7115
ITED STATES ENVIRONMENTAL PROTECTION AGE1
Office of Air Quality Planning and Standards
Research Triangle Park. North Carolina 27711
2 6 JUN 1987
MEMORANDUM
SUBJECT:
Operational Guidance on Control Technology for New and
Modified Municipal Waste Combustors (MWCs)
FROM:
TO:
Gerald A. Emlson, 01 reel
Office of A1r Quality PianftTng'am
A1r Management Division Directors
Regions I, III, V and IX
eandards (MO-10)
A1r and Waste Management Division Director
Region'II
A1r, Pesticides, and Toxics Management Division Directors *
Regions IV and VI
A1r and Toxics Division Directors
Regions VII, VIII and X
As you know, numerous questions regarding the selection of appropriate
pollution control requirements for MWCs have arisen during recent years
1n major source permitting proceedings under the prevention of significant
deterioration (PSD) provisions of Part C of the Clean A1r Act and the
nonattalnment new source review (NSR) provisions of Part D of the Act.
Accordingly, the attached operational guidance 1s being Issued to promote
consistency 1n making best available control technology (BACT) determinations
under PSD and lowest achievable emission rate (LAER) determinations under
nonattalnment NSR, and to reduce delay and confusion 1n the permitting
process. This guidance requires reviewing authorities, 1n considering the
range of potential control options during the BACT determination process
for MWCs, to consider a dry scrubber and a fabric filter or electrostatic
predpltator as BACT for sulfur dioxide (SOg) and paniculate matter (PM),
and combustion controls as BACT for carbon monoxide (CO).
The Administrator remanded to Region IX on June 22, 1987, their previous
concurrence on a PSD permit for the H-Power MWC to be constructed 1n Honolulu,
Hawaii. Petitioners had argued that, (a) BACT for this facility did not
adequately justify the failure to require the use of an add gas scrubber,
and (b) the permitting authority did not evaluate the effectiveness of add
gas scrubbers 1n reducing emissions of unregulated pollutants, as required
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicaeo.il 60604-3590
-------
by the June 1986 North County Resource Recovery Associates PSD Appeal
decision (or North County remand). In remanding the H-Power permit appli-
cation to Region IX for further proceedings, the Administrator made 1t
clear that the Agency considers add gas scrubbers to be an available
technology for excess air MWCs that fire refuse-derived fuel (RDF) such as
the H-power facility. The attached operational guidance states that this
type of post-combustion control 1s one component of available technology
for modular, starved air MWCs and massburn, excess air MWCs, 1n addition to
RDF-f1red, excess air MWCs.
As stated above, the operational guidance Includes a second component
of available technology, which 1s combustion control for the criteria
pollutant CO. Since the effectiveness of the two components of available
technology In controlling unregulated pollutants 1s an Important consideration
1n Individual BACT determinations (per the North County remand), the
attached guidance states that (a) add gas scrubbers followed by fabric
filters or electrostatic predpltators are effective 1n controlling
potentially toxic organic and metal pollutants, as well as acid gases
other than sulfur dioxide, and (b) combustion controls are effective 1n
controlling potentially toxic organic pollutants.
The technical basis for the operational guidance 1s documented 1n t
five reports which are a part of the Agency's comprehensive study of MWC.
These volumes are listed 1n the References section of the guidance. You
will note that the guidance Indicates "specified values" should be selected
on a site specific basis for several design and operating parameters of
the facility and for emissions of criteria pollutants. A thorough discussion
of the factors to be considered In choosing the "selected values" 1s
Included 1n the five reports from the comprehensive MWC study.
As noted under Section V, this guidance should be transmitted to all
State and local agencies to which PSD permitting authority has been delegated
under 40 CFR Section 52.21(u). The transmlttal letter should specify that
the delegation agreement Is amended to Include this guidance. States which
have received SIP approval of a PSD program under 40 CFR Section 51,166
(formerly Section 51.24) should also be Informed of this guidance and of
EPA's expectation that 1t be followed.
Attachment
cc: James DeMocker (ANR-443)
Gregory Foote (LE-132A)
Steve Greene (WH-565)
Joseph E. Lees (ANR-443)
J. Craig Potter (ANR-443)
John C. Ulfelder (A-1Q1)
Marda Williams (WH-562)
-------
6/26/87
OPERATIONAL GUIDANCE ON CONTROL
TECHNOLOGY FOR NEW AND MODIFIED
MUNICIPAL WASTE COMBUSTORS
I. The Need for Guidance.
The combustion of municipal waste represents an Increasingly Important
element of the solid waste disposal problem in the U.S. However, the
operation of municipal waste combustors (MWCs) releases potentially harmful
pollutants to the air. Human exposure can occur directly or Indirectly,
and there 1s also concern that the environment could be vulnerable to
long-term accumulation of emitted pollutants. EPA 1s addressing these
Issues 1n a comprehensive, Integrated Municipal Waste Combustion Study and
,41 th this operational guidance.
Numerous questions regarding the selection of appropriate pollution
control requirements have arisen during recent years 1n major source
permitting proceedings under the prevention of significant deterioration
(PSD) provisions of Part C of the Act and the nonattalnment new source
review (NSR) provisions of Part D of the Act. Uncertainty over these
questions has led to conflict over minimum legal requirements and consequent
delay 1n the permitting and construction of MWCs. Hence, there 1s a need
for guidance to resolve controversies which may arise as to facilities
seeking permits. Accordingly, EPA 1s issuing this operational guidance
for use 1n making best available control technology (BACT) determinations
under PSD and lowest achievable emission rate (LAER) determinations under
nonattalnment NSR, EPA believes that this guidance will promote consistency
1n control requirements, and reduce delay and confusion 1n the permitting
-------
2
proctss. At the same time It will allow permitting authorities to give
appropriate consideration to local factors In making case-by-case BACT
determinations as required under law.
