Re: EPA's MACT, HWI's and dioxin

["Alex J. Sagady & Associates" <asagady@sojourn.com>]

At 12:58 PM 8/8/96 -0400, you wrote:
>----------
>Original-TO:      dioxin-l@essential.org
>----------
>Alex--
> 
>In your memo on the new CAA MACT standards you cite a figure on 
>dioxin emissions from incinerators:
>
> 
>"Currently emitted dioxin/furan per year, nationwide
> 
>All hazardous waste combustors  -- 122 pounds total congeners/
>2.15 pounds TEQs
> 
>       of the HWC total....
> 
>        .....  9 pounds (total congeners)/;0.2 pounds TEQ come
>                 from hazardous waste incinerators
> 
>        .....  113 pounds (total congeners)/1.95 pounds TEQ come 
>                from cement and aggregate kilns
> 
>See page 17366, April 19, 1996 Federal Register...
> 
>(Having not reviewed the rule, I assume this figure only covers 
>commercial incinerators, kilns, etc.?)


These figures are for hazardous waste combustors, which 
include commercial and on-site hazardous waste incinerators,
and hazardous waste burning cement and light-weight 
aggregate kilns, according to EPA.   In the same document,
EPA cites one of their national dioxin documents which 
indicates that the whole annual national emission of dioxin/
furan emissions to be 4.18 pounds of TEQ per year.  As a result,
the proposed regulation would deal with emission sources 
covering 51% of all dioxin emissions, according to EPA;s 
estimates.


> 
>Another problem with EPA's rule is that it exempts on-site BIFs 
>and HWIs, which have been put off until phase 2, along with all 
>the other categories of combustors.  The importance of this is 
>that some of these incinerators burn the most highly-chlorinated 
>wastes generated and probably release more dioxin than any other 
>kind of incinerator.  

Not exactly...   on-site hazardous waste incinerators ARE COVERED
by the rule...

....  industrial boilers that burn hazardous waste
and other types of  industrial furnaces (such as smelters and
acid furnaces)  that may be used to 
burn hazardous wastes are NOT covered in this present
rulemaking.


> 
>The vinyl chloride manufacturers, for instance, burn thousands of 
>tons per year of "tars" from EDC/VCM production, which have high 
>levels of PCBs and dioxins.  Dow's VCM wastes are documented to 
>contain up to 320 ppm PCBs.

320 PPM of PCBs is a relatively small amount, considering all of
the transmission and capacity dielectric oil out there which will
be far, far higher....

  We sampled a barrel of distillation 
>tars from Vulcan and found 6 ppm TEQ dioxin!  Since they also 
>contain (in some instances) copper catalysts from the reaction 
>process, they not only release uncombusted dioxin, but most 
>likely form all sorts of PICs.

But what was the results of tests from burning these wastes???  Also,
it is hard to believe that these would be going to an industrial
boiler rather than a dedicated hazwaste incinerator somewhere...

> 
>Some of these facilities (like PPG in Lake Charles) not only burn 
>their own wastes, but those of other companies.  Must be 
>lucrative. 

If they operate a hazardous waste incinerator, they would be 
covered by the proposed rules....

> 
>EPA also failed to look closely at these incinerators as part of 
>its Dioxin Reassessment source inventory.  Industry has failed to 
>submit any data as part of its voluntary self-characterization 
>scam (they are testing water etc. first), though they know that's 
>likely to be the largest source of dioxin from production plants.  
> 
>Dow has 18 on-site HWI's and BIFs at its Freeport facility alone.  
>A week or so before their shareholders' meeting this May they did 
>a press conference at the National Press Club in DC claiming (for 
>the second time) that they will get 90% dioxin reduction in the 
>next ten years.  Either they are lying because they have no 
>baseline of data to stake this claim upon, or they have failed to 
>cough up the data for the EPA's call-in.  Which is it?

EPA is predicting that only 5-8 percent of ALL hazwaste incinerators 
and cement kilns will be able to meet ALL of the MACT standards,
so there must be room for improvement out there.....There are
large ranges, over several orders of magnitude of existing 
emission control performance for dioxin emission control out
among existing waste incinerators and hazardous waste 
burning kilns.


> 
>Some of the VCM plants (like PPG and Borden) still use mercury in 
>their chloralkili process.  PPG has a mercury recovery unit 
>which is also likely to be a significant source of mercury.  
>Unfortunately, I don't have exact figures.

Most mercury emissions come from burning coal, particularly 
high sulfur coal.....

Alex J. Sagady & Associates    		Email:  asagady@sojourn.com
Environmental Consulting and Database Systems
PO Box 39
East Lansing, MI  48826-0039         (517) 332-6971 (voice); (517) 332-8987
(fax)