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~ PCCD/F's are a complex mixture of 210 of these dioxins and furans. Al] dioxin or futon isomers with <br />the same number of chlorine atoms belong to the same homologue group. For example, all <br />polychlorinated dioxins with the same number of chlorine atoms, i.e. 4, belong to the <br />tetrachlorodibenzo-p-dioxin homologue. The seventeen PCDD/F isomers with chlorine atoms in the <br />_~ 2,3,7 and 8 positions (at the outside of ends of the "bow tie" made up of hvo benzene rings held <br />together by 2 oxygen bonds -dioxins, or acarbon-carbon and an oxygen bond -furans) all belong to <br />the so-called toxic dioxins, sometimes referred to as the "dirty seventeen". <br />.9ppend& B contains technical papers which support the case that toxic dioxins could not have <br />formed in any significant quantity from the heating in the kiln. <br />Paper 1 - ASME (American Society of Mechanical Engineers) Reseazch Report titled The <br />1 Relationship Between Chlorine in Waste Stream and dioxin Emissrons From Waste Combustor <br />Stacks. In this report, municipal waste combustors and cement kilns were tested for PCDD/F <br />production as a function of chlorine content in the feed material. It was found that there is absolutely <br />no correlation between the two. <br />Paper -2 -Dioxin Emissions from Full Scale Hazardous Waste Combustion Units Handling Variable <br />1 Chlorine Feed Compositions, by Dow Chemical Company. This report also concludes that there is no <br />relationship between chlorine in the feed and PCDD/F production. In fact, the article states that based <br />on the evidence, it could be argued that PCDD/F decreases as the chlorine in the feed increases. This <br />contradicts the notion that the 2,4-D, could have produced toxic dioxins in significant quantities, <br />even though chlorine is a component of 2,4-D. <br />Paper 3 -Trace Chemistries of Fire, published in October 1980 issue of Science, shows that very <br />minor amounts of chlorinated dioxins are produced from a wide variety of sources, including <br />incinerators, soot from fireplaces, mufflers, wastewater treatment sludge, etc. The data indicate that <br />minor amounts of chlorinated dioxins exist in the particulate matter from the burning of most types <br />of organic matter. The paper also states that chlorinated dioxins form from trace chemical reactions <br />in the burning and have nothing to do with chlorine content. <br />Based on the information above, the data indicate that the heating of 2,4-D would produce no more <br />dioxins than the burning of any other organic material. These amounts are very low and <br />~ inconsequential to the environment. The following paper (Paper 4) shows that the potential dioxin <br />formed from burning 2,4-D is non-toxic. Furthermore, this study indicates that trace amounts could <br />be formed (and deposited in the bag house dust) from B&B's normal asphalt production process. <br />B&B is allowed under it's CDOH permit to heat petroleum laden gravel in the making of asphalt. <br />Therefore, even if the dust were sampled and dioxin found, it would add little useful information, <br />1 because the source of the dioxin could not be determined. <br />Paper 4 -Combustion of Herbicides, by Dr. Frank Dost, Professor of Toxicology at Oregon State <br />l University. This paper discusses the potential for toxic products of combustion of herbicides <br />12 <br />