MEMORANDUM

TO: Toni Jones , U.S. Environmental Protection Agency

FROM: E astern R esearch G roup , Inc.

DATE: November 26 , 2012

SUBJECT: Final Reconsideration Baseline Emissions and Emissions Reductions Estimates

for Existing CISWI Units

B ACKGROUND

The U.S. Environmental Protection Agency (EPA), under section 129 of the Clean Air Act (CAA), is required to regulate emissions of nine pollu tants from Commercial and Industrial Solid
Waste Incineration ( CISWI ) units : hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd), m ercury (Hg), particulate matter (PM), dioxins/furans ( P CDD/ P CDF), nitrogen oxides (NO

x ), and sulfur dioxid e (SO 2 ).

On December 1, 2000, EPA adopted new source performance standards and emission guidelines
for commercial and industrial solid waste incineration units established under Sections 111 and
129 of the Clean Air Act. 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." In 2001, the United States Court of Appeals for the District of Columbia
Circuit granted E PA’s voluntary remand, without vacatur, of the 2000 rule. In 2005, EPA proposed and finalized the commercial and industrial solid waste incineration definition rule
which revised the definition s of “solid waste,” “ commercial and industrial waste, ” and

“ co mmercial 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.

On March 21, 2011, the E PA promulgated revised NSPS and EG as its response to the voluntary remand that was granted in 2001 and the vacatur and remand of the commercial and industrial solid waste incineration definition rule in 2007. In addition, the standards re

- development

inc luded the 5

- year technology review of the new source performance standards and emission guidelines required under Section 129. Following that action, the Administrator received petitions for reconsideration and identified some issues that warranted furthe r opportunity for public comment. In addition, data were received that enabled the EPA to revise the CISWI inventory of waste

- burning kilns and energy recovery units to more accurately reflect the

definition of non

- hazardous secondary materials. On Decem ber 23, 2011

, the EPA published proposed amendments that incorporated these changes and allowed public comment on specific

issues identified for reconsideration. The development of the MACT floors used to determine
these options is discussed in more detai l in a separate memorandum

. 1 The purpose of this
memorandum is to present baseline emissions estimates for existing sources and anticipated emissions reductions that would result from compliance with the final standards.

This memo is organized as follows:

I. Emissions Reductions SummaryII. Baseline Emissions
III. MACT Floor Emissions

IV. Lowest Cost Floor Emissions

V. New Sources

I. Emissions Reductions Summary

The current population of CISWI units is estimated to consist of 10 6 units. Th is population represents the estimate of CISWI units that would still be burning waste materials upon implementation of the rule. Waste

- burning kilns that are considered " waste

- burning” solely due to burning whole tires are assumed to be able to find a so urce of whole tires that would not be
considered a waste ( whole tires obtained from approved tire management programs and tire

derived fuel from whi ch the metal has been removed are not considered solid waste under the
definition of solid waste ) prior to i mplementation, and would thus be subject to the provisions of
the Portland Cement NESHAP instead of CISWI.

Emissions reductions for the CISWI units were calculated for each of the nine pollutants (plus particulate matter less than 2.5 microns (PM 2.5 )) for two scenarios: 1) Assuming each existing unit complied with the final emissions limits, and 2) Assuming that units would comply using the lowest cost alternative, either complying with the emission limits or ceasing to use the
combustion device and u tilizing less costly alternatives, such as landfilling solid waste materials.

Under the first scenario (MACT Floor Emission Reductions), we estimate 34,7 71 tons per year of emissions would be reduced, consisting of 772 tons of HCl, 20,09 3 tons of CO, 2. 5 tons of Pb,

1.8 tons of Cd, 0. 34 tons of Hg, 2, 397 tons of PM, 0. 00006 tons of P CDD/ P CDF, 5,292 tons of

NO

x , and 6,211 tons of SO 2 . Under the second scenario (Lowest Cost Alternative Emissions Reductions), we estimate 34,9 09 tons per year of emissions wo uld be reduced, consisting of 7 8 4 tons of HCl, 20,05 8 tons of CO, 2. 5 tons of Pb, 1.8 tons of Cd, 0. 34 tons of Hg, 2, 4 01 tons of PM,

0. 00006 tons of P CDD/ P CDF, 5,399 tons of NO

x , and 6,262 tons of SO 2

.

Table 1 presents the anticipated emissions reductions by subcategory assuming all units remain operating and comply with the final emission limits. Table 2 presents the anticipated emissions reductions by subcategory assuming units either comply or cease operation and use alternative disposal methods, depending on which option costs less. Table 2 also includes estimates of secondary air emissions that would result from landfilling the diverted waste materials and flaring the landfill gas that these wastes would generate.

II. Baseline Emissions

Baseline emissions represent the estimated annual emissions of existing units prior to retrofit of controls to comply with the final emission limits.

