RCRA TSDF Air Emissions Background Technical Memoranda For Proposed Standards

&EPA
           United States
           Environmental Protection
           Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/3-86-009
October 1986
           Air
RCRATSDF

Background
Technical
Memoranda for
Proposed
Standards

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                                EPA-450/3-86-009
   RCRA TSDF Air Emissions —
Background Technical Memoranda
       for Proposed Standards
          Emission Standards and Engineering Division
          U.S. ENVIRONMENTAL PROTECTION AGENCY
               Office of Air and Radiation
          Office of Air Quality Planning and Standards
             Research Triangle Park, NC 27711

                  October 1986

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This report has been reviewed by the Emission Standards and Engineering 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, North Carolina 27711; or, for a fee, from
the National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.

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                                 CONTENTS
Section                                                                Page
         Fi gure	       v
         Tables	       v
  1.     INTRODUCTION AND OVERVIEW.
  2.     SUMMARY OF STUDY APPROACH AND ESTIMATES	   '    3
         2.1  Approach	       3
         2.2  Emissions	       3
         2.3  Costs	       5
         2.4  Health	       6
         2.5  Summary of Results	       7
         2.6  Uncertainties in the Analysis	       7
  3.     KEY TO LOCATION OF SPECIFIC INFORMATION DEVELOPED
         UNDER THESE ASSIGNMENTS	-		      13
Attachment
  1.     DRAFT MODEL FACILITY PARAMETERS
  2.     REVISED MODEL FACILITY PARAMETERS
  3.     HEM INPUTS
  4.    "CHEMICALS OF CONCERN
  5.     INCINERATOR COST ESTIMATES
  6.     PRELIMINARY NATIONWIDE RISK ESTIMATES
  7.     REVISED COST FOR FUGITIVE EMISSION CONTROLS
  8.     NATIONWIDE EMISSION AND COST ESTIMATES
  9.     DRAFT IMPACTS FOR TSDF WITH ORGANIC  WASTE STREAMS
                                     m

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                           CONTENTS (continued)





Appendix



  A.     REFERENCES



  B.     HEM RESULTS FOR WSTF MODEL CASES



  C.     ADDITIONAL DOCUMENTATION
                                     IV

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                                  FIGURE
Number
  2-1    Flow diagram for WSTF analysis,
Page
   4
                                  TABLES
Number
2-1
C. i
2-2
C. C—
2-3
2-4
3-1

Summary of Model Plant Parameters and Emission Rates 	
Summary of Model Facility Control Cost Estimates 	
Summary of Typical and Upper-Bound Estimates of
Nationwide Emissions and Control Costs for 95 Plants 	
Summary of Nationwide Emissions and Costs for TSDF in
Key to Location of Major Work Outputs and Assumptions 	
Page
8
9
10
11
15

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                       1.  INTRODUCTION AND OVERVIEW

     The Emission Standards and Engineering Division (ESED) of the U.S.
Environmental Protection Agency's (EPA's) Office of Air Quality Planning
and Standards (OAQPS) is responsible for developing regulations under the
1976 Resource Conservation and Recovery ACT (RCRA) and its 1984 amendments
to control air emissions from hazardous waste treatment, storage, and
disposal facilities  (TSDF).  As part of the Office of Solid Waste (OSW)
effort to ban solvents from land disposal and as part of the OAQPS effort
to control air emissions from TSDF,  ESED is studying what air pollution
regulations are appropriate for waste solvent treatment facilities (WSTF)
and TSDF.  The purpose of this Technical Note is to present information
developed by Pacific Environmental Services (PES) and the Research Triangle
Institute (RTI) under assignments for ESED to support an accelerated e'ffort
to regulate WSTF and TSDF.
     Under these assignments,  PES reviewed available information on
treatment technologies for waste solvents and developed order-of-magnitude
emission, cost, and health input estimates associated with air pollution
from WSTF.  The scope of these impact analyses was limited to vapor-phase
mass transfer treatment technologies (e.g., distillation, steam stripping)
because sufficient information was available for only these techniques.
The sources of process and fugitive emissions from these technologies are
generally similar.  Under these assignments, RTI extended the WSTF-based
analysis to TSDF in general.  Consequently, the approach used to evaluate
emissions and controls was a general one, and not particular to a specific
treatment technology.
     A summary of the impact estimates and the approach to development of
the estimates are summarized in Section 2 of this Technical Note.  The

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general approach to development of the impact estimates included
(1) approximating nationwide impacts by using an average of typical  basis,
and (2) approximating the risk of cancer incidence to the most exposed
individuals by using a reasonable worst-case basis.   In reviewing and then
selecting the basic facts to fill in as the basis of the impact estimates,
this general approach was followed.   Section 3 presents a key to where
specific information developed under these assignments is located.   The
detailed basis of the analyses is presented in Attachments 1-9 as a  series
of memoranda from PES and RTI staff  to the ESED Task Manager.

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                2.  SUMMARY OF STUDY APPROACH AND ESTIMATES

2.1  APPROACH
     Vapor-phase mass transfer operations separate solvent waste
constituents through volatilization and condensation of the more volatile
components in the waste stream.  The approach taken in the estimation of
order-of-magnitude emission, cost, and health impacts for WSTF is shown in
Figure 2-1 and is based on the general similarity of equipment and opera-
tions, i.e., the operation of distillation,  steam stripping, and thin-film
evaporation all have a common process emission source and common fugitive
emission sources.  The common process source is the column condenser vent.
The fugitive emission sources common to these operations are pumps, valves,
flanges, sampling connections, open-ended lines or valves, and pressure
relief devices.  These sources also are common to TSDF in general.
2.2  EMISSIONS
     Order-of-magnitude emission estimates were developed for these
treatment operations by developing generic parameters for process and
fugitive emissions from a model WSTF facility based on information in
reports provided by ESED, as well as using judgment to develop best
estimates of parameters.  The background information in these reports is
summarized in the attachments, and the reports are referenced.  The
estimates then were extrapolated to TSDF in  general.  Because insufficient
information was available to characterize the specific compositions of the
waste solvents and other hazardous wastes beyond total volatile organic
(VO) content, the uncontrolled process and fugitive emission rate could not
be precisely quantified on a chemical-by-chemical basis.  Thus, to provide
a broad overview of potential emissions (and costs and health impacts),
estimates were developed of the maximum process emission rate expected for

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                         Characterize model
                               facility
 Estimate likely and upper-
 bound process emission
  rates for model facility
      Estimate fugitive
      emission rate for
       model facility
Estimate cost of controlling
   model facility process
emissions with condenser,
   flare, and incinerator
    Estimate cost of leak
detection and repair program
      for model facility
                     Estimate health impacts due
                       to model facility process
                        and fugitive emissions
                      Estimate number of model
                       facilities required to treat
                     total quantity of solvent waste
               Estimate nationwide emission, health, and
                 cost impacts from expected number of
              model facilities required to treat solvent waste
              Figure 2-1. Flow diagram for WSTF analysis.

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highly volatile solvents and of a likely, or typical, process emission rate
from a WSTF.  These emission rates were developed from a broad collection
of information and should reflect a cross section of the process emission
rates.  Fugitive emissions from the model WSTF were estimated using
synthetic organic chemical manufacturing industry (SOCMI) emission factors,
and the equipment count was specified in the benzene fugitive emission
standard model Case A.  This basis was judged to be representative of the
size and emission factors for WSTF and TSDF in general.*
2.3  COSTS
     Estimates were developed of the range of costs to control process
emissions and the cost to control fugitive emissions from a WSTF model
facility.  These estimates were used to estimate the upper-bound and likely
lower-bound costs to control air emissions from WSTF.  Specifically, order-
of-magnitude cost estimates for process emission control were estimated
assuming application of a 95-percent efficient secondary condenser, flare,
or incinerator to the generic model facility condenser vent.  The cost for
secondary condenser control was used to estimate the likely or expected  .
control costs, and the average of the cost to incinerate or flare emissions
was. used to estimate the upper, bound for per plant process emission control
costs.  The cost to operate an inspection and maintenance program to reduce
fugitive emissions was estimated using the fugitive emission cost algorithm
developed by EPA for estimating the cost of controlling benzene fugitive
emissions.  These costs were extrapolated to TSDF in general.
     In estimating likely lower-bound and upper-bound per plant costs of
control for process emissions, it was necessary to specify model emission
streams to be treated by a secondary condenser, flare, or incinerator.
Methyl ethyl ketone (MEK) and toluene were selected as representative of
typical nonhalogenated emission streams, and 1,1,1-trichloroethane was
chosen to represent a typical halogenated emission stream.
*The emission factors were not adjusted for the waste stream composition as
was done in the WET model because part of the equipment contacts the
purified solvent or full-strength organics and the estimates are intended
to be order-of-magnitude.

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     The per plant ranges of emission and cost estimates were projected to
a nationwide basis using an estimate of the number of model facilities
required to treat an estimated 436 x 106 gallons (gal) of waste solvent per
year.*  The number of model facilities was derived from the estimated
average solvent recovery rate (I.e., the volume of solvent recovered to the
volume of waste solvent treated at the facility) and the expected total
volume of waste solvent.
     In estimating lower-bound, or typical, nationwide control costs, it
was assumed that all plants would use secondary condensers to control proc-
ess emissions.  In estimating upper-bound nationwide costs, it was assumed
that approximately 50 percent of the total number of plants would treat
halogenated compounds (and use incinerators for process emission control),
and approximately 50 percent would treat nonhalogenated compounds (and use
flares for process emission control).
2.4  HEALTH
     Order-of-magnitude health impacts were estimated for cancer risks from
exposure to air emissions from WSTF.  These impacts were extrapolated to
TSDF in general.  Although cancer risks are not the only health impacts
associated with air emissions from WSTF, they are the.most available meas-
ure of direct health effects associated with chronic low-level exposures to
organic solvents.  The Human Exposure Model (HEM) was used to calculate the
magnitude of risks posed by WSTF at both typical and maximum emission
rates.  Based on EPA's efforts to locate WSTF and then perform surveys of
these facilities, EPA selected an urban/rural  distribution and specific
locations (where actual  WSTF are located) to approximate this distribution
in performing the risk assessment.  In doing this,  EPA also selected the
population and meteorologic conditions needed for using the HEM.  In addi-
tion, health impacts were evaluated for a range of unit risk factors (i.e.,
2 x 10~7 and 2 x 10~5 cases/^g/m3-person).  The range of unit risk factors
was based on an analysis of the organic chemicals associated with TSDF
operations.  This analysis found that carbon tetrachloride is the organic
*The estimate of the quantity of solvent waste to be treated per year was
provided by OSW.  Note that 1 gal = 3.785 liters (L).

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chemical with the most individual impact vis-a-vis emissions and risks.
Thus, it was used as the upper bound on the range of unit risk factors.
The nationwide annual cancer incidence was calculated as the average annual
incidence considering the projected number of WSTF and the range in
emission rates, geographic location, and urban/rural sites expected for
WSTF.  The risk of cancer for the most exposed individuals was calculated
as the largest expected risk resulting from the largest emission rate,
highest exposure location, and highest unit risk factor.
2.5  SUMMARY OF RESULTS
     Table 2-1 presents a summary of the model WSTF parameters and emission
rates, and Table 2-2 presents the range and average of the per plant emis-
sion control cost.  Nationwide emissions and costs for WSTF are summarized
in Table 2-3.  Nationwide emissions and costs for TSDF in general are sum-
marized in Table 2-4.
     The order-of-magnitude health impact analysis showed the emission
controls would reduce the individual maximum lifetime risk (MLR) of cancer
from WSTF operating at the upper-bound emission rate from about 3.7 x 10~3
to 2.6 x 10~4.  The nationwide annual  incidence of cancer in the population
living within 50 kilometers (km) (1 km = 0.62137 mile [mi]) of uncontrolled
WSTF is estimated to be about 3.4 cases/year (yr) assuming the higher risk
factor.  With the process and fugitive emission controls evaluated in this
study, this nationwide evidence rate would be reduced to about 0.3 case/yr.
2.6  UNCERTAINTIES IN THE ANALYSIS
     It should be recognized that these order-of-magnitude emission, cost,
and risk estimates possess considerable uncertainty.  Even though these
estimates were developed using the best available information, they are
imprecise because of a paucity of specific information on WSTF and TSDF
operations and inconsistencies in the available information.  Considering
the lack of available information,  ranges of impact estimates were devel-
oped to bound what the true impacts might be.  Judgment then was used to
identify the most likely or "typical"  impact estimates within each range.
The value selected as the likely impact estimate within each range was
chosen such that potential error should be on the conservative side, unless
other factors indicated that another value within the range would represent
a better estimate.

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     TABLE 2-1.  SUMMARY OF MODEL PLANT PARAMETERS AND EMISSION RATES
              Item
         Value
General plant operation

  Waste solvent reclaimed per year

  Emitting hours for condenser
  Emitting hours for fugitive
    emission sources

Condenser vent stream emission
  characteristics

  Temperature, *F
  Flow rate
  VO emission rate
    Likely
    Upper-bound

  Fugitive emission sources
8 gigagrams/year (Gg/yr)

4,160 hours/year (h/yr)
8,760 h/yr
75 »F
26 scfrn3

7 pounds/hour (-lb/h)
75 lb/h

13.5 megagrams/year (Mg/yr)
ascfm = cubic feet per minute at specified standard conditions of
 temperature and pressure.

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                   TABLE 2-2.  SUMMARY OF MODEL FACILITY CONTROL COST ESTIMATES
Emi ssion
Control device rate, Ib/h
Condenser vent
Case 1 7
Secondary condenser
Flare
Incinerator
Case 2 32 to 75
Secondary condenser
Flare
Incinerator
Fugitive sources
LDR program 3.47
Capital cost, 1985 3
Range
2,630 to 3,850
81,000 to 91,000
NAa
21,000 to 29,000
81,000 to 91,000
NAa
NAa-
Average
3,270
86,000
209,000
25,000
' 86,000
209,000
26,960
Annual! zed cost, 1985 S/yr
Range Average
1,425 to 1,885 1,660
52,000
NAa 164,100
4,700 to 6,400 5,500
43,000
NAa 150,900
NAa 11,900
LDR = Land disposal restrictions.
 NA = Not applicable.

"Only average value calculated.

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           TABLE 2-3.  SUMMARY OF TYPICAL AND UPPER-BOUND ESTIMATES OF
               NATIONWIDE EMISSION AND CONTROL COSTS FOR 95 PLANTS •
Typical

VO emissions, Mg/yr
(tons/yr)
Uncontrolled
2,550
(2,810)
Controlled
400
(440)
Upper-bound
Uncontrolled
14,740
(16,250)
Controlled
1,010
(1,110)
Control costs3
Capital cost, $
Annual cost, $/yr
Recovery credit, $/yr^
Net annual cost (with
recovery credit), $/yr
NA
NA
NA
NA

2,872,000
1,288,000
(1,176, 000)c
112,000

NA
NA
NA
NA
-
16,635,000
10,970,000
(429,000)c
10,541,000

NA = Not applicable.

aAll costs are in June 1985 $.
^Recovery credits were estimated assuming a recovered solvent value of $450/Mg.
c(  ) indicates a cost credit.
                                      10

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           TABLE 2-4.  SUMMARY OF NATIONWIDE EMISSIONS AND COSTS
                           FOR TSDF IN GENERAL3

                                      Uncontrolled         Controlled

VO emissions, Mg/yr                      17,800   '              4,500

Control  costs

   Capital cost, $                         NA              35,000,000
   Annual cost,  $/yr                       NA               9,600,000

NA = Not applicable.

aEstimates shown include only fugitive emissions.
                                      11

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     The major deficiencies in the available information were:

     •     Characterization of WSTF.  The number of facilities, the
           distribution of production capacities (and typical capac-
           ity), and geographical  distribution were not well defined
           in the available reports, or only a single estimate was
           available.  For example,  the number of facilities treating
           waste solvents was estimated to range from about 60 to 400
           based on information in various reports, and production
           capacity estimates were available from essentially only two
           surveys.

     •     Waste Stream Characterization.  Information on specific
           composition of waste streams appeared to be highly uncer-
           tain because the original survey data did not include com-
           position by constituent and subsequent estimates were
           derived from these data using several assumptions.

     •     Emission Rate and Stream Characterization.  Very little-
           information was availalbe on emission stream composition
           (temperature, flow rate,  and concentrations) and on uncon-
           trolled emission rates.  The available information on emis-
           sion rates was based on a small number of tests conducted
           at unknown operating conditions and waste streams of
           unknown composition.

