Memorandum

TO: Portland Cement NESHAP Docket

From Keith Barnett, US EPA

Subject: ACI and Dioxin E m issions

DATE: August 3, 2010

One commented claimed that the application of ACI to a cement kiln could result in an increase
in dioxin emissions. In order to ascertain the accuracy of this statement, I contacted EPA experts on this matter.

One of the sources where the commenter claimed this occurred was municipal waste incinerators. I spoke with Wa lt Stevenson, the project lead in the air emission rules for municipal incinerators. Walt indicated that he was unaware that anyone had found that ACI
increased dioxin emissions. The data he had collected showed that applying ACI red uced
dioxin emission s by 75 percent.

I also contacted Nick Hutson of the Office or research and development. His response is
attached.From: Nick Hutson/RTP/USEPA/US
To: RobertJ Wayland/RTP/USEPA/US@EPA Cc: Brian Shrager/RTP/USEPA/US@EPA, Keith Barnett/RTP/USEPA/US@EPA, Walt Stevenson/RTP/USEPA/US@EPA
Date: 08/03/2010 08:48 AM Subject: Re: Fw: Comment we need help on

Keith

- do you have these references (i.e., the citation)? I find this hard to believe. Activated carbon injection is implemented TO MITIGATE dioxin/furan emissions. See also excerpts from some papers (including one of mine) examining dioxin emissions w ith ACI.

Nick

This is the industry comment Nick was responding to:

It was reported by Chang and Lin that the total dioxin/furan concentrations exiting a municipal incinerator were 2.4 times higher than the input level when implementing ACI. This phenomenon was also reported by Schreiber for cement plants burning
hazardous waste.

Conclusions The collected fly ashes of the fabric filters [after ACI] possessed the highest PCDD/F TEQ distribution (92.7%) in the MSWIs , while BA had the highest PBDD/F an d PBDE distributions (92.2

– 97.3%). Only 0.547

– 5.97% of the total PCDD/Fs, PBDD/Fs and PBDEs emitted from the stack flue gases. Owing to the PBDD/Fs and PBDEs in the feeding waste may not be completely destroyed, the type of the feeding waste is an influent ial factor affecting the PBDD/F characteristics in BA, as well as PBDE characteristics in BA, fly ashes and flue gases. The PBDE concentrations/contents in the stack flue gases (26.1

– 109 ng/Nm3) and in the BA (20.4

– 186 ng/g) of the MSWIs could

reach three orders higher than those in the atmosphere and reference soils. Consequently, MSWIs could contribute PBDEs to the environment through the stack flue gases or the reutilization of BA. Further study are needed including preventing high PBDE

- contained wastes into incinerators, and reducing PBDE and PBDD/F leaching through reutilization of BA. Furthermore, decreasing de novo syntheses among the economizers, and increasing the removal efficiencies of APCDs are also crucial for abating PCDD/F, PBDD/F and PBDE e missions from the stack flue gases of MSWIs.Abstract The effect of the injection of brominated powdered activated carbon (Br

- PAC) on the emission
of brominated and chlorinated dioxins and furans in coal combustion fl ue gas has been evaluated. The sampling campaigns were performed at two U.S. Department of Energy (DOE)

demonstration sites where brominated PAC was being injected for control of mercury emissions. The results of the sampling campaigns showed that injectio n of the brominated PAC upstream of the electrostatic precipitator (ESP) did not increase the emissions of total and Toxic EQuivalent (TEQ) chlorinated and brominated dioxin compounds. Rather, the data suggested the sorbent may capture these compounds and reduce their concentration in the flue gas stream. This effect, when seen, was small, and independent of the type of plant emission controls, temperature at the point of injection, or fuel

- chlorine
content. The addition of the brominated PAC sorbent result ed in slight increases the total content of chlorinated dioxins and furan in the particulate matter (ash) collected in the ESP, but did not increase its overall toxicity.

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