1



### MEMORANDUM **TO:** Toni Jones, U.S. Environmental Protection Agency **FROM:** Eastern Research Group, Inc. **DATE:** November 21, 2011 **SUBJECT:** Summary

of the Secondary

Impacts of Control Options for CI SWIStandards for Reconsideratio n Proposal **1.0 P**  **URPOSE** 

### This memorandum summarizes the secondary impacts associated with control devices used to comply with the proposed emission standards for Commercial and Industrial Solid Waste In cineration (CI SWI ) units. Secondary impacts result f

rom the consumption of fuel, water, and electricity and generation of solid wastes by control devices. Section 2.0 provides a background for the standards, Section 3.0 presents the secondary impact estimates associated with control devices necessary

for a ll units to comply

with the standards, and Section 4.0 presents the air emission estimates associated with the secondary impacts. **2.0 B**  **ACKGROUND** 

### The U.S. Environmental Protection Agency , under section 129 of the Clean Air Act (CAA), is required to regu late emissions of the following nine pollutants from CI SWI units: hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd), mercury (Hg), particulate matter (PM), dioxins/furans (PCDD/PCDF), nitrogen oxides (NO x

### ), and sulfur dioxide (SO 2 

### ). On December 1, 2000, the EPA established new source performance standards (NSPS) and emission guidelines (EG) for CI SWIunits under Sections 111 and 129 of the CAA. In 2001, EPA was granted a petition for reconsideration regarding the definitions of “comm ercial and industrial waste” and “commercial and industrial solid waste incineration unit.” Also in 2001, the United States Court of Appeals for the District of Columbia Circuit granted the EPA’s voluntary remand, without vacatur, of the 2000 rule. In 20 05, the EPA proposed and finalized the CI SWIdefinition rule which revised the definitions of “solid waste,” “commercial and industrial waste,” and “commercial and industrial waste incineration unit.” In 2007, the United States Court of Appeals for the Di strict of Columbia Circuit vacated and remanded the 2005 commercial and industrial solid waste incineration definition rule. On March 21, 2011, the EPA 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 included the 5
- ye ar technology review of the new source performance standards and emission guidelines requir ed under Section 129. Following that action, the Administrator received petition[s] for reconsideration and identified some issues that warranted further opportunity for public comment. In addition, data were received that enabled the EPA to revise the C IS WI2



### inventory of waste
- burning kilns and energy recovery units to more accurately

reflect the definition of non
- hazardous secondary materials. The EPA has developed maximum achievable control technology (MACT) floors and emission limits in the development of the proposed standards. The development of the proposed emission limits used to determine these options is discussed in more detail in a separate memorandum. 1 

### 3.0 **S UMMARY OF**  

### S **ECONDARY** 

### I **MPACT** 

### E **STIMATES** 

### To comply

with the final standards, faciliti es may need to install the following types of controls on CI SWIunits:  Wet scrubbers (WS) to reduce HCl and SO 2 

### emissions,  Fabric filters (FF) to reduce Cd, Pb, and PM emissions,  Duct sorbent injection/fabric filter (DIFF) s ys tems to reduce HCl and SO 2 

### em issions,  Regenerative Thermal Oxidizers (RTO) to reduce CO emissions,  Selective non
- catal yt ic reduction (SNCR) to reduce NO x 

### emissions,  Activated carbon injection (ACI) s ys tems to reduce PCDD/PCDF and Hg emissions, and  Afterburner retrofits, tune
- ups, or o xidation catalysts to reduce CO emissions. Additional electricity is required to operate the pumps and fans associated with wet scrubbers, FF, D IFF, and SNCR s ys tems. Also, water and subsequent wastewater disposal are required to operate wet scrubbers, D IFF and SNCR sy stems. Activated carbon injection sy stems require activated carbon as well as a method to dispose of the dust produced from the ACI s ys tem. RTOs require natural gas to oxidize the carbon monoxide in the flue gas. Although afterburners require natural gas to operate, these are primaril y replacing existing afterburners, so the change in natural gas consumption may be minimal, and we do not have the data to be able to estimate this change. The algorithms used in the cost anal ys is provide annual cost estimates for electricity , water, and carbon requirements as itemized components of the annual costs for the control device. 2 

### These cost elements for the control devices anticipated to be installed to comply with the final standards were then summed up to provide an estimate of the overall costs of electricity , water and activated carbon. To estimate the secondary impact components (e.g., electricity, water, and dust from carbon), the itemized annual cost of each component was divided by the unit price of the component utilized by the algorithm. To estimate the additional annual fuel requirements for each combustion unit operating an RTO the annual operating hours were multiplied by the natural gas fuel requirement. Two control scenarios were co nsidered for the proposed standards:  Compliance by

additional control only , and  Compliance or choose another method of disposal, depending on which cost was lowest. These scenarios are described in sections 3.1 and 3.2, respectivel y.3