     Consequently, the emission,  cost, and risk estimates that were

developed reflect judgments on the best estimate of many of the parameters,

Such judgments were made on characterization of WSTF operation, waste

stream composition, the range of possible emission rates, emission stream

parameters,  and possible range of unit risk factors.  The estimates, there-

fore, are believed to be useful for presenting a broad overview of the

potential impacts of the control  of air emissions, but not for precisely
quantifying the impacts.
                                      12

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        3.  KEY TO LOCATION OF SPECIFIC INFORMATION DEVELOPED UNDER
                             THESE ASSIGNMENTS
     The memoranda prepared under these assignments and included as
attachments to this Technical Note are listed below:
Attachment No. 1.  Memorandum from Meyer, J., and Fitzsimons, G., Pacific
     Environmental Services, to Dimmick, F., U.S. EPA:ESED:SDB.
     October 21, 1985.  Model facility parameters and draft control cost
     estimates.

Attachment No. 2.  Memorandum from Meyer, J., Pacific Environmental Ser-
     vices, to Dimmick, F., U.S. EPA:ESED:SDB.  October 23, 1985.  Revi-
     sions to draft model facility parameters and draft condenser cost.
     estimates.

Attachment No. 3.  Memorandum from Fitzsimons, G., Pacific Environmental
     Services, to Dimmick, F., U.S. EPA:ESED:SDB.  October 30, 1985.
     Revised HEM modeling inputs for WSTF model plants.

Attachment No. 4.  Memorandum from Meyer, J., Pacific Environmental Ser-
     vices, to Dimmick, F., U.S. EPA:ESED:SDB.  October 31, 1985.  Chemi-
     cals covered in land banning action.

Attachment No. 5.  Memorandum from Meyer, J., Pacific Environmental Ser-
     vices, to Dimmick, F., U.S. EPA:ESED:SDB.  October 31, 1985.  Revised
     incinerator cost estimates and additional cost estimates for secondary
     condenser control.

Attachment No. 6.  Fitzsimons, G. (Pacific Environmental Services).  Pre-
     liminary Estimate Using Model Plant Approach of Nationwide Maximum
     Risk and Incidence Associated with Air Emissions from WSTFs.
     November 11, 1985.  5 p.

Attachment No. 7.  Memorandum from Fitzsimons, G., Pacific Environmental
     Services, to Dimmick, F., U.S. EPA:ESED:SDB.  January 24, 1986.
     Revised costs for fugitive emission control at a model WSTF.
                                      13

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Attachment No. 8.  Memorandum from Fitzsimons, G., Pacific Environmental
     Services, to Dimmick-, F., U.S. EPA:ESED:SDB.  January 24, 1986.  Esti
     mates of nationwide emissions and cost of control for waste solvent
     treatment facilities (WSTFs).

Attachment No. 9.  Memorandum from York, S., Research Triangle Institute,
     to Dimmick,  F., U.S. EPA:ESED:SDB.  June 5, 1986.  Draft calculation
     of impacts for proposed WSTF standards.

     Table 3-1 presents a key to where major work outputs and assumptions
are located in the attachments.
                                      14

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     TABLE 3-1.  KEY TO LOCATION OF MAJOR WORK OUTPUTS AND ASSUMPTIONS

                                                  Attachment no.
                Item                    123456789

General model facility
  characterization

   Waste solvent reclamation rate	D   F
   Operating hours	 D   F
   Chemicals of concern	             F
   Model chemicals selected	 DDF
   Equipment count (for fugitive
     emission estimate)	 F
   Process emission stream
     temperature	 D   F   F

Per plant VO emission estimates

   Uncontrolled and controlled
     process emission rate range	 OFF
   Uncontrolled and controlled
     fugitive emission rate	 OFF
   Range of per plant total
     emissions	:	                             F

Per plant control  cost estimates

   Incinerator control of process
     emissions	 D               F
   Flare control of process
     emissions	 F
   Condenser control of process
     emissions	 D   D           D           F
   Fugitive emission control	 D                       F
   Range of total  per plant costs
     for process and fugitive
     controls	                             F   F

Estimate of nationwide emission and
  cost impacts (WSTF/TSDF)		                             F

Preliminary risk assessment

   Model case inputs to Human
     Exposure Model (HEM)	         F
   Estimate of maximum lifetime
     risk and nationwide annual
     incidence	                     F

D = Draft (subject to revision in a latter attachment).
F = Final estimate used.
                                      15

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     Standards for the control of volatile organic (VO) air emissions from
hazardous waste treatment, storage, and disposal facilities'(TSDF) and
waste solvent treatment facilities (WSTF) are being proposed under the
authority of Section 3004(n)  of the 1976 Resource Conservation and Recovery
Act (RCRA).  These standards  would apply to certain process vents
associated with distillation  and stripping equipment at WSTF (and at TSDF,
if applicable) and to fugitive emissions from equipment leaks at TSDF where
the waste stream (or its derivatives)  contain 10 percent or more total
organics.  This document contains a technical note and background memoranda
considered in developing the  proposed standards.
                                      16

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ATTACHMENT 1

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                                                                OCT 2 1  1S85

                                                              DRAFT
                          MEMORANDUM
 SUBJECT:   Model  Facility Parameters and Draft Control Cost Estimates

 TO:        Fred Dimmick, SDB

 FROM:      Jan Meyer,  PES
           Graham Fitzslmons, PES
      The model  facility parameters recommended for waste solvent treatment
 facilities  (WSTF's) and the basis for recommendation of these  parameters
 are  presented in this memorandum.  In addition,  draft estimates  of  control
 costs are presented for 95 percent control  of condenser vent emissions
 by an incinerator, a flare, or a condenser and for control  of  fugitive
 emissions using an inspection and maintenance program.

 II.   Discussion

     A.  Model Facility Parameters

     Model  facility parameters were developed to characterize  emissions
 and  costs for control of air emissions from WSTF's using distillation
 treatment technologies.   The analysis is being limited  to distillation
 technologies because of (1) their greater potential  for significant air
 emissions and (2) the paucity of information on  treatment of highly
 aqueous-organic streams and the applicability of previously  developed
 control requirements to these technologies.

     Model facility parameters were developed to characterize  both
 process and fugitive emissions from distillation treatment  technologies
 at WSTF's.  Process emissions from distillation  technologies (these
 operations include distillation,  steam stripping,  thin  film  evaporation,
 and air stripping)  consist mainly of  emissions from  the  condenser vent.
 Consequently,  for the purpose of  the  cost and emission  rate* analyses,
 model operating conditions and condenser  vent characteristics were
 developed.   The recommended parameters for  process emissions and the
 basis for the  recommendations are summarized  in  Table 1.  These parameters
are considered to represent best  judgments  of reasonable  values for the
 parameters based on our  review of the  information  provided on WSTF's
and distillation operations in Synthetic  Organic Chemical Manufacturing
*This emission rate is  the  rate  per quantity of reclaimed solvent.
 Emission rates used to  estimate nationwide emissions will be developed
 from these rates using  best estimates of recovery rates for concentrated
 organic liquids and for aqueous-organic liquids.

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 Industry (SOCHI').   Since WSTF operations are expected  to be predomi-
 nantly batch operations, the  use  of SOCMI  distillation  column  parameters,
 which are continuous operations,  is expected to  introduce errors  of
 unknown direction  and magnitude.   Furthermore, because  of considerable
 uncertainty on  emission  rates from condenser vents  from batch  operations
 two estimates of emission  rates are presented  in Table  1  to allow
 development of  upper and lower bound emission  estimates.

 om,-c Becauf °f the  similarity of  equipment  and operations,  fugitive
 emissions from  WSTF's were  characterized using information  developed in
 VOC Fugitive Emissions in SOCMI and in Benzene Fugitive Emissions

                               ^  reCOmmended ^™»*  '"v.ntory and
     8.  Cost Estimates
     Cost estimates were developed for application of a control device
to the condenser vent and for implementation of a fugitive emission
inspection and maintenance program.  Cost estimates were developed for
control of the condenser vent stream using a condenser, an incinerator
or a flare to present the range of control options available to WSTF's'
JJeSi?0IJ es5lmates were developed using cost algorithms developed in'
Distillation Operations in SOCMI and Polymers and Resins.

     Table 3 summarizes the preliminary cost estimates developed for
incinerator or flare control  of condenser vent emissions, and Table 4
presents preliminary cost estimates for secondary condenser control of
these emissions.   Table 5 presents the estimated emission'reduction
annualized cost,  and cost effectiveness for a fugitive emission control
program at a WSTF.   Appendix  A presents the basis for the control  cost
estimates for control  devices applied to the condenser vent

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TABLE 1. ^OEL FACILITY: PROCESS EMISSIONS
I
I Recommendation
3asis
Comments
PLANT
OPERATION:

• aste Solvent
Reclamation
Rate
|8000 Metric Tons per
year
Operating Hours |4160 per year
Condenser Stream
Cases
CONDENSER VENT
STREAM EMISSION
CHARACTERISTICS:

Temperature

Flowrate
1(1)
1(2)
1(3)
991 Haxane
99% Toluene
99% 1,1.1
tricnloroetnane
!75°F
I

126 scfm
/OC Emission Rate|7-d2 Ib/nr
Subjective judgement after
reviewing 1978 EPA Source
Assessment,1'
1/30/81 Engineering Science
Memorandum,2
SOCHI Distillation NSPS BID,
ana RTI/Radian site visit
reports.
Intermittent operation:
2 smfts/day x 5 day/wn x
52 wK/yr.

Supjective judgment after
review of references 1-5.
RTI/Engineenng Science site
visit reports.

SOCMI Distillation NSPS BID,
"Case 5" (page 3-15).
IMost solvent reclamation plants
I appear to Oe in tne range of 2-4000
(metric tons/yr. A size at tne
[large and of tms range was cnosen
because some model plant parame-
ters (e.y., airflow) are being
[based on SOCHI Distillation, and a
jlarye solvent reclamation facility
|is closer to a small SOCHI Distil -
jlation facility.
Lower limit based on avg.
AP-42 emission factor (1.7g
YOC/kg reclaimed solvent)
applied to 3000 metric cons/yr
plant. Upper limit is
Range was about 50-30° F. Highest
i used was 90°F in ICF report.1* ••

I Range of flowrates reported for all
[SOCHI Distillation facilities was
0.005-637 scfm. No correlation of
plant size -and flowrate possible.
No information found on flowrates
at waste solvent recovery
facilities.

|AP-i2_factor used in GCA Tecn-
jnote.5 (Range of AP-42 factor is
10. 26-4. 17 g/icg reclaimed solvent).
Range of SOCHI Distillation
emission rates reported was 0-3668
emission rate snown for Case 5|lb/hr, witn 78 Ib/hr tne average.
(cited above) in SOCMI
distillation BID.
Example material oalance in EPA
Source Assessment (page 22) indi-
cate oiucn lower emission factor.
'•"Source Assessment: Reclaiming of Haste Solvents, State of tne Art," EPA-600/2-78-004f, Aon! 1978.

^Memorandum, "Development of a Control Tecnnology Guideline (CTG) Document for tne Waste Solvent Recovery
Industry," from L.L. Lloyd of Engineering Science to F.L. Porter of EPA/ESED.

'"Preliminary Assessment of Hazardous Waste Pretreatment as an Air Pollution Control Tecnmque," prepared
oy 3TI for EPA/-IERL, Octooer 15, 1984.

4"The RCRA Risn-Cost Analysis Model - Phase III Report," prepared by ICF, Inc. for tPA/OSW.'Marcn 1, 1984.

'Draft Tecnnical Note, "Emission Algorithm Development for Pretreatment Operations," prepared oy GCA Corp.
for EPA/ESED/CPB, July 1985.

-------
                           TABLE  £.  MODEL FACILITY:   FUGITIVE EMISSIONS ESTIMATE
   Item
Operating Hours
Source Inventory
Emission Factors
?or teaks from
Equipment
  Recommendation
8760 h/yr
Mode] Unit A In
Benzene Fugitive
Emissions Standard
(See Attachment 1)
SOCMI Factors
(See Attachment 2)
       Basis
Assumes system Is not purged
between batches.
Smallest reviewed Inventory
available.
SOCMI factors are for fairly
comparable composition
streams.
                                                                                    Comments
SOCMI uses 8760 h/yr field reports
hrs highly variable ( 4000 h/yr to
8760 h/yr).
Available Information on equipment
counts Is poor.  GCA TechNote
Inventory Is for a very small pot
still and Is very loosely derived
from SOCMI Case A model unit.
Factors will overestimate emissions
from aqueous-organic streams.  The
factors could be weighted by
average organic content'of streams
but that would require apportioning
the equipment between 2 types of
streams.

-------
                         TABLE 3.    SUMMARY  OF  CONTROL  COST ESTIMATES FOR WSTF
                          DISTILLATION  VENTS - INCINERATOR AND FLARE CONTROL2

                                             (June 1985 dollars)
Stream6
Item
Control SystemC.e
Control costs:
Capital, J
Opera tlngf, S
Total annuallzed.l'f, $
Annual emissions, t/yr
Case 1
VOC • 7 Ib/h
Toluene
Flare

81,000
39,800
52.000
14.56
Case 2
VOC » 82 Ib./h
Toluene
Flare

81.000
30,000
43,000
170.56
Case 3
VOC - 7 Ib/h
Hexane
Flare

91.000
39.800
52.000
14.56
Case 4
VOC - 82 Ib/h
Hexane
Flare

91,000
30.000
43,000
170.56
Case 5
VOC • 7 Ib/h
Trlchloroe thane
Incinerator

758.000
159,000
312,000
14.56
Case 6
VOC * 82 Ib/L
Trlchloroe thane
Incinerator

• 758,000
140,000
293,000
170.56
 Cost estimates are developed using Radian's "Documentation for the  Synthetic Organic Chemicals Manufacturing  Industry
 (SOCHI)  Incinerator/Flare Costing Algorithm."
b
 Stream characteristics  - 26 scfm at 75* (assumed to consist of VOC  and nitrogen).

 Flare system costs Include flare stack, flare  tip. knock out drum,  seal. 400 ft length  duct work, and 350 ft  pipe rack.
 It Is not known If the  total costs Include  a compressor.  Incinerator System costs include combustion chamber,  150 ft
 duct work, fan, stack,  and quench/scrub system.  It Is unknown If the system Includes a heat exchanger.
d
 Based on 4,160 annual operating hours,  15 years life for flares, 10 years life for Incinerators, and 10  percent  Interest
 pates.
e
 For cases 1 through 4.  lowest size flares (I.e., 2 In. dla and 30 ft high) are required, and for cases 5 and  6,  lowest
 size Incinerators (I.e., 1 mj combustion chamber) are required.
f
 Calculations for case 5 resulted In negative fuel costs.

-------
                        TABLE 4.   SUMMARY  OF CONTROL COST ESTIMATES FOR  WSTF
                               DISTILLATION VENTS -  CONDENSER  CONTROL
Stream
Item
Control SystemC.e
Control costs:
Capital, J
Total annuallzed, $
Recovery Credit, $
Net Annuallzed, $
Annual Emission Reduction,
ton/yr
Cost Effectiveness, J/ton
Case 1* Case 2
VOC « 7 Ib/h VOC « 82 Ib/h
Toluene Toluene
Condenser Condenser

3,336 b
1.631
(4.230)
(2.599)
13.83 162
(178.50) b
Case 3*
VOC - 7 Ib/h
Hexane
Condenser

2,843
1.398
(4,479)
(3.081)
13.83
(211.61)
Case 4
VOC - 82 Ib/h
Hexane
Condenser

b



162
b
Case 5*
VOC • 7 Ib/h
Trlchloroe thane
Condenser

2.280
1.219
(921)
298
13.83
20.46
Case 6
VOG « 82 Ib/h
Tr1chloroethan€
Condenser

b



162
b
 Cost estimates were developed using PES'  condenser  cost algorithm 1n "Polymers Manufacturing NSPS"; all costs  are 1n
 June 1980 dollars.                                   "                                 •

b
 Cost estimates will be developed using standard cost estimation procedures and vendor data  for condenser costs.

