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Dioxin / Furans

Stakeholders Minutes - January 11, 2000
Workgroup Teleconference Minutes

Workgroup Leaders:
Sandro Leonardelli, EC
Anita Wong, EC
Nan Gowda, EPA

Facilitator:
John Menkedick, Battelle

Introduction

The objectives for the day were to discuss the dioxin workgroup’s involvement in the BNS Incineration Workshop, continue application of the decision tree process to the remaining targeted sectors, identify reduction projects for each priority sector, and discuss the status of outstanding action items. It was announced that the Canadian/EC co-chair position would still be a joint effort from Sandro Leonardelli and Anita Wong from Environment Canada.

Materials distributed to workgroup members prior to the teleconference included: updated U.S. Sector Information, minutes from the November and December teleconferences, materials on open barrel burning (press releases, the Environmental Science and Technology article presenting 1997 data from EPA, and an abstract on more recent EPA research presented at the 1999 Dioxin Conference, provided by Dwain Winters (EPA)), and an EPA research paper on dioxin/furan releases from PCP-treated poles.

General Workgroup Progress and Action Item Updates

To start out the meeting, the general status of work group progress was reviewed:

The group is still in the process of discussing available sector information and using the decision tree to prioritize sectors
Residential wood combustion (RWC) and open burning have been designated as high priority at this time
Medical Waste Incinerators (MWI) still have issues that need to be resolved (e.g., waste separation, fly ash disposal) before a priority designation can be given to this sector
Municipal Waste Combustors (MWC) also have unresolved information needs (e.g., more specific information related to size category, clarification of Canadian significance, and more information on alternative/non-incineration waste disposal technologies)
The group has discussed the possibility of forming specific subgroups for high-priority sectors after going through all sources

Next, updates were given on some of the action items:

MWC emissions data by size category (and regulatory category) were in the process of being prepared. Dwain Winters (EPA) reported the EPA’s Office of Air and Radiation staff were currently writing up the details on the various compliance requirements, etc. for the different size categories of MWC.
Dale Phenecie (CGLI) reported that his efforts to gather information on waste management in hospitals was in progress, and that he had made a contact that was a hospital waste specialist.
EC reported that information gathering on medical waste management in Ontario was in progress

Coordination with B(a)P Work Group on Woodstoves

Since the last teleconference, Anita Wong spoke with the co-chairs of the B(a)P workgroup regarding their current and planned activities related to residential woodstoves. Anita provided an update on the B(a)P workgroup’s activities.

In Canada:

Woodstoves are a high priority sector in Canada and previous/ongoing activities include workshops, educational campaigns, and a pilot changeout program in eastern Ontario in early 1999

Currently, Canada has a stack test program underway, which includes testing for particulate matter (PM) and dioxins/furans. The study will compare emissions from conventional and new certified wood stoves; in addition, it is hoped that the results of the study will help to determine if there is a correlation between particulate matter and dioxins/furans in wood stoves. Testing is taking place in January and February, with results expected sometime in March or April.

Sandro noted that the EPA approved stove technology has been shown to reduce particulate matter emissions by up to 90%; therefore, determining the relationship between PM and dioxins is important (e.g., dioxin reductions could be inferred)

A question was asked regarding the auxiliary parameters being tested: the complete suite includes PM, volatile organics (VOCs), dioxins/furans, hexachlorobenzene (HCB), polycyclic aromatic hydrocarbons (PAHs), CO, and NOx

A question was asked regarding the type of fuel that was being used in the stoves: Two types of wood (maple and spruce, i.e., representative of the largest % of wood burned in Canada) were being used. Prior to combustion, the wood was tested for total Cl-content. Workgroup member suggested that moisture content of the wood would also be a useful parameter to measure for, and that testing the woodstove burning of non-conventional wastes that might be of significance regionally (e.g., garbage, pallets) would also be of interest.

It was asked if the U.S. was conducting similar studies. Dwain Winters (EPA) volunteered to check on what EPA is doing related to assessing residential wood combustion (RWC) / woodstove dioxin emissions and the correlation between particulate matter and dioxin.

In the U.S.:

A woodstove changeover pilot program is scheduled for the1st week in February for Traverse City, MI, and later in Green Bay, WI. The goals of these pilot projects will be to gauge the regional response and potential impacts of a woodstove changeover.

Although the workgroup has a high interest in residential wood combustion and woodstove reductions, after discussing the current activities, the workgroup decided that at the present time (i.e., pilot project stage) there was relatively little opportunity for the dioxin workgroup to coordinate with the B(a)P workgroup. Sandro Leonardelli suggested that after the results of these studies and projects are available, the workgroup may be better able to reassess potential coordination activities and appropriate reductions actions related to woodstoves. The workgroup agreed to revisit the woodstove issue in May.

Next, discussion turned to an update on the planning of the upcoming BNS Incineration Workshop.