II. Administrative History.
Section 169(3) of the Act provides that BACT determinations 1n PSD
permits must be "based on the maximum degree of reduction of each pollutant
subject to regulation under this [Act] . . . which the permitting authority,
on a case-by-case basis, taking Into account energy, environmental, and
economic Impacts and other costs, determines 1s achievable." EPA's
regulations track this language. See 40 C.F.R. 52.2Kb)(12), 40 C.F.R.
51.166(b)(12), In addition, 1n two administrative appeals Involving
resource recovery facilities, EPA has further refined the analysis which $
permitting authorities must conduct 1n making BACT determinations.
In North County Resource Recovery Associates, PSD Appeal No. 85-2
(June 3, 1986), the Administrator Issued a Remand Order which held that,
1n making BACT determinations for a regulated air pollutant, the permitting
authority must consider the effect of that decision on emissions of pollutants
not regulated under the Clean A1r Act. North County provided that the
final BACT decision should address these environmental Impacts, and that
the permitting authority may ultimately choose more stringent emissions
limitations for the regulated pollutant than it would otherwise have chosen
1f 1t would have the collateral benefit of restricting emissions of the
unregulated pollutant. In the North County case, the permitting authority
had required the use of a dry scrubber and fabric filter as BACT for sulfur
dioxide, but had failed to consider the effect of that decision on emissions
-------
3
of certain unregulated pollutants -- dloxlns and furans, heavy metals, and
add gases — on the grounds that it lacked authority to do so. Various
persons petitioned the Administrator under 40 C.F.R. Part 124. In response
to the Administrator's subsequent remand order, the permitting authority
analyzed the effect of various control options on these three classes of
pollutants, and found that no other controls on regulated pollutants would
be more effective 1n reducing emissions of the unregulated pollutants. The
Administrator then ruled that the permitting authority had satisfied the
requirements of the remand order, and denied the petitions. See North
County Resource Recovery Associates, PSD Appeal No. 85-2, Order Denying
Review (September 4, 1986).
The Administrator ruled 1n Honolulu Resource Recovery Facility
("H-Power"), PSD Appeal No. 86-6, Remand Order (Oune 22, 1987), that a PSD
permitting authority has the burden of demonstrating that adverse economic
Impacts justify the failure to require as BACT the most effective control
technology which 1s available. He also found that add gas scrubbers are
an available control technology for sulfur dioxide ($02). The H-Power
decision also provided that the economic Impacts must be specific to the
source In question and substantial. Thus, because the Administrator
agreed with EPA Region IX that Hawaii had not adequately demonstrated the
basis for Us conclusion that economic factors Justified the absence of
flue gas treatment as BACT for $02, he remanded the matter for further
proceedings.
-------
4
EPA today also draws upon the technical data referenced below, and
Its experience 1n Issuing, reviewing, and enforcing PSD permits for MWCs.
Recent emission test data have demonstrated that participate matter (PM),
$02, and other air pollutants (Including organic?, heavy metals, and add
gases) can be controlled effectively by add gas scrubbing devices (dry
scrubbers) equipped with efficient participate collectors. Over 20 MWC
facilities 1n Europe are known to be operating with dry scrubbers and
participate collectors, and at least 37 such facilities are known to exist
1n Japan. In the United States, three facilities currrently are 1n operation
and at least 15 have been permitted to construct with dry scrubbing and
particulate control devices as the specified technology. Thirteen of these
facilities are expected to be operating by December 1988. \
Based on this Information, 1t 1s clear that a dry scrubber followed
by either a fabric filter or electrostatic predpltator are "available"
technologies for effective control of the SOg and PM emitted by MWCs, and
that these technologies also are effective 1n controlling emissions of
potentially toxic organic and heavy metal pollutants, and add gases
other than $03. In addition, the data show that these technologies are
reliable and reasonably affordable. Similarly, combustion controls are
an available technology for the control of carbon monoxide (CO) emitted
by MWCs, and are effective 1n controlling that criteria pollutant and
potentially toxic organic pollutants. EPA's Information Indicates that
this technology also 1s reliable and reasonably affordable.
-------
III. BACT Guidance for SO?, PM, and CO.
Accordingly, 1n considering the range of potential control options
during the BACT determination process for MWCs, the reviewing authority
must consider a dry scrubber and a fabric filter or electrostatic predpltator
as BACT for SOe and PM, and combustion controls as BACT for CO. In order
to justify a BACT determination calling for a lesser degree of emissions
control than can be achieved using these technologies, the permitting
authority must demonstrate, based on Information contained 1n the permit
file, that significant technical defects, or substantial adverse economic,
energy, or environmental Impacts or other costs would arise that are
specific to the MWC 1n question. Permitting authorities remain free to
make case-by-case judgments 1n accordance with today's guidance. However, \
based on the above-referenced Information regarding legal requirements
and the availability, effectiveness, and cost of these technologies, EPA
expects that proper application of this guidance will result 1n few, 1f
any, BACT determinations entailing application of pollution control
technologies less effective than those called for herein.
