1

M E M ORA N D U M

D A TE: May 2 6

, 2014

S UBJ E CT: De velopment of the RTR Emissions Dataset for the Off

- Site Waste and Recovery

Operations Source Category

F RO M : Lesley Stobert, EC/R Incorporated

TO: Paula Hirtz, EPA/OAQPS

The pur p ose o f this m e m o ra ndum i s to provide in f o r mation about the development of t he r isk

and t ec hno l o g y r e vi e w ( RTR) emissions d a taset used to estimate r e s idual r isk for the Off

- Site Waste and Recovery Operations (OSWRO) sou r c e ca t e gory.

1.0 BACKGROUND

S ec t i on 112 of the Cl ea n Air Ac t (CAA) e stablishes a tw o

- st a g e r e g ulato r y pro c e ss t o a dd r e ss

e m i ss i ons of h a z a rdous a ir pol l utants ( H APs) f r o m s t a t i on a r y sou r ce s. I n t he f irst s ta g e , s e c t i on 112( d ) directs the EPA to dev e lop t ec hnol o g y

- b a s e d st a nd a rds f o r c a t e g o r ies of industrial

sou rce s. This first stage of the regulatory process has been completed for the OSWRO source

category. The MACT standards for OSWRO were proposed on October 13, 1994 (59 FR 51913), promulgated on July 1, 1996 (61 FR 34140), and codified at 40 CFR part 63, subpart DD. The final rule was amended on July 20, 1999 (64 FR 38950).

I n the s ec ond st a g e of the regulatory process , kn o wn a s the RTR stag e , CAA se c t i on 112 ( f ) ( 2 )

directs the E P A to ass e ss t he h ea l t h a nd e nvironme n t a l risks that re main a ft e r s o u rce s co m e in t o

c omp l ian c e with the MACT standards

. I f a ddi t ional r isk r e du c t i ons a re n e ce ss a r y to prot ec t publ i c h ea l t h with an a m ple m a r g in of s a f e t y or to p re v e nt ad v e rse e nviro n ment a l e f f ec ts, the

E P A mu s t dev e lop s t a nd a rds to a d d r e ss t h e se r e maining risks. The EPA is also required to review the technology

- based standards and revise them “as necessary (taking into account developments in practices, processes, and control technologies)” no less frequently than every eight years , as directed by CAA section 112(d)(6)

.

To asse ss the residual risks, the EPA conducts baseline risk assessments (i.e., after the implementation of the respective MACT standards) that include estimates of chronic inhalation exposures and human health risks for cancer and noncancer endpoints, and screen s for acute health risks, chronic non

- inhalation health risks (i.e., multipathway exposures) , and adverse

environmental effects. C hronic inhalation exposures and human health risks for cancer and noncancer endpoints are also estimated for the entire facili ty site (i.e., facility

- wide assessment)

. T hese baseline risk assess m ents were p e rfor m ed us i ng a set of emissions and emissions

- related data for the facilities in the OSWRO source category.2

2.0 DEVELOPMENT OF THE OSWRO DATASET USED IN RESIDUAL RISK

MODELING

To develop a set of data that could be used in risk modeling for the OSWRO source category,

several data gathering steps were taken. These steps are described in the following sections and

include: 1) D etermin ation of the facilities that are subject to the OSWRO MACT standards ; 2) Development of an in itial dataset using information from the National Emissions Inventory (NEI), Toxics Release Inventory (TRI) and Environmental Information System (EIS ); 3) I ndustry requested review of the preliminary dataset and incor poration of comments

received into the dataset ; 4) EPA

- requested review o f the preliminary data set by states and local air agencies for

certain facilities and incorporation of comments received into the dataset ; and 5) D ata gather ing through a CAA section 114 questionnaire and incorporation of

information received into the dataset

.

In addition to these primary data gathering activities, quality assurance/quality control procedures were also undertaken to ensure data accuracy.

2.1 Preliminary Facility List

T he baseline risk assess m ents were p e rfor m ed us i ng a set of emissions and emissions

- related data for the facilities in the OSWRO source category. The starting point for this set of emissions

and emissions

- related data involved generating a list of facilities potentially subject to the

OSWRO MACT standards . The initial list, which included over 400 facilities across the United States, was developed from databases maintained for the Resources Conservation and Recovery

Ac t (RCRA) and the EPA’s Office of Enforcement and Compliance Assurance (OECA), as well

as from facility lists used in development of the original OSWRO MACT standards . The

facilities on the initial list were checked against additional EPA databases , includi ng the Envirofacts databases, and title V operating permit information to determine whether the facilities were subject to the OSWRO MACT standards and were still operating. T h e facility list resulting from this process consisted of 5 2 f ac i lities . This pre liminary list of facilities is shown

in Table 1.

