuel are displayed in Table 4-12. These emission factors were developed from stack
testing of CDD/CDF emissions from eleven cement kilns burning hazardous waste. The majority of
stack emissions data from cement kilns burning hazardous waste were derived during trial burns, and
may overestimate the CDD/CDF emissions that most kilns achieve during normal operations.
The emission factors in Table 4-12 were derived from facilities that were stack tested in 1998
and may not reflect current regulatory requirements. In 1999, EPA promulgated final standards for the
stack emission limits of dioxin and dioxin-like compounds from hazardous waste combustion facilities
(64 FR 52828 - 53077; Final Standards for Hazardous Air Pollutants For Hazardous Waste
Combustors; Final Rule; September 30, 1999). The promulgated regulations require periodic stack
sampling for dioxin-like compounds for all cement kilns burning hazardous waste. The owner/operator
of such facilities is encouraged to use actual facility-specific emissions data (i.e., Approach 1) in lieu of
EPA's default emission factors. Such data are the most representative and best data to use in estimating
annual releases of dioxin-like compounds.
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Table 4-12. Average Emission Factors (ng per dscm) for Estimating Air Releases of Dioxin and Dioxin-Like Compounds from
cement Kilns Combusting Hazardous Waste as Supplemental Fuel
Facility
A
B
C
D
E
F
G
H
I
J
K
Mean emission factor
Facility
A
B
C
D
E
F
G
H
I
J
K
Mean emission factor
2378-
TCDD
0.096
0.028
0.005
0.310
0.005
0.007
0.053
0.026
0.067
0.035
0.016
0.059
2378-
TCDF
1.080
0.755
0.380
1.604
0.111
0.011
0.562
0.072
0.572
0.239
0.462
0.532
12378-
PeCDD
0.089
0.014
0.011
0.496
0.010
0.009
0.327
0.039
1.191
0.041
0.019
0.204
12378-PeDF
0.078
0.070
0.035
1.050
0.005
0.005
0.654
0.014
0.239
0.223
0.121
0.227
Dioxin and dioxin-like compounds:
123478-
HxCDD
0.144
0.009
0.014
0.709
0.010
0.006
0.536
0.054
1.385
0.048
0.022
0.267
23478-
PeCDF
0.183
0.093
0.067
2.353
0.012
0.010
1.790
0.054
0.570
0.226
0.133
0.499
7.06
123678-
HxCDD
0.258
0.008
0.016
1.381
0.012
0.012
0.832
0.078
1.875
0.047
0.023
0.413
123478-
HxCDF
0.098
0.034
0.039
2.024
0.008
0.011
1.366
0.022
0.450
0.182
0.078
0.392
123789-
HxCDD
0.206
0.010
0.559
1.893
0.006
0.013
0.812
0.048
2.697
0.044
0.018
0.573
123678-
HxCDF
0.043
0.019
0.017
1.029
0.004
0.005
0.533
0.015
0.208
0.103
0.031
0.182
1234678-
HPCDD
2.162
0.043
0.155
6.011
0.068
0.057
5.366
0.430
9.971
0.216
0.064
2.231
123789-
HxCDF
0.031
0.007
0.003
0.316
0.005
0.002
0.115
0.003
0.060
0.023
0.017
0.053
OCDD
0.461
0.459
3.325
0.784
0.033
0.201
1.752
0.140
1.542
0.091
0.154
0.813
234678- 1234678-
HxCDF HPCDF
0.065 0.051
0.025 0.006
0.027 0.026
1.441 0.946
0.006 0.009
0.006 0.010
1.168 0.609
0.011 0.009
0.344 0.208
0.085 0.185
0.032 0.050
0.292 0.192
1234789-
HpCDF
0.048
0.008
0.006
0.256
0.010
0.003
0.192
0.006
0.066
0.043
0.024
0.060
OCDF
0.116
0.029
0.021
0.141
0.039
0.008
0.119
0.008
0.060
0.095
0.106
0.067
per dry standard cubic meter of stack gas
52
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The emission factors in Table 4-12 are in units of nanogram dioxin-like compound per dry
standard cubic meter (at standard temperature and pressure and adjusted to 7% oxygen) of stack gas
flow. This unit is a concentration of dioxin-like compounds measured in the stack gases. The facilities
listed in Table 4-12 are cement kilns burning hazardous waste, and the emission factors (expressed on a
concentration basis) are the average of multiple "runs" at the same facility. A "run" is defined as a single
stack sampling episode to determine the amount of dioxin-like compounds present in the gases leaving
the stack. These data can be found in a database maintained by EPA's Office of Solid Waste as
documented in: Final Technical Support Document for Hazardous Waste Combustors (HWQ MACT
Standards: HWC Emissions Database. Volume IT; Appendix A: Cement Kilns: In: Final Standards for
Hazardous Air Pollutants For Hazardous Waste Combustors; Final Rule; September 30, 1999. This
cement kiln dioxin/furan database may be accessed on the Internet at the following URL:
http://www.epa.gov/epaoswer/hazwaste/comust/.
