August 12, 1998
Mr. Robert Perciasepe
Assistant Administrator
Office of Air and Radiation (6101)
Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
Dear Mr. Perciasepe:
On July 28 - 29, 1998, the Industrial Combustion Coordinated Rulemaking (ICCR) Federal
Advisory Committee (a.k.a. ICCR Coordinating Committee) met to discuss recommendations and
thoughts to forward to the Environmental Protection Agency (EPA) for consideration regarding
the development of regulations under Sections 112 and 129 of the Clean Air Act. The Committee
reached closure and is submitting the attached documents to the EPA for consideration.
The ICCR Coordinating Committee was established by the EPA under the Federal Advisory
Committee Act (FACA) in September, 1996. The purpose of the Committee is to develop
recommendations for consideration by EPA in the development of regulations for the following
stationary combustion source categories: combustion turbines; internal combustion engines;
industrial-commercial-institutional boilers; process heaters; and non-hazardous waste incinerators
(excluding municipal waste combustors and medical waste incinerators). Sections 112 and 129
direct the EPA to develop regulations limiting emissions of hazardous air pollutants (and several
criteria air pollutants) from these source categories by November, 2000.
The Coordinating Committee met six times in fiscal year 1997 and, to date, has met four times in
fiscal year 1998. Notice of all meetings of the Committee was published in advance in the Federal
Register and all meetings were open to the public.
The Charter establishing this committee expires in September, 1998. At the July meeting of the
Committee, the EPA announced that, after much consideration, the Charter for this committee
will not be renewed. As a result, the final meeting of the ICCR Coordinating Committee is
scheduled for September 16 - 17, 1998 in Durham, North Carolina.
Sincerely,
[Signed By]
[Signed By]
Richard F. Anderson, Ph.D.
Stakeholder Co-Chair
ICCR Coordinating Committee
ICCR Coordinating Committee
Fred L. Porter
EPA Co-Chair
cc: Bruce C. Jordan - Director, Emission Standards Division
John S. Seitz - Director, Office of Air Quality Planning and Standards
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Attachments
Attachment I - Emission Testing Recommendations
Attachment II - Boiler Emission Testing Recommendations
Attachment III - Recommended Subcategories and MACT Floors for Existing Stationary
Reciprocating Internal Combustion Engines (RICE)
Attachment IV - Thoughts on Pollution Prevention Planning Requirements Offered to EPA
for Consideration
Attachment V - Thoughts on Alternative Compliance - Flexible Permitting Offered to EPA
for Consideration
Attachment VI - Thoughts on Options for ICCR MACT Rules Offered to EPA
for Consideration
Attachment VII - Draft Industrial/Commercial Waste Incinerators (ICWI) and Other Solid Waste
Incinerators (OSWI) Thoughts on Regulatory Alternatives Offered to EPA
for Consideration
Attachment VIII - Thoughts On An Economic and Benefits Analysis Framework Offered To EPA
for Consideration
2
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ATTACHMENT I
ICCR COORDINATING COMMITTEE
EMISSION TESTING RECOMMENDATIONS
The ICCR Coordinating Committee forwards these recommendations for emission testing
to EPA for consideration. To the extent resources for emission testing may be limited, it is the
general sense of the Committee that resources should be focused on incinerators as defined in
Section 129 of the Clean Air Act, boilers, and internal combustion engines.
JULY 29, 1998
3
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SOURCE: Boilers
SOURCES/SUBCATEGORIES RECOMMENDED TO BE TESTED: Boilers firing non-
fossil materials, such as tires and sludge, particularly those co-firing with wood and/or coal.
PURPOSE & NEED FOR TESTING: The ICCR Coordinating Committee recommends a 2-
phase test plan. Phase I would focus on materials testing and emissions testing to fill in obvious
data gaps. Phase II would fill in remaining data gaps.
Phase I: Materials testing- The ICCR boiler databases indicate very little information are
available on non-fossil materials. Therefore, it is difficult to determine whether some non-fossil
materials are similar and can be grouped together and it is also difficult to determine what HAPs
may be emitted from some of the non-fossil materials. Materials testing will be used to:
characterize non-fossil materials with the goals being to group similar materials together; help
prioritize materials and HAPs for further emissions testing; and help identify what control
strategies may be feasible based on the material composition and pollutants they could emit.