Table 1. Preliminary OSRWO RTR Facility List

Facility Name City ST

Ash Grove Cement Foreman AR

Clean Harbors El Dorado El Dorado AR
FutureFuel Chemical Company Batesville AR
Pratt & Whitney East Hartford CT

Clean Harbors Services Inc. Chicago IL
Clean Harbors Recycling Services of Chicago Chicago IL3

Facility Name City ST

Safety

- Kleen Systems, Inc. Dolton IL

E li Lilly and Company

– Clinton Labs Clinton IN
Essroc Cement Corporation Logansport IN
Evonik Degussa Corp. Lafayette IN
Reclaimed Energy Company, Inc. Connersville IN
Tradebe Treatment and Recycling, LLC East Chicago IN
Ash Grove Cement Company Chanute KS

Clean Harbors PPM, LLC Coffeyville KS
Systech Environmental Corporation Fredonia KS

Marathon Petroleum Co., LLC Catlettsburg KY

Rohm and Haas Louisville KY
Safety

- Kleen Systems, Inc. Smithfield KY

Biolab, Inc. Westlake LA

Noranda Alumina, LLC Gramercy LA

Shell Chemical LP

– Norco Chemical Plant Norco LA

UOP, LLC Shreveport LA

EQ

- Belleville Belleville MI

Nortru, LLC Detroit MI
The Dow Chemical Company Midland MI
Continental Cement Company Hannibal MO
The Boeing Company St. Louis MO
Kodak Operations at Eastman Business Park Rochester NY
Norlite Corp. Cohoes NY
SI Group, Inc. Rotterdam Junction NY
Clean Harbors Recycling Services of Ohio Hebron OH
Heritage

- WTI, Inc. East Liverpool OH

Ross Incineration Services, Inc. Grafton OH
ConocoPhillips

– Ponca City Refinery Ponca City OK

EQ Oklahoma, Inc. Tulsa OK
Keystone Portland Cement/East Allen Bath PA
BASF Corporation Seneca SC

Giant Cement Co. Harleyville SC

Clean Harbors Deer Park La Porte TX
Dow Chemical La Porte Operations La Porte TX
Dow Texas Operations Freeport Freeport TX

Invista SARL Victoria TX4

Facility Name City ST

Safety

- Kleen Systems Denton Recycling Center Denton TX
Valero Port Arthur Refinery Port Arthur TX

Veolia ES Technical Solutions Port Arthur TX
Clean Harbors Aragonite/Safety Kleen Aragonite UT

Solite

– Main Plant Arvonia VA
US Navy Norfolk Naval Base

– Sewells Point Norfolk VA
Boeing Commercial Airplane Group

- Auburn Auburn WA

Boeing Commercial Airplane Group

- Everett Everett WA
Hydrite Chemical Co. Cottage Grove WI

WRR Environmental Services Co, Inc. Eau Claire WI

2.2 Initial Data Gathering

For the facilities shown in Table 1 , data were retrieved from the 2005 N a t i on a l Emis s ions

I n v e nto r y ( N E I ) to c r e a te a subset of the 2005 NEI that included facility, unit, process , release point, and emissions data. In the NEI, each HAP that is emitted from a distinct emissions point is associated with certain codes that are used to help categorize those emissions. Two of those codes are the MACT code and the source classification code (SCC). Generally, these codes can be used to apportion the emissions records to a particular source category. However, for the OSWRO source category, a MACT code exists, but was not widely used in the NEI (only one facility had any emissions with the OSWRO MACT code). Also, there are no specific SCCs for the OSWRO source category. While there are some SCCs that could potentially be associated with the OSWRO source category, such as those for industrial waste disposal, most of these SCCs for the OSWRO facilities in the NEI were related to waste incineration, which is not part

of the OSWRO source category. Title V operating permits for the 5 2 facilities were downloaded where the permits were available online. These permits were reviewed to understand the processes present, and based on this information, along with data from the NEI, i ncluding the MACT code, SCC, and specific HAP emitted, emissions records were assigned to the OSWRO

source category. G eneral ly

, in making these assignments , where emissions were assigned by MACT code to another MACT source category, those emissions were no t moved to the OSWRO source category, and only records with the OSWRO MACT code or a MACT code of “NONE” were assigned to the OSWRO source category. This set of data, after revisions from the q uality assurance/quality control ( QA/QC) procedures discussed b elow, formed the preliminary modeling dataset for the OSWRO source category.

