&EPA
United States
Environmental Protection
Agency
EPA/600/R-16/353 I November 2016
www.epa.gov/homeland-security-research

Managing Debris after a Natural
Disaster: Evaluation of the Combustion
of Storm-Generated Vegetative and
C&D Debris in an Air Curtain Burner:
Source Emissions Measurement
Results
Office of Research and Development
Homeland Security Research Program

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EPA/600/R-16/353
November 2016
Managing Debris after a Natural Disaster: Evaluation
of the Combustion of Storm-Generated Vegetative and
C&D Debris in an Air Curtain Burner: Source
Emissions Measurement Results
November 17, 2016

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
Abstract
In an effort to expand available options to better manage natural disaster debris in the future, EPA evaluated
the combustion of both vegetative debris and construction and demolition (C&D) debris in air curtain burners
(ACBs). ACBs can be mobilized to where they're needed as a potential means of reducing the waste volume
while minimizing potentially harmful environmental impacts. These tests were conducted in June 2008 by
EPA/ORD at the Old Paris Road Landfill in St. Bernard Parish, Louisiana.
Testing was comprised of triplicate tests for each of two main test conditions:
•	Evaluation of emissions while burning vegetative debris; and
•	Evaluation of emissions from burning a mixture of C&D debris (which did not contain asbestos in
sufficient quantities to be categorized as Regulated Asbestos Containing Materials (RACM)) and
vegetative debris (used as supplemental fuel to maintain operating temperatures).
The analytes measured in these tests included:
•	Asbestos
•	Fine PM (less than 2.5 jjm)
•	Acid gases (HF, HCI, HBr, Cl2, Br2)
•	Toxic metals (Hg, Pb, As, Cr, Cd, Ni, etc.)
•	Polychlorinated dibenzo-p-dioxins and furans (PCDD/PCDF)
•	Co-planar polychlorinated biphenyls (PCBs)
•	Polycyclic aromatic hydrocarbons (PAHs)
•	Semivolatile organic compounds (SVOCs)
•	Volatile organic compounds (VOCs)
•	Visible emissions (opacity).
Analysis of the data suggests that for some of the pollutants (e.g., PM, NOx), there is little observable
difference between ACB operation on vegetative debris or on C&D debris. Emissions from other pollutants
(e.g., CO, SO2, HCI, VOCs) were somewhat higher from combustion of C&D debris than from combustion
of vegetative debris. Emissions of some pollutants (e.g., dioxins and furans) were significantly higher from
burning C&D debris than from burning vegetative debris.
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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
Disclaimer
U.S. Environmental Protection Agency (EPA), through its Office of Research and Development, performed
the work described in this report. Technical support was provided by Research Triangle Institute (RTI) under
Contract EP-C-05-060 with ARCADIS as a subcontractor. This document has been subjected to the
Agency's review and has been approved for publication. Note that approval does not signify that the
contents necessarily reflect the views of the Agency. EPA does not endorse the purchase or sale of any
commercial products or services.

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
Table of Contents
Abstract	i
Disclaimer	ii
List of Appendices	vi
List of Figures	vii
List of Tables	ix
Acronyms and Abbreviations	xi
Acknowledgments	xiii
Executive Summary	xiv
1.	Introduction	1
1.1	Objective/Purpose and Intended Use of Project Results	1
1.2	Scope of Project	2
1.3	ACB Technology	2
1.4	Application of ACB Technology to Demolition Debris	4
2.	Air Curtain Burner Test Descriptions	6
2.1 Characteristics of Field Test Site	6
3.	Test Operations	8
3.1	Sample Locations	8
3.2	Target Analytes	8
3.2.1	Feed Debris	8
3.2.2	ACB Ash	8
3.2.3	ACB Combustion Gases	9
3.3	Sampling and Analysis Methods	9
3.3.1	Feed Debris Sampling Analysis Methods	9
3.3.2	ACB Combustion Gases Sampling and Analysis Methods	10
3.3.2.1	Continuous Emissions Monitors	10
3.3.2.1.1	CO2/O2 (EPA Method 3A)	11
3.3.2.1.2	SO2 (EPA Method 6C)	12
3.3.2.1.3	NOx (EPA Method 7E)	12
3.3.2.1.4	CO (EPA Method 10)	12
3.3.2.1.5	THC (EPA Method 25A)	12
3.3.2.2	Temperature	13

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
3.3.2.3	Flue Gas Volumetric Flow Rate (EPA Methods 1A and 2C)	13
3.3.2.4	Stack Gas Molecular Weight and Stack Moisture (EPA Methods 3A and 4)	13
3.3.2.5	Filterable Particulate and Acid Gases	14
3.3.2.6	Asbestos	14
3.3.2.7	Metals	15
3.3.2.8	VOCs	15
3.3.2.9	Dioxins/Furans	15
3.3.2.10	SVOCs	16
3.3.2.11	Particle Size Determination	16
3.3.2.12	PM2 5 Particulate	16
3.3.2.13	Visible Emissions	16
3.4	Estimation of ACB Emissions	17
3.4.1	Estimation of Qtotai using a Carbon Balance	17
3.4.2	Estimation of Mass Emitted per Unit Mass Feed	19
3.5	Quality Assurance Considerations	19
4. Test Results	22
4.1 ACB Feed Material and Operational Overview	22
4.1.1	Daily Account	22
4.1.1.1	June 20-22, 2008	22
4.1.1.2	June 24, 2008 (First day of ACB testing, Vegetative Runs (Veg Run) 1 and (Veg
Run) 2)	22
4.1.1.3	June 25, 2008, Morning (Veg Run 3)	23
4.1.1.4	June 25, 2008, Afternoon (1st C&D Run 1, House 1)	23
4.1.1.5	June 26, 2008 Morning (C&D Run 2; House 1)	23
4.1.1.6	June 26, 2008 Afternoon (C&D Run 3; House 2)	24
4.1.2	Overall Mass Balance for Vegetative Material	25
4.1.2.1 Ash Production	27
4.1.3	Debris Weighing Procedure	28
4.1.4	Other Process Operation Notes	29
4.1.4.1	June 24, 2008 	29
4.1.4.2	June 25, 2008 	29
4.1.4.3	June 26, 2008 	30
4.1.5	Combustion Air Fan Speed and ACB Exhaust Airflow	30
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4.2	Test Periods	31
4.3	CEMs	35
4.4	ACB Temperatures	39
4.4.1	Time-Resolved Wall Temperatures	39
4.4.2	Average Wall Temperatures	42
4.4.3	Sampling Scoop Temperature	45
4.4.4	ACB Bed Temperatures	47
4.5	ACB Performance Test Sampling Results	52
4.5.1	ACB Ash Characteristics	52
4.5.2	ACB Combustion Gas Test Results	52
4.5.2.1	Dioxin/Furan and PCB Test Results	52
4.5.2.2	Metal Test Results	60
4.5.2.3	PAH Test Results	60
4.5.2.4	M5 Particulate and Acid Gas Test Results	60
4.5.2.5	SVOC Test Results	60
4.5.2.6	VOC Test Results	61
4.5.2.7	Tentatively Identified Compounds (TICs)	75
4.5.2.8	Brominated Organic Compounds	80
4.5.2.9	Particle Sizing Test Results	80
4.5.2.10	Visible Emissions during Vegetative Debris Burning	80
4.5.2.11	Filterable and Condensable Particulate Matter Test Results	82
4.5.2.12	Results of Microscopy Analysis of Air Samples and Ash	88
4.5.2.12.1	Airborne Asbestos Samples	88
4.5.2.12.2	Ash Samples	89
5. Discussion of Results	90
5.1	Fixed Combustion Gases	91
5.2	Dioxins and PCBs	94
5.3	Metals	94
5.4	Particulate Matter and Acid Gases	94
5.5	Semivolatile Organic Compounds (SVOCs)	94
5.6	Volatile Organic Compounds (VOCs)	95
5.7	Asbestos	95
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5.8	Analysis of Variance between Vegetative Debris and C&D Debris Emission Factors	103
5.8.1	Metals	104
5.8.2	PAHs	104
5.8.3	Particulate and Acid Gases	104
5.8.4	SVOCs	106
5.8.5	Dioxins, Furans, and PCBs	108
5.8.6	VOCs	108
5.8.7	Fixed Combustion Gases	109
5.9	Comparison Between ACB Technology and Other Combustion Sources	109
6.	Data Quality Assessment	113
6.1	CEMs	114
6.2	VOCs/TO-15	115
6.3	Acid Gases (HCI, HF, HBr, Ch and Br2) by EPA Method 26/26A	115
6.4	Filterable and Condensable Particulate by EPA Method 5/201 A/202 and Particle Sizing	115
6.5	Multi-Metals by EPA Method 29	117
6.6	SVOCs-EPA Method 0010/Method 8270	118
6.7	PCDD/PCDF (Method 23)	118
6.8	PCBs and PAHs	119
6.9	Ash TCLP Analysis	120
6.10	Asbestos Analysis	121
6.10.1	Airborne Asbestos QA Samples	121
6.10.2	Ash QA Samples	122
6.11	Audits	122
7.	Summary	125
8.	References	127
List of Appendices
Appendix A: CEM Data
Appendix B: Field Data
Appendix C: Analytical Results
Appendix D: Supporting Documents
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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
List of Figures
Figure 1-1. Photograph of an Air Burners LLC Air Curtain Burner Unit	3
Figure 1-2. ACB with Extended Skirt	4
Figure 2-1. Aerial Photo of Test Site	6
Figure 2-2. Near-isokinetic Scoop and Sample Extraction System	7
Figure 4-1. Removal of Ash from the ACB the Morning Following a Day of Testing	28
Figure 4-2. Axle scale	28
Figure 4-3. Loaded Front Axle Being Weighed	29
Figure 4-4. Veg Run 1 Activity Timeline	32
Figure 4-5. Veg Run 2 Activity Timeline	32
Figure 4-6. Veg Run 3 Activity Timeline	33
Figure 4-7. C&D Run 1 Activity Timeline	33
Figure 4-8. C&D Run 2 Activity Timeline	34
Figure 4-9. C&D Run 3 Activity Timeline	34
Figure 4-10. NOx Concentrations Corrected to 12 Percent CO2	36
Figure 4-11. CO Concentrations Corrected to 12 Percent CO2	37
Figure 4-12. SO2 Concentrations Corrected to 12 Percent CO2	37
Figure 4-13. THC Concentration Corrected to 12 Percent CO2	38
Figure 4-14. Location of Thermocouple Probes on ACB Walls	39
Figure 4-15. Wall Temperatures from Veg Run 1	40
Figure 4-16. Wall Temperatures from Veg Run 2	40
Figure 4-17. Wall Temperatures from Veg Run 3	41
Figure 4-18. Wall Temperatures from C&D Run 1 	41
Figure 4-19. Wall Temperatures from C&D Run 2	42
Figure 4-20. Average Wall Temperatures from Veg Run 1	42
Figure 4-21. Average Wall Temperatures from Veg Run 2	43
Figure 4-22. Average Wall Temperatures from Veg Run 3	43
Figure 4-23. Average Wall Temperatures from C&D Run 1	44
Figure 4-24. Average Wall Temperatures from C&D Run 2	44
Figure 4-25. Sampling Scoop Inlet Temperature from Veg Run 1	45
Figure 4-26. Sampling Scoop Inlet Temperature from Veg Run 2	46
Figure 4-27. Sampling Scoop Inlet Temperature from C&D Run 2	46
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Figure 4-28.	ACB Bed Temperature Taken during the Morning of June 24, 2008 (Veg Run 1)	47
Figure 4-29.	ACB Bed Temperature Taken during the Morning of June 24, 2008 (Veg Run 1)	48
Figure 4-30.	ACB Bed Temperature Taken during the Afternoon of June 24, 2008 (Veg Run 2)	48
Figure 4-31.	ACB Bed Temperature Taken during the Afternoon of June 24, 2008 (Veg Run 2)	49
Figure 4-32.	ACB Bed Temperature Taken during the Morning of June 25, 2008 (Veg Run 3)	49
Figure 4-33.	ACB Bed Temperature Taken during the Morning of June 26, 2008 (C&D Run 2)	50
Figure 4-34.	ACB Bed Temperature Taken during the Afternoon of June 26, 2008 (C&D Run 3)	50
Figure 4-35.	ACB Bed Temperature Taken during the Afternoon of June 26, 2008 (C&D Run 3)	51
Figure 4-36.	Andersen 1 - 24 June 2008, Vegetative Run 2	82
Figure 4-37.	Andersen 2 - 25 June 2008, Vegetative Run 3	83
Figure 4-38.	Andersen 3 - 25 June 2008, C&D Run 1	84
Figure 4-39.	Andersen 4 - 25 June 2008, C&D Run 2	85
Figure 4-40.	Andersen 5 - 25 June 2008, C&D Run 3	86
Figure 5-1. Emission Factors for Fixed Combustion Gases: Vegetative Debris vs. C&D Debris
(Error bars represent the range of data)	92
Figure 5-2. Emission Factors for PCDDs/Fs and PCBs: Vegetative Debris vs. C&D Debris (Error
bars represent the range of data)	93
Figure 5-3. Emission Factors for Airborne Metals: Vegetative Debris vs. C&D Debris (Error bars
represent the range of data)	96
Figure 5-4. Emission Factors for Particulate Matter: Vegetative Debris vs. C&D Debris (Error
bars represent the range of data)	97
Figure 5-5. Emission Factors for Particulate Matter and Acid Gases: Vegetative Debris vs. C&D
Debris (Error bars represent the range of data)	98
Figure 5.6. Comparison of CO Emission Factors Among Several Combustion Sources	111
Figure 5.7. Comparison of PM Emission Factors Among Several Combustion Sources	111
Figure 5.8. Comparison of PCDD/F Emission Factors Among Several Combustion Sources	112

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List of Tables
Table 3-1. Equipment used during the ACB Testing	11
Table 3-2. Estimation of Total Flow Rate	19
Table 4-1. Inner Perimeter Material Balance for Vegetative (Wood) Material in Tons	25
Table 4-2. Revised Inner Perimeter Material Balance for Vegetative (Wood) Material in Tons	26
Table 4-3. Inner Perimeter Material Balance for House 1 C&D Debris Material in Tons	26
Table 4-4.	Revised Inner Perimeter Material Balance for House 1 C&D Debris Material in Tons
	26
Table 4-5. Summary of Feed Rates (tons/hour) for Each Test Run	26
Table 4-6. Burner Fan Speed Readings and Notes on Fan Operation	31
Table 4-7. Run Start and Stop Times	31
Table 4-8. Raw CEM Concentrations for Air Curtain Burner Tests	35
Table 4-9. CEM Concentrations Corrected to 12 Percent CO2	36
Table 4-10. Ash and Vegetative Debris Composition	53
Table 4-11. Metals TCLP Results	53
Table 4-12. Dioxin, Furan, and PCB Test Results, Uncorrected (dry basis)	54
Table 4-13. Dioxin, Furan, and PCB Test Results, Corrected to 12% CO2 (dry basis)	57
Table 4-14. Metal Test Results, Uncorrected (dry basis)	62
Table 4-15. Metal Test Results, Corrected to 12% CO2 (dry basis)	62
Table 4-16. PAH Test Results, Uncorrected (dry basis)	63
Table 4-17. PAH Test Results, Corrected to 12% CO2 (dry basis)	64
Table 4-18. M5 Particulate and Acid Gas Test Results, Uncorrected (dry basis)	65
Table 4-19. M5 Particulate and Acid Gas Test Results, Corrected to 12% CO2 (dry basis)	65
Table 4-20. SVOC Test Results, Uncorrected (dry basis)	66
Table 4-21. SVOC Test Results, Corrected to 12% CO2 (dry basis)	69
Table 4-22. VOC Test Results, Uncorrected (dry basis)	72
Table 4-23. VOC Test Results, Corrected to 12% CO2 (dry basis)	74
Table 4-24. Tentatively Identified Compounds, Uncorrected (dry basis)	76
Table 4-25. Tentatively Identified Compounds, Corrected to 12% CO2 (dry basis)	78
Table 4-26. Brominated Compounds, Uncorrected (Dry Basis)	81
Table 4-27. Visible Emissions (% Opacity)	87
Table 4-28.	Filterable and Condensable Particulate Test Results for All Vegetative and C&D
Debris Burns	87
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Table 4-29. Analytical Results of TEM Asbestos Analysis of Air Samples	88
Table 4-30. Analytical Results PLM and TEM Analysis of Ash Samples	89
Table 5-1. Emission Rates and Estimated Emission Factors for CO, NOx, SO2, and THC	92
Table 5-2. Emission Rates and Estimated Emission Factors for PCDDs/Fs and PCBs	93
Table 5-3. Emission Rates and Estimated Emission Factors for Airborne Metals	95
Table 5-4. Emission Rates and Estimated Emission Factors of Particulate Matter	97
Table 5-5.	Emission Rates and Estimated Emission Factors of Filterable Particulate Matter and
Acid Gases	98
Table 5-6. Emission Rates and Estimated Emission Factors for SVOCs	99
Table 5-7. Emission Rates and Estimated Emission Factors for PAHs	101
Table 5-8. Emission Rates and Estimated Emission Factors for VOCs	102
Table 5-9. Emission Rates and Estimated Emission Factors for Asbestos	103
Table 5.10. Results from Analysis of Metals Emission Factors	105
Table 5.11. Results from Analysis of PAH Emission Factors	105
Table 5.12. Results from Analysis of Particulate and Acid Gas Emission Factors	106
Table 5.13. Results from Analysis of SVOC Emission Factors	107
Table 5.14. Results from Analysis of Dioxin, Furan, and PCB Emission Factors	108
Table 5.15. Results from Analysis of Fixed Combustion Gas Emission Factors	109
Table 5.16. Comparison of Emission Factors of Various Combustion Sources	109
Table 6-1. Measurement Quality Objectives	113
Table 6-2. Field Blank and Filterable Particulate Results	116
Table 6-3. Field Blank and Particulate Data Summary	117
Table 6-4. Metals Field Blank and Sample Results Summary	118
Table 6-5. PAH Method and Field Blank Concentrations	120
Table 6-6. Comparison of BV and RTI TEM Fiber Counts	122
Table 6-7. Comparison of BV and RTI Bulk Sample Analysis	122
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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
Acronyms and Abbreviations
ACB	Air Curtain Burner
ACFM	Actual Cubic Feet per Minute
APPCD	Air Pollution Prevention and Control Division
BTU	British Thermal Unit
BV	Bureau Veritas
C&D	Construction and Demolition
CARB	California Air Resource Board
CEM	Continuous Emissions Monitor
CFR	Code of Federal Regulations
DAS	Data Acquisition System
DCMD	Decontamination and Consequence Management Division
DSCM	Dry Standard Cubic Meter
EPA	U.S. Environmental Protection Agency
GC/MS	Gas Chromatography/Mass Spectrometry
ICAP	Inductively Coupled Argon Plasma
ID	Identification, also Induced Draft, also Inner Diameter
ISO	International Organization for Standardization
LCS	Laboratory Control Spike
LCSD	Laboratory Control Spike Duplicate
LLC	Limited Liability Company
MQO	Measurement Quality Objectives
MTBE	Methyl Tertiary Butyl Ether
N/A	Not Available
ND	Non-detect
NDIR	Non Dispersive Infra Red
NHSRC	National Homeland Security Research Center
NIOSH	National Institute for Occupational Safety and Health
NMOC	Non-Methane Organic Compounds
NPT	National Pipe Thread (U.S. standard for tapered threads)
NRMRL	National Risk Management Research Laboratory
ORD	Office of Research and Development
PAH	Polycyclic Aromatic Hydrocarbon
PCB	Polychlorinated Biphenyls
PCDDs/PCDFs	Polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans
PCM	Phase Contrast Microscopy
PLM	Polarized Light Microscopy
PM	Particulate Matter
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PM10	Particulate Matter with an aerodynamic diameter less than or equal to
a nominal 10 micrometers
PM2.5	Particulate Matter with an aerodynamic diameter less than or equal to
a nominal 2.5 micrometers
ppbv	Parts per billion by volume
OA	Quality Assurance
QAPP	Quality Assurance Project Plan
QC	Quality Control
RACM	Regulated Asbestos Containing Material
RPM	Revolutions Per Minute
RPD	Relative Percent Difference
SCFM	Standard Cubic Feet per Minute
SDT	SDT Waste & Debris, LLC
sLm	Standard Liters per Minute
SVOC	Semivolatile Organic Compound
TCLP	Toxicity Characteristic Leaching Procedure
TEF	Toxicity Equivalency Factor
TEM	Transmission Electron Microscopy
TEQ	Toxicity Equivalency Quotient
THC	Total Hydrocarbons
TIC	Tentatively Identified Compound
URG	Unified Recovery Group
UV	Ultraviolet
VOC	Volatile Organic Compound
XAD	Highly absorbent resins used in continuous sampling of organic
materials, especially for monitoring of pollutants in gas streams
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Acknowledgments
The authors would like to acknowledge the following people for their contributions to this work: Nancy Jones
of EPA Region 6, Pam Mazakas of EPA OECA, Wayne Desselle from Louisiana DEQ, St. Bernard Parish,
Brian O'Connor and Mike Dulmage of Air Burners, Inc., Dan Oser of Shaw, Jack Hayes, Tim Donaldson,
Alex Pullen, and John Donaldson of Northwest Environmental Resources, LLC, Johannes Lee, Gene
Stephenson, Michal Derlicki, John Nash, Ed Brown, Richie Perry, Jerry Revis, Libby Nessley, Aaron
Dublois, Russell Logan, Charly King, John Foley, and Richard Snow of ARCADIS, Coleen Northeim and
Owen Crankshaw of RTI, Alan Seagrave of Bureau Veritas, Tony Zimmer and Dave Roady of EPA's
National Decontamination Team, and Bob Olexsey, Fran Kremer, Roger Wilmoth, Andy Miller, Joe Wood,
Paul Lemieux, Paul Groff, Lauren Drees, and Dave Ferguson of EPA's Office of Research and
Development. We would also like to remember our colleague Mike Beard of RTI, who fought a valiant battle
with cancer over the course of this project.

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
Executive Summary
In an effort to provide a scientific basis to expand available options to better manage natural disaster debris
in the future, EPA evaluated the combustion of both vegetative debris and construction and demolition
(C&D) debris in an air curtain burner (ACB). ACBs can be mobilized to where they're needed as a potential
means of reducing the waste volume while minimizing potentially harmful environmental impacts. These
tests were conducted in June 2008 by EPA/ORD at the Old Paris Road Landfill in St. Bernard Parish,
Louisiana.
Testing was comprised of triplicate tests for each of two main test conditions:
•	Evaluation of emissions while burning hurricane-derived vegetative debris; and
•	Evaluation of emissions from burning a mixture of C&D debris which did not contain asbestos in
sufficient quantities to be categorized as Regulated Asbestos Containing Materials (RACM) and
hurricane-derived vegetative debris (used as supplemental fuel to maintain operating temperatures).
The analytes measured in these tests included:
•	Asbestos
•	Fine PM (less than 2.5 jjm)
•	Acid gases (HF, HCI, HBr, Cl2, Br2)
•	Toxic metals (Antimony (Sb), Arsenic (As), Barium (Ba), Beryllium (Be), Cadmium (Cd), Chromium (Cr),
Cobalt (Co), Lead (Pb), Manganese (Mn), Mercury (Hg), Nickel (Ni), Selenium (Se), Silver (Ag))
•	Polychlorinated dibenzo-p-dioxins and furans (PCDDs/PCDFs)
•	Co-planar polychlorinated biphenyls (PCBs)
•	Polycyclic aromatic hydrocarbons (PAHs)
•	Semivolatile organic compounds (SVOCs)
•	Volatile organic compounds (VOCs)
•	Visible emissions (opacity).
These data are intended for use in a separate risk assessment to support decision-making activities
regarding disaster debris management. Additional effort is required to relate these results, where possible,
to the operational parameters used in the field in execution of the daily burn cycle. Additionally, these data
may be used to develop operational guidelines for operators and technical guidelines for local, state, and
regional managers in using this technology.
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Preliminary analysis of the data suggests that for some of the pollutants (e.g., PM, NOx), there is little
observable difference between ACB operation on vegetative debris or on C&D debris. Emissions of other
pollutants (e.g., CO, SO2, HCI, VOCs) were somewhat higher from combustion of C&D debris than from
combustion of vegetative debris. Emission of some pollutants (e.g., dioxins and furans), were significantly
higher from burning C&D debris than from burning vegetative debris.
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DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
1. Introduction
In the aftermath of the devastation caused by natural disasters such as Hurricane Katrina, federal, state,
and local officials are faced with an overwhelming amount of storm-related debris requiring disposal. In
addition to vegetative debris including downed trees and limbs, a large number of houses may be damaged
beyond repair. In an effort to better deal with these types of situations in the future, EPA is working to
develop debris management options that expedite debris removal in a cost-effective and environmentally
sound manner. Given the enormous amount of vegetative, building, and demolition debris created by such
disasters, coupled with the limited capacity of existing landfills and industrial/commercial incineration
facilities capable of handling said waste, combustion in Air Curtain Burners (ACBs) has been proposed as
a potential means of reducing the waste volume on site while reducing potentially harmful environmental
impacts in emergency response situations that require quickly supplementing conventional waste
management methods.
1.1 Objective/Purpose and Intended Use of Project Results
Balancing the needs for efficient and timely disposal of debris with the need to protect both the environment
and human health presents a unique challenge. Information shall be gathered on the types and relative
quantities of potentially harmful emissions from ACBs burning both land-clearing (vegetative) and
construction and demolition (C&D) debris. This information shall be related, where possible, to the
operational parameters used in the field in actual execution of the daily burn cycle. Additionally, these data
will be used to develop operational guidelines for operators and technical guidelines for local, state, and
regional managers who will be using and developing permits for this technology. Note that burning anything
but clean wood-type waste in ACBs may subject these units to additional standards which may require
development of "official" test procedures for emissions measurements.
To this end, EPA's Office of Research and Development (ORD), in collaboration with EPA's Region 6
(located in Dallas, TX), conducted a series of tests of combustion of vegetative debris and construction and
demolition (C&D) debris in an ACB. EPA and its contractors conducted measurements of gaseous
emissions and combustion ash analysis to provide information on the emissions from ACBs during
operation.
This report provides an assessment on the types and relative quantities of source emissions directly from
ACBs burning both vegetative and demolition debris. It describes the operational parameters used in the
field in actual execution of the daily burn cycle. These data can be used to develop operational guidelines
for operators and technical guidelines for local, state, and regional managers who may be using and
developing permits for this technology.
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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
1.2	Scope of Project
In June 2008, EPA/ORD conducted a field testing campaign on an ACB that was temporarily deployed at
the Old Paris Road Landfill in St. Bernard Parish, Louisiana, for the sole purpose of studying its
performance. Testing was comprised of two groupings:
1.	Evaluation of emissions from burning hurricane-derived vegetative debris; and
2.	Evaluation of emissions from burning a mixture of C&D debris which did not contain asbestos in
sufficient quantities to be categorized as Regulated Asbestos Containing Materials (RACM) and
hurricane-derived vegetative debris (used as supplemental fuel to maintain operating temperatures).
The key reason for performing testing with vegetative debris as well as C&D debris is to place a comparative
perspective on the emissions while burning C&D debris. ACBs are commonly used for vegetative debris
combustion, and their use for this application is widely accepted.
In each grouping, a representative portion of the exhaust gas from the combustion process was sub-
sampled and routed through ducting to allow stationary sampling at a safe distance for a variety of analytes
using codified EPA methods. In addition to emission sampling, there were several stationary air samplers
located at regular distances downwind to determine the ambient concentrations of key contaminants
downwind from the ACB (the results from this sampling effort are outside the scope of this report and will
be reported separately). Estimates of total mass emissions from the entire ACB were calculated using the
volume of gas sampled coupled with estimates of the total volume of exhaust gas from the ACB. Emission
factors were also generated by determining the mass of contaminant emitted per mass of waste burned.
Because of the inherent variability seen in the waste feeds and combustor operation, and the logistical
difficulties of accurately measuring some of the operational parameters on an operation of this scale, our
ability to accurately estimate potential mass emission rates was limited to order-of-magnitude
determinations. In spite of these limitations, however, the emissions measurements reported in this
document are believed to be more complete and higher quality than any other available data set reporting
on ACB emissions.
1.3	ACB Technology
Figure 1-1 shows a design for a commercially available ACB (Air Burners LLC, 1998-2007). Operated as
an above ground installation, or in some instances, installed with the top of the unit at ground level, ACBs
are mobile incinerators that utilize the general concept that a high-volume sheet of air is blown at a slight
downward angle across the top of, and into, the combustion vessel. The air serves a dual purpose: 1)
combustion is enhanced (compared to open burning) through providing a steady supply of forced excess
oxygen with turbulent mixing resulting in higher temperatures and more thorough consumption of the solid
debris used as fuel; and 2) the injection of the air at a slightly incident angle forms a "curtain" that creates
a recirculation zone and serves as a barrier to the emission of particulate matter (PM) (smoke) and forces
longer residence times as opposed to conventional open burning (where debris is burned in an open pile
with no forced combustion air).
ACBs have been deployed on numerous occasions by the U.S. Forest Service and the U.S. Army Corps of
Engineers for the reduction of vegetative waste and in some cases for destruction of animal carcasses.
Limited data are available on the emissions from these applications, essentially amounting to just emissions
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data for carbon monoxide (CO), filterable particulate matter, and opacity. A detailed analysis of available
literature on ACB emissions can be found in Miller and Lemieux (Miller and Lemieux, 2007).
Figure 1 -1. Photograph of an Air Burners LLC Air Curtain Burner Unit
ACBs are generally used for on-site disposal of vegetative debris such as the debris generated from large
scale land clearing or forest management operations. The ACB units burn the combustible material in an
enclosed space with an open top, over which a high velocity "curtain" of air is directed to reduce the escape
of large particles and to improve air circulation into the burning debris The combination of high airflow into
the combustion zone and recirculation of the combustion products is designed to reduce visible particulate
matter (PM) emissions and provide increased gas-phase residence times compared with open pile burning.
There are several types of ACB designs. The firebox can be a pit dug into the ground and equipped with a
transportable blower and curtain air plenum positioned to blow the curtain air over and down into the pit.
These designs are common in applications such as destruction of forest clearing debris because the units
are relatively light and can be towed into remote areas with poor roads. A second type of ACB uses a
refractory-lined firebox that is entirely above ground. These ACB units are approximately the size of a large
waste dumpster and incorporate the air curtain fan on the same skid as the firebox. A third ACB design
variant extends the side and back walls of the firebox upward to minimize the impact of wind and may also
incorporate provisions for introducing combustion air (underfire air) into the firebox underneath the debris
to theoretically improve the airflow through the combustion zone (see Figure 1-2), although field data are
not available to assess the performance of this design variant as well as its impact on other pollutants due
to potential entrainment of bed material resulting from air blowing up through the bed. This type of unit
cannot be transported as an integral unit and can require a week or more to set up and begin operations.
It must also be noted that this third design variant is included here only for completeness, - the
manufacturer of the ACB unit tested for this effort does not produce this design variant and data on its
performance are not available. Other variants on the design include misters or even secondary combustion
chambers. For all of these designs, the operation when burning vegetative debris is fundamentally the
same. The initial charge of debris is loaded into the unit and ignited, usually using diesel fuel or kerosene
as a starting fluid. Once the debris has ignited, the blower is started and additional debris is loaded into the
unit as needed to maintain combustion. The ignition process can generate a temporary puff of black smoke
as the diesel fuel ignites, and smoke typically increases for a brief period as subsequent loads of debris are
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loaded. Generally, no auxiliary fuel is used to maintain good combustion within the unit when burning
vegetative debris.
Figure 1-2. ACB with Extended Skirt
1.4 Application of ACB Technology to Demolition Debris
Managing debris from natural disasters presents some unique issues as yet unstudied. One of the more
serious problems associated with Hurricane Katrina was the huge number of homes, many of them older
homes, built before 1970, that will have to be demolished and disposed of. Many of these homes are likely
to contain asbestos and/or lead-based paints, as well as numerous sources of chlorine and metals. We are
unaware of any reliable information on the potential emission rates from ACBs burning C&D debris, which
may contain a range of contaminants including:
•	Asbestos;
•	PM2 5 (PM with an aerodynamic diameter less than or equal to than 2.5 pm);
•	Acid gases -- hydrogen fluoride (HF), hydrogen chloride (HCI), hydrogen bromide (HBr), chlorine (CI2),
bromine (Eto);
•	Toxic metals (Antimony (Sb), Arsenic (As), Barium (Ba), Beryllium (Be), Cadmium (Cd), Chromium (Cr),
Cobalt (Co), Lead (Pb), Manganese (Mn), Mercury (Hg), Nickel (Ni), Selenium (Se), Silver (Ag));
•	Polychlorinated dibenzo-p-dioxins and furans (PCDDs/PCDFs);
•	Co-planar polychlorinated biphenyls (PCBs);
•	Polycyciic aromatic hydrocarbons (PAHs);
•	Semivolatile organic compounds (SVOCs);
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•	Volatile organic compounds (VOCs); and
•	Visible emissions (opacity);
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2. Air Curtain Burner Test Descriptions
2.1 Characteristics of Field Test Site
Figure 2-1 shows the area at the Old Paris Road Landfill in St. Bernard Parish, Louisiana, which was the
site of the testing and data gathering. The area is remote from occupied residences (greater than 1000
feet). The numbers refer to locations described in the text following the figure.
Paris Rd Landfill Sampling Areas
Figure 2-1. Aerial Photo of Test Site
The ACB unit used in the tests was an Air Burners Model S-327(Air Burners LLC, 2009) Refractory Lined
Air Curtain Burner rated at a throughput of 6 to 10 tons of wood waste while burning approximately 3 gallons
per hour of diesel fuel in the onboard generator.
In addition to the source sampling described in this report, additional sampling efforts (outside the scope of
this report) were simultaneously occurring on the site to measure pollutant concentrations in the air
surrounding the ACB unit. This sampling effort included two concentric sampling rings both centered on the
ACB. The two concentric sampling rings are shown in green in Figure 2-1. The inner sampling ring was
located between 60 to 75 feet from the ACB. The outer sampling ring was approximately 300 feet from the
center of the ACB. Each ring consisted of 18 air sampling stations (measuring PM, dioxins/furans, and
asbestos) evenly spaced around the ring.
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The ACB unit, centered inside the inner sampling ring shown in Figure 2-1, was oriented roughly east-west
lengthwise (refer to Figure 1-1) with the air plenum on the north side. Previous detailed velocity traverse
measurements taken on the Air Burners S-327 model (Miller and Lemieux, 2007), showed negligible
velocity and gas concentration gradients along the long side of the unit opposite the air inlet plenum. Based
on these observations and the desire to minimize damage to the sampling equipment due to the heavy
equipment or falling debris, the sampling scoop was placed on the southeast corner of the ACB and the
sample extraction ductwork ran south to an induced draft (ID) fan which was approximately 40 feet outside
the inner sampling ring. The scoop was positioned flush with the top edge of the ACB, above the air curtain.
The duct in which the sampling took place was a section 35 feet in length and six inches in inner diameter
roughly centered between the inner sampling ring and the blower. A schematic representation of the
extraction system is shown in Figure 2-2.
Blower Plenum
Air Curtain Burner
Stack -
4" ID Port
X
6" ID Stainless Steel
Sampling Duct

