COMBUSTION
HUMAN
HEALTH
RISK
ASSESSMENT
FOR
WESTVACO
CORPORATION
DERIDDER,
LOUISIANA
Prepared
by
US
EPA
Region
6
Center
for
Combustion
Science
and
Engineering
Dallas,
Texas
July
24,
2002
TABLE
OF
CONTENTS
Foreword
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1
Executive
Summary
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2
Background
Information
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6
Facility
and
Source
Information
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7
Air
Modeling
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10
Compounds
of
Potential
Concern
(
COPCs)
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11
Exposure
Assessment
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16
Study
Area
Characterization
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16
Exposure
Scenario
Locations
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17
Transport
and
Fate
Parameters
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17
Risk
Characterization
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17
Excess
Cancer
Risks
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18
Non­
Carcinogenic
Health
Effects
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19
Other
Risks
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19
Uncertainty
Discussion
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20
Modified
Parameters
for
Dioxins/
Furans
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20
Comparison
Risk
Model
Evaluation
for
Dioxins/
Furans
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21
Bio­
Transfer
Factors
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21
Use
of
Non­
Detected
Compounds
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22
Compounds
Dropped
from
Quantitative
Analysis
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23
Unidentified
Organic
Compounds
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23
Conclusion
&
Recommendations
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23
References
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26
List
of
Appendices
Appendix
A:
Air
Modeling
Appendix
B:
Spreadsheets
Appendix
C:
Mapping
Appendix
D:
Risk
Modeling
Appendix
E:
IRAP­
h
View
Project
Files
Page
1
of
27
FOREWORD
On
May
18,
1993,
the
United
States
Environmental
Protection
Agency
(
EPA)
announced
a
series
of
steps
that
the
Agency
would
undertake,
first,
to
achieve
reductions
in
the
amount
of
hazardous
waste
generated
in
this
country
and,
second,
to
ensure
the
safety
and
reliability
of
hazardous
waste
combustion
in
incinerators,
boilers,
and
industrial
furnaces.
With
this
announcement,
EPA
released
its
Draft
Hazardous
Waste
Minimization
and
Combustion
Strategy.
Eighteen
months
later,
EPA's
released
its
Final
Strategy
which
solidified
the
Agency's
policy
on
"
how
best
to
assure
the
public
of
safe
operation
of
hazardous
waste
combustion
facilities."
In
short,
EPA's
Final
Strategy
specifically
recognized
the
multi­
pathway
risk
assessment
as
a
valuable
tool
for
evaluating
and
ensuring
protection
of
human
health
and
the
environment
in
the
permitting
of
hazardous
waste
combustion
facilities.

In
keeping
with
EPA's
Final
Strategy,
Region
6
believes
that
those
combustion
facilities
which
are
in
close
proximity
to
population
centers
can
be
evaluated
by
a
multi­
pathway
risk
assessment
to
ensure
that
permit
limits
are
protective
of
human
health.
Furthermore,
EPA
Region
6
believes
that
multi­
pathway
risk
assessments
should
consider
the
specific
nature
of
process
operations
and
the
type
of
combustion
units
and
air
pollution
control
equipment
utilized
at
each
facility
in
order
to
be
representative
of
actual
facility
operations.
Therefore,
although
certain
provisions
of
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
program
have
since
been
delegated
to
the
States,
EPA
Region
6
is
committed
to
reviewing
facilities
on
a
site
specific
basis
to
evaluate
the
protectiveness
of
permits
for
combustion
operations.

EPA
Region
6,
in
partnership
with
the
Louisiana
Department
of
Environmental
Quality
(
LDEQ),
requested
more
comprehensive
testing
for
boiler
and
industrial
furnace
(
BIF)
combustion
facilities
in
the
State
of
Louisiana
as
part
of
the
regulatory
trial
burn
testing
conducted
during
early
1997
through
1998.
Although
the
science
of
combustion
risk
assessments
was
still
under
development,
BIF
facilities
agreed
to
conduct
more
comprehensive
testing
prior
to
EPA's
completion
of
the
revised
national
guidance
documents
for
combustion
emissions
testing
and
risk
assessment
protocols.
Based
upon
the
nature
of
their
operations,
EPA
allowed
BIF
facilities
to
demonstrate
their
performance
at
"
normal
operating
conditions"
during
the
trial
burn
by
adding
a
separate
"
risk
burn"
test
condition.
The
information
from
the
risk
burn
was
collected
with
the
intent
of
EPA
conducting
facility­
specific
human
health
risk
assessments.

In
July
1998,
EPA
published
its
Human
Health
Risk
Assessment
Protocol
for
Hazardous
Waste
Combustion
Facilities,
Peer
Review
Draft
(
EPA530­
D­
98­
001
A,
B,
and
C),
commonly
referred
to
as
the
HHRAP.
In
August
1998,
EPA
issued
its
Guidance
on
Collection
of
Emissions
Data
to
support
Site­
Specific
Risk
Assessments
at
Hazardous
Waste
Combustion
Facilities,
Peer
Review
Draft
(
EPA530­
D­
98­
002).
In
the
following
year,
EPA
staff
worked
through
several
implementation
issues
in
applying
these
guidance
documents
and
in
July
1999,
EPA
issued
an
Errata
to
the
HHRAP
(
EPA
Memo,
July
1999)
which
addressed
issues
specific
to
conducting
human
health
risk
assessments.
EPA
utilized
the
above
listed
guidance
documents,
along
with
facility
specific
information,
to
complete
this
human
health
risk
assessment.
This
risk
assessment
report
documents
the
Agency's
effort
in
ensuring
protective
permit
limits
and
ensuring
that
normal
combustion
facility
operations
do
not
pose
unacceptable
risks
to
surrounding
communities.
Page
2
of
27
EXECUTIVE
SUMMARY
The
Westvaco
Corporation
("
Westvaco")
applied
to
the
LDEQ
for
a
RCRA
permit
to
burn
hazardous
waste
in
two
BIF
units
at
their
facility
located
in
DeRidder,
Beauregard
Parish,
Louisiana
("
DeRidder
facility").
In
order
to
assist
LDEQ
in
identifying
any
additional
permit
conditions
which
might
be
necessary
to
ensure
protection
of
human
health,
EPA
has
conducted
this
risk
assessment.
This
assessment
evaluates
those
potential
emissions
from
the
one
RCRA
point
source
at
Westvaco's
DeRidder
facility,
a
common
stack
for
Boilers
No.
1,
No.
2,
No.
3,
and
No.
4
(
Boiler
No.
1
is
closed
and
Boiler
No.
4
is
a
non­
hazardous
waste
boiler),
as
well
as
potential
fugitive
emissions
associated
with
operation
of
the
RCRA
combustion
units.

Data
in
lieu
of
Trial/
Risk
Burn
Testing
was
proposed
for
use
in
the
risk
assessment
by
Westvaco
in
their
"
BIF
Data
Package"
submittal,
dated
December
17,
1996.
The
data
for
dioxin/
furans,
particulate
matter,
particle
size
distribution,
metals,
chloride,
and
sulfur
were
accepted
by
EPA
in
correspondence
dated
January
31,
1997.
All
other
data
necessary
for
risk
assessment
purposes
were
collected
during
the
Risk
Burn
Testing
event
and
subsequent
Certification
of
Compliance
(
COC)
testing
events.
Upon
comparison
of
the
various
data
sets,
EPA
noted
that
the
emission
levels
for
dioxin
and
furan
congeners
demonstrated
during
the
2001
COC
testing
event
were
much
higher
than
the
congener
emission
levels
demonstrated
during
the
1995
and
1998
COC
testing
events.
Many
variables
may
have
contributed
to
this
difference
in
results
and
are
discussed
in
appropriate
sections
of
this
report
along
with
their
potential
impact.
In
summary,
the
1995/
1998
data,
corresponding
to
risk
burn
operating
conditions,
did
not
result
in
risk
estimates
above
EPA
levels
of
concern.
However,
the
risk
estimates
associated
with
the
2001
COC
operating
conditions
and
emission
rate
levels
do
exceed
EPA
levels
of
concern.

EPA's
risk
assessment
evaluates
not
only
representative
operating
data,
but
also
those
risk­
based
permit
limits
that
can
be
incorporated
into
the
RCRA
permit
in
order
to
supplement
regulatory
maximum
allowable
limits
and
ensure
protection
of
human
health
over
the
long
term.
Specifically
for
Westvaco,
EPA
recommends
risk­
based
waste
feed
limits
for
metals
(
necessitated
by
the
evaluation
of
Tier
1
regulatory
limits
for
metals).
Based
upon
the
variance
in
operating
conditions
and
results
from
the
2001
COC
test
event,
EPA
also
recommends
a
risk­
based
emission
rate
limit
for
incorporation
into
the
RCRA
permit
of
4.24E­
10
grams
per
second
TCDDE
(
2,3,7,8­
tetrachlorinated
dibenzo­
p­
dioxin
equivalencies).
Recommended
permit
limits
are
provided
in
Executive
Summary
Tables
ES­
1
and
ES­
2.
The
risk
assessment
indicates
that
"
normal
operations"
of
the
BIF
hazardous
waste
combustion
units
at
the
DeRidder
facility
should
not
adversely
impact
human
health,
with
incorporation
of
EPA's
recommended
permit
limits
and
operating
conditions.
Page
3
of
27
Table
ES­
1:
Waste
Feed
Rates
(
g/
s)

Metals
of
Concern
Recommended
Risk­
Based
1
Permit
Limit
Annual
Average
"
Normal
Operations"
Data
in
Lieu
of
Risk
Burn
Testing
(
BIF
Data
Package
2)

Antimony
4.17E­
01
ND
3
=
1.63E­
03
Arsenic
3.33E­
02
ND
3
=
1.63E­
03
Barium
7.22E­
01
6.53E­
04
Beryllium
6.11E­
03
ND
3
=
3.25E­
04
Cadmium
1.61E­
03
ND
3
=
3.25E­
04
Chromium
(
Total)
1.19E­
03
4
ND
3
=
3.25E­
04
Lead
1.28E+
00
9.78E­
04
Mercury
(
Total)
2.60E­
06
5
ND
3
=
6.19E­
05
Nickel
5.58E­
02
5.58E­
05
6
Silver
8.34E­
02
ND
3
=
3.25E­
04
Selenium
1.39E­
03
1.39E­
06
6
Thallium
8.34E­
02
ND
3
=
1.63E­
03
NOTES:
1.
Recommended
RCRA
Permit
Limits
are
based
upon
an
annual
average
stack
gas
temperature
of
459
K
and
an
annual
average
stack
gas
flow
rate
of
58
m3/
s
as
demonstrated
during
the
risk
burn
and
alternative
COC
sampling
events.
The
recommended
limits
were
also
evaluated
at
those
conditions
demonstrated
during
the
2001
COC
testing
event
(
61
m3/
s
@
439
K)
and
found
to
still
be
protective.

2.
Metals
Emissions
Data
in
Lieu
of
Trial/
Risk
Burn
Testing
was
submitted
by
Westvaco
in
their
"
BIF
Data
Package",
dated
December
17,
1996,
Table
5.

3.
ND
means
that
the
metal
was
not
detected
in
the
waste
feed;
the
detection
limit
was
used
to
calculate
the
emission
rate
shown.

4.
Recommended
RCRA
Permit
Limit
for
Chromium
is
actually
based
upon
the
assumption
that
Hexavalent
Chromium
is
equal
to
100%
of
the
Total
Chromium
measured
in
the
waste
feed.

5.
Mercury
is
not
believed
to
be
present
in
the
waste
feed,
but
the
analytical
method
used
in
the
risk
burn
did
not
provide
low
enough
detection
limits
for
comparison
with
the
Recommended
RCRA
Permit
Limit.
The
Risk­
Based
Annual
Average
RCRA
Permit
Limit
for
mercury
is
based
upon
a
reliable
detection
limit
for
mercury
of
0.01
ppm
and
the
volumetric
flow
rate
demonstrated
during
the
Risk
Burn.

