U.
S.
Environmental
Protection
Agency
Draft,
September
16,
2003
PFOA
ECA
Telomer
Technical
Workgroup
Revised
Tentative
Agenda
Tuesday,
September
16,
2003
9:
00
AM
to
4:
00
PM
EDT
U.
S.
Environmental
Protection
Agency
East
Building,
Room
1133
1201
Constitution
Avenue,
NW
Washington,
DC
20460
S
Welcome
and
Introductions
 
EPA
Data
Needs
Review
 
Chemical
Selection
Criteria
Presentation
 
Fire
Fighting
Foam
Presentation
S
Telomer
Degradation
Technical
Expert
Subgroup
Progress
Report
and
Discussion
S
EPA
Presentation
S
TRP
Presentation
S
Discussion
S
Telomer
Incineration
Technical
Expert
Subgroup
Progress
Report
and
Discussion
S
Next
Steps
S
Adjourn
RECEIVED
OPPT
NCIC
2003
September
24
4:
34
PM
OPPT­
2003­
0012­
0198
U.
S.
Environmental
Protection
Agency
Draft,
September
15,
2003
Anticipated
Attendees
for
PFOA
ECA
Technical
Workgroup
Meetings
September
16­
18,
2003
Name
Affiliation
Aller,
Linda
Bennett
&
Williams
Altman,
Bobbie
Clariant
Baillie,
Richard
W.
L.
Gore
Begley,
Tim
U.
S.
Food
and
Drug
Administration
Beers,
A.
W.
(
Bill)
OMNOVA
Solutions
Berti,
Bill
DuPont
Biles,
Blake
Arnold
&
Porter
(
Clariant)
Bilott,
Rob
WV
Class
Action
Plaintiffs
Bittner,
Patte
Consumer
Product
Safety
Commission
Buck,
Robert
DuPont
Buxton,
Bill
DuPont
Campbell,
Lisa
Bergeson
&
Campbell
(
W.
L.
Gore)
Cardona,
Mike
DuPont
Cortina,
Tom
Fire
Fighting
Foam
Coalition
Cuthriell,
Bob
Environmental
Health
Research
Foundation
DiPasquale,
Tom
3M
Duncan,
Don
Society
of
the
Plastics
Industry
Emmet,
Edward
University
of
Pennsylvania
Medical
Center
Gannon,
John
DuPont
Girard,
Robert
DuPont
Greenwood,
Mark
Ropes
&
Gray
(
Daikin)
Griffin,
Bob
Little
Hocking
Water
Association
Harris,
Lynne
Society
of
the
Plastics
Industry
Hatcher,
Julie
Latham
&
Watkins
(
3M)
Honigfort,
Paul
U.
S.
Food
and
Drug
Administration
Houlihan,
Jane
Environmental
Working
Group
Jung,
Reinhard
Clariant
Klein,
Jennifer
Environmental
Working
Group
Knight,
Frances
Ciba
Specialty
Chemicals
Koch,
Volker
Clariant
Komatsu,
Satoshi
Daikin
Korzeniowski,
Stephen
DuPont
Kubo,
Takaharu
Daikin
Kusumi,
Kayo
Daikin
Lampert,
Edward
Daikin
Mabon,
Jim
Asahi
Glass
Malinowski,
Andrea
DuPont
McCabe,
W.
Michael
Consultant
(
DuPont)
Menotti,
David
Shaw
Pittman
(
Asahi)
Millet,
George
Dyneon
(
3M)
U.
S.
Environmental
Protection
Agency
Draft,
September
15,
2003
2
Name
Affiliation
Misa,
Noel
Asahi
Glass
Fluoropolymers
Nishiyama,
Yukiko
Daikin
Norman,
Caffey
Patton
Boggs
(
FFFC
Counsel)
Onishi,
Keiichi
Asahi
Glass
Panke,
Hans­
Ludwig
Clariant
Parr,
Michael
DuPont
Phibbs,
Pat
BNA
Poole,
Donald
Tuppers
Plains­
Chester
Water
District
Ritchie,
Bob
DuPont
Rurak,
David
DuPont
Russell,
Erin
Clariant
Santoro,
Mike
3M
Shin­
ya,
Seiji
Asahi
Glass
Shinohara,
Motoki
Asahi
Glass
Shomper,
Diane
DuPont
Smythe,
Katie
Rand
(
TRP)
Stennes,
Libretta
Steptoe
&
Johnson
(
DuPont)
Sussman,
Bob
Latham
&
Watkins
(
3M)
Thayre,
Kris
Environmental
Working
Group
Thomas,
Treye
Consumer
Product
Safety
Commission
Toner,
Pat
Environmental
Health
Research
Foundation
Webb,
Clif
DuPont
Weidman,
Allen
Society
of
the
Plastics
Industry
Wernke,
Michael
BBL
(
Clariant)
Wiedow,
Al
Ciba
Specialty
Chemicals
Williams,
Steve
Ohio
EPA
Zuckerman,
Diana
National
Center
for
Policy
Research
for
Women
&
Families
U.
S.
Environmental
Protection
Agency
Personnel
Blouin,
John
Boethling,
Bob
Collette,
Tim
Coutlakis,
Anna
Dominiak,
Mary
Farren,
Brigitte
Fehrenbacher,
Cathy
Flessner,
Conrad
Fritz,
Greg
Guo,
Zhishi
Heithmar,
Ed
Highsmith,
Ross
Hoffman,
Wendy
Leczynski,
Barbara
Leukroth,
Rich
Lewis,
Harry
Libelo,
Laurence
Lynch,
David
Mamantov,
Andy
Nguyen,
Nhan
Oshida,
Phil
Penberthy,
Ward
Pennington,
Tracey
(
EPA
Contractor)
Srinivasan,
Gautam
Stewart,
Eric
Utterback,
Dennis
Weber,
Eric
Weber,
Mary
Ellen
PFOA
ECA
Telomer
Technical
Workgroup
Meeting
September
16,
2003
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ECA
Telomer
Technical
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September
16,
2003
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ECA
Telomer
Technical
Workgroup
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September
16,
2003
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PFOA
ECA
Telomer
Technical
Workgroup
Meeting
_________________
September
16,
2003
`
St
U.
S.
Environmental
Protection
Agency
Telomer
Summary
Table
Draft,
September
15,
2003
Table
I.
EPA
Data
Needs:
Telomers
Item
EPA
Data
Need:

Telomers
Test
Substances
LOI
Commitment/
Chemical/

Data
EPA
Proposal
to
Address
Data
Needs
Not
Included
in
LOI
or
Proposed
ECA
1.
*
Comprehensive
telomer
market
information:

CAS
numbers
Chemical
names
Syn
sequences
Production/
import
volumes
Uses/
applications
All
telomers
and
polymers
made
from
telomers.
Information
to
be
provided.

Near
completion
None
U.
S.
Environmental
Protection
Agency
Telomer
Summary
Table
Draft,
September
15,
2003
Item
EPA
Data
Need:

Telomers
Test
Substances
LOI
Commitment/
Chemical/

Data
EPA
Proposal
to
Address
Data
Needs
Not
Included
in
LOI
or
Proposed
ECA
2
2.
P­
chem
properties
to
inform
fate
testing.

This
information
should
be
obtained
prior
to
fate
testing
of
representative
test
substances.
Unnecessary
for
certain
polymeric
materials
Examples:

telomer
iodides
telomer
alcohols
telomer
esters
of
(
meth)
acrylates
telomer
sulfonates
and
other
nonpolymeric
materials
Telomer
8­
2
alcohol
Water
solubility
Vapor
Pressure
UV/
visible
absorption
Hydrolysis
as
a
function
of
pH
Adsorption­
Desorption
(
soil,

sediment,
sludge
nonlabelled
and
14C)

Specific
gravity
TRP
commitments
beyond
LOI
:
Activated
Sludge
Adsorption
of
Telomer­
based
Polymer(
s)

Specific
substances
to
be
determined
The
following,
as
appropriate:

*
Water
solubility
OECD
105
*
Vapor
pressure
OECD
104
*
Soil
and
sludge
adsorption/

desorption
isotherm
OPPTS
835.1220
*
UV/
visible
absorption
OPPTS
830.7050
*
Hydrolysis
as
a
function
of
pH
OPPTS
835.2130
Representative
test
substances
to
be
determined.
U.
S.
Environmental
Protection
Agency
Telomer
Summary
Table
Draft,
September
15,
2003
Item
EPA
Data
Need:

Telomers
Test
Substances
LOI
Commitment/
Chemical/

Data
EPA
Proposal
to
Address
Data
Needs
Not
Included
in
LOI
or
Proposed
ECA
3
3.
Elucidation
of
degradation
pathways
and
identification
of
degradation
products
Telomer
products
will
be
specified,
and
should
be
individual
representative
test
substances
with
appropriate
chain
lengths
representative
of
desired
product
information,
and
different
classes
of
telomer­
based
polymers
such
as
polyethers,
polyurethanes,
and
polyacrylates.

