United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-453/R-94-070a
September 1994
Air
OFF-SITE WASTE
AND RECOVERY
OPERATIONS:
BACKGROUND
INFORMATION FOR
PROPOSED STANDARDS
DRAFT
EIS
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EPA-453/R-94-070a
Off-Site Waste and Recovery Operations:
Background Information
Document for
Proposed Standards
Emission Standards Division
Office of Air Quality Planning and Standards
United States Environmental Protection Agency
Research Triangle Park, North Carolina 27711
September 8, 1994
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Disclaimer
This final report has been reviewed by the Emissions Standards
Division, Office of Air Quality Planning and Standards, U.S.
Environmental Protection Agency, and approved for publication.
Mention of trade names of commercial products does not
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, (919) 5411-2777, or they
may be ordered from National technical Information Services,
5285 Port Royal Road, Springfield, Virginia 22161, (703)
487-4650.
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ENVIRONMENTAL PROTECTION AGENCY
Background Information for Proposed Standards
Off-Site Waste Operations
Prepared by:
Bruce C. Jordan (Date)
Director, Emission Standards
Division
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
1. The proposed standards would regulate organic hazardous
air pollutants (HAP) emitted from off-site waste
operations. Section 112 of the Clean Air Act requires the
EPA to regulate HAP emissions from sources listed
pursuant to section 112(c)
2. Copies of this document have been sent to the following
Federal Departments: Labor, Health and Human Services,
Defense, Office of Management and Budget, Transportation,
Agriculture, Commerce, Interior, and Energy; the National
Science Foundation; and the Council of Environmental
Quality. Copies have also been sent to member of the
State and Territorial Air Pollution Program
Administrators; the Association of Local Air Pollution
Control Officials; EPA Regional Administrators; and other
interested parties.
3. The comment period for this document is 60 days from the
date of publication of the proposed standards in the
Federal Register. Ms. Jolynn Collins may be contacted at
919-541-*5671 regarding the date of the comment period.
4. For additional information contact:
Mr. Eric L. Crump
Chemical and Petroleum Branch (MD-13)
US Environmental Protection Agency
Research Triangle Park, NC 27711
Telephone: 919-541-5032
5. Copies of this document may be obtained from:
U.S. EPA Library (MD-35)
Research Triangle Park, NC 27711
Telephone: 919-541-2777
National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
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CONTENTS
Section Page
TABLES vi
1.0 INTRODUCTION 1-1
1 . 1 BACKGROUND 1-1
1.2 OFF-SITE WASTE OPERATIONS NESHAP 1-1
1.3 PURPOSE OF THIS DOCUMENT 1-2
2.0 SOURCE CATEGORY DESCRIPTION 2-1
2.1 GENERAL SCOPE OF CONTROL OPTION IMPACT ANALYSIS 2-1
2.1.1 Definition of "Waste" 2-1
2.1.2 Definition of "Off-site Waste
Operations" 2-2
2.2 OFF-SITE WASTE OPERATIONS SELECTED FOR ANALYSIS 2-3
2.2.1 Hazardous Waste TSDF 2-3
Industrial Waste Landfills 2-4
Industrial Wastewater Treatment
Facilities 2-5
4 Recycled Used Oil Management Facilities 2-5
5 Oil and Gas E&P Waste Management
Facilities 2-6
6 Other Facilities 2-7
2.3 SOURCE CATEGORY ORGANIC HAP EMISSION ESTIMATES 2-8
2.3.1 Individual Facility Emission Estimates . 2-8
2.3.1.1 Hazardous Waste TSDF 2-8
2.3.1.2 Industrial Waste Landfills . . . 2-9
2.3.1.3 Industrial Wastewater Treatment
Facilities 2-10
2.3.1.4 Recycled Used Oil Management
Facilities 2-10
2.3.1.5 Oil and Gas E&P Waste Management
Facilities 2-11
2.3.1.6 Other Facilities 2-12
2.3.2 Summary of Nationwide Organic HAP
Emission Estimates 2-13
2.4 REFERENCES 2-15
3.0 SOURCE CATEGORY EMISSION POINTS 3-1
3.1 WASTE MANAGEMENT UNITS 3-1
3.1.1 Tanks 3-1
3.1.2 Containers 3-3
3.1.3 Surface Impoundments 3-4
3.1.4 Landfills 3-5
3.1.5 Land Treatment Units 3-5
3.1.6 Wastepiles 3-6
3.1.7 Other Treatment Processes 3-6
3.1.8 Ancillary Equipment 3-7
iii
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CONTENTS
4.0
5.0
6.0
7.0
.on
3.2
SOURCE CATEGORY EMISSION POINTS
CONTROL TECHNOLOGIES
4.1
4.2
4.3
WASTE PRETREATMENT
ADD-ON ORGANIC EMISSION CONTROLS
4.2.1 Tanks
4.2.2 Containers
4.2.3 Land Disposal Units
4.2.4 Process Vents
4.2.5 Equipment Leaks
REFERENCES
ORGANIC EMISSION IMPACT ESTIMATES
5.1
5.2
5.3
5.4
SELECTION OF CONTROL OPTIONS
5.1.1 Tank Control Options
5.1.2 Containers Control Options
5.1.3 Land Disposal Unit Control Options . . .
5.1.4 Process Vent Control Options
5.1.5 Equipment Leak Control Options
BASELINE FOR CONTROL OPTION COMPARISON ....
ORGANIC EMISSION ESTIMATION METHODOLOGY ....
CONTROL OPTION ORGANIC EMISSION ESTIMATES . . .
OTHER ENVIRONMENTAL AND ENERGY IMPACTS ESTIMATES . .
6.1
6.2
6.3
IDENTIFICATION OF OTHER CONTROL OPTION IMPACTS
6.1.1 Tank Control Options
6.1.2 Container Control Options
6.1.3 Land Disposal Units Control Option . . .
6.1.4 Process Vent Control Option
6.1.5 Equipment Leak Control Options
SUMMARY OF IMPACT ESTIMATION METHODOLOGY . . .
IMPACT ESTIMATES
6.3.1 Secondary Air Emission Impacts
6.3.2 Water Impacts
6.3.3 Solid Waste Impacts
6.3.4 Energy Impacts
ENHANCED MONITORING
7.1
7.2
7.3
7.4
7.5
7.6
ENHANCED MONITORING LEVELS
ENHANCED MONITORING FOR TANKS
ENHANCED MONITORING FOR CONTAINERS
ENHANCED MONITORING FOR LAND DISPOSAL UNITS . .
ENHANCED MONITORING FOR PROCESS VENTS
ENHANCED MONITORING FOR EQUIPMENT LEAKS ....
Paae
3-7
4-1
4-2
4-3
4-3
4-5
4-5
4-7
4-7
4-8
5-1
5-1
5-2
5-3
5-3
5-4
5-4
5-5
5-5
5-7
6-1
6-1
6-2
6-3
6-3
6-3
6-3
6-4
6-6
6-6
6-6
6-6
6-10
7-1
7-1
7-2
7-6
7-6
7-7
7-7
IV
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CONTENTS
Section Page
8.0 CONTROL OPTION COST ESTIMATES 8-1
8.1 CONTROL OPTION COSTS 8-1
8.2 COST ESTIMATION METHODOLOGY 8-2
8.3 CONTROL OPTION COST ESTIMATES 8-4
8.4 REFERENCES 8-4
APPENDIX A A-l
APPENDIX B B-l
APPENDIX C C-l
APPENDIX D D-l
APPENDIX E E-l
v
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TABLES
Table Page
2-1. ESTIMATED NATIONWIDE ORGANIC HAP EMISSIONS
FOR OFF-SITE WASTE OPERATIONS 2-14
5-1. SUMMARY OF BASELINE ASSUMPTIONS
USED FOR ORGANIC EMISSION ESTIMATES 5-9
5-2. SUMMARY OF CONTROL OPTION ASSUMPTIONS
USED FOR ORGANIC EMISSION ESTIMATES 5-11
5-3. ORGANIC EMISSION ESTIMATES FOR BASELINE 5-12
5-4. ORGANIC EMISSION ESTIMATES FOR CONTROL OPTIONS . . 5-13
6-1. SUMMARY OF ASSUMPTIONS USED FOR CONTROL OPTION
OTHER ENVIRONMENTAL AND ENERGY IMPACT ESTIMATES . . 6-5
6-2. ESTIMATED RANGE OF SECONDARY AIR EMISSIONS .... 6-7
6-3. ESTIMATED RANGE OF WATER IMPACTS 6-8
6-4. ESTIMATED RANGE OF SOLID WASTE IMPACTS 6-9
6-5. ESTIMATED RANGE OF ENERGY IMPACTS 6-10
8-1. ESTIMATED TOTAL CAPITAL INVESTMENT (TCI) FOR
CONTROL OPTIONS 8-5
8-2. ESTIMATED ANNUAL OPERATING COST (AOC) FOR CONTROL
OPTIONS 8-6
8-3. ESTIMATED MONITORING, INSPECTION, REPORTING, AND
RECORDKEEPING (MIRR) COSTS 8-7
8-4. ESTIMATED TOTAL ANNUAL COST (TAC) FOR CONTROL
OPTIONS 8-8
VI
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1.0 INTRODUCTION
1.1 BACKGROUND
Title III of the 1990 Amendments to the Clean Air Act
(CAA) substantially revised section 112 of the Act regarding
the development of National Emission Standards for Hazardous
Air Pollutants (NESHAP). To implement the congressional
directives of Title III, the U.S. Environmental Protection
Agency (EPA) has initiated a program to develop NESHAP for
certain categories of stationary air emission sources that
emit one or more of the hazardous air pollutants (HAP) listed
in section 112 (b) of the CAA.
1.2 OFF-SITE WASTE OPERATIONS NESHAP
Under section 112(c) of the CAA, the EPA is required to
develop and publish a list of all source categories emitting
HAP. The EPA's initial list was published in the Federal
Register on July 16, 1992 (57 FR 31576). On this initial list
of HAP emission source categories, the EPA included one source
category which the Agency intended to address HAP emissions
from those waste management and materials recovery operations
that are not included in another separate NESHAP source
category or are being addressed by other EPA regulatory
actions. This source category was originally titled on the
initial source category list as "solid waste treatment,
storage, and disposal facilities."
Since the initial source category list was published in
the Federal Register, the EPA decided to change the title of
this NESHAP source category to "off-site waste operations."
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The EPA decided that this change is appropriate for two
reasons: (1) to avoid confusion with the terms "solid waste"
and "treatment, storage, and disposal facilities" which have
specific meanings within the context of statutory and
regulatory requirements in existing rules established by the
EPA under authority of the Resource Conservation and Recovery
Act (RCRA); and (2) to better distinguish the types of air
emission sources addressed by this NESHAP source category from
other NESHAP source categories.
The EPA published an advance notice of proposed
rulemaking (ANPR) in the Federal Register on December 20, 1993
(58 FR 66336) announcing EPA's intent to develop a NESHAP for
off-site waste operation source category. In the ANPR, the
EPA noted that it is the Agency's intent to regulate under
this NESHAP only organic chemicals which have been designated
as HAP under section 112(b) of the CAA. These organic
chemicals are referred to collectively hereafter in this
document as "organic HAP."
1.3 PURPOSE OF THIS DOCUMENT
In developing NESHAP, the EPA selects and evaluates
different strategies for reducing air emissions from the
source category. Each strategy is referred to as a "control
option." This background information document (BID) presents
information and methods used by the EPA for a control option
impact analysis in support of developing a NESHAP for the
off-site waste operations source category.
Chapter 2 identifies the types of waste materials and
off-site waste management facilities addressed by the control
option analysis. The types of HAP emission points at the
off-site waste operations selected for the control option
impact analysis are described in Chapter 3. Chapter 4
describes the types of air emission controls used to develop
control options. Chapter 5 presents a comparison of the
organic HAP and volatile organic compound (VOC) emission
1-2
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reduction levels for the control options. Estimates of other
environmental and energy impacts associated with implementing
these control options are presented in Chapter 6. Chapter 7
discusses the application of enhanced monitoring to the
control technologies selected for the control options.
Estimates of capital and annual costs to implement the control
options are presented in Chapter 8. Appendix A presents a
chronology of the NESHAP development for the off-site waste
operations source category. Additional details of the control
option impacts estimation methods are presented in
Appendices B through E.
1-3
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2.0 SOURCE CATEGORY DESCRIPTION
This chapter presents the description of the off-site
waste operations source category as used for the control
option impact analysis. Section 2.1 identifies the general
scope of the off-site waste operations source category
addressed by the control option impact analysis. Section 2.2
describes the types of off-site waste operations selected for
this analysis. Section 2.3 presents estimates of organic HAP
emissions for the off-site waste operations source category.
2.1 GENERAL SCOPE OF CONTROL OPTION IMPACT ANALYSIS
2.1.1 Definition of "Waste"
For the purpose of performing a control option analysis
for the off-site waste operations source category, the EPA
defined "waste" to be any material generated from industrial,
commercial, mining, or agricultural operations or from
community activities that is recycled, reprocessed, reused,
discarded, or is being accumulated, stored, or physically,
chemically, thermally, or biologically treated prior to being
discarded, recycled, or discharged. This definition is
consistent with the definition of waste used by the EPA for
other air rules promulgated under authority of the CAA. Under
this definition of waste, secondary materials such as used,
surplus, and scrap materials that are recycled or reprocessed
to recover reusable materials or to create new products are
considered by the EPA to be wastes for the purposes of this
analysis.
The waste definition used for the control option analysis
defines the types of materials considered to be a "waste" in a
broader context than the EPA has historically used for the
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Agency's solid waste management rules established under the
authority of the Resource Conservation and Recovery Act
(RCRA). The waste data used for the off-site waste operations
control option analysis include wastes defined as hazardous
waste under RCRA subtitle C and other nonhazardous solid
wastes as defined under RCRA subtitle D. In addition,
materials excluded from the RCRA definitions of waste under
subtitles C and D (e.g., recovered materials recycled back to
a process and used oil reprocessed for sale as a fuel) were
included as wastes for the off-site waste operations control
option analysis.
2.1.2 Definition of "Off-Site Waste Operations"
For the control option analysis, the EPA defined
"off-site waste operations" to be operations conducted to
manage wastes containing HAP that are received from other
facilities. In other words, the wastes have been generated
off-site at a separate location and, then, shipped or
transferred to the facility for subsequent management. Waste
management operations considered to be "off-site waste
operations" for this analysis include waste storage,
treatment, and disposal operations as well as waste recycling,
recovery, and reprocessing operations.
The EPA is addressing HAP emissions from certain types of
waste management operations by establishing separate NESHAP or
other regulatory actions. Consequently, wastes managed in the
following operations are not included in control option
analysis for the off-site waste operations source category:
(1) operations that exclusively managed waste generated at the
off-site waste operations facility site (i.e., waste generated
on-site); (2) municipal solid waste (MSW) landfill units;
(3) incinerators used to burn waste; (4) boilers or furnaces
used to burn waste to produce energy; (5) operations located
at a publicly-owned treatment works (POTW); and (6) operations
used exclusively to manage waste that has been received from
remediation activities to cleanup RCRA hazardous wastes.
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2.2 OFF-SITE WASTE OPERATIONS SELECTED FOR ANALYSIS
The off-site waste operations considered for inclusion in
the control option impact analysis were classified into six
types of off-site waste operations. These waste operation
types are labelled:
! Hazardous waste treatment,
storage, and disposal facilities
(TSDF)
! Industrial waste landfills
! Industrial wastewater treatment
facilities
! Recycled used oil management
facilities
! Oil and gas exploration and
production (E&P) waste
management facilities
! Other facilities
A brief description of each of these six types of
off-site waste operations is presented in the following
subsections.
2.2.1 Hazardous Waste TSDF
The EPA has established rules under the authority of RCRA
regulating the management of wastes determined to be hazardous
wastes (40 CFR Parts 260 through 271). These rules establish
a permit system for owners and operators of facilities where
operations are conducted to treat, store, and dispose of a
RCRA hazardous waste. A facility requiring a RCRA permit is
referred to under the RCRA rules as a hazardous waste
treatment, storage, and disposal facility (TSDF). A RCRA
hazardous waste may be generated at the same site where a TSDF
is located, or may be generated at one site and then
transported to a TSDF at a separate location.
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Waste materials not designated as RCRA hazardous wastes
are also managed at TSDF. Although a waste material may not
specifically be designated as a RCRA hazardous waste, this
waste material can still contain significant quantities of
organic constituents listed as HAP under the CAA.
The EPA has conducted nationwide surveys to collect
information regarding hazardous waste management practices.1'2
Data from the most recent surveys indicates that approximately
2,300 TSDFs were operating in the United States in 1986. At
710 of these TSDF, owners and operators reported managing RCRA
hazardous wastes that are generated off-site. The EPA survey
data indicates that approximately 240 of these 710 TSDFs also
managed nonhazardous waste materials.
2.2.2 Industrial Waste Landfills
Many landfill facilities throughout the Unites States are
dedicated to the disposal of solid waste materials other than
those defined as RCRA hazardous wastes. Landfills accepting
household wastes are defined under RCRA rules to be municipal
solid waste (MSW) landfill units. No MSW landfill units are
included in the off-site waste operations source category
because these units are listed as a separate NESHAP source
category. However, some other landfills are operated by waste
management companies that will accept only industrial
nonhazardous waste materials (i.e., these landfills do not
accept any household wastes nor RCRA hazardous wastes).
The EPA estimates that there are approximately
10 industrial landfills currently operating nationwide that
accept only nonhazardous industrial process waste materials.
These industrial nonhazardous waste landfills receive a wide
range of waste material, some of which may contain organic
HAP. Furthermore, the EPA estimates that nationwide there are
approximately 1,800 construction and demolition debris
landfills that could be subject to a NESHAP for off-site waste
operations. However, the EPA does not expect the construction
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and demolition debris landfills to contain significant amounts
of organic HAP.3
2.2.3 Industrial Wastewater Treatment Facilities
Analogous to landfills, many waste treatment facilities
are operated by municipal governments and private companies
throughout the Unites States for the treatment of wastewaters
other than those defined to be RCRA hazardous wastes.
Wastewater treatment facilities accepting residential and
commercial wastewaters are considered to be publicly owned
treatment works (POTW). No POTW are included in the off-site
waste operations source category because POTW are listed as a
separate NESHAP source category. In addition to POTW, some
privately-owned wastewater treatment facilities process
nonhazardous wastewaters received from off-site sources.
A nationwide survey was conducted by the EPA of
wastewater treatment facilities operating in 1989.4 Using
these survey data, a data base excluding POTW was created.
Many of the facilities listed in this wastewater treatment
facility data base are also listed in the hazardous waste TSDF
data base described in Section 2.2.1 of this chapter.
However, the data base also lists an additional 15 wastewater
treatment facilities were operating nationwide which were
neither a POTW nor a hazardous waste TSDF but do process
wastewaters received from off-site sources that potentially
could generate wastewaters containing organic HAP.
2.2.4 Recycled Used Oil Management Facilities
Used oils from motor vehicles and other sources can
contain individual constituents listed as HAP under
section 112(b) of the CAA. While the management of used oils
which are recycled is regulated by separate rules promulgated
by the EPA under section 3014 of RCRA, these rules do not
specifically establish air standards for used oil management
facilities.
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The EPA gathered information regarding recycled used oil
management practices in the United States for the development
of the RCRA standards.5 This information indicates that
approximately 2,800 million liters (750 million gallons) of
used oil enters the commercial used oil recycling market each
year. Approximately three-fourths of this recycled used oil
is sent to facilities categorized by EPA as "used oil
processors." Used oil processors typically collect used motor
oil and industrial lubricating oils. These oils are processed
to remove water and sediments from the oils. The processors
than sell the oil as a fuel for burning primarily in boilers,
furnaces, and space heaters. There were 182 used oil
processing facilities operating in the United States in 1991.
The remainder of the recycled used oil is sent to facilities
categorized as "used oil re-refiners." At these facilities
the used oil is processed into base lube oil stocks and other
products. In 1991, there were 4 used oil re-refining
facilities operating in the United States. Several companies
have expressed interest in expanding used oil re-refining
capacity in the United States.
2.2.5 Oil and Gas E&P Waste Management Facilities
There are a variety of waste materials generated during
oil and gas exploration and production (E&P). The majority of
these waste materials are managed on-site at the production
site. However, some E&P waste materials generated at
production sites are subsequently transferred to off-site
facilities for treatment or disposal. The off-site waste
management operations that typically process E&P waste
materials can be classified into three different types of
operations. These are: crude oil reclamation; land
treatment/road spreading; and produced water disposal.
The EPA gathered information regarding E&P waste
management practices from EPA conducted site visits and
existing industry sponsored surveys.6 From this information,
the nationwide total quantity of E&P waste materials managed
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at off-site facilities was estimated to be approximately
930,000 megagrams per year (Mg/yr) (1 million tons/yr).
Approximately 70 percent of the E&P waste materials are
contaminated waters that are managed in small produced water
disposal operations by deep-well injection. Nationwide, there
are approximately 16 off-site crude oil reclaimers managing
approximately 100,000 Mg/yr (115,000 tons/yr) of E&P waste
materials. These waste materials consist mostly of tank
bottoms from crude oil storage tanks or produced water storage
tanks. Approximately 135,000 Mg/yr (150,000 tons/yr) of E&P
waste sludges are managed in off-site land treatment or road
spreading operations.
2.2.6 Other Facilities
In addition to the facilities that are in business to
manage waste materials received from waste generators, some
facilities which provide waste management support services may
indirectly receive waste materials which are potential organic
HAP emission sources. Two types of such facilities have been
identified by the EPA: (1) facilities where empty drums
previously used to hold waste materials containing organics
are cleaned and reconditioned for reuse; and (2) truck
terminal facilities at which tank trucks used for chemical
waste transport are cleaned and rinsed prior to being used to
transport a new load. At both of these types of facilities,
organic HAP emissions can occur from the wastewater treatment
system operated at the facility to treat the waste materials
and cleaning solutions drained from drums or truck tanks as a
result of the container cleaning operation. Wastewater
treatment operations are expected to be the primary source of
organic HAP emissions at these types of facility.
The need for and frequency of cleaning a drum and tank
truck depends on the type of service in which the container is
used. If drums and tank trucks are reused for the same type
of product or waste materials (i.e., dedicated service), the
containers do not need to be cleaned between each use. Only
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when a drum or tank truck is used for different types of
products or waste materials (i.e, nondedicated service) is
there frequent cleaning of the containers. Of the
approximately 45 million drums used annually in the United
States, about 5.6 million are estimated to be in nondedicated
service.7 Approximately 20,000 tank trucks of the nationwide
total of 91,000 are estimated to be in nondedicated service.8
2.3 SOURCE CATEGORY ORGANIC HAP EMISSION ESTIMATES
Under section 112(a) of the CAA, a "major source" is
defined as any stationary source or group of stationary
sources that emits or has the potential to emit 10 tons per
year or more of any single HAP constituent or 25 tons per year
or more of any combination of HAP constituents. An analysis
was performed to determine if facilities in each of the off-
site waste operation types described in Section 2.2 of this
chapter are likely to have annual organic HAP emissions that
exceed the HAP emission levels defined by the CAA for a "major
source."
2.3.1 Individual Facility Emission Estimates
The EPA estimated organic HAP emissions for each of the
six types of off-site waste operations described in
Section 2.2 of this chapter using the best information
available to the Agency at the time that the estimates were
completed. The type, amount, and date of this information
varies for each of the off-site waste operation types.
2.3.1.1 Hazardous Waste TSDF. Organic HAP emissions for
hazardous waste TSDF were estimated using nationwide survey
data for the year 1986 collected by the EPA and a computer
model developed specifically for this analysis as described in
Appendix B of this BID. Using site-specific information
regarding waste management practices and waste composition,
the computer model estimates organic HAP emissions for
464 individual hazardous waste TSDF locations. The results of
this computer model analysis indicate that 131 of the
464 hazardous waste TSDF are estimated to have either organic
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HAP emissions greater than 10 tons per year of any single
organic HAP constituent or 25 tons per year of all organic HAP
constituents resulting from the management of hazardous waste
materials received from off-site. Also, many of the hazardous
waste TSDFs may have additional organic HAP emissions
resulting from the management of nonhazardous wastes received
from off-site, on-site production operations as well as from
the management of waste materials generated on-site. No
emission estimates were made for the management of the waste
at TSDF reported in the data base to be quantities generated
on-site. Order-of-magnitude nationwide organic HAP emissions
from the management of nonhazardous wastes received by TSDF
from off-site were estimated using nationwide survey data
collected for the year 1986.9 Using compositional data for
hazardous wastes managed in similar types of processes, an
additional 12,000 Mg/yr (13,000 tons/yr) of organic HAP
emissions are estimated nationwide at TSDFs from the
management of nonhazardous wastes received from off-site.
Therefore, the EPA expects many hazardous waste TSDFs have
annual organic HAP emissions that exceed the HAP emission
levels defined by the CAA for a "major source."
2.3.1.2 Industrial Waste Landfills. Order-of-magnitude
nationwide organic emissions from industrial waste landfill
facilities were estimated using data collected by EPA in 1994
from industry representatives and waste management companies.10
Based on this information, the EPA estimates there are
10 industrial waste landfill facilities currently operating in
the United States that accept industrial process waste
materials likely to contain organic HAP from off-site waste
generators. Nationwide organic HAP emissions from these
landfill facilities are estimated to be approximately
1,300 Mg/yr (1,400 ton/yr). If it is assumed that each of the
10 landfill facilities receives approximately the same annual
quantity of waste materials with similar organic HAP
characteristics, the average organic HAP emissions from a
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single landfill facility is estimated to be on the order of
130 Mg/yr (140 tons/yr). The EPA recognizes that in actuality
it is unlikely that this is the case and that some of these
industrial waste landfill facilities may have significantly
lower organic HAP emission levels. However, these estimates
suggest that at least some industrial waste landfill
facilities are likely to have annual organic HAP emissions
that exceed the HAP emission levels defined by the CAA for a
"major source."
2.3.1.3 Industrial Wastewater Treatment Facilities.
Order-of-magnitude nationwide organic emissions from
industrial wastewater treatment facilities were estimated
using survey data collected by the EPA.11 These data contain
limited wastewater composition data and operation information
for the 15 industrial wastewater treatment facilities
identified nationwide that only accept off-site wastewaters
which are not defined to be RC~RA hazardous wastes. Organic
HAP emission estimates for these facilities indicate that 5 of
the 15 facilities have annual organic HAP emissions that
exceed the HAP emission levels defined by the CAA for a "major
source."
2.3.1.4 Recycled Used Oil Management Facilities.
Order-of-magnitude nationwide organic emissions from used oil
management facilities were estimated using nationwide
estimates of annual 1991 used oil quantities and facility
numbers prepared by the EPA in support of the development of
recycled used oil management standards under RCRA
section 3014.12'13 The nationwide organic HAP emissions from
all used oil processing facilities are estimated to be
approximately 43 Mg/yr (47 ton/yr). Considering that a total
of 182 used oil processing facilities were operating in the
United States in 1991, the organic HAP emissions from a single
used oil processing facility are expected to be less than
1 Mg/yr (approximately 1 ton/yr). The nationwide organic HAP
emissions from used oil re-refining facilities are estimated
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to be 44 Mg/year (48 tons/yr). Thus, for the 4 used oil
re-refining facilities, the average organic HAP emissions from
each facility are approximately 11 Mg/yr (12 tons/year).
