EPA-450/3-89-023a
Hazardous Waste TSDF -
Background Information for
Proposed RCRA Air Emission
Standards
Volume I - Chapters 1 - 8,
& Appendices A - C
Emission Standards Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
June 1991
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DISCLAIMER
This report has been reviewed by the Emission Standards Division
of the Office of Air Quality Planning and Standards, EPA, and
approved for publication. Mention of trade names or commercial
products is not intended to constitute endorsement or
recommendation for use. Copies of this report are available
through the Library Services Office (MD-35), U.S. Environmental
Protection Agency, Research Triangle Park NC 27711, or from
National Technical Information Services, 5285 Port Royal Road,
Springfield VA 22161.
11
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ENVIRONMENTAL PROTECTION AGENCY
Background Information and Draft Environmental Impact Statement
for
Hazardous Waste Treatment, Storage, and Disposal Facilities -
Tanks, Surface Impoundments, and Containers
Prepared by:
Bruce C. Jordan
Acting Director, Emission Standards Division
U.S. Environmental Protection Agency (MD-13)
Research Triangle Park, North Carolina 27711
(Date)
1. Section 3004(n) of the Resource Conservation and Recovery
Act as amended, requires EPA to develop standards for air
emissions from hazardous waste treatment, storage, and
disposal facilities (TSDF) as necessary to protect human
health and the environment. The proposed standards would
require organic emission control equipment be installed,
operated, and maintained on all TSDF tanks, surface
impoundments, and containers into which is placed hazardous
waste with a volatile organic concentration equal to or
greater than 500 parts per million by weight.
2. Copies of this document have been sent to the following:
Federal Departments of Labor, Health and Human Services,
Defense, Transportation, Agriculture, Commerce, Interior,
and Energy; the National Science Foundation; the Council on
Environmental Quality; State and Territorial Air Pollution
Program Administrators; EPA Regional Administrators; Local
Air Pollution Control Officials; Office of Management and
Budget; and other interested parties.
3. The comment period for review of this document is 60 days
from the date of publication of the proposed standards in
the Federal Register. Ms. Gail Lacy may be contacted ,at
(919) 541-5261 regarding the date of the comment period.
4. For additional technical information contact:
Mr. Stephen A. Shedd
Chemicals and Petroleum Branch, ESD (MD-13)
-•U.S. Environmental Protection Agency
•- -Research Triangle Park, NC 27711
Telephone: (919) 541-5397
5. Copies of this document may be obtained from:
U.S. Environmental Protection Agency, Library (MD-35)
Research Triangle Park, North Carolina 27711
Telephone: (919) 541-2777
National Technical Information Service
5285 Port Royal Road
Springfield, Virginia 22161
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IV
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CONTENTS
Chapter
Figures ix
Tables xi
Abbreviations and Conversion Factors xv
1.0 Introduction , i-i
1.1 Control Options 1-1
1.2 Health and Environmental Impacts 1-2
1.3 Cost and Economic Impacts 1-3
2.0 . Regulatory Authority and Standards Development 2-1
2.1 Regulatory Authority 2-1
2.2 Standards Development for Waste
Management Air Emissions 2-2
3.0 Industry Description and Air Emissions 3-1
3.1 The Hazardous Waste Industry 3-1
3.1.1 General Hazardous Waste Description 3-1
3.1.2 Generators 3-4
3.1.3 Transporters 3-5
3.1.4 Treatment, Storage, and Disposal Facilities... 3-7
3.1.5 TSDF Emission Sources 3-14
3.2 Estimates of Organic Emissions 3-18
3.2.1 Emission Estimation Data Requirements 3-19
3.2.2 Nationwide TSDF Emissions 3-24
3.3 References 3-29
4.0 Control Technologies 4-1
4.1 Application of Control Technologies to
TSDF Emission Sources • 4-1
4.1.1 Control Technology Categories 4-1
4.1.2 Organic Air Emission Control Efficiency 4-2
4.1.3 Secondary Air and Cross-Media Impacts 4-4
4.2 Suppression Controls 4-5
4.2.1 Fixed-Roof Tanks 4-5
4.2.2 Tank Floating Roofs 4-9
4.2.3 Pressure Tanks 4-11
4.2.4 Floating Membrane Covers 4-12
4.2.5 Air-Supported Structures 4-15
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CONTENTS (continued)
Chapter
4.2.6 Flexible Membrane Covers 4-19
4.2.7 Rigid Membrane Covers 4-20
4.2.8 Rigid Structures 4-20
4.3 Add-On Controls 4-20
4.3.1 Carbon Adsorbers 4-22
4.3.2 Thermal Vapor Incinerators 4-28
4.3.3 Catalytic Vapor Incinerators 4-30
4.3.4 Flares 4-33
4.3.5 Boilers and Process Heaters 4-36
4.3.6 Condensers 4-36
4.3.7 Absorbers 4-39
4.4 Organic Removal and Hazardous Waste
Incineration Processes 4-39
4.4.1 Steam Stripping 4-39
4.4.2 Air Stripping 4-45
4.4.3 Thin-Film Evaporation 4-49
4.4.4 Batch Distillation 4-52
4.4.5 Dewatering 4-56
4.4.6 Hazardous Waste Incineration 4-59
4.5 Process Modifications 4-63
4.5.1 Petroleum Refinery Waste Coking 4-63
4.5.2 Submerged Loading 4-65
4.5.3 Subsurface Injection 4-66
4.5.4 Waste Fixation Mechanical Mixing 4-66
4.6 Work Practice Modification 4-68
• 4.6.1 Housekeeping in Drum Storage Areas 4-68
4.6.2 Leak Detection and Repair 4-69
4.7 Summary of Control Technologies Selected
for Control Option Analyses 4-70
4.8 References 4-78
5.0 Control Options 5-1
5.1 Control Option Concept 5-1
5.2 Emission Sources, Controls, and Action
Levels Considered in Developing Control
Options 5-2
5.2.1 Emission Sources 5-2
5.2.2 Controls 5-2
5.2.3 Action Levels 5-5
5.3 Selection of Control Options..., 5-5
5.4 Baseline for Nationwide Impacts Estimates 5-8
5.4.1 Land Disposal Restrictions 5-9
5.4.2 TSDF Air Standards for Equipment
Leaks and Process Vent Control 5-10
5.4.3 New Source Performance Standards (NSPS)
for Volatile Organic Storage Vessels 5-11
5.5 Reference 5-13
VI
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CONTENTS (continued)
Chapter page
6.0 National Organic Emissions and Health Risk Impacts 6-1
6.1 Organic Emission Impacts „ 6-1
6.2 Human Health Risks 6-7
6.2.1 Annual Cancer Incidence 6-7
6.2.2 Maximum Lifetime Risk 6-8
6.2.3 Noncancer Health Effects Assessment--
Acute and Chronic Exposures 6-11
6.3 Other Environmental Impacts 6-13
6.4 References 6-17
7.0 Costs of the Control Options 7-1
7.1 Control Costs Development 7-1
7.1.1 Methodology for Model Units 7-2
7.1.2 Derivation of Unit Costs to Estimate
Nationwide Costs of Control. Options 7-4
7.2 Summary of Nationwide Control Costs for Control
Options 7_5
7.3 Cost Effectiveness of Control Options 7-7
7.4 References 7_10
8.0 Economic Impacts 8-1
8.1 Industry Profile ',[', 8-2
8.1.1 The Supply Side 8-3
8.1.2 The Demand Side 8-10
8.1.3 Market Outcomes 8-14
8.2 Analytical Approach 8-14
8.2.1 Model Overview 8-15
8.2.2 Model Design 8-18
8.3 Economic Impacts 8-24
8.3.1 Price and Quantity Adjustments 8-25
8.3.2 Regulatory Costs 8-29
8.3.3 Emissions and Cost Effectiveness 8-29
8.3.4 Facility Closures 8-41
8.3.5 Employment Effects 8-43
8.3.6 Small Business Effects „ 8-45
8.4 References 8-52
Appendix . page
A Evolution of Proposed Standards A-l
B Index to Environmental Impact Considerations B-l
C Emission Models and Emission Estimates C-l
C.I Emission Models C-4
C.I.I Description of Models C-4
C.I.2 Comparison of Emission Estimates
with Test Results... C-14
vn
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CONTENTS (continued)
Appendix
C.I.3 Sensitivity Analysis C-16
C.2 Model TSDF Waste Management Unit Analyses C-18
C.2.1 Model Unit Descriptions C-19
C.2.2 Model Wastes C-47
C.2.3 Summary of Model Unit Analysis of
Emission Reductions and Control Costs C-50
C.3 References C-85
(Bound separately in Volume II)
D Source Assessment Model D-l
E Estimating Health Effects E-l
F Test Data F-!
(Bound separately in Volume III)
G Emission Measurement and Continuous Monitoring G-l
H Suppression and Add-On Control Device Cost Estimates
and Suppression Control Efficiency Estimates H-l
I Supporting Documents for the Economic Impact Analysis 1-1
J Exposure Assessment for Maximum Risk and Noncancer
Health Effects J-l
K Secondary Air and Cross-Media Impact Estimates K-l
L 90-Day Tanks and Container Impacts L-l
vn i
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FIGURES
Number
Page
3-1 Simplified hazardous waste system from generation to
disposal 3-2
3-2 Estimate of physical characteristics of RCRA
hazardous wastes " 3-6
3-3 Two examples of onsite hazardous waste land treatment
operations 3-10
3-4 Two examples of active landfill operations 3-11
3-5 Example onsite hazardous waste storage facility 3-12
3-6 Source Assessment Model (SAM) input files used in
estimating nationwide treatment, storage, and
disposal facilities (TSDF) uncontrolled air emissions 3-25
4-1 Storage tank covers 4-7
4-2 Typical air-supported structure 4-16
4-3 Carbon canister unit 4-24
4-4 Schematic diagram of thermal incinerator system 4-29
4-5 Schematic diagram of catalytic incinerator system 4-32
4-6 Steam-assisted elevated flare system 4-34
4-7 Schematic diagram of a shell-and-tube surface
condenser 4-38
4-8 Schematic diagram of a steam stripping system 4-41
4-9 Schematic diagram of an air stripping system 4-46
4-10 Schematic diagram of a thin-film evaporator system 4-50
4-11 Schematic diagram of batch distillation with
fractionating column 4-54
4-12 Dewatering system with enclosed dewatering device 4-58
4-13 Hazardous waste incinerators 4-62
8-1 A market supply curve constructed by summing
four firms' supply curves ' 8-17
8-2 Hypothetical price and output adjustments due to
a market supply shift induced by air emission
regulations 8-19
IX
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TABLES
Number Page
1-1 Residual Health and Environmental Effects of
Control Options for TSDF Organic Air Emissions 1-4
3-1 Resource Conservation and Recovery Act (RCRA)
Hazardous Waste Management Definitions 3-8
3-2 Nationwide Quantity of Hazardous Waste Managed
by Specific Processes 3-9
3-3 Hazardous Waste Management Process Emission Sources 3-15
3-4 Summary of Selected Model Hazardous Waste Management
Unit Uncontrolled Organic Emission Estimates for
Model Wastes „ 3-22
3-5 Nationwide Uncontrolled TSDF Organic Emission
Estimates 3-30
4-1 TSDF Control Technology Categories 4-3
4-2 Emission Control Options Used for Selecting
TSDF Control Options 4-71
4-3 Emission Control Efficiencies Used in
Estimating Nationwide Impacts of Control Options 4-73
4-4 Generic Control Device Definitions 4-77
5-1 TSDF Emission Source Categories 5-3
5-2 TSDF Air Emission Control Options 5-6
5-3 Control Requirements Under the Clean Air Act
for Volatile Organic Liquid Storage Vessels 5-12
6-1 Summary of Nationwide Organic Air Emissions and
Health Risk Impacts for Uncontrolled, Baseline,
and Five Control Options 6-2
6-2 Nationwide TSDF Emissions for the Uncontrolled,
Baseline, and After Control Options 6-4
6-3 Nationwide Cancer Incidence from TSDF Emissions by
Source Category 6-9
6-4 Maximum Lifetime Risks from TSDF Emissions 6-12
6-5 TSDF Control Device Operating Conditions Selected for
Secondary Air and Cross-Media Impact Estimates 6-14
6-6 Summary of Nationwide Annual Secondary Air and
Cross-Media Impact Estimates for Control Options
1 Through 5 6-16
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TABLES (continued)
Number
Page
7-1 Estimated Total Capital Investment and Total
Annual Cost Per Unit of Waste Throughput by
Source Category for Five Control Options 7-6
7-2 Estimated Nationwide Total Capital Investment and
Total Annual Cost for Five Control Options ,. 7-8
7-3 Nationwide TSDF Cost Effectiveness of Five
Control Options 7-9
8-1 Comparison of Unit Costs per Metric Ton 8-5
8-2 Parameters of the Unit Cost Function 8-6
8-3 Volume of Waste Managed by Sector, 1986 8-8
8-4 Supply Elasticities for Hazardous Waste
Management Services by Sector 8-9
8-5 Consumption of Hazardous Waste Management
Services and Value of Shipments by Sector, 1986 8-12
8-6 Cost Shares and Demand Elasticities by Sector 8-13
8-7 Market Share Parameters for Hazardous Waste
Management Services, by Sector 8-22
8-8 Control Option Shift Parameters by Sector, Percent 8-23
8-9 Number of Treatment, Storage, and Disposal
Facilities (TSDF) Affected by the Control Options 8-26
8-10 Price Adjustments by Control Option for Goods
and Services Produced by Hazardous Waste
Generators, Percent 8-27
8-11 Quantity Adjustments by Control Option for
Goods and Services Produced by Hazardous
Waste Generators, Percent 8-28
8-12 Quantity Adjustments in Waste Generation and
Management by Generating Sector: Control Option 1 8-30
8-13 Quantity Adjustments in Waste Generation and
Management by Generating Sector: Control Option 2 8-31
8-14 Quantity Adjustments in Waste Generation and
Management by Generating Sector: Control Option 3 8-32
8-15 Quantity Adjustments in Waste Generation and
Management by Generating Sector: Control Option 4 8-33
8-16 Quantity Adjustments in Waste Generation and
Management by Generating Sector: Control1 Option 5 8-34
8-17 Price and Quantity Adjustments in the Market for
Commercial Hazardous Waste Management Services 8-35
8-18 Compliance Costs by Control Option Without
Quantity Adjustments, $106/yr 8-36
8-19 Compliance Costs by Control Option with
Quantity Adjustments, $106/yr 8-37
8-20 Capital Costs by Control Option, $106/yr . 8-38
8-21 Compliance Costs as Percent of Hazardous
Waste Management Costs, Percent 8-39
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TABLES (continued)
Number Page
8-22 Emissions and Cost Effectiveness by Control Option 8-40
8-23 Potential Facility Closures by Control
Option and Sector 8-42
8-24 Potential Employment Effects by Control
Option and Sector, Number of Jobs 8-44
8-25 Small Business Administration Size Criteria
by SIC Code 8-47
8-26 Baseline Statistical Data for Small Commercial
Facilities with Estimated Sales Revenue Less
Than $5 Million (Annual Values) 8-49
8-27 Effects of the Most Stringent Regulation
(Option 1) on Small Commercial Facilities with
Estimated Sales Revenue Less Than $3.5 Million.. 8-51
A-l Evolution of Proposed Treatment, Storage, and
Disposal Facility Air Standard A-6
C-l Design and Operating Parameters of Hazardous
Waste Surface Impoundment and Uncovered
Tank Model Units. C-20
C-2 Design and Operating Parameters of Hazardous
Waste Land Treatment Model Units C-32
C-3 Design and Operating Parameters of Hazardous
Waste Fixation Pit, Wastepile Storage,
and Landfill Disposal Model Units C-33
C-4 Design and Operating Parameters of Hazardous
Waste Transfer, Storage, and Handling Operation
Model Units C-41
C-5 Model Waste Compositions C-48
C-6 Summary of TSDF Model Unit Analysis Results C-51
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XIV
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ABBREVIATIONS AND CONVERSION FACTORS
The EPA policy is to express all measurements in Agency documents in
the International System of Units (SI). Listed below are abbreviations
and conversion factors for equivalents of these units.
Abbreviations
L - liters
kg - kilograms
Mg - meg ag rams
m - meters
cm - centimeters
kPa - kilopascals
ha - hectares
rad - radians
kW - kilowatts
Conversion Factor
liter X 0.26 = gallons
gallons X 3.79 = liters
kilograms X 2.203 = pounds
pounds X 0.454 = kilograms
megagram XI = metric tons
megagram X 1.1 = short tons
short tons X 0.907 = megagrams
meters X 3.28 = feet
centimeters X 0.396 = inches
kilopascals X 0.01 = bars
bars X 100 ' = kilopascals
kilopascals X 0.0099 = atmospheres
atmospheres X 101 = kilopascals
kilopascals X 0.145 = pound per
square inch
pound per square inch X 6.90 =
kilopascals
hectares X 2.471 = acres
acres X 0.40469 = hectares
radians X 0.1592
revolutions X 6.281
kilowatts X 1.341
horsepower X 0.7457
revolutions
radians
horsepower
kilowatts
Frequently used measurements in this document are:
0.21
5.7
30
76
800
1.83
210
5,700
30,000
nP ~ 76,000 L
m3 ~ 800,000 L
kg 02/kW/h
kW/28.3 m3
55 gal
1,500 gal
8,000 gal
20,000 gal
~ 210,000 gal
3 Ib 02/hp/h
1.341 hp/103 ft3
•"•/^^•'J?** ill .1 • ^ ^ J. flhS/^W I W
kPa«m3/g«mol « 0.0099 atm»m3/g«mol
xv
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1.0 INTRODUCTION
Hazardous waste treatment, storage, and disposal facilities (TSDF)
managing wastes containing organics are potential sources of organic air
emissions. These organic air emissions can contain toxic chemical com-
pounds as well as ozone precursors. Cancer and other adverse noncancer
human health effects can result from exposure to these organic air emis-
sions. In addition, these emissions contribute to formation of ozone,
which causes adverse impacts on human health (e.g., lung damage) and the
environment (e.g.\ reduction in crop yields). Excessive ambient ozone
concentrations are a major air quality problem in many large cities
throughout the United States.
In 1984, Congress passed the Hazardous and Solid Waste Amendments
(HSWA) to the Resource Conservation and Recovery Act (RCRA) of 1976.
Section 3004(n) of HSWA directs the U.S. Environmental Protection Agency
(EPA) to promulgate regulations for the monitoring and control of air
emissions from hazardous waste TSDF as may be necessary to protect human
health and the environment. Standards are being developed by EPA under the
authority of §3002 and §3004 of RCRA to reduce organic air emissions from
TSDF. The standards would apply to owners and operators of permitted and
interim status TSDF under RCRA Subtitle C. This document presents informa-
tion used in the development of the proposed RCRA air emission standards
for TSDF.
1.1 CONTROL OPTIONS
To select a basis for the proposed standards, EPA identified and eval-
uated a variety of possible strategies for applying organic air emission
controls to TSDF. Each strategy considered by EPA is referred to as a
"control option." Different control options were identified by varying the
types of waste management units that would need to use emission controls
and the level of organic air emission reduction that would be required for
1-1
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the emission controls. Each control option defines a unique set of wastes
(based on the volatile organic content of the waste) and organic air emis-
sion control levels that allows EPA to perform an analysis to estimate the
nationwide human health and environmental impacts expected to occur if
standards based on a particular control option were promulgated. The EPA
compares the control option impacts relative to a common set of reference
values called the "baseline." The baseline represents the estimated human
health and environmental impacts that would occur in the absence of devel-
oping the standards.
The EPA selected five control options for analysis. All five of the
control options would require that all TSDF tanks, surface impoundments,
and containers managing hazardous waste with a volatile organics content
greater than a specified concentration use emission controls. The speci-
fied volatile organic concentration at which a waste stream would be
required to use emission controls is referred to as the "action level."
The primary differences between the control options are the value used for
the action level and whether a closed vent system and control device are
used in combination with the cover for the tank and surface impoundment
units requiring emission controls. A detailed description of the five
control options is presented in Chapter 5.0 of this document.
1.2 HEALTH AND ENVIRONMENTAL. IMPACTS
In evaluating the health and environmental impacts of the emission
control options, EPA relied primarily on the use of computerized analytical
models. These models are complex computer programs that process a wide
variety of information and data concerning the TSDF industry in the United
States. The data processed by the model include results from nationwide
surveys of the TSDF industry, characterizations of TSDF processes and
wastes, as well as engineering simulations of the relationships between:
(1) waste management unit type, the quantity and composition of the waste
managed in the unit, and the air emission mechanism; (2) air emission
control technology, control efficiencies, and associated capital and
operating costs; and (3) population exposure to TSDF air emissions and
resulting nationwide cancer incidence.
The Source Assessment Model (SAM) provides estimates of the nationwide
impacts by summing the estimated facility impacts across all facilities in
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the model. Further information on the emission models and emission
estimates is included in Appendix C; the SAM is further discussed in
Appendix D. The estimated emissions were used as input to dispersion and
risk models that produce an estimate of risk and cancer incidence in the
exposed population. These health effects were estimated based on a
composite unit risk factor, which is an emission-weighted average of the
unit risk factors for the individual organic carcinogens contained in the
emissions. The Human Exposure Model was used to estimate cancer incidence,
and the Industrial Source Complex Long-Term Model was used to estimate the
maximum lifetime risk to the most exposed individual (MET). The health
effects analysis included cancer risk to the MEI and noncancer impacts,
which may be long-term (chronic) or short-term (acute) health effects. The
assessment methodology for chronic, noncancer effects involves a comparison
of estimated ambient concentrations with reference air concentrations, or
health "thresholds." Additional information on the health effects analyses
is included in Appendixes E and J. The estimated health and environmental
impacts of the selected control options are shown in Table 1-1.
1.3 COST AND ECONOMIC IMPACTS
Estimates of the nationwide costs for the control options .are based on
estimates of the control costs for individual waste management units within
a TSDF. For each control option, EPA developed a detailed estimate of the
total capital investment, annual operating costs, and total annual costs of
each emission control technology applied to each waste management unit. To
obtain nationwide costs from model unit costs, a weighted average model
unit control cost was derived for each control applied to each waste
management unit. These control costs, divided by the weighted average
model unit throughput, provided cost factors used to generate control cost
estimates for each TSDF. The SAM was used to generate nationwide costs by
summing individual facility costs across all facilities. Additional
information on the cost impacts for the control options is presented in
Chapter 7.0.
The%economic analysis results indicate that all five control options
are projected to have small impacts—less than 1 percent—on the unit cost
of hazardous waste management services at facilities that treat and dispose
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TABLE 1-1. RESIDUAL HEALTH AND ENVIRONMENTAL EFFECTS OF
CONTROL OPTIONS FOR TSDF ORGANIC AIR EMISSIONS9
Control
option
number
BASELINE
1
2
3
4
5
Action
level ,
ppm
--
0
500 '
500
1,500
3,000
Organic
emissions,
103 Mg/yr
1,800
92
96
130
140
180
Cancer
incidence,
cases/yr
140
5.9
6.4
8.4
14
16
Maximum
individual
risk,
lifetime
2 X ID'2
5 x 10-4
5 x ID'4
5 x 10-4
P v m-4
o x ID ^
9 x ID'4
TSDF - Treatment, storage, and disposal facility.
— = Not applicable.
aControl options 1 through 5 apply to wastes containing organics at con-
centrations greater than the action level associated with the particular
option. They entail covers and control devices for tanks (including waste
fixation) and impoundments, and covers and submerged loading of containers.
For covered storage and quiescent treatment tanks, venting to a control
device is required if the vapor pressure of the waste in the tank exceeds
10.3 kPa (1.5 psi) for control options 1, 2, 4, and 5. No control devices
are applied to covered storage and quiescent treatment tanks in control
option 3. The impacts presented in this table are only for the TSDF units
affected by the proposed standards.
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these wastes. The unit-cost increases for storage-only facilities are
substantial for several industrial sectors when viewed as a share of
hazardous waste management costs. These cost increases translate into
nationwide compliance costs of between $4 million and $31 million for
storage-only facilities. The economic analysis is further described in
Chapter 8.0.
1-5
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2.0 REGULATORY AUTHORITY AND STANDARDS DEVELOPMENT
This chapter presents an overview of EPA's regulatory framework for
controlling organic air emissions from hazardous waste treatment, storage,
and disposal facilities (TSDF). Regulatory authority for the control of
air emissions from hazardous waste TSDF under the Resource Conservation and
Recovery Act (RCRA), as amended, is discussed in Section 2.1. The EPA's
standards development plan for controlling waste management air emissions
under RCRA and the Clean Air Act (CAA) is summarized in Section 2.
2.1 REGULATORY AUTHORITY
In November 1984, Congress passed the Hazardous and Solid Waste
Amendments to the Resource Conservation and Recovery Act of 1976. As
amended, RCRA §3004 authorizes EPA to establish standards that regulate the
operation of hazardous waste TSDF. Air emission standards are required
under §3004(n), which states:
... the Administrator shall promulgate such regulations for the
monitoring and control of air emissions at hazardous waste
treatment, storage, and disposal facilities, including but not
limited to open tanks, surface impoundments, and landfills, as
may be necessary to protect human health and the environment.
Section 3004(n) does not confer new authority, but rather requires the
Agency to exercise its preexisting authority to control air emissions from
hazardous waste management. Several rulemakings related to the control of
air emissions already have been undertaken by EPA under RCRA authority.
For example, EPA has promulgated standards for the control of air emissions
from hazardous waste incinerators (40 CFR 264, Subpart 0). Standards for
air emissions from the burning of hazardous waste in boilers and industrial
furnaces and amendments to Subpart 0 standards were proposed April 27, 1990
(55 FR 17862). The Agency also has promulgated standards under 40 CFR 264
and 265 for windblown dust from wastepiles, landfills, and land treatment
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operations. Additionally, final standards for miscellaneous units and for
research, development, and demonstration units under 40 CFR 264, Subparts X
and Y, contain provisions that require prevention of air releases that may
have adverse effects on human health or the environment.
Air emissions from hazardous wastes are generated or released from
numerous sources at TSDF. Air emission sources identified by EPA to date
include waste treatment processes such as distillation and fixation, equip-
ment leaks, surface impoundments, tanks, containers, landfills, wastepiles,
and land treatment facilities. Organic air emissions from hazardous wastes
managed in these sources include photochemically reactive and nonphotochem-
ically reactive organics, some of which are toxic or carcinogenic, and also
may include toxic or carcinogenic inorganic compounds. Depending on the
source, particulates (including metals, aerosols of organics, dust, as well
as toxics and carcinogens) also may be released. Reduction of the toxic or
carcinogenic emissions will reduce the incidence and risk of both cancer
and noncancer health effects in the exposed population; reduction of ozone
precursors in the organic emissions also will assist in reducing ozone
formation.
2.2 STANDARDS DEVELOPMENT FOR WASTE MANAGEMENT AIR EMISSIONS
Given the wide variety of TSDF sources and the complex analyses and
data required to assess emissions from these sources and their impacts, EPA
is taking several separate actions. On June 21, 1990 (55 FR 25454), EPA
promulgated standards for the control of organic air emissions from
(1) hazardous waste management process vents associated with distillation,
separation, fractionation, air or steam stripping, and thin-film evapora-
tion processes under Subpart AA to 40 CFR Parts 264 and 265, and (2) leaks
in piping and other equipment managing hazardous waste under Subpart BB to
40 CFR Parts 264 and 265.
The EPA also is further addressing the potential health effects
resulting from exposure to particulate emissions at TSDF. This is being
done through development of detailed guidance to supplement existing
standards under 40 CFR 264 and 265 for windblown dust from landfills, land
treatment facilities, and wastepiles.
The standards developed for proposal that are supported by this
background information document (BID) would control the class of organic
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air emissions from surface impoundments, tanks (including vents on closed,
vented tanks), containers, and waste fixation process units. The EPA is
also evaluating the need for standards to control emissions of individual
chemical constituents from these sources. Standards for individual consti-
tuents will be developed separately in the future as necessary to address
residual health risk that may remain after controls are implemented for
organic emissions as a class.
The control options and their associated environmental and health risk
impacts for organic air emissions from surface impoundments, tanks,
containers, and waste fixation process units are discussed in Chapters 5.0
and 6.0 of this document. The evolution of the standards for these sources
is described in Appendix A of this document. As discussed in Appendix A,
this BID reflects revisions that have been made based on comments received
since the May 18, 1988, meeting of the National Air Pollution Control
Techniques Advisory Committee. In the next step of the standards develop-
ment process, a draft proposal package will be assembled and reviewed by
the EPA Assistant Administrators and the Administrator for concurrence
before the standards are proposed in the Federal Register. Information
received and generated in studies in support of the proposed standard is
available to the public in Docket F-90-CESP-FFFFF on file in Washington,
D.C.
As part of the Federal Register notice of proposal, the public is
invited to participate in the standard-setting process. The EPA invites
written comments and will hold one or more public hearings to receive
comments on the proposed standards from interested parties. All public
comments will be analyzed, and written responses will be prepared. A
document will be prepared that summarizes the comments and provides the
Agency's responses. If public comments indicate that changes to the
proposed standards are warranted, the standards will be revised accordingly
before publication in the Federal Register.
2-3
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3.0 INDUSTRY DESCRIPTION AND AIR EMISSIONS
This chapter presents a brief overview of the hazardous waste industry
and a summary description of the techniques used in estimating nationwide
organic air emissions for hazardous waste treatment, storage, and disposal
facilities (TSDF) in the United States. The hazardous waste industry and
TSDF emission sources are described in Section 3.1. The estimation of TSDF
nationwide emissions is presented in Section 3.2. Emission estimation
techniques include the development and use of (1) TSDF emission models,
which provide a mechanism for analyzing air emissions from TSDF management
processes and applicable emission control technologies, and (2) a computer
program developed to process the data and information on the TSDF industry
and to perform emission calculations based on the available data. Discus-
sions of air pollution controls and control strategies at TSDF follow in
Chapters 4.0 and 5.0, respectively.
3.1 THE HAZARDOUS WASTE INDUSTRY
The hazardous waste.industry in the United States i-s diverse and com-
plex. The universe of hazardous waste generators represents a broad spec-
trum of industry types and sizes. Wastes generated vary considerably in
both composition and form; and the waste management processes and practices
used in treating, storing, and disposing of hazardous wastes are also
widely varied. Figure 3-1 presents a simplified waste system flow chart
for the hazardous waste industry. Key elements of the industry are: gene-
ration, transportation, treatment, storage, and disposal. The major ele-
ments of the hazardous waste industry are discussed in the following sec-
tions.
3.1.1 General Hazardous Waste Description
General waste descriptions include hazardous wastes in the following
forms: contaminated wastewaters, spent solvents residuals, still bottoms,
3-1
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spent catalysts, electroplating wastes, metal-contaminated sludges,
degreasing solvents, leaded tank bottoms, American Petroleum Institute
(API) separator sludges, off-specification chemicals, and a variety of
other waste types. In reviewing waste data, more than 4,000 chemical con-
stituents have been identified as being contained in the various waste
types examined.1
Title 40 of the Code of Federal Regulations (CFR), Part 261.3 (40 CFR
261.3), defines hazardous waste as four categories:
• Characteristic wastes—wastes that exhibit any hazardous
characteristic identified in 40 CFR 261 Subpart C, includ-
ing: ignitibility, corrosivity, reactivity, or extraction
procedure (EP) toxicity
Listed waste—wastes listed in 40 CFR 261, Subpart D
Mixture rule wastes—wastes that are (1) a mixture of solid
waste and a characteristic waste unless the mixture no
longer exhibits any hazardous characteristic, or (2) a mix-
ture of a solid waste and one or more listed hazardous
wastes
* Derived from rule wastes—anv solid waste generated from the
treatment, storage, or disposal of a hazardous waste,
including any sludge, spill residue, ash, emission control
dust, or leachate (but not including precipitation runoff).
Hazardous wastes are designated by Resource Conservation and Recovery
Act (RCRA) alphanumeric codes. Codes D001 through D017 are referred to as
"characteristic wastes." D001 represents wastes that are ignitible in
character; D002, those that are corrosive; and D003, those that are reac-
tive. Extracts of wastes that contain toxic concentrations of specific
metals, pesticides, or herbicides are assigned one of the codes D004
through 0017.
"Listed wastes" encompass four groups of alphanumeric codes published
in 40 CFR 261, Subpart D. Hazardous wastes generated from nonspecific
industry sources such as degreasing operations and electroplating are
listed as codes beginning with the letter "F," e.g., FOOl. Hazardous
wastes from specific generating sources such as petroleum refining are
assigned codes beginning with the letter "K," e.g., K048. Waste codes
beginning with "P" or "U" represent waste commercial chemical products and
manufacturing chemical intermediates (whether usable or off-specification).
3-3
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40 CFR 261, "Identification and Listing of Hazardous Wastes," not only
lists hazardous wastes but also identifies specific wastes that are
excluded from regulation as hazardous. These excluded wastes can be
stored, treated, or disposed of without a RCRA permit.
3.1.2 Generators
The overwhelming majority of hazardous wastes are produced by large-
quantity generators, those firms that generate more than 1,000 kg of
hazardous waste per month. It has been estimated that there are about
71,000 large-quantity generators of hazardous waste in the United States.2
These generators account for 99 percent of the 275 million Mg/yr of hazard-
ous waste produced and managed under RCRA in 1985.3 Hazardous waste gener-
ators are most prevalent in the manufacturing industries (standard indus-
trial classification [SIC] codes 20-39). Manufacturing as a whole accounts
for more than 90 percent of the total quantity of hazardous waste gener-
ated. Among specific industries, the chemical, petroleum, metals, electri-
cal equipment, and transportation industries are the major generators of
hazardous wastes. Two industry groups that stand out as generators are the
chemical and petroleum industries (SIC 28 and 29); these industries alone
account for more than 70 percent of total waste generation. The chemical
industry (SIC 28), with only 17 percent of the generators, generated
68 percent of all the hazardous wastes produced in 1981. Another prominent
group in the manufacturing sector was metal-related industries (SIC 33-37);
these industries generated about 22 percent of all hazardous wastes in
1981.4
The 1981 Survey of Hazardous Waste Generators and Treatment, Storage,
and Disposal Facilities (Westat Survey)5 showed that only 15 percent of the
generators were nonmanufacturing or unclassified under SIC. The survey
results also provide estimates of number of generators producing specific
types of hazardous wastes. Just over half the generators indicated that
they generate spent solvents, both halogenated and nonhalogenated (RCRA
waste codes F001-F005). Generators of sludges from wastewater treatment
systems associated with electroplating and coating operations and gener-
ators of quenching and plating bath solutions and sludges accounted for
16 percent of the generator population. Only 10 percent of the generators
3-4
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generated listed hazardous wastes from specific industrial sources (e.g.,
slop oil emulsion solids from the petroleum refining industry—K049).
Forty-three percent of generators produce ignitible wastes (RCRA waste code
D001), a third generated corrosive wastes (D002), and more than a quarter
generated wastes that failed EPA's test for toxicity (0004-D017). Just
under 30 percent of the generators reported hazardous wastes that were
spilled, discarded, or off-specification commercial chemical products or
manufacturing chemical intermediates ("P" and "U" prefix waste codes).
The physical characteristics of the 275 million Mg of RCRA hazardous
waste managed in 1985 vary from dilute wastewater to metal-bearing sludges
to soils contaminated with polychlorinated biphenyl (PCB). Over 90 percent
(by weight) of RCRA hazardous waste is in the form of dilute aqueous waste.
The remaining'wastes are organic and inorganic sludges and organic and
inorganic solids. Figure 3-2 categorizes hazardous waste by physical char-
acteristics.
Although small-quantity generators (those that generate more than
100 kg and less than 1,000 kg of hazardous waste per month) represent a
large proportion of the number of hazardous waste generators nationally
(more than 26,000)J they account for only a very small fraction of the
hazardous wastes generated. About 25 percent of the country's hazardous
waste generators are small-quantity generators, but these generators con-
tribute less than one-half of 1 percent of the total hazardous waste gener-
"ated.8 The majority of the small-quantity generators are automotive repair
firms, construction firms, dry cleaners, photographic processors, and
laboratories. The wastes produced by small-quantity generators span the
full spectrum of RC£A hazardous wastes. According to EPA's National Small
Quantity Hazardous Waste Generator Survey,9 the majority of small-quantity
generator waste is derived from lead acid batteries; the remainder includes
such hazardous wastes as acids, solvents, photographic wastes, and dry
cleaning residues.
3.1.3 Transporters
Once a RCRA hazardous waste is generated, it must be managed (i.e.,
stored, treated, or disposed of) in accordance with legal requirements.
Although nearly all hazardous waste is managed to some degree at the site
3-5
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Aqueous Liquids
(252 X 106 Mg)
Organic Sludges (2 X 106 Mg)
Organic Liquids
(4X 106 Mg)
Inorganic Solids
{2 X 106 Mg)
Aqueous Sludges
(15 X 106Mg)
Figure 3-2. Estimate of physical characteristics of RCRA hazardous wastes.6
3-6
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where it is generated, the Westat Survey has shown that only about one in
six generators manage their hazardous waste exclusively onsite.10 Of those
generators that ship hazardous wastes to offsite management facilities for
treatment, storage, and disposal, roughly a quarter still manage part of
their hazardous wastes onsite. Although the survey estimated that 84 per-
cent of the generators ship some or all of their hazardous wastes offsite,
the vast majority of the quantities of hazardous waste are nonetheless
managed onsite. Data supplied by generators indicate that about 96 percent
of all generated hazardous wastes are managed onsite, with only 4 percent
being shipped offsite for treatment, storage, or disposal.
In response to the movement of hazardous waste, a large industry has
developed that transports hazardous wastes from generators to TSDF. It has
been estimated that over 13,000 transporters are involved in moving hazard-
ous wastes by land or water from generators to TSDF.11
3.1.4 Treatment, Storage, and Disposal Facilities
A significant segment of the hazardous waste industry is involved in
hazardous waste management (i.e., treatment, storage, and disposal activi-
ties). Table 3-1 provides the RCRA definition of treatment, storage, and
disposal. TSDF must apply for and receive a permit to operate under RCRA
Subtitle C regulations. The RCRA Subtitle C permit program regulates 13
categories of waste management processes. There are four process categor-
ies each within storage and treatment practices and five categories within
disposal practices. Table 3-2 presents the 13 major categories by RCRA
process code.
Some of the 13 RCRA process categories can be further classified by
characteristics of the waste management processes. For example, tank
treatment may be quiescent or agitated/aerated (referring to the presence
or lack of movement/mixing of the liquid contained in the tank). Such
process varieties and similarities are reflected in the characterization of
the industry when estimating nationwide TSDF emissions. Figures 3-3
through 3-5 provide a more detailed look at examples of the various manage-
ment processes. As can be seen from the range of treatment and disposal
processes, the industry is complex and not easily characterized. The
hazardous waste industry is also dynamic; that is, in response to
3-7
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TABLE 3-1. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
HAZARDOUS WASTE MANAGEMENT DEFINITIONS3
Term
Definition
Storage
Treatment
Disposal facility
"Storage" means the holding of hazardous waste
for a temporary period, at the end of which the
hazardous waste is treated, disposed of, or -
stored elsewhere.
"Treatment" means any method, technique, or
process, including neutralization, designed to
change the physical, chemical, or biological
character or composition of any hazardous waste
so as to neutralize such waste, or so as to
recover energy or material resources from the
waste, or so as to render such waste non-
hazardous, or less hazardous; safer to
transport, store, or dispose of; or amenable
for recovery, amenable for storage, or reduced
in volume.
"Disposal facility" means a facility or part of
a facility at which hazardous waste is
intentionally placed into or on any land or
water, and at which waste will remain after
closure.
aDefinitions are presented as stated in RCRA regulations (40 CFR 260.10)
as of July 1, 1986.12
3-8
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TABLE 3-2. NATIONWIDE QUANTITY OF HAZARDOUS WASTE MANAGED BY
SPECIFIC PROCESSES
Waste
management
process
RCRA Number of active
process facilities with
code process9
Waste quantity
managed,3 10^ Mg/yr
Storage
133
Container
Tank
Wastepile
Impoundment
Treatment
Tank
Impoundment
Incineration
Otherb
Disposal
Injection well
Landfill
Land treatment
Ocean disposal
Impoundment
Totalc
SOI
S02
SOS
S04
T01
T02
T03
T04
D79
D80
D81
D82
D83
1,440
911
57
223
291
127
158
319
61
90
54
NA
47
>2,300
154
49
275
RCRA = Resource Conservation and Recovery Act,
NA = Not available.
aBased on the 1986 Screener Survey.!3 Excludes facilities that manage
less than 0.01 Mg/yr in storage, treatment, and disposal processes.
Quantities were not reported in this survey by specific management
process.
b"0ther" refers to physical, chemical, thermal, or biological treatment
processes not occurring in tanks, surface impoundments, or incinerators.
cFacilities do not add up to about 2,300 because some facilities have more
than one process. Waste quantities presented do not add to the total of
275 million Mg of hazardous waste produced and managed in 1985 because
some facilities may process a waste in more than one management process.
For example, a waste may be stored prior to treatment or treated prior to
disposal.
3-9
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changing demands and regulations, the facilities change the ways wastes are
treated, stored, and disposed of.
The total estimated quantity of hazardous wastes managed at more than
2,300 TSDF in 1985 was 275 million Mg. The waste quantities handled by
each of the three main waste management processes (i.e., treatment, stor-
age, and disposal) are presented in Table 3-2. The waste quantities given
in Table 3-2 will not sum to the total national estimate because some
wastes pass through more than one process; for example, a waste may be
stored prior to treatment or treated prior to disposal. Also provided in
Table 3-2 is a breakdown of the number of active TSDF by specific type of
treatment, storage, or disposal process. In the storage category, con-
tainer storage is a management process utilized by more than half the TSDF;
tank storage occurs at slightly more than a third of the TSDF. Of the
treatment processes, tank treatment is widely practiced, but no single
treatment process is used in a majority of facilities. In the disposal
category, landfills are the dominant disposal units operated at TSDF.
The information presented above is taken from a TSDF data base of
waste management practices compiled for use in examining the industry and
its environmental and health impacts. Three data bases were used to gener-
ate this TSDF data base. Two major sources were the Hazardous Waste Data
Management System (HWDMS)14 and the 1981 Westat Survey, both of which are
EPA Office of Solid Waste (OSW) data bases. More recent information from
the OSW 1986 National Screening Survey of Hazardous Waste Treatment, Stor-
age, Disposal, and Recycling Facilities (1986 Screener) was also used to
make the TSDF data base as current as possible.15 Each of these three data
bases provided a different level of detail regarding particular aspects of
the TSDF industry. For example, the HWDMS provided waste management proc-
ess codes, wastes codes, and facility SIC codes. The 1986 Screener pro-
vided information on total annual waste quantities managed by the facility
and operating status (active or closed) for the entire industry. The
Westat Survey, on the other hand, deals with only a subset of the industry
but provides a greater level of detail regarding individual facility
operations; for example, the distribution of waste quantities handled by
each waste management process is available for each facility in the data
base.
3-13
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3.1.5 TSDF Emission Sources
The organic emission sources associated with each type of storage,
treatment, and disposal process are summarized in Table 3-3. The emission
sources in this table are arranged into six categories based on their
common emission characteristics and/or their routine association with other
processes. These are (1) impoundments and tanks, (2) land treatment,
(3) landfills and wastepiles, (4) transfer and handling operations, (5)
injection wells, and (6) incinerators.
For open (or uncovered) surface impoundments and tanks, the major
source of organic emissions is the uncovered liquid surface exposed to the
air. The conditions under which liquids are stored in uncovered impound-
ments and uncovered tanks ranges from quiescent to highly turbulent since,
in some cases, aeration and/or agitation are applied to aid in treatment of
the waste. Emissions tend to increase with an increase in surface turbu-
lence because of enhanced mass transfer between the liquid and air. For
both uncovered and covered storage tanks, loading and breathing losses are
a major source of emissions.
At land treatment facilities, wastes are either spread on or injected
into the soil, after which they are normally tilled into the soil. Other
activities that are likely to occur at land treatment facilities include
transfer, storage, handling, and dewatering of the wastes to be land-
treated. Examples would include loading and unloading of wastes in vacuum
trucks and dewatering of wastes using one of the various types of available
filtration devices. Each of the land treatment process stages illustrated
in Figure 3-3 is a potential source of organic air emissions. The major
emission source associated with land treatment is the land treatment area
itself.
A landfill is a facility, usually an excavated, lined pit or trench,
into which wastes are placed for disposal. Some existing landfills may not
be lined; however, all new facilities are lined to meet RCRA permit
requirements. All wastes containing liquids and destined for disposal in a
landfill must be treated or "fixed" to form a nonliquid material. The
landfilling of waste is a source of organic emissions from several emission
3-14
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TABLE 3-3. HAZARDOUS WASTE MANAGEMENT PROCESS EMISSION SOURCES
Management process
Emission source
Impoundments and Tanks
(S04, T02, D83) (S02, T01)
Quiescent impoundments
(storage & treatment)
Quiescent tanks
(storage & treatment)
Uncovered
Covered
Aerated/agitated impoundments
(treatment)
Aerated/agitated uncovered tanks
(treatment)
Impoundment lining
Impoundment inlet
Quiescent liquid surface
Quiescent liquid surface
Working and breathing losses
Turbulent liquid surface
Turbulent liquid surface
Dredging (exposed waste
surface)3
Splash loading13
Land Treatment (D81)
Land application
Dewatering devices
Landfills (D80) and Wastepiles (S03)
Active landfill
Application of waste to soil
Applied waste before tilling
Applied waste after tilling
Vacuum pump exhaust for vacuum
filters3
Exposed waste surface in belt
filter presses .
Filter cake collection and
disposal
Transport of waste to landfill
(open trucks)
Unloading and spreading of .
wastes
Landfilled waste
Leachate (within the confines
of the liner system)
(continued)
3-15
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TABLE 3-3 (continued)
Management process
Emission source
Landfills and Wastepiles (con.)
Closed landfill
Wastepiles
Waste fixation
Pit and mixer
Drum
Transfer and Handling Operations (SOI, S02)
Vacuum trucks
Open dump trucks
Equipment leaks0
Containers
Drums
Tank trucks
Railroad tank cars
Marine tankers
Barges
Dumpsters
Landfill surface gas vents and
manholes
Leachate (within the confines
of the liner system)
Wastepile surface
Leachate (within the confines
of the liner system)
Splash loading into fixation
pits'3
Mixing of waste and fixative
Mechanical mixer vents
Drum inspection3
Drum decanting3
In-drum fixation3
Vacuum pump exhaust
Spills during truck loading
Truck cleaning3
Waste surface during loading
and transport
Spills
Truck cleaning3
Losses from pumps, valves,
sampling connections, open-
end lines, and pressure-
relief devices
Waste loading
Spillage in transit
Spillage during waste loading/
unloading
Exposed waste surface
Cleaning losses3
(continued)
3-16
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TABLE 3-3 (continued)
Management process
source category
Emission source
Injection Wells (D79)d
Incinerators (T03)e
Exhaust gas stacks
aNo emission estimating method exists for this source.
&No emission estimating method exists for this source. Unlike enclosed
sources such as tanks, this is an open'source and vapor saturation does
not occur.
Emissions from equipment leaks are associated with all management
processes that involve the use of pumps, valves, sampling connections,
open-ended lines, and pressure-relief devices.
dThis management process is being regulated under a different standard.
The equipment leak emissions related to the injection well disposal
process are evaluated in this document.
elncinerator emission sources, such as exhaust gas stacks, are regulated
under 40 CFR 264, Subpart 0, "Incinerators." The equipment leak emissions
related to incineration are evaluated in this document.
3-17
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points, as illustrated in Figure 3-3. This figure shows typical process
stages for two variations in landfill processing; each of the processing
steps identified is a potential emission source. The landfill surface,
whether open, covered with earth daily, or closed with a cap is an emission
source. A waste fixation pit is another source of organic emissions that
could be associated with landfills. Activities at the landfill, such as
waste transport and waste unloading and spreading, are also sources of
emissions. Wastepiles are similar to landfills and the same emission
sources can be found; they are, in essence, temporary landfills.
Each of the process steps illustrated in Figure 3-5 is a potential
emission source associated with hazardous waste transfer, storage, and
handling operations. Loading operations contribute to overall emissions,
especially splash loading of waste as opposed to submerged loading. Spills
also occur during waste transfer and handling and, for liquid wastes that
are pumped, emissions may occur from fugitive sources such as pumps and
valves or at open-ended lines, pressure-relief valves, and sampling connec-
tions. Organic emissions are associated with all three of the storage
methods shown in Figure 3-5: drums, dumpsters, and tanks.
Miscellaneous sources of emissions such as drum cleaning or the crush-
ing and landfilling of empty drums containing waste residues also contrib-
ute to organic air emissions. The improper handling of drum residue can
lead to emissions along with waste residues lost to the environment by
uncontained drum crushing operations. In addition, RCRA permit conditions
require annual dredging of surface impoundments; the dredging operation, a
waste transfer process, may also be a source of organic emissions.
3.2 ESTIMATES OF ORGANIC EMISSIONS
A modeling approach based on applicable mass transfer equations was
selected as the method of estimating organic emissions from TSDF. Models
initially developed by the EPA Office of Solid Waste were refined to incor-
porate inputs relevant to estimating air emissions. The models selected
for use are formulated for individual management processes at TSDF and
account for such factors as process design and operating parameters as well
as the meteorological effects on emissions. These emission models were
used to generate estimates of the amounts of organics in the incoming
3-18
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wastes that are emitted to the air or biodegraded during processing. More
traditional emission estimating techniques and methodologies, such as
basing emission estimates on the results of a limited number of actual TSDF
source tests, are not appropriate for the diverse operations found in this
industry. The TSDF industry and its waste management processes are too
varied to use source test data as the sole basis to estimate industry-wide
emissions.
The use of emission models makes it possible to generate emission
estimates under a wide variety of source conditions and waste compositions.
The accuracy of estimates made by the emission models in comparison to
actual field measurements of emissions for specific sites has been exam-
ined. That comparison is discussed in Appendix C. In general, it was
found that, where comparisons could be made, emission model estimates com-
pared favorably with field data. Appendix F contains the TSDF source test
data.
The following sections describe the bases for developing estimates of
organic compound emissions from TSDF using the modeling approach. Section
3.2.1 discusses the elements necessary for producing nationwide emission
estimates for individual waste management units. Section 3.2.2 discusses
how those elements are combined in a single computer model to produce the
nationwide emission estimates.
3.2.1 Emission Estimation Data Requirements
Key elements in the estimation of organic emissions from TSDF are the
availability of: (1) facility-specific information, (2) management process
emission characteristics, and (3) waste compositions. Facility-specific
information and data include the types of waste management processes pres-
ent in those facilities, the RCRA waste codes managed at the facilities,
and the total quantity of waste managed for each of the facilities nation-
wide. Some facility-specific information is available through data bases
established for other EPA projects, e.g., the HWDMS, the 1981 Westat Sur-
vey, and the 1986 Screener (refer to Appendix D, Section D.2.1.4, for a
description of how these data sources are used). Where facility-specific
data such as waste compositions and management process characteristics
(e.g., aerated versus quiescent operations) are insufficient, estimated
3-19
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values based on existing data bases of industry-specific waste compositions
and operating practices are used. (See Appendix D, Sections D.2.2 and
D.2.4, for waste composition and operating practice discussions, respec-
tively.) Section 3.2.2.1 describes the facility information available for
the generation of nationwide estimates.
In addition to facility-specific data, emitting characteristics of the
waste management units are needed to estimate nationwide emissions. Typi-
cally, emission measurements are made at the source and those measurements
serve as the basis for characterization of similar emission sources. In
the case of TSDF, there is a diversity of sources and factors within a
source that have a significant impact on emissions, waste composition being
a major one; this variation makes estimation of nationwide TSDF emissions
directly from only measured data impractical. Other factors that restrict
this approach include the overall lack of emission test data for the range
of TSDF management processes and the absence of standardized test methods
that allow meaningful comparisons of available emission data to be made.
As an alternative, emission models have been adapted to facilitate genera-
tion of waste management process emission estimates. These emission models
are presented in Appendix C, Section C.I. To use the emission models, it
is necessary to define certain waste management unit design and operating
characteristics (such as surface area and waste retention time for surface
impoundments). Given that this level of detail is not available for most
facilities, process parameters based on model management units were devel-
oped for use in calculating emissions (also, costs of control and emission
reductions). Using survey results and information from other sources such
as design manuals and site visit reports, model units were developed in
terms of operating and design parameters spanning typical ranges of surface
area, retention times, and other characteristics representative of the TSDF
industry. A sensitivity analysis was conducted for each model to determine
which input parameters, over what range, have significant effects on emis-
sion model estimates. Appendix C, Section C.2, discusses the sources of
information and rationale used to develop the TSDF model units and lists
the specific characteristics of each model waste management unit that are
needed to compute emissions using the appropriate emission model.
3-20
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The other key element in estimating emissions is the composition of
the waste in the waste management unit. The specific chemicals found in
each waste management unit nationwide are not known. However, facility-
specific data described above do identify RCRA waste codes and their
management process codes. Existing data bases of waste compositions are
available by industrial category for waste codes. These waste codes allow
the assignment of waste compositions to process codes in order to estimate
emissions. These data bases have been combined into a single data base
that contains waste compositions for over 300 SIC codes. The data base
presents waste composition as a function of SIC, RCRA waste codes, and
their physical/chemical forms. The file is described briefly in Section
3.2.2.2 and described in detail in Appendix D, Section D.2.2.
Table 3-4 presents the relative emissions predicted by the emission
models for selected model waste management units. This table lists pre-
dicted uncontrolled organic emissions by model unit for five different
model waste compositions. The specific compositions of the five model
wastes are given in Appendix C, Section C.2.2, along with the rationale for
their development. The results in Table 3-4 illustrate the variability in
emissions that may occur from waste management units for different waste
compositions. The table also shows emission variability between waste
management units for the same waste type. No conclusions should be drawn
from this latter comparison without considering the differences in waste
throughput between the waste management units. It should be pointed out
that, to the extent possible, the composition and quantities of the actual
waste streams processed at the existing facilities were used in estimating
nationwide emissions. The model wastes are presented here to illustrate
the variability in potential air emissions in relation to waste composition
and management process.
In calculating nationwide TSDF air emissions, emission models are used
with the model waste management unit design and operating characteristics
to produce emission factors for the model units. The model unit emission
factors are estimates of the fraction of specific organic compounds enter-
ing the waste management unit that become air emissions from that unit.
Derivation of these emission factors involves combining the steps discussed
3-21
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TABLE 3-4. SUMMARY OF SELECTED MODEL HAZARDOUS WASTE MANAGEMENT UNIT
UNCONTROLLED ORGANIC EMISSION ESTIMATES FOR MODEL WASTES (Mg/yr)a
Model unit**
Covered storage tank
(S02D) .
Covered quiescent
treatment tank (T01E)
Quiescent uncovered
storage tank (S02I)
Quiescent uncovered
treatment tank (T01B)
Quiescent storage
impoundment (S04C)
Quiescent treatment
impoundment (T02D)
Quiescent disposal
impoundment (D83A)
Uncovered aerated/
Aqueous
sludge/
slurry
0.117
0.24
24
34
686
946
842
870
Model
Dilute
aqueous
2.12
4.6
8.1
19
159
269
130
130
waste
Organic
liquid
0.437
1.19
514
954
--
—
—
_ _
type
Organic
s;ludge/
slurry
1.11
1.40
586
1,026
--
--
--
_ _
Two-phase
aqueous/
organic
0.891
1.94
9.7
31
183
326
16,000
— _
agitated treatment
tank (T01G)
Aerated/agitated treat-
ment impoundment
(T02J)
1,920
390
Waste fixation (Fixation 4,110
Pit B)
Drum storage (S01B) 0.0036
Dumpster storage (S01C) 0.72
Wastepiles (S03E) 139.7
0.0000909
0.0236 0.0298
0.049 1.44
380
31,700
0.000181
100
(continued)
3-22
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TABLE 3-4 (continued)
Model unitb
Landfill-active (D80E)
Landfill -closed (D80H)
Land treatment (D81C)
Aqueous
sludge/
slurry
358C
0.068
269
Model waste type
Organic
Dilute Organic sludge/
aqueous liquid slurry
—
—
21.6
Two-phase
aqueous/
organic
29QC
2.09
--
— = Indicates this model unit does not manage this model waste type, thus an
uncontrolled emission estimate is not available.
aThis table lists the estimated organic emissions for selected model waste
management units when the listed model wastes are managed in those units.