Insulated 4" ID Flexible
Stainless Steel Duct
O O O O O
D
<3 Butterfly Valve
Fan
Approximately 90'
35'
Figure 2-2. Near-isokinetic Scoop and Sample Extraction System.
Ambient air samplers were placed at five additional locations (indicated in Figure 2-1 as red numerals)
outside the outer sampling ring. These locations were:
Location 1. West of the trailers at the United Recyclers Group (URG) Office compound;
Location 2. Inside the fence on the URG/Parish property west of Paris Road;
Location 3. West of the motel on Paris Road;
Location 4. West of SDT Waste & Debris, LLC (landfill operator), Transfer Station; and
Location 5. West of the URG inspection tower.
The procedures and results from the ambient air samplers are not within the scope of this report and will
be published elsewhere.
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3. Test Operations
3.1	Sample Locations
The test team utilized five sample locations during the test program: ACB bed temperatures were
intermittently obtained by placing sensors and recording devices directly into the bed during operation; ACB
combustion level temperatures were recorded during operation by thermocouples placed at intervals
through the metal wall and refractory of the device; fuel samples were taken directly from the fuel piles
maintained by another contractor; ash samples were extracted from the bed of the ACB after a period of
cooling; and all emissions samples were taken from a 6-inch duct connected to a near-isokinetic sampling
scoop placed at one corner of the ACB exit. Further discussion of the isokineticity of the scoop during the
sampling program can be found in Section 3.2.3. Visible emissions readings were taken by an operator
directly observing the ACB exhaust as per EPA Method 9 (U.S. EPA, 1996a).
3.2	Target Analytes
3.2.1	Feed Debris
Samples of the vegetation used for the feed were taken and composited for later analysis. No practical
method of compositing the highly heterogeneous C&D debris to accurately represent what was actually
combusted was derived so no laboratory analyses of that material were undertaken. The wood fuel was
composited into a single wood fuel sample and analyzed by proximate/ultimate analyses for: moisture,
volatiles, fixed carbon, ash, sulfur, total carbon, hydrogen, nitrogen, oxygen, chlorine and higher heating
value. It must be noted that the vegetative debris used for fuel was recovered as part of the Hurricane
Katrina response and had sat in brackish water for an unknown period of time prior to being recovered and
brought to the test site. The debris used in the tests therefore was likely representative of much of the
vegetative debris recovered during hurricane response activities, where the debris was exposed to salt
water for extended periods of time. This uncontrollable variable may have influenced emissions of
chlorinated organic compounds including chlorinated benzenes and phenols as well as polychlorinated
dibenzo-p-dioxins and polychlorinated furans.
3.2.2	ACB Ash
Samples of bulk ash were collected following each of the two phases of testing (vegetative and C&D) on
the morning following conclusion of testing. Prior experience indicated that the ash would not cool to
ambient temperatures if it remained in the unit overnight, so care was taken in obtaining samples. Multiple
samples were taken from randomly selected portions of the ash bed using a metal scoop and placed in a
stainless steel container for cooling. The actual number of samples per test condition was determined by
ash bed accessibility, and samples were collected from the same locations for each condition to the extent
possible. At least one composited sample consisting of sub-samples from several parts of the ACB ash bed
(e.g., middle, corner, several depths) was collected forthe two fuel types. The composited sample was then
sub-sampled and sent to TestAmerica for extraction by the Toxicity Characteristic Leaching Procedure
(TCLP) (U.S. EPA, 1992) by SW-846 1311 and for subsequent analyses for the following: RCRA metals by
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SW-846 601 OB and 7470A, VOCs by SW-846 8260B, SVOCs by SW-846 8270B, organochlorine pesticides
and PCBs by SW-846 8081A and 8082, chlorinated herbicides by SW-846 8151A, ignitability by SW-846
1030, reactive cyanide by SW-846 9014, reactive sulfide by SW-846 9034, and pH by SW-846 9045C.
Additional sub-samples were provided to Bureau Veritas for evaluation of asbestos content and to Standard
Laboratories for proximate/ultimate analyses.
3.2.3 ACB Combustion Gases
The ACB combustion gases were extracted from the ACB exhaust by a near-isokinetic scoop and conveyed
by an ID fan to a six-inch diameter duct constructed for the purpose of allowing conventional extractive
sampling methodology to be used to sample the gas content (see Figure 2-2). The duct had a number of
1-inch, 3-inch, and 4-inch National Pipe Thread (NPT) sampling ports to provide entry for the sampling
probes. Target analytes were: filterable particulate and condensable matter, particle size distribution, PM2 5
particulate, asbestos, metals, VOCs, SVOCs, acid gases, dioxins/furans, PCBs, and PAHs. The flexible
section of the duct between the scoop and the sampling section was insulated to prevent heat loss. The ID
fan outlet pipe was equipped with a butterfly valve, but attempts at fine control proved futile as the
temperature of the gas from the scoop varied too widely over a relatively short period of time. We therefore
decided to set the valve wide open and leave it at that setting for the duration of the sampling program.
With this valve set at wide open, scoop temperature variation during test runs became the sole extraction
system operational parameter of great significance for the isokineticity of the extraction scoop.
The entry face of the extraction scoop was 18 inches by 5 inches, with the longer dimension spanning the
final 18 inches of the ACB firebox width on the side opposite the blower plenum as shown in Figure 2-2.
This 18-inch span along the length of the ACB represents the area where, from earlier flow determinations
on an identical burner, essentially all the combustion product gases exit the firebox. With this experience in
mind, and the earlier measurement of 15 ft/sec bulk velocity in that 18-inch span, estimated extraction
scoop isokinetic variation during the sampling runs was calculated. During the test program, isokinetic
variation was between 47.8% and 90.9%, with an average of 65.9%.
3.3 Sampling and Analysis Methods
3.3.1 Feed Debris Sampling Analysis Methods
ACB wood fuel samples were taken daily by technical staff. On June 24 and the morning of the 25th, wood
samples were taken hourly and composited for a single laboratory sample representing a single vegetative
debris run: i.e., three composited samples were collected. Specific sample collection procedures involved
selecting a log from the inner ring that was due for burning and using a claw hammer to remove a handful
of thick bacon-strip-size pieces (including bark properly represented) that were temporarily stored in a
bucket. At the end of the run, all the hourly samples were representatively sampled to fill a one liter sample
jar. These three composited samples were later composited representatively again and submitted for a
single proximate/ultimate analysis and chlorine analysis. When received by the lab, the entire sample of
bacon-strip-size pieces were air dried, crushed/pulverized to 20 mesh, and riffled to produce a homogenous
feed stock for all further analyses. These further analyses utilized a 1-5 gram portion of the whole sample.
No practical method of C&D debris sampling could be developed due to the content and variability of the
feed material.
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3.3.2 ACB Combustion Gases Sampling and Analysis Methods
3.3.2.1 Continuous Emissions Monitors
Continuous instrumental methods using continuous emissions monitors (CEMs) were employed to measure
concentrations of carbon dioxide (CO2), oxygen (O2), nitrogen oxides (NOx), carbon monoxide (CO), sulfur
dioxide (SO2), and THC. These instruments were operated in accordance with EPA Methods 3A (CO2/O2)
(U.S. EPA, 1989), 7E (NOx) (U.S. EPA, 1990), 10 (CO) (U.S. EPA, 1996b), 6C (SO2) (U.S. EPA, 1996c),
and 25A (THC) (U.S. EPA, 1996d) as prescribed in the Code of Federal Regulations (CFR), specifically 40
CFR Part 60, Appendices A2, A4, and A7. CEM sampling began prior to test material being fed into the
ACB and continued until after extractive sample acquisition was completed.
Effluent gas samples destined for CEM sampling (except the THC monitor) were conditioned to remove
water vapor and particulate matter, which are interfering constituents. The sample gas going to the THC
monitor was heated and maintained at 250-300 ฐF and filtered with glass fiber filters. The THC monitor
requires the sample to be hot and condensate-free to operate properly, as some components of THC can
be disabled by condensation of water.
Components of the sampling system in contact with the sample gas, including the ducting but excepting
the extraction scoop, which was constructed of black iron, were constructed of Type 316 stainless steel or
Teflonฎ to minimize the possibility of surface chemical reactions, which can affect the accuracy of the
measurements. The CO2/O2, NOx, SO2, THC, and CO sample collection and conditioning system consisted
of a heated probe and a particulate filter, followed by a moisture-removal trap and an out-of-stack secondary
particulate filter. A sample pump (Thomas Model 2107CA 18-TFE) transported the effluent sample through
a distribution manifold to the analyzers. The configuration of the sampling system allowed the calibration
gases to be injected either directly into the analyzers or through the complete sample collection and
conditioning system. Table 3-1 lists the model number and the name and location of the manufacturer of
this pump, and summarizes this same information for the remainder of the equipment used during this
project.
An Environics Series 4000 Gas Mixer was used to produce calibration gases at the desired concentration.
The mixer achieved accurate blending/mixing by using four Tylan Series FC thermal mass flow controllers
and an integral Environics computer control system. Based on EPA Method 205 procedures (U.S. EPA,
1996o), the gas mixer blended a high-level EPA protocol 1 calibration gas of known concentration with an
inert diluent gas such as nitrogen, thus producing a calibration gas at lower concentration.
The concentration signal outputs from the CEMs were connected to a computer-based data acquisition
system (DAS) using software written by ARCADIS. The DAS used a portable computer and a strip chart
recorder/analog-to-digital converter. In addition to providing an instantaneous display of analyzer response,
the DAS compiled, averaged, and saved analyzer data at a user-set frequency. For the purposes of these
tests, the data were logged with a one minute rolling average. The DAS integrated the real-time
measurements and provided files and printouts of the averaged emissions over the desired time period.
The functioning of the DAS was checked by verifying that its indicated signal levels were in agreement with
a calibrated Yokogawa chart recorder.
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Table 3-1. Equipment used during the ACB Testing
Item
Model #
Manufacturer
Location
Sample pump
Model 2107CA 18-
TFE
Thomas
1419 Illinois Avenue, Sheboygan, Wl
53082
Gas mixer
Series 4000
Environics
69 Industrial Park Road East, Tolland,
CT 06084
Mass flow controllers
Series FC
Tylan
Company no longer in business
O2 Analyzer
Model 3300P
Teledyne
16830 Chestnut Street, City of Industry,
CA 91748
CO2 Analyzer
Model ZRH
California Analytical
1312 W. Grove Ave, Orange, CA 92865
SO2 Analyzer
Model ZRF
California Analytical
1312 W. Grove Ave, Orange, CA 92865
NOx Analyzer
Model CLD 70S
Eco Physics
3915 Research Park Drive, Suite A-3,
Ann Arbor, Ml 48108
CO Analyzer
Model ZRH
California Analytical
1312 W. Grove Ave, Orange, CA 92865
THC Analyzer
Model 20S
VIG
4051 East La Palma Ave., Suite C,
Anaheim, CA 92807
ACB Thermocouples
K-Type
Omega
One Omega Drive, Stamford, CT 06907
IC for acid gases
LC-10AD/CDD6A
Shimadzu
7102 Riverwood Drive, Columbia, MD
21046
ICAP for metals
Model 3300DV
Perkin-Elmer
940 Winter Street, Waltham, MA 02451
CVAAS for Hg
Model 1100
Perkin-Elmer
940 Winter Street, Waltham, MA 02451
PM2.5 cyclone
Model PM2-K
Apex Instruments
125 Quantum Street, Holly Springs, NC
27540
Cascade impactor
Mark III
Andersen
Company no longer in business
PM10 cyclone
Model PM10-K
Apex Instruments
125 Quantum Street, Holly Springs, NC
27540
Portable scale
Model L-3040
Vishay Sl/Lodec
11400 P.P.G. S.E., Cumberland, MD
21502
TEM for asbestos
Model CM-12
Phillips
5350 NE Dawson Creek Dr., Hillsboro,
OR 97124
PCM for asbestos
Model BH-2
Olympus
3500 Corporate Parkway, Center Valley,
PA 18034
Data system chart
recorder
Model DR-130
Yokogawa
2 Dart Road, Newnan, GA 30265
Asbestos re-
deposition filter
47 mm MCE
Pall
600 S. Wagner Rd., Ann Arbor, Ml
48103
All pre-test and post-test calibration procedures were performed as outlined in the specific EPA methods.
The operating principles of the analyzers are described in the following subsections.
3.3.2.1.1 CO2/O2 (EPA Method 3A)
Carbon dioxide and oxygen concentrations were determined by EPA Method 3A - Determination of
Oxygen and Carbon Dioxide Concentrations in Emissions from Stationary Sources (Instrumental
Analyzer Procedure), as described in 40 CFR Part 60, Appendix A-2 (U.S. EPA, 1989). In Method 3A, a
gas sample is continuously extracted from the stack and conveyed to instrumental analyzers for the
determination of oxygen and carbon dioxide concentration. Specifically, an electrochemical analyzer
(Teledyne Model 3300P) was used for oxygen and a non-dispersive infrared (NDIR) analyzer (California
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Analytical Model ZRH) was utilized for carbon dioxide. Results were used in the calculation of sampling
duct gas molecular weight.
3.3.2.1.2	S02 (EPA Method 6C)
Sulfur dioxide concentration was determined by EPA Method 6C - Determination of Sulfur Dioxide
Emissions from Stationary Sources (Instrumental Analyzer Procedure), as described in 40 CFR Part
60, Appendix A-4 (U.S. EPA, 1996c). In Method 6C, a gas sample is continuously extracted from the
sampling duct and conveyed to an instrumental analyzer (in this case a California Analytical Model ZRF
non-dispersive infrared (NDIR) analyzer) for the determination of sulfur dioxide concentration. Flow data
from concurrent EPA Methods 1A (U.S. EPA, 1996n) and 2C (U.S. EPA, 1996m) were used to calculate
sulfur dioxide mass emission rates.
3.3.2.1.3	NOx (EPA Method 7E)
Nitrogen oxides were determined by EPA Method 7E - Determination of Nitrogen Oxides Emissions
from Stationary Sources (Instrumental Analyzer Procedure), as described in 40 CFR Part 60, Appendix
A-4 (U.S. EPA, 1990). In Method 7E, a gas sample is continuously extracted from the sampling duct and
conveyed to an instrumental analyzer (here an Eco Physics Model CLD-70S Chemiluminescence Analyzer)
for the determination of nitrogen oxides concentration. Flow data from concurrent EPA Methods 1A (U.S.
EPA, 1996n) and 2C (U.S. EPA, 1996m) were used to calculate nitrogen oxides mass emission rates.
3.3.2.1.4	CO (EPA Method 10)
CO emissions were determined by EPA Method 10 - Determination of Carbon Monoxide Emissions
from Stationary Sources, as described in 40 CFR Part 60, Appendix A-4 (U.S. EPA, 1996b). In Method
10, a gas sample is continuously extracted from the sampling duct and conveyed to an instrumental
analyzer (California Analytical Model ZRH NDIR in this case) for the determination of carbon monoxide
concentration. Flow data from concurrent EPA Methods 1A (U.S. EPA, 1996n)and 2C (U.S. EPA, 1996m)
were used to calculate carbon monoxide mass emission rates.
3.3.2.1.5	THC (EPA Method 25A)
THC emissions were determined by EPA Method 25A - Determination of Total Gaseous Organic
Concentration Using a Flame Ionization Analyzer as described in 40 CFR Part 60, Appendix A-7 (U.S.
EPA, 1996d). Method 25A is applicable over a wide range of THC concentrations, from percent levels down
to low ppm levels. The method does not differentiate the species that constitute total hydrocarbons, i.e.,
methane and non-methane organic compounds (NMOCs) are measured together and reported as one
concentration as equivalent propane. Method 25 (U.S. EPA, 19961) is specifically designed to measure
NMOCs. However, Method 25 is not suitable for measuring concentrations less than 50 ppm and was not
used.
In Method 25A, a gas sample is extracted from the source through a heated sample line and a glass fiber
filter; the gas sample is then introduced to a flame ionization detector (FID). Used here was the VIG Model
20S FID. Results are reported as volume concentration equivalents (ppm by volume) of the calibration gas
(propane). The mass emission rate was calculated by the incorporation of results of EPA Methods 1A (U.S.
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EPA, 1996n) and 2C (U.S. EPA, 1996m) volumetric flow data along with moisture and molecular weights
determined by EPA Methods 3A (U.S. EPA, 1989) and 4 (U.S. EPA, 1995b).
3.3.2.2	Temperature
Temperature in the ACB was determined using two methods. K-type thermocouples were inserted through
joints in the refractory lining to allow recording of near-wall temperatures at various points in the ACB.
Additionally, bed temperatures were intermittently determined in situ using shielded thermocouple/recorder
packages directly in the ACB bed. The ultimate objective of temperature measurement was not to ascertain
a "true" temperature; rather the goal was to determine a readily reproducible temperature parameter that
can potentially be used by inspectors and operators to monitor ACB performance.
3.3.2.3	Flue Gas Volumetric Flow Rate (EPA Methods 1A and 2C)
Flue gas volumetric flow rates were determined by EPA Method 1A - Sample and Velocity Traverses for
Stationary Sources with Small Stacks or Ducts and EPA Method 2C - Determination of Stack Gas
Velocity and Volumetric Flow Rate in Small Stacks and Ducts (Standard Pitot Tube), as described in
40 CFR Part 60, Appendix A-1 (U.S. EPA, 1996m, U.S. EPA, 1996n). A measurement location in the
effluent stream was selected to minimize angular and cyclonic flow. Using Method 1A, the duct cross
section was divided into an appropriate number of equal areas and the probe was marked to signify the
velocity traverse points. Due to the potential for flow disturbance in small stacks, the sample extraction and
flow measurement were performed apart from one another. Sampling ports for extractive samples were
located eight equivalent diameters upstream of the velocity sampling ports to allow forthe re-establishment
of flow stability. Using Method 2C, a traverse for velocity head and sampling duct gas temperature was
performed using a standard pitot tube and thermocouple probe to minimize flow disturbance. Sampling duct
gas volumetric flow rate was calculated using the resultant data, the sampling duct gas density, and duct
cross sectional area. Measurements were performed in conjunction with each test run for
filterable/condensable particulate, metals, and dioxins/furans. ACB flow estimates, along with pollutant
concentration data from concurrent methods, were used to calculate pollutant mass emission rates.
3.3.2.4	Stack Gas Molecular Weight and Stack Moisture (EPA Methods 3A and 4)
Sampling duct gas molecular weight and diluent concentration were determined by EPA Method 3A -
Determination of Oxygen and Carbon Dioxide Concentrations in Emissions from Stationary Sources
(Instrumental Analyzer Procedure) and EPA Method 4 - Determination of Moisture Content in Stack
Gases, as described in 40 CFR Part 60, Appendices A-2 and A-3, respectively (U.S. EPA, 1989, U.S. EPA,
1995b). In Method 3A, a gas sample is continuously extracted from the sampling duct and conveyed to
instrumental analyzers forthe determination of O2 and CO2 concentration. Diluent gas concentration and
molecular weight are calculated from these results. In Method 4, a gas sample is extracted from the source
with moisture being removed and determined gravimetrically and/or volumetrically. Method 4 samples were
taken as a part of the EPA Method 5/202 (U.S. EPA, 1996j, U.S. EPA, 1996k), M29 (U.S. EPA, 1996i), and
M23 (U.S. EPA, 1995c) samples.
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3.3.2.5	Filterable Particulate and Acid Gases
Filterable particulate matter and acid gases (HF, HCI, Cb, HBr, and Br2) were determined according to EPA
Method 5 - Determination of Particulate Emissions from Stationary Sources, and EPA Method 26A -
Determination of Hydrogen Haiide and Halogen Emissions from Stationary Sources (Isokinetic
Method), both described in 40 CFR Part 60, Appendix A-3 (U.S. EPA, 1994, U.S. EPA, 1996g, U.S. EPA,
1996k). These two methods were combined into a single sampling train. Using this combined method, a
flue gas sample was withdrawn from the sampling duct isokinetically through a heated probe and a pre-
weighed, heated, glass fiber filter into an impinger/condensertrain containing dilute sulfuric acid and sodium
hydroxide solutions which collected the gaseous hydrogen halides and halogens, respectively. The filtered,
dried gas was measured with a calibrated dry gas meter and the particulate matter captured in the probe
and filter were desiccated and weighed. The hydrogen halides were solubilized in the acidic solution and
subsequently formed chloride (CI ), bromide (Br), and fluoride (F ) ions. The halogens have a very low
solubility in the acidic solution and pass through to the alkaline solution where they are hydrolyzed to form
a proton (H+), the haiide ion, and the hypohalous acid (HCIO or HBrO). Sodium thiosulfate was added in
excess to the alkaline solution to assure reaction with the hypohalous acid to form a second haiide ion such
that two haiide ions are formed for each molecule of halogen gas. The haiide ions in the separate solutions
were measured by ion chromatography. Emission rates were calculated from these results and the results
of concurrent flue gas flow rate measurements using EPA Methods 1A (U.S. EPA, 1996n) and 2C (U.S.
EPA, 1996m).
3.3.2.6	Asbestos
No approved method for measuring asbestos in combustion flue gases currently exists. It was initially
planned to pull a sample isokinetically from the sampling duct through a 37 mm diameter polycarbonate
filter with a 0.4 jjm pore size at approximately 15 sLm. In that scenario, it would have been necessary to
perform a preliminary test to determine the correct sampling time to load the filters with an amount of sample
appropriate to the ultimate asbestos analysis methodology - Transmission Electron Microscopy (TEM) by
ISO 10312:1995 Ambient Air-Determinations of Asbestos Fibers - Direct Transfer Transmission Electron
Microscopy Method (U.S. EPA, 1987). This microscopic method is capable of identifying the presence and
type of asbestos. The preliminary test runs were to be taken for the following durations: one minute, three
minutes, five minutes, ten minutes, and thirty minutes. The filters from the preliminary runs were to be
subjected to visible examination and phase contrast microscopy (PCM) on site. This technique, National
Institute for Occupational Safety and Health (NIOSH) Method 7400 (NIOSH, 1994), is capable of
determining if a given filter is properly loaded for TEM analyses. It was hoped that one of the preliminary
test run sampling times would be satisfactory for the collection of the actual samples.
However, upon arrival on site and preliminary monitoring of the duct temperature, it was decided that the
temperature was too high (as well as widely variable) for the 37 mm polycarbonate filter material. That fact,
in addition to the fact that it was decided not to burn RACM during the test program, led to an alteration of
the asbestos sampling method. The alteration consisted of simply removing the 37 mm filter from the
sampling train and collecting the sample directly into the deionized water in three glass impingers. The
samples were extracted isokinetically with what was essentially an EPA Method 5-type sampling train
without the filter. Operating parameters were those of Method 5, i. e., extraction rate of ~0.6 cfm,
probe/hotbox temperature of ~ 240 ฐF, impinger volume of 100 mL, impinger temperature of ~35 ฐF, and a
run time of 120 minutes (one was cut short by a thunderstorm). Sample volumes ranged from 47 scf (the
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shortened run) to 95 scf, sufficient for determination of asbestos. Samples were recovered from the
impingers by triple washes of Dl water into glass sample jars for shipment to the laboratory. Due to an
oversight, field blanks were not collected, but all laboratory method blanks analyzed with these samples did
not detect asbestos.
Ash samples were analyzed for asbestos using EPA/600/R-93/116 "Interim Method for the Determination
of Asbestos in Bulk Insulation Sample", EPA-600/M4-82-020, December 1982, published as Appendix E to
Subpart E of 40CFR763 (U.S. EPA, 1993).
3.3.2.7	Metals
Metals emission rates were determined by the use of EPA Method 29 - Determination of Metals
Emissions from Stationary Sources, as described in 40 CFR Part 60, Appendix A-8 (U.S. EPA, 1996i).
A metered flue gas sample was withdrawn isokinetically from the sampling duct through a heated probe
and glass fiber filter into an impinger/condenser train. The impingers contained a mixture of 5 percent
nitric/10 percent hydrogen peroxide for metals absorption. Mercury is further absorbed by impingers
containing 4 percent potassium permanganate/10 percent sulfuric acid. The filtered, dried, metals-depleted
gas was measured with a calibrated dry gas meter. The filter and impinger solutions were digested and
analyzed for the target metals by Inductively Coupled Argon Plasma (ICAP) with exception of mercury
which was analyzed by cold vapor atomic absorption spectroscopy (CVAAS). Metals emission rates were
calculated from the resultant metals concentrations and the results of flue gas volumetric flow rate
measurements using concurrent EPA Methods 1A (U.S. EPA, 1996n) and 2C (U.S. EPA, 1996m)
measurements.
3.3.2.8	VOCs
Concentrations of VOCs were determined by an adapted version of EPA Method 0040 - Sampling of
Principal Organic Hazardous Constituents from Combustion Sources Using Tedlar Bags, as
described in SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (U.S. EPA,
1996e). In Method 0040, a representative sample was drawn from a source through a heated sample probe
and filter. The sample then passed through a heated 3-way valve into a condenser where the moisture and
condensable components were removed from the gas stream and collected in a glass trap. The gas sample
was then collected in a canister.
A SUMMAฎ-passivated canister was substituted for the Tedlar bag. This modification was necessitated by
the fact that Tedlar bags are fragile and prone to burst during shipment. SUMMAฎ canisters, which are
routinely used in ambient sampling methods for organics, were an acceptable substitution to solve this
problem. VOC mass emission rates were calculated from the resultant constituent VOC concentrations and
the results of flue gas volumetric flow rate measurements using concurrent EPA Methods 1A (U.S. EPA,
1996n) and 2C (U.S. EPA, 1996m).
3.3.2.9	Dioxins/Furans
Dioxin/furan emission rates were determined by the use of EPA Method 23 - Determination of
Polychlorinated Dibenzo-p-Dioxins and Polychlorinated Dibenzofurans from Stationary Sources, as
described in 40 CFR Part 60, Appendix A-7 (U.S. EPA, 1995c). A metered flue gas sample was withdrawn
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from the stack isokinetically through a heated probe and Teflon coated, glass fiber filter onto a
condenser/XAD-2 packed resin trap for collection of dioxins/furans. The filtered, dried gas flow rate was
measured with a calibrated dry gas meter. The XAD resin trap was extracted and analyzed for
dioxins/furans by high resolution gas chromatography/mass spectrometry (GC/MS). Dioxin/furan emission
rates were calculated from these results and the results of concurrent flue gas flow rate measurements
using EPA Methods 1 (U.S. EPA, 1996f) and 2C (U.S. EPA, 1996m). PAHs and PCBs were also determined
by use of Method 23 by taking aliquots of the resultant samples and analyzing them for those additional
constituents.
3.3.2.10	SVOCs
SVOC emission rates were determined by the use of EPA Method 0010 - Modified Method 5 Sampling
Train as described in SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (U.S.
EPA, 1986). A metered flue gas sample was isokinetically withdrawn from the sampling duct through a
heated probe and Teflon coated, glass fiber filter onto a condenser/XAD-2 packed resin trap for collection
of SVOCs. The filtered, dried gas was measured with a calibrated dry gas meter. The XAD resin trap was
extracted, split, and analyzed by GC/MS for a variety of SVOCs. Emission rates were calculated from these
results and the results of concurrent flue gas flow rate measurements using EPA Methods 1A (U.S. EPA,
1996n) and 2C (U.S. EPA, 1996m).
3.3.2.11	Particle Size Determination
Detailed particle size determinations were made using a modification of California Air Resource Board
(CARB) Method 501 (CARB, 1990). In CARB Method 501, an in-stack PM10 (PM smaller than or equal to
10 jjm in aerodynamic diameter) particle separation device (a cyclone) was used to determine the
concentration of PM10 particulate matter. A portion of the sampling duct gas then passed to an Andersen
10-stage cascade particle sizing impactor for further sub-PMio size determination. This procedure yielded
PM10 concentration (from the PM10 cyclone) and a distribution of particle sizes smaller than 10 jjm (from
the Andersen cascade impactor).
3.3.2.12	PM2.5 Particulate
PM2 5 particulate determinations were made by a modified version of EPA Method 201A - Determination
of PM10 Emissions (Constant Sampling Rate Procedure) (U.S. EPA, 1996h). In this method, a gas
sample was extracted at a constant flow rate through an in-stack sizing device, which separates PM greater
than PM10. Variations from isokinetic sampling conditions were maintained within well-defined limits. The
particulate mass was determined gravimetrically after removal of uncombined water. The modification
employed involved substituting a PM2 5 cyclone for the PM10 cyclone normally used in this method. The two
devices were designed to characterize their respective particulate fractions at the same flow rate, which
allowed this modification to be made.
3.3.2.13	Visible Emissions
Visible emissions (opacity) from the ACB were monitored and recorded by the use of EPA Method 9 -
Visual Determination of the Opacity of Emissions from Stationary Sources, as described in 40 CFR
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Part 60, Appendix A-4 (U.S. EPA, 1996a). In this method, the opacity of emissions was determined visually
by an EPA certified observer (smoke reader).
3.4 Estimation of ACB Emissions
Some mathematical calculations must be performed in order to convert the concentration measurements
in the sampling duct into mass emission rates or emissions per unit mass of feed material. If the assumption
is made that the concentrations of the pollutants in the sampling duct are equal to the average concentration
of that pollutant leaving the firebox, then:
where mi is the mass emission rate of pollutant i, Ci is the concentration of pollutant i in on a dry basis, and
Qtotai is the volumetric flow rate of gas leaving the firebox, on a dry basis.
Qtotai is not a known quantity. The concentration of CO, CO2 and water vapor are, however, known, and
the feed rate and composition are known. Therefore, using material balance calculations, Qtotai can be
estimated using a carbon balance.
Note that QtotaI inherently contains a contribution due to ambient wind that did not actually pass through
the firebox as combustion air. However, this additional dilution does not affect the estimates of mass
emission rates or emission factors.
3.4.1 Estimation of Qtotai using a Carbon Balance
If we assume ideal gas behavior, by the definition of mole fraction,
where Yc^ is the mole fraction of CO2 in the exhaust gas of the ACB, ncfeed is the molar input rate of
carbon in the debris feed, nCair is the molar input rate of carbon in the air (due to CO2), nCash is the molar
generation rate of residual carbon in the ash, ncco is the molar emission rate of carbon due to CO in the
exhaust gas, and nCTHC is the molar emission rate of carbon due to hydrocarbons (as propane) in the
exhaust gas. The molar emission rate of carbon in the particulate matter is neglected for two reasons: 1)
carbon is not a measured compound, and 2) the recirculation zones in the ACB serve to increase the
burnout of carbon in the flyash to near completeness.
The various molar feed rate terms are calculated using Equations (3) through (7) as follows:
m,=C1Qtotal
(1)
(2)
m,
C,feed
n,
C,feed
Mc
(3)
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nc,air
YcO^rPQ,