The
choice
of
testing
material
should
be
based
on
structure,

production
volume,

use,
and
environmental
exposures.
Telomer
8­
2
alcohol
Only
PFOA
degradation
product
will
be
identified
OECD
301D
Closed
Bottle
Test
(
Ready
Biodeg)

nonlabelled
and
14C
Hydrolysis
as
a
function
of
pH
Atmospheric
Degradation
Long
Range
Transport
Properties
(
Air/
Water)

Telomer
8­
2
alcohol
and
12
representative
polymer
products
*
Inherent
Biodegradability
Zahn­
Wellens/
EMPA
OECD
To
be
discussed
in
Degradation
Subgroup
report
U.
S.
Environmental
Protection
Agency
Telomer
Summary
Table
Draft,
September
15,
2003
Item
EPA
Data
Need:

Telomers
Test
Substances
LOI
Commitment/
Chemical/

Data
EPA
Proposal
to
Address
Data
Needs
Not
Included
in
LOI
or
Proposed
ECA
4
4.
Determination
of
pchem
fate
and
transport
properties
of
major
degradation
products
Synthesis
and
testing
of
standards
for
known
degradants
(
e.
g.,

Rf
 
acetate
and
Rfacrylate
Not
Included
For
known
degradants
as
determined
in
item
3
P­
Chem
properties/
Fate/
Transport
in
2
above
and
Determination
of
air/
water
partition
coefficient/
Henry's
Law
Constant
(
method
to
be
determined).

UV/
visible
absorption
OPPTS
830.7050.

Direct
Photolysis
in
Water
OPPTS
835.2210.

Indirect
Photolysis
Screening
Test
OPPTS
835.5270.
U.
S.
Environmental
Protection
Agency
Telomer
Summary
Table
Draft,
September
15,
2003
Item
EPA
Data
Need:

Telomers
Test
Substances
LOI
Commitment/
Chemical/

Data
EPA
Proposal
to
Address
Data
Needs
Not
Included
in
LOI
or
Proposed
ECA
5
5.
Determination
of
incineration
byproducts
of
telomers
and
telomer
treated
products
and
articles
Representative
telomers
and
telomer
treated
products
and
articles
(
paper,
textile
and
carpet
products,

fire
fighting
foams)

from
manufacturers
and
importers
Not
Included
TRP
commitments
beyond
LOI
to
be
discussed
in
Incineration
Subgroup
report.
To
be
discussed
in
Incineration
Subgroup
report.

6.
Determination
of
pchem
fate
and
transport
properties
of
incineration
byproducts
Representative
telomer
incineration
byproducts
(
direct
release
of
PFAC
/
Rf
acetate)
Not
Included
To
be
determined
based
on
incineration
test
results.
U.
S.
Environmental
Protection
Agency
Telomer
Summary
Table
Draft,
September
15,
2003
Item
EPA
Data
Need:

Telomers
Test
Substances
LOI
Commitment/
Chemical/

Data
EPA
Proposal
to
Address
Data
Needs
Not
Included
in
LOI
or
Proposed
ECA
6
7.
*
Presence/
quantification
of
PFOA,
telomer
alcohol
or
other
PFOA
precursors
in
telomer
chemical
products
Representative
telomers
from
manufacturers
and
importers
TRP
plan
will
test
for
PFOA
and
telomer
8­
2
alcohol
in
12
polymers
representing
three
major
end­
use
categories:

carpet,
textiles,
and
paper.

No
TRP
commitments
beyond
LOI
More
information/
clarification
needed
from
TRP
U.
S.
Environmental
Protection
Agency
Telomer
Summary
Table
Draft,
September
15,
2003
Item
EPA
Data
Need:

Telomers
Test
Substances
LOI
Commitment/
Chemical/

Data
EPA
Proposal
to
Address
Data
Needs
Not
Included
in
LOI
or
Proposed
ECA
7
8.
*
Presence/

quantification
of
PFOA,

telomer
alcohol
or
other
PFOA
precursors
in
telomer­
treated
or
telomer­
containing
products
and
articles
Representative
telomer­
treated
or
telomer­
containing
products
and
articles
(
paper,
textile
and
carpet
products,

firefighting
foams),
from
manufacturers
and
importers
The
12
representative
telomer
based
polymers
will
be
applied
to
carpet
(
4),
textiles
(
6)
and
paper
(
2);
samples
will
be
tested
for
PFOA.

Impurity
analysis
of
articles
will
be
conducted
(
per
2/
7/
03
submission)
using
water/
methanol
extraction,
1
ppm
LOQ
1.
"
In­
use
articles":

a)
Temp
accelerated
aging
(
45
°
C
over
12
weeks)­
carpet,

textiles
and
paper;
and
b)

Photolysis
at
amb
temp
(
Xenon
lamp
for
24
hr.)
­
carpet,

textiles
and
paper
2.
If
sufficiently
quantifiable
levels
of
PFOA
are
detected
in
samples,
additional
testing
conducted:
a)
Abrasion
(
walk
off)­
carpet
and
textile;

b)
Washing
­
textile;

c)
Drycleaning
­
textile;

d)
Hot
water
extraction
­

carpet;
and
possibly
PFOA
EPA
is
reviewing
the
articles
selected.
Telomer
precursors
and
alcohols
are
not
included.

Impurity
testing
at
an
LOD
of
1
ppb
is
appropriate;
use
chloroform
or
another
aggressive
solvent.
If
PFOA
is
detected,
then
test
under
actual
conditions
of
use
using
a
mass
balance
approach.

Steam
temperatures,
hot
oil
(
coated
papers);
hot
oil
and
water
(
coated
papers);

ironing
(
textiles),
mouthing
by
children
(
textiles),
acid
exposure
(
carpet
and
textiles)

are
not
included.
Length
of
lifetime
testing
will
vary
by
article
(
e.
g.,
textile
lifetime
~

3
yr;
carpet
lifetime
~
10
yr.).

Additional
information
on
TRP
lifetime
testing
is
needed.
Consider
testing
articles
which
have
been
in
actual
consumer
use.
U.
S.
Environmental
Protection
Agency
Telomer
Summary
Table
Draft,
September
15,
2003
Item
EPA
Data
Need:

Telomers
Test
Substances
LOI
Commitment/
Chemical/

Data
EPA
Proposal
to
Address
Data
Needs
Not
Included
in
LOI
or
Proposed
ECA
8
9.
*
Presence
of
PFOA,

telomer
alcohol
or
other
PFOA
precursors
emitted
from
telomer
treated
products
and
articles
as
they
age
during
use
Representative
telomers
and
telomer
treated
products
and
articles
from
manufacturers
and
importers
in
indoor
air
adjacent
to
 
and
dust
from
or
adjacent
to
 
carpet,
textile,
and
paper
products.
PFOA
and
telomer
8­
2
alcohol
analyses
of
12
temperatureaged
telomer
polymers;
PFOA
analysis
before
and
after:

temperature
and
photolytic
aging
of
treated
carpet,
textile
and
paper;
abrasion
of
treated
carpet
and
textiles;
washing
and
dry
cleaning
of
treated
textiles;
and
hot
water
extraction
of
treated
carpet
No
TRP
commitments
beyond
LOI
See
comments
above,

although
the
actual
conditions
of
use
for
aged
articles
would
be
modified
to
mimic
actual
conditions
and
lifetime
(
e.
g.,
coated
papers
would
sit
at
ambient
temperature
for
a
given
period
of
time,
then
be
subjected
to
hot
oil
and
water,
then
disposed
of.

10.
Release
and
exposure
assessments
for
PFOA
and
PFOA
precursors
adjacent
to
telomer
manufacturing
and
use
facilities;
also
of
control
areas
Representative
telomers
and
related
compounds
in
air,

stream
and
quiet
surface
waters
(
surface
film
and
subsurface),

groundwater,
sediment,

surface
soil,
and
biota.
Covered
under
Environmental
Monitoring
Work
group
U.
S.
Environmental
Protection
Agency
Telomer
Summary
Table
Draft,
September
15,
2003
Item
EPA
Data
Need:

Telomers
Test
Substances
LOI
Commitment/
Chemical/

Data
EPA
Proposal
to
Address
Data
Needs
Not
Included
in
LOI
or
Proposed
ECA
9
11.
Release
and
exposure
assessments
for
PFOA
and
PFOA
precursors
from
use
of
fire­
fighting
foam
Representative
telomers
and
related
compounds
in
soil,

groundwater,
surface
water
runoff,
and
air
during
and
after
firefighting
foam
use.
None
­
presentation
to
be
made
at
9/
16/
2003
Telomers
Work
Group
Meeting
To
be
determined
12.
Product
stewardship
information
concerning
telomer
products
and
articles
Telomer
products
and
articles
Documentation
of
Product
Stewardship
Programs
EPA
is
reviewing
the
documentation
submitted.

*
Denotes
that
the
TRP
has
committed
to
provide
some,
but
not
necessarily
all,
information
concerning
this
particular
data
need
or
endpoint
for
one
or
more
chemicals.
Analytical
methods
are
to
be
determined,
and
data
quality
requirements
need
to
be
reviewed
to
determine
appropriateness
and
acceptability
in
the
context
of
this
ECA.
To
the
extent
that
chemicals
beyond
those
being
covered
under
the
LOI
are
identified
as
possible
test
candidates,
the
need
for
such
testing
will
be
considered
in
the
context
of
the
ECA
process.

Test
methods
may
be
amended
and
adapted
through
the
ECA
process,
and
where
test
methods
have
not
been
identified,
they
may
be
developed
during
the
ECA
process.
Draft
U.
S.
EPA
Draft
U.
S.
EPA
Telomer
Telomer
Selection
Selection
Criteria
for
PFOA
ECA
Criteria
for
PFOA
ECA


Use
category
Use
category
 
Carpet,
Textiles,
Paper,
etc.