The model unit definitions are given in Appendix C, Section C.2.1. The
model waste compositions are also described in Appendix C, Section C.2.2.
These compositions and resulting emission estimates are not intended to be
representative of nationwide TSDF operations but rather are presented to
illustrate the variability in potential air emissions in relation to the
waste composition and management process.
parenthetical listings are the model unit designations under which the
model unit definitions can be found in Appendix C, Section C.2.2.
cThis estimate does not assume that regulations restricting land disposal of
bulk liquids are in effect.
3-23
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previously in this section with a knowledge of the properties of the com-
pounds for which emission factors are required. The development of emis-
sion factors is explained in detail in Appendix D, Section D.2.4.
3.2.2 Nationwide TSDF Emissions
Nationwide organic air emissions from the TSDF industry were estimated
using the Source Assessment Model (SAM), a computerized simulation program
designed to generate nationwide emissions estimates on a facility, waste
management unit, or emission source basis. Summation of individual facil-
ity results provides the nationwide emission estimate. The SAM utilizes a
variety of information and data concerning the TSDF industry to calculate
emissions. The SAM processes the information and data from a number of
input files that contain TSDF-specific information (facility location,
waste management processes used, and types and quantities of wastes man-
aged), waste characterization data (approximate compositions of typical
wastes), and air emission model estimates (emission factors based on char-
acteristics of both TSDF waste management units and waste types).
Because of the complexity of the TSDF industry and the current lack of
detailed information for all TSDF, it is unlikely that the SAM estimates
are accurate for an individual facility. However, it is believed that the
SAM emission estimates are a reasonable approximation on a nationwide basis
and the TSDF modeling approach provides the best basis for analysis of
options for controlling TSDF air emissions.
A brief discussion of the input data files, assembled for and used by
the SAM to calculate air emissions, and the output emissions files gen-
erated by the SAM are presented in the following sections of this chapter.
Figure 3-6 outlines the main SAM files and functions used in estimating
nationwide emissions from the TSDF industry. The SAM, its data inputs and
outputs, and the overall logic used in the model's calculations are dis-
cussed in more detail in Appendix D.
3.2.2.1 SAM Input Files. There are four main data files that are
inputs to the SAM nationwide uncontrolled emission estimates: the Industry
Profile (a file of waste management practices for each TSDF in the Nation),
the waste characterization file (also referred to as the Waste Characteri-
zation Data Base), the chemical properties file, and the emission factors
3-24
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INPUT FILES
OUTPUT
Industry
Profile
Waste
Characterization
File
Chemical
Properties
File
Emission
Factors
File
SAM
Processor
Nationwide TSDF
Uncontrolled
Emissions
Figure 3-6. Source Assessment Model (SAM) input files used in estimating nationwide
treatment, storage, and disposal facilities (TSDF) uncontrolled air emissions.
3-25
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file. These inputs provide the information and data necessary to calculate
nationwide TSDF uncontrolled emissions.
3.2.2.1.1 Industry Profile. The Industry Profile data base was
developed to provide a list of TSDF nationwide and to describe facility-
specific waste management practices in terms of the types and quantities of
wastes handled and the processes utilized. Several hazardous waste indus-
try surveys and data bases, available through EPA's Office of Solid Waste,
serve as the basis of the SAM Industry Profile (see Appendix D, Section
D.2.1). The information and data from each of these surveys and data bases
were used in the SAM to estimate nationwide emissions and impacts of poten-
tial control options.
The information that the SAM uses from the Industry Profile to esti-
mate nationwide emissions includes the following for each TSDF: (1) facil-
ity identification number (FCID), (2) location coordinates of the facility,
(3) the primary SIC code for the facility, (4) the RCRA waste codes managed
at the TSDF, (5) the waste quantity for each of the waste codes, and
(6) the management process codes applicable to each waste code. It is
important to note that the SIC and waste codes link the facility to the
waste characterization file, which gives estimated waste compositions.
3.2.2.1.2 Waste characterization file. This waste characterization
file contains waste data that have been compiled to represent chemical-
specific waste compositions for each waste found within an SIC code. An
RCRA waste may be generated in one of several physical/chemical forms; for
example, a waste may be an aqueous liquid or an organic sludge. The waste
characterization file contains the composition of waste streams in terms of
chemical constituents and their respective concentrations for each physi-
cal/chemical form of a waste associated with a particular RCRA waste, code..
in an SIC category. If specific chemical constituents were not found in
the original data, chemical assignments were made based on a review of
similar TSDF processes. Wherever available, specific chemicals were
retained in the waste characterization file. The data provided in the
waste characterization file are accessed by the SAM for each TSDF emission
calculation. (See Appendix D, Section D.2.2, for a more detailed discus-
sion.)
3-26
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3.2.2.1.3 Chemical properties file. Emission estimation for each of
the more than 4,000 waste chemical constituents identified in the waste
characterization file would require property data for all compounds; many
of which are not available. Therefore, to provide the emission models with
appropriate constituent physical, chemical, and biological properties, the
waste constituents were categorized and grouped into classes based on
volatility (i.e., vapor pressure or Henry's law constant) and
biodegradation. These categories were defined to represent the actual
organic compounds that occur in hazardous waste streams and serve as
surrogates for the particular waste constituents in terms of physical,
chemical, and biological properties in the emission calculations carried
out by the SAM. (See Appendix D, Section D.2.3, for a more detailed
discussion.)
3.2.2.1.4 Emission factors file. For each waste management process
(e.g., aerated surface impoundment or treatment tank), the respective emis-
sion models applicable to the process were used to determine the amount or
fraction of the organic compound entering the unit that is emitted to the
air and the fraction that is biodegraded. The calculations were made for
each chemical surrogate category for each waste management process. In
addition to emission factors for process-related emissions, emission fac-
tors developed for transfer and handling-related emissions were also incor-
porated into the SAM program file. The emission factors used for estimat-
ing TSDF emissions in this document were calculated using the TSDF air
emission models as presented in the March 1987 draft of the Hazardous Waste
Treatment, Storage, and Disposal Facilities: Air Emission Models, Draft
Report.16 since that time, certain TSDF emission models have been revised.
A new edition of the air emission models report was released in December.
1987.17 7he principal changes to the emission models involved refining the
biodegradation component of the models for biologically active systems
handling low organic concentration waste streams. With regard to emission
model outputs, the changes from the March 1987 draft to the December 1987
version affected, for the most part, only aerated surface impoundments and
result in a minor increase in the fraction emitted for the chemical
surrogates in the high biodegradation categories.18 For the other air
emission models, such as the land treatment model, which were also revised
3-27
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to incorporate new biodegradation rate data, the changes did not result in
appreciable differences in the emission estimates. Since the December 1987
report version was issued, new data on biodegration rates have been
obtained and comments were received.19 Based on these data and comments,
the biodegradation model for aerated wastewater treatment systems was
further revised to incorporate Monod kinetics. Additional investigation
and comments led to an evaluation of changes to the model units used for
aerated tanks and impoundments. These changes improve the technical basis
for the biodegradation model. However, the combined effect of these
changes did not significantly affect the estimated nationwide emissions and
other impacts presented in this document.20 Therefore, the emission
factors remain based on the March 1987 draft of the air emissions model
report and the model unit definitions were not changed. (Appendix C,
Section C.I.1.1.3, contains more details on the biodegradation modeling and
Appendix D, Section D.2.4, contains a more extensive discussion of emission
factors.)
3.2.2.2 Uncontrolled Nationwide Emissions. The SAM computes nation-
wide uncontrolled TSDF emissions by first identifying particular waste
management process units within the facility from the Industry Profile.
Once a management process is identified, the SAM then calculates emissions
on a chemical-by-chemical basis. The quantity of a particular chemical in
the waste stream is multiplied by the appropriate emission factor, which is
determined by the chemical, physical, and biological properties of the
chemical. Emissions for the unit are the sum of the emissions for each
chemical constituent in the waste stream. Emissions for each management
process unit can then be summed; emissions from source categories (manage-
ment units with similar emission characteristics, e.g., quiescent storage.
impoundments and quiescent treatment impoundments) are then summed to yield
a nationwide emission estimate.
The nationwide emission estimates for the current TSDF community are
based on 1985 data containing general operating conditions and practices,
the time covered by the most recent TSDF industry survey. These emission
estimates are considered to represent the uncontrolled situation or case;
review of the existing applicable State regulations has shown a wide varia-
tion in level of control required for these sources, with many States
having no control requirements for TSDF.
3-28
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The uncontrolled nationwide TSDF emission estimate as determined by
the SAM is 1.8 million Mg of organic emissions annually. The breakdown of
nationwide emissions by source category is provided in Table 3-5. (Chap-
ter 6.0 presents additional information on these uncontrolled emissions.)
Table 3-5 shows that storage tanks are estimated to be the single largest
emitting source nationwide. Treatment tanks and impoundments that are
aerated to promote biological activity are the second highest single
source. These two source categories combined account for about 70 percent
of the annual emissions estimated.
3.3 REFERENCES
1. Memorandum from Coy, David, RTI, to Docket. December 9, 1987.
Hazardous waste treatment, storage, and disposal facility (TSDF) uni-
verse of waste constituents.
2. U.S. Environmental Protection Agency. Summary Report on RCRA Activi-
ties for May 1986. Office of Solid Waste. Washington, DC. June 16,
1986. p. 4.
3. U.S. Environmental Protection Agency. The Hazardous Waste System.
Office of Solid Waste and Emergency Response. Washington, DC. June
1987. p. 1-4.
4. Westat, Inc. National Survey of Hazardous Waste Generators and Treat-
ment, Storage and Disposal Facilities Regulated Under RCRA in 1981.
Prepared for the U.S. Environmental Protection Agency, Office of Solid
Waste. April 1984. p. 141.
5. Reference 4, p. 65.
6. Reference 3, p. 2-3.
7. Reference 2, p. 4.
8. Abt Associates, Inc. National Small Quantity Hazardous Waste Genera-
tors Survey. Prepared for the U.S. Environmental Protection Agency,
Office of Solid Waste. Washington, DC. February 1985. p. 2.
9. Reference 8, p. 2.
10. Reference 4, p. 69.
11. Reference 2, p. 4.
12. Code of Federal Regulations. Title 40, Part 260.10. Definitions.
U.S. Government Printing Office. Washington, DC. July 1, 1986.
p. 340-347.
3-29
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TABLE 3-5. NATIONWIDE UNCONTROLLED TSDF ORGANIC EMISSION ESTIMATES9
Source category
Nationwide uncontrolled emissions,
103 Mg/yr
Drum storage
Dumpster storage
Storage tanks
Quiescent surface impoundments'3
Quiescent treatment tanks
Aerated/agitated tank and surface
impoundments
Wastepiles
Landfills
Waste fixation
Incineration0
Land treatment
Spills
Loading
Equipment leaks
0.19
78
756
209
48
515
0.13
40
2.1
0.88
73
0.43
6.8
80
Total
1,810
TSDF ~ Treatment, storage, and disposal facility.
aThis table presents the nationwide estimates of uncontrolled TSDF organic
emissions generated by the Source Assessment Model described in Appendix
D. Emissions are presented for management processes that have similar
emission characteristics, i.e., source categories.
^Includes quiescent surface impoundments used for both storage, treatment,
or disposal.
cUncontrolled incinerator emissions includes emissions from wastes that
are routinely incinerated with stack exhaust gas emission controls.
These sources are currently regulated under 40 CFR 264 Subpart 0. The
uncontrolled emission scenario does not include wastes that are or would
be incinerated as a result of implementing the RCRA land disposal
restrictions (LDR). The baseline and two example control strategies do,
however, account for the incinerator emissions resulting from the LDR.
The emission scenarios are explained in Chapter 5.0.
3-30
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13. Memorandum from Maclntyre, Lisa, RTI, to Docket. November 4, 1987.
Data from the 1986 National Screening Survey of the Hazardous Waste
Treatment, Storage, Disposal and Recycling Facilities used to develop
the Industry Profile.
14. Memorandum from Maclntyre, Lisa, RTI, to Docket. November 4, 1987.
Data from the National Hazardous Waste Data Management System used to
develop the Industry Profile.
15. Reference 13.
16. Research Triangle Institute. Hazardous Waste Treatment, Storage and
Disposal Facilities: Air Emission Models, Draft Report. Prepared for
U.S. Environmental Protection Agency. Office of Air Quality Planning
and Standards. Research Triangle Park, NC. March 13, 1987.
17. U.S. Environmental Protection Agency. Hazardous Waste Treatment,
Storage, and Disposal Facilities (TSDF)--Air Emission Models.
Research Triangle Park, NC. Publication No. EPA-450/3-87-026.
December 1987.
18. Memorandum from Coy, D., RTI, to Docket. January 1989. Investigation
of and Recommendation for Revisions to Aerated Model Unit Parameters
Used in the Source Assessment Model.
19. Chemical Manufacturers Association. Comments of the Chemical
Manufacturers Association on the Environmental Protection Agency
Document "Hazardous Waste TSDF - Background Information for Proposed
RCRA Air Emission Standards - Volumes I and II." Washington, D.C.
July 11, 1988. 105 p.
20. Reference 18.
3-31
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4.0 CONTROL TECHNOLOGIES
A variety of control technologies is available that can be used to
reduce organic air emissions from hazardous waste treatment, storage, and
disposal facilities (TSDF). All of these control technologies are not
applicable to all TSDF emission sources. The applicability of a control
technology to a TSDF emission source depends on the type of waste manage-
ment unit as well as the characteristics of the hazardous waste managed in
the unit. The purpose of this chapter is to introduce the control technol-
ogies that are potentially applicable to TSDF emission sources. Chapters
5.0 through 7.0 present analyses to evaluate the organic air emission
reductions, health risk and environmental impacts, and costs for implement-
ing alternative combinations of the control technologies to TSDF emission
sources on a nationwide basis.
4.1 APPLICATION OF CONTROL TECHNOLOGIES TO TSDF EMISSION SOURCES
4.1.1 Control Technology Categories
Control technologies applicable for TSDF organic air emission reduc-
tion can be classified into five major categories:
• Suppression controls
• Add-on controls
• Organic removal and hazardous waste incineration processes
• Process modifications
• Work practice improvements.
Suppression controls contain or capture the organics at the TSDF
emission source. For example, placing a cover on the surface of the waste
contains the organics in the waste medium and inhibits the release of
4-1
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organic vapors to the atmosphere. Installing an enclosed waste management
unit in place of an open unit or erecting an enclosure over an existing
waste management unit captures the organic vapors released from the waste
and allows the control of the vapors using an add-on control device.
Add-on controls reduce organic air emissions by removing organics from
the captured vapor stream prior to discharge of the gases to the atmos-
phere. This is achieved by extraction of the organics from the vapor
stream or by destruction of the organics in the vapor stream.
Organic removal and hazardous waste incineration processes remove
volatile organics from the hazardous waste before the waste arrives at the
next TSDF waste management unit. These processes offer an alternative to
using add-on controls to control organic air emissions after they have been
emitted from the TSDF unit. The type of organic removal or incineration
process used varies depending on the hazardous waste forms.
Process modifications achieve organic air emission reductions by
changing the equipment or procedures used to manage hazardous waste.
Work practice improvements are steps that the TSDF personnel can
implement during everyday waste management unit operations to minimize
organic air emissions. For example, programs can be implemented to
promptly detect and repair leaking equipment.
This chapter presents descriptions of the control technologies that
are potentially applicable to the TSDF emission source categories identi-
fied in Chapter 3.0. The control technologies are organized using the five
control technology categories described above and presented in the order
listed in Table 4-1.
4.1.2 Organic Air Emission Control Efficiency
The effectiveness or efficiency of each control technology to. reduce
organic air emissions is a key parameter used for the TSDF control option
analyses presented in Chapters 6.0 and 7.0. The preferred method for
determining the potential organic air emission control efficiency for a
particular control technology is by the source testing of full-sized
control devices. Unfortunately, source testing is not practical for
certain types of control technologies because of the large area that must
be enclosed to obtain accurate results or physical conditions that prevent
measurement devices from being placed at the source of the emissions.
4-2
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TABLE 4-1. TSDF CONTROL TECHNOLOGY CATEGORIES
Suppression controls
Fixed-roof tanks
Floating roof tanks
Pressure tanks
Floating membrane covers
Air-supported structures
Flexible membrane covers
Rigid membrane covers
Rigid structures
Add-on controls
Carbon adsorbers
Thermal vapor incinerators
Catalytic vapor incinerators
Flares
Boilers and process heaters
Condensers
Absorbers
Organic removal and hazardous waste, incineration processes:
Steam stripping units
Air stripping units
Thin-film evaporation (TFE) units
Batch distillation units
Dewatering units
Hazardous waste incinerators
Process modification
• Coking of petroleum refinery sludges
• Mechanical mixing for waste fixation
• Submerged loading of containers
• Subsurface injection
Work practice modification
• Leak detection and repair
• Drum storage area housekeeping
4-3
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Consequently, the control efficiency must be estimated using information
such as laboratory test data and mathematical models.
This chapter discusses the organic air emission control efficiencies
that each control technology is capable of achieving when applied to TSDF
emission sources. The source test data used to determine the control
efficiencies for many of the control technologies are summarized in Appen-
dix F. Appendix H presents detailed descriptions of the methodology and
calculations used to determine the control efficiencies for the control
technologies for which no source test data could be obtained.
4.1.3 Secondary Air and Cross-Media Impacts
The control technologies applicable to TSDF emission sources achieve
organic air emission reductions by using physical, chemical, and thermal
processes that may create additional environmental impacts. The impacts
resulting from the emission of non-organic air pollutants are termed
"secondary air impacts." The impacts from production of new liquid or
solid wastes are termed "cross-media impacts."
Control technologies based on extraction processes remove the volatile
organics in the form of liquid or solid by-products. Often these
by-products can be recycled or burned as a fuel. However, in some situa-
tions, there is no other alternative but to dispose the by-products as
wastes, thereby creating additional demands on wastewater treatment units
and landfills. Control technologies based on destruction processes convert
organic vapors to carbon dioxide, water, and small quantities of various
other chemical compounds. Depending on the original organic composition in
the waste, non-organic air pollutants may be formed that need to be con-
trolled. Supplying electricity and process steam required to operate
certain TSDF control technologies may create air emissions, wastewater
discharges, and solid wastes from non-TSDF sources such as industrial
boilers and utility power plants.
Because a control technology may produce secondary air and cross-media
impacts, the human health and environmental benefits from the organic air
emission reduction that can be achieved by applying the control technology
to TSDF emission sources are evaluated relative to the secondary air and
cross-media impacts produced by implementing the control technology. This
4-4
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chapter identifies the types of secondary air and cross-media impacts
associated with each of the control technologies. Chapter 6.0, Section
6.3, presents the results of the secondary air and cross-media impacts
analysis.
4.2 SUPPRESSION CONTROLS
Suppression controls consist of covers and enclosures. These controls
serve to keep the volatile organics in the hazardous waste process streams
instead of being released to the atmosphere. However, the potential
remains that the volatile organics in the waste could ultimately be
released to the atmosphere from a point downstream in the storage, treat-
ment, or disposal of the waste unless suppression controls are used in
conjunction with add-on control, organic removal, or process modification
control technologies.
Covers that directly contact the waste medium suppress the volatiza-
tion of the organics by creating a physical barrier at the waste surface.
There is no or very little vapor space between the waste surface and the
underside of the cover where volatile organic vapors can collect. The
effectiveness of a cover in suppressing organic air emissions depends on
the permeability of the cover, the leak rate at the cover edges and from
any fittings on the cover, and the frequency that the cover is opened to
add or remove material from the waste management unit.
Organic air emissions can also be suppressed by forming a closed vapor
space above the waste surface. Enclosing the vapor space can be achieved
by erecting a structure around the entire waste management unit or, for
some types of open-top units, installing a rigid cover. The organic vapors
from the waste are confined by the enclosure and prevented from being
emitted to the atmosphere. However, if the enclosure vents directly to the
atmosphere, the enclosure suppression effectiveness will be diminished
significantly. Therefore, many types of enclosures must be used in
combination with an add-on control device to provide effective TSDF organic
air emission control.
4.2.1 Fixed-Roof Tanks
A fixed-roof tank is a vertical cylindrical steel wall tank with a
cone-shaped or dome-shaped roof that is permanently attached to the tank
4-5
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shell (see Figure 4-1).1 Vents are installed on the roof to prevent the
tank internal pressure from exceeding the tank design pressure limits and,
thereby, causing physical damage or permanent deformation to the tank
structure. The vents can either open directly to the atmosphere, be
equipped with valves that open at specified pressure or vacuum settings, or
be connected to an add-on control device (e.g., carbon adsorption system,
vapor incinerator).
Storage or treatment of organic-containing liquid or sludge wastes in
fixed-roof tanks instead of open-top tanks reduces organic air emissions.
By covering the tank, the waste surface is sheltered from the wind. This
decreases the mass transfer rate of organic compounds in the waste to the
atmosphere. The extent to which organic air emissions are reduced varies
on many factors including waste composition and concentrations, windspeed,
and the ratio of the tank diameter to the depth of the liquid contained in
the tank.
Theoretical and empirical models have been developed to study open-top
and fixed-roof tank emissions. Several of these models were selected for
the TSDF analyses and are described in Appendix C, Section C.I.I. Using
the models, estimated organic air emission from a 76 m3 (20,000 gal) open-
top tank were compared to an equivalently sized fixed-roof tank storing the
same type of waste material. This analysis is described in Appendix H,
Section H.2.1. For a windspeed of 4.5 m/s (10 mph), the estimated organic
air emissions from the fixed-roof tank are 86 to 99 percent lower than the
open-top tank emissions depending on waste composition. Thus, using fixed-
roof tanks in place of open-top tanks can provide significant suppression
efficiencies.
An existing open-top tank can be converted to a fixed-roof tank by
retrofitting the tank with a dome roof. Aluminum, geodesic dome roofs are
available from several manufacturers.2,3 These domes have been used suc-
cessfully to cover petroleum and chemical storage tanks. The domes are
clear-span, self-supported structures (i.e., require no internal columns be
placed in the tank) that can be installed on open-top tanks ranging in
diameter from 5 to over 100 m (15 to over 330 ft).
4-6
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Eaccb
Maahol*
Hoizl. (For
fill
or dr*lnaz«)
Typical fixed roof tank.
External floating roof tank.
7«ne
7csc—•
Kanhol*
Manhole
Rla Plmt«
Support Col
with Caluan
Contact Deck Type
l—' / \ \. TanK support Calix
/ \ with Coluaa v«l
£jt ?oacooo* —J \
^ 7«por Spac*
Noncontact Deck Type
Internal floating roof tanks.
Figure 4-1. Storage tank covers.
4-7
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Although fixed-roof tanks provide large reductions in organic air
emissions from open-top tanks, fixed-roof tanks still can emit significant
quantities of organics. The major sources of organic air emissions from
fixed-roof tanks are breathing losses and working losses.4 Breathing
losses occur from the expulsion of vapor through the roof vents because of
the expansion or contraction of the tank vapor space resulting from daily
changes in ambient temperature or barometric pressure. These emissions
occur in the absence of any liquid level change in the tank. Working
losses occur from the displacement of vapors resulting from filling and
emptying of the tank.
Breathing and working losses from fixed-roof tanks can be reduced by
installing an internal floating roof, connecting the tank roof vents to an
add-on control device, or installing pressure-vacuum relief valves on the
tank roof vents. The use of internal floating roofs in fixed-roof tanks is
discussed in Section 4.2.2.
For add-on control applications, vapors are contained in the tank
until the internal tank pressure attains a preselected level. Upon
reaching this level, a pressure switch activates a blower to collect the
vapors from the tank and transfer the vapors through piping to the add-on
control device. As a safety precaution, flame arresters normally are
installed between the tank and control device. Other safety devices may be
used such as a saturator unit to increase the vapor concentration above the
upper explosive limit. Add-on control devices for organic vapors are
discussed in Section 4.3.
Fixed-roof tanks can be designed to operate safely at internal
pressures up to 35 kPa (2.5 psig).5 The use of pressure relief valves to
control organic air emissions from a 38 m^ (10,000 gal) fixed-roof tank
storing volatile organic liquids has been investigated using emission
models.6 This analysis estimated that using pressure relief valves set at
35 kPa reduces breathing and working losses from a fixed-roof tank storing
high-volatility organic liquids by 20 to 45 percent. However, many
existing fixed-roof tanks are designed to operate at atmospheric pressure
and cannot be pressurized. Therefore, use of high-pressure relief valve
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settings for organic air emission control is limited to tanks specifically
built to design specifications for operating at elevated internal
pressures.
Fixed-roof tanks require no energy to operate. Use of fixed-roof
tanks at TSDF produces no secondary air or cross-media impacts.
4.2.2 Tank Floating Roofs
Floating roofs are used extensively in the petroleum refining,
gasoline marketing, and chemical manufacturing industries to control
organic air emissions from tanks storing volatile organic liquids. A tank
floating roof is basically a disk-shaped structure (termed a "deck") with a
diameter slightly less than the inside tank diameter that floats freely on
the surface of liquid stored in the tank. A seal is attached around the
outer rim of the deck to cover the open annular space between the deck and
inside tank wall. The seal mechanism is designed to slide against the tank
wall as the liquid level in the tank is raised or lowered. There are two
general types of tank floating roofs: external floating roofs and internal
floating roofs.
Floating roofs are appropriate for TSDF hazardous waste storage tanks
and certain treatment tanks where the presence of the floating cover would
not interfere with the treatment process. Treatment tanks equipped with
surface mixing or aeration equipment cannot use floating roofs. Also,
because floating roofs are in direct contact with the hazardous waste, the
materials selected to fabricate the deck and seals must be compatible with
the waste composition. This may prevent the use of floating roofs in tanks
containing certain types of hazardous waste (e.g., highly corrosive
wastes).
An external floating roof consists of a single- or double-layer steel
deck that moves within the walls of an open-top tank (see Figure 4-1).7
Pontoon sections often are added to the deck to improve floatation
stability. Because the top surface of the deck is exposed to the outdoors,
the external floating roof design must include additional components for
rainwater drainage and snow removal to prevent the deck from sinking, and
for cleaning the inside walls of the tank above the deck to protect the
sliding seal mechanism from dirt. A variety of seal types (e.g., metallic
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shoe seal, liquid-filled seal, or resilient foam-filled seal) and seal
configurations (e.g., mounted above liquid surface, mounted on liquid sur-
face) can be used for external floating roofs.8 Small openings are
required on the deck for various fittings such as vents, inspection
hatches, gage wells, and sampling ports.
An internal floating roof consists of a steel, stainless steel,
aluminum, or fiberglass-reinforced plastic deck that is installed inside a
fixed-roof tank (see Figure 4-1).9 Many internal floating roof designs can
be retrofitted into existing fixed-roof tanks. Because the fixed roof
shelters the deck from weather, internal floating roofs do not need addi-
tional components for rainwater drainage or for seal protection. An
internal floating roof is equipped with the same types of deck fittings
used on an external floating roof, but normally uses a simpler deck seal
mechanism (e.g., a single resilient foam-filled seal or wiper seal).10
Vertical guide rods are installed inside the tank to maintain deck align-
ment. The internal tank space above the deck must be vented to prevent the
accumulation of a flammable vapor mixture.
Floating roof tanks significantly reduce but do not eliminate organic
air emissions. Organic vapor losses termed "standing losses" occur at the
deck seals and fitting openings. The imperfect fit of the deck seals
allows gaps that expose a small amount of the liquid surface to the atmos-
phere. Small quantities of vapors that collect in the small openings under
the deck can leak from the deck fitting openings. Standing losses can be
reduced by installing secondary deck seals, selecting appropriate pressure-
relief valve settings, and using tight-gasketed and bolted covers on all
other fittings. Additional organic vapor losses termed "withdrawal losses"
occur from evaporation of the liquid that wets the inside tank wall as the
roof descends during emptying operations.
No emission source test studies of full-sized tanks equipped with
floating roofs have been conducted because of the complexity of erecting an
enclosure around a tank. However, emission test studies of full-sized
floating roof components sponsored by the American Petroleum Institute
(API) were conducted using a pilot-scale tank.11 The results of these
studies in combination with other data have been used by API and EPA to
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develop empirical models that estimate external and internal floating roof
tank standing and withdrawal losses.12
For the development of volatile organic liquid storage New Source
Performance Standards (NSPS), EPA analyzed the emission reduction effec-
tiveness of using floating roof tanks compared to fixed-roof tanks using
the empirical models.13 The percentage of reduction in emissions varies
with the tank characteristics (e.g., tank size, vapor pressure of the
material stored in the tank). A model tank was selected for the NSPS
analysis that has a volume of 606 m3 (160,000 gal), contains a volatile
organic liquid having a vapor pressure of 6.9 kPa (1 psia), and operates
with 50 turnovers per year. The analysis concluded that, depending on the
type of deck and seal system selected, installing an internal floating roof
tank in a fixed-roof tank will reduce volatile organic emissions by 93 to
97 percent. The analysis also concluded that a similar level of emission
reduction can be achieved using an external floating roof tank. %
Because many tanks at TSDF are smaller than 606 m3 (160,000 gal) and
contain hazardous wastes having vapor pressures less than 6.9 kPa (1 psia),
a separate analysis was performed to estimate the effectiveness of using
internal floating roofs to suppress TSDF organic air emissions. A detailed
description of this analysis is presented in Appendix H, Section H.2.1.
For this analysis, the model tank capacity of 76 m3 (20,000 gal) was used
with five different waste compositions that are representative of the range
of hazardous wastes managed at TSDF. Installing internal floating roofs is
estimated to reduce TSDF fixed-roof tank organic air emissions by 74 to 82
percent. Converting an open-top tank to a fixed-roof tank and installing
an internal floating roof is estimated to reduce emissions by 96 to 99
percent.
Floating roof tanks require no energy to operate. Use of floating
roof tanks at TSDF produces no secondary air or cross-media impacts.
4.2.3 Pressure Tanks
Pressure tanks are structurally designed to operate safely at internal
pressures above atmospheric pressure. Consequently, pressure tanks operate
as closed systems and do not emit organic air emissions at normal storage
conditions or during routine filling and emptying operations. Pressure-
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relief valves on the tanks open only in the event of improper operation
(e.g. overfilling the tank) or an emergency (e.g., exposure to excessive
heat).
There are two general pressure tank classes: tanks with internal
pressure operating ranges not exceeding 204 kPa (2 atm) termed "low-
pressure tanks," and tanks with operating pressure greater than 204 kPa
termed "high-pressure tanks".14 The design and shape of the pressure tank
depends on the internal pressure operating range-. Fixed-roof tanks can be
designed to operate at pressures up to 35 kPa (2.5 psig). Above this
pressure, noded spheroid and noded hemispheriod shapes normally are used
for low-pressure tanks. Horizontal cylinder and spheroid shapes generally
are used for high-pressure tanks.
Pressure tanks are closed systems and require no energy to operate.
Use of pressure tanks at TSDF produces no secondary air or cross-media
impacts.
4.2.4 Floating Membrane Covers
Similar to using a fixed-roof tank to manage hazardous waste, placing
a cover over a surface impoundment reduces the release of volatile organics
contained in the waste by preventing waste mixing due to wind blowing
across the unit. One type of cover available for application to surface
impoundments is a floating membrane cover. A floating membrane cover con-
sists of large sheets of synthetic, flexible membrane material that float
on the surface of a liquid or sludge. Individual, standard-dimension
sheets can be seamed or welded together to form covers applicable to any
size of surface impoundment.
Floating membrane covers have been used for many years to cover the
surface of potable water reservoirs. More recently, use of floating mem-
brane covers has been extended to applications that require the cover be
airtight, as in anaerobic sludge lagoons. One example of a state-of-the-
art floating membrane cover installation is the successful operation since
1987 of a floating membrane cover on a 2.8 ha (7 acre) surface impoundment
used as an anaerobic digester.15,16 jhis cover is required to be airtight
because a vacuum is pulled from under the cover to extract the methane gas
formed by the anaerobic process. The cover is fabricated from 2.5 mm
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(100 mil) thick high-density polyethylene (HOPE). Although HOPE is buoyant
in water, foam floats are placed under the membrane sheet to provide addi-
tional floatation and to form channels for collecting the methane. Two
blowers are used to pull a vacuum (maximum of 0.25 kPa or 1 in. of water
column) under the cover to extract the methane that accumulates in the gas
collection channels. The collected gas is vented to a system of three
flares.
Overall performance of the floating membrane cover in airtight
applications as demonstrated by the 2.5 mm HOPE cover described above is
good. No leaks have occurred in the HOPE seams. An initial problem with
leaking around access hatch lids on the cover was corrected by installing
positive seal hatch lids. To prevent the cover from sinking because of
rainwater accumulating on top of the cover, the cover is fabricated with
sufficient excess materials to form troughs that collect rainfall. Plastic
drainage pipes are placed in the troughs and connected to a pump that is
periodically operated to drain the accumulated rainwater off the cover.
Also, emergency gas vents are installed on the cover to prevent any buildup
of gas under the cover should the gas collection system blowers fail to
operate. These vents consists of short lengths of open-ended pipes that
extend a short distance below the liquid surface during normal operation.
The liquid seal prevents gases from being discharged through the vent.
Should a sufficient quantity of gas collect under the cover causing the
cover to bulge above the liquid surface, the vent inlet is lifted out of
the liquid, allowing the gas to be vented and the cover to return to its
normal position contacting the liquid surface.
Surface impoundments used for hazardous waste treatment are exempt
from the RCRA land disposal restrictions (40 CFR Part 268) if the treatment
residues that do not meet specific treatment standards are removed from the
impoundment for subsequent management within 1 yr of placement in the
impoundment. The application of floating membrane covers to these TSDF
surface impoundments will require that the cover allow for impoundment
cleaning. Because a floating membrane cover is heavy (e.g., 2.5 mm HOPE
weighs over 2 kg/m^ or approximately 10 ton/acre*?), routine removal of the
entire cover is impractical. Therefore, waste residues will need ,to be
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removed with the cover in place, requiring a sludge pumping or other type
of system to be installed on the bottom of the impoundment at the same time
the floating membrane cover is installed. This requirement may prevent the
use of a floating membrane cover for those TSDF surface impoundment appli-
cations where the residues on the impoundment bottom can only be removed by
draining the impoundment and scraping the material out of the impoundment
using heavy construction equipment (e.g., bulldozer, power shovel).
The application of a floating membrane cover to a TSDF surface
impoundment will require the cover to be made of a material that is resist-
ant to chemical and biological degradation from compounds in the waste
while also having good strength characteristics to resist tearing due to
wind stresses and long-term weather exposure. Floating membrane covers for
water reservoir and anaerobic digester applications have been fabricated
using HOPE or chlorosulfonated polyethylene (more commonly known as
Hypalon, a registered trademark of E.I. du Pont de Nemours & Co., Inc.) for
the membrane material. Because these materials have also been used for
lining hazardous waste landfills and surface impoundments, they are candi-
date materials for TSDF surface impoundment floating membrane covers--
provided the material is effective in controlling organic emissions.
The effectiveness of using a floating membrane cover for organic
emission control is a function of the amount of leakage from the cover
fittings and seams as well as the losses resulting from the permeation of
the membrane material by volatile organic compounds contained in the waste.
The successful application of floating membrane covers to anaerobic sludge
impoundments demonstrates that leakage from fittings and seams can be
reduced to very low levels by using a membrane material with adequate
thickness, installing proper seals on cover fittings and vents, and follow-
ing good installation practices to ensure the seams are properly welded and
to prevent tearing or puncturing the membrane material. Consequently, for
a properly installed floating membrane cover, the organic emission control
effectiveness is expected to be determined primarily by the permeability of
the cover to the organic constituents in the waste.
Permeability is a measure of how well a membrane material resists
allowing the organics to pass through the membrane. Permeation of a
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membrane material is a three-step process that involves the adsorption of
an organic by the material, diffusion of the organics through the material,
and evaporation of the organics on the air side of the membrane. The
permeability of a floating membrane cover is a function of the organic
composition and concentration of the waste managed in the surface impound-
ment as well as cover materials composition and thickness.
No source test-data are available to measure the effectiveness of a
floating membrane cover in controlling organic emissions from a surface
impoundment. However, an indication of the effectiveness of using floating
membrane covers applied to representative TSDF surface impoundments can be
estimated using theoretical mass transfer relationships. These estimates
suggest that a flexible membrane cover fabricated from HOPE can be an
effective organic emission control for hazardous waste managed in TSDF
surface impoundments. For example, the organic emission control levels
estimated for a 2.5 mm HOPE floating membrane cover range from approxi-
mately 50 percent to over 95 percent depending on the organic constituents
in the waste and the waste retention time in the surface impoundment. The
estimate procedure and calculations are described in Appendix H, Section
H.I.2. This procedure provides only an approximation of the effectiveness
of using floating membrane covers to control organic emissions because
certain assumptions must be made that simplify the actual mass transfer
conditions that occur in surface impoundments. Improved estimates of the
organic emission control effectiveness of using floating membrane covers
will be possible when the results from ongoing laboratory tests to measure
the organic permeability of potential membrane materials become available.
The only secondary air or cross-media impacts from application of
floating membrane covers would be any impacts attributed to the intermit-
tent operation of the small electric-powered or gasoline-powered pumps used
to drain rainwater off the cover.
4.2.5 Air-Supported Structures
An air-supported structure is a plastic-reinforced fabric shell that
is inflated and, therefore, requires no internal rigid supports. Figure
4-2 shows the major air-supported structure components.18 The structure
shape and support is provided by maintaining a positive interior pressure
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VINYL-COATED
POLYESTER BASE
FABRIC
BIAS HARNESS
NET SYSTEM
VEHICULAR
AIR-LOCK
INFLATION/HEATING
SYSTEM
PERSONNEL DOOR
Sources Air Structures International, Inc.
Figure 4-2. Typical air-supported structure.
4-16
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(i.e., the interior pressure is greater than the external atmospheric
pressure).
Large electric-motor driven fans are used to blow air continuously or
intermittently through the structure and out a vent system. The interior
pressure is maintained at a constant 10 to 15 kPa (1.25 to 1.5 inch of
water) for structure inflation. Adequate air changes are necessary to
prevent the organic vapor concentrations inside the structure from
exceeding the lower explosive limits. A standby blower system consisting
of internal combustion engine driven fans normally is installed to keep the
structure inflated and ventilated in the event of an electrical power
outage. The vent system can discharge directly to the atmosphere or be
connected to an add-on control device.
Large areas can be enclosed by erecting an air-supported structure.
Structures are commercially available ranging in widths from 24 to 91 m (80
to 300 ft) wide and lengths from 24 to 137 m (80 to 450 ft).1^ For larger
areas, a number of modules can be connected together. Air-supported
structures have been used as enclosures for conveyors and coke ovens, open-
top tanks, and material storage piles. A 4,000 m3 (1 acre) aerated
wastewater treatment lagoon at a specialty chemical manufacturing plant has
been covered by an air-supported structure for more than 4 years.20 Thus,
air-supported structures offer good potential as a suppression device for
TSDF surface impoundments that cannot use floating membrane covers (e.g.,
surface treatment impoundments using surface-mounted aeration equipment).
The fabric used for the air-supported structure depends on the size of
the structure, design requirements (e.g., wind and snow loadings), and type
of chemicals to which the fabric's inner side will be exposed. Polyvinyl-
fluoride-coated polyester fabric would likely be the material of current
choice for TSDF applications because of the fabric's=good resistance to
deterioration from chemical, weather, or ultraviolet sunlight exposure.
The service life of the fabric ranges from 2 to 12 years depending on the
site-specific conditions.
Anchoring the air-supported structure likely will be accomplished by
bolting the edges of the fabric to a continuous, grade-level concrete
footing or beam installed around the perimeter of the surface impoundment.
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Entrance into an air-supported structure is through airlocked doors. These
doors can be sized to allow earth-moving equipment to be used inside the
structure for impoundment cleaning operations.
The use of air-supported structures to enclose TSDF surface impound-
ments can result in excessive condensation and high temperatures inside the
structure. An air-supported structure's interior temperatures typically
are 5 to 11 °C (10 to 20 °F) above the ambient temperature.21 Conse-
quently, during hot summer days, temperatures inside an air-supported
structure can exceed 42 °C (110 °F). Depending on the severity of these
conditions, workers entering the structure may need to follow additional
safety procedures and be restricted as to the period of time they may
remain inside the structure. Also, any equipment operating inside the
structure may require more frequent repair or replacement because of
accelerated rust and corrosion of the equipment components.
The effectiveness of an air-supported structure in controlling organic
air emissions primarily depends on the amount of leakage from the structure
and whether the structure vent system is connected to an add-on control
device. Air-supported structure leaks are usually confined to areas around
airlocks, doors, and anchor points. Leak checks were performed at the air-
supported structure operating at the specialty chemical manufacturing plant
(refer to Appendix F, Section F.2.1.1). A soap solution was sprayed around
the structure base and fittings to locate leaks, and measurements were made
using a portable hydrocarbon analyzer. Few leaks were found, and the sizes
of the leaks ranged from 2 to 40 ppm. The operating experience at this
facility indicates that proper installation and maintenance of the air-
supported structure can limit leakage to very low levels.
Because of the very low leakage levels attainable, almost all of the
organic vapors contained by an air-supported stricture will be ultimately
discharged through the structure's vent system. Therefore, connecting the
vent system to one of the add-on control devices discussed in Section 4.3
will result in an overall organic air emission control efficiency for TSDF
applications using an air-supported structure that is approximately equiva-
lent to the efficiency of the control device. These add-on control devices
are capable of achieving control efficiencies in excess of 95 percent.
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Operation of an air-supported structure consumes large quantities of
electricity to maintain the positive interior pressure. For example, the
existing air-supported structure covering a 4,000 m3 aerated wastewater
treatment lagoon uses fans with a combined power rating of 26 kW (35 hp)
for structure inflation and ventilation.22 Annual electricity consumption
to operate continuously a standard 26 kW fan is approximately 250,000 kWh.
Application of air-supported structures to TSDF emission sources increases
demand for electricity and, consequently, would contribute to nationwide
electricity consumption impacts.
Any other air emissions, wastewater effluents, or solid wastes
associated with the use of air-supported structures at TSDF, are determined
by the type of add-on control device used in conjunction with the enclo-
sure. Add-on control device secondary air and cross-media impacts are
discussed in Section 4.3.
4.2.6 Flexible Membrane Covers
The flexible membrane cover is the analogous organic suppression
control to the floating membrane cover (described in Section 4.2.4) but for
application to wastepiles. A flexible membrane cover is simply a large
sheet of a synthetic, flexible membrane material that is placed over the
top of a wastepile. Like a floating membrane cover, individual, standard-
dimension sheets of the membrane material can be seamed or welded together
to form covers applicable to large wastepiles. The cover can be secured at
the perimeter using earth fill or another type of mechanical anchoring
system (e.g., cables attached to concrete piers). To obtain access to the
waste for addition or removal of material, the entire cover is lifted off
the wastepile or a section of the cover is folded back.
The material used to fabricate a flexible membrane cover to TSDF
applications needs to be resistant to chemical and biological degradation
from compounds in the waste while also having good strength and durability
characteristics to withstand the wear and tear of repeated handling and
weather exposure. No source test data are available to measure the effec-
tiveness of a flexible membrane cover in controlling organic emissions from
a wastepile. The effectiveness of the flexible membrane cover in control-
ling organic emissions is expected to be similar to that of a floating
membrane cover.
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Flexible membrane covers require no energy to operate. Use of
flexible membrane covers at TSDF produces no secondary air or cross-media
"impacts.
4.2.7 Rigid Membrane Covers
Rigid membrane covers consist of plastic-reinforced fabric that is
stretched over a rigid structural support system such as an aluminum frame
or a mast with tensioned cables.23 The fabric is supported above the waste
material so that a vapor space is formed between the waste surface and the
cover. Used with an add-on control device, this type of cover provides an
alternative to an air-supported structure for a TSDF surface impoundment.
Any non-organic air emissions, wastewater effluents, or solid wastes
associated with the use of rigid membrane covers at TSDF is determined by
the type of add-on control device used in conjunction with the cover. Add-
on control device secondary air and cross-media impacts are discussed in
Section 4.3.
4.2.8 Rigid Structures
A rigid structure is a permanent building that is designed to confine
air emissions from storage or processing operations. The configuration and
design of the building depend on the process requirements and site
conditions. Steel-frame construction with metal or reinforced fiberglass
panels most likely would be used for TSDF applications.
Existing applications of rigid structures to TSDF have been for
particulate matter and odor control from hazardous waste fixation proces-
ses. 24,25,26 These buildings are vented to wet scrubber control devices.
Other potential TSDF applications for rigid structures are to confine air
emissions from drum storage and processing operations.
Any non-organic air emissions, wastewater effluents, or solid wastes
associated with the use of rigid structures at TSDF is determined by the
type of add-on control device used in conjunction with the structure. Add-
on control device secondary air and cross-media impacts are discussed in
Section 4.3.
4.3 ADD-ON CONTROLS
Add-on controls are processes applied to captured organic vapors
vented from TSDF emission sources. These controls serve to reduce organic
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air emissions by destroying organics in the gas stream or extracting
organics from the gas stream before discharging the gas stream to the
atmosphere. Add-on controls for organic' air emissions are classified into
four broad categories: combustion, adsorption, condensation, and absorp-
tion. General background information about these types of add-on controls
is available in Reference 27. The type of add-on control best suited for a
particular TSDF emission source depends on the size of the source and the
characteristics of the hazardous waste managed by the TSDF source.
Combustion destroys the organics in the gas stream by oxidation of the
compounds to primarily carbon dioxide and water. Because essentially all
organics will burn, combustion add-on controls are applicable to all TSDF
emission sources for which the organic vapors can be captured. However,
combustion add-on controls will likely be used for those TSDF emission
sources where recovery of the organics is not practical or desirable.
Combustion add-on controls are thermal vapor incinerators, catalytic vapor
incinerators, flares, boilers, and process heaters.
Adsorption, condensation, or absorption processes can be used to
extract the organics from the gas stream. All of these processes are
capable of achieving very high levels of organic removal efficiencies.
However, adsorbers or condensers are likely to be less expensive than
absorbers for application to TSDF emission sources.
The type and magnitude of the secondary air and cross-media impacts
associated with add-on controls varies depending on the type of control.
However, all add-on control devices use electric-motor driven equipment
such as fans, blowers, and pumps. The electricity required to operate the
control device is supplied by the local electric utility or perhaps an
existing on-site cogeneration unit. Thus, add-on control device operation
increases demand for electricity, which in turn increases any air, water,
and solid waste impacts associated with the power plants that supply the
electricity. The types and quantities of these impacts varies depending on
the technology used to generate the electricity (e.g., fossil-fuel-fired
steam boiler, gas turbine, hydroelectric, or nuclear power plants) and, for
combustion power plants, the type of fuel burned (e.g., natural gas, coal,
municipal solid waste).
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4.3.1 Carbon Adsorbers
Adsorption as applied to air pollutant control is the process by which
organic molecules in a gas stream are retained on the surface of solid
particles. The solid most frequently used is carbon that has been proc-
essed or "activated" to have a very porous structure. This provides many
surfaces upon which the organic molecules can attach, resulting in a high
rate of organic removal from a gas stream as it passes through a bed of
carbon.
Activated carbon has a finite adsorption capacity. When the carbon
becomes saturated (i.e., all of the carbon surface is covered with organic
material), there is no further organic air emission control because all of
the organic vapors pass through the carbon bed. At this point (referred to
as "breakthrough"), the organic compounds must be removed from the carbon
before organic air emission control can resume. This process is called
desorption or regeneration.
For most air pollutant control applications, regeneration of the
carbon in the adsorber is performed by passing steam through the carbon
bed. The steam heats the carbon particles, which releases the organic
molecules into the steam flow. The resulting steam and organic vapor
mixture is condensed to recover the organics and separate the water for
discharge to a wastewater treatment unit. An alternative method for
regenerating the carbon is to reduce the pressure of the atmosphere
surrounding the carbon particles. Vacuum regeneration is used for special
carbon adsorber applications when direct recycling of the recovered
organics is desired such as vapor recovery at gasoline tank truck loading
terminals. A detailed description of carbon adsorption and desorption
mechanisms is available in Reference 28.
Two types of carbon adsorption systems most .commonly used for air
pollutant control are: fixed-bed carbon adsorbers and carbon canisters. A
fluidized-bed carbon adsorption system has been developed, but currently is
not commercially available.
Fixed-bed carbon adsorbers are used for controlling continuous,
organic gas streams with flow rates ranging from 30 to over 3,000 m3/min
(1,000 to over 100,000 ft^/min). The organic concentration can be as low
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as several parts per billion by volume (ppbv) or as high as 25 percent of
the lower explosive limit for the vapor stream constituents. The major
components of a fixed-bed carbon adsorber system are one or more carbon bed
units to adsorb the organics, a condenser to convert the desorbed organics
and steam mixture to a liquid, a decanter to separate the organic and
aqueous phases, and blowers to cool and dry the carbon beds following
desorption.
Fixed-bed carbon adsorbers may be operated in either intermittent or
continuous modes. For intermittent operation, the adsorber removes
organics only during a specific period of the day. Intermittent mode of
operation allows a single carbon bed to be used because it can be
regenerated during the off-line periods. This mode of operation would be
suitable for TSDF emission sources that operate one 8 to 10 hour shift per
day such as a waste fixation unit. For continuous operation, the unit is
equipped with two or more carbon beds so that at least one bed is always
available for adsorption while other beds are being regenerated. This mode
of operation would be suitable for TSDF emission sources that are in
operation 24 hours per day such as tanks and surface impoundments.
Carbon canisters differ from fixed-bed carbon adsorbers. First, a
carbon canisters is a very simple add-on control device consisting of a
0.21 m^ (55 gal) drum with inlet and outlet pipe fittings (see Figure
4-3).29 A typical canister unit is filled with 70 to 90 kg (150 to 200 Ib)
of activated carbon. Second, use of carbon canisters is limited to
controlling low volume gas streams with flow rates less than 3 nvVmin
(100 ft3/min).30 Third, the carbon cannot be regenerated directly in the
canister. Once the activated carbon in the canister becomes saturated by
the organic vapors, the carbon canister must be removed and replaced with a
fresh carbon canister. The spent carbon canister is then recycled or
discarded depending on site-specific factors.
For a carbon canister to be an effective organic air emission control
device, the canister must be replaced promptly when carbon breakthrough
first occurs. An automated, continuous organic analyzer could be used to
signal when carbon breakthrough occurs but is expensive relative to the
total capital cost of the carbon canister unit. Manual monitoring of
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Activated carbon
Support material
Figure 4-3. Carbon canister unit.
4-24
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carbon breakthrough can be conducted by a facility worker checking periodi-
cally to see whether the organic concentration at £he canister outlet has
increased significantly.31 A colorimetric detection test or a portable
instrument that measures organic concentration can be used to check the
canister outlet concentration. An alternative to monitoring is to replace
the carbon canister regularly based on a maintenance schedule. The
replacement interval would be a specified number of operating hours less
than the number of operating hours at which carbon breakthrough first
occurs.
The design of a carbon adsorption system depends on the inlet gas
stream characteristics including organic composition and concentrations,
flow rate, and temperature. Good carbon adsorber performance requires that
(1) the adsorber is charged with an adequate quantity of high-quality
activated carbon; (2) the gas stream receives appropriate preconditioning
(e.g., cooling, filtering) before entering the carbon bed; and (3) the
carbon beds are regenerated before breakthrough occurs.
Emission source test data for 12 full-sized, fixed-bed carbon adsorb-
ers operating in industrial applications has been compiled by EPA for a
study of carbon adsorber performance.32 The analysis of these data
concluded that for well-designed and operated carbon adsorbers continuous
organic removal efficiencies of at least 95 percent are achievable over
long periods. Several units have been shown to continuously achieve
organic removal efficiencies of 97 to 99 percent.
An equivalent level of performance for carbon canisters applied to
TSDF emission sources is indicated by the results of an emission source
test conducted on carbon canisters installed on the neutralizer tanks for a
wastewater treatment system at a specialty chemicals plant (refer to
Appendix F, Section F.2.2.1.2). This device was designed for odor control
and not organic removal. However, 100 percent removal was measured for
1,2-dichlorobenzene, benzene, toluene, chlorobenzene, and chloroform.
Overall organic removal efficiencies measured for various hydrocarbon
categories ranged from 50 to 99 percent.
High moisture content in the gas stream can affect carbon adsorber
performance for gas streams having organic concentrations less than
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1,000 ppm.33 At these conditions, water molecules compete with the organic
compounds for the available adsorption sites on the carbon particles.
Consequently, the carbon bed working capacity is decreased. Above an
organic concentration of 1,000 ppm, high moisture does not significantly
affect performance. Thus, to obtain good adsorber performance for gas
streams with a high relative humidity (relative humidity greater than
50 percent) and low organic concentration (less than 1,000 ppm) requires
preconditioning the gas stream upstream of the carbon bed. This can be
accomplished using a dehumidification system, installing duct burners to
heat the gas stream, or diluting the gas stream with ambient air. For TSDF
applications, these gas stream conditions would most likely occur at
locations where a carbon adsorber is used in conjunction with an air-
supported structure enclosing an aerated surface impoundment containing
dilute aqueous hazardous waste.
Carbon bed operating temperature can also affect carbon adsorber
performance. Excessive bed temperatures can result due to the release of
heat from exothermic chemical reactions that may occur in the carbon bed.34
Ketones and aldehydes are especially reactive compounds that exothermically
polymerize in the carbon bed. If temperatures rise too high, spontaneous
combustion will result in carbon bed fires. To avoid this problem, carbon
adsorbers applied to gas streams containing these types of compounds must
be carefully designed and operated to allow sufficient airflow through the
bed to remove excess heat.
Carbon adsorption control devices produce two types of cross-media
impacts: (1) wastewater effluent from the condensation of steam used to
regenerate spent carbon; and (2) solid waste from periodic replacement of
spent carbon. The magnitude of these impacts will depend primarily on the
type of carbon adsorption systems used (e.g., fixed-bed carbon adsorbers.
versus carbon canisters), the type of carbon regeneration used (e.g., steam
regeneration versus vacuum regeneration), and the spent carbon canister
management practices used (e.g., regenerate carbon or direct disposal of
carbon).
Most fixed-bed carbon adsorbers used for TSDF organic air emission
control are expected to use conventional low-pressure steam regeneration.
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After passing through the carbon bed, the steam is condensed and passed
through a decanter or distillation column to separate the condensed organ-
ics from the water. A wastewater effluent containing small quantities of
water soluble organics is produced. Also, the carbon cannot be regenerated
indefinitely. Gradual deactivation and attrition of the carbon in the
fixed-bed adsorber requires the carbon be replaced with fresh carbon
approximately once every several years. The spent carbon is either
recycled by returning it to the vendor for processing or discarded in the
appropriate disposal facility as determined by the spent carbon's waste
classification.
The waste classification of the spent carbon used for air pollutant
control applications will depend on the type of waste managed in the TSDF
unit that is being controlled by the carbon adsorption system. The spent
carbon from a particular TSDF control application may be determined to be a
hazardous waste if it exhibits any of the four hazardous waste characteris-
tics as defined by the Resource Conservation and Recovery Act (RCRA), Part
261 Subpart C. If the spent carbon is determined to be nonhazardous, it
may be possible to dispose the carbon in a municipal solid waste landfill
depending on the rules and policies affecting disposal at the landfill.
Otherwise the spent carbon from many TSDF will need to be disposed in a
hazardous waste landfill or incinerator.
The steam required for fixed-bed carbon adsorber regeneration most
likely will be supplied by an on-site industrial boiler. Production of the
steam required for regeneration creates secondary air emission impacts due
to the boiler air emissions. Because natural gas or distillate fuel oil
commonly is the type of fuel burned in industrial boilers, these impacts
primarily are expected to be increases in nitrogen oxides (NOX) and carbon
monoxide (CO) emissions.
