DRAFT EPA/600/R-11/005A

DO NOT CITE OR QUOTE January 2013

External Review Draft

Update to

An Inventory of Sources and Environmental Releases of 

Dioxin-Like Compounds in the United States for the Years 

1987, 1995, and 2000 

NOTICE

THIS DOCUMENT IS AN EXTERNAL REVIEW DRAFT. It has not been formally released 

by the U.S. Environmental Protection Agency and should not at this stage be construed to 

represent Agency Policy. It is being circulated for comment on its technical accuracy and policy 

implications.

National Center for Environmental Assessment

Office of Research and Development

U.S. Environmental Protection Agency

Washington, DC 20460
This document is a draft for review purposes only and does not constitute Agency policy.

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DISCLAIMER

This document is distributed solely for the purpose of pre-dissemination peer review 

under applicable information quality guidelines. It has not been formally disseminated by EPA.

It does not represent and should not be construed to represent any Agency determination or 

policy. Mention of trade names or commercial products does not constitute endorsement or 

recommendation for use.

ABSTRACT

The purpose of this document is to present an update and revision to the dioxin source 

inventory published in 2006 (U.S. EPA, 2006), which is an inventory of sources and 

environmental releases of dioxin-like compounds in the United States. The current document 

presents updated estimates of environmental releases of dioxin-like compounds to the air, water, 

land and products. The sources are grouped into five broad categories: combustion sources, 

metals smelting/refining, chemical manufacturing, natural sources, and environmental reservoirs. 

Estimates of annual releases to land, air, and water are presented for reference years 1987, 1995, 

and 2000 (the years presented in the original report). The quantitative results are expressed in 

terms of the toxicity equivalence (TEQ) of the mixture of polychlorinated dibenzo-p-dioxin 

(CDD) and polychlorinated dibenzofuran (CDF) compounds present in environmental releases 

using a procedure sanctioned by the World Health Organization (WHO) in 1998. This TEQ 

procedure translates the complex mixture of CDDs and CDFs characteristic of environmental 

releases into an equivalent toxicity concentration of 2,3,7,8-tetrachorodibenzo-p-dioxin (2,3,7,8-

TCDD), the most toxic member of this class of compounds. The total releases under the national 

inventory for 1987 in g WHO98 TEQDF were 15,000 to air, 2,400 to land, 360 to water, and 36 to 

products. For 1995, the releases in g WHO98 TEQDF were 3,400 to air, 2,500 to land, 30 to 

water, and 47 to products. For 2000, the releases in g WHO98 TEQDF were 2,300 to air, 2,300 to 

land, 28 to water, and 7 to products. While the overall decreasing trend in emissions seen in the 

original report continues, the individual dioxin releases in this draft updated report are generally 

higher than the values reported in 2006. This is largely due to the inclusion (in all three years) of 

additional sources in the quantitative inventory that were not included in the 2006 report.
This document is a draft for review purposes only and does not constitute Agency policy.

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CONTENTS

LIST OF TABLES ........................................................................................................................ xv

LIST OF FIGURES .................................................................................................................... xvii 

LIST OF ABBREVIATIONS AND ACRONYMS .................................................................. xviii

PREFACE .................................................................................................................................... xxi 

AUTHORS, CONTRIBUTORS, AND REVIEWERS .............................................................. xxii 

EXECUTIVE SUMMARY ....................................................................................................... xxiii

1. BACKGROUND, APPROACH, AND CONCLUSIONS ................................................... 1-1 

1.1. BACKGROUND .......................................................................................................... 1-1

1.1.1. Dioxin-Like Compounds ................................................................................ 1-1

1.1.2. Toxicity Equivalence Factors ........................................................................ 1-2

1.1.3. Regulatory Summary ..................................................................................... 1-5

1.1.4. Information Sources ....................................................................................... 1-5

1.2. APPROACH ................................................................................................................ 1-6

1.2.1. Reference Years ............................................................................................. 1-7

1.2.2. Release Types ................................................................................................ 1-7

1.2.3. Source Classes ............................................................................................... 1-8

1.2.4. Quantitative Method for Inventory of Sources .............................................. 1-9

1.2.5. Uncertainties ................................................................................................ 1-12

1.3. SUMMARY AND CONCLUSIONS ........................................................................ 1-15

1.3.1. Contemporary Formation Sources ............................................................... 1-16

1.3.2. Reservoir Sources ........................................................................................ 1-17

1.3.3. Time Trends ................................................................................................. 1-17

1.3.4. Sources Not Included in the Inventory ........................................................ 1-20

1.3.5. Congener Profiles of CDD/CDF Sources .................................................... 1-20

1.3.6. Uncertainty Analysis .................................................................................... 1-20

1.3.6.1. Air Releases .................................................................................. 1-21

 1.3.6.2. Land Releases ............................................................................... 1-24

1.3.7. Relative Impact of Releases ......................................................................... 1-24 

2. MECHANISMS OF FORMATION OF DIOXIN-LIKE COMPOUNDS DURING 

COMBUSTION OF ORGANIC MATERIALS ................................................................... 2-1 

3. COMBUSTION SOURCES OF CDDs/CDFs: WASTE INCINERATION ........................ 3-1 

3.1. MUNICIPAL WASTE COMBUSTION .................................................................... 3-1 

3.1.1. Air Releases .................................................................................................. 3-1 

3.1.2. Water Releases .............................................................................................. 3-2 

3.1.3. Solid Residue Releases ................................................................................. 3-2 

3.1.4. Products ........................................................................................................ 3-5 

3.1.5. Release Summary ......................................................................................... 3-5 

3.2. HAZARDOUS WASTE INCINERATION ................................................................ 3-6 
This document is a draft for review purposes only and does not constitute Agency policy.

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CONTENTS (continued)

3.2.1. Dedicated HWIs ............................................................................................ 3-7 

3.2.1.1. Air Releases ................................................................................... 3-7

3.2.1.2. Water Releases ............................................................................... 3-8 

3.2.1.3. Solid Residue Releases .................................................................. 3-8 

3.2.1.4. Products―None ............................................................................. 3-8 

3.2.1.5. Release Summary .......................................................................... 3-9 

3.2.2. Industrial Boilers and Furnaces Burning Hazardous Waste ....................... 3-10 

3.2.2.1. Air Releases ................................................................................. 3-10 

3.2.2.2. Water Releases ............................................................................. 3-10 

3.2.2.3. Solid Residue Releases ................................................................ 3-10 

3.2.2.4. Products―None ........................................................................... 3-10 

3.2.2.5. Release Summary ........................................................................ 3-10 

3.2.3. Halogen Acid Furnaces Burning Hazardous Waste.................................... 3-12 

3.2.3.1. Air Releases ................................................................................. 3-12 

3.2.3.2. Water Releases ............................................................................. 3-12 

3.2.3.3. Solid Residue Releases ................................................................ 3-12 

3.2.3.4. Products―None ........................................................................... 3-12 

3.2.3.5. Release Summary ........................................................................ 3-12 

3.3. MEDICAL WASTE INCINERATION .................................................................... 3-13 

3.3.1. Air Releases ................................................................................................ 3-13 

3.3.2. Water Releases ............................................................................................ 3-14 

3.3.3. Solid Residue Releases ............................................................................... 3-14 

3.3.4. Products―None .......................................................................................... 3-15 

3.3.5. Release Summary ....................................................................................... 3-15 

3.4. CREMATORIA......................................................................................................... 3-16 

3.4.1. Human Crematoria ...................................................................................... 3-16 

3.4.1.1. Air Releases ................................................................................. 3-16 

3.4.1.2. Water Releases ............................................................................. 3-17 

3.4.1.3. Solid Residue Releases ................................................................ 3-17 

3.4.1.4. Products―None ........................................................................... 3-17 

3.4.1.5. Release Summary ........................................................................ 3-17 

3.4.2. Animal Crematoria ..................................................................................... 3-20 

3.4.2.1. Air Releases ................................................................................. 3-20 

3.4.2.2. Water Releases―None ................................................................ 3-20 

3.4.2.3. Solid Residue Releases ................................................................ 3-20 

3.4.2.4. Products―None ........................................................................... 3-21 

3.4.2.5. Release Summary ........................................................................ 3-21 

3.5. SEWAGE SLUDGE INCINERATION .................................................................... 3-23 

3.5.1. Air Releases ................................................................................................ 3-23 

3.5.2. Water Releases ............................................................................................ 3-23 

3.5.3. Solid Residue Releases ............................................................................... 3-23 

3.5.4. Products―None .......................................................................................... 3-24 

3.5.5. Release Summary ....................................................................................... 3-25 
This document is a draft for review purposes only and does not constitute Agency policy.

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CONTENTS (continued)

3.6. TIRE COMBUSTION ............................................................................................... 3-26 

3.6.1. Air Releases ................................................................................................ 3-26

3.6.2. Water Releases ............................................................................................ 3-26 

3.6.3. Solid Residue Releases ............................................................................... 3-26 

3.6.4. Products―None .......................................................................................... 3-27 

3.6.5. Release Summary ....................................................................................... 3-27 

3.7. COMBUSTION OF WASTEWATER SLUDGE AT BLEACHED 

CHEMICAL PULP MILLS ...................................................................................... 3-28 

3.8. BIOGAS COMBUSTION ......................................................................................... 3-29 

4. COMBUSTION SOURCES OF CDDs/CDFs: POWER/ENERGY GENERATION ......... 4-1 

4.1. MOTOR VEHICLE FUEL COMBUSTION .............................................................. 4-1 

4.1.1. Air Literature ................................................................................................ 4-1 

4.1.2. Air Emission Factor ...................................................................................... 4-3 

4.1.2.1. Leaded Gasoline ............................................................................ 4-3 

4.1.2.2. Unleaded Gasoline ......................................................................... 4-4 

4.1.2.3. Diesel Fuel ..................................................................................... 4-5 

4.1.3. Air Activity Level ......................................................................................... 4-7 

4.1.3.1. Gasoline ......................................................................................... 4-7 

4.1.3.2. Diesel ............................................................................................. 4-8 

4.1.4. Air Releases .................................................................................................. 4-8 

4.1.5. Water Releases—None ................................................................................. 4-8 

4.1.6. Solid Residue Releases ................................................................................. 4-8 

4.1.7. Products—None ............................................................................................ 4-8 

4.1.8. Release Summary .......................................................................................... 4-9 

4.2. WOOD COMBUSTION ........................................................................................... 4-11 

4.2.1. Residential Wood Combustion ................................................................... 4-11 

4.2.1.1. Air Releases from Indoor Residential Wood Burners ................. 4-12 

4.2.1.2. Air Releases from Residential Outdoor Wood-Fired Boilers ...... 4-13 

4.2.1.3. Water Releases—None ................................................................ 4-14 

4.2.1.4. Solid Residues from All Residential Wood Burning ................... 4-15 

4.2.1.5. Solid Residue Emission Factor .................................................... 4-15 

4.2.1.6. Solid Residue Activity Level ....................................................... 4-15 

4.2.1.7. Solid Residue Releases ................................................................ 4-16 

4.2.1.8. Release Summary ........................................................................ 4-16 

4.2.2. Industrial Wood Combustion ...................................................................... 4-18 

4.2.2.1. Air Releases ................................................................................. 4-18 

4.2.2.2. Water Literature—None .............................................................. 4-19 

4.2.2.3. Solid Residue Releases ................................................................ 4-19 

4.2.2.4. Release Summary ........................................................................ 4-20 

4.3. OIL COMBUSTION ................................................................................................. 4-22
This document is a draft for review purposes only and does not constitute Agency policy.

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CONTENTS (continued)

4.3.1. Institutional/Commercial and Residential Oil Combustion ........................ 4-22 

4.3.1.1. Air Releases ................................................................................. 4-22 

4.3.1.2. Water Releases—None ................................................................ 4-23 

4.3.1.3. Solid Residue Releases—None ................................................... 4-23 

4.3.1.4. Products—None ........................................................................... 4-23 

4.3.1.5. Release Summary ........................................................................ 4-23 

4.3.2. Utility Sector and Industrial Oil Combustion ............................................. 4-24 

4.3.2.1. Air Literature ............................................................................... 4-25 

4.3.2.2. Air Emission Factor ..................................................................... 4-25 

4.3.2.3. Activity Level .............................................................................. 4-25 

4.3.2.4. Air Releases ................................................................................. 4-26 

4.3.2.5. Water Releases—None ................................................................ 4-26 

4.3.2.6. Solid Residue Releases—None ................................................... 4-26 

4.3.2.7. Products—None ........................................................................... 4-26 

4.3.2.8. Release Summary ........................................................................ 4-26 

4.3.3. Waste Oil Combustion ................................................................................ 4-27 

4.3.3.1. Air Literature ............................................................................... 4-28 

4.3.3.2. Air Emission Factor ..................................................................... 4-28 

4.3.3.3. Activity Level .............................................................................. 4-29 

4.3.3.4. Air Releases ................................................................................. 4-29 

4.3.3.5. Water Releases – None ................................................................ 4-29 

4.3.3.6. Solid Residue Releases – None. .................................................. 4-29 

4.3.3.7. Products – None. .......................................................................... 4-29 

4.3.3.8. Release Summary ........................................................................ 4-29 

4.4. COAL COMBUSTION ............................................................................................. 4-30 

4.4.1. Coal-Fired Power Plants ............................................................................. 4-30 

4.4.1.1. Air Releases................................................................................. 4-31 

4.4.1.2. Water Releases ............................................................................. 4-32 

4.4.1.3. Solid Residue Releases ................................................................ 4-32 

4.4.1.4. Product Literature—None ............................................................ 4-33 

4.4.1.5. Release Summary ........................................................................ 4-33 

4.4.2. Coal-Fired Industrial Boilers ...................................................................... 4-35 

4.4.2.1. Air Releases ................................................................................. 4-35 

4.4.2.2. Water Literature ........................................................................... 4-36 

4.4.2.3. Solid Residue Releases ................................................................ 4-36 

4.4.2.4. Release Summary ........................................................................ 4-36 

4.4.3. Residential Coal Combustion ..................................................................... 4-37 

4.4.3.1. Air Releases ................................................................................. 4-37 

4.4.3.2. Water Releases—None ................................................................ 4-38 

4.4.3.3. Solid Residue Releases ................................................................ 4-38 

4.4.3.4. Products—None ........................................................................... 4-39 

4.4.3.5. Release Summary ........................................................................ 4-39
This document is a draft for review purposes only and does not constitute Agency policy.

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CONTENTS (continued)

5. COMBUSTION SOURCES OF CDDs/CDFs: OTHER HIGH-TEMPERATURE 

SOURCES ............................................................................................................................ 5-1 

5.1. CEMENT KILNS ........................................................................................................ 5-1 

5.1.1. Air Releases .................................................................................................. 5-1 

5.1.2. Water Releases .............................................................................................. 5-2 

5.1.3. Solid Residue Releases ................................................................................. 5-3 

5.1.4. Products ........................................................................................................ 5-4 

5.1.5. Release Summary ......................................................................................... 5-4 

5.2. LIGHTWEIGHT AGGREGATE KILNS ................................................................... 5-7 

5.2.1. Air Releases .................................................................................................. 5-7 

5.2.2. Water Releases―None ................................................................................. 5-7 

5.2.3. Solid Residue Releases―None .................................................................... 5-7 

5.2.4. Product Literature―None ............................................................................. 5-7 

5.2.5. Release Summary ......................................................................................... 5-7 

5.3. ASPHALT MIXING PLANTS ................................................................................... 5-9 

5.3.1. Air Releases .................................................................................................. 5-9 

5.3.2. Water Releases .............................................................................................. 5-9 

5.3.3. Solid Residue Releases ................................................................................. 5-9 

5.3.4. Products ...................................................................................................... 5-10 

5.3.5. Release Summary ....................................................................................... 5-10 

5.4. PETROLEUM REFINING CATALYST REGENERATION PLANTS ................. 5-11 

5.4.1. Air Releases ................................................................................................ 5-11 

5.4.2. Water Releases ............................................................................................ 5-12 

5.4.3. Solid Residue Releases ............................................................................... 5-12 

5.4.4. Product Literature ....................................................................................... 5-12 

5.4.5. Release Summary ....................................................................................... 5-12 

5.5. CIGARETTE SMOKING ......................................................................................... 5-13 

5.5.1. Air Releases ................................................................................................ 5-13 

5.5.2. Water Releases―None ............................................................................... 5-13 

5.5.3. Solid Residue Releases............................................................................... 5-14 

5.5.4. Products―None .......................................................................................... 5-14 

5.5.5. Release Summary ....................................................................................... 5-14 

5.6. PYROLYSIS OF BROMINATED FLAME RETARDANTS ................................. 5-15 

5.7. CARBON REACTIVATION FURNACES .............................................................. 5-15 

5.7.1. Air Releases ................................................................................................ 5-15 

5.7.2. Water Releases―None ............................................................................... 5-16 

5.7.3. Solid Residue Releases―None .................................................................. 5-16 

5.7.4. Products ...................................................................................................... 5-16 

5.7.5. Release Summary ....................................................................................... 5-16 

5.8. KRAFT BLACK LIQUOR RECOVERY BOILERS ............................................... 5-17 

5.8.1. Air Releases ................................................................................................ 5-17 

5.8.2. Water Releases―None ............................................................................... 5-17 

5.8.3. Solid Residue Releases ............................................................................... 5-18
This document is a draft for review purposes only and does not constitute Agency policy.

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CONTENTS (continued)

5.8.4. Products ...................................................................................................... 5-18 

5.8.5. Release Summary ....................................................................................... 5-18 

5.9. LIME KILNS ............................................................................................................ 5-19 

5.9.1. Process Description ..................................................................................... 5-19 

5.9.2. Regulations ................................................................................................. 5-20 

5.9.3. Air Releases ................................................................................................ 5-20 

5.9.4. Water Releases ............................................................................................ 5-21 

5.9.5. Solid Residue Releases ............................................................................... 5-21 

5.9.6. Products ...................................................................................................... 5-21 

5.9.7. Release Summary ....................................................................................... 5-21 

5.10. GLASS MANUFACTURING .................................................................................. 5-22 

5.11. OTHER IDENTIFIED SOURCES ........................................................................... 5-24 

6. COMBUSTION SOURCES OF CDDs/CDFs MINIMALLY CONTROLLED AND 

UNCONTROLLED COMBUSTION SOURCES ............................................................... 6-1 

6.1. COMBUSTION OF LANDFILL GAS ....................................................................... 6-1 

6.1.1. Air Releases .................................................................................................. 6-1 

6.1.2. Water Releases .............................................................................................. 6-1 

6.1.3. Solid Residue Releases―None .................................................................... 6-1 

6.1.4. Products―None ............................................................................................ 6-1 

6.1.5. Release Summary ......................................................................................... 6-1 

6.2. ACCIDENTAL FIRES................................................................................................ 6-3 

6.2.1. Structural Fires .............................................................................................. 6-3 

6.2.1.1. Air Releases ................................................................................... 6-3 

6.2.1.2. Water Releases ............................................................................... 6-4 

6.2.1.3. Solid Residue Releases .................................................................. 6-4 

6.2.1.4. Products―None ............................................................................. 6-4 

6.2.1.5. Release Summary .......................................................................... 6-4 

6.2.2. Vehicle Fires ................................................................................................. 6-6 

6.2.2.1. Air Releases ................................................................................... 6-6 

6.2.2.2. Water Releases............................................................................... 6-7 

6.2.2.3. Solid Residue Releases .................................................................. 6-7 

6.2.2.4. Products―None ............................................................................. 6-8 

6.2.2.5. Release Summary .......................................................................... 6-8 

6.3. LANDFILL FIRES.................................................................................................... 6-11 

6.3.1. Air Releases ................................................................................................ 6-11 

6.3.2. Water Releases―None ............................................................................... 6-13 

6.3.3. Solid Residue Releases―None .................................................................. 6-13 

6.3.4. Products―None .......................................................................................... 6-13 

6.3.5. Release Summary ....................................................................................... 6-13 

6.4. FOREST AND BRUSH FIRES ................................................................................ 6-14 

6.4.1. Air Releases ................................................................................................ 6-14 

6.4.2. Air Emission Factors .................................................................................. 6-17
This document is a draft for review purposes only and does not constitute Agency policy.

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CONTENTS (continued)

6.4.3. Air Activity Levels ..................................................................................... 6-18 

6.4.4. Water Releases ............................................................................................ 6-19 

6.4.5. Solid Residue Releases ............................................................................... 6-19 

6.4.6. Products―None .......................................................................................... 6-19 

6.4.7. Release Summary ....................................................................................... 6-19 

6.5. BACKYARD BARREL BURNING ........................................................................ 6-21 

6.5.1. Air Releases ................................................................................................ 6-21 

6.5.2. Solid Residue Releases ............................................................................... 6-23 

6.5.3. Release Summary ....................................................................................... 6-24 

6.6. RESIDENTIAL YARD WASTE BURNING ........................................................... 6-26 

6.6.1. Air Releases ................................................................................................ 6-26 

6.6.2. Water Releases―None ............................................................................... 6-27 

6.6.3. Solid Residue Releases ............................................................................... 6-27 

6.6.4. Products―None .......................................................................................... 6-27 

6.6.5. Release Summary ....................................................................................... 6-27 

6.7. LAND-CLEARING DEBRIS BURNING ................................................................ 6-28 

6.7.1. Air Releases ................................................................................................ 6-28 

6.7.2. Water Releases―None ............................................................................... 6-29 

6.7.3. Solid Residue Releases ............................................................................... 6-29 

6.7.4. Release Summary ....................................................................................... 6-29 

6.8. UNCONTROLLED COMBUSTION OF POLYCHLORINATED 

BIPHENYLS ............................................................................................................. 6-31 

6.9. VOLCANOES ........................................................................................................... 6-32 

6.10. FIREWORKS ............................................................................................................ 6-32 

6.11. OPEN BURNING AND OPEN DETONATION OF ENERGETIC 

MATERIALS ............................................................................................................ 6-32 

6.12. UNDERGROUND COAL FIRES ............................................................................ 6-33 

6.13. AGRICULTURAL BURNING ................................................................................. 6-33 

6.13.1. Air Releases ................................................................................................ 6-33 

6.13.2. Water Releases―None ............................................................................... 6-34 

6.13.3. Solid Residue Releases ............................................................................... 6-35 

6.13.4. Products―None .......................................................................................... 6-35 

6.13.5. Release Summary ....................................................................................... 6-35 

6.14. OPEN BURNING DEMOLITION/CONSTRUCTION WOOD .............................. 6-36 

6.14.1. Air Releases ................................................................................................ 6-36 

6.14.2. Water Releases―None ............................................................................... 6-37 

6.14.3. Solid Residue Releases ............................................................................... 6-37 

6.14.4. Release Summary ....................................................................................... 6-37 

6.15. OIL SPILL BURNING ............................................................................................. 6-39 

6.16. CANDLE BURNING................................................................................................ 6-40 

7. METAL SMELTING AND REFINING SOURCES OF CDD/CDFs ................................. 7-1 

7.1. PRIMARY NONFERROUS METAL SMELTING/REFINING ............................... 7-1
This document is a draft for review purposes only and does not constitute Agency policy.

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CONTENTS (continued)

7.1.1. Primary Copper Smelting and Refining ........................................................ 7-1 

7.1.1.1. Air Releases ................................................................................... 7-1 

7.1.1.2. Water Releases ............................................................................... 7-1 

7.1.1.3. Solid Residue Releases .................................................................. 7-1 

7.1.1.4. Products ......................................................................................... 7-2 

7.1.1.5. Release Summary .......................................................................... 7-2 

7.1.2. Primary Magnesium Smelting and Refining ................................................ 7-3 

7.1.2.1. Air Releases ................................................................................... 7-3 

7.1.2.2. Water Releases ............................................................................... 7-4 

7.1.2.3. Solid Residue Releases .................................................................. 7-4 

7.1.2.4. Release Summary .......................................................................... 7-4 

7.1.3. Primary Nickel Smelting and Refining ......................................................... 7-6 

7.1.3.1. Air Releases ................................................................................... 7-6 

7.1.3.2. Water Releases ............................................................................... 7-6 

7.1.3.3. Solid Residue Releases .................................................................. 7-6 

7.1.3.4. Products ......................................................................................... 7-6 

7.1.3.5. Release Summary .......................................................................... 7-6 

7.1.4. Primary Aluminum Smelting and Refining .................................................. 7-7 

7.1.5. Primary Titanium Smelting and Refining ..................................................... 7-7 

7.1.5.1. Air Releases ................................................................................... 7-8 

7.1.5.2. Water Releases ............................................................................... 7-8 

7.1.5.3. Solid Residue Releases .................................................................. 7-8 

7.1.5.4. Products ......................................................................................... 7-9 

7.1.5.5. Release Summary .......................................................................... 7-9 

7.2. SECONDARY NONFERROUS METAL SMELTING AND REFINING ............... 7-9 

7.2.1. Secondary Aluminum Smelting and Refining .............................................. 7-9 

7.2.1.1. Air Releases ................................................................................. 7-10 

7.2.1.2. Water Releases ............................................................................. 7-10 

7.2.1.3. Solid Residue Releases ................................................................ 7-10 

7.2.1.4. Products ....................................................................................... 7-10 

7.2.1.5. Releases ....................................................................................... 7-10 

7.2.2. Secondary Copper Smelting and Refining .................................................. 7-11 

7.2.2.1. Air Releases ................................................................................. 7-12 

7.2.2.2. Water Releases ............................................................................. 7-12 

7.2.2.3. Solid Residue Releases ................................................................ 7-12 

7.2.2.4. Products ....................................................................................... 7-12 

7.2.2.5. Releases ....................................................................................... 7-12 

7.2.3. Secondary Lead Smelting ........................................................................... 7-14 

7.2.3.1. Air Releases ................................................................................. 7-15 

7.2.3.2. Water Releases ............................................................................. 7-15 

7.2.3.3. Solid Residue Releases ................................................................ 7-15 

7.2.3.4. Products ....................................................................................... 7-15 

7.2.3.5. Releases ....................................................................................... 7-15
This document is a draft for review purposes only and does not constitute Agency policy.

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CONTENTS (continued)

7.2.4. Secondary Zinc Production ......................................................................... 7-18 

7.2.4.1. Air Releases ................................................................................. 7-18 

7.2.4.2. Water Releases ............................................................................. 7-19 

7.2.4.3. Solid Residue Releases ................................................................ 7-19 

7.2.4.4. Products ....................................................................................... 7-19 

7.2.4.5. Releases ....................................................................................... 7-19 

7.3. PRIMARY FERROUS METAL SMELTING/REFINING ...................................... 7-20 

7.3.1. Sinter Production ........................................................................................ 7-20 

7.3.1.1. Air Releases ................................................................................. 7-20 

7.3.1.2. Water Releases ............................................................................. 7-21 

7.3.1.3. Solid Residue Releases ................................................................ 7-21 

7.3.1.4. Products ....................................................................................... 7-21 

7.3.1.5. Releases ....................................................................................... 7-21 

7.3.2. Coke Production ......................................................................................... 7-22 

7.3.2.1. Air Releases ................................................................................. 7-23 

7.3.2.2. Water Releases ............................................................................. 7-23 

7.3.2.3. Solid Residue Releases ................................................................ 7-23 

7.3.2.4. Products ....................................................................................... 7-23 

7.3.2.5. Release Summary ........................................................................ 7-24 

7.4. SECONDARY FERROUS METAL SMELTING/REFINING ................................ 7-25 

7.4.1. Air Releases ................................................................................................ 7-25 

7.4.2. Water Releases ............................................................................................ 7-25 

7.4.3. Solid Residue Releases ............................................................................... 7-25 

7.4.4. Products ...................................................................................................... 7-25 

7.4.5. Release Summary ....................................................................................... 7-25 

7.5. FERROUS FOUNDRIES ......................................................................................... 7-27 

7.5.1. Air Releases ................................................................................................ 7-27 

7.5.2. Water Releases ............................................................................................ 7-27 

7.5.3. Solid Residue Releases............................................................................... 7-27 

7.5.4. Products ...................................................................................................... 7-28 

7.5.5. Release Summary ....................................................................................... 7-28 

7.6. NONFERROUS METAL FOUNDRIES .................................................................. 7-29 

7.6.1. Aluminum Foundries .................................................................................. 7-29 

7.6.2. Copper Foundries ........................................................................................ 7-31 

7.7. SCRAP ELECTRIC WIRE RECOVERY ................................................................ 7-33 

7.7.1. Air Releases ................................................................................................ 7-33 

7.7.2. Water Releases ............................................................................................ 7-33 

7.7.3. Solid Residue Releases ............................................................................... 7-33 

7.7.4. Products ...................................................................................................... 7-33 

7.7.5. Release Summary ....................................................................................... 7-34 

7.8. DRUM AND BARREL RECLAMATION FURNACES ........................................ 7-35 

7.8.1. Air Releases ................................................................................................ 7-35 

7.8.2. Water Releases ............................................................................................ 7-35
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CONTENTS (continued)

7.8.3. Solid Residue Releases ............................................................................... 7-36 

7.8.4. Products ...................................................................................................... 7-36 

7.8.5. Release Summary ....................................................................................... 7-36 

8. CHEMICAL MANUFACTURING AND PROCESSING SOURCES ............................... 8-1 

8.1. BLEACHED CHEMICAL WOOD PULP AND PAPER MILLS ............................. 8-1 

8.1.1. Air Releases .................................................................................................. 8-1 

8.1.2. Water Releases .............................................................................................. 8-1 

8.1.3. Solid Residue Releases ................................................................................. 8-1 

8.1.4. Products ........................................................................................................ 8-2 

8.1.5. Release Summary ......................................................................................... 8-2 

8.2. STAND-ALONE CHLOR-ALKALI PLANTS .......................................................... 8-4 

8.2.1. Process Description ....................................................................................... 8-5 

8.2.2. Regulations ................................................................................................... 8-6 

8.2.3. Literature ....................................................................................................... 8-6 

8.2.4. Releases ........................................................................................................ 8-7 

8.3. STAND ALONE VINYL CHLORIDE MANUFACTURING PLANTS .................. 8-8 

8.3.1. Process .......................................................................................................... 8-9 

8.3.2. Regulations ................................................................................................... 8-9 

8.3.3. Literature ....................................................................................................... 8-9 

8.3.4. Releases ...................................................................................................... 8-12 

8.4. COMPLEX CHEMICAL PLANTS PRODUCING CHLORINE AND A VARIETY 

OF CHLORINATED 

ORGANICS............................................................................................................... 8-13 

8.4.1. Chlorophenols ............................................................................................. 8-14 

8.4.1.1. Process Description ...................................................................... 8-14 

8.4.1.2. Regulations for Chlorophenols .................................................... 8-15 

8.4.1.3. Products—Chlorophenols ............................................................ 8-17 

8.4.1.4. Products—2,4 D ........................................................................... 8-20 

8.4.2. Chlorobenzenes ........................................................................................... 8-20 

8.4.2.1. Process Description ...................................................................... 8-20 

8.4.2.2. Regulations for Chlorobenzenes .................................................. 8-21 

8.4.2.3. Products—Chlorobenzenes .......................................................... 8-22 

8.4.3. Complex Plants ........................................................................................... 8-23 

8.5. MUNICIPAL WASTEWATER TREATMENT PLANTS ...................................... 8-26 

8.5.1. Air Releases ................................................................................................ 8-27 

8.5.2. Water Releases ............................................................................................ 8-27 

8.5.3. Solid Residue Releases ............................................................................... 8-27 

8.5.4. Products ...................................................................................................... 8-28 

8.5.5. Releases ...................................................................................................... 8-28 

8.6. DRINKING WATER TREATMENT PLANTS ....................................................... 8-31 

8.7. SOAPS AND DETERGENTS .................................................................................. 8-31 

8.8. TEXTILE MANUFACTURING AND DRY CLEANING ...................................... 8-31
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CONTENTS (continued)

8.9. DYES, PIGMENTS, AND PRINTING INKS .......................................................... 8-32 

8.10. OTHER ALIPHATIC CHLORINE COMPOUNDS ................................................ 8-32 

8.11. RESIDENTIAL SEPTIC SYSTEMS ........................................................................ 8-32 

8.11.1. Process Description ..................................................................................... 8-33 

8.11.2. Regulations ................................................................................................. 8-33 

8.11.3. Emission Factor .......................................................................................... 8-33 

8.11.4. Activity ....................................................................................................... 8-34 

8.11.5. Releases ...................................................................................................... 8-34 

9. NATURAL SOURCES OF CDDs/CDFs ............................................................................. 9-1 

9.1. BIOTRANSFORMATIONS ....................................................................................... 9-1 

9.1.1. Biotransformation of Chlorophenols ............................................................ 9-1 

9.1.2. Biotransformation of Higher CDDs/CDFs ................................................... 9-2 

9.1.3. Biotransformation of Animal Manure .......................................................... 9-2 

9.2. PHOTOCHEMICAL TRANSFORMATIONS ........................................................... 9-3 

9.2.1. Photolysis of PCP ......................................................................................... 9-4 

9.2.2. Photolysis of Higher CDDs/CDFs ................................................................ 9-4 

9.2.3. Photolysis in Water ....................................................................................... 9-4 

9.2.4. Photolysis on Soil Surfaces ........................................................................... 9-4 

9.2.5. Photolysis on Vegetation .............................................................................. 9-5 

9.2.6. Photolysis in Air ........................................................................................... 9-5 

9.3. CDDs/CDFs IN BALL CLAY .................................................................................... 9-5 

10. SOURCES OF DIOXIN-LIKE POLYCHLORINATED BIPHENYLS (PCBs) ............... 10-1 

10.1. GENERAL FINDINGS OF THE EMISSIONS INVENTORY ............................... 10-1 

10.2. RELEASES FROM COMMERCIAL PCB PRODUCTS ........................................ 10-2 

10.2.1. Approved PCB Disposal/Destruction Methods .......................................... 10-2 

10.2.2. Releases of In-Service PCBs ...................................................................... 10-2 

10.3. CHEMICAL MANUFACTURING AND PROCESSING SOURCES .................... 10-4 

10.4. COMBUSTION SOURCES ..................................................................................... 10-6 

10.4.1. Municipal Waste Combustion..................................................................... 10-6 

10.4.2. Industrial Wood Combustion ...................................................................... 10-8 

10.4.3. Medical Waste Incineration ........................................................................ 10-9 

10.4.4. Tire Combustion ....................................................................................... 10-10 

10.4.5. Cigarette Smoking .................................................................................... 10-11 

10.4.6. Sewage Sludge Incineration ...................................................................... 10-12 

10.4.7. Backyard Barrel Burning .......................................................................... 10-13 

10.4.8. Petroleum Refining Catalyst Regeneration ............................................... 10-15 

10.4.9. Hazardous Waste Incineration .................................................................. 10-16 

10.4.10. Power Plants ............................................................................................. 10-16 

10.4.11. Forest Fires ............................................................................................... 10-17 

10.5. METAL REFINING SOURCES............................................................................. 10-19 

10.6. NATURAL SOURCES (originally Section 10.5) ................................................... 10-23
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CONTENTS (continued)

10.6.1. Biotransformation of Other PCBs ............................................................. 10-23 

10.6.2. Photochemical Transformation of Other PCBs ........................................ 10-23 

10.7. PAST USE OF COMMERCIAL PCBs (originally Section 10.6) .......................... 10-23 

11. RESERVOIR SOURCES OF CDD/CDFs AND DIOXIN-LIKE PCBs ............................ 11-1 

11.1. SOIL RESERVOIRS (originally Section 11.2.1) ..................................................... 11-2 

11.1.1. Mechanisms Responsible for Releases from Surface Soils ........................ 11-4 

11.1.2. Estimated Annual Releases from Soil to Water .......................................... 11-4 

11.1.2.1. Urban Runoff ............................................................................... 11-4 

11.1.2.2. Rural Soil Erosion ........................................................................ 11-5 

11.1.3. Estimated Annual Releases from Soil to Air .............................................. 11-5 

11.2. WATER RESERVOIRS (originally Section 11.2.2) ................................................ 11-7 

11.3. SEDIMENT RESERVOIRS (originally Section 11.2.3) .......................................... 11-8 

11.3.1. Mechanisms Responsible for Supply to and Releases from Sediment ....... 11-8 

11.3.2. Releases from Sediment to Water ............................................................... 11-8 

11.4. BIOTA RESERVOIRS (originally Section 11.2.4) .................................................. 11-8 

11.4.1. Mechanisms Responsible for Supply to and Releases from Biota ............. 11-9 

11.4.2. Approaches for Measuring and Estimating Releases from Biota ............... 11-9 

11.5. PRODUCT RESERVOIRS ....................................................................................... 11-9 

11.5.1. Bleached Chemical Wood Pulp .................................................................. 11-9 

11.5.2. Chlorophenols ........................................................................................... 11-10 

11.5.3. Vinyl Chloride Products ........................................................................... 11-11 

11.5.4. Chloranil ................................................................................................... 11-11 

11.5.5. Polychlorinated Biphenyls (PCBs) ........................................................... 11-11 

11.6. SUMMARY AND CONCLUSIONS (originally Section 11.3) ............................. 11-12 

BIBLIOGRAPHY
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LIST OF TABLES

ES-1. Overview of changes to total quantities of TEQ emissions to air and land from the 

2006 inventory. .............................................................................................................. xxiv 

ES-2. Overview of total releases to air, land, water, and products in the updated inventory. . xxvii 

ES-3. Changes in quantitative release estimates from 2006 Report to present Report ............ xxxii 

1-1. Nomenclature for dioxin-like compounds ...................................................................... 1-25 

1-2. TEF schemes for CDDs, CDFs, and PCBs ..................................................................... 1-26 

1-3. Municipal waste combustors ........................................................................................... 1-28 

1-4. Hazardous waste combustors .......................................................................................... 1-29 

1-5. Cement kilns not burning hazardous waste .................................................................... 1-30 

1-6. Secondary aluminum smelters ........................................................................................ 1-30 

1-7. Medical waste incinerators ............................................................................................. 1-31 

1-8. Pulp and paper mills ........................................................................................................ 1-31 

1-9. Commercial/Industrial solid waste incinerators .............................................................. 1-31 

1-10. Sewage sludge incinerators ............................................................................................. 1-32 

1-11. Industrial, commercial, and institutional boilers and process heaters ............................ 1-32 

1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 .................. 1-33 

1-13. Summary of PCB releases for reference years 1987, 1995, and 2000 ............................ 1-48 

1-14. Summary of CDD/CDF reservoir releases ..................................................................... 1-51 

1-15. Summary of PCB reservoir releases ............................................................................... 1-51 

1-16. Ranking of top five sources by year and media release .................................................. 1-52 

1-17. Amounts of CDDs/CDFs contained in products in year manufactured .......................... 1-52 

1-18. Trend analyses based on quantitative inventory ............................................................. 1-53 

1-19. Uncertainty analysis for top nine air sources in 2000 ..................................................... 1-54 

3-1. Inventory of municipal waste combustors in 1987 ......................................................... 3-31 

3-2. Inventory of municipal waste combustors in 1995 ......................................................... 3-39 

3-3. Inventory of municipal waste combustors in 2000 ......................................................... 3-49 

3-4. TEQ emissions from medical waste incinerators for reference year 1987, 1995, 

and 2000 .......................................................................................................................... 3-57 

5-1. CDD/CDF TEQ emission factors and emission estimates from Kraft lime kilns .......... 5-25 

6-1. CDD/CDF emission factors for forest fires .................................................................... 6-41 

6-2. Comparison of Forest Fire Data ...................................................................................... 6-43 

8-1. CDD/CDF concentrations in graphite electrode sludge from chlorine production ........ 8-36 

8-2. Releases of dioxin-like compounds in wastewater discharges from chlor-alkali 

manufacturing facilities to surface water in 2000 ........................................................... 8-37 

8-3. Congener-specific and TEQ annual releases to air from a chlor-alkali facility 

in 2000 ............................................................................................................................ 8-38 

8-4. Annual releases in 2000 from stand-alone chlor-alkali plants ........................................ 8-39 

8-5. Reported CDD/CDF concentrations in wastes from polyvinyl chloride 

manufacture ..................................................................................................................... 8-40 

8-6. CDD/CDF concentrations in products from U.S. EDC/VCM/PVC manufacturers ....... 8-41 

8-7. Annual releases in 2000 from stand-alone vinyl chloride plants .................................... 8-43 

8-8. CDD/CDF concentrations in mono-through tetrachlorophenols .................................... 8-44
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LIST OF TABLES

8-9. Summary of specific dioxin-containing wastes that must comply with land 

disposal restrictions ......................................................................................................... 8-45 

8-10. CDD/CDF concentrations (historical and current) in technical-grade 

pentachlorophenol products ............................................................................................ 8-47 

8-11. Historical CDD/CDF concentrations in pentachlorophenol-Na ..................................... 8-49 

8-12. CDD/CDF concentrations in chlorobenzenes ................................................................. 8-51 

8-13. Annual releases in 2000 from complex plants producing chlorine and a variety 

of chlorinated organics .................................................................................................... 8-52 

8-14. CDD/CDF mean concentrations measured in the 2001 National Sewage Sludge 

Survey ............................................................................................................................. 8-54 

9-1. CDD and CDF concentrations in samples of animal manure in the 

United Kingdom ............................................................................................................... 9-7 

10-1. Summary of PCB releases for reference years 1987, 1995, and 2000 .......................... 10-24 

10-2. PCB analysis for composite ash samples from barrel burning ..................................... 10-27 

11-1. Amounts of CDD/CDFs Landfilled .............................................................................. 11-13
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LIST OF FIGURES

1-1. Process inputs and outputs .............................................................................................. 1-55 

6-1. Congener profile for structure fires ................................................................................ 6-44 

6-2. Forest fire types in the United States .............................................................................. 6-45 

8-1. Congener profile for technical grade PCP ...................................................................... 8-55 

11-1. Fluxes among environmental reservoirs ....................................................................... 11-14
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LIST OF ABBREVIATIONS AND ACRONYMS

APCD Air pollution control device

BDDs polybrominated dibenzo-p-dioxins 

BDFs polybrominated dibenzofurans

Btu British thermal unit

CARB California Air Resources Board

CDD polychlorinated dibenzo-p-dioxin

CDF polychlorinated dibenzofuran

CFR Code of Federal Regulations

CKD cement kiln dust

DBF dibenzofuran

DCBz dichlorobenzene

DCI data call-in

DCP dichlorophenol

DL detection limit

dscm dry standard cubic meter

DSI dry sorbent injection

EDC ethylene dichloride

EIA Energy Information Administration

EPA U.S. Environmental Protection Agency

EPRI Electric Power Research Institute

ESP electrostatic precipitator

FF fabric filter

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

GAC granular activated carbon

GC/ECD gas chromatography/electron capture detector

GC/MS gas chromatography/mass spectrometry

HCl hydrogen chloride

HCBz hexachlorobenzene

HDD halogenated dibenzo-p-dioxin

HDF halogenated dibenzofuran

HWI hazardous waste incinerator

HxCB hexachlorobiphenyl

IUPAC International Union of Pure and Applied Chemistry 
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LOQ limit of quantitation

MB-WW mass burn waterwall

MCBz monochlorobenzene 

MMT million metric tons

MSW municipal solid waste

MT metric ton (1000 kg)

MWI medical waste incinerator

NCASI National Council of the Paper Industry for Air and Stream Improvement

Nm3 standard cubic meter

NMOC nonmethane organic compound

OAQPS Office of Air Quality Planning and Standards

OH hydroxide ion 

OPP Office of Pesticide Programs

ORD Office of Research and Development

OSW Office of Solid Waste

PCA Portland Cement Association

PCB polychlorinated biphenyl

PCP pentachlorophenol

PeCB pentachlorobiphenyl

PeCBz pentachlorobenzene

PM particulate matter

POTW publicly owned treatment works

ppb parts per billion

ppm parts per million

ppmv parts per million (volume basis)

ppt parts per trillion

PVC polyvinyl chloride

QA/QC quality assurance/quality control

RCRA Resource Conservation and Recovery Act

RDF refuse-derived fuel

SIC Standard Industrial Classification

SIP State Implementation Plan

TCBz trichlorobenzene

TCDD 2,3,7,8-tetrachlorobidenzo-p-dioxin

TCDF 2,3,.7,8-tetrachlorobidenzofuran

TeCB tetrachlorobiphenyl
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TeCP tetrachlorophenol

TEF toxicity equivalency factor

TEQ toxicity equivalence

TEQ/yr toxicity equivalents per year

TrCB trichlorobiphenyl

TrCP trichlorophenol

TRI Toxics Release Inventory

TSCA Toxic Substances Control Act

2,4-D 2,4-dichlorophenoxyacetic acid

2,4-DCP 2,4-dichlorophenol

2,4,5-T 2,4,5-trichlorophenoxy (phenoxy herbicides)

U.K. United Kingdom

USDA U.S. Department of Agriculture

VCM vinyl chloride monomer

WHO World Health Organization

WS wet scrubber
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PREFACE

In 2006, EPA released a Dioxin Inventory Report that provided a comprehensive inventory and 

overview of sources and environmental releases of dioxin-like compounds in the United States 

(U.S. EPA, 2006). The purpose of this current document is to present an update and revision to 

the 2006 dioxin source inventory. This report includes some new data and also addresses 

additional comments EPA received on the 2006 Dioxin Inventory Report after it was published.

This document was prepared by the National Center for Environmental Assessment, Office of 

Research and Development of the U.S. Environmental Protection Agency. 
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AUTHORS, CONTRIBUTORS, AND REVIEWERS

AUTHORS

John Schaum, National Center for Environmental Assessment, Office of Research and 

Development, U.S. Environmental Protection Agency, Washington, DC.

David Cleverly, National Center for Environmental Assessment, Office of Research and 

Development, U.S. Environmental Protection Agency, Washington, DC.

Matthew Lorber, National Center for Environmental Assessment, Office of Research and 

Development, U.S. Environmental Protection Agency, Washington, DC.

CONTRIBUTORS

Dwain Winters, Office of Pollution Prevention and Toxics, U.S. Environmental Protection 

Agency, Washington, DC

REVIEWERS

Linda Phillips, National Center for Environmental Assessment, Office of Research and 

Development, U.S. Environmental Protection Agency, Washington, DC.

ACKNOWLEDGMENTS

This report is derived largely from the original version published in 2006. The contributions 

from the numerous authors and reviewers of that report (see full list in U.S. EPA, 2006) are 

gratefully acknowledged. 
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EXECUTIVE SUMMARY

Synopsis

The purpose of this document is to present an update and revision to the dioxin source 

inventory published in 2006 (U.S. EPA, 2006), which is an inventory of sources and 

environmental releases of dioxin-like compounds in the United States for the years 1987, 1995, 

and 2000. The current document presents updated estimates of environmental releases of dioxinlike compounds to the air, water, land and products. These updates do not expand the scope of 

the document beyond the three reference years covered in the original document: 1987, 1995, 

and 2000. 

The sources in this report are grouped into five broad categories: combustion sources, 

metals smelting/refining, chemical manufacturing, natural sources, and environmental reservoirs. 

The quantitative results are expressed in terms of the toxicity equivalence (TEQ) of the mixture 

of polychlorinated dibenzo-p-dioxin (CDD) and polychlorinated dibenzofuran (CDF) compounds 

present in environmental releases using a procedure sanctioned by the World Health 

Organization (WHO) in 1998. This TEQ procedure translates the complex mixture of CDDs and 

CDFs in the environmental releases into a single equivalent toxicity concentration (or mass) of 

2,3,7,8-tetrachorodibenzo-p-dioxin (2,3,7,8-TCDD), the most toxic member of this class of 

compounds. 

The updated releases to land and air are presented in Table ES-1, alongside the results 

from the 2006 report. The quantitative releases to water and products did not change.

While the overall decreasing trend in emissions seen in the original report continues, the 

individual dioxin releases in this draft updated report are generally higher than the values 

reported in 2006. This is largely due to the inclusion of additional sources in the quantitative 

inventory that were not included in the 2006 report. 
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Table ES-1. Overview of changes to total quantities of TEQ emissions to air and land 

from the 2006 inventory

Description 2006 Report Present Report

Air Releases (g WHO98TEQ)

 1987 13,500 15,000

 1995 3,200 3,400

 2000 1,300 2,300

Land Releases (g WHO98 TEQ)

 1987 130 2,400

 1995 150 2,500

 2000 82 2,300

For example, air releases are higher than listed in the 2006 report because the draft 

updated report includes emissions from forest fires as well as adjustments to emission factors 

used for municipal and medical waste incinerators. Forest fires were only reported as 

preliminary in 2006, but new experimental data has resulted in more certainty in the 

development of an emission factor for this source. Hence emissions were more accurately 

quantified as compared to the preliminary estimate made in 2006 and reclassified for inclusion in 

the quantitative inventory. The quantitative releases to land are markedly higher for all years 

compared to the 2006 report, due almost entirely to including ash from backyard trash burning in 

the current draft. 

The current report still contains estimates for some sources that are considered

preliminary and not included in the quantitative inventory. Some of these sources are potentially 

large and, if confirmed, could change the trend observations based on the currently quantified 

sources, as happened with forest fires for this updated report.

Approach

Dioxin releases from a source can be in the form of products, air emissions, water

discharges, and solid residues. Solid residues can be used in products or disposed via landfills or 

incinerators. Each source addressed in this document is evaluated in terms of all of these 

outputs. However, not all of the outputs are considered to be environmental releases. Outputs 

judged to have a reasonable likelihood for releases to the circulating environment include all air 

emissions, water discharges, and landfarmed wastes. Outputs that are not generally considered 

environmental releases include waste disposal at a lined landfill and intermediate products or 
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internal waste streams. While it is recognized that some of the dioxins contained in products or 

disposed in secure landfills may be released to the circulating environment at some time in the 

future, they are less likely to be released to the circulating environment during the same year that 

they entered into commerce or were landfilled. Consequently, these contained dioxins would not 

initially be considered environmental releases. Ideally, releases derived from products and 

landfill practices of past years would be included in the inventory for the reference year in which 

the releases occur. Unfortunately, the current state of science does not support estimating when 

and to what degree such releases may occur. For informational purposes, and when sufficient 

information is available, this document provides estimates of the amounts of solid waste 

disposed in landfills.

Sources can be categorized in terms of when releases occur: (1) contemporary 

formation sources (sources that have essentially simultaneous formation and release) and (2) 

reservoir sources (materials or places that contain previously formed CDDs/CDFs or dioxin-like 

PCBs that are rereleased to the environment). The contemporary formation sources are 

discussed in Chapters 3 through 10, and the reservoir sources are discussed in Chapter 11. 

This document also classifies sources into five broad categories based mainly on their 

formation process:

• Combustion. CDDs/CDFs are formed in most types of combustion. This document 

addresses waste incineration, sources related to power/energy generation, a variety 

high temperature sources (including cement kilns, asphalt plants, carbon reactivation 

furnaces, and others) and minimally controlled or uncontrolled sources (including 

landfill gas flares/fires, forest fires, backyard trash burning in barrels, and others). 

• Metals Smelting/Refining. This category includes sources that are involved in 

metals smelting, refining, and processing. 

• Chemical Manufacturing. CDDs/CDFs can be formed as by-products in a variety 

of chemical manufacturing operations. These include chlorine-bleached wood pulp, 

chlorinated phenols (e.g., pentachlorophenol), PCBs, chlorobenzenes, phenoxy 

herbicides (e.g., 2,4-D and 2,4,5-T), and chlorinated aliphatic compounds (e.g., 

ethylene dichloride, vinyl chloride, polyvinyl chloride).

• Biological, Photochemical, and Other Natural Processes. CDDs/CDFs can form 

via biological processes such as the action of microorganisms on chlorinated phenolic 

compounds and also during photolysis of highly chlorinated phenols. 

• Reservoirs. Reservoirs are environmental compartments and materials that have the 

capacity to store previously formed CDDs/CDFs or dioxin-like PCBs. These 
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compounds are thus sequestered from the open and circulating environment. 

Potential reservoirs include soils, sediments, and biota as well as some anthropogenic 

materials, such as PCP-treated utility poles. Dioxin-like compounds in these 

reservoirs have the potential for redistribution and circulation in the environment 

through the physical processes such as leaching, volatilization, erosion, 

sedimentation, and deposition. Whenever dioxins are released from their place of 

storage back into the circulating environment, the reservoir is considered a source of 

dioxin. 

The approach used to estimate the emissions from most sources is based on an 

emission factor which relates mass of dioxins released into the environment with some measure 

of activity (e.g., kilograms of material processed per year, vehicle miles traveled per year, liters 

of wastewater discharged per year). The emission factor representing a class of facilities is 

developed by averaging the emission factors across the tested facilities in the class. This average 

emission factor is then multiplied by the measure of activity for the class to get total releases.

In this update, a revised approach has been developed to characterize the confidence 

ratings of the release estimates. The revised approach maintains the three major categories 

previously used, i.e., (1) the quantitative inventory [which now includes the sum of the previous 

confidence ratings that were subdivided into Class A, B, or C], (2) the preliminary release 

estimates [previously assigned a rating of Class D], and the unquantifiable sources [previously 

assigned a rating of Class E]. The major changes are the elimination of the Class A, B, or C 

confidence distinctions in the quantitative inventory and the addition of the quantitative 

uncertainty analysis of the quantitative inventory (presented in Section 1.3.6). The old Class A, 

B, and C confidence ratings were eliminated because they were too subjective and difficult to 

apply in a consistent fashion. Also, it was judged that confidence ratings for the individual 

source classes were less essential because a new quantitative uncertainty analysis has been added 

(see discussion below).

Key components of both the old and new schemes for classifying facilities are the criteria 

for deciding whether a source belongs in the quantitative inventory or the preliminary class. This 

update uses more specific guidance for making this decision. In order for a source to be included 

in the quantitative inventory, it must (a) have emission tests for at least two units/source types 

with sufficient documentation to directly derive emission factors, (b) the measured emission 

factors must be reasonably consistent or have understandable differences, (c) the emission factor 
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tests must represent units that are reasonably typical of the class and (d) the activity estimates 

must be based on source-specific surveys.

The actual magnitude of releases from the preliminary sources could be significantly 

lower or higher than estimated. Although EPA does not support including them in the 

quantitative inventory at this time, some of these preliminary sources have the potential of being 

major contributors of releases to the environment. Accordingly, they are important to identify 

and could be used to help set priorities for future research and data collection. As the uncertainty 

around these sources is reduced, they will be included in future inventory calculations. 

Results

Eighty source categories were identified with the potential for dioxin emissions. An 

overview of the total releases to air, land, water, and products is provided in Table ES-2. The 

major conclusions regarding CDD/CDF releases from contemporary formation sources are 

presented below: 

• The total releases under the national quantitative inventory for 1987 in g WHO98 TEQDF

were 15,000 to air, 2,400 to land, 360 to water, and 36 to products. 

• The total releases under the national quantitative inventory for 1995 in g WHO98 TEQDF

were 3,400 to air, 2,400 to land, 30 to water, and 47 to products. 

• The total releases under the national quantitative inventory for 2000 in g WHO98 TEQDF

were 2,300 to air, 2,300 to land, 28 to water, and 7 to products. 

Table ES-2. Overview of total releases to air, land, water, and products in the updated 

inventory

Year

Releases (g WHO98 TEQ)

Air Land Water Products

1987 15,000 2,400 360 36

1995 3,400 2,400 30 47

2000 2,300 2,300 28 7
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• The top three quantified air sources in 2000 were: 

o forest fires (730 g WHO98 TEQDF), 

o backyard barrel burning of refuse (600 g WHO98 TEQDF), and 

o medical waste incinerators (400 g WHO98 TEQDF). 

• Sources with preliminary release estimates have the potential for large releases of dioxinlike compounds. While not included in the current quantitative estimates listed above, 

future inclusion of these sources could change current release estimates. The largest 

preliminary sources in the current report are:

o accidental fires at landfills (1,300 g WHO98 TEQDF to air in 2000), and

o land clearing debris burning (85 g WHO98 TEQDF to air in 2000). 

• A total of 20 contemporary formation sources were identified as having unquantifiable 

releases to one or more media. Information suggests these may be sources of dioxin-like 

compounds, but it is insufficient to make a national estimate of releases. 

• The chemical product with the largest amount of CDD/CDF is pentachlorophenol, but the 

environmental releases associated with this product (primarily used to treat wood) could 

not be estimated. Release estimates could only be made for 2,4-D, where it can be 

assumed that the entire amount produced is released to the environment. 

The environmental releases of dioxin-like PCBs have not been well characterized. PCBs 

were not produced during the reference years, but are still present in capacitors, transformers, 

building materials and other products in use today. No estimates could be made for releases 

from these in-use products. Only one source (backyard barrel burning) was judged to have 

adequate data to support quantitative air-release estimates for dioxin-like PCBs: 41, 43, and 

34 g WHO98 TEQP for the years 1987, 1995, and 2000, respectively. Similarly, only two sources 

(backyard barrel burning and municipal wastewater treatment) were judged to have adequate 

data to support quantitative land release estimates for dioxin-like PCBs: 52, 78, and 

20 g WHO98 TEQP for the years 1987, 1995, and 2000, respectively. Also, only preliminary 

estimates could be made for 6 sources, and 10 sources were identified as being unquantifiable. 

Although the information is limited, it suggests that, in terms of TEQs, PCB releases are much 

lower than CDD/CDF releases.

Soil is likely to be the reservoir source with the greatest potential for release of 

CDD/CDFs and PCBs to other environmental media, particularly to water. This is due to its 

relatively large mass of stored CDD/CDFs and PCBs and the existence of demonstrated 
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transport mechanisms for intermedia exchange, e.g., soil erosion to surface waters and particle 

resuspension to air.

Discussion

Some observations about how releases have changed over the reference years can be 

made for the quantified sources. It is important to understand, though, that these observations do 

not include the sources classified as preliminary or unquantifiable. Some of the preliminary 

sources are potentially very large and, if confirmed and included in future quantitative estimates, 

could change the trend observations based on the currently quantified sources. With this caveat 

in mind, the following trends were identified. In terms of total releases from all media, a 67% 

reduction occurred from 1987 to 1995, a 23% reduction occurred from 1995 to 2000, and a 74% 

reduction occurred from 1987 to 2000. 

Significant amounts of the dioxin-like compounds produced annually in the United States 

are not considered releases to the open and circulating environment and are not included in the 

national inventory. Examples include dioxin-like compounds generated internal to a process but 

destroyed before release and waste streams that are disposed of in approved landfills.

A number of contemporary formation sources were classified as preliminary or 

unquantifiable and, therefore, were not included in the inventory. The largest contemporary 

formation preliminary source is accidental fires at municipal solid waste landfills. This source 

has the potential to significantly increase the release estimates for 2000 if preliminary estimates 

are confirmed. 

A series of analyses were used to assess the uncertainties of the quantitative inventory. 

This analysis was limited to the air and land releases from the top sources (accounting for over 

90% of the releases) in 2000. This first involved using a propagation of error approach, which 

estimates the variance for the air emissions from each source and sums these to get the overall 

variance in total emissions. Multiple factors contribute to the uncertainty in the emission 

estimate for a class of facilities. These include sampling error which reflects the number of 

facilities tested out of the total, the representativeness of the tests of long term conditions, and 

measurement error from inaccuracies in the stack monitoring and chemical analysis. The 

propagation of error approach used here assumes that the variability in the emissions from the 

sampled facilities is an indication of the possible uncertainty in the emissions from the whole 
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class of facilities. The analysis concludes that the total air releases from the top sources in 2000 

sum to 2,100 g TEQ/year with a standard deviation of 1,300 g TEQ/year.

Secondly, a probabilistic analysis was conducted to evaluate the uncertainties in the air 

releases. All emission factors were assumed to have log normal distributions with means and 

standard deviations based on an arithmetic analysis of the data. A Monte Carlo analysis was 

conducted using the Crystal Ball program. A total of 10,000 simulations were run, producing a 

mean of 2,100 g TEQ and standard deviation of 1,100 g TEQ, which are very similar to the 

results of the propagation-of-error approach described above. Percentiles were estimated as 

1,100 g TEQ for 10%, 1,800 g TEQ for 50%, and 3,300 g TEQ for 90%. These percentiles can 

be interpreted as the probability that the emissions will less than or equal to the specified 

amount.

Finally, further analysis is offered on the uncertainties associated with the forest fire air 

releases. These uncertainties are especially important to evaluate because they are the largest 

source and have high uncertainty in the emission factor. Both chamber studies and field studies 

have been used to measure these emissions. The field data suggest an emission factor of 

0.95 ng TEQ/kg, and the chamber data suggest an emission factor of 7.5 ng TEQ/kg. If the 

lower emission factor is used, the forest fires would have a release of 230 g TEQ, and the total 

releases across the nine top sources in 2000 would be 1,600 g TEQ. Similarly, if the higher 

emission factor is used, the forest fires would have a release of 1,800 g TEQ, and the total 

releases across the nine top sources in 2000 would be 3,200 g TEQ. 

The 2000 land releases were dominated by backyard barrel burning which had releases of 

1,900 g WHO98 TEQ (88% of the total) and the uncertainty analysis for land releases was limited 

to this one source. The releases from backyard barrel burning were based on a study by Lemieux 

(1997). Ash samples from the experiments were combined, resulting in two composite samples, 

one for recyclers (2,700 ng WHO98 TEQDF /kg ash) and one for nonrecyclers 

(620 ng WHO98 TEQDF /kg ash). The final emission factor was based on the average of these 

values (1,700 ng WHO98 TEQDF /kg ash). The limited data do not allow statistical analyses such 

as that done for the air releases. Instead a potential range of releases was estimated based on the 

lower and upper emission factor estimates. The activity estimate for 2,000 was 1.2 MMT. 

Combining this value with the lower emission factor yields a release estimate of 

740 g WHO98 TEQ. Combining the activity with the higher emission factor yields a release 
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estimate of 2,800 g WHO98 TEQ. Accordingly the potential range of releases is 740 to 

2,800 g WHO98 TEQ. Relative to the average value (1,900 g WHO98 TEQ), the lower estimate 

is 62% less and the upper estimate is 46% more.

Changes from 2006 Document

This discussion summarizes the changes from the 2006 report to the present report. 

Quantitative release estimates of CDD/CDFs to air increased for all years. The changes reflect 

the addition of new sources and adjustments to emission factors used for municipal and medical 

waste incinerators. The largest new source was forest fires which was previously classified as 

preliminary and not included in the quantitative inventory. Based on a number of new studies, it 

was decided that sufficient data were now available to move this source into the quantitative 

inventory. The forest fire releases in 2000 were about 4 times higher than 1987 and 1995 (due to 

more fires) causing a particularly large percent increase in that year. Other new sources added to 

the present document were secondary zinc smelters, glass manufacturers, lime kilns, agricultural 

burning, outdoor wood combustors, aluminum foundries, copper foundries and septic systems. 

Quantitative release estimates of CDD/CDFs to land also increased for all years. These 

increases were due almost entirely to ash from backyard barrel burning which had not been 

addressed in the 2006 report. The quantitative releases to water and products did not change. 

The changes to the air and land releases are summarized in Table ES-3 below.

For dioxins, furans, and PCBs combined, the 2006 report indicated a 90% decrease in 

quantitative releases from 1987 to 2000. The updated report now indicates a 74% decrease over 

this time period. This reduction is due primarily to the addition of ash from backyard barrel 

burning (which remained relatively constant over the years) and air releases from forest fires 

(which had a particularly large release in 2000 as discussed above). The present document 

emphasizes that some of the preliminary sources are potentially very large and, if confirmed, 

could change the trend observations based on the currently quantified sources.
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Table ES-3. Changes in quantitative release estimates from 2006 Report to present Report

2006 

Report

Present 

Report

Primary Reason for Change

Air Releases (g WHO98TEQ)

 1987 13,500 15,000 Addition of forest fires, changes to municipal and 

medical waste incinerators

 1995 3,200 3,400 Addition of forest fires, changes to municipal and 

medical waste incinerators

 2000 1,300 2,300 Addition of forest fires, changes to municipal and 

medical waste incinerators

Land Releases (g WHO98 TEQ)

 1987 130 2,400 Addition of backyard barrel burners

 1995 150 2,500 Addition of backyard barrel burners

 2000 82 2,300 Addition of backyard barrel burners
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1 1. BACKGROUND, APPROACH, AND CONCLUSIONS

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1.1. BACKGROUND

This report presents an update to the dioxin source inventory published in 2006 (U.S. 

EPA, 2006). The update does not expand the scope of the document beyond the three reference 

years covered in the original document: 1987, 1995, and 2000. 

This document is organized in a parallel fashion to the 2006 document, i.e., both 

documents use the same chapter/section sequence, although several additional sections have been 

added for new sources. This first chapter of the document is a complete rewrite and should be 

used as a replacement of Chapter 1 in the 2006 document. Chapter 2 on formation theory was 

not updated because it is not critical for the inventory. All subsequent chapters have sections 

organized by environmental media, i.e., releases to air, water, land, and products. Individual 

sections do not repeat the material in the 2006 document. Instead, they summarize new literature 

references and describe any changes in release estimates. At the end of each section, a table is 

presented (in a shaded text box to facilitate their identification and location) that provides all 

emission factors, activities, and release estimates. Most readers will only need to use this 

updated document because it describes all changes from the 2006 document and provides the 

bottom-line release estimates for all sources. Readers interested in further details about sources 

(i.e., process descriptions, summaries of the older literature, information on congener profiles, 

etc.) may find it helpful to consult the 2006 document. 

1.1.1. Dioxin-Like Compounds

This document addresses specific compounds in the following chemical classes: 

chlorinated dibenzo-p-dioxins (CDDs), chlorinated dibenzofurans (CDFs), and polychlorinated 

biphenyls (PCBs). The physical/chemical properties of these compounds vary according to the 

degree and position of chlorine substitution. However, these compounds are generally 

hydrophobic, persistent in the environment, resistant towards metabolism, and bioaccumulate in 

the fatty tissues of animals and humans. 

The CDDs include 75 individual compounds, CDFs include 135 individual compounds, 

and PCBs include 209 individual compounds. These individual compounds are technically 

referred to as congeners. 2,3,7,8-tetrachlorodibenzo-p-dioxin is the most widely studied (and 
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1 historically considered to be the most toxic) chemical in this general class of compounds. A 

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relatively small subset of the CDDs, CDFs, and PCBs are considered to have dioxin-like toxicity.

These compounds have similar chemical structures and invoke a common battery of toxic 

responses as 2,3,7,8-TCDD. Only 7 of the 75 CDD congeners and 10 of the 135 CDF congeners 

are recognized to have dioxin-like toxicity; they are the ones with chlorine substitutions in, at a 

minimum, the 2, 3, 7, and 8 positions. There are 209 PCB congeners; of which, only 12 are 

recognized to have dioxin-like toxicity—those with four or more lateral chlorine atoms with one 

or no substitution in the ortho position. These compounds are sometimes referred to as coplanar, 

meaning that they can assume a flat configuration with rings aligned along the same plane. 

Other halogenated compounds have been identified as having dioxin-like toxicity, such as 

chlorinated naphthalenes, brominated dibenzo-p-dioxins and dibenzofurans, and similar 

compounds with a mix of bromines and chlorines. However, as discussed below, these are not 

addressed in this document. 

The term “dioxins” has been used in several different ways in the literature. For 

example, it has been used to refer to TCDD only, all CDDs and CDFs, or subsets of these 

compounds. The present document uses “dioxins” to refer generally to the CDDs, CDFs, and 

PCBs that have dioxin-like toxicity. (This can also be defined as the 17 CDDs/CDFs and 12 

coplanar PCBs with toxicity equivalence factors [TEFs] greater than zero; this concept of 

toxicity equivalence is discussed further in Section 1.1.2 below.) Similarly, the phrase “dioxinlike compounds” is used in this document to refer to only those compounds with established TEF 

values. As noted above, a number of other compounds have been suggested to have “dioxin-like 

toxicity,” but these are not addressed in this document. 

This document focuses primarily on the 17 CDDs/CDFs, with a more limited discussion 

of the 12 coplanar PCBs. This is because there are relatively little congener-specific data on 

PCB releases. 

Table 1-1 provides a complete listing of the chemical nomenclature used in this report.

1.1.2. Toxicity Equivalence Factors 

CDDs, CDFs, and PCBs are commonly found as complex mixtures when detected in 

environmental media, biological tissues, or releases from specific sources. Humans are likely to 

be exposed to mixtures of these compounds that vary by source and pathway, complicating the 
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1 assessment of human health risk assessment. To address this problem, the concept of a “toxicity 

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equivalence” (TEQ) has been developed.

TEFs compare the toxicity of each dioxin-like compound in the mixture to the 

well-studied 2,3,7,8-TCDD, historically considered the most toxic member of the group. The 

comparison procedure involves assigning individual TEFs to the 2,3,7,8-substituted CDD/CDF 

congeners and dioxin-like PCBs. To accomplish this, scientists have reviewed the toxicological 

databases and, with considerations of chemical structure, persistence, and resistance to 

metabolism, have agreed to ascribe specific “order-of-magnitude” TEFs for each dioxin-like 

congener relative to 2,3,7,8-TCDD, which is assigned a TEF of 1. The other congeners have 

TEF values ranging from 1 to 0.00001. 

To apply this concept, the TEF of each congener present in a mixture is multiplied by the 

respective mass concentration, and the products are added to represent the 2,3,7,8-TCDD TEQ of 

the mixture (eq 1-1).

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TEQ Concentration TEF =

=∑ × (1-1) 

A variety of TEF schemes have been developed since the 1980s. This can lead to 

confusion when a TEQ value is presented without a clear designation of which TEF scheme was 

used to calculate it. This document uses a nomenclature that distinguishes between the different 

TEF schemes and identifies the congener groups included in specific TEQ calculations:

• I-TEQ refers to toxic equivalents derived using the international TEF scheme adopted by 

EPA in 1989 (U.S. EPA, 1989). 

• WHO94 TEQ refers to toxic equivalents derived using the 1994 World Health 

Organization (WHO) extension of the I-TEF scheme, which includes 13 dioxin-like 

PCBs (Ahlborg et al., 1994). 

• WHO98 TEQ refers to toxic equivalents derived using the 1998 WHO update to the 

previously established TEFs for dioxins, furans, and dioxin-like PCBs (Van den Berg 

et al., 1998). 

• WHO2005 TEQ refers to toxic equivalents derived using the 2005 WHO update to the 

previously established TEFs for dioxins, furans, and dioxin-like PCBs (Van den Berg 

et al., 2006). 
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Table 1-2 shows all four of these TEF schemes.

The nomenclature also uses subscripts to indicate which family of compounds is included 

in any specific TEQ calculation. Under this convention, a subscript D is used to designate 

dioxins, a subscript F is used to designate furans, and a subscript P is used to designate PCBs. 

As an example, WHO98 TEQDF would be used to describe a mixture for which only dioxin and 

furan congeners were determined and where the TEQ was calculated using the WHO98 scheme. 

If PCBs had also been determined, the nomenclature would be WHO98 TEQDFP. Note that in this 

document I-TEQ sometimes appears without the D or F subscripts. This indicates that the TEQ 

calculation includes both dioxins and furans. 

This document uses the WHO98 TEF scheme as the primary basis for presenting TEQ 

estimates. While the WHO2005 TEFs are more current, the previous version of this document 

used the WHO98 TEFs. This document continues the use of the WHO98 TEFs to be consistent 

with the 2006 document, allowing for easy comparison. A limited number of estimates were 

generated using the newer TEF values, and it was seen that differences were inconsequential 

(data not provided). 

Throughout this document, environmental release estimates are presented in terms of 

TEQs. This is consistent with previous versions of the inventory and is the common approach to 

dioxin sources inventories worldwide (UNEP, 2005). Doing so facilitates comparisons across 

sources. For the purposes of environmental fate modeling, however, it is important to use the 

individual CDD/CDF and PCB congener values rather than TEQs. This is because the 

physical/chemical properties of individual CDD/CDF congeners vary and, consequently, the 

congeners will behave differently in the environment. For example, the relative mix of 

congeners released from a stack cannot be assumed to remain constant during transport through 

the atmosphere and deposition to various media. Further, the bioavailability of dioxin congeners 

are different, so that bioaccumulation in the food chain up through humans results in different 

relative proportions of dioxins compared to the profile of dioxins to which animals and humans 

are exposed. Generally, human exposure to releases of dioxins from sources is a complex 

phenomena encompassing proximity to source, congener-specific fate and transport 

characteristics, and congener-specific bioavailability. For this reason, the amount of dioxins 

being emitted from a specific source may not translate directly into human exposure. 
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1 TEQ values are frequently based on some congeners that were not found above detection 

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limits (DLs). Undetected values are commonly referred to using the term “nondetect,” or ND, 

and that terminology is adopted here. EPA risk assessments typically address this issue by 

assuming that NDs = 2DL. This document is not a risk assessment and uses a different 

approach. Here, it is assumed that NDs = 0. This assumption allows a consistent approach to 

this issue throughout the document. Because many studies did not provide DLs, the only 

practical, consistent approach is to assume NDs = 0. Many assessments also present TEQ 

estimates in two ways: first assuming NDs = 0 and then assuming NDs = 2 DL. Such 

comparisons are useful for illustrating the impact of DLs on TEQ calculations. This approach 

was used in some places in this document, but generally, it was not used for two reasons. First, it 

was not possible in many instances due to lack of DL information. Second, many release 

estimates are presented in terms of two TEF schemes and three reference years. Presenting all 

values with two ways of treating DLs, would increase complexity enough to compromise the 

readability of the document. 

1.1.3. Regulatory Summary 

Over the time frame represented by these inventories (1987–2000), EPA, states, and 

industry have worked to develop regulations limiting dioxin emissions. Although not all of these 

regulations are fully implemented yet, they have contributed to reductions in emissions from 

certain source categories (see time trend discussion in Section 1.3.3). Tables 1-3 through 1-8 

present a synopsis of the principal EPA emission standards for the control of dioxin releases. 

1.1.4. Information Sources

The references used to support this report are based on an intensive literature review of 

documents published in 2003 (or earlier) and selected documents published in 2004–2010. The 

report also used information from databases maintained by EPA’s Office of Air Quality Planning 

and Standards and Office of Resource Conservation and Recovery (ORCR). 

An important reference in this field is the Standardized Toolkit for Identification and 

Quantification of Dioxin and Furan Releases issued by the United Nations Environment 

Programme in 2005 (UNEP, 2005). This document was produced to help support 

implementation of the Stockholm Convention on Persistent Organic Pollutants. This Toolkit
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1 provides a methodology to help countries just developing their inventories to estimate releases of 

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CDD/CDF and to lead them through the process of enhancing and refining these inventories. It 

is intended to provide a consistent basis for assessing CDD/CDF releases over time and between 

countries. This updated inventory frequently references the Toolkit and discusses the 

recommended emission factors. 

The EPA Toxics Release Inventory (TRI) began collecting data on PCBs in 1988 and on 

CDDs/CDFs in 2000 (U.S. EPA, 2003b). The TRI reporting of dioxin sources provides 

important information in the overall understanding of dioxin releases. These data were 

considered in this report for the purposes of identifying possible sources and as supportive 

evidence for where releases can occur, but they were not used for making quantitative release 

estimates because of the following considerations: 

• With respect to PCBs, for reporting years 1988–2000, the TRI data are reported as total 

PCBs rather than on a congener-specific basis. Thus, it is unknown what portion of these 

releases are dioxin-like PCBs, and TEQs cannot be calculated. 

• With respect to CDDs/CDFs, for reporting year 2000, the TRI data are reported as the 

sum of the 17 congeners with 2,3,7,8-chlorine-substituted compounds. Facilities had the 

option to report an estimate of the congener distribution for total releases, though many 

chose not to provide this information. Accordingly, much of the 2000 data could not be 

used to make TEQ estimates.

• The TRI data are self-reported, and facilities are not required to take measurements to 

support their emission estimates. Rather, they can be derived from emission factors or 

other methods. Facilities are also not required to describe the approach used to make the 

emission estimates. Consequently, it would be difficult to evaluate inconsistencies 

between these estimates and those in this inventory. 

• The TRI reports include SIC codes but lack further details describing the facilities in 

terms of process, production, and pollution controls. Therefore, in many cases, it is not 

clear where a reporting facility fits into the classification system used in this report.

1.2. APPROACH

This section describes the key components of the approach used to develop the dioxin 

inventory. The discussion covers the selection of reference years, release types, how sources are 

classified, quantitative methods used to develop release estimates, and confidence ratings. 
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1 1.2.1. Reference Years

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A central part of EPA’s dioxin inventory is the organization of estimates of annual 

releases of dioxin-like compounds into reference years 1987, 1995, and 2000. The selection and 

use of three reference years provides a basis for comparing environmental releases over time.

The year 1987 was selected as the initial reference year because it was the earliest time 

when it was feasible to assemble a reasonably comprehensive inventory. Prior to that time, very 

little data existed on dioxin emissions from stacks or other release points. The first study 

providing the type of data needed for a national inventory was the EPA National Dioxin Study 

(U.S. EPA, 1987). The year 1987 also corresponds roughly with the time when significant 

advances occurred in emissions measurement techniques and in the development of 

high-resolution mass spectrometry and gas chromatography, which allowed analytical 

laboratories to detect low levels of CDD and CDF congeners in environmental samples. Soon 

after this time, a number of facilities began upgrades specifically intended to reduce CDD/CDF 

emissions. Consequently, 1987 emissions are representative of levels that occurred before the 

widespread installation of pollution control systems and pollution prevention techniques 

specifically designed to reduce dioxin releases from man-made sources into the air, land, and 

water. 

EPA selected 1995 as the second reference year because it reflects the completion time of 

the first set of regulatory activities specifically tailored to reduce dioxin releases from major 

sources. By 1995, EPA had proposed or promulgated regulations limiting CDD/CDF emissions 

from municipal waste combustors (MWCs), medical waste incinerators, and pulp and paper mill 

facilities using bleached chlorine processes. 

The year 2000 was chosen as the most current date that could be addressed when this 

effort began in 2002. Also, it corresponds to a reasonable time interval since 1995 when one 

could expect to see further changes occurring in releases as a result of continuing regulatory 

activities, voluntary actions on the part of industry, and facility closures. 

1.2.2. Release Types

A comprehensive assessment of potential dioxin releases from a source requires 

consideration of all possible outputs. As diagrammed in Figure 1-1, the outputs of a process can 

be in the form of products, air emissions, water discharges, and solid residues. Solid residues 
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1 can be used in products, land disposed or incinerated. Each source addressed in this document is 

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evaluated in terms of all of these outputs. However, not all of the outputs are considered to be 

environmental releases. Outputs judged to have a reasonable likelihood for release to the 

circulating environment include all air emissions, water discharges, landfarmed wastes and 

products which are directly released to the open environment such as some pesticides. Outputs 

that are generally not considered an environmental release include waste disposal at lined 

landfills, intermediate products or internal waste streams or products containing tightly bound 

dioxins such as treated wood. Dioxins contained in some products or disposed in secure landfills 

may be released to the circulating environment at some time in the future. They are less likely to 

be released to the circulating environment during the same year that they enter into commerce or 

are landfilled. Consequently, these contained dioxins would not initially be considered 

environmental releases. Ideally, releases derived from such products and landfill practices of 

past years would be included in the inventory for the reference year in which the releases occur. 

Unfortunately, the current state of science does not support estimating when and to what degree 

such releases may occur. However, for informational purposes, and when sufficient information 

is available, this document provides estimates of the amount of dioxins contained in products or 

disposed in landfills.

1.2.3. Source Classes

Sources can be categorized in terms of when releases occur: (1) contemporary formation 

sources (sources that have essentially simultaneous formation and release) and (2) reservoir 

sources (materials or places that contain previously formed CDDs/CDFs or dioxin-like PCBs that 

are rereleased to the environment). The contemporary formation sources are discussed in 

Chapters 3 through 10, and the reservoir sources are discussed in Chapter 11. 

This document also classifies sources into five broad categories based mainly on their 

formation process: 

1. Combustion. CDDs/CDFs are formed in most types of combustion. These sources are 

addressed in Chapters 3–6: 

• Chapter 3 covers sources involved in waste incineration including municipal solid 

waste (MSW), hazardous waste, medical waste, sewage sludge, and other types of 

waste. 
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1 • Chapter 4 covers sources related to power/energy generation including motor vehicles 

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and combustion of wood, oil, and coal.

• Chapter 5 covers a variety high temperature sources including cement kilns, asphalt 

plants, carbon reactivation furnaces, and others. 

• Chapter 6 covers minimally controlled or uncontrolled sources and includes landfill 

gas flares/fires, forest fires, backyard trash burning in barrels, and others. 

2. Metals Smelting/Refining. This category includes sources that are involved in metals 

smelting, refining, and processing. They are addressed in Chapter 7. 

3. Chemical Manufacturing. CDDs/CDFs can be formed as by-products in a variety of 

chemical manufacturing operations. These are addressed in Chapter 8 and include 

chlorine-bleached wood pulp, chlorinated phenols (e.g., pentachlorophenol), PCBs, 

chlorobenzenes, phenoxy herbicides (e.g., 2,4-D and 2,4,5-T), and chlorinated aliphatic 

compounds (e.g., ethylene dichloride, vinyl chloride, polyvinyl chloride). 

4. Biological, Photochemical, and Other Natural Processes. CDDs/CDFs can form via 

biological processes such as the action of microorganisms on chlorinated phenolic 

compounds and also during photolysis of highly chlorinated phenols. These are 

addressed in Chapter 9. 

5. Reservoirs. Reservoirs are environmental compartments and materials that have the 

capacity to store previously formed CDDs/CDFs or dioxin-like PCBs. These compounds 

are thus sequestered from the open and circulating environment. Potential reservoirs 

include soils, sediments, and biota as well as some anthropogenic materials, such as 

PCP-treated utility poles. Dioxin-like compounds in these reservoirs have the potential 

for redistribution and circulation in the environment through the physical processes such 

as leaching, volatilization, erosion, sedimentation, and deposition. Whenever dioxins are 

released from their place of storage back into the circulating environment, the reservoir is 

considered a source of dioxin. Reservoirs are addressed in Chapter 11. 

Note that Chapters 3–9, discussed above, address releases of only CDDs and CDFs. 

Contemporary formation sources that releases dioxin-like PCBs are discussed in Chapter 10. 

Reservoir sources that release CDDs, CDFs, or PCBs are covered in Chapter 11. 

1.2.4. Quantitative Method for Inventory of Sources 

Estimates of CDD/CDF releases to the air from individual facilities are derived from 

stack testing, which provides the concentration of CDD/CDF in the flue gas. This is combined 

with the flue gas flow rate and operating time to estimate annual releases as shown in 

equation 1-2: 
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1 

gng

HCFFC E v

TEQ /109 = (1-2)

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where

 ETEQ = annual TEQ emissions (g/year) 

C = combustion flue gas TEQ concentration (ng/dscm) (20oC, 1 atm; adjusted to 

7% O2) 

 Fv = volumetric flow rate of combustion flue gas (dscm/hour) (20oC, 1 atm; adjusted 

to 7% O2) 

CF = capacity factor; fraction of time that the facility operates

H = total hours in a year (8,760 hour/year) 

A similar approach is used for estimating facility releases to other media. For example, releases 

to water would involve multiplying the concentration of the CDD/CDF in the effluent by the 

discharge rate. Ideally, national release estimates would be derived by testing every facility in a 

source category, estimating their releases, and summing across facilities. This was feasible in 

only a few situations such as wastewater releases from chlorine-bleached pulp and paper mills. 

For all other source categories, EPA used a method to extrapolate from tested to untested sources 

and derive national estimates of environmental releases. As explained below, this method is 

based on the use of emission factors and activity levels. 

The first step in this approach is to use emission monitoring data to derive an emission 

factor (or series of emission factors) deemed to be representative of the source category (or 

segments of a source category that differ in terms of configuration, fuel type, air pollution 

control equipment, etc.). The emission factor relates mass of dioxins released into the 

environment with some measure of activity (e.g., kilograms of material processed per year, 

vehicle miles traveled per year, liters of wastewater discharged per year). For individual 

facilities, it is calculated using the following equation (eq 1-3):

ETEQ EF

A = (1-3) 

where
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1 EF = emission factor (ng TEQ/kg) 

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 ETEQ = annual TEQ emissions (g/year) (see eq 1-1) 

A = annual activity rate (kg/year)

A similar approach is used for estimating emission factors for releases to other media. 

For example, an emission factor for releases to water would involve dividing the annual TEQ 

release rate via effluent discharges by the annual waste processing rate (or some other measure 

of activity). The emission factor representing a class of facilities is developed by averaging the 

emission factors across the tested facilities in the class. This average emission factor is then 

multiplied by the measure of activity for the nontested facilities in the class (e.g., total kilograms 

of material processed by these facilities annually). Finally, releases are summed for the tested 

facilities and nontested facilities. In general, this procedure can be represented by the following 

equations (eq 1-4 and 1-5):

, ,

1 1

n n

Total Tested i Untested i

i i

RR R = == + ∑ ∑ (1-4) 

i

n

i

Untested i

n

i

Total = RR Tested i +∑∑ EF × A = =1

,

1

, (1-5) 

where

RTotal = annual releases from all facilities (g TEQ/year)

RTested, i = annual releases from all tested facilities in class i (g TEQ/year)

RUntested, i = annual releases from all untested facilities in class i (g TEQ/year)

EFUntestedi = mean emission factor for untested facilities in class i (g TEQ/kg)

Ai = activity measure for untested facilities in class i (kg/year)

Note that even though this approach is presented using the term “emission factor,” it is 

intended to apply to releases to all media. The method was originally developed for evaluating 

air emissions and is thus traditionally defined using this term. Also note that for most sources, a 

small percentage of the facilities had been tested. In these cases, it was not worth the effort to 
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1 estimate releases from tested and untested facilities separately as shown in equation 1-5. Instead, 

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the average emission factor was applied to the activity level for the whole class. 