Based on these emission estimates, it is judged most likely
that used oil processing facilities do not have annual organic
HAP emissions that exceed the HAP emission levels defined by
the CAA for a "major source." However, some used oil
re-refining facilities are likely to have annual organic HAP
emissions greater than 10 ton per year of an individual
organic HAP or more than 25 ton per year of total organic HAP.
2.3.1.5 Oil and Gas E&P Waste Management Facilities. An
order-of-magnitude nationwide organic HAP emission estimate
was developed for E&P waste management operations using the
general information collected by the EPA.14 The total
nationwide organic HAP emissions from all E&P waste materials
are estimated to be 600 Mg/yr (660 tons/yr). Off-site crude
oil reclaimers are estimated to have organic HAP emissions of
approximately 260 Mg/yr (290 tons/yr). An average off-site
crude oil reclaimer is estimated to have total organic HAP
emissions of approximately 16 Mg/yr (18 tons/yr). As such, it
is judged likely that some crude oil reclaiming facilities may
have annual organic HAP emissions that exceed the HAP emission
levels defined by the CAA for a "major source." Based on the
order-of-magnitude emissions estimate for crude oil
reclamation, it is estimated that there are no more than
11 facilities that may have annual organic HAP emissions
greater than 10 ton per year of an individual organic HAP or
more than 25 ton per year of total organic HAP.
The total annual organic HAP emissions estimated for all
produced water disposal operations are only 3.8 Mg/yr
(4.2 tons/yr). As such, produced water disposal operations
are not expected to have annual organic HAP emissions that
exceed the HAP emission levels defined by the CAA for a singe
"major source."
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The total annual organic HAP emissions for land treatment
and road spreading of off-site E&P waste materials are
estimated to by approximately 340 Mg/yr (370 tons/yr). Based
on the number and size of road spreading operations, it is
judged most likely that road spreading operations using off-
site E&P waste materials do not have annual organic HAP
emissions that exceed the HAP emission levels defined by the
CAA for a "major source." However, it is possible that some
larger land treatment operations managing off-site E&P waste
materials may have annual organic HAP emissions that exceed
the HAP emission levels defined by the CAA for a "major
source." Based on the order-of-magnitude emissions estimate
for land treatment/road spreading operations, it is estimated
that there are no more than 15 facilities that may have annual
organic HAP emissions greater than 10 ton per year of an
individual organic HAP or more than 25 ton per year of total
organic HAP.
2.3.1.6 Other Facilities. No nationwide survey data are
available for drum reconditioning facilities or truck tank
cleaning facilities. Therefore, estimates of organic HAP
emissions were made for individual drum reconditioning and
truck tank cleaning facilities considered by the EPA to be
representative of the sizes of these types of waste management
support services facilities.15 Annual organic HAP emissions
for a drum reconditioning facility are estimated to range from
0 to 7 Mg/yr (0 to 6 tons/yr). Annual organic HAP emissions
for a truck tank cleaning facility are estimated to be less
than 1 Mg/yr (less than 1 ton/yr). Based on these estimates,
the EPA does not expect either drum reconditioning or truck
tank cleaning facilities to have annual organic HAP emissions
that exceed the HAP emission levels defined by the CAA for a
"major source."
2.3.2 Summary of Nationwide Organic HAP Emission Estimates
Table 2-1 presents a summary of the estimated nationwide
organic HAP emissions for the off-site waste operations. The
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table shows nationwide organic HAP emissions for the facility
types described in Section 2.2 of this chapter likely to
include individual facilities emitting more than 10 ton per
year of an individual organic HAP or more than 25 ton per year
of total organic HAP. These facility types are: hazardous
waste TSDF; industrial waste landfills; industrial wastewater
treatment facilities; used oil re-refining facilities; crude
oil reclamation facilities; and oil and gas E&P waste land
treatment facilities. For these six off-site waste operations
facility types, the EPA estimates there are currently
nationwide a total of 765 facilities. The EPA estimates that
710 of these off-site waste operation facilities are also
hazardous waste TSDF.
The total nationwide organic HAP emissions from off-site
waste operations at hazardous waste TSDF, industrial waste
landfills, industrial wastewater treatment facilities, used
oil re-refining facilities, crude oil reclamation facilities,
and oil and gas E&P waste land treatment facilities are
estimated to be approximately 51,500 Mg/yr of organic HAP.
The results indicate for the off-site waste operations source
category approximately 90 percent of the total nationwide
organic HAP emissions occur at hazardous waste TSDF.
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TABLE 2-1. ESTIMATED NATIONWIDE ORGANIC HAP EMISSIONS
FOR OFF-SITE WASTE OPERATIONS SOURCE CATEGORY
Type. of. Facility .
Receiving Materials
From Off-Site(a)
Hazardous waste TSDF(C)
Industrial wastewater
treatment operations1"1'
Industrial waste
landfills'6'
Crude oil reclamation
and land treatment
facilities (f)
Used oil re-refining
facilities'9'
Estimated
Number of
Existing
Facilities
Nationwide •
710
15
10
26
4
Type of
Material
Received from
Off-site(b)
hazardous waste
nonhazardous
waste
nonhazardous
wastewater
industrial
process waste
E&P waste
material
used oil
Estimated
Nationwide.
Quantity of
Material
Managed
(1, 000 Mg/yr)
26, 000
9,400
22, 000
1, 800
230
430
Estimated
. Nationwide
Organic HAP
Emissions
(Mg/yr) •
34, 000
12, 000
3, 600
1, 300
600
50
I
I—1
J^
Notes:
(a) Types of off-site waste facilities estimated to include individual facilities emitting more than 10 ton
per year of an individual organic HAP or more than 25 ton per year of total organic HAP.
(b) "Hazardous" refers to materials defined to be a "hazardous waste" under RCRA regulations.
"Nonhazardous" refers to materials not defined to be a "hazardous waste" under RCRA regulations.
(c) Estimates based on EPA Office of Solid Waste (OSW) 1986 nationwide survey data.
(d) Estimates based on EPA Office of Water 1989 nationwide survey data.
(e) Estimates based on 1994 telephone contacts of industry representatives and waste management companies.
(f) Estimates based on information gathered during site visits of oil and gas E&P waste management
facilities in 1993 and a 1985 production waste survey.
(g) Estimates based on EPA OSW estimates of nationwide used oil management practices for 1991.
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2.4 REFERENCES
1. U.S. Environmental Protection Agency. National Survey of
Hazardous Waste Treatment, Storage, Disposal, and
Recycling Facilities. Office of Solid Waste. Washington,
B.C. June 1987.
2. U.S. Environmental Protection Agency. National Survey of
Hazardous Waste Generators. Office of Solid Waste.
Washington, B.C. June 1987.
3. Memorandum from Coburn, J., Research Triangle Institute,
to Crump, E., U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. Order-of-
Magnitude Emissions Estimate for Nonhazardous Waste
Materials Managed at RCRA Subtitle C TSBF. March 8,
1994.
4. U.S. Environmental Protection Agency. Waste Treatment
Industry Questionnaire. Office of Water. Washington,
B.C. April 1991.
5. U.S. Environmental Protection Agency. Hazardous Waste
Management Systems; Identification and Listing of
Hazardous Waste; Recycled Used Oil Management Standards:
Final Rule. 57 FR 41566-41626. September 10, 1992.
6. Memorandum from Coburn, J., Research Triangle Institute,
to Crump, E., U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. Order-of-
Magnitude Organic HAP Emission Estimate for Off-site
Facilities Managing Wastes From Oil and Gas Exploration
and Production Operations. August 10, 1994.
7. U.S. Environmental Protection Agency. Compilation of Air
Pollutant Emission Factors, 4th Edition. AP-42.
September 1985.
8. Reference 7.
9. Memorandum from Coburn, J., Research Triangle Institute,
to Crump, E., U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. Order-of-
Magnitude Emissions Estimate for Nonhazardous Waste
Materials Managed at RCRA Subtitle C TSBF. March 8,
1994.
10. Reference 3.
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11. Memorandum from Coburn, J. and P. Peterson, Research
Triangle Institute, to Crump, E., U.S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards. Order-of-Magnitude Estimate of Organic HAP
Emissions from Commercial Nonhazardous Wastewater
Treatment Facilities. August 4, 1993.
12. U. S. Environmental Protection Agency. Cost and Economic
Impact of Used Oil Management Standards. Regulatory
Analysis Branch, Office of Solid Waste. August 4, 1992.
13. Memorandum from Coburn, J. and P. Peterson, Research
Triangle Institute, to Crump, E., U.S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards. Order-of-Magnitude Organic HAP Emission
Estimates for Commercial Waste Oil Recycling Facilities.
May 20, 1993.
14. Reference 6.
15. Memorandum with attachments from Coburn, J. and
P. Peterson, Research Triangle Institute, to Crump, E.,
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards. Annual Total Organic HAP
Emission Estimates for Drum Reconditioning Operations and
Tank Truck Cleaning Operations. April 14, 1993.
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3.0 SOURCE CATEGORY EMISSION POINTS
This chapter discusses the types of emission points at
off-site waste operations facilities from which organic
emissions to the atmosphere may occur. The organic vapors
emitted from these emission points are composed of varying
amounts of organic hazardous air pollutants (HAP) as well
volatile organic compounds (VOC) depending on the specific
organic constituent composition of the waste materials being
managed at the emission point. Section 3.1 presents a brief
overview of the types of waste management units commonly used
at off-site waste operations facilities. The organic HAP
emission point type classifications used for the off-site
waste operations source category impact analysis are described
in Section 3.2.
3.1 WASTE MANAGEMENT UNITS
3.1.1 Tanks
Tanks are used for many different applications at
off-site waste operations facilities to accumulate, store, or
treat waste materials containing organics. These tanks can be
either open tanks (i.e., the surface of the waste material is
exposed directly to the atmosphere), covered tanks (i.e., the
surface of the waste material is enclosed by a roof or cover),
or pressure tanks (i.e., the waste material is stored at
pressures above atmospheric pressure).
Organic emissions result from the volatilization of
organics-containing waste materials placed in the tank, and
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the subsequent release of these organic vapors to the
atmosphere. For open tanks, the organic vapors released from
the surface of the waste material are dispersed immediately
into the atmosphere by diffusion and the wind effects. The
rate of organic volatilization is increased when the waste
material is heated or when the waste material is agitated or
aerated (e.g., the use of surface aerators in open-top tanks
to increase the supply of oxygen for microorganisms in
biological wastewater treatment units). However, under
certain operating conditions, the microbes in biological
wastewater treatment process can degrade (i.e., destroy)
certain organic compounds in the waste material at a rate much
faster than the organic compounds can volatilize and be
released into the air. In this special case, organic
emissions from an aerated open-top tank are low.
Covering a tank (referred to as a "fixed-roof tank")
significantly lowers organic emissions compared to open tanks.
However, organic emissions still occur from fixed-roof tanks
as a result of the displacement of organic vapors which have
collected in the enclosed space above the waste surface
through vents on the tank roof. This displacement occurs
during tank filling operations when the vapors are pushed out
through the tank vents by the rising level of liquid in the
tank (commonly referred to as "working losses"). Organic
emissions, to a lesser extent, also occur from organic vapor
displacement when the volume of the vapor in the tank is
increased by fluctuations in ambient temperature or pressure
(commonly referred to as "breathing losses"). The quantity of
organic emissions from a fixed-roof tank varies greatly
depending on volatility of the organic constituents in he
waste materials placed in the tank, and whether the tank vents
are open to the atmosphere, equipped with a pressure-vacuum
relief valves, or vented to an air emission control device.
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Organic emissions from a properly operated tank using a
floating roof or a pressure tank are very low. Installing a
cover which floats on the waste surface essential eliminates
the vapor space inside the tank in which organic vapors can
collect. Small quantities of organic emissions occur from
small openings for floating roof deck fittings (commonly
referred to as "working losses"), and from the evaporation of
the liquid that wets the inside tank wall as the roof descends
during emptying operations (commonly referred to as
"withdrawal losses"). Additional organic emissions from
floating roof tanks occur if there are gaps or holes in the
seals between the roof rim and the tank wall. Pressure tanks
operate as closed systems and do not emit organic vapors under
normal operating conditions.
3.1.2 Containers
Waste materials frequently are delivered to off-site
waste operations facilities in containers such as drums,
roll-off boxes, tank trucks, and rail cars. In addition,
certain types of containers (e.g., drums, dumpster, and
roll-off boxes) can be used at the facility to accumulate,
store, and treat waste materials. Drums used for waste
management are typically fitted with lids. Tank trucks and
tank railcars are equipped with hatches or ports which are
opened when waste materials are being loaded or unloaded.
Dumpsters and roll-off boxes used for handling waste materials
are frequently open-top but, in some applications, lids or
covers are installed on these types of containers.
Organic emissions from containers can result by several
emission mechanisms. Open containers are an emission source
when organics evaporate from the exposed surface of the waste
material placed in the container. Organic emissions occur
during loading of liquid, slurry, and sludge waste materials
into containers due to the displacement of organic vapors out
through container openings (e.g., the unplugged bung on a drum
3-3
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lid, the open hatch on a tank truck or tank railcar) by the
rising level of material in the container. The organic
emissions from loading operations are greatest when splash
filling is used. During this type of loading operation, the
impact of the incoming waste material on the surface of
material already in the container creates turbulence and
splashing which tends to quickly saturate the vapors above the
waste surface with organics. Organics emissions during
loading operations using submerged fill are significantly
lower because the incoming waste material is discharged below
the waste surface eliminating the splashing and reducing the
degree of saturation of the displaced vapors.
3.1.3 Surface Impoundments
Liquid, slurry, and sludge waste materials are managed at
some off-site waste operations facilities in surface
impoundments. A surface impoundment is an earthen pit, pond,
or lagoon which may be lined with a synthetic membrane liner
or other materials. The most common use of surface
impoundments at off-site waste operations facilities is for
wastewater treatment systems. Examples of surface impoundment
used for wastewater treatment systems include accumulation of
on-site rainfall runoff, mixing and equalization of wastewater
streams collected from multiple sources, neutralization of
acidic wastewaters, and biodegradation of organics in
wastewaters. Surface impoundments are sometimes used for
disposal of liquid, slurry, or sludge waste materials that are
not defined to be a RCRA hazardous waste. The use of surface
impoundments for managing RCRA hazardous wastes is decreasing
as many TSDF owners and operators are choosing to convert
their existing surface impoundments to tanks.
Organic emissions from surface impoundments occur as
organics evaporate from the exposed surface of the waste
materials placed in the impoundment. Surface impoundments
containing organic-containing waste materials have a high
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organic emission potential because of the very large exposed
surface area (typical-size surface impoundments cover several
acres or more) and the long residence time that waste
materials have in the impoundment (sometimes weeks or months).
These two factors often allow the loss of most of the volatile
organic constituents. In addition, when mechanical or
diffused air aerators are used to enhance a biodegradation
process performed in a surface impoundment, the aerators cause
turbulent surface areas which significantly increases the rate
of organic emissions near the aerators.
3.1.4 Landfills
A landfill is usually an excavated, lined pit or trench
into which waste materials are buried for permanent disposal.
If any organics remain in the waste materials that are placed
in landfill, organic emissions occur as a result of the
volatilization of organics from the exposed waste material
surface until the material is covered by a layer of soil.
Once the waste material is covered, additional organic
emissions can still occur over extended periods of time due to
the diffusion of organic vapors from the waste materials
upward to the soil surface as well as the migration of
organic-containing gases formed by the decomposition of waste
materials in the landfill.
3.1.5 Land Treatment Units
For land treatment, a waste material is spread on or
injected into the soil, and then the soil is tilled to allow
aerobic soil bacteria adequate oxygen to compose the organic
compounds contained in the material. However, tilling also
increases the surface area of the waste matter that is exposed
to the atmosphere. Organic emissions are generated due to the
volatilization of organics from the exposed surface of the
waste materials primarily during application and tilling.
After application and tilling organic emissions continue to
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occur from the soil and/or waste material mixture, although at
a decreasing rate, until all of the volatile organics
originally in the applied waste material are either emitted or
biologically degraded.
3.1.6 Wastepiles
A wastepile is used for the storage or treatment of
solid, nonflowing waste materials on the ground, on a pad, or
other open area exposed to the ambient air. The organic
emission mechanism for waste piles is similar to that for
uncovered waste material placed in a landfill; volatilization
of organics from the exposed surface of the waste material and
the diffusion of organic vapors from the waste material within
the waste pile to the surface of the surface.
3.1.7 Other Treatment Processes
At off-site waste operations facilities, waste treatment
processes are commonly employed when managing waste materials
containing organics. Examples of these waste treatment
processes include batch distillation units, thin-film
evaporators, solvent extraction units, air stripping units,
and steam stripping units. Emissions from these types of
waste treatment processes primarily occur through the process
vent.
A "process vent" is a pipe, stack, duct, or similar
opening through which gases and vapors generated in a process
unit or waste management unit are exhausted to the atmosphere.
Organic emissions from process vents result primarily from
venting organic vapors and evacuation of equipment for vacuum
processing. These emissions occur at the point at which the
organic-containing vapors and gases exit the process vent
outlet into the atmosphere. Process vents can be used to
directly vent the process column or vessel, to vent condensers
serving this process equipment, and to indirectly vent the
process equipment through tanks which are integral components
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of the process (e.g., distillate receivers, bottoms receivers,
surge control tanks, separator tanks, and hot wells).
3.1.8 Ancillary Equipment
Ancillary equipment is needed throughout an off-site
waste operations facility to operate tanks and the waste
treatment processes described in Section 3.1.7 of this
chapter, for container loading and unloading operations, for
transfer of waste material from one waste management unit to
another, and for other waste management operations. Pumps and
valves are used extensively for handling liquid, slurry, and
sludge waste materials. Many connectors such as flanges and
threaded fittings are needed to join sections of pipe or
equipment. Other ancillary equipment consist of compressors,
agitators, pressure relief devices, sampling connections,
open-ended lines, accumulator vessels, and instrumentation
systems.
Organic emissions occur from ancillary equipment
containing or contacting gases or liquids that have organic
constituents. Organic vapors can be emitted directly to the
atmosphere by flowing through small openings created in worn
or defective pump and valve packings, flange gaskets, or other
types of equipment seals. In addition, organic emissions
occur when liquids leak outside the equipment exposing the
leaked fluid to the ambient air. Emissions result when
organics contained in the drip, puddle, or pool of leaked
liquid evaporate into the atmosphere. Although the quantity
of organic emissions from a single leak is small, when many
equipment leaks occur at a facility, the total organic
emissions from equipment leaks can be significant.
3.2 SOURCE CATEGORY EMISSION POINTS
For the control option impact analysis, the EPA
classified the organic HAP emission sources for the off-site
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waste operations source category into five emission point
types:
Tanks. The tank emission point type for the off-site
waste operations source category represents the organic
emissions from all waste material management in tanks
including wastewater treatment tanks.
Containers. The container emission point type for the
off-site waste operations source category represents the
organic emissions from the handling of waste materials in
drums, dumpsters, roll-off boxes, trucks, and railcars.
Land Disposal Units. The land disposal unit emission
point type for the off-site waste operations source
category represents the organic emissions from surface
impoundments, landfills, land treatment units, and waste
piles.
Process Vents. The process vent emission point type for
the off-site waste operations source category represents
the organic emissions from process vents on batch
distillation units, thin-film evaporators, solvent
extraction units, air stripping units, and steam
stripping units.
Equipment Leaks. The equipment leak emission point type
for the off-site waste operations source category
represents the organic emissions from gaseous and liquid
leaks in pumps, valves, flanges, compressors, agitators,
pressure relief devices, sampling connections, open-ended
lines, accumulator vessels, and instrumentation systems.
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4.0 CONTROL TECHNOLOGIES
This chapter describes the organic emission reduction
strategies considered by the EPA to develop organic HAP
control options for the off-site waste operations source
category. Organic HAP compounds in general are a subset of
all organic compounds that can potentially be emitted to the
atmosphere. Thus, the same control technologies used to
control total organic emissions are applicable to controlling
organic HAP emissions from waste operations.
One strategy for reducing organic emissions applicable to
all types of waste management units is to pretreat the waste
materials to reduce the organic content of the waste material
before the material enters the unit. Section 4.1 discusses
pretreatment processes which can be used for removing organics
from or destroying organics in waste materials. An
alternative strategy is to apply add-on organic emission
controls on each waste management unit in which
organic-containing waste materials are managed. Section 4.2
identifies the add-on organic emission controls selected by
the EPA as most appropriate for waste management unit types
described in Chapter 3 for the off-site waste operations
source category.
Background information is not presented in this chapter
regarding the selected control technologies, alternative but
less effective control technologies, or emerging but not
commercially available control technologies. For detailed
4-1
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background information on organic emission control
technologies, the reader is referred to other published EPA
documents as cited throughout this chapter.
4.1 WASTE PRETREATMENT
Pretreatment of the waste materials, to remove or destroy
the organics in the waste materials, reduces organic emissions
from all subsequent waste management units handling these
materials without the need to apply add-on emission controls
on these units. Volatile organic compounds can effectively be
removed from many waste materials using conventional processes
such as steam stripping, air stripping, solvent extraction, or
thin-film evaporation. Biological degradation processes also
can be used to destroy volatile and other organic compounds in
wastewaters (e.g., activated sludge wastewater treatment
processes). All forms of waste materials containing organics
can be burned in an incinerator to destroy organics and
produce inorganic waste materials for subsequent management at
the off-site waste operations facility. Background
information regarding treatment processes for waste materials
containing organics is available in References 1 and 2 for
this chapter.
The organic removal performance of noncombustion
treatment processes is dependent on, among other factors
specific to the process used, the concentration and volatility
of the specific organic constituents contained in the waste
materials. For organic compounds that have high volatilities
(e.g., these include HAP compounds such as benzene, carbon
tetrachloride, chlorobenzene, chloroform, ethylene oxide,
methylene chloride, tetrachloroethene, toluene, vinyl
chloride), organic removal efficiencies of 90 percent and
higher can be achieved. However, it is important to note that
many noncombustion treatment processes produce byproducts,
residual materials, or gas streams which contain the organic
compounds removed from the waste materials. Thus, to achieve
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actual organic emission reductions from the off-site waste
operations facility, these secondary materials and gas streams
must also be properly managed in units using organic emission
controls to prevent subsequent release of the organics into
the atmosphere.
4.2 ADD-ON ORGANIC EMISSION CONTROLS
When organic-containing waste materials are placed in a
waste management unit, organic emissions released from the
unit can be reduced by adding emission controls at the
individual emission points on the unit and its ancillary
equipment. The organic emission controls which are applicable
and effective to a particular type of waste management unit
vary depending on the source size and the organic emission
mechanisms.
4.2.1 Tanks
Several alternative organic emission controls are
available for most tank types in which organic-containing
waste materials are managed depending on the concentration and
volatility of the organic constituents in these waste
materials as well as the tank use, design, and size. The
first step to controlling tank organic emissions is to convert
waste operations performed in open tanks to closed tanks. In
many cases, roofs can be retrofitted to existing open tanks.
Although fixed-roof tanks provide large reductions in organic
emissions compared to open tanks, significant quantities of
organic emissions can be emitted from a fixed-roof tank that
either is used to manage waste materials composed of higher
volatility organic compounds or is used to manage large
quantities of low organic concentration or low volatility
waste materials. In these cases, additional organic emission
controls are needed to achieve low organic emission levels
from the tank. These controls include using a floating roof
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tank, a pressure tank, or a fixed-roof tank connected through
a closed vent system to an organic emission control device.
Organic emissions from a properly designed and maintained
floating roof tank are very low. Floating roofs can be
installed internally in fixed-roof tanks or used externally
without a fixed-roof. As applied to off-site waste
operations, application of floating roofs can provide
effective organic emission control for cylindrical,
vertical-wall tanks used for storage of waste materials or,
under some circumstances, treatment of waste materials.
Because the roof deck floats on the surface of the waste
material placed in the tank, a floating roof cannot be used
where the presence of the roof deck on the waste surface
interferes with the treatment process (e.g., biological
wastewater treatment tanks using surface mixing or aeration
equipment).
Pressure tanks are most commonly used for the storage of
gaseous waste materials but can also be used for liquid waste
materials. This type of tank is designed to operate safely at
internal pressures above atmospheric pressure. Consequently,
a pressure tank is operated as a closed system that does not
emit organic vapors at normal storage conditions or during
routine loading and unloading operations. Pressure-relief
valves are installed on a pressure tank to open only in the
event of improper operation or an emergency to prevent the
internal tank pressure from exceeding the design limit.
In all cases for tanks managing waste materials
containing organics, organic emissions can be controlled by
covering the tank and venting the tank through a closed vent
system to an organic emission control device. These organic
emission control devices can be grouped into two general
categories: vapor recovery control devices and vapor
destruction control devices. Vapor recovery control devices
use noncombustion processes to extract the organics from the
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vent stream for potential recycling or reuse. These control
devices include carbon adsorbers, condensers, and absorbers.
Vapor destruction control devices use combustion/oxidation
processes to destroy the organics in the vent stream before it
is discharged to the atmosphere. These control devices
include flares, thermal vapor incinerators, catalytic vapor
incinerators, and boilers and process heaters. The type of
control device best suited for reducing organic emissions from
a tank depends on the size of the tank and the characteristics
of the organic vapor stream vented from the tank.
Additional background information regarding the
application of floating roofs, pressure tanks, and control
devices for controlling tank organic emissions from waste
operations is available in Reference 3.
4.2.2 Containers
Organic emissions from containers in which waste
materials containing organics are handled are controlled by
using vapor leak-tight covers on the containers and using
submerged fill loading of liquid, slurry, and sludge type
waste materials into containers. In submerged fill loading,
the influent pipe used to fill the container is positioned
below the surface of the waste material already in the
container. This control technique significantly reduces the
induced turbulence, evaporation, and liquid entrainment that
occurs during splash loading operations. Submerged fill
loading is applicable to the loading of liquid wastes and many
sludges into containers of all types.
4.2.3 Land Disposal Units
If waste materials are not pretreated to remove organics
prior to disposal, then organic emissions from surface
impoundments, landfills, land treatment units, and waste piles
must be controlled by covering the entire surface of the unit
through installation of a flexible membrane cover or by
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enclosing the unit in a rigid or air-supported structure which
is vented to a control device. Because land disposal units
typically encompass very large areas (on the order of acres),
the EPA considers the removal of organics from the waste
material prior to disposal to be a more practical approach for
controlling organic emissions from land disposal units at
off-site waste operations facilities.
Add-on organic emission controls have been applied to
surface impoundments. Using a floating membrane cover on a
surface impoundment is analogous to using a floating roof in a
tank for organic emission control. A floating membrane cover
consists of large sheets of a synthetic, flexible membrane
material (e.g., high-density polyethylene) seamed or welded
together to form a cover that floats directly on the surface
of the waste material placed in the impoundment. The level of
organic emission control achieved by a floating membrane cover
depends on the type and thickness of membrane material as well
as the specific organic compounds composing the waste
materials on which the cover is installed. Additional
background information regarding the use of floating membrane
covers for organic emission control is available in
Reference 4 for this chapter.
When installation of a floating membrane cover is not
possible such as in the case of a treatment surface
impoundment using surface aerators, organic emissions from a
surface impoundment have been controlled by erecting an
air-supported structure over the entire surface of the
impoundment and venting the enclosure through a closed vent
system to a control device. An air-supported structure is a
plastic-reinforced fabric shell that is inflated and therefore
requires no internal rigid supports. Large fans are used to
blow air through the structure and out a vent system connected
to a control device. The same control devices discussed for
tanks in Section 4.2.1 of this chapter generally apply to
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controlling organic emissions from surface impoundments.
