United States
Environmental Protection
Agency
Guide to Calculating
Environmental Benefits of
Enforcement Cases:
FY2005 CCDS Update
Uy9 Printed on paper that contains at least 30 percent postconsumer fiber
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TABLE OF CONTENTS
1.0 INTRODUCTION 1-1
1.1 Background 1-1
1.2 How CCDS Data are Used by EPA/OECA 1-1
1.3 How This Document Is Organized 1-2
2.0 QUALITY ASSURANCE/QUALITY CONTROL FOR THE CCDS PROCESS 2-1
2.1 Completing the Form 2-1
2.2 Review of the CCDS Form 2-1
2.3 Reconciliation of Inconsistent and Incomplete Forms 2-4
2.4 CCDS Data Entryinto ICIS .- 2-4
3.0 CCDS FORM AND INSTRUCTIONS 3-1
3.1 The Revised CCDS Form : 3-1
3.2 Form Instructions 3-8
4.0 GUIDE FOR POLLUTANT REDUCTION/ELIMINATION CALCULATIONS 4-1
4.1 When Do You Need to Calculate Pollutant Reductions/Eliminations or
Environmental Benefit? 4-2
4.2 How Do You Calculate Pollutant Reductions/Eliminations? 4-3
4.2.1 Categories of Outcomes for GPRA Reporting Purposes 4-3
4.2.2 Basic Methodology 4-3
4.2.3 Calculation Basis for Time 4-4
5.0 WATER EXAMPLES 5-1
5.1. Clean Water Act/NPDES 5-2
5.1.1 Background 5-2
5.1.2 Calculation Methodology 5-3
5.1.3 Example Calculations and Input for ICIS 5-4
5.2 Clean Water Act - 311 SPCC and Spill Clean-up Provisions 5-6
5.2.1 Background and Methodology 5-6
5.2.2 Examples and Input for ICIS 5-7
5.3 Stormwater Violations 5-8
5.3.1 Background and Methodology 5-8
5.3.2 Calculation Methodology for Determining Pounds of Sediment Reduced
As a Result of the Implementation of Best Management Practices at
Construction Sites 5-9
5.3.3 Example and Input for ICIS 5-14
5.4 Stormwater Violation for CAFOs 5-16
5.4.1 Background 5-16
5.4.2 Calculation Methodology 5-17
5.4.3 Example Calculations and Input for ICIS 5-21
5.4.4 Additional Reporting Requirements for CAFO Performance Based
Strategy Implementation -. § jhrwy -v 5-26
US EPA Region 3
1 1650 Arch St.
Philadelphia, PA 19103
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TABLE OF CONTEMTS (Continued)
Page
5.5 Combined Sewer Overflow (CSO) 5-26
5.5.1 Background 5-26
5.5.2 Calculation Methodology 5-28
5.5.3 Example Calculation and IC1S Input 5-29
5.6 Sanitary Sewer Overflow (SSO) 5-30
5.6.1 Background 5-30
5.6.2 Calculation Methodology 5-31
5.6.3 Example Calculation and Input for 1CIS 5-32
5.7 Wetlands 5-3.3
5.7.1 Background and Methodology 5-33
5.7.2 Examples and Input for ICIS 5-34
5.8 SDWA - PWSS 5-35
5.8.1 Background and Methodology 5-35
5.8.2 Example and Input for ICIS 5-36
5.9 SDWA - UIC 5-36
5.9.1 Background and Methodology 5-36
5.9.2 Example and Input for ICIS: 5-38
5.10 References 5-38
6.0 AIR EXAMPLES 6-1
6.1 NOX Reductions at a Petroleum Refinery under PSD/NSR 6-1
6.1.1 Background 6-1
6.1.2 Calculation Methodology 6-3
6.1.3 Example Calculations and Input for ICIS 6-5
6.2 SO, and HAP Reductions at a Kraft Pulp and Paper Mill Under MACT 6-9
6.2.1 Background 6-9
6.2.2 Calculation Methodology 6-11
6.2.3 Example Calculations and Input for ICIS 6-12
6.3 Leak Detection and Repair 6-17
6.3.1 Background 6-17
6.3.2 Calculation Methodology 6-17
6.3.3 Example Calculations and Input for ICIS 6-20
6.4 References 6-22
7.0 HAZARDOUS WASTE EXAMPLES 7-1
7.1 RCRA Subtitle C 7-1
7.1.1 Background 7-1
7.1.2 Example Calculations and Input for ICIS 7-3
7.2 RCRA UST 7-5
7.2.1 Background 7-5
7.2.2 Examples and Input for ICIS 7-7
7.3 RCRA/Superfund Corrective Actions 7-7
7.3.1 Background 7-8
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TABLE OF CONTENTS (Continued)
Page
7.3.2 Calculation Methodology by Media Response Type 7-10
7.3.3 Examples and Input for 1CIS 7-12
7.4 References 7-15
8.0 TSCA VIOLATIONS 8-1
8.1 TSCA Lead-based Paint 8-1
8.2 TSCA Section 6 8-3
8.3 Asbestos under TSCA/AHERA and CAA NESHAP 8-4
8.4 References 8-7
9.0 ENVIRONMENTAL BENEFITS FROM FIFRA ENFORCEMENT CASES 9-1
9.1 Examples and Input for 1C1S 9-2
9.2 References 9-3
10.0 DENSITIES, UNITS AND UNIT CONVERSIONS 10-1
11.0 LOOK-UP TABLES 11-1
HI
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LIST OF TABLES
3-1 Question 20 Actions 3-6
3-2 Key SEP Actions to Track 3-7
3-3 CCDS Form Instructions 3-8
3-4 Reference Law Sections, Question 8 3-10
3-5 Definitions for Question 20 3-15
3-6 Question 19 and 22 Entries for "Media" 3-20
3-7 Question 19 and 22 Entries for "Units" 3-20
3-8 Definitions for Question 17 3-21
5-1 Typical Pollutant Concentrations (in mg/L) by Source 5-27
5-2 CSO Treatment Process Efficiencies (in %) 5-28
6-1 Worksheet to Calculate NOX Emission Reductions from Process Heaters and
Boilers 6-8
6-2 SOCMI Leak Rate/Screening Value Correlations 6-18
6-3 Petroleum Industry Leak Rate/Screening Value Correlations 6-18
6-4 SOCMI Default Zero Leak Rates and Pegged Leak Rates 6-19
6-5 Petroleum Industry Default Zero Leak Rates and Pegged Leak Rates 6-19
10-1 Common Densities 10-2
10-2 Common Conversion Factors 10-3
10-3 Examples of Common Pollutant Loading Conversions for Different Media 10-3
11-1 Typical Pollutant Concentrations (lb/d/1000# of animal) in As Excreted Manure
for Beef and Dairy Cattle 11-1
11-2 Typical Pollutant Concentrations (lb/d/1000# of animal) in As Excreted Manure
for Swine • 11-1
IV
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LIST OF TABLES (Continued)
Page
11-3 Typical Supernate Pollutant Concentrations (lbs/1000 gal) in Lagoons and Runoff
Ponds 11-2
11 -4 Typical Manure Recoverability Factors and Nitrogen/Phosphorus Losses by
Animal Type 11-2
11-5 Typical Animal Weight and Manure Density for Beef and Dairy Cattle 11-2
11-6 Typical Crop Uptake Values 11-3
11-7 NO, and SO, Emission Factors for Boiler Fuel Oil Combustion 11-4
11-8 NOX Emission Factors for Boiler Natural Gas Combustion 11-5
11-9 SO2 Emission Factors for Boiler Natural Gas Combustion 11-6
11-10 NOX Emission Factors for Process Heater Natural Gas Combustion 11-6
11-11 NOX Emission Factors for Process Heater Oil Combustion 11-7
11-12 Estimated Control Efficiencies (%) for NOX 11-8
LIST OF FIGURES
Page
2-1 CCDS Completion Checklist 2-2
2-2 CCDS Calculation Checklist 2-3
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1.0 INTRODUCTION
1.1 Background
EPA implemented the Case Conclusion Data Sheet (CCDS) in FY 1996 to capture relevant
information on results and environmental benefits of concluded enforcement cases including
pollutant reduction benefits. CCDS information must be provided whenever any formal
enforcement case is "concluded." For civil judicial cases, the information is reported when a
consent decree, court order, or judgment is entered (not lodged). For administrative cases,
information is reported when an administrative order or final agreement is signed (usually by the
Regional Administrator) and issued. To ensure good data quality, several regions will not sign
off on an administrative order unless the CCDS is attached and has been reviewed.
During 1999-2000, EPA assessed the quality and completeness of the data being provided by the
CCDS form and identified areas for improvement. As part of this effort, OECA developed a
training booklet and course to help explain the underlying value of the data provided by the
CCDS and to provide methodologies for regional staff to use in developing pollutant reductions
for various types of cases. In November 2000, OECA published the Case Conclusion Data
Sheet Training Booklet and Quick Guide for Case Conclusion Data Sheet and then conducted
CCDS training the following year at each of EPA's regional offices.
This booklet is an update to the November 2000 training booklet. This booklet has been revised
to address suggestions and input collected from the regional training courses conducted in 2001
and to incorporate additional pollutant reduction calculation methodologies and policies that
have been developed since that time.
1.2 How CCDS Data arc Used bv EPA/OECA
The data from completed CCDS forms are entered by each of the EPA's regional offices into
OECA's enforcement and compliance data system - ICIS (Integrated Compliance Information
System). The data are used:
• To report OECA's accomplishments under the Government Planning and Results Act
(GPRA) on an annual basis;
• As a management tool to assess regional case performance;
• To describe the results of our enforcement program to the public, Congress, and others.
OECA's emphasis on the environmental benefits of its compliance and enforcement activities is
growing, and OECA needs to be able to assess the impact and benefit to the environment from
these actions. The data collected on the CCDS is key to achieving this goal and therefore
improving the quality of the CCDS data, which has been an imperative of the Agency. Most
recently, the importance of this data has been made clear by the fact that regions are now asked
to certify that the estimates of environmental benefits were calculated using current guidance and
methodologies, and are complete and entered into ICIS.
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1.3 How This Document Is Organized
This training booklet is organized to present the overall CCDS process, including:
Quality Assurance/Quality Control (QA/QC; Section 2.0);
• Guidance on completing the form (Section 3.0);
• General guidance on estimating pollutant reductions resulting from enforcement actions
(Section 4.0);
• Regulatory Act-specific guidance and examples for estimating pollutant reductions
(Sections 5.0 - 9.0);
• A summary of pollutant densities and unit conversions for use in estimating pollutant
reductions (Section 10.0);
• Look up tables for use in some of the water and air examples (Section 11.0); and
• Explanation of new "filtering" compliance actions by statute in ICIS (Section 12.0).
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2.0 QUALITY ASSURANCE/QUALITY CONTROL FOR THE CCDS PROCESS
This section provides a process for assessing the quality of estimated pollutant reductions,
reconciling inaccurate, incomplete, and inconsistent data entries, and facilitating regional review
of completed CCDS forms. The CCDS review methodology includes an independent review of
the CCDS form and the use of two checklists to provide a consistent and documentable QA/QC
program. Regions need to ensure that a data quality review process is implemented; while it may
differ in specific detail, it needs to address similar principles of data review and correction. In
addition, calculation sheets used for determining pollutant reduction amounts need to be
included with the review package and retained in the case file for auditing purposes.
The CCDS completion process involves the attorney and/or program staff who provide the case
information, the reviewers of the form, and the (CIS data entry staff. Once a case file is
received, the CCDS must be completed and input into ICIS in a timely manner. The basic steps
in the CCDS QA/QC process are:
1. Complete the CCDS form;
2. Review key data on the form;
3. Reconcile inconsistencies and incomplete entries as needed; and
4. Enter CCDS data into ICIS.
5. Certify that the data is complete and accurate at mid-year and end-of-year.
2.1 Completing the Form
The CCDS contains information about the case including facility information, reasons for the
enforcement action/order, costs/penalties associated with the action/order, and the resulting
environmental benefits. Sections 3.0 through 12.0 of this training booklet provide guidance for
use in completing this form.
2.2 Review of the CCDS Form
It is important that the completed CCDS be reviewed by another program staff member;
otherwise, key information may be mis-reported, or not reported at all. An independent reviewer
can often spot problems or omissions by reviewing the form. EPA has prepared two checklists
to facilitate this review. One is for a completeness check and the second is for a check on
pollutant reduction calculations. These checklists are discussed below.
Figure 2-1 presents a checklist to use for a completeness review. The reviewer indicates that the
proper information has been provided on the CCDS by completing the last column in Figure 2-1.
This checklist also has a sign-off table at the top for tracking the status of the CCDS form and its
review. Each person signs and dates this box when they have completed their tasks or when the
form is transferred to the next person. A reviewer should not sign off on the form until all issues
have been resolved to his/her satisfaction. The end of the checklist includes a yes/no question to
identify if the CCDS needs to be returned to the person who completed it because fields are
blank, with no explanation as to why.
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Figure 2-1. CCDS Completion Checklist
IC1S Case Number
CCDS Sign Off
CCDS Completed By
CCDS Review Completed By
CCDS Returned Tor Problem Resolution To
Ycs_ N/A
CCDS 1CIS Entry Completed By
Name of Person
Date
CCDS Field
Arc all questions required for ICIS entry complete?
Includes questions in Sections A, B, C, and E (Section D questions will
apply if a SEP is included with the enforcement action)
If not, which questions are not complete1'
Completed
(Y, N)
Form Complete
Revision(s) Required
Indicate Problem (s) / missing item(s):
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Figure 2-2. CCDS Calculation Checklist
ICIS Case Number
CCDS Question ft/Description
Completed
(Y,N,
N/A)*
Reviewer Comments
General
Do laws violated (Q. 8) correspond with the multi-media check
(Q. ID1'
Q. 17 Supplemental Environmental Projects (SEPs)
Are any of the following categories checked'
- Pollution prevention
- Pollution reduction
If yes, is corresponding information presented in Question 19'
Are valid pollutant names provided?
Are reduction/elimination amounts provided in acceptable units
for the media affected'
Is the affected media indicated?
Does the affected media correspond to the statutes violated and
the actions checked'
Are calculation sheets included in the review package'
Were the approved methodologies in the CCDS guide used in
developing the calculations' If not, why not and what
alternative calculation was used'
Can you verify that the estimation methods are valid'
Can you replicate the calculations'
Q. 20 Violator Actions (Non-SEP Related)
Are any Q. 20, Column 1 actions (Direct Actions, Preventative
Actions) checked'
If yes, is corresponding information presented in Question 22'
Are valid pollutant names provided'
Are reduction/elimination/treatment/managed/prevention
amounts provided in acceptable units for the media affected?
Is the affected media indicated'
Does the affected media correspond to the statutes violated and
the actions checked'
Are calculation sheets included in the review package'
Were the approved methodologies in the CCDS guide used in
developing the calculations? If not, why not and what
alternative calculation was used'
Can you verify that the estimation methods are valid'
Can you replicate the calculations'
N/A = Not Applicable
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Generally, reporting errors and/or inconsistencies are most common when pollutant reductions
are being reported. If pollutant reductions/eliminations are reported in CCDS Question 19
and/or 22 (see page 3-3, 3-4), the reviewer should use Figure 2-2 to verify that these are
correctly reported. The reviewer should evaluate the case file, case summary, or referral
transmission memo that should accompany the CCDS, including the calculation sheets used to
quantify environmental benefits. If sufficient information is not provided, the reviewer should
return the CCDS to the person who completed it and not submit it for entry into ICIS until it is
fully complete.
EPA recommends that all case conclusion data sheets be reviewed for completeness using the
Figure 2-1 checklist, or an equivalent written process, and that all forms that require a pollutant
reduction calculation be reviewed using the Figure 2-2 checklist. We also recommend that copies
of pollutant-reduction calculations, including densities used for converting to pounds, be kept in
case files.
2.3 Reconciliation of Inconsistent and Incomplete Forms
As noted above, the reviewer is responsible for verifying that the CCDS is complete and contains
accurate pollutant reduction data. If fields are left blank, calculations are in error, or calculations
cannot be verified, then the form should be returned to the originator for corrections.
2.4 CCDS Data Entry into ICIS
Entry of the CCDS data into ICIS should occur within 2 weeks of a judicial case being entered or
an administrative actions becoming final. Data may be entered by program personnel directly or
a Region may have a specified data entry person. (Currently the process for entry of ICIS data
varies by EPA region)
Questions related to CCDS data entry into ICIS should be brought to the Regional System
Administrator. Questions may also be directed to EPA's Federal ICIS Administrator, Mr.
Michael Mundell at mundell.michael@.epa.gov and (202) 564-7069.
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3.0 CCDS FORM AND INSTRUCTIONS
This section provides a general discussion of the CCDS form (Section 3.1) and question-specific
instructions (Section 3.2).
3.1 The Revised CCDS Form
This section presents the revised CCDS form for illustrative purposes. Note that various regions
may have their own versions of this form. The CCDS form asks for case information as follows:
• Case and Facility Background (Questions 1-10);
• Penalty Information (Questions 11-13);
• Cost Recovery (Question 14);
• Supplemental Environmental Project (SEP) Information (Questions 15-19); and
• Injunctive Relief/Compliance Actions Information (Questions 20-22).
One important aspect of the CCDS is the quantification of pollutant reductions and/or
environmental benefits that occur as a result of enforcement activities. These reductions and/or
benefits are quantified using the following questions on the form:
• Categories of supplemental environmental projects (SEP(s)) (Q. 17);
• Quantitative environmental impacts of these SEP activities (Q. 19);
• Injunctive relief/Compliance actions (non- SEP) (Q. 20); and
• Quantitative environmental impacts of these activities (Q. 22).
EPA has categorized complying action types into the following groups:
Actions with Direct Environmental Benefits/Response/Corrective Action: those actions that
treat, reduce, or eliminate a pollutant or emission/discharge stream to reduce/eliminate human
health exposure or environmental impact (e.g., source reduction, emissions/discharge change,
implementing best management practices, removal). .OC measures the direct environmental
benefits in terms of quantity, volume, area, and people protected.
Preventative Actions to Reduce the Likelihood of Future Releases: those actions that
properly manage a waste stream or prevent a release or exposure. Preventative actions may
reduce the likelihood of future human health risk or environmental impact by maintenance of
proper controls prior to a release or waste stream being generated (e.g., plug and abandon wells,
develop spill prevention plan, secondary containment, asbestos removal training) or after it has
been generated as a waste (e.g., RCRA labeling, storage change, disposal change). OC measures
the environmental benefits of these actions in terms of quantity, volume, area,
schools/housing/building units, wells, and people protected.
Facility/Site Management and Information Practices (FMIP): those actions that a facility
conducts to better manage their environmental program and to inform the public/permitting
authority of the toxicity, quantity, and location of their chemicals, waste streams, and emissions
(e.g., auditing, environmental management review, site assessment, testing, recordkeeping,
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reporting). OC does not try to quantify the environmental benefits of Facility/Site Management
and Information Practices.
Beginning in FY 2005, when entering environmental benefit data into [CIS, the system will
automatically filter the possible selections for complying action types, units, and potentially
impacted media.
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Case Conclusion Data Sheet
A. Case and Facility Background
I Enforcement Action ID - -_
2 Enforcement Action Name
3 Settlement Action Type
(a) Consent decree or court order resolving a judicial action (c) Federal Facility Compliance Agreement (not mcl RCRA matters)
_(b) Admin Compliance Order (with/without injunctivc relief) (0 Supcrfund Administrative Order for Cost Recovery
_©) Admin Penalty Order (with/without injunctivc relief)
_(d) Notice of Determination
4 Was Alternative Dispute Resolution used in this action (Y/N)
5 Was an Environmental Management System requested (Y/N)
6 Administrative Action Date Final Order Issued
or
Civil Action Date CD Lodged CD Entcrcd_
7 Rcspondcnt(s)
8 Federal Slatutc(s) violated (c g, CAA, EPCRA, etc ) (Not U S C or CFR)
9 Facility Namc(s)
10 Facility Addrcss(s) Stfcct City County St Zip
B. Penalty (if there is no penalty, enter 0 and proceed to #15)
11 For multimedia actions. Cash Civil Penalty Amount Required by statute
Statute Amount
S
S
12 Federal Penalty Required S
13 (if shared) State/Local Penalty Amount $
C. Cost Recovery
14 Amount cost recovery Required S EPA $ State and/or Local Government S Other
D. Supplemental Environmental Project (SEP) Information (Y/N) If Yes. for each SEP provide the following
IS Is Environmental Justice addressed by impact of SEP'' (Y/N)
16 SEP description
17 Category of SEP(s)
_(a) Public Health
(b) Pollution Prevention (Complete Q 19)
(I) equipment/technology modifications
(2) process/procedure modification
(3) product reformulation/redesign
(4) raw materials substitution
(5) improved housckccping/O&M/training/mvcntory-control
(6) m-proccss recycling
(7) energy efficiency/conservation
_©) Pollution Reduction (Complete Q 19)
(d) Environmental Restoration and Protection
(c) Assessments and Audits
(f) Environmental Compliance Promotion
(g) Emergency Planning and Preparedness
_ (h) Other Program Specific SEP
18 Cost of SEP Cost calculated by the Project Model is required $
19 Quantitative environmental pollutants and/or chemicals and/or waste-streams, amount of reductions/eliminations (c g ^missions/discharges)
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Pollutant/Chemical/Waste Slream
ENVIRONMENTAL BENEFIT OF SEP
Amount Units (circle one)
Pounds/yr
People
Acres
Linear Feet ss
Linear Feel ms
Linear Feel Is
Gallons/yr
Pounds
Potentially Impacted Media
Air
Land
Water (navigable/surface)
Water (wetlands)
Water (wastcwater to a POTW)
Water (underground source of drinking water)
Water (ground)
Animals/Plants/Humans
Buildings/Houscs/Schools
E. Injunctive Relief/Compliance Actions (Non-SEP)(APO's w/o mj relief [4©) above], Supcrfund Admin Cost Recovery Agrccmcnls|4(f) above)
SKIP THIS SECTION)
20 What action did violator accomplish prior to receipt of settlement/order or will take to return to compliance or meet addl requirements (other than
what has already been reported on the Inspection Conclusion Data Sheet (ICDS)) This may be due to settlement/order requirements or otherwise
required by statute or regulation (c g actions related to an APO which did not specify compliance requirements) Where separate penalty and/or
compliance orders arc issued in connection w/samc violation(s), report the following information for only one Select rcsponsc(s) from the following
Actions with Direct Environmental Benefits and/or Direct
Response/Corrective Action
Source Reduction/Waste Minimization (RCRA)
Industrial/Municipal Process Change (includes flow reduction)
Emissions/Discharge Change (c g cnd-of-pipc treatment)
Implement Best Management Practices (BMPs)
Wetlands Mitigation
In-situ and Ex-situ Treatment (CERCLA/RCRA Corrective Action)
Waste Treatment (RCRA/TSCA)
Removal of Spill
Removal of Contaminated Medium (soil, drums etc )
Containment (CERCLA)
Leak Repair (CAA)
Import Denied (FIFRA)
Prevenlative Actions to Reduce Likelihood of Future Releases
Disposal Change
Storage Change
Develop/Implement Asbestos Management Plan
Develop/Implement Spill Prevention and Countcrmcasurcs
Control (SPCC) Plan
Obtain Permit for Underground Injection (UIC)
UIC Plug and Abandon
UIC Demonstrate Mechanical Integrity
UST Tank Closure
UST Secondary Containment
UST Corrosion or Overfill Protection
RCRA Labeling/Manifesting
RCRA Waste Identification
RCRA Secondary Containment
Lead-Based Paint Disclosure
Lead-Based Paint Removal Training/Certification (TSCA 402, 1018, 206)
Asbestos Trainmg/Ccrtification/Accrcditation
Asbestos Abatement
Notification (SDWA. FIFRA)
Worker Protection (FIFRA)
Pesticide Registered (FIFRA)
Pesticide Certified (FIFRA)
Pesticide Claim Removed (FIFRA)
Pesticide Label Revision (FIFRA)
Facility/Site Management and Info. Practices
Testing/Sampling
Auditing
Labeling/Manifesting
Record keeping
Reporting
Information Letter Response
Financial Responsibility Requirements
Environmental Management Review
RI/FS or RD (CERCLA)
Site Assessment/Characterization (CERCLA)
Provide Site Access (CERCLA)
Monitoring
UST Release Detection
Storm water Site Inspections
Asbestos Inspections
Training
Planning
Permit Application
Work Practices
Notification (TSCA Section 6)
Leak Detection (CAA)
Spill Notification
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21 Cost of actions described in item #21 (Actual cost data supplied by violator is preferred figure )
Physical actions $ Non-Physical actions S
22 Quantitative environmental impact of actions described in item #21 (Add additional pollutants on blank sheet)
REDUCTIONS/ELIMINATIONS/TREATMENT
Pollulanl/Chemical/Waste Slream Annual Amount
Polliitanl/Chemical/Wasle Stream
Amount
Units
Pounds/yr
People
Cubic Yards
Acres
Linear Feet (ss/ins/ls)
Gallons/yr
Pounds
Miles of Stream Impacted
PREVENTION
Units
Wells
Gallons
SF/MF/Housmg units
Building Units
Schools
People
Pounds
Potentially Impacted Media
Air
Land
Soil
Water (navigable/surface)
Water (wetlands)
Water (underground source of drinking water)
Water (ground)
Animals/Plants/Humans
Potentially Imnacted Media
Water (underground source of drinking water)
Water (navigable/surface)
Schools/Housing/Buildmgs
Animals/Plants/Humans
This form is for illustrative purposes - When entering quantitative data into ICIS, the system will automatically
filter the possible selections for complying action types, units, and potentially impacted media.
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Not all improvement actions have quantifiable benefits. The actions listed on Question 20 arc
divided into two groups as shown in Table 3-1 below. Actions checked in the first column
should have pollutant reductions or environmental benefits quantified in Question 22. Actions
checked in the second column may have identification of a pollutant(s) at the facility as part of
the action or order but will not result in quantifiable pollutant reduction. For these activities no
pollutant reductions should be identified in Question 22.
Table 3-1. Question 20 Actions
Actions with Direct Environmental Benefits and/or
Direct Response/Corrective Action; Prevcntative
Actions to Reduce Likelihood of Future Releases
Source Reduction/Waste Minimization
Industrial/Municipal Process Change
Emissions/Discharge Change
Implement Best Management Practices (BMPs)
Wetlands Mitigation
In-situ and ex-situ Treatment (CERCLA and RCRA
Corrective Action)
Waste Treatment (RCRA and TSCA)
Removal of Spill
Removal of Contaminated Medium
Containment
Leak Repair (CAA)
Impon Denied (FIFRA)
Disposal Change
Storage Change
Develop/Implement Asbestos Management Plan
Develop/Implement Spill Prevention and
Countenneasures Control Plan (SPCC)
Obtain Permit Tor Underground Injection (UIC)
UIC Plug and Abandon
UIC Demonstrate Mechanical Integrity
UST Tank Closure
UST Secondary Containment
UST Corrosion or Overfill Protection
RCRA Labeling/Manifesting
RCRA Waste Identification
RCRA Secondary Containment
Facility/Site Management and Information
Practices
Testing/Sampling
Auditing
Labeling/Manifesting
Record keeping
Reporting
Information Letter Response
Financial Responsibility Requirements
Environmental Management Review
RI/FS or RD (CERCLA)
Site Assessment/Characterization (CERCLA)
Provide Site Access (CERCLA)
Monitoring
UST Release Detection
Storm water Site Inspections
Asbestos Inspections
Training
Planning
Permit Application
Work Practices
Notification (TSCA Section 6)
Leak Detection (CAA)
Spill Notification
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Table 3-1. Question 20 Actions (Continued)
Actions with Direct Environmental Benefits and/or
Direct Response/Corrective Action; Prcventative
Actions to Reduce Likelihood of Future Releases
Lead-Based Paint Disclosure
Lead-Based Paint Removal Training/Certification
Asbestos Training/Certification/Accreditation
Asbestos Abatement
Notification (SDWA/F1FRA)
Worker Protection (FIFRA)
Pesticide Registered (FIFRA)
Pesticide Certified (FIFRA)
Pesticide Claim Removed (FIFRA)
Pesticide Label Revision (FIFRA)
Facility/Site Management and Information
Practices
Actions where quantitative benefits can be tracked are those that treat, reduce, or eliminate a
pollutant or emission/discharge stream to reduce or eliminate human health exposure or
environmental impact. Also included are those actions that reduce the likelihood of future
human health risk or environmental impact by proper management or through ensuring proper
operation of existing controls.
OECA also tracks the environmental benefits that result from SEPs. Table 3-2 lists the key SEP
actions (from CCDS Question 17) and identifies those actions that result in quantifiable
environmental benefits.
Table 3-2. Key SEP Actions to Track
Public Health
Pollution Prevention*
Pollution Reduction*
Environmental Restoration and Protection*
Assessments and Audits
Environmental Compliance Promotion
Emergency Planning and Preparedness
* Items where benefits can (and should) be quantified.
Once you have determined that an enforcement action has resulted in a quantifiable pollutant
reduction, you need to complete Question 19 and/or Question 22 of the CCDS. You must
correctly identify the pollutant(s) affected, quantify the amount of contamination that has been
reduced, eliminated, treated, properly managed, or prevented, and identify the affected media.
3-7
-------
3.2 Form Instructions
Table 3-3 provides instructions for completing the CCDS form. This table is followed by Tables
3-4 through 3-9 which provide information on specific valid inputs for the form.
Table 3-3. CCDS Form Instructions
Question #
1
2
3
4
5
'6
7
8
9
10
11-13
14
15
16
17
18
Instructions
This is the unique alphanumeric identifier used to identify a specific Enforcement Action
pertaining to a regulated entity or facility
Enter the enforcement action name exactly as it appears in the caption of the enforcement
instrument.
Indicate the type of action (consent decree, APO, etc.) from the list provided.
This question asks whether an alternative dispute resolution process was used in the development
of the requirements of the action Alternative Dispute Resolution (ADR) is a procedure, such as
mediation or arbitration, used by EPA in resolving differences with companies, groups, and/or
individuals over enforcement-related issues
This is the flag to indicate whether Environmental Management System (EMS) input was
requested for this settlement
For Administrative actions, the Final Order date is the date the Complaint or Administrative
Order was signed by the appropriate EPA official and issued to the respondent. The Final Order
date is the date the compliance order becomes effective without further administrative appeal For
unappealed or unilateral administrative compliance orders, the final date is the signature date of the
EPA issuing official For two-step orders, both issue date and final date should be provided on the
form, even if the issue and final date are the same. For Civil actions, the CD lodged and entered
date is the date the complaint was signed by the appropriate EPA official and issued to the
respondent. The CD lodged and entered dates apply to the consent decree resulting from the civil
action Enter as mm/dd/yy.
This is the Respondent's name
Enter the acronym for the law violated (CWA, CAA, RCRA).
Name of facility against which the enforcement action is lodged.
The street address of the facility against which the enforcement action is lodged (where the
violation(s) occurred) Do Not use Post Office Box number for this address.
These questions report in dollars the Penalty associated with the case.
This question reports the amount in dollars of cost recovery associated with the case.
This question asks whether Environmental Justice (EJ) is addressed by the SEP.
Provide a brief description of the SEP Indicate what activities are included as part of the SEP and
the purpose of those activities (what environmental benefit is intended by the SEP).
Check only the actions that apply to the SEP Table 3-8 provides definitions for the different SEP
actions. If 1 7(b) or I7(c) is checked, Question 19 should be completed including pollutants,
amount, units, and media. If only actions that do not result in a pollutant reduction/elimination are
checked, then SKIP Question 19.
This question reports the cost in dollars of the SEP.
3-8
-------
Table 3-3. CCDS Form Instructions (Continued)
Question #
Instructions
19
Complete this question if you have checked I7(b) or 17(c). See instructions under Question 22.
20
Check the appropriate action type from the list on the CCDS form. Check only the actions that
apply to the settlement or order. Table 3-5 below provides definitions for the different violator
actions. If an action is checked from the First column then Question 22 should be completed
including pollutants, amount, units, and media If only actions from the second column are
checked, then pollutant reductions/eliminations do not apply and you can SKIP Question 22.