Carpet,
Textiles,
Paper,
etc.

 
A
qualitative
criterion
A
qualitative
criterion


Structure
information
Structure
information
 
Polymeric
and
Non
Polymeric
and
Non­
polymeric
polymeric


Monomer
content;
variety
of
non
Monomer
content;
variety
of
non­
polymeric
structures
polymeric
structures
 
A
qualitative
criterion
A
qualitative
criterion


Fluorochemical
Fluorochemical
production
volume
production
volume
 
Annual
production
volume
(
kg)

Annual
production
volume
(
kg)
Draft
U.
S.
EPA
Draft
U.
S.
EPA
Telomer
Telomer
Selection
Selection
Criteria
for
PFOA
ECA
(
continued)

Criteria
for
PFOA
ECA
(
continued)



Rf
Rf
composition
composition
 
Isomeric
fluorocarbon
chain
length
ratio
in
chemical,

Isomeric
fluorocarbon
chain
length
ratio
in
chemical,

expressed
as
wt.
percent
expressed
as
wt.
percent
perfluoro
perfluoro­
C8
or
greater
C8
or
greater


Degradation
pathways
and
likelihood
Degradation
pathways
and
likelihood
 
Susceptibility
of
chemical
to
degradation
to
Susceptibility
of
chemical
to
degradation
to
corresponding
corresponding
perfluorinated
perfluorinated
acids
acids
 
Derived
from
Structure
information
Derived
from
Structure
information


Exposure
likelihood
Exposure
likelihood
 
Frequency
and
pathway
of
exposure,
number
of
Frequency
and
pathway
of
exposure,
number
of
exposure
events
per
year
exposure
events
per
year
 
Derived
from
Usage
category
Derived
from
Usage
category
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
1
EPA
Data
Needs
for
Elucidation
of
Degradation
Pathways
and
Identification
of
Degradation
Products
Test
Substances:

EPA:
Telomer
products
will
be
specified;
individual
representative
test
substances.
Examples
include
telomer
iodides,
telomer
alcohols,
telomer
esters
of
(
meth)
acrylates,
telomer
sulfonates,
telomer
phosphates
TRP:

TRP
will
select
two
telomer
based
products
and
two
telomer
based
polymers
isolated
from
them
for
proposed
OECD
302B
Zahn­
Wellens
testing
and
OPPTS
835.5045
Modified
SCAS
Test
for
Insoluble
and
Volatile
Chemicals.
Subsequently,
10
additional
polymeric
products
will
be
tested
using
the
OECD
302B
Zahn­
Wellens
test
.
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
2
Alternately,
(
1)
12
Telomer
Based
Polymer
Products
(
TBPP)
from
the
TRP
LOI
will
be
tested
as
a
composite
in
equal
weight
proportions
and
(
2)
the
isolated
polymers
from
the
12
LOI
TBPP
in
composite
equal
weight
proportions
will
be
tested
using
OECD
302B
Zahn­
Wellens
test.

A
composite
of
isolated
polymers
from
Telomer
Based
Polymer
Products
will
be
tested
using
a
Modified
SCAS
Test
for
Insoluble
and
Volatile
Chemicals
OPPTS
835.5045
2
telomer
based
polymers
isolated
from
the
12
LOI
telomer
based
polymer
products
or
isolated
polymer
composite
will
be
tested
using
the
Aerobic
and
Anaerobic
Transformation
in
Soils
Test
OECD
307.
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
3
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
Inherent
Biodegradation
Zahn­
Wellens
OECD
302B
Inherent
Biodegradation
Zahn­

Wellens
OECD
302
B
Telomer
8­
2
alcohol
and
12
representative
polymer
products
Analysis
for
PFOA
*
Inherent
Biodegradation
Zahn­

Wellens
OECD
302
B
2
telomer
based
polymer
products
2
telomer
based
polymers
Identification
of
degradation
products
including
PFOA
2H,
2Hperfluorodecanoate
2H­
perfluoro­
2­

decenoate
Trap
and
analyze
volatiles
Mass
balance
Sludge:
PFOA
Aqueous:
Fluoride
[
F­]

No
volatiles
analysis
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
4
NA
OECD
301D
Closed
Bottle
Test­
Ready
Biodegradability14C
and
nonlabelled
8­
2
telomer
alcohol
Analysis
for
PFOA
NA
NA
NA
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
5
Semicontinuous
Activated
Sludge
(
SCAS)
Test
OECD
302A
NA
Modified
SCAS
Test
for
Insoluble
and
Volatile
Chemicals
OPPTS
835.5045
Identification
of
degradation
products
including
PFOA
2H,
2Hperfluorodecanoate
2H­
perfluoro­
2­

decenoate
Trap
and
analyze
volatiles
Mass
balance
SCAS
Sludge:
PFOA
Aqueous:
Fluoride
[
F­]
PFOA
Air:
TOF,
F­
PFOA,

8­
2
alcohol
Possible
additional
time
point
analyses
for
PFOA,
8­
2
alcohol,
rate
constants
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
6
Simulation
Test­

Aerobic
Sewage
Treatment
(
Activated
Sludge
Units)
OECD
303A
NA
None
Identification
of
degradation
products
including
PFOA
2H,
2Hperfluorodecanoate
2H­
perfluoro­
2­

decenoate
Trap
and
analyze
volatiles
Mass
balance
NA
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
7
Aerobic
and
Anaerobic
Transformations
in
Soil
OECD
307
NA
Aerobic
and
Anaerobic
Transformations
in
Soil
OECD
307
Identification
of
degradation
products
including
PFOA
2H,
2Hperfluorodecanoate
2H­
perfluoro­
2­

decenoate
Trap
volatiles
Determine
rates
and
half­
lives
Duration
up
to
1
year
Unspecified
Duration
120
days
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
8
Aerobic
and
Anaerobic
Transformations
in
Aquatic
Sediment
Systems
OECD
308
NA
*
Aerobic
and
Anaerobic
Transformations
in
Aquatic
Sediments
OECD
308
Identification
of
degradation
products
including
PFOA
2H,
2Hperfluorodecanoate
2H­
perfluoro­
2­

decenoate
Trap
volatiles
Determine
rates
and
half­
lives
Duration
up
to
1
year
To
be
determined
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
9
Anaerobic
Biodegradability
of
Organic
Compounds
in
Digested
Sludge:

Measurement
of
Gas
Production,

OECD
311
NA
*
Anaerobic
Biodegradation
of
Organic
Compounds
in
Sludge
Identification
of
degradation
products
including
PFOA
Trap
volatiles
Determine
rates
and
half­
lives
Duration
to
be
determined
Mass
balance
To
be
determined
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
10
(
Covered
under
OECD
308)
*
Modified
River
Die
Away
NA
To
be
determined
UV/
Visible
Absorption
OPPTS
830.7050
UV/
Visible
Absorption
Telomer
8­
2
Alcohol
*
UV/
Visible
Absorption
NA
NA
Direct
Photolysis
in
Water
OPPTS
835.2210
NA
*
Direct
Photolysis
in
Water
To
be
determined
To
be
determined
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
11
Indirect
Photolysis
Screening
Test
OPPTS
835.5270
NA
*
Indirect
Photolysis
in
Water
To
be
determined
To
be
determined
None
Atmospheric
Oxidation
Telomer
8­
2
Alcohol
*
Indirect
Photolysis
in
Air
NA
To
be
determined
None
*
Direct
Photolysis
in
Air
NA
To
be
determined
U.
S.
Environmental
Protection
Agency
Telomer
Degradation
Needs
Comparison
September
15,
2003
EPA
Proposed
Test
TRP
LOI
Commitment
TRP
Proposed
Test
Beyond
LOI
Commitment
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Beyond
LOI
Commitment
12
None
*
Indirect
Photolysis
in
Soil
NA
To
be
determined
*
Part
of
TRP
E­
Fate
testing
decision
tree
but
not
part
of
proposed
study
plan.
TRP
Telomer
Research
Program
Telomer
Technical
Work
Group
Meeting
Telomer­
based
Polymeric
Products
(
TBPP)
Biodegradation
Study
Strategy
16
September
2003
16
September
2003,
page
2
Telomer
Research
Program
Overview

Objective
of
Biodegradation
Studies
for
Telomer­
based
Polymeric
Products

Analytical
Considerations
&
Limitations

Biodegradation
in
Sludge

Biodegradation
in
Soil

Summary
&
Conclusions
16
September
2003,
page
3
Telomer
Research
Program
Study
Objective

Do
Telomer­
based
Polymeric
Products
(
TBPP)
biodegrade
to
PFOA?


TRP
recognizes
that
data
is
needed
to
inform
this
question
and
offers
a
study
approach
where
both
Telomer­
based
Polymeric
Products
and
Telomer­
based
Polymers
are
investigated
and
the
desire
for
timely
results.


Proposed
Studies

address
partitioning
and
biotransformation
in
relevant
environmental
compartments

start
with
laboratory
studies
that
are
simple
and
inform
the
question
of
whether
telomer­
based
polymeric
products
and
telomer­
based
polymers
have
the
potential
to
transform
to
PFOA
16
September
2003,
page
4
Telomer
Research
Program
80%
Water
20%
Telomer
Polymer
°
Aqueous
Dispersion
of .

°
Polymeric
Particles
100­
200
nm
with...