Another result would be that limited emissions data on non-fossil materials may be used to
characterize emissions for materials where information is lacking.
Phase I: Emission testing- A review of the ICCR boiler emissions database, test reports
expected from ICR requests, and a literature search for emissions and materials information
indicated that there are significant data gaps in emissions data for HAPs of interest and Section
129 pollutants from boilers that co-fire various non-fossil materials with primary fuels (wood or
coal). The most prevalent and representative types of non-fossil co-fired boilers for which HAP
and Section 129 pollutant emission data are lacking are industrial sludges and tires co-fired with
wood. Data on the effects on emissions of co-firing different percentages of these materials are
lacking. Such data are needed to determine into which of the current subcategories co-fired
boilers should be placed (i.e. classified by primary fuel or in a non-fossil subcategory) and to
characterize emissions and develop emission standards that will apply to non-fossil co-fired units.
Emission data are also lacking on the effects of co-firing various percentages of wood and coal,
which is a common practice. Therefore, the phase I emission test will focus on collecting data on
non-fossil materials (sludges and tires) co-fired with wood at varying percentages and on co-firing
of coal and wood at varying percentages.
Phase II: Emissions testing- The phase II emissions testing is meant to: (1) fill data gaps on
emissions from fuel/wastes and/or boiler subcategories for which there are little or no emissions
data; (2) establish performance of control techniques, i.e., fill data gaps on control device
performance and impact of combustion control techniques (GCP) on emissions; (3) understand
the effects of operating parameters on emissions and (4) fill data gaps on interaction between
criteria pollutants and HAP emissions.
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SUMMARY OF CURRENTLY AVAILABLE TEST DATA: Version 3 of the boiler
emissions database contains test data from 183 emission reports. Only 45 reports are currently in
the database for boilers burning non-fossil non-wood materials. The reports are limited to a few
materials burned, mostly landfill gas and industrial sludge. Of these, 20 reports are for boilers
solely burning a non-fossil material (mostly landfill gas), and 16 reports are for boilers co-firing
non-fossil materials with wood or coal. A materials analysis database is also available that
contains information on fuel/waste characteristics for a large number of materials. Materials
where information is lacking are identified in the "Description of Combustion Units and Materials
to be Tested, Phase I: Materials testing".
DATA GAPS TESTING WOULD FILL: See purpose and needs section
ALTERNATIVES TO TESTING: If emissions testing is not conducted, EPA is likely to rely
on the materials analysis to place boilers in subcategories, but the placement of co-fired units will
be questionable. EPA is also likely to rely on the limited emission tests for non-fossil boilers to
characterize emissions from all non-fossil materials burned. If materials testing is not conducted,
EPA is likely to rely on existing information to place boilers firing various materials into
subcategories, but data for some materials is lacking so the placement will be uncertain.
DESCRIPTION OF COMBUSTION UNITS AND MATERIALS RECOMMENDED TO
BE TESTED:
Phase I: Materials testing- Coke plant liquids, tall oils and turpentines, waste activated
biological sludge from brewery wastes, wastewater treatment sludges from various industries,
waste paper from printing, rice hulls, shells, corn stalks, mil-spec coatings, and automotive body
coatings.
Phase I: Emissions testing- A representative boiler (stoker) co-firing sludge and or/ tires with
wood and/or coal at various percentages.
Phase II: Emissions-See "Number of Combustion Units and Tests, Phase II: Emissions
Testing".
NUMBER OF COMBUSTION UNITS AND TESTS RECOMMENDED:
Phase I: Materials testing-Samples should be collected from 31 facilities (approximately 3
samples per material to be tested)
Phase I: Emissions testing- The test should be conducted on one representative boiler and
should consist of 3 test runs under each of several conditions, for example:
• Firing primary fuel (wood) alone under representative operating conditions
• Firing wood with sludge at 2 or 3 different percentages (up to 30% sludge if possible)
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• Firing wood with tires at 2 or 3 different percentages (up to 25 or 30% tires if possible)
• Firing wood with waste oil at a low percentage, if the test site burns waste oil
• Firing coal with wood at 3 different percentages, if the test site can fire coal
All of the above conditions should include control device inlet and outlet testing
Phase II: Emissions testing- If a single facility can not accommodate the material combinations
listed above in phase I, EPA should test a second boiler in phase II to collect remaining data.