21
Identify the cost of implementation of the actions identified in Question 20. Actual cost data
supplied by the violator are preferred. For Superfund actions, this should be the estimated value of
Responsible Party work to be performed as included in the ROD or other documents
22
Complete this question if you have checked any actions from the first column of Question 20. If
you checked items from the first column calculate pollutant reduction/elimination or environmental
benefit as appropriate (See Section 4.0).
The impacted media is the media where the pollutant(s) or waste were emitted/discharged
Table 3-6 lists the valid entries possible for this column
Do include units with any pollutant amount provided ICIS preferred units are "pounds". Table 3-
7 lists the valid entries possible for this column
3-9
-------
Table 3-4. Reference Law Sections, Question 8
Law
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CERCLA
CERCLA
CERCLA
Law
Section
Code
110
111
112
112(R)(1)
112(R)(7)
II2B
112D
II2E
1I2G
1I2H
1121
II2K
II2R
113A
114
USD
129
165
103A
103D2
104E2
Law Section Description
State Implementation Plan
Standards
New Source Performance
Standards (NSPS)
Hazardous Air Pollutants
except 1 12(r)
Prevention of Accidental
Release/General Duty
Clause
Prevention of Accidental
Release/Risk Management
Plans (RMPs)
Asbestos
MACT Standards
MACT Adoption Schedule
Modification
Work Practices
Permi ts/Conipl lance
Schedule
Area Source MACT
General Duty/Accidental
Release
Violation of Existing
Administrative Order
Recordkeeping, Insp., Info.
Request
Fed Facility Motor Vehicles
Solid Waste Fuel
Combustion
Prevention of Significant
Deterioration (PSD)
Notification of Hazardous
Reportable Quantity
Release
Destruction of Records
Information and/or Access
Law
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CAA
CERCLA
CERCLA
CERCLA
Law
Section
Code
173
I83E1A
183EIB
183 F
202
203
208
211
213
219
303
412
502
608
609
610
611
107M
108
109A5
Law Section Description
New Source Review Permit
Requirements
Federal Ozone Measures
Federal Ozone Measures
Federal Ozone Measures
Emission Std. for New
Motor Vehicles and Engines
Prohibited Acts Mobile
Sources
Record keeping, Insp, Info
Request
Fuel Regulation
Non-road Engines &
Vehicles
Urban Bus Standards
Imminent/Substantial
Endanger.
Acid Rain Requirements
Operating Permits (Title V)
CFC Recycling/Emission
Red.
Motor Vehicle Air
Conditioning (CFCs)
Non-essential CFC Products
CFC Labeling
Maritime Lien
Violation of Financial Resp.
Violation of 109(a)(5)
Subpoena
3-10
-------
Table 3-4. Reference Law Sections, Question 8 (Continued)
Law
CERCLA
CERCLA
CERCLA
CERCLA
CERCLA
CERCLA
CERCLA
CWA
CWA
CWA
CWA
CWA
CWA
CWA
EPCRA
EPCRA
EPCRA
EPCRA
FIFRA
FIFRA
Law
Section
Code
I04E3
I04E4
I04E5
106 A
107 A
I07C3
107L
301
301/307
301/31 IB
301/3 11C/
31IE
301/402
301/404
308
302
303
304
311
12A1A
12A1B
Law Section Description
Entry Access
Inspection and Samples
Violation of 104(e)
Compliance Order
Imminent & Substantial
Endangerment Order
Cost Recovery
Treble Damages
Lien
NPDES Discharge w/o
Permit
Toxic and Pretreatment
Effluent Standards
Oil & Hazardous
Substances Discharge
Emergency Powers Oil
Imminent & Substantial
Endangerment
NPDES Wet Weather/Other
Permit Violations
Discharge/Dredge and Fill
Permit Violations
Information Request,
Records, Entry
List Presence of
Substances/Notify
Emergency Response Plans
Emergency Release
Notification
Material Safety Data Sheets
Unregistered Pesticide
Claim Difference
Law
CERCLA
CERCLA
CERCLA
CERCLA
CERCLA
CERCLA
CWA
CWA
CWA
CWA
CWA
CWA
EPCRA
EPCRA
EPCRA
EPCRA
FIFRA
FIFRA
Law
Section
Code
120E
122 A
122D3
122E3B
I22G
I22H
309
309G3/
3IIB6H
3I1F
3I1J
405
504
312
313
322
323
12A2H
12A2I
Law Section Description
Federal Facility Interagency
Agreement
Agreement to Do I04B
RI/FS
Violation of Existing AO or
CD
Violation of 122(e)(3)(B)
Subpoena
Admin. De Mmimis
Settlement
Admin. Cost Recovery
Settlement
Violation of Existing AO
Collection Action
Oil Removal Cost Recovery
SPCC and/or Federal
Response Plan Violations
Sewage Sludge Disposal
Emergency Powers
Inventory of Chemicals
Toxic Chemical Release
Reporting (TRI)
Trade Secrets
Provide Info to Health
Professionals
Contrary Use - Experimental
Permit
Violate SSUR Order
3-11
-------
Table 3-4. Reference Law Sections, Question 8 (Continued)
Law
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
MCRBMA
MCRBMA
MCRBMA
MCRBMA
MCRBMA
MCRBMA
MPRSA
RCRA
RCRA
Law
Section
Code
12AIC
I2A1D
I2AIE
I2A1F
I2A2A
12A2B
12A2C
I2A2D
I2A2E
12A2F
I2A2G
103 A
I03B
104 A
I04B
203
204
IOIA
3002
3003
Law Section Description
Composition Difference
Colored/Discolored
Adulterated/Misbranded
Device Misbranded
Label Alter/Detach
Refuse Records, Repts,
Entry
False Guaranty
Confidential Information
Revealed
Advertise w/o
Classification
Restricted Usage
Misuse
Rechargeable Batteries,
Rechargeable Consumer
Products, Easy
Removability & Labeling
Regulated Batteries &
Rechargeable Consumer
Products
Collection, Storage, and
Transportation of Spent
Rechargeable Batteries &
Rechargeable Consumer
Products
Enforcement of Handling
Requirements under RCRA
Alkaline-Manganese
Batteries
Zinc-Carbon Batteries
Mar Prot, Res & Sane Act
Haz Waste Generator Regs
Haz Waste Transporter
Regs
Law
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
FIFRA
MCRBMA
MCRBMA
MCRBMA
MCRBMA
MCRBMA
MPRSA
RCRA
RCRA
Law
Section
Code
12A2J
12A2K
12A2L
12A2M
12A2N
12A20
12A2P
I2A2Q
12A2R
I2A2S
13
205
206
5A
5F
6
I01B
3013
3014
Law Section Description
Violate Suspension Order
Violate Cancellation Order
Establishment Registration
Falsify Application,
Information, etc
Failure to File Reports
Add/Remove Substance
Test Pesticide on Humans
Falsify Testing Information
Falsify Registration Data
Violate Regs Under 3(a) or
19
Stop Sale. Remove, and
Seizure
Button Cell Mercuric Oxide
Batteries
Non-Button Cell Mercuric
Oxide Batteries
Violation of MCRBMA
Section 5(A)AO or Civil
Action in District Court
Violation of 5(F) Subpoena
Reports, Records, Access
Mar. Prot, Res & Sane Act
Monitoring, Analysis,
Testing Order
Recycled Oil
3-12
-------
Table 3-4. Reference Law Sections, Question 8 (Continued)
Law
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
SDWA
SDWA
SDWA
SDWA
SDWA
SDWA
SDWA
SDWA
SDWA
Law
Section
Code
3004
3004
VU
3005
3005D
3005 F
3005G
3007
3008A
3008C
3008G
3008H
3010
1412
1412/
1414
14I4C
I4I4G
1414
G3D
1415
1416
1417
1421
Law Section Description
Treatment, Storage, and
Disposal (TSD) Standards
TSD Corrective Action
TSD Permit Requirements
Revocation of Permit
Reclamation Permit
RD&D Permits
Recordkeeping, Inspection,
Information Request
Compliance Order
Injunctive & Penalty
Violation of Compliance
Order
Penalty Authority
Interim Status Corrective
Action Order
Notification of HW Activity
National Drinking Water
Compliance Schedule -
Effective Date
National Drinking Water
Regulations
PWS - Notice to Persons
Served
PWS -Viol of !414(g)AO
PWS Administrative
Penalty Case Collection
Action
Variances
Exemptions
Lead Pipe, Solder & Flux
UIC Regulations
Law
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
RCRA
SDWA
SDWA
SDWA
SDWA
SDWA
SDWA
SDWA
SDWA
Law
Section
Code
3017
3018D
3020
3023
4005A
7003
9002
9003
9003C
(3)-(4)
9005
9006A
9006D
1422/ 1423
1423C
1423C7
1431
1432
1441
1445
1463
Law Section Description
Export of Haz Waste
Information Gathering &
Enforcement Authority -
Domestic Sewage
Underground Injection of
Hazardous Waste
HW Discharge to Fed-
Owned Treatment Works
Solid Waste Management -
Subtitle D
Imminent Order: Solid or
Hazardous Waste
UST Notification
Requirements
UST Release Detection,
Prevention, Correction
UST Release Detection,
Prevention, Correction
Inspection, Monitoring,
Testing, Corrections
UST Compliance Order
UST Civil Penalties
UIC Regulations Classes I-V
UIC- Violation of 1423(c)
AO
UIC Administrative Penalty
Case Collection Action
Emergency Powers
Tampering with a PWS
Adequate Supplies of Chems
Recordkeeping & Access
Lead in Water Coolers
3-13
-------
Table 3-4. Reference Law Sections, Question 8 (Continued)
Law
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
Law
Section
Code
II
12
13
15-2
I6A4
203
205
206
207 A2
207A5
208
215
4
402
406A
Law Section Description
Inspections & Subpoenas
Exports
Imports
Knowing Commercial Use
Failure to Pay Civil Penalty
School Asbestos Regs
Plan Submission - LEA
Asbestos - Contractor/Lab
Certification
False Information on
Asbestos Inspection
False Asbestos Information
under 205(d)
Asbestos Emergency Auth
Asbestos Worker Protection
Good Laboratory Practices
and Testing Requirements
Lead (Pb) Paint Training
and/or Certification
HUD 10 18 Disclosure Rule
Law
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
TSCA
Law
Section
Code
406B
409
5A/5B
5E
5F
5H
6
6-PCBS
7
8
8A
8B
8C
8D
8
Law Section Description
Renovation/Lead Haz
Pamphlet
Violation of Section 1018
Failure to Comply w/
Significant New Use Rules
and Pre-manufacture Notice
Failure to Comply with 5E
Consent Order
Violation of Unreasonable
Risk AO
Failure to Comply w/ New
Chemical
Asbestos Hazard Emergency
Response Act (AH ERA)
PCBs
Imminent Hazard
Reporting & Records
Retention
Failure to Comply w/ Prelim.
Assess Inf Repting &
Chemical Specific Record-
keeping Rules
Failure to Comply w/
Invention Update Rule
Failure to Comply w/
Allegations of Sig Adverse
React. Record & Rptmg
Rule
Failure to Comply w/ Health
and Safety
Failure to Comply w/
Substance Risk
3-14
-------
Table 3-5. Definitions for Question 20
Compliance Action
Definition
Actions with Direct Environmental Benefits and/or Direct Response/Corrective Action
Source Reduction/Waste
Minimization (RCRA)
Industrial/Municipal Process Change
(includes flow reduction)
Emissions/Discharge Change
Implement Best Management
Practices (BM Ps)
Wetlands Mitigation
In-situ and Ex-situ Treatment
Waste Treatment (RCRA/TSCA)
Removal of Spill
Removal of Contaminated Medium
Containment (CERCLA)
This category covers the reduced use of chemicals or other input
materials at the beginning of an industrial process, thereby eliminating
the amount of waste/emission/discharge produced by the process.
This category includes process-based facility-specific activities relating
to changes in industrial processes and procedures other than pollution
control equipment. E.g., upgrading of equipment or processes to reduce
the emission of a pollutant at the point of its generation
This category primarily impacts CWA and CAA cases where water
discharges or air emissions are reduced through end-of-pipe treatment
technologies. Examples include bringing waste water discharges into
compliance with NPDES standards or water quality standards, requiring
air emission reductions to comply with CAA standards, or eliminating a
pollutant discharge to surface water or groundwater.
This category covers practices thut have been determined to be the most
effective and practical means of preventing or reducing pollution These
practices are often employed in agriculture, forestry, mining, and
construction. EPA has published BMPs for soil erosion, wastewater
treatment, fuel storage, pesticide and fertilizer handling and the
management of livestock yards This action type is applicable to SPCC,
storm water, some NPDES requirements, and CAFO cases
This category involves returning a developed or degraded location to its
previous undeveloped state or to thut which mimics natural
characteristics. This category includes wetlands restoration, creation,
and preservation of wetlands.
This category covers CWA/OPA, CERCLA and RCRA corrective action
clean-up activities in which a contaminated medium is treated (either m-
situ or ex-situ), stabilized or otherwise addressed E.g., CERCLA clean-
up activities involving contaminated soil and/or groundwater in-situ
treatment
Any method, technique, or process designed to physically, chemically, or
biologically change the nature of a hazardous waste.
This category covers oil spill cleanups under CWA 3 1 1 (b)
This category covers cleanup of wastes or contaminated material to
address acute threats to humans, environment, or property for
underground storage tank spill clean ups and corrective action clean ups
under CERCLA/RCRA.
This category includes response or corrective actions that encapsulate,
cover, or create physical forces (e.g., hydraulic gradients) to keep
contaminants in place but do not reduce the concentration or physical
extent of the contamination.
3-15
-------
Table 3-5. Definitions for Question 20 (Continued)
Compliance Action
Leak Repair (CAA)
Import Denied (FIFRA)
Definition
This category includes process piping and equipment repair activities that
stop fugitive emissions from process equipment leaks from occurring.
This category is specific to CAA.
This category includes all persons or companies importing pesticides into
the United States who's EPA Form 3540- 1 has been denied acceptance
This form, which is presented to U.S. Customs at the time the pesticide is
being imported, gives basic information on the chemical formulation of
the product being imported, the names of the broker and shipper, the
EPA Registration Number and other information Import can be denied
without completion and acceptance of this form.
Prcventative Actions to Reduce Likelihood or Future Releases
Disposal Change
Storage Change
Develop/Implement Asbestos
Management Plan
Develop/Implement Spill Prevention
and Countermeasures Control
(SPCC) Plan
Obtain Permit for Underground
Injection (UIC)
UIC Plug and Abandon
UIC Demonstrate Mechanical
Integrity
UST Tank Closure
UST Secondary Containment
UST Corrosion or Overfill Protection
RCRA Labeling/Manifesting
This category includes activities involving disposal of waste and spent
products. This action will commonly occur under a RCRA or TSCA
PCB action where improper storage, transportation, or disposal of
hazardous waste results in an action forcing proper waste disposal An
example includes proper disposal of waste and spent products at an
approved hazardous waste landfill
This category includes activities involving storage of waste and spent
products. Examples include modifications of the storage for used oil at a
facility, changes in CAFO storage pond requirements and changes to
hazardous waste storage areas, and container management.
This category covers actions requiring the development and
implementation of an asbestos management plan under TSCA 203
This category covers actions requiring the development of a spill
prevention plan under CWA - 3 1 l(j).
This category is specific to the underground injection (UIC) program
when an entity is cited for failure to obtain a permit for an underground
injection well.
This category refers specifically to the plugging and abandonment of
injection wells under the UIC program.
This category refers to action in the UIC program that will provide
assurance that there will not be fluid movement in the well annulus.
This category is specific to the requirement that an UST storage tank be
closed.
This category is specific to the implementation of a secondary
containment system around an underground storage tank
This category is specific to the implementation of corrosion or overfill
prevention technologies on an underground storage tank (e.g., addition of
level controls/alarms for overfill prevention orcathodic protection)
This category is specific to actions that require proper labeling and
manifesting of RCRA hazardous wastes.
3-16
-------
Table 3-5. Definitions for Question 20 (Continued)
Compliance Action
Definition
RCRA Waste Identification
This category is specific to the identification of hazardous waste under
RCRA.
RCRA Secondary Containment
This category is specific to the implementation of a secondary
containment system around an underground or above ground storage
tank
Lead-Based Paint Disclosure
Lead rules require disclosure of known lead-based paint and/or lead-
based painting hazards by persons selling or leasing housing constructed
before 1978 and ensures that information is provided to owners and
occupants concerning potential hazards of lead-based paint exposure
before certain renovations are begun.
Lead-Based Paint Removal
Training/Certification
Covers TSCA 402, 1018, and 206 requirements regarding training and
certification Lead rules require that training programs and training
providers be approved and accredited.and that firms and/or persons
conducting certain activities be properly trained and certified.
Asbestos Training/Certification/
Accreditation
AHERA requires that persons conducting specified asbestos activities be
trained and accredited.
Asbestos Abatement
This applies to asbestos NESHAP cases requiring the removal and
disposal of asbestos materials from buildings, schools, and housing as
part of renovation and demolition projects.
Notification (SDWA, FIFRA)
This category covers compliance actions requiring a facility to provide
public notice under SDWA or FIFRA, or notification to the public or a
government agency of a release (e.g , required notifications to the
National Response Center, or notification of hazardous reportable
quantity release).
Worker Protection (FIFRA)
The purpose of EPA's Worker Protection Standard (WPS) is to protect
agricultural workers from the effects of exposure to pesticides This
standard is aimed at reducing the risk of pesticide poisonings and injuries
among agricultural workers and handlers of agricultural pesticides.
Pesticide Registered (FIFRA)
Registered pesticides are those pesticides that EPA has approved -- after
strict testing — for use in your home Pesticides are regulated under
several laws, primarily the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA), which authorizes EPA to oversee the
registration, distribution, sale, and use of pesticides. Individuals
registering pesticides must do so in a manner not only consistent with
federal laws, but also consistent with state laws and regulations which
differ from state to state.
Pesticide Certified (FIFRA)
Certain Pesticides may be applied only by or under the direct supervision
of specially trained and certified applicators Certification and training
programs are conducted by states, territories, and tribes in accordance
with national standards.
Pesticide Claim Removed (FIFRA)
This category includes action to make a pesticide manufacturer remove
certain claims from their products. For example, a manufacturer could be
required to remove the claim "this product disinfects" if the product is
not registered under FIFRA
3-17
-------
Table 3-5. Definitions for Question 20 (Continued)
Compliance Action
Pesticide Label Revision (FIFRA)
Definition
In general, states have primary authority Tor enforcing against use of
pesticides in violation of the labeling requirements The agency with
primary responsibility for pesticides differs from state to state. Usually it
is a state's department of agriculture, but may be a state's environmental
agency or other agency. Pesticide labeling is also regulated under the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
Facility/Site Management and Information Practices (FMIP)
Testing/Sampling
Auditing
Labeling/Manifesting (non-RCRA)
Record-keeping
Reporting
Information Letter Response
Financial Responsibility
Requirements
Environmental Management Review
RI/FS or RD (CERCLA)
Site Assessment/ Characterization
(CERCLA)
Laboratory or other types of testing and sampling to determine the hazard
of a waste or the toxicity of a chemical or release
This category involves cases where environmental audit is included with
the settlement/order as a means for identifying problems and reducing the
likelihood of similar problems recurring
This category applies to actions that require proper labeling and
manifesting for non-RCRA cases
This category includes types of record keeping ranging from records of
sampling and analysis of hazardous waste to records of inspections and
maintenance. E g., requiring a facility to maintain underground storage
tank monitoring records
This category includes reporting required by regulations or permits, c g ,
DMR reports required under the NPDES regulations
This category includes compelling response by a recipient to a formal
request for information relating to an uncontrolled hazardous waste site
This category includes actions that compel owners or operators to show
that they have the financial resources to clean up a site if a release
occurs, correct environmental damage, and/or compensate third parties
for injury to their properties or themselves.
This category covers conducting an environmental management review,
which includes reviewing organizational structure, planning activities,
responsibilities, practices, procedures, processes and resources for
developing, implementing, achieving, reviewing, and maintaining an
organization's environmental policy
Remedial lnvestiganon(Rl)/Feasibility Study(FS) or Remedial
Design(RD) This category covers investigation and study of
requirements for extensive cleanup of a hazardous waste site E.g.,
evaluating where buried waste may have mrgrated into adjoining
watercourses
This category includes collecting site samples and data to assess the
seventy of a contamination hazard. E.g., a site/facility where indications
suggest an extensive cleanup may be required
3-18
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Table 3-5. Definitions for Question 20 (Continued)
Compliance Action
Provide Site Access (CERCLA)
Monitoring
UST Release Detection
Storm water Site Inspections
Asbestos Inspections
Training
Planning
Permit Application
Work Practices
Notification (TSCA Section 6)
Leak Detection (CAA)
Spill Notification
Definition
This category includes compelling facility/site owners to admit EPA
officials entry to inspect or assess hazards E g., gaming entrance to a
fenced, locked storage area containing potential leaking drums where
admittance has been denied
This category includes monitoring activities performed to assess whether
a pollutant release is occurring.
This category includes leak detection activities performed to assess
whether a pollutant release is occurring. This category is specific to
RCRA UST cases.
This category refers to the storm water site BMP inspections required by
federal storm water regulations.
This category refers to asbestos inspections required under TSCA 203
(AHERA)
This category includes worker training programs
This category covers actions requiring the development of or
improvement to a plan. E.g., preparation of a Storm Water Pollution
Prevention Plan Implementation of a plan should be reported under
individual implementation activities (e g use reduction, BMPs, etc )
This category includes participation in a required permit process by an
un-permitted facility. E.g., an inspected facility storing hazardous wastes
onsite without notification or permit.
This category includes any modification of business practice to facilitate
the protection of human health and the environment For example, a
business may be sand-blasting part of a bridge without proper
environmental protection and this practice is stopped (Unlike BMP's,
this type of pollutant reduction is not quantifiable
This category includes notification of fire response personnel and
adjacent building owners in the event of a release of PCBS
This category includes leak detection activities performed to assess
whether a pollutant release is occurring This category is specific to
CAA cases
This category covers oil and hazardous substance spill notification
requirements covered by CWA Section 311.
3-19
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Table 3-6. Question 19 and 22 Entries for "Media"
Air
Animals/Plants/Humans
Land
Schools/Housmg/Buildmgs
Soil
Soil Vapor
Water (biosolids and other sludges)
Water (drinking)
Water (ground)
Water (underground source of drinking water)
Water (navigable/surface)
Water (sediment)
Water (storm water)
Water (wastewater to POTW)
Water (wetlands)
Table 3-7. Question 19 and 22 Entries for "Units"
Units
ACRES
Building units
yd3
gal
Guls
Housing units
SF
Housing units
MF
Ibs
Definition
Acres
Number of Building units
Cubic Yards
Gallons
Gallons Spilled
Number of Single Family
Housing units
Number of Multi-family
Housing units
Pounds
Units
LBS/YR
LFss
LFms
LFIs
PEOPLE
Schools
Wells
Definition
Pounds Per Year
Linear Feet of small stream (< 10 ft wide)
Linear Feet of medium stream (10-20 ft wide)
Linear Feet of large stream (> 20 ft wide)
People (SOW A/FIFRA)
Number of Schools
Number of Wells
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Table 3-8. Definitions for Question 17
SEP Category
Public Health
Pollution Prevention
Pollution Reduction
Environmental Restoration
and Protection
Assessments and Audits
Environmental Compliance
Promotion
Emergency Planning and
Preparedness
Definition
A project which provides diagnostic, preventative, and/or remedial components
of human health care related to the health damage caused by the violation
A project which reduces the generation of pollution through source reduction
This category includes seven specific subcategones of actions including,
equipment or technology modifications; process or procedure modifications;
product reformulation or redesign, raw materials substitution; improved
housekeeping, operation and maintenance activities, training, or inventory-
control, in-process recycling; and energy efficiency and conservation activities.
If the pollutant or waste stream has been generated, pollution prevention is no
longer possible and the waste must be handled by appropriate recycling,
treatment or disposal methods.
A project which results in a decrease in the amount or toxicity of any hazardous
substance, pollutant or contaminant entering a waste stream or otherwise being
released into the environment (e g, waste recycling, waste treatment).
A project which goes beyond repairing the damage caused by the violation to
enhance the condition of the environment adversely affected.
Pollution prevention assessments are systematic, internal reviews of specific
processes and operations designed to identify and provide information about
opportunities to reduce the use, production, and generation of toxic and
hazardous materials and other wastes. Site assessments are investigations of the
condition of the environment at a site, or of the environment impacted by a site,
and/or investigations of threats to human health or the environment relating to a
site. Environmental compliance audits are an independent evaluation of a
defendant/respondent's compliance status with environmental requirements
A project which involves disseminating information or providing training or
technical support to a regulated party or to some or all members of the
defendant/respondent's economic sector
A project where a defendant/respondent provides assistance, such as computers
and software, telephone/radio communication systems, chemical emission
detection and inactivation equipment, HAZM AT equipment, or training for first
responders to chemical emergencies, to a responsible state or local planning
entity.
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4.0 GUIDE FOR POLLUTANT REDUCTION/ELIMINATION CALCULATIONS
This section presents a general overview of when and how to estimate pollutant
reductions/eliminations associated with enforcement actions. Sections 5.0 through 10.0 present
the following Regulatory Act discussions and specific examples for water, air, and
solid/hazardous wastes:
Act
CWA/
SDWA
CAA
RCRA/
CERCLA
TSCA
FIFRA
Media
Water
Air
Solid/Hazardous
Waste
Solid/Hazardous
Waste
Solid/Hazardous
Waste
Example Description
CWA/NPDES
CWA/SPCC
Storm water Violations
Violations for CAFOs
Combined Sewer Overflow CSO
Sanitary Sewer Overflow SSO
Wetlands
SDWA PWSS Violations
SDWA UIC Violations
NO, Reduction at a Petroleum Refinery
under PSD/NSR
SO: and HAP Reduction at a Pulp and
Paper Mill under MACT
Leak Detection And Repair
RCRA Subtitle C
RCRA UST
RCRA/Superfund Corrective Actions
TSCA Lead-based Paint
TSCA Section 6
Asbestos under TSCA/AHERA and
CAA NESHAP
FIFRA
Section Number
5 1
5.2
53
54
55
56
5.7
58
59
6.1
62
6.3
7.1
72
73
8.1
82
83
9.1
4-1
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4.1 When Do You Need to Calculate Pollutant Reductions/Eliminations or
Environmental Benefit?
When the civil, judicial or administrative order requires the respondent to take actions that
reduce, eliminate, or treat pollutant releases; or properly manage waste streams, then the
program office technical lead or lead attorney should report an estimate of the environmental
benefit of those actions at CCDS Question 22. The first column of CCDS Question 20 can be
broken down into the following types of complying actions:
Actions with Direct Environmental
Benefits/Response/Corrective Action
Source Reduction/Waste Minimization
Industrial/Municipal Process Change
Emissions/Discharge Change
Implement Best Management Practices
Wetlands Mitigation
In-situ and Ex-situ Treatment
Waste Treatment
Removal of Spill
Removal of Contaminated Medium
Containment
Leak Repair
Import Denied
PreventiUive Actions to Reduce the Likelihood of
Future Releases
Disposal Change
Storage Change
Develop/Implement Asbestos Management Plan
Develop/Implement Spill Prevention and Countermeasures
Control (SPCC) Plan
Obtain Permit for Underground Injection (UIC)
UIC Plug and Abandon
UIC Demonstrate Mechanical Integrity
UST Tank Closure
UST Secondary Containment
UST Corrosion or Overfill Protection
RCRA Labeling/Manifesting
RCRA Waste Identification
RCRA Secondary Containment
Lead-Based Paint Disclosure
Lead-Based Paint Removal Training/Certification
Asbestos Training/Certification/Accreditation
Asbestos Abatement
Notification (SDWA. FIFRA)
Worker Protection
Pesticide Registered
Pesticide Certified
Pesticide Claim Removed
Pesticide Label Revision
EPA regional workgroups have evaluated each of these complying action types and have
determined on a statute basis the best method for determining the environmental benefit.
Depending on the statute and complying action, the environmental benefit may be measured as a
reduction/elimination or treatment of pollutants (reported in pounds) or may include other units
of measure to represent the environmental or human health benefit (such as acres or linear feet
4-2
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for wetland cases and population for SDWA cases). A discussion of appropriate calculation
methodologies and measurement units is provided in the subsections of Sections 5.0 through 9.0
below. In addition, if a case includes a SEP incorporating pollution prevention, pollution
reduction, or environmental restoration, then the environmental benefit of the SEP project should
be estimated and reported at CCDS Question 19.
4.2 How Do You Calculate Pollutant Reductions/Eliminations?
The following sections present the basic methodology to use in estimating pollutant reductions
or eliminations and a discussion of the time basis to use in these calculations.
4.2.1 Categories of Outcomes for GPRA Reporting Purposes
OECA currently reports the Ibs of pollutants estimated to be reduced or treated under GPRA.
OECA expands on this outcome measure for our End-of-Year reporting purposes to include:
estimated cubic yards of contaminated soil/aquifer to be cleaned up; linear feet of stream miles
mitigated; acres of wetlands protected/mitigated; and number of people receiving cleaner
drinking water. With the addition of the new prevention measures covered in this guide, these
EOY categories are likely to expand to also include: number of underground injection wells
protected from leaking; gallons of oil prevented from spilling or leaking; number of housing
units notified of lead-paint risks; school and buildings protected from asbestos exposure; people
notified of potential drinking water hazardous; and pounds of unregistered pesticides removed
from commerce.
4.2.2 Basic Methodology
For many of the CWA and CAA cases you will calculate the estimated reduction that will occur
in the pollutant or pollutants of concern in terms of the level that they are being released at above
the allowable permit level. The enforcement action is estimated to return the facility to
compliance and therefore bring the allowable amount of pollutant level down to the permitted
level. To commonly describe these reductions across media we express this reduction in pounds.
For RCRA, CERCLA and TSCA (asbestos, PCB, and lead-based paint) cases that involve in-situ
or ex-situ treatment, removal, and proper disposal of contaminated media, you should report the
volume of contaminated media impacted by the action instead of pounds of pollutant.
To calculate pollutant reductions or eliminations for water and air cases, you need to use the
difference between the current "out of compliance" concentration and the post-action "in
compliance" concentration for each pollutant of concern. This difference is then converted to
mass per time using flow or quantity information from the case. The following steps outline the
general method to follow to estimate a pollutant reduction/elimination.
Step A Determine the average "out of compliance" concentration of each pollutant
(concentrations are usually reported in mg/1 or ug/1).
Step B Determine the post-action concentration for each pollutant (this may be a permit
limit, a prescribed action level, or the assumption of complete elimination of the
pollutant).
4-3
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Step C Determine average flow or quantity of media impacted.
Step D Determine the incremental concentration by which the pollutant is out of
compliance by subtracting the post-action concentration from the "out of
compliance" concentration.
Incremental Concentration = Out of compliance cone. - Post-action cone.
Step E Determine the incremental loading using flow or quantity information, for
example:
Loading (Ibs/day) = Incremental Concentration (mg/L) * Flow (MOD) * 8.34
- 8.34 (Conversion Factor) = (g/1000 mg) x (lb/454 g) x (3.78 L/gal) x (1E6
gal/Mgal)
Step F Report on the CCDS form the total pollutant reduction that will occur during the
first year of post-action compliance.
Pollutant Reduction (Ibs) = Loading (Ibs/day) x Discharge Time (days/year) x
I year
4.2.3 Calculation Basis for Time
OECA has conservatively chosen to use one year as the period of time over which a reduction/
elimination credit is taken. OECA is requesting that the annual pollutant reduction ONCE the
complying action(s) have been fully implemented be reported on the CCDS form. Thus, if the
pollutant reduction is a continuous action (e.g., implementation of a treatment technology), you
would report one year's worth of pollutant removal benefits. For example, if the complying
action will include the addition of new treatment technology over several years at a facility, then
the pollutant benefit for CCDS represents the pollutant reduction that occurs over one year once
the technology has been put into place. If the pollutant reduction occurs as a one time (or short
term) action then you report the total pollutant removal benefit.
Despite when the benefits occur (whether they will occur now or later), report benefits in the
year in which the case is settled.
For complying actions that properly manage a waste (e.g., corrective actions) or result in
prevention of pollution, report the total amount/volume of media impacted by the action. For
statute specific instructions and examples see the subsections in Sections 5.0 through 9.0 below.