In order to estimate annual air emissions of dioxin-like compounds using the EPA default
emission factors, the owner/operator are advised to follow the calculation steps given in section 3.1.1.
Please note that the EPA default emission factors are generally applicable to all Portland cement kilns
burning hazardous waste regardless of primary fuel type; constituents of hazardous waste burned as
supplemental fuel; air pollution control equipment installed at the kiln; temperature of the kiln and
whether or not the kiln is a wet or dry process. However, the emissions of dioxin-like compounds in
Table 4-12 are more representative of cement kilns that operate the air pollution control equipment at
temperatures of 204° Celsius (400° F) or less. Such temperatures are known to suppress the post
combustion formation of dioxins and furans, and result in lower emissions of dioxin-like compounds than
if the temperatures were more elevated.
Section 4.5.4. Hazardous Waste Incineration (HWI) Facilities
The four principal furnace designs employed for the combustion of hazardous waste in the
United States are: liquid injection, rotary kiln, fixed hearth, and fluidized-bed incinerators (Dempsey and
Oppelt, 1993). The majority of commercial operations are of the rotary kiln incinerator type. On-site
(noncommercial) HWI technologies are an equal mix of rotary kiln and liquid injection facilities, with a
few additional fixed hearths and fluidized bed operations (U.S. EPA, 1996h). Each of these HWI
technologies is discussed below:
Rotary Kiln HWI: Rotary kiln incinerators consist of a rotating kiln, coupled with a high
temperature afterburner. Because these are excess air units designed to combust hazardous waste in
any physical form (i.e., liquid, semi-solid, or solid), rotary kilns are the most common type of hazardous
waste incinerator used by commercial "off-site" operators. The rotary kiln is a horizontal cylinder lined
with refractory material. Rotation of the cylinder on a slight slope provides for gravitational transport of
the hazardous waste through the kiln (Buonicore, 1992a). The tumbling action of the rotating kiln causes
mixing and exposure of the waste to the heat of combustion, thereby enhancing burnout. Solid and
semi-solid wastes are loaded into the top of the kiln by an auger or rotating screw. Fluid and pumpable
sludges and wastes are typically introduced into the kiln through a water-cooled tube. Liquid hazardous
waste is fed directly into the kiln through a burner nozzle. Auxiliary fuel (natural gas or oil) is burned in
53
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the kiln chamber at start-up to reach elevated temperatures. The typical heating value of hazardous
waste (i.e., 8,000 Btu/kg) is sufficient to sustain combustion without auxiliary fuel (U.S. EPA, 1996h).
The combustion gases emanating from the kiln are passed through a high temperature afterburner
chamber to more completely destroy organic pollutants entrained in the flue gases. Rotary kilns can be
designed to operate at temperatures as high as 2,580 °C, but more commonly operate at about 1,100
Liquid Injection HWI: Liquid injection incinerators (LIIs) are designed to burn liquid
hazardous waste. These wastes must be sufficiently fluid to pass through an atomizer for injection as
droplets into the combustion chamber. The LIIs consist of a refractory-lined steel cylinder mounted
either in a horizontal or vertical alignment. The combustion chamber is equipped with one or more
waste burners. Because of the rather large surface area of the atomized droplets of liquid hazardous
waste, the droplets quickly vaporize. The moisture evaporates, leaving a highly combustible mix of
waste fumes and combustion air (U.S. EPA, 1996h). Secondary air is added to the combustion
chamber to complete the oxidation of the fume/air mixture.
Fixed Hearth HWI: Fixed hearths, the third principal hazardous waste incineration
technology, are starved air or pyrolytic incinerators, which are two-stage combustion units. Waste is
ram-fed into the primary chamber and incinerated below stoichiometric requirements (i.e., at about 50 to
80 percent of stoichiometric air requirements). The resulting smoke and pyrolytic combustion products
are then passed though a secondary combustion chamber where relatively high temperatures are
maintained by the combustion of auxiliary fuel. Oxygen is introduced into the secondary chamber to
promote complete thermal oxidation of the organic molecules entrained in the gases.
Fluidized-bed HWI: The fourth hazardous waste incineration technology is the fluidized-bed
incinerator, which is similar in design to that used in municipal solid waste incineration. In this
configuration, a layer of sand is placed on the bottom of the combustion chamber. The bed is preheated
by underfire auxiliary fuel at startup. During combustion of auxiliary fuel at start-up, the hot gases are
channeled through the sand at relatively high velocity, and the turbulent mixing of combustion gases and
combustion air causes the sand to become suspended (Buonicore, 1992a). This takes on the
appearance of a fluid medium, hence the incinerator is termed a 'fluidized-bed' combustor The
incinerator is operated below the melting point temperature of the bed material. Typical temperatures of
the fluid medium are within the range of 650 to 940* C. A constraint on the types of waste burned is that
the solid waste particles must be capable of being suspended within the furnace. When the liquid or
solid waste is combusted in the fluid medium, the exothermic reaction causes heat to be released into the
upper portion of the combustion chamber. The upper portion is typically much larger in volume than the
lower portion, and temperatures can reach 1,000* C (Buonicore, 1992a). This high temperature is
sufficient to combust volatilized pollutants emanating from the combustion bed.