Additional background information regarding application of
air-supported structures to covering surface impoundments is
available in Reference 5 for this chapter.
An alternative approach to applying add-on organic
emission controls to surface impoundments is to replace the
surface impoundment with tanks that use the add-on organic
emission controls described in Section 4.2.1 of this chapter.
Many owners and operators of existing facilities that manage
hazardous wastes in surface impoundments are already choosing
to use this approach to comply with other regulations.
4.2.4 Process Vents
Controlling process vent organic emissions requires
discharging the organic vapors and gases from the vent through
a closed vent system to an organic emission control device.
Considering process vent stream characteristics, the control
devices most likely to be used to control organic emissions
from process vents at off-site waste operation facilities are
carbon adsorbers, condensers, flares, and thermal vapor
incinerators. Additional background information regarding the
application of control devices for controlling process vent
organic emissions from waste operations is available in
Reference 6 for this chapter.
4.2.5 Equipment Leaks
Two basic approaches are effective for controlling
organic emissions that occur as a result of leaks from
ancillary equipment containing or contacting organic waste
materials: (1) implementing a work practice referred to as a
leak detection and repair (LDAR) program; or (2) equipment
modifications. A LDAR program is primarily applicable to
controlling organic emissions from leaking pumps, valves,
connectors, and, to a lesser degree, compressors. Leaks from
4-7
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other types of ancillary equipment are more easily controlled
by equipment modifications.
A LDAR program involves periodic monitoring of ancillary
equipment components (e.g., valves, pump seals, flanges) by
facility personnel using a portable organic vapor detector to
identify those components that are leaking. Once a leaking
component is detected, the component is adjusted, repaired, or
replaced as needed to stop the leak. Implementing a LDAR
program is estimated to reduce organic emissions from
equipment leaks on the order of 70 to 90 percent depending on
the leak detection monitoring frequency and the organic
concentration level used for defining a leak.
Equipment modifications minimize, if not eliminate, the
potential for the equipment to leak during normal operations.
Examples of effective equipment modifications include:
installing dual mechanical seals with a barrier fluid on
pumps; installing sealless type pumps; installing diaphragm or
sealed-bellows type valves; using a rupture disk as the
pressure relief device; installing closed-loop sampling lines;
and installing caps or plugs on open-end lines. When the
appropriate modifications are made on equipment components,
leak detection monitoring of the component is not required.
Additional background information regarding the
application of LDAR programs and equipment modifications for
controlling organic emissions from leaking waste operation
equipment is available in Reference 7.
4.3 REFERENCES
1. U.S. Environmental Protection Agency. Alternative
Control Technology Document - Organic Waste Process
Vents. Office of Air Quality Planning and Standards.
Research Triangle Park, NC. EPA Publication No.
EPA-450/3-91-007. December 1990. pp. 2-16 through 2-34.
-------
U.S. Environmental Protection Agency. Hazardous Waste
TSDF - Background Information for Proposed RCRA Air
Emission Standards. Office of Air Quality Planning and
Standards. Research Triangle Park, NC. EPA Publication
No. EPA-450/3-89-023. June 1991. pp. 4-39 through 4-62.
3,
4,
5,
6,
7,
Reference 2.
Reference 2.
pp. 4-5 through 4-12 and 4-20 through 4-39.
pp. 4-12 through 4-15.
Reference 2. pp. 4-15 through 4-19.
Reference 1. pp. 2-34 through 2-51.
U.S. Environmental Protection Agency. Hazardous Waste
TSDF - Technical Guidance Document for RCRA Air Emission
Standards for Process Vents and Equipment Leaks. Office
of Air Quality Planning and Standards. Research Triangle
Park, NC. EPA Publication No. EPA-450/3-89-021. July
1990. pp. 5-1 through 5-67.
4-9
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5.0 ORGANIC EMISSION IMPACT ESTIMATES
This chapter presents organic emission impact estimates
for control options to reduce organic HAP emissions from the
off-site waste operations source category. The control
options selected for analysis are described in Section 5.1.
Section 5.2 describes the baseline used by EPA to compare
reductions for each control option. A summary of the general
methodology used to estimate the level of organic emission
reduction each control option would achieve if implemented is
presented in Section 5.3. Estimates of organic HAP and VOC
emission reductions for each control options are presented
Section 5.4.
5.1 SELECTION OF CONTROL OPTIONS
To develop the NESHAP for off-site waste operations
source category, the EPA identified and evaluated a variety of
possible control options for applying the organic emission
controls identified in Chapter 4 of this document to the
emission point types identified in Chapter 3 of this document.
Different control options were identified by varying which
waste management units within an emission point type that
would use organic emission controls and the types of organic
emission controls applied to these units.
Many possible control options can be identified for an
emission point type. However, evaluating every conceivable
control option regardless of the control option's potential
effectiveness to reduce organic HAP emissions is not
5-1
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practicable. Therefore, the EPA selected only the control
options for this analysis that would likely produce
significant reductions in the organic HAP emission level for
the emission point type. Control options judged likely to
produce little or no reductions in the organic HAP emission
level for an emission point type were excluded from further
consideration. The control options used for the off-site
waste operations source category impact analysis are described
in the following subsections.
5.1.1 Tank Control Options
Three control options were identified for the tank
emission point type (labeled Options Tl, T2, and T3). All
three of these control options would require that all tanks
managing waste materials received from off-site and having a
volatile organic HAP concentration equal to or greater than
100 ppmw use covers as a minimum level of control. The
difference between the control options is whether certain of
these covered tanks be required to use additional organic
emission controls based on the organic HAP vapor pressure of
the waste material placed in the tank.
Option Tl would require the use of covered tanks for all
waste materials with a volatile organic HAP concentration
equal to or greater than 100 ppmw. No additional controls
would be required regardless of the organic HAP vapor pressure
of the waste material placed in the tank.
Option T2 would require the use of covered tanks for all
waste materials with a volatile organic HAP concentration
equal to or greater than 100 ppmw. In addition, all tanks
managing waste materials having an organic HAP vapor pressure
action level equal to or greater than 0.75 psia would be
required to use, in combination with the cover, a closed vent
system with control device that achieves a total organic
control efficiency of 95 percent (or use of an equivalent
5-2
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control technology, such as the installation of an internal
floating roof inside a fixed-roof tank).
Option T3 again would require the use of covered tanks
for all waste materials with a volatile organic HAP
concentration equal to or greater than 100 ppmw. All tanks
managing waste materials having an organic HAP vapor pressure
action level equal to or greater than 0.1 psia would be
required to use, in combination with the cover, a closed vent
system with control device that achieves a total organic
control efficiency of 95 percent (or an equivalent control
technology).
5.1.2 Containers Control Options
Two control options are identified for the container
emission point type (labeled Options Cl and C2). Both of
these control options would require that containers managing
waste materials received from off-site and having a volatile
organic HAP concentration equal to or greater than 100 ppmw
use covers as a minimum level of control. The difference
between the control options is the second control option adds
a requirement for submerged fill loading.
Option Cl would require the use of covers on containers
handling waste materials with a volatile organic HAP
concentration equal to or greater than 100 ppmw. No
additional controls would be required.
Option C2 would require the use of covered tanks for all
waste materials with a volatile organic HAP concentration
equal to or greater than 100 ppmw. In addition, when
transferring waste materials into containers by pumping,
submerged fill loading would be required if the volatile
organic HAP concentration of the waste material is equal to or
greater than 100 ppmw.
5-3
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5.1.3 Land Disposal Unit Control Options
One control option is identified for the land disposal
unit emission point type (labeled Option LD1). This control
option would limit the management of waste materials in open
land disposal units to only those waste materials with a
volatile organic HAP concentration less than 100 ppmw. No
other realistic control options were identified which could
produce significant additional reductions in the organic HAP
emission levels for land disposal units.
5.1.4 Process Vent Control Options
One control option is defined for the process vent
emission point type (labeled Option PV1). This control option
would require that process vents with total organic HAP mass
emissions equal to or greater than 3 tons/yr be connected to a
control device with a 95 percent organic emission control
efficiency. No other realistic process vent control options
were identified that could produce significant additional
reductions in the organic HAP emission level for the emission
point type.
5.1.5 Equipment Leak Control Options
Two control options are identified for the equipment leak
emission point type (labeled Options ELI and EL2). Both
control options would require the control of emissions from
leaks in equipment containing or contacting waste materials
with total organic HAP concentrations equal to or greater than
10 percent. The control options differ in the type of leak
detection and repair (LDAR) work practice program to be
implemented.
Option ELI would require control of emissions from leaks
in equipment containing or contacting waste materials with
total organic HAP concentrations equal to or greater than
10 percent by implementing a LDAR program which follow the
procedures specified in existing NSPS process equipment leak
5-4
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standards promulgated by the EPA under 40 CFR 60 subparts W,
GG, and KK, and the NESHAP for process equipment leak
promulgated under 40 CFR 61 subpart V.
Option EL2 would require control of emissions from leaks
in equipment containing or contacting waste materials with
total organic HAP concentrations equal to or greater than
10 percent by implementing a LDAR program which follow the
procedures specified in the EPA's negotiated regulation for
equipment leaks consistent with the Hazardous Organic NESHAP
(HON) promulgated by the EPA under 40 CFR 63 subpart H.
5.2 BASELINE FOR CONTROL OPTION COMPARISON
For the purposes of evaluating the relative organic
emission reduction effectiveness of alternative control
options, the EPA defines a "baseline" as a reference point
from which each control option can be compared. The baseline
represents the estimated level of organic emissions from the
source category that would occur in the absence of
implementing any of the control options. For the off-site
waste operations source category, a baseline was chosen to
reflect the level of organic emissions for each emission point
type following implementation of air emission controls
required by federally enforceable air regulations in effective
as of July 1991. The federally enforceable air regulations
that the EPA considered when developing the baseline emission
estimates follow:
! RCRA organic air emission standards for
TSDF process vents (40 CFR 264 subpart AA
and 40 CFR 265 subpart AA)
! RCRA organic air emission standards for
TSDF equipment leaks (40 CFR 264
subpart BB and 40 CFR 265 subpart BB)
! RCRA land disposal restrictions (40 CFR
part 268)
5-5
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! NESHAP for benzene waste operations
(40 CFR 61 subpart FF)
5.3 ORGANIC EMISSION ESTIMATION METHODOLOGY
In developing NESHAP and other air standards, the EPA
frequently uses a model plant approach for comparing
alternative control options. However, for the off-site waste
operations source category, it is difficult to adequately
characterize the source category using a selection of several
representative model plants. For many of the facilities in
the source category, the quantities and characteristics of
waste materials received at the facility are highly variable
and can change often (as frequently as on a day-to-day basis).
In addition, many different waste management unit
configurations are used at off-site waste operations
facilities to manage these ever changing waste materials.
Consequently, the EPA decided a model plant approach is not
appropriate for estimating control option impacts for the off-
site waste operations source category.
Instead of using a model plant approach for the off-site
waste operations source category, the EPA decided to
adapt a computer model developed by the Agency to estimate
nationwide organic air emission impacts from RCRA hazardous
waste treatment, storage, and disposal facilities (TSDF). As
presented in Table 2-1 of this document, the EPA estimates
that approximately 90 percent of the nationwide total organic
HAP emissions for the off-site waste operations source
category occur at hazardous waste TSDF. Consequently, the EPA
considers adapting this computer model to be appropriate for
evaluating alternative control options for the off-site waste
operations source category.
The primary sources of site-specific waste data used as
input into the computer model are two comprehensive nationwide
surveys that the EPA Office of Solid Waste (OSW) conducted in
1987: the National Survey of Hazardous Waste Generators
5-6
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(referred to hereafter as the "GENSUR"); and the National
Survey of Hazardous Waste Treatment, Storage, Disposal, and
Recycling Facilities (referred to hereafter as the "TSDR
Survey"). These data represent waste quantities, waste
compositions, and waste management practices at hazardous
waste TSDF in 1986, and are the most recent nationwide TSDF
waste data available to the EPA on a consistent, industry-wide
basis.
The data base indicates that 710 TSDF received waste
materials from off-site waste generators in 1986. The EPA
adapted its computer model to simulate the waste management
process reported in the TSDR Survey to be operating at each of
these TSDF. Organic HAP emission factors and emission control
cost factors are assigned to each waste management processes
using one (or in many cases a combination of several) of the
model units developed for the TSDF RCRA air rules projects.
Further details regarding the emission estimation methodology
are provided in Appendix B to this document.
Waste management practices at some TSDF have changed
since the data were collected for the GENSUR and TSDR Survey.
Industry has implemented these changes either to improve
services or to comply with new EPA regulations promulgated
since 1986. To address these changes, assumptions were
applied in the computer model to better reflect current
industry-wide waste management trends (e.g., conversion of
surface impoundments to tanks, treatment of certain wastes
prior to or as an alternative to land disposal). These
assumptions are summarized in Table 5-1 and described in
further detail in Appendix B to this document.
Additional assumptions were made to simulate the
implementation of the different control options in the
computer model. These assumptions are summarized in Table 5-2
and described in further detail in Appendix B to this
document.
5-7
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5.4 CONTROL OPTION ORGANIC EMISSION ESTIMATES
The baseline organic HAP and VOC emissions estimated by
the computer model for the 710 RCRA hazardous waste TSDF
receiving waste materials from off-site are presented in
Table 5-3. At the baseline conditions, the organic HAP
emissions are estimated to be approximately 34,400 Mg/yr.
Approximately 90 percent of these emissions are from the tank
emission point type.
A comparison of the organic HAP and VOC emission
reductions for the control options selected for each emission
point type are presented in Table 5-4.
5-!
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TABLE 5-1. SUMMARY OF BASELINE ASSUMPTIONS
USED FOR ORGANIC EMISSION ESTIMATES
RCRA Organic Air Emission Standards
for TSDF Process Vents
(40 CFR 264 subpart AA and 40 CFR 265 subpart AA)
Process vents on processes listed in data base as
distillation, solvent extraction, thin-film
evaporation, steam stripping, or air stripping and
estimated to have a total organic mass emissions > 3
tons/yr are assumed to be vented to a control device
with a 95% organic emission control efficiency.
RCRA Organic Air Emission Standards
for TSDF Equipment Leaks
(40 CFR 264 subpart BB and 40 CFR 265 subpart AA)
Waste streams reported in the data base with total
organic concentrations > 10 percent are assumed to
be controlled by implementing a leak detection and
repair (LDAR) program which results in an emission
reduction ranging from 70% to 75% depending on the
form of the waste materials.
RCRA Land Disposal Restrictions
(40 CFR part 268)
All surface impoundments reported in the data base
to be used for storage or treatment are assumed to
be closed and the waste materials managed in these
units to be managed in new tanks.
All surface impoundments reported in the data base
to be used for disposal are assumed to be replaced
by (or closed as) landfills.
All waste streams reported to be disposed in a land
treatment unit or landfill unit are assumed to be
treated to meet the LDR treatment standards prior to
disposal.
5-9
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TABLE 5-1. (concluded)
NESHAP for Benzene Waste Operations
(40 CFR 61 subpart FF).
All waste streams reported in the data base to have
a benzene concentration > 10 ppmw use organic
emission controls to comply with rule.
Affected non-wastewater streams managed in tanks are
vented to control devices with a 95% organic
emission control efficiency.
Affected wastewater streams are pre-treated by steam
stripping to reduce the benzene concentration of the
waste stream to 10 ppmw or to the benzene
concentration corresponding to a 99% removal of
benzene from the wastewater stream, whichever
concentration value is higher.
Processes handling affected waste streams are vented
to control devices with a 95% organic emission
control efficiency.
Transfer of affected waste streams into containers
is by submerged fill loading.
Other Organic Emission Controls
Organic emission control equipment reported in data
base to be in place at a facility are assumed to be
in operation.
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TABLE 5-2. SUMMARY OF CONTROL OPTION ASSUMPTIONS
USED FOR ORGANIC EMISSION ESTIMATES
Tank Control Options
Open tanks reported in the data base managing waste
streams with estimated volatile organic HAP
concentrations > 100 ppmw are converted to covered
tanks.
All hazardous waste quantities reported in the data
base to managed in surface impoundments are assumed
to now be managed in tanks.
Container Control Options
Organic control efficiency for submerged fill
loading is assumed to be 65%.
Land Disposal Unit Control Option
All hazardous waste quantities reported in the data
base to managed in surface impoundments are assumed
to now be managed by treatment and disposal in
landfills.
All hazardous waste streams reported to be disposed
in a land treatment unit or landfill unit are
assumed to be treated to meet the LDR treatment
standards prior to disposal.
Process Vent Control Option
All process vent streams associated waste materials
with volatile organic HAP concentration > 100 ppm or
HAP vapor pressure > 0.1 psia are assumed to be
vented to control device with a 95% organic emission
control efficiency.
Equipment Leaks Control Options
Organic control efficiency assigned to "NSPS" type
LDAR program is 70% to 75% depending on the form of
the waste stream.
Organic control efficiency assigned to "negotiated
rule" type LDAR program is 88%.
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TABLE 5-3.
ORGANIC EMISSION ESTIMATES
FOR BASELINE
Emission
Point
Type
Tanks
Containers
Land disposal units(a)
Process vents
Equipment leaks
TOTAL (b)
- Total -
Organic HAP
Emissions
(Mg/yr)
30, 900
2,530
420
310
270
34,430
- Total
voc
Emissions
(Mg/yr)
37,400
3, 060
510
370
330
41, 660
NOTES:
(a) For analysis, it is assumed that there is
no disposal of waste materials in surface
impoundments. All surface impoundments
are assumed to be converted to tanks.
(b) Total may differ from sum of individual
values due to rounding.
5-12
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TABLE 5-4. ORGANIC EMISSION ESTIMATES
FOR CONTROL OPTIONS
Emission
Point
Type
Tanks
Organic
Emission
Control
Level
Baseline
Option Tl
Option T2
Option T3
Total
Organic HAP
Emissions
(Mg/yr)
30, 900
12,200
2, 840
2,240
Total
VOC
Emissions
(Mg/yr)
37, 400
14, 800
3,440
2,710
Emission
- Point-
Type
Containers
Organic
Emission
-- Control -
Level
Baseline
Option Cl
Option C2
Total
Organic HAP
-- Emissions-
(Mg/yr)
2,530
2,530
890
Total
VOC
Emissions --
(Mg/yr)
3,060
3, 060
1, 080
-Emission
Point
Type
Land Disposal
Units
Organic
- Emission -
Control
Level
Baseline
Option LDl
Total
-Organic HAP
Emissions
(Mg/yr)
420
290
Total
- voc -
Emissions
(Mg/yr)
510
350
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TABLE 5-4.
{concluded)
Emission
Point
Type
Process Vents
-- Organic
Emission
Control
Level
Baseline
Option PV1
Total -
Organic HAP
Emissions
(Mg/yr)
310
310
- Total -
voc
Emissions
(Mg/yr)
370
370
Emission
Point
Type
Equipment Leaks
Organic
Emission
Control
Level
Baseline
Option ELI
Option EL2
Total
Organic HAP
Emissions
(Mg/yr) '
270
270
150
" Total "
voc
Emissions
(Mg/yr)
330
330
180
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6.0 OTHER ENVIRONMENTAL AND ENERGY IMPACTS ESTIMATES
This chapter presents estimates of the environmental
impacts other than organic emissions reduction and the energy
impacts associated with the control options selected in
Chapter 5 of this document for the off-site waste operations
source category. Section 6.1 identifies the types of other
environmental and energy impacts that may occur from
implementing the control options. A summary of the
methodology used to estimate these impacts is presented in
Section 6.2. Estimates are presented in Section 6.3 of the
control option secondary air impacts, water impacts, solid
waste impacts, and energy impacts.
6.1 IDENTIFICATION OF OTHER CONTROL OPTION IMPACTS
Implementation of the control options analyzed for the
off-site waste operations source category (refer to
Section 5.1 in this document) would require using a variety of
organic emission control techniques. Some of the control
options are based on equipment requirements (e.g.,
installation of a cover on a tank or container) or work
practices (e.g., facility workers conduct an equipment leak
detection and repair program) that reduce organic emissions
with essentially no other environmental or energy impacts.
For other control options, the types of organic emission
controls selected by the facility owner or operator may result
in other environmental impacts and have energy impacts.
6-1
-------
The primary source of other environmental and energy
impacts is expected to result from the operation of control
devices used to remove or destroy organics in captured vapor
streams. Electric motor-driven fans, blowers, or pumps,
depending on the type of control device, are used for
operations such as moving the captured organic vapors to the
control device, circulating cooling water through a condenser,
or pumping recovered liquids to an accumulation tank.
Generation of the electricity to operate the control device
often requires burning of fuel in an electric utility power
plant which produces air emissions, wastewater discharges, and
solid wastes. When carbon adsorption systems are used, the
organic HAP removed from the vapor stream are adsorbed on the
activated carbon in the control device. Once the carbon
becomes saturated with organics, it must be regenerated with
steam, or disposed of in a landfill. Producing regeneration
steam in a boiler creates both secondary air and energy
impacts. Disposal of the spent carbon produces a solid waste
impact.
The types of other environmental and energy impacts that
may occur from implementing each of the control options are
identified in the following subsections.
6.1.1 Tank Control Options
The first tank control option (Option Tl) requires the
installation of a cover on an open tank. The operation of a
cover does not require an energy source nor does it generate
gaseous, liquid, or solid wastes. Consequently, there are no
other environmental or energy impacts associated with
Option Tl. However, the other two tank control options
(Options T2 and T3) require certain tanks use floating roofs
or be vented to a control device. Consequently, other
environmental and energy impacts will occur for Options T2 and
T3 at those facilities where control devices are used to
implement the control option requirements.
6-2
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6.1.2 Container Control Options
Both of the control options for containers (Options Cl
and C2) require the use of covers. In addition, Option C2
requires the use of submerged fill pipes for loading certain
waste materials into containers. The operation of this
equipment does not require an energy source nor does it
generate gaseous, liquid, or solid wastes. Consequently,
there are no other environmental or energy impacts associated
with the container control options.
6.1.3 Land Disposal Units Control Option
The land disposal control option (Option LD1) limits the
management of waste materials in open land disposal units to
only those waste materials with a volatile organic HAP
concentration less than 100 ppmw. For the control option
analysis, the EPA assumes that facility owners and operators
will meet the control option requirements by pretreatment of
waste materials to reduce the volatile organic HAP
concentration to below 100 ppmw. Operation of pretreatment
processes produces other environmental and energy impacts.
6.1.4 Process Vent Control Option
The process vent control option (Option PV1) requires
that process vents with total organic HAP mass emissions equal
to or greater than 3 tons/yr be connected to a control device
with a 95 percent organic emission control efficiency. Other
environmental and energy impacts will occur for Option PV1 at
those facilities where control devices are used to implement
the control option requirements.
6.1.5 Equipment Leak Control Options
For equipment leaks, both of the control options
(Options ELI and EL2) are based on a LDAR program and
modification of certain equipment. A LDAR program is a work
practice. The equipment modifications do not require energy
to operate nor do they generate gaseous, liquid, or solid
6-3
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wastes. Consequently, there are no other environmental or
energy impacts associated with the equipment leak control
options.
6.2 SUMMARY OF IMPACT ESTIMATION METHODOLOGY
The general approach used to estimate the control option
other environmental and energy impacts for the off-site waste
operations source category follows the approach used to
estimate these types of impacts for the RCRA hazardous TSDF
air rules. This approach uses "control device operation
factors" based on the waste material throughput in controlled
units and "impact factors" based on the operating
characteristic of each control device. These factors are
described in further detail in Appendix C to this document.
There are different approaches that facility owners and
operators may choose to implement a control option as well as
different types of energy sources available at a particular
off-site waste operations facility. Consequently, upper and
lower boundary estimates for the "impact factors" were
developed using scenarios of differing fuel sources and spent
activated carbon management methods to estimate the potential
range of other environmental and energy impacts. The
assumptions used for the scenarios are summarized in
Table 6-1.
The "control device operation factors" and the "impact
factors" were developed for the waste management model units
and control options used for the RCRA TSDF air rules impact
analysis. The computer model developed to estimate organic
HAP emissions for the control options (refer to Appendix B to
this document) uses the same types of waste management model
unit air emission controls that were used to develop these
factors. Therefore, the application of these factors should
provide a reasonable order-of-magnitude estimate of the other
environmental and energy impacts for the off-site waste
operations source category control options.
6-4
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TABLE 6-1. SUMMARY OF ASSUMPTIONS USED FOR CONTROL OPTION
OTHER ENVIRONMENTAL AND ENERGY IMPACT ESTIMATES
Facility
Control. Equipment
Operating Conditions
Lower Boundary
Assumption
Upper Boundary
Assumption
I
Cn
Electricity
source
50% coal power plant
25% natural gas power plant
25% noncombustion utility
100% coal power plant
Steam
source
100% natural gas boiler
100% fuel oil boiler
Spent carbon
regeneration
yield
90% yield
80% yield
Spent carbon canister
management
practice
100% regenerated
100% landfill disposal
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6.3 IMPACT ESTIMATES
Other environmental and energy impact estimates are
presented for two tank control options (Option T2 and T3) and
the land disposal unit control option (Option LD1). As
discussed in Section 6.1 of this document, the EPA expects
that implementation of all of the container control options
(Options Cl and C2) and equipment leak control options
(Options El and E2) will reduce organic emissions with
essentially no other environmental or energy impacts.
Finally, because all process vents in the computer model data
base are assumed (at baseline) to already be vented to
existing control devices for compliance with the RCRA air
standards for TSDF process vents, no additional other
environmental or energy impacts are estimated for the process
vent control option (Option PV1).
6.3.1 Secondary Air Emission Impacts
The secondary air emission estimates for the control
options are presented in Table 6-2. The primary source of
secondary air emissions result from the generation of
electricity to operate the pretreatment units used to remove
organics from waste materials prior to land disposal.
6.3.2 Water Impacts
The water impact estimates for the control options are
presented in Table 6-3. The primary source of produced
wastewater is wet scrubbers used in conjunction with the
operation of thermal vapor incinerators.
6.3.3 Solid Waste Impacts
The solid waste impact estimates for the control options
are presented in Table 6-4. The primary source of generated
solid waste is associated with the electricity produced to
operate the land disposal pretreatment units. However, the
solid waste impact presented in Table 6-4 for the land
disposal control option (Option LD1) is likely to be offset by
the reduced quantity of waste material entering the land
disposal unit after pretreatment.
6-6
-------
TABLE 6-2. ESTIMATED RANGE OF SECONDARY AIR EMISSIONS
en
i
Air Pollutant
CO emissions
NOx emissions
SOx emissions
Particulate emissions
Air Emissions (Mg/yr)
Option T2
<1
2-7
<1 - 5
<1
Option T3
<1
3-12
<1 - 10
<1
Option LD1
4
50 - 86
31 - 83
2-4
Range of values presented in this table for each impact represents the
upper and lower boundary estimates of the impacts to reflect different
approaches owners and operators may choose to implement a control option as
well as different types of fuel sources available at a particular facility
location.