Today's guidance 1s general; 1t 1s limited to describing types of
post-combustion control equipment and to establishing general criteria
for combustor design, combustor operating practices, emission monitoring,
and operator training. It does not set specific emission limits. Detailed
Information regarding the maximum degree of emissions control achievable
with these technologies 1s available In the referenced technical documents,
the BACT/tAER Clearinghouse, or from EPA. Such Information should be
used by applicants and permitting authorities setting specific emissions
-------
6
limits for PSD permits. In addition, today's guidance only addresses
control technologies currently 1n widespread use for MWCs, and establishes
minimum criteria for BACT determinations. Permitting authorities are not
relieved of their responsibility to consider, on a case-by-case basis,
whatever available technologies may be anticipated to provide a greater
degree of control than those addressed today. Similarly, because control
technologies and the other factors in forming BACT determinations are
constantly evolving, the technology providing the greatest degree of
emissions control taking economic, energy, and environmental Impacts Into
account may likewise change over time. As one example, flue gas treatment
technology for the criteria pollutant nitrogen oxides (NOX) 1s 1n operation
at one MWC 1n the U.S., and this technology shoulc* be considered by permitting
authorities 1n making BACT determinations. In addition, emerging technologies
1n flue gas cleaning may develop which can attain the level of multlpollutant
control currently demonstrated by dry scrubbing/partial!ate matter controls,
and technologies such as these should be considered 1n future BACT determinations.
Permitting authorities and applicants must keep abreast of new developments.
Of course, EPA will assist 1n this endeavor.
IV. LAER Guidance for Nonattalnment Areas.
The technologies discussed herein for control of SOg PM, CO, and NOX
have all been successfully Implemented, and thus have been "achieved 1n
practice" by MWCs within the meaning of section 171(3) of the Act.
Hence, 1n nonattalnment areas where NSR requirements apply and major new
sources and modifications must apply LAER, no less effective pollution
control technologies may be Imposed as LAER.
-------
7
V. Implementation.
Today's guidance applies to all ongoing PSD and NSR proceedings, as
well as to all new permit applications. In consideration of the needs
for program stability and equity to sources which have 1n good faith
relied on pre-existing permitting guidelines, this guidance does not
apply to PSD and NSR permit proceedings for which, as of June 26, 1987,
final permits have already been Issued and, with respect to PSD permits
Issued by EPA, agency review procedures under 40 C.F.R. Part 124 have been
exhausted.
This operational guidance applies to PSD permits Issued by EPA directly
through Us Regional offices and Indirectly through State and local
agencies pursuant to delegation agreements made under 40 C.F.R. 52.21(u).
Such agencies will be notified by letter of this guidance. It will
constitute an amendment to the pre-existing delegation agreements. EPA
Regional offices will review all draft permits for MWCs Issued by delegate
agencies during the public comment period to Insure proper application.
Further program evaluation will take place under the National A1r Audit
System (NAAS). If delegate agencies should fall to adhere to this guidance,
EPA staff may Initiate administrative appeal proceedings under 40 C.F.R,
Part 124 1n appropriate cases. Such action would be appropriate where, for
example, failure to follow the guidance results 1n a finding of fact or
conclusion of law which 1s clearly erroneous, or Involves an exercise of
discretion or an Important policy consideration which the Administrator
should review. See 40 C.F.R. 124.l9(a). Action would also be appropriate
where failure to follow the guidance resulted 1n an Inability to determine,
-------
8
based on the record, whether a clear error occurred. If necessary, EPA
may also revoke the delegation of PSD authority to the State or local
agency.
With respect to State PSD permits Issued pursuant to a State Implementation
plan (SIP) program approved by EPA under 40 C.F.R. 51.166 (formerly 51.24),
and State NSR programs approved under Part D of the Act and 40 C.F.R.
51.165 (formerly 51.18U)), EPA expects States to follow today's guidance
1n generally the same fashion as delegate agencies. EPA will use the
guidance at a reference point 1n Us oversight of State MWC permit actions.
As with delegated permits EPA will participate 1n permit proceedings and
conduct NAAS evaluations. If agencies processing NSR permits or PSD
permits under approved State programs should fall to adhere to this \
guidance, EPA may Initiate administrative and/or judicial action under
sections 113 and/or 167 of the Act 1n appropriate cases. Such action
would be appropriate where, for example, failure to follow the guidance
results 1n a finding of fact or conclusion of law which 1s clearly erroneous,
or 1n an Inability to determine whether a clear error occurred. If
necessary, EPA may also call for SIP revisions under section 110(a)(2)(H).
Insofar as today's guidance addresses minimum legal requirements for
BACT determinations, 1t simply Implements existing regulations and policy,
Including Agency actions already made by the Administrator 1n the North
County and H-Power cases. To the extent the guidance addresses the technical
Issues of availability, effectiveness, and cost of control technologies for
MWCs, 1t expresses EPA's view regarding the proper usage, 1n permit proceedings
under existing EPA regulations and SIP programs, of the factual data contained
-------
9
In the five documents referenced below. Those documents present Information
on the alternative controls available for MWCs, the performance capabilities
and costs of those controls, and the methods for monitoring and measuring
emissions from MWCs. Factors to be considered In choosing the "specified
values" to be Included 1n permits, as noted 1n the guidance, such as maximum
concentration of CO 1n emissions and minimum value of furnace temperature,
are contained 1n these references. Thus, the guidance does not constitute
rulemaklng within the meaning of section 307(d) of the Act or under the
Administrative Procedure Act. Accordingly, It 1s not necessary to Implement
this guidance, as to EPA permits Issued by Regional offices or State and
local agencies, through changes 1n the PSD regulations at 40 C.F.R, 52.21.
Likewise, regarding approved State PSD programs, 1t 1s not necessary to \
revise 40 C.F.R. 51.166 and require corresponding SIP revisions.
VI. Technical Guidance.
Today's operational guidance applies to thre« types of MWCs:
massburn, excess air MWCs; excess air MWCs that fire refuse-derived fuel;
and modular, starved air MWCs. It applies to those MWCs that operate with
energy recovery and those that operate without energy recovery. It applies
to both major new and major modified facilities of these types. The guidance
requires that values for emission limits and operating parameters be specified
1n MWC permitting decisions.