### 3.1 **Compliance by A dditional Control Only**  In the first scenario, each CI SWIunit in all subcategories complies with the proposed MACT floor standards b y installing the anticipated control devices and associated monitoring equipment. Table 3
- 1 shows the estimated values fo r secondary impacts, by

subcategory , for the “All units comply” scenario. **T ABLE**  

### 3 **- 1.**  **Secondary Impacts for MACT Compliance All units comply**  **Subcategory Electricity**  **Required (M**  **Wh/yr) Water Required** 

**(gal/yr) Activated** 

**Carbon Required**  **(ton/yr) Dus**  **t**

**Produced (ton/yr)**  **Supplemental**

**Fuel Requirements**  **(MMft3/yr)** ERU - Liquid/Gas 5,637 21,303,000 0 308 - ERU - Solids 187,499 90,042,168,599 4,424 16,721 - Incinerators 7,725 102,581,104 235 335 - Small, remote 140 0 5 10 - Kilns 48,624 424,226,569 5 ,328 5,450 1,288 **Totals 249,626**  **90,590,279,272 9,993**  **22,824 1,288**  

### 3.2 **Compliance or Alternative Method of Disposal** The second scenario entails a situation where facilities considered alternative disposal options and, where the alternative disposal m ethods are less expensive than adding control devices to comply with the standards, would instead cease burning waste and use alternative disposal methods. In addition to the electricity , water, and activated carbon requirements for those facilities that choose to add control devices to comply with the standards, secondary impacts also occur when alternative waste
- handling methods are used. For the majority of incinerators, it would be less expensive to send waste to a landfill than to comply with the pro posed emission limits (i.e., facilities would choose to shut down CISWI units). According to our estimates based on unit capacities and annual operating hours, this would result in approximately 110,417 tons per year of additional waste being sent to land fills. This would also result in subsequent landfill gas emissions from decomposition of this waste, which would likely be sent to a landfill gas flare. This gas flaring would result in emissions of NO x 

### and CO, with some SO 2 

### , PM, and small amounts of mercury

also being emitted. Further details on landfill emissions can be found in a separate memorandum. 3 

### For small, remote units, it was determined that i t is generally less expensive for facilities to segregate their waste and divert the nonferrous metal and chlorinated plastic to a landfill than to landfill all of their waste. In this case, the landfilled material is considered non
digestable and will not contribute significantly to landfill emissions. 

### While not quantified in our anal ys is, there are also likely to be secondary

emissions associated with the transport of the waste to a landfill site. These emissions would be site
- specific and depend primarily on the number of trips, ty

pe of vehicle, and distance traveled necessary to transport the waste to the landfill.4



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


### T **ABLE** 

### 3 **- 2.**  **Secondary Impacts for MACT Compliance for Lowest Cost Options Lowest Cost Option**  **Subcategory Electricity** 

**Required (M**  **Wh/yr) Water** 

**Required (gal/yr)**  **Activated**

**Carbon Required**  **(ton/yr) Dust** 

**Produced (ton/yr)**  **Supplemental**

**Fuel Re**  **quirements (ft3/yr)**  **An nual Waste** 

**Diverted to Landfill**  **(ton/yr)** ERU - Liquid/Gas 5,637 21,303,000 0 308 - ERU - Solids 187,499 90,042,168,599 4,424 16,721 - Incinerators 494 8,178 67 68 - 110,417 Small, remote 29 0 1 3 - Kilns 48,624 424,226,5 69 5,328 5,450 1,288 **Totals 242,283**  **90,487,706,345 9,820**  **22,549 1,288**  **110,417** 

### 4.0 **S UMMARY OF**  

### S **ECONDARY** 

### I **MPACT** 

### E **MISSION** 

### E **STIMATES** 

### Emission factors from EPA’s eGRID 4 

### database were used to calculate emissions resulting from the electricity required for additional control devices, and emission factors from EPA’s AP
- 42 emission factor document 5 

### were used to calculate emissions resulting from the combustion of additional fuel for RTOs. Increased electrical use from the control options will require addi tional fuel to be burned in power plants, resulting in emissions of CO 2 

### and criteria pollutants, such as SO 2 

### , NO x 

### , and CO. Emissions of these pollutants (caused by increase in electricity) were estimated using EPA’s eGRID database. 4 

### The eGRID database summarizes emissions of criteria pollutants on a per electrical usage basis (lb emitted per MW
- hr), on a national average or state average basis. For this analy sis the national average was used. To estimate emissions from combustion of natural gas, emission factors from EPA’s AP
- 42 emission factor document were used. 5 