4-4
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s.o WATER EXAMPLES
Under the CWA the following types of enforcement cases are typical:
• 5.1 Enforcement actions against facilities that are out of compliance with their
NPDES permit, including cases involving a violation of permit limits or
conditions, discharge without a permit, and cases for industrial users
subject to pretreatment standards, (pg. 5-2)
• 5.2 Enforcement actions resulting from an oil spill or the need to prevent oil
spills under CWA 311, the Spill Prevention, Control and Countermeasures
(SPCC) program, (pg. 5-6)
• 5.3 Enforcement actions to control solids (sediment) and other pollutant loses
from CWA 301/402 cases related to stormwater violations, (pg. 5-8)
5.4 Enforcement actions to
control wastewater
discharges or releases
occurring at concentrated
animal feeding
operations (CAFOs).
These cases reduce or
EPA is currently developing desk-top based
"expert system/spreadsheets" for CAFO,
CSO and SSO type cases that will walk you
through the calculations (including the
conversions of concentration to mass).
eliminate the discharge of storm water contaminated with raw animal
manure whose pollutants of concern include BOD, COD, TSS,
phosphorus, nitrogen, and pathogens, (pg. 5-16)
• 5.5 & 5.6 Enforcement actions limiting or eliminating combined sewer overflows
(CSOs) and sanitary sewer overflows (SSOs). These cases reduce or
eliminate the discharge of sanitary wastewater whose pollutants of
concern include BOD, COD, TSS, phosphorus, nitrogen, and pathogens.
(pgs. 5-26, 5-30)
• 5.7 Enforcement actions under CWA 404 impacting wetlands, (pg. 5-33)
• 5.8 & 5.9 Actions stemming from Safe Drinking Water Act violations under the
Public Water Supervision (PWSS) program and the Underground
Injection Control (UIC) program, (pgs. 5-35, 5-36)
The sections below present methodologies for determining pollutant reductions and
environmental benefit for typical cases involving a water media. Each section includes
information on the following:
• Background;
• Calculation methodology; and
• Example calculations and IC1S input using specific scenarios.
5-1
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5.1 Clean Water Act/NPDES
5.1.1 Background
The CWA requires point sources discharging to waters of the United States to obtain a National
Pollutant Discharge Elimination System (NPDES) Permit. The NPDES program is implemented
through site-specific or general permits that may be as stringent as or more stringent than
national regulations. The NPDES program is enforced by comparing actual discharges or
discharge conditions to the permitted level of pollutant discharges or discharge conditions.
The NPDES program regulates industrial process discharges from direct and indirect
dischargers, municipal sewage treatment plant effluent, and storm water runoff. Direct
dischargers discharge water directly to surface waters while indirect dischargers discharge to a
publicly owned treatment works (POTW). Limitations may be set for indirect dischargers to
prevent interference with POTW treatment processes or pass-through of the pollutants to surface
waters. EPA's Office of Water, Office of Science and Technology has set effluent limits for
various industries. Information can be found on their website at
www.epa.gov/waterscience/guide. The regulations are listed in 40 CFR Part 401 through Part
471.
General permits cover several facilities that have the same type of discharge and are located in a
specific geographic area. General permits apply the same or similar conditions to all dischargers
covered under the general permit. An example would be an industrial facility whose stormwater
discharges are covered by a general stormwater permit. Information on general permits can be
found on EPA's website at http://cfpub.epa.gov/npdes/permitissuance/genpermits.cfm.
Many NPDES cases will involve complying actions that reduce, eliminate or treat specific
pollutants. The pollutant reduction may be realized through changes to an end-of-pipe treatment
system, process-based activities, chemical use reduction or chemical substitution, or
implementation of a best management practice. Typical physical CWA/NPDES complying
actions include:
Actions with Direct Environmental Benefits/Response
or Corrective Action
Source Reduction
Industrial/Municipal Process Change
Emissions/Discharge Change
Implement Best Management Practices (BMPs)
For these cases you should:
• Check those complying actions that apply;
• Identify the pollutant name(s) impacted by the action, and
• Calculate pollutant reductions estimated to occur from implementation of the action.
The typical units and media that will apply for the direct complying actions are "pounds" (of
pollutant reduced per year) and "Water (navigable/surface)" or "Water (wastewater to
POTW)".
5-2
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5.1.2 Calculation Methodology
To calculate pollutant reductions for water, use the difference between the permit limit (which
will be expressed as a concentration and/or mass) and the sampled concentrations or mass. For
cases based on a one-day violation, use the daily maximum concentration as your exceedence
concentration and calculate the loadings for one-day pollutant reduction. For cases based on a
one- to three-month violation, use the highest monthly average concentration as your initial out-
of-compliance concentration and calculate the reductions for that time period.
If facility history indicates that there has been potentially long term non compliance, for
example, it has had more than three months of exceedences or is on the EPA Watch List or
QNCR Exceptions list, then you may want to assume that they would have continued violating
throughout the year had the action not stopped. For these cases, use the highest monthly
exceedence and calculate one year's worth of reductions.
The following steps outline the general method that should be followed to calculate the pollutant
reduction for exceedences that are more than a one day event. This method can be used for all
pollutants for which pre-comphance and permit concentrations are known.
Methodology to Calculate Pollutant Reductions Tor Water
Step A Determine the monthly average "out-of-comphance" concentration of each pollutant in mg/L.
Step B Determine the enforceable limits for each pollutant in mg/L.
[In cases where holh a maximum daily and a monthly average limit are given, the pollutant
reduction should he calculated iiMiig the monihlv average Mass limit.'; can he converted to
concentration limil\ ax follows
Concentration limit\ (mg/L) = Mass limits (Ibs/day)/ [Flow (MOD) x 8 34 Ihs/MG/mg/LJ
Step C Determine average flow in million gallons per day (MOD).
Step D Determine the concentration by which the pollutant is out of compliance by subtracting the permit limit
from the "out-of-comphance" concentration.
Exceeded Concentration (mg/L) = Out-of-compliance concentration - Permit Limit
Step E Determine the exceeded loading in pounds by using the following formula:
Loading (Ibs/day) = Exceeded Concentration (mg/L) * Flow (MOD) * 8 34
8 34 (Conversion Factor) = (g/1000 mg) x (lb/454 g) x (3 78 Ugal) x (IxlO" gal/MG)
Step F Report the total pollutant reduction in pounds in 1C1S. Identify "Water (navigable/surface)" or "Water
(wastewater to POTW)" as the impacted media.
5-3
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5.1.3 Example Calculations and Input for ICIS
Example 1. NPDES Permit Violation for Direct Industrial Discharger
The method used to calculate pollutant reductions for a permit violation by an industrial
discharger is similar for all industries. The permit limits (either as a concentration or an
allowable mass discharge) are compared with the average "out-of-compliance" pollutant
concentration (or mass discharge) obtained from sampling. This example calculates a pollutant
reduction from a chemical manufacturing plant but could be used for any industry.
NPDES sampling by the Sunburst Chemical Company indicates that the plant has been
consistently discharging elevated concentrations of Biochemical Oxygen Demand (BOD) and
Total Suspended Solids (TSS) for over four months. Under an enforcement order, the facility is
upgrading their end-of-pipe treatment system to bring the plant into compliance. The highest
monthly out of compliance average effluent concentrations of BOD and TSS are 100 mg/L and
120 mg/L, respectively, and the mill's treatment system processes on average 6.0 million gallons
per day (MGD). The plant's permit specifies a BOD limit of 1,000 pounds/day and a TSS limit
of 1,500 pounds/day. The plant discharges 365 days per year.
Since this facility has a history of out-of-compliance discharges, use their highest monthly
average concentrations as the out-of-compliance concentration and determine one year's worth
of reductions.
Step A Out-of-compliance concentrations:
BOD =100 mg/L
TSS= 120 mg/L
Converted to mass discharge:
BOD mass discharge = 100 mg/L x 6.0 MGD x 8.34 = 5,000 Ibs/day
TSS mass discharge = 120 mg/L x 6.0 MGD x 8.34 = 6,000 Ibs/day
Step B Enforceable limits in mass per day:
BOD =1,000 Ibs/day
TSS= 1,500 Ibs/day
Step C Flow = 6.0 MGD
Step D and E BOD Exceeded Mass = 5,000 Ibs/day - 1,000 Ibs/day = 4,000 Ibs/day
TSS Exceeded Mass = 6,000 Ibs/day - 1,500 Ibs/day = 4,500 Ibs/day
Step F Assume that the chronic nature of the plants exceedences will result in a full years
worth of environmental benefit once the compliance action has been
implemented. Pollutant Reduction (Ibs) = Loading (Ibs/day) x Time (days/year) x
1 year
BOD Reduction = 4,000 Ibs/day x 365 days/yr. x l yr. = 1,460,000 Ibs.
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TSS Reduction =4,500 Ibs/day x 365 days/yr x | yr.= 1,640,000 Ibs.
Input for ICIS is as follows:
• Complying Action: Emissions/Discharge Change;
Pollutant: BOD
Unit: 1,460,000 Pounds
• Media: Water (navigable/surface)
AND
Pollutant: TSS
Unit: 1,640,000 Pounds
• Media: Water (navigable/surface).
Example 2. NPDCS Permit Violation for an Indirect Discharger (Pretreatment
Violation)
Note: For pretreatment cases, the time frame to use in determining pollutant
reductions should be determined based on the nature of the case and best
professional judgement. This may be a particular issue with batch processing where
exceedences do not occur continuously.
Sampling at ThinkFast Printed Wiring Board Manufacturing Corporation indicated elevated
concentrations of cadmium during a two month period. The average elevated effluent
concentration of cadmium for the two month period was 0.39 mg/L. ThinkFast discharges
wastewater to the local POTW. Their pretreatment permit limits cadmium at a maximum daily
effluent concentration of 0.14 mg/L and a maximum monthly average of 0.09 mg/L. Under an
enforcement order, the facility is implementing a process change to bring the plant into
compliance. The average annual discharge of the plant is 25 million gallons. The plant operates
and discharges wastewater 5 days a week, 24 hours a day.
Step A Actual average concentration:
Cadmium = 0.39 mg/L
Step B Enforceable limit:
Cadmium = 0.09 maximum monthly average
Step C Flow = 25 MG/year
Compute flow in million gallons per day. The site operates 5 days a week.
Flow (MGD) = 25 MG/year x 1 year/260 days = 0.0962 MOD
Step D Cadmium Exceeded Concentration = 0.39 - 0.09 = 0.30 mg/L
Step E Pollutant Reduction (Ibs/day) = Incremental Concentration (mg/L) x Flow
(MGD) x 8.34 (Ibs/MG/mg/L)
Cadmium Loading = 0.30 (mg/L) x 0.0962 (MGD) x 8.34 = 0.2407 Ibs/day
5-5
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Step F Since the exceedences were only temporary, only two months of environmental
benefit will be reported in ICIS. Therefore, Pollutant Reduction (Ibs) = Loading
(Ibs/day) * 30 days/month x 2 months
Cadmium Reduction = 0.2407 Ibs/day x 30 days/mo, x 2 mo. = 14.4 Ibs
Input to ICIS is as follows:
Complying Action: Industrial/Municipal Process Change
Pollutant: Cadmium
Unit: 14.4 Pounds
Media: Water (wastewater to POTW)
5.2 Clean Water Act - 311 SPCC and Spill Clean-up Provisions
5.2.1 Background and Methodology
Section 311 of the CWA addresses pollution from oil and hazardous substance releases and
provides EPA with the authority to establish programs for preventing, preparing for, and
responding to oil spills that occur in navigable waters of the U.S. In addition, in August 1990,
the Oil Pollution Act (OPA) was signed into law. The OPA, enacted largely in response to
public concern after the Exxon Valdez incident, improved the nation's ability to prevent and
respond to oil spills by requiring facility owners or operators to prepare facility response plans
addressing a worst-case discharge of oil. The statute requires the notification of authorities of oil
or hazardous substance discharges. The regulations require the Oil Spill Prevention, Control,
and Countermeasures (SPCC) program and the Facility Response Program (FRP). The SPCC
program applies to non-transportation related facilities that have a large oil storage capacity and
could reasonably be expected to discharge oil into navigable waters. The SPCC regulations
require each owner or operator of a regulated facility to prepare an SPCC plan.
Enforcement actions related to CWA SPCC cases may include the following types of direct and
preventive complying actions:
Statute/Section
Violated
Oil or hazardous
substance spill
3H(b)(3)
RCRA 7003
Actions with Direct
Environmental
Benefits/Response
or Corrective
Action
Removal of spill
Removal of
Contaminated
Medium
In-situ and Ex-situ
Treatment
Pollutant
Name
Oil or name
of hazardous
substance
Oil-
contaminated
soil
Amount
Total amount
recoverable
Cubic yards
of soil
removed
Unit
Gallons Spilled
(Recoverable
gallons)
Pounds
Cubic yards
Potential
Impacted
Media
Water
(navigable/
surface)
Soil
5-6
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Statute/Section
Violated
Spill prevention
CWA31IO)
Preventative
Actions to Reduce
Likelihood of
Future Releases
Develop Spill
Prevention and
Countermeasures
Control Plan (SPCC)
Pollutant
Name
Oil
Amount
Capacity of
holding
vessel
Unit
Gallons
Potential
Impacted
Media
Water
(navigable/
surface)
In addition, it is also very common for there to be an administrative penalty only type of
situation where an oil spill release has occurred. In these cases, the administrative action does
NOT require clean up - though the facility receiving the penalty may choose to conduct a clean
up on its own. These cases do not result in a direct or preventative action since they are "penalty
only" and you should not report an environmental benefit for these types of administrative
actions.
5.2.2 Examples and Input for ICIS
Three types of CWA/SPCC examples are presented below. Under the first example, an
administrative penalty is lodged against a facility for an oil spill. This is an example of a
"penalty only" type of action. In the second example, an enforcement action has been lodged
against a facility to require removal of an oil spill into a navigable body of water adjacent to the
oil storage facility. A determination of the gallons of recoverable oil and the amount of
contaminated soil to be removed is required for this case. The third example covers an
enforcement case requiring the facility to incorporate preventive measures.
Example 1. CWA/SPCC Administrative Penalty
ABC oil storage facility has been cited for an oil spill release from one of their tanks which has
reached and contaminated a nearby stream. The administrative action applies a penalty to the oil
storage facility.
Input for ICIS:
This is a "penalty only" action and no information on environmental benefit is reported into
ICIS.
Example 2. CWA/SPCC Removal
ABC oil storage facility has been cited for an oil spill release from one of their tanks which has
reached and contaminated a nearby stream. EPA issues a judicial case against the facility
ordering them to recover the spill. It is estimated that 10,000 gallons of No. 5 Fuel Oil were
released in the spill and that 8,000 of them were recoverable.
Input for ICIS:
5-7
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• Complying Action: Removal of spill
Pollutant: Oil
Unit: 10,000 Gallons Spilled
• Media: Water (navigable/surface)
Example 3. CWA/SPCC Prevention
Under an Expedited Settlement Agreement, XYZ oil storage facility has agreed to prepare an Oil
Spill Prevention Plan. The agreement requires the facility to develop and implement a plan and
will also require notification, and training of facility personnel once the spill prevention plan has
been developed. The facility includes 2 oil storage tanks with a total holding capacity of 30,000
gallons.
Input for ICIS:
• Complying Actions: Develop/Implement Spill Prevention and Countermeasures Control
(SPCC) Plan (Preventative), Spill Notification and Training (FMIP)
Pollutant: Oil
Unit: 30,000 gallons
• Media: Water (navigable/surface)
5.3 Stormwater Violations
5.3.1 Background and Methodology
Stormwater provisions under CWA Sections 301/402 impact stormwater discharges from
construction activities, industrial facilities, and municipalities.
Stormwater runoff from construction activities can have a significant impact on water quality.
As stormwater flows over a construction site, it picks up pollutants like sediment, debris, and
chemicals. Polluted stormwater runoff can harm or kill fish and other wildlife. Sedimentation
can destroy aquatic habitat and high volumes of runoff can cause stream bank erosion. The
NPDES Stormwater program requires operators of construction sites one acre or larger
(including smaller sites that are part of a larger common plan of development) to obtain
authorization to discharge stormwater under an NPDES construction stormwater permit. The
NPDES stormwater permits for regulated construction activities focus on the development and
implementation of stormwater pollution prevention plans. Environmental benefits of storm
water cases at construction sites are to be measured in terms of pounds of sediment reduced.
Stormwater is also an issue at industrial facilities and from Municipal Separate Storm Sewer
Systems (MS4s). Activities that take place at industrial facilities, such as material handling and
storage, are often exposed to stormwater. The runoff from these activities discharges industrial
pollutants into nearby storm sewer systems and water bodies. This situation may also adversely
impact water quality. To limit pollutants in stormwater discharges from industrial facilities, the
NPDES Phase I Storm Water Program includes an industrial stormwater permitting component.
Operators of industrial facilities included in one of 11 categories of "stormwater discharges
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associated with industrial activity" that discharge stormwater to a MS4 or directly to waters of
the United States require authorization under a NPDES industrial stormwater permit. If an
industrial facility has a Standard Industrial Classification (SIC) code or meets the narrative
description listed in the 11 categories, the facility operator must determine if the facility is
eligible for coverage under a general or an individual NPDES industrial stormwater permit. In
some cases, a facility operator may be eligible for a conditional/temporary exclusion from
permitting requirements. OECA is in the process of developing a pollutant reduction
methodology for reductions from industrial sites. In the interim, you should report acres covered
by the stormwater permit in ICIS.
The NPDES Phase I and II Stormwater Programs also required NPDES permit coverage for
stormwater discharge from Medium and Large MS4s located in incorporated places or counties
with populations of 100,000 or more and for certain regulated Small MS4s. Environmental
benefits of stormwater cases at MS4 sites has not yet been determined and reporting on MS4
environmental benefits is not currently required.
Enforcement actions related to CWA storm water cases may include the following types of direct
and FMIP complying actions:
Statute/Section
Violated
CWA 30 1/402
(for Construction
Permits)
CWA 301/402
(for Industrial and
MS4 Permits)
Complying
Actions with
Direct
Environmental
Benefits
Implement Best
Management
Practices
Implement Best
Management
Practices
Pollutant
Name
Sediment
Stormwater
Amount
Amount of
sediment
Number of
Acres covered
by SWPP '
Unit
Pounds
Acres
Potential
Impacted
Media
Water
(navigable/
surface)
Water
(navigable/
surface)
Will be changed to a pollutant reduction measure once a methodology is developed in 2005.
Statute/Section
Violated
CWA 30 1/402 (for
Construction, Industrial,
and MS4 permits)
CWA 301/402 (for
Construction, Industrial,
and MS4 Permits)
Complying Actions with
Facility Management and
Information Practices (FMIP)
Develop a Plan (e.g., SWPPP or
SWMP)
Permit Application
Pollutant
Name
Storm Water
Storm Water
Amount
NA
NA
Unit
NA
NA
Potential
Impacted
Media
NA
NA
5.3.2 Calculation Methodology for Determining Pounds of Sediment Reduced As a Result
of the Implementation of Best Management Practices at Construction Sites
EPA developed a model to estimate sediment reduction at construction sites as a result of the
implementation of stormwater best management practices. The model is available as an Excel
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spreadsheet at http://intranet.epa.gov/oeca/NPMAS. The model utilizes the Revised Universal
Soil Loss Equation (RUSLE) to determine soil loss and soil loss reduction. RUSLE was
developed by the United States Department of Agriculture (USDA) to estimate erosion. The
RUSLE equation uses the erosivity of rainfall, the erodibility of the soil, the length and slope of
the land area, and cover and conservation management practices on the land to estimate erosion
from a specific area. The RUSLE equation is expressed as:
T = RKLSCP
Where:
T = Predicted Soil Loss (tons per acre per year)
R = Annual Rainfall-Runoff Erosivity Factor
K - = Soil Erodibility Factor
LS = Length/Slope Factor
C = Cover Management Factor
P = Conservation Practice Factor
For the purposes of EPA's model, T will be expressed as tons of sediment loss per construction
site (or specified area of a construction site). The equation used in the EPA model is:
T = A x (RF) x K x LS x C x [1 - (Eff. x E)|
Where:
T = Predicted Soil Loss (tons)
A* = Area of Construction Site (in acres)
RF* = Erosivity Index (which incorporates the annual rainfall-runoff erosivity
factor (R) with the time period of construction (F))
K = Soil Erodibility Factor
LS = Length/Slope Factor
C = Cover Management Factor
Eff* = Efficiency of the Conservation Practice
E* = Effectiveness Factor for an existing BMP
* The area (A) and time period of construction (F) factors were added to the RUSLE equation to
determine soil loss in tons. The conservation practice efficiency (Eff.) is being adjusted by the
BMP effectiveness factor (E) to address cases where existing BMPs are improperly maintained.
The conservation practice factor (P) is equal to [1 - Eff]
The following steps outline the general method that should be followed to calculate the sediment
reduction for construction stormwater cases:
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Methodology to Calculate Sediment Reductions for Construction Stormwater Cases
Step A Determine the best method of using the EPA model for the specific site If appropriate, split up the
construction site into drainage areas or areas with specific BMPs
Step B Enter the disturbed area of the construction site (in acres) into the model
Step C Using the location and a one year time frame for the construction project, determine the location
specific RF factor appropriate for the site from the Texas A&M Erosivity Index Calculator website link
provided in the model Alternatively, use the model's drop down menu to identify the state in which
the construction site is located.
Step D Select an appropriate soil type for the site. Alternatively, you can input a specific soil credibility factor
into the model.
Step E Select an appropriate length and slope for the site. Alternatively, you can input a specific length/slope
factor into the model
Step F The C factor for the site is being set to 1.0
Step G Determine the BMP Eff factor for the site for pre-compliance conditions and the post-compliance
conditions. If there are existing BMPs at the site that are not being maintained or are being used
improperly, include an effectiveness factor (E) for the pre-compliance BMP efficiency factor
Step H Report the total sediment.reduction (in pounds) from the model output into ICIS Identify "Water
(navigable/surface)" as the impacted media.
From an inspection, you should have information on the location and acreage of the construction
site and erosion and sediment control BMPs that are used on site or that are being required as
part of the enforcement action. This information is needed to determine the erosivity index (RF)
factor, the area of construction (A) factor, and the efficiency of the conservation practice (Eff.)
for the model. You may or may not have specific information to determine the other factors in
the model. For each of these other factors, the model will present you with a drop down menu of
choices. You should use your best professional judgement to select one of the drop down menu
choices. If you do not know what menu item to select, then an average value can be used as
described in the questions and answers below.
How do I determine the acreage (A) to use in this model?
The disturbed area that is the basis of the enforcement action (in acres) should be estimated and input for
the area of construction (A) factor in the model.
How do I determine the rainfall-runoff erosivity (R) factor to use in this model?
Use the Texas A&M Erosivity Calculator (located on the internet at http://ci.tamu.edu/indcx.html) to
determine the value to input for this factor. Inputs for the Texas A&M Erosivity Calculator arc the
location of the construction site (the city or county and the state) and a time period for construction. The
spreadsheet model will provide you with the internet link and the output from the erosivity index
calculator can then be input into the model.
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As an alternative to the Erosivity Calculator, the model includes a drop down menu where you can select
the state in which the construction site is located (which will provide the model with a state specific
default R factor).
What should the time frame be for calculating pollutant reductions for storm water cases?
EPA is using an estimated benefit period of one year for construction stormwatcr cases to correspond with
the one year benefit periods for most other types of cases reported in ICIS. EPA realizes that the benefits
from BMPs at construction sites may occur over shorter or longer time frames.
Thus, if you use the Texas A&M Erosivity Calculator, you should input the location of the construction
site (using the city or county and the state) and a time period for construction. The time period of
construction should be estimated as one year (e.g., input January 1, 2004 to December 31, 2004 into the
crosivity index calculator). Or, if you use the drop down menu in the storm water model as an alternative
to the crosivity index calculator, you can select the state in which the construction site is located (which
will provide the model with a state specific default R factor) and the model will automatically assume a
one year time frame.
How do I determine the soil erodibility (K) factor to use in this model?
Based on your general knowledge of the predominant soil type common in the area in which the
construction site is located, you can select a soil type from the model drop down menu. Selection options
include sandy loam, clay, loam, or silty clay loam K values for each of these soil types arc included in
the spreadsheet model and range from 0.13 to 0.32. If the type of soil is unknown, then you can input an
average value of 0.22 for this factor.
How do I determine the length/slope (LS) factor to use in this model?
For the length/slope factor, use your visual observations from the inspection to estimate whether the site
slope would be considered predominantly flat, moderate, or steep and estimate an average slope length for
the whole site. If there arc significantly different grades at the construction site then subdivision of the
construction area (modeling each separately) may be appropriate. If you do not have any information
about the site to estimate a length/slope factor, then you can input an average value of 6.1, where typical
LS factors range from 0.09 (for a 1% slope and IS foot slope length) to 12.23 (for a 14% slope and a
1,000 foot slope length.)
What cover management (C) factor is used in this model?
EPA expects, for most cases, that the disturbed acreage of a construction site will have been cleared of
cover. EPA is therefore assuming a cover factor of 1.0 in the spreadsheet model and no input for this
factor is required.
How do I determine the efficiency of the conservation practice (Eff.) to use in this model?
The model will set a default efficiency by the type of sediment erosion control practice (or BMP) that you
select for current (or prc-compliance) conditions and for post-compliance conditions. The reduction in
sediment loss between these conditions is the reduction that should be reported in ICIS. The types of
BMPs used on the site or required by the enforcement action will determine which BMP efficiency you
pick from the drop down menu. For the current conditions, use observations from the inspection on
current erosion control BMPs to determine which item to select from the drop down menu. The
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requirements of the enforcement action will determine which BMPs arc going to be put into place to
address deficiencies for the post-compliance conditions.
How do I determine the effectiveness factor (E) of the existing BMPs present on site?
The effectiveness factor would be used in cases where BMPs currently exist at a site and arc not working
properly. This factor is an estimate of how well the existing BMPS arc working. Use best professional
judgement to estimate the effectiveness factor based on observations from the inspection. Example: You
visit a site that has a silt fence installed, but about one third of the silt fence is falling down and torn.
Because about 30 percent of the fence is not working properly, the effectiveness factor (E) is estimated to
be 70 percent. If the site docs not have existing BMPs then the E factor should be set to 100%
Are return inspections required to collect information for the factor values in this model?
No. The sediment reductions calculated for a case and input into 1CIS arc estimates based on the
information that you have for the case and your best professional judgement. The Office of Compliance
is developing the construction site sediment reduction spreadsheet model in an effort to standardize the
approach used by all the regions in estimating these sediment reductions.
What data should I start collecting at future inspections?
For future inspections, make observations that will help you determine factor values or which drop down
menu options to select. For example,
• Request information on the disturbed acreage of the site,
• Request information on the time period for construction,
• Note the soil type common to the site area,
• Observe how steep the site appears to be and estimate average slope lengths, and
• Observe whether there arc existing BMPs, and their condition.
What if the construction site has different slope characteristics in different areas?
If your site docs not lend itself to one overall slope for the entire area, you can run the model multiple
times to capture different slope characteristics present. Example: A site is 4 acres in area. About half of
site has a moderate slope, and the remaining area has a steep slope. Run the model twice: 1) for the 2 acre
area with moderate slope and 2) for the 2 acre area with a steep slope. The total amount of sediment loss
will be the sum of the sediment loss from those two portions of the construction site.
What if the construction area has or will require multiple management practices?
Where different erosion and/or sediment loss management practices occur at different locations within a
construction site, model each area separately and sum the sediment losses to determine the total site
sediment loss. Where multiple BMPs arc incorporated for the same area, use the cumulative efficiency of
the practices in the spreadsheet model. For example, hydrosccding should result in a SO percent sediment
removal efficiency. If the site will also include straw bales then an additional 70 percent removal
efficiency can be achieved. Overall the site would experience 50 percent sediment removal from
hydrosccding + 70 percent removal of the remaining sediment loss (from the straw bales) = 0.5 + (0.70 *
0.50) = 0.5 + 0.35 = 0.85 or 85 percent total removal efficiency. The model has a separate tab to use if
multiple BMPs apply. If a construction site has BMPs and they arc not functioning, then the Eff. should
be set to 0 as if there were no BMPs on site.
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5.3.3 Example and Input for ICIS
Kandle Construction Company is building a shopping mall in Camden, New Jersey. The site is 5
acres in area and construction is occurring from May 1, 2004 through October 1, 2004. A site
visit reveals that the site is located on an area with a moderate slope and sandy loam soil.
Existing BMPs include a silt fence around approximately 2 acres of the site that slope towards a
drainage ditch and no erosion control surrounding the rest of the site. The site visit showed that
about one third of the silt fence was falling down and torn. The site will be addressed through an
enforcement action requiring that the existing silt fence be repaired and properly maintained and
the area of the construction site with no erosion controls will be hydroseeded.
Step A Determine the best method of using the EPA model for the specific site.
The site will be modeled to determine the current (pre-compliance) sediment loss
and a post-compliance sediment loss for two areas: Area 1) the three acre area
that has no current soil erosion BMP and Area 2) the two acre area that has a silt
fence that is not being properly maintained. The post-compliance situation will
include hydroseeding on Area 1 and silt fence repair on Area 2. The reduction in
sediment loss (from pre-compliance to post-compliance conditions) for the two
areas will be summed and reported in ICIS for this case.
Step B Enter the area ef the construction site.
Area 1 = 3 acres
Area 2 = 2 acres
Step C Determine the location specific RF factor appropriate for the site from the website
link provided in the model. ( http://ei.tamu.edu/mdex.html) This website link is
for the Texas A&M Erosivity Index Calculator.
For our example,"Camden, New Jersey" and the start and stop date for the
construction project are input into the erosivity index calculator and a (RF) value
of 124.03 is provided as output from the calculator. This index factor is then
input into the EPA spreadsheet model.
Step D Determine the appropriate K factor for the soil type.
For our example, "Sandy Loam" is selected from the drop down menu in the
model.
Step E Determine the LS factor for the site. The model user may:
• Select the slope and slope length from a drop-down menu in the model
(which will select an LS factor for the site); or
• Determine an LS factor by interpolating the information from an LS table
provided in the model.
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For this example, a "Moderate" slope with a slope length of "1,000 feet" are
selected from the drop-down menus in the model.
Step F The C Factor is set in the model at 1.0.
Step G Determine the Eff. factor of the existing BMPs at the site.
For Area 1, "none" is selected from the list in the model.
For Area 2, "silt fence" is selected from the list in the model. Also, since the silt
fence at the site is not being maintained properly, a BMP effectiveness factor will
also be input into the model. The model user must use best professional
judgement to estimate the effectiveness of the existing BMPs. For this site,
because the about one third of the silt fence located on this site is falling down .
and torn, only two thirds of the fence is effective; the effectiveness factor is about
67 percent. For this example an E factor of 67% is input into the model.
Determine the Eff. factor for the post-compliance conditions at the site. For Area
1 chose "Hydroseeding" and for Area 2 chose "Silt Fence" from the drop down
list in the model.
Step-H After all inputs are made, the model will estimate the amount of sediment
reduction for the construction site (or portion of the construction site modeled) as
a result of the BMPs.
In this example the sediment reduction in pounds is:
Area 1 = 159,627 pounds
Area 2 = 49,165 pounds
For a total sediment reduction of 208,792 pounds
Input for ICIS is as follows:
Complying Action: Implement Best Management Practices;
Pollutant: Sediment;
Unit: 208,792 Pounds
Media: Water (navigable/surface).
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5.4 Stormwater Violation for CAFOs
5.4.1 Background
EPA has promulgated regulations to reduce the amount of water pollution from Concentrated
Animal Feeding Operations (CAFOs). The final rule updates regulations that are more than 20
years old and will result in more effective, nationally consistent regulations to protect water
resources.
CAFO cases are expected to include the following types of discharge violations:
• Contaminated surface runoff from CAFO areas which do not have runoff storage and
control;
• Releases from storage lagoons or runoff ponds which are caused by storm event spills or
lagoon leaks; and
• Releases due to over application of manure wastes.
Typical complying actions that may apply to these cases include:
Actions with Direct Environmental
Benefits/Response or Corrective Action
Preventive Actions to Reduce Likelihood of Future
Releases
Emission/Discharge Change
Implement Best Management Practices
Storage Change
For CAFO cases, you can calculate pollutant reductions for BOD5, COD, TSS, nitrogen,
phosphorus, and potassium using information from the case file on the type of animal operation,
areas impacted by the action, and the volumes of manure or wastewater handled/released. If
manure or wastewater characterization data are not known, Tables 11-1 through 11-4 (located in
Section 11 at the end of this booklet) can be used.