-------
TABLE 6-3. ESTIMATED RANGE OF WATER IMPACTS
en
i
CO
Wastewater Type
Power plant effluent
Carbon regeneration effluent
Incineration scrubber effluent
Total Wastewater Impacts
Wastewater Quantity (1,000 m3/yr)
Option T2
0
<1
0-19
<1 - 19
• Option T3
0
<1
0-33
<1 - 33
Option LD1
2-3
0
0
2-3
Range of values presented in this table for each impact represents the upper and
lower boundary estimates of the impacts to reflect different approaches owners
and operators may choose to implement a control option as well as different
types of fuel sources available at a particular facility location.
-------
TABLE 6-4. ESTIMATED RANGE OF SOLID WASTE IMPACTS
Solid Waste Type
Power plant fly & bottom ash
Power plant scrubber sludge
Spent activated carbon
Total Solid Waste Impacts
Solid Waste Quantity (Mg/yr)
Option T2
4-8
7-14
22 - 210
33 - 230
Option T3
7-14
12 - 23
35 - 340
54 - 380
Option LD1
620 - 1,240
980 - 1,960
0
1, 600 - 3,200
Range of values presented in this table for each impact represents the upper and
lower boundary estimates of the impacts to reflect different approaches owners
and operators may choose to implement a control option as well as different
types of fuel sources available at a particular facility location.
-------
6.3.4 Energy Impacts
Table 6-5 presents the energy impact estimates for the
control options that have other environmental impacts. The
energy impacts for the tank control options vary widely
depending on the assumptions used regarding the energy
requirements of the thermal vapor incinerator.
TABLE 6-5. ESTIMATED RANGE OF ENERGY IMPACTS
- Control
Option
Option T2
Option T3
Option LD1
- Energy
Consumption
~(1012 j/yr)~
20 - 5,300
38 - 8,900
310 - 400
Range of values presented in this table for each
impact represents the upper and lower boundary
estimates of the impacts to reflect different
approaches owners and operators may choose to
implement a control option as well as different
types of fuel sources available at a particular
facility location.
6-10
-------
7.0 ENHANCED MONITORING
Section 114(a)(3) of the 1990 Clean Air Act Amendments
require NESHAP to include monitoring strategies that
incorporate the concepts of enhanced monitoring. This
approach is intended to ensure that monitoring requirements
under a NESHAP provide data that can be used as a determinant
of compliance with each applicable standard, including
emission standards, in the rule.
Preferably, a continuous emission monitor (CEM) can be
used. In cases when a CEM is not technically feasible or
economically practicable, the EPA's approach is generally to
establish operating parameters that can be directly related to
emission control performance which must be continuously
monitored to determine if the control device remains in
compliance with the applicable emission standard. This
chapter describes application of enhanced monitoring to each
of the control options described in Chapter 5 of this
document.
7.1 ENHANCED MONITORING LEVELS
In general, four levels of enhanced monitoring can be
defined for organic HAP emission control technologies. These
four monitoring levels are:
Level 1. Continuous emission monitoring of the organic
HAP emission limit as defined by the standard
(i.e., control option).
Level 2. Continuous emission monitoring of a surrogate
of the organic HAP emission limit.
7-1
-------
Level 3. Continuous monitoring of an operating parameter
indicative of the performance of the control
device for reducing organic HAP emissions as
defined by the standard (i.e., control option).
Level 4. Continuous monitoring of an operating parameter
indicative of the performance of the control
device for a surrogate of the organic HAP
emission reduction.
The technical applicability of the enhanced monitoring
levels are dependent on the emission control technologies used
for each emission point type and the characteristics of the
waste streams managed in the controlled units. Due to the
nature of the off-site waste operations, the composition of
waste materials at a given site is expected to vary widely
from day-to-day or week-to-week. This variability in the
waste stream composition causes numerous difficulties with
continuous monitoring systems, especially systems designed to
analyze for specific HAP constituents. Therefore, continuous
emission monitoring of the organic HAP emission limit as
defined by a control option (monitoring Level 1) is not, in
most cases, technically applicable for control devices
operated at off-site waste operation facilities.
The enhanced monitoring levels are evaluated for each
emission point type control option, in order of decreasing
monitoring requirements (i.e., starting with Level 1 and
continuing to Level 4), to identify the enhanced monitoring
level appropriate for the control option. The following
sections provide additional explanation regarding the
selection of enhanced monitoring levels for each emission
point type control option.
7.2 ENHANCED MONITORING FOR TANKS
The emission control options for tank control Option Tl
are based on the use of covers. As using a cover is an
equipment requirement rather than a performance standard,
there are no enhanced monitoring alternatives for the tank
control Option Tl.
7-2
-------
Tank control Options T2 and T3 both require the
application of an additional emission control device for tanks
managing waste streams that exceed a certain vapor pressure
threshold. To comply with the control option, a owner or
operator will in most cases do two things: 1) install a
floating roof; and 2) vent the emissions to an external
control device that achieves a 95 percent emission reduction.
The use of a floating roof cover is again an equipment
standard rather than a performance control standard. As with
fixed roofs, there are no continuous or enhanced monitoring
alternatives for floating roof covers installed to comply with
tank control Options T2 and T3.
External control devices include flares, vapor
incinerators, condensers and carbon adsorption devices. With
the external control devices, it is possible to evaluate the
actual emission reduction performance of the device. Numerous
monitoring strategies can be applied for these units, some of
which are dependent on the actual device used. The strategies
outlined here do not attempt to distinguish the specific
operating parameters that could be used to monitor the
performance of each of these devices separately, but rather
the general monitoring strategies that can be applied to this
class of emission control devices.
For most external control devices, both the inlet and the
outlet streams are gaseous. This affords continuous sampling
of both the control device inlet and outlet streams. In this
discussion, very frequent (every 10 to 15 minutes) GC/MS
sampling and analysis of inlet and outlet gas streams is
considered "continuous" monitoring of HAP concentrations
(Level 1). However, as mentioned previously, fluctuations in
waste stream composition and flow rates, as well as the
operating characteristics of the analytical equipment used to
analyze for specific HAP constituents, will require pooling or
averaging of the monitoring data to limit false conclusions
from being made regarding the performance of the external
control device. Subsequently, a control device could operate
7-3
-------
inefficiently for 30 minutes or more before noncompliance is
validated. Additionally, for most off-site waste operations,
the frequent changes in the organic HAP composition of the
waste material being processed will require frequent
recalibration and tuning of the analytical equipment
associated with the continuous HAP emission monitor.
Consequently, continuous organic HAP emission monitoring
(Level 1) will not be technically applicable for most external
control devices used to control organic HAP emissions from
off-site waste operations.
Continuous monitoring of an indicator of total organics
for both the control device inlet and outlet streams (Level 2)
can easily be accomplished for gas streams using a flame
ionization detector (FID) or photo ionization detector (PID)
continuous emission monitor (CEM). Again, some pooling or
averaging methodology may be necessary to limit false
conclusions from being made regarding the performance of the
external control device, but because the FID or similar CEM
provides nearly instantaneous data, the time required to
validate noncompliance is much less for monitoring Level 2
than for monitoring Level 1. Depending on the pooling or
averaging methodology employed, which is dependent on the
variability in composition of the organic emissions entering
the control device, continuous monitoring of a surrogate of
organic HAP emissions in both inlet and outlet gas streams may
be used to document control device removal efficiency.
However, monitoring both inlet and outlet gas streams may not
provide the best or quickest method to identify inadequate
control device performance.
An alternative surrogate of organic HAP removal
efficiency that may be appropriate for certain external
control devices is the continuous emission monitoring of the
control device exhaust stream alone (Level 2). Although the
tank control options (Options T2 and T3) specify a required
control efficiency, an emission limit may be defined and
documented through an initial source test as a surrogate of
7-4
-------
control device performance. Monitoring the exhaust for an
emission limit minimizes the need to pool analytical results,
and streamlines the decision-making process in determining
whether the control device is operating in compliance with the
standard (i.e., control option).
Continuously monitoring process operating parameters
(flow rates, temperatures, etc.) that indicate acceptable
control device performance in terms of either organic HAP
removal efficiency (Level 3) or a surrogate of organic HAP
removal efficiency (Level 4) is both accurate and timely.
Both enhanced monitoring levels using operating parameters
(Levels 3 and 4) would require that an initial performance
test be conducted to determine that the emission control
device is reducing HAP emissions (or a surrogate of HAP
emissions) to the required limits while certain operating
conditions exist (flow rates, temperatures, etc.). The
organic HAP removal efficiency of a control device can change
significantly with the physical and chemical properties of
different HAP in the emission stream. For emissions that are
predominantly organic HAP (e.g., 70 percent organic HAP or
more) or have a consistent HAP composition, operating
parameters can be a good indicator of organic HAP removal
efficiency (Level 3). However, for emissions that contain a
significant proportion of non-HAP organics and that have a
wide variability in the organic HAP composition, operating
parameters cannot be directly linked with organic HAP removal
efficiency. In this case, the operating parameters provide a
better indication of total volatile organic compound removal
efficiency or other surrogate of organic HAP removal
efficiency (Level 4).
7-5
-------
7.3 ENHANCED MONITORING FOR CONTAINERS
The emission control options for containers (Cl and C2)
are based on the use of covers and, for Option C2, the use of
a submerged filling pipe for container loading operations. As
these control techniques are equipment requirements rather
than a performance standard, there are no enhanced monitoring
alternatives for the container controls options.
7.4 ENHANCED MONITORING FOR LAND DISPOSAL UNITS
The control option for land disposal (LD1) is based on
pretreatment of the waste materials to remove the volatile
organic HAP to below 100 ppmw prior to land disposal.
Consequently, a direct indicator of compliance would be to
monitor the HAP concentration of the effluent stream from the
treatment process. However, analytical techniques used to
measure organic HAP content or a surrogate of organic HAP in
solids require discrete sampling, and often timely sample
preparation prior to analysis. Therefore, continuous
monitoring of either organic HAP (Level 1) or a surrogate of
organic HAP (Level 2) is not technically feasible to document
continuous compliance with the land disposal control option.
Continuously monitoring process operating parameters
(flow rates, temperatures, etc.) that indicate acceptable
treatment device performance in terms of either organic HAP
removal efficiency (Level 3) or a surrogate of organic HAP
removal efficiency (Level 4) is both accurate and timely.
Both enhanced monitoring levels using operating parameters
(Levels 3 and 4) would require that an initial performance
test be conducted to determine that the treatment device is
reducing HAP concentration (or a surrogate of HAP
concentration) to the required limits while certain operating
conditions exist (flow rates, temperatures, etc.). The
organic HAP removal efficiency of a treatment device can
change significantly with the physical and chemical properties
of different HAP in the waste material. For waste materials
that are predominantly organic HAP (e.g., 70 percent organic
HAP or more) or have a consistent HAP composition, operating
7-6
-------
parameters can be a good indicator of organic HAP removal
efficiency (Level 3). However, for waste materials that
contain a significant proportion of non-HAP organics and that
have a wide variability in the organic HAP composition,
operating parameters cannot be directly linked with organic
HAP removal efficiency. In this case, the operating
parameters provide a better indication of total volatile
organic compound removal efficiency or other surrogate of
organic HAP removal efficiency (Level 4).
Emissions from the pretreatment system will be subject to
emission control requirements. Emission points from the
pretreatment system consist of emissions from tanks, process
vents, equipment leaks, and containers. Consequently,
appropriate enhanced monitoring levels for the pretreatment
system emissions are equivalent to the monitoring levels for
each of the applicable emission point categories.
7.5 ENHANCED MONITORING FOR PROCESS VENTS
The enhanced monitoring levels for process vents are the
same as the levels discussed in Section 7.2 of this chapter
for external control devices used to control tank emissions.
7.6 ENHANCED MONITORING FOR EQUIPMENT LEAKS
The control techniques proposed for equipment leaks
(Options ELI and EL2) are based on leak detection and repair
(LDAR) programs which include monitoring requirements. As
LDAR programs are work practices, there are no enhanced
monitoring alternatives for the equipment leak control
options.
7-7
-------
-------
.0 CONTROL OPTION COST ESTIMATES
This chapter presents estimates of the costs associated
with the control options selected in Chapter 5 of this
document for the off-site waste operations source category.
Section 8.1 defines the control cost parameters. A summary of
the methodology used to estimate these costs is presented in
Section 8.2. Estimates of the capital investment, the annual
operating costs, monitoring, inspection, recordkeeping, and
reporting (MIRR) costs, and the total annual costs for each of
the control options are presented in Section 8.3.
8.1 CONTROL OPTION COSTS
Costs are associated with the design, installation,
operation, and maintenance of the organic emission controls
required by each control option. Four different cost
parameters are estimated for each control option:
! Total capital investment (TCI)
! Annual operating costs (AOC)
! Monitoring, inspection, recordkeeping, and
reporting (MIRR) costs
! Total annual costs (TAC)
Total capital investment (TCI) is the total of the costs
required to purchase the equipment needed for the control
system, costs of labor and materials for installing that
equipment, costs for site preparation and buildings,
contractor fees, field expenses, start-up and performance test
costs, and contingencies.
8-1
-------
Annual operating cost (AOC) is the direct and indirect
operating costs incurred while operating the control system.
Direct operating costs include costs for raw materials,
utilities (steam, water, electricity), waste treatment and
disposal, maintenance materials, and operating, maintenance
and supervisory labor. Indirect operating costs include costs
for overhead, administration, property taxes, and insurance.
The AOC also includes any recovery credits for materials or
energy recovered by the control system which can be sold or
reused at the site.
Monitoring, inspection, recordkeeping, and reporting
(MIRR) costs are the costs incurred to ensure that the organic
emission controls that are installed to comply with the
control option requirements are properly operated and
maintained.
Total annual cost (TAG) is the sum of the AOC plus the
MIRR costs plus the capital recovery costs for the capital
investment. Capital recovery costs are a function of the
equipment service life and the interest rate used to annualize
the capital investments.
8.2 COST ESTIMATION METHODOLOGY
The total capital investment and the annual operating
costs for a control device are calculated using control cost
factors developed for a specific control option. Actual TCI
and AOC for an organic HAP emission controls were first
calculated using the methods outlined in the OAQPS Control
Cost Manual1 for various waste throughput (or equipment sizes)
and different waste characteristics. These costs were then
proportioned for the waste throughput (or size) distribution
of a waste management model unit to develop control cost
factors for each of the control options.
-------
The control cost factors used in the computer model to
estimate the costs of applying controls to the tanks,
containers, process vents, and equipment leaks emission point
types are based on the control cost factors developed for the
TSDF RCRA air standards projects.2 For the off-site waste
operations source category, each of the original cost factors
were adjusted to update the cost factor to mid-1991 dollars.
No control cost factors applicable to the land disposal
unit control option for the off-site waste operations source
category were developed for the TSDF RCRA air standards
projects. Consequently, new control cost factors were
developed for the land disposal unit control option.
Pretreatment processes potentially applicable for the
treatment of waste materials in accordance with the land
disposal control option include: steam stripping; air
stripping; thin-film evaporation; distillation; and
incineration. The pretreatment process employed by a facility
is dependent on the physical and chemical characteristics of
the waste material and the availability of excess treatment
capacity in existing treatment processes, if any. Total
capital investment and annual operating costs for pretreatment
of waste material using steam stripping were estimated using
the steam stripping cost algorithms developed for the
industrial wastewater CTG.3 Control cost factors were then
developed for pretreatment using steam stripping following the
same general methodology used to develop the control cost
factors for the TSDF RCRA air standards projects. Based on
the similarity in the complexity of the pretreatment process
equipment and analyzing the relative accuracy of the control
cost factors, the control cost factors developed for steam
stripping waste materials were deemed reasonable for
estimating the TCI and AOC control costs for all waste
material requiring pretreatment prior to land disposal.
-------
Monitoring, inspection, recordkeeping, and reporting
costs associated are not specifically included in the cost
factors used in the computer model. A separate cost analysis
external to the computer model was performed to estimate the
MIRR cost. This analysis is provided in Appendix E of this
document.
Further details regarding the control cost estimation
methodology are provided in Appendix D of this document and
Reference 4 to this chapter.
8.3 CONTROL OPTION COST ESTIMATES
Table 8-1 presents the total capital investment (TCI)
cost estimates calculated by the computer model for each
control option. Table 8-2 presents the annual operating cost
(AOC) estimates calculated by the computer model for each
control option. The results of the separate analysis of the
monitoring, inspection, recordkeeping, and reporting (MIRR)
costs are summarized in Table 8-3. Table 8-4 presents the
estimates for the total annual costs (TAG) for each control
option.
REFERENCES
U.S. Environmental Protection Agency. OAQPS Control Cost
Manual, 4th Edition, EPA 450/3-90-006. January 1990.
U.S. Environmental Protection Agency. Hazardous Waste
TSDF - Background for Proposed RCRA Air Emission
Standards. Publication No. EPA-450/3-89-023c. Office of
Air Quality Planning and Standards, Research Triangle
Park, NC. June 1991. pp. K-l through K-15.
U.S. Environmental Protection Agency. Control of
Volatile Organic Compound Emissions from Industrial
Wastewater. Guideline Series. Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
September 1992.
-------
TABLE 8-1. ESTIMATED TOTAL CAPITAL INVESTMENT (TCI!
FOR CONTROL OPTIONS
Emission
Point
Type
Tanks
Control
Opt Ton
Option Tl
Option T2
Option T3
TCI
"Cost
($1,000)
$3, 960
$27,400
$41, 300
Emission
Point
Type
Containers
Control
Option
Option Cl
Option C2
TCI
Cost '
($1,000) '
$0
$1, 960
Emission
Point
Type
Land disposal units
Control
Option
Option LD1
TCI
Cost
($1,000)
$3, 330
Emission
Point
Type
Process vents
Control
Option
Option PV1
TCI
Cost
. ($1,000) .
$0
Emission
Point
Type
Equipment
Leaks
Control
Option
Option ELI
Option EL2
TCI
Cost
($1,000)
$0
$5,260
-------
TABLE 8-2. ESTIMATED ANNUAL OPERATING COST (AOC)
FOR CONTROL OPTIONS
Emission
Point
Type
Tanks
Control
Opt Ton
Option Tl
Option T2
Option T3
"AOC
($l,000/yr)
$300
$8,200
$12, 800
Emission
Point
Type
Containers
Control
Option
Option Cl
Option C2
AOC
•($l,000'/yr)
$0
$100
Emission
Point
Type
Land disposal units
Control
Option
Option LD1
AOC
($1, 000/yr)
$700
Emission
Point
Type
Process vents
Control
Option
Option PV1
AOC
.($l,0007yr)
$0
Emission
Point
Type
Equipment
Leaks
Control
Option
Option ELI
Option EL2
"AOC
($l,000/yr)
$0
$340
-------
TABLE 8-3. ESTIMATED MONITORING, INSPECTION, REPORTING,
AND RECORDKEEPING (MIRR) COSTS
Emission
Point
Type
Tanks
Control
Opt Ton
Option Tl
Option T2
Option T3
Annual
"MIRR Costs
($l,000/yr)
$160
$1,730
$1, 950
Emission
Point
Type
Containers
Control
Option
Option Cl
Option C2
Annual
MIRR Costs
•($l,000'/yr)
$640
$640
Emission
Point
Type
Land disposal units
Control
Option
Option LD1
Annual
MIRR Costs
($1, 000/yr)
$160
Emission
Point
Type
Process vents
Control
Option
Option PV1
Annual
MIRR Costs
.($l,000/yr)
$320
Emission
Point
Type
Equipment
Leaks
Control
Option
Option ELI
Option EL2
Annual
"MIRR Costs
($l,000/yr)
$135
$135
-------
TABLE 8-4. ESTIMATED TOTAL ANNUAL COST (TAG)
FOR CONTROL OPTIONS
Emission
Point
Type
Tanks
Control
Opt Ton
Option Tl
Option T2
Option T3
Total
Annual "Cost
($l,000/yr)
$840
$13,700
$20,500
Emission
Point
Type
Containers
Control
Option
Option Cl
Option C2
Total
Annual Cost
($1,000) '
$640
$960
Emission
Point
Type
Land disposal units
Control
Option
Option LD1
Total
Annual Cost
($1, 000/yr)
$1,210
Emission
Point
Type
Process vents
Control
Option
Option PV1
Total
Annual Cost
.($l,000/yr)
$320
Emission
Point
Type
Equipment
Leaks
Control
Option
Option ELI
Option EL2
Total
Annual Cost
($l,000/yr)
$140
$1,220
-------
APPENDIX A
KEY DATES IN DEVELOPMENT OF BID
TABLE A-l. KEY DATES IN THE DEVELOPMENT OF THE BID
Date
Event
July 16, 1992
August 9-11, 1993
December 20, 1993
December 20, 1993
through
January 19, 1994
The EPA publishes initial list of
hazardous air pollutant (HAP) emission
source categories (57 FR 31576).
Representatives of the EPA and their
contractors conduct site visits of oil
and gas exploration and production (E&P)
waste management facilities in Kansas.
The EPA publishes an advanced notice of
proposed rulemaking (ANPR) to announce
EPA's intent to develop a NESHAP for the
off-site waste operations source
category (58 FR 66336) .
EPA public comment period on the ANPR.
A-l
-------
A-2
-------
APPENDIX B
IMPACTS ESTIMATION COMPUTER MODEL DESCRIPTION
The EPA adapted a computer model originally developed by
the Agency to estimate organic air emissions impacts from RCRA
hazardous waste treatment, storage, and disposal facilities
(TSDF) to estimate the emission of organic compounds, which
have been listed as hazardous air pollutants (HAP) under
section 112(b) of the 1990 Amendments to the Clean Air Act,
from those hazardous wastes TSDF nationwide that reported
receiving waste materials generated at other facilities. As
discussed in Chapter 2 of this BID, the EPA estimates that
approximately 90 percent of the current nationwide organic HAP
emissions from the off-site waste operations source category
occur at hazardous waste TSDF.
B.I INTRODUCTION TO THE DATA SOURCES
The major sources of waste data used for the computer
model analysis are the results from two comprehensive
nationwide surveys that the EPA Office of Solid Waste (OSW)
conducted in 1987: (1) the National Survey of Hazardous Waste
Generators4 (referred to hereafter as the "GENSUR"), and (2)
the National Survey of Hazardous Waste Treatment, Storage,
Disposal, and Recycling Facilities5 (referred to hereafter as
the "TSDR Survey"). These data represent waste quantities,
waste compositions, and waste management practices at TSDF in
1986 but are the most recent nationwide TSDF waste data
available to EPA on a consistent basis. A summary knowledge
of these two data bases is needed to understand the treatment
of the data as used to determine baseline emissions.
B-l
-------
The TSDR Survey is a nationwide survey of hazardous waste
TSDF conducted by OSW by sending a series of questionnaires to
TSDF owners and operators. One of the questionnaires
requested general facility information including the total
quantity of waste managed on-site, the quantity of waste
received from off-site, and the types of hazardous waste
management units operated at the facility in 1986. For each
hazardous waste management unit type identified, detailed
questionnaires were completed by the TSDF owner or operator
that provided process-specific information about the hazardous
waste management practices at that TSDF (refer to Table 1).
These questionnaires requested further detail regarding the
type of waste management process (e.g., batch distillation for
solvent recovery) and the quantity of waste managed in each
process unit, but no information was requested regarding
compositional analysis of these waste streams. Table 2 lists
the information reported by the TSDF owners and operators in
the process specific TSDR Survey questionnaires that is used
for the computer modeling analysis.
The GENSUR is a nationwide survey of hazardous waste
generators also conducted by OSW in 1987. The GENSUR
requested detailed compositional information about each of the
waste streams generated in 1986, and it requested some general
information regarding the on-site and off-site treatment,
storage, disposal, or recycling (TSDR) processes used to
manage each waste stream. Table 3 lists the information
reported by the waste generators in the GENSUR questionnaire
that is used for the computer model analysis.
The GENSUR database includes a sequential listing of the
waste management practices expected to be used by the off-site
facility (from question "GB19"). The GENSUR's off-site waste
management codes were basically the same as the general waste
management practices listed in Table 1 for TSDR Survey
Questionnaires "B" through "N". Presumably, the TSDF owner
B-2
-------
TABLE 1. TSDR SURVEY QUESTIONNAIRES
Questionnaire
Questionnaire A.
Questionnaire B.
Questionnaire C.
Questionnaire D.
Questionnaire E.
Questionnaire F.
Questionnaire G.
Questionnaire H.
Questionnaire I.a
Questionnaire J.
Questionnaire K.
Questionnaire L.
Questionnaire M.
Questionnaire N.
Questionnaire 0.
Subject
General facility information
Incineration
Reuse as fuel
Fuel blending
Solidif icat ion/ stabilization
Solvent and liquid organic recovery
for reuse
Metals recovery for reuse
Wastewater treatment
Other processes (treatment or
recovery)
Management in waste piles
Management in surface impoundments
Landfill disposal
Land treatment
Underground injection
Management in tanks
Data from Questionnaire I were not available due to the
format of this questionnaire. Information was available
as to whether the TSDF had a process of this type.
-------
TABLE 2. LIST OF INFORMATION USED FROM THE
TSDR SURVEY QUESTIONNAIRES
1. Facility identification number
2. Total quantity of waste managed by this general type of
waste management process
3. Number of process units in use at this facility for the
specified general type of waste management process
4. Process description code for each process unit
5. Total quantity of waste managed by each process unit
6. Quantity of waste received from off-site that was
managed by each process unit
7. Type of emission control device, if any, used for each
process unit
i-4
-------
TABLE 3. LIST OF INFORMATION USED FROM GENSUR
Question-
Number
GB1
GB2,GB3
GB4,GB5
GB6
GB18
GB19
GB25
GB26
Parameter Description-
(for each waste stream/facility combination)
Generator ID (RTI Survey and EPA ID number)
RCRA waste codes (can list up to 15)
Primary and secondary waste description codes
Primary and secondary waste source codes
SIC codes (can list up to 3)
Quantity of waste shipped off-site for management
Receiving facility ID (EPA ID number) and off-
site management codes
Concentration of targeted metals in waste
Constituent ID and concentration range for
hazardous constituents with highest
concentrations (top 10)
B-5
-------
and operator have better knowledge of which waste management
operations were used, but the TSDR Survey does not request
that the data regarding the process units be given in
sequential order. The TSDR Survey process-specific databases
offered: 1) more detail regarding the specific process units
used at the TSDF (e.g., batch distillation versus generic
solvent recovery); and 2) the only source of information
regarding the type of air emission controls, if any, used with
a particular waste management process.
B.2 IDENTIFYING FACILITIES THAT MANAGE OFF-SITE WASTES
An initial target list of facilities for the computer
modeling analysis was derived from the TSDR Survey. One of
the questions in the general facility questionnaire asked if
this facility managed any waste that was received from off-
site. Additionally, both the general and process-specific
TSDR Survey questionnaires asked a question regarding the
quantity of waste received from off-site that was managed at
the facility or in the specific process. The target list of
facilities for this modeling effort included all facilities
that indicated that they received waste from off-site by
either answering the direct question affirmatively or by
indicating a non-zero quantity of waste received from off-
site. Based on the TSDR Survey responses in 1986, there were
a total of 710 TSDF nationwide that managed waste received
from off-site waste generators.
This target list of 710 facilities that manage waste
received from off-site was then used to request information
from GENSUR. The information outlined in Table 3 was obtained
for each of the 710 target facilities that were included in
GENSUR Question GB19 as the off-site facility that the
hazardous waste was shipped to for treatment, storage,
disposal, or recycling.