Most HWIs use APCDs to remove undesirable components from the flue gases that evolved
during the combustion of the hazardous waste. These unwanted pollutants include suspended ash
particles (particulate matter or PM), acid gases, metal, and organic pollutants. The APCD controls or
collects these pollutants and reduces their discharge from the incinerator stack to the atmosphere. Levels
54
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and kinds of these combustion byproducts are highly site-specific, depending on factors such as waste
composition and incinerator system design and operating parameters (e.g., temperature and exhaust gas
velocity). The APCD is typically comprised of a series of different devices that work together to clean
the exhaust combustion flue gas. Unit operations usually include exhaust gas cooling, followed by
particulate matter and acid gas control.
Exhaust gas cooling may be achieved using a waste heat boiler or heat exchanger, mixing with
cool ambient air, or injection of a water spray into the exhaust gas. A variety of different types of
APCDs are employed for the removal of particulate matter and acid gases. Such devices include: wet
scrubbers (such as venturi, packed bed, and ionizing systems), electrostatic precipitators, and fabric
filters (sometimes used in combination with dry acid gas scrubbing). In general, the control systems can
be grouped into the following three categories: wet, dry, and hybrid wet/dry systems. The controls for
acid gases (either dry or wet systems) cause temperatures to be reduced preceding the control device.
This impedes the extent of formation of CDDs and CDFs in the post-combustion area of the typical
HWI. It is not unusual for stack concentrations of CDD/CDFs at a particular HWI to be in the range of
1 to 100 ng CDD/CDF/dscm (Helble, 1993), which is low in comparison to other waste incineration
systems. The range of total CDD/CDF flue gas concentrations measured in the stack emissions of
HWIs during trial burns across the class of HWI facilities, however, has spanned four orders of
magnitude (ranging from 0.1 to 1,600 ng/dscm) (Helble, 1993). The APCD systems are described
below:
Wet Systems: A wet scrubber is used for both particulate and acid gas control. Typically, a
venturi scrubber and packed-bed scrubber are used in a back-to-back arrangement. Ionizing
wet scrubbers, wet electrostatic precipitators, and innovative venturi-type scrubbers may be
used for more efficient particulate control. Wet scrubbers generate a wet effluent liquid
wastestream (scrubber blowdown), are relatively inefficient at fine particulate control compared
to dry control techniques, and have equipment corrosion concerns. However, wet scrubbers
do provide efficient control of acid gases and have lower operating temperatures (compared
with dry systems), which may help control the emissions of volatile metals and organic
pollutants.
• Dry Systems: In dry systems, a fabric filter or electrostatic precipitator (ESP) is used for
particulate control. A fabric filter or ESP is frequently used in combination with dry scrubbing
for acid gas control. Dry scrubbing systems, in comparison with wet scrubbing systems, are
inefficient in controlling acid gases.
Hybrid Systems: In hybrid systems, a dry technique (ESP or fabric filter) is used for
particulate control, followed by a wet technique (wet scrubber) for acid gas control. Hybrid
systems have the advantages of both wet and dry systems (lower operating temperature for
capture of volatile metals, efficient collection of fine particulate, efficient capture of acid gases),
while avoiding many of the individual disadvantages. In some hybrid systems, known as "zero
discharge systems," the wet scrubber liquid is used in the dry scrubbing operation, thus
minimizing the amount of liquid byproduct waste.
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Uncontrolled HWIs: Facilities that do not use any air pollution control devices fall under a
separate and unique category. These are primarily liquid waste injection facilities, which burn
low ash and chlorine content wastes; therefore, they are low emitters of PM and acid gases.
For purposes of estimating emission factors, this document considers subdividing the combustors in each
source category into design classes judged to have similar potential for CDD/CDF emissions. As
explained below, it was decided not to subdivide dedicated HWIs.
Combustion research has identified three mechanisms involved in the emission of CDD/CDFs
from combustion systems: (1) CDD/CDFs can be introduced into the combustor with the feed and pass
through the system not completely burned/destroyed; (2) CDD/CDFs can be formed by chemical
reactions inside the combustion chamber; and (3) CDD/CDFs can be formed by chemical reactions
outside the combustion chamber. The total CDD/CDF emissions are likely to be the net result of all
three mechanisms; however, the relative importance of the mechanisms can vary among source
categories. In the case of HWIs, the third mechanism (i.e., post-combustion formation) is likely to
dominate, because HWIs are typically operated at high temperatures and long residence times, and most
have sophisticated real-time monitoring and controls to manage the combustion process. Therefore, any
CDD/CDFs present in the feed or formed during combustion are likely to be destroyed before exiting
the combustion chamber. Consequently, for purposes of generating emission factors, it was decided not
to subdivide this class on the basis of furnace type.