### Tables 4
- 1 summarizes the resulting emissions of CO 2 

### , CO, NO x 

### , and SO 2 

### from combustion of natural gas supplemental fuel and increase electricity usage for the control options analy zed for ex isting sources. Table 4
- 2 shows the resulting emissions of CO 2 

### , CO, NO x 

### , and SO 2 

### from combustion of natural gas supplemental fuel and increase electricity usage for the lowest cost options analy

zed for existing sources. The Appendix to the secondary impa cts analy sis contains the spreadsheets supporting these summaries.5



### T **ABLE** 

### 4 **- 1.**  **Secondary Emission Impacts for MACT Compliance**

**Subcategory Electricity Requirements and**  **Emissions (tons/yr) Supplemental Fuel Requirements and**  **Emissions (tons/yr) Total Second**  **ary Emissions (tons/yr) Mw**  **** **hr/yr CO**  **2**

**Emitted NO**  **x**

**Emitted SO**  **2**

**Emitted Million** 

**ft 3**  **Natural Gas/ yr**  **CO 2** 

**Emitted CO** 

**Emitted NO**  **x**

**Emitted CO**  **2**

**Emitted CO** 

**Emitted NO**  **x**

**Emitted SO**  **2**

**Emitted** ERU - Liquid/Gas 5,637 3,747 5.46 14.82 - - - - 3,747 - 5.46 14.82 ERU - Solids 187,499 124,626 181.56 493.02 - - - - 124,626

- 181.56 493.02 Incinerators 7,725 5,135 7.48 20.31 - - - - 5,135 - 7.48 20.31 Small, remote 140 93 0.14 0.37 - - - - 93 - 0.14 0.37 Kilns 48,624 32,319 47.08 127.85 1,288 77,287 54.1 64.4 109,606 54 .1 111.49 127.85 **Totals 249,626**  **165,920 242**  **656 1,288**  **77,287 54.1**  **64.4 243,207**  **54.1 306**  **656** a. National emission factors from Egrid4 for EGUs. b. Natural gas emission factors from AP
- 42. 5 

### T **ABLE** 

### 4 **- 2.**  **Secondary Emission Impacts for L owest Cost Option** 

**Subcategory Electricity Requirements and**  **Emissions (tons/yr) Supplemental Fuel Requirements and**  **Emissions (tons/yr) Total Secondary Emissions (tons/yr)**  **Mw**   ** hr/yr** **CO 2** 

**Emitted NO**  **x**

**Emitted SO**  **2**

**Emitted Million** 

**ft 3**  **Natural Gas/ yr**  **CO 2** 

**Emitted CO** 

**Emitted NO**  **x**

**Emitted CO**  **2**

**Emitted CO** 

**Emitted NO**  **x**

**Emitted SO**  **2**

**Emitted** ERU - Liquid/Gas 5,637 3,747 5.46 14.82 - - - - 3,747 - 5.46 14.82 ERU - Solids 187,499 124,626 181.56 493.02 - - - - 124,626 - 181.56 493.02 Incinerators 494 328 0.48 1.30 - - - - 3 28 - 0.48 1.30 Small, remote 29 19 0.03 0.08 - - - - 19 - 0.03 0.08 Kilns 48,624 32,319 47.08 127.85 1,288 77,287 54.1 64.4 109,606 54.1 111.49 127.85 **Totals 242,283**  **161,039 235**  **637 1,288**  **77,287 54.1**  **64.4 238,327**  **54.1 299**  **637** a. National emission facto rs from Egrid4 for EGUs. b. Natural gas emission factors from AP
- 42. 56



### R**EFERENCES** 

### 1. “CI SWIEmission L imit Calculations for Existing and New Sources for Reconsideration Proposal” Memorandum from Eastern Research Group, In c. to Toni Jon es, U.S. Environmental Protection Agency. November 3, 2011. 2. “Reconsideration Proposal Compliance Cost Analy ses for CISWI Units” Memorandum from Eastern Research Group, Inc. to Toni Jones, U.S. Environmental Protection Agency . November 20, 2011. 3. “ Reconsideration Proposal Baseline Emissions and Emissions Reductions Estimates for Existing CI SWIUnits” Memorandum from Eastern Research Group, Inc. to Toni Jones, U.S. Environmental Protection Agency . November 20, 2011. 4. EPA eGRID database eGRID200 7 Version 1.1. Year 2005 summary tables located at www.epa.gov/cleanenergy/documents/egridzips/eGRID2007V1_1_year05_SummaryTab les.pdf 5. U.S. Environmental Protection Agency , 1995. Compilation of Air Pollutant Emission Factors (AP
- 42), Fifth Edition, Vo lume 1: Stationary and Point Sources, Chapter 1: External Combustion Sources.