6.
Nickel
and
Selenium
were
estimated
from
fly
ash
sampling,
estimates
provided
in
the
"
BIF
Data
Package"
as
data
in
lieu
of
testing.
Page
4
of
27
Table
ES­
2:
Comparison
of
TCDDE
Emission
Rates
(
g/
s)

Source
of
Data/
Limit
TCDDE
(
g/
s)
Comments
Recommended
Risk­
Based
Permit
Limit
(
Long­
Term
Average
Value1)
4.24E­
10
Based
upon
an
annual
average
stack
gas
temperature
of
439
K
and
an
annual
average
stack
gas
flow
rate
of
61
m3/
s
as
demonstrated
during
the
2001
COC.
Compliance
with
this
level
was
demonstrated
during
the
1998
COC
testing
event.

December
2001
COC
Testing
(
2002
COC
Form)
4.24E­
09
Significant
increase
in
value
from
historical
data
is
assumed
attributable
to
operational
testing
scheme
changes
(
e.
g.,

configuration
of
boilers
tested,
combination
of
waste
feed
streams,
exit
temp,
etc.).

June
1998
COC
Testing
(
1998
COC
Form)
4.04E­
10
Improved
analytical
capabilities
from
the
1995
COC
testing
event
most
probably
account
for
the
lower
value
obtained
here
in
comparison
to
the
1995
test.
Operational
conditions
were
sufficiently
similar.

1995
COC
Testing
("
Data
in
Lieu
of"
Risk
Burn
Testing;

1996
BIF
Data
Package)
7.584E­
10
Congener­
specific
data
not
evaluated
due
to
the
older
analytical
method
used
for
this
testing
event.
This
calculated
value
was
taken
from
Table
1
of
the
BIF
Data
Package
for
comparative
analysis
only.

NOTE:
1.
A
3­
year
initial
sampling
frequency
is
recommended
in
order
to
effectively
demonstrate
compliance
with
the
Risk­
Based
Permit
Limit.
Due
to
the
long
term
nature
of
the
risk
assessment,
an
annual
average
emission
rate
value
is
not
practical.
Sampling
every
3
years
will
provide
data
for
determining
a
9
year
average
value.
If
compliance
is
demonstrated
for
the
first
nine
years,
the
sampling
frequency
may
be
lessened
to
every
5
years.
Page
5
of
27
EPA
back­
calculated
the
risk­
based
annual
average
waste
feed
limits
listed
in
Table
ES­
1
from
the
Tier
I
limit
for
each
metal
of
concern
and
then
used
the
calculated
limits
in
the
risk
assessment
in
order
to
show
permit
protectiveness
over
the
long
term.
For
those
metals
where
the
Tier
I
limit
did
not
result
in
risks
above
EPA
levels
of
concern,
EPA
merely
set
the
risk
based
limit
at
that
tier
limit
evaluated
in
the
risk
assessment.
For
those
metals
not
having
regulatory
maximum
limits
specified
by
the
regulations
(
i.
e.,
nickel
and
selenium),
EPA
calculated
risk­
based
limits
in
consideration
of
the
available
data­
in­
lieu­
of
BIF
Data
Package
as
appropriate.
Therefore,
EPA
recommends
that
LDEQ
incorporate
the
annual
average
metal
feed
rate
limits
listed
in
Table
ES­
1
into
the
RCRA
permit.

EPA
calculated
the
risk­
based
TCDDE
emission
rate
limit
shown
in
Table
ES­
2
from
evaluation
of
the
individual
dioxin
and
furan
congener
emission
rates
and
assumed
that
the
mix
of
individual
congeners
would
not
significantly
change
unless
operations
change.
Given
the
need
for
a
risk­
based
permit
limit,
EPA
took
into
account
the
possible
change
in
TCDD
slope
factor
anticipated
within
the
next
year
and
set
the
recommended
TCDDE
limit
at
the
corresponding
congener
levels
necessary
to
not
exceed
a
one
in
one
hundred
thousand
(
1E­
5)
carcinogenic
risk
level.
This
TCDDE
level
was
compared
with
the
most
stringent
dioxin
and
furan
Hazardous
Waste
Combustion
Maximum
Achievable
Control
Technology
(
MACT)
Interim
Standard
currently
promulgated
for
incinerator
systems,
cement
kilns,
and
light
weight
aggregate
kilns
(
0.2
ng/
dscm)
since
a
MACT
standard
has
not
yet
been
promulgated
for
BIF
units.
However,
the
MACT
Interim
Standards
are
concentration­
based
and
when
converted
to
a
mass
basis
for
the
Westvaco
stack,
the
dioxin
limit
was
higher
than
the
risk­
based
limit
being
recommended.
Since
the
calculated
risk­
based
limit
was
virtually
the
same
level
demonstrated
during
the
1998
COC
testing,
and
the
original
risk
analysis
did
not
result
in
TCDDE
risks
above
EPA
levels
of
concern,
the
calculated
TCDDE
limit
will
ensure
permit
protectiveness
over
the
long
term.
Therefore,
EPA
recommends
that
LDEQ
incorporate
the
TCDDE
emission
rate
limit
listed
in
Table
ES­
2
into
the
RCRA
permit.

EPA
evaluated
the
most
current
information
available
to
estimate
potential
impacts
to
human
health,
both
directly
via
inhalation
and
incidental
soil
ingestion,
and
indirectly
via
modeled
deposition
and
uptake
through
the
food
chain.
Ingestion
of
drinking
water,
via
surface
water
intakes,
was
not
considered
since
all
drinking
water
comes
from
groundwater
sources.
Emissions
data
collected
as
part
of
the
risk
burn
and
subsequent
data
collected
during
Certification
of
Compliance
(
COC)
testing
events,
operational
data
specific
to
the
DeRidder
facility,
and
site­
specific
information
based
upon
the
facility's
location,
were
evaluated
and
considered
in
making
assumptions
and
in
predicting
risks
associated
with
long
term
operations.
The
risk
estimates
provided
in
this
risk
assessment
are
conservative
in
nature
and
represent
possible
future
risks,
based
upon
those
operating
conditions
evaluated
for
issuance
of
a
final
RCRA
combustion
permit.
If
operations
change
significantly,
or
land
use
changes
occur
which
would
result
in
more
frequent
potential
exposure
to
receptors,
risks
from
facility
operations
may
need
to
be
reevaluated.
Page
6
of
27
BACKGROUND
INFORMATION
This
risk
assessment
report
presents
a
brief
description
of
Westvaco's
DeRidder
facility
and
the
emission
sources
evaluated,
the
air
modeling
effort
conducted,
the
risk
modeling
effort
conducted,
and
EPA's
evaluation
of
risk
estimates
based
upon
the
information
presented.
EPA
utilized
the
Industrial
Source
Complex
Short
Term
Version
3
Program
(
EPA,
ISCST3
software)
for
air
modeling
and
the
Industrial
Risk
Assessment
Program
­
Health
(
Lakes
Environmental,
IRAP­
h
View
software
Version
1.7)
for
risk
modeling.
EPA
utilized
the
ArcView
Program
(
Environmental
Systems
Research
Institute,
software
Version
3.1),
for
desktop
Geographical
Information
Systems
(
GIS),
for
all
mapping
efforts.
All
available
information
used
to
assess
risks
attributable
to
the
DeRidder
facility
can
be
found
in
electronic
format,
converted
mainly
to
pdf
files,
in
appendices
enclosed
via
compact
disc
with
this
risk
assessment
report
as
follows:

Appendix
A:
Air
Modeling
Audit
Files
Input
and
Output
Air
Files
from
the
ISCT3
Model
Plot
Files
ISC
File
(
file
built
for
import
into
the
IRAP­
h
Project
File)
Appendix
B:
Spreadsheets
Surface
Roughness
Calculation
Source
Emission
Rate
Calculations
Transport
&
Fate
Parameters
Total
Organic
Emissions
(
TOE)
Factor
Appendix
C:
Mapping
Background
Maps
Land
Use
Shape
Files
Appendix
D:
Risk
Modeling
Source
Information
from
the
IRAP­
h
Project
File
Receptor
Information
from
the
IRAP­
h
Project
File
Risk
Summary
Information
from
the
IRAP­
h
Project
File
Appendix
E:
IRAP­
h
View
Project
Files
Readme
File
Metals.
ihb
­
Metals
Only
Run,
Tier
I
limits
for
Westvaco
facility
evaluated
Westvaco
Original
Run.
ihb
­
All
Chemicals
Run,
with
metals
adjusted
to
risk­
based
permit
limits
Metals­
Compare.
ihb
­
Revised
air
model
incorporated
to
evaluate
2002
COC
conditions
for
riskbased
metal
permit
limits;
Westvaco
Comparison
Run.
ihb
­
Same
as
Metals­
Compare.
ihb,
but
metals
were
replaced
with
dioxin
and
furan
congener
emission
rates
reported
in
2002
COC
form.
This
run
necessary
for
the
supplemental
dioxin/
furan
risk
evaluation.

Since
The
HHRAP
provides
generic
discussions
of
the
uncertainties
associated
with
each
major
component
of
the
risk
assessment
process,
this
report
only
discusses
those
uncertainties
particular
to
the
site
specific
results
evaluated
for
Westvaco's
DeRidder
facility.
References
are
provided
at
the
end
of
this
document.
Page
7
of
27
Facility
and
Source
Information
The
DeRidder
facility
is
located
along
Louisiana
State
Highway
2
near
DeRidder,
Beauregard
Parish,
Louisiana.
The
facility
is
bordered
on
the
north
and
the
east
by
forested
land;
on
the
south
by
Palmetto
Creek;
and
on
the
west
by
residences,
and
forested
land.
Land
use
surrounding
the
facility
consists
primarily
of
rural
land
use,
including
residences,
agricultural
land,
surface­
water
bodies,
and
wetlands.

Westvaco
facility
operations
in
DeRidder,
Louisiana
include
tall
oil
refining
and
post
refining
operations
which
include
solution
resinates
and
hard
resin
manufacturing.
Tall
oil
is
fractionated
into
rosin
and
fatty
acids
that
are
used
in
the
production
of
various
rosin­
based
resins
and
resinates.
Rosins
and
fatty
acids
are
also
used
to
produce
adhesives,
coatings,
and
wax
compounds.
In
addition,
the
facility
in
DeRidder
also
has
an
acrylic
resin
manufacturing
plant.
This
plant
includes
two
major
processes:
an
acrylic
emulsion
process
and
a
styrenic­
acrylic
hard
resin
process.

The
primary
hazardous
waste
stream
generated
by
facility
operations
is
burned
for
fuel
value
in
the
on­
site
boilers.
This
waste
stream
is
a
toluene­
ladened
filter­
aid,
with
a
waste
code
designation
of
D001
(
ignitability).
Historically,
this
waste
stream
also
carried
an
F005
(
solvent
wastes)
listing,
but
this
listing
was
dropped
due
to
characterization
and
reclassification
of
the
waste
stream.
The
filter­
aid
is
a
cellulose
base
material.
Other
hazardous
waste
streams
have
historically
included
the
following:
the
HC­
920
Sparge
Oil,
a
D001
waste;
the
Waste
Laboratory
Solvents,
combination
of
D001,
F003,
and
F005
wastes;
and
the
Acrylic
Hard
Resin
Spent
Solvents,
also
a
D001
waste.
However,
the
facility
no
longer
burns
the
Waste
Laboratory
Solvents
stream
(
1995
decision).
Therefore,
current
operations
involve
only
those
streams
designated
as
D001
wastes.
These
components
are
mixed
with
either
non­
hazardous
light
ends
or
non­
hazardous
waste
fuel
prior
to
being
fed
to
one
of
two
onsite
hazardous
waste
boilers.
Based
upon
the
low
risk
waste
exemption
in
40
CFR
266.109,
the
waste
fuel
blend
may
consist
of
at
least
50%
tall
oil
derived
fuel
(
coproduct
known
as
"
tall
oil
heads")
or
fuel
oil,
and
a
maximum
of
50%
hazardous
waste
fuels
(
resinate
filter
cake,
HC­
920/
sparge
oil,
acrylic
process
spent
organics/
acrylic
process
overheads).
The
DeRidder
facility
operations
result
in
waste
fuel
normally
consisting
of
approximately
85%
primary
fuel
and
15%
hazardous
waste
components.