Some source categories are made up of facilities that vary widely in terms of design and 

operating conditions. For these sources, as explained above, an attempt was made to create 

subcategories that grouped facilities with common features and then to develop separate 

emission factors for each subcategory. Implicit in this procedure is the assumption that facilities 

with similar design and operating conditions should have similar CDD/CDF-release potential. 

For most source categories, however, the specific combination of features that contributes most 

to CDD/CDF or dioxin-like PCB releases is not well understood. Therefore, the procedure for 

how to best subcategorize a source category was often problematic. For each subcategorized 

source category in this document, a discussion is presented about the variability in design and 

operating conditions, what was known about how these features contributed to CDD/CDF or 

dioxin-like PCB releases, and the rationale for creating subcategories.

The emission factors developed for the inventory are intended to be used for estimating 

total emissions for a source category rather than emissions from individual facilities. If applied 

to individual facilities, the emission factor would likely overestimate releases from some 

facilities and underestimate others. When it is applied to a class of facilities, these over- and 

underestimates balance out to some extent. Thus, in using these emission factors, one can place 

significantly greater confidence in an emission estimate for a class than in an estimate for any 

individual facility. Given the limited amount of data available for deriving emission factors and 

the limitations of our understanding about facility-specific conditions that determine formation 

and control of dioxin-like compounds, the current state of knowledge cannot support the 

development of emission factors that can be used to accurately estimate emissions on an 

individual facility-specific basis. 

1.2.5. Uncertainties

The quantitative inventory has multiple uncertainties, including the following: 

• It is based on emissions testing that covers a small fraction of the facilities in most 

classes. 

• Facility testing is generally over short time periods during normal operating conditions. 

The releases during start-up and shutdown may be different than normal operations. For 
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1 conventional pollutants, releases are generally greater during these times, but dioxin 

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releases may occur at rates lower or higher than normal operations due to changes in 

formation conditions. Recent efforts by EPA’s Office of Air Quality Planning and 

Standards are addressing emissions that occur during start-up and shutdown and may 

allow these uncertainties to be addressed in the future. 

• Testing has sometimes found individual facilities within a class with unusually low or 

high dioxin releases for unknown reasons. 

• It does not include the emissions from a number of suspected sources that lack sufficient 

data to make reliable estimates (defined below as preliminary or unquantifiable sources). 

Because many types of sources release dioxins, it is likely that some have been missed 

completely.

All of these factors introduce uncertainty into the release estimates. While most of these 

uncertainties are impossible to characterize, some can be evaluated as discussed below.

The original inventory report (U.S. EPA, 2006) used a qualitative scheme to assess 

uncertainty. This scheme assigned qualitative confidence ratings to the emission factors, activity 

levels, and release estimates. The five confidence ratings (Class A, B, C, D, or E) were defined 

as follows: 

• Classes A, B, and C—Class A indicates high confidence, Class B indicates medium 

confidence, and Class C indicates low confidence. These three classes make up the 

quantitative inventory. 

• Class D—For many source categories, very limited release data were available and 

judged to be inadequate to support development of reliable quantitative release estimates 

for one or more media. For some of these source categories, sufficient information was 

available, however, to make preliminary estimates of releases. These preliminary 

estimates were assigned to Class D.

• Class E—For other sources, no dioxin release data were available, but either formation 

theory or similarity to other sources with measured releases suggested that releases may 

occur. These sources were identified to the extent possible, but no release estimates 

could be made. They were assigned to Class E.

The overall confidence rating assigned to an emissions estimate was determined by the lowest 

rating assigned to either the emission factor or activity level. 

In this update, a revised approach has been developed to characterize the confidence 

ratings of the release estimates. The revised approach maintains the three major categories 

previously used, i.e., (1) the quantitative inventory [which now includes the sum of the previous 
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1 confidence ratings that were subdivided into Class A, B, or C], (2) the preliminary release 

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estimates [previously assigned a rating of Class D], and the unquantifiable sources [previously 

assigned a rating of Class E]. The major changes are the elimination of the Class A, B, or C 

confidence distinctions in the quantitative inventory and the addition of the quantitative 

uncertainty analysis of the quantitative inventory (presented in Section 1.3.6). The old Class A, 

B, and C confidence ratings were eliminated because they were too subjective and difficult to 

apply in a consistent fashion. Also, it was judged that confidence ratings for the individual 

source classes were less essential because a new quantitative uncertainty analysis has been 

added. It was determined that the more important issue was the uncertainty in the total national 

release estimate. Accordingly, the new quantitative approach focuses on this issue. 

Key components of both the old and new scheme for assessing uncertainty are the criteria 

for deciding whether a source belongs in the quantitative inventory or preliminary class. This 

update uses more specific guidance for making this decision. In order for a source to be included 

in the quantitative inventory, it must (a) have emission tests for at least two units/source types 

with sufficient documentation to directly derive emission factors, (b) the measured emission 

factors must be reasonably consistent or have understandable differences, (c) the emission factor 

tests must represent units that are reasonably typical of the class and (d) the activity estimates 

must be based on source-specific surveys.

The actual magnitude of releases from the preliminary sources could be significantly 

lower or higher than estimated. Although EPA has chosen not to include them in the quantitative 

inventory, it must be emphasized that some of the preliminary sources have the potential of being 

major contributors of releases to the environment. Accordingly, they are important to identify 

and can be used to help set priorities for future research and data collection. As the uncertainty 

around these sources is reduced, they will be included in future inventory calculations. 

The data used in this document come from hundreds of studies which reported values 

using a wide range of significant figures. In the present report, the decision about how many 

significant figures to use began with the general policy to report previously published data in the 

same manner as in the original publication and to report calculated values with a number of 

significant figures no more than the input with the least number of significant figures. This 

document reports all emission factors and releases in TEQs. TEQs are derived from toxicity 

equivalency factors that are presented with only one significant figure. Although this suggests 
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1 that all TEQ estimates should be presented with only one significant figure, they are commonly 

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reported to 2 or more significant figures in the literature. Limiting the number of significant 

figures to 1 for the larger release estimates introduces large rounding adjustments. Therefore, it 

was decided to present the release estimates to 2 significant figures when they equal or exceed 10 

g TEQ/year. Releases less than 10 g TEQ/year were limited to only 1 significant figure. 

Releases less than 0.1 g TEQ/year were presented as <0.1 to reflect the additional uncertainty in 

such small estimates and because they have negligible contributions to the total releases. 

Similarly the emission factors were reported to 2 significant figures for values that equal or 

exceed 0.1 ng TEQ/kg and to 1 significant figure for values less than 0.1 ng TEQ/kg. Activity 

estimates are typically very large numbers and are generally known with more certainty than the 

emission factors. Therefore, it was decided to report activities to 3 or fewer significant figures. 

1.3. SUMMARY AND CONCLUSIONS

Table 1-12 lists all of the quantitative and preliminary CDD/CDF release estimates 

developed in this document. It also identifies all of the unquantifiable sources. Where feasible, 

the table presents release estimates to air, water, land, and products for each reference year. As 

discussed earlier, the preliminary release estimates are not part of the official inventory, but they 

are included in this table to provide a complete picture of what is known and unknown about 

potential CDD/CDF releases.

Table 1-13 lists all of the quantitative and preliminary PCB release estimates and 

unquantifiable PCB sources. It is organized in the same manner as Table 1-12. Both Tables 

1-12 and 1-13 include only contemporary formation sources, i.e., those which form CDD/CDFs 

during the same time frame as when the releases occur. Releases can also occur from reservoirs, 

which are defined as materials or places that contain previously released CDD/CDFs or dioxinlike PCBs and have the potential for redistributing these compounds into the environment. 

Tables 1-14 (CDD/CDFs) and 1-15 (PCBs) present releases for reservoirs. Releases from 

reservoirs are not considered to be part of the official inventory because they are not original 

releases but rather the recirculation of past releases. 
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1 1.3.1. Contemporary Formation Sources 

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Eighty source categories were identified with the potential for dioxin emissions. The 

major conclusions regarding CDD/CDF releases from contemporary formation sources are 

presented below: 

• The total releases under the national quantitative inventory for 1987 in g WHO98 TEQDF

were 15,000 to air, 2,400 to land, 360 to water, and 36 to products. 

• The total releases under the national quantitative inventory for 1995 in g WHO98 TEQDF

were 3,400 to air, 2,400 to land, 30 to water, and 47 to products. 

• The total releases under the national quantitative inventory for 2000 in g WHO98 TEQDF

were 2,300 to air, 2,300 to land, 28 to water, and 7 to products. 

• Table 1-16 presents a ranking of the top five sources based on the magnitude of 

environmental release by year and media. The top three air sources in 2000 were forest 

fires (730 g WHO98 TEQDF), backyard barrel burning of refuse (600 g WHO98 TEQDF), 

and medical waste incinerators (400 g WHO98 TEQDF). 

• Preliminary sources have the potential for large releases of dioxin-like compounds. The 

largest preliminary sources are accidental fires at landfills (1,300 g WHO98 TEQDF to air 

in 2000) and land clearing debris burning (85 g TEQDF to air in 2000). 

• A total of 20 contemporary formation sources were identified as having unquantifiable 

releases to one or more media. Information suggests these may be sources of dioxin-like 

compounds, but it is insufficient to make a national estimate of releases. 

• Table 1-17 lists the amounts of CDD/CDF found in several chemical products. The 

largest amounts are found in pentachlorophenol, but the environmental releases 

associated with this product (primarily used to treat wood) could not be estimated. 

Release estimates could only be made for 2,4-D, where it can be assumed that the entire

amount produced is released to the environment. 

The environmental releases of dioxin-like PCBs have not been well characterized. PCBs 

were not produced during the reference years, but are still present in capacitors, transformers, 

building materials and other products in use today. No estimates could be made for releases 

from these in-use products. As shown in Table 1-13, only one source (backyard barrel burning) 

was judged to have adequate data to support quantitative air-release estimates of 41, 43, and 

34 g WHO98 TEQP for the years 1987, 1995, and 2000, respectively. Similarly, only two sources 

(backyard barrel burning and municipal wastewater treatment) were judged to have adequate 

data to support quantitative land release estimates of 52, 78, and 20 g WHO98 TEQP for the years 

1987, 1995, and 2000, respectively. Also, preliminary estimates could be made for 6 sources, 
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1 and 10 sources were identified as being unquantifiable. Although the information is limited, it 

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suggests that, in terms of TEQs, PCB releases are much lower than CDD/CDF releases.

1.3.2. Reservoir Sources

Soil is likely to be the reservoir source with the greatest potential for release of 

CDD/CDFs and PCBs to other environmental media, particularly to water. This is due to its 

relatively large mass of stored CDD/CDFs and PCBs and the existence of demonstrated 

transport mechanisms for intermedia exchange, e.g., soil erosion to surface waters and particle 

resuspension to air.

The preliminary estimates of CDD/CDF TEQs in soil runoff to waterways (Table 1-14) 

are more than 100 times greater than known industrial point-source releases to water. It is 

unclear how much of the soil erosion and runoff represents recently deposited CDD/CDFs from 

primary sources or longer-term accumulation. Much of the eroded soil comes from tilled 

agricultural lands, which would include a mix of CDD/CDFs from various deposition times. 

Five possible product reservoirs were identified: bleached chemical wood pulp, 

pentachlorophenol, vinyl chloride, chloranil, and PCBs. No estimates could be made for the 

total mass of CDD/CDFs contained in these reservoirs or their releases.

1.3.3. Time Trends

Some observations about how releases have changed over the reference years can be 

made for the quantified sources. It is important to understand, though, that these observations do 

not include the sources classified as preliminary or unquantifiable. Some of the preliminary 

sources are potentially very large and, if confirmed, could change the trend observations based 

on the currently quantified sources. With this caveat in mind, the following trends were 

identified.

Table 1-18 shows the total releases in 1987, 1995, and 2000 and the percent changes 

from 1987 to 1995, 1995 to 2000, and 1987 to 2000. A few sources were included in some 

reference years and not others due to lack of information. Removal of these sources from the 

yearly totals only had a large effect on the water release estimates. Thus, the water totals 

presented in Table 1-18 reflect this adjustment (discussed further below). 
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1 In terms of total releases from all media, a 67% reduction occurred from 1987 to 1995, a 

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23% reduction occurred from 1995 to 2000, and a 74% reduction occurred from 1987 to 2000. 

Further insight can be gained from examining trends occurring in each medium: 

• Air—The reductions in total air releases were 85% from 1987 to 2000. Three sources 

accounted for over 100% of the reduction: municipal waste incinerators (74%), medical 

waste incinerators (18%), and secondary copper smelters (8%). These reductions were 

offset by increases in releases from forest fires, which increased by a factor of 4 from 

1987 to 2000: 180 g WHO98 TEQ in 1987 to 730 g WHO98 TEQ in 2000. Table 1-16 

shows that the nonindustrial sources have moved to the top of the rankings. 

• Land—Very little change occurred in land releases over the reference years (4% 

reduction in 1987 to 2000). Land release estimates could only be made for 

seven sources, and these were dominated by structural fires and backyard barrel burning. 

• Water—Only one source—bleached pulp and paper mills—had water release estimates 

for each of the reference years. Thus, the trend analysis is limited to this source. The 

reductions from 1987 to 2000 were almost 100% (360 to 1 g WHO98 TEQ).

• Product—The reductions in product releases were 81% from 1987 to 2000. Release 

estimates could only be made for two products: 2,4-D and land-applied municipal 

wastewater treatment sludge. Assuming that dioxins have been eliminated from 2,4-D by 

2000 (data are lacking to confirm this), this reduction is virtually 100%. Releases from 

sludge actually increased from 1987 to 2000, although the amounts were low (i.e., 

7 gWHO98 TEQ in 2000). 

One way to assess the validity of these trends is to consider the uncertainties associated with 

the release estimates. As discussed in Section 1.3.6 a propagation of error analysis was used to 

derive the standard deviation for the air release estimate for the year 2000 based on the top 9 

sources (releases = 2,100 g WHO98 TEQ with SD = 1,300). A similar analysis of the 1987 data 

suggests that the air releases (14,000 g WHO98 TEQ) have an SD of 3,000. This means that the 

1987 releases minus two SDs still exceeds the 2000 releases plus two SDs. As a point of 

comparison, for normal distributions, 95% of the probability falls within two SDs of the mean. 

Although the distribution of possible releases is likely skewed, the large difference between the 

total releases and their associated SDs suggest that little overlap occurs between the possible 

range of estimates for the 1987 and 2000 releases. Thus the results of this analysis strongly 

support the observation of a downward trend. 
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based on recent rulemaking and data collection efforts conducted by EPA’s Office of Air Quality 

Planning and Standards. The Clean Air Act requires that regulation support efforts include 

estimates of current nationwide baseline emissions and future reductions that will occur after full 

implementation of the regulations. The list below shows these estimates for regulation support 

activities that have occurred after 2000: 

• Sewage sludge incineration – Baseline estimates for 2010 were 0.4 g WHO2005 TEQ/yr 

with future reductions of 0 g WHO2005 TEQ/yr (ERG, 2011a). This compares to the 

estimates presented here of 10 g WHO98 TEQ/yr for the year 2000. 

• Medical waste incineration – Baseline estimates for 2008 were 0.83 g WHO2005 TEQ/yr 

with future reductions of 0.66 g WHO2005 TEQ/yr (Holloway, 2009). This compares to 

the estimates presented here of 400 g WHO98 TEQ/yr for the year 2000. 

• Secondary copper smelting - US EPA concluded that no dioxin emissions occurred from 

secondary copper smelting plants in 2006 because all had been shut down (Federal 

Register, 2006). This compares to the estimates presented here of 0.9 g WHO98 TEQ/yr 

for the year 2000. 

• Industrial, Commercial, Institutional Boilers and Process Heaters - Baseline estimates for 

2008 were 37 g WHO2005 TEQ/yr with future reductions of 23 g WHO2005 TEQ/yr 

(Singleton and Gibson, 2011). This source category does not match exactly with the 

source definitions used here. It includes industrial oil burning boilers (7 g WHO98

TEQ/yr for the year 2000) and industrial coal burning boilers (41 g WHO98 TEQ/yr for 

the year 2000) 

• Commercial/Industrial solid waste incineration - Baseline estimates for 2010 were 165 g 

total CDD/Fs with future reductions of 115 g total CDD/Fs (ERG, 2011b). Unfortunately 

as of press time for the present document, no TEQ conversions were available for these 

estimates, making comparisons difficult. Also this source category does not match 

exactly with the source definitions used here. 
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 1.3.4. Sources Not Included in the Inventory

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

Significant amounts of the dioxin-like compounds produced annually in the United States 

are not considered releases to the open and circulating environment and are not included in the 

national inventory. Examples include dioxin-like compounds generated internal to a process but 

destroyed before release and waste streams that are disposed of in approved landfills. 

A number of contemporary formation sources were classified as preliminary or 

unquantifiable and, therefore, were not included in the inventory. The largest contemporary 

formation preliminary source is accidental fires at MSW landfills. This source has the potential 

to significantly increase the release estimates for 2000 if preliminary estimates are confirmed. 

The possibility remains that truly undiscovered sources exist. Many of the sources that 

are well accepted today were discovered only in the recent past. For example, CDDs/CDFs in 

stack emissions from MWCs were not detected until the late 1970s; CDDs/CDFs in the 

wastewater effluent from bleached pulp and paper mills were found unexpectedly in the 

mid-1980s; iron ore was not recognized as a source until the early 1990s. 

1.3.5. Congener Profiles of CDD/CDF Sources

The 2006 document presented congener profiles for a number of sources, showing the 

relative amounts of CDD/CDF congeners in environmental releases. While these profiles can be 

useful for identifying sources, they are not essential to the inventory itself. Therefore, they were 

not updated in the present document. 

1.3.6. Uncertainty Analysis 

The purpose of this section is to present a quantitative analysis of the uncertainty in the 

total release estimates. Given the wide scope of this document (over 80 source categories, 

three reference years and four release media), a number of steps were taken to simplify this 

analysis. First, it was limited to the 2000 releases because these are the most current. Second, it 

was limited to the air and land releases. The releases to the other media are so much smaller, 

they will have negligible impact on the overall uncertainty (air—2,300 g WHO98 TEQ, land—

2,200 g WHO98 TEQ, water—28 g WHO98 TEQ and product—7 g WHO98-TEQ). Finally, the 

number of source categories included in the analyses was limited to the largest ones, with 

cumulative contributions of about 90% of the total releases. 
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 1-21 DRAFT: DO NOT CITE OR QUOTE

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

1.3.6.1. Air Releases

The uncertainty was first evaluated using a propagation of error approach. This involves 

estimating the variance for the emissions from each source and summing these to get the overall 

variance in total emissions. Multiple factors contribute to the uncertainty in the emission 

estimate for a class of facilities. These include sampling error which reflects the number of 

facilities tested out of the total, the representativeness of the tests of long term conditions and 

measurement error from inaccuracies in the stack monitoring and chemical analysis. The 

propagation of error approach used here assumes that the variability in the emissions from the 

sampled facilities is an indication of the possible uncertainty in the emissions from the whole 

class of facilities. While some of the variability is due to differences in the design and operation 

of the facilities, some also results from the various sources of uncertainty. It is impossible to 

know how much of the variability can be attributed to design/operation versus uncertainty, so 

this approach interprets all of the variability as an indication of the possible uncertainty. While 

this may imply an overestimate of the uncertainty, this is offset to some degree by the limitations 

of the database, such as the small n’s for many classes, lack of testing during start-up and 

shutdown, use of short term testing to represent long term conditions, etc. 

The total releases (Rtotal) are calculated by summing the releases across the 9 largest air 

sources (Ri) which account for over 90% of the total: 

∑=

=

9

i 1

Total RR i (1-6) 

The emissions from each source are computed as the product of the emission factor and activity: 

i

i

RTotal ∑EFi ×= A =

9

1

(1-7) 
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 1-22 DRAFT: DO NOT CITE OR QUOTE

1 where

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

RTotal = Total Releases (g TEQ/year)

EFi = Emission factor for source i (ng TEQ/kg) 

Ai = Activity for source i (kg/year)

The emission factor is calculated on the basis of emission measurements that involve some error. 

Sampling error results from the fact, in general, only a small subset of the total facilities in each 

source class was tested. Measurement error is associated with stack sampling procedures and 

has been estimated to be +/- 30% for dioxins (U.S. EPA, 1990b). Lanier and Hendrix (2001) 

assessed the accuracy of Test Method 23 for stack measurements of PCDD and PCDFs. For 

determination of total PCDD/PCDF mass, the analysis found that RSD varied between about 6.3% 

and 20% for stack concentrations in the range of 2 to 27 ng/dscm. Although activity estimates also 

have uncertainty, it is assumed here that this is negligible compared to the uncertainty in the 

emission factor. The amount of error in estimating the releases from each source is assumed to 

be independent of each other. The variance in releases from each source is estimated using the 

variance of the emission factor data and treating the activity as a constant:

9

2

1

Total i i

i

variance in R variance in EF A =

=∑ × (1-8) 

Generally, the variance estimates for the emission factors were derived using the standard 

equation, i.e. Σ(x - 0)

2

/(n-1). However, in a few cases, some special considerations were 

necessary:

• The emission factor data for forest fires consisted of a series of chamber tests and field 

tests. Given the fundamental differences in the data from these two types of tests, it was 

not considered appropriate to combine them. Instead, the emission factor was estimated 

for each data set and averaged to get the best overall estimate:

EF EF EF = + 0.5( field chamber ) (1-9) 
This document is a draft for review purposes only and does not constitute Agency policy. 

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( ) 2 0.5 field chamber 1 variance in EF variance in EF variance in EF = + (1-10) 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

• In 2000, stack tests were available for all operating municipal waste incinerators and 

cement kilns burning hazardous waste. The total emissions for these two classes were 

estimated by summing the individual emissions from each facility. Thus, an 

emission-factor approach based on a subset of the facilities was not necessary. Because 

all facilities were tested, in theory, there is no sampling error. However, it is recognized 

that factors other than sampling error can contribute to the error in these estimates. 

Therefore, the variance for these sources were estimated and included in the propagation 

of error calculation.

Table 1-19 summarizes the results of this analysis. The analysis concludes that the total 

emissions sum to 2,100 g TEQ/year with a standard deviation of 1,300 g TEQ/year.

Frey and Zhao (2004) demonstrated that probabilistic methods can be used to evaluate 

uncertainties in emission inventories for benzene, formaldehyde, chromium, and arsenic. 

Accordingly, a probabilistic approach was also explored here as discussed below. 

Probabilistic methods for evaluating uncertainty require developing distributions for the 

input variables. Frey and Zhao (2004) fit their emission factor data to parametric distributions 

using maximum likelihood estimation. This is a complex procedure and difficult to apply 

accurately to the emission factor data sets with low n values. Instead, all emission factors were 

assumed to have log normal distributions with means and standard deviations based on an 

arithmetic analysis of the data. Log normal distributions have been found to apply to many types 

of environmental data including emission factors (Frey and Zhao, 2004). A Monte Carlo 

analysis was conducted using the Crystal Ball program. A total of 10,000 simulations were run, 

producing a mean of 2,100 g TEQ and standard deviation of 1,100 g TEQ, which are very similar 

to the results of the propagation-of-error approach described above. Percentiles were estimated 

as 1,100 g TEQ for 10%, 1,800 g TEQ for 50%, and 3,300 g TEQ for 90%. These percentiles 

can be interpreted as the probability that the emissions will less than or equal to the specified 

amount. 

Finally, further analysis is offered on the uncertainties associated with the forest fires. 

These uncertainties are especially important to evaluate because they are the largest source and 

have high uncertainty in the emission factor. As stated above, both chamber studies and field 

studies have been used to measure these emissions. The field data suggest an emission factor of 
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 1-24 DRAFT: DO NOT CITE OR QUOTE

1 0.95 ng TEQ/kg, and the chamber data suggest an emission factor of 7.5 ng TEQ/kg. If the 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

lower emission factor is used, the forest fires would have a release of 230 g TEQ, and the total 

releases across the 9 top sources would be 1,600 g TEQ. Similarly, if the higher emission factor 

is used, the forest fires would have a release of 1,800 TEQ, and the total releases across the 

nine top sources would be 3,200 g TEQ. 

1.3.6.2. Land Releases

 The 2000 land releases were dominated by backyard barrel burning which had releases of 

1,900 g WHO98 TEQ (88% of the total) and the uncertainty analysis was limited to this 

one source. The releases from backyard barrel burning were based on a study by Lemieux 

(1997). Ash samples from the experiments were combined, resulting in two composite samples, 

one for recyclers (2,700 ng WHO98 TEQDF /kg ash) and one for nonrecyclers 

(620 ng WHO98 TEQDF /kg ash). The final emission factor was based on the average of these 

values (1,700 ng WHO98 TEQDF /kg ash). The limited data do not allow a statistical analysis

such as done for the air releases. Instead a potential range of releases was estimated based on the 

lower and upper emission factor estimates. The activity estimate for 2,000 was 1.2 MMT. 

Combining this value with the lower emission factor yields a release estimate of 

740 g WHO98 TEQ. Combining the activity with the higher emission factor yields a release 

estimate of 2,800 g WHO98 TEQ. Accordingly the potential range of releases is 740 to 

2,800 g WHO98 TEQ. Relative to the average value (1,900 g WHO98 TEQ), the lower estimate 

is 62% less and the upper estimate is 46% more. 

1.3.7. Relative Impact of Releases

When comparing national release estimates across sources, it should not be assumed that 

the magnitude of dioxin-like compound emissions is proportional to their impact on human 

health. Human exposure to dioxins occurs primarily via the diet. Therefore, factors such as the 

proximity of sources to food production areas and their location relative to wind direction may 

cause disproportionate impacts from emissions. 
This document is a draft for review purposes only and does not constitute Agency policy. 

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Table 1-1. Nomenclature for dioxin-like compounds

Term/symbol Definition

CDD Chlorinated dibenzo-p-dioxin, halogens substituted in any position

CDF Chlorinated dibenzofuran, halogens substituted in any position

PCB Polychlorinated biphenyl

M Symbol for mono (i.e., one halogen substitution)

D Symbol for di (i.e., two halogen substitution)

Tr Symbol for tri (i.e., three halogen substitution)

T Symbol for tetra (i.e., four halogen substitution)

Pe Symbol for penta (i.e., five halogen substitution)

Hx Symbol for hexa (i.e., six halogen substitution)

Hp Symbol for hepta (i.e., seven halogen substitution)

O Symbol for octa (i.e., eight halogen substitution)

2,3,7,8 Halogen substitutions in the 2,3,7,8-positions

Congener Any one particular member of the same chemical family (e.g., there are 

75 congeners of CDDs)

Congener group Group of structurally related chemicals that have the same degree of chlorination 

(e.g., there are eight congener groups of CDDs, MCDD through OCDD)

Isomer Substances that belong to the same congener group (e.g., 22 isomers constitute the 

congener group of TCDDs)

Specific isomer Isomers denoted by unique chemical notation (e.g., 2,4,8,9-tetrachlorodibenzofuran 

is referred to as 2,4,8,9-TCDF)

MCDD = monochlorinated. 

OCDD = octachlorinated. 

Source: Adapted from U.S. EPA (1989). 
This document is a draft for review purposes only and does not constitute Agency policy. 

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Table 1-2. TEF schemes for CDDs, CDFs, and PCBs

Compound I-TEFs WHO94 WHO98 WHO2005

Chlorinated dibenzo-p-dioxins

2,3,7,8-TCDD 1 1 1

1,2,3,7,8-PeCDD 0.5 1 1

1,2,3,4,7,8-HxCDD 0.1 0.1 0.1

1,2,3,6,7,8-HxCDD 0.1 0.1 0.1

1,2,3,7,8,9-HxCDD 0.1 0.1 0.1

1,2,3,4,6,7,8-HpCDD 0.01 0.01 0.01

OCDD 0.0001 0.0001 0.0003

Chlorinated dibenzofurans

2,3,7,8-TCDF 0.1 0.1 0.1

1,2,3,7,8-PeCDF 0.05 0.05 0.03

2,3,4,7,8-PeCDF 0.5 0.5 0.3

1,2,3,4,7,8-HxCDF 0.1 0.1 0.1

1,2,3,6,7,8-HxCDF 0.1 0.1 0.1

1,2,3,7,8,9-HxCDF 0.1 0.1 0.1

2,3,4,6,7,8-HxCDF 0.1 0.1 0.1

1,2,3,4,6,7,8-HpCDF 0.01 0.01 0.01

1,2,3,6,7,8,9-HpCDF 0.01 0.01 0.01

OCDF 0.0001 0.0001 0.0003
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 1-2. TEF schemes for CDDs, CDFs, and PCBs (continued)

Compound I-TEFs WHO94 WHO98 WHO2005

Polychlorinated Biphenyls

3,3',4,4'-TCB (PCB-77) 0.0005 0.0001 0.0001

3,4,4',5-TCB (PCB-81) 0.0001 0.0003

2,3,3',4,4'-PeCB (PCB-105) 0.0001 0.0001 0.00003

2,3,4,4',5-PeCB (PCB-114) 0.0005 0.0005 0.00003

2,3',4,4',5-PeCB (PCB-118) 0.0001 0.0001 0.00003

2',3,4,4',5-PeCB (PCB-123) 0.0001 0.0001 0.00003

3,3',4,4',5-PeCB (PCB-126) 0.1 0.1 0.1

2,3,3',4,4',5-HxCB (PCB-156) 0.0005 0.0005 0.00003

2,3',4,4',5,5'-HxCB (PCB-157) 0.0005 0.0005 0.00003

2,3',4,4',5,5'-HxCB (PCB-167) 0.00001 0.00001 0.00003

3,3',4,4',5,5'-HxCB (PCB-169) 0.01 0.01 0.03

2,2',3,3',4,4',5-HpCB (PCB-170) 0.0001

2,2',3,4,4',5,5'-HpCB (PCB-180) 0.00001

2,3,3',4,4',5,5'-HpCB (PCB-189) 0.0001 0.0001 0.00003

OCDF = octachlorodibenzofuran.

OCDD = octachlorinated.
This document is a draft for review purposes only and does not constitute Agency policy. 

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Table 1-3. Municipal waste combustorsa 

Categoryb

Stack emission limitc

(ng total CDD/CDF/dscm) Effective date

New, large 13 September 20, 1994d

June 19, 1996e

Existing, large

With electrostatic precipitators as the APCD

With dry scrubber/fabric filters as the APCD

60

30

When SIPs are 

approvedf

New, small 13 June 6, 2001g

Existing, small

With electrostatic precipitators as the APCD

With dry scrubber/fabric filters as the APCD

60

30

When SIPs are 

approvedh

a

Air emission standards promulgated on December 19, 1995.

b

Large = aggregate capacity >225 tons/day; small = aggregate capacity <225 tons/day. c

ng total CDD/CDF/dscm = nanograms total Cl4–Cl8 CDDs plus CDFs per dry standard cubic meter of stack gas 

volume, corrected to 7% O2. d

Began construction on this date. e

Modified or upgraded on this date.

f

When SIPs have been approved by EPA (approximately 3 years from the final rule, or 1998). g

For facilities constructed on or before this date.

h

When SIPs have been approved by EPA (approximately 3 years from the final rule, or 2003).

APCD = air pollution control device.

SIP = State Implementation Plan.
This document is a draft for review purposes only and does not constitute Agency policy. 

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Table 1-4. Hazardous waste combustorsa 

 1 

Source category Standards for new sourcesb Standards for existing sourcesb

Incinerators burning 

hazardous waste 

For an incinerator with dry 

APCD and/or waste heat boiler: 

0.11 ng I-TEQ/dscm

For all other incinerators: 

0.20 ng I-TEQ/dscm

For an incinerator with dry APCD 

and/or waste heat boiler: 

0.20 ng I-TEQ/dscm, or 

0.40 ng I-TEQ/dscm when PM 

control device operated >400°F 

For all other incinerators: 

0.40 ng I-TEQ/dscm

Cement kilns burning 

hazardous waste 

0.20 ng I-TEQ/dscm, or

0.40 ng I-TEQ/dscm when PM 

control device operated >400°F

0.20 ng I-TEQ/dscm, or

0.40 ng I-TEQ/dscm when PM 

control device operated >400°F

Lightweight aggregate 

kilns burning hazardous 

waste

0.20 ng I-TEQ/dscm, or rapid 

quench of combustion gas to 

below 400°F at kiln exit

0.20 ng I-TEQ/dscm, or rapid 

quench of combustion gas to 

below 400°F at kiln exit

Solid fuel boilers 

burning hazardous waste

Either CO of 100 ppmv or HC 

of 10 ppmv

Either CO of 100 ppmv or HC of 

10 ppmv

Liquid fuel boilers 

burning hazardous waste 

For a LFB with dry APCD:

0.40 ng I-TEQ/dscm.

For all other LFBs: 

Either CO of 100 ppmv or HC 

of 10 ppmv

For a LFB with dry APCD:

0.40 ng I-TEQ/dscm.

For all other LFBs: 

Either CO of 100 ppmv or HC of 

10 ppmv

Hydrochloric acid 

production furnaces 

burning hazardous waste

Either CO of 100 ppmv or HC 

of 10 ppmv 

Either CO of 100 ppmv or HC of 

10 ppmv 

a

Air emission standards promulgated October 12, 2005. b

ng I-TEQ/dscm = nanogram I-TEQ per dry standard cubic meter of stack gas volume corrected to 7% O2. 

APCD = Air pollution control device (dry = dry scrubber or fabric filter). 

2 CO = carbon monoxide continuously monitored. 

3 

4 

HC = Total hydrocarbons continuously monitored. 

LFB = Liquid fuel boiler.

PM = Particulate matter. 
This document is a draft for review purposes only and does not constitute Agency policy. 

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Table 1-5. Cement kilns not burning hazardous wastea 

Existing cement kilnsb New cement kilnsb

0.20 ng I-TEQ/dscm and temperature control 

<400ΕF at the APCD inlet

0.40 ng I-TEQ/dscm when PM control device 

operated >400ΕF 

0.20 ng I-TEQ/dscm and temperature control 

<400ΕF at the APCD inlet

0.40 ng I-TEQ/dscm when PM control device 

operated >400ΕF 

a

Air emission standards promulgated on June 14, 1999.

b

ng I-TEQ/dscm = nanograms I-TEQ per dry standard cubic meter of stack gas volume corrected to 7% O2. 

APCD = Air pollution control device. 

PM = Particulate matter. 

Table 1-6. Secondary aluminum smeltersa 

Process Emission standard

Sweat furnace 0.8 ng I-TEQ/dscm stack gas corrected to 7% O2

Thermal chip dryer 2.50 μg I-TEQ per MT of scrap charged to the dryer

Scrap dryer/delacquering kiln/decoating kiln 0.25 g I-TEQ per MT of scrap charged to the kiln

Scrap dryer/delacquering kiln/decoating kiln 

equipped with an afterburner

5.0 g I-TEQ per MT of scrap charged to the kiln

a

Air emission standards promulgated on March 23, 2000.

MT = metric ton.

1 
This document is a draft for review purposes only and does not constitute Agency policy. 

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Table 1-7. Medical waste incineratorsa 

Category

Existing (ng 

WHO2005TEQ/dscm)

New (ng 

WHO2005TEQ/dscm)

Large 0.054 0.035

Medium 0.020 0.014

Small 0.013 0.013

Small rural 2.1

a

Federal Register, 2009.

Table 1-8. Pulp and paper millsa 

1 

Pollutant Maximum 1-day wastewater discharge

Tetrachlorodibenzo-p-dioxin <5 parts per quadrillion

Tetrachlorodibenzofuran 31.9 picograms per liter

a

Effluent limitation guidelines promulgated on April 15, 1998.

Table 1-9. Commercial/Industrial solid waste incineratorsa 

Category

Existing (ng 

WHO2005TEQ/dscm)

New (ng 

WHO2005TEQ/dscm)

Incinerators 0.13 0.13

Energy Recovery Units -

solids

0.059 0.011

Energy Recovery Units –

liquid/gas

0.32 0.002

Waste Burning Kilns 0.0070 0.0030

Small, remote Incinerators 57 31

a

Federal Register, 2011a.
This document is a draft for review purposes only and does not constitute Agency policy. 

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Table 1-10. Sewage sludge incineratorsa

Category

Existing (ng 

WHO2005TEQ/dscm)

New (ng 

WHO2005TEQ/dscm)

Multiple Hearth 0.32 0.0022

Fluidized Bed 0.10 0.0044

a

Federal Register, 2011b.

Table 1-11. Industrial, commercial, and institutional boilers and process heatersa 

Category

Existing (ng 

WHO2005TEQ/dscm)

New (ng 

WHO2005TEQ/dscm)

Coal Stoker 0.003 0.003

Coal Fluidized Bed 0.002 0.002

Pulverized Coal 0.004 0.003

Biomass Stoker/other 0.005 0.005

Biomass Fluidized Bed 0.02 0.02

Biomass Dutch 

Oven/Suspension Burner

0.2 0.2

Biomass Fuel Cells 4 0.003

Biomass Suspension/Grate 0.2 0.2

Liquid 4 0.002

Gas 2 (Other Process Gases) 0.08 0.08

Non-continental liquid 4 0.002

a

Federal Register, 2011c.
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ.

WASTE INCINERATION

Municipal solid waste 

incinerators

1987

1995

2000

9,500

1,200

77

x 

x 

x

x 

x 

x

Hazardous waste 

incinerators

1987

1995

2000

5 

6 

3

x 

x 

x

Industrial boilers burning 

haz. waste

1987

1995

2000

0.8

0.4

0.7

x 

x 

x

Halogen acid furnaces 

burning haz. waste

1987

1995

2000

0.3

0.3

0.3

x 

x 

x
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

Medical waste incinerators

1987

1995

2000

2,700

510

400

 

x 

x 

x 

 

Human crematoria

1987

1995

2000

0.2

0.2

0.3

 

0.1a

0.1a

0.1a

 

Animal crematoria

1987

1995

2000

 

3 

4 

4 

 

Sewage sludge incinerators

1987

1995

2000

6 

14

10

 

x 

x 

x 

 

Tire combustion

1987

1995

2000

 

0.1

0.1

0.5

 

x 

x 

x 

 

Biogas combustion

1987

1995

2000

 

0.2a

0.2a

0.2a

 
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

POWER/ENERGY GENERATION

Leaded gasoline, on-road

1987 50

 

Leaded gasoline, off-road

1987

 

3 

 

Unleaded gasoline, 

on-road

1987

1995

2000

5 

6 

7 

 

Unleaded gasoline, 

off road

1987

1995

2000

 

0.2

0.3

0.4

 

Diesel, on-road 

1987

1995

2000

51

55

64

 

Diesel, off-road 

1987

1995

2000

 

19

20

23

 
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

Indoor residential 

burners

1987

1995

2000

wood 

36

19

15

 

21

11

9 

 

Outdoor wood-fired 

boilers

2000

 

9 

 

Industrial wood 

combustion

1987

1995

2000

78

78

82

 

Commercial and 

residential oil combustion

1987

1995

2000

6 

6 

7 

 

Utility sector and 

industrial oil combustion

1987

1995

2000

19

14

15

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-36 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

Waste oil combustion

1987

1995

2000

 

0.6

0.7

0.7

 

Industrial coal-fired 

utilities

1987

1995

2000

51

60

70

 

17

18

22

 

Industrial coal-fired boilers 

1987

1995

2000

48

46

41

 

x 

x 

x 

 

Residential coal 

combustion

1987

1995

2000

10

5 

3 

 

0.1

0.1

<0.1

 

OTHER HIGH TEMPERATURE SOURCES

Cement kilns burning 

hazardous waste

1987

1995

2000

120

160

19

 

4a

4a

3a

 

x 

x 

x 

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-37 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

Cement kilns not 

hazardous waste

1987

1995

2000

burning 

13

17

17

 

<0.1

<0.1

<0.1

 

x 

x 

x 

 

Lightweight aggregate 

kilns

1987

1995

2000

3a

2a

2 

 

Asphalt mixing plants

1987

1995

2000

5a

5a

5a

 

Petroleum refining catalyst 

regeneration plants 

1987

1995

2000

2 

2 

2 

 

x 

x 

x 

 

Cigarette smoking

1987

1995

2000

1 

0.8

0.7

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-38 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

Carbon reactivation 

furnaces

1987

1995

2000

0.1

0.1

0.1

 

Kraft black liquor recovery 

boilers

1987

1995

2000

2 

2 

0.9

 

Lime kilns

2000 0.1

 

Glass manufacturing

1987

1995

2000 

0.4a

0.4a

0.4a

 

Automobile shredders and 

thermal APCDs at plating 

and painting facilities

1987

1995

2000 

 

x 

x 

x 

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-39 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

MINIMALLY CONTROLLED OR UNCONTROLLED COMBUSTION

Combustion of landfill gas

1987

1995

2000

 

2a

7a

22a

 

Structural fires

1987

1995

2000

 

24

18

16

 

260

200

180

 

x 

x 

x 

 

Vehicle fires—cars and 

other vehicles

1987

1995

2000

 

39a

29a

24a

 

11a

7a

6a

 

x 

x 

x 

 

x 

x 

x 

 

Landfill fires

1987

1995

2000

 

1,300

1,300

1,300

 

Forest and brush fires

1987

1995

2000

180

170

730

 

18a

17a

73a

 

Backyard burning

1987

1995

2000

610

630

600

 

2,000

2,000

2,000

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-40 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

Residential 

1987

1995

2000

yard burning

4 

5 

5 

 

<0.1

<0.1

<0.1

 

Land clearing debris 

burning

1987

1995

2000

 

83

79

85

 

8 

8 

9 

 

Open burning of 

demolition/construction 

wood

1987

1995

2000

 

22

22

22

 

240

240

240

 

Fireworks, underground 

coal fires, open burning of 

energetic materials, PCBs, 

candles, oil spills 

1987

1995

2000 

 

x 

x 

x 

 

x 

x 

x 

 

Sugar cane burning

1987

1995

2000 

 

28

31

35

 

1 

2 

2 

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-41 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

METALLURGICAL PROCESSES

Primary copper smelting 

and refining

1987

1995

2000

0.3a

0.5a

0.5a

 

Primary magnesium 

smelting and refining

1987

1995

2000

13

13

8 

 

x 

x 

x 

 

Primary nickel smelting 

and refining

1987

1995

2000

 

x 

x 

x 

 

x 

x 

 

Primary titanium smelting 

and refining

1987

1995

2000

 

x 

x 

x 

 

x 

x 

x 

 

Secondary aluminum 

smelting

1987

1995

2000

11

20

8 

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-42 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

Secondary zinc production

1987

1995

2000

4a

7a

7a

 

Secondary copper smelting

1987

1995

2000

990

270

0.9

 

Secondary lead smelting

1987

1995

2000 

1 

2 

2 

 

Sinter production

1987

1995

2000

33

28

24

 

Coke production

1987

1995

2000

10a

9a

8a

 

Secondary ferrous 

smelting/refining

1987

1995

2000

metal 

37

46

59

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-43 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

Ferrous foundries

1987

1995

2000

13

19

16

 

Aluminum foundries

1987

1995

2000

 

0.3a

0.3a

0.3a

 

Copper foundries

1987

1995

2000

<0.1a

<0.1a

<0.1a

 

Scrap electric wire 

recovery

1987

1995

2000 

 

x 

x 

x 

 

x 

x 

x 

 

Drum and barrel 

reclamation furnaces

1987

1995

2000

0.6

0.6

0.6

 

x 

x 

x 

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-44 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

CHEMICAL MANUFACTURING/PROCESSING SOURCES

Bleached chemical pulp 

and paper mills

1987

1995

2000

 

14

2 

0.2

 

360

28

1 

 

x 

x 

x 

Stand-alone chlor-alkali 

plants

1987

1995

2000

<0.1a

<0.1a

 

2a

2a

 

Stand-alone 

plants

1987

1995

2000

vinyl chloride 

0.6a

 

<0.1a

 

x 

Complex chemical plants 

producing chlorine and a 

variety of chlorinated 

organics

1987

1995

2000 5 

 

1 

 

25

 

33

29

 

x 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-45 DRAFT: DO NOT CITE OR QUOTE
Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

Municipal wastewater 

treatment plants

1987

1995

2000

 

62

120

50

 

13

12

15

 

3 

18

7 

 

Residential septic systems

1987

1995

2000

 

0.2

0.2

0.3

 

Manufacturing of soaps, 

detergents, textiles, dyes, 

pigments, and inks 

1987

1995

2000 

 

x 

x 

x 

 

All natural processes and 

sources, including ball 

clay, biotransformation, 

etc.

1987

1995

2000

 

x 

x 

x 

 

x 

x 

x 

 

x 

x 

x 

 

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-46 DRAFT: DO NOT CITE OR QUOTE
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-47 DRAFT: DO NOT CITE OR QUOTE

Table 1-12. Summary of CDD/CDF releases for reference years 1987, 1995, and 2000 (g WHO98 TEQDF/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ. Q. Inv. Prelim. NQ

TOTALS 

1987 15,000 1,500 2,400 270 360 13 36

1995 3,400 1,500 2,400 270 30 12 47

2000 2,300 1,500 2,300 330 28 15 7 

a

Results provided in I-TEQ.

x = Releases are possible during this year, but the data are insufficient to develop estimates. 

Q. Inv. = Quantitative Inventory.

Prelim. = Preliminary.

NQ = Not quantified. 

APCD = air pollution control device.

Blanks = No evidence that releases occur.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-48 DRAFT: DO NOT CITE OR QUOTE

Table 1-13. Summary of PCB releases for reference years 1987, 1995, and 2000 (g WHO98 TEQp/year)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ

RELEASES FROM COMMERCIAL PCB PRODUCTS

PCB incineration x x

Accidental fires, leaks, 

and spills

x x x

CHEMICAL MANUFACTURING AND PROCESSING SOURCES

Municipal wastewater 

treatment

1987

1995

2000

51 

78 

19 

2 

12 

3 

COMBUSTION SOURCES

Municipal waste 

combustors 

1987

1995

2000

7 

15

15

Industrial wood 

combustion

x

Medical waste 

incineration

1987

1995

2000

97

18

14

Tire combustion x
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-49 DRAFT: DO NOT CITE OR QUOTE

Table 1-13. Summary of PCB releases for reference years 1987, 1995, and 2000 (g WHO98 TEQp/year) (continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ

Cigarette smoking

1987

1995

2000

<0.1

<0.1

<0.1

Sewage sludge 

incineration

1987

1995

2000

0.4 

1

0.7

Backyard barrel burning

1987

1995

2000

41 

43 

34 

1 

1 

0.8 

Petroleum refining 

catalyst regeneration

x

Hazardous waste 

incineration

x

Power plants x

Forest fires

1987

1995

2000

12

11

49

x
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 1-50 DRAFT: DO NOT CITE OR QUOTE

Table 1-13. Summary of PCB releases for reference years 1987, 1995, and 2000 (g WHO98 TEQp/year) (continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ

METAL REFINING

Iron ore sintering

1987

1995

2000

4 

3 

3

Copper smelting x

Aluminum smelting x

TOTAL

1987

1995

2000

41 

43 

34

120

48

82

52

79

20

2 

12

3 

x = Releases are possible during this year, but the data are insufficient to develop estimates. 

Q. Inv. = Quantitative Inventory. 

Prelim. = Preliminary. 

NQ = Not quantified.

Blanks = No evidence that releases occur.
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 1-51 DRAFT: DO NOT CITE OR QUOTE

Table 1-14. Summary of CDD/CDF reservoir releases (g WHO98 TEQDF) 

Source

Air releases Land releases Water releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ

Soil reservoirs

1987

1995

2000

x 

x 

x

5,000a

4,600a

4,300a

Water, sediment, 

biota reservoirs 

1987

1995

2000

x 

x 

x

x 

x 

x

x

x 

x

Product reservoirs

1987

1995

2000

x 

x 

x

x 

x 

x

x

x

x

a

Includes both urban and rural waters.

x = Releases are possible during this year, but the data are insufficient to develop estimates. 

Q. Inv. = Quantitative Inventory.

Prelim. = Preliminary.

NQ = Not quantified.

Table 1-15. Summary of PCB reservoir releases (g WHO98 TEQP) 

Source

Air releases Land releases Water releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ

Soil reservoirs

1987

1995

2000

x 

x 

x

200a

180a

170a

Water, sediment, 

biota reservoirs 

1987

1995

2000

x 

x 

x

x 

x 

x

x

x 

x

Product reservoirs

1987

1995

2000

x 

x 

x

x 

x 

x

x

x

x

a

Includes rural waters only.

x = Releases are possible during this year, but the data are insufficient to develop estimates. 

Q. Inv. = Quantitative Inventory.

Prelim. = Preliminary.

NQ = Not quantified.
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 1-52 DRAFT: DO NOT CITE OR QUOTE

Table 1-16. Ranking of top five sources by year and media release

1987 releases (g TEQ) 1995 releases (g TEQ) 2000 releases (g TEQ)

Air Municipal waste—9,500

Medical waste—2,700 

2° copper—990 

Backyard barrel—610

Forest—180

Municipal waste incineration—1,200

Backyard barrel—630

Medical waste incineration—510

2° copper—270 

Forest—170

Forest—730

Backyard barrel—600

Medical waste incineration

Industrial wood—82

Municipal waste incineratio

—400

n—77

Land Backyard barrel—2,000

Structure fires—260

Municipal waste 

treatment—62

Residential wood—21

Coal utilities—17

Backyard barrel—2,100

Structure fires—200

Municipal waste treatment—120

Coal utilities—18

Residential wood—11

Backyard barrel—2,000

Structure fires—180

Municipal waste treatment—50

Coal utilities—22

Residential wood—9 

Water Paper mills—360 Paper mills—28

Chlor-alkali plants—2 

Chlorinated organics—25

Chlor-alkali plants—2 

Paper mills—1

Table 1-17. Amounts of CDDs/CDFs (g WHO98 TEQDF/year) contained in 

products in year manufactured

Product 1987 1995 2000

Bleached chemical wood pulp 500 40 0.6

Ethylene dichloride/vinyl chloride NA 0.02 0.02

Chloranila 64b 0.4b 1.2b

Pentachlorophenol 20,000 4,800 4,200

2,4 -Dichlorophenoxy acetic acid (2,4-D)a 33 29 NA

TOTAL 21,000 4,900 4,200

a

Only 2,4-D is considered to be an environmental release. b

Units are I-TEQ.

NA = not available.
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 1-53 DRAFT: DO NOT CITE OR QUOTE

Table 1-18. Trend analyses based on quantitative inventorya 

Releases (g WHO98 TEQ) Percent change

1987 1995 2000 1987 to 1995 1995 to 2000 1987 to 2000

Air 15,000 3,400 2,300 −77 −32 −85

Land 2,400 2,500 2,300 +4 −8 −4

Waterb 360 28 1 −92 −96 −100

Product 36 47 7 +31 −85 −81

Total 18,000 6,000 4,600 −67 −23 −74

a

These trends are based on the quantitative inventory only, i.e., they do not include the sources classified as 

preliminary or unquantifiable. Some of the preliminary sources are potentially very large and if confirmed 

could significantly change the trend observations.

b

Water releases are based on bleached pulp and paper plants only because this is only source covered in all 

three reference years.
This document is a draft for review purposes only and does not constitute Agency policy. 

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Table 1-19. Uncertainty analysis for top nine air sources in 2000 

Activity (kg)

Emission factor

(ng WHO98-TEQ/kg)

Releases

(g WHO98-TEQ)

Total mean n SD Total SD

Forest fires 2.44 × 1011 3 13 4.7 730 1,100

Backyard barrel burning 7.79 × 109 77 5 53 600 410

Medical waste

 Uncontrolled

 Controlled

1.98 × 

4.03 × 

108

108

1,900

51

7 

13

1,600

81

 380 

20

320

33 

Municipal waste 

combustion

105 77 27

Coal fired utility boilers 8.94 × 1011 0.078 11 0.2 70 130

Industrial wood 

 Salt laden

 Nonsalt laden

8.0 × 

1.16 × 

108

1011

15

0.6

5 

9 

11

0.6 

12 

70

8.9

66

Diesel on-road vehicles 1.19 × 1011a 540b 7 240b 64 29

Cement kilns

 Burning haz waste

 Not burning haz waste

 

6.37 × 1010

 

0.27

22

13

 

0.9 

19 

17

7 

55

Industrial coal-fired 

boilers 

5.92 × 1010 0.7 15 1.3 41 78

Total releases 2,100 1,300

a

Units are L.

b

Units are pg WHO98-TEQ/L.
This document is a draft for review purposes only and does not constitute Agency policy. 

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Process Inputs

Solid Residues

Water Discharges

Air Emissions

Landfill Incinerator By-Product

Open

Land

Disposal

Product

Process Inputs and Outputs

Figure 1-1. Process inputs and outputs.
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 2-1 DRAFT: DO NOT CITE OR QUOTE

1 2. MECHANISMS OF FORMATION OF DIOXIN-LIKE COMPOUNDS DURING 

2 

3 

4 

5 

6 

7 

COMBUSTION OF ORGANIC MATERIALS

This chapter has not been updated because it is not critical to the inventory and may be 

best presented elsewhere. Accordingly, any future updates to this chapter will be pursued 

independently from the inventory. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 3. COMBUSTION SOURCES OF CDDS/CDFS: WASTE INCINERATION

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

3.1. MUNICIPAL WASTE COMBUSTION

3.1.1. Air Releases

More information was available for the municipal waste incinerators than any other 

source, allowing a detailed approach for estimating the total emissions. Stack test data were 

available for 11 of 111 facilities in 1987, 27 of 125 facilities in the 1995, and 78 of 105 facilities 

in 2000. These data were used to develop emission factors for over 20 design classes based on 

the combination of furnace type and air pollution controls. Additionally, a complete list of all 

facilities operating in the reference years and their activity levels were available. Releases from 

the tested facilities were derived directly from the stack tests, and the releases from the untested 

facilities were derived by assigning it an emission factor and multiplying by the activity. Finally, 

the total releases for each reference year were estimated by summing the releases from each 

facility operating in that year. 

This approach is a modification of the approach used in the 2006 report. Emission 

factors were changed for a few design classes to make them more consistent, and new tables 

were developed for each reference year that list each facility and its emission factor, activity 

level, and emission rate (see Tables 3-1, 3-2, and 3-3). This led to some minor changes in total 

emissions.

The releases for the year 2000 were also estimated using the UNEP (2005) emission 

factors: 

• Low technology, no APCD―35,000 ng I-TEQ/kg

• Controlled, minimal APCD―350 ng I-TEQ/kg

• Controlled, good APCD―30 ng I-TEQ/kg

• High technology, sophisticated APCD―0.5 ng I-TEQ/kg

The emission factor for controlled facilities with good APCDs (30 ng I-TEQ/kg) was 

applied to all small incinerators (defined as those with operating capacities less than 250 tons/day 

and totaling 2.6 million tons in 2000), and the emission factor for high technology facilities with 

sophisticated APCDs (0.5 ng I-TEQ/kg) was applied to all large facilities (defined as those with 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 3-2 DRAFT: DO NOT CITE OR QUOTE

1 operating capacities greater than 250 tons/day and totaling 27 million tons in 2000). This 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

approach yields a release estimate of 92 g I-TEQ/year, which is comparable to the 

69 g I-TEQDF/year estimate reported here based on adding emissions of each facility. 

3.1.2. Water Releases

Some municipal waste combustors use wet scrubbers to treat emissions. Water 

discharges may be associated with such devices. Some of these facilities have water treatment 

systems that reduce particulate levels (and associated dioxins) prior to discharge. No 

information was found to estimate the magnitude of CDD/CDF releases from these devices. 

Accordingly, releases are possible, but estimates could not be made (Not quantifiable). 

3.1.3. Solid Residue Releases

In the United States, all municipal waste combustor ash (except the portion used in 

products―see discussion below) is disposed in permitted landfills. As defined in this inventory, 

landfilled material does not represent a release to the open environment and is not included in the 

source inventory. However, for informational purposes and when sufficient information is 

available, this document provides estimates of the amounts of ash landfilled. The discussion 

below presents estimates of the amount of dioxin in municipal waste ash sent to landfills.

Municipal waste combustors create solid residues in the form of fly ash, which is 

collected from the stack by APCDs, and bottom ash, which is discharged directly from the 

combustor. As discussed in EPA (2006), a variety of studies have measured dioxin levels in 

municipal waste combustor ash from the United States. Only two of these provided congener 

data allowing TEQ calculations:

• Ashes from five state-of-the-art municipal waste combustor facilities located in different 

regions of the United States were analyzed for all 2,3,7,8-substituted CDDs/CDFs. The 

TEQ levels in the ash (fly ash mixed with bottom ash) ranged from 106 to 

466 ng I-TEQDF/kg, with a mean value of 258 ng I-TEQDF/kg CDFs (U.S. EPA, 1990a). 

• Washington State Department of Ecology (1998) reported CDD/CDF congener data for 

ash and other solid residuals from three municipal incinerators (Fort Lewis, Bellingham 

[municipal plus medical wastes], and Spokane). The data were compiled and evaluated 

to determine a total I-TEQ concentration and loading. The results showed fly ash ranging 

from 0.51 to 4.98 μg I-TEQ/kg, bottom ash ranging from 0.00 to 0.2 μg I-TEQ/kg, and 

mixed ash ranging from 0.038 to 0.163 μg I-TEQ/kg. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 EPA (2006) also summarized municipal waste combustor ash information from a variety of 

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studies conducted in other countries, with two reporting TEQ calculations:

• Kobylecki et al. (2001) analyzed the reduction of dioxins in fly ash by pelletizing the ash 

and reburning the pellets in a laboratory-scale bubbling fluidized-bed furnace. Fly ash 

for the test input material was collected from a fly ash filter vessel during 4 days of 

municipal waste combustor operation. The total TEQ value derived by Kobylecki was 

862 ng I-TEQDF/kg of fly ash.

• Sakai et al. (2001) analyzed the levels of dioxins and PCBs in fly ash and bottom ash 

from a newly constructed municipal waste combustor in Japan. TEQ values derived from 

the data give a total of 423 ng I-TEQDF/kg for fly ash and 10.5 ng I-TEQDF/kg for bottom 

ash for dioxins and 31.6 ng I-TEQDF/kg for fly ash and 0.85 ng I-TEQDF/kg for bottom 

ash for PCBs.

UNEP (2005) provided emission factors for fly ash ranging from 15 to 500 μg I-TEQ/MT of 

municipal solid waste burned and emission factors for bottom ash ranging from 1.5 to 

75 μg I-TEQ/MT of municipal solid waste burned. For municipal waste combustors with 

controlled combustion and good APCD (this class would be typical of many of the U.S. 

facilities), the recommended values were 200 μg I-TEQ/MT of municipal solid waste burned for 

fly ash and 7 μg I-TEQ/MT of municipal solid waste burned for bottom ash. 

Given the very limited data on TEQ levels in ash from U.S. facilities, it was decided to 

use the UNEP (2005) default recommendations as follows: the UNEP recommendations for 

municipal waste combustors with controlled combustion and minimal APCDs 

(200 μg I-TEQ/MT of municipal solid waste burned for fly ash and 7 μg I-TEQ/MT of municipal 

solid waste burned for bottom ash) were assumed to apply to 1987. Extensive improvements in 

APCDs (including reductions in the use of hot-sided electrostatic precipitators ESPs) occurred 

from 1987 to 1990. So reductions would also be expected in the dioxin content of the ash. Thus, 

the UNEP recommendations for municipal waste combustors with controlled combustion and 

good APCDs (15 μg I-TEQ/MT of municipal solid waste burned for fly ash and 

1.5 μg I-TEQ/MT of municipal solid waste burned for bottom ash) were assumed to apply to 

1995 and 2000. These assumptions are summarized below: 

• 1987―200 ng I-TEQ/kg of municipal solid waste burned for fly ash and 7 ng I-TEQ/kg 

of municipal solid waste burned for bottom ash 
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1 • 1995―15 ng I-TEQ/kg of municipal solid waste burned for fly ash and 1.5 ng I-TEQ/kg 

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of municipal solid waste burned for bottom ash 

• 2000―15 ng I-TEQ/kg of municipal solid waste burned for fly ash and 1.5 ng I-TEQ/kg 

of municipal solid waste burned for bottom ash 

Multiplying the emission factors by the total municipal waste activity levels, yielded the 

following estimates of amount of dioxin in landfilled ash: 

• 1987―2,800 g I-TEQ 

• 1995―490 g I-TEQ 

• 2000―490 g I-TEQ 

As indicated earlier, in the United States, all municipal waste combustor ash (except the portion 

used in products—see discussion below) is disposed in permitted landfills and, therefore, not 

included in the source inventory. 

The amount of ash generated by municipal waste incineration is not directly used in the 

procedure described above to estimate the amount of dioxin in landfilled ash. However, this 

may be of interest and is estimated here for informational purposes only. An estimated 7 MMT 

of total ash (bottom ash plus fly ash) were generated by municipal waste combustors in 1992 

(telephone conversation between J. Loundsberry, EPA Office of Solid Waste, and L. Brown, 

Versar, Inc., February 24, 1993). EPA indicated that 2 to 5 MMT of total ash were produced 

annually in the late 1980s from municipal waste combustors, with fly ash comprising 5 to 15% 

of the total (U.S. EPA, 1991). UNEP (2005) indicates that the amount of fly ash generated per 

ton of municipal solid waste is typically 1−2%, and the amount of bottom ash generated per ton 

of municipal solid waste is approximately 10−20%. The amounts of ash generated were 

calculated using the midpoints of these ranges:

• 1987―The total municipal solid waste burned was estimated as 13.7 billion kg (this 

implies that 0.2 billion kg of fly ash and 2.1 billion kg of bottom ash were generated). 

• 1995―The total municipal solid waste burned was estimated as 29.8 billion kg (this 

implies that 0.4 billion kg of fly ash and 4.5 billion kg of bottom ash were generated). 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 • 2000―The total municipal solid waste burned was estimated as 29.4 billion kg (this 

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implies that 0.4 billion kg of fly ash and 4.4 billion kg of bottom ash were generated). 

3.1.4. Products

The primary purpose of municipal waste combustors is waste disposal rather than the 

manufacture of products. However, some municipal waste combustor ash has been used in 

road-building materials (UNEP, 2005). The concentration of CDD/CDFs in these products 

would be a fraction of the level found in the original residues. For example, if the product 

contained 1% municipal waste combustor residues, the CDD/CDF concentration would be 1% of 

the level found in the original residue. No information could be found on the residue content of 

these products. Similarly, no information could be found on the quantity of ash going into such 

products. It is possible that the ash is tightly bound to the construction materials, reducing the 

chance of release to the open environment. However, no data could be found on this issue. 

Accordingly, releases are probably small, but estimates could not be made (Not quantifiable). 

3.1.5. Release Summary

The inventory decision criteria and release estimates to all media are summarized below.

Inventory Decision Criteria for Municipal Waste Incinerators

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
This document is a draft for review purposes only and does not constitute Agency policy.

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Municipal Waste Incinerators

Air Releases

Emission Factors 

• 1987―Table 3-1. 

• 1995―Table 3-2. 

• 2000―Table 3-3.

Activity Levels

• 1987―Table 3-1 (overall total is 13.7 billion kg of waste). 

• 1995―Table 3-2 (overall total is 29.8 billion kg of waste). 

• 2000―Table 3-3 (overall total is 29.4 billion kg of waste).

Releases

• 1987―Table 3-1. Total 

• 1995―Table 3-2. Total 

• 2000―Table 3-3. Total 

releases were 9,500 g WHO98 TEQDF/yr (8,500 g I-TEQDF/yr). 

releases were 1,200 g WHO98 TEQDF/yr (1,100 g I-TEQDF/yr). 

releases were 77 g WHO98 TEQDF/yr (69 g I-TEQDF/yr).

Water Releases

Water releases are possible, but data are insufficient to make quantitative estimates (Not 

quantifiable). 

Solid Residue Releases

All municipal waste combustor ash (except the portion used in products—see below) is disposed 

in permitted landfills. As defined in this inventory, landfilled material does not represent a 

release to the open environment and is not included in the source inventory. 

Products

Product releases are possible, but data are insufficient to make

quantifiable). 

quantitative estimates (Not 

1 3.2. HAZARDOUS WASTE INCINERATION

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Hazardous wastes are burned in a variety of situations and are covered in a number of 

different sections in this report. 

• Hazardous waste is burned in facilities dedicated to burning this type of waste. Most of 

these dedicated facilities are located on site at chemical manufacturing facilities and burn 

only the waste associated with their on-site industrial operations. Hazardous waste is also 

burned at dedicated facilities located off site. These facilities accept waste from multiple 

sources. On- and off-site dedicated hazardous waste burning facilities are addressed in 

Section 3.2.1. 

• Hazardous waste is also burned in industrial boilers and furnaces that are permitted to 

burn the waste as supplemental fuel. These facilities have significantly different furnace 

designs and operations than those of dedicated hazardous waste incinerators (HWIs). 

They are discussed in Section 3.2.2. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 • Hazardous waste is also burned in halogen acid furnaces (HAFs), in which halogen acids 

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(such as HCl) may be produced from halogenated secondary materials. These facilities 

are discussed in Section 3.2.3. 

• A number of cement kilns and lightweight aggregate kilns are also permitted to burn 

hazardous waste as auxiliary fuel. These are discussed separately in Section 5.1. 

• Mobile HWIs are typically used for site cleanup at Superfund sites. These units can be 

transported from one location to another and operate for a limited duration at any given 

location. Due to a lack of information about these facilities, they are not included in this 

inventory. 

3.2.1. Dedicated HWIs

3.2.1.1. Air Releases

No changes were made in the air-release estimates reported in U.S. EPA (2006). Where 

feasible, this document subdivides the combustors in each source category into design classes 

judged to have similar potential for CDD/CDF emissions. However, this would not have been 

useful for dedicated HWIs because information was lacking about the amount of waste burned in 

each of the design classes. Additionally, all HWI designs achieve excellent combustion 

efficiency using high temperatures and long residence times, suggesting that little difference in 

emission factors would be observed among the design classes. Minor changes in design and 

operating procedures would be expected in 2000 due to the stricter emission limits that became 

effective at that time. Therefore, the strategy used to develop emission factors for HWIs was to 

assume that the emission tests conducted prior to 2000 represented facilities in operation during 

the reference years 1987 and 1995 and the emission tests conducted in 2000 represented the 

facilities operating in 2000. 

The emission factors were developed using stack test data from a database compiled by 

the EPA Office of Solid Waste (OSW). This database summarizes the results of stack testing for 

CDDs/CDFs at a number of HWIs between 1993 and 2000 (U.S. EPA, 2002b). For the purposes 

of estimating emissions in 1995, an emission factor was developed using data from 17 HWIs 

tested between 1993 and 1996. For the purposes of estimating emissions in 2000, an emission 

factor was developed using data from 10 HWIs tested in 2000 (a total of 22 HWIs were tested in 

2000, but flue gas flow rates were available for only 10 of these incinerators). For the purposes 

of estimating emissions in 1987, the emission factor derived for 1995 was assumed to apply to 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 1987. The 1987 activity estimate is from Dempsey and Oppelt (1993), and the 1995/2000 

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estimate is based on Federal Register (1996). 

The emission factors assumed here were in the range of 2−4 ng I-TEQ/kg, which falls in 

between the values recommended by UNEP (2005) for the top two performing classes: 

• Low technology, no APCD―35,000 ng I-TEQ/kg

• Controlled, minimal APCD―350 ng I-TEQ/kg

• Controlled, good APCD―10 ng I-TEQ/kg

• High technology, sophisticated APCD―0.75 ng I-TEQ/kg

3.2.1.2. Water Releases

Many HWIs use wet scrubber systems, which can have water discharges. However, no 

information was found to support release estimates (Not quantifiable). 

3.2.1.3. Solid Residue Releases 

 EPA (1987) contains limited data on ash generated from hazardous waste incineration. 

The study indicates that the mean concentrations of CDDs and CDFs from an HWI with an 

afterburner were 538 μg/kg and 2,853 μg/kg, respectively (Table 3-8 in U.S. EPA, 1987). 

Specific data for congeners and for ash quantities were not provided. Accordingly, quantitative 

estimates cannot be made about amounts of CDD/CDFs in solid residues from dedicated HWIs. 

In the United States, all HWI ash is disposed in permitted landfills. As defined in this inventory, 

landfilled material does not represent a true release to the open environment and is not included 

in the source inventory. 

3.2.1.4. Products―None
This document is a draft for review purposes only and does not constitute Agency policy.

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1 3.2.1.5. Release Summary

2 

3 

The inventory decision criteria and releases are summarized below:

Inventory Decision Criteria for Dedicated HWIs

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors.

Measured emission factors consistent or have Yes

understandable differences.

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

Dedicated HWIs

Air Releases

Emission Factors 

• 1987―3.9 ng WHO98 TEQDF/kg (3.8 ng I-TEQDF/kg) of waste feed. 

• 1995―3.9 ng WHO98 TEQDF/kg (3.8 ng I-TEQDF/kg) of waste feed. 

• 2000―2.1 ng WHO98 TEQDF/kg (2.1 ng I-TEQDF/kg) of waste feed.

Activity Levels

• 1987―1.3 billion kg. 

• 1995―1.5 billion kg. 

• 2000―1.5 billion kg. 

Releases

• 1987―5 g (WHO98 TEQDF or I-TEQDF). 

• 1995―6 g WHO98 TEQDF (5.7 g I-TEQDF). 

• 2000―3 g WHO98 TEQDF (3 g I-TEQDF).

Water Releases

Possible, but data are insufficient to make quantitative estimates (Not quantifiable).

Solid Residue Releases

Ash is landfilled, so it is not considered an environmental release.

Products

None.
This document is a draft for review purposes only and does not constitute Agency policy.

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1 3.2.2. Industrial Boilers and Furnaces Burning Hazardous Waste 

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3.2.2.1. Air Releases

The emission factors for industrial boilers and furnaces burning hazardous waste were 

derived from test data for three facilities presented in the OSW database. Minor changes in 

design and operating procedures would be expected in 2000 due to the stricter emission limits 

that became effective at that time. Therefore, the strategy used to develop emission factors for 

these facilities was to assume that the emission tests conducted prior to 2000 represented 

facilities in operation during the reference years 1987 and 1995 and the emission tests conducted 

in 2000 represented the facilities operating in 2000. The activity level used in US EPA, 2006 

(derived from survey data in Dempsey and Oppelt, 1993 and other OSW data) for 2000 was 

changed from 1.5 to 0.6 billion kg based on the assumption that no change occurred from 1995. 

As a result, minor changes were also made in the air-release estimate for reference year 2000.

3.2.2.2. Water Releases

Some industrial boilers use wet scrubber systems, which can have water discharges. 

However, no information was found to support release estimates (Not quantifiable). 

3.2.2.3. Solid Residue Releases 

Because these facilities are typically burning liquid waste, little ash would be generated.

3.2.2.4. Products―None

3.2.2.5. Release Summary

The releases are summarized below:
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1 

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Inventory Decision Criteria for Industrial Boilers and Furnaces Burning Hazardous Waste

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

Industrial Boilers and Furnaces Burning Hazardous Waste

Air Releases

Emission Factors 

• 1987―0.65 ng WHO98 TEQDF/kg (0.64 ng I-TEQDF/kg) of waste feed. 

• 1995―0.65 ng WHO98 TEQDF/kg (0.64 ng I-TEQDF/kg) of waste feed. 

• 2000―1.2 ng WHO98 TEQDF/kg (1.2 ng I-TEQDF/kg) of waste feed.

Activity Levels

• 1987―1.2 billion kg. 

• 1995―0.6 billion kg. 

• 2000―0.6 billion kg.

Releases

• 1987―0.8 g WHO98 TEQDF (0.8 g I-TEQDF). 

• 1995―0.4 g WHO98 TEQDF (0.4 g I-TEQDF). 

• 2000―0.7 g WHO98 TEQDF (0.7 g I-TEQDF).

Water Releases

Possible, but data are insufficient to make quantitative estimates (Not quantifiable).

Solid Residue Releases

None.

Products

None.
This document is a draft for review purposes only and does not constitute Agency policy.

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1 3.2.3. Halogen Acid Furnaces Burning Hazardous Waste

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3.2.3.1. Air Releases

No changes were made to the air-release estimates. The emission factors for halogen 

acid furnaces (HAFs) burning hazardous waste were derived from the same OSW database used 

for dedicated HWIs. For the purposes of estimating emissions in 2000, an emission factor was 

developed using data from two HAFs tested in 2000. For the purposes of estimating emissions 

in 1987 and 1995, the emission factor derived for 2000 was assumed to apply to the earlier years. 

The activity estimate was based on survey data provided by OSW for 2000 and assumed to be 

also representative of the earlier years.

3.2.3.2. Water Releases

 No information was found to support release estimates.

3.2.3.3. Solid Residue Releases 

Because these facilities are typically burning liquid waste, no ash would be generated. 

3.2.3.4. Products―None

3.2.3.5. Release Summary

The inventory decision criteria and releases are summarized below:

Inventory Decision Criteria for Halogen Acid Furnaces Burning Hazardous Waste

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors.

Measured emission factors consistent or have Yes

understandable differences.

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
This document is a draft for review purposes only and does not constitute Agency policy.

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Halogen Acid Furnaces Burning Hazardous Waste

Air Releases

Emission Factors 

• 1987―0.84 ng WHO98 TEQDF/kg (0.80 ng I-TEQDF/kg) of waste feed. 

• 1995―0.84 ng WHO98 TEQDF/kg (0.80 ng I-TEQDF/kg) of waste feed. 

• 2000―0.84 ng WHO98 TEQDF/kg (0.80 ng I-TEQDF/kg) of waste feed.

Activity Levels

• 1987―376 million kg. 

• 1995―376 million kg. 

• 2000―376 million kg.

Releases

• 1987―0.3 g WHO98 TEQDF (0.3 g I-TEQDF). 

• 1995―0.3 g WHO98 TEQDF (0.3 g I-TEQDF). 

• 2000―0.3 g WHO98 TEQDF (0.3 g I-TEQDF). 

Water Releases

Possible, but data are insufficient to make quantitative estimates (Not quantifiable).

Solid Residue Releases

None.

Products

None.

 

1 3.3. MEDICAL WASTE INCINERATION

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3.3.1. Air Releases

 Changes were made to the emission factors. The U.S. EPA, 2006 report divided the 

uncontrolled class into two subclasses and the controlled class into three subclasses. Some of 

these classes had very few tested facilities, and the range of emission factors overlapped between 

subclasses. Thus, it was decided to combine these classes into one emission factor for 

uncontrolled facilities (1,870 ng WHO98 TEQ/kg, 1,760 ng I-TEQ/kg) based on testing at 

seven facilities and one for controlled facilities (51 ng WHO98 TEQ/kg, 50 ng I-TEQ/kg) based 

on testing at 12 facilities. For comparison purposes, the UNEP (2005) emission factor 

recommendations are provided below:

• Uncontrolled, batch, no APCD―40,000 ng I-TEQ/kg

• Controlled, batch, minimal APCD―3,000 ng I-TEQ/kg

• Controlled, batch, good APCD―525 ng I-TEQ/kg

• Controlled, continuous, excellent APCD―1 ng I-TEQ/kg
This document is a draft for review purposes only and does not constitute Agency policy.

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1 Activity estimates are based on survey data summarized in U.S. EPA, 2006. Table 3-4 

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shows the activities and release estimates for each year. These changes resulted in small 

increases in total releases compared to the original values reported in U.S. EPA, 2006. 

3.3.2. Water Releases

Some medical waste incinerators use wet scrubber systems, which can have water 

discharges. However, no information was found to support release estimates (Not quantifiable). 

3.3.3. Solid Residue Releases

In the United States, all ash from medical waste incinerators is disposed in permitted 

landfills. As defined in this inventory, landfilled material does not represent a true release to the 

open environment and is not included in the source inventory. However, for informational 

purposes, the discussion below presents estimates of the amount of dioxin in landfilled ash. 

Fiedler et al. (2002) tested a hospital waste incinerator in Thailand. The furnace had a 

static grate and was equipped with a secondary combustion chamber and two afterburners. The 

flue gases passed over an alkaline water bath before being discharged through a flue stack. 

Overall, the plant appeared poorly designed and poorly maintained. Bottom ash concentrations 

of 1,390 and 1,980 ng -TEQ/kg were found. The authors suggest the high results were due to the 

poor combustion conditions in the primary chamber and the practice of leaving the bottom ashes 

overnight in the chamber to slowly cool down. 

As indicated above, emission testing data could be located for only one facility. The poor 

condition of this facility suggests it is not representative of U.S. facilities. UNEP (2005) 

suggests emission factors ranging from 150 to 920 ng I-TEQ/kg of waste burned (for combined 

bottom ash and fly ash) for controlled facilities. The average of this range is assumed for all 

reference years: 530 ng I-TEQDF/kg of waste. These UNEP recommendations are not linked to 

specific references and appear to represent the professional judgment and consensus among the 

authors. It is unknown how representative this emission factor is of U.S. facilities. Accordingly, 

it is regarded as preliminary. 
This document is a draft for review purposes only and does not constitute Agency policy.

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The amounts of dioxin in landfilled ash were estimated by multiplying the emission 

factor by the activity level:

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• 1987―760 g I-TEQDF 

• 1995―410 g I-TEQDF

• 2000―320 g I-TEQDF

Because the ash is landfilled, it is not considered a release to the open environment and is not 

included in the source inventory. 

The total amount of landfilled ash is not directly used in the calculation above. However, 

it may be of interest and is provided below for information purposes only. The estimates were 

generated by assuming that the combined fly and bottom equals 20% of the waste feed (UNEP, 

2005). This yields the following estimates:

• 1987―0.28 billion kg 

• 1995―0.15 billion kg

• 2000―0.12 billion kg

3.3.4. Products―None

3.3.5. Release Summary

The inventory decision criteria and releases to all media are summarized below:

Inventory Decision Criteria for Medical Waste Incinerators

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Yes

Activity estimates based on source-specific surveys.

Conclusion (Q = Quantitative, P = Preliminary). Q
This document is a draft for review purposes only and does not constitute Agency policy.

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Medical Waste Incinerators

Air Releases

Emission Factors 

• 1987―Table 3-4.

• 1995―Table 3-4. 

• 2000―Table 3-4.

Activity Levels

• 1987―Table 3-4. 

• 1995―Table 3-4. 

• 2000―Table 3-4.

Releases

• 1987―2,700 g WHO98 TEQDF/yr (2,600 g I-TEQDF/yr). 

• 1995―510 g WHO98 TEQDF/yr (490 g I-TEQDF/yr). 

• 2000―400 g WHO98 TEQDF/yr (380 g I-TEQDF/yr).

Water Releases

Possible, but data are insufficient to make quantitative estimates (Not quantifiable).

Solid Residue Releases

The ash is landfilled so it is not considered an environmental release.

Products

None.

1 3.4. CREMATORIA

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3.4.1. Human Crematoria 

3.4.1.1. Air Releases

No changes were made to the air-release estimates. The emission factor was derived on 

the basis of testing at two U.S. facilities and assumed to apply to all reference years. It 

corresponds to the low end of the range recommended by UNEP (2005): 

400 ng I-TEQ/cremation for facilities with optimal control, 10,000 ng I-TEQ/cremation for 

facilities with medium control, and 90,000 ng I-TEQ/cremation for facilities with no control. 

Activity information was derived from CANA (2006). 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 3.4.1.2. Water Releases

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These facilities do not use wet scrubbers, and there are no other identifiable water 

releases associated with their operation.

3.4.1.3. Solid Residue Releases

 No information was found on the disposition of cremation ash. It is assumed here that all 

of it is eventually released to the open environment. 

UNEP (2005) recommends an ash emission factor of 2,500 ng I-TEQ/cremation for 

facilities with medium or optimal control. The CDD/CDF concentrations in the bottom ashes 

collected from a two-chamber crematory in Thailand were 44 and 48 ng I-TEQ/kg of bottom ash 

(UNEP, 2005; Fiedler et al., 2002). Based on the average of these tests, a concentration of 

46 ng I-TEQ/kg of bottom ash is assumed for each reference year. This facility appears to have a 

similar design to U.S. facilities. However, the emission factor was assigned a preliminary rating 

because it is based on testing at only one facility. 

The total bottom ash generated was estimated by multiplying the number of bodies 

cremated per year (CANA, 2006), 5.5% ash content (Forbes et al., 1953), and 70 kg (average 

adult body weight). This yields the following estimates:

• 1987―1.24 million kg

• 1995―1.88 million kg

• 2000―2.42 million kg

The solid residue releases were estimated by multiplying the ash concentration by the ash 

activity level.

3.4.1.4. Products―None

3.4.1.5. Release Summary

The inventory decision criteria and releases are summarized below. The ash is typically 

disposed in landfills and therefore not considered an environmental release. 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 3-18 DRAFT: DO NOT CITE OR QUOTE

Inventory Decision Criteria for Human Crematoria

Air Water Solids Products

Emission tests for at least two units/source types with Yes No

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes Yes

understandable differences. 

Emission factor tests represent units that are typical of the Yes Yes

class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q P
This document is a draft for review purposes only and does not constitute Agency policy.

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Human Crematoria

Air Releases

Emission Factors 

• 1987―450 

• 1995―450 

• 2000―450

ng WHO98

ng WHO98

ng WHO98

TEQDF/body cremated (430

TEQDF/body cremated (430

TEQDF/body cremated (430

ng I-TEQDF/body cremated). 

ng I-TEQDF/body cremated). 

ng I-TEQDF/body cremated). 

Activity Levels

• 1987―A total of 323,371 cremations were performed.

• 1995―A total of 488,224 cremations were performed.

• 2000―A total of 629,362 cremations were performed.

Releases

• 1987―0.2 

• 1995―0.2 

• 2000―0.3

g WHO98

g WHO98

g WHO98

TEQDF

TEQDF

TEQDF

(0.1 g I-TEQDF). 

(0.2 g I-TEQDF). 

(0.3 g I-TEQDF).

Water Releases

None.

Solid Residue Releases

Emission Factors

• 1987―46 ng 

• 1995―46 ng 

• 2000―46 ng 

I-TEQ/kg

I-TEQ/kg

I-TEQ/kg

of ash

of ash

of ash

(Preliminary). 

(Preliminary). 

(Preliminary).

Activity Levels

• 1987―1.24 million kg

• 1995―1.88 million kg

• 2000―2.42 million kg

ash. 

ash. 

ash.

Releases

• 1987―0.1 g I-TEQDF

• 1995―0.1 g I-TEQDF

• 2000―0.1 g I-TEQDF

(Preliminary). 

(Preliminary). 

(Preliminary).

Products

None.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 3-20 DRAFT: DO NOT CITE OR QUOTE

1 3.4.2. Animal Crematoria

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29 

30 

3.4.2.1. Air Releases

Minor changes were made in how these air releases were estimated. For destruction of 

animal carcasses, UNEP (2005) recommends emission factors of 5 ng I-TEQ/kg for state-of-theart facilities, 50 ng I-TEQ/kg for updated facilities, and 500 ng I-TEQ/kg for uncontrolled 

facilities. As described in EPA, 2006, only one U.S. facility emission test could be located. This 

facility had very low emissions and may not be representative of most facilities. The mid-range 

value recommend by UNEP was judged to more likely represent typical U.S. facilities. 

Therefore, this emission factor was assumed to apply to each of the reference years: 

50 ng I-TEQDF/kg of animal cremated. Based on the limited test data and questions about its 

representativeness, this emission factor is considered a preliminary estimate. 

 As part of the 2000 inventory, OAQPS (U.S. EPA, 2002b) calculated a national animal 

cremation activity level estimate of 81.9 million kg/year for reference year 2000. Assuming that 

the fraction of the population owning pets and the fraction of pets cremated stay reasonably 

constant, this value can be extrapolated to the other reference years by assuming that animal 

cremation rates are proportional to the human population. The following U.S. population 

estimates were used in this exercise: 1987―242 billion, 1995―263 billion, and 

2000―291 billion. The data for each reference year are presented below: 

• 1987―68 million kg/year. 