QA/QC of the OSWRO source category data set

Modeling emissions QA/QC In some cases, it was difficult to determine whether emissions from a facility were emitted from OSWRO processes using the process described above due to the lack of the use of the OSWRO MACT code, lack of OSWRO

- specific SCCs and also due to the way facili ties report emissions. Some facilities are subject to the OSWRO MACT standards but comply with a related standard5

(e.g., NESHAP for Benzene Waste Operations)

, as allowed by the OSWRO MACT standards

, or

are not subject to the emissions standards due to the low HAP content of the off

- site waste they

receive.

In an effort to ensure emissions were assigned to the OSWRO source category wherever possible, an emissions summary was developed by HAP category name at the facility level for side by side comparison of emissions data from the 2005 NEI, 2008 EIS , and 2008, 2009, and

2010 toxics release inventory ( TRI )

. As the 2010 TRI contained the most recent data available,

these data were general ly used to fill gaps in or replace the NEI data . For instance, i f 2005 NEI emissions data did not exist for a distinct emission source and HAP at a facility, the 2010 TRI

data were used instead

. The 2010 TRI emissions data were also used in some instances where

SCC codes were non

- descriptive in the 2005 NEI. For two facilities, either 2005 NEI data or 2010 TRI data were not available, and 2008 EIS data were used to fill these gaps.

Latitude and l ongitude QA/QC

The latitude and longitude coordinates of the point source emission s release points in the dataset were reviewed by plotting the emission points in Google Earth and verif ying the location against satellite imagery. Fugitive area source locations were also reviewed using Google Earth by plotting t he latitude and longitude coordinates of the southwest corner of the source and then also plotting the area of the source, considering the length, width and angle of release (from true North). Emission sources with suspect locations (e.g., an emission sou rce that is not located over an industrialized area) were compared to the street address provided in the master file. In some cases, the street address indicated that the release point should be moved, and the emission

source was relocated to coincide with other emission sources with the same NEI ID, or the center of the property

.

Stack and fugitive parameter QA/QC

Quality assurance/quality control (QA/QC) checks of the data were performed, and sta c k a nd

f u g i t ive p a r a m e te r s that did not m ee t the E P A Q A stan d a r ds w e re c o r r ec ted. To verify the accuracy of stack flow rates, flow rates were calculated using the reported stack diameter and velocity and compared to the reported flow rate. If the calculated flow rate was more than 10

percent different from the reported flow rate, the calculated flow rate was used.

In some cases, OSWRO fugitive emission sources were reported without length, width, and angle values, and there w ere inadequate data to determine whether these sources were actually fugitive point or area sources. Rather than defaulting the length, width and angle properties, it was assumed that these emission sources were fugitive point sources. Where length, width and angle values were provided, it was assumed that these were fugitive area s ources.

Emission p rocess g roup QA/QC

The emission sources in the NEI data were divided into emission process groups using the SCC

codes supplied in the NEI

. The only emission process group that could be identified through

SCC codes in the NEI data wa s “ Waste Disposal

- Process Vents

. ” All other processes that could6

not be identified (i.e., processes associated with non

- descriptive SCC codes) were labeled

“Offsite Waste Other

. ” Assignment of emission process groups is typically done for the purpose

of id entifying the types of equipment associated with any high risk results; however, the designation of process group s ha s no effect on the overall risk results because the emission s and

emission source locations are not altered. Table 2 provides a list of SCCs that were assigned to the OSWRO emission process groups in the preliminary modeling dataset.

Table 2. Emissions Process Groups in the Preliminary OSWRO Modeling Dataset

Emission Process Group SCC SCC Description

Offsite Waste

- Other 30199998 Industrial Processes Chemical Manufacturing Other Not Classified Specify in Comments Field

Offsite Waste

- Other 39999992 Industrial Processes Miscellaneous Manufacturing

Industries Miscellaneous Industrial Processes Other Not

Classified

Offsite Waste

- Other 39999999 Industrial Processes Miscellaneous Manufacturing

Industries Miscellaneous Industrial Processes Other Not

Classified

Offsite Waste

- Other 49000199 Petroleum and Solvent Evaporation Organic Solvent Evaporation Solvent Extraction Process Othe r Not

Classified

Offsite Waste

- Other 50300603 Waste Disposal Solid Waste Disposal

- Industrial Landfill Dump Hazardous: Fugitive Emissions

Offsite Waste

- Other 50300701 Waste Disposal Solid Waste Disposal

- Industrial Liquid

Waste General

Offsite Waste

- Other 50300702 Waste Disposal Solid Waste Disposal

- Industrial Liquid

Waste Waste Treatment: General

Offsite Waste

- Other 50300801 Waste Disposal Solid Waste Disposal

- Industrial Treatment, Storage, Disposal/TSDF Surface Impoundment: Fugitive E missions