°
Hydrocarbon
Surfactant(
s)

What
is
a
Typical
Telomer­
Based
Polymeric
Product's
Composition
?


Telomer
Polymeric
Product
Variables

wt.%
solids
in
product
(~
20%)


19.8
+
%
polymer

0.2
+
%
residual
raw
materials

wt.%
fluorine

wt.%
Telomer
raw
materials

wt.%
eight­
fluorinated
carbon
chain
C8F17­


PFOA
(
from
product
analysis)


Mol.
Wt.
­
Typically
>
10,000
Daltons

polyacrylates

polyurethanes
16
September
2003,
page
5
Telomer
Research
Program
Release
of
Telomer­
based
polymeric
products

Telomer­
based
polymeric
products
(
TBPP)
primarily
enter
the
environment

in
sewage
treatment
plants
(
stp)


in
soil
via
sludge
amendment
to
agricultural
soils

in
surface
water
and
sediment
via
stp
e.
g.
sorbed
to
effluent
particles

in
landfills
from
sludge
or
disposal
of
treated
articles
(
carpets,
textiles,

paper)


TRP
Program
:


Sludge
and
Soil
are
environmental
compartments
for
TBPP
where
study
work
should
be
focused

Other
compartments
(
air,
sediment,
water)
are
...


considered
in
the
work
plans
for
soil
and
sludge
or
are
not
primary
compartments
of
entry
for
TBPP

considered
in
the
TRP
work
on
8­
2
Telomer
B
Alcohol
16
September
2003,
page
6
Telomer
Research
Program
Analytical
Method
Requirements

First,
establishment
of
robust
analytical
methods
for
study
matrices
is
mandatory
to
achieve
meaningful
results

Matrices

sludge,
aerobic
and
anaerobic
soil;
appropriate
dispersion
of
test
polymer
solid

Analytes

e.
g.
Fluoride,
PFOA
and
Total
Organic
Fluorine
(
TOF)


Extraction
&
Recovery
Demonstration

analyte
recovery
within
test
time
period
must
be
acceptable

sludge
28
to
84
days

soil
4
­
6
months

It
is
required
by
test
guidelines
to
only
begin
testing
after
appropriate
analytical
methods
have
been
established
and
demonstrated.
16
September
2003,
page
7
Telomer
Research
Program
Establish
Dispersion
Method
Establish
Extraction
Method
Establish
Quantification
Method
Quality
Check
Spiking
experiment
Full
Exposure
Period
Quality
Check
START
REAL
TEST
Test
method
not
applicable
yes
yes
no
no
It
has
to
be
proven,
for
the
study
to
be
conducted
 ..

°
that
dispersion,
extraction
and
quantification
is
possible
°
that
the
development
methodology
is
applicable
to
conditions
over
the
full
study
exposure
time
period
(
e.
g.

28d,
84d
or
6
months)

°
that
analyte
recovery
and
measurement
is
stable
over
the
study
time
period
Improvement
?
Analytical
Requirements
for
Environmental
Studies
­
General
Overview
16
September
2003,
page
8
Telomer
Research
Program
Water
°
Fluoride
°
PFOA
Solids
°
Total
Fluorine
Air
Trap
°
Fluoride
°
PFOA
°
8­
2
TBA
+
+

Analysis
Matrices
Polymeric
Product
(
TBPP)

°
Inorganic
Fluoride
(
F­)

°
PFOA
?

°
8­
2
TBA
?

°
Total
Organic
Fluorine
How
to
achieve
Mass
Balance
the
measurements
fit
together
Solvent
Extraction
°
PFOA
°
8­
2
TBA
°
Other
organic
fluorine
compounds
as
TOF
Step
1
Characterization
of
TBPP
Test
Substance
Step
2
Analyte
Recovery
&
Quantitation
16
September
2003,
page
9
Telomer
Research
Program
Sewage
Treatment
Plants
(
STP)

Biodegradability
Testing
Experimental
Design
Discussion
16
September
2003,
page
10
Telomer
Research
Program
Test
Materials
for
STP
Biodegradation
Study
Proposal
9
Sept.
2003

OECD
302
B
(
Zahn­
Wellens
/
EMPA
Test)
on

Two
(
2)
Telomer­
based
Polymeric
Products
(
TBPP)
&
2
Telomerbased
polymers
isolated
from
TBPP
Products
will
be
from
the
12
that
are
included
in
the
TRP
LOI

Two
isolated
polymers
from
the
two
Products

to
understand
whether
the
polymer
alone
undergoes
transformation

characterization
of
the
products
and
isolated
polymers
will
be
done

will
enable
method
development
and
demonstration
for
longer­
term
studies

provides
results
in
short
timeframe

Then
 ..
Conduct
302B
on
additional
10
polymeric
products
in
LOI

This
is
a
modification
of
the
TRP
LOI
commitment
16
September
2003,
page
11
Telomer
Research
Program
Test
Materials
for
STP
Biodegradation
Study
Proposal
16
Sept.
2003

Alternatively
  ...
To
ensure
representativeness

We
propose
to
study

the
twelve
(
12)
TBPP
outlined
in
the
TRP
LOI

in
equal
weight
proportions,
as
a
composite

in
an
OECD
302B
Modified
Zahn­
Wellens
Study

and

the
isolated
polymers
from
the
twelve
(
12)
TBPP

in
equal
weight
proportions,
as
a
composite

in
an
OECD
302B
Modified
Zahn­
Wellens
Study
16
September
2003,
page
12
Telomer
Research
Program
Test
Materials
for
STP
Biodegradation
Study
Proposals

In
parallel,
we
propose
to
develop
a
study
protocol
to
conduct
 


OPPTS
835.5045
"
Modified
SCAS
Test
For
Insoluble
and
Volatile
Chemicals"


need
to
develop
and
demonstrate
feasible
analytical
methods

on
the
composite
of
Isolated
Polymers
(
from
Telomer
Based
Polymer
Products)


we
want
to
discuss
the
decision
triggers
for
this
study

and
to
develop
the
appropriate
work
to
demonstrate
analytical
feasibility
16
September
2003,
page
13
Telomer
Research
Program
Biodegradation
Testing
Strategy
Telomer­
Based
Polymer
Product
(
TBPP)
or
Composite
Isolated
Polymer
from
TBPP
or
Composite
Conduct
Modified
SCAS
Test
on
Isolated
Polymer
only*

Does
TBPP
Biodegrade?
Yes
No
Conduct
Modified
SCAS
Test
on
TBPP*
SCAS:

Analytical
Methods
work
?

STOP
Decision
:

1)
PFOA
or
F­
>
LOQ
2)
related
to
residuals
STOP
No
Yes
Modified
Zahn­

Wellens/
EMPA
Test
LOI
Modified
Zahn­

Wellens/
EMPA
Test
LOI
SCAS:

Analytical
Methods
work
?
Yes
No
*
Kinetic
Investigations
will
be
considered
after
reviewing
study
results
16
September
2003,
page
14
Telomer
Research
Program
Proposal
for
Modification
of
Performance
of
Test:

Modified
SCAS
Test
(
OPPTS
835.5045)


Run
study
for
12
weeks

Collect
and
freeze
samples
daily
over
12
weeks

Analyze
samples
at
Day
0,
Weeks
4,
8,
and
12.


Will
look
for:


1)
Effluent
&
Sludge
:
Total
Organic
Fluorine,
Fluoride
ion

2)
Effluent
&
Sludge
solids
:
PFOA

3)
Volatility
Traps
:
Total
Organic
Fluorine,
Fluoride
ion,
PFOA,
8_
2
Telomer
B
Alcohol

If
2
&
3
PFOA
concentration
is
less
than
LOQ,
stop.


If
2
or
3
PFOA
concentration
is
greater
than
LOQ,
then
consider
further
studies
and
analyses.
16
September
2003,
page
15
Telomer
Research
Program
Modification
of
OECD
307
Aerobic
and
Anaerobic
Transformations
in
Soil
Experimental
Design
Discussion
16
September
2003,
page
16
Telomer
Research
Program
Test
Materials
for
Soil
Biodegradation
Study
Proposals

OECD
307
Aerobic
and
Anaerobic
Transformations
in
Soil

Two
(
2)
Telomer­
based
polymers
isolated
from
TBPP
Products
will
be
from
the
12
that
are
included
in
the
TRP
LOI

Two
isolated
polymers
from
the
two
Products

to
understand
whether
the
polymer
alone
undergoes
transformation

characterization
of
the
products
and
isolated
polymers
will
be
done

will
enable
method
development
and
demonstration

option
:
conduct
study
on
isolated
polymer
composite
of
all
12
TBPP
16
September
2003,
page
17
Telomer
Research
Program
Biodegradation
Testing
in
Soil
Testing
Strategy
Pilot
Study

Pilot
study
:
Modified
OECD
307
Test
setting

Establishment
and
Verification
of
the
Analytical
method
for
four
to
six
months
exposure

Testing
of
two
isolated
polymers

Use
of
the
OECD
307
(
Aerobic
and
anaerobic
transformation
in
soil)

setting

apply
aerobic
and
anaerobic
conditions

Alternatively,
conduct
study
on
isolated
polymer
composite

Kinetic
investigations

will
be
considered
after
reviewing
study
results
TRP
Telomer
Research
Program
Telomer
Technical
Work
Group
Meeting
Telomer­
based
Polymeric
Paper
and
Textile
Products
Incineration
Test
Protocol
Outline
September
16,
2003
16
September
2003,
page
2
Telomer
Research
Program
Discussion
Objective