• 1995―74 million kg/year

• 2000―81.9 million kg/year

3.4.2.2. Water Releases―None

3.4.2.3. Solid Residue Releases

All ash from these facilities is assumed to be disposed in permitted landfills. As defined 

in this inventory, landfilled material does not represent a true release to the open environment 

and is not included in the source inventory. However, for informational purposes, the discussion 

below presents estimates of the amount of dioxin in landfilled ash. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 As indicated above, emission testing data could be located for only one facility. No 

2 

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25 

26 

27 

28 

29 

30 

bottom ash testing was reported for this facility. It has a similar design to the human cremation 

facility in Thailand where testing found 44 and 48 ng I-TEQ/kg of bottom ash (UNEP, 2005; 

Fiedler et al., 2002). Based on the average of these tests, an bottom ash concentration of 

46 ng I-TEQ/kg is assumed for all reference years. It is completely unknown how representative 

this facility is of U.S. facilities. Accordingly, it must be regarded as preliminary. 

The total bottom ash generated was estimated by multiplying the mass of animals 

cremated per year (see above) and 5.5% ash content (value for humans from Forbes et al., 1953). 

This yields the following estimates:

• 1987―3.7 million kg 

• 1995―4.1 million kg 

• 2000―4.5 million kg 

These estimates are considered preliminary because they are derived from Class D-rated 

estimates for mass of animals cremated.

The amounts of dioxin in landfilled ash were estimated by multiplying the bottom ash 

concentration by the ash activity level:

• 1987―0.17 g I-TEQDF (Preliminary)

• 1995―0.19 g I-TEQDF (Preliminary)

• 2000―0.21 g I-TEQDF (Preliminary)

The ash from these facilities is assumed to be landfilled and, therefore, is not considered a 

release to the open environment. 

3.4.2.4. Products―None

3.4.2.5. Release Summary

The inventory decision criteria and releases are summarized below:

 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 3-22 DRAFT: DO NOT CITE OR QUOTE

Inventory Decision Criteria for Animal Crematoria

Air Water Solids Products

Emission tests for at least two units/source types with No

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of No

the class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P

Animal Crematoria

Air Releases

Emission Factors 

• 1987―50 ng I-TEQDF/kg of animal cremated (Preliminary). 

• 1995―50 ng I-TEQDF/kg of animal cremated (Preliminary). 

• 2000―50 ng I-TEQDF/kg of animal cremated (Preliminary).

Activity Levels

• 1987―68 million kg/yr. 

• 1995―74 million kg/yr. 

• 2000―81.9 million kg/yr.

Releases

• 1987―3 g I-TEQDF (Preliminary). 

• 1995―4 g I-TEQDF (Preliminary). 

• 2000―4 g I-TEQDF (Preliminary).

Water Releases

None.

Solid Residue Releases

This ash is landfilled and, therefore, is not considered an environmental release.

Products

None.
This document is a draft for review purposes only and does not constitute Agency policy.

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1 3.5. SEWAGE SLUDGE INCINERATION

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27 

28 

29 

30 

31 

3.5.1. Air Releases

No changes were made to the air-release estimates. The emission factor of 6.7 ng 

WHO98 TEQDF/kg was derived from testing at 14 U.S. facilities and applied to all three reference 

years. UNEP (2005) recommends emission factors of 0.4 ng I-TEQ/kg for state-of-art facilities 

and 4 ng I-TEQ/kg for updated facilities with controls. The emission factor used here is similar 

to the UNEP recommendation for updated facilities with controls. The activity estimates were 

derived from survey data summarized in EPA, 2006. 

3.5.2. Water Releases

Because some sewage sludge incinerators use wet scrubber systems, it is possible that 

water discharges occur. However, wastewater from wet scrubbers is often treated and then 

reintroduced to the wastewater treatment plant, so that no water discharges occur directly from 

the incinerator (in these cases, the CDD/CDFs in the effluent would likely end up in the sewage 

sludge). As discussed below, some limited information is available on dioxin levels in scrubber 

water. No information is available on quantities of scrubber effluent from U.S. facilities or what 

portion is recycled back to the wastewater treatment operation. Therefore, releases are possible, 

but no quantitative estimates could be made (Not quantifiable). 

 In Table 5-16 of EPA (1987), data are presented indicating that 2,3,7,8-TCDD was not 

detected in scrubber water filtrate from three sewage sludge incinerators. However, total CDDs 

for the three incinerators averaged 0.3 ng/kg, and total CDFs averaged 4 ng/kg. No data were 

given for any congeners (other than 2,3,7,8-TCDD), nor were there any data on the quantities of 

filtrate.

 The European inventory (EU, 1999) reports concentrations between 1.2 and 

6.5 pg I-TEQ/L in scrubber effluents from sewage sludge incinerators. 

3.5.3. Solid Residue Releases

All ash from these facilities is assumed to be disposed in permitted landfills. As defined 

in this inventory, landfilled material does not represent a true release to the open environment 

and is not included in the source inventory. However, for informational purposes, the discussion 

below presents estimates of the amount of dioxin in landfilled ash. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 Testing of multiple hearth furnaces in the United Kingdom (Dyke et al., 1997) showed 

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22 

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24 

25 

26 

27 

28 

29 

CDD/CDF in the grate ash at concentrations of 39 ng TEQ/kg and 470 ng TEQ/kg in fly ash 

from the ESP. Rates of ash production were 430 kg/ton of grate ash and 13 kg/ton of ESP ash 

for the multiple hearth plant. Levels in ash (all the ash was collected in the ESP) from fluidized 

bed combustion were much lower (<1 ng TEQ/kg); 373 kg of ESP ash were produced per ton of 

sludge combusted in the fluidized bed. 

 In Table 5-16 of EPA (1987), data are presented indicating that 2,3,7,8-TCDD was not 

detected in the bottom ash from three sewage sludge incinerators. However, total CDDs for the 

three incinerators were nondetects, 20 ng/kg, and 10 ng/kg. For total CDFs, the values were 

nondetects, 70 ng/kg, and 50 ng/kg. No data were given for any congeners (other than 

2,3,7,8-TCDD), nor were there any data on the quantities of ash. 

 UNEP (2005) recommends default residue emission factors of 0.5 ng I-TEQ/kg of 

sewage sludge for updated and modern furnaces. This was adopted for all reference years. This 

is considered a preliminary (Class D) estimate because there were no U.S. data and very limited 

European data to support it. 

 No data on ash generation rates were found. Rather, the activity was based on the annual 

amount of sewage sludge incinerated—see the discussion above. 

The amounts of dioxin in landfilled ash were estimated by multiplying the emission 

factor by the activity level:

• 1987―0.43 g I-TEQDF (Preliminary)

• 1995―1.0 g I-TEQDF (Preliminary)

• 2000―0.71 g I-TEQDF (Preliminary)

The ash from these facilities is assumed to be landfilled and, therefore, is not considered a 

release to the open environment. 

3.5.4. Products―None
This document is a draft for review purposes only and does not constitute Agency policy.

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1 3.5.5. Release Summary

2 

3 

The inventory decision criteria and releases to all media are summarized below:

Inventory Decision Criteria for Sewage Sludge Incinerators

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes

the class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

Sewage Sludge Incinerators

Air Releases

Emission Factors 

• 1987―6.7 ng WHO98 TEQDF/kg (6.6 ng I-TEQDF/kg). 

• 1995―6.7 ng WHO98 TEQDF/kg (6.6 ng I-TEQDF/kg). 

• 2000―6.7 ng WHO98 TEQDF/kg (6.6 ng I-TEQDF/kg).

Activity Levels

• 1987―0.865 billion kg of dry sewage sludge. 

• 1995―2.11 billion kg of dry sewage sludge. 

• 2000―1.42 billion kg of dry sewage sludge.

Releases

• 1987―6 g WHO98 TEQDF (6 g I-TEQDF). 

• 1995―14 g WHO98 TEQDF (14 g I-TEQDF). 

• 2000―10 g WHO98 TEQDF (9 g I-TEQDF).

Water Releases

Possible but quantitative releases could not be made (Not quantifiable).

Solid Residue Releases

The ash from these facilities is assumed to be landfilled and, therefore, is not considered a 

release to the open environment.

Products

None.
This document is a draft for review purposes only and does not constitute Agency policy.

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1 3.6. TIRE COMBUSTION

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25 

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27 

28 

29 

30 

31 

This section covers releases from dedicated tire incinerators. Tires are also burned in 

cement kilns, which are covered in Section 5.1. Some are combusted as auxiliary fuel in 

industrial boilers and in pulp and paper mill combustion facilities, but the amount of tires going 

to these types of facilities is assumed to be negligible (note that emissions from industrial boilers 

are covered in Sections 3.2 and 4.3, and emissions from pulp and paper mills are covered in 

Sections 3.7 and 8.1). Additionally, tires may be unintentionally burned in an uncontrolled 

fashion at landfills (open burning). The open burning of tires is not discussed in this report due 

to the lack of information, and, thus, is an unquantifiable source. 

3.6.1. Air Releases

No changes were made to the air-release estimates. The emission factor of 0.28 ng 

WHO98 TEQDF/kg was derived from testing at one facility that was equipped with a dry scrubber 

and fabric filter (CARB, 1991). Because other facilities may be equipped with less sophisticated 

air pollution control systems, the TEQ emissions could be higher. For example, Cains and Dyke 

(1994) reported much higher emission rates for two tire incinerators in the United Kingdom that 

were equipped with only simple grit arrestors. Because the emission factor is based on testing at 

only one facility and it is inconsistent with other data, the release estimate is considered 

preliminary. The activity estimates were derived from survey data from EPA, (1992b) and 

Rubber Manufacturers Association (RMA) (2002). 

3.6.2. Water Releases

Some tire combustion facilities may have wet scrubbers indicating that water releases are 

possible. No information could be found on CDD/CDF levels in effluent or amounts of effluent 

discharged from these facilities. Therefore, releases are possible but could not be quantified (Not 

quantifiable). 

3.6.3. Solid Residue Releases 

Both bottom ash and fly ash can be created from tire combustion. No information could 

be found on CDD/CDF levels in ash or amounts of ash associated with these facilities. Any ash 

would be landfilled, and therefore, would not be considered an environmental release. 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 3-27 DRAFT: DO NOT CITE OR QUOTE

1 

2 

3 

4 

5 

3.6.4. Products―None

3.6.5. Release Summary

 The inventory decision criteria and releases are summarized below:

 

Inventory Decision Criteria for Tire Combustion

Air Water Solids Products

Emission tests for at least two units/source types with No

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have No

understandable differences. 

Emission factor tests represent units that are typical of the No

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 3-28 DRAFT: DO NOT CITE OR QUOTE

Tire Combustion

Air Releases

Emission Factors 

• 1987―0.28 ng WHO98 TEQDF/kg (0.28 ng I-TEQDF/kg) (Preliminary). 

• 1995―0.28 ng WHO98 TEQDF/kg (0.28 ng I-TEQDF/kg) (Preliminary). 

• 2000―0.28 ng WHO98 TEQDF/kg (0.28 ng I-TEQDF/kg) (Preliminary).

Activity Levels

• 1987―0.385 billion kg. 

• 1995―0.385 billion kg. 

• 2000―1.8 billion kg.

Releases

• 1987―0.1 g WHO98 TEQDF/yr (0.1 g I-TEQDF/yr) (Preliminary). 

• 1995―0.1 g WHO98 TEQDF/yr (0.1 g I-TEQDF/yr) (Preliminary). 

• 2000―0.5 g WHO98 TEQDF/yr (0.5 g I-TEQDF/yr) (Preliminary).

Water Releases

Possible but quantitative releases could not be made (Not quantifiable).

Solid Residue Releases

Ash generated at these facilities is landfilled and, therefore, not considered an environmental 

release.

Products

None.

1 3.7. COMBUSTION OF WASTEWATER SLUDGE AT BLEACHED CHEMICAL 

2 

3 

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6 

7 

8 

9 

10 

11 

PULP MILLS

Approximately 20.5% of the wastewater sludges generated at bleached chemical pulp 

mills are dewatered and burned in bark boilers at the mills (NCASI, 1995). These sludges can 

contain CDDs/CDFs and elevated levels of chloride (NCASI, 1995). However, the sludges 

generally make up less than 10% of the total feed to the boilers. Most of the feed is composed of 

wood residues. On this basis, it is believed that the dioxin emission estimates derived in 

Section 4.2.2 for industrial wood-burning facilities include emissions from boilers burning 

wastewater sludges generated at bleached chemical pulp mills. 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 3-29 DRAFT: DO NOT CITE OR QUOTE

1 3.8. BIOGAS COMBUSTION

2 

3 

4 

5 

6 

No changes were made to the release estimates. The emission factor was derived from 

testing at one facility in Germany and was considered preliminary. The activity was derived 

from data on the amount of sewage sludge generated and assumptions about how much gas is 

generated from the sludge. No other water, solid residue, or product releases occur from this 

source. The inventory decision criteria and releases are summarized below: 

Inventory Decision Criteria for Biogas Combustion

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission 

factors.

No

Measured emission factors consistent or have Yes

understandable differences.

Emission factor tests represent units that are typical of 

the class.

Yes

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P
This document is a draft for review purposes only and does not constitute Agency policy.

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Biogas Combustion

Air Releases

Emission Factors 

• 1987―0.46 ng I-TEQDF/Nm3 of digester gas combusted (Preliminary). 

• 1995―0.46 ng I-TEQDF/Nm3 of digester gas combusted (Preliminary). 

• 2000―0.46 ng I-TEQDF/Nm3 of digester gas combusted (Preliminary).

Activity Levels

3 • 1987―467-million Nm

3 • 1995―467-million Nm

3 • 2000―467-million Nm

(Preliminary). 

(Preliminary). 

(Preliminary).

Releases

• 1987―0.2 g I-TEQDF/yr (Preliminary). 

• 1995―0.2 g I-TEQDF/yr (Preliminary). 

• 2000―0.2 g I-TEQDF/yr (Preliminary).

Water Releases

None.

Solid Residue Releases

None.

Products

None.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

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Table 3-1. Inventory of municipal waste combustors (MWCs) in 1987 

Designa class

APCDb 

Facility

name

City

located State

Activity levelc

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ 

EFe (ng/kg)

Annual air emissions 

(g/y)

I-TEQDF

WHO98

TEQDF

MBWW

H-ESP

1 Pinellas Co. Pinellas Co. FL 5.63E+08 478 535 269 301

2 St. Petersburg St. Petersburg FL 3.24E+08 478 535 155 173

3 Tampa Tampa FL 2.82E+08 478 535 135 151

4 Chicago Chicago IL 4.51E+08 478 535 216 241

5 North Andover North Andover MA 4.22E+08 Actual tested stack emissions 200 224

6 Saugus Saugus MA 4.22E+08 478 535 202 226

7 Baltimore (RESCO) Baltimore MD 6.34E+08 478 535 303 339

8 Wilmington Wilmington NC 5.63E+07 478 535 27 30

9 Glen Cove Glen Cove NY 7.04E+07 478 535 34 38

10 Westchester Co. Peekskill NY 6.34E+08 Actual tested stack emissions 44 47

11 Tulsa Tulsa OK 2.11E+08 478 535 101 113

12 Harrisburg Harrisburg PA 2.03E+08 Actual tested stack emissions 147 167

13 Philadelphia E. Philadelphia PA 2.11E+08 Actual tested stack emissions 100 112

14 Philadelphia NW Philadelphia PA 2.11E+08 478 535 101 113

15 Nashville Thermal Nashville TN 3.16E+08 478 535 151 169

16 Hampton WTE Hampton VA 5.63E+07 Actual tested stack emissions 27 30

17 Harrisonburg Harrisonburg VA 2.82E+07 478 535 13 15

18 Norfolk Norfolk NAS VA 1.01E+08 Actual tested stack emissions 222 251

H-ESP subtotals 5.20E+09 2,450 2,740
Table 3-1. Inventory of municipal waste combustors (MWCs) in 1987 (continued)

Annual air emissions 

a Design class

APCDb 

Facility

name

City

located State

Activity levelc

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ 

EFe (ng/kg)

(g/y)

I-TEQDF

WHO98

TEQDF

MBWW 19 Marion Co. Brooks OR 1.55E+08 0.67 0.72 0.1 0.1

DS/FF

DS/FF subtotals 1.55E+08 0.1 0.1

Totals For Mass Burn Waterwall 5.35E+09 2,450 2,740

MB/REF

H-ESP

20 Stamford I Stamford CT 5.63E+07 473 554 27 31

21 Stamford II Stamford CT 1.01E+08 473 554 48 56

22 Washington Washington DC 2.82E+08 473 554 133 156

23 Baltimore (Pulaski) Baltimore MD 3.38E+08 Actual tested stack emissions 160 179 

24 Clinton Clinton Township MI 1.69E+08 473 554 80 94

25 Brooklyn (Henry 

St.)

Brooklyn NY 2.82E+08 473 554 133 156

26 Brooklyn (SW) Brooklyn NY 2.11E+08 473 554 100 117

27 Betts Avenue Queens NY 2.82E+08 473 554 133 156 

28 Euclid Euclid OH 5.63E+07 473 554 27 31

29 Ogden Layton UT 1.27E+08 473 554 60 70

30 Portsmouth Portsmouth VA 4.51E+07 473 554 21 25 

31 Waukesha Waukesha WI 4.93E+07 473 554 23 27

H-ESP subtotals 2.00E+09 945 1,100

MB/REF

WS

32 New Canaan New Canaan CT 3.04E+07 236 254 7 8 

33 Louisville Louisville KY 2.82E+08 236 254 66 72

34 Shreveport Shreveport LA 5.63E+07 236 254 13 14

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

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This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-33 DRAFT: DO NOT CITE OR QUOTE

Table 3-1. Inventory of municipal waste combustors (MWCs) in 1987 (continued)

Annual air emissions 

a Design class

APCDb 

Facility

name

City

located State

Activity levelc

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ 

EFe (ng/kg)

(g/y)

I-TEQDF

WHO98

TEQDF

MB/REF

WS (continued)

35 Fall River Fall River MA 1.69E+08 236 254 40 43 

36 S.E. Oakland Co. Auburn Hills MI 1.69E+08 236 254 40 43 

37 Huntington Huntington NY 1.27E+08 236 254 30 32

38 Sheboygan Sheboygan WI 6.76E+07 236 254 16 17

WS subtotals 9.01E+08 212 229

MB/REF

DS/FF

39 Framingham Framingham MA 1.41E+08 0.67 0.72 0.1 0.1

DS/FF subtotals 1.41E+08 0.1 0.1

Totals For Mass Burn Refractory 3.04E+09 1,160 1,330

MOD/SA

H-ESP

40 Sitka Sitka AK 7.04E+06 79 85.7 0.6 0.6

41 Tuscaloosa Tuscaloosa AL 8.45E+07 79 85.7 6.7 7.2

42 Purham Purham MN 2.25E+07 79 85.7 1.8 1.9

43 Red Wing Red Wing MN 2.03E+07 Actual tested stack emissions 0.1 0.1

44 Savage Savage MN 1.69E+07 79 85.7 1.3 1.5 

45 Pascagoula Moss Point MS 4.22E+07 79 85.7 3.3 3.6

46 Oswego Co. Fulton NY 5.63E+07 79 85.7 4.5 4.8

47 Oneida Co. Rome NY 5.63E+07 Actual tested stack emissions 4.5 4.8

48 Hampton Hampton SC 7.60E+07 79 85.7 6.0 6.5

49 Cleburne Clebume TX 3.24E+07 79 85.7 2.6 2.8 

50 Barron Co. Almena WI 2.25E+07 79 85.7 1.8 1.9

H-ESP subtotals 4.37E+08 33 36
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-34 DRAFT: DO NOT CITE OR QUOTE

Table 3-1. Inventory of municipal waste combustors (MWCs) in 1987 (continued)

a Design class

APCDb 

Facility

name

City

located State

Activity levelc

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ 

EFe (ng/kg)

Annual air emissions 

(g/y)

I-TEQDF

WHO98

TEQDF

MOD/SA

UNC

51 Batesville Batesville AR 1.41E+07 16.2 17 0.2 0.2

52 Blytheville Blytheville AR 1.97E+07 16.2 17 0.3 0.3

53 Hope Hope AR 1.07E+07 16.2 17 0.2 0.2

54 Hot Springs Hot Springs AR 2.82E+07 16.2 17 0.5 0.5

55 North Little Rock North Little Rock AR 2.82E+07 16.2 17 0.5 0.5

56 Osceola Osceola AR 1.41E+07 16.2 17 0.2 0.2

57 Stuttgart Stuttgart AR 1.69E+07 16.2 17 0.3 0.3

58 Cassia Co. Burley ID 1.41E+07 16.2 17 0.2 0.2

59 Simpson Co. Simpson Co. KY 2.17E+07 16.2 17 0.3 0.4

60 Harpswell Harpswell ME 3.94E+06 16.2 17 0.1 0.1

61 Fort Leonard Wood Fort Leonard Wood MO 2.11E+07 16.2 17 0.3 0.4

62 Livingston Park Co. MT 2.11E+07 16.2 17 0.3 0.4

63 Wrightsville Wrightsville NC 1.41E+07 16.2 17 0.2 0.2

64 Auburn Auburn NH 1.41E+06 16.2 17 <0.1 <0.1

65 Candia Candia NH 4.22E+06 16.2 17 0.1 0.1

66 Canterbury Canterbury NH 2.82E+06 16.2 17 0.1 0.1

67 Durham Durham NH 3.04E+07 16.2 17 0.5 0.5

68 Groveton Groveton NH 6.76E+06 16.2 17 0.1 0.1

69 Litchfield Litchfield NH 6.20E+06 16.2 17 0.1 0.1

70 Meredith Meredith NH 8.73E+06 16.2 17 0.1 0.2

MOD/SA 71 Nottingham Nottingham NH 2.25E+06 16.2 17 <0.1 <0.1
Table 3-1. Inventory of municipal waste combustors (MWCs) in 1987 (continued)

Annual air emissions 

a Design class

APCDb 

UNC (continued)

Facility

name

City

located State

Activity levelc

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ 

EFe (ng/kg)

(g/y)

I-TEQDF

WHO98

TEQDF

72 Pittsfield Pittsfield NH 1.35E+07 16.2 17 0.2 0.2

73 Wilton Wilton NH 8.45E+06 16.2 17 0.1 0.1

74 Wolfeboro Wolfeboro NH 4.51E+06 16.2 17 0.1 0.1

75 Cattaraugus Co. Cuba NY 3.15E+07 16.2 17 0.5 0.5

76 Skaneateless Skaneateless NY 3.66E+06 16.2 17 0.1 0.1

77 Miami Miami OK 3.04E+07 16.2 17 0.5 0.5

78 Johnsonville Johnsonville SC 1.41E+07 16.2 17 0.2 0.2

79 Dyersburg Dyersburg TN 2.82E+07 16.2 17 0.5 0.5 

80 Carthage City Carthage City TX 1.01E+07 16.2 17 0.2 0.2

81 Center Center TX 1.01E+07 16.2 17 0.2 0.2

82 Gatesville Gatesville TX 5.63E+06 16.2 17 0.1 0.1

83 Newport News Newport News VA 9.86E+06 16.2 17 0.2 0.2

84 Salem Salem VA 2.82E+07 16.2 17 0.5 0.5 

85 Bellingham Bellingham WA 2.82E+07 16.2 17 0.5 0.5

UNC subtotals 5.17E+08 8.5 8.9 

MOD/SA

WS

86 Collegeville Collegeville MN 1.41E+07 16.2 17 0.2 0.2

87 Lewisburg Lewisburg TN 1.69E+07 16.2 17 0.3 0.3

88 Palestine Palestine TX 7.89E+06 16.2 17 0.1 0.1

89 Waxahachie Waxahachie TX 1.41E+07 16.2 17 0.2 0.2

WS subtotals 5.30E+07 0.8 0.8 

MOD/SA 90 Windham Windham CT 3.04E+07 16.2 17 0.5 0.5

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-35 DRAFT: DO NOT CITE OR QUOTE
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-36 DRAFT: DO NOT CITE OR QUOTE

Table 3-1. Inventory of municipal waste combustors (MWCs) in 1987 (continued)

FF

a Design class

APCDb 

Facility

name

City

located State

Activity levelc

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ 

EFe (ng/kg)

Annual air emissions 

(g/y)

I-TEQDF

WHO98

TEQDF

91 Auburn Auburn ME 5.63E+07 16.2 17 0.9 1.0

92 Portsmouth Portsmouth NH 5.63E+07 16.2 17 0.9 1.0

FF subtotals 1.43E+08 2.3 2.5 

Totals For Modular-Starved Air 1.15E+09 44 48

MOD/EA

UNC

93 Mayport Mayport NAS FL 1.35E+07 16.2 17 0.2 0.2

94 Bellingham Bellingham WA 2.82E+07 16.2 17 0.5 0.5

UNC subtotals 4.17E+07 0.7 0.7

MOD/EA

WS

95 East Chicago East Chicago IN 1.27E+08 16.2 17 2.1 2.2

WS subtotals 1.27E+08 2.1 2.2

MOD/EA

EGB

96 Pittsfield Pittsfield MA 6.76E+07 0.67 0.72 0.1 0.1

EGB subtotals 6.76E+07 0.1 0.1

Totals For Modular Excess Air 2.36E+08 2.8 2.9

RDF/Co

H-ESP

97 Lakeland Lakeland FL 8.45E+07 231 231 20 20

98 Ames Ames IA 5.63E+07 231 231 13 13

H-ESP subtotals 1.41E+08 33 33 

Totals For Refuse Derived Fuel Cofired With Coal 1.41E+08 33 33 

RDF/Ded

H-ESP

99 Dade Co. Miami FL 8.45E+08 1,490 1,680 1,260 1,420

100 Honolulu Honolulu HI 1.69E+08 1,490 1,680 252 284

101 Haverhill Lawrence MA 3.66E+08 Actual tested stack emissions 546 615

102 Albany Albany NY 1.69E+08 1,490 1,680 252 284

103 Niagara Falls Niagara NY 6.20E+08 1,490 1,680 924 1,040

104 Akron Akron OH 2.82E+08 1,490 1,680 420 473
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-37 DRAFT: DO NOT CITE OR QUOTE

Table 3-1. Inventory of municipal waste combustors (MWCs) in 1987 (continued)

Annual air emissions 

a Design class

APCDb

Facility

name

City

located State

Activity levelc

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ 

EFe (ng/kg)

(g/y)

I-TEQDF

WHO98

TEQDF

105 Columbus Columbus OH 5.63E+08 Actual tested stack emissions 840 946

H-ESP subtotals 3.01E+09 4,490 5,060

RDF/Ded

WS

106 Duluth Duluth MN 1.13E+08 236 254 27 29 

107 St. Louis St. Louis MO 2.25E+08 236 254 53 53

WS subtotals 3.38E+08 80 82 

Totals for refuse-derived fuel―dedicated 3.49E+09 4570 5140

MB/RK

H-ESP

108 N. Dayton Dayton OH 1.69E+08 478 535 81 90

109 S. Dayton Dayton OH 1.69E+08 478 535 81 90

110 Gallatin Gallatin TN 5.63E+07 478 535 27 30

H-ESP subtotals 3.94E+08 189 210

MB/RK

FF

111 Galax Galax VA 1.58E+07 47 93.1 0.7 1.5

FF subtotals 1.58E+07 0.7 1.5

Totals for mass burn rotary kiln 4.10E+08 190 212

TOTALS FOR ALL MWCs operating in 1987 1.37E+10 8450 9510
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-38 DRAFT: DO NOT CITE OR QUOTE

Table 3-1. Inventory of municipal waste combustors (MWCs) in 1987 (continued)

a

MWC Design class: FB/RDF = Fluidized-bed refuse-derived fuel; MB/WW = Mass burn waterwall; MB/RK = Mass burn rotary kiln; MB/REF = Mass burn 

refractory walled; MOD/EA = Modular excess air; RDF/Ded = Dedicated refuse-derived fuel; RDF/co = Refuse-derived fuel cofired with coal (slash indicates 

devices used in conjunction).

b

APCD = air pollution control device. This includes DS/FF (dry scrubber with fabric filters); H-ESP (hot-sided electrostatic precipitator); EGB (electrified 

gravel bed); WS (wet scrubber); FF (fabric filter); UNC = uncontrolled or no APCD. c

Activity Level is the annual amount (kg) of municipal solid waste or refuse derived fuel expected to be combusted by the MWC. It is estimated by multiplying 

the annual design capacity of the furnace by 85%. The figure of 85% represents the assumption that the MWC will experience downtime during the year for 

maintenance and repairs.

d

The I-TEQDF Emission Factor (EF) expressed in units of ng TEQ/kg combusted. e

The WHO98 TEQDF Emission Factor (EF) expressed in units of ng TEQ/kg combusted. 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-39 DRAFT: DO NOT CITE OR QUOTE

Table 3-2. Inventory of municipal waste combustors (MWCs) in 1995 

a Design class

APCDb 

Facility

name

City

located State

Activity 

levelc 

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ EFe

(ng/kg)

Annual air emissions 

(g/y)

I-TEQDF

WHO98

TEQDF

MB/WW

DS/FF

1 Huntsville RRF Huntsville AL 1.94E+08 0.67 0.72 0.1 0.1

2 Long Beach RRF Long Beach CA 3.89E+08 0.67 0.72 0.3 0.3

3 Commerce RRF Commerce CA 1.07E+08 Actual tested stack emissions 0.1 0.1

4 Modesto RRF Crows Landing CA 2.25E+08 Actual tested stack emissions 0.1 0.2

5 Bridgeport RESCO Bridgeport CT 6.34E+08 0.67 0.72 0.4 0.5

6 Convanta SECONN Preston CT 1.69E+08 0.67 0.72 0.1 0.1

7 Bristol RRF Bristol CT 1.83E+08 0.67 0.72 0.1 0.1

8 Mid-Conn RRF Hartford CT 5.63E+08 0.67 0.72 0.4 0.4

9 Pasco Co. Hudson FL 2.96E+08 0.67 0.72 0.2 0.2

10 Broward Co. S Fort Lauderdale FL 6.34E+08 0.67 0.72 0.4 0.5

11 Broward Co. N Fort Lauderdale FL 6.34E+08 0.67 0.72 0.4 0.5

12 Lake Co. RRF Okahumpka FL 1.49E+08 0.67 0.72 0.1 0.1

13 Savannah RRF Savannah GA 1.41E+08 0.67 0.72 0.1 0.1

14 Indianapolis RRF Indianapolis IN 6.65E+08 Actual tested stack emissions 0.7 0.7

15 Saugus RESCO Saugus MA 4.22E+08 Actual tested stack emissions 0.3 0.3

16 Kent Co. RRF Grand Rapids MI 1.76E+08 0.67 0.72 0.1 0.1

17 Jackson Co. Jackson MI 5.63E+07 0.67 0.72 <0.1 <0.1 

18 New Hanover Wilmington NC 7.01E+07 0.67 0.72 0.1 0.1

19 Gloucester Co. Westville NJ 1.62E+08 0.67 0.72 0.1 0.1

20 Warren Energy RRF Oxford 

Township

NJ 1.13E+08 0.67 0.72 0.1 0.1
Table 3-2. Inventory of municipal waste combustors (MWCs) in 1995 (continued)

a Design class

APCDb 

Facility

name

City

located State

Activity 

levelc 

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ EFe

(ng/kg)

Annual air emissions 

(g/y)

I-TEQDF

WHO98

TEQDF

MB/WW

DS/FF

(continued)

21 Onondaga Co. Onondaga NY 2.79E+08 0.67 0.72 0.2 0.2

22 Babylon RRF Babylon NY 2.11E+08 Actual tested stack emissions 0.3 0.3

23 Hempstead Westbury NY 7.06E+08 Actual tested stack emissions 0.1 0.1

24 Marion Co. Brooks OR 1.55E+08 Actual tested stack emissions <0.1 <0.1 

25 Montgomery Co. Conshohocken PA 3.38E+08 0.67 0.72 0.2 0.2

26 Lancaster Co. Bainbridge PA 3.38E+08 0.67 0.72 0.2 0.2

27 I-95 Energy RRF Lorton VA 8.45E+08 Actual tested stack emissions 0.9 1.0

28 Spokane Regional Spokane WA 2.25E+08 0.67 0.72 0.2 0.2

29 Skagit Co. RRF Mount Vernon WA 5.01E+07 0.67 0.72 <0.1 <0.1 

DS/FF subtotals 9.13E+09 6.3 6.8

MB/WW

C-ESP

30 Pinellas Co. St. Petersburg FL 8.45E+08 Actual tested stack emissions 5.2 5.5

31 Hillsborough Co. Tampa FL 3.38E+08 6.1 6.54 2.1 2.2

32 McKay Bay Tampa FL 2.82E+08 6.1 6.54 1.7 1.8

33 Southernmost RRF Key West FL 4.22E+07 6.1 6.54 0.3 0.3

34 Olmstead RRF Rochester MN 5.63E+07 6.1 6.54 0.3 0.4

35 Westchester RESCO Peekskill NY 6.34E+08 6.1 6.54 3.9 4.1

36 Walter B. Hall RRF Tulsa OK 3.17E+08 6.1 6.54 1.9 2.1

37 Nashville Thermal Nashville TN 2.96E+08 6.1 6.54 1.8 1.9

C-ESP subtotals 2.81E+09 17 18

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-40 DRAFT: DO NOT CITE OR QUOTE
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-41 DRAFT: DO NOT CITE OR QUOTE

Table 3-2. Inventory of municipal waste combustors (MWCs) in 1995 (continued)

a Design class

APCDb 

Facility

name

City

located State

Activity 

levelc 

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ EFe

(ng/kg)

Annual air emissions 

(g/y)

I-TEQDF

WHO98

TEQDF

MB/WW

DS/C-ESP

38 Millbury Millbury MA 4.22E+08 6.1 6.54 2.6 2.8

39 Greater Portland Portland ME 1.41E+08 Actual tested stack emissions 1.4 1.5

40 Covanta Haverhill Haverhill MA 4.65E+08 6.1 6.54 2.8 3.0

41 New Hanover Wilmington NC 5.63E+07 6.1 6.54 0.3 0.4

42 Essex Co. RRF Newark NJ 6.41E+08 6.1 6.54 3.9 4.2

43 Camden RRF Camden NJ 2.96E+08 Actual tested stack emissions 0.7 0.8

44 Adirondack RRF Hudson Falls NY 1.22E+08 6.1 6.54 0.7 0.8

45 Charleston RRF Charleston SC 1.69E+08 Actual tested stack emissions 1.0 1.1

DS/C-ESP subtotals 2.73E+09 13 15

MB/WW

DSI/FF

46 SES Claremont RRF Claremont NH 5.63E+07 Actual tested stack emissions 0.2 0.2

47 Concord Concord NH 1.41E+08 1.9 2.07 0.3 0.3

DSI/FF subtotals 1.97E+08 0.5 0.5

MB/WW

DS/CI/FF

48 Hennepin Energy Minneapolis MN 3.38E+08 1.5 1.61 0.5 0.5

49 Union Co. RRF Rahway NJ 4.06E+08 1.5 1.61 0.6 0.7

50 Wheelabrator Falls Falls Creek PA 4.22E+08 Actual tested stack emissions 0.6 0.7

DS/CI/FF subtotals 1.17E+09 1.7 1.9

MB/WW

H-ESP

51 University City RRF Charlotte NC 6.62E+07 478 535 32 35

52 Long Beach RRF Long Beach NY 5.63E+07 478 535 27 30

53 Harrisburg WTE Harrisburg PA 2.03E+08 Actual tested stack emissions 147 167

54 NASA RRF Hampton VA 5.63E+07 Actual tested stack emissions 27 30
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-42 DRAFT: DO NOT CITE OR QUOTE

Table 3-2. Inventory of municipal waste combustors (MWCs) in 1995 (continued)

Annual air emissions 

a Design class

APCDb 

Facility

name

City

located State

Activity 

levelc 

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ EFe

(ng/kg)

(g/y)

I-TEQDF

WHO98

TEQDF

MB/WW

H-ESP

(continued)

55 Harrisonburg RRF Harrisonburg VA 2.82E+07 Actual tested stack emissions 5.8 5.9

56 Baltimore (RESCO) Baltimore MD 6.34E+08 Actual tested stack emissions 9.9 11

H-ESP subtotals 1.04E+09 249 279

MB/WW

DSI/H-ESP

57 North Andover North Andover MA 4.22E+08 Actual tested stack emissions 3.3 3.5

DSI/H-ESP subtotals 4.22E+08 3.3 3.5 

MB/WW

DSI/CI/H-ESP

58 Alexandria RRF Alexandria VA 2.75E+08 Actual tested stack emissions 2.1 2.3

DSI/CI/H-ESP subtotals 2.75E+08 2.1 2.3 

Totals for mass burn waterwall 1.74E+10 293 327 

MB/REF

WS

59 New Canaan MWC New Canaan CT 3.52E+07 236 254 8.3 9.0

60 Fall River Fall River MA 1.69E+08 236 254 40 43

Subtotals for MB/REF WS 2.04E+08 48 52

MB/REF

DS/C-ESP

61 Pulaski Baltimore MD 4.22E+08 Actual tested stack emissions 22 22

DS/C-ESP subtotals 4.22E+08 22 22

MB/REF

C-ESP

62 Clinton Clinton MI 1.69E+08 Actual tested stack emissions 40 43

C-ESP subtotals 1.69E+08 40 43

MB/REF

DS/FF

63 Mid Maine Waste Auburn ME 5.63E+07 0.67 0.72 <0.1 <0.1

64 Huntington Huntington NY 2.11E+08 0.67 0.72 0.1 0.2

DS/FF subtotals 2.67E+08 0.1 0.2
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-43 DRAFT: DO NOT CITE OR QUOTE

Table 3-2. Inventory of municipal waste combustors (MWCs) in 1995 (continued)

Annual air emissions 

a Design class

APCDb 

Facility

name

City

located State

Activity 

levelc 

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ EFe

(ng/kg)

(g/y)

I-TEQDF

WHO98

TEQDF

MB/REF

DSI/FF

65 Davis Co. Layton UT 1.13E+08 1.91 2.07 0.2 0.2

DSI/FF subtotals 1.13E+08 0.2 0.2

Totals for mass burn refractory 1.18E+09 110 117

MB/RK

C-ESP

66 Montenay Bay Panama City FL 1.44E+08 47 93.1 6.8 13

67 Sumner Co. Gallatin TN 5.63E+07 47 93.1 2.7 5.2

MB/RK C-ESP subtotals 2.00E+08 9.5 18

MB/RK

DSI/C-ESP

68 Dayton RRF Dayton OH 5.07E+08 47 93.1 24 47

DSI/C-ESP subtotals 5.07E+08 24 47

MB/RK

DSI/FF

69 Dutchess Co. Poughkeepsie NY 1.13E+08 Actual tested stack emissions 5.3 10

70 MacArthur WTE Ronkonkoma NY 1.46E+08 47 93.1 6.7 14

DSI/FF subtotals 2.59E+08 12 24

MB/RK

DS/FF

71 Delaware Co. Chester PA 7.57E+08 0.62 0.68 0.5 0.5

72 York Co. York PA 3.79E+08 Actual tested stack emissions 0.2 0.3

DS/FF subtotals 1.14E+09 0.7 0.8 

Totals for mass burn rotary kiln 2.10E+09 46 90

RDF/ded

C-ESP

73 Dade Co. RRF Miami FL 8.45E+08 231 253 199 214

74 Niagara Falls RDF Niagara Falls NY 6.20E+08 Actual tested stack emissions 143 157 

75 Central Wayne Co. Dearborn MI 1.41E+08 Actual tested stack emissions 33 36

76 Ramsey-WA Red Wing MN 2.03E+08 231 253 47 51
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-44 DRAFT: DO NOT CITE OR QUOTE

Table 3-2. Inventory of municipal waste combustors (MWCs) in 1995 (continued)

a Design class

APCDb 

Facility

name

City

located State

Activity 

levelc 

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ EFe

(ng/kg)

Annual air emissions 

(g/y)

I-TEQDF

WHO98

TEQDF

RDF/ded C-ESP subtotals 1.81E+09 422 458

RDF/ded

DS/C-ESP

77 West Palm Beach Palm Beach FL 5.63E+08 0.53 0.56 0.3 0.3

78 SEMASS RRF Rochester MA 5.07E+08 0.53 0.56 0.3 0.3

79 Western L Superior Duluth MN 7.32E+07 0.53 0.56 <0.1 <0.1

80 Honolulu RRF Honolulu HI 6.08E+08 0.53 0.56 0.3 0.3

DS/C-ESP subtotals 1.75E+09 0.9 0.9

RDF/ded

DS/FF

81 SEMASS RRF Rochester MA 7.60E+08 0.24 0.26 0.2 0.2

82 Maine Energy RRF Biddeford ME 1.69E+08 Actual tested stack emissions 0.1 0.1

83 Penobscot Energy Orrington ME 1.97E+08 Actual tested stack emissions <0.1 <0.1

84 Greater Detroit RRF Detroit MI 6.20E+08 Actual tested stack emissions 0.1 0.2

85 Wilmarth Plant Mankato MN 2.03E+08 47 93.1 0.1 0.1

86 Norfolk Navy Yard Norfolk VA 5.63E+08 0.24 0.26 0.1 0.1

87 Mid-Connecticut Hartford CT 5.63E+08 Actual tested stack emissions 0.1 0.1

DS/FF subtotals 3.07E+09 0.7 0.8

RDF/ded

DSI/FF

88 Elk River RRF Elk River MN 4.22E+08 47 93.1 20 39

DSI/FF subtotals 4.22E+08 20 39

RDF/ded

DSI/H-ESP

89 Haverhill Lawrence Lawrence MA 2.00E+08 285 316 57 63

DSI/H-ESP subtotals 2.00E+08 57 63

RDF/ded

H-ESP

90 Kodak MWC Rochester NY 4.22E+07 1,490 1,680 63 71

H-ESP subtotals 4.22E+07 63 71
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-45 DRAFT: DO NOT CITE OR QUOTE

Table 3-2. Inventory of municipal waste combustors (MWCs) in 1995 (continued)

a Design class

APCDb 

Facility

name

City

located State

Activity 

levelc 

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ EFe

(ng/kg)

Annual air emissions 

(g/y)

I-TEQDF

WHO98

TEQDF

Totals for dedicated refuse derived fuel 7.30E+09 564 633

MOD/SA

UNC

91 Batesville MWC Batesville AR 2.82E+07 16.2 17 0.5 0.5

92 Stuttgart MWC Stuttgart AR 1.77E+07 16.2 17 0.3 0.3

93 Osceola MWC Osceola AR 1.41E+07 16.2 17 0.2 0.2

94 Miami Airport Miami FL 1.69E+07 16.2 17 0.3 0.3

95 NIEHS MWC Durham NC 1.13E+07 16.2 17 0.2 0.2

96 Livingston/Park Co. Park Co. MT 2.03E+07 16.2 17 0.3 0.3

97 Miami MWC Miami OH 2.96E+07 16.2 17 0.5 0.5

98 Coos Bay MWC Coquille OR 3.52E+07 16.2 17 0.6 0.6

99 Pentagon MWC Arlington VA 1.41E+07 16.2 17 0.2 0.2

UNC subtotals 1.87E+08 3.1 3.1

MOD/SA

H-ESP

100 Juneau MWC Juneau AK 1.97E+07 79 85.7 1.6 1.7

101 Harford Co. Aberdeen MD 1.01E+08 79 85.7 8.0 8.7

102 City of Clebume Clebume TX 3.24E+07 79 85.7 2.6 2.8 

103 Barron Co. Almena WI 2.82E+07 79 85.7 2.2 2.4

H-ESP subtotals 1.81E+08 14 16

MOD/SA

C-ESP

104 Perham MWC Perham MN 3.21E+07 16.2 17 0.5 0.6

105 Polk Co. MWC Fosston MN 2.25E+07 16.2 17 0.4 0.4

106 Oswego Co. Fulton NY 5.63E+07 16.2 17 0.9 1.0

107 Westmoreland Greensburg PA 1.41E+07 16.2 17 0.2 0.2

C-ESP subtotals 1.25E+08 2.0 2.2
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-46 DRAFT: DO NOT CITE OR QUOTE

Table 3-2. Inventory of municipal waste combustors (MWCs) in 1995 (continued)

Annual air emissions 

a Design class

APCDb 

Facility

name

City

located State

Activity 

levelc 

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ EFe

(ng/kg)

(g/y)

I-TEQDF

WHO98

TEQDF

MOD/SA

DS/DSI/C-ESP

108 Chamber Medical Hampton SC 7.60E+07 16.2 17 1.2 1.3

DS/DSI/C-ESP subtotals 7.60E+07 1.2 1.3

MOD/SA

DSI/FF

109 St. Croix WTE New Richmond WI 2.87E+07 0.02 0.03 <0.1 <0.1

DSI/FF subtotals 2.87E+07 <0.1 <0.1

MOD/SA

WS

110 Fergus Falls Fergus Falls MN 2.65E+07 16.2 17 0.4 0.5

111 Center MWC Center TX 1.13E+07 16.2 17 0.2 0.2

112 Panola Co. Carthage TX 1.13E+07 16.2 17 0.2 0.2

WS subtotals 4.90E+07 0.8 0.9

MOD/SA

WS/FF

113 Recomp Bellingham Bellingham WA 2.82E+07 16.2 17 0.5 0.5

WS/FF subtotals 2.82E+07 0.5 0.5

Totals for modular-starved air 6.46E+08 22 24

MOD/EA

UNC

114 Mayport NAS Mayport FL 1.41E+07 16.2 17 0.2 0.2

UNC subtotals 1.41E+07 0.2 0.2

MOD/EA

H-ESP

115 Richards Asphalt Co. Savage MN 1.97E+07 Actual tested stack emissions 2.3 2.4 

H-ESP subtotals 1.97E+07 2.3 2.4

MOD/EA

DSI/H-ESP

116 Sitka MWC Sitka AK 1.41E+07 118 119 1.7 1.7

DSI/H-ESP subtotals 1.41E+07 1.7 1.7

MOD/EA

C-ESP

117 Pope-Douglas SW Alexandria MN 2.03E+07 Actual tested stack emissions 0.3 0.3

118 Red Wing Red Wing MN 2.03E+07 Actual tested stack emissions 0.1 0.1
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-47 DRAFT: DO NOT CITE OR QUOTE

Table 3-2. Inventory of municipal waste combustors (MWCs) in 1995 (continued)

Annual air emissions 

a Design class

APCDb 

Facility

name

City

located State

Activity 

levelc 

(kg/y)

I-TEQ EFd

(ng/kg)

WHO TEQ EFe

(ng/kg)

(g/y)

I-TEQDF

WHO98

TEQDF

119 Pascagoula RRF Moss Point MS 4.22E+07 16.2 17 0.7 0.7

C-ESP subtotals 8.28E+07 1.1 1.1

MOD/EA

DS/FF

120 Wallingford RRF Wallingford CT 1.18E+08 16.2 17 1.9 2.0

DS/FF subtotals 1.18E+08 1.9 2.0

MOD/EA

DSI/FF

121 Springfield RRF Agawam MA 1.01E+08 16.2 17 1.6 1.7

DSI/FF subtotals 1.01E+08 1.6 1.7

MOD/EA

WS/C-ESP

122 Pittsfield RRF Pittsfield MA 6.76E+07 Actual tested stack emissions 1.1 1.2

WS/C-ESP subtotals 6.76E+07 1.1 1.2

Totals for modular excess air 4.17E+08 10 10

FB/RDF

DS/FF

123 Fayetteville RRF Fayetteville NC 1.69E+08 0.67 0.72 0.1 0.1

DS/FF subtotals 1.69E+08 0.1 0.1

FB/RDF

DSI/FF

124 Tacoma RRF Tacoma WA 8.45E+07 0.67 0.72 0.1 0.1

DSI/FF subtotals 8.45E+07 0.1 0.1

FB/RDF

DSI/EGB

125 LaCrosse Co. La Crosse WI 1.13E+08 Actual tested stack emissions 0.1 0.1

DSI/EGB subtotals 1.13E+08 0.1 0.1

Totals for fluidized bed/refuse-derived fuel 3.66E+08 0.3 0.3

Totals for all MWCs operating in 1995 2.98E+10 1050 1200

a

MWC Design class: FB/RDF = Fluidized-bed refuse-derived fuel; MB/WW = Mass burn waterwall; MB/RK = Mass burn rotary kiln; MB/REF = Mass burn 

refractory walled; MOD/EA = Modular excess air; RDF/Ded = Dedicated refuse-derived fuel; RDF/co = Refuse-derived fuel cofired with coal (slash indicates 

devices used in conjunction).
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-48 DRAFT: DO NOT CITE OR QUOTE

b

APCD = air pollution control device. This includes DS/FF (dry scrubber with fabric filters); H-ESP (hot-sided electrostatic precipitator); EGB (electrified 

gravel bed); WS (wet scrubber); FF (fabric filter); UNC = uncontrolled or no APCD. c

Activity Level is the annual amount (kg) of municipal solid waste or refuse derived fuel expected to be combusted by the MWC. It is estimated by multiplying 

the annual design capacity of the furnace by 85%. The figure of 85% represents the assumption that the MWC will experience downtime during the year for 

maintenance and repairs.

d

The I-TEQDF Emission Factor (EF) expressed in units of ng TEQ/kg combusted. e

The WHO98 TEQDF Emission Factor (EF) expressed in units of ng TEQ/kg combusted. 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-49 DRAFT: DO NOT CITE OR QUOTE

Table 3-3. Inventory of municipal waste combustors (MWCs) in 2000 

a Design Class

APCDb Facility Name City Located State

Activity 

Levelc

(kg/y)

Emission Factor (ng 

TEQ/kg)

Annual Air Emissions 

(g/y)

I-TEQDF

WHO98

TEQDF I-TEQDF

WHO98

TEQDF

MB/WW 

DS/FF/CI/SNCR 

1 Huntsville Madison AL 1.77E+08 Tested Tested <0.1 <0.1

2 Stanislaus Stanislaus CA 2.61E+08 Tested Tested <0.1 <0.1

3 Bristol RRF Hartford CT 1.86E+08 Tested Tested <0.1 <0.1

4 Wheelabrator Lisbon Inc. New London CT 1.79E+08 Tested Tested <0.1 <0.1

5 Hillsborough Co. RRF Hillsborough FL 3.58E+08 Tested Tested 0.1 0.1

6 McKay Bay REF Hillsborough FL 1.80E+08 Tested Tested <0.1 <0.1

7 Lake Co. RRF Lake FL 1.66E+08 Tested Tested 0.1 0.1

8 Lee Co. RRF Lee FL 3.95E+08 Tested Tested 0.2 0.2

9 Pasco Co. RRF Pasco FL 3.10E+08 Tested Tested <0.1 <0.1

10 Pinellas Co. RRF Pinellas FL 8.91E+08 Tested Tested 0.1 0.2

11 Savannah RRF Chatham GA 1.21E+08 Tested Tested <0.1 <0.1

12 Indianapolis RRF Marion IN 6.54E+08 Tested Tested 0.1 0.1

13 Haverhill RRF Essex MA 5.68E+08 Tested Tested 0.1 0.1

14 Wheelabrator North Andover Essex MA 3.83E+08 Tested Tested <0.1 <0.1

15 Wheelabrator Saugus Essex MA 4.32E+08 Tested Tested <0.1 <0.1

16 Montgomery Co. RRF Montgomery MD 5.20E+08 Tested Tested 0.3 0.3

17 Kent Co. WTE Facility Kent MI 1.80E+08 Tested Tested 0.02 0.02

18 Central Wayne Energy Wayne MI 6.18E+07 Tested Tested <0.1 <0.1

19 Covanta Hennepin Hennepin MN 3.65E+08 Tested Tested 0.1 0.1

20 New Hanover Co. WTE New Hanover NC 1.27E+08 Tested Tested <0.1 <0.1

21 Wheelabrator Concord Merrimack NH 1.84E+08 Tested Tested <0.1 <0.1
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-50 DRAFT: DO NOT CITE OR QUOTE

Table 3-3. Inventory of municipal waste combustors (MWCs) in 2000 (continued)

Emission Factor (ng Annual Air Emissions 

a Design Class

APCDb Facility Name City Located State

Activity 

Levelc

(kg/y)

TEQ/kg) (g/y)

I-TEQDF

WHO98

TEQDF I-TEQDF

WHO98

TEQDF

MB/WW 

DS/FF/CI/SNCR

(continued) 

22 Gloucester Co. Gloucester NJ 1.81E+08 Tested Tested <0.1 <0.1

23 Union Co. RRF Union NJ 5.09E+08 Tested Tested <0.1 <0.1

24 Niagara Falls Niagara NY 7.14E+08 Tested Tested 0.4 0.4

25 Onondaga Co. RRF Onondaga NY 3.35E+08 Tested Tested <0.1 <0.1

26 Babylon RRF Suffolk NY 2.20E+08 Tested Tested <0.1 <0.1

27 Huntington RRF Suffolk NY 3.16E+08 Tested Tested <0.1 <0.1

28 Wheelabrator Westchester Westchester NY 6.50E+08 Tested Tested 0.1 0.1

29 Walter B. Hall RRF (Tulsa) Tulsa OK 3.39E+08 Tested Tested <0.1 <0.1

30 Marion Co. WTE Marion OR 1.84E+08 Tested Tested <0.1 <0.1

31 Lancaster Co. Bainbridge PA 3.81E+08 Tested Tested 0.1 0.1

32 Wheelabrator Falls RRF Bucks PA 5.25E+08 Tested Tested <0.1 <0.1

33 Montenay Montgomery Montgomery PA 4.03E+08 Tested Tested 0.5 0.6

34 Nashville Thermal Transfer Corp. Davidson TN 2.25E+08 Tested Tested <0.1 <0.1

35 Alexandria/Arlington RRF Alexandria VA 3.32E+08 Tested Tested 0.1 0.1

36 I-95 Energy RRF Fairfax VA 1.09E+09 Tested Tested <0.1 <0.1

37 Spokane Regional Facility Spokane WA 2.85E+08 Tested Tested <0.1 <0.1

DS/FF/CI/SNCR subtotals 1.34E+10 2.3 2.5

MB/WW 

DS/FF/SNCR 

38 Long Beach SERRF Los Angeles CA 5.74E+08 Tested Tested 0.1 0.1

39 Wheelabrator South Broward Ft. Lauderdale FL 7.56E+08 Tested Tested 0.2 0.2

40 Wheelabrator North Broward Broward FL 7.76E+08 Tested Tested 0.1 0.1

41 Hempstead Nassau NY 8.87E+08 Tested Tested 0.5 0.5

DS/FF/SNCR subtotals 2.99E+09 0.9 0.9

MB/WW 

DS/FF/CI 

42 Wheelabrator Bridgeport, L.P. Fairfield CT 7.08E+08 Tested Tested 0.1 0.1

43 Southeastern Connecticut RRF New London CT 7.08E+08 Tested Tested 0.1 0.1

44 Warren Energy RF Warren NJ 1.25E+08 Tested Tested <0.1 <0.1

DS/FF/CI subtotals 1.25E+08 0.2 0.2

MB/WW 

DS/FF 

45 Jackson Co. RRF Jackson MI 6.27E+07 0.67 0.72 <0.1 0.1

46 New Hanover Co. New Hanover NC 6.27E+07 0.67 0.72 <0.1 0.1

47 SES Claremont Sullivan NH 6.27E+07 0.67 0.72 <0.1 0.1

DS/FF subtotals 1.88E+08 <0.1 0.3 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-51 DRAFT: DO NOT CITE OR QUOTE

Table 3-3. Inventory of municipal waste combustors (MWCs) in 2000 (continued)

a Design Class

APCDb Facility Name City Located State

Activity 

Levelc

(kg/y)

Emission Factor (ng 

TEQ/kg)

Annual Air Emissions 

(g/y)

I-TEQDF

WHO98

TEQDF I-TEQDF

WHO98

TEQDF

MB/WW 

DS/ESP/CI/SNCR 

48 McKay Bay REF Hillsborough FL 1.80E+08 Tested Tested <0.1 <0.1

49 Wheelabrator Millbury Worcester MA 4.64E+08 Tested Tested 0.1 0.1

50 Wheelabrator Baltimore Independent 

City 

MD 7.15E+08 Tested Tested 0.4 0.4

51 Greater Portland Region RRF Cumberland ME 1.73E+08 Tested Tested 0.2 0.2

52 Camden RRF Camden NJ 2.77E+08 Tested Tested 0.4 0.4

53 Essex Co. RRF Essex NJ 9.85E+08 Tested Tested 0.2 0.2

DS/ESP/CI/SNCR subtotals 2.79E+09 1.3 1.3

MB/WW 

DS/ESP/CI 

54 Adirondack RRF Washington NY 1.62E+08 Tested Tested 1.0 1.0

55 Foster Wheeler Charleston RRF Charleston SC 2.11E+08 Tested Tested 0.3 0.3

DS/ESP/CI subtotals 3.74E+08 1.3 1.3

MB/WW 

C-ESP 

56 Southernmost WTE Monroe FL 3.74E+08 6.1 6.54 2.3 2.4

57 Olmstead WTE Facility Olmstead MN 6.27E+07 6.1 6.54 0.4 0.4

58 NASA Hampton City VA 6.27E+07 6.1 6.54 0.4 0.4

C-ESP subtotals 4.99E+08 3.1 3.2

MB/WW 

H-ESP

59 Harrisburg WTE Dauphin PA 1.54E+08 Tested Tested 21 23

H-ESP subtotals 1.54E+08 21 23

MB/WW 

UNC

60 Harrisonburg Harrisonburg VA 3.14E+07 1.9 2.07 0.1 0.1

UNC subtotals 3.14E+07 0.1 0.1

Totals for all MB/WW 2.05E+10 30 33

MB/REF 

DSI/H-ESP 

61 Davis/Wasatch Davis UT 1.25E+08 Tested Tested 2.7 2.9

DSI/H-ESP subtotals 1.25E+08 2.7 2.9

MB/REF 

DS/FF 

62 Mid Maine Waste Action Corp. Androscoggin ME 6.27E+07 0.67 0.72 <0.1 0.1

DS/FF subtotals 6.27E+07 <0.1 0.1

Totals for all MB/REF 1.88E+08 2.7 3.0

MB/RK

DS/FF 

63 American Ref-Fuel of Delaware Valley Delaware PA 1.11E+09 Tested Tested 0.5 0.5

DS/FF subtotals 1.11E+09 0.5 0.5

MB/RK

DS/FF/CI/SNCR 

64 York Co. York PA 3.97E+08 Tested Tested 0.1 0.1

DS/FF/CI/SNCR subtotals 3.97E+08 0.1 0.1

MB/RK

DSI/FF 

65 Dutchess Co. RRF Dutchess NY 1.25E+08 Tested Tested <0.1 0.1

66 MacArthur WTE Suffolk NY 1.52E+08 Tested Tested <0.1 <0.1
Table 3-3. Inventory of municipal waste combustors (MWCs) in 2000 (continued)

Emission Factor (ng Annual Air Emissions 

a Design Class

APCDb Facility Name City Located State

Activity 

Levelc

(kg/y)

TEQ/kg) (g/y)

I-TEQDF

WHO98

TEQDF I-TEQDF

WHO98

TEQDF

DSI/FF subtotals 2.78E+08 <0.1 0.1

MB/RK

FF 

67 Galax City SW Grayson VA 1.76E+07 Tested Tested 0.2 0.3

FF subtotals 1.76E+07 0.2 0.3

MB/RK

H-ESP

68 Bay Resource Management Center Bay FL 1.54E+08 Tested Tested 8.1 8.9

H-ESP subtotals 1.54E+08 8.1 8.9

MB/RK

C-ESP

69 Sumner Co. Sumner TN 6.27E+07 47 93.1 3.0 5.9

C-ESP subtotals 6.27E+07 3.0 5.9

Totals for all MB/RK 2.02E+09 12 16

MOD/EA 

DS/FF 

70 Wallingford RRF New Haven CT 1.32E+08 Tested Tested 0.1 0.1

DS/FF subtotals 1.32E+08 0.1 0.1

MOD/EA 

DSI/FF 

71 Springfield RRF Hampden MA 1.13E+08 0.025 0.024 <0.1 <0.1

DSI/FF subtotals 1.13E+08 <0.1 <0.1

MOD/EA 

WS/C-ESP 

72 Pittsfield RRF Berkshire MA 1.13E+08 16.2 17 1.8 1.9

WS/C-ESP subtotals 1.13E+08 1.8 1.9

MOD/EA 

C-ESP

73 Pope-Douglas Waste Douglas MN 2.26E+07 16.2 17 0.4 0.4

74 Red Wing Solid Waste Boiler Facility Goodhue MN 2.26E+07 16.2 17 0.4 0.4

 C-ESP subtotals 4.52E+07 0.8 0.8

MOD/EA 

H-ESP

75 Pascagoula Jackson MS 4.70E+07 118 119 5.6 5.6

 H-ESP subtotals 4.70E+07 5.6 5.6

Totals for all MOD/EA 4.50E+08 8.3 8.4

MOD/SA 

C-ESP

76 Juneau RRF Juneau Borough AK 2.20E+07 16.2 17 0.4 0.4

77 Perham Renewable RF Otter Tail MN 3.57E+07 16.2 17 0.6 0.6

78 Polk Co. Polk MN 2.51E+07 16.2 17 0.4 0.4

79 Barron Co. Barron WI 3.14E+07 16.2 17 0.5 0.5

 C-ESP subtotals 1.14E+08 1.9 1.9

MOD/SA 

DSI/C-ESP 

80 City of Cleburne Johnson TX 3.57E+07 16.2 17 0.6 0.6

DSI/C-ESP subtotals 3.57E+07 0.6 0.6

MOD/SA 

DSI/H-ESP 

81 Harford Co. WTE Fac. Harford MD 1.13E+08 Tested Tested 5.4 6.0

DSI/H-ESP subtotals 1.13E+08 5.4 6.0

MOD/SA 

DS/FF/CI 

82 Oswego Co. WTE Oswego NY 6.27E+07 Tested Tested 0.1 0.1

DS/FF/CI subtotals 6.27E+07 0.1 0.1

This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-52 DRAFT: DO NOT CITE OR QUOTE
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-53 DRAFT: DO NOT CITE OR QUOTE

Table 3-3. Inventory of municipal waste combustors (MWCs) in 2000 (continued)

a Design Class

APCDb Facility Name City Located State

Activity 

Levelc

(kg/y)

Emission Factor (ng 

TEQ/kg)

Annual Air Emissions 

(g/y)

I-TEQDF

WHO98

TEQDF I-TEQDF

WHO98

TEQDF

MOD/SA 

DSI/FF 

83 Coos Bay Incinerator Coos OR 4.70E+07 Tested Tested <0.1 <0.1

DSI/FF subtotals 4.70E+07 <0.1 <0.1 

MOD/SA 84 Arlington -Pentagon Arlington VA 3.14E+07 16.2 17 0.5 0.5

 MOD/SA subtotals 3.14E+07 0.5 0.5

MOD/SA 

WS 

85 Fergus Falls Otter Tail MN 2.95E+07 16.2 17 0.5 0.5

86 Panola Co. WTE Panola TX 1.25E+07 16.2 17 0.2 0.2

87 Center RRF Shelby TX 1.25E+07 16.2 17 0.2 0.2

WS subtotals 5.46E+07 0.9 0.9

MOD/SA 

UNC

88 Miami Airport Dade FL 1.88E+07 16.2 17 0.3 0.3

89 Livingston/Park Co. Park MT 2.26E+07 16.2 17 0.4 0.4

90 Miami RRF Ottawa OK 3.29E+07 16.2 17 0.5 0.6 

UNC subtotals 7.43E+07 1.2 1.3

Totals for all MOD/SA 

5.33E+08 10 11

RDF/Ded 

DS/FF/SNCR 

91 Mid-Connecticut RRF Hartford CT 7.50E+08 Tested Tested 0.1 0.1

92 SEMASS RRF Plymouth MA 3.65E+08 Tested Tested <0.1 <0.1

93 Maine Energy Recovery York ME 2.47E+08 Tested Tested <0.1 <0.1

94 Wilmarth Plant Blue Earth MN 2.03E+08 Tested Tested 0.1 0.1

DS/FF/SNCR subtotals 1.57E+09 0.2 0.2

RDF/Ded 

DS/FF/CI/SNCR 

95 Dade Co. RRF Dade FL 6.68E+08 Tested Tested 1.3 1.4

DS/FF/CI/SNCR subtotals 6.68E+08 1.3 1.4

RDF/Ded 

DS/FF 

96 Penobscot Energy Recovery Penobscot ME 2.20E+08 Tested Tested <0.1 <0.1

97 Greater Detroit RRF Wayne MI 6.93E+08 Tested Tested 0.5 0.5

98 Great River Energy Sherburne MN 2.85E+08 Tested Tested 0.1 0.1

99 SPSA Waste to Energy Portsmouth VA 4.89E+08 Tested Tested 0.5 0.5

DS/FF subtotals 1.69E+09 1.1 1.1

RDF/Ded 

DSI/FF 

100 Red Wing Plant Goodhue MN 1.82E+08 Tested Tested 0.1 0.1

DSI/FF subtotals 1.82E+08 0.1 0.1

RDF/Ded 101 LaCrosse Co. LaCrosse WI 4.44E+07 Tested Tested 0.7 0.7
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

3-54 DRAFT: DO NOT CITE OR QUOTE

Table 3-3. Inventory of municipal waste combustors (MWCs) in 2000 (continued)

a Design Class

APCDb 

DSI/FF/WSp/SNCR 

Facility Name City Located State

Activity 

Levelc

(kg/y)

Emission Factor (ng 

TEQ/kg)

Annual Air Emissions 

(g/y)

I-TEQDF

WHO98

TEQDF I-TEQDF

WHO98

TEQDF

DSI/FF/WSp/SNCR subtotals 4.44E+07 0.7 0.7

RDF/Ded 

C-ESP

102 Central Wayne Co. Wayne MI 1.56E+08 Tested Tested 0.1 0.1

C-ESP subtotals 1.56E+08 0.1 0.1

RDF/Ded 

DS/ESP 

103 Honolulu RRF Honolulu HI 5.15E+08 Tested Tested 2.0 2.2

DS/ESP subtotals 5.15E+08 2.0 2.2

RDF/Ded 

DS/ESP/FF/CI 

104 SEMASS RRF Plymouth MA 7.41E+08 Tested Tested 0.1 0.10

DS/ESP/FF/CI subtotals 7.41E+08 0.1 0.10

Totals for all RDF/Ded 5.56E+09 5.6 5.9

FB/RDF 

DSI/FF 

105 Tacoma Pierce WA 9.41E+07 0.67 0.72 0.1 0.1

DSI/FF subtotals 9.41E+07 0.1 0.1

Totals for all FB/RDF 9.41E+07 0.1 0.1

Totals for all MWCs operating in year 2000 2.94E+10 69 77

a

MWC Design class: FB/RDF = Fluidized-bed refuse-derived fuel; MB/WW = Mass burn waterwall; MB/RK = Mass burn rotary kiln; MB/REF = Mass burn 

refractory walled; MOD/EA = Modular excess air; RDF/Ded = Dedicated refuse-derived fuel. b

APCD = air pollution control device. DS/FF/CI/SNCR (dry scrubber followed by fabric filter with carbon injection and nitrogen oxide control); DS/FF/SNCR 

(dry scrubber followed by fabric filter with nitrogen oxide control); DS/FF/CI (dry scrubber followed by fabric filter with carbon injection); DS/FF (dry 

scrubber followed by fabric filter); DSI/FF (duct sorbent injection followed by fabric filter); DSI/FF/WSp/SNCR (duct sorbent injection followed by fabric filter 

with water spray and nitrogen oxide control); DS/ESP/CI/SNCR (dry scrubber followed by electrostatic precipitator with carbon injection and nitrogen oxide 

control); DS/ESP/CI (dry scrubber followed by electrostatic precipitator with carbon injection); C-ESP (cold-sided electrostatic precipitator); H-ESP (hot-sided 

electrostatic precipitator); DSI/C-ESP (duct sorbent injection followed by cold-sided electrostatic precipitator); DSI/H-ESP (duct sorbent injection followed by 

hot-sided electrostatic precipitator); WS (wet scrubber); WS/C-ESP (wet scrubber followed by cold-sided electrostatic precipitator); UNC (uncontrolled). c

Activity Level is the annual amount (kg) of municipal solid waste or refuse derived fuel expected to be combusted by the MWC. It is estimated by multiplying 

the annual design capacity of the furnace by 85%. The figure of 85% represents the assumption that the MWC will experience downtime during the year for 

maintenance and repairs.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 3-55 DRAFT: DO NOT CITE OR QUOTE

Table 3-4. TEQ air emissions from medical waste incinerators (MWIs) for 

reference year 1987, 1995, and 2000 

MWI class

No. of tested 

facilities/total

I-TEQDF

emission 

factor 

(ng/kg)

WHO98

TEQDF

emission 

factor 

(ng/kg)

Activity level

(kg/yr)

Annual

I-TEQDF

emissions

(g/yr)

Annual 

WHO98

TEQDF

emissions 

(g/yr)

1987

Uncontrolled 7/5,000 1,800 1,900 1.43E+09 2,600 2,700

Controlled 0 0 0 0

TOTAL 1.43E+09 2,600 2,700

1995

Uncontrolled 7/1,770 1,800 1,900 2.54E+08 460 480

Controlled 12/605 50 51 5.17E+08 26 26

TOTAL 7.71E+08 490 510

2000

Uncontrolled 7/975 1,800 1,900 1.98E+08 360 380

Controlled 12/333 50 51 4.03E+08 20 20

TOTAL 6.01E+08 380 400
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 4-1 DRAFT: DO NOT CITE OR QUOTE

1 4. COMBUSTION SOURCES OF CDDS/CDFS: POWER/ENERGY GENERATION

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

4.1. MOTOR VEHICLE FUEL COMBUSTION

This section covers on-road and off-road vehicles. The activity estimates were changed 

so that all are on a per-liter basis rather than a per-km driven basis, resulting in small changes in 

the air-release estimates. Other changes include addition of new literature studies, clarifications 

about derivations of emission factors, and discussions about the uncertainties associated with the 

estimates for off-road vehicles. Separate release estimates for 2-stroke engines (also referred to 

as 2-cycle engines) were considered, but insufficient information was available on both emission 

factors and activities to do this. The activity estimates are based on total fuel sold and include 

fuels used in all types of engines. Thus, 2-stroke engines are represented, and the uncertainties 

associated with their emissions are discussed. The confidence ratings for releases from all offroad vehicles were changed to preliminary due to lack of emissions test data. There were 

insufficient data to make an emission estimate for waste motor oil; see Section 4.3 for 

information on combustion of waste motor oil. 

4.1.1. Air Literature

A number of additional studies on dioxin emissions from diesel engines were found as 

summarized below. 

Gullett and Ryan (2002) characterized CDD/CDF emissions from two heavy duty diesel 

trucks under highway driving conditions and while idling: a 1989 Ford with a turbocharged 

Cummins engine and mechanical fuel controls and a 1990 Kenworth with a T800 engine 

equipped with the first generation of electronic fuel controls. The Ford trailer was loaded at 

16,900 kg, and the Kenworth trailer at 8,400 kg. The Kenworth was tested using both a high 

mileage and the same engine in rebuilt, or “low mileage” condition. The average emission 

factors reported for each vehicle and driving condition are presented below: 

• Ford/highway: 385 pg WHO98 TEQ/L

• Kenworth/highway (old engine): 58 pg WHO98 TEQ/L

• Kenworth/highway (rebuilt engine): 24 pg WHO98 TEQ/L

• Kenworth/idle: 6 pg WHO98 TEQ/L
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 4-2 DRAFT: DO NOT CITE OR QUOTE

1 Tests were also performed using a low-sulfur fuel, which was representative of U.S. diesel fuels 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

in 2000. 

Kim et al. (2003) conducted a study in Korea that measured CDD/CDF emissions from a 

light duty diesel engine under various loadings. The average CDD/CDFs concentrations per unit 

of exhaust gas with 25, 50, and 75% load rate are 14.5, 6.9, and 6.4 pg TEQ/Nm3, respectively. 

According to the authors, these values, respectively, convert to 2.0, 0.6, and 0.5 pg TEQ/L fuel.

Norbeck et al. (1998) measured CDD/CDF emissions from a 6-cylinder, 310-hp diesel 

engine over the heavy-duty transient test cycle. Emission testing was conducted at the Los 

Angeles County Metropolitan Transportation Authority emission test facility. Dioxin sampling 

was conducted for the pre-1993 and reformulated fuels. Although PCDDs and PCDFs were 

detected, the most toxic isomers, 2,3,7,8-TCDD, 1,2,3,7,8-PeCDD, and 2,3,4,7,8-PeCDF were

not detected in either the pre-1993 or reformulated fuel. TEQ profiles were incomplete due to 

the low levels of CDD and PCDF detected in the emission samples. 

Mayer et al (2003) reports on the use of fine-pored hot gas traps with filtration 

efficiencies exceeding 99% of the solid particles in the diesel exhaust gas. Catalyzed particle 

traps also achieve greater than 99% reduction in emissions of semi-volatile hydrocarbons (Laroo 

et al., 2011, CRC, 2009). This technology is used by original equipment manufacturers on new 

diesel exhaust systems and has been used to retrofit on-road and off-road engines in the U.S. 

Mayer et al testing with fuel borne catalysts indicate that in these situations, the large effective 

area of the filter, and the engine exhaust gas components in conjunction with the fuel borne 

catalysts can promote undesirable chemical reactions that release toxic secondary emissions. 

Dioxins and furans were found not to form in most trap systems but fuel-borne additives 

containing copper with extremely high fuel chlorine levels (up to 110 ppm), caused emissions to 

increase by four orders of magnitude. Copper fuel additives are not registered for use in the U.S. in 

on-road engines. 

Laroo et al. (2011), Liu et al. (2011) and Hovemann et al. (2010) compared emissions of 

dioxins and furans using various catalyzed aftertreatment systems, including diesel oxidation 

catalysts, catalyzed diesel particulate filters, and copper and iron zeolite selective catalytic 

reduction (SCR) systems that are currently used in on-road diesel trucks in the U.S. These 

studies report no increase in dioxin or furan emissions when using catalyzed aftertreatment 
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1 systems and fuel chlorine levels that were representative and one order of magnitude higher than 

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what is currently in ultra low sulfur pump diesel fuel. 

UNEP (2005) presents emission factors for a variety of engine types and fuels. These 

were originally presented in units of μg I-TEQ/MT and are converted to pg I-TEQ/L below 

(assumes diesel fuel has a density of 0.85 kg/L and gasoline has a density of 

0.75 kg/L―Hazardous Substances Database, 

http://toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB.htm):

• Leaded gasoline, 4-stroke engine—1,600 pg I-TEQ/L

• Leaded gasoline, 2-stroke engine—2,600 pg I-TEQ/L

• Unleaded gasoline, 4-stroke engine without catalyst—75 pg I-TEQ/L

• Unleaded gasoline, 4-stroke engine with catalyst—0 

• Unleaded gasoline, 2-stroke engine without catalyst—1,900 pg I-TEQ/L

• Diesel engines—85 pg I-TEQ/L

4.1.2. Air Emission Factor

In the original document, some of the emission factors were presented on a per-km driven 

basis and some on a per-liter of fuel basis. The present document changes all vehicle emission 

factors to a per-liter basis. Separate emission factors were developed for vehicles burning leaded 

gasoline, unleaded gasoline, and diesel fuel. 

4.1.2.1. Leaded Gasoline 

The literature indicates that CDD/CDF emissions occur from vehicles using leaded 

gasoline, and that considerable variation occurs depending, at least in part, on the types of 

additives used in the fuel or motor oil (Ballschmiter et al., 1986; Marklund et al., 1990). 

The average emission factor, as reported for the tailpipe emission studies performed 

using commercial leaded fuel (see Table 4-4 in U.S. EPA, 2006), was 532 pg WHO98 TEQDF/L 

(450 pg I-TEQDF/L), (Marklund et al., 1990; Hagenmaier et al., 1990; Schwind et al., 1991). 

This emission factor was applied to 1987 but was not needed for the other years due to the 

phaseout of leaded gasoline. 
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1 For application to off-road engines, this emission factor is considered preliminary 

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because it is based on automobile testing and it is uncertain how well it applies to off-road 

engines (see discussion below). 

4.1.2.2. Unleaded Gasoline 

The literature documenting results of European studies indicates that CDD/CDF 

emissions from vehicles burning unleaded fuels are lower than emissions from vehicles burning 

leaded gas with chlorinated scavengers. It also appears, based on the limited data available, that 

catalyst-equipped cars have lower emission factors than do noncatalyst-equipped cars (Marklund 

et al., 1987; Marklund et al., 1990; Hagenmaier et al., 1990; Schwind et al., 1991). All 

automobiles running on unleaded gasoline in the United States are equipped with catalysts

(commonly known as “catalytic converters”). The average emission factor reported for the 

tailpipe emission studies performed on catalyst-equipped cars (Hagenmaier et al., 1990; Schwind 

et al., 1991; Hutzinger et al., 1992) was calculated as 15.6 pg WHO98 TEQDF/L 

(14.9 pg I-TEQDF/L). This emission factor was assumed to apply to each reference year.

For application to off-road engines, this emission factor is considered preliminary

because it is based on automobile testing, and it is uncertain how well it applies to off-road 

engines. Off-road engines can have very different designs. For example, few, if any, off-road 

gasoline engines have the mechanisms for fuel efficiency and emission control that on-road 

engines have, such as feedback control systems that monitor and correct the air-to-fuel ratio for 

combustion; either oxidation or three-way catalysts or exhaust gas recirculation systems (EGR); 

or overhead valves. Two-stroke engines are much more commonly used in off-road applications 

than on-road vehicles. The compression ratios for these engines are generally significantly less 

than those of four-stroke engines (U.S. EPA, 2002c). As a result, emissions of traditional 

pollutants from two-stroke engines are higher than from four-stroke engines. For example, EPA 

estimates emissions of PM from two-stroke, off-road motorcycles to be more than 20 times that 

of four-stroke motorcycles (U.S. EPA, 2002a). Although dioxin emissions do not always 

correspond to emissions of conventional pollutants, it is possible that two-stroke off-road engines 

have higher dioxin emissions. This belief is strongly reflected in the UNEP (2005) emission 

factor recommendations of 1,900 pg I-TEQ/L for unleaded gasoline in two-stroke engines 

without catalysts versus zero for unleaded gasoline in four-stroke engines with catalyst. The 
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1 UNEP (2005) recommendations for two-stroke engines were not adopted here due to the lack of 

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supporting references. 

4.1.2.3. Diesel Fuel

Data available upon which to base an evaluation of the extent of CDD/CDF emissions 

resulting from diesel fuel combustion are discussed in this section. These data address only 

emissions from on-road vehicles; no emissions data are available for off-road diesel uses 

(construction vehicles, farm vehicles, and stationary equipment). 

Laroo et al. (2011) reported emission factors for a 2008 model year diesel engine of 1.89 

pg I-TEQ/L without aftertreatment under steady-state operation; 1.28 pg I-TEQ/L for an engine 

with copper zeolite urea SCR, diesel oxidation catalyst, and catalyzed particulate filter

aftertreatment under transient operation; and 0.21 pg I-TEQ/L for an engine equipped with a 

diesel oxidation catalyst and catalyzed particulate filter under transient operation. Liu et al. 

(2011) reported emission factors for a 2010 model year diesel engine of 0.31 pg WHO 1998 

TEQ/hp-hr without aftertreatment; 0.12 pg WHO 1998 TEQ/hp-hr for an engine with copper 

zeolite urea SCR, diesel oxidation catalyst, and catalyzed particulate filter aftertreatment and 

0.13 pg WHO 1998 TEQ/hp-hr for an engine equipped with a diesel oxidation catalyst and 

catalyzed particulate filter under steady-state operation. Hovemann et al. (2010) reported 

emissions factors of 0.11 pg/m3 for steady-state operation and 0.10 pg/m3

 for transient operation 

of a diesel engine with aftertreatment including a diesel oxidation catalyst, copper zeolite SCR 

and urea. The Health Effects Institute (2009) reported a range of emissions from 0.13 – 1.4 pg ITEQ/L for three diesel engines equipped with catalyzed particulate filters.

Although aggregate samples representing several thousand heavy-duty diesel vehicles 

were collected in Oehme et al. (1991), several characteristics of the study introduce considerable 

uncertainty with regard to the use of the study’s results as a basis for estimating emissions in the 

United States: (a) heavy-duty vehicles represented only 3 to 19% of total vehicle traffic in the 

tunnel; (b) the majority of the light-duty vehicles were fueled with leaded gasoline, which can 

lead to increased releases of CDD/CDFs; and (c) technology differences likely existed between 

the 1988 Norwegian and the 1987 and 1995 U.S. vehicle fleets. 

The tunnel study conducted in Baltimore, MD, by Gertler et al. (1996, 1998) shares the 

disadvantages of all tunnel studies relative to those that directly measured CDDs and CDFs in 
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1 tailpipe emissions. Specifically, tunnel studies rely on indirect measurements (rather than 

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tailpipe measurements), which may introduce bias, and the emission factors calculated from 

these studies reflect the mix of vehicles using the tunnel—and not necessarily the overall vehicle 

fleet. Also, they reflect the driving conditions of the tunnel (surface slope, speed, braking, etc.), 

which may not be representative of usual driving conditions. 

However, the Gertler et al. (1996, 1998) study does have strengths that are lacking in the 

Oehme et al. (1991) tunnel study, and it has advantages over the two U.S. diesel truck tailpipe 

studies, including: (a) the study was conducted during the reference year time frame (1995) in 

the United States and, thus, reflects U.S. fuels and technology of that time period, (b) virtually no 

vehicle using the tunnel was fueled with leaded gasoline, (c) the tunnel walls and streets were 

cleaned one week prior to the start of sampling and, in addition, the study analyzed road dust and 

determined that resuspended road dust contributed only about 4% of the estimated emission 

factors, (d) the heavy-duty vehicles comprised, on average, a relatively large proportion (25.7%) 

of vehicles using the tunnel, and (e) a large number of heavy-duty vehicles—approximately 

33,000—passed through the tunnel during the sampling period, which generates confidence that 

the emission factor is representative of interstate trucks. It should be noted, though, that the 

study was most representative of heavy duty trucks because these were the primary type of 

vehicle using the tunnel. For other diesel vehicles (e.g., light duty trucks, automobiles, buses), 

the study is less representative, and uncertainty is greater.

Considering the strengths and weaknesses of the available emission factor data from the 

tailpipe and tunnel studies, the mean TEQ emission factor reported by Gertler et al. (1996, 

1998)—182 pg WHO98 TEQDF/km (172 pg I-TEQDF/km)—is assumed to represent the best 

current estimate of the average emission factor for on-road diesel-fueled vehicles. This emission 

factor was converted to a per-liter basis assuming a fuel efficiency of 2.98 km/L (U.S. EPA, 

2003a). This yields an emission factor of 540 pg WHO98 TEQDF/L (510 pg I-TEQDF/L), which 

was assumed to apply to all reference years for both on-road and off-road vehicles. It is likely 

that the fleet average emission factor has decreased over the reference years (due to 

improvements in engine/emission designs), but insufficient information was available to account 

for this. For application to off-road vehicles, the factor is considered preliminary because it is 

based on truck testing, and it is uncertain how well it applies to other types of diesel vehicles 
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locomotives. 

4.1.3. Air Activity Level

The activity estimates for internal combustion engines were derived on the basis of fuel 

consumed as reported by the Energy Information Administration (EIA, 2008a).

4.1.3.1. Gasoline 

EIA (2008a) provides data on the total “motor gasoline product supplied,” which 

represents all gasoline consumed in the United States. These data were reported as barrels per 

year and are converted here to liters by multiplying by 42 gal/barrel and 3.78 L/gal. For 1987, it 

is assumed that 24% of the gasoline was leaded (1.00 × 1011 L) and the remainder unleaded 

(3.18 × 1011 L) (EIA, 1993). For years 1995 and 2000, it is assumed that leaded gasoline was 

produced in negligible amounts. The total amount of unleaded gasoline consumed in 1995 was 

4.00 × 1011 L, and the total amount consumed in 2000 was 4.93 × 1011 L. EIA does not provide 

data that allow the gasoline uses to be divided between on road and off road. However, 

U.S. EPA (2006) provided estimates for the year 2000 suggesting that 5% of the gasoline was 

used for off-road engines (kilometers driven on road were converted to liters, assuming an 

average fuel efficiency of 10 km/L). This percentage was assumed to apply to all reference 

years, resulting in the following estimates: 

Leaded (L) Unleaded (L)

Total On-road Off-road Total On-road Off-road

1987 1.00 × 1011 9.5 × 1010 0.5 × 1010 3.18 × 1011 3.03 × 1011 0.15 × 1011

1995 0 0 0 4.00 × 1011 3.80 × 1011 0.20 × 1011

2000 0 0 0 4.93 × 1011 4.68 × 1011 0.25 × 1011
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1 4.1.3.2. Diesel

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EIA provides data on “distillate fuel oil product supplied,” which represents all distillate 

fuel consumed in the United States. Distillate fuel includes diesel and other fuels used primarily 

for space heating. The diesel portion of the distillate fuel was determined using EIA data on 

“sales of distillate fuel oil by end use.” For 2001, these data suggest the following: 

• Diesel fuel used on road is 55% of the total.

• Diesel fuel used off road (includes off-highway, farm, railroad, vessels, and military 

categories) is 20% of the total.