Emissions resulting from the post-combustion formation in HWIs can be minimized through a
variety of technologies:
• Rapid Flue Gas Quenching: The use of wet and dry scrubbing devices to remove acid gases
usually results in the rapid reduction of flue gas temperatures at the inlet to the PM APCD. If
temperature is reduced below 200°C, the low-temperature catalytic formation of CDD/CDFs
is substantially retarded.
• Use of Particulate Matter (PM) Air Pollution Control Devices: PM control devices can
effectively capture condensed and adsorbed CDD/CDFs that are associated with the entrained
paniculate matter (in particular, that which is adsorbed on unburned carbon containing
parti culates).
• Use of Activated Carbon: Activated carbon injection is used at some HWIs to collect (sorb)
CDD/CDFs from the flue gas. This may be achieved using carbon beds or by injecting carbon
and collecting it in a downstream PM APCD.
All of these approaches appear very effective in controlling dioxin emissions at dedicated HWIs, and
insufficient emissions data are available to generalize about any minor differences. Consequently, for
purposes of generating emission factors, it was decided not to subdivide this class on the basis of APCD
type.
56
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In 1999, EPA promulgated final standards for the stack emission limits of dioxin and dioxin-like
compounds from hazardous waste combustion facilities (64 FR 52828 - 53077; Final Standards for
Hazardous Air Pollutants For Hazardous Waste Combustors; Final Rule; September 30, 1999). Table
4-13 displays mean CDD/CDF emission factors for estimating air releases of dioxin and dioxin-like
compounds from hazardous waste combustion facilities. The promulgated regulations require periodic
stack sampling for dioxin-like compounds for all commercial hazardous waste combustion facilities. The
owner/operator of such facilities is encouraged to use actual facility-specific emissions data (i.e.,
Approach 1) in lieu of EPA's default emission factors. Such data are the most representative and best
data to use in estimating annual releases of dioxin-like compounds.
Table 4-13. Average Emission Factors (ng/kg waste feed) for Estimating Air Releases of
Dioxin and Dioxin-like Compounds from Hazardous Waste Combustion Facilities
CDD Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1, 2,3,4, 7,8-HxCDD
1, 2,3,6, 7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
• CDD
• Dioxin and dioxin-like
compounds*
Emission
Factor
(ng/kg waste
feed)
0.14
0.14
0.18
0.28
0.48
1.75
3.74
6.71
62.74
CDF Congener
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
• CDF
Emission
Factor
(ng/kg waste
feed)
2.69
2.33
2.51
9.71
3.95
0.29
2.70
16.68
1.71
13.46
56.03
*• Dioxin and dioxin-like compounds = • CDDs + « CDFs
57
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Abatement:
Air Emission
Air Pollutant
Air Pollution Control Device:
Ambient Measurement
Area Source
BACT-Best Available
Control Technology
Section 5.0 GLOSSARY
Reducing the degree or intensity of, or eliminating, pollution.
The release or discharge of a pollutant by an owner or operator
into the ambient air either by means of a stack or as a fugitive
dust, mist, or vapor as a result inherent to the manufacturing,
forming or combustion process.
Dust, fumes, smoke, and other paniculate matter, vapor, gas,
odorous substances, or any combination thereof. Also any air
pollution agent or combination of such agents, including any
physical, chemical, biological, radioactive substance or matter
which is emitted into or otherwise enters the ambient air.
Mechanism or equipment that cleans emissions generated by a
source (e.g., an incinerator, industrial smokestack, or an
automobile exhaust system) by removing pollutants that would
otherwise be released to the atmosphere.
A measurement of the concentration of a substance or pollutant
within the immediate environs of an organism; taken to relate it
to the amount of possible exposure.
Any source of air pollution that is released over a relatively small
area but which cannot be classified as a point source. Such
sources may include vehicles and other small engines, small
businesses and household activities, or biogenic sources such as
a forest that releases hydrocarbons
An emission limitation based on the maximum degree of emission
reduction (considering energy, environmental, and economic
impacts) achievable through application of production processes
and available methods, systems, and techniques. BACT does
not permit emissions in excess of those allowed under any
applicable Clean Air Act provisions. Use of the BACT concept
is allowable on a case by case basis for major new or modified
emissions sources in attainment areas and applies to each
regulated pollutant.
58
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Boiler
British Thermal Unit (Btu)
CAS Registration Number
Combustion
Concentration
Congener
Cubic Feet Per Minute (CFM)
Dioxin and Dioxin-like compounds:
Discharge
Design Capacity
Detection Limit
A vessel designed to transfer heat produced by combustion or
electric resistance to water. Boilers may provide hot water or
steam.
Unit of heat energy equal to the amount of heat required to raise
the temperature of one pound of water by one degree
Fahrenheit at sea level.
A number assigned by the Chemical Abstract Service to identify
a chemical.
