Document YreRgXVbwqYrKwwgKeRk75ky

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 February 29, 1984 \ MEMORANDUM SUBJECT: National Dioxin Study - Tier 4 LiteratfureyRff/iew Source Prioritization and Testing .n /\ VyJs FROM: Edward J. Lillis, Chief f\JL [ Air Management Technology Branch, OARF TO: Regional Dioxin Contacts As you may know, the National Dioxin Study was officially initiated by Mr. Ruckelshaus late last year. The study is divided into seven tiers. The Air Management Technology Branch (AMTB) in the Office of Air Quality Planning and Standards (OAQPS) has been given the responsibility to manage Tier 4 which deals with combustion sources. We have initiated a literature review to col lect and evaluate all available emissions data for 2,3,7,8-tetrachlorodibenzop-dloxin (2378-TCDD) and other dioxin isomers from ongoing and planned work for combustion sources. A preliminary listing of these references/tests is attached. ^ This information will help us identify and prioritize (for testing) the combustion source categories that may potentially emit 2378-TCDD. We expect that only 10 to 20 actual sources can be tested with the level of funding available; therefore, we are attempting to maximize the impact of these funds. The final literature review, along with a general source category prioriti zation and proposed testing plan, will be available later this spring. At that time, we expect to work with the Regions in locating, selecting and arranging sites for possible source testing. We plan to work with the Regions and other appropriate groups or individuals to gain necessary access and approvals for testing. We would also plan to seek the support of the Regional Offices with requests to provide assistance in actual on-site monitoring during the testing program. We would appreciate your assistance in locating test data, commenting on our program, identifying potentially sensitive sources, etc. If you have any questions in the meanwhile please call me at (FTS) 629-5586 or Jim Southerland or Bill Lamason of my staff. Their telephone number is (FTS) 629-5585. Andrew Miles and/or John Williams from Radian and/or Bill Lamason will soon be contacting you to determine if we have all available pertinent test data for combustion sources to obtain any useful references they do not already have and to acquire information on current and future test programs. Any preliminary data that may not yet be approved for release would be appre ciated and would, of course, not be released by us without approval. Your cooperation and assistance will expedite both this and subsequent tasks. cc: vnief, Air Branch, Regions I-X J. Cummings, (PM-222) J. McGinnity, SASD D. Rhoads, MDAD G. Smith, RO II J . SoutherlandAMTB B. Thayll, RO V Regional Air Toxics Contacts, Regions I-X National Dioxin Strategy T ier 4 - Combustion Sources Work Plan Draft November 1983 Objective of T ie r 4 - National Dioxin Study The objective of the T ie r 4 e ffo r t of the National Dioxin Strategy is to gain a better understanding of the lik elih o o d and magnitude of 2,3,7,8-TCDD* emissions from combustion related f a c i l i t i e s . This two-year study w ill address the following questions: (a) What combustion related source categories are known to, or lik e ly to, emit 2,3,7,8-TCDD into the atmosphere and at what concentrations? (b) What is the source of 2,3,7,8-TCDD emitted from such f a c i l i t i e s ( i . e . , is 2,3,7,8-TCDD emitted only as a re s u lt of being a constituent of the fuel that is combusted, and/or is i t being formed as a by-product of the combustion process)? An outline of a work plan that addresses these questions is provided below: What Combustion Related Source Categories Are Known To (Or Likely To) Emit 2,3,7,8-TCDD Into The Atmosphere, And At What Concentration? 1. Prepare a comprehensive l i s t of combustion related source categories and the number of individual sources within each category. Develop c r it e r ia and rank each source category with respect to th e ir 1ikelihood/potential of emitting dioxin. A preliminary l i s t of source categories is provided in Table 1. 