total
RT
(4)
_ mc,ash
C,ash ~ T,7
Mc
(5)
fl —
"c^co
YcoPQtotd
RT
(6)
n.
_ 3YmcPQ,
total
RT(1~Yh,o)
(7)
where tncfeed is the mass feed rate of carbon into the ACB due to the debris being burned, Mc is the
molecular weight of carbon, P and T are the pressure and temperature at standard conditions, R is the ideal
gas constant, Yco^air is the mole fraction of CO2 in the ambient air, approximately 314 ppm
(http://chemistrv.about.eom/od/chemistrvfaqs/f/aircomposition.htm). mCash is the mass generation rate of
carbon in the bottom ash, Yco is the mole fraction of CO in the exhaust gas, Ymc is the mole fraction of
hydrocarbons (as propane) in the exhaust gas, and YH 0 is the mole fraction of water vapor in the exhaust
gas (since THC is measured on a wet basis unlike the other fixed combustion gases). Note that Equation
(4) is an approximation, because Qtotal is really the outlet flow rate, not the inlet flow rate. However, due to
the large quantities of ambient air contributing to QtotaI, any errors introduced due to this approximation are
negligible.
Substituting these terms for the molar rates in Equation (2) yields Equation (8),
m
Y =-
1 CO,
CJeed
Mn
Y
CO^air^Q total
RT
m
C,ash
Mn
YcpPQlotal
RT
3YTHCPQtotal
RT(l-YH o)
pQ,
total
RT
(8)
which upon simplification yields Equation (9).
Y =
1 CO,
X*1 CJeed mc,ash
y^T
McPQ,
>\ f
+
total
J
Y -Y -
1 C02,air 1 CO
37
rp}
V
(1 -Yh2o)j
(9)
Substituting the mass fractions of carbon in the feed and the ash (as measured by the proximate/ultimate
analysis) and solving for Qtotal, Equation (10) is produced, which can be used to estimate QtotaI based on
a carbon balance,
Qtotal
Cmfeed^CJeed m ash^C ,ash)PT
Mr
Y -Y
1 CO, 1 CO.,air 1 "*ฆ CO
37
, y ,	THC
~r 1 ~r
(10)
(1 -YHi0)j
P
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where mfeed is the measured mass feed rate into the ACB, Xc feed is the mass fraction of carbon in the
feed, mash is the ash generation rate, and Xc mh is the mass fraction of carbon in the ash.
Table 3-2 lists the results from estimating Qtotal using Equation (10). Note that the parameters for the C&D
ash were taken from the sample acquired the morning of Day 3 of testing since the last C&D ash sample
was acquired much later after the ash had completely burned out.
Table 3-2. Estimation of Total Flow Rate
Run
Feed
Rate
(Ib/hr)
Feed
Mass
Frac.
C
Feed
Mass
Frac.
H20
Feed
Mass
Frac.
H
Ash
Gen.
Rate
(Ib/hr)
Ash
Mass
Frac.
C
Ash
Mass
Frac.
H
YCO2
(dry)
YC02,air
(dry)
YCO
(dry)
YTHC
(wet)
YH2O
Qtotal
(EQ
10)
(dry
scfm)
Veg1
9600
0.349
0.27
0.04
1152
0.58
0.010
0.019
0.00031
0.0001
0.00001
0.034
76342
Veg2
9600
0.349
0.27
0.04
1152
0.58
0.010
0.012
0.00031
0.0001
0.00001
0.038
121589
Veg3
13600
0.349
0.27
0.04
1224
0.58
0.010
0.019
0.00031
0.0001
0.00001
0.054
114509
CD1
14800
0.349
0.27
0.04
1332
0.29
0.013
0.008
0.00031
0.0001
0.00001
0.032
327788
CD2
18400
0.349
0.27
0.04
4600
0.29
0.013
0.010
0.00031
0.0002
0.00004
0.070
273234
CD3
9400
0.349
0.27
0.04
2350
0.29
0.013
0.006
0.00031
0.0001
0.00002
0.040
237562
3.4.2 Estimation of Mass Emitted per Unit Mass Feed
The mass emission of a given pollutant per mass of debris fed is calculated using the feed rate and pollutant
emission rate from Equation (1), as follows:
171
(11)
mfeed
where Ei is the estimated emissions of pollutant i per unit mass of debris burned. This quantity is in units
as reported in the EPA's AP-42 database of emission factors (U.S. EPA, 1995a).
3.5 Quality Assurance Considerations
This project's main objective was to evaluate emissions from an ACB. This objective puts it into the method
development project category, fitting Quality Assurance (QA) Category III. However, this project has high
visibility and includes enforcement and regulatory implications, with data that will be used to perform a risk
assessment. Therefore, where feasible, QA Category II requirements were adhered to, including an on-site
technical systems audit conducted by EPA QA staff. The project utilized the general guidance of EPA's
Quality Assurance Handbook for Air Pollution Measurement System: Volume III - Stationary Source-
Specific Methods. The ultimate decision to permit or prohibit the burning of C&D debris in ACBs is beyond
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the scope of this project. However, it is important to note that current regulations for solid waste incineration
units may not allow this practice due to the stringency of the regulations and the lack of approved testing
procedures that could be used to demonstrate compliance with the regulations. The objective of this work
was to provide objective and reliable data on the types and relative order of magnitude of emissions from
the process.
This pilot project has measured a number of pollutants that are likely to be emitted into the air during the
combustion of both vegetative and demolition debris in an ACB. Some of these pollutants are known to
cause adverse health effects under certain conditions and durations of exposure. Risk assessment is a tool
EPA uses to estimate the likelihood that adverse health effects may occur in people exposed to pollutants
present in the environment as a consequence of releases from manmade sources. Risk assessment will
be applied here to evaluate the potential human health risk that may be associated with exposures to
pollutants emitted from the ACB. The risk assessment process consists of the following four steps:
1.	Hazard Identification: the toxicological evaluation of adverse human health effects of a chemical;
2.	Dose-response Assessment: the process of characterizing the relationship between the dose of a
chemical and the incidence of an adverse health effect in the exposed populations;
3.	Exposure Assessment: the process of estimating the ways in which people become exposed to a
chemical when the chemical is released into the environment from a source. Exposure assessment
involves estimating or measuring the chemical concentrations in the environment as well as estimating
the intensity, frequency and durations of human exposures to the chemical; and
4.	Risk Characterization (the quantitative expression of the likelihood of an adverse effect occurring in
populations exposed to the chemical contaminant).
This report uses the term 'risk driver' to describe the identification a pollutant or set of pollutants that
constitutes most of the potential human health risk in the context of the pollutant emissions from the ACB
and subsequent human exposures. The measurement protocols employed in this project are known to have
a relatively high degree of accuracy and precision. How well these measurement protocols translate to
ACBs is not well known, however. The ACB does not have a conventional stack, where the concept of stack
diameters is meaningful, and there are no validated methodologies to withdraw a representative sample
from an ACB. In addition, the representativeness of the conditions tested, including the debris composition
and condition, compared to normal daily operation over the lifetime of this or potential future cleanup
programs, was unknown and largely unknowable. The composition of the C&D debris is expected to vary
substantially with regard to the constituents of greatest concern (lead, mercury, arsenic, and chlorine) and
to the parameters of key importance to combustion effectiveness (energy and moisture content). Therefore,
although the ACB feed materials and operating conditions were likely to lie within a relatively consistent
envelope, the widely varying composition of the debris and transient nature of the feeding operation were
expected to lead to substantial variability in emissions.
Currently, visible emissions (i.e., opacity) are the only regulatory criteria specified forthe operation of ACBs
burning vegetative debris. Opacity is limited to 10% on a 6 minute period (40 CFR Part 62). The critical
measurement parameters necessary to adequately evaluate the most important environmental impacts of
using ACBs for debris cleanup are as follows:
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•	Emission rate for Hg, As, and Pb (potential risk drivers);
•	Emission rate for CO2/CO (necessary for estimation of total mass emission rate for other species);
•	Emission rate for filterable PM (potential risk driver);
•	Emission rate of asbestos (potential risk driver);
•	Emission rate of dioxins/furans (potential risk drivers);
•	Total sample flow rate (necessary for calculation of total mass emission rate for other species);
•	Wall temperature (parameter potentially capable of routine measurement by ACB operators); and
•	Visible emissions (i.e., opacity), (the only operating parameter currently used to regulate ACB
operation).
For each set of test conditions (i.e., waste feed type), the measured values over all of the individual tests
are reported. The measured values, corrected for dilution to a 12 percent CO2 basis, are also reported.
Correction for dilution to a 7% O2 basis was desirable. However, due to the near-ambient levels of oxygen
that were observed in the sampling duct, this calculation would have created large errors in the corrected
results. For conventional combustion systems, where O2 concentrations are in the 7% range and CO2
concentrations are in the 12% range, the dilution-corrected concentrations are similar. Average values for
the dilution-corrected concentrations are also reported, but their ultimate use may not adequately represent
long-term emissions given the expected high variability associated with the waste. Subsequent use of these
data must be done with the understanding that these tests are limited in scope.
Due to expected variation in the feed/performance of the ACB, triplicate sampling runs (performed
successively) will not yield a viable method precision estimate. Concurrent sampling runs are prohibited, in
most cases, by a lack of sufficient sampling ports. Performance criteria for precision are therefore limited
to two of the methods - M26A for hydrogen halide acid gases and VOCs by modified EPA Method 0040.
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4. Test Results
This section presents the test results. Detailed test results can be found in Appendix A, the field data can
be found in Appendix B, and the analytical reports themselves can be found in Appendix C. Appendix D
contains other supporting documents.
4.1 ACB Feed Material and Operational Overview
4.1.1 Daily Account
4.1.1.1	June 20 - 22, 2008
Five piles of vegetative material were staged near the ACB, referred to as the "inner perimeter", for loading
into the ACB with an excavator. The total weight of this material was 82 tons. This vegetative material
consisted primarily of wood from residential trees that had died due to contact with salt water; the wood had
been cut at least 2 months prior to the test. Refer to the proximate and ultimate analysis of wood samples
(see Section 4.5.1) for further details on this feed stock. The beginning of a given run is defined as the time
where sampling was initiated on the series of sampling trains, and the end of the run is defined as the time
where sampling was terminated on the series of sampling trains. The ACB unit was in operation prior to the
initiation of the run and after termination of the run. A period of operation was maintained prior to the
initiation of each run. During the periods between runs, the ACB was allowed to idle at temperature until
approximately 20 minutes before the next run. Mass feed estimates are based on average feed rates
throughout an entire day of testing.
4.1.1.2	June 24, 2008 (First day of ACB testing, Vegetative Runs (Veg Run) 1 and (Veg Run) 2)
For the first day of testing, three piles of the vegetative material totaling approximately 62 tons were used
as the feedstock to the ACB. However, approximately 5 tons of waste vegetative material from these three
piles were removed from the inner perimeter, due to their undesirable characteristics (e.g., too large, too
sediment- or soil-laden). Therefore, a total of 57 tons was fed to the ACB during the day, which began at
0730 when the ACB was first lit, proceeded through the first run with vegetative debris (Veg Run 1) and
ended at 1850, when emissions sampling for Veg Run 2 was completed. This is a time period of 11.3 hours,
although the ACB was one-fourth filled with wood, using material from the first 3 piles, prior to being lit at
0730. The emissions sampling for Veg Run 1 began at approximately 0945, and finished at 1345. Veg Run
2 began at 1450, and lasted until 1850. In the interim period between sampling runs, the ACB was still
being fed vegetative debris. Material was fed to the ACB using an excavator with a "thumb" attachment,
approximately every 15-20 minutes.
In the afternoon on June 24, three additional piles of vegetative material, totaling 31 tons, were brought to
the inner perimeter.
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4.1.1.3	June 25, 2008, Morning (Veg Run 3)
Based on the total amount of vegetative material that had been brought to the inner perimeter so far (82 +
31 = 113 tons), less the amount fed to the ACB (57 tons), less the waste material removed from the inner
perimeter (5 tons), the total amount of vegetative material at the inner perimeter at the start of this day was
estimated to be 51 tons. This material was aggregated into 4 piles, with the first pile weighing approximately
21 tons (this was material left over from the previous day, which was brought to the inner perimeter prior to
June 23), and the three other piles weighing approximately 10 tons each. At 0710, feeding of vegetative
material began (emissions sampling for Veg Run 3 did not begin until 0815), and feeding stopped at 1215,
when the emissions sampling for Veg Run 3 stopped. During this approximately 4-hour time period, the first
three piles (weighing 41 tons) of vegetative matter were fed to the ACB, except for approximately 5 tons of
undesirable vegetative materials from these 3 piles that was removed from the inner perimeter. Therefore,
about 36 tons of vegetative material was fed over approximately 5 hours. Additionally, it is estimated that
about 10 tons of vegetative material remained in the inner perimeter after Veg Run 3 was completed.
4.1.1.4	June 25, 2008, Afternoon (1st C&D Run 1, House 1)
At about 1330, ACB operation contractors started bringing C&D material from House 1 to the inner
perimeter. The debris from House 1 consisted of structural materials as well as the contents of the house,
since House 1 was not gutted. The material was roughly segregated based on material type (metals, bricks,
furnishings, wood, and sediment) to minimize non-combustible loading in the ACB. The materials were
recombined as they were brought into the inner perimeter. At around 1505, the feeding of this debris to the
ACB began, with C&D Run 1 commencing at 1520. Over the course of the afternoon, 4 piles of C&D were
brought to the inner perimeter, with a total combined weight of 42 tons. Starting at around 1840, another
pile of vegetative debris, weighing 11 tons, was brought to the inner perimeter as well. The feeding to the
ACB stopped around 1910, except for small pieces of debris that had fallen to ground and were fed
manually. C&D Run 1 ended at 1920. Overthe course of the afternoon operations (from 1505 to 1910), two
of the C&D piles were fed to the ACB, for a combined weight of 21 tons.
For the vegetative material (fed with the C&D as supplemental fuel), it is a bit more difficult to estimate how
much was fed to the ACB during this same time period, since the wood piles were moved around the inner
perimeter, aggregated, and some wood was separated again because the pieces were too large in diameter
to feed, and the operator loading the ACB picked material from different piles to ensure the right size logs
were being fed as needed. However, it is estimated that about half of the vegetative material within the
perimeter during this run (21 tons were in the perimeter) was fed to the ACB during this time period. To
further corroborate this estimate, in a conversation with representatives of Air Burners LLC during this test
run, their intention to feed about 10 tons of vegetative material to the ACB during this period was indicated.
Thus at the end of the day, 11 tons of vegetative material was estimated to remain in the perimeter.
4.1.1.5	June 26, 2008 Morning (C&D Run 2; House 1)
Based on the above analysis, an estimated 21 tons of C&D was available to start with in the morning. At
the beginning of the day, this C&D material began as 2 piles, but the C&D material was eventually combined
into one pile by around 1000. C&D Run 2 sampling began at 0900. Starting around 1100, another C&D pile
of about 14 tons was brought in, although only a minimal amount of material from this pile was used to feed
the ACB during C&D Run 2. At 1200, feeding to the ACB and emissions sampling stopped temporarily, due
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to rain and lightning from a severe thunderstorm. When the thunderstorm persisted, at 1300, C&D Run 2
at the 3-hour point was terminated due to the continued rain and lightning. At this point, very little remained
of the combined 21-ton pile (estimated 2 tons remaining). Therefore, approximately 19 tons of C&D were
fed to the ACB in this 3-hour test period (feeding of C&D debris and C&D Run 2 began at around 0900 and
stopped at 1200).
A synopsis of the vegetative material balance during this C&D Run 2 follows. After removal of the ash in
the ACB, kindling (small logs) was stoked into the ACB from about 0800 to 0830. A small pile of kindling
(from all the wood available in the perimeter) had previously been assembled for this purpose, although the
mass of this pile is unknown. At 0900 emissions sampling for C&D Run 2 commenced. As with the previous
test run, an unknown amount of vegetative debris was fed during this test run, since there were various
piles of wood aggregated within the perimeter. However, most of the wood within the perimeter at the start
of the day (11 tons) was fed to the ACB, save for the waste material and oversize logs. This waste
vegetative material and wood pieces too large to feed were removed from the perimeter, with a total weight
removed estimated at 5 tons. Additional wood (6 tons) was brought into the perimeter around 1100 and
placed in a separate pile. This wood was used for tamping down the C&D debris in the ACB; only a small
portion of this pile was fed to the ACB.
4.1.1.6 June 26, 2008 Afternoon (C&D Run 3; House 2)
Due to concerns over not having sufficient feed material to complete C&D Run 3, the test team decided to
use debris from another gutted house (referred to as House 2) to provide emissions data for the burning of
C&D debris from a house in which the internal materials and furniture had been removed. However, due to
the severe thunderstorm during the early afternoon, this material could not be weighed prior to bringing it
to the inner perimeter. The un-weighed House 2 C&D debris was pushed into the inner perimeter using a
bulldozer, bypassing the scale, to protect the landfill cap. Feeding to the ACB began at 1530 and ended at
1945; emissions sampling for C&D Run 3 began at 1615 and ended at 1945. The feed material was muddy
and wet and fed to the ACB using smaller, more frequent loads.
The C&D from House 2 was amassed in a large pile on the side of the ACB opposite from the C&D from
House 1. The piles of C&D from the two houses were separate. The approach for estimating the amount
of House 2 C&D material that was fed to the ACB during C&D Run 3 is based on a mass balance for the
total House 2 material brought on site. The total weight of House 2 C&D material that remained after the
test (weighed by the use of a dump truck during the week of July 7, 2008, when the landfill cap was dry
enough to sustain heavy equipment) was 95 tons. The total volume of House 2 C&D remaining on-site after
the test was determined to be 201 yds3 (based on the known dump truck volume and the number of truck
loads), thus giving a density of 0.47 tons/yd3.
Three 80 yd3 trucks of House 2 C&D material were brought on site on June 26, 2008. Using the density
figure determined above, the estimate for the total weight of material brought on site is 3 * 80 yds3 * 0.47 =
113 tons. Therefore, the estimated amount of House 2 C&D fed to the ACB is 113 - 95 = 18 tons.
Only a small amount of vegetative material was fed to the ACB during C&D Run 3. The approach used for
estimating the mass of vegetative material fed to the ACB was to count the number of times the excavator
loaded the vegetative material into the ACB throughout the test run, and estimate how full the bucket on
the excavator was for each load (it is estimated that the bucket was only one quarter full of material). Using
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the bucket volume of 2.5 yd3, and assuming a density of 0.5 tons/yd3 for wood, the following estimate is
made:
6 buckets * 0.25 bucket * 2.5 yd3/bucket * 0.5 ton/yd3 = 2 tons
4.1.2 Overall Mass Balance for Vegetative Material
Table 4-1 is a summary of the overall mass balance for vegetative material as described in previous
sections, which was used as the sole feedstock for the three vegetative test runs, and as supplemental fuel
for the three C&D tests.
Table 4-1. Inner Perimeter Material Balance for Vegetative (Wood) Material in Tons
Date
Test Run
Veg Material
Brought in
Fed to ACB
Removed from
Perimeter as
Waste or Too Big
to Feed
Remaining
Amount at
End of Day or
Test Run
June 20-22, 2008

82
0
0
82
June 24
Veg Run 1
Veg Run 2
31
57
5
51
June 25 (morning)
Veg Run 3
0
36
5
10
June 25 (afternoon)
C&D Run 1
11
Estimated at 10 tons
0
11
June 26 (morning)
C&D Run 2
6
Estimated at 10 tons
5
2
June 26 (afternoon)
C&D Run 3
0
Estimated at 2 tons
0
0
Total

130
115
15
0
ACB operation contractors reported that 12 tons of vegetative debris remained in the inner perimeter, as
determined by weighing dump truck loads during the week of July 7, 2008. This result is in contrast to the
mass balance approach discussed above which resulted in an estimate that zero tons of vegetative material
would remain. To account forthis error, the 12 ton discrepancy was distributed equally between the amount
of material brought into the inner perimeter and the amount removed (fed to ACB or removed as waste).
The revised vegetative material feed estimates, based on this error distribution, are shown in Table 4-2
below, accounting for the 12 tons of vegetative feed remaining at the end of the test.
Table 4-3 below is a summary of the mass balance for the C&D debris for House 1 only, based on the
above discussion.
As with the vegetative material, the actual amount of House 1 C&D material remaining after the test, as
reported by ACB operators (weighed afterwards when the landfill cap was dry enough, during the week of
July 7, 2008, using a dump truck), was different from the estimated value per the above discussion. The
ACB operators determined that 20 tons of material remained, whereas in the mass balance approach
described above, 16 tons was estimated to remain. To account for this error, the 4 ton discrepancy was
equally distributed, and the revised feed estimates based on this error distribution are shown in Table 4-4.
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Based on the revised material feed balance estimates as shown in Tables 4-2 and 4-4, along with the time
periods in which these amounts were fed (discussed in the above narrative), the mass feed rates for the
vegetative and C&D debris for each test run are summarized in Table 4-5, below. Table 4-5 also contains
the total mass fed to the ACB each day, including time periods when emissions tests were not conducted.
Table 4-2. Revised Inner Perimeter Material Balance for Vegetative (Wood) Material in Tons
Date
Test Run
Material
Brought in
Material
Fed to
ACB
Material Removed
from Perimeter as
Waste or Too Big to
Feed
Material Remaining
at End of Day or
Test Run
June 20-22, 2008

86
0
0
86
June 24
Veg Run 1
Veg Run 2
32
54
5
59
June 25 (morning)
Veg Run 3
0
34
5
20
June 25 (afternoon)
C&D Run 1
12
9.5
0
22.5
June 26 (morning)
C&D Run 2
6
9.5
5
14
June 26 (afternoon)
C&D Run 3
0
2
0
12
Total

136
109
15
12
Table 4-3. Inner Perimeter Material Balance for House 1 C&D Debris Material in Tons
Date
Test Run
Material
Brought In
Material
Fed to
ACB
Material Removed
from Perimeter as
Waste
Material Remaining at
End of Day or Test Run
June 25 (afternoon)
C&D Run 1
42
21
0
21
June 26 (morning)
C&D Run 2
14
19
0
16
Table 4-4. Revised Inner Perimeter Material Balance for House 1 C&D Debris Material in Tons
Date
Test Run
Material
Brought In
Material
Fed to
ACB
Material Removed
from Perimeter as
Waste
Material Remaining at
End of Day or Test Run
June 25 (afternoon)
C&D Run 1
43.5
20
0
23.5
June 26 (morning)
C&D Run 2
14.5
18
0
20
Table 4-5. Summary of Feed Rates (tons/hour) for Each Test Run
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Date
Test Run
Vegetative Feed Rate
C&D Feed Rate
Total Mass Fed
during Day (tons)
June 24
Veg Run1
Veg Run 2
4.8
0
54
June 25 (morning)
Veg Run 3
6.8
0

June 25 (afternoon)
C&D Run 1 (House 1)
2.4
5
64
June 26 (morning)
C&D Run 2 (House 1)
3.2
6

June 26 (afternoon)
C&D Run 3 (House 2)
0.5
4.2
48
4.1.2.1 Ash Production
Around 0600 on June 25, ash (still hot; see Figure 4-1) from the previous day was removed from the ACB
and placed in a 40 yd3 roll-off container. The weight and volume were 2.5 tons and 5 yd3, respectively,
giving a density of 0.5 tons/yd3. Roughly 12 inches of ash was left in the ACB to facilitate the ignition of the
new vegetative material for the testing that day. With firebox dimensions of 27 feet 2 inches long by 8 feet
5 inches wide by 8 feet 1 inch high, the remaining ash volume was 8.5 yd3, or 4 tons. The total ash produced
on June 24 was thus 6.5 tons, 12 percent of the total material fed that day (54 tons).
At 0600 on June 26, ash from the previous day's burn was removed from the ACB. The weight and volume
were 6 tons and 14 yds3, giving a density of 0.43 tons/yd3. As on the previous day, roughly 12 inches of
ash was left in the ACB to provide residual heat to facilitate the ignition of the new material for the testing
that day. However, since 12 inches of ash was in the burner to start with, the amount of ash that was
removed was approximately the same as the amount of ash that was produced on June 25. The ash
produced was thus approximately 9 percent of the total material fed that day (63.5 tons).
On June 27 in the morning, all of the ash was removed from the ACB and placed in a roll-off container, of
Ash at a volume of 24 yds3 (18.9 tons) was removed (density of 0.79 tons/yd3). Since there had been 12
inches of ash in the ACB at the start of the testing the previous day, this amount of ash (8.5 yd3, which
equals 6.7 tons based on the above density) is subtracted from the above figure. Therefore, 12.2 tons of
ash was produced on June 26, 25 percent of the total material (47.5 tons) fed that day.
Note all the ash weights and volumes described above were determined during the week of July 7, 2008,
after the test had been completed. The ash from each previous day's test was placed in separate 40 yd3
roll-off containers. The ash weight was determined as the difference between the weight of the roll-off
container when filled with ash and when empty.
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Figure 4-1. Removal of Ash from the ACB the Morning Following a Day of Testing
4.1.3 Debris Weighing Procedure
The materials placed in the inner perimeter (also waste material removed from the inner perimeter) that
were fed to the ACB during the three vegetative test runs and C&D test runs 1-2 was weighed with an axle
scale (LODEC L3040 Portable Axle Scale, electronic load cell, 50 ton capacity, calibrated 6/4/2008) (see
Figure 4-2), Two front-end loaders were used to move and weigh this material. The weight of each front-
end loader, whether empty (tare) or loaded, was determined as the combined weight of each axle reading.
The material mass was determined as the difference between the tare and loaded weight. Figure 4-3 is a
photograph of the front axle being weighed when loaded with vegetative material. The readout for each
axle weight, and the calculated weight of each load, was manually recorded in a notebook. The loads were
then tallied for each material pile.
Figure 4-2. Axle scale
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Figure 4-3. Loaded Front Axle Being Weighed
The ash and feed material remaining after the test were weighed with roll-off containers and dump trucks,
respectively.
4.1.4 Other Process Operation Notes
The following additional noteworthy items related to the ACB operation during the test are meant, to
supplement the other discussions (e.g., feed, ash, burner airflow, etc.) in this section of the report.
4.1.4.1	June 24, 2008
0730: With ACB filled with vegetative matter, diesel fuel was sprayed onto the material and lit using a
propane torch.
0930: The first load of C&D material was brought to the site; workers began separating non-combustible
materials such as bricks, aluminum, shingles, etc.
1345:	A railroad tie was inadvertently fed to the ACB.
1815:	Water was sprayed on C&D piles for dust suppression.
4.1.4.2	June 25, 2008
0645:	Ash sample taken
1035:	Wood sample taken; another taken at 1145.
1430:	Replaced thermocouple located at ACB sample scoop.
1450:	Started raining lightly - sampling continued.
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1515: The thermocouple at the sample scoop was lost again when the loader bucket hooked the
thermocouple wire.
1650: Due to a change in wind direction, feeding of ACB was suspended for about 5 minutes, although
emissions sampling continued.
1900: A roll of carpet (approximately 10 feet long by 1 foot in diameter) was fed to the ACB.
4.1.4.3 June 26, 2008
0650: Ash sample taken while there was still enough ash from the C&D material.
0745: Another thermocouple was installed on the sample scoop.
0945: C&D material from house 2 arrived on site.
1200: Sampling and feeding stopped due to rain and lightning, which lasted until ~ 1500. After the rain
stopped, operations continued and C&D Run 3 proceeded.
4.1.5 Combustion Air Fan Speed and ACB Exhaust Airflow
Although the monitoring of the ACB blower fan speed was not included in the QA project plan (QAPP) the
ACB blower fan speed was manually recorded. Blower fan speed could be used as an indication of
combustion air flow and potentially exhaust air flow, since actual ACB exhaust gas velocity or flow was not
measured during the test. (Refer to Section 3.4 for the discussion of exhaust gas flow estimation methods.)
However, velocity profile measurements were made on the same ACB model burning vegetative material
during a previous scoping test conducted in 2005 (Miller and Lemieux, 2007).
Air Burners personnel operated the ACB during the test, including periodic adjustment of the fan speed and
providing direction to the equipment operator about what, how often, and where to place the feed to optimize
combustion. The following text summarizes information provided by Air Burners personnel regarding the
planned and actual operation of the diesel engine (which rotates the fan), the fan itself, and the combustion
air flows during the test.
•	At typical operations, the burner combustion air flow rate is approximately 9,000 SCFM.
•	The maximum fuel usage for the engine is about 3.2 gallons per hour, but more typically runs at 2.9
gallons per hour at 2000 RPM fan speed. The engine is exhausted near the intake for the combustion
air flow.
•	Air Burners personnel indicated that during the feeding of C&D material, the fan speed would be
lowered to 1800 RPM. However, vegetative material would be fed alternately with the C&D, and when
this situation occurred, the fan speed would be raised to 2000 - 2200 RPM.
•	In e-mails following the test, Air Burners personnel reported that, in general, during the test they were
running at 2100 RPM for the vegetative burns and at 2000 RPM for the C&D test runs. They did run at
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lower RPM ranges for short periods of time during startup, but otherwise they were operating at either
2100 or 2000 RPM settings the majority of the time.
A few actual fan speed readings were taken during the test program; the times they were taken and other
related information are shown in Table 4-6 below.
Table 4-6. Burner Fan Speed Readings and Notes on Fan Operation
Date
Test Run
Time
Fan speed (RPM)
Notes
6/24/08
Veg Run 1
1205
1300
1320
2400
Blower fan off due to technical
malfunction
Blower fan back on
6/25/08
Veg Run 3
0845
2200

6/26/08
C&D Run 2
0920
2000

The ACB combustion airflows, as a function of fan speed and as reported by Air Burners personnel, are
listed below:
•	2400 RPM = 10,200 SCFM
•	2100 RPM = 8800 SCFM
•	1800 RPM = 7600 SCFM
4.2 Test Periods
Table 4-7 shows the start and stop times of the various runs.
Table 4-7. Run Start and Stop Times
Run
Date
Start Time
Stop Time
Veg Run 1
June 24, 2008
945
1345
Veg Run 2
June 24, 2008
1532
1847
Veg Run 3
June 25, 2008
900
1220
C&D Run 1
June 25, 2008
1520
1920
C&D Run 2
June 26, 2008
900
1215
C&D Run 3
June 26, 2008
1615
1945
Times of collection for all temperature and CEM data were adjusted to local (Central Daylight) time.
Figures 4-4 through 4-9 are Gantt charts detailing the timing of the burns and sampling runs.
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Task Name
Tue Jun 24
6 AM 7 AM 8 AM 9 AM 10 AM 11AM 12 PM 1PM 2 PM 3 PM 4 PM 5 PM 6 PM 7 PM 8 PM 9 PM
24 June 2008 - Veg Debris Feed

Veg Rim 1

M23
M23
M0010
MO010
M 5/2 6 A
M5/26A
M29
M29
CARB M501

M201 A/202
M201 A/202
M9
M9
OEMs

Figure 4-4. Veg Run 1 Activity Timeline
Task Name
Tue Jun 24
6 AM 7 AM SAM 9 AM 10 AM 11AM 12 PM 1PM 2 PM 3 PM 4 PM 5 PM 6 PM 7 PM 8 PM 9 PM
24 June 2008 -Veg DebrisFeed

Veg Run 2

M23

M0010

M 5/2 6 A
M5/26A
M29
M29
N/A (CARB M501)
0 NA (CARB M501)
N/A (M201 A/202)
ฎ N A (M201 A/202)
M9
hV}
CEMs

Figure 4-5. Veg Run 2 Activity Timeline
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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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Task Name
Wed Jun 25
6 AM 7 AM SAM 9 AM 10 AM 11AM 12 PM 1PM 2 PM 3 PM
25 June 2008 - Veg Debris Feed

Veg Run 3

M23

M0010

M 5/2 6 A
M526A
M29
M29
GARB M501
CARBM501
M201A<202
M201A202
M9
M9
OEMs

N/A (Asbestos)
0 H A ( Asbestos)
Figure 4-6. Veg Run 3 Activity Timeline
Task Name