Review
draft
test
protocol
outline
for
understanding

Determine
next
steps
16
September
2003,
page
3
Telomer
Research
Program
Outline

Introduction

Test
Objective

Experimental
Approach

Materials
and
Methods

Combustion
Test
Sampling
and
Analysis

Reporting
of
Results

Appendix
16
September
2003,
page
4
Telomer
Research
Program
Introduction

Overall
objective
of
test
program
is
to
determine
if
incineration
of
Telomer­
based
Polymeric
Products
is
a
potential
source
of
PFOA

Draft
Test
Protocol
Submission
(
9/
12/
03)
is
an
outline
as
agreed;
protocol
to
be
developed
pending
agreement
on
outline

QAPP
addressing
QA/
QC
to
be
developed
pending
agreement
on
protocol
outline
16
September
2003,
page
5
Telomer
Research
Program
Reminder

Initial
work
will
focus
on
demonstrating
that
proposed
methods
are
capable
of
meeting
data
quality
objectives
(
DQOs)


Program
needs
to
include
a
provision
to
obtain
approval
to
modify
test
program
for
alternative
methods
in
case
proposed
methods
do
not
provide
information
meeting
DQOs
16
September
2003,
page
6
Telomer
Research
Program
Test
Objective

Investigate
incineration
of
telomer­
based
polymeric
products
under
laboratory­
scale
conditions
representative
of
typical
municipal
waste
combustor
(
MWC)
operations
in
the
U.
S.
to
quantitatively
determine
potential
emission
levels
of
PFOA
16
September
2003,
page
7
Telomer
Research
Program
Experimental
Approach

Conduct
elemental
analysis
of
test
feeds
to
define
stoichiometry

Perform
TGA
to
inform
needed
conditions
for
feed
gasification
in
combustion
tests

Verify
quantitative
transport
of
PFOA

Conduct
combustion
tests
16
September
2003,
page
8
Telomer
Research
Program
Experimental
Apparatus
­
General
Description

A
batch­
charged
continuous
flow
reactor
system

The
test
sample
is
gasified
and
transported
to
a
high
temperature
reactor.


In
the
high
temperature
reactor,
the
sample
vapors
are
subjected
to
controlled
conditions
of
residence
time,
temperature,
and
excess
air.


Combustion
products
are
collected
for
quantitative
analysis.
16
September
2003,
page
9
Telomer
Research
Program
Advanced
Thermal
Reactor
System
(
ATRS)

Gas
Chromatograph
Mass
Selective
Detector
Workstation
Reactor
Coolant
Cold
Trap
Pyroprobe
Inlets
&

Main
Gas
Flow
Supplemental
Gas
Flow
To
Ventilation
System
Bubblers
16
September
2003,
page
10
Telomer
Research
Program
Test
Materials

Telomer­
based
Polymeric
Product
­
Paper

A
single
representative
composite
mixture
of
the
LOI
telomer­
based
polymeric
products
which
are
applied
to
paper,
as
solids,
in
equal
proportions

Telomer­
based
Polymeric
Product
­
Textile

A
single
representative
composite
mixture
of
the
LOI
telomer­
based
polymeric
products
which
are
applied
to
textiles,
as
solids,
in
equal
proportions
16
September
2003,
page
11
Telomer
Research
Program
Experimental
Conditions

Telomer­
based
polymeric
product
solids
will
be
subjected
to
laboratory­
scale
incineration
using
the
experimental
apparatus

Two
test
levels
are
proposed
for
the
high
temperature
reactor:


(
1)
900
°
C
for
two
seconds
residence
time
(
municipal)


(
2)
1000
°
C
for
two
seconds
residence
time
(
medical,
municipal)


Three
(
3)
replicates
for
each
test
level
(
combination
of
test
feed
and
temperature).


Additionally,
a
blank
run
under
each
experimental
condition

The
amount
of
test
material
in
feed
will
be
large
enough
to
assure
ability
to
detect
compounds
of
interest
in
the
emissions,
but
small
enough
to
assure
sufficient
excess
oxygen
to
be
representative
of
MWC
conditions.
16
September
2003,
page
12
Telomer
Research
Program
Test
Feed
Paper
Composite
Paper
Composite
Textile
Composite
Textile
Composite
Temperature
900
oC
1000
oC
900
oC
1000
oC
Residence
Time
2
sec
2
sec
2
sec
2
sec
Excess
O2
10
%
10
%
10
%
10
%

No.
of
runs
3
3
3
3
No.
of
thermal
blanks
>
1
1
1
1
Experimental
Study
Plan
16
September
2003,
page
13
Telomer
Research
Program
Combustion
Test
Sampling
&
Analysis

Exhaust
Gas

Monitored
parameters
(
GC:
CO,
CO2;
O2,
flow)


Fluoride
ion
via
ISE
or
ion
chromatography

PFOA
(
LC/
MS/
MS)


Total
fluoride
(
total
organic
fluoride
by
difference)


Test
Feed
Material

Elemental
analysis
(
C,
H,
N,
F,
S,
O)


Total
fluoride
(
total
organic
fluoride
by
difference)


Thermogravimetric
Analysis
(
TGA)


PFOA
(
LC/
MS/
MS)
16
September
2003,
page
14
Telomer
Research
Program
Sampling
&
Analysis
(
cont'd.)


Sampling

Methods
need
to
be
developed
and
demonstrated

Sorbent
Cartridge

OSHA
Versatile
Sampler
(
OVS)


analyze
for
PFOA

Aqueous
Solution

use
one
or
more
impingers
containing
aqueous
solution

analyze
for
PFOA

analyze
for
fluoride
ion
to
assist
in
performing
a
fluoride
balance
across
the
experimental
system.


Analysis
Method
for
PFOA

Method
needs
to
be
developed
and
demonstrated

via
off­
line
LC/
MS/
MS
at
a
qualified
commercial
laboratory
operating
under
suitable
data
quality
guidelines.
16
September
2003,
page
15
Telomer
Research
Program
Reporting
of
Results

Exhaust
Gas
Results

Test
Feed
Material
Results

Exposure
Assessment
16
September
2003,
page
16
Telomer
Research
Program
Discussion

1
9/
12/
03
Detailed
Test
Protocol
Outline
Proposal,
September
12,
2003
1.
Introduction
The
overall
goal
of
this
program
is
to
determine
if
incineration
of
telomer­
based
substances
(
in
applications
where
incineration
is
a
commonly
used
disposal
practice)
is
a
potential
source
of
PFOA
to
the
environment.

This
document
presents
a
detailed
outline
of
a
protocol
for
a
research
program
to
conduct
incineration
testing.
Substantial
work
is
necessary
to
integrate
available
sampling
and
analytical
methods
for
PFOA
into
an
experimental
program
for
incineration
testing.

Following
agreement
on
this
document,
a
test
protocol
and
Quality
Assurance
Project
Plan
(
QAPP)
can
be
prepared.
The
QAPP
will
include
data
quality
objectives
(
DQOs).
Although
alternative
methods
are
included
herein
to
the
extent
practicable,
it
is
anticipated
that
the
administration
of
this
program
will
allow
for
obtaining
approval
to
modify
the
test
program
(
e.
g.,
to
substitute
alternate
test
methods)
in
case(
s)
where
proposed
method(
s)
do
not
appear
able
to
provide
information
meeting
these
DQOs.

The
QAPP
will
also
address
other
quality
assurance/
quality
control
elements
for
this
test
program,
including
project
organization,
chain
of
custody,
and
sample
container
selection.

Details
of
this
test
protocol
are
outlined
in
subsequent
sections.
The
test
objective
is
presented
in
Section
2.
Section
3
discusses
the
overall
experimental
approach
and
preliminary
testing
prior
to
the
combustion
tests.
Section
4
presents
the
materials
and
methods
involved
in
this
test
program
with
focus
on
combustion
testing.
Plans
for
sampling
and
analysis
are
described
in
Section
5.
Section
6
reviews
how
results
of
this
program
will
be
reported.

2.
Test
Objective
The
specific
objective
of
this
test
program
is
to
investigate
incineration
of
telomer­
based
substances
under
laboratory­
scale
conditions
representative
of
typical
2
9/
12/
03
municipal
waste
combustor
operations
in
the
U.
S.
to
quantitatively
determine
potential
emission
levels
of
PFOA.

3.
Experimental
Approach
Each
test
material
(
as
described
in
Section
4.2)
will
undergo
elemental
analysis
(
see
Section
5.2)
to
define
the
basic
parameters
for
stoichiometric
calculations.

Thermogravimetric
analysis
(
TGA)
per
ASTM
E1641
will
be
conducted
to
determine
the
gasification
temperature
of
each
test
material.
TGA
will
be
performed
on
each
sample
to
determine
the
temperature
range
required
for
gasification
of
the
sample
and
ash
content.
This
analysis
will
be
conducted
in
flowing
air
from
room
temperature
to
1000
°
C
at
25
°
C/
minute
using
3
to
5
mg
samples.
The
temperature
for
100%
gasification
for
each
test
material
will
be
considered
in
establishing
conditions
for
the
gasification
section
(
pyroprobe
section)
of
the
experimental
apparatus
for
the
combustion
tests;
see
section
4.3.

