92-23.03

EFFECT OF WASTE STREAM MODIFICATION AND OTHER FACTORS

ON GROUND LEVEL CONCENTRATIONS RESULTING FROM MEDICAL WASTE INCINERATION

COMPARED WITH ACCEPTABLE AIR QUALITY

by

FLOYD HASSELRIIS Consulting Engineer

Forest Hills, NY, 11375

and

RENGASAMY KASINATHAN Doucet & Mainka, P.C.

Peekskill, NY 10566

For Presentation at the 85th Annual Meeting of the A&WMA

Kansas City, MO June 21-26, 1992

1

92-23.03

INTRODUCTION

There has been increasing concern about the impact upon ambient air quality of emissions from medical waste

incinerators (MWIs), largely because they burn waste materials which contain potentially toxic organic and

inorganic substances which produce stack emissions of hydrochloric acid, heavy metals and dioxins. Adding

to the concern is the fact that they were installed in most hospitals many years ago when the technology was

relatively primitive, emission controls were not provided, and their stacks were often short, preventing

effective dispersion of pollutants before they may be entrained in ventilation air taken into nearby tall

buildings. The concern about toxies in the waste has led to efforts to reduce emissions to the atmosphere by

removing materials which are likely to have an unfavorable impact on the environment.

Most MWIs burn relatively small quantities, and often are operated for a short duration, and at burning rates

ranging from 100 to 2000 pounds per hour, totaling from one half ton to a maximum of 24 tons per day.

These rates are small compared with municipal waste combustors (MWCs), which have a capacity range from

100 to 2000 or even 3000 tons per day. Thus MWCs have capacities which are 100 to 200 times those of

MWIs.1

The concern about atmospheric discharge of combustion gases has led to requirements that emission controls

be installed on large MWCs, and has carried over to regulations on the much smaller MWIs.

While providing efficient emission controls adds relatively little to the cost of large MWC facilities, such

controls may cost more than the cost of the MWI itself, and may increase the cost of disposal to a point where

off-site disposal becomes the more economical solution. On the other hand, those responsible for the

management of health care facilities usually prefer to retain responsibility for wastes produced under their

jurisdiction, to reduce liability, and to be certain that disposal is carried out properly.

The process of regulation of MWIs has progressed through the states, while waiting for Federal legislation

(the Clean Air Act) to be implemented by the U.S.EPA. The progress has been uneven, driven toward greater

stringency in states where the political pressure was great. While reduction, recycling, and removal of toxies

are desirable, these ideals do not dictate just which materials should be removed, nor from where, to achieve

the desired objective of protecting the environment. There are many choices which can and should be made.

There must be a sound basis for making these choices and decisions in order to assure optimum results with

minimum or acceptable costs. In order to make these decisions it is necessary to quantify the factors involved.

The information needed to do this is rarely available, and is difficult to obtain.

The health effects of emissions depend upon the concentration of the pollutant per unit volume of

atmospheric air, usually expressed as micrograms per cubic meter (�g/m\ As the combustion products

progress through the incinerator and the emission control devices (if any) they are diluted by the addition of

air and/or water vapor. As the gases enter the atmosphere from the top of the stack, they are diluted by the

process of dispersion before they reach the ground or elevated receptors.

The ground level concentrations (GLCs) based on this chain of factors can be compared with health risk­

based acceptable ambient concentrations (AACs) to determine which pollutants are critically excessive. The

individual factors may then be examined to determine by what means the excessive pollutant levels can be

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92-23.03

Dilution of Combustion Gases

Reduciug the concentration of pollutants in the stack gases reduces the resulting concentrations at ground

level, since the dispersion process starts from the stack concentration. Actually, for a given pollutant emission

rate, an increase in the gas flow which reduces the stack gas concentration reduces the ground level

concentration in a square root relationship. For example, modeling analyses shows that a 50% increase in gas

flow would produce a 22% reduction in ground level concentration.

The lowest possible quantity of discharged gases would result when the combustion air provided contains

exactly the amount of oxygen needed to complete combustion of the combustible matter in the waste or fuel.

More than twice this minimum amount of air must actually be supplied for various reasons. Chemical

reaction calculations show that for complete oxidation (combustion) of fuels or combustible wastes about 750

pounds of air must be provided for every million Btu of heat released by combustion, and that about 800

pounds of gaseous products of combustion are created. Heat and mass balance calculations show that if only

this ideal (theoretical or stoichiometric) amount of air is supplied, the gaseous products will be raised

anywhere between 2500° F to 3200° F, depending on the nature of the combustible matter and the amount of

moisture and inert material in the waste. Refractory furnaces cannot withstand these high temperatures,

hence additional (excess) air must be supplied to bring the temperature down to an acceptable range such as

1800° F to 2000° F. The quantity of excess air (EA) needed to do this is about equal to the theoretical air,

hence about 100% EA must be supplied.

The total products of combustion at 100010 EA are thus about 1,550 pounds per million Btu of heat released,

diluting the pollutants by a factor of 800/1,550 or about 0.52, as compared with ideal or stoichiometric air.

The gases may be further diluted if water is added to reduce the temperature of the gases. For instance, if the

gases are cooled from 1800° F to 150° F/800, about 0.43 pounds of water must be added per pound of

products, raising the total by 660 pounds to 2216 pounds per million Btu released. The combustion dilution

factor will then be 800/2216 or 0.36.