• Other uses of distillate fuels (includes residential, commercial, industrial, and electric 

power categories) make up 25% of the total. 

It is assumed that these percentages for 2001 apply to all reference years. Applying these to the 

“distillate fuel oil product supplied,” yields: 

• 1987—9.48 × 1010 L on road, 3.45 × 1010 L off road

• 1995—1.02 × 1011 L on road, 3.71 × 1010 L off road

• 2000—1.19 × 1011 L on road, 4.32 × 1010 L off road

4.1.4. Air Releases

Air-release estimates were made by multiplying the emission factors with the activity 

estimates. Separate release estimates were made for leaded gasoline, unleaded gasoline, diesel 

off road, and diesel on road.

4.1.5. Water Releases—None

4.1.6. Solid Residue Releases

 Solid residue releases could result from disposal/recycling of mufflers or catalytic 

converters. No information could be found on the possible CDD/CDF content of these materials. 

4.1.7. Products—None
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1 4.1.8. Release Summary

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The inventory decision criteria and release estimates to all media are summarized below: 

Inventory Decision Criteria for Motor Vehicle Combustion—On-road

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors.

Measured emission factors consistent or have Yes

understandable differences.

Emission factor tests represent units that are typical of the Yes

class.

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

Inventory Decision Criteria for Motor Vehicle Combustion—Off-road

Air Water Solids Products 

Emission tests for at least two units/source types with No

sufficient documentation to directly derive emission factors.

Measured emission factors consistent or have 

understandable differences. 

Emission factor tests represent units that are typical of the 

class. 

No

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P
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Motor Vehicle Combustion

Air Releases

Emission Factors

Leaded Gasoline 

• 1987—530 pg WHO98 TEQDF/L (450 pg I-TEQDF/L) (Preliminary for off-road). 

Unleaded Gasoline 

• 1987—16 pg WHO98 TEQDF/L (15 pg I-TEQDF/L) (Preliminary for off-road).

• 1995—16 pg WHO98 TEQDF/L (15 pg I-TEQDF/L) (Preliminary for off-road).

• 2000—16 pg WHO98 TEQDF/L (15 pg I-TEQDF/L) (Preliminary for off-road).

Diesel

• 1987—540 pg WHO98 TEQDF/L (510 pg I-TEQDF/L) (Preliminary for off-road). 

• 1995—540 pg WHO98 TEQDF/L (510 pg I-TEQDF/L) (Preliminary for off-road). 

• 2000—540 pg WHO98 TEQDF/L (510 pg I-TEQDF/L) (Preliminary for off-road).

Activity Levels

Leaded Gasoline, On-road 

• 1987—9.5 × 1010 L/yr.

Leaded Gasoline, Off-road 

• 1987—0.5 × 1010 L/yr.

Unleaded Gasoline, On-road 

• 1987—3.03 × 1011 L/yr.

• 1995—3.80 × 1011 L/yr.

• 2000—4.68 × 1011 L/yr.

Unleaded Gasoline, Off-road 

• 1987—3.18 × 1011 L/yr.

• 1995—4.00 × 1011 L/yr.

• 2000—4.93 × 1011 L/yr.

Diesel, On-road 

• 1987—0.15 × 1010 L/yr.

• 1995—0.20 × 1011 L/yr.

• 2000—0.25 × 1011 L/yr.

Diesel, Off-road 

• 1987—3.45 × 1010 L/yr.

• 1995—3.71 × 1010 L/yr.

• 2000—4.32 × 1010 L/yr.
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Motor Vehicle Combustion (continued)

Releases

Leaded Gasoline, On--road 

• 1987—50 g WHO98 TEQDF (43 g I-TEQDF)

Leaded Gasoline, Off--road 

• 1987—3 g WHO98 TEQDF (2 g I-TEQDF) (Preliminary).

Unleaded Gasoline, On-road 

• 1987—5 g WHO98 TEQDF (5 g I-TEQDF).

• 1995—6 g WHO98 TEQDF (6 g I-TEQDF).

• 2000—7 g WHO98 TEQDF (7 g I-TEQDF).

Unleaded Gasoline, Off-road 

• 1987—0.2 g WHO98 TEQDF (0.2 g I-TEQDF) (Preliminary).

• 1995—0.3 g WHO98 TEQDF (0.3 g I-TEQDF) (Preliminary).

• 2000—0.4 g WHO98 TEQDF (0.4 g I-TEQDF) (Preliminary).

Diesel, On-road 

• 1987—51 g WHO98 TEQDF (48 g I-TEQDF). 

• 1995—55 g WHO98 TEQDF (52 g I-TEQDF). 

• 2000—64 g WHO98 TEQDF (61 g I-TEQDF). 

Diesel, Off-road 

• 1987—19 g WHO98 TEQDF (18 g I-TEQDF) (Preliminary).

• 1995—20 g WHO98 TEQDF (19 g I-TEQDF) (Preliminary).

• 2000—23 g WHO98 TEQDF (22 g I-TEQDF) (Preliminary).

Water Releases

No information was found suggesting that water releases from internal combustion engines

would contain CDDs and CDFs. 

Solid Residue Releases

No information was found suggesting that solid residue releases from internal combustion 

engines would contain CDDs and CDFs. 

Products

None.

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4.2. WOOD COMBUSTION

4.2.1. Residential Wood Combustion 

Several new literature studies were added, but no changes were made to the estimates of air 

releases from traditional residential wood-burning fireplaces and stoves. New sections were 

developed on the air releases from outdoor wood-fired boilers and on solid residues from all 

forms of residential wood burning. 
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1 This section focuses on residential burning of natural untreated wood. It should be noted 

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though, that treated wood may be burned at some residences with the potential for increased 

CDD/CDF emissions. Wevers et al. (2003) measured CDD/CDF emissions from domestic 

wood-burning appliances and reported emission factors of 22.4 ng I-TEQ/kg for burning 

untreated wood and 1,702 ng I-TEQ/kg for burning treated wood. Tame et al. (2003) measured 

CDD/CDF levels in ash from wood combustion in a cone calorimeter. Ash from burning 

untreated pine had an average of 0.050 ng I-TEQ/kg ash. For the CCA (chromated copper 

arsenate) treated pine, burnt under identical conditions, a significant increase was observed, with 

an average of 35 ng I-TEQ/kg. Tame et al. (2007) reviewed the literature on the role of

preservatives in the formation of dioxin in the combustion of wood. They conclude that current 

and emerging wood preservatives significantly increase dioxin formation during combustion in 

domestic stoves and in fires. Not all investigators, however, have observed these increases. 

Wasson et al. (2005) conducted chamber tests to measure CDD/CDF emissions from burning 

CCA treated wood. Emission factors ranged from 1.4 to 2.3 ng WHO98 TEQ/kg, which are 

similar to those for untreated wood. 

4.2.1.1. Air Releases from Indoor Residential Wood Burners

 A study conducted in Australia by Gras et al. (2002) measured dioxin emissions from a 

variety of wood-burning appliances and wood types. The average values for various wood types 

were 7.5 ng WHO98 TEQ/kg for eucalyptus, 19 ng WHO98 TEQ/kg for manufactured wood, and 

<1 ng WHO98 TEQ/kg for softwoods. 

Gullett et al. (2003) measured dioxin emissions from residential fireplace and woodstove 

appliances burning fuels available from the San Francisco Bay area. Common California natural 

firewoods and manufactured artificial logs were tested under operating conditions intended to 

reflect domestic use patterns in the Bay area, which are primarily episodic burning for aesthetic 

reasons. Average CDD/CDF emissions factors ranged from 0.25 to 1.4 ng WHO98 TEQ/kg of 

wood burned for natural wood fuels and 2.4 ng WHO98 TEQ/kg for artificial logs. 

Pfeiffer et al. (2000) measured CDD/CDF emissions from wood fired household 

appliances used in Germany. Emission factors ranged from 0.141 to 0.785 ng I-TEQ/kg. 
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appliances used in Belgium. The average emission factor was 22.4 ng I-TEQ/kg for burning 

untreated wood. 

 UNEP (2005) recommended an emission factor of 100 μg I-TEQ/TJ (TJ = terajoule or 

1012 joule) for virgin biomass-fired stoves. Assuming that wood combustion produces 

12−15 MJ/kg where MJ = megajoule or 106

 joule (UNEP, 2005), this converts to 1.2 to 

1.5 ng I-TEQ/kg of wood burned. 

The emission factor selected for indoor residential wood burning was based on 

Environment Canada (2000) because these tests took place in North America using indigenous 

wood, and they included the analysis of an EPA-certified wood stove. The mean value of the 

Environment Canada study (0.5 ng I-TEQ/kg wood or ng WHO98 TEQ/kg wood) was applied to 

all reference years.

Activity estimates were derived from EIA (2008b), which reports energy production from 

residential wood burning in BTUs. These were converted to mass of wood burned by dividing 

these values by 14,080 BTU/kg (average heat value of seasoned wood at 20% moisture—ORNL, 

2008). This yields estimates of 71 MMT in 1987, 37 MMT in 1995 and 30 MMT in 2000. 

4.2.1.2. Air Releases from Residential Outdoor Wood-Fired Boilers

 Outdoor wood-fired boilers (OWBs) are wood-fired furnaces used for heating, typically 

in residential settings. They are located some distance from the house, usually in an insulated 

shed. Each OWB houses an oversized firebox surrounded by a water jacket. Water is circulated 

through the jacket and piped underground to deliver hot water for space heating and domestic 

use. OWBs are designed to burn large amounts of wood over extended periods of time; 

fireboxes range in size from 20 ft3 to 150 ft3 and can heat buildings up to 20,000 ft2. They can 

produce from 115,000 BTU/hour up to 3.2 million BTU/hour, although most residential 

installations are less than 1 million BTU/hour (NESCAUM, 2006). 

Because OWBs operate in a cyclic fashion, they can produce large amounts of smoke. 

When an OWB is in the “off” cycle and does not need to generate heat, the air damper closes to 

cut off the air supply. This creates an oxygen-starved environment in which the fire smolders, 

creating smoke and creosote that condenses on the internal steel surfaces. When heat needs to be 

produced, the air damper opens and natural draft forces air into the firebox, pushing the smoke 
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1 and air pollutants out the stack. Measured emissions peak when the unit has received a fresh 

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load of fuel and the wood has not yet reached a charcoal stage. In the field test conducted by 

NESCAUM, the unit’s internal stack temperature never reached levels that would have resulted 

in complete combustion. In comparing emissions of particulate matter (PM) from various 

sources, it was noted that one OWB can emit as much PM as four heavy duty diesel trucks. 

Generally, OWBs do not use catalytic or noncatalytic emission control devices commonly 

employed by other residential combustion devices (NESCAUM, 2006). 

 OWBs have not been tested for CDD/CDF emissions. Their cyclic air flow and low 

operating temperatures (see discussion above), suggests that their emissions may be best 

represented by a value near the upper end of measurements for natural wood burned in wood 

stoves. Accordingly, an emission factor of 20 ng WHO98 TEQDF/kg wood (based on Wevers 

et al., 2003) is used to represent OWBs. This emission factor is assigned a preliminary 

confidence rating because it is not based on testing of actual OWBs. 

EPA estimates that there were more than 100,000 OWBs in use in the United States in 

2007; NESCAUM estimates that more than 155,000 units have been sold since 1990 (U.S. EPA, 

2007a). An average household in the Northeast (where many of these units are used) consumes 

63.1 million BTU per year for space heating (EIA, 2001). Multiplying this value by the 

100,000 OWBs in use suggests they produced a total of 6.3 trillion BTU in 2007. Dividing this 

value by 14,080 BTU per kilogram (the average heat value of seasoned wood at 20% moisture 

[ORNL, 2008]) yields a total wood consumption of 448,000 MTs in 2007, and this is assumed to 

apply to 2000. Because it is not known how many units were in operation in 1987 and 1995, the 

activity level could not be estimated for these years.

 This procedure assumes that all OWBs supply 100% of a home’s space heating needs, 

which may lead to an overestimate of wood consumed. The assumption that the 2007 activity 

value applies to 2000 also leads to an overestimate. However, the assumption that only seasoned 

wood is burned, when in fact unseasoned wood may also be used, would underestimate the 

amount of wood consumed. It is unclear to what extent these uncertainties offset each other.

4.2.1.3. Water Releases—None 
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1 4.2.1.4. Solid Residues from All Residential Wood Burning

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EPA (2006) summarizes studies measuring CDDs/CDFs in chimney soot from woodburning stoves and fireplaces by several researchers (Bumb et al., 1980; Nestrick and Lamparski, 

1982, 1983; Clement et al., 1985; Bacher et al., 1992; Van Oostam and Ward, 1995; DumlerGradl et al., 1995). The CDD/CDF levels ranged from 80 to 350 ng WHO98 TEQ/kg.

Wunderli et al. (1996) measured CDD/CDF levels in ash of wood-burning facilities in 

Switzerland. The facilities were characterized as small-to-medium sized, but they were not 

described in detail. Some of them had air pollution controls and may have been more 

sophisticated than most residential wood stoves. The mean level for natural wood burning was 

2.5 ng I-TEQ/kg of fly ash (n = 6) and 5.3 ng I-TEQ/kg of bottom ash (n = 8). UNEP (2005) 

used this reference to support their recommendation of 10 ng I-TEQ/kg of ash residue from 

biomass-fired stoves. 

4.2.1.5. Solid Residue Emission Factor

The CDD/CDF levels in soot are likely to be higher than bottom ash from wood burning, 

so the soot based studies noted above were not used to select an emission factor. Instead, the 

UNEP (2005) recommendation of 10 ng I-TEQ/kg of ash residue (based on Wunderli et al., 

[1996] data for wood-burning bottom ash) was selected as the best for residential wood burning. 

The congener profile for bottom ash from natural wood burning reported by Wunderli et al. 

(1996) indicated that the WHO98 TEQs were only about 4% greater than the I-TEQs. On this 

basis, the UNEP recommendation can also be expressed as 10 ng WHO98 TEQ/kg of ash residue. 

4.2.1.6. Solid Residue Activity Level

 The ash yield from wood grown in temperate zones is 0.1 to 1%, and bark produces 3 to 

8% ash (Ragland et. al, 1991). A mid-range value of 3% is assumed here for all wood burned. 

Multiplying this percentage by the amount of wood consumed (as reported above) yields the ash 

production amounts for each reference year: 2.13 MMT in 1987, 1.11 MMT in 1995, and 

0.9 MMT in 2000. 
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1 4.2.1.7. Solid Residue Releases

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Solid residue releases were estimated by multiplying the ash emission factor by the ash 

activity level. These release estimates include both indoor and outdoor sources of residential 

wood combustion. Some ash from residential wood combustion is disposed with household 

garbage that is sent to municipal landfills. This portion of the ash would not be considered a 

release to the open environment. The remainder is land disposed in a manner that is assumed to 

be releasable to the environment. One study reported that approximately 80% of all ash is land 

applied in the Northeast United States, less than 10% is land applied in the Southeast (University 

of Georgia, 2002). Because the portion going to a landfill is probably small, it is assumed here 

that all of the ash releases can be considered an environmental release. 

4.2.1.8. Release Summary

The inventory decision criteria and release estimates to all media are summarized below: 

Inventory Decision Criteria for Indoor Residential Wood Burners

Air Water Solids Products

Emission tests for at least two units/source types with Yes Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes Yes

differences. 

Emission factor tests represent units that are typical of the Yes Yes

class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q Q
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Residential Wood Combustion

Air Releases

Emission Factor

Indoor Residential Wood Burners

• 1987—0.5 ng WHO98 TEQDF/kg (I-TEQDF/kg) of wood. 

• 1995—0.5 ng WHO98 TEQDF/kg (I-TEQDF/kg) of wood. 

• 2000—0.5 ng WHO98 TEQDF/kg (I-TEQDF/kg) of wood. 

Outdoor Wood-Fired Boilers 

• 1987—20 ng WHO98 TEQDF/kg of wood (Preliminary).

• 1995—20 ng WHO98 TEQDF/kg of wood (Preliminary).

• 2000—20 ng WHO98 TEQDF/kg of wood (Preliminary).

Activity Level

Indoor Residential Wood Burners 

• 1987—71 MMT. 

• 1995—37 MMT.

• 2000—30 MMT. 

Outdoor Wood-Fired Boilers 

• 1987—Not Available.

• 1995—Not Available.

• 2000—0.448 MMT (Preliminary).

Releases

Indoor Residential Wood Burners

• 1987—36 g (WHO98 TEQDF or I-TEQDF). 

• 1995—19 g (WHO98 TEQDF or I-TEQDF). 

• 2000—15 g (WHO98 TEQDF or I-TEQDF). 

Outdoor Wood-Fired Boilers 

• 1987—Not Available

• 1995—Not Available

• 2000—9 g WHO98 TEQDF (Preliminary).

Water Releases

None.

1 
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Residential Wood Combustion (continued)

Solid Residue Releases

Emission Factors 

• 1987—10 ng WHO98 TEQDF/kg (I-TEQDF/kg) of ash. 

• 1995—10 ng WHO98 TEQDF/kg (I-TEQDF/kg) of ash. 

• 2000—10 ng WHO98 TEQDF/kg (I-TEQDF/kg) of ash.

Activity Levels

• 1987—2.13 MMT of ash. 

• 1995—1.11 MMT of ash. 

• 2000—0.9 MMT of ash.

Releases

• 1987—21 g (WHO98 TEQDF or I-TEQDF). 

• 1995—11 g (WHO98 TEQDF or I-TEQDF). 

• 2000—9 g (WHO98 TEQDF or I-TEQDF).

Products

None.

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4.2.2. Industrial Wood Combustion 

4.2.2.1. Air Releases

No changes were made to the emission factor estimates for industrial burning of salt and 

nonsalt laden wood. However, an additional study is discussed below which shows that 

combustion temperature and wood condition can have a large impact on emission factors. 

Yasuhara et al. (2003) measured CDD/CDF emissions from a wood burning incinerator 

in Japan. With combustion temperature of about 600ΕC, the following emission factors 

(ng WHO98 TEQ/kg) were measured: pine—167, cedar—164, seawater impregnated pine—392, 

seawater impregnated cedar bark—559 and seawater impregnated cedar without bark—828. 

Much lower emission factors were measured when the combustion temperature was increased to 

800ΕC: pine—2.3, beech—3.5, chlordane impregnated waste wood—40 and pentachlorophenol 

impregnated waste wood—44. 

 For nonsalt laden wood, the mean of the emission factors derived from the four CARB 

studies and five NCASI studies (assuming nondetect values were zero) is 

0.6 ng WHO98 TEQDF/kg wood (0.56 ng I-TEQDF/kg wood) and is used in this document as the 

most representative of industrial wood combustion for all reference years.

NCASI (1995) concluded that CDD/CDF emissions from facilities burning salt-laden 

wood residue may be considerably higher than those from facilities burning salt-free wood. The 
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1 overall average of the five tested facilities in Canada (Luthe et al., 1998) and the United States

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(U.S. EPA, 1987), 13.2 ng I-TEQDF/kg of wood, was applied to all three reference years. Based 

on the congener profile reported by Luthe et al. (1998), this converts to 15.3 ng WHO98 TEQ/kg.

Similarly, no change was made to the activity estimate for salt laden wood. However, the 

activity estimate for nonsalt laden wood was changed for all years to reflect more recent data in 

EIA (2008c). Values are reported in the release summary below.

4.2.2.2. Water Literature—None

4.2.2.3. Solid Residue Releases

 As indicated in U.S. EPA (2006), the ash concentrations from the NCASI Handbook 

(13.2 ng WHO98 TEQDF/kg) appears to fall within the range of values reported in the various 

studies and a reasonable value for mixed bottom and fly ash. Oeheme and Muller (1995) 

measured CDD/CDF levels in ash from wood-fired boilers in Switzerland. The levels in bottom 

ash were on the order of 1 ng I-TEQ/kg when natural wood was incinerated. However, in filter 

ash the levels were about two orders of magnitude higher. Burning of waste wood from house 

demolition and construction resulted in concentrations in the range of 1–10 ng I-TEQ/kg. 

 The ash yield from wood grown in temperate zones is 0.1 to 1%, and bark produces 3 to 

8% ash (Ragland et al, 1991). A mid-range value of 3% is assumed here for all wood burned. 

Multiplying this percentage by the amount of wood consumed (as reported in the release 

summary below) yields the ash production amounts for each reference year: 3.48 MMT in 1987, 

3.51 MMT in 1995, and 3.48 MMT in 2000. 

All ash from industrial wood combustion is assumed to be disposed in a secure landfill 

and is, therefore, not considered an environmental release. However, the amounts of dioxin in 

landfilled ash from industrial wood burning can be estimated by multiplying the ash 

concentration and ash amounts presented above. This yields the following estimates: 

• 1987—46 g WHO98 TEQDF/kg

• 1995—46 g WHO98 TEQDF/kg

• 2000—46 g WHO98 TEQDF/kg
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1 4.2.2.4. Release Summary

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The inventory decision criteria and release estimates to all media are summarized below: 

Inventory Decision Criteria for Industrial Wood Combustion

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
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Industrial Wood Combustion

Air Releases

Emission Factor

Nonsalt-Laden Wood 

• 1987—0.6 ng WHO98 TEQDF/kg (0.56 ng I-TEQDF/kg) of wood. 

• 1995—0.6 ng WHO98 TEQDF/kg (0.56 ng I-TEQDF/kg) of wood. 

• 2000—0.6 ng WHO98 TEQDF/kg (0.56 ng I-TEQDF/kg) of wood. 

Salt-Laden Wood 

• 1987—15 ng WHO98 TEQ/kg (13 ng I-TEQDF/kg) of wood. 

• 1995—15 ng WHO98 TEQ/kg (13 ng I-TEQDF/kg) of wood. 

• 2000—15 ng WHO98 TEQ/kg (13 ng I-TEQDF/kg) of wood.

Activity Level

Nonsalt-Laden Wood 

• 1987—116 MMT. 

• 1995—117 MMT. 

• 2000—116 MMT. 

Salt-Laden Wood

• 1987—0.5 MMT. 

• 1995—0.5 MMT. 

• 2000—0.8 MMT.

Releases

Nonsalt-Laden Wood

• 1987—70 g WHO98 TEQDF (65 g I-TEQDF). 

• 1995—70 g WHO98 TEQDF (65 g I-TEQDF). 

• 2000—70 g WHO98 TEQDF (65 g I-TEQDF). 

Salt-Laden Wood

• 1987—8 g WHO98 TEQDF (7 g I-TEQDF).

• 1995—8 g WHO98 TEQDF (7 g I-TEQDF).

• 2000—12 g WHO98 TEQDF (10 g I-TEQDF).

Total Industrial Releases 

• 1987—78 g WHO98 TEQDF (72 g I-TEQDF).

• 1995—78 g WHO98 TEQDF (72 g I-TEQDF).

• 2000—82 g WHO98 TEQDF (75 g I-TEQDF).

Water Releases

None.

Solid Residue Releases

All ash is assumed to be landfilled and, therefore, is not considered to be an environmental 

release.

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Industrial Wood Combustion (continued)

Products

None.

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4.3. OIL COMBUSTION

 Section 4.1 covered combustion of gasoline and diesel fuels in engines. This section 

addresses the combustion of other types of distillate oil products and residual fuel oils. These 

products are burned primarily in furnaces or boilers in both residential/institutional settings and 

in large industrial facilities. Distillate fuel oils are distilled from crude oil. Residual oils are 

what remain of the crude oil after gasoline, and the distillate fuel oils are extracted through 

distillation. Residual and distillate oils are further distinguished by grade: Numbers 1 and 2 are 

distillate oils. No. 1 is similar to kerosene and is the fraction that boils off right after gasoline. 

No. 2 is the diesel that trucks and some cars run on, leading to the name “road diesel”; this 

category is addressed in Section 4.1. 

Fuel Grades 5 and 6 are residual oils and sometimes referred to as “heavy fuel oils.” 

Number 6 fuel oil is sometimes referred to as Bunker C. Fuel Grade 4 is either distillate oil or a 

mixture of distillate and residual oils. Distillate oils are more volatile and less viscous than 

residual oils, which have negligible nitrogen and ash content, and usually contain less than 

0.3% sulfur (by weight). Distillate oils are used mainly in domestic and small commercial 

applications. The heavier residual oils (Grades 5 and 6), being more viscous and less volatile 

than distillate oils, must be heated for ease of handling and to facilitate proper atomization. 

Because residual oils are produced from the residue after the lighter fractions are removed from 

the crude oil, they may contain significant quantities of ash, nitrogen, and sulfur. 

 

4.3.1. Institutional/Commercial and Residential Oil Combustion

4.3.1.1. Air Releases

No changes were made to the emission factors. No testing for CDD/CDF emissions from 

commercial or residential oil-fired combustion units in the United States could be located. 

However, EPA (1997a) estimated CDD/CDF congener group and TEQ emission factors using 

average CDD/CDF concentrations reported for soot samples from 21 distillate fuel oil-fired 

furnaces used for central heating in Canada and a PM emission factor for distillate fuel oil 

combustors (300 mg/L oil) obtained from AP-42 (U.S. EPA, 1995a). The TEQ emission factor 
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1 estimate—0.19 ng WHO98 TEQDF/L of oil (0.15 ng I-TEQDF/L of oil)—was derived using the 

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calculated emission factors for 2,3,7,8-TCDD, 2,3,7,8-TCDF, and the 10 congener groups. 

These results are near the upper end of the range from Pfeiffer et al. (2000) who measured 

CDD/CDF emissions from oil fired household appliances used in Germany. Emission factors 

were in the range of 0.025 to 0.135 ng I-TEQ/kg.

Minor updates were made to the activity estimates. EIA (2008a) data were used to derive 

the activity levels. EIA supplied yearly data on total distillate fuel oil and total residual fuel oil 

supplied in the United States. EIA also provided a breakdown of fuel oil sales by sector for the 

years back to 2001. The sector percentages for 2001 were assumed to apply to each of the 

reference years. These percentages were multiplied by the totals (also used conversion factors of 

42 gal/barrel and 3.79 L/gal) to estimate the amount of distillate fuel oil consumed in the 

residential and commercial sectors. On this basis, the following estimates were made for each 

reference year: 1987—29.4 billion L, 1995—31.7 billion L, and 2000—36.9 billion L.

4.3.1.2. Water Releases—None

4.3.1.3. Solid Residue Releases—None

4.3.1.4. Products—None

4.3.1.5. Release Summary

The inventory decision criteria and release estimates are summarized below: 
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Inventory Decision Criteria for Institutional/Commercial and Residential Oil Combustion

Air Water Solids Products

Emission tests for at least two units/source types with sufficient 

documentation to directly derive emission factors. 

Yes

Measured emission factors consistent or have understandable 

differences. 

Yes

Emission factor tests represent units that are typical of the class. Yes

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

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Institutional/Commercial and Residential Oil Combustion

Air Releases

Emission Factors

• 1987—190 pg WHO98 TEQDF/L (150 pg I-TEQDF/L) of oil combusted. 

• 1995—190 pg WHO98 TEQDF/L (150 pg I-TEQDF/L) of oil combusted. 

• 2000—190 pg WHO98 TEQDF/L (150 pg I-TEQDF/L) of oil combusted. 

Activity Levels

• 1987—29.4 billion L. 

• 1995—31.7 billion L. 

• 2000—36.9 billion L. 

Releases

• 1987—6 g WHO98 TEQDF (4 g I-TEQDF). 

• 1995—6 g WHO98 TEQDF (5 g I-TEQDF). 

• 2000—7 g WHO98 TEQDF (6 g I-TEQDF). 

Water Releases

These facilities do not have wastewater releases.

Solid Residue Releases

These facilities do not have solid releases.

Products

None.

4.3.2. Utility Sector and Industrial Oil Combustion

 Minor changes were made to the activity estimates as explained below. 
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1 4.3.2.1. Air Literature

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In 1993, the Electric Power Research Institute (EPRI) sponsored a project to gather 

information of consistent quality on power plant emissions. The Field Chemical Emissions 

Measurement (FCEM) project included testing of two cold-sided, ESP-equipped, oil-fired power 

plants for CDD/CDF emissions. EPA (1997a) reports on testing at oil fired utility boilers for a 

variety of furnace configurations and APCDs. 

 Some boilers use low-NOx burners, which reduce flame turbulence, delay fuel/air 

mixing, and establish fuel-rich zones within the boiler during initial combustion. The longer, 

less intense flames that result from the altered combustion lower flame temperatures and reduce 

thermal NOx formation (Colburn, 1996), Because low-NOx burners reduce temperatures and, 

thus, the completeness of combustion the potential exists for increased CDD/CDF formation. 

However, this has not yet been evaluated via stack testing. 

4.3.2.2. Air Emission Factor

 EPA (2006) based the emission factor on the average of the EPRI (1994) and EPA 

(1997a) studies. The emission factor—230 pg WHO98 TEQDF/L oil combusted 

(200 pg I-TEQDF/L oil combusted)—was applied to all three reference years. 

4.3.2.3. Activity Level

 Updated EIA data were used to derive the activity levels. EIA supplied yearly data on 

total distillate fuel oil and total residual fuel oil supplied in the United States. EIA also provided 

a breakdown of fuel oil sales by sector for the years back to 2001. The sector percentages for 

2001 were assumed to apply to each of the reference years. Multiplying these percentages by the 

totals yields the following estimates for each reference year (also used conversion factors of 

42 gal/barrel and 3.79 L/gal):

Distillate Fuel Oil—Industrial and Electric Power Use

• 1987—10.4 billion L

• 1995—11.2 billion L

• 2000—13.0 billion L
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1 Residual Fuel Oil—Total

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• 1987—73.4 billion L

• 1995—49.5 billion L

• 2000—53.0 billion L

4.3.2.4. Air Releases

The air releases were estimated by multiplying the emission factor and activity estimates. 

4.3.2.5. Water Releases—None

4.3.2.6. Solid Residue Releases—None

4.3.2.7. Products—None

4.3.2.8. Release Summary

The inventory decision criteria and release estimates are summarized below: 

Inventory Decision Criteria for Utility Sector and Industrial Oil Combustion

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission factors. 

Yes

Measured emission factors consistent or have understandable 

differences. 

Yes

Emission factor tests represent units that are typical of the 

class. 

Yes

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
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Utility Sector and Industrial Oil Combustion

Air Releases

Emission Factors 

• 1987—230 pg WHO98

• 1995—230 pg WHO98

• 2000—230 pg WHO98

TEQDF/L (200 pg I-TEQDF/L) of oil combusted. 

TEQDF/L (200 pg I-TEQDF/L) of oil combusted. 

TEQDF/L (200 pg I-TEQDF/L) of oil combusted. 

Activity Level

• 1987—83.8 billion L. 

• 1995—60.7 billion L. 

• 2000—66.0 billion L. 

Releases

• 1987—19 g WHO98

• 1995—14 g WHO98

• 2000—15 g WHO98

TEQDF

TEQDF

TEQDF

(17 g I-TEQDF). 

(12 g I-TEQDF). 

(13 g I-TEQDF). 

Water Releases

These facilities do not have wastewater releases.

Solid Residue Releases

These facilities do not have solid releases.

Products

These facilities do not have products.

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4.3.3. Waste Oil Combustion

Waste oil includes used crankcase oils from automobiles and trucks, used industrial 

lubricating oils (such as metal working oils), and other used industrial oils (such as heat transfer 

fluids). When discarded, these oils become waste oils due to a breakdown of physical properties 

and contamination by the materials they come in contact with. The different types of waste oils 

may be burned as mixtures or as single fuels where supplies allow. Waste, or used, oil can be 

burned in a variety of combustion systems including industrial boilers; commercial/institutional 

boilers; space heaters; asphalt plants; cement and lime kilns; other types of dryers and calciners; 

and steel-production blast furnaces (U.S. EPA, 1998c). USDOE (2006) reports the following 

breakout for 2006 in billions of gallons: 

Asphalt Plants - 0.286 

Space Heaters - 0.113 

Industrial Boilers - 0.093 

Utility Boilers - 0.080 
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Cement Kilns - 0.033 

Others - 0.095 (includes: marine boilers, pulp & paper mills, commercial boilers)

Total - 0.780 

CDD/F emissions from all of these facility types except space heaters were covered in other parts 

of this document. So this section will address only releases from space heaters. 

4.3.3.1. Air Literature

Bremmer et al. (1994) measured the CDD/CDF emissions from the combustion of used 

oil by small combustion units in the Netherlands. Flue gases from a garage stove consisting of 

an atomizer fueled by spent lubricating oil from diesel engines (35 mg Cl!

/kg) were reported to 

contain 0.1 ng I-TEQDF/Nm3

 (2 ng I-TEQDF/kg) oil burned. The flue gases from a hot water 

boiler consisting of a rotary cup burner fueled with the organic phase of rinse water from oil 

tanks (340 mg Cl!/kg) contained 0.2 ng I-TEQDF/Nm3 (4.8 ng I-TEQDF/kg) oil burned. The flue 

gases from a steam boiler consisting of a rotary cup burner fueled by processed spent oil (240 mg 

Cl!/kg) contained 0.3 ng I-TEQDF/Nm3 (6 ng I-TEQDF/kg) oil burned. The emission factor for a 

ferry burning heavy fuel oil containing 11 ng/kg organic chlorine was 3.2 to 6.5 ng I-TEQDF/kg 

oil burned. From these data, Bremmer et al. (1994) derived an average emission factor for 

combustion of used oil of 4 ng I-TEQDF/kg oil burned. 

Measured data from the burning of recycled waste oils are available from Austria, where 

emissions from a small incinerator gave a concentration of 0.02 ng TEQ/Nm3 (at 11% O2) 

equivalent to an emission factor of 0.37 ng TEQ/kg of waste oil burned (LUA, 1997). 

4.3.3.2. Air Emission Factor

The emission factor measured by Bremmer et al. (1994) for small combustion units was 

selected as most relevant to space heaters, i.e. 2 ng I-TEQDF/kg. Based on the limited data from 

only one study and uncertainty about how the units tested by Bremmer et al. compare to space 

heaters in the U.S., this is considered to be a preliminary estimate.
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The total amount of waste oil burned in 1983 was 0.59 billion gallons (USEPA, 1993). 

Comparing this estimate with the 2006 estimate (described above) and assuming linear growth, 

implies that used oil combustion has increased at a rate of about 1.4% per year. The 2006 data 

indicates that 14.5 % of the total waste burned was in space heaters. Assuming this percentage 

remains constant and using the annual growth rate, allows estimates of the amount of oil burned 

in space heaters for each of the reference years (converted to kg based on 3.78 L/gal and density 

of 0.88 kg/L): 

1987 – 0.30 billion kg 

1995 – 0.33 billion kg 

2000 – 0.35 billion kg 

Based on the lack of survey data specific to the reference years and facility types, these estimates 

are considered preliminary.

4.3.3.4. Air Releases

The air releases were estimated by multiplying the emission factor and activity estimates.

4.3.3.5. Water Releases – None

4.3.3.6. Solid Residue Releases – None.

4.3.3.7. Products – None.

4.3.3.8. Release Summary

The inventory decision criteria and release estimates are summarized below:

Inventory Decision Criteria for Waste Oil Combustion

Air Water Solids Product

Emission tests for at least two units/source types with No

sufficient documentation to directly derive emission factors
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Inventory Decision Criteria for Waste Oil Combustion

Measured emission factors consistent or have Yes

understandable differences

Emission factor tests represent units that are typical of the No

class 

Activity estimates based on source-specific surveys No

Conclusion (Q = Quantitative, P = Preliminary) P

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Waste Oil Combustion

Air Releases

Emission Factors 

• 1987 – 2 ng I-TEQDF/kg oil combusted (Preliminary)

• 1995 – 2 ng I-TEQDF/kg oil combusted (Preliminary)

• 2000 – 2 ng I-TEQDF/kg oil combusted (Preliminary)

Activity Levels 

• 1987 – 0.30 billion kg (Preliminary) 

• 1995 – 0.33 billion kg (Preliminary) 

• 2000 – 0.35 billion kg (Preliminary)

Releases

• 1987 – 0.60 g I-TEQDF (Preliminary)

• 1995 – 0.66 g I-TEQDF (Preliminary)

• 2000 – 0.70 g I-TEQDF (Preliminary)

Water Releases

These facilities do not have wastewater releases.

Solid Residue Releases

These facilities do not have solid releases.

Products

These facilities do not have products. 

4.4. COAL COMBUSTION

4.4.1. Coal-Fired Power Plants

No changes were made to the air emission factors or activity estimates, but additional 

background information is provided. Minor changes were made to the activity estimates for 

solid residues resulting in minor changes in residue amounts. 
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1 4.4.1.1. Air Releases

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 UNEP (2005) reports that Dutch data from large coal-fired power plants gave an 

emission factor of 0.35 μg I-TEQ/MT; German data were between 0.004 and 0.2 μg I-TEQ/MT , 

and U.K. data had a median value of 0.14 μg I-TEQ/MT (range: 0.06–0.32 μg I-TEQ/MT). 

 As discussed in EPA (2006), EPRI and DOE data were used to derive an emission factor 

of 0.078 ng WHO98 TEQDF/kg of coal combusted (0.079 ng I-TEQDF/kg). This is an average 

over 11 U.S. facilities, but it is on the low end of the range reported in UNEP (2005) for 

European facilities. Thus, there is some concern that this emission factor may be an 

underestimate. One reason why it may be low is because all of the tested facilities had 

cold-sided ESPs and experience in other industries suggested that higher emissions were likely 

from facilities with hot-sided ESPs. In recognition of this concern, EPA/Department of Energy 

(DOE) conducted testing of stack emissions in 1999 at the coal-fired Presque Island electric 

utility boiler in Wisconsin, which was equipped with a hot-sided ESP. The testing showed no 

increases in dioxin concentrations from the flue gas inlet to the outlet of a hot-sided ESP 

(personal communication from Thomas Feeley, National Energy Technical Laboratory, 

U.S. Department of Energy, Pittsburgh, PA to David Cleverly, National Center for 

Environmental Assessment, U.S. Environmental Protection Agency, Washington, DC on 

December 17, 2008). Accordingly, it is assumed that the TEQ emission factor for coal fired 

utilities with hot-sided ESPs is of the same order of magnitude as the average TEQ emission 

factors derived above. 

 In the year 2000, 10 facilities with an SIC code for electric services reported dioxin 

releases under the EPA TRI program (U.S. EPA, 2008). The sum of the air releases across these 

facilities was 63.2 g, which EPA estimates is equal to 8.9 g WHO98 TEQDF. No releases to other 

media were reported. Also, in the year 2000, two facilities with an SIC code for electric and 

other services combined reported dioxin releases under EPA’s TRI program (U.S. EPA, 2008). 

The sum of the air releases across these facilities was 457 g, which EPA estimates is equal to 

22.2 g WHO98 TEQDF. No releases to other media were reported. As explained in Chapter 1, the 

TRI data are not used to make quantitative estimates in this document but rather as supportive 

evidence that releases do occur.

The activity estimates were derived from EIA (1999b).
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1 4.4.1.2. Water Releases

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No data on CDD/CDF levels in water releases from these facilities were found. Because

CDD/CDFs are found in the air emissions from these facilities, it is possible they could also be 

found in scrubber waters. Thus, water releases of CDD/CDFs from these facilities are 

considered possible but unquantifiable.

4.4.1.3. Solid Residue Releases

Dyke et al. (1997) provided data on residues from industrial coal combustion in the 

United Kingdom: Concentrations in fly ash were 0.23–8.7 ng TEQ/kg ash, and grate ash were 

0.02–13.5 ng TEQ/kg. UNEP (2005) used these data to derive an average value of 

4 ng I-TEQ/kg. A limited amount of CDD/CDF concentration data have been developed for ash 

from coal combustion facilities in the United States (U.S. EPA, 1999c), and these data are for 

wastes that are comanaged (i.e., combinations of fly ash, bottom ash, boiler slag, and flue gas 

desulfurization wastes). A total of 15 samples were taken from 11 disposal sites. The total mean 

concentration was 0.73 ng WHO98 TEQDF/kg (0.62 ng I-TEQDF/kg).

 The total mean concentration from EPA (1999c) was selected as the only U.S. data 

available and within the range reported for the United Kingdom. This value of 

0.73 ng WHO9 TEQDF/kg (0.62 ng I-TEQDF/kg) was assumed to apply to all reference years.

The American Coal Ash Association (ACAA—http://www.acaa-usa.org/) releases annual 

production and use estimates for coal ash. Production estimates for the reference years are as 

follows: 

• 1987—75.4 MMT

• 1995—83.6 MMT

• 2000—98.2 MMT

 According to ACAA, between 25 and 30% of industrial coal ash was recycled in a variety 

of ways including use in cement, grout, road base materials, manufactured aggregate, fill 

material, snow/ice control, and agriculture. These amounts were estimated as 30% of the total 

ash:
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1 • 1987—22.6 MMT

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• 1995—25.1 MMT

• 2000—29.5 MMT

The potential for environmental releases from these uses is unknown, but it is assumed here that 

all of the CDD/CDF in the recycled ash represent an environmental release (release estimates are 

shown in the summary below). The emission factor presented above is based on recent testing at 

11 disposal sites, but it is uncertain how much actual release occurs from these products. 

The ash that was not recycled was disposed of in landfills, and these residues are not 

considered environmental releases. These amounts were multiplied by the ash emission factor 

(presented above) to get the amount landfilled (on a TEQ basis): 

• 1987—38.5 g WHO98 TEQDF (32.7 g I-TEQDF) 

• 1995—42.7 g WHO98 TEQDF (36.3 g I-TEQDF) 

• 2000—50.2 g WHO98 TEQDF (42.6 g I-TEQDF) 

4.4.1.4. Product Literature—None

4.4.1.5. Release Summary

The inventory decision criteria and release estimates for all media are summarized below: 
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Inventory Decision Criteria for Industrial Coal-Fired Utilities

Air Water Solids Products

Emission tests for at least two units/source types with sufficient Yes Yes

documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes Yes

differences. 

Emission factor tests represent units that are typical of the class. Yes Yes

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q Q

1 
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Industrial Coal-Fired Utilities

Air Releases

Emission Factor

• 1987—0.078 ng 

• 1995—0.078 ng 

• 2000—0.078 ng 

WHO98 TEQDF/kg 

WHO98 TEQDF/kg 

WHO98 TEQDF/kg 

(0.079 ng 

(0.079 ng 

(0.079 ng

I-TEQDF/kg). 

I-TEQDF/kg). 

I-TEQDF/kg).

Activity Levels

• 1987—651 MMT. 

• 1995—771 MMT. 

• 2000—894 MMT.

Releases

• 1987—51 g WHO98 TEQDF

• 1995—60 g WHO98 TEQDF

• 2000—70 g WHO98 TEQDF

(51 g I-TEQDF). 

(61 g I-TEQDF). 

(71 g I-TEQDF).

Water Releases

Because some evidence exists that wastewater from these facilities may contain CDDs and 

CDFs, they are classified as possible but unquantifiable (Not quantifiable) sources.

Solid Residue Releases

Emission Factor

• 1987—0.73 ng WHO98

• 1995—0.73 ng WHO98

• 2000—0.73 ng WHO98

TEQDF/kg (0.62 ng I-TEQDF/kg) of ash. 

TEQDF/kg (0.079 ng I-TEQDF/kg) of ash. 

TEQDF/kg (0.079 ng I-TEQDF/kg) of ash.

Activity Levels

• 1987—22.6 MMT

• 1995—25.1 MMT

• 2000—29.5 MMT

ash. 

ash. 

ash.

Releases

• 1987—17 g WHO98 TEQDF

• 1995—18 g WHO98 TEQDF

• 2000—22 g WHO98 TEQDF

(14 g I-TEQDF). 

(16 g I-TEQDF). 

(18 g I-TEQDF).

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4.4.2. Coal-Fired Industrial Boilers

4.4.2.1. Air Releases

No changes were made to the air emission factors, but they were upgraded from a 

confidence rating of preliminary to quantifiable. This was because they were based on a 

reasonably large study (n = 15) from the U.K. (CRE, 1994) and the likelihood that the 

technologies were similar to U.S. facilities. The activity estimates were updated using EIA 

(2006), which indicated that the amount of coal burned in industrial utilities was 68.2 MMT in 

1987, 66.3 MMT in 1995, and 59.2 MMT in 2000. 
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1 4.4.2.2. Water Literature

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No data on CDD/CDF levels in water releases from these facilities were found. Because

CDD/CDFs are found in the air emissions from these facilities, it is possible they could also be 

found in scrubber waters. Thus, water releases of CDD/CDFs from these facilities are 

considered possible but unquantifiable.

4.4.2.3. Solid Residue Releases

No data on the CDD/CDF content of ash from industrial boilers were found; however, 

this should be similar to the values presented in Section 4.4.1 for coal-fired utilities. Also, the 

activity estimates presented for coal-fired utilities include ash from all coal combustion used to 

generate electricity. Thus, they should represent most of the industrial utility boilers. So it is 

assumed that the solid residue releases presented for the utilities include the releases from 

industrial boilers (see Section 4.4.1). 

4.4.2.4. Release Summary

The inventory decision criteria and release estimates for all media are summarized below: 

Inventory Decision Criteria for Industrial Coal-Fired Boilers

Air Water Solids Products

Emission tests for at least two units/source types with sufficient Yes

documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
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Industrial Coal-Fired Boilers

Air Releases

Emission Factors 

• 1987—0.7 ng WHO98 TEQDF/kg (0.6 ng I-TEQDF/kg)of coal combusted. 

• 1995—0.7 ng WHO98 TEQDF/kg (0.6 ng I-TEQDF/kg) of coal combusted. 

• 2000—0.7 ng WHO98 TEQDF/kg (0.6 ng I-TEQDF/kg) of coal combusted.

Activity Levels

• 1987—68.2 MMT. 

• 1995—66.3 MMT. 

• 2000—59.2 MMT.

Releases

• 1987—48 g WHO98 TEQDF (41 g I-TEQDF). 

• 1995—46 g WHO98 TEQDF (40 g I-TEQDF). 

• 2000—41 g WHO98 TEQDF (36 g I-TEQDF).

Water Releases

Because some evidence exists that wastewater from these facilities may contain CDDs and 

CDFs, they are classified as possible but unquantifiable sources.

Solid Residue Releases

These releases are included in the estimates for coal-fired utilities presented in Section 4.4.1.

Products

No information was found suggesting that products from these facilities would contain CDDs

and CDFs.

4.4.3. Residential Coal Combustion 

4.4.3.1. Air Releases

No changes were made to the air emission factor, but it was upgraded from preliminary to 

quantitative. Also a new study was found as summarized below. 

Paradiz et al. (2008) measured CDD/F emissions from a coal fired domestic stove. The 

study was conducted in Italy using a high chlorine content coal. Testing with a non-insulated 

chimney yielded an emission factor of 1326 I-TEQ μg/ton of coal burned. Testing with an 

insulated chimney yielded an emission factor of 126 I-TEQ μg/ton of coal burned. A 

pronounced effect of the temperature profile in the chimney on PCDD/F emissions was 

identified, suggesting formation in the chimney. 

As discussed in the original document, the emission factor was based on an analysis by 

Eduljee and Dyke (1996) on data from the Coal Research Establishment in the United Kingdom 

(2.1 ng I-TEQDF/kg for anthracite coal and 5.7 to 9.3 ng I-TEQDF/kg [midpoint, 
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1 7.5 ng I-TEQDF/kg] for bituminous coal). Wevers et al. (2003) measured CDD/CDF emissions 

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from various types of household appliances used in Belgium. The average emission factor for 

anthracite coal burners was 77.1 ng I-TEQ/kg. UNEP (2005) reports that European studies 

generally show a range of 1.6 to 50 ng TEQ/kg for typical coal and emission factors as high as 

660 ng I-TEQ/kg for high chlorine coals. Ultimately UNEP (2005) recommends 3 ng I-TEQ/kg 

for domestic burning with typical coals. Based on the similarity of the emission factor data 

summarized by UNEP for typical coals and estimates by Eduljee and Dyke (1996), the emission 

factor was upgraded from preliminary to quantitative. The congener data for emissions from 

normal lignite (Thub et al., 1995), indicate that the WHO98 TEQs were less than 9% higher than 

the I-TEQs. Based on this small difference, the I-TEQ emission factor was assumed to be 

essentially equivalent when expressed as WHO98 TEQs.

The activity estimates were updated using EIA (2006), which indicated that the amount 

of coal burned at residences was 1.6 MMT in 1987, 0.8 MMT in 1995, and 0.5 MMT in 2000. 

EPA (1997a) reported that 72.5% of the coal consumed by the residential sector in 1990 was 

bituminous and 27.5% was anthracite. These factors were assumed to apply to all reference 

years.

4.4.3.2. Water Releases—None

4.4.3.3. Solid Residue Releases

The solid residues from coal-fired utility boilers are likely to be similar to the solid 

residues from residential units. On this basis, the same emission factor is assumed to apply, i.e., 

0.73 ng WHO98 TEQDF/kg (0.62 ng I-TEQDF/kg). UNEP (2005) suggests a “first estimate” 

emission factor for residues from coal fired stoves of 5,000 ng I-TEQ/kg. This is based on 

measurements in soot, which may not be representative of bottom ash. A preliminary confidence 

rating is assigned to this emission factor because it is based on testing from different facilities.

The total amount of ash generated by these facilities is assumed to be 10% of the total 

coal used. On this basis, the solid residues are estimated to be 0.16 MMT in 1987, 0.08 MMT in 

1995, and 0.05 MMT in 2000. Some of this ash is likely to be disposed along with household 

trash and taken to a municipal landfill. This portion would not be considered an environmental 

release. Others may dispose of it on their property in a manner that is open to the environment. 
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4.4.3.4. Products—None

4.4.3.5. Release Summary

The inventory decision criteria and release estimates for all media are summarized below: 

Inventory Decision Criteria for Residential Coal Combustion

Air Water Solids Products

Emission tests for at least two units/source types with sufficient Yes No

documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the class. Yes No

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q P
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Residential Coal Combustion

Air Releases

Emission Factors

Anthracite

• 1987—2.1 ng 

• 1995—2.1 ng 

• 2000—2.1 ng 

Bituminous

• 1987—7.5 ng 

• 1995—7.5 ng 

• 2000—7.5 ng 

WHO98

WHO98

WHO98

WHO98

WHO98

WHO98

TEQDF/kg (2.1 ng 

TEQDF/kg (2.1 ng 

TEQDF/kg (2.1 ng 

TEQDF/kg (7.5 ng 

TEQDF/kg (7.5 ng 

TEQDF/kg (7.5 ng 

I-TEQDF/kg). 

I-TEQDF/kg). 

I-TEQDF/kg). 

I-TEQDF/kg). 

I-TEQDF/kg). 

I-TEQDF/kg). a Activity Levels

• 1987—1.6 MMT. 

• 1995—0.8 MMT. 

• 2000—0.5 MMT.

Releases

•

•

•

1987—10 g WHO98 TEQDF or I-TEQDF. 

1995—5 g WHO98 TEQDF or I-TEQDF. 

2000—3 g WHO98 TEQDF or I-TEQDF.

Water Releases

These facilities do not have wastewater releases.

Solid Residue Releases

Emission Factors 

• 1987—0.73 ng WHO98

• 1995—0.73 ng WHO98

• 2000—0.73 ng WHO98

TEQDF/kg (0.62 ng I-TEQDF/kg) 

TEQDF/kg (0.62 ng I-TEQDF/kg) 

TEQDF/kg (0.62 ng I-TEQDF/kg) 

(Preliminary). 

(Preliminary). 

(Preliminary).

Activity Levels

• 1987—0.16 MMT. 

• 1995—0.08 MMT. 

• 2000—0.05 MMT. b Releases

•

•

•

1987—0.1 g WHO98 TEQDF (0.1 g I-TEQDF) (Preliminary). 

1995—0.1 g WHO98 TEQDF (0.1 g I-TEQDF) (Preliminary). 

2000— <0.1 g WHO98 TEQDF (<0.1 g I-TEQD) (Preliminary).

Products

These facilities do not have products.

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Note: 72.5% of the coal burned is bituminous, and 27.5% is anthracite. b

Note: An unknown portion of this is landfilled and, therefore, is not considered a release to the open environment. 
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1 5. COMBUSTION SOURCES OF CDDS/CDFS: OTHER

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HIGH-TEMPERATURE SOURCES

5.1. CEMENT KILNS

5.1.1. Air Releases

No changes were made to the air-release estimates from cement kilns. However, 

additional background information is provided below. 

The present report uses higher emission factors for cement kilns burning hazardous waste 

in 1987 and 1995 than kilns not burning hazardous waste (emission factors were not needed in 

2000 for hazardous waste burners because virtually all facilities had been tested). As discussed 

below, these higher emissions were more likely due to APCD temperatures than the hazardous 

waste. 

World Business Council for Sustainable Development (2006) evaluated 2,200 CDD/CDF

measurements made at cement kilns from the late 1970s until recently. This report concluded 

that coprocessing of alternative fuels and raw materials, fed to the main burner, kiln inlet or the 

precalciner does not influence or change the emissions of persistent organic pollutants (POPs). 

EPA (1999) also concluded that hazardous waste burning at cement kilns is not likely to affect 

emissions of dioxins/furans. Rather, these reports conclude that reducing the temperature at the 

inlet of the air pollution control device is one factor shown to have a significant impact on 

limiting dioxin formation and emissions at all types of cement kilns, independent of waste 

feeding. Lower APCD temperatures are believed to prevent the postcombustion catalytic 

formation of CDD/CDFs. This is supported by emissions testing at a Portland cement kiln which 

showed that CDDs/CDFs were almost entirely absent at the inlet to a hot-sided ESP, but 

measurements taken at the exit showed conclusively that dioxins were formed within the 

hot-sided ESP (U.S. EPA, 1997b). After 1995, a number of cement kilns added exhaust 

gas-quenching units upstream of the APCD to reduce the inlet APCD temperature, thereby 

reducing CDD/CDF stack concentrations.

UNEP (2005) also concluded that APCD temperature is the key factor affecting 

CDD/CDF emissions and recommended emission factors on this basis: 
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1 • ESP temperature <200°C―0.05 ng I-TEQ/kg of clinker 

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• ESP temperature 200−300°C―0.6 ng I-TEQ/kg of clinker

• ESP temperature >300°C―5 ng I-TEQ/kg of clinker 

 In the year 2000, nine facilities with an SIC code for “cement, hydraulic” reported dioxin 

releases under the EPA TRI program (U.S. EPA, 2008). The total air releases across these 

facilities was 201 g, which EPA estimates is equal to 36 g WHO98 TEQDF. No releases to other 

media were reported. As explained in Chapter 1, the TRI data are not used to make quantitative 

estimates in this document, but, rather, the data are offered as supportive evidence that releases 

do occur. 

 For kilns burning hazardous waste, the emission factors were derived using test report 

data from 1989−1996 (U.S. EPA, 1996a). These data provided APCD inlet temperature data for 

88 test runs at 14 cement kilns and allowed development of emission factors for kilns with 

APCD inlet temperatures greater than 232oC and for kilns with APCD inlet temperatures less 

than 232oC. These were used in 1987 and 1995. In 2000, almost all of the facilities had been 

tested, and it was unnecessary to use an emission-factor/activity-level approach to derive release 

estimates (U.S. EPA, 2002a). 

For the kilns not burning hazardous waste, insufficient information was available to 

derive temperature-specific emission factors, and the same emission factor was assumed to apply 

to all facilities. This was derived from data in Bell (1999) and EPA (1996b) on a total of 

16 facilities. The lack of temperature data for the kilns not burning hazardous waste introduces 

uncertainty into the emission-factor assumption and may be an underestimate if the testing did 

not include facilities with high-temperature control devices. 

The activity data for clinker production were derived from information provided by U.S. 

DOC (1996) and Portland Cement Association (2001). All emission factors, activities, and 

release estimates are shown in the release summary below.

5.1.2. Water Releases 

It is possible that the effluent from the APCD systems at these facilities contains CDDs 

and CDFs because they have been measured in the stack gases. No information was found on 

the levels in the effluent, so this is considered a possible but unquantifiable source. 
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1 5.1.3. Solid Residue Releases

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No changes were made to the solid residue release estimates from cement kilns. 

However, additional background information is provided below. 

 Cement kiln dust (CKD) is the solid residual material collected by the APCD system of a 

cement kiln. Gross CKD (or as-generated CKD) is either recycled back into the kiln system or 

removed from the system for disposal (becoming net CKD or as-managed CKD). Most of the 

net CKD is disposed in secure landfills, but some is used for a variety of beneficial purposes 

such as municipal waste daily cover material, municipal waste landfill final cover material, soil 

stabilization for roadways or other structures, waste neutralization/stabilization/solidification 

(e.g., food wastes, hazardous wastes, etc.), and agricultural soil amendment. It is assumed that 

CDD/CDF releases could occur during the beneficial uses but not from the landfilled portions. 

As discussed in EPA, 2006 data on the amounts of CKD used for beneficial purposes was 

provided by the Portland Cement Association and split between kilns burning and not burning 

hazardous waste based on the relative amounts of clinker produced.

A wide range of CDD/PCDF concentrations in the CKD has been measured. A range 

from 0.001 to 30 ng TEQ/kg has been reported for U.K. kilns (Dyke et al., 1997), and 

1−40 ng TEQ/kg were summarized for German tests (SCEP, 1994). As discussed in EPA 

(2006), for kilns burning hazardous waste, the CKD concentration is assumed to be 

35 ng I-TEQ/kg (n = 5), and for the kilns not burning hazardous waste, the CKD concentration is 

assumed to be 0.003 ng I-TEQ/kg (n = 6). These emission factors were applied to all reference 

years. They are considered preliminary because of the inconsistency in measured values and 

lack of understanding for the differences. The dioxin concentrations in CKD were also used to 

estimate the amounts of CDD/CDFs in landfilled CKD, as shown below: 

Kilns burning hazardous waste Kilns not burning hazardous waste

CKD activity 

(million kg)

Landfilled 

(g I-TEQ)

CKD activity 

(million kg)

Landfilled

(g I-TEQ)

1987 426 14.9 2,230 0.007

1995 505 17.7 2,642 0.008

2000 365 12.8 1,858 0.006
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 5.1.4. Products

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

Clinker is the primary product of cement kilns and is ultimately used to make Portland 

cement. EPA (1993a) described the results of sampling and analysis of clinker conducted in 

1992 and 1993. Clinker samples were collected from five cement kilns burning nonhazardous 

waste and six kilns burning hazardous waste. CDDs/CDFs were not detected in any of the 

samples. Some of the CKD is beneficially reused as discussed above. Releases associated with 

beneficial uses of CKD are covered under the solid residue section. 

5.1.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Cement Kilns

Air Water Solids Products

Emission tests for at least two units/source types with Yes Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes No

understandable differences. 

Emission factor tests represent units that are typical of Yes Yes

the class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q P
This document is a draft for review purposes only and does not constitute Agency policy. 

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Cement Kilns Not Burning Hazardous Waste

Air Releases

Emission Factor

• 1987―0.27

• 1995―0.27

• 2000―0.27

ng WHO98

ng WHO98

ng WHO98

TEQDF/kg (0.26 ng 

TEQDF/kg (0.26 ng 

TEQDF/kg (0.26 ng 

I-TEQ/kg)

I-TEQ/kg)

I-TEQ/kg)

of clinker produced. 

of clinker produced. 

of clinker produced.

Activity Levels

• 1987―47.2 billion kg of 

• 1995―61.3 billion kg of 

• 2000―63.7 billion kg of 

clinker. 

clinker. 

clinker.

Releases

• 1987―13 g WHO98

• 1995―17 g WHO98

• 2000―17 g WHO98

TEQDF/yr (12 g I-TEQDF/yr). 

TEQDF/yr (16 g I-TEQDF/yr). 

TEQDF/yr (17 g I-TEQDF/yr).

Water Releases

It is possible that the effluent from the APCD systems at these facilities contains CDDs and 

CDFs because they have been measured in the stack gases. No information was found on levels 

in the effluent, so this considered a possible but unquantifiable source. 

Solid Residue Releases

Emission Factor 

• 1987―0.003

• 1995―0.003

• 2000―0.003

ng I-TEQ/kg (Preliminary).

ng I-TEQ/kg (Preliminary).

ng I-TEQ/kg (Preliminary).

Activity Levels

• 1987―632 million kg. 

• 1995―547 million kg. 

• 2000―480 million kg.

Releases for Beneficial Uses

• 1987―<0.1 g I-TEQ (Preliminary). 

• 1995―<0.1 g I-TEQ (Preliminary). 

• 2000―<0.1 g I-TEQ (Preliminary).

Products

No information was found suggesting that clinker contained measureable levels of CDDs and 

CDFs. Beneficial uses of CKD are covered under solid residues.

1 

2 

3 
This document is a draft for review purposes only and does not constitute Agency policy. 

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Cement Kilns Burning Hazardous Waste

Air Releases

Emission Factors 

• 1987―APCD > 232oC: 31 ng WHO98 TEQDF/kg (29 ng I-TEQ/kg) of clinker produced. 

APCD < 232oC: 1.1 ng WHO98 TEQDF/kg (1.0 ng I-TEQ/kg) of clinker produced. 

• 1995―APCD > 232oC: 31 ng WHO98 TEQDF/kg (29 ng I-TEQ/kg) of clinker produced. 

APCD < 232oC: 1.1 ng WHO98 TEQDF/kg (1.0 ng I-TEQ/kg) of clinker produced.

• 2000―EFs not needed because all individual facilities were tested.

Activity Levels

• 1987―APCD > 232oC: 3.8 billion kg of clinker. 

APCD < 232oC: 1 billion kg of clinker. 

• 1995―APCD > 232oC: 5.04 billion kg of clinker. 

APCD < 232oC: 1.26 billion kg of clinker. 

• 2000―Activity estimates not needed because all individual facilities were tested.

Releases

• 1987―APCD > 232oC: 120 g WHO98 TEQDF/yr (110 g I-TEQDF/yr). 

APCD < 232oC: 1 g WHO98 TEQDF/yr (1 g I-TEQDF/yr). 

• 1995―APCD > 232oC: 160 g WHO98 TEQDF/yr (150 g I-TEQDF/yr). 

APCD < 232oC: 1 g WHO98 TEQDF/yr (1 g I-TEQDF/yr). 

• 2000―19 g WHO98 TEQDF/yr (17 g I-TEQDF/yr).

Water Releases

It is possible that the effluent from the APCD systems at these facilities contain CDDs and CDFs 

because they have been measured in the stack gases. No information was found on levels in the 

effluent, so this considered a possible but unquantifiable source. 

Solid Residue Releases

Emission Factor 

• 1987―35 ng 

• 1995―35 ng 

• 2000―35 ng 

I-TEQDF/kg

I-TEQDF/kg

I-TEQDF/kg

(Preliminary).

(Preliminary).

(Preliminary).

Activity Level for Beneficial Uses

• 1987―120 million kg. 

• 1995―104 million kg. 

• 2000―94 million kg.
This document is a draft for review purposes only and does not constitute Agency policy. 

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Cement Kilns Burning Hazardous Waste (continued)

Releases for Beneficial Uses

• 1987―4 g I-TEQ (Preliminary). 

• 1995―4 g I-TEQ (Preliminary). 

• 2000―3 g I-TEQ (Preliminary).

Products

No information was found suggesting that clinker contained measureable levels of CDDs and 

CDFs. Beneficial uses of CKD are covered under solid residues.

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24 

5.2. LIGHTWEIGHT AGGREGATE KILNS

5.2.1. Air Releases

No changes were made to the air-release estimates, but some clarifications are provided. 

Lightweight aggregate (LWA) kilns burning hazardous waste are estimated to have emitted 

3.3 g I-TEQDF to air in 1990 (Federal Register, 1998) and 2.4 g I-TEQDF in 1997 (Federal 

Register, 1999); these estimates are used in this report for reference years 1987 and 1995, 

respectively. The emission factor estimate for 2000 is 1.99 ng WHO98 TEQDF/kg 

(2.06 ng I-TEQDF/kg) based on testing at 5 kilns (U.S. EPA, 2002a). As discussed in EPA, 2006, 

activity data were available on all 9 facilities operating in 2000 from EPA’s Office of Solid 

Waste. This information was combined with assumptions about annual feed rates and operating 

time percentage to get total activity estimates. EPA (2006) mislabeled the activity estimates as 

applying to halogen acid furnaces rather than light weight aggregate kilns. 

5.2.2. Water Releases―None

5.2.3. Solid Residue Releases―None

5.2.4. Product Literature―None 

5.2.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy. 

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Inventory Decision Criteria for Lightweight Aggregate Kilns

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors.

Measured emission factors consistent or have Yes

understandable differences.

Emission factor tests represent units that are typical of Yes

the class.

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

1 

2 

3 

4 

5 

6 

Lightweight Aggregate Kilns

Air Releases

Emission Factors 

• 1987―not needed. 

• 1995―not needed. 

• 2000―2.0 ng WHO98 TEQDF/kg (2.1 ng I-TEQDF/kg) of waste feed.

Activity Levels

• 1987―not needed. 

• 1995―not needed. 

• 2000―903,000 MT. 

Releases

• 1987―3 g I-TEQDF.

• 1995―2 g I-TEQDF.

• 2000―2 g WHO98 TEQDF (2 g I-TEQDF).

Water Releases

No information was found suggesting that water releases from these facilities would contain 

CDDs and CDFs. 

Solid Residue Releases

No information was found suggesting that solid residues from these facilities would contain 

CDDs and CDFs. 

Products

No information was found suggesting that products from these facilities would contain CDDs 

and CDFs. 
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 5.3. ASPHALT MIXING PLANTS 

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27 

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29 

30 

5.3.1. Air Releases

 Changes were made to the air emission factor, and the releases estimated for 2000 were 

also assumed to apply to the reference years 1987 and 1995. 

The original report estimated the emission factor on the basis of tests at two U.S. 

facilities. The original report also included information on testing at one facility in the 

Netherlands: 0.047 ng I-TEQ/kg (Bremmer et al., 1994) and three facilities in Germany: 0.0002, 

0.0035, and 0.0038 ng I-TEQ/kg (Umweltbundesamt, 1996). Because the European facilities are 

likely similar to those in the United States, the y were averaged in with the U.S. facilities to 

derive an emission factor of 0.0095 ng I-TEQ/kg, and this was applied to all reference years. 

This factor falls within the range recommended by UNEP (2005) for asphalt mixing plants: 

0.0.007 to 0.07 ng I-TEQ/kg. The confidence rating was upgraded from preliminary to 

quantifiable based on the additional testing used to support it and similarity to UNEP, 2005. 

The original report provided an activity estimate of 500 million tons for 2000 based on 

1996 survey data. Because this industry is fairly stable in terms of growth and the activity data 

are near the midpoint of the reference year range, it is reasonable to assume it applies to all 

reference years. Asphalt can be produced at both fixed and mobile facilities. It is unclear if this 

activity estimate includes both types of plants or only those at fixed locations. The National 

Cooperative Highway Research Program Web site and other related sites were searched, but no 

relevant information was found. 

5.3.2. Water Releases

No information was found suggesting that water releases from these facilities would 

contain CDDs and CDFs. 

5.3.3. Solid Residue Releases

UNEP (2005) indicates that flue gas cleaning residues are likely to have CDD/CDFs and 

suggests an emission factor of 0.06 ng I-TEQ/kg. No information was available on the quantity 

of this material generated. Also, it is likely that these residues would be landfilled and, therefore, 

not considered a release. 
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 5.3.4. Products

2 

3 

4 

5 

6 

7 

8 

9 

No information was found suggesting that products from these facilities would contain 

CDDs and CDFs. 

5.3.5. Release Summary

The inventory decision criteria and releases are summarized below:

Inventory Decision Criteria for Asphalt Mixing Plants

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes

the class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 5-11 DRAFT: DO NOT CITE OR QUOTE

Asphalt Mixing Plants

Air Releases

Emission Factors 

• 1987―0.009 ng I-TEQ/kg 

• 1995―0.009 ng I-TEQ/kg 

• 2000―0.009 ng I-TEQ/kg 

of asphalt produced. 

of asphalt produced. 

of asphalt produced.

Activity Levels

• 1987―500 MMT. 

• 1995―500 MMT. 

• 2000―500 MMT.

Releases

• 1987―5 g I-TEQ. 

• 1995―5 g I-TEQ. 

• 2000―5 g I-TEQ.

Water Releases

No information was found suggesting that water releases from these facilities would contain 

CDDs and CDFs. 

Solid Residue Releases

Any solid residues from these facilities would 

release. 

be landfilled and not considered an environmental 

Products

No information was found suggesting that products from these facilities would contain CDDs 

and CDFs. 

1 

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6 

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10 

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12 

13 

14 

5.4. PETROLEUM-REFINING CATALYST REGENERATION PLANTS

5.4.1. Air Releases

No changes were made to the air-release estimates. The average of the emission factors 

for two California facilities (1.59 ng WHO98 TEQDF/barrel (1.52 ng I-TEQDF/barrel) of reformer 

feed) is assumed to apply to all reference years. The activity estimates were derived from EIA, 

2002. 

 In the year 2000, one facility with an SIC code for petroleum bulk stations and terminals

reported dioxin releases under EPA’s TRI program (U.S. EPA, 2008). The total air releases for 

this facility was 102.8 g, which EPA estimates is equal to 3 g WHO98 TEQDF. No releases to 

other media were reported. As explained in Chapter 1, the TRI data are not used to make 

quantitative estimates in this document, but, rather, the data are offered as supportive evidence 

that releases do occur. 
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 5.4.2. Water Releases

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3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

As discussed in EPA (2006), CDD/CDFs have been detected in wastewaters from these 

facilities. However, insufficient information is available on the levels and quantities of these 

wastes to generate release estimates. On this basis, they are considered possible but 

unquantifiable sources. 

5.4.3. Solid Residue Releases

 As discussed in EPA (2006), CDD/CDFs have been detected in solid residues from these 

facilities. However, insufficient information is available on the levels and quantities of these 

wastes to estimate the amounts. However, these residues would be landfilled and, therefore, not 

considered an environmental release. 

5.4.4. Product Literature

No information was found suggesting that products from these facilities would contain 

CDDs and CDFs. 

5.4.5. Release Summary

The inventory decision criteria and releases are summarized below: 

Inventory Decision Criteria for Petroleum-Refining Catalyst Regeneration Plants

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes

the class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 5-13 DRAFT: DO NOT CITE OR QUOTE

Petroleum-Refining Catalyst Regeneration Plants

Air Releases

Emission Factors 

• 1987―1.6 ng WHO98

• 1995―1.6 ng WHO98

• 2000―1.6 ng WHO98

TEQDF/barrel (1.5 ng I-TEQDF/barrel) of reformer feed. 

TEQDF/barrel (1.5 ng I-TEQDF/barrel) of reformer feed. 

TEQDF/barrel (1.5 ng I-TEQDF/barrel) of reformer feed.

Activity Levels

• 1987―1,390 million barrels. 

• 1995―1,410 million barrels. 

• 2000―1,380 million barrels.

Releases

• 1987―2 g WHO98

• 1995―2 g WHO98

• 2000―2 g WHO98

TEQDF

TEQDF

TEQDF

(2

(2

(2

g I-TEQDF). 

g I-TEQDF). 

g I-TEQDF).

Water Releases

CDD/CDFs have been detected in wastewaters from these facilities. However, insufficient 

information is available on the levels and quantities of these wastes to generate release estimates. 

On this basis, they are considered possible but unquantifiable sources. 

Solid Residue Releases

Any solid residues from these facilities would 

release. 

be landfilled and not considered an environmental 

Products

No information was found suggesting that products from these facilities would contain CDDs 

and CDFs. 

1 

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15 

5.5. CIGARETTE SMOKING 

5.5.1. Air Releases

No changes were made to the air-release estimates. The air emission factor was derived 

using data from Matsueda et al. (1994) and Löfroth and Zebühr (1992). The activity estimates 

were based on Brown (2002). 

5.5.2. Water Releases―None
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 5.5.3. Solid Residue Releases 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

No information was found suggesting that ash from cigarette smoking would contain 

CDDs and CDFs. 

5.5.4. Products―None

5.5.5. Release Summary

The inventory decision criteria and releases are summarized below. Although these 

emission estimates are relatively small compared to many other sources, they have increased 

importance because humans are directly exposed to cigarette smoke.

Inventory Decision Criteria for Cigarette Smoking

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes

the class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 5-15 DRAFT: DO NOT CITE OR QUOTE

Cigarette Smoking

Air Releases

Emission Factors 

• 1987―1.7 pg WHO98 TEQDF/cigarette (1.6 pg I-TEQDF/cigarette). 

• 1995―1.7 pg WHO98 TEQDF/cigarette (1.6 pg I-TEQDF/cigarette). 

• 2000―1.7 pg WHO98 TEQDF/cigarette (1.6 pg I-TEQDF/cigarette).

Activity Levels

• 1987―575 billion cigarettes. 

• 1995―487 billion cigarettes. 

• 2000―440 billion cigarettes.

Releases

• 1987―1 g WHO98 TEQDF (0.9 g I-TEQDF). 

• 1995―0.8 g WHO98 TEQDF (0.8 g I-TEQDF). 

• 2000―0.7 g WHO98 TEQDF (0.7 g I-TEQDF).

Water Releases

None. 

Solid Residue Releases

No information was found suggesting that ash from cigarette smoking would contain CDDs and 

CDFs. 

Products

Not applicable.

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5.6. PYROLYSIS OF BROMINATED FLAME RETARDANTS

 The primary purpose of this report is to provide emission estimates for chlorinated 

dibenzo-p-dioxins and dibenzofurans. However, the brominated dibenzo-p-dioxins (BDDs) and 

dibenzofurans (BDFs) may also have dioxin-like toxicity. To date, though, no TEQs have been 

established for these compounds. Because these compounds are related to the CDDs and CDFs, 

some information on their emissions from facilities that pyrolyze brominated flame retardants is 

included in EPA (2006). 

5.7. CARBON REACTIVATION FURNACES 

5.7.1. Air Releases

No changes were made to the air-release estimates. The emission factor was derived 

from two GAC reactivation furnaces stack-tested by EPA (U.S. EPA, 1987; Lykins et al., 1987). 
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 5-16 DRAFT: DO NOT CITE OR QUOTE

1 One test was conducted at a multiple hearth facility which is typical of large scale operations and 

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15 

16 

17 

18 

the second test was conducted at a fluidized bed facility which is more typical of smaller 

operations. The activity was estimated on the basis of the mass of virgin GAC shipped each year 

by GAC manufacturers according to the U.S. Department of Commerce (U.S. DOC, 1990). 

5.7.2. Water Releases―None

5.7.3. Solid Residue Releases―None

5.7.4. Products 

No information was found suggesting that products from these facilities would contain 

CDDs and CDFs. 

5.7.5. Release Summary

The inventory decision criteria and releases are summarized below: 

Inventory Decision Criteria for Carbon Reactivation Furnaces

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes

the class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 5-17 DRAFT: DO NOT CITE OR QUOTE

Carbon Reactivation Furnaces

Air Releases

Emission Factors 

• 1987―1.2 ng (WHO98 TEQDF or I-TEQDF) per kg of reactivated carbon. 

• 1995―1.2 ng (WHO98 TEQDF or I-TEQDF) per kg of reactivated carbon. 

• 2000―1.2 ng (WHO98 TEQDF or I-TEQDF) per kg of reactivated carbon.

Activity Levels

• 1987―48,000 MT. 

• 1995―65,000 MT. 

• 2000―65,000 MT.

Releases

• 1987―0.1 g (WHO98 TEQDF or I-TEQDF). 

• 1995―0.1 g (WHO98 TEQDF or I-TEQDF). 

• 2000―0.1 g (WHO98 TEQDF or I-TEQDF).

Water Releases

No water releases are produced. 

Solid Residue Releases

No solid residues are produced.

Products

No information was found suggesting that products from these facilities would contain CDDs 

and CDFs. 

1 

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10 

11 

12 

13 

14 

15 

16 

5.8. KRAFT BLACK LIQUOR RECOVERY BOILERS 

5.8.1. Air Releases

No changes were made to the air-release estimates. The emission factor for 1987 and 

1995 was based on the data for the six NCASI facilities (NCASI, 1995). For 2000, the emission 

factor was based on “NCASI Handbook of Chemical Specific Information for SARA 

Section 313 Form R Reporting.” Activity estimates were derived from information provided by 

American Paper Institute (API, 1992), American Forest and Paper Association (AF&PA,1997), 

and NCASI (2002). 

5.8.2. Water Releases―None
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 5.8.3. Solid Residue Releases 

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3 

4 

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8 

9 

10 

11 

12 

13 

14 

15 

Fly ash is typically collected in ESPs at these facilities. Because CDD/CDFs have been 

detected in the stack gases, they are likely to be also contained in the fly ash, but no 

measurements have been reported. Any solid residues are likely to be landfilled and, therefore, 

are not considered an environmental release. 

5.8.4. Products 

No information was found suggesting that products from these facilities would contain 

CDDs and CDFs.

5.8.5. Release Summary

The inventory decision criteria and releases are summarized below: 

Inventory Decision Criteria for Kraft Black Liquor Recovery Boilers

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes

the class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 5-19 DRAFT: DO NOT CITE OR QUOTE

Kraft Black Liquor Recovery Boilers

Air Releases

Emission Factors 

• 1987―0.03 ng WHO98 TEQDF/kg (0.03 ng I-TEQDF/kg) of black liquor solids. 

• 1995―0.03 ng WHO98 TEQDF/kg (0.03 ng I-TEQDF/kg) of black liquor solids. 

• 2000―0.010 ng WHO98 TEQDF/kg of black liquor solids.

Activity Levels

• 1987―69.8 MMT. 

• 1995―80.8 MMT. 

• 2000―90.7 MMT for Kraft recovery furnaces.

Releases

• 1987―2 g (WHO98 TEQDF or I-TEQDF). 

• 1995―2 g (WHO98 TEQDF or I-TEQDF). 

• 2000―0.9 g WHO98 TEQDF/yr.

Water Releases

No water releases are produced. 

Solid Residue Releases

Any solid residues from these facilities would be landfilled and not considered an environmental 

release. 

Products

No information was found suggesting that products from these facilities would contain CDDs 

and CDFs. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

5.9. LIME KILNS

This is a new section covering lime kilns used in the pulp and paper industry as well as 

other industries. 

5.9.1. Process Description

 Lime making consists of burning of calcium and/or magnesium carbonate at a 

temperature between 900 and 1,500°C. The burned lime is either delivered to the end user in the 

form of quicklime or reacted with water in a hydrating plant to produce hydrated lime or slaked 

lime. Different fuels—solid, liquid, or gaseous—are used in lime burning. Most of the kilns are 

either shaft or rotary design and have countercurrent flow of solids and gases. Fluidized bed 

kilns and rotary hearths may also be found (UNEP, 2005). 
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 5.9.2. Regulations 

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25 

26 

27 

28 

29 

30 

31 

None specific to dioxins. 

5.9.3. Air Releases

Annual emissions from lime kilns in Belgium and the United Kingdom have been 

reported by Wevers and De Fre (1995) and Douben et al. (1995), respectively. However, the 

emission factors used to generate those estimates were not provided. Umweltbundesamt (1996) 

reported emission factors of 0.016 to 0.028 ng I-TEQDF/kg during tests at two lime kilns in 

Germany.

 UNEP (2005) reports that data from Europe on seven kilns, of which four were rotary 

kilns and three were shaft kilns, showed CDD/PCDF concentrations below 0.1 ng TEQ/Nm3. 

Measurements at two annular shaft kilns in Germany were all below 0.05 ng I-TEQ/Nm3.

 High concentrations of CDD/PCDF have been measured at three kilns, two rotary kilns, 

and one shaft kiln, in Sweden. The measurements made between 1989 and 1993 gave 

concentrations between 4.1 and 42 ng N-TEQ/Nm3. All measurements of high CDD/PCDF 

concentrations have been explained by the raw material, fuel content, or less-than-optimum 

burning conditions, underlining the importance of controlling the kiln inputs and maintaining a 

stable kiln operation (IPPC, 2001).

 UNEP (2005) recommends two emission factors. For no dust controls or poor fuel, 

10 μg I-TEQ/MT of CaO are recommended, and for kilns with good dust controls, 

0.07 μg I-TEQ/MT of CaO are recommended.

 In the year 2000, one facility with an SIC code for lime reported dioxin releases under the 

EPA TRI program (U.S. EPA, 2008). The total air releases for this facility was 0.73 g, which 

EPA estimates is equal to 0.15 g WHO98 TEQDF. The total land releases for this facility was 

2.8 g, which EPA estimates is equal to 0.6 g WHO98 TEQDF. No releases to other media were 

reported. As explained in Chapter 1, the TRI data are not used to make quantitative estimates in 

this document but rather as supportive evidence that releases do occur. 

For 2000, the emission factor of 0.0058 ng WHO98 TEQDF/kg of CaO was used on the 

basis of “NCASI Handbook of Chemical Specific Information for SARA Section 313 Form R 

Reporting.” The factors provided in this handbook were compiled from test data supplied to 

NCASI by a variety of sources, including NCASI member companies who had performed the 
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 tests in response to a regulatory program. Congener-specific CDD/CDF TEQ emission factors 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

were provided (see Table 5-1). 

 For 2000, NCASI provided estimates of activity levels for Kraft lime kilns (Gillespie, 

2002). The activity levels were reported to be 13 MMT. Insufficient information was available 

to make release estimates for the other reference years.

5.9.4. Water Releases

No information was found suggesting that any water releases from these facilities would 

contain CDDs and CDFs. 

5.9.5. Solid Residue Releases 

Any solid residues from these facilities would be landfilled and are not considered an 

environmental release. 

5.9.6. Products 

No information was found suggesting that products from these facilities would contain 

CDDs and CDFs. 

5.9.7. Release Summary

The inventory decision criteria and releases are summarized below: 

Inventory Decision Criteria for Lime Kilns

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes

the class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
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Lime Kilns

Air Releases

Emission Factors 

• 1987―NA. 

• 1995―NA. 

• 2000―0.006 ng WHO98 TEQDF/kg of CaO.

Activity Levels

• 1987―NA. 

• 1995―NA. 

• 2000―13 MMT.

Releases

• 1987―NA. 

• 1995―NA. 

• 2000―0.1 g WHO98 TEQDF/yr.

Water Releases

No information was found suggesting that 

CDDs and CDFs. 

any water releases from these facilities would contain 

Solid Residue Releases

Any solid residues from these facilities would 

environmental release. 

be landfilled and are not considered an 

Products

No information was found suggesting that products from these facilities would contain CDDs 

and CDFs. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

5.10. GLASS MANUFACTURING

This is a new section. 

UNEP (2005) provides an emission factor for glass manufacturing operations using dust 

abatement of 0.015 ng I-TEQ/kg of product. This factor was based on testing at three facilities 

in Germany. It was assumed to apply to all reference years. The amount of glass produced in 

the United States during 1999 was 18 MMT (DOE, 2002). Data were not found for the earlier 

years, and this value was assumed to apply to all of the reference years. 

No information was found on CDD/CDF levels in the solid waste generated from glass 

manufacturing. However, these residues would be landfilled and, therefore, are not considered 

to be an environmental release. 

The inventory decision criteria and releases are summarized below: 
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Inventory Decision Criteria for Glass Manufacturing

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes

the class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

1 

2 

3 

4 

5 

6 

7 

8 

Glass Manufacturing

Air Releases

Emission Factors 

• 1987―0.02 ng I-TEQDF/kg of metal feed. 

• 1995―0.02 ng I-TEQDF/kg of metal feed. 

• 2000―0.02 ng I-TEQDF/kg of metal feed.

Activity Levels

• 1987―18 MMT. 

• 1995―18 MMT. 

• 2000―18 MMT.

Releases

• 1987―0.4 g I-TEQDF.

• 1995―0.4 g I-TEQDF.

• 2000―0.4 g I-TEQDF.

Water Releases

None.

Solid Residue Releases

None. 

Products

None.
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1 5.11. OTHER IDENTIFIED SOURCES

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3 

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5 

6 

7 

8 

9 

10 

11 

A number of additional operations may be sources of CDD/CDF formation because the 

processes use chlorine-containing components or involve application of high temperatures. 

These include ceramics/rubber production facilities and plating/painting facilities which use 

thermal air-pollution control devices. Additionally automobile shredding was identified as a 

potential source of CDD/CDF releases. However, no testing of emissions from these processes 

has been performed in the United States, and only minimal emission rate information has been 

reported for these processes in other countries. Therefore, emissions from these sources are 

possible but cannot be quantified. 

Miscellaneous Sources

Possible Air Releases

Ceramics and rubber manufacturers (Not quantifiable).

Thermal air pollution control devices used at plating facilities and painting operations (Not 

quantifiable).

Automobile shredders (Not quantifiable).