Spent carbon canisters can be either recycled or discarded.35 The
type of spent carbon canister management practice used at a specific TSDF
location will depend on site-specific factors. Recycling involves removing
the spent carbon from the canister, regenerating the carbon, and then
repacking the canister with regenerated carbon plus any necessary makeup
carbon. If disposal is selected, the spent carbon and canister are sent to
an appropriate disposal site depending on the waste classification.
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4.3.2 Thermal Vapor Incinerators
Thermal vapor incineration is a controlled oxidation process that
occurs in an enclosed chamber. Figure 4-4 shows a simplified diagram of a
thermal vapor incinerator. One type of thermal vapor incinerator consists
of a refractory-lined chamber containing one or more discrete burners that
premix the organic vapor gas stream with the combustion air and any
required supplemental fuel. A second type of incinerator uses a plate-type
burner firing natural gas to produce a flame zone through which the organic
vapor gas stream passes. Packaged thermal vapor incinerators are commer-
cially available in sizes capable of handling gas stream flow rates ranging
from approximately 8 to 1,400 m3/min (300 to 50,000 ft3/min).36
Organic vapor destruction efficiency for a thermal vapor incinerator
is a function of the organic vapor composition and concentration, combus-
tion zone temperature, the period of time the organics remain in the
combustion zone (referred to as "residence time"), and the degree of turbu-
lent mixing in the combustion zone. Field emission testing and combustion
kinetic modeling analyses have been conducted to evaluate thermal vapor
incinerator organic destruction efficiencies.37-41 These analysis results
indicate that thermal vapor incineration destroys at least 98 percent of
non-halogenated organic compounds in the vapor stream at a temperature of
870 °C (1,600 °F) and a residence time of 0.75 seconds. If the vapor
stream contains halogenated compounds, a temperature of 1,100 °C (2,000 6F)
and a residence time of 1 second is needed to achieve a 98 percent
destruction efficiency.
Incinerator performance is affected by the heating value and moisture
content of the organic vapor stream, and the amount of excess combustion
air. Combustion of organic vapor streams with a heating value less than
1.9 MJ/m3 (50 Btu/ft3) usually requires the addition of supplemental fuel
(also referred to as auxiliary fuel) to maintain the desired combustion
temperature.42 Above this heating value, supplemental fuel may be used to
maintain flame stability. Although either natural gas or fuel oil can be
used as supplemental fuel, natural gas is preferred. Supplemental fuel
requirements can be decreased if the combustion air or organic vapor stream
is preheated.
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Thermal vapor incinerator exhaust gases are comprised mainly of carbon
dioxide and water. Using good thermal vapor incinerator design and operat-
ing practices limits CO and unburned hydrocarbon emissions to very low
levels. However, the combustion temperature levels required to achieve
good organic vapor destruction efficiency also promote the oxidation of
molecular nitrogen in the combustion air to produce NOX air emissions.
The quantity of NOX emitted from a thermal vapor incinerator is
affected by peak temperatures in the incinerator combustion zone, quantity
of excess combustion air used for incineration, and period of time combus-
tion gases are exposed to the peak temperatures. Additional quantities of
NOX can form if the vapor stream contains nitrogen compounds. A series of
EPA-sponsored source tests on three thermal vapor incinerators used to
control organic emissions from air oxidation plants measured incinerator
outlet NOX concentrations ranging from 8 to 200 ppmv.43 For vapor streams
not containing nitrogen compounds, the measured NOX concentrations were
less than 30 ppmv.
If compounds containing halogens are present in the organic vapor
stream, hydrogen chloride (HC1) will be formed when the vapors are
incinerated. Similarly, the presence of sulfur compounds in the vapor
stream results in the formation of sulfur oxides. These acid gases can be
controlled by venting the thermal vapor incinerator exhaust gases through a
wet scrubber. Water is normally used as the scrubbing agent increasing the
TSDF wastewater effluent discharge to an on-site wastewater treatment unit
or to a sewer for treatment by a publicly owned treatment works (POTW). To
meet effluent discharge requirements, it may be necessary to neutralize the
scrubber wastewater prior to discharge to the TSDF wastewater system. This
is normally accomplished by adding a caustic (e.g., sodium hydroxide) to
the wastewater producing small quantities of salts that must be disposed as
hazardous waste. . -
4.3.3 Catalytic Vapor Incinerators
Catalytic vapor incineration is essentially a flameless combustion
process. Passing the organic vapor stream through a catalyst bed promotes
oxidation of the organics at temperatures in the range of 320 to 650 °C
(600 to 1,200 °F).44 Temperatures below this range slow down or stop the
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oxidation reactions resulting in low destruction efficiencies. Tempera-
tures above this range shorten catalyst life or may even cause catalyst
failure. Oxidation of vapor streams with a high organic content can
produce temperatures well above 650 °C (1,200 °F). Consequently, high
organic concentration vapor streams may not be suitable for catalytic
incineration.
Figure 4-5 shows a simplified diagram of a catalytic vapor incinera-
tor. The device consists of a chamber where the gas stream vented from the
emission source is heated to the desired reaction temperature by mixing the
organic vapors with hot combustion gas from natural gas-fired burners. The
heated gas mixture then flows through the catalyst bed. The catalyst is
composed of a porous inert substrate material that is plated with a metal
alloy containing platinum, palladium, copper, chromium, or cobalt. A heat
exchanger is installed to preheat the vapor stream and, hence, reduce the
amount of fuel that must be burned.
Organic vapor destruction efficiency for catalytic vapor incinerators
is a function of organic vapor composition and concentration, catalyst
operating temperature, oxygen concentration, catalyst characteristics, and
the ratio of the volumetric flow of gas entering the catalyst bed to the
volume of the catalyst bed (referred to as "space velocity"). Destruction
efficiency is increased by decreasing the space velocity. However, a lower
space velocity increases the size of the catalyst bed and, consequently,
the incinerator capital cost. For a specific catalyst bed size, increasing
the catalyst bed temperature allows a higher space velocity to be used
without impairing destruction efficiency.
A series of studies have been sponsored by EPA to investigate the
destruction efficiency of catalytic vapor incinerators used to control
organic and hazardous air pollutants.45'46 The results of these studies
concluded that destruction efficiencies of 97 to 98 percent are achievable.
The destruction efficiency is reduced by the accumulation of particu-
late matter, condensed organics, or polymerized hydrocarbons on the
catalyst. These materials deactivate the catalyst by permanently blocking
the active sites on the catalyst surface. If the catalyst is deactivated,
the volatile organics in the gas stream will pass through the catalyst bed
4-31
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unreacted or form new compounds such as aldehydes, ketones, and organic
acids. Catalysts can also be deactivated by compounds containing sulfur,
bismuth, phosphorous, arsenic, antimony, mercury, lead, zinc, tin, or
halogens.
Catalytic vapor incinerators do not have the magnitude of NOX air
emission impacts or potential HC1 and sulfur oxide air emission impacts
associated with thermal vapor incineration because of lower operating
temperatures and applicability restrictions. Catalytic vapor incinerators'
operating temperatures are significantly lower than the temperatures
required for significant NOX formation from molecular nitrogen in the air
(above 1,600 °C [2,900 °F]).47 Small quantities of NOX may form in the
auxiliary burner flame zone. Also, the catalysts are very susceptible to
rapid deactivation by halogens or sulfur. Consequently, catalytic vapor
incineration will not likely be selected to control TSDF organics vapor
streams containing halogen or sulfur compounds.
Using catalytic vapor incineration does produce small solid waste
impacts. The incinerator catalyst must be periodically replaced with fresh
catalyst because of gradual deactivation of the catalyst over time. The
spent catalyst materials are either returned to a catalyst vendor for
recycling or disposed as a solid waste. Because the catalyst formulations
currently used contain heavy metals, spent catalyst materials will need to
be disposed as a hazardous waste.
4.3.4 Flares
Unlike vapor incinerators, a flare is an open combustion process. The
ambient air surrounding the flare provides the oxygen needed for combus-
tion, Consequently, a flare does not require blowers to provide combustion
air. To achieve smokeless flare operation, turbulent mixing of the organic
vapor stream with the ambient air at the flame zone boundary can be
"assisted" by injecting steam or air at the flare tip%or by releasing the
gas stream through a high velocity nozzle (i.e., a nozzle with a high
pressure drop). Flares are used extensively to burn purge and waste gases
from many industrial processes such as petroleum refinery process units,
blast furnaces, and coke ovens.
Figure 4-6 shows a diagram of a typical steam-assisted flare config-
uration.^ The knockout drum is used to remove entrained liquids from the
4-33
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4-34
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organic vapor stream. A water seal is used to prevent air intrusion into
the flare stack. A pilot burner fired with natural gas is used to ignite
the waste gases.
Flares without assist continuously burn the vapors from the emission
source. A flare equipped with a steam, air, or pressure assist operates on
an intermittent basis. Steam-assisted flares typically are used for burn-
ing large volumes of waste gases released from a process unit during an
upset or emergency condition. Air-assisted flares are less expensive to
operate than steam-assisted flares. However, air-assisted flares are not
suitable for large gas volumes because the airflow is difficult to control
when the gas flow is intermittent. Pressure-assisted flares normally are
used for applications requiring ground-level operation.
A series of flare destruction efficiency studies has been performed by
EPA.49»50 Based on the results of these studies, EPA concluded that
98 percent combustion efficiency can be achieved by steam-assisted and air-
assisted flares burning gases with heat contents greater than 11 MJ/m3 (300
Btu/ft3). To achieve this efficiency level, EPA developed a set of flare
design guidelines.51 The guidelines specify flare tip exit velocities for
different flares types and waste gas stream heating values.
Because flaring is a combustion process, using a flare to destruct
organic vapors also produces NOX emissions. However, flare NOX emissions
are very low. Measurements obtained during EPA-sponsored testing of two
flares used to control hydrocarbon emissions from refinery and petrochemi-
cal processes indicate that NOX concentrations in the flared gases are less
than 10 ppmv.52
Application of flares to TSDF emission sources are not expected to
produce HC1 and sulfur oxide air emission impacts. Flares are not recom-
mended for organic vapor streams containing halogens or sulfur compounds.
The acid gases formed from these compounds during combustion causes severe
corrosion and premature wear of flare tips. Thus, flares are not likely to
be selected to control TSDF organic vapor streams containing halogen or
sulfur compounds.
Steam-assisted flares with high steam rates emit high-pitched sounds
that are considered annoying by many people. The use of this type of flare
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at a TSDF may create a noise nuisance impact especially if a residential
neighborhood is located near the TSDF.
4.3.5 Boilers and Process Heaters
A boiler or process heater can be used for organic vapor destruction.
The organic vapor stream is either (1) premixed with a gaseous fuel and
fired using the existing burner configuration, or (2) fired separately
through a special burner or burners that are retrofitted to the combustion
unit.53 Industrial boilers and process heaters currently are being used to
burn vent gases from chemical manufacturing and petroleum refining process
units.
A series of EPA-sponsored studies of organic vapor destruction
efficiencies for industrial boilers and process heaters was conducted by
premixing waste materials with the fuel used to fire representative types
of combustion devices.54,55,56 The destruction efficiency was determined
based on the waste constituent concentrations measured in the fuel feed and
stack gases using a gas chromatograph. The results of one study indicated
that the destruction efficiency for an industrial boiler firing fuel oil
spiked with polychlorinated biphenyls (PCB) was greater than 99.9 percent.
A second study investigated the destruction efficiency of five process
heaters firing a benzene vapor and natural gas mixture. The results of
these tests showed 98 to,99 percent overall destruction efficiencies for GI
to CQ hydrocarbons.
Industrial boilers and process heaters are located at a plant site to
provide steam or heat for a manufacturing process. Because plant operation
requires these combustion units to be on-line, boilers and process heaters
are suitable for controlling only organic vapor streams that do not impair
the combustion device performance (e.g., reduce steam output) or reliabil-
ity (e.g., cause premature boiler tube failure).
4.3.6 Condensers
Condensation is the process by which a gas or vapor is converted to a
liquid form by lowering the temperature or increasing the pressure. This
process occurs when the partial pressure for a specific organic compound in
the vapor stream equals its partial pressure as a pure substance at operat-
ing conditions. For air pollutant control applications, cooling the gas
stream is the more cost-effective method of achieving organic condensation.
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There are two major types of condensers: surface condensers and
contact condensers. In a surface condenser, the coolant does not contact
the vapors or the condensate. In a contact condenser, the coolant and
vapor stream are physically mixed together inside the vessel and exit the
condenser as a single stream. For the TSDF applications, a contact
condenser would not likely be used because the combined organic/coolant
condensate creates additional treatment and disposal requirements.
A shell-and-tube-type heat exchanger is used for most surface
condenser applications (see Figure 4-7).57 The gas stream flows into a
cylindrical shell and condenses on the outer surface of tubes that are
chilled by a coolant flowing inside the tubes. The coolant used depends on
the saturation temperature or dewpoint of the particular organic compounds
in the gas stream. The condensed organic liquids are pumped to a tank.
Additional information about condenser equipment and operations is avail-
able in References 58 and 59.
The volatile organic removal efficiency for a condenser is dependent
upon the gas stream organic composition and concentrations as well as the
condenser operating temperature. Condensation can be an effective control
device for gas streams having high concentrations of organic compounds with
high-boiling points. However, condensation is not effective for gas
streams containing low organic concentrations or composed primarily of low-
boiling point organics. At these conditions, organics cannot readily be
condensed at normal condenser operating temperatures.
Appendix F, Section F.2.2.3, summarizes the results of a field
evaluation of a condenser used to recover organics from a steam stripping
process used to treat wastewater at a plant manufacturing ethylene
dichloride and vinyl chloride monomer. The measured condenser removal
efficiencies for specific organic constituents ranged from a high value of
99.5 percent for 1,2-dichloroethane to a low value of 6 percent for vinyl
chloride.
Use of surface condensers for TSDF organic air emission control will
likely produce no cross-media or secondary impacts other than any impacts
attributed to electricity consumption. Because the coolant does not
contact the condensate, organic condensate is not contaminated and can be
4-37
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COOLANT INLET VAPOR OUTLET
VAPOR INLET
COOLANT OUTLET CONDENSED ORGANICS
Figure 4-7. Schematic diagram of a shell-and-tube surface condenser.
4-38
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readily recycled instead of being disposed. Electricity is required to
power the coolant and condensate pumps.
4.3.7 Absorbers
Absorption as applied to air pollutant control is the process by which
organic molecules in a gas stream are selectively removed by a liquid
solvent (referred to as the "absorbent"). This process may occur by a
physical or chemical mechanism. For physical absorption, the organic
compounds dissolve in the absorbent. For chemical absorption, the organic
compounds react with the absorbent or with reagents dissolved in the
absorbent. The combined organic and absorbent mixture is then processed
further to separate the organics and absorbent.
To achieve high organic control efficiencies using absorption,
intimate mixing of the organic vapors with the absorbent is required.
Several different types of equipment are available that achieve good
contact between the gas and the absorbent. Absorbers include packed
towers, plate or tray towers, spray towers, and venturi scrubbers. Back-
ground information about these devices is available in Reference 60.
The relatively low organic concentrations in the vent streams from
many TSDF emission sources would require long contact times and large quan-
tities of absorbent for effective emission control. This increases the
size of the absorber vessel required as well as the absorber operating
costs. Furthermore, the organics and absorbent are physically mixed
together inside the absorber vessel, and exit as a single stream that
creates additional hazardous waste treatment and disposal requirements.
Consequently, application of an absorber to a TSDF emission source is
generally more expensive than using a adsorption, combustion, or condensa-
tion add-on control device. Thus, it is expected that absorbers will not
be selected for TSDF organic air emission control except perhaps at a TSDF
location where a unique combination of waste characteristics and site-
specific factors make an absorber the better choice for an add-on control
device.
4.4 ORGANIC REMOVAL AND HAZARDOUS WASTE INCINERATION PROCESSES
4.4.1 Steam Stripping
Steam stripping involves the fractional distillation of volatile
organics from a less volatile waste material. It is a commercially proven
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process and currently is used to remove organics from dilute aqueous
liquids such as chemical manufacturing process wastewater. Several
references discuss steam stripping in detail, including a steam-stripping
manual published by EPA,61 discussions of the theory and design proce-
dures,62-65 and discussions of applicability to hazardous wastes.66"69
The basic operating principle of steam stripping is the direct contact
of steam with the waste, which results in the transfer of heat to the waste
and the vaporization of the more volatile organic compounds. The vapor is
condensed and separated (usually decanted) from the condensed water vapor.
Final control of organics is accomplished by recycling or incinerating the
condensed organic layer. A simplified diagram of a steam stripper is shown
in Figure 4-8.
Batch steam stripping is used extensively in the laboratory and in
small production units where a single unit may have to serve for many mix-
tures. Large installations also use batch steam stripping if the material
to be separated contains solids, tars, or resins that may foul or plug a
continuous unit. Batch steam stripping is also used to treat materials
that are generated from a cyclical or batch process.70 Batch processing
may offer advantages at TSDF because the unit can be operated to optimize
organic removal for a particular type of waste. For example, the same unit
may be used to remove volatiles from a batch of wastewater, from a waste
containing solids, or from a high-boiling organic matrix. The heat input
rate and fraction boiled over can be varied for each waste type to obtain
the recovery or removal desired for the specific batch of waste.
Continuous steam stripping requires a feed stream that is a free-
flowing liquid with a negligible solids content. Solids, including tars
and resins, tend to foul the column trays or packing and heat exchangers..
Consequently, wastes containing solids may require removal of the solids
prior to processing through a continuous steam stripper. Unlike the batch
operation, a continuous steam stripper requires a relatively consistent
feed composition to maintain a consistent removal efficiency from the waste
material.71 The continuous steam stripper may offer cost advantages over a
batch operation for applications in which there is little variation in the
type of feed and for relatively high volumes of waste materials.
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The products and residues from steam stripping include the condensed
vapors (condensate), noncondensible gases, and the treated waste or efflu-
ent. The condensate usually is decanted to remove any separate organic
layer from the aqueous layer with recycle of the aqueous condensate back to
the feed stream. The separate organic layer may be recovered and reused as
product or fuel. If the condensate is a single phase of water containing
dissolved organics, then additional treatment of the condensate may be
necessary for ultimate control of organics. Most commercial processes rely
on the formation of a separate organic phase and decanting for economical
removal and recovery of organics. Noncondensibles in the overhead stream
include gases dissolved in the waste material and very volatile compounds
in low concentrations that are not condensed in the overhead system. The
noncondensibles leave through the condenser or decanter vent and usually
are vented to the atmosphere or to an incinerator. For example, vinyl
chloride and chloroethane in one steam stripping test were found to pass
through the condenser and were vented as noncondensibles to an inciner-
ator. 72 The effluent from the steam stripper should be essentially free of
the most volatile compounds; however, semivolatiles and compounds that are
relatively nonvolatile may still be present in the stripper bottoms or
effluent and may require additional treatment for removal.
Steam stripping is applicable to most waste types that have a reason-
ably high vapor-phase concentration of organics at elevated temperatures
(as measured by the vapor/liquid equilibrium coefficient). These waste
types are commonly found in TSDF. Theoretically, wastes can be processed
by batch steam stripping if they can be pumped into the unit and if they
produce a residue that can be removed from the still. This batch operation
may be applicable for waste streams generated in relatively low quantities.
However, batch stripping of sludges with high solids content is not a
technology that has been demonstrated and evaluated in full-scale units.
Consequently, no design or performance data are available for batch strip-
ping of sludges. Some of the difficulties associated with batch stripping
of sludges include material handling problems, heat transfer in the unit,
long cycle times, and unknown performance. All of these factors would
affect the basic design and operation of the unit.
4-42
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Preliminary treatment such as solids removal or pH adjustment are
often used before wastewater is stripped in a continuous unit. Continuous
steam stripping has been used routinely in the chemical industry to recover
organics for recycle and to pretreat wastewater for organic removal prior
to the conventional wastewater treatment process. Common steam stripping
applications include recovery of ethylene dichloride, ammonia, sulfur, or
phenol for recycle and removal of phenol, mercaptans, vinyl chloride, and
other chlorinated compounds from wastewater.73 Batch steam stripping
appears to be more common at commercial TSDF because it is adaptable to
different types of wastes that may be received in batches.74 For any given
waste type, pilot-scale evaluations or trials in the full-scale process may
be required to optimize the operating conditions for maximum removal at the
lowest cost.
Removal efficiencies on the order of 95 to 100 percent are achievable
for volatile organics such as benzene, toluene, and one- or two-carbon
chlorinated compounds.75»76 Batch operations usually provide a single
equilibrium stage of separation, and the removal efficiency is determined
essentially by the equilibrium coefficient and the fraction of the waste
distilled. The efficiency of a continuous system is related to the
equilibrium coefficient and the number of equilibrium stages, which is
determined primarily by the number of trays or height of packing. The
organic removal efficiency also is affected by the steam input rate, column
temperatures, and, in some cases, the pH. Temperature affects the solubil-
ity and partition coefficient of the volatile compound. The liquid pH also
may affect the solubility and treatability of specific compounds, such as
phenol. In principle, the removal efficiency in a multistage system can be
designed to achieve almost any level. In practice, removal efficiencies
are determined by practical limits in the column design (such as maximum
column height or pressure drop) and cost. Consequently, steam stripping is
difficult to characterize in terms of maximum achievable performance with
respect to percent organic emission reduction or organic concentration in
the treated waste.
Emission source tests for five steam stripping units are presented in
Appendix F. Wastewater containing methylene chloride, chloroform, and
4-43
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carbon tetrachloride was treated by steam stripping at a chemical plant
(Section F.2.3.1.1). An inlet concentration of approximately 6,000 ppm
organics was reduced to less than 0.037 ppm for an overall removal effi-
ciency of about 99.999 percent. The effluent from the stripper required no
further treatment and was discharged directly to a river under a National
Pollutant Discharge Elimination System (NPDES) permit.
The steam stripper at a second plant (Section F.2.3.1.2) was used to
strip volatile organics from industrial wastewater. The major component,
1,2-dichloroethane, was removed from the wastewater at an efficiency of
99.998 percent. The removal of total organics, which generally included
chlorinated compounds with one to two carbon atoms, averaged 99.8 percent.
The test at a third chemical manufacturing plant (Section F.2.3.1.3)
evaluated the removal of nitrobenzene and nitrotoluene from wastewater.
These compounds are less volatile than the compounds in the wastewater at
the first plant. The removal efficiency for nitrobenzene and 2-nitrotolu-
ene ranged from 91 to 97 percent with an overall organics removal of
92 percent.
The steam stripper at a fourth chemicals manufacturing plant (Section
F.2.3.1.5) is used to remove relatively volatile compounds (methylene
chloride, chloroform, and carbon tetrachloride) from wastewater. The
removal of the major component, methylene chloride, was 99.99 percent. The
removal of total organics was 98 percent.
Four batches of waste were evaluated in a batch steam stripping proc-
ess used to reclaim organic solvents (Section F.2.3.1.4). The types of
compounds present in the waste included both very volatile compounds and
some considered to be semivolatiles because of their solubility in water.
The removal of the most volatile compounds was on the order of 99 percent.
with occasionally lower values for specific compo.unds (e.g., 91 percent for
acetone, 87 to 94 percent for 1,1,1-trichloroethane, and 74 percent for
ethyl benzene). The removal of total organics from the batches ranged from
94 to 99.8 percent.
At a solvent recycling plant (Section F.2.3.4.1), tests were conducted
on two batches of waste processed through a batch steam distillation unit.
In the first batch, removal of individual compounds ranged from 36 to
4-44
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92 percent and total organics removal was 76 percent. In the second batch,
removal of individual compounds ranged from 12 to 91 percent and total
organics removal was 91 percent. In this latter batch, a major portion of
the total organic content of the waste consisted of the most volatile
compound.
The steam required for steam stripping most likely is supplied by an
on-site industrial boiler. Increasing process steam production will
increase boiler air emission impacts.
4.4.2 Air Stripping
Air stripping is a process that uses forced air to remove volatile
compounds from a less volatile liquid. The contact between air and liquid
can be accomplished in spray towers, mechanical or diffused-air aeration
systems, and packed towers.77 Packed tower air strippers are preferred for
TSDF organic air emission control because the vapor-laden air can be sent
to a control device, whereas the other devices rely upon dilution in ambi-
ent air to avoid environmental problems. In packed towers, the liquid to
be treated is sprayed into the top of a packed column and flows down the
column by gravity. Air is injected at the bottom of the column and rises
countercurrent to the liquid flow. The air becomes progressively richer in
organics as it rises through the column and is sent to a control device to
remove or destroy organics in the air stream. See Figure 4-9 for a sche-
matic of a typical air stripping system with gas-phase organic emission
control.
The principle of operation is the equilibrium differential between the
concentration of the organics in the waste and the air with which it is in
contact. Consequently, compounds that are very volatile are the most
easily stripped. The packing in the column promotes contact between the
air and liquid and enhances the mass transfer of organics to the air. The
residues from air stripping include the organics-laden air that must be
treated and the water effluent from the air stripper. This effluent will
contain very low levels of the most volatile organic compounds; however,
semi volatile compounds that are not easily air stripped may still be
present and may require some form of additional treatment before final
disposal. The process does not offer a significant potential for recovery
4-45
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and reuse of organics. Condensers generally are not used to recover the
stripped organics because of the large energy requirements to cool the
large quantity of noncondensibles (primarily air) and to condense the
relatively low vapor-phase quantities of organic compounds. Thermal and
catalytic incinerators and carbon adsorption units are the most common
control devices used for control of the overhead gas stream from air
strippers. Fixed-bed carbon adsorption systems offer some potential for
recovery of organics; however, the decision on type of control (organic
destruction or recovery) is usually based on economics.
Air stripping has been used primarily on dilute aqueous waste streams
with organic concentrations that range from a few parts per billion to
hundreds of parts per million. The feed stream should be relatively free
of solids to avoid fouling in the column; consequently, some form of solids
removal may be required for certain aqueous hazardous wastes. In addition,
dissolved metals that may be oxidized to an insoluble form should be
removed. Equipment may be designed and operated to air-strip organics from
sludges and solids in a batch operation; however, this application has not
been demonstrated extensively and is not a common practice. The major
industrial application of air stripping has been in the removal of ammonia
from wastewater.78 in recent years, the use of air strippers has become a
widely used technology in the removal of volatile compounds from contami-
nated groundwater.79,80
Packed towers can achieve up to 99.9 percent removal of volatiles from
water.81 The major factors affecting removal efficiency include the equi-
librium between the organics and the vapor phase (usually measured by
Henry's law constant for dilute aqueous wastes) and the system's design,
which determines mass transfer rates. Removal efficiency increases as the
equilibrium coefficient increases; consequently, the extent of removal is
strongly affected by the type of waste and the volatility of the individual
organic constituents. Mass transfer rates (and removal efficiency) are
also a function of the airrwater ratio, height of packing, and type of
packing.82 The operating temperature is also an important variable that
affects efficiency because of its direct effect on the vapor/liquid
equilibrium. Higher temperatures result in higher vapor-phase
4-47
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concentrations of organics and higher removal rates. Air strippers have
operational difficulties in freezing weather that may require heating the
input waste stream, heating and insulating the column, or housing the
operation inside an enclosure. Air strippers are typically designed to
remove key or major constituents. Compounds more volatile than the design
constituent are removed at or above the design efficiency, and less vola-
tile compounds are removed at a lower efficiency. Numerous vendors are
available for the design and installation of air strippers. As is the case
with steam strippers, these vendors usually require pilot-scale tests on
the actual waste material to design the column and to guarantee minimum
removal efficiencies.
Emission sources associated with an air stripping operation include
tank vents (storage or feed tanks, preliminary treatment tanks) and equip-
ment used to transfer and handle the waste (pumps, valves, etc). The air
leaving the stripping column usually is treated by incineration (with
destruction efficiencies of 98 percent or higher) or carbon adsorption
(with removal efficiencies of 95 percent or higher if carbon breakthrough
is monitored). The choice between incineration and carbon adsorption
depends on the specific conditions at the facility. For example, high
relative humidity in the air stream leaving the air stripper may adversely
affect the adsorption capacity of a carbon bed. This could be avoided by
choosing incineration. However, if the air stream contains chlorinated
organics, the incinerated air stream may need to be scrubbed to remove HC1,
leading to higher costs. In this case, it might be better to choose carbon
adsorption and design to avoid the humidity problem.
The effluent from the air stripper may be an emission source for
semivolatiles that are not removed efficiently, especially if subsequent
processing includes placement in an evaporation pond or disposal impound-
ment. Air stripping could be used to reduce organics from wastewater prior
to a wastewater treatment operation.
An air stripper was evaluated at a Superfund site (Section F.2.3.2.1)
where it is used to remove organics from the leachate collected at the
site. The evaluation focused on optimizing the removal efficiency for
organic components that represented a relatively wide range in volatility.
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During one test, the removal of the most volatile constituents (1,2,3-
trichloropropane and xylene) ranged from 88 to 98 percent. The removal of
semivolatiles such as aniline, phenol, methyl phenol, and ethyl benzene
ranged from 53 to 70 percent. The removal of total organics averaged
99 percent.
Any air emissions, wastewater effluents, or solid wastes associated
with the use of air stripping at TSDF are determined by the type of add-on
control device used in conjunction with the air stripping unit. Section
4.3 discusses add-on control device cross-media and secondary impacts.
4.4.3 Thin-Film Evaporation
Thin-film evaporators (TFE) are designed to promote heat transfer by
spreading a thin-layer film of liquid on one side of a metallic surface
while supplying heat to the other side.83 The unique feature of this
equipment is the mechanical agitator device, which permits the processing
of high-viscosity liquids and liquids with suspended solids. However, if
solid particles are large, a coarse filtration operation may be required to
pretreat the waste stream going to the TFE. The mechanical agitator pro-
motes the transfer of heat to the material by exposing a large surface area
for the evaporation of volatile compounds and agitates the film to maintain
the solids in suspension without fouling the heat transfer area. Heat can
be supplied by either steam or hot oil; hot oils are used to heat the mate-
rial to temperatures higher than can be achieved with saturated steam
(>100 °C). TFE can be operated at atmospheric pressure or under vacuum as
needed based on the characteristics of the material treated. A TFE is
illustrated in Figure 4-10.
The two types of mechanically agitated TFE are horizontal and
vertical. A typical unit consists of a motor-driven rotor with longi-
tudinal blades that rotate concentrically within a heated cylinder. The
rotating blade has a typical tip speed of 9 to 12 m/s and a clearance of
0.8 to 2.5 mm to the outer shell. In a vertical design, feed material
enters the feed nozzle above the heated zone and is transported mechan-
ically by the rotor and grating down a helical path on the inner heat
transfer surface while the volatile compounds are volatilized and leave the
evaporator on the top. The vapor-phase products from TFE are condensed in
a condenser, and the bottom residues are collected for disposal.
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TFE have been used widely for many years in a number of applications
such as processing of chemicals, Pharmaceuticals, plastics, and foods.84
Because of their unique features, their use in chemical and waste material
processing has expanded rapidly. The flexibility in operating temperature
and pressure add potential to TFE for recovering low-boiling-point organics
from a complex waste matrix.
Although TFE can be used to remove varying levels of organics from a
waste stream, when applied to hazardous petroleum refinery sludges, the
most suitable mode of operation is to evaporate the water and volatiles and
leave most of the hydrocarbons that are less volatile than water.
With this mode of operation, the TFE bottom residue contains only low
concentrations of both volatile and semivolatile organic compounds and thus
has a low potential for air emissions after ultimate disposal. This mode
of operation was used during a pilot-scale test discussed below. Waste
forms suitable for TFE treatment include organic liquids, organic sludge/
slurry, two-phase aqueous/organic liquids, and aqueous sludges. TFE would
not be used as a means of treating dilute aqueous waste because of the high
water content in the waste.
Although TFE technology is readily available, as with other organic
removal techniques, a pilot-plant study is usually conducted before full-
scale operation to determine the suitability of the TFE for pretreating a
particular waste stream and to identify optimal operating conditions. The
EPA recently sponsored a pilot-scale test to assess the performance of a
TFE in removing organics from the different types of petroleum refining
wastes.85 jn that study, 98.4 to 99.99 percent of the volatile and 10 to
75 percent of the semivolatile compounds were removed from the sludge.
These results suggest that a TFE can be used to reduce organics substan-
tially in refinery sludges that are currently land treated. No commercial -
scale TFE installations have been identified that process the types of
wastes normally handled by TSDF. However, two installations of TFE used to
recover organics from waste streams have been documented in the literature
and may have some relevance for TSDF operations.86 In one installation
(Section F.2.3.3.3), a hazardous waste recycling plant operates a TFE under
vacuum to separate approximately 95 percent of a feed stream that consists
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of waste oils, a small amount of solids, and approximately 5 percent
organics. In that operation, toluene is removed from the oily wastes at
less than 85 percent efficiency while both chloroform and methylene
chloride are removed at greater than 99 percent efficiency. However, that
installation reportedly has significant organic air emissions through the
vacuum pump vent although no estimate was given for the magnitude of the
emissions. At another organic solvent reclamation and recycling plant
(Section F.2.3.3.2), a TFE operating at atmospheric pressure was able to
remove approximately 76 percent of the acetone and 30 percent of the xylene
from a contaminated acetone waste. Air samples from the process vent at
that operation indicated that air emissions were negligible. At a solvent
recycling plant (Section F.2.3.3.1), a TFE showed removal efficiencies of
45 to 99 percent for individual volatile and semivolatile compounds and
yielded a total organic removal efficiency of 74 percent.
Factors likely to affect or limit the applicability or removal effi-
ciency of TFE include:
• Large changes in the properties of the waste being treated,
which, could cause fouling of the TFE unit.
• The requirement for separation of water and condensed organ-
ics when water is evaporated from the waste stream, which
adds to the operating expense of the unit.
The steam required for thin film evaporation most likely is supplied
by an on-site industrial boiler. Increasing process steam production will
increase boiler air emission impacts.
4.4.4 Batch Distillation
Batch distillation is a commonly used process for recovery of organics
from wastes. Its principal use is for recovery of valuable organic chemi-
cals for recycling or reuse and the re-refining of waste oil as discussed
later in this section. Examples of its use show that it can be applied to
wastes and reduce the organic air emission potential of those wastes by
separating the volatile compounds from the wastes. Although it has been
applied to aqueous wastes, it has been more typically applied to predomi-
nantly organic wastes.
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The simplest form of distillation is a batch operation that consists
of a heated vessel (called the pot), a condenser, and one or more receiving
tanks. This process is identical in principle to batch steam stripping
except that the waste charge is heated indirectly instead of by direct
steam injection. The waste material is charged to the pot and heated to
boiling; vapors enriched in organics are removed, condensed, and collected
in receiving tanks. The distillation is continued to a cutoff point deter-
mined by the concentration of organics in the condensate or the concentra-
tion of organics remaining in the batch. A common modification is to add a
rectifying column and some means of returning a portion of the distillate
as reflux (see Figure 4-11). Rectification enables the operator to obtain
products from the condensate that have a narrow composition range. Differ-
ent distillate cuts are made by switching to alternate receivers, at which
time the operating conditions may be changed. If the distillate is
collected as one product, the distillation is stopped when the combined
distillate reaches the desired average composition.87 Several references
are available that discuss the design and operation of batch distillation
units.88-94 -[^e batch still is operated at a temperature determined by the
boiling point of the waste, which may increase with the time of .operation.
The distillation can be carried out under pressure or under vacuum. The
use of vacuum reduces the operating temperature and may improve product
recovery, especially when decomposition or chemical reaction occurs at
higher temperatures.
Batch distillation provides a means for removing organics from a waste
matrix and recovery of the organics by condensation for recycle, sale as
product, or for fuel. The products and residues include the condensate
that is enriched in organics and recovered, noncondensibles that escape
through the condenser vent, and the waste residue that remains in the pot.
The noncondensibles are composed of gases dissolved in the waste and very
volatile organic compounds with relatively low-vapor phase concentrations.
The waste material after distillation may have been concentrated with high-
boiling-point organics or solids that are not removed with the overhead
vapors. These still bottoms may be a free-flowing liquid, a viscous
slurry, or an organic material that may solidify upon cooling. If the
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waste material contains water, a separate aqueous phase may be generated
with the condensate. This phase may be returned to the batch or processed
with additional treatment to remove organics or other contaminants.
Batch distillation may be used for wastes that have a significant
vapor-phase concentration of organics at the distillation temperature. If
the waste can be pumped and charged to the still pot and the residue can be
removed from the pot, then the waste is likely to be treatable for organic
removal by this process. Such wastes include dilute aqueous wastes (the
operation would be similar to batch steam stripping), aqueous or organic
sludges, or wastes with volatiles in a high-boiling-point organic solvent
or oil. The batch distillation of sludges has not been demonstrated and
evaluated in full-scale units; consequently, the processing of sludges in a
batch di'stillation unit is subject to the same limitations described for
the batch steam stripping of sludges (Section 4.4.1). Batch distillation
has been used to remove organics from plating wastes, phenol from aqueous
wastes, recovery and separation of solvents, and re-refining of waste
oils.95,96 Tne applicability of batch distillation for a specific waste
type can be evaluated by a simple laboratory distillation to assess poten-
tial organic recovery. As with other organic removal techniques, the
process may require optimization in a pilot-scale or full-scale system for
different types of wastes to determine operating conditions that provide
the desired distillate composition or percent removal from the waste.
Batch stills usually are operated as a single equilibrium stage (i.e.,
with no reflux); consequently, the organic removal efficiency is primarily
a function of the vapor/liquid equilibrium coefficient of the organics at
distillation temperatures and the fraction of the waste boiled over as
distillate. The use of a rectifying section yields an overhead product
with a composition that can be controlled by the operator. The removal
efficiency for various waste types can be highly variable because of the
dependence on both properties of the waste (e.g., organic equilibrium) and
the operating conditions that are used. Emission tests were conducted on a
batch unit at a plant engaged in the reclamation of contaminated solvents
and other chemicals.97 The test results (summarized in Appendix F, Section
F.2.3.4.2) indicate organic removal efficiencies on the order of 99.4 to
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99.97 percent for organics, including compounds such as methyl ethyl
ketone, 2,2-dimethyl oxirane, methanol, methylene chloride, isopropanol,
and carbon tetrachloride. Results for a second distillation unit at the
same site processing contaminated solvents showed organic removal efficien-
cies ranged from 97 percent (for xylene and ethyl benzene) to 99.9 percent
(for trichloroethane). These results demonstrate that batch distillation
has been used successfully to remove organics from aqueous and organic
wastes or solvents.
The steam required for batch distillation most likely is supplied by
an on-site industrial boiler. Increasing process steam production will
increase boiler air emission impacts.
4.4.5 Dewatering
As used herein, dewatering refers to solid-liquid separation achieved
by filtration or centrifugation. Such devices normally are characterized
according to the force used to achieve the desired separation. At TSDF,
solid-liquid separation most often is achieved by filtration rather than
centrifugation. Filtration is achieved by passing the waste stream through
a filtering medium, often a textile product, using force that may be
applied in any of several ways. Press-type filters consist of a series of
plates covered with a filtering medium and enclosed in a frame. Separation
is achieved by filling the void spaces between plates with the input mater-
ial and then applying pressure to force the plates together and generate
the desired separation. Examples of this type of filter include plate and
frame, recessed plate, and pressure leaf filters.98 Filtration force also
may be applied by using atmospheric pressure on one side of the filter
medium while the other side is maintained at greater or lesser than atmos-
pheric pressure. Examples of this type of filter include rotary drum
vacuum and rotary drum pressure filters. In rotary drum vacuum filters,
the driving force is achieved by reducing the pressure inside a rotating
drum to below atmospheric. The drum is covered with a filter medium that
builds up a cake of solids that contributes to filtration efficiency. The
rotary drum pressure filter uses the reverse principle of applying greater
than atmospheric pressure to the inside of the rotating drum. In these
filters, the filtering medium is inside the drum. Advantages of the vacuum
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filter include its adaptability to continuous operation and the ease with
which the filter material can be cleaned and maintained.99 In recent
years, belt filter presses have become one of the more widely used types
for many applications. These filters use a combination of gravity and
pressure to apply force across the filter medium. In belt filter presses,
the input stream is applied to a horizontal moving belt that is covered
with filter material. Gravity forces cause partial separation of the
liquid from the solids in the stream. As the belt continues to move, it
approaches a second moving belt, and the two move along together over a
series of rollers that force the belts closer and closer together, creating
pressure on the material between the two belts. The belts separate for
solids removal, and the filter medium separates from the underlying sup-
porting web. At this point, the filter medium can be washed continuously.
The ease of continuous washing is one of the primary advantages of the belt
filter press.100 Other advantages include the adaptability to continuous
operation and the higher throughputs handled relative to other types of
filters. Exit streams from a filtering or dewatering operation include the
filtrate, which is mostly free of solids, and the filter cake, which gen-
erally has a sufficiently low moisture content to be handled using solids
handling techniques. A schematic diagram of a dewatering system is illus-
trated in Figure 4-12.
Dewatering is applicable to any waste stream that consists of a sludge
or slurry such as petroleum refinery sludges. When used for this applica-
tion, toxic metals remain in the filter cake, which could continue to be
land treated or may be fixated and landfilled, while the liquid passes
through a separation process where oil (which will contain a large fraction
of the organics) is recovered for recycle. Little data have been identi-
fied that can be used to estimate the emission reduction achieved by
dewatering. However, Chevron Research Company has conducted tests that
indicate as much as 90 percent of the oil in refinery sludges can be recov-
ered by dewatering and that oil recovery is improved substantially if the
filtration or centrifugation step is followed by a drying step.101 At an
EPA-sponsored test at a Midwest refinery, oil removal using a belt filter
was found to be 78 percent for an API separator sludge and 66 percent for a
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dissolved air flotation (DAF) float.102 If the recovery efficiencies
obtained in the tests can be achieved in full-scale applications, an
equivalent reduction in emissions from land treatment or landfill opera-
tions would be expected.
Emissions during dewatering would come from pumps, valves, storage,
and other handling operations and also from any exposed waste surfaces at
the dewatering device. At the test of the belt filter press cited above,
measured air emissions were equal to 21 percent of the volatiles in the API
separator sludge and 13 percent of the volatiles and 22 percent of the
semivolatiles in the DAF float.
When vacuum filters are used, emissions would occur with the vacuum
pump exhaust. Control of emissions could be achieved by enclosing the
operation where necessary and venting the enclosure to one of the add-on
control devices described in Section 4.3. Vacuum pump exhaust also could
be controlled with an add-on control device.
Any air emissions, wastewater effluents, or solid wastes associated
with the use of dewatering are determined by the type of add-on control
device used in conjunction with the dewatering device. Add-on control
device cross-media and secondary impacts are discussed in Section 4.2.
4.4.6 Hazardous Haste Incineration
Incineration is an engineered process that uses thermal oxidation of a
bulk or containerized waste to produce a less bulky, toxic, or noxious
material. Combustion temperature, residence time, and proper mixing are
crucial in controlling operating conditions.103,104 of the several types
of waste incineration systems, four are generally cited as being the most
useful and having the greatest potential for application to wastes proc-
essed at TSDF. They are liquid injection, rotary kiln, fluidized-bed, and
multiple-hearth incinerators. The type of incinerator selected for a par-
ticular installation depends on the waste type and composition as well as
other factors such as whether the waste is in bulk or containerized.
Liquid injection incinerators are versatile and can be used to dispose
of virtually any combustible liquid that can be pumped. The liquid waste
must be converted to gas prior to combustion. This change is brought about
in the combustion chamber and is generally expedited by increasing the
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waste surface area by atomization.105 Liquid injection incinerators oper-
ate at temperatures between 820 and 1,600 °C. Gas-phase residence times
range from 0.1 to 2 s.
Rotary kilns are versatile units that can be used to dispose of
solids, liquids, slurries, and gaseous combustible wastes. Rotary kilns
are long, cylindrical rotating furnaces lined with firebrick or other
refractory material in which solids are combusted by themselves or are
incinerated by combustion of an auxiliary fuel or liquid wastes. Combus-
tion temperatures range from 870 to 1,600 °C depending on the waste
material character!sties.106 Solids residence time varies from seconds to
hours, depending on the type of waste. Unless the kiln is very long (i.e,
provides a larger residence time), some type of secondary burning chamber
usually is required to complete combustion of the solid waste. The heat
release per unit volume is generally quite low, but the rotary kiln pro-
vides a method of mixing solids with combustion air and can be operated at
temperatures in excess of 1,400 °C that are unavailable in other types of
systems.
A fluidized-bed incinerator consists of a bed of inert granular mate-
rial fluidized by hot air onto which the waste and auxiliary fuel is
injected.107 yne waste in turn combusts and returns energy to the bed
material; thus, heat release per unit volume is generally higher than for
other types of incinerators. Fluidized-bed incinerators operate at temper-
atures below the softening point of the bed medium, usually around 450 to
850 °C.108 The residence time is generally around 12 to 14 s for a liquid
waste and longer for solid wastes. This type of incinerator is suited
particularly to heavy sludge and to certain types of organic/inorganic
mixtures. The inorganic material will stay in the bed and can be removed
as ash. Scrubbing of flue gases usually is required to remove fine partic-
ulates, and subsequent flue gas treatment is required for halogen, sulfur,
and phosphorus compounds.
The multiple-hearth incinerator was designed for the incineration of
low heat content waste such as sewage sludge. It generally uses large
amounts of auxiliary fuel and is large in size. A multiple-hearth unit
generally has three operating zones: the uppermost hearths where feed is
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dried (350 to 550 °C), the incineration zone (800 to 1,000 °C), and the
cooling zone (200 to 350 "C).^9 Exit gases have good potential for heat
recovery, being around 300 to 600 °C. Temperatures on each hearth can be
maintained using supplemental fuel. Multiple-hearth units may be suitable
for hazardous sludge disposal, although it may be necessary to add an
afterburner to destroy unburned hydrocarbons that volatilize on the upper-
most hearths. Several incinerator types are shown in Figure 4-13.
The cost of operating an incinerator can be reduced by recovering and
using the heat generated by the combustion of waste. Primary heat recovery
can be employed by using the incinerator exhaust to preheat the incoming
waste stream. Secondary heat recovery, such as a waste heat boiler, can
also be used if the production process can make use of the steam generated.
Heat recovery is shown in the incinerator illustration in Figure 4-13.
Incineration under proper control and using proper techniques will
provide total destruction of all forms of hazardous organic wastes.HO
There are two basic types of wastes: (1) combustible wastes, which will
sustain combustion without auxiliary fuel; and (2) noncombustible wastes,
which usually contain large amounts of water or other inert compounds and
will not sustain combustion without auxiliary fuel. Organic liquid and
sludge are most suitable for incineration because of their heat content.
Aqueous sludge, two-phase aqueous/sludge, and organic-containing solids may
be incinerated with auxiliary fuel to destruct hazardous organics. Dilute
aqueous waste would not be suitable for direct incineration because of its
high water content.
Of the four types of incineration, liquid injection and rotary kiln
have been proven to destruct hazardous waste and to be commercially avail-
able; fluidized-bed and multiple-hearth are less frequently used tech-
nologies. However, fluidized-bed incinerators may have greater potential
because of their compact design, which results in relatively low capital
cost, and their general applicability to solids, liquids, gases, and wastes
containing inorganics.HI
Air emission standards of performance for incinerators burning
hazardous waste have been established by EPA.H2 Existing standards
require that each incinerator (i) achieve a destruction and removal
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PROCESS STEAM
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Fluidized-Bed Incinerator
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Rotary Kiln Incinerator
Figure 4-13. Hazardous waste incinerators.
4-62
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efficiency (ORE) of 99.99 percent for each principal organic hazardous
constituent (POHC) designated for each waste stream; (2) have hydrogen
chloride (HC1) emissions not to exceed the larger of 1.8 kg/h (4 Ib/h) or
1 percent of the HC1 in the incinerator exhaust gas upstream of any
emission control device; and (3) have total particulate matter emissions
not to exceed 0.18 grams per dry standard cubic meter (0.08 grains/dscf).
Additional standards are being developed by EPA to improve the control of
toxic metals, HC1, carbon monoxide, and residual organics.
To meet Federal and State standards, complex air pollution control
systems are installed on hazardous waste incinerators. These control
systems include the use of wet or dry scrubbers in conjunction with fabric
filter or electrostatic precipitator control devices. Control system oper-
ation results in the production of solid wastes and, if a wet scrubber is
used, wastewater effluents. Additional solid waste is produced by the
incombustible material or ash that is removed from the incinerator and must
be disposed as a hazardous material.
4.5 PROCESS MODIFICATIONS
4.5.1 Petroleum Refinery HasteCoking
Delayed coking is a process used in some petroleum refineries to
recover useful products from the heavy ends of the raw petroleum. In this
process, the feed stream enters a fractionator where gas oil, gasoline, and
lighter fractions are flashed off and recovered. The fractionator bottoms
are combined with a recycle stream and heated to reaction temperatures of
480 to 580 °C in the coker heater. The vapor-liquid mixture from the
heater then enters the coke drum, where the primary coking reaction takes
place. The coke drum provides the proper residence time, pressure, and
temperature for coking. In the coke drum, the vapor portion of the feed
undergoes further cracking as it passes through the drum, and the liquid
portion undergoes successive cracking and polymerization until it is con-
verted to vapor and coke.113 Coking units consist of at least two coke
drums so that one can remain online while coke is removed from the other.
In removal of coke from the drum, steam is first injected into the
drum to remove hydrocarbon vapors, which are cooled to form a steam-hydro-
carbon mixture. This is followed by water injection to cool the coke and
4-63
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allow removal. When the coke is cooled sufficiently, a high-pressure water
jet is used to cut the coke into pieces that are then removed from the coke
drum.
Coking is an alternative to the land treatment or landfilling of
petroleum refinery hazardous wastes according to the requirements specified
in the Federal Register.H4 coke produced from petroleum refinery hazard-
ous wastes is exempt from regulation as a hazardous waste, if the waste is
coked at the facility where the waste is generated. In addition, the coke
cannot exhibit any of the characteristics of a hazardous waste.
Refinery sludges can be introduced to a delayed coking operation in
one of two ways. In one process, sludge is injected into the coker during
the cool-down period. In that process, the water content of the sludge
contributes to cooling the coke while organics are cracked into products or
polymerized into coke. Sludge solids are immobilized inside the coke.^5
This process currently is used at several refineries. In the second
process, sludge is introduced into the coker as a part of the feed stream
by injecting it into the blowdown system where it is vaporized and recy-
cled. In that process, the amount of sludge that can be added to the feed
stream must not exceed some small percentage of the total feed, and the
sludge must undergo extensive dewatering prior to entering the coking oper-
ation. H6 Only one refinery is known to use this operation.
No emission measurement data were found for coking operations; how-
ever, because the entire operation is enclosed, organic air emissions are
estimated to be quite low. Some emissions would be expected from transfer,
storage, and handling operations associated with coking. Most of these
would be expected to come from the transportation of sludge from the point
of generation to the coking operation and from storage of sludge at the
coker. Although no definitive data are available to permit estimates of
the emission reduction that would be achieved by processing refinery
sludges through a coker rather than land treating, reductions approaching
100 percent are expected. Increased emissions from the coking operation as
a result of introducing wastes into the feed stream are estimated to be
negligible.
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Coking is a possible control option at refineries that produce fuel-
grade coke. At refineries that produce high-quality, electrode-grade coke,
the quality degradation caused by sludge injection may be unacceptable.
For refineries that do not have an existing coking operation, coking would
not be a practical emission control alternative.
Application of coking for TSDF organic air emission control essen-
tially involves using refinery sludges as additional feed materials for an
existing refinery process unit. Existing petroleum coking units are oper-
ated to improve overall refinery product yield and economics. Therefore,
no cross-media or secondary impacts are attributed to the organic air
emission reduction achieved by coking of petroleum refinery wastes.
4.5.2 Submerged Loading
Organic air emissions generated during TSDF waste loading operations
are the primary source of evaporative emissions from waste containers
(e.g., tank trucks and drums). Emissions occur when liquid or semi liquid
wastes are poured into a container displacing—from inside the container to
the ambient air--an equal volume of air that is saturated or nearly satu-
rated with organics. The quantity of organics emitted is a function of the
loading method and whether the container is clean before loading.
For splash loading, the influent pipe dispensing the waste is lowered
only partially into the container. Consequently, the waste flows from the
end of the pipe that is above the liquid level in the tank or drum. Sig-
nificant turbulence and vapor-liquid contact occur when the falling liquid
splashes on the surface of the liquid already in the container. This
results in organic vapor generation and emission to the atmosphere through
the container opening used for waste loading. Control of loading air emis-
sions can be accomplished by using submerged loading. During submerged
loading, the influent pipe opening is located below the liquid surface
level. This position decreases turbulence and evaporation, and eliminates
liquid entrainment.
The quantity of organic air emissions is also affected by the condi-
tion of the container prior to loading. If a clean container is used, only
the vapors generated by the loading operation are emitted. However, if the
container contains residue vapors from a previous waste!oad, then addi-
tional emissions will be released when the container is filled.
4-65
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No emission source test studies of TSDF container loading have been
conducted. To estimate the effectiveness of submerged loading in suppres-
sing organic air emissions, an emission model derived for estimating emis-
sions from loading petroleum liquids into trucks, tank cars, and marine
vessels was used. A complete description of the emission model, as well as
the analysis, are presented in Appendix H, Section H.I.3. Use of submerged
loading is estimated to reduce organic air emissions from TSDF waste load-
ing operations by 65 percent.
Submerged loading of open area sources, such as surface impoundments
or open-top tanks, is not considered a control technique unless it is used
in conjunction with covers or enclosures over the source. If the loading
is changed from above to below the liquid surface in the absence of covers
or enclosures, organics that would have been emitted during filling are
instead emitted quickly from the open liquid surface by wind blowing across
the source. However, if the open-top tank is covered or if the impoundment
is enclosed, then emissions may be generated from the displacement of vapor
by liquid. In this case, submerged loading may reduce emissions as
described above for containers, and would provide additional control of
organic air emissions.
There are no cross-media or secondary environmental impacts associated
with submerged loading.
4.5.3 Subsurface Injection
Subsurface injection is a land treatment practice in which waste is
injected directly into the soil. The process could be used to apply wastes
to a land treatment site in lieu of surface application. In subsurface
injection, as opposed to surface application, there is no pooling of liquid
on the soil surface and thus potentially less opportunity for the material
to be emitted to the atmosphere. However, in a field study to evaluate the
relative air emissions from land treatment plots using surface application
and subsurface injection, no difference in emissions was evident.117
Therefore, subsurface injection is not currently being considered for air
emission control.
4.5.4 Haste Fixation Mechanical Mixing
As a result of the RCRA land disposal restrictions, many liquid,
slurry, and sludge types of hazardous wastes are now treated at TSDF using
4-66
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a waste fixation process so that the waste can be disposed in a hazardous
waste landfill. Waste fixation, also referred to as waste solidification
or stabilization, is a chemical process in which the free water in the
waste reacts with a binder (i.e., cement) to form a solid material that
immobilizes specific metal and organic contaminants in the waste for which
treatment standards have been set.
Waste fixation involves first mixing the waste with the binder
material. The binder can be either an inorganic or organic material. The
prevalent TSDF industry practice is to use the least expensive binder
material locally available (usually cement kiln or lime kiln dust). Typi-
cally, the waste and binder are mixed together in proportions to produce a
moist, soil-like material. Following mixing, the mixture is cured by hold-
ing the mixture for a sufficient period of time (usually 24 to 48 h to
allow the mixture to harden. The waste is then tested, and if it meets the
appropriate treatment standards, the waste is transferred to a landfill.
More information about TSDF waste fixation practices is presented in Refer-
ences .118 and 119.
Organic emissions from waste fixation occur when organics in the waste
volatilize and are released to the atmosphere during mixing and curing.
Results from a laboratory study of waste fixation suggest that the majority
of organic emissions occur during the mixing of the waste and the
binder.120 por this study, organic emissions were measured for bench-scale
simulations of waste fixation processes. Approximately 60 to 90 percent of
the volatile organics in the waste were emitted during mixing of the waste
and binder. The percentage varied depending on the type of binder used.
The bulk of the remainder of the volatile organics was emitted during the
curing step.
The simplest mixing procedure used at TSDF involves placing the waste
into an open-pit or open-top tank, dumping the binder into the waste, and
mixing the materials using heavy construction equipment such as a backhoe.