Volume of S tack Gases Discharged to the Atmosphere

More important than the increase in the mass of the gases is the increase in volume which affects the

dispersion of the gases after they leave the stack. The volume of the gases is affected by the temperature of the

stack gases. This will depend on whether or not there is a waste heat boiler, a water spray to cool the gases, or

both. Table 1 shows the actual volumes of gases discharged as a function of the type of system, expressed in

actual cubic feet per minute for a heat release of one million Btu per hour.

Stack concentrations which are reported as corrected to standard temperature and pressure at 7% oxygen can

be corrected to actual stack concentrations by the use of heat and mass balance calculations. Stack

concentrations are thus influenced by the combustion and emission control systems. This influence may be

called the combustion dilution factor. Direct discharge of the 1800°F gases would result in a 6-time

dilution of the gases on a volumetric basis, as compared with a 7-time dilution when the gases are cooled by

blending in air, and about a 2-time dilution for systems using a baghouse discharging gases at 300° F or a wet

scrubber discharging at 145°F.

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92-23.03

TABLE 1 - Stack Gas Flow at Various Stack Temperatures (per million Btu of heat released in the furnace)

Emission Control Stack Tem:p. (OF)

Direct to Stack

Diluted with Air

Wet Scrubber

Boiler and Filter

Boiler, Spray-dry+Filter

Boiler and Wet Scrubber

Fossil-fuel Boiler

Reference gas flow, 12% CO2

Dilution by Dispersion

1800

1300

80

350

300

145

450

68

Actual Stack

Gas Volume

ACFM (fe /min)

1510

1730

660

520

490

450

400

236

Combustion

Dilution

Factor (m

3/ sec)

6

7

3

2

2

1

Ai; the gases leave the stack they are dispersed into the atmosphere. Computer modeling is used to relate stack concentrations to ground level conditions. Since this is basically a form of dilution, the degree of dilution can be called the dilution factor (DF). The DF can be defIned as the ratio of stack gas concentration (SGC) to the modeled ground level concentration (GLC) of the pollutants:

DF = [SGC, llg/m1 / [GLC, llg/m1

Averaging Factor

Acceptable environmental concentrations of pollutants are based on different averaging times. One-hour averages are a concern for acute affects. Twenty-four hour averages are appropriate for toxic pollutants, and annual averages are used to evaluate life-time exposures to cancer-causing pollutants. The effect of dispersion is constantly varied by atmospheric conditions, hence the time over which these variations is averaged will affect the average value. For this reason, an averaging factor must be applied. Simple models such as the EPA Screen model yield one-hour averages and more complex models give 3-hour, 24-hour, quarterly and

al 12 annu averages.

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92-23.03

ENVIRONMENTAL IMPACT AS THE PRODUCT OF REDUCTION FACTORS

In each step of the process a reduction factor is applied by multiplication. Thus the process from waste to

fmal average ground level concentration (GLC) is as follows:

GLC = W x (1/K.) x Fl x R l x R2 x R3 x R4 x R5 x R6 x R7

Where: GLC = Ground level concentration, grams pollutant per cubic meter.

W = Burning rate, tons of waste per hour.

K = Conversion factor, cubic meters per hour of standard dry gas produced.

Fl = Uncontrolled emission factor, grams of pollutant per ton of waste.

Rl = Reduction in pollutant, weight fraction of pollutant in the waste, divided by fraction which

would have been in waste if waste had not been modified prior to burning.

R2 = Partitioning factor, grams of pollutant discharged with combustion gases, per gram of

pollutant in the waste burned.

R3 = Combustion improvement factor, rate of emission after combustion improvement divided by

rate of emission before improvement.

R4 = Emission control reduction factor, gram of pollutant discharged per gram of pollutant

entering emission control device.

R5 = Combustion dilution factor, concentration of pollutant in gases actually discharged at the

stack, compared with pollutant concentration in gases at standard conditions and 7% 02.

R6 = Dispersion factor, one-hour average concentration of pollutant at ground level (or selected

receptor), compared with concentration of pollutant in gases leaving the stack.

R7 = Averaging time factor, ratio between annual (or other) average concentration and the one­

hour average concentration of pollutant.

REGULATORY REQUIREMENTS

The Clean Air Act of 1970 required each state to develop a plan for meeting air quality standards, called state

implementation plans. Under SIP, demonstration is required that National Ambient Air Quality Standards

(NAAQS) would be met. Thus requirement has undergone intense analysis and has fmally become an

acceptable procedure to verify levels of emissions from pollutant-discharging stacks. 12.13

The New York State Department of Environmental Conservation (NYSDEC) has promulgated new air

pollution control regulations, namely NYCRR-Part 219 to regulate incinerators. 14 Subpart 219.3 and a

subsequent memo (90-Air-28A) specifically regulate existing and new medical waste incinerators (MWI).

Under these regulations, all MWIs (existing and new) need to be brought under NYSDEC compliance prior

to January I, 1992.