1. Burning, or rapid oxidation, accompanied by release of
energy in the form of heat and light. 2. Refers to controlled
burning of waste, in which heat chemically alters organic
compounds, converting into stable inorganics such as carbon
dioxide and water.
The relative amount of a substance mixed with another
substance. An example is five ppm of carbon monoxide in air or
1 mg/1 of iron in water.
A discrete chemical compound within a group of compounds
having the same molecular weight and chemical/physical
properties.
A measure of the volume of a substance flowing through air
within a unit period of time.
CDDs and CDFs substituted with chlorine substitution in the
2,3,7, and 8-positions along the molecule. There are 7 CDDs
and 10 CDFs (for a total of 17 compounds) that meet this
definition.
The release of any waste stream or any constituent thereof, into
the environment.
The average daily flow that a treatment plant or other facility is
designed to accommodate.
The lowest concentration of a chemical that can reliably be
distinguished from a zero concentration.
59
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Destruction and
Removal Efficiency (DRE)
Effluent Guidelines
Effluent
Emission Factor
A percentage that represents the number of molecules of a
compound removed or destroyed in an incinerator relative to the
number of molecules entering the system (e.g., a DRE of 99.99
percent means that 9,999 molecules are destroyed for every
10,000 that enter; 99.99 percent is known as "four nines." For
some pollutants, the RCRA removal requirement may be as
stringent as "six nines."
Technical EPA documents which set effluent limitations for given
industries and pollutants.
Wastewater-treated or untreated-that flows out of a treatment
plant, sewer, or industrial outfall. Generally refers to wastes
discharged into surface waters.
The relationship between the amount of pollution produced and
released into the environment and the amount of raw material
processed, fuel consumed, or waste processed. For example, an
emission factor for a blast furnace making iron would be the
number of grams of dioxin-like compounds per ton of raw
materials.
Emission Inventory
Emission
Emission Standard
End-of-the-pipe
Electrostatic precipitator
Emission Rate
A listing, by source, of the amount of contaminant released into
the environment per year.
Pollution discharged into the atmosphere from smokestacks,
other vents, and surface areas of commercial or industrial
facilities; from residential chimneys; and from motor vehicle,
locomotive, or aircraft exhausts.
The maximum amount of air polluting discharge legally allowed
from a single source, mobile or stationary.
Technologies such as scrubbers on smokestacks and catalytic
converters on automobile tailpipes that reduce emissions of
pollutants after they have formed.
An air pollution control device that imparts an electric charge to
particles in a gas stream causing them to collect on an electrode.
The amount of a pollutant or contaminant emitted per unit of
time.
60
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Equivalent Method
Fabric Filter
Flow Rate
Any method of sampling and analyzing for the presence and
occurrence of a contaminant in an environmental sample which
has been demonstrated to the EPA Administrator's satisfaction
to be, under specific conditions, an acceptable alternative to
normally used reference methods.
Large fabric bag, usually made of glass fibers, used to eliminate
intermediate and large (greater than 20 PM in diameter)
particles. This device operates like the bag of an electric vacuum
cleaner, passing the air and smaller particles while entrapping the
larger ones.
The rate, expressed in gallons -or liters-per-hour, at which a
fluid escapes from a hole or fissure in a tank. Such
measurements are also made of liquid waste, effluent, and
surface water movement.
Flue Gas
Fossil Fuel:
Fugitive Emissions
Gas Chromatography/
Mass Spectrometer
Grab Sample
Hazardous Waste
Incineration
Industrial Process Waste
The products of combustion, including pollutants, emitted to the
air after a production process or combustion takes place
Fuel derived from ancient organic remains; e.g., peat, coal,
crude oil, and natural gas.
Emissions not caught by a capture system.
Instrument that identifies the molecular composition and
concentrations of various chemicals in water and soil samples.
A single sample collected at a particular time and place that
represents the composition of the water, air, or soil only at that
time and place.
Wastes that possess at least one of four characteristics
(ignitability, corrosivity, reactivity, or toxicity), or appears on
special EPA lists, as defined by RCRA Subtitle C.
An engineered process using controlled flame combustion to
thermally degrade waste materials.
Residues produced during manufacturing operations.
61
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Industrial Sludge
Semi-liquid residue or slurry remaining from treatment of
industrial water and wastewater.
Industrial Waste
Land Application
Maximum Available
Control Technology (MACT)
Maximum Contaminant Level
Unwanted materials from an industrial operation; may be liquid,
sludge, solid, or hazardous waste.
Discharge of wastewater, sludge or solid waste onto the surface
of the ground for treatment or reuse.
The emission standard for sources of air pollution requiring the
maximum reduction of hazardous emissions, taking cost and
feasibility into account. Under the Clean Air Act Amendments of
1990, the MACT must not be less than the average emission
level achieved by controls on the best performing 12 percent of
existing sources, by category of industrial and utility sources.
The maximum permissible level of a contaminant in water
delivered to any user of a public system. MCLs are enforceable
standards.
