iwms air quality technical response document 041312 (2)

8/2/2019 IWMS Air Quality Technical Response Document 041312 (2)

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TABLE OF CONTENTS

SectionPage Number

1. Executive Summary .......................................................................................................................... 11

2. Introduction ..................................................................................................................................... 21

3. Why Macclenny, FL for the proposed facility? ................................................................................... 31

4. What are the emissions from the proposed facility? ......................................................................... 41

4.1 UNITS OF MEASURE ................................................................................................................................... 41

4.2 BREAKDOWN OF THE EXHAUST STREAM .................................................................................................. 42

4.3 BREAKDOWN OF THE EMISSION LIMITS .................................................................................................... 44

4.4 QUANTIFICATION OF EMISSIONS .............................................................................................................. 46

5. Are dioxins emitted from this proposed facility and how can they affect humans? ........................... 51

6. What about the ash? ........................................................................................................................ 61

7. What is the overall impact of this proposed facility on our community? ........................................... 71

8. References ....................................................................................................................................... 81


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Integrated Waste Management Systems, Inc. BioMedical Waste Thermal Reduction Facility

Air Quality Technical Response Document

IWMS Air Quality Technical Response Document 041312 11 04/13/12

1. EXECUTIVE SUMMARY

Integrated Waste Management Systems, Inc. (IWMS) proposes to construct a bio medical waste thermal reduction facility in Baker County, FL to provide jobs for the county and service the rapidly growing

medical waste needs of the region. In an April 9, 2012 letter to the Baker County Board of County

Commissioners (Board), IWMS promised to submit this Technical Response Document to the Board to

address some of the technical issues raised by the Board and the public.

IWMS believes that Baker County is a strategic location for the proposed facility based on its proximity

to metropolitan areas (customers) and the interstate highway system (transportation system); the

regulatory framework and experience of the regulators dealing with similar hospital/medical/infectious

waste incinerators (HMIWIs); and the opportunity to partner with Baker County.

Due to the complexity of the regulations that govern HMIWIs, there are technical considerations that

should be understood by key stakeholders. This document highlights some of these technical

considerations and presents them in a context that relates to both the technical and non technical

stakeholders. The technical considerations addressed include:

Less than 0.1% by volume of the exhaust gas stream is comprised of regulated air pollutants; the

remaining 99.9% is nitrogen, carbon dioxide, oxygen, and water (i.e., the primary constituents of

ambient air).

The emission limits for new HMIWIs are based on the top performing unit in the industry for

each pollutant. Any new unit constructed to meet such a combination of extremely stringent

standards was referred to as a super unit in the regulatory development process. IWMS

proposes to construct a super unit.

Relating overall cancer risk to the construction of the proposed facility is not simple. There are

numerous risk factors that must be considered and the emissions from the proposed facility are

just one component of the overall risk. All 10 existing HMIWIs in Florida, none of which have

the controls of a super unit, are located in counties that have decreasing deaths attributed to

cancer and have death rates that are either equal to, or lower than, the national average cancer

death rates. (National Cancer Institute, 2004 2008)


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Dioxins from all incinerators in the U.S. have been reduced by approximately 99% from 1985

levels. Backyard burn barrel emissions now represent the majority of U.S. dioxin emissions and

generate anywhere from 1,728 to 75,314 times the emission (on a g/kg of waste burned basis)

from a municipal waste combustor. (American Chemistry Council, 2012)

Ash will be thoroughly tested in compliance with all applicable environmental standards and

properly disposed of in a safe manner at an appropriately licensed landfill that will accept the

waste.

The IWMS project team is committed to the project being a model facility for the industry that will meet

or exceed the applicable emission limits and will incorporate an environmentally conscious design.

IWMS believes that a well permitted, designed, constructed, operated, and maintained HMIWI facility in

Baker County can be a valued community partner.


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2. INTRODUCTION

As outlined in Integrated Waste Management Systems, Inc.s (IWMSs) April 9, 2012 letter to the Baker County Board of County Commissioners (Board), the purpose of this document is to provide additional

air quality regulatory and technical information related to a planned bio medical waste thermal

reduction facility in Baker County, near Macclenny, Florida. Information is very powerful and

misinformation can be equally powerful. The internet provides society access to information like never

before some of it current and valuable, some of it outdated and misleading. The owners of this

project wish to share the resources that were relied upon to evaluate the planned facility.

