A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 NOVEMBER 1994

BACKGROUND: When Waste Not learned that the EPA had mandated that some incinerators, operating with only an electrostatic precipitator (ESP) for pollution control, be tested for dioxins, we requested under the Freedom of Information Act (FOIA) the location of the incinerators and the test results. We understand that this mandate was initiated in January 1994 by Carol Browner, Administrator of the U.S. EPA, in response to the very high dioxin emission test results from the Columbus, Ohio, trash incinerator. On November 9, EPA’s Fred Porter telephoned us and said our request was denied on the grounds, (1) it was the first request he had received and (2) the results may cause alarm. In the same FOIA request we asked for the dioxin emission test results from all trash incinerators since 1977. Though Fred Porter informed us of the enormous amount of work that this would involve, and that it probably would cost us “thousands of dollars,” and would take at least “six months, maybe even longer” to complete, we informed him that we needed the information in our review of the Sources document of the Dioxin Reassessment. The material he agreed to send us would include the 1994 MSW incinerators tested in 1994, which he had previously denied us. Though Porter refused to inform us of the incinerators that were tested for dioxin in 1994, we received a copy of them, from another source, along with a letter that Porter wrote to EPA regional offices regarding these tests.

EPA Plant Size Group 1 Group 2

Plant Name State Region (tons per day) Testing Dioxin ESP-temp State Lead

Harrisburg PA 3 720 x No

Harrisonburg VA 3 100 x No

Pinnellas FL 4 3000 x No

Hillsborough FL 4 1200 x Probably Not

Tampa FL 4 1000 x Probably Not

Lakeland FL 4 300 x Probably Not

Key West FL 4 150 x Probably Not

Mecklenberg NC 4 235 x Yes, if EPA sends $

Dearborn Hts. MI 5 500 x Probably Not

Clinton Twnshp MI 5 600 x Probably Not

Olmstead MN 5 200 x Probably Not

Akron OH 5 1000 x Yes

North Dayton (#3) OH 5 900 x Yes

Ames (#8) IA 7 200 x No

Honolulu HI 9 800 x No

Prudhoe Bay AK 10 100 x No

Letterhead Address: U.S. EPA, Office of Air Quality Planning and Standards, Research Triangle Park, N.C. 27711

Subject: Municipal Waste Combustors (MWC’s) -- Dioxin Testing

From: Walter Stevenson for Fred L. Porter, Chief, Regulations Development Section, SDB (MD-13)

To: Director, Air, Pesticides and Toxics Management Division, Regions I and IV; Director, Air and Waste Management Division, Region II; Director, Air, Radiation and Toxics Division, Region III; Director, Air and Radiation Division, Region V; Director, Air, Pesticides and Toxics Division, Region VI; Director, Air and Toxics Division, Regions VII, VIII, IX, and X.

“We successfully completed phase 1 of the municipal waste combustor (MWC) dioxin investigation. This included identification of: (1) MWC’s that have tested for dioxins, (2) MWC’s that are not of concern because of design or operational parameters, and (3) MWC’s that require dioxin testing. We are now starting phase 2 of the MWC investigation, which is dioxin testing. A teleconference is scheduled for Wednesday, March 30, 1994 from 3:00 p.m. to 5:00 p.m. (Eastern Standard Time) to discuss dioxin testing. The meeting can be accessed by calling (919) 541-1592.

“The meeting will focus on those MWC’s that require Regional Office issuance of Section 114 letters. Most of the MWC’s to receive 114 letters are in Regions IV and V, but testing is also required in Regions III, VII, IX, and X. As we discussed during our meeting on March 10,1994, our first choice was to have State agencies assume lead responsibility for testing; however, only one State (Ohio) stepped forward to assume lead responsibility. In cases where the State is not able to assume lead responsibility, the EPA must assume that responsibility. Whether a Section 114 letter is issued by the EPA or the State issues its own letter requiring testing under the State’s authority, dioxin testing would be completed and the test results submitted to the Regional Office within 90 days of issuance of the letter.