Possible Water Releases

Ceramics and rubber manufacturers (Not quantifiable).
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1 Table 5-1. CDD/CDF TEQ emission factors and emission estimates from 

2 

3 

4 

5 

Kraft lime kilns

Congener

WHO98 TEQDF

(ng/lb CaO)

WHO98 TEQDF

(ng/kg CaO)

2,3,7,8-TCDD

1,2,3,7,8-PeCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

1,2,3,4,6,7,8,9-OCDD

0.00 × 100

0.00 × 100

0.00 × 100

1.00 × 10−4

0.00 × 100

2.80 × 10−4

2.56 × 10−4

0.00 × 100

0.00 × 100

0.00 × 100

2.20 × 10−4

0.00 × 100

6.16 × 10−4

5.63 × 10−4

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

1,2,3,4,6,7,8,9-OCDF

8.00 × 10−4

1.00 × 10−4

0.00 × 100

9.00 × 10−4

2.00 × 10−4

0.00 × 100

0.00 × 100

0.00 × 100

0.00 × 100

0.00 × 100

1.76 × 10−3

2.20 × 10−4

0.00 × 100

1.98 × 10−3

4.40 × 10−4

0.00 × 100

0.00 × 100

0.00 × 100

0.00 × 100

0.00 × 100

Total 2.64 × 10−3 5.80 × 10−3

CaO = Calcium oxide.
This document is a draft for review purposes only and does not constitute Agency policy.

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1 6. COMBUSTION SOURCES OF CDDs/CDFs MINIMALLY CONTROLLED AND 

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26 

27 

UNCONTROLLED COMBUSTION SOURCES

6.1. COMBUSTION OF LANDFILL GAS

6.1.1. Air Releases

No changes were made to the air-release estimates. The emission factor was derived by 

averaging test results for one landfill flare in California (CARB, 1990) and one in the 

Netherlands (Bremmer et al., 1994). This value was assumed to apply to all reference years: 

1.4 ng I-TEQDF/m3

. The emission factors for the two facilities differed by a factor of six. UNEP 

(2005) used studies from Germany and the U.K. to derive an emission factor of 8 μg I-TEQ/TJ of 

gas burned. Assuming that the landfill gas has a heating value of 16 MJ/m3 (half that of natural 

gas), this converts to 0.13 ng I-TEQ/m3. Based on the limited data and inconsistency in emission 

factors this was considered preliminary. As described in the 2006 document, survey data and 

assumptions were used to derive activity estimates. 

6.1.2. Water Releases

No wet scrubbers are used for these facilities, so no releases to surface waters should 

occur.

6.1.3. Solid Residue Releases―None

6.1.4. Products―None

6.1.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 
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1 

2 

3 

4 

Inventory Decision Criteria for Landfill Gas

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors.

Measured emission factors consistent or have No

understandable differences.

Emission factor tests represent units that are typical of the Yes

class.

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P

Combustion of Landfill Gas

Air Releases

Emission Factors 

• 1987―1.4 ng I-TEQDF/m3 (Preliminary). 

• 1995―1.4 ng I-TEQDF/m3 (Preliminary). 

• 2000―1.4 ng I-TEQDF/m3 (Preliminary).

Activity Levels

3 • 1987―1.35 billion m . 

3 • 1995―4.7 billion m . 

3 • 2000―16 billion m .

Releases

• 1987―2 g I-TEQDF (Preliminary). 

• 1995―7 g I-TEQDF (Preliminary). 

• 2000―22 g I-TEQDF (Preliminary).

Water Releases

None. 

Solid Residue Releases

None. 

Products

None.
This document is a draft for review purposes only and does not constitute Agency policy.

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1 6.2. ACCIDENTAL FIRES

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7 

8 

9 

10 

11 

12 

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26 

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28 

29 

30 

31 

6.2.1. Structural Fires

6.2.1.1. Air Releases

No changes were made to the air-release estimates, but additional background 

information is provided below. 

 The most recent evidence of the release of CDD/CDFs from combustion of structures 

was from the collapse of the World Trade Center Towers. Pleil and Lorber (2007) examined 

dioxin congener concentrations and profiles from several fires including the fires that burned at 

Ground Zero after the collapse of the Towers for upwards of 200 days, the Binghamton office 

fire that occurred in the early 1980s starting from a transformer fire in the basement of the office 

building, and an office fire from a building in Philadelphia. The air concentrations that resulted 

from World Trade Center fires exceeded 100 pg WHO98 TEQDF/m3 for several ambient air 

measurements within 500 m of the fires. The Binghamton office fire was dominated by the 

combustion of PCBs in the transformers. The Philadelphia office fire was typical of urban 

building structures. Pleil and Lorber (2007) looked at profiles of CDD/CDFs in impacted air, 

dust, and soot, and compared these profiles with background profiles. While their analysis did 

not allow for generation of an emission factor, it did produce a congener profile (see Figure 6-1). 

The presence of manufactured boards and treated lumber in structures is expected to 

increase dioxin emissions relative to the combustion of untreated natural wood. As discussed in 

Section 4.2, Tame et al. (2007) reviewed the literature on the role of preservatives in the 

formation of dioxin in the combustion of wood. They conclude that current and emerging wood 

preservatives significantly increase dioxin formation during combustion in domestic stoves and 

in fires. Also Bhargava et al. (2002) conducted calorimeter testing and derived emission factors 

of 20.5 ng WHO98 TEQ/kg for chip boards and15.4 ng WHO98 TEQ/kg for medium density 

fiberboard (MDF) compared to nondetect to 2.5 ng WHO98 TEQ/kg for natural woods. 

 The original report (U.S. EPA, 2006) recommends an emission factor of 32 μg I-TEQ/fire 

based on averaging data from Carroll (1996) and Thomas and Spiro (1995). These were based 

on soot measurements or other indirect methods and were assigned a preliminary confidence 

rating. This emission factor can be converted to a mass basis by dividing by a default 

fuel-loading factor for structural fires of 1.15 tons/fire (ERG, 2001), yielding 28 ng I-TEQ/kg. 

This is much less than the emission factor of 400 ng I-TEQ/kg recommended by UNEP (2005). 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 No changes were made to the activity estimates which were derived from survey data in FEMA 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

(1997, 2001) and are presented in the release summary below.

6.2.1.2. Water Releases

It is possible that dioxin-contaminated particles could be entrained in water used to fight 

fires or rainwater that falls on the site. This water could run off the site and eventually get into 

surface waters. No quantitative release estimates could be made.

6.2.1.3. Solid Residue Releases

Solid residue releases are possible because CDDs and CDFs have been measured in solid 

residues remaining after structural fires. EPA (2006) summarized six field studies with residue 

concentrations ranging from 0.03 to 130 μg I-TEQDF/kg. This wide data range is understandable 

considering that the amount/types of treated wood and household products found in structures is 

likely to be highly variable. The geometric mean of 2 μg I-TEQDF/kg of residue was selected as 

a central value. This was converted to an emission factor by assuming that 15% of the fuel is 

converted to ash (this is based on the assumption that structural fires will generate ash at a 

similar rate as observed for bottom ash in municipal waste combustion, which is reported by 

UNEP [2005] to be typically 10−20%). This yields an emission factor of 300 ng I-TEQDF/kg of 

material burned, which was assumed to apply to all reference years. Based on an analysis of the 

congener data reported by Christmann et al. (1989b) for soot from a building fire, this emission 

factor will be the same when converted to WHO98 TEQs. This value is similar to the UNEP, 

2005 recommendation of 400 ng I-TEQDF/kg of material burned. 

The activity estimates used to calculate residue releases for structural fires were 

computed by multiplying the number of fires by the default fuel-loading factor for structural fires 

of 1.15 tons/fire (ERG, 2001).

6.2.1.4. Products―None

6.2.1.5. Release Summary

The inventory decision criteria and releases to all media are summarized below. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 The air-release estimates presented here are similar to those reached for national emission 

2 

3 

4 

5 

6 

inventories developed for the Netherlands (Bremmer et al., 1994) and the United Kingdom (U.K. 

Department of the Environment, 1995). 

Inventory Decision Criteria for Structural Fires

Air Water Solids Products

Emission tests for at least two units/source types with No Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes Yes

the class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). P Q
This document is a draft for review purposes only and does not constitute Agency policy.

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Structural Fires

Air Releases

Emission Factors 

• 1987―32 μg I-TEQDF/fire

• 1995―32 μg I-TEQDF/fire

• 2000―32 μg I-TEQDF/fire

(Preliminary). 

(Preliminary). 

(Preliminary).

Activity Levels

• 1987―746,000 fires. 

• 1995―574,000 fires. 

• 2000―512,000 fires.

Releases

• 1987―24 g I-TEQDF

• 1995―18 g I-TEQDF

• 2000―16 g I-TEQDF

(Preliminary). 

(Preliminary). 

(Preliminary).

Water Releases

Possible but unquantifiable releases. 

Solid Residue Releases

Emission Factors

• 1987―300 ng (WHO98

• 1995―300 ng (WHO98

• 2000―300 ng (WHO98

or I-TEQDF/kg) of material burned. 

or I-TEQDF/kg) of material burned. 

or I-TEQDF/kg) of material burned.

Activity Levels

• 1987―860,000 tons. 

• 1995―660,000 tons. 

• 2000―589,000 tons.

Releases

• 1987―260 g (WHO98

• 1995―200 g (WHO98

• 2000―180 g (WHO98

or I-TEQDF). 

or I-TEQDF). 

or I-TEQDF). 

Products

None.

1 

2 

3 

4 

5 

6 

7 

6.2.2. Vehicle Fires

6.2.2.1. Air Releases

No changes were made to the air-release estimates. Wichmann et al. (1993, 1995) 

measured CDD/CDF emissions from controlled vehicle fires in a tunnel (two cars, one subway 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 car, and one railway car). This study suggests an emission factor of 0.044 mg I-TEQDF for cars 

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5 

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13 

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15 

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17 

18 

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21 

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23 

24 

25 

26 

27 

28 

29 

30 

and trucks and 2.6 mg I-TEQDF/fire for other vehicles. These values were assumed for all 

reference years. They are uncertain because Wichmann et al. (1993, 1995) based their estimates 

on surface deposits. This procedure may not have fully accounted for volatile CDDs/CDFs, 

which were reported by Merk et al. (1995) to account for the majority of CDDs/CDFs formed 

during a fire. Given the indirect method of measuring emissions, they are considered 

preliminary estimates. UNEP (2005) derived an emission factor of 0.094 mg I-TEQDF/incident. 

This was also based on Wichmann et al. (1995) and represents an average across all vehicle 

types. 

The activity estimates were based on the number of vehicle fires reported in the United 

States: approximately 561,530 in 1987 (FEMA, 1997), 406,000 in 1995 (U.S. DOC, 1997), and 

341,600 in 2000 (FEMA, 2001). Also, the assumption was made that 99% of those fires 

involved cars and trucks (the approximate percentage of all U.S. motor vehicles that are 

in-service cars and trucks; U.S. DOC, 1995). 

6.2.2.2. Water Releases

It is possible that dioxin-contaminated particles could be entrained in water used to fight 

fires or rainwater that falls on the site. This water could run off the site and eventually get into 

surface waters. No quantitative release estimates could be made. Therefore, this is a possible 

but unquantifiable source.

6.2.2.3. Solid Residue Releases

 The original document (US EPA, 2006) did not address solid residue releases. Solid 

residue releases are possible because CDDs and CDFs have been measured in solid residues 

remaining after vehicle fires. Wichmann et al. (1995) measured an average of 

0.01 mg I-TEQDF/fire for cars and trucks and 0.8 mg I-TEQDF/fire for other vehicles. These 

values were adopted here for all reference years using the same data; UNEP (2005) derived a 

solid residues emission factor of 0.018 mg I-TEQDF/incident for all vehicles. These emission 

factors were combined with the same activity data reported above to estimate releases. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 6.2.2.4. Products―None

2 

3 

4 

5 

6 

7 

6.2.2.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Vehicle Fires

Air Water Solids Products

Emission tests for at least two units/source types with No Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of the Yes Yes

class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). P Q
This document is a draft for review purposes only and does not constitute Agency policy.

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Vehicle Fires

Air Releases

Emission Factors

Cars and Trucks 

• 1987―0.044 mg I-TEQDF/incident (Preliminary). 

• 1995―0.044 mg I-TEQDF/incident (Preliminary). 

• 2000―0.044 mg I-TEQDF/incident (Preliminary). 

Other Vehicles

• 1987―2.6 mg I-TEQDF/incident (Preliminary). 

• 1995―2.6 mg I-TEQDF/incident (Preliminary). 

• 2000―2.6 mg I-TEQDF/incident (Preliminary).

Activity Levels

Cars and Trucks

• 1987―556,000 vehicle fires. 

• 1995―402,000 vehicle fires. 

• 2000―338,000 vehicle fires. 

Other Vehicles

• 1987―5,600 vehicle fires. 

• 1995―4,060 vehicle fires. 

• 2000―3,400 vehicle fires.

Releases

Cars and Trucks 

• 1987―24 g I-TEQDF (Preliminary). 

• 1995―18 g I-TEQDF (Preliminary). 

• 2000―15 g I-TEQDF (Preliminary). 

Other Vehicles

• 1987―15 g I-TEQDF (Preliminary). 

• 1995―11 g I-TEQDF (Preliminary). 

• 2000―9 g I-TEQDF (Preliminary). 

All Vehicles

• 1987―39 g I-TEQDF (Preliminary). 

• 1995―29 g I-TEQDF (Preliminary). 

• 2000―24 g I-TEQDF (Preliminary).

1 
This document is a draft for review purposes only and does not constitute Agency policy.

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Vehicle Fires (continued)

Water Releases

Possible but unquantifiable releases.

Solid Residue Releases

Emission Factors

Cars and Trucks 

• 1987―0.01 mg I-TEQDF/incident. 

• 1995―0.01 mg I-TEQDF/incident. 

• 2000―0.01 mg I-TEQDF/incident. 

Other Vehicles

• 1987―0.8 mg I-TEQDF/incident. 

• 1995―0.8 mg I-TEQDF/incident. 

• 2000―0.8 mg I-TEQDF/incident.

Activity Levels

Cars and Trucks

• 1987―556,000 vehicle fires. 

• 1995―402,000 vehicle fires. 

• 2000―338,000 vehicle fires. 

Other Vehicles

• 1987―5,600 vehicle fires. 

• 1995―4,060 vehicle fires. 

• 2000―3,400 vehicle fires.

Releases

Cars and Trucks 

• 1987―6 g I-TEQDF. 

• 1995―4 g I-TEQDF. 

• 2000―3 g I-TEQDF. 

Other Vehicles

• 1987―5 g I-TEQDF. 

• 1995―3 g I-TEQDF. 

• 2000―3 g I-TEQDF. 

All Vehicles

• 1987―11 g I-TEQDF. 

• 1995―7 g I-TEQDF. 

• 2000―6 g I-TEQDF. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 6.3. LANDFILL FIRES

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10 

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24 

25 

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27 

28 

29 

30 

31 

6.3.1. Air Releases

 The original report derived a preliminary release estimate from landfill fires using a per 

capita release factor of 4 μg I-TEQ per person developed from Swedish data. This factor was 

estimated by dividing the national release estimate for Sweden by the population. This per capita 

approach assumes that landfill fires increase over the reference years in proportion to the 

population. However, improved regulations and increases in methane recovery systems at 

landfills are likely to have reduced landfill fire frequency/magnitude over this time frame. 

Accordingly, a new approach is suggested below that does not show a downward trend. 

 Collet and Fiani (2006) reported on the measurement of PAH, PCB, and CDD/CDF 

emission from simulated forest and landfill fires. For the landfill simulations, samples were 

collected from two landfills located in southwest France. They collected samples from what they 

characterized as the superficial part of the landfill ground, only the first 15 cm. These samples

included municipal wastes and nonhazardous industrial wastes containing various plastics, wood, 

rubber, rags, and so on. The combustion chamber had an air flow of 1,800 nm3

/hour, 

corresponding to 22.5 volume changes per hour, to simulate open burning conditions. Emissions 

were sampled near the chamber exit and prior to the scrubber. They conducted two landfill fire 

simulations, and the emission factors for CDD/CDFs, in ng I-TEQ/kg, were 242 and 

233 ng I-TEQ/kg. Collet and Fiani also provided emission factors for 12 dioxin-like PCBs, in 

ng I-TEQ/kg, and they were 9.9 and 16.6 ng I-TEQ/kg. Their landfill samples were collected 

over a surface area of 2 m

2

, allowing generation of emission factors on an area basis. The 

emission factors for CDD/CDFs, in ng I-TEQ/m2

, were 1380 and 1321, and for the 

12 dioxin-like PCBs, also in ng I-TEQ/m2

, were 56.3 and 94.2. 

 Persson and Bergstrom (1991) conducted experiments simulating surface and deep fires 

and estimated an emission factor of 1000 ng Nordic TEQ/kg of material burned for landfill fires. 

This value (assumed equal to 1000 ng I-TEQ/kg) was also adopted by UNEP (2005). This factor 

is about four times higher than the factor developed by Collet and Fiani (2006). The midpoint of 

this range, or 600 ng I-TEQ/kg, was adopted here for each reference year. Neither Persson and 

Bergstrom (1991) nor Collet and Fiani (2006) reported individual congener data that would have 

allowed converting this I-TEQ estimate to a WHO98 TEQ estimate. However, Ruokojarvi et al. 

(1995) reported congener profiles for air concentrations measured during a landfill fire in 
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1 Finland. This profile suggest that the WHO98 TEQs would be about 20% greater than the 

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I-TEQs. On this basis, the emission factor of 600 ng I-TEQ/kg was converted to 

700 ng WHO98 TEQ/kg. The kinds of wastes and combustion conditions occurring in landfill 

fires are likely to be highly variable. It is very uncertain how well these are represented in the 

limited experiments used to derive the emission factors. Therefore, this emission factor was 

assigned a preliminary confidence rating. 

Blomqvist et al. (2007) used an emission factor range of 40 to 900 ng TEQ/kg for landfill 

fires in the Swedish inventory. This was based on two studies conducted in Sweden, one 

described as a “model study on household waste” and the other as one that “quantified emissions 

from real waste dump fires.” 

 In order to use the per kg emission factors reported above, it is necessary to estimate the 

amount of waste burned in landfill fires. Persson and Bergstrom (1991) assumed that 100,000 kg 

of material are burned in each surface fire and 350,000 kg are burned in deep fires. The 

midpoint of this range (225,000 kg) was multiplied by the number of landfill fires occurring in 

the United States. The U.S. Fire Administration (USFA, 2001) reports that an average of 

8,300 landfill fires occur each year (where landfills are defined broadly to include public or 

private areas where waste is buried; this includes municipal solid waste landfills and general 

refuse disposal areas and dumps in open ground). This suggests that a total of 1.9 MMT of 

material/year are burned in landfill fires in the United States. No information was found on how 

the number of landfill fires has changed over the reference years, and this amount (1.9 MMT)

was assumed to apply to each of the years. As discussed above, the actual trend is probably 

downward because improved regulations and increases in methane recovery systems at landfills 

are likely to have reduced landfill fire frequency/magnitude over this time frame. Considering 

the lack of data to accurately reflect this trend and the uncertainty in the assumptions about the 

amount of waste burned per fire, these activity estimates are considered preliminary 

(Preliminary). 

 As shown below, this approach suggests a total release of 1,100 g I-TEQ. Another way 

to estimate landfill fire releases is by using a per fire emission factor. Personn and Bergstrom 

(1991) estimated that 35 g Nordic TEQ were released from landfills fires in Sweden. This 

estimate assumed that 217 fires occurred per year (167 surface fires and 50 deep fires). This 

implies an average release of 0.16 g Nordic TEQ/fire. Multiplying this by the number of fires 
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1 occurring in the United States (8,300/year as reported by the USFA, 2001) suggests a total 

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release of 1,300 g Nordic TEQ. This value is similar to the original one using a per capita 

approach, which gave estimates of about 1,000 g I-TEQ/year (assuming minor differences 

between Nordic TEQs and I-TEQs). Although these alternative approaches suggest similar 

releases, the release estimate is still considered preliminary due to the uncertainties in both the 

emission factor and activity estimates. 

6.3.2. Water Releases―None

6.3.3. Solid Residue Releases―None

6.3.4. Products―None

6.3.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Landfill Fires

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have No

understandable differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. No

Conclusion (Q = Quantitative, P = Preliminary). P
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Landfill Fires

Air Releases

Emission Factors 

• 1987―700 ng WHO98 TEQ/kg (600 ng I-TEQ/kg) of material burned (Preliminary). 

• 1995―700 ng WHO98 TEQ/kg (600 ng I-TEQ/kg) of material burned (Preliminary). 

• 2000―700 ng WHO98 TEQ/kg (600 ng I-TEQ/kg) of material burned (Preliminary).

Activity Levels

• 1987―1.9 MMT (Preliminary). 

• 1995―1.9 MMT (Preliminary). 

• 2000―1.9 MMT (Preliminary).

Releases

• 1987―1,300 g WHO98 TEQDF (1,100 g I-TEQDF) (Preliminary). 

• 1995―1,300 g WHO98 TEQDF (1,100 g I-TEQDF) (Preliminary). 

• 2000―1,300 g WHO98 TEQDF (1,100 g I-TEQDF) (Preliminary).

Water Releases

None. 

Solid Residue Releases

None. 

Products

None.

6.4. FOREST AND BRUSH FIRES

6.4.1. Air Releases

 As described below, a number of additional studies have been identified, allowing 

updates to the air-release estimates from forest fires. 

Ikeguchi and Tanaka (1999) simulated the open burning of several waste types using a 

large furnace with open doors. The flue gas was sampled immediately downstream of the 

furnace. One test was conducted with tree and leaf materials. A total of 162.7 kg of this material 

were burned in a batch mode lasting 33 minutes. The emission factor was estimated as 

4.7 I-TEQ/kg of waste. UNEP (2005) used this study to support their recommended emission 

factor of 5 ng TEQ/kg of biomass burned for forest fires. 

Gonczi et al. (2005) measured dioxin emissions from burning various types of domestic 

wastes under a variety of conditions. One test involved the open burning of garden waste, which

was composed of approximately one half wood branches and one half leaves and grass. A 
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1 sampling hood was mounted 0.5 m above the fire to collect the emissions. This test yielded an 

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emission factor of 27 ng TEQ/kg.

Blomqvist et al. (2007) used an emission factor of 2 ng TEQ/kg for forest fires in the 

Swedish inventory. This was based on work by Bhargava et al. (2002) who measured dioxin 

emissions from the combustion of different wood materials in a cone calorimeter. 

 Collet and Fiani (2006) studied the emissions of PAHs, PCBs, and CDD/CDF emissions 

from simulated forest and landfill fires in France. They collected samples from two forests in the 

southeast and southwest of France during August, 2003. The samples consisted of litters, 

mosses, heathers, brackens, conifer needles, pine cones, shrubs, barks, pine, and oak branches. 

The 80 m3 combustion chamber had an air flow of 1,800 m3/hour, corresponding to 22.5 volume 

changes per hour, to simulate open burning conditions. Emissions were sampled near the 

chamber exit prior to the scrubber and measured in accordance with existing European standards 

(EN 1948-1-2-3 for CDD/CDFs and PCBs). For the five simulated forest fire tests, they 

estimated these emission factors for CDD/CDFs, in ng I-TEQ/kg: 10.4, 1.02, 25.9, 12.1, and 3.3, 

for an average of 10.5 ng I-TEQ/kg. Collet and Fiani also provide emission factors for 

12 dioxin-like PCBs, in ng I-TEQ/kg: 0.48, 0.35, 2.34, 0.74, and 0.23, for an average of 

0.8 ng I-TEQ/kg. Based on these results they provide a “first estimate” of emissions from forest 

fires in France of 28.8 g I-TEQ/year. 

 Using a controlled-burn facility, Gullett and Touati (2003) estimated CDD/CDF 

emissions through the testing of three biomass samples collected from the Oregon coast near 

Seal Rock and from four biomass samples collected from the North Carolina Piedmont region, 

approximately 200 km from the Atlantic coast. The samples generally consisted of equal 

portions of live shoots (needles cut from tree branches) and needle litter gathered from the forest 

floor. The Oregon samples were composed of pine needles (Pinus contorta and Pinus 

monticola) and hemlock needles (Tyuga heterophylla); the North Carolina samples were 

composed entirely of lobolly pine (Pinus taeda). The combustion of these seven samples, piled 

approximately 10 cm high, took place on top of an open, flat combustion platform. The average 

total TEQ emission factors for the three Oregon samples and the four North Carolina samples 

were 15 ng and 25 ng WHO98 TEQDF/kg, respectively. Because the waxy cuticle layer on pine 

needles has been demonstrated to absorb lipophilic compounds from the atmosphere, Gullett and 

Touati (2003) also extracted a raw, as-received Oregon biomass sample to determine whether the 
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1 observed emissions were due to simple vaporization of existing CDDs/CDFs or the formation of 

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new CDDs/CDFs in the combustion process. The CDD/CDF concentration in the sample 

measured 1.3 ng WHO98 TEQDF/kg, which is approximately 20 times lower than the Oregon 

CDD/CDF emission factor. The CDD/CDF isomer patterns of the extracted biomass samples 

and the emission samples were similar. Therefore, this preliminary evidence suggests CDD/CDF 

emissions are not due solely to vaporization of cuticle-bound CDDs/CDFs but are primarily a 

result of new formation during forest fires. 

Gullett et al. (2008) present emission factor data for several types of forest and grass 

fires. The study used the same burn chamber as described above for Gullett and Touati (2003). 

Burn tests (n = 27) on forest biomass from five sources gave emission factors ranging from 0.3 

to 26.3 ng TEQ/kg of carbon burned with an average of 5.8 ng TEQ/kg of carbon burned (the 

TEQs were reported to be essentially the same whether presented as I-TEQs or WHO95). The 

authors indicate that forest biomass contains approximately 50% carbon. Thus, the reported 

emission factors can be converted to a whole biomass basis by multiplying by 0.5. The study 

also found that the total CDD/CDF in the emissions exceeded the amounts in the raw biomass by 

a factor of four, confirming that formation was occurring during the combustion process. 

Meyer et al. (2004, 2007) conducted a series of chamber and field tests in Australia to 

characterize dioxin emission from a variety of fire types. Five chamber tests were conducted 

with forest leaf litter (eucalyptus, box, and ironbark) and producing a mean emission factor of 

0.37 ng WHO98 TEQDF/kg of fuel. A total of 18 forest fire field tests were conducted using 

portable high volume air samplers. The field monitors also measured CO2, which was related to 

combusted biomass and used to calculate emission factors. The field test results are summarized 

below: 

• Ten prescribed burns in Queensland (coastal forest), Victoria (eucalyptus), and Western 

Australia (jarrah forest) with a mean emission factor of 0.5 ng WHO98 TEQDF/kg of fuel.

• Three fires in tropical savannas with a mean emission factor of 1.1 ng WHO98 TEQDF/kg 

of fuel.

• Two wildfires in Victoria (mixed eucalyptus) with a mean emission factor of 

0.7 ng WHO98 TEQDF/kg of fuel. 

• Three woodland fires with a mean emission factor of 1.5 ng WHO98 TEQDF/kg of fuel.
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1 6.4.2. Air Emission Factors 

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Several lines of evidence indicate that forest fires release dioxins to the environment. 

Sediment core studies have shown that dioxins were found at measurable levels prior to the 

industrial revolution (Smith et al., 1992, 1993). The most likely source for these residues is 

natural fires. Gullett et al. (2003, 2008) used chamber tests to show that more dioxins are 

emitted than contained in the biomass being burned. Finally, multiple chamber studies and 

one large field study (summarized above) have now measured dioxins in forest fire emissions. 

Thus, it is reasonably well established that dioxin emissions occur from forest fires.

The chamber studies have shown a wide range of results (means across tests vary from 

0.37 to 25 ng TEQ/kg) suggesting that emissions are highly variable across fuel types and fire 

conditions. The Australian field measurements suggest emission factors near the low end of the 

chamber results. Meyer et al. (2004) believe that the chamber tests have overestimated dioxin 

emissions due to longer residence time in the formation temperatures than occurs in the field. 

They also support their belief that forest fires have low dioxin emissions on the basis of ambient 

air monitoring in southern Victoria during the large forest fires in northeast Victoria in January 

2003. The monitor showed clear impacts of the plume during the fire based on sharp increases in 

particulate and potassium salts (biomass tracer) but no increases in dioxins. 

As summarized in Table 6-1, a total of 6 chamber studies have been conducted with a 

variety of wood types and a cumulative n of 46. Also, as summarized in Table 6-1, one large 

field study was conducted in Australia involving various types of forests with an n of 18. The 

n-weighted average for the field tests is 0.8 ng TEQDF/kg and for the chamber tests is 

5.9 ng TEQDF/kg. As discussed below, both types of tests have uncertainties, and the midpoint 

of this range (3 ng TEQDF/kg) was selected as a reasonable assumption for a central value 

emission factor and applied to all three reference years. 

 The confidence in this emission factor depends on how representative the test data are of 

the types of wood and fires that occur in North America: 

• Wood types―Over 20 different types of forests exist in the United States (see Figure 6-2) 

with a variety of wood types, biomass density, moisture content, height, etc. The 

chamber tests did not represent all wood types found in North America but did include 

some common types such as pine and oak. All of the field tests were conducted in 
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1 Australia; some included pines, but others were primarily eucalyptus and jarrah trees, 

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which are uncommon in the United States. 

• Fire types―A number of different types of fires can occur such as ground fires, which 

burn the humus layer of the forest floor but do not burn appreciably above the surface; 

surface fires, which burn forest undergrowth and surface litter; and crown fires, which 

advance through the tops of trees or shrubs. It is not uncommon for two or three of the 

types to occur simultaneously. The ground level monitors cannot directly sample the 

high smoke plume generated near the tops of trees during a crown fire. Some of the 

smoke generated during a crown fire is present at ground level, but it is uncertain how 

representative this smoke is of the main plume. Ground/surface fires create a smoke 

plume, which starts near ground level, and the monitors are much more likely to collect 

samples, which are representative of these emissions. Similarly, the chamber tests cannot 

mimic the intensity and scale of crown fires but may be representative of the conditions 

associated with the smaller ground/surface fires. 

In summary, the forest fire data appear to represent some but not all of the wood types 

and fire types that occur in North America. The large database of emission tests suggest a wide 

range of emission factors, but this is reasonable considering that they cover a wide variety of 

wood types, fire types and burn conditions. The wide range of results increases the confidence 

that the full range of emission factors have been characterized and that the midpoint of the range 

provides a reasonable central point estimate. On this basis, the emission factor has been 

upgraded from preliminary to quantifiable. 

6.4.3. Air Activity Levels

 EPA (2006) derived forest fire activity estimates using data on acres burned per year and 

estimates of the amount of biomass per acre. New data for acres burned were found at a 

database managed by the National Interagency Fire Center (NIFC) (www.nifc.gov/fire). These 

new data are compared to the previously used data in Table 6-2. The data are generally 

comparable except for the wildfire data for 1987 and 1995 where the NIFC data are less than half 

the previously used values. These two estimates were changed to reflect these new data. The 

amount of biomass burned per acre was assumed to be 9.43 MT/acre for wildfires and 

7.44 MT/acre for prescribed burns (Ward et al., 1976). The total forest fire activities were 

estimated as 61 MMT in 1987, 55 MMT in 1995 and 243.8 MMT in 2000. A review of the 

NFIC historical data on wildfires from 1960 to 2008 suggests that the acres burned in 2000 were 

above average and the acres burned in 1987 and 1995 were below average. 
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1 6.4.4. Water Releases

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It is possible that dioxin-contaminated particles could be entrained in water used to fight 

fires or rainwater that falls on the site. This water could run off the site and eventually get into 

surface waters. No quantitative release estimates could be made. Therefore, this is a possible 

but unquantifiable source. 

6.4.5. Solid Residue Releases

 Buckland et al. (1994) collected soil samples in a national park near Sydney, Australia. 

Some were collected in areas where large brush fires had occurred 6 weeks earlier and others in 

areas where no fires had occurred. The sampling depth was 2 cm. The dioxin content of 

samples from burnt areas ranged from 2.2 to 36.8 pg I-TEQ/g, and the samples from unburnt 

areas ranged from 3.0 to 10.0 pg I-TEQ/g. They concluded that the fires had not had a major 

impact on the soil levels.

No other direct measures of CDD/CDF content of forest fire ash were found. Wunderli 

et al. (1996) determined an average of 10 ng I-TEQ/kg of ash generated for clean wood burned in 

stoves. This value is similar to the levels measured by Buckland et al. (1994) in surface soils 

after fires and is assumed here for forest fires. UNEP (2005) recommended 4 ng I-TEQ/kg of 

material burned (this was derived from an estimate of 200 ng I-TEQ/kg of ash and assumption of 

2% ash). This emission factor is assigned a preliminary confidence rating because direct 

measurements were available from only one area/fire type and it is unclear if it is representative 

of other areas.

 The ash yield from wood grown in temperate zones is 0.1 to 1%, and bark produces 3 to 

8% ash (Ragland et al., 1991). A midrange value of 3% is assumed here for all wood burned. 

Multiplying this value by the activity factors discussed above for biomass burned in fires yields 

the following: 1.8 MMT in 1987, 1.7 MMT in 1995, and 7.3 MMT in 2000. 

6.4.6. Products―None

6.4.7. Release Summary

The inventory decision criteria and releases to all media are summarized below: 
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Inventory Decision Criteria for Forest and Brush Fires

Air Water Solids Products

Emission tests for at least two units/source types with Yes Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes No

the class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q P

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Forest and Brush Fires

Air Releases

Emission Factors 

• 1987―3 ng WHO98

• 1995―3 ng WHO98

• 2000―3 ng WHO98

TEQDF/kg. 

TEQDF/kg. 

TEQDF/kg. 

Activity Levels

• 1987―61 MMT. 

• 1995―55 MMT. 

• 2000―243.8 MMT.

Releases

• 1987―180 g WHO98

• 1995―170 g WHO98

• 2000―730 g WHO98

TEQDF. 

TEQDF. 

TEQDF.

Water Releases

None. 

Solid Residue Releases

Emission Factors 

• 1987―10 ng 

• 1995―10 ng 

• 2000―10 ng 

I-TEQDF/kg ash 

I-TEQDF/kg ash 

I-TEQDF/kg ash 

(Preliminary). 

(Preliminary). 

(Preliminary).

Activity Levels

• 1987―1.8 MMT

• 1995―1.7 MMT

• 2000―7.3 MMT

ash. 

ash. 

ash.

Releases

• 1987―18 g I-TEQDF

• 1995―17 g I-TEQDF

• 2000―73 g I-TEQDF

(Preliminary). 

(Preliminary). 

(Preliminary).

Products

None.

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6.5. BACKYARD BARREL BURNING

6.5.1. Air Releases

Additional studies are presented below, and changes were made to the 2000 activity 

estimate and resulting release estimate.

 
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1 Hirai et al (2003) estimated total CDD/F emission factors from soil measurements at 

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open burning sites. Soil concentrations in India of 52 pg TEQ/g implied an emission factor over 

500 pg TEQ/g of waste. Soil concentrations in Cambodia of 400 pg TEQ/g implied an emission 

factor over 4000 pg TEQ/g of waste. 

Wevers et al. (2004) measured dioxin emissions from the combustion of garden waste in 

barrels and in open fires, and the incineration of household waste in an empty oil drum. Each set

of experiments was composed of eight individual experiments over 4 hours. Air samples were 

taken in the plume with a medium volume sampler equipped with a quartz filter and a 

polyurethane plug. Emission factors in the order of magnitude of 4.5 ng TEQ/kg combusted 

garden waste and 35 ng TEQ/kg burned municipal waste were determined. 

Hedman et al. (2005) measured the emissions of CDD/CDFs and PCBs from 

uncontrolled domestic combustion of waste. The waste fuels used were garden waste, paper, 

paper and plastic packaging, refuse-derived fuel (RDF), PVC, and electronic scrap. Samples 

were collected from the emissions drawn through a conical fume hood placed directly over the 

barrel. Combustions including PVC and electronic scrap emitted several orders of magnitude 

more dioxins than the other waste fuels. Emissions from the other fuels had considerable 

variations, but the levels were difficult to relate to waste composition. Emission factors of 

CDD/CDF and PCB from the backyard burning ranged from 2.2 to 13,000 ng (WHO TEQ)/kg. 

The levels found in ash usually were less than 5% of the total. For assessment of total emissions 

of dioxins and PCB from backyard burning of low and moderately contaminated wastes, an 

emission factor range of 4−72 ng WHO TEQ/kg is suggested. 

 Gonczi et al. (2005) tested emissions from burning domestic wastes in barrels (19 tests) 

and open fires (2 tests). Gas collected above these fires allowed for estimation of emission 

factors for CDD/CDFs and dioxin-like PCBs for barrel burn and open fire conditions. The 

material burned consisted of various mixtures of garden wastes, straw, paper, several forms of 

plastic, waste motor oil, RDF, and computer scrap. A barrel burn with a mix of garden waste 

and polyvinyl chloride (PVC) waste had the highest emission factor of 

96,000 ng WHO98 TEQDF/kg burned. The other emission tests ranged from 2.2 to 

890 ng WHO98 TEQP/kg burned. 

The emission factor selected in the original report was 76.8 ng WHO98 TEQDF/kg 

(72.8 ng I-TEQDF/kg) based on studies by Gullett et al. (1999, 2000) and Lemieux et al. (2000). 
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1 This falls within the range found by Gonczi et al. (2005), about twice the level found by Weveres 

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et al. (2004) and near the upper end of the range recommended by Hedman et al. (2005). 

Accordingly, the original emission factor still appears to be a reasonable central estimate, and no 

changes were made. 

The original report (US EPA, 2006) presented data from six surveys on the prevalence of 

backyard trash burning. This data was combined with trash generation rates and Census data on 

rural populations to derive national estimates of the amount of trash burned in backyards for each 

of the reference years. The original report also described an alternative activity estimate for 

2000 developed by OAQPS. The alternative method used similar factors applied on a county by 

county basis and made adjustments for amount of waste recycled and influence of open burning 

bans. The present report considered the OAQPS method more accurate and adopted it for the 

year 2000. This resulted in a 16% increase in activity and a corresponding increase in releases in 

2000. No changes were made to the release estimates for 1987 and 1995. All activity estimates 

are presented in the release summary below.

6.5.2. Solid Residue Releases

 Minh et al. (2003) measured CDDs and CDFs in soils from open burning dump sites for 

municipal waste in the Philippines, Cambodia, India, and Vietnam. Average levels across sites 

ranged from 2 to 520 pg WHO98 TEQ/g. The levels were higher than those in agricultural and 

urban areas distant from the dump sites. 

Lemieux (1997) collected ash samples from open barrel burning and analyzed them for 

CDDs/CDFs. Ash samples from the experiments were combined, resulting in two composite 

samples, one for recyclers, and one for nonrecyclers. The average of the recycler and 

nonrecycler values were averaged and assumed to apply to all three reference years: 1,670 ng 

WHO98 TEQDF/kg (1,640 ng I-TEQDF/kg) of ash.

 The generation rate of ash from backyard barrel burning is assumed to match that of 

municipal waste incineration, which has a central estimate of 15% for bottom ash as discussed in 

Section 3.1. Applying this to the total amount burned (as discussed above) yields these activity 

levels for each reference year: 1.2 MMT in 1987, 1.2 MMT in 1990, and 1.2 MMT in 2000. 

The solid residue releases were estimated by multiplying the emission factor and activity 

level for each reference year (results shown in summary chart below). It is possible that some of 
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1 the ash from barrel burning is taken to municipal waste landfills, but most is probably not. 

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Therefore, all of these releases are assumed to occur to the open environment. 

6.5.3. Release Summary

The inventory decision criteria and releases to all media are summarized below: 

 

Inventory Decision Criteria for Backyard Barrel Burning

Air Water Solids Products

Emission tests for at least two units/source types with Yes Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have Yes Yes

understandable differences. 

Emission factor tests represent units that are typical of the Yes Yes

class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q Q
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Backyard Barrel Burning

Air Releases

Emission Factors 

• 1987―77 ng WHO98

• 1995―77 ng WHO98

• 2000―77 ng WHO98

TEQDF/kg (73

TEQDF/kg (73

TEQDF/kg (73

ng I-TEQDF/kg). 

ng I-TEQDF/kg). 

ng I-TEQDF/kg).

Activity Levels • 1987―7.87 MMT. 

 • 1995―8.18 MMT. 

 • 2000―7.79 MMT.

Releases

• 1987―610 g WHO98

• 1995―630 g WHO98

• 2000―600 g WHO98

TEQDF

TEQDF

TEQDF

(570 g I-TEQDF). 

(600 g I-TEQDF). 

(570 g I-TEQDF).

Water Releases

None

Solid Residue Releases

Emission Factors

• 1987―1,700 ng WHO98

• 1995―1,700 ng WHO98

• 2000―1,700 ng WHO98

TEQDF/kg (1,600 ng I-TEQDF/kg) 

TEQDF/kg (1,600 ng I-TEQDF/kg) 

TEQDF/kg (1,600 ng I-TEQDF/kg)

of ash. 

of ash. 

of ash.

Activity Levels

• 1987―1.2 MMT. 

• 1995―1.2 MMT. 

• 2000―1.2 MMT.

Releases

• 1987―2,000 g WHO98

• 1995―2,000 g WHO98

• 2000―2,000 g WHO98

TEQDF (1,900 g I-TEQDF). 

TEQDF (2,000 g I-TEQDF). 

TEQDF (1,900 g I-TEQDF).

Products

None.

1 

2 

3 

4 

5 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 6.6. RESIDENTIAL YARD WASTE BURNING

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16 

17 

18 

19 

20 

21 

22 

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24 

25 

26 

27 

28 

29 

30 

31 

Additional studies are presented below, and changes were made to the release estimates.

6.6.1. Air Releases

 Ikeguchi and Tanaka (1999) simulated the open burning of several waste types using a 

large furnace with open doors. The flue gas was sampled immediately downstream of the 

furnace. One test was conducted with tree and leaf materials. A total of 162.7 kg of this material 

were burned in a batch mode lasting 33 minutes. The emission factor was estimated as 

4.7 I-TEQ/kg of waste. 

Gonczi et al. (2005) measured dioxin emissions from burning various types of domestic 

wastes under a variety of conditions. One test involved the open burning of garden waste, which 

was composed of approximately one half wood branches and one half leaves and grass. A 

sampling hood was mounted 0.5 m above the fire to collect the emissions. This test yielded an 

emission factor of 27 ng TEQ/kg.

Wevers et al. (2004) measured dioxin emissions from the combustion of garden waste in 

barrels and in open fires, and the incineration of household waste in an empty oil drum. Each set 

of experiments was composed of eight individual experiments over 4 hours. Air samples were 

taken in the plume with a medium volume sampler equipped with a quartz filter and a 

polyurethane plug. For garden waste, an emission factors of 4.5 ng TEQ/kg of waste was 

determined.

Hedman et al. (2005) measured the emissions of CDD/CDFs and PCBs from 

uncontrolled burning of various forms of household waste. Samples were collected from the 

emissions drawn through a conical fume hood placed directly over the barrel. For burns with 

garden waste (n = 3), CDD/CDF emission factors ranged from 12 to 100 ng WHO98 TEQ/kg of 

material burned with a median value of 20 ng WHO98 TEQ/kg of material burned. 

 The studies summarized above had central values ranging from about 4 to 

27 ng WHO98 TEQ/kg of material burned. A midrange value of 10 ng WHO98 TEQ/kg of 

material burned was selected as an overall central estimate. 

 As described in the original report, OAQPS estimated that 255,000 MT of leaf and 

255,000 MT of brush (total of 510,000 MT of yard waste) were burned in 2000. Estimates for 

1987 and 1995 were derived by assuming that the activities would be proportional to the total 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 U.S. population for these years. This approach yields the following activity levels for each 

2 

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6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

reference year: 441,000 MT in 1987, 485,000 MT in 1995, and 510,000 MT in 2000. 

6.6.2. Water Releases―None

6.6.3. Solid Residue Releases

 Hedman et al. (2005) measured an ash emission factor of 0.02 ng WHO98 TEQ/kg of 

waste burned for barrel burning of garden waste. It is assigned a preliminary confidence rating 

because it is based on only one waste sample. 

6.6.4. Products―None

6.6.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Residential Yard Waste Burning

Air Water Solids Products

Emission tests for at least two units/source types with Yes No

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes

understandable differences. 

Emission factor tests represent units that are typical of Yes Yes

the class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q P
This document is a draft for review purposes only and does not constitute Agency policy.

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1 

2 

3 

4 

5 

6 

7 

8 

Residential Yard Waste Burning

Air Releases

Emission Factors 

• 1987―10 ng WHO98

• 1995―10 ng WHO98

• 2000―10 ng WHO98

TEQDF/kg. 

TEQDF/kg. 

TEQDF/kg.

Activity Levels

• 1987―441,000 MT. 

• 1995―485,000 MT. 

• 2000―510,000 MT.

Releases

• 1987―4 g WHO98

• 1995―5 g WHO98

• 2000―5 g WHO98

TEQDF. 

TEQDF. 

TEQDF.

Water Releases

None. 

Solid Residue Releases

Emission Factors 

• 1987―0.02 ng WHO98

• 1995―0.02 ng WHO98

• 2000―0.02 ng WHO98

TEQDF/kg of material burned (Preliminary). 

TEQDF/kg of material burned (Preliminary). 

TEQDF/kg of material burned (Preliminary).

Activity Levels

• 1987―441,000 MT. 

• 1995―485,000 MT. 

• 2000―510,000 MT.

Releases

• 1987―<0.1g WHO98 TEQDF (Preliminary). 

• 1995―<0.1 g WHO98 TEQDF (Preliminary). 

• 2000―<0.1 g WHO98 TEQDF (Preliminary).

Products

None.

6.7. LAND-CLEARING DEBRIS BURNING

6.7.1. Air Releases

The emission factor was changed to correspond to the new forest fire emission factor. No 

direct measurements of CDD/CDF emissions from the burning of land-clearing debris have been 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 6-29 DRAFT: DO NOT CITE OR QUOTE

1 performed, so the average emission factor of 3 ng WHO98 TEQDF/kg, which was used for forest 

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16 

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18 

19 

20 

21 

22 

23 

24 

25 

fires is also used for burning of land-clearing debris. This factor was assumed to apply to all 

three reference years. A preliminary confidence rating was assigned to the emission factor 

estimate because it was derived from forest fire testing and may not be representative of 

land-clearing debris burning. 

No changes were made to the activity level estimates. As described in EPA (2006), these 

were provided by OAQPS and involved multiplying estimates of acres cleared during residential, 

nonresidential, and roadway construction by the fuel-loading factors.

6.7.2. Water Releases―None

6.7.3. Solid Residue Releases

 Wunderli et al. (1996) determined an average of 10 ng I-TEQ/kg of ash generated for 

clean wood. This value is recommended by UNEP (2005) for virgin biomass fired stoves and is 

adopted here for ash from land-clearing debris burning. It is assigned a preliminary confidence 

rating because ash from land-clearing debris burning may be different from stove ash. 

 The ash yield from wood grown in temperate zones is 0.1 to 1%, and bark produces 3 to 

8% ash (Ragland et al., 1991). A midrange value of 3% is assumed here for all debris burned. 

Multiplying this value by the activity factors discussed above for land clearing debris fires yields 

the following: 831,000 MT in 1987, 792,000 MT in 1995, and 852,000 MT in 2000. 

6.7.4. Release Summary

The inventory decision criteria and releases to all media are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 6-30 DRAFT: DO NOT CITE OR QUOTE

Inventory Decision Criteria for Land-Clearing Debris Burning

Air Water Solids Products

Emission tests for at least two units/source types with No No

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have 

understandable differences.

No No

Emission factor tests represent units that are typical of the 

class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). P P

1 

2 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 6-31 DRAFT: DO NOT CITE OR QUOTE

Land-Clearing Debris Burning

Air Releases

Emission Factors 

• 1987―3 ng WHO98

• 1995―3 ng WHO98

• 2000―3 ng WHO98

TEQDF/kg (Preliminary). 

TEQDF/kg (Preliminary). 

TEQDF/kg (Preliminary).

Activity Levels

• 1987―27.7 MMT. 

• 1995―26.4 MMT. 

• 2000―28.4 MMT.

Releases

• 1987―83 g WHO98

• 1995―79 g WHO98

• 2000―85 g WHO98

TEQDF

TEQDF

TEQDF

(Preliminary). 

(Preliminary). 

(Preliminary).

Water Releases

None. 

Solid Residue Releases

Emission Factors 

• 1987―10 ng 

• 1995―10 ng 

• 2000―10 ng 

I-TEQDF/kg of ash (Preliminary). 

I-TEQDF/kg of ash (Preliminary). 

I-TEQDF/kg of ash (Preliminary).

Activity Levels

• 1987―0.831 MMT

• 1995―0.792 MMT

• 2000―0.852 MMT

ash. 

ash. 

ash.

Releases

• 1987―8 g WHO98

• 1995―8 g WHO98

• 2000―9 g WHO98

TEQDF (Preliminary). 

TEQDF (Preliminary). 

TEQDF (Preliminary).

Products

None.

1 

2 

3 

4 

5 

6 

6.8. UNCONTROLLED COMBUSTION OF POLYCHLORINATED BIPHENYLS

 No new studies were found on this topic, and no changes were made to the release 

estimate. The use of PCBs in new transformers in the United States is banned, and their use in 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 existing transformers and capacitors is being phased out under regulations promulgated under the 

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16 

17 

18 

19 

20 

Toxic Substances Control Act. 

Because of the accidental nature of these incidents, the variation in duration and intensity 

of elevated temperatures, the variation in CDD/CDF content of residues, and the uncertainty 

regarding the amount of PCBs still in service in electrical equipment, EPA judged the available 

data inadequate for developing any quantifiable emission estimates. Therefore, they are

considered unquantifiable for air and solid residue releases. Information on this source is also 

presented in Chapter 11. 

Uncontrolled Combustion of PCBs

CDDs and CDFs have been detected in soot from PCB fires, but the available information is 

insufficient to make quantitative release estimates. Therefore, it is considered an unquantifiable 

source for air and solid residue releases.

6.9. VOLCANOES

 No evidence exists that this source can release CDDs/CDFs and, therefore, it is not even 

considered unquantifiable. 

6.10. FIREWORKS

 No new studies were found on this topic, and no changes were made to the release 

estimate. Evidence exists that fireworks can release CDDs/CDFs to the air and solid residues, 

but insufficient information exists to make a quantitative estimate. Therefore, it is considered 

unquantifiable for air and solid residue releases.

Fireworks

CDDs and CDFs have been detected in fireworks ash and in air after using fireworks, but the 

available information is insufficient to make quantitative release estimates. 

considered an unquantifiable source for air and solid residue releases.

Therefore, it is 

6.11. OPEN BURNING AND OPEN DETONATION OF ENERGETIC MATERIALS

No evidence exists that this source can release CDDs/CDFs, and, therefore, it is not even 

considered unquantifiable. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 6.12. UNDERGROUND COAL FIRES

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17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

Underground coal fires are a possible source of CDD/CDFs to the air because CDD/CDF 

releases have been measured from other forms of coal burning. However, no emissions data or 

activity information were found specifically for this source, so no quantitative release estimate 

could be made (Not quantifiable). 

Underground Coal Fires

The available information is insufficient to make quantitative release estimates (Not 

quantifiable). 

6.13. AGRICULTURAL BURNING

This source category was not included in the original report. Agricultural fields are 

sometimes burned prior to harvesting to facilitate crop collection and sometimes after harvesting 

to clear the fields and control weeds. In the United States, it is believed that this practice is most 

prevalent for sugar cane, and it is the only crop addressed in this section. 

6.13.1. Air Releases

Gullett et al. (2006) measured dioxin emission from simulated sugarcane field burns. 

Sugarcane leaves from Hawaii and Florida were burned in a manner simulating the natural 

physical dimensions and biomass density found during the practice of preharvest field burning. 

Eight composite burn tests consisting of 3−33 kg of biomass were conducted, some with 

replicate samplers. Emission factor calculations using sampled concentration and measured 

mass loss compared well to rigorous carbon balance methods commonly used in field sampling. 

The two sources of sugarcane had distinctive emission levels, as did tests on separate seasonal 

gatherings of the Florida sugarcane. The average emission factor for two tests of Hawaii 

sugarcane was 114 ng TEQ/kg of biomass and for two gatherings of Florida sugarcane was 

11 ng TEQ/kg biomass and 2 ng TEQ/kg biomass (these values were originally reported on a 

carbon basis and were converted to a total biomass basis by multiplying by 45%). 

Meyer et al. (2004) conducted a series of chamber and field tests in Australia to 

characterize dioxin emissions from a variety of fire types including agricultural fires. The mean 

emission factors from the chamber tests are listed below: 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 • Straw―17 ng WHO98 TEQDF/kg of fuel.

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5 

6 

7 

8 

9 

10 

11 

12 

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15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

• Sorghum―35 ng WHO98 TEQDF/kg of fuel.

• Sugar cane―5 ng WHO98 TEQDF/kg of fuel.

Additionally, two field tests were conducted during sugar cane burning. These tests used 

portable high volume air samplers. The field monitors also measured CO2, which was related to 

combusted biomass and used to calculate emission factors. The emission factor was 

1.2 ng WHO98 TEQDF/kg of fuel. 

UNEP (2005) recommended an emission factor for agricultural residue burning of 

30 ng I-TEQ/kg of material burned (in fields where pesticides or other contaminants are present) 

and 0.5 ng I-TEQ/kg of material burned (in fields where pesticides or other contaminants are not 

present). 

In summary, sugar cane chamber tests have produced a very wide range of emission 

factors from 2 to 114 ng TEQ/kg. The limited field testing yielded an emission factor of 

1 ng TEQ/kg. Accordingly, there is considerable uncertainty about what value is most 

representative of U.S. conditions. For the purposes of a preliminary estimate, a value of 

10 ng TEQ/kg (rounded geometric mean of range) was selected.

Gullett et al. (2006) derived activity estimates for sugar cane burning in the United States

using the following factors: the sugar cane field area for Hawaii, Texas, Louisiana, and Florida; a 

biomass production rate of 20 dry tons/ha; and the assumption that 50% of the sugar cane crop 

was burned with 90% combustion efficiency. This approach suggests that about 3.5 MMT of 

sugar cane were burned. The data were from the 2001−2003 time frame and are assumed here to 

apply to 2000. USDA (2009) indicates that sugar cane production increased by about 10% from 

1995 to 2000, and a similar amount is assumed for 1987 to 1995. On this basis, the amount of 

sugar cane burned in 1987 was 2.8 MMT, and the amount in 1995 was 3.1 MMT. Considering 

the multiple assumptions required for this estimate, it is assigned a preliminary confidence 

rating.

6.13.2. Water Releases―None
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 6-35 DRAFT: DO NOT CITE OR QUOTE

1 6.13.3. Solid Residue Releases

2 

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6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

Gullett et al. (2006) measured the dioxin content of ash from several samples with a 

range of 0.004 to 1.22 ng WHO98 TEQ/kg of initial carbon of the biomass. Meyer et al. (2004) 

measured the dioxin content of sugar cane ash as 1 ng WHO98 TEQ/kg of carbon. An emission 

factor of 1 ng WHO98 TEQ/kg of carbon was selected as a central value within the range 

observed by Gullett et al. (2006). It was converted to 0.5 ng TEQ/kg of biomass burned 

assuming 45% carbon in the biomass. UNEP (2005) recommends a higher land emission factor 

for agricultural residue burning of 10 ng I-TEQ/kg of material burned, but the basis was not 

clear. Based on the limited testing showing widely ranging results, it was assigned a preliminary 

confidence rating. 

6.13.4. Products―None

6.13.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Sugar Cane Burning

Air Water Solids Products

Emission tests for at least two units/source types with Yes Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have No No

understandable differences.

Yes Yes

Emission factor tests represent units that are typical of the 

class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). P P
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 6-36 DRAFT: DO NOT CITE OR QUOTE

1 

2 

3 

4 

5 

6 

7 

8 

9 

Sugar Cane Burning

Air Releases

Emission Factors 

• 1987―10 ng 

• 1995―10 ng 

• 2000―10 ng 

WHO98

WHO98

WHO98

TEQDF/kg of biomass 

TEQDF/kg of biomass 

TEQDF/kg of biomass

(Preliminary). 

(Preliminary). 

(Preliminary).

Activity Levels

• 1987―2.8 MMT

• 1995―3.1 MMT

• 2000―3.5 MMT

(Preliminary). 

(Preliminary). 

(Preliminary).

Releases

• 1987―28 g WHO98

• 1995―31 g WHO98

• 2000―35 g WHO98

TEQDF

TEQDF

TEQDF

(Preliminary). 

(Preliminary). 

(Preliminary).

Water Releases

None. 

Solid Residue Releases

Emission Factors 

• 1987―0.5 ng WHO98

• 1995―0.5 ng WHO98

• 2000―0.5 ng WHO98

TEQDF/kg of biomass 

TEQDF/kg of biomass 

TEQDF/kg of biomass 

(Preliminary). 

(Preliminary). 

(Preliminary).

Activity Levels

• 1987―2.8 MMT

• 1995―3.1 MMT

• 2000―3.5 MMT

(Preliminary). 

(Preliminary). 

(Preliminary).

Releases

• 1987―1 g WHO98

• 1995―2 g WHO98

• 2000―2 g WHO98

TEQDF

TEQDF

TEQDF

(Preliminary). 

(Preliminary). 

(Preliminary).

Products

None.

6.14. OPEN BURNING DEMOLITION/CONSTRUCTION WOOD 

6.14.1. Air Releases

 This is a new section. No direct measurements of CDD/CDF emissions from the open 

burning of demolition/construction wood were found. However, this activity involves similar 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 6-37 DRAFT: DO NOT CITE OR QUOTE

1 material as burned in structural fires. As discussed in Section 6.2.1, the presence of 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

manufactured boards and treated lumber in structures is expected to increase dioxin emissions 

relative to the combustion of untreated natural wood. Section 6.2.1 derived a structural fire 

emission factor of 32 μg I-TEQ/fire by averaging data from Carroll (1996) and Thomas and 

Spiro (1995) and converting to a mass basis by dividing by a default fuel-loading factor for 

structural fires of 1.15 tons/fire (ERG, 2001), yielding 28 ng I-TEQ/kg. This factor was assumed 

to apply to the open burning of demolition/construction wood for all three reference years. A 

preliminary confidence rating was assigned to the emission factor estimate because it was 

derived from structural fire estimates that were considered preliminary. 

 U.S. DOE (2000) reports that 8 MMT of wood construction and demolition debris were 

generated in 1995. The majority of this waste was legally disposed via landfill or incineration. 

However, an unknown portion is open burned at construction sites. For the purposes of a 

preliminary estimate, it is assumed that 10% of the total, or 0.8 MMT, is open burned during all 

three reference years.

6.14.2. Water Releases―None

6.14.3. Solid Residue Releases

 As discussed in Section 6.2, an ash emission factor of 300 ng WHO98 TEQDF/kg of 

material burned was developed for structural fires and is adopted here for ash from open burning 

of construction/demolition wood. A preliminary confidence rating was assigned to the emission 

factor estimate because it was derived from structural fire estimates. 

 The ash yield from wood grown in temperate zones is 0.1 to 1%, and bark produces 3 to 

8% ash (Ragland et al., 1991). A midrange value of 3% is assumed here for all wood burned. 

Multiplying this value by the activity factors discussed above for open burning of 

construction/demolition wood yields the following: 0.024 MMT in all reference years. These are 

given a preliminary confidence rating because they are derived from emission factors with 

preliminary confidence ratings. 

6.14.4. Release Summary

The inventory decision criteria and releases to all media are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 6-38 DRAFT: DO NOT CITE OR QUOTE

Inventory Decision Criteria for Open Burning Demolition/Construction Wood

Air Water Solids Products

Emission tests for at least two units/source types with No No

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have 

understandable differences.

No No

Emission factor tests represent units that are typical of the 

class. 

Activity estimates based on source-specific surveys. No No

Conclusion (Q = Quantitative, P = Preliminary). P P

1 

2 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 6-39 DRAFT: DO NOT CITE OR QUOTE

Open Burning Demolition/Construction Wood

Air Releases

Emission Factors 

• 1987―28 ng WHO98

• 1995―28 ng WHO98

• 2000―28 ng WHO98

TEQDF/kg (Preliminary). 

TEQDF/kg (Preliminary). 

TEQDF/kg (Preliminary).

Activity Levels

• 1987―0.8 MMT

• 1995―0.8 MMT

• 2000―0.8 MMT

(Preliminary). 

(Preliminary). 

(Preliminary).

Releases

• 1987―22 g WHO98

• 1995―22 g WHO98

• 2000―22 g WHO98

TEQDF

TEQDF

TEQDF

(Preliminary). 

(Preliminary). 

(Preliminary).

Water Releases

None. 

Solid Residue Releases

Emission Factors 

• 1987―300 ng 

• 1995―300 ng 

• 2000―300 ng 

WHO98

WHO98

WHO98

TEQDF/kg (Preliminary). 

TEQDF/kg (Preliminary). 

TEQDF/kg (Preliminary).

Activity Levels

• 1987―0.024 MMT

• 1995―0.024 MMT

• 2000―0.024 MMT

(Preliminary). 

(Preliminary). 

(Preliminary).

Releases

• 1987―7 g WHO98

• 1995―7 g WHO98

• 2000―7 g WHO98

TEQDF

TEQDF

TEQDF

(Preliminary). 

(Preliminary). 

(Preliminary).

Products

None.

1 

2 

3 

4 

5 

6 

7 

6.15. OIL SPILL BURNING

 Aurell and Gullett (2010) measured dioxin emissions during in situ burning of oil spilled 

into the Gulf of Mexico over the time period of July 13-16, 2010. They derived an emission 

factor of 1.7 ng TEQ/kg of oil burned assuming that congeners below detection limits equal zero. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 If congeners below detection limits were set to their full detection limit, the emission factor was 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

estimated to be 3.0 ng TEQ/kg. However, no activity information was found specifically for in 

situ oil burning during the reference years, so no quantitative release estimate could be made 

(Not quantifiable). 

Oil Spill Burning

The available information is insufficient to make quantitative release estimates (Not 

quantifiable). 

6.16. CANDLE BURNING

 Candle burning is a possible source of CDD/CDFs to the air because CDD/CDF releases 

have been measured from other types of fires. However, no emissions data or activity 

information were found specifically for this source, so no quantitative release estimate could be 

made (Not quantifiable). 

Candle Burning 

The available information is insufficient to make quantitative release estimates (Not 

quantifiable).
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 6-1. CDD/CDF emission factors (ng/kg) for forest fires

Biomass description 

and location Wood type Test device n

ng TEQDF/kg of biomass

Mean (Range) Reference

Tree from Central North 

Carolina 

Loblolly pine Chamber 7 0.86a Gullett et al. (2008)

Pile―Central North 

Carolina 

Loblolly pine Chamber 10 0.615a Gullett et al. (2008)

Supplement―Central 

North Carolina 

Loblolly pine Chamber 2 0.93a Gullett et al. (2008)

Supplement―Western 

North Carolina 

White pine Chamber 2 1.225a Gullett et al. (2008)

Supplement―Oregon Hemlock/Pine Chamber 2 1.64a Gullett et al. (2008)

Shrub―California Titi, pine straw, 

gallberry

Chamber 2 8.36a Gullett et al. (2008)

Shrub―Florida Maritime chaparral Chamber 2 2.62a Gullett et al. (2008)

Central North Carolina White pine Chamber 4 25 (14−47) Gullett and Touati 

(2003)

Oregon Hemlock/Pine Chamber 3 15 (1−56) Gullett and Touati 

(2003)

Tree and leaves from Japan Unspecified Chamber 1 4.7 Ikeguchi and Tanaka 

(1999)

Wood, leaves, and grass 

from Sweden

Unspecified Hood over fire 

on plate

1 27 Gonczi et al. (2005)
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

6-42 DRAFT: DO NOT CITE OR QUOTE

Table 6-1. CDD/CDF emission factors (ng/kg) for forest fires (continued)

Biomass description 

and location Wood type Test device n

ng TEQDF/kg of biomass

Mean (Range) Reference

Litters, mosses, heathers, 

brackens, conifer needles, 

pine cones, shrubs, barks, 

and branches from France

Pine and oak Chamber 5 10 (1−26) Collet and Fiani 

(2006) 

Forest leaf litter from 

three locations in Australia

Eucalyptus, box, 

ironback 

Chamber 5 0.37 (0.09−0.79) Meyer et al. (2004)

Prescribed forest fires in 

Queensland, Victoria, and 

Western Australia

Eucalyptus Field 10 0.5 (0.07−1.4)a Meyer et al. (2004, 

2007) 

Tropical 

savanna―Australia

Unspecified Field 3 1.1 (0.2−2.8)a Meyer et al. (2004, 

2007)

Wildfires in Victoria Eucalyptus Field 2 0.7 (0.6−0.8)a Meyer et al. (2004, 

2007)

Woodlands in Australia Unspecified Field 3 1.5 (0.9−2.5)a Meyer et al. (2004, 

2007)

a

Originally reported as ng TEQ/kg of carbon and converted to ng TEQ/kg of biomass by multiplying by 0.5.
This document is a draft for review purposes only and does not constitute Agency policy.

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1 Table 6-2. Comparison of Forest Fire Data (million acres burned/year) 

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3 

4 

5 

Fire type and year CEQ, 1997 U.S. EPA, 2002d NIFC, 2009 

Wildfires―1987 5 2.45 

Wildfires―1995 7 1.84 

Wildfires―2000 8.36 7.39 

Prescribed Fires―1987 5.1 NA

Prescribed Fires―1995 5.1 NA

Prescribed Fires―2000 1.26 1.19 

NA= Not Available. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 

2 

3 

0 0.1 0.2 0.3

2,3,7,8-TCDD

1,2,3,7,8-PCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

1,2,3,4,6,7,8,9-OCDD

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HpCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

1,2,3,4,6,7,8,9-OCDF

Congener Ratio

Source: Pleil and Lorber (2007)

0 0.1 0.2 0.3

2,3,7,8-TCDD

1,2,3,7,8-PCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

1,2,3,4,6,7,8,9-OCDD

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HpCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

1,2,3,4,6,7,8,9-OCDF

Congener Ratio

0 0.1 0.2 0.3

2,3,7,8-TCDD

1,2,3,7,8-PCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

1,2,3,4,6,7,8,9-OCDD

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HpCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

1,2,3,4,6,7,8,9-OCDF

0 0.1 0.2 0.3

2,3,7,8-TCDD

1,2,3,7,8-PCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

1,2,3,4,6,7,8,9-OCDD

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HpCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

1,2,3,4,6,7,8,9-OCDF

Congener Ratio

Source: Pleil and Lorber (2007)

Figure 6-1. Congener profile for structure fires. 
This document is a draft for review purposes only and does not constitute Agency policy.

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6-45 DRAFT: DO NOT CITE OR QUOTE

Figure 6-2. Forest fire types in the United States. 
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1 7. METAL SMELTING AND REFINING SOURCES OF CDD/CDFS 

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This chapter addresses dioxin releases associated with primary and secondary metal 

processing. Primary processes involve the extraction of the base metal from mineral ores. 

Secondary processes extract the base metal from recycled or waste materials. 

7.1. PRIMARY NONFERROUS METAL SMELTING/REFINING

7.1.1. Primary Copper Smelting and Refining

Minor changes were made to the air-release estimates.

7.1.1.1. Air Releases

The emission factor was derived from testing at two facilities by Environmental Risk 

Sciences, Inc. (1995), who used stack testing results to calculate the annual TEQ emission to air 

to be less than 0.5 g I-TEQDF in 1995 for the seven facilities (out of a total of eight) belonging to 

the National Mining Association. Using the activity level presented below of 1.60 MMT for 

1995, the emission factor is calculated to be 0.31 ng I-TEQDF/kg of copper. This emission factor 

was applied to all three reference years.

In 1987, copper refineries produced 1.13 MMT of copper (USGS, 1997a). In 1995, 

eight primary copper smelters were in operation in the United States; one of which closed at the 

end of that year (Edelstein, 1995). Total refinery production was 1.60 MMT in 1995, including 

0.36 MMT from scrap material (Edelstein, 1995). In 2000, four primary smelters of copper were 

in operation in the United States, producing 1.61 MMT of copper (USGS, 2002a).

7.1.1.2. Water Releases

No information was found on water releases from these facilities.

7.1.1.3. Solid Residue Releases

 Although no measurement data were found, CDD/CDFs are likely to be present in the fly 

ash and possibly other solid residues at these facilities because they have been found in the air 
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1 emissions. These residues are disposed in landfills and, therefore, are not considered to be an 

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environmental release.

7.1.1.4. Products 

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.1.1.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Primary Copper Smelting and Refining

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
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Primary Copper Smelting and Refining

Air Releases

Emission Factors

• 1987—0.31 ng I-TEQDF/kg of copper. 

• 1995—0.31 ng I-TEQDF/kg of copper. 

• 2000—0.31 ng I-TEQDF/kg of copper.

Activity Levels

• 1987—1.13 MMT of copper. 

• 1995—1.60 MMT of copper. 

• 2000—1.61 MMT of copper.

Releases

• 1987—0.3 g I-TEQ. 

• 1995—0.5 g I-TEQ. 

• 2000—0.5 g I-TEQ.

Water Releases

None.

Solid Residue Releases

None.

Products

None.

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7.1.2. Primary Magnesium Smelting and Refining

7.1.2.1. Air Releases

No change was made to the emission factor, but minor changes were made to the activity 

estimates and resulting release estimates. The emission factor was derived from stack testing at a 

Utah facility (Western Environmental Services and Testing, Inc., 2000). This was originally 

reported as 105 ng I-TEQ/kg of magnesium produced and is converted here to 

94 ng WHO98 TEQ/kg of magnesium produced based on congener data presented in Western 

Environmental Services and Testing, Inc., 2000. Even though the testing occurred at only 

one facility, the estimated releases for the year 2000 are included in the quantitative inventory. 

This is because the Utah facility was the only one operating in the United States in 2000. 

Additional facilities were operating in 1987 and 1995 and it is uncertain how well the testing at 

the Utah facility represented the others. Therefore, the release estimates for 1987 and 1995 were 
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1 considered preliminary. The activity estimates were derived from production data from the 

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U.S. Geological Society (USGS, 2002).

Under the EPA TRI program for 2000, this facility reported air releases of 

623 g CDD/CDFs (3.3 g WHO98 TEQDF) and on-site surface impoundments of 

1,661 g CDD/CDFs (8.3 g WHO98 TEQDF) (U.S. EPA, 2008). No releases to other media were 

reported. As explained in Chapter 1, the accuracy of the TRI data is unknown, and, therefore, 

they are not used to make quantitative estimates in this document but rather as supportive 

evidence that releases do occur.

7.1.2.2. Water Releases

Monitoring of wastewater discharges from U.S. magnesium production facilities for 

CDD/CDF content has not been reported. Wastewater discharges of CDDs/CDFs reported for 

the Norwegian facility (Oehme et al., 1989) are not adequate to support development of 

wastewater emission factors for U.S. facilities because of possible differences in the processes 

used to manufacture MgCl2 and pollution control equipment. Therefore, water releases are 

possible but could not be quantified.

 

7.1.2.3. Solid Residue Releases

 CDD/CDFs have been reported in waste sludge generated during magnesium production. 

EPA (2008) reports that in the year 2001, Magnesium Corporation of America (Rowley, UT) 

released 2,289 g total CDD/CDF (10 g WHO98 TEQDF, or 12 g I-TEQDF) to on-site surface 

impoundments. The potential for environmental release is unknown (Not quantifiable). 

7.1.2.4. Release Summary

The inventory decision criteria and releases to all media are summarized below: 
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Inventory Decision Criteria for Primary Magnesium Smelting and Refining

Air Water Solids Products

Emission tests for at least two units/source types with No

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable 

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P/Qa

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a

Preliminary for 1987 and 1995, Quantitative for 2000 because testing occurred at only facility operating in 2000. 

Primary Magnesium Smelting and Refining

Air Releases

Emission Factors

• 1987—94 ng WHO98 TEQDF/kg (110 ng I-TEQDF/kg). (Preliminary)

• 1995—94 ng WHO98 TEQDF/kg (110 ng I-TEQDF/kg). (Preliminary)

• 2000—94 ng WHO98 TEQDF/kg (110 ng I-TEQDF/kg).

Activity Levels

• 1987—0.142 MMT. 

• 1995—0.142 MMT. 

• 2000—0.083 MMT.

Releases

• 1987—13 g WHO98 TEQDF (16 g I-TEQDF). (Preliminary)

• 1995—13 g WHO98 TEQDF (16 g I-TEQDF). (Preliminary)

• 2000—8 g WHO98 TEQDF (9 g I-TEQDF).

Water Releases

Releases are possible but could not be quantified.

Solid Residue Releases

Releases are possible but could not be quantified.

Products

None.
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7.1.3. Primary Nickel Smelting and Refining

No changes were made in the release estimates from these facilities.

7.1.3.1. Air Releases

The emissions information contained in the Norwegian study (Oehme et al., 1989) is not 

adequate to support development of emission factors for the U.S. facility for 1987 and 1995. 

Since the only U.S. facility closed in 1998, emissions for 2000 are zero.

7.1.3.2. Water Releases

EPA (2006) reports that one study (Oehme et al., 1989) measured CDD/CDFs in 

wastewater releases from a nickel production plant in Norway. The information is not adequate 

to support development of emission factors for the United States. Thus, releases are possible but 

could not be quantified in 1987 and 1995. Since the only U.S. facility closed in 1998, emissions 

for 2000 are zero.

7.1.3.3. Solid Residue Releases

 No information was found indicating that CDD/CDFs were present in solid residues from 

these facilities.

7.1.3.4. Products 

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.1.3.5. Release Summary

The release estimates are summarized below: 
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Primary Nickel Smelting and Refining

Air Releases

Releases are possible but could not be quantified in 1987 and 1995 and were zero in 2000.

Water Releases

Releases are possible but could not be quantified in 1987 and 1995 and were zero in 2000.

Solid Residue Releases

None.

Products

None.

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7.1.4. Primary Aluminum Smelting and Refining

No changes were made to the release estimates for these facilities, but additional 

background information is provided below. 

The use of hexachloroethane during aluminum production has been identified as a cause 

for dioxin emissions (UNEP, 2005). The production of hexachloroethane ceased in the 

United States in the 1970s, so it is not likely to have been used for this purpose during the 

reference years (ATSDR, 1997). UNEP (2005) did not determine emission factors for primary 

aluminum production. 

Kucherenko et al. (2001) measured CDD/CDFs emissions from a primary aluminum 

plant in Krasnoyarsk, Russia. The air release emission factor was estimated as 11 ng I-TEQ/kg, 

and the water release emission factor was estimated as 0.141 ng I-TEQ/L. It is unknown how 

similar this plant is to those in the United States.

In summary, insufficient information is available to estimate if CDD/CDF releases occur 

from these facilities in the United States.

7.1.5. Primary Titanium Smelting and Refining

No changes were made to the release estimates from these facilities, but additional 

background information is provided below. 

In the year 2000, nine facilities with an SIC code for inorganic pigments reported dioxin 

releases under EPA’s TRI program. The air and water releases summed across these facilities
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1 were less than 1 g WHO98 TEQDF. A total of 240 g WHO98 TEQDF were disposed in landfills 

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29 

(U.S. EPA, 2008). No releases to other media were reported. As explained in Chapter 1, the 

accuracy of the TRI data is unknown, and therefore, they are not used to make quantitative 

estimates in this document but rather as supportive evidence that releases do occur.

7.1.5.1. Air Releases

Based on the TRI data reported above, air releases are possible but could not be 

quantified. 

7.1.5.2. Water Releases

Based on the TRI data reported above, water releases are possible but could not be 

quantified. 

7.1.5.3. Solid Residue Releases

Titanium dioxide production creates a variety of sludge wastes, which can contain 

CDDs/CDFs. As discussed above, the TRI data suggest that inorganic pigment facilities 

disposed a total of 240 g WHO98 TEQDF in landfills in 2000 (U.S. EPA, 2008). 

 EPA (2001) reports the following measurements in wastes generated in conjunction with 

chlorinators: 

• Millennium Baltimore, chloride solids/waste acid: 812 ng WHO98 TEQDF/L. 

• Millennium Baltimore, filter press solids: 2,615 ng WHO98 TEQDF/kg.

• DuPont Edge Moor, iron rich: 58.7 ng WHO98 TEQDF/kg.

• DuPont New Johnsonville, wastewater treatment solids: 402 ng WHO98 TEQDF/kg.

EPA (2001) reports that the production of wastewater treatment sludges from comingled chloride 

and sulfate process wastewaters at the Millennium Plant was 93,121 MT/year. Combining this 

production rate with an assumed 1,000 ng WHO98 TEQDF/kg suggests that about 

90 g WHO98 TEQDF/year may be associated with these sludges at this plant. 
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1 For the most part, these sludges have been disposed of in either on-site or off-site RCRA 

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Subtitle D solid waste disposal facilities. However, given the potential for leaching of the heavy 

metals from the sludge in the Subtitle D landfill, EPA has listed this waste as hazardous waste 

under Subtitle C. These sludges are now considered a hazardous waste under RCRA and must 

be disposed of in permitted landfills (U.S. EPA, 2001). These amounts are not considered to 

cause environmental releases under the definition in this document. 

7.1.5.4. Products 

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.1.5.5. Release Summary

The release estimates are summarized below: 

Primary Titanium Smelting and Refining

Air Releases

Not quantifiable.

Water Releases

Not quantifiable.

Solid Residue Releases

None.

Products

None.

7.2. SECONDARY NONFERROUS METAL SMELTING AND REFINING

7.2.1. Secondary Aluminum Smelting and Refining

No changes were made in the release estimates from these facilities, but some additional 

background information is provided below. 
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1 7.2.1.1. Air Releases

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27 

The emission factors were derived from testing at seven facilities (CARB, 1992a, b; U.S. 

EPA, 1995c). Activity data were based on survey information from USGS (2002a).

In the year 2000, 29 facilities with an SIC code for secondary smelting and refining of 

nonferrous metals reported dioxin releases under the EPA TRI program (U.S. EPA, 2008). Most 

of these facilities appeared to be aluminum producers. The sum of the air releases across these 

facilities was 1,022 g, which EPA estimates is equal to 13.8 g WHO98 TEQDF. No releases to 

other media were reported. As explained in Chapter 1, the TRI data are not used to make 

quantitative estimates in this document but rather as supportive evidence that releases do occur.

7.2.1.2. Water Releases

 No information was found indicating that CDD/CDFs were present in water releases from 

these facilities.

7.2.1.3. Solid Residue Releases

Although no measurement data were found, CDD/CDFs are likely to be present in the fly 

ash and possibly other solid residues at these facilities because they have been found in the air 

emissions. These residues are disposed in landfills and, therefore, are not considered to be an 

environmental release.

7.2.1.4. Products 

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.2.1.5. Releases

The inventory decision criteria and releases to all media are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy. 

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Inventory Decision Criteria for Secondary Aluminum Smelting and Refining

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

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7 

Secondary Aluminum Smelting and Refining

Air Releases

Emission Factors

• 1987—15 ng WHO98 TEQDF/kg (14 ng I-TEQDF/kg). 

• 1995—15 ng WHO98 TEQDF/kg (14 ng I-TEQDF/kg). 

• 2000—5.2 ng WHO98 TEQDF/kg (4.9 ng I-TEQDF/kg).

Activity Levels

• 1987—0.7 MMT. 

• 1995—1.3 MMT. 

• 2000—1.6 MMT.

Releases

• 1987—11 g WHO98 TEQDF(10 g I-TEQDF). 

• 1995—20 g WHO98 TEQDF(18 g I-TEQDF). 

• 2000—8 g WHO98 TEQDF(8 g I-TEQDF).

Water Releases

None.

Solid Residue Releases

None.

Products

None.

7.2.2. Secondary Copper Smelting and Refining

No changes were made in the release estimates from these facilities.
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1 7.2.2.1. Air Releases

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23 

 Only three facilities were active during the reference years. The emission factors were 

derived from stack testing at these plants as described in US EPA (2006). The release summary 

below shows the emission factor and activity estimates (based on data for each plant) in each 

reference year.

7.2.2.2. Water Releases

 No information was found indicating that CDD/CDFs were present in water releases from 

these facilities.

7.2.2.3. Solid Residue Releases

Although no measurement data were found, CDD/CDFs are likely to be present in the fly 

ash and possibly other solid residues at these facilities because they have been found in the air 

emissions. These residues are disposed in landfills and, therefore, are not considered to be an 

environmental release.

7.2.2.4. Products 

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.2.2.5. Releases

The inventory decision criteria and releases to all media are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy. 

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Inventory Decision Criteria for Secondary Copper Smelting and Refining

Air Water Solids Products 

Emission tests for at least two units/source types with Yes 

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes 

differences. 

Emission factor tests represent units that are typical of the Yes 

class. 

Activity estimates based on source-specific surveys. Yes 

Conclusion (Q = Quantitative, P = Preliminary). Q 

1

2 
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Secondary Copper Smelting and Refining

Air Releases

Emission Factors

Franklin 

• 1987―17,000 ng WHO98 TEQDF/kg (17,000 ng I-TEQDF/kg). 

• 1995―17.000 ng WHO98 TEQDF/kg (17,000 ng I-TEQDF/kg). 

Chemetco

• 1987―3.7 ng WHO98 TEQDF/kg (3.6 ng I-TEQDF/kg). 

• 1995―3.7 ng WHO98 TEQDF/kg (3.6 ng I-TEQDF/kg). 

• 2000―3.7 ng WHO98 TEQDF/kg (3.66 ng I-TEQDF/kg). 

Gaston

• 1987―8,900 ng WHO98 TEQDF/kg (8,700 ng I-TEQDF/kg). 

Activity Levels 

Franklin 

• 1987―13,600,000 kg.

• 1995―16,000,000 kg.

Chemetco

• 1987―120,000,000 kg.

• 1995―135,000,000 kg.

• 2000―235,000,000 kg.

Gaston 

• 1987―85,000,000 kg. 

Releases

• 1987—990 g WHO98 TEQDF (970 g I-TEQDF). 

• 1995—270 g WHO98 TEQDF (270 g I-TEQDF). 

• 2000—0.9 g WHO98 TEQDF (0.8 g I-TEQDF). 

Water Releases

None. 

Solid Residue Releases

None. 

Products

None. 

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7.2.3. Secondary Lead Smelting

No changes were made in the release estimates from these facilities.
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7.2.3.1. Air Releases

 Three types of furnaces are used in secondary lead smelting. CDD/CDF emission factors 

were estimated for secondary lead smelters using the results of emission tests performed by EPA 

at three smelters (a blast furnace [U.S. EPA, 1995b], a colocated blast/reverberatory furnace 

[U.S. EPA, 1992a], and a rotary kiln furnace [U.S. EPA, 1995c]). Activity estimates were 

derived from USGS survey data. The release summary below shows the emission factor and 

activity for each furnace type in each reference year.

7.2.3.2. Water Releases

 No information was found indicating that CDD/CDFs were present in water releases from 

these facilities.

7.2.3.3. Solid Residue Releases

Although no measurement data were found, CDD/CDFs are likely to be present in the fly 

ash and possibly other solid residues at these facilities because they have been found in the air 

emissions. These residues are disposed in landfills and, therefore, are not considered to be an 

environmental release.

7.2.3.4. Products 

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.2.3.5. Releases

The inventory decision criteria and releases to all media are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy. 

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Inventory Decision Criteria for Secondary Lead Smelting

Air Water Solids Products 

Emission tests for at least two units/source types with Yes 

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes 

differences. 

Emission factor tests represent units that are typical of the Yes 

class. 

Activity estimates based on source-specific surveys. Yes 

Conclusion (Q = Quantitative, P = Preliminary). Q 

1 
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Secondary Lead Smelting

Air Releases

Emission Factors

Blast furnaces without scrubber 

• 1987, 1995, 2000― 8.8 ng WHO98 TEQDF/kg (8.3 ng I-TEQDF/kg). 

Blast furnaces with scrubber

• 1987, 1995, 2000―0.64 ng WHO98 TEQDF/kg (0.63 ng I-TEQDF/kg). 

Reverberatory and colocated furnaces without scrubber

• 1987, 1995, 2000―0.42 ng WHO98 TEQDF/kg (0.41 ng I-TEQDF/kg). 

Reverberatory and colocated furnaces with scrubber

• 1987, 1995, 2000―0.05 ng WHO98 TEQDF/kg (0.05 ng I-TEQDF/kg).). 

Rotary furnaces without scrubber

• 1987, 1995, 2000―0.66 ng WHO98 TEQDF/kg (0.66 ng I-TEQDF/kg). 

Rotary furnaces with scrubber

• 1987, 1995, 2000―0.24 ng WHO98 TEQDF/kg (0.24 ng I-TEQDF/kg). 

Activity Levels

Blast furnaces (14% with and 86% without scrubbers) 

• 1987―0.15 MMT.

• 1995―0.2 MMT.

• 2000―0.29 MMT.

Reverberatory and colocated furnaces (52% with and 48% without scrubbers) 

• 1987―0.53 MMT.

• 1995―0.72 MMT.

• 2000―1 MMT.

