A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617. Tel: 315-379-9200. SEPTEMBER 1995

New Data indicates U.S. EPA
greatly underestimated
dioxin emissions
from U.S. trash incinerators

The total dioxin
emissions from the whole
of Germany is estimated at less than
1,000 grams a year.
In 1994, Waste Not estimates that
the Norfolk, VA, incinerator
was putting out
2,425 grams dioxin
per year.

Part 1: Under a Freedom of Information Act request submitted in October 1994, Waste Not was able to obtain1 the dioxin emission data from eleven trash incinerators fitted with ‘hot-sided’ electrostatic precipitators (ESP). These incinerators allow the flue gas to enter the ESPs (air pollution control device) at or above 440°F, i.e., temperatures which allow the excessive formation of dioxins on the particles captured in the control device. This phenonema of ‘post-combustion formation’ of dioxins has been known since 1985. A simple and approximate extrapolation of this emission data indicates that eleven incinerators were putting out, as recently as 1993, a combined yearly total of dioxins, measured as 2,3,7,8-TCDD toxic equivalents of between 4,500 - 6,000 grams. In the US EPA’s dioxin exposure document released to the public in Sept 1994, the authors estimated that the total annual dioxin emissions emitted from 171 (sic) U.S. trash incinerators was 3,000 grams. The EPA’s 3,000 gram figure was based on calculations by Radian Corporation who appear to have used emission data collected in 1988 and 1989. If these new data are included, that figure should be raised to 7,500 - 9,000 grams/year. However, even this figure of 7,500-9,000 grams/year, underestimates the actual total because there were some other serious problems with Radian’s and U.S. EPA’s estimated 3,000 gram total.

A) They did not include an estimate of emissions during soot blowing, upset conditions or periods when the air pollution control devices were by-passed.

B) The U.S. EPA use of a flue gas flow rate of 2.69 cubic meters per kilogram of waste burned is a low estimate. Had they used a more realistic average flue gas flow rate of 5 cubic meters per kilogram of waste burned, the TEQ total would have doubled to approximately 6,000 grams per year.

C) The U.S. EPA use of a conversion factor of 1/60 to convert total dioxins and furans to dioxin TEQ further underestimated the TEQs. A conversion factor of 1/41 would have been more appropriate. (Ref: USEPA, May 1994, Combustion Emissions Technical Resource Document (CETRED), EPA 530-R-014. Draft) This would have further increased the total TEQs per year to approximately 9,000 grams per year.

With these additional adjustments, the total TEQ for all U.S. trash incinerators operating in 1993 would have been at least 13,500 to 15,000 grams per year. It is not enough for the EPA or the incinerator industry to claim that some of these incinerators have been modifed or closed down. With the notion that dioxins can recycle in the environment it is important that we have the best estimates of emissions on a yearly basis going back to where dioxin measurements were first made in trash incinerators. In Waste Not’s calculations we simply compared the average emissions of each incinerator, measured in ng of total dioxins and furans per dry standard cubic meter (see table below) with the emissions of the Columbus, Ohio, incinerator, and ______________________________________________________________________________________

1. Waste Not FOIA request of October 4, 1994 to Fred Porter, U.S. EPA. Response received on July 27, 1995; letter signed by Fred Porter for Bruce C. Jordan, Director, U.S. EPA, Emission Standards Division, Office of Air Quality Planning and Standards.

scaled them according to the size of the incinerator (in tons per day) and to the yearly total of 984 grams of 2,3,7,8-TCDD equivalents extrapolated from the Ohio EPA analysis of the measurements made at Columbus in September 1992. See sample calculation below.

Table: Summary of Dioxin Emission Measurements & Estimated Annual Totals

Note: only measurements made prior to modifications were used in order to get an accurate assessment of the emissions for the years of operation prior to 1994.

Location Tons Date Emissions Average Waste Not estimate* of

Per Tested PCDD/PCDF PCDD/PCDF cumulative total emissions

Day ng/dscm ng/dscm grams dioxin TEQ/Year

Tampa, FL 1000 1994 893 2,160 3,862 146 8,533

Pinellas 3000 1994 1,964 County, 3,840 3,401 386 FL 4,400

Waipahu, HI 600 1994 5,690 5,690 129

Pulaski 1500 1993 3,313 Maryland 5,984 6,114 347 9,045 Clinton Twnsp,

MI 600 1994 3,254 3,254 74 Detroit, IL 3300 1993 2,851 2,851 119a

Columbus, 2000 1992 12,998 12,998 984b OH Dayton (N), 900 1994 8,100 8,100 276 Ohio (85)c(3)c

Dayton (S), 900 1989 15,815 15,815 539 OH(766)d (26)d

Harrisonburg 100 1994 8,459 8,459 32 VA

Norfolk, VA 2000 1992 37,468 1993 21,129 1993 32,237 32,039 2,425 1994 42,995 1994 26,360

Akron, OH 1000 (Not tested) 492e

Total = 4,671 g               Total = 5,457 g