The IWMS evaluation was based upon the following goal:

The planned facility will be owned and operated by IWMS. IWMS will construct and operate up to four

(4) hospital/medical/infectious waste incinerators (HMIWIs), each burning a maximum of 30 tons per

day (tpd) of bio medical waste (30 tpd is approximately four (4) to five (5) tractor trailers of waste each

24hour period per unit). The proposed facility will also include one (1) emergency generator and one

(1) emergency fire pump, each permitted to operate a maximum of 500 hours per year, during

emergency conditions. The emergency generator and emergency fire pump are intended to maximize

the safe operation of the facility. The emergency generator will provide back up power in the event of a

power outage and the emergency fire pump will permit operation of the fire suppression systems in the

event of a fire and associated loss of power. This back up contingency will facilitate the safe shutdown

of the operations in the event of a power failure.

This operation will be very tightly regulated by the U.S. Environmental Protection Agency (U.S. EPA) and

the Florida Department of Environmental Protection (FDEP). On October 6, 2009, the U.S. EPA

The GOAL: Partner, Build, and Serve

Integrated Waste Management Systems (IWMS) is seeking a partnership with Baker County

to build a bio medical waste thermal reduction facility to provide jobs for the county and

service the rapidly growing medical waste needs of the region.


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dramatically revised the federal air regulations that govern HMIWIs significantly lowering the

allowable emission rates and enhancing the on going activities required to demonstrate compliance.

One part of the revised regulations addresses existing units (i.e., those already in operation) and another section of the regulations addresses new units (like the planned IWMS facility). Upon construction, the

proposed IWMS facility would be subject to the new unit requirements under 40 CFR Part 60, Subpart Ec

(New Source Performance Standards for Hospital/Medical/Infectious Waste Incinerators).

The remainder of this air quality technical response document has been assembled to address the

following key considerations:

Why Macclenny, FL for the proposed facility?

What are the emissions from this proposed facility?

Are dioxins emitted from this proposed facility and how can they affect humans?

What about the ash?

What is the overall impact of this proposed facility on our community?


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3. WHY MACCLENNY, FL FOR THE PROPOSED FACILITY?

The first question is probably: Why build any of these facilities at all? The short answer is that they are

needed to effectively treat the medical waste that is being generated every day. From a business

planning perspective, IWMS considered the following factors for locating the proposed facility:

1. An area with multiple major medical facilities with declining options for required disposal of

medical waste.

2. A site location that would provide access to major interstate highway systems.

3. A regulatory

framework

(i.e.,

State

of

Florida)

and

regulators

that

were

familiar

with

the

HMIWI

regulations due to existing facilities and the ability for proactive planning to properly

incorporate the new federal HMIWI regulations.

4. A county that was looking for a partner to provide jobs and service the rapidly growing medical

waste needs of the region.

Baker County satisfies each of the first three factors outlined above. It has been IWMSs goal from the

introduction of this project over a year ago to a group of Baker County business and government leaders

to ensure that the fourth factor is also satisfied.


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4. WHAT ARE THE EMISSIONS FROM THE PROPOSED FACILITY?

4.1 UNITS OF MEASURE

The first place to start is with the units of measure the numbers do not mean much without an

understanding of the units of measure. Most folks are familiar with the unit of %. From our early days

in school, a 90% on a test meant that we got 9 out of 10 correct or 90 out of 100. For the main

constituents (i.e., components, ingredients, or make up) in air; like oxygen, nitrogen, and carbon

dioxide, the units of % make sense because they make up a large portion of air. However, when looking

at regulated air pollutants, % is too large of a scale and a smaller scale is used with different units of

measure.

Different scales are used to put numbers in terms that we can easily read; however, the relative

magnitude of numbers can be easily lost. Consider, for example, units of measure and the

corresponding tool that you would use to measure distance. To measure the distance from Macclenny

to Jacksonville, one would probably

use miles as the units of measure,

and then utilize a cars odometer to

determine the distance from

Macclenny to Jacksonville in miles.

