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MEMORANDUM 

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

Protection Agency

FROM: Danny Greene, Amber Allen, and Kristen James; Eastern 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 associated with control devices 

used to comply with the proposed standards for Commercial and Industrial Solid Waste 

Incineration (CISWI) units. Secondary impacts result from 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 presents the secondary 

impact estimates associated with control devices necessary for all units to comply with 

proposed standards. 

2.0 BACKGROUND

The U.S. Environmental Protection Agency (EPA), under section 129 of the Clean Air 

Act (CAA), is required to regulate emissions of the following nine pollutants from 

Commercial and Industrial Solid Waste Incineration (CISWI) units: hydrogen chloride 

(HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd), mercury (Hg), particulate 

matter (PM), dioxins/furans (CDD/CDF), nitrogen oxides (NOx), and sulfur dioxide 

(SO2). 

On December 1, 2000, EPA established new source performance standards and emission 

guidelines for CISWI units under Sections 111 and 129 of the CAA. In 2001, EPA was 

granted a petition for reconsideration regarding the definitions 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 definitions of “solid waste,” 

“commercial and industrial waste,” and “commercial and industrial waste incineration 

unit.” In 2007, the United States Court of Appeals for the District of Columbia Circuit 

vacated and remanded the 2005 commercial and industrial solid waste incineration 

definition rule. 

 
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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 standards for CISWI 

units. EPA’s solid waste definition rule proposes to define which non-hazardous 

secondary materials that are used as fuels or ingredients in combustion units are solid 

wastes under Subtitle D of RCRA. In addition to the primary 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 the 5-year technology 

review of the new source performance standards and emission guidelines required under 

Section 129. The EPA has developed a series of maximum achievable control 

technology (MACT) floor options for the “proposed approach” 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 separate memorandum.1 

3.0 SUMMARY OF SECONDARY IMPACT ESTIMATES 

To comply with the proposed standards, facilities may need to install the following types 

of controls on CISWI units: 

• Wet scrubbers (WS) to reduce HCl and SO2 emissions, 

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

• Selective non-catalytic reduction (SNCR) systems to reduce NOx emissions, 

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

and 

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

Additional electricity is required to operate the pumps and fans associated with wet 

scrubbers, FF, and SNCR systems. Also, water and subsequent wastewater disposal are 

required to operate wet scrubbers and SNCR systems. Activated 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 anticipated to be installed to 

comply with the proposed standards were then summed up to provide an estimate of the 

overall costs of electricity, water and activated carbon. 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 utilized by the algorithm. 

Two control scenarios were considered for the proposed standards. In the first scenario, 

each CISWI unit in all subcategories comply with the proposed MACT floor standards by 

installing the anticipated control devices and associated monitoring equipment. Table 3-1 

shows the estimated values for secondary impacts for Scenario 1. 
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TABLE 3-1. Secondary Impacts for MACT Compliance

Subcategory 

Controls 

Required for 

Compliance 

Electricity 

Required 

(MWh/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 facilities considered alternative disposal 

options and, where the alternative disposal methods are less expensive than adding 

control devices to comply with the proposed standards, would instead cease burning 

waste and use alternative disposal methods. In addition to the electricity, water, and 

activated carbon requirements for those facilities that choose to add control devices to 

comply with the proposed standards, secondary impacts also 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 landfill than to comply with the 

proposed limits (i.e., facilities would choose to shut down CISWI units). According to 

our estimates based on unit capacities and annual operating hours, this would result in 

approximately 205,801 tons per year of additional waste being sent to landfills. This 

would also result in subsequent landfill gas emissions from decomposition of this waste, 

which would likely be sent to a landfill gas flare. This gas flaring would result in 

emissions of NOx and CO, with some SO2, 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 likely to be secondary emissions 

associated with the transport of the waste to a landfill site. These emissions would be 

site-specific and depend primarily on the number of trips, type of vehicle, and distance 

traveled necessary to transport the waste to the landfill. Likewise, facilities using burnoff ovens may choose to use alternative surface preparation 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 utilize 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 available to quantify what this amount of 

waste would be. We expect, though, that the spent blasting media would likely be 
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aluminum oxide, glass beads, or silica sand, and therefore would be biologically inert in 

the landfill and would not contribute to landfill emissions. 

Table 3-2 shows the estimated values for secondary impacts resulting from each facility 

choosing the lowest-cost option for its units. Details regarding the unit-specific, lowestcost options can be found in the compliance cost memorandum.2

 

TABLE 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 

 

REFERENCES

1. “MACT Floor Analysis for the Commercial and Industrial Solid Waste Incinerators 

Source Category” Memorandum from Jason Huckaby, Amber Allen and Kristen James, 

Eastern Research Group, Inc. to Charlene Spells, Toni Jones and Ketan Patel, U.S. 

Environmental Protection Agency. April 26, 2010. 

2. “Compliance Cost Analyses for CISWI Units” Memorandum from Jason Huckaby, 

Amber Allen and Kristen James, Eastern Research Group, Inc. to Charlene Spells, Toni 

Jones and Ketan Patel, U.S. Environmental Protection Agency. April 28, 2010. 

3. “Baseline Emissions and Emissions Reductions Estimates for Existing 

CISWI Units” Memorandum from Jason Huckaby, Amber Allen and Kristen James, 

Eastern Research Group, Inc. to Charlene Spells, Toni Jones and Ketan Patel, U.S. 

Environmental Protection Agency. April 28, 2010.