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Dioxin (PCDD/PCDF) Emissions, Sources and Test Methods
dibenzo-dioxins (PCDDs) and
Polychlorinated dibenzo-furans (PCDFs)
In the beginning
Gossman Consulting, Inc. has been looking closely at PCDDs/PCDFs, what the general public has come to know as dioxins/furans, emissions as relates to combustion devices since 1990. Even before that, when the boiler and industrial furnace regulations were being developed starting in 1987, GCI has been involved in reviewing USEPA proposals and providing comment whenever possible. It was in 1992 however that PCDD/PCDF emissions began to get increasing attention from combustion device emissions when the first round of compliance testing began for boilers and industrial furnaces (BIFs). It was at this time that 15/28 BIFs reported dioxin emission results. GCI reviewed all of that data as part of publishing a report on all of the BIF compliance testing performed in accordance with the 8-21-91 compliance deadline. GCI was primary contractor for four of these tests, designing/planning them from the ground up, and involved in a total of seven tests or 25% of the BIF testing. GCI was later involved in an extensive dioxin emissions testing data review for the Portland Cement Association. This review included dioxin emission data produced by non-hazardous waste burning cement kilns since the 1992 BIF testing. While some data was not good enough to be used or had to be qualified in some fashion, all Gossman Consulting, Inc. managed tests resulted in sound data.
Gossman Consulting, Inc. also prides itself in having reviewed the USEPA dioxin report to Congress, which was released to Congress as well as the general public in 1994. Much has been reported on this dioxin report. The USEPA’s own Science Advisory Board found problems with conclusions presented in the report in that the excellent data review found in most of the report did not support the report conclusions. GCI also published a version of their comments to the USEPA on this report. One of the more important ideas to come out of this review, put forth by USEPA but given little emphasis, was the resuspension of dioxins. "Naturally occurring" dioxins if you will. More on this concept a little later.
The general negative effect on combustion
Since the release of the draft dioxin report to Congress industry has been forced to become increasingly more familiar with dioxin emissions and the possible sources of those emissions. Interestingly enough, the all out assault on dioxins by the USEPA has actually turned the waste disposal debate back towards landfills as a preferred disposal option rather than combustion. Many municipalities around the United States have either shut down their waste combustion units or are in the process of doing so. It is also worth note that even after the serious criticism by the USEPA’s own Science Advisory Board, the draft report has still not been finalized even though three and one half years have passed.
The debate continues
Gossman Consulting, Inc. did have the opportunity to attend one of the dioxin workshops conducted by the USEPA in the fall of 1996. Unfortunately, it was quite clear from the workshop that EPA was not interested in changing their agenda, justified or not, but were just interested in making sure that they had turned over ever whit of information as to possible sources of dioxins. Even more interesting, they had already discounted the role of possibly one of the largest sources of environmental dioxins, forest fires. Resuspension of naturally occurring dioxins can occur from forest fires. Resuspension of naturally occurring dioxins can also occur if large amounts of raw materials go into a combustion process such as cement manufacturing. A general overview of that workshop is available at this web site for interested parties.
Gossman Consulting, Inc. has also been involved in reviewing the proposed hazardous waste combustor regulations which ratchets down the allowable dioxin emissions from combustion devices even further. The first round of HWC comments by GCI is also available at this web site.
Dioxin emission and source assessment
As already mentioned, GCI has written numerous test plans to include dioxin (PCDD/PCDF) testing. This includes process sampling, raw material source testing and emissions testing. We are experienced in providing quality assurance and quality control to ensure defensible test result data. We have done this for many clients across the United States as well as internationally. GCI dioxin experience spans a 10 year period and remains current as the debate on dioxins heat up.
SARA 313 (TRI) Reporting Requirements for Dioxins (PCDD/PCDFs)
"Sources of PCDDs/PCDFs in Cement Kiln Emissions”
GCI Tech Notes "Dioxins - Primer & Commentary”, May-96
GCI Tech Notes "A Caution in the Use of Analytical Data in Calculating TEQ Values for Dioxin Reporting”, Dec-95
GCI Tech Notes "Dioxin Health Assessment Document Review and Comment, (EPA/600/BP-92/001a,b & c)”, March-95
GCI Tech Notes "EPA Dioxin Exposure Assessment Comments”, Feb-95
HWF Notes "A Review of Dioxin Emissions and Cement Kilns”, Sep-94
HWF Notes "Testing for Pentachlorophenol as a Screening Procedure to exclude PCDD’s and PCDF’s from Hazardous Waste Fuel”, Dec-93
How to interpret and understand dioxin (PCDD/PCDF) data from emission tests and industrial / environmental samples.