The
Boiler
House
generates
steam
for
use
throughout
the
DeRidder
facility.
The
boilers
within
the
Boiler
House
are
designated
as
Boilers
1,
2,
3,
and
4
and
all
share
a
common
Electrostatic
Precipitator
(
ESP)
and
common
exhaust
stack
(
Common
Stack).
Boiler
1
is
not
currently
in
service
and
Boiler
4
only
burns
nonhazardous
waste
(
e.
g.,
tall
oil
pitch,
natural
gas,
or
small
quantities
of
other
non­
hazardous
fuels).
Boilers
2
and
3
are
identical
60
to70
million
BTU
per
hour
Combustion
Engineering
Stirling
type
boilers
(
Model
VAX
with
Coen
burners.
These
two
units
are
water­
tube,
single
wall­
fired
boilers
with
design
ratings
of
approximately
60,000
pounds
of
steam
per
hour.
The
operating
conditions
of
Boilers
2
and
3
are
the
same,
but
only
one
boiler
at
a
time
burns
hazardous
waste.
The
temperature
in
the
firebox
of
Boiler
2/
3
is
approximately
2200oF
during
normal
conditions.

Westvaco
operates
each
unit
under
a
Tier
I
status,
which
simply
means
that
all
of
the
metals
fed
to
the
unit
are
assumed
to
be
emitted
in
the
stack
gas.
Therefore,
the
regulations
limit
stack
metal
emissions
based
on
the
hourly
feed
rate
of
individual
metals
into
the
combustion
unit.
A
destruction
and
removal
efficiency
(
DRE)
test
for
organic
compounds
was
not
performed
on
Boiler
2/
3
because
operations
meet
the
exemption
from
DRE
testing
in
accordance
with
Title
40
of
the
Code
of
Federal
Regulations
(
CFR)
266.109.
The
1997
Risk
Burn
provides
speciated
organic
emissions
data
for
use
in
the
risk
assessment,
as
does
Westvaco's
1995
Page
8
of
27
COC
test
 
requested
by
Westvaco
to
be
used
as
data
in
lieu
of
testing
for
the
Risk
Burn
(
metals
and
dioxins
and
furans
were
allowed
by
EPA
to
be
used
in
lieu
of
testing
at
the
time
of
the
Risk
Burn).
Subsequent
COC
testing
events
in
1998
and
2001
also
provide
updated
speciated
organic
emissions
data
for
dioxins
and
furans
during
operations
that
simulate
operations
measured
during
the
Risk
Burn
testing.
EPA
has
utilized
all
of
the
available
speciated
emissions
data
in
conducting
this
risk
assessment,
although
some
of
the
data
needed
separate
evaluation
in
consideration
of
corresponding
"
operational"
conditions
for
each
set
of
data
collected.
Some
of
the
differences
in
test
conditions
outlined
below,
but
how
the
data
from
these
various
test
events
were
used
in
this
risk
assessment
are
discussed
in
the
appropriate
sections
of
this
report.

A
risk
burn
is
considered
an
additional
operating
condition
of
the
trial
burn
during
which
data
are
collected
to
demonstrate
that
the
hazardous
waste­
burning
boiler
unit
does
not
pose
an
unacceptable
health
risk
when
operating
at
typical
(
or
normal)
operating
conditions
over
the
long
term.
Based
upon
the
fact
that
Boiler
3
is
only
used
when
Boiler
2
is
down
for
maintenance
and
the
fact
that
both
boilers
are
similar
in
construction
and
design
capacity,
the
risk
burn
was
conducted
as
follows:
Boiler
3
burned
only
tall
oil
pitch
("
TOP",
designated
a
non­
hazardous
waste
fuel)
while
Boiler
2
burned
a
"
worst
case
waste"
fuel
blend
(
about
19
to
21%
hazardous
waste
fuel
blended
with
79
to
81%
tall
oil
heads).
In
order
to
ensure
a
"
reasonably
worst
case"
waste
feed
and
maintain
consistency
for
all
3
runs
of
the
risk
burn,
the
facility
developed
a
waste
fuel
blend
for
Boiler
2
consisting
of
all
available
waste
fuel
components.
Since
the
Acrylic
Hard
Resin
Spent
Solvents
(
ASO)
waste
stream
was
not
generated
during
the
six
months
preceding
the
Risk
Burn,
Westvaco
generated
a
surrogate
ASO
stream
for
the
risk
burn
testing.
This
surrogate
stream
closely
resembled
the
actual
ASO
stream,
which
mainly
consists
of
isopropanol
and/
or
dipropylene
glycol
monomethyl
ether.
The
ASO
stream
is
considered
hazardous
due
to
its
ignitability.

Prior
to
December
of
2001,
all
COC
tests
were
conducted
in
a
manner
similar
to
the
risk
burn
tests
with
only
Boiler
2
burning
hazardous
waste
components
(
the
1998
COC
documented
a
waste
feed
at
about
the
same
ratio
as
the
risk
burn,
and
at
about
the
same
mix
of
specific
waste
streams).
Conversely,
the
more
recent
COC
testing
conducted
in
December
of
2001
provided
emissions
test
data
for
Boiler
3
hazardous
waste
feed
operations.
Boiler
2
was
not
operated
during
the
December
2001
testing
event,
but
TOP
was
fed
to
Boiler
4
instead.
The
2001
COC
test
ran
a
waste
fuel
blend
of
lower
content
hazardous
waste
components
(
about
10
to
16%),
yet
included
a
portion
of
the
actual
Acrylic
Hard
Resin
Spent
Solvents
(
ASO)
waste
stream
and
an
increased
portion
of
the
HC­
920
waste
stream
(
i.
e.,
as
opposed
to
including
a
portion
of
the
Resinate
Filter
Cake
stream)
in
some
of
the
batches
fed
to
the
boiler.

During
the
COC
testing
events,
waste
feed
for
all
3
runs
of
each
event
did
not
maintain
consistency
as
was
done
in
the
Risk
Burn.
Rather,
batches
were
used
that
differed
in
available
waste
fuel
components
for
the
various
runs.
In
some
of
these
runs,
the
actual
ASO
stream
was
used
in
the
fuel
blend
as
discussed
above.
Also,
as
already
noted
for
the
December
2001
testing,
tall
oil
pitch
was
fed
to
Boiler
4
(
non­
hazardous
unit)
rather
than
operating
both
of
the
hazardous
waste
boilers
as
was
done
in
the
Risk
Burn
testing.
However,
this
operational
set­
up
is
typical
of
normal
operating
conditions
since
only
one
hazardous
waste
unit
can
be
operated
at
any
time.

The
normal
waste
fuel
feed
rate
at
the
DeRidder
facility
typically
ranges
from
27
to
30
lb/
min.
The
waste
fuel
feed
rate
during
the
risk
burn
ranged
from
33.2
to
51.0
lb/
min,
while
the
waste
fuel
feed
rate
during
the
Page
9
of
27
Table
1:
Westvaco
Data
Comparison
Common
Stack
for
Boilers
2,
3,
4
(
B2,
B3,

B4)
Average
%
of
Waste
Fed
Specific
Waste
Streams
Fed
to
Boilers
Waste
Designation
Risk
Burn
1998COC
2001COC1
Comments
Ba
1&
2
Ba
3&
4
Tall
Oil
Heads
(
TOH,
Co­
Product)
Non­
Hazardous
Waste
Fuel
81%
B2
82%
B2
90%
85%
B3
Resinate
Filter
Cake
D001
(
F005
list
dropped)
13%
B2
13%
B2
10%
0%
B3
HC­
920
Sparge
Oil
D001
3%
B2
5%
B2
0%
8%
B3
Waste
Lab
Solvents
F003,
F005,
D001
0%
B2
0%
B2
0%
0%
B3
Last
Burned
in
January
1996
Acrylic
Hard
Resin
Spent
Solvents
(
ASO)
D001
3%
B2
0%
B2
0%
7%
B3
Surrogate
used
in
RB
Test
Total
Hz
Waste
Fuel
19%
B2
18%
B2
10%
15%
B3
Low
Risk
Waste
Exemption2
Tall
Oil
Pitch
(
TOP)
Non­
Hazardous
Fuel
100%
B3
100%
B3
100%
100%
B4
B4
specs
unknown3
NOTES:

1.
2001
COC
Test
split
batches
of
different
make­
up
across
runs:
Batches
1&
2
were
used
for
Runs
1&
2;
Batches
3&
4
were
used
for
Run3.

2.
Low
Risk
Waste
Exemption
limits
HWF
to
50%;
Typical
Operations
were
identified
in
the
RBR
as
15%
with
85%
nonhazardous
TOHs.

3.
Boiler
4
is
a
non­
hazardous
waste
boiler
and
may
or
may
not
be
identical
in
construction/
operations
to
Boiler
2/
3.

However,
use
of
Boiler
4
is
more
in
line
with
actual
operations­­
with
only
one
of
the
hazardous
waste
boilers
operating
at
any
one
time.
Page
10
of
27
1998
COC
test
and
the
2001
COC
test
ranged
from
46.0
to
50.6
lb/
min.
Measurements
taken
during
the
risk
burn
and
the
1998
COC
test
demonstrated
a
stack
gas
flow
rate
of
57
cubic
meters
per
second
(
m3/
sec),
a
stack
gas
exit
velocity
of
4.22
meters
per
second
(
m/
sec),
and
an
exit
temperature
of
459
K
(
about
367oF)
for
normal
operating
conditions.
Although
measurements
taken
during
the
2001
COC
test
demonstrated
similar
stack
parameters
for
the
flow
and
exit
velocity,
the
2001
COC
test
demonstrated
a
much
lower
stack
exit
temperature
of
439
K
(
about
331oF).
LDEQ
and
EPA
provided
oversight
at
the
risk
burn
testing
in
September
of
1997
for
Boiler
2
at
the
Westvaco
facility.
LDEQ
provided
limited
oversight
at
both
COC
testing
events
in
1998
and
2001.
Due
to
the
variations
noted
for
the
2001
COC
test,
EPA
calculated
two
different
sets
of
air
modeling
parameters
and
corresponding
emission
rates
for
use
in
assessing
risks.

Air
Modeling
EPA
used
the
ISCST3
for
determining
air
dispersion
and
deposition
of
compounds
resulting
from
operations
at
the
Westvaco
facility
in
accordance
with
the
HHRAP.
EPA
evaluated
emission
sources
using
primarily
the
data
and
information
provided
in
the
Westvaco
Risk
Burn
Report
dated
September
1997,
and
the
BIF
Data
Package
dated
December
1996.
In
addition,
EPA
utilized
data
provided
in
both
the
1998
and
the
2002
Certification
of
Compliance
Test
Reports
and
supplemental
information
requested
by
EPA
and
provided
by
Westvaco
in
the
"
Fugitive
Emission
Estimating
Data
Report"
dated
October,
1998.

EPA
modeled
two
separate
emission
sources
for
Westvaco's
DeRidder
facility:
one
stack
source
(
Common
Stack)
for
the
onsite
boilers;
and
one
volume
area
source
to
account
for
fugitive
emissions
associated
with
the
waste
feed
storage
area.
EPA
evaluated
emissions
from
the
Common
Stack
for
365
days
per
year.
EPA
believes
that
this
is
a
reasonable
approximation
of
emissions
from
both
boilers
since
hazardous
waste
can
only
be
burned
in
one
hazardous
waste
boiler
at
a
time,
both
boilers
are
similar
in
design
capacity
and
construction,
burn
exactly
the
same
waste
under
identical
operating
conditions,
and
share
a
common
air
pollution
control
system.
EPA
modeled
fugitives
associated
with
ancillary
equipment
to
both
boilers.