Tables 11-1 and 11-2 present typical pollutant concentrations in manure as excreted based on
animal type. Table 11-1 covers beef and dairy cattle and Table 11-2 covers swine. To find
manure characteristics for other animal types see USDA's Agricultural Waste Management Field
Handbook at: www.ftw.nrcs.usda.gov/awmfh.html. Chapter 4. These tables include information
for the following pollutants, Total Solids (TS), Chemical Oxygen Demand (COD), 5-day
Biochemical Oxygen Demand (BOD5), Nitrogen (N), Phosphorus (P), and Potassium (K).
Table 11-3 presents typical pollutant concentrations for stored manure supemate. Since manure
storage often occurs in lagoons, these values are useful for enforcement actions where a facility
has had spills or overflows from their storage lagoons. A storage lagoon will have sludge
accumulate at the bottom and a liquid supernate will rest above the sludge layer. Spills and leaks
are most likely to have supernate characteristics.
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Not all manure that is excreted at a CAFO is available for collection, storage, treatment or
transfer, since there are typically some losses associated with these operations. Table 11-4
presents typical recoverability factors for manure based on the animal type. In addition, nitrogen
and phosphorus volatilization losses also occur during collection, storage, treatment, or transfer.
These losses are also presented in Table 11-4.
5.4.2 Calculation Methodology
The calculation of pollutant reductions for CAFOs will depend on the type of discharge
violation. Step-by-step instructions are provided below for surface runoff violations, storage
lagoon spills or leaks, and over application violations.
Surface Runoff Violation
This approach applies to those cases where the CAFO has no storage or control of feedlot runoff
and assumes that approximately 1.5% of the annual runoff volume is solids. (Based on the
Livestock Waste Facilities Handbook, Second Edition, 1985) This approach also assumes that
the composition of solids in the runoff is the same as in the facility's manure as excreted.
Surface Runol
Step A Dcteri
Step B Using
genen
Note The runt
and the ground
otherwise you t
dr\
-------
Surface Runoff Violation (Continued)
Step C Since an enforcement action will result in storage and/or control of the facility's surface runoff, you
can assume that manure releases will no longer occur in the surface runoff after the compliance action
is completed Therefore, assume that all of the manure that was being released in surface runoff
annually will now be reduced [Note Sites may still be allowed to have some runoj) discharges due to
25 or 100-year storm events]
Manure Reduction (Ibs/yr) = Annual runoff volume (cu ft /yr) * 0 015 (manure volume/runoff
volume) * manure density (Ibs/cu.ft)
Manure density by animal type is provided in Table 11-5
Step D Using the characterization data from Table 11-1 or Table 11 -2, determine pollutant reductions as1
Pollutant reduction (Jbs/yr) = Manure reduction (Ibs/yr) * [Pollutant characterization from
Table 11-1 or Table 11-2 (lbs/d/1000#)/ Manure characterization from Table 11-1 or Table
ll-2(lbs/d/IOOO#)]
Step E Report the total pollutant reduction (for one year) in pounds in ICIS Identify "Water
(navigable/surface)" as the impacted media
Lagoon/Storage Pond Spill or Leak
This approach applies to those cases where the CAFO operation uses a waste storage pond or
lagoon. Spills are assumed to occur during a wet weather event where the storage pond or
lagoon has insufficient freeboard and overflows. Leaks are assumed to be the result of poor
maintenance or damage.
Lagoon/Storage Pond Spill or Leak
Step A Determine the type of animal operation at the facility and the facility's manure management practices
(i e , type of storage lagoon or runoff pond)
Step B Determine the volume of stored waste released in gallons.
For a spill due to a storm event this may be determined from the storm event data (rainfall in
inches) x the surface area of the storage lagoon (sq ft.) * 1 ft/12 inches x 7.481 gal/1 cu.ft).
[Note This calculation assumes that the storage lagoon has no freeboard 1J the site's
lagoon is maintained with some Jreeboard. then you should subtract from the storm event
volume the free board volume ]
For a leak this may be determined from the storage lagoon liquid height before and after the
leak (height change (ft.) * the surface area of the storage lagoon (sq ft.) x 7 481 ga/1 cu.ft.)
Step C Determine the pollutant concentration in the lagoon
If this information is not known you can use typical values from Table 11-3.
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Lagoon/Storage Pond Spill or Leak (Continued)
Step D Assume that the enforcement action will result in no further spills or releases and that the losses from
the spill/leak will no longer occur. Determine the reduction in pollutant as1
Pollutant Reduction (Ibs) = Volume of spill/leak released (gal) * Pollutant concentration
(Ibs/lOOOgal)
Step E Report the total pollutant reduction in pounds in ICIS Identify "Water (navigable/surface)" as the
impacted media
Over Application Violation
CAFOs may use land application of manure as a beneficial reuse option in lieu of or in addition
to manure storage and treatment. In this process, manure is applied to crop or pasture lands
through various types of application devices depending on the nature of the manure (i.e., manure
is applied as a dry solid, a slurry, or a wastewater). A CAFO should determine proper
application rates of manure based on the amount of land available for manure application,
specific crops that are grown on that land, and the expected crop yields and soils analysis.
Enforcement actions have occurred against CAFOs that perform land application of manure in
amounts that far exceed a proper application rate. An enforcement authority may determine that
over application is occurring by checking actual manure application rates against the application
rates required by the crop or it may be evident from visible manure releases from crop/pasture
land into nearby water bodies or by elevated levels of nutrients in waterbodies adjacent to land
application operations. In these cases, an enforcement action against a CAFO may include the
requirement that the facility develop a Nutrient Management Plan (NMP). As part of the NMP,
the CAFO would be required to calculate the application rates that are appropriate for the type of
land application practices conducted by the facility and these rates could then be monitored to
see that they are not exceeded.
Over Application Violation
The methodology described below is a simplified evaluation of manure application vs. crop uptake This
calculation methodology has the following flaws:
• It assumes that manure application for nutrient needs will not exceed the hydraulic capacity of the soil
If the hydraulic capacity of the soil is more limning than the nutrient capacity then the hydraulic flow
rate becomes the determining factor.
• This approach does not take into account the manure decomposition rate Since it may take more than
a year for applied manure to breakdown into its component nutrients, manure may be applied at a
greater rate so that sufficient nutrients are available for crop uptake the first year. This issue should be
considered when you evaluate the specifics of the enforcement case.
The nitrogen and phosphorus pollutant reductions that would occur from an enforcement,action against over
application of manure can be estimated using the following steps.
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Over Application Violation (Continued)
Step A Determine the type of animal operation and land application information (amount of land available for
application, crops grown on that land, expected crop yields)
Step B Identify the current manure application rate (Ibs manure applied/yr).
This rate should be known or can be calculated if the facility land applies all of the manure generated
onsite
Manure generated onsite (Ibs/year) = number of animals * avg weight/animal (from Table 11-5) x Ibs
manure generated as excreted (from Table 11-1 or 11-2 expressed as Ibs manure/d/1000#) x days/yr the
animal is onsite x recoverability factor (from Table 11-4)
Step C Using the current manure application rate, calculate the equivalent amount of nitrogen and phosphorus
that is being land applied.
Nitrogen land applied (Ibs/yr) = Quantity of manure land applied (Ibs/yr) x [Nitrogen characterization
data from Table 11-1 or Table 11-2 (lbs/d/IOOO#)/ Manure characterization data from Table 11-1 or
Table 11-2 (lbs/d/1000#)] x ((100 - typical % nitrogen loss factor from Table 11-4)/100)
Phosphorus land applied (Ibs/yr) = Quantity of manure land applied (Ibs/yr) x [Phosphorus
characterization data from Table 11-1 or Table 11-2 (lbs/d/IOOO#)/ Manure characterization data from
Table ll-l or Table 11-2 (lbs/d/IOOO#)] x ((100-typical % nitrogen loss factor from Table ll-4)/IOO)
' Step D Using the land application information, calculate the amount of nitrogen and phosphorus that will be
taken up by the crops grown
Crop nitrogen requirements (Ibs) = Crop yield (tons/acre) x Crop uptake (Ibs nitrogen/ton of crop) x
area of crop land (acres)
Crop phosphorus requirements (Ibs) = Crop yield (tons/acre) x Crop uptake (Ibs phosphorus/ton of
crop) x area of crop land (acres)
Typical crop yields can be found by state and county at www.nass usda.tiov 81/medb
Typical crop uptake values for nitrogen and phosphorus are shown in Table 11 -6
Step C If more than one crop is grown on a field per year, determine the total annual nitrogen and phosphorus
land application needs
For example, if two crops are grown on the land for the year(corn in summer and winter
wheat in the winter) then the total annual nitrogen needs will be the sum oj the corn crop
nitrogen needs + the winter wheat crop nitrogen needs)
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Over Application Violation (Continued)
Step P Determine the annual amount of nitrogen and/or phosphorus removal that will occur once the CAFO
comes into compliance with proper land application rates.
The ratio of nitrogen to phosphorus in the manure will determine the reduction of the non-limiting
nutrient.
Whether nitrogen or phosphorus is the limiting nutrient will depend on whether the land application
area is susceptible to phosphorus leaching (primarily karst terrain). If it is, then the manure should be
applied to meet the crop's phosphorus requirements and the nitrogen from the manure should be
supplemented with commercial nitrogen fertilizer.
If the land application area is not susceptible to phosphorus leaching then the manure should be
applied to meet the crop's nitrogen requirements and there will be a slow build up of excess
phosphorus in the soil.
Nitrogen or Phosphorus removal (Ibs/yr) = Total nitrogen or phosphorus land applied (Ibs/yr) - Annual
crop nitrogen or phosphorus needs (Ibs/yr)
Non-limiting nutrient removal (Ibs/yr) = limiting nutrient reduction (Ibs/yr) * ratio of non-limiting
nutrient/limiting nutrient in the manure.
Step G Report the total pollutant reduction (for one year) in pounds in ICIS Identify "Water
(navigable/surface)" as the impacted media
5.4.3 Example Calculations and Input for ICIS
CAFO Surface Runoff Violation
EPA visited a beef cattle CAFO in response to fish kills downstream of the feedlot. A review of
operations at the site identified that the feedlot facility had no control or storage of site runoff
and the topography of the site resulted in runoff flowing to the affected stream. The facility is
the subject of a judicial order compelling the operation to put in runoff control (using berms and
grading) and storage in a runoff storage pond. The operation has the capacity for 1,500 head of
beef cattle and has continuous turnover of cattle to stay at capacity throughout the year. The area
of the CAFO is 690,000 sq. ft. Local meteorological data for the area indicate that the average
annual rainfall for the past year was 26 inches.
Step A The operation handles beef cattle
Step B Using the local annual rainfall data and the size of the feedlot, the volume of
surface runoff generated over one year is:
Annual volume of runoff (cu. ft./yr) = 0.4 * 26 inches/yr x 690,000 sq. ft. x l ft./12 inches
= 598,000 cu. ft./yr
5-21
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Step C Since the compliance action will result in the elimination of feedlot runoff, the
reduction in manure discharge will equal the current level of manure discharge in
runoff.
Manure reduction (Ibs/yr) = 598,000 cu. ft./yr x 0.015 x 62 Ib/cu. ft.
(Beef cattle manure density)'= 556,140 Ibs/yr
Step D Pollutant reductions (using characterization data from Table 11-1) are:
Total Solids reduction (Ibs/yr) = 556,140 Ibs manure/yr x (7.30/63.00)
= 64,442 Ibs/yr
COD reduction (Ibs/yr) = 556,140 Ibs manure/yr x (6.00/63.00)
= 52,966 Ibs/yr
BOD5 reduction (Ibs/yr) = 556,140 Ibs manure/yr x (1.20/63.00)
= 10,593 Ibs/yr
Nitrogen reduction (Ibs/yr) = 556,140 Ibs manure/yr x (0.33/63.00)
= 2,913 Ibs/yr
Phosphorus reduction (Ibs/yr) = 556,140 Ibs manure/yr x (0.12/63.00)
= 1,059 Ibs/yr
Potassium reduction (Ibs/yr) = 556,140 Ibs manure/yr x (0.26/63.00)
= 2,295 Ibs/yr
Step E Input for ICIS is as follows:
• Complying Action: Implement Best Management Practices
Pollutant: and Unit: TSS and 64,442 pounds
Pollutant: and Unit: COD and 52,966 pounds
Pollutant: and Unit: BODS and 10,593 pounds
• Pollutant: and Unit: Nitrogen and 2,913 pounds
• Pollutant: and Unit: Phosphorus and 1,059 pounds
• Pollutant: and Unit: Potassium, 2,295 pounds
• Media: Water (navigable/surface)
Lagoon/Storage Pond Spill or Leak
A large swine operation located in North Carolina has been cited in an enforcement action. The
site's anaerobic storage lagoon located next to a tributary of Pamlico Bay was found to be
overflowing and a spill of lagoon supernate is believed to have occurred during a recent intense
24-hour storm event. The facility lagoon is 500 feet by 250 feet in size and the recent storm
event totaled 2.5 inches of rain. The enforcement action will result in additional site storage and
lowering of the current lagoon level to allow for sufficient freeboard in the storage lagoon.
5-22
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Step A The facility is a swine operation and uses an anaerobic storage lagoon.
Step B Assuming that the storage lagoon was maintained with no freeboard, waste
discharged from the lagoon is equal to the volume of lagoon supemate displaced
by the rainfall:
The volume of stored waste released (gallons) = 2.5 inches of rainfall x 500 feet
x 250 feet x l ft/12 inches x 7.481 gal/1 cu.ft. = 194,800 gallons
Step C Typical pollutant concentrations in the lagoon supemate (using Table 11-3) are:
Total solids = 20.83 Ibs/1,000 gal
COD= 10.00 Ibs/1,000 gal
BOD5 = 3.331bs/l,OOOgal
Nitrogen = 2.91 lbs/l,000gal
Phosphorus = 0.63 lbs/1,000 gal
Potassium = 3.16 Ibs/1,000 gal
Step D Pollutant amounts brought under proper management after compliance will be:
Total solids = 20.83 Ibs/1,000 gal x 194,800 gal = 4,058 Ibs TS
COD = 10.00 Ibs/1,000 gal x 194,800 gal = 1,948 Ibs COD
BOD, = 3.33 lbs/1,000 gal x 194,800 gal = 649 Ibs BODS
Nitrogen = 2.91 lbs/1,000 gal x 194,800 gal = 567 Ibs Nitrogen
Phosphorus = 0.63 lbs/1,000 gal x 194,800 gal = 123 Ibs Phosphorus
Potassium = 3.16 Ibs/1,000 gal x 194,800 gal =615 Ibs Potassium
Step E Input for ICIS is as follows:
• Complying Action: Implement Best Management Practices
Pollutant: and Unit: Total Solids and 4,058 pounds
Pollutant: and Unit: COD and 1,948 pounds
Pollutant: and Unit: BODS and 649 pounds
• Pollutant: and Unit: Nitrogen and 567 pounds
• Pollutant: and Unit: Phosphorus and 123 pounds
• Pollutant: and Unit: Potassium and 615 pounds
• Media: Water (navigable/surface)
Over Application Violation
EPA has completed an administrative order for a dairy facility located in central Indiana. An
investigation into the dairy operation found that the facility was disposing of all manure
generated onsite by land application onto 200 acres of nearby farm land. An evaluation of the
land application rates revealed that the site was over applying and excess manure appears to be
washing off of the farm land and into a stream that runs through the area. The facility handles
800 head of mature dairy cows during the year. The farm land on which land application
5-23
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operations are occurring is used to grow com during the spring/summer and winter wheat during
the fall/winter. Under the administrative order, the facility will be required to cut back their land
application rates to those that meet (and don't exceed) the crop's nitrogen requirements. The
remaining site manure will require storage and application on additional farm land or
composting for sale.
Step A The CAFO is a dairy cow facility whose manure management practices consist of
land application of all manure generated onsite. The facility handles 800 head of
mature dairy cows throughout the year. The farm land available for land
application is 200 acres. The crops grown on that farm land are corn for grain in
the spring/summer and winter wheat in the fall/winter.
Using www.nass.usda.gov:81 /ipedb: the expected crop yields for 2000 in Indiana
are 147 bushels of corn/acre and 69 bushels of winter wheat/acre.
Step B The current manure application rate is equal to the amount of manure generated at
the site by the dairy cows.
Lbs manure generated at the site = # of cows x avg. weight/cow (from Table 11 -
5) x Ibs manure/d/1000# (from Table 11-1) x days/year x recoverability factor
(from Table 11-4)
Lbs manure applied/yr = [800 dairy cows x 1,350 Ibs/cow x 80 Ibs
manure/d/IOOO# x 355 d/yr] x 0.98
= 30,900,000 Ibs manure/yr
Step C The equivalent amount of nitrogen and phosphorus that is being land applied is:
N land applied (Ib/yr) = 30,900,000 Ibs manure/yr x [(0.45 Ibs. N/d/1000#)/(80
Ibs. manure/d/1000#)] x [(100 - 59.8)/100]
= 69,900 Ibs. N/yr
P land applied (Ib/yr) = 30,900,000 Ibs manure/yr x [(0.07 Ibs. N/d/1000#)/(80
Ibs. manure/d/1000#)] x [(100- 14.1)/100]
= 23,200 Ibs. P/yr
Step D Nitrogen and phosphorus that will be taken up by the crops grown is:
From Table 11-6 the nitrogen and phosphorus uptake in the two crops grown at
the land application site are:
Corn for grain: N = 0.80 Ibs/bushel
P = 0.151bs/bushel
Winter Wheat: N = 1.02 Ibs/bushel
P = 0.20 Ibs/bushel
5-24
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Crop nitrogen requirements (Ibs/yr) =
Corn: 0.80 Ibs N/bushel x 147 bushels/acre x 200 acres = 23,520 Ibs/yr
Wheat: 1.02 Ibs N/bushel x 69 bushels/acre x 200 acres = 14,076 Ibs/yr
Crop phosphorus requirements (Ibs/yr) =
Corn: 0.15 Ibs P/bushel x 147 bushels/acre x 200 acres = 4,410 Ibs/yr
Wheat: 0.20 Ibs P/bushel x 69 bushels/acre x 200 acres = 2,760 Ibs/yr
Step E The total annual nitrogen and phosphorus land application needs are:
Nitrogen needs = 23,520 + 14,076 = 37,600 Ibs/yr
Phosphorus needs = 4,410 + 2,760 = 7,170 Ibs/yr
Comparing these numbers to the amount of nitrogen and phosphorus that is
currently being land applied shows that nitrogen is being applied at almost double
that required.
(69,900 Ibs N applied - 37,600 Ibs N needed)/ 69,900 Ibs N applied x 100 = 46%
over application of nitrogen
(23,200 Ibs P applied - 7,170 Ibs P needed)/ 23,200 Ibs N applied x 100 = 69%
over application of phosphorus
Step F The amount of nitrogen and phosphorus that will be brought under proper
management once the dairy complies with appropriate nitrogen application rates
is:
69,900 Ibs N currently applied - 37,600 Ibs N needed = 32,300 Ibs N reduction/yr.
The manure containing this excess nitrogen will be either land applied onto
additional farmland or might be composted for sale.
For dairy manure the ratio of phosphorus to nitrogen (from Table 11-1) is:
(0.07 Ib P/d/1000#)/(0.45 Ib N/d/1000#) = 0.16
Therefore the amount of phosphorus that will be reduced is:
32,300 Ibs N reduction/yr x 0.16 Ibs P/lbs N = 5,168 Ibs P reduction/yr.
Step G Input for 1CIS is as follows:
• Complying Action: Implement Best Management Practices
• Pollutant: and Unit: Nitrogen and 32,300 pounds
• Pollutant: and Unit: Phosphorus and 5,168 pounds
• Media: Water (navigable/surface)
5-25
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5.4.4 Additional Reporting Requirements for CAFO Performance Based Strategy
Implementation
In order to track progress against the goals laid out in the performance-based strategy for
CAFOs, we will be asking the regions to input additional data into IC1S from the CCDS form.
See sample ICIS entry below:
Pollutant
Nitrogen
Phosphorus
Manure
Manure Runoff
Amount
5,000
5,000
1,000
10
Unit
Pounds
Pounds
Pounds
Stream miles
Impacted Media
Water (navigable/surface)
Water (navigable/surface)
Water (navigable/surface)
Water (streams)
5.5 Combined Sewer Overflow (CSO)
5.5.1 Background
Combined sewers collect both storm water and sanitary sewage in the same piping system.
During rainfall, the sewer capacity can be exceeded and the sewer may overflow, which is
known as a combined sewer overflow or CSO. Combined sewer overflows may contain
contaminated stormwater along with human and industrial waste. CSOs are primarily a problem
in cities with old infrastructure and are most common in the Northeast and Great Lakes Region.
EPA's CSO Control Policy (published April 19, 1994) requires communities to implement nine
minimum CSO controls. In addition, EPA expects communities with a combined sewer system
to develop a long-term CSO control plan that will ultimately provide for full compliance with the
Clean Water Act. The nine minimum controls are:
• Proper operation and maintenance of the combined sewer system;
• Maximum use of the collection system for storage;
• Review and modification of pretreatment requirements to assure CSO impacts are
minimized;
• Maximization of flow to the publicly owned treatment works (POTW) for treatment;
• Prohibition of CSOs during dry weather;
• Control of solids and floatable materials in CSOs;
• Pollution prevention;
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• Public notification of CSO occurrences and impacts; and
• Monitoring of CSO impacts and the effectiveness of CSO controls.
Long-term plans must evaluate control strategies and identify control measures and should
include monitoring and modeling. EPA provides guidance on developing a long term CSO
control plan on the Internet at http://cfpub.epa.gov/npdes/cso/cpolicv.cfm.
Most CSO cases will involve system modifications that result in either:
• A greater amount of flow treated through the municipal treatment system;
• Additional primary treatment of CSO flows prior to discharge; or
• Specialized in-line treatment systems such as holding tanks/facilities and swirl
concentrators.
The complying action that applies to system modifications (including flow reduction) is
"industrial/municipal process change". For cases where additional primary treatment of CSO
flow occurs, the complying action that applies is "emissions/discharge change". The impacted
media should be identified as "water (navigable/surface)".
You can calculate pollutant reductions for BOD,, COD, TSS, and nitrogen and phosphorus using
information on the reduction of untreated CSO flow due to the action or information on the
amount of direct discharged CSO flow that will undergo primary treatment due to the action.
When available, use case specific information for flow and wastewater characterization. If flow
and/or wastewater characterization data are not known the methodology and tables below can be
used.
Table 5-1. Typical Pollutant Concentrations (in mg/L) by Source
Source
Urban Stormwater
Median Value (or range)
Combined Sewer
Overflows
Municipal Sewage,
untreated
Municipal Sewage,
treated
TSS
58
4-4,420
(median = 70)
118-487
(median = 217)
30
BOD,
8.6
4-699
(median = 40)
88-451
(median = 209)
30
COD"
20-600
20-1,000
(median = 367)
250-750
25-80
Total Kjeldahl
Nitrogen
1.4
0.01-16.6
(median = 1.17)
11.4-61
(median = 33)
0.5-32
(median = 3 95)
Total
Phosphorus
0.27
0.15-6.36
(median = 1 .04)
1.3-157
(median = 5.8)
007-6
(median = 1.65)
Source USEPA, Report to Congress on the Impacts and Control of CSOs and SSOs [Publication Pending] (except
where noted)
a - From. Control and Treatment of Combined Sewer Overflows, P.E. MofFa, 1990.
5-27
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Table 5-2. CSO Treatment Process Efficiencies (in %)
Physical Unit Process
Total Suspended
Solids
BOD,
COD
Total Kjeldahl
Nitrogen
Total
Phosphorus
Sedimentation
Without chemicals
Chemically assisted
Swirl Regulator/
Concentrator
20-60
68
40-60
30
68
25-60
34
45
-
38
-
-
20
-
-
Screening
Microstrainers
Drum screens
Rotary screens
Disc screens
Static screens
50-95
30-55
20-35
10-45
5-25
10-50
10-40
1-30
5-20
0-20
35
25
15
15
13
30
17
10
-
8
20
10
12
-
10
Source- Control and Treatment of Combined Sewer Overflows, P E Mofta, 1990.
5.5.Z Calculation Methodology
Step A Determine the volume of CSO flow that will undergo treatment due to the compliance action
This may occur as overflow reduction (e g, greater storage in the system that results in more CSO flow through
the POTW) or as primary treatment of CSO at the overflow point(s)
If flow is unknown it can be estimated as follows
1) Estimate stormwater flow per year = yearly rainfall x surface area * runoff coefficient
Where the surface area is the area of the municipality that feeds the combined sewer, and
The runoJJ coefficient is an average value for the area (e g, 0 3jor rural areas, 0 65-1 0 for urban
areas)
2) Estimate the current volume of overflow per year = stormwater flow per year - extra POTW capacity
above dry weather flow (this is usually 1 to 2 times the dry weather flow). This can be calculated as
the POTW flow capacity above dry weather flow x the number of days per year overflows occur.
3) Estimate the volume of overflow that undergoes treatment = volume of overflow per year x 0.85
This assumes that 85% of the overflow per year will undergo treatment under the enforcement action
(either as primary treatment oj overflow or reduction in overflow)
Step B Determine the pollutant concentration reduction as the pollutant concentration in untreated CSO - the
pollutant concentration after treatment
There are representative values that can be used to estimate CSO concentrations before and after treatment if
system specific information is not available, See Table 5-1 above (This calculation does not apply to
microbials)
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(Continued)
Step C Determine the reduction in pollutant loading
Pollutant reduction (Ibs/yr) = volume of overflow that undergoes treatment (volume/yr) * pollutant
concentration reduction (mass/volume)
Step D Report the total pollutant reduction (for one year) in pounds in ICIS Identify "Water
(navigable/surface) as the impacted media.
5.5.3 Example Calculation and ICIS Input
As an example, a small urban municipality with a combined sewer system has the following
characteristics:
• A drainage area of 1,000 acres;
• An average annual rainfall amount of 20 inches;
• An estimated overall runoff coefficient of 0.75;
• 30 days during the year where the POTW system exceeded its flow capacity; and
• POTW capacity of 1 MOD flow above its dry weather flow.
The municipality will incorporate sewer system and POTW system upgrades to maximize the
system's storage capacity during wet weather events. Therefore, the reduction in CSOs is
occurring as a result of additional flow through the POTW.
Step A Stormwater flow per year = 20 inches/year x 1,000 acres x 0.75 (estimated runoff
coefficient) x | ft/12 inches x 43,560 sq. ft./acrc x 7.481 gal/1 cu. ft. x
MG/1,000,000 gal = 407.3 MGY
Overflow per year = 407.3 MGY - [30 days/yr. x | MGD] = 377.3 MGY
Volume of overflow that undergoes treatment = 377.3 MGY x 0.85 = 320.7 MGY
Step B The system's CSO flow will go from a median untreated overflow concentration
to the effluent concentrations from the POTW. Using Table 5-1 estimates for
representative CSO pollutant concentrations and average treated concentrations,
the reductions will be:
TSS = 70 mg/1 - 30 mg/l = 40 mg/1
BOD5 = 40 mg/1 - 30 mg/1 = 10 mg/1
COD = 367 mg/1 - 50 mg/1 = 317 mg/1
Typical POTW effluents for Total N and Total P are equal to or higher than the
typical values for these pollutants in CSO. Therefore, assume in this example that
no additional treatment of these pollutants will be effected.
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Step C TSS reductions = 320.7 MGY x 40 mg/l * 3.785 I/gal x 1,000,000 gal/MG *
g/1,000 mg x | lb/454 g = 106,900 Ibs/year TSS
BOD, reductions = 320.7 MGY x 10 mg/l x 3.785 I/gal x 1,000,000 gal/MG x
g/1,000 mg x 1 lb/454 g = 26,700 Ibs/year BOD5
COD reductions = 320.7 MGY x 317 mg/l x 3.785 I/gal x 1,000,000 gal/MG x
g/1,000 mg x | lb/454 g = 847,500 Ibs/year COD
Step D Input for ICIS is as follows:
• Complying Action: Emissions/Discharge Change
Pollutant: and Unit: TSS and 106,900 pounds
Pollutant:-and Unit: BOD, and 26,700 pounds
Pollutant: and Unit: COD and 847,500 pounds
• Media: Water (navigable/surface)
5.6 Sanitary Sewer Overflow (SSO)
5.6.1 Background
Properly designed, operated, and maintained sanitary sewer systems are meant to collect and
transport sewage to a publicly owned treatment works (POTW). However, occasional
unintentional discharges of raw sewage from municipal sanitary sewers occur. These types of
discharges are called sanitary sewer overflows (SSOs) and EPA estimates that there are at least
40,000 SSOs each year. SSOs have a variety of causes, including but not limited to severe
weather, damage and blockages due to grease and roots, improper system operation and
maintenance leading to inflow and infiltration (I/I) problems, and vandalism. The untreated
sewage from these overflows can contaminate our waters, causing serious water quality
problems.
Capacity, Management, Operation, and Maintenance (CMOM) techniques as well as system
rehabilitation and diagnostic methods have been shown to reduce SSO occurrences and volumes.
Examples of CMOM and I/I reduction techniques include implementing central control of
system maintenance (for systems that have fragmented authorities with control over pieces of the
system), tracking and recording service complaints, repairing or replacing manhole structures,
identifying and disconnecting un-permitted sources of storm water inflow on private property,
and clarifying how to respond to system problems.
Most SSO cases will involve system upgrades and maintenance to eliminate SSOs. The
complying action type that applies to these situations is "industrial/municipal process change"
which includes municipal system changes. The impacted media should be identified as "water
(navigable/surface)". Pollutant reductions occur from SSO cases due to the reduction in the
amount of untreated sewage that overflows. The system improvements that result from these
cases eliminate overflows. Thus, the sanitary wastewater stays in the system and is treated
through the municipalities POTW, receiving the appropriate secondary treatment.
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The main problem in estimating pollutant reductions for SSO cases is the lack of information on
the volume of SSO that occurs. Based on the information that EPA has to date, the SSO CCDS
methodology will use the following assumptions when case specific information is not available:
• Unless specific quantities are know or can be determined, the annual volume of SSO can
be estimated to be equivalent to 0.5 to 3% of the average daily wastewater flow to the
POTW. If the average daily wastewater flow to the municipality is unknown (e.g., a
satellite system), you can estimate the daily wastewater flow from the service population
using a standard value of 120 gallons per capita per day.
• Assume that the case once it has been fully implemented will result in 100% SSO
elimination.
You can calculate pollutant reductions for BODS, COD, TSS, and nitrogen and phosphorus using
information on the SSO flow and wastewater characterization data. When available, use case
specific information for flow and wastewater characterization. If flow and/or wastewater
characterization data are not known, the methodology and Table 5-1 (pg. 5-27) can be used.
5.6.2 Calculation Methodology
Step A Determine the annual amount of sanitary sewer overflow that occurs for the municipality (in million
gallons MG)
If the annual volume of SSO can be estimated by the utility, use this volume
If not and the average daily flow discharged to the POTW is known, use from 0 5 to 3% of one day's flow to
estimate the volume of SSO For example, a utility with severe SSO problems and a daily flow discharge of 20
MGD would be estimated to have (0.03 x 20 MGD) = 0.6 MG of SSO annually The less severe the SSO
problems or more and the region, the lower the percentage you would use foi the estimate
If the average daily flow discharged to the POTW is unknown, determine the population served by the system
and multiply by 120 gallons per capita per day (gpcd) to determine an average daily flow. For example, a
satellite system serving 84,000 people would generate an average daily wastewater flow of (84,000 people x
120 gpcd) = 10,080,000 gallons per day or 10.08 MGD.
Step B Determine the pollutant concentration reduction as the pollutant concentration in untreated SSO - the
pollutant concentration after treatment
If the typical untreated and treated concentrations of SSO pollutants are known, use those values
If not, there are representative values that can be used to estimate untreated and treated concentrations. See
Table 5-1 above. (This calculation does not apply to microbials)
Step C Determine the reduction in pollutant loading
Pollutant reduction (Pounds/yr) = Annual volume of SSO (MG/yr) x pollutant concentration reduction
(mass/volume) x conversion factors
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(Continued)
Step D Report the total pollutant reduction (for one year) in pounds in IC1S. Identify "Water
(navigable/surface)" as the impacted media
5.6.3 Example Calculation and Input for ICIS
As an example, a small urban municipality with a POTW flow of 42 MOD will be implementing
an SSO plan in response to an enforcement action. It is assumed that with full implementation of
the plan, SSOs will be eliminated and all wastewater in the system will be treated through the
POTW.