2. Review the availab le lite r a tu r e and compile, summarize and evaluate a ll previously reported dioxin related source studies fo r combustion related f a c i l i t i e s to determine:' (a) i f 2,3,7,8-TCDD was s p e c ific a lly sampled and/or measured in eith er the gas phase and/or as p a rtic u la te matter;' * At this time, the National Dioxin Study is focusing on 2,3,7,8-TCDD. However, OSWER is currently in vestig atin g other dioxin isomers that should also be evaluated. t Table 1: Combustion Related Source Categories With Potential To Emit Dioxins* Incineration o Hazardous Waste Incinerators o Municipal Waste Incinerators o Hospital (P a th o lo g ic a l) Waste In cin erators o Sewage Sludge Incinerators o Wire Reclamation Incinerators Combustion o U tility Boilers -- coal-fired -- residual o il- fire d o Industrial Boilers -- wood-fired -- coal-fired -- residual o il- fire d -- d istilla te oil-fired -- waste o il fire d -- refused derived fuel-fired o Residential Boilers -- coal-fired -- residual o il- fire d -- d is tilla te oil-fired -- other o Rotary K iln s (using contaminated o il as fu el) o Regeneration of Spent Activated Carbon at Waste Treatment F a c ilit y o Stationary Internal Combustion Engines o Highway Vehicles -- gasoline-fired -- diesel-fired Process Related o Coking o Steel Making Miscellaneous 0 Open Burning 0 Forest Fires 0 PCB Transformer Fire s 0 Structural Fires ' 0 A gricultural Burning 0 Charcoal G r ills 0 Wood Stoves 0 Fireplaces * not lis te d in any p r io r ity order (b) the concentration of 2,3,7,8-TCDD measured in: ( i ) the gas phase (ii) (iii) as p a rtic le s in control equipment dust ( i v ) in ash from combustion p it (v) in fuel or processfeed* (v i) other (e .o ., soil in the v ic in it y of the f a c i li t y ) ; ic ) the source testing methodology and the laboratory analysis methodologies used; (d) the detection lim it of the a n a ly tic a l methodologies used; (e) other dioxin sources th at were measured and reported; ( f ) source and process description of the tested f a c i l i t y (g) pertinent operating, conditions that existed a t the f a c i l i t y during the sampling period, including fuel and process ra te; and- (h) any other pertinent information. 3. Using information from items 1 and 2 above, determine those source categories fo r which additional source sampling may be needed to provide a more complete understanding of the magnitude-of 2,3,7,8-TCDD emissions discharged from the source category. 4. Recognizing that funds w ill not be adequate to f u lly te s t each source category, determine the most reasonable way to d istrib u te the available project funds so that the objectives of the study can best be achieved. C rite ria to be used in selecting source categories for testing include: (a) source categories with the greatest potential for 2,3,7,8-TCDD emissions w ill be given the highest p r io r ity for testin g ; (b) source categories fo r which data are already ava ila b le w ill need to be examined to determine i f additional source testing is needed and/or desirable; and (c) other factors. 5. Once the source categories have been selected, candidate sources for testin g within each of the source categories w ill be id e n tifie d . In i t ia l e ffo rts at locating candidate sources w ill be based on contacts with EPA's Regional O ffices. 6. C rite ria to be used in selecting sp e c ific sources for testing from the l i s t of candidate sources w ill include: (a) the representativeness of the candidate source, with respect to other sources within the source category; (b) the potential of supplemental funding and/or other support from a State/local agency in performing tshe source te s t at the candidate f a c i l i t y ; (c) the potential of piggy-backing on other related EPA and other federal agency ( e . g . s DOE) projects (e .g ., piggy-backing onto planned compli ance testing for NSPS for pertinent source categories, and/or piggy-backing on currently planned and/or funded FY-84 or FY-85 EPA projects related to testing combustion related f a c i l i t i e s ) ; and (d) other considerations.* 7. Once actual f a c i l i t i e s for testing have been selected, e ffo rts w ill be made through the Regional O ffices and the State and local agencies to secure permission to te st the f a c i l i t y . * I t has already been decided that the Hempstead in cin erato r w ill be tested under the T ie r 4 program. 8. Source testing at each f a c i l i t y w ill follow a prescribed sampling protocol that w ill be prepared in conjunction with ORD. -The purpose of the detailed sampling protocol is to assure that each of the various groups that may be funded to perform the actual source te sts under the T ie r 4 program use the same sampling methodology and c o lle c t the same pertinent operating data. The protocol shall indicate: (a) the procedures to be followed and the equipment to be used in co lle ctin g samples; * (b) the number of individual source tests to be performed at each fa cility; (c) the types of tests (e .g ., before or a fte r controls, feedstock, c o lle cto r dust, ash, s o il) ; (d) information on the various operating parameters that shall be recorded during source te stin g ; ( ej procedures to be follow ed'ccncerning the storage and shipping the samples' to ORD for laboratory a n a ly s is ;* and * ( f ) a QA/QC program for the source testing program. Note: The completion of the sampling protocol w ill be contingent upon the results of an anticipated ASME Workshop to be held on source sampling methodologies for dioxin. This workshop is currently scheduled for January 1984. 