One component of control technology for MWCs 1s the application of the
appropriate post-combustion control equipment. The EPA has Identified
this equipment as a dry scrubber with fabric filter or with electrostatic
-------
10
preclpltator. The concentration of participate emissions 1n the exhaust
gases from the post-combustion control equipment shall not exceed a
specified maximum value; and the S02 emissions 1n the exhaust gases
shall not exceed a specified maximum concentration value or the percent
reduction 1n S0£ emissions across the post-combustion control equipment
shall not be less than a specified value. Performance of the dry scrubber
and fabric filter or electrostatic preclpltator 1n controlling add
gases, potentially toxic metals, and potentially toxic organic pollutants
1s affected slglflcantly by the reduction 1n flue gas temperature which
occurs 1n the dry scrubber. The control system shall be designed and
operated such that the flue gas temperature at the outlet from the dry
scrubber does not exceed a specified value.
A second component of control technology for MWCs 1s proper design
and operation of the combustion system, which controls CO and potentially
toxic organic pollutants. Minimum concentrations of CO 1n emissions from
MWCs are associated with the Implementation of several good combustion
practices. These practices are also related to the effective destruction
of potential emissions of toxic organic pollutants, Including dloxlns and
furans. Concentrations of CO 1n furnace exhaust gases shall not exceed a
specified maximum value, and CO and Og concentrations 1n the exhaust gases
shall be monitored continuously. In addition, furnace operating temperatures
shall be no lower than a specified minimum value, and a procedure for continuous
monitoring shall be established to ensure that the specified temperature Is
maintained.
-------
t>i 'd "iuj.01
11
The capabilities to control flow rates and distributions of underflre
(primary) and overflre (secondary) air, to monitor continuously CO
concentration and furnace temperature, to maintain thermal load within a
specified range, and to control the process to maintain CO and temperature
of the furnace at appropriate levels are all Important to good combustion.
Detailed Information regarding the numerical values to be assigned to the
emission levels and equipment design and operating parameters associated
with good combustion are provided In the documents dted under References.
References;
Municipal Waste Combustion Study: Emission Data Base for Municipal
Waste Combustor*.
EPA/530-SW-87-021B
Municipal Waste Combustion Study: Combustion Control of Organic Emissions.
EPA/530-SW-87-021C
Municipal Waste Combustion Study: Flue Gas Cleaning Technology.
EPA/530-SW-87-021D
Municipal Waste Combustion Study: Cost of Flue Gas Cleaning Technologies.
EPA/530-SW-87-021E
Municipal Waste Combustion Study: Sampling and Analysis.
EPA/53Q-SW-87-021F
-------
From: D.COHEN {EPA1704) Delivered: Wed l-July-87 15:02 EOT Sys 163 (187)
Subject: press release - municipal waste combustors
Mail Id: IPM-163-870701-135340904
MWC press release, July/87
FOR RELEASE: WEDNESDAY, JULY 1, 1987 Robin Woods (202) 382-4377
EPA TO REGULATE EMISSIONS FROM MUNICIPAL WASTE INCINERATORS
The U.S. Environmental Protection Agency today announced that it is requiring
controls on air emissions from municipal waste incinerators in light of findings
which show that available technologies can substantially reduce risks associated
with such emissions.
The agency reported that existing facilities can emit dioxins and other
organic chemicals, metals and acid gases, which, if left unregulated, could
pose health and environmental risks, based on lifetime exposures. New,
state-of-the-art facilities which follow certain performance procedures, such
as providing optimal high-temperature combustion and using various kinds of
pollution-control equipment, can substantially reduce these emissions. fc
J. Winston Porter, Assistant Administrator for Solid Waste and Emergency
Response, said, "Municipal incinerators represent an important option for
solving America's waste problems. EPA is now requiring controls that will
assure the safe operation of this technology."
Don Clay, Deputy Assistant Administrator for Air and Radiation, said
"EPA's conservative risk assessment shows that the potential health risks to
the public are generally small, but of enough concern to justify regulation.
The controls we are calling for today will substantially reduce the potential
risks associated with such emissions."
The findings came in a report to Congress on municipal waste combustion
and in an advance notice of proposed rulemaking for new facilities under the
federal Clean Air Act. Last week, EPA issued guidance to its regional offices
and to states to ensure that the best control technologies are required in the
permitting of new incinerators to control emissions. This guidance will have
the immediate effect of ensuring that these technologies are used on new facilities
even before the development of the upcoming regulations. All facilities must
receive permits under the Clean Air Act.
Concurrent with proposal of regulations for new sources, the agency will
propose guidelines to states for use in developing performance standards for
all existing facilities, calling for the use of best available technologies.
The state implementation of these guidelines is subject to EPA approval, and the
agency can issue regulations for existing facilities in the event states fail
to do so. In 1974 and 1986, EPA regulated dust (called particulate matter)
from these facilities.
As a result of its findings that facility design and operation are major
factors in the control of emissions, EPA has developed a set of "good combustion
-------
- 2 -
practices," which lead to complete combustion through high temperatures and
good air distribution to minimize harmful emissions.
There are currently 111 municipal waste incinerators in the United States,
with a capacity to incinerate 49,000 tons of solid (non-hazardous) waste per
day. An estimated 210 facilities are known to be planned or under construction,
which would add approximately 190,000-tons-per-day capacity by the year 2000.
Incineration of municipal waste is an increasingly attractive waste-management
option to local governments in the face of shrinking landfill availability,
because it reduces the volume of the waste by 70 to 90 percent. Some incinerators
also offer the ability to recover energy from the combustion process that can
be used to offset the energy requirements of the facility or sold to local
industries or utilities. These are often referred to as resource-recovery or
waste-to-energy plants.
