Document g2MNz7RxNQb6abEzdOVM0vv1e

r c UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 JAN 9 1984 MEMORANDUM SUBJECT: Preliminary Estimates National Dioxin Study rements for Tier A of FROM: Edward J. Lillis, Chie Air Management Techno TO: Alexander McBride, Chief Water Quality Analysli Branch (WH-553) Per recent conversations with the Office of Water (OW), the Office of Solid Waste (OSW), the Office of Research and Development (ORD) and other National Dioxin study participants, our preliminary estimate is that approximately 1200 analyses for dioxin isomers will be required for the Tier A (combustion sources) of the National Dioxin Study. This preliminary estimate assumes that 15 to 20 sources wiil be tested and that an average of 25t 30 samples will be analyzed. Two separate analyses will be required for each sample to determine 2378-TCDD and the tetra, hexa, octa and hepta*homologues (at high resolution parts per trillion concentrations). The 1200 analyses include an allowance of approxi mately 20 percent for quality assurance purposes. Analysis of other organic and inorganic substances, such as total chlorine, will also be required but will be done by other contractor laboratories. These estimates are soft at this time but will be firmed up following the results of the American Society of Mechanical Engineers (ASME) workshop that is focusing on dioxin sampling and analysis protocols. The type of samples to be analyzed at most external combustion point sources are expected to generally agree with the "model" in the attached table. The typical number and type of samples will probably vary considerably for internal combustion engines, wood stoves and other special sources if such sources are tested under the program. At this time, we do not expect sampling to begin until the Summer of 198A. As a result, samples would be sent to the labs for analysis over a time period of about a year. Sample lot size will be coordinated with ORD. A decision path way will be developed and followed which would allow for "in lab" determinations of when some of the analyses may not be warranted. Sufficient storage-and possible future analyses for other dioxin isomers and furans not addressed under the current funding levels will need be considered. Please review these estimates and give me your reaction. If your office authorizes it we understand such an effort would be In agreement with ORD's 'support and capacity to handle the work. We would like to establish reasonably firm committments and get the necessary concurrences so that we can adequately plan the Tier 4 sampling program. Thank you for your continued assistance on this matter. We look forward to working with you in the future on this project. cc: Jim Cummings, OSW (PH-222) Michael Cook, OSW (WH-562) Michael Dellarco, QAMS (RD-675) Paul desRoslers, ORD (RD-681) Bill Lamason, AKTB Gary McAlister, ESED Joe Padgett, SASD Robert Olexsey, IERL/Cinn. Steve Schatzow, OWES (WH-551) Mike Slimak, OW (WH-553) Garrett Smith, RO II James Southerland, AMTB Davjd' Sussman, OSW (WH-656A) JJwlilface Thayil, RO V TABLE 1. PRILIMINARY SAMPLE ANALYSES ESTIMATES FOR SOURCE TESTING UNDER TIER 4, NATIONAL DIOXIN STUDY SOURCE PROBABLE NUMBER OF SAMPLES LOW | HIGH |AVERAGE POSSIBLE COLLECTION MEDIA OTHER ANALYSES (TIER 4 CONTRACTORS) Stack/Vent Before Control^ After Control^ >* Fuel/Waste Feed^ 39 09 36 6 MM5 filter, wash sorbents Total chlorine 6 Total organic chlorine 3 Grab samples Total chlorine Total organic chlorine Waste compounds (l.e. PCB, TCP) Indicator organics (l.e. substituted benzenes) Ash or Slurry From Control Devlce^^ 03 2 Grab samples Total chlorine Waste Compounds Bottom Ash^ ABh Quench Water7 Ash Pit Water7 Service Water7 Precombustion Air7 Soil7 Local Ground/Surface Waters7 02 02 02 02 02 06 02 2 Grab samples 1 Grab samples 1 Grab samples 1 Grab samples 1 Filter 3 Grab samples 1 Grab samples Waste compounds Total chlorine 1 TOTAL 6 45 27 number of samples would be more representative of tests on an external combustion, point source (e.g. boiler or incinerator) but less representative of other tests on area sources (e..g._internal__ combustion engines, fireplaces, and open burning). The estimated number of analyses per sample in Table does not include quality assurance samples. All analyses are for ppt concentration using high resolution techniques, but these may not be required for all samples. ^Three test runs before and after control. Low estimate assumes combined analysis of implnger and sorbent catches, while high estimate assumes separate analyses of two sorbents and Implnger extracts ^Low estimate assumes no control device on a tested source. Mligh estimate assumes separate analyses of two fuels for co-fired sources. ^High estimate assumes as many as three control devices used In exhaust cleaning. ^Low estimate assumes no bottom ash from process (e.g. internal combustion engines). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY August 19/ 1983 REGION II SUBJECT: Dioxin Strategy - Tier 4 FROM: Dick j Deput; Admini strator Steve rector Office of Water Standards & Regulations, WH-551 In November 1981 EPA issued a document entitled "Interim Evaluation of Health Risks Associated with Emissions of Tetrachlorinated Dioxins from Municipal Waste Resource Recovery Facilities". The "Draft" strategy makes little reference to this Agency report, which essentially indicates that if municipal combustion facilities operate within an "emission window" of ND - 3.5 ng/dscm for 2,3,7,8 TCDD, and N.D. - 8.5 ng/dscm for total TCDDs, there should be no reason for public health concern. Steve, since a finalization of additional studies or results to support Tier 4 activities/decisions are at least 12 - 18 months away, what is our position which regard to the November '*81 report. I don't know about other areas of the U.S.; however, in the Northeast, the push is on for the construction of resource recovery facilities. Therefore, we need to know now,' pending the receipt of additional information under the strategy, whether or not we still follow the November *81 document. cc: Al Aim, Deputy. Administrator A-101 Lee Val Thomas,.Adamkus, AARegfioornaSlolAiddmiWnaissttera&toErm,ergReengciyonRVes\p/onse, WH-562A Chuck Elkins, Acting AA for Air, Noise and Radiation, ANR-445 E P A Form 1320-6 (Rev. 3-76) A U Se 51983 pr u. 7W"n1ST|: A % 4 & f- O^' * * s g <2 \l TIER 4 STATUS REPORT July 17. 1984 OUTLINE Accomplishments Since Last Meeting Brief Summary Of Tier 4 Work Plan Alternatives Considered/Rejected In Designing PI Outstanding Issues Accomplishments Since Last Meeting o OAQPS reorganization to establish 4-person group to focus solely on T ier 4. o Draft Tier 4 Work Plan Sent For Internal/External Review and Comment (June) - Regional Offices - SAB - CDWG - Tier 4 Work Group - Others o All Tier 4 Project Funds Committed. o Arrangements Nearing Completion For IERL-ORD Support For Source Testing. 2 Summary Of Tier 4 Work Plan Mote: Study Design, By Necessity, Based Upon Resource Constraints. Objective: Problem Definition To The Extent Possible, Address The Following Two Questions: 1. What Source Categories Emit 2378-TCDD? 2. At What Concentration Is 2378-TCDD Emitted? Key Elements: Stack Testing Program o 12 Source Tests Possible (@ $90k per test), o Source Categories With Greatest Likelihood Of Emitting 2378-TCDD Identified. o Source Categories Ranked By Groups {See Page 4). o Plan To Test Three Sources In Each High P rio rity Source Category, o Samples To Be Collected And Analyzed (See Page 5). Ash Sampling Program o Ash Data Of Limited Usefulness, o Only A Qualitative Tool. o Ash Data Will Be Collected To Help Refine P rio rity L ist, o Source Categories To Be Tested Via Ash (See Page 6). Ambient A ir Study o Collect Ambient A ir Samples Downwind From One Site Where 2378-TCDD Was Found In Stack Emissions, o Four-Six Monitors For One-Two Months, o Study Planned For Summer 1985. 3 Ranked Source Category List Rank A Source Categories: Sewage Sludge Incinerators Black Liquor Boilers Commercial Boilers F irin g Fuels Contaminated with Chlorinated Organic Wastes Rank B Source Categories: PCP Sludge Incinerators Carbon Regeneration (indu strial) Charcoal Manufacturing Wire Reclamation Rank C Source Categories: Wood Stoves Boilers (Firing PCP treated Wood) Mobile Sources Small Spreader-Stoker Coal Boiler Hazardous Waste Incinerators Lime/Cement Kilns Co-fired with Chlorinated Organic Wastes Rank D Source Categories: Municipal Solid Waste (MSW) Incineration Industrial Boilers C o-firing Wastes Rank A: Large source categories (greater than 1 m illion tons of fuel and/or waste burned annually) with elevated dioxin precursor contamination of feed/fuel. These categories are judged to have the highest potential to emit TCDD. Rank B: Small source categories (le ss than 1 m illion tons of fuel and/or waste burned annually) or source categories with limited dioxin precursor contamination of feed/fuel. These categories have a high potential to emit TCDD. Rank C: Source categories less lik e ly to emit TCDD. Rank D: Source categories which have already been tested three or more times. Sampling And Analyses Model Sample Me thod Samples A n a ly se s T o tal Samples* for A nalysis In p u ts Frecombuatlon A ir Peed/Fuel Outputs Stack (before control) Stack (afte r control) Bottom Ash