A similar procedure is used, but on a smaller scale, for fixating waste
directly in a drum. For this operation, a worker manually adds the fixa-
tive into the open-top drum containing the waste and mixes the materials
with a small auger or blender. At some TSDF, open mixing of the waste and
4-67
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fixative has been replaced by enclosed mechanical mixing devices such as a
pug mill and a ribbon blender.
Observation of waste fixation operations at sites throughout the
United States indicates that mechanical mixers effectively control air
emissions from the mixing of the waste and binder.121-126 jne mixer
enclosure can be vented directly to an add-on control device. Controlling
organic emissions is demonstrated by the use of carbon adsorption systems
in combination with particulate controls on pug mills at two waste fixation
facilities.127,128 These controls have been installed to meet State or
local air emission regulations.
4.6 WORK PRACTICE MODIFICATION
4.6.1 Housekeeping in Drum Storage Areas
Drum storage is the temporary holding of liquid, semi sol id, or solid
wastes until treatment and/or disposal can be undertaken. Drums can be
stored on concrete pads that have a perimeter curb and gutter for secondary
containment. Secondary containment is required at any drum storage area
(40 CFR 264.175), and spilled or leaked waste and accumulated precipitation
must be removed from the sump or collection area in as timely a manner as
necessary to prevent overflow of the collection system.
Typically, drums are sealed and in good condition during storage;
therefore, the potential for breathing emissions is assumed to be negligi-
ble. However, drums may rupture and leak hazardous wastes during storage
or transfer. Management and technical practices not only cause spillage,
they also determine what fraction is available for volatilization. Because
RCRA requires that container storage areas be inspected weekly for con-
tainer leaks and deterioration (40 CFR 264.174), a 50-percent loss of the
volatiles to the atmosphere from the spilled waste was selected for emis-
sion estimating purposes; the remaining 50 percent are recovered as a
result of implementing RCRA spill response actions.
Two control options are considered appropriate for reducing emissions
from drum storage: one option is to vent the existing enclosed drum stor-
age areas through a fixed-bed carbon adsorption system (see Section 4.2.2
for more detail). The other control option is to use an open secondary
containment area, conduct daily inspections and maintenance, and have a
4-68
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policy to clean up spills within 24 hours of discovery. This option is an
adaptation of the proposed 1986 RCRA tank regulations (40 CFR 264.196).
Leak detection of stored drums is accomplished by visual inspection on a
daily basis. In case of a spill or leak, sorbent material is used to clean
.up the spillage, or the spillage is collected in a collection sump for
transfer to a drum for treatment or disposal. This policy of daily inspec-
tion with cleanup within 24 hours decreases the fraction of volatiles lost
to the atmosphere. The magnitude,of the reduction will depend on operating
practices, waste type, and volatiles concentration; however, no data are
available that quantify the emission reduction achieved by this method.
Because it is estimated that these housekeeping practices are already used
at most TSDF, no credit for an emission reduction was included in the
estimates of nationwide emissions.
4.6.2 Leak Detection and Repair
Waste transfer operations often involve pumping waste through pipe-
lines into a variety of waste management process units. This pumping
creates the potential for equipment leak (fugitive) emissions from pump
seals, valves, pressure-relief valves, sampling connections, and open-ended
lines and flanges. Leaks from these types of equipment are generally ran-
dom occurrences that are independent of temperature, pressure, and other
process variables. However, these leaks do show a correlation with the
vapor pressure of the material in the line. For example, monthly inspec-
tion data from the synthetic organic chemicals manufacturing industries
(SOCMI) show that 8.8 percent of the seals on pumps handling light liquids
have leaks and only 2.1 percent of the seals on pumps handling heavy
liquids have leaks.129 Light liquids are defined as those containing at
least 20 percent by weight of organic compounds having a vapor pressure
greater than 10 mm Hg. , -
An effective method for controlling fugitive emissions is to implement
a routine leak detection and repair program (i.e., periodic inspection and
maintenance). Leaks can be detected by individual component surveys, which
may be carried out independently or may be a part of activities such as
area (walkthrough) surveys, fixed-point monitoring, and visual inspection.
Leaks can be repaired by adjusting the tightness of parts in pumps, valves,
4-69
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pressure-relief valves, closed-loop sampling, and capping or plugging open-
ended lines or by replacing faulty devices. The use of portable organic
vapor detection instruments during individual component surveys is consid-
ered to be the best method for identifying leaks of organics from valves
and pump seals;130 use Of such instruments constitutes the only type of
leak detection method for which a control efficiency has been quantified.
The control efficiency of individual component surveys depends on:
(1) action level or leak definition, (2) monitoring interval or frequency,
(3) achievable emission reduction of maintenance, and (4) interval between
detection and repair of the leak. Background information developed by EPA
to support standards for SOCMI fugitive emissions indicates that a monthly
inspection and repair program of systems handling light liquid reduces
fugitive emissions from pumps by 61 percent and from valves by 46 per-
cent. 131 The study also shows that closed-loop sampling and capping open-
ended lines provide 100 percent control of these emission sources. Consid-
ering the similarity between SOCMI sources and TSDF sources, these prac-
tices are expected to give equivalent reductions at TSDF. Nationwide
emission reductions were estimated based on the above emission reductions
along with the estimated relative numbers of pumps, valves, sampling con-
nections, and open-ended lines in the waste management system. Combined,
these control techniques provide weighted control efficiencies of 70 per-
cent for systems handling light liquids and 78 percent for systems handling
heavy liquids.
4.7 SUMMARY OF CONTROL TECHNOLOGIES SELECTED FOR CONTROL OPTION
ANALYSES
A control option is a combination of control technologies applied to
TSDF emission source categories to reduce nationwide TSDF organic air emis-
sions. The selection of control options and estimates of the nationwide
organic air emission, health risk, environmental, and cost impacts of
options are discussed beginning in Chapter 5.0.
Table 4-2 lists the types of control technologies that are selected in
Chapter 5.0 for reducing organic air emissions from each TSDF emission
source category. Table 4-3 shows the emission reduction efficiencies used
in the nationwide impacts analysis for specific control options applied to
specific emission sources.
4-70
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TABLE 4-2. EMISSION CONTROL OPTIONS USED FOR SELECTING
TSDF CONTROL OPTIONS9
Management process
source category
Control options*3
Suppression .Add-on
Process
modification/work
practices
Quiescent surface impoundment0
Storage or treatment
Disposal
Dumpster storage
Quiescent (storage or treatment) tank
Uncovered
Covered
Waste fixation
Pit
Enclosed mechanical mixer
Aerated/agitated surface impoundment
(treatment)
Aerated/agitated uncovered tank
(treatment)
Land treatment
X
X
No direct controls; pretreat to
remove organics or incinerate wastes"
X
X
X
X
X
X
X
No direct controls; pretreat to
remove organics, incinerate, or
coke wastes6
Active landfill
Closed landfill
Wastepile
Equipment leaks
Pumps, valves, and
pressure-relief valves
X
X
X
X
(continued)
4-71
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TABLE 4-2 (continued)
Control options^3
Management process
source category
Suppression Add-on
Process
modification/work
practices
Equipment leaks (con.)
Sampling connections
Open-ended lines
Drum storage with enclosure^
Drum and tank truck loading
Spills
Organic compound removal devices
All TSDF process/emission sources
X
X
X
X
TSDF = Transfer, storage, and disposal facilities.
HW = Hazardous waste.
aThe development of control strategies is discussed in Chapter 5.0.
^Emission control options are of four types; examples of each control type
are given in Table 4-1. Specific control options evaluated in this study
are identified in Table 4-3.
clncludes treatment impoundments that are dredged annually and that are thus
exempt from land disposal restriction regulations.
"Disposal surface impoundments function via evaporation. Direct controls
such as covers inhibit evaporation.
eCoking is a control option only at refineries that have an existing coking
operation and that meet the conditions specified in a November 1985 Federal
Register notice.132
fbrums and containers are stored in a building that can be vented to a
control device.
4-72
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4-75
-------
Although the control types listed in Table 4-3 for the source category
are typically applicable to the source category, there may be site-specific
conditions that inhibit or prevent the use of a particular control type at
a particular facility. Where there are several choices of control type
with equivalent levels of performance for a specific source category, pre-
sumably the facility operator would choose the lowest cost type to apply.
In some cases, there are significant differences in the costs of control
for similar performance levels, but factors such as waste incompatibility
or source size may prevent use of the least costly control. For this rea-
son, "generic control devices" have been defined for tanks and waste fixa-
tion source categories for use in estimating nationwide emission reductions
and control costs.
Table 4-4 defines the generic control devices used for the nationwide
impacts estimates. Selection of the percentage weightings for each generic
control device was made on the basis of engineering judgment, taking into
account the application limitations of the different control technologies,
relative costs, and information about current industry practice.
Venting a tank to an existing, on-site control device is generally
less expensive than using an internal floating roof or venting to a carbon
adsorber. However, not all TSDF have an existing control device suitable
to receive the tank vent stream. Depending on number of tank turnovers and
organic content of the waste, an internal floating roof will be less expen-
sive than venting to a carbon adsorber. However, some wastes are not com-
patible with roof seal materials,-so the internal floating roof is not
always applicable either. With a low number of tank turnovers and low
concentrations of low-volatility organics, carbon adsorbers can be cost-
competitive with internal floating roofs (details of estimated emission
reductions and control costs for the tank model units storing or treating
model wastes are presented in Appendixes C and H). The percentage weight-
ings presented in Table 4-4 for tank generic control devices were selected
after considering the above factors.
The selection of the percentage weightings for waste fixation is based
on TSDF site visits and contacts with TSDF operators. This information
indicates that open pit fixation is the most frequently used waste fixation
4-76
-------
TABLE 4-4. GENERIC CONTROL DEVICE DEFINITIONS3
Management process
source category
Percentage
weighting
Control technology
Quiescent (storage
or treatment) tank
Uncovered
Covered
Waste fixation
50
25
25
50
25
25
70
30
Fixed roof plus internal floating
roof
Fixed roof plus venting to carbon
canister or fixed-bed carbon
adsorber
Fixed roof plus venting to existing
control device
Internal floating roof
Vent to carbon canister or
fixed-bed carbon adsorber
Vent to existing control device
Replace pit with mechanical mixer
vented to fixed-bed carbon
adsorber
Vent existing mechanical mixer
to fixed-bed carbon adsorber
aThis table defines the combinations of control technology types used to
estimate nationwide emission reductions and control costs for the listed
source category.
bPercentage weightings show the percentages of each control option emission
reduction and cost used to define overall emission reductions and costs
for the particular combination of source category and control type.
4-77
-------
process. Consequently, it is estimated that 70 percent of existing TSDF
waste fixation operations will need to be converted to mechanical mixing-
type operations before add-on controls can be applied.
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4-78
-------
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4-79
-------
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34. Reference 28, p. 3-30.
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36. , Reference 27, p. 3-7 through 3-13.
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list of EPA addressees. August 22, 1980. Thermal incinerators and
flares.
38. Lee, K., J. L. Hansen, and D. C. McCauley, Union Carbide. Revised
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4-80
-------
40.
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Midwest Research Institute. Emission Test of Acrylic Acid and Ester
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78-OCM-9. August 1980.
Midwest Research Institute. Stationary Source Testing of a Maleic
Anhydride Plant at the Denka Chemical Corporation, Houston, Texas.
Prepared for the U.S. Environmental Protection Agency, Office of Air
Qulity Planning and Standards. Research Triangle Park, NC. EMB
Report 78-OCM-4. March 1978.
U.S. Environmental Protection Agency. Distillation Operations in
Synthetic Organic Chemical Manufacturing-Background Information for
Proposed Standards. Publication No. EPA-450/3-83/005a. December
1983. p. 4-21.
Reference 42, p. 7-6.
Reference 42, p. 4-31.
U.S. Environmental Protection Agency. Parametric Evaluation of VOC/
HAP Destruction via Catalytic Incineration. Project Summary.
Research Triangle Park, NC. Publication No. EPA/600/52-85/041. July
1985. 4 p.
U.S. Environmental Protection Agency. Destruction of Chlorinated
Hydrocarbons by Catalytic Oxidation. Washington, DC. Publication
No. EPA-600/2-86-079. September 1986. p. 9.
MacKinnon, D. J. Nitric Oxide Formation at High Temperatures. Jour-
nal of the Air Pollution Control Association. 24(3):237-239. March
1974.
Reference 42, p. 4-12 through 4-14.
U.S. Environmental Protection Agency. Flare Efficiency Study.
Research Triangle Park, NC. Publication No. EPA-600/2-83-052.
1983. 133 p.
July
U.S. Environmental Protection Agency. Evaluation of the Efficiency
of Industrial Flares: Test Results. Research Triangle Park, NC.
Publication No. EPA-600/2-84-095. May 1984. 178 p.
Code of Federal Regulations. Title 40, Part 60.18. General Control
Device Requirements. U.S. Government Printing Office. Washington,
DC. July 1, 1986. p. 218-219.
U.S. Environmental Protection Agency. Evaluation of the Efficiency
of Industrial Flares: Flare Head Design and Gas Composition.
Research Triangle Park, NC. Publication No. EPA-600/2-85-106.
September 1985. 129 p.
4-81
-------
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
Reference 42, p. 4-20 through 4-23.
U.S. Environmental Protection Agency. Emission Test Report on Ethyl-
benzene/Styrene, Amoco Chemicals Company, Texas City, Texas. Office
of Air Quality Planning and Standards. Research Triangle Park, NC.
EMB Report 79-OCM-13. August 1979.
U.S. Environmental Protection Agency. Emission Test Report on
Ethyl benzene/Styrene, U.S.S. Chemicals, Houston, Texas. Office of
Air Quality Planning and Standards. Research Triangle Park, NC. EMB
Report 80-OCM-19. August 1980.
U.S. Environmental Protection Agency. Emission Test Report on
Ethylbenzene/Styrene, El Paso Products Company, Odessa, Texas.
Office of Air Quality Planning and Standards. Research Triangle
Park, NC. EMB Report 79-OCM-15. April 1981.
U.S. Environmental Protection Agency. Organic Chemical Manufactur-
ing. Volume 5: Adsorption, Condensation, and Absorption Devices.
Research Triangle Park, NC. Publication No. EPA-450/3-80-027.
December 1980. p. II-2.
U.S. Environmental Protection Agency. Air Pollution Engineering
Manual. Research Triangle Park, NC. Publication No. AP-40. May
1973. p. 189-198.
Reference 27, p. 3-63 through 3-74.
Reference 27, p. 3-52 through 3-63.
U.S. Environmental Protection Agency. Process Design Manual for
Stripping of Organics. Cincinnati, OH. Publication No. EPA-600/2-
84-139. August 1984.
Schweitzer, P. A. Handbook of Separation Techniques for Chemical
Engineers. New York, McGraw-Hill Book Co. 1979. p. 1-147 through
1-178.
Perry, R. H. (ed.). Chemical Engineers' Handbook. 5th ed.
York, McGraw-Hill Book Co. 1973. p. 13-1 through 13-60.
New
King, C. J. Separation Processes. New York, McGraw-Hill Book Co.
1971. 809 p.
Treybal, R. E. Mass-Transfer Operations. New York, McGraw-Hill Book
Co. 1968. p. 220-406.
Berkowitz, J. B., et al. Unit Operations for Treatment of Hazardous
Industrial Wastes. Noyes Data Corporation. Park Ridge, NJ. 1978.
p. 369-405, 849-896.
4-82
-------
67. U.S. Environmental Protection Agency. Preliminary Assessment of
Hazardous Waste Pretreatment as an Air Pollution Control Technique.
EPA 600/2-86-028, NTIS PB46-17209/A6, March 1986.
68. Exner, J. H. Detoxification of Hazardous Waste. Ann Arbor, MI, Ann
Arbor Science. 1980. p. 1-39.
69. Metcalf and Eddy, Inc. Briefing: Technologies Applicable to Hazard-
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70. Reference 63, p. 13-50 through 13-55.
71. Reference 67, p. 45.
72. Research Triangle Institute. Field Test and Evaluation of the Steam
Stripping Process at B. F. Goodrich, LaPorte, Texas. Prepared for
U.S. Environmental Protection Agency. Cincinnati, OH. Contract No.
68-03-3253. December 5, 1986. 91 p.
73. Reference 67, p. 43.
74. Allen, C. C., et al. Research Triangle Institute. Field Evaluations
of Hazardous Waste Pretreatment as an Air Pollution Control Tech-
nique. Prepared for U.S. Environmental Protection Agency. Cincin-
nati, OH. Publication No. EPA-600/2-86-048. April 1986. p. 63.
75. Reference 61.
76. Hwang, S. T., and P. Fahrenthold. Treatability of Organic Priority
Pollutants by Steam Stripping. AIChE Symposium Series 197, Volume
76. 1980. p. 37-60.
77. Reference 69, Section 2.16.
78. Reference 66, p. 869.
79. Reference 66, Section 2.16.
80. U.S. Environmental Protection Agency. Air Stripping of Contaminated
Water Sources-Air Emissions and Controls. Research Triangle Park,
NC. Publication No. EPA-450/3-87-017. August 1987. 125pp.
81. Reference 66, Section 2.16.
82. Reference 66, p. 869-880.
83. Reference 74, p. 23.
84. Luwa Corporation. Product Literature--Luwa Thin-Film Evaporation
Technology. P.O. Box 16348, Charlotte, NC 28216.
4-83
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85. Harkins, S. M., et al. Research Triangle Institute. Pilot-Scale
Evaluation of a Thin-Film Evaporator for Volatile Organic Removal
from Petroleum Refinery Wastes. Prepared for U.S. Environmental
Protection Agency. Cincinnati, OH. EPA Contract No. 68-02-3253.
June 1987. p. 2-1.
86. Reference 74, p. 65-84.
87. Reference 63, p. 13-50 through 13-55.
88. Reference 62.
89. Reference 63, p. 13-50 through 13-55.
90. Reference 64.
91. Reference 65.
92. Reference 66.
93. Reference 67.
94. Reference 42.
95. Reference 68, p. 3-25.
96. Reference 69, Section 2.9.
97. Allen, C. C. Research Triangle Institute. Hazardous Waste Pre-
treatment for Emissions Control: Field Tests of Fractional Distilla-
tion at Plant B. Prepared for U.S. Environmental Protection Agency.
Cincinnati, OH. EPA Contract No. 68-02-3992, Work Assignment No. 35.
January 1986.
98. Reference 63, p. 19-57 through 19-85.
99. Reference 63, p. 19-76.
100. JACA Corporation. Preliminary Assessment of Predictive Techniques
for Filtration, Drying, Size Reduction, and Mixing Unit Operations.
Prepared for U.S. Environmental Protection Agency. Cincinnati, OH.
p. a-13 through a-14.
101. Northeim, C. Research Triangle Institute. Summary of EPA/Chevron/
API/RTI meeting on pretreatment of land treatable wastes for VO
removal. March 6, 1986.
102. PEI Associates, Inc. Field Evaluation of a Sludge Dewatering Unit at
a Petroleum Refinery. Volume I. Prepared for U.S. Environmental
Protection Agency. Cincinnati, OH. Contract-No. 68-02-3995. May
1988. p. 6-28 through 6-29.
4-84
-------
103.
104.
105.
106.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
Ross, R. D. The Burning Issue: Incineration of Hazardous Waste.
Pollution Engineering. August 1979. p. 25-28.
Reed, J. C., and B. L. Moore. Chapter 12, Ultimate Hazardous Waste
Disposal by Incineration. In: Toxic and Hazardous Waste Disposal,
Vol. 4. Ann Arbor, Michigan, New Ultimate Disposal Options, Ann
Arbor Science. 1980. p. 163-173.
Bonner, T. ,A., et al. Engineering Handbook for Hazardous Waste
Incineration. Monsanto Research Corporation. Dayton, OH. EPA Con-
• tract No. 68-03-3025, Work Directive SDM02. June 1981. p. 2-26.
Reference 105, p. 2-24.
U.S. Environmental Protection Agency. Innovative Thermal Hazardous
Waste Treatment Processes. Cincinnati, OH. Publication No. EPA-
600/2-85-049. NTIS PB85-192847. April 1985. p. 55.
Reference 105, p. 2-30.
Reference 105, p. 2-32.
Sittig, M. Incineration of Industrial Hazardous Wastes and Sludge.
Noyes Data Corporation. Park Ridge, NJ. 1979.
Reference 107.
Code of Federal Regulations. Title 40, Part 264.343. Incinerator
Performance Standards. U.S. Government Printing Office. Washington,
DC. July 1. 1986, p. 533-534.
U.S. Environmental Protection Agency. Petroleum Refinery Enforcement
Manual. Research Triangle Park, NC. January 1980. p. 4.13-1.
U.S. Environmental Protection Agency. Hazardous Waste Management
System; Burning of Waste Fuel and Used Oil in Boilers and Industrial
Furnaces: Final Rule. 50 FR 49164-71. November 28, 1985.
Trip report. Research Triangle Institute. Visit to Mobil Oil Cor-
poration, Joliet Refinery, Joliet, IL. Prepared for U.S. Environmen-
tal Protection Agency. September 4, 1986.
Telecon. Wright, Milton D., Research Triangle Institute, with
Weisenborn, Bill, Conoco, Inc. June 19, 1986. Coking of refinery
sludges.
Radian Corporation. Field Assessment of Air Emissions and Their Con-
trol at a Refinery Land Treatment Facility: Project Summary. Pre-
pared for U.S. Environmental Protection Agency. Cincinnati, OH. EPA
Contract No. 68-02-3850. September 12, 1986. 17 p.
4-85
-------
118. Weitzman, L. (Acurex Corporation). Organic Air Emissions from Waste
Stabilization. Prepared for U.S. Environmental Protection Agency,
Risk Reduction Engineering Research Laboratory, Cincinnati, Ohio.
Contract No. 68-02-4285, Work Assignment No. 1/016. January 30,
1989. 24 p.
119. Research Triangle Institute. Characterization of Nationwide Waste
Fixation Practices for Facilities Subject to RCRA Subtitle C.
Prepared for the U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle Park, NC.
August 17, 1989. 15 p.
120. Weitzman, L., L. Hamel, and S. Cadmus (Acurex Corporation). Volatile
Emissions from Stabilized Waste. Prepared for U.S. Environmental
Protection Agency, Hazardous Waste Engineering Research Laboratory,
Cincinnati, Ohio. Contract No. 68-02-3993, Work Assignments No. 32
and 37. September 1987. 125 pp.
121. Acurex Corporation. Trip report for visit to Michigan Disposal.
Prepared for the U.S. Environmental Protection Agency, Risk Reduction
Engineering Research Laboratory, Cincinnati, Ohio. June 6, 1989.
122. Acurex Corporation. Trip report for visit to S & W Waste, Inc.
Prepared for the U.S. Environmental Protection Agency, Risk Reduction
Engineering Research Laboratory, Cincinnati, Ohio. June 6, 1989.
123. Acurex Corporation. Trip report for visit to Chem-Met Services.
Prepared for the U.S. Environmental Protection Agency, Risk Reduction
Engineering Research Laboratory, Cincinnati, Ohio. June 6, 1989.
124. Acurex Corporation. Trip report for visit to Stout Environmental.
Prepared for the U.S. Environmental Protection Agency, Risk Reduction
Engineering Research Laboratory, Cincinnati, Ohio. June 22, 1989.
125. Acurex Corporation. Trip report for visit to GSX Services, Inc.
Prepared for the U.S. Environmental Protection Agency, Risk Reduction
Engineering Research Laboratory, Cincinnati, Ohio. June 22, 1989.
126. Research Triangle Institute. Trip report for site visit to Solidtek
Systems, Inc. Prepared for the U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle Park,
NC. August 3, 1989.
127. Reference 123.
128. Reference 126.
129. U.S. Environmental Protection Agency. Fugitive Emission Sources of
Organic Compounds—Additional Information on Emissions, Emission
Reductions, and Costs. Office of Air Quality Planning and Standards.
Research Triangle Park, NC. Publication No. EPA-450/3-82-010. April
1982. p. 2-21.
4-86
-------
130. Reference 129, p. 4-1 through 4-75.
131. U.S. Environmental Protection Agency. VOC Fugitive Emission Sources
in Synthetic Organic Chemicals Manufacturing Industry—Background
Information for Proposed Standards. Office of Air Quality Planning
and Standards. Research Triangle Park, NC. Publication No. EPA-
450/3-80-033a. November 1980. p. 4-1 through 4-27.
132. Reference 114.
4-87
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5.0 CONTROL OPTIONS
The purpose of this chapter is to describe control options considered
in the selection of a basis for air emission standards to be proposed for
treatment, storage, and disposal facilities (TSDF) under Section 3004(n) of
the Resource, Conservation, and Recovery Act (RCRA) as amended. In addi-
tion, this chapter describes the "baseline" against which the nationwide
impacts of control options were measured.
Five specific control options are described. These options are based
on the use of add-on emission controls applied to individual emission
sources. The estimated human health and environmental impacts of these
five options are presented in Chapter 6.0. Cost impacts are presented in
Chapter 7.0, and economic impacts^are presented in Chapter 8.0. The option
selected as the basis for the proposed standards, and the factors leading
to the selection of that option, are discussed in the preamble to the
proposed standards published in the Federal Register.
5.1 CONTROL OPTION CONCEPT
As discussed in Chapters 3.0 and.4.0, there are a variety of sources
of organic emissions at TSOF and several types of emission controls that
can be applied to many of these sources. The term "control option," as used
here, refers to a unique combination of emission sources, emission
controls, and action levels for applying the controls. Different options
are developed and evaluated to estimate the impacts of potential
regulations. It is important to recognize, however, that although a
control option identifies specific emission controls to be applied to TSDF
sources, a regulation written to implement the option may be in terms of
performance standards that allow equivalent, or more effective, controls
for compliance. The emission sources, controls, and action levels
considered in developing control options, the selection of control options
5-1
-------
for detailed evaluation, and the impacts to be estimated for each option
are discussed in the following sections.
5.2 EMISSION SOURCES, CONTROLS, AND ACTION LEVELS CONSIDERED IN
DEVELOPING CONTROL OPTIONS
5.2.1 Emission Sources
TDSF emission source categories are shown in Table 5-1. Hazardous
waste management processes with similar emission characteristics and
potential emission controls are grouped together (e.g., storage and
treatment quiescent tanks are combined into one source category). Land-
fills, wastepiles, and land treatment are shown grouped together under the
category of "Land Disposal Units." This is because hazardous wastes
entering these types of waste management units are regulated by the land
disposal restrictions (LDR), which require treatment of a waste with best
demonstrated available technology (BOAT) before it is placed in one of
these units. It is presumed that this treatment will decrease the organic
air emission potential of landfills, wastepiles, and land treatment, and
therefore additional air emission controls for these sources were not
considered in developing regulatory options. This presumption will be
reviewed after all requirements under the LDR program are promulgated.
Similarly, control of organic air emissions from ancillary equipment
(pumps, valves, flanges, etc.) and certain process vents at TSDF is
required by a separate rulemaking under RCRA Section 3004(n) proposed on
February 5, 1987 (52 FR 3748), and therefore additional controls for these
sources were not considered. More information on the LDR and the standards
for emissions from equipment leaks and process vents is presented in
Section 5.4.2.
Surface impoundments are also covered by the LDR, but are exempt from
LDR requirements under certain conditions. Those' impoundments not covered
by the LDR would continue to have significant potential air emissions and,
therefore, additional controls for surface impoundments are being con-
sidered under RCRA Section 3004(n).
5.2.2 Controls
As described in Chapter 4.0, there are a variety of control techniques
available to reduce organic air emissions from TSDF. These include the
5-2
-------
TABLE 5-1. TSDF EMISSION SOURCE CATEGORIES
Source category
Quiescent tanks (storage or treatment)
Quiescent impoundments (storage or treatment)
Non-quiescent tanks
Non-quiescent impoundments
Containers9
Waste fixation units
Ancillary equipment (pumps, valves, flanges, etc.)b
SpillsC
Hazardous waste incineration^
Land disposal units: Landfills, wastepiles, and land treatment6
TSDF = Treatment, storage, and disposal facilities.
alncludes loading and storage. Containers are any portable device in
which a material is stored, transported, treated, disposed, or otherwise
handled.
^Separate standards for equipment leaks were proposed February 5, 1987
(52 FR 3748).
cSpills are regulated by 40 CFR Part 264, Subparts D and J, and by Part
265, Subparts D and J.
^Air emissions from hazardous waste incinerators are regulated by 40 CFR
Part 264, Subpart 0.
eAll hazardous wastes placed in these sources must meet pretreatment.
requirements of the land disposal restrictions.
5-3
-------
addition of engineering controls, such as covers and add-on control
devices, and the use of waste treatment processes to remove organics
directly from hazardous waste, thus reducing its air emission potential
prior to placement in a waste management unit.
In selecting controls to serve as the bases of regulatory options, EPA
considered how the standards being developed for air emissions would fit
into the broad framework of regulations that affect the management of
hazardous waste at TSDF. Regulations are currently in place, or are being
developed, that are directed at hazardous waste disposal. These include
the LDR, standards for equipment leaks and process vents from treatment
processes, and standards for hazardous waste incinerators. In addition,
RCRA-exempt wastewater treatment units are being addressed under the Clean
Air Act. All of these regulations are designed to act together to protect
public health and the environment from exposure to pollutants via both
ground water and air from waste disposal units.
Considering that all hazardous waste must ultimately be disposed and
that the LDR ensure that air emissions generated by hazardous waste
disposal practices will be controlled, EPA has adopted a regulatory
philosophy of emission containment for TSDF sources that manage waste prior
to waste disposal. Under this philosophy, the focus is on applying
controls that reduce the volatilization of organics from hazardous waste
prior to disposal, where organics will either be destroyed or removed from
the waste by treatment processes that are controlled for air emissions.
Consistent with the objective of containing potential organic emis-
sions from hazardous waste prior to its disposal, the regulatory options
selected for detailed evaluation as possible bases for standards involve
primarily the use of suppression (covers) or suppression plus add-on
control devices. However, this will not necessarily preclude the use of
other, equally or more effective controls to meet the requirements of the
proposed regulation. For example, each of the options under consideration
consists of a combination of controls applied to TSDF emission sources plus
an action level above which the controls must be applied. By incorporating
an action level, each option would implicitly allow an owner or operator to
use a waste treatment process to reduce the organic content of the waste
5-4
-------
managed to below the action level, in which case additional controls would
not be required by the air standards.
5.2.3 Action Levels
To apply emission controls to waste management processes with regard
to the emission potential of the wastes managed, the regulatory control
options developed for TSDF air emission standards include an "action level"
above which controls must be applied. Action levels can be used as a
mechanism for prioritizing emission sources within a waste management
facility for control and for excluding sources that have lower emission
potential. Action levels can be expressed in several formats (e.g., in
terms of volume throughput, capacity, or measured or calculated emissions).
An action level based on waste volatile organic concentration (as measured
by an appropriate test method) is appropriate for TSDF sources such as open
tanks, surface impoundments, containers, and waste fixation, where hazard-
ous waste can be exposed directly to the ambient air, sunlight, and wind.
For completely enclosed sources, such as covered quiescent tanks, a more
appropriate indicator of emissions, and thus a more appropriate format for
an action level, is the vapor pressure of the waste.
In developing control options for TSDF air emission standards, EPA
incorporated two types of action levels. For all sources except covered
quiescent tanks, the action level associated with the option is based on
the volatile organic content of the waste at the point of generation. For
covered quiescent tanks, the action level above which additional controls
(e.g., vent to control device) would be required is based on the vapor
pressure of the waste contained in the tank.
5.3 SELECTION OF CONTROL OPTIONS
Five control options were selected for detailed evaluation that
illustrate the various combinations of action levels and controls that
could be applied to TSDF emission sources. All of the options selected
would be expected to result in significant reductions in organic emissions,
and associated human health and environmental impacts. They are also used
in later chapters to illustrate how the impacts of TSDF control options are
estimated. These five options are described in Table 5-2.
5-5
-------
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5-6
-------
Options 1, 2, 4, and 5 are distinguished from one another by the
number of sources requiring control; the number of sources requiring
control is determined by the volatile organic concentration action level.
In control option 1, the concentration action level is 0; that is, controls
would be required on all waste streams containing detectable amounts of
volatile organics. For control options 2, 4, and 5, the concentration
action levels are 500 ppm, 1,500 ppm, and 3,000 ppm, respectively. Unless
it is demonstrated that the waste being handled is below the volatile
organic concentration action level, all of the following controls would be
required: (1) covers or enclosures and submerged loading techniques would
be required to control emissions from container loading operations and for
dumpsters, (2) covers and control devices would be required for surface
impoundments, and (3) covers and control devices would be required for
tanks unless the tank is non-aerated and it is demonstrated that the vapor
pressure of the waste in the tank is below the vapor pressure action level.
In this case, covers alone would be required. If an owner or operator
wishes to demonstrate that the vapor pressure of a waste stream is below
the vapor pressure action level, he would have to perform a vapor pressure
test using an appropriate test method.
The types of covers that could be used on tanks to meet the standards
include fixed roofs, internal floating roofs, and external floating roofs.
Covers that could be used for surface impoundments include air-supported
structures. Control devices that could be used include carbon adsorption
units, vapor incinerators, and flares.
Control option 3 has an action level of 500 ppm, the same as option 2,
but differs from the other options in that covers alone may be used on non-
aerated tanks and surface impoundments without the need for a vapor
pressure test. The controls specified for this option are the same as
described above for all sources except non-aerated surface impoundments and
non-aerated tanks. Under this option, non-aerated surface impoundments
could use floating synthetic membranes as a means of complying with the
proposed standard.
The nationwide impacts that will be estimated for control options
selected for detailed evaluation and the baseline to which the impacts of
options will be compared are discussed below.
5-7
-------
5.4 BASELINE FOR NATIONWIDE IMPACTS ESTIMATES
The baseline provides a perspective from which the impacts of adopting
control options can be evaluated. Chapter 3.0 of this document presents
nationwide uncontrolled TSDF organic emissions; i.e., emissions with cur-
rent existing controls and before the adoption of additional nationwide
control requirements. However, there are regulations that affect TSDF air
emissions that are, or will be, in place when the RCRA 3004(n) standards
being developed in this rulemaking are promulgated. The baseline against
which the potential impacts of the 3004(n) standards are measured should
reflect these other regulatory requirements if they affect TSDF nationwide.
Federal regulatory requirements that affect TSDF nationwide include
the land disposal restrictions (proposed and promulgated under RCRA Section
3004(m)) and TSDF air standards for process vents and fugitive emissions
(proposed February 5, 1987, under RCRA Section 3004(n)). There are other
Federal requirements applicable to TSDF, such as the RCRA Corrective Action
Program (implemented under RCRA Section 3004(u)), but these are site-
specific rather than nationwide control requirements.
Also, there are standards that apply to TSDF emission sources at the
State level. However, these are limited and vary widely from State to
State. A survey of State programs indicated that 12 States have estab-
lished generic volatile organic compounds (VOC) standards that might affect
TSDF emission sources. Thirty States have standards applicable to storage
tanks, 17 States have standards for terminal loading, and 9 States have
standards for hazardous waste landfills. For those States that do have
standards, there are differences in how VOC is defined, making it difficult
to compare requirements from State to State.
After the review of Federal and State standards applicable to TSDF, it
was concluded that the baseline for the RCRA Section 3004(n) standards
under development should reflect the impacts of the LDR and the TSDF air
standards for process vents and equipment leaks. Due to the limited
applicability and lack of uniformity in State standards, they should not be
included in the baseline.
More information on how the impacts of the LDR and the TSDF process
vent and equipment leak standards will be simulated in the baseline is
presented below.
5-8
-------
5.4.1 Land Disposal Restrictions
The Hazardous and Solid Waste Amendments (HSWA) of 1984 mandate a
number of actions that EPA must take to reduce the threat of hazardous
waste to human health and the environment. These actions include
restricting hazardous wastes from land disposal. The EPA is currently
developing regulations (referred to as "land disposal restrictions") that
will require that hazardous wastes be treated to reduce concentrations of
.specific chemicals or hazardous properties before the waste may be placed
in a land disposal unit. The affected land disposal units include surface
impoundments, wastepiles, landfills, and land treatment operations.
Surface impoundments used for treatment of hazardous wastes are exempt from
the LDR if treatment residues are removed annually. The waste treatment
technologies required to reduce chemical concentrations before land
disposal are referred to as best demonstrated available technologies
(BOAT). The restrictions express BOAT as a performance standard that
requires wastes to be treated before entering a land disposal unit (to
reduce the waste's toxicity or mobility). The wastes must be treated to
levels that can be achieved by use of the best technologies commercially
available.
The EPA is developing the LDR in stages. Waste-specific prohibitions
on land disposal have been promulgated for certain spent solvent wastes (40
CFR 268.30); dioxin-containing hazardous wastes (40 CFR 268.31); the
"California list" wastes (40 CFR 268.32); the "First Third" set of listed
wastes (40 CFR 268.33); the "Second Third" set of listed wastes (40 CFR
268.34); and, recently, the "Third Third" set of listed wastes (55 FR
22520, June 1, 1990). The TSDF air emission standards being developed in
this current rulemaking would be promulgated after the date that LDR are in
effect for all wastes identified or listed as hazardous as of November 8,
1984. Therefore, the LDR are considered a part of the baseline against
which the potential impacts of the 3004(n) standards are measured.
The LDR for many listed wastes have only recently been finalized and
many of the treatment standards are expressed as performance standards for
certain constituents in the treatment residue rather than as specific
technology requirements. Therefore, EPA is not certain at this time as to
5-9
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how the LDR will ultimately impact TSDF air emissions. For the nationwide
impacts analysis, EPA first needed to forecast the approaches TSDF owners
and operators would most likely choose to implement the LDR for specific
wastes types. Using available information, EPA made certain assumptions
regarding the general or average response of the hazardous waste management
industry to compliance with the LDR. The following assumptions were
developed concerning the manner in which TSDF will respond to the restric-
tions for purposes of estimating overall baseline impacts for the air
standards:1
• All wastes currently land-treated (except organic-containing
solids) will be incinerated. Solids will be fixated.
• All organic liquids and sludge/slurries that are currently
sent to landfills and wastepiles will be incinerated or
steam-stripped.
• All dilute aqueous liquids and aqueous sludge/slurries are
fixated and landfilled.
• All surface impoundments will continue to operate as
impoundments and be dredged annually or will be converted to
uncovered tanks. In both cases, it is assumed that there
will be no change in emission, emission reductions, or cost
of control.
• All fixation processes will yield a solid waste product
rather than a nonliquid such as sludge. This assumes an
increase in the degree of fixation that will increase emis-
sions from the treatment process.
The technology assumptions listed above may not be sufficient to
comply with the LDR treatment standards for all TSDF. However, on a
nationwide basis, it is likely that they represent the general or average
response of the hazardous waste management industry. Therefore, it is a
reasonable basis for the calculation of baseline emissions against which
the nationwide impacts of potential air standards under RCRA Section
3004(n) are evaluated.
5.4.2 TSDF Air Standards for Equipment Leaks and Process Vent Control
To address concerns about air emissions from the treatment processes
expected to be used to comply with the land disposal restrictions, EPA
promulgated air emission standards under RCRA Section 3004(n) to reduce
5-10
-------
organic emissions vented from the treatment of hazardous wastes by
distillation, fractionation, thin-film evaporation, solvent extraction,
steam stripping, and air stripping, as well as from leaks in certain piping
and equipment used for hazardous waste management processes (55 FR 25454,
June 21, 1990). Sources of process vent emissions from treatment units
include process condenser vents, and distillate receivers, surge control
vessels, product separators, and hot wells, if process emissions are vented
through these vessels. Equipment leak sources include pumps, valves,
pressure-relief devices, compressors, open-ended lines, and sampling
connections. These standards apply to hazardous wastes containing greater
than 10 percent organics. Specific requirements include reduction of
process vent emissions to less than 1.4 kg/h (3 Ib/h) and 2.8 Mg/yr (3.1
tons/yr) or reduction of facility process vent emissions by 95 percent; and
a leak detection and repair program for equipment leaks.
To simulate the impact of these standards on the baseline, all process
vents and equipment leak emissions at facilities handling wastes containing
greater than 10 percent organics are assumed to be controlled as part of
the baseline.
5.4.3 New Source Performance Standards (NSPS) for Volatile
Organic Storage Vessels
Under the authority of the Clean Air Act, EPA has promulgated
standards of performance in 40 CFR Part 60 for storage vessels that contain
volatile organic liquids (VOL), and that are constructed or modified after
July 23, 1984. These standards require that tanks larger than 75 m3 (about
20,000 gal) containing VOL be equipped with air pollution controls if the
vapor pressure of the stored organic liquid is greater than the specified
levels. The controls required by the standards are shown in Table 5-3.
The EPA views the controls required by the NSPS as minimum controls
for any large tank containing organic hazardous waste, regardless of the
date of construction of the tank. Accordingly, the NSPS control require-
ments for VOL storage vessels are included as minimum baseline control
requirements for tanks in the standards proposed for hazardous waste TSDF
under RCRA Section 3004(n). An exception to this is the NSPS requirement
for any tank greater than 75 m3 and containing an organic liquid with a
vapor pressure greater than 76.6 kPa. This requirement is not included in
5-11
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TABLE 5-3. CONTROL REQUIREMENTS UNDER THE CLEAN AIR ACT FOR
VOLATILE ORGANIC LIQUID STORAGE VESSELS3
Tank size
Vapor pressure
of stored liquid
Controls required
From 75 m3 up to
151 ra3
(from 19,789 to
39,841 gal)
From 27.6 kPa to
76.6 kPa
Equal to or
greater than
76.6 kPa
One of the following:
(1) Fixed roof plus internal
floating roof;
(2) External floating roof;
(3) Closed vent system plus a
control device; or
(4) A system equivalent to those
described in (1) - (3).
A closed vent system plus a
control device.
Equal to or
greater than
151 m3
(greater than
39,841 gal)
From 5.2 up to
76.6 kPa
Equal to or
greater than
76.6 kPa
One of the following:
(1) Fixed roof plus internal
floating roof;
(2) External floating roof;
(3) Closed vent system plus a •
control device; or
(4) A system equivalent to those
described in (1) - (3).
A closed vent system plus a
control device.
aSource: 40 CFR Part 60, Subpart Kb.
5-12
-------
the proposed TSDF standards because EPA does not expect wastes managed at
TSDF to have vapor pressures near or above this value.
The EPA believes that most existing tanks at TSDF are smaller than the
sizes regulated by the NSPS for VOL storage vessels. Consequently, includ-
ing the NSPS requirements for VOL storage in the proposed standards for
TSDF under RCRA 3004(n) should have little or no additional impacts.
However, making the NSPS control requirements part of the baseline for the
TSDF standards would ensure that any existing large tanks used for the
management of hazardous waste at TSDF are controlled at least as effec-
tively as new tanks.
5.5 REFERENCE
1. Industrial Economics, Inc., and ICF Incorporated. Regulatory Analysis
of Proposed Restrictions on Land Disposal of"Hazardous Wastes. Pre-
pared for U.S. Environmental Protection Agency. Washington, DC.
December 27, 1985. p. 4-20 through 4-22 and exhibits.
5-13
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6.0 NATIONAL ORGANIC EMISSIONS AND HEALTH RISK IMPACTS
The nationwide organic air emission and health risk impacts associated
with each of the treatment, storage, and disposal facility (TSDF) control
options identified in Chapter 5.0 are discussed in this chapter. The
primary emphasis of Chapter 6.0 is to present the approach for assessing
these impacts by using the control options as a guide for discussion and
presentation. Both beneficial and adverse environmental impacts are
assessed. Table 6-1 summarizes these nationwide impacts; presented are the
nationwide estimates of TSDF organic emissions, cancer incidence, and maxi-
mum lifetime risk for the five control options as well as the uncontrolled
and baseline scenarios. Comparisons to the baseline situation are also
made to provide a relative measure of the effectiveness of or degree of
control required under the five options. More detailed information on the
emissions and health risks associated with implementation of the control
options are provided in Sections 6.1 and 6.2. The nationwide emission
reduction for each control option is tabulated in Section 6.1. Impacts on
human health, assessed as cancer incidence and maximum lifetime risk of
contracting cancer, are presented in Section 6.2. Impacts on water qual-
ity, solid waste, energy, and other environmental concerns are presented in
Section 6.3.
6.1 ORGANIC EMISSION IMPACTS
This section presents the nationwide impacts on TSDF organic air emis-
sions for five control options and includes a description of how emissions
under the uncontrolled, baseline, and controlled scenarios were estimated.
A tabular presentation of the estimated emission reductions from affected
waste management units is also included. As discussed in Chapter 5.0, the
baseline case assumes that Resource Conservation and Recovery Act (RCRA)
land disposal restrictions and the 1987 proposed TSDF air emission
6-1
-------
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6-2
-------
standards (52 FR 3748) are in effect. Control options 1 through 5
represent the potential "controlled" cases. Data are presented for these
seven scenarios to allow comparison of the impacts of the control options
to current and to 1987 proposed standards on TSDF organic air emissions
nationwide.
Chapter 3.0 of this document, "Industry Description and Air Emis-
sions," provides nationwide estimates of uncontrolled emissions by TSDF
management process. Nationwide emissions were computed using the computer-
ized Source Assessment Model (SAM) by first identifying all process source
categories listed in the Industry Profile (described in Appendix D.2.1).
Once these categories were identified, their emissions were calculated by
multiplying the organic quantity of each waste stream by an emission factor
specific to the particular management process and the wastes being
processed (see Appendix D, Section D.2.4.1). Emissions per process per
TSDF then were summed to yield a nationwide uncontrolled emission estimate.
To calculate the quantity of emissions reduced by applying organic
emission controls, the control technologies described in.Chapter 4.0 were
applied to the appropriate waste management processes (source category) as
required by one of five control options. Control options 1-5 apply to
wastes containing organics at concentrations greater than the action level
associated with the option. They entail covers and control devices for
tanks (including waste fixation) and impoundments, submerged loading of
drums, and covers for dumpsters. For covered storage and quiescent treat-
ment tanks, venting to a control device is required only if the vapor
pressure of the waste in the tank exceeds 10.3 kPa (1.5 psi) for control
options 1, 2, 4, and 5. No control devices are applied to covered storage
and quiescent treatment tanks for control option 3.
The magnitude of nationwide organic emissions associated with each
option was calculated using the SAM. In short, this consisted of adjusting
the uncontrolled and baseline emissions by the control efficiency of the
control technology required under each particular option, for each TSDF
process stream at each facility nationwide. Summation of results provides
an estimate of emissions per control option. Table 6-2 presents the
nationwide results by emission source resulting from implementation of.each
6-3
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-------
control option by source category. Because the specific design and
operating characteristics of each waste management process are not widely
available, nationwide distributions of process design and operating
parameters were used in estimating TSDF emissions. Therefore, it is
appropriate that nationwide TSDF emissions and impacts are used in the
comparison of the various control options. As noted in Chapter 3.0, the
estimation of TSDF emissions in this document involved the use of the TSDF
air emission models as presented in the March 1987 draft of the air emis-
sion models report rather than the December 1987 version of the report.
Comments have been received providing additional information on the
concentration of organics in biologically active treatment processes and
the aeration parameters used for the model units.1 Proposed revisions to
the aerated units and the biodegradation model were evaluated in a sensi-
tivity analysis to determine the effect on the nationwide impacts presented
in this document.2 The results of the analysis showed that the combined
effects of the proposed changes had only a minor effect (less than 5 per-
cent) on nationwide impacts. Consequently, the impacts presented for
emissions and incidence, although based on the original biodegradation
model and material balance in Appendix C, Equation C-5, would not change
significantly with the revisions that were proposed to improve the modeling
approach.
Nationwide uncontrolled organic air emissions were estimated at about
1.7 million Mg/yr; baseline emissions were 1.8 million Mg/yr. Quiescent
tanks used for storage or treatment are the largest uncontrolled emitters
nationwide under these two scenarios. Land treatment sources have zero
emissions for the baseline and controlled cases because the land disposal
restrictions will require pretreatment to remove volatile organics prior to
land treatment. The control options do not apply.to drum storage because
this source is controlled by existing regulations (CFR Parts 264 and 265,
Subpart I). Similarly, wastepiles and landfills are not controlled under
the options because they are controlled by the land disposal restrictions.
Emission reductions from baseline for the five control options range
from 1.6 million Mg/yr (control option 5) to 1.7 million Mg/yr (control
option 1). Control options for quiescent tanks yield the highest emission
reductions. Some sources such as landfill and incineration processes show
_
6-6
-------
an increase in emissions when a control option is applied. These increases
occur because (1) emissions are suppressed from upstream controlled sources
(i.e., the waste stream retains the organics that would have been emitted
previously, which results in an increase in organics at the source of
interest), and (2) when controls are applied, new emission sources are
created such as pumps and valves (i.e., equipment leaks).
6.2 HUMAN HEALTH RISKS
Health risks posed by exposure to TSDF organic air emissions are
presented in this section in three forms: annual cancer incidence
(incidents per year nationwide resulting from exposure to TSDF organic air
emissions), maximum lifetime risk (the highest risk of contracting cancer
that any individual could have from exposure to TSDF emissions), and
noncancer health effects (from acute and chronic exposures to noncarcino-
genic chemical emissions from TSDF). Annual cancer incidence and maximum
lifetime risk are used as an index to quantify health impacts for seven
cases: (1) uncontrolled organic air emissions, (2) baseline air emissions,
and (3) controlled emissions under the five options.
Detailed discussion on the development of the health effects data
presented here are found in Appendixes E and J. In general, the methodol-
ogy consists of four major components: estimation of the annual average
concentration patterns of TSDF organic air emissions in the region sur-
rounding each facility, estimation of the population associated with each
computed concentration, estimation of exposures computed by summing the
products of the concentrations and associated populations, and, finally,
estimation of annual incidence and maximum lifetime risk, which are
obtained from exposure and TSDF emission potency data.
6.2.1 Annual Cancer Incidence
For the estimates of TSDF incidence, the Human Exposure Model (HEM),
which uses a basic EPA dispersion algorithm, was used to generate organic
emission concentration patterns. The TSDF Industry Profile (see Appendix
D.2.1) was accessed to identify facility locations for population pattern
estimation within the HEM using 1980 census population distributions. The
HEM was run for each TSDF using a fixed unit risk factor and a facility
organic emission rate; as such, the HEM site-specific incidence results can
6-7
-------
be adjusted by the annual facility emissions generated from the SAM and the
appropriate TSDF unit risk factor to give facility-specific estimates for
the control option under consideration. A unique unit risk factor was
derived for each option based on the emissions of specific carcinogens
under that option (see Appendix E). The incidence results therefore
reflect the level and composition of emissions resulting from a particular
emission scenario or control option.
As shown in Table 6-3, incidence estimates indicate that an uncon-
trolled TSDF industry would lead to 130 cancer incidents per year
nationwide; the baseline TSDF industry case would lead to 140 incidents.
Control options 1 through 5 reduce the estimated number of cancer
incidences by 89 to 95 percent from 140 in the baseline case to a range of
6.4 to 16 per year.
6.2.2 Maximum Lifetime Risk
Maximum lifetime risk (MLR) represents "individual" risk as opposed to
the "aggregate" risk in the total nationwide cancer incidence and is
intended to reflect the Nation's most exposed individual's chance of
getting cancer if exposed continuously for 70 years to the highest annual
average ambient concentration around a TSDF. As such, MLR reflects the
highest risk that any person would have from exposure to TSDF emissions.
MLR is calculated as a function of ambient organic concentration and the
composite unit risk factor for TSDF organic emissions. For TSDF MLR
estimates, the Industrial Source Complex Long-Term Model (ISCLT), a state-
of-the-art air quality dispersion model, was used to generate the maximum
annual average ambient organic concentration estimates (see Appendix J for
a description of the model). In order to provide a more comprehensive
analysis of maximum ambient concentrations, two TSDF were selected for
detailed, rigorous analysis in making MLR estimates. The two facilities
were selected on the basis of their estimated emissions and the TSDF
management processes utilized at the facilities. The design and operating
parameters and wastes managed at these two facilities were used in conjunc-
tion with the local meteorological conditions (standard climatological
frequency of occurrence summaries) to estimate dispersion of emissions from
each source at each facility on an annual basis. Multiplying the maximum
annual average ambient concentration by the composite unit risk factor
6-8
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yields the maximum risk, given that someone is predicted to reside at that
location. The unit risks from the various individual dispersed carcinogens
are represented by a composite unit risk factor derived for each option for
TSDF organic emissions. Pertinent information on the selected TSDF and
unit risks is presented in Appendix J and Appendix E, respectively.
The results of the MLR calculations, shown in Table 6-4, indicate that
the probability of contracting cancer is 2 x 10"2 for the baseline TSDF
industry. For control options 1 through 5, these risks range from 5 x 10~4
to 9 x 10~4. For all options, aerated units are the major sources
contributing to the maximum ambient air concentrations associated with the
MLR values.
6.2.3 Noncancer Health Effects Assessment—Acute and Chronic Exposures
A screening analysis of the potential adverse noncancer health effects
associated with acute and chronic exposure to individual waste constituents
emitted from the two selected TSDF was based on a comparison of relevant
health data to the highest short-term (i.e., 15-min, 1-h, 3-h, and 24-h) or
long-term (i.e., annual) modeled ambient concentrations for chemicals at
each facility (see Appendix E). Modeled concentrations were estimated from
the Industrial Source Complex-Short Term (ISCST) Model. Detailed informa-
tion on this model and on modeled ambient concentrations of constituents at
each facility is provided in Appendix J.
Results of this analysis indicate that adverse noncancer health
effects are unlikely to be associated with acute or chronic exposure to the
given ambient concentrations of individual chemicals at these two TSDF.
Modeled short-term and long-term ambient concentrations were in most cases
at least three orders of magnitude below health effects levels of concern.
It should be noted that the health data base for many chemicals was
limited, particularly for short-term exposures. The conclusions reached in
this analysis should be considered in the context of the limitations of the
health data, the uncertainties associated with the characterization of
wastes at the two facilities, and the assumptions used in estimating
emissions, ambient concentrations, and the potential for human exposure.
6-11
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TABLE 6-4. MAXIMUM LIFETIME RISKS FROM
TSDF EMISSIONS9
Control scenario
Uncontrolled
Baseline
Option 1
Option 2
Option 3
Option 4
Option 5
Maximum
concentration,
/jg/m3
1,700
1,700
43
43
47
60
81
Maximum risk*3
2 x lO-2
2 x ID'2
5 x 10-4
5 x 10-4
5 x ID'4
8 x ID'4
9 x ID'4
aThis table shows the cancer risk of the individual in
the United States most exposed to TSDF emissions over a
70-year period. Risk is presented for seven scenarios,
which are described in detail in Chapter 5.0.
Development of risk data is presented in Appendixes E
and J.
bBased on the composite risk factors derived for each
scenario as described in Appendix E.
6-12
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6.3 OTHER ENVIRONMENTAL IMPACTS
The types of environmental impacts that potentially may result from
the operation of control devices used to reduce TSDF organic air emissions
were discussed in Chapter 4.0. Estimates of the magnitude of the secondary
air and cross-media impacts associated with the different control options
were prepared using an approach that applied energy conversion factors, air
emission factors, and wastewater and solid waste generation rates to the
results of the Source Assessment Model (SAM) control option analyses.
The secondary air and cross-media impact results are sensitive to the
control device operating conditions used at TSDF (e.g., electricity source,
type of fuel burned to produce steam, spent activated carbon management
practices). To account for this sensitivity, a range of secondary air and
cross-media impacts estimates was computed for each control option by
defining two sets of TSDF control device operating conditions that provide
an upper boundary estimate and a lower boundary estimate. This approach
allows a range of values to be computed that spans the conditions most
likely to occur at TSDF on a nationwide average basis. The two sets of
TSDF control device operating conditions selected are summarized in Table
6-5.
A nine-step procedure was followed to estimate nationwide annual air
emission, wastewater, solid waste, and energy impacts produced by the
operation of the control devices selected for each control option. The
procedure is outlined below:
Define the TSDF control device operating conditions.
1.
2.
4.
5.
Develop TSDF source category operation factors relating
specific control device operating requirements (e.g., elec-
tricity demand, steam demand, activated carbon requirements)
to the amount of hazardous waste managed.
Select energy conversion factors for electricity generation
by fossil fuel-fired utility power plants and process steam
production by industrial boilers.