BNS Incineration Workshop Update

Workgroup members who had been participating in the preliminary planning meetings, lead by Rita Cestaric (EPA), reviewed some of the ideas discussed for the workshop (Rita was scheduled to join the teleconference shortly to elaborate):

there was talk at the planning meetings of having one-half day each on conventional and non incineration/ alternative waste disposal technologies
discussion at the planning meetings indicated that a primary goal of the workshop would be to determine whether incineration is a viable technology

Discussion followed, with topics including:

what the primary focus of the workshop should be (i.e., some workgroup members thought that the major thrust should be evaluating alternatives to incineration, some thought that evaluation of incineration options was appropriate)
the need to assess incineration as a baseline (i.e., what is the current state of the art regarding incineration, and what will be the effect of the MACT standards relative to alternatives?)
the sufficiency of previous extensive MACT assessments for understanding incineration
the ability of incineration to reach virtual elimination goals
questions concerning emissions from MWI alternative such as autoclaving and microwaving

Finally, it was noted by Sandro Leonardelli and Anita Wong that even when phasing in new technologies, incinerators will not be immediately shut down. In addition, most incinerators are aware of the VE goals often have problems meeting standards. Therefore, this workshop could explore and assess alternative technologies, necessary to start phasing in alternatives, as well as provide a forum for updating operators on the current technologies to help them meet interim targets.

Dan Hopkins (EPA) emphasized that, except for the decision to dedicate a portion of the workshop to implementing a life cycle management tool to evaluate various waste handling processes (i.e., incinerator non-incinerator), the workshop agenda has not been finalized. Anyone interested in participating in workshop should email Rita Cestaric at cestaric.rita@epa.gov

Rita was not yet present, the workgroup moved on to other discussions.

Open Burning Research

Dwain Winters (EPA) clarified that the February ES&T article that was distributed to the workgroup was actually the same data as was in the 1997 EPA report on open barrel burning. The abstract from the Dioxin Conference that was distributed represented a follow-up study that was subsequently conducted EPA. The full article on the follow-up study is now under review by Chemosphere, and will be available once accepted. In the interim, Dwain included a summary of the conclusions with the abstract workgroup information. Dwain will distribute the full Chemosphere article to the workgroup when it is published.

Rita Cestaric joined the call, and discussion turned back to the Incineration Workshop.

Incineration Workshop Incineration Workshop (continued)

Rita summarized the workshop planning status:

municipal waste management districts, environmental groups, and industry groups have been participating
the workshop focus will be on solid municipal waste management, and will look at emissions as well as alternative technologies
the workshop will be held in conjunction with Integration Group meeting in May
they are not ready to determine the content of the Agenda

Questions directed to Rita included:

whether the focus should be more on alternatives to incineration
how the focus on incinerators and municipal solid waste was decided
if it was possible to include all alternatives without being so polarized.
how the workshop would support multiple workgroups (mercury, HCB, B(a)P, and dioxin)

It was clarified that the appropriate process for providing input to the incineration workshop agenda was through participation in the planning committee meetings. Individuals interested in direct input should contact Rita directly.

It was also noted that some issues raised via planning for the Incineration Workshop, but not addressed by that workshop, may be specifically relevant to the dioxin workgroup. These issues will be brought to the dioxin workgroup by dioxin workgroup members participating in the incineration workshop planning.

Sector Specific Analysis: Using the Decision Tree Process

Discussion then turned back to the decision tree process and prioritization of sectors for action.

Cement Kilns (Hazardous Waste Burning)

Information was briefly summarized regarding hazardous waste burning cement kilns in the U.S.:

In the ‘98 Inventory, cement kilns represent 6% of total air emission, or 150 g TEQ/yr.
Hazardous waste burning kilns are subject to MACT standards for Hazardous Waste Combustors (HWC); non-hazardous waste burning kilns are under a separate ruling
Full compliance with MACT for HWC is expected to result in a 70% reduction in dioxins and furans from this source category (this includes all hazardous waste incinerators combined)

Unresolved issues regarding hazardous waste burning cement kilns include:

the reliability of the emission estimates (emission factors have a low confidence level)
the significance of cement kilns in the Great Lakes basin
uncertainties related to reductions (i.e., How much of the expected 70% reduction will be a result of reductions in cement kiln releases versus the other types of hazardous waste facilities included in the reductions estimate?)

