A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 NOVEMBER 1995
Note: Standards apply to New MWCs, over 40 tpd, that began construction after Sept. 20, 1994; Guidelines are the standards that apply to Existing MWCs. MWC = Municipal Waste Combustor; APC = Air Pollution Control System.
ng/dscm = nanograms per dry standard cubic meter
Small Existing MWCs = 40 to 250 tpd; Large Existing MWCs = 250 tpd and over; New MWCs = all over 40 tpd.
Dioxins/Furans = total mass of tetra- through octa- chlorinated dibenzo-p-dioxins and dibenzofurans
All concentration levels in the table are corrected to 7 percent O2, dry basis.
1995 Standards for 1995 Guidelines for Proposed 1991 Guidelines
NEW MWCs EXISTING MWCs in 1994 & Standards SMALL MWCs
For MWCs constructed after Sept. 20, 1994, 125 ng/dscm (mandatory) 60 ng/dscm for None.
but on or before Sept. 22, 1997, the or 30 ng.dscm (optional existing incinerators; See (d) below
standard is 30 ng/dscm for the first 3 years of for less frequent testing)c 13 ng/dscm for operation. After the first 3 years, the standard is new incinerators.
NEW LARGE MWCs
Same as above 13 ng/dscm for New MWCs
MWCs. with units (i.e., boilers) over 250 tpd: 30 ng/dscmd
Large MWCs utilizing ESP-based APC
60 ng/dscm or 30 ng/dscm 250 tpdd
15 ng/dscm (optional for to 1100 tpd; less frequent testing)c 125 ng/dscm;
Over 1100 tpd
= 60 ng/dscm
Large MWCs utilizing a non-ESP APC
30 ng/dscm (mandatory) or 30 ng/dscm see above 15 ng/dscm (optional for less frequent testing) (c)
U.S. EPA Dioxin/Furan Standards and Guidelines are less stringent than the German, Dutch, Austrian & Swedish Dioxin/Furan Standards for MWCs.
EPAs standards, compared to the European standards, using the PCDD/PCDF/TEQ rate 41.2e are
13 ng/dscm 3 times less stringent 60 ng/dscm 14 times less stringent
15 ng/dscm 4 times less stringent 125 ng//dscm 30 times less stringent
30 ng/dscm 7 times less stringent
* The standards are expected to be published in the Federal Register (FR) in late November 1995.
Basis for dioxin/furan limits:
Existing Small MWCs: Good Combustion Practices (GCP) and Dry Sorbent Injection/ESP
Existing Large MWCs: GCP and Spray Dryer/ESP; or GCP and Spray Dryer/Fabric Filter
New Incinerators, Large & Small: GCP and Spray Dryer/Fabric Filter/Carbon Injection
...The EPA strongly believes (based on emissions data from MWCs which incorporate the necessary control technology) that the air pollution control technology to be retrofitted to existing MWCs to meet the emission guidelines will reduce actual emissions to levels significantly below the limits established by the emission guidelines. There remains, however, some uncertainty as to the actual performance level that will be achieved on a continuous basis by the control technology when installed at large MWC plants where ESP-based scrubber systems are used...Since proposal, the EPA has obtained data from 12 new MWC units [boilers] at 5 MWC plants that have recently begun operation and all are equipped with the full set of controls proposed as MACT (SD/FF/SNCR and carbon injection). Data from these plants show that all proposed emission limits for all pollutants are simultaneously being achieved. Therefore, the EPA remains convinced that properly designed, constructed, maintained, and operated MWC plants can comply with all pollutant emission limits included in the final standards...