Stack
location
and
parameters
were
provided
by
Westvaco
and
building
heights
were
taken
from
plot
plans
provided
by
Westvaco
(
No.
E38­
708­
04).
The
Universal
Transverse
Mercator
(
UTM)
projection
coordinates
in
North
American
Datum
revised
in
1983
(
NAD83)
for
each
source
are
as
follows:
for
the
Common
Stack
(
472662.9498,
3410300.8892);
and
for
fugitive
emissions
(
472652.72,
3410292.76).
EPA
ran
two
separate
air
models
due
to
a
difference
in
operating
conditions
(
i.
e.,
mainly
temperature)
noted
for
the
2001
COC
testing
versus
the
1998
COC
testing
and
the
1997
Risk
Burn.
Each
air
model
was
used
independently
to
assess
any
impact
from
dioxin/
furan
emissions
data
collected
at
the
corresponding
set
of
operating
conditions.
Differences
in
emission
rates
are
discussed
in
the
Compounds
of
Potential
Concern
(
COPC)
Section.
Results
from
the
comparative
risk
analysis
are
provided
in
the
Risk
Characterization
Section
of
this
report.

For
the
first
air
model
run
("
Risk
Burn/
1998
COC
Operating
Conditions
Run"),
EPA
used
a
stack
gas
flow
rate
of
57.57
cubic
meters
per
second
(
m3/
sec),
a
stack
gas
exit
velocity
of
4.22
meters
per
second
(
m/
sec),
and
a
stack
gas
exit
temperature
of
459
Kelvin
(
approximately
367
oF)
for
the
Common
Stack
as
input
to
ISCST3.
The
stack
height
is
76.2
meters
(
250
feet)
above
grade.
EPA
used
a
height
of
5
meters
(
assumed
midpoint
of
height
of
equipment)
and
an
area
of
approximately
3610
square
meters
(
m2)
for
evaluation
of
Page
11
of
27
fugitive
emissions.
For
the
second
air
model
run
("
2001
COC
Operating
Conditions
Run"),
EPA
used
a
stack
gas
flow
rate
of
60.52
m3/
sec,
a
stack
gas
exit
velocity
of
4.44
m/
sec,
and
a
stack
gas
exit
temperature
of
439
Kelvin
(
approximately
331
oF)
for
the
Common
Stack
as
input
to
ISCST3.
Fugitive
parameters
were
left
unchanged.

Modeling
for
Westvaco's
DeRidder
facility
was
based
upon
an
array
of
receptor
grid
nodes
at
100­
meter
spacing
out
to
a
distance
of
3
kilometers
from
the
facility
and
an
array
of
receptor
grid
nodes
at
500­
meter
spacing
between
a
distance
of
3
kilometers
and
out
to
a
distance
of
10
kilometers
from
the
facility.
Unitized
concentration
and
deposition
rates
were
determined
by
the
ISCST3
model
for
each
receptor
grid
node
for
use
in
assessing
risks.
Consistent
with
the
HHRAP,
water
body
and
watershed
air
parameter
values
were
obtained
from
the
single
receptor
grid
node
array
without
need
for
executing
values
to
a
separate
array.

Terrain
elevations
based
on
90­
meter
spaced
USGS
digital
elevation
data
were
specified
for
all
receptor
grid
nodes.
Other
site­
specific
information
used
to
complete
the
ISCST3
models
included
the
most
current
surrounding
terrain
information,
surrounding
land
use
information,
facility
building
characteristics,
and
meteorological
data
available.
Meteorological
data
collected
over
a
5­
year
period
from
representative
National
Weather
Service
(
NWS)
stations
near
the
facility
were
used
as
inputs
to
the
ISCST3
models.
The
surface
and
upper
air
data
was
collected
from
the
Lake
Charles
NWS
station.

Model
runs
were
executed
for
accurate
evaluation
of
partitioning
of
all
compounds
specific
to
vapor
phase,
particle
phase,
and
particle­
bound
phase
runs.
In
addition,
particle
diameter
size
distributions
and
mass
fractions
for
the
Common
Stack
were
based
on
Westvaco's
May
1987
particle
size
test
on
the
stack
gases
to
design
an
electrostatic
precipitator
(
ESP)
to
control
particulate
matter
emissions.
EPA
adjusted
the
particle
size
based
upon
the
ESP
graph
submitted
by
Westvaco
to
account
for
the
presence
of
the
ESP.

Appendix
A
contains
all
air
modeling
information
utilized
and
generated
for
the
Westvaco
facility.
The
files
found
in
the
"
ISC_
Original"
subdirectory
correspond
to
the
Risk
Burn/
1998
COC
Operating
Conditions
Run.
The
files
found
in
the
"
ISC_
Compare"
subdirectory
correspond
to
the
2001
COC
Operating
Conditions
Run.
Under
the
"
Source"
subdirectory,
the
Common
Stack
also
has
one
subdirectory
dedicated
to
the
Risk
Burn/
1998
COC
files
("
Common")
and
one
directory
for
the
2001
COC
files
("
Common02"
since
the
COC
testing
conducted
in
December
2001
was
documented
in
forms
dated
2002).

Compounds
of
Potential
Concern
(
COPCs)

EPA
identified
Compounds
of
Potential
Concern
(
COPCs)
in
accordance
with
the
HHRAP.
Although
the
Westvaco
facility
does
not
burn
plastics
or
materials
with
phthalate
plasticizers,
certain
phthalate
compounds
were
detected
during
various
risk
burn
runs.
Therefore,
EPA
did
not
drop
phthalate
compounds
from
the
risk
analysis.
However,
EPA
eliminated
certain
other
compounds
from
the
quantitative
risk
analysis
based
upon
availability
of
toxicity
data
and/
or
transport
and
fate
data.
Those
few
chemicals
which
were
detected,
but
dropped
from
the
risk
analysis,
are
qualitatively
discussed
in
the
Uncertainty
Section
of
this
report.
Appendix
B
contains
EPA­
calculated
COPC­
specific
emission
rates
used
in
the
risk
assessment
for
each
source,
including
the
fugitives
areas,
and
provides
justification
for
all
chemicals
dropped
from
the
risk
Page
12
of
27
analysis.
EPA
input
these
COPC­
specific
emission
rates
directly
into
the
risk
model,
which
allowed
calculation
of
compound­
specific
media
concentrations
and
corresponding
risk
estimates.

EPA
initially
evaluated
Tier
1
Feed
Rate
Limits
(
i.
e.,
maximum
allowable
regulatory
limits)
for
the
Westvaco
boilers
and
found
that
the
limits
for
several
metals
would
need
to
be
supplemented
with
lower
annual
average
limits
(
risk­
based
limits)
in
order
for
the
permit
to
be
protective
of
human
health.
In
addition,
EPA
estimated
stack
emissions
for
inorganic
compounds
from
the
waste
feed
data
reported
in
a
letter
from
the
facility
entitled
"
BIF
Risk
Assessment
Information",
dated
January
31,
1997.
This
data
was
proposed
and
accepted
as
data
in
lieu
of
risk
burn
testing
since
the
data
were
collected
during
a
1995
COC
testing
event.
A
subsequent
COC
form
on
file
for
the
Westvaco
facility,
dated
1998,
was
reviewed
in
order
to
compare
the
Tier
I
levels
with
operations
data
collected
subsequent
to
the
1995
COC
testing
event.
EPA
used
an
upset
factor
of
1
for
calculating
inorganic
compound
emission
rates
since
operation
under
Tier
I
status
means
evaluation
of
waste
feed
measurements
and
not
collection
of
actual
emissions
data
(
i.
e.,
all
of
the
metals
fed
to
the
unit
are
assumed
to
be
emitted
in
the
stack
gas).
Since
the
risk
burn
data
as
well
as
the
COC
forms
for
the
Westvaco
facility
show
that
typical
operations
result
in
emission
rates
which
are
orders
of
magnitude
below
the
maximum
allowable
regulatory
limits,
EPA
back­
calculated
risk­
based
annual
average
permit
limits
from
the
Tier
I
limit
for
each
metal
of
concern.

EPA
next
calculated
emission
rates
from
stack
emissions
data
for
organic
compounds
collected
during
the
risk
burn
conducted
between
September
9
and
12,
1997.
Dioxin
data
from
the
COC
testing
in
1995
was
originally
intended
for
use
as
data
in
lieu
of
risk
burn
testing
for
these
particular
compounds
(
similar
to
the
metals,
above
discussion).
However,
EPA
evaluated
and
utilized
the
more
recent
dioxin/
furan
emissions
data
collected
during
the
1998
COC
testing
event
since
operating
conditions
were
sufficiently
similar
to
both
the
1995
COC
and
the
1997
Risk
Burn
test
events.
Of
special
note,
an
updated
analytical
method
was
used
in
the
1998
data
collection
effort
that
provided
more
accuracy
in
reporting
of
individual
congener
results
than
was
possible
for
the
1995
data.
EPA
used
an
upset
factor
of
1.01
in
calculation
of
COPC­
specific
emission
rates
for
organic
compounds,
in
consideration
of
the
letter
report
from
the
Louisiana
Chemical
Association
(
LCA)
representing
liquid
burning
BIFs
in
the
State
of
Louisiana,
dated
October
27,
1999
(
letter
report
presents
adequate
rationale
and
example
calculation
for
the
upset
factor
of
1.01
for
organic
compounds).

Finally,
in
order
to
properly
assess
fugitive
emissions
associated
with
Westvaco
'
s
typical
operations,
EPA
evaluated
supplemental
information
provided
by
Westvaco
in
the
"
Fugitive
Emission
Estimating
Data
Report"
dated
October
15,
1998.
This
document
provided
historical
information
on
the
typical
mix
of
specific
compounds
in
the
waste
feed
and
the
engineering
details
for
equipment
in
the
areas
being
evaluated.

Upon
completion
of
EPA's
preliminary
risk
analysis,
a
subsequent
COC
test
event
was
completed
in
December
of
2001.
This
most
recent
test
was
conducted
in
a
manner
that
differed
from
the
Risk
Burn
and
historical
COC
tests
(
See
Facility
and
Source
Information
Section
of
this
Report).
Therefore,
prior
to
completing
this
risk
assessment
report,
EPA
conducted
a
comparative
evaluation
of
all
of
the
various
test
events
for
these
particular
compounds
in
order
to
account
for
differences
in
both
operating
conditions
and
data
results
between
the
risk
burn
and
1998/
1995
COC
testing
events
versus
the
2001
COC
testing
event.

As
part
of
the
comparative
evaluation,
EPA
first
assessed
the
recommended
metal
permit
limits
at
the
Page
13
of
27
corresponding
2001
COC
test
conditions
and
found
the
limits
to
still
be
protective.
Next,
EPA
calculated
the
emission
rates
of
individual
dioxin
and
furan
congeners
demonstrated
during
the
2001
COC
testing
event
and
determined
that
a
separate
risk
evaluation
was
warranted
for
dioxins
and
furans.
The
new
emission
rate
calculations
were
added
as
a
separate
table
to
the
workbook
already
containing
the
risk
burn
and
1998
COC
emission
rate
calculations
in
Appendix
B.
In
effect,
EPA
conducted
multiple
air
modeling
and
risk
modeling
efforts
to
evaluate
the
differences
and
potential
impacts
from
dioxin
and
furan
congener­
specific
emissions.
In
summary,
the
comparative
evaluation
of
emission
rates
for
dioxins
and
furans
based
upon
the
results
of
the
2001
COC
testing
event
led
EPA
to
consider
the
need
for
an
emission
rate
limit
for
dioxin/
furan
compounds
in
the
RCRA
permit.
Therefore,
EPA
back­
calculated
the
recommended
emission
rate
limit
of
4.24E­
10
grams
per
second
TCDDE
(
2,3,7,8­
tetrachlorinated
dibenzo­
p­
dioxin
equivalencies)
from
the
2001
COC
test
results
in
order
to
sufficiently
reduce
those
risks
identified
in
the
comparative
risk
evaluation
for
the
2001
COC
test
data.