Media
Method Detection Limit (MDL)
Million-Gallons Per Day (MOD)
Molecule
Monitoring
Specific environments-air, water, soil-which are the subject of
regulatory concern and activities.
See limit of detection.
A measure of water flow.
The smallest division of a compound that still retains or exhibits
all the properties of the substance.
The direct measurement of the amount or concentration of a
contaminant in an environmental medium.
National Emissions Standards
for Hazardous
Air Pollutants (NESHAPS)
Emissions standards set by EPA for an air pollutant not covered
by NAAQS that may cause an increase in fatalities or in serious,
irreversible, or incapacitating illness. Primary standards are
designed to protect human health, secondary standards to
protect public welfare (e.g., building facades, visibility, crops,
and domestic animals).
62
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National Pollutant Discharge
Elimination System (NPDES):
Outfall
Particulates
Performance Standards
Physical and Chemical Treatment
A provision of the Clean Water Act which prohibits discharge of
pollutants into waters of the United States unless a special permit
is issued by EPA, a state, or, where delegated, a tribal
government on an Indian reservation.
The place where effluent is discharged into receiving waters.
1. Fine liquid or solid particles such as dust, smoke, mist, fumes,
or smog, found in air or emissions. 2. Very small solids
suspended in water; they can vary in size, shape, density and
electrical charge and can be gathered together by coagulation
and flocculation.
1. Regulatory requirements limiting the concentrations of
designated organic compounds, particulate matter, and hydrogen
chloride in emissions from incinerators. 2. Operating standards
established by EPA for various permitted pollution control
systems, asbestos inspections, and various program operations
and maintenance requirements.
Processes generally used in large-scale wastewater treatment
facilities. Physical processes may include air-stripping or
filtration. Chemical treatment includes coagulation, chlorination,
or ozonation. The term can also refer to treatment of toxic
materials in surface and ground waters, oil spills, and some
methods of dealing with hazardous materials on or in the ground.
Quality Assurance/Quality Control
Receiving Waters
Representative Sample
Sampling Frequency
A system of procedures, checks, audits, and corrective actions
to ensure that all EPA research design and performance,
environmental monitoring and sampling, and other technical and
reporting activities are of the highest achievable quality.
A river, lake, ocean, stream or other watercourse into which
wastewater or treated effluent is discharged.
A portion of material, medium or water that is as nearly identical
in content and consistency as possible to that in the larger body
of material, medium or water being sampled.
The interval between the collection of successive samples.
63
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Scrap
Scrubber
Site
Materials discarded from manufacturing operations that may be
suitable for reprocessing.
An air pollution device that uses a spray of water or reactant or
a dry process to trap pollutants in emissions.
An area or place within the jurisdiction of the EPA and/or a
state.
Sludge
Smelter
Source
Source Characterization
Any solid, semisolid or liquid waste generated from a municipal,
commercial, or industrial wastewater treatment plant, water
supply treatment plant, or air pollution control facility, or any
other such waste having similar characteristics.
A facility that melts or fuses ore, often with an accompanying
chemical change, to separate its metal content. Emissions cause
pollution. "Smelting" is the process involved.
Any building, structure, facility or installation from which there is
or may be the discharge of pollutants into the environment.
Measurements made to estimate the rate of release of pollutants
into the environment from a source such as an incinerator,
landfill, etc.
Solid Waste
Non-liquid, non-soluble materials ranging from municipal
garbage to industrial wastes that contain complex and sometimes
hazardous substances. Solid wastes also include sewage sludge,
agricultural refuse, demolition wastes, and mining residues.
Technically, solid waste also refers to liquids and gases in
containers.
Stack
Standards
Any chimney, flue, vent, roof monitor, conduit or duct arranged
to discharge emissions to the air.
Norms that impose limits on the amount of pollutants or
emissions produced. EPA establishes minimum standards, but
states are allowed to be stricter.
Surface Water
All water naturally open to the atmosphere (rivers, lakes,
reservoirs, ponds, streams, impoundments, seas, estuaries, etc.)
64
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Technology-Based Limitations
Technology-Based Standards
Treatment Plant
Trial Burn
Utility Boiler
Industry-specific effluent limitations based on best available
preventive technology applied to a discharge when it will not
cause a violation of water quality standards at low stream flows.
Usually applied to discharges into large rivers.
Industry-specific effluent limitations applicable to direct and
indirect sources which are developed on a category-by-category
basis using statutory factors, not including water-quality effects.
A structure built to treat wastewater before discharging it into
the environment. Treatment, Storage, and Disposal Facility: Site
where a hazardous substance is treated, stored, or disposed of.
TSD facilities are regulated by EPA and states under RCRA.
An incinerator test in which emissions are monitored for the
presence of specific organic compounds, particulates, and
hydrogen chloride. Trichloroethylene (TCE): A stable, low
boiling-point colorless liquid, toxic if inhaled. Used as a solvent
or metal degreasing agent, and in other industrial applications.
Coal, oil or natural gas fired boiler used to exchange heat of
combustion to steam to operate an electric generator for the
expressed purpose of producing electricity. Alternative term is
Power Plant.