Offsite Waste

- Other 50400201 Waste Disposal Site Remediation General Processes

Miscellaneous Waste Disposal

Process Vents 30106099 Industrial Processes Chemical Manufacturing Pharmaceutical Preparations Other Not Classified

2.3 Industry Review

Upon the request of industry trade groups

, such as the American Chemistry Council (ACC), in 2012, an opportunity to review the preliminary modeling dataset for the OSWRO source

category for correctness of facility names, SCCs , MACT codes, emissions, locati on (latitude and longitude coordinates) and other modeling parameters was provided to industry . The industry proposed revisions were reviewed on a case

- by

- case basis and accepted where appropriate. From this review, t wo facilities, Eli Lilly in Clinton, In diana ( NEIIN12844 ) and Dow Chemical in LaPorte, Texas ( NEI12245 ) , were removed from the preliminary modeling

dataset based on industry comments that they are not subject to the OSWRO MACT. Suggested

revisions to the data for several facilities were receive d and incorporated for Rohm and Haas in7

Louisville, Kentucky ( NEI32966 ) ; Dow Chemical in Freeport, Texas ( NEI11295 ) ; Dow Chemical in Midland, Michigan ( NEI11906 ) ; and Evonik Degussa in Lafayette, Indiana
( NEI32342 )

. The revisions included updates to HAP emissions data, as well as facility process information that was used to assign emissions into or out of the OSWRO source category. Specifically, based on comment s from Dow Chemical in Midland, Michigan , emissions of

acetonitrile and methanol were re assigned from the OSWRO source category to other processes at the facility because the emissions were associated with a wastewater treatment plant that

processes waste originating from operations on

- site. The MACT code s for these emissions w ere revised to “NONE”. Minor revisions to HAP emissions from OSWRO processes were incorporated f

or Rohm and Haas in Louisville, KY and Dow Chemical in Freeport, Texas. Lastly

, Evonik Degussa provided updated process information that allow ed for the correct assignment of acetonitrile emissions between the OSWRO and Phar maceuticals Production source categories. Emissions information was received from Shell in Norco, Louisiana ( NEI16363 ) ; however, it was unclear which emissions were due to OS WRO processes , and th e modeling dataset was not revised for this facility

.

The EPA also contacted three facilities (Clean Harbors, in Hebron, OH (NEIOHT$5677), Essroc in Logansport, IN (NEI16354), and Heritage

- WTI in East Liverpool, OH (NEIOHT$5915) with specific questions regarding emissions or emissions release parameters. However, these facilities later received a CAA section 114 questionnaire , as discussed below , and the information from those responses superceded the OSWRO data in the preliminary modeling file and the information received from this request.

2.4 NACAA Review

On February 4, 2013, the EPA request ed the assistance of the National Association of Clean Air Agencies (NACAA) and EPA Region 6 in contacting several st ates for data review and information gathering for the OSWRO source category

. Specifically, the EPA requested to be provided with a list of facilities subject to the OSWRO NESHAP from all states in EPA Region 9 (AZ, CA, NV, HI) , and also requested the foll owing for each identified facility: an e missions inventory for the facility ; d etails on the processes covered by OSWRO, including emissions

estimates and other emissions information ; and the Title V operating p ermit. The EPA also requested that

, for a list of six specific facilities for which OSWRO emissions data were unquantified, each state review the facility (s) listed in their state and provide information regarding the following: whether the facility(s) are subject to the OSWRO NESHAP; details

about th e processes covered ; and emissions estimates a nd other emissions information. The specific list of facilities for which data w ere requested is shown in Table 3

.

Table 3 . Specific Facilities Identified for NACAA Review

F acility Name City State

Clean Harbors Environmental Services, Inc. El Dorado AR

FutureFuel Chemical Company Batesville AR

Shell Chemical LP

– Norco Chemical Plant Norco LA

SI Group, Inc. Rotterdam Junction NY8

Dow Chemical La Porte Operations La Porte TX

B oeing Commercial Airplane Group

- Everett E verett WA

Responses to this request were received from three state and local air agencies.

The Puget Sound Clean Air Agency (PSCAA) confirmed that the Boeing facility in Everett, WA ( NEIWA13120) is subject to the NESHAP. Based on information provided by PSCAA, the facility complies with the OSWRO MACT requirements by meeting the requirements of §63.6 83 (b )(1) (iii) for material management units and §63.6 83(c)(1)(ii) for process vents, in

which t he owner or operator determines before placing off

- site material in of

f

- site material management units and in equipment associated with a process vent that the average VOHAP

concentration of the off

- site material is less than 500 parts per million by weight (ppmw) at the point

- of

- delivery. By f

ollowing this compliance option, the emissions standards §§63.6 83 through 63.690 and §63.6 93 do not apply. In addition, none of the equipment components

contain or contact off

- site material having a total HAP concentration equal to or greater than 10% by w eight, so the equipment leak standards of §63.6 91 do not apply. T he PSCAA did not provide any OSWRO emissions data, noting that Boeing does not provide any s pecific emission

estimates for the off

- site material management unit in their annual emission reports to the

PSCAA

.