-------
TABLE  5.   DRAFT  FUGITIVE  EMISSION REDUCTIONS  AND  CONTROL COST  ESTIMATES
                          .NUfflER   SfcMJfiL   OCTROI  DHSSION CflPITPL  ANNUSLIL £C2V£RY   CCST
                          OF      BUSS.   ZFFIC.   SEDUCTION  COST     1^37    ISaiT  EFFECT.
    31ISSICN SOUSCE         SOURCES  (Sq/YR)     -,s>   (Rg/YR)     it!   SUI??S«T ^IFE !C.~=a.223£
    se *INTEN»(C£. TflXES.  linSURflNCE =£3* SF CflPIT^. CCST

-------

-------
Attachment 1
           United States
           Environmental Protection
           Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-80-032b
June 198^
           Air
           Benzene Fugitive
           Emissions—

           Background
           Information for
           Promulgated
           Standards
              EIS

-------
Attachment 1
Table 2-5. ANNUALIZED MODEL UNIT CONTROL COSTS ANDwSAVINGSa
OF THE BENZENE FUGITIVE EMISSIONS STANDARD5
(Thousand May 1979 Dollars)
I tan
installed Capital Cost
Total Annual 1 zed Cost
Recovery Credit
Net Annual ized Cost or Savings4
VOC/Yr Emission Reduction
Senzene/Yr Emission Reduction
Cost (Savings) per Mg
Total Emissions Reduced
Cost (Savings) per Mg Benzene Reduced

New
16
10
S
3
19
12

.1
.9
.2
*9
Mg

.17
0.27

A
Existing
17
10.
6.
3.
19
12

2
9
3
Mg
"9

17
0.28
Model
Unite

3
New Existing New
31
20.1
20.5
(0.40)d
56 fig
31 Mg

(0.007)d
(0.013)*
32
20.2
20.5
(0.30)d '
56 fig
31 Mg

(O.OOS)d
(0.010)d
48
30.
33.
(3.
93
71

(0.
(0.

c
i Existing

1
3
7)d
"9
"9

040)d
052)d
49
30.
33.
(3.
93
71

(0.
(0.

4
3

"9
Mg

036)
048)

d
d
Costs »re for new and existing units and include monitoring instruments but do not include
cast for coBpressors because ceMpresson in benzene service are not Known w exist.
Recovery credits are based on total emission ^reductions (benzene and atfter YOC) and S370/Hg.
4The standara requires wxitnly leak detection and reoalr proqrats for valves and puns and
eoulpBMtt soec1f1cat1on« for pressure relief devices, bpen-«nded lines, sailing connections,
and product accuotilator vessels.

Soael units nave tne folloving marten of cceoonents:
A
5
34-
37
3
35
9
1
Node! Unit
3
15
100
264
9
105
25
I
c
25
167
439
16
175
44
2
Puaps
VaTves
Sas
lignt Liquid
Pressure Relief Devices (gas)
Ooeit-«nded Lines
Saoellng Connections
Accumulator Vessels

Several assumtlons are mde to coraute model unit costs. ?or aressure relief devices 75
percent are assuoed already controlled in the aosenca of tne standard. For tne 25 percent
of pressure relief devices tnat are uncontrolled, it is assumed tnat 75 oercant will ge
controlled with a closed vent svstae so flare and 25 percent -ill be controlled witft a
ruptur* disk systaw. For relief valves usinq raoture d1s«, one-«alf will be controlled
»itn block valve* and ane-fl*lf will be controlled witft 3-«ay valves. For accunilator
vessels. 95 percent are issuMd already controlled 1n tne aosence of tne'stanoart.
'witters in parenthesis denote savings.
*Total ensslons include- benzene and otner VOC.
2-94

-------
Attachment 2
&EPA
           United States
           Environmental Protection
           Agency
          Office of Air Quality
          Planning and Standards
          Research Triangle Park NC 27711
EPA-450/3-80-033b
June 1982
           Air
VOC Fugitive
Emissions in
Synthetic
Organic Chemicals
Manufacturing
industry—

Background
Information for
Promulgated
Standards
EIS

-------
Attachment  2
               TABLE 3-2.  COMPARISON OF EMISSION FACTORS, kg/hr/source
          Source
                                        AID
                                BID
     Pumps  -  light  liquid
           -  heavy  liquid
     Valves -  gas
           -  light  liquid
           -  heavy  liquid
     Compressors
     Pressure  relief devices
     Fl anges
     Oper-ended lines
     Sampling connections.
- gas
 0.0494
 0.0214
 0.0056
 0.0071
 0.00023
 0.228
 0.104
 0.00083
0.0017
0.0150
0.114
0.021
0.0268
0.0109
0.00023
0.636
0.16
0.00025
0.0023
0.0150
                                        3-9

-------
Appendix A.  Summary of Details of Control Cost Estimates

-------
Z- • Pe-tAIUS  OF ertMSSiorxj
                                                           COST GSTlmf\T&S  FUR  TSDF D»ST»LuATi°»^
   I-tr«-rux>.'
                      li
-7,600
 1,100
                                                        7,600
                                           i^ooo
                                                                               2.^000
                                      3£>yooo
                                                        ^qoo
                                                                                 iyooo

                                                                                 I, ooo
                                                                    88,000
                                                                                                 AO^OOO
                                                                                                    ooo
                                                                                                    000
                                                                               30,000
                                                                                 , goo
                             2-%ooo

                             ^3,000
                                                                   — 8^00
                                                                                              ^ooo
                                                                                             Q.OOOO
                                                                   HfOOO

                                                                  140^000
                                                                   12.5,400
                                                                    3o, ooo

-------
"5  .  A NNJUAL.I
                              COST   &A.SG.S
                                                     .  OS"
                                                   ir
                                                      %
                                                      %
                                                      O-p
                                                       c+
                                                       op
it -A
       lfc>
                                              r-
                                              O-  7.^ 2.
                                              r-  is

-------
CGNDE.NSA ' ItjtM  SYSTEM DESIGN S

Proauction capacity,  bg/yr                                              3
•3oerating nours  oer year                                             4161?
j^nlet emission  factor,  *g VQC/Mg product                             1.63
triii35ion  reduction                                                   95. 37*
Cutlet emission  factor,  kg VOC/Mg product                         2. i28£5
Inlet temoerature.  aeo. F                                               73
in 1st pressure,  atrnosaheres                                             I
Inlet TOLUENE mass flow rats,  io/hr                                  7. tffl
Iniet gas stream volumetric flow rats, acfm                         14. 63
Gas outlet temperature required for redaction,  oeg.r             -11.37
Coolant temperature selected,  aeg. F                     .              -£0
Design neat  loac.  Btu/hr                                             £557
Coce for  coolant selected (.1 = Freon—50'£;  £  =  Freon—1£;
  3 = i/5 ethvlene glycol & 1/2 water; 4 = water;                       £
Required  conaenser area,  so.ft                                      15.31
Selectea  condenser area.  sa. ft                                      ££i. 93
Meat excnanger  actual inner snail aiarnetar,  in.                     *(•. 32S
i_enath of neat  excnancer,  ft
Numoer of tuoes  in heat exchanger    "
Tube ourer diameter,  in.                                              a. £5
Tube inside  cross-sectional area, sq. ft oer  tube               3. '2iiZiiZ!c:05
Coolant soecific gravity (relative to water  at  S£i  oeg.i-)            1. 4fi£
Coolant flow  in  heat  exchanger,  qpm                                 £3.79
Coolant temperature change,  deg. F                                   13. 539
Reauired  refrigeration caoacity,  tons of refrigeration           8.£131
Selected  refrigeration capacity,  tons of refrigeration                NA
Selected  refrigeration caoacity,  compressor  horseoower              i3.75
Horsepower per  ton of refrigeration for coolant  temperature        3.£15



       CfiPITflL  AND ANNUAL OPERATING COST ESTIMATION

Capital•Costs
Heat excnanaer
   Installed cost  oer Enviroscience, December  1979                 .   NA
   Instaliea cost  oer venaors,  July 1984  (est.)                     *S6£
   Installed cost,  June 19Si2                                        3750

Refrigeration
   Installed cost  oer Enviroscience, Decernoer  1979                    MA
   Installed cost  per vendors.  June 1980  (est.)                   $£, 585
   Installed cost,  June 1980                                      s£.585

Total Instaiiea  Caoitai Cost,  June  1980                           $3.33&

Annualizea Costs
   Ooerating  labor
   Maintenance materials & laoor                                    si6
   Utilities
     Electricity, ournoing                                           *131
     Electricity, refrigeration                                     S'4«.
     Coolant, make—uo                                            '    si£
   Caoitai recovery                                                  $543
   Taxes, administration.  & insurance                               $133
   Total annualisea  cost without recovery creqit                  s1.631
   TOLUENE recovery  credit                                        i'*4, £30)

Met Annualised Cost  (after recovery creait)                       (*£,599)

TOLUENE Emission  Reduction,  Mg/yr                                 l£.5407

Average Cost  Effectiveness,  */Mg                                   (S£07)

-------
 -•r-:-auct ion caaaeitv.. ua/'vr                                              ^
 Coerating  Tours oer year"                                            ^ia5
 Jin let  sail S3 1 on factor. x.n VQC/Mg  procuct                            -."So
 Emission reduction       "         '                                   95. tf/
 Outlet  emission factor.  KD  v'GC/mg oroouct                         2>. tf6£5
 Inlet  temoeraturs.  cea. F ~                                             75
 Inlet  oressure.  atrnosoheres                                             1
 Inlet  HEXANt. mass flow rate,  io/hr                                  7,00
 ^nlet  gas  stream voiumetric  flow  rate,  acfm                         £.86
 Gas  outlet temoerature reauired  for reduction, aea. F              -IS. 25
 Coolant  temoerature selected,  aea.F              ~                   -3(3
 Design  heat load.  5tu/hr         "                                   l^^.
-------
       :tion capacity,  us/yr                                              r
 -i-serat me nours aer year                                              -ritiZ1
 In 1st  emission factor.  K.n  v'QC/'Mg arc-cuet                             ^.65
 ilrnission rsauction       "       "                                     §5.'3%
 Outlet emission factor.  k= VQC/rog proauct                          3. >2>5£5
 Inlet  temperature. aeg.F  "                                         "   ~7=
 Inlet  oressurs, atmosonerss                              •               7
 Inlet  TRICHLORO mass  flow  >-ats.  ia/hr                                7. #0
 Inlet  gas stream volumetric flow rate,  acf'-n                          £.£5
 Gas  outlet temperature  recuired  for reauction. aec. F               -17.51
 Coolant temoerature seiectea.  sen. F               ~                    -30
 Design neat ioaa.  Btu/hr         "    _   .                             367
 Code for coolant seiectea  ki  = Freon—D                      *£C6
   Installed cost,  June 1380       "            ,                      '6£58

 Refrigeration
   Installed cost  oer Envirosciencs,  Decemper 1373                     MP
   Instaliea cost  oer vendors. June I98i2 (est.)                    $£ i3££
   Instaliea cost,  June 1980                                       3£^ i3££

 Total  Installed Caoitai  Cost.  June  138i3                           *£. £3ei

 Annualirec Costs

   Ooerating iaaor                                                   3A37
   Maintenance materials &  iacor                 •                    *-*i.
   Uti1ities -                                                         *4
     Electricity,  purnoing                                             *63
     Electricity,  refriaeration                                       573
     Coolant,  make—UD   ~                                               50
   Capital  recovery                                                . 5T7^"
   Taxes,  administration,   & insurance                                 53i
   Total  annuaiiaed cost without  recoverv credit                  «i  -1-5
   TRICHLORO recovery  credit             '                           (S3£l)

Net Annual i zed  Cost  (after  recovery  credit)                          rs£96

TRICHLORO  Emission  Reauction,  Mg/yr'                              1£. 54(37

Average  Cost Effectiveness, S/Mg
-------
ATTACHMENT 2
-------
                                                               u u I  'L o
SUBJECT:   Revisions to Draft Model  Facility  Parameters  and  Draft
           Condenser Cost Estimates

TO:        Fred Dimmick, SDB

FROM:      Jan Meyer, PES
     Attached are revised Tables 1 and 4 presenting model  facility
parameters and control condenser cost estimates.
-------
                                TABLE 1.  MODEL FACILITY:  PROCESS EMISSIONS
   Item
                    Recommendation
                               Basis
                                                                                    Comments
GENERAL PLANT
  OPERATION:

Waste Solvent
  Reclamation
  Rate
8000 Metric Tons per
  year
Operating Hours
Condenser Stream
  Cases
CONDENSER VENT  •
STREAM EMISSION
CHARACTERISTICS:

Temperature
FT owrate
4160 per year
(1)  Hexane
(2)  Toluene
(3)  1,1,1
     tricnloroetnane
75"F
                  26 scfm
VOC Emission Rate
(1) 12 Ib/hr toluene
(2) 7-59 Ib/hr nexane
(3) 7-75 Ib/hr tnch-
      loroethane
Subjective judgement after
reviewing 1978 EPA Source
Assessment,^
1/30/81 Engineering Science
Memorandum, 2
SOCMI Distillation NSPS BID,
and RTI/Radian site visit
reports.
Intermittent operation:
2 shifts/day x 5 day/wk x
52 wk/yr.

Subjective judgment after
review of references 1-5.
 Most  solvent  reclamation plants
 appear to  be  in  the range of 2-3000
 metric tons/yr.   A size at the
 large end  of  this range was chosen
 because some  model  plant parame-
 ters  (e.g.,  airflow)  are being
 based on SOCMI Distillation, and a
 large solvent reclamation facility
 is  closer  to  a small  SOCMI Distil-
 lation facility.
RTI/Engineering Science site
visit reports.

SOCMI Distillation NSPS BID,
"Case- 5" (page 8-15).
lower limit based on avg.
AP-42 emission factor (1.7g
VOCAg reclaimed solvent)
applied to 8000 metric tons/yr
plant.  Upper limit is
emission rate associated with
gas stream at the dew point
of the compound.
Range was  about  50-80°F.   Highest
used  was  90°F In ICF report.*

{Range of  flowrates  reported for all
SOCMI Distillation  facilities was
0.005-637  scfm.   No correlation of
plant size and  flowrate possible.
No  information  found on flowrates
at  waste  solvent recovery
facilities.

AP-42 factor used in GCA Tecn-
note.^  (Range  of AP-42 factor is
0.26-4.17  g/kg  reclaimed  solvent).
Range of  SOCMI  Distillation
emission  rates  reported was 0-3663
Ib/hr, witn 78  Ib/hr the  average.
|Example material  balance  in EPA
Source Assessment, (page 22) indi-
cate  mucn  lower  emission  factor.
lMSource Assessment:  Reclaiming of Waste Solvents, State of the Art,"  EPA-600/2-78-004f, April 1978.

Memorandum, "Development of a Control Technology Guideline (CTG) Document for the Waste Solvent Recovery
 Industry," from.L.L. Lloyd of Engineering Science to F.L. Porter of EPA/ESED.

3"Preliminary Assessment of Hazardous Waste Pretreatment as an A1r Pollution Control Techn-ique," prepared
 by RTI for EPA/IERU, October 15, 1984.

*"The RCRA Risk-Cost Analysis Model  - Phase III Report," prepared by ICF, Inc. for EPA/OSW, March 1, 1984.

50raft Tecnnical Note, "Emission Algorithm Development for Pretreatment Operations," prepared by GCA Corp.
 for EPA/ESED/CPB, July 1985.
-------
                                   TABLE  4.   SUMMARY OF  CONTROL COST  ESTIMATES  FOR WSTF
                                         DISTILLATION VENTS  -  CONDENSER  CONTROL
Stream
Item
Control System0 »e
Control costs:
Capital, $
Total annual i zed, $
Recovery Credit, $
Net Annual i zed, $
Annual Emission Reduction,
ton/yr
Cost Effectiveness, $/ton
Case la
VOC = 7 Ib/h
Toluene
Condenser

3,336
1,631
(4,230)
(2,599)
13.83
(187.92)
Case 2b
VOC = 12 Ib./h
Toluene
Condenser

21,000
4,700
(8,126)
(3,426)
23.9
(143.35)
Case 3d
VOC = 7 Ib/h
Hexane
Condenser

2,843
1,398
(4,479)
(3,081)
13.83
(222.78)
Case 4b
VOC = 58.9
Hexane
Condenser

38,000
8,100
(41,900)
(33,800)
116.39
'290.40
Case 5a
Ib/h VOC = 7 Ib/h
Trichloroethane
Condenser

2,280
1,219
(921)
298
13.83
21.55
Case 6b
VOC = 75 Ib/L
Trichloroethane
Condenser

29,000
5,500
(11,025)
(5,525)
148.99
(37.08)
 (  )  indicates  a credit.
a
 Cost estimates were developed using RES'  condenser cost  algorithm  in  "Polymers Manufacturing  NSPS";  all costs  are  in
 June 1980 dollars.
3
 Cost estimates developed using standard  cost  estimation  procedures  and  vendor data  for  condenser  costs; all costs  are
 in 1985 dollars.
-------
ATTACHMENT 3
-------
                          MEMORANDUM

                                                     October  30,  1985

TO:       Fred Dimmick, SDB

FROM:     Graham Fitzsimons, PES

SUBJECT:  Revised HEM Modeling Inputs for WSTF Model Plants
     Attached for your review are revised HEM modeling inputs for each of
the uncontrolled and controlled model cases that PES has developed for the
WSTF project.  Attachment 1 presents a key to the various model case  inputs
prepared.  The inputs for each case are presented in Attachment 2.