Additional emission test needs may depend on the results of Phase I testing and review of test
data currently being submitted by ICR respondents. Potential tests which EPA should consider
include:
• Testing a representative boiler co-firing another type of non-fossil material (3 test
conditions).
• Test a representative boiler with GCP under different operating conditions, for example, 3
load levels and 3 air/fuel ratios.
• Test a representative boiler with a control technique or control combination not tested
during phase I for which data are lacking.
RECOMMENDED POLLUTANTS TO BE TESTED/ANALYSES TO BE CONDUCTED:
Phase I Materials testing: ultimate; metals in fuel; heat content; moisture content; total
halogens; organics; particle size (for solids); viscosity (for liquids); specific gravity (for liquids);
and bottoms, sediment, and water (for liquids).
Phase I and Phase II Emission testing: Section 129 pollutants (PM, CO, NOx, S02, HC1, lead
cadmium, mercury, dioxins/furans), additional metals (e.g., antimony, arsenic, beryllium,
chromium, manganese, and nickel), PAH, PCBs, benzene, formaldehyde, and radionuclides
(during coal co-fired runs only)
LEVERAGING OF RESOURCES: To reduce the number of emissions tests, the results of a
literature search was reviewed, attachments to ICR survey responses reviewed, and available test
reports reviewed. The Committee believes that the cost and scope of the recommended testing
has been significantly reduced.
COST:
Phase I: Materials - $183,000 - 221,000
Phase I: Emissions - $820,000 - 1,070,000
Phase II: Emissions - $1,000,000 - 2,000,000
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SOURCE: Combustion Turbines
SOURCES/SUBCATEGORIES RECOMMENDED TO BE TESTED: 5 combustion
turbines (3 natural gas and 2 distillate oil-fired turbines)
PURPOSE & NEED FOR TESTING: A review of the combustion turbines emissions database
indicates that additional emissions data should be collected to support the ICCR rulemaking
development for this source category. Very little data are available in the emissions database on
control technologies with the potential to reduce HAP emissions. Two test reports are available
for turbines with lean pre-mix combustion systems, and one test report is available for a turbine
with a CO oxidation catalyst system. Therefore, additional test data should be collected to
evaluate the HAP emission reduction effectiveness of these control systems. These test data
could be used to establish emission standards for NESHAP regulations. Also, only a limited
number of the tests in the emissions database were conducted at multiple operating loads.
Therefore, test data could be collected to more thoroughly evaluate the impact of load changes on
HAP emissions.
SUMMARY OF CURRENTLY AVAILABLE TEST DATA: The combustion turbines
emissions database contains test data from 70 source tests. Most of these source tests were
conducted in the State of California as part of the AB 2588 program (Air Toxics "Hot Spots"
Information Assessment Act of 1987). However, only two source tests were conducted on LPM
combustion systems, and only one source test is available in the emissions database for a CO
oxidation catalyst system.
DATA GAPS TESTING WOULD FILL: Test data should be collected to support MACT
emission limitations and to determine the control effectiveness of CO oxidation catalysts and LPM
combustion systems.
ALTERNATIVES TO TESTING: Based on catalyst vendor information, some turbines are
equipped with CO oxidation catalyst systems. These turbine operators could be contacted to
ascertain whether test data are available to determine the control effectiveness of these systems.
If test data are not available for these systems, EPA should conduct source tests to develop these
data.
DESCRIPTION OF COMBUSTION UNITS AND MATERIALS RECOMMENDED TO
BE TESTED: Five combustion turbines (3 natural gas and 2 distillate oil-fired turbines). Sizes
of the combustion turbines: 1-10 megawatts (MW), 15-50 MW, and >70 MW for the three
natural gas-fired turbines; 15-50 MW and >70 MW for the two distillate oil-fired turbines.