The Texas Commission on Environmental Quality (TCEQ) confirmed that the Dow Chemical facility in La Porte, TX ( NEI12245 ) is still operating, but indicated that the facility is not subject

to the OSWRO NESHAP because it does not meet the applicability criteria of § 63.680(a)(2)

. However, the TCEQ indicated that s ubstantial research would be required to verify applicability

based on reviews of numerous case

- by

- case permits , and no permit or supporting informatio n was provided to the EPA.

The Louisiana Department of Environmental Quality (LDEQ) confirmed that the Shell facility in
Norco, LA ( NEI16363) is subject to the NESHAP but noted the facility complies with the OSWRO MACT requirements by meeting the requirements of §63.6 83 (b )(1) (iii) for off

- site material management units. The LDEQ did not provide any OSWRO emissions data for this facility.

As no emissions or emissions

- related data were provided by these air agencies , no data w ere added to the modeli ng dataset for these facilities.

2.5 CAA Section 114 Questionnaire

To better understand the processes

, emissions

, emissions release param e ters and emissions control techniques for the OSWRO source category, the EPA collected information from industry through the authority of CAA s ection 114

. In March 2013 , the EPA developed and sent a questionnaire to nine companies that own or operate OSWRO fac ilities , and responses to the questionnaire were received for 2 4 facilities that are owned by those nine companies

. The facilities for which ICR responses were received are shown in Table 4

. The ICR responses received by the EPA are included in the docket for this action.9

The data received from these responses included the emissions and emissions release parameters for the OSWRO processes at the facilities that are required for risk modeling. These data were compiled

, and the same latitude and longitude, s tack parameter and fugitive parameter QA/QC procedures were conducted as described in Section 2.2 . In most cases, the data received in response to the CAA section 114 data request were used in place of the NEI /EIS/TRI data

attributed to the OSWRO source ca tegory for these facilities , and 2005 NEI data w ere u sed for the remaining operations at the facility site

. However, i n a few instances, the information

recei ved in response to the questionnaire resulted in a different action regarding inclusion in the OSWRO modeling dataset

. Three responses were for facilities that were not included in the preliminary facility list and data set, including Systech in Paulding, OH ( NEI11681) and Tulsa,

OK ( NEIOK4013107) and Clean Harbors in Kim ball, NE ( NEINE00009) . Data from the section 114 responses were used for the OSWRO processes at these facilities

, and NEI data for the remaining processes at the facility sites were added to the dataset for use in the facility

- wide modeling. O ne company , C lean Harbors , reported that its facility in Chicago, IL (Stony Island facility) ( NEI48888 ) , had closed and was demolished in 2012. Another facility, Clean Harbors in Coffeeville, KS ( NEIKS325 ) reported that it stopped processing off

- site wastes containing HAP

in 2010 . The s e facilit ies were removed from the dataset. Another facility, Phillips 66 in Ponca City, OK ( NEI12988) reported that it meets the facility

- wide exemption to the OSWRO MACT requirements and did not provide any OSWRO emissions data. The Clea n Harbors facility in Deer Park, TX ( NEI7162) provided emissions data only for volatile organic compounds, rather than speciated HAP emissions, and did not provide any emissions release characteristic data. For

th e s e two facilit ies , the NEI data w ere retained for the OSWRO processes, as well as for the other processes at the facility site.

Table 4 . Facilities Providing Responses to the CAA Section 114 Questionnaire

F acility Name City State

Ash Grove Cement Company Foreman AR

Ash Grove Cement Company Chanute KS

Clean Harbors Environmental Services, Inc. E l D orado AR

Clean Harbors Environmental Services, Inc. Chicago (Stony Island) IL

Clean Harbors Environmental Services, Inc. Chicago (West 42 nd Street) IL

Clean Harbors Environmental Services, Inc. Dolton IL

Clean Harbors Environmental Services, Inc. East Chicago IL

Clean Harbors Environmental Services, Inc. C offeyville KS

Clean Harbors Environmental Services, Inc. S mithfield KY

Clean Harbors Environmental Services, Inc. Kimball NE

Clean Harbors Environmental Services, Inc. Hebron OH

Clean Harbors Environmental Services, Inc. Deer P ark TX

Clean Harbors Environmental Services, Inc. Denton TX

Clean Harbors Environmental Services, Inc. G rantsville UT

Essroc Cement Corp. Logansport IN10

F acility Name City State

Giant Cement Company Harleyville SC

Keystone Cement Company Bath PA

Heritage

- WTI, LLC East L iverpool OH

Hydrite Chemical Co. C ottage Grove WI

Phillips 66 Company Ponca City Refinery P onca City OK

Systech Environmental Corporation Fredonia KS

Systech Environmental Corporation Paulding OH

Systech Environmental Corporation Tulsa OK

Tradebe Environmental Services, LLC East Chicago IN

After revising the modeling dataset to incorporate the CAA section 114 data, further QA/QC