In
back­
calculating
the
recommended
TCDDE
limit,
EPA
did
take
into
account
the
6­
fold
increase
in
slope
factor
for
TCDD
that
is
anticipated
in
the
near
future.
In
addition,
the
recommended
TCDDE
level
was
compared
with
the
most
stringent
dioxin
and
furan
Hazardous
Waste
Combustion
MACT
Interim
Standard
currently
promulgated
for
incinerator
systems,
cement
kilns,
and
light
weight
aggregate
kilns
(
0.2
ng/
dscm)
since
a
MACT
standard
has
not
yet
been
promulgated
for
BIF
units.
However,
the
MACT
Interim
Standards
are
concentration­
based
and
when
converted
to
a
mass
basis
for
the
Westvaco
stack,
the
TCDDE
limit
was
higher
than
the
risk­
based
limit
being
recommended
and
demonstrated
by
actual
emissions
data
collected
during
all
the
various
testing
events
(
Table
3).

In
summary,
EPA
used
the
calculated
(
or
"
recommended
risk­
based")
permit
limits
for
metals
in
the
final
risk
assessment
model
 
along
with
actual
emissions
data
for
all
the
other
COPCs
being
evaluated
 
in
order
to
show
permit
protectiveness
over
the
long
term.
Westvaco's
data
in
lieu
of
testing
show
that
feed
rates
during
"
normal
operations"
fall
below
the
recommended
permit
feed
rate
limits,
or
in
the
case
of
mercury,
can
achieve
the
limit
and
demonstrate
compliance
during
future
sampling
events
(
Table
2).
In
addition,
Westvaco's
historical
data
shows
that
dioxin
and
furan
emission
levels
achieve
the
recommended
permit
emission
rate
limit
(
Table
3).
Since
the
calculated
TCDDE
limit
is
virtually
the
same
level
as
demonstrated
during
the
1998
COC
testing,
and
the
original
risk
analysis
did
not
result
in
TCDDE
risks
above
EPA
levels
of
concern,
the
calculated
(
or
"
recommended
TCDDE")
limit
will
ensure
permit
protectiveness
over
the
long
term.
Page
14
of
27
Table
2:
Metals
Waste
Feed
Rates
(
g/
s)

Metals
of
Concern
Regulatory
Tier
I
Permit
Limit
Maximum
Allowable
Recommended
Risk­
Based
1
Permit
Limit
Annual
Average
"
Normal
Operations"
Data
in
Lieu
of
Risk
Burn
Testing
(
BIF
Data
Package
2)

Antimony
4.17E+
00
4.17E­
01
ND
3
=
1.63E­
03
Arsenic
3.33E­
02
3.33E­
02
ND
3
=
1.63E­
03
Barium
7.22E+
02
7.22E­
01
6.53E­
04
Beryllium
6.11E­
02
6.11E­
03
ND
3
=
3.25E­
04
Cadmium
8.06E­
02
1.61E­
03
ND
3
=
3.25E­
04
Chromium
(
Total)
1.19E­
02
4
1.19E­
03
4
ND
3
=
3.25E­
04
Lead
1.28E+
00
1.28E+
00
9.78E­
04
Mercury
(
Total)
4.17E+
00
2.60E­
06
5
ND
3
=
6.19E­
05
Nickel
N/
A
5.58E­
02
5.58E­
05
6
Silver
4.17E+
01
8.34E­
02
ND
3
=
3.25E­
04
Selenium
N/
A
1.39E­
03
1.39E­
06
6
Thallium
4.17E+
00
8.34E­
02
ND
3
=
1.63E­
03
NOTES:
1.
Recommended
RCRA
Permit
Limits
are
based
upon
an
annual
average
stack
gas
temperature
of
459
K
and
an
annual
average
stack
gas
flow
rate
of
58
m3/
s
as
demonstrated
during
the
risk
burn
and
alternative
COC
sampling
events.
The
recommended
limits
were
also
evaluated
at
those
conditions
demonstrated
during
the
2001
COC
testing
event
(
61
m3/
s
@
439
K)
and
found
to
still
be
protective.

2.
Metals
Emissions
Data
in
Lieu
of
Trial/
Risk
Burn
Testing
was
submitted
by
Westvaco
in
their
"
BIF
Data
Package",
dated
December
17,
1996,
Table
5.

3.
ND
means
that
the
metal
was
not
detected
in
the
waste
feed;
the
detection
limit
was
used
to
calculate
the
emission
rate
shown.

4.
Recommended
RCRA
Permit
Limit
for
Chromium
is
actually
based
upon
the
assumption
that
Hexavalent
Chromium
is
equal
to
100%
of
the
Total
Chromium
measured
in
the
waste
feed.

5.
Mercury
is
not
believed
to
be
present
in
the
waste
feed,
but
the
analytical
method
used
in
the
risk
burn
did
not
provide
low
enough
detection
limits
for
comparison
with
the
Recommended
RCRA
Permit
Limit.
The
Risk­
Based
Annual
Average
RCRA
Permit
Limit
for
mercury
is
based
upon
a
reliable
detection
limit
for
mercury
of
0.01
ppm
and
the
volumetric
flow
rate
demonstrated
during
the
Risk
Burn.

6.
Nickel
and
Selenium
were
estimated
from
fly
ash
sampling,
estimates
provided
in
the
"
BIF
Data
Package"
as
data
in
lieu
of
testing.
Page
15
of
27
Table
3:
TCDDE
Emission
Rates
(
g/
s)

Test
Conditions
MACT
Interim
Standard
1
@
Test
Conditions
Recommended
Risk­
Based
2
Permit
Limit
TCDDE
Operations
Data
3
Demonstrated
@
each
Test
Condition
December
2001
COC
Testing
(
2002
COC
Form)
7.62E­
09
g/
s
4.24E­
10
g/
s
0.07
ng/
dscm
=
4.24E­
09
g/
s
June
1998
COC
Testing
(
1998
COC
Form)
7.36E­
09
g/
s
0.01
ng/
dscm
=
4.04E­
10
g/
s
1995
COC
Testing
(
1996
BIF
Data
Package,
Table
1)
7.40E­
09
g/
s
0.21
ng/
dscm
=
7.58E­
10
g/
s
NOTES:
1.
Most
Stringent
MACT
Interim
Standard
(
i.
e.,
new
combustion
unit)
of
0.2
ng/
dscm
is
converted
to
a
mass
basis
at
each
set
of
operating
conditions.

2.
Recommended
RCRA
Permit
Limit
is
based
upon
an
annual
average
stack
gas
temperature
of
439
K
and
an
annual
average
stack
gas
flow
rate
of
61
m3/
s
as
demonstrated
during
the
2001
COC
testing
event.
This
limit
is
achievable
at
those
conditions
noted
for
the
Risk
Burn
and
1998
COC
testing
events
and
falls
close
to
the
1995
COC
Test
level,
where
an
older
analytical
method
was
used
for
reporting
of
results.

3.
TCDDE
levels
shown
are
average
values
from
3
runs
of
data
collected
per
test
condition.
A
3­
year
initial
sampling
frequency
is
recommended
in
order
to
effectively
demonstrate
compliance
with
the
Risk­
Based
Permit
Limit.
Due
to
the
long
term
nature
of
the
risk
assessment,
an
annual
average
emission
rate
value
is
not
practical.
Sampling
every
3
years
will
provide
data
for
determining
a
9
year
average
value.
If
compliance
is
demonstrated
for
the
first
nine
years,
the
sampling
frequency
may
be
lessened
to
every
5
years.
Page
16
of
27
EXPOSURE
ASSESSMENT
Exact
locations
where
people
can
potentially
be
exposed
to
contaminants
in
the
air,
surface
water,
or
soil
are
determined
by
the
grid
spacing
used
in
the
air
model
and
subsequently
imported
into
the
risk
model.
These
specific
locations
can
be
used
for
assessing
exposure
for
a
particular
type
of
receptor
based
upon
the
land
use
type
being
evaluated
(
i.
e.,
farming
or
residential).
Since
plants
or
animals
can
also
be
exposed
to
contaminants
at
these
coordinate
points,
possible
uptake
through
the
food
chain
can
be
assessed
based
upon
the
type
of
land
use
designated.

The
potential
exposure
scenarios
evaluated
in
this
risk
assessment
include
both
adult
and
child
receptors
for
the
following
land
use
types:
residential,
subsistence
farming,
and
subsistence
fishing.
In
all
cases,
EPA
used
default
values
for
receptor
specific
parameters,
as
outlined
in
the
HHRAP.
However,
for
dioxins
and
furans,
EPA
used
updated
bioaccumulation
factors
and
toxicity
equivalency
values
based
upon
the
results
of
the
External
Peer
Review
of
the
HHRAP
Guidance
(
External
Peer
Review
Meeting,
May
2000).
Please
see
the
Uncertainty
Section
of
this
risk
assessment
for
a
discussion
of
those
parameters
modified
for
specific
dioxin/
furan
cogeners.
Current
land
use
was
considered
in
determining
those
receptors
potentially
impacted
by
identified
emission
sources,
while
potential
future
land
use
was
assumed
to
be
the
same
as
current
land
use.

Study
Area
Characterization
Although
the
study
area
for
air
modeling
purposes
extends
out
approximately
10
kilometers
from
the
Common
Stack,
the
risk
assessment
evaluated
possible
exposure
based
upon
potential
receptors
located
closer
to
the
facility
where
the
reasonable
maximum
risks
to
various
types
of
receptors
might
occur.
Specifically,
discrete
land
use
areas
where
results
of
the
air
modeling
indicated
maximum
air
concentration
or
maximum
deposition
of
COPCs
might
occur
typically
fell
within
a
3
kilometer
radius
from
the
Common
Stack.
EPA
then
evaluated
multiple
locations
within
each
discrete
land
use
area
potentially
impacted,
in
accordance
with
the
HHRAP.
This
ensured
that
all
possible
receptors
were
evaluated
for
identifying
reasonable
maximum
risks
for
each
exposure
scenario
type.

Potentially
impacted
water
bodies
and
their
associated
effective
watershed
areas
were
also
evaluated
as
part
of
the
risk
assessment.
Although
DeRidder
Pond
may
not
currently
be
used
for
fishing,
EPA
evaluated
this
pond
for
fishing
consumption
based
upon
the
potential
for
fishing
to
occur.
Although
this
assumption
may
have
been
overly
conservative
for
evaluation
of
current
use,
further
evaluation
is
not
warranted
since
resulting
risks
for
the
fish
consumption
pathways
were
well
below
EPA
levels
of
concern.
Additionally,
because
DeRidder
currently
obtains
its
drinking
water
from
deep
wells
rather
than
any
surface
water
bodies
within
the
study
area,
EPA
did
not
evaluate
the
drinking
water
consumption
pathway
for
any
of
the
receptor
scenarios.

EPA
contractors
conducted
a
site
visit
to
verify
information
shown
on
digitized
land
use
land
cover
maps,
topographic
maps,
and
aerial
photographs.
EPA
also
visited
the
site
and
utilized
the
internet
to
locate
and
verify
local
schools
and
daycare
facilities
on
the
topographic
maps.
EPA
also
requested
and
obtained
input
from
LDEQ
and
facility
representatives
on
actual
land
use
designations
used.
Appendix
C
contains
the
Page
17
of
27
topographic,
land
use,
and
watershed
maps
which
show
the
specific
areas
evaluated
as
part
of
the
study
area
 
as
well
as
those
effective
watershed
areas
specific
to
this
risk
assessment.

