Coalition for Responsible Waste Incineration

Document Control Office (7407)
Office of Pollution Prevention and Toxics
Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Ariel Rios Building
Washington, DC 20460

Docket Control Number OEI-100000

The Coalition for Responsible Waste Incineration (CRWI) is pleased to submit comments on the Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic Chemicals within the Dioxin and Dioxin-like Compounds Category. CRWI represents ten companies that operate hazardous waste combustion units and eight other companies with interests in hazardous waste combustion. These companies account for a significant portion of the U.S. capacity for hazardous waste combustion. In addition, CRWI is advised by a number of academic members with research interests in hazardous waste combustion. Since its inception, CRWI has encouraged its members to reduce the generation of hazardous waste. However, for certain hazardous waste streams, CRWI believes that combustion is a safe and effective method of treatment, reducing both the volume and toxicity of the waste treated. CRWI seeks to help its member companies both to improve their operations and to provide lawmakers and regulators helpful data and comments.

CRWI would like to comment on four areas of the guidance document.

1. Example 2 in Section 1.5 (p. 8) is somewhat confusing. CRWI believes that if dioxin and dioxin-like compounds are in the waste when it is received by the waste management facility, it should be reported by the generator, not the waste handling facility. Reporting by both entities would result in double counting of the same materials. CRWI suggests that this example be revised to make it clear which entity is required to report these emissions.
2. The general guidance (Section 2.1, p 11) suggests that any of the three methods for estimating annual releases of dioxin and dioxin-like compounds can be used. EPA makes the statement that they consider the three approaches to be hierarchical but leaves the final determination of which method to use to the facility. CRWI suggests that the Agency make it clear which method of reporting is required if, for example, a facility is in the position to use any of the three methods. While this may seem like a strange request, the public attention that any TRI reporting of dioxin will be given makes it important for all facilities to have a clear picture of what will be required.
3. CRWI supports the use of "non-detects" as zero as defined in Section 2.2 (p. 14).

4. CRWI has three concerns pertaining to the default emission factors for cement kilns and incinerators burning hazardous waste.
   1. CRWI suggests that the default emission factors are too high for both cement kilns and incinerators burning hazardous waste. It appears that these emission factors are based on data that were collected many years ago. Since that time, cement kilns and incinerator operators have greatly reduced any dioxin emissions. For example, CRWI was able to obtain data from one incinerator to check this default (Due to the short comment period, additional data could not be obtained. However, CRWI will attempt to provide additional data in the next several weeks). Using the average of four runs during a recent trial burn, the emission factor for this facility was 0.8 ng/kg feed. This is a factor of 100 below the default value. In addition, trial burn results are expected to be higher than under normal operations. Therefore, CRWI suggests that the default values, if included in the final guidance, be updated to reflect current data from cement kilns and incinerators.
   2. CRWI believes that feed rate is the only one of the ways to develop an emission factor for incinerators. Since most hazardous waste incinerators will be required to meet a concentration based standard, an alternative might be gas flow rates. There may be other factors that should be considered. CRWI suggests that the Agency make it clear that alternative emission factors are allowed for all reporting categories.

   3. While it is clear that the Agency used 17 cement kilns to determine the default emission factor, it is not clear how many incinerator units were used to determine their default emission factor. In addition, the agency goes through a description of four different types of incinerators and then proposes a single default emission factor. It seems pointless to describe the different types of incinerators and then use a single default factor. There are many other factors for both cement kilns and incinerators that impact dioxin emissions. Yet none of these are included in the discussion. CRWI suggests that the Agency clarify what data were used for both cement kilns and incinerators burning hazardous waste to determine the default emission factors.

Sincerely yours,

Melvin E. Keener, Ph.D.
Executive Director

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