     The revised inputs were prepared based on our discussions with you
and K.C. Hustvedt concerning the model  inputs PES submitted on October
23.  The specific changes from the October 23 inputs are:  1) the
controlled and uncontrolled cases for toluene at an uncontrolled emission
rate of 7 Ib/h from the condenser vent have been dropped, and 2) methyl
ethyl ketone (at uncontrolled emission rates of 7 and 32 Ib/h) has been
substituted for hexane.

     Our recommendations for candidate rural and urban locations for
modeling-remain the same.  These locations correspond to existing
solvent reclamation facility sites.  The recommended candidate locations
and the EPA ID numbers of the facilities at those locations are shown
below.
               Plant Location
Latitude
Longitude    Rural/Urban
EPA ID »

CAT000646117
OKD065438376

OHD052324548
NJD002182897
NCDU71572036
ORD009020231

     Please call  me if you have any questions on the modeling inputs or
recommended candidate modeling locations.
Kettleman City, CA
Waynoka, OK
Twinsburg,
Linden, NJ
Greensboro
Beaverton,
»
OH
NC
OR
36
36
41
40
36
45
o
o
o
o
o
o
06'
32'
27'
44'
07'
30'
20"
30"
30"
30"
50"
00"
120°
98°
81°
74°
79°
122°
05'
48'
29'
16'
56'
49-
20"
00"
40"
10"
10"
30"
R
R
U
U
U
U
-------
                           Attachment  1.   KEY  TO MODEL CASES
Pollutant
Emission Rate^
Ib/h •
Uncontrolled
Case Nos.
Control
Condenser
L
MEK 712
32 5 6
led Case Nos.
Incinerator
NA
NA

Flare
3
10
Toluene

1,1,1-Trichloroethane
 7
75
2
8
NA

 4
 9
                                                                                 NA
                                                                                 NA
Uncontrolled emission  rate  from  the condenser vent.  In  addition,  fugitive  emissions
  of  3.44  Ib/h  and  0.88  Ib/h were included  in  the  uncontrolled  and  controlled  cases,
 'respectively.   Condenser vent emissions were assumed to  occur 4160  hrs/yr and
  fugitive emissions, were assumed to occur  8760  hrs/yr.
-------
       ATTACHMENT 2



HEM INPUTS FOR MODEL CASES
-------
                                        HEM INPUTS  FOR MODEL CASE NO.  1
Model  Case No. 1
Condenser Vent Controls:  None
Fugitive Emission Controls:  None
Pollutant:  MEK. Toluene, or 1,1,1-Trichloroethane
Uncontrolled Condenser  Vent Emission Rate:  7 Ib/h
Condenser Vent Flowrate:  26 scfm


Emission Point

Emission
Rate
kg/yr
(tons/yr)

Condenser Vent 13,209
(14.6)
Fugitive Emissions 13.666
from Pumps, (15.1)

Operating
Hours
Per Year

4,160

8,760


Emission
> Point
Elevation
m
(ft)
6.5
(21.3)
0


Emission
Point
Diameter
• m
(in)
0.0381
(1.5)
_ —

Emission
Point
Cross Sectional
Area
«?•
(In2)
0.00114
(1.77)
__

Emission
Point Gas
Exit
Velocity
m/s
(ft/s)
10.8
(35.4)



Emission
Point Gas
Temperature
°K
(°F)
297
(75)
293
(68)
  Assumed  value  to  result  in an exit velocity  of approximately 10
  meters per  second.
-------
                                           HEM INPUTS FOK MODEL CASE NO. 2
Model Case No. 2
Condenser Vent Controls:  Secondary Condenser (95% eff.)
Fuyitive Emission Controls:  Leak Detection and Repair
Pollutant:  MEK, Toluene, or 1,1,1 - Trichlor'oethane
Uncontrolled Condenser Vent Emission Rate:  7 Ib/h
Condenser Vent Flowrate:  26 scfm



Emission Point


Secondary Condenser
Vent
Fugitive Emissions
from Pumps,

Emission
Rate
kg/yr
(tons/yr)

660
(0.7)
3,513
(3.9)

Operating
Hours
Per Year


4,160

8,760


Emission
Point
Elevation
m
(ft)
6.5
(21:3)
0


Emission
Point
Di ameter
m
(in)
0.0381
(1.5)


Emission
Point
Cross Sectional
Area
m^
(in?)
0.00114
(1.77)


Emission
Point Gas
Exit
Velocity
m/s
(ft/s)
10.8
(35.4)



Emission
Point Gas
Temperature
°K
(°F)
293
(68)
293
(68)
-------
                                       HEM INPUTS FOR MODEL CASE NO. 3
Model  Case No.  3
Condenser Vent Controls:  Flare (98%  eff.)
Fugitive Emission Controls:  Leak Detection and  Repair
Pollutant:  Toluene or MEK
Uncontrolled Condenser Vent Emission  Rate:  7 Ib/h
Condenser Vent Flowrate:  26 scfm


Emission Point


Emission
Rate
kg/yr
(tons/yr)

Flare 264
(0.3)
Fugitive Emissions 3,513
from Pumps, (3.9)
Valves, etc.

Operating
Hours
Per Year

4,160

8.760



Emission

Emission
Point Point
Elevation^ Diameter2
m m
(ft)
10
(33)
0


(In)
0.0508
(2)



Emission
Point
Cross Sectional
Area
m2
(1n2)
0.002
(3.14)



Emission
Point Gas
Exit
Velocity'
m/s
(ft/s)
18
(60)



'• 	 • 	
Emission
Point Gas „
Temperature
°K
(°F)
811
(1,000)
291
(68)

   Computed  based on  requirements  for maximum flare  exit velocity
   contained  In 50 FR  14941, April  16, 1985,  and assuming a
   heat content of 300  Btu/scf.
gas
  Assumed value based  on engineering judgement
-------
                                          HEM  INPUTS FOR MODEL CASE NO.  4
Model Case No.  4
Condenser Vent Controls:   Incinerator (98% eff.)
Fugitive Emission Controls:  Leak Detection and Repair
Pollutant:  1,1,1-Trlchloroethane
Uncontrolled Condenser Vent Emission Rate:  7  Ib/h
Condenser Vent Flowrate:   26 scfm



Emission Point


Emission
Rate
kg/yr
( tons/yr )

Incinerator 264
(0.3)

Operating
Hours
Per Year

4.160


Emission
Point
Elevation'
m
(ft)
7
(23)

Emission
Point
Diameter'
m
(In)
0.3048
(12)
Emission
Point
Cross Sectional
Area
in*
(In*)
0.073
(113)
Emission
Point Gas
Exit
Velocity
m/s
(ft/s)
7.6
(25)

Emission
Point Gas
Temperature'
°K
(°F)
811
(1,000)
Fugitive Emissions     3,513
  from Pumps,             (3.9)
  Valves,  etc.
8,760
0
                                                       293
                                                       (68)
   Assumed value based on  engineering  Judgement.
-------
                                           HEM INPUTS  FOR MODEL  CASE  NO.  5
Model Case No. 5
Condenser Vent Controls:  None
Fugitive Emission Controls:   None
Pollutant:  MEK
Uncontrolled Condenser Vent Emission  Rate:  32  Ib/h
Condenser Vent Flowrate:  26 scfm



Emission Point


Emission
Rate
kg/yr
(tons/yr)

Condenser Vent 60,383
(66.6)
/

Operating
Hours
Per Year


4.160


Emission
Point
Elevation
m
(ft) .
6.5
(21.3)

Emission
Point
Diameter
m
(In)
0.0381
(1.5)
Emission
Point
Cross Sectional
Area
m2
(In2)
0.00114
(1.77)
Emission
Point Gas
Exit
Velocity
m/s
(ft/s)
10.8
(35.4)

Emission
Point Gas
Temperature
°K
(°F)
297
(75)
Fugitive Emissions    13,666       8,760
  from Pumps,            (15.1)
  Valves, etc.
293
(68)
-------
                                           HEM INPUTS  FOR  MODEL  CASE  NO.  6
Mode] Case No. 6
Condenser Vent Controls:  Secondary Condenser (95$ eff.)
Fugitive Emission Controls:  Leak Detection  arid  Repair
Pollutant:  MEK
Uncontrolled Condenser Vent Emission Rate: 32 Ib/h
Condenser Vent Flowrate:  26 scfm



Emission Point

Emission
Rate
kg/yr
(tons/yr)

Secondary Condenser 3,019
Vent (3.3)
Fugitive Emissions 3,513
from Pumps, (3.9)

Operating
Hours
Per Year

4,160

8.760


Emission
Point
Elevation
m
(ft)
6.5
(21.3)
0


Emission
Point
Diameter
m
(In)
0.0381
(1.5)
..

Emission
Point
Cross Sectional
Area
•2
(1n2)
0.00114
(1.77)


Emission
Point Gas
Exit
Velocity
m/s
(ft/s)
10.8
(35.4)



Emission
Point Gas
Temperature
°K
(°F)
293
(68)
293 '
(68)
  Valyes,  etc.
-------
                                           HEM  INPUTS  FOR MODEL  CASE  NO.  7
Model Case No. 7
Condenser Vent Controls:   None
Fugitive Emission Controls:   None
Pollutant:  1.1,1-Trlchloroethane
Uncontrolled Condenser Vent Emission  Rate:  75  Ib/h
Condenser Vent Flowrate:   26 scfm

1
Emission Point

Condenser Vent

Fugitive Emissions
from Pumps,
Valves, etc.

Emission
Rate
kg/yr
(tons/yr)

141.521
(156)
13,666
(15.1)


Operating
Hours
Per Year

4,160

8,760



Emission
Point
Elevation
m
(ft)
6.5
(21.3)
0

•

Emission
Point
Diameter
m
(In)
0.0381
(1.5)



Emission
Point
Cross. Sectional
Area
•*
Hn2)
0.00114
(1.77)



Emission
Point Gas
Exit
Velocity
m/s
(ft/s)
10.8
(35.4)




Emission
Point Gas
Temperature
°K
(°F)
297
(75)
?Q1
(68)

-------
                                           HEM  INPUTS  FOR MODEL  CASE  NO.  8
Model Case No. 8
Condenser Vent Controls:   Secondary Condenser  (95$ eff.)
Fugitive Emission Controls:   Leak Detection and Repair
Pollutant:  1.1,1-Trlchloroethane
Uncontrolled Condenser Vent Emission Rate:  75  Ib/h
Condenser Vent Flowrate:   26 scfm



Emission Point


Secondary Condenser
Vent
Fugitive Emissions
from Pumps,
Valves, etc.

Emission
Rate
•kg/yr
(tons/yr)

7,076
(7.8)
3,513
(3.9)


Operating
Hours
Per Year


4,160

8.760



Emission
Point
Elevation
in
(ft)
6.5
(21.3) •
0
•


Emission
Point
Diameter
m
(In)
0.0381
(1.5)
__


Emission
Point
Cross Sectional
Area
m2
(In?)
0.00114
(1.77)
_.


Emission
Point Gas
Exit
Velocity
m/s
(ft/s)
10.8
(35.4)




Emission
Point Gas
Temperature
°K
(°F)
293
(68)
293
(68)

-------
                                           HEM  INPUTS  FOR MODEL  CASE  NO. 9
Model Case No. 9
Condenser Vent Controls:   Incinerator  (9B%  eff.)
Fugitive Emission Controls:   Leak  Detection and Repair
Pollutant:  1,1,1-Trlchloroethane
Uncontrolled Condenser Vent Emission Rate:  75  Ib/h
Condenser Vent Flowrate:   26 scfm


Emission Point

Incinerator

Fugitive Emissions
from Pumps,
Valves, etc.

Emission
Rate
kg/yr
( tons/yr)

2,830
(3.1)
3,513
(3.9)


Operating
Hours
Per Year

4.160

8,760



Emission
Point
Elevation
m
(ft)
7
(23)
0



Emission
Point
Diameter
m
(in)
0.3048
(12)



Emission
Point
Cross Sectional
Area
m2
(In*)
0.073
(113)



Emission
Point Gas
Exit
Velocity
m/s
(ft/s)
7.6
(25)




Emission
Point Gas
Temperature
°K
(°F)
811
(1,000)
293
(68)

-------
                                          HEM  INPUTS FOR MODEL CASE NO.  10
Model Case No. 10
Condenser Vent Controls:   Flare (98% eff.)
Fugitive Emission Controls:   Leak Detection and Repair
Pollutant:  MEK
Uncontrolled Condenser Vent Emission Rate: 32  Ib/h
Condenser Vent Flowrate:   26 scfm



Emission Point

Flare

Fugitive Emissions
from Pumps,
Valves, etc.

Emission
Rate
kg/yr
( tons/yr )

1.208
(1.33)
3,513
(3.9)


Operating
Hours
Per Year

4,160

8,760



Emission
Point
Elevation
in
(ft)
10
(33)
0



Emission
Point
Diameter
in
(In)
0.0508
(2)
__


Emission
Point
Cross Sectional
Area
m2
(in*)
0.002
(3.14)
_.

.
Emission
Point Gas
Exit
Velocity
m/s
(ft/s)
59
(195)



'
Emission
Point Gas
Temperature
°K
(°F)
811
(1,000)
293
(68)

-------
ATTACHMENT 4
-------
-------
                          MEMORANDUM



TO:        Fred Dimmick, SDB

FROM:      Jan Meyer, PES

SUBJECT:   Chemicals Covered in Land Banning Action
October 31, 1985
     The list of. chemicals effected by OSW's land-banning regulation
was inadvertently omitted from the HEM modeling input parameters-
submitted on October 30,  1985.  Attached is a list of chemicals likely
to be present in wastes effected by the land-banning/pretreatment
requirements.

cc:  Mike Dusetzina, PAB
-------
                CHEMICALS LIKELY TO BE COVERED
                          BY ACTION
P022  -  carbon alsulfide
U002  -  acetone
U031  -  n butyl alcohol
U037  -  chlorobenzene
U052  -  cresols & cresylic acid
U057  -  cyclohexanone
U070  -  o-dichlorobenzene
U060  -  methylene chloride
U112  -  ethyl acetate
U117  -  ethyl ether
U140  -  isobutanol
U154  -  methanol
U159  -  methyl ethyl ketone
U161  -  methyl isobutyl ketone
U169  -  nitrobenzene
U196  -  pyridine
U210  -  tetrachloroethane
U211  -  carbon tetrachloride
U220  -  toluene
U226  -  1,1,1-trichloroethane
U228  -  trichloroethylene
U229  -  trichlorofluoromethane
U239  -  xylene
      -" ethyl benzene'
      -  tetrachloroethylene
      -  1,1,2-trichloro - 1,2,2-trifluoroethane
-------
ATTACHMENT 5
-------
                                        October  31,  1985

TO:        Fred Dimmick, SDB

FROM:      Jan Meyer, PES

SUBJECT:   Revised Incinerator Cost Estimates and Additional  Cost
           Estimates for Secondary Condenser Control
     As agreed in recent discussions, we have (1) developed revised
cost estimates for incinerator control of a halogenated compound and
(2) have substituted a methyl ethyl ketone (MEK) model case for the
hexane model case and -have developed condenser control cost estimates
for the new case.  Because of concerns regarding the  applicability of
the cost estimates developed using the incinerator cost program in the
SOCMIa distillation Background Document to small gas  streams, cost
estimates were developed using vendor cost information.  These revised
cost estimates are presented in Table 1 along with the initial cost
estimates.  Table 2 presents the secondary condenser  control cost
estimates for the MEK case, and presents corrected cost effectiveness
values for Cases 1 and 5.
     After you review these cost estimates, please let us know which
incinerator cost estimates should be used in -estimation of nationwide
control cost.
a
 SOCMI - Synthetic Organic Chemical  Manufacturing Industry
-------
                             TABLE  1.   SUMMARY OF  CONTROL  COST  ESTIMATES  FOR WSTF
                                   DISTILLATION VENTS  -  INCINERATOR  CONTROL

