1 

### MEMORANDUM

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

FROM: Eastern Research Group, Inc.

DATE: November 26 , 2012

SUBJECT: Summary of the Secondary Impacts of Control Options for CISWI Standards

1.0 P URPOSE



### Thi s memorandum summarizes the secondary impacts associated with control devices used to comply with the final emission standards for Commercial and Industrial Solid Waste Incineration (CISWI) units. Secondary impacts result from the consumption of fuel, wat er, 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 all units to comply with the stan dards, and Section 4.0 presents the air emission estimates associated with the secondary impacts. Section 5.0 discusses secondary impacts resulting from new source compliance with CISWI standards.

2.0 B ACKGROUND



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

x 

### ), and sulfur dioxide (SO 2 

### ).

On December 1, 2000, EPA established new source performance standards and emission guidelines for CISWI units under Sections 111 an d 129 of the CAA. In 2001, EPA was granted a petition for reconsideration regarding the definitions of “commercial and industrial waste” and “commercial and industrial solid waste incineration unit.” Also in 2001, the United States Court of Appeals for t he District of Columbia Circuit granted EPA’s voluntary remand, without vacatur, of the 2000 rule. In 2005, EPA proposed and finalized the CISWI definition rule which revised the definitions of “solid waste,” “commercial and industrial waste,” and “commer cial 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.

In response to the voluntary remand that was granted in 2001, the vacatur, and remand of the CISWI definition rule in 2007, EPA developed these final standards for CISWI units. On March 21, 2011, the EPA promulgated revised NSPS and EG as its response to the voluntary remand

that wa s 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

- year technology review of the new source performance standards and emi ssion guidelines required under Section 129. Following that action, the Administrator received petition[s] for reconsideration and identified some issues that warranted further opportunity for public2 

### 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 December 23, 2011

, the EPA published proposed

amendments that incorporated these chan ges and allowed public comment on specific issues

identified for reconsideration. In addition, these final standards include the 5

- year technology review of the new source performance standards and emission guidelines required under Section

129 of the CAA. The EPA has developed a series of maximum achievable control technology (MACT) floor and beyond the MACT floor (BTF) options for consideration in developing the final standards. The development of the final emission limits used to determine these option s 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, facilities may need to install the following types of controls

on CISWI units:

**•** 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) systems to reduce HCl and SO 2 

### emissions,

**•** Regenerative Thermal Oxidizers (RTO) to reduce CO emissions,

**•** Selective non

- catalytic reduction (SN CR) to reduce NO

x 

### emissions,

**•** Activated carbon injection (ACI) systems to reduce PCDD/PCDF and Hg emissions, and

**•** Afterburner retrofits, tune

- ups, or oxidation catalysts to reduce CO emissions.

Additional electricity is required to operate the pumps and fan s associated with wet scrubbers, FF, DIFF, and SNCR systems. Also, water and subsequent wastewater disposal are required to operate wet scrubbers, DIFF and SNCR systems. Activated carbon injection systems require

activated carbon as well as a method to d ispose of the dust produced from the ACI system. Likewise, DIFF systems generate dust which must be disposed of. RTOs require natural gas to oxidize the carbon monoxide in the flue gas. Although afterburners require natural gas to operate, these are pri marily 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 analysis provide annual cost estimates for electricity, water, and carbon requirements as itemized components of the annual costs for the control device. 2 

### These cost elements for the control devices anticipated to be installed to comply with the final standards were then summed up to provide an estimate of the overal l 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 alg orithm. 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. The increased dust collected by improvements made to existing FF

systems were estimated based on the PM reduction required to meet the emission limit.

Two control scenarios were considered for the final standards:

**•** Compliance by additional control only, and

**•** Compliance or choose another method of disposal, depending on which c ost was lowest. These scenarios are described in sections 3.1 and 3.2, respectively.3 

### 3.1 Compliance by Additional Control Only

In the first scenario, each CISWI unit in all subcategories complies with the final MACT floor standards by installing the ant icipated control devices and associated monitoring equipment.

Table 3

- 1 shows the estimated values for secondary impacts, by subcategory, for the “All units comply” scenario.

T ABLE 

### 3

- 1. Secondary Impacts for MACT Compliance

**All units comply**

S ubcategory Electricity Required (MWh/yr) Water Required (gal/yr) Activated
Carbon Required

(ton/yr) Dust

Produced

(ton/yr) Supplemental

Fuel Requirements

(MMft3/yr)

ERU

- Liquid/Gas 5,637 21,303,000 0 308

-

ERU

- Solids 1 46 ,7 3 3 70,803,115,725 3, 355 1 3

, 56 6

-

Incinerators 7,7 31 102,58 2,724 23 6 3 4 2

- Small, remote 302 0 10 21

-

Kilns 64,542 528, 609

, 726 10,291 11,486 1, 444

Totals 2 24

, 9 4 6 71,455, 611,175 1 3

, 891 25

, 72 4 1, 444



### 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 methods are less expensive than adding control devices to comply with the standards, would instead cease burning waste and use alternative disposal

metho ds. 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 majo rity of incinerators, it would be less expensive to send waste to a landfill than to comply with the final emission limits (i.e., facilities would choose to shut down CISWI units). According to our estimates based on unit capacities and annual operating h ours, this would result in approximately 110, 567 tons per year of additional waste being sent to landfills. This would also result in subsequent landfill gas emissions from decomposition of this waste, which would likely be sent to a landfill gas flare. This gas flaring would result in emissions of NO

x 

### and CO, with some SO 2 

### , PM, and small amounts of mercury also being emitted . D etails on landfill emissions can be found in Appendix

C of the CISWI emission reductions memorandum

. 3 

### For small, remote units, i t 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 analysis, there are also likely to be secondary emissions associated with the transport of the waste to a landfill site. These emissions would be site

- spe cific and depend primarily on the number of trips, type 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 Electri city Required (MWh/yr) Water Required

(gal/yr) Activated
Carbon Required (ton/yr) Dust

Produced

(ton/yr) Supplemental

Fuel Requirements ( Million ft3/yr) Annual Waste
Diverted to

Landfill (ton/yr)

ERU

- Liquid/Gas 5,637 21,303,000 0 308

-

ERU

- Solids 1 4 6 ,7 3 3 70,803,115,725 3, 355 1 3

, 56 6

-

Incinerators 494 8,178 67 68

- 110, 567

Small, remote 23 0 1 2

-

Kilns 64,542 528, 609

, 726 10,291 11,486 1,444

Totals 2 17

, 4 2 9 71,35 3

, 036

, 629 1 3

, 7 1 4 2 5

, 43 1 1,444 110, 567



### 4.0 S UMMARY OF 

### S ECONDARY 

### I MPACT 

### E MISSION 

### E ST IMATES



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

### and criteria pollutants,

such as SO 2 

### , NO

x 

### , and CO. Emission s 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

aver age basis. For this analysis 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 analyzed for existing sources. Table 4

- 2 shows the resulting emissions of CO 2 

### , CO, NO

x 

### , and SO 2 

### from combustion of natural gas supplemental fuel a nd increase electricity usage for the lowest cost options analyzed for existing sources.

The Appendix to the secondary impacts analysis contains the spreadsheets supporting these

summaries.5 

### T ABLE 

### 4

- 1. Secondary Emission Impacts for MACT Compliance

Subca tegory 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 146,733 97,530 1 42

. 08 385.83

- - - - 97,530

- 142.08 385.83

Incinerators 7, 731 5,13 9 7.4 9 20.3 3

- - - - 5,13 9

- 7.4 9 20.3 3

S mall, remote 302 201 0. 29 0. 79

- - - - 201

- 0. 29 0. 79

Kilns 64,542 42,900 62.50 169.71 1,444 86,6 12 60.6 72.2 129,5 12 60.6 134. 67 169.71

Totals 224,946 149,516 2 18 591 1,444 86,6 12 60.6 72.2 2 36

, 128 60.6 290 591

a. National emission factors from Egrid 4 for EGUs.

b. Natural gas emission factors from AP

- 42. 5



### T ABLE 

### 4

- 2. Secondary Emission Impacts for Lowest 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 1 4.82

ERU

- Solids 146,733 97,530 142.08 385.83

- - - - 97,530

- 142.08 385.83

Incinerators 494 328 0.48 1.30

- - - - 328

- 0.48 1.30

Small, remote 23 1 5 0.0 2 0.0 6

- - - - 1 5

- 0.0 2 0.0 6

Kilns 64,542 42,900 62.50 169.71 1,444 86,6 12 60.6 72.2 129,5 12 60 .6 134. 67 169.71

Totals 217,429 1 44

, 519 2 11 572 1,444 86,6 12 60.6 72.2 23 1

, 132 60.6 2 83 572

a. National emission factors from Egrid 4 for EGUs. b. Natural gas emission factors from AP

- 42. 56 

### 5.0 S UMMARY OF 

### S ECONDARY 

### I MPACTS FOR 

### N EW 

### S OUR CES



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

- burning kilns to be constructed, it is conceivable that some new units will be installed in the future. It was assumed that 1 new incinerator would come into operation over the next fiv e years. We anticipate 3 new small, remote units to come online next year and 1 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



### Secondary im pacts for new units were determined by applying the methodology described above for existing units. Table 5

- 1 presents the annual impacts anticipated for

new sources as a result of the CISWI standards. Table 5

- 2 shows the expected secondary

emissions from the electricity required for prescribed control devices.

T ABLE 

### 5

- 1. Annual S econdary Impacts for New Sources

Subcategory Replacement
Units (#/year) 1 Electricity Required (MWh/yr) Water Required

(gal/yr) Activated
Carbon Required

(ton/yr) Dust

Produced

( ton/yr)

Incinerators 0.2 71 979,804 4 5

Small, remote 1.4 23 0 0.75 1.63

Totals

- 94 979,804 4.66 6.82

1. It was assumed that 1 new incinerator would come into ope ration over the next five years, and w e anticipate 3 new small, remote units to come onli ne next year and 1 new small remote unit to be constructed each subsequent year.



### T ABLE 

### 5

- 2. Secondary Emission Impacts for New Sources

Subcategory Electricity Required (MWh/yr) Emissions from Electricity Requirements (tons/year)

CO 2 Emitted NO
x Emi tted SO 2 Emitted

Incinerators 71 47 0.07 0.19

Small, remote 23 15 0.02 0.06

Totals 94 62 0.09 0.25

a. National emission factors from Egrid 4 for EGUs7 

### R EFERENCES



### 1. “CISWI Emission Limit Calculations for Existing and New Sources for the

Reconsideratio n Final Rule ” Memorandum from Eastern Research Group, Inc. to Amy

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 To ni Jones , U.S. Environmental Protection Agency. November 2 6 , 201 2

.

3. “ Final Reconsideration Baseline Emissions and Emissions Reductions Estimates for Existing CISWI Units” Memorandum from Eastern Research Group, Inc. to Toni Jones

, U.S. Environmental P rotection Agency. November 2 6 , 201 2

.

4. EPA eGRID database eGRID2007 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. Com pilation of Air Pollutant Emission Factors (AP

- 42), Fifth Edition, Volume 1: Stationary and Point Sources, Chapter 1:

External Combustion Sources.