Overall,
stoichiometry
and
TGA
results
will
form
the
basis
for
setting
experimental
conditions
(
e.
g.,
time
and
temperature)
in
the
gasification
section
of
the
experimental
system
during
the
combustion
tests.

Combustion
tests
will
be
carried
out
at
specified
operating
conditions
as
presented
in
Section
4.3.

Prior
to
combustion
testing,
quantitative
transport
of
PFOA
will
be
verified.
For
these
transport
tests,
plans
call
for
gasifying
nominally
1
mg
of
PFOA
at
150
to
200
o
C
with
transfer
line
and
reactor
temperatures
nominally
30
to
50
o
C
higher
than
the
gasification
temperature.
The
exhaust
gas
will
be
sampled
and
analyzed
as
described
in
Section
5.1.4
to
determine
quantitation
of
PFOA.
If
the
PFOA
transport
efficiency
is
found
to
be
less
than
a
specified
level
(
e.
g.,
70%),
then
the
reactor
would
be
disassembled
and
extracted
with
an
appropriate
solvent
(
e.
g.,
methanol).
This
solvent
sample
would
be
analyzed
via
the
analytical
method
described
in
Section
5.1.4
to
determine
if
adsorption
on
the
reactor
walls
is
responsible
for
the
low
recovery.
The
experimental
apparatus
described
in
Section
4.1
is
configured
such
that
additional
extractions
of
the
transfer
lines
between
the
pyroprobe
and
the
reactor
and
3
9/
12/
03
between
the
reactor
and
the
downstream
sampling
point
are
not
feasible.

4.
Materials
and
Methods
4.1
Combustion
Test
Experimental
Apparatus
Incineration
testing
is
to
be
accomplished
using
a
batchcharged
continuous
flow
reactor
system.
The
test
sample
is
gasified
and
transported
to
a
high
temperature
reactor
In
the
high
temperature
reactor,
the
sample
vapors
are
subjected
to
controlled
conditions
of
residence
time,
temperature,
and
excess
air.
Combustion
products
are
collected
for
quantitative
analysis.

Use
of
the
Advanced
Thermal
Reactor
System
(
ATRS)
at
the
University
of
Dayton
Research
Institute
(
UDRI)
is
planned.
A
schematic
of
the
ATRS
as
planned
for
use
in
this
test
program
is
presented
in
Figure
1.

Figure
1.
Schematic
of
ATRS
for
Planned
Testing
Gas
Chromatograph
Mass
Selective
Detector
Workstation
Reactor
Coolant
Cold
Trap
Pyroprobe
Inlets
&
Main
Gas
Flow
Supplemental
Gas
Flow
To
Ventilation
System
Bubblers
4
9/
12/
03
Supplemental
gas
flow
and
main
gas
flow
refer
to
the
planned
gas
feeds
(
synthetic
air
and
methane).

The
ATRS
consists
of
a
reactor
assembly
and
in­
line
gas
chromatograph/
detector
system
connected
via
a
cryogenic
interface.
The
reactor
assembly
consists
of
a
thermally
insulated
enclosure
housing
the
sample
introduction,
reactor,
and
transfer
line
systems.
Sample
introduction
for
solid
materials
employs
a
pyroprobe,
a
device
designed
to
gasify
samples
by
heating
them
at
a
fixed
rate.
During
combustion
tests,
the
transfer
line
between
the
pyroprobe
and
the
reactor
is
heated
and
maintained
above
250
oC.
The
reactor
is
housed
within
its
own
small
tube
furnace
and
may
be
independently
heated
to
as
high
as
1200
oC.
(
Actual
conditions
planned
for
this
test
program
are
presented
in
Section
4.3.)
The
exhaust
line
from
the
reactor
is
heat
traced
to
prevent
cool
regions
where
reactor
products
could
otherwise
be
lost
through
condensation.
The
cryogenic
interface
(
cold
trap)
is
of
a
shell
and
tube
design
and
provides
significant
cooling
of
the
combustion
exhaust
gas
prior
to
on­
line
monitoring
or
sample
collection.

For
this
test
program,
plans
call
for
setting
the
cold
trap
temperature
at
nominally
 
15
oC
to
be
below
the
freezing
point
of
water
(
H2O)
but
above
the
sublimation
temperature
of
carbon
dioxide
(
CO2)
to
assist
in
separating
H2O
from
carbon
monoxide
(
CO)
and
CO2.

The
in­
line
gas
chromatograph
(
with
molecular
sieve
column)
and
mass
selective
detector
(
MSD)
are
planned
to
be
used
to
monitor
CO
and
CO2.
Exhaust
gas
samples
for
off­
line
analysis
will
be
collected
from
the
vent
line
off
the
cold
trap;
see
Section
5.1.

4.2
Test
Materials
Two
test
materials
are
planned
for
this
study:

 
A
single
representative
composite
mixture
of
the
LOI
telomer­
based
polymeric
products
which
are
applied
to
paper,
as
solids,
in
equal
proportions.

 
A
single
representative
composite
mixture
of
the
LOI
telomer­
based
polymeric
products
which
are
applied
to
textiles,
as
solids,
in
equal
proportions.
5
9/
12/
03
4.3
Combustion
Test
Experimental
Conditions
The
test
materials
described
in
Section
4.2
will
be
subjected
to
laboratory­
scale
incineration
using
the
experimental
apparatus
described
in
Section
4.1.

Synthetic
air
(
mixture
of
21%
oxygen
and
79
%
nitrogen)
will
be
used
in
place
of
compressed
air
to
prevent
potential
interference
in
the
experimental
system
due
to
background
levels
of
CO2
in
compressed
air.

Methane
will
be
used
as
needed
as
a
supplemental
fuel
to
ensure
the
presence
of
sufficient
hydrogen
to
convert
fluorine
to
hydrogen
fluoride
(
HF).

Two
levels
of
temperature
for
the
high
temperature
reactor
are
planned:

 
900
°
C
 
1000
o
C
As
the
Appendix
indicates,
the
lower
temperature
represents
the
low
end
of
normal
operating
temperatures
for
the
high
temperature
zone
of
municipal
waste
combustors
(
MWCs)
in
the
U.
S.,
and
the
higher
temperature
represents
the
typical
operating
temperature
for
the
high
temperature
zone
of
MWCs
and
medical
waste
incinerators
in
the
U.
S.

At
each
temperature
level,
the
planned
operating
conditions
for
the
high
temperature
reactor
during
the
combustion
tests
are
2
seconds
gas
residence
time
and
10%
oxygen
in
the
exhaust
gas.
As
the
Appendix
indicates,
these
conditions
are
representative
of
typical
operating
conditions
for
MWCs
in
the
U.
S
As
noted
in
Table
1,
three
replicates
are
planned
for
each
test
level
(
combination
of
test
material
and
temperature).

Table
1
Test
Material
Paper
composite
Paper
composite
Textile
composite
Textile
composite
Temperature
900
o
C
1000
o
C
900
o
C
1000
o
C
No.
of
runs
3
3
3
3
Additionally,
at
least
one
thermal
blank
(
with
combustion
test
feeds
except
for
the
test
material)
is
planned
for
each
group
of
3
runs.
6
9/
12/
03
The
amount
of
test
material
fed
will
be
large
enough
to
assure
ability
to
detect
PFOA
in
the
emissions,
but
small
enough
to
assure
sufficient
excess
oxygen
to
be
representative
of
typical
MWC
conditions.
While
elemental
analysis
and
TGA
is
required
to
establish
the
planned
mass
of
sample,
the
expected
sample
size
is
on
the
order
of
1
to
2
mg.

The
temperature
in
the
pyroprobe
section
will
be
maintained
at
approximately
50
to
100
o
C
above
the
highest
temperature
for
100%
gasification
across
the
test
materials
as
determined
from
the
thermogravimetric
experiments
earlier
in
the
test
program.
This
is
necessary
to
assure
complete
gasification
of
the
sample
of
test
material
and
a
common
set
of
experimental
conditions
across
the
test
materials
during
combustion
testing.

5.
Combustion
Test
Sampling
and
Analysis
5.1
Exhaust
Gas
Sampling
&
Analysis
Gas
samples
for
off­
line
analysis
will
be
collected
from
a
vent
line
off
the
cold
trap
and
may
be
subjected
to
additional
external
cooling
(
e.
g.,
ice
bath)
as
needed.

Analysis
of
the
exhaust
gas
samples
of
the
thermal
blanks
will
focus
on
PFOA
since
the
primary
purpose
of
conducting
these
blank
runs
is
to
check
for
possible
crosscontamination
between
sample
runs.

5.1.1
Monitored
Parameters
As
noted
in
Section
4.1,
on­
line
monitoring
for
CO
and
CO2
via
the
in­
line
GC
using
a
molecular
sieve
column
and
MSD
is
planned.
Alternately,
Tedlar
®
bag
samples
of
exhaust
gas
may
be
collected
for
off­
line
CO
and
CO2
analysis.

Exhaust
gas
flow
rate
will
be
monitored
based
on
measured
input
flow
rates
of
the
synthetic
air
and
methane
gas
feeds.
Exhaust
gas
oxygen
concentration
will
be
calculated,
based
on
measured
input
flow
rate
of
synthetic
air
and
methane
assuming
complete
combustion.
7
9/
12/
03
5.1.2.
Fluoride
The
exhaust
gas
will
be
sampled
and
analyzed
for
fluoride
ion
to
assist
in
performing
a
fluoride
balance
across
the
experimental
system.