9. A source te st report, describing each source te s t conducted under the T ie r 4 program, w ill be prepared to document the te s t conditions and sampling re su lts. A detailed ou tlin e, id e n tify in g the sp ecific information to be included in the report, w ill be prepared and provided to a ll groups involved in the source te st e ffo rt. r This assumes that T ie r 4 samples w ill be analyzed by ORD. However, there is some question at th is time i f ORD w ill do these analyses. What Is The Source Of The 2 ,3 ,7 ,8-TCDD Emitted From Combustion F a c ilit ie s ? _______( i , e . . Is I t In The Fuel Or Is I t A By-Product Of Combustion)?_______ A two phased study is anticipated to address the question of where the 2 .3 .7 .8- TCDD emissions in combustion emissions come from end what factors {e .g ., operating conditions, feedstock) are important in the formation of 2 .3 .7 .8- TCDD during the combustion process). Phase 1 w ill include a summary and analysis of the various theories and hypotheses that e x ist concerning the lik e ly reasons for the formation of dioxin in exhaust emissions from combustion f a c i l i t i e s . Phase 1 w ill also examine the apparent impact of various operating conditions on the formation of dioxin emissions. Based on th is analysis, Phase I w ill re su lt in a recommended l i s t of projects that could possibly be undertaken during the-Tier 4 Study to resolve some {or a l l ) of the current u ncertainties. I f sp e c ific tasks and studies can be id e n tifie d that could be performed within the budget and timetable of the T ie r 4 e ff o r t, a Phase I I e ffo rt would be in itia te d . T ier 4 Final Report A fter the two year study, a fin a l report w ill be prepared. The report w ill focus on answering the two key questions previously id e n tifie d . In addition to summarizing e ll of the availab le 2 .3 ,7 ,8-TCDD data for combustion related f a c i l i t i e s , the report w ill also descrihe the representativeness of the available source te st data with respect to expected emissions from other sources in the source category. Known lim ita tio n s in the data base w ill also be described. The report w ill lik e ly recommend a followup program that could be pursued to gain a more complete understanding of the potential discharge of 2,3,7,8-TCDD from these combustion related sources that were inadequately characterized in the current study because of lim ited resources. The report w ill be circu lated for peer review, both w ithin and outside the Agency. Management of T ie r 4 The re sp o n sib ility for the management of the T ie r 4 Study of the National Dioxin Study has been delegated to OANR from OSWER through OW. Within OANR, the task has been del gated to OAQPS/MDAD/AMTB. Mr. Edward 0. L i l l i s , Chief of the A ir Management Technology Branch, w ill be Program Manager of the T ie r 4 Study. Mr. L i l l i s w ill be assisted by Mr. James H. Southerland, Chief of the Source Analysis Section/AMTB, and by Mr. W illiam H. Lamason, S ta ff Engineer, Source Analysis Section. A Tier 4 Work Group, comprised of representatives of the various EPA program o ffic e s , w ill be organized, and Mr. L i l l i s w ill chair the Work Group. The purposes of the Work Group w ill be: (a) to keep the program o ffic e s advised of the goals and status of the project; (b) to seek technical expertise and guidance on various issues that may arise during the project; (c) to seek and obtain suggestions concerning the most appropriate manner in which to accomplish the objectives of the study;-and (d) to review and comment on protocols, reports and other'm aterials that may be prepared for the project. As such, the Work Group is advisory in nature. Issues id e n tifie d at the Work- Group level w ill be resolved e ith e r by OANR or w ill be elevated for resolution w ithin the management structure of the National Dioxin Study. A l i s t of the program o ffic e representatives anticipated to p articip ate in th is T ier 4 Work Group is provided in Table 2. Table 2: T ier 4 Work Group , Name Organization Hail Code or Room Number Telephone Number ( FTS ) Edward J . L i l l i s OAQPS - RTP, NC James H. Southerland OAQPS - RTP, NC HD-14 MD-14 629-5586 629-5585 Lisa Barrera OANR - Washington, DC 382-7426 Jim Cummings Dioxin Management Coordination S ta ff - Washington, DC W-439 382-5363 