PFPI-BiomassIsTheNewCoal-April-2-2014

developmental and reproductive effects in rats and mice. A study by the National Toxicology Program (NTP)showed that DEHP administered orally increased the incidence of liver tumors in rats and mice. EPA hasclassified DEHP as a Group B2, probable human carcinogen.” 142Although a variety of the waste-derived fuels approved by EPA contain plastics, of the comfortletters we reviewed, the letter about SpecFUEL was the only one that referenced phthalatecontent. One large source of DEHP is the blue nitrile gloves used for medical exams and otherpurposes, suggesting that Waste Management may be using medical waste for making its SpecFUELproduct. Waste Management reported to EPA that the concentration of DEHP in SpecFUEL cubesis 240 – 1,410 parts per million, but because there are no data on levels of this contaminant in coalor wood to which the SpecFUEL levels could be compared, EPA simply declared that the fuel metthe legitimacy criterion for DEHP.Waste Management also reported the SpecFUEL concentration of fluorine, a toxic substanceemitted as hydrogen fluoride gas when burned, as 585 – 1,070 parts per million, significantlyexceeding the reported level in coal, which according to EPA’s data can reach 178 parts per million(Table 10). However, EPA glossed over the excessive fluorine content when it approved theSpecFUEL product, arguing that because combined, concentrations of fluorine and chlorine togetherwere within the ranges found for the most contaminated coals, the high fluorine content inSpecFUEL did not cause it to fail the legitimacy test.Table 10: Levels of fluorine in SpecFUEL exceed levels in coalHalogenUnitsAverageRangeSpecFUEL 1 Coal 1 Wood 1 SpecFUEL 2 Coal 2 Wood 2Chlorine ppm 2033 992 259 1840 - 2250 ND - 9080 ND - 5400Fluorine ppm 892 64 32.4 585 - 1070 ND - 178 ND - 300Total Halogens 3 ppm 2925 1056 291 2425 - 3320 ND - 9080 ND - 5497Notes:l. SpecFUEL data represents five samples taken on different days in January 2012, provided by WasteManagement on March 16, 2012..2. Data for coal and wood (i.e., clean wood and biomass materials) from a combination of EPA data andliterature sources, as presented in EPA document Contaminant Concentrations in Traditional Fuels: Tablesfor Comparison, November 29,2011, available at www.epa.gov/epawaste/nonhaz/define/index.htm.3 The high and low ends of each individual halogen's range do not necessarily add up to total halogensrange. This is because maximum and minimum concentrations for individual halogens do not alwayscome from the same sample.Table 10. Re-creation of Table 3 (“Contaminant Comparison, Total Halogens Group”) from EPA comfort letter toWaste Management, approving use of SpecFUEL as a “non-waste fuel product.”142http://www.epa.gov/ttnatw01/hlthef/eth-phth.html64