review was performed of the entire modeling dataset

. From this review, it was noted that some facilities with NEI data for their OSWRO processes had HAP emissions that are not expected from this source category, including metal HAP , PAH (non

- naphthalene)

, and for one facility,

asbestos. N one of the facilities with CAA section 114 data for their OSWRO processes had any

emissions of metal HAP, PAH (non

- naphthalene ) or asbestos

. As metal HAP and PAH (non

napthalene) emissions are likely due to non

- OSWRO combu stion processes, and the CAA

section 114 data indicates that facilities do not emit these HAP from OSWRO processes, the modeling dataset was revised to reassign these HAP to other portions of the facilities (by reassigning the MACT code to “NONE” ) and were not included in the OSWRO emissions from

those facilities. Similarly , emissions of asbestos are not expected from OSWRO processes, and these emissions were assigned to other processes at the one facility with these emissions. Emissions of methyl ethyl ketone ( MEK) were also removed from the dataset since this chemical

is now a delisted HAP.

The resulting modeling data set was used to perform t he baseline risk assess m ents for the OSWRO source category. As shown in Table 6 , the OSWRO source category has 52 facilities that are subject to some portion of the OSWRO NESHAP, but the modeling dataset only

includes information for 38 facilities. The remaining 14 facilities were not included in the modeling file because the availab le information did not attribute any amount of HAP emissions that could be identified as being from OSWRO processes at these facilities. As shown in Table

6 , available permit information indicates that five of these 14 facilities are only subject to off

- si te waste HAP content determination requirements and are not subject to the emissions standards and other requirements of the OSWRO NESHAP due to the low amount of HAP in the off

- site waste accepted by these facil ities. Also, as noted in Table 6 , available permit data indicates that two additional facilities are not subject to the emissions standards and other requirements of the OSWRO NESHAP because they comply instead with 40 CFR 61 subpart FF, as allowed by the OSWRO NESHAP. For these seven facilities, we would not expect any emission points to be labeled as OSWRO emission points because those emission points are not subject to any

OSWRO MACT emissions standards.

As noted in section 2.2, there are no specific SCCs for the OSWRO source category. As part of11

the CAA s ection 114 questionnaire, to get a better understanding of the emissions that could be attributed to the various emissions process groups for the OSWRO source category, source category codes (SCCs) were developed for specific processes at OSWRO facilities. Facilities were asked to classify their OSWRO emissions with one of the SCCs shown in Table 5 for the purposes of identifying the types of equipment associated with any high risk results . These proposed SCCs have not yet been added to the published list of SCCs and may be revised during

final review.

Table 5 . SCCs Developed for the OSWRO Source Category

Emission Process Group SCC SCC Description

Offsite Waste

– Equipment Leaks 50310001 Waste Disposal, Solid Waste Disposal

- Industrial, Non

TSDF Treatment, Storage, Disposal Processes, Equipment Leaks

Offsite Waste

– Containers 50310002 Waste Disposal, Solid Waste Disposal

- Industrial, Non

TSDF Treatment, Storage, D isposal Processes,

Containers

Offsite Waste

– Tanks 50310003 Waste Disposal, Solid Waste Disposal

- Industrial, Non

TSDF Treatment, Storage, Disposal Processes, Tanks

Offsite Waste

– Oil

water separators 50310004 Waste Disposal, Solid Waste Disposal

- Industrial, Non

TSDF Treatment, Storage, Disposal Processes, Organic

and Oil

- Water Separators

Offsite Waste

– Surface impoundments 50310005 Waste Disposal, Solid Waste Disposal

- Industrial, Non

TSDF Treatment, Storage, Disposal Processes, Surface Impoundments

Offsite Waste

– Transfer systems 50310006 Waste Disposal, Solid Waste Disposal

- Industrial, Non

TSDF Treatment, Storage, Disposal Processes, Transfer Systems

Offsite Waste

– Process

vents 50310007 Waste Disposal, Solid Waste Disposal

- Industrial, Non

TSDF Treatment, Storage, Disposal Processes, Process

Vents12

Table 6 . List of OSWRO Facilities and Facilities Included in the OSWRO Source Category Modeling Dataset