Exposure
Scenario
Locations
The
exposure
scenario
locations
in
this
risk
assessment
were
chosen
to
be
representative
of
potential
maximally
exposed
individuals,
or
receptors,
within
each
representative
land
use
type.
Infant
potential
exposure
to
dioxins
and
furans
via
the
ingestion
of
their
mother's
breast
milk
is
evaluated
at
corresponding
adult
scenario
locations
(
i.
e.,
locations
where
the
mother
may
live).
Receptor
locations
for
a
child's
potential
exposure
to
lead
in
soil
and
air
are
the
same
as
the
various
child
scenario
locations.
Fisher
receptors
were
placed
at
residential
scenario
locations
near
each
water
body
evaluated.
All
exposure
scenario
locations
are
shown
on
those
topographic
maps
provided
in
Appendix
C,
and
are
also
provided
via
a
coordinate
list
exported
from
the
risk
model
project
file
in
Appendix
D.

Transport
and
Fate
Parameters
EPA
used
transport
and
fate
equations
presented
in
the
HHRAP
to
determine
air,
soil,
and
surface
water
COPC­
specific
concentrations.
Those
equations
which
determine
uptake
of
specific
COPCs
in
the
food
chain
(
i.
e.,
COPC
concentrations
in
fish,
pork,
milk,
eggs,
etc.)
allow
the
use
of
parameters
derived
as
either
default
values,
also
provided
in
the
HHRAP,
or
facility/
site­
specific
values,
as
available
and
appropriate.
Site­
specific
transport
and
fate
parameters
utilized
for
the
Westvaco
facility
include
universal
soil
loss
constants,
delineation
of
water
body
and
effective
watershed
areas
potentially
impacted
by
facility
sources,
water
body
depth,
and
average
annual
total
suspended
solids
concentration.

Of
special
note
is
EPA's
decision
to
use
40
years
for
the
time
of
COPCs
deposition
(
i.
e.,
facility
operational
time),
rather
than
the
100
years
recommended
by
the
HHRAP.
EPA
Region
6
considerations
in
using
40
years
as
opposed
to
100
years
include
the
following:
1)
the
longest
receptor
exposure
duration
is
40
years;
and
2)
RCRA
permit
renewals
are
required
every
10
years
so
risks
can
be
reevaluated
at
any
time
utilizing
the
most
current
transport
and
fate
information
available
at
that
time.

Site­
specific
transport
and
fate
parameters
are
provided
in
the
spreadsheet
provided
in
Appendix
B.
COPCspecific
chemical
and
physical
parameters
are
not
provided
in
this
risk
assessment
report
since
they
can
be
found
in
Appendix
A
of
the
HHRAP
and
also
in
EPA's
July
1999
Errata
to
the
HHRAP.
The
IRAP­
h
View
Version
1.7
utilizes
all
updated
information
found
in
EPA's
Errata
to
the
HHRAP.

RISK
CHARACTERIZATION
In
this
risk
assessment,
EPA
evaluated
chronic
excess
risk
estimates
for
both
direct
exposure
pathways,
or
those
pathways
where
contact
may
occur
with
a
contaminated
media
(
i.
e,
inhalation,
incidental
soil
ingestion),
and
also
indirect
pathways
(
i.
e.,
those
risks
associated
with
uptake
through
the
food
chain).
EPA
also
evaluated
the
potential
for
non­
carcinogenic
health
effects
to
occur
by
calculation
of
hazard
indices
(
HIs)
for
the
various
COPCs
identified
at
the
Westvaco
facility.
In
addition,
EPA
assessed
the
following:
1)
Page
18
of
27
potential
acute
effects
(
i.
e.,
risks
associated
with
short­
term
emissions)
from
inhalation;
2)
potential
impacts
from
possible
accumulation
of
dioxin
and
furan
compounds
in
breastmilk;
and
3)
potential
adverse
impacts
for
small
children
(
i.
e.,
children
under
6
years
old)
who
are
susceptible
to
lead
exposure
in
surface
soils
and
ambient
air.

Of
special
consideration,
and
as
indicated
in
prior
sections
of
this
report,
EPA
conducted
multiple
air
and
risk
modeling
efforts
in
order
to
evaluate
different
test
results
for
the
Westvaco
facility.
Overall,
the
final
risk
model
runs
"
Original"
and
"
Comparison"
incorporated
those
adjusted
metal
emission
rates
determined
to
be
protective
from
preliminary
risk
evaluations
on
a
"
Metals"
only
model
run
(
i.
e.,
recommended
metal
permit
limits
were
incorporated
into
the
risk
assessment
prior
to
evaluation
of
organic
emissions).
Consequentially,
final
risk
estimates
are
not
driven
by
any
of
the
metals
evaluated.
In
the
case
of
dioxins
and
furans,
the
Comparison
risk
model
run
resulted
in
elevated
emission
rates
and
consequently,
risks
exceeding
EPA's
level
of
concern.
However,
the
Original
risk
model
run
corresponding
to
test
events
prior
to
the
2001
COC
test
utilized
emission
levels
a
bit
lower
than
the
TCDDE
recommended
permit
limit.
Therefore,
the
Original
risk
model
run
demonstrates
that
dioxin
and
furan
risk
estimates
fall
below
EPA
levels
of
concern
if
the
recommended
TCDDE
limit
is
incorporated
into
the
RCRA
permit.

Although
metal
waste
feed
rate
limits
can
easily
be
incorporated
into
the
RCRA
permit,
reduction
of
dioxin
emissions
may
require
more
complex
engineering
evaluation
due
to
the
nature
of
testing
conducted
to
date
that
demonstrates
"
normal
operating
conditions"
at
the
Westvaco
facility.
Therefore,
EPA
has
tailored
the
following
risk
characterization
discussions
to
document
those
risks
that
could
potentially
occur
if
the
dioxin
emission
rate
limit
is
not
incorporated
into
the
RCRA
permit
or
if
dioxin
emissions
are
not
reduced
by
process
operational
refinements
in
some
manner
(
i.
e.,
Comparison
risk
model
run
results
are
discussed
in
addition
to
the
Original
risk
model
run
results).

In
general,
for
those
chemicals
detected
in
stack
gas
emissions
or
quantified
as
fugitive
source
emissions
at
the
Westvaco
facility,
EPA
found
that
RCRA
operations
could
potentially
pose
adverse
impacts
for
certain
receptors
evaluated.
For
those
chemicals
not
actually
detected
in
stack
gas
emissions
or
not
detected
in
the
waste
feed
analysis,
as
well
as
for
those
chemicals
detected
that
need
further
discussion
due
to
uncertainties
associated
with
resulting
risk
estimates,
please
see
the
Uncertainty
Section
of
this
report.
EPA
used
target
action
levels
identified
in
the
Region
6
Risk
Management
Addendum
­
Draft
Human
Health
Risk
Assessment
Protocol
for
Hazardous
Waste
Combustion
Facilities
(
EPA­
R6­
98­
002,
July
1998)
to
evaluate
resulting
risk
estimates.

Excess
Cancer
Risks
For
those
COPCs
detected
in
stack
gas
emissions
or
quantified
as
fugitive
source
emissions
at
the
Westvaco
facility,
chronic
excess
cancer
risk
estimates
attributed
to
both
direct
exposure
pathways
and
indirect
exposure
pathways
fell
above
EPA's
1
x
10­
5
level
of
concern
for
certain
receptors
evaluated.
This
excess
cancer
risk
was
attributable
to
dioxins
and
furans
and
certain
phthalate
compounds.

Risk
associated
with
dioxins
and
furans
emissions
during
the
2001
COC
test
were
estimated
at
3
x
10­
5
for
certain
farmer
receptors.
Although
non­
dioxin/
furan
organics
data
were
not
collected
during
the
2001
COC
Page
19
of
27
testing
event,
risk
attributable
to
phthalate
compounds
were
estimated
at
3
x
10­
5
for
farmer
receptors
based
upon
emissions
data
collected
during
the
Risk
Burn.
With
the
anticipated
six­
fold
increase
of
the
slope
factor
for
dioxins,
the
total
excess
risk
for
combustion
operations
would
then
easily
exceed
the
1
x
10­
4
level,
predominately
being
driven
by
dioxin
and
furan
emissions
data.
This
means
that
there
would
be
more
than
one
chance
in
ten
thousand
of
a
person
getting
cancer
from
possible
exposure
to
RCRA
combustion
emissions
associated
with
the
Westvaco
facility.
Conversely,
if
recommended
risk­
based
permit
limits
for
dioxins
and
furans
are
incorporated
into
the
RCRA
permit,
and
operations
are
similar
to
those
demonstrated
during
the
Risk
Burn
testing
event,
risk
estimates
attributable
to
dioxins
and
furans
drop
well
below
EPA's
1
x
10­
5
level
of
concern
 
even
in
consideration
of
the
slope
factor
change,
and
total
risk
estimates
are
reduced
significantly.
Due
to
the
uncertainties
associated
with
calculation
of
risks
from
phthalate
compounds
(
please
see
the
Uncertainty
Section
of
this
report),
EPA
contends
that
the
recommended
reduction
of
dioxin
and
furan
emission
rates
is
sufficient
for
protection
of
human
health.

Excess
cancer
risk
estimates
for
each
receptor,
delineated
by
source
and
specific
COPC,
are
provided
via
a
summary
table
exported
from
the
Original
and
Comparison
runs
of
the
risk
model
project
file,
"
copc_
risk"
in
Appendix
D.
In
addition,
excess
cancer
risk
estimates
for
each
receptor,
delineated
by
pathway,
are
provided
in
a
summary
table
exported
from
each
risk
model
project
file,
"
pathway"
in
Appendix
D.
The
next
to
last
column
of
each
table
contains
the
excess
cancer
risk
estimates.
Two
differences
between
the
Original
and
Comparison
risk
model
runs
can
be
summarized
as
follows:
1)
each
risk
model
uses
an
independent
air
model
imported
in
order
to
evaluate
the
difference
between
the
Risk
Burn
and
1995/
1998
operating
conditions;
and
2)
each
risk
model
uses
independent
dioxin/
furan
congener
emission
rates
based
upon
the
difference
in
data
results
reported
in
association
with
the
Risk
Burn
and
1995/
1998
COC
test
events
versus
the
2001
COC
test
event.

Non­
Carcinogenic
Health
Effects
For
those
COPCs
detected
in
stack
gas
emissions
or
quantified
as
fugitive
source
emissions,
the
HIs
associated
with
both
direct
and
indirect
pathways
are
all
well
below
EPA's
0.25
level
of
concern
for
all
receptors
evaluated.
This
means
that
a
person's
health
should
not
be
adversely
effected
by
possible
exposure
to
RCRA
combustion
emissions
at
the
Westvaco
facility.

The
HI
estimates
for
each
receptor,
delineated
by
source
and
specific
COPC,
are
provided
via
a
summary
table
exported
from
the
original
and
comparison
runs
of
the
risk
model
project
file,
"
copc_
risk"
in
Appendix
D.
In
addition,
HI
estimates
for
each
receptor,
delineated
by
pathway,
are
provided
in
a
summary
table
exported
from
each
risk
model
project
file,
"
pathway"
in
Appendix
D.
The
last
column
of
each
table
contains
the
HI
estimates.

Other
Risks
Acute
Hazard
Quotients
are
all
less
than
1.0
for
those
receptors
evaluated.
This
means
that
a
person's
health
should
not
be
adversely
effected
from
direct
inhalation
of
the
maximum
1­
hour
concentration
of
vapors
and/
or
particulates
associated
with
RCRA
combustion
emissions
at
the
Westvaco
facility.
An
acute
adverse
health
effect
is
defined
here
as
a
concentration
intended
to
protect
the
general
public
from
discomfort
Page
20
of
27
or
mild
adverse
health
effects
over
1
hour
of
possible
exposure.
See
the
summary
tables
exported
from
each
risk
model
project
file,
"
acute"
in
Appendix
D.