Ideally, the database developed from the GENSUR
information request could be sorted by the off-site facility's
ID numbers so that the quantity of waste reported by the waste
B-6
-------
generator in the GENSUR to be shipped to a TSDF location
matches exactly the quantity of waste that the TSDF owner or
operator reported in the TSDR Survey receiving from off-site.
In reality, off-site quantities reported between TSDR Survey
and GENSUR often varied significantly. Reasons for the
disparity between the two data sets are outlined in Table 4.
The discrepancies between the TSDR Survey and GENSUR data
bases needed to be resolved because each of the data bases
contained useful but unique data. The GENSUR contained the
only compositional data available for the waste streams while
the TSDR Survey contained the only data available specifying
the type of waste management process used and whether an air
emission control device was used with each process.
Discussions with the coordinator of the TSDR Survey and GENSUR
indicated that the TSDR Survey data was more thoroughly
reviewed and is expected to be more accurate than the GENSUR
data. However, the survey coordinator also stated that the
survey respondents were more likely to under-report the amount
of hazardous waste that their facility generated or managed
than over-report their waste quantities. Consequently, a
facility quantity correction factor was developed to correlate
the quantities of off-site wastes managed by each facility as
reported in the TSDR Survey and GENSUR data. This facility
quantity correction factor is the ratio of the total waste
quantity received from off-site for a given facility as
reported in the TSDR Survey (numerator) and the total waste
quantity shipped off-site to a that facility as reported in
the GENSUR (denominator).
Approximately 80 percent of the total waste quantity
reported by waste generators in the GENSUR to be shipped off-
site can be matched with the TSDR Survey data for 464 specific
TSDF locations. For some of these TSDF locations, there is a
discrepancy between the waste quantity values reported in the
GENSUR and TSDR Survey. When this occurred, the larger of the
reported waste quantity values is used based on the
B-7
-------
TABLE 4. LIST OF POTENTIAL DISCREPANCIES BETWEEN
TSDR SURVEY AND GENSUR DATA
1. The GENSUR listed different off-site waste management
codes (i.e., different waste management processes) than
the TSDF facility actually used. This discrepancy
primarily affects the quantities of waste that a given
process type is assumed to manage.
2. Total quantities of wastes shipped by the generator are
accounted for differently by the receiving facility.
For example, a 55-gallon drum containing 20 gallons of
waste may be accounted for by the generator as
20 gallons of waste, but may be accounted for by the
receiving TSDF as one drum or 55 gallons. In this
case, the accounting difference could error in either
direction. Another possibility is that the generator
generates a nonhazardous waste, but the receiving
facility manages it as a hazardous waste. Presumably
the reverse situation should not occur. Consequently,
the TSDR Survey is expected to have slightly higher
waste quantities due to discrepancies in accounting
procedures.
3. Two or more receiving off-site facilities can be listed
in GENSUR question GB19 for a given waste stream.
GENSUR only provides information regarding the total
quantity of that waste stream, but it provides no
further breakdown of what fraction of the total
quantity of the waste stream went to each receiving
facility. It was assumed that the waste was equally
divided between the receiving facilities. This may
cause errors in the facility specific quantities, but
should not provide an overall bias.
4. At times, the generator indicated that waste was sent
off-site, but did not list an EPA ID Number for the
receiving facility. This made it impossible to match
all of the GENSUR quantities with a receiving facility.
Consequently, the TSDR Survey waste quantity reported
for a given facility are expected to be greater than
the GENSUR waste quantity for that facility.
5. The GENSUR was a survey that included the major
hazardous waste generators, but not all hazardous waste
generators. Therefore, the TSDR Survey waste
quantities are expected to be greater than the GENSUR
waste quantities.
-------
assumption that a survey respondent would not overstate the
hazardous waste quantity generated or managed at a facility.
Using the site-specific information on waste management
operations reported in the TSDR Survey and the organic HAP
composition data for the wastes managed at the facility as
reported in the GENSUR Survey, the computer model simulates
the waste management practices by emission point types at each
of the 464 TSDF locations.
For the remaining 20 percent of the total waste quantity
reported in the GENSUR, the specific TSDF locations where the
generators shipped this waste are not identified in the survey
responses. However, there are also 246 TSDF locations listed
in the TSDR Survey that reported receiving waste from off-site
waste generators, but were not specifically identified in the
GENSUR as a location to where waste generators shipped waste.
The total quantity of waste received from off-site waste
generators reported in the TSDR Survey for these 246 TSDF
locations is approximately the same as the total quantity of
waste reported in the GENSUR to be shipped off-site but for
which the specific TSDF location receiving the waste was not
identified. It is assumed that the waste data reported in the
GENSUR to be shipped off-site to unidentified TSDF locations
represent the waste managed at the 246 TSDF locations for
which the GENSUR data cannot be matched. Organic HAP
emissions for the "unmatched" GENSUR waste stream data (i.e.,
data for waste streams that were shipped to unidentified off-
site TSDF locations) were estimated by using the emission
fractions for the off-site waste management codes reported in
GENSUR for those waste streams. The organic HAP emissions
calculated by the computer model for these "unmatched" waste
steams are added together with the sum of the organic HAP
emissions calculated by the computer model for the 464
specific TSDF locations. This approach is considered to
provide a reasonable estimate of the total organic HAP
emissions from the management of hazardous waste received from
B-9
-------
off-site waste generators at all 710 of the TSDF listed in the
TSDR Survey.
Using this approach correlated the quantities reported in
the GENSUR with the quantities reported in the TSDR Survey on
a facility-specific basis. It did not, however, equate the
waste streams on a process-specific basis. To investigate the
differences in the quantities of waste managed by each type of
waste management process as reported in the TSDR Survey versus
as calculated in the computer model, a computer program was
written to summarize and compare the TSDR Survey and GENSUR
data on a facility- and process-specific basis.
Table 5 presents the nationwide totals for the quantities
of waste managed in each of the general types of waste
management process. Comparing the relative totals presented
in Table 5 shows that both TSDR Survey and GENSUR data exhibit
a similar distribution of the nationwide quantities of
hazardous waste by waste management process. However, the
waste quantities on a process-specific basis at any given
facility are, in some cases, very different.
B.3 DATA INPUT PREPARATION
In general, the main input database (filename
MAININP.DAT) for the computer model used the data as reported
in the GENSUR. However, two separate programs were written to
revise some of the input waste management codes and
constituent data. The first program (filename PRCODEON.BAS)
reads the off-site facility ID number and the off-site waste
management codes for each waste stream as reported in GENSUR.
The program then searches for that off-site facility ID number
in the corresponding process specific TSDR questionnaire
database. If the search is successful, the program then
replaces the GENSUR off-site waste management code with the
more specific TSDR on-site waste management code and returns
an indicator of the type of organic emission control device
used with the process ("0" for no control; "1" for 95%
control; "2" for 98% control; and "3" for 100% control).
B-10
-------
TABLE 5. TOTAL WASTE QUANTITIES BY PROCESS
FOR ALL FACILITIES
TSDR Survey Waste
Management
Process Type
Incineration
Reuse as Fuel
Fuel Blending
Fixation (S/S)
Solvent Recovery
Metals Recovery
Wastewater
Treatment
Waste Piles
Surface
Impoundment
Landfill
Land treatment
Underground
Inj ection
Other
Unknown
TOTAL QUANTITIES
Comparable
GENSUR
process
code
M01
M02
MOB
M04
M05
M06
M07,M09
(M16,M17)
Mil
M08,M12
M13
M14
M15
M10,M18
M19,None
TSDR Survey
Off-site
Quantity,
(Mg/yr) (1)
257,000
410, 000
521, 000
421, 000
479, 000
474, 000
14, 900, 000
381,000
3, 050, 000
2,250, 000
50,400
415, 000
532, 000
5, 040, 000
29,200, 000
GENSUR
Off-Site
Quantity
(Mg/yr) [1)
709,000
545, 000
498, 000
597, 000
708, 000
465, 000
11, 100, 000
(29, 800, 000)
30,000
4, 600, 000
3, 610, 000
115,000
527, 000
1, 150, 000
2,530,000
27,200, 000
(1) Quantities are calculated by process and may double
account some wastes at a given facility.
B-ll
-------
The second program (filename VOFLAG.BAS) was written
primarily to calculate the total volatile organic content, as
determined by Method 25D6, and the equilibrium partial
pressure (headspace organic concentration) for each waste
stream. These results are subsequently used to determine the
applicability of the RCRA Subpart AA7 and BB8 rules.
Additionally, this program was used to replace missing
constituent data with average constituent concentration data
based on RCRA waste code and waste form (waste source code)
information. The GENSUR database for the target facilities
was used to calculate average constituent concentrations for a
given RCRA waste code and waste form pair using the
ACEVOCC.BAS (filename) program. The output file from this
program was then sorted by constituent concentration for each
RCRA waste code and waste form. The resulting constituent
concentration database was then used to update certain missing
or unreadable data in the main input database.
There were two conditions for which the VOFLAG.BAS would
replace the original compositional data. The first condition
occurred when a readable constituent code was paired with a
non-readable concentration range code. In this case, the
average compositional database was used to replace the
concentration range code with the corresponding average
concentration, if found, for the specified RCRA waste code,
waste form, and constituent code. The second condition
occurred when both the constituent codes and the concentration
range codes contained no readable data (even after evaluating
the first condition) and the average compositional database
contained data for the specified RCRA waste code and waste
form pair. Under the second condition, data for the top ten
constituents with the highest concentrations were used to
replace both the constituent codes and concentration range
codes in the main input database. The total volatile organic
content and vapor pressure for the waste stream were then
evaluated using the revised constituent data.
B-12
-------
A third program (filename TOTHAP.BAS) used the revised
constituent data output from VOFLAG.BAS to calculate the total
organic HAP concentration, the total organic HAP concentration
using EPA Reference Method 25D9 recovery factors, and the
total organic HAP vapor pressure. These organic HAP
indicators were used to evaluate application of different
candidate control options.
B.4 ORGANIC HAP EMISSION ESTIMATION PROCEDURES
The computer model uses the waste stream specific data in
the GENSUR to calculate facility organic HAP emissions. Each
organic HAP compound is assigned a surrogate number according
to the volatility characteristics of the compound (i.e., based
on the compound's vapor pressure and Henry's Law constant).
The criteria used for the classification of surrogates is the
same surrogate criteria used for the source assessment model10
(SAM). Table 6 lists each of the organic HAP compounds, the
corresponding GENSUR "Y-code," and the assigned surrogate
number.
Waste management operations at each of the TSDF are
simulated based on the waste management process types defined
in the TSDR Survey. Organic HAP emission factors are assigned
to each waste management process type using one (or in many
cases, a combination of several) of the model units developed
for the TSDF RCRA air standards projects.11 Table 7 identifies
the model unit or the combination of model units used to
represent each waste management process type.
The organic HAP emission factors used for this analysis
are the same factors developed for the TSDF RCRA air standards
projects. However, because of the small number of biological
treatment processes actually in use at the TSDF included in
the data set used for this analysis, the emission fractions
developed for compounds of low biodegradability were used for
all HAP compounds in developing the baseline emission
estimate. Table 8 provides the aqueous surrogate emission
factors for each of the model units, and Table 9 provides the
B-13
-------
TABLE 6
ORGANIC HAP COMPOUND SURROGATE ASSIGNMENTS HAPS£
GENSUR
Y-code -
Y004
Y005
Y006
Y009
Y010
YOU
Y016
Y018
Y023
Y025
Y026
Y038
Y040
Y047
Y048
Y049
Y054
Y053
Y056
Y062
Y064
Y065
Y067
Y070
Y080
Organ! a HAP Compound -
Acetonitrile
Acetophenone
2-Acetylaminof luorene
Acrolein
Acrylamide
Acrylonitrile
Allyl chloride
4-Aminobiphenyl
Aniline
Antimony compounds'3
Arsenic compounds'3
Benzene
Benzidine
Benzotri chloride
Benzyl chloride
Beryllium compounds'3
Bis (2-ethylhexyl)phthalate
Bis (chloromethyl ) ether
Bromoform
Cadmium compounds'3
Calcium cyanide13
Carbon disulfide
Carbon tetrachloride
Chlordane
Chlorobenzene
Aqueous
. Surr . .#
4
3
4
3
6
3
1
1
4
0
0
1
6
1
2
0
5
2
2
0
0
1
1
3
1
Organic
-Surr . #.
2
3
6
1
5
1
1
6
3
0
0
2
6
4
3
0
6
2
3
0
3
1
1
6
2
B-14
-------
TABLE 6
ORGANIC HAP COMPOUND SURROGATE ASSIGNMENTS HAPS£
GENSUR
Y-code
Y081
Y085
Y086
Y090
Y092
Y098
Y100
Y108
Ylll
Y121
Y122
Y125
Y127
Y051
Y139
Y154
Y155
Y157
Y158
Y159
Y163
Y164
Y166
Y167
Organic HAP Compound
Chlorobenzilate
Chloroform
Chloromethyl methyl ether
Chloroprene (neoprene)
Chromium compounds'3
Cresols/Cresylic acid
(isomers and mixtures)
Cyanide Compounds'3
2,4-D (including salts and
esters )
DDE
1, 2-Dibromo-3-chloropropane
Dibutylphthalate
1, 4-Dichlorobenzene
3,3' -Dichlorobenzidine
Dichloroethyl ether
(Bis (2-chloroethyl) ether)
1, 3-Dichloropropene
3,3' -Dimethoxybenzidine
Dimethyl aminoazobenzene
3,3' -Dimethylbenzidine
Dimethylcarbamoyl chloride
1, 1-Dimehtylhydrazine
Dimethyl phthalate
Dimethyl sulfate
4, 6-Dinitro-o-cresol
(including salts)
2, 4-Dinitrophenol
Aqueous
Surr. #
6
1
6
1
0
3
6
1
1
3
5
1
3
3
1
1
2
2
1
2
4
5
3
5
Organic
Surr. #
6
1
1
1
0
2
6
6
6
4
6
3
6
3
2
6
6
4
3
1
5
4
6
4
B-15
-------
TABLE 6
ORGANIC HAP COMPOUND SURROGATE ASSIGNMENTS HAPS£
GENSUR
Y-code
Y168
Y143
Y173
Y083
Y181
Y182
Y186
Y187
Y189
Y190
Y191
Y192
Y201
Y204
Y206
Y207
Y208
Y211
Y215
Y217
Y226
Y230
Y231
Organic HAP Compound
2, 4-Dinitrotoluene
1 , 4-Dioxane
(1, 4-diethyleneoxide)
1, 2-Diphenylhydrazine
Epichlorohydrin
(l-chloro-2, 3-epoxypropane)
Ethylbenzene
Ethyl carbamate (urethane)
Ethylene dibromide
( 1, 2 -dibromo ethane)
Ethylene dichloride
( 1, 2-dichloroethane)
Ethyleneimine (aziridine)
Ethylene oxide
Ethylene thiourea
Ethylidene dichloride
(1, 1-dichloroethane)
Formaldehyde
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroe thane
Hydrazine
Hydrogen fluoride13
(hydrofluoric acid)
Lead compounds'"
Lindane
Maleic anhydride
Aqueous
Surr. #
4
3
6
1
1
3
2
1
4
2
2
1
3
1
1
1
1
1
5
0
0
5
6
Organic
Surr. #
6
2
6
2
2
4
2
2
1
1
6
1
1
6
4
4
5
4
2
0
0
6
6
B-16
-------
TABLE 6
ORGANIC HAP COMPOUND SURROGATE ASSIGNMENTS HAPS£
GENSUR
Y-code
Y236
Y238
Y241
Y242
Y243
Y245
Y250
Y252
Y253
Y254
Y255
Y257
Y247
Y249
Y264
Y269
Y275
Y280
Y281
Y290
Y287
Y293
Y302
Organic HAP Compound
Mercury compounds'"
Methanol
Methoxychlor
Methyl bromide (bromomethane)
Methyl chloride
(chlorome thane)
Methyl chloroform
(1, 1, 1-trichloroethane)
Methyl ethyl ketone
(2-butanone)
Methylhydrazine
Methyl iodide (iodomethane)
Methyl isobutyl ketone
(hexone)
Methyl isocyanate
Methyl methacrylate
4,4' -Methylenebis (2-chloro-
analine)
Methylene chloride
(dichloroe thane)
Naphthalene
Nickel compounds'3
Nitrobenzene
4-Nitrophenol
2-Nitropropane
N-Nitroso-N-methylurea
N-Nitrosodimethylamine
N-Nitrosomorpholine
Parathion
Aqueous
Surr. #
0
4
5
1
1
1
3
4
1
3
3
3
6
1
2
0
3
5
2
3
5
3
3
Organic
Surr. #
0
1
6
1
1
1
1
2
1
2
2
1
6
1
5
0
4
4
2
3
3
3
6
B-17
-------
TABLE 6
ORGANIC HAP COMPOUND SURROGATE ASSIGNMENTS HAPS£
GENSUR
Y-code
Y307
Y308
Y311
Y312
Y315
Y316
Y319
Y321
Y325
Y328
Y329
Y046
Y338
Y348
Y351
Y355
Y356
Y377
Y379
Y382
Y385
Y387
Y388
Organic HAP Compound
Pentachloronitrobenzene
Pentachlorophenol
Phenol
p-Phenylenediamine
Phosgene
Phosphine
Phthalic anhydride
Polychlorinated biphenyls
(Aroclors)
1,3-Propane sultone
Propylene dichloride
( 1, 2-dichloropropane)
1 , 2-Propylenimine
(2-methyl aziridine)
Quinone (benzoquinone)
Selenium compounds'3
Styrene
2,3,7 , 8-Tetrachlorodibenzo-p-
dioxin
1,1,2, 2-Tetrachloroethane
Tetrachloroethylene
(perchloroethylene)
Toluene
2, 4-Toluenediamine
2,4-Toluene diisocyanate
Toxaphene (chlorinated
camphene)
1,2, 4-Trichlorobenzene
1,1, 2-Trichloroethane
Aqueous
Surr. #
2
4
5
6
1
1
5
2
3
1
4
4
0
1
3
2
1
1
6
4
1
1
2
Organic
Surr. #
5
6
4
5
1
1
6
6
6
2
1
4
0
3
6
3
2
2
6
5
4
4
2
B-li
-------
TABLE 6
ORGANIC HAP COMPOUND SURROGATE ASSIGNMENTS HAPS£
GENSUR
Y-code
Y389
Y393
Y394
Y407
Y132
Y409
Organic HAP Compound
Trichloroethylene
2,4, 5-Trichlorophenol
2,4, 6-Trichlorophenol
Vinyl chloride
Vinylidene chloride
(1, 1-dichloroethylene)
Xylenes (isomers and mixtures)
Aqueous
Surr. #
1
3
3
1
1
1
Organic
Surr. #
2
6
6
1
1
3
The organic HAP compounds used for the computer model
were limited to the HAP compounds that were included in
the list of constituents in GENSUR Instructions:
Appendix D. All listed compounds are also volatile
organic HAPs unless otherwise indicated.
Compound is not a volatile organic HAP.
B-19
-------
TABLE 7. WASTE MANAGEMENT PROCESS MODEL UNIT CONFIGURATIONS
Waste Management
Process
Incineration
Reuse as fuel
Fuel blending
Waste fixation
Solvent recovery
(vented)
Solvent recovery
(non-vented)
Process
Code
11-111
& M01
1RF-13RF
& M02
1FB,M03
1S-7S
& M04
1SR-4SR &
8SR,M05
5SR-7SR
Organic HAP Emission Sources for
Waste Management _ Process3
! Storage/feed tanks
! Storage tanks
! Waste transfer operations
! Storage/blending tanks
! Waste/binder mixing tanks
! Batch distillation process
vents
! Waste transfer operations
! Storage tanks
! Waste transfer operations
! Storage tanks
Model Unit
Conf igurationb
2*CST
2*CST
TF
2*CST
ATT1
PV
TF
2*CST
TF
2*CST
dd
i
to
o
See notes at end of table.
-------
TABLE 7. WASTE MANAGEMENT PROCESS MODEL UNIT CONFIGURATIONS (continued)
Waste Management •
- Process
Metals recovery
Wastewater
Treatment
- Process
Code
1MR-5MR,
8MR, 10MR,
M06
6MR, 9MR
7MR
6WT-12WT
14WT-19WT
34WT-42WT
47WT-49WT
60WT-64WT
66WT
M07,M09
1WT
43WT-46WT
2WT-5WT
13WT
20WT-26WT
32WT, 50WT
51WT, 57WT
59WT, 65WT
Organic HAP Emission Sources for
-Waste Management - Process3
! Covered treatment tanks
! Open treatment tanks
! Evaporation ponds
! Open treatment tanks with no
mixing or biodegradation
! Aerated treatment tanks with
no biodegradation
! Covered treatment tanks
Model Unit -
- Conf igurationb
CTT
QOTT
DI
QOTT
ATT1
CTT
dd
i
to
See notes at end of table.
-------
TABLE 7. WASTE MANAGEMENT PROCESS MODEL UNIT CONFIGURATIONS (continued)
Waste Management
Process
Wastewater
(continued)
Other
Treatment
Waste Accumulation
and Storage in
Containers
Process
Code
27WT
28WT,29WT
30WT, 31WT
33WT
52WT-54WT
58WT
55WT
56WT,M08
1TR,M18
2TR,M10
1A, 1ST
Organic HAP Emission Sources for
Waste Management . Process3
! Steam/air stripping process
vents
! Aerated treatment tanks
! Steam/air stripping process
vents
! Covered storage tanks
! Evaporation pond
! Aerated biotreatment tanks
! Aerated biotreatment
impoundments
! Quiescent biotreatment
impoundment s
Treatment process vents
Storage tanks
Treatment process vents
Waste transfer operations
Storage tanks
! Waste transfer operations
Model Unit
Conf igurationb
PV
ATT1
PV
2*CST
DI
ATT2
ATI
QTI
PV
2*CST
PV
TF
2*CST
TF
dd
i
to
to
See notes at end of table,
-------
TABLE 7. WASTE MANAGEMENT PROCESS MODEL UNIT CONFIGURATIONS (continued)
Waste Management •
- Process
Waste Accumulation
and Storage in
Tanks
Waste Piled
Storage
Impoundment'1
Underground
Inj ection
Land Disposal6
Wastewater
Discharge
Unknown
- Process
Code
2A, 2ST
3ST,M11
4ST
5ST, 4D,M15
1D,M13
2D,M14
3D,M12
M16,M17
M19
Organic HAP Emission Sources for
-Waste Management - Process3
! Waste transfer operations
! Storage tanks
! Storage waste pile
! Storage surface impoundments
! Storage tanks
! Landfill
! Land treatment
! Disposal impoundments
! POTW and NPDES discharge
9
Model Unit -
- Conf igurationb
TF
Aq=QOSTc
Org=CSTc
WP
QSI
Aq=QOSTc
Org=CSTc
LF
LT
DI
not
modelled
2*CST
dd
i
to
CO
See notes at end of table.
-------
TABLE 7. WASTE MANAGEMENT PROCESS MODEL UNIT CONFIGURATIONS (concluded)
NOTES:
(a)
dd ro
i i
to to
(b)
2*CST
CTT
QOTT
ATT1
ATT2
DI
ATI
QTI
QSI
WP
LF
LT
PV
TF
(C)
(d)
All units are modelled to have equipment leak emissions.
Model Unit Key
= Two covered storage tanks operated in series
= Covered treatment tank
= Quiescent open treatment tank
= Aerated treatment tank with no biodegradation
= Aerated treatment tank with biodegradation
= Disposal impoundment
= Aerated treatment impoundment
= Quiescent treatment impoundment
= Quiescent storage impoundment
= Waste pile
= Landfill (open)
= Land treatment unit (with subsurface application)
= Process vent stack
= Splash loading of liquid wastes
Storage tanks for aqueous wastes (i.e., aqueous surrogates) are assumed to be
quiescent and open; storage tanks for organic wastes (surrogates) are assumed
to be covered.
These units are expected to be replaced by tanks. When including the land
disposal restrictions12 (LDR) in the baseline assumptions, the model unit
configuration for 5ST is used for these units.
LDR requires organic wastes to be pretreated prior to land disposal.
Therefore, when including LDR in the baseline assumptions, wastes are first
pretreated (pretreatment emissions are estimated using the model
configuration for 1SR-4SR); a 90 percent organic removal efficiency is
assumed, then the emissions associated with the land disposal unit is
estimated using the appropriate model unit configuration for that unit.
-------
TABLE
EMISSION FACTORS FOR AQUEOUS SURROGATES
Model
Unit'
ATT1
ATT2
ATT2
ATI
CST
2*CST
CTT
DI
QOST
QOTT
QTI
Description
Aerated treatment tank
w/no biodeg.
Aerated treatment tank
with low biodeg.3
Aerated treatment tank
with high biodeg. b
Aerated treatment
impoundment w/bio.a
Covered storage tank
Two covered storage
tanks in series
Covered treatment tank
Disposal impoundment
Quiescent open storage
tank
Quiescent open
treatment tank
Quiescent treatment
impoundment w/bio.a
~ Fracti
1
0.919
0.850
0.31
0.938
0.291
0.390
0.0581
1.00
0.671
0.100
0.446
on "emitted for specified aqueous surrogate
(kg HAP emit ted/ kg HAP entering unit)
2
0.667
0.610
0.086
0.865
0.0301
0.0593
6.42E-3
1.00
0.666
0.0981
0.442
3
0.202
0.182
0.0114
0.613
3.96E-3
7.88E-3
7.21E-4
1.00
0.618
0.0799
0.407
4
0.028
0.0256
0.0012
0.288
5.86E-4
1.16E-3
8.79E-5
1.00
0.368
0.0283
0.234
5
0.0029
2.87E-3
0.0
0.0700
9.79E-5
1.93E-4
1.21E-5
0.688
0.077
3. 64E-3
0.0460
6
2.0E-4
0.0
0.0
8.53E-3
1.80E-5
3.56E-5
1.90E-6
0.112
8.70E-3
3.26E-4
5.11E-3
(Continued)
-------
TABLE
EMISSION FACTORS FOR AQUEOUS SURROGATES (CONTINUED)
Model
Unit
WP
LF
LT
PV
TF
Description
Waste pile storage
Landfill (open)
Land treatment3 with
subsurface application
Process vents
Transfer
Fraction emitted for specified aqueous surrogate
"(kg" HAP" emitted/kg HAP entering unit)
1
0.177
0.841
0.998
0.030
0.326
2
0.0562
0.349
0.998
7.0E-3
0.0326
3
0.0179
0.110
0.996
2.5E-3
3.26E-3
4
5.62E-3
0.0350
0.979
l.OE-3
3.26E-4
5
1.67E-3
0.0107
0.708
l.OE-4
3.26E-5
6
3.95E-4
0.0034
0.231
0.0
3.26E-6
td
i
aEmission factors for these units are dependent on the biodegradability of
the HAP; the emission factors presented for these model units assume low
biorates for all HAPs at baseline.
bEmission factors for these units are dependent on the biodegradability of
the HAP; the emission factors presented for these model units assume high
biorates for all HAPs if specific performance standards are met.