Venturi Scrubbers
Air pollution control devices that use water to remove particulate
matter from emissions
Waste Feed
Waste Generation
Waste Stream
Waste Treatment Plant
The continuous or intermittent flow of wastes into an incinerator.
The weight or volume of materials and products that enter the
waste stream before recycling, composting, landfilling, or
combustion takes place. Also can represent the amount of waste
generated by a given source or category of sources
The total flow of solid waste from homes, businesses,
institutions, and manufacturing plants that is recycled, burned, or
disposed of in landfills, or segments thereof such as the
"residential waste stream" or the "recyclable waste stream."
A facility containing a series of tanks, screens, filters and other
processes by which pollutants are removed.
65
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Waste Treatment Stream
Wastewater
Water Quality Criteria
Water Quality Standards
Water Quality-Based Limitations
Water Quality-Based Permit
The continuous movement of waste from generator to treater
and disposer.
The spent or used water from a home, community, farm, or
industry that contains dissolved or suspended matter. Water
Pollution: The presence in water of enough harmful or
objectionable material to damage the water's quality.
Levels of water quality expected to render a body of water
suitable for its designated use. Criteria are based on specific
levels of pollutants that would make the water harmful if used for
drinking, swimming, farming, fish production, or industrial
processes.
State-adopted and EPA-approved ambient standards for water
bodies. The standards prescribe the use of the water body and
establish the water quality criteria that must be met to protect
designated uses.
Effluent limitations applied to dischargers when mere
technology-based limitations would cause violations of water
quality standards. Usually applied to discharges into small
streams.
A permit with an effluent limit more stringent than one based on
technology performance. Such limits may be necessary to
protect the designated use of receiving waters (e.g., recreation,
irrigation, industry or water supply).
66
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Section 6.0 CONVERSION FACTORS
Abbreviation
From
Multiply by
To
Abbreviation
Length (English to Metric)
in
ft
ft
yd
mi
inch
feet
feet
yard
mile
2.5
30.5
0.3048
0.914
1.609
centimeters
centimeters
meters
meters
kilometer
cm
cm
m
m
km
Length (Metric to English)
cm
m
m
m
km
centimeter
meter
meter
meter
kilometer
0.394
3.281
1.093
39.37
0.6214
inch
feet
yard
inches
mile
in
ft
yd
in
mi
Length (English to English)
ft
ft
ft
in
in
mi
mi
feet
feet
feet
inches
inches
miles
miles
12
0.333
0.000189
0.083
0.028
5,280
1,760
inches
yards
miles
feet
yards
feet
yards
in
yd
mi
ft
yd
ft
yd
Area (English to English)
ac
ac
ac
ft2
ft2
ft2
acre
acre
acre
square feet
square feet
square feet
43,560
4,840
0.0016
0.000023
144
0.111
square feet
square yards
square miles
acres
square inches
square yards
ft2
yd2
mi2
ac
in2
yd2
67
-------
Abbreviation
in2
mi2
From
square inches
square miles
Multiply by
0.007
640
To
square feet
acres
Abbreviation
ft2
ac
Area (English to Metric)
in2
ft2
yd2
mi2
mi2
ac
ac
ac
square inch
square foot
square yard
square mile
square mile
acre
acre
acre
6.5
0.0929
0.836
2.59
259
4,047
0.405
0.004
square centimeter
square meters
square meters
square kilometer
hectares
square meters
hectares
square kilometer
cm2
m2
m2
km2
ha
m2
ha
km2
Area (Metric to English)
cm2
m2
m2
km2
m2
ha
ha
ha
square centimeter
square meter
square meter
square kilometer
square meter
hectares
hectares
hectares
0.16
10.76
1.2
0.386
0.0002471
2.5
107,639
0.004
square inch
square feet
square yard
square mile
acre
acre
square feet
square miles
in2
ft2
yd2
mi2
ac
ac
ft2
mi2
Volume (English to Metric)
Pt
gal
ft3
ft3
yd3
cfsorfWs
cfsorfWs
pint
gallon
cubic feet
cubic feet
cubic yard
cubic feet per second
cubic feet per second
0.47
3.8
0.0283
28.317
0.765
0.0283
0.646
liter
liter
cubic meter
liters
cubic meter
cubic meter/second
million gallons per day
L
L
m3
L
m3
m3/s
Mgal/d
68
-------
Abbreviation
Mgal/d
Mgal/d
bb
From
million gallons per day
million gallons per day
barrels , US Petro leum
Multiply by
0.0438
1.547
159
To
cubic meter/second
cubic feet per second
liters
Abbreviation