Comment from Waste Not: While some national environmental groups may be cheering at EPAs new tougher regulations on trash incinerators, we sigh. We sigh for two reasons. Firstly, tough regulations, of themselves, do not protect the public from toxic air emissions. Three things are needed to do that: (1) tough regulations, (2) adequate monitoring, and (3) aggressive enforcement. If either of the later two factors are missing, the public is not protected. In the case of trash incinerators, it is not possible to monitor the facilities in a scientific fashion. There is no equipment available that can monitor dioxin and heavy metal emissions on a continuous basis. The best we can hope for is that the plant will be checked once a year. We, the gullible public, are expected to believe that such measurements, made with advance notice, and made under ideal conditions, will indicate what happens under upset conditions, or what happens when the incinerator is burning a different kind of waste stream like demolition debris, pharmaceutical waste, industrial waste, railroad ties, tires, or medical waste (see WN #311), or what happens late at night, or what happens 24 hours a day the other 360 days of the year! Also, no one knows what material is burned during dioxin emission tests. (See WN # 302 on the rigged dioxin tests at the Columbus, Ohio, incinerator, where the waste stream had been stockpiled, dried and plastics removed, for the 1994 tests. Rigging the tests is a federal crime, but EPA took no action.)
Secondly, we sigh because once again, it shows that otherwise clever people can become over-preoccupied with the wrong question: a wrong question, in this case, because it deals with the wrong end of the problem. Our task as we approach the beginning of the 21st century is not to find safer ways of destroying our waste, but to find ways of avoiding making it in the first place. We should not be spending billions of dollars destroying resources we should be sharing with our children and grandchildren. However, such revolutionary ideas fall on deaf ears at the EPA, because the back-end thinkers who spin the regulatory wheels promote policies in the best interest of the multinational corporations who build these machines and the other multinational corporations who make most of the materials we throw away in the first place.
Einstein said it best: a clever person solves a problem, a wise person avoids it. Whatever happened to EPAs Pollution Prevention Policy? It is interesting that the EPA spent a considerable amount of taxpayers money to calculate how many billions of dollars these new regulations would cost. However, they did not cost out the only alternative that makes any economic or environmental sense. And that is to shut the incinerators down and to put the money into source separation, reuse, recycling and composting programs. As for the remainder, the EPA should pluck up the courage to tell the multinationals that if our communities cant reuse, recycle or compost their products, then they shouldn't be making them!
What is particularly sad about all this short sighted policy is that it comes at a time when very good scientists at the EPA are under attack from corporate interests for their reassessment of dioxin. It makes it more difficult for those of us to uphold science free of corporate influence at the EPA only to have to deal with policy makers at the same agency who so easily become influenced by these same corporate interests. For those who feel we are overstating the case we refer you back to Carol Browners deplorable decision (WN #s 315-318) on incinerator ash testing, which has made it possible for nearly all incinerator ash to pass the so-called toxicity test, and thus highly hazardous ash is being sent willy-nilly to regular landfills.
For the record, none of the new standards are as tough as the dioxin standards for trash incinerators in Sweden, Germany, Switzerland, Austria, or Holland. Their standard is 0.1 ng of dioxin teq/dscm. If we convert the total dioxins and furans used in the EPAs standards to TEQs, using a conversion factor of 1 / 41.2 (an average figure developed in EPAs CETREDe document) we find that the EPA standards range from 3 times to 30 times higher than these European standards.
a. The standards include provisions that allow large and small plants to conduct performance tests for dioxins./furans on only one unit per year if all units at the plant achieve emission levels of 7 ng/dscm total mass for 2 consecutive years.
b. The standards include provisions that allow small MWC plants to conduct performance tests for dioxins/furans (as well as PM, Cd, Pb,, Hg, HCL) every third year if the MWC passes the annual performance test for the pollutant for three years in a row. If any subsequent annual test indicates noncompliance, then annual testing will again be required until three annual tests in a row indicate compliance.
c. The emission guidelines include provisions that allow large and small MWC plants to conduct performance tests for dioxins/furans on only one unit per year if all units at the MWC plant achieve an emission level of 15 ng/dscm total mass (large plants) or 30 ng/dscm total mass (small plants) for 2 consecutive years.
d. 1991 Standards & Guidelines. Units [i.e. boilers] under 250 tpd were exempted (i.e., if a 300 tpd incinerator had 3 boilers of 100 tpd each, it would be exempt from the standard). The 1995 standards and guidelines apply to each MWC plant.
e. US EPA, Combustion Emissions Technical Resource Document (CETRED), EPA530-R-94-014, May 1994, page 4-31
Editors: Ellen & Paul Connett, 82 Judson Street, Canton, New York 13617. Tel: 315-379-9200. Fax: 315-379-0448.