Select air pollutant emission factors for utility boilers,
industrial boilers, and hazardous waste incinerators.
Select wastewater and solid waste generation rate factors
for utility power plants, carbon regeneration units, and
hazardous waste incinerators.
6-13
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TABLE 6-5. TSDF CONTROL DEVICE OPERATING CONDITIONS SELECTED FOR
SECONDARY AIR AND CROSS-MEDIA IMPACT ESTIMATES
TSDF control device
operating condition
Lower
boundary
Upper
boundary
Electricity
Electicity source
Electric utility
power plant mix
Electric utility
50% coal
25% natural gas
25% noncombustion
Electric utility
100% coal
Process steam
Process steam source
Steam boiler fuel
Onsite industrial
boiler
100% natural gas
Onsite industrial
boiler
100% fuel oil
Carbon adsorption units
Fixed-bed carbon unit
regeneration yield
Spent carbon canister
management practice
903
100% regenerated
with 90% yield
803
100% direct
landfill disposal
6-14
-------
6. Obtain SAM results for each control option listing annual
nationwide hazardous waste throughput (megagrams of waste
per year) by TSDF source category.
7. Multiply control device operation factors times individual
TSDF source category throughput to obtain annual electric-
ity, steam, and carbon demand for each TSDF source category.
8. Add the individual source category demand values to obtain
the total nationwide annual electricity, steam, and carbon
demand for each control option.
9. Multiply the total annual electricity, steam, and carbon
demand values by the appropriate energy conversion factors,
air emission factors, and wastewater and solid waste genera-
tion rate factors to obtain nationwide annual secondary air
and cross-media impacts.
Control device operation factors were developed for each TSDF source
category using the control cost estimates presented in Appendix H. As part
of these cost estimates, annual control device electricity, steam, and
carbon consumption were computed to determine capital and annual control
costs for individual TSDF model units defined for each TSDF source cate-
gory. Each operation factor was calculated by dividing the control device
annual consumption value by the annual hazardous waste throughput defined
for the model unit.
Energy conversion factors were selected based on engineering judgment
to be consistent with typical electric utility power generation and indus-
trial process steam production practices. Fuel property and air emission
factor values were selected from the EPA document Compilation of Air Pol-
lutant Emission Factors (AP-42).3 Wastewater and solid waste generation
rates were computed for the defined TSDF control device operations and fuel
property values. The specific values used for the secondary air and cross.r
media impacts calculations are listed in Appendix K.
Secondary air and cross-media impacts were estimated for each control
option using the TSDF source category nationwide annual hazardous waste
throughput values estimated by the SAM analyses. The nationwide secondary
air pollutant emission impacts, wastewater discharge impacts, solid waste
disposal impacts, and energy impact for the five control options are
presented in Table 6-6.
6-15
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To provide a sense of the magnitude of the nationwide TSDF control
device secondary air and cross-media impacts, the values presented in Table
6-6 can be compared to the impacts produced by a single coal-fired utility
power plant. Recognizing that the TSDF control device impacts would not
all occur at a single location, the order-of-magnitude of the nationwide
control options 1 through 5 impacts is comparable to the air emission,
wastewater, and solid waste impacts associated with a new 100-MW utility
power plant burning a high-sulfur coal.
6.4 REFERENCES
1. Chemical Manufacturers Association. Comments of the Chemical
Manufacturers Association on the Environmental Protection Agency
Document "Hazardous Waste TSDF - Background Information for Proposed
RCRA Air Emission Standards - Volumes I and II." Washington, D.C.
July 11, 1988. 105 p.
2. Memorandum from Coy, D., RTI, to Docket. January 1989. Investigation
of and Recommendations for Revisions to Aerated Model Unit Parameters
Used in the Source Assessment Model.
3. U.S. Environmental Protection Agency. Compilation of Air Pollutant
Emission Factors, 4th edition, AP-42. Office of Air Quality Planning
and Standards, Research Triangle Park, NC. September 1985.
6-17
-------
-------
7.0 COSTS OF THE CONTROL OPTIONS
The purpose of this chapter is to present the methodology used to
estimate nationwide costs of adopting each of the five control options
described in Chapter 5.0 as the basis for regulation of air emissions, from.
hazardous waste treatment, storage, and disposal facilities (TSDF). Esti-
mated nationwide total capital investment (TCI; i.e., equipment purchase
and direct and indirect installation costs) and total annual costs (TAC;
i.e., costs of operating control technologies minus any energy or materials
credits) are provided in a subsequent section of this chapter. In addi-
tion, the cost per unit of waste throughput for the control technologies
identified in Chapter 5.0 as part of the control options is discussed and
listed, and a general explanation of the methodology used to derive those
unit costs is presented in this chapter. Supporting data are provided in
Appendix H to this document, and other references to cost information are
listed in that appendix.
Development of costs requires the presumption of a baseline level of
emissions and emission control from which the control costs can be calcu-
lated. The baseline used for this effort is described in Chapter 5.0,
Section 5.1, of this document. Costs to implement the control options are
provided to permit a comparison of the resources that would be expended to
reduce air emissions from TSDF using different combinations of controls and
sources.
7.1 CONTROL COSTS DEVELOPMENT
Estimation of the nationwide costs of adopting a control option begins
with estimation of the control costs for individual waste management units
within a TSDF. Ideally, information about the design and operating charac-
teristics (such as surface area and retention time for impoundments) of
each waste management unit would be available to permit accurate estimates
7-1
-------
of control costs for that unit. Information at that level of detail is not
available for each unit at each facility; generally, only waste throughput
is known. For this reason, model units were developed. Rationale for the
development of model units is given in Chapter 3.0, Section 3.2.1 (as
relates to emission estimation) and Section C.2. Control cost estimates
were developed for each of the model units (results are shown in Section
C.2.3). The methodology for developing control costs for the model units
is described partially in Section 7.1.1 and in detail in Appendix H.
To obtain nationwide costs from model unit costs requires a method of
assigning a model unit cost to each waste management unit in each facility
and then computing the sum. Given that only TSDF waste management unit
throughput is known, the assignment of one of the defined model units to
represent each TSDF waste management unit is not possible. Therefore, a
weighted average model unit control cost—in essence, "national average
model unit" control cost—was derived for each control applied to each TSDF
waste management unit. These control costs, divided by the model unit
throughput, provide cost factors that are used to generate control cost
estimates for each TSDF facility. The discussions of weighted average
model unit control costs and control costs as a function of throughput are
given in Sections 7.1.2.2 and 7.1.2.1, respectively.
7.1.1 Methodology for Model Units
To estimate the nationwide cost impacts of implementing the five
control options presented in Chapter 5.0, the estimated total capital
investment and total annual costs were developed for each of the various
control technologies applied in the control options. (A general discussion
of these control technologies is contained in Chapter 4.0.) The control
options describe the control technology for each source category in general
terms, such as cover and vent to control device. • The specific control
technologies assumed to be applied to each source category for each option
are defined in Chapter 5.0, Section 5.4.
A standardized cost estimating approach was developed for add-on and
suppression-type control devices based on an EPA cost manual 1 and a series
of articles by Vatavuk and Neveril.2'7 These sources identified the total
capital investment, annual operating costs (costs of operating control
7-2
-------
technologies minus capital recovery and energy credits), and the total
annual costs (i.e., annualized costs) as the key elements of a cost
estimate.
For each control technology applied in a control option, a detailed
cost estimate was developed. The detailed cost estimate consisted of three
standard cost tables. The first of the three cost tables lists the major
equipment items associated with the control technology. The second table
lists any auxiliary equipment required, instrumentation, sales tax and
freight, plus direct and indirect installation charges. These first two
tables are used to calculate total capital investment. The third table
lists the direct operating costs, indirect operating costs, and energy
credits used to calculate total annual costs. Examples of these three
tables are presented in Appendix H.
The purchase cost, material of construction, and size of each major
equipment item were obtained from vendor data, engineering handbooks, the
literature, and currently operating commercial facilities. (Such sources
are referenced in Appendix H.) The sum of the costs for the major equip-
ment items is equal to the base equipment cost (BEC).
Using the base equipment cost, the purchased equipment cost (PEC) for
the control technology is computed. Direct and indirect installation
charges for each control technology are factored directly from the
purchased equipment cost. For this analysis, the direct and indirect
installation factors are based on information obtained from vendors, other
cost estimates, data summarized in References 2 through 7, and engineering
judgment based on typical TSDF wastes and operating practices. The costs
for site preparation and buildings were based on vendor information and
construction cost reference sources.8 The sum of the purchased equipment
cost, direct installation charges, and indirect installation charges are
equal to the total capital investment (TCI).
The sum of direct and indirect operating expenses less capital recov-
ery and energy credits is equal to the annual operating costs. The total
annual cost is equal to the direct plus indirect operating costs less any
energy credits.
7-3
-------
To illustrate this cost approach for add-on control devices,
Appendix H gives detailed cost analyses for control technologies used in
the control option definitions in Chapter 5.0. Appendix H provides the
rationale for the design, costing, and material and energy balances for
TSDF control options. In addition, Appendix H provides sample calculations
and other details of how each control was costed.
7.1.2 Derivation of Unit Costs to Estimate Nationwide Costs of
Control Options
The estimation of nationwide costs of the control options makes use of
a TSDF Industry Profile data base (assembled to aid in this effort and
described in Appendix D) and the emission control costs for individual
source category/emission control combinations whose development is dis-
cussed in Appendix H. The Industry Profile gives the waste throughput data
used to assign throughputs to each TSDF waste management unit in each
facility in the Nation. To facilitate the use of these two information
sources, the total capital investment and annual operating cost for each of
the model unit cost estimates were divided by the throughput of the model
waste management unit (emission source) to obtain a cost (both total
capital investment and annual operating cost) per unit of waste throughput.
The following paragraphs discuss the development of the unit cost factors.
7.1.2.1 Costs as a Function of Throughput (Unit Cost Factors). As
part of the effort to characterize the variety of TSDF operating practices,
model TSDF waste management units were defined. The main purposes of the
model units are to evaluate uncontrolled emissions from waste management
processes, assess the reduction in air emissions when emission controls are
applied, and estimate the costs of applying controls. Model units were
defined for TSDF storage, transfer and handling, treatment, and disposal
operations. The model units cover a range of waste management unit sizes
(e.g., throughput, surface area, and tank volumes) and other characteris-
tics that may impact air emissions. The entire set of model units is
presented in Appendix C of this document. The approach to developing con-
trol costs discussed in Section 7.1.1 was applied to each of the model
units listed in Appendix C for each of the individual unit emission con-
trols.
7-4
-------
The next step toward generating the control costs on a nationwide
basis was to convert the costs of controls for the model units to a cost
per unit of waste throughput; i.e., the costs of controlling emissions from
each model unit were divided by the annual waste throughput of the model
waste management unit to which the control was applied. These factors
(referred to as unit cost factors), when multiplied by the waste throughput
for a particular waste management unit, yield an estimate of the cost of
air emission controls for that unit.
7.1.2.2 Development of Weighted Cost Factors. Data contained in the
TSDF Industry Profile (described in Appendix D) are used to estimate annual
waste throughput for each type of waste management unit at each TSDF. The
Industry Profile, however, does not yield the exact size of each management
unit, e.g., 758 m3 of tank storage could be ten 75.8-m3 tanks in one case,
or one 758-m3 tank in another case. Because there are economies of scale
associated with emission control costs, the total control costs might be
substantially different for these cases. To compensate for the lack of
facility-specific unit size information, weighted unit cost factors were
developed that account for the national size distribution of TSDF waste
management units. Statistics on the national distribution of waste
management unit sizes were used to weight the emission control costs for
each model unit size defined in Appendix C (see Appendix H). This approach
yields an approximation of the effects of economies of scale for the
nationwide cost estimates.
Table 7-1 lists the unit cost factors used to estimate nationwide
total capital investment and annual operating costs for each of the emis-
sion controls specified in the control options.
7.2 SUMMARY OF NATIONWIDE CONTROL COSTS FOR CONTROL OPTIONS
This section presents tabular summaries of the estimated nationwide
total capital investment and total annual costs (annualized capital cost
plus annual operating costs) for the five control options described in
Chapter 5.0. Separate cost estimates are given for each TSDF source
category.
The nationwide cost estimates were obtained by multiplying the quan-
tity of wastes managed in each TSDF waste management unit (obtained from
7-5
-------
TABLE 7-1. ESTIMATED TOTAL CAPITAL INVESTMENT AND TOTAL ANNUAL COST PER
UNIT OF WASTE THROUGHPUT BY SOURCE CATEGORY FOR
FIVE CONTROL OPTIONS9
Source category
Total
capital investment,
$/Mg throughput
Total
annual cost,
$/Mg throughput13
Drum storage0
Dumpster storage
Storage tanks
Quiescent surface impoundments
Quiescent treatment tanks
Aerated/agitated tanks and
impoundments
Wastepilesc
Landfills0
Waste fixation process units
Incineration0
Land treatment0
Spills0
Loading
Equipment leaks0
6.3-26
9.7-28
1.9-2.6
0.22-1.2
0.41-2.9
12.3
2.1-9.9
4.9-15.0
0.87-4.8
0.14-0.58
0.26-1.7
5.1
0.49-0.94
0.09-0.18
aTotal capital investment includes all costs to purchase equipment, direct
installation charges, and indirect installation charges. Total annual cost
is the sum of the annual operating cost and the annual ized capital costs.
All costs are in January 1986 dollars.
unit costs were obtained from information presented in Appendix H.
Where a cost range is given, the range represents cost variations due to
differences in waste composition. Model waste compositions for which costs-
were derived are presented in Appendix C.
°These sources are not being controlled by the control options presented in
this chapter. For further information, see Chapter 5.0.
7-6
-------
the TSDF Industry Profile) by the unit cost factors listed in Table 7-1.
The estimated costs for each TSDF were summed to produce national totals.
Table 7-2 lists the estimated nationwide total capital investment and the
estimated nationwide total annual cost, respectively, for each of the
control options.
The estimated total capital investment for control options 1 through 5
ranges from a low value of $520 million for option 5 to a high value of
$2.1 billion for option 1. The estimated total annual costs (i.e.,
annualized costs) for control options 1 through 5 range from a low value of
$210 million for option 5 to a high value of $930 million for option 1.
The nationwide cost information presented in this chapter provides two
means of comparing control options: capital and annual costs. Other means
of comparing options are discussed in Chapter 5.0. Section 5.5 describes a
methodology for ranking control options according to the relative health
and environmental benefits achieved by the options.
7.3 COST EFFECTIVENESS OF CONTROL OPTIONS
Table 7-3 shows the cost effectiveness of the five control options.
The cost effectiveness of a control option is defined as the total annual
cost of applying controls to all emission sources covered by the option
divided by the total emission reduction that would be achieved. Total
annual cost is the annual operating cost plus the annual cost of capital
required to purchase and install the controls. As shown, the cost effec-
tiveness of options 1 through 5 varies from $130/Mg to $540/Mg of, organic
emission reduction.
Only a single aggregate cost effectiveness is presented for each TSDF
control option. The cost effectiveness of controlling specific emission
source categories covered by an option (e.g., the cost effectiveness of
controlling storage tanks) is not presented. This is because emissions
from TSDF sources are interrelated in many strategies and, consequently, it
is potentially misleading to estimate the cost effectiveness on an emission
source category basis.
For example, covering only the first of several TSDF waste management
units (emission sources) in series will reduce organic emissions from the
unit that is covered but may increase the emissions from the uncovered
7-7
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7-8
-------
TABLE 7-3. NATIONWIDE TSDF COST EFFECTIVENESS OF FIVE CONTROL OPTIONS
Control option13
Cost effectiveness,
$/Mg emission reduction
1
2
3
4
5
540
420
220
170
130
aThis table presents total annual costs of control divided by organic
emission reductions, i.e., cost effectiveness.
^Control options 1 through 5 are based predominantly on the use of add-on
emission controls. The control options are described in Chapter 5.0.
7-9
-------
units downstream, resulting in no change in total facility emissions. The
cost effectiveness of controlling the first unit may look attractive in
isolation, but, as a practical concern, reduction in total facility emis-
sions would not be achieved unless units downstream were controlled as
well.
7.4 REFERENCES
1.
2.
3.
4.
5.
6.
7.
8.
U.S. Environmental Protection Agency. EAB Control Cost Manual (Third
Edition), Section 2: Manual Estimating Methodology. Publication No.
EPA-450/5-87-001A. Office of Air Quality Planning and Standards,
Economic Analysis Branch. February 1987.
Vatavuk, W. M., and R. B. Neveril. Chemical Engineering. 165-168.
October 6, 1980.
Vatavuk, W. M., and R. B. Neveril
November 3, 1980.
Vatavuk, W. M., and R. B. Neveril
December 29, 1980.
Vatavuk, W. M., and R. B. Neveril,
May 18, 1981.
Vatavuk, W. M., and R. B. Neveril,
January 24, 1983.
Vatavuk, W. M., and R. B. Neveril,
April 2, 1984.
Chemical Engineering. 157-162.
Chemical Engineering. 71-73.
Chemical Engineering. 171-177.
Chemical Engineering. 131-132.
Chemical Engineering. 97-99.
Mahoney, W. D. (ed.). Means Construction Cost Data. Kingston, MA,
R. S. Means Co., Inc. 1986.
_
7-10
-------
8.0 ECONOMIC IMPACTS
Chapter 5.0 describes five control options for organic air emissions
from treatment, storage, and disposal facilities (TSDF). This chapter
estimates the economic impacts of control options 1 through 5. For
analytical purposes, it is useful to divide the affected facilities into
those that only have hazardous waste storage facilities and those that also
perform treatment or disposal services.
All control options examined are projected to have small impacts—less
than 1 percent—on the unit cost of hazardous waste management services at
facilities that treat and dispose of these wastes. These unit-cost
increases will slightly raise the costs and prices of goods and services
produced by the generating sectors. This will encourage a small amount of
waste minimization. The capital costs will vary between $500 million and
$2 billion for these facilities; annual compliance costs will vary between
$200 million and $900 million. Small decreases are projected in the number
of jobs at TSDF, so small that employment dislocations will probably be few
if any. Similarly, while the projected reductions in waste generation
could, in the aggregate, imply facility closures, it appears much more
likely that the reductions will be distributed across all facilities and
that the number of closures, if any, will be nominal.
The unit-cost increases for storage-only facilities are substantial
for several sectors and options when viewed as a share of hazardous waste
management costs. These cost increases translate into compliance costs of
between $4 million and $31 million. However, storage facility closures
again appear unlikely, even though there may be some economic pressures in
that direction, because closing a permitted facility requires the firm to
undertake a time-consuming and expensive process. This process is designed
to ensure that liability rules are met and that the environment is pro-
tected from hazardous wastes.
8-1
-------
8.1 INDUSTRY PROFILE
Before beginning the economic analysis, it is necessary to define the
affected industry. The following sections discuss the activities of haz-
ardous waste managers and describe the markets where they are active. The
demanders and suppliers of these services are described, along with the
factors underlying their production and consumption decisions. The size of
firms operating the hazardous waste management facilities, along with other
characteristics relevant to the economic analysis model, are also pre-
sented.
The demand for hazardous waste management services is a function of
the production process. In the course of producing final goods or ser-
vices, firms often produce hazardous waste. Because these production
outputs are technically interdependent, they are referred to as "joint
products."
The firms that produce hazardous wastes as joint products with their
product or service represent more than 100 different Standard Industry
Classification (SIC) codes. The hazardous wastes they produce represent
more than 400 Resource Conservation and Recovery Act (RCRA) waste codes.
Hazardous wastes include characteristic wastes, wastes from both specific
and nonspecific sources, chemical products and intermediates, and discarded
chemical products and residues.
Because these wastes are classified as hazardous under RCRA, they must
be treated, stored, or disposed by a permitted TSDF. A generator can
treat, store, or dispose, hazardous wastes on site if it has a permit, or
hire a commercial TSDF to manage its hazardous wastes. To reduce the
demand for hazardous waste management services, generators may reduce the
level of waste generated. Generators may reduce output levels of the
primary product or substitute other inputs in the' production process to
reduce waste and, hence, the need for waste management services.
The following industries generate wastes in their production processes
and, therefore, produce not only their marketable commodity but also haz-
ardous wastes:
• Mining
• Milling
8-2
-------
• Manufacturing of chemicals and Pharmaceuticals
• Manufacturing of primary and fabricated metals
• Manufacturing of cement
• Manufacturing of electrical and nonelectrical machinery
• Manufacturing of transportation equipment and instruments
• Electric and gas utilities
• Wholesale and retail sales
• Research labs, hospitals, university research centers
• Remainder of the economy, including government facilities.
On the supply side of the market for hazardous waste management
services are many of the same firms that generate the hazardous waste and,
therefore, appear on the demand side of the market. These firms provide
"captive" onsite hazardous waste management services. In addition to these
captive firms, a group of commercial firms specializes in managing hazard-
ous materials. Section 8.1.1 describes the suppliers of hazardous waste
management services in more detail.
8.1.1 The Supply Side
Hazardous waste management processes fall into three major categories:
(1) treatment, (2) storage, and (3) disposal. Within each of these cate-
gories are further subcategories totaling 12 waste management processes.
TSDF can be classified into four broad categories: (1) captive storage-
only facilities; (2) commercial storage-only facilities; (3) captive TSDF;
and (4) commercial TSDF. Storage-only facilities (captive or commercial)
store the wastes using containers and/or tanks prior to treatment and
disposal; TSDF (captive or commercial) include all facilities other than
storage-only facilities (captive and commercial).
8.1.1.1 Hazardous Waste Management Processes. Hazardous Waste
management services include storage, treatment, and disposal of wastes
described in Table 3-1 and Table 3-2, Chapter 3.0. Twelve processes are
identified.
The key storage processes include containers, tanks, wastepiles, and
surface impoundments. The key treatment processes include tank treatment,
8-3
-------
surface impoundment treatment, incineration, and other treatment. The key
disposal processes include injection wells, landfills, land application,
and surface impoundments.
8.1.1.2 Costs of Hazardous Waste Management Processes. The costs of
a hazardous waste management process include all annual costs (e.g., raw
materials, utilities, labor, maintenance, and overhead) required to operate
a plant. Typical plant sizes and typical operating practices were identi-
fied for each of the 12 management processes to develop generalized cost
equations. The annualized average costs of hazardous waste management
processes ($/Mg of waste managed) were estimated for each of the 12 waste
management processes.
The operating costs of waste management processes were obtained from
several sources, including studies by Booz-Allen and Hamilton; Research
Triangle Institute; Industrial Economics, Inc.; Temple, Barker, and Sloane;
and the National Council of the Paper Industry on Air and Stream Improve-
ment. As with some of the other data, process costs reflect recent but not
necessarily current values. For each of the 12 processes, model costs were
developed for different plant sizes using available information on model
and actual process expenditures. In this manner, cost estimates were
determined for the different waste management processes.
The per-metric ton processing costs for the 12 different waste
management processes were compared with values found in other sources to
verify their reasonableness. The results of this comparison are presented
in Table 8-1. As can be seen from the blank entries in the table, not
every source gives costs estimates for each process technology. It is also
evident from the tables that, in most cases, the RTI cost estimates are
comparable to those of the other sources.
Finally, the cost functions were developed using unit costs developed
for the 12 different waste management processes and several plant sizes.
The estimated parameters of the cost functions are summarized in Table 8-2.
These cost functions were used to compute costs for waste management opera-
tions in TSDF from which price adjustments resulting from the control
options were estimated.
8.1.1.3 Identifying Directly Affected Facilities. From the Industry
Profile discussed in Appendix D, 2,336 facilities were identified that
8-4
-------
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8-5
-------
TABLE 8-2. PARAMETERS OF THE UNIT COST FUNCTION3
Waste
management practice
baseline
Intercept
Slope
Treatment options
Tank treatment
Other treatment
Incinerator-
Treatment impoundment
Storage options
Container storage
Tank storage
Wastepiles
Storage impoundment
Disposal options
Land treatment
Landfill RCRA
Injection well
Disposal impoundment
8.60
8.60
8.78
8.70
7.09
8.70
7.58
7.09
0
9.43
10.4
8.70
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0.60
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0.44
0.56
0.26
0.44
6.98
0.50
0.66
0.56
aThe unit cost function depends on the amount of waste processed and
the type of waste management processes used. The function was esti-
mated using the available data described in Table 8-1. The function •
was assumed a log-linear function, defined by: C(Q) = a - b ln(Q),
where a and b are the estimated intercept and slope values, Q is the
amount of waste processed, and 'In' represents natural logarithm. The
unit costs are truncated by the upper and lower bounds represented in
the last column of Table 8-1. The estimation of the parameters of the
cost functions are described in Reference 7.
8-6
-------
performed some form of hazardous management service in 1985. Out of 2,336
facilities, 2,002 are estimated to produce organic emissions. Of these
facilities, 1,098 facilities were storage-only facilities; the remaining
904 facilities provided all forms of hazardous waste management services.
Nearly 70 of the 904 facilities were either government facilities or
facilities listed under service industries. The economic analysis includes
only the remaining 834 directly affected facilities. The excluded storage-
only facilities (1,098) and government facilities (70) represented less
than 5 percent of the total waste volume serviced by all the 2,002
facilities. In addition, the compliance costs of the excluded facilities
comprised less than 1 percent of the total compliance costs in all options.
The summary statistics by directly affected facilities, storage-only
facilities, and government facilities are presented in Appendix I.
These directly affected facilities (834) were found in more than 100
different industries, as described by their 4-digit SIC code. To facili-
tate the economic analysis, the TSDF were grouped into 20 generating sec-
tors and 1 commercial treatment sector. The 834 facilities were assigned
to one of the 21 market sectors, based on their primary product or service
as indicated by their SIC codes. In 20 of the 21 sectors, firms generated
as well as treated, stored, or disposed of hazardous wastes. In the 21st
sector, the commercial sector, facilities only supplied hazardous waste
management services to firms in the other sectors. Table 8-3 lists the 20
generating sectors and the 1 commercial sector, along with the number of
facilities in each sector and the volume managed by each sector.
The supply elasticities of hazardous waste management services, which
measure the responsiveness of-an industry's quantity supplied of hazardous
waste management services to changes in the price of these services, are
shown in Table 8-4. To compute these elasticities, unit cost estimates
were first developed for each of the 12 processes using engineering rela-
tionships and costs. These cost functions are only valid for the range of
output for which data are available; at very low outputs and very high
outputs they give unreliable results. Therefore, the cost function was
truncated using judgment and information about the costs of actual hazard-
ous waste management firms. The cost curve is shaped like a backward L.
8-7
-------
TABLE 8-3. VOLUME OF WASTE MANAGED BY SECTOR, 1986a
Sector
Number of
facilities
Volume managed,
103 Mg/yr
Mining 12
Grain and textile mill products 4
Furniture, paper products, printing 35
Industrial chemicals, inorganic and organic 139
Plastics, fibers 39
Biological, pharmaceutical, medical chemicals 20
Assorted chemical products 54
Paint and allied products, petroleum and coal 99
Rubber, plastics 7
Cement companies 11
Primary metals 70
Metal fabrication 67
Nonelectrical machinery 15
Electrical machinery and supplies 45
Transportation equipment 29
Instruments 8
Miscellaneous manufacturing 5
Electric and gas utilities 24
Nondurable goods: wholesale sales 4
Research labs, hospitals, universities 11
Commercial hazardous waste handlers 136
Totals 834
92.8
130.0
38.3
99,600.0
53,900.0
2,820.0
20,800.0
6,740.0
5.4
36.0
1,960.0
1,070.0
42.3
514.0
764.0
29.8
260.0
340.0
60.6
0.2
5,720.0
195,000.0
aThis table groups each of the 834 facilities included for the economic
analysis into one of the 21 market sectors (20 generating sectors and 1
commercial sector). Facilities included in the generating sectors gen-
erate and manage (treat and/or store and/or dispose) hazardous wastes.
Facilities included in the commercial sector only supply hazardous waste
management services to the generating facilities. Data are taken from
the Source Assessment Model (SAM) Industry Profile data base, Appendix D,
Section D.2.1.
8-8
-------
TABLE 8-4. SUPPLY ELASTICITIES FOR HAZARDOUS WASTE MANAGEMENT
SERVICES BY SECTOR3
Sector
Supply elasticity
Mining
Grain and textile mill products
Furniture, paper products, printing
Industrial chemicals, inorganic and organic
Plastics, fibers
Biological, pharmaceutical, medical chemicals
Assorted chemical products
Paint and allied products, petroleum and coal
Rubber, plastics
Cement companies
Primary metals
Metal fabrication
Nonelectrical machinery
Electrical machinery and supplies
Transportation equipment
Instruments
Miscellaneous manufacturing
Electric and gas utilities
Nondurable goods: wholesale sales
Research labs, hospitals, universities
Commercial hazardous waste handlers
0.55
1.82
0.47
0.10
0.03
0.03
0.38
0.16
0.05
0.46
0.13
0.08
0.15
0.54
0.07
1.26
0.00
0.17
0.01
0.66
.0.29
aThe supply elasticities of hazardous waste management services in this
table measure the responsiveness of a sector's quantity of hazardous waste
management services to changes in the price of these services. Step
supply functions for each of the 21 sectors reported in the table were
constructed using the waste management cost functions reported in
A Profile of the Market for Hazardous Haste Management Services, a
1986 draft report prepared by Research Triangle Institute for the
U.S. Environmental Protection Agency, Office of Air Quality Planning
and Standards, Research Triangle Park, NC. A log-linear regression was
performed to estimate the elasticities. Data are taken from the Source
Assessment Model (SAM) Industry Profile data base, Appendix D,
Section D.2.1.
8-9
-------
Up to the capacity volume of throughput, the marginal cost curve is hori-
zontal (perfectly elastic); beyond that volume, vertical (perfectly
inelastic).
Each facility's marginal cost (= average cost) of hazardous waste
management service was calculated based on the volume of hazardous waste
management service. Then, ranking facilities from the lowest unit cost to
highest, the volumes of hazardous waste management services were accumu-
lated across all the firms in the sector. This process results in a
"stepped" supply function for each industry sector. After constructing
these stepped supply functions for each sector, a log-linear regression was
performed to find a constant elasticity of supply for each industry as
reported in Table 8-4.
8.1.2 The Demand Side
As mentioned earlier, the demand for hazardous waste management
services arises because, in the course of producing their final goods or
services, firms may also generate hazardous wastes. The majority of the
facilities generating hazardous wastes as a result of their production
;
process are chemical manufacturers. In all, however, firms in more than
100 4-digit SIC codes demand hazardous waste management services.
Many facilities choose to recycle or incinerate their own hazardous
waste on site, for a variety of reasons. Not all of these reasons are
directly related to management costs. Under RCRA, generators retain some
liability for the waste they generate after it leaves their facility.
This undoubtedly induces some firms to reduce their risk by keeping the
hazardous waste on site.
However, not all of the facilities generating hazardous wastes choose
to manage them entirely on site. Rather, some use the services of commer-
cial waste management firms. It is assumed in this analysis that all the
demand for hazardous waste management services originates in the first 20
generating sectors listed in Table 8-3. Some of the demand is met by the
generators themselves, while other firms in these same generating sectors
use the services of commercial waste management facilities. The firms in
the generating sectors that have RCRA permits are assumed here to manage
all their own hazardous wastes on site. All other firms within these
8-10
-------
sectors are assumed to ship hazardous wastes off site to commercial waste
management facilities.
To estimate total consumption of hazardous waste management services
in each generating sector, it is necessary to sum the consumption that is
met by onsite management with the sector's estimated share of commercially
supplied management services. No information is available about commercial
consumption arising in each of the generating sectors. It is assumed that
all the demand for these services arises from the same 20 sectors that
perform onsite captive management. The total commercially supplied hazard-
ous waste management services are allocated across the 20 sectors based on
the ratio of each sector's transported waste quantities to the total quan-
tity transported by the 20 sectors. Table 8-5 shows the 20 demanding
sectors, along with the total volume that each sector services commercially
or on site, and the grand total of hazardous waste management demand origi-
nating in each generating sector.
To simplify the economic analysis, it is assumed that each firm uses
only two inputs to produce its output: hazardous waste management services
and one other composite input. Table 8-6 shows the estimated share of each
industry's total production cost attributable to hazardous waste management
services.
A measure of the price elasticity of demand for the products of each
generating sector is needed for the economic analysis. Price elasticity of
demand measures the percentage change in quantity demanded in response to a
percentage change in product price. The elasticity of demand for interme-
diate products such as those produced by all the firms in the data base
depends on several factors related to the final product. First, because an
intermediate product is used to produce a final product, the demand for the
intermediate product depends on the demand for the final product in which
it is used. Thus, the demand for a chemical depends on the demand, for
example, for the paint, pharmaceutical product, or plastic product it is
used to produce. The degree of variation in quantity demanded of the
intermediate product in response to a change in its price thus depends, in
part, on the responsiveness of the final product's quantity demanded to
changes in its price. It also depends on the cost share of the final
8-11
-------
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8-12
-------
TABLE 8-6. COST SHARES AND DEMAND ELASTICITIES BY SECTOR9
Sector
Mining
Grain and textile mill products
Furniture, paper products, printing
Industrial chemicals, inorganic and organic
Plastics, fibers -
Biological, pharmaceutical, medical chemicals
Assorted chemical products
Paint and allied products, petroleum and coal
Rubber, plastics
Cement companies
Primary metals
Metal fabrication
Nonelectrical machinery
Electrical machinery and supplies
Transportation equipment
Instruments
Miscellaneous manufacturing
Electric and gas utilities
Nondurable goods: wholesale sales
Research labs, hospitals, universities
Commercial hazardous waste handlers
Cost share of
HWM services,
x 10-3
0.5
1.4
0.4
84.6
180.0
14.1
43.1
1.6
*
1.5
1.9
1.8
0.1
1.1
1.1
0.2
2.6
0.1
0.4
*
NA
Demand
elasticity
-0.70
-0.70
-0.70
-0.67
-0.16
-0.89
-0.87
-0.23
-0.13
-0.70
-0.70
-0.70
-0.19
-1.05
-0.83
-0.70
-0.96
-1.90
-0.70
-2.92
-2.41
* = Less than 0.05.
HWM = Hazardous waste management.
NA = Not applicable.
aThe cost-shares and price elasticities reported in this table are the key
parameters of the analytical model used to estimate the economic impacts
of the air emission regulations. The cost-share of the hazardous waste
management services of each of the generating sectors represents the
ratio of the costs of hazardous waste management services to the value
of shipments. The price elasticities of demand in the table are obtained
from the Iiterature.8f9 Qata On the value of shipments are taken from
the Census of Service Industries, Washington, D.C., U.S. Department of
Commerce, Bureau of the Census, 1982.
8-13
-------
product this intermediate product represents. The elasticities of demand
used in the model are found in the literature.10!11 They are less than
zero because an increase in the price of the commodity results, other
things being equal, in a decrease in the quantity demanded of the commod-
ity. For those sectors whose elasticity of demand is not available in the
literature, -0.7 is assumed. This figure is consistent with the range of
elasticities found in the literature for other sectors. These price elas-
ticities of demand for hazardous waste management services are shown in
Table 8-6.
8.1.3 Market Outcomes
The market forces represented above in the supply of and demand for
hazardous waste management services result in a market solution for the
quantity of each type of hazardous waste management service undertaken in
each sector and the price of each type of management service. The baseline
situation in these markets is the quantities for 1986 as shown in Table
8-5. In a competitive market, the market price for hazardous waste manage-
ment services would equal the marginal cost of the highest cost supplier.
Of course, most TSDF do not offer the service on the open market. Only the
hazardous waste management services performed by the commercial sector
actually pass through the market. The commercial TSDF were ordered by
their marginal cost and the marginal cost of the highest-cost facility was
selected as the market price. The price selected, $l,280/Mg, furnishes a
baseline price against which the compliance costs of hazardous waste man-
agement resulting from the options may be compared.
8.2 ANALYTICAL APPROACH
This study estimates the economic impact of regulatory options on air
emissions from hazardous waste TSDF, with special attention to the possible
facility closure effects. The primary emphasis of the economic analysis is
a multimarket partial equilibrium model of the hazardous waste management
industry.
For the economic analysis, the 834 directly affected facilities in the
20 generator sectors and 1 commercial hazardous waste management sector
were analyzed. The 1,098 storage-only facilities were excluded from
detailed economic analysis because they represent less than 4 percent of
8-14
-------
the total compliance cost of all TSDF and less than 3 percent of the quan-
tity of hazardous waste managed by all the TSDF. The costs of compliance
for storage-only facilities are estimated and presented in Appendix I,
Section 1.2.
For each TSDF in the data base, the costs of implementing the emission
controls were estimated. These costs are expressed as changes in capital
and operating expenses incurred by the plants as a result of complying with
the control options. Using this compliance cost information, the economic
effects of the air emissions regulation on TSDF were then projected. The
following impacts were projected:
• Price and quantity changes in affected markets
• Annual regulatory costs
• Employment effects
• Facility closures (if any)
• Small business effects.
The economic theory and operational model underlying this analysis are
discussed in this section.
8.2.1 Model Overview
To estimate the impacts of the regulatory options, a comparative
statics model, based in traditional microeconomic theory, was used. The
term "comparative statics" means that a snapshot is presented of all of the
affected markets in their baseline condition. It is then compared to
another snapshot of the same markets after all of the adjustments have
taken place in response to the controls. The market for the services of
TSDF was assumed to be competitive. TSDF were assumed to operate in a
profit-maximizing manner, and to have complete knowledge of all the markets
in which they participated.
Decisions made by TSDF can be broken down into two broad categories:
• Existing plant and equipment operating decisions, frequently
referred to as short-run decisions
• Investment decisions for new plants and equipment, fre-
quently referred to as long-run decisions.
8-15
-------
Short-run or operating decisions concern the quantity of a good or
services the firm produces to achieve the greatest profit, or the smallest
loss. In general, a firm will continue to produce as long as the price
received for its good or services is sufficient to cover the average vari-
able, or operating, cost of producing it. As long as price exceeds average
variable cost, the firm is covering the costs of all of its variable inputs
and some of its capital costs as well.
Long-run or investment decisions require different reasoning. Because
the investment in plant or equipment has not been made, that cost too is
variable. For the firm to decide to invest in a new machine or plant, it
must expect that the price it will receive for the goods or services pro-
duced by that machine or plant will be sufficiently high to cover all of
the costs associated with producing it, including both the cost of purchas-
ing the plant or equipment and a normal rate of return on the plant or
equipment. In other words, the market price of the good or services must
at least equal the plant's average total cost. The plant is not yet in
place, so all inputs, and hence the scale of the plant, are variable.
At any given time, the firm's supply curve is its marginal cost curve
above its average variable cost curve, and the market supply curve is the
sum of the existing firms' supply curves (see Figure 8-1). The willingness
of different plants—with different average variable costs of production--
to produce at different market prices results in the familiar upward slope
of the market supply curve. Firm 1 has the lowest operating costs, firm 4
the highest in Figure 8-1. The market price is determined by the intersec-
tion of the market demand and market supply curves. The marginal plant is
that plant whose average operating costs just equal market price. If
market price were to decrease, the marginal plant would close.
A regulation limiting air emissions from TSDF will increase both the
capital and operating costs of these facilities. It is likely that the
increase in costs will be greater per unit produced for existing plants,
which must be retrofitted in order to comply with the regulation, than for
new plants, which can design their equipment to comply. In addition, capi-
tal costs may be higher for small firms than for larger firms making the
same change in equipment. This may be true because the interest rate
8-16
-------
Price/Quantity
($)
MC4
AVC4
Note: In this market, firm 4, whose average operating costs exactly equal market price,
is the marginal firm.
MC = Long-run marginal cost curve (for firms 1 through 4)
AVC = Average variable cost curve
P* = Market price
Q* = Quantity produced (output) at price P*
D = Market demand curve
Figure 8-1. A market supply curve constructed by
summing four firms' supply curves.
8-17
-------
charged these smaller companies is higher than that charged larger com-
panies. For example, while larger companies may be able to issue bonds
(and have higher bond ratings and, hence lower financing costs than smaller
companies), smaller companies-more frequently must borrow funds from a
bank. In fact, if their credit rating is sufficiently low, the smaller
company may not be able to obtain a loan for pollution abatement equipment
at any acceptable rate of interest. Finally, economies of scale in compli-
ance are usually found, so small facilities may have higher unit compliance
costs than large facilities.
The initial impact of the regulation will be in the directly affected
market—the market for hazardous waste management services. The increased
costs resulting from complying with the new air emission standard will
cause each firm's supply curve, and therefore the market supply curve, of
hazardous waste management services to shift upward. With a smaller
supply, a higher market price is then required to justify producing any
given level of output. The new equilibrium price will be higher and the
new equilibrium quantity of services produced less than would have been the
case in the absence of the regulation, all else being equal. Because the
cost of onsite hazardous waste management services is higher than in the
absence of the regulation, generators may reconsider their decision about
whether to manage waste on site or off site. .If the cost of their onsite
management increases sufficiently, offsite hazardous waste management
services may become more economical. They may also decide to alter their
production process to reduce the quantity of hazardous waste management
services they require.
In the market for the firms' primary products, the supply curve will
also shift upward. This is because hazardous waste management is an input
to their production process, and its cost has now risen. It will now cost
more to produce a given output than without the regulation, resulting in
higher prices and lower output rates. Figure 8-2 shows these changes.
8.2.2 Model Design
To assess the impact of the control options, a model of 82 simultane-
ous equations, designed to capture the major market interactions of firms
in the affected industries identified earlier, was constructed. This model
8-18
-------
Price/Quantity
($)
Q2 Q,
Quantity/Time
• Preregulation price
• Postregulation price
• Preregulation quantity (output)
= Postregulation quantity (output)
• Preregulation supply
= Postregulation supply
» Market demand
- Demand elasticity (percent change in demand
quantity for 1 percent change in price)
6 = Supply elasticity (percent change in supply
quantity for 1 percent change in price)
Figure 8-2. Hypothetical price and output adjustments due to a market supply
shift induced by air emission regulations.
U1
Q2
D
1}
8-19
-------
is only for hazardous waste management facilities that, in addition to
providing storage, treat or dispose of hazardous wastes. Storage-only
facilities are addressed separately in Appendix I, Section 1.2, by simply
summing compliance costs.
When such a regulation is promulgated, its effects are felt throughout
the economy. The major impact, however, will be felt in the active markets
of firms directly affected by the regulation. Other markets both upstream
and downstream from the directly affected markets will experience smaller
impacts. It is beyond the scope of this analysis to detail every activity
of every industry in these markets; rather, the most important trends and
characteristics of each directly affected market are incorporated. The
model is based on research by Muth,12 Miedema,13 and Gardner.14 Specific-
ally, it includes equations describing the industries' output markets and
input markets for hazardous waste management services. Firms in these
markets will bear the major impact of the regulation.
The model of TSDF is a comparative statics model. It portrays the
impact of the control options on the markets most directly affected,
assuming that all other conditions in the markets remain unchanged. For
example, the prices of inputs other than hazardous waste management ser-
vices are assumed constant, as is technology. The only thing that changes
initially is the cost of hazardous waste management services, which
increases as a result of the proposed regulation. It is assumed that all
of the affected markets simultaneously arrive at new equilibrium positions.
The firms performing hazardous waste management services find that, as
a result of the control options, their cost of doing business increases.
This, in turn, may affect the price of hazardous waste management services,
the quantities of hazardous waste management services performed on site and
commercially, the quantity of other inputs used on site and commercially,
and the quantity and price of final products produced.
The partial equilibrium multimarket model uses minimal data about the
markets to project these market adjustments. The model uses percentage
changes in production costs as a result of the regulation to generate the
percentage changes in the following market variables:
• Price and quantity of goods produced in each generating
sector
_
8-20
-------
• Quantity of hazardous waste management services produced and
consumed, on and off site, for each sector
• Price and quantity of commercial hazardous waste management
services supplied.
These results are used to calculate economic impacts that result from
the regulation. A detailed description of the model is presented in
Appendix I, Section 1.3. '
To describe the relationships between the sectors in the affected
markets, a set of parameters—including the demand elasticities in the
final products markets, the supply elasticities in the hazardous waste
management markets, and the share of total production costs represented by
hazardous wastes—is used as presented in Section 8.1.
In addition to the parameters already developed, several other
parameters—dealing largely with each sector's share of the hazardous
wastes industries—are required to run the analytical model. These "share"
parameters are shown in Table 8-7. The values shown in column 2 of Table
8-7 are each generating sector's share of commercial hazardous wastes.
Similarly, columns 3 and 4 of Table 8-7 represent the other two parameters
(the proportion of each sector's total demand for hazardous waste manage-
ment services supplied onsite and commercially). The cost shift for the
marginal facility is the shift parameter. Five shift parameters are used,
one for each control option. These shift parameters, XI, X2 , X3, X4, and
X5, are shown in Table 8-8.
Another set of parameters describes the relationship between inputs in
the production processes of each sector. These parameters are the elas-
ticities of substitution between the various inputs used by the producers.
It is assumed that the production of the goods produced by the generating
sectors involves the use of two inputs. These inputs are (1) hazardous
waste management services, and (2) a composite input. The elasticity of
substitution between these inputs measures the ease with which the producer
can substitute between them in his production process. It is difficult,
a priori, to tell how much substitution is possible between hazardous waste
management services and all other inputs—"waste minimization." It is
assumed that some substitution is possible between hazardous waste
8-21
-------
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8-23
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management services and all other inputs; specifically, all the
elasticities of substitution are set equal to 1.
In summary, the impact model is a system of 82 linear equations
representing the activities and relationships embodied in each of the
affected markets in terms of the parameters described above and the
dependent variables. These dependent variables are the percentage changes
in prices and quantities in each of two sets of markets: the markets for
goods and the market for hazardous waste management services. This system
of linear equations is represented by
Zx = y
where
Z - an 82 x 82 matrix of coefficients
x s an 82 x 1 vector of percentage changes in the dependent variables,
and
y - an 82 x 1 vector of shifts in market relationships resulting from
the control option.
To solve the system of equations, the Z matrix is inverted and multiplied
by the vector of shift variables:
Z~l \I = Y
y A
For a more detailed description of the model, refer to Appendix I, Section
1.3. This model is a simplification of a complex set of technical and
behavioral relationships. It can provide only a general indication of the
types of pressures and adjustments that may result due to the costs of
complying with a control option.
8.3 ECONOMIC IMPACTS
The increased cost of performing hazardous waste management services
due to the control options will affect plants with TSDF in several ways.
Captive facilities use hazardous waste management as an input in the pro-
duction of their products—for example, industrial chemicals. Managers of
these plants may elect either to incur the higher costs of onsite hazardous
waste management or to purchase these services from a commercial firm.
Commercial firms will experience increased costs of hazardous waste
8-24
-------
management services. This will affect the prices they charge for hazardous
waste management services. Next, the impact of the regulation may be felt
in the markets for the goods and services produced by generators of hazard-
ous waste. The partial equilibrium analytical model described above is
used to estimate the direction and possible magnitude of changes in the
following:
• Quantities of goods and services produced in the 20 generat-
ing sectors
• Prices of goods and services produced in the 20 generating
sectors
• Quantities of hazardous waste management services supplied
by captive and commercial facilities
• Quantity of commercial hazardous waste management demanded
by each of the 20 generating sectors
• Price of hazardous waste management services
• Quantity of organic air emissions.
The number of facilities affected by the control options are identified in
Table 8-9.
8.3.1 Price and Quantity Adjustments
Changes in the prices and quantities are projected for each control
option for each of two markets:
• The market for goods and services produced by demanders of
hazardous waste management services
• The market for hazardous waste management services.
Insignificant price increases and quantity decreases are projected for
the products produced by the 20 generating sectors (see Tables 8-10 and
8-11). These adjustments are expected to be small due to the minor share
of production costs represented by hazardous waste management services.
Hazardous waste management costs represent less than one-tenth of one
percent of production costs for all generator sectors except plastics.
Only slight reductions are projected in the quantity of hazardous
waste generated under all control options. These reductions are due to two
factors. First, the reduced output rate of the 20 generating sectors will
8-25
-------
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8-28
-------
reduce the generation of hazardous waste. Also, it is assumed that some
potential waste minimization will further contribute to the reduced level
of hazardous waste generation. The sector-by-sector values for all options
are shown in Tables 8-12 to 8-16. Overall, the projected reduction in
hazardous waste generation is between approximately 200,000 and 800,000 Mg
annually, depending on the control option.
The major adjustment projected is the shift to less offsite manage-
ment. Although the price of offsite management services is projected to
increase only minimally for all control options, these increases are more
than the cost increase for relatively large captive hazardous waste manage-
ment facilities. Thus, the quantity of offsite hazardous waste management
is projected to decrease slightly, as shown in Table 8-17.
8.3.2 Regulatory Costs
A direct cost incurred by TSDF as a result of the regulation is the
compliance cost. Compliance costs are the costs of meeting the air emis-
sions control options. For each facility, these costs will vary depending
on the configuration of the facility and the volume of throughput. Tables
8-18 and 8-19 present the compliance costs without quantity adjustments and
with quantity adjustments presented above, respectively. The compliance
costs are smaller with the quantity adjustments because less hazardous
waste is projected to be generated due to reductions in production of the
goods and services produced by each sector and due to increased waste mini-
mization.
A large part of the compliance costs incurred by TSDF is the capital
cost required to modify hazardous waste management units to comply with the
control options. The capital costs are shown in Table 8-20. In Table
8-21, the percentage of the hazardous waste management costs are repre-
sented by compliance cost for all captive and commercial facilities. For
most sectors this is below 5 percent.
8.3.3 Emissions and Cost Effectiveness
Organic air emissions will decrease for the affected facilities due to
two factors: (1) the control efficiencies of each option, and (2) the
reduction in hazardous waste generation.
Table 8-22 provides the baseline estimates of emissions and the
percentage reduction from these values.
8-29
-------
TABLE 8-12.
QUANTITY ADJUSTMENTS IN WASTE GENERATION AND MANAGEMENT
BY GENERATING SECTOR: CONTROL OPTION la
Sector
HWM services, 103 Mg/yr
Onsite Commercial Total
Mining
Grain and textile mill products
Furniture, paper products, printing
Industrial chemicals, inorganic and organic
Plastics, fibers
Biological, pharmaceutical, medical chemicals
Assorted chemical products
Paint and allied products, petroleum and coal
Rubber, plastics
Cement companies
Primary metals
Metal fabrication
Nonelectrical machinery
Electrical machinery and supplies
Transportation equipment
Instruments
Miscellaneous manufacturing
Electric and gas utilities
Nondurable goods: wholesale sales
Research labs, hospitals, universities
Commercial hazardous waste handlers
Totals
-0.14
1.05
-0.16
-439.00
-325.00
-17.20
35.60
-39.50
-0.03
-0.14
-6.80
-3.92
-0.15
-0.09
-2.91
0.17
*
-0.18
-*
*
NA
-798.00
-0.28
-1.63
-0.02
-9.78
121.00
4.03
-129.00
9.54
*
-0.03
-2.33
-1.03
-0.05
-2.34
-0.58
-0.30
-1.23
-1.38
-0.27
*
-15.80
NA
-0.42
-0.58
-0.18
-449.00
-204.00
-13.20
-93.80
-30.00
-0.02
-0.17
-9.13
-4.95
-0.20
-2.43
-3.49
-0.14
-1.23
-1.56
-0.27
*
-15.80
-830. 57b
* - Absolute value less than 0.01.
HWM = Hazardous waste management.
NA s Not applicable.
aData for this table are obtained from the Source Assessment Model (SAM)
Industry Profile data base, (Appendix D, Section p. 2.1.), and from the
analytical model (as explained in Section 8.2).
effects of control option 1 on the quantity of waste management ser-
vices demanded by the 20 generating sectors estimated by the analytical
model are presented in this table. Control options 1 through 5 are based
predominantly on the use of add-on emission controls and reflect five
levels of controls (1=0 ppm organ ics; 2 and 3 = 500 ppm; 4 = 1,500 ppm;
and 5 s 3,000 ppm). The example control options are described in
Chapter 5.0.
8-30
-------
TABLE 8-13. QUANTITY ADJUSTMENTS IN WASTE GENERATION AND MANAGEMENT
BY GENERATING SECTOR: CONTROL OPTION 2a
HWM services, 10-
Sector
Mining
Grain and textile mill products
Furniture, paper products, printing
Industrial chemicals, inorganic and organic
Plastics, fibers
Biological, pharmaceutical, medical chemicals
Assorted chemical products
Paint and allied products, petroleum and coal
Rubber, plastics
Cement companies
Primary metals
Metal fabrication
Nonelectrical machinery
Electrical machinery and supplies
Transportation equipment
Instruments
Miscellaneous manufacturing
Electric and gas utilities
Nondurable goods: wholesale sales
Research labs, hospitals, universities
Commercial hazardous waste handlers
Onsite
-0.18
0.87
-0.17
-341.00
-326.00
-2.33
29.40
-4.71
-0.03
-0.15
-6.99
-0.94
-0.15
-0.09
-2.90
0.14
*
-0.22
*
*
NA
Commercial
-0.17
-1.35
0.02
-29.20
157.00
-8.57
-107.00
-20.10
0.01
0.01
-0.55
-3.16
-0.01
-1.91
0.01
-0.25
-1.02
-1.06
-0.22
*
-17.00
5 Mg/yr
Total
-0.35
-0.48
-0.15
-370.00
-168.00
-10.90
-77.50
-24.80
-0.02
-0.14
-7.54
-4.09
-0.16
-2.01
-2.89
-0.11
-1.02
-1.28
-0.22
*
-17.00
Totals
-656.00
NA -690.00b
* = Absolute value less than 0.01.
HWM = Hazardous waste management.
NA = Not applicable.
aData for this table are obtained from the Source Assessment Model (SAM)
Industry Profile data base, (Appendix D, Section D.2.I.), and from the
analytical model (as explained in Section 8.2).
bThe effects of control option 2 on the quantity of waste management ser-
vices demanded by the 20 generating sectors estimated by the analytical
model are presented in this table. Control options 1 through 5 are based
predominantly on the use of add-on emission controls and reflect five
levels of controls (1 = 0 ppm organics; 2 and 3 = 500 ppm; 4 = 1,500 ppm;
and 5 = 3,000 ppm). The example control options are described in
Chapter 5.0.
8-31
-------
TABLE 8-14.
QUANTITY ADJUSTMENTS IN WASTE GENERATION AND MANAGEMENT
BY GENERATING SECTOR: CONTROL OPTION 3a
Sector
HWM services, 103 Mg/yr
Onsite Commercial Total
Mining
Grain and textile mill products
Furniture, paper products, printing
Industrial chemicals, inorganic and organic
Plastics, fibers
Biological, pharmaceutical / medical chemicals
Assorted chemical products
Paint and allied products, petroleum and coal
Rubber, plastics
Cement companies
Primary metals
Metal fabrication
Nonelectrical machinery
Electrical machinery and supplies
Transportation equipment
Instruments
Miscellaneous manufacturing
Electric and gas utilities
Nondurable goods: wholesale sales
Research labs, hospitals, universities
Commercial hazardous waste handlers
-0.32
0.23
-0.02
-97.60
-47.90
-2.04
7.74
-6.41
*
*
-7.66
-0.94
-0.02
-0.06
-0.54
0.04
*
-0.168
*
*
NA
0.23
-0.36
-0.02
0.05
3.54
-0.83
-28.10
-0.12
-0.00
-0.34
5.67
-0.14
-0.02
-0.47
-0.22
-0.07
-0.27
-0.17
-0.06
*
-21.40
-0.09
-0.13
-0.04
-97.60
-44.40
-2.87
-20.40
-6.53
*
-0.04
-1.99
-1.08
-0.04
-0.53
-0.76
-0.03
-0.27
-0.34
-0.06
*
-21.40
Totals
-156.00
NA -199.00b
* - Absolute value less than 0.01.
HWM - Hazardous waste management.
NA s Not applicable.
aData for this table are obtained from the Source Assessment Model (SAM)
Industry Profile data base, (Appendix D, Section D.2.I.), and from the
analytical model (as explained in Section 8.2).
"The effects of control option 3 on the quantity of waste management ser-
vices demanded by the 20 generating sectors estimated by the analytical
model are presented in this table. Control options 1 through 5 are based
predominantly on the use of add-on emission controls and reflect five
levels of controls (1=0 ppm organics; .2 and 3 = 500 ppm; 4 = 1,500 ppm;
and 15 = 3,000 ppm).