The following section describes the various requirements of the regulatory agency for incinerator permitting

and risk assessment. Case studies of permit applications on behalf of several MWIs located in the State of

New York are presented for the purpose of analysis and illustration. Air quality dispersion modeling

(AQDM) must be performed prior to obtaining permits to construct are awaiting approval. Described below

are the various aspects of AQDM, such as stack height requirements, project location, emission factors,

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92-23.03

Worst Case Impact of the MWIs

The AQDM analysis predicts the concentrations in terms of I-Lglm3 based on a unitary emission rate of 1 gram per second (gls) for different averaging time periods, namely I-hour, 3-hour, 8-hour, 24-hour and annual averages. These are multiplied by the expected emissions from the MWIs in gls for each of the critical pollutants in order to obtain the ground level concentrations.

EVALUATING THE VARIOUS FACTORS

An illustration of this methodology is presented in Tables 3, 4, 5 and 6, using published data showing the effect of various configurations on GLCs, and comparing then with acceptable air quality levels (AAQLs).

Uncontrolled Emission Factors

The emission factors which are used to estimate the environmental impact of emissions are determined from stack tests of uncontrolled emissions from appropriate (similar) combustion systems. They are expressed in pounds of pollutant per ton of waste or equivalent units. Uncontrolled emission factors are available from data bases such as those published by the U.S.EP A. One set of data is based on the tests performed for the CARB.IS More recent data are based on U.S. EPA tests performed on several types of incinerators, with and without state-of-the-art emission control systems.7 These data sets are especially valuable since they include both uncontrolled and controlled emissions data.

Stack test data do not provide direct information on the quantity of individual pollutants in the waste, since a portion remains in the ash residues. The EPA tests include measurements of the partitioning of the pollutants, making it possible to relate the emissions to the waste. Average uncontrolled emissions measured during the EPA tests are presented in Table 2. The standard deviations of these data range from 25% for HCl to as high as 100% for mercury, reflecting the fact that they are impacted by its form (i.e. HgC� vs Hg or HgO), and that they are highly temperature dependent. Using the averages of these data, and following the procedures outlined above, Tables 3 to 6 have been developed.

TABLE 2 - Average Uncontrolled Emissions from MWIs*

Standard Coef. of Pollutant Ayerage Deyiation variation

PM, gr/dscf 0.109 0.031 29%

HCl, ppmv, 7% 02 1,627 397 24%

Arsenic, I-Lg/m3 320 23 83%

Cadmium, I-Lg/m3 4,632 290 51%

Chromium, I-Lg/m 3

46 29 43%

Lead, I-Lg/m 3 56,408 3,526 51%

Mercury, I-Lg/m 3 48,662 1,411 101%

Total CDD/CDF, ng/m3 410 101 25%

* Data from Durkee'S·1

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92-23.03

Partition Factors

The fraction of the specific pollutant which ends up in the gas stream can be defined as the partition factor.

This can be used to relate the pounds per ton of waste burned from the uncontrolled stack emissions.

Representative partition factors have been determined by the U.S. EPA, from comprehensive testing. Only

about 5% of the chromium and 12% of the arsenic appeared in the stack gases, as compared with about 45%

of the lead and 77% of the cadmium. All of the HCI and mercury escape with the.smek gases. d1w-

Acceptable Ground Level Air Quality

The acceptable ground level concentrations listed in the Tables 3,4,5 and 6 are the average annual concentra­

tions which are used in permit applications in New York State. These vary somewhat from state to state, but are based on health standards. The tables list the ground level concentrations, based on dilution factors of

1,000, 10,000 and 100,000, in order to discern the effect of dispersion of stack gases before they reach ground level.

Since the computer modeling process gives one-hour concentrations, and the health risk factors are based on

annual averages, the one-hour concentrations must be converted to annual concentrations. Using the CARB

data obtained from modeling exercises, we find that the I-hour average ranged from about 10 to 70 times the

annual average, depending upon the stack height and other site conditions. II The low number derives from a

facility with a 3-meter stack. The average, including this low stack, was about 30 times the annual average;

therefore a factor of 30 has been used to obtain the annual average GLC as a percent of the Acceptable GLC.

It should be stated here that each situation must be studied on the basis of the site conditions; the numbers in the tables should be used only for comparative purposes.

Table 3, for a system with heat recovery boiler and no emission control, shows excessive GLCs if the DF is

only 1,000, and with a DF of 10,000 high but acceptable emissions of HCl and cadmium are found. The

hourly average for HCl must also be investigated on a I-hour basis, for which the AGLC is 150 I!g/m3. In this case this limit would be close to 5000la of the limit at a DF of 10,000, and 50% of the limit at a DF of

100,000.

Table 4, for the boiler without emission controls, shows the effect of waste modification if the HCI and

cadmium in the waste could be reduced by 8oola. A DF of 10,000 would result in acceptable levels of HCl.

Likewise, cadmium would be reduced to 14% of the AGLC at this DF.

Table 5 shows the effect of adding a wet scrubber to the boiler system. The HCI concentration is now 1% at the lower DF of 1,000, reduced by the 99% control provided by the scrubber. The scrubber makes it possible

to deal with much more unfavorable site conditions.

Table 6 shows the effect of providing a boiler with a fabric fIlter, with a 3000 F stack temperature. The HCI

concentration at a DF of 1,000 is 21 % of the AGLC, somewhat lower than that of the wet scrubber due to the

higher stack gas temperature.