                                             (June  1985 dollars)
         Stream6
 Item
    October 21, 1985. Estimate*
     Case 5             Case 6
  VOC = 7 Ib/h      VOC = 82 Ib/h
Trichloroethane    Trichloroethane
     Revised Cost Estimateb
    Case 5             Case 6
 VOC = 7 Ib/h      VOC = 75 Ib/h
Trichloroethane    Trichloroethane
Control System0. e
Control costs:
Capital, $
Operatingf,$
Total annual i zed, d$
Emission Reduction, t/yr
Incinerator

758,000
159,000
312,000
13.8
Incinerator

758,000
140,000
293,000f
148.2
Incinerator

209,000
121,700
164,100
13.8
Incinerator

209,000
108,500
150,900
148.2
aCost estimates are developed using Radian's "Documentation for the Synthetic Organic Chemicals
 Manufacturing Industry (SOCMI) Incinerator/Flare Costing Algorithm."

bCapital cost estimates were developed using "Report of Fuel Requirements, Capital Cost and Operating
 Expense for Catalytic Afterburners," EPA-450/3-76-031 (1976) and CE Price Indexes.  Natural gas
 and electricity costs are estimated using standard procedures and gas cost of $5.08/106 Btu and
 electricity cost of $0.0512/kWh.

clncinerator system costs include  combustion chamber, 150 ft duct work, fan, stack, and quench/scrub
 system.  It is unknown if the system includes  a heat exchanger.

dBased on 4,160 annual operating hours, 15 years life for flares, 10 years of life for incinerators
 and 10 percent interest rates.                                                                    '

eFor Cases 5 and 6, lowest size incinerators (i.e., 1 m3 combustion chamber) are required.

fCalculations for case 5 resulted  in negative fuel  costs.
-------
                                    I ABU  2.   SUMMARY Of CONTROL COST ESTIMATES FOR WSIF
                                          DISIIILATION VENTS - CONDENSER CONTROL
Stream
Item
Control System
Control costs;
Capital. $
Total annual Ized, f
Recovery Credit, )
Net Annual Ized. $
Annual Emission Reduction.
ton/yr
Cost Effectiveness. $/ton
( I Inrfiratac a rrotllt
Case la
VOC = / Ib/h
Toluene
Condenser

3.336
1.631
(4.230)
(2.599)
13.83
(187.92)
Case 2b
VOC * 12 Ib/h
Toluene
Condenser

21,000
4.700
(8.126)
(3.426)
23.9
(I43.3S)
Case 3*
VOC - 7 Ib/h
Methyl Ethyl
Ketone
Condenser

2.891
1.445
(8.95.7)
(7.613)
13.83
(543.24)
Case 4b
VOC - 32 Ib/h
Methyl Ethyl
Ketone
Condenser

28.500
6,400
(45.525)
(39.125)
63.23
(618.77)
Case 5*
VOC - 7 Ib/h
Trlchloroethane
Condenser

2.280
1.219
(921)
298
13.83
21.54
Case 6b
VOC - 75 Ib/h
Trlchloroethane
Condenser

29.000
5.500
(11,025)
(5.525)
148.99
(37.08)
Case 7d>*
VOC =0.7 Ib/h
Methyl Ethyl
Ketone
Condenser

1.520
924
(518)
407
0.8
509
 Cost estimates were developed using PES' condenser cost  algorithm In "Polymers Manufacturing NSPS"; all costs are In
 June 1980 dollars.
b
 Cost estimates developed using standard cost estimation  procedures  and  vendor data for condenser costs: all  costs are
 In 1985 dollars.

 To be provided later
d
 Supplemental  case to evaluate Impact of approximately  one  order-of-maynltude  change  In the primary condenser
 flow rate.
-------
ATTACHMENT   6
-------
             PRELIMINARY ESTIMATE USING MODEL PLANT APPROACH
          OF NATIONWIDE MAXIMUM RISK AND  INCIDENCE ASSOCIATED
                     WITH AIR EMISSIONS FROM WSTFs
GIVEN:   o  WSTF Model Plant Size = 8 Gg per year of Reclaimed Solvent
            Produced.

         o  Amount of  spent solvent waste to be handled =
            436.3 million gallons/yr (428 + 8.3 million gallons).

         o  Uncontrolled model plant emissions range from 7 Ib/h to
            75 Ib/h from the condenser vent plus uncontrolled
            fugitive emissions (one rate).

         o  Proposed action would require 95% control of condenser
            vent emissions plus fugitive controls.

         o  Six candidate facility locations (4 urban and 2 rural).

         o  Range for Unit Risk Factor in earlier preliminary risk
            assessment for TSDFs was 2 x 10~7 to 2 x 10~5.

SUMMARY OF APPROACH:   HEM was used to calculate max. risk and incidence
         for a plant with 7 Ib/h condenser vent emissions and 75 Ib/h
         condenser vent emissions at each of the six candidate loca-
         tions (fugitive emissions were also included).  Max.  nation-
         wide uncontrolled risk was assumed to be the highest risk In
         any of these model cases.  To determine nationwide uncontrolled
         incidence, the total  number of 8 Gg/yr production plants
         required to handle 436.3 million gallons of waste solvent was
         estimated.  These plants were then assumed to be distributed
         as follows:   1/2 were assumed to have condenser vent emissions
         of 7 Ib/h and be equally spread among the six locations, and
         1/2 were assumed to have condenser vent emissions of 75 Ib/h
         and also spread equally among the six locations.   Nationwide
         .incidence for controlled emissions was similarly calculated
         assuming 95% control  of condenser vent emissions plus fugitive
         controls (see next page for details).

SUMMARY OF RESULTS USING THIS  APPROACH:

Max. Individual Risk
Nationwide Incidences
Per Year
Uncontrolled*
3.7 x 10-5 to
3.7 x 10-3
.034 - 3.4
Controlled*
2.6 x 10-6 to
2.6 x 10-4
.0028 - .28
*Range based on range of unit risk  factor.
-------
DETAILS ON APPROACH USED FOR ESTIMATING INCIDENCE AND MAX RISK:
    Incidence

    A.  Uncontrolled Emissions

       1)  HEM was run for uncontrolled condenser vent emissions of
          7 Ib/h and 75  Ib/h at the six candidate locations (plus
          uncontrolled fugitives in each case).  Twelve dispersion
          modeling runs  were required for this.  The HEM inputs
          for these cases were  Model  Case l  and  Model Case 7 in the
          Oct.  31. 1985  memo from G.  Fitzsimons  to F. Dimmick.
          The six candidate  locations (where WSTFs are actually
          located) are:
               Rural
            Kettleman  City,  CA
            Waynoka. OK
      Urban
  Twinsburg, OH
  Linden. MJ
  Greensboro, NC
  Beaverton. OR
       2)  In  calculating  risk  and  incidence  for  the  cases  in Al
          above,  a  range  of  unit  risk  factors  from  2.0E-07 to
          2.0E-05 was  used.  This  is the  same  as  used  by  GCA in
          previous  risk assessments  of  TSDFs.

       3)  Using  an  assumed average  solvent recovery  rate  of  55  'i.
          it  was  estimated that 95-8  G'g/yr model  plants  would be
          necessary  to handle  436.3  million  gallons  of  solvent  waste
          (see Attachment  1).

       4)  The result of Al and A2  above was  that  a  range  of
          incidences/yr was  calculated  for each  of  12  model  cases
          (2  condenser vent  emission rates X six  locations).
          To  estimate  nationwide  incidence,  it was assumed that 1/12
          of  the  number of plants  calculated in A3 correspond to
          each case, and  then  the  number  of  plants of  each case type
          multiplied by tae  incidence associated  with  each case type
          was summed as follows:
         Nationwide

          •Incidence
12
                                                      12
    95
   Total
Plants Reqd
/incidence  \
f  for each  1
\model case/
-------
    B.  Controlled Emissions

       1) HEM was run at the 6 candidate locations for the control cases
          where uncontrolled condenser vent emissions of 7 ib/h and
          75 ib/h are controlled with a 95% efficient seco.ndary
          condenser,  and fugitive controls are applied.  The model
          plant HEM inputs for these cases were Model Case 2 and Model
          Case 8 in the Oct. 31 memo.

       2) To estimate nationwide incidence, the same procedure as
          in A2 - A4  above was used.

11.   Maximum Risk

     The  maximum individual risks calculated for any single plant
     in IA and IB above were assumed to be the nationwide maximums.
Note:  The approach described above to estimate the range in
       nationwide risks differs from that used to estimate
       nationwide emissions and costs.  The range in health
       risk estimates calculated using the above approach
       represents the range of risks at the midpoint nationwide
       emission estimate and not the range of risks at the upoer
       or lower bound nationwide emission estimate.  This
       approach was used to minimize the number of estimates
       nresented.
-------
ATTACHMENT 1 - DETERMINATION OF NUMBER OF MODEL PLANTS REQUIRED
    TO HANDLE 436.3 MILLION GALLONS OF SOLVENT WASTE PER YEAR
Assumptions:

     Model Plant Size - 8 Gg Solvent Produced/yr
                      » 8E+O6 kg/yr

     Denaity of Reclaimed Solvent = 7 Ib/gal - 3.175 kg/gal


Estimate of Number of Model Plants Required:

       Maaa of      Vol. of Waste     Recovery    Denaity of
 1)   Recovered *     Treated      X    Rate   X  Recovered
       Solvent         

                »   436,3OO,OOO gal X Recovery Rate X 3.175 kg/gal

                »    1.3853E+09 kg/yr X Recovery Rate


                               Vol. Solvent Recovered
       where:  Recovery Rate -	.	________
                                 Vol. Waste Treated
     Number of       Mass of Recovered Solvent
 2)    8 Gg/yr   »    	
    Plants Reqd.       SE+O6 kg/yr/model plant

                     1.3853E+O9 kg/yr X Recovery Rate
                3    ———___———____——___——____________
                      8E*O6 kg/yr/model plant

                *    173.17 X Recovery Rate


 3>  Recovery Rate vs.  Number of Plants is shown in Figure 1.
    Baaed on a review  of the literature, an overall average
    recovery rate of .55 <55*>  appears reasonable.  Using this
    recovery rate,  the total number of plants required to treat
    436.3 million gallons of solvent waste is 95.
-------
1*0
                   Figure 1.

   Number of 8 Gg/Yr  Plants  Required
             tn Treat 426.3 Million Gallons af Waste
130 -
120 -
1 1O -
100 -
 SO
-------
ATTACHMENT 7
-------
                          MEMORANDUM


DATE:     January 24, 1986

SUBJECT:  Revised Costs for Fugitive Emission Control at a Model WSTF

FROM:     Graham Fitzsimons, PES

TO:       Fred Dimmick, EPA/SDB
     PES' draft estimates of the costs associated with controlling
fugitive emissions from a WSTF model facility were presented in Table 5
of the memorandum to you, "Model Facility Parameters and Draft Control
Cost Estimates," dated October 21, 1985.  The draft estimates were
prepared using EPA/CPB's LOTUS 1-2-3 costing program for a leak detection
and repair program (LDRP) for pumps, valves, and other potentially
leaking sources.

     PES' review of the LOTUS program since those draft estimates were
prepared revealed that the program assumed 10 minutes would be required
for each valve check.  Following discussions with you, PES reran the
LOTUS program assuming 2 minutes per valve check, which is consistent
with EPA's approach to costing LDRP's for other standards.

     The results of the program assuming 2 minutes per valve are shown
in Table 1.  The only difference from the results presented in the
October 21, 1985, memo is that the annual cost to implement the LDRP
for valves is decreased to $2,378/yr (from $8,413/yr).  This decreased
the total annualized cost of control for all fugitive sources evaluated
at the model  plant to $11,901 (from $17,936).
-------
  Table  1.   Cost,  Emission Reduction,  and  Cost Effectiveness  of
                 Model  Plant  Fugitive Emission Controls
EMISSION SOURCE
NUMBER   ANNUAL  CONTROL  EMISSION CAPITffi. ANNJALIZ. RECOVERY   COST
OF      EMISS.   EFFIC.   REDUCTION COST    COST    CREDI^ EFFECT.
SOURCES  (Mg/YR)     (*)   (l«g/YR)     ($)  ($/YR)   (S/Y3) (a (S
PUP SEALS
LIGHT LIQUID
HEAVY LIQUID
COMPRESSORS
FJW6ES -
VALVES GAS
LIQUID
SAFETY/RELIEF GAS
VALVES LIQUID
SAMPLING CONNECTIONS
OPEN-ENDED LINES
MONITOR. INSTRUMENT 
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ATTACHMENT 8
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                          MEMORANDUM


 DATE:       January  24,  1986

 SUBJECT:    Estimates of  Nationwide-Emissions and Cost of Control for
            Waste  Solvent Treatment Facilities  (WSTFs)

 FROM:       Graham Fitzsimons, PES

 TO:         Fred Dimmick, EPA/SDB
     The purpose of this memorandum is to present PES' estimates of the
 following nationwide impacts for WSTFs:  (1) nationwide uncontrolled
 VOC process and fugitive emissions; (2) nationwide VOC emissions with
 95 percent process emission control and a leak detection and repair
 program for fugitive emission control; and (3) nationwide capital and
 annual costs to apply these controls.  PES prepared the nationwide
 estimates by extrapolating from the most recent emission and cost data
 developed for a variety of "model cases."  These model cases correspond
 to a plant of 8 Gg per year solvent production capacity with a range of
 uncontrolled process emission rates and various controls applied to
 achieve at least 95 percent control.  One uncontrolled or controlled
 rate for fugitive emissions was included in each case based on an
 assumed equipment count and SOCMI emission factors.

     Due to the wide range of emission and cost estimates for the model
 cases, lower and upper bound estimates were made for the nationwide
 impacts.  PES used the following general  approach to estimate the lower
 and upper bound estimates:  First,  the number of 8 Gg per year capacity
 plants required to treat 436 million gallons per year of solvent
 waste was estimated.1  Secondly, from the model  case analysis,
 representative lower and upper bound estimates of emissions and costs
 on a per plant basis were selected.   Finally, the total  number of 8 Gg
 per year plants was multiplied by the representative per plant estimates
 to derive the nationwide impacts.

     The estimated nationwide impacts are presented  below.   It should
be emphasized that,  although we  feel  the  approach used to estimate  the
nationwide  impacts is reasonable given the  limited data  available,  the
impacts presented  are highly uncertain, and at best  represent order-
of-magnitude  estimates.
iBased on information provided by EPA,  PES understands that the impacts
 are to be estimated for treating 428 million gallons of solvent waste
 currently treated by distillation plus an additional  8.3 million
 gallons that may be treated  by distillation  as  a  result of EPA/OSW's
 proposed land banning action.
-------
 Estimate of  the Total Number of 8 Gg per Year (Solvent Production
 Capacity Plants Required

     The assumptions and calculations used to estimate the number of
 8 Gg per year (production capacity) model plants necessary to treat
 436 million  gallons of solvent waste are presented in Attachment 1.
 The key assumption affecting the result is the average recovery factor
 assumed.2  Based on a review of available information, an average
 recovery factor of 55 percent appears reasonable.3  Using this as an
 assumed average recovery rate, the number of 8 Gg per year plants
 required to  treat 436 million gallons of solvent waste is 95.

 Estimates of Lower and Upper Bound Nationwide Emissions

     The upper and lower bound estimates of per plant, uncontrolled and
 controlled condenser vent (process), fugitive, and total  emissions are
 presented in Table 1.  The nationwide estimates of total  uncontrolled
 and controlled emissions assuming 95 plants are shown in Table 2.

 Estimate of Lower Bound Nationwide Control  Cost

     Of the control techniques costed for application to the model
 cases (secondary condensers, flares, and incinerators), secondary
 condenser, control  is the least costly method of controlling process
 condenser vent emissions.  Therefore, this control technique applied
 to process condenser vent emissions, plus fugitive emission controls,
 i.s assumed as the basis of l.ower bound control cost estimates.

     Table 3 presents a summary of cost estimates to apply secondary
 condenser control  to process condenser vent emissions for the various
 cases analyzed.4  As can be seen,  there is a large difference in the
 estimates prepared using the condenser costing program and those
 prepared by hand calculation.   Considering that the costs for the
 7 Ib/h emission rate cases were consistently computed using the cost
 program, and that these are the lower cost estimates, it was decided to
 use these in developing a lower bound nationwide cost estimate.

