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Gossman Consulting, Inc

GCI TECH NOTES©
Volume 5, Number 10           A Gossman Consulting, Inc. Publication          November, 1999

Regulatory Alert - CKD Testing Requirements

David Gossman

EPA has confirmed that the new HWC MACT rule requirement for testing Bevil residues (CKD) for dioxins is effective as of October 30, 1999. Facilities should evaluate data quality of any previously obtained data and then compare that data with the F039 limits. There are actually six separate limits that have to be met:

Total TCDD < 0.001 mg/kg
Total PeCDD < 0.001 mg/kg
Total HxCDD < 0.001 mg/kg
Total TCDF < 0.001 mg/kg
Total PeCDF < 0.001 mg/kg
Total HxCDF < 0.001 mg/kg

Be certain that the laboratory you use provides the data in a form that permits a valid comparison with the F039 limits to be made. Proper sampling and testing protocols are critical to avoid QC difficulties. Once past data has been evaluated, an appropriate testing frequency can be chosen. If past CKD dioxin data has been collected during "worst case" BIF Compliance Testing or Trial Burns during dioxin stack tests (as is GCI standard practice), such data may bolster claims for a reduced testing frequency.

In a related development, EPA has indicated that they will be issuing a technical amendment to the MACT rule to clarify that only those compounds on the F039 list that actually have limits must be evaluated.