NEI ID Facility Name City ST Facility in Modeling

File? Data Source/Notes

NEI13475 Ash Grove Cement Company Foreman AR Y CAA section 114 response

data

NEI880 Clean Harbors El Dorado El Dorado AR Y CAA section 114 response

data

NEI839 FutureFuel Chemical Company Batesville AR N No OSWRO data identified

NEICT1509 Pratt & Whitney East Hartford CT N No OSWRO data identified; facility exempt from DD requirements **

NEIIL03153 Clean Harbors Environmental Services, Inc. Chicago IL Y CAA section 114 response

data

NEIIL031069A Clean Harbors Environmental Services, Inc. Dolton IL Y CAA section 114 response

data

NEI16354 Essroc Cement Corp. Logansport IN Y CAA section 114 response

data

NEI32342 Evonik Degussa Corp. Lafayette IN Y NEI data

NEIIN423 Reclaimed Energy Company,

Inc. Connersville IN Y NEI & TRI data

NEIIN00345 Tradebe Environmental Services, LLC East Chicago IN Y CAA section 114 response

data

NEI16356 Ash Grove Cement Company Chanute KS Y CAA section 114 response

data

NEIKS325 Clean Harbors Environmental Services, Inc. Coffeyville KS N No longer processing off

- site waste containing HAP

NEI16355 Systech Environmental Corporation Fredonia KS Y CAA section 114 response

data13

NEI ID Facility Name City ST Facility in Modeling

File? Data Source/Notes

NEI32864 Marathon Petroleum Co., LLC Catlettsburg KY N No OSWRO data identified; facility exempt from DD requirements *

NEI32966 Rohm and Haas Louisville KY Y EIS data

NEIKY103236 Clean Harbors Environmental Services, Inc. Smithfield KY Y CAA section 114 response

data

NEILA0167 Biolab, Inc. Westlake LA N No OSWRO data identified; facility exempt from DD requirements **

NEILA0930002 Noranda Alumina, LLC Gramercy LA Y TR I data

NEI16363 Shell Chemical LP

– Norco

Chemical Plant Norco LA N No OSWRO data identified

NEI6007 UOP, LLC Shreveport LA N No OSWRO data identified; facility exempt from DD requirements **

NEIMILF450 EQ

- Belleville Belleville MI Y TRI data

NEIMIN0731 Nortru, LLC Detroit MI Y NEI data

NEI11906 The Dow Chemical Company Midland MI N No OSWRO data identified a

NEI34520 Continental Cement Company Hannibal MO N No OSWRO data identified; facility exempt from DD requirements *

NEI34632 The Boeing Company St. Louis MO N No OSWRO data identified; facility exempt from DD requirements **

NEINE00009 Clean Harbors Environmental Services, Inc. Kimball NE Y CAA section 114 response

data

NEI37022 Kodak Operations at Eastman

Business Park Rochester NY Y NEI data

NEI16605 Norlite Corp. Cohoes NY Y TRI data14

NEI ID Facility Name City ST Facility in Modeling

File? Data Source/Notes

NEI43353 SI Group, Inc. Rotterdam

Junction NY N No OSWRO data identified

NEIOHT$5677 Clean Harbors Environmental Services, Inc. Hebron OH Y CAA section 114 response

data

NEIOHT$5915 Heritage

- WTI, LLC East Liverpool OH Y CAA section 114 response

data

NEI40462 Ross Incineration Services, Inc. Grafton OH Y TRI data

NEI11681 Systech Environmental Corporation Paulding OH Y ICR data

NEI12988 Phillips 66 Company Ponca City Refinery Ponca City OK Y NEI & TRI data

NEI40143EQOK EQ Oklahoma, Inc. Tulsa OK N No OSWRO data identified b

NEIOK4013107 Systech Environmental Corporation Tulsa OK Y CAA section 114 response

data

NEI16665 Keystone Cement Company Bath PA Y CAA section 114 response

data

NEI41416 BASF Corporation Seneca SC Y TRI data

NEI16783 Giant Cement Company Harleyville SC Y CAA section 114 response

data

NEI7162 Clean Harbors Environmental Services, Inc. Deer Park TX Y NEI & TRI data

NEI11295 Dow Texas Operations Freeport Freeport TX Y NEI /Industry review data

NEI6481 Invista SARL Victoria TX Y NEI data

NEI7868 Clean Harbors Environmental Services, Inc. Denton TX Y CAA section 114 response data