NUMBER OF COMBUSTION UNITS AND TESTS RECOMMENDED: For the three
natural gas-fired turbines, two tests should involve stack sampling to characterize emissions from
LPM combustors. The third natural gas-fired turbine test should involve sampling at the inlet and
outlet of a CO oxidation catalyst system. Two load conditions should be evaluated for each of
1-4
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these three turbines. Each test condition should involve a set of 3 runs. Therefore, the LPM-
related tests would involve two sets of three runs; one set of three runs at each of the two load
conditions. The CO oxidation catalyst-related test should involve four sets of three runs; two sets
of three runs (inlet and outlet of the catalyst) at each load condition.
For the two distillate oil-fired turbines, sampling should be conducted at the inlet and outlet of the
CO oxidation catalyst system on each turbine. Two load conditions should be evaluated for each
of these two turbines. As discussed above for the natural gas-related tests, each test condition
should involve a set of 3 runs. Therefore, the tests should involve four sets of three runs; two sets
of three runs (inlet and outlet of the catalyst) at each load condition. Also, if one of these turbines
has water or steam injection, one test should be conducted with the water or steam injection
turned off.
An attempt should be made to identify a cogeneration unit equipped with a duct burner for one of
the five source tests described above. If this type of unit can be identified, sampling should be
conducted at the inlet to the duct burner in addition to the sampling runs discussed above.
Therefore, this test would involve two additional sets of three runs; one set of three runs at each
of the two load conditions.
POLLUTANTS RECOMMENDED TO BE TESTED: See Table 1
LEVERAGING OF RESOURCES: To reduce the number of tests, EPA should try to identify
a natural gas-fired turbine employing LPM combustion and a CO catalyst system. If this type of
turbine can be identified, the number of natural gas tests would be reduced from three to two.
Also, a test of a turbine equipped with an oxidation catalyst system was recently conducted and
EPA should obtain a copy of this test. Results from this test should be adequate for consideration
by EPA.
COST: The estimated total cost for testing the five combustion turbines is $350,000.
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TABLE 1. Pollutants Recommended to be Measured
Pollutants
Test Methods**
Natural Gas
Distillate Oil
Hazardous Air Pollutants (HAPs)
2,2,4-Trimethylpentane
Method 18/TO-14
X
X
Acetaldehyde
FTIR/CARB 430/EPA TO-11
X
X
Acrolein
FTIR/CARB 430
X
X
Arsenic Compounds*
Fuel Analysis (ASTMD5185)
X
X
Benzene
Method 18/TO-14/CARB 410A
X
X
Beryllium Compounds*
Fuel Analysis (ASTMD5185)
X
Biphenyl
CARB 429 and 429 (m)
X
X
Cadmium Compounds*
Fuel Analysis (ASTMD5185)
X
Chromium Compounds*
Fuel Analysis (ASTMD5185)
X
Ethylbenzene
Method 18/TO-14/CARB 410A
X
X
Formaldehyde
FTIR/CARB 430/EPA TO-11
X
X
Flexane
Method 18/TO-14
X
X
Lead Compounds*
Fuel Analysis (ASTMD5185)
X
Manganese Compounds*
Fuel Analysis (ASTMD5185)
X
Mercury Compounds*
Fuel Analysis (ASTMD5185)
X
X
Methanol
Method 18/TO-14/Method 308
X
X
Naphthalene
CARB 429 and 429 (m)
X
X
Nickel Compounds*
Fuel Analysis (ASTMD5185)
X
PAH
CARB 429 and 429 (m)
X
X
Phenol
CARB 429 and 429 (m)
X
X
Styrene
Method 18/TO-14
X
X
Toluene
Method 18/TO-14/CARB 410A
X
X
Xylene (total)
Method 18/TO-14/CARB 410A
X
X
Criteria Pollutants
Carbon monoxide (CO)
EPA Method 10/FTIR
X
X
Oxides of nitrogen (NOx)
EPA Method 7E/FTIR
X
X
Particulate Matter (PM)
Method 5
X
Total Flydrocarbons (THC)
Method 25A
X
X
TABLE 1 FOOTNOTES:
*To be measured using fuel sampling only .