Calculation Methodology. Annual emissions estimates are calculated using the pollutant concentration (mass per stack gas volume) multiplied by the flue gas flow rate (dry standard cubic feet per minute) and the time (hours per year) the unit is operated. Appendix A presents the calculations needed to convert from the standard pollutant concentrations to the annual tons
emitted.

Pollutant Concentration data. Pollutant concentration data measured from emissions tests for the
unit were used whenever available. When there were da ta gaps, these were filled first by usingthe same measured data from similar units operated by the corporate entity. If these data were not available, then subcategory default values were assigned for the unit. These default values were

the mean of the actual emissions test values measured for the units within a subcategory.

Flue Gas Flow Rate and Operating Hours. The flue gas flow rate and annual operating hours used to calculate emissions were similar to those that were used as inputs for control co sting algorithms. Each unit’s baseline emissions are based on unit average test data for each pollutant. Actual emissions test data and survey data from the CISWI database were used whenever available. Similar unit values were used if there were any data gaps for a similar unit operated by the entity. Lastly, F

- factor estimates or subcategory default values were applied as necessary to fill in the remaining gaps in flue gas flow rates. The flue gas flow rate data gap filling procedures

are discussed in more detail in the control costing memorandum. 2

Table 3 presents the baseline concentration, hours of operation, stack gas flow rate, and annual
emissions estimates for each of the CISWI units.

III. MACT Floor Emissions

MACT floor emissions are the es timated annual emissions that would result from CISWI units complying with the MACT floor emissions limits. These were calculated using the same equations that were used for the baseline emissions that are listed in Appendix A. However, the
final MACT fl oor emissions limit is used as the pollutant concentration if the baseline
concentration exceeds the final limit value. If a unit’s baseline pollutant concentration is below

the final emissions limit, then that concentration was used to calculate the MACT floor emissions as well (i.e., no backsliding or emissions increases would occur). Additionally, for units expected to require the addition of fabric filters to meet one or more pollutant limits, a reduction efficiency of 99% was applied to their baseline values for Cd, Pb,and PM to determine their MACT floor emissions for these pollutants to fully account for the co

- control for all of these pollutants due to the addition of a high

- efficiency fabric filter.

Table 4 presents the estimated MACT floor emissi ons for each unit as described above. Hours of operation and stack gas flow rates used to determine tons per year are also included. Table 5 puts the baseline and MACT floor emissions estimates together and presents the annual emissions

reductions for eac h CISWI unit.

Table 5 also presents the amount of PM 2.5 emissions reduction anticipated for each unit. These emissions are calculated as a percent of the PM filterable emissions reductions. These fractions
were based on emission factors from EPA’s AP

- 42 document 3 , and are a function of the materials burned and the baseline control devices (if any) present on the unit. These PM 2.5 fraction factors are presented in Appendix B.

IV. Lowest Cost Floor Emissions

Two of the CISWI subcategories have potential alternatives to incineration that could be more economical than complying with the final CISWI standards. The incinerator and small, remote incinerator subcategories could cease to burn solid waste and instead divert this waste to a landfill for disposal. The costs of complying with the rule and those associated with these disposal alternatives are discussed in more detail in the control costing memorandum. 2 The cost estimates
indicate that all but three of t he incinerators would cease using the combustion unit and use alternative disposal rather than adding controls necessary to comply with the final standards. Thethree incinerators that would likely remain operating are ILFlintHillsResources MB

- 1012,
LAShe llChemical F

- T701, and SCEastmanColumbia 1560

- 0008 ID #15. For the small remote subcategory, we estimate that no units would shut down, but that for many units it would be less expensive to segregate their waste and divert the nonferrous metal and chlorin ated plastic to a landfill, rather than install the controls necessary to comply with the limits if no waste segregation were being practiced

. This is possible for this particular subcategory since the waste these units are burning is primarily municipal

- type waste from industrial sites, which is usually able to be segregated for recyclable materials. The waste segregated out is assumed to be non

- digestable or minimally digestible materials such as ferrous and non

- ferrous metals and PVC, and therefore

wou ld not contribute significantly to landfill gas emissions. By removing these materials from the waste stream, it is expected that these small remote units will be able to meet the

PCDD/PCDF and Hg MACT floor limits.

When incinerators cease combusting waste, the waste that is diverted to a landfill will generate landfill gas (methane, carbon dioxide, hydrogen sulfide, chlorine gas, and other trace constituents). This waste may likely be combusted by a landfill flare, which would generate

some emissions . These landfill flare emissions would be considered a secondary air impact to the
final CISWI rule, since the waste that generates the landfill gas was diverted to the landfill due to the rule. The potentially diverted waste estimates are presented in t he control costing

memorandum 2 , but were estimated based on the unit’s waste combustion capacity and the annual operating hours. The waste diverted estimates were then assumed to be steady for 20 years (the expected useful life of a CISWI unit) to calculate estimates of the landfill gas generated from the diverted waste. These estimates were calculated using a first

- order decay model ( EPA’s Landfill Gas Emissions Model (LandGEM) Version 3.02). 4 Then, LandGEM default landfill gas sulfur

and chlorin e concentrations, along with landfill gas flare emissions factors from EPA’s AP

- 42 were then used to calculate annual secondary air impact emissions from the landfilling of the diverted solid waste. The LandGEM model inputs, flare emission factors, and ca lculated emissions are presented in Appendix C. These emissions were then subtracted from the total emission reductions to get an adjusted annual emissions reduction in Table 2.