Similar comparisons may be made for the other pollutants. In these tables it can be noted that the toxic

11

92-23.03

equivalent TCDD concentrations produce significant percentages of the AGLC at the low control efficiencies reported by Durkee.

RISK ANALYSIS BASED ON PERMIT APPLICATIONS

NYSDEC states that the risk analysis is deemed to be complete if the following criteria are met:

o The worst case annual concentrations of the on-site receptors are less than 50% of the AGe.

o The next worst case annual concentrations of arsenic (As), dioxin and polyaromatic hydrocarbons (P ARC) at off-site elevated receptors are less than 1% of the respective AGCs.

The pollutant concentrations at on-site, off-site and elevated receptors of the five MWIs were compared with the AGC levels established by the NYSDEe. In all cases the above conditions were met for the physical configurations of the stacks and the critical buildings. In order to relate these fmdings to the more theoretical

discussions of dilution factors, the DFs for each of the cases are listed in Table 7. It is interesting to note that

in the case of on-site receptors the DFs were relatively low, in the range of 200 to 900, whereas those off-site

ranged from 100,000 to over 380,000. It is apparent that the considerations described above must be studied to determine what type of emission control system would be most appropriate, what stack height would be

required, and, perhaps, whether or not waste modification procedures might be able to achieve sufficient

reductions.

12

92-23.03

TABLE 3. Comparison with Acceptable GLCs - Boiler Without APC

TABLE 4. Comparison with Acceptable GLCs - Boiler Without APC, Removing 80% of Critical Pollutants.

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92-23.03

TABLE 5. Comparison with Acceptable GLCs - Boiler With Fabric Filter APC

TABLE 6. Comparison with Acceptable GLCs - Boiler With Wet Scrubber APC

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92-23.03

TABLE 7. Dilution Factors Calculated from Modeling of New York Incinerators

Incinerator: No. 1 No. 2 No. 3 No. 4 No. 5

Capacity, lb/hr 1000 975 900 300 300

Ground Level 263,800 103,000 336,800 383,300 92,000

Elevated 216 560 420 17,000

Receptors 308 560 500 39,000

426 730 650

531 177,600 4,900

892 162,000 257,500

CONCLUSIONS

The many factors which control the ambient concentrations of pollutants resulting from combustion of wastes

can be identified and separately evaluated. They can be expressed as reduction factors which, multiplied together, give the ground level concentrations. When all factors are considered, and ground level concentra­

tions are compared with established acceptable health-based ambient concentrations, it is possible to identify the significant pollutants, after which consideration can be given to the various factors which may be used to reduce the GLCs of these pollutants.

Modification of the waste to reduce the quantity and concentration of specific elements in the waste can be

initiated by identifying the objectionable components and making efforts to reduce them by purchasing procedures. These include chlorine and heavy metals such as cadmium found in plastic compounds, and

mercury which may come from batteries discarded at the facility.

Emission control devices are capable of reducing stack emissions by factors ranging from 5 to 1,000.

However, it is also possible to reduce the toxic forms of metals and organic compounds modifying the waste

stream by modifying the waste stream so as to minimize the toxic forms of metals and organic compounds in

the products of combustion. If this is done, the use of emission controls may not be justified if the stack gases

can be effectively dispersed before they reach the ground.

The partitioning of the volatile metals between the ash and the combustion gases is significantly influenced by

furnace temperatures and the degree of agitation of the wastes as they bum. Limited test data show that

about half of the lead and cadmium are carried by the combustion gases of two-stage controlled-air

incinerators.

Effective control of combustion can minimize emissions of organic pollutants. Oxygen readings can be used

for control, and carbon monoxide monitoring can be used as a surrogate for good combustion.

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92-23.03

The degree of dilution resulting from dispersion is highly dependent upon factors such as stack height, discharge temperature and velocity, meteorological conditions, and the configuration of nearby buildings and the local terrain.

Dilution factors obtained from modeling of several New York State MWIs show that DFs affecting on-site elevated receptors on high buildings ranged from about 200 to 1,000, whereas those related to off-site conditions ranged to over 300,000, depending on site configuration. The DFs which could be obtained by

installing stacks of adequate height may be more effective than emission controls in attaining acceptable

GLCs. On the other hand, when low DFs result from the presence of high-rise buildings, emission controls

may be unavoidable.

REFERENCES

l . Hasselriis, F. , and R Kasinathan, "Environmental and Health Risk Analysis of Medical Waste

Incinerators Employing State of the Art Emission Controls," 84th Annual Meeting of A&WMA, Vancouver, Canada, June, 1991. Paper 91-30.3

2. Green, Alex, "Pollution Prevention and Medical Waste Incineration," Reinhold Van Nostrand, 1992.

3. Hasselriis, Floyd, "Relationship Between Waste Composition and Environmental Impact," � Annual Meeting of the A&WMA, June 1990. Paper 90-38.2

4. Brady, J.D., "Recent Developments in Pollution Control Systems for Chemical and Infectious Waste

Incinerators," Mid-West American 1nst. of Chern. Engineers, st. Louis, MO, February, 1991.

5. Hasselriis, F., "Effect of Waste Composition and Charging Cycle on Combustion Efficiency of Medical and Other Solid Waste Combustors," 15th National Waste Processing Conference, Detroit,

MI, May 17-20, 1992.