     Table 4 shows the range and average of per plant estimates of
 capital cost,  annual cost (before recovery credit),  recovery credit,
 and net annual  cost for the 7 Ib/h condenser vent emission cases.

      Using the average costs  of condenser vent process emission
 controls from Table 4, and the cost of fugitive emission  controls
Recovery Factor = Yo1ume of So1vent Recovered
                     Volume of Waste Treated

3A separate memorandum will be submitted on selection of the average
 recovery factor.

4This is Table 3 from the October 21 memo with all  costs updated to
 June 1985 $.
-------
                    Table 1.   LOWER AND UPPER BOUND ESTIMATES OF ANNUAL
                           VOC EMISSIONS FROM A WSTF MODEL PLANT
                                (8 Gg/y Solvent Production)
Uncontrolled Emissions,
Mg/yr (tons/yr)a
Description
Lower Bound Estimate
(Uncontrolled Condenser Vent
Emissions = 3.2 kg/h
[7 lb/h])
Upper Bound Estimate
(Uncontrolled Condenser Vent
Emissions = 34 kg/h
[75 lb/h])
Condenser
Ventc
13.2
(14.6)
141.5
(156.0)
Fugi-
tives01
13.7
(15.1)
13.7
(15.1)
Total
26.9
(29.6)
155.2
(171.1)
Controlled Emissions,
Mg/yr (tons/yr)b
Condenser
Vent
0.7
(0.7)
7.1
(7.8)
Fugi-
tives
3.5
(3.9)
3.5
(3.9)
Total
4.2
(4.6)
10.6
(11.7)
aAl1  figures are rounded to the nearest one-tenth.

aAssumed control level  is 95% control  of condenser vent emissions plus a leak detection
 and  repair program for fugitive emission control.  All figures are rounded to the
 nearest one-tenth.

cTo  compute condenser vent emissions,  4,160 hours per year of operation was assumed.

dTo  compute fugitive emissions, 8,760 hours per year of operation was assumed.
-------
         Table 2.  LOWER AND UPPER SOUND ESTIMATES OF NATIONWIDE ANNUAL
                    VOC EMISSIONS FROM 95 WSTF MODEL PLANTS



                         Nationwide Uncontrolled       Nationwide Controlled
Description            Emissions, Mg/yr (tons/yr)a   Emissions, Mg/yr (tons/yr)a



Lower Bound Estimate             2,550                           400
                                (2,810)                         (440)



Upper Bound Estimate            14,740                         1,010
                               (16,250)                       (1,110)
Includes condenser vent and fugitive emissions.   All  figures are rounded to
 the nearest 10.
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                     Table 3.   SUMMARY  OF CONTROL  COST ESTIMATES  FOR  WSTF
                              DISTILLATION VENTS -  CONDENSER  CONTROL
                                             [June 1985 S)
. S tream
Item
Control System
Control costs:
Capital, $
Total annuallzed. S
Recovery Credit, S
Met Annuallzed, I
Annual Emission Reduction,
ton/yr
Cost Effectiveness, J/ton
Case la
VOC * 7 Ib/h
Toluene
Condenser

3.350
1.S8S
(4,550)
(2,665)
13.83
(192.70)
Case 2°
VOC » 12 Ib/h
Toluene
Condenser

21.000
4.700
(8\126)
(3,426)
23.9
(143.35)
Case 3*
VOC - 7 Ib/h
Methyl Ethyl
Ketone
Condenser

3,337
1.678
(8,957)
(7.279)
13.83
(526.32)
Case 4°
VOC « 32 Ib/h
Methyl Ethyl
Ketone
. Condenser

28.500
6,400
(45,525)
(39.125)
S3. 23
"(618.77)
Case S*
VOC « 7 Ib/h
Trlchloroe thane
Condenser

2.631
1.425
(10.077)
(8,652)
13.83
(625.60)
Case 6"
VOC - 75 Ib/h
Trlchloroe thane
Condenser

29 , 000
5.SOO
(11,025)
(5,525)
148.99
(37.08)
 (  I indicates a credit.
 Cost estimates were developed using PES'  condenser cost algorithm  In "Polymers Manufacturing NSPS"; all costs have been
 adjusted to June 1985 dollars.

o
 Cost estimates developed using  standard cost estimation procedures and vendor data for condenser  costs.
-------
      Table 4.  RANGE AND AVERAGE OF PER PLANT COSTS TO APPLY SECONDARY
                   CONDENSER CONTROL TO 7 Ib/h MODEL CASES
Range of Cost
or Credit
Capital Cost Range, $ 2,631 - 3,850
Annual Cost Range, $/yr 1,425 - 1,885
Recovery Credit Range, $/yr (4,550 - 10,077)
Net Average Annual ized
Cost with Recovery Credit, $/yr
Average Cost
or Credita
3,270
1,660
(7,860)
(6,200)
(     )  Indicates a cost credit.

aRounded to the nearest 10.
-------
 computed using ESED/CPB's LOTUS l-2-?3 costing program  for  fugitive
 emission controls for pumps, valves, and  leaks, total  lower  bound
 per plant and nationwide control costs are presented in Table 5.

 Estimate of Upper Bound Nationwide Control Cost

      Upper bound control costs were estimated assuming:  (1) incinerator
 control of condenser vent process emissions for halogenated  compounds
 (plus fugitive controls); (2) flare control of condenser vent process
 emissions for non-halogenated compounds (plus fugitive controls);
 and (3) that 20 percent of pla'nts process halogenated  compounds and
 80 percent process non-halogenated compounds.5

      Table 6 presents the range and average of per plant costs computed
 by PES to apply incinerator control to process condenser vent emissions
 for the model  cases involving halogenated compounds.   Table  7 presents
 this information  for flare controlled cases involving non-halogenated
 compounds.

      Using the average  costs presented in Table  6,  Table 8  shows the
 estimated cost to apply  incinerator control  to process  condenser vent
 emissions plus fugitives emission  control  at 19  model  plants (20% of 95
 total  plants).  Similarly,  Table 9  shows, the  costs  to  apply flare
 control  to process  condenser vent  emissions  plus fugitive "controls at
 76 plants (80% of 95 total  plants).

      The  upper bound nationwide  costs  are  then  computed as  the  sum of
 the  total  control  cost for  19  plants  (Table  8) and  the  total  control
 cost for  76  plants  (Table  9).   The  total  upper bound  nationwide  cost
 of control  is  shown  in Table 10.

 Summary of  Nationwide Estimates

     A  summary  of lower  and  upper bound nationwide  estimates  of  emis-
 sions and  control costs  is presented in Table  11.
5PES judgment based on a review of material supplied by K.C. Hustvedt
 of ESED/CPB.
-------
                  Table 5.  ESTIMATE OF LOWER BOUND  NATIONWIDE
                          •   COST TO APPLY CONTROLS
                                 '(June, 1985 $)
Per Plant Cost

Capital Cost, $
Annual Cost, $/yr
Recovery Credit, $/yr
Net Annual Cost (with
Recovery Credit), $/yr
Process
Control3
3,270
1,660
(7,860)
(6,200)
Fugitive
Control b
26,960
11,900
(4,520)
7,380
Total
30,230
13,560
(12,380)
1,180
Nationwide
Total0
2,872,000
1,288,000
(1,176,000)
112,000
(    )  Indicates a cost credit.

aSource:  See Table 4.

^Source:  Memorandum.  Fitzsimons, G.,  Pacific  Environmental  Services,  Inc.,  to
          Dimmick F., U.S. EPA:ESED:SDB.  January  24, 1986.   Revised  Costs  for
          Fugitive Emission Control at  a Model  WSTF.

GAssuming 95 model plants.  All figures are  rounded to  the  nearest  1,000.
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         Table 6.  RANGE AND AVERAGE OF PER PLANT COSTS TO APPLY
                   INCINERATOR CONTROL TO MODEL CASES*
                            Range of Cost              Average Cost


Capital Cost Range, $            209,000^                 209,000

Annual Cost Range, $/yr      151,000-164,000              158,000
aSource:  Memorandum.  Meyer, J., Pacific Environmental Services, Inc.,
          to Dimmick, F., U.S. EPA:ESED:SDB.  October 31, 1985.  Revised
          Incinerator Cost Estimates and Additional Cost Estimates for
          Secondary Condenser Control.

bCapital cost identical in both cases analyzed.
         Table 7.  RANGE AND AVERAGE OF PER PLANT COSTS TO APPLY
                      FLARE CONTROL TO MODEL CASESa
                            Range'of Cost              Average Cost


Capital Cost Range, $         81,000-91,000                86,000

Annual Cost Range,  $/yr       43,000-52,000                48,000
aSource:   Memorandum.   Meyer,  J.,  Pacific Environmental  Services,  Inc.,
          to Dimmick,  F.,  U.S.  EPA:£SED:SDB.   October  21,  1985. .
          Model  Facility Parameters and Draft Control  Cost Estimates.
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        Table 8.  ESTIMATE OF COST TO APPLY  INCINERATOR  PROCESS  EMISSION
          CONTROL PLUS FUGITIVE EMISSION CONTROL AT SQ%  OF THE PLANTS3
                                 (June 1985  $)


Capital Cost, $
Annual Cost, $/yr
Recovery Credit, $/yr
Net Annual Cost, $/yr
Per
Process
Control b
209,000
158,000
—
158,000
Plant Costs
Fugitive
Control0
26,960
11,900
(4,520)
7,380

Total
235,960
169,900
(4,520)
165,380
Cost to Control
48 Plants
11,326,000
8,155,000
(217,000)
7,938,000
(   )  Indicates a cost credit.

&2Q% of 95 total plants (19 plants) are estimated to treat halogenated  compounds,

bSee Table 6.

cSource:  Memorandum.  Fitzsimons, G., Pacific Environmental Services,  Inc.,  to
          Dimmick F., U.S. EPA:ESED:SDB.  January 24,  1986.  Revised  Costs  for
          Fugitive Emission Control at a Model WSTF.
           Table 9.  ESTIMATE OF COST TO APPLY FLARE PROCESS  EMISSION
          CONTROL PLUS FUGITIVE" EMISSION CONTROL AT 50% OF TKE  PLANTS3
                                 (June 1985 $)
Per Plant Costs

Capital Cost, $
Annual Cost, $/yr
Recovery Credit, $/yr
Net Annual Cost, $/yr
Process
Control5
86,000
48,000
—
48,000
Fugitive
Control0
26,960
11,900
(4,520)
7,380
Total
112,960
59,900
(4,520)
55,380
Cost to Control
47 Plants
5,309,000
2,815,000
(212,000)
2,603,000
(    )  Indicates a cost credit.

a80% of 95 total plants (76 plants) are estimated to treat non-halogenated
 compounds.

bSee Table 7.

cSource:  Memorandum.  Fitzsimons, G., Pacific Environmental Services,  Inc.,  to
          Dimmick F., U.S. EPA:ESED:SDB.  January 24, 1986.  Revised Costs  for
          Fugitive Emission Control at a Model WSTF.

                                       10
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                  Table 10.  ESTIMATE OF UPPER BOUND NATIONWIDE COST TO
                    APPLY PROCESS AND FUGITIVE CONTROLS AT 95 PLANTS3
                                      (June 1985 $)
                                                Cost to Control
                           	95 Plants

                            Capital Cost, $        16,635,000

                            Annual Cost, $/yr      10,970,000

                            Recovery Credit, $/yr    (429,000)

                            Net Annual Cost, $/yr  10,541,000


                            (   )  Indicates a cost credit.

                            aComputed from Tables 8 and 9.
                 Table 11.  SUMMARY OF LOWER AND UPPER BOUND ESTIMATES OF
                          NATIONWIDE EMISSIONS AND CONTROL COSTS
                                      FOR 95 PLANTS

Lower
Bound
Upper Bound
Uncontrolled Controlled Uncontrolled
VOC Emissions,3 Mg/yr
(tons/yr)
Control Costsb
Capital Cost, $
Annual Cost, $/yr
Recovery Credit, $/yr
Net Annual Cost (with
recovery credit), $/yr
2,550
(2,810)

n.a.
n.a.
n.a.
n.a.
400
(440)
.
2,872,000
1,289,000
(l,176,000)c
113,000
14,740
(16,250)

n.a.
n.a.
n.a.
n.a.
Control 1 ed
1,010
(1,110)

16,635,000
10,970,000
(429,000)c
10,541,000
3From Table 2.

bFrom Tables 5 and 10.  All costs are in June, 1985 $.

c(   )  Indicates a cost credit.
                                        11
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ATTACHMENT 1 - DETERMINATION OF NUMBER OF,MODEL PLANTS  REQUIRED
    TO HANDLE 436.3 MILLION GALLONS OF SOLVENT WASTE PER  YEAR
Assumptions:

     Model Plant. Size » 8 Gg Solvent Produced/yr
                      * 8E+06 kg/yr

     Density of Reclaimed Solvent = 7 Ib/gal • 3.175 kg/gal


Estimate of Number of Model Plants Required:

       Mass of      Vol. of Waste     Recovery    Density of
 1)   Recovered *     Treated      X    Rate   X  Recovered
       Solvent         (gel)                      Solvent  appears reasonable.  Using this
    recovery rate, the total number .of plants required to treat
    436.3 million gallons of solvent waste is 95.
-------
                       Figure 1.

      Number  of S Gg/Yr  Plants Required
                 ta Treat 433.3 Million Gallons of Waste
1
a.
ID
u_
0
    SO
                            f?at= (~)
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ATTACHMENT 9
-------
                                     June  5,  1986
 MEMORANDUM
 TO:        Fred  Dimmick,  SDB
 FROM:      Steve York,  RTI
 SUBJECT:   Draft Calculation  of  Impacts for Proposed WSTF Standards

      Per  your  request  of 5/20/86, we have developed rough estimates of the
 environmental,  health, and cost impacts of controlling all TSDF operations
 handling  waste  streams with  greater than 10%  organics.  The impacts only
 account for  fugitive emissions; insufficient  data are available to estimate
 the  number of TSDF's handling waste streams with greater than 10% organics
 that have process vents, the number of process vents per TSDF if there are
 process vents,  and the number of process vents with emission controls  already
 in place.
     The  first  step in estimating .impacts  was to estimate the number.of TSDF's
 handling  waste  streams with greater than 10 percent organics.   Because of  the
 present lack of detailed  waste characterization data,  the industry  profile was
 used to generate a range  of the number  of  TSDF's that  potentially manage
 greater than 10 percent organic content  wastes.  The industry  profile  contains
 information about the types of management  methods employed and  the  waste types
 (RCRA codes)  managed by facilities that  have  submitted RCRA  Part A
 applications.  As a  lower bound estimate,  the number of  facilities  with
incinerators  was calculated,  based on the  assumption that  incinerators  would
be used as treatment for  high organic content  streams.   The  number  is
overstated to some extent because  solids incineration  could  not  be  separated
from liquid incineration.  As an upper bound  estimate, the number of
facilities managing  organic liquids, pesticides,  and D001  and D002  wastes  was
computed.   Table 1 lists  the  RCRA  codes  classified  as  organic liquid and
-------
     TABLE 1.  RCRA CODES SERVING AS BASIS FOR UPPER BOUND ESTIMATE
   Waste type                                RCRA Waste Code
Organic liquids                     K011   K012   K013   K014   K022
                                    K023   K026   K027   K047   K073
                                    P002   P003   P005   P009   P014
                                    P018   P019   P022   P025   P042
                                    P046   P053   P054   P069   P077
                                    P081   P082   P083   P086   P093
                                    P100   P101   P102   U001   U003
                                    U004   U005   U007   U008   U009
                                    U012   U015   U021   U022   U028
                                    U031   U037   U051   U052   U053
                                    U055   U056   U083   U085   U086
                                    U088   U089   U090   U091   U092
                                    U096   U098   U099   U100   U101
                                    U102   U103   U104   U105   U106
                                    U107   U108   U109   U110   Ulll
                                    U112   U113   U115   U116   U118
                                    U119   U122   U124   U125   U133
                                    U140   U149   U150   U152   U153
                                    U155   U162   U165   U167   U169
                                    U170   U171   U172   U173   U174
                                    U175   U176   U177   U178   U179
                                    U180   U186   U188   U191   U197
                                    U200   U201   U213"   U221   U223
                                    U237

