Memorandum

TO: Portland Cement NESHAP Docket

From Keith Barnett, US EPA

Subject: ACI and Dioxin Emissions

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 Walt 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 reduced 

dioxin emissions 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 with 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 and 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 influential 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 emissions 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 flue 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 injection 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 resulted 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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