Step A Without case specific information on the SSO volumes, we will assume that 2%
of the one day's worth of average daily POTW system flow is equivalent to the
annual SSO volume.
Estimate of annual SSO volume = 42 MOD x 0.02 = 0.84 MGY
Step B The pollutant concentration reductions Using Table5-l (for typical untreated and
treated concentrations) will be:
TSS = 2l7mg/l-30mg/l= I87mg/l
BOD, = 209 mg/l - 30 mg/l = 179 mg/1
COD = 250 mg/l - 30 mg/l = 220 mg/l
Total N = 33 mg/l - 3.95 mg/l = 29.05 mg/l
Total P = 5.8 mg/l - 1.65 mg/l = 4.15 mg/l
Step C TSS reductions = 0.84 MGY x 187 mg/l x 3.785 1/gal x l ,000,000 gal/MG x
g/1,000 mg x l lb/454 g = 1,310 Ibs/year TSS
BODS reductions = 0.84 MGY x 179 mg/l x 3.785 1/gal x 1,000,000 gal/MG x
g/1,000 mg x l lb/454 g = 1,250 Ibs/year BOD5
COD reductions = 0.84 MGY x 220 mg/l x 3.785 1/gal x 1,000,000 gal/MG x
g/1,000 mg x l lb/454 g = 1,540 Ibs/year COD
Total N reductions = 0.84 MGY x 29.05 mg/l x 3.785 1/gal x 1,000,000 gal/MG x
g/1,000 mg x l lb/454 g = 203 Ibs/year Total N
Total P reductions = 0.84 MGY x 4.15 mg/l x 3.785 1/gal x 1,000,000 gal/MG x
g/1,000 mg x l lb/454 g = 29 Ibs/year Total P
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StepD
Input for 1CIS is as follows:
Complying Action: Industrial/Municipal Process Change
Pollutant: and Unit: TSS and 1,310 pounds
Pollutant: and Unit: BOD5 and 1,250 pounds
Pollutant: and Unit: COD and 1,540 pounds
Pollutant: and Unit: Nitrogen and 203 pounds
Pollutant: and Unit: Phosphorus and 29 pounds
Media: Water (navigable/surface)
5.7 Wetlands
5.7.1 Background and Methodology
Section 404 of the CWA establishes a program to regulate the discharge of dredged fill material
into waters of the U.S., including wetlands. The activities regulated under this program include
fills for development, water resource projects (such as dams and levees), infrastructure
development (such as highways and airports), and conversion of wetlands to uplands for farming
and forestry.
The purpose of the program is to ensure that alternatives, that are less damaging to the aquatic
environment, are evaluated and implemented where possible. Permittees must show that they
have taken steps to avoid wetland impacts where practicable, minimized potential impacts to
wetlands, and provided compensation for any remaining, unavoidable impacts through activities
to restore or create wetlands. The program is administered by the Army Corp of Engineers
through individual or general permits and both the Army Corp of Engineers and EPA enforce the
Section 404 provisions.
Enforcement actions related to CWA 404 wetland cases may include the following types of
direct and FMIP complying actions:
Statute/Section
Violated
CWA 404
Actions with
Direct
Environmental
Benefits/Response
or Corrective
Action
Wetlands Mitigation
(note that this
includes restoration,
creation, and
preservation of
wetlands)
Pollutant
Name
Fill Material
Amount
Enter a value
Unit
Acres, or
Linear feet of
small stream
(< 10 ft. wide),
Linear feet of
medium stream
(10-20 ft wide);
Linear feet of
large stream
(<20 ft wide)
Potential
Impacted
Media
Water
(wetlands)
5-33
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Statute/Section
Violated
CWA 404
Facility/Site
Management and
Information Practices
(FMIP)
Permit Application
Pollutant
Name
Fill Material
Amount
NA
Unit
NA
Potential
Impacted
Media
NA
Statute/Section
Violated
CWA 404
Actions with Direct
Environmental
Benefits/Response or
Corrective Action
SEP - Environmental
Restoration
Pollutant
Name
Fill Material
Amount
Enter a value
Unit
Acres
Potential
Impacted
Media
NA
For wetland mitigation efforts, you should report the acres of wetland or linear feet of stream
subject to the restoration or planned for creation or preservation. Identify "fill material" as the
pollutant and the media impacted will be "Water (wetlands)." Permit application actions are a
facility management and information practice and should not have an environmental benefit
measurement included in IC1S.
Supplemental Environmental Projects (SEPs) involving the restoration of wetlands may also
occur. For these types of actions you should identify "environmental restoration and
protection" as the category of SEP on Question 18. of the CCDS and input the acres of wetlands
to be restored or mitigated under the SEP in Question 20. The pollutant to be identified in
Question 20 is "fill material" and the media impacted will be "Water (wetlands)".
5.7.2 Examples and Input for (CIS
Example 1. Wetlands Restoration
For some CWA Section 404 restoration efforts, the wetland area impacted will be along a stream
or river. For these types of cases you can report the environmental benefit as linear feet of
stream or river restored. In the identification of units, you should indicate the size of the stream
or river using the following options:
• Linear feet of small stream (defined as < 10 feet in width);
• Linear feet of medium stream (defined as 10-20 feet in width); or
• Linear feet of large stream (defined as > 20 feet in width).
For a case involving the restoration of 300 feet of wetlands along a stream bed (where the stream
size is considered small) you would report in ICIS the following:
• Complying action: Wetlands Mitigation
Pollutant: Fill Material
• Unit: 300 linear feet of small stream
5-34
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• Media: Water (wetlands)
Example 2. Wetlands Creation/Preservation
For a case involving the preservation of a 10 acre wetlands area, the input to 1C1S would be:
• Complying action: Wetlands Mitigation
Pollutant: Fill Material
• Unit: 10 acres
• Media: Water (wetlands)
5.8 SDWA - PWSS
5.8.1 Background and Methodology
The Safe Drinking Water Act (SDWA) directs EPA to set requirements for the level of
contaminants in drinking water, and standards by which water supply system operators must
comply to meet these levels. Through the PWSS program, EPA implements and enforces
drinking water standards to protect public health. EPA's Office of Ground Water and Drinking
Water regulates contaminants that present health risks and can potentially occur in public
drinking water supplies. EPA set National Primary Drinking Water Regulations (NPDWRs)
which arc legally enforceable standards that apply to public water systems. The NPDWRs set a
Maximum Contaminant Level Goal (MCLG) and a Maximum Contaminant Level (MCL) for
specific contaminants. MCLGs are defined as the maximum level of a contaminant in drinking
water at which no known or anticipated adverse effect on health would occur and are not
enforceable. MCLs are the maximum allowable concentration of the contaminant for each
pollutant and are an enforceable standard. The NPDWRs contain limits for inorganic chemicals,
organic chemicals, radionuclides, and microorganisms.
Contaminants listed under the microorganism section of the NPDWR include Giardia lamblia,
heterotrophic plate count, Legionella, total coliforms, turbidity, and viruses. These contaminants
cannot be expressed in the typical concentration units of mass per unit volume and their
standards are set as a treatment technique, which is an enforceable level of technical
performance which public water systems must follow to ensure control of the contaminant.
Additional information on microbial pollutants and disinfection byproducts in drinking water can
be found at www.epa.gov/OGWDW/mdbp/mdbp.htmltfregsch.
Because microbial contaminants are not measured in concentration terms, it is not possible to
obtain microbial pollutant reductions in terms of pounds of pollutant reduced/eliminated or
treated. Therefore, OECA is requesting that the measure of success for SDWA - PWSS cases be
represented by the population impacted by the action that will receive cleaner drinking water.
The unit of measure for SDWA cases is the number of people served by the system covered
under the compliance action. Typical complying actions under SDWA - PWSS cases may
include:
5-35
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Actions with Direct Environmental
Benefits/Response or Corrective Action
Preventative Actions to Reduce Likelihood of
Future Releases
Implement Best Management Practices (BMPs)
Notification
Enforcement actions against public water systems that are found to have contamination and are
brought back into compliance with a pollutant problem should be entered into ICIS as the direct
complying action "Implement Best Management Practices (BMPs)". Enforcement actions that
address public notification violations should be entered into ICIS as the preventative complying
action "Notification". If an action involves both the direct and preventative complying actions,
you should report into ICIS the direct complying action and indicate the population measurement
only once per case. The impacted media should be identified as "Water (drinking)".
5.8.2 Example and Input for ICIS
For example, a SDWA case involving a public water utility serving a population of 20,000
people that has been cited for deficiencies in public notification and requiring implementation of
BMPs to address exceedences in fecal coliform and lead would result in the following ICIS
input:
• Complying Actions: Implementing Best Management Practices
• Pollutant: Lead, Fecal Coliform
Unit: 20,000 People
• Media: Water (drinking)
5.9 SDWA-UIC
5.9.1 Background and Methodology
The SDWA (under SDWA Sections 1422/1423) established the Underground Injection Control
(UIC) program to provide safeguards on underground injection operations in order to protect
current and future underground sources of drinking water (USDW).
Underground injection is the technology of placing fluids underground into porous formations of
rocks, through wells or other similar conveyance systems. The fluids injected may be water,
wastewater, or water mixed with chemicals. Facilities across the U.S. discharge a variety of
hazardous and nonhazardous fluids into more than 400,000 injection wells. Agribusiness and the
chemical and petroleum industries all make use of underground injection for waste disposal.
EPA has grouped underground injection into five classes for regulatory control purposes. Each
class includes wells with similar functions, and construction and operating features so that the
technical requirements can be applied consistently to the class. These classes of wells include:
• Class 1 - injection or emplacement of hazardous and nonhazardous fluids (industrial and
municipal wastes) into isolated formations beneath the lowermost USDW. Because they
5-36
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may inject hazardous waste, Class 1 wells are the most strictly regulated by both the
CWA - UIC program and RCRA.
• Class II - injection of brines and other fluids associated with oil and gas production.
Some Class II wells inject fluids for enhanced recovery of oil and natural gas while
others inject liquid hydrocarbons that constitute our Nation's strategic fuel reserves in
times of crisis.
• Class III - injection of superheated steam, water, or other fluids into formations to
extract minerals.
• Class IV - injection of hazardous or radioactive wastes into or above a USDW. These
wells are banned under the UIC program because they directly threaten public health.
• Class V - includes all other underground injection not covered under Classes I- IV.
Some Class V wells my not be waste disposal wells, for example, injection of surface
water to replenish depleted aquifers or to prevent salt water intrusion.
Injection wells have the potential to inject contaminants that may cause our underground sources
of drinking water to become contaminated. The UIC program prevents this contamination by
setting minium requirements. These requirements are designed to keep injected fluids within the
well and the intended injection zone, or to require that injected fluids not cause a public water
system to violate drinking water standards or otherwise adversely affect public health. These
minimum requirements affect the siting of an injection well, and the construction, operation,
maintenance, monitoring, testing, and ultimately closure of the well. All injection wells require
authorization under general rules of specific permits.
Typical direct and FMIP complying actions under SDWA - UIC cases may include:
Statute/Section
Violated
SDWA 1422/1423
SDWA 1422/1423
SDWA 1422/1423
Preventative
Actions to
Reduce
Likelihood of
Future Releases
Obtain Permit for
Underground
Injection (UIC)
UIC Plug und
Abandon
UIC Demonstrate
Mechanical
Integrity
Pollutant
Name
Wastewater or
see 1CIS list
Wastewater or
see IC1S list
Wastewater or
see 1CIS list
Amount
Number
of wells
Number
of wells
Number
of wells
Unit
Wells
Wells
Wells
Potential Impacted
Media
Water (Underground
Source of Drinking
Water (USDW))
Water (USDW)
Water (USDW)
5-37
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Statute/Section
Violated
SOW A 1422/1423
SDWA 1422/1423
SDWA 1422/1423
SDWA 1422/1423
SDWA 1422/1423
Facility/Site
Management and
Information Practices
(FMIP)
Recordkeeping
Monitoring
Reporting
Financial Responsibility
Permit Application
Pollutant Name
Wastewater 01
see 1CIS list
Wastewater 01
see ICIS list
Wastewater or
see ICIS list
Wastewater or
see ICIS list
Wastewater or
see ICIS list
Amount
NA
NA
NA
NA
NA
Unit
NA
NA
NA
NA
NA
Potential
Impacted
(Media
NA
NA
NA
NA
NA
For preventive actions, you should report the number of wells monitored or decommissioned.
For each of these types of cases the pollutant identified may be either "wastewater" or other
pollutant(s) specific to the enforcement action. The media impacted will be "Water
(underground source of drinking water)". For facility management and information practices
you should identify the appropriate complying action in Question 20 but should not report an
environmental benefit under Question 22 (you may identify wastewater or some other pollutant
as appropriate).
5.9.2 Example and Input for ICIS:
For example, a UIC case requiring the plugging and abandonment of 10 injection wells at a
mining facility with accompanying monitoring to ensure no aquifer contamination has occurred
and a demonstration of financial responsibility would be reported in (CIS as follows:
Complying Actions: UIC Plug and Abandon (Preventative), Financial Responsibility
Requirements, Monitoring, and UST Release Detection
Pollutant: Wastewater
Unit: 10 wells
Media: Water (underground source of drinking water)
5.10 References
U.S. EPA, February 2000. Drinking Water: Past, Present, and Future,^.?A 816-F-00-002.
U.S. EPA, Office of Ground Water and Drinking Water, Underground Injection Control
Program, www.epa.gov/safewater/uic
U.S. EPA, Office of Water, Office of Ground Water and Drinking Water, Public Drinking Water
Systems Program, www.epa.gov/safewater/pws/pwss.html
5-38
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U.S. EPA, Office of Water, Office of Ground Water and Drinking Water, Current Drinking
Water Standards, www.epa.gov/OGWDW/mcl.html
U.S. EPA, Office of Water, Office of Science and Technology, Effluent Guidelines
www.epa.gov/waterscience/guide
U.S. EPA, Office of Water, Storm Water, www.epa.gov/npdes/stormwater
U.S. EPA, Office of Wetlands, Oceans and Watersheds, Section 404 of the Clean Water Act,
www.epa.gov/owow/wetlands/facts/fact 10.html
U.S. EPA, Office Emergency and Remedial Response, RCRA, Superfund & EPCRA Call Center
Program Areas, OPA/SPCC, www.epa.gov/epaoswer/hotline/spcc.htm
U.S. EPA, Report to Congress on the Impacts and Control of Combined Sewer Overflows
(CSOs) and Sanitary Sewer Overflows (SSOs). 2003.
Letterman, Raymond D., ed., Water Quality and Treatment: A Handbook of Community Water
Supplies, American Water Works Association, McGraw-Hill, Inc., Washington, D.C., 1999.
5-39
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6.0 AIR EXAMPLES
Under the CAA the following types of enforcement cases are typical:
• 6.1 Enforcement actions against facilities that have triggered a Prevention of
Significant Deterioration (PSD)/New Source Review (NSR) violation, (pg. 6-1)
• 6.2 Enforcement actions resulting from violations with a MACT/NESHAP standard.
(pg- 6-9)
• 6.3 Enforcement actions impacting Leak Detection and Repair (LDAR) requirements.
(pg.6-17)
The sections below present methodologies'for determining pollutant reductions and
environmental benefit for typical cases involving an air media. Each section includes
information on the following:
• Background;
• Calculation Methodology; and
• Example calculations and input for ICIS using specific scenarios.
Section 6.4 presents references and Websites used in developing these examples.
In addition, it should be noted that for CAA cases involving exceedences with existing air
pollution standards, actual emission amounts should be used in the calculations and not potential
to emit amounts.
6.1 NO, Reductions at a Petroleum Refinery under PSD/NSR
6.1.1 Background
Emissions of NO, at petroleum refineries are associated with refinery combustion units.
Refinery boilers and process heaters are usually targeted for NOX reductions under compliance
actions. Fluidized catalytic cracking unit (FCCU) regenerators are also sources of NOX emissions
at petroleum refineries (NOX is generated when coke is burned off of the catalyst); however,
these units are typically not controlled for NOX reductions and therefore will not be discussed
further under this guidance. There are two primary types of fuel burned in the boilers and
process heaters: fuel oil and gas. The gas can be either refinery fuel gas that is produced at the
facility or natural gas. There are different options that facilities may use to reduce NOX emissions
depending on the unit and fuel type.
The primary reduction techniques for boilers and process heaters can be classified into one of
three fundamentally different methods — combustion controls, post-combustion controls, and
fuel switching. Combustion controls reduce NOX by suppressing NOX formation during the
combustion process while post-combustion controls reduce NOX emissions after their formation.
6-1
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Combustion controls are the most widely used method of controlling NOX formation in all types
of boilers and process heaters and include:
• Low excess air;
• Burners out of service;
• Biased-burner firing;
• Flue gas recirculation;
• Overfire air; and
• Low-NOx burners.
Post-combustion control methods include selective noncatalytic reduction (SNCR) and selective
catalytic reduction (SCR). These controls can be used separately, or combined to achieve greater
NOX reduction. For enforcement actions where combustion control technologies will be
implemented, the complying action is "emission/discharge change". Fuel switching replaces
one type of fuel with another and can also be combined with other controls to achieved greater
NO, reduction. For actions that will implement fuel switching you should identify the
complying action "source reduction". For each of these complying action types the typical
units reported are "tons" or "pounds" and the media impacted is "air".
Combustion Techniques (FGR and Low NOX Burners)
Currently, the two most prevalent combustion control techniques used to reduce NC\ emissions
are flue gas recirculation (FGR) and low NOX burners. In an FGR system, a portion of the flue
gas is recycled from the stack to the burner windbox. Upon entering the windbox, the
rccirculated gas is mixed with combustion air prior to being fed to the burner. The recycled flue
gas consists of combustion products which act as merts during combustion of the fuel/air
mixture. The FGR system reduces NO, emissions by two mechanisms. Primarily, the
recirculated gas acts as a diluent to reduce combustion temperatures, thus suppressing the
thermal NOX mechanism. To a lesser extent, FGR also reduces NOX formation by lowering the
oxygen concentration in the primary flame zone.
Low NOX burners reduce NOX by accomplishing the combustion process in stages. Staging
partially delays the combustion process, resulting in a cooler flame which suppresses thermal
NO, formation. The two most common types of low NO, burners being applied are staged air
burners and staged fuel burners. NOX emission reductions of 40 to 85 percent (relative to
uncontrolled emission levels) have been observed with low NOX burners. When low NO,
burners and FGR are used in combination, these techniques are capable of reducing NOX
emissions by 60 to 90 percent.
Post-Combustion Technologies
Two post-combustion technologies that may be applied to natural gas-fired boilers to reduce NOX
emissions are selective noncatalytic reduction (SNCR) and selective catalytic reduction (SCR).
The SNCR system injects ammonia or urea into combustion flue gases (in a specific temperature
zone) to reduce NOX emission. In many situations, a boiler or process heater may have an SNCR
system installed to trim NOX emissions to meet permitted levels. In these cases, the SNCR
6-2
-------
system may not be operated to achieve maximum NOX reduction. The SCR system involves
injecting NH into the flue gas in the presence of a catalyst to reduce NOX emissions.
Fuel Switching
Fuel switching may be used to reduce NOX emissions. For certain boiler and process heater
units, it may be possible for the facility to switch from fuel oil combustion to natural gas
combustion. This switch in fuels can result in reduced NO, emissions.
6.1.2 Calculation Methodology
There are essentially two methods to calculate NOX reductions from process heaters and boilers:
1. Calculate emissions for the unit using emission factors representing the pre-compliance
and post-compliance conditions (e.g., uncontrolled and controlled scenario; or, emissions
from fuel oil burning versus emission from refinery fuel gas switching). Subtract the
post-compliance estimate from the pre-compliance estimate to determine the reductions.
2. Calculate emissions for the pre-compliance condition (e.g., uncontrolled) using emission
factors. Multiply a NOX control efficiency to the pre-compliance emission estimate that
represents the control strategy that is or will be used by the facility to come into
compliance (e.g., the control efficiency for a low-NOx burner). The estimated reduction
is equal to the amount of NOX emissions controlled.
Published emission factors and control efficiencies are available for process heaters and boilers
by fuel type and size or rated heat input of the unit. It is important to note that there are no
published emission factors or control efficiencies specific to the use of'refinery fuel gas'.
Factors are available for the combustion of natural gas. In situations where refinery gas is being
used as a fuel, the emissions reductions should be calculated using the emission factors or
control efficiencies that are published for natural gas combustion in boilers and process heaters.
The exception to this case would be if the facility provides emission factors specific to the
refinery fuel gas being used at that facility.
The following steps should be followed to calculate NO, emission reductions for boilers and
process heaters at petroleum refineries. Note: The steps should be followed to calculate
emission reductions for each unit that is affected by the compliance measures and total
reductions should be summed for all affected units to estimate a total reduction quantity
for the compliance action. Table 6-1 (following the examples) presents a worksheet that shows
how to compile the information in order to calculate emission reductions (the field names in
Table 6-1 are coded to the items listed in the methodology below):
6-3
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Calculation Methodology for NOX Reductions from Boilers and Process Heaters
Step A Determine the operating conditions of the unit under non-compliance conditions
Step B Determine the reduction strategy for the affected unit.
StepC If the affected unit is a boiler, locate the emission factor in Table 1.3-1 or Table 1.4-1 ofAP-42(EPA,
1995) that best matches the pre-compliance condition (e.g., uncontrolled). If the affected unit is a
process heater, locate the emission factor from Tables 5-11 to 5-15 of the Alternative Control
Techniques Document - NO, Emissions Jrom Process Heaters (EPA, 1993) that best matches the pre-
comphance condition. Table 6-1 shows examples for a boiler unit (Bl) and process heaters (PH1,
PH2) Note: Section 11.0 of this guidance provides selected tables from these references.
Step D If the affected unit is a boiler, locate the emission factor in Table 1.3-1 or Table 1.4-1 of AP-42 that
best matches the post-compliance condition (e.g., unit controlled with low NO, burners) If the
affected unit is a process heater, locate the emission factor from Tables 5-11 to 5-15 of the Alternative
Control Techniques Document - NO, Emissions from Process Heaters that best matches the post-
compliance (i.e., controlled) condition Table 6-1 shows examples for a boiler unit (B 1) and process
heaters (PH 1, PH2) NOTE: if an emission factor that represents the reduction strategy cannot he
located in the referenced tables, then skip to step "E" below.
Step E If emission factors representing emission reduction strategies are not available, it is also possible to
calculate emission reductions based on estimated control efficiencies In these cases, refer to Table
12.3-1 of Volume II, Chapter 12 of the EIIP document series located at
hltn//w\\wenii uov itn/chicf/onn icchrcnoii volumc02 nl2'mir Locate the control efficiency that best
mutches the reduction strategy used for compliance and use the value in Table 6-1, Column E.
Step F If the unit is a process heater, enter the annual heat input for the affected unit for which emission
reductions are being estimated
[Conversion factors to go from a volume basis to an energy basis are provided in Table 6-1 ]
Step G If the unit is a boiler, enter the annual quantity of fuel burned
[If the fuel burned is fuel oil use units of 1 x 10' gallons; if the fuel burned is natural gas use units of I
* 10" scf Conversion factors to go from a volume basis to an energy basis are provided in Table 6-1 ]
Step H Multiply the emission factor (from Column C) for the pre-compliance scenario by either the heat input
value (from Column F for process heaters) or the fuel bumed (from Column G for boilers) and enter
the emission estimate in Column H.
Step I Multiply the emission factor for the post-compliance scenario (Column D) by either the heat input
value (Column F for process heaters) or the fuel burned (Column G for boilers) and enter the emission
estimate in Column I. If an emission factor was not available for the control device adopted by the
facility to come into compliance, then skip to step K below See example calculation below.
Step J Subtract Column I from Column H and enter the quantity of NO, emissions reduced for the unit. Note
Step K Multiply the pre-comphance estimate in Column H by the control efficiency in Column E and enter the
quantity of NO, emissions reduced for the unit.
Step L Report the total pollutant reduction in pounds in ICIS. Identify "Air" as the impacted media.
6-4
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6.1.3 Example Calculations and Input for ICIS
The following examples demonstrate how emission reductions can be calculated for a petroleum
refining facility. The input data to perform the reduction calculation have been entered onto the
worksheet in Table 6-1 to illustrate how the worksheet can be used.
Example 1.
ABC Oil Company has a facility that added a new gas-fired boiler and 2 gas-fired process
heaters (both are natural draft [ND] heaters) in order to increase its production. The boiler and
process heaters were installed with no controls. In operating the new units, the facility increased
its NO, emissions by more than 40 tons per year, and thus triggered PSD/NSR, falling out of
compliance with Prevention of Significant Deterioration (PSD) requirements for their NOX
emissions cap. Following an administrative order, the facility agrees to add control devices to
the new boiler and process heater units in order to reduce NOX emissions. The facility agrees to
use a low-NOx burner (LNB) and flue-gas recirculation (FGR) on the boiler unit and to retrofit
the two new process heaters with ultra low-NOx burners (ULNB). The annual quantity of fuel
burned in the boiler is 687 x 106 scf. The annual quantity of heat input into the process heaters is
l.Ox IOf'MMBtueach.
The worksheet in Table 6-1 is used to calculate emissions for the boiler (Bl) and the process
heaters (PH1 and PH2) based on uncontrolled conditions (pre-compliance) and also with controls
installed (post-compliance). The calculations of reductions follow the steps outlined in Section
6.1.2.
For Boiler I:
Pre-compliance NOX emissions (Column H) =
Post compliance NOX emissions (Column I) =
Annual NO, reduction (Column J)
annual quantity of fuel burned (Column G)
x pre-compliance emission factor
(Column C)
687 x io6 scf/yr x |QO Ib/IO6 scf
68,700 Ib/yr
34 ton/yr
Annual quantity of fuel burned (Column G)
x post-compliance emission factor
(Column D)
687 x 106 scf/yr x 32 lb/106 scf
21,984 Ib/yr
11 ton/yr
Pre-compliance emissions - post-compliance
emissions
34 ton/yr - 11 ton/yr
23 ton/yr
6-5
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For Process Heaters 1 and 2:
Pre-comphance NO, emissions (Column H)=
Post-compliance NO, emissions (Column I)=
Annual NO, reduction (Column J)
Annual heat input (Column F) x pre-
compliance emission factor (Column C)
1.0 x 106 MMBtu/yr x 0.098 Ib/MMBtu
98,000 Ib/yr
49 ton/yr
Annual heat input (Column F) x post-
compliance emission factor (Column D)
1.0 x 106 MMBtu/yr x 0.025 lb/ MMBtu
25,000 Ib/yr
12.5 ton/yr
Pre-compliance emissions - post-compliance
emissions
49 ton/yr- 12.5 ton/yr
36.5 ton/yr
The total reductions for the facility based on its compliance actions equals the sum of the
reductions for all three units on which controls were installed. The total reductions for NO, are
equal to 192,000 pounds per year.
Total NO, Reduction
Bl reduction + PH I reduction + PH 2
reduction
23 ton/yr + 36.5 ton/yr + 36.5 ton/yr
96 ton/yr or 192,000 pounds/yr
Input for ICIS:
• Complying action: Emissions/Discharge Change
Pollutant: NO,
Unit: 192,000 pounds
• Media: Air
Example 2.
XYZ Refining Company has decided that to come into compliance with its PSD requirements it
will switch from using No. 6 fuel oil in its utility boiler to using No. 2 fuel oil, and in addition,
will install low-NO, burners with flue gas recirculation. The utility boiler is rated at 250
MMbtu/hr heat input and has a normal firing configuration prior to compliance action. The
annual quantity of fuel burned in the utility boiler is 11,680 x 101 gallons. The worksheet in
Table 6-1 is used to calculate emissions for the utility boiler (UB1) based on uncontrolled
conditions (pre-compliance) and after the fuel switch and control device additions are made
(post-compliance). The NO, reductions achieved represent the difference between the pre-
compliance and post-compliance estimates, which in this case is estimated to be 216 tons.
6-6
-------
Pre-compliance NOX emissions (Column H) =
Post-compliance NO, emissions (Column I) =
Total annual NOV reduction
Input for I CIS:
Annual fuel bumed (Column G) x pre-
compliance emission factor (Column C)
= 11,680 x l 03 gal/yr x 47 lb/ IO3 gal
= 548,960 Ib/yr
= 274 ton/yr
Annual fuel burned (Column G) x post-
compliance emission factor (Column D)
= 11,680 x 103 gal/yr x 10 lb/103 gal
= 116,800 Ib/yr
= 58 ton/yr
= Pre-compliance emissions - post-
compliance emissions
= 274 ton/yr - 58 ton/yr
= 216 ton/yr or 432,000 pounds/yr
Complying action: Source reduction and Emissions/Discharge Change
Pollutant: NOX
Unit: 432,000 pounds
Media: Air
6-7
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Table 6-1. Worksheet to Calculate NOX Emission Reductions from Process Heaters and Boilers
Unit
ID
B 1
PH 1
PH2
UB1
Pre-
compliance
condition
(A)'
no control
no control
no control
no control
Reduction
Strategy
(B)'
LNB +
FGR
ULNB
ULNB
Fuel switch
+ LNB +
FGR
Pre-
compliance
emission
factor
©)
I00lb/I06scf
098
Ib/MM Btu
098
Ib/MMBtu
47lb/l03gal
Post-
compliance
emission factor
(D)
32lb/l06scf
025 Ib/MMBtu
025 Ib/MMBtu
IOlb/10'gal
NO,
Control
Efficiency
(E)
NA
NA
NA
NA
Annual
heat
input
(FT
1 OxIO'
MMBtu
1 OxIO6
MMBtu
Annual
fuel
burned
(G)"
687 x
10'scf
Il680x
10' gal
Pre-
compliance
emission
estimate
(H)
34 tons
NO,
49 tons NO,
i
49 tons NO,
274 tons.
NOX
Post-
compliance
emission
estimate
(D
1 1 tons NO,
1 2 5 tons
NO,
1 2 5 tons
NO,
58 tons NO,
NO,
emissions
reduced
(factor
based)
(J)
23 tons
NO,
36 5 tons
NO,
36.5 tons
NO,
2 16 tons
NO,
NO,
emissions
reduced
(CE based)
(K)
NA
NA
NA
NA
oo
a - Information known from the case Tile
2000 pounds = I ton
Conversion factors to convert energy values (Million BTU or MMBtu) to volume \alues for fuels used in process heaters and boilers
For gas, use the natural gas heating value of 1,020 MMBtu/IO6 scf
For fuel oil, use a heating value of 150 MMBtu/10 3 gal for Nos 4, 5, 6, and residual fuel oil. and 140 MMBtu/10' gal for No 2 and distillate fuel oil
Bl = boiler # I from example calculation I
PH I = process heater # 1 from example calculation 1
PH2 = process heater # 2 from example calculation I
UBI = utility boiler #1 from example calculation 2
LNB = low NO, burner
FGR = flue-gas recirculation
ULNB = ultra low-NO, burner
-------
6.2 SO, and HAP Reductions at a Kraft Pulp and Paper Mill Under IMACT
6.2.1 Background
In the kraft pulping process, wood is digested under elevated temperature and pressure using a
cooking liquor of sodium hydroxide and sodium sulfide. The digester contents are separated by
the pulp washing system into a pulp slurry and spent cooking liquor. The pulp slurry is sent to
subsequent processing and conditioning equipment (e.g., screening, oxygen delignification,
bleaching) and the spent cooking liquor is concentrated in the evaporator system and then fired
in the chemical recovery boiler. The inorganic cooking chemicals, recovered as smelt from the
boiler furnace floor, are sent to the recausticizing area to be used in preparing fresh cooking
liquor. The kraft pulping process also produces several byproducts (tall oil, turpentine) that are
usually recovered onsite.
Air toxics (hazardous air pollutants or HAPs) and total reduced sulfur (TRS) compounds are
formed in the wood digestion process and pulp treatment processes (e.g., oxygen delignification,
chemical bleaching) and are emitted from discrete process vents and open equipment throughout
the process. The emission points at a typical kraft pulp and paper mill include vents from the
following systems: digester, evaporator, turpentine recovery, pulp washing, screening, knotter,
decker, oxygen delignification, and chemical bleaching. Most mills tend to reuse or recycle
process condensates in an effort to reduce fresh water consumption. Process equipment that uses
recycled condensates typically has higher emissions than the same piece of equipment using
fresh water due to the volatilization of pollutants in the process condensates.
Sulfur dioxide (SO2) emissions at kraft pulp and paper mills are generated by the combustion of
sulfur-containing fuels (black liquor and fossil fuels) and by the combustion of pulping vent
gases that contain TRS compounds. Lime kilns, which convert calcium carbonate to quick lime
for use in liquor preparation, are generally not considered significant sources of SO, emission at
kraft mills since the exhaust gases are usually passed through a wet scrubber to remove
paniculate matter, which in turn also reduces SO2 emissions.
The recovery boiler is the heart of the kraft chemical pulping process. During normal operation,
spent cooking liquor (black liquor) from the evaporator system is burned in the chemical
recovery boiler (fuel oil or natural gas may be burned during periods of start-up and shutdown).
The organic content of the black liquor is oxidized to generate process steam and the inorganic
cooking chemicals are recovered as smelt from the furnace bed. Some of the sulfur contained in
the black liquor is reduced in the furnace bed and exits the boiler with the smelt. The remaining
sulfur is oxidized in the upper furnace. The SO2 emissions from the recovery boiler are
determined by the relative amounts of sodium and sulfur volatilized during black liquor
combustion.
The generation of black liquor is directly related to pulp production, therefore, any increases in
pulp production necessitates an increase in black liquor firing rate with an associated increase in
SO2 emissions. In some cases, the recovery boiler has sufficient excess capacity to handle pulp
production increases. However, if the pulp production capacity is greater than the available
recovery capacity, then the boiler must be modified to handle the increase in black liquor
throughput.
6-9
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Although the chemical recovery boiler is the primary source of process steam in the mill, fossil
fuels and wood waste are fired in power boilers at pulp and paper mills to generate additional
process steam and electricity. Sulfur dioxide emissions generated by burning a given fuel are
proportional to the heat input rate of the boiler. An increase in heat input rate, either due to
modification of an existing boiler or addition of a new boiler, translates to an increase in SO,
emissions.
Control Techniques
Air Toxic Emissions
Air toxic emissions from regulated pulping process vents are almost exclusively controlled using
mill combustion sources (e.g., power boilers, lime kilns) or using dedicated thermal oxidizers.
Reductions in HAP emissions can also be achieved by replacing higher-emitting process
equipment with lower-emitting ones. For example, HAP emissions from the pulp washing
system could be reduced by replacing the rotary vacuum drum washers with diffusion washers.
Sulfur Dioxide Emissions
The strategy for reducing SO2 emissions is dependent on the source of sulfur (i.e., fuel or pulping
process vent gases). For sources of emissions associated with fuel combustion, emission
reductions can be achieved through physical process modifications and fuel switching.
However, for chemical recovery boilers, fuel switching is only an option during periods of start-
up and shutdown. For sources of SO, emissions associated with pulping process vent gas
combustion, emission reductions can be achieved by treating the inlet gas to remove TRS
compounds prior to combustion or by treating the outlet gas to remove SO2 directly. This type of
gas treatment is typically accomplished using a gas scrubber with caustic scrubbing media
(sodium hydroxide or fresh (white) cooking liquor).
Process Modifications
Process modifications are the most prevalent control techniques used to reduce SO2 emissions
from chemical recovery boilers. Sulfur dioxide emissions are influenced by the temperature in
the lower furnace area and can be nearly zero for boilers that have been modified to operate with
a hotter lower furnace. Sulfur dioxide emissions can also be reduced by using sulfur-free
chemicals, such as caustic soda (NaOH) and soda ash (Na,CO3), instead of saltcake (Na2SO4) to
makeup sodium lost in the chemical recovery process.
Fuel Switching
Fuel switching can reduce SO, emissions from power (and recovery boilers during start
up/shutdown), if a fuel with a lower sulfur content can be used. For example, a boiler burning
coal or distillate oil, natural gas would be a candidate for fuel switching. However, fuel
switching would not be feasible for a boiler firing natural gas since a fuel with a lower sulfur
content is not available.
6-10
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Gas Treatment
At some mills, the pulping process vent gases are routed through a scrubber (typically using
white cooking liquor or caustic solution as the scrubbing media) to absorb sulfur compounds
prior to combustion. This type of pretreatment is usually limited to dedicated thermal oxidizers.
Due to the large volume of gas associated with recovery and power boilers, treatment of inlet
and outlet gases to remove TRS (or SO2 after combustion) is usually cost prohibitive.
Based on these control technologies, the typical types of direct complying actions applicable to
SO2 and HAP reduction, elimination, and treatment would include, "source reduction",
"industrial/municipal process change", and/or "emission/discharge change".
6.2.2 Calculation Methodology
The preferred method for calculating emission reductions associated with an add-on control
technology or with process modifications is to use approved test data for the period before and
after the emission reduction was achieved. For some process modifications, such as
modifications to the heat recovery sections of recovery boilers, test data may be the only method
for calculating emission reductions since reliable emission factors are not generally available.
However, if approved test data are not available, as in most cases, then emission factors and
control technology/treatment device efficiencies must be used to estimate emission reductions.
As discussed in Section 6.2.1, emissions from noncombustion and combustion sources at kraft
pulp mills are either directly or indirectly a function of the pulp production rate. Consequently,
site-specific process data (e.g., pulp production rate, fuel firing rate, operating schedule) are
necessary to estimate reductions using emission factors.
Emission factors for characterizing HAP and TRS emissions are typically in units of mass of
pollutant per mass of pulp production and are available from EPA documents (AP-42, Pulp and
Paper NESHAP emission factor document). Emission factors are also available from industry
reports and publications. Sulfur dioxide emission factors for fuel combustion are typically given
in mass of pollutant per unit of fuel usage. AP-42 contains emission factors for various boiler
configurations and fuels firing combinations. Process data (e.g., pulp production rate, operating
schedule) should be obtained from mill documents or mill personnel. The efficiencies of control
technologies or devices can be found in the EPA's Emission Inventory Improvement Program
(EIIP), Volume 11, Chapter 12, How To Incorporate the Effects of Air Pollution Control Device
Efficiencies and Malfunctions into Emission Inventory Estimates located at
http://www.epa.gov/ttn/chief/eiip/techreport/volume02/iil2.pdf. Note: Section 11.0 of this
guidance provides selected tables from the references mentioned in this section.
To estimate the reduction in SO2 emissions achieved by Fuel switching, the following calculation
steps should be used:
6-11
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Step A Gather process parameters for power boiler no 1.
Step B Find appropriate SO, emission factors for no. 6 fuel oil and natural gas for power boiler no 1
Step C Determine the maximum amount of no. 6 fuel oil burned per year in the boiler.
Step D Determine the equivalent amount of natural gas bumed per year in the boiler
Step E Calculate the SCs emissions from Tiring no. 6 fuel oil for the boiler
Step F Calculate the SO, emissions from firing natural gas for the boiler.
Step G Subtract the SO, emissions from natural gas firing from the SO, emissions from no. 6 fuel oil Tiring to
estimate emission reductions.
Step H Report the total pollutant reduction in pounds in (CIS Identify "Air" as the impacted media.
To estimate the reduction in HAP emissions achieved by an add-on control device, the following
calculation steps should be used:
Step A Gather process parameters for the pulp washing system.
Step B Find an appropriate HAP emission factor for the pulp washing system
Step C Determine the uncontrolled HAP emissions from the pulp washing system.
Step I) Determine the control efficiency of the add-on control device
Step E Calculate the HAP emission reduction by multiplying the control efficiency of the add-on device by
the uncontrolled emissions from the pulp washing system.
Step F Report the total pollutant reduction in pounds in ICIS. Identify "Air" as the impacted media
6.2.3 Example Calculations and Input for ICIS
The following examples demonstrate how HAP and SO2 emission reductions can be calculated
from emission sources at a kraft pulp and paper mill. In these examples, the data (emission
factors, process parameter, and control device efficiencies) are arranged such that the specific
units (MMBtu/hr, Ib/ton, Ib removed/100 pounds at inlet) in the numerator and denominator of
the data can be canceled out. This approach is used to help ensure that conversion errors are not
introduced into the emission reduction calculations.
6-12
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Example 1. Sulfur Dioxide Emission Reductions Using Fuel Switching
Under a Prevention of Significant Deterioration (PSD) violation, ABC Paper Company was
found to have significantly increased pulp production. The increase in pulp production resulted
in an increase in SO2 emissions from the recovery furnace due to increased firing of black liquor.
Since the cost of an add-on control device for reducing SO, emissions was determined to be cost-
prohibitive, the mill is planning to offset the SO, emissions increase from the recovery boiler by
reducing SO, emissions from the mill's power boiler.
To achieve the required SO2 emission reduction, the mill plans to switch from burning no. 6 oil
to natural gas in the power boiler. The mill currently has one no. 6 fuel oil-fired power boiler
with maximum heat input rate of 250 million British thermal units per hour (MMBtu/hr). The
boiler uses low-NO, burners and has a maximum operating schedule of 8,760 hours per year.
Step A In calculating emissions from the power boiler, the following process parameters
are needed:
• Maximum heat input rate (MMBtu/hr);
• Fuels fired;
• Type of burners used; and
• Boiler operating hours.
From the information provided in Example 1, the following information is
obtained:
• Maximum heat input rate of power boiler no. 1 = 250 MMBtu/hr;
• No. 6 fuel oil is fired;
• The boiler uses low-NO, burners; and
• The boiler operates a maximum of 8,760 hours per year.
Step B Once the boiler process parameters have been identified, appropriate SO2
emissions factors for no. 6 fuel oil and natural gas firing can be found in Sections
1.3 and 1.4, respectively, of EPA's AP-42. For the boiler and fuel type, the
following emission factors were selected from Tables 1.3-1 and 1.4-1:
no. 6 fuel oil firing = 157(S) lb/1,000 gallons
where S = the percent sulfur in no. 6 fuel oil; and
natural gas firing = 0.6 Ib/scf of natural gas
For the fuel oil emission factor, the percent sulfur content of the fuel oil is needed
before the emission factor can be used. Appendix A of AP-42 (Miscellaneous
Data and Conversion Factors) contains average fuel characteristics that can be
used in lieu of more specific information (e.g., vendor specifications for percent
sulfur). For this calculation, the percent sulfur in fuel oil was selected as 0.5
percent. Therefore, the SO, emission factor for fuel oil is calculated as follows:
157(0.5) = 78.5 lb/1,000 gallon fuel oil
6-13
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Step C The maximum amount of no. 6 fuel oil burned in the boiler is determined using
the maximum heat input rate, the heat content of no. 6 fuel oil, and the operating
schedule. Since the heat content of no. 6 fuel oil was not provided by the mill, an
average value of 140,000 Btu/gallon (for distillate oil) was selected from
Appendix A of AP-42.
To determine the maximum amount of no. 6 fuel oil burned in the boiler, the
following unit conversion is used:
MMBtu x 1,000.000 Btu x hrs x gallon no.6 oil
hr MMBtu yr 140,000 Btu
For power boiler no. 1, the above unit conversion is calculated as follows:
250 MMBtu 106 Btu v 8760 hr v 1 gal _ 1.56 x 1Q7 gal
X X
hr MMBtu yr 140,000 Btu yr
Step D Once the maximum amount of no. 6 fuel oil burned for the boiler is determined,
an amount of natural gas that is equivalent to the quantity of no. 6 fuel oil is
needed. To determine the equivalent amount of natural gas burned per year in the
boiler, a unit conversion similar to that used in Step 3 is followed:
MMBtu x 1,000,000 Btu x hr x scf natural gal
hr MMBtu yr 1,050 Btu
For power boiler no. I , the above unit conversion is calculated as follows:
250 MMBtu x 106 Btu x 8,760 hr x 1 scf = 2.09 x 1Q9 scf
hr MMBtu yr 1,050 Btu yr
Step E The SO2 emissions from firing no. 6 fuel oil in power boiler no. 1 are calculated
using the appropriate emission factor determined in Step 2 and the maximum
amount of fuel oil burned, determined in Step 3, as follows:
78'5 'b S°> '•* * '°7 " , 6.3.98 tons
1,000 gal fuel oil yr 2,000 Ib
Step F Similarly to the procedures in Step E, the SO2 emissions from natural gas firing in
power boiler no. 1 are calculated as follows:
_06Jb_ x 2.09 x itf scf x Iton =
/% AAA It. ^
106 scf yr 2,000 Ib
6-14
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Step G The emission reduction achieved by switching from no. 6 fuel oil to natural gas
for the power boiler is determined by subtracting the SO2 emissions determined in
Step 6 from the SO2 emissions determined in Step 5.
Power boiler no. 1 emission reduction = 613.98 - 0.63 = 613.35 tons SO,/yr or
1,226,700 pounds SO2/yr.
Step H Input for (CIS
• Complying Action: Source Reduction
Pollutant: SO2
Unit: 1,226,700 pounds
• Media: Air
Example 2. Air Toxic Emission Reduction Using an Add-on Control Device
As a result of an enforcement action, a kraft mill subject to the pulp and paper NESHAP must
control their emissions from their brown stock washing system (all other subject vents at the mill
are currently controlled). Because the distance between the pulp washing system and the
existing power boilers is too great, the mill decides to control the pulp washing system emissions
using a dedicated thermal oxidizer meeting the design parameters specified in the NESHAP.
The pulp production rate of the mill is 1,200 air-dried tons of pulp per day (ADTPD). The pulp
washing system is a diffusion washer (i.e., low-air flow design) that uses fresh water as wash
water.
Step A In calculating uncontrolled HAP emissions from a pulp washing system, the
following process parameters are needed:
• Type of pulp washing system (e.g., rotary vacuum drum);
• HAP concentration of washed water used; and
• Pulp production rate.
From the information provided in Example 2, the following information is
obtained:
• Type of pulp washing system = diffusion washer (low-air flow design);
• HAP concentration of washed water = negligible; and
Pulp production rate = 1,200 ADTPD.
Step B The Chemical Pulping Emission Factor Development Document (Revised Draft)
prepared by the EPA for the pulp and paper NESHAP (40 CFR part 63 subpart S)
contains HAP emission factors for kraft pulp mills. In Table 1-1 of the emission
factor document, HAP emissions are presented for an example (1,000 tons oven-
dried pulp per day, ODTPD). For low air flow washers, the HAP emissions for
the example mill in the emission factor document are given as 20 tnegagrams per
6-15
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year (Mg/yr). Dividing the HAP emissions by the example mill production yields
(1,000 tons air-dried pulp per day) and an assumed operating schedule of 365
days per year, a HAP emission factor of 5.48E-05 Mg/ODT is obtained.
Step C Once an appropriate HAP emission factor for the pulp washing system has been
obtained, uncontrolled emissions can be estimated by multiplying the mill pulp
production rate by the HAP emission factor. However, in this example, the pulp
production rate is given in terms of air-dried tons and the emission factor is in
terms of oven-dried tons. To properly use the HAP emission factor, the pulp
production rate must be converted to oven-dried tons using the following
relationship:
1 air-dried ton of pulp = 0.9 oven-dried ton of pulp
This relationship is developed based on the industry standard that an air-dried ton
of pulp contains 10 percent moisture. Using the above conversion, the ADTPD
pulp production rate in this example is converted to ODTPD using the following
calculation:
1,200 air-dried tons x 0.9 oven-dried ton _ . ogo ODTPD
day 1 air- dried ton
The uncontrolled HAP emissions from the pulp washing system can now be
estimated by multiplying the mill pulp production rate by the HAP emission
factor as follows:
5.48 * 1Q-5 Mg HAP x 1,080 OPT? x 365 days = 21.60 Mg HAP
ODTP day yr yr
Step D The pulp and paper NESHAP provides several control options for reducing HAP
emissions from pulping process vents. The control options, of which the design
thermal oxidizer is an alternative, are intended to achieve at least 98 percent
destruction of HAP emissions. Therefore, it is appropriate to assume that the
control efficiency of the thermal oxidizer in this example is 98 percent.
Step E Once an appropriate efficiency for the add-on control device is obtained, the HAP
emission reduction for the pulp washing system is calculated by multiplying the
control device efficiency by the uncontrolled HAP emissions as follows:
21.6 Mg HAP at thermal oxidizer inlet x 98 Mg Reduced = 21.17 Mg HAP reduced
yr 100 Mg at thermal oxidizer inlet yr
his metric value can be converted to English units using the following conversion:
6-16
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21.17 Mg HAP Reduced x 1000 kg x 1 Ib = 46.630 pounds HAP Reduced
yr Mg 0.454 kg yr
Step F Input for ICIS
• Complying Action: Emissions/Discharge Change
Pollutant: HAP
• Unit: 46,630 pounds
• Media: Air
6.3 Leak Detection and Repair
6.3.1 Background
Under the Clean Air Act, fugitive emissions from a variety of equipment, including pumps,
valves, flanges, connectors, and compressors, are to be controlled through the implementation of
a Leak Detection and Repair program (LDAR). Through this program, equipment must be
routinely monitored for leaks and if a leak is found, it must be repaired. If equipment leaks go
undetected, fugitive emissions of volatile organic compounds (VOCs) and other hazardous
chemicals will be emitted continually into the atmosphere. These emissions have a number of
adverse effects such as contributing to smog and human health problems. The types of
complying actions that apply to LDAR cases include "Leak Detection" to address the
monitoring and leak detection aspects of the enforcement action and "Leak Repair" to address
the process piping repair.
Once a LDAR program has been implemented and a leak has been identified, emissions from a
particular piece of equipment can be estimated using the EPA correlation equation approach.
This method involves obtaining screening values (from a portable organic vapor analyzer) before
and after the leak was repaired. Using these values, a calculation can be performed to determine
the resulting reduction in emissions. If screening data is available, but as "greater than or equal
to 10,000 ppmv" or "less than or equal to 10,000 ppmv," screening ranges should be used.
6.3.2 Calculation (Methodology
To estimate LDAR pollutant reductions according to the EPA correlation equation method, you
need:
• The equipment screening value (ppmv) before the repair;
• The equipment screening value (ppmv) after the repair;
• The hours of operation (hr/yr);
• The pollutant concentration (weight percent) within the equipment; and
• The Total Organic Carbon (TOC) concentration (weight percent) within the equipment.
The EPA correlation equation approach involves the use of a unit and site-specific correlation
equation. These correlation equations have been developed for organic chemical manufacturing
6-17
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(SOCMI) process units and for the petroleum industry and can be found in the document
entitled, Protocol for Equipment Leak Emission Estimates (EPA, Nov. 95). Table 6-2 and 6-3
contain a few of these equations.
Table 6-2. SOCMI Leak Rate/Screening Value Correlations
Equipment Type
Gas valves
Light liquid valves
Light liquid pumps
Connectors
Correlation
leak rate (kg/hr) = 1 .87 E-06 * (SV)08"
leak rate (kg/hr) = 641 E-06 * (SV)0797
leak rate (kg/hr) = 1 90 E-05 x (SV)08M
leak rate (ku/hr) = 3.05 E-06 x (SV)01""
Source ProtocolJor Equipment Leak Emission Estimates (EPA, Nov. 1995)
SV = screening value in ppmv
Table 6-3. Petroleum Industry Leak Rate/Screening Value Correlations
Equipment Type
Valves (all)
Pump seals (all)
Open-ended lines (all)
Connectors (all)
Flanges (all)
Others1'
Correlation
leak rate (kg/hr) = 2.29 E-06 x (SV)"74"
leak rate (kg/hr) = 5.03 E-05 x (SV)""1"
leak rate (kg/hr) = 2.20 E-06 x (SV)"7(M
leak rate (kg/hr) = 1.53 E-06 x (SV)"7"
leak rate (kg/hr) = 4.61 E-06 x (SV)"71"
leak rate (k«/hr) = 1 36 E-05 x (SV)""*'
Source Protocol for Equipment Leak Emission Estimates (EPA, Nov. 1995)
SV = screening value in ppmv
a - others shall be applied to any equipment type other than connectors, flanges, open-ended lines, pumps, or valves
If the available screening value is a "zero" screening value (the screening value that represents
the minimum detection limit of the monitoring device) or a "pegged" screening value (the
screening value that represents the upper detection limit of the monitoring device), the
correlations in the above two tables cannot be used. Instead, the values displayed in Tables 6-4
and 6-5 should be used rather than a correlation.
6-18
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Table 6-4. SOCMI Default Zero Leak Rates and Pegged Leak Rates
Equipment Type
Gas Valves
Light liquid valves
Light liquid pumps
Connectors
Default Zero Emission
Rate (kg/hr)
6 6E-07
4 9E-07
7 5E-06
6.1E-07
Pegged Emission Rate
(10,000 ppmv) (kg//hr)
0024
0036
0 14
0.044
Pegged Emission Rate
(100,00 ppmv) (kg/hr)
0.11
0.15
0.62
0.22
Source ProtocolJor Equipment Leak Emission Estimates (EPA, Nov 1995)
Table 6-5. Petroleum Industry Default Zero Leak Rates and Pegged Leak
Rates
Equipment Type
Connector (all)
Flange (all)
Open-ended line (all)
Pump (all)
Valve (all)
Other
Default Zero Emission
Rate (kg/hr)
7.5E-06
3.1E-07
2 OE-06
2 4E-05
7.8E-06
4 OE-06
Pegged Emission Rate
(10,000 ppmv) (kg/hr)
0028
0085
0030
0074
0064
0073
Pegged Emission Rate
(100,000 ppmv) (kg/hr)
0030
0.084
0079
0 160
0.140
0 110
Source Protocol /or Equipment Leak Emission Estimates (EPA, Nov 1995)
6-19
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Calculation Methodology for Lead Detection and Repair
Step A For each leaking equipment type, choose the appropriate equation from Table 6-2 or 6-3 If the
available screening value is a "zero" or "pegged" value, choose the appropriate value from Table 6-4
or 6-5 If a "zero" or "pegged" screening value exists before repair, skip Step B If a "zero" or
"pegged" screening value exists after repair, skip Step D
Step B Enter the equipment screening value (ppmv) before the repair into the equation chosen in Step A in
order to calculate the leak rate (kg/hr) before repair
Step C Calculate the pollutant emissions (kg/yr) before repair of the leak using the following equation
Pollutant emissions before repair (kg/yr) = [Leak rate (kg/hr) calculated in Step B or picked in Step A
* pollutant concentration (weight percent) within the equipment * hours of operation (hr/yr)] / TOC
concentration (weight percent) within the equipment
Step D Now, enter the screening value (ppmv) after the repair into the equation chosen in Step A in order to
calculated the leak rate after repair
Step E Calculate the pollutant emissions (kg/yr) after repair of the leak using the following equation
Pollutant emissions after repair (kg/yr) = [Leak rate (kg/hr) calculated m Step D or picked in Step A *
pollutant concentration (weight percent) within the equipment * hours of operation (hr/yr)] / TOC
concentration (weight percent) within the equipment
Step F The emission reduction achieved by the repair is determined by subtracting the emissions after repair
from the emissions before the repair and converting to a total load reduction for one year
Step G Report the total pollutant reduction in pounds in ICIS. Identify "Air" as the impacted media
6.3.3 Example Calculations and Input for ICIS
Example 1. SOCMI with Non-Zero, Non-Pegged Screening Values
An EPA inspection of a chemical manufacturing facility identified a leak at a pump that pumps
light liquid. The monitoring device signaled that the VOC concentration was 5,000 ppmv. Upon
repair of the leak, the inspector went back to the equipment location with his monitoring device.
This time the device registered a VOC concentration of 50 ppmv. Records show that the pump
is run for approximately 8760 hr/yr and that the light liquid that is pumped contains 20% wt.
VOC and 40% wt. TOC.
Step A The following equation is chosen from the SOCMI table (Table 6-2) and
corresponds to the light liquid pump: leak rate (kg/hr) = 1.90 E-05 x (SV)08M
where SV = screening value in ppmv
Step B Leak rate (kg/hr) before repair = 1.90E-05 x (5000)"824 = 0.0212 kg/hr
Step C VOC emission (kg/yr) = 0.0212 (kg/hr) x 20 (wt. %) x 8760 (hr/yr) / 40 (wt. %)
VOC emission (kg/yr) before repair = 92.8 kg/yr
6-20
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Step D Leak rate (kg/hr) after repair = 1.90E-05 x (50)°*» = 0.000477 (kg/hr)
Step E VOC emission (kg/yr) = 0.000477 (kg/hr) x 20 (wt. %) x 8760 (hr/yr) / 40 (wt.
VOC emission (kg/yr) after repair = 2.09 kg/yr
Step F VOC emission reduction = (92.8 (kg/yr) - 2.09 (kg/yr)) x l lb/454 kg x lOOOg/kg
x 1 year =200 Ibs of VOC
Step G Input for ICIS
• Complying Actions: Leak Repair and Leak Detection
Pollutant: VOC
Unit: 200 pounds '
• Media: Air
Example 2. Petroleum Industry with Zero and Pegged Screening Values
A LDAR inspection of a petroleum refining facility resulted in the discovery of leaks at 4
connectors. During the inspection, the monitoring device signaled that the VOC concentrations
were greater than 10,000 ppmv, the upper detection limit of the monitoring device. An
administrative order requires repair of the connectors to a monitoring concentration of less than
1,000 ppmv, the lower detection limit of the monitoring device. Facility records show that the
facility operates continuously (approximately 8760 hr/yr) and that the light liquid that is pumped
through the connectors contains 20% wt. VOC and 40% wt. TOC.
Step A Since the screening values before the repair are "pegged" and after the repair will
be "zero," respectively, the values are chosen off of Table 6-5.
Leak rate before repair = 0.028 kg/hr.
Leak rate after repair = 7.5E-06 kg/hr
Step B Skipped
Step C VOC emission (kg/yr) = 0.028 (kg/hr) x 20 (wt. %) x 8760 (hr/yr) / 40 (wt. %)
VOC emission (kg/yr) before repair = 122.6 kg/yr per connector
Step D Skipped
Step E VOC emission (kg/yr) = 7.5E-06 (kg/hr) x 20 (wt. %) x 8760 (hr/yr) / 40 (wt. %)
VOC emission (kg/yr) after repair = 0.03 kg/yr per connector
Step F VOC emission reductions = (122.6 (kg/yr) - 0.03 (kg/yr)) x 4 connectors x
1 lb/454g x lOOOg/kg x l year= 1,080 Ibs VOC
6-21
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Step G Input for ICIS
Complying Actions: Leak Repair and Leak Detection
Pollutant: VOC
Unit: 1,080pounds
Media: Air
6.4 References
U.S. EPA, 1995. Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point
and Area Sources, Fifth Edition, AP-42. Supplements A, B, C, D, and E. Sections 1.3, Natural
Gas Combustion and Section 1.4, Fuel Oil Combustion. U.S. Environmental Protection Agency.
Office of Air Quality Planning and Standards, Research Triangle Park, NC.
www.epa.gov/ttn/chief/ap-42etc.html
U.S. EPA, 1993. Alternative Control Techniques Document- /VO, Emissions from Process
Heaters (Revised). EPA-453/R-93-034. U.S. Environmental Protection Agency. Office of Air
Quality Planning and Standards., Research Triangle Park, NC.
www.epa.go v/ttn/catc/d ir 17procheat.pdf
El IP, 2000. How to Incorporate the Effects of Air Pollution Control Device Efficiencies and
Malfunctions into Emission Inventory Estimates. Volume II, Chapter 12 of the Emission
Inventory Improvement Program (ElIP) document series, www.cpa.gov/ttn/chief/ciip
Adams, Terry N., editor, et. al. 1997. Kraft Recovery Boilers. Chapter 8, Recovery Boiler Air
Emissions. American Forest and Paper Association. New York, NY.
Smook, G.A. 1997. Handbook for Pulp & Paper Technologists, 2nd Edition. Angus Wilde
Publications. Belhngham, WA.
USEPA. 1995. Compilation of Air Pollutant Emission Factors. AP-42, 5lh Edition, including
Supplements A through F. Sections 1.3, 1.4, and 10.2. U. S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle Park, NC.
www.epa.gov/ttn/chief/ap-42.html.
Chemical Pulping Emission Factor Development Document. Revised Draft. Prepared by
Eastern Research Group for U.S. EPA. July 8, 1997. Air docket A-92-40, item 1V-A-8.
USEPA. July 2000. Emission Inventory Improvement Program. Volume II, Chapter 12: How
To Incorporate the Effects of Air Pollution Control Device Efficiencies and Malfunctions into
Emission Inventory Estimates, www.epa.gov/ttn/chief/eiip/iil2.pdf.
U.S. EPA, November 1995. Office of Air Quality Planning and Standards, Protocol for
Equipment Leak Emission Estimates. See http://www.epa.gov/ttn/chief/efdocs/lks95_ch.pdf
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U.S. EPA, July 1997. Emission Inventory and Improvement Plan. Vol. 2, Ch 4 and 5. See
http://www.epa.gov/ttn/chief/eiip/techrep.htmtfpointsrc
http://www.epa.gov/reg5foia/asbestos/ban.html (information on the ABPO rule)
http://www.epa.gov/reg5foia/asbestos/legislat.html (information on various Asbestos-related
legislation)
"Common Questions on the Asbestos NESHAP", EPA 340/1-90-021, December 1990 available
at: http://yosemite.epa.gov/r5/r5ard.nsf/2f86cbca09880b61862565fe00588192?OpenView
"Enforcement and Compliance Assurance Accomplishments Report", FY 1997, OECA, EPA-
300-R-98-093, July 1998.
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7.0 HAZARDOUS WASTE EXAMPLES
Solid and hazardous wastes are regulated by the Resource Conservation and Recovery Act
(RCRA) and the Comprehensive Environmental Response and Liability Act (CERCLA), also
referred to as Superfund. In response to RCRA and Superfund enforcement actions, the
following types of cases are typical:
• 7.1 RCRA Subtitle C enforcement actions that are geared toward the proper
management of solid and hazardous wastes. These include implementation of the
used oil regulations developed under RCRA. (pg. 7-1)
• 7.2 RCRA enforcement actions resulting from the Underground Storage Tank (UST)
regulations, (pg. 7-5)
• 7.3 RCRA corrective actions and Superfund response actions that result in
environmental cleanups, (pg. 7-7)
The sections below present various pollutant reduction, waste management, and prevention
examples for solid/hazardous waste media. Each section includes information on the following:
• Background;
• Calculation methodology; and
• Example calculations and input for IC1S using specific scenarios.
Section 7.4 presents references and websites used in developing these examples.
7.1 RCRA Subtitle C
7.1.1 Background
The Resource Conservation and Recovery Act (RCRA), an amendment to the Solid Waste
Disposal Act, was enacted in 1976 to address the huge volumes of industrial solid waste
generated nationwide. RCRA has three primary goals: I) to protect the environment and human
health, 2) to conserve energy and natural resources, and 3) to reduce or eliminate the generation
of hazardous waste. RCRA created the framework for EPA to regulate solid waste, hazardous
waste, medical waste, and underground storage tanks (USTs).
RCRA is comprised of three major programs: Subtitle C (the hazardous waste management
program), Subtitle D (the solid waste program), and Subtitle I (the UST program).
Under Subtitle C, the EPA has developed a comprehensive program to ensure that all hazardous
waste is safely managed from the moment it is generated until its' final disposition at a
Treatment, Storage or Disposal (TSD) Facility. The objective of this "cradle-to-grave"
management system is to ensure that hazardous waste is handled in a manner that protects human
health and the environment. To this end, there are Subtitle C regulations for the generation,
transportation, and treatment, storage, or disposal of hazardous wastes. The regulations first
7-1
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identify the criteria to determine which solid wastes are hazardous, and then establish various
requirements for the three categories of hazardous waste handlers: generators, transporters, and
TSDFs. These standards, which primarily involve proper identification, management, and
handling safeguards, are designed to minimize the likelihood of an unintended release of
hazardous waste into the environment.
EPA's used oil regulations are included under the RCRA regulatory umbrella. In an effort to
encourage the recycling of used oil, and in recognition of the unique properties and potential
hazards posed by used oil, Congress passed the Used Oil Recycling Act in 1980. This Act
amended RCRA by requiring EPA to study used oil and to develop used oil management
standards. Used oil mixed with hazardous waste is subject to all applicable hazardous waste
standards. Examples of common used oil generators include car repair shops, service stations,
and metalworking industries. Individuals who generate used oil through the maintenance of their
own vehicles and equipment are not considered used oil generators.