Chapter 5.0.
The example control options are described in
8-32
-------
TABLE 8-15. QUANTITY ADJUSTMENTS IN WASTE GENERATION AND MANAGEMENT
BY GENERATING SECTOR: CONTROL OPTION 4*
HWM services, 103 Mg/yr
Sector Onsite Commercial Total
Mining
Grain and textile mill products
Furniture, paper products, printing
Industrial chemicals, inorganic and organic
Plastics, fibers
Biological, pharmaceutical, medical chemicals
Assorted chemical products
Paint and allied products, petroleum and coal
Rubber, plastics
Cement companies
Primary metals
Metal fabrication
Nonelectrical machinery
Electrical machinery and supplies
Transportation equipment
Instruments
Miscellaneous manufacturing
Electric and gas utilities
Nondurable goods: wholesale sales
Research labs, hospitals, universities
Commercial hazardous waste handlers
Totals
0.05
0.44
-0.20
11.40
-328.00
-2.47
15.00
-6.62
-0.03
-0.18
-7.44
-1.10
-0.16
0.48
-2.99
0.07
*
-0.32
*
*
NA
-323.00
-0.23
-0.69
0.13
-200.00
243.00
-3.08
-54.40
-6.00
0.02
0.11
3.60
-0.99
0.07
-1.51
1.52
-0.13
-0.52
-0.33
-0.11
*
-199.00
NA
-0.18
-0.24
-0.08
-189.00
-85.80
-5.55
-39.40
-12.60
-0.01
-0.07
-3.84
-2.08
-0.08
-1.02
-1.47
-0.06
-0.52
-0.65
-0.11
*
-19.90
-362. 00b
* = Absolute value less than 0.01.
HWM = Hazardous waste management.
NA = Not applicable.
aData for this table are obtained from the Source Assessment Model (SAM)
Industry Profile data base, (Appendix D, Section D.2.I.), and from the
analytical model (as explained in Section 8.2).
bThe effects of control option 4 on the quantity of waste management ser-
vices demanded by the 20 generating sectors estimated by the analytical
model are presented in this table. Control options 1 through 5 are based
predominantly on the use of add-on emission controls and reflect five
levels of controls (1=0 ppm organics; 2 and 3 = 500 ppm; 4 = 1,500 ppm;
and 15 = 3,000 ppm). The example control options are described in
Chapter 5.0.
8-33
-------
TABLE 8-16.
QUANTITY ADJUSTMENTS IN WASTE GENERATION AND MANAGEMENT
BY GENERATING SECTOR: CONTROL OPTION 5a
Sector
HWM services, 103 Mq/yr
Onsite Commercial Total
Mining
Grain and textile mill products
Furniture, paper products, printing
Industrial chemicals, inorganic and organic
Plastics, fibers
Biological, pharmaceutical, medical chemicals
Assorted chemical products
Paint and allied products, petroleum and coal
Rubber, plastics
Cement companies
Primary metals
Metal fabrication
Nonelectrical machinery
Electrical machinery and supplies
Transportation equipment
Instruments
Miscellaneous manufacturing
Electric and gas utilities
Nondurable goods: wholesale sales
Research labs, hospitals, universities
Commercial hazardous waste handlers
0.05
0.44
-0.20
11.30
-329.00
-0.26
14.80
-6.63
-0.03
-0.18
-7.44
-1.10
-0.16
0.48
-2.99
0.07
*
0.11
*
*
NA
-0.23
-0.68
0.13
-190.00
243.00
-5.26
-54.00
-5.90
0.02
0.11
3.62
-0.97
0.08
-1.50
1.53
-0.13
-0.52
-0.76
-0.11
*
-19.90
-0.18
-0.24
-0.08
-187.00
-85.20
-5.51
-39.20
-12.50
-0.01
-0.07
-3.81
-2.07
-0.08
-1.01
-1.46
-0.06
-0.52
-0.65
-0.11
*
-19.90
Totals
* = Absolute value less than 0.01.
HWM = Hazardous waste management.
NA = Not applicable.
-320.000
NA -360. 00b
effects of control option 5 on the quantity of waste management ser-
vices demanded by the 20 generating sectors estimated by the analytical
model are presented in this table. Control options 1 through 5 are based
predominantly on the use of add-on emission controls and reflect five
levels of controls (1=0 ppm organ ics; 2 and 3 = 500 ppm; 4 = 1,500 ppm;
and 15 = 3,000 ppm). The example control options are described in
Chapter 5.0.
8-34
-------
TABLE 8-17. PRICE AND QUANTITY ADJUSTMENTS IN THE MARKET FOR
COMMERCIAL HAZARDOUS WASTE MANAGEMENT SERVICES3
Control15
option
Baseline
Option 1
Option 2
Option 3
Option 4
Option 5
Waste quantity,
103 Mg/yr
5,718
5,703
5,702
5,697
5,699
5,699
Price of HWM,
$/Mg
1,276
1,281
1,280
1,277
1,278
1,278
Change from
Quantity
._
-0.28
-0.30
-0.37
-0.35
-0.35
baseline, %
Price
«, «•
0.44
0.37
0.10
0.19
0.19
HWM = Hazardous waste management.
aThis table presents the changes in the prices and quantities estimated by
the analytical model for the commercial hazardous waste management sector.
The price increases and quantity decreases are small in comparison to the
baseline price ($l,276/Mg) and baseline volume of hazardous waste services
supplied (5.7 million Mg). Data for this table are obtained from the
Source Assessment Model (SAM) Industry Profile data base, (Appendix D,
Section D.2.I.), and from the analytical model (as explained in
Section 8.2).
^Control options 1 through 5 are based predominantly on the use of add-on
emission controls and reflect five levels of controls (1=0 ppm organics;
2 and 3 = 500 ppm; 4 = 1,500 ppm; and 5 = 3,000 ppm). The example control
options are described in Chapter 5.0.
8-35
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8.3.4 Facility Closures
The costs of compliance will move each firm's average variable cost
(marginal cost) upward. As a consequence of market adjustments of supply
and demand, the economic model predicted that the new equilibrium price of
hazardous waste services would be higher and the new market quantity lower.
The reduced quantity of hazardous waste services implies reduced capacity
utilizat4on rates across the industry, and possibly facility closures.
The basic economic model of facility closures posits that if the price
of the commodity does not cover average variable cost, then total costs
exceed total revenue and the firm should close the facility. Porter15
identifies a number of reasons why closures may not always accompany such
situations:
• Existence of durable and specialized assets
• Presence of closure costs
• Absence of precise information on revenues and costs
• Existence of other managerial or emotional factors
• Absence of a mechanism for asset disposition.
However, the basic facility model is intuitively appealing and is
capable of identifying possible closure candidates. For captive facili-.
ties, using the market price is especially problematic because the
hazardous waste management services are the result of an internal transac-
tion and do not take place in a market. However, the market price is the
best surrogate available for the marginal benefit of the captive-provided
hazardous waste management services. Also, simple hazardous waste manage-
ment cost functions are used that represent the general relationship
between hazardous waste management output and costs. Undoubtedly, many
other important factors that affect production costs are ignored here.
Thus, the results can only suggest the general magnitude of the facility
closure pressures that the options may create.
Table 8-23 shows the possible facility closures given the assumptions
employed in this analysis:
• Hazardous waste management services are competitively
produced.
8-41
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8-42
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• Each hazardous waste management facility has constant costs
to the capacity utilization rate, and infinite costs there-
after.
These assumptions lead to the conclusion that some very small facilities
would be uneconomical and would experience pressures to close under the
control options. However, given the nominal reduction in hazardous waste
generation, it is doubtful that few, if any, of the closures predicted by
the model would actually take place. There are several reasons for this
interpretation of the results: (1) The reductions in hazardous waste
generation are likely to be distributed across all generators. Thus, each
generator will slightly reduce the operating rate of the hazardous waste
management facility. (2) The permitting process for a hazardous waste
management facility is long and costly. Facilities with transferrable
permits are likely to become more valuable when market prices for waste
management services are rising. Firms that run facilities with trans-
ferable permits* are likely to sell the permits to more efficient entre-
preneurs. (3) Transportation costs will preclude some of the projected
real locations of waste management. (4) Closure costs can be very substan-
tial.
8.3.5 Employment Effects
Increases in the cost of waste management services are projected to
slightly reduce the quantity of these services. The possible changes in
jobs due to these reductions is presented in Table 8-24.16 These estimates
are for the hazardous waste industry and are the direct consequences of the
potential plant closures in Table 8-23. The number of jobs in the TSDF
industry are estimated using a regression model. A representative sample
of facilities was selected from the SAM Industry Profile data base and the
number of production workers and amount of hazardous waste obtained.17 A
simple linear regression model was used to estimate the relationship
between number of jobs and production quantity:
transferable permits allow a business to sell the permit to a potential
buyer of the facility.
8-43
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8-44
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L = A + BQ
where
L'= number of production workers
Q = quantity of waste (Mg/yr)
A = intercept of the regression
,B = slope of the regression.
The estimated regression equation was statistically significant (5 percent
level of statistical significance).
Table 8-24 indicates that the number of hazardous waste management
jobs is likely to decline overall. The number of jobs lost in the regula-
tory options 1 to 5 is less than 1.5 percent of the total number of jobs
before the regulation. The number of jobs for the hazardous waste industry
is presented in Appendix I, section I.A.
The regulatory costs identified and estimated above are annualized
capital and operating costs of the options. There may also be one-time
dislocation costs to workers due to the projected output changes. No
attempt is made here to value the costs of these dislocations. Insignifi-
cant reductions in other jobs at captive facilities are projected due to
the projected reduction in output. All generating sectors were projected
to reduce the number of jobs in their hazardous waste management facilities
in proportion to the reduction in their hazardous waste management
activity.
Clearly, these projected reductions in jobs may not be translated one-
for-one into worker dislocations. Firms may move workers between jobs,
taking advantage of other demand shifts or attrition though resignations
and retirements.
8.3.6 Small Business Effects
The Regulatory Flexibility Act requires Federal agencies to analyze
the effects of their regulations on small entities and to involve these
entities more actively in developing and reviewing regulations. "Small
entities" here includes small businesses, small governmental jurisdictions,
and small organizations. The purpose of the Regulatory Flexibility Act is
to minimize the effects of the environmental regulations on small entities.
8-45
-------
The regulation of TSDF affects the hazardous waste generators who
supply onsite waste management services (captive facilities), and the
suppliers of commercial hazardous waste management services (commercial
facilities). The criteria for "smallness" applies to the firm, not to the
facility. The Small Business Administration (SBA) defines "small busi-
nesses" by industry (by SIC code) in terms of annual sales or employment.
(The SBA size criteria for each industry are shown in Table 8-25.) Deter-
mining the size of the business that owns a hazardous waste management
captive facility (a facility generating and managing some or all waste on
site) is complex because waste management is a secondary activity of the
business. These captive facilities in the industrial sectors are owned by
businesses that produce products such as petroleum products, solvents,
chemicals, etc., besides supplying hazardous waste management services.
The determination of the ownership of commercial facilities is less complex
because the primary activity of such businesses is hazardous waste manage-
ment services. Therefore, the formal analyses of small business effects
were limited to the commercial facilities. However, some general conclu-
sions are drawn for captive facilities at the end of this section.
A several-step process was initiated to investigate the potential
small business effects for commercial facilities. Information on the U.S.
Environmental Protection Agency (EPA) facility identification number, the
SIC code, and the volume entering hazardous waste management processes was
gathered from the Industry Profile Data Base. Using the baseline hazardous
waste management service price of $l,280/Mg and volume from the data base,
annual sales of waste management services were estimated (volume of hazard-
ous waste management service multiplied by the baseline price) for each of
the 136 commercial facilities. The SIC codes used to identify commercial
facilities include SIC 4212 (local trucking and storage), SIC 4213 (truck-
ing, without storage), SIC 4953 (refuse systems), and SIC 7399 (business
services, not elsewhere classified). A uniform annual sales cutoff equal
to $3.5 million is used to identify potential small businesses among the
commercial facilities instead of the SBA annual sales cutoff (SIC 4953)
equal to $6 million. The choice of $3.5 million is likely to overstate the
small business effects from the regulation. Thus, the number of small
businesses identified, 16, is likely to overstate the actual value.
8-46
-------
TABLE 8-25. SMALL BUSINESS ADMINISTRATION SIZE
CRITERIA BY SIC CODEa
SIC Code
SBA Cutoff
2800
2869
2899
3811
4953
4959
5161
5172
7399
8999
Does not exist
1,000 employees
500 employees
500 employees
$6 million
$3.5 million
500 employees
500 employees
$3.5 million
$3.5 million
aThe Small Business Administration (SBA) uses annual sales and
employment figures to determine the size of business entities, by
Standard Industrial Classification (SIC) code. The SBA cutoff
figures for "Small business" classification listed in this table
were used to determine which of the 136 commercial hazardous waste
management facilities could be designated as "small" (between 11
and 15). The next step was to assess the economic impact of the
regulation on these small firms.
8-47
-------
Of the 136 commercial facilities, 101 are estimated to have annual
sales greater than or equal to $3.5 million and hence are not considered
small businesses. The remaining 35 facilities have estimated annual sales
of less than $3.5 million and are potential candidates for small business
classification.
The survey forms for these 35 facilities from the National Survey of
Hazardous Waste Treatment, Storage, Disposal, and Recycling Facilities18
were examined to acquire more detailed information about the facilities and
the firms that own them. From these forms, the following items of informa-
tion were gathered:
• Facility name, contact person, and telephone number
• Name of the business owning the facility
• Names of other facilities also under the same ownership
• Types of hazardous waste management services performed
• Prices charged for hazardous waste management services
• Number of persons employed
• Current status of the facility (active or out of business).
Of the 35 facilities examined, 7 are owned by businesses with sales
greater than $3.5 million and hence were determined to be large. Ten of
these 35 facilities were verified to be small because they were owned by
businesses with sales less than $3.5 million. Twelve of these facilities
have gone out of business and are no longer active. The survey forms for
the remaining five facilities were not readily available, but they are
likely to be small. On the basis of this determination, between 10 and 16
facilities of the 136 total commercial facilities are likely to be poten-
tial small businesses.
Table 8-26 presents the baseline statistical data on the 16 potential
small businesses. These facilities supplied hazardous waste management
service (annual waste quantity) between 2 Mg and 2,300 Mg. Their annual
management costs were between $400 and $1.7 million. The annual revenue
from hazardous waste management services from these facilities was between
$2,000 and $3 million.
8-48
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TABLE 8-26. BASELINE STATISTICAL DATA FOR SMALL COMMERCIAL
FACILITIES WITH ESTIMATED SALES REVENUE LESS THAN
$3.5 MILLION (ANNUAL VALUES)3
Facility13
Waste
quantity, Mg
Service Service
cost,c $103 sales,d $103
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
2
2
7
19
62
70
94
175
438
744
951
981
1,111
1,965
2,201
2,346
0
2
1
24
62
59
104
22
78
265
226
420
62
1,686
91
94
2
2
9
24
79
90
119
223
559
949
1,213
1,252
1,417
2,507
2,808
2,993
aThis table presents the baseline statistical data on the key vari-
ables such as hazardous waste management services supplied (Mg/yr),
annual hazardous waste management costs ($/yr), annual revenue from
hazardous waste management services ($/yr), and profits (dollar
differences between annual revenue and annual costs) for the
potential small businesses.
^Facility codes are not used so as to protect the anonymity of each
facility.
cService costs were estimated using cost functions.
dService sales = Waste quantity times baseline price of $1,275.84.
8-49
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The next issue is whether the regulation would have "a significant
economic impact on a substantial number of small entities" was examined. A
"substantial number" is generally thought to imply greater than 20 percent
of the small entities, although this is not a fixed rule. A "significant
economic impact" is said to occur whenever any of the following criteria
are satisfied:
• Annual compliance costs (including annualized capital, oper-
ating, and reporting costs) increase as a percent of total
costs of production for small entities for the relevant
process or product by more than 5 percent.
• Compliance costs as a percent of sales for small entities
are at least 10 percent higher than compliance costs as a
percent of sales for large entities.
• Capital costs of compliance represent a significant portion
of capital available to small entities, considering internal
cash flow plus external financing capabilities.
• The requirements of the regulation are likely to result in
closures of small entities.
To assess whether the economic impacts on small businesses are likely
to be significant, the four criteria are examined. Table 8-27 summarizes
the with-regulation implications of control option 1, the most stringent of
the options. The first column presents the facility number. Column 2
provides the ratio of compliance costs to production cost. The ratio of
compliance costs to annual sales for the small businesses is presented in
column 3. Column 4 presents the ratio of capital costs to annual sales for
each small businesses. Finally, column 5 identifies the small businesses
that are potential closure candidates.
The compliance cost increases as a percent of total costs of
production for small businesses are less than 3.5 percent for all small
businesses.
The compliance costs as a percent of sales for small businesses are
less than 2 percent. The estimated ratio of compliance costs to total
sales for the 16 small businesses is 0.28 percent. For the larger busi-
nesses, the estimated ratio of total compliance costs to total sales is
0.26 percent. The compliance costs as a percent of sales for small
8-50
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TABLE 8-27. EFFECTS OF THE MOST STRINGENT REGULATION (OPTION 1) ON
SMALL COMMERCIAL FACILITIES WITH ESTIMATED SALES
REVENUE LESS THAN $3.5 MILLION3
Facility^
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Compliance
cost/cost0
308
986
307
402
824
98
70
203
337
2,669
3,607
1,200
878
942
735
771
Compliance
cost/sales11
38
652
38
401
647
65
61
20
47
743
602
401
38
631
24
24
Capital
cost/sales6
62
1,222
62
939
1,213
113
168
33
63
1,548
1,303
939
62
1,427
29
28
Potential
closure
candidate
N
N
N
Y
N
N
N
N
N
N
N
N
N
N
N
N
N = Not likely to close.
Y = Potential for closure.
aThe postregulatory financial implications of regulatory control option 1
are summarized in this table. Column 2 represents the ratio of annual
compliance costs (annualized capital and operating costs) and annual
hazardous waste management costs. Column 3 represents the ratio of
compliance capital costs and annual profits. Column 4 represents the
ratio of compliance costs and annual revenue, and column 5 represents the
ratio of compliance capital costs and annual revenue. Data for this
table are obtained from the Source Assessment Model (SAM) Industry
Profile data base, Appendix D, Section D.2.1.
^Facility codes are not used so as to protect the anonymity of each
facility.
cCompliance costs ($) per $100,000 of waste management costs.
dCompliance costs ($) per $100,000 of revenue received.
eCapital costs ($) per $100,000 of revenue received.
8-51
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businesses are less than 10 percent higher than the compliance costs as a
percent of sales for large businesses.
The capital costs as a percent of sales for small businesses are less
than 2 percent. Because the compliance capital costs represent a small
portion of the total amount of sales, it is reasonable to conclude that the
capital costs of compliance represent an insignificant portion of the capi-
tal available to small businesses.
The economic impact model estimates that 6 of the larger businesses
and 1 of the 16 small businesses are potential closure candidates if all
the projected quantity adjustments are registered on the highest-cost
facilities. However, given the nominal reduction in hazardous waste
generation, it is likely that these adjustments will be spread over many
facilities. Thus, it is doubtful that any of the closures predicted by the
model would actually take place.
The analysis indicates that the economic impacts on small businesses
are not "significant" using the criteria outlined above. The TSDF process
is a component of the cost of production for captive facilities. As shown
in Table 8-6, at the industry level, TSDF costs are estimated to represent
a very small share of production costs. Thus, even large hazardous waste
treatment costs would not typically be significant as a percent of the
costs of the entire plant. Table 8-27 shows that the highest share of
compliance to production costs for any small commercial businesses is less
than 5 percent. Given these values, it seems reasonable to conclude also
that it is unlikely that there would be any significant impact on small
businesses in the captive sector.
8.4 REFERENCES
1. Booz-Allen and Hamilton, Inc. Review of Activities of Major Firms in
the Commercial Hazardous Waste Management Industry: 1982 Update.
Exhibit 5. Prepared for U.S. Environmental Protection Agency, Office
of Policy Analysis. Washington, DC. August 15, 1983.
2. Development Planning and Research Associates, Inc. RIA Mail Survey
Questionnaire. Prepared for U.S. Environmental Protection Agency,
Office of Solid Waste. Washington, DC. 1981.
3. Industrial Economics, Inc. Regulatory Analysis of Proposed Restric-
tions on Land Disposal of Hazardous Wastes. Prepared for U.S. Envi-
ronmental Protection Agency, Office of Solid Waste. Washington, DC.
May 1985. Exhibit 4.
8-52
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4.
5.
6.
7.
8.
9.
Temple, Barker, and Sloane, Inc. New England Regional Hazardous Waste
Pilot Project: Phase I Briefing. Prepared for U.S. Environmental
Protection Agency, Region I, Boston, MA. May 1985. p. IV-18.
National Council of the Paper Industry for Air and Stream Improvement,
Inc. The Land Application and Related Utilization of Pulp and Paper
Mill Sludges. Technical Bulletin No. 439. New York, NY. August
1984. p. 117-122. . v .
ICF, Incorporated. The RCRA Risk-Cost Analysis Model, Phase III.
Appendixes B and D. Prepared for U.S. Environmental Protection
Agency, Office of Solid Waste. Washington, DC. March 1984.
Research Triangle Institute. A Profile of the Market for Hazardous
Waste Management Services. Prepared for U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards. May 1986.
Houthakker, H. S., and L. D. Taylor. Consumer Demand in the United
States: Analysis and Projections. Cambridge, MA, Harvard University
Press. Second Edition. 1970. p. 87, 100, 115-120, 166-167.
Koutsoyiannis, A. Goals of Oligopolistic Firms: An
of Competing Hypotheses. Southern Economics Journal
1984.
Empirical Testing
. 51(2):540-567.
10. Reference 8.
11. Reference 9.
12. Muth, R. F. The Derived Demand Curve for a Productive Factor and the
Industry Supply Curve. Oxford Economic Papers. 16(2):221-234, July
1964.
13. Miedema, A. K. The Retail-Farm Price Ratio, the Farmer's Share, and
Technical Change. American Journal of Agricultural Economics.
58(4):750-756, November 1976.
14. Gardner, B. L. Determinants of Supply Elasticity in Interdependent
Markets. American Journal of Agricultural Economics. 61(3):463-745,
August 1979.
15. Porter, M. E. Competitive Strategy: Techniques for Analyzing Indus-
tries and Competitors. New York City, The Free Press. 1980.
p. 303-320.
16. Memorandum from Chandran, Ram, RTI, to Docket. September 19, 1988.
Estimation of Number of Workers in Treatment, Storage, and Disposal
Facilities (TSDF).
17. Reference 16.
8-53
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18. Research Triangle Institute. Small Business Analysis. National
Survey of Hazardous Waste Treatment, Storage, Disposal, and Recycling
Facilities. Prepared for U.S. Environmental Protection Agency, Office
of Solid Waste. Research Triangle Park, NC. 1987.
8-54
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APPENDIX A
EVOLUTION OF PROPOSED STANDARDS
-------
-------
APPENDIX A
EVOLUTION OF PROPOSED STANDARDS
The EPA Office of Solid Waste and Emergency Response (OSWER) first
initiated the development of air emission standards for hazardous waste
treatment, storage, and disposal facilities (TSDF) in 1978. In December
1978, OSWER proposed air emission standards for treatment and disposal of
hazardous waste based on an approach that included definition of volatile
waste solely in terms of its vapor pressure and use of the U.S. Occupa-
tional Safety and Health Administration (OSHA) levels for determining
acceptable emission levels (43 FR 59008, December 18, 1978). A supple-
mental notice of proposed rulemaking was published on October 8, 1980
(45 FR 66816).
The 1978 and 1980 actions were reproposed in 1981 (46 FR 11126,
February 5, 1981); the proposed standards included requirements for systems
to monitor ambient air quality and gaseous emissions, sampling and analysis
plans, data evaluation by predictive models, and recordkeeping/reporting.
General control requirements to prevent wind dispersion of particulate
matter from land disposal sources also were proposed. The final standards
adopted by EPA included the particulate control requirements, but they did
not incorporate any other measures for air emission management
(47 FR 32274, July 26, 1982).
In February 1984, EPA considered the need to further evaluate air
emission standards and delegated authority to the Office of Air Quality
Planning and Standards (OAQPS) to develop standards for air emissions from
area sources at TSDF. At that time, OAQPS initiated the project that led
to this draft background information document (BID). The program plan
outlining the technical and regulatory approaches selected for the project
was reviewed by the National Air Pollution Control Technique Advisory
Committee (NAPCTAC) meeting held August 29-30, 1984. The NAPCTAC is
composed of 16 persons from industry, State, and local air pollution
agencies, environmental groups, and others with expertise in air pollution
control. In November 1984, Congress passed the Hazardous and Solid Waste
Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA) of
A-3
-------
1976. Section 3004(n) of HSWA specifically directs the Administrator to
establish standards for the monitoring and control of air emissions from
hazardous waste TSDF as necessary to protect human health and the
environment. It is under the authority of Section 3004(n) that these
standards are being developed.
This OAQPS study to develop air standards for TSDF air emissions began
with the collection of information on waste management processes, hazardous
waste characteristics, and controls that could potentially be applied to
reduce air emissions. This information was obtained through site visits
and sampling surveys, industry surveys, various Agency data bases, and
testing programs. Additional information was gathered through literature
searches, meetings, and telephone contacts with experts within EPA, State
and local regulatory authorities, and affected industries. Based on this
information, preliminary draft BID chapters, which described the TSDF
industry, emission sources, and potential controls were prepared and trans-
mitted to representatives of industry, trade associations, and environ-
mental groups for review and comment in February 1986. The comments
received were analyzed and incorporated in the BID, as were additional data
obtained through test programs, other data bases, and internal EPA review.
V
Public comments were also solicited on three specific aspects of the
project. In February 1987, comments were solicited from TSDF operators,
major trade associations, and environmental groups on potential test
methods for determining the volatile organic content of hazardous wastes.
In March 1987, a draft report on predictive models for estimating organic
air emissions was mailed out for public review. This report was finalized
and distributed in December 1987. (See "Hazardous Waste Treatment,
Storage, and Disposal Facilities [TSDF] - Air Emission Models," EPA-450/3-
87-026.) On June 9, 1987, OAQPS presented a status report on the project
and test method development work at a public meeting of the NAPCTAC.
Under a separate project, the OAQPS proposed its initial set of TSDF
air standards for organic emissions from process vents and equipment leaks
(52 FR 3748, February 5, 1987). At that time, EPA requested comments from
TSDF operators, trade associations, and environmental groups on the
proposed air controls. A public hearing was held on March 23, 1987, in
A-4
-------
Durham, North Carolina, to obtain external comments on the proposed
standards. These standards were promulgated on June 21, 1990
(55 FR 25454). Additional Information on this project can be found 1n
Docket Number F-90-AESP-FFFFF.
On April 5, 1988, OAQPS distributed the draft BID for review to
NAPCTAC members, Industry representatives, and environmental groups prior
to the NAPCTAC meeting held May 18, 1988. Also distributed for review were
draft papers titled, "Preliminary Control Strategies for TSDF A1r Emission
Standards," and "Method for the Determination of Volatile Organic Content
of Hazardous Waste." This .meeting, open to the public, provided an
additional opportunity for industry and environmental groups to comment on
the draft rulemaking prior to proposal. This BID reflects revisions that
have been made based on comments received since NAPCTAC review. Major
events that have occurred in the development of background information for
the proposed standards are present 1n Table A-l.
A-5
-------
TABLE A-l. EVOLUTION OF PROPOSED TREATMENT, STORAGE,
AND DISPOSAL FACILITY AIR STANDARDS
Date
Event
November 1983
December 1983
February 1984
August 29-30, 1984
November 9, 1984
November 9, 1984
April 24, 1985
January 8, 1985
October 1985
February 6, 1986
March 6-7, 1986
Contractors begin site visits and source sampling at
over 100 TSDF; testing under OAQPS/ORD/OSW program
extending through 1986 also begins.
Meeting with Chemical Manufacturers Association to
review "Evaluation and Selection of Models for
Estimating Air"Emissions from Hazardous Waste
Treatment, Storage, and Disposal Facilities,"
"Assessment of Air Emissions from Hazadous Waste
Treatment, Storage, and Disposal Facilities:
Hazardous Waste Rankings," and "Assessment of Air
Emissions from Hazardous Waste Treatment, Storage,
and Disposal Facilities: Preliminary National
Emissions Estimates."
OSWER delegates authority for development of air
standards for TSDF area sources to OAQPS.
National Air Pollution Control Techniques Advisory
Committee meeting held in Durham, North Carolina, to
review TSDF program plan (49 FR 26808).
Congress passes Hazardous and Solid Waste Amendments
to Resource Conservation and Recovery Act of 1976.
Meeting with Chemical Manufacturers Association
Secondary Emissions Work Group to review and comment
on draft technical note, "Basis for Design of Test
Facility for Flux Chamber Emissions Measurement
Validation."
Meeting with American Petroleum Institute to discuss
status of standards development for land treatment.
Meeting with Chemicals Manufacturers Association to
discuss current studies of air source emissions from
TSDF.
Research Triangle Institute begins work to develop air
emissions for hazardous waste treatment, storage, and
disposal facilities, under EPA Contract No. 68-02-
4326.
Mailout of preliminary BID Chapters 3.0 to 6.0 to
industry and environmental groups.
Meeting with Chevron Chemical Co. to discuss planned
landfarm simulation study.
A-6
(continued)
-------
TABLE A-l (continued)
Date
Event
April 24, 1986
May 14, 1986
December 17, 1986
February 5, 1987
February 11, 1987
March 23, 1987
April 10, 1987
June 9, 1987
September 30, 1987
December 10, 1987
January 14, 1988
April 5, 1988
Meeting with American Petroleum Institute on status
of TSDF standards development.
Meeting with Chemical Manufacturers Association to
discuss project status and BID comments.
Meeting with American Petroleum Institute on land
treatment air emission research.
Proposal of accelerated standards for selected
sources at hazardous waste TSDF (52 FR 3748).
Mai lout of draft test method approach document to
industry and environmental groups.
Public hearing for accelerated rulemaking for
selected sources at hazardous waste TSDF held in
Durham, North Carolina.
Mailout of draft report on organic air emission models
to industry and environmental groups.
Meeting of National Air Pollution Control Techniques
Advisory Committee to review project status and test
method development program (52 FR 15762).
Meeting with Chevron Chemical Corporation to discuss
land treatment data.
Mailout of final report on organic air emission
models to industry and environmental groups.
Meeting with Chemical Manufacturers Association to
discuss project status.
Mailout of preliminary draft BID to National
Air Pollution Control Techniques Advisory Committee,
TSDF operators, trade associations, environmental
groups, and other public groups.
(continued)
A-7
-------
TABLE A-l (continued)
Date
Event
Meeting of National Air Pollution Control Techniques
Advisory Committee to review preliminary draft BID.
Meeting with Chemical Manufacturers Association to
receive comments on preliminary draft BID.
Meeting with Chemical Manufacturers Association to
receive comments on volatile organics test method.
Promulgation of accelerated standards for TSDF
process vents and equipment leaks (55 FR 25454).
TSDF
OAQPS
ORD
OSW
BID
May 18, 1988
July 27, 1988
August 16, 1988
June 21, 1990
Treatment, storage, and disposal facility.
Office of Air Quality Planning and Standards.
Office of Research and Development.
Office of Solid Waste.
Background Information Document.
aThis table presents those major events that have occurred to date in the
development of background information for the TSDF air standard.
A-8
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
-------
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
This appendix consists of a reference system that is cross-indexed
with the October 21, 1974, Federal Register (39 FR 37419) containing EPA
guidelines for the preparation of Environmental Impact Statements. This
index can be used to identify sections of the document that contain data
and information germane to any portion of the Federal Register guidelines.
B-3
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the Background
Information Document (BID)
1. Background and description
a. Summary of control
options
b. Industry affected by the
control options
c. Relationship to other
regulatory Agency actions
d. Specific processes affected
by the control options
A description of the control options
is provided in Chapter 5.0 of BID
Vol. I.
A discussion of the industry affected
by the control options is presented in
Chapter 3.0 of BID Vol. I.
The relationship to other regulatory
Agency actions is discussed in Chapter
5.0 of BID Vol. I.
The specific processes affected by the
control options are summarized in
Chapter 3.0 of BID Vol. I.
2. Impacts of the alternatives
a. Air pollution
b. Water pollution
c. Solid waste disposal
d. Energy impact
The air pollution impacts are dis-
cussed in Chapter 6.0 of BID Vol. I.
Supplementary information on the
emission models and emission estimates
is included in Appendix C of BID
Vol. I. Appendix D of BID Vol. II
describes the Source Assessment Model
used to estimate nationwide emissions
and their correlations to test
methods. Test data are presented in
Appendix F of BID Vol. II.
The water pollution impacts are
described in Chapter 6.0 of BID
Vol. I.
The solid waste disposal impacts are
discussed in Chapter 6.0 of BID
Vol. I.
The energy impacts are discussed in
Chapter 6.0 of BID Vol. I.
(continued)
B-4
-------
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS (continued)
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the Background
Information Document (BID)
e. Cross-media impacts
f. Economic impact
g. Health impact
Cross-media and secondary air environ-
mental impacts are discussed in
Chapter 6.0 of the BID Vol. I. Addi-
tional information is presented in
Appendix K of BID Vol. III.
The cost and economic impacts of
control options are presented in
Chapters 7.0 and 8.0 of BID.Vol., I.
Supplementary information on control
costs and on the economic impact
analysis is included in Appendixes H
and I of BID Vol. III.
Incidence and risk impacts are
presented in Chapter 6.0 of BID
Vol. I. The health risk analyses are
discussed further in Appendixes D and
E of BID Vol. II and Appendix J of BID
Vol. III.
B-5
-------
-------
APPENDIX C
EMISSION MODELS AND EMISSION ESTIMATES
-------
-------
APPENDIX C
EMISSION MODELS AND EMISSION ESTIMATES
The objective of Appendix C is to provide a link between
• Emission models used to estimate organic air emissions from
treatment, storage, and disposal facility (TSDF) waste
management units
• Model TSDF waste management unit analyses used to develop
estimates of emission reductions and costs of applying emis-
sion control technologies
• The Source Assessment Model (SAM), which uses both the
aforementioned to generate an estimate of nationwide TSDF
organic air emissions and control costs.
This appendix provides a discussion of the mathematical models used to
estimate nationwide air emissions from hazardous waste TSDF, These models
represent most of the TSDF emission sources introduced in Chapter 3.0,
Section 3.1. Some emission sources, such as drum crushing, are undergoing
analysis at this time. The discussion of the emission models in Sec-
tion C.I includes a description of the models, a comparison of emission
model estimates with results from specific field tests of TSDF waste man-
agement units, and a sensitivity analysis.
To estimate emissions with these emission models, inputs such as waste
management unit surface area, waste retention time, and depth of unit are
essential. Physical and chemical characteristics.of the waste in the
unit—such as the specific organic compounds present and their concentra-
tions and knowledge of the presence or absence of multiple phases (e.g.,
separate aqueous and organic layers)--are also needed.
Use of these emission models to develop estimates of nationwide emis-
sions requires some knowledge of the waste management unit characteristics
that could affect emissions for each TSDF in the country. Given that only
C-3
-------
general information such as annual waste throughput is available for the
thousands of TSDF, a model waste management unit approach was developed to
facilitate emission estimates, as well as control emission reductions and
control costs. Descriptions of the model units and the basis for develop-
ing the range of model units characteristics are given in Section C.2.1.
As explained above, knowledge of waste physical and chemical charac-
teristics is essential to emission estimates. Emission reductions and
control costs likewise are sensitive to waste properties, so a model unit
analysis to derive emission reduction and control costs also requires a
definition of wastes being managed in the model waste management units.
Model wastes were defined for this purpose. Section C.2.2 provides a dis-
cussion of the selection of model wastes and defines those wastes.
Lastly, in Section C.2.3, control costs and control emission reduc-
tions for a selected set of model waste management units are given in tabu-
lar form. The data contained in the table demonstrate the variations in
costs and emission reductions that occur along with variations in model
waste compositions and degree of emission control provided by different
control technologies. These model waste management unit control costs and
control emission reductions are the bases for extrapolating costs and emis-
sion reductions to nationwide estimates. Appendix D contains a discussion
of the procedure for relating costs to waste throughput in each model waste
management unit and then extrapolating for nationwide cost estimates via
the SAM. The emission reductions expressed as a percentage of uncontrolled
emissions are discussed in Chapter 4.0 and Appendix D.
C.I EMISSION MODELS
C.I.I Description of Models
The emission models that are used to estimate air emissions from TSDF
processes are drawn from several different sources. These models are
presented in a TSDF air emission models report that provides the basis and
description of each model, along with sample calculations and comparisons
of modeled emissions to measured emissions using field test data.
The emission models discussed in Chapter 3.0 are those presented in
the March 1987 draft of the TSDF air emission models report.1 Certain TSDF
C-4
-------
emission models have been revised since that time, and a final version of
the report has been released (December 1987).2 The principal changes to
the models involved refining the biodegradation component of the models to
more accuractely reflect biologically active systems handling low organic
concentration waste streams. With regard to emission model outputs, the
changes, by and large, did not result in appreciable differences in the
emission estimates. (Refer to Appendix D, Section D.2.4, for a more
detailed discussion.)
In the emission models report, models are presented for the following
TSDF management processes: surface impoundments and uncovered storage and
treatment tanks; land treatment; landfills and wastepiles; and transfer,
storage, and handling operations. In general, the report describes the
chemical and physical pathways for organics released from hazardous wastes
to the atmosphere, and it discusses their relevance to the different types
of TSDF management processes and the sets of conditions that are important
in emission estimation.
In the following paragraphs, the models are presented in simplified
forms or in qualitative terms. For a full discussion, refer to the TSDF
air emission models report.
C.I.1.1 Surface Impoundments and Uncovered Tanks.
This section presents emission models for quiescent and
aerated/agitated surface impoundments and uncovered tanks. Quiescent
surface impoundments where wastes flow through to other processes (i.e.,
storage and treatment) are addressed initially with uncovered tanks
(C.I.1.1.1). Quiescent impoundments without waste flowthrough, such as
disposal impoundments, are discussed in the next section (C.I.1.1.2).
Aerated treatment impoundments and uncovered tanks are discussed in
Section C.I.1.1.3.
C.I. 1.1.1 Quiescent surface with flow. Emission characteristics from
quiescent uncovered storage and treatment processes are similar; therefore,
the same basic model was used to estimate emissions from all such
processes. These waste management processes for flowthrough emission
modeling include uncovered tank storage, storage surface impoundments,
uncovered quiescent treatment tanks, and quiescent treatment impoundments.
The modeling approach used to estimate emissions from these types of TSDF
management units is based on the work of Springer et al.3 and Mackay and
C-5
-------
Yeun4 for the liquid-phase mass transfer and MacKay and Matasugu5 for the
gas-phase mass transfer. The emission equation used is a form of the basic
relationship describing the mass transfer of a volatile constituent from
the opened liquid surface to the air. The model for flowthrough impound-
ments and tanks assumes that the system is well-mixed and that the bulk
concentration is equal to the effluent concentration. A material balance
for this yields:
QCQ = KACL + QCL
where
Q = volumetric flow rate, m3/s
C0 - influent concentration of organics in the waste, g/m3
K = overall mass transfer coefficient, m/s
A = liquid surface area, m2
CL = bulk (effluent) concentration of organics, g/m3.
The overall mass transfer coefficient is based on:
(C-l)
1
1
1
KGKeq
(C-2)
where
K = overall mass transfer coefficient, m/s
KL = liquid-phase mass transfer coefficient, m/s
Kg = gas-phase mass transfer coefficient, m/s
Keq » equilibrium constant or partition coefficient, unitless.
The air emissions from the liquid surface are calculated using the
basic relationship describing mass transfer of a volatile constituent from
the open liquid surface to the air:
E = KACL (C-3)
C-6
-------
where
E = air emissions from the liquid surface, g/s
K = overall mass transfer coefficient, m/s
A = liquid surface area, m^
CL = concentration of the constituent in the liquid phase, g/m3.
C.I.1.1.2 Quiescent surface with no outlet flow. A disposal
impoundment is defined as a unit that receives waste for ultimate disposal
rather than for storage or treatment. This type of impoundment differs
from the storage and treatment impoundments in that there is no liquid flow
out of the impoundment. The calculation of the overall mass transfer coef-
ficient is the same as that presented for quiescent surfaces with flow.
However, the assumption that the bulk concentration is equal to the efflu-
ent concentration is not applicable here. The emission-estimating proced-
ure differs in the calculation of the liquid-phase concentration that is
the driving force for mass transfer to the air. The emission rate can be
calculated as follows:
E =
[1_exp (.KAt/V)]
(C-4)
where
E = Emission rate, g/s
V = Volume of the impoundment, m3
t = Time after disposal, s
and with the other symbols as previously defined. Reference 2 gives a
detailed derivation of the above equation.
C.I.1.1.3 Aerated systems. Aeration or agitation in an aqueous system
transfers air (oxygen) to the liquid to improve mixing or to increase biode-
gradation. Aerated hazardous waste management processes include uncovered,
aerated treatment tanks and aerated treatment impoundments. A turbulent
liquid surface in uncovered tanks and impoundments enhances mass transfer to
the air. Thus, there are two significant differences between the quiescent
emission model and the aerated emission model: (1) the modified mass transfer
C-7
-------
coefficient and (2) the incorporation of a biodegradation term. The calcula-
tion of the overall mass transfer coefficient for mechanically aerated systems
is based on the correlations of Thibodeaux and Reinhart for the liquid and gas
phases, respectively.6 The rate of biodegradation was assumed to be first
order with respect to concentration based on experimental data in the form of
a decay model; this is similar to the Monod model at low loadings.
A material balance around the well-mixed system yields:
QCQ = QCL
KCLA
(C-5)
where
Q
C0
V
K
A
volumetric flow rate, m3/s
influent concentration of organics in the waste, g/m3
bulk (effluent) concentration of organics in the waste, g/m3
pseudo first-order rate constant for biodegradation, 1/s
system volume, m3
overall mass transfer coefficient, m/s
surface area, m2.
Air emissions can be estimated using Equation (C-3) .
Additional research data have been obtained on biodegradation rates of
specific constituents, and numerous comments were received on the emission
and biodegradation models. 6-5 Based on the new information, an improved
biodegradation model was developed that incorporates Monod kinetics. This
model fits the available biodegradation rate data better than the model
described above and generally provides a sounder technical basis for evalu-
ating the extent of biodegradation. The comments also provided additional
information on the concentration of organics in biologically active treat-
ment processes and the aeration parameters used for the model units.
Proposed revisions to the aerated units and the biodgradation model were
evaluated in a sensitivity analysis to determine the effect on the nation-
wide impacts presented in this document. 7 The results of the analysis
C-8
-------
showed that the combined effects of the proposed changes had only a minor
effect (less than 5 percent) on nationwide impacts.
C.I.1.2 Land Treatment. Emissions from land treatment operations may
occur in three distinct ways: from application of waste to the soil sur-
face, from the waste on the soil surface before tilling, and from the soil
surface after the waste has been tilled into the soil or retilled after
initial waste application.
Short-term emissions of organics from hazardous waste on the soil
surface prior to tilling, a result of surface application land treatment,
or immediately following tilling, are estimated by calculating an overall
mass transfer coefficient similar to that for an oil film on a surface
impoundment. The basic assumption is that mass transfer is controlled by
the gas-phase resistance. The gas-phase mass transfer coefficient and the
equilibrium constant are calculated from the correlation of MacKay and
Matasugu8 and from Raoult's law, respectively.
The RTI land treatment model is used to calculate emissions from waste
that is mixed with the soil. This condition may exist when waste has been
applied to the soil surface and has seeped into the soil, when waste has
been injected beneath the soil surface, or when the waste has been tilled
into the soil. In land treatment, soil tilling typically occurs regardless
of the method of waste application. Air emissions from land treatment
operations are at their highest when a waste containing volatile organics
is applied onto or tilled into the soil or retilled after initial waste
application. Within a few hours after application or tilling, the rate of
air emissions will be substantially less than the maximum because the
volatiles at the surface have been removed and the remaining volatiles must
diffuse up through a layer of porous solids. The effect of tilling on
emissions is reflected in the model by including a short-term maximum
evaporation rate immediately after tilling occurs, then applying or
resuming the long-term emission rate model.
The RTI land treatment emission model for long-term emissions from a
land treatment unit incorporates terms that consider the major competing
pathways for loss of organics from the soil; the model combines a diffusion
equation for the waste vapors in the soil and a biological decay rate equa-
tion. The RTI model is based on Pick's second law of diffusion applied to
C-9
-------
a flat slab as described by Crank^ and includes a term to estimate biologi-
cal decay assuming a decay rate that is first order with respect to waste
loading in the soil. No equations are presented here because they are not
easily condensed. However, these equations are described in the TSDF air
emission models report.
C.I.1.3 Waste Fixation, Wastepiles, and Landfills. Two major
emission models are used in estimating emissions from landfills. Both
assume that all wastes are fixed wastes and that no biological degradation
takes place to reduce organic content.
One model estimates emissions from closed landfills.10 The Closed
Landfill Model is used to estimate emissions from waste placed in a closed
(or capped) landfill that is vented to the atmosphere and, as a special
case, emissions from active landfills receiving daily earth covers. This
model accounts for the escape of organics resulting from diffusion through
the cap and convective loss from landfill vents resulting from barometric
pumping. The closed landfill model is based primarily on the work of
Farmer et al.,11 who applied Pick's first law for steady-state diffusion.
Farmer's equation utilizes an effective diffusion coefficient for the soil
cap based on the work of Millington and Quirk.12 The model also includes a
step to estimate convective losses from the landfill. The TSDF air emis-
sion models report describes the model in detail.
The RTI land treatment model is used to estimate the air emissions
from active landfills (landfills still receiving wastes) and wastepiles.13
As previously stated, this model is based on Fick's second law of diffusion
applied to a flat slab as described by Crank, and it includes a term to
estimate biological decay assuming a decay rate that is first order with
respect to waste loading in the soil. A land-treatment-type model was
selected for estimating emissions from open landfills and wastepiles
because (1) there are a number of similarities in physical characteristics
of open landfills, wastepiles, and land treatment operations, and (2) the
input parameters required for the land treatment model are generally
available for open landfills and wastepiles, which is not the case for some
of the more theoretical models for these sources.
The emission model developed to characterize organic air emissions
from uncovered wastes described in the air emissions model report was not
C-10
-------
considered appropriate for estimating emissions from waste fixation
processes. However, a number of field tests have been conducted,^ and
these data were used to develop an emission factor for this process.
C.I.1.4 Transfer, Storage, and Handling. This subsection discusses
organic emission models for container loading and spills, fixed-roof tank
loading and storage, dumpster storage, and equipment leaks.
C.I.1.4.1 Container loading and spills. Containers can include
drums, tank trucks, railroad tank cars, and dumpsters. To calculate organ-
ic emissions from loading liquid wastes into all of these containers except
dumpsters, the AP-42 equation for loading petroleum liquids is applied.15
This equation was derived for tank cars and marine vessels. It is also
applied to tank trucks and 0.21-m3 (55-gal) drums in this case because the
loading principles are similar. (No equation has been developed exclu-
sively for small containers such as drums.) Covered container loading
emissions are based on the AP-42 equation:
(C-6)
where
LL = loading loss, lb/1,000 gal of liquid loaded
T = bulk temperature of liquid, K
S = saturation factor, dimensionless
M = molecular weight of vapor, Ib/lb mol
P = true vapor pressure of liquid, psia.
Spillage is the only other significant emission source from covered
containers. An EPA study of truck transport to and from TSDF and truck
emissions at TSDF terminals provided the background information necessary
to estimate spillage losses during TSDF trucking, handling, and storage
operations. The emission estimate for losses at a storage facility applies
the same spill fraction used for drum handling, 1 x 10~4, developed by
EPA.16 .The following equation estimates drum handling and storage emis-
sions:
,-4
x T x
(C-7)
C-ll
-------
where
Ls = emissions from drum storage, Mg/yr
T ~ throughput, Mg/yr
W-j = organic weight fraction
V-j * volatilization fraction.
Spillage emissions from tank trucks and railroad tank cars are esti-
mated using the same equation except that the spill fraction of 10~5 for
other types of waste movement is applied instead of the 10~4 spill fraction
for drum handling.1? (See the TSDF air emission models report, Section
7.7.)
C.I.1.4.2 Dumpster storage. Emissions from open dumpster storage are
estimated using a model based originally upon the work of Arnold, which was
subsequently modified by SheniS and EPA/GCA1^ Corporation to characterize
organic air emissions from uncovered wastes. The equation in its final
form is thus presented as:
Ei =
ri w
RT
where:
(C-8)
E-j = emission rate of constituent of interest from the emitting
surface, g/s
P0 s total system pressure (ambient pressure), mmHg
MW-j = molecular weight of constituent i, g/g mol
y-j* = equilibrium mole fraction of the i-th constitutent in the gas
phase
w = width of the volatilizing surface perpendicular to the wind
direction, cm
R - ideal gas constant, 62,300 mmHg»cm3/g mol»K
T = ambient temperature, K
D-i = diffusivity of volatilizing constituent in air, cm2/s
1 =? length of volatilizing surface parallel to the wind direction
cm
C-12
-------
U = windspeed, cm/s
Fv = correction factor for Pick's law
•K = 3.1416.
C.I. 1.4. 3 Tank storage. Stationary, fixed-roof tank working losses
are those created by loading and unloading wastes and are estimated using
AP-42, "Storage of Organic Liquids":20
Lw = 1.09 x 10
"8
x My x P x V x Kn x Kc
(C-9)
where
Lw = working losses, Mg/yr (the AP-42 constant of 2.4 x 10"2 is
converted to 1.09 x 10~8 to convert Ib/gal throughput to Mg/yr)
Mv = molecular weight of vapor in tank, Ib/lb mol
P = true vapor pressure at bulk liquid conditions, psia
V = throughput, gal/yr
Kn = turnover factor, dimensionless
Kc = product factor, dimensionless.
There are also "breathing" losses for a fixed-roof tank caused by
temperature and pressure changes. An existing AP-422^ equation is used to
estimate these emissions:
Lb = 1.02 x 10
"5
M
[ 14 P p] o.
^xD^xH^xAT0'5
(C-10)
x F x C x KC
where
Lt, = fixed-roof breathing loss, Mg/yr (the AP-42 constant of 2.26 x
10"2 is converted to 1.02 x 10~5 to convert Ib/gal thoughput to
Mg/yr)
Mv = molecular weight, Ib/lb mol
P = true vapor pressure, psia
D = tank diameter, ft
H = average vapor space height, ft
C-13
-------
AT s average ambient diurnal temperature change, °F
Fp = paint factor, dimensionless
C = adjustment factor for small diameter tanks, dimensionless
Kc = product factor, dimensionless.
These equations originally were developed for handling organic liquids in
industries producing or consuming organic liquids, but are used here for
TSDF tank storage.
C.I.1.4.4 Equipment leaks. Emissions from equipment leaks are those
resulting from leaks in equipment that is used to control pressure, provide
samples, or transfer pumpable organic hazardous waste. The emissions from
equipment leaks in hazardous waste management are dependent on the number
of pump seals, valves, pressure relief devices, sampling connections, open-
ended lines, and the volatility of the wastes handled. The emission-
estimating model used for TSDF equipment leaks is independent of the
throughput, type, or size of the process unit. The TSDF equipment leak
emission model is based on the Synthetic Organic Chemical Manufacturing
Industries (SOCMI) emission factors developed to support standard SOCMI
equipment leak emission standards.22 The input parameters required for the
equipment leak emission model begin with the emission factor for the equip-
ment pieces such as pump seals, the number of sources, and the residence
time of the waste in the equipment. It was assumed that with no purge of
waste from the equipment when the equipment is not in use, organics are
continuously being leaked to the atmosphere. Section C.2, "Model Unit
Description," explains the selection process for the number of emission
sources used to develop the equipment model units.
C.I.2 Comparison of Emission Estimates with Test Results
Predictions from TSDF emission models have been compared with field
test data. The following sections summarize qualitatively the comparative
results that are discussed in detail in Chapter 8.0 of the TSDF air emis-
sion models report. Actual field test data are presented in Appendix F.
This comparison was made with the knowledge that some uncertainty in field
test precision and accuracy and the empirical nature of emission models
must be considered.
C-14
-------
C.I.2.1 Surface Impoundments and Uncovered Tanks Comparison. Emis-
sion test data were available for five quiescent surface impoundments. The
overall mass transfer coefficients determined in these tests agreed within
an order of magnitude with the overall coefficient predicted by the mass
transfer correlations. Predicted emissions for these impoundments using
the March 1987 version of the air emission models were higher than the
measured emissions in some cases and lower in others.
When predicted emission estimates were compared to uncovered tank
measured emissions, the results were mixed. For quiescent tanks, the
predicted emissions were generally lower than measured emissions but agreed
within an order of magnitude. For the aerated systems, the model predic-
tions agreed well with material balance and ambient air measurements for an
open aerated system.
C.I.2.2 Land Treatment. Field test data from four sites and one
laboratory simulation were used as a basis of comparison with estimates
from the land treatment emission model (see Section C.I.1.2). Estimated
and measured emissions were within an order of magnitude. Estimates of
both emission flux rates and cumulative emissions show results above and
below measured values. Considering the potential for error in measuring or
estimating values for input parameters, differences in the range of an
order of magnitude are not unexpected. The emission test reports did not
provide complete sets of model input data; therefore, field data averages,
averages from the TSDF data base, or values identified elsewhere as repre-
sentative were used as model inputs.
C.I.2.3 Landfills and Wastepiles. Comparisons between predicted and
measured emissions from a landfill are of limited value because of lack of
detailed, site-specific soil, waste, and landfill operating parameters.
Typically, the composition of the landfilled waste.and other required
inputs to the emission models, such as the porosity of the landfill cap and
the barometric pumping rate, were not included in the field test data.
Comparisons of model emissions were made to measured emissions from two
active landfills. The modeled emissions were found to be higher than field
test measurements, in general, by factors ranging from 1 to 2 orders of
magnitude. No test data were available for wastepiles.
C-15
-------
C.I.2.4 Transfer, Storage, and Handling Comparison. Emission models
for transfer, storage, and handling operations are based on extensive
testing that led to AP-4223 emission models and to models developed for the
petroleum industry and SOCMI. The following models were developed in the
petroleum industry and are applied to TSDF:
• Container loading (AP-42, Section 4.4)
• Stationary covered tank loading-(AP-42, Section 4.3)
• Stationary covered tank storage (AP-42, Section 4.3).
Equipment leak emission factors are drawn from the study of organics
leak control at SOCMI facilities. Test data supporting the SOCMI equipment
leak emission standard24 were collected to develop these factors. An EPA
study2^ of truck transport to and from TSDF and truck emissions at TSDF
terminals provided information for spillage loss estimates. No test data
were available for comparison in this TSDF effort.
C.I.3 Sensitivity Analysis
The emission models have been evaluated to determine which parameters
have the greatest impacts on emissions. A brief discussion follows on the
important model parameters for the four major types of TSDF processes: (1)
surface impoundments and uncovered tanks, (2) land treatment, (3) landfills
and wastepiles, and (4) transfer, storage, and handling operations. Input
parameters were varied individually over the entire range of reasonable
values in order to generate emission estimates. A full discussion of the
emission model sensitivity analysis is presented in the TSDF air emission
models report.
C.I.3.1 Surface Impoundments and Uncovered Tanks. Parameters to
which emission estimates are most sensitive include waste concentration,
retention time, windspeed for quiescent systems, fetch to depth, and
biodegradation.
The emission estimates for highly volatile constituents (as defined in
Appendix D, Section D.2.3.3.1) are sensitive to short retention times. For
retention times on the order of several days, essentially all high vola-
tiles are emitted. In impoundments, significant emissions of medium vola-
tiles (as defined in Appendix D, Section D.2.3.3.1) may occur over long
_
C-16
-------
retention times. Henry's law constant has a direct effect on emissions of
medium volatiles and a greater effect on relatively low volatile organics
for which mass transfer is controlled by the gas-phase resistance.
