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2.2 NESHAP Requirements National emission standards for hazardous air pollutants (NESHAP)3 are established by EPA under the Clean Air Act (1990) and are based on the best available engineering and control practices for a given industrial source. This level of control is also referred to as Maximum Achievable Control Technology or MACT. The results from both the FF and TDF emission tests were well below applicable NESHAP requirements for PM and dioxins and furans, as shown in Table 3. When calculated in terms of pounds/ton of raw feed, PM emission rates were nearly identical (FF- 0.09; TDF - 0.10) for the two fuel tests. On a TEO basis, dioxins and furan emission rate was 0.02 ng/m3 for the FF test, which is approximately 10 times lower than the NESHAP requirement of 0.2 ng/m3. For the TDF emissions test, TCDD TEQ measurements were below the detection limit, which for the TDF runs was <0.02 ng/m3. 2.3 Unregulated Air Pollutants Relative differences in emission levels between the two tests varied by chemical class and by chemical but were very low in both cases. 2.3.1 Metals The emission rates for metals are summarized in Table 4. Most metal emission rates increased with TDF; the increases ranged from 8-165%. Only Co (-74%)and Ag (-25%) decreased with TDF. Although the percentage differences in metal emission rates may appear rather large in some cases, it is important to note that the actual emission rates involved are extremely small. This means that the actual difference in mass of material emitted over a year's time is only a few pounds per year. For example, the maximum increase in annual mass for any one metal was a little less than 18 pounds (zinc) and the total annual increase for all metals emitted by the use of TDF was less than 100 pounds. Typically, metal emissions contribute a small proportion (2-20 %) of the overall potential health risk based on risk assessments pertormed at other facilities; so, the magnitude of the increases observed with TDF are of no public health concern. 2.3.2 Hydrogen Halides Hydrogen Chloride (HCI) was the only hydrogen halide measured in these tests. The emission rate for HCI was approximately the same (0.6 Ib/hr) for both FF and TDF fuels. (Table 5). 2.3.3 Aldehydes/Ketones Formaldehyde and acetaldehyde are commonly measured in cement kiln emissions. TDF emissions were higher than FF emissions by a factor of 2 for formaldehyde and nearly a factor of 4 for acetaldehyde (Table 5). However, the very small emission rates for these two aldehydes during the FF test exaggerate these differences. The formaldehyde emission rates 10