Fluoride
ion
will
be
sampled
via
absorption
into
aqueous
solution,
using
bubblers
(
low
pressure
drop
midget
impingers)
in
series.
As
Figure
1
indicates,
initial
plans
call
for
using
three
bubblers
in
series
with
the
first
one
empty
to
serve
as
a
knock­
out
pot
and
the
second
and
third
containing
a
predetermined
amount
of
aqueous
solution.
(
The
number
of
aqueous
solution
bubblers
will
be
adjusted
as
necessary.)
Upon
completion
of
sample
collection,
the
amounts
in
each
bubbler
will
be
measured
and
the
contents
of
the
bubblers
will
be
quantitatively
transferred
into
a
container
for
subsequent
analysis
for
total
inorganic
fluorine
(
i.
e.,
fluoride
ion)
via
ion
chromatography
or
ion
selective
electrode.

5.1.3
Total
Fluorine
The
aqueous
solution
sample
collected
as
described
in
Section
5.1.2
is
also
planned
to
be
subjected
to
analysis
for
total
fluorine
via
Wickbold
torch
so
that
total
organic
fluorine
can
be
determined
by
difference
between
total
fluorine
and
total
inorganic
fluorine.
Work
is
in
progress
to
confirm
that
detection
limits
for
total
fluorine
analysis
via
Wickbold
torch
are
low
enough
to
be
informative
for
this
test
system.

5.1.4
PFOA
Exhaust
gas
samples
will
be
analyzed
for
PFOA
via
LC/
MS/
MS
at
a
qualified
commercial
laboratory
operating
under
suitable
data
quality
guidelines.

Development
is
in
progress
to
define
the
most
suitable
sampling
technique
for
PFOA
in
the
incineration
exhaust
gas.

Initial
plans
call
for
using
the
aqueous
solution
bubblers
described
in
Section
5.1.2
to
collect
PFOA
from
the
exhaust
gas
and
for
sending
a
portion
of
the
aqueous
solution
for
PFOA
analysis
as
described
above.
Additionally,
an
attempt
will
be
made
to
use
an
OSHA
Versatile
Sampler
(
OVS)
as
a
back­
up
sampling
device.
If
OVS
is
also
used
to
sample
8
9/
12/
03
PFOA
in
the
exhaust
gas,
then
the
OVS
would
also
be
sent
for
off­
line
LC/
MS/
MS
analysis
to
quantify
PFOA
as
a
crosscheck
on
the
aqueous
solution
bubbler
results.

5.2
Test
Material
Sampling
&
Analysis
Each
test
material
composite
will
be
dissolved
in
an
appropriate
solvent
and
analyzed
for
PFOA
via
LC/
MS/
MS
at
a
qualified
commercial
laboratory
operating
under
suitable
data
quality
guidelines.

As
noted
in
Section
3,
each
test
material
composite
will
undergo
elemental
analysis
for
carbon,
hydrogen,
nitrogen,
fluorine,
sulfur,
and
oxygen
by
difference.
Ultimate
analysis
(
ASTM
D3176
and
other
ASTM
methods
referenced
therein)
are
planned
for
this
analysis.
Moisture
is
also
determined
by
this
method.
Depending
on
sample
size,
it
may
be
necessary
to
implement
the
microanalytic
analog
of
ultimate
analysis.

In
order
to
enable
determination
total
organic
fluoride
(
in
each
test
material
composite)
by
difference
between
fluorine
(
total
fluorine)
and
fluoride
(
total
inorganic
fluoride),
each
test
material
will
undergo
aqueous
extraction
and
analysis
of
the
aqueous
extract
for
fluoride
ion
(
via
ion
chromatography
or
ion
selective
electrode)
to
yield
a
total
inorganic
fluorine.

6.
Reporting
of
Results
6.1
Exhaust
Gas
Results
6.1.1
Monitored
Parameters
CO
will
be
reported
in
terms
of
parts
per
million
by
volume
(
ppmv).
CO
2
will
be
reported
in
terms
of
percent
by
volume
(%).
Oxygen
will
be
reported
in
terms
of
percent
by
volume
(%).
Exhaust
gas
flowrate
will
be
reported
in
units
of
cubic
centimeters
per
minute
(
cm
3/
min).

6.1.2
Fluoride
and
Fluorine
Total
fluorine
and
fluoride
(
total
inorganic
fluorine)
in
the
exhaust
gas
will
each
be
reported
in
terms
of
concentration
(
mass
of
fluorine
per
volume
of
exhaust
gas)
9
9/
12/
03
in
the
gas
as
well
as
on
the
basis
of
mass
of
fluorine
per
mass
of
starting
test
material.

Total
organic
fluorine
will
be
determined
by
difference
between
total
fluorine
and
total
inorganic
fluorine.

6.1.3
PFOA
PFOA
in
the
exhaust
gas
will
be
reported
in
terms
of
concentration
in
the
gas
as
well
as
on
the
basis
of
mass
per
mass
of
starting
test
material.

6.2
Test
Material
Results
PFOA
for
each
composite
will
be
reported
in
terms
of
mass
per
mass
of
composite
feed
material.

Elemental
compositions
and
total
organic
fluoride
will
be
reported
in
terms
of
mass
per
mass
of
composite
feed
material.

6.3
Exposure
Assessment
In
the
event
that
PFOA
is
found
in
the
exhaust
gas
at
a
concentration
above
the
limit
of
quantitation
(
for
the
matrix)
from
one
or
more
experiments
described
in
this
protocol,
then
the
potential
for
exposure
related
to
incineration
of
the
subject
material
will
be
assessed
to
inform
the
basis
for
possible
next
steps.

This
assessment
will
consider
a
number
of
factors
such
as
 
Test
program­
determined
PFOA
emission
factor,

 
Estimated
amounts
of
subject
material
in
feed
to
fullscale
waste
incinerators,
and
 
Degree
of
post­
combustion
air
pollution
control
(
e.
g.,
use
and
effectiveness
of
carbon
adsorption).
10
9/
12/
03
Appendix
Polymers
of
the
sort
being
investigated
in
this
test
program
may
be
present
at
trace
to
low
concentrations
in
municipal
solid
waste
or
in
medical
waste
and
therefore
may
be
incinerated.

A.
1
Types
of
Incinerators
A.
1.1
Municipal
Waste
Combustors
According
to
the
Integrated
Waste
Services
Association
(
IWSA),
there
are
a
total
of
98
waste­
to­
energy
facilities
operating
municipal
waste
combustors
(
MWCs)
in
the
U.
S.
as
of
2002.(
IWSA
2002)
Table
A­
1
summarizes
the
number
and
annual
capacity
of
these
units
by
type
of
technology
employed.

Table
A­
1.
MWCs
in
2002
Type
Number
of
Facilities
Annual
Capacity
(
million
Ton/
year
Mass
Burn
68
22.5
Refused
Derived
Fuel
(
RDF)
18
6.4
Modular
12
0.5
Total
98
29.4
As
the
capacity
values
indicate,
modular
units
are
generally
small
MWCs
accounting
for
less
than
a
total
of
2%
of
the
municipal
solid
waste
incinerated
in
the
U.
S.
in
2002.

A.
1.2
Hospital/
Medical/
Infectious
Waste
Incinerators
Although
earlier
reports
indicated
over
2200
medical
waste
incinerators
in
the
U.
S.
in
the
1990s
(
EPA
2000a),
the
current
EPA
Office
of
Air
Quality,
Planning,
and
Standards
(
OAQPS)
inventory
indicates
that
there
are
116
hospital/
medical/
infectious
waste
incinerators
(
HMIWIs)
in
the
U.
S.
as
of
July
28,
2003.
(
EPA
2003)

This
represents
a
greater
than
90%
reduction
in
the
number
of
operating
HMIWIs
in
the
U.
S.
Many
medical
waste
incinerators
were
closed
rather
than
upgraded
to
meet
new
emission
standards,
as
hospitals
improved
their
programs
to
segregate
infectious
("
red
bag")
waste
burned
in
HMIWIs
11
9/
12/
03
from
non­
infectious
("
black
bag")
waste
handled
as
municipal
solid
waste
after
it
leaves
the
hospital.

A.
2
Operating
Conditions
As
noted
by
EPA,
many
incinerators
for
municipal
solid
waste
are
designed
to
operate
in
the
combustion
zone
at
1800
°
F
[
982
°
C]
to
2000
°
F
[
1093
°
C]
to
ensure
good
combustion.
(
EPA
1995)
EPA
new
source
performance
standards
(
NSPS)
and
emission
guidelines
for
both
municipal
waste
combustors
(
MWCs)
and
hospital/
medical/
infectious
waste
incinerators
(
HMIWIs)
are
based
on
the
use
of
"
good
combustion
practices"
(
GCP).
(
EPA
1997,
EPA
2000b,
EPA
2000c,
Van
Remmen
1998)

Speaking
of
MWCs,
Donnelly
notes,
"
Design
of
modern
efficient
combustors
is
such
that
there
is
adequate
turbulence
in
the
flue
gas
to
ensure
good
mixing,
a
hightemperature
zone
(
greater
than
1000
o
C)
to
complete
burnout,
and
long
enough
residence
time
at
high
temperature
(
1­
2
sec)
for
complete
burnout."
(
Donnelly
2000)
The
term
"
flue
gas"
here
refers
to
the
gas
above
the
grate.