Rotary furnaces (57% with and 43% without scrubbers) 

• 1987―0.04 MMT.

• 1995―0.05 MMT.

• 2000―0.07 MMT.

Releases

• 1987—1 g WHO98 TEQDF (1 g I-TEQDF). 

• 1995— 2 g WHO98 TEQDF (2 g I-TEQDF). 

• 2000—2 g WHO98 TEQDF (2 g I-TEQDF).

Water Releases

None.

Solid Residue Releases

None.

Products

None.

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7.2.4. Secondary Zinc Production

This is a new section.

 More than one-fourth of the total zinc (Zn) consumed in 2002 by domestic industries was 

secondary Zn. About 87% of recycled zinc was derived from new scrap, generated mainly in 

galvanizing and die casting plants and brass mills. The remaining 13% was obtained from brass 

products, flue dust, old die casts, and old rolled Zn articles. Recycled Zn was used by 2 primary 

smelters and 13 large and medium (more than 1,000 tons/year) sized secondary smelters 

principally for production of zinc chemicals, mainly oxide, and Zn metal, including alloys

(USGS, 2002b).

Clean new scrap, mainly brass, rolled zinc clippings, and rejected die castings, usually 

requires only remelting. In the case of mixed nonferrous shredded metal scrap, zinc is separated 

from other materials by hand or magnetic separation. Most of the zinc recovered from dust 

produced during remelting of galvanized steel scrap, is recovered in rotary kilns by using the 

Waelz process (USGS, 2009a). 

7.2.4.1. Air Releases

 UNEP (2005) proposed several zinc related emission factors based on testing at facilities 

in Germany and Japan: 

• Kilns with no APCs—1,000 ng I-TEQ/kg of zinc

• Hot briquetting/rotary furnaces with basic dust controls—100 ng I-TEQ/kg of zinc

• Furnaces with comprehensive pollution controls—5 ng I-TEQ/kg of zinc

• Zinc melting—0.3 ng I-TEQ/kg of zinc 

 The European Dioxin Inventory (Quass et al., 2001) suggests an emission factor of 

50 ng I-TEQ/kg of zinc with a range of 5 to 500 ng I-TEQ/kg for secondary zinc production. 

The central value of 50 ng I-TEQ/kg of zinc was selected for all reference years.
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131,000 MT in 1995 and 135,000 MT in 2000 (USGS, 2009b). 

7.2.4.2. Water Releases

 No information was found indicating that CDD/CDFs were present in water releases from 

these facilities.

7.2.4.3. Solid Residue Releases

Although no measurement data were found, CDD/CDFs are likely to be present in the fly 

ash and possibly other solid residues at these facilities because they have been found in the air 

emissions. These residues are disposed in landfills and, therefore, are not considered to be an 

environmental release.

7.2.4.4. Products 

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.2.4.5. Releases

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Secondary Zinc Production

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
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Secondary Zinc Production

Air Releases

Emission Factor

• 1987—50 ng I-TEQ/kg of zinc. 

• 1995—50 ng I-TEQ/kg of zinc. 

• 2000—50 ng I-TEQ/kg of zinc.

Activity Levels

• 1987—82,500 MT. 

• 1995—131,000 MT. 

• 2000—135,000 MT.

Releases

• 1987—4 g I-TEQ. 

• 1995—7 g I-TEQ. 

• 2000—7 g I-TEQ.

Water Releases

None.

Solid Residue Releases

None.

Products

None.

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7.3. PRIMARY FERROUS METAL SMELTING/REFINING

7.3.1. Sinter Production

No changes were made to the release estimates except the air releases in 2000, which 

decreased slightly due to computational corrections. 

7.3.1.1. Air Releases

Two types of APCDs are used in sinter production: wet scrubbers and fabric filters. The 

emission factors for facilities with these two types of APCDs were derived from testing at 

two U.S. sintering plants operating in 1997 (Calcagni et al., 1998). Activity estimates were 

derived from several sources: Calcagni et al. (1998), AISI (1990), and Fenton (1996). The 

release summary below shows the emission factor and activity for each APCD type in each 

reference year.
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1 7.3.1.2. Water Releases

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No information was found indicating that CDD/CDFs were present in water releases from 

these facilities.

7.3.1.3. Solid Residue Releases

Although no measurement data were found, CDD/CDFs are likely to be present in the fly 

ash and possibly other solid residues at these facilities because they have been found in the air 

emissions. These residues are disposed in landfills and, therefore, are not considered to be an 

environmental release.

7.3.1.4. Products 

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.3.1.5. Releases

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Sinter Production

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q
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Sinter Production

Air Releases

Emission Factors

Wet scrubber

• 1987―0.62 ng WHO98 TEQDF/kg (0.55 ng I-TEQDF/kg) of sinter. 

• 1995―0.62 ng WHO98 TEQDF/kg (0.55 ng I-TEQDF/kg) of sinter.

• 2000―0.62 ng WHO98 TEQDF/kg (0.55 ng I-TEQDF/kg) sinter.

Fabric filter

• 1987―4.6 ng WHO98 TEQDF/kg (4.1 ng I-TEQDF/kg) of sinter.

• 1995―4.6 ng WHO98 TEQDF/kg (4.1 ng I-TEQDF/kg) of sinter.

• 2000―4.6 ng WHO98 TEQDF/kg (4.1 ng I-TEQDF/kg) of sinter. a Activity Levels

• 1987—14.5 MMT. 

• 1995—12.4 MMT. 

• 2000—10.6 MMT.

Releases

• 1987—33 g WHO98

• 1995—28 g WHO98

• 2000—24 g WHO98

TEQDF

TEQDF

TEQDF

(30 g I-TEQDF). 

(25 g I-TEQDF). 

(21 g I-TEQDF).

Water Releases

None.

Solid Residue Releases

None.

Products

None.

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a

Fifty-nine percent of sinter production was at facilities with wet scrubbers and 41% was at facilities with fabric 

filters. 

7.3.2. Coke Production

Minor changes were made to the air emission factor and resulting air-release estimates. 

The confidence rating was upgraded from preliminary to quantifiable for the air releases due to 

addition of facility tests used to estimate the emission factor.
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1 7.3.2.1. Air Releases

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US EPA (2006) used the emission factor of 0.23 ng I-TEQDF/kg of coal consumed 

estimated by Bremmer, et al. (1994). Another study measured dioxin emissions at four Canadian 

facilities (Charles E. Napier Company, Ltd., 2000). The present study averages the emission 

factor across the facilities tested in both studies to derive an emission factor of 

0.29 ng I-TEQDF/kg of coal consumed. This emission factor was applied to all three reference 

years. Coke production estimates were obtained from EIA (2002). The confidence rating was 

upgraded from preliminary to quantitative because the emission factor was derived from two 

studies involving 5 facilities.

In the year 2000, four facilities with an SIC code for steel works, blast furnaces 

(including coke ovens), and rolling mills reported dioxin releases under the EPA TRI program 

(U.S. EPA, 2008). The sum of the air releases across these facilities was 31.8 g, which EPA 

estimates is equal to 4.1 g WHO98 TEQDF. No releases to other media were reported. As 

explained in Chapter 1, the TRI data are not used to make quantitative estimates in this document 

but rather as supportive evidence that releases do occur.

7.3.2.2. Water Releases

Although water is used in quench towers to cool hot coke, it is recycled, and the 

evaporate is replenished. Therefore no water releases occur.

7.3.2.3. Solid Residue Releases

 Although no measurement data were found, CDD/CDFs are likely to be present in the fly 

ash and possibly other solid residues at these facilities because they have been found in the air 

emissions. These residues are disposed in landfills and, therefore, are not considered to be an 

environmental release.

7.3.2.4. Products 

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.
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1 7.3.2.5. Release Summary

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The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Coke Production

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

Coke Production

Air Releases

Emission Factors

• 1987—0.29 ng I-TEQDF/kg of coal. 

• 1995—0.29 ng I-TEQDF/kg of coal. 

• 2000—0.29 ng I-TEQDF/kg of coal.

Activity Levels

• 1987—33.5 MMT. 

• 1995—29.9 MMT. 

• 2000—26.2 MMT.

Releases

• 1987—10 g I-TEQDF.

• 1995—9 g I-TEQDF.

• 2000—8 g I-TEQDF.

Water Releases

None.

Solid Residue Releases

None.

Products

None.
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7.4. SECONDARY FERROUS METAL SMELTING/REFINING

No changes were made in the release estimates from these facilities.

7.4.1. Air Releases

No changes were made in the air-release estimates, but the confidence rating was 

upgraded from preliminary to quantifiable. This was based on the support for the emission factor 

from testing at 6 facilities in Germany and 13 facilities in Canada. The emission factor was 

derived by averaging the data reported in Umweltbundesamt (1996) and the three Environment 

Canada reports (Charles E. Napier Company, Ltd., 2000; Cianciarelli, 2000, 2001). Based on the 

congener data reported by Cianciarelli, 2000, the I-TEQs are approximately equivalent to the 

WHO98 TEQs. The activity estimates were derived from steel-production data from USGS 

(2002a). 

7.4.2. Water Releases

 No information was found indicating that CDD/CDFs were present in water releases from 

these facilities.

7.4.3. Solid Residue Releases

Although no measurement data were found, CDD/CDFs are likely to be present in the fly 

ash and possibly other solid residues at these facilities because they have been found in the air 

emissions. These residues are disposed in landfills and, therefore, are not considered an 

environmental release.

7.4.4. Products

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.4.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 
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Inventory Decision Criteria for Secondary Ferrous Metal Smelting/Refining

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

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Secondary Ferrous Metal Smelting/Refining

Air Releases

Emission Factors

• 1987—1.2 ng (WHO98 or I-TEQDF/kg) of steel. 

• 1995—1.2 ng (WHO98 or I-TEQDF/kg) of steel. 

• 2000—1.2 ng (WHO98 or I-TEQDF/kg) of steel.

Activity Levels

• 1987—30.8 MMT. 

• 1995—38.4 MMT. 

• 2000—49.0 MMT.

Releases

• 1987—37 g (WHO98 or I-TEQDF).

• 1995—46 g (WHO98 or I-TEQDF).

• 2000—59 g (WHO98 or I-TEQDF).

Water Releases

None.

Solid Residue Releases

None.

Products

None.
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1 7.5. FERROUS FOUNDRIES

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No changes were made to the release estimates for these facilities, but some additional 

background information is provided below. 

7.5.1. Air Releases

 The emission factor for the ferrous foundries was estimated by combining the mean 

emission factor derived from the data reported in Umweltbundesamt (1996), CARB (1993), and 

EPA (1997a), yielding a value of 1.23 ng I-TEQDF/kg of metal feed. This was converted to 

1.37 ng WHO98 TEQDF/kg based on the congener profile reported in EPA, 1997a. The emission 

data represent a total of 10 facilities and generated emission factors ranging over 4 orders of 

magnitude. Based on the inconsistency of these results for reasons that are not clear, the release 

estimates are considered preliminary. The activity estimates were derived from survey data from 

USGS (2001). 

In the year 2000, five facilities with an SIC code for gray and ductile iron foundries 

reported dioxin releases under the EPA TRI program (U.S. EPA, 2008). The sum of the air 

releases across these facilities was 117 g, which EPA estimates is equal to 21.5 g WHO98 TEQDF. 

No releases to other media were reported. As explained in Chapter 1, the TRI data are not used 

to make quantitative estimates in this document but rather as supportive evidence that releases do 

occur.

7.5.2. Water Releases

Liquid pollution makes up a small portion of the total waste stream from foundries 

(Freeman, 1995). Water is used in foundries to cool metal and other work pieces and in the wet 

scrubber air emission system. No information was found on CDD/CDF levels in these 

wastewaters.

7.5.3. Solid Residue Releases

Solid waste makes up a large portion of the pollution from foundries. One-quarter to 

one ton of solid waste per one ton of castings is expected (Shah, 1995). The waste comes from 
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 sand, slag, emissions control dust, and spent refractories. Molding and core sand make up 

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66−88% of the total waste from ferrous foundries (U.S. EPA, 1992b).

Slag waste is often very complex chemically and contains a variety of contaminants from 

the scrap metals. Common components include metal oxides, melted refractories, sand, and coke 

ash (if coke is used). Fluxes may also be added to help remove the slag from the furnace. Slag 

may be hazardous if it contains lead, cadmium, or chromium from steel or nonferrous metals 

melting. Iron foundry slag may be highly reactive if calcium carbide is used to desulfurize the 

iron. No information was found on CDD/CDF levels in these solid wastes. However, they are 

typically landfilled and thus not considered a release to environment. 

7.5.4. Products

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.5.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Ferrous Foundries

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable No

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P
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Ferrous Foundries

Air Releases

Emission Factors

• 1987—1.4 ng WHO98 TEQDF/kg (1.2 ng I-TEQDF/kg) of metal feed. (Preliminary)

• 1995—1.4 ng WHO98 TEQDF/kg (1.2 ng I-TEQDF/kg) of metal feed. (Preliminary)

• 2000—1.4 ng WHO98 TEQDF/kg (1.2 ng I-TEQDF/kg) of metal feed. (Preliminary)

Activity Levels

• 1987—9.19 MMT. 

• 1995—13.9 MMT. 

• 2000—11.3 MMT.

Releases

• 1987—13 g WHO98 TEQDF (11 g I-TEQDF). (Preliminary)

• 1995—19 g WHO98 TEQDF (17 g I-TEQDF). (Preliminary)

• 2000—16 g WHO98 TEQDF (14 g I-TEQDF). (Preliminary)

Water Releases

None.

Solid Residue Releases

None.

Products

None.

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7.6. NONFERROUS METAL FOUNDRIES

This is a new section.

7.6.1. Aluminum Foundries

No CDD/CDF emissions data were found for aluminum foundries. However, UNEP 

(2005) provides a range of emission factors for various types of aluminum processing. For the 

purposes of a preliminary estimate, a midrange value of 3.5 ng I-TEQ/kg was assumed to apply 

to all reference years. This corresponds to well-controlled facilities with fabric filters and lime 

injection.

The activity estimate for aluminum foundries in 2000 was found to be 95,600 MT based 

on the USGS Minerals Yearbook (USGS, 2000). The earlier years were estimated by assuming 
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1 that foundry production was a constant ratio with total consumption: 82,500 MT in 1995 and 

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72,000 MT in 1987. 

Foundries typically have solid waste associated with residues from the casting process. 

No information was found on CDD/CDF levels in these materials. However, these residues 

would be landfilled and, therefore, are not considered an environmental release. 

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Aluminum Foundries

Air Water Solids Products

Emission tests for at least two units/source types with No

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable 

differences. 

Emission factor tests represent units that are typical of the No

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P
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Aluminum Foundries

Air Releases

Emission Factors

• 1987—3.5 ng I-TEQDF/kg of metal feed (Preliminary). 

• 1995—3.5 ng I-TEQDF/kg of metal feed (Preliminary). 

• 2000—3.5 ng I-TEQDF/kg of metal feed (Preliminary).

Activity Levels

• 1987—72,000 MT. 

• 1995—82,500 MT. 

• 2000—95,600 MT.

Releases

• 1987—0.3 g I-TEQDF (Preliminary). 

• 1995—0.3 g I-TEQDF (Preliminary). 

• 2000—0.3 g I-TEQDF (Preliminary).

Water Releases

None.

Solid Residue Releases

None.

Products

None 

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7.6.2. Copper Foundries

UNEP (2005) provides an emission factor for copper casting operations of 

0.03 ng I-TEQ/kg of copper based on emissions testing at foundries in Germany. This was 

assumed to apply to all reference years. 

The activity estimate for copper foundries in 2000 was found to be 26,000 MT based on 

the USGS Minerals Yearbook (USGS, 2000). The earlier years were estimated by assuming that 

foundry production was a constant ratio with total consumption: 21,000 MT in 1995 and 

18,500 MT in 1987. 

Foundries typically have solid waste associated with residues from the casting process. 

No information was found on CDD/CDF levels in these materials. However, these residues 

would be landfilled and, therefore, are not considered to be an environmental release.

The inventory decision criteria and releases to all media are summarized below: 
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Inventory Decision Criteria for Aluminum Foundries

Air Water Solids Products

Emission tests for at least two units/source types with Yes

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable Yes

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

Copper Foundries

Air Releases

Emission Factors

• 1987—0.03 ng I-TEQDF/kg of metal feed. 

• 1995—0.03 ng I-TEQDF/kg of metal feed. 

• 2000—0.03 ng I-TEQDF/kg of metal feed.

Activity Levels

• 1987—72,000 MT. 

• 1995—82,500 MT. 

• 2000—95,600 MT.

Releases

• 1987—<0.1 g I-TEQDF.

• 1995—<0.1 g I-TEQDF.

• 2000—<0.1 g I-TEQDF.

Water Releases

None.

Solid Residue Releases

None.

Products

None.
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7.7. SCRAP ELECTRIC WIRE RECOVERY

No changes were made in the release estimates for these facilities. It is unknown how 

many facilities in the United States conducted scrap wire recovery operations over the reference 

years, so no activity estimates could be made, and therefore, no release estimates could be made 

as well.

7.7.1. Air Releases

 As reported in EPA (2006), CDDs/CDFs have been measured in the emissions from these 

facilities. The emission factor from EPA (1987) of 15.8 ng WHO98 TEQDF (16.9 ng I-TEQDF/kg) 

of scrap feed was applied to all reference years. This factor is considered preliminary because it 

is based on testing at only one facility. Lacking activity information on these facilities; however, 

no estimates of air releases can be made.

7.7.2. Water Releases

No information was found indicating that these facilities have water effluents. 

 

7.7.3. Solid Residue Releases

 Ash is produced as a byproduct when scrap wire is combusted. Harnly et al. (1995) 

analyzed soil/ash mixtures from three closed metal recovery facilities and from three closed sites 

using open burning for copper recovery near a California desert town. The geometric means of 

the total CDD/CDF concentrations at the facility sites and the open burning sites were 86,000 

and 48,500 ng/kg, respectively. The geometric mean TEQ concentrations were 2,900 and 

1,300 ng I-TEQDF/kg, respectively. A significantly higher geometric mean concentration 

(19,000 ng I-TEQDF/kg) was found in fly ash located at two of the facility sites. Lacking activity 

information on these facilities, no estimates of releases from solid residues can be made. The 

portion of the ash that is disposed in landfills would not be considered an environmental release.

7.7.4. Products
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7.7.5. Release Summary

The inventory decision criteria and releases to all media are summarized below. 
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Scrap Electric Wire Recovery

Air Releases

Releases are possible but cannot be quantified (Not quantifiable).

Water Releases

None.

Solid Residue Releases

Releases are possible but cannot be quantified (Not quantifiable).

Products

None.

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7.8. DRUM AND BARREL RECLAMATION FURNACES

 Changes were made to the activity estimates and resulting air-release estimates from 

these facilities.

7.8.1. Air Releases

The emission factor estimate (17.5 ng WHO98 TEQDF/drum) was based on testing at a 

reclamation facility equipped with an afterburner (U.S. EPA, 1987). The testing at this facility 

indicated that the afterburner achieved a 95% reduction in CDD/CDF emissions. It is possible 

that some of these facilities do not have afterburners and using this emission factor may 

underestimate their emissions by 20 times. Based on this uncertainty and data from only one 

facility, this emission factor is considered preliminary. EPA (2006) reports that 35 million 

drums were reclaimed in 1997 based on RIPA (1997), and this was assumed for the activity level 

in 2000. EPA (2006) assumed an activity level of 4.6 million drums in 1987 and 1995 based on 

a personal communication. These activity assumptions imply a large change in barrel 

reclamation activity over a short time period, which seems unlikely. Because the RIPA (1997) is 

a stronger reference, the activity assumptions for 1987 and 1995 were changed to 35 million 

barrels as well. However, survey data were lacking for all years and these activity estimates are 

considered preliminary. 

7.8.2. Water Releases
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7.8.3. Solid Residue Releases

 Sludges and ashes are stored in collection pits at these facilities. No information was 

found indicating that CDD/CDFs were present in solid residues from these facilities. However, 

it is reasonable to assume that CDD/CDFs are present in these ashes because they have been 

found in the ash from other types of combustion. Lacking measurement information, no 

estimates of releases from solid residues can be made (Not quantifiable). The portion of the 

solid waste that is disposed in landfills would not be considered an environmental release. 

7.8.4. Products

 No information was found indicating that CDD/CDFs were present in products from 

these facilities.

7.8.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Drum and Barrel Reclamation Furnaces

Air Water Solids Products

Emission tests for at least two units/source types with No

sufficient documentation to directly derive emission factors. 

Measured emission factors consistent or have understandable 

differences. 

Emission factor tests represent units that are typical of the Yes

class. 

Activity estimates based on source-specific surveys. No

Conclusion (Q = Quantitative, P = Preliminary). P

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Drum and Barrel Reclamation Furnaces

Air Releases

Emission Factors

• 1987—17.5 ng WHO98 TEQDF/drum (16.5 ng I-TEQDF/drum) (Preliminary). 

• 1995—17.5 ng WHO98 TEQDF/drum (16.5 ng I-TEQDF/drum) (Preliminary). 

• 2000—17.5 ng WHO98 TEQDF/drum (16.5 ng I-TEQDF/drum) (Preliminary).

Activity Levels

• 1987—35 million drums burned. 

• 1995—35 million drums burned. 

• 2000—35 million drums burned.

Releases

• 1987—0.6 g WHO98 TEQDF (0.6 g I-TEQDF) (Preliminary). 

• 1995—0.6 g WHO98 TEQDF (0.6 g I-TEQDF) (Preliminary). 

• 2000—0.6 g WHO98 TEQDF (0.6 g I-TEQDF) (Preliminary).

Water Releases

None.

Solid Residue Releases

Releases are possible but cannot be quantified.

Products

None.
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1 8. CHEMICAL MANUFACTURING AND PROCESSING SOURCES

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8.1. BLEACHED CHEMICAL WOOD PULP AND PAPER MILLS

No changes were made to the release estimates for these facilities; however, some 

additional discussion is provided below to clarify how the estimates were derived. 

8.1.1. Air Releases

Air releases from incineration of sludges are covered in Section 3.7.

8.1.2. Water Releases

For 1987 and 1995, an emission-factor approach was not needed because release 

estimates were available for virtually all facilities. These data came from six industry-wide 

surveys as described in EPA (2006). 

An emission-factor approach was used to estimate releases in 2000 because a 

comprehensive plant survey was not done for this year. The emission factor and activity 

estimates were provided by NCASI (Gillespie, 2002) based on data from multiple facilities. 

8.1.3. Solid Residue Releases

As described in EPA (2006), the amounts of CDD/CDFs in solid residues came from the 

comprehensive industry surveys in 1987 and 1995. In 1990, the majority (75.5%) of the 

wastewater sludge generated by these facilities was placed in landfills or in surface 

impoundments, with the remainder incinerated (20.5%), applied to land or used as compost 

(4.1%), or distributed as a commercial product (less than 1%) (U.S. EPA, 1993b). Data on the 

disposition of wastewater sludges are available only for years 1988 through 1995. On the basis 

of these data, the best estimate of the amount applied to land (i.e., not incinerated or landfilled) is 

14.1 g WHO98 or I-TEQ (4.1% of 343 g) for 1987 and 2 g 1 g WHO98 or I-TEQ (4.1% of 50 g) 

for 1995. 

For 2000, the primary waste treatment residuals from pulp mills 

(0.974 million dry MT/year) and the combined, secondary, and dredged waste treatment 

residuals from pulp mills (1.37 million dry MT/year) were derived from the NCASI database 

(Gillespie, 2002) on multiple facilities. This yields a total sludge production of 
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1 2.34 million dry MT. Fifty-one percent of the sludge generated in 2000 was sent to landfills or 

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lagoons (Gillepsie, 2002). It is uncertain how much of the remaining 49% of the sludge was 

applied to land. However, a conservative estimate can be developed by applying the 4.1% used 

to develop the 1987 and 1995 estimates. This implies that 1.19 MMT was landfilled and 

0.096 MMT were land applied. 

The CDD/CDFs in sludges that are land applied are assumed to represent environmental 

releases. These amounts are shown in the release summary below. The CDD/CDFs in sludges 

that are landfilled are not considered to be environmental releases, and these amounts are listed 

below: 

• 1987—260 g WHO98 or I-TEQ/year 

• 1995—38 g WHO98 or I-TEQ/year 

• 2000—2 g WHO98 or I-TEQ/year 

8.1.4. Products

The surveys discussed above provide information on the amounts of CDD/CDFs found in 

wood pulp: 500 g WHO98 or I-TEQ in 1987, 40 g WHO98 or I-TEQ in 1995, and 0.6 g WHO98 or 

I-TEQ in 2000. It is unknown if environmental releases occur from paper products made from 

the pulp. The CDD/CDFs in wood pulp products can be considered to be a reservoir as 

discussed further in Chapter 11. 

8.1.5. Release Summary

The inventory decision criteria and releases to all media are summarized below: 
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Inventory Decision Criteria for Bleached Chemical Wood Pulp and Paper Mills

Air Water Solids Products

Emission tests for at least two units/source types with Yes Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes Yes

understandable differences. 

Emission factor tests represent units that are typical of the Yes Yes

class. 

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q Q

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Bleached Chemical Wood Pulp and Paper Mills

Air Releases

Air releases from incineration of sludges are covered in Section 3.7.

Water Releases

Emission Factor

• 2000—0.49 pg (WHO98 or I-TEQ/L) of wastewater.

Activity Level

• 2000—2.87 trillion L.

Releases 

• 1987—360 g (WHO98 or I-TEQ). 

• 1995—28 g (WHO98 or I-TEQ). 

• 2000—1 g (WHO98 or I-TEQ).

Solid Residue Releases

Emission Factor

• 2000—1.8 ng (WHO98 or I-TEQ/kg) of sludge.

Activity Level

Land Applied 

• 2000—0.096 million dry MT.

Releases

Land Applied 

• 1987—14 g (WHO98 or I-TEQ). 

• 1995—2 g (WHO98 or I-TEQ). 

• 2000—0.2 g (WHO98 or I-TEQ).

Products

Releases

• 1987—Not quantifiable. 

• 1995—Not quantifiable. 

• 2000—Not quantifiable.

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8.2. STAND-ALONE CHLOR-ALKALI PLANTS

In the original report, Section 8.2 covered the manufacture of chlorine, chlorine 

derivatives, and metal chlorides, and Section 8.3 covered the manufacture of halogenated organic 

chemicals. These two sections have been reorganized into the following three sections: 

8.2—Stand-Alone Chlor-Alkali Plants
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1 8.3—Stand-Alone Vinyl Chloride Manufacturing Plants 

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8.4—Complex Chemical Plants Producing Chlorine and a Variety of Chlorinated Organics 

Because the changes to these sections are extensive, they are presented here in their entirety. 

Although the reorganization is extensive, only minor changes were made to the release estimates.

This section covers plants that produce only chlorine, sodium hydroxide (NaOH), and 

related caustic chemicals (also known as chlor-alkali plants). These chemicals are also produced 

at complex plants that produce a variety of chlorinated organic compounds. The CDD/CDF 

releases associated with chlor-alkali production at these complex plants are covered in 

Section 8.4. 

8.2.1. Process Description

Chlorine gas is produced by electrolysis of brine in electrolytic cells. Three processes are 

in use: the diaphragm-cell process, the membrane-cell process, and the mercury-cell process. In 

the diaphragm-cell process, a porous diaphragm divides the electrolytic cell, which contains 

brine, into an anode compartment and a cathode compartment. When an electric current passes 

through the brine, the chlorine ions and sodium ions from the salt move to the electrodes. 

Chlorine gas is produced at the anode, and sodium ions at the cathode react with the water, 

forming caustic soda. In the membrane-cell process, the compartments are separated by a 

membrane rather than a diaphragm. Brine is pumped into the anode compartment, and only 

sodium ions pass into the cathode compartment, which contains pure water. Thus, the caustic 

soda produced has very little salt contamination. In the mercury-cell process, mercury, which 

flows along the bottom of the electrolytic cell, serves as the cathode. When an electric current 

passes through the brine, chlorine is produced at the anode, and sodium dissolves in the mercury, 

forming an amalgam of sodium and mercury (Chorine Institute, 2010).

Until the late 1970s, the primary type of electrolytic process used in the chlor-alkali 

industry to produce chlorine consisted of the use of mercury cells containing graphite electrodes. 

During the 1980s, titanium metal anodes were developed to replace graphite electrodes 

(U.S. EPA, 1982; Curlin and Bommaraju, 1991). Currently, no U.S. facility is believed to use 

graphite electrodes in the production of chlorine gas (telephone conversation between L. Phillips, 

Versar, Inc., and T. Fielding, U.S. EPA, Office of Water, February 1993). 
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1 8.2.2. Regulations 

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Although EPA does not regulate CDDs/CDFs specifically, it issued restrictions under 

RCRA on the land disposal of wastewater and sludges generated by chlorine manufacturers that 

use the mercury-cell process and the diaphragm-cell process (with graphite electrodes) (waste 

codes K071, K073, and K106) (40 CFR 268). 

8.2.3. Literature

As shown in Table 8-1, high levels of CDFs have been found in several samples of 

graphite electrode sludge from facilities in Europe. The CDFs predominate in these sludges, and 

the 2,3,7,8-substituted congeners account for a large fraction of the respective congener totals 

(Rappe et al., 1990, 1991; Rappe, 1993; Strandell et al., 1994). Although the origin of the CDFs 

in graphite electrode sludge is uncertain, chlorination of the cyclic aromatic hydrocarbons (such 

as dibenzofuran) present in the coal tar used as a binding agent in the graphite electrodes has 

been proposed as the primary source (Strandell et al., 1994). For this reason, sludges produced 

using metal electrodes were not expected to contain CDFs. However, results of an analysis of 

metal electrode sludge from a facility in Sweden, analyzed as part of the Swedish Dioxin Survey, 

showed that the sludge contained high levels of CDFs (similar to those of the graphite sludge) 

and primarily nondetectable levels of CDDs (Strandell et al., 1994). The sludge showed the 

same type of CDF congener pattern reported by Rappe et al. (1991) and Rappe (1993). Strandell 

et al. suggested that chlorination of polyaromatic hydrocarbons present in the rubber linings of 

the electrolytic cell may have produced the CDFs found in the one sample analyzed. 

The Chlorine Chemistry Council (CCC), a trade association representing manufacturers 

that produce and/or use chlorine, sampled a variety of waste streams at seven stand-alone 

chlor-alkali facilities in the United States (CCC, 2004). Note that one of these plants (Occidental 

in Deer Park, TX) also produced vinyl chloride monomer (VCM), but the processes and 

associated waste streams are adequately separated such that it can be treated as a stand-alone 

facility. This information is also summarized in Dyke and Amendola (2007). This study 

measured CDD/CDF releases to water from all seven facilities as summarized in Table 8-2. Air 

releases were only detected at one facility (see Table 8-3). Dyke and Amendola (2007) 

summarized the amount of CDD/CDF in all waste streams and provided a confidence rating for 
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1 each value (see Table 8-4). Table 8-4 shows the amount of CDD/CDFs that are sent to off-site 

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incinerators, landfills, and deep-well injection facilities. The releases from incineration are 

included in the estimates presented for hazardous waste incinerators (see Section 3.2). The 

amounts sent to secure landfills and deep-well injection facilities are not considered to be 

environmental releases.

Dyke and Amendola (2007) present release estimates for both the years 2000 and 2002. 

The 2002 values are not reproduced here but are generally lower or similar to the 2000 values. 

In the year 2000, five facilities with an SIC code for alkalies and chlorine reported dioxin 

releases under the EPA TRI program (U.S. EPA, 2008). The sum of the air releases across these 

facilities was 204 g, which EPA estimates is equal to 3.3 g WHO98 TEQDF. The sum of the 

water releases across these facilities was 1,416 g, which EPA estimates is equal to 

24.8 g WHO98 TEQDF. No releases to other media were reported. As explained in Chapter 1, the 

TRI data are not used to make quantitative estimates in this document but rather as supportive 

evidence that releases do occur.

8.2.4. Releases

The information presented in Dyke and Amendola (2007) was selected as the best basis 

for estimating CDD/CDF releases from these facilities. The seven stand-alone chlor-alkali plants

covered in this study are believed to represent most of the stand-alone chlor-alkali production in 

the United States. Therefore, it was unnecessary to develop emission factors to estimate releases 

from untested facilities. The Dyke and Amendola release estimates are specific to the year 2000. 

No release data were found for earlier years. Because the chemical production rates and 

technologies used at these facilities were probably similar in 1995 and 2000, the 2000 results are 

assumed to apply to 1995. However, significant changes may have occurred since 1987, so no 

release estimates could be made for 1987. The releases to all media are presented in Table 8-4 

and summarized below. 

The solid residues from these plants are disposed in secure landfills or by deep-well 

injection and, therefore, are not considered an environmental release. The amounts are 

summarized below: 

• 1987—Not Available 
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The inventory decision criteria and releases to all media are summarized below:

Inventory Decision Criteria for Stand-Alone Chlor-Alkali Plants

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission 

factors. 

Yes Yes `

Measured emission factors consistent or have 

understandable differences. 

Yes Yes

Emission factor tests represent units that are typical of the 

class. 

Yes Yes

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q Q

Stand-Alone Chlor-Alkali Plants

Air Releases

• 1987—Not available.

• 1995—0.03 g I-TEQ. 

• 2000—0.03 g I-TEQ.

Water Releases

• 1987—Not available.

• 1995—2 g I-TEQ. 

• 2000—2 g I-TEQ.

Solid Residue Releases

None. The solid residues from these plants are disposed in secure landfills or by deep-well 

injection and, therefore, are not considered an environmental release.

Products

No information was found suggesting that CDD/CDFs are found in the products from these 

facilities.

8.3. STAND-ALONE VINYL CHLORIDE MANUFACTURING PLANTS
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1 As explained at the beginning of Section 8.2, this is a new section based on the 

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reorganization of Sections 8.2 and 8.3 in the original report. This section covers plants that 

produce only polyvinyl chloride (PVC) and PVC intermediates such as ethylene dichloride 

(EDC) and VCM. These chemicals are also produced at complex plants that produce a variety of 

chlorinated organic compounds. The CDD/CDF releases associated with vinyl chloride 

production at these complex plants are covered in Section 8.4. 

8.3.1. Process

PVC resins are produced from the polymerization of VCM. VCM is typically produced 

by the thermal dehydrochlorination (commonly known as cracking) of EDC. The cracking of 

EDC requires elevated pressure (20 to 30 atm) and temperature (450 to 650ΕC) and yields VCM 

and HCl at about a 1:1 molar ratio. EDC is produced by two different methods: (1) direct 

chlorination of ethylene with chlorine in the presence of a catalyst at a temperature of 50 to 

60ΕC and pressure of 4 to 5 atm; and (2) oxychlorination, which involves reaction of ethylene 

with HCl and oxygen in the presence of a catalyst at temperatures generally less than 325ΕC. 

The primary source of HCl for the oxychlorination process is the HCl produced from the 

cracking of EDC to form VCM. Most VCM manufacturing facilities are integrated with EDC 

production facilities (The Vinyl Institute, 1998). 

8.3.2. Regulations 

Although EPA regulates emissions from EDC/VCM production facilities under the Clean 

Water Act (40 CFR 61), the Clean Air Act (40 CFR 414), and RCRA (40 CFR 268, waste codes 

F024, K019, and K020), CDDs/CDFs are not specifically regulated pollutants. 

8.3.3. Literature

Although it has been generally recognized that CDDs/CDFs can be formed during the 

manufacture of EDC, VCM, and PVC, manufacturers and environmental public interest groups 

have disagreed as to the quantity of CDDs/CDFs that are formed and released to the environment 

in wastes and possibly in PVC products. Greenpeace International initially determined that 

CDDs and CDFs can be formed during the manufacture of PVC. In 1993, it issued a report on 

CDD/CDF emissions associated with the production of EDC/VCM (Greenpeace, 1993). 
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1 Greenpeace estimated that 5 to 10 g I-TEQDF were released to the environment (air, water, and 

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ground combined) annually for every 100,000 MT of VCM produced. This emission factor was 

based on data gathered by Greenpeace on four European plants. The Vinyl Institute responded 

with a critique of the Greenpeace report (ChemRisk, 1993). Miller (1993) summarized the 

differing views of the two parties. According to Miller, European PVC manufacturers claimed 

the emission factor was 0.01 to 0.5 g I-TEQDF/100,000 MT of VCM, and although Greenpeace 

and ChemRisk used basically the same monitoring information to develop their emission factors, 

Greenpeace adjusted the emission factor to account for unquantified fugitive emissions and 

waste products that contain unspecified amounts of CDDs/CDFs. 

In 1995, Greenpeace issued a second report (Stringer et al., 1995) reiterating the 

organization’s concern that the generation and the emission of CDDs/CDFs may be significant 

and urging that further work be initiated to quantify and prevent emissions. Stringer et al. (1995) 

presented the results of analyses of three samples of chlorinated wastes obtained from 

U.S. EDC/VCM manufacturing facilities. The three samples were characterized according to 

EPA hazardous waste classification numbers as an F024 waste (waste from the production of 

short-chain aliphatics by free radical-catalyzed processes), a K019 waste (heavy ends from the 

distillation of ethylene from EDC production), and a probable K020 waste (heavy ends from 

distillation of vinyl chloride in VCM manufacturing). Table 8-5 presents the analytical results 

reported by Stringer et al. (1995). This study acknowledged that because EDC/VCM production 

technologies and waste treatment and disposal practices are very site-specific, the limited 

information available on CDD/CDF generation and emissions made it difficult to quantify 

amounts of CDDs/CDFs generated and emitted.

In response to the lack of definitive studies, and at the recommendation of the EPA, 

U.S. PVC manufacturers began an extensive monitoring program—the Dioxin Characterization 

Program (DCP). The objective of the DCP was to evaluate the extent and magnitude of potential 

CDD/CDF releases to air, water, and land, as well as the potential for PVC product 

contamination. Manufacturers performed emissions and product testing at several facilities that 

were representative of various manufacturing and process control technologies. In 1998, The 

Vinyl Institute completed studies of CDD/CDF releases in wastewater, wastewater treatment 

plant solids, and stack gases, as well as studies of the CDD/CDF content of products (PVC resins 

and EDC sold as products) (The Vinyl Institute, 1998). This study presented results for 
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1 22 samples from 14 of the 24 U.S. and Canadian facilities manufacturing suspension and mass 

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PVC resins (13 pipe resins, 3 bottle resins, and 6 packaging resins). The results for U.S. 

manufacturers are summarized in Table 8-6. The 14 sampled sites represented approximately 

74% of estimated 1995 U.S. and Canadian suspension and mass PVC resin production. 

CDDs/CDFs were detected in only one sample (0.043 ng I-TEQDF/kg, assuming nondetects 

equal to zero). The overall mean TEQ concentrations were 0.002 ng I-TEQDF/kg (assuming 

nondetects equal to zero) and 0.7 ng I-TEQDF/kg (assuming nondetects equal to one-half the 

DL). The DLs were 2 ng/kg or less for all congeners in all samples except for OCDD and 

OCDF, which had DLs of 6 ng/kg or less.

The same study also presented results for six samples from four of the seven U.S. 

facilities manufacturing dispersion PVC resins. CDDs/CDFs were detected in five of the 

samples. The results are summarized in Table 8-6. In terms of production, the four sampled 

sites represent approximately 61% of estimated 1995 U.S. dispersion PVC resin production. The 

results ranged from not detected to 0.008 ng I-TEQDF/kg (overall mean = 0.001 ng I-TEQDF/kg, 

assuming nondetects equal to zero, and 0.4 ng I-TEQDF/kg, assuming nondetects equal to 

one-half the DL). The DLs were 2 ng/kg or less for all congeners in all samples except for 

OCDD and OCDF, which had DLs of 4 ng/kg or less.

Results were also presented for five samples from 5 of the 15 U.S. facilities 

manufacturing EDC. The results are summarized in Table 8-6. In terms of production, the 

five sampled sites represented approximately 71% of the estimated EDC produced in the United 

States in 1995. CDDs/CDFs were detected in only one sample (0.03 ng I-TEQDF/kg). The 

overall mean TEQ concentrations were 0.006 ng I-TEQDF/kg (nondetects equal to zero) and 

0.21 ng I-TEQDF/kg (nondetects equal to one-half the DL). The DLs for all congeners were 

1 ng/kg or less.

EPA (2006) used concentration and production data to estimate that vinyl chloride 

contained 0.02 g I-TEQ in 1995 and 0.02 g I-TEQ in 2000. It is unknown if releases occurred 

from these products. 

The Chlorine Chemistry Council (CCC), a trade association representing manufacturers 

that produce and/or use chlorine, also sponsored studies to measure CDD/CDF releases from the 

production of chlorine and chlorinated organics. The information from The Vinyl Institute and 

CCC studies was summarized in a recent article by Dyke and Amendola (2007). This article 
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1 identifies two facilities as stand-alone vinyl chloride plants. Dyke and Amendola (2007) 

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summarized the releases of CDD/CDF to all media for the year 2000 and provided a confidence 

rating for each value analogous to one used in this report (see Table 8-7). Dyke and Amendola 

(2007) presented release estimates for both the years 2000 and 2002. The 2002 values are not 

reproduced here but are generally lower or similar to the 2000 values. 

8.3.4. Releases

The information presented in Dyke and Amendola (2007) was selected as the best basis 

for estimating CDD/CDF releases from these facilities. The two stand-alone vinyl chloride 

plants covered in this study are believed to represent most of the stand-alone vinyl chloride 

production in the United States. Therefore, it was not necessary to develop emission factors to 

estimate releases from untested facilities. The Dyke and Amendola (2007) release estimates are 

specific to the year 2000. Since the chemical production rates and technologies used at these 

facilities have changed significantly since 1987, release estimates cannot be made for 1987 and 

1995. 

Table 8-7 shows the amount of CDD/CDFs that are sent to off-site incinerators and 

landfills. The releases from incineration are included in the estimates presented for hazardous 

waste incinerators (see Section 3.2). The amount sent to secure landfills (5.57 g I-TEQ in 2000) 

is not considered to be an environmental release. 

As discussed above, several studies have detected CDD/CDFs in PVC products. 

However, no information is available on possible releases from these products, and therefore, 

they are a potential but unquantifiable source (Not quantifiable).

The releases to all media from the stand-alone vinyl chloride plants are presented in 

Table 8-7. 

The inventory decision criteria and releases to all media are summarized below:
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Inventory Decision Criteria for Stand-Alone Vinyl Chloride Manufacturing Plants

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission 

factors. 

Yes Yes

Measured emission factors consistent or have 

understandable differences. 

Yes Yes

Emission factor tests represent units that are typical of the 

class. 

Yes Yes

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q Q

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Stand-Alone Vinyl Chloride Manufacturing Plants

Air Releases

• 1987—Not available.

• 1995—Not available. 

• 2000—0.62 g I-TEQ.

Water Releases

• 1987—Not available.

• 1995—Not available. 

• 2000—<0.1 g I-TEQ.

Solid Residue Releases

None. The solid residues from these plants are disposed in secure landfills and, therefore, are 

not considered to be an environmental release.

Products

Not quantifiable.

8.4. COMPLEX CHEMICAL PLANTS PRODUCING CHLORINE AND A VARIETY 

OF CHLORINATED ORGANICS

As explained at the beginning of Section 8.2, this is a new section based on the 

reorganization of Sections 8.2 and 8.3 in the original report. This section describes CDD/CDF 

releases from facilities that produce combinations of chlorine and multiple chlorinated organic 

chemicals. The plants that exclusively manufacture chlorine are covered in Section 8.2, and the 

plants that exclusively produce vinyl chloride are covered in Section 8.3. 
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1 The waste streams at these complex plants are typically combined, which prevents 

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derivation of chemical-specific release estimates. Instead, a facility-specific approach has been 

used where the releases for each plant are estimated on the basis of the CDD/CDF levels and 

total flow rates measured at the final release point.

These plants currently—or have in the past—produced a variety of chemicals that have 

been associated with CDD/CDF releases. These include chlorine, vinyl chloride, chlorophenols, 

chlorobenzenes, and chlorobiphenyls. Background information on the regulations, processes, 

and products related to chlorine and vinyl chloride products were presented in Sections 8.2 and 

8.3, respectively. Therefore, they are not repeated in this section. The production and use of 

chlorophenols, chlorophenoxy herbicides, and PCB products are now banned or strictly regulated 

in most countries. PCB production ceased prior to the first reference year, i.e., 1987. So 

CDD/CDF releases associated with PCB production are not covered in this report (PCB releases 

from nonproduction contemporary sources are covered in Chapter 10, and releases from 

reservoirs are covered in Chapter 11). 

Section 8.4 first presents separate discussions on chlorophenol and chlorobenzenes. 

These discussions describe the manufacturing processes, regulations, and products for these 

chemical groups. Then the section presents the release estimates occurring during production 

activities at the complex plants. 

8.4.1. Chlorophenols

8.4.1.1. Process Description

The two major commercial methods used to produce chlorophenols are (1) electrophilic 

chlorination of molten phenol by chlorine gas in the presence of catalytic amounts of a metal 

chloride and organic chlorination promoters and stabilizers, and (2) alkaline hydrolysis of 

chlorobenzenes under heat and pressure using aqueous methanolic sodium hydroxide. Other 

manufacturing methods include conversion of diazonium salts of various chlorinated anilines and 

chlorination of phenolsulfonic acids and benzenesulfonic acids, followed by the removal of the 

sulfonic acid group (Gilman et al., 1988; Hutzinger and Fiedler, 1991b). 
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1 8.4.1.2. Regulations for Chlorophenols 

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In 1983, EPA cancelled the sale of Silvex and 2,4,5-T for all uses (Federal Register, 

1987a). Earlier, in 1979, EPA had ordered emergency suspension of the forestry, rights-of-way, 

and pasture uses of 2,4,5-T. Emergency suspensions of the forestry, rights-of-way, pasture, 

home and garden, commercial/ornamental turf, and aquatic weed control/ditch bank uses of 

Silvex were also ordered (Federal Register, 1979; Plimmer, 1980). The home and garden, 

commercial/ornamental turf, and aquatic weed control/ditch bank uses of 2,4,5-T had been 

suspended in 1970. 

Pentachlorophenol (PCP) was one of the most widely used biocides in the United States 

prior to the regulatory actions to cancel and restrict certain of its wood and nonwood preservative 

uses. PCP was registered for use as a herbicide, defoliant, mossicide, and mushroom house 

biocide. It also found use as a biocide in pulp-paper mills, oil wells, and cooling towers. These 

latter three uses were terminated on or before 1993 (U.S. EPA, 1993b). However, the major use 

(greater than 80% of consumption) of PCP was and continues to be wood preservation. An 

overview of the history of the PCP pesticide rules is presented below. 

In 1984, EPA issued a notice of intent to cancel registrations of pesticide products 

containing PCP (including its salts) for all wood preservative uses (Federal Register, 1984). This 

notice specified modifications to the terms and conditions of product registrations that were 

required in order to avoid cancellation of the products. In response to this notice, several trade 

associations and registrants requested administrative hearings to challenge EPA’s 

determinations. After considering the comments and alternatives suggested during the 

prehearing stage of the administrative proceedings, EPA concluded that certain changes to the 

1984 notice were appropriate. These changes, finalized in 1986 (Federal Register, 1986), 

included the following: (a) all wood preservative uses of PCP and its salts were classified as 

“restricted use” only by certified applicators, (b) specific worker protection measures were 

required, (c) limits were placed on the HxCDD content of PCP, and (d) label restrictions for 

home and farm uses of PCP prohibited its application indoors and to wood intended for interior 

use (with a few exceptions) as well as its application in a manner that might result in direct 

exposure of domestic animals or livestock or in the contamination of food, feed, or drinking and 

irrigation water.
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1 EPA subsequently amended its notice on the wood preservative uses to establish reliable 

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and enforceable methods for implementing certified limits for HxCDD and 2,3,7,8-TCDD in 

registered wood preservative pesticide products (Federal Register, 1987b). Levels of 

2,3,7,8-TCDD were not allowed to exceed 1 ppb in any product, and after February 2, 1989, any 

manufacturing-use PCP released for shipment could not contain HxCDD levels that exceeded an 

average of 2 ppm over a monthly release or a batch level of 4 ppm (a gradually phased-in 

requirement). On January 21, 1987, EPA prohibited the registration of PCP and its salts for most 

nonwood uses (Federal Register, 1987c). EPA deferred action on several uses (uses in 

pulp/paper mills, oil wells, and cooling towers) pending receipt of additional exposure, use, and 

ecological effects data. On January 8, 1993, EPA issued a press advisory stating that its special 

review of these deferred nonwood uses was being terminated because all of these uses had been 

either voluntarily cancelled by the registrants or cancelled by EPA for failure of the registrants to 

pay the required annual maintenance fees (U.S. EPA, 1993b).

Di- and trichlorophenol manufacturers are subject to reporting under the Dioxin/Furan 

Test Rule, which is discussed in Section 8.3.7 of the original report. Since the effective date of 

that rule (June 5, 1987), only the 2,4-dichlorophenol isomer has been commercially produced in 

(or imported to) the United States, and as noted in Table 8-8, no CDDs/CDFs were detected in 

the product. Testing is required for the other di- and trichlorophenols if manufacture or 

importation resumes. Similarly, tetrachlorophenols were subject to reporting under the 

Dioxin/Furan Pesticide Data Call-In (discussed in Section 8.3.8 of the original report). Since 

issuance of the Data Call-in, the registrants of tetrachlorophenol-containing pesticide products 

have elected to no longer support the registration of their products in the United States. 

In the mid-1980s, the EPA Office of Solid Waste (OSW) promulgated, under RCRA, 

land disposal restrictions on wastes (wastewaters and nonwastewaters) resulting from the 

manufacture of chlorophenols (40 CFR 268). Table 8-9 lists all wastes in which CDDs/CDFs are 

specifically regulated by EPA as hazardous constituents, including chlorophenol wastes (waste 

codes F020 and F021). The regulations prohibit the land disposal of these wastes until they are 

treated to a level below the routinely achievable DLs for the EPA hazardous waste numbers 

listed in Table 8-9 for each of the following congener groups: TCDDs, PeCDDs, HxCDDs, 

TCDFs, PeCDFs, and HxCDFs. Wastes from PCP-based wood-preserving operations (waste 

codes K001 and F032) are also regulated as hazardous wastes under RCRA (40 CFR 261). 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 The EPA Office of Water promulgated effluent limitations for facilities that manufacture 

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chlorinated phenols and discharge treated wastewater (40 CFR 414.70). These effluent 

limitations do not specifically regulate CDDs or CDFs. The effluent limitations for the 

individually regulated chlorinated phenols are less than or equal to 39 μg/L for facilities that use 

biological end-of-pipe treatment.

8.4.1.3. Products—Chlorophenols

Chlorophenols have been widely used for a variety of pesticidal applications. The 

higher-chlorinated phenols (tetrachlorophenol and PCP) and their sodium salts have been used 

primarily for wood preservation. The lower-chlorinated phenols have been used primarily as 

chemical intermediates in the manufacture of other pesticides. For example, 2,4-dichlorophenol 

is used to produce the herbicides 2,4-dichlorophenoxyacetic acid (2,4-D), 

4-(2,4-dichlorophenoxy)butanoic acid (2,4-DB), 2-(2,4-dichlorophenoxy)-propanoic acid 

(2,4-DP), Nitrophen, Genite, and Zytron, and 2,4,5-trichlorophenol was used to produce 

hexachlorophene, 2,4,5-T, Silvex, Erbon, Ronnel, and Gardona (Gilman et al., 1988; Hutzinger 

and Fiedler, 1991b). 

Because of the manufacturing processes employed, commercial chlorophenol products 

can contain appreciable amounts of impurities (Gilman et al., 1988). During the direct 

chlorination of phenol, CDDs/CDFs can form either by the condensation of tri-, tetra-, and 

pentachlorophenols or by the condensation of chlorophenols with hexachlorocyclohexadienone 

(which forms from excessive chlorination of phenol). During alkaline hydrolysis of 

chlorobenzenes, CDDs/CDFs can form through chlorophenate condensation (Ree et al., 1988; 

Gilman et al., 1988; Hutzinger and Fiedler, 1991b) 

The limited information on CDD/CDF concentrations in chlorophenols published in the 

1970s and early 1980s was compiled by Versar, Inc. (1985) and Hutzinger and Fiedler (1991b). 

The results of several major studies cited by these reviewers (Firestone et al., 1972; Rappe and 

Marklund, 1978; Rappe et al., 1978) are presented in Table 8-8. Typically, CDDs/CDFs were 

not detected in mono- and dichlorophenols but were reported in tri- and tetrachlorophenols. 

More recent results of testing of 2,4-dichlorophenol, performed in response to the Toxic 

Substances Control Act (TSCA) dioxin/furan test rule, showed no detectable concentrations of 

2,3,7,8-substituted tetra- through hepta-CDD/CDFs.
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1 Detailed information on 2,4,5-T production and 2,3,7,8-TCDD levels was presented in 

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Chapter 11 of the original report. Production of 2,4,5-T during the 1950s, 1960s, and 1970s was 

estimated as 2,000, 4,000, and 1,500 MT/year, respectively. This was combined with estimates 

of 2,3,7,8-TCDD levels in the product to estimate that the cumulative amount of 2,3,7,8-TCDD 

in 2,4,5-T used over the period of 1950 to 1979 was 36,000 g. No product release estimates are 

presented for the reference years because production ceased prior to 1987. After the chemical 

was applied, it would have become incorporated into the soil reservoir. The potential amounts of 

2,3,7,8-TCDD remaining in the soil reservoir and possible releases are discussed in Chapter 11. 

The production of PCP for wood preserving began on an experimental basis in the 1930s. 

In 1947, nearly 3,200 MT of PCP were reported to have been used in the United States by the 

commercial wood preserving industry. Use in this industry steadily increased through the 

mid-1970s (AWPI, 1977). Although domestic consumption volumes are not available for all 

years, it is estimated, on the basis of historical production/export data for PCP reported in 

Mannsville (1983), that 90 to 95% of production volume has typically been consumed 

domestically rather than exported. A reasonable estimate of total domestic PCP consumption 

during the period of 1970 to 1995 is about 400,000 MT. This estimate assumes an average 

annual consumption rate of 20,000 MT/year during the 1970s, 15,000 MT/year during the 1980s, 

and 10,000 MT/year during the 1990s. 

Table 8-10 presents a compilation of published data on the CDD/CDF content of 

technical-grade PCP. The only samples that have been analyzed for all dioxin-like CDDs/CDFs 

were manufactured in the mid-to-late 1980s. Figure 8-1 presents these data in graphical form. It 

shows that the predominant congener groups are OCDD, OCDF, and HpCDD, Waddell et al. 

(1995) tested analytical-grade PCP (from Aldrich Chemical Co.) for CDD/CDF content and 

found the same congener profile; however, the CDD/CDF levels were three to four orders of 

magnitude lower. Table 8-11 presents a similar compilation of published data on the CDD/CDF 

content of PCP-Na. The table shows the same patterns of dominant congeners and congener 

groups reported for PCP

Samples of technical-grade PCP manufactured during the mid-to-late 1980s contained 

about 1.7 mg WHO98 TEQDF/kg (3 mg I-TEQ/kg), based on the data presented in Table 8-10. 

No published reports could be located that present the results of any congener-specific analyses 

of PCP manufactured since the late 1980s. However, monthly measurements of CDD/CDF 
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1 congener group concentrations in technical PCP manufactured for use in the United States have 

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been reported to EPA from 1987 to the present (letter dated March 5, 1997, from Thomas 

Mitchell, KMG-Bernuth, to Matthew Lorber, U.S. EPA; letter dated February 7, 1997, from John 

Wilkinson, Pentachlorophenol Task Force, to Matthew Lorber, U.S. EPA; U.S. EPA, 1999a). 

The average congener group concentrations reported to EPA for the years 1988 (i.e., 1 year after 

EPA regulations were imposed limiting HxCDD and 2,3,7,8-TCDD concentrations in PCP) to 

1999 are presented in Table 8-10. In general, the average congener group concentrations during 

the period of 1988 to 1999 are lower by a factor of 2 to 4 than the concentrations observed in the 

mid-to-late 1980 (based on the full-congener analysis of samples). If it is assumed that the toxic 

CDD/CDF congeners have also been reduced by a similar factor, then the TEQ content of PCP 

manufactured since 1988 is about 0.6 mg WHO98 TEQDF/kg (1 mg I-TEQ/kg).

An estimated 12,000 MT of PCP were used for wood preservation in the United States in 

1987 (WHO, 1991). An estimated 8,400 MT were used in 1994 (AWPI, 1995); for the purposes 

of this report, it is assumed that an identical amount was used in 1995. In 1999, approximately 

7,710 MT of PCP were produced annually in the United States (Council of Great Lakes 

Industries, 1999); for the purposes of this report, it is assumed that an identical amount was 

produced in 2000. Assuming that 95% of the production volume was consumed domestically 

(Mannsville, 1983) and that all of the PCP produced in 2000 was used for wood preservation, 

approximately 7,325 MT of PCP were used in the United States for wood preservation. 

Combining these activity level estimates with the TEQ concentration estimates presented above 

indicates that 20,000 g WHO98 TEQDF (36,000 g I-TEQDF), 4,800 g WHO98 TEQDF

(8,400 g I-TEQDF), and 4,200 g WHO98 TEQDF (7,300 g I-TEQDF) were incorporated into 

PCP-treated wood products in 1987, 1995, and 2000, respectively. It is unknown how much of 

the CDD/CDFs escape from the wood into the environment. Several field studies (Gurprasad et 

al., 1995; EPRI, 1995; Wan, 1995; Wan and Van Oostdam, 1995) demonstrate that CDDs/CDFs 

do apparently leach into soil from PCP-treated wood, but the studies do not provide release-rate 

data. No studies were located that provide any measured CDD/CDF volatilization rates from 

PCP-treated wood. Although CDDs/CDFs have very low vapor pressures, they are not bound to, 

nor do they react with, the wood in any way that would preclude volatilization. Lorber et al. 

(2002) compared the spatial distribution of CDD/CDF congeners in PCP-treated poles of 

different ages. A trend for dioxins to concentrate in the outer portions of the pole over time 
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1 suggests migration within the poles, and this migration may result in some environmental 

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release. However, this study could not quantify such releases. Several studies (Bremmer et al. 

[1994], Rappe [1995], Eduljee and Dyke [1996] and Douben et al. [1995]) have attempted to 

estimate potential CDD/CDF volatilization releases using conservative assumptions or modeling 

approaches, but these estimates span many orders of magnitude. Therefore, no estimate could be 

made as to what portion of the CDD/CDFs in products are released to the environment (Not 

quantifiable). The cumulative amounts of CDD/CDFs in PCP-treated wood can also be 

considered a potential reservoir source (see Chapter 11 for further discussion of this issue). 

8.4.1.4. Products—2,4-D 

Although 2,4-Dichlorophenoxyacetic acid (2,4-D) is not a true chlorophenol, it is 

included in this section because it is produced from chlorophenols and, therefore, is closely 

associated. The available information on 2,4-D production and CDD/CDF levels was

summarized in Chapter 11 of the original report. An estimated 28,100 MT of 2,4-D were used in 

the United States in 2000, making it one of the top 10 pesticides in terms of quantity used (EPA 

proprietary data). The pesticide 2,4-D is judged to have the potential for environmental release 

through its agricultural use. Since 1995, the chemical manufacturers of 2,4-D have been 

undertaking voluntary actions to significantly reduce the dioxin content of the product. No 

information is available on the level of dioxin contamination, if any, that may have been present 

in 2,4-D in 2000. An estimated 26,300 and 30,400 MT were used during 1995 and 1987, 

respectively (U.S. EPA, 1997c, 1988). On the basis of the average CDD/CDF congener 

concentrations in 2,4-D (not including OCDD and OCDF), the corresponding WHO98 TEQDF

concentration is 1.1 μg/kg (0.7 μg I-TEQDF/kg). Combining this TEQ concentration with the 

activity level estimates for 1995 and 1987 indicates that 28.9 g WHO98 TEQDF (18.4 g I-TEQDF) 

were released in 1995 and 33.4 g WHO98 TEQDF (21.3 g I-TEQDF) was released in 1987. No 

estimate can be made for 2000 because of the poor quality of existing information. 

8.4.2. Chlorobenzenes

8.4.2.1. Process Description

Chlorobenzenes can be produced via three methods: (1) electrophilic substitution of 

benzene (in liquid or vapor phase) with chlorine gas in the presence of a metal salt catalyst, 
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1 (2) oxidative chlorination of benzene with HCl at 150 to 300ΕC in the presence of a metal salt 

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catalyst, and (3) dehydrohalogenation of hexachlorocyclohexane wastes at 200 to 240ΕC with a 

carbon catalyst to produce trichlorobenzene, which can be further chlorinated to produce 

higher-chlorinated benzenes (Ree et al., 1988; Hutzinger and Fiedler, 1991b; Bryant, 1993). 

All chlorobenzenes currently manufactured in the United States are produced by the 

electrophilic substitution process using liquid-phase benzene (i.e., temperature is at or below 

80ΕC). FeCl3 is the most common catalyst employed. Although this method can be used to 

produce mono- through hexachlorobenzene, the extent of chlorination is controlled to yield 

primarily monochlorobenzene and dichlorobenzene. The finished product is a mixture of 

chlorobenzenes, and refined products must be obtained by distillation and crystallization (Bryant, 

1993). 

8.4.2.2. Regulations for Chlorobenzenes 

EPA determined, as part of the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA) Data Call-In, that the 1,4-dichlorobenzene manufacturing processes used in the United 

States are not likely to form CDDs/CDFs. Mono-, di-, and trichlorobenzene are listed as 

potential precursor chemicals under the TSCA dioxin/furan test rule and are subject to reporting. 

In addition, EPA issued a Significant New Use Rule (SNUR) under Section 5(a)(2) of TSCA on 

December 1, 1993 (effective January 14, 1994) for pentachlorobenzene and 

1,2,4,5-tetrachlorobenzene (Federal Register, 1993). This rule requires that EPA be notified at 

least 90 days before the manufacture, import, or processing of either of these compounds in 

amounts of 10,000 pounds or greater per year per facility for any use. All registrations of 

pesticide products containing hexachlorobenzene were cancelled in the mid-1980s (Carpenter 

et al., 1986). 

OSW promulgated land disposal restrictions on wastes (i.e., wastewaters and 

nonwastewaters) resulting from the manufacture of chlorobenzenes (40 CFR 268). Table 8-9 

lists all solid wastes for which EPA specifically regulates CDDs and CDFs, including 

chlorobenzene wastes, as hazardous constituents. The regulations prohibit the land disposal of 

these wastes until they are treated to a level below the routinely achievable DLs in the waste 

extract listed in Table 8-9 for each of the following congener groups: TCDDs, PeCDDs, 

HxCDDs, TCDFs, PeCDFs, and HxCDFs.
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1 The EPA Office of Water promulgated effluent limitations for facilities that manufacture

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chlorinated benzenes and discharge treated wastewater (40 CFR 414.70). These effluent 

limitations do not specifically address CDDs and CDFs. The following chlorinated benzenes are 

regulated: chlorobenzene, 1,2-dichlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene, 

1,2,4-trichlorobenzene, and hexachlorobenzene. The effluent limitations for the individual 

regulated chlorinated benzenes are less than or equal to 77 μg/L for facilities that use biological 

end-of-pipe treatment and less than or equal to 196 μg/L for facilities that do not use biological 

end-of-pipe treatment.

Since at least 1993, U.S. commercial production of chlorobenzenes has been limited to 

monochlorobenzene, 1,2-dichlorobenzene, 1,4-dichlorobenzene, and, to a much lesser extent, 

1,2,4-trichlorobenzene. As noted above, CDD/CDF formation is not expected under the normal 

operating conditions of the processes currently used in the United States to produce these 

four chemicals. No tetra-, penta-, or hexachlorinated benzenes are now intentionally produced or 

used in the United States (Bryant, 1993). Thus, releases of CDDs/CDFs from the manufacture of 

chlorobenzenes in 1995 were estimated to be negligible. Because the information available on 

CDD/CDF content of mono-through pentachlorobenzene is very limited and is based primarily 

on unpublished European data, and because information on the chlorobenzene manufacturing 

processes in place during 1987 is not readily available, no emission estimates can be made for 

1987. 

8.4.2.3. Products—Chlorobenzenes 

Chlorobenzenes have been produced in the United States since 1909. U.S. production 

operations were developed primarily to provide chemical raw materials for the production of 

phenol, aniline, and various pesticides based on the higher-chlorinated benzenes. Because of 

(incremental) changes in the processes used to manufacture phenol and aniline and the phaseout 

of highly chlorinated pesticides such as DDT and hexachlorobenzene, U.S. production of 

chlorobenzenes in 1988 had decreased to 50% of the peak production level, in 1969. 

CDDs/CDFs can be produced inadvertently during the manufacture of chlorobenzenes by 

nucleophilic substitution and pyrolysis mechanisms (Ree et al., 1988). The criteria required for 

production of CDDs/CDFs via nucleophilic substitution are oxygen as a nuclear substituent (i.e., 

presence of chlorophenols) and production or purification of the substance under alkaline 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 conditions. Formation via pyrolysis requires reaction temperatures above 150°C (Ree et al., 

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13 

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15 

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31 

1988; Hutzinger and Fiedler, 1991b). The liquid-phase electrophilic substitution process 

currently used in the United States does not meet either of these criteria. Although Ree et al. 

(1988) and Hutzinger and Fiedler (1991b) state that the criteria for formation of CDDs/CDFs via 

nucleophilic substitution may be present in the catalyst neutralization and purification/distillation 

steps of the manufacturing process; Opatick (1995) states that the chlorobenzene reaction 

product in U.S. processes remains mildly acidic throughout these steps. 

Table 8-12 summarizes the very limited published information on CDD/CDF 

contamination of chlorobenzene products. The presence of CDDs/CDFs has been reported in 

tri-, penta-, and hexachlorobenzene. No CDDs/CDFs have been reported in mono- or 

dichlorobenzene. Conflicting data exist concerning the presence of CDDs/CDFs in 

trichlorobenzene. One study (Villanueva et al., 1974) detected no CDDs/CDFs in one sample of 

1,2,4-TCBz at a DL of 0.1 μg/kg. Hutzinger and Fiedler (1991b) reported unpublished results of 

a study by Dr. Hans Hagenmaier showing CDD/CDF congener group concentrations ranging 

from 0.02 to 0.074 μg/kg in a sample of mixed TCBz. Because the TCBz examined by 

Hagenmaier contained about 2% hexachlorocyclohexane, it is reasonable to assume that it was 

produced by dehydrohalogenation of hexachlorocyclohexane (a manufacturing process not 

currently used in the United States). 

In conclusion, although there is some evidence that CDD/CDFs may be present in 

chlorobenzene products, insufficient information is available to make quantitative estimates. 

Accordingly, they are considered to be unquantifiable. 

8.4.3. Complex Plants 

 In the year 2000, two facilities with an SIC code for plastic materials, synthetic resins, 

and nonvulcanizable elastomers reported dioxin releases under the EPA TRI program (U.S. EPA, 

2008). The sum of the air releases across these facilities was 5.6 g, which EPA estimates is 

equal to 0.5 g WHO98 TEQDF. No releases to other media were reported. As explained in 

Chapter 1, the TRI data are not used to make quantitative estimates in this document but rather as 

supportive evidence that releases do occur. 

In the year 2000, four facilities with an SIC code for industrial organic chemicals not 

classified elsewhere reported dioxin releases under the EPA TRI program (U.S. EPA, 2008). 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 The sum of the air releases across these facilities was 153 g, which EPA estimates is equal to 

2 

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6 

7 

8 

9 

10 

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13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

2.2 g WHO98 TEQDF. No releases to other media were reported. As explained in Chapter 1, the 

TRI data are not used to make quantitative estimates in this document but rather as supportive 

evidence that releases do occur.

The information presented in Dyke and Amendola (2007) was selected as the best basis 

for estimating CDD/CDF releases from facilities that produce combinations of chlorine and 

multiple chlorinated organic chemicals. The 10 complex chemical plants covered in this study 

are believed to represent most facilities of this type in the United States. Therefore, it was 

unnecessary to develop emission factors to estimate releases from untested facilities. Dyke and 

Amendola reported their release estimates in I-TEQs, but stated that WHO98 values were usually 

less than 20% different. Using the water congener profile, the WHO98 values were computed to 

be only 4% higher that the I-TEQs. On this basis the I-TEQs were assumed to be equivalent to 

the WHO98 TEQs for all releases. The Dyke and Amendola release estimates are specific to the 

year 2000. Because the chemical production rates and technologies used at these facilities have 

changed significantly, no release estimates could be made for 1987 and 1995. 

Table 8-13 shows the amount of CDD/CDFs that are sent to off-site incinerators and 

landfills. The releases from incineration are included in the estimates presented for hazardous 

waste incinerators (see Section 3.2). The amounts sent to secure landfills (118 g I-TEQ in 2000) 

are not considered to be environmental releases.

The releases to all media from the complex chemical plants are presented in Table 8-13. 

The inventory decision criteria and releases to all media are summarized below:
This document is a draft for review purposes only and does not constitute Agency policy.

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Inventory Decision Criteria for Complex Chemical Plants Producing Chlorine and a 

Variety of Chlorinated Organics

Air Water Solids Products

Emission tests for at least two units/source types with Yes Yes Yes Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes Yes Yes Yes

understandable differences. 

Emission factor tests represent units that are typical of the Yes Yes Yes Yes

class. 

Activity estimates based on source-specific surveys. Yes Yes Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q Q Q Q

1 

2 
This document is a draft for review purposes only and does not constitute Agency policy.

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Complex Chemical Plants Producing Chlorine and a Variety of Chlorinated Organics

Air Releases

•

•

•

1987—Not available.

1995—Not available. 

2000—5 g (WHO98 or I-TEQ).

Water Releases

•

•

•

1987—Not available.

1995—Not available. 

2000—25 g (WHO98 or I-TEQ).

Solid Residue Releases

Landfarmed

• 1987—Not available. 

• 1995—Not available. 

• 2000—1 g (WHO98 or I-TEQ).

Products

PVCs

• 1987—Not quantifiable. 

• 1995—Not quantifiable. 

• 2000—Not quantifiable. 

Pentachlorophenols

• 1987—Not quantifiable. 

• 1995—Not quantifiable. 

• 2000—Not quantifiable. 

2,4-Dichlorophenoxy acetic acid (2,4-D)

• 1987—33 g WHO98 TEQDF (21 g I-TEQDF). 

• 1995—29 g WHO98 TEQDF (18 g I-TEQDF).

• 2000—Not quantifiable. 

Chlorobenzenes

• 1987—Not quantifiable. 

• 1995—Not quantifiable. 

• 2000—Not quantifiable.

1 

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4 

5 

6 

8.5. MUNICIPAL WASTEWATER TREATMENT PLANTS

This section corresponds to Section 8.4.1 of the original report. Minor changes were 

made to the solid residue and product release estimates.
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1 8.5.1. Air Releases

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Releases associated with sewage sludge incineration are covered in Section 3.5. 

8.5.2. Water Releases

No changes were made to the emission factors, activities, or release estimates. The 

CRWQCB data (memorandum dated March 21, 1996, from Lila Tang, California Regional 

Water Quality Control Board, to David Cleverly, U.S. EPA) were the only U.S. data that 

provided TEQ estimates for CDD/CDF levels in wastewaters from sewage treatment plants. 

Accordingly, the concentration from this study (0.27 pg WHO98 TEQDF/L [0.29 pg I-TEQDF/L]) 

was assumed to apply to all reference years. However, these data were from plants in the San 

Francisco area and cannot be considered to be representative of the 16,000-plus POTWs 

nationwide. Therefore, the emission factor was considered preliminary. Activity estimates were 

derived from EPA surveys as described in US EPA (2006) and are presented in the release 

summary below.

8.5.3. Solid Residue Releases

The large U.S. studies (U.S. EPA, 1996b, 2002d; Green et al., 1995; Cramer et al., 1995) 

were selected as the best basis for estimating emission factors. Because the mean I-TEQDF

concentration values reported in the 1988/1989 sewage sludge survey (U.S. EPA, 1996b) and the 

1995 survey (Green et al., 1995; Cramer et al., 1995) were very similar, the estimated amounts of 

TEQs that may have been present in sewage sludge and released to the environment in 1987 and 

1995 were assumed to be the same. These values were estimated using the average of the mean 

concentration values (nondetects equal to DLs) reported by EPA (1996b) (50 ng I-TEQDF/kg) 

and by Green et al. (1995) and Cramer et al. (1995) (36.3 ng WHO98 TEQDF/kg 

[47.7 ng I-TEQDF/kg]). Therefore, the overall average mean emission factor for reference years 

1987 and 1995 is 36.3 ng WHO98 TEQDF/kg (48.9 ng I-TEQDF/kg). The emission factor of 

14 ng WHO98 TEQDF/kg (15 ng I-TEQDF/kg), as calculated from the 2001 survey (U.S. EPA, 

2002d), appears to be the most reasonable TEQ emission factor estimate for reference year 2000 

because this estimate is nationally weighted on the basis of wastewater flow rates of POTWs 

operating in the United States in 2001 (see Table 8-14—note that the values in this table were 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 recalculated, resulting in minor decreases compared to the original document, which presented 

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the data in Table 8-40). 

No changes were made to the sludge activity results, which were presented in 

three categories: land applied (includes advanced treatment since this refers to composting, 

which is generally done in unlined containers), landfilled (includes sludge landfills, codisposal 

landfills, and surface disposal), and product (includes distribution/marketing and beneficial use). 

The summary table below presents the activities and releases for sludge, which is land applied or 

used in products. These are assumed to result in environmental releases. The landfilled sludges 

are not included in the summary because they are not considered to be environmental releases. 

The activity estimates for the landfilled sludge were 2.37 million dry MT in 1987, 

1.10 million dry MT in 1995, and 0.90 million dry MT in 2000. The CDD/CDF amounts in the 

landfilled sludge were estimated as follows:

• 1987—86 g WHO TEQDF (120 g I-TEQDF/kg) 

• 1995—40 g WHO TEQDF (54 g I-TEQDF/kg) 

• 2000—13 g WHO TEQDF (14 g I-TEQDF/kg) 

8.5.4. Products

The sewage sludge emission factors described above were also applied to the swage

sludge used as products. No changes were made to the activity estimates. All of these values 

and the resulting release estimates are presented in the summary table below.

8.5.5. Releases

The inventory decision criteria and releases to all media are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy.

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Inventory Decision Criteria for Municipal Wastewater Treatment Plants

Air Water Solids Products

Emission tests for at least two units/source types with Yes Yes Yes

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have Yes Yes Yes

understandable differences. 

Emission factor tests represent units that are typical of the No Yes Yes

class. 

Activity estimates based on source-specific surveys. Yes Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). P Q Q

1 

2 
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Municipal Wastewater Treatment Plants

Air Releases

None.

Water Releases

Emission Factors

• 1987—0.27 pg WHO TEQDF/L (0.29 pg I-TEQDF/L) 

• 1995—0.27 pg WHO TEQDF/L (0.29 pg I-TEQDF/L) 

• 2000—0.27 pg WHO TEQDF/L (0.29 pg I-TEQDF/L) 

(Preliminary). 

(Preliminary). 

(Preliminary).

Activity Levels

• 1987—47.8 trillion L. 

• 1995—44.5 trillion L.

• 2000—54.0 trillion L.

Releases

• 1987—13 g WHO TEQDF/yr (14 

• 1995—12 g WHO TEQDF/yr (13 

• 2000—15 g WHO TEQDF/yr (16

g I-TEQDF/yr) (Preliminary). 

g I-TEQDF/yr) (Preliminary). 

g I-TEQDF/yr) (Preliminary).

Solid Residue Releases

Emission Factors

• 1987—36 ng WHO TEQDF/kg (49 ng I-TEQDF/kg). 

• 1995—36 ng WHO TEQDF/kg (49 ng I-TEQDF/kg). 

• 2000—14 ng WHO TEQDF/kg (15 ng I-TEQDF/kg).

Activity Levels

Land Applied 

• 1987—1.71 million dry 

• 1995—3.20 million dry 

• 2000—3.60 million dry 

MT/yr. 

MT/yr. 

MT/yr.

Releases

Land Applied 

• 1987—62 g WHO TEQDF (84 g I-TEQDF/kg). 

• 1995—120 g WHO TEQDF (160 g I-TEQDF/kg). 

• 2000—50 g WHO TEQDF (54 g I-TEQDF/kg).
This document is a draft for review purposes only and does not constitute Agency policy.

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Municipal Wastewater Treatment Plants (continued)

Products

Emission Factors

• 1987—36 ng WHO TEQDF/kg (49 ng I-TEQDF/kg). 

• 1995—36 ng WHO TEQDF/kg (49 ng I-TEQDF/kg). 

• 2000—14 ng WHO TEQDF/kg (15 ng I-TEQDF/kg).

Activity Levels

• 1987—0.07 MMT. 

• 1995—0.50 MMT. 

• 2000—0.50 MMT.

Releases

• 1987—3 g WHO TEQDF (3 g I-TEQDF/kg). 

• 1995—18 g WHO TEQDF (24 g I-TEQDF/kg). 

• 2000—7 g WHO TEQDF (8 g I-TEQDF/kg).

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8.6. DRINKING WATER TREATMENT PLANTS

This section corresponds to Section 8.4.2 in the original report. As discussed in the 

original report, there is no evidence that releases of CDD/CDFs occur from drinking water 

treatment plants. No changes were made to this conclusion. 

8.7. SOAPS AND DETERGENTS

This section corresponds to Section 8.4.3 in the original report. As discussed in the 

original report, there is some evidence that soaps and detergents may be a source of CDD/CDFs, 

but the data were judged inadequate for making quantitative estimates. 

Soaps and Detergents

Releases

Not quantifiable.

8.8. TEXTILE MANUFACTURING AND DRY CLEANING

This section corresponds to Section 8.4.4 in the original report. As discussed in the 

original report, there is some evidence that textiles manufacturing and dry cleaning may be 

sources of CDD/CDFs, but the data were judged inadequate for making quantitative estimates.
This document is a draft for review purposes only and does not constitute Agency policy.

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Textiles Manufacturing and Dry Cleaning

Releases

Not quantifiable.

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26 

8.9. DYES, PIGMENTS, AND PRINTING INKS

This section corresponds to Section 8.3.6 in the original report. As discussed in the 

original report, very little chloranil has been produced in the United States since the 1980s, so 

production releases during the reference years are probably negligible. EPA (2006) used 

concentration and import data to estimate that chloranil imports contained 64 g I-TEQ in 1987, 

0.4 g I-TEQ in 1995, and 1.2 g I-TEQ in 2000. It is unknown if releases occurred from these 

products. 

Chloranil Imports

Releases

Not quantifiable.

Similarly, some evidence exists that phthalocyanine dyes and printing inks may be a 

source of CDD/CDFs, but the data were judged inadequate for making quantitative estimates.

Phthalocyanine Dyes and Printing Inks

Releases

Not quantifiable.

8.10. OTHER ALIPHATIC CHLORINE COMPOUNDS

This section corresponds to Section 8.3.5 in the original report. As discussed in the 

original report, there is no strong evidence that CDD/CDFs are present in these compounds. 

8.11. RESIDENTIAL SEPTIC SYSTEMS

This is a new section. Because CDD/CDFs have been measured in discharges from 

municipal wastewater treatment systems, they may also be released from residential septic 

systems. No information was found on measured CDD/CDF levels in the sewage entering these 

systems. However, preliminary estimates can be made as discussed below. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 8.11.1. Process Description

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31 

Most residential septic systems consist of a septic tank and drainage field or dry well. 

The household waste flows by gravity into the septic tank where biological digestion occurs and 

solids settle out. The overflow goes into the drainage field or dry well where it slowly percolates 

into the ground. 

8.11.2. Regulations 

None specific to dioxins. 

8.11.3. Emission Factor 

No measurements were found on the amount of CDD/CDF excreted by people. However 

studies have been done with dairy cattle involving measurements of dioxins in their feed, milk, 

feces, and urine under carefully controlled settings (Winters et al., 2000; Lorber et al., 2000; 

McLachlan et al., 1990). These studies found that 50% to 100% of both TEQs and individual 

congeners in the feed were recovered in the milk and feces. For purposes of a preliminary 

estimate, it is assumed here that 100% of the dioxin TEQs ingested by people are excreted in the 

feces. Clearly this is an overestimate particularly for lactating mothers. For the general 

population, adult daily intakes are estimated to average 43 pg WHO98 TEQDF for CDD/CDFs and 

23 pg WHO98 TEQPCB for PCBs (U.S. EPA, 2004). It is assumed that 30 pg WHO98 TEQDF/day 

represents a whole population average (children plus adults) for the CDD/CDFs. Assuming that 

two thirds of an individual’s excretion occurs at their residence, 20 pg WHO98TEQDF/day is 

discharged to the septic system. It is also assumed that no TEQ degradation or formation occurs 

in the septic system.

Septic systems are designed to trap the solid components of sewage in a septic tank. The 

tank is periodically pumped, and the contents are discharged to a municipal wastewater treatment 

system (these releases are covered in Section 8.5). Many of the smaller particles and oily 

components will flow into the drainage field. The fraction CDD/CDFs released to the drainage 

field will depend largely on the solids trapping efficiency of the system, which depends on 

variables such as tank size, flow rates, and pumping frequency. For the purposes of a 

preliminary estimate, this is assumed to be 50%. Thus, the overall emission factor is assumed to 

be 10 pg WHO98 TEQDF/day-person and would be applicable to all reference years. Considering 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 the lack of direct feces measurements and multiple assumptions required for this estimate, it is 

2 

3 

4 

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6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

given a preliminary confidence rating.

8.11.4. Activity

Septic systems serve 25% of the U.S. population (U.S. EPA, 2005). The total U.S. 

population is estimated to be 242 million in 1987, 263 million in 1995, and 300 million in 2000 

(U.S. DOC, 2000). Multiplying by 25%, the activity for each reference year is 61 million in 

1987, 66 million in 1995, and 75 million in 2000. 

8.11.5. Releases

The releases from septic systems will occur via the liquid effluent that drains into the soil. 

It is included with the solid residues because the release is to land. 

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Residential Septic Systems

Air Water Solids Products

Emission tests for at least two units/source types with No

sufficient documentation to directly derive emission 

factors. 

Measured emission factors consistent or have 

understandable differences. 

Emission factor tests represent units that are typical of the 

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P
This document is a draft for review purposes only and does not constitute Agency policy.

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Residential Septic Systems

Air Releases

None.

Water Releases

None.

Solid Residue Releases

Emission Factors

• 1987—10 pg WHO98 TEQDF/day-person (Preliminary). 

• 1995—10 pg WHO98 TEQDF/day-person (Preliminary). 

• 2000—10 pg WHO98 TEQDF/day-person (Preliminary).

Activity Levels

• 1987—61 million people. 

• 1995—66 million people. 

• 2000—75 million people.

Releases

• 1987—0.2 g WHO98 TEQDF (Preliminary). 

• 1995—0.2 g WHO98 TEQDF (Preliminary). 

• 2000—0.3 g WHO98 TEQDF (Preliminary).

1 
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Table 8-1. CDD/CDF concentrations (μg/kg) in graphite electrode sludge 

from chlorine production

Congener/congener group Sludge 1 Sludge 2 Sludge 3 Sludge 4

2,3,7,8-TCDD

1,2,3,7,8-PeCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

OCDD

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

OCDF

ND (0.006)

ND (0.007) 

ND (0.018) 

ND (0.012) 

ND (0.016) 

0.095 

0.92 

26 

25 

12 

32 

7 

1.3 

0.87 

9.1 

8.1 

31

ND (0.009)

ND (0.009) 

ND (0.026) 

ND (0.016) 

ND (0.022) 

0.21 

2 

56 

55 

25 

71 

16 

2.8 

1.9 

19 

19 

76

ND (0.009)

ND (0.009) 

ND (0.029) 

ND (0.019) 

ND (0.025) 

0.25 

2.2 

57 

56 

24 

73 

15 

2.6 

2 

19 

20 

71

ND

ND (0.033) 

ND (0.49) 

ND (0.053) 

ND (1.2) 

0.055 

0.65 

52 

55 

27 

44 

12 

1.7 

1.3 

15 

14 

81

Total 2,3,7,8-CDDa

Total 2,3,7,8-CDFa

Total I-TEQDFa

Total WHO98 TEQDFa

1.02

152.37 

14.2 

14.1

2.21

341.7 

30.5 

30.4

2.45

339.6 

30.2 

30.2

0.7

303 

27.7 

27.6

Total TCDD

Total PeCDD

Total HxCDD

Total HpCDD

Total OCDD

Total TCDF

Total PeCDF

Total HxCDF

Total HpCDF

Total OCDF

ND (0.006)

ND (0.070) 

ND (0.046) 

0.22 

0.92 

64 

75 

68 

24 

31

ND (0.009)

ND (0.009) 

ND (0.064) 

0.48 

2 

150 

240 

140 

53 

76

ND (0.009)

ND (0.009) 

ND (0.074) 

0.56 

2.2 

140 

240 

140 

54 

71

--

--

--

--

0.65 

--

--

--

--

81

Total CDD/CDFa 263.14 661.48 647.76 --

a

Calculated assuming nondetect values were zero.