6. Hasselriis, F., "Optimization of combustion conditions to minimize dioxin emissions," �

Management & Research (1987) Vol. 5, No. 3, pages 311-326.

7. Durkee, K.R, and James A. Eddinger, "Status of EPA Regulatory Program for Medical Waste

Incinerators - Test Program and Characterization of Emissions," presented at 1991 Incinerator

Conference on Thermal Treatment of Radioactive. Hazardous, Chemical, Mixed and Medical �, May, 1991, Knoxville, TN.

8. NITEP, "Two-stage Combustion, Prince Edward Island," EPS 3IUPIl, 1985, Environment Canada,

Ottawa, Ontario. 9. Corbus, David, "A Comparison of Air Pollution Control Equipment for Hospital Waste Incinera­

tors," AWMA June 1990. Paper 90-27.4

10. NITEP, "Air Pollution Control Technology," EPS 3IUP/2, 1986, Envir. Canada, Ottawa, Ontario.

11. Fry, Barbara, et al, "Technical Support Document to Proposed Dioxins and Cadmium Control

Measure for Medical Waste Incinerators," California Air Resources Board, May, 1990. 12. Guideline on Air Quality Models (Revised), 1986, u. S. EPA, Office of Air Quality Planning and Stan-

dards, NTIS PB86-245248.

13. Zanetti, Paolo, "Air Pollution Modeling," Van Nostrand Reinhold, New York, 1990. 14. New York State Department of Environmental Conservation, NYCRR Part 219, Albany, NY, 1990 15. Morrison, R, "Hospital Waste Combustion Study - Data Gathering Phase," Contract 68-02-4330,

U.S. EPA, Research Triangle Park, NC., 1988.

1 6

92-23.03

TABLE 3. Comparison with Acceptable GLCs - Boiler Without APC

BOILER WITHOUT AIR POLLUTION CONTROL

Stack Emission Conc. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = OF = OF = Waste Factor Factor Factor @450 F ug/m3 1000 10,000 100,000

HCI 8.16 1 1 1 967611 7 461% 46.08� 4.61% Particulate 0.86 1 1 1 101984 50 7� 0.68� 0.07% Arsenic 0.0005 1 0.12 1 7 0.00023 101� 10.14� 1.01% Cadmium 0.0013 1 0.77 1 117 0.00056 696� 69.64� 6.96% Chromium 0.002 1 0.05 1 12 1.2 O� O.oo� O.� Chrome VI 0.0002 1 0.05 1 1 8E-05 4� 4.17� 0.42% Lead 0.0268 1 0.45 1 1428 1.5 3� 0.32% 0.03% Mercury 0.0048 1 1 1 571 0.12 16� 1.59% 0.16% T.E.TCOO 4.8E-08 1 1 1 0.0057 3E-08 633� 63.33� 6.33%

TABLE 4. Comparison with Acceptable GLCs - Boiler Without APC, Removing 80% of Critical Pollutants.

BOILER WITHOUT AIR POLLUTION CONTROL - REMOVING 80% OF CRmCAL POLLUTANTS

Stack Emission Conc. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF= OF = OF = Waste Factor Factor Factor @450 F ug/m3 1000 10,000 100,000

HCI 8.16 0.2 1 1 193522 7 920/. 9.22� 0.92% Particulate 0.86 1 1 '. 1 101984 50 7� 0.68� 0.07% Arsenic 0.0005 1 0.12 1 7 0.00023 101� 10.14� 1.01% Cadmium 0.0013 0.2 0.77 1 23 0.00056 139� 13.93� 1.39% Chromium 0.002 1 0.05 1 12 1.2 O� 0.00% 0.00% Chrome VI 0.0002 1 0.05 1 1 8E-05 42% 4.17% 0.42% Lead 0.0268 1 0.45 1 1428 1.5 3% 0.32% 0.03% Mercury 0.0048 1 1 1 571 0.12 16% 1.59% 0.16% T.E.TCOO 4.8E-08 0.2 1 1 0.00114 3E-08 127% 12.67% 1.27%

13

92-23.03

TABLE 5. Comparison with Acceptable GLCs - Boiler With Fabric Filter APe

BOILER WITH FABRIC FILTER AIR POLLUTION CONTROL

Stack Emission Cone. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control uglm3 GLC OF = OF = OF =

Waste Factor Factor Factor @300 F uglm3 1000 10,000 100,000 HCI 8.16 1 1 0.04 44341 7 21% 2.11% 0.21� Particulate 0.86 1 1 0.08 9347 SO 1% 0.06� 0.01� Arsenic O.OOOS 1 0.12 0.31 3 0.00023 43% 4.3S% 0.43� Cadmium 0.0013 1 0.77 0.01 1 0.000S6 6� 0.60% 0.06% Chromium 0.002 1 O.OS 0.21 3 1.2 0% 0.00% O.OO� Chrome VI 0.0002 1 O.OS 0.21 0 8E-OS 0% O.OO� O.OO� Lead 0.0268 1 O.4S 0.01 16 1.S 0% 0.00% 0.00% Mercury 0.0048 1 1 1 654 0.12 18% 1.82% 0.18% T.E.TCDD 4.8E-08 1 1 0.77 O.OOSO 3E-08 SS9� SS.86� S.S9�

TABLE 6. Comparison with Acceptable GLCs - Boiler With Wet Scrubber APC

BOILER WITH WET SCRUBBER AIR POLLUTION CONTROL

Stack Emission Conc. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = DF = OF =

Waste Factor Factor Factor @14S F uglm3 1000 10,000 100,000

HCI B.16 1 1 0.001 1306 7 1% 0.06% 0.01%

Particulate 0.B6 1 1 0.46 63319 50 4% 0.42% 0.04%

Arsenic O.OOOS 1 0.12 0.33 3 0.00023 43% 4.35% 0.43%

Cadmium 0.0013 1 0.77 1 158 0.00056 940% 94.0S% 9.4OOi'

Chromium 0.002 1 O.OS 0.49 8 1.2 0% 0.00% 0.00%

Chrome VI 0.0002 1 O.OS 0.49 1 BE-OS 42% 4.17% 0.42%

Lead 0.0268 1 O.4S 0.53 1021 1.S 2% 0.23% 0.02%

Mercury 0.0048 1 1 0.906 699 0.12 19% 1.94% 0.19%

T.E.TCDD 4.BE-OB 1 1 0.2B 0.0020 3E-08 217% 21.71% 2.17%

14

REM-FAC REMOVAL FACTORS -FOR KANSAS PAPER

BOILER WITHOUT AIR POLLUTION CONTROL

Stack Emission Cone. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = OF = OF =

Waste Factor Factor Factor @450F ug/m3 1000 10,000 100,000 HCI 8.16 1 1 1 967611 7 461'* 46.08'* 4.61'* Particulate 0.86 1 1 1 101984 50 7,* 0.68'* 0.07,* Arsenic 0.0005 1 0.12 1 7 0.00023 101'* 10.14,* 1.01'* Cadmium 0.0013 1 0.77 1 117 0.00056 696'* 69.64'* 6.96'* Chromium 0.002 1 0.05 1 12 1.2 0'* 0.00'* 0.00'* Chrome VI 0.0002 1 0.05 1 1 8E-05 42,* 4.17'* 0.42'* Lead 0.0268 1 0.45 1 1428 1.5 3'* 0.32'* 0.03'* Mercury 0.0048 1 1 1 571 0.12 16'* 1.59'* 0.16'* T.E.TCDD 4.8E-08 1 1 1 0.0057 3E-08 633'* 63.33'* 6.33'*

BOILER WITHOUT AIR POLLUTION CONTROL - REMOVING 80% OF CRITICAL POLLUTANTS

Stack Emission Cone. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = OF = OF =

Waste Factor Factor Factor @450F ug/m3 1000 10,000 100,000 HCI 8.16 0.2 1 1 193522 7 92'* 9.22,* 0.92'* Particulate 0.86 1 1 1 101984 50 7,* 0.68'* 0.07,* Arsenic 0.0005 1 0.12 1 7 0.00023 101'* 10.14,* 1.01'* Cadmium 0.0013 0.2 0.77 1 23 0.00056 139'* 13.93'* 1.39'* Chromium 0.002 1 0.05 1 12 1.2 0'* 0.00'* 0.00'* Chrome VI 0.0002 1 0.05 1 1 8E-05 42'* 4.17'* 0.42'* Lead 0.0268 1 0.45 1 1428 1.5 3'* 0.32'* 0.03'* Mercury 0.0048 1 1 1 571 0.12 16'* 1.59'* 0.16,* T.E.TCDD 4.8E-08 0.2 1 1 0.00114 3E-08 127'* 12.67,* 1.27'*

BOILER WITH FABRIC FILTER AIR POLLUTION CONTROL

Stack Emission Cone. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = OF = OF =

Waste Factor Factor Factor @300F ug/m3 1000 10,000 100,000 HCI 8.16 1 1 0.04 44341 7 21% 2.11 % 0.21% Particulate 0.86 1 1 0.08 9347 50 1% 0.06% 0.01% Arsenic 0.0005 1 0.12 0.31 3 0.00023 43% 4.35% 0.43% Cadmium 0.0013 1 0.77 0.01 1 0. 00056 6% 0.60% 0.06% Chromium 0.002 1 0.05 0.21 3 1.2 0% 0.00% 0.00% Chrome VI 0.0002 1 0.05 0.21 0 8E-05 0% 0.00% 0.00% Lead 0.0268 1 0.45 0.01 16 1.5 0% 0.00% 0.00% Mercury 0.0048 1 1 1 654 0.12 18% 1.82% 0.18% T.E.TCO O 4.8E-08 1 1 0.77 0.0050 3E-08 559% 55.86% 5.59%

BOILER WITH WET SCRUBBER AIR POLLUTION CONTROL

Stack Emission Cone. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = OF = OF =

Waste Factor Factor Factor @145F ug/m3 1000 10,000 100,000 HCI 8.16 1 1 0.001 1306 7 1% 0.06% 0.01% Particulate 0.86 1 1 0.46 63319 50 4% 0.42% 0.04% Arsenic 0.0005 1 0.12 0.33 3 0.00023 43% 4.35% 0.43% Cadmium 0.0013 1 0.77 0.53 56 0.00056 333% 33.33% 3.33% Chromium 0.002 1 0.05 0.50 8 1.2 0% 0.00% 0.00% Chrome VI 0.0002 1 0.05 0.50 1 8E-05 42% 4.17% 0.42% Lead 0.0268 1 0.45 0.53 1021 1.5 2% 0.23% 0.02% Mercury 0.0048 1 1 0.906 699 0.12 19% 1.94% 0.19% T.E.TCO O 4.8E-08 1 1 0.28 0.0020 3E-08 217% 21.71 % 2.17%

BOILER WITH FABRIC FILTER AIR POLLUTION CONTROL

Stack Emission Cone. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC DF = DF = DF =

Waste Factor Factor Factor @300F ug/m3 1000 10,000 100,000 HCI 8.16 1 1 0.04 44341 7 21O/C 2.11O/C 0.21O/C Particulate 0.86 1 1 0.08 9347 50 1O/C 0.06o/c 0.01o/c Arsenic 0.0005 1 0.12 0.31 3 0.00023 43o/c 4.35o/c O.43o/c Cadmium 0.0013 1 0.77 0.01 1 0.00056 6o/c 0.60o/c 0.06o/c Chromium 0.002 1 0.05 0.21 3 1.2 Oo/c O.OOo/c O.OOo/c Chrome VI 0.0002 1 0.05 0.21 a 8E-05 Oo/c O.OOo/c O.OOo/c Lead 0.0268 1 0.45 0.01 16 1.5 Oo/c O.OOo/c O.OOo/c Mercury 0.0048 1 1 1 654 0.12 18o/c 1.82O/C 0.18o/c T.E.TCDD 4.8E-08 1 1 0.77 0.0050 3E-08 559o/c 55.86o/c 5.59o/c

BOILER WITH WET SCRUBBER AIR POLLUTION CONTROL

Stack Emission Cone. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC DF = DF = DF = Waste Factor Factor Factor @145F ug/m3 1000 10,000 100,000

HCI 8.16 1 1 0.001 1306 7 1O/C 0.06o/c 0.01o/c Particulate 0.86 1 1 0.46 63319 50 4O/C 0.42O/C O.04o/c Arsenic 0.0005 1 0.12 0.33 3 0.00023 43o/c 4.35o/c 0.43o/c Cadmium 0.0013 1 0.77 0.53 56 0.00056 333o/c 33.33o/c 3.33o/c Chromium 0.002 1 0.05 0.50 8 1.2 Oo/c O.OOo/c O.OOo/c Chrome VI 0.0002 1 0.05 0.50 1 8E-05 42O/C 4.17O/C 0.42O/C Lead 0.0268 1 0.45 0.53 1021 1.5 2O/C 0.23o/c 0.02o/c Mercury 0.0048 1 1 0.906 699 0.12 19o/c 1.94o/c 0.19o/c T.E.TCDD 4.8E-08 1 1 0.28 0.0020 3E-08 217O/C 21.71O/C 2.17O/C

REM-FAC REMOVAL FACTORS - FOR KANSAS PAPER

BOILER WITHOUT AIR POLLUTION CONTROL

Stack Emission Conc. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = OF = OF =

Waste Factor Factor Factor @450F ug/m3 1000 10,000 100,000 HCI 8.16 1 1 1 967611 7 461O/C 46.08o/c 4.61O/C Particulate 0.86 1 1 1 101984 50 7O/C 0.68o/c 0.07o/c Arsenic 0.0005 1 0.12 1 7 0.00023 101O/C 10.14O/C 1.01o/c Cadmium 0.0013 1 0.77 1 117 0.00056 696o/c 69.64o/c 6.96o/c Chromium 0.002 1 0.05 1 12 1.2 OO/C O.OOo/c O.OOo/c Chrome VI 0.0002 1 0.05 1 1 8E-05 42O/C 4.17O/C 0.42O/C Lead 0.0268 1 0.45 1 1428 1.5 3o/c 0.32O/C 0.03o/c Mercury 0.0048 1 1 1 571 0.12 16o/c 1.59o/c 0.16o/c T.E.TCDD 4.8E-08 1 1 1 0.0057 3E-08 633o/c 63.33o/c 6.33o/c

BOILER WITHOUT AIR POLLUTION CONTROL - REMOVING 80% OF CRITICAL POLLUTANTS

Stack Emission Conc. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = OF = OF = Waste Factor Factor Factor @450F ug/m3 1000 10,000 100,000

HCI 8.16 0.2 1 1 193522 7 92O/C 9.22O/C 0.92O/C Particulate 0.86 1 1 1 101984 50 7O/C 0.68o/c 0.07o/c Arsenic 0.0005 1 0.12 1 7 0.00023 101O/C 10.14O/C 1.01O/C Cadmium 0.0013 0.2 0.77 1 23 0.00056 139o/c 13.93o/c 1.39o/c Chromium 0.002 1 0.05 1 12 1.2 Oo/c O.OOo/c O.OOo/c Chrome VI 0.0002 1 0.05 1 1 8E-05 42O/C 4.17O/C 0.42O/C Lead 0.0268 1 0.45 1 1428 1.5 3o/c 0.32O/C 0.03o/c Mercury 0.0048 1 1 1 571 0.12 16o/c 1.59o/c 0.16o/c T.E.TCDD 4.8E-08 0.2 1 1 0.00114 3E-08 127O/C 12.67o/c 1.27O/C