m3/s
cfs or ft3/s
L
Volume (Metric to English)
mL
L
L
L
mL
m3
m3
m3/s
m3/s
milliliters
liter
liter
liter
milliliter
cubic meter
cubic meter
cubic meter per
second
cubic meter per
second
0.034
2.1
1.06
0.264
0.034
35.31
1.31
35.31
22.821
fluid ounces
pint
quart
gallon
ounces
cubic feet
cubic yard
cubic feet per second
milliongallonsperday
floz
Pt
qt
gal
oz
ft3
yd3
cfs or ft3/s
Mgal/d
Volume (English to English)
bb
bu
ft3
ft3
gal
gal
gal
gal
oz
barrels, petroleum
bushels
cubic feet
cubic feet
gallons
gallons
gallons
gallons
once
42
1.244
1,728
0.037
0.134
128
8
4
0.001
gallons
cubic feet
cubic inches
cubic yards
cubic feet
ounces
pints
quarts
cubic feet
gal
ft3
in3
yd3
ft3
oz
Pt
qt
ft3
Weight (English to English)
oz
oz
Ib
ounces
ounces
pounds
0.0625
437.5
16
pounds
grains
ounces
lb
gr
oz
69
-------
Abbreviation
t
t
From
tons, long
tons, long
Multiply by
2,240
1.12
To
pounds
tons, short
Weight (English to Metric)
oz
oz
Ib
Ib
t
t
t
ounces
ounces
pounds
pounds
tons, short
tons, short
tons, long
28.35
0.028
453.59
0.454
0.907
907
1.016
grams
kilogram
grams
kilograms
metric tons
kilograms
metric tons
Abbreviation
Ib
t
t
g
kg
g
kg
mt
kg
mt
Weight (Metric to English)
g
g
g
kg
kg
kg
mt
mt
mt
grams
grams
grams
kilograms
kilograms
kilograms
metric tons
metric tons
metric tons
0.002
15.43
0.035
2.205
0.0011
0.001
0.984
1.102
2,204.6
pounds
grains
ounces
pounds
tons, short
tons, long
tons, long
tons, short
pounds
Ib
gr
oz
Ib
t
t
t
t
Ib
Temperature
°F
°C
degrees Fahrenheit
degrees Celsius
5/9 * (°F-32)
9/5 * (°C +32)
degrees Celsius
degrees Fahrenheit
°C
°F
Concentration
mg/L
ppm
milligrams per liter
parts per million
1
1
parts per million
milligrams per liter
ppm
mg/L
70
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Section 7.0 REFERENCES
AGES. Applied Geotechnical and Environmental Service Corp. (1992) Source sampling report -
comprehensive emissions testing; blast furnace, May/June 1992, Franklin Smelting & Refining Corp.
Valley Forge, PA: AGES. Report No. 42614.01-01.
Advanced Technology Systems, Inc. (1995) Report on measurement of hazardous air pollutants from
aluminum melt furnace operations at Ravenswood Aluminum Corporation. Monroeville, PA: Advanced
Technology Systems, Inc.
Buekens, A.; Stieglitz, L.; Huang, H.; Dinova, C.; Cornells, E. (1997) Preliminary investigation of
formation mechanism of chlorinated dioxins and furans in industrial and metallurgical processes.
Organohalogen Compounds 31:516-520.
Buonicore, AJ. (1992) Control of gaseous pollutants. In: Buoni core, A. J., Davis, W.T., eds., Air
pollution engineering manual. Air and Waste Management Association. New York, NY: Van Nostrand
Reinhold.
CARB (California Air Resources Board) (1990a) Evaluation on a woodwaste fired incinerator at
Koppers Company, Oroville,California. Test Report No. C-88-065. Engineering Evaluation Branch,
Monitoring and Laboratory Division. May 29, 1990.
CARB (California Air Resources Board) (1990c) Evaluation test on twin fluidized bed wood waste
fueled combustors located in Cental California. Test Report No. C-87-042. Engineering Evaluation
Branch, Monitoring and Laboratory Division. February 7, 1990.
CARB (California Air Resources Board) (1990d) Evaluation test on a wood waste fired incinerator at
Louisiana Pacific Hardboard Plant, Oroville, CA. Test Report No. C-88-066. Engineering Evaluation
Branch, Monitoring and Laboratory Division. [As reported in NCASI, 1995.]
CARB (California Air Resources Board) (1990b) Evaluation test on a wood waste fired incinerator at
Pacific Oroville Power Inc. Test Report No. C-88-050. Engineering Evaluation Branch, Monitoring
and Laboratory Division. May 29, 1990.
Commonwealth Aluminum Corp (1995). Item 1 l-D-64 in USEPA Secondary Aluminum MACT Air
Docket Number A-92-61; Letter and attachment, S. Bruntz, Commonwealth Aluminum Corp., July 5,
1995, enclosing test report and discussion of test report results. Test Report: "MACT Emission Testing
of the "B" Rotary Kiln at Commonwealth Aluminum Corp, Lewisport, KY."
71
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Dempsey, C.R.; Oppelt, E.T. (1993) Incineration of hazardous waste: A critical review update. Air&
Waste 43: 25-73.
Edelstein, D.L. (1999) Personal communication between D. Edelstein (U.S. Geological Survey) and G.
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