-------
TABLE 9 ,
EMISSION FACTORS FOR ORGANIC SURROGATES
Model
Unit'
CST
2*CST
CTT
QOST
QOTT
QSI,DI
WP
LF
LT
PV
TF
Description
Covered storage tank
Two covered storage
tanks in series
Covered treatment tank
Quiescent open storage
tank
Quiescent open
treatment tank
Surface impoundment3
Waste pile storage
Landfill (open)
Land treatment1" with
subsurface application
Process vents
Transfer
Fracti
1
2.77E-3
5.53E-3
6.31E-4
0.9998
0.577
0.9998
0.0300
0.188
0.998
0.030
3.35E-3
on" emitted for specified organic "surrogate ~
(kg HAP emitted/kg HAP entering unit)
2
3.96E-4
7.92E-4
8.42E-5
0.890
0.131
0.890
0.109
0.068
0.993
7.0E-3
4.28E-4
3
5.01E-5
l.OOE-4
9.33E-6
0.268
0.0143
0.268
3.2E-3
0.021
0.943
2.5E-3
4.20E-5
4
7.26E-6
1.45E-5
1.12E-6
0.0319
1.40E-3
0.0319
1.2E-3
6.0E-3
0.445
l.OE-3
4.29E-6
5
1.20E-6
2.40E-6
1.52E-7
3.20E-3
1.45E-4
3.20E-3
2.0E-4
2.0E-3
0.0795
l.OE-4
4.29E-7
6
1.29E-8
2.58E-8
1.18E-9
5.34E-6
2.63E-7
5.34E-6
l.OE-5
l.OE-4
2.9E-3
0.0
0.78E-9
Cd
i
impoundments were not modeled for organic wastes; used emission factors for QOST.
bEmission factors for this unit is dependent on the biodegradability of the HAP;
the emission factors presented assume low biorates for all HAPs. Note: It is
assumed that all wastes processed in other biological units (ATT1, ATT2, ATI, or
QTI) are aqueous wastes; therefore, only aqueous surrogate emission factors apply.
-------
organic surrogate emission factors for each of the model
units. The equipment leak emission factors developed for the
TSDF RCRA air standards for equipment leaks were used in the
computer model.13 Table 10 summarizes the equipment leak
emission factors for each waste management code. [Note: Due
to the lack of data regarding the quantity of waste stored in
containers and typical storage times for wastes in containers,
no emission fractions were developed for container storage.
Consequently, emissions are not estimated for container
storage.]
A line input for the computer model contains data for one
off-site waste stream. For a given waste stream, constituent
codes and concentrations for up to 10 HAP and a waste
management sequence consisting of up to 10 process codes
(refer to Table 7) are input. The computer model calculates
the organic HAP emission estimates on a HAP-, emission point
type-, waste stream-, and waste management unit-specific
basis. There are six different emission point types: 1) non-
wastewater treatment tanks; 2) wastewater treatment tanks; 3)
containers; 4) land disposal units; 5) process vents; and
6) equipment leaks.
Emissions are calculated for the first waste management
unit for each individual HAP constituent for each emission
point type. The waste stream HAP concentrations are then
adjusted to reflect HAP removal (by treatment or emissions)
for that waste management unit before emissions are calculated
for the next waste management unit. After emissions are
calculated for all of the waste management units in the waste
management sequence for that waste stream, data for the next
waste stream are input. In this manner, emissions are
calculated for every waste stream managed by a given facility.
The facility emissions can then be stored in an output file,
and the program continues until emissions are calculated for
all of the facilities included in the input database.
-------
TABLE 10. EMISSION FRACTIONS FOR EQUIPMENT LEAKS
Process Code
11-111 & M01
1RF-13RF & M02
1FB & M03
1S-7S & M04
1SR-3SR, 8SR & M05
4SR
5SR-7SR
1MR-10MR & MO 6
1WT-26WT, 32WT,
34WT-42WT, 47WT-51WT,
59WT & M07,M09
27WT
28WT,29WT
30WT, 31WT, 33WT,
55WT-57WT, 4ST, 3D
& M08,M12
43WT-46WT,
52WT-54WT,58WT
60WTa
61WTa
62WTa
63WTa
64WTa
Emission Fraction
-(kg- HAP- emitted/kg HAP in waste)
Org. Surr . 1-3
& Aq. Surr. 1
1.69E-3
1.69E-3
6.60E-5
1.30E-5
9.79E-4
5.76E-4
6.60E-5
6. 60E-5
6.60E-5
3.10E-5
1.39E-4
9.00E-6
1.30E-5
A: 6.60E-5
0: 1.30E-5
A: 6.60E-5
0: 3.10E-5
A: 6.60E-5
0: 5.76E-4
A: 6.60E-5
0: 1.01E-3
A: 6.60E-5
0: 9.00E-6
Org. Surr. 4-6
& Aq. Surr. 2-6
5.75E-4
5.75E-4
2.24E-5
4.42E-6
3.33E-4
1.96E-4
2.24E-5
2.24E-5
2.24E-5
1.05E-5
4.73E-5
3.06E-6
4.42E-6
A: 2.24E-5
0: 4.42E-6
A: 2.24E-5
0: 1.05E-5
A: 2.24E-5
0: 1.96E-4
A: 2.24E-5
0: 3.44E-4
A: 2.24E-5
0: 3.06E-6
5-29
-------
TABLE 10. EMISSION FRACTIONS FOR EQUIPMENT LEAKS
65WTa
66WTa
1TR,2TR,2A, 2ST, 5ST
& M18,M19
1A, 1ST
3ST, lD,2Da
& M11,M13,M14
4D & M15
M10a
-(kg-
A:
0:
A:
0:
Emission Fraction
HAP- emitted/ kg HAP in waste)
6.60E-5
7.06E-4
6.60E-5
2.83E-3
1.01E-3
2.83E-3
A:
0:
1.30E-5
1.69E-3
9.00E-5
A:
0:
9.79E-4
6.60E-5
A:
0:
A:
0:
2.24E-5
2.40E-4
2.24E-5
9.61E-4
3.44E-4
9.61E-4
A:
0:
4.42E-6
5.75E-4
3.06E-5
A:
0:
3.33E-4
2.24E-5
aThese units have different equipment leak emission
fractions for aqueous and organic surrogates. Emission
fractions preceded by "A:" apply only to the aqueous
surrogate(s) in that column. Emission fractions preceded
by "0:" apply only to the organic surrogates
in that column.
B-30
-------
Figure 1 presents a general flow chart for the computer model
to show the calculation methodology algorithm logic.
The computer model maintains HAP-specific emission totals
for each emission point type on a facility-wide basis. The
computer model also maintains an overall HAP emission total
for each emission point type for all facilities (or waste
streams) represented by the computer model input data. These
overall emission point type HAP emission totals are then used
for comparing alternative control options. Note: the HAP
emissions totals for non-wastewater treatment tanks and
wastewater treatment tanks are summed together to yield the
total HAP emissions for the "tanks" emission point type.
B.5 COMPUTER MODEL BASELINE ASSUMPTIONS
For the purposes of evaluating the relative organic
emission reduction effectiveness of alternative control
options, the EPA defines a "baseline" as a reference point
from which each control option can be compared. The baseline
represents the estimated level of organic emissions from the
source category that would occur in the absence of
implementing any of the control options. For the off-site
waste operations source category, a baseline was chosen to
reflect the level of organic emissions for each emission point
type following implementation of air emission controls
required by federally enforceable air regulations in effective
as of July 1991. The following regulatory baseline
assumptions are used for the computer model:
(1) Existing Controls. Air emission controls
reported in the TSDR Survey to be installed on
a unit are assumed to be in operation.
(2) RCRA Air Standards for TSDF Process Vents
(40 CFR 264 subpart AA.) .14 Process vents on
processes listed in data base as distillation,
B-31
-------
solvent extraction, thin-film evaporation,
steam stripping, or air stripping and estimated
to have a total organic mass emissions equal to
or greater than 3 tons/yr are assumed to be
vented to a control device with a 95 percent
organic emission control efficiency.
;3) RCRA Air Standards for TSDF Equipment Leaks
(40 CFR 264 subpart BB) .15 Each waste stream
reported in the data base to have a total
organic concentration equal or greater than 10
percent is assumed to be controlled by
implementing a leak detection and repair (LDAR)
program which results in a 70 to 75 percent
organic emission reduction depending on the
waste materials type.
;4) RCRA Land Disposal Restrictions (40 CFR
part 268).16 All surface impoundments reported
in the data base to be used for disposal are
assumed to be replaced by landfills. Each
waste stream disposed in a land treatment unit
or landfill is assumed to be treated to meet
the LDR treatment standards prior to disposal.
;5) NESHAP for Benzene Waste Operations (40 CFR 61
subpart FF).17 Each waste stream reported in
the data base to have a benzene concentration
equal to or greater than 10 ppmw uses organic
emission controls as follows: (1) affected
non-wastewater streams managed in tanks are
vented to control devices with a 95 percent
organic emission control efficiency; (2)
affected wastewater streams are pre-treated by
-------
steam stripping to reduce the benzene
concentration to 10 ppmw or to the benzene
concentration corresponding to a 99 percent
removal of benzene, whichever value is higher;
(3) treatment processes handling affected waste
streams are vented to control devices with a 95
percent organic emission control efficiency;
and (4) transfer of affected waste streams into
containers is by submerged fill loading.
B.6 EMISSION CONTROL EFFICIENCIES FOR BASELINE ASSUMPTIONS
All existing control devices reported to be in place for
a given waste management process unit are assumed to be
operating effectively. Consequently, an appropriate emission
reduction factor (based on the type of emission control device
reported for that process unit) is applied to the
"uncontrolled" emission fraction for the emission point type
affected by the emission control device to calculate the
baseline emissions for all waste streams that are managed in
that process unit. Thermal control devices, which includes
flares and fume/vapor incinerators, were assigned a control
efficiency of 98 percent for all surrogate assignments.
Internal floating roofs, external floating roofs, condensers,
and carbon adsorption units were assigned a control efficiency
of 95 percent for all surrogate assignments.
The total organic concentration and the benzene
concentration is evaluated for each waste stream to determine
if one of the RCRA air standards or the Benzene Waste
Operations NESHAP apply for that waste stream. [Note: For
the computer model simulation, it is assumed that the action
level for identifying the waste streams required to use these
additional controls is based on the waste stream
characteristics at the point where the waste first enters the
TSDF site (i.e., at the facility entrance gate).] If the
waste stream concentrations exceed the action levels, an
B-33
-------
appropriate emission reduction factor is applied to the
appropriate emission point type "uncontrolled" emission
fraction for the affected units to calculate the baseline
emissions.
Control devices assumed to be installed on process vents
to comply with the RCRA air rules for process vents are
assumed to have a control efficiency of 95 percent. An LDAR
program implemented to comply with the RCRA air rules for
equipment leaks is assumed to achieve a 70 percent emission
reduction for aqueous Surrogate 1; a 75 percent emission
reduction for organic Surrogates 1, 2, and 3; and zero
reduction for all other surrogate assignments.
All waste streams in the data base are assumed to be
affected by the RCRA LDR. Consequently, organic HAP emissions
are estimated for waste streams originally managed in land
disposal units are reflective of the emission fractions for
the waste management model unit configuration sequence
expected to be in place due to the LDR (i.e., tanks used to
replace storage or treatment impoundments and pretreatment
tank sequence preceding land treatment units, disposal
impoundments or landfills). Table 11 presents the pre- and
post-LDR waste management model unit configuration sequences
used for the land disposal model process codes. Note,
baseline emissions from evaporation processes are modeled
using the emission fractions for disposal impoundments whether
the evaporation unit is a surface impoundment or a tank.
Replacing surface impoundments with tanks tends to reduce
the organic HAP emissions because tanks are generally have a
lower surface area to waste volume ratio and a lower residence
time. The emission reduction attributed to replacing a
surface impoundment with a tank is dependent on the relative
emission fractions of the surface impoundment and the tank
sequence used to replace the surface impoundment, and it
varies with the volatility (surrogate assignment) of the
organic HAP constituents in the waste material.
B-34
-------
TABLE 11. MODEL UNIT CONFIGURATIONS FOR PROCESSES AFFECTED
BY THE LAND DISPOSAL RESTRICTIONS18
Reported
Process
Code3"
55WT
56WT,M08
3ST,M11
1D,M13
2D,M14
3D,M12
Original Model Unit
"Configuration1^
ATIC
QTIC
WP
LF
LT
DI
Model Unit
Configuration
after LDRb -
ATT2C
QOTTC
Aq=QOSTd
Org=CSTd
Treat = PV, TF,2*CST
90% HAP reduction
then LF
Treat = PV, TF,2*CST
90% HAP reduction
then LF
Treat = PV, TF,2*CST
90% HAP reduction
then DI
aProcess codes as reported in the TSDR survey19 and GENSUR.20
bEmission factors for model unit configurations are provided in Table
Key to model unit configuration follows:
DI = Disposal impoundment
ATI = Aerated treatment impoundment
ATT2 = Aerated treatment tank with biodegradation
QTI = Quiescent treatment impoundment
QOTT = Quiescent open treatment tank
WP = Waste pile
LF = Landfill (open)
LT = Land treatment unit (with subsurface application)
2*CST = Two covered storage tanks operated in series
PV = Process vent stack
TF = Splash loading of liquid wastes
CA11 waste materials managed in these units are assumed to be aqueous
waste streams.
dStorage tanks for aqueous wastes (i.e., aqueous surrogates
assumed to be quiescent and open; storage tanks for organ:
(surrogates) are assumed to be covered.
are
organic wastes
B-35
-------
The organic removal efficiency of the pretreatment
sequence used in the baseline assumptions prior to land
disposal is assumed to be 90 percent for all organic HAPs in
the waste (i.e., all surrogate assignments). The emissions
from pretreatment units are estimated using the model
configuration for vented solvent recovery units (Process
Codes 1SR through 4SR as indicated in Table 7). The treated
waste stream (with one tenth the organic HAP concentration
that existed prior to pretreatment)is then disposed of as
originally indicated. Consequently, the land disposal unit
emissions are reduced by 90 percent for all surrogates, but
additional emissions occur from tanks, containers, and process
vents during the treatment process. The overall emission
reduction achieved by the pretreatment/land disposal unit
combination is dependent on the additional emissions that
occur from the pretreatment unit (which are, in turn,
dependent on the surrogate assignment for the specific HAP),
and it may be significantly less than 90 percent.
Control devices assumed to be installed on non-
wastewater treatment tanks and process vents used to comply
with the Benzene Waste Operations NESHAP are assumed to have a
control efficiency of 95 percent for all surrogate
assignments. The control efficiency for submerged fill during
container waste transfer to comply with the Benzene Waste
Operations NESHAP is assumed to be 65 percent for all
surrogate assignments.
The required emission control efficiencies for steam
strippers used for wastewater treatment to comply with the
Benzene Waste Operations NESHAP is dependent on the surrogate
assignment and may be limited by the control efficiency
required to reduce the benzene concentration to 10 ppmw. The
maximum control/removal efficiency for steam stripping for
each surrogate class is presented in Table 12. As seen in
Table 12, the organic HAP control (or removal) efficiency of a
steam stripping unit is dependent on the aqueous volatility of
B-36
-------
the organic HAP, (i.e., the aqueous surrogate assignment). If
the benzene concentration is 1,000 ppmw or more, the control
efficiencies in Table 12 are used directly. (Note: Benzene
has an aqueous surrogate assignment of 1, so that the benzene
removal efficiency of the steam stripper is 99 percent). If
the benzene concentration is less than 1,000 ppmw, the control
efficiencies presented in Table 12 are adjusted by a
correction factor to yield a benzene concentration leaving the
steam stripper of 10 ppmw. For example, if the benzene
concentration is 100 ppmw, the required steam stripper
efficiency for benzene is 90 percent. In this situation, the
steam stripper control efficiencies presented in Table 12 are
multiplied by 90 percent.
TABLE 12. STEAM STRIPPER FRACTION REMOVED BY SURROGATE CLASS
Surrogate
- Number
1
2
3
4
5
6
Henry's Law Constant
(atm-mViriGl)
3.16 x ID'3
3.16 x ID'4
3.16 x ID'5
3.16 x ID'6
3.16 x ID'7
3.16 x 1Q-8
Steam Stripper
Fraction Removed
0.99
0.98
0.94
0.63
0
0
5-37
-------
B.7 EMISSION CONTROL EFFICIENCIES FOR CONTROL OPTIONS
A specific subroutine was written to add additional
controls to each waste management unit/emission point type to
evaluate the impacts of alternative control options. The
impact of additional emission controls can be estimated for
any one or any combination of emission controls applied to the
six emission point types: 1) non-wastewater treatment tanks;
2) wastewater treatment tanks; 3) containers; 4) land disposal
units; 5) process vents; and 6) equipment leaks.
The control efficiency of applying a fixed roof cover to
an open tank depends on the surrogate assignment. The control
efficiency is calculated as: 1 minus the ratio of the
emission fraction for a covered tank to the emission fraction
for an open tank for that surrogate assignment. Covers are
applied to both non-wastewater treatment tanks and wastewater
treatment tanks for waste streams that exceed a selected VOHAP
concentration limit, with two exceptions. The first exception
is for enhanced biological treatment units (Process
Code 52WT). These biological treatment units are assumed to
meet specific performance standards and, as such, are not
required to apply controls. The second exception is for waste
streams that have been treated to remove or destroy the VOHAP
in the waste streams to lower the VOHAP concentration to below
the selected VOHAP concentration action level.
For enhanced biological treatment units that meet
specific performance standards (assumed to be all Process
Code 52WT units and only those units), additional credit for
biological removal of VOHAP is given. First, the emission
fractions used for Process Code 52WT's model unit
configuration (i.e., ATT2) are the emission fractions for the
aerated treatment tank with high biodegradability (see
Table 8). This reduces the emissions from this unit compared
to units where the low biodegradability emission factors are
used. Second, it is assumed that the overall VOHAP removal
efficiency of the unit, including removal by both
B-38
-------
volatilization and biodegradation, is 90 percent. This
assumption reduces the potential for VOHAP emissions in
downstream units.
For the purpose of the computer impacts model, it is
assumed that covers are not needed for tanks downstream of
wastewater steam and air strippers and enhanced biological
wastewater treatment units (Process Codes 27WT, 28WT, 29WT,
and 52WT). This assumption is based on the typical VOHAP
removal efficiencies of these units and the range of VOHAP
concentrations in the wastewater streams typically managed in
these units. Although there are other treatment units (e.g.,
incineration, distillation, and thin-film evaporation) that
may be as or more efficient in removing or destroying VOHAP,
the range of waste stream VOHAP concentrations in these units
is much higher than the waste stream VOHAP concentrations in
the wastewater treatment units. Consequently, even with
99 percent or more removal or destruction efficiencies, the
remaining VOHAP concentrations can still exceed the control
option's VOHAP concentration action level. As such, it is
assumed that tanks downstream of these other units do require
controls if the original VOHAP concentration of the waste
stream exceeds the selected VOHAP concentration action level.
Tank control options requiring additional control
devices, (e.g., floating roofs, thermal vapor incinerators,
condensers, and carbon adsorbers) are applied subsequent to
adding covers for open tanks. All of the additional control
devices are assumed to reduce covered tank emissions by
95 percent independent of the surrogate assignment.
The control options for containers include installing
leak-tight covers during container storage and employing
submerged fill pipes for waste transfer between containers.
As emissions are not estimated for container storage, the
computer model does not estimate the emission reduction
achieved by installing leak-tight covers on containers. The
control efficiency for submerged fill during container waste
B-39
-------
transfer is assumed to be 65 percent for all surrogate
assignments.
The HAP removal efficiency of the land disposal
pretreatment units are based on the removal efficiency needed
to reduce the VOHAP concentration to the selected VOHAP
concentration action level. All waste streams managed in land
disposal units are already assumed to be treated to comply
with the RCRA LDR. However, after the VOHAP concentration of
the waste stream is revised to account for the pretreatment
unit, some waste streams may still exceed different VOHAP
concentration action levels. The emission reduction
efficiency of the additional pretreatment unit and land
disposal unit is assumed to be equivalent to the HAP removal
efficiency required to meet the control option action level,
but is limited to (i.e., cannot exceed) 95 percent.
An LDAR program equivalent to the requirements of the
RCRA Subpart BB standard (except for the waste stream
concentration action level) is assumed to achieve a 70 percent
emission reduction for aqueous Surrogate 1; a 75 percent
emission reduction for organic Surrogates 1, 2, and 3; and
zero reduction for all other surrogate assignments. The
emission reduction achieved by an LDAR program equivalent to
the requirements of the NSPS standard is assumed to be
88 percent for aqueous Surrogate 1 and organic Surrogates 1,
2, and 3, and it is assumed to be zero for all other surrogate
assignments. Note, the control efficiencies of LDAR programs
are not additive. If a RCRA LDAR program is already assumed
to be in place to comply with the RCRA Subpart BB standard (as
in the baseline assumption), implementing an LDAR program
equivalent to the requirements of the NSPS standard only
produces a net emission reduction from baseline of 50 to
60 percent, so that the overall equipment leak emission
reduction from an uncontrolled state would be 88 percent.
B-4(
-------
B.8 CONCENTRATION ADJUSTMENTS FOR SEQUENTIAL UNITS
The organic HAP concentrations in the waste stream are
updated following each model waste management unit
configuration according to the HAP emissions from that
process. When emission controls are employed with the waste
management unit, the controls are classified as either a
suppression control or a reduction control. Suppression
controls inhibit the volatilization of the organic compounds
in the waste and include: submerged fill for container waste
transfer; adding a fixed roof or floating roof to a tank; or
implementing a leak detection and repair program for equipment
leaks. Reduction controls remove or destroy organic compounds
in the waste and include: flares; thermal incinerators;
condensers; and carbon adsorption systems. For suppression
controls, only the amount of HAP emitted from the controlled
unit is used to calculate the reduction in HAP concentration.
For reduction control, the amount of HAP that would have been
emitted from the unit if no controls were in-place is used to
calculate the reduction in HAP concentration (i.e., the HAPs
are still released from the waste, but they are collected or
destroyed rather than released to the atmosphere).
The HAP concentration entering the next waste management
unit configuration is also adjusted after processes that would
typically destroy or remove organic HAPs from waste stream.
Specifically, for thermal incinerators, reuse as fuel
processes, and solvent recovery units, it is assumed that
90 percent of the organic HAPs are removed from the waste
stream when updating the HAP concentrations for subsequent
waste management units.
B.8 REFERENCES
4. Office of Solid Waste. National Survey of Hazardous
Waste Generators. U.S. Environmental Protection Agency.
Washington, B.C. June 1987.
5. Office of Solid Waste. National Screening Survey of
Hazardous Waste Treatment, Storage, Disposal, and
Recycling Facilities. U.S. Environmental Protection
B-41
-------
Agency. Washington, B.C. June 1987.
6. Federal Register. Volume 56, No. 140. Method 25D -
Determination of the Volatile Organic Concentration of
Waste Samples. July 22, 1991. pp. 33544 through 33557.
7. Code of Federal Regulations. Title 40, Part 264.1030.
Air Emissions Standards for Process Vents. U.S.
Government Printing Office. Washington, B.C. July 1,
1992.
8. Code of Federal Regulations. Title 40, Part 264.1050.
Air Emission Standards for Equipment Leaks. U.S.
Printing Office. Washington, B.C. July 1, 1992.
9. Reference 3.
10. U.S. Environmental Protection Agency. Hazardous Waste
TSBF - Background Information for Proposed RCRA Air
Emission Standard. Publication No. EPA-450/3-89-023b.
Appendix B. Office of Air Quality Planning and Standards,
Research Triangle Park, NC. June 1991.
11. U.S. Environmental Protection Agency. Hazardous Waste
TSBF - Background Information for Proposed RCRA Air
Emission Standard. Publication No. EPA-450/3-89-023c.
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. June 1991.
12. Code of Federal Regulations. Title 40, Part 268. Land
Bisposal Restrictions. U.S. Government Printing Office.
Washington, B.C. July 1, 1992.
13. U.S. Environmental Protection Agency. Hazardous Waste
TSBF - Background Information for Promulgated Organic
Emission Standards for Process Vents and Equipment Leaks.
Publication No. EPA-450/3-89-009. Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
June 1990.
14. Code of Federal Regulations. Title 40, Part 264.1030.
Air Emission Standards for Process Vents. U.S.
Government Printing Office. Washington, B.C. July 1,
1992.
15. Code of Federal Regulations. Title 40, Part 264.1050.
Air Emission Standards for Equipment Leaks. U.S.
Government Printing Office. Washington, B.C. July 1,
1992.
16. Code of Federal Regulations. Title 40, Part 268. Land
Bisposal Restrictions. U.S. Government Printing Office.
Washington, B.C. July 1, 1992.
B-42
-------
17. Code of Federal Regulations. Title 40, Part 261.340.
National Emission Standards for Hazardous Air Pollutants
for Benzene Waste Operations. U.S. Government Printing
Office. Washington, B.C. July 1, 1992.
18. Reference 10.
19. Reference 2.
20. Reference 1.
B-43
-------
-------
APPENDIX C
OTHER ENVIRONMENTAL AND ENERGY IMPACTS
ESTIMATE METHODOLOGY
This appendix provides a description of the methodology
used to estimate the environmental impacts other than organic
emissions reduction and the energy impacts associated with the
control options selected in Chapter 5 of this document for the
off-site waste operations source category. Other
environmental and energy impacts were estimated for two tank
control options (Option T2 and T3) and the land disposal unit
control option (Option LD1). As discussed in section 6.1 of
this document, the EPA expects that implementation of all of
the container control options (Options Cl and C2) and
equipment leak control options (Options El and E2) will
reduce organic emissions with essentially no other
environmental or energy impacts. Because all process vents in
the computer model data base are assumed at baseline to
already be vented to existing control devices for compliance
with the RCRA air standards for TSDF process vents, no
additional other environmental or energy impacts were
estimated for the process vent control option (Option PV1).
C.I WASTE QUANTITY ESTIMATES FOR CONTROL OPTIONS
To estimate the other environmental and energy impacts
for a given control option, the quantity of off-site waste
material that is managed in waste operation units that require
controls due to each control option must first be calculated.
These quantities are calculated on a waste stream specific
basis by the computer model for each waste management model
C-l
-------
unit when estimating the organic HAP emissions for each
control option. Table C-l presents the annual quantity of
waste material that is managed in the different waste
management model units that are required to apply a
"95 percent control device" for the tank control options
(Options T2 and T3) and the annual quantity of waste material
that is treated prior to land disposal to comply with the land
disposal control option (Option LD1).
Tanks are used for a wide variety of waste management
processes. Consequently, the control device appropriate for a
given tank is dependent on: 1) the type of tank (storage or
treatment; quiescent or aerated); and 2) the form of the waste
material itself (aqueous or organic; sludge, solid or liquid).
For example, floating roofs can be used for storage tanks, but
only external control devices can be used for mixing tanks or
waste fixation tanks. Additionally, some applications of
carbon adsorption for organic emission control may allow the
use of carbon canisters system. A specific combination or
"mix" of control devices has been previously assumed in the
development of the control cost factors for each type of waste
management unit.1 This same "mix" of control devices, as
applied to each type of waste management model unit, is used
in the calculation to estimate the other environmental and
energy impacts. Table C-2 summarizes the "mix" of control
devices (Table C-2a) and pretreatment units (Table C-2b) that
are applied for each of the waste management model units
listed in Table C-l. As previously discussed, there are no
other environmental or energy impacts associated with floating
roofs employed to comply with the 95 percent control device
requirement.