REM-FAC REMOVAL FACTORS - FOR KANSAS PAPER

BOILER WITHOUT AIR POLLUTION CONTROL

Stack

Emission Conc. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = O F = O F =

Waste Factor Factor Factor @450F ug/m3 1000 10,000 100,000

HCI 8.16 1 1 1 967611 7 461% 46.08% 4.61%

Particulate 0.86 1 1 1 101984 50 7% 0.68% 0.07%

Arsenic 0.0005 1 0.12 1 7 0.00023 101% 10.14% 1.01 %

Cadmium 0.0013 1 0.77 1 117 0.00056 696% 69.64% 6.96%

Chromium 0.002 1 0.05 1 12 1.2 0% 0.00% 0.00%

Chrome VI 0.0002 1 0.05 1 1 8E-05 42% 4.17% 0.42%

Lead 0.0268 1 0.45 1 1428 1.5 3% 0.32% 0.03%

Mercury 0.0048 1 1 1 571 0.12 16% 1.59% 0.16%

T.E.TCO O 4.8E-08 1 1 1 0.0057 3E-08 633% 63.33% 6.33%

BOILER WITHOUT AIR POLLUTION CONTROL - REMOVING 80% OF CRITICAL POLLUTANTS

Stack

Emission Conc. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC OF = O F = O F =

Waste Factor Factor Factor @450F ug/m3 1000 10,000 100,000

HCI 8.16 0.2 1 1 193522 7 92% 9.22% 0.92%

Particulate 0.86 1 1 1 101984 50 7% 0.68% 0.07%

Arsenic 0.0005 1 0.12 1 7 0.00023 101% 10.14% 1.01 % Cadmium 0.0013 0.2 0.77 1 23 0.00056 139% 13.93% 1.39%

Chromium 0.002 1 0.05 1 12 1.2 0% 0.00% 0.00%

Chrome VI 0.0002 1 0.05 1 1 8E-05 42% 4.17% 0.42%

Lead 0.0268 1 0.45 1 1428 1.5 3% 0.32% 0.03%

Mercury 0.0048 1 1 1 571 0.12 16% 1.59% 0.16%

T.E.TCO O 4.8E-08 0.2 1 1 0.00114 3E-08 127% 12.67% 1.27%

BOILER WITH FABRIC FILTER AIR POLLUTION CONTROL

Stack

Emission Cone. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC DF = DF = DF =

Waste Factor Factor Factor @300 F ug/m3 1 000 1 0,000 1 00,000

HCI 8. 1 6 1 1 0.04 44341 7 21 O/C 2. 1 1 O/C 0.21 O/C

Particulate 0.86 1 1 0.08 9347 50 1 O/C 0.06o/c 0.01 o/c

Arsenic 0.0005 1 0. 1 2 0.31 3 0.00023 43o/c 4.35o/c O.43o/c

Cadmium 0.0013 1 0.77 0.01 1 0.00056 6o/c 0.60o/c 0.06o/c

Chromium 0.002 1 0.05 0.21 3 1 .2 Oo/c O.OOo/c O.OOo/c

Chrome VI 0.0002 1 0.05 0.21 0 8E-05 Oo/c O.OOo/c O.OOo/c

Lead 0.0268 1 0.45 0.01 1 6 1 .5 Oo/c O. OOo/c O.OOo/c

Mercury 0.0048 1 1 1 654 0. 1 2 1 8o/c 1 . 82O/C 0.1 8o/c

T E.TCDD 4.8E-08 1 1 0.77 0.0050 3E-08 559o/c 55.86o/c 5.59o/c

BOILER WITH WET SCRU BBER AIR POLLUTION CONTROL

Stack

Emission Cone. Acceptable GLC, % of AGLC, Annual Avg.

POLLUTANT Ib/ton Removal Partition Control ug/m3 GLC DF = DF = DF =

Waste Factor Factor Factor @ 1 45 F ug/m3 1 000 1 0,000 1 00,000

HCI 8. 1 6 1 1 0.001 1 306 7 1 O/C 0.06o/c 0.01 o/c

Particulate 0.86 1 1 0.46 6331 9 50 4O/C 0.42O/C O.04o/c

Arsenic 0.0005 1 0. 1 2 0.33 3 0.00023 43o/c 4.35o/c O.43o/c

Cadmium 0.001 3 1 0.77 1 1 58 0.00056 940O/C 94.05o/c 9.40O/C

Chromium 0.002 1 0.05 0.49 8 1 .2 Oo/c O.OOo/c O.OOo/c

Chrome VI 0.0002 1 0.05 0.49 1 8E-05 42O/C 4. 1 7O/C 0.42O/C

Lead 0.0268 1 0.45 0.53 1 021 1 .5 2O/C 0.23o/c 0.02o/c

Mercury 0.0048 1 1 0.906 699 0. 1 2 1 9o/c 1 .94o/c 0. 1 9%

TE.TCDD 4.8E-08 1 1 0.28 0.0020 3E-08 2 1 7o/c 2 1 . 7 1 O/C 2. 1 7O/C