It does not make sense to use

feet or inches to measure the

distance when the scale of miles is

more appropriate. It also doesnt

make sense to measure the

dimensions of a bedroom in miles

when feet or inches is more

appropriate.

Applying this analogy to the breakdown of air Oxygen, nitrogen, and carbon dioxide would be

measured in miles [or volume % in reality] and regulated air pollutants would be measured in inches

[or parts per million in reality].

Units of measure

The distance from Macclenny to Jacksonville = 30 miles or

158,400 feet.

The typical dimensions of a bedroom are 10 feet by 12 feet = 0.00189 miles by 0.00227 miles

The concentration of oxygen in ambient air is 21%, by volume = 210,000 ppm, by volume

The concentration of HCl in the exhaust gas is 5.1 ppm, by

volume or 0.00051%, by volume


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So lets put the common units of measure for regulated air pollutants in perspective:

Nitrogen Oxide HMIWI emission limit = 140 ppmv at 7% O2

10,000 ppm is equal to 1%.

Nitrogen Oxide concentration = 0.014%, by volume at 7% O2

Lead HMIWI emission limit = 0.69 g/m 3

16,016,610,000 g/m 3 is equal to 1 lb/ft 3

Lead concentration limit = 0.000000000043 lb/ft 3

Both examples above highlight that for each pollutant, a different smaller scale has been utilized so

that the numbers are easily read and can be more easily evaluated.

4.2 BREAKDOWN OF THE EXHAUST STREAM

The breakdown of the exhaust stream is the first place to start. The regulated air pollutants comprise

just 0.1% of the total exhaust stream, by volume. Table 1 provides a breakdown of the exhaust stream both numerically and graphically. Notice that the regulated air pollutant fraction is so small that it

barely shows up as a pie sliver in the graphic. For comparison purposes, dry ambient air is comprised of

approximately 78% nitrogen, 21% oxygen, and 1% other constituents (including carbon dioxide,

methane, helium, hydrogen, and argon).


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The carbon monoxide limit of 11 ppmv is comparable to the average concentration emitted from a properly operated gas stove in your home.

http://www.epa.gov/iaq/co.html

4.3 BREAKDOWN OF THE EMISSION LIMITS

The proposed units will be subject to federal regulations that were

originally promulgated in 1997 and then updated in 2009. Among

other changes, the emissions limitations established in the 1997

rule were significantly reduced in the 2009 rule. The rule

establishes emissions limitations for units depending on whether

they are new or existing units, as well as whether they are

classified as small, medium, or large units. The proposed IWMS

units will be classified as new, large units. While the other Florida commercial unit (located in Apopka,

FL) will be subject to the 2009 standards for existing, large units (to be implemented by 2014), the

proposed IWMS units will be subject to the more stringent 2009 standards for new, large units (to be

implemented upon operation of a new unit). A comparison of the 1997 standards for new and existing

large units to the 2009 standards for new and existing large units is provided in the table below.

Table 2

Emission Limit

Comparison

for

Existing

and

New

Large

HMIWIs

1997 Standards vs. 2009 Standards (@ 7% O2)

Pol lu tan t E x i s t i n g Un i t s N e w U n i t s

1997Standard

2009Standard

Red uc t i on(% )

1997Standard

2009Standard

R educ t i on(% )

PM/PM 10 (gr/dscf) 0.015 0.011 26.7 0.015 0.008 46.7

Carbon Monoxide (CO) (ppmv) 40 11 72.5 40 11 72.5

Sulfur Dioxide (SO 2) (ppmv) 55 9 83.6 55 8.1 85.3

Nitrogen Oxides (NO X) (ppmv) 250 14044.0

250 14044.0

Hydrogen Chloride (ppmv) 100 6.6 93.4 15 5.1 66.0

Dioxins/Furans (ng/dscm) 125 9.3 92.6 25 9.3 62.8

Dioxins/Furans TEQ (ng/dscm) 2.3 0.054 97.7 0.6 0.035 94.2

Lead (mg/dscm) 1.2 0.036 97.0 0.07 0.00069 99.0

Cadmium (mg/dscm) 0.16 0.0092 94.3 0.04 0.00013 99.7

Mercury (mg/dscm) 0.55 0.018 96.7 0.55 0.0013 99.8


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Super Unit Designation

The emissions limitations established for new units represent the emission rates achieved in practice by

the best performing existing unit at the time the 2009 rule was developed on a pollutant bypollutant basis.

Since the emissions limitations were developed on a pollutant bypollutant basis, no single unit could

achieve all of the best performing emission rates at the same time (i.e., the best performing unit for NOX

may not have been the best performing unit for CO). This non existent unit was referred to as a super

unit in the rule development process; however, the resulting emissions limitations for new units will, in

effect, require new units to become super units. That is to say, new units will have the lowest overall

emissions of any HMIWI unit currently in existence. IWMS is proposing to install super units as part

of this project.

Emission Limits in every day terms

It can be very difficult to understand the context of what part per million or milligram per dry

standard cubic meter means. A part per million means one part out of one million parts . If you think of

it in terms of grains of sand, try finding 8 grains of sand out of a tub of 1,000,000 grains of sand. That is

a comparison of the allowable sulfur dioxide (SO2) concentration in the exhaust gas for a new, large HMIWI [SO2 limit is 8.1 ppmv].

They keep lowering the limits

One of the most common questions is Since they keep lowering the limits, does that mean that

emissions werent safe before? The answer is that as technology continues to improve, the limits will

continue to be reduced. Technology influences the emission limits on a number of fronts:

The air pollution control technology (the equipment that cleans the gas stream of regulated air

pollutants) continues to evolve. Since the regulatory limits are technology based limits, as

technology improves the limits will go down.

The ability to detect pollutants at lower concentrations continues to evolve. The dioxin limit

identified above is in the units of nanograms per dry standard cubic meter. There are 1 billion

nanograms in one gram. Laboratory equipment can now be calibrated to analyze levels that are


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one billionth of a gram. That is equivalent to finding ONE person out of all the people in North

America, Latin America, and the Caribbean, combined!

One of the primary goals of the regulatory review process is to force continued improvement

and lower emission limits . The U.S. EPA rules require routine reviews once every five (5) years

to determine if the emission limits should be lowered. This approach protects human health

and the environment.

What about cancer risk?

We consulted the National Cancer Institutes database to seek clarity on this issue. Figure 1 shows a

map of Florida and charts cancer incidence rates by county. Also shown on the figure are the locations

of the 10 existing HMIWIs. There is no clear correlation between HMIWI location and an increased

cancer risk. What is significant is that all 10 existing HMIWI are located in Florida counties that have

decreasing deaths associated with cancer (over the 2004 2008 period) and have death rates that are

either equal to, or lower than, the national average cancer death rates. (National Cancer Institute, 2004

2008)

4.4 QUANTIFICATION OF EMISSIONS

While the emission limits presented in Table 2 provide a level of confidence that the concentrations in

the exhaust gas stream are very low and will represent a super unit designation, it is the MASS of

these regulated air pollutants emitted into the atmosphere that is most important. The majority of the

air quality requirements are triggered based on the weight (or mass) of emissions that are released into

the atmosphere. Table 3 provides a summary of anticipated maximum mass emission rates from the

four (4) IWMS units based on the concentration limits from the regulations and an anticipated maximum

exhaust gas flow rate out of the stack these two values can be used to calculate the mass emission

rates out of the stack.


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Figure 1

Cancer Incidence Rates for Florida (2004 2008)


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Integrated Waste Management Systems, Inc .BioMedical Waste Thermal Reduction Facility


Emiss ion

Fac t or Uni t s F o o t n o t ePol lu t an t (lb /hr ) (t on /yr )