For the land disposal control option (Option LD1), the
other environmental and energy impacts are caused by the
operation of the additional treatment unit used treat the
waste stream prior to land disposal. The type of treatment
unit used to treat this waste stream depends primarily on the
C-2
-------
TABLE C-l. QUANTITY OF WASTE MATERIAL MANAGED IN CONTROLLED UNITS
Emission Source
(Model Unit)
Single storage tanks (QOST/CST)
Series of storage tanks (2*CST)
Quiescent treatment tank (QOTT & CTT)
Aerated treatment tank (ATT1 & ATT2)
Fixation tank (ATT1)
Land disposal unit
Total Annual Waste Throughput in
Controlled Units (Mg/yr)
Option T2a
70, 825
1, 083, 813
425, 951
73, 126
52, 681
0
Option T3a
90, 450
1,736, 067
1,234, 631
216,773
69, 632
0
Option LDlb
0
0
0
0
0
168, 604
o
I
(a) Tank control options T2 and T3 require covering tanks and venting to a 95% efficient control
device or similar performing control technique (e.g., use of floating roof) if the organic HAP
vapor pressure > 0.75 psia and > 0.1 psia, respectively.
(b) Land disposal control option LD1 requires treatment of waste streams to reduce the volatile
organic HAP concentration to below 100 ppmw prior to land disposal.
-------
TABLE C-2a. PROPORTIONAL USE OF CONTROL DEVICES FOR TANKS
Emission Source
(Model Unit)
Single storage tank
(QOST/CST)
Series of storage
tanks (2*CST)
Quiescent treatment
tank (QOTT & CTT)
Aerated treatment
tank (ATT1 & ATT2)
Fixation tank
(ATT1)
% of Waste Throughput Controlled by
Control Device
Floating
roof
50
50
50
0
0
Fixed-bed
carbon
adsorber
8.5
16.8
24
100
100
Carbon
canister
16.5
8.2
1.0
0
0
Vapor
incin-
erator
25
25
25
0
0
TABLE C-2b. PROPORTIONAL USE OF PRETREATMENT FOR LAND
DISPOSAL
Emission Source
(Model Unit) -
Land disposal pretreatment
% of Waste Throughput Pretreated
using Treatment Unit
" Thin-film
evaporator
50
Solids
incinerator
50
C-4
-------
characteristics of the waste material, but may be influenced
by the types of treatment units that already exist at the
facility. For this analysis, it is assumed that 50 percent of
the waste material is treated using a thin-film evaporator and
50 percent of the waste material is treated in an incinerator
to remove the organic HAP (see Table C-2b).
C.2 CONTROL DEVICE OPERATION FACTORS
The control device operation factors for the waste
management model units and the pretreatment units are
summarized in Table C-3. Many of these factors were developed
for the RCRA TSDF air rules.2 Control device operation
factors for vapor incineration were developed and documented
in a technical report prepared for the EPA.3
Multiplying the quantity of waste material managed in
controlled units for a given control option (see Table C-l) by
the proportional use factors in Table C-2 and the control
device operation factors in Table C-3, yields the annual
amount of electricity and steam needed to operate the control
devices, the annual quantity of vapor incinerated, and annual
quantity of spent carbon generated for that control
option/waste management model unit combination. These annual
control device operation values are then summed for each of
the waste management model units for a given control option to
yield the total annual control device operation values.
Table C-4 provides a summary of the calculation methodology
and the intermediate results in calculating the total annual
control device operation quantity for tank control Option T3.
Table C-5 summarizes the total annual control device operation
values for each of the three control options that have
appreciable other environmental and energy impacts.
C.3 IMPACT FACTORS
Other environmental and energy impacts from applying the
control options are produced primarily from the generation of
electricity and steam required to operate the control devices
(i.e., the control device operation values reported in
C-5
-------
TABLE C-3. CONTROL DEVICE OPERATION FACTORS
Emission Source/
Control Strategy
Single storage
tank
Series of
storage tanks3
Quiescent
treatment tank
Aerated
treatment tank
Waste fixation
Thin-film
evaporation
Incineration
- Control Device Operation Factor -
(unit per Mg of waste material throughput)
Electricity
Demand
(Kwh~)
0.01
0.02
0.14
0.2
2.6
30
303
Steam-
Demand
• (kg of
steam)"
10
20
10
10
11.2
307
0
Vapor -
Incineration
(m3 of
" vapor) "
23
46
9
0
0
0
0
Fixed-Bed
Spent Carbon
(kg of
carbon)
0.01
0.02
0.01
0.01
0.1
0
0
Canister -
Spent Carbon
(kg of
" carbon)
1.1
2.2
0.3
0
0
0
0
o
I
Control device operation factors for series of two covered storage tanks calculated as: 2 x the
control device operation factor for single storage tank.
-------
TABLE C-4. CALCULATION METHODOLOGY FOR ANNUAL CONTROL DEVICE OPERATION VALUES
Emission Source/
Control Strategy
Single storage tank
Series of storage tanks
Quiescent trtmnt tank
Aerated treatment tank
Waste fixation
Thin-film evaporation
Incineration
TOTAL
(A)
Annual Waste
Throughput
(Mg/yr)
90,450
1,736,067
1,234,631
216,773
69,632
Of
Of
3,347,553
Annual
Electricity
Demand6
(MWh/yr)
0
17
87
43
182
0
0
329
Annual
Steam
Demand6
(Mg/yr)
77
5,816
2,995
2,168
780
0
0
11,834
Annual
Vapor
Incineration0
(m3/yr)
520,088
19,964,770
2,777,920
0
0
0
0
23,232,778
Annual
Fixed-Bed
Spent
Carbond
(Mg/yr)
0
6
3
2
7
0
0
18
Annual
Canister
Spent
Carbon6
(Mg/yr)
16
315
3
0
0
0
0
334
o
I
(a) A x [1 - (%floating roof/100)](Table C-2) x Electricity demand factorable C-3) -=- 1000 (i.e., the electricity
demand factor applies to all control devices except floating roofs)
(b) A x [(%fixed-bed + %steam stripping)/! 00](Table C-2) x Steam demand factor(Table C-3) -=- 1000
(c) A x [%vapor incineration/100](Table C-2) x Vapor incineration factor(Table C-3)
(d) A x [(%fixed-bed)/100](Table C-2) x Fixed-bed spent carbon demand factor (Table C-3) -=- 1000
(e) A x [(%carbon canister)/100](Table C-2) x Canister spent carbon demand factor(Table C-3) -=- 1000
(f) A = Quantity waste material treated prior to land disposal (Table C-1) x 0.5 (Table C-2b)
-------
TABLE C-5. SUMMARY OF ANNUAL CONTROL DEVICE OPERATION VALUES
. Control
Option
T2
T3
LD1
Annual
' Electricity
Demand
(MWh/yr)
193
329
28, 073
Annual
Steam
Demand
. (Mg/yr) .
6, 045
11,834
25, 881
Annual
' Vapor
Incineration
.(mVyr) .
13, 829,484
23,232,779
0
Annual
Fixed-Bed
Spent
Carbon
.(Mg/yr).
11
18
0
Annual
Canister
Spent
Carbon
(Mg/yr)
211
334
0
o
I
CO
-------
Table C-5). Certain secondary air pollutant emissions and
other environmental and energy impacts that occur from the
generation of electricity and steam are greatly affected by:
1) the type of fuel used in the boiler to produce steam (e.g.,
natural gas versus fuel oil); and 2) the type of power plant
generating the electricity supplied to the facility (e.g.
coal-fired, nuclear or hydroelectric). Similarly, the method
selected by a facility owner or operator to manage spent
activated carbon generated by a carbon adsorption emission
control device affects the other environmental and energy
impacts. Consequently, upper and lower boundary estimates for
the other environmental and energy impacts were developed
using scenarios of differing fuel sources and spent activated
carbon management methods to estimate the potential range of
other environmental and energy impacts. The boundary
assumptions used for this analysis are presented in Table C-6.
The assumptions summarized in Table C-6 are the same
boundary assumptions used to estimate the other environmental
and energy impacts for the RCRA air rules; consequently, the
other environmental and energy impact factors used for this
analysis are the same as those reported in the Hazardous Waste
TSDF BID.4 These other environmental and energy impact
factors were developed using fuel property and emission factor
values selected from the EPA document AP-42.5 Table C-7
presents a summary of these other environmental and energy
impact factors.
C.4 OTHER ENVIRONMENTAL AND ENERGY IMPACT ESTIMATES
The other impact environmental and energy impact factors
in Table C-7 multiplied by the control device operating values
in Table C-4 yield an estimate of the other environmental and
energy impacts for each of the control options selected for
model analysis that have appreciable other environmental and
energy impacts. Table C-8 presents the calculation results
for the other environmental and energy impacts using the lower
boundary conditions. Table C-9 presents the calculation
C-9
-------
TABLE C-6.
CONTROL DEVICE OPERATING CONDITIONS USED FOR
BOUNDARY ASSUMPTIONS
Control Device
Operating Condition
Electric utility
power plant mix
Steam boiler fuel
Carbon regeneration
yield
Spent carbon canister
management practice
Lower Boundary
Assumption
50% coal
25% natural gas
25% noncombustion
100% natural gas
90% yield
100% regenerated
Upper Boundary
Assumption
100% coal
100% fuel oil
80% yield
100% direct
landfill disposal
C-K
-------
TABLE C-7. IMPACT FACTORS FOR CONTROL DEVICE OPERATION VALUES
Control Device
Operation Parameter
(units)
Electricity Demand
(MWh)
Steam Demand
(Mg)
Vapor Incineration
: (m3) . ;
Fixed-Bed Spent Carbon
(Mg)
Canister Spent Carbon
" (M9) "
Boundary
Level
Estimate
Lower
Upper
Lower
Upper
Lower
Upper
Lower
Upper
Lower
Upper
Secondary Air Impact Factors
CO
Emissions
(Mg)
1.0E-4
1.1 E-4
4.4E-5
4.7E-5
0
0
0
0
0
0
NOx
Emissions
(Mg)
1.6E-3
2.9E-3
1.8E-4
1.9E-4
1.5E-5
3.7E-4
0
0
0
0
SOx
Emissions
(Mg)
1.1E-3
2.3E-3
8.0E-7
8.1 E-4
0
0
0
0
0
0
Particulate
Emissions
(Mg)
7.4E-5
1.4E-4
4.0E-6
1.9E-5
0
0
0
0
0
0
Energy
Impact
Factor (MJ)
8.2
11
3.0
3.0
0
0.38
0
0
0
0
o
I
(Continued)
-------
TABLE C-7.
[Concluded)
Control Device
Operation Parameter
(units)
Electricity Demand
(MWh)
Steam Demand
(Mg)
Vapor Incineration
(m3)
Fixed-Bed Spent Carbon
(Mg)
Canister Spent Carbon
(Mg)
Boundary
Level
Estimate
Lower
Upper
Lower
Upper
Lower
Upper
Lower
Upper
Lower
Upper
Water Impact Factors
Power
Plant
Effluent
(103m3)
5.9E-5
1.2E-4
0
0
0
0
0
0
0
0
Carbon
Regen.
Effluent
(103m3)
0
0
0
0
0
0
1.4E-3
1.4E-3
1.4E-3
0
Incin,
Scrubber
Effluent
(1 Q3 m3)
0
0
0
0
0
1.4
0
0
0
0
Solid Waste Impact Factors
Flyash &
Bottom
Ash
(Mg)
0.022
0.044
0
0
0
0
0
0
0
0
Scrubber
Sludge
(Mg)
0.035
0.070
0
0
0
0
0
0
0
0
Spent
Carbon
(Mg)
0
0
0
0
0
0
0.1
0.2
0.1
1.0
o
I
-------
TABLE C-8. CALCULATION RESULTS FOR LOWER BOUNDARY
OTHER ENVIRONMENTAL AND ENERGY IMPACTS
Lower Boundary
Impacts
Secondary Air Impacts, Mg/yr
CO emissions
NOx emissions
SOx emissions
Particulate emissions
Water Impacts, 1,000 m3/yr
Power plant effluent
Carbon regeneration effluent
Incineration scrubber effluent
Total Wastewater
Solid Waste Impacts, Mg/yr
Power plant fly & bottom ash
Power plant scrubber sludge
Spent Carbon
Total Solid Waste
Energy Impact, 1,000 MJ/yr
Total energy consumption
Control Option
T2
T3
LD1
0.3
1.6
0.2
0.0
0.6
3.0
0.4
0.0
4
50
31
2
0
0.3
0
0.3
0
0.5
0
0.5
1.7
0
0
1.7
4
7
22
33
7
12
35
54
620
980
0
1,600
20
38
310
C-13
-------
TABLE C-9. CALCULATION RESULTS FOR UPPER BOUNDARY NATIONWIDE
OTHER ENVIRONMENTAL AND ENERGY IMPACTS
Upper Boundary
Impacts
Secondary Air Impacts, Mg/yr
CO emissions
NOx emissions
SOx emissions
Paniculate emissions
Water Impacts, 1,000 m3/yr
Power plant effluent
Carbon regeneration effluent
Incineration scrubber effluent
Total Wastewater
Solid Waste Impacts, Mg/yr
Power plant fly & bottom ash
Power plant scrubber sludge
Spent Carbon
Total Solid Waste
Energy Impact, 1 ,000 MJ/yr
Total energy consumption
Control Option
T2
T3
LD1
0.3
7
5
0.1
0.6
12
10
0.3
4
86
83
4
0
0
19
19
0
0
33
33
3.4
0
0
3.4
8
14
213
235
14
23
338
375
1,240
1,960
0
3,200
5,300
8,900
400
C-14
-------
results for the other environmental and energy impacts using
the upper boundary conditions.
C.5 REFERENCES
1. U.S. Environmental Protection Agency. Hazardous Waste
TSDF - Background Information for Proposed RCRA Air
Emission Standards, Volume III, Appendix H.
EPA-450/3-89-023. June 1991.
2. Reference 4.
3. Research Triangle Institute. Vapor Incineration: Cross-
Media Environmental and Energy Impact Estimates.
Technical Note prepared for U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards.
Research Triangle Park, NC. EPA Contract No. 68-02-4326,
July 7, 1988.
4. Reference 4.
5. U.S. Environmental Protection Agency. Compilation of Air
Pollutant Emission Factors, 4th Edition. AP-42,
September 1985.
C-15
-------
-------
APPENDIX D
CONTROL COST ESTIMATION METHODOLOGY
This appendix provides a description of the methodology
used to estimate the costs associated with the control options
selected in Chapter 5 of this document for the off-site waste
operations source category.
D.I AIR EMISSION CONTROL COSTS
A computer model was developed to estimate the emission
of organic hazardous air pollutants (organic HAP) from the
management of hazardous waste materials at treatment, storage,
and disposal facilities (TSDF) nationwide subject to
regulation under RCRA subtitle C that receive waste from off-
site generators (refer to Appendix B of this document). This
computer model also calculates the costs associated with the
installation and operation of the organic HAP emission
controls required by each emission point type control option.
Three different costs parameters are calculated for each
control option: 1) total capital investment (TCI); 2) annual
operating cost (AOC); and 3) total annual cost (TAG).
The TCI is the total of the costs required to purchase
the equipment needed for the control system, costs of labor
and materials for installing that equipment, costs for site
preparation and buildings, contractor fees, field expenses,
start-up and performance test costs, and contingencies. The
AOC is the direct and indirect operating costs incurred while
operating the control system. Direct operating costs include
costs for raw materials, utilities (steam, water,
D-l
-------
electricity), waste treatment and disposal, maintenance
materials, and operating, maintenance and supervisory labor.
Indirect operating costs include costs for overhead,
administration, property taxes, and insurance. The AOC also
includes any recovery credits for materials or energy
recovered by the control system which can be sold or reused at
the site.
The total annual cost (TAG) is the AOC plus capital
recovery costs. The TAG is calculated from the TCI, the AOC,
the equipment life (n) and the annual interest rate (i) using
the following equation:
TAC = AOC + CRF x TCI (D.I)
where:
CRF = capital recovery factor = i(1 + i)V [ (1 + i) n-l] .
All total annual costs are calculated based on a 7 percent
interest rate (i = 0.07) to annualize the capital investments.
D.2 OVERVIEW OF COST ESTIMATION METHODOLOGY
In the computer model, the total capital investment and
the annual operating costs for a control device are calculated
using control cost factors developed for a specific control
option. Actual TCI and AOC for an organic HAP emission
control technique were first calculated using the methods
outlined in the OAQPS Control Cost Manual6 for various waste
throughput (or equipment size) and different waste
characteristics. These costs were then proportioned for the
waste throughput (or size) distribution of a waste management
model unit to develop control cost factors for each control
option.
This methodology has been used previously by the EPA for
the development of control cost factors used for the TSDF RCRA
air standards project.7 Control cost factors developed for
the TSDF RCRA air standards project were available for the
control options for the following emission point types: tanks
(both wastewater and non-wastewater tanks); containers;
D-2
-------
process vents; and equipment leaks. No control cost factors
were available for the land disposal emission point type
control option. Section D.3 provides the derivation of the
control cost factors used by the computer model to estimate
the control costs for pretreating waste material prior to land
disposal (following the general methodology used to develop
the control cost factors used for the TSDF RCRA air standards
proj ect) .
D.3 EXAMPLE COST FACTOR DERIVATION FOR LAND DISPOSAL UNITS
The methodology used to develop cost factors for a given
emission point type control option requires: 1) a size
distribution of the population for which costs are being
estimated; and 2) representative control costs for each size
class. One control option considered for land disposal units
is the use of a pretreatment process to remove the organic HAP
from the waste stream prior to management in open land
disposal units. Pretreatment processes potentially applicable
to remove volatile organic HAP from off-site waste material
include: steam stripping; air stripping; thin-film
evaporation; distillation; and incineration. For this control
option, "size distribution of the population" is based on the
annual quantity of off-site waste material managed in
landfills, and the "representative control costs" are based on
control costs associated with the installation and operation
of a steam stripper. Control costs for steam stripping are
used because: 1) control cost equations based on the quantity
of waste material processed are available for steam stripping;
2) similar control cost equations are not readily available
for other preatreatment processes; 3) the complexity of the
different pretreatment process equipment is relatively
comparable, and therefore, the equipment and operating costs
are assumed to be comparable.
The distribution of facilities that manage off-site waste
materials in landfills was determined from data reported in
the TSDR Survey.8 Of 710 facilities that receive waste from
D-3
-------
offsite, 63 facilities were identified that have landfills,
but only 44 facilities were identified that have landfills
that specifically manage waste materials received from
offsite. The annual quantity of off-site waste material
processed by these landfills was used to define four size
classes representative of the land disposal units operated at
TSDF. The number of facilities that operate landfills that
manage offsite waste materials for each of the size class,
based on data reported in the TSDR Survey, was used to
calculate size class distribution factors. The results of
this distribution analysis are summarized in Table D-l.
The control costs for steam stripping pretreatment were
calculated for each quantity range based on equations reported
in the draft Industrial Wastewater CTG for the total capital
investment (TCI) and the total annual cost (TAG) for steam
strippers.9 However, a similar equation for calculating the
annual operating cost (AOC) was not reported. The capital
recovery factor used in the draft Industrial Wastewater CTG
was 0.1315 (i.e., it was based on a 10 percent interest rate
and a 15 year equipment life) .10 Therefore, an equation to
estimate the annual operating cost (AOC) was developed from
the equations reported for total capital developed from the
equations reported for total capital investment (TCI) and
total annual costs (TAC) as follows:
AOC = TAC - 0.1315 x TCI. (D.2)
The control cost equations provided in the draft
Industrial Wastewater CTG were reported in July 1989 dollars.
However, all of the other cost factors used in the computer
model were developed in January 1986 dollars. Therefore, it
was convenient for modeling purposes to adjust the control
cost equations reported in the draft Industrial Wastewater CTG
to January 1986 dollars. The escalation factor for converting
the cost equations reported in July 1989 dollars to January
1986 dollars was calculated using the Chemical Engineering
composite plant index values.11 The composite index value for
D-4
-------
TABLE D-l. FACILITY DISTRIBUTION BASED ON THE QUANTITY
OF HAZARDOUS WASTE MATERIAL RECEIVED FROM OFF-SITE
FOR LAND DISPOSAL IN A LANDFILL3
Distribution
Size Class
Very Small
Small
Medium
Large
Wastewater Quantity (Q)
Range (tpy)
0 < Q < 10,000
10,000 < Q < 50,000
50,000 < Q < 200,000
Q > 200,000
Representative
Q (tpy)
10,000
22,000
100,000
447,000
Mo. of Facilities
in Size Class
21
11
9
3
Distribution
Factor
0.477
0.250
0.205
0.068
facility distribution obtained from data reported in the TSDR Survey.1
D-5
-------
July 1989 is 356.0; the composite index value for January 1986
is 323.5. Therefore, the cost equations in July 1989 dollars
were converted to January 1986 dollars by dividing the
July 1989 cost equations by the escalation factor of 1.10
(356/323.5).
Finally, the control cost equations, as reported in the
draft Industrial Wastewater CTG, were modified to calculate
the control costs as a function of the annual waste quantity,
Q, in tons per year (tpy) by assuming the density of the waste
material to be 1 kg/liter and that the pretreatment process
would run 24 hours/day x 300 days/year or 7,200 hrs/yr (this
is the annual operating hours used in developing the control
cost equations reported in the draft Industrial Wastewater
CTG). The resulting equations used to calculate the control
costs for steam stripping follow.
AOC(Jan. 1986 $/yr) = 37,550 + 1.010 x Q(tpy) (D.3)
TCI(Jan. 1986 $) = 217,860 + 1.601 x Q(tpy) (D.4)
The control cost equations reported in the draft
Industrial Wastewater CTG were developed for continuous steam
stripper systems with wastewater flow rates ranging from 10 to
200 gpm (this corresponds to annual waste quantities of 22,000
to 440,000 tpy).13 However, there were a significant number of
facilities (48 percent) that had annual quantities of off-site
waste material of less than 10,000 tpy (i.e, more than a
factor of 2 less than the low end of the quantity range for
which the control cost equations were developed). Efforts
were made to develop an alternative methodology to estimate
the control cost factors for the lowest waste quantity range
listed in Table D-l (Range 1). For example, batch processing
of wastewater in steam strippers, which may be more
appropriate these low flow rate systems, was investigated.
Unfortunately, the draft Industrial Wastewater CTG only
briefly discussed batch steam strippers, and it provided no
D-6
-------
cost equations for them.14 Instead, it was assumed that the
steam stripper used for lowest waste quantity range was
operated 12 hours/day x 5 days/week x 50 weeks/year, or
3,000 hrs/yr. Using this assumption, the steam stripper is
basically designed for approximately 2 times the average
annual flow rate (7,200 hrs/yr versus 3,000 hrs/yr).
Consequently, for waste quantity Range 1, the basic control
cost equation for TCI (Equation D.4) was revised based on
3,000 annual operating hours as follows:
TCI(Jan. 1986 $) = 217,860 + 3.842 x Q(tpy) (D.5)
A representative annual waste quantity of 10,000 tpy was
selected for Range 1 because it was closest to the quantity
range for which the control cost equations were developed.
Equation D.4 was used to estimate the TCI control costs for
waste quantity Ranges 2, 3 and 4; Equation D.5 was used to
estimate the TCI control costs for waste quantity Range 1.
Although there are increased operating costs during
operation for the larger steam stripper and waste material
throughput for Range 1, these costs are offset by the reduced
total operating hours. That is, the annual operating costs
are expected to remain constant with the average annual
throughput. Consequently, Equation D.3 was used to estimate
the annual operating costs for all waste quantity ranges.
Tables D-2 and D-3 illustrate the derivation of the
overall TCI and AOC cost factors that were developed for steam
stripping as a pretreatment control device used to remove
volatile organic HAPs from waste materials prior to land
disposal. Consistent with the Industrial Wastewater CTG, the
equipment life for the steam stripper was assumed to be
15 years.15
D.4 SUMMARY OF COST FACTORS USED FOR MODEL ANALYSIS
Using this methodology, overall control cost factors were
developed to estimate the costs of applying controls to the
tanks, containers, land disposal units, process vents, and
D-7
-------
TABLE D-2. STEAM STRIPPER TOTAL CAPITAL INVESTMENT (TCI) COST FACTORS
Size Class
Number
1
2
3
4
Rep. Q
(Mq/yr)
9,090
20,400
90,900
406,000
TCI
($/yr)
256,300a
253,100b
378,000b
933,500b
$/Mq
28.20
12.41
4.16
2.30
Distribution
Factor
0.477
0.250
0.205
0.068
Overall TCI Cost Factor:
TCI Cost
Factor ($/Mg)
13.45
3.10
0.85
0.16
$17.56/Mg
Calculated using Equation D.5
Calculated using Equation D.4
TABLE D-3. STEAM STRIPPER ANNUAL OPERATING COST (AOC) COST FACTORS
Size Class
Number
1
2
3
4
Rep. Q
(Mq/yr)
9,090
20,400
90,900
406,000
AOC
($/yr)
47,600a
59,800a
138,600a
489,000a
$/Mq
5.24
2.93
1.52
1.20
Distribution
Factor
0.477
0.250
0.205
0.068
Overall AOC Cost Factor:
AOC Cost
Factor ($/Mq)
2.50
0.73
0.31
0.08
$3.62/Mq
"Calculated using Equation D.3
D-i
-------
equipment leaks emission point types.16 Different cost factors
were developed for each of the different waste management
model units used in the computer model (refer to Appendix B
for further information regarding the waste management model
units) based on the "form" of the waste stream [i.e., 1) VOC-
containing solids; 2) aqueous sludges and slurries; 3) dilute
aqueous mixtures; 4) organic liquids; 5) organic sludges and
solids; and 6) other mixtures (includes 2-phase
organic/aqueous mixtures)]. Waste form codes were assigned
according to the waste description code reported for the waste
stream.17
In the previous example for the development of cost
factors for control options based on pretreatment using steam
stripping, the control costs are largely driven by the amount
of steam required to heat the waste material. As the heat
capacity of the different waste forms that are typiclly
managed in land disposal units are expected to be similar, the
cost factors presented in Tables D-2 and D-3 were used for all
waste forms. However, some control costs do vary with the
form of waste processed in the waste management model unit.
Table D-4 presents the overall control cost factors that are
used as input to the computer model for each emission point
type, waste management model unit control option, and waste
form.
D.5 CALCULATION OF CONTROL COSTS
The control costs are calculated by the computer model at
the same time organic HAP emissions are calculated.