Hike Slimak OWRS/OW - Washington, DC E-829 382-7051 Don Barnes Chlorinated Dioxin Work Group - Washington, DC E-635 382-2897 Bob Olexsey 1ERL - C in cin n ati, OH 684-7696 Dave Sussman OSW/OSWER - Washington, DC WSM-S2811 382-7927 Paul des Rosiers ORD - Washington, DC W-621 382-2722 Boniface Thayil A ir Programs - Region V 886-6054 G arrett Smith A ir Programs - Region I I 264-3407 Hike Dellarco ORD - Washington, DC H-3100 382-5763 An informal work group, comprised of various OAQPS representatives, w ill also be formed, and Mr. L i l l i s w ill serve as chairman. The purposes of this work group w ill be e s s e n tia lly the same as for the T ie r 4 Work Group. Contractual Support Several contractors w ill be used to perform varisous aspects of the T ie r 4 Study. The following two contracts are currently anticipated. 1. Management Related A contractor w ill be selected, prim arily to a s sis t in the overall management of the task. I n i t i a l l y , the contractor w ill prepare a detailed, technical work plan for the T ie r 4 e ffo r t, id e n tifyin g the key subtasks, an a lyse s,.in ve stig atio n s, e t c ., that are to be performed during the T ie r 4 Study. The contractor w ill also be responsible for monitoring the progress of the study and w ill prepare d ra ft and fin a l reports for the T ie r 4 e ffo r t. The contractor w ill id e n tify and bring to the project manager's attention, on a continuous basis, various questions/issues that may have an impact on the study. The contractor w ill also develop a detailed project schedule, which includes the completion of a d ra ft fin a l report (by the co ntractor), by September 30, 1985. 2. Lite ratu re Review and D etailed Evaluation of Existing Data A separate contract with Radian is anticipated, for the purpose of performing a lite ra tu re search and detailed evaluation of existing source te st information. The contractor w ill compile a ll availab le combustion related source te st information for dioxins and TCDDs, and s p e c ific a lly for 2,3,7,8-TCDD. Based upon c r it e r ia established by the project manager, in conjunction with the T ie r 4 Work Group, the contractor w ill review and assess the v a lid it y of each of the ava ila b le data sets to determine it s usefulness in achieving the objectives of the project. Based upon this review, the contractor w ill recommend a p rio ritiz e d l i s t of source categories for which additional source testing for 2,3,7,8-TCDD is needed to f i l l data gaps. The p rio ritiz e d l i s t w ill be reviewed by the project manager and the Tier 4 Work Group, who w ill select a fin a l l i s t of combustion related source categories for te stin g . E ffo rts w ill then be made to locate individual sources within each of the source categories fo r source te stin g . Schedule I t is expected that the detailed evaluation of ava ila b le data and the selection of sources for testing and the te s t protocol w ill be completed by March 31, 1984. Source testin g w ill begin by the summer of 1984. I t is expected that a ll T ie r 4 a c t iv it ie s w ill be completed, and a fin a l report prepared, by September 30, 1985. A more detailed schedule is provided in Figure 1. Budget The total budget for the T ie r 4 Study is $1,500,000 ($715,000 in FY-84 and S785,000 in FY-85). To the extent possible, an e ffo r t w ill be made to coordinate with other ongoing or anticipated dioxin related e ffo rts within EPA and other Federal agencies. External funding sources w ill also be pursued, p a rtic u la rly with respect to jo in t testing e ffo rts of sp e c ific f a c i l i t i e s that State/local agencies may wish to perform in conjunction with EPA. Figure 1: Anticipateci Schedule: Tier 4 - Combustion Related Sources Act ivi ties 1903 1900 1905 NDJFMAMJJASONDJFMAMJJAS ONO Begin project 1o 1i 11i 1i In i t ia l W/G Meeting* 1o 1 11i iii Perform lite ra tu re review 1 1 1 and evaluation 1 o----1---- 0 11 i 11i Se le ct source categories and 1 1 1 sources for testing 111 1 0--0 1I i 1 Obtain source agreements for 1 i te s ti ng I11 1 11 0-- ---o 1 1i ASTM Conference on source 1 1 1 te s t methodologies 1 lo 11 1 i i Prepare source te st protocol 1 lo---------- ---o 1 Conduct source testing Prepare source te s t reports 1 1 11 11 1 1 1 1 '84 Funds *'85 Fundsl o---------- 0------- o I o------------ --- o 11 In vestig ate factors which 1 ! influence formation of Phase 1 Phase 11 1 dioxin in combustion process 1 0--11 1 I Prepare draft T ier 4 report ! ii iii 1 o--- ----o 1 Revised d raft T ie r 4 report It1 Prepare final Tier 4 report 1 1 1i f o----- 0 11 i 0-- c 11 i !1 i Tier 4 Work Group w ill meet p e rio d ic a lly (bi-monthly) throughout'th study period.