1

MEMORANDUM

TO: Charlene Spells, Toni Jones, and Ketan Patel; U.S. En vironmental

Protection Agency

FROM: Danny Greene, Amber Allen, and Kristen James; Easter n Research Group,

Inc.

DATE: April 26, 2010

SUBJECT: Summary of the Secondary Impacts of Control Options for Proposed

CISWI Standards

1.0 PURPOSE This memorandum summarizes the secondary impacts assoc iated with control devices used to comply with the proposed standards for Commercial and Industrial Solid Waste Incineration (CISWI) units. Secondary impacts result f rom the consumption of fuel, water, and electricity and generation of solid wastes by control devices. Section 2.0 provides a background for the proposed standards and Section 3.0 pr esents the secondary impact estimates associated with control devices necessa ry for all units to comply with proposed standards.

2.0 BACKGROUND The U.S. Environmental Protection Agency (EPA), under sect ion 129 of the Clean Air Act (CAA), is required to regulate emissions of the fo llowing nine pollutants from Commercial and Industrial Solid Waste Incineration (CISW I) units: hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd), me rcury (Hg), particulate matter (PM), dioxins/furans (CDD/CDF), nitrogen oxides (NO x ), and sulfur dioxide (SO 2 ).

On December 1, 2000, EPA established new source performance st andards and emission guidelines for CISWI units under Sections 111 and 129 of the CA A. In 2001, EPA was granted a petition for reconsideration regarding the defi nitions of “commercial and industrial waste” and “commercial and industrial solid waste incineration unit.” Also in 2001, the United States Court of Appeals for the District of Columbia Circuit granted EPA’s voluntary remand, without vacature, of the 2000 rule. In 2005, EPA proposed and finalized the CISWI definition rule which revised the defi nitions of “solid waste,” “commercial and industrial waste,” and “commercial and industrial waste incineration unit.” In 2007, the United States Court of Appeals for the Di strict of Columbia Circuit vacated and remanded the 2005 commercial and industrial solid wa ste incineration definition rule.2

In response to the voluntary remand that was granted in 2001, the vacature, and remand of the CISWI definition rule in 2007, EPA developed proposed st andards for CISWI units. EPA’s solid waste definition rule proposes to define which non-hazardous secondary materials that are used as fuels or ingredient s in combustion units are solid wastes under Subtitle D of RCRA. In addition to the prim ary proposed approach set forth in the Solid Waste Definition rule, the rule solicits comments on an alternative approach for determining which secondary materials are solid waste under Subtitle D of RCRA, when combusted. In addition, the proposed standards include t he 5-year technology review of the new source performance standards and emissi on guidelines required under Section 129. The EPA has developed a series of maximum achi evable control technology (MACT) floor options for the “proposed appro ach” and the “alternative approach” to support proposal. The development of the MACT floors used to determine these options is discussed in more detail in a separat e memorandum. 1

3.0 SUMMARY OF S ECONDARY I MPACT E STIMATES To comply with the proposed standards, facilities may ne ed to install the following types of controls on CISWI units:

• Wet scrubbers (WS) to reduce HCl and SO 2 emissions,

• Fabric filters (FF) to reduce Cd, Pb, and PM emissions,

• Selective non-catalytic reduction (SNCR) systems to re duce NO x emissions,

• Activated carbon injection (ACI) systems to reduce CDD/ CDF and Hg emissions, and

• Afterburner retrofits, tune-ups, or oxidation catalysts t o reduce CO emissions.

Additional electricity is required to operate the pumps a nd fans associated with wet scrubbers, FF, and SNCR systems. Also, water and subseque nt wastewater disposal are required to operate wet scrubbers and SNCR systems. Activa ted carbon injection systems require activated carbon as well as a method to dispose of the dust produced from the ACI system.

The algorithms used in the cost analysis provide annual cost estimates for electricity, water, and carbon requirements as itemized components of the annual costs for the control device. 2 These cost elements for the control devices anticipa ted to be installed to comply with the proposed standards were then summed up to pr ovide an estimate of the overall costs of electricity, water and activated car bon. To estimate the secondary impact components (e.g., electricity, water, dust from carbon), the itemized annual cost of each component was divided by the unit price of the component util ized by the algorithm.

Two control scenarios were considered for the proposed sta ndards. In the first scenario, each CISWI unit in all subcategories comply with the pr oposed MACT floor standards by installing the anticipated control devices and associated mo nitoring equipment. Table 3-1 shows the estimated values for secondary impacts for Sc enario 1.3

T ABLE 3-1. Secondary Impacts for MACT Compliance

Subcategory Controls

Required for Compliance Electricity

Required (MW h/yr) Water

Required (gal/yr) Activated

Carbon Required (ton/yr) Dust

Produced (ton/yr)
Burn-Off Ovens WS, FF, SNCR 86 1,040,789 0 0 Waste-burning Kilns FF 41,653 0 0 0
Energy Recovery Units FF, WS, SCNR, ACI 229,801 68,368,392 10,860 10,860

Incinerators FF, WS, SCNR, ACI 7,770 166,169,443 575 575

Small Remote Units FF, ACI 139 0 10 10

Total 279,450 235,578,624 11,445 11,445

The second scenario entails a situation where faciliti es considered alternative disposal options and, where the alternative disposal methods ar e less expensive than adding control devices to comply with the proposed standards, w ould instead cease burning waste and use alternative disposal methods. In addition to the electricity, water, and activated carbon requirements for those facilities th at choose to add control devices to comply with the proposed standards, secondary impacts als o occur when alternative waste-handling methods are used. For all incinerators and the majority of small, remote units, it would be less expensive to send waste to a land fill than to comply with the proposed limits (i.e., facilities would choose to shut d own CISWI units). According to our estimates based on unit capacities and annual operating h ours, this would result in approximately 205,801 tons per year of additional waste being s ent to landfills. This would also result in subsequent landfill gas emissions f rom decomposition of this waste, which would likely be sent to a landfill gas flare. This gas flaring would result in emissions of NO x and CO, with some SO 2 , PM, and small amounts of mercury also being emitted. Further details on landfill emissions can be found in a separate memorandum. 3 While not quantified in our analysis, there are also like ly to be secondary emissions associated with the transport of the waste to a landf ill site. These emissions would be site-specific and depend primarily on the number of trips, t ype of vehicle, and distance traveled necessary to transport the waste to the landfil l. Likewise, facilities using burnoff ovens may choose to use alternative surface preparat ion or part cleaning techniques, such as abrasive blasting, instead of adding control devices to comply with the proposed rule. In our cost analysis, 2 we predict that 21 burn-off ovens will likely opt to util ize an abrasive blasting to comply with the proposed rule. While the spent blasting media will be disposed of in a landfill, we do not have data availa ble to quantify what this amount of waste would be. We expect, though, that the spent blastin g media would likely be4

aluminum oxide, glass beads, or silica sand, and therefor e would be biologically inert in the landfill and would not contribute to landfill emissi ons.

Table 3-2 shows the estimated values for secondary impacts resulting from each facility choosing the lowest-cost option for its units. Detail s regarding the unit-specific, lowestcost options can be found in the compliance cost memor andum. 2

T ABLE 3-2. Secondary Impacts for Lowest Cost Options

Subcategory Controls

Required for Compliance Electricity

Required (MWh/yr) Water

Required (gal/yr) Activated

Carbon Required (ton/yr) Dust

Produced (ton/yr) Annual

Waste Diverted to Landfill (tpy) Burn-Off Ovens WS, FF,

SNCR 1.1 32,131 0 0 0

Wasteburning Kilns FF 41,653 0 0 0 0

Energy Recovery Units FF, WS,

SCNR, ACI 229,801 68,368,392 10,860 10,860 0

Incinerators FF, WS,

SCNR, ACI 0 0 0 0 200,095

Small Remote Units FF, ACI 0 0 0 0 5,706

Total 271,455 68,400,522 10,860 10,860 205,801

R EFERENCES 1. “MACT Floor Analysis for the Commercial and Industri al Solid Waste Incinerators Source Category” Memorandum from Jason Huckaby, Amber A llen and Kristen James, Eastern Research Group, Inc. to Charlene Spells, Toni J ones and Ketan Patel, U.S. Environmental Protection Agency. April 26, 2010.

2. “Compliance Cost Analyses for CISWI Units” Memora ndum from Jason Huckaby, Amber Allen and Kristen James, Eastern Research Group, I nc. to Charlene Spells, Toni Jones and Ketan Patel, U.S. Environmental Protection Ag ency. April 28, 2010.

3. “Baseline Emissions and Emissions Reductions Estimates f or Existing CISWI Units” Memorandum from Jason Huckaby, Amber Allen a nd Kristen James, Eastern Research Group, Inc. to Charlene Spells, Toni J ones and Ketan Patel, U.S. Environmental Protection Agency. April 28, 2010.