1 PM 2 PM 3 PM 4 PM 5 PM 6 PM 7 PM 8 PM 9 PM
25 June 2008 - C&D Debris Feed

C&D Run I

M23

M0010

M 5/2 6 A
M5.26A
M29
M29
CARB M501

M201 A/202
M201A 202
M9
MO
CEMs

Asbestos
Asbestos
Figure 4-7. C&D Run 1 Activity Timeline
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Task Name
Thu Jun 26
6 AM 7 AM SAM 9 AM 10 AM 11AM 12 PM 1PM 2 PM
26 June 2008 - C&D Debris Feed
i;Jim*MM:- *i is Feed
C&D Run 2

M23
M23
M0010
MO010
M 5/2 6 A
M5.26A
M29
M29
CARB M501
CARB M501
M201 A/202
M201A 202
M9
MO
CEMs

Asbestos
Asbestos
Figure 4-8. C&D Run 2 Activity Timeline
Task Name

1 PM 2 PM 3 PM 4 PM 5 PM 6 PM 7 PM 8 PM 9 PM
26 June 2008 - C&D Debris Feed

C&D Run 3

M23

M0010

M 5/2 6 A
M5/26A
M29
M29
CARB M501
CARB M501
M201 A/202
M201A 202
M9

CEMs

Asbestos
Asbestos
Figure 4-9. C&D Run 3 Activity Timeline
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4.3 CEMs
Table 4-8 shows the average of the raw concentrations determined by CEMs over the nominal test
durations. All CEM measurements were on a dry basis except THC.
Table 4-8. Raw CEM Concentrations for Air Curtain Burner Tests
Run
O2 (%)
CO2 (%)
CO (ppm)
NOx (ppm)
SO2 (ppm)
THC (ppm)
Veg Run 1
19
1.9
56
18
5.3
9.3
Veg Run 2
20
1.2
72
13
2.1
8.9
Veg Run 3
19
1.9
119
24
0.7
10
C&D Run 1
20
0.8
72
13
6.5
12
C&D Run 2
20
1.0
150
13
29
39
C&D Run 3
21
0.6
99
6.4
5.6
22
In order to compare "apples to apples" when examining both the replicate runs and the different test
conditions, it is important to account for the effect of ambient dilution air (drawn in by the sampling scoop,
or entrained into the unit itself) on the measurements. Normal U.S. regulatory reporting for incinerators
typically mandates correcting emissions data to 7 percent oxygen. However, the formula for calculating the
corrected emissions is susceptible to very large errors when the oxygen concentrations in the samples
approach ambient levels, as was the case for these data. So for the purposes of this analysis, the CEM
data have been corrected to 12 percent CO2, which is the method used in the Canadian regulations.
Correcting emissions based on CO2 does not introduce significant errors when sampling at near ambient
oxygen concentrations. Note that for most conventional combustion systems, correcting to 7 percent O2
and 12 percent CO2 yields similar results. Note also that when calculating mass emissions rates or emission
factors (see Section 5), the raw pollutant concentrations are used, so the method of correcting for dilution
does not affect the numbers that will eventually be used as the source term in any risk assessment activities.
Looking at the CO2 data in particular, and the O2 data to a lesser extent, and comparing the results from
Day 1 (which was a calm day) and Days 2 and 3 (which were much windier days), it is readily apparent that
the ambient wind speed and wind direction played a role in how much effluent gas was pulled into the
sampling scoop. However, as explained below, this external influence appears not to have adversely
impacted the measurements. Detailed meteorological data on the wind speed and ambient conditions will
be published in a separate report along with the air monitoring data.
Table 4-9 shows the average of the CO, NOx, SO2, and THC, corrected to 12 percent CO2. Again note that
all CEM measurements are on a dry basis, with the exception of THC. SO2 concentrations on Veg Run 3
and C&D Run 1 may have been slightly affected by an out-of-specification post-test bias check on June 25.
This situation was corrected for the following day's testing.
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Table 4-9. CEM Concentrations Corrected to 12 Percent CO2
Run
CO (ppm)
NOx (ppm)
SO2 (ppm)
THC (ppm)
Veg Run 1
364
118
34
60
Veg Run 2
701
126
20
87
Veg Run 3
754
151
4
64
C&D Run 1
1122
203
101
193
C&D Run 2
1824
153
347
470
C&D Run 3
1876
121
107
412
Plots of the dilution-corrected CEM data are shown in Figures 4-10 through 4-13. The following discussion
applies to the data as corrected to 12 percent CO2.
250 n
Veg Run 1 Veg Run 2 Veg Run 3 C&D Run 1 C&D Run 2 C&D Run 3
Run
Figure 4-10. NOx Concentrations Corrected to 12 Percent CO2
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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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2000
Veg Run 1 Veg Run 2 Veg Run 3 C&D Run 1 C&D Run 2 C&D Run 3
Run
Figure 4-11. CO Concentrations Corrected to 12 Percent CO2
400
350
300
250
200
150
100
50
0
1
1
1
1
ฆ - 11
11
Veg Run 1 Veg Run 2 Veg Run 3 C&D Run 1 C&D Run 2 C&D Run 3
Run
Figure 4-12. SO2 Concentrations Corrected to 12 Percent CO2
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500
450
400
350
300
250
200
150
100
50
0
Veg Run 1 Veg Run 2 Veg Run 3 C&D Run 1 C&D Run 2 C&D Run 3
Run
Figure 4-13. THC Concentration Corrected to 12 Percent CO2
To examine the CEM data, it makes sense to examine the NOx data first, since the NOx data will give an
initial assessment of how well the sampling scoop worked across varying ambient conditions. Since the
feed materials both for the vegetative debris and for the C&D debris contain little fuel nitrogen (and what
fuel nitrogen is present is not expected to be significantly different between the two feedstocks - see Table
4-10), the majority of the NOx emissions should be due to thermal NOx, mostly a function of the firebox
temperature. Since the firebox temperature generally ranged from 1300 to 1800 ฐF across all tests, as long
as the sampling was generally consistent in spite of ambient conditions (e.g., wind speed, wind direction),
then NOx should not vary significantly across all test conditions.
If we examine Figure 4-10, NOx measurements showed relatively little variation among test conditions and
among replicate runs (when compared with other continuously monitored gases). This consistency in the
NOx measurements suggests that the ambient wind conditions, although affecting the relative amount of
dilution air entering the scoop, did not impact the overall measurements after accounting for dilution.
Therefore, once dilution is considered, observed differences both among test conditions and within test
conditions are likely to be real and not artifacts due to changes in wind speed and wind direction.
CO concentrations (Figure 4-11) were fairly consistent within test conditions. The CO emissions from the
C&D material are approximately a factor of 3 higher than the CO emissions from the vegetative debris.
SO2 concentrations are shown in Figure 4-12. In general, SO2 concentrations from the vegetative debris
were very low, on the order of 50 ppm, and there was not a significant degree of variation from run to run.
38

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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The C&D debris showed somewhat higher SO2 emissions, and much greater variability among runs, with
nearly an order of magnitude variation between the lowest and highest observed measurements. SO2
emissions on C&D Run 2 were significantly higher than all other runs. It is likely that something in the feed
throughout that run contributed to higher SO2 emissions. Analysis of the video record of the burns will be
done in the future to attempt to explain this observation.
THC measurements, shown in Figure 4-13, somewhat paralleled the observations seen with the CO and
SO2 measurements, with C&D Run 2 being high relative to C&D Run 1. Since THC is a measure of
incomplete combustion, it wouid be expected to track more ciosely with CO than SO2. As in the SO2
measurements, the THCs from the vegetative debris did not vary significantly, yet there was a factor of 5
difference between the lowest and highest THC measurements with the C&D debris.
Appendix A, Test Results, contains the raw CEM measurements plotted versus time. Looking at those plots
shows that the increased SO2 and THC emissions observed during C&D Run 2 persisted throughout the
test and were not an isolated transient that unduly influenced the average concentration.
4.4 ACB Temperatures
4.4.1 Time-Resolved Wall Temperatures
Figure 4-14 shows the locations of the thermocouples mounted on the walls of the ACB. The tips of the
thermocouples protruded approximately Y> inch into the firebox. A set of thermocouples was installed on
the side with the air inlet plenum and directly opposite, on the side without the air inlet plenum.
Figure 4-14. Location of Thermocouple Probes on ACB Walls
39

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Figures 4-15 through 4-19 show the time-resolved temperatures measured by the thermocouples mounted
on the walls of the ACB. Temperature data were not available for C&D Run 3. The yellow traces represent
the thermocouples mounted at the two lowest locations. These particular thermocouples start out in the
freeboard, and as the runs progress, become covered with the ash at the bottom of the ACB. Note that the
traces have fewer transient fluctuations once the thermocouples are buried in the ash. The temperatures
on the side with the plenum tend to be somewhat lower than the temperatures on the corresponding
thermocouples on the opposite side. This observation suggests that the cool air being introduced through
the plenum tends to cool the ACB on the side on which the air is introduced. In general, observed
temperatures from the C&D burns were lower than temperatures observed from the vegetative debris burns.
1800
S 1400
1200
1800
ฃ• 1600 -
To
S 1400 -
ro

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
SIDE OPPOSITE PLENUM	PLENUM SIDE
Figure 4-17. Wall Temperatures from Veg Run 3
SIDE OPPOSITE PLENUM	PLENUM SIDE
Figure 4-18. Wall Temperatures from C&D Run 1
1800
lT 1600
ง 1400
ro
2! 1200
3
ro
o. 1000
E
o
H 800 -
11:00
Time
1800 -
1600
1400
1200
Q. 1000
E
1800
^ 1600
| 1400
o 1200
| 1000
ฎ 800
600
16:00 17:00 18:00 19:00
Time
16:00 17:00 18:00 19:00
Time
1800
1600
1400
1200
1000
800
600
	Top (Fan End)
—	Middle (Fan End)
—	Bottom (Fan End)
	Top (Door End)
--- Middle (Door End)
	Bottom (Door End)
	Top (Fan End)
—	Middle (Fan End)
—	Bottom (Fan End)
	Top (Door End)
--- Middle (Door End)
	Bottom (Door End)
41

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Air Curtain Burner Performance Tests: Source Emissions Measurement Resuits
DRAFT Revision 5 • February 2010 • Contract No, EP-C-05-060 • Streams Task Order 72
1800
1600
| 1400
| 1200
13
1 1000
Q_
ฃ
ฎ 800
600

CO 1400
j.
E
ฎ 800
09:00
10:00 11:00 12:00
Time
Top (Fan End)
Middle (Fan End)
Bottom (Fan End)
Top (Door End)
Middle (Door End)
Bottom (Door End)
SIDE OPPOSITE PLENUM
PLENUM SIDE
Figure 4-19. Wall Temperatures from C&D Run 2
4.4.2 Average Wall Temperatures
Taking the average temperatures at each of the thermocouple locations over the duration of each of the
runs yields the temperature distributions shown in Figures 4-20 through 4-24, The average temperatures
on the plenum side appear to be generally lower than the temperatures on the side opposite the plenum.
Noting that Veg Run 1 was started with no ash in the firebox, and Veg Run 3 and C&D Run 2 were both
started after most of the ash was removed. As the ACB fills with ash, the average temperatures are
apparently lower.
<= 1200
<= 1300
<= 1400
<= 1400
<= 1500
<= 1500
<= 1600
1600
<= 1700
<= 1700
1800
> 1800
PLENUM SIDE
Figure 4-20. Average Wall Temperatures from Veg Run 1
42

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Air Curtain Burner Performance Tests: Source Emissions Measurement Resuits
DRAFT Revision 5 • February 2010 • Contract No, EP-C-05-060 • Streams Task Order 72
<= 1200
<= 1300
<= 1400
<= 1400
<= 1500
<= 1500
<= 1600
<= 1600
<= 1700
<= 1700
<= 1600
> 1800
PLENUM SIDE
Figure 4-21. Average Wall Temperatures from Veg Run 2
T  1800
PLENUM SIDE
Figure 4-22. Average Wall Temperatures from Veg Run 3
43

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Air Curtain Burner Performance Tests: Source Emissions Measurement Resuits
DRAFT Revision 5 • February 2010 • Contract No, EP-C-05-060 • Streams Task Order 72
<= 1200
<= 1300
<= 1400
<= 1400
<= 1500
<= 1500
<= 1600
<= 1600
<= 1700
<= 1700
<= 1800
> 1800
PLENUM SIDE
Figure 4-23. Average Wall Temperatures from C&D Run 1
™ <= 1200
™ <= 1300
<= 1400
ฆ	<= 1400
1 <= 1500
<= 1500
ฆ	<= 1600
™ <= 1600
ฆ	<= 1700
<= 1700
<= IfiOO
ฆฆ > 1800
PLENUM SIDE
Figure 4-24. Average Wall Temperatures from C&D Run 2
44

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
4.4.3 Sampling Scoop Temperature
The time-resolved temperatures from the thermocouple at the inlet to the sampling scoop are shown in
Figures 4-25 to 4-27. The scoop thermocouple was highly susceptible to damage due to radiative heat
transfer from the burning bed and physical contact with the feed material and heavy equipment. Because
of these factors, valid scoop data were only acquired from Veg Runs 1 and 2 and C&D Run 2. In general,
inlet temperatures to the sampling scoop were in the 600 to 800 ฐF range. Because the temperatures at the
top set of wall thermocouples inside the firebox were typically in the 1300-1500 ฐF range, it is readily
apparent that a significant amount of dilution air is being introduced into the gas stream being sampled,
either through air being entrained into the ACB or from dilution due to wind blowing across the top of the
unit.
300 -
10:00
11:00
12:00
13:00
Time
Figure 4-25. Sampling Scoop Inlet Temperature from Veg Run 1
45

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No, EP-C-05-060 • Streams Task Order 12
700 -
rp 600 -
E 500 -
400 -
300 -
16:00
16:30
17:00
17:30
18:00
18:30
Time
Figure 4-26. Sampling Scoop Inlet Temperature from Veg Run 2
1000 -
09:00	09:30	10:00	10:30	11:00	11:30	12:00
Time
Figure 4-27. Sampling Scoop Inlet Temperature from C&D Run 2
46

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
4.4.4 ACB Bed Temperatures
Figures 4-28 through 4-35 show the results from temperature measurements of the ACB bed made using
a prototype device that was placed in the bed of burning material and then generally removed 30 - 60
minutes later. The device is an in-house manufactured metal box 8 inches on a side with a protruding
thermocouple. The box is heavily insulated to protect the interior electronics (thermocouple data logger)
from the incinerator environment. The electronics embedded within the box record the temperature signals
from the thermocouple and voltage from the battery, which can later be recovered.
A number of these in-situ measurement devices were thrown into the ACB during the three days of tests,
but for various reasons, only the data shown here were available. In some cases, only a portion of the
recovered data was usable. For example, even with the insulating material, the electronics within the box
become heated and this heating of the electronics may lower the voltage of the battery. If the battery voltage
drops below a certain level, the temperature readings at that point become questionable. Therefore, the
data presented below represent only the temperature data considered valid, and the temperature data
which were judged to have been collected with inadequate battery voltage have been removed from these
charts.
In-situ Bed Temperature 062408B
1500
ซ 1000
(A
a>
O)
ฆg 500
0
9:50 9:57 10:04 10:12 10:19
time
Figure 4-28. ACB Bed Temperature Taken during the Morning of June 24, 2008 (Veg Run 1).
47

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
ln-situ Bed Temperature 062408C
2000
~_ 1500
ป
ฃ 1000
O)
0)
73 500
11:13 11:16
11:19 11:22
time
11:25 11:28
Figure 4-29. ACB Bed Temperature Taken during the Morning of June 24, 2008 (Veg Run 1).
In-situ bed temperature 062408D
a> 800
5, 600
ฆS 400
12:50
12:57
13:04
time
Figure 4-30. ACB Bed Temperature Taken during the Afternoon of June 24, 2008 (Veg Run 2).
48

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
ln-situ Bed Temperature, test062408F
2000
1500
1000
O)
0)
ฆc 500
i n—i—i i

—i ' ' 1 1 i i | i i i— *




0
15:21
15:28
15:36
time
15:43
15:50
Figure 4-31. ACB Bed Temperature Taken during the Afternoon of June 24, 2008 (Veg Run 2).
in-situ Bed temperature, test 062508A
2000
u. 1500

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
in-situ bed temperature, test 062608C
2000
u. 1500
tit
2 1000
O)
0)
ฆc 500
0 J
11:42
11:47 11:51
11:55 12:00 12:04 12:08
time
Figure 4-33. ACB Bed Temperature Taken during the Morning of June 26, 2008 (C&D Run 2).
in-situ bed temperature, test062608E
2000
u. 1500
tit
2 1000
O)
0)
ฆc 500



	







16:55 17:02 17:09 17:16 17:24 17:31 17:38 17:45 17:52
time
Figure 4-34. ACB Bed Temperature Taken during the Afternoon of June 26, 2008 (C&D Run 3).
50

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
19:33
Figure 4-35. ACB Bed Temperature Taken during the Afternoon of June 26, 2008 (C&D Run 3).
The following notes and observations pertain to the data shown in Figures 4-28 through 4-35:
•	Ambient temperatures were approximately 90 ฐF, as indicated by the initial temperature data in each
figure, recorded prior to placing the in-situ measurement device in the ACB.
•	Once the device was placed in the bed (the start of the temperature trace), a steep temperature rise
can be seen for a few minutes, at which point the rate of temperature increase diminishes or levels off.
•	Tests in which the all of the temperature data were valid, i.e., none of the data were removed due to
low battery voltage, are shown in Figures 4-29, 4-34, and 4-35. Note in these figures that the steep
drop in temperature at the end of the test was occurred when the device was removed from the bed
and then quenched in water.
•	Excluding the temperature data taken during the initial placement or removal of the device, bed
temperatures ranged between approximately 800 - 1700 ฐF, with the majority of tests having bed
temperatures stabilizing around 1500 - 1600 ฐF.
•	Because the duration of each test and the amount of time in which valid data were available varied, the
time scale for the figures (x-axis) is variable as well.
in-situ bed temperature, test062608G
1500

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
4.5 ACB Performance Test Sampling Results
4.5.1	A CB Ash Characteristics
The ash present in the ACB from the previous day's testing was sampled prior to initiation of subsequent
operation. The ash present in the bed after sitting overnight had the visual appearance of a charcoal-like
material. Normal ACB operation would involve movement of the ACB unit to a new location, allowing the
ash to achieve complete burnout while outside the ACB. In this case, however, due to space constraints,
the ash was removed using heavy equipment and the ACB unit was not moved. Subsequent runs were
initiated on the hot bed of ash left over from the previous day, and not until the completion of the tests was
the ash allowed to completely burn out prior to sampling.
Results from proximate/ultimate analysis performed by Standard Laboratories, Inc., for vegetative debris,
vegetative ash, and C&D ash are presented in Table 4-10. TCLP analysis (U.S. EPA, 1992) for metals was
also performed on the ash. These results are shown in Table 4-11. TCLP results indicated that the ash from
all samples could be disposed of as non-hazardous waste. Other than the final ash sample, acquired
several days after the burn, the ash had significant carbon content and heating value, consistent with its
charcoal-like characteristics.
4.5.2	ACB Combustion Gas Test Results
Duct concentrations of the target analytes are reported in the following subsections. Note that
concentrations below the detection limits are listed as "ND - not detected" in the following tables. If the
detection limits are needed, please see the corresponding data tables in Appendix A, Test Results.
4.5.2.1 Dioxin/Furan and PCB Test Results
Table 4-12 details the dioxin, furan, and PCB raw test results for each of the vegetative and C&D debris
burns. The Toxicity Equivalency Factors (TEFs) and calculated Toxicity Equivalency Quotients (TEQs) for
each congener are also shown, based on the 2005 World Health Organization TEFs (Van den Berg et al.,
2006). Table 4-13 shows the data corrected to 12 percent CO2.
52

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-10. Ash and Vegetative Debris Composition

Vegetative Debris
6/25
Vegetative
Debris 6/25*
Vegetative Ash
6/25
C&D Ash 6/26
C&D Ash 6/27
As
Received
(%)
Dry
Basis
(%)
As
Received
(%)
Dry
Basis
(%)
As
Received
(%)
Dry
Basis
(%)
As
Received
(%)
Dry
Basis
(%)
As
Received
(%)
Dry
Basis
(%)
Moisture
27

30

2.0

1.1

0.82

Volatile
60
82
57
81
5.9
6.0
11
11
4.1
4.1
Fixed Carbon
11
16
12
17
58
59
29
29
-0.40
-0.40
Ash
1.7
2.3
1.0
1.4
34
35
59
60
95
96
Sulfur
0.08
0.11
0.14
0.20
0.09
0.09
3.8
3.9
0.10
0.10
Carbon
35
48
36
51
61
63
34
35
1.5
1.5
Hydrogen
4.1
5.7
4.0
5.7
0.98
1.0
1.3
1.3
0.04
0.04
Nitrogen
0.14
0.20
0.28
0.41
0.36
0.36
0.34
0.34
0.38
0.38
Oxygen
32
44
29
41
1.3
1.4
0
0
1.7
1.7
Chlorine,
ppmw


294
422






BTU/Lb
6520
8990
6235
8960
9159
9345
5831
5896
40
40
MAF BTU/Lb

9204

9083

14285

14602

1078
Lbs
SO2AT1BTU

0.24

0.45

0.19

13

50
Lbs S/mBTU
0.12

0.23

0.10

6.6

25

* Re-analysis with chlorine added as an analyte
Table 4-11. Metals TCLP Results

Wood Ash 6/25/08
C/D Ash 06/26/08
C/D Ash 06/27/08

mg/L
mg/L
mg/L
Arsenic
0.22
<0.2
0.3
Barium
<1
<1
<1
Cadmium
<0.1
<0.1
<0.1
Chromium
<0.2
<0.2
<0.2
Lead
<0.2
<0.2
<0.2
Selenium
<0.5
<0.5
<0.5
Silver
<0.1
<0.1
<0.1
Mercury
<0.02
<0.02
<0.02
53

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-12. Dioxin, Furan, and PCB Test Results, Uncorrected (dry basis)
Pollutant
TEF*
Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACD-M23-1
I-ACD-M23-2
I-ACD-M23-3
II-ACD-M23-1
II-ACD-M23-2
II-ACD-M23-3
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
2,3,7,8-TCDD
1
159
109
389
1339
1868
2293
Other TCDD

3599
3211
10764
27593
37334
54771
1,2,3,7,8-PeCDD
0.5
286
334
827
3163
3815
6335
Other PeCDD

2896
3630
9880
29723
35650
64145
1,2,3,4,7,8-HxCDD
0.1
147
214
491
1544
1979
3974
1,2,3,6,7,8-HxCDD
0.1
162
285
635
2120
2894
5842
1,2,3,7,8,9-HxCDD
0.1
163
278
596
2103
2710
4687
Other HxCDD

1469
2668
6897
18673
26358
55807
1,2,3,4,6,7,8-HpCDD
0.01
443
1762
2312
11914
28415
25814
Other HpCDD

403
2029
1805
9830
23153
25644
1,2,3,4,6,7,8,9-OCDD
0.001
249
5302
1634
44207
115502
28871
Total ODD

9977
19822
36229
152209
279679
278183








2,3,7,8-TCDF
0.1
1130
637
2555
6200
9814
11820
Other TCDF

24675
13140
53210
145829
238819
341428
1,2,3,7,8-PeCDF
0.05
739
486
1732
6361
8261
14249
2,3,4,7,8-PeCDF
0.5
1130
902
3224
9255
11892
22588
Other PeCDF

9480
6814
25461
79447
109819
207720
1,2,3,4,7,8-HxCDF
0.1
516
436
1486
4996
5920
14707
1,2,3,6,7,8-HxCDF
0.1
516
466
1551
5319
5920
14079
2,3,4,6,7,8-HxCDF
0.1
546
612
2129
5481
6051
15845
1,2,3,7,8,9-HxCDF
0.1
154
180
645
1815
1763
4806
Other HxCDF

3002
2815
10086
28932
34019
82691
54

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Pollutant
TEF*
Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACD-M23-1
I-ACD-M23-2
I-ACD-M23-3
II-ACD-M23-1
II-ACD-M23-2
II-ACD-M23-3
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
1,2,3,4,6,7,8-HpCDF
0.01
686
842
2758
7368
8025
25135
1,2,3,4,7,8,9-HpCDF
0.01
111
176
574
1556
1452
3770
Other HpCDF

385
632
2103
5165
5257
12534
1,2,3,4,6,7,8,9-OCDF
0.001
116
344
866
2785
3131
6471
Total CDF

43188
28482
108381
310509
450143
777844








Total CDD/CDF

53165
48304
144610
462718
729822
1056027
PCDD/PCDF TEQ

1250
1095
3569
11079
14337
25625










pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
PCB-77 (3,3' ,4,4' -T etrach lorobiph enyl)
0.0001
1090
3694
2089
8212
14549
20720
PCB-81 (3,4,4',5-Tetrachlorobiphenyl)
0.0003
188
57
318
1141
2920
4348
PCB-105 (2,3,3' ,4,4'-Pentach lorobiphenyl)
0.00003
263
116
552
5031
20889
10802
PCB-114 (2,3,4,4',5-Pentachlorobiphenyl)
0.00003
52
21
89
525
2002
1615
PCB-118 (2,3' ,4,4', 5-Pe ntach lorobiphenyl)
0.00003
393
152
627
7206
45514
14215
PCB-123 (2,3',4,4',5'-Pentachlorobiphenyl)
0.00003
49
27
111
636
1539
1430
PCB-126 (3,3',4,4',5-Pentachlorobiphenyl)
0.1
353
156
858
3235
7209
14606
PCB-156/157 (2,3,3',4,4',5-Hexachlorobiphenyl)
0.00003
238
110
513
1833
10576
8781
PCB-167 (2,3',4,4',5,5'-Hexachlorobiphenyl)
0.00003
80
37
164
613
3315
2429
PCB-169 (3,3',4,4',5,5'-Hexachlorobiphenyl)
0.03
63
33
157
1689
2762
3006
PCB-189 (2,3,3',4,4',5,5'-Heptachlorobiphenyl)
0.00003
83
35
170
401
1031
2497
PCB-209 (2,2',3,3',4,4',5,5',6,6'-Decachlorobiphenyl)

54
33
186
593
800
887
Total Mono-CB

37083
5129
31434
44025
230992
234375
Total Di-CB

21624
4807
22511
49955
121547
99015
55

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Pollutant
TEF*
Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACD-M23-1
I-ACD-M23-2
I-ACD-M23-3
II-ACD-M23-1
II-ACD-M23-2
II-ACD-M23-3
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
Total Tri-CB

12152
4311
14520
87871
117864
102921
Total Tetra-CB

9546
3940
16386
111950
145488
116338
Total Penta-CB

4335
1544
6023
55166
331492
124660
Total Hexa-CB

5863
1001
3772
26415
239937
65048
Total Hepta-CB

15986
565
6388
10386
59984
20720
Total Octa-CB

13029
312
5090
4708
16627
7558
Total Nona-CB

1566
116
929
1626
2363
2310








Total PCBs (Mono-Nona)

121185
21724
107054
392102
1266293
772945
PCBTEQ

37
17
91
376
809
1555








PCDD/F TEQ+PCB TEQ

1287
1112
3660
11454
15146
27180
•WHO 2005 TEF Values (Van den Berg, et al., 2006)
56

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-13. Dioxin, Furan, and PCB Test Results, Corrected to 12% CO2 (dry basis)
Pollutant
TEF*
Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACD-M23-1
I-ACD-M23-2
I-ACD-M23-3
II-ACD-M23-1
II-ACD-M23-2
II-ACD-M23-3
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
2,3,7,8-TCDD
1
1003
1004
2596
12358
37361
30570
Other TCDD

22732
29644
71758
254708
746686
7302741
1,2,3,7,8-PeCDD
1
1804
3088
5516
29195
76300
84463
Other PeCDD

18292
33507
65864
274365
713009
855270
1,2,3,4,7,8-HxCDD
0.1
929
1974
3272
14249
39571
52987
1,2,3,6,7,8-HxCDD
0.1
1024
2630
4231
19574
57883
77896
1,2,3,7,8,9-HxCDD
0.1
1032
2562
3975
19408
54199
62498
Other HxCDD

9279
24626
45977
172366
527153
744087
1,2,3,4,6,7,8-HpCDD
0.01
2801
16262
15411
109978
568303
344191
Other HpCDD

2548
18732
12032
90736
463061
341927
1,2,3,4,6,7,8,9-OCDD
0.0003
1570
48945
10896
408064
2310045
384951
Total ODD

63012
182973
241527
1405002
5593570
3709112








2,3,7,8-TCDF
0.1
7136
5878
17034
57229
196275
157603
Other TCDF

155844
121288
354733
1346115
4776372
4552380
1,2,3,7,8-PeCDF
0.03
4668
4483
11545
58723
165229
189984
2,3,4,7,8-PeCDF
0.3
7136
8325
21495
85428
237845
301167
Other PeCDF

59875
62897
169742
733355
2196384
2769606
1,2,3,4,7,8-HxCDF
0.1
3260
4025
9909
46115
118396
196098
1,2,3,6,7,8-HxCDF
0.1
3260
4300
10342
49100
118396
187720
2,3,4,6,7,8-HxCDF
0.1
3449
5649
14195
50593
121027
211270
1,2,3,7,8,9-HxCDF
0.1
975
1663
4299
16754
35256
64083
Other HxCDF

18963
25989
67242
267067
680384
1102544
57

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Pollutant
TEF*
Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACD-M23-1
I-ACD-M23-2
I-ACD-M23-3
II-ACD-M23-1
II-ACD-M23-2
II-ACD-M23-3
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
1,2,3,4,6,7,8-HpCDF
0.01
4336
7776
18386
68011
160493
335133
1,2,3,4,7,8,9-HpCDF
0.01
704
1622
3826
14365
29047
50270
Other HpCDF

2429
5835
14019
47674
105136
167114
1,2,3,4,6,7,8,9-OCDF
0.0003
731
3179
5773
25711
62619
86274
Total CDF

272765
262909
722538
2866239
9002860
10371247








Total CDD/CDF

335777
445882
964065
4271242
14596430
14080359
PCDD/PCDF TEQ

7273
9864
22013
98299
272361
319535










pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
PCB-77 (3,3',4,4'-Tetrachlorobiphenyl)
0.0001
6884
3408
13926
140778
218232
414402
PCB-81 (3,4,4',5-Tetrachlorobiphenyl)
0.0003
1185
531
2123
19561
43804
86957
PCB-105 (2,3,3',4,4'-Pentachlorobiphenyl)
0.00003
1662
1075
3677
86253
313339
216033
PCB-114 (2,3,4,4',5-Pentachlorobiphenyl)
0.00003
328
192
594
8995
30032
32303
PCB-118 (2,3' ,4,4', 5-Pe ntach lorobiphenyl)
0.00003
2485
1407
4178
123527
682715
284307
PCB-123 (2,3',4,4',5'-Pentachlorobiphenyl)
0.00003
309
252
738
10905
23086
28601
PCB-126 (3,3',4,4',5-Pentachlorobiphenyl)
0.1
2231
1439
5719
55449
108129
292120
PCB-156/157 (2,3,3',4,4',5-Hexachlorobiphenyl)
0.00003
1505
1015
3421
31421
158642
175611
PCB-167 (2,3',4,4',5,5'-Hexachlorobiphenyl)
0.00003
503
338
1096
10504
49724
48573
PCB-169 (3,3',4,4',5,5'-Hexachlorobiphenyl)
0.03
397
302
1044
28956
41436
60122
PCB-189 (2,3,3',4,4',5,5'-Heptachlorobiphenyl)
0.00003
524
325
1130
6869
15470
49932
PCB-209 (2,2',3,3',4,4',5,5',6,6'-Decachlorobiphenyl)

339
302
1242
10166
11997
17731
Total Mono-CB

234211
47343
209559
754717
3464878
4687500
Total Di-CB

136570
44370
150071
856373
1823204
1980299
58

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Pollutant
TEF*
Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACD-M23-1
I-ACD-M23-2
I-ACD-M23-3
II-ACD-M23-1
II-ACD-M23-2
II-ACD-M23-3
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
pg/DSCM
Total Tri-CB

76752
39796
96803
1506353
1767956
2058424
Total Tetra-CB

60294
36365
109241
1919137
2182320
2326766
Total Penta-CB

27377
14249
40154
945707
4972376
2493207
Total Hexa-CB

37031
9240
25147
452830
3599053
1300951
Total Hepta-CB

100964
5215
42588
178052
899763
414402
Total Octa-CB

82290
2882
33935
80709
249408
151155
Total Nona-CB

9891
1068
6192
27878
35438
46196








Total PCBs (Mono-Nona)

765380
200527
713689
6721756
18994396
15458899
PCBTEQ

236
154
606
6442
12129
31108








PCDD/F TEQ + PCB TEQ

7510
10018
22619
104741
284491
350643
•WHO 2005 TEF Values (Van den Burg, et al., 2006)
CB = chlorobiphenyl
59