PM 0.008 gr/dscf @ 7% O 2 (c) 2.97 13.00PM 10 0.008 gr/dscf @ 7% O 2 (b) 2.97 13.00PM 2.5 0.008 gr/dscf @ 7% O 2 (b) 2.97 13.00NO X 140 ppmv @ 7% O 2 (c) 43.40 190.07SO2 8.1 ppmv @ 7% O 2 (c) 3.49 15.30CO 11 ppmv @ 7% O 2 (c) 2.08 9.09VOC 0.047 lb/ton (d) 0.24 1.03HCl 5.1 ppmv @ 7% O 2 (c) 1.24 5.42Cd 0.13 g/dscm @ 7% O 2 (c) 2.11E-05 9.23E-05Hg 1.30 g/dscm @ 7% O 2 (c) 2.11E-04 9.23E-04Pb 0.69 g/dscm @ 7% O 2 (c) 1.12E-04 4.90E-04Dioxins and Furans 9.3 ng/dscm @ 7% O 2 (c) 1.51E-06 6.60E-06

Aluminum 2.99E-03 lb/ton (d) 1.50E-02 6.55E-02Antimony 1.51E-04 lb/ton (d) 7.55E-04 3.31E-03Arsenic 1.46E-05 lb/ton (d) 7.30E-05 3.20E-04Barium 7.39E-05 lb/ton (d) 3.70E-04 1.62E-03Beryllium 3.84E-06 lb/ton (d) 1.92E-05 8.41E-05Chlorine 1.05E-01 lb/ton (d) 5.25E-01 2.30E+00Chromium 1.92E-04 lb/ton (d) 9.60E-04 4.20E-03Copper 2.75E-04 lb/ton (d) 1.38E-03 6.02E-03Hydrogen Bromide 4.42E-03 lb/ton (d) 2.21E-02 9.68E-02Hydrogen Fluoride 1.33E-02 lb/ton (d) 6.65E-02 2.91E-01Iron 1.44E-02 lb/ton (d) 7.20E-02 3.15E-01Manganese 5.67E-04 lb/ton (d) 2.84E-03 1.24E-02Nickel 2.84E-04 lb/ton (d) 1.42E-03 6.22E-03Silver 7.19E-05 lb/ton (d) 3.60E-04 1.57E-03SO3 9.07E-03 lb/ton (d) 4.54E-02 1.99E-01Thallium 1.10E-03 lb/ton (d) 5.50E-03 2.41E-02Total PCBs 4.65E-05 lb/ton (d) 2.33E-04 1.02E-03

Notes:

Parameter Value UnitsStack Gas Volumetric Flow Rate 17,520 ACFM @ 7% O 2Stack Gas Temperature 395 OFStandard Stack Gas Volumetric Flow Rate 10,819 DSCFM @ 68 OFHMIW Feed Rate (per HMIWI) 2,500 lb/hrOperating Time 8,760 hr/yrNumber of Incinerators 4 UnitsConversion Factor 1 60 min/hrConversion Factor 2 7,000 gr/lbConversion Factor 3 2.2046E-09 lb gConversion Factor 4 35.31 ft3 /m 3

Molar Volume of Air @ STP 385.35 scf/lb molMolecular Weight of NO x (as NO 2) 46 lb/lb molMolecular Weight of SO 2 64 lb/lb molMolecular Weight of CO 28 lb/lb molMolecular Weight of HCl 36 lb/lb mol

P o t e n t i a l t o E m i t (a)

(a) Emission calculations are based on the following information.

(d) Emission factor from U.S. EPA, AP-42: Chapter 2.3.

Maximum HMIWI Mass Emiss ion Rates

(b) Emission factor represents emission guarantee provided by Tri-Mer Corporation for an UltraCat Filtration (UCF) Air Pollution Control Systemfor total filterable particulate matter.(c) Emission factor represents emission limit for new units subject to 40 CFR Part 60, Subpart Ec Standards of Performance for New StationarySources: Hospital/Medical/Infectious Waste Incinerators."

Table 3

48


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So how do the emissions from the proposed IWMS facility compare to other existing Baker County

facilities?

There are numerous permitted and unpermitted sources of air pollution located in Baker County.

Submitting environmental permit applications, receiving environmental permits, and then operating

pursuant to the permits is common to municipal, governmental, industrial, and manufacturing facilities.

The regulatory agencies understand the rules and the requirements, and the regulated community

understands that such permits are required. The rules and requirements are developed with two

common goals: (1) protect human health and welfare, and (2) prevent adverse environmental impact.

This is accomplished by a formal rulemaking process that is based on scientific data, involves the public,

and mandates on going review and reconsideration of emission levels.