There are three types of municipal waste incinerators: 1) mass-burn,
which burns unprocessed waste and is the most prevalent (68 percent of existing
facilities); 2) modular, which also burns unprocessed waste but is generally
smaller than the mass-burn facility; and 3) refuse-derived-fuel, which burrfs
processed wastes, in some cases in conjunction with coal.
EPA is currently studying the characteristics of municipal-wasteincinerator
ash produced in the combustion process. The results are expected to be available
in the early fall.
EPA evaluated six organic chemical constituents in the emissions of municipal
waste incinerators: dioxins, chlorobenzenes, chloriphenols, formaldehyde,
polycyclic aromatic hydrocarbons, polychlorinated biphenyls (PCBs); and six
metals: arsenic, beryllium, cadmium, chromium, lead and mercury. EPA also
evaluated particulate (dust) emissions, sulfur dioxide, hydrogen chloride,
carbon monoxide and nitrogen oxides.
Control technologies can remove a wide range of pollutants from the combustion
gases. A combination of proper combustion conditions, an acid gas scrubber and
a particulate-matter-collection device can reduce: dioxins and furans by greater
than 99 percent; other organics by greater R-93 than 95 percent; hydrogen
chloride by 90 percent; and metals by 97 to 99 percent.
In its health-risk analysis, the agency found that lifetime exposure to
unregulated stack emissions could contribute potential long-term health effects.
EPA believes that its estimated risk is higher than actual risk and that actual
risk may be considerably lower. Using mathmatical models to project possible
exposure to local populations, the agency found that most of the estimated
long-term cancer risk is attributable to dioxins. Under reasonable worst-case
assumptions, unregulated dioxins from existing facilities could potentially
produce, on a national level, from three to 38 cancer cases a year through
inhalation.
EPA believes additional controls could significantly reduce the risks
from all pollutants, including dioxins, to 0.2 to 3.0 cancer cases a year
-------
- 3 -
for all existing facilities, and 0.3 to 1.0 cases for all new facilities.
Several carcinogenic (cancer-causing) metals, arsenic, beryllium, cadmium
and chromium, are emitted in trace quantities. Under worst-case assumptions,
without additional controls the overall national cancer risk associated with
inhalation of these unregulated emissions is estimated to range up to 0.5 cases
per year for existing sources and 0.4 cases for new facilities.
Other carcinogenic organic compounds, chlorobenzenes, chlorophenols,
formaldehyde, polycyclic aromatic hydrocarbons and PCBs, are estimated to pose
similar risks without additional controls, ranging from 0.05 to 0.7 cases a
year for existing facilities and from 0.2 to 0.3 cases for new facilities.
Of the two non-carcinogenic substances studied, lead and mercury, neither
is produced in levels that would exceed current ambient-air standards or guidelines,
EPA also is studying exposure through indirect sources such as absorption
through the skin and from deposits on soil, water and food. Preliminary results
indicate that exposures through indirect mechanisms may be comparable to exposures
through direct inhalation for dioxins, PCBs, chlorobenzenes and mercury. £
Mercury may be further absorbed through food; lead through soil. Indirect
exposure does not appear to be of concern for chromium, beryllium and formaldehyde.
At about one-half of the facilities, hydrogen chloride is produced in
quantities which may lead to corrosion of ferrous metals.
The advance notice of proposed rulemaking will be published in the Federal
Register within the next two weeks. The notice allows a 60-day public-comment
period. The Federal Register can be found at most libraries. Copies of the
"Report to Congress on Municipal Waste Combustion" and supporting documents
will be available for purchase within the next week from the National Technical
Information Service, Springfield, Va. 22161; (703) 487-4600. The Federal
Register notice will provide additional required ordering information.
R-93 | f |
-------
1937-07-01
09: 30
EPA HDQTPS WflSH DC
MUNICIPAL HASTE COKIU8T40N STUDV:
REPORT TO COMBRESS
1403027 02
Juni IM7
Prtptrtd by
Offlct of Solid Wastt and EMffltficy
U.S. EiwIroniAtntal ProttotiM
401 M StTMt \M,
Wtfhlngton, O.C, t04«0
-------
: 3 1 ErMhL'jTP5ujA5H
EXECUTIVE SUMMARY
INTRODUCTION
This report to Congress 1s 1n response to Section 102 of tht Hazardous
and Solid Waste Amendments (HSWA) of 1984. Section 102 of HSWA requires that
the EPA provide a rtport to Congress describing:
"(1) the current data and Information available on omissions of
polychlorlnated d1binzo-p-d1ox1ns from resource recovery facilities
burning municipal solid waste;
(11) any significant risks to human health posed by these omissions; and
(111) operating practices appropriate for controlling these emissions."
The EPA has enlarged the scope of the Section 102 rtport to Include ^
additional Information generated during an Integrated study of Municipal
Waste Combustion. The Integrated study resulted 1n this Report to Congress
and eight technical reports. Much of the Information contained 1f> this
report has been extracted from the technical reports.
MUNICIPAL WASTE COMBUSTION IN THE UNITED STATES
Combustion of municipal waste 1s an attractive waste management option
because It reduces the volume of the waste by 70 to 90 percent, In the face
of shrinking landfill availability, municipal waste combustion capacity 1n
the United States 1s txpected to grow rapidly, from tht currtnt U.S. capacity
of 45,000 tons per day to 117,000 to 252,000 tons per day by tht year 2000.
This added capacity 1s txpected to be added with nearly 200 new municipal
waste combustion facilities.