“Attached for your use is a ‘model’ Section 114 letter. Also attached is a listing of MWC’s that require Section 114 letters (see Table 1). Table 1 is arranged by Regional Office and subcategorized into two groups. The first group is those MWC's that have not been tested recently, have a ‘hot’ ESP, and have the potential for high dioxin emissions. This first group (13 MWC’s) includes those MWC’s that have never been tested, as well as those that have not been tested since 1989. The second group (3 MWC’s) includes those that have not been tested recently and the ESP inlet temperature is unknown. For the second group, the MWC’s can be removed from the list if the source provides copies of data that show the ESP inlet temperature is significantly less than 450 degrees F; otherwise, a dioxin test is required. If we have incorrectly reported any information on Table 1, or if the information has changed since being reported to us, please note those corrections at the March 30 teleconference. Please call me at (919) 541-5251 or Walt Stevenson at (919) 541-5264 if you have any questions on any of the attached information.”

cc: Bob Baker, Region IX; Doug Bell, SDE (MD-13); Richard Chakot, Region II; John Coursier, Region 1; Scott Davis, Region IV; Tom Driscoll, Region VI; Tim Fisher, Region V; Chris James, Region X; Bruce C. Jordan, [illegable, perhaps ESD] (MD-13); Cory Potash, Region VIII; John S. Seitz, OAQPS (MD-10); Art Spratlin, Region VII; Jim Topsale, Region III.

“Information available to the Environmental Protection Agency (EPA) indicates dioxin emission levels from the (NAME) municipal waste combustor (MWC) may present an imminent and substantial endangerment to the public health or welfare or the environment under Section 303 of the Clean Air Act. If the information outlined below is correct, the EPA directs the (NAME) MWC to perform an emission test to measure dioxin emission levels and report the results of this test to the EPA...

“The information available to the EPA, indicates that the (NAME) MWC currently operates without a ‘scrubbing’ system. This MWC also operates an electrostatic precipitator (ESP) with an inlet combustion gas stream temperature in the range of 450 degrees Fahrenheit or greater. In addition, no emission test to measure dioxin emission levels has been performed at this MWC within the past 5 years.

“Scrubbing systems control dioxin emissions by injecting or spraying a lime-water mixture into the combustion gases after these gases leave the MWC. The absence of a scrubbing system indicates there is little, if any, control of dioxin emissions at the (NAME) MWC.

“Operating an ESP with a combustion gas inlet temperature in the range of 450 degrees Fahrenheit or greater, normally leads to substantial formation of dioxin in the ESP. By operating in this manner the ESP at the (NAME) MWC may be generating dioxin emissions at levels which present an imminent and substantial endangerment to the public health or welfare or the environment. It is possible dioxin emissions from the (NAME)MWC are not at such levels. No emission test to measure dioxin emission levels, however, has been performed at this MWC within the past five years.

“If this information concerning the absence of a scrubbing system, the temperature of the combustion gases at the inlet to the ESP, or the lack of an emission test to measure dioxin emissions within the past five years is incorrect, please contact (NAME) at the EPA Region ___#___ by (One week from date of letter). If the inlet temperature of the combustion gases entering the ESP is incorrect, provide a record of recent temperature measurement data indicating the correct temperature of the combustion gases entering the ESP. If an emission test has been performed within the past five years to measure dioxin emission levels, provide the results of this test, the date of this test, and a copy of the test report...If the information is correct, under the authority of Section 114 of the Clean Air Act, the EPA directs the (NAME) MSW to perform an emission test, as prescribed below, to measure dioxin emission levels. The results of this test must be submitted to ((NAME) at the EPA Region _#_ office by (Ninety days from date of letter)...In addition, these test runs should not occur during soot blowing in the MWC, but should occur during the normal rapping cycle of the ESP....”