Temperature did not affect emission estimates of' the highly volatile
constituents, although mass transfer for low volatile constituents was
affected because of the temperature dependence of Henry's law constant.
Diffusivity in air and water did not affect emission estimates.
Physical parameters of aerated systems, such as kilowatts (horsepower)
and turbulent area, did affect emission estimates of medium volatiles,
although highly volatile constituents were unaffected. High volatiles are
stripped out almost completely under any aerated condition.
C.I.3.2 Land Treatment. Air emissions from land treatment units are
dependent on the chemical/physical properties of the organic constituents,
such as vapor pressure, diffusivity, and biodegradation rate.
Operating and field parameters affect the emission rate, although
their impact is not as great as that of constituent properties. Tilling
depth, for example, plays a role; the deeper the tilling depth, the greater
the time required for diffusion to the surface and therefore the greater is
the potential for organics to be biodegraded. Waste concentration and
waste loading (the amount of material applied to the soil per unit area)
affect the emission rate on a unit area basis (emissions per unit area),
but not in terms of the mass of organics disposed of (emissions per unit
mass of waste).
C.I.3.3 Landfills and Wastepiles. Emissions from active (open)
landfills, those still receiving wastes, are estimated by applying the RTI
land treatment model. The sensitivity of the land treatment model to some
parameters differs in its application to open landfills and wastepiles from
that in land treatment operations. For application to open landfills and
wastepiles, the model is sensitive to the air porosity of the solid waste,
the liquid loading in the solid waste, the waste depth, the concentration
of the constituent in the waste, and the volatility of the constituent
under consideration. In contrast, the model is less sensitive to the
diffusion coefficient of the constituent in air.
Emissions from closed landfills, those filled to design capacity and
with a cap (final cover) installed, are estimated using the closed landfill
C-17
-------
model. The model is highly sensitive to the air porosity of the clay cap,
which largely determines the diffusion rate through the cap. The model is
also sensitive to the properties of the constituent of interest, particu-
larly vapor pressure, Henry's law constant, and concentration. In con-
trast, the model exhibits relatively low sensitivity to the diffusiveness
of the constituent in air, the cap thickness, and the total mass of
constituent in the landfill.
C.I.3.4 Transfer. Storage, and Handling Operations. Equipment leak
emission estimates are a function of the number of pump seals, valves,
pressure-relief valves, open-ended lines, and sampling connections selected
for given process rather than throughput rate. However, equipment leak
frequencies and leak rates have been shown to vary with stream volatility;
emissions for high-volatility streams are greater than those for streams of
low volatility.
Loading emission estimates are also sensitive to the volatility of the
constituents. Both loading and spill emissions are directly proportional
to throughput. The loading emission estimates for open aqueous systems,
such as impoundments and uncovered tanks, are highly sensitive to the type
of-loading, which is either submerged or splash loading.
The fraction of waste spilled and waste throughput are used to
estimate emissions resulting from spills.
C.2 MODEL TSDF WASTE MANAGEMENT UNIT ANALYSES
To evaluate the effectiveness (emission reductions) and costs of
applying various types of control technologies (discussed in Chapter 4.0)
to reduce emissions from waste management process units, a model unit anal-
ysis was performed. Hazardous waste management model units and model waste
compositions were input to the emission models discussed above to generate
uncontrolled emissions estimates from which emission reductions were com-
puted. The model units and model waste compositions also served as the
bases for estimating add-on and suppression-type control costs for each
applicable control technology. Appendix H presents a discussion of the
costing of add-on and suppression-type controls.
The development of.model units, selection of model waste compositions
and the results of the analyses of emission reductions and control costs
are discussed in the following sections.
C-18
-------
C.2.1 Model Unit Descriptions
Sets of model units were developed to represent the range of sizes and
throughputs of hazardous waste management processes. For each model unit,
parameters needed as input to the emission models were specified. The
following paragraphs provide the sources of information and rationale used
in developing the model units. Discussions are presented as four categor-
ies, each containing waste management processes with similar emission char-
acteristics.
Multiple model units were developed for each waste management process
to describe the nationwide range of characteristics (surface area,, waste
throughputs, retention time, etc.). This was determined using the
frequency distributions of quantity processed, unit size, or unit area of
each waste management process that were results of the Westat Survey. The
distributions (expressed as weighting factors for the SAM) are presented
with the tabular listing of model units in this section. The distributions
were used to develop a "national average model unit" to represent each
waste management process when using the Source Assessment Model. Each
frequency serves as a weighting factor to approximate a national distri-
bution of the model units defined for a particular TSDF waste management
process. Appendix D, Section D.2.4.3, describes these weights and the
approach to estimating nationwide organic air emissions in greater detail.
C.2.1.1 Surface Impoundments and Uncovered Tanks. Hazardous waste
surface impoundment storage, treatment, and disposal model units are dis-
played in Table C-l. The ranges of surface areas and depths were based on
results of the National Survey of Hazardous Waste Generators and Treatment,
Storage, and Disposal Facilities Regulated Under RCRA in 1981 (Westat
Survey).26 The median surface area for storage and treatment impoundments
in the Westat Survey was 1,500 m2 and the median depth was 1.8 m. Three
model unit surface areas and depths were chosen for storage and treatment
impoundments, representing the medians and spanning the representative
ranges of sizes for each parameter. The Westat Survey data summary for
impoundments indicated that disposal impoundments generally have higher
surface areas and shallower depths than storage and treatment impoundments.
The model disposal impoundment was designed with the Westat Survey median
surface area of 9,000 m2 and the median depth of approximately 1.8 m.
C-19
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TABLE C-l. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE SURFACE IMPOUNDMENT AND
UNCOVERED TANK MODEL UNITS3
Model unit (weights,13 %)
Parameters0
Surface impoundment storage
S04A Quiescent impoundment
S04B Quiescent impoundment
(S04A and B = 38.3)
S04C Quiescent impoundment
S04D Quiescent impoundment
(S04C and D = 35.9)
Throughput - 99,000 Mg/yr
Surface area - 300 m2
Depth - 0.9 m
Volume - 270 m3
Retention time - 1 d
Flow rate - 3.1 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 9,800 Mg/yr
Surface area - 300 m2
Depth - 0.9 m
Volume - 270 m3
Retention time - 10 d
Flow rate - 0.31 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 49,000 Mg/yr
Surface area - 1,500 m2
Depth - 1.8 m
Volume - 2,700 m3
Retention time - 20 d
Flow rate - 1.6 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 25,000 Mg/yr
Surface area - 1,500 m2
Depth - 1.8 m
Volume - 2..700 m3
Retention time - 40 d
Flow rate - 0.78 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
See notes at end of table.
(continued)
C-20
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TABLE C-l. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE SURFACE IMPOUNDMENT AND
UNCOVERED TANK MODEL UNITS3 (continued)
Model unit (weights,b %)
Parameters0
Surface impoundment storage (con.)
S04E Quiescent impoundment
S04F Quiescent impoundment
(S04E and F = 25.9)
y
Surface impoundment treatment
T02A Quiescent impoundment with
no biodegradation
T02B Quiescent impoundment with
no biodegradation
(T02A and B = 31.2)
Throughput - 120,000 Mg/yr
Surface area - 9,000 m2
Depth - 3.7 m
Volume 33,000 m3
Retention time - 100 d
Flow rate - 3.8 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 67,000 Mg/yr
Surface area - 9,000 m2
Depth - 3.7 m
Volume - 33,000 m3
Retention time - 180 d
Flow rate - 2.1 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 200,000 Mg/yr
Surface area - 300 m2
Depth - 0.9 m
Volume - 270 m3
Retention time - 0.5 d
Flow rate - 6.3 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 20,000 Mg/yr
Surface area - 300 m2
Depth - 0.9 m
Volume - 270 m3
Retention time - 5 d
Flow rate - 0.63 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
See notes at end of table.
(continued)
C-21
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TABLE C-l. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE SURFACE IMPOUNDMENT AND
UNCOVERED TANK MODEL UNITS9 (continued)
Model unit (weights,b %)
Parameters0
Surface impoundment treatment (con.)
T02C Quiescent impoundment with
no biodegradation
T02D Quiescent impoundment with
no biodegradation
(T02C and D = 35.6)
T02E Quiescent impoundment with
no biodegradation
T02F Quiescent impoundment with
no biodegradation
(T02E and F = 33.3)
Throughput - 990,000 Mg/yr
Surface area - 1,500 m2
Depth - 1.8 m
Volume - 2,700 m3
Retention time -Id
Flow rate - 31 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 99,000 Mg/yr
Surface area - 1,500 m2
Depth - 1.8 m
Volume - 2,700 m3
Retention time - 10 d
Flow rate - 3.1 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 608,000 Mg/yr
Surface area - 9,000 m2
Depth - 3.7 m
Volume - 33,000 m3
Retention time - 20 d
Flow rate - 19 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 302,000 Mg/yr
Surface area - 9,000 m2
Depth - 3.7 m
Volume - 33',000 m3
Retention time - 40 d
Flow rate - 9.6 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
See notes at end of table.
(continued)
C-22
-------
TABLE C-l. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE SURFACE IMPOUNDMENT AND
UNCOVERED TANK MODEL UNITS3 (continued)
Model unit (weights,b %)
Parameters0
Surface impoundment treatment (con.)
T02G Aerated/agitated impoundment
with biodegradation
T02H Aerated/agitated impoundment
with biodegradation
(T02G and H = 31.2)
Throughput - 200,000 Mg/yr
Surface area - 300 m2
Depth - 0.9 m
Volume - 270 m3
Retention time - 0.5 d
Flow rate - 6.3 L/s
Turbulent area - 63 m2
Total power - 5.6 kW (7.5 hp)
Impeller power - 4.8 kW (6.4
Impeller speed - 130 rad/s
Impeller diameter - 61 cm
0? transfer - 1.83 kg/kW/h
13 Ib/hp/h)
02 correction factor
Biomass concentration
Temperature - 25 °C
Windspeed - 4.5 m/s
hp)
0.83
0.5 g/L
Throughput - 20,000 Mg/yr
Surface area - 300 m2
Depth - 0.9 m
Volume - 270 m3
Retention time - 5 d
Flow rate - 0.63 L/s
Turbulent area - 63 m2
Total power - 5.6 kW (7.5 hp)
Impeller power - 4.8 kW (6.4 hp)
Impeller speed - 130 rad/s
Impeller diameter - 61 cm
0? transfer - 1.83 kg/kW/h
13 Ib/hp/h)
02 correction factor - 0.83
Biomass concentration - 0.5 g/L
Temperature. - 25 °C
Windspeed - 4.5 m/s
See notes at end of table.
(continued)
C-23
-------
TABLE C-l. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE SURFACE IMPOUNDMENT AND
UNCOVERED TANK MODEL UNITS3 (continued)
Model unit (weights,b %)
Parameters0
Surface impoundment treatment (con.)
T02I Aerated/agitated impoundment Throughput - 990,000 Mg/yr
t«i*i T* h r\T^\rt^^/^w\^*J^^^**»^ r*.. c___ _____ "t *•*>** O
with biodegradation
T02J
Aerated/agitated impoundment
with biodegradation
Surface area - 1,500 m
Depth - 1.8 m
Volume - 2,700 m3
Retention time - 1 d
Flow rate - 31 L/s
Turbulent area - 370 m2
Total power - 56 kW (75 hp)
Impeller power - 48 kW (64 hp)
Impeller speed - 130 rad/s
Impeller diameter - 61 cm
0? transfer - 1.83 kg/kW/h
(3 Ib/hp/h)
02 correction factor - 0.83
Biomass concentration - 0.5 g/L
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 99,000 Mg/yr
Surface area - 1,500 m^
Depth - 1.8 m
Volume - 2,700 m3
Retention time - 10 d
Flow rate - 3.1 L/s
Turbulent area - 370 m2
Total power - 56 kW (75 hp)
Impeller power - 48 kW (64 hp)
Impeller speed - 130 rad/s
Impeller diameter - 61 cm
0? transfer - 1.83 kg/kW/h
(3 Ib/hp/h)
02 correction factor - 0.83
Biomass concentration - 0.5 g/L
Temperature - 25 °C
Windspeed - 4.5 m/s
(T02I and J = 35.6)
See notes at end of table.
(continued)
C-24
-------
TABLE C-l. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE SURFACE IMPOUNDMENT AND
UNCOVERED TANK MODEL UNITS3 (continued)
Model unit (weights,b %)
Parameters0
Surface impoundment treatment (con.)
T02K Aerated/agitated impoundment
with biodegradation
T02L Aerated/agitated impoundment
with biodegradation
(T02K and L = 33.3)
Surface impoundment disposal
D83A Quiescent impoundment with
no biodegradation (100)
Throughput - 608,000 Mg/yr
Surface area - 9,000 m2
Depth - 3.7 m
Volume - 33,000 m3
Retention time - 20 d
Flow rate - 19 L/s
Turbulent area - 2,700 m2
Total power - 671 kW (900 hp)
Impeller power - 574 kW (85 hp)
Impeller speed - 130 rad/s
Impeller diameter - 61 cm
0? transfer - 1.83 kg/kW/h
13 Ib/hp/h)
02 correction factor - 0.83
Biomass concentration - 0.5 g/L
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 302,000 Mg/yr
Surface area - 9,000 m2
Depth - 3.7 m
Volume - 33,000 m3
Retention time - 40 d
Flow rate - 9.6 L/s
Turbulent area - 2,700 m2
Total power - 671 kW (900 hp)
Impeller power - 574 kW (85 hp)
Impeller speed - 130 rad/s
Impeller diameter - 61 cm
0? transfer - 1.83 kg/kW/h
(3 Ib/hp/h)
02 correction factor - 0.83
Biomass concentration - 0.5 g/L
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 32,000 Mg/yr
Surface area - 9,000 m2
Depth - 1.8 m
Volume - 16,000 m3
See notes at end of table.
(continued)
C-25
-------
TABLE C-l. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE SURFACE IMPOUNDMENT AND
UNCOVERED TANK MODEL UNITS9 (continued)
Model unit (weights,13 %)
Parameters0
Surface impoundment disposal (con.)
Storage tanks
S02F Uncovered tank (37.7)
S02G Uncovered tank (Od)
S02H Uncovered tank (32.3)
S02I Uncovered tank (17.8)
S02J Uncovered tank (12.2)
See notes at end of table.
Retention time - 183 d
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 110 m3/yr
Surface area - 2.3 m2
Depth - 2.4 m
Volume - 5.3 m3
Retention time - 18.3 d
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 60 m3/yr
Surface area - 13 m2
Depth - 2.4 m
Volume - 30 m3
Retention time - 183 d
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 1,100 m3/yr
Surface area - 13 m2
Depth - 2.4 m
Volume - 30 m3
Retention time - 9.9 d
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 3,300 m3/yr
Surface area - 26 m2
Depth - 2.7 m
Volume - 76. m3
Retention time - 8.3 d
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 17,000 m3/yr
Surface area - 65 m2
Depth - 12 m
Volume - 800 m3
Retention time - 17.4 d
Temperature - 25 °C
Windspeed - 4.5 m/s
C-26
(continued)
-------
TABLE C-l. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE SURFACE IMPOUNDMENT AND
UNCOVERED TANK MODEL UNITSa (continued)
Model unit (weights,13 %)
Parameters0
Treatment tanks
T01A
Uncovered quiescent tank
(28.3)
T01B
Uncovered quiescent tank
(21.8)
T01C
Uncovered quiescent tank
(50.0)
T01G
Uncovered aerated/agitated
tank (78.3)
Throughput - 11,000 Mg/yr
Surface area - 13 m2
Depth - 2.4 m
Volume - 30 m3
Retention time - 24 h
Flow rate - 0.35 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 28,000 Mg/yr
Surface area - 26 m2
Depth - 2.7 m
Volume - 76 m3
Retention time - 24 h
Flow rate - 0.88 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Mg/yr
Throughput - 290,OOC
Surface area - 65 m^
Depth - 12 m
Volume - 800 m3
Retention time - 24
Flow rate - 9.2 L/s
Temperature - 25 °C
Windspeed - 4.5 m/s
Throughput - 240,000 Mg/yr
Surface area - 27 m2
Depth -4m
Volume - 108 m3
Retention time
Flow rate - 7.5 L/s
Turbulent area - 14 m2
Total power - 5.6 kW (7
Impeller power - 4.8 kW
Impeller speed
- 4 h
5 hp)
(6.4 hp)
130 rad/s
Impeller diameter - 61 cm
0? transfer - 1.83 kg/kW/h
(3 Ib/hp/h)
02 correction factor - 0.83
Biomass concentration - 4.0 g/L
Temperature - 25 °C
Windspeed - 4.5 m/s
C-27
(continued)
-------
TABLE C-l. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE SURFACE IMPOUNDMENT AND
UNCOVERED TANK MODEL UNITS9 (continued)
Model unit (weights,b %)
Parameters0
Treatment tanks (con.)
T01H Uncovered aerated/agitated
tank (21.8)
Throughput - 2,800,000 Mg/yr
Surface area - 430 m2
Depth - 3.7 m
Volume - 1,600 m3
Retention time - 5 h
Flow rate - 88 L/s
Turbulent area - 250 m2
Total power - 89.5 kW
(120 hp)
Impeller power - 38 kW (51 hp)
Impeller speed - 130 rad/s
Impeller diameter - 61 cm
0? transfer - 1.83 kg/kW/h
(3 Ib/hp/h)
Og correction factor - 0.83
Biomass concentration - 4.0 g/L
Temperature - 25 °C
Windspeed - 4.5 m/s
Hazardous waste surface impoundment and uncovered tank model units repre-
sent the ranges of uncovered, quiescent, and aerated surface storage,
treatment, and disposal surface impoundments and storage and treatment
tanks in the hazardous waste management industry.
bBecause design characteristics and operating parameters (surface area,
waste throughputs, detention times, and so on) were generally not avail-
able for all treatment, storage, and disposal facilities (TSDF),
weighting factors were developed to approximate the nationwide distri-
bution of model units defined for a particular TSDF waste management
process. The weighting factors are based on the considerable statistical
data available in the 1981 EPA survey of hazardous waste generators and
TSDF conducted by Westat, Inc. (Westat Survey). For example, results of
this survey were used to determine the national distribution of sizes of
storage tanks (storage volume), surface impoundments (surface area) and
landfills (surface area and depth). For further information on weighting
factors, refer to Appendix D, Sections D.2.4.3 and D.2.5.
cModel unit parameters may not be equal (e.g., Throughput j4 Volume x
Turnovers) because of rounding.
dThis model unit was weighted 0% because S02H also has the same surface
area. This avoids double weighting of a unit siz,e.
C-28
-------
Retention times in the Westat Survey ranged from 1 to 550 days, with
over half of the values at 46 days or less. The storage impoundment model
unit retention times, ranging from 1 to 180 days, were chosen to span the -.
reasonable range of values, based on knowledge of the operation of impound-
ments that are representative of the industry. Retention times greater
than 180 days were not used to estimate emissions because organics are
emitted from a surface impoundment within 180 days. The retention time in
treatment impoundments was expected to be less than the retention times in
storage impoundments. Two design manuals listed typical retention times
for aerated impoundments as 7 to 20 days27 and 3 to 10 days.28 Retention
times bounding these ranges were chosen for the quiescent and aerated/
agitated impoundments. No data were available concerning disposal surface
impoundment retention times; therefore, the disposal surface impoundment
was selected with a 6-month retention time or the time within which the
organics would be emitted. Volume for each surface impoundment model unit
was calculated from area and depth; the retention time yielded the flow
rate.
Two meteorological parameters required for the emission models were
temperature and windspeed. The parameters chosen were a standard tempera-
ture of 25 °C and a windspeed of 4.5 m/s. These standard values were eval-
uated by estimating emissions from surface impoundments for windspeed/
temperature combinations at actual sites based on their frequency of
occurrence. Over a 1-yr period, the results from site-specific data on
windspeed and temperature were not significantly different from the results
using the standard values. Consequently, the standard values were judged
adequate for the model units.
With regard to the aerated/agitated treatment impoundments, one
source, Metcalf and Eddy,29 suggests a range of 0.37 to 0.75 kW/28.3 m3
(0.5 to 1.0 hp/1,000 ft3) for mixing. However, more power may be needed to
supply additional oxygen or to mix certain treatment solutions. Informa-
tion obtained through site visits to impoundments indicates power usage as
high as 2.6 kW/28.3 m3 (3.5 hp/1,000 ft3) at a specific TSDF impoundment.30
For this analysis, a midrange value of 0.56 kW/28.3 m3 (0.75 hp/1,000 ft3)
from Metcalf and Eddy, was used to generate estimates of the power required
for mixing in each model unit.
C-29
-------
Data from Reference 31 indicate that an aerator with a 56-kW (75-hp)
motor and a 61-cm-diameter propeller turning at 126 rad/s would agitate a
volume of 660 m3. Agitated volumes were estimated by holding propeller
diameter and rotation constant and treating agitated volume as being pro-
portional to power. The agitated volume divided by depth yielded the agi-
tated surface area, which was modeled as turbulent area. Typical values
were chosen for the oxygen transfer rating of the aerator and the oxygen
transfer correction factor. A value of 1.83 kg 02/kW/h (3.0 Ib 02/hp/h)
was chosen for the oxygen transfer rating from a range of 1.76 to 1.83 (2.9
to 3.0),32 A value of 0.83 was used for the correction factor from a typi-
cal range of 0.80 to 0.85.33 For estimating the impeller power, an
85-percent efficient transfer of power to the impeller was used.34 A
midrange biomass concentration for continuous stirred tank reactors was
chosen from Reference 35. A biomass concentration of 0.5 g/L was chosen as
an estimate, representing an upper bound on the design guidelines in
References 36 and 37.
Table C-l also presents uncovered, quiescent and aerated/agitated
hazardous waste treatment tank model units. According to responses to the
1981 EPA survey of hazardous waste generators and TSDF conducted by Westat,
Inc. (Westat Survey),38 there are four sizes of tanks that best represent
the waste management industry: 5.3 m3, 30 m3, 76 m3, and 800 m3. The
quiescent storage and treatment tank model units were sized accordingly.
Retention times were chosen to span the retention times commonly used
by wastewater treatment tank units.39 jhe retention times and tank capaci-
ties were used to arrive at flow rates for the model units. These flow
rates are comparable to those found in the EPA survey conducted by Westat
for medium and large wastewater treatment tanks. The remaining physical
parameters for quiescent treatment tanks were chosen on the basis of
engineering judgment. Meteorological conditions cited for quiescent and
aerated tanks represent standard annual (temperature and windspeed) and
daily (temperature change) values.
For aerated/agitated treatment tanks, the agitation parameters for the
aerated, biologically active tanks were derived as described previously for
aerated/agitated surface impoundments.
C-30
-------
C.2.1.2 Land Treatment. Table C-2 displays hazardous waste land
treatment model units. Model unit parameters were based primarily on a
data base developed by EPA40 from site visits and contacts with State,
regional, and industry sources and supplemented by information from recent
literature. These values were chosen as reasonably representative of aver-
age or typical practices currently used at land treatment operations. The
data base showed annual throughput varying from about 2 Mg/yr to about
400,000 Mg/yr with a median value of 1,800 Mg/yr. The area of land treat-
ment sites ranged from less than 1 ha to about 250 ha with a median value
of 5 ha. These two median values were selected to develop the model units.
The data base showed tilling depth varying from 15 cm to one case of 65 cm,
with most being in the range of 15 to 30 cm. The single most frequently
reported tilling depth was 20 cm, which was selected as a typical value.
This value is in line with values of 15 to 30 cm reported in another
study.41 The data base showed oil content of the waste streams varying
from about 2 to 50 percent, with a median value of about 12 percent and
model value of 10 percent. The 10-percent figure was selected as typical.
Very little soil porosity information has been identified. One study
reported measured values of soil porosity in a land treatment plot as rang-
ing from 43.3 to 65.1 percent42 with an average value of about 50 percent.
The literature did not specify whether this soil porosity represented total
soil porosity or soil air porosity. Therefore, these literature values
were chosen to represent soil air porosity. Total soil porosity included
the air porosity and the space occupied by oil and water within soil. One
field study reported measured values of both total porosity and air-filled
porosity.43 Measured values of total soil porosity ranged from 54.7 to
64.8 percent, with an average value of 60.7 percent. Measured values of
air-filled porosity ranged from 27.4 to 46.9 percent, with an average of
37.2 percent. Thus, the value of 61 percent for total soil porosity was
chosen to be a representative value based on the median measured total soil
porosity of 60.7 percent. A value of 50 percent was used as a default for
air porosity.
C.2.1.3 Waste Fixation, Hastepiles/ and Landfills. As part of the
landfill operation, fixation model units were developed. Table C-3 shows
hazardous waste fixation pit model units. The fixation pit has a length of
C-31
-------
TABLE C-2. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE LAND TREATMENT
MODEL UNITS9
Model unit (weights,b %)
Parameters
D81A (NA)
D81B (NA)
D81C (NA)
D81D (NA)
Throughput - 360 Mg/yr
Land areac - 1 ha
Oil content of waste - 10%
Soil air porosity - 0.5
Soil total porosity - 0.61
Tilling depth - 20 cm
Temperature - 25 °C
Throughput - 1,800 Mg/yr
Land area0 - 5 ha
Oil content of waste - 10%
Soil air porosity - 0.5
Soil total porosity - 0.61
Tilling depth - 20 cm
Temperature - 25 °C
Throughput - 5,400 Mg/yr
Land areac - 15 ha
Oil content of waste - 10%
Soil air porosity - 0.5
Soil total porosity - 0.61
Tilling depth - 20 cm
Temperature - 25 °C
Throughput - 27,000 Mg/yr
Land areac - 75 ha
Oil content of waste - 10%
Soil air porosity - 0.5
Soil total porosity - 0.61
Tilling depth - 20 cm
Temperature - 25 °C
NA - Not applicable.
Hazardous waste land treatment model units represent the range of land
treatment processes in the hazardous waste management industry.
Weighting factors were developed for each unit to represent each waste
management process when estimating nationwide emissions. These factors
are based on frequency distributions of quantity processed, unit size or
unit area that were results of the Westat Survey, approximately a national
distribution of model units.
cWaste is applied only to one-half of the land area based on knowledge of
industry practice, allowing the undisturbed area to stabilize.
C-32
-------
TABLE C-3. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE FIXATION PIT, WASTEPILE STORAGE,
AND LANDFILL DISPOSAL MODEL UNITS3
Model unit (weights,b %)
Parameters
Fixation pit
Fixation pit A (46.0)
Fixation pit B (14.9)
Throughput - 17,000 Mg/yr
fixed waste
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Fixed waste density - 1.8 g/cm3
Number of pits - 1
Pit surface dimensions - 3x6 m
Pit depth -3m
Number of batches - 160/yr
Windspeed - 4.5 m/s
Wind direction - along length of
pit
Temperature = 25 °C
Duration of fixation - 2 h
Throughput - 120,000 Mg/yr
fixed waste
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Fixed waste density - 1.8 g/cm3
Number of pits - 2
Pit surface dimensions - 3x6 m
Pit depth -3m
Number of batches - 1,200/yr
Windspeed - 4.5 m/s
Wind direction - along length of
pit
Temperature - 25 °C
Duration of fixation - 2 h
See notes at end of table.
(continued)
C-33
-------
TABLE C-3. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE FIXATION PIT, WASTEPILE STORAGE,
AND LANDFILL DISPOSAL MODEL UNITS3 (continued)
Model unit (weights,b %)
Parameters
Fixation pit (con.)
Fixation pit C (39.2)
Hastepile
S03D Wastepile (41.5)
Throughput - 170,000 Mg/yr
fixed waste
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Fixed.waste density - 1.8 g/cm3
Number of pits - 4
Pit surface dimensions - 3x6 m
Pit depth -3m
Number of batches - 1,600/yr
Windspeed - 4.5'm/s
Wind direction - along length of
pit
Temperature - 25 °C
Duration of fixation - 2 h
Throughput - 17,000 Mg/yr
Surface area - 46 m2
Average height - 0.77 m
Volume - 35 m3
Waste density - 1.8 g/cm3
Turnovers - 300/yr
Retention time - 1.2 days
Temperature - 25 °C
Windspeed - 4.5 m/s
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Total porosity fixed waste - 0.50
Air porosity fixed waste - 0.25
Biomass concentration - 0 g/cm3
See notes at end of table.
(continued)
C-34
-------
TABLE C-3. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE FIXATION PIT, WASTEPILE STORAGE,
AND LANDFILL DISPOSAL MODEL UNITS3 (continued)
Model unit (weights,b %)
Parameters
Wastepile (con.)
S03E Wastepile (36-.0)
S03F Wastepile (22.5)
Throughput - 120,000 Mg/yr
Surface area - 470 m2
Average height -1m
Volume - 470 m3
Waste density - 1.8 g/cm3
Turnovers - 140/yr
Retention time - 2.6 days
Temperature - 25 °C
Windspeed - 4.5 m/s
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Total porosity fixed waste - 0.50
Air porosity fixed waste - 0.25
Biomass concentration - 0 g/cm3
Throughput - 170,000 Mg/yr
Surface area - 14,000 m2
Average height -4m
Volume - 56,000 m3
Waste density - 1.8 g/cm3
Turnovers - 1.6/yr
Retention time - 220 days
Windspeed - 4.5 m/s
Temperature - 25 °C
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Total porosity fixed waste - 0.50
Air porosity fixed waste - 0.25
Biomass concentration - 0 g/cm3
See notes at end of table.
(continued)
C-35
-------
TABLE C-3. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE FIXATION PIT, WASTEPILE STORAGE
AND LANDFILL DISPOSAL MODEL UNITS9 (continued)
Model unit (weights,b %)
Parameters
Landfill disposal
D80D Active landfill (46.0)
D80E Active landfill (14.9)
D80F Active landfill (39.2)
Surface area - 0.4 ha
Depth of waste - 1.1 m
Degree of filling - half full
Ambient temperature - 25 °C
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste.
Total porosity of fixed
waste - 0.50
Air porosity of fixed
waste - 0.25
Biomass cone. - 0 g/cm3
Surface area - 1.4 ha
Depth of waste - 2.3 m
Degree of filling - half full
Ambient temperature - 25 °C
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Total porosity of fixed
waste - 0.50
Air porosity of fixed
waste - 0.25
Biomass cone. - 0 g/cm3
Surface area - 2 ha
Depth of waste - 2.3 m
Degree of filling - half full
Ambient temperature - 25 °C
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Total porosity of fixed
waste - 0.50
Air porosity of fixed waste - 0.25
Biomass cone. - 0 g/cm3
See notes at end of table.
(continued)
C-36
-------
TABLE C-3. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE FIXATION PIT, WASTEPILE STORAGE,
AND LANDFILL DISPOSAL MODEL UNITS3 (continued)
Model unit (weights,13 %)
Parameters
Landfill disposal (con.)
D80G Closed landfill (46.0)
D80H Closed landfill (14.9)
Surface area - 0.4 ha
Waste bed thickness - 2.3 m
Cap thickness - 110 cm
Total porosity of cap - 0.41
Air porosity of cap - 0.08
Temperature beneath cap - 15 °C
Typical barometric pressure -
1.01 x ID'5 Pa (1,013 mbar)
Daily barometric pressure drop -
4.0 x 10~8 Pa (4 mbar)
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Air porosity of fixed waste -
0.25
Biomass cone. - 0 g/cm3
Surface area - 1.4 ha
Waste bed thickness - 4.6 m
Cap thickness - 110 cm
Total porosity of cap - 0.41
Air porosity of cap - 0.08
Temperature beneath cap - 15 °C
Typical barometric pressure -
1.01 x ID'5 Pa (1,013 mbar)
Daily barometric pressure drop -
4.0 x 10~8 Pa (4 mbar)
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Air porosity of fixed waste -
0.25
Biomass cone. - 0 g/cnn
See notes at end of table.
(continued)
C-37
-------
TABLE C-3. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE FIXATION PIT, WASTEPILE STORAGE
AND LANDFILL DISPOSAL MODEL UNITS3 (continued)
Model unit (weights,b %)
Parameters
Landfill disposal (con.)
D80I Closed landfill (39.2)
Surface area - 2 ha
Waste bed thickness - 4.6 m
Cap thickness - 110 cm
Total porosity of cap - 0.41
Air porosity of cap - 0.08
Temperature beneath cap - 15 °C
Typical barometric pressure -
1.01 x 10-5 Pa (1,013 mbar)
Daily barometric pressure drop -
4.0 x ID'8 Pa (4 mbar)
Liquid/fixative - 1 cm3 liquid +
fixative = 1 cm3 fixed waste
Air porosity of fixed waste -
0.25
Biomass cone. - 0 g/cm3
Hazardous waste fixation pit, wastepile storage, and landfill disposal
model units represent the ranges of these processes in the hazardous waste
management industry.
bBecause design characteristics and operating parameters (surface area
waste throughputs, detention times, and so on) were generally not avail-
able for all treatment, storage, and disposal facilities (TSDF), weighting
factors were developed to approximate the nationwide distribution of model
units defined for a particular TSDF waste management process. The
weighting factors are based on the considerable statistical data available
in the 1981 EPA survey of hazardous waste generators and TSDF conducted by
Westat, Inc. (Westat Survey). For example, results of this survey were
used to determine the national distribution of sizes of storage tanks
(storage volume), surface impoundments (surface area), and landfills
(surface area and depth). For further information on weighting factors
refer to Appendix D, Sections D.2.4.3 and D.2.5.
C-38
-------
6 m, with a width of 3 m and a depth of 3 m. These dimensions represent
reasonable estimates of industry practice based on observations at actual
sites. The duration of the fixation operation was taken to be a maximum of
2 h, based on operating practice at one site.44 The wind direction was
assumed to be along the length of the pit, and a standard temperature of
25 °C and windspeed of 4.5 m/s were used.
Hazardous waste wastepile storage model units are presented in
Table C-3 as part of landfill operations. The wastepile surface areas were
designed to represent the range of basal areas reported in the Westat
Survey, with 470 m2 being an approximately midrange value. For modeling
purposes, the pile was assumed to be flat. The heights were based on
Westat information and engineering judgment. The wastepile retention times
were derived from the landfill volumes, the wastepile volumes, and the
landfill filling time (to capacity) of 1 yr. With regard to the waste
characteristics, the waste density represents a fixed two-phase aqueous/
organic waste. The fixation industry indicated that waste liquid, when
combined with fixative, may increase in volume by up to 50 percent,45,46,47
depending on the specific combination of waste fixative. However, because
of the inherent variability in the fixation process and the lack of real
data on volume changes, this analysis did not incorporate a waste volume
change during fixation. Measurements48 performed on various types of fixed
waste yielded a broad range of total porosities; therefore, 50 percent was
chosen as a reasonable estimate of total porosity. A 25-percent air poros-
ity value was inferred from measurements of total porosity and moisture
content.4$ The toxic property of the waste can inhibit the biological
processes and prevent biogas generation.50 Therefore, the waste biomass
concentration is 0 g/cm^.
Table C-3 also provides hazardous waste landfill disposal model units.
The active landfill surface areas represent the range of surface areas
reported in the Westat Survey. A standard temperature of 25 °C was chosen
for the model.
As with active landfills, the closed landfill surface areas and depths
were based on Westat Survey data. The landfill cap was considered to be
composed of compacted clay. The cap thickness of 110 cm represents the
average of extremes in thickness of clay caps (61 cm to 180 cm) reported in
C-39
-------
site studies.51 The value used for air porosity of the clay cap is 8 per-
cent, while the total porosity is 41 percent. These values were computed
based on reasonable physical properties and level of compaction for
compacted clay.52 jhe temperature beneath the landfill cap was estimated
at 15 °C, which represents the temperature of shallow ground water at a
mid-latitude U.S. location.53 A constant temperature was used. The
landfill is exposed to a nominal barometric pressure of 1.01 x 10~5 Pa
(1,013 mbar), which represents an estimate of the annual average atmos-
pheric pressure in the United States.54 Barometric pumping was estimated
for the landfill using a daily pressure drop from the nominal value of
4.0 x 10-8 Pa (4 mbar). The 4.0 x 10-8 pa (4 mbar) value represents an
estimate of the annual average diurnal pressure drop.55 jhe closed
landfill model units were designed to contain fixed or solid wastes. As
explained previously for hazardous waste wastepile model units, biomass
concentration was taken to be 0 g/cm3 for active and closed landfills.
C.2.1.4 Transfer, Storage, and Handling. Table C-4 presents model
units for loading and storing hazardous waste in containers and covered
tanks and for sources of equipment leaks during waste transfer. The EPA's
Hazardous Waste Data Management System was reviewed56 to select the most
representative volumetric capacities of container storage (drums and dump-
sters) facilities. Based on this review, two model drum storage facilities
were developed: an onsite or private TSDF with a 21-m3 capacity processing
42 m3 annually, and a commercial TSDF with a 40-m3 capacity processing
460 m3 annually. The Westat Survey indicated that waste containers are
typically in the form of 0.21-m3 (55-gal) drums.57 Therefore, these model
capacities would hold 100 and 180 drums, respectively, at any one time. A
telephone conversation with a dumpster vendor58 identified two basic capa-
cities of small roll-off containers: 3.1 m3 and 4.6 m3. The 3.1-ra3 roll-
off, which turns over 6.1 m3 annually, was selected as a model. It has a
length of 1.9 m, width of 1.5 m, and height of 1.2 m. In addition, an
average annual ambient temperature of 25 °C and an average-windspeed of
4.5 m/s were used.
Containers (drums, tank trucks, and rail tank cars) were considered to
be splash-loaded for emission-estimating purposes because data were not
C-40
-------
TABLE C-4. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE TRANSFER, STORAGE, AND
HANDLING OPERATION MODEL UNITS3
Model unit (weights,b %)
Parameters
Container storage
S01A Drum storage (66.1)
S01B Drum storage (33.9)
S01C Dumpster storage (0)
Container loading
Drum loading (NA)
Drum loading (NA)
Tank truck loading (NA)
Throughput - 42 m3/yr
Volume - 0.21 m3/drum
Capacity - 100 drums
Turnovers - 2/yr
Spill fraction - 10-4
Volatilization fraction - 0.5
Throughput - 450 m3/yr
Volume - 0.21 m3/drum
Capacity - 180 drums
Turnovers - 12/yr
Spill fraction - 10~4
Volatilization fraction - 0.5
Throughput - 6.8 m3/yr
Windspeed - 4.5 m/s
Temperature - 25 °C
Length - 1.9 m
Width - 1.5 m
Height - 1.2 m
Turnovers - 2/yr
Throughput - 42 m3/yr
Volume - 0.21 m3/drum
Bulk temperature - 25 °C
Saturation factor
(dimensionless) - 1.45
Number of loadings - 200/yr
Throughput - 460 m3/yr
Volume - 0.21 m3/drum
Bulk temperature - 25 °C
Saturation factor
(dimensionless) - 1.45
Number of loadings - 2,200/yr
Throughput - 110 m3/yr
Volume - 27 m3
Bulk temperature - 25 °C
Saturation factor
(dimensionless) - 1.45
Number of loadings - 4/yr
See notes at end of table.
(continued)
C-41
-------
TABLE C-4. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE TRANSFER, STORAGE, AND
HANDLING OPERATION MODEL UNITS9 (continued)
Model unit (weights,b %)
Parameters
Container loading (con.)
Tank truck loading (NA)
Rail tank car loading (NA)
Rail tank car loading (NA)
Storage tanks
S02A Covered tank (37.7)
Throughput - 430 m3/yr
Volume - 27 m3
Bulk temperature - 25 °C
Saturation factor
(dimensionless) - 1.45
Number of loadings - 16/yr
Throughput - 440 m3/yr
Volume - 110 m3
Bulk temperature - 25 °C
Saturation factor
(dimensionless) - 1.45
Number of loadings - 4/yr
Throughput - 1 800 m3/yr
Volume - HO'm3
Bulk temperature - 25 °C
Saturation factor
(dimensionless) - 1.45
Number of loadings - 16/yr
Throughput - 110 m3/yr (30,000
gal/yr)
Volume - 5.7 m3 (1,500 gal)
Diameter - 1.7 m (5.6 ft)
Adjustment for small diameter
(dimensionless) - 0.26
Height - 2.4 m (8 ft)
Average vapor space height - 1.2 m
(4 ft)
Average diurnal temperature
change - 11 °C
Paint factor (dimensionless)
Turnovers - 20/yr
See notes at end of table.
(continued)
C-42
-------
TABLE C-4. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE TRANSFER, STORAGE, AND
HANDLING OPERATION MODEL UNITS9 (continued)
Model unit (weights,b %)
Parameters
Storage tanks (con.)
S02B Covered tank (Oc)
S02C Covered tank (32.3)
S02D Covered tank (17.8)
Throughput - 60 m3/yr (16,000
gai/yr)
Volume - 30 m3 (8,000 gal)
Diameter - 4 m (13 ft)
Adjustment for small diameter
(dimensionless) - 0.65
Height - 2.4 m (8 ft)
Average vapor space height - 1.2 m
(4 ft)
Average diurnal temperature
change - 11 °C
Paint factor (dimensionless) - 1
Turnovers - 2/yr
Throughput^- 1,100 m3/yr (290,000
gal/yr)
Volume - 30 m3 (8,000 gal)
Diameter - 4 m (13 ft)
Adjustment for small diameter
(dimensionless) - 0.65
Height - 2.4 m (8 ft)
Average vapor space height - 1.2 m
(4 ft)
Average diurnal temperature
change - 11 °C
Paint factor (dimensionless) - 1
Turnovers - 37/yr
Throughput - 3,300 m3/yr (870,000
_
Volume - 76 m3 (20,000 gal)
Diameter - 5.8 m (19 ft)
Adjustment for small diameter
(dimensionless) - 0.86
Height - 2.7 m (9 ft)
Average vapor space height - 1.4 m
(4.6 ft)
Average diurnal temperature
change - 11 °C
Paint factor (dimensionless) - 1
Turnovers - 44/yr
See notes at end of table.
(continued)
C-43
-------
TABLE C-4. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE TRANSFER, STORAGE, AND
HANDLING OPERATION MODEL UNITSa (continued)
Model unit (weights,b %)
Parameters
Storage tanks (con.)
S02E Covered tank (12.2)
Throughput - 17,000 m3/yr
(4,500,000 gal/yr)
Volume - 800 m3 (210,000 gal)
Diameter - 9.1 m (30 ft)
Adjustment for small diameter
(dimensionless) - 1
Height - 12 m (39 ft)
Average vapor space height -6m
(20 ft)
Average diurnal temperature
change - 11 °C
Paint factor (dimensionless)
Turnovers - 21/yr
Treatment tanksd
T01D Covered quiescent tank (28.3)
T01E
Throughput - 11,000 Mg/yr
Volume - 30 m3
Diameter -4m
Adjustment for small diameter
(dimensionless) - 0.65
Height - 2.4 m
Average vapor space height - 1.2 m
Average diurnal temperature
change - 11 °C
Paint factor (dimensionless) - 1
Retention time - 24 h
Turnovers - 365/yr
Covered quiescent tank (21.8) Throughput - 28,000 Mg/yr
Volume - 76 m3
Diameter - 5.8 m
Adjustment for small diameter
(dimensionless) - 0.86
Height - 2.7 m
Average vapor space height - 1.4 m
Average diurnal temperature
change - 11 °C
Paint factor (dimensionless) - 1
Turnovers - 365/yr
See notes at end of table.
(continued)
C-44
-------
TABLE C-4. DESIGN AND OPERATING PARAMETERS OF
HAZARDOUS WASTE TRANSFER, STORAGE, AND
HANDLING OPERATION MODEL UNITS9 (continued)
Model unit (weights,& %)
Parameters
Treatment tanks (con.)
T01F Covered quiescent tank (50.0) Throughput - 290,000 Mg/yr
Volume - 800 ITH
Diameter - 9.1 m
Adjustment for small diameter
(dimensionless) - 1
Height - 12 m
Average vapor space height - 6
Average diurnal temperature
change - 11 °C
Paint factor (dimensionless)
Turnovers - 365/yr
m
- 1
Equipment leaks
Equipment leak model unit Ae (NA)
Pump seals - 5
Valves - 165
Sampling connections - 9
Open-ended lines - 44
Pressure relief valves - 3
NA = Not applicable.
Hazardous waste transfer, storage, and handling operation model units
represent the ranges of these operations in the hazardous waste management
industry.
bBecause design characteristics and operating parameters (surface area,
waste throughputs, detention times, and so on) were generally not avail-
able for all treatment, storage, and disposal facilities (TSDF), weighting
factors were developed to approximate the nationwide distribution of model
units defined for a particular TSDF waste management process. The
weighting factors are based on the considerable statistical data available
in the 1981 EPA survey of hazardous waste generators and TSDF conducted by
Westat, Inc. (Westat Survey). For example, results of this survey were
used to determine the national distribution of sizes of storage tanks
(storage volume), surface impoundments (surface area), and landfills
(surface area and depth). For further information on weighting factors,
refer to Appendix D, Sections D.2.4.3 and D.2.5.
cThe model unit was weighted 0% because S02C also has the same volumetric
capacity. This avoids double-weighting of a unit size.
dLoading emissions from covered quiescent treatment tanks are estimated in
the same manner as loading emissions from covered storage tanks.
eEquipment leak model units B and C were not specified in terms of equip-
ment counts. Emission estimates and control costs were calculated on the
basis of model unit A equipment counts, and emission and control costs
for model units B and C were factored from these estimates.
C-45
-------
available to determine whether one loading method predominates. This load-
ing method creates larger quantities of organic vapors and increases the
saturation factor of each volatile compound within the container. A satu-
ration factor is a dimensionless quantity that represents the expelled
vapors fractional approach to saturation and accounts for the variations
observed in emission rates from the different unloading and loading
methods.59 /\ saturation factor of 1.45 was selected for the emission
estimates, based on previous documentation of splash-loading petroleum
liquids.60,61 Typical capacities for containers were selected, and 25 °C
was considered the annual average ambient operating temperature.
Table C-4 presents covered, hazardous waste tank storage and quiescent
treatment model units. The tank sizes were based on Westat Survey informa-
tion, as has been explained previously for open hazardous waste quiescent
treatment tank model units in Section C.2.1.1. (The Westat Survey did not
distinguish between storage and treatment tanks.) Turnovers per year were
selected based on volumes of waste processed as reported in Westat62 anc|
the Hazardous Waste Data Management System.63 The remaining parameters
were chosen, based on documented information and engineering judgment, to
represent hazardous waste tank storage processes. Meteorological condi-
tions used represent standard temperature (25 °C) and daily average temper-
ature change (11 °C).
Table C-4 also provides hazardous waste transfer, handling, and load-
ing (THL) operation model units to estimate emissions from equipment leaks.
The equipment leak model unit A was obtained from the benzene fugitives
emissions promulgation background information document64 ancj was usec| as
the baseline to develop equipment leak model units B and C. Equipment leak
model units B and C were not specified in terms of equipment counts and,
therefore, are not presented in Table C-4. Emission estimates and control
costs were calculated on the basis of model unit A equipment counts, and
emissions and control costs for model units B and C were factored from
these estimates. Although the emission estimating model for equipment
leaks (essentially the emission factor) is independent of throughput, it
was necessary to account for throughput when applying the model units to a
TSDF to estimate emissions. TSDF may treat, store, or dispose of large
volumes of waste fay one management process. Rather than assume that only
C-46
-------
one very large process unit (and, in turn, one fugitive model unit) is
operated, the throughput of the process is divided by the throughput of its
average model process unit, thus simulating the presence of multiple
process units. This estimates the number of average model process units
operating at the TSDF, and one equipment leak model unit is then applied to
each average model process unit to estimate emissions from equipment leaks.
C.2.2 Model Wastes
A set of model waste compositions was developed to provide a uniform
basis for emission control, emission reductions, and cost estimation for
the model waste management units. Table C-5 lists the model waste
compositions. These model wastes were used to develop control costs and
control efficiencies by waste form for add-on and suppression-type
controls. It should be noted that the model waste compositions defined
here are not used to estimate uncontrolled emissions from the industry
facilities. The compositions and quantities of actual waste streams
processed at the existing facilities were used to estimate nationwide TSDF
emissions and the emission reductions resulting from the control options.
The waste stream compositions in Table C-5 were selected to be repre-
sentative of the major hazardous waste types containing organics.66 One
EPA study using the Waste Environmental Treatment (WET) data base67 cate-
gorized organic-containing waste streams into major classes and evaluated
pretreatment options for these wastes. That study categorized organic-
containing wastes according to the following waste classes:68
• Organic liquids
• Aqueous organics (up to 20 percent organics)
• Dilute aqueous wastes (less than 2 percent organics)
• Organic sludges
• Aqueous/organic sludges.
Other data bases are available for specific industries,69 but compre-
hensive waste stream listings for all domestic wastes are not available.
Based on the known physical and chemical forms of organic-containing
wastes, the following six generic waste stream types were selected for
evaluation of add-on and suppression-type controls:
O47
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C-48
-------
• Dilute aqueous wastes
• Organic liquids
• Organic sludge/slurry
• Aqueous sludge/slurry
• Two-phase aqueous/organic
• Organic-containing solids.
For each generic waste type, specific chemical compositions were next
defined so that material/energy balances and costs could be calculated.
Chemical compositions were chosen that represent the properties of hazard-
ous waste, but they may not represent specific constituents. In general,
compositions were specified that are:
• Representative of the generic waste stream type, i.e., that
include the major organic chemical classes of environmental
importance (e.g., chlorinated organics, aromatics)
• Composed of chemicals representing a range of physical and
chemical properties, based on Henry's law, biodegradability,
and vapor pressure
• Physically and chemically realistic (e.g., a two-phase aque-
ous/organic waste that in fact forms two phases at the pro-
posed composition)
• Readily characterized by available physical and chemical
property data required for the treatment or control system
process designs (e.g., vapor-liquid equilibrium composi-
tions) .
To validate the criterion of being physically and chemically realis-
tic, small samples" of most of the selected generic waste streams were
prepared. However, the physical and chemical properties (e.g., vapor-
liquid equilibrium compositions) needed for the material and energy
balances have not been verified experimentally. Many organic-containing
wastes are complex multicomponent mixtures. Trace levels of certain
compounds (not examined in this study) could significantly affect the
properties of a particular waste stream. However, the chosen waste
compositions are generally suitable for developing design and cost
information for treatment and control processes.
C-49
-------
C.2.3 Summary of Model Unit Analysis of Emission Reductions and Control
Costs ~~~—
The model unit analysis was conducted to provide a basis for estimat-
ing the effectiveness (achievable emission reductions) and associated costs
of controlling organic air emissions from TSDF hazardous waste management
units. In the model unit analysis, control costs (both capital and
annualized) and achievable emission reductions were determined for a matrix
of (1) TSDF model units (e.g., covered storage tanks, quiescent uncovered
treatment tanks, waste fixation operations, and open landfills), (2) waste
forms (e.g., aqueous sludges, organic liquids, and dilute aqueous wastes),
and (3) control technologies (e.g., suppression controls such as tank
covers, add-on controls such as carbon adsorbers). The cost and emission
reduction data generated in the analysis were then used to develop the
control technology and cost file used for estimating nationwide impacts for
alternative TSDF control options. This fi'le provides control device
efficiencies, emission reductions, and control costs according to waste
form for each emission control technology that is applicable to a waste
management process.
Table C-6 presents a summary of the results, of the model unit analysis
in terms of uncontrolled emission estimates, emission reductions, and
control costs for the various model hazardous waste management units. This
model unit analysis includes only compatible combinations of model waste
forms and model unit. Incompatible combinations of waste form and model
unit were not analyzed; e.g., an organic-containing solid waste would not
be treated in a tank.
In Table C-6, the emission control refers to the control technologies
described in Chapter 4.0. Model units and their annual throughputs are
those described in Section C.2.1. Model wastes are as defined in Section
C.2.2. Uncontrolled emissions are estimates generated by the applicable
emission model described in Section C.I.I. The emission reduction is
calculated on the basis of efficiencies presented in Chapter 4.0 for each
control technology. The costs of add-on and suppression-type controls are
calculated as described in Appendix H.
The emission estimates in Table C-6 show the wide range of emission
levels possible from a given model waste management model unit when wastes
C-50
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b {
EMISSION !
CONTROL !
MODEL
WASTE TYPE
i
I ANNUAL
i TmOUGWUT
! (Mg/yr)
c,
UNCONTROLLED
EMISSIONS
(Mg/yr)
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL !
CAPITAL i
INVESTMENT !
TOTAL
ANNUAL
COSTS
UUNtAlNCK SlUKflUL
— DRUM STORAGE (SOU) - 200 Dmms/yr — ,
Fixed Bed !
Carbon
Adsorber
Aqueous 50
Sludge
Dilute 40
Aqueous-1
Organic 40
Liquid
Organic 60
Sludge/Slurry
Two-Phase 40
Aqueous/Organic
0.00033 0.00031
0.0000083 0.0000079
0.0022 0.0021
0.0027 0.0026
0.000017 0.000016
$43,460 |
$43,460
$43,460
$43,460
$43,460
$18,300
$18,300
$18,300
$18,300
$18,300
— DRUM STORAGE (S01B) - 2200 Drums/yr —
Fixed Bed
Carbon
Adsorber
— DUMPSTER
Dumpster
Cover
! Aqueous 560'
0.0038 0.0034
Sludge j
Dilute 450
Aqueous-1
Organic 440
Liquid
Organic 610
Sludge/Slurry
Two-Phase 440
Aqueous/Organic
0.000091 0.000086
0.024 0.022
i
0.030 0.028
0.00018 0.00017
i i
$43,460 !
$43,460
$43,460
$43,460
$43,460
$18,300
$18,300
$18,300
$18,300
$18,300
STORAGE (S01C) - 3.4 m*3 (120 ftA3) Dumpster volume —
j Aqueous ' 16
i Sludge
! Organic 24
i .Solid
0.72 0-71
0.049 0.0485
$150
$150
$64
$72
See notes at end of table.
(continued)
C-51
-------
TABLE Cr6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
MODEL
WASTE TYPE
ANNUAL
THROUGHPUT
(Mg/yr)
! c|
! UNCONTROLLED |
! EMISSIONS !
i (Mg/yr) j
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
— COVERED
Internal
Floating
Roof
Vent to
Existing
Control
Device
Vent to
Carbon
Canisters
STORAGE TANK (S02A) -
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
\queous/0rganlc
».uiji..ii^.n^.K-»ju»gass»3£=s3ai
• i/um
1,500 gal
140
110
110
130
131
i
140
110
110
130
131
140
110
110
130
131
^g-»^-»— • — 1--T.
OIUttAUL
tank —
0.0045
0.083
0.017 .
0.043
0.035
0.0045
0.083
0.017
0.043
0.035
0.0045
0.083
0.017
0.043
0.035
0.004
0.061
0.014
0.035
0.027
• 0.004
0.079
0.016
0.041
0.033
0.004
0.079
0.016
0.041
0.033
$4,820
$4,820
$4,820
$4,820
$4,820
$1,600
$1,600
$1.600
$1,600
$1,600
$1,050
$1,050
$1,050
$1,050
$1,050
$1 ,520
$1,520
$1,520
$1,520
$1,520
$320
$320
$320
$320
$320
$2,220
$5,330
$2,800
$3,520
$3,500
See notes at end of table.
(continued)
C-52
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
MODEL ANNUAL
WASTE TYPE THROUGHPUT
(Mg/yr)
cj d
UNCONTROLLED EMISSION TOTAL TOTAL
EMISSIONS REDUCTION CAPITAL ANNUAL
(Mg/yr) (Mg/yr) INVESTMENT COSTS
TAUI/ crnonnp
— COVERED STORAGE TANK (S02B) -
Internal
Floating
Roof
Vent to
Existing
Control
Device
Vent to
Carbon
Canisters
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous !
Sludge |
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
8,000 gal tank —
70
60
60
70
70
70
60
60
70
70
70
60
60
70
70
0.013
0.180
0.0465
0.114
0.075
0.013
0.180J
0.0465
0.114
0.075
0.013
0.180
0.0465
0.114
0.075
0.011
0.133
0.038
0.093
0.058
0.012
0.171
0.044
0.108
0.071
0.012
0.171
•0.044
0.108
0.071
$8,400
$8,400
$8,400
$8,400
$8,400
$1,600
$1,680
$1,600
$1,600
$1,600
$1,050
$1,050
$1,050
$1,050
$1,050
$2,600
$2,600
$2,600
$2,600
$2,600
$320
$320
$320
$32o
$320
$2,220
$8,720
$3,520
$6,100
$4,810
See notes at end of table.
(continued)
C-53
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS'.RESULTS6
b
EMISSION
CONTROL
— COVERED
Internal
Floating
Roof
Vent to
Existing
Control
Device
Vent to
Carbon
Canisters
j _
MODEL
HASTE TYPE
i
STORAGE TANK (S02
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
! Aqueous
Sludge
! Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic!
.
ANNUAL
TfflOUGHPUT
(Mg/yr)
TANK
C) - 8,000 gal
1,380
1,120
1,090
1,320
1,300
i
1,380
•1,120
1,090
1.320
1,300
1,380
1,120
1,090
1,320
1,300
UNCONTROLLED
EMISSIONS
(Mg/yr)
:CTnDAPC
tank —
0.045
0.813
0.167
0.424
0.342
0.045
0.813
0.167
0.424
0.342
0.045
0.813
0.167
0.424
0.342
i
m t =AU!iMJJt=s
EMISSION
REDUCTION
(Mg/yr) \
0.037
0.602
0.137
0.348
0.267
0.043
0.772
0.159
0.403
0.325
0.043
0.772
0.159
0.403
0.325
TOTAL
CAPITAL
INVESTMENT
$8,400
$8,400
$8,400
$8,400
$8,400
$1,600
$1,600-
$1,600
$1,600
$1,600
$1,050
$1,050
$1,050
$1,050
$1,050
TOTAL
ANNUAL
COSTS
$2,600
$2,600
$2,600
$2,600
$2,600
$320 '
$320
$320
$320
$320
$3,530
$34,130
$8,730
$18,500
$15,220
See notes at end of table.
(continued)
C-54
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS*
b
EMISSION
CONTROL
— COVERED
Internal
Floating
Roof
Vent to
Existing
Control
Device
Vent to
Carbon
Canisters
MODEL ANNUAL
WASTE TYPE THROUGHPUT
! (Mg/yr)
TAI,
STORAGE TANK (S02D) - 20,000 J
Aqueous 4,100
Sludge
Dilute 3,300
Aqueous-1
Organic 3,200
Liquid
Organic 3,900
Sludge/S lurry
Two-Phase 3,900
Aqueous/Organic
Aqueous 4,100
Sludge
Dilute 3,300
Aqueous-1
Organic 3,200
Liquid
Organic 3,900
Sludge/Slurry
Two-Phase 3,900
Aqueous/Organic
Aqueous 4,100
Sludge
Dilute 3,300
Aqueous-1
Organic 3,200
Liquid
Organic 3,900
Sludge/Slurry
Two-Phase 3,900
Aqueous/Organic
c
UNCONTROLLED
EMISSIONS
(Wg/yr)
IK STORAGE
jal tank —
0.117
2.12
0.437
1.11
0.891
0.117
2.12
0.437
1.11
0.891
0.117
2.12
0.437
1.11
0.891
d
EMISSION
REDUCTION
(Mg/yr)
0.096
1.569
0.358
0.910
0.695
0.111
2.014
0.415
1.055
0.846
0.111
2.014
0.415
1.055
0.846
TOTAL
CAPITAL
INVESTMENT
$11,380
$11,380
$11,380
$11,380
$11,380
.
$1,600
$1,600
$1,600
$i,600
$1,600
$1,050
$1.050
$1,050
$1,050
$1,050
TOTAL
ANNUAL
COSTS
$3,500
$3,500
$3,500
$3,500
$3,500
$320
$320
$320
$320
$320
$8,110
$87,600
$20,480
$47,240
$38,750
See notes at end of table,,
(continued)
C-55
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS3
b !
EMISSION |
CONTROL j
i
MODEL
WASTE TYPE
i
ANNUAL !
THROUGHPUT i
(Mg/yr) 5
c!
UNCONTROLLED J
EMISSIONS i
(Mg/yr) j
d
EMISSION
REDUCTION
(Mg/yr)
"
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
\nn\ OIUHAUC
— COVERED STORAGE TANK (S02E) - 210,000 gal tank
Internal
Floating
Roof
Vent to
Existing
Control
Device
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phasa
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Vent to
Fixed Bed
Carbon
Adsorber
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
20,520
16,660
16,260
19,640
19,300
20,520
16,660 J
16,260
19,640
19,300
20,520
16,660
16,260
19,640
19,300
0.678
12.35
2.53
6.43
5.19
0.678
12.35
2.53
6.43
5.19
0.678
12.35
2.53
6.43
5.19
0.556
9.139
2.075
5.273
4.048
0.644
11.733 .
2.403
6.108
4.931
0.644
11.733
2.403
6.108
4.931
$19,660
$19,660
$19,660
$19,660
$19,660
$1,600
$1,600
$1,600
$1,600
$1,600
$72,300
$72,300
$72.300
$72,300
$72,300
$6,100
$6,100
$6,100
$6,100
$6,100
$11,080
$15,660
$13,170
$13,160
$13,700
$40,000
$50,480
$40,000
$40,260
$40,140
"See notes at end of table.
(continued)
C-56
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
EMISSION
CONTROL
MODEL
WASTE TYPE
ANNUAL
TtfiOUGHW
(Mg/yr)
UNCONTROLLED
EMISSIONS
(Mg/yr)
EMISSION
REDUCTION
TOTAL
CAPITAL
(Mg/yr) i INVESTMENT
TOTAL
ANNUAL
COSTS
TANK STORAGE
— QUIESCENT UNCOVERED STORAGE TANK (S02F) - 1.500 gal tank —
Fixed Roof !
Internal
Floating
Roof
( + fixed
roof)
Vent to
Existing
Control
Device
( + fixed
roof)
Vent to
Carbon
Canister
( + fixed
roof)
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
140
110
110
130
130
140
110
110
130
130
140
110
110
130
130
140
110
110
130
13C
1.5
0.38
26
31
0.39
1.5
0.38
26
31
0.39
1.5
_
0.3S
26
31
0.33
1.5
0.36
26
31
0.39
1.496
0.28
25.98
30.96
0.36
1.499
0.34
. 25.996
30.99
0.383
1.4998
0.356
25.999
30.998
0.389
1.4998.
• 0.356
25.939
30.998
0.389
:
$3,790
$3.790
$3.790
$3,790
$3.790
$7.330
$7,330
$7,330
$7.330
"
$7.330
$5,370
$5,370
$5,370
$5,370
$5,370
$4,840
$4,840
$4,840
$4,840
$4,840
$760
$760
$760
$760
$760
$1,870
$1,870
. $1,870
$1,870
$1,870
$1,080
$1.080
$1,080
$1,080
$1,080
$2.980
$6.090
$3,560
$4.280
$4.260
See notes at end of table.
(continued)
C-57
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
EMISSION
CONTROL
MODEL
WASTE TYPE
ANNUAL ! UNCONTROLLED ! EMISSION | TOTAL
THROUGHPUT ! EMISSIONS i REDUCTION ! CAPITAL
(Mg/yr) ! (Mg/yr) i (Mg/yr) ! INVESTMENT
TOTAL
ANNUAL
COSTS
TANK
— QUIESCENT UNCOVERED STORAGE TANK (S02G) - 8.000 gal tank —
Fixed Roof
Internal
Floating
Roof
( + fixed
roof)
Vent to
Existing
Control .
Device
(•i- fixed
roof) •
Vent to
Carbon
Canister
( + fixed
roof)
! Aqueous ! 70
j Sludge j
Dilute j 60
Aqueous-1 j
Organic j 60
Liquid i
Organic i 70
Sludge/Slurry !
1 '
Trio-Phase i 70
Aqueous/Organic!
Aqueous ! 70
Sludge !
1
Dl lute j 60
Aqueous-l !
Organic I 60
• Liquid j
Organic ! 70
Sludge/Slurry j
Trio-Phase i 70
Aqueous/Organic!
Aqueous ! 70
Sludge j
1
Dl lute ! 60
Aqueous-1 j
j
Organic | 60
Liquid j
i
Organic I 70
Sludge/Slurry !
Trio-Phase ! 70
Aqueous/Organic!
Aqueous ! 70
Sludge ;
-3 1
Dilute I 60
Aqueous-1 |
Organic i 60
Liquid !
i
Organic ! 70
Sludge/Slurry !
Tho-Phase i 70
queous/Orcanlc!
! 1.4
t
0.24
24
29
0.23
1.4
0.24
24
29
0.23
1.4
0.24
24
29
0.23
1.4
0.24
24
29
0.23
! 1.39
i
0.06
23.95
28.89
0.16
1.398
0.19
23.99
28.98
0.21
1.3995
0.23
23.998
28.99
0.227
1.3995
0.23
23.998
28.99
0.227
$9,500
$9,500
$9,500
$9.500
$9,500
$16,450
$16,450
$16,450
$16,450
$16,450
$11,080
$11,080
$11,030
$11,030
$11,030
$10.550
$10,550
$10,550
$10,550
$10,550
$1,880
$1,880
$1,880
$1.880
$1.830
$4.000
$4,000
$4,000
$4.000
t
,
$4.000
$2,200
$2,200
$2,200
$2,200
$2,200
$4,100
S10.600
$5,4GO
$7,9SO
$6,690
See notes at end of table.
(continued)
C-58
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS0
b
EMISSION
CONTROL
MODEL
KASTE TYPE
ANNUAL
THROUGHPUT
(Mg/yr)
c
UNCONTROLLED
EMISSIONS
(Mg/yr)
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
TANK STORAGE
QUIESCENT UNCOVERED STORAGE TANK (SQ2H) - 8.000 gal tank —
Fixed Roof
Internal
Floating
Roof
( + fixed
roof)
•
Vent to
Existing
Control
Device
( + fixed
roof)
Vent to
Carbon
Canister
{ + fixed
roof)
Aqueous
Sludge
Dilute
Aqusous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Tvio-Ttese
Aqueous/Organ)
1,380
1.120
1,090
1.320
1,300
1,380
1.120
1.090
1.320
1,300
1,380
.
i
; 1,120
1.090
1,320
1,300
1,330
1,120
1,030
1,320
1,300
11
3.2
217
243
3.6
11
3.2
217
243
1
3.6
11
3.2
217
243
3.6
11
3.2
217
243
3.6
!
10.96
2.4
216.8
242.6
3.3
10.99
3.0
216.98
242.9
3.53
10.998
I
3.16
216.99
242.98
3.59
10.998
3.16
216.99
242.93
3.59
$9,500
$9,500
$9.500
$9.500
$9.500
$16,450
$16,450
$16,450
$16,450
$16,450
$11,080
$11,080
$11.080
$1 1,030
$11,080
$10,550
$10.550
$10,550
$10,550
J10.550
$1,880
$1,880
$1.880
$1,880
$1,880
$4,000
$4,000
$4,000
$4.000
$4,000
$2.200
$2,200
$2,200
$2,200
$2,200
$5,410
$33,010
$10.610
S20.330
$17,100
See notes at end of table.
(continued)
C-59
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS9
EMISSION
MODEL
tmiooiun j MUUCL
CONTROL j WASTE TYPE
ANNUAL i UNCONTROLLED
TffiOUGHPUT ! EMISSIONS
(Mg/yr) ! (Mg/yr)
EMISSION i TOTAL ! TOTAL
REDUCTION CAPITAL ANNUAL
(Mg/yr) \ INVESTMENT ! COSTS
- TANK STORAGE
— QUIESCENT UNCOVERED STORAGE TANK (S02I) - 20.000 flal —
Fixed Roof
Internal
Floating
Roof
( + fixed
roof)
Vent to
Existing
Control
Device
( + fixed
roof)
Vent to
Carbon
Canister
( + f Ixsd
roof)
! Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organ
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organl
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
queous/Organlc
Aqueous
Sludge
Dilute
Aqueaus-1
Oraanic
Liquid
Organic
ludgs/Slurry
Two-Phase
queous/Organlc
4.100 |
1
1
3,300 J
i
i
3.200 j
I
3.900 j
I
1
3.900 j
i
4.100 !
3,300 j
i
3,200 !
t
i
3,900 !
i
i ,
t
3,900 !
4,100 !
j
3,300 j
t
3.200 i
1
3,900 j
3,900 !
i
i
4,100 !
1
t
1
3,300 i
t
t
3.200 i
I
1
3,900 j
i
t
3.900 i
i
1'
8.1
514
586
9.7
24
8.T
514
586
9.7
24
8.1
514
586
9.7
24
8.1
514
5£3
9.7
23.9 !
i
i
6.0 j
i
j
513.6 j
1
584.9 1
8.8 j
23.98 j
1
I
7.6 j
. 513..9 j
1
585.8 !
1
9.5 j
23.995 j
<
I .
8.0 j
j
513.98 !
i
585.9 !
9.66 j
1
1
23.995 !
1
J
1
8.0 !
1
513.98 !
i
i
5S5.9 !
1
1
t
9.66 I
1
$14.800 j
$14,800 j
j
1
$14,800 j
i
i
$14,800 j
j
$14,800 j
1
$24,420 1
t
i
$24,420 j
1
I
$24,420 !
1
t
$24.420 i
I
1
$24,420 !
i
$16,380 !
1
1
1
$16,380 >
j
$16.380 i
t
I
$16,380 i
I
1
$16,380 i
1
1
$15.850 |
I
I
$15,850 j
$15,850 !
1
1
515.850 i
1
$15,850 i
$2,930
$2,930
$2.930
$2.930
$2,930
$5,860
$5,860
$5,860
$5,860
$5,860
$3,250
$3,250
$3,250
$3.250
$3,250
$11,040
$90,530
$23,410
$50,170
$41.650
See notes at end of table.
(continued)
C-60
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
MODEL
WASTE TYPE
ANNUAL
THROUGHPUT
(Mg/yr)
0
UNCONTROLLED
EMISSIONS
(Mg/yr)
o :
EMISSION !
REDUCTION |
(Mg/yr) !
•TOTAL
CAPITAL
INVESTMENT
1
i TOTAL
! ANNUAL
! COSTS
TANK STORAGE
QUIESCENT UNCOVERED STORAGE TANK (S02J) - 210.000 gal tank
rlxed Roof
Internal
Floating
Roof
( + fixed
roof)
Vent to
Existing
Control
Device
( + fixed
roof)
Vent to
Fixed Bed
Carbon
Adsorber
( t fixed
roof)
Aqueous
Sludge
Dilute
Aqueous-1
Organic I
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two -Phase
Aqueous/Organ 1
20.520
16,660
16,260
19,640
19,300
20,520
16,660
16,260
19,640
19,300
20.520
16,660
16,260
19,640
19,300
20,520
16,660
16,260
19,640
13.300
70
30
1,730
1,960
41
70
30
1,730
1.960
41
70
30
1,730
1.960
41
70
30
1,730
1,960
41
69.3 j
17.7
1,727
1,954
35.8
69.9
26.8
1,729.5
t.958.9
39.9
69.97
29.4
1,729.9
1959.7
40.7
6S.97
'
29.4
1,729.9
1959.7
40.7
$26.040
$26,040
$26,040
$26,040
$26,040
$40,560
$40,560
$40.560
$40,560
$40,560
$27,620
$27,620
$27,620
$27,620
$27,620
$98,340
$98,340
$98,340
$98,340
$98,340
$5.200
$5,200
$5.200
$5.200
$5,200
$9,500
$9,500
$9,500
$9,5pO
$9,500
$5,600
;
$5,600'
$5,600
$5,600
$5,600
$45,200
$55,6SQ
$45,200
$45,400
$45,340
See notes at end of table.
(continued)
C-61
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
!
| MODEL
! HASTE TYPE
!
ANNUAL
THMHJGHW
(Mg/yr)
c
UNCONTROLLED
EMISSIONS
(Mg/yr)
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
"== — ="• —
TOTAL
ANNUAL
COSTS
— — — IIHOIU ILL OIUftMUL
— WASTEPILE COVER (S030) - 1300 ftA3 waste volume —
Hasteplle j Aqueous J 17,000 J 16.0 15.95 !
Cover-30 nil Sludge ! j
HOPE j !
Two-Phase ! 17,000 10.0 4.9 1
iAquaous/Organlcj | j
— HASTEPILE COVER (S03E) -
Wasteplle Aqueous
Cover-30 nl 1 Sludge
HOPE
Two-Phase
Aqueous/Organic
— HASTEPILE COVER (S03F) -
Wasteplle Aqueous
Cover-30 all Sludge
HOPE
Two-Phase
Aqueous/Organic
16,000 ftA3 waste volume —
120,000 139.7 139.3 S
120,000 100.0 49.3 $
I
2,010,000 ftA3 waste volume —
170,000 457.0 j 455.6 $1£
i
170,000 390.0 192.3 $1£
i
i
$650 $2,500
t
t
$650 $2,500
6,480 $4,700
6,480 $4,700
i
7,300 $62,000
7,300 $62,000
See notes at end of table.
(continued)
C-62
-------
TABLE C-6, SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
MODEL ANNUAL
WASTE TYPE THROUGHPUT
(Mg/yr)
OIIO
— QUIESCENT STORAGE IMPOUNDMENT (S04A) -
ASP+FBCA
Aqueous 99,000
c!
UNCONTROLLED
EMISSIONS
(Mg/yr)
PAPF IlPmiNHMFMT
d
EMISSION
REDUCTION
(Mg/yr)
crrnACF
i
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
71 ,300 gal Impoundment —
278
264
i Sludge
Dilute 99,000
Aqueous-1
Two-Phase 99,000
MEMBRANE
Aqueous/Organic
Aqueous 99,000
Sludge
Dilute 99,000
Aqueous-1
Two-Phase 99,000
Aqueous/Organic
— QUIESCENT STORAGE IMPOUNDMENT (S04B) -
ASP-:FBCA
MEMBRANE
Aqueous 9,800
Sludge
Dilute 9,800
Aqueous-1
Two-Phase 9,800
Aqueous/Organic
Aqueous 9,800
Sludge
Dilute 9,800
Aqueous-1
Two-Phase 9,800
Aqueous/Organic
114
191
,-
278
114
" 191
108
181
236
97
162
$181 ,000
$177,000
$177,000
1
$15,000
$15,000
$15,000
i
$84,000
$78,000
$78,000
$8,000
$8,000
$8,000
• 71,300 gal Impoundment —
140
32
i 36
140
32
36
133
30
34
119
27
31
$180,000
! $179,000
! $179,000
1
$15,000
$15,000
$15,000
$78,000
$74,000
$74,000
$8,000
$8,000
$8,000
See notes at end of table.
(continued)
C-63
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION MODEL ANNUAL
CONTROL WASTE TYPE THROUGHPUT
(Mg/yr)
c d
UNCONTROLLED EMISSION TOTAL
EMISSIONS REDUCTION CAPITAL
(Mg/yr) (Mg/yr) INVESTMENT
TOTAL
ANNUAL
COSTS
SURFACE IMPOUNUffMT STORAGE
— QUIESCENT .STORAGE UPOUNDMENT (S04C) - 713,000 gal impoundment —
ASP+FBCA Aqueous 49,000
Sludge
Dilute 49,000
Aqueous-1
Two-Phase 49,000
i Aqueous/Organic
MEMBRANE Aqueous 49,000
Sludge
Dilute 49.000
Aqueous-1
Two-Phase 49,000
Aqueous/Organic
— QUIESCENT STORAGE IMPOUNDMENT (S04D) -
ASP+FBCA i Aqueous 25,000
Sludge
Dl lute 25,000
! Aqueous-1
Two-Phase 25,000
Aqueous/Organic
MEMBRANE Aqueous 25,000
Sludge
Dilute 25,000
Aqueous-1
Two-Phase 25,000
Aqueous/Organic
See notes at end of table.
^^^_^_^^__^_^^_!__
686 652 $311,000
1
1
159 j 151 $249,000
183 174 $249,000
i
686 583 $57,000
159 135 ' $57,000
183 156 $57,000
' ' .
• 713,000 gal Impoundment —
442 420 $310,000
i
157 149 $310,000
S3 88 $310,000
442 376 $57,000
157 133 $57,000
93 79 $57,000
i
$42,000
$42,000
$42,000
$16,200
$16,200
$16,200
$127,000
$114,000
$114,000
$17,000
$17,000
$17,000
(continued)
C-64
.
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS0
b
EMISSION
CONTROL
MODEL ANNUAL
HASTE TYPE THROUGtfW
(Mg/yr)
c d
UNCONTROLLED EMISSION
EMISSIONS REDUCTION
(Mg/yr) (Mg/yr)
i
TOTAL
CAPITAL
i INVESTMENT
TOTAL
ANNUAL
COSTS
cjiOFAPF IMPnUNDUFNT STORAGE
— QUIESCENT STORAGE IMPOUNDMENT (S04E) - 8,720,000 gal Impoundment —
ASP+FBCA
Aqueous 120,000
Sludge
Di lute 120,000
Aqueous-1
Two-Phase 120,000
{Aqueous/Organic
MEMBRANE Aqueous 120,000
Sludge
! Dilute 120,000
Aqueous-1
Two-Phase 120.000
Aqueous/Organic
— QUIESCENT STORAGE IMPOUNDMENT (S04F) -
ASP+FBCA
MEMBRANE
Aqueous 67,000
Sludge
DI lute 67,000
Aqueous-1
Two-Phase 67,000
Aqueous/Organic
i
Aqueous 67,000
Sludge
Di lute 67,000
Aqueous-1
Two-Phase 67,000
Aqueous/Organic
2,200 2,090
446 424
464 441
2,200 1,870
446 379
464 394
8,720,000 gal Impoundment
1,420 1.3«3
253 240
i
i
262 249
i
1,420 1,207
253 215
•
262 223
$1,160,000
$804,000
$804,000
i
$300,000
$300,000
$300,000
1
vi—
j $1,170,000
$806,000
$806,000
i
$300,000
$300,000
$300,000
$488,000
$284,000
$284,000
$65,000
$65,000
$65,000
$450,000
$276,000
$276,000
$65,000
$65,000
$65,000
See notes at end of table.
(continued)
C-65
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS*
b
EMISSION
CONTROL
MODEL
HASTE TYPE
ANNUAL
THROUGHPUT
(Hg/yr)
p
UNCONTROLLED
EMISSIONS
(Mg/yr)
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
=3Sa=3S=SSr==
TOTAL
ANNUAL
COSTS
TANK TREATMENT -
— QUIESCENT UNCOVERED TREATMENT TANK (T01A) - 8,000 gal
tank
Fixed Roof
Internal
Floating
Roof
( + fixed
roof)
Vent to
Existing
Control
Device
( + fixed
roof)
Vent to
Carbon
Canister
( + fixed
roof)
Aq Sludge
Dilute Aq
Org Liquid
Org Sludge/Slurry
THO-Phasa Aq/Org
Aq Sludge
Dilute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
Dilute Aq
Org Liquid
C/g Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
Dl lute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
11,000
11,000
11,000
11,000
' 11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
16
8.6
467
523
14
16
8.6
467
523
14
16
8.6
467
523
14
16
8.6
467
523
14
15.9 j $9,500
6.8 j $9,500
466.5 | $9,500
522.4 j $9,500
13.2 j $9,500
i
15.98 j $16,450
8.12 j $16,450
466.91 j $16,450
522.90 | $16,450
13.83 i $16,450
15.995 ! $11,080
[
8.51 j $11,080
466.98 j $11,080
522.97 j $11,080
13.96 i $11,080
15.995 j $10,550
8.5 j $10,550
466.98 j $10,550
522.97 j $10,550
13.96 {' $10,550
$1,880
$1,880
$1,880
$1,880
$1,880
$4,090
$4,090
$4,090
$4,090
$4,090
; $2,210
$2,210
$2,210
$2,210
$2,210
$7,300
$76,380
$22,360
$25)570
$34,090
See notes at end of table.
(continued)
C-66
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS
b
EMISSION
CONTROL
!
MODEL ! ANNUAL
WASTE TYPE ! THROUGHPUT
! (Mg/yr)
c
UNCONTROLLED
EMISSIONS
(Mg/yr)
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
————— IHTIIV intMimtm — — — — —
— QUIESCENT UNCOVERED TREATMENT TANK (T01B) - 20,000 gal tank —
Fixed Roof
Internal
Floating
Roof
( + fixed
roof)
Vent to
Existing
Control
Device
( + fixed
roof)
Vent to
Carbon
Canister
( + fixed
roof)
Aq Sludge
Dilute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
Dl lute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
i
Dl lute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
Dilute Aq
Org Liquid
Org Sludge/Slurry
! Two-Phase Aq/Org
28,000
28,000
28,000
28,000
28,000
28,000
28,000
28,000
28,000
28,000
28,000
28.000
28,000
28,000
28,000
28,000
28,000
28,000
23,000
28,000
34
19
954
1,026
31
34
19
954
1,026
31
34
1
19
954
1,026
31
34
19
954
1,026
31
33.8
14.4
952.8
1,024.6
29.1
33.96
17.80
953.79
1025.75
30.57
33.99
18.8
953.9
1025.9
30.9
33.99
18.8
953.9
1025.9
30.9
$14,800
$14,800
$14,800
$14,800
$14,800
$24,420
$24,420
$24,420
$24,420
$24,420
$16,380
$16,380
$16,380
$16,380
$16,380
$15,850
$15,850
$15,850
$15,850
$15,850
$3,050
$3,050
$3,050
$3,050
$3,050
$6,100
$6,100
$6,100
$6,100
$6,100
$3,350
$3,350
$3,350
$3,350
$3,350
$15,790
$188,920
$53,460
$20,220
$82,830
See notes at end of table.
(continued)
C-67
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
MODEL
WASTE TYPE
i ANNUAL
! THROUGHPUT
! (Mg/yr)
c
UNCONTROLLED
EMISSIONS
(Mg/yr)
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
— ^— — — - i«™\ intHimcm — — — —
— QUIESCENT UNCOVERED TREATMENT TANK (T01C) - 210,000 gal tank —
Fixed Roof
Internal
Floating
Roof
(• £. \\*ftf&
+ f Ixsd
roof)
.
Vent to
Existing
Control
Device
( + fixed
*>jti*£\
roof)
Vent to
Fixed Bed
Carbon
Adsorber
( + fixed
ff\ft£.\
roof)
Aq Sludge
DI lute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Drg
Aq Sludge
Dilute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
DI lute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
DI lute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290.000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
83
53
4,770
5,320
98
83
53
4,770
5,320
98
83
53
4,770
5,320
98
83
53
4,770
5,320
98
80.6
5.8
4,759
5,306
78.1
68.06
60.16
3912.44
5219.01
1243.69
82.88
50.64
4769.45
5319.28
97.01
$26,040
$26,040
$26,040
$26,040
$26,040
$40,560
$40.560
$40,560
$40,560
$40,560
$42,460
$42,460
$42.460
$42.460
$42.460
82.88 $100,220
50.64 $100,220
4769.45 $100,220
5319.28 $100,220
97.01 $100,220
$5.810
$5,810
$5,810
$5,810
$5.810
$11,620
$11,620
$11,620
$11,620
$11,620
$8',720
$8,720
$8,720
$8,720
$8,720
$58,120
$58,120
$58,120
$58,120
$58, 120
See notes at end of table.
(continued)
C-68
-------
TABLE C-6o SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
MODEL
HASTE TYPE
! ANNUM.
j THROUGWtJT
! (Mg/yr)
! c
i UNCONTROLLED
i EMISSIONS
! (Mg/yr)
d!
EMISSION !
REDUCTION i
(Mg/yr) i
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
TANK TREATMENT
— COVERED C
Internal
Floating
Roof
Vent to
Existing
Control
Device
Vent to
Carbon
Canister
IUIESCENT TREATMENT
Aq Sludge
Dl lute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
Dl lute Aq
Org Liquid
Org Sludge/Slurry
i Two-Phase Aq/Org
Aq Sludge
Dl lute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
TANK (T01D)
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11.000
11,000
11,000
i 11,000
- 8,000 gal tar
0.0953
1.83
0.473
0.56
0.769
0.0953
1.83
0.473
0.58
0.769
0.0953
1.83
0.473
0.56
0.769
k —
0.08
1.35
0.39
0.46
0.60
0.09
1.74
0.45
0.53
0.73
0.09.
»
1.74'
0.45
0.53
0.73
$8,400
$8,400
$8,400
$8,400
$8,400
$1,600
$1,600
$1,600
$1,600
$1,600
$1,050
$1,050
$1,050
$1,050
$4,900
$2,660
$2,660
$2,680
$2,660
$2,660
$330
$330
$330
$330
$330
$5,420
1
$74,500
$20,480
$23,690
$32,210
See notes at end of table.
(continued)
C-69
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS3
b i
EMISSION 1
CONTROL j
I
MODEL
HASTE TYPE
ANNUAL
THROUGHPUT
(Mg/yr)
UNCONTROLLED
EMISSIONS
(Mg/yr)
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
TANK TREATMENT
COVERED QUIESCENT TREATMENT TANK (T01E) - 20,000 gal tank
Internal
Floating
Roof
Vent to
Existing
Control
Device
Vent to .
Carbon '
Canister"
Aq Sludge
Dilute Aq
Org Liquid
Org Sludge/S lurry
Two-Phase Aq/Org
Aq Sludge
Di lute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
Dilute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Two-Phase
28,000
28,000
28,000
28,000
28,000
28,000
28,000
28,000
28,000
28,000
t 28,000
28,000
28,000
28,000
28,000 |
0.24
4.60
1.19
1.40
1.94
0.24
4.60
1.19
1.40
1.94
0.24
4.60
1.19
1.40
1.94
0.20
3.40
0.98
1.15
1.51
0.23
4.37
1.13
1.33
1.84
0.23
4.37
1.13
1.33
1.84
$11,380
$11,380
$11,380
$11,380
$11,380
$1,600
$1,600
$1,600
$1,600
$1,600
$1,050
$1,050
$1,050
$1,050
$1,050
$3,600
$3,600
$3,600
$3,600
$3,600 '
$300
$300
$300
$300
$300
$12,740
$185,870
$50,410
$5,900
$79,780
See notes at end of table.
(continued)
C-70
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
MODEL
WASTE TYPE
,"*"""- ' '"Ji=a
! ANNUAL
j THROUGHPUT
! (Mg/yr)
. TAl
c!
UNCONTROLLED !
EMISSIONS !
(Mg/yr) !
« TREATMENT
d!
EMISSION !
REDUCTION \
(Mg/yr) !
i
TOTAL !
CAPITAL !
INVESTMENT |
TOTAL
ANNUAL
COSTS
— COVERED Q
Internal
Floating
Roof
Vent to
Existing
Control
Device
Vent to
Fixed Bed
Carbon
Adsorber
UIESCENT TREATMENT
Aq Sludge
Dilute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
DlluteAq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
Aq Sludge
Dilute Aq
Org Liquid
Org Sludge/Slurry
Two-Phase Aq/Org
TANK (T01F)
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
290,000
- 210,000 gal t
2.45
47.23
11.05
14.32
19.89
2.45
47.23
11.05
14.32
- 19:89
2.45
47.23
11.05
14.32
19.89
ank —
2.01
34.95
9.06
11.74
15.52
2.32
44.87
10.49
13.60
18.90
2.32
44.87
10.49
13.60
18.90
$19,660
$19,660
$19,660
$19,660
$19,660
$1,600
$1,600
$1,600
$1,600
$1,600
$74,180
$74,180
$74,180
$74,180
$74,180
$5,810
$5,810
$5,810
$5,810
$5,810
$300
$300
$300
$300
$300
$52,310
$52,310
$52,310
552,310
$52,310
See notes at end of table.
(continued)
C-71
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS^
EMISSION
CONTROL
t
! MODEL
j WASTE TYPE
i
i
ANNUAL
THROUGHPUT
(Mg/yr)
Q
UNCONTROLLED
EMISSIONS
(Mg/yr)
d!
EMISSION !
REDUCTION i
(Mg/yr) |
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
—————— IMIUV ini.Himi.iii — — — —
— UNCOVERED AERATED/AGITATED TREATMENT TANK (T01G) - 28,500 gal tank —
ASP+FBCA | Aqueous 240,000 870 827 $124.000
i Sludge
! Dilute 240,000 130 124 $125,000
! Aqueous-1
$66,600
$94,800
— UNCOVERED AERATED/AGITATED TREATMENT TANK (T01H) - 423,000 gal tank —
ASP+FBCA J Aqueous 2,800,000 | 10,600 10,070 $732,000
j Sludge j
! Dilute 2.80G
i Aqueous-1
,000 4,600 4,370 $732,000
i
$607,000
$607,000
See notes at end of table.
(continued)
C-72
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b !
EMISSION !
CONTROL |
i
MODEL
HASTE TYPE
! ANNUAL
i THROUGt-PUT
! (Mg/yr)
c!
UNCONTROLLED !
EMISSIONS !
(Mg/yr) i
d !
EMISSION !
REDUCTION i
(Mg/yr) !
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
bUKrALL IMfUUNUMtW muumuii
— QUIESCENT TREATMENT IMPOUNDMENT (T02A) - 71,300 gal Impoundment —
ASP+FBCA ! Aqueous
! Sludge
Dilute
Aqueous-1
Two-Phase
Aqueous/Organic
MEMBRANE Aqueous
Sludge
Dilute
Aqueous-1
Two-Phase
Aqueous/Organic
200,000 301 286 j $181,200 | $85,300
!
200,000 135 128 $
200,000 265 252 i
200,000 301 256
200,000 135 115
200,000 265 225
179,800 $83,300
i
H79.800 $83,300
i
$14,760 $8,000
t
i
$14,760 ! $8,000
i
$14,760 j $8;000
t
QUIESCENT TREATMENT IMPOUNDMENT (T02B) - 71,300 gal irapounctaent —
ASP+FBCA ! Aqueous
! Sludge
Dilute
Aqueous-1
i Two-Phase
! Aqueous/Organic
MEMBRANE Aqueous
Sludge
Dilute
Aqueous-1
Two-Phase
Aqueous/Organic
20,000 191 j 181 j
!
20,000 53 50
20,000 65 62
i '
20,000 191 162
i
i
20,000 53 45
i
20,000 65 55
i
$176,900 $79,200
$171,800 $72,600
$171,800 $72,600
t
$14,760 $8,000
$14,760 $8,000
$14,760 $8,000
See notes at end of table.
(continued)
C-73
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS3
b
EMISSION
CONTROL
MODEL
WASTE TYPE
ANNUAL
™OUGH=UT
(Mg/yr)
UNCONTROLLED
EMISSIONS
(Mg/yr)
d !
EMISSION !
REDUCTION |
(Mg/yr) i
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
ouni i
— QUIESCENT TREATMENT IMPOUNDMENT (T02C) -
ASP+FBCA
Aqueous
Sludge
Dilute
Aqueous-1
990,000
990,000
Two-Phase 990,000
Aqueous/Organic
MEMBRANE
! Aqueous
! Sludge
Dilute
Aqueous-1
990,000
990,000
! Two-Phase j -990,000
[Aqueous/Organic!
— QUIESCENT TREATMENT IMPOUNDMENT (T02D) -
ASP+FBCA
Aqueous
Sludgu
Dilute
Aqueous-1
99,000 !
i
i
99,000
1
j Two-Phase ! 99,000
Aqueous/Organic!
MEMBRANE
Aqueous
Sludge
Dilute
Aqueous-1
Two-Phase
Aqueous/Organlcj
99,000
99,000
99,000
1UC IWlAJNUMtNl IKtAIMtNT
- 713,000 gal impoundment —
1.400
700
1,320
1,400
700
1,320
713,000 gal
946
269
326
946
269
326
1,330
665
1,254
1190
595
1122
Impoundment —
899
1
I
256
i
i
i
310
i
804
229
277
- $280,600
$277,500
$277,500
$57,000
$57,000
$57,000
$262.800
$237,500
I
$237,500 1
i
i
$57,000
$57,000
$57,000
$147,900
$147,900
$147,900
$19,700
$19,700
$19,700
$128,200
$97,600
$97,600
$15,800
$15,800
$15,800
See notes at end of table.
(continued)
C-74
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION MODEL ANNUAL
CONTROL ! WASTE TYPE THROUGHPUT
! (Mg/yr)
CttDI
— QUIESCENT TREATMENT IMPOUNDMENT (T02E)
ASP+FBCA Aqueous 608.000
Sludge
Dilute 608,000
Aqueous-1
Two-Phase 608,000
Aqueous/Organic
MEMBRANE Aqueous ! 608,000
Sludge !
Dilute 608,000
Aqueous-1
Two-Phase i 608,000
Aqueous/Organlcj
UNCONTROLLED
EMISSIONS
(Mg/yr)
:ACE IMPOUNDMENT
- 8,720,000 gal
5,530
1,710
2,040
5,530
1,710
2,040
— QUIESCENT TREATMENT IMPOUNDMENT (T02F) - 8,720,000 gal
ASP+FBCA Aqueous 302,000
Sludge
Dilute 302,000
Aqueous-1
Two-Phase 302,000
Aqueous/Organic
MEMBRANE Aqueous 302,000
Sludge
Dilute 302,000
Aqueous-1
Two-Phase 302,000
Aqueous/Organic
4,030
990
1,120
i
4,030
990
1,120
d
EMISSION
REDUCTION
(Mg/yr)
TREATMENT -
Impoundment
5,254
1,625
1,938
4,701
1,454
1,734
Impoundment
3,829
941
1,064
3,426
842
952
i
TOTAL
CAPITAL
INVESTMENT
—
$636,600
$500,000
$500,000
! $300,070
$300,070
i
! $300,070
I 1
lar-i-i-ir'
$577,900
$461,500
$461 ,500
i
$300,070
$300,070
$300,070
ZS=== =====: =SR=S3=3
TOTAL
ANNUAL
COSTS
$395,200
$224,900
$224,900
$10,800
$10,800
$10,800
$321,000
$169,300
$169,300
$66,500
$66,500
$66,500
See notes at end of table.
(continued)
C-75
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS3
EMISSION ! MODEL
CONTROL ! HASTE TYPE
i
i
ANNUAL
THROUGHPUT
(Mg/yr)
c
UNCONTROLLED
EMISSIONS
(Mg/yr)
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
SURFACE IMPOUNDMENT TREATMENT
— AERATED/AGITATED TREATMENT IMPOUNDMENT (T02G) - 7.1,300 gal Impoundment —
ASP+FBCA
Aqueous
Sludge
Dilute
Aqueous-1
Two-Phase
.{Aqueous/Organic!
200,000
200,000
200,000
683
760
763
649
722
725
$196,200 j $103,000
$199,200
$199,200
$107,000
$107,000
AERATED/AGITATED TREATMENT IMPOUNDMENT (T02H) - 71,300 gal Impoundment —
ASP+FBCA
Aqueous
Sludge
Dilute
Aqueous-1
} Tiro-Phase
!Aqueous/Organic
20,000 j
i
20,000 !
20,000 !
302
78
77
287 ! $181,300 |
73
$179,000 !
i
$179,000 |
$9.000
$8,000
$8,000
AERATED/AGITATED TREATMENT IMPOUNDMENT (T02I) - 713,000 gal Inpoundinent —
ASP+FBCA
Aqueous
Sludge
Dilute
Aqueous-1
Two-Phase
Aqueous/Organic
990,000 i
j
990,000 |
990,000
6,530
3,800
3,860
6,204
3,610
$481,000 j $404,000
I
$376,000 j $266,000
3,667 $376,000 j $266,000
— AERATED/AGITATED TREATMENT IMPOUNDMENT (T02J) - 713,000 gal impoundment
ASP+FBCA
Aqueous
Sludge
Dilute
Aqueous-1
Two-Phase
Aqueous/Organic
99,000
99,000
99,000
See notes at end of table.
1,920
390 !
380 !
1,824
371
361
$305,000
$298,000
$293,000
$177,000
$122,000
$122,000
(continued)
C-76
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
i
MODEL
HASTE TYPE
i
ANNUAL
TffiOUGtfHJT
(Mg/yr) !
C
UNCONTROLLED
EMISSIONS
(Mg/yr)
d!
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
fllRFAPF IMPffllNTIMFNT TRFATMFNT
AERATED AGITATED TREATMENT IMPOUNDMENT (T02K) - 8,720,000 gal Impoundment —
ASP+FBCA
Aqueous !
Sludge !
1
Dilute
Aqueous-1
Two-Phase
Aqueous/Organic
608,000
608,000
608,000
12,160
2,300
2,400
11,552
2,185
2,280
$777,000
$512,000
$512,000
$693,000
$237,000
$237,000
i
— AERATED/AGITATED TREATMENT IMPOUNDMENT (T02L) - 8,720,000 gal impoundment —
ASP+FBCA
| Aqueous
Sludge
. Di lute
Aqueous-1
Two-Phase
302,000
302,000
302,000
6,520
i
! 810
1,200
6,194
770
1,140
$675,000
$460,000
$480,000
Aqueous/Organic!
$445,000
$169,000
$169,000
i
See notes at end of table.
(continued)
C-77
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS3
b
EMISSION
CONTROL
MODEL
HASTE TYPE
ANNUAL
THROUGHPUT
(Mg/yr)
! c
j UNCONTROLLED
! EMISSIONS
! (Mg/yr)
d!
EMISSION !
REDUCTION !
(Mg/yr) |
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
— HASTE FIXATION (Fixation
Mixer
Baghouse,
&FBCA
Aqueous
Sludge
i
Two-Phase
! Aqueous/Organic
— HASTE FIXATION (Fixation
Mixer
Baghouse,
& FBCA
Aqueous
Sludge
Two-Phase
Aqueous/Organic
— HASTE FIXATJON (Fixation
* Mixer
Baghouse.
& FBCA ,
i
i
Aqueous
Sludge
Two-Phase
Aqueous/Organic
————— nnoiL i IAMI IUM
Pit A) —
17,000 51.0
17,000 51.0
Pit B) —
117,000 351.0 i
i
117,000 351.0
i
Pit C) — «
167,000 501.0
i
i
167,000 501.0
i
48.0 j $464,000 $228,000
i
50.0 $464,000 $228,000
i
330 $572,000 $213,000
300 $572,000 $213,000
480 $616,000 $277,000
! !
500 $616,000 $277,000
i
See notes at end of table.
(continued)
C-78
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS'
b
EMISSION
CONTROL
MODEL
WASTE TYPE
!
ANNUAL !
ThROUGtfHJT!
(Mg/yr) !
c!
UNCONTROLLED i
EMISSIONS i
(Mg/yr) !
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
— ACTIVE LANDFILL (D800) - 1
Dally Earth Aqueous !
Cover Sludge !
Two-Phase !
Aqueous/Organic!
— ACTIVE LANDFILL (D80E) - 3
Dally Earth j Aqueous !
Cover j Sludge !
! Two-Phase !
j Aqueous/Organic!
— ACTIVE LANDFILL (D80F) - 5
Dally Earth ! Aqueous !
Cover ! Sludge !
j Two-Phase !
i Aqueous/Organic j
LHIUM ILL UIOI UOML.
acre —
16,650 ! 100.6 ! 11.1
i t
i i
16,650 ! 86.1 j 9.5
.5 acres —
116,500 i 358.1 39.4
i
i
116,500 j 299 32.9
acres —
166,500 j 510.9 j 56.2 |
i i i
166,500 j 427 j 47 j
! ! !
$0 $44,800
$0 $44,800
$0 ! $313,400
i
$0 ! $313,400
1
$0 | $447,300
$0 ! $447,900
I
1
See notes at end of table.
(continued)
C-79
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS*
sBi? | wjs&t \ ™*SUT 1 1 sal
! ! (Mg/yr) | (Mg/yr) j (Mg/yr) j
— CLOSING LANDFILL (D80G) -
C.Landf 1 1 1 | Aqueous
30 all-HOPE j Sludge
i Two-Phase
[Aqueous/Organic
C.Landf 1 1 1 j Aqueous
100BU-HQPEJ Sludge
! Two-Phase
i Aqueous/Organic
— CLOSING LANDFILL (D80H) -
C.Landflll j Aqueous !
SOall-HOPE | Sludge i
! Two-Phase ,'
! Aqueous/Organic!
C.Landflll j Aqueous !
lOOall-HOPEi Sludge \
! Two-Phase |
i Aqueous/Organic,1
— CLOSING LANDFILL (D80I) -
C.Landflll | Aqueous !
30BII-HDPE j Sludge i
! Two-Phase |
[Aqueous/Organic!
C.Landflll | Aqueous J
100HII-HDPE! Sludge !
I " Two-Phase J
! Aqueous/Organic!
LAWDFI
• 1 acre —
16,650 j
16,650 |
i
i
16,650 j
i
16,650 j
i
3.5 acres —
116,500
116,500
116,500
116,500
5 acres —
166,500
166,500
166,500
166,500
!" * • « MmSM.^. 1- « _ -^S£=J
0.020
0.6
0.020
0.6
0.068
2.09
0.068 '
2.09
0.0973 j
t
2.89 !
i
0.0973 j
i
2.89 i
t
0.019 j
0.29 |
i
i
0.019 i
0.51 |
i
0.0678
1.03
0.0679
1.77
0.0970 |
i
i
1.42 j
0.0972 j
i
2.45 1
i
===^;gjii-i— _ T--JI.
TOTAL
CAPITAL
INVESTMENT
$17,260
$17,260
$44,490
$44,490
$60,370
$60,370
$155,720 '
$155,720
$86,250
$88,250
$222,450
$222,450
TOTAL
ANNUAL
COSTS
$2,000
$2,000
$6,000
$6,000
$9,000
$9,000
$23,000
$23,000
$13,000
$13,000
$33,000
$33,000
See notes at end of table.
(continued)
C-80
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS*
b i
EMISSION !
CONTROL !
)EL
TYPE
ANNUAL
THROUGHPUT
(Mg/yr)
c
UNCONTROLLED
EMISSIONS
(Mg/yr)
d
EMISSION
REDUCTION
(Mg/yr)
TOTAL
CAPITAL
INVESTMENT
TOTAL
ANNUAL
COSTS
e
CONTAINER LOADING
— DRUM LOADING - 200 drunts/yr
Submerged
Fill Pipe
Aqueous
Sludge
Dilute
Aqueous- 1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
50
40
40
60
40
0.0018 |
0.0357
0.0068
0.0175
0.0150
0.0012
0.0232
.
0.0044
0.0114
0.0098
$390
I
$390
$390
$390
$390
$70
$70
$70
$70
$70
— DRUM LOADING - 2,200 drums/yr —
Submerged
Fill Pipe
•
.
-
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
560
450
440
610
440
0.0195
0.3900
0.0743
•
0.1910
0.1640
0.0127
0.2535
0.0483
0.1242
0.1066
$390
.
$390
$390
-
$390
$390
$70
$70
$70
$70
$70
TANK TRUCK LOADING —
Submerged
Fill Pipe
Aqueous
Sludge
Dilute
Aqueous-1
Organic
Liquid
Organic
Sludge/Slurry
Two-Phase
Aqueous/Organic
521
423
413
499
490
0.0045
0.0908
.
0.0169
'
0.0446
0.0385
0.003
0.059
0.011
0.029
0.025
$390
$390
$390
$390
$390
±==s=:==:=s===s
$70
$70
$70
$70
$70
See notes at end of table.
(continued)
C-81
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS9 (continued)
aThis table summarizes the control costs and emission reductions by process
unit for controlling organic air emissions from hazardous waste treatment
storage, and disposal facilities (TSDF). The control costs and achievable
emission reductions were estimated through a model unit analysis utilizing a
variety of diverse yet representative TSDF process model units, model waste
compositions or forms, and applicable control technologies. The costs (in
terms of 5/Mg of waste throughput) were then used to develop the control
technology and cost file (Appendix D, Section D.2.5) that is used in
combination with the TSDF Industry Profile (Appendix D, Section D.I.3) and
the waste characterization data base (Appendix D, Section D.I.4) to estimate
nationwide cost impacts for alternative control strategies.
The model wastes used in the determination of control costs and emission
reduction in the model unit analysis may not necessarily be representative-of
all actual waste streams processed at existing facilities. However, to the
extent possible, the composition and quantities of the actual waste streams
processed at existing facilities were used in estimating nationwide emissions
and emission reductions resulting from the alternative control strategies.
Please note that all costs presented in this table are in January 1986
dollars. J
bl- Carbon Adsorption—Two different carbon adsorption systems were examined
for application as control devices. One system involves the use of
fixed-bed, regenerate carbon adsorption units (FBCA); the other involves
use of disposable carbon canisters. Both carbon canisters and fixed bed
regenerate carbon systems were costed for each of the model unit/waste
form cases; the less expensive system was selected for application. The
fixed-bed carbon system's operating costs include the regeneration and
eventual replacement and disposal of spent carbon; carbon canister's
operating costs include carbon canister replacement and disposal. Carbon
adsorption can reasonably be expected to achieve a 95-percent control
efficiency for most organics under a wide variety of stream conditions
provided (1) the adsorber is supplied with an adequate quantity of hiqh
quality activated carbon, (2) the gas stream receives appropriate
conditioning (e.g., cooling, filtering) before entering the carbon bed,
and 13) the carbon beds are regenerated or replaced before breakthrough.
Internal Floating Roofs—Emission reductions for internal floating roofs
relative to a fixed-roof tank were estimated by using the emission models
5CcDA?d ln APPe"dix c- Section C.I.1.4.3 (fixed roof tank emissions)
and EPA's Compilation of Air Pollutant Emission Factors (AP-42)
Estimated emission reductions ranged from 74 to 82 percent. The varia-
tion in emission reductions is attributable to differences in composition
and concentrations of model wastes.
Internal floating roofs are applied to uncovered vertical tanks in
conjunction with a fixed roof to suppress the uncovered tank organic
emissions. For this combination, the emission reductions achievable are
a combination of the reduction from application of the fixed roof to the
2.
(continued)
C-82
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS9 (continued)
uncovered tank, plus application of an internal floating roof to a fixed-
roof tank. The range of emission reductions achievable based on
combination of the fixed roof with the internal floating roof is 96 to
99.
3 Existing Control Device—Venting organic emissions to an existing control
device -is assumed to achieve an overall emission reduction of 95 percent;
this includes both capture and control efficiencies.
4. Fixed Roof—Emission reductions for application of fixed roofs to
uncovered tanks ranged from 25 to greater than 99 percent depending on
waste form for both storage and treatment tanks.
5 Membrane—Floating synthetic membranes are applicable to quiescent
impoundments and uncovered storage tanks. Emission reductions are
determined by the fraction of surface area covered and by the perme-
ability of the membrane. An emission reduction of 85 percent was used
for floating synthetic membranes for purposes of estimating emission
reductions from membrane-covered impoundments.
6 ASP—This control alternative involves installing an air-supported
structure (ASP) and venting emissions to a carbon adsorption system. The
efficiency of air-supported structures in reducing or suppressing emis-
sions is determined by the combined effects of the capture efficiency of
the structure and the removal efficiency of the control device. An over-
all control efficiency of 95 percent is used for air-supported structures
vented to carbon adsorber.
7 HOPE—In this control technique, flexible covers are used to suppress or
TTiTt organic emissions from area sources. A typical cover material is
30-mil high-density polyethylene (HOPE). For the purposes of estimating
emission reductions, control efficiencies of 0, 49.3, and 99.7 percent
were used for 30-mil HOPE covers, depending on characteristics of the
waste (i.e., permeability). Emission reductions of 0, 84.8, and 99.9
percent were selected for the model wastes with a 100-mil HOPE cover.
The variations in emission reductions are attributable to differences in
composition and concentrations of the model wastes.
^Uncontrolled emissions were estimated for each model unit and waste type
using the appropriate TSDF air emission models as described in Section C.I;
the model unit design and operating parameters described in Section C.Z.I;
and the waste compositions listed in Appendix C, Table C-5.
^Emission reductions achievable through application of the emission control
technologies are calculated on the basis of the control efficiencies
presented in Chapter 4.0. These emission reductions can be grouped into
three broad categories based on the technologies involved:
(1) Suppression Controls-- Emission reduction are achieved by controls
that contain the organics within a confined area and prevent or
limit volatilization of the organics. Unless used in combination
with add-on control devices, the organics may be emitted from a
(continued)
C-83
-------
TABLE C-6. SUMMARY OF TSDF MODEL UNIT ANALYSIS RESULTS* (continued)
(2)
downstream TSDF waste management process. Suppression devices
include internal floating roofs for covered or closed tanks and
floating synthetic membranes for impoundments.
Add-on Controls—Emission reductions are achieved by add-on controls
that adsorb, condense, or combust the volatile organics and as a
I?SUItupUevenJ their release to the atmosphere. Examples include
nxed-bed carbon adsorbers, condensers, thermal or catalytic
incinerators.
total capital investment and total annual costs for the Container
rail tank°car ^ ^ "^ f°r drUm Ioad1ng' tank truck loading, and
C-84
-------
of different compositions and forms are managed in that unit. The table
also shows that control costs for certain controls are independent of waste
composition, e.g., fixed roof for storage tanks and floating synthetic
membranes. At the opposite extreme, the costs for fixed-bed carbon
adsorption controls (e.g., those applied to uncovered, aerated treatment
tanks model unit T01G) are highly sensitive to composition; i.e., bed size
is a function of the level or quantity of uncontrolled emissions.
The emission reductions reported in Table C-6 are achieved through
application of control technologies that can be classified into two broad
categories based on the control mechanisms. Suppression controls contain
the organics within a confined area and prevent or limit volatilization.
Add-on controls are typically conventional air pollution control devices
that adsorb, condense, or thermally destroy the volatile organics to
prevent release to the atmosphere.
The footnotes to Table C-6 explain an important point about the
reported emission reductions. Controls, such as a fixed roof applied to a
storage tank, suppress organic emissions from that tank by the amount
indicated in the table. The emissions prevented by installation of a fixed
roof may escape from the waste at some downstream waste processing step
unless emissions from that downstream process are also controlled. The
emission reductions achieved through suppression controls are truly
emission reductions only if the suppressed emissions are prevented from
escaping the waste processes at other downstream processing steps. Add-on
controls (such as carbon adsorption and vapor incineration) and/or biolog-
ical decay to less volatile compounds are the principal approaches to avoid
ultimate discharge to the atmosphere.
C.3
1.
2.
REFERENCES
Research Triangle Institute. Hazardous Waste Treatment Storage, and
Disposal Facilities: Air Emission Models, Draft Report. Prepared for
U.S. Environmental Protection Agency. Office of Air Quality Planning
and Standards. Research Triangle Park, NC. March 1987.
U.S. Environmental Protection Agency. Hazardous Waste Treatment,
Storage, and Disposal Facilities (TSDF)—Air Emission Models.
Publication No. EPA-450/3-87-026. Research Triangle Park, NC. Office
of Air Quality Planning and Standards. December 1987. p. 4-41 to
4-49.
C-85
-------
3. Springer, C., P. D. Lunney, and K. T. Valsaraj. Emission of Hazardous
Chemicals from Surface and Near Surface Impoundments to Air. U.S
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-89-023a
4. TITLE AND SUBTITLE
Hazardous Waste TSDF - Background Information for
Proposed RCRA Air Emission Standards
Volume I - Chapters 1-8, & Appendices A-C
7. AUTHOR(S)
5. REPORT DATE
June 1991
6. PERFORMING ORGANIZATION CODE
5. RECIPIENT'S ACCESSION NO.
8. PERFORMING ORG/
9. PERFORMING ORGANIZATION NAME AND ADDRESS
• Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
1C. PROGRAM ELEMENT
11. CONTRACT/GRANT NO.
68-02-4326
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air and Radiation
U.S. Environmental Protection Agency
Washington, B.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Interim Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Air emission standards are being proposed under the Resource Conservation
and Recovery Act for hazardous waste treatment, storage, and disposal facilities
(TSDF) to reduce emissions of ozone precursors (volatile organic compounds) and
exposures to hazardous air pollutants. This document contains background
information and environmental and economic assessments of regulatory alternatives
considered in developing the proposed standards. The regulatory alternatives
consider application of air pollution controls on tanks, surface impoundments,
and containers used to manage hazardous waste at TSDFs, as well as at generators
using tanks and containers to accumulate large quantities of waste on site. This
document is divided into a three volume set.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COSATI Field/Group
Air Pollution
Volatile Organic Compounds
Hazardous Waste
Treatment
Storage
Disposal
Air Pollution Control
13b
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (Til
Unclassified
346
2O. SECURITY CLASS (This page/
Unclassified
22. PRICE
EPA Form 2220-1 (R»v. 4-77) PREVIOUS EDITION is OBSOLETE
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