For
dioxin­
like
compounds,
calculations
show
that
projected
possible
intakes
for
babies
who
are
breastfed
are
all
below
the
average
infant
intake
target
level
of
60
pg/
kg­
day
of
2,3,7,8­
TCDD
Equivalents.
See
the
summary
table
exported
from
each
risk
model
project
file,
"
b­
milk"
in
Appendix
D.
More
detailed
information
relating
to
dioxins
and
potential
exposure
and
risk
characterization
for
dioxin
and
furan
congenrs
can
be
found
at
the
EPA
website
http://
www.
epa.
gov/
nceawww1/
dioxin.
htm
(
contains
documents
generated
as
part
of
the
Dioxin
Reassessment
Initiative).

For
lead,
calculations
show
that
projected
possible
concentrations
in
surface
soils
and
ambient
air
should
not
exceed
EPA
target
levels
of
100
mg/
kg
and
0.2
µ
g/
m3,
respectively.
This
means
that
concentrations
of
lead
predicted
to
occur
in
soils
and
ambient
air
from
RCRA
combustion
emissions
at
the
Westvaco
facility
are
at
levels
which
should
not
adversely
impact
the
health
of
children
under
the
age
of
6
years
old
(
i.
e.,
those
children
who
are
susceptible
to
health
impacts
from
lead
exposure).
See
the
summary
table
exported
from
each
risk
model
project
file,
"
lead"
in
Appendix
D.

UNCERTAINTY
DISCUSSION
Uncertainty
is
inherent
in
any
risk
assessment
process,
and
in
the
case
of
combustion
risk
assessments,
can
become
complex
in
consideration
of
the
necessary
integration
of
various
data,
process
parameters,
and
modeling
efforts
undertaken.
Uncertainties
and
limitations
of
the
risk
assessment
process
are
discussed
in
general
in
Chapter
8
of
the
HHRAP
and
in
more
detail
in
each
separate
chapter
of
the
HHRAP.
Therefore,
this
risk
assessment
will
not
reiterate
that
lengthy
discussion,
but
will
complement
it
by
addressing
specific
key
areas
of
interest
which
were
identified
during
EPA's
evaluation
of
resulting
risk
estimates
at
the
Westvaco
facility.
Some,
if
not
all,
of
these
areas
of
interest
have
been
identified
by
other
EPA
regions
and/
or
State
partners
conducting
risk
assessments
at
similar
combustion
facilities
across
the
country.

Modified
Parameters
for
Dioxins/
Furans
Please
see
the
"
Modified
Parameters"
file
in
Appendix
D
for
an
all­
inclusive
parameter
list
of
chemicalspecific
values
used
in
this
human
health
risk
assessment
(
i.
e.,
a
side­
by­
side
comparison
of
the
modified
value
versus
the
original
default
value
for
each
COPC­
specific
parameter).
For
the
Westvaco
facility,
the
only
compounds
where
chemical­
specific
values
were
modified
include
individual
dioxin/
furan
cogeners.
Modifications
are
based
upon
input
from
the
External
Peer
Review
of
EPA's
HHRAP
and
Errata
(
External
Peer
Review
Meeting,
May
2000).

In
determining
the
bioaccumulation
factors
for
chickens
(
Ba
chicken)
and
eggs
(
Ba
egg),
as
published
in
the
July
1999
Errata
to
the
HHRAP,
EPA
assumed
that
the
bioconcentration
factors
(
BCFs)
presented
in
the
1995
Stephens,
Petreas,
and
Hayward
paper
were
calculated
as
the
ratio
of
the
dioxin/
furan
concentration
in
tissue
to
the
concentration
in
soil.
However,
the
BCFs
were
actually
calculated
as
the
ratio
of
dioxin/
furan
concentration
in
tissue
to
the
concentration
in
feed.
Therefore,
since
the
soil/
feed
mixture
fed
to
the
chickens
Page
21
of
27
was
one
part
soil
and
nine
parts
feed
(
1:
9),
the
bioaccumulation
factors
presented
in
the
Errata
would
appear
to
be
ten­
fold
too
high.
Therefore,
EPA
reduced
the
Ba
chicken
and
BA
egg
values
provided
in
the
Errata
by
a
factor
of
10
for
those
cogeners
evaluated
(
"
Biotransfer
and
Bioaccumulation
of
Dioxins
and
Furans
from
Soil:
Chickens
as
a
Model
for
Foraging
Animals";
Stephens,
Petreas,
and
Hayward,
1995).

Additionally,
since
publication
of
the
July
1999
Errata
to
the
HHRAP,
EPA's
Office
of
Solid
Waste
has
recommended
use
of
the
1997
World
Health
Organization
(
WHO,
1997)
Toxicity
Equivalency
Factors
(
TEFs)
for
dioxin/
furan
cogeners.
Therefore,
EPA
Region
6
changed
appropriately
those
three
cogeners
where
TEFs
specified
in
the
HHRAP
were
different
than
the
WHO
values
recommended
for
human
health
risk
assessments
(
i.
e.,
1997
WHO
TEFs
for
fish,
mammals,
and
birds).

Comparison
Risk
Model
Evaluation
for
Dioxins/
Furans
As
discussed
in
the
Facility
and
Source
Information
Section,
many
different
factors
may
have
contributed
to
the
elevated
emission
levels
of
dioxin
and
furan
congeners
during
the
2001
COC
testing
event.
Both
the
Original
and
Comparison
air
models
and
risk
models
were
identical,
with
exception
of
the
changes
to
stack
parameters
and
emission
rates
as
outlined
in
appropriate
sections
of
this
report.
Given
the
particular
uncertainty
associated
with
the
source
of
elevated
emissions
of
dioxins
and
furans
during
the
2001
COC
testing
event,
EPA
took
a
conservative
approach
in
calculating
the
risk­
based
TCDDE
permit
limit.
If
the
recommended
risk­
based
permit
limit
for
dioxins
and
furans
are
not
incorporated
into
the
RCRA
permit,
and
operations
are
similar
to
those
demonstrated
during
the
2001
COC
testing
event,
risk
estimates
attributable
to
dioxins
and
furan
congeners
exceed
EPA's
level
of
concern
by
a
factor
of
about
3.
However,
if
the
slope
factor
for
dioxin
is
increased
by
a
factor
of
6
(
i.
e.,
anticipated
change
within
the
next
year
for
this
group
of
COPCs),
risk
estimates
would
increase
proportionally
and
the
end
result
would
be
risks
above
the
one
in
ten
thousand
level
(
1
x
10­
4).
Therefore,
EPA
decreased
the
value
demonstrated
during
the
2001
COC
by
one
order
of
magnitude.
The
calculated
value
is
slightly
higher
than
the
level
demonstrated
in
the
company's
1998
COC.
Thus,
even
given
the
uncertainties
discussed
above,
the
company
should
be
able
to
determine
the
source
of
dioxin
and
furan
emissions
and
be
able
to
maintain
those
levels
demonstrated
in
the
1998
COC
 
thereby
complying
with
the
recommended
permit
limit
quite
easily.

Bio­
Transfer
Factors
In
completing
the
evaluation
of
risk
estimates
for
the
Westvaco
facility,
EPA
has
noted
that
biotransfer
factors
are
primarily
responsible
for
artificially
high
risk
estimates
for
certain
compounds.
Two
types
of
compounds,
polycyclic
aromatic
hydrocarbons
(
PAH)
and
phthalates,
were
identified
for
further
evaluation
when
resulting
risk
estimates
seemed
disproportionate
for
the
low
level
emission
rates
(
e.
g.,
rates
based
upon
non­
detected
levels
for
the
PAHs)
used
in
the
Westvaco
risk
assessment:

indeno(
1,2,3­
cd)
pyrene
and
dibenz(
a,
h)
anthracene,
di­
n­
octylphthalate
Cumulative
risk
estimates
for
the
two
PAH
compounds
fell
just
above
EPA's
1E­
5
level
of
concern
for
evaluation
of
carcinogenic
risks
for
certain
farmer
receptors.
In
a
similar
trend,
although
di­
n­
octylphthalate
Page
22
of
27
was
detected
in
only
one
of
three
runs,
and
even
though
the
emission
rate
was
similar
to
that
of
other
phthalate
compounds
measured
during
the
risk
burn,
excessive
hazard
quotients
resulted
for
both
adult
and
child
farmer
receptors.

The
farmer
scenario
uses
beef,
pork,
and
milk
biotransfer
factors
based
upon
the
n­
octanol/
water
partition
coefficient
(
K
ow),
as
specified
in
the
HHRAP.
However,
the
HHRAP
also
provides
discussion
about
the
possibility
of
decreasing
(
rather
than
increasing)
biotransfer
values
with
increasing
K
ow
values.
The
two
PAH
compounds
in
question
and
di­
n­
octylphthalate
all
fall
within
the
range
cited
(
log
K
ow
between
6.5
and
8.0).
The
HHRAP
suggests
that
this
trend
may
be
due
to
a
greater
rate
of
metabolism
of
higher
K
ow
compounds
(
HHRAP,
Volume
2,
Appendix
A
pages
A­
3­
25
thru
A­
3­
26).
In
addition,
other
literature
sources
acknowledge
that
PAHs
(
Gorelova
and
Cherepanova,
1970;
Gorelova
et
al.,
1970)
and
phthalates
(
ATSDR,
1987;
U.
S.
EPA,
1995)
with
large
K
ow
values
are
readily
metabolized
by
the
mixed
function
oxidase
metabolic
pathway
in
mammals
to
water­
soluble
substances,
which
are
then
excreted.
Therefore,
the
resulting
risk
estimates
for
these
two
PAHs
and
di­
n­
octylphthalate
may
be
biased
high.
In
fact,
the
EPA
Office
of
Research
and
Development
has
currently
estimated
that
the
metabolism
factor
for
di­
noctylphthalate
may
be
overestimated
by
at
least
a
factor
of
100.
With
this
consideration,
the
risk
estimates
attributable
to
this
compound
are
consequently
overestimated
by
a
factor
of
100.
In
other
words,
EPA
believes
that
the
potential
risk
from
exposure
to
these
three
compounds
is
not
of
concern
since
they
tend
not
to
bioaccumulate
in
animal
or
human
tissue,
but
rather
to
be
metabolized
and
excreted.

Use
of
Non­
Detected
Compounds
Compounds
which
were
quantified
as
not
present
at
or
above
a
laboratory
specified
reporting
limit
but
could
possibly
be
formed
as
products
of
incomplete
combustion,
were
used
in
calculation
of
risk
estimates.
For
example,
PAHs
are
semi­
volatile
compounds
typically
associated
with
combustion
sources.
Therefore,
EPA
retained
and
considered
these
compounds
in
the
risk
assessment
in
accordance
with
the
HHRAP
even
though
they
were
not
detected
in
any
of
the
analyses
conducted.

Additionally,
EPA
followed
the
HHRAP
in
determining
the
appropriate
detection
limits
to
use
in
estimating
emission
rates
for
non­
detected
compounds.
However,
since
the
HHRAP
does
not
address
the
appropriate
detection
limit
for
waste
feed
samples,
EPA
used
Sample
Quantitation
Limits
(
SQLs)
to
calculate
emission
rates
for
non­
detected
compounds,
as
reported
by
the
laboratory.
Conceptually,
SQLs
are
the
most
appropriate
detection
limit
to
use
for
waste
matrices
where
compounds
are
suspected
to
be
present
but
interferences
may
occur
to
obscure
the
detection
of
certain
compounds
as
presented
in
EPA's
Guidance
for
Data
Useability
in
Risk
Assessment
(
Publication
9285.7­
090A;
April
1992).