To provide some perspective: The City of Macclenny has a permit to operate an Air Curtain

Incinerator. [FDEP Permit7775429 002 AO] This unit is subject to unit specific federal New Source

Performance Standards (40 CFR Part 60, Subpart AAAA) just like the proposed IWMS facility (40 CFR Part

60, Subpart Ec) and is not equipped with any add on air pollution control equipment. In addition to

being permitted to burn yard waste, this incinerator is permitted to be used for the destruction of

animal carcasses in accordance with the provisions of Rule 62256.700(6), F.A.C.

If such carcasses were burned in the proposed

IWMS facility, the exhaust gas would be treated

and exhausted through the air pollution control

system. The requirement for operation of the

Citys Air Curtain Incinerator when burning

animal carcasses is only that When using the air curtain incinerator to burn animal carcasses, untreated

wood may also be used to maintain good combustion. [FDEP Permit7775429 002 AO, Emission Unit

Specific Condition 9] There are no additional air pollution control requirements associated with burning

animal carcasses in the City of Macclennys incinerator.

This example is not cited to imply that the City of Macclenny is doing anything wrong. On the contrary,

the example is provided to show what is typically required by the regulations and what is currently

The City of Macclenny is currently permitted to operate an Air Curtain Incinerator . The unit is subject to the New Source Performance Standards (40 CFR Part 60, Subpart AAAA) and is permitted to be used for the destruction of animal carcasses.


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permitted to operate in Baker County. In addition, this example highlights the ADDITIONAL level of

control and the ADDITIONAL requirements that would be associated with the proposed IWMS facility

when treating similar waste streams.


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5. ARE DIOXINS EMITTED FROM THIS PROPOSED FACILITY ANDHOW CAN THEY AFFECT HUMANS?

Dioxin Emissions

Dioxins is the generic name that is given to a group of chemical compounds that are toxic and share

many of the same chemical structures and biological characteristics. Dioxins have been around since

the invention of fire and can be released into the atmosphere from both natural sources and man made

sources . The most common sources of dioxins are:

Forest fires;

Backyard burning of trash (burn barrels);

Certain industrial activities; and

Past commercial waste burning. (Agency, 2010)

The first step to understanding dioxins is to make

sure that the information being reviewed is current.

Data showing that the leading source of dioxins is

incineration is outdated. Emissions of dioxins from

U.S. industrial and municipal sources have been

dramatically reduced by up to 92% from 1985 levels

and backyard burn barrels now comprise the

majority of all dioxin emissions in the U.S. The figure

below provides a graphical representation of this

dramatic transformation (American Chemistry

Council, 2012). Two things are immediately clear:

1. Total dioxin emissions have dramatically reduced from 1985 levels of 13,949 grams of dioxins

(TEQ basis) to those projected in 2002/2004 of 1,106 grams of dioxins (TEQ basis). This is a total

emissions reduction of 92%. [NOTE: TEQ means dioxin toxic equivalents and provides a

weighting factor for each member of the dioxin family. 2,3,7,8 TCDD is the most toxic of the

Make sure the data is current!

Emissions of dioxins from US industrial and municipal sources have declined by 92 percent since 1985. U.S. EPA anticipates that dioxin emissions from municipal waste combustors and incinerators will have been reduced by approximately 99% and mercury emissions by 95% when technology based emissions standards for industrial and combustion sources are fully implemented.

http://www.epa.gov/airtrends/aqtrnd02/2002_airtrends_final.pdf


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bunch and is given a toxic equivalency factor (TEF) of one. All other dioxin family members are

given a TEF based on 2,3,7,8 TCDD and are one or less.]

2. Contribution of dioxin emissions from burn barrels is over 50% of the 2002/2004 levels while the contribution from incineration is less than 5%.

Mr. Paul Lemieux of the U.S. EPAs National Risk Management Research Laboratory performed a study in

1999 that analyzed the emissions of dioxins from burn barrels. (Lemieux, 1999) The study very clearly

showed that the dioxin generation rate (on a g/kg of waste burned basis) from backyard waste

burning were anywhere from 1,728 to 75,314 times higher than that for a municipal waste combustor.