Dwain Winters (EPA) reported that a significant portion of the hazardous waste burning and the non-hazardous waste burning cement kilns are indistinguishable in regards to emissions. Outliers in the cement kiln data also make differentiation difficult. Dwain cited a study that was conducted on 14 cement kilns to test for differences in emissions from hazardous and non hazardous cement kilns:

In 7 of 14 kilns there were no differences in dioxin/furan emissions between hazardous and non-hazardous waste burning kilns
In 2 of the facilities, dioxin/furan emissions decreased when hazardous waste was burned
In 5 of the facilities, dioxin/furan emissions increased when hazardous waste was burned
Generally, this study indicated that the emissions are difficult to predict

Dwain committed to find out more about differences between hazardous and non-hazardous waste burning kilns in the ‘98 Inventory and regarding MACT standards

Next, the differences in emissions estimates from hazardous waste burning cement kilns and designated HWI (cement kilns are much higher) were discussed. Dwain noted that the calculated emission factors are very similar for HWI and hazardous waste burning kilns, therefore, the differences in emissions estimates are due mostly to differences in activity levels (i.e., cement kilns combust large volumes of low level hazardous waste). In addition, due to design, cement kilns also perform somewhat erratically.

Dwain also reminded the group that we will have better picture of cement kiln emissions with the new monitoring data required under MACT.

Questions were asked regarding the influence of waste input on dioxin emissions:

Dwain reported that studies show inconsistencies, but that results tend to indicate that emissions are more a result of the combustion process, rather that waste inputs
For example, this has been observed in the case of the Fast Track Rule, in which waste control measures (such as waste minimization, separation) did not have the same effect after technology upgrades occurred. Thus, in regards to dioxin emissions, efforts geared towards the waste fuel end were probably more effective for pre-regulation/interim control.
The primary motivation for burning hazardous waste at a cement kiln facility is to drive down auxiliary fuel costs; the disposal of hazardous waste may provide extra revenue.

A workgroup member asked the group if hazardous waste doesn’t have much of an effect, should the workgroup broaden their efforts to include all cement kilns?

Discussion also included ideal incinerator waste products (i.e., CO2, HCl, and water), dioxin/furan formation mechanisms, and effective formation prevention technology.

The priority status of hazardous waste burning cement kilns was discussed:

cement kilns are on hold for further assessment of cost-effective reductions until more information on the effects of regulations is available.

Summary of hazardous waste-burning cement kiln discussion:

More information is needed on post-MACT emission estimates and more information on the differences between facility types (this information will aid the workgroup in deciding on whether to eventually target this sector for action)
Information / input should be gathered from the cement kiln industry (Dale Phenecie (CGLI))
The group should investigate the Fast Track rule incentives for applicability
Information is needed on where facilities are located around basin
Sandro Leonardelli will speak to the workgroup cement kiln industry representative (Andre Auger (St. Lawrence Cement)) to find out how they are meeting control limits (0.5 mg/m3 is the federal provincial guidelines; 0.158 mg/m3 is level of control achieved in Ontario).
Anita Wong volunteered to look into control technology methods in Ontario facilities

Discussion then briefly turned to the disposal of PCP-treated wood poles:

It was noted that PCP-treated wood is not considered hazardous in Quebec
A workgroup member reported that the Viking energy facility in Michigan was burning treated wood
Information provided by Andre Auger on PCP pole use as fuel in cement kilns was referenced (these website citations will be distributed to the workgroup)

Next Steps and New Action Items:

Next Teleconference:

The workgroup will continue discussion of other sectors
Concurrently, the workgroup will initiate discussions on potential activities (possibly setting up subgroups), and continue to gather information to fill information gaps/resolve questions

New action Items:

Dwain Winters (EPA) volunteered to check on what EPA is doing related to assessing residential wood combustion (RWC) / woodstove dioxin emissions and the correlation between particulate matter and dioxin.
The workgroup will reassess potential coordination activities and appropriate reductions actions related to woodstoves, after the results of the Canadian studies and pilot projects are available in May.
Dwain Winters committed to find out more about differences between hazardous and non-hazardous waste burning kilns in the ‘98 Inventory and regarding MACT standards
Investigate the Fast Track rule for hazardous waste combustors
Sandro Leonardelli will speak to the workgroup cement kiln industry representative (Andre Auger (St. Lawrence Cement)) to find out how they are meeting control limits (0.5 mg/m3 is the federal provincial guidelines; 0.158 mg/m3 is level of control achieved in Ontario)
Anita Wong will look into control technology methods in Ontario facilities The workgroup will continue work on current action items identified in the action item update.

The next conference call is scheduled for February 1, 2000.

Participant Roster

Tracey Easthope, Ecology Center of Ann Arbor
Herb Estreicher, Covington & Burling
Stephane Gingras, Great Lakes United
Nan Gowda, USEPA Region 5
Doug Green, Piper, Marbury, Rodnick and Wolfe LLP
Dan Hopkins, USEPA
Jackie Hunt Christensen, Health Care Without Harm
Sandro Leonardelli, Environment Canada
John Menkedick, Battelle
Julie O’Leary, Western Lake Superior Sanitary District
Daniel Parshley, Glynn Environmental Coalition
Dale Phenicie, Council of Great Lakes Industries
Greg Phillips, Environment Canada
Jim Rower, Edison Electric Institute
Joe Stepun, Western Lake Superior Sanitary District
Dwain Winters, USEPA
Anita Wong, Environment Canada
Maureen Wooton, Battelle