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
4.5.2.2	Metal Test Results
Table 4-14 details the raw metal test results for each of the vegetative and C&D debris burns. Table 4-15
shows the data corrected to 12 percent CO2. During C&D debris metals Run 3, it was necessary to estimate
dry gas meter temperatures due to a thermocouple readout failure after a sudden violent storm. Dry gas
meter temperatures of an operating readout on an adjacent sampling train were used to aid the estimate.
This procedure could have led to a small error (1-2%) in final sample gas volume. It should be noted that
arsenic is normally present in negligible quantities in virgin wood (Zhurinsh et al., 2005). The fact that
arsenic emissions were observed in the effluent from the ACB suggests that the environment that the wood
was exposed to (which included sediments from the storm) may have impacted As emissions. A 2001 U.S.
Geological Survey Report showed approximately 10 mg/kg of arsenic in the New Orleans area (U.S.
Geological Survey, 2001).
4.5.2.3	PAH Test Results
Table 4-16 details the raw PAH test results for each of the vegetative and C&D debris burns. Table 4-17
shows the data corrected to 12 percent CO2. PAHs were collected in the same sampling train as
dioxins/furans. Separate aliquots were used for the analyses.
4.5.2.4	M5 Particulate and Acid Gas Test Results
Table 4-18 details the raw M5 particulate and acid gas test results for each of the vegetative and C&D
debris burns. Table 4-19 shows the data corrected to 12 percent CO2. Note that the vegetative debris used
in these tests consisted primarily of driftwood material recovered from the aftermath of Hurricane Katrina,
after having soaked in brackish water for an undetermined period of time. The presence of chloride in the
vegetative material due to the brackish water may contribute to elevated levels of HCI and chlorinated
organic compounds. During C&D debris particulate and acid gas Run 3, it was necessary to estimate dry
gas meter temperatures due to a thermocouple readout failure after a sudden violent storm. Dry gas meter
temperatures of an operating readout on an adjacent sampling train were used to aid the estimate. This
procedure could have led to a small error (1-2%) in final sample gas volume.
4.5.2.5	SVOC Test Results
Table 4-20 details the raw SVOC test results for each of the vegetative and C&D debris burns. Table 4-21
shows the data corrected to 12 percent CO2. Note that some of the SVOC target analytes are also target
analytes for the PAH test method. Any differences in observed concentrations may be due to the fact that
the PAH-specific analytical method uses Selective Ion Monitoring (SIM) which is more sensitive than the
full-scan method used for the SVOC analysis, and the fact that the sample train start and stop times for the
two methods may not coincide. Note the presence of chlorinated aromatic compounds in the vegetative
runs; not every run had every chlorinated benzene or chlorinated phenol that was a target, but given that
these chlorinated SVOCs are not typically found from the combustion of clean vegetative material (Lemieux
et al., 2004), it is possible that the soaking of the debris in brackish water in the aftermath of the hurricane
led to increases in emissions of chlorinated organic compounds.
60

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
4.5.2.6 VOC Test Results
Table 4-22 details the raw VOC test results for each of the vegetative and C&D debris burns. Table 4-23
shows the data corrected to 12 percent CO2.
61

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-14. Metal Test Results, Uncorrected (dry basis)

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
Antimony
5.7
11
1.5
40
122
7.0
Arsenic
39
3.7
74
22
4.6
245
Barium
7.9
5.9
11
9.4
21
7.9
Beryllium
0.03
0.03
0.02
0.01
0.02
ND
Cadmium
3.5
3.4
4.6
8.3
21
8.7
Chromium
22
17
8.2
4.6
8.6
63
Cobalt
ND
ND
21
ND
ND
0.60
Lead
60
62
38
327
329
632
Manganese
21
25
45
31
25
27
Mercury
ND
ND
ND
1.4
3.1
0.57
Nickel
23
24
9.5
6.5
7.9
44
Selenium
0.74
ND
ND
ND
ND
ND
Silver
0.59
0.45
0.22
0.2
0.32
0.41
Table 4-15. Metal Test Results, Corrected to 12% CC>2(dry basis)

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
Antimony
36
102
9.7
682
1825
140
Arsenic
248
34
491
374
69
4895
Barium
50
54
71
160
308
157
Beryllium
0.16
0.25
0.12
0.23
0.32
ND
Cadmium
22
32
31
142
311
173
Chromium
141
160
54
79
130
1261
Cobalt
ND
ND
143
ND
ND
12
Lead
376
576
250
5598
4928
12645
Manganese
134
229
297
527
368
539
Mercury
ND
ND
ND
23
47
11
Nickel
147
217
63
111
118
871
Selenium
4.7
ND
ND
ND
ND
ND
Silver
3.7
4.2
1.5
3.4
4.9
8.2
62

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-16. PAH Test Results, Uncorrected (dry basis)

Veg. Run 1
Veg. Run 2
Veg. Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

ng/DSCM
ng/DSCM
ng/DSCM
ng/DSCM
ng/DSCM
ng/DSCM
Naphthalene
32573
34192
77266
71159
116811
72690
2-Methylnaphthalene
5487
6244
6733
10332
29992
22079
Acenaphthylene
4210
3444
7564
23001
49461
32439
Acenaphthene
481
468
229
1001
5578
2819
Fluorene
922
1058
3184
5229
18179
10836
Phenanthrene
6440
7086
24741
23181
49724
32779
Anthracene
621
607
1152
3163
14312
6301
Fluoranthene
2325
2503
13547
11393
21731
12449
Pyrene
1461
1506
5232
4798
6604
4399
Benzo(a)Anthracene
199
253
797
1923
5236
3448
Chrysene
376
453
1910
2444
5867
3889
Benzo(b)Fluoranthene
276
310
1775
2731
6051
3516
Benzo(k)Fluoranthene
85
104
661
943
1873
1104
Benzo(e)Pyrene
150
164
868
1630
3657
1588
Benzo(a)Pyrene
85
47
78
728
2947
1014
Perylene
14
5.0
0.7
82
418
80
lndeno(1,2,3-cd)Pyrene
97
122
639
1391
2342
1163
Dibenzo(a,h)Anthracene
17
18
75
182
631
360
Benzo(ghi)Perylene
113
124
487
1283
2544
1000
63

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-17. PAH Test Results, Corrected to 12% C02(dry basis)

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

ng/DSCM
ng/DSCM
ng/DSCM
ng/DSCM
ng/DSCM
ng/DSCM
Naphthalene
205726
31562
515109
1219869
1557485
1453804
2-Methylnaphthalene
34657
57635
44886
177127
399895
441576
Acenaphthylene
26586
31791
50429
394301
659476
648777
Acenaphthene
3038
4323
1528
17158
74366
56386
Fluorene
5824
9766
21226
89642
242392
216712
Phenanthrene
40670
65411
164943
397382
662983
655571
Anthracene
3925
5603
7679
54216
190827
126019
Fluoranthene
14686
23100
90313
195302
289748
248981
Pyrene
9226
13906
34881
82249
88047
87976
Benzo(a)Anthracene
1258
2333
5313
32961
69806
68954
Chrysene
2374
4185
12736
41894
78225
77785
Benzo(b)Fluoranthene
1741
2859
11830
46823
80681
70313
Benzo(k)Fluoranthene
540
963
4407
16173
24976
22079
Benzo(e)Pyrene
946
1516
5787
27940
48759
31760
Benzo(a)Pyrene
540
432
519
12476
39288
20279
Perylene
85
46
4.9
1405
5577
1607
lndeno(1,2,3-cd) Pyrene
611
1128
4259
23843
31220
23268
Dibenzo(a,h)Anthracene
106
161
499
3111
8419
7201
Benzo(ghi)Perylene
715
1141
3245
21995
33921
20007
64

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-18. M5 Particulate and Acid Gas Test Results, Uncorrected (dry basis)

Veg Run 1
Veg Run 2
Veg Run 3*
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

mg/DSCM
mg/DSCM
mg/DSCM
mg/DSCM
mg/DSCM
mg/DSCM
Filterable Particulate
66
41
N/A
39
46
32
HCI
8.5
0.77
N/A
14
30
110
HF
0.25
0.21
N/A
0.28
0.59
0.51
HBr
0.29
0.30
N/A
0.40
0.49
0.47
Cb
0.27
0.25
N/A
0.32
0.48
0.52
Br2
0.12
0.14
N/A
0.08
0.10
0.09
* Sample lost prior to laboratory analysis.
N/A = Not available.
Table 4-19. M5 Particulate and Acid Gas Test Results, Corrected to 12% CO2 (dry basis)

Veg Run 1
Veg Run 2
Veg Run 3*
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

mg/DSCM
mg/DSCM
mg/DSCM
mg/DSCM
mg/DSCM
mg/DSCM
Filterable Particulate
414
375
N/A
259
607
636
HCI
53
7.1
N/A
96
404
2197
HF
1.6
1.9
N/A
1.9
7.9
10
HBr
1.9
2.8
N/A
2.7
6.6
9.4
Cb
1.7
2.3
N/A
2.2
6.5
10
Br2
0.73
1.3
N/A
0.5
1.4
1.9
* Sample lost prior to laboratory analysis.
N/A = Not available.
65

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-20. SVOC Test Results, Uncorrected (dry basis)

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
Pyridine
ND
ND
ND
ND
ND
ND
N-Nitrosodimethyl amine
ND
ND
ND
ND
ND
ND
Phenol
ND
ND
ND
ND
ND
ND
Aniline
ND
ND
ND
ND
ND
13
s-Dichloroethyl ether
ND
ND
ND
ND
ND
ND
2-Chlorophenol
ND
ND
ND
22
60
37
1,3-Dichlorobenzene
ND
ND
ND
ND
2.8
2.6
1,4-Dichlorobenzene
ND
0.8
ND
ND
2.7
2.4
Benzyl Alcohol
27
ND
13
ND
34
22
1,2-Dichlorobenzene
ND
ND
ND
ND
ND
2.2
2-Methylphenol
ND
ND
ND
ND
58
32
B is(2-ch loroisopropy l)eth er
ND
ND
ND
ND
ND
ND
3- & 4-Methylphenol
ND
ND
ND
11
100
47
N-nitroso-di-n-propyl amine
ND
ND
ND
ND
ND
ND
Hexachloroethane
ND
ND
ND
ND
ND
ND
Nitrobenzene
ND
ND
ND
10
180
83
Isophorone
ND
ND
ND
ND
ND
ND
2-Nitrophenol
ND
ND
17
14
29
24
2,4-Dimethylphenol
ND
ND
ND
3.2
24
15
Bis(2-chloroethoxy)methane
ND
ND
ND
ND
17
ND
2,4-Dichlorophenol
21
ND
ND
ND
30
23
1,2,4-Trichlorobenzene
ND
ND
0.2
ND
ND
1.0
Naphthalene
23
16
88
74
273
144
p-Chloroaniline
ND
ND
ND
ND
ND
ND
Hexachloro-1,3-butadiene
ND
ND
ND
ND
ND
ND
4-Chloro-3-methylphenol
ND
ND
ND
ND
ND
15
2-Methylnaphthalene
14
7.8
10
15
42
27
1-Methylnaphthalene
3.4
2.0
2.4
5.7
ND
ND
Hexachlorocyclopentadiene
ND
ND
ND
ND
ND
ND
2,4,6-T richlorophenol
ND
ND
ND
ND
ND
ND
2,4,5-T richlorophenol
1.2
ND
ND
ND
ND
ND
2-Chloronaphthalene
ND
ND
0.2
ND
ND
0.8
2-Nitroaniline
ND
ND
0.7
ND
22
ND
1,4-Dinitrobenzene
ND
ND
ND
ND
ND
ND
66

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
Dimethyl phthalate
1.5
ND
ND
ND
1.8
ND
1,3-Dinitrobezene
ND
ND
1.9
9.8
36
16
Acenaphthylene
1.7
1.2
2.9
12
44
20
2,6-Dinitrotoluene
1.5
ND
ND
ND
ND
ND
1,2-Dinitrobenzene
ND
ND
ND
ND
ND
ND
3-Nitroaniline
ND
ND
ND
ND
ND
ND
Acenaphthene
0.3
ND
ND
ND
4.0
ND
2,4-Dinitrophenol
ND
ND
ND
ND
ND
ND
4-Nitrophenol
ND
ND
ND
ND
50
29
Dibenzofuran
2.3
1.3
5.3
7.6
31
14
2,4-Dinitro toluene
ND
ND
ND
ND
ND
2.1
2,3,4,6-T etrachlorophenol
ND
ND
ND
ND
ND
4.6
2,3,5,6-T etrachlorophenol
ND
ND
ND
ND
ND
3.5
Diethyl phthalate
2.1
ND
1.9
ND
1.8
ND
4-Chlorophenyl phenyl ether
ND
ND
ND
ND
ND
ND
Fluorene
ND
0.3
0.8
2.3
14
5.7
4-Nitroaniline
ND
0.8
ND
ND
ND
ND
4,6-Dinitro-2-methylphenol
ND
ND
ND
ND
ND
2.1
Diphenyl amine
ND
ND
ND
ND
ND
ND
Azobenzene
ND
ND
ND
ND
1.2
ND
4-Bromophenyl phenyl ether
ND
ND
ND
ND
ND
ND
Hexachlorobenzene
ND
ND
ND
ND
ND
ND
Pentachlorophenol
ND
ND
ND
ND
ND
ND
Phenanthrene
4.6
4.1
15
20
87
32
Anthracene
5.1
4.8
17
23
83
33
Carbazole
ND
0.2
ND
0.3
1.8
ND
Di-n-butyl phthalate
19
3.0
2.5
4.7
ND
2.7
Fluoranthene
1.4
ND
7.9
9.2
26
8.6
Pyrene
1.1
ND
6.4
8.4
23
7.1
Benzyl butyl phthalate
ND
ND
ND
1.1
ND
ND
Bis(2-ethylhexyl)adipate
ND
ND
ND
ND
ND
ND
Benz[a]anthracene
ND
ND
ND
ND
6.7
2.8
Chrysene
ND
ND
ND
ND
25
14
Bis(2-ethylhexyl) phthalate
14
3.8
3.5
8.7
219
15
Di-n-octyl phthalate
21
ND
ND
ND
ND
0.7
67

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
Benzo[b]fluoranthene
ND
ND
ND
ND
ND
ND
Benzo[k]fluoranthene
ND
ND
ND
ND
ND
ND
Benzo[a]pyrene
ND
ND
ND
ND
ND
ND
lndeno[1,2,3-cd]pyrene
ND
ND
ND
ND
ND
ND
Dibenz[a,h]anthracene
ND
ND
ND
ND
0.5
ND
Benzo[ghi]perylene
ND
ND
ND
ND
ND
ND
68

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-21. SVOC Test Results, Corrected to 12% CO2 (dry basis)

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
Pyridine
ND
ND
ND
ND
ND
ND
N-Nitrosodimethyl amine
ND
ND
ND
ND
ND
ND
Phenol
ND
ND
ND
ND
ND
ND
Aniline
ND
ND
ND
ND
ND
267.86
s-Dichloroethyl ether
ND
ND
ND
ND
ND
ND
2-Chlorophenol
ND
ND
ND
204.25
803.93
746.08
1,3-Dichlorobenzene
ND
ND
ND
ND
37.67
51.81
1,4-Dichlorobenzene
ND
7.26
ND
ND
35.54
48.91
Benzyl Alcohol
171
ND
88.18
ND
458.84
441.81
1,2-Dichlorobenzene
ND
ND
ND
ND
ND
43.64
2-Methylphenol
ND
ND
ND
ND
771.88
638.62
B is(2-ch loroisopropy l)eth er
ND
ND
ND
ND
ND
ND
3- & 4-Methylphenol
ND
ND
ND
98.08
1330.32
940.56
N-nitroso-di-n-propyl amine
ND
ND
ND
ND
ND
ND
Hexachloroethane
ND
ND
ND
ND
ND
ND
Nitrobenzene
ND
ND
ND
93.47
2401.90
1653.17
Isophorone
ND
ND
ND
ND
ND
ND
2-Nitrophenol
ND
ND
116.10
126.19
383.37
488.57
2,4-Dimethylphenol
ND
ND
ND
29.57
316.80
293.37
Bis(2-chloroethoxy)methane
ND
ND
ND
ND
231.88
ND
2,4-Dichlorophenol
134
ND
ND
ND
402.68
466.82
1,2,4-Trichlorobenzene
ND
ND
1.42
ND
ND
20.57
Naphthalene
147
151.59
586.77
683.86
3636.38
2878.07
p-Chloroaniline
ND
ND
ND
ND
ND
ND
Hexachloro-1,3-butadiene
ND
ND
ND
ND
ND
ND
4-Chloro-3-methylphenol
ND
ND
ND
ND
ND
298.03
2-Methylnaphthalene
86
72.38
69.16
138.74
558.91
547.22
1-Methylnaphthalene
21
18.45
16.22
52.91
ND
ND
Hexachlorocyclopentadiene
ND
ND
ND
ND
ND
ND
2,4,6-T richlorophenol
ND
ND
ND
ND
ND
ND
2,4,5-T richlorophenol
ND
ND
ND
ND
ND
ND
2-Chloronaphthalene
ND
ND
1.42
ND
ND
15.19
2-Nitroaniline
ND
ND
4.88
ND
297.66
ND
1,4-Dinitrobenzene
ND
ND
ND
ND
ND
ND
69

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
Dimethyl phthalate
9.4
ND
ND
ND
ND
ND
1,3-Dinitrobezene
ND
ND
12
90
484
310
Acenaphthylene
11
11
19
114
586
391
2,6-Dinitrotoluene
9.4
ND
ND
ND
ND
ND
1,2-Dinitrobenzene
ND
ND
ND
ND
ND
ND
3-Nitroaniline
ND
ND
ND
ND
ND
ND
Acenaphthene
1.9
ND
ND
ND
54
ND
2,4-Dinitrophenol
ND
ND
ND
ND
ND
ND
4-Nitrophenol
ND
ND
ND
ND
659
578
Dibenzofuran
15
12
35
70
417
277
2,4-Dinitro toluene
ND
ND
ND
ND
ND
42
2,3,4,6-T etrachlorophenol
ND
ND
ND
ND
ND
92
2,3,5,6-T etrachlorophenol
ND
ND
ND
ND
ND
70
Diethyl phthalate
13
ND
13

23
ND
4-Chlorophenyl phenyl ether
ND
ND
ND
ND
ND
ND
Fluorene
ND
2.8
5.6
22
186
114
4-Nitroaniline
ND
7.3
ND
ND
ND
ND
4,6-Dinitro-2-methylphenol
ND
ND
ND
ND
ND
43
Diphenylamine
ND
ND
ND
ND
ND
ND
Azobenzene
ND
ND
ND
ND
16
ND
4-Bromophenyl phenyl ether
ND
ND
ND
ND
ND
ND
Hexachlorobenzene
ND
ND
ND
ND
ND
ND
Pentachlorophenol
ND
ND
ND
ND
ND
ND
Phenanthrene
29
38
101
189
1160
641
Anthracene
32
45
112
208
1102
664
Carbazole
ND
2.3
ND
2.9
24
ND
Di- n-butyl phthalate
119
28
17
43
ND
54
Fluoranthene
9.0
ND
53
85
348
172
Pyrene
7.1
ND
43
77
300
142
Benzyl butyl phthalate
ND
ND
ND
11
ND
ND
Bis(2-ethylhexyl)adipate
ND
ND
ND
ND
ND
ND
Benz[a]anthracene
ND
ND
ND
ND
89
56
Chrysene
ND
ND
ND
ND
333
271
Bis(2-ethylhexyl) phthalate
89
35
23
81
2916
296
Di-n-octyl phthalate
133
ND
ND
ND
ND
15
70

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
I-ACB-M29-01
I-ACB-M29-02
I-ACB-M29-03
II-ACB-M29-01
II-ACB-M29-02
II-ACB-M29-03

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
Benzo[b]fluoranthene
ND
ND
ND
ND
ND
ND
Benzo[k]fluoranthene
ND
ND
ND
ND
ND
ND
Benzo[a]pyrene
ND
ND
ND
ND
ND
ND
lndeno[1,2,3-cd]pyrene
ND
ND
ND
ND
ND
ND
Dibenz[a,h]anthracene
ND
ND
ND
ND
7.0
ND
Benzo[ghi]perylene
ND
ND
ND
ND
ND
ND
71

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-22. VOC Test Results, Uncorrected (dry basis)
Pollutant
Veg Run 3
Total
|jg/DSCM
C&D Run 1
Total
|jg/DSCM
C&D Run 2
Total
|jg/DSCM
C&D Run 3
Total
|jg/DSCM
Dichlorodifluoromethane (Freon 12)
ND
2.8
ND
2.5
1,2-Chloro-1,1,2,2-tetrafluoroethane
ND
ND
ND
ND
Chloromethane
25
34
ND
250
Vinyl chloride
ND
8.4
37
86
1,3-Butadiene
5.9
42
279
292
Bromomethane
ND
9.9
ND
15
Chloroethane
ND
ND
ND
ND
Trichlorofluoromethane
2.9
2.9
2.9
2.9
1,1-Dichloroethene
1.8
ND
ND
1.4
1,1,2-T richloro-1,2,2-trifluoroethane
ND
ND
ND
ND
Ethanol
58
19
ND
36
Carbon disulfide
104
44
ND
60
Isopropyl alcohol
1.3
ND
ND
ND
Methylene chloride
19
46
61
18
Acetone
110
130
688
133
t-1,2-dichloroethene
ND
ND
ND
ND
Hexane
ND
ND
ND
ND
Methyl-f-butyl ether (MTBE)
ND
ND
ND
ND
1,1-Dichloroethane
ND
ND
ND
ND
Vinyl acetate
ND
3.2
3.0
3.8
cis-1,2-dichloroethene
ND
ND
ND
ND
Cyclohexane
ND
ND
ND
ND
Chloroform
ND
ND
3.9
2.2
Ethyl Acetate
ND
7.8
11
28
Tetrahydrofuran
ND
1.7
4.2
5.5
1,1,1-Trichloroethane
ND
ND
ND
ND
Carbon tetrachloride
ND
ND
ND
3.7
2-Butanone
ND
27
ND
84
Heptane
23
2.8
22
ND
Benzene
1131
282
1094
859
1,2-Dichloroethane
ND
ND
ND
ND
Trichloroethylene
3.4
2.4
27
2.7
1,2-Dichloropropane
ND
ND
ND
ND
Bromodichloromethane
ND
ND
ND
ND
72

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72

Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
Total
Total
Total
Total

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
1,4-Dioxane
2.2
1.8
1.6
ND
cis-1,3-Dichloropropene
ND
ND
ND
ND
Toluene
93
51
209
212
4-Methyl-2-pentanone (MIBK)
2.7
2.1
2.7
ND
t-1,3-Dichloropropene
ND
ND
ND
ND
Tetrachloroethylene
4.3
4.0
11
ND
1,1,2-Trichloroethane
ND
ND
ND
ND
Dibromochloro methane
ND
ND
ND
ND
1,2-Dibromoethane
ND
ND
ND
ND
2-Hexanone
ND
ND
ND
ND
Ethylbenzene
6.1
8.4
22
32
Chlorobenzene
5.2
3.6
11
18
m-/p-Xylene
10
18
29
49
o-Xylene
3.9
6.7
12
19
Styrene
26
32
81
273
Tribromomethane
ND
ND
5.1
ND
1,1,2,2-Tetrachloroethane
ND
ND
ND
ND
1 -Ethyl-4-methylbenzene
ND
6.2
ND
13
1,3,5-Trimethylbenzene
1.9
ND
ND
ND
1,2,4-T rimethylbenzene
2.7
6.9
4.6
9.5
1,3-Dichlorobenzene
ND
ND
ND
ND
1,4-Dichlorobenzene
ND
ND
ND
ND
Benzyl chloride
ND
6.6
ND
154
1,2-Dichlorobenzene
ND
ND
ND
3.6
1,1,2,3,4,4-Hexachloro-1,3-butadiene
ND
ND
ND
ND
1,2,4-T richlorobenzene
ND
ND
ND
ND
73

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-23. VOC Test Results, Corrected to 12% CO2 (dry basis)
Pollutant
Veg Run 3
Total
|jg/DSCM
C&D Run 1
Total
|jg/DSCM
C&D Run 2
Total
|jg/DSCM
C&D Run 3
Total
|jg/DSCM
Dichlorodifluoromethane (Freon 12)
ND
48
ND
49
1,2-Chloro-1,1,2,2-tetrafluoroethane
ND
ND
ND
ND
Chloromethane
169
576
ND
5000
Vinyl chloride
ND
144
557
1725
1,3-Butadiene
39
716
4178
5834
Bromomethane
ND
169
ND
306
Chloroethane
ND
ND
ND
ND
Trichlorofluoromethane
19
49
43
57
1,1-Dichloroethene
12
ND
ND
28
1,1,2-T richloro-1,2,2-trifluoroethane
ND
ND
ND
ND
Ethanol
386
333
ND
715
Carbon disulfide
695
752
ND
1206
Isopropyl alcohol
8.3
ND
ND
ND
Methylene chloride
124
796
907
354
Acetone
733
2220
10319
2655
t-1,2-Dichloroethene
ND
ND
ND
ND
Hexane
ND
ND
ND
ND
Methyl-f-butyl ether (MTBE)
ND
ND
ND
ND
1,1-Dichloroethane
ND
ND
ND
ND
Vinyl acetate
ND
55
46
76
cis-1,2-Dichloroethene
ND
ND
ND
ND
Cyclohexane
ND
ND
ND
ND
Chloroform
ND
ND
58
44
Ethyl Acetate
ND
133
160
555
Tetrahydrofuran
ND
30
63
109
1,1,1-Trichloroethane
ND
ND
ND
ND
Carbon Tetrachloride
ND
ND
ND
73
2-Butanone
ND
461
ND
1671
Heptane
154
47
335
ND
Benzene
7541
4836
16417
17174
1,2-Dichloroethane
ND
ND
ND
ND
Trichloroethylene
23
42
409
54
1,2-Dichloropropane
ND
ND
ND
ND
Bromodichloromethane
ND
ND
ND
ND
74

-------
Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72

Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Pollutant
Total
Total
Total
Total

|jg/DSCM
|jg/DSCM
|jg/DSCM
|jg/DSCM
1,4-Dioxane
15
31
24
ND
cis-1,3-Dichloropropene
ND
ND
ND
ND
Toluene
618
868
3137
4231
4-Methyl-2-pentanone (MIBK)
18
36
41
ND
t-1,3-Dichloropropene
ND
ND
ND
ND
Tetrachloroethylene
29
69
160
ND
1,1,2-Trichloroethane
ND
ND
ND
ND
Dibromochloro methane
ND
ND
ND
ND
1,2-Dibromoethane
ND
ND
ND
ND
2-Hexanone
ND
ND
ND
ND
Ethylbenzene
41
144
330
630
Chlorobenzene
35
61
168
359
m-/p-Xylene
69
300
437
985
o-Xylene
26
114
178
376
Styrene
176
555
1208
5452
Tribromomethane
ND
ND
76
ND
1,1,2,2-Tetrachloroethane
ND
ND
ND
ND
1 -Ethyl-4-methylbenzene
ND
106
ND
253
1,3,5-Trimethylbenzene
13
ND
ND

1,2,4-T rimethylbenzene
18
119
69
190
1,3-Dichlorobenzene
ND
ND
ND
ND
1,4-Dichlorobenzene
ND
ND
ND
ND
Benzyl chloride
ND
113
ND
3087
1,2-Dichlorobenzene
ND
ND
ND
72
1,1,2,3,4,4-Hexachloro-1,3-butadiene
ND
ND
ND
ND
1,2,4-T richlorobenzene
ND
ND
ND
ND
4.5.2.7 Tentatively Identified Compounds (TICs)
TICs for each sample are shown in Tables 4-24 (raw) and 4-25 (corrected to 12% CO2). TICs are
compounds collected in the same SUMMAฎ canisters as VOCs. TICs are tentatively identified in the sense
that they match an elution time and/or a mass class that is contained in the mass spectrometer reference
library, possibly as fragments. However, TICs have not been specifically calibrated as targets.
75

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-24. Tentatively Identified Compounds, Uncorrected (dry basis)
TICs
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACB-M29-03A
ppbv
I-ACB-M29-03B
ppbv
II-ACB-M29-01A
ppbv
II-ACB-M29-01B
ppbv
II-ACB-M29-02A
ppbv
II-ACB-M29-02B
ppbv
II-ACB-M29-03A
ppbv
II-ACB-M29-03B
ppbv
Propene
Not Found
Not Found
Not Found
Not Found
60
19
Not Found
Not Found
1,3-Butadiene
Not Found
Not Found
Not Found
Not Found
Not Found
25
Not Found
Not Found
1,2-Pentadiene
Not Found
Not Found
Not Found
Not Found
30
Not Found
Not Found
Not Found
Furan
Not Found
Not Found
Not Found
Not Found
50
Not Found
Not Found
Not Found
1-Butanol
Not Found
Not Found
Not Found
Not Found
Not Found
12
Not Found
Not Found
2-Butene
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
53.37
13.66
Furan, 2-methyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
35.71
20.09
Methane, bromochloro-
21
21
44
16
100
Not Found
32.99
Not Found
Disulfide, dimethyl
Not Found
Not Found
Not Found
31
49
Not Found
Not Found
Not Found
Hexane, 3,3,4,4-tetrafluoro-
Not Found
Not Found
7.7
Not Found
Not Found
Not Found
Not Found
Not Found
1,3,5-Cydoheptatriene
Not Found
107
9.7
63
244
62
168.51
42.25
2-Cyclopenten-1-one, 2-methyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
8.96
Cyclopenta[c]pyran-1,3-dione, 4,4a,5,6-t
Not Found
Not Found
Not Found
Not Found
Not Found
15
Not Found
Not Found
Hexanal, 2-ethyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
19.79/85.84
1-Hexene, 3,5-dimethyl-
45
Not Found
25
25
Not Found
31
Not Found
Not Found
Phenol
Not Found
Not Found
Not Found
Not Found
Not Found
489
Not Found
Not Found
Azulene
Not Found
Not Found
Not Found
Not Found
Not Found
184
Not Found
Not Found
Camphene
Not Found
Not Found
11
Not Found
Not Found
Not Found
47.27
Not Found
1-Butyne, 3-methyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
30.23
Not Found
Cyclohexene, 1 -methyl-4-(1 -methylethenyl
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
64.89
Not Found
Phenylethyne
Not Found
22
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Methyl isopropyl disulfide
Not Found
Not Found
Not Found
16
Not Found
Not Found
Not Found
Not Found
Furfural
Not Found
15
Not Found
52
Not Found
Not Found
132.46
63.35
76

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
TICs
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACB-M29-03A
ppbv
I-ACB-M29-03B
ppbv
II-ACB-M29-01A
ppbv
II-ACB-M29-01B
ppbv
II-ACB-M29-02A
ppbv
II-ACB-M29-02B
ppbv
II-ACB-M29-03A
ppbv
II-ACB-M29-03B
ppbv
1-Hepten-3-one
Not Found
13
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Heptanal
Not Found
Not Found
12
Not Found
35
Not Found
Not Found
Not Found
1-Hexanol, 2-ethyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
85.84
Benzonitrile
Not Found
35
Not Found
Not Found
76
Not Found
Not Found
Not Found
Benzaldehyde, 4-methyl-
Not Found
14
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Benzene, 1 -methyl-3-(1 -methylethyl)-
Not Found
Not Found
Not Found
28
Not Found
Not Found
Not Found
Not Found
Benzene, 1 -methyl4-(1 -methylethyl)-
Not Found
Not Found
60
Not Found
Not Found
Not Found
32.79
Not Found
Benzene, 1-propynyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
114.58
Not Found
Benzaldehyde, 3-methyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
47.93
Not Found
Benzene, 1-ethynyl4-methyl-
Not Found
Not Found
Not Found
18
Not Found
Not Found
Not Found
Not Found
Cyclohexanemethyl propanoate
Not Found
16
Not Found
19
76
43
Not Found
9.92
2,2-D imethy l-propyl 2,2-dimethyl-propane
12
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Naphthalene
96
346
100
102
232
Not Found
140.73
26.77
Benzaldehyde, 4-(1 -methylethyl)-
Not Found
Not Found
Not Found
19
Not Found
Not Found
Not Found
Not Found
NOTE: Multiple cell entries separated by a slash indicate likelihood of multiple isomers detected
77