**These test methods have been recommended or have been used to obtain emissions data on these pollutants.
1-6
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SOURCE: Incinerators
SOURCES/SUBCATEGORIES RECOMMENDED TO BE TESTED: Drum reclaimers
PURPOSE & NEED FOR TESTING: The EPA ICCR emissions database, trade group
records, EPA technical documents, State agency resources, and State air permits that specify
emission limits were reviewed and no data could be found to characterize these units. As a result,
emissions data should be collected to characterize these units.
SUMMARY OF CURRENTLY AVAILABLE TEST DATA: The ICR survey did not
identify any HAPs emission data for drum reclamation furnaces.
DATA GAPS TESTING WOULD FILL: The following emissions data gaps have been
identified:
1. Little data to characterize most Section 129 pollutants.
2. Unknown effect of furnace differences on emissions, including size and age of the unit.
3. Unknown effectiveness of possible MACT control devices.
ALTERNATIVES TO TESTING: Since little data exist to determine either a numerical
emission limit or a percent reduction, the only alternative to testing would be to develop a MACT
standard based on engineering judgement or experience with other similar facilities.
DESCRIPTION OF COMBUSTION UNITS AND MATERIALS RECOMMENDED TO
BE TESTED: Typically these units are semi-continuous, natural gas fired tunnel furnaces
equipped with afterburners. Process rates range from 40 to 500 55-gal drums per hour.
Container residues may include hazardous materials. The units tested should be operated at or
near the maximum rated/permitted capacity and should utilize a thermal oxidizer. Operating
conditions should be representative of normal operating conditions. The following testing
priorities are proposed:
Priority 1 — A natural gas fired drum furnace with a thermal oxidizer running approximately 300
drums per hour (over 10 years of age)
Priority 2 — A natural gas fired furnace with a thermal oxidizer running less than 200 drums per
hour (any age; small business)
Priority 3 — A natural gas fired furnace with a thermal oxidizer running 300 or more drums per
hour (less than 10 years of age)
NUMBER OF COMBUSTION UNITS AND TESTS RECOMMENDED: The ICCR
Coordinating Committee recommends testing three drum reclamation furnaces for all Section
129 pollutants.
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POLLUTANTS RECOMMENDED TO BE TESTED: All Section 129 pollutants
LEVERAGING OF RESOURCES:
COST: A preliminary estimate for the three emissions tests recommended, data analysis, and
data reporting is about $300,000.
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SOURCE: Incinerators
SOURCES/SUBCATEGORIES RECOMMENDED TO BE TESTED: Industrial
wastewater sludge and solid waste incinerators.
PURPOSE AND NEED FOR TESTING: A review of the survey and emissions databases
indicates that additional emissions data should be collected to support a Section 129 rulemaking
for miscellaneous industrial and waste incineration units. In particular, there are little data on
dioxin emissions or controls in the databases, and it appears the only source of dioxin
information is the EPA Dioxin Primer. Dioxin is a Section 129 listed air pollutant which must
have a specific emission limit.
SUMMARY OF CURRENTLY AVAILABLE TEST DATA: There are 15 units in the
inventory database that incinerate wastewater sludge. Of these 15 units, 14 were surveyed by
EPA for testing results. No data were found on dioxin emissions or control equipment
effectiveness in removing dioxins from flue gases. Based on data provided by the EPA Dioxin
Primer, these units may have a high potential for dioxin emissions based on the following factors
that may potentially contribute to dioxin formation:
1. The feed to the unit contains complex organics.
2. There is entrained PM.
3. The units have PM controls.
4. The feed to the unit contains metals and chlorine.
5. The temperature to the PM control device is itself controlled.
6. These units can have heat recovery.
There are 138 facilities in the ICCR population database that incinerate non-wastewater,
industrial solid waste. Of these 138 units, 73 were surveyed by EPA for testing results. No
data were found on dioxin emissions or control equipment effectiveness from the flue gases of
the incinerators in this category. Based on data provided by the EPA Dioxin Primer, these
units may have a high potential for dioxin emissions, based on the same six factors listed above
for the incