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MEMORANDUM

DATE: May 26, 2014

SUBJECT: Development of the RTR Emissions Dataset for the Off-Site Waste and Recovery 

Operations Source Category

FROM: Lesley Stobert, EC/R Incorporated

TO: Paula Hirtz, EPA/OAQPS

The purpose of this memorandum is to provide information about the development of the risk 

and technology review (RTR) emissions dataset used to estimate residual risk for the Off-Site 

Waste and Recovery Operations (OSWRO) source category. 

1.0 BACKGROUND

Section 112 of the Clean Air Act (CAA) establishes a two-stage regulatory process to address 

emissions of hazardous air pollutants (HAPs) from stationary sources. In the first stage, section 

112(d) directs the EPA to develop technology-based standards for categories of industrial 

sources. 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).

In the second stage of the regulatory process, known as the RTR stage, CAA section 112(f)(2) 

directs the EPA to assess the health and environmental risks that remain after sources come into 

compliance with the MACT standards. If additional risk reductions are necessary to protect

public health with an ample margin of safety or to prevent adverse environmental effects, the 

EPA must develop standards to address these remaining 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 assess 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 screens for acute 

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

environmental effects. Chronic inhalation exposures and human health risks for cancer and 

noncancer endpoints are also estimated for the entire facility site (i.e., facility-wide assessment).

These baseline risk assessments were performed using a set of emissions and emissions-related 

data for the facilities in the OSWRO source category.
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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) Determination of the facilities that are subject to the OSWRO MACT standards;

2) Development of an initial dataset using information from the National Emissions 

Inventory (NEI), Toxics Release Inventory (TRI) and Environmental Information 

System (EIS);

3) Industry requested review of the preliminary dataset and incorporation of comments 

received into the dataset;

4) EPA-requested review of the preliminary dataset by states and local air agencies for 

certain facilities and incorporation of comments received into the dataset; and 

5) Data gathering 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

The baseline risk assessments were performed using 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 

Act (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, including 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. The facility list 

resulting from this process consisted of 52 facilities. This preliminary 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 IL
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Facility Name City ST

Safety-Kleen Systems, Inc. Dolton IL

Eli 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 TX
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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 National Emissions

Inventory (NEI) to create 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 52 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, including the 

MACT code, SCC, and specific HAP emitted, emissions records were assigned to the OSWRO 

source category. Generally, in making these assignments, where emissions were assigned by 

MACT code to another MACT source category, those emissions were not 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 quality 

assurance/quality control (QA/QC) procedures discussed below, 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 facilities report emissions. 

Some facilities are subject to the OSWRO MACT standards but comply with a related standard 
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(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 generally used to fill gaps in or replace the NEI data. For instance, if 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 longitude QA/QC

The latitude and longitude coordinates of the point source emissions release points in the dataset

were reviewed by plotting the emission points in Google Earth and verifying the location against 

satellite imagery. Fugitive area source locations were also reviewed using Google Earth by 

plotting the 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 source 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 stack and 

fugitive parameters that did not meet the EPA QA standards were corrected. 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 were 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 sources. 

Emission process group 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 was “Waste Disposal-Process Vents.” All other processes that could 
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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 identifying the types of equipment associated with any high risk results; however, the 

designation of process groups has no effect on the overall risk results because the emissions 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 Other 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 Emissions

Offsite Waste - Other 50400201 Waste Disposal Site Remediation General Processes 

Miscellaneous

Waste DisposalProcess 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, location (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, two facilities, Eli Lilly in Clinton, Indiana (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 received and incorporated for Rohm and Haas in 
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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 comments from Dow Chemical in Midland, Michigan, emissions of 

acetonitrile and methanol were reassigned 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 codes for these emissions were

revised to “NONE”. Minor revisions to HAP emissions from OSWRO processes were 

incorporated for Rohm and Haas in Louisville, KY and Dow Chemical in Freeport, Texas.

Lastly, Evonik Degussa provided updated process information that allowed for the correct 

assignment of acetonitrile emissions between the OSWRO and Pharmaceuticals Production 

source categories. Emissions information was received from Shell in Norco, Louisiana

(NEI16363); however, it was unclear which emissions were due to OSWRO processes, and the 

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 requested the assistance of the National Association of Clean Air 

Agencies (NACAA) and EPA Region 6 in contacting several states 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 following for each identified facility: an emissions 

inventory for the facility; details on the processes covered by OSWRO, including emissions 

estimates and other emissions information; and the Title V operating permit. 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 the processes covered; and emissions estimates and other emissions information. The 

specific list of facilities for which data were requested is shown in Table 3.

Table 3. Specific Facilities Identified for NACAA Review

Facility 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 NY
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Dow Chemical La Porte Operations La Porte TX

Boeing Commercial Airplane Group - Everett Everett 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

§63.683(b)(1)(iii) for material management units and §63.683(c)(1)(ii) for process vents, in 

which the owner or operator determines before placing off-site material in off-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 following this compliance option, the emissions standards §§63.683 

through 63.690 and §63.693 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 weight, so the equipment leak standards of §63.691 do not apply. The PSCAA did not 

provide any OSWRO emissions data, noting that Boeing does not provide any specific 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 substantial research would be required to verify applicability 

based on reviews of numerous case-by-case permits, and no permit or supporting information 

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 §63.683(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 were

added to the modeling dataset for these facilities.

2.5 CAA Section 114 Questionnaire

To better understand the processes, emissions, emissions release parameters and emissions 

control techniques for the OSWRO source category, the EPA collected information from 

industry through the authority of CAA section 114. In March 2013, the EPA developed and sent 

a questionnaire to nine companies that own or operate OSWRO facilities, and responses to the 

questionnaire were received for 24 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.
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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, stack 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 category for these facilities, and 2005 NEI data were used for 

the remaining operations at the facility site. However, in a few instances, the information 

received 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 Kimball, 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. One company, Clean 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. These facilities 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 Clean 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 

these two facilities, the NEI data were 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

Facility Name City State

Ash Grove Cement Company Foreman AR

Ash Grove Cement Company Chanute KS

Clean Harbors Environmental Services, Inc. El Dorado AR

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

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

Clean Harbors Environmental Services, Inc. Dolton IL

Clean Harbors Environmental Services, Inc. East Chicago IL

Clean Harbors Environmental Services, Inc. Coffeyville KS

Clean Harbors Environmental Services, Inc. Smithfield KY

Clean Harbors Environmental Services, Inc. Kimball NE

Clean Harbors Environmental Services, Inc. Hebron OH

Clean Harbors Environmental Services, Inc. Deer Park TX

Clean Harbors Environmental Services, Inc. Denton TX

Clean Harbors Environmental Services, Inc. Grantsville UT

Essroc Cement Corp. Logansport IN
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Facility Name City State

Giant Cement Company Harleyville SC

Keystone Cement Company Bath PA

Heritage - WTI, LLC East Liverpool OH

Hydrite Chemical Co. Cottage Grove WI

Phillips 66 Company Ponca City Refinery Ponca 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. None 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 (nonnapthalene) emissions are likely due to non-OSWRO combustion 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 dataset was used to perform the baseline risk assessments 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 available 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-site 

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 facilities. 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 of
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the CAA section 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, NonTSDF Treatment, Storage, Disposal Processes, 

Equipment Leaks 

Offsite Waste –

Containers 50310002

Waste Disposal, Solid Waste Disposal-Industrial, NonTSDF Treatment, Storage, Disposal Processes, 

Containers

Offsite Waste – Tanks 50310003 Waste Disposal, Solid Waste Disposal-Industrial, NonTSDF Treatment, Storage, Disposal Processes, Tanks

Offsite Waste – Oilwater separators 50310004

Waste Disposal, Solid Waste Disposal-Industrial, NonTSDF Treatment, Storage, Disposal Processes, Organic 

and Oil-Water Separators

Offsite Waste – Surface 

impoundments 50310005

Waste Disposal, Solid Waste Disposal-Industrial, NonTSDF Treatment, Storage, Disposal Processes, Surface 

Impoundments

Offsite Waste –

Transfer systems 50310006

Waste Disposal, Solid Waste Disposal-Industrial, NonTSDF Treatment, Storage, Disposal Processes, 

Transfer Systems

Offsite Waste – Process 

vents

50310007

Waste Disposal, Solid Waste Disposal-Industrial, NonTSDF Treatment, Storage, Disposal Processes, Process 

Vents
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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 

data
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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 TRI 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 identifieda

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 data
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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 identifiedb

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 data
15

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 reassigning 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 exemptions described above in section 2.4 of this document.
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3.0 DATASET 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 emissions 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 characteristics data for estimating the non-OSWRO processes 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 described in Section 2.2 of this document). 

Emissions of chromium and mercury were reported for some non-OSWRO processes at 

OSWRO facility sites. Chromium emissions were speciated into hexavalent and trivalent forms,

and mercury emissions were speciated into particulate 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 Classification 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.

As noted in Table 6, after redesignating metal HAP emissions as coming from nonOSWRO 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 Tulsa, 

OK (NEI40143EQOK). However, these facilities were included in the OSWRO RTR facilitywide emissions dataset, and the emissions 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 

rates for the OSWRO emission points were 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 in 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 “MACTallowable” emissions level. While the risk modeling was performed with the RTR emissions 

dataset described in Section 2 of this document, risks for the OSWRO source category were also 
17

estimated considering the emissions that would occur at the MACT-allowable emissions levels. 

For more information about the estimated MACT-allowable emissions and associated 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.