Although
using
non­
detected
compounds
may
tend
to
overestimate
risks
to
some
degree,
all
compounds
which
were
retained
in
the
Westvaco
risk
assessment
resulted
in
risk
estimates
well
below
EPA
levels
of
concern
with
the
exception
of
two
PAH
compounds.
The
same
two
PAH
compounds
discussed
in
the
prior
section
were
not
detected
in
stack
emissions,
but
were
assumed
to
be
present
at
their
Reliable
Detection
Level
(
RDL).
In
other
words,
in
addition
to
risk
estimates
for
these
two
compounds
being
biased
high
due
to
use
of
biotransfer
factors
which
do
not
account
for
metabolization,
the
risk
estimates
may
also
be
biased
high
due
to
use
of
emission
rates
based
upon
non­
detected
values.
Therefore,
EPA
believes
that
these
two
PAH
Page
23
of
27
compounds
do
not
actually
pose
adverse
health
impacts
 
even
assuming
the
compounds
are
present
at
their
RDLs.

Compounds
Dropped
from
Quantitative
Analysis
Of
those
compounds
dropped
from
the
risk
analysis
due
to
a
lack
of
toxicity
or
transport
and
fate
information,
only
the
following
chemicals
were
actually
detected
in
the
emissions
data:

bromobenzene,
n­
propylbenzene,
1,2,4­
trimethylbenzene,
sec­
butylbenzene,
p­
cymene,
and
n­
butylbenzene
All
of
these
compounds
are
volatile
organic
compounds.
Bromobenzene
was
detected
only
in
one
tenax
portion
of
the
train
for
one
particular
run.
The
other
compounds
were
detected
in
multiple
portions
of
the
train
for
each
run
or
multiple
runs.
Since
these
compounds
do
not
have
toxicity
data
and/
or
transport
and
fate
information,
they
can
not
be
quantitatively
evaluated
in
the
risk
assessment.
However,
EPA
did
examine
the
data
for
each
of
these
chemicals
in
relation
to
their
corresponding
Region
6
"
Risk­
Based
Screening
Level"
benchmark
values
as
available
for
Ambient
Air,
Residential
Scenario
(
please
see
EPA's
website
http://
www.
epa.
gov/
earth1r6/
6pd/
rcra_
c/
pd­
n/
screen.
htm
for
more
information
on
the
benchmark
values).
Although
p­
cymene
does
not
have
a
benchmark
value,
it
is
similar
in
chemical
structure
to
benzene,
which
does
have
a
benchmark
value
for
qualitative
comparison.
All
of
the
detected
values
were
well
below
the
corresponding
screening
level
values,
which
would
indicate
that
further
evaluation
of
risk
is
unnecessary
based
upon
the
low
levels
emitted.

Unidentified
Organic
Compounds
Westvaco
conducted
Total
Organic
Emissions
(
TOE)
testing
in
accordance
with
the
HHRAP.
Permitting
authorities
need
this
information
to
address
concerns
about
the
unknown
fraction
of
organic
emissions
from
combustion
units.
Using
the
TOE
test
results,
and
the
speciated
data
from
the
Risk
Burn,
EPA
calculated
a
TOE
factor
which
falls
at
the
low
end
of
the
range
anticipated
in
the
HHRAP
(
2
­
40).
Based
upon
these
results,
and
the
process
information
available
for
the
Westvaco
facility,
EPA
believes
that
unidentified
organic
compounds
do
not
contribute
significantly
to
those
risk
estimates
calculated
in
this
risk
assessment.

CONCLUSION
&
RECOMMENDATIONS
EPA's
risk
assessment
indicates
that
"
normal
operations"
of
the
BIF
units
at
the
Westvaco
facility
should
not
adversely
impact
human
health,
with
incorporation
of
recommended
risk­
based
permit
limits
and/
or
operating
limits.
Overall,
EPA's
risk
assessment
shows
that
the
appropriate
regulatory
maximum
permit
limits
(
i.
e.,
Tier
1
Waste
Feed
Limits)
for
the
Westvaco
hazardous
waste
combustion
units
should
be
supplemented
with
lower
annual
average
risk­
based
waste
feed
limits
for
metals
as
well
as
a
dioxin/
furan
emission
rate
limit
(
i.
e.,
TCDDE
Recommended
Limit)
in
order
for
the
permit
to
be
protective
of
human
health.
A
summary
of
the
recommended
permit
limits
is
provided
in
the
Table
4
below:
Page
24
of
27
Table
4:
Recommended
Risk­
Based
1
Permit
Limits
COPCs
Waste
Feed
Rates
(
g/
s)
Emission
Rates
(
g/
s)

Antimony
4.17E­
01
NA
Arsenic
3.33E­
02
NA
Barium
7.22E­
01
NA
Beryllium
6.11E­
03
NA
Cadmium
1.61E­
03
NA
Chromium
(
Total)
1.19E­
03
2
NA
Lead
1.28E+
00
NA
Mercury
(
Total)
2.60E­
06
3
NA
Nickel
5.58E­
02
NA
Silver
8.34E­
02
NA
Selenium
1.39E­
03
NA
Thallium
8.34E­
02
NA
TCDDE
4
(
Dioxins
&
Furans)
NA
4.24E­
10
NOTES:
1.
Recommended
RCRA
Permit
Limits
are
based
upon
an
annual
average
stack
gas
temperature
of
459
K
and
an
annual
average
stack
gas
flow
rate
of
58
m3/
s
as
demonstrated
during
the
risk
burn
and
alternative
COC
sampling
events.
The
recommended
limits
were
also
evaluated
at
those
conditions
demonstrated
during
the
2001
COC
testing
event
(
61
m3/
s
@
439
K)
and
found
to
still
be
protective.

2.
Recommended
RCRA
Permit
Limit
for
Chromium
is
actually
based
upon
the
assumption
that
Hexavalent
Chromium
is
equal
to
100%
of
the
Total
Chromium
measured
in
the
waste
feed.

3.
Mercury
is
not
believed
to
be
present
in
the
waste
feed,
but
the
analytical
method
used
in
the
risk
burn
did
not
provide
low
enough
detection
limits
for
comparison
with
the
Recommended
RCRA
Permit
Limit.
The
Risk­
Based
Annual
Average
RCRA
Permit
Limit
for
mercury
is
based
upon
a
reliable
detection
limit
for
mercury
of
0.01
ppm
and
the
volumetric
flow
rate
demonstrated
during
the
Risk
Burn.

4.
TCDDE
refers
to
2,3,7,8­
tetrachlorinated
dibenzo­
p­
dioxin
equivalencies
and
is
based
upon
the
assumption
that
the
mix
of
individual
congeners
will
not
change.
A
3­
year
initial
sampling
frequency
is
recommended
in
order
to
effectively
demonstrate
compliance
with
the
Risk­
Based
Permit
Limit.
Due
to
the
long
term
nature
of
the
risk
assessment,
an
annual
average
emission
rate
value
is
not
practical.
Sampling
every
3
years
will
provide
data
for
determining
a
9
year
average
value.
If
compliance
is
demonstrated
for
the
first
nine
years,
the
sampling
frequency
may
be
lessened
to
every
5
years.
Page
25
of
27
The
recommended
TCDDE
level
was
compared
with
the
Hazardous
Waste
Combustion
MACT
Interim
Standards
currently
promulgated
for
incinerator
systems,
cement
kilns,
and
light
weight
aggregate
kilns
since
a
MACT
standard
has
not
yet
been
promulgated
for
BIF
units.
However,
the
MACT
Interim
Standards
are
concentration­
based
and
when
converted
to
a
mass
basis
for
Westvaco's
operations,
even
the
most
stringent
standard
currently
in
place
was
higher
than
the
risk­
based
limit
being
recommended
and
demonstrated
by
actual
emissions
data
collected
during
all
the
various
testing
events.

EPA
evaluated
the
most
current
information
available
to
estimate
potential
impacts
to
human
health,
both
directly
via
inhalation,
incidental
soil
ingestion,
and
indirectly
via
modeled
deposition
and
uptake
through
the
food
chain.
Emissions
data
collected
as
part
of
the
risk
burn,
operational
data
specific
to
the
Westvaco
facility,
and
site­
specific
information
based
upon
the
facility's
location,
were
evaluated
and
considered
in
making
assumptions
and
in
predicting
risks
associated
with
long
term
operations.
The
risk
estimates
provided
in
this
risk
assessment
are
conservative
in
nature
and
represent
possible
future
risks,
based
upon
those
operating
conditions
evaluated
for
issuance
of
a
final
RCRA
combustion
permit.
If
operations
change
significantly,
or
land
use
changes
occur
which
would
result
in
more
frequent
potential
exposure
to
receptors,
risks
from
facility
operations
may
need
to
be
reevaluated.
Page
26
of
27
REFERENCES
1.
Human
Health
Risk
Assessment
Protocol
for
Hazardous
Waste
Combustion
Facilities,
Peer
Review
Draft
(
EPA530­
D­
98­
001
A,
B,
and
C;
July
1998);
Errata
to
the
HHRAP
(
EPA,
July
1999).

2.
Guidance
on
Collection
of
Emissions
Data
to
Support
Site­
Specific
Risk
Assessments
at
Hazardous
Waste
Combustion
Facilities,
Peer
Review
Draft
(
EPA530­
D­
98­
002;
August
1998).

3.
Risk
Burn
Report
for
Westvaco
Corporation
(
February
1998).

4.
BIF
Data
Package
for
Westvaco
Corporation
(
December
1996).

5.
"
Fugitive
Emission
Estimating
Data
Report"
for
Westvaco
Corporation
(
October
1998).

6.
Certificates
Of
Compliance
for
the
Westvaco
facility
(
1987,
1995,
1998,
2002).

7.
Louisiana
Chemical
Association
(
LCA)
Letter
Report
on
Upset
Factors
(
October
27,
1999).

8.
External
Peer
Review
Meeting,
HHRAP
and
Errata.
(
TechLaw,
Inc.;
Dallas,
Texas;
May
2000).

9.
Region
6
Risk
Management
Addendum
­
Draft
Human
Health
Risk
Assessment
Protocol
for
Hazardous
Waste
Combustion
Facilities
(
EPA­
R6­
98­
002,
July
1998).

10.
Biotransfer
and
Bioaccumulation
of
Dioxins
and
Furans
from
Soil:
Chickens
as
a
Model
for
Foraging
Animals
(
Stephens,
Petreas,
and
Hayward,
1995).

11.
World
Health
Organization
(
WHO)
Meeting
on
the
Derivation
of
Toxicity
Equivalency
Factors
(
TEFs)
for
PCBs,
PCDDs,
PCDFs,
and
other
Dioxin­
like
Compounds
for
Human
Health
&
Wildlife,
June
15
­
18,
1997.
Institute
of
Environmental
Medicene,
Karolinska
Institute,
Stockholm,
Sweden.
Draft
Report
dated
July
30,
1997.

12.
Federal
Register,
40
CFR
Parts
148,
261,
266,
etc.
Hazardous
Waste
Management
System;
Identification
and
Listing
of
Hazardous
Waste;
et
al.;
Final
Rule
and
Proposed
Rule;
Thursday,
August
6,
1998
(
Bioavailability
and
Bioaccumulation,
pages
42148
­
42149).

13.
On
the
Possibility
of
Accumulation
of
3,4­
Benzpyrene
in
Tissues
and
Organs
of
Cows
and
Calves,
As
Well
as
in
Milk
in
Case
of
Presence
of
This
Carcinogen
in
Fodder
(
Gorelova
and
Cherepanova;
The
N.
N.
Petrov
Research
Institute
of
Oncology
of
the
USSR
Ministry
of
Public
Health,
Leningrad;
1970).

14.
Correlation
Between
The
Content
of
Polycyclic
Carcinogens
in
Animal
Food
Products
and
In
Fodder
for
Farm
Animals
(
Gorelova,
Dikun,
Dmitrochenko,
Krasnitskaya,
Cherepanova,
and
Page
27
of
27
Shendrikova;
The
N.
N.
Petrov
Research
Institute
of
Oncology
of
the
USSR
Ministry
of
Public
Health,
Leningrad;
1970).

15.
EPA
Region
6
Human
Health
Medium
Specific
Screening
Levels
(
EPA
November
2001).

16.
Guidance
for
Data
Useability
in
Risk
Assessment
(
Part
A)
Final
(
EPA
9285.7­
09A,
April
1992).