ND = Not detected (value in parenthesis is the reported detection limit).

-- = No information given.

Sources: Rappe et al. (1991); Rappe (1993).
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 8-2. Releases of dioxin-like compounds in wastewater discharges from chlor-alkali manufacturing 

facilities to surface water in 2000 

Congener

Occidental Chemical Corporation PPG Industries

Total

Battleground, 

TX Deer Park, TX

Delaware City, 

DE

Hahnville, 

LA

Mobile, 

AL

Muscle Shoals, 

AL

Natrium,

WV

2,3,7,8 TCDD 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02

1,2,3,7,8 PeCDD 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

1,2,3,4,7,8 HxCDD 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

1,2,3,6,7,8 HxCDD 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

1,2,3,7,8,9 HxCDD 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

1,2,3,4,6,7,8 HpCDD 0.00 0.08 0.00 0.01 0.00 0.00 0.22 0.31

OCDD 0.48 21.50 4.09e!03 0.10 1.15e!03 1.13e!09 3.13 25.22

2,3,7,8 TCDF 0.00 0.63 1.02e!03 0.19 2.88e!04 3.94e!08 0.06 0.89

1,2,3,7,8 PeCDF 0.00 1.20 0.00 0.90 0.00 1.33e!07 0.06 2.16

2,3,4,7,8 PeCDF 0.00 0.21 0.00 0.85 0.00 7.99e!08 0.33 1.39

1,2,3,4,7,8 HxCDF 0.00 2.11 0.00 2.96 0.00 1.85e!07 0.11 5.18

1,2,3,6,7,8 HxCDF 0.00 0.38 0.00 1.18 0.00 9.76e!08 0.00 1.56

1,2,3,7,8,9 HxCDF 0.00 2.03e!03 0.00 0.63 0.00 2.29e!08 0.00 0.63

2,3,4,6,7,8 HxCDF 0.00 0.00 0.00 0.60 0.00 3.28e!08 0.00 0.60

1,2,3,4,6,7,8 HpCDF 0.00 0.59 2.31e!03 4.47 6.49e!04 1.32e!07 0.15 5.22

1,2,3,4,7,8,9 HpCDF 0.00 5.66e!03 0.00 0.69 0.00 6.30e!08 0.00 0.69

OCDF 0.00 4.88 0.00 1.75 0.00 1.34e!07 0.66 7.29

Total I-TEQ 4.83e!04 0.53 1.29e!04 1.08 3.64e!05 8.65e!08 0.19 1.80

Total WHO98 TEQDF 4.83e!05 0.51 1.26e!04 1.08 3.54e!05 8.63e!08 0.19 1.59

Source: CCC (2004).
This document is a draft for review purposes only and does not constitute Agency policy

1/7/2013 8-38 DRAFT: DO NOT CITE OR QUOTE

Table 8-3. Congener-specific and TEQ annual releases to air (g/year) from a 

chlor-alkali facility in 2000 

Congener

PPG Industries

Natrium, WV

2,3,7,8-TCDD 0.003

1,2,3,7,8-PeCDD 0.000

1,2,3,4,7,8-HxCDD 0.000

1,2,3,6,7,8-HxCDD 0.002

1,2,3,7,8,9-HxCDD 0.002

1,2,3,4,6,7,8-HpCDD 0.087

OCDD 0.208

2,3,7,8-TCDF 0.044

1,2,3,7,8-PeCDF 0.003

2,3,4,7,8-PeCDF 0.030

1,2,3,4,7,8-HxCDF 0.044

1,2,3,6,7,8-HxCDF 0.006

1,2,3,7,8,9-HxCDF 0.006

2,3,4,6,7,8-HxCDF 0.022

1,2,3,4,6,7,8-HpCDD 0.142

1,2,3,4,7,8,9-HpCDD 0.039

OCDF 0.064

Total I-TEQDF 0.034

Total WHO98 TEQDF 0.033

Source: Chlorine Chemistry Council (2004).
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

8-39 DRAFT: DO NOT CITE OR QUOTE

Table 8-4. Annual releases in 2000 from stand-alone chlor-alkali plants (g I-TEQ/year)

Plant/Location Chemicals

On-site Off-site transfersa

Air Water Landfill Landfarm Landfill Incineration Well Inj

Occidental—Mobile, AL Cl2 (membrane-cell), caustic 

potash, sodium silicate

3.60 × 10–5 0.83

Confidence Rating H/H H/H

Occidental—Battleground, 

TX 

Cl2 (diaphragm-cell), NaOH 4.80× 10–4

Confidence Rating H/H

Occidental—Deer Park, TX 

(CA) 

Cl2 (mercury/diaphragmcell), NaOH 0.54 0.38

Confidence Rating H/H R/H

Occidental—Delaware City, 

DE 

Cl2 (mercury-cell), NaOH, 

caustic potash,

1.30× 10–4 0.81 3.50 × 10–6

Confidence Rating R/H H/H H/H

Occidental—Hahnville (Taft), 

LA 

Cl2 (mercury/diaphragmcell), NaOH, sulfur1.08 0.2 9.60 × 10–9 0.04

Confidence Rating H/H H/H H/H R/H

Occidental—Muscle Shoals, 

AL 

Cl2 (mercury-cell) and 

caustic potash 

8.70 × 10–8 0.38

Confidence Rating H/H H/H

PPG Industries—Natrium, 

WV 

Cl2 (mercury/diaphragm-cell 

cell), NaOH

0.034 0.193 0.085

Confidence Rating R/H R/R H/H

Total 0.03 1.81 0.0 0.0 2.69 0.0 0.04

a

The off-site transfers represent the amount going to off-site facilities and not the amount released to the environment. 

H = High.

R = Reasonable.

Source: Dyke and Amendola, 2007.
This document is a draft for review purposes only and does not constitute Agency policy

1/7/2013 8-40 DRAFT: DO NOT CITE OR QUOTE

Table 8-5. Reported CDD/CDF concentrations (μg/kg) in wastes from 

polyvinyl chloride (PVC) manufacture 

Congener/congener group F024 waste K019 waste K020 waste

2,3,7,8-TCDD

1,2,3,7,8-PeCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

OCDD

0.37

0.14 

0.3 

0.14 

0.11 

4.2 

15

260

890 

260 

330 

620 

920 

1,060

0.06

0.05 

0.08 

0.06 

0.07 

0.89 

3

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

OCDF

0.91

9.5 

1.6 

110 

24 

9.5 

3.1 

250 

51 

390

680

975 

1,050 

10,100 

9,760 

21,800 

930 

13,400 

1,340 

43,500

0.44

1.8 

0.58 

11 

2.4 

1.3 

0.89 

38 

6 

650

Total 2,3,7,8-CDD

Total 2,3,7,8-CDF

Total I-TEQDF

Total WHO98 TEQDF

20.3

849.6 

20 

19.7

4,340

103,535 

5,928 

6,333

4.21

712.4 

3.2 

2.6

Total TCDD

Total PeCDD

Total HxCDD

Total HpCDD

Total OCDD

Total TCDF

Total PeCDF

Total HxCDF

Total HpCDF

Total OCDF

3.1

3.6 

1.3 

5 

15 

15 

65 

300 

450 

390

1,230

3,540 

3,950 

1,270 

1,060 

20,600 

45,300 

63,700 

16,600 

43,500

1.9

1.7 

a

1.7 

3 

6 

11 

27 

58 

650 

Total CDD/CDF 1,248 200,750 760.3

a

Congener group concentration reported in source is not consistent with reported congener concentrations.

Source: Stringer et al. (1995). 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

8-41 DRAFT: DO NOT CITE OR QUOTE

Table 8-6. CDD/CDF concentrations in products from U.S. EDC/VCM/PVC manufacturers

Congener/congener group

Suspension and mass 

PVC resins Dispersion PVC resins EDC sold as productd

No. 

detects/

samplesa

Rangeb (ng/kg) No. of 

detects/

samples

Rangec (ng/kg)

No. detects/

samples

Rangee (ng/kg)

Min. Max. Min. Max. Min. Max.

2,3,7,8-TCDD

1,2,3,7,8-PeCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

OCDD

0/22

0/22 

0/22 

0/22 

0/22 

1/22 

0/22

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

0.64 

ND

0/6

0/6 

0/6 

0/6 

0/6 

1/6 

0/6

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

0.8 

ND

0/5

0/5 

0/5 

0/5 

0/5 

0/5 

0/5

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

OCDF

0/22

0/22 

0/22 

0/22 

0/22 

0/22 

1/22 

0/22 

0/22 

0/22

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

0.37 

ND

ND

ND

0/6

0/6 

0/6 

0/6 

0/6 

0/6 

0/6 

0/6 

0/6 

2/6

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

0.38

0/5

0/5 

0/5 

0/5 

0/5 

0/5 

0/5 

1/5 

1/5 

1/5

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

1.1 

0.4 

11

Mean I-TEQDF (nondetect = 0)

Mean I-TEQDF (nondetect = 1⁄2 DL)

0.002 0.7 0.001 0.4 0.001 0.21
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

8-42 DRAFT: DO NOT CITE OR QUOTE

Table 8-6. CDD/CDF concentrations in products from U.S. EDC/VCM/PVC manufacturers (continued)

Congener/congener group

Suspension and mass 

PVC resins Dispersion PVC resins EDC sold as productd

No. 

detects/

samplesa

Rangeb (ng/kg) No. of 

detects/

samples

Rangec (ng/kg)

No. detects/

samples

Rangee (ng/kg)

Min. Max. Min. Max. Min. Max.

Total TCDD

Total PeCDD

Total HxCDD

Total HpCDD

Total OCDD

Total TCDF

Total PeCDF

Total HxCDF

Total HpCDF 

Total OCDF

0/22

0/22 

0/22 

1/22 

0/22 

0/22 

0/22 

1/22 

0/22 

0/22

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

0.64 

ND

ND

ND

0.37 

ND

ND

1/6

1/6 

5/6 

1/6 

0/6 

0/6 

1/6 

0/6 

0/6 

2/6

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

0.24

0.32 

0.97 

1.3 

ND

ND

0.3 

ND

ND

0.38

0/5

0/5 

0/5 

0/5 

0/5 

0/5 

0/5 

0/5 

1/5 

1/5

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

2.02 

11

a

Two of these 22 samples were duplicate samples from two sites. The results were averaged and treated as one sample for each site. b

Detection limits (DLs) for individual samples were less than 2 ng/kg for all congeners and congener groups except OCDD and OCDF, which had DLs less than 

6 ng/kg. c

DLs for individual samples were less than 2 ng/kg for all congeners and congener groups except OCDD and OCDF, which had DLs less than 4 ng/kg. d

“Sales” EDC is defined as EDC sold commercially for non-VCM uses or exported from the United States. e

DLs were less than 1 ng/kg for all congeners in all samples.

DL = Detection limit.

EDC = Ethylene dichloride.

ND = Not detected.

PVC = Polyvinyl chloride.

VCM = Vinyl chloride monomer.

Source: The Vinyl Institute (1998).
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

8-43 DRAFT: DO NOT CITE OR QUOTE

Table 8-7. Annual releases in 2000 from stand-alone vinyl chloride plants (g I-TEQ/year)

Plant/Location Chemicals

On-site Off-site Transfersa

Air Water Landfill Landfarm Landfill Incineration

Occidental—Deer Park, TX VCM 0.581 0.031 0.474 22.2

Confidence Rating H/H H/H H/H H/H

Occidental—LaPorte, TX VCM 0.039 0.0064 5.1 44.4

Confidence Rating H/H H/H H/H H/H

Total 0.62 0.04 5.57 66.60

a

The off-site transfers represent the amount going to off-site facilities and not the amount released to the environment.

H = High Confidence.

Source: Dyke and Amendola, 2007.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

8-44 DRAFT: DO NOT CITE OR QUOTE

Table 8-8. CDD/CDF concentrations (mg/kg) in mono-through tetrachlorophenols

Congener/

congener 

group 2-CPa 2,4-DCPa 2,6-DCPa 2,4,5-TrCP

(Na salt)a 2,4,5-TrCPa 2,4,6-TrCPa 2,4,6-TrCP(Na salt)b 2,3,4,6-TeCPa 2,3,4,6-TeCP(Na salt)b

Total TCDD

Total PeCDD

Total HxCDD

Total HpCDD

Total OCDD

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02) to 14

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02) to 6.5

ND (0.02) to 1.5

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02) to 49

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

<0.02

<0.03

<0.03

<0.1

<0.1

ND (0.02)

ND (0.02)

ND (0.02) to 15

ND (0.02) to 5.1

ND (0.02) to 0.17

0.7

5.2

9.5

5.6

0.7

Total TCDF

Total PeCDF

Total HxCDF

Total HpCDF

Total OCDF

+

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

+

+ 

+ 

ND

ND

1.5

17.5

36

4.8

--

+

+ 

+ 

+ 

+

0.5

10

70

70

10

TOTAL -- -- -- -- -- -- -- -- --

a

Source: Firestone et al. (1972); because of poor recoveries, the authors stated that actual CDD/CDF levels may have been considerably higher than those 

reported.

b

Sources: Rappe and Marklund (1978); Rappe et al. (1978); common Scandinavian commercial chlorophenols.

ND = Not detected (value in parenthesis is the detection limit, if reported).

+ = Detected but not quantified.

-- = No information given.
This document is a draft for review purposes only and does not constitute Agency policy

1/7/2013 8-45 DRAFT: DO NOT CITE OR QUOTE

Table 8-9. Summary of specific dioxin-containing wastes that must comply 

with land disposal restrictionsa 

EPA 

hazardous 

waste number Waste description

Land disposal 

restriction effective 

date

Regulated 

waste 

constituent

F020 Wastes (except wastewater and spent carbon from 

HCl purification) from the production or 

manufacturing use (as a reactant, chemical 

intermediate, or component in a formulating 

process) of tri- or tetrachlorophenol or of 

intermediates used to produce their pesticide 

derivatives. (This listing does not include wastes 

from the production of hexachlorophene from 

highly purified 2,4,5-trichlorophenol.)

November 8, 1988 TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs

F021 Wastes (except wastewater and spent carbon from 

HCl purification) from the production or 

manufacturing use (as a reactant, chemical 

intermediate, or component in a formulating 

process) of pentachlorophenol or of intermediates 

used to produce its derivatives.

November 8, 1988 TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs

F022 Wastes (except wastewater and spent carbon from 

HCl purification) from the manufacturing use (as 

a reactant, chemical intermediate, or component in 

a formulating process) of tetra-, penta-, or 

hexachlorobenzenes under alkaline conditions.

November 8, 1988 TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs

F023 Wastes (except wastewater and spent carbon from 

HCl purification) from the production of materials 

on equipment previously used for the production 

or manufacturing use (as a reactant, chemical 

intermediate, or component in a formulating 

process) of tri- and tetrachlorophenols. (This 

listing does not include wastes from equipment 

used only for the production or use of 

hexachlorophene from highly purified 

2,4,5-trichlorophenol.)

November 8, 1988 TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs

F026 Wastes (except wastewater and spent carbon from 

HCl purification) from the production of materials 

on equipment previously used for the 

manufacturing use (as a reactant, chemical 

intermediate, or component in a formulating 

process) of tetra-, penta-, or hexachlorobenzene 

under alkaline conditions.

November 8, 1988 TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs
This document is a draft for review purposes only and does not constitute Agency policy

1/7/2013 8-46 DRAFT: DO NOT CITE OR QUOTE

Table 8-9. Summary of specific dioxin containing wastes that must comply 

with land disposal restrictionsa (continued)

EPA 

hazardous 

waste number Waste description

Land disposal 

restriction effective 

date

Regulated 

waste 

constituent

F027 Discarded unused formulations containing tri-, 

tetra-, or pentachlorophenol or discarded unused 

formulations containing compounds derived from 

these chlorophenols. (This listing does not 

include formulations containing hexachlorophene 

synthesized from prepurified 2,4,5-trichlorophenol 

as the sole component.)

November 8, 1988 TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs

F028 Residues resulting from the incineration or 

thermal treatment of soil contaminated with EPA 

Hazardous Wastes No. F020BF023, F026, and 

F027.

November 8, 1988 TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs

F039 Leachate (liquids that have percolated through 

land-disposed wastes) resulting from the disposal 

of more than one restricted waste classified as 

hazardous under Subpart D of 40 CFR 268. 

(Leachate resulting from the disposal of one or 

more of the following EPA hazardous wastes and 

no other hazardous wastes retains its EPA 

hazardous waste number[s]: F020, F021, F022, 

F026, F027, and/or F028.)

August 8, 1990

(wastewater)

May 8, 1992

(nonwastewater)

TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs

K043 2,6-Dichlorophenol waste from the production of 

2,4-D.

June 8, 1989 TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs

K099 Untreated wastewater from the production of 

2,4-D.

August 8, 1988 TCDDs

PeCDDs

HxCDDs

TCDFs

PeCDFs

HxCDFs

a

For wastewater, the treatment standard for all regulated waste constituents—except for PeCDFs—is 0.063 μg/L; the 

standard for PeCDFs is 0.035 μg/L. For nonwastewater, the treatment standard for all regulated waste constituents 

is 1 μg/kg. Treatment standards are based on incineration to 99.9999% destruction and removal efficiency.

Source: 40 CFR 268.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

8-47 DRAFT: DO NOT CITE OR QUOTE

Table 8-10. CDD/CDF concentrations (historical and current) (μg/kg) in technical-grade pentachlorophenol 

(PCP) products

Congener/

congener group 1973a 1978b 1979c 1984d 1985e 1986e 1987f 1987g 1985B88h 1991i 1988B99e 1988B99j Unknownk

2,3,7,8-TCDD

1,2,3,7,8-PeCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

OCDD

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

ND (10)

ND (10)

- 

2,200

100

100,000

610,000

ND (0.05)

ND (1)

6 

2,565

44

210,000

1,475,000

ND (0.05)

ND (1)

8 

1,532

28

106,000

930,000

ND (0.03)

1 

ND (1)

831

28

78,000

733,000

ND (0.05)

2 

ND (1)

1,480

53

99,900

790,000

ND (0.05)

ND (1)

8 

600

13

89,000

2,723,000

ND

ND

--

--

--

--

1,100,000

--

--

--

--

--

--

--

ND (0.5)

--

--

--

--

--

--

ND (10)

ND (10)

ND (10)

860

20

36,400

296,810

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

OCDF

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

130,000

--

--

--

--

--

--

--

--

--

--

ND (10)

--

--

--

--

--

--

--

--

130,000

ND (0.5)

ND (1)

ND (1)

49

5 

5 

ND (1)

34,000

4,100

222,000

ND (0.5)

ND (1)

ND (1)

34

4 

ND (1)

ND (1)

29,000

6,200

233,000

ND (0.1)

0.5

1.5

125

ND (1)

32

ND (1)

11,280

637

118,000

ND (0.1)

0.2

0.9

163

ND (1)

146

ND (1)

19,940

980

137,000

ND (0.5)

ND (1)

ND (1)

67

2 

ND (1)

ND (1)

22,000

3,400

237,000

ND

ND

ND

--

--

--

--

--

--

170,000

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

ND (10)

ND (10)

ND (10)

200

ND (20)

ND (20)

ND (20)

2,000

140

19,940

Total 2,3,7,8-CDD1

Total 2,3,7,8-CDF1

Total I-TEQDF1

Total WHO98 TEQDF1

--

--

--

--

--

--

--

--

--

--

--

--

712,300

130,000

1,970

1,304

1,687,615

260,159

4,445

2,918

1,037,568

268,238

2,735

1,689

811,860

130,076

1,853

1,088

891,435

158,230

2,321

1,488

2,812,621

262,469

4,173

1,509

1,100,000

170,000

∃1,270

>127 

--

--

--

--

--

--

--

--

334,090

22,280

810

525

Total TCDD

Total PeCDD

Total HxCDD

Total HpCDD

Total OCDD

Total TCDF

Total PeCDF

Total HxCDF

Total HpCDF

Total OCDF

ND (20)

ND (30)

5,500

98,000

220,000

40

250

22,000

150,000

160,000

--

--

--

--

--

900

4,000 

32,000

120,000

130,000

--

--

10,100

296,000

1,386,000

--

1,400

9,900

88,000

43,000

ND (10)

ND (10)

4,500

135,000

610,000

ND (10)

--

--

62,000

130,000

ND

ND

4,694

283,000

1,475,000

6 

10

1,982

125,000

222,000

ND

ND

2,925

134,000

930,000

ND

3 

1,407

146,000

233,000

1.9

6.5

1,700

154,000

733,000

0.8

141

4,300

74,000

118,000

0.4

15.2

3,300

198,000

790,000

0.4

343

13,900

127,000

137,000

ND

ND

912

117,000

2,723,000

ND

200

1,486

99,000

237,000

ND (10)

ND (10)

8,900

130,000

1,100,000

ND (10)

ND (10)

14,000

36,000

170,000

ND (1)

ND (10)

1,440

55,560

--

ND (10)

ND (10)

3,070

36,530

--

ND

3 

1,490

48,430

191,700

48

520

13,650

76,090

136,310

--

--

--

--

--

--

--

--

--

--

Total CDD/CDFl 655,790 286,900 1,834,400 941,500 2,111,692 1,447,335 1,085,150 1,269,559 3,178,598 1,458,900 960,000 468,241 --
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

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Table 8-10. CDD/CDF concentrations (historical and current) (μg/kg) in technical-grade pentachlorophenol 

(PCP) products (continued)

a

Source: Buser and Bosshardt (1976); mean of 10 samples of Ahigh@ CDD/CDF-content PCP received from Swiss commercial sources in 1973. b

Source: Rappe et al. (1978); sample of U.S. origin, Apresumably prepared by alkaline hydrolysis of hexachlorobenzene.@ c

Source: NTP (1989); composite of technical-grade materials produced in 1979 by Monsanto Industrial Chemical Co. (St. Louis, MO), Reichhold Chemicals, Inc. 

(White Plains, NY), and Vulcan Materials Co. (Birmingham, AL).

d

Source: Cull et al. (1984); mean of four Arecent@ production batches from each of two manufacturers of technical PCP using three different analytical methods; 

analysis of variance (ANOVA) showed no statistically significant difference in CDD/CDF concentrations between the eight samples (samples obtained in the 

United Kingdom).

e

Source: Letter dated February 7, 1997, from John Wilkinson, Pentachlorophenol Task Force, to Matthew Lorber, U.S. EPA; average of monthly batch samples 

for the period January 1987 to August 1996.

f

Source: Hagenmaier and Brunner (1987); sample of Witophen P (Dynamit Nobel-Lot no. 7777) (obtained in Germany). g

Source: Hagenmaier and Brunner (1987); sample of PCP produced by Rhone Poulenc (obtained in Germany). h

Source: Letter dated February 7, 1997, from John Wilkinson, Pentachlorophenol Task Force, to Matthew Lorber, U.S. EPA; samples of Apenta@ manufactured in 

1985, 1986, and 1988.

i

Source: Harrad et al. (1991); PCP-based herbicide formulation from the New York State Department of Environmental Conservation.

j

Source: Letter dated March 5, 1997, from Thomas Mitchell, KMG-Bernuth, to Matthew Lorber, U.S. EPA; average of monthly batch samples for the period 

February 1987 to December 1996 (excluding the following months, for which data were not available: February 1993, January 1992, December 1991, September 

1991, December 1988, and September 1988).

k

Source: Schecter et al. (1997); sample found stored in a barn in Vermont. l

Calculated assuming nondetects were zero.

ND = Not detected (value in parenthesis is the detection limit).

-- = No information given.
This document is a draft for review purposes only and does not constitute Agency policy

1/7/2013 8-49 DRAFT: DO NOT CITE OR QUOTE

Table 8-11. Historical CDD/CDF concentrations (μg/kg) in 

pentachlorophenol-Na (PCP-Na)

Congener/congener 

group 1969a 1973b 1973c 1987d 1987e 1992f 1980sg

2,3,7,8-TCDD

1,2,3,7,8-PeCDD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

OCDD

--

--

--

--

--

--

3,600

--

--

--

--

--

--

--

--

--

--

--

--

--

--

0.23

18.2 

28.3 

2,034 

282 

9,100 

41,600

0.51

3.2 

13.3 

53 

19 

3,800 

32,400

0.076

18.7 

96 

4,410 

328 

175,400 

879,000

ND (1.4)

28.3 

ND (6.1) 

4,050 

ND (1.4) 

33,800 

81,000

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

OCDF

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

--

1.8

8.2 

6.6 

48 

69 

ND (1)

87 

699 

675 

37,200

0.79

1.9 

1.1 

4.6 

1.3 

1.3 

4.6 

197 

36 

4,250

ND (1)

ND (4)

ND (4)

27.6 

21.9 

9.8 

103 

9,650 

2,080 

114,600

149

319 

324 

ND (2.8) 

225 

480 

ND (385) 

6,190 

154 

36,000

Total 2,3,7,8-CDDh

Total 2,3,7,8-CDFh

Total I-TEQDF

h

Total WHO98 TEQDF

h

--

--

--

--

--

--

--

--

--

--

--

--

53,062.7

38,794.6 

452 

390

36,289

4,498.6 

89.5 

58.1

1,059,252.8

126,492.3 

3,374 

2,489

118,878.3

43,841 

1,201 

1,110

Total TCDD

Total PeCDD

Total HxCDD

Total HpCDD

Total OCDD

Total TCDF

Total PeCDF

Total HxCDF

Total HpCDF

Total OCDF

--

--

17,000 

9,600 

3,600 

--

--

--

--

--

140

40 

140 

1,600 

4,000 

ND (20)

60 

1,400 

4,300 

4,300

50

ND (30)

3,400 

38,000 

110,000 

ND (20)

40 

11,000 

47,000 

26,500

27

213 

3,900 

18,500 

41,600 

82 

137 

3,000 

13,200 

37,200

52

31 

230 

5,800 

32,400 

12 

27 

90 

860 

4,250

3.6

142.7 

9,694 

260,200 

879,000 

10.1 

88.4 

9,082.3 

75,930 

114,600

1.9

140 

14,000 

100,000 

81,000 

1,200 

6,400 

49,000 

91,000 

36,000

Total CDD/CDFh 30,200 15,980 235,990 117,859 43,752 1,348,751 378,742

a

Source: Firestone et al. (1972); mean of two samples of PCP-Na obtained in the United States between 1967 and 

1969.

b

Source: Buser and Bosshardt (1976); mean of five samples of Alow@ CDD/CDF-content PCP-Na received from 

Swiss commercial sources.

c

Source: Buser and Bosshardt (1976); sample of Ahigh@ CDD/CDF-content PCP-Na received from a Swiss 

commercial source.
This document is a draft for review purposes only and does not constitute Agency policy

1/7/2013 8-50 DRAFT: DO NOT CITE OR QUOTE

Table 8-11. Historical CDD/CDF concentrations (μg/kg) in pentachlorophenol 

Na (PCP Na) (continued)

d

Source: Hagenmaier and Brunner (1987); sample of Dowicide-G purchased from Fluka; sample obtained in 

Germany.

e

Source: Hagenmaier and Brunner (1987); sample of Preventol PN (Bayer AG); sample obtained in Germany. f

Source: Santl et al. (1994); 1992 sample of PCP-Na from Prolabo, France. g

Source: Palmer et al. (1988); sample of a PCP-Na formulation collected from a closed sawmill in California in the 

late 1980s.

h

Calculated assuming nondetect values were zero.

ND = Not detected (value in parenthesis is the detection limit).

-- = No information given.

. 
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 8-12. CDD/CDF concentrations (μg/kg) in chlorobenzenes

Congener/ 

congener group MCBza

1,2-DCBz

(for 

synthesis)a

1,2,4-TrCBz

(Apure@)

b

Mixed 

TrCBz

(47%)a

1,2,4,5-TCBz

(99%)a

PeCBz

(98%)a

HCBz

(97%)a HCBzb

Total TCDD

Total PeCDD

Total HxCDD

Total HpCDD

Total OCDD

Total TCDF

Total PeCDF

Total HxCDF

Total HpCDF

Total OCDF

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

0.3

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.02)

0.5

ND (0.02)

ND (0.02)

ND (0.02)

ND (0.1)

ND (0.1)

ND (0.1)

ND (0.1)

ND (0.1)

ND (0.1)

ND (0.1)

ND (0.1)

ND (0.1)

ND (0.1)

0.027

0.14

0.259

0.253

0.081

0.736

0.272

0.091

0.03

0.016

ND (0.02)

0.2

0.5

0.8

0.4

0.03

0.2

0.8

1.5

2.1

ND (0.02)

ND (0.02)

0.02

0.02

0.05

0.02 

ND (0.02)

ND (0.02)

0.1

0.1

ND (20)

ND (20)

ND 

(20)470

6,700

ND (20)

ND (20)

ND (20)

455

2,830

--

--

--

--

50B212,000

--

--

--

--

350B58,300

Total CDD/CDF ND 0.8 ND 1.9 6.5 0.3 10,455 400B270,300

a

Source: Hutzinger and Fiedler (1991b); unpublished results of tests performed at the University of Bayreuth, Germany, and by Dr. H. Hagenmaier. b

Source: Villanueva et al. (1974); range of three samples of commercially available HCBz.

ND = Not detected (value in parenthesis is the detection limit, if reported). 

-- = No information given.
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 8-13. Annual releases in 2000 from complex plants producing chlorine and a variety of chlorinated 

organics (g I-TEQ/year)

Plant/Location Chemicals

On-site Off-site transfersa

Air Water Landfill Landfarm Landfill Incineration

Dow Chemical—Midland MI Ag chemicals, polymers, others 0.046 0.037 12.6

Confidence Rating H/H H/H H/H

Dow Chemical—Plaquemine, LA Chlorine, EDC, others 0.092 7.71 12.8

Confidence Rating H/H H/H H/H

Dow Chemical—Freeport, TX Chlorine, EDC, VCM, solvents, others 3.08 6.91 89.3

Confidence Rating H/H H/H H/H

Company A, Plant A1 Chlorine, EDC, VCM, others 0.068 0.023 1.45 1.5 2.18

Confidence Rating H/H H/H H/H H/H H/H

Occidental—Convent, LA Chlorine, NaOH, EDC 0.022 0.002 0.081 12.1

Confidence Rating R/H LR/H H/H R/H

Occidental—Ingleside, TX Cl2 (diaphragm-cell), NaOH, EDC, VCM 1.61 0.018 1.47

Confidence Rating RH/H H/H H/H

PPG Industries—Lake Charles, LA Cl2 (mercury-/diaphragm-cell), hydrogen, 

NaOH, EDC, and VCM

0.02 8.98 0.303 8.66

Confidence Rating H/H H/H H/H H/H

Company B, Plant B1 Cl2, solvents, other chlorinated organics 0.037 1.07 0.208

Confidence Rating R/H R/H

Occidental—Niagara Falls Cl2, NaOH, organic chemicals 3.80 × 10–3 1.40 × 10–3 0.028 210

Confidence Rating H/H H/H R/H R/H

Company B, Plant B2 Cl2, EDC, solvents 8.38 × 10–3 3.72 × 10–1
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

8-53 DRAFT: DO NOT CITE OR QUOTE

Table 8-13. Annual Releases in 2000 from complex plants producing chlorine and a variety of chlorinated organics 

(g I-TEQ/year) (continued)

Plant/Location Chemicals

On-Site Off-site Transfersa

Air Water Landfill Landfarm Landfill Incineration

Confidence Rating R/H R/H

Total 4.99 25.12 114.70 1.45 3.38 233.15

a

The off-site transfers represent the amount going to off-site facilities not the amount released to the environment.

H = High.

R = Reasonable.

L = Low.

Source: Dyke and Amendola (2007).
This document is a draft for review purposes only and does not constitute Agency policy

1/7/2013 8-54 DRAFT: DO NOT CITE OR QUOTE

Table 8-14. CDD/CDF mean concentrations (ng/kg) measured in the 2001 

National Sewage Sludge Survey 

Congener

Nondetect set to 

1⁄2 detection limit

Nondetect set to

zero

2,3,7,8-TCDD

1,2,3,7,8-PeCD

1,2,3,4,7,8-HxCDD

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

OCDD

1.41

5.76 

11.8 

21.3 

3.6 

492 

6,780

1.1

4.57 

7.49 

15.1 

2.22 

273 

2,730

2,3,7,8-TCDF

1,2,3,7,8-PeCDF

2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF

1,2,3,6,7,8-HxCDF

1,2,3,7,8,9-HxCDF

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

1,2,3,4,7,8,9-HpCDF

OCDF

3.11

2.61 

6.03 

1.37 

0.27 

5.21 

5.5 

9.13 

167 

802

2.3

1.5 

2.8 

1 

0 

2.6 

3.36 

2.8 

88.2 

279

Average total WHO98 TEQDF

Average total I-TEQDF

23

27

14

15

Source: EPA (2002d).
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013

8-55 DRAFT: DO NOT CITE OR QUOTE

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

2,3,7,8-TCDD

1,2,3,7,8-PeCDD

1,2,3,4,7,8-HxCDD1,2,3,6,7,8-HxCDD1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

OCDD

2,3,7,8-TCDF

1,2,3,7,8-PeCDF2,3,4,7,8-PeCDF

1,2,3,4,7,8-HxCDF1,2,3,6,7,8-HxCDF1,2,3,7,8,9-HxCDF2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF1,2,3,4,7,8,9-HpCDF

OCDF

Percent Total CDDs and CDFs

Congener

Figure 8-1. Congener profile for technical-grade PCP (developed from data in last column in Table 8-10). 
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 9-1 DRAFT: DO NOT CITE OR QUOTE

1 9. NATURAL SOURCES OF CDDS/CDFS

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

Numerous laboratory and field research studies have demonstrated that biochemical and 

photolytic formation of CDDs/CDFs from chlorophenol precursors is possible. In addition, 

under certain conditions, some CDDs/CDFs can be biodegraded to form less-chlorinated (and 

possibly more toxic) CDDs/CDFs. Both of these mechanisms are discussed in this chapter; 

however, the extent to which CDDs/CDFs are formed by either mechanism in the environment is 

unknown at present. The potential for releases of CDDs/CDFs from the application of animal 

manure to farmland and the mining and use of ball clay are also discussed. Forest fires could be 

considered a potential natural source, but it was decided that the discussion fit better in Chapter 6 

on minimally and uncontrolled combustion sources. Similarly, volcanoes were discussed in 

Chapter 6 where it indicates that no studies have demonstrated the formation of CDDs/CDFs by 

volcanoes. 

9.1. BIOTRANSFORMATIONS

9.1.1. Biotransformation of Chlorophenols 

 As discussed in the original report, the biochemical formation of CDDs/CDFs—

particularly the higher-chlorinated congeners―from chlorophenol precursors is possible, as 

indicated in laboratory studies with solutions of trichlorophenols and PCP in the presence of 

peroxidase enzymes and hydrogen peroxide. However, the extent to which CDDs/CDFs are 

formed in the environment via this mechanism cannot be estimated at this time.

 UNEP (2005) suggests the following emission factors for composted materials: garden 

and kitchen wastes―15 ng I-TEQ/kg dry matter, and green materials from unimpacted

environments―5 ng I-TEQ/kg dry matter. The discussion indicates that some very high levels 

(approximately 100 ng I-TEQ/kg dry matter) have been observed in compost as a result of 

contaminated input. 

 Products from composting operations are typically land spread and have the potential to 

be a land release. However, insufficient information is available on emission factors and 

activities to make release estimates for composting or other potential sources involving 

biotransformation of chlorophenols (Not quantifiable). 
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 9-2 DRAFT: DO NOT CITE OR QUOTE

Biotransformation of Chlorophenols

Releases to Soil

Not quantifiable.

1 9.1.2. Biotransformation of Higher CDDs/CDFs 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

 As discussed in the original report, results of several studies that examined the fate of a 

range of CDD/CDF congeners in pure cultures, sediments, and sludges indicate that under 

certain conditions, some CDD/CDF congeners will undergo biodegradation to form 

lower-chlorinated (and possibly more toxic) CDDs/CDFs. However, the extent to which more 

toxic CDDs/CDFs are formed in the environment via this mechanism cannot be estimated at this 

time. 

Therefore, these releases are not quantifiable.

Biotransformation of Higher CDDs/CDFs

Releases to Soil

Not quantifiable.

9.1.3. Biotransformation of Animal Manure

 Because livestock and poultry manure can provide valuable organic material and 

nutrients for crop and pasture growth, most of the animal manure generated at commercial farms 

and animal feed lots is applied to farmland as fertilizer. To the extent dioxin-like compounds 

may contaminate animal manures, the practice of land-spreading animal waste may result in 

releases of CDDs/CDFs to the open and circulating environment. 

 Mass balance studies have shown that no new formation of dioxins and furans appears to 

occur within a cow (Winters et al., 2000; Lorber et al., 2000; McLachlan et al., 1990). These 

studies have involved measuring the dioxins present in the feeds provided to dairy cows and then 

measuring the dioxins in the cow milk, feces, and urine in carefully controlled settings. Studies 

by EPA (Winters et al., 2000; Lorber et al., 2000) involved four cows, sampled three times 

between July and November of 1997. Preliminary testing on urine showed nondetects as 

expected, so this matrix was not included in further testing. The tests were designed to represent 

typical conditions (feed types, dairy cow housing, etc.) in the United States with regard to the 

production of milk. The feed and feces concentrations ranged from 0.13 to 
This document is a draft for review purposes only and does not constitute Agency policy. 

1/7/2013 9-3 DRAFT: DO NOT CITE OR QUOTE

1 0.30 ng WHO98 TEQDF/kg dry weight basis, and milk concentrations ranged from 0.53 to 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

0.96 ng WHO98 TEQDF/kg lipid basis. The feces concentrations in these lactating cows were 

about one order of magnitude lower than that measured by Stevens and Jones (2003) in the 

United Kingdom (U.K.) (see Table 9-1). A mass balance was determined by dividing the mass 

of CDD/CDFs present in feces and milk by the mass in the feed and then multiplying by 100% (a 

finding of 100% suggests that the dioxins excreted in milk and feces equals that in the feed; a 

finding greater than 100% suggests formation). These matrices were sampled once the cows 

were well into lactation, so an assumption of steady state was reasonable. The mass balance of 

both TEQs and individual congeners ranged from about 50 to 100%, suggesting no internal 

formation of CDD/CDFs by the cows. The average mass balance over 17 congeners was 73%. 

McLachlan et al. (1990) conducted a similar experiment with one cow in a background setting 

and also found mass balances between 50 and 100%, with an average of 75% over all 

17 CDD/CDF congeners.

 As discussed in the original report, reasonably good data are available on the generation 

rates of livestock manure. However, limited data are available on CDD/CDF levels in livestock 

manure. Further, mass balance studies on lactating cows suggest that no new formation of 

CDD/CDFs are occurring. Thus, while the land application of farm animal manure is a potential 

land release, it is concluded that insufficient data are available to quantify these releases, and 

because of the mass balance studies, these may be better characterized as a redistribution rather 

than a new formation. Accordingly, EPA currently considers this source to be unquantifiable in 

terms of dioxin emissions.

Biotransformation of Animal Manure

Releases to Soil

Not quantifiable.

9.2. PHOTOCHEMICAL TRANSFORMATIONS 

 A number of researchers have demonstrated that CDD/CDFs can be formed via various 

types of photochemical transformations. 
This document is a draft for review purposes only and does not constitute Agency policy. 

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1 9.2.1. Photolysis of PCP

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

 As discussed in the original report, several studies have demonstrated that photolysis of 

PCP may lead to the formation of CDD/CDFs; however, the information is considered 

inadequate to estimate releases of CDD/CDFs to the environment. 

Photolysis of PCP

Releases to Wood or Air

Not quantifiable.

9.2.2. Photolysis of Higher CDDs/CDFs

 As discussed in the original report, a number of studies have demonstrated that photolysis 

of higher CDD/CDFs may lead to the formation of CDD/CDFs; however, the information is 

considered inadequate to estimate releases of CDD/CDFs to the environment.

Photolysis of Higher CDDs/CDFs

Releases to Air, Water, or Soil

Not quantifiable.

9.2.3. Photolysis in Water 

 As discussed in the original report, a number of studies have demonstrated that photolysis 

in water may lead to the formation of CDD/CDFs; however, the information is considered 

inadequate to estimate releases of CDD/CDFs to the environment.

Photolysis in Water

Releases to Water

Not quantifiable.

9.2.4. Photolysis on Soil Surfaces

 As discussed in the original report, studies have demonstrated that photolysis on soil 

surfaces may lead to the formation of CDD/CDFs; however, the information is considered 

inadequate to estimate releases of CDD/CDFs to the environment.

Photolysis on Soil

Releases to Soil

Not quantifiable.
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1 9.2.5. Photolysis on Vegetation 

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 As discussed in the original report, studies have demonstrated that photolysis on 

vegetation may lead to the formation of CDD/CDFs; however, the information is considered 

inadequate to estimate releases of CDD/CDFs to the environment.

Photolysis on Vegetation

Releases to Biota

Not quantifiable.

9.2.6. Photolysis in Air

 As discussed in the original report, studies have demonstrated that photolysis in air may 

lead to the formation of CDD/CDFs; however, the information is considered inadequate to 

estimate releases of CDD/CDFs to the environment.

Photolysis in Air

Releases to Air

Not quantifiable.

9.3. CDDS/CDFS IN BALL CLAY

 As discussed in the original report, studies have demonstrated that CDD/CDFs are found 

naturally in ball clay. Releases from ball clay may occur when it is disturbed during mining and 

subsequent processing. Accordingly, such releases have both a natural and an anthropogenic 

aspect to them. Multiplication of the mean WHO98 TEQDF concentration in mined ball clay by 

the total amount of ball clay mined in 1995 gives an estimate of 1,502 g WHO98 TEQDF

(U.S. EPA, 2006). It is unknown how much of these CDD/CDFs contained in mined ball clay 

are released to the environment during the mining, initial refining, and product handling. Most 

ball clay is used to produce ceramic products where releases may occur from processes such as 

drying or high-temperature vitrification. The temperatures found in ceramic kilns vary but can 

reach levels needed for both volatilization and destruction of CDD/CDFs. No stack 

measurement data are available from these facilities, so there is insufficient evidence to make 

even a preliminary estimate of releases.
This document is a draft for review purposes only and does not constitute Agency policy. 

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Ball Clay

Releases to Air

Not quantifiable.
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Table 9-1. CDD and CDF concentrations (ng/kg dry weight) in samples of animal manure in the United Kingdom 

Congener (n

a Cows

= 6) (mean) (n

b Cows

= 10) (mean)

a Sheep

(n = 1) 

a Pig

(n = 1) 

a Chicken

(n = 1) 

2,3,7,8-TCDD 0.17 0.02 0.11 0.01 0.01 

1,2,3,7,8-PeCDD 0.46 0.04 0.41 0.07 0.04 

1,2,3,4,7,8-HxCDD 2.4 0.06 0.9 0.26 0.03 

1,2,3,6,7,8-HxCDD 4.5 0.15 0.86 0.1 0.09 

1,2,3,7,8,9-HxCDD 2.6 0.11 0.56 0.07 0.12 

1,2,3,4,6,7,8-HpCDD 120 3.6 9.4 0.8 1.4 

OCDD 460 58 53 11 14 

Total 2,3,7,8-CDD 590.1 62.3 65.2 12.3 15.7 

2,3,7,8-TCDF 0.3 0.05 1.2 0.03 0.03 

1,2,3,7,8-PeCDF 0.3 0.04 1.1 0.04 0.09 

2,3,4,7,8-PeCDF 0.28 0.06 1.2 0.06 0.12 

1,2,3,4,7,8-HxCDF 0.6 0.18 1.4 0.05 0.15 

1,2,3,6,7,8-HxCDF 0.51 0.12 1.1 0.06 0.07 

1,2,3,7,8,9-HxCDF 1.9 0.05 0.15 0.04 0.05 

2,3,4,6,7,8-HxCDF 0.4 0.16 1.4 0.06 0.14 

1,2,3,4,6,7,8-HpCDF 7.6 1.8 5.2 0.48 0.37 

1,2,3,4,7,8,9-HpCDF 12 0.17 0.56 0.04 0.09 

OCDF 35 2.4 5 0.73 0.8 

Total 2,3,7,8-CDF 58.9 5.0 18.3 1.6 1.9 

Total CDD/CDF 649 67.4 83.5 13.9 17.6 

WHO98 TEQ 3.6 0.2 2.1 0.2 0.2 

Sources: a

Stevens and Jones (2003); bPersonal communication, M. Lorber (2008), who provided the raw data for the study summarized in Lorber et al. (2000). 

The data reflect four cows sampled three times; n = 10 instead of 12 because two cows in one sampling date were exposed to feed purposefully contaminated 

with PCP-treated wood shavings. 
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1 10. SOURCES OF DIOXIN-LIKE POLYCHLORINATED BIPHENYLS (PCBS)

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This chapter estimates releases of dioxin-like PCB congeners to the environment. PCB 

releases from media reservoirs (i.e., soil, sediment, and water) are covered in Chapter 11. This 

chapter covers other PCB sources, primarily conventional point sources. These sources are 

assumed to have contemporary formation releases. This is uncertain, though, because some 

portion of these releases may be passed through from inputs to outputs rather than new 

formation. Both Chapters 10 and 11 contain information on releases associated with PCB 

products. 

10.1. GENERAL FINDINGS OF THE EMISSIONS INVENTORY

The primary changes to this chapter include the addition of several new source

categories, addition of background information to a number of the other sources, and minor 

changes to the release estimates. Additionally, the release summary table (see Table 10-1) has 

been reformatted to match the new one used for CDD/CDFs. 

Relatively few sources have well-characterized releases of dioxin-like PCBs. As shown 

in Table 10-1, 2 sources had quantitative release estimates, 6 sources had preliminary release 

estimates and 9 sources were identified as being unquantifiable. Although the information is 

limited, it suggests that, in terms of TEQs, PCB releases are much lower than CDD/CDF 

releases. 

Two potential source categories that could not be addressed are contaminated PCB sites 

and wastes with less than 50-ppm PCB (which are not regulated under TSCA). No information 

was found that would allow evaluation of releases from these sources.

The original report concluded that it is likely that no significant releases of newly formed 

dioxin-like PCBs are occurring in the United States. This is based on three arguments. First, 

although the data are limited, the inventory presented here suggests that new releases are low in 

comparison to the amounts currently present in the environment. As shown in Table 10-1, the 

total quantitative release estimates for 2000 sum to only about 30 g WHO98 TEQP/year to air and 

20 g WHO98 TEQP/year to land. As discussed in Chapter 11, the surface soils in the United 

States are estimated to contain about 95 kg of PCB TEQs. Also, the release estimates may 

overestimate new releases because some portion may be passed through from inputs to outputs 
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1 rather than new formation. Second, the new releases appear low compared to past releases 

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associated with PCB production, use, and disposal. As discussed in Section 10.7, an estimated 

3,702 kg of WHO98 TEQP were released directly to the U.S. environment between 1930 and 

1977. Third, North American sediment studies have shown decreasing PCB levels since the 

1980s (Lebeuf et al., 1995; Cleverly et al., 1996), indicating that releases of newly formed PCBs 

are not large enough to prevent this decline. Accordingly, the original statement is still believed 

to likely be true, but it is acknowledged to be uncertain because releases could be estimated for 

only a few sources. 

10.2. RELEASES FROM COMMERCIAL PCB PRODUCTS

10.2.1. Approved PCB Disposal/Destruction Methods

As discussed in the original report, landfilling and incineration can be used as disposal 

methods for PCBs. It is assumed that the amounts landfilled would not represent an 

environmental release. The incineration facilities achieve a high combustion efficiency, but 

some releases are possible. The original report summarizes TRI information on total PCB 

releases to air, surface water, and land. Insufficient information was available to convert these 

releases to TEQ estimates. 

PCB Incineration

Releases

Not quantifiable.

10.2.2. Releases of In-Service PCBs

As discussed in the original report, insufficient information is available to make 

quantitative release estimates occurring from in-service PCBs. No changes were made to this 

conclusion, but some additional background information on accidental fires is provided below. 

Also, this section was expanded to include nonaccidental releases of in-service PCBs. 

A variety of PCB products can remain in use for long time periods, such as paint, caulk, 

transformers, and capacitors. Releases from these products can occur via vaporization or leaks 

or during disposal operations. As discussed in the original report (see Section 10.6), 

approximately 568,000 MT of PCBs were used in the United States between 1930 and 1975. An 
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1 estimated 50.3% were used in capacitors, and 26.8% were used in transformers. Assuming that 

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these products contained an average of 8 mg WHO98 TEQP/kg (average concentration for 

Aroclor 1242, which accounted for over 50% of total sales―see Section 10.6 of original report), 

then a total of 3,500 kg of WHO98 TEQP were used in capacitors and transformers. It is 

unknown how much of this material is still in use today or what amount of releases may be 

occurring. Note that these products can be considered reservoirs because the releases can occur 

after their initial use, so they are also discussed in Chapter 11. 

A report by the Environment Agency in the United Kingdom assessed the importance of 

releases of PCBs from various sources (Dyke, 2002). This report concluded that leaks from 

capacitors and transformers are likely to be the largest source of PCB releases occurring 

currently, although this is expected to decline as these devices are taken out of service and 

disposed. Leaks from electrical equipment were estimated to account for 80% of the total PCB 

releases occurring in the United Kingdom in 1998 (Dyke, 2002). 

A number of PCB transformer fires have occurred in the United States, leading to PCB 

contamination of the interiors of office buildings (Michaud et al., 1994). Soot can be produced 

in large amounts, consisting of particles that may contain PCB concentrations up to 

5,000−8,000 mg/kg of soot (Michaud et al., 1994). The following are several examples of PCB 

fires in office buildings. 

In the case of a transformer fire in the basement of the New York State office building in 

Binghamton, NY, the circulation of PCB-contaminated soot particles resulted in an average 

interior surface concentration of 162 mg/m2 (expressed as the equivalent Aroclor 1254 

concentration) (Erickson, 1997). Additionally, the soot samples from the Binghamton PCB fire 

contained about 20 mg/g and 700 mg/g of total CDDs and total PCDFs, respectively (Erickson, 

1997). In 1985, a PCB transformer fire occurred in the basement transformer vault in the main 

building of the New Mexico State Highway Department Office Building (CDC, 1985). Interior 

air concentrations of PCBs in the transformer vault were found to average about 48 μg/m3

. 

Surface wipes on horizontal surfaces had PCB concentrations ranging from 4,700 to 

30 million μg/m2. Other notable U.S. transformer fires include the office building at 

1 Marke Plaza in San Francisco in 1983, the Saniford Street office building in Boston in 1981, 

and the Page Belcher building in Tulsa (Michaud et al., 1994). In these fires, indoor air PCB 

concentrations ranged from 140 to 1,500 μg/m3

; interior surfaces to the buildings ranged from 
This document is a draft for review purposes only and does not constitute Agency policy.

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20−90 μg/m2 total PCBs. TCDF concentrations ranged from 4−30 pg/m3 1 in the indoor office air 

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and from 200−700 ng/m

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 to interior surfaces. 

Releases of In-Service PCBs

Releases

Not quantifiable.

10.3. CHEMICAL MANUFACTURING AND PROCESSING SOURCES

The original report discussed Municipal Wastewater Treatment under Section 10.2. In 

this update, it has been moved to this section because these facilities are not associated with 

commercial PCB products and do conduct a type of chemical processing. Minor changes were 

made to the release estimates as summarized below.

For reference years 1987 and 1995, the concentration of dioxin-like PCBs that may be 

present in sewage sludge was estimated as 24.3 ng WHO98 TEQP/kg. This is based on the 1994 

survey of 74 plants as reported by Green et al. (1995) and Cramer et al. (1995). For reference 

year 2000, the concentration of dioxin-like PCBs that may be present in sewage sludge was 

estimated as 5.22 ng WHO98 TEQP/kg. This is based on the 2001 survey of 94 plants (U.S. EPA, 

2002d). The activity estimates were based on the 1988/1989 National Sewage Sludge Survey 

and the results of the 1984 to 1996 Clean Water Needs Surveys (U.S. EPA, 1999b). All 

beneficial uses were assumed to have the potential for release to the environment, resulting in 

increases in the product release estimates compared to the original report.

As discussed in EPA (2006), there is no clear evidence that other types of chemical 

manufacturing and processing facilities release dioxin-like PCBs. 

The inventory decision criteria and releases to all media are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy.

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Inventory Decision Criteria for Municipal Wastewater Treatment

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission factors. 

Yes

Measured emission factors consistent or have understandable 

differences. 

Yes

Emission factor tests represent units that are typical of the 

class. 

Yes

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). Q

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Municipal Wastewater Treatment

Soil Releases

Emission Factors 

• 1987―24 ng WHO98 TEQP/kg of sludge. 

• 1995―24 ng WHO98 TEQP/kg of sludge. 

• 2000―5.2 ng WHO98 TEQP/kg of sludge.

Activity Levels

• 1987―2.1 MMT of sludge. 

• 1995―3.2 MMT of sludge. 

• 2000―3.6 MMT of sludge.

Releases

• 1987―51 g WHO98

• 1995―78 g WHO98

• 2000―19 g WHO98

TEQP. 

TEQP. 

TEQP.

Product Releases

Emission Factors 

• 1987―24 ng WHO98 TEQP/kg of sludge. 

• 1995―24 ng WHO98 TEQP/kg of sludge. 

• 2000―5.2 ng WHO98 TEQP/kg of sludge.

Activity Levels

• 1987―0.07 MMT of sludge. 

• 1995―0.5 MMT of sludge. 

• 2000―0.5 MMT of sludge.

Releases

• 1987―2 g WHO98 TEQP. 

• 1995―12 g WHO98 TEQP. 

• 2000―3 g WHO98 TEQP.
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1 10.4. COMBUSTION SOURCES

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10.4.1. Municipal Waste Combustion 

The 2006 report concluded that insufficient information was available to develop 

quantitative release estimates from municipal waste incinerators. A number of additional studies 

are presented below that allow making preliminary estimates.

Dyke (2002) provides a review of PCB emission factors for municipal waste incinerators. 

These vary from 0.000027 to 14 ng TEQP/kg. Dyke et al. (2003) provide a similar literature 

survey of 1990’s data on incinerator emissions and fly ash concentrations of concurrently 

measured dioxin-like PCBs and CDD/CDF TEQ. Their literature summary supports the 

observation that WHO98 TEQP emission concentrations from MWCs are an order of magnitude 

and more lower than WHO98 TEQDF. They also provide some PCB emission factors from these 

references, showing a fairly wide range from as low as 0.0085 to as high as 

25.6 μg WHO98 TEQP/MT. Finally, they provide results of their own testing on two MWCs with 

different levels of pollution control. For one MWC, three of four tests were nondetect for all 

14 PCBs measured and the other test showed some positive concentrations. For the second 

MWC, two tests had positive measurements for PCB-114, PCB-118, PCB-123, and PCB-180. 

The range of reported WHO98 TEQP emission concentrations was between 0 (assuming ND = 0) 

and 0.016 ng WHO98 TEQP/Nm3

 (assuming ND = QL). 

Sakai et al. (1999) found that the input of coplanar PCBs into the municipal solid waste

incineration facilities in Kyoto City (Japan) was 0.13–0.29 mg-TEQ per ton waste, the total 

output of coplanar PCBs (the sum released from emission gas, fly ash, and bottom ash) was 4.9 

mg TEQ per ton waste. The PCB emission factor for gas releases was reported to be 1.2 μg 

TEQ/ton of waste burned. They reported PCB concentrations in fly ash of 0.053 ng TEQ/g and in 

bottom ash as 0.000023 ng TEQ/g. 

CDD/CDFs and dioxin-like PCBs were measured in the emissions from an MWC in 

Madrid, Spain, which was equipped with a high level of pollution control (Abad et al., 2006). 

Over 16 samples, CDD/CDF emissions averaged 0.047 ng I-TEQ/Nm3

, and dioxin-like PCBs 

added an average of 0.0015 ng I-TEQ/Nm3

, with most of this dioxin-like PCB contribution from 

PCB-126. 

Eight incinerators, including two commercial MWCs, were sampled for CDD/CDFs, 

PCBs, and HCB in a study conducted in Japan (Kim et al., 2004a). The average concentration 
This document is a draft for review purposes only and does not constitute Agency policy.

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over all eight incinerators was 0.281 ng WHO98 TEQDF/Nm3 1 for CDD/CDFs and 

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0.023 ng WHO98 TEQP/Nm3 for PCBs, suggesting a factor of difference of 10 on average. The 

disparity from one of the two MWC incinerators was 0.069 ng WHO98 TEQDF/Nm3 for 

CDD/CDF and 0.009 ng WHO98 TEQP/Nm3 for PCBs. Emissions were much lower for the other 

MWC, with reported TEQ concentrations uninformative at 0.000 ng WHO98 TEQDFP/Nm3

. 

Francois et al. (2005) provide side-by-side measurements of CDD/CDFs and dioxin-like 

PCBs, which contradict the observations provided by Dyke et al. (2003). Francois et al. (2005) 

reports on testing at 15 incinerators including three MWCs in Belgium. The dioxin-like PCBs 

often dominated the overall TEQ emissions. For example, the average shares of the dioxin-like 

PCBs to total TEQ were 22, 34, and 97% for the three MWCs. The stack concentrations of 

dioxin-like PCBs were 0.0008, 0.045, and 0.0034 ng WHO98 TEQP/Nm3

, compared to 

corresponding CDD/CDF concentrations of 0.0014, 0.0014, and 0.012 ng WHO98 TEQDF/Nm3. 

Based on these concentrations and other plant characteristics, annual dioxin-like PCB emissions 

were quantified in all of these plants at 0.4, 7.0, and 1.2 mg WHO98 TEQP/year. 

Kim et al. (2005) measured 209 congeners in stack emissions from nine facilities in 

Japan, including three MWCs. They did not measure CDD/CDFs, but their measured 

concentrations can be compared with other studies identified above. They detected PCBs at all 

facilities, with total PCBs ranging from 10−700 ng/Nm3 and coplanar PCBs in the range of 

1−25 ng/Nm3

 (0.008−0.324 ng WHO98 TEQP/Nm3). On a class basis, the average from the 

MWCs was the highest at 0.136 ng WHO98 TEQP/Nm3

. 

The PCB emission factor for municipal waste incinerators was assumed to equal the 

geometric mean of the range reported by Dyke et al., 2003 (0.0085 to 

25.6 μg WHO98 TEQP/MT) which is 0.5 ng WHO98 TEQP/kg. This emission factor is considered 

preliminary due to the inconsistency in the results. The activity data are presented in Chapter 3. 

PCBs are also likely to be present in the ash, but these would be landfilled and not considered an 

environmental release. The inventory decision criteria and releases to all media are summarized 

below: 
This document is a draft for review purposes only and does not constitute Agency policy.

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Inventory Decision Criteria for Municipal Waste Combustion

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission factors. 

Yes

Measured emission factors consistent or have understandable 

differences. 

No

Emission factor tests represent units that are typical of the 

class. 

Yes

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P

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Municipal Waste Combustion

Air Releases

Emission Factors 

• 1987―0.5 ng WHO98 TEQP/kg (Preliminary). 

• 1995―0.5 ng WHO98 TEQP/kg (Preliminary). 

• 2000―0.5 ng WHO98 TEQP/kg (Preliminary).

Activity Levels

• 1987―13.7 billion kg. 

• 1995―29.8 billion kg. 

• 2000―29.4 billion kg.

Releases

• 1987―7 g WHO98 TEQP (Preliminary). 

• 1995―15 g WHO98 TEQP (Preliminary). 

• 2000―15 g WHO98 TEQP (Preliminary).

10.4.2. Industrial Wood Combustion 

As discussed in EPA (2006), evidence exists that PCBs can be released from industrial 

wood combustion, but the information is insufficient to make quantitative release estimates. No 

changes were made to this conclusion.

Industrial Wood Combustion

Releases

Not quantifiable.
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1 10.4.3. Medical Waste Incineration

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EPA (2006) concluded that insufficient evidence existed to derive emission factors for 

PCB releases from medical waste combustion. As discussed below, additional studies were 

found that allowed making preliminary release estimates. 

Dyke et al. (2003) surveyed the literature for studies providing measurements of 

dioxin-like PCBs along with CDD/CDFs from power stations and waste incineration processes. 

They identified a study published in 1996 (Ehrlich et al., 1996) in which the PCB emission 

concentration from a medical waste incineration was 0.035 ng WHO98 TEQP/Nm3, while it was 

0.97 ng WHO98 TEQDF/Nm3 for CDD/CDFs. They also conducted their own measurements on a 

medical waste incinerator in the United Kingdom. They quantified concentrations of PCB-118, 

PCB-123, PCB-170, and PCB-180―but not the other 14 congeners. Assuming ND = 0, one of 

two runs had a concentration of 0.00007 ng WHO98 TEQP/Nm3, while the other had a 

concentration of 0.022 WHO98 TEQP/Nm3 at ND = 0. In contrast, the same two runs had 

CDD/CDF concentrations at ND = 0 at 0.07 and 0.05 ng WHO98 TEQDF/Nm3

. 

The data reported by Dyke et al. (2003) suggest that PCB TEQ emissions are 1 to 25% of 

the dioxin emissions. The Ehrlich et al. (1996) data suggest that the PCB TEQ emissions are 4% 

of the dioxin emissions. The Ehrlich et al. (1996) value was selected as a central estimate and 

multiplied by the average CDD/CDF emission factor for each reference year (total CDD/CDF 

emissions divided by the total activity as reported in Chapter 3). This procedure gave the 

emission factors shown below. These emission factors are considered preliminary because the 

studies provided insufficient information to directly derive them. The activity data are presented 

in Chapter 3. PCBs are also likely to be present in the ash, but these would be landfilled and not 

considered an environmental release. The inventory decision criteria and releases to all media 

are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy.

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Inventory Decision Criteria for Medical Waste Incineration

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission factors. 

No

Measured emission factors consistent or have understandable 

differences. 

Emission factor tests represent units that are typical of the 

class. 

Yes

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P

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Medical Waste Incineration

Air Releases

Emission Factors 

• 1987―68 ng WHO98 TEQP/kg (Preliminary). 

• 1995―24 ng WHO98 TEQP/kg (Preliminary). 

• 2000―24 ng WHO98 TEQP/kg (Preliminary).

Activity Levels

• 1987―1.43 billion kg. 

• 1995―0.77 billion kg. 

• 2000―0.6 billion kg.

Releases

• 1987―97 g WHO98 TEQP (Preliminary). 

• 1995―18 g WHO98 TEQP (Preliminary). 

• 2000―14 g WHO98 TEQP (Preliminary).

10.4.4. Tire Combustion

As discussed in EPA (2006), evidence exists that PCBs can be released from tire 

combustion, but the information is insufficient to make quantitative release estimates. No 

changes were made to this conclusion. 

Tire Combustion

Releases

Not quantifiable.
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1 10.4.5. Cigarette Smoking

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As discussed in the original report, PCB releases can occur during cigarette 

smoking. No changes were made to these estimates as summarized below. 

A preliminary estimate of potential emissions of dioxin-like PCBs can be made using the 

following assumptions: (a) the average WHO98 TEQP content of seven brands of U.S. cigarettes 

reported by Matsueda et al. (1994), 0.64 pg/pack (0.032 pg/cigarette), is representative of 

cigarettes smoked in the United States; (b) dioxin-like PCBs are neither formed nor destroyed, 

and the congener profile reported by Matsueda et al. (1994) is not altered during combustion of 

cigarettes; and (c) all dioxin-like PCBs contributing to the TEQ are released from the tobacco 

during smoking. This emission factor is considered preliminary because of the multiple 

assumptions required in its derivation. Cigarette consumption is discussed in Section 5.5. 

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Cigarette Smoking

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission factors. 

No

Measured emission factors consistent or have understandable 

differences. 

Emission factor tests represent units that are typical of the 

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P

 
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Cigarette Smoking

Air Releases

Emission Factors 

• 1987―0.03 pg WHO98 TEQP/cigarette (Preliminary). 

• 1995―0.03 pg WHO98 TEQP/cigarette (Preliminary). 

• 2000―0.03 pg WHO98 TEQP/cigarette (Preliminary).

Activity Levels

• 1987―575 billion cigarettes. 

• 1995―487 billion cigarettes. 

• 2000―440 billion cigarettes.

Releases

• 1987―<0.1 g WHO98 TEQP (Preliminary). 

• 1995―<0.1 g WHO98 TEQP (Preliminary). 

• 2000―<0.1 g WHO98 TEQP (Preliminary).

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9 

10 

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12 

13 

14 

10.4.6. Sewage Sludge Incineration

As discussed in the original report, PCB releases can occur from sewage sludge 

incineration. No changes were made to these estimates as summarized below. Additional 

information was found regarding a stack test for a sewage sludge incinerator in the United 

Kingdom (Dyke et al., 2003). This was not used in the emission factor derivation because all 

dioxin-like PCB congeners were below the detection limits of about 0.12 ng/Nm3 for each 

congener. 

The emission factor was based on measurements conducted at a multiple-hearth 

incinerator in Ohio equipped with a venturi scrubber and a three-tray impingement conditioning 

tower (U.S. EPA, 2000b). This emission factor was considered preliminary because it is based 

on testing at only one facility. Sewage sludge activity data are presented in Chapter 8. 

The inventory decision criteria and releases to all media are summarized below: 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 10-13 DRAFT: DO NOT CITE OR QUOTE

Inventory Decision Criteria for Sewage Sludge Incineration

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission factors. 

No

Measured emission factors consistent or have understandable 

differences. 

Emission factor tests represent units that are typical of the 

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P

1 

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3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

Sewage Sludge Incineration

Air Releases

Emission Factors 

• 1987―0.51 ng WHO98 TEQP/kg of sludge (Preliminary). 

• 1995―0.51 ng WHO98 TEQP/kg of sludge (Preliminary). 

• 2000―0.51 ng WHO98 TEQP/kg of sludge (Preliminary).

Activity Levels

• 1987―0.865 MMT. 

• 1995―2.11 MMT. 

• 2000―1.42 MMT.

Releases

• 1987―0.4 g WHO98 TEQP (Preliminary). 

• 1995―1 g WHO98 TEQP (Preliminary). 

• 2000―0.7 g WHO98 TEQP (Preliminary).

10.4.7. Backyard Barrel Burning

The original report concluded that insufficient information was available to make 

quantitative PCB release estimates for backyard barrel burning. New information is provided 

below, which allowed making both air and land release estimates for this source category. 

Gonczi et al. (2005) tested emissions from burning domestic wastes in barrels (19 tests) 

and open fires (2 tests). Gas collected above these fires allowed for estimation of emission 

factors. The material burned consisted of various mixtures of garden wastes, straw, paper, 

several forms of plastic, tires, waste motor oil, RDF, and computer scrap. A barrel burn with a 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 mix of garden waste and polyvinyl chloride (PVC) waste had the highest emission factor of 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

190 ng PCB TEQ/kg burned. The other tests ranged from 0.3 to 3.2 ng WHO98 TEQP/kg burned. 

The dioxin-like PCBs generally made up much less than 10% of the total TEQ emissions. 

As reported in EPA (2006), Lemieux (1997) also measured PCB emissions from tests 

simulating backyard barrel burning. The average emission factor across two tests was 

5.26 ng WHO98 TEQP/kg waste burned. This emission factor was selected as the most 

representative of typical domestic waste.

 Lemieux (1997) also collected ash samples from open barrel burning and analyzed for 

PCBs. Ash samples from the experiments were combined, resulting in two composite 

samples―one for recyclers and one for nonrecyclers (see Table 10-2). The overall average was 

0.8 ng WHO98 TEQP/kg of ash. 

The activity levels for backyard barrel burning (total waste burned and ash generated) 

were presented in Section 6.5.2. 

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Backyard Barrel Burning

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission factors. 

Yes Yes

Measured emission factors consistent or have understandable 

differences. 

Yes Yes

Emission factor tests represent units that are typical of the 

class. 

Yes Yes

Activity estimates based on source-specific surveys. Yes Yes

Conclusion (Q = Quantitative, P = Preliminary). Q Q
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 10-15 DRAFT: DO NOT CITE OR QUOTE

Backyard Barrel Burning

Air Releases

Emission Factors 

• 1987―5.3 ng WHO98 TEQP/kg of waste burned. 

• 1995―5.3 ng WHO98 TEQP/kg of waste burned. 

• 2000―5.3 ng WHO98 TEQP/kg of waste burned.

Activity Levels

• 1987―7.87 MMT.

 

• 1995―8.18 MMT.

 

• 2000―6.49 MMT.

 

Releases

• 1987―41 g WHO98 TEQP. 

• 1995―43 g WHO98 TEQP. 

• 2000―34 g WHO98 TEQP.

Solid Residue Releases

Emission Factors 

• 1987―0.8 ng WHO98 TEQP/kg of ash. 

• 1995―0.8 ng WHO98 TEQP/kg of ash. 

• 2000―0.8 ng WHO98 TEQP/kg of ash burned.

Activity Levels

• 1987―1.2 MMT. 

• 1995―1.2 MMT. 

• 2000―0.97 MMT.

Releases

• 1987―1 g WHO98 TEQP. 

• 1995―1 g WHO98 TEQP. 

• 2000―0.8 g WHO98 TEQP.

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4 

5 

6 

7 

8 

10.4.8. Petroleum Refining Catalyst Regeneration 

As discussed in EPA (2006), evidence exists that PCBs can be released from petroleum 

refining catalyst regeneration, but the information is insufficient to make quantitative release 

estimates. No changes were made to this conclusion.

Petroleum Refining Catalyst Regeneration

Air Releases

Not quantifiable.
This document is a draft for review purposes only and does not constitute Agency policy.

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1 10.4.9. Hazardous Waste Incineration 

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24 

25 

26 

27 

28 

29 

30 

This is a completely new section on hazardous waste incineration. 

Two studies were identified from outside of the United States that measured emissions of 

dioxin-like PCBs along with dioxins and furans from hazardous waste incinerators. One of the 

studies was consistent with studies on municipal solid waste incinerators, which showed

CDD/CDF TEQ emissions to be an order of magnitude and more higher than PCB emissions. 

Kim et al. (2005) measured 209 congeners in stack emissions from nine facilities, which 

included two industrial waste incinerators and a “specific industrial waste incinerator.” The 

emission concentrations of the dioxin-like PCBs in the industrial waste incinerators were 

0.136 for the “specific” incinerator and 0.025 ng WHO98 TEQP/Nm3 for the average of the 

two industrial waste incinerators. These were characterized as being equal to 2.9 and 1.3% of 

the emission concentrations of WHO98 TEQDF. On the other hand, Francois et al. (2005) 

measured dioxins, furans, and coplanar PCBs from 15 facilities including one HWI. The 

concentration of the PCBs was 0.0051 ng WHO98 TEQP/Nm3

, which was almost three times 

higher than the measurement of CDD/CDFs, at 0.0019 ng WHO98 TEQP/Nm3

. The annual 

emission of dioxin-like PCBs from this facility was estimated at 1.5 mg WHO98 TEQP/year. 

Given the inconsistent results from these two studies, it is unclear how to make emission 

estimates on even a preliminary basis. 

Therefore, the available data were judged inadequate to support development of a 

quantitative estimate of a dioxin-like PCB emission factor for this source category. 

Hazardous Waste Incineration

Releases

Not quantifiable.

10.4.10. Power Plants

This is a completely new section.

Emissions from power plants were estimated to account for 2% of the total PCB releases 

occurring in the United Kingdom in 1998 (Dyke, 2002). 

Brodsky et al. (2003) reported on measurements from six combustion sources in Russia, 

including two power plants. Numerous individual congener concentrations in the stack gas 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 emissions were provided including some dioxin-like PCBs, although no TEQ estimates were 

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28

29

30

provided and no congener-specific emission factors were provided. Concentrations were 

provided for PCB-105, PCB-118, PCB-123, PCB-156, PCB-157, PCB-170, and PCB-180. The 

TEQ concentration in the power plant for these congeners was 0.02 ng WHO98 TEQP/Nm3. 

Francois et al. (2005) reported on testing at 15 incinerators including one coal-fired 

power plant. They measured emissions of CDD/CDF and PCB as 

0.0003 ng WHO98 TEQDF/Nm3 and 0.0009 ng WHO98 TEQP/Nm3, respectively. Extrapolating to 

annual emissions, they estimated an emission of 1.17 mg WHO98 TEQP/year. Dyke et al. (2003) 

reported on emission measurements from a coal-fired power station in the United Kingdom. 

They found nondetects for all dioxin-like PCBs tested, except a positive for PCB-180 in one of 

two tests.

The available data were judged inadequate to support development of a quantitative 

estimate of a dioxin-like PCB emission factor for this source category. 

Power Plants

Releases

Not quantifiable.

10.4.11. Forest Fires

This is a completely new section. 

 Collet and Fianni (2006) conducted five forest fire test burns in a chamber of about 

80 m3

. The samples were collected from forests in two regions of southern France and the tests 

were conducted by the French Agency for Environment and Energy Management. Blank 

samples were also taken to ensure that the chamber did not introduce contaminants to the burns. 

Emission concentrations were determined for the 17 CDD/CDFs and 12 dioxin-like PCBs. 

Generally, PCBs explained about 6% of the total TEQ emissions, except for one forest fire burn, 

where emissions overall were close to blanks and PCBs contributed 26% in this case. The 

emission factors for CDD/CDFs ranged from 1.0 ng I-TEQDF/kg burned (the low for the test 

close to the blank) to 26 ng I-TEQDF/kg. The TEF scheme used to characterize PCB emissions 

was not clear but assumed here to be WHO98. This implies that the PCB emission factor ranged 

from 0.06 to 1.6 WHO98 TEQP. 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 For the purposes of deriving a preliminary estimate, it is assumed that the PCB TEQ 

2 

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4 

5 

6 

7 

8 

9 

10 

emission factor is 6% of the one for CDD/CDFs (based on the results from Collet and Fianni 

[2006]). As discussed in Chapter 6, the forest fire emission factor is 3 ng WHO98 TEQDF/kg. 

This is adjusted to 0.2 ng WHO98 TEQP/kg for PCBs. This emission factor is considered 

preliminary because it is uncertain how well the limited testing represents all fire/wood types. 

The activity levels for forest fires are presented in Chapter 6. PCBs are also likely to be present 

in the ash, but insufficient information was available to make quantifiable estimates. 

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Forest Fires

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission factors. 

Yes

Measured emission factors consistent or have understandable 

differences. 

Yes

Emission factor tests represent units that are typical of the 

class. 

No

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 10-19 DRAFT: DO NOT CITE OR QUOTE

Forest Fires

Air Releases

Emission Factors 

• 1987―0.2 ng WHO98 TEQP/kg (Preliminary). 

• 1995―0.2 ng WHO98 TEQP/kg (Preliminary). 

• 2000―0.2 ng WHO98 TEQP/kg (Preliminary).

Activity Levels

• 1987―61 MMT. 

• 1995―55 MMT. 

• 2000―243.8 MMT.

Releases

• 1987―12 g WHO98 TEQP (Preliminary). 

• 1995―11 g WHO98 TEQP (Preliminary). 

• 2000―49 g WHO98 TEQP (Preliminary).

Solid Residue Releases

Not quantifiable.

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

10.5. METAL REFINING SOURCES

This is a completely new section.

Kim et al. (2004) measured all 209 PCB congeners in stack emissions from 

nine facilities, including a sintering furnace in a ferrous metal foundry and two smelting furnaces 

in nonferrous metal foundries in Japan. All nine facilities emitted PCBs, with total PCBs 

ranging from 10−700 ng/Nm3

 and coplanar PCBs in the range of 1−25 ng/Nm3

(0.008−0.324 ng WHO98 TEQP/Nm3). The three metal facilities had these results: aluminum 

smelting furnace―0.020 ng WHO98 TEQP/Nm3; copper smelting 

furnace―0.026 ng WHO98 TEQP/Nm3

; and sintering furnace―0.018 ng WHO98 TEQP/Nm3. In 

terms of a relationship to CDD/CDFs, Kim et al. (2004) developed a ratio of the TEQ 

concentration of dioxin-like PCBs to that of CDD/CDFs and found the narrow range of 0.032 to 

0.050, suggesting that the TEQ concentration of dioxin-like PCBs was over an order of 

magnitude lower than that of CDD/CDFs. 

Stack gas emissions of dioxin-like PCBs were measured along with CDD/CDFs from 

three iron ore sintering plants in the United Kingdom between 2002 and 2003 (Aries et al., 

2006). The dioxin-like PCBs found at the highest concentrations were PCB-118 at 6−9 ng/Nm3

, 

followed by 105 at 2−4 ng/Nm3, and 77 at 2−3 ng/Nm3, with others detected at below 2 ng/Nm3. 

On a TEQ basis, including CDD/CDFs and dioxin-like PCBs (the authors calculated CDD/CDF
This document is a draft for review purposes only and does not constitute Agency policy.

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1 using I-TEFs while dioxin-like PCB TEQ was calculated using WHO98 TEFs), the PCBs 

2 

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4 

5 

6 

7 

8 

9 

10 

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15 

16 

17 

18 

19 

20 

21 

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24 

25 

26 

27 

28 

29 

30 

31 

contributed less than 10% of the total TEQ concentration, which averaged between 0.6 and 

1.6 ng total TEQ/Nm3. The mass emissions of total TEQ from the three plants, calculated based 

on emission concentrations in conjunction with mass loadings, totaled 8.7, 9.2, and 

10.9 g TEQ/year over the three plants. 

Kim et al. (2004a) reported on the testing of eight incinerators including two sintering 

furnaces and four smelting furnaces for CDD/CDFs, PCBs, and HCB. The average over all 

eight incinerators, on a WHO98 TEQ basis, was 0.281 ng/Nm3 for CDD/CDFs and 0.023 ng/Nm3

for PCBs, suggesting a factor of 10 difference on average. The aluminum nonferrous metal 

smelter showed a PCB TEQ concentration at 0.016 ng WHO98 TEQP/Nm3, which was only 

one-half that of CDD/CDF TEQ, not the order of magnitude suggested by averaging all 

eight facilities. The copper smelter had the same TEQ concentration for both PCBs and 

CDD/CDFs: 0.002 ng WHO98 TEQP/Nm3

. The most informative tests, perhaps, were the 

two iron ferrous metal smelters, where CDD/CDF overwhelmed PCB emissions. The CDD/CDF

emission concentrations were 1.492 and 0.926 ng WHO98 TEQDF/Nm3, while the PCB emission 

concentrations were 0.112 and 0.067 ng WHO98 TEQP/Nm3, respectively. 

 Brodsky et al. (2003) reported on measurements from six combustion sources in Russia, 

including a nonferrous metallurgy plant, a cement plant, an aluminum plant in the calcination 

furnace, and an aluminum plant in the entry into the electrostatic filter. Numerous individual 

congener concentrations in the stack gas emissions were provided including some dioxin-like 

PCBs, although no TEQ estimates were provided and no congener-specific emission factors were 

provided. Concentrations were provided for PCB-105, PCB-118, PCB-123, PCB-156, PCB-157, 

PCB-170, and PCB-180. The TEQ concentration in these four facilities ranged from 0.001 to 

0.006 ng WHO98 TEQP/Nm3. Brodsky et al. (2003) provided a total concentration (sum of all 

congeners) and an emission factor of total PCBs in μg/MT. 

Fisher et al. (2004) reported on tests for an experimental sinter box apparatus, which is 

essentially a small pilot plant. A raw mix of typical iron ore feed―including iron ore fines, 

fluxes, fuel in the form of coke, and some recycled materials―was combined with five different 

amounts of potassium chloride to test the effect of chloride on CDD/CDF and dioxin-like PCB 

emissions. A correlation was found for both CDD/CDF and dioxin-like PCB emissions with 

chloride content. At a chloride concentration in the entire feed of 250 mg/kg and less, which 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 encompassed a baseline run and a run at 250 mg/kg chloride, CDD/CDF emissions were fairly 

2 

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4 

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6 

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8 

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12 

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14 

15 

16 

17 

18 

19 

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21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

steady, suggesting chloride did not affect emissions at concentrations in this range, but at higher 

concentrations with up to about 800 mg/kg chloride added, the effect was second order. For 

PCBs, the effect was more linear―a linear rise in PCB emissions was noted with increasing 

chloride content. PCDF concentrations dominated CDD/CDF, and on a TEQ basis, CDD/CDF

dominated over PCBs. Specifically, the ratio of PCB to CDD/CDF TEQ concentrations was in 

the range of 0.07 for the five tests. On a TEQ basis, PCB-126 contributed 90−95% of total PCB 

TEQ, but PCB-105 and PCB-118 contributed the most on a straight concentration basis. The 

authors concluded that at typical chloride concentrations of 50−100 mg/kg in the industry, the 

total CDD/CDF/PCB concentrations are expected to be below 1.5 ng TEQ/Nm3. 

Francois et al. (2004) measured emissions at 15 facilities, including two metal smelters 

and an iron ore sintering plant. For most facilities, their sampling indicated that the TEQ 

emissions of dioxin-like PCBs nearly matched that of dioxins. With the iron ore sintering plant, 

however, the dioxin-like PCBs were an order of magnitude less than dioxins: 

0.058 ng WHO98 TEQP/Nm3

 versus 0.65 ng WHO98 TEQDF/Nm3. For the aluminum and copper 

smelters, PCB emissions were a factor of 2 (at 0.046 ng WHO98 TEQP/Nm3) and a factor of 4 (at 

0.017 ng WHO98 TEQP/Nm3

) less than dioxin TEQ, respectively. They calculated total annual 

TEQ emissions for these plants and estimated dioxin-like PCB emissions to be 2.3 and 

18.8 mg WHO98 TEQP/year for the aluminum and copper smelters, respectively, and to be much 

higher at 474 mg WHO98 TEQP/year for the iron ore sintering plant. 

 As described above, several studies outside of the United States have measured 

dioxin-like PCBs along with CDD/CDFs from a variety of metal processing facilities including 

ferrous and nonferrous smelters, iron ore sintering facilities, and other combustion units within 

the metal refining industry. These studies did not report emission factors but the concentration 

data consistently suggest that emissions from iron ore sintering plants are about an order of 

magnitude or more lower than CDD/CDFs, on a TEQ basis. Accordingly, for the purposes of a 

preliminary estimate, the PCB emission factor is assumed to be 10% of the CDD/CDF emission 

factor. The activity levels (from Chapter 7) and release estimates are shown below. The studies 

also indicate that PCB emissions are occurring from copper and aluminum smelting operations, 
This document is a draft for review purposes only and does not constitute Agency policy.

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1 but the results are not consistent and not easily converted to TEQ emission factors. Thus, 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

quantitative estimates could not be made for these facilities.

The inventory decision criteria and releases to all media are summarized below: 

Inventory Decision Criteria for Iron Ore Sinter Production

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission factors. 

No

Measured emission factors consistent or have understandable 

differences. 

Emission factor tests represent units that are typical of the 

class. 

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P

Iron Ore Sinter Production

Air Releases

Emission Factors

Wet Scrubber

• 1987―0.06 ng WHO98 TEQP/kg of sinter (Preliminary). 

• 1995―0.06 ng WHO98 TEQP/kg of sinter (Preliminary). 

• 2000―0.06 ng WHO98 TEQP/kg of sinter (Preliminary). 

Fabric Filter

• 1987―0.5 ng WHO98 TEQP/kg of sinter (Preliminary). 

• 1995―0.5 ng WHO98 TEQP/kg of sinter (Preliminary). 

• 2000―0.5 ng WHO98 TEQP/kg of sinter (Preliminary).

Activity Levels

a

• 1987―14.5 MMT. 

• 1995―12.4 MMT. 

• 2000―10.6 MMT.

Releases

• 1987―4 g WHO98 TEQP (Preliminary). 

• 1995―3 g WHO98 TEQP (Preliminary). 

• 2000―3 g WHO98 TEQP (Preliminary).

a

Fifty-nine percent of sinter production was at facilities with wet scrubbers, and 41% was at facilities with fabric 

filters.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 10-23 DRAFT: DO NOT CITE OR QUOTE

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

Copper and Aluminum Smelting

Air Releases

Not quantifiable.

10.6. NATURAL SOURCES (ORIGINALLY SECTION 10.5) 

As discussed in EPA (2006), there is no clear evidence that releases of dioxin-like PCBs 

occur from natural sources. No changes were made to this conclusion. 

10.6.1. Biotransformation of Other PCBs 

 As discussed in the original report, studies have shown that under anaerobic conditions, 

biologically mediated reductive dechlorination to lower-chlorinated congeners, followed by slow 

anaerobic and/or aerobic biodegradation, is a major pathway for destruction of PCBs in the 

environment. This research indicates that biodegradation should result in a net decrease rather 

than a net increase in the environmental load of dioxin-like PCBs. 