The table below has been reproduced from that 1999 study. The nd value represents none detected

based on the detection limit at the time of the test.


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For comparison purposes, the current dioxin emission limits for municipal waste combustors are 13

nanograms/dscm @ 7% O2 [Total dioxins/furans]. The proposed HMIWIs at the IWMS facility would

have a lower dioxin permit limit. The dioxin emission limit for the IWMS units is 9.3 nanograms/dscm @

7% O2 [Total dioxins/furans]. This corresponds to emission rates of 1.51 x 106 pounds per hour and 6.6 x

106 tons per year of dioxins/furans. Assuming that a grain of sand weighs 0.1 milligrams, the IWMS

emission rate represents the equivalent of 6 grains of sand per hour emitted from the facility.

A tremendous amount of effort has been spent trying to understand how dioxins are formed and also

about their impacts on human health and the environment. One of the key considerations for formation

of dioxins is The 3T Rule. (Council, 2007) The 3T Rule Combustion temperature, time, and

turbulence conditions are adjusted to minimize dioxin formation.

The 3T Rule is a fundamental principal of all regulated waste combustion sectors and has proven that

combustion technology does work to reduce dioxin emissions. Combustion temperature appears to be

the primary driver in minimizing dioxin formation. The temperature range most conducive to dioxin

formation is approximately 390 deg F to 750 deg F. Dioxin formation in that temperature range is

approximately ten times higher than that below 390 deg. F, while dioxin concentrations are next to

totally destroyed above 750 deg. F. (Vehlow, 2005) The IWMS HMIWIs will operate at temperatures in excess of 1,600 deg. F in the primary chamber and in excess of 1,800 deg. F in the secondary chamber.

In addition, IWMS will employ rapid quench technology in the air pollution control system to minimize

the time that the exhaust stream will be in the critical temperature range. Dioxin formation will be very

low in the high temperature zone typical of combustion, and in the low temperature zone required to

maintain the integrity of the air pollution control system. In addition, IWMS will be required to test and


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to establish operating parameter limits that are continuously monitored and recorded to ensure that the

emission limits are satisfied.

Dioxin Affects

Dioxins have been categorized by U.S. EPA as likely to be human carcinogen and are anticipated to

increase the risk of cancer at background levels of exposure. (Agency, Persistent Bioaccumulative and

Toxic (PBT) Chemical Program Dioxins and Furans, 2011) Our most common exposure to dioxins is

primarily from the food we eat animal fats associated with eating beef, pork, poultry, fish, milk, and

other dairy products.

Dioxins have been widely studied by the U.S. EPA and health organizations and the health effects of

dioxins depend on a variety of factors including:

The level of exposure,

When someone is exposed, and

For how long and how often someone is exposed. (Agency, Dioxin, 2010)

The U.S. EPA issued a draft health assessment for dioxins in 1994. Since that initial report, 14 additional

documents have been released on the subject often contradicting the previous documents.

www.DioxinFacts.org summarizes the February 2012 U.S. EPA document as presented below and

concludes that current exposure to dioxins does not pose a significant health risk. (American

Chemistry Council, 2012)


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6. WHAT ABOUT THE ASH?

There are two types of ash that would be generated at the facility: bottom ash and fly ash. Bottom ash

is the ash generated in the primary combustion chamber and fly ash is the ash that is collected from the

fabric filter baghouse system that is part of the air pollution control system. Bottom ash is similar to the

ash that remains after a camp fire. The fly ash is a very fine powder this is a combination of the sodium

bicarbonate that is added to the ductwork just prior to the fabric filter system to control acid gases and

any particulate matter or other pollutants that stick to the sodium bicarbonate. The fly ash is either

sodium bicarbonate and particulate matter (i.e., baking soda) or a sodium salt based on the reaction of

the sodium

bicarbonate

and

chlorine

acid

gases).

The

fly

ash

particles

are

prevented

from

being

discharged into the atmosphere with the exhaust gas stream because they are too large to fit through

the microscopic holes of the bag filters. This controlled fly ash falls to the bottom of the hopper

where it is collected.