NEI11200 Valero Port Arthur Refinery Port Arthur TX Y NEI data

NEI6631 Veolia ES Technical Solutions Port Arthur TX Y TRI data15

NEI ID Facility Name City ST Facility in Modeling

File? Data Source/Notes

NEIUT19459 Clean Harbors Environmental Services, Inc. Aragonite UT Y CAA section 114 response

data

NEI17512 Solite

– Main Plant Arvonia VA Y TRI data

NEI51710SEWELL US Navy Norfolk Naval Base

– Sewells Point Norfolk VA Y EIS data

NEIWA13117 Boeing Commercial Airplane Group

- Auburn Auburn WA N No OSWRO data identified; facility exempt from DD requirements **

NEIWA13120 Boeing Commercial Airplane Group

- Everett Everett WA N No OSWRO data identified; facility exempt from most DD requirements ***

NEI42539 Hydrite Chemical Co. Cottage Grove WI Y CAA section 114 response

data

NEI18116 WRR Environmental Services Co, Inc. Eau Claire WI Y TRI data

a After making changes based on industry review, the only OSWRO emissions remaining in the modeling dataset for this facility were metal HAP. After reassigning metal HAP from OSWRO source category emissions to other facility processes , this facility was left with no OSWRO emissions.

b The only OSWRO emissions in the modeling dataset for this facility were metal HAP. After re assigning metal HAP from OSWRO source category emissions to other facility processes

, this facility was left with no OSWRO emissions. * Based on the Title V operation permit, the only equipment subject to the OSWRO NESHAP is exempt from the OSWRO requirements because the equipment is also subject to 40 CFR 61 Subpart FF and the facility complies with the provisions of that subpart

. ** Based on the Title V permit, the facility meets the OSWRO facility

- wide exemption in § 63.680(d ).

*** OSWRO e xemptions described above in section 2.4 of this document.16

3.0 D ATASET FOR NON

- OSWRO SOURCE CATEGORY FACILITY EMISSIONS

While one RTR emissions dataset file was created that included only OSWRO process emissions, another file was created to include e missions from non

- OSWRO processes at OSWRO facility sites, along with the OSWRO process emissions, and these “facility

- wide”

emissions were modeled to put the OSWRO source category risks in context

. The emissions and

associated emissions release characteri stics data for estimating the non

- OSWRO process es risks

were obtained from the 2005 NEI. The same latitude and longitude, stack parameter and fugitive parameter QA/QC procedures were conducted as that conducted for the OSWRO source category data (as descri bed in Section 2.2 of this document).

Emissions of chromium and mercury were reported for some non

- OSWRO processes at OSWRO facility sites. C hromium e missions were speciated into hexavalent and trivalent forms

, and mercury emissions were speciated into p articulate divalent, gaseous divalent and elemental gaseous forms . The chemicals were speciated into these forms based on the speciation profiles developed for specific MACT codes

, SCCs and standard industrial classification/ North

American Industry Classif ication System (SIC/NAICS) codes for the NEI . These profiles can be found at the following website: http://www.epa.gov/ttn/chief/net/2005inventory.html#inventorydata

.

A s noted in Table 6 , after re designating metal HAP emissions as coming from non

OSWRO processes at the facility sites, two facilities did not have any remaining HAP attributed

to the OSWRO source category (Dow Chemical in Midland, MI ( NEI11906) and EQ in Tu lsa, OK ( NEI40143EQOK)

. However, these facilities were included in the OSWRO RTR facility

wide emissions dataset

, and the e missions were modeled and included in the facility

- wide risk assessment results. With the inclusion of these two facilities, 40 total facilities were included in

the OSWRO facility

- wide RTR emissions dataset and were included in the risk modeling.

4.0 ACUTE EMISSIONS

Emissions from equipment at OSWRO facilities can vary over time. In order to evaluate

the acute effects of these variations in the risk modeling

, the average annual hourly emission

rate s for the OSWRO emission points w ere determined based on the reported annual emission

values and were multiplied by a default factor of ten. For more information about the acute risk screening analysis, see the Draft Residual Risk Assessment for the Off

- Site Waste and Recovery Operations Source Category , which is available i n the docket for this action.

5.0 MACT

- ALLOWABLE EMISSIONS

The available emissions data in the RTR emissions dataset include estimates of the mass of HAP emitted during the specified annual time period. In some cases, these “actual” emission

levels are lower than the emission levels required to comply with the MACT standards. The emissions level allowed to be emitted by the MACT standards is referred to as the “MACT

allowable” emissions level. While the risk modeling was performed with the RTR emissions

datas et described in Section 2 of this document, risks for the OSWRO source category were also17

estimated considering the emissions that would occur at the MACT

- allowable emissions levels.

For more information about the estimated MACT

- allowable emissions and ass ociated risks , see the MACT

- Allowable Emissions for the Off

- Site Waste and Recovery Operations Source Category , which is available in the docket for this action.