1 day left to comment (by email) on halogens in hwi fuels

[ttweed@wildrockies.org (Tony Tweedale)]

  some days ago i posted a f.r. notice (97-23,843), 'Revised Technical
  Standards for Haz Waste Combustion Facilities' announcing epa's intent to
  accept new industry data on total halogens in fuel oil and gasoline, which
  happens to show 16-1,000 ppm/v levels, allowing this data to be used to
  allow high halogen levels in acceptable fuels for hw combustors.  epa's
  earlier halogen tests on fuels were using a definition of total halogens
  that excluded inorganic halogens (!, due method difficulties and a concern
  'that the inorganic fraction is widely variable').  i have no problem w/
  the industry data's total halogen meaning just that, and it (only ~20 data
  points) does vary over 2+ orders of magnitude--possibly due to the
  inorganic fraction.  but why allow as much as 500 ppm/w (in the 99th
  percentile, and 260 ppm/w at the 90th percentile, and 25 ppm/w at the 50th)
  halogens in  fuel, when epa now has its own data showing total (incl.
  inorganic) halogen content all at less than the non-detect level of 25
  ppm/v??
  
  
  tony tweedale