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-25. Tentatively Identified Compounds, Corrected to 12% CO2 (dry basis)
TICs
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACB-M29-03A
ppbv
I-ACB-M29-03B
ppbv
II-ACB-M29-01A
ppbv
II-ACB-M29-01B
ppbv
II-ACB-M29-02A
ppbv
II-ACB-M29-02B
ppbv
II-ACB-M29-03A
ppbv
II-ACB-M29-03B
ppbv
Propene
Not Found
Not Found
Not Found
Not Found
900
284
Not Found
Not Found
1,3-Butadiene
Not Found
Not Found
Not Found
Not Found
Not Found
371
Not Found
Not Found
1,2-Pentadiene
Not Found
Not Found
Not Found
Not Found
447
Not Found
Not Found
Not Found
Furan
Not Found
Not Found
Not Found
Not Found
747
Not Found
Not Found
Not Found
1 -Butanol
Not Found
Not Found
Not Found
Not Found
Not Found
178
Not Found
Not Found
2-Butene
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
1067
273
Furan, 2-methyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
714
402
Methane, bromochloro-
138
142
759
277
1501
Not Found
660
Not Found
Disulfide, dimethyl
Not Found
Not Found
Not Found
533
741
Not Found
Not Found
Not Found
Hexane, 3,3,4,4-tetrafluoro-
Not Found
Not Found
133
Not Found
Not Found
Not Found
Not Found
Not Found
1,3,5-Cydoheptatriene
Not Found
714
166
1084
3663
924
3370
845
2-Cyclopenten-1-one, 2-methyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
179
Hexanal, 2-ethyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
396/1717
1-Hexene, 3,5-dimethyl-
303
Not Found
429
425
Not Found
472
Not Found
Not Found
Phenol
Not Found
Not Found
Not Found
Not Found
Not Found
7335
Not Found
Not Found
Azulene
Not Found
Not Found
Not Found
Not Found
Not Found
2766
Not Found
Not Found
Camphene
Not Found
Not Found
188
Not Found
Not Found
Not Found
945
Not Found
1-Butyne, 3-methyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
605
Not Found
Cyclohexene, 1-methyl4-(1-
methylethenyl
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
1298
Not Found
Phenylethyne
Not Found
145
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Methyl isopropyl disulphide
Not Found
Not Found
Not Found
276
Not Found
Not Found
Not Found
Not Found
Furfural
Not Found
100
Not Found
893
Not Found
Not Found
2649
1267
78

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
TICs
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3
I-ACB-M29-03A
ppbv
I-ACB-M29-03B
ppbv
II-ACB-M29-01A
ppbv
II-ACB-M29-01B
ppbv
II-ACB-M29-02A
ppbv
II-ACB-M29-02B
ppbv
II-ACB-M29-03A
ppbv
II-ACB-M29-03B
ppbv
1-Hepten-3-one
Not Found
84
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Heptanal
Not Found
Not Found
200
Not Found
532
Not Found
Not Found
Not Found
1-Hexanol, 2-ethyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
1717
Benzonitrile
Not Found
231
Not Found
Not Found
1140
Not Found
Not Found
Not Found
Benzaldehyde, 4-methyl-
Not Found
94
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Benzene, 1 -methyl-3-(1 -methylethyl)-
Not Found
Not Found
Not Found
481
Not Found
Not Found
Not Found
Not Found
Benzene, 1 -methyl-4-(1 -methylethyl)-
Not Found
Not Found
1023
Not Found
Not Found
Not Found
656
Not Found
Benzene, 1-propynyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
2292
Not Found
Benzaldehyde, 3-methyl-
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
959
Not Found
Benzene, 1-ethynyl4-methyl-
Not Found
Not Found
Not Found
302
Not Found
Not Found
Not Found
Not Found
Cyclohexanemethyl propanoate
Not Found
108
Not Found
328
1146
647
Not Found
198
2,2-D imethy l-propyl 2,2-dimethyl-
propane
79
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Not Found
Naphthalene
637
2306
1716
1740
3477
Not Found
2815
535
Benzaldehyde, 4-(1 -methylethyl)-
Not Found
Not Found
Not Found
332
Not Found
Not Found
Not Found
Not Found
NOTE: Multiple cell entries separated by a slash indicate likelihood of multiple isomers detected
79

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
4.5.2.8	Brominated Organic Compounds
The Method 23 extracts were analyzed for polybrominated dibenzo-p-dioxins and polybrominated
dibenzofurans (PBDDs/PBDFs), as well as for brominated diphenyl ethers (PBDPEs). The results for the
analyses are shown in Table 4-26. The analysis was done using GC/MS under a full-scan mode, using
response factors based on Octachlorodibenzodioxin (OCDD). This was done because standards for the
PBDDs, PBDFs, and PBDPEs are not generally available at commercial laboratories. It must also be noted
that Method 23 has not been validated for PBDDs/PBDFs and PBDPE analysis.
Based on examination of the chromatograms and mass spectral results, it is believed that there is good
confidence in the identification of the brominated compounds, but because the quantifications were based
on using the OCDD response factor, and the fact that OCDD was present in these samples only at low
levels, there is not good confidence in the concentrations presented here, so the reported values are semi-
quantitative at best.
The brominated targets were only found in the emissions from the C&D tests. This is consistent with
intuition because it is likely that brominated compounds released as combustion emissions from vegetative
debris would be at exceedingly low concentrations and not likely to be identified in a full-scan mass spectral
run. Brominated flame retardants, however, are in widespread used in a variety of commercial applications
including carpet, draperies, furniture, and consumer electronics items. There is a high likelihood of finding
any or all of these types of materials in C&D debris. The investigators witnessed a mattress and sofa being
fed into the ACB during the C&D Runs.
The samples from C&D Runs 1 and 3 showed significant levels of tetra- and penta- brominated diphenyl
ethers, and lesser amounts of TBDF and PeBDF. This is consistent with emissions of undestroyed flame
retardants, which are a mix of tetra- and penta- brominated diphenyl ethers (La Guardia et al., 2006). This
particular flame retardant mix has been shown to have trace levels of PBDFs as contaminants in the mix
(Hanari et al., 2006) in a manner similar to the presence of TCDDs found as trace contaminants in the
herbicide 2,4,5-trichlorophenoxyacetic acid (otherwise known as 2,4,5-T or Agent Orange). Therefore it is
likely that the brominated compounds that are reported here were released as undestroyed flame retardant
material from the C&D debris rather than as products of incomplete combustion.
Because of the semi-quantitative nature of these results, values corrected to 12% C02 were not estimated,
and emission factors were not calculated.
4.5.2.9	Particle Sizing Test Results
Particle sizing test results can be seen visually in Figures 4-36 through 4-40. The graphs represent a plot
of derived particle aerodynamic diameter (Di) vs. mass distribution (dM/dlogDp). The graphical presentation
allows the particle size distribution across the sampled size range to be seen more easily.
4.5.2.10	Visible Emissions during Vegetative Debris Burning
The results of visible emissions determination using EPA Method 9 are presented in Table 4-27. Each of
the vegetative burns was sampled for two sequential 30-minute periods, and the results from both runs are
shown.
80

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 4-26. Brominated Compounds, Uncorrected (Dry Basis)

C&D Run 1 (ng/DSCM)*
C&D Run 2 (ng/DSCM)*
C&D Run 3 (ng/DSCM)*
TriBrDPE
2,174
ND
ND
TBrDPE
19,586,703
ND
703
PeBrDPE
3,234,501
ND
1,150
HxBrDPE
26,056
ND
22
HpBrDPE
442
ND
ND
OBrDPE
262
ND
ND
NBrDPE
282
ND
ND
DBrDPE
99
ND
11
TBrDF
8,392
ND
761
PeBrDF
2,282
ND
226
HxBrDF
455
ND
73
HpBrDF
163
ND
11
* - Note that quantitations of all analytes in this table was done based on a response factor for OCDD,
which was not present in high levels; therefore these concentration estimates should be considered as
semiquantitative.
81

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
4.5.2.11 Filterable and Condensable Particulate Matter Test Results
Filterable and condensable particulate matter test results are presented in Table 4-28 for two vegetative
and three C&D debris burns.
D50 (um)
Log D50
dlogDp
Di (um)
dM/dlogDp
PM (mg)
[PM]
dM
N (particles)
0.200
-0.699
0.352
0.300
20.452593
141.9
35.4573
7.20305
1.00E+14
0.450
-0.347
0.173
0.549
11.996163
19.7
4.92254
2.07368
2.27E+12
0.670
-0.174
0.215
0.858
6.893877
9.5
2.37381
1.48438
2.87E+11
1.100
0.0414
0.301
1.556
6.0743828
6.4
1.5992
1.82857
3.25E+10
2.200
0.3424
0.189
2.735
5.1425028
3.5
0.87456
0.97222
3.27E+09
3.400
0.5315
0.167
4.123
16.533601
3.6
0.89955
2.76923
9.81 E+08
5.000
0.699
0.164
6.042
9.8872635
1.3
0.32484
1.625
1.13E+08
7.300
0.8633
0.209
9.281
1.0959549
0.8
0.1999
0.22857
1.91E+07
Particle Size Distribution
25
0.1	1	10
Particle Aerodiameter Di [um]
Figure 4-36. Andersen 1-24 June 2008, Vegetative Run 2
82

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
D50 (um)
Log D50
dlogDp
Di (um)
dM/dlogDp
PM (mg)
[PM]
dM
N (particles)
0.2
-0.69897
0.361728
0.303
28.263043
86.9
46.44575
10.22353
5.95E+13
0.46
-0.33724
0.169751
0.559
6.8593587
8.5
4.543025
1.164384
9.28E+11
0.68
-0.16749
0.208884
0.865
7.4356733
7.3
3.901657
1.553191
2.16E+11
1.1
0.041393
0.30103
1.556
4.7312309
4.7
2.512026
1.424242
2.38E+10
2.2
0.342423
0.201645
2.775
13.637804
3.3
1.763763
2.75
2.95E+09
3.5
0.544068
0.163502
4.225
2.6211978
1.2
0.641368
0.428571
3.04E+08
5.1
0.70757
0.167491
6.185
167.17307
2.8
1.496526
28
2.26E+08
7.5
0.875061
0.20412
9.487
0.5443422
0.1
0.053447
0.111111
2.24E+06
Particle Size Distribution
0.1	1	10
Particle Aerodiameter Di [um]
Figure 4-37. Andersen 2-25 June 2008, Vegetative Run 3
83

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
D50 (um)
Log D50
dlogDp
Di (um)
dM/dlogDp
PM (mg)
[PM]
dM
N (particles)
0.2
-0.69897
0.30103
0.283
22.293252
85.9
32.0164
6.710938
7.25E+13
0.4
-0.39794
0.168792
0.486
8.1540827
12.8
4.770779
1.376344
2.13E+12
0.59
-0.22915
0.18339
0.729
42.25955
9.3
3.466269
7.75
4.59E+11
0.9
-0.04576
0.324511
1.308
0.8404251
1.2
0.447261
0.272727
1.02E+10
1.9
0.278754
0.198368
2.387
7.1551728
4.4
1.639955
1.419355
6.18E+09
3
0.477121
0.176091
3.674
5.3346994
3.1
1.155423
0.939394
1.19E+09
4.5
0.653213
0.166331
5.450
19.839907
3.3
1.229966
3.3
3.89E+08
6.6
0.819544
0.201645
8.325
4.132668
1
0.372717
0.833333
3.31 E+07
Particle Size Distribution
45
40
35
30
25
20
15
10
5
0
0.1
1
10
Particle Aerodiameter Di [um]
Figure 4-38. Andersen 3-25 June 2008, C&D Run 1
84

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
D50 (um)
Log D50
dlogDp
Di (um)
dM/dlogDp
PM (mg)
[PM]
dM
N (particles)
0.2
-0.69897
0.352183
0.300
35.355568
38.6
16.7462
12.45161
2.73E+13
0.45
-0.34679
0.166331
0.545
5.0371591
3.1
1.344902
0.837838
3.66E+11
0.66
-0.18046
0.221849
0.852
3.4745895
3.7
1.605206
0.770833
1.14E+11
1.1
0.041393
0.30103
1.556
11.389468
4.8
2.08243
3.428571
2.44E+10
2.2
0.342423
0.189056
2.735
3.702602
1.4
0.607375
0.7
1.31E+09
3.4
0.531479
0.167491
4.123
2.2530064
2
0.867679
0.377358
5.45E+08
5
0.69897
0.164353
6.042
10.077403
5.3
2.299349
1.65625
4.59E+08
7.3
0.863323
0.204863
9.242
7.8100974
3.2
1.388286
1.6
7.74E+07
Particle Size Distribution
0 —
0.1	1	10
Particle Aerodiameter Di [um]
Figure 4-39. Andersen 4-25 June 2008, C&D Run 2
85

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
D50 (um)
Log D50
dlogDp
Di (um)
dM/dlogDp
PM (mg)
[PM]
dM
N (particles)
0.2
-0.69897
0.332438
0.293
12.163088
83.7
38.28911
4.043478
6.34E+13
0.43
-0.36653
0.165872
0.520
12.479495
20.7
9.46935
2.07
2.80E+12
0.63
-0.20066
0.200659
0.794
16.076026
10
4.574565
3.225806
3.82E+11
1
0
0.322219
1.449
6.8719836
3.1
1.418115
2.214286
1.95E+10
2.1
0.322219
0.182931
2.592
4.0279853
1.4
0.640439
0.736842
1.53E+09
3.2
0.50515
0.166948
3.878
3.0758912
1.9
0.869167
0.513514
6.22E+08
4.7
0.672098
0.173
5.736
7.6383074
3.7
1.692589
1.321429
3.74E+08
7
0.845098
0.20412
8.854
0.7706417
2.8
1.280878
0.157303
7.70E+07
Particle Size Distribution
Particle Aerodiameter Di [urn]
Figure 4-40. Andersen 5-25 June 2008, C&D Run 3
86

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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Table 4-27. Visible Emissions (% Opacity)

Veg Run 1
Veg Run 2
Veg Run 3
C&D Run 1
C&D Run 2
C&D Run 3

6-24-M9-1
6-24-M9-2
6-25-M9-1
6-25-M9-2
6-26-M9-1
6-26-M9-2
Single Highest 6-Minute
13
17
17
19
00
CO
15
Rolling Average
8.3
8.3
17
19
4.8
13
Highest Observed
30
25
25
30
20
25
Opacity Reading
15
20
25
35
15
35
Lowest Observed
0
0
0
0
0
0
Opacity Reading
0
0
0
0
0
0
Table 4-28. Filterable and Condensable Particulate Test Results for All Vegetative and C&D
Debris Burns

Veg Run 1
Veg Run 2
C&D Run 1
C&D Run 2
C&D Run 3

I-ACB-M202-01
I-ACB-M202-02
II-ACB-M202-01
II-ACB-M202-02
II-ACB-M202-03

mg/DSCM
mg/DSCM
mg/DSCM
mg/DSCM
mg/DSCM
Filterable Particulate PMio
16
9.8
12
21
3.8
Organic Condensable Particulate
1.8
1.1
1.8
5.0
1.4
Inorganic Condensable Particulate
62
23
27
28
67
Total Particulate 
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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
4.5.2.12 Results of Microscopy Analysis of Air Samples and Ash
Samples collected for asbestos analysis during the incinerator study were analyzed by Bureau Veritas (BV)
of Kennesaw, GA. The samples collected were analyzed for the presence of asbestos fibers and forsterite
fibers. Samples analyzed included three air emission samples and two bulk samples of ash. The air
emission samples, taken during C&D burning, were analyzed by transmission electron microscopy (TEM)
utilizing ISO 10312 (U.S. EPA, 1987). The ash samples were analyzed using the EPA 600 polarized light
microscopy (PLM) method and by drop mount TEM qualitative verification.
4.5.2.12.1 Airborne Asbestos Samples
The water impinger samples were sonicated and the entire volume was filtered onto new MCE 47 mm 0.45
micron filters. The filters were then ashed in a muffle furnace to remove organic particles that may have
been present. The ashed residue was then treated with dilute hydrochloric acid to remove soluble materials.
This residual material was then suspended in 100 mL deionized water and sonicated. The entire contents
were then filtered onto MCE 47 mm 0.45 micron filters. Portions of the filter were then prepared and
examined as indicated below.
The air samples were analyzed by TEM using ISO 10312; structures were counted according to the protocol
in ISO 10312, Annex C, "Structure counting criteria". The method was modified to count all structures >0.5
jjm with a length to width aspect ratio of >3:1. Phase Contrast Microscopy Equivalent (PCME) structures
(structures > 5 jjm in length and 0.2 to 3 jjm in width) are also reported. BV observed tremolite in all three
samples; chrysotile, and actinolite were also observed in two of the three samples. No forsterite was
observed in any of the air samples. The results of analysis are in Table 4-29.
Table 4-29. Analytical Results of TEM Asbestos Analysis of Air Samples
Sam-
ple
Vol-
ume
(DSCM)
Number
of
Structures
Structures/
mm2
on Filter
Laboratory Analytical
Limit of
Detection
(structures / mm2)
Structures/cc
In
Stack Gas
Laboratory Analytical
Sensitivity
(structures/cc)


Total
PCME
Total
PCME
Total
PCME
Total
Q
s
PCME
Q
s
Total
PCME
C&D
Run1
1.816
8=
1
8.2
3.1
3.1
3.1
0.0060
0.0022
0.00075
0.0022
0.00075
0.00075
C&D
Run 2
1.327
3"
1
3.1
3.1
3.1
3.1
0.0031
0.0031
0.0010
0.0031
0.0010
0.0010
C&D
Run 3
2.678
3C
0
3.1
<3.1
3.1
3.1
0.0015
0.0015
<0.00050
0.0015
0.00050
0.00050
*MDL - total method detection limit
a - tremolite, chrysotile, and actinolite
b - tremolite, chrysotile
c-tremolite, actinolite
88

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On each sample, 94 grid openings of 0.0104 mm2 were analyzed, for a total analytical area of 0.98 mm2 on
a filter of 1320 mm2 effective filter area. The analytical sensitivity of the method is based on a single fiber;
the limit of detection for the method is based on 2.99 fibers per analysis (as per ISO 10312). These counts
were obtained during two rounds of analyses and summed to obtain the results shown in Table 4-28. The
second round of analyses was ordered to add examinations of many more grid openings than were counted
in the first round for the purpose of improving the analytical sensitivity and increasing the confidence in the
results. Both analytical reports can be seen in Appendix C. The second analytical report incorporates data
from the first, i.e., the second report is a revised report rather than a supplemental report.
4.5.2.12.2 Ash Samples
Two ash samples were analyzed by PLM using EPA/600/R-93/116 (U.S. EPA, 1993) with the visual
estimation technique and identification by refractive index measurement. No asbestos or forsterite was
found by BV. The ash samples were also analyzed by preparing a drop mount on a carbon-coated grid to
verify at high magnification the presence or absence of asbestos or forsterite fibers in the bulk sample. No
such fibers in either sample were found by TEM analysis. Results of PLM and TEM analysis of ash samples
are in Table 4-30. The reliable limit of quantitation of the method is 1%, although asbestos may be
qualitatively detected at concentrations less than 1%. Samples in which asbestos is detected at <1% are
reported as "trace, <1%". "None detected" indicates that no asbestos fibers were observed.
Table 4-30. Analytical Results PLM and TEM Analysis of Ash Samples
Sample
PLM Analysis
TEM Analysis
Composite Ash Sample 1
No asbestos detected
No asbestos detected
Composite Ash Sample 2
No asbestos detected
No asbestos detected
89

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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5. Discussion of Results
All emissions results were estimated based on the use of the airflow calculations of Equation (10) in Section
3.4 and averaging over the triplicate samples. Those averages are presented in the following tables. Non-
detects were taken as zero for the purposes of averaging within conditions. If a more complete analysis is
desired that includes detection limits and the raw data, please see the appendices. In the appendix
containing the emissions calculations, analytes that fell below laboratory detection limits were calculated
as if they were in fact seen at those limits and are reported in red. These values were carried forward into
the "within condition" averages and represent a "worst case" result.
Isokineticity of the sampling scoop during the sampling program averaged 65.9% percent with variation
between 47.8% and 90.9% based on a bulk gas velocity of 15 feet per second (seen during the 2005
preliminary test) and scoop temperature variation due to ACB feed irregularities. This non-ideal isokineticity
(in comparison with the EPA requirement of maintaining between 90% and 110% isokinetic during
compliance testing using EPA Method 5) would result in a slight overestimation of the emission rates of any
analyte existing in particulate form or associated with particulate matter.
If isokinetic rate calculations are based upon the estimated total flow rates presented in Table 5-1, variation
was between 6.1% and 46.5% isokinetic. The values in Table 5-1 were affected by significant wind during
the tests; the wind was calm during the 2005 pre-test period.
The following assumptions were made in order to generate the emissions estimates:
•	The feed composition of all the vegetative debris and C&D debris is based on the feed composition for
the one vegetative debris sample that was taken during the test (i.e., the C&D debris was too
heterogeneous to procure a representative sample to use for proximate and ultimate analysis). This
detail is relevant because all mass emission rates and emission factors presented below are calculated
based on the exhaust flow rates, and the ACB exhaust flow rates were calculated based on the carbon
and hydrogen content of the vegetative debris sample. As explained in Section 5.1, this assumption is
supported by the fact that the NOx results for vegetative and C&D debris are quite similar.
•	The gas sample that is being withdrawn by the sampling scoop represents gases that enter the ACB
through the blower, entrained into the gas flow due to fluid mechanics, drawn into the ACB through
gaps in the equipment due to natural draft, and ambient air due to wind blowing across the top of the
ACB unit and being drawn into the scoop. The additional dilution due to the wind does not affect the
mass emission rate or emission factor calculations.
•	The mean pollutant concentrations in the sampling duct were equal to the mean pollutant concentration
emitted into the atmosphere from the ACB; based on visual observations and previous velocity
traverses (Miller and Lemieux, 2007). This appears to be a reasonable assumption. There does not
90

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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appear to be a significant velocity or concentration gradient along the long end of the ACB opposite the
air plenum.
•	The water vapor measured in the sampling duct was due only to water present in the feed or water
generated during the combustion process (i.e., rainfall and overspray from debris misting procedures
did not significantly affect measured water vapor estimates).
•	All of the carbon in the feed is converted to CO, hydrocarbons, or CO2 or remains behind in the ash.
Although this assumption is not quantitatively correct, since some of the carbon is emitted in the form
of soot and trace organic air toxics that are not detected by the hydrocarbon analyzer, the relative
contribution of these species to the overall amount of carbon released into the air is very small.
•	The amount of moisture remaining behind in the ash is negligible. Although the ash was sampled for
moisture as part of the proximate and ultimate analysis, the ash removal process involved significant
quantities of water being sprayed on the ash, and since the ash was above the boiling point of water
while in the ACB, the moisture in the ash is assumed to be negligible.
•	The emission factors from C&D debris combustion inherently contain the emissions from the vegetative
debris used as supplemental fuel.
Care must be taken in examining the mass emissions rates and estimated emission factors due to the
differences in engineering units used to present the data. The units to present the data were selected to
have a range of values appropriate for visual comparison in tabular format.
Section 5.8 includes an analysis of variance, where a discussion is included about whether emissions of a
given pollutant or set of pollutants were higher from combustion of C&D debris than from combustion of the
vegetative debris used in the tests.
5.1 Fixed Combustion Gases
Emissions rates and estimated emission factors for CO, NOx (reported as NO), SO2, and THC (reported as
propane) are shown in Table 5-1. Figure 5-1 shows the data from Table 5-1 in graphical form. As mentioned
in the evaluation of the CEM data, the emissions of NOx are virtually identical from both the vegetative and
C&D debris. Since NOx emissions are primarily a function of the firebox temperature for a combustion
system like an ACB that is burning debris, the fact that the estimated emission factor for NOx was essentially
the same for both vegetative and C&D debris suggests that the initial assumption that the bulk composition
of the C&D debris was the same as the vegetative debris was a reasonable assumption, and that observed
differences between vegetative and C&D debris were primarily due to effects resulting from minor or maybe
even trace constituents in the C&D debris. Section 5.8.7 includes a discussion of the statistical significance
of differences in emissions of fixed combustion gases between the Veg and C&D test conditions.
91

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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Table 5-1. Emission Rates and Estimated Emission Factors for CO, NOx, S02, and THC

Emission Rate (g/hr)
Emission Factor (mg/kg debris)

Veg
Run
1
Veg
Run
2
Veg
Run
3
C&D
Run
1
C&D
Run
2
C&D
Run
3
Veg
Run
1
Veg
Run
2
Veg
Run
3
C&D
Run
1
C&D
Run
2
C&D
Run
3
CO
8494
1732
5
2688
0
4642
6
8125
3
4655
0
1951
3979
4357
6916
9735
1091
7
NOx (as NO)
2950
3345
5767
8982
7280
3215
678
768
935
1338
872
754
S02
1838
1136
346
9572
3533
1
6059
422
261
56
1426
4233
1421
THC (as
propane)
737
1123
1194
4198
1097
8
5363
169
258
194
625
1315
1258
l.E+05
l.E+04
l.E+03
ง l.E+02
l.E+01
1.E+00
Vegetative Debris
IC&D Debris
O
u
O
10
x
O
u
x
Figure 5-1. Emission Factors for Fixed Combustion Gases: Vegetative Debris vs. C&D Debris
(Error bars represent the range of data)
92

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 5-2. Emission Rates and Estimated Emission Factors for PCDDs/Fs and PCBs

Emission Rate (|jg/hr)
Emission Factor (ng/kg debris)

Veg
Run
1
Veg
Run
2
Veg
Run
3
C&D
Run 1
C&D
Run 2
C&D
Run 3
Veg
Run
1
Veg
Run
2
Veg
Run
3
C&D
Run
1
C&D
Run
2
C&D
Run
3
Total
CDD/CDF
6896
997
9
2813
4
25769
5
33880
4
42623
3
158
4
229
2
456
1
3838
6
4059
4
9996
5
PCDD/PCD
FTEQ
162
226
694
6170
6656
10343
37
52
113
919
797
2426
Total PCBs
(Mono-
Nona)
1571
8
448
8
2082
7
21836
8
58784
9
31197
6
361
0
103
1
337
6
3252
8
7043
3
7316
8
PCB TEQ
5
3
18
209
375
628
1
1
3
31
45
147
PCDD/F
TEQ+PCB
TEQ
167
230
712
6379
7031
10971
38
53
115
950
842
2573
l.E+05
l.E + 04
ฆfl l.F + 03
~I l.E+02
c
W) l.E+01
ฃ
1.E+00
ca Cr
U LU
Vegetative Debris
I C&D Debris
l.E-01
Figure 5-2. Emission Factors for PCDDs/Fs and PCBs: Vegetative Debris vs. C&D Debris (Error
bars represent the range of data)
93

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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5.2	Dioxins and PCBs
Table 5-2 lists the emission rates and estimated emission factors for dioxins and PCBs, both in terms of
total emissions and emissions in terms of the WHO 1998 TEQ values. Figure 5-2 illustrates these results
graphically. In terms of TEQ, the emission factors from vegetative debris were slightly higher than published
literature from combustion of biomass in forest fires (Gullett and Touati, 2003, UNEP, 2005) and slightly
lower than combustion of trash in burn barrels (Lemieux et al., 2003). The emissions of these chlorinated
organic compounds from C&D debris were significantly higher than from the vegetative debris. One
possible explanation for the PCDD/F levels from the vegetative debris burns being elevated over that of
forest fires and other agricultural burning is that the vegetative debris used in these tests had sat for an
unknown period of time in brackish water prior to being dried out and brought to the test site. It is not
necessary to have an organic source of chlorine to form PCDD/F (Preto et al., 2005, Wikstrom and
Marklund, 2001), although in the case of the C&D debris, the presence of plastics (possibly chlorinated)
and household wiring (which commonly has polyvinyl chloride insulation) were visually observed. Another
possible explanation is that the time-temperature history in an ACD is more amenable to PCDD/F formation.
It is not possible to determine which explanation is more likely, although the presence of chlorophenols in
the emissions from the vegetative burns where chlorophenols are not a likely air pollutant from the
combustion of clean wood (Lemieux et al., 2004), does suggest that there were elevated levels of potential
precursors for PCDD/F formation (Altarawneh et al., 2009, Briois et al., 2007) in the emissions from burning
the vegetative debris used in these tests. Section 5.8.5 includes a discussion of the statistical significance
of differences in PCCD/F emissions between the Veg and C&D test conditions.
5.3	Metals
Table 5-3 lists the emission rates and estimated emission factors for airborne metals. It should be noted
that arsenic is normally present in negligible quantities in virgin wood (Zhurinsh et al., 2005). The fact that
arsenic emissions were observed in the effluent from the ACB suggests that the environment that the wood
was exposed to (which included sediments from the storm) may have impacted As emissions. Figure 5-3
shows the results in graphical format. Mercury was not detected from the vegetative debris runs and
selenium was not detected in the C&D debris runs. The C&D airborne metal results appeared to be
consistently higher than from the vegetative debris. Section 5.8.1 includes a discussion of the statistical
significance of differences in metal emissions between the Veg and C&D test conditions.
5.4	Particulate Matter and Acid Gases
Filterable PM measurements were made using two different sampling methods: one specifically directed at
PM (Method 5/202), and the other on the filter used in the hydrogen halide acid gas sampling train (Method
26). Both are presented here. Emissions rates and estimated emission factors for the Method 5/202
sampling train are shown in Table 5-4. Emissions rates and estimated emission factors for the Method 26
sampling train are shown in Table 5-5. HCI emissions were significantly higher for the C&D debris. Other
species, with the exception of Br2, were about a factor of 2 higher for the C&D debris burns. Br2 emissions
were about the same for both feed types. Figures 5-4 and 5-5 show the same data in graphical form.
Section 5.8.3 includes a discussion of the statistical significance of differences in PM and acid gas
emissions between the Veg and C&D test conditions.
5.5	Semivolatile Organic Compounds (SVOCs)
Table 5-6 lists the emissions rates and estimated emission factors for SVOC target analytes that were
identified at levels above the detection limit. Table 5-7 lists the emission rates and estimated emission
94

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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factors for PAHs. Note that some of the target analytes for the SVOC analysis were also target analytes for
the PAH analysis. However, the PAH analytical method is more specific and accurate for those analytes
than the general SVOC method. In general, SVOC emissions were higher from C&D debris. Section 5.8.4
includes a discussion of the statistical significance of differences in SVOC emissions between the Veg and
C&D test conditions.
5.6	Volatile Organic Compounds (VOCs)
Table 5-8 lists the VOC results for target analytes that were present above the detection limits. In general,
the VOC emissions from C&D debris appeared to be higher than the emissions from vegetative debris.
However, for most compounds this difference may not be statistically significant.
5.7	Asbestos
Conversion of asbestos results in Table 4-28 into emission rates and estimated emission factors yields the
results in Table 5-9. Great care must be taken in using these values, however, since these values are
essentially derived by extrapolating a small number of fibers in a sampling train to a large volume of gas
and debris feed. The analytical results thus range from "I.Oxto 2.7xthe limit of detection of the method as
expressed in ISO 10312 which is based on 2.99 fibers per sample. For the PCME fraction, the analytical
results are all less than or equal to one-third of the limit of detection. Therefore, while the results are
extrapolated by calculation of all factors into what appears to be a quite high concentration of
structures/hour, the basis of this result is in fact a numerically very few fibers found by TEM analysis.
Table 5-3. Emission Rates and Estimated Emission Factors for Airborne Metals

Emission Rate (mg/hr)
Emission Factor (|jg/kg debris)

Veg
Run
1
Veg
Run
2
Veg
Run
3
C&D
Run 1
C&D
Run 2
C&D
Run 3
Veg
Run
1
Veg
Run
2
Veg
Run
3
C&D
Run
1
C&D
Run
2
C&D
Run
3
Antimony
735
2278
284
22150
56483
2819
169
523
46
3299
6767
661
Arsenic
509
9
765
1433
2
12155
2122
98791
117
1
176
232
3
1811
254
2316
9
Barium
102
2
1214
2058
5212
9525
3174
235
279
334
776
1141
744
Beryllium
3.2
5.6
3.5
7.4
10
ND
0.7
1.3
0.6
1.1
1.2
ND
Cadmium
455
711
890
4609
9629
3500
104
163
144
687
1154
821
Chromium
290
1
3585
1589
2569
4011
25444
666
823
258
383
481
5967
Cobalt
ND
ND
4181
ND
ND
241
ND
ND
678
ND
ND
57
Lead
773
1
1288
2
7308
18185
4
15252
0
25519
8
177
5
295
8
118
5
2708
9
1827
4
5985
2
Manganes
e
276
0
5116
8677
17106
11397
10868
634
117
5
140
7
2548
1366
2549
Mercury
ND
ND
ND
763
1454
229
ND
ND
ND
114
174
54
Nickel
301
6
4863
1838
3592
3660
17585
693
111
7
298
535
438
4124
Selenium
96
ND
ND
ND
ND
ND
22
ND
ND
ND
ND
ND
95

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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Silver
77
93
43
112
150
165
18
21
6.9
17
18
39
ND - not detected
Vegetative Debris
I C&D Debris
<ฃ	CO
CD	C_)
Figure 5-3. Emission Factors for Airborne Metals: Vegetative Debris vs. C&D Debris (Error bars
represent the range of data)
96