Therefore, as with the emission calculations, the control
costs are calculated on an emission point type, waste stream,
and waste management unit-specific basis. At this lowest
level, the control costs are escalated to mid-1991 (July 1991)
dollars. As all the control cost factors are in January 1986
dollars, a single escalation factor is used to inflate the
control costs to mid-1991 dollars. The Chemical Engineering
composite plant index value for July 1991 is 362.8; the
D-9
-------
TABLE D-4. SUMMARY OF COST FACTORS USED IN MODEL ANALYSIS'
- Emission point type - Waste --
Management Model Unit Control
Option6
Tanks
Fixed-roof for QOST
Fixed-roof for QOST
95% CD for QOST
95% CD for QOST
95% CD for CST
95% CD for CST
95% CD for CST
95% CD for CST
95% CD for 2*CST
95% CD for 2*CST
95% CD for 2*CST
95% CD for 2*CST
95% CD for 2*CST
95% CD for 2*CST
95% CD for CTT
95% CD for CTT
95% CD for CTT
95% CD for CTT
95% CD for CTT
95% CD for CTT
Fixed-roof for ATT1
95% CD for ATT1 (non-fixation)
95% CD for ATT1 (fixation)
Fixed-roof for QOTT
Waste
Form0
TCI Cost
Factor
($/Mg)
AOC Cost
Factor
($/Mg)
- Equip. -
Life
(yr)
2
3
2
3
1
4
5
6
1
2
3
4
5
6
1
2
3
4
5
6
all
all
all
all
14.66
18.47
20.98
27.66
9.74
12.36
11.08
10.74
14.47d
14.47d
19.07d
18.32d
16.02d
15.80d
0.22
0.22
0.82
0.36
0.36
0.80
0.39
0.42
12.03
0.39
1.07
1.36
3.98
10.50
3.29
4.72
5.71
4.78
3.50d
3.50d
9.70d
4.98d
5.93d
5.00d
0.10
0.10
0.37
0.25
0.27
0.36
0.032
0.30
3.72
0.032
20
20
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
20
10
20
20
D-10
-------
TABLE D-4. SUMMARY OF COST FACTORS USED IN MODEL ANALYSIS"
Emission point type - Waste
-Management Model Unit Control
Option13
95% CD for QOTT
95% CD for QOTT
95% CD for QOTT
95% CD for QOTT
95% CD for QOTT
95% CD for QOTT
Containers
Submerged fill
Submerged fill
Submerged fill
Submerged fill
Submerged fill
Submerged fill
Land Disposal
Pretreatment6
Process Vents
95% CD for process vents
Equipment Leaksr
LDAR program for QOST
LDAR program for CST
LDAR program for 2* CST
LDAR program for CTT
LDAR program for ATT1 (fix)
LDAR program for QOTT
LDAR program for ATT1 &2
- Waste -
Form0
1
2
3
4
5
6
1
2
3
4
5
6
all
all
all
all
all
all
all
all
all
TCI Cost
- Factor
($/Mg)
0.57
0.57
1.16
0.71
0.80
1.16
0.75
0.75
0.92
0.94
0.78
0.79
17.56
25.90
1.28
1.28
2.569
0.083
0.016
0.083
0.016
AOC Cost
- Factor -
($/Mg)
0.13
0.13
0.39
0.28
0.30
0.39
0.04
0.04
0.05
0.05
0.04
0.04
3.62
9.38
0.34
0.34
0.679
0.022
0.004
0.022
0.004
Equip.
- Life -
(yr)
10
10
10
10
10
10
15
15
15
15
15
15
15
10
10
10
10
10
10
10
10
D-ll
-------
TABLE D-4. SUMMARY OF COST FACTORS USED IN MODEL ANALYSIS3
Emission point type - Waste
-Management Model Unit Control
Option13
LDAR program for SI
LDAR program for containers
- Waste -
Forrrf
all
all
TCI Cost
-- Factor
($/Mg)
0.011
3.57
AOC Cost
- Factor -
($/Mg)
0.003
0.94
Equip.
Life
(F)
10
10
NOTES:
a All cost factors are in January 1986 dollars.
b Legend for waste management model unit control options:
QOST = quiescent open storage tank
CST = covered storage tank
2*CST = series of two covered storage tanks
CTT = covered treatment tank
ATT1(fix) = waste fixation "aerated" treatment tank
LDAR = leak detection and repair
QOTT = quiescent open treatment tank
ATT1&2 = aerated treatment tank (with or without biodegradation)
SI = surface impoundment (storage or treatment)
c Key for waste forms:
1 = VOC-containing solids
2 = Aqueous sludge/slurry
3 = Dilute aqueous
4 = Organic liquid
5 = Organic sludge/slurry
6 = Other (2-phase)
d Control costs for 2*CST model tanks were calculated as the control costs for a single
CST plus the cost of venting a second CST to an existing control device.
D-12
-------
TABLE D-4. SUMMARY OF COST FACTORS USED IN MODEL ANALYSIS
NOTES (Continued):
e Land disposal pretreatment techniques are expected to vary widely. Assumed total
capital investment and annual operating costs of purchasing and operating a
pretreatment process are similar to the capital investment and operting cost associated
with steam stripping. Therefore, used cost factors developed for steam stripping for all
pretreatment processes.
f Due to the nature of control costs for equipment leaks, a facility implementing a LDAR
program will incur certain costs which are not a function of the quantity of waste (e.g.,
include a one time purchase of a portable VO meter). Consequently, a facility that has
to implement a LDAR program, a fixed TCI of $6,318 is added (one time) to the TCI
calculated using the TCI equipment leak cost factor. Additionally, a fixed AOC of
$918/yr is added (one time) to the AOC calculated using the AOC equipment leak cost
factor.
9 Control costs for equipment leaks for 2*CST model units were estimated to be twice the
equipment leak control costs for a single CST.
D-13
-------
composite index value for January 1986 is 323.5.18 Therefore,
the escalation factor of 1.1215 (362.8/323.5). Once the waste
stream/waste management unit TCI and AOC are converted to mid-
1991 dollars, the TAG is calculated using Equation D.I using a
7 percent interest rate.
The control costs (TCI, AOC, and TAC) for a given
emission point type, waste stream, and process unit is
calculated by multiplying the appropriate control cost factor
for a given waste management model unit (from Table D-4) times
the waste stream quantity and the escalation factor (1.1215).
The control costs for that waste stream/process unit are
calculated by totalling the individual emission point type
control costs. The total control costs for the waste stream
is calculated as the sum of the waste stream/process unit
control costs for all the waste management model units in
which that waste material is managed. The facility control
costs are calculated by summing the waste stream control costs
for all of the waste streams managed by a given facility.
Finally, the facility control costs are totalled for all
facilities included in the database to calculate the total
control costs used for comparing alternative control options.
The control costs are accounted for in two different
ways: 1) by emission point type for direct evaluation of
control options; and 2) by process or "service" type for
subsequent evaluation of economic impacts. Control costs by
emission point type are calculated for six different types:
1) non-wastewater treatment tanks; 2) wastewater treatment
tanks; 3) containers; 4) land disposal units; 5) process
vents; and 6) equipment leaks. The emission point type
control costs are calculated at the emission point type/waste
stream/process unit level. Control costs by process type are
calculated for 12 different process types (refer to Table D-
5). The process type control costs are calculated at the
waste stream/process unit level.
D-14
-------
TABLE D-5. WASTE MANAGEMENT PROCESS TYPE ASSIGNMENTS
Process
Type
1
2
3
4
5
6
7
8
9
10
11
12
Waste Management
Process
Incineration
Reuse as fuel
Fuel blending
Waste fixation
Solvent recovery
Metals recovery
Wastewater treatment
Land disposal
Underground Injection
Other treatment
Storage /unknown
Discharge only
Process
Code3
11-111, M01
1RF-13RF,M02
1FB,M03
1S-7S,M04
1SR-8SR,M05
1MR-10MR,M06
1WT-66WT,M07-M09
3ST-5ST, 1D-3D,M11-M14
4D,M15
1TR,2TR,M10
1A, 2A, 1ST, 2ST, Ml 8, Ml 9
M16,M17
^Process codes as defined and used in the survey database.
19
D-15
-------
D.6 REFERENCES
6. U.S. Environmental Protection Agency. OAQPS Control Cost
Manual, 4th Edition, EPA 450/3-90-006. January 1990.
7. U.S. Environmental Protection Agency. Hazardous Waste
TSDF - Background for Proposed RCRA Air Emission
Standards. Publication No. EPA-450/3-89-023c. Office of
Air Quality Planning and Standards, Research Triangle
Park, NC. June 1991. pp. K-l through K-15.
8. U.S. Environmental Protection Agency. National Survey of
Hazardous Waste Treatment, Storage, Disposal, and
Recycling Facilities. OMB No. 2050-0070. June 1988.
Questions H21c and H21d.
9. U.S. Environmental Protection Agency. Control of
Volatile Organic Compound Emissions from Industrial
Wastewater, September 1992. pp. 5-11 and 5-15.
10. Reference 5. p. 5-13.
11. Vatavuk, William M., "Cost Escalation." Technical paper
prepared for the U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. March
1993.
12. Reference 3. Questions H21c and H21d.
13. Reference 5. p. 5-8.
14. Reference 5. p. 4-4.
15. Reference 5. p. 5-13.
16. Reference 2. pp. K-l through K-15.
17. U.S. Environmental Protection Agency. National Survey of
Hazardous Waste Generators. OMB No. 2050-0075.
November 1989. Question GB2.
18. Reference 7. pp. 12 and 13.
19. U.S. Environmental Protection Agency. National Survey of
Hazardous Waste Generators - Instructions. OMB No. 2050-
0075. November 1989. Appendix A, pp. A-2 and A-3.
D-16
-------
APPENDIX E
COST ESTIMATION METHODOLOGY FOR MONITORING,
INSPECTIONS, RECORDKEEPING AND REPORTING
The purpose of this appendix is to document the
methodology used to estimate the costs associated with
monitoring, inspections, recordkeeping, and reporting (MIRR)
for the control options selected for consideration for the
off-site waste operations source category. The MIRR costs are
estimated only for the hazardous waste TSDF included in the
computer model data base (i.e., refer to Appendix B of this
document).
E.I OVERVIEW OF COST METHODOLOGY
For the off-site waste operations source category control
options, the costs of the associated with the MIRR
requirements are driven by the labor required to perform the
MIRR. The man-hours needed to perform MIRR for a single
emission source and control option combination are estimated.
Data obtained from the National Survey of Hazardous Waste
Treatment, Storage, Disposal, and Recycling Facilities1
(hereon referred to as the "TSDR Survey") are used to
characterize the number of emission sources within each
emission point type defined for the off-site waste operations
source category that would be required to apply controls for
E-l
-------
that control option. Annual MIRR costs are then calculated
based on the number of man-hours per emission source times the
number of emission sources times the labor costs associated
with the MIRR requirements for that emission source and
control option combination.
The labor costs used to calculate the annual MIRR costs
are derived from the operating and supervisory labor costs
reported in the OAQPS Control Cost Manual.2 The operating
labor cost, as reported in the OAQPS Control Cost Manual in
"1988 dollars," is $12.96/hr.3 As recommended in the OAOPS
Control Cost Manual, the supervisory labor costs are estimated
to be 15 percent of the operating labor costs,4 and an
overhead rate of 60 percent was used on the operating and
supervisory costs5 to calculate an overall labor cost per hour
(in 1988 dollars) as follows: [$12.96 + (0.15 x $12.96)] x
1.60 = $23.85/hr. Since all of the control costs are in July
1991 dollars, the labor costs are escalated to July 1991
dollars, using the Chemical Engineering (CE) Plant Index
values. The average CE Plant Index value for 1988 is 342.5;
the CE Plan Index value for July 1991 is 362.8.6 Therefore,
the escalation factor is 362.8/342.5 or 1.059, and the overall
labor rate used in estimating MIRR costs is $23.85 x 1.059 =
$25.26/hr (in July 1991 dollars). This labor rate is used for
estimating the MIRR costs for each emission point type and
control option combination.
E.2 MIRR COSTS FOR TANK CONTROL OPTIONS
Based on the information collected in the TSDR Survey,
there are 8,510 tanks at the 710 facilities that manage
hazardous wastes received from off-site. Almost 80 percent of
these tanks already have some type of cover according to the
data obtained from the TSDR Survey.
Tank control Option Tl requires use of a fixed-roof cover
for tanks managing wastes with volatile organic HAP
concentrations equal to or greater than 100 ppmw. From the
baseline emission estimates, 83 percent of the facilities that
E-2
-------
accept off-site waste materials have organic HAP emissions
from tanks. Although not every tank at these facilities are
expected to manage waste materials that contain organic HAP,
it was assumed that 83 percent of the tanks (7,063 tanks)
would be required to have fixed-roofs for the purpose of
estimating MIRR costs.
It was assumed that the monitoring and inspections would
be performed semi-annually and that these monitoring and
inspections would take 15 minutes per tank. Semi-annual
recordkeeping for the monitoring and inspections was assumed
to require 5 minutes per tank, and that annual reporting would
require 15 minutes per tank. Therefore, just under 1 labor
hour [(15/60 x 2) + (15/60 x 1) + (5/60 x 2) = 0.92] is
required annually per tank for all MIRR activities, resulting
in an annual cost of $23.24 per tank (0.92 hours/tank/yr x
$25.26/hr) and a nationwide annual cost of $164,000 (7,063
tanks x $23.24/tank/yr). Table 1 summarizes these assumptions
and the calculation methodology. This basic calculation
methodology is used for estimating the monitoring costs for
each control option.
Tank control Options T2 and T3 require that a 95 percent
efficient emission control device in addition to fixed-roof
covers for tanks managing certain waste streams. The number
of tanks requiring additional controls under control
Options T2 and T3 could not be directly evaluated, but the
total number of facilities that were required to apply
additional controls on tanks could be evaluated from the
computer model used to estimate the emissions from the
hazardous waste TSDF. For tank control Option T2, 70 percent
of the facilities were required to have apply additional
controls on at least one tank. For tank control Option T3,
80 percent of the facilities were required to have apply
additional controls on at least one tank. As stated
previously, not every tank at these facilities are expected to
require additional organic emission controls. However, for
the purpose of estimating MIRR costs, the proportion of
E-3
-------
facilities requiring additional controls was used to estimate
the number of tanks that would be required to apply additional
controls. Consequently, 5,960 tanks were assumed to require
TABLE 1. MONITORING, INSPECTIONS, RECORDKEEPING, AND
REPORTING COSTS FOR
TANK CONTROL OPTION Tl
Item
1) QAPPa
2) Performance Test
3) Inspections
4) Monitoring
5) Reporting
6) Recordkeeping
(A)
Labor Required
{time/occurrence)
0
0
15 min.
(included in A3)
15 min.
5 min.
(B)
Frequency
(occurrences/yr)
0
0
2
(included in B3)
1
2
7) Annual labor hours per emission source (£ C1 through
C6)
8) Annual cost per emission source ($25.26 x C7)
9) Total number of emission sources
10) Total annual MIRR cost (C8 x C9)
(C = A x B)
Annual Labor
(hrs/yr)
0
0
0.50
(included in C3)
0.25
0.17
0.92
$23.24
7,063
$164,000
aQAPP = quality assurance program plan
E-4
-------
additional controls for tank control Option T2, and
6,810 tanks were assumed to require additional controls for
tank control Option T3. These assumptions are expected to be
an upper bound for the tank control options' annual MIRR cost
estimates.
TSDF owners and operators can choose to use floating
roofs instead of external control devices to comply with tank
control Options T2 and T3. The cost factors used to estimate
the control costs for these options assumed that 50 percent of
the tanks would employ an external control device and
50 percent of the tanks would employ a floating roof.
Consequently, separate (subtotal) monitoring costs are
estimated for each of the different approaches used to comply
with the rule. Table 2 presents the assumptions used to
estimate time requirements and per tank monitoring costs for
both floating roofs and external control devices. Table 3
completes the calculation methodology and presents the total
monitoring costs for both tank control Options T2 and T3.
E.3 MIRR COSTS FOR CONTAINER CONTROL OPTIONS
According to the data in the TSDR Survey for the 710
hazardous waste TSDF, a total of 626 facilities used
containers for the accumulation and/or storage of hazardous
materials. As data are no available on the total number of
containers used for storing or transferring off-site waste
material at the hazardous waste TSDF, the MIRR costs are based
on the estimated number of container storage areas. Assuming
that each facility has, on average, two areas designated for
container storage/accumulation, inspections (monitoring) will
be required at approximately 1,250 container storage areas.
For both container control Option Cl and C2, every container
storage area is assumed to be inspected on a monthly basis,
and that the time needed to perform the inspections is the
same for both container control options. Based on a monthly
inspection frequency, the annual MIRR costs for the container
control options (Options Cl and C2) are presented in Table 4.
E-5
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TABLE 2. MONITORING, INSPECTIONS, RECORDKEEPING AND
REPORTING COSTS FACTORS FOR
ADDITIONAL CONTROL DEVICES USED FOR TANKS
Control Device/
Item
(A)
Labor Required
(time/occurrence)
(B)
Frequency
(occurrences/yr)
(C = A x B)
Annual Labor
(hrs/yr)
Tank with floating roof (FR)
1) QAPPa
2) Performance Test0
3) Inspections
4) Monitoring
5) Reporting
6) Recordkeeping
2 hr
4 hr
15 min.
0
15 min.
5 min.
0.5b
0.5b
2
0
1
2
7) Annual labor hours per tank w/FR (£ C1 through C6)
8) Annual cost per tank w/FR ($25.26 x C7)
1
2
0.50
0
0.25
0.17
3.92
$99
Tank with external control device (Ext. CD)d
9) QAPPa
10) Performance Test
11) Inspections
12) Monitoring
13) Reporting
14) Recordkeeping
2
6
30 min.
1 min.
30 min.
1 min.
0.5b
0.5b
4
365
1
365
15) Annual labor hours per tank w/Ext. CD (£ C1 thru C6)
16) Annual cost per tank w/Ext. CD ($25.26 x C7)
1
3
2
6.1
0.5
6.1
18.7
$472
aQAPP = Quality assurance project plan.
bAn occurrence of 0.5/yr is used for tests that would be conducted on
a one time only basis or less frequently than once per year.
cPerformance test for floating roofs are gap measurements.
dEstimates assume two tanks are controlled per control device on
average.
E-6
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TABLE 3. MONITORING, INSPECTIONS, RECORDKEEPING AND
REPORTING COSTS FOR
TANK OPTIONS T2 AND T3
Control Option/Control Technique
Tank Control Option T2
1) Fixed-roof covers only
2) Floating roof
3) External control device
No. Tanks
Cost/Tank
Annual Cost
1,103
2,980
2,980
$23
$99
$472
4) Total annual MIRR cost
Tank Control Option T3
5) Fixed-roof covers only
6) Floating roof
7) External control device
$25,000
$295,000
$1,410,000
$1,730,000
253
3,405
3,405
$23
$99
$472
8) Total annual MIRR cost
$6,000
$337,000
$1,607,000
$1,950,000
E-7
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TABLE 4. MONITORING, INSPECTIONS, RECORDKEEPING AND
REPORTING COSTS FOR
CONTAINER CONTROL OPTIONS Cl AND C2
Item
1) QAPPa
2) Performance Test
3) Inspections
4) Monitoring
5) Reporting
6) Recordkeeping
(A)
Labor Required
(time/occurrence)
0
0
30 min.
0
30 min.
15 min.
(B)
Frequency
(occurrences/yr)
0
0
12
0
1
12
7) Annual labor hours per storage area (£ C1 through C6)
8) Annual cost per storage area {$25.26 x C7)
9) Total number of storage areas for Option C1 or C2
10) Annual MIRR cost for Option C1 or C2 (C8 x C9)
(C = A x B)
Annual Labor
(hrs/yr)
0
0
6
0
0.5
3
9.5
$510.50
1,250
$638,100
aQAPP = Quality assurance project plan.
E-i
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E.4 MIRR COSTS FOR LAND DISPOSAL UNIT CONTROL OPTIONS
Annual MIRR costs for land disposal units are estimated
from the MIRR requirements of the pretreatment units used
prior to land disposal. From the TSDR Survey, a total of
64 facilities (out of 710) operate one or more land disposal
units. Therefore, it is assumed that there are 64 pre-
treatment processes requiring MIRR. The MIRR requirements for
land disposal pretreatment include an initial performance test
and continuous monitoring of important operating parameters.
Table 5 presents the assumptions and the annual MIRR costs for
the land disposal control option (Options LD1).
E.5 MIRR COSTS FOR PROCESS VENT CONTROL OPTIONS
The total number of process vents at the 710 TSDF was
estimated from the number of vented solvent recovery units,
the number of steam and air strippers, and the number of
facilities that are assumed to pretreat wastes prior to land
disposal. A total of 407 process vents were counted. The
number of process vents requiring controls was then estimated
from the ratio of the number of facilities that had emission
controls on at least one process vent to the total number of
facilities that had process vents. Using the computer model
emission estimates, 80 percent of the facilities needed some
process vent emission control for the process vent control
option (Option PV1). Consequently, a total of 326 vents were
assumed to require emission controls for calculating the MIRR
costs. The annual MIRR costs for the process vent control
option (Option PV1) are presented in Table 6.
E.6 MIRR COSTS FOR EQUIPMENT LEAK CONTROL OPTIONS
The total number of equipment leak emission sources was
estimated from the number of waste management units that have
associated equipment leaks (as modeled in the computer impacts
model). The number of equipment leak emission sources per
waste management unit was estimated using the equipment leak
counts for the model unit configurations used to develop the
equipment leak emission factors (see Memorandum from Coy,
E-9
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TABLE 5. MONITORING, INSPECTIONS, RECORDKEEPING AND
REPORTING COSTS FOR
LAND DISPOSAL CONTROL OPTION LD1
Item
1) QAPP
2) Performance Test
3) Inspections
4) Monitoring
5) Reporting
6) Recordkeeping
(A)
Labor Required
(time/occurrence)
16 hr
16 hr
1 hr
5 min.
2 hr
5 min.
(B)
Frequency
(occurrences/yr)
0.5
0.5
12
365
4
365
7) Annual labor hours per emission source (£ C1 through C6)
8) Annual cost per emission source ($25.26 x C7)
9) Total number of emission sources
10) Total annual MIRR cost (C8 x C9)
(C = A x B)
Annual Labor
(hrs/yr)
8
8
12
30.5
8
30.5
97
$2,450
64
$157,000
aQAPP = Quality assurance project plan.
bAn occurrence of 0.5/yr is used for tests that would be conducted on a
one time only basis or less frequently than once per year.
E-10
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TABLE 6. MONITORING, INSPECTIONS, RECORDKEEPING AND
REPORTING COSTS FOR
PROCESS VENT CONTROL OPTION PV1
Item
1) QAPPb
2) Performance Test
3) Inspections
4) Monitoring
5) Reporting
6) Recordkeeping
(A)
Labor Required"
(time/occurrence)
2 hr
6 hr
30 min.
3 min.
30 min.
2 min.
(B)
Frequency
(occurrences/yr)
0.5C
0.5C
4
365
4
365
7) Annual labor hours per emission source (£ C1 through C6)
8) Annual cost per emission source ($25.26 x C7)
9) Total number of emission sources
10) Total annual MIRR cost (C8 x C9)
(C = A x B)
Annual Labor
(hrs/yr)
1
3
2
18.2
2
12.2
38.4
$970
326
$316,000
Estimates assume two vents are controlled per control device on
average.
bQAPP = Quality assurance project plan.
cAn occurrence of 0.5/yr is used for tests that would be conducted on a
one time only basis or less frequently than once per year.
E-ll
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D. W., and Robert Zerbonia to Hustvedt, K. C., "Revisions to
the Model Units, Weighted Average Throughputs, and Partition
Fractions for Equipment Leak Emission Sources Used in the
Source Assessment Model," September 30, 1988). As the
equipment leak emission control options affect only waste
streams that have 10 percent organic HAP content or more,
equipment leak counts for metals recovery units, wastewater
treatment units, and underground injection wells were not
included in the overall equipment leak count. Table 7
summarizes the assumptions used to develop a total number of
potential equipment leak emission sources. From the computer
impacts model, approximately 80 percent of the facilities will
need to implement a leak detection and repair (LDAR) program
for both equipment leak control options (Options ELI and EL2
both apply to equipment handling waste streams containing
10 percent organic HAP content or more). The LDAR control
costs include costs associated with inspections and leak
monitoring. Furthermore, it is expected that most waste
streams that contain 10 percent or more organic HAP are
currently managed as hazardous waste. Consequently, as
monitoring for these equipment leak emission sources is
already required under RCRA Subpart BB rules, it is
anticipated that little additional reporting and recordkeeping
costs will be associated with equipment leak control options.
Nevertheless, to provide an estimate of potential, additional
MIRR costs, it is assumed that an additional quarterly report
is filed to document compliance with the equipment leak
control option MIRR requirements. The annual MIRR costs for
equipment leak control options (Options ELI and EL2) are
summarized in Table 8.
E-12
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TABLE 7. ESTIMATED NUMBER OF EQUIPMENT LEAK EMISSION SOURCES
Waste Management Unit
1) Incineration
2) Reuse as Fuel
3) Fuel Blending
4) Fixation
5) Solvent Recovery
7) Land disposal pretreatment
No. Units3
66
122
83
15. c
328
64
Sources
per Unitb
226
226
45
45
136
136
8) Total number of potential emission sources (£ C1 thru C7)
9) Number of emission sources @ 10% TOHAP (0.80 x C8)
Total No.
Sources
14,916
27,572
3,735
675
44,608
8,704
100,210
80,170
aCounts from TSDR Survey individual process questionnaires.
bFrom model process units used to develop equipment leak emission factors.
cAssumed one-fourth of the fixation units would manage waste that have
organic HAP concentrations anywhere near 5 percent or more.
E-13
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TABLE 8. MONITORING, INSPECTIONS, RECORDKEEPING AND
REPORTING COSTS FOR
EQUIPMENT LEAK CONTROL OPTIONS ELI AND EL2
Item
1) QAPPa
2) Performance Test
3) Inspections
4) Monitoring
5) Reporting
6) Recordkeeping
(A)
Labor Required
(time/occurrence)
0
0
0
0
1 min.
0
(B)
Frequency
(occurrences/yr)
0
0
Ob
Ob
4
Ob
7) Annual labor hours per emission source (£ C1 through C6)
8) Annual cost per emission source ($25.26 x C7)
9) Number of emission sources for Options EL1 or EL2
10) Annual MIRR cost for Option EL1 or EL2 (C8 x C9)
(C = A x B)
Annual Labor
(hrs/yr)
0
0
0
0
0.067
0
0.067
$1.69
80,170
$135,000
aQAPP = Quality assurance project plan.
bThe monitoring, inspections, recordkeeping and reporting (MIRR) costs
associated with an LDAR program are included in the control costs;
only minimal additional reporting costs are anticipated.
E-14
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E.7 REFERENCES
1. U.S. Environmental Protection Agency. National Survey of
Hazardous Waste Treatment, Storage, Disposal, and
Recycling Facilities. OMB No. 2050-0070. June 1988.
2. U.S. Environmental Protection Agency. OAQPS Control Cost
Manual. 4th Edition, EPA 450/3-90-006. January 1990.
3. Reference 2. p. 3-54.
4. Reference 2. p. 2-25.
5. Reference 2. p. 2-29.
6. Vatavuk, William M., "Cost Escalation." Technical paper
prepared for the U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. March
1993.
E-15
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TECHNICAL REPORT DATA
(Please nod Instructions on reverse before completing)
1. REPORT NO.
EPA-453/R-94-070a
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Off-site Waste and Recovery Operations - Background
Information Document for Proposed Standards
5. REPORT DATE
September 1994
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Emission Standards Division (MD-13)
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
U. CONTRACT/GRANT NO.
68-D1-0118
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD C.OVERED
Interim Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Off-site waste and recovery operations are facilities that treat, store, recycle, and/or dispose of wastes
received from outside the boundaries of the facility. Under the authority of the Clean Air Act, a
national emission standard for hazardous air pollutants (NESHAP) is proposed to control organic
hazardous air pollutant (HAP) emissions from off-site waste and recovery operations. This document
provides background information on emission sources at off-site waste and recovery operations, HAP
emissions, applicable emission control technologies, and the costs and environmental impacts of
implementing these control technologies.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Hazardous Air Pollutants
Waste and Recovery Operations
Volatile Organic Compounds
Hazardous Waste
Solid Waste
Recycling
Air Pollution Control
IS. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
187
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
ETA Fora 2220-1 (Her. 4-77) PREVIOUS EDITION IS OBSOLETE
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