Aah Prom C o n tro l Device Quench Water E fflu e n t Other S o lis (In v ic in ity ) XAlb-2 (P U P P )b 0 - l c Crabs B a l l y Compost te 2J78-TCDD, PCD D fl, T0CL, C l-ph e n o ls, Cl-benzenes PCnO S ca n , C l- p h e n o ls C l-b e n z e n e s, PCB, TOOL 1 3f HH5T8 HH5T Crabs Crabs Crabs B o rin g s 2 trains -Back It* If D a lly Composite -condenser Ulnae -adsorbent Resin -F ro n t H alf D o lly Composite -cyclone Catch -filte r -probe rinse 2 trains -Back H alf D a lly Composite -condenser Rinse -sdsorhent Resin -P ro n t H alf D a lly Composite - f ilt e r Catch -probe Rinse Dal ly Compost te D a lly Composite D a lly ComposIte 2370-TCDD, M onologuesb ( te tra - o c t a ) , PCDD 2370-TCDD, Homologues ( t e t r a - o c t a ) , PCDD 2370-TCDD, Homologues ( t e t r a - o c t a ) , PCDD 23 70-TCDD, ttoaologucs ( t e t r a - o c t a ) , PCDD 2370-TCDD, Homologuea ( t e t r a - o c t a ) , PCDD & 6 3 3 3 1 Composite 2370-TCDD, Homologuea ( t e t r a - o c t a ) , PCDD 1 Total 26* b XAI>-2 ( N IF F ) d e n o te s a m o d ifie d h ig h volume a i r sam pler w ith a s p e c ia l sa m p lin g head f o r am bient o r g a n ic compounds. c Sample to be c o lle c te d I f there Is a s i g n i f i c a n t source o f suspected p r e c u r so r s In v i c i n i t y o f s s n p lln g s i t e . d rCOD - P o ly c h lo rin a te d dlbenzo d io x in . *TOCL - T otal organic c h lo rin e , fA n a ly s is by co n tra c to r. RHMST I s n nod I fle d P.PA "Method 5 * t r a in ns d e fin e d In the ASUK p r o t o c o l. hfooaloguea - A n alyse s done on h igh e r (t e t r n through o c t s ) PC D D 's as a to t a l fo r each group o n ly . ^ M u ltip le a n a ly se s fo r each sample w ill have s m u lt ip lie r e ffe c t on the a n a ly t ic a l co sta a ls o . T o ta l does not Include q u a lity assurance samples (approx. 201). Combustion Source Categories Where Ash Samples Will Likely Be Collected Source Categories:* Chemical Sludge Incinerators Carbon Regeneration Unit (at industrial source) Charcoal Manufacturing Wire Reclamation Wood Stoves Wood Boilers Burning PCP Treated Wood Spreader-Stoker Coal Boiler Hazardous Waste Incineration Lime/Cement Kiln Burning Hazardous Wastes Forest Fires Apartment House Flue Fed Incinerators Agricultural Burning *To be supplemented by other categories identifed by State and Regional O ffic ia ls with reasonable likelihood of emitting 2378-TCDD. 6 Primary Alternatives Considered And Rejected 1. Focus Tier 4 Prim arily On Municipal Waste Incinerators. Rejected: (a) On A Relative Basis, This Source Category Has Been Fairly Well Tested. (b) Other Agencies Are Planning Tests Of Municipal Incinerators (New York State). (c) Uncertain If Other Source Categories Are More Important; Will Not Know Unless Tested. 2. Investigate Conditions That Increase/Decrease 2378-TCDD Emissions. Rejected: This Alternative Was Rejected, Primarily Since Other Agencies (e.g., Canada, ASME) Have Related Work Planned. 3. Analyze Samples For Furans. Rejected: (a) Limited Laboratory Resource Allocation. (b) ORD Indicates Technical Limitations With Furan Analysis. (c) Duplicate Samples Will Be Collected For Future Analysis. 7 4 ' *> Other Issues 1. Schedule I t is probable that Tier 4 may not be fu lly completed by December 1985. Key factors which may greatly influence the time needed to complete the study are (1) the time required to gain access to site s for testing and (2) the turnaround time needed by the TROIKA until samples are analyzed and results released. 2. Level Of TROIKA Support For Tier 4 For planning purposes, Tier 4 was allocated 700 of the approximate 3600 analyses to be performed by the TROIKA. This "planning" estimate was to be revised based upon the laboratory needs set forth in the Work Plan. A revised allocation should be determined shortly. 3. A va ila b ility Of Sampling And Analytical Protocols Sampling and analyses under Tier 4 are to follow procedures specified by ORD. A sampling protocol (EPA/ASME) has been under development, and a preliminary draft is available. However, a final document is not yet available. Sim ilarly, laboratory procedures for Tier 4 samples have not been documented. While the lack of these documents has not delayed Tier 4 to date, they w ill be needed soon. 4. Testing "Worst" Case Or "Typical" Sources An issue not fu lly resolved is whether we should focus our test program on sources which represent either the "worst" case or more "typ ica l" situation. Since three sources are to be tested in each category, an alternative would be to test some worst case and some typical sources. We have asked for feedback on this issue from reviewers of the Tier 4 Work Plan. 8