There are currently 111 municipal waste combustion facilities 1n tht
United States. Figure 1 shows their geographic distribution. Figure 2 shows
geographic locations of 210 facilities known by tht EPA to be planned or
under construction. The maps show that municipal waste combustion facilities
are concentrated on the East Coast with many facilities also planned for
California.
v1
-------
'-01
J3: 3
EPS h D 0 T F 5 Ui-^SH DC
140302'
0-t
Flgurt 1.
l Di»tribt/tton
of Ixiiflftfl Munlo^al WHIi nni||l^tpn
rigurt2
-------
E- DC 143 = 21'
Three main types of combustors irt used for combustion of
waste: mass bum, nodular, and those that fire refute-derived ftttl (*DF).
The first type ts called 'MSS bum* because the waste Is combutttd without
any pre-processing other than removal of Items too large to go through the
feed system. In a typical MSS burn cowuitor, rtfuse Is placed on t grate
that moves through the conbustor. Combustion air In excess of ft*1«MoMtr1c
amounts Is supplied both below (underf1re air) and abeve (overfly air)
grate. Mass burn combustors are usually field-erected and range In MM from
50 to 1000 tons per day of refuse throughput per unit. Many Mtt bum
facilities have 2 or more combustors and have site capacities of greater than
1000 tons per day.
Modular combustors also bum waste without pre-processing,4ut they ere
typically shop fabricated and generally range 1n size fro* I to*4Q04«ns ?er
day of refuse throughput. One of the most cannon types of nodular unbutton
1n the starved air or controlled air type, Incorporating two eotfcustlon
chambers. Air 1s supplied to the primary chamber at substo1ch1«MtHc
levels. The Incomplete combustion products pass Into the secondary
combustion chamber where excess air Is added and combustion 1s otfeplited.
Another type of modular combust or, functionally sleillar to larger, mess bum
units, uses excess air 1n the primary chamber; no additional e1r 1s -added 1n
the secondary chamber. The third Mjor type burns rtfuse-deHftd Awl
(RDF). This type of combustor burns processed waste which My viry from
shredded waste to finely divided fuel suitable for co-firing «1*Jt pfllveMted
coal.
The distribution of the existing U.S. Mite combustion oeM«1ty wong
the three types 1s shown 1n Figure 3. As shown» Mai bum fac11U1«a have
the largest share of U.S. capacity, $1 percent of the total, tiff facilities
represent 23 percent of tht total capacity, and Modular ftcHMttft *ocount
for g percent. Although nodular facilities represent a tMll fflicMtn of the
total U.S. capacity, the number of facilities equipped with a*6fltr
facilities Is greater than the number of combustion fadlUlM ^ulppod with
mass burn units (56 modular facilities compared to 41 MM
There are ten RDF facilities 1n operation.
-------
1 387-0"
03: 33
EPA HDQTPS UJH3H DC
1408227
MlMlumlMH)
Tottl OMl0n
4MOP (•*•»« *ty
Flgurt 3. Distribution of Ixiitlng InittiM MunUJMl Wutt
Combustion Capaolty by O^tlflft Typf
Fiourt 4. Distribution of Flanntd Muntelptl Wtitt Oombuttion
-------
13S7-0?-.;
03: 34
EPS HDQTRS UftSH DC
1408027
Figure 4 shows the txptcttd distribution of design types
facilities the EPA his knowledge of. Mm burn facilities tre ea^eotftd to
continue to dominate with 59 percent of the U.S. design capacity* RDF
facilities are expected to account for 20 percent, and deilgn capacity for
nodular facflltlts 1$ expected to account for S percent.
EMISSIONS AND THEIR CONTROL
Environmental concerns have been raised about both solid fttfdwt and
pollutants emitted to the air from nunldpal watte cwebustcrs, NrMculer
concern has been raised concerning the presence of chlorinated
d1benzo-p-d1ox1ns (COO) and chlorinated d1binzofura.ni (CDF) 1n e*1se4ont to
the air and solid residues. »
The EPA 1s currently working to detenlne the most envlronawnUlly
acceptable methods for disposal of nunldpal waste combuitor Mild residues.
The Agency's findings concerning residue disposal will be pub11ffc*dm*en that
work 1s complete. The remainder of this Report to Congren and tt>e
accompanying technical reports focus on environmental effects of*e*rtes1oiu to
the air from municipal waste combustors.
As part of the Integrated study, EPA attested to collect *M «va1lible
data on emissions fro» anuilclpal wastt combustors. Fro* this ddN4fce GM
established an missions data base of almost 10 facilities frMMttft
emissions had been measured 1n documented tests. CoapaMeon of^*ha-data from
different tests Is difficult because the facilities vary w1d«ly In-design and
operating conditions* the tests were conducttd with different «4fe4t1vei and
different protocols, and the level of detail of the reported dftl wH«t%
Further, the specific sampling and analysis methods were not ttfi-sa** for all
tests. These differences sake 1t difficult not only to nake o«afiM«oni
among the combustors tested, but also to draw conclusions about^hfentire
population of combustors. Nevertheless, this study has used
the extent possible to evaluate nunlclpal wastt cenbustlon
-------
133"-0~-31 03:35 EPAHDGTRSWPSHDC 1408327 03
Pollutant* of Interest emitted from municipal waste combuitori Include
metals, add gases (primarily HC1), organic* {Including COD and COF), and, fn
some locelHies, MOX, is will. Ttblt 1 contain! t wmury of enllilons
quantities Matured fro* municipal waste combustors.
For municipal waste combustors controlling Minions Involves
controlling missions of a whole lilt of pollutants. Moreover, implication
of control technology for ont pollutant or class of pollutants maj effect
control of other pollutants. Devising a control strategy, then, Involves
consideration of control techniques for each of the classes of pollutants
present but also requires consideration of the effects of a selected control
technique on the entire 11st.