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Table 5-4. Emission Rates and Estimated Emission Factors of Particulate Matter

Emission Rate (g/hr

Emission Factor (mg/kg debris)

Veg
Run 1
Veg
Run 2
Veg
Run 3
C&D
Run 1
C&D
Run 2
C&D
Run 3
Veg
Run 1
Veg
Run 2
Veg
Run 3
C&D
Run 1
C&D
Run 2
C&D
Run 3
Filterable
Particulate
PM2.5
2101
2024
NA
6906
9795
1534
483
465
NA
1029
1174
360
Organic
Condensible
Particulate
233
227
NA
1002
2321
565
54
52
NA
149
278
133
Inorganic
Condensible
Particulate
8081
4689
NA
14870
13138
26841
1856
1077
NA
2215
1574
6295
Total
Particulate

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 5-5. Emission Rates and Estimated Emission Factors of Filterable Particulate Matter and
Acid Gases

Emission Rate (g/hr)
Emission Factor (mg/kg debris)

Veg
Run 1
Veg
Run
2
Veg
Run
3
C&D
Run 1
C&D
Run 2
C&D
Run 3
Veg
Run 1
Veg
Run
2
Veg
Run
3
C&D
Run
1
C&D
Run
2
C&D
Run 3
Filterable
Particulate
8507
8398
NA
21605
21150
12844
1954
1928
NA
3218
2534
3012
HCI
1097
159
NA
8015
14055
44338
252
37
NA
1194
1684
10399
HF
33
43
NA
156
274
206
7.5
10
NA
23
33
48
HBr
38
62
NA
221
228
189
9
14
NA
33
27
44
CI2
35
51
NA
180
225
210
8
12
NA
27
27
49
Br2
15
29
NA
44
48
38
3.4
6.6
NA
6.5
5.8
9
NA - Not Available
l.E + 04
l.E + 03
1.E + 00

1 1

1 I

II
H
H
1—1
ฆ
Vegetative Debris
I C&D Debris
Figure 5-5. Emission Factors for Particulate Matter and Acid Gases: Vegetative Debris vs. C&D
Debris (Error bars represent the range of data)
98

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Table 5-6. Emission Rates and Estimated Emission Factors for SVOCs

Emission Rate (mg/hr)
Emission Factor (|jg/kg debris


Veg
Run 1
Veg
Run
2
Veg
Run 3
C&D
Run 1
C&D
Run 2
C&D
Run 3
Veg
Run 1
Veg
Run
2
Veg
Run
3
C&D
Run
1
C&D
Run 2
C&D
Run 3
Aniline
ND
ND
ND
ND
ND
5406
ND
ND
ND
ND
ND
1268
2-Chlorophenol
ND
ND
ND
12323
27990
15057
ND
ND
ND
1836
3354
3531
1,3-Dichlorobenzene
ND
ND
ND
ND
1312
1046
ND
ND
ND
ND
157
245
1,4-Dichlorobenzene
ND
163
ND
ND
1237
987
ND
37
ND
ND
148
231
Benzyl Alcohol
3502
ND
2573
ND
15976
8916
804
ND
417
ND
1914
2091
1,2-Dichlorobenzene
ND
ND
ND
ND
ND
881
ND
ND
ND
ND
ND
207
2-Methylphenol
ND
ND
ND
ND
26875
12888
ND
ND
ND
ND
3220
3023
3 & 4-Methylphenol
ND
ND
ND
5917
46318
18981
ND
ND
ND
881
5550
4452
Nitrobenzene
ND
ND
ND
5639
83627
33363
ND
ND
ND
840
10020
7825
2-Nitrophenol
ND
ND
3388
7613
13348
9860
ND
ND
549
1134
1599
2312
2,4-Dimethylphenol
ND
ND
ND
1784
11030
5921
ND
ND
ND
266
1322
1389
Bis(2-
chloroethoxy)methane
ND
ND
ND
ND
8073
ND
ND
ND
ND
ND
967
ND
2,4-Dichlorophenol
2758
ND
ND
ND
14020
9421
633
ND
ND
ND
1680
2209
1,2,4-Trichlorobenzene
ND
ND
41
ND
ND
415
ND
ND
7
ND
ND
97
Naphthalene
3023
3393
17124
41259
126608
58082
694
779
2776
6146
15169
13622
4-Chloro-3-methylphenol
ND
ND
ND
ND
ND
6015
ND
ND
ND
ND
ND
1411
2-Methylnaphthalene
1773
1620
2018
8371
19460
11044
407
372
327
1247
2332
2590
1 -Methylnaphthalene
440
413
473
3192
ND
ND
101
95
77
476
ND
ND
2,4,5-T richlorophenol
151
ND
ND
ND
ND
ND
35
ND
ND
ND
ND
ND
2-Chloronaphthalene
ND
ND
41
ND
ND
307
ND
ND
7
ND
ND
72
2-Nitroaniline
ND
ND
142
ND
10364
ND
ND
ND
23
ND
1242
ND
Dimethyl phthalate
193
ND
ND
ND
834
ND
44
ND
ND
ND
100
ND
1,3-Dinitrobezene
ND
ND
361
5454
16855
6257
ND
ND
59
812
2020
1467
Acenaphthylene
222
248
562
6898
20409
7888
51
57
91
1028
2445
1850
2,6-Dinitrotoluene
194
ND
ND
ND
ND
ND
44
ND
ND
ND
ND
ND
Acenaphthene
40
ND
ND
ND
1880
ND
9
ND
ND
ND
225
ND
4-Nitrophenol
ND
ND
ND
ND
22957
11673
ND
ND
ND
ND
2751
2738
Dibenzofuran
298
266
1030
4205
14506
5599
68
61
167
626
1738
1313
2,4-Dinitrotoluene
ND
ND
ND
ND
ND
857
ND
ND
ND
ND
ND
201
2,3,4,6-Tetnachlorophenol
ND
ND
ND
ND
ND
1847
ND
ND
ND
ND
ND
433
2,3,5,6-Tetrachlorophenol
ND
ND
ND
ND
ND
1420
ND
ND
ND
ND
ND
333
Diethylphthalate
266
ND
372
ND
814
ND
61
ND
60
ND
98
ND
Fluorene
ND
63
163
1309
6488
2302
ND
14
26
195
777
540
4,6-Dinitro-2-
methylphenol
ND
ND
ND
ND
ND
866
ND
ND
ND
ND
ND
203
Azobenzene
ND
ND
ND
ND
545
ND
ND
ND
ND
ND
65
ND
99

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72

Emission Rate (mg/hr)
Emission Factor (|jg/kg debris)

Veg
Run 1
Veg
Run
2
Veg
Run 3
C&D
Run 1
C&D
Run 2
C&D
Run 3
Veg
Run 1
Veg
Run
2
Veg
Run
3
C&D
Run
1
C&D
Run 2
C&D
Run 3
Phenanthrene
598
854
2951
11388
40396
12926
137
196
478
1696
4840
3032
Anthracene
660
1002
3257
12569
38353
13391
152
230
528
1872
4595
3141
Carbazole
ND
51
ND
175
850
ND
ND
12
ND
26
102
ND
Di-n-butyl phthalate
2450
621
490
2595
ND
1091
563
143
79
387
ND
256
Fluoranthene
185
ND
1546
5150
12114
3479
42
ND
251
767
1451
816
Pyrene
146
ND
1250
4672
10433
2859
33
ND
203
696
1250
671
Benzyl butyl phthalate
ND
ND
ND
633
ND
ND
ND
ND
ND
94
ND
ND
Benz[a]anthracene
ND
ND
ND
ND
3114
1132
ND
ND
ND
ND
373
265
Chrysene
ND
ND
ND
ND
11600
5475
ND
ND
ND
ND
1390
1284
Bis(2-ethylhexyl)
phthalate
1826
775
673
4866
101527
5976
419
178
109
725
12164
1402
Di-n-octyl phthalate
2726
ND
ND
ND
ND
296
626
ND
ND
ND
ND
69
Dibenz[a,h]anthracene
ND
ND
ND
ND
243
ND
ND
ND
ND
ND
29
ND
ND - Not Detected
100

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 5-7. Emission Rates and Estimated Emission Factors for PAHs

Emission Rate (mg/hr)
Emission Factor (|jg/kg debris)

Veg
Run
1
Veg
Run
2
Veg
Run 3
C&D
Run 1
C&D
Run 2
C&D
Run 3
Veg
Run
1
Veg
Run
2
Veg
Run
3
C&D
Run
1
C&D
Run
2
C&D
Run
3
Naphthalene
4225
7063
15032
39630
54227
29339
970
1622
2437
5903
6497
6881
2-Methylnaphthalene
712
1290
1310
5754
13923
8911
163
296
212
857
1668
2090
Acenaphthylene
546
711
1472
12810
22961
13093
125
163
239
1908
2751
3071
Acenaphthene
62
97
45
557
2589
1138
14
22
7.2
83
310
267
Fluorene
120
219
619
2912
8439
4373
27
50
100
434
1011
1026
Phenanthrene
835
1464
4813
12910
23083
13230
192
336
780
1923
2766
3103
Anthracene
81
125
224
1761
6644
2543
19
29
36
262
796
596
Fluoranthene
302
517
2636
6345
10088
5025
69
119
427
945
1209
1178
Pyrene
189
311
1018
2672
3066
1775
44
71
165
398
367
416
Benzo(a)Anthracene
26
52
155
1071
2430
1392
5.9
12
25
160
291
326
Chrysene
49
94
372
1361
2724
1570
11
22
60
203
326
368
Benzo(b)Fluoranthene
36
64
345
1521
2809
1419
8
15
56
227
337
333
Benzo(k)Fluoranthene
11
22
129
525
870
446
2.5
4.9
21
78
104
105
Benzo(e)Pyrene
19
34
169
908
1698
641
4.5
8
27
135
203
150
Benzo(a)Pyrene
11
10
15
405
1368
409
2.5
2.2
2.5
60
164
96
Perylene
1.7
1.0
0.1
46
194
32
0.4
0.2
0.02
6.8
23
7.6
lndeno(1,2,3-cd)Pyrene
13
25
124
775
1087
470
2.9
5.8
20
115
130
110
Dibenzo(a,h)Anthracene
2.2
3.6
15
101
293
145
0.5
0.8
2.4
15
35
34
Benzo(ghi)Perylene
15
26
95
715
1181
404
3.4
5.9
15
106
142
95
101

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
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Table 5-8. Emission Rates and Estimated Emission Factors for VOCs

Emission Rate (mg/hr)
Emission Factor (|jg/kg debris)

Veg
Run
1
Veg
Run
2
Veg
Run 3
C&D
Run 1
C&D
Run 2
C&D Run
3
Veg
Run
1
Veg
Run
2
Veg
Run 3
C&D
Run 1
C&D
Run 2
C&D
Run 3
Dichlorodifluoromethane
NA
NA
ND
1553
ND
994
NA
NA
ND
231
ND
233
Chloromethane
NA
NA
4935
18706
ND
100897
NA
NA
800
2786
ND
23663
Vinyl chloride
NA
NA
ND
4691
17241
34807
NA
NA
ND
699
2066
8163
1,3-Butadiene
NA
NA
1149
23255
129294
117735
NA
NA
186
3464
15491
27613
Bromomethane
NA
NA
ND
5495
ND
6182
NA
NA
ND
819
ND
1450
T richloromonofluoromethane
NA
NA
556
1592
1327
1153
NA
NA
90
237
159
271
1,1-dichloroethene
NA
NA
349
ND
ND
570
NA
NA
57
ND
ND
134
Ethanol
NA
NA
11276
10818
ND
14427
NA
NA
1828
1612
ND
3384
Carbon disulfide
NA
NA
20284
24420
ND
24346
NA
NA
3288
3638
ND
5710
Isopropyl alcohol
NA
NA
243
ND
ND
ND
NA
NA
39
ND
ND
ND
Methylene chloride
NA
NA
3631
25844
28084
7134
NA
NA
589
3850
3365
1673
Acetone
NA
NA
21401
72130
319357
53573
NA
NA
3469
10744
38264
12564
Vinyl acetate
NA
NA
ND
1775
1413
1525
NA
NA
ND
264
169
358
Chloroform
NA
NA
ND
ND
1787
882
NA
NA
ND
ND
214
207
Ethyl Acetate
NA
NA
ND
4326
4950
11197
NA
NA
ND
644
593
2626
Tetrahydrofuran
NA
NA
ND
969
1935
2209
NA
NA
ND
144
232
518
Carbon Tetrachloride
NA
NA
ND
ND
ND
1472
NA
NA
ND
ND
ND
345
2-Butanone
NA
NA
ND
14966
ND
33731
NA
NA
ND
2229
ND
7911
Heptane
NA
NA
4496
1531
10362
ND
NA
NA
729
228
1241
ND
Benzene
NA
NA
220079
157106
508089
346581
NA
NA
35675
23402
60876
81284
T richloroethylene
NA
NA
664
1354
12661
1080
NA
NA
108
202
1517
253
1,4-dioxane
NA
NA
435
999
740
ND
NA
NA
70
149
89
ND
Toluene
NA
NA
18040
28197
97090
85395
NA
NA
2924
4200
11633
20028
4-Methyl-2-pentanone
NA
NA
519
1172
1257
ND
NA
NA
84
175
151
ND
Tetrachloroethylene
NA
NA
839
2247
4947
ND
NA
NA
136
335
593
ND
Ethylbenzene
NA
NA
1195
4674
10203
12713
NA
NA
194
696
1222
2982
Chloro benzene
NA
NA
1016
1982
5186
7241
NA
NA
165
295
621
1698
m/p-Xylene
NA
NA
2008
9760
13538
19888
NA
NA
326
1454
1622
4664
o-Xylene
NA
NA
761
3715
5496
7596
NA
NA
123
553
659
1781
Styrene
NA
NA
5123
18045
37396
110024
NA
NA
830
2688
4481
25804
Tribromomethane
NA
NA
ND
ND
2368
ND
NA
NA
ND
ND
284
ND
1 -ethyl-4-methylbenzene
NA
NA
ND
3439
ND
5106
NA
NA
ND
512
ND
1197
1,3,5-trimethylbenzene
NA
NA
375
ND
ND
ND
NA
NA
61
ND
ND
ND
1,2,4-trimethylbenzene
NA
NA
520
3857
2124
3834
NA
NA
84
574
254
899
Benzyl chloride
NA
NA
ND
3680
ND
62300
NA
NA
ND
548
ND
14611
1,2-dichlorobenzene
NA
NA
ND
ND
ND
1444
NA
NA
ND
ND
ND
339
NA - Not Available; ND - Not Detected
102

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Table 5-9. Emission Rates and Estimated Emission Factors for Asbestos

Emission Rate (structures/hr)
Emission Factor (structures/kg debris)
C&D Run 1
C&D Run 2
C&D Run 3
C&D Run 1
C&D Run 2
C&D Run 3
Based on
Total
Structures
3.3E+09
1.4E+09
6.1E+08
5.0E+05
1.7E+05
1.4E+05
Based on
PCME
4.2E+08
4.6E+08
ND
6.2E+04
5.6E+04
ND
Based on
Method
Detection
Limit
1.2E+09
1.4E+09
6.1E+08
1.8E+05
1.7E+05
1.4E+05
ND = Not Detected
5.8 Analysis of Variance between Vegetative Debris and C&D Debris Emission
Factors
A One-Way Analysis of Variance (ANOVA) statistical analysis was performed on the emission factor data
to determine whether a statistically significant difference was observed between emissions of different
pollutants from burning vegetative (VEG) or C&D (CD) debris in an ACB.
There are some assumptions that must hold true for a standard ANOVA analysis to be valid. First, the data
must be normally distributed; second, the variances in the conditions being investigated must be equal.
Unfortunately, with a maximum of only three data points, one cannot adequately assess the validity of these
assumptions. However, even with only three observations, the data do suggest that there is a difference
between the variability exhibited by the VEG and CD emissions and that a normality assumption is
problematic.
Because of this, a standard ANOVA was not utilized, and a nonparametric analysis (hereafter referenced
as HL) was performed by Alion Science and Technology, Inc. to analyze the data for differences between
the test conditions. The difference between the CD and VEG emissions levels was estimated (as CD minus
VEG) using Hodges-Lehmann estimates (Hodges and Lehmann, 1963, Hollander and Wolfe, 1973). Briefly,
these estimates are formed by calculating all possible differences for the given chemical and using the
median of these differences as the estimate. The differences were also used to provide a 90% confidence
interval for this difference (Hollander and Wolfe, 1973). One may utilize the confidence intervals for a formal
statistical significance test as follows. If the number 0 lies outside the confidence interval, then the VEG
and CD emissions are statistically significantly different at the 10% level. (N. B., The reader will note that
many of the confidence intervals displayed below contain 0 as one of the bounds. The decision to declare
statistical significance only if 0 is strictly outside the confidence interval is conservative. This was deemed
appropriate for this experiment because only three samples, at most, were available for either VEG or CD,
and here the value of 0 for the difference resulted from at least one sample for both VEG and CD being
below the detection limit.)
However, it is more intuitive to give more focus to the estimate itself, rather than formal significance testing
for these data. The reason for this is that the small sample size of 3 forced the use of the maximum
103

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difference as the upper bound and the minimum difference for the lower bound. These extremes are valid
statistics, but they are inherently very variable. On the other hand, the estimate of the difference is based
on the median, which is more stable. Therefore, the statisticians who performed the HL analysis believed
that the estimate of the difference is a more robust quantity for this data set than the confidence interval.
Note that when the VEG sample size was below 3 (as for VOCs and the particulates and acid gases) a
confidence interval was not even formed. A sample size of 3 for both CD and VEG was required for a 90%
confidence interval, and the fact that only three observations (maximum) were available precluded using a
tighter confidence interval (say 95%).
While these estimates provide some insight in terms of absolute differences between CD and VEG, the
relative difference was also examined. This was done by simply taking the ratio of the median CD value to
the median VEG value. Based on observations of variability between duplicate conditions, the heterogeneity
of the feed materials, and the batch nature of the process, in the opinion of the authors, any difference in
the ratio of median values less than 2 indicates a negligible difference between the two conditions, and only
a marginal difference with ratios of median values up to 4. In addition, below detection limit (BDL) counts
were made for each chemical species for both VEG and CD.
5.8.1	Metals
Of all the metal target analytes, antimony, barium, cadmium, lead, and mercury showed a statistically
significant difference between the two feed types. The analytes with the largest difference between VEG
and CD conditions were mercury (with the ratio of the medians being undefined since no mercury was
detected in the VEG runs), antimony (with the ratio of the medians equal to 19.6), and lead (with the ratio
of the medians equal to 15.3). Table 5.10 lists the results from the HL analysis of the metals emission
factors, with only the analytes with a significant difference between the VEG and CD not being grayed out.
5.8.2	PAHs
All of the PAHs were significantly higher from C&D debris combustion than from vegetative debris
combustion. The ratio of the median values ranged from a high of 41.1 for Dibenzo(a,h)Anthracene to a
low of 4.0 for Naphthalene. Table 5.11 summarizes the results from the HL analysis of the PAH emission
factors. Note that none of the rows are grayed out, indicating that all PAHs were significantly higher for
C&D debris.
5.8.3	Particulate and A cid Gases
It was not possible to determine confidence intervals for the PM and Acid Gas measurements because only
two VEG data points were available. However, based on the ratio of the medians, the PM was not
significantly higher for the CD condition than it was for the VEG condition, except possibly the organic
condensables, with a ratio of medians of only 2.8. The acid gases, other than HCI, which showed a ratio
of medians of 11.7, only showed a marginal difference between the VEG and CD cases. Table 5.12 lists
the results from the HL analysis of the PM and acid gas emission factors, with only the analytes with a
significant difference between the VEG and CD not being grayed out.
104

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Table 5.10. Results from Analysis of Metals Emission Factors.
Name
Difference
Estimate (CD -
VEG)
Med CD/Med
VEG
90% CI
Lower
Bound
90% CI
Upper
Bound
VEG
BDL
CD BDL
Antimony
3130.7
19.55
137.9
6721.4
0
0
Arsenic
639.6
1.55
-2069
22993.7
0
0
Barium
509.6
2.79
410.9
906.5
0
0
Beryllium
-0.1
1.51
-1.3
0.6
0
1
Cadmium
676.7
5.69
523.1
1049.2
0
0
Chromium
125
0.72
-440.6
5709.7
0
0
Cobalt
0
ฆ
-677.8
56.6
2
2
Lead
25313.3
15.26
15315.8
58667.1
0
0
Manganese
1142.3
2.17
-41.1
1915
0
0
Mercury
113.7
ฆ
53.6
174.2
3
0
Nickel
140.6
0.77
-678.4
3826.2
0
0
Selenium
0
ฆ
-22
0
2
3
Silver
9.7
1.02
-4.8
31.8
0
0
* Ratio Undefined Because Median VEG = 0.
Table 5.11. Results from Analysis of PAH Emission Factors.
Name
Difference
Estimate (CD -
VEG)
Med CD /Med
VEG
90% CI
Lower
Bound
90% CI
Upper
Bound
VEG
BDL
CD BDL
Naphthalene
4875.1
4.01
3466.4
5910.7
0
0
2-Methylnaphthalene
1455.9
7.86
561
1926.6
0
0
Acenaphthylene
2587.7
16.84
1669.5
2945.3
0
0
Acenaphthene
252.6
18.62
60.8
303
0
0
Fluorene
925.3
20.15
333.4
998.2
0
0
Phenanthrene
2322.6
8.23
1142.7
2911.1
0
0
Anthracene
567.7
20.71
226.1
777.6
0
0
Fluoranthene
875.8
9.93
517.9
1139.4
0
0
Pyrene
323.8
5.57
202.3
372.9
0
0
Benzo(a)Anthracene
279.2
24.29
134.4
320.5
0
0
Chrysene
304.8
15.17
142.5
357
0
0
Benzo(b)Fluoranthene
280.6
22.65
170.6
328.4
0
0
Benzo(k)Fluoranthene
83.7
21.05
57.5
102
0
0
Benzo(e)Pyrene
142.5
19.29
107.8
198.9
0
0
Benzo(a)Pyrene
93.5
39.08
57.9
161.7
0
0
Perylene
7.4
32.03
6.4
23.3
0
0
lndeno(1,2,3-cd)Pyrene
109.6
19.91
90
127.3
0
0
Dibenzo(a,h)Anthracene
32.7
41.13
12.7
34.6
0
0
Benzo(ghi)Perylene
100.6
18.15
79.3
138.1
0
0
105

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 5.12. Results from Analysis of Particulate and Acid Gas Emission Factors.
Name
Difference
Estimate (CD -
VEG)
Med CD/Med
VEG
90% CI
Lower
Bound
90% CI
Upper
Bound
VEG
BDL
CD BDL
M5 Filterable Particulate
1071.3
1.55
-
-
0t
0
HCI
1539.7
11.67
-
-
0t
0
HF
24.1
3.76
-
-
of
0
HBr
21.5
2.87
-
-
0t
0
CI2
18.8
2.73
-
-
of
0
Br2
2.3
1.30
-
-
of
0
Filterable Particulate PM2_5
554.9
2.17
-
-
of
0
Organic Condensable Particulate
96.4
2.82
-
-
0t
0
Inorganic Condensable Particulate
817.6
1.51
-
-
of
0
Total Particulate 
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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Table 5.13. Results from Analysis of SVOC Emission Factors.
Name
Difference
Estimate (CD -
VEG)
Med CD/Med
VEG
90% CI
Lower
Bound
90% CI
Upper
Bound
VEG
BDL
CD
BDL
Aniline
0
ฆ
0
1267.8
3
2
2-Chlorophenol
3353.7
*
1835.6
3531.2
3
0
1,3-Dichlorobenzene
157.1
ฆ
0
245.2
3
1
1,4-Dichlorobenzene
148.2
ฆ
-37.3
231.5
2
1
Benzyl-Alcohol
1286.9
4.59
-804.2
2091.1
1
1
1,2-Dichlorobenzene
0
ฆ
0
206.6
3
2
2-Methylphenol
3022.6
ฆ
0
3220
3
1
3-and-4-Methylphenol
4451.7
*
881.4
5549.5
3
0
Nitrobenzene
7824.5
*
840
10019.7
3
0
2-Nitrophenol
1599.3
*
584.8
2312.4
2
0
2,4-Dimethylphenol
1321.6
*
265.7
1388.5
3
0
Bis(2-chloroethoxy)methane
0
ฆ
0
967.3
3
2
2,4-Dichlorophenol
1576.2
ฆ
-633.3
2209.5
2
1
1,2,4-Trichlorobenzene
0
ฆ
-6.7
97.3
2
2
Naphthalene
12393.7
17.49
3370.1
14475.2
0
0
4-Chloro-3-methylphenol
0
ฆ
0
1410.6
3
2
2-Methylnaphthalene
1959.5
6.27
839.7
2262.8
0
0
1 -Methylnaphthalene
-76.7
0.00
-101.1
398.8
0
2
2,4,5-T richlorophenol
0
ฆ
-34.8
0
2
3
2-Chloronaphthalene
0
ฆ
-6.7
71.9
2
2
2-Nitroaniline
0
ฆ
-23.1
1241.7
2
2
Dimethylphthalate
0
ฆ
-44.4
99.9
2
2
1,3-Dinitrobezene
1467.4
ฆ
753.8
2019.5
2
0
Acenaphthylene
1793
32.43
936.5
2394.2
0
0
2,6-Dinitrotoluene
0
ฆ
-44.5
0
2
3
Acenaphthene
0
ฆ
-9.1
225.3
2
2
4-Nitrophenol
2737.6
ฆ
0
2750.5
3
1
Dibenzofuran
1244.7
19.21
459.5
1676.8
0
0
2,4-Dinitrotoluene
0
ฆ
0
201
3
2
2,3,4,6-Tetrachlorophenol
0
ฆ
0
433.1
3
2
2,3,5,6-Tetrachlorophenol
0
ฆ
0
333.1
3
2
Diethylphthalate
0
0.00
-61.2
97.5
1
2
Fluorene
525.6
37.49
168.5
777.4
1
0
4-Nitroaniline
0
ฆ
-37.3
0
2
3
4,6-Dinitro-2-methylphenol
0
ฆ
0
203
3
2
Azobenzene
0
ฆ
0
65.3
3
2
Phenanthrene
2835.6
15.47
1218
4702.7
0
0
107

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Name
Difference
Estimate (CD -
VEG)
Med CD/Med
VEG
90% CI
Lower
Bound
90% CI
Upper
Bound
VEG
BDL
CD
BDL
Anthracene
2910.5
13.65
1344.3
4443.7
0
0
Carbazole
26
ฆ
-11.6
101.9
2
1
Di-n-butylphthalate
-79.5
1.79
-562.6
307
0
1
Fluoranthene
773.5
19.24
516.5
1451.4
1
0
Pyrene
670.5
20.81
467.9
1250.1
1
0
Benzylbutylphthalate
0
ฆ
0
94.4
3
2
Benz[a]anthracene
265.4
ฆ
0
373.1
3
1
Chrysene
1284.1
ฆ
0
1389.8
3
1
Bis(2-ethylhexyl)phthalate
1223.6
7.87
305.5
12055.4
0
0
Di-n-octylphthalate
0
ฆ
-625.9
69.4
2
2
Dibenz[a,h]anthracene
0
ฆ
0
29.1
3
2
5.8.5 Dioxins, Furans, and PCBs
The HL analysis of the dioxins, furans, and PCBs showed a statistically significant difference between the
VEG and CD conditions. The ratios of the medians ranged from 40.4 for the PCB TEQ down to 17.7 for
the Total CDD/CDF and the PCDD/PCDF TEQ. The fact that chlorophenols (see the SVOC section) were
significantly higher for the C&D debris than for the vegetative debris is consistent with the observation of
the higher dioxins and furans from the C&D debris, since chlorinated phenols are considered precursors in
the formation process for dioxins and furans (Altarawneh et al., 2009, Briois et al., 2007). Table 5.14 lists
the results from the HL analysis of the dioxin, furan, and PCB emission factors. No rows are grayed out for
these analytes indicating that all analytes showed a statistically significant difference between the test
conditions.
Table 5.14. Results from Analysis of Dioxin, Furan, and PCB Emission Factors.
Name
Difference
Med CD /Med
90% CI
90% CI
VEG
CD BDL

Estimate (CD -
VEG
Lower
Upper
BDL


VEG)

Bound
Bound


Total CDD/CDF
38302.1
17.71
33825.2
98381.1
0
0
PCDD/PCDF TEQ
867.1
17.69
684.9
2388.5
0
0
Total PCBs (Mono-Nona)
67056.6
20.86
28918.2
72137.2
0
0
PCB TEQ
43.9
40.36
28.3
146.4
0
0
PCDD/F TEQ+PCB TEQ
897.4
18.01
727
2534.6
0
0
5.8.6 VOCs
Because there was only 1 VOC run it was not possible to perform the HL analysis of the VOCs.
108

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
5.8.7 Fixed Combustion Gases
Of the combustion gas samples acquired with the CEMs, CO, SO2, and THC showed a statistically
significant increase for the C&D debris over the vegetative debris. NOx did not exhibit a statistically
significant difference. Table 5.15 lists the results from the HL analysis of the fixed combustion gas emission
factors, with only the analytes with a significant difference between the VEG and CD not being grayed out.
Table 5.15. Results from Analysis of Fixed Combustion Gas Emission Factors.
Name
Difference
Med CD/Med
90% CI
90% CI
VEG
CD BDL

Estimate (CD -
VEG
Lower
Upper
BDL


VEG)

Bound
Bound


CO
5756
2.45
2559
8966
0
0
NOx (as NO)
104
1.14
-181
660
0
0
S02
1365
5.47
999
4177
0
0
THC (as propane)
1057
6.50
367
1146
0
0
5.9 Comparison Between ACB Technology and Other Combustion Sources
In an effort to put the emissions of pollutants of interest from ACBs into perspective with other, more familiar
combustion sources, emission factors for CO, total filterable PM, and PCDD/F (in TEQ units) were
compared. Combustion sources that were used in this comparison included coal and wood-fired boilers,
municipal solid waste combustors, and common open burning sources including forest fires, open burning
of land clearing debris and domestic waste, and landfill fires. The summary of these comparisons can be
found in Table 5.16.
Table 5.16. Comparison of Emission Factors of Various Combustion Sources
Source
CO (mg/kg)
Filterable PM
(mg/kg)
PCDD/F (ng
TEQ/kg)
Reference
Bituminous Coal Spreader Stoker
with cyclones
2500
8500
0.3
(U.S. EPA, 1995a, UNEP, 2005)
Wood-Fired Boiler, no controls
3869
2386
0.8
(U.S. EPA, 1995a, UNEP, 2005)
Residential Woodstove
115400
15300
1.5
(U.S. EPA, 1995a, UNEP, 2005)
Municipal Waste Combustor, Well
Controlled
232
31
0.5
(U.S. EPA, 1995a, UNEP, 2005)
Open Burning, Forest Residues
70000
8500
0.5
(U.S. EPA, 1995a, UNEP, 2005)
Forest Fires
114000
16600
5.0
(Lemieux et al., 2004, UNEP,
2005)
Open Burning, Domestic Waste in
Barrels
42000
8000
300
(Lemieux et al., 2004, UNEP,
2005)
Landfill Fires
NA
NA
1000
(UNEP, 2005)
Air Curtain Burner, Vegetative Debris
3429
3852
69

Air Curtain Burner, C&D Debris
9189
7215
1455

NA - no data were available
109

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
A graphical comparison of these sources can be found in Figures 5.6 through 5.8, showing CO, PM, and
PCDD/F, respectively. In the case of CO, emissions from ACBs are not quite as low as very well controlled
combustion units such as the Municipal Waste Combustor, but are significantly lower than the uncontrolled
sources. PM emissions from the ACBs are significantly lower than the uncontrolled combustion sources,
and although they are higher than the well-controlled combustion sources, are on the same order of
magnitude as some conventional stationary sources equipped with low-tech PM controls (e.g., coal-fired
spreader stoker with cyclones). The PCDD/F emission factors show a wide degree of variation, with the
PCDD/F emissions from ACBs burning vegetative debris being significantly higher than the well-controlled
combustion sources, and slightly higher than forest fires. Note that the ACB PCDD/F emission factor
burning vegetative debris resulting from hurricanes is somewhat higher than open burning of conventional
vegetative debris. The vegetative debris used in the VEG runs was recovered from the Hurricane Katrina
response and had sat in brackish water for an unknown period of time priorto being moved to the Old Paris
Road Landfill for these tests. This likely contributed to an increase in chlorine content of the vegetative
debris beyond the level that would have been present in the wood, and it is not necessary to have an
organic source of chlorine in order to form PCDD/F during combustion processes (Preto et al., 2005,
Wikstrom and Marklund, 2001). This increased chlorine level may have contributed to the vegetative
PCDD/F emission factors being higher than forest fires. Other factors could have contributed as well,
included the time-temperature environment that the gases and particles leaving the ACB were subjected to
as it was emitted into the atmosphere. The fact that chlorinated phenols were identified in the emissions
from the vegetative debris combustion supports the hypothesis that the increased chlorine due to sitting in
brackish water may have contributed to an increase in PCDD/F emissions. Chlorinated phenols are not
typical products of incomplete combustion from the combustion of clean woody material (Lemieux et al.,
2004) and have been implicated as precursors in the mechanism of PCDD/F formation in combustion
sources (Altarawneh et al., 2009, Briois et al., 2007). The PCDD/F emission factors from ACBs burning
C&D debris are higher than uncontrolled domestic waste burning, and are on the same order of magnitude
as landfill fires. It is not surprising that C&D debris has higher PCDD/F emissions than vegetative debris,
since the presence of plastics (some of which was likely chlorinated) and household wiring (which frequently
has polyvinyl chloride insulation) were visually observed in the C&D debris stream.
110