RCRA Subtitle C enforcement actions may include the following types of Direct, Preventative
and FMIP complying actions:
Statute/Section
Violated
RCRA 3002, 3003,
3004
Complying Actions with Direct Env.
Benefits
Waste Treatment
Waste Minimization
Unit
Pounds
Potential Impacted .
Media
Land
Soil
Water (ground)
Water (navigable/surface)
Air
Statute/Section
Violated
RCRA 3002, 3003,
3004
Preventative Actions to Reduce
Likelihood of Future Releases
Disposal Change
Storage Change
RCRA Labeling/Manifesting
RCRA Waste Identification
RCRA Secondary Containment
Unit
Gallons
Cubic Yards
Potential Impacted
Media
Land
Soil
Water (ground)
Water (navigable/surface)
Air
Statute/Section
Violated
RCRA all sections
Facility/Site Management and
Information Practices (FMIP)
Testing/Sampling
Record-keeping
Reporting
Notification
Financial Responsibility Requirements
Training
Permit Application
Unit
N/A
Potential Impacted Media
N/A
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7.1.2 Example Calculations and Input for (CIS
All Subtitle C non-corrective enforcement actions that include physical complying actions will
be categorized as direct reduction only when waste minimization or waste treatment occurs. All
other actions, such as storage change or disposal change, will be classified as prevention or
proper management of waste. For all of these cases, you will report in ICIS the amount of
pollutant or characteristic waste that is impacted by the enforcement action. So that they may be
included in our GPRA measure for "Lbs of pollutants estimated to be reduced, eliminated or
treated", the unit for direct reductions in the RCRA program must be pounds. Common
densities to convert gallons to pounds can be found in Chapter Ten. If not included or if
unknown, you should use the density of water.
For Subtitle C enforcement actions that include only Facility Management and Information
Practices (FMIP) complying actions, identify in ICIS the applicable complying action(s) only.
For these situations you do not need to identify a pollutant, amount, unit, or media.
Examples of some RCRA Subtitle C cases and the appropriate input for ICIS are provided
below.
Example I. Hazardous Waste Treatment (Direct)
ABC Chemical Company is subject to a RCRA Subtitle C order requiring treatment of an FOOI
solvent waste (containing methylene chloride) that is currently stored at the facility. The facility
will send out ten 55-gallon drums of the material for incineration treatment. Using the density of
methlyene chloride (From Table 10-1 in Section 10) the amount of material in pounds sent to
treatment can be estimated as follows:
10 drums FOOI x 55 gallons/drum x 11.149 Ibs./gallon = 6,132 pounds of FOOI
Input for ICIS:
• Complying Action: Waste Treatment
Pollutant: FOOI Solvent Waste
Unit: 6,132 pounds
• Media: Land
Example 2. Hazardous Waste Use Reduction (Direct)
ABC Chemical Company is currently generating a waste ash in their process which contains
dioxins formed during a process combustion step. The facility has been sited for improper
storage and disposal of this material. In response to an enforcement order, the facility is
proposing to eliminate this waste by incorporating a change in their production process and the
pre-curser chemicals used, thereby, eliminating the possible formation of dioxin in the waste ash.
Currently, the facility generates one ton of ash per month. To determine the environmental
benefit from this use reduction activity use the current waste ash production rate and scale the
amount of hazardous material eliminated by the action to one year's worth of benefits.
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1 ton waste ash/month x 12 months/yr x 2000 Ibs/ton = 24,000 Ibs waste ash
Input for ICIS:
• Complying Action: Use Reduction
• Pollutant: Dioxin contaminated waste ash
Unit: 24,000 pounds
• Media: Land
Example 3. Hazardous Waste Disposal Change (Prevention)
ABC Chemical Company is subject to a RCRA Subtitle C order identifying a solid waste stream
that is currently mis-characterized as non-hazardous. The material has recently been classified
as hazardous become of its characteristic for ignitability. The facility is planning to collect and
properly dispose of this waste. The quantity of waste generated over the past 12 months totals
5,000 pounds of material.
Input for ICIS:
• Complying Actions: Disposal Change (Preventative), RCRA Waste Identification
(FMIP)
• Pollutant: Ignitable Waste
Unit: 5,000 pounds
• Media: Land
Example 4. Used Oil (Prevention)
Metal Works Company is a metal machining shop which uses lubricating oil in their process.
After use, the oil is stored on site. During an on-site inspection the used oil from the shop was
found to be stored in a concrete pit (which is 4 ft. by 6 ft. and contains oil at a 12 inch depth)
along the back of the shop. The Agency inspector issued an administrative order requiring the
facility to install a used oil tank for storage, relocate the used oil in the pit at the back of the
facility to the new storage tank, properly label the tank as "Used Oil", and arrange for periodic
pick up by a used oil transporter. The quantity of used oil generated at the facility is
approximately 10 gallons per month.
An estimate of the amount of used oil coming under proper management is calculated as:
Used oil in the outdoor pit + used oil generated during the reporting year.
Volume of Used oil in the outdoor pit is calculated as:
4 ft. x 6 ft. x i ft. = 24 cubic feet x 1 cubic yard/ 27 cubic feet = 0.89 cubic yards
Used oil generated per year is calculated as:
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10 gallons/mo. * 12 mo./year x 1 cubic yard/202 gallons = 0.59 cubic yards
Total Used Oil Brought into Proper Management is:
0.89 cubic yards + 0.59 cubic yards = 1.48 cubic yards
Input for ICIS:
• Complying Actions: Disposal Change, Storage Change, and RCRA
Labeling/Manifesting
• Pollutant: Used oil
• Unit: 1.48 cubic yards
• Media: Land
Note: When there are several preventative and direct complying actions applicable to one
waste stream you only report the benefit once.
7.2 RCRA UST
7.2.1 Background
Subtitle I of RCRA provides EPA with regulatory authority for Underground Storage Tanks
(USTs) and is an important component of the act because it allows EPA to regulate products as
well as wastes. An underground storage tank is defined as a tank with at least 10 percent of its
volume underground, including piping, ancillary equipment, and containment systems. In order
to be regulated by Subtitle I, the tank must store petroleum or a hazardous substance. Certain
tanks are excluded from this definition. For a complete list of exempt USTs, please see 40 CFR,
Part 280. (http://www.epa.gov/docs/epacfr40/chapt-l.info/subch-I/40P0280.pdf)
For all non-exempt USTs, performance standards for tank design, construction, and installation
have been developed. Additionally, requirements concerning leak detection, record keeping,
reporting, corrective action, and closure have also been promulgated.
The regulation of USTs is vital because leaks from an UST can cause fires and explosions, as
well as contamination of the ground water. In order to protect both people and the environment,
several key regulations have been developed for the safe operation of USTs. As of December,
1993, all new and existing USTs had to be equipped with a leak detection system, and by
December, 1998, new and existing USTs had to be equipped with spill, overfill, and corrosion
protection. To ensure spill protection, USTs are required to be equipped with catch basins to
contain spills. For overfill protection, USTs are required to be equipped with automatic shut off
devices, overfill alarms, or ball float valves. Finally, for corrosion protection, the tank and
piping had to be made completely of non-corrodible material, or of steel having a corrosion-
resistant coating and having cathodic protection, or of steel clad with a thick layer of non-
corrodible material.
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To deal with non-compliance or illegal UST operation, EPA or the state regulatory agency may
take enforcement actions to ensure that the substandard UST is temporarily closed until it can be
permanently closed, replaced, or upgraded. These pollution prevention actions may include
monetary penalties and administrative or judicial enforcement actions. However, if an UST
pollutant release is detected, the result is a corrective action scenario and pollutant reductions
can be calculated.
Enforcement actions related to RCRA UST cases may include the following types of Direct,
Preventive, and FMIP complying actions:
Statute/Section
Violated
RCRA UST
Actions with Direct
Environmental
Benefits/Response or
Corrective Action
Removal of Contaminated
Medium
Pollutant
Name
Specific
pollutant name
Amount
Volume of
contaminated
medium removed
Unit
Cubic
Yards
Potential
Impacted
Media
Soil
Statute/Section
Violated
RCRA UST
RCRA UST
RCRA UST
Preventative Actions to
Reduce Likelihood of
Future Releases
UST Secondary
Containment
UST Tank Closure
UST Corrosion or
Overfill Protection
Pollutant
Name
Specific
pollutant name
Specific
pollutant name
Specific
pollutant name
Amount
Amount impacted
by action
Amount impacted
by action
Amount impacted
by action
Unit
Gallons
Gallons
Gallons
Potential
Impacted
Media
Land
Land
Land
Statute/Section
Violated
RCRA UST
RCRA UST
RCRA UST
RCRA UST
RCRA UST
Complying Actions with
Facility/Site Management and
Information Practices (FMIP)
UST Release Detection
Testing/Sampling
Record-keeping
Reporting
Financial Responsibility
Requirements
Pollutant Name
NA
NA
NA
NA
NA
Amount
NA
NA
NA
NA
NA
Unit
NA
NA
NA
NA
NA
Potential
Impacted
Media
NA
NA
NA
NA
NA
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7.2.2 Examples and Input for ICIS
Example 1. UST Spill Clean-up (Direct)
An enforcement action has been lodged against Ajax Service Station for release of gasoline from
their underground storage tanks into the surrounding soil. The station will be required to
decommission the existing three tanks (which were non-compliant with the UST regulations) and
remediate the site. The amount of gasoline leaked is estimated at 900 gallons from the three
tanks and it is estimated that 1,000 cubic yards of soil will be removed from the site.
Input for ICIS:
• Complying Action: Removal of Contaminated Medium
• Pollutant: Gasoline
Unit: 1,000 cubic yards
• Media: Soil
Example 2. UST Prevention
Under an APO, Barker Chemical Company has been cited for non-compliance with requirements
under the UST regulations. Six underground storage tanks at the facility were found to be
lacking leak detection controls and secondary containment. The APO requires the facility to add
leak detection and spill prevention controls onto the six tanks and they must also conduct soil
vapor sampling to determine whether any leaks have occurred from the tanks. The facility must
also supply proof of financial responsibility in case of a spill event. The tanks contain
manufactured solvents including toluene (in 4 - 5,000 gallon tanks) and benzene (in 2 - 500
gallon tanks).
Input for ICIS:
• Complying actions: UST Secondary Containment (Preventative), Testing/Sampling,
Financial Responsibility Requirements, and Release Detection (FMIP)
• Pollutants Toluene
Unit: 20,000 gallons
• Media: Land
AND
• Pollutant: Benzene
Unit: 1,000gallons
• Media: Land
7.3 RCRA/Superfund Corrective Actions
For RCRA corrective actions and Superfund response actions, the following types of media-
specific response actions may be encountered:
• Soil response actions (including mine tailings);
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• Groundwater hydraulic response actions;
• Landfill response actions;
• Soil vapor extraction response actions;
• Vapor intrusion (point of entry control) response actions;
• Non-aqueous phase liquid (NAPL) recovery response actions;
• Sediment response actions;
• Surface water response actions;
• Mine drainage diversion and treatment (point of entry control) response actions; and
• Container (e.g., drum) and large debris removal actions.
7.3.1 Background
Past and present activities at RCRA facilities may result in releases of hazardous waste and
hazardous constituents to soil, groundwater, surface water, and air. Through the RCRA
Corrective Action Program, EPA requires the investigation and cleanup, or in-situ or ex-situ
treatment of hazardous releases at RCRA facilities. EPA enforces the Corrective Action
Program primarily through the statutory authorities established by the Hazardous and Solid
Waste Amendments (HSWA) of 1984.
The corrective action program is structured around elements common to most cleanups under
other EPA programs: an initial site assessment, an extensive characterization of the
contamination, and the evaluation and implementation of cleanup alternatives, both immediate
and long-term. To facilitate investigations, EPA uses the concept of action levels in some cases.
Action levels are risk-based concentrations of hazardous constituents in ground water, soil, or
sediment, and the presence of hazardous constituents above these action levels suggests that
there has been a release requiring corrective measures. Under this approach, contamination
below appropriate action levels would not generally be subject to cleanup or further study.
For more information on corrective actions to clean up hazardous waste contamination see:
http://www.epa.gov/epaoswer/general/orientat/
Several complying actions are applicable to corrective action cases. These include:
Statute/Section
Violated
RCRA 3004VU,
3008H, 3023, 7003,
9003, 9003C(3-4),
9005
Actions with Direct
Environmental Benefits
and/or Direct
Response/Corrective Action
In-situ and Ex-situ treatment
Removal of Contaminated
Medium
Containment
Pollutant
Name
Top 3
pollutants in the
contaminated
medium
Amount
Volume of
contaminated
medium
(0 for addtl
pollutants)
Unit
Cubic
Yards
Potential
Impacted
Media
Soil
The CERCLA complying actions above are being categorized as actions with Direct
Environmental Benefits because they require immediate response in order to avoid imminent
and/or substantial endangerment to human health and the environment. Environmental benefits
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that accrue from these CERCLA actions are to be reported in ICIS in terms of the volume of
contaminated media addressed by the action. These types of cases will be quantified based on
the physical state of the medium that is addressed by the response action. For example, for soil
remedies, the volume of contaminated media measured will be the volume of soil subject to
removal or treatment. For groundwater remedies, the volume of contaminated media is the
volume of physical aquifer (not water, but entire formation) that will be addressed by the
response action.
Statute/Section
Violated
RCRA 3004VU,
3008H, 3023;7003,
9003, 9003C(3-4),
9005
Facility/Site Management and
Information Practices
Remedial Investigation/Feasibility
Study (RI/FS)
Site Assessment/Site Characterization
Provide Site Access
Pollutant
Name
Top 3
pollutants in
the
contaminated
medium
Amount
N/A
Unit
N/A
Potential
Impacted
Media
N/A
For cases with FMIP complying actions only, you may identify the pollutant/waste subject to the
action but should not identify any amount, unit, or media.
As mentioned in Section 7.0 above, RCRA corrective actions and Supcrfund response actions
may encompass several types of media-specific response actions. The following table identifies
the volume of media that should be estimated for each type of response action and the typical
reporting units that apply. More than one type of medium may be addressed and thus reported
for a given response action.
Type or Response Action
Soil (including mine tailings)
Groundwater/NAPL hydraulic
containment
Landfill/Dump/
Waste Pile/Impoundment
Soil vapor extraction (SVE)
Vapor intrusion (point of entry
control)/Landfill gas collection
Volume of Media to be Estimated
Volume of soil, fine debris, or tailings that are being
addressed (treated, removed, capped, stabilized) by
the response action.
Volume of aquifer formation (not just the water) that
is contaminated above Record of Decision (ROD)
cleanup standards and will be subject to the response
action.
Volume of soil, waste, or debris that is being
addressed (treated, removed, capped, stabilized) by
the response action.
Total volume of soil that will be subject to a
concentration reduction from SVE or volume of soil
subject to vacuum to achieve vapor recovery with
SVE.
Volume of air/vapor which will be diverted or treated
by the vapor intrusion control system over its
expected lifetime
Unit to Report in
ICIS
Cubic Yards
Cubic Yards
Cubic Yards
Cubic Yards
Cubic Yards
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Type of Response Action
Non-aqueous phase liquid
(NAPL) recovery
Sediment
Surface water
Mine drainage diversion and/or
treatment (point of entry control)
Container (e.g., drum) and large
debris removal
Volume of Media to be Estimated
Volume of formation impacted with NAPL that will
be subject to the recovery technology This volume
may also be the zone in which NAPL is known to
occur and in which a remedy will be applied to
address it
Volume of sediment to be addressed by the response
action
Volume of water, m-situ, within the surface water
body that is contaminated and that will be addressed
by the response action
Volume of drainage water that will be diverted or
treated by the mine drainage diversion and/or
treatment system over its expected lifetime.
Volume of material removed in containers or volume
of large-scale material removed, stabilized, or
disposed.
Unit to Report in
ICIS
Cubic Yards
Cubic Yards
Cubic Yards
Cubic Yards
Cubic Yards
For each of these media-specific response actions, Section 7.3.2 below discusses the case data or
calculation steps that can be used to determine the volume of media impacted by the action.
7.3.2 Calculation Methodology by Media Response Type
The following calculation methodologies apply to the media-specific response actions identified
above:
Soil, Landfill, and Soil Vapor Extraction Methodology
Step A Identify the area and depth of soil (or landfill waste) within which contamination resides. Convert to
volume by multiplying the area by the depth
Step B Determine the subset of this volume that will be addressed by the response action.
Step C Convert to units of cubic yards and report that volume in ICIS.
Notes-
I Depending on the nature of the contaminated site, you may want/need to determine multiple sub-volumes
and will then sum these to make a total volume.
2 For landfill capping, calculate the volume of waste beneath the cap based on best available information
3 You can use either m-situ or after excavation volumes - which ever data is more readily available.
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Groundwater Methodology
Step A Compile plume maps for each aquifer layer and collect information on the thickness of each aquifer
unit
Step B For each aquifer layer, calculate the area that will be addressed by the response action remedy
Step C For each aquifer layer, multiply the area by the average thickness of the aquifer unit to determine a
volume.
Step D Add up the volume(s) calculated in Step C to determine a total volume.
Step E Convert the total volume to cubic yurds and divide by 1,000 to get into the units of 1000 cubic yards.
Notes-
I If the thickness of an aquifer layer vanes by more than 50% across the area, do not use the average
thickness Instead, divide the area up into smaller areas with similar thicknesses
Vapor Intrusion and Mine Drainage Diversion/Treatment Methodology
Step A Determine the expected average volumetric flowrate of the system over the duration it will run (usually
represented as cubic feet per second (cfs)).
Step B Estimate the amount of time the system is expected to run (maybe in months or years)
Step C Multiply the flowrate by time and convert to units of cubic feet of air/vapor or cubic feet of mine
drainage to be diverted or treated
Notes
I Best professional judgement may need to be used to determine/estimate the volumetric flowrate of the
system and the expected system running time.
NAPL Recovery Methodology
Step A Determine the volume within which the NAPL recovery technology will be applied (area x depth).
Notes.
I The remedial action will be applied to an overall area within which it is known that the NAPL occurs This
is NOT the volume of NAPL itself.
2 For disjointed NAPL areas on a large scale, you can sum smaller distinct volumes.
3. If a hydraulic groundwater remedy is also subject to the response action, then the NAPL volume should be
counted and reported separately from the groundwater volume This is because NAPL recovery and
groundwater pump and treat are focused on two different phases of contaminant and usually require entirely
separate feasibility study analysis and response. It is appropriate to report both volumes, even though one lies
within the other in physical space.
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Sediment Methodology (for Rivers, Streams, Shoreline, Drainage, and Drainage
Conveyances)
Step A Determine the average downstream cross-sectional area of sediment subject to the response action
Step B Determine the length of the overall reach of sediment subject to the response action
Step C Multiply the cross-sectional area by length of reach to determine sediment volume and convert to units
of cubic yards
Notes'
I For multiple reaches, calculate a volume of sediment for each and sum the volumes
2. For lake bottoms or wetlands not along a reach, use best professional judgement to determine the area and
depth of sediment to be subject to the response action.
Surface Water Methodology
Due to the wide variety of surface water bodies, there is no single calculation that will address
all of them. The volume of surface water that is contaminated and will be addressed by the
enforcement action will therefore need to be determined using best professional judgement. If
soil or sediment lying under the water is contaminated and will also be subject to the response '
action, a separate volume estimate for the soil or sediment should be made using the
methodologies above.
Container/Large Debris Methodology
Step A Determine the volume of each container addressed by the action.
Step B Sum all volumes.
Notes:
1. If the number of containers impacted by the action is numerous, you may be able to use volumes from
manifests or billing records from bulk shipments to determine the volume of material that will be impacted by
the response action
7.3.3 Examples and Input for ICIS
Example 1. Corrective Action for Contaminated Groundwater and Soil
XYZ Industrial Company is a hazardous waste storage facility with a RCRA permit. During a
routine EPA inspection, the Agency discovered contamination in XYZ Industrial's tank storage
area. Soils under the area were contaminated by wastes spilled during pumping and by leaking
tanks. The soil exhibited high levels of trichloroethylene, benzene, and toluene, which are
volatile organic compounds that can migrate through the soil into the groundwater.
Additionally, the investigation of the site discovered that a municipal drinking water well located
within a mile of the facility was also contaminated with trichloroethylene and toluene. None of
this contamination was detected in the initial permitting process.
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EPA conducted a RCRA facility assessment (RFA) to compile information on the types of
hazardous wastes managed at the facility in the past, areas where these wastes were managed,
and possible exposure pathways.
The owner and operator of XYZ Industrial then conducted a RCRA facility investigation (RFI),
with EPA oversight, to estimate the health and environmental problems that could result if the
contamination was not cleaned up, and to determine the extent of the contamination. These
investigations showed the VOC plume extending from the facility in the direction of the drinking
water well for a distance of 4,000 feet with a plume width of approximately 100 feet. The
aquifer of the impacted area is located 20 to 25 feet below the ground surface and has an average
aquifer thickness of 20 feet. To protect human health and the environment while the assessment
and investigation were taking place, the owner and operator established an alternative drinking
water source for the households served by the municipal well as interim measures.
A corrective measures study (CMS) determined that the company should clean up the
groundwater contamination via a pump and treat process and excavate the soil for disposal off-
site at a permitted landfill. The area of soil to be remediated by the response action includes
selected sections underneath the surface area where outdoor chemical storage occurred which is
equal to 2,400 sq.ft. Two 20 ft. by 20 ft. sections of soil will be removed to a depth of 10 feet.
The recommendations of the CMS were incorporated into an administrative order imposed on
the facility by the Agency in its enforcement action.
The total remediation volumes of trichloroethylene and benzene for the facility based on the
adopted corrective action will include the volume of aquifer impacted by the groundwater pump
and treat system and the volume of contaminated soil removed.
The determination of these volumes is shown below:
For Groundwater:
Step A The average thickness of the aquifer impacted by this response action is 20 feet.
Step B The area to be impacted by the action includes the VOC plume area which is
estimated to be 4,000 feet by 100 feet = 400,000 sq.ft.
Step C The volume of aquifer impacted by the action will be 400,000 sq. ft. * 20 feet =
8,000,000 cu.ft.
Step E Convert to cu.yds. as follows:
8,000,000 cu. ft. x l cu. yd./27 cu.ft. = 296,296 cu. yd.
For Soil:
Step A The area of contamination is equivalent to the soil storage area of 2,400 sq. ft. to
10 feet of soil depth = 24,000 cu. ft.
7-13
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Step B The remediation effort will impact one third of this area or 8,000 cu. ft.
Step C 8,000 cu. ft. x | Cu. yd./27 cu. ft. = 296 cu. yds. of soil removed.
Input for IC1S:
For ground water
• Complying Actions: In-situ and ex-situ treatment, Removal
• Pollutant: Trichloroethylene
Unit: 296,296 cubic yards
• Media: Water (ground)
AND
• Pollutant: Benzene
Unit:0
• Media: Water (ground)
AND
• Pollutant: Toluene
Unit:0
• Media: Water (ground)
For soil
• Complying Actions: In-situ and ex-situ treatment, Removal
• Pollutant: Trichloroethylene
• Unit: 296 cubic yards
• Media: Soil
AND
• Pollutant: Benzene
UnitrO
• Media: Soil
AND
• Pollutant: Toluene
Unit:0
• Media: Soil
Example 2. Mine Drainage Diversion
An abandoned mine land Superfund site is currently undergoing clean up. Activities at the site
have resulted in a release of highly acidic mine drainage to a stream on the site. As part of a
Superfund response action, the mine drainage stream will be diverted and treated prior to
discharge to the stream. The amount of drainage for diversion is estimated to have a volumetric
flow rate of 0.5 cfs. The diversion of the stream is expected to occur throughout the duration of
the Superfund clean up action, i.e., 2 years.
Step A The estimate of the volumetric flow rate is 0.5 cfs.
7-14
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Step B The estimate of running time for the diversion and treatment system is 2 years.
Step C The total volume of mine drainage impacted by the response action is:
0.5 cu. ft./sec. x 60 sec./l min. x 60 min./l hr. x 24 hr./l day x 365 days/yr. x 2
years x 1 cu.yd./27 cu.ft.= 1,168,000 cu. yd.
Input for ICIS:
Complying Action: In-situ and ex-situ treatment
Pollutant: Mine Drainage
Unit: 1,168,000 cu. yd.
Media: Water (navigable/surface)
7.4 References
U.S. EPA, 2000. Office of Solid Waste, RCRA Orientation Manual Section 111. See
http://www.cpa.gov/epaoswer/general/orientat
40 CFR Part 268, Subpart D - Land Disposal Restrictions Treatment Standards
U.S. EPA. RCRA Statutory Overview.
See http://www.epa.gov/epaoswer/hotline/training/statov.txt
U.S. EPA. July 1995. Office of Solid Waste and Emergency Response. Musts for USTs: A
Summary of Federal Regulations for Underground Storage Tank Systems. See
http://www.epa.gov/swerust 1 /pubs/musts.pdf
U.S. EPA. Office of Underground Storage Tanks. 1998 Deadline for Upgrading, Replacing, or
Closing Substandard USTSystems. See http://www.epa.gov/swerust I/1998/index.htm
7-15
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8.0 TSCA VIOLATIONS
The Toxic Substances Control Act (TSCA) of 1976 was enacted by Congress to give EPA the
ability to track the 75,000 industrial chemicals currently produced or imported into the U.S.
EPA repeatedly screens these chemicals and can require reporting or testing of those that may
pose an environmental or human-health hazard. EPA can ban the manufacture and import of
those chemicals that pose an unreasonable risk.
Many of the enforcement actions under TSCA address reporting and recordkeeping activities and
result in facility management and information practice (FMIP) complying actions. These actions
do not require you to report environmental benefit in ICIS. Enforcement cases under TSCA that
result in the prevention of future human health risk or environmental impact generally include
those related to lead-based paint, PCBs, and asbestos. In addition, asbestos is also regulated
under the CAA NESHAP regulations.
This section discusses the following types of cases:
8.1 TSCA Lead-Based Paint;
8.2 TSCA Section 6 (PCBS); and
8.3 Asbestos under TSCA/AHERA and CAA NESHAP.
The sections below present various waste management and prevention examples for lead-based
paint, PCB wastes, and asbestos wastes. Each section includes background information and
example calculations and input for ICIS using specific scenarios. Section 8.4 presents references
and websites used in developing these examples. This chapter does not include examples for
core TSCA because it was assumed that instances of quantifiable direct or preventative benefits
from core TSCA would be rare and that the majority of cases would have facility management
and information practices benefits that do not require quantification.
8.1 TSCA Lead-based Paint
Deteriorated lead-based paint is a significant concern for older schools, houses, and buildings.
Buildings constructed prior to 1978 may contain lead-based paint, which, if not properly
maintained, can peel and become dust. This dust can then pose an inhalation and ingestion
hazard to children. Exposures can also occur during renovation, remodeling, or demolition
work. Children are susceptible to adverse health effects from extremely low exposures to
environmental lead.
EPA adopted final lead hazard standards on January 5, 2001 that identify dangerous levels of
lead in paint, dust and soil. These standards (at TSCA Section 403) can be found at:
http://www.epa.gov/lead/leadhaz.htm.
Under TSCA Section 402, training/certification and work practice standards are required. Under
these regulations, all persons (including school employees) that perform lead-based paint
8-1
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activities in "child-occupied facilities" must be trained and certified to conduct this work. They
must also adhere to certain work practice requirements. This applies to persons inspecting for
lead-based paint, and also to those involved in abating lead-based paint hazards.
Enforcement actions related to TSCA lead-based paint cases include the following types of
preventive actions:
Statute/Section
Violated
TSCA 406/1 01 8
TSCA 206/402/10 18
Preventative
Actions to Reduce
Likelihood of
Future Releases
Lead-Based Paint
Disclosure
Lead-Based Paint
Removal, Training,
and Certification
Pollutant Name
Lead-based paint
Lead-based paint
Amount
Number of
units
Number of
units
Unit
Single Family
Housing Units
Multi-Family
Housing Units
Building Units
Single Family
Housing Units
Multi-Family
Housing Units
Building Units
Potential
Impacted
Media
Schools/
Housing/
Buildings
"Schools/
Housing/
Buildings
When reporting environmental benefit from these cases the unit of measurement will be the
number of Single Family or Multi-Family housing or building units impacted by the enforcement
action. The pollutant to report is "lead-based paint" and the media impacted should be
identified as "schools/housing/ buildings".
Example and Input for ICIS:
For example, a lead-based paint inspection of a pre-1978 public housing project (composed of 20
housing units) identified chipped and deteriorating lead-based paint on all buildings. A
subsequent enforcement action requires disclosure of information to the housing residents and
applicable authorities, and removal and replacement of the old paint by certified personnel. Input
for ICIS would include the following:
• Complying Actions: Lead Based Paint Disclosure and Lead Based Paint Removal
Training/Certification (Preventative)
• Pollutant: Lead-based Paint
• Unit: 20 multi-family housing units
• Media: Schools/Housing/Buildings
Note: Where multiple complying actions apply, only calculate preventative benefits once.
8-2
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8.2 TSCA Section 6
TSCA Section 6 regulates certain hazardous chemical substances and mixtures and authorizes
EPA to take regulatory action to protect against unreasonable risk to human health or the
environment. EPA has promulgated regulations under Section 6 of TSCA applicable to
polychlorinated biphenyls (PCBs). The final rules applicable to the disposal of PCBs were
published on June 29, 1998. This rule provided the following:
• Flexibility in selecting disposal technologies for PCB wastes and expansion of the list of
available decontamination procedures;
• Less burdensome mechanisms for obtaining EPA approval for a variety of activities;
• Clarification and modification of implementation requirements;
• Modification of the requirements regarding the use and disposal of PCB equipment; and
• Discussion of issues associated with the notification and manifesting of PCB wastes and
changes in the operation of commercial storage facilities.
PCB.Rules fall into two broad categories: non-disposal violations and disposal violations.
Enforcement actions related to TSCA Section 6 cases include the following types of direct,
preventive, and FMIP complying actions. Generally, disposal violations will result in direct or
preventative complying actions while non-disposal violations will result in FMIP complying
actions.
Statute/Section
Violated
TSCA 6-PCBs
Actions with Direct
Environmental
Benefits/Response or
Corrective Action
Removal of
contaminated material
Waste Treatment
Pollutant
Name
PCBS
PCBS
Amount
Volume of
material properly
managed
#
Unit
Cubic yards
Pounds
Potential
Impacted
Media
Soil or
Land
Statute/Section
Violated
TSCA 6-PCBs
Preventative
Actions to Reduce
Likelihood of
Future Releases
Disposal Change
Pollutant
Name
PCBS
Amount
Volume of
material properly
managed
#
Unit
Cubic yards
Pounds
Potential
Impacted
Media
Soil or Land
8-3
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Statute/Section
Violated
TSCA 6-PCBs
Facility/Site Management and
Information Practices (FM IP)
Labeling/Manifesting
Record-keeping
Reporting
Permit Application
Notification
Pollutant Name
NA
Amount
NA
Unit
NA
Potential
Impacted
Media
NA
If the case is a labeling violation only, you should check "Labeling/Manifesting" as the
complying action and omit entering a pollutant amount.
If the case includes removal of PCB contaminated material and/or proper disposal of PCB
contaminated material, a calculation of the volume of contaminated material properly managed
by the action should be reported in cubic yards. The pollutant should be identified as "PCBS"
and the media should be identified as "soil" or "land".
Example and Input for ICIS:
For example, Clean Harbors of Braintree, Rl was sited for shipping dredged sediments with a
>50 ppm concentration of PCBs without identification of PCBs on the manifest. The
enforcement action will require proper labeling/manifesting of the waste and proper disposal of
20 cubic yards of PCB containing sediment.