Options for control Include optimization for minimizing organic
emissions; scrubbing for add gas control; flue gat cooling for condensation
of metals and organlcs; high efficiency partIculate matter collection; and *
NOX control where necessary. A control approach designed to Incorporate all
of these processes., thereby Minimizing Million! of the whole lift of
pollutants would be:
optimization of the combustion process,
alkaline scrubbing combined with ESPt or fabric f1lters,o.pa.rated.
at temperatures conducive to promoting condensation, and,
flue gas treatment for NOX control, If necessary.
Some of the newest facilities In Europe and in the United Statei hjvt
Incorporated the first two parts of this approach, and at least oqa facility
In California has Incorporated all three parti. The alkaline tctyj|bej* bejog
chosen for most of the new facilities are dry scrubbers,
With a goal of optimizing combustion in mind the ERA tfjvejftfjd. 4 ttt of
combustion strategy elements termed 'good combustion practical,•
1n Table 2. Also shown art preliminary spedfleetfont for each
elements. Even though these good combustion practices are
have not been verified 1n field tests, they have been Included be^tusj It 1s
Important for permit writers and those applying for permits to bf ^ware of
the conditions that promote achievement of complete combustion.
x1
-------
1387-07-01
09:35
EPA HDQTRS UJPSH DC
1438027
09
I
I
i
I
\
*
I
8
s
i
i
i
i
i
j
-------
13-37-07-01
09: 36
EPP HDQTRS WASH DC
408027
10
§*
si
i -
5 S
i
J
i
•j
1
7
*
£
*
i
.
I
Mi
i
I
* 5J
1
t
i
I
i
ii
i i
s i
1
t
I
HI
I lit I
1
fc
Jil
'*« . - -.
aJJ! HH«'ii»L i
a{ * 111|« iJ |}j
;! •!§ ji 11 : «i lu *
(
(
\
i
'
\\
I
i
«M,!
Jill
It
f
I
I
I
t
i
t
* 8
i
fl
J, Ul
St«!
I! t 14 !
**
» - •
: til i
Li
i1 i*
5i •*
I
-------
1387-07-31 09:37 EPAHDQTRSUIflSHDC 1408027 11
Recent test data obtained from a new municipal waste coabufter 1n TuUi
show that low concentrations of organlcs My be achieved by optimizing
combustion conditions. Moreover, Missions testing his recently begun on
municipal waste combustors equipped with dry scrubber! combined with
partlculate utter collection devices. Recently collected test data show
generally high removal efficiencies for til pollutants except wfrcury, and
even for mercury one stt of pilot pltnt ttst data show higher control
efficiencies may be possible with sufficient cooling.
HEALTH RISK ANALYSIS
The EPA performed a health rlik analysis of two control scenarios. One,
the baseline scenario, approximates the status quo 1n control ttfllmology, t
mostly partlculate matter emission control. Thi second reflects uniform
application of dry alkaline scrubbing combined with partlculate tatter
collection devices. Estimated health risk under these two control scenarios
was generated for both the existing population of combustors and for thost
facilities planned for construction.
Two different expressions of health risk were generated: aggregate
annual Incidence and maximum Individual risk. Aggregate annual Incidence
values Include the total number of cancer cases per year predicted fey the
models In populations living within SO kilometers of ill the muni t1 sal waste
combustors In the United States. Maximum Individual risk valueVera the
model's estimates of the probability that a person exposed to tin highest
modeled concentration of pollutants from a municipal waste combttftof will
develop cancer due to continuous exposure over a 70-year lifetime.
The EPA's risk analysis estimated direct Inhalation cancer ftske
associated with maintaining the status quo 1n control tecfmolo^fof the
existing facilities and those projected for the near future. Nm Ot the
estimated cancer risk 1s attributable to chlorinated d1bertzo-paff*d1ttc1ns
(COD) and chlorinated dlbenzofurans (CDF). Thert remain basic qiesttfbfls
concerning the mechanism of carclnogenesls for these and relat*t$bot|pun4t.
The models used to estimate the plausible, upper bound carclmmkifottffcy
of compounds such as CDD/CDF, Implicitly assume that the lubSttMl fttl '
-------
136 7-0 7-01 09:33 EPftHDQTRSUfiSHDC 1408027 12
directly to Initiate cancer. If, however, COD/CDF acts as a pnopotlnj agent,
as some scientists believe, to amplify the carcinogenic response of other
direct acting carcinogens, the present model may not be appropriate. A
change of this nature 1n the assumption on which tme cancer potency estimate
Is based could lead to a reduction 1n this estimate.
The ranges presented below reflect uncertainties regarding the relative
toxldty of structurally related compounds, and tht ability to accurately
measure compounds at trace levels. These estimates also reflect,aiiwptIons
Including a conservative extrapolation of the results of ep Ideological and
animal studies, mathematical modeling of pollutant dispersion, constant
emission rates based on those at tested facilities, and cons tent, ex#uure of
persons to pollutants for 70 years.