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No, EP-C-05-060 • Streams Task Order 12
1000000
100000
10000
O CO CO
c I_ LU
F CD
t	-a
5 --J
m o j-
_ CO
S ฎ CQ
(1)
(/)
0


XI
0
ฃZ
(/)



XI
ฃ=
0
C
n
CO

CO
Q
~5
0
rs
ort
(J
O
(J




<
>
<

Figure 5.6. Comparison of CO Emission Factors Among Several Combustion Sources
100000 -1	1
r 1000
 >
03 > "
O X) O
E E O
U) 0
E w
ro	_(/)
^ >	0
CO o	j-
•43	(0
E (/)	CD
8. ฎ
o I
O o)
< >
ฃ= (/)
CD
0
O
t Q
zs o3
O O
Figure 5.7. Comparison of PM Emission Factors Among Several Combustion Sources
111

-------
(Q
ฃ
s
Ol
00
o
o
3
ฆa
03
tti
o
3
O
-*1
ฆo
o
a
a
ro
m
3
w
w
5'
3
-n
0)
o

3
o
3
ID
0)
CD
<
CD
o
O
3
CT
C
(/)
o"
3
(/)
O
c
o
a>

PCDD/F Emission Factor (ng TEQ/kg)
Bituminous Coal
Spreader Stoker with
ESP
Wood-Fired Boiler, no
controls
Residential Woodstove
Municipal Waste
Combustor, Well
Controlled
Open Burning, Forest
Residues
Forest Fires
Open Burning,
Domestic Waste in
Barrels
Landfill Fires
Air Curtain Burner,
Vegetative Debris
Air Curtain Burner,
C&D Debris
0
2
Ti
-H
*
	(a
ฐ	o'
•	s
CO	M
1	I
I	8!
M	ง
-~H	CD
Q?	2
%	ฉ

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
6. Data Quality Assessment
Measurement Quality Objectives (MQOs) were established in terms of accuracy, precision and
completeness for all critical measurements in the QAPP. These goals are shown in Table 6-1 and are
assessed in the subsections that follow. Additional analyses were performed that were not deemed critical.
The acceptance criteria for those analyses are based on the method acceptance criteria and are also
assessed in this section.
Table 6-1. Measurement Quality Objectives
Measurement
Sampling Method
Sub-Parameter
Analysis Method
Acceptance Criteria
(Bias/Recovery)
Completeness
Moisture
EPA Method 4
Post-test Calibration
Standard meter
comparison
ฑ0.02%ofdrygas
meter pre-run
calibration gamma
100%
Balance check
Gravimetric S-Class
weights
ฑ0.5g
N/A
CO2/O2
EPA Method 3A
Calibration error
Instrumental
Calibration Gases
ฑ2%
90%
Sampling system bias

ฑ5%
Zero & calibration drift

ฑ3%
S02
EPA Method 6C
Calibration error
Instrumental
Calibration Gases
ฑ2%
90%
Sampling system bias

ฑ5%
Zero & calibration drift

ฑ3%
NOx
EPA Method 7E
Calibration error
Instrumental
Calibration Gases
ฑ2%
90%
Sampling system bias

ฑ5%
Zero & calibration drift

ฑ3%
CO
EPA Method 10
Calibration error
Instrumental
Calibration Gases
ฑ2%
90%
Sampling system bias

ฑ5%
Zero & calibration drift

ฑ3%
VOCs
Modified EPA
Method 0040
N/A
EPA Method 0040
N/A
75% (minimum
6 of 8)
Precision criteria
is ฑ 10% using
duplicates
113

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Air Curtain Burner Performance Tests: Source Emissions Measurement Results
DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
Measurement
Sampling Method
Sub-Parameter
Analysis Method
Acceptance Criteria
(Bias/Recovery)
Completeness
Acid Gases
EPA Method 26A
Post-test meter
calibration check
Standard Meter
Comparison
ฑ 0.5g of
pre-calibration
75% (minimum
6 of 8)
Precision criteria
is ฑ 10% using
duplicates
Total/Condensable
Particulate
EPA Method 5/202
Post-test meter
calibration check
Standard Meter
Comparison
ฑ 0.5g of
pre-calibration
67% (minimum
4 of 6)
Metals
EPA Method 29
Laboratory QC Samples
EPA Method 29
ฑ 25%
67% (minimum
4 of 6)
Asbestos
Modification of EPA
Method 5
Using polycarbonate filter
or distilled water for
sample collection -
determination made in
field based on PCM
analyses
Post-test meter
calibration check
Standard Meter
Comparison
ฑ 0.5g of
pre-calibration
100%
ACB Bed
Temperature (Direct)
N/A
Calibration error
K-type thermocouple
ฑ3ฐF
100%
ACB Bed
Temperature
(Remote)
N/A
Manufacturer's internal
calibration check
Infrared pyrometer
ฑ 10% of temperature
range
100%
6.1 CEMs
All MQOs were met for Chand CO2 (100% complete). For the remaining measurements, MQOs were met
with the following exceptions:
•	CO: MQO was ฑ2 percent for both bias and drift, a value which was slightly exceeded on 50 percent of
the bias checks ranging from 2.3 to 3.3 percent. The 90 percent completeness goal was not met.
•	SO2: MQO was ฑ5 percent bias/ฑ3 percent drift which was exceeded once on a pre-test bias check at
-6.3 percent and once on a drift check at 3.1 percent. The 90 percent completeness goal was met.
•	THC: There were no criteria in the QAPP for this measurement. Method states ฑ3 percent for both bias
and drift. Two post-test bias checks and drift values exceeded MQO criteria ranging from 6.6 to 7.6
percent.
•	NOx: MQO for NOx was 2 percent for both bias and drift. This bias MQO was slightly exceeded in 4 out
of 6 pre-test calibration checks ranging from 2.7 to 4.1 percent. Drift MQOs were also exceeded 4 out
of 6 times ranging from 2.2 to 4.0 percent. The 90 percent completeness goal was not met.
Overall, due to the huge transient fluctuations in the measurements with respect to time, these minor issues
of not meeting MQOs for every instrument on every test will not adversely impact the data. This is true
particularly since all MQOs for O2 and CO2 were met, so the dilution corrections will not introduce errors.
114

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DRAFT Revision 5 • February 2010 • Contract No. EP-C-05-060 • Streams Task Order 72
6.2	VOCs/TO-15
Research Triangle Park Laboratories, Inc. performed SUMMAฎ canister analysis. Samples were analyzed
for 60 VOCs by EPA Method TO-15/GC/MS (U.S. EPA, 1999). In addition, a library search was performed
for unknown VOCs using EPA/National Institute of Standards and Technology's 129,000 compound mass
spectral database for TICs. Nine samples were submitted which included one field blank. The only
compounds identified in the blank were:
•	Methylene chloride	7.3 ppbv
•	Acetone	6.6 ppbv
These compounds are common VOC contaminants. Any concentrations reported in the samples less than
10X the concentration reported in the blank are flagged as non-detects. Accuracy is assessed using
recovery of internal and surrogate standards. All recoveries met method criteria. Precision is assessed by
performing duplicate injections. Relative percent differences between duplicate injections met laboratory
acceptance criteria. No other QC problems were noted by the laboratory. These analyses were 100 percent
complete.
6.3	Acid Gases (HCI, HF, HBr, CI2 and Br2) by EPA Method 26/26A
Samples were analyzed by Resolution Analytics, Inc., in Sanford, North Carolina, on July 28, 2008, several
days beyond the recommended 4-week hold time for the method. This exceedance is not expected to affect
the analytical results.
The field blank had a CI2 result of 0.217 mg compared to the following sample results:
I-ACB-M5/26A-01 0.570 mg
I-ACB-M5/26A-02	0.529 mg
II-ACB-M5/26A-01	0.958 mg
II-ACB-M5/26A-02 1.33 mg
II-ACB-M5/26A-03 1.65 mg
No analytical or data quality issues were noted by the laboratory. All calibration curves and internal audit
QC results were within the laboratory control limits, as were the percent differences between the duplicate
injections. Therefore, accuracy and precision goals were met. The matrix spike recoveries were also within
laboratory acceptance criteria. One sample was lost priorto analysis (I-ACB-M5/M26A-03), a completeness
that represents 83 percent, which meets the 75 percent goal.
6.4	Filterable and Condensable Particulate by EPA Method 5/201 A/202 and
Particle Sizing
Filterable particulate was determined by EPA Method 5. All weights recorded include filterable particulate
catch only. The total catch reported for each run was a sum of the filter and rinse catches. The laboratory
subtracted the acetone blank catch (0.2 mg) from the sample rinse catches in proportion to their respective
volumes.
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The Field Blank has a filterable particulate (EPA Method 5) of 5.1 mg, and the acetone blank had 0.2 mg
(100 mL).
I-ACB-M5/25A-FB	5.1 mg
I-ACB-M5/26A-01	138.0 mg
I-ACB-M5/26A-02	87.4 mg
II-ACB-M5/26A-01	115.1 mg
II-ACB-M5/26A-02	125.2 mg
II-ACB-M5/26A-03	101.1 mg
Filterable particulate/particle sizing was determined by EPA Method 5, and no modifications were made to
the method. All weights recorded include filterable particulate catch only. The total catch reported for each
run was a sum of the filter catches. Acetone rinses were not sent with the dry filters and the reagent blanks
from another project were used. The Field Blank had measurable results at all stages. These results are
summarized in Table 6-2.
Table 6-2. Field Blank and Filterable Particulate Results
Stage ID
ACB-PM-10-
FB
(mg)
R1-ACB-PM-10-
1
(mg)
R1-ACB-PM-10-
2
(mg)
R2-ACB-PM-10-
1
(mg)
R2-ACB-PM-10-
2
(mg)
R2-ACB-PM-10-3
(mg)
Stage 0
0.2
3.5
0.9
1.2
2.0
17.8
Stage 1
0.1
0.8
0.1
1.0
3.2
2.8
Stage 2
0.6
1.3
2.8
3.3
5.3
3.7
Stage 3
1.4
3.6
1.2
3.1
2.0
1.9
Stage 4
1.1
3.5
3.3
4.4
1.4
1.4
Stage 5
1.1
6.4
4.7
1.2
4.8
3.1
Stage 6
1.6
9.5
7.3
9.3
3.7
10
Stage 7
0.7
20
8.5
13
3.1
21
Solid Filter
Precutter Rinse
2.5
142
87
86
39
84
EPA Method 201A was used to determine PM10. All weights recorded include filterable particulate catch
only. The total catch reported for each run was a sum of the filter and rinse catches. The laboratory
subtracted the acetone blank catch (0.2 mg/100 mL) from the sample rinse catches in proportion to their
respective volumes. The methylene chloride blank for the organic particulate was 0.3 mg/90 mL and the
water blank for the inorganic particulate was 0.5 mg/100 mL.
EPA Method 202 was used to determine condensable particulate. The total catch reported for each run
was a sum of the condensable (organic and inorganic) catches. The H2O impinger samples had a pH <4.5
and were therefore adjusted for NH4CI and (NH4)2SC>4 reaction products per EPA Method 5F (ion
Chromatography). The solvent catch weights were subtracted from sample catches in proportion to their
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respective solvent volumes. Note that the hard copy report had incorrectly calculated the Total Particulate
for samples Field Blank, R2-ACB-PM-2.5-2 and R2-ACB-PM-2.5-3. These results are summarized in Table
6-3.
Table 6-3. Field Blank and Particulate Data Summary
Sample ID
Filterable
Particulate
(mg)
Organic
Particulate
(mg)
Inorganic
Particulate
(mg)
Total
Particulate
(mg)
Field Blank
1.9
0.9
0.8
1.6
R1-ACB-PM-2.5-1
78
2.4
84
87
R1-ACB-PM-2.5-2
55
1.0
20
21
R2-ACB-PM-2.5-1
35
1.3
20
21
R2-ACB-PM-2.5-2
47
3.8
22
26
R2-ACB-PM-2.5-3
17
0.6
30
30
Sample ID
< 10|jM
Particulate
(mg)
> 10|jM
Particulate
(mg)
Filterable
Particulate
(mg)

Field Blank
1.9
0.0
1.9

R1-ACB-PM-2.5-1
56
22
78

R1-ACB-PM-2.5-2
46
8.6
55

R2-ACB-PM-2.5-1
26
9.2
35

R2-ACB-PM-2.5-2
31
16
47

R2-ACB-PM-2.5-3
16
1.7
17

Sulfate was determined by EPA Method 202/5F. The calibration curve and internal audit QC result were
within the laboratory control limits, as were the percent differences between the duplicate injections. The
Field Blank had a reported sulfate catch of 0.101 mg, well below the next lowest reported result of 8.89 mg
in R2-03.
6.5 Multi-Metals by EPA Method 29
All Multi-Metals by EPA Method 29 were analyzed by First Analytical Laboratories in Chapel Hill, North
Carolina. No container 4 was provided for Run I-ACB-M29-01. All samples were received in good condition,
with no apparent leakage or damage. Antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead,
manganese, nickel, selenium, and silver were determined by Graphite Furnace Atomic Absorption
Spectrophotometry. Mercury was determined by Cold Vapor Atomic Absorption Spectrophotometry. Their
Inductively Coupled Plasma system was not operational at the time, and the barium analysis was performed
by the certified laboratory Microbac Laboratories, Inc., in Wilson, North Carolina.
All of the spike recoveries were within the acceptable range of 75 to 125 percent and all samples were
analyzed in duplicate. Traces of cadmium, chromium, manganese and nickel were found in the blanks,
which is normal. The laboratory stated in their narrative that the results should be blank-corrected by the
user, since in some cases the sample levels are so low that the blank levels are significant. However, in all
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cases, the levels found in sample Field Blank were higher than those detected in any of the associated
blanks for these metals. These results are shown in Table 6-4.
Table 6-4. Metals Field Blank and Sample Results Summary
Sample
Cd
(H9)
Cr
(H9)
Mn
(H9)
Ni
(H9)
ACB-M29-FB Front
2.5
0.8
2.4
<1.0
I-ACB-M29-01 Front
7.1
45
43
47
I-ACB-M29-02 Front
6.2
37
43
51
I-ACB-M29-03 Front
12
21
108
23
II-ACB-M29-01 Front
23
13
81
16
II-ACB-M29-02 Front
57
23
60
18
II-ACB-M29-03 Front
27
199
81
135

ACB-M29-FB Back
1.9
1.6
11
2.0
I-ACB-M29-01 Back*




I-ACB-M29-02 Back
1.5
1.1
12
1.5
I-ACB-M29-03 Back
0.35
1.2
14
2.9
II-ACB-M29-01 Back
2.2
1.3
11
3.6
II-ACB-M29-02 Back
0.52
1.4
8.4
3.9
II-ACB-M29-03 Back
0.57
1.4
4.9
3.5
*Front and back half samples were combined by mistake prior to submittal to lab
6.6	SVOCs-EPA Method 0010/Method 8270
Seven sets (including one Field Blank) of EPA Method 0010 sample fractions (XAD-2 cartridges, filter,
impinger contents) were analyzed by Research Triangle Park Laboratories, Inc. Sample fractions were
combined, extracted and analyzed by EPA Method 8270 (U.S. EPA, 1998). The following compounds and
concentrations were identified in the field blank:
•	N-nitro-di-n-propylamine	1.1 jjg
•	Di-n-butyl phthalate	4.9 jjg
•	Bis(2-ethylhexyl) phthalate	2.8 jjg
Any samples with reported concentrations of these compounds less than 5X the concentrations reported in
the blank are flagged as non-detects.
6.7	PCDD/PCDF (Method 23)
Samples were submitted to Analytical Perspectives for the determination of polychlorinated dibenzo-p-
dioxins and dibenzofurans (PCDD/PCDF). Seven samples (including a field blank) were submitted,
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extracted and analyzed within method hold time criteria. No PCDD/PCDF concentrations were reported in
the method blanks. The Field Blank had estimated concentrations (J flagged) for the following compounds:
•	OCDD	46.1J
•	2378 TCDD	7.35J
•	23478 PeCDD	14J
•	234678 HxCDD	6.53J
•	1234678 HpCDD	6.1J
Concentrations reported in the samples were orders of magnitude above the Field Blank so no qualification
due to blanks was required. Accuracy is assessed by recovery of standards described in the method.
Recoveries of extraction, surrogate and analysis standards were all excellent ranging from 84-106 percent.
Precision is assessed by reviewing relative percent differences between initial calibration and continuing
calibration standards and the analysis of laboratory control samples. All relative percent differences (RPDs)
were within laboratory control limits. These analyses were 100 percent complete.
Concentrations for a number of congeners in the C&D debris runs exceeded the instrument calibration
range. These values are flagged (*) in the reported data.
6.8 PCBs and PAHs
Samples were submitted to Analytical Perspectives for the determination of PCBs and PAHs. Seven
samples (including a Field Blank) were submitted, extracted and analyzed within method hold time criteria.
The following PCB was reported in the method blank:
•	PCB-118	10.9J pg
The following PCBs were reported in the Field Blank:
•	PCB-77	21.1 pg
•	PCB-105	33 pg
•	PCB-118	96.7 pg
•	PCB 156/157 11.7J pg
All sample concentrations were orders of magnitude higher than concentrations reported in the blanks, so
no further qualification due to blank contamination was required. An "RJ-D10" flag was appended to several
of the Sample IDs indicating results reported from a second analysis/re-injection of the sample extract with
a 10-fold dilution.
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There were some issues noted in the case narrative for PAH analysis due to severe saturation of the
detector by several analytes. Analysis was repeated for these samples using split injection equivalent to
dilutions ranging from 300-500 times. These samples were flagged "SP300", "SP400" or "SP500"
depending upon the dilution factor. In addition, extraction standards for naphthalene and pyrene forsamples
requiring the highest dilutions had elevated recoveries. The measured recoveries for these standards are
considered unreliable resulting in an underestimation of the corresponding analyte concentrations by a
factor of two to three. The elevated recoveries are most probably the result of carryover from the detector
and/or contributions due to the extremely high levels of the target analyte. Also, any analytes flagged "PR"
were poorly resolved and any flagged "H" had alternate standard recoveries < 40 percent.
Table 6-5 represents concentrations of compounds found in the method blank and the Field Blank.
Concentrations reported in samples were orders of magnitude higher than concentrations in the blanks.
Therefore, no qualification of samples due to blank contamination was required.
Table 6-5. PAH Method and Field Blank Concentrations
Analyte
Method Blank (ng/Train)
Field Blank (ng/Train)
Naphthalene
814
1460
2-Methylnaphthalene
44
111
Acenaphthylene
0.82
493
Acenaphthene
4.6
15
Fluorene
48
100
Phenanthrene
29
147
Anthracene
1.4
<0.91
Fluoranthene
9.8
38
Pyrene
4.2
18
Benzo(a)Anthracene
1.2
2.9
Chrysene
<0.91
5
Benzo(b)Fluoranthene
1.7
5.7
Benzo(k)Fluoranthene
<0.30
1.7
Benzo(e)Pyrene
0.56
2.5
Benzo(a)Pyrene
1.0
2.1
Perylene
<0.49
0.73
lndeno(1,2,3-cd)Pyrene
<0.73
3.1
Dibenzo(a,h)Anthracene
<0.77
<4
Benzo(g,h,i)Perylene
1.2
2.3
TOTAL PAH
963
2410
6.9 Ash TCLP Analysis
All TCLP analyses were performed by Test America in Savannah, Georgia. Three solid samples collected
on 06/25/08 (Wood Ash), 06/26/08 (C/D Ash) and 06/27/08 (C/D Ash) were submitted and received by the
laboratory on 07/07/2008. Samples were received in good condition and were all within temperature
requirements. For GC/MS volatiles, one sample was prepared outside of the preparation holding time
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(Wood Ash 6/25). No other analytical or quality issues were noted for TCLP (Method 1311) results. All
TCLP results were less than the laboratory reporting limits with the following exceptions:
•	Arsenic 0.22 mg/L Wood Ash 6/25
•	Arsenic 0.3 mg/L C/D Ash 6/27
Surrogate recoveries were all within the laboratory acceptance criteria. Results of method blanks and
leachate blanks were all below detection limits. Results from all laboratory control spikes and laboratory
control spike duplicates (LCS/LCSD) fell within laboratory acceptance criteria of 75 to 125 percent.
6.10 Asbestos Analysis
Samples collected for asbestos analysis during the incinerator study were analyzed by Bureau Veritas (BV)
of Kennesaw, Georgia. The samples collected were analyzed for the presence of asbestos fibers and
forsterite fibers. Those samples included three samples representing airborne particles, two personnel air
samples, and two bulk samples of ash. The air samples were analyzed by TEM utilizing ISO 10312
(International Organization for Standardization). The personnel samples were analyzed with PCM utilizing
NIOSH Method 7400 and the bulk samples were analyzed using the EPA 600 PLM method and by drop
mount TEM qualitative verification.
RTI International re-analyzed the three airborne samples and the two bulk samples, and also performed
verified analysis on the air sample grids.
6.10.1 Airborne Asbestos QA Samples
BV found no chrysotile asbestos or forsterite fibers on any of the three samples. At least three tremolite
fibers were found on each of the samples. RTI performed verified analysis on the two grid openings where
those fibers were located. The fibers were readily relocated by RTI, and qualitatively and quantitatively
verified. Based on those two grid openings, BV has a 100 percent true positive, 0 percent false positive,
and 0 percent false negative verified count rating.
RTI re-prepared all three samples for TEM analysis. Using BV's count sheet format and performing analysis
utilizing ISO 10312, RTI counted a sample area representing approximately 20% of the area analyzed by
BV. In their analysis, RTI found four tremolite fibers (see Table 6-6).
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Table 6-6. Comparison of BV and RTI TEM Fiber Counts
Sample
BV fibers/mm2
found
RTI fibers/mm2
found
Acceptable variance?
1
6.4
3.6
yes
2
2.4
7.2
yes
3
3.2
3.6
yes
Source emission samples analyzed by TEM using ISO 10312 used an analytical sensitivity of 0.00039 to
0.00080 structures per cubic centimeter (s/cc). Structures were counted according to the protocol in ISO
10312, AnnexC, "Structure counting criteria."
The personnel samples analyzed by PCM by BV were not reanalyzed by RTI.
6.10.2 Ash QA Samples
Two ash samples were analyzed by PLM using EPA/600/R-93/116 with visual estimation technique and
identification by refractive index measurement. No asbestos or forsterite was found by BV. RTI analyzed
both samples using the same technique and found the same result (see Table 6-7). The ash samples were
also analyzed by both laboratories by preparing a drop mount on a carbon-coated grid to verify at high
magnification the presence or absence of asbestos or forsterite fibers in the bulk sample. Neither laboratory
found any such fibers by TEM analysis.
Table 6-7. Comparison of BV and RTI Bulk Sample Analysis
Sample
BV Result PLM
RTI Result PLM
BV Result TEM
RTI Result TEM
1
none detected
none detected
none detected
none detected
2
none detected
none detected
none detected
none detected
6.11 Audits
A technical systems audit was performed for this project by the EPA QA Manager, Paul Groff, who was
present on June 26, 2008, and Kenneth Cowen of Battelle, under subcontract to Neptune, a contractor to
EPA. Dr. Cowen was present June 25 and 26, 2008. Project personnel present for the audit were Mr. Paul
Lemieux of EPA, Mr. Gene Stephenson, Mr. Michal Derlicki, Mr. Charly King, Mr. Russell Logan, Mr.
Richard Snow, Mr. John Foley, and Mr. Ed Brown, all from ARCADIS. This audit addressed measurement
of key target analytes from the source and included the real-time measurement of CO2, CO, SO2 and NOx,
as well as the collection of integrated samples for particulate matter (PM2 5, filterable/condensable PM, and
particle size distribution) (Method 201 A, Method 5/202, and CARB Method 501, respectively), asbestos,
acid gases (Method 26), metals (Method 29), VOCs (Method 40), SVOCs (Method 0010), and PCBs and
PCDDs/PCDFs (Method 23). Additionally, the audit included visible emissions monitoring according to
Method 9. All measurements included in this audit were performed by ARCADIS and were performed
according to the QAPP entitled "Air Curtain Destructor Performance Test" dated May 8, 2008, with an
Addendum to the QAPP dated June 20, 2008.
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The full audit report and audit checklist can be found in Appendix D, Supporting Documents, but findings
and observations are summarized as follows:
•	Observation: No documentation was available in the field to demonstrate that the source sampling
personnel had read the signed QAPP. However, copies of the QAPP and associated methods were
available at the sampling locations and it was clear that the field personnel were utilizing them.
•	Finding: A velocity profile of the ACD was not performed. Near isokinetic conditions were not
maintained in the sampling duct. To avoid condensation in the sampling duct, the blower was operated
at maximum capacity for all test runs, resulting in temperatures from 200 to 400 ฐF.
•	Observation: The sampling scoop was located on the end of the ACD rather than in the center. The
center was chosen as most representative, but that position was prone to breaking the scoop and
associated equipment so the scoop was moved to the end.
•	Observation: The sampling ports were located 3-10 duct diameters from each other. A large number
of ports were required for all necessary sampling. Minimum interferences were expected from spacing
of sampling probes, and the interferences due to spacing of sampling probes is expected to be small
compared to other uncertainties in the sampling.
•	Observation: No documentation was available in the field to demonstrate that the source sampling
personnel had read the methods. Observation of the field personnel indicated that they were familiar
with the methods and were following the necessary protocols.
•	Observation: Sample collection forms and other documentation were legible and written in indelible
ink. However,, corrections to entries were occasionally partially obliterated and frequently not initialed
and dated. Additionally, some data form spaces were not filled in. For example, several sample
collection data sheets did not identify the operator of the sample collection train, Also, although several
pre- and post-test leak checks were observed, these leak checks were not promptly documented on
the sample collection data sheets. Although perfect laboratory notebook practice was not observed, the
laboratory notebook practices do not appear to obscure what was performed in the field.
•	Observation: Calibration checks of the balance used for gravimetric measurements were not
performed. Although the balance was calibrated, routine calibration checks should be performed to
document balance performance during the use of the instrument
•	Observation: The post-test bias cheeks forthe SO2 CEM fortests on June 25 were out of specification.
This problem was corrected on 6-26-08 through adjustment of an interference compensator. The SO2
values for this day should be checked for consistency with the other runs and noted in the final report.
•	Observation: Sufficiently high quality reagents were used for samples. However, some reagents were
transferred from their original containers without documentation. Transferring reagents should be
avoided when possible to prevent potential contamination and transfer of reagents should be thoroughly
documented when performed to maintain traceability.
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•	Observation: The EPA auditor witnessed a Method 26 train being collected from the impinger train in
which the last impinger was empty except for some condensed water and was lighter than the initial
weight (tare weight) recorded which apparently had silica gel as per the method. There was no
explanation for the discrepancy.
•	Observation: The traverse of the stack conducted as part of Method 2C included points inside the
minimum distance from the stack wall. Eight points were included in the traverse, and four of these
points were 0.1 inches inside the 0.5 inch minimum distance from the stack wall specified in Method
2A. This deviation did not appear to adversely impact data quality.
•	Observation: Several boxes of glass nozzles were used for the various sampling trains. The following
boxes were checked and of the four boxes that were checked, two of the boxes were out of calibration;
Box A 2/1/2007; Box B 2/1/2007; Box C 5/1/2008; Box D 5/1/2008. Although two of the nozzles were
out of calibration, the nozzles were made of glass and are not likely to have changed in diameter. There
was no apparent damage to the nozzles, so their performance should not be adversely affected.
•	Observation: Two meter boxes and two vacuum gauges failed during a heavy rain event on June 26.
These meter box failures resulted in the need to estimate various temperatures measured during
sample collection. Estimates of these temperatures may introduce a small error into the calculation of
the sample volume and should be noted in the final report. Also, the failure of the vacuum gauges
resulted in the need to collect grab samples for VOC analysis rather than integrated samples over one
hour.
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7. Summary
In an effort to expand available options to better manage natural disaster debris in the future, EPA evaluated
the combustion of both vegetative debris and C&D debris in an air curtain burner (ACB). ACBs can be
mobilized to where they are needed as a potential means of reducing waste volume while minimizing
potentially harmful environmental impacts. These tests were conducted in June 2008 by EPA/ORD at the
Old Paris Road Landfill in St. Bernard Parish, Louisiana.
Testing was comprised of triplicate tests for each of two main test conditions:
1.	Evaluation of emissions while burning vegetative debris; and
2.	Evaluation of emissions from burning a mixture of construction and demolition (C&D) debris which did
not contain asbestos in sufficient quantities to be categorized as Regulated Asbestos Containing
Materials (RACM) and vegetative debris (used as supplemental fuel to maintain operating
temperatures).
The analytes measured in these tests included:
•	Asbestos;
•	Fine PM (less than or equal to 2.5 jjm);
•	Acid gases (HF, HCI, HBr, Cl2, Br2);
•	Toxic metals (Antimony (Sb), Arsenic (As), Barium (Ba), Beryllium (Be), Cadmium (Cd), Chromium (Cr),
Cobalt (Co), Lead (Pb), Manganese (Mn), Mercury (Hg), Nickel (Ni), Selenium (Se), Silver (Ag));
•	Polychlorinated dibenzo-p-dioxins and furans (PCDDs/PCDFs);
•	Co-planar polychlorinated biphenyls (PCBs);
•	Polycyclic aromatic hydrocarbons (PAHs);
•	Semivolatile organic compounds (SVOCs);
•	Volatile organic compounds (VOCs); and
•	Visible emissions (opacity).
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These data are intended to be used in a risk assessment to support decision-making activities regarding
disaster debris management. Later efforts will relate these results, where possible, to the operational
parameters used in the field in execution of the daily burn cycle. Additionally, these data may be used to
develop operational guidelines for operators and technical guidelines for local, state, and regional managers
in using this technology.
The data suggest that for some of the pollutants (e.g., PM, NOx), there is not a statistically significant
difference between ACB operation on vegetative debris or on C&D debris. Other pollutants (e.g., CO, SO2,
HCI) were somewhat higher from combustion of C&D debris than from combustion of vegetative debris.
Some pollutants (e.g., dioxins and furans), were significantly higher from burning C&D debris than from
burning vegetative debris.
It must also be noted that the emission factors for vegetative debris reported in this study more accurately
reflect emission factors for vegetative debris recovered from hurricane response operations rather than
from clean vegetative debris that had not sat in brackish water, exposed to sediment and other sources of
contaminants for an extended period of time prior to combustion.
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8. References
Air Burners LLC, (1998-2007). Operating Manual, S-300 Series, Equipped with Kubota V3300-TE Diesel
Engine, Self Contained Refractory Walled Air Curtain Burner. Palm City, Florida
http://www.airburners.com/.
Air Burners LLC, "S-327 Refractory Walled Air Curtain Burner" httpJ/www.airburners.com/ab-s327.htm,
October 23.
Altarawneh, M., B. Dlugogorski, E. Kennedy and J. Mackie, (2009). Mechanisms for formation,
chlorination, dechlorination and destruction of polychlorinated dibenzo-p-dioxins and
dibenzofurans (PCDD/Fs). Progress in Energy and Combustion Science. 35: 245-274.
Briois, C., S. Ryan, D. Tabor, A. Touati and B. Gullett, (2007). Formation of Polychlorinated Dibenzo-p-
dioxins and Dibenzofurans from a Mixture of Chlorophenols over Fly Ash: Influence of Water
Vapor. Environmental Science and Technology. 41: 850-856.
CARB, (1990). California Air Resources Board, CARB Method 501, Determination of Size Distribution of
Particulate Matter from Stationary Sources, Amended: September 12, 1990.
http://www.arb.ca.aov/testmeth/vo 11 /Meth 501 .pdf.
Gullett, B. and A. Touati, (2003). PCDD/F emissions from forest fire simulations. Atmospheric
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