• Complying Action: Disposal Change (Preventative)
Pollutant: PCBS
• Unit: 20 cubic yards
• Media: land
8.3 Asbestos under TSC A/A HERA and CAA NESHAP
The EPA is one of six agencies with the authority to regulate asbestos. The EPA's authority to
do so is provided under both the Toxic Substances Control Act (TSCA) and the Clean Air Act
(CAA). Under TSCA, EPA is authorized to enforce the requirements of the Asbestos Ban and
Phase Out Rule (ABPO) and the Asbestos Hazard Emergency Response Act (AHERA). The
Asbestos Ban and Phase Out Rule phases out and bans production of five specific types of
asbestos-containing products including corrugated paper, rollboard, and flooring paper, as well
as new uses of asbestos. AHERA prescribes asbestos management practices and abatement
standards for public schools and private, not-for-profit schools. Finally, the EPA is authorized
under the CAA at 40 CFR Part 61 Subpart M to enforce the requirements of the National
Emissions Standards for Hazardous Air Pollutants regulations dealing with asbestos (Asbestos
NESHAP). Note: asbestos was delisted under 40 CFR Part 63 as a source category but is still
regulated by 40 CFR Part 61 Subpart M.
8-4
-------
TSCA/AHERA
AH ERA required EPA to develop regulations creating a comprehensive framework for
addressing asbestos hazards in schools. The Act also required EPA to develop an accreditation
program for individuals who conduct inspections for asbestos, develop management plans, and
perform asbestos abatement work. Other provisions of AHERA require all public and private
elementary and secondary schools to conduct inspections for asbestos-containing building
materials, develop management plans, and implement response actions in a timely fashion. The
provisions of AHERA required management plans to be submitted to State agencies on or before
May 9, 1989 and local education agencies (LEAs) were required to begin implementation of
their management plans by July 9, 1989.
Enforcement actions related to TSCA/AHERA cases include the following types of preventive
and FMIP complying actions:
Statute/Section
Violated
TSCA 203
(AHERA)
TSCA 203
(AHERA)
Preventative
Actions to Reduce
Likelihood of
Future Releases
Asbestos Training,
Certification, and
Accreditation
Develop/Implement
Asbestos
Management Plun
Pollutant
Name
Asbestos
Asbestos
Amount
Number of units
Number of units
Unit
Schools,
building units
Schools,
building units
Potential
Impacted
Media
Schools/
Housing/
Buildings
Schools/
Housing/
Buildings
Statute/Section
Violated
TSCA 203
(AHERA)
Facility/Site Management and
Information Practices (FMIP)
Asbestos Inspection
Pollutant Name
NA
Amount
NA
Unit
NA
Potential
Impacted
Media
NA
When reporting environmental benefit from these cases the unit of measurement will be the
number of schools or building units impacted by the enforcement action. The pollutant to report
is "asbestos" and the media impacted should be identified as "schools/housing/buildings".
Example and Input for ICIS:
For example, under an AHERA enforcement action, the Monroe County School District has been
cited for a failure to conduct asbestos inspections at their 4 elementary /secondary schools and
have not complied with the management plan requirement for the managing and exposure
control of asbestos in each school. The school district will need to designate and train a person to
oversee asbestos-related activities in the LEA, will need to utilize a properly accredited person to
conduct the asbestos inspections and to help them develop their asbestos management plans.
8-5
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They will also need to provide custodial and maintenance staff with awareness and proper work
practices training. Input for IC1S would include the following:
• Complying Actions: Develop/Implement Asbestos Management Plan (Preventative),
Training (Preventative), and Asbestos Inspections (FMIP)
• Pollutant: Asbestos
Unit: 4 Schools*
• Media: schools/housing/buildings
* Note: Schools refers to the individual schools as opposed to school districts.
Asbestos NESHAP
The Asbestos NESHAP provides regulatory standards that are applicable to asbestos disposal
and asbestos removal from buildings as part of renovation and demolition projects. With the
goal of minimizing asbestos emissions during the processing, transport, or disposal of asbestos
containing material, the Asbestos NESHAP requires that building owners and/or
renovation/demolition contractors follow specific work practices to minimize asbestos releases.
Furthermore, the regulation requires that the proper regulatory authorities be notified prior to all
demolitions and any renovation involving certain threshold levels of asbestos containing
material.
Unlike other NESHAP regulations, the Asbestos NESHAP does not specify a numeric emission
limitation for the release of asbestos fiber during renovation/demolition, nor docs it require any
air monitoring or sampling during renovation or removal activities. Instead of a numeric
emissions limitations, the Asbestos NESHAP specifies that zero visible emissions from the
outside air are allowed during the removal, transport, or disposal of asbestos containing waste.
Towards this end, the asbestos NESHAP requires specific work practices be followed including
a requirement that any asbestos containing materials be sufficiently wetted to a level which
would prevent release of particulates prior to, during, and after renovation/demolition activities
until the point of disposal. In addition, the regulation requires that asbestos containing material
be transported in leak-tight containers or wrapped and disposed of at an acceptable disposal site.
For cases triggered by CAA 112(B) (the Asbestos NESHAP) the complying action that will
apply is "Asbestos Abatement". When reporting environmental benefit from these cases the
unit of measurement will be the number of schools or building units impacted by the
enforcement action. The pollutant to report is "Asbestos" and the media impacted should be
identified as "schools/housing/buildings".
Example Calculation and Input for ICIS:
The environmental benefit measurement of Asbestos NESHAP cases be represented by the
number of schools, housing units, or building units impacted by the action.
8-6
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For example, an inspection of Monroe County's local elementary schools identified loose and
decaying asbestos roof tiles. A corresponding enforcement action will result in the removal and
disposal of these tiles on 10 schools.
Input for ICIS:
• Complying Action: Asbestos Abatement (Preventative)
• Pollutant: Asbestos
Unit: 10 schools
• Media: schools/housing/buildings
8.4 References
U.S. EPA Region 5, Major Environmental Laws - Toxic Substances Control Act,
www.epa.gov/region5/defs/html/tsca.htm
U.S. EPA, Lead in Buildings, www.epa.gov/seahome/child/lead/lbu m.htm
U.S. EPA, Asbestos - What are the Current Asbestos Requirements,
www.epa.gov/seahome/child/asbes/asbes_req.htm
ChemAlliance, Regulatory Handbook, Background: TSCA,
www.chemalliance.org/Handbook/background/back-tsca.asp
U.S. EPA, Disposal of Polychlorinated Biphenyls (PCBs); Final Rule, Federal Register Notice.
63 FR 35383, June 29, 1998.
8-7
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9.0 ENVIRONMENTAL BENEFITS FROM FIFRA ENFORCEMENT CASES
The primary focus of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) is to
provide federal control of pesticide distribution, sale, and use. Important FIFRA requirements
include the registration of pesticides prior to their sale, distribution, or use (unless the pesticide
meets specific exemptions as described in the regulations). Registration includes acceptance by
the EPA of the pesticide's label, which gives detailed instructions for its proper use. In addition,
EPA must classify each pesticide as either "general use", "restricted use", or both. "General
use" pesticides may be applied by anyone, but "restricted use" pesticides may only be applied by
certified applicators or persons working under the direct supervision of a certified applicator.
Applicators are state-certified if the state operates an EPA approved certification program.
The EPA may issue a civil administrative compliant to any person or company who violates
FIFRA. The complaint may impose a civil penalty, and may also require correction of the
violation. EPA may also issue a Stop Sale, Use or Removal Order (SSURO) prohibiting the
person who owns, controls, or has custody of a violative pesticide or device from selling, using,
or removing that product except in accordance with the provisions of the SSURO.
FIFRA enforcement actions can produce Direct Environmental Benefit complying actions,
Preventative complying actions, and Facility/Site Management and Information Practice (FMIP)
complying actions. Direct environmental benefits should be calculated when a pesticide has been
removed from commerce and-destroyed or when an import has been denied. Preventative
benefits should be calculated when an enforcement action is taken because the pesticide was
mislabeled or not properly registered. For both Direct and Preventive complying actions the
quantity of pesticide should be calculated and the pollutant reported should be the predominant
pesticide active ingredient in the product: e.g., malathion or simazme.
Example of 1CIS input where Direct Environmental Benefit Complying Action is taken:
Applicable
Section
FIFRA 12
FIFRA 13
Actions with Direct
Environmental
Benefits/Response or
Corrective Action
Pesticide Destroyed
Import Denied
Pollutant Name
Pesticide Active
Ingredient
Amount
One year's
worth of
production of
pesticide
destroyed or
denied
import
Unit
Pounds
(convert
gallons to Ibs
using
instructions in
Section 10.0)
Potentially
Impacted
Media
Land
Plants
9-1
-------
Example of ICIS input where Preventative Actions Occur:
Applicable
Section
F1FRA 12
FIFRA
12A2G
Preventative Actions to
Reduce Likelihood of
Future Releases
Pesticide Registered
Pesticide Certified
Pesticide Claim Removed
Pesticide Label Revision
Worker Protection
Notification
Pollutant
Name
Pesticide
Active
Ingredient
Pesticide
Active
Ingredient
Amount
One year's
worth of
production of
pesticide
Number of Ag
Workers on-site
the day the
Inspector visited
the facility.
Unit
Pounds
(convert
gallons to Ibs
using
instructions in
Section 10.0)
People
Potential
Impacted
Media
Land
Plants
Humans
9.1 Examples and Input for ICIS
Example I. SSURO (Direct Environmental Benefit Example)
Under a stop sale order, you know that a pesticide identified as Product X and containing
malathion as its active ingredient will be taken off the shelf and destroyed. One hundred pounds
of the material will be impacted by the action. The FIFRA Section Violated is FIFRA 12.
Input for ICIS:
• Complying Action: Pesticide Destroyed
• Pollutant: Malathion
• Unit: 100 pounds
• Media: Land, Plants
Example 2. FIFRA Prevention Example
ABC Greenhouse is selling a homemade herbicide containing bromacil called "ABC's Choice".
The case reveals that ABC Greenhouse was selling 100 Ibs of ABC Choice a year and the
herbicide was not registered with the EPA. The FIFRA Section Violated is FIFRA 12A1A
(Unregistered Pesticide).
Input for ICIS:
• Complying Action: Pesticide Registration
• Pollutant: Bromacil
• Unit: 100 pounds
• Media: Land, Plants
9-2
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Example 3. FIFRA Misuse Example
Farmer X has sprayed his sweet corn crop with the herbicide simazine and did not post any sort
of notification in the field to inform his five agricultural workers that the chemicals had recently
been applied. During an EPA inspection of the farm, the inspector notes the lack of notification
and issues an administrative penalty order. As a result of the EPA action, we know that the
farmer has posted the appropriate notification. The FIFRA Section Violated is FIFRA I2A2G
(Misuse).
Input for ICIS:
• Complying Action: Notification
• Pollutant: Simazine
Unit: 5 People
• Media: Humans
9.2 References
U.S. EPA Region 5, Major Environmental Laws - Federal Insecticide, Fungicide, and
Rodenticidc Act, www.epa.uov/region5/defs/html/fifra.htm
9-3
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10.0 DENSITIES, UNITS AND UNIT CONVERSIONS
Unit conversion is a simple tool which allows you to describe a quantity in other terms that are
of interest. In its most basic form, unit conversion may contain only one step involving
multiplication of a given quantity by a known conversion factor. More complex conversions
may involve handling multiple sets of given information and conversion factors all within the
same calculation. However, the steps for both simple and more complex unit conversions are the
same as illustrated by the following examples.
Example 1. Simple Unit Conversion
To convert a pollutant loading discharged to a stream from 1.5 kilograms (kg) per day to pounds
(Ibs) per day requires the following information: 1.5 kg per day, represents the given information
and 2.2 Ibs per 1 kg, represents the required conversion factor.
A unit conversion will return an answer in the units of interest. This is accomplished by
canceling out identical units that are opposite to each other in separate entries (i.e., one must be
in the denominator and one must be in the numerator of the respective entries). In this example,
the units for kilograms have been canceled out to return an answer in Ibs per day:
1.5 kg 2.2 Ibs _ 3.3 Ibs
^^_^_^^^^_ X ^^^^^^^^^^— — ^^^—^-^^^—•
day 1 kg day
Example!. Complex Unit Conversion
An example of a complex unit conversion would be calculating the pounds of paniculate matter
(PM) emitted per year when given an actual pollutant concentration of 0.15 grains (gr) of PM per
dry standard cubic feet (dscf) of exhaust and an exhaust flow rate of 75,000 dscf per minute. For
this calculation, the following conversion factors are used.
• 7,000 grains per pound • 8,760 hours per year
• 60 minutes per hour
As with the previous example, all units except pounds and year will cancel each other out thus
returning an answer in the units of interest, pounds per year:
0.15 grains x 75,000 dscf x 1 pound x 60 minutes x 8,760 hours = 844,714 pounds
1 dscf 1 minute 7,000 grains 1 hour year year
10-1
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Example 3. Conversion Requiring Density Information
When dealing with liquid wastes, conversion from a unit of volume to a unit of mass may be
required. This can be done using information on the density of the liquid waste/material. An
example would be to convert 100 gallons of toluene waste into its equivalent mass (in pounds)
using the density of toluene:
100 gallons toluene x 7.227 Ibs/gallon = 722.6 Ibs. of toluene
Table 10-1 below includes common density factors to use in converting a volume of liquid waste
to mass. Chemical densities can also be identified from Material Data Safety Sheets (MSDS)
which are accessible via online databases. Table 10-2 below contains common conversion
factors encountered in calculations to determine pollutant loading. Table 10-3 contains various
examples of unit conversions commonly used to calculate pollutant loadings in air, solid waste,
and water media, respectively.
Table 10-1. Common Densities
Pollutant
Triethylamme
Gasoline/Petroleum
hydrocarbons/PAHs
Acetone
Methyl Ethyl Ketone(MEK)
Toluene
Fuel Blend/Xylene
Benzene
Ammonium Hydroxide
Styrene Resin
Waste oil/Diesel fuel/Crude
oil/Asphaltic oil
Water
o-Toluidme
Salt water/Brine
Density Conversion
(Ibs/gallon)
6.054
6.092
6.609
6.718
7.227
7.260
7.335
7.489
7.536
7.594
8345
8412
8762
Pollutant
Spent Hydrochloric Acid
Acrylic Polymer
Spent Nitric Acid
Antifreeze
Hydrogen Peroxide
Sodium Hypochlonte
Dodecylbenzene Sulfonic
Acid (DDBSA)
1 , 1 ,"1 -Tnchloroethane
Methylene Chloride
Sodium Hydroxide
PCBs
Tetrachloroethylene/
Perchloroethylene
Sulfunc Acid
Density Conversion
(Ibs/gallon)
9 163
9.2
9305
9.346
9597
9.722
10.014
11 057
11 149
11.683
12*
13.552
15.021
* As per the PCB penalty policy.
Sources: CRC Handbook of Chemistry and Physics, Perry and Chilton's Chemical Engineers
selected Material Data Safety Sheets.
Note. Densities will vary based on the concentration of the solution and its temperature. The
table are approximate.
' Handbook, and
values included in this
10-2
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Table 10-2. Common Conversion Factors
Mass
1 microgram (ug) =
1 milligram (mg) =
1 gram (g) =
1 kilogram (kg) =
1 kilogram (kg) =
1 megagram (Mg) =
1 pound (lb) =
1 pound (Ib) =
1 ton (short) =
1 ton (short) =
1 000 picograms (pg)
1 000 micrograms (ug)
1000 milligrams (mg)
1000 grams (g)
2.2 pounds (Ibs)
1 ,000 kilograms (kg)
7,000 grains (gr)
454 grams (g)
0.907 metric tons
2,000 pounds (Ibs)
Volume
1 cubic foot (ft3) =
1 cubic yard (yd3) =
1 gallon (gal) =
7.481 gallons (gal)
0 764 cubic meters (m3)
3.785 liters (1)
Time
1 day =
1 hour =
1 year =
1 year =
24 hours
60 minutes
365 days
8,760 hours
Area
1 Acre =
43,560 square feet (sq. ft.)
Table 10-3. Examples of Common Pollutant Loading Conversions for
Different Media
Air
0.15 gr PM 75,000 dscf 1 pound 60 minutes 8.760 hours
1 dscf 1 minute 7,000 gr 1 hour
1 year
844,714 pounds PM
year
0-»7 Ibs NUX x IQO million Btu x 8.760 hours = 61.32U Ibs NU,
1 million Btu 1 hour 1 vear vear
0.13 pounds VOC 110 thousand Ibs steam 8,760 hours 125,268 pounds VOC
thousand Ibs steam
1 hour
1 year
year
Solid Waste
00 mg benzene x 500 yd3 soil x 1.4 Mg soil x 0.764 m' x 1.000 kg x 1 Ib x 1 g _ 118 11
1kg soil X 1 1 m3 soil 1 vd3 1 Mg 454 g 1,000 mg "benzei
Water
4.95 mg benzene removed 1,000 gal 3.785 { 365 days 1 g 1 Ib
^^~" X - - - X ^^^^~^^^^ X ^^^^^~^^^~^ X " X
treated
1 day
1 year 1,000 mg 454 g
IS ibs benzene
year
80 mg BOD x 9,000.000 gal x 3.785 ( x g
1C 1 day 1 gal 1,000 mg " 454 g
1 Ib = 6,002 Ibs BOD
day
10-3
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n.o LOOK-UP TABLES
Table 11-1. Typical Pollutant Concentrations (lb/d/1000# of animal) in As
Excreted Manure for Beef and Dairy Cattle
Pollutant
Manure
TS
COD
BOD,
N
P
K
Lactating Dairy Cow
80.00
10.00
890
1.60
045
007
026
Dry Cow
82.00
9.50
8.50
1.20
0.35
0.05
0.23
Heifer
85.00
914
8.30
1.30
031
0.04
024
Beef Cow
6300
7.30
6.00
1.20
0.33
012
0.26
Source. USDA's Agricultural Waste Management Field Handbook, Chapter 4.
Table 11-2. Typical Pollutant Concentrations (lb/d/1000# of animal) in As
Excreted Manure for Swine
Pollutant
Manure
TS
COD
BOD, •
N
P
K
Grower Pig
(40-220 Ib)
634
6.34
6.06
208
0.42
0.16
0.22
Replacement
Gilt
32.8
3.28
3.12
1.08
0.24
0.08
0 13
Sow
Gestation
272
2.50
2.37
083
0.19
006
0.12
Sow
Lactation
60.0
600
573
200
0.47
0.15
0.30
Boar
20.5
1.90
1.37
065
0 15
0.05
0.10
Nursery Pig
(0-40 Ib)
1060
10.60
980
340
0.60
0.25
035
Source USDA's Agricultural Waste Management Field Handbook, Chapter 4.
ll-l
-------
Table 11-3. Typical Supernate Pollutant Concentrations (lbs/1000 gal) in
Lagoons and Runoff Ponds9
Pollutant
TS*
COD
BOD,
N
P
K
Dairy Anaerobic
Lagoon
20.82
1250
2.92
1 67
0.48
4.17
Dairy Aerobic
Lagoon
4.17
1.25
0.29
0.17
008
-
Beef Feedlot
Runoff Pond
25.00
11 67
-
1.67
-
7.50
Swine Anaerobic
Lagoon
20.83
10.00
3.33
291
0.63
3 16
a - Source. USDA's Agricultural Waste Management Field Book, Chapter 4,
the TS value is calculated as the sum of the volatile solids + fixed solids concentrations
Table 11-4. Typical Manure Recoverability Factors and Nitrogen/Phosphorus
Losses by Animal Type
Animal Type
Beef Cows
Milk Cows
Heifers
Breeding Hogs
Hogs for Slaughter
Recoverability Factor
098
098
098
095
0.95
Nitrogen Losses
(percent loss)
60.0
59.8
700
750
750
Phosphorus Losses
(percent loss)
15 1
14 1
154
154
149
Source1 USDA's Manure Nutrients Relative to the Capacity of Cropland and Pastureland
to Assimilate Nutrients. Spatial and Temporal Trends for the United States, December 2000.
Table 11-5. Typical Animal Weight and Manure Density for Beef and Dairy
Cattle
Animal Type
Beef Cattle
Mature Dairy Cattle
Heifers
Animal Weight (Ibs)
877
1,350
550
Manure Density (Ib/cu. ft.)
62
62
62
Source' Cost Methodology Report for Beef and Dairy Animal Feeding Operations, EPA-821-R-01-019, January
2001.
1-2
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Table 11-6. Typical Crop Uptake Values
Crop Type
Com for gram
Corn for silage
Soybeans
Sorghum for grain
Sorghum for silage
Cotton (lint and seed)
Barley
Winter wheat
Durum wheat
Other spring wheat
Oats
Rye for grain
Rice
Peanuts for nuts (w/pods)
Sugar beets for sugar
Tobacco (IN, MO, OH, and WV)
Tobacco (KY)
Tobacco (NC)
Tobacco (TN)
Tobacco (VA)
Tobacco (all other states)
Potatoes
Sweet Potatoes
Alfalfa hay
Small grain hay
Other tame hay/Wild hay
Grass silage
Sorghum hay
Nitrogen
(Ibs N/yield unit)
0 80 Ibs/bushel
7.09 Ibs/ton
3 55 Ibs/bushel
0 98 Ibs/bushel
14 76 Ibs/ton
15 19lbs/bale
0.90 Ibs/bushel
1 02 Ibs/bushel
1.29 Ibs/bushel
1 39 Ibs/bushel
0 59 Ibs/bushel
1 07 Ibs/bushel
l.251bs/bag
0.04 Ibs/lb
4 76 Ibs/ton
0 0298 Ibs/lb
00299 Ibs/lb
0.0329 Ibs/lb
0.0302 Ibs/lb
0 0322 Ibs/lb
00330 Ibs/lb
0.36 Ibs/bag
0.1 3 Ibs/bushel
50 40 Ibs/ton
25.60 Ibs/ton
19.80 Ibs/ton
13.60 Ibs/ton
2.39 Ibs/ton
Phosphorus
(Ibs P/yield unit)
0.1 5 Ibs/bushel
1.05 Ibs/ton
0.36 Ibs/bushel
0. 1 8 Ibs/bushel
2 44 Ibs/ton
l.89lbs/bale
0.1 8 Ibs/bushel
0 20 Ibs/bushel
0.22 Ibs/bushel
0.23 Ibs/bushel
0 1 1 Ibs/bushel
O.I 8 Ibs/bushel
0.29 Ibs/bag
0 003 Ibs/lb
0 94 Ibs/ton
0.0024 Ibs/lb
0.0024 Ibs/lb
0.0020 Ibs/lb
0.0023 Ibs/lb
0.0021 Ibs/lb
0.0020 Ibs/lb
0.06 Ibs/bag
0.02 Ibs/bushel
4 72 Ibs/ton
4.48 Ibs/ton
15.30 Ibs/ton
1 60 Ibs/ton
1.01 Ibs/ton
Source- USDA's Manure Nutrients Relative to the Capacity of Cropland and Pastureland to Assimilate Nutrients.
Spatial and Temporal Trends for the United States, December 2000.
1-3
-------
Table 11-7. NOX and SO2 Emission Factors for Boiler Fuel Oil Combustion
Firing Configuration (SCC)"
NO, Emission Factor
(Ib/lO'gal)"
SO, Emission Factor
(lb/lb/101 gal)c
Boilers > 100 Million Btu/hr
No. 6 oil fired, normal firing (1-01-004-01), (1-02-004-
01), (1-03-004-01)
No. 6 oil fired, normal firing, low NOX burner, (1-01-
004-01), (1-02-004-01)
No. 6 oil fired, tangential firing, (1-01-004-04)
No 6 oil fired, tangential firing, low NO, burner, (1-01-
004-04)
No 5 oil fired, normal firing (1-01-004-05), (1-02-004-
04)
No. 5 oil fired, tangential firing, (1-01-004-06)
No. 4 oil fired, normal firing (1-01-005-04), (1-02-005-
04)
No. 4 oil fired, tangential firing, (1-01-005-05)
No 2 oil fired (1-0 1-005-0 ]),( 1-02-005-0 !),( 1-03-005-
01)
No. 2 oil fired, LNB/FGR, (1-01-005-01), (1-02-005-
01), (1-03-005-01)
47
40
32
26
47
32
47
32
24
10
I57S
157S
157S
157S
157S
157S
I50S
150S
157S
I57S
Boilers < 100 Million Btu/hr
No 6 oil fired, (1-02-004-02/03). (1-03-004-02/03)
No 5 oil fired, (1-03-004-04)
No 4 oil fired, (1-03-005-04)
Distillate oil fired (1-02-005-02/03), (1-03-005-02/03)
Residential furnace (A2104004/A2 10401 1)
55
55
20
20
18
I57S
I57S
I50S
L42S
I42S
a - SCC = Source Classification Code
b - Expressed as NO,. Test results indicate that at least 95% by weight of NOX is NO for all boiler types except
residential furnaces, where about 75% is NO. For utility vertical fired boilers use 105 lb/103gal at full load and
normal (>15%) excess air Nitrogen oxides emissions from residual oil combustion in industrial and commercial
boilers are related to fuel nitrogen content, estimated by the following empirical relationship: Ib NO2/103gal = 20.54
+ 104 39(N), where N is the wight % of nitrogen in the oil. For example, if the fuel is 1% nitrogen, then N = 1.
c - S indicates that the weight % of sulfur in the oil should be multiplied by the value given. For example, if the fuel
is 1 % sulfur, then S= 1.
Source: Table 1.3-1 of AP-42 (EPA, 1995)
11-4
-------
Table 11-8. NOX Emission Factors for Boiler Natural Gas Combustion
Combustor Type (MMBtu/hr Heat Input [SCC|
NO, Emission Factor (Ib/IO* scO°
Large Wall-Fired Boilers (>IOO) 1 1-0 1-006-01, 1-02-066-01, 1-03-006-01 1
Uncontrolled (Pre-NSPS)h
Uncontrolled (Post-NSPS)h
Controlled - Low NO, burners
Controlled - Flue gas recirculation
280
190
140
100
Small Boilers (
-------
Table 11-9. SO, Emission Factors for Boiler Natural Gas Combustion
1 Pollutant
SO,a
Emission Factor (lb/106scf)
06
a - Based on 100% conversion of fuel sulfur to SO,. Assumes sulfur content is natural gas of 2,000 grams/10'' scf.
The SO2 emission factor in this table can be converted to other natural gas sulfur contents by multiplying the SO2
emission factor by the ratio of the site-specific sulfur content (grains/106 scf) to 2,000 grains/10*1 scf.
Source: Table 1.4-2 of AP-42 (EPA, 1995)
Note: This emission factor is to be used for all natural gas fired boilers
Table 11-10. NOX Emission Factors for Process Heater Natural Gas
Combustion
Type of Process
Heater
ND
MD
Uncontrolled NO,
Emission Factor
(lb/MMBtu)J
0.098
0 197
NO, Control Technique
(ND) LNB
(ND)ULNB
(ND) SNCR
(ND)LNB + (ND)SNCR
(MD) LNB
(MD)ULNB
(MD)SNCR
(MD) SCR
(MD)LNB+FGR
(MD) LNB + SNCR
(MD) LNB + SCR
Controlled NO,
Emission Factor
(Ib/MMBtu)
0.049
0.025
0039
0.020
0099
0.049
0079
0.049
0089
0039
0025
u - Uncontrolled emissions for natural gas-fired heaters are from thermal NO, formation
ND = natural draft
MD = mechanical draft
Source. Table 5-11 and 5-12 of Alternative Control Technique? Document - M9, Emissions Jrom Process Heaters
(EPA, 1993)
1-6
-------
Table 11-11. NOX Emission Factors for Process Heater Oil Combustion
Model Heater
Capacity
(MMBtu/hr)
69
69
135
135
Type of
Process
Heater
ND
ND
MD
MD
Fuel
Distillate Oil
Residual Oil
Distillate Oil
Residual Oil
Uncontrolled Emission
Factor (Ib/MMBtu)
Thermal
NO,"
0 14
0.14
0.26
0.26
Fuel
NO,"
0.06
0.28
006
0.28
NO, Control
Technique
(ND) LNB
(ND) ULNB
(ND) SNCR
(ND) LNB +
(ND) SNCR
(ND) LNB
(ND) ULNB
(ND) SNCR
(ND) LNB +
(ND) SNCR
LNB
ULNB
SNCR
SCR
LNB 4 FGR
LNB + SNCR
LNB + SCR
LNB
ULNB
SNCR
SCR
LNB + FGR
LNB + SNCR
LNB + SCR
Controlled
NO, Emission
Factor
(Ib/MMBtu)
0 121
0.048
0.080
0.048
0.308
0.097
0.168
0 123
0 175
0082
0.128
0.080
0 168
0070
0026
0340
0143
0.216
0.135
0355
0136
0051
a - Uncontrolled emission factor for thermal NO, represents the NOX from thermal NO, formation
b - Uncontrolled emission factor for fuel NO, represents the NO, from fuel NO, formation
ND = natural draft
MD = mechanical draft
Source. Table 5-13 and 5-14 of Alternative Control Techniques Document - NOt Emissions from Process Heaters
(EPA, 1993)
1-7
-------
Table 11-12. Estimated Control Efficiencies (%) for NOX
Process
Chemical Manufacturing
Fuel Combustion - Coal
Fuel Combustion - Coal
Fuel Combustion - Coal
Fuel Combustion - Coal
Fuel Combustion - Coal
Fuel Combustion - Coal
Fuel Combustion - Coal
Fuel Combustion -
Distillate Oil
Fuel Combustion -
Distillate Oil
Fuel Combustion -
Distillate Oil
Fuel Combustion -
Dislilliite Oil
Fuel Combustion - Coal
Fuel Combustion - Coal
Fuel Combustion - Coal
Fuel Combustion -
Municipal Waste
Fuel Combustion -
Municipal Waste
Fuel Combustion - Natural
Gas
Fuel Combustion - Natural
Gas
Fuel Combustion - Natural
Gas
Fuel Combustion - Natural
Gas
Operation
Acrylomtrile -
Incinerator
Stacks
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Incinerator
Boiler
Boiler
Boiler
Boiler
Control Device Type
Selective Non-catalytic
Reduction
Flue Gas Recirculation
Low Excess Air
Low NO, Burners
Natural Gas Bumers/Reburn
Overfire Air
Selective Catalytic Reduction
Selective Non-catalytic
Reduction
Flue Gas Recirculution
Low Excess Air
Overfire Air
Selective Catalytic Reduction
Low-N0x Burner with Selective
Non-catalytic Reduction
Low-NOx Burner with Overfire
Air and Selective Catalytic
Reduction
Low-NO, Burner with Overfire
Air
Selective Catalytic Reduction
Selective Non-catalytic
Reduction
Flue Gas Recirculation
Low Excess Air
Low NO, Burners
Overfire Air
Average
Control
Efficiency (%)
80
90
69
60
Control
Efficiency
Range (%)
5-45
5-30
35-55
50-70
5-30
63-94
45-55J
2-19
20-45
90 (max)
50-80
85-95
40-60
80 (max)
30-65
49-68
0-31
40-85
13-73
11-8
-------
Table 11-12. Estimated Control Efficiencies (%) for NO, (Continued)
Process
Fuel Combustion - Natural
Gas
Fuel Combustion - Natural
Gas
Fuel Combustion - Natural
Gas
Fuel Combustion - Natural
Gas
Fuel Combustion - Natural
Gas
Fuel Combustion - Natural
Gas
Fuel Combustion - Natural
Boiler Gas
Fuel Combustion - Residual
Oil"
Fuel Combustion - Residual
Oil
Fuel Combustion - Residual
Oil
Fuel Combustion - Residual
Oil
Fuel Combustion - Residual
Oil
Fuel Combustion - Utility
Oil or Natural Gas
Fuel Combustion - Wood
Mineral Products Industry
Petroleum Industry
Petroleum Industry
Operation
Boiler
Boiler
Gas Turbines
Gas Turbines
Reciprocating
Engines
Gas Turbines
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Boiler
Glass Flue
Process Heater
Process Heater
Control Device Type
Selective Catalytic Reduction
Selective Non-Catalytic
Reduction
Selective Catalytic Reduction
Water or Steam Injection
Selective Non-catalytic
Reduction
Staged Combustion
Low-NOx Burner with Overfire
Air
Flue Gas Recirculation
Low Excess Air
Overfire Air
Selective Catalytic Reduction
Selective Non-catalytic
Reduction
Flue Gas Recirculation
Selective Non-catalytic
Reduction
Selective Non-catalytic
Reduction
Selective Catalytic Reduction
Selective Non-catalytic '
Reduction
Average
Control
Efficiency (%)
21
90
-
Control
Efficiency
Range (%)
80-90
35-80
60-96
60-94
80-90
50-80
40-50
2-31
5-31
24-47
70-80
35-70
40-65
50-70
50-75
35-70
a - Average of widely varying values
Source: Table 12.3-1 of EIIP, Vol II, Chapter 12
11-9
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