The estimates of annual Incidence aggregated over tht United S|Atts and
for all pollutants modeled are 3 to 38 cases per year for tht Misting
combustors and 2-22 for those projected. Estimated maximum Individual risks
(As noted above, these are for the greatest potential txposurt.) range from
1/1000 to 1/10,000 for existing facilities and from 1/10,000 to J/100,000 for
those projected to be built 1n the next few years. Uniform application of
dry scrubbers combined with high efficiency partlculate collection devices
would be expected to reduce annual Incidence to 0.2 to 3 cases for existing
sources, and 0.3 to 1 for those projected. Similarly, such c
reduce maximum Individual risks to 1/10,000 to 1/100,000 for
facilities and 1/100,000 to 1/1,000,000 for projected facilities^
When the risk estimates are disaggregated by design type, t^e
contributed by mass burn technology used In existing facilities ajjm^tes thi
risk contributed by the major design types. However, the risk
contributed by RDF technology dominates 1n tht projected
A preliminary analysis was performed to determine whether
exposure routes due to surface deposition of pollutants from mj*ftj£f(U)J wajtt
combustors could contribute significantly to total exposure duj Jp ^mlfiljpa]
waste combustors. The analysis was designed to tvaluate tht cWtnajJM pf
parameters that would result 1n the maximum txposurt that was s($l JflLtMp
the realm of plausibility. Results showed that for mtrcury end Jjaji Indirect
exposure may be a significant part of tht total txppsyre due
-------
1937-07-0! 09=39 EPfl HDQTR3 __ m ^^ ^
waste. However, no such Indications were teen for nlefcel, chr«»4«, «r
formaldehyde. Also, the ftodellng results shotted that Indirect ettffoturo to
environmentally persistent organic compounds eay be conparable
Inhalation route of exposure. Analysis of Indirect exposure at a fOMlble
source of health risk 1s continuing.
COST OF CONTROL
The incremental cost of adding dry scrubbing to partleulataNfett*r
control (considered representative of the status quo) at awnlolptl mitt
combustors Is $4 to $9 per ton of garbage consulted at «ass biimmnlU aM 14
•
to $5 per ton for RDF-fired coibustors. The IBM Increment fort»duUr
combustors 1s $5 to $12 per ton of garbage coabusttd. However,
modular units are equipped with no flue gas treaUent devices, eovtht eost
for those units would be higher, about $7 to 111 per ion.
------- An error occurred while trying to OCR this image.
------- An error occurred while trying to OCR this image.
-------
•o
0V
3
O
.
P UJ
co
O
o
UJ
h-
CD gj
Q «
S
$
UO
X
i
§
£
S
o
S-
•c
> at «
^ ^ I i§i
— QC -• O
« — O «
tf UJ PH
a j[ a ac ac
> M X uZ 1C 5
K UJ ** O O H"
< o O *- «
H. So «» =
y) M uy . M
X I — S uj O
» » _i j !fe >•
wj S2 o o x
SS5:S±
iiss*
Q
5
S u> at
*^ u. (/I *rt
> >S V. U. U. ^ -^
iiiif f
I
CL
u
o
s
O UJ
. s
» UJ
§ i 4
-» *
9l o m * < 8 <
uj^oSS-j 2
-------
a.
>-
o
on
u~
o
o
00
o
o ,
o *|i
-* o -- i
^0 *• t '
cu
i
CO
GO
S
i
8
'°'°
fc * ft
> w> 4 *» *
.'555!
S 38
£ SS
* z>~ *
5 5SI±
« •
E I
S
!5!
S
SI
UJ
5
4
-------
•D
OJ
c
o
C5
00
UJ
a
o
Q£
O
oo
UJ
Sjtfftc
u
s
si §
_j
a.
3
S
I I
— (M
Iklfc'i'itl'il" Ifc^^tfc >«N.'v'X^'».>»'x'^>»>»^l*.lfc^'v^-» ^.N«^(fclfc>i!;^>.ifc'x
Sifffffff22328ifi2*ffixff!ff!2!iiifi!2fffiiiif!!if
*
!
js s i::
i — ^ « ^ ;
;- a ri!
i
i
i
i
I
I
:S"
ift i
»Ol -iCLXwi
; ("45;
sis
-------
•o
0»
o
C_J
CM
S
2351 2 SSI
K K K K Z K 2 £ & to 5» 2 2 K Si
2 2 2
U IBM Z £ K
5 5 5 oJ
222222s
-x
o.
>-
H-
tr
o «£ a !? „. * i i
u>
~8
u>
M^ r>» i^ r^ i
Z V « • _
_ _ Oi»»» »O>0|>Oi O>«^O>O> O>9>ON»**«|<«>
cr
jj«
r- 8S°ooSgoSog°
t m «««4«4 *«mMrf.«(si
tt et^s ?
o °
(/I £
UJ 5 $
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^u,^^^^^^^^^^^^^^^,
*•
- p
a. S-i
2 55
— « H-
. = -*
5 5
§ «
IS
its
O O :
u _ S;
li'ii
$Ii£|'
*isl?
gv> • » f « 28 J
5t»-^oaw**
aomxwZtXoz
-------
3
C
C
O
O
o
C/l
CO
a
UJ
a:
LU
a
O£
o
I-
rt 5
o
UJ
cvi
i
CD
8 — — —
XXX
tec ^
«*
•'S
5
s
^cccc tc t cc
x«xx
8*88
«O — ••••'
---
8 — <
8 ~ — — — « — — * — *<» — ~« w» < « trt
ssg
?!
l22il
goe
o»
«« m m m
P
«A Z
5' ** ^ Q
• >• a * — s
>. 5 uu P X < O
c»oi-»a-o
* ^ Q w I
u < A IM C at
3 » _ 3 -< UJ
O _ * ^ u i~
j-'aKLugis
< a: < < a £ —
Is2l=£
^M
$?t
Ii
-I?
^5
tXR
i*
52
M« ^
** 5
^sli
u O ** **
w "> o Z
gj uj O O :
s5«5i
-------
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, II 60604-3590
-------
*
3
UJ
o.
o
>-
o
UJ
o
o
CM
I
CD
CD
tis
« P-
II
*s
S
g
55J5 SS^
—I.J-J^-J^-V'^.J.J*- —
— — — ^.—t-l—t-.- — «!'
ooo
k/ioO
I m
S
*«
2 ft
»» V.
is
=
I8
§s
2«H£5i
SS = !
Jgf:
VI *rt i
of
S j
S55
***
S
I
a.
I
a.
9 3
------- |