10.6.2. Photochemical Transformation of Other PCBs 

 Photolysis and photo-oxidation may be major pathways for destruction of PCBs in the 

environment. Research reported to date and summarized in the original report indicates that 

ortho-substituted chlorines are more susceptible to photolysis than are meta- and para-substituted 

congeners; thus, photolytic formation of more toxic dioxin-like PCBs may occur. Oxidation by 

hydroxyl radicals, however, apparently occurs preferentially at the meta and para positions, 

resulting in a net decrease rather than a net increase in the environmental load of dioxin-like 

PCBs.

10.7. PAST USE OF COMMERCIAL PCBS (ORIGINALLY SECTION 10.6) 

 This section provides background information about the amount of PCBs used in the past 

and does not discuss release estimates for the reference years. No changes were made to this 

section. As discussed in the original report, an estimated 568,000 MT of PCBs were sold in the 

United States between 1930 and 1975. The environmental releases associated with production, 

use, and disposal during this time period were estimated as 3,702 kg WHO98 TEQP. 
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 10-1. Summary of PCB releases for reference years 1987, 1995, and 2000 (g WHO98 TEQP/year)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ

Releases from commercial PCB products

PCB incineration x x

Releases from in-service 

PCBs

x x x

Chemical manufacturing and processing sources

Municipal wastewater 

treatment

1987 

1995 

2000

51 

78 

19

2 

12 

3

Combustion sources

Municipal waste 

combustors 

1987 

1995 

2000

7 

15 

15

Industrial wood 

combustion

x

Medical waste 

incineration 

1987 

1995 

2000

97 

18 

14

Tire combustion x
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 10 1. Summary of PCB releases for reference years 1987, 1995, and 2000 (g WHO98 TEQP/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ

Cigarette smoking

1987 

1995 

2000 

<0.1 

<0.1 

<0.1 

Sewage sludge 

incineration 

1987 

1995 

2000 

 

0.4 

1 

0.7 

Backyard barrel 

burning 

1987 

1995 

2000 

41 

43 

34 

1 

1 

0.8 

Petroleum-refining 

catalyst regeneration

x 

Hazardous waste 

incineration 

x 

Power plants x 

Forest fires

1987 

1995 

2000 

12 

11 

49 

x 
This document is a draft for review purposes only and does not constitute Agency policy.

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Table 10 1. Summary of PCB releases for reference years 1987, 1995, and 2000 (g WHO98 TEQP/year) 

(continued)

Source

Air releases Land releases Water releases Product releases

Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ Q. Inv. Prelim. NQ

Metal refining

Iron ore sintering

1987 

1995 

2000

4 

3 

3

Copper smelting x

Aluminum smelting x

Total

1987 

1995 

2000

41 

43 

34

120 

48 

82

52 

79 

20

2 

12 

3 

x = Releases are possible during this year, but the data are insufficient to develop estimates. 

Q. Inv. = Quantitative Inventory. 

Prelim. = Preliminary. 

NQ = Not quantified.
This document is a draft for review purposes only and does not constitute Agency policy.

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1 Table 10-2. PCB analysis for composite ash samples from barrel burning

2 

3 

4 

5 

6 

7 

Congener

IUPAC 

number

Emission factors (μg/kg)

Recycler Nonrecycler Average

3,3',4,4'-TCB 77 1.2 1 1.1

3,4,4',5-TCB 81

2,3,3',4,4'-PeCB 105 3.4 3.5 3.5

2,3,4,4',5-PeCB 114

2,3',4,4',5-PeCB 118

2',3,4,4',5-PeCB 123

3,3',4,4',5-PeCB 126

2,3,3',4,4',5-HxCB 156 0.7 <0.5 0.5

2,3,3',4,4',5'-HxCB 157

2,3',4,4',5,5'-HxCB 167

3,3',4,4',5,5'-HxCB 169

2,3,3',4,4',5,5'-HpCB 189 0.6 <0.5 0.4

Total WHO98 TEQP 0.0009 0.0006 0.0008

Averages and TEQs calculated assuming half the values for entries shown as less than.

IUPAC = International Union of Pure and Applied Chemistry.

Source: Lemieux (1997).
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1 11. RESERVOIR SOURCES OF CDD/CDFS AND DIOXIN-LIKE PCBS

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This introduction has been expanded to more clearly define reservoirs. Chapters 2 

through 10 of this document discuss sources with the potential for initial releases of dioxin-like 

compounds to the environment in the United States. This chapter addresses releases from 

reservoirs that are defined as materials or places that contain previously released CDD/CDFs or 

dioxin-like PCBs and have the potential for redistributing these compounds into the environment. 

Potential reservoirs include soils, sediments, biota, water, and some products. Products that 

contain CDD/CDFs can be considered reservoirs when they have the potential for releases after 

their initial use. The atmosphere could be considered a reservoir but is excluded here because it 

is the primary medium for transporting and distributing CDDs and CDFs over large geographical 

areas. Thus, it is considered a temporary holding place rather than a long-term reservoir. 

Although water is also an important transport medium, the residence times can be long, and, 

therefore, it is appropriately considered a reservoir. 

The definition of reservoirs as used in this document also excludes CDD/CDFs contained 

in natural ball clay deposits. The CDD/CDFs contained in ball clay were formed by geochemical 

processes that are thought to have occurred millions of years ago. Any release from ball clay 

would be an initial release to the contemporary environment, and, therefore, ball clay is not 

considered to be a reservoir. Potential ball clay releases are covered in Chapter 9 on Natural 

Sources. 

Soils in some locations could have elevated CDD/CDF levels due to past activities such 

as pesticide use, spills, illegal disposal, or fires. These areas would be considered part of the soil 

reservoir and would have the potential for greater release rates than normal soils with background 

CDD/CDF levels. The soil-release estimates presented in this document do not include releases 

from these “hot spots” due to lack of appropriate information. However, they could be important 

events on a local scale and should be considered where feasible.

Dioxin-like compounds are sequestered by a reservoir only until physical processes 

cause these contaminants to become released into the open environment over a defined time and 

space. When this occurs, reservoirs become sources of dioxin-like compounds in the circulating 

environment. Figure 11-1 presents a conceptual diagram of flux and exchange of dioxin-like 

compounds to multiple environmental compartments such as soils, water, air, sediments, and 
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1 biota. This dynamic system consists of fluxes in and out of the atmosphere as well as other 

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exchanges between reservoirs and the atmosphere (recall that the atmosphere is not defined here 

as an environmental reservoir, rather as a transport medium for dioxin-like compounds). 

Movement of dioxin-like compounds between media can be induced by the physical processes of 

volatilization, wet and dry atmospheric particle and vapor deposition, adsorption, erosion and 

runoff, resuspension of soils into air, and resuspension of sediments into water. 

This chapter describes the major reservoir sources of CDD/CDFs and PCBs, including, to 

the extent feasible, estimates of the potential mass of CDD/CDFs and PCBs in each reservoir, the 

chemical/physical mechanisms responsible for releases of these compounds, and estimates of 

potential annual releases from each reservoir. 

11.1. SOIL RESERVOIRS (ORIGINALLY SECTION 11.2.1) 

 This section provides revised estimates of the amounts of CDD/CDFs in soil reservoirs.

 Harrad and Jones (1992) and Duarte-Davidson et al. (1997) estimated the CDD/CDF 

content of soils in the United Kingdom by multiplying the soil surface area by the contamination 

depth, soil density, and CDD/CDF concentration in the soil. A similar approach was used here 

to estimate the amount CDD/CDFs in surface soils of the United States. The following inputs 

were used in these calculations:

• Surface soils were divided into rural and urban areas to reflect differences in the 

CDD/CDF levels. Urban areas were assumed to have an average concentration of 

10 pg WHO TEQDF/g, and rural soils, 2 pg WHO TEQDF/g (U.S. EPA, 2007b). 

• The urban land area in the United States is 1.82 million km2 based on Census Bureau 

statistics for metropolitan areas (USDA, 2002). The portion of urban areas covered by 

impervious surfaces (rather than soil) varies widely. For the purposes of a preliminary 

estimate, it was assumed that an average of 50% of the metropolitan land area had soil 

coverage. The land area of nonmetropolitan areas in the United States is 

7.28 million km2 (USDA, 2002). 

• The soil density was assumed to be 2.6 g/cm3

 (Brady, 1984). 

• The contamination depth was assumed to be 10 cm (U.S. EPA, 2007b).

Based on these assumptions, the amount of CDD/CDFs in U.S. surface soils was estimated as 

2,370 kg WHO TEQDF in urban soils and 3,790 kg WHO TEQDF in rural soils, for a total of 
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1 6,150 kg WHO TEQDF. EPA (2007b) found that average PCB TEQs were about 4% of average 

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total D/F/P TEQs in rural soils. Assuming this percentage applies to urban areas as well, this 

would imply that the soil reservoir contains about 95 kg WHO TEQP. These calculations are not 

definitive and only indicate approximate amounts of dioxins that may be contained in U.S. 

surface soils. 

 Soils in some locations could have elevated CDD/CDF levels (or “hot spots”) due to 

uncontrolled activities such as spills, illegal disposal, or fires. Elevated soil levels could also 

occur in areas where 2,4-D and 2,4,5-T were used and areas with land-applied sludges/ash. 

These areas would be considered part of the soil reservoir and would have the potential for 

greater release rates than normal soils with background CDD/CDF levels. The amounts in 

landfills could also be considered part of the soil reservoir, although the potential for release is 

much less. No estimates could be made for the additional CDD/CDF soil burdens due to the 

uncontrolled activities, but estimates were made for the other activities as discussed below. 

Estimates can be made for the total mass of CDD/CDF TEQs that have been applied to 

soil from past use of the pesticides 2,4-dichlorophenoxyacetic acid (2,4-D) and 

2,4,5-trichlorophenoxyacetic acid (2,4,5-T). As discussed in Chapter 11 of the original report, 

the total amounts of CDD/CDF released to the environment are as follows: 

• From 2,4-D use during the period of 1975 to 1995, the total release was estimated as 

0.55 kg WHO98 TEQDF (0.35 kg I-TEQDF). 

• From 2,4,5-T use over the period of 1950 to 1979, the total release was estimated as 

36 kg of 2,3,7,8-TCDD. 

 The amounts of CDD/CDFs in landfills can also be considered a soil reservoir with the 

potential for releases in the future. The earlier chapters provided estimates of the amounts of 

CDD/CDFs landfilled for many sources. As shown in Table 11-1, the total amounts landfilled 

were estimated as 3,750 g TEQ in 1987, 1,050 g TEQ in 1995, and 1,310 g TEQ in 2000. If it is 

assumed that most landfills operate for 30 years and the average annual input equals the average 

over the reference years (2,040 g TEQ), then the cumulative sum would be 61,000 g TEQ. This 

should be regarded as a preliminary estimate because it is based on numerous assumptions and 

limited data.
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1 A variety of waste types containing CDD/CDFs are land applied such as sewage sludge, 

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wood pulp sludge, residential wood burning ash, and beneficial uses of cement kiln clinker. 

These sources also contribute to the soil reservoir. As shown in Table 1-9, these sum to 

2,400 g TEQ in 1987, 2,500 g TEQ in 1995, and 2,300 g TEQ in 2000. If it is assumed that 

operations persist for 30 years and the average annual input equals the average over the reference 

years (2,400 g TEQ), then the cumulative sum would be 72,000 g TEQ. This should be regarded 

as a preliminary estimate because it is based on numerous assumptions and limited data. 

In summary, the total mass of CDD/CDF that is contained in the soil reservoir is 

approximately 6,150 kg WHO98 TEQ with perhaps an additional 170 kg TEQ from past 

additions (landfills - 61 kg TEQ, pesticide use - 37 kg TEQ and land-applied sludges/ash - 72 kg 

TEQ). As discussed below, various forms of degradation/removal can occur in soil, which 

would reduce these contributions from the past, making it uncertain how much of these remain in 

the soil reservoir today. 

11.1.1. Mechanisms Responsible for Releases from Surface Soils

As discussed in the original report, a number of studies have demonstrated that soil 

releases can occur via erosion, degradation, volatilization, and particle resuspension. 

11.1.2. Estimated Annual Releases from Soil to Water 

Nonpoint sources of CDD/CDFs to waterways include stormwater runoff from urban 

areas and soil erosion in rural areas during storms. Approaches for estimating national loadings 

to water for both of these sources are described below. 

11.1.2.1.Urban Runoff 

No changes were made in this update. As discussed in the original report, a wide range 

of CDD/CDF concentrations were measured in urban runoff at 23 sites in California (Mathur 

et al., 1997; Fisher et al., 1999). The midpoint of the 4 order of magnitude range was selected. 

Based on the wide range of results and uncertainty about the representativeness of the samples, 

this factor is considered preliminary. The run-off volume was calculated based on rainfall data 

and urban area data. All factors and release estimates are presented in the release summary 

below. 
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11.1.2.2.Rural Soil Erosion

The original report also presented estimates for CDD/CDF releases from rural soils. No 

changes were made to the activity estimates, but updates were made to the emission factors as 

discussed below. 

The data summarized in EPA (2007b) suggest that the typical concentration of 

CDD/CDFs in soils in rural areas is about 1.7 ng WHO98 TEQDF/kg based on samples from 

27 locations. Similarly, EPA (2007b) suggests that the typical concentration of PCBs in soils in 

rural areas is about 0.07 ng WHO98 TEQP/kg. These values were assumed to apply to all 

three reference years. It is not known how well these estimates represent eroded soil from 

cropland and rangeland and were given a preliminary confidence rating. Multiplying the 

emission factor and activities, yields CDD/CDF release estimates of 4,900, 4,400 and 

4,200 g WHO98 TEQDF for 1987, 1995, and 2000, respectively. Similarly, the PCB release 

estimates were calculated as 200, 180, and 170 g WHO98 TEQP for 1987, 1995, and 2000, 

respectively. These release estimates have preliminary confidence ratings because the emission 

factor has a preliminary rating. 

11.1.3. Estimated Annual Releases from Soil to Air 

 As discussed in the original report, a number of investigators have studied releases from 

soil to air, but no quantitative estimates of the mass of dioxin-like compounds that may be 

released to the atmosphere annually from U.S. soils have been published in the literature and 

none were developed for this report. Particulate dioxin concentrations were compared with 

average total particulate dioxin levels to arrive at the conclusion that soil reentrainment could 

account for only 1 to 4% of the particulate dioxins in the atmosphere in urban areas and 0.1 to 

0.3% of those in rural regions (Kao and Venkataraman, 1995). 

The inventory decision criteria and releases to all media are summarized below: 
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Inventory Decision Criteria for Soil Reservoirs

Air Water Solids Products

Emission tests for at least two units/source types with 

sufficient documentation to directly derive emission 

factors.

Yes

Measured emission factors consistent or have 

understandable differences.

No

Emission factor tests represent units that are typical of 

the class.

No

Activity estimates based on source-specific surveys. Yes

Conclusion (Q = Quantitative, P = Preliminary). P

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Soil Reservoirs

Releases to Air

Not quantifiable. 

Releases to Urban Water

Emission Factors 

• 1987―1 pg WHO98 TEQDF/L (1 pg I-TEQDF/L) (Preliminary). 

• 1995―1 pg WHO98 TEQDF/L (1 pg I-TEQDF/L) (Preliminary). 

• 2000―1 pg WHO98 TEQDF/L (1 pg I-TEQDF/L) (Preliminary).

Activity Levels 

• 1987―1.24 × 1014 L/yr. 

• 1995―1.33 × 1014 L/yr. 

• 2000―1.42 × 1014 L/yr.

Releases

• 1987―120 g (WHO98 TEQDF or I-TEQDF) (Preliminary). 

• 1995―130 g (WHO98 TEQDF or I-TEQDF) (Preliminary). 

• 2000―140 g (WHO98 TEQDF or I-TEQDF) (Preliminary).

Release to Rural Water 

Emission Factors 

• 1987―1.7 ng WHO98 TEQDF/kg (Preliminary) and 

0.07 ng WHO98 TEQP/kg (Preliminary). 

• 1995―1.7 ng WHO98 TEQDF/kg (Preliminary) and 

0.07 ng WHO98 TEQP/kg (Preliminary). 

• 2000―1.7 ng WHO98 TEQDF/kg (Preliminary) and 

0.07 ng WHO98 TEQP/kg (Preliminary).

Activity Levels 

• 1987―2.91 billion MT of soil. 

• 1995―2.62 billion MT of soil. 

• 2000―2.46 billion MT of soil.

Releases

• 1987―4,900 g WHO98 TEQDF (Preliminary) and 200 g WHO98 TEQP (Preliminary). 

• 1995―4,500 g WHO98 TEQDF (Preliminary) and 180 g WHO98 TEQP (Preliminary). 

• 2000―4,200 g WHO98 TEQDF (Preliminary) and 170 g WHO98 TEQP (Preliminary).

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11.2. WATER RESERVOIRS (ORIGINALLY SECTION 11.2.2) 

 As discussed in the original report, water reservoirs have the potential for releases to air 

or sediment, but no quantifiable estimates could be made. 
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Water Reservoirs

Releases to Air

Not quantifiable. 

Releases to Sediment

Not quantifiable. 

11.3. SEDIMENT RESERVOIRS (ORIGINALLY SECTION 11.2.3) 

The original report used assumptions about the water surface area, sediment depth, and 

background TEQ concentration for U.S. sediments to estimate that at least 

120 kg WHO98 TEQDF (120 kg I-TEQDF) are present in the sediment reservoir.

 

11.3.1. Mechanisms Responsible for Supply to and Releases from Sediment

The original report identified atmospheric deposition of CDDs and CDFs as an important 

mechanism for CDD/CDFs to enter sediments and those sediments are a likely sink for these 

compounds because they are strongly bound to organic particles in the sediment. 

11.3.2. Releases from Sediment to Water

As discussed in the original report, studies have attempted to evaluate the transfers from 

sediment to water to air, but the information needed to estimate this release nationally is lacking. 

For this reason, no quantitative estimates can be made for annual releases from sediment 

reservoirs to water. 

Sediment Reservoirs

Releases to Water

Not quantifiable.

11.4. BIOTA RESERVOIRS (ORIGINALLY SECTION 11.2.4) 

CDD/CDFs are found in all types of biota including vegetative matter and animal tissues. 

No studies were found that estimated the mass of CDD/CDFs in biota in the United States. 
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1 11.4.1. Mechanisms Responsible for Supply to and Releases from Biota

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The original report identified vapor absorption and desorption as an important 

mechanism for plants and ingestion/bioaccumulation as an important mechanism for animals.

11.4.2. Approaches for Measuring and Estimating Releases from Biota

The original report describes a number of studies that evaluate the CDD/CDF releases 

from biota to soil and air, but insufficient information is available to make quantitative estimates 

for national releases. 

Biota Reservoirs

Releases to Air

Not quantifiable. 

Releases to Soil

Not quantifiable. 

11.5. PRODUCT RESERVOIRS

This is a new section. As discussed in Chapter 8, a number of chemical products contain 

CDD/CDFs. Some of these can be considered reservoirs because they have the potential for 

CDD/CDF releases after their initial use. Others are used in a manner such that any releases 

would occur during their initial use, and therefore, they are not considered a reservoir for future 

releases. For example, 2,4-D is a pesticide that is applied to foliage and would have an 

immediate release to biota and soil. Although it may persist in the environment after application, 

it would become part of the biota or soil reservoir rather than a separate product reservoir. 

Similarly, chlorobenzenes are used as pesticides or chemical intermediates for pesticides and, 

therefore, are not considered product reservoirs. The products that may represent potential 

reservoirs are discussed below. 

11.5.1. Bleached Chemical Wood Pulp

The primary discussion of potential dioxin releases from the bleached chemical wood 

pulp and paper industry is presented in Section 8.1. Many products made from bleached 

chemical wood pulp remain in use long after their production and, therefore, represent a potential 

reservoir. The limited data available on the dioxin concentrations in these products indicate 
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1 decreasing levels over time, but the data are insufficient to make a reliable estimate of the 

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cumulative amounts. As reported in Section 8.1, wood pulp is estimated to have contained 

500 g WHO98 TEQ in 1987, 40 g WHO98 TEQ in 1995, and 0.6 g WHO98 TEQ in 2000. The 

total reservoir of CDD/CDFs in these products would be the cumulative amount of these 

products remaining in use minus any degradation or releases that have occurred. Insufficient 

information is available to estimate the size of the total reservoir or the possible releases.

11.5.2. Chlorophenols

 The primary discussion of potential dioxin releases from chlorophenol production is 

presented in Section 8.4. The lower-chlorinated phenols have been used primarily as chemical 

intermediates in the manufacture of other pesticides. Pesticides are typically used the same year 

as they are produced and, therefore, are not a reservoir for future releases. The 

higher-chlorinated phenols (tetrachlorophenol and PCP) and their sodium salts have been used 

primarily for wood preservation. Wood products treated with these chemicals have long service 

lives and represent a potential reservoir. As discussed in Chapter 8, an estimate of average 

annual domestic PCP consumption during the period of 1970 to 1995 is about 400,000 MT. As 

reported in Section 8.4, PCP is estimated to have contained 20,000 g WHO98 TEQ in 1987, 

4,800 g WHO TEQ in 1995, and 4,200 g WHO98 TEQ in 2000. The limited data available on the 

dioxin concentrations in these products indicate decreasing levels over time, but the data are 

insufficient to make a reliable estimate of the cumulative amounts. It is unknown how much of 

the CDD/CDFs degrade in situ or escapes from the wood into the environment. Several recent 

field studies, as discussed in Chapter 8, demonstrate that CDD/CDFs do apparently leach into 

soil from PCP-treated wood, but the studies do not provide release-rate data. No studies were

located that provide any measured CDD/CDF volatilization rates from PCP-treated wood. 

Although CDD/CDFs have very low vapor pressures, they are not bound to, nor do they react 

with, the wood in any way that would preclude volatilization. Several studies (see Chapter 8) 

have attempted to estimate potential CDD/CDF volatilization releases using conservative 

assumptions or modeling approaches, but these estimates span many orders of magnitude. 

Insufficient information is available to estimate the size of the total reservoir or the possible 

releases.
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1 11.5.3. Vinyl Chloride Products

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The primary discussion of potential dioxin releases from vinyl chloride production is 

presented in Section 8.3. Many vinyl chloride products remain in use long after their production 

and, therefore, represent a potential reservoir. Limited data are available on the dioxin 

concentrations in these products, but the data are insufficient to make a reliable estimate of the 

cumulative amounts. As discussed in Section 8.3, concentration and production data can be used 

to estimate that vinyl chloride contained 0.02 g I-TEQ in 1995 and 0.02 g I-TEQ in 2000. The 

total reservoir of CDD/CDFs in these products would be the cumulative amount of these 

products remaining in use minus any degradation or releases that have occurred. Insufficient 

information is available to estimate the size of the total reservoir or the possible releases.

11.5.4. Chloranil 

The primary discussion of potential dioxin releases from chloranil production is 

presented in Section 8.9. Chloranil is used to make dyes and pigments. These products may 

remain in use long after their production and, therefore, represent a potential reservoir. As 

discussed in Section 8.9, chloranil imports contained 64 g I-TEQ in 1987, 0.4 g I-TEQ in 1995, 

and 1.2 g I-TEQ in 2000. The total reservoir of CDD/CDFs in these products would be the 

cumulative amount of these products remaining in use minus any degradation or releases that 

have occurred. Insufficient information is available to estimate the size of the total reservoir or 

the possible releases.

11.5.5. Polychlorinated Biphenyls (PCBs)

 As discussed in Chapter 10 (the primary chapter on PCBs), production of PCBs ceased in 

the 1970s. However, they were used in a variety of products that can remain in use for long time 

periods, such as transformers and capacitors. The portion of these products that are still in use 

today represents potential reservoirs because releases can occur via leaks or during disposal 

operations. As discussed in the original report (see Section 10.6), approximately 568,000 MT of 

PCBs were used in the United States between 1930 and 1975. An estimated 50.3% were used in 

capacitors, and 26.8% were used in transformers. Assuming that these products contained an 

average of 8 mg WHO98 TEQP/kg (average concentration for Aroclor 1242, which accounted for 

over 50% of total sales―see Section 10.6 of original report), then a total of 3,500 kg of 
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material is still in use or what amount of releases may be occurring. 

 In summary, five possible product reservoirs were identified: bleached chemical wood 

pulp, pentachlorophenol, vinyl chloride, chloranil, and PCBs. No estimates could be made for 

the cumulative mass of CDD/CDFs contained in these reservoirs or their releases.

Product Reservoirs

Releases to Air

Bleached Chemical Wood Pulp (Not quantifiable).

Pentachlorophenol (Not quantifiable). 

Vinylchloride (Not quantifiable). 

Chloranil (Not quantifiable). 

PCBs (Not quantifiable).

Releases to Soil

Bleached Chemical Wood Pulp (Not quantifiable).

Pentachlorophenol (Not quantifiable). 

Vinylchloride (Not quantifiable). 

Chloranil (Not quantifiable).

PCBs (Not quantifiable).

11.6. SUMMARY AND CONCLUSIONS (ORIGINALLY SECTION 11.3) 

The original report presented a series of conclusions about the relative importance of 

reservoir sources and their implications to human exposure. Because this version of the 

document contains only slight revisions to reservoir source estimates, the same general 

observations made in the previous version still apply. In addition, reservoir sources are all still 

considered "preliminary”, and thus not part of the quantitative inventory. 
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1 Table 11-1. Amounts of CDD/CDFs Landfilled (g WHO98 TEQ/year)

Source 1987 1995 2000

Municipal waste incinerators 2800 490 490

Medical waste incinerators 760 410 320

Animal crematoria 0.2 0.2 0.2

Sewage sludge 0.4 1 0.7

Industrial wood 46 46 46

Industrial coal-fired utilities 39 43 50

Cement kilns 15 18 13

Magnesium smelting and refining 10a

Titanium smelting and refining 240a

Chlor-akali plants 3

Vinyl chloride plants 6

Complex organic chemical plants 118

Municipal wastewater treatment sludge 86 40 13

Total 3,750 1,050 1,310

a

Based on TRI data (U.S. EPA, 2008).
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Figure 11-1. Fluxes among environmental reservoirs. 
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REFERENCES 

Abad, E; Martinez, K; Caixach, J; et al. (2006) Polychlorinated dibenzo-p-dioxins, dibenzofurans and ‘dioxin-like’ 

PCBs in flue gas emissions from municipal waste management plants. Chemosphere 63(4):570–580.

Ahlborg, UG; Becking, GC; Birnbaum, LS; et al. (1994) Toxic equivalency factors for dioxin-like PCBs: report on a 

WHO-ECEH and IPCS consultation, December 1993. Chemosphere 28(6):1049−1067.

AF&PA (American Forest and Paper Association). (1997) Paper, paperboard, and wood pulp statistics: data through 

1996. Washington, DC.

AISI (American Iron and Steel Institute). (1990) Annual statistical report, 1989. Washington, DC: AISI. 

API (American Paper Institute). (1992) Statistics of paper, paperboard, and wood pulp: data through 1991. New 

York, NY.

AWPA (American Wood Preservers Association). (1977) Pentachlorophenol: a wood preservative. McLean, VA. 

AWPI (American Wood Preservers Institute). (1995) 1994 Wood preserving industry production statistical report. 

McLean, VA.

Aries, E; Anderson, DR; Fisher, R; et al. (2006). PCDD/F and “Dioxin-like” PCB emissions from iron ore sintering 

plants in the UK. Chemosphere 65(9):1470−1480

ATSDR (Agency for Toxic Substances and Disease Registry). (1997) Toxicological profile for hexachloroethane. 

Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service

Aurell, J.; Gullett, B.K. (2010) Aerostat sampling of PCDD/PCDF emissions from the Gulf oil spill in situ burns. 

Environ. Sci. Technol. 44(24):9431–9437.

Bacher, R; Swerev, M; Ballschmiter, K. (1992) Profile and pattern of monochloro-through 

octachlorodibenzodioxins and dibenzofurans in chimney deposits from wood burning. Environ Sci Technol 

26(8):1649−1655.

Ballschmiter, K; Buchert, H; Niemczyk, R; et al. (1986) Automobile exhausts versus municipal waste incineration 

as sources of the polychloro-dibenzodioxins (PCDD) and -furans (PCDF) found in the environment. Chemosphere 

15(7):901−915.

Bell, A. (1999) AB2588 emissions testing at California Portland Cement Company’s Colton Plant; coal firing and 

coal with tires firing. Prepared for California Portland Cement Company; for submittal to South Coast Air Quality 

Management District. Prepared by Delta Air Quality Services, Inc., Glendora, CA. 

Brady, NC. (1984). The nature and properties of soils. 9th ed. New York, NY: Macmillan Publishing Co.

Bremmer, HJ; Troost, LM; Kuipers, G; et al. (1994) Emissions of dioxins in The Netherlands. National Institute of 

Public Health and Environmental Protection (RIVM) and Netherlands Organization for Applied Scientific Research 

(TNO). Report No. 770501018.

Brodsky, ES; Kucherenko, AV; Jilnikov, VG; et al., (2003). PCB emission in the combustion processes. 

Organohalogen Compd, Volumes 60−65, Dioxin 2003 Boston, MA. Available online at 

http://www.dioxin.ru/publ/Organohalogen_Compounds_2003_63_17-20.pdf. 

Brown, A. (2002) 2002 North Carolina flue-cured tobacco production guide.

http://ipm.ncsu.edu/getsubs2.cfm?TopicID=12.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-2 DRAFT: DO NOT CITE OR QUOTE

Bryant, JG. (1993) Chlorinated benzenes. In: Kirk-Othmer encyclopedia of chemical technology. 4th ed.; Vol. 6, 

Chlorocarbons and Chlorohydrocarbons-C. New York: Wiley Interscience; pp. 87−100.

Brzuzy, LP; Hites, RA. (1995). Estimating the atmospheric deposition of polychlorinated dienzo-p-dioxins and 

dibenzofurans from soils. Environ Sci Technol 29:2090−2098.

Buckland, SJ; Dye, EA; Leathem, SV; et al. (1994) The levels of PCDDs and PCDFs in soil samples collected from 

conservation areas following brush fires. Organohalogen Compd 20:85−89.

Bumb, RR; Crummett, WB; Cutie, SS; et al. (1980) Trace chemistries of fire: a source of chlorinated dioxins. 

Science 210(4468):385−390.

Buser, HR; Bosshardt, HP. (1976) Determination of polychlorinated dibenzo-p-dioxins and dibenzofurans in 

commercial pentachlorophenols by combined gas chromatography-mass spectrometry. J Assoc Off Anal Chem

59(3):562−569.

Cains, PW; Dyke, P. (1994) Emissions of chlorinated dibenzodioxins and dibenzofurans from waste combustion 

plants in the UK. Organohalogen Compd 20:271−276.

Calcagni, J; Ciolek, M; Mulrine, P. (1998) Dioxin emissions from U.S. sinter plants. U.S. Environmental Protection 

Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC.

CANA (Cremation Association of North America). (2006) Historical statistics (provides data for 1876B2005, based 

on the number of deaths, the number of crematories, and the number of cremations for both the United States and 

Canada).

CARB (California Air Resources Board). (1990) Compliance testing for non-criteria pollutants at a landfill flare. 

Engineering Evaluation Branch, Monitoring and Laboratory Division, Sacramento, CA. Confidential Report No. 

ERC-2. 

CARB (California Air Resources Board). (1992a) Dioxin/furan estimates from a secondary aluminum facility. 

Engineering Evaluation Branch, Monitoring and Laboratory Division, Sacramento, CA. Confidential Report 

No. ERC-9.

CARB (California Air Resources Board). (1992b) Emission measurements on delacquering system. Engineering 

Evaluation Branch, Monitoring and Laboratory Division, Sacramento, CA. Confidential Report No. ERC-32. 

CARB (California Air Resources Board). (1993) Emissions measurement of toxic compounds from a cupola 

baghouse at a steel foundry. Engineering Evaluation Branch, Monitoring and Laboratory Division, Sacramento, CA. 

Confidential Report No. ERC-61. 

Carpenter, C; Schweer, G; Stinnett, G; et al. (1986) Exposure assessment for hexachlorobenzene. U.S. 

Environmental Protection Agency, Office of Toxic Substances, Washington, DC; EPA 560/5-86-019.

Carroll, WF. (1996) Is PVC in house fires the great unknown source of dioxin? Fire and Materials 20(4):161−166.

CCC (Chlorine Chemistry Council). (2004) CDD/CDF data validation project. CDD/CDF release estimates for 

Occidental Chemical Corporation: Convent, LA; Deer Park (VCM Plant), TX; Ingleside, TX; LaPorte, TX; 

Mobile, AL. 

CDC (Centers for Desease Control and Prevention) (1985) Polychlorinated biphenyl transformer incident – Mew 

Mexico. MMWR 34(36):557−559. Available online at 

http://www.cdc.gov/mmwr/preview/mmwrhtml/00000609.htm. 

CEQ (Council on Environmental Quality). (1997). 25th Anniversary Report. Council on Environmental Quality, 

Executive Office of the President of the United States, Washington, DC. 

http://ceq.hss.doe.gov/ceq_reports/annual_environmental_quality_reports.html
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-3 DRAFT: DO NOT CITE OR QUOTE

ChemRisk. (1993) Critique of dioxin factories. Prepared for The Vinyl Institute.

Chlorine Institute (2010) Chlorine manufacture. Arlington, Va: the Chorine Institute, Inc. Available online at 

http://www.chlorineinstitute.org/Stewardship/content.cfm?itemnumber=1039&navItemNumber=3506.

Cianciarelli, D. (2000) Measurement of PCDD/PCDF and hexachlorobenzene emissions from an electric arc furnace 

shop, Dofasco Inc., Hamilton, Ontario. Emissions Research Advancement Division, Environment Canada. Report 

ERMD 99-08. 

Cianciarelli, D. (2001) Characterization of organic emissions from an electric arc furnace, Gerdau Courtice Steel 

Inc., Cambridge, Ontario. Emissions Research and Measurement Division, Environmental Technology 

Advancement Directorate, Environment Canada. Report ERMD 2000-05. 

Charles E. Napier Company, Ltd. (2000) Draft: background technical discussion paper on the release and control of 

dioxins/furans from the steel sector. Prepared for Environment Canada, Minerals and Metals Division, Ottawa, 

Canada.

Clement, RE; Tosine, HM; Ali, B. (1985) Levels of polychlorinated dibenzo-p-dioxins and dibenzofurans in wood 

burning stoves and fireplaces. Chemosphere 14(6−7):815−819.

Cleverly, D.; Monetti, M.; Phillips, L.; et al. (1996) A time-trends study of the occurrences and levels of CDDs, 

CDFs and dioxin-like PCBs in sediment cores from 11 geographically distributed lakes in the United States.

Organohalogen Compd 28:77−82.

Colburn, Ken (1996). States’ Report on electric utility nitrogen oxides reduction technology options for application 

by the Ozone Transport Assessment Group. Available online at

http://www.epa.gov/ttn/naaqs/ozone/rto/otag/finalrpt/chp5/appa.htm.

Collet, S; Fiani, E. (2006) PAH, PCB and PCDD/F emissions from simulated forest and landfill fires. 

Organohalogen Compd 68:856–859.

Council of Great Lakes Industries. (1999) Octachlorostyrene and suggested industrial sources. A report to the Great 

Lakes Binational Toxics Strategy OCS Workgroup. Council of Great Lakes Industries, Ann Arbor, MI. Available 

online at http://www.cgli.org/binationalToxics/BiToxOxy.pdf.

Cramer, PH; Heiman, J; Horrigan, M; et al. (1995) Results of a national survey for polychlorinated 

dibenzo-p-dioxins, dibenzofurans, and coplanar polychlorinated biphenyls in municipal biosolids. Organohalogen 

Compd 24:305−308.

CRE (Coal Research Establishment). (1994) Emissions of environmental concern from coal utilization. Coal 

Research Establishment, National Coal Board, Stoke Orchard, United Kingdom. Report number 

ECSC 7220-EC/011. 

Cull, MR; Dobbs, AJ; Goudot, M; et al. (1984) Polychlorodibenzo-p-dioxins and dibenzofurans in technical 

pentachlorophenol-results of a collaborative analytical exercise. Chemosphere 13(10):1157−1165.

Curlin, LC; Bommaraju, TV. (1991) Alkali and chlorine products. In: Kirk-Othmer encyclopedia of chemical 

technology. 4th ed. New York: Wiley-Interscience; pp. 938−1025.

Dempsey, CR; Oppelt, ET. (1993) Incineration of hazardous waste: a critical review update. Air and Waste 

43:25−73.

Douben, PET; Eduljee, GH; Dyke, P. (1995) A review of potential PCDD and PCDF emission sources in the UK. 

Organohalogen Compd 24:131−136.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-4 DRAFT: DO NOT CITE OR QUOTE

Duarte-Davidson, R; Sewart, A; Alcock, RE; et al. (1997) Exploring the balance between sources, deposition and 

the environmental burden of PCDD/Fs in the U.K. terrestrial environment: an aid to identifying uncertainties and 

research needs. Environ Sci Technol 31(1):1−11.

Dumler-Gradl, R; Thoma, H; Vierle, O. (1995) Research program on dioxin/furan concentrations in chimney soot 

from house heating systems in the Bavarian area. Organohalogen Compd 24:115−118.

Dyke, PH (2002) PCB and PAH releases from incineration and power generation processes. R&D Technical Report 

P4-052. Bristol, UK: Environment Agency. Available online at 

http://www.pops.int/documents/guidance/NIPsFinal/techrep.pdf.

Dyke, PH; Amendola, G (2007) Dioxin releases from US chemical industry sites manufacturing or using chlorine. 

Chemosphere 67(11):S125–S134.

Dyke, PH; Foan, C; Wenborn, M; et al. (1997) A review of dioxin releases to land and water in the UK. Sci Total 

Environ 207(2−3):119−131.

Dyke, PH; Foan, C; Fiedler, H. (2003) PCB and PAH releases from power stations and waste incineration processes 

in the UK Chemosphere 50(4):469–480.

Edelstein, DL. (1995) Minerals yearbook: copper. U.S. Geological Survey, Geologic Division, Reston, VA.

Available onlinea at http://minerals.usgs.gov/minerals/pubs/commodity/copper/240495.pdf.

Eduljee, GH; Dyke, P. (1996) An updated inventory of potential PCDD and PCDF emission sources in the UK. Sci 

Total Environ 177(1−3):303−321.

Ehrlich, C; Kalkoff, WD; Albrecht, W. (1996) Industrial emissions of PCDD/F and of dioxin-like PCBs in 

Saxony-Anhalt. Organohalogen Compd 27:50–55.

EIA (Energy Information Administration). (1993) Petroleum supply annual 1992. Vol. 1. U.S. Department of 

Energy, Office of Oil and Gas, Washington, DC; DOE/EIA-0340(92)/1.

EIA (Energy Information Administration). (1999a) State energy data report 1996, consumption estimates. U.S. 

Department of Energy, Office of Energy Markets and End Use, Washington, DC; DOE/EIA-0214(96).

EIA (Energy Information Administration) (1999b) Coal. Available online at http://www.eia.doe.gov/fuelcoal.html.

EIA (Energy Information Administration) (2001) Residential energy consumption. Available online at 

http://www.eia.doe.gov/emeu/consumption/index.html.

EIA (Energy Information Administration). (2002) Annual energy review 2000. Available online at 

www.eia.doe.gov.

EIA (Energy Information Administration) (2006) Coal. Available online at http://www.eia.doe.gov/fuelcoal.html.

EIA (Energy Information Administration) (2008a) Petroleum navigator. Available online at 

http://tonto.eia.doe.gov/dnav/pet/pet_sum_top.asp.

EIA (Energy Information Administration). (2008b) Biomass. Available online at 

http://www.eia.doe.gov/cneaf/solar.renewables/page/biomass/biomass.html.

EIA (Energy Information Administration). (2008c) Manufacturing energy consumption. Available online at 

http://eia.doe.gov/emeu/mecs/.

Environment Canada. (2000) Characterization of organic compounds from selected residential wood stoves and 

fuels. Environment Canada, Emissions Research and Measurement Division, Ottawa, Canada. Report ERMD 

2000-01.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-5 DRAFT: DO NOT CITE OR QUOTE

Environmental Risk Sciences, Inc. (1995) An analysis of the potential for dioxin emissions in the primary copper 

smelting industry. Prepared for the National Mining Association, Washington, DC.

EPRI (Electric Power Research Institute). (1994) Electric utility trace substances synthesis report. Palo Alto, CA; 

EPRI TR-104614.

EPRI (Electric Power Research Institute). (1995) Pentachlorophenol (PCP) in soils adjacent to in-service utility 

poles in New York State. Palo Alto, CA; EPRI TR-104893.

ERG (Eastern Research Group) (2001) Structure Fires. Volume III, Chapter 18. Available online at 

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/iii18_apr2001.pdf.

Erickson, MD (1997). Analytical Chemistry of PCBs, Lewis Publishers, New York.

EU (European Union). (1999) Releases of dioxins and furans to land and water in Europe. Final Report by M 

Wenborn, K King, D Buckley-Golder and J Gason, produced for Landesumweltamt Nordrhein-Westfalen, Germany 

on behalf of the EU Commission DG Environment, September 1999.

Federal Register. (1979) Decision and emergency order suspending registrations for certain uses of 2,4,5-T and 

Silvex. FR (March 15) 44:15874−15920.

Federal Register. (1984) Pentachlorophenol, and inorganic arsenicals; intent to cancel registrations of pesticide 

products containing creosote, pentachlorophenol (including its salts) and the inorganic arsenicals; determination 

concluding the rebuttal presumption against registration of the wood preservative uses of pesticide products; 

availability of position document. FR (July 13) 49:28666−28689.

Federal Register. (1986) Creosote, pentachlorophenol, and inorganic arsenicals; amendment of notice of intent to 

cancel registrations. FR (January 10) 51:1334−1348.

Federal Register. (1987a) Polyhalogenated dibenzo-p-dioxins/dibenzofurans; testing and reporting requirements; 

final rule. FR (June 5) 52:21412−21452.

Federal Register. (1987b) Pentachlorophenol; amendment of notice of intent to cancel registrations. FR (January 2) 

52:140−148.

Federal Register. (1987c) Final determination and intent to cancel and deny applications for registrations of 

pesticide products containing pentachlorophenol (including but not limited to its salts and esters) for non-wood uses. 

FR (January 21) 52:2282−2293.

Federal Register. (1993) Chemicals; toxic chemical release reporting; community right-to-know; significant new use 

rule. FR (December 1) 58:63500−63518.

Federal Register. (1996) Revised standards for hazardous waste combustors: proposed rule. FR (April 19) 

61:17357−17536.

Federal Register. (1998) Source category listing for Section 112(d)(2) rulemaking pursuant to Section 112(c)(6) 

requirements. FR (April 10) 63:17838−17855.

Federal Register. (1999) NESHAPS: final standards for hazardous air pollutants for hazardous waste combustors. 

FR (September 30) 64:52828−53077.

FEMA (Federal Emergency Management Agency). (1997) Fire in the United States. 9th ed. United States Fire 

Administration, Washington, DC. FA-173. Available online at 

http://www.usfa.dhs.gov/downloads/pdf/publications/fius9th.pdf.

FEMA (Federal Emergency Management Agency). (2001) The national fire problem. United States Fire 

Administration, Washington, DC.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-6 DRAFT: DO NOT CITE OR QUOTE

Fenton, M. (1996) Minerals yearbook: iron and steel. U.S. Department of the Interior, U.S. Geological Survey, 

Washington, DC. Available online at http://minerals.usgs.gov/minerals/pubs/commodity/iron_&_steel/350496.pdf.

Fiedler, H; Chareonsong, P, Mayer, J; et al. (2002) PCDD/PCDF emissions from stationary sources – first results 

from Thailand. Organohalogen Compd 59:211−214.

Firestone, D; Ress, J; Brown, NL; et al. (1972) Determination of polychlorodibenzo-p-dioxins and related 

compounds in commercial chlorophenols. J Assoc Off Anal Chem 55(1):85−92.

Fisher, R; Anderson, DR; Wilson, DT; et al. (2004) Effect of chloride on the formation of PCDD/Fs and 

WHO-12 PCBs in iron ore sintering. Organohalogen Compd 66:1132−1139.

Forbes RM, AR Cooper and HH Mitchell, 1953. The composition of the adult human body as determined by 

chemical analysis. J Biol Chem:359-366. http://www.jbc.org/content/203/1/359.full.pdf

François, F; Blondeel, M; Bernaert, P; et al. (2004) Diffuse emissions of PCDD/F and dioxin-like PCB from 

industrial sources in the Flemish Region. Organohalogen Compd 66:921−927.

François, F; Blondeel, M; Bernaert, P; et al. (2005) Dioxin-like PCB emissions in the Flemish Region (Belgium). 

Organohalogen Compd 67:2140−2143

Freeman, HM (1995). Industrial pollution prevention handbook. McGraw-Hill, Inc., New York, NY.

Frey, HC; Zhao, Y. (2004) Quantification of variability and uncertainty for air toxic emission inventories with 

censored emission factor data. Environ Sci Technol 38(22):6094−6100.

Gertler, AW; Sagebiel, JC; Dippel, WA; et al. (1996) A study to quantify on-road emissions of dioxins and furans 

from mobile sources: phase 2. Energy and Environmental Engineering Center, Desert Research Institute, Reno, 

NV. 

Gertler, A; Sagebiel, J; Dippel, W; et al. (1998) Measurements of dioxin and furan emissions factors from heavy 

duty diesel vehicles. J Air Waste Mgmt Assoc 48(3):276−278.

Gilman, AP; Douglas, VM; Newhook, RC; et al. (1988) Chlorophenols and their impurities: a health hazard 

evaluation. Health and Welfare Canada. Document No. H46-2/88-110E.

Gonczi, M; Gunnarsson, M; Hedman, B; et al. (2005) Emissions of PCD/F and PCB from uncontrolled combustion 

of domestic waste in Sweden. Organohalogen Compd 67:2033−2036.

Gras, J; Meyer, C; Weeks, I; et al. (2002) Emissions from domestic solid fuel burning appliances (wood-heaters, 

open fireplaces). Technical Report No. 5. Environment Australia, March 2002. Available online at 

http://www.environment.gov.au/atmosphere/airquality/publications/report5/chapter4.html#4-3.

Green, LC; Lester, RL; Armstrong, SR. (1995) Comments on EPA’s external review draft estimating exposures to 

dioxin-like compounds. Cambridge Environmental Inc., Cambridge, MA. 

Greenpeace. (1993) Dioxin factories: a study of the creation and discharge of dioxins and other organochlorines 

from the production of PVC. Greenpeace International, Amsterdam, The Netherlands.

Gullett, BK; Ryan, JV. (2002) On-road emissions of PCDDs and PCDFs from heavy duty diesel vehicles. Environ 

Sci Technol 36(13):3036−3040.

Gullett, B; Touati, A. (2003) PCDD/F emissions from forest fire simulations. Atmos Environ 37:803−813.

Gullett, BK; Lemieux, PM; Lutes, CC; et al. (1999) PCDD/F emissions from uncontrolled, domestic waste burning. 

Organohalogen Compd 41:27−30.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-7 DRAFT: DO NOT CITE OR QUOTE

Gullett, BK; Lemieux, PM; Winterrowd, CK; et al. (2000) PCDD/F emissions from uncontrolled, domestic waste 

burning. Organohalogen Compd 46:193−196.

Gullett, BK; Touati, A; Hays, MD. (2003) PCDD/F, PCB, HxCBz, PAH, and PM emission factors for fireplace and 

woodstove combustion in the San Francisco Bay Region. Environ Sci Technol 37(9):1758−1765

Gullet, BK; Touati, A; Huwe, J; et al. (2006) PCDD and PCDF emissions from simulated sugarcane field burning. 

Environ Sci Technol 40(20):6228−6234.

Gullet, B; Touati, A; Oudejans, L. (2008) PCDD/F and aromatic emissions from simulated forest and grassland 

fires. Atmospheric Environment 42:7997−8006.

Gurprasad, N; Constable, M; Haidar, N; et al. (1995) Polychlorinated dibenzo-p-dioxins (PCDDs) leaching from 

pentachlorophenol-treated utility poles. Organohalogen Compd 24:501−504.

Hagenmaier, H; Brunner, H. (1987) Isomerspecific analysis of pentachlorophenol and sodium pentachlorophenate 

for 2,3,7,8-substituted PCDD and PCDF at sub-ppb levels. Chemosphere 16(8−9):1759−1764.

Hagenmaier, H; Dawidowsky, V; Weber, UB; et al. (1990) Emission of polyhalogenated dibenzodioxins and 

dibenzofurans from combustion-engines. Organohalogen Compd 12:329−334.

Harnly, M; Stephens, R; McLaughlin, C; et al. (1995) Polychlorinated dibenzo-p-dioxin and dibenzofuran 

contamination at metal recovery facilities, open burn sites, and a railroad car incineration facility. Environ Sci 

Technol 29(3):677−684.

Harrad, SJ; Jones, KC. (1992) A source inventory and budget for chlorinated dioxins and furans in the United 

Kingdom environment. Sci Total Environ 126(1−2):89−107.

Harrad, SJ; Malloy, TA; Khan, MA; et al. (1991) Levels and sources of PCDDs, PCDFs, chlorophenols (CPs) and 

chlorobenzenes (CBzs) in composts from a municipal yard waste composting facility. Chemosphere 

23(2):181−191.

Hedman, B; Näslund. M; Nilsson, C; et al. (2005) Emissions of polychlorinated dibenzodioxins and dibenzofurans 

and polychlorinated biphenyls from uncontrolled burning of garden and domestic waste (backyard burning). 

Environ Sci Technol 39 (22):8790−8796.

Hirai Y, Shin-ichi Sakai, Tatsuya Kunisue, Shinsuke Tanabe (2003). Emission factors for uncontrolled burning and 

simulation of PCDD/F contamination in open dumping sites. Organohalogen Compounds 60-65, Dioxin 2003. 

Boston, MA

Hovemann, A.; Steeg, W.; Rabl, H. P.; Bock, M.; Helm, M.; Pfaffinger, (2010). A. PCDD/PCDF Emissions of 

modern diesel direct injection powertrains and their aftertreatment system. Presented at the 30th International 

Symposium on Halogenated Persistent Organic Pollutants, San Antonio, TX, 2010.

Hutzinger, O; Fiedler, H. (1991) Formation of dioxins and related compounds in industrial processes. In: 

Bretthauer, EW; Kraus, HW; di Domenico, A; eds. Dioxin perspectives. A pilot study on international information 

exchange on dioxins and related compounds. New York, NY: Plenum Press.

Ikeguchi, T; Tanaka, M. (1999) Experimental study of dioxin emission from open burning simulation of selected 

wastes. Organohalogen Compd 41:507−510.

IPPC (Integrated pollution prevention and control) (2001) Reference document on best available techniques in the 

cement and lime manufacturing industries. European Commission, Technologies for Sustainable Development, 

European IPPC Bureau, Seville, Spain.

Kao, AS; Venkataraman, C. (1995) Estimating the contribution of reentrainment to the atmospheric deposition of 

dioxin. Chemosphere 31(10):4317−4331.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-8 DRAFT: DO NOT CITE OR QUOTE

Kim, K-S; Hong, K-H; Ko, Y-H; et al. (2003) Emission characteristics of PCDD/Fs in diesel engine with variable 

load rate. Chemosphere 53(6):601−607.

Kim, K-S; Hong, K-H; Ko, Y-H. (2004a) Emission characteristics of PCDD/Fs, PCBs, chlorobenzenes, 

chlorophenols, and PAHs from polyvinylchloride combustion at various temperatures. J Air Waste Manage Assoc 

54(5):555−562.

Kim, S-C; Choe, S-H; Na, J-G; et al. (2004b) Correlations of emission concentrations among PCDDs/PCDFs, 

co-planar PCBs and HCB from major thermal stationary sources. Organohalogen Compd 66:926−930.

Kim, S-C; Hwang, S-R; Kim, K-H; et al. (2005) Emission characteristics of coplanar PCBs in stationary thermal 

sources. Organohalogen Compd 67:2008−2010.

Kobylecki, R; Ohira, K; Ito, I; et al. (2001) Dioxin and fly ash free incineration by ash pelletization and reburning. 

Environ Sci Technol 35:4313−4319.

Kucherenko, AV; Klyuev, NA; Yufit, SS; et al. (2001) Study of dioxin sources in Krasnoyarsk, Russia. 

Organohalogen Compd 53:275−278.

Laroo, C. A.; Schenk, C. R.; Sanchez, L. J.; McDonald, J. (2011) Emissions of PCDD/Fs, PCBs, and PAHs from a 

Modern Diesel Engine Equipped with Catalyzed Emission Control Systems. Environ. Sci. Technol. 45 (15), 6420-

6428.

Lebeuf, M.; Gobell, C.; Clermont, Y. (1995) Non-ortho chlorophenyls in fish and sediments of the Estuary and Gulf 

of St. Lawrence. Organohalogen Compd 26:421−426.

Lemieux, PM. (1997) Evaluation of emissions from the open burning of household waste in barrels. Vol 1. 

Technical report. U.S. Environmental Protection Agency, National Risk Management Research Laboratory, 

Research Triangle Park, NC; EPA-600/R-97-134a. Available online at 

http://www.ecy.wa.gov/programs/air/outdoor_woodsmoke/PDFs/EPAbarlbrn1.pdf.

Lemieux, PM; Gullett, BK; Lutes, CC; et al. (2000) Parameters influencing emissions of PCDDs/Fs from open 

burning of household waste in barrels. Presented at AWMA/Environment Canada specialty conference on recent 

advances in the science and management of air toxics, April 10−12, 2000, Banff, Alberta, Canada.

Liu, Z. G.; Wall, J. C.; Barge, P.; Dettmann, M. E.; Ottinger, N. A. (2011) Investigation of PCDD/F emissions from 

mobile source diesel engines: impact of copper zeolite SCR catalysts and exhaust aftertreatment configurations. 

Environ. Sci. Technol. 45 (7), 2965–2972.

Löfroth, G; Zebühr, Y. (1992) Polychlorinated dibenzo-p-dioxins (PCDDs) and dibenzofurans (PCDFs) in 

mainstream and sidestream cigarette smoke. Bull Environ Contam Toxicol 48(6):789−794.

Lorber, M; Fries, G; Winters, D; et al. (2000) A study of the mass balance of dioxins and furans in lactating cows in 

background conditions. Organohalogen Compd 46:236−239 and 534−537.

Lorber, M; Barton, RG; Winters, DL; et al. (2002) Investigation of the potential release of polychlorinated dioxins 

and furans from PCP-treated utility poles. Sci Total Environ 290:15−39.

LUA (Landesumweltamt Nordrhein-Westfalen). (1997) Identification of relevant industrial sources of dioxins and 

furans in Europe. Materialien No. 43. North Rhine-Westphalia State Environment Agency, Essen, Germany. 

ISSN 0947-5206.

Lykins, BW; Clark, R; Cleverly, DH. (1987) Polychlorinated dioxin and furan discharge during carbon reactivation. 

J Environ Engin 114(2):300−316.

Mannsville. (1983) Mannsville chemical products synopsis. Cortland, NY: Mannsville Chemical Products Corp. 

December 1983.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-9 DRAFT: DO NOT CITE OR QUOTE

Marklund, S; Rappe, C; Tysklind, M; et al. (1987) Identification of polychlorinated dibenzofurans and dioxins in 

exhausts from cars run on leaded gasoline. Chemosphere 16(1):29−36.

Marklund, S; Andersson, R; Tysklind, M; et al. (1990) Emissions of PCDDs and PCDFs in gasoline and diesel 

fueled cars. Chemosphere 20(5):553−561.

Matsueda, T; Kurokawa, Y; Nakamura, M; et al. (1994) Concentrations of PCDDs, PCDFs and coplanar PCBs in 

cigarettes from various countries. Organohalogen Compd 20:331−334.

Mayer, A; Heeb, N; Czerwinski, J; Wyser, M. (2003) Secondary emissions from catalytic active particle filter 

systems. SAE Transactions 112(4):159−169.

McLachlan, MS; Thoma, H; Reissinger, M; et al. (1990) PCDD/F in an agricultural food chain. Part 1: PCDD/F 

mass balance of a lactating cow. Chemosphere 20:1013.

Merk, M; Schramm, KW; Lenoir, D; et al. (1995) Determination of the PCDD/F concentration in the fumes from a 

PVC fire. Organohalogen Compd 23:491−494.

Meyer, C; Beer, T; Muller, J. (2004) Dioxins emissions from bushfires in Australia – Technical Report No. 1. 

Australian Government, Department of the Environment, Water, Heritage and the Arts. Available online at 

http://www.environment.gov.au/settlements/publications/chemicals/dioxins/report-1/index.html. 

Meyer, CP; Black, RR; Tolhurst, KG; et al. (2007) Emissions of dioxins from bush fires in Australia. 

Organohalogen Compd 69:307−310.

Michaud, JM; Huntley, SL; Sherer, RA; et al. (1994) PCB and dioxin reentry criteria for building surfaces and air. J 

Expo Anal Env Epid 4(2):197−227.

Miller, A. (1993) Dioxin emissions from EDC/VCM plants. Environ Sci Technol 27(6):1014−1015.

Minh, Nguyen Hung; Minh, Tu Binh; Watanabe, Mafumi; Kunisue, Tatsuya; Monirith, I.; Tanabe, Shinsuke; Sakai, 

Shinichi; Subramanian, A.; Sasikumar, K.; Viet, Pham Hung; Tuyen, Bui Cach; Tana, T.S.; Prudente, M.S. (2003). 

Open dumping site in Asian developing countries: a potential source of polychlorinated dibenzo-p-dioxins and 

polychlorinated dibenzofurans. Environmental Science and Technology. 37(8): 1493-1502. 

NCASI (National Council for Air and Stream Improvement). (1995) NCASI summary of PCDD/F emission from 

wood residue and black liquor combustion. Attachment 2 to comments on EPA’s external review draft “Estimating 

exposures to dioxin-like compounds”. Submitted January 13, 1995, New York, NY.

NCASI (National Council for Air and Stream Improvement). (2002) Evaluation of sources of dioxins and dioxinlike compounds in bleached chemical pulp effluents and treatment plant residuals. Technical Bulletin No. 0844. 

Research Triangle Park, NC: National Council for Air and Stream Improvement, Inc.

NESCAUM (Northeast States for Coordinated Air Use Management) (2006) Assessment of outdoor wood-fired 

boilers. Available online at http://www.vtwoodsmoke.org/pdf/OWB-Report3-06.pdf. 

Nestrick, TJ; Lamparski, LL. (1982) Isomer-specific determination of chlorinated dioxins for assessment of 

formation and potential environmental emission from wood combustion. Anal Chem 54(13):2292−2299.

Nestrick, TJ; Lamparski, LL. (1983) Assessment of chlorinated dibenzo-p-dioxin formation and potential emission 

to the environment from wood combustion. Chemosphere 12(4/5):617−626.

NIFC (National Interagency Fire Center) (2010) Website available online at http://www.nifc.gov/. 

Norbeck JM, JArey, N Kado and B Okamoto. (1998) Evaluation of Factors That Affect Diesel Exhaust Toxicity. 

Contract No. 94-312 Submitted to: California Air Resources Board. 

http://cichlid.cert.ucr.edu/research/pubs/detox_final_report.pdf
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-10 DRAFT: DO NOT CITE OR QUOTE

Oehme, M; Mano, S; Bjerke, B. (1989) Formation of polychlorinated dibenzofurans and dibenzo-p-dioxins by 

production processes for magnesium and refined nickel. Chemosphere 18(7−8):1379−1389.

Oehme, M; Larssen, S; Brevik, EM. (1991) Emission factors of PCDD/CDF for road vehicles obtained by a tunnel 

experiment. Chemosphere 23:1699−1708.

Opatick, RE. (1995) Chlorobenzene Producers Association comments on EPA’s external review draft “Estimating 

exposures to dioxin-like compounds”. Chlorobenzene Producers Association, Washington, DC. January 10, 1995.

ORNL (Oak Ridge National Laboratory) (2008) Bioenergy conversion factors. Available online at 

http://bioenergy.ornl.gov/papers/misc/energy_conv.html.

Palmer, FH; Sapudar, RA; Heath, JA; et al. (1988) Chlorinated dibenzo-p-dioxin and dibenzofuran contamination in 

California from chlorophenol wood preservative use. California State Water Resources Control Board. Report No. 

88-5WQ.

Paradiz B, Dilara P , Horák J, De Santi G, Christoph EH, Umlauf G. (2008) An integrated approach to asses the 

PCDD/F emissions of the coal fired stoves combining emission measurements and ambient air levels modeling. 

Chemosphere 73: S94–S100.

PCA (Portland Cement Association). (2001) U.S. and Canadian Portland Cement Industry: plant information 

summary. PCA: Skokie, Illinois.

Persson, PE; Bergström, J. (1991) Emission of chlorinated dioxins from landfill fires. In: Proceedings of the 

Sardinia 91: Third International Landfill Symposium, Vol. 1. CISA: Cagliari, Italy; pp. 1635−1645.

Pleil, J; Lorber, M. (2007) Relative congener scaling of polychlorinated dibenzo-p-dioxins and dibenzofurans to 

estimate building fire contributions in air, surface wipes, and dust samples. Environ Sci Technol 41(21):7286−7293.

Plimmer, JR. (1980) Herbicides. In: Kirk-Othmer encyclopedia of chemical technology. 3rd ed. Vol. 12. New 

York:Wiley-Interscience; pp. 297−351.

Quass, U; Fermann, M; Bröker, G. (2001) European dioxin inventory. Stage II. North Rhine-Westphalia State 

Environment Agency (LUA NRW), Dusseldorf, Germany. Available online at 

http://ec.europa.eu/environment/dioxin/download.htm.

Ragland, KW; Aerts, DJ; Baker, AJ. (1991) Properties of wood for combustion analysis. Bioresour Technol 

37:161−168.

Rappe, C. (1993) Sources of exposure, environmental concentrations and exposure assessment of PCDDs and 

PCDFs. Chemosphere 27(1−3):211−225.

Rappe, C. (1995) Comments submitted to EPA by the Integrated Waste Services Association on EPA’s “Estimating 

exposure to dioxin-like compounds”. Washington, DC: Integrated Waste Services Association. January 13, 1995.

Rappe, C; Marklund, S. (1978) Formation of polychlorinated dibenzo-p-dioxins (PCDDs) and dibenzofurans 

(PCDFs) by burning or heating chlorophenates. Chemosphere 7(3):269−281.

Rappe, C; Gara, A; Buser, HR. (1978) Identification of polychlorinated dibenzofurans (PCDFs) in commercial 

chlorophenol formulations. Chemosphere 7(12):981−991.

Rappe, C; Glas, B; Kjeller, LO; et al. (1990) Levels of PCDDs and PCDFs in products and effluent from the 

Swedish pulp and paper industry and chloralkali process. Chemosphere 20(10−12):1701−1706.

Rappe, C; Kjeller, L; Kulp, S; et al. (1991) Levels, profile and pattern of PCDDs and PCDFs in samples related to 

the production and use of chlorine. Chemosphere 23(11−12):1629−1636.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-11 DRAFT: DO NOT CITE OR QUOTE

Ree, KC; Evers, EHG; Van Der Berg, M. (1988) Mechanism of formation of polychlorinated dibenzo(p)dioxins 

(PCDDs) and polychlorinated dibenzofurans (PCDFs) from potential industrial sources. Toxicol Environ Chem 

17(3):171−195.

RIPA (Reusable Industrial Packaging Association). (1997) 1997 Statistics as found on the Reusable Industrial 

Packaging Association (RIPA) webpage. Available online at http://www.reusablepackaging.org/Stats.html.

RMA (Rubber Manufacturers Association). (2002) Statistical report on scrap tire markets. Rubber Manufacturers 

Association, Washington, DC. Available online at http://www.rma.org//scrap_tires/.

Sakai, S., Ukai, T., Takatsuki, H., Nakamura, K., Kinoshita, S., Takasuga, T. (1999) Substance flow analysis of 

coplanar PCBs released from waste incineration processes. Journal of Material Cycles and Waste Management, 

1(1), 62-74. 

Sakai, S; Hayakawa, K; Takatsuki, H; et al. (2001) Dioxin-like PCBs released from waste incineration and their 

deposition flux. Environ Sci Technol 35(18):3601−3607.

Santl, H; Gruber, L; Stöhrer, E. (1994) Some new sources of polychlorinated dibenzodioxins (PCDDs) and 

dibenzofurans (PCDFs) in waste papers and recycled pulps. Chemosphere 29(9−11):1995−2003.

SCEP (State Committee for Emission Protection) (1994) Determination of requirements to limit emissions of 

dioxins and furans - report of the Working Group of the Subcommittee Air/Technology of the State Committee for 

Emission Protection (SCEP) - Germany

Schecter, A; Papke, O; Isaac, J; et al. (1997) 2,3,7,8 Chlorine substituted dioxin and dibenzofuran congeners in 

2,4-D, 2,4,5-T and pentachlorophenol. Organohalogen Compd 32:51−55.

Schwind, K-H; Thoma, H; Hutzinger, O; et al. (1991) Emission halogenierter dibenzodioxine (PXDD) und 

dibenzofurane (PXDF) aus verbrennungsmotoren [Emission of halogenated dibenzo-p-dioxins (PCDD) and 

dibenzofurans(PCDF) from combustion engines]. UWSF-Z. Umweltchem. Oekotox. 3:291−298. [English 

translation]

Shah, DB; Phadke, AV; Kocher, WM. (1995) Lead removal of foundry waste by solvent extraction. J Air Waste 

Manag Assoc 45(3):150−155.

Smith, RM; O’Keefe, P; Aldous, K; et al. (1992) Measurement of PCDFs and PCDDs in air samples and lake 

sediments at several locations in upstate New York. Chemosphere 25:95−98.

Smith, RM; O’Keefe, PW; Hilker, DR; et al. (1993) The historical record of PCDDs, PCDFs, PAHs, PCBs, and lead 

in Green Lake, New York - 1860 to 1990. Organohalogen Compd 20:215−218.

Stevens, JL; Jones, KC. (2003) Quantification of PCDD/F concentrations in animal manure and comparison of the 

effects of the application of cattle manure and sewage sludge to agricultural land on human exposure to PCDD/F. 

Chemosphere 50:1183−1191.

Strandell, ME; Lexen, KM; deWit, CA; et al. (1994) The Swedish dioxin survey: summary of results from PCDD/F 

and coplanar PCB analyses in source-related samples. Organohalogen Compd 20:363−366.

Stringer, RL; Costner, P; Johnston, PA. (1995) PVC manufacture as a source of PCCD/Fs. Organohalogen Compd

24:119−123.

The Vinyl Institute. (1998) Dioxin characterization program. Phase I Report. The Vinyl Institute, Morristown, NJ.

Thomas, VM; Spiro, TG. (1995) An estimation of dioxin emissions in the United States. Toxicol Environ Chem 

50:1−37.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-12 DRAFT: DO NOT CITE OR QUOTE

U.K. Department of the Environment. (1995) Comments on EPA’s external review draft “Estimating exposures to 

dioxin-like compounds”. Submitted by the Department of the Environment, Food, and Rural Affaires, London, 

England. 

Umweltbundesamt. (1996) Determination of requirements to limit emissions of dioxins and furans. Report from the 

Working Group of the Subcommittee Air/Technology of the Federal Government/Federal States Emission Control 

Committee. Berlin, Germany.

University of Georgia (2002) Best management practices for wood ash as agricultural soil amendment. Cooperative 

Extension Service. Athens, GA. Available online at http://terrapreta.bioenergylists.org/files/B1142.pdf.

UNEP (United Nations Environment Programme) (2005) Standardized toolkit for identification and quantification 

of dioxin and furan releases. UNEP Chemicals, Geneva Switzerland. Available online at 

http://chm.pops.int/Portals/0/Repository/toolkit1/UNEP-POPS-TOOLKIT.1-4.English.PDF.

USDA (Department of Agriculture). (2002) Major uses of land in the United States, 2002/EIB-14. Economic 

Research Service/USDA. Available online at http://www.ers.usda.gov/publications/EIB14/eib14fm.pdf.

USDA (Department of Agriculture) (2009) Economic Research Center. US sugar supply and use. Available online 

at http://www.ers.usda.gov/Briefing/Sugar/Data.htm.

NTP (National Toxicology Program) (1989) Toxicology and carcinogenesis studies of two pentachlorophenol 

technical-grade mixtures (CAS No. 87-86-5) in B6C3F1 mice (feed studies). Technical Report Series No. 349. U.S. 

Department of Health and Human Services, Public Health Service, National Institutes of Health, Research Triangle 

Park, NC. NIH Publication No. 89-2804. Available online at http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr349.pdf.

U.S. DOC (Department of Commerce). (1990) 1987 Census of manufactures. Industrial inorganic chemicals. 

Bureau of the Census, Washington, DC. Report No. MC87-I-28A.

U.S. DOC (Department of Commerce). (1995) Statistical abstract of the United States, 1995. 118th ed. 

Washington, DC.

U.S. DOC (Department of Commerce). (1996) 1992 Economic census report series, disc 1G. U.S. Bureau of the 

Census, Washington, DC. Report No. CD-EC92-1G.

U.S. DOC (Department of Commerce). (1997) Statistical abstract of the United States, 1997. 117th ed. U.S. Bureau 

of the Census, Washington, DC. 

U.S. DOC (Department of Commerce). (2000) Census 2000. U.S. Census Bureau, Washington, DC. Available 

online at http://www.census.gov/main/www/cen2000.html.

U.S. DOE (Department of Energy). (2002) Glass industry of the future. Energy and environmental profile of the 

U.S. glass industry. Office of Industrial Technologies, Washington, DC. Available online at 

http://www1.eere.energy.gov/industry/glass/pdfs/glass2002profile.pdf.

U.S. EPA (Environmental Protection Agency). (1982) Development document for effluent limitations guidelines 

and standards for the inorganic chemicals manufacturing point source category. Office of Water Regulations and 

Standards, Washington, DC; EPA 440/1-82/007.

U.S. EPA (Environmental Protection Agency). (1987) National dioxin study Tier 4: combustion sources. 

Engineering analysis report. Office of Air Quality Planning and Standards, Research Triangle Park, NC; 

EPA/450/4-84/014h.

U.S. EPA (Environmental Protection Agency). (1988) Pesticide industry sales and usage: 1987 market estimates. 

Office of Pesticide Programs, Washington, DC.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-13 DRAFT: DO NOT CITE OR QUOTE

U.S. EPA (Environmental Protection Agency). (1989) Interim procedures for estimating risks associated with 

exposures to mixtures of chlorinated dibenzo-p-dioxins and -dibenzofurans (CDDs and CDFs) and 1989 update. 

Risk Assessment Forum, Washington, DC; EPA/625/3-89/016. 

U.S. EPA (Environmental Protection Agency). (1990a) Characterization of municipal waste combustion ash, ash 

extracts, and leachates. Coalition on Resource Recovery and the Environment, Office of Solid Waste and 

Emergency Response, Washington, DC; EPA/530/SW-90/029A.

U.S. EPA(Environmental Protection Agency). (1990b) Validation of emission sampling and analysis test method for 

PCDDs and PCDFs II. Project summary. Atmospheric Research and Exposure Assessment laboratory, Research 

Triangle Park, NC; EPA/600/S3-90/047. 

U.S. EPA (Environmental Protection Agency). (1991) Methodology for assessing environmental releases of and 

exposure to municipal solid waste combustor residuals. Office of Research and Development, Washington, DC; 

EPA/600/8-91/031.

U.S. EPA (Environmental Protection Agency). (1992a) Secondary lead smelter emission test report, East Penn 

Manufacturing, Lyon Station, Pennsylvania. Office of Air Quality Planning and Standards, Emission Measurement 

Branch, Research Triangle Park, NC. EMB Report No. 92-SLS-3.

U.S. EPA (Environmental Protection Agency). (1992b) Guides to pollution prevention, metal casting and heat 

treating industry; EPA/6251R-92/009. Available online at http://www.p2pays.org/ref/01/00733.pdf.

U.S. EPA (Environmental Protection Agency). (1993a) Report to Congress on cement kiln dust. Office of Solid 

Waste, Washington, DC. Available online at http://www.epa.gov/osw/nonhaz/industrial/special/ckd/cement2.htm.

U.S. EPA (Environmental Protection Agency). (1993b) Press advisory: EPA terminates special review of non-wood 

pesticide uses of pentachlorophenol. Office of Pesticide Programs, Washington, DC.

U.S. EPA (Environmental Protection Agency). (1995a) Compilation of air pollutant emission factors. 5th ed. Office

of Air Quality Planning and Standards, Research Triangle Park, NC. Available online at 

http://www.epa.gov/ttn/chief/old/ap42/5th_edition/ap42_5thed_orig.pdf.

U.S. EPA (Environmental Protection Agency). (1995b) Final emission test report, HAP emission testing on selected 

sources at a secondary lead smelter, Schuylkill Metals Corporation, Forest City, Missouri. Office of Air Quality 

Planning and Standards, Emission Measurement Branch, Research Triangle Park, NC. EMB Report No. 93-SLS-2.

U.S. EPA (Environmental Protection Agency). (1995c) Final emission test report, HAP emission testing on selected 

sources at a secondary lead smelter, Tejas Resources, Inc., Terrell, Texas. Office of Air Quality Planning and 

Standards, Emission Measurement Branch, Research Triangle Park, NC. EMB Report No. 93-SLS-1.

U.S. EPA (Environmental Protection Agency). (1996a) OSW hazardous waste combustion data base. Office of 

Solid Waste, Washington, DC.

U.S. EPA (Environmental Protection Agency). (1996b) Percentile estimates used to develop the list of pollutants for 

round two of the Part 503 Regulation. Office of Science and Technology, Washington, DC; EPA Contract No. 

68-C4-0046.

U.S. EPA (Environmental Protection Agency). (1997a) Locating and estimating air emissions from sources of 

dioxins and furans. Office of Air Quality Planning and Standards, Research Triangle Park, NC; EPA/454/R-97/003.

Available online at http://www.epa.gov/ttnchie1/le/dioxin.pdf.

U.S. EPA (Environmental Protection Agency). (1997b) Draft technical support document for hazardous waste 

combustors MACT standards (NODA). Vol. I. MACT evaluations based on revised database. Office of Solid 

Waste and Emergency Response, Washington, DC. 
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-14 DRAFT: DO NOT CITE OR QUOTE

U.S. EPA (Environmental Protection Agency). (1997c) Pesticide industry sales and usage: 1994 and 1995 market 

estimates. Office of Prevention, Pesticides and Toxic Substances, Washington, DC; EPA/733/R-97/002. Available 

online at http://www.epa.gov/oppbead1/pestsales/95pestsales/market_estimates1995.pdf. 

U.S. EPA (Environmental Protection Agency). (1998) AP-42: compilation of air pollutant emissions factors. 

Volume I: stationary point and area sources. Supplement D to the 5th ed. Office of Air Quality Planning and 

Standards, Research Triangle Park, NC.

U.S. EPA (Environmental Protection Agency). (1999a) Emission test evaluation of a crematory at Woodlawn 

Cemetery in the Bronx, NY. Office of Air Quality Planning and Standards, Washington, DC; EPA/454/R-99/049 

U.S. EPA (Environmental Protection Agency). (1999b) Biosolids generation, use, and disposal in the United States. 

Office of Solid Waste and Emergency Response, Washington, DC; EPA/530/R-99/009. Available online at 

http://www.biosolids.org/docs/18941.PDF. 

U.S. EPA (Environmental Protection Agency). (1999c) Technical background document for the Report to Congress 

on remaining wastes from fossil fuel combustion: waste characterization. Office of Solid Waste and Emergency 

Response, Washington, DC. Avaliable online at 

http://www.epa.gov/epawaste/nonhaz/industrial/special/fossil/ffc2_399.pdf. 

U.S. EPA (Environmental Protection Agency). (2001) Final titanium dioxide listing background document for the 

inorganic chemical listing determination. Office of Solid Waste, Washington, DC. Available online at 

http://www.epa.gov/waste/hazard/wastetypes/wasteid/inorchem/pdfs/tio2-bd.pdf. 

U.S. EPA (Environmental Protection Agency). (2002a) NESHAPS – Maximum Achievable Control Technology 

(MACT) standards. Office of Solid Waste, Washington, DC. Available online at

http://www.epa.gov/epaoswer/hazwaste/combust/ph2noda1/page2-3.htm#Words (accessed February 25, 2003). 

U.S. EPA (Environmental Protection Agency). (2002b) Statistical support document for the development of round 

2 biosolids use or disposal regulations. Office of Science and Technology, Washington, DC; EPA/822/R-02/034. 

Available online at http://www.epa.gov/waterscience/biosolids/adssummary.pdf. 

U.S. EPA (Environmental Protection Agency) (2002c) Exhaust emission effects of fuel sulfur and oxygen on 

gasoline nonroad engines. Office of Air and Radiation, Washington, DC. EPA/420/P-02/012. Available online at 

http://www.epa.gov/otaq/models/nonrdmdl/p02012.pdf. 

U.S. EPA (Environmental Protection Agency). (2002d) 2002 National emissions inventory. Technology Transfer 

Network. Available online at http://www.epa.gov/ttn/chief/net/2002inventory.html. 

U.S. EPA (Environmental Protection Agency). (2003a) Documentation of emission estimation methods for 

year 2000 and 2001 mobile and nonpoint source dioxin inventories. Prepared for the Office of Air Quality Planning 

and Standards, Washington, DC, by E.H. Pechan & Associates, Inc.

U.S. EPA (Environmental Protection Agency). (2003b) Chemical information collection and data development 

(testing) web site. Office of Prevention, Pesticides and Toxic Substances, Washington, DC. Available online at 

www.epa.gov/oppt/chemtest. 

U.S. EPA (Environmental Protection Agency). (2003c) Exposure and human health reassessment of 

2,3,7,8-tetrachlorodibenzo-p-dixoin (TCDD) and related compounds. National Academy of Sciences (NAS) Review 

Draft. Exposure Assessment and Risk Characterization Group, Washington, D.C.; EPA/600/P-00/001Cb. Available 

online at http://www.epa.gov/ncea/pdfs/dioxin/nas-review/. 

U.S. EPA (Environmental Protection Agency) (2005). Decentralized Wastewater Treatment Systems A Program 

Strategy. http://www.epa.gov/owm/septic/pubs/septic_program_strategy.pdf
This document is a draft for review purposes only and does not constitute Agency policy.

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U.S. EPA (Environmental Protection Agency) (2006) An inventory of sources and environmental releases of 

dioxin-like compounds in the U.S. for the Years 1987, 1995, and 2000. Final report. National Center for 

Environmental Assessment, Washington, DC; EPA/600/P-03/002F.

U.S. EPA (Environmental Protection Agency) (2007a) Frequently asked questions - EPA’s Program to reduce 

pollution from outdoor wood-fired hydronic heaters. Available online at http://www.epa.gov/burnwise/.

U.S. EPA (Environmental Protection Agency. (2007b) Pilot survey of levels of polychlorinated dibenzo-p-dioxins, 

polychlorinated dibenzofurans, polychlorinated biphenyls, and mercury in rural soils of the U.S. National Center for 

Enviornmental Assessment, Washington, DC; EPA/600/R-05/048F. Available online at 

http://oaspub.epa.gov/eims/eimscomm.getfile?p_download_id=461190.

U.S. EPA(Environmental Protection Agency) (2008) TRI explorer – chemical report. Available online at 

http://www.epa.gov/triexplorer/.

USFA (U.S. Fire Administration) (2001) Landfill fires. Topical fire research series: Volume 1, Issue 18. Available 

online at http://www.usfa.dhs.gov/downloads/pdf/tfrs/v1i18-508.pdf.

USGS (U.S. Geological Survey). (2000) Iron and steel. In: Mineral commodity summaries for 2000. Reston, VA: 

U.S. Geological Survey; pp 88−89. Available online at 

http://minerals.usgs.gov/minerals/pubs/mcs/2000/mcs2000.pdf.

USGS (U.S. Geological Survey). (2001) Iron and steel. In: Mineral commodity summaries for 2001. Reston, VA: 

U.S. Geological Survey; pp. 84−85. Available online at 

http://minerals.usgs.gov/minerals/pubs/mcs/2001/mcs2001.pdf.

USGS (U.S. Geological Survey). (2002a) Mineral commodity summaries for 2002. Reston, VA: U.S. Geological 

Survey. Available online at http://minerals.usgs.gov/minerals/pubs/mcs/2002/mcs2002.pdf.

USGS (U.S. Geological Survey). (2002b) Recycling – Metals. In: U.S. Geological Survey minerals yearbook—

2002. Reston, VA: U.S. Geological Survey. Available online at 

http://minerals.usgs.gov/minerals/pubs/commodity/recycle/recycmyb02r.pdf.

USGS (U.S. Geological Survey). (2009a) Recycling statistics and information. Mineral information. U.S. 

Geological Survey, Reston, VA. Available online at 

http://minerals.er.usgs.gov/minerals/pubs/commodity/recycle/index.html#myb.

USGS (U.S. Geological Survey). (2009b) Zinc statistics and information. Mineral commodity summaries. U.S. 

Geological Survey, Reston, VA. Available online at http://minerals.er.usgs.gov/minerals/pubs/commodity/zinc/.

Van den Berg, M; Birnbaum, L; Bosveld, AT; et al. (1998) Toxic equivalency factors (TEFs) for PCBs, PCDDs, 

PCDFs for humans and wildlife. Environ Health Perspect 106(12):775−792.

Van den Berg, M; Birnbaum, L; Denison, M; et al. (2006) The 2005 World Health Organization reevaluation of 

human and mammalian toxic equivalency factors for dioxins and dioxin-like compounds. Toxicol Sci 

93(2):223−241.

Van Oostdam, JC; Ward, JEH. (1995) Dioxins and furans in the British Columbia environment. BC Environment, 

Environmental Protection Department, Victoria, British Columbia.

Versar, Inc. (1985) List of chemicals contaminated or precursors to contamination with incidentally generated 

polychlorinated and polybrominated dibenzodioxins and dibenzofurans. Prepared for the U.S. Environmental 

Protection Agency; EPA Contract No. 68-02-3968, Task No. 48.

Villanueva, EC; Jennings, RW; Burse, VW; et al. (1974) Evidence of chlorodibenzo-p-dioxin and 

chlorodibenzofuran in hexachlorobenzene. J Agr Food Chem 22(5):916−917.
This document is a draft for review purposes only and does not constitute Agency policy.

1/7/2013 R-16 DRAFT: DO NOT CITE OR QUOTE

Waddell, DS; Boneck-Ociesa, H; Gobran, T; et al. (1995) PCDD/PCDF formation by UV photolysis of 

pentachlorophenol with and without the addition of hydrogen peroxide. Organohalogen Compd 23:407−412.

Wan, MT. (1995) Treated wood as a source of dioxin/furan releases. Organohalogen Compd 24:109−114.

Wan, MT; Van Oostdam, J. (1995) Utility and railway rights-of-way contaminants: dioxins and furans. J Environ 

Qual 24:257−265.

Ward, DE; McMahon, CK; Johansen, RW. (1976) An update on particulate emissions from forest fires. Presented at 

69th Annual Meeting of the Air Pollution Control Association. Portland, OR; June 27−July 1.

Western Environmental Services and Testing, Inc. (2000) Polychlorinated dibenzo-p-dioxins and polychlorinated 

dibenzofurans. Melt reactor and cathode stacks. Magnesium Corporation of America, Rowley, Utah. File Number 

00-1043.

Wevers, M; De Fre, R. (1995) Estimated evolution of dioxin emissions in Belgium from 1988 to 1995. 

Organohalogen Compd 24:105−108.

Wevers. M; De Fre, R; Desmedt, M. (2004) Effect of backyard burning on dioxin deposition and air concentrations. 

Chemosphere 54:1351–1356.

WHO (World Health Organization). (1991) IARC monographs on the evaluation of carcinogenic risks to humans: 

occupational exposures in insecticide application, and some pesticides. World Health Organization, International 

Agency for Research on Cancer, Geneva, Switzerland. Available online at http://monographs.iarc.fr/.

Wichmann, H; Zelinski, V; Scholz-Böttcher, B; et al. (1993) Sampling strategy to investigate the distribution 

behavior of low volatile pollutants like "dioxins" during vehicle fires in traffic tunnels. Chemosphere 

26(6):1159−1166.

Wichmann, H; Lorenz, W; Bahadir, M. (1995) Release of PCDD/F and PAH during vehicle fires in traffic tunnels. 

Chemosphere 31(2):2755−2766.

Winters, D; Fries, G; Lorber, M; et al. (2000) A study of the mass balance of dioxins and furans in lactating cows in 

background conditions. Part 1: Study design and analysis of feed. Organohalogen Compd 46:534−537.

Wunderli, S; Zennegg, M; Dolezal, IS; et al. (1996) Levels and congener pattern of PCDD/F in fly and bottom ash 

from waste wood and natural wood burned in small to medium sized wood firing facilities in Switzerland. 

Organohal Comp. 27: 231−236.

Yake, B; Singleton, S; Erickson, K. (1998) Washington State dioxin source assessment. Washington State 

Department of Ecology, Olympia, Washington. Publication No. 98-320. Available online at 

http://www.ecy.wa.gov/pubs/98320.pdf.