With
respect
to
HMIWIs,
Van
Remmen
states
"
any
unit
which
presently
[
prior
to
compliance
date]
has
a
[
secondary
chamber]
residence
time
less
than
two
seconds
at
1000
o
C
does
not
meet
the
requirement
for
good
combustion
under
the
new
regulations."
(
Van
Remmen
1998)

Similarly,
most
MWCs
are
expected
to
typically
operate
with
a
2
second
gas
residence
time
in
the
high
temperature
zone
in
order
to
assure
compliance
with
emission
standards
on
carbon
monoxide
and
dioxins.

A.
2.1
MWC
Operating
Conditions
EPA
presents
operating
data
for
some
MWCs
in
"
Municipal
Waste
Combustion
Assessment:
Technical
Basis
for
Good
Combustion
Practice"
and
points
the
reader
elsewhere
for
additional
data
on
specific
representative
MWCs.

Modular
MWC
Specifically,
this
background
document
(
EPA
1989)
includes
secondary
chamber
temperatures
for
modular
MWCs
that
had
CO
emission
levels
less
than
current
emission
standards,
and
these
are
summarized
in
Table
A­
2.
12
9/
12/
03
Table
A­
2.
Modular
MWC
Temperatures
Secondary
Chamber
Temperature
(
o
C)
Oswego
Co.,
NY
Red
Wing,
MN
Start
of
campaign
1012
Mid­
range
secondary
temperature
951
End
of
campaign
995
Low
secondary
temperature
885
Mean
secondary
temperature
954
­
1071
As
highlighted
in
Table
A­
2,
typical
secondary
chamber
temperatures
for
these
dual­
chamber
modular
units
are
in
the
range
of
951
to
1071
o
C.

As
indicated
in
section
A.
1,
such
modular
units
are
generally
small
MWCs
and
account
for
less
than
a
total
of
2%
of
the
municipal
solid
waste
incinerated
in
the
U.
S.

Although
this
1989
EPA
background
document
does
not
present
temperature
data
for
mass
burn
nor
RDF
units,
reports
from
the
National
Incinerator
Testing
and
Evaluation
Program
(
NITEP)
present
operating
data
for
an
RDF
combustor
(
Mid­
Connecticut)
and
for
a
mass
burn
waterwall
combustor
(
Quebec
City)
otherwise
discussed
in
the
1989
background
document.

RDF
MWC
Furnace
temperatures
and
flue
gas
oxygen
levels
for
Mid­
Connecticut
RDF
combustor
performance
tests
operating
under
good
combustion
conditions
across
a
range
of
steam
loads
(
Finklestein
and
Klicius
1994)
are
summarized
in
Table
A­
3.

Table
A­
3.
RDF
MWC
 
Mid­
Connecticut
Steam
load
Low
low
Intermediate
Intermediate
normal
normal
normal
high
test
number
PT­
13
PT­
14
PT­
10
PT­
02
PT­
09
PT­
08
PT­
11
PT­
12
Furnace
temperature
(
o
C)
965
1004
1012
1022
1033
1015
1026
1049
flue
gas
O
2
(%)
10.1
9.6
9.2
9.1
7.6
7.5
7.9
6.4
The
average
operating
conditions
for
this
RDF
unit
across
the
range
of
steam
loads
are
1016
o
C
and
8.4%
O
2.

Mass
Burn
MWC
Furnace
temperatures
(
average
of
front
and
rear
radiation
chamber
temperatures)
and
flue
gas
oxygen
levels
(
dry
basis)
for
Quebec
City
mass
burn
combustor
performance
tests
operating
under
good
combustion
conditions
across
a
13
9/
12/
03
range
of
steam
loads
(
Environment
Canada
1988)
are
summarized
in
Table
A­
4.

Table
A­
4.
Mass
Burn
MWC
 
Quebec
City
Steam
load
Low
low
Low
design
design
Design
High
high
test
number
PT02
PT10
PT11
PT05
PT06
PT12
PT07
PT09
Furnace
temperature
(
o
C)
849
875
869
1014
1030
992
1085
1006
flue
gas
O
2
(
dry)
13
13
12
9
9
10
10
10
The
average
operating
conditions
for
this
mass
burn
unit
across
the
range
of
steam
loads
are
965
o
C
and
10.8%
O
2.
When
operated
at
design
steam
load,
the
average
operating
conditions
for
this
mass
burn
MWC
are
1012
o
C
and
9.3%
O
2.

MWC
Summary
Considering
the
relative
quantities
of
municipal
waste
burned
annually
in
each
type
of
MWC
and
the
data
in
this
section,
average
typical
operating
conditions
for
the
high
temperature
zone
of
MWCs
are
nominally
1000
o
C
and
10%
O
2.

A.
2.2
HMIWI
Operating
Conditions
EPA
notes
that
over
97%
of
medical
waste
incinerators
are
controlled
air
modular
units
(
EPA
2000a).
Recent
communication
with
EPA
OAQPS
indicates
that
virtually
all
existing
HMIWIs
are
controlled
air
modular
(
two­
chamber)
units.

Theodore
reports
the
range
of
temperatures
for
the
secondary
chamber
of
controlled
air
medical
waste
incinerators
as
980
to
1200
o
C.
(
Theodore
1990)
EPA
notes
that
auxiliary
fuel
(
e.
g.,
natural
gas)
is
burned
in
the
secondary
chamber
of
medical
waste
incinerators
to
sustain
temperatures
in
the
range
of
985
to
1095
o
C
and
that
combustion
air
at
100
to
300
%
in
excess
of
the
stoichiometric
requirement
is
usually
added
to
the
secondary
chamber.
(
EPA
2000a)

As
noted
above,
a
more
recent
report
indicates
that
existing
HMIWIs
operate
with
secondary
chamber
temperatures
greater
than
or
equal
to
1000
oC
with
a
gas
residence
of
2
seconds.
(
Van
Remmen
1998)
14
9/
12/
03
References
Donnelly,
J.
R.
Waste
Incineration
Sources:
Municipal
Waste
Combustion.
In:
W.
T.,
ed.,
Air
Pollution
Engineering
Manual,
2nd
edition.
Air
and
Waste
Management
Association.
New
York,
NY:
Van
Nostrand
Reinhold,
2000,
pp
257­
268.

Environment
Canada.
National
Incinerator
Testing
and
Evaluation
Program:
Environmental
Characterization
of
Mass
Burning
Incinerator
Technology
at
Quebec
City
 
Summary
Report,
EPS
3/
UP/
5,
June
1988.

Environmental
Protection
Agency
(
EPA).
Municipal
Waste
Combustion
Assessment:
Technical
Basis
for
Good
Combustion
Practice,
EPA
600/
8­
89­
063,
August
1989.

EPA.
Emission
Factor
Documentation
for
AP­
42
Section
2.1,
Refuse
Combustion,
May
1993.

EPA.
Decision
Maker's
Guide
to
Solid
Waste
Management,
Volume
II,
Chapter
8,
1995.

EPA.
Standards
of
Performance
for
New
Stationary
Sources
and
Emission
Guidelines
for
Existing
Sources:
Hospital/
Medical/
Infectious
Waste
Incinerators,
62
Federal
Register
48346,
September
15,
1997.

EPA.
Exposure
and
Human
Health
Reassessment
of
2,3,7,8­
Tetrachlorodibenzo­
p­
Dioxin
(
TCDD)
and
Related
Compounds,
Part
I:
Estimating
Exposure
to
Dioxin­
Like
Compounds
Volume
2:
Sources
of
Dioxin­
Like
Compounds
in
the
United
States,
Chapter
3,
EPA/
600/
P­
00/
001Bb,
Draft
Final
Report,
September
2000.

EPA.
New
Source
Performance
Standards
for
New
Small
Municipal
Waste
Combustion
Units,
65
Federal
Register
76350,
December
6,
2000.

EPA.
Emission
Guidelines
for
Existing
Small
Municipal
Waste
Combustion
Units,
65
Federal
Register
76378,
December
6,
2000.

EPA.
HMIWI
Facility
and
Emissions
Inventory,
draft,
July
28,
2003,
www.
epa.
gov/
ttnatw01/
129/
hmiwi/
2003hmiwi_
inventory.
xls
15
9/
12/
03
Finklestein,
A.
and
R.
D.
Klicius.
National
Incinerator
Testing
and
Evaluation
Program:
The
Environmental
Characterization
of
Refuse­
derived
Fuel
(
RDF)
Combustion
Technology,
Mid­
Connecticut
Facility,
Hartford,
Connecticut,
EPA­
600/
R­
94­
140
(
NTIS
PB96­
153432),
December
1994.

Integrated
Waste
Services
Association
(
IWSA).
The
2002
IWSA
Directory
of
Waste­
to­
Energy
Plants,
2002,
www.
wte.
org/
2002_
directory/
IWSA_
2002_
Directory.
html
Theodore,
L.
Air
Pollution
Control
and
Waste
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for
Hospitals
and
Other
Medical
Facilities,
Van
Nostrand
Reinhold,
New
York,
1990,
pp
313­
320.

Van
Remmen,
T.
Evaluation
of
the
available
air
pollution
control
technologies
for
achievement
of
the
MACT
requirements
in
the
newly
implemented
new
source
performance
standards
(
NSPS)
and
emission
guidelines
(
EG)
for
hospital
and
medical/
infectious
waste
incinerators,
Waste
Management,
1998,
Vol.
18,
pp
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402