Pesticides                          D012   D013   D014   D015   D016
Herbicides                          D017   F027   K031   K032   K033
                                    K034   K036   K037   K038   K039
                                    K040   K041   K042   K043   P001
                                    P004   P007   POOS   P020   P021
                                    P034   P035   P037   P038   P039
                                    P040   P041   P043   P044   P045
                                    P047   P048   P049   P050   P051
                                    P057   P058   P059   P060   P066
                                    P067   P070   P071   P072   P075
                                    P085   P088   P089   P090   P091
                                    P092   P094   P097   P108   P109
                                .    Pill   P113   P114   P115   P116
                                    P117   P118   P122   U010   U011
                                    U014   U017   U036   U058   U060
                                    U061   U062   U066   U082   U087
                                    U097   U114   U136   U142   U158
                               '   •  U224   U230   U231   U232

Characteristic of                   D001
 ignitability

Characteristic of                   D002
 corrosivity
-------
pesticide wastes.  The upper bound estimate double counts some facilities  with
incinerators and WSTF's (e.g., P022, U031, U037, U052, U060, U112,  U140,
U169). The lower and upper bound estimates of TSDF's handling greater  than 10
percent organic waste streams are 269 and 2,332 facilities.   To  estimate
impacts, the midpoint of this range, 1300 facilities,  was used.
     As you suggested, "per facility" estimates from the WSTF assessment were
used to calculate the national  impacts of regulating fugitive VOC emissions
from TSDF's handling greater than 10 percent  organic waste streams.  Table 2
presents the nationwide emission and health  risk impacts and associated
control costs.
     Several  uncertainties are apparent in the estimation of impacts of
controlling all TSDF operatons  handling waste streams  with greater than 10%
organics.  There is little basis for estimating the number of these
facilities, as  is evidenced by  the range between the upper and lower bound
estimates.  The nationwide impacts are based  on "per facility" estimates for
WSTF's, which in turn are based on SOCMI emission factors and the equipment
count specified in the benzene  fugitive emission standard model  case A.
Fugitive emissions are proportional  to the number of pumps,  valves, flanges,
sampling connections, etc.  Therefore, the "per facility" estimates of
fugitive emissons and the associated incidence and control costs are only  as
good as the benzene fugitive emission standard model  case A  is representative
of a TSDF handling greater than 10%  organic content  wastes.
     Also at  your request, we have calculated  incremental  environmental,
health, and cost impacts  of using flares/incinerators  versus condensers to
control WSTF  process  emissions.  Table 3 presents these  estimates, based on a
prorating analysis as you  suggested.
-------
                                     TABLE 2.  NATIONWIDE IMPACTS
*
Fugitive emissions (Mg/yr)a
Incidences (cases/yr)^
Control costc: capital ($)
annual ($/yr)
Factor/faci
Uncontrolled
13.7
0.0005
N/A
N/A
lity
Controlled
3.5
0.0001
26,960
7,380
Number of
faci lities
1300
1300
1300
1300
Nationwide
Uncontrolled
17,810
0.65
N/A
N/A
estimates
Controlled
4,550
0.13
35,000,000
9,600,000
a Attachment 8, Table 1, Lower Bound Estimate.

b Attachment 6, Summary of Results Using this Approach.   Nationwide  incidences  per year  for  2  x  10~6
  Unit Risk Factor (the midpoint of the range of  Unit  Risk  Factors)  were factored by  percentage  of
  nationwide emissions estimated to be fugitive from Attachment  8, Table 1  and  by 95  3.2 kg/h  WSTF
  plants to derive per facility factor.  (Note that  incidence  presented  in  Attachment  6  was  estimated
  using 50 percent 3.2 kg/h and 50 percent  34 kg/h plants).

c Attachment 8, Table 5.
-------
                       TABLE 3.
INCREMENTAL  IMPACTS OF CONTROLLING WSTF  PROCESS VENT EMISSIONS* WITH
          FLARES/INCINERATORS VERSUS CONDENSERS
Process Vent
Emissions
Control
Technique
Condensers
Flares/i nci nerators
Incremental Impact
Nationwide Emissions
(Mg/yr)b
Uncontrolled
8,660
8,660

Controlled
700
470
230
Nationwide
Control
Cost ($/yr)c
112,000
7,351,000
7,239,000
Nationwide Incidences
per year^
Uncontrolled
0.34
0.34

Controlled
0.028
0.018
0.010
Maximum Individual
Risk6
Uncontrolled
3.7xlO-3
3.7x10-3

Controlled
2.6x10-4
2.0x10-4
6.0x10-5
a Fugitive emissions and control costs are included,  but control  efficiency and cost  of controlling fugitive emissions  are
  the same for the upper and lower bound cases,  therefore the incremental  impacts  represent  differences  in process  vent
  emissions and control costs.

  Attachment 8, Table 1, average of Lower Bound  Estimate.and Upper Bound  Estimate  of  uncontrolled  condenser vent  and
  fugitive emissions x 95 WSTF s.  Condenser achieves 95% control; flares  and  incinerators achieve 98% control; leak
  detection and repair program achieves 75% control of fugitive emissions.

c Lower bound nationwide control cost  is cost  of  condenser control  of  process  emissions  plus  fugitive  emission control
  from Attachment 8, Table 5.  Upper bound nationwide control  cost is  cost'of  incinerator process  emission control  plus
  fugitive emission control  at 20% of  the plants  and  flare process emission control plus fugitive  emission control  at 80%
  of the plants from Attachment 8, Tables 8 and  9,  respectively.

d From Attachment 6, Summary of Results Using  this  Approach.   Based  on  Unit Risk Factor  of 2  x  lO'6, the midpoint of the
  range of Unit Risk Factors.  Nationwide incidences  per year  for  flares/incinerators control of process vent emissions
  factored from nationwide incidences  per year for  uncontrolled emissions using  ratio of nationwide controlled and
  uncontrolled emissions.

e From Attachment 6, Summary of Results Using  this  Approach.   Based  on  maximum  Unit Risk Factor of  2 x lO'5.  Maximum
 individual  risk  for flares/incinerators control  of process  vent emissions  factored from maximum individual  risk for
 uncontrolled emissions using ratio of nationwide control-led and uncontrolled  emissions.
-------
APPENDICES
-------
APPENDIX A




REFERENCES
-------
-------
 APPENDIX A - LIST OF REFERENCES
 AUTHOR:    Allen,  C.,  Brant,  G.,  Husband,  S.,  and Simpson, S
 DOC.TYPE:' Site Visit  Report
 TITLE1:    Hazardous  Waste Pretreatment for Emissions Control:  Field
 TITLE2:    Evaluations - Oil  & Solvent Process Co.,  Azusa, CA
 DATE:      May  22,  1985


 AUTHOR:    Allen,  C..  Brant,  G.,  and Simpson,  S.
 DOC.TYPE:  Site Visit  Report
 TITLE1:    Hazardous  Waste Pretreatment for Emissions Control:  Field
 TITLE2:    Evaluations - Environmental Recycling,  Durham,  N.C.
 DATE:      May  22,  1985


 AUTHOR:    Allen.  C.,  Brant,  G.,  and Simpson,  S.
 DOC.TYPE:  Site Visit  Report
 TITLE1:    Hazardous Waste Pretreatment for Emissions Control:  Field
 TITLE2:    Evaluations - Plant A
 DATE:      May  22,  1985
AUTHOR:
DOC.TYPE
TITLE1 :
TITLE2 :
DATE :
Allen, C., Brant,  G.,  and  Simpson,  S.
Site Visit Report
Hazardous Waste Pretreatment  for  Emissions  Control:  Field
Evaluations - Romic  Chemical  Corporation.  E.  Palo  Alto   CA
May 22, 1985
AUTHOR:   Allen, C., Brant, G., and Simpson, S.
DOC.TYPE: Site Visit Report
TITLE1:   Hazardous Waste Pretreatment for Emissions  Control: Field
TITLE2:   Evaluations - IT Corporation, Martinez, CA
DATE:     May 22, 1985
AUTHOR:
DOC.TYPE
TITLE1 :
TITLE2 :
DATE :
Allen. C.. Brant, G., and Simpson, S.
Site Visit Report
Hazardous Waste Pretreatment for Emissions Control: Field
Evaluations - Alternate Energy Resources, Inc.. Augusta  GA
May 22, 1985
AUTHOR:
DOC.TYPE
TITLE1 :
TITLE2 :
DATE:
Allen,  C.C.,  et. al.,  Research Triangle Institute
Final Report  for EPA/ORD
Field Evaluations of  Hazardous Waste Pretreatment As An Air
Pollution Control Technique
September 1985
-------
AUTHOR:'   Allen, C.C., et . al., Research Triangle  Institute
DOC.TYPE: Final Report for EPA/ORD
TITLE1:  , Field Evaluations of Hazardous Waste Pretreatment
T'ITLE2:   Pollution Control Technique
DATE:     April 1985
                                                  as an Air
AUTHOR:   Arienti, M., et. al., GCA Corporation
DOC.TYPE: Final Report for EPA/OSW
TITLE1:   Technical Assessment of Treatment Alternatives
TITLES:   Containing Halogenated Organics
DATE:     October 1984
                                               for Wastes
AUTHOR:   Balfour, W.D., et. al.. Radian Corporation
DOC.TYPE: Report for EPA/ORD
TITLE1:   Evaluation of Air Emissions From Hazardous Waste Treatment,
TITLE2:   Storage, and Disposal Facilities
DATE:     June '1984


AUTHOR:   Battye, W., et. al.. GCA Corporation
DOC.TYPE: Final Report for EPA/OAQPS
TITLE!:   Preliminary Source Assessment for Hazardous Waste Air Emissions
TITLE2:   From- Treatment, Storage, and Disposal Facilities (TSDFs)
DATE:     February 1985


AUTHOR:   Breton, M., et. al., GCA Corporation
DOC.TYPE: Draft Final Report for EPA/OSW
TITLE1:   Assessment of Air Emissions From Hazardous Waste Treatmt, Storage
TITLE2:   and Disposal Facilities-Preliminary National Emissions Estimates
DATE:     August 1983
AUTHOR:   Engineering Science
DOC.TYPE: Draft Final Report
TITLE1:   Supplemental Report on
TITLES:   Alternatives for Waste
DATE:      September 1984
                       the Technical
                       So 1vents
             Assessment of Treatment
AUTHOR:   Fitzsimons, G.. Pacific Environmental Services, Inc.
DOC.TYPE: Memorandum to Project File
TITLE1:   Miscellaneous Information Received From EPA/ESED on the
TITLE2:   Composition of Wastes Processed at TSDT's
DATE:      November 20.  1985
AUTHOR:
DOC.TYPE
TITLE1:
TITLE2:
DATE :
GCA Corp.
Monthly Progress Report
Performance Evaluations

September  1985
No
of
Existing Treatment Systems
-------
AUTHOR:   Hargate.  A., Liberty Solvents and Chemicals Company
DOC.TYPE: Letter to K.C. Hustvedt/EPA
TITLE1:   Corrections to Case Study Prepared by Engineering Science  on
TITLE2:   Liberty Solvents
DATE:     August 30, 1984
AUTHOR:
DOC.TYPE
TITLE1:
TITLE2:
DATE:
ICF Inc.  .
Report for EPA/OSW
The RCRA Risk-Cost Analysis Model Waste Stream Data Base

July 9,  1984
AUTHOR:
DOC.TYPE
TITLE1:
TITLE2:
DATE:
ICF,  Inc.
Report for EPA/OSW
The RCRA Risk-Cost Analysis Model

March 1, 1984
- Phase III Report
AUTHOR:   Lloyd, L.L., Engineering Science
DOC.TYPE: Memorandum to Porter, F.L.
TITLE1:   Development of a Control Technology Guideline
TITLES:   for the Waste Solv'ent Recovery Industry
DATE:     January 30, 1981
                                               CTG)  Document
AUTHOR:   Radian Corporation
DOC.TYPE: Data Vol. for Site 6
TITLE1:   Evaluation of Air Emissions From Hazardous Waste Treatmt, Storage
TITLE2:   and Dispasal Facilities in Support of the RCRA Air Emission RIA
DATE:     February 21, 1984
AUTHOR:   Research Triangle Institute
DOC.TYPE: Report for EPA/IERL
TITLE1:   Preliminary Assessment of Hazardous
TITLE2:   Air Pollution Control Technique
DATE:      October 15. 1984
                                    Waste Pretreatment as an
AUTHOR:   Rimpo,  T., Radian Corporation
DOC.TYPE: Letter  to D. Beck, EPA/CPB
TITLE1:   Documentation for the Synthetic Organic Chemicals Manufacturing
TITLE2:   Industry (SOCMI) Incinerator/Flare Costing Algorithm
DATE:      September 9, 1985
AUTHOR:   Roeck, D.,  et.  al.,  GCA Corporation
DOC.TYPE:  Draft Final Report  for EPA/OSW
TITLE1:   Assessment  of Wastes Containing Halogenated
TITLE2:   and Current Disposal Practices
DATE:      August 1984
                                            Organic Compounds
-------
AUTHOR:    Spivey,  J.J.,  et.  al.,  Research  Triangle  Institute
DOC.TYPE:  Final  Report  for  EPA/IERL/ORD
TITLE1:    Preliminary Assessment  of  Hazardous  Waste  Pretreatment
TITLE2:    Air  Pollution  Control Technique
DATE:      October  15, 1984
                                                       as an
AUTHOR:
DOC.TYPE
TITLE1 :
TITLE2:
DATE :
Surprenant, N., et. al., GCA Corporation
Draft Final Report for EPA/OSW
Land Disposal Alternatives for Certain Solvents

January 1984
AUTHOR:
DOC.TYPE
TITLE1 :
TITLE2:
DATE:
Turner, M., GCA Corp.
Draft Technical Note
Emission Algorithm Development for Pretreatment Operations

July, 1985
AUTHOR:
DOC.TYPE
TITLE1:
TITLE2:
DATE:
Turner,  M., GCA Corporation
Memorandum
Review of OSW WET-Model Emission Estimation Methodology for
Pretreatment
June 24,  1985
AUTHOR:   U.S. EPA
DOC.TYPE: Source Assessment
TITLE1:   Reclaiming of Waste
TITLE2:   (EPA-600/2-78-004f )
DATE:    'April 1978
                    Solvents,  State of the Art
AUTHOR:   U.S. EPA
DOC.TYPE: BID
TITLE1:   Benzene Fugitive Emissions - Background Information for
TITLE2:   Promulgated Standards (EPA-450/3-80-032b )
DATE:      June 1984
AUTHOR:   U.S. EPA
DOC.TYPE: BID
TITLE1:   VOC Fugitive Emissions
TITLE2:   Background Information
DATE:      November 1980
                       in Synthetic
                       for Proposed
Organic Chemicals Mfg. Indus.
Standards (EPA-450/3-80-033a)
AUTHOR:   U.S. EPA
DOC.TYPE:  BID
TITLE1:   VOC Fugitive Emissions
TITLE2:   Background Information
DATE:      June 1982
                       in  Synthetic  Organic Chemicals Mfg.  Indus
                       for Promulgated  Stds.  (EPA-450/3-80-033b)
-------
AUTHOR:   U.S. EPA
DOC.TYPE: BID
TITLE1:   Distillation Operations in
TITLE2:   Background Information for
DATE:     December 1983
Synthetic Organic Chemical Mfg.
Proposed Standards (EPA-450/3-83-005a
AUTHOR:   U.S. EPA
DOC.TYPE: Federal Register Notice
TITLE1:   Equipment Leaks of VOC From SOCMI...;
TITLE2:   Operations;... and General Provisions
DATE:     April 16, 1985
           Distillation
           (50 FR 14941
Unit Operatior
AUTHOR:   Wyrick, E.T., Morflex Chemical Company
DOC.TYPE: Letter to-K.C. Hustvedt.EPA
TITLE1:   Corrections to Case Study Visit Report
TITLE2:   Greensboro, N.C.  by Versar Inc.
DATE:      June 15.  1984
            for Morflex Chemical
-------
                      APPENDIX  B




HUMAN EXPOSURE MODEL  (HEM) RESULTS  FOR  WSTF MODEL CASES
-------
                           MEMORANDUM



SUBJECT: Human Exposure Model Results for Model WSTF Cases

FROM:    Graham Fitzsimons, PES

TO:      Project File

DATE:    November 19, 1985
     Attached is the computer printout containing the results of
a preliminary risk assessment using the Human Exposure Model
(HEM)  for each of the model cases developed for waste solvent
treatment facilities.  A key to the model cases is also attached

     Each model case was run at six locations.  On the printout,
the corresponding case number for each location can be found at
the right end of each line.

     The area assumed for fugitive emissions (modeled as an area
source) was 5 square meters.  The unit risk factor used to
calculate maximum risk'and incidence Was 2 . OE-05 .   To obtain-
results for a risk factor of 2.0E-07,  divide the results on the
attached printout by 100.
Attachments
-------
                           Attachment 1.  KEY TO MODEL CASES
Pollutant
Emission Ratel
   Ib/h
Uncontrolled
  Case Nos.
                                                            Controlled Case Nos.
                                                       Condenser   IncineratorFlare
MEK


Toluene

1,1,1-Tri chloroethane
     7
    32
     7
    75
     1
     5
     1
     7
2
6
2
8
NA
NA

NA

 4
 9
 3
10
                                                                                  NA
                                                                                  NA
^Uncontrolled emission rate from the condenser vent.
-------
-------
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       APPENDIX C




ADDITIONAL DOCUMENTATION
-------
                                MEMORANDUM



 TO:         File,  PES  Project  No.  758          Date:   November  18,  1985

 FROM:       Jan Meyer,  Pacific Environmental  Services,  Inc.

 SUBJECT:    Recovery Factor Estimate

     This  memorandum  documents  the method  used  to  estimate  the  solvent
 recovery factor.  This  factor is  a conversion factor  that relates  the
 volume  of  waste  solvent entering  a waste solvent treatment  facility  to
 the  volume  of recovered solvent exiting the  facility.   Estimation  of
 a  recovery  factor enables determination of the  number  of model  plants
 that would  be needed  to handle  the nationwide volume  of waste solvent
 requiring  treatment.  The number  of model  plants is  then used to estimate
 nationwide  emissions  of VOC and costs to control these  emissions.

 A.   Recovery Factor Definition

     The recovery factor is defined as the volume  of  VOC recovered by a
.facility per volume of  waste  solvent entering the  facility, and is a
 function of two parameters:   (1)  the VOC composition  of the waste
 stream, and (2) the VOC distillation efficiency of which the facility
 is capable.  This relationship  can be represented as  follows:

      Volvoc out          /    Yo1voc in    \    /   Volvoc out
     VoTwaste in          \   v°Wste in            voc in
where:

     recovery factor  =  Volvoc out
                         "°'waste in


                                       " voc in
     waste stream VOC composition  =     	   ,  and
                                      Volwaste in


     ,.  .,,   .     JJ?J            Volvoc out
     distillation efficiency   =   ______  •
                                  Volvoc in
-------
B.  Recovery Factor Determination

     1.  Waste Stream VOC Composition

     Attachment 1 Is a summary of available Information on the major
solvent wastes composition.  From Attachment 1, the volume weighted
average composition of F001-F005 wastes appears to be about 60 percent
VOC.  Barring receipt of information that shows the basis of these
numbers to be faulty, this estimate appears to be the best that can be
developed given the limited information and time available.

     2.  Distillation Efficiency

     Attachment 2 presents a summary of information on distillation
efficiencies reported in the provided literature sources.  Several of
the case study reports suggest that efficiencies of 80 to 90 percent
are typical of concentrated streams while efficiencies of 50 to 70
percent are expected of dilute or sludgy streams.   The data summarized
in Attachment 2,  however, do not support this generalization.   The
available data suggest that, regardless of YOC composition, distillation
efficiencies can range up to 99 or 100 percent.  The average and median
efficiencies attained are 85 and 90 percent, respectively.  Although
the data are believed to be rather uncertain, the best estimate of
typical distillation efficiency is 85 to 90 percent.

C.  Conclusion

     To estimate volume of YOC recoverable per volume of waste solvent
entering the facility, the volume weighted average VOC composition of
the waste is multiplied by the distillation efficiency.   At the median
distillation efficiency,  the recovery factor is approximately  55 percent.
     0.6 YOCin      0.90 YOCout       =  0.55
     _  x
       wastein  /  \   VOC in
-------
Attachment 1
                               WASTE STREAM VOC COMPOSITION
Waste Code
F001
F002
F003
F004
F005
Tot al
Vol. Wted. Avg.


Amt. Land
Disposed
106 Gallons3
<4.5
16.1 •
77.67
<4.5
460.05
562.82



Avg. VOC
Content, %D
31
63
81
100
55
vol . wted. average
= 59%
round to 60%
(arith. avg. = 66%)
Total Amount
VOC Land Disposed
106 Gallons
<1.4
10.14
62.91
<4.5
253.05
• 331.98



      aSource:   OSW Summary of March 7, 1985, Top 30 Waste Streams in Land Disposal
       (Excluding Injection Wells), by volume.

      bSource:   GCA-TR-83-94-G, p.  31..'-

      Note:   There are several  references  with different volume estimates for these
             categories  of wastes.
            Range
Frequency Distribution of VOC Concentration

   I         Amount                   |        Frequency
<30% VOC
<65% VOC
<85% VOC
<100% VOC
<4.5
476.15
77.67
<4.5
4.5
480.7
558.3
562.8
0.8%
85%
99.2
100
                                                                 Avg.  60%
-------
Attachment 2
                            Summary of Recovery Efficiency Information
Facility
(References)
Plant A: Thin Film Evap.
(RTI-Field Study)
Romic (Thin Film Evap.)
(RTI-Field Study)
IT Corp.: Steam Stripper
(RTI-Field Study)
IT Corp.: Air Stripper
(RTI-Field Study)
AER, Inc: Steam Stripping
(RTI-Field Study)
Environ. Recycling:
(Thin Film Evap. )
(RTI-Field Study)
Oil & Solvent Recycling:
(Thin Film Evap. )
(RTI-Field Study)
Morflex: Dist. Col.
(Versar Report
incomplete)
Plant D: Steam Stripping
(RTI-Field Studies Report)
Plant D: Dist. Col.
(RTI-Field Studies Report)
Feed Composition, %
(A)
100
100
<10
<3
N.A.
83
1
N.A.
95
18
74
26
3
5
23
Disti nation
Efficiency, %
(B)
85 typical
80
90
N.A. (to atmos. )
50 to 70

80-85
N.A.
43
100
92.5
100
99
99
Recovery Factor, 2
(A X B)
85
80
9
0
-

80
<90
8
74
25
3
5
23
    Radian  Test-Site
    (Thin-Film Evap)
85 (MEK)
92
78
    Average
      <50Z  VOC
      >502  VOC
               Avg. = 85Z overall
                                   12% to
                                   79Z to
          a  =  midpoint  of  YOC  range  x  .85

          bAverage  of recoveries  observed  for  range.  >50Z  biased  by  the  majority  cases with
           100Z  VOC feed streams.
-------
                          MEMORANDUM

                                                    November 27,  1985

SUBJECT:   Summary of Information  on the Number and  Treatment Capacities
          of Waste Solvent Treatment Facilities (WSTF's)

FROM:      Jan Meyer, PES
          David Cole,  PES

TO:        Project 758  File
     Information on treatment capacities  and  number  of WSTF's  presented
in the references provided by EPA is  summarized  in Table  1.  The  only
information on the distribution  of treatment  capacities was  presented
in Reference 1 and the distribution is  presented in  Table  2.
-------
                   T-able 1.   ESTIMATES  OF  NUMBER  AND  TYPICAL  CAPACITIES
                                        OF WSTF'S
     Source
Number of WSTF's
 Typical
Capacity,3
  Gg/yr
Comments
Engineering Science,
September 1984(1)
GCA, February 1985
Contract No.
68-01-6871(2)
     61
4,000
392
N.A.
5.5
              Estimate projected from survey
              of National  Association of
              Solvent Recyclers

              Monsanto Research Survey of
              1978

              Number of facilities reported
              to be from 1984 Westat survey
OSW Summary of
TSDF information(3)
    177
    N.A.       Excludes TSDF's incinerating
              waste solvent streams
Calculated from information presented  in  each  report assuming an average solvent
 density of 7 Ib/gal.
N.A. - Not applicable.
-------
             Table 2.  CUMULATIVE FREQUENCY DISTRIBUTION
                 OF WASTE SOLVENT RECOVERY CAPACITIES
                        (Source:  Reference 1)
Capacity
Range
(1,000 gallons
of solvent
per year)
0 -
500
1000
1500
2000
2500
3000
3500
4000
4500
5000
5500
499
- 999
- 1499
- 1999
- 2499
- 2999
- 3499
- 3999
- 4499
- 4999
- 5499
- 5999
Proportion in (1
Internal
(n) (%)
10
3
3
4
0
2
1
5
0
0
0
1
34.5
10.3
10.3 •
13.8
0.0
6.9
3.4
17.2
fl.O
0.0
0.0
3.4
Capacity
,000 gallons
of solvent
per year)
<500
<1000
<1500
<2000
<2500
<3000
<3500
<4000
<4500
<5000
<5500
<6000
Cumulative Frequency
(n) (Z)
10
13
16
20
20
22
23
28
28
28
28
29
34.5
44.8
55.2
69.0
69.0
75.9
79.3
96.6
96.6
96.6
96.6
100.0
Total
29
100
. 29
100.0
-------
References

1.  Engineering Science.   Supplemental  Report on the Technical  Assess-
    ment of Treatment Alternatives for  Waste Solvents.   Prepared  for
    U.S. Environmental Protection Agency,  Washington,  D.C.   September
    1984.   pp.  4-74 to 4-82.

2.  Battye, W., C.  Vought,  D.  Zimmerman, M.  Glowers,  and E.  Ryan  (GCA
    Corporation).   Preliminary Source Assessment for Hazardous  Waste
    Air Emissions  from Treatment, Storage,  and Disposal  Facilities
    (TSDF's).   Prepared for U.S.  Environmental  Protection Agency,
    Research Triangle Park, N.C.   February  1985.

3.  Memorandum  from G. Fitzsimons (PES)  to  Project File.  November 20,
    1985.   Miscellaneous  Information  on  the  Composition  of Wastes
    Processed at WSTF's.
-------
                          MEMORANDUM

                                                    November 25, 1985

 SUBJECT:  Estimate  of Proportion of Waste Solvent Streams Containing
          Halogenated Solvents

 FROM:     Jan Meyer, PES

 TO:       Project #758 File



 I.  Purpose

     This memorandum presents the basis for the assumption that 20
 percent of waste solvent treatment facilities (WSTF's) process halo-
 genated solvent wastes and that 80 percent process nonhalogenated
 solvent wastes.                        «

 II.  Discussion

     The assumption that 20 percent of the facilities treating halogenated
 solvent wastes was derived from the information presented in Attachment
 1.   The fraction of facilities treating halogenated waste solvents was
 calculated:

      fraction     = No.  of facilities treating .halogenated waste solvents
              hal.     Total  number of facilities treating waste solvents

       fraction    =  68
               hal.   TT2

                   = 0.21

 Among the treatment categories presented in the table,  the fraction
 halogenated ranged  from 0.24 to 0.13.

     Several assumptions  were made in use of this factor to estimate
 the upper bound control  costs.   These assumptions were:   (1)  the
 population  of TSDF's surveyed included. WSTF's,  and (2)  the distribu-
 tion of treatment  capacities of WSTF's treating halogenated waste
 solvents does not  differ significantly from that of WSTF's treating
 nonhalogenated waste solvents.   If these assumptions  are invalid,  it
*This information source was used in lieu of derivation of an'estimate
 from estimates of volume of halogenated and nonhalogenated waste
 solvent due to significant differences between  the  estimates
 presented in the various studies provided (see  draft Technical  Note
 for list of references) and the estimates of organic liquid waste
 being used in this study (429 x 106 gallons and 11.1 x 106 gallons).
-------
is believed that the upper  bound  cost  estimates at worst.will slightly
underrepresent the actual upper  limit  of  control costs.
-------
Attachment 1

                                                                 NOV 2 0  1985
                                    MEMORANDUM
        SUBJECT: Miscellaneous  Information  on  the  Composition  of  Wastes
                 Processed at TSDF's

        FROM:    Graham Fitzsimons, PES

        TO:      Project File
             Attached is miscellaneous  information  on  the  composition  of
        wastes processed by hazardous waste  treatment,  storage,  and
        disposal facilities (TSDF's).   This  information  was  provided  to
        PES by the Chemical and Petroleum Branch  of  EPA/ESED  for  use  in
        estimating nationwide emissions from waste  solvent  treatment
        facilities (WSTF1s) .
        Attachments
-------
 Attachment 1
                                           DRAFT
Q .««
                        Number of Facilities Managing Solvent Wastes
                         Based on the RIA National Survey of TSD s
Response to Question;
                         total
                                      halogenated
                                   sbtl llFOOI.ZJU&P
nonhalogenaced
sbtl
1
F004.5
F003
U&P

|_ D001
total quantity managed
total quantity disposed
by landfilling^
by deep well injection
in a surface impoundment
total quantity stored
in surface impoundments
1886
79~"
17
6
8
3
380
69""1
38~~
203
"1556
23T~
1157
185


634
20
12
5
0
2
1
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10
28
8
547
55
426
11
0
55
495
13
8
2
0
2
1
44
10
3
16
6
426
42
"• 337
9
0
43
139
7
4
3
0
0
0
24
12
121
13
89
2
0
12


1252

59

33
12
6
6
2

312

56
28
175
54

1009

176
731
16
7
130
208

5

4
0
0
0
1

39

3
5
21
5

169

22
" 117
4
0
29
224

7

4
2
0
• 1
0

47

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4
25
10

179

28
283

17

8
6
i '
2
0

91

10
11
63
7
1
235

37
127 i 175
4
1
27
Z
'0
24
537

30

17


3
1

135

30
3
66


426

39
" m""


50
                   <.   w A i<«r« at ~n- and ~P" halogenated and nonhalogenated solvents;

            "
              solvents and is assumed  to not contain halogenated solvents
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                                     TECHNICAL flEPOftT DATA
                             (Please read Instructions on the reverse before completing)
  PEr^ORTNO.
  EPA-450/3-86-009
                                                              3. RECIPIENT'S ACCESSION NO.
 .TITLE AND SUBTITLE
  RCRA TSDF Mr Emissions—Background Technical Memoranda
  for Proposed Standards
                                        6. PERFORMING ORGANIZATION CODE
                                                                r, October 1986
  Altf HOR(S)
                                                              3. PERFORMING ORGANIZATION REPORT NO.
 . PERFORMING ORGANIZATION NAME AND ADDRESS

  Office of Air Quality Planning and Standards
  Environmental Protection  Agency
  Research Triangle  Park,  North Carolina  27711
                                                               1O. PROGRAM ELEMENT NO.
                                        11. CONTRACT/GRANT NO.
                                         68-02-4326
 2. SPONSORING AGENCY NAME AND ADDRESS

  DAA for Air Oua-lity  Planning and Standards
  Office of Air, Noise, and  Radiation
  U.S. Environmental Protection Agency
  Research Triangle  Park.  North Parnlina—P7711
                                        13. TYPE OF REPORT AND PERIOD COVERED

                                         Draft           	
                                        14. SPONSORING AGENCY CODE
                                         EPA/200/04
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT

       Standards for  the  control  of volatile organic  (VO)  air emissions from
 .waste treatment,  storage,  and disposal facilities  (TSDF) and waste solvent
  facilities  (WSTF) are  being  proposed under the authority of Section 3004(n)
  Resource Conservation  and  Recovery Act (RCRA).   These standards would apply
  process vents associated with distillation and stripping equipment at WSTF
  if applicable) and  to  fugitive emissions from equipment  leaks at TSDF where
  stream (or  its derivatives)  contain 10 percent or more total organics.  Thi
  contains a  technical note  and background memoranda  considered in developing
  standards.
                                                         hazardous
                                                         treatment
                                                          of the 1976
                                                          to certain
                                                         (and at TSDF,
                                                          the waste
                                                         s document
                                                          the proposed
 17.
                                  KEY WORDS ANO OOCUMHNT ANALYSIS
                    DESCRIPTORS
                                                 b.lDENTIFIERS.'OPEN ENDED TERMS
                                                                              c. COSATl Field/Group
 Air pollution
 Benzene
'Carcinogenic
 Equipment leaks
 Hazardous waste
Recycling
Treatment, storage,  and
 disposal facilities
Volatile organics
Waste solvent  treatment
Air pollution  control
13 B
 National emission  standards
  for hazardous air pollutants
  rocess vents	
              facilities
 18. DISTRIBUTION STATEMENT
    Unlimited
                           19. SECURITY CLASS (This Report)

                             Unclassified  	
                                                                                   _124_
                           2O. SECURITY CLASS (Tl:i

                             Unclassified
                                                                              22. PRICE
  EPA Form 2220-1 (R«v. 4-77)   paevious EDITION is OBSOLETE
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