The bottom ash and fly ash are both collected in covered hoppers. The respective ashes are then

sampled, analyzed, and then properly transported and disposed of in an appropriately licensed landfill

based on the results of the sampling. Each landfill is also regulated and will only accept waste (ash in

our case) that meets certain criteria. IWMS will only send the ash to permitted landfills that accept our

ash criteria. IWMS has no intention of land applying any of the ash collected at the facility. IWMS will

follow a strict sampling/analysis/transportation/disposal plan that will minimize the potential

environmental impact of the ash and will only dispose of the ash at an appropriately licensed landfill.


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7. WHAT IS THE OVERALL IMPACT OF THIS PROPOSED FACILITYON OUR COMMUNITY?

After all the technical data is presented and reviewed, the final question is What is the impact on our

community? This question can be analyzed from many different perspectives from the economic

impact to the impact on human health and the environment. The economic impact was addressed in an

independent study commissioned last year that identified 100 local jobs, $27 million in construction

spending, and almost $200 million in economic impact. The focus of this document is solely on human

health and the environment. There are a few fundamental truths when considering the human health

and environmental impact of the project.

1. HMIWIs have successfully operated, and continue to operate, in the U.S. and 10 units currently

operate right here in FL. There are specific bio medical waste streams that are best treated, and

in some cases legally required to be treated, by incineration.

2. The updated 2009 emission limits and the process for developing the emission limits are as

stringent as U.S. EPA has ever approved for any industry/sector. The development of the 2009

rules governing HMIWIs was based on a two step process:

Step 1:

Establish

technology

based

standards

that

reflect

the

maximum

levels

of

control

that U.S. EPA determines are achievable for new and existing units after considering

costs, non air quality health and environmental impacts, and energy impacts.

Step 2: Review and revise the standards as necessary every five (5) years to provide an

ample margin of safety to protect public health and to prevent (taking into

consideration costs, energy, safety, and other relevant factors) an adverse

environmental impact.

3. The system design, training (both operator training and customer training), emission testing,

continuous parameter monitoring, recordkeeping, and reporting are extremely rigorous with

the purpose of demonstrating continuous compliance with the stringent emission limits.

4. IWMS is committed to this project being a model facility for the industry that will meet or

exceed the emission limits and will use an environmentally conscious design.


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The IWMS project team believes that a properly designed, permitted, constructed, operated, and

maintained HMIWI facility will be a safe and valued community partner here in Baker County.


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8. REFERENCES

Agency, U. S. (2010, August 12). Dioxin. Retrieved April 10, 2012, from U.S. EPA Research

Environmental Assessment Dioxin:

http://cfpub.epa.gov/ncea/CFM/nceaQFind.cfm?keyword=Dioxin

Agency, U. S. (2011, April 18). Persistent Bioaccumulative and Toxic (PBT) Chemical Program Dioxins

and Furans . Retrieved April 10, 2012, from U.S. EPA: http://www.epa.gov/pbt/pubs/dioxins.htm

American Chemistry Council. (2012). DioxinFacts.org Dioxin in Depth . Retrieved April 11, 2012, from

DioxinFacts.org: http://www.dioxinfacts.org/

Council, A.

C.

(2007).

Trends

in

Dioxin

Emissions

and

Exposure

in

the

United

States .

Retrieved

April

10,

2012, from DioxinFacts.org: http://www.dioxinfacts.org/sources_trends/trends_emissions.html

Lemieux, P. M. (1999). Emissions of Polychlorinated Dibenzo pdioxins and Polychlorinated

Dibenzofurans from the Open Burning of Household Waste in Barrels. American Chemistry

Society .

National Cancer Institute. (2004 2008). State Cancer Profiles . Retrieved April 11, 2012, from Cancer.gov:

http://statecancerprofiles.cancer.gov/cgi bin/quickprofiles/profile.pl?12&001

Vehlow, J. (2005, December 1013). Dioxins in Waste Combustion Conclusions from 20 Years of

Research . Retrieved April 10, 2012, from IEA Bioenergy Task 36.org (Bioenergy Australia 2005):

http://www.ieabioenergytask36.org/Publications/2004

2006/Report%2010_Dioxins%20in%20%20Waste.pdf

iwms air quality technical response document 041312 (2)

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