V. New Sources

While we do not anticipate any new energy recovery units or waste

- burning kilns to be constructed, it is conceivable that some new incinerator and small, remote incinerator units will

be installed in the future to replace aging units or to service new faci lities

. It was assumed that

one new incinerator would come into operation over the next five years. We anticipate three new small, remote units to come online next year and one new small

, remote unit to be constructed each subsequent year. Please see the CISWI compliance cost memo for additional details regarding new source assumptions. 2

In order to determine the expected emission reductions resulting from NSPS compliance

, average uncontrolled emissions resulting for each pollutant were calculated u sing default control efficiencies in conjunction with the average baseline concentrations for each unit and its corresponding controls. Calculations can be found in the CISWI compliance cost memo. 2 These values were compared with NSPS emission limits and reductions were calculated following the method described above for existing units.

Emission reductions for incinerators and small, remote incinerators are presented in Table 6. The reductions are presented on a per

- unit basis. For each new incinerator, we estimate 122 tons per year of emissions would be reduced, consisting of 2.6 tons of HCl, 0.56 tons of Pb, 0.14 tons of Cd, 0.0026 tons of Hg, 102.7 tons of PM, 0.0000 005 tons of PCDD/PCDF, 11.3 tons of NO

x , and5.1 tons of SO 2

. No significa nt reduction for CO is anticipated because data from existing units suggest new units will be able to meet the CO limit without additional add

- on control s

. For each new small, remote unit , we estimate 22 tons per year of emissions would be reduced, consis ting of 0.11 tons of Pb, 0.02 tons of Cd, 6.7 tons of CO, 0.0004 tons of Hg, 10.7 tons of PM, and 4.5
tons of SO 2

. No reductions were calculated for HCl, NO

x , and PCDD/PCDF because data from existing units suggest new units will be able to meet these limits without additional add

- on control.

REFERENCES

1. “ CISWI Emission Limit Calculations for Existing and New Sources for the Reconsideration
Final Rule ” Mem orandum from Eastern Research Group, Inc. to Toni Jones , U.S. Environmental Protection Agency. November 16

, 201 2

.

2. “ Final Reconsideration Compliance Cost Analyses for CISWI Units ” Memorandum from Eastern Research Group, Inc. to Toni Jones , U.S. Environmental Protection Agency

. November 26, 2012

.

3. U.S. EPA. Compilation of Air Pollutant Emission Factors, Vol. 1. (AP

- 42) Fifth Edition.
1995.

4. U.S. EPA Office of Research and Development. Landfill Gas Emissions Model (LandGEM)
Version 3.02. May 2005.APPENDIX A

CONVERSION CALCULATIONS The following calculations were used to develop ton/year emission estimates:

PM, Pb, Cd and Hg

Concentration ”X” given in mg/dscm, flow rate ”FR” in dscf/minute (dscfm), and annual hours ”H” (hours/year):

[X(mg/dscm) x FR(dscf/min) x 60(min/hr) x H(hr/year)] ÷ [35.3147(dscf/dscm) x 453,592(mg/lb) x 2,000(lb/ton)] = (ton/yr)

CDD/CDF

Concentration ”X” given in ng/dscm, flow rate ”FR” in dscf/minute (dscfm), and annual hours ”H” (hours/year):

[X(ng/dscm) x FR(dscf/min) x 60(min/hr) x H(hr/year)] ÷ [35.3147(dscf/dscm) x 1,000,000 (ng/mg) x 453,592(mg/lb) x 2,000(lb/ton)] = (ton/yr)

HCl, NOx, SO 2 , CO

Concentration ”X” given in ppmvd, flow rate ”FR” in dscf/minute (dscfm), annual hours ”H” (hours/year), a nd molecular weight ”MW” as follows: HCl = 36.45, NOx = 46, SO2 = 64.06,

CO = 28.01:

[X(ppmvd) x MW(lb/lbmol) x FR(dscf/min) x 60(min/hr) x H(hr/year)] ÷ [1,000,000 x 385.5(dscf/lbmol) x 2,000(lb/ton)] = (ton/yr)APPENDIX B

PM2.5 FRACTION INFORMATIONAPPENDIX C

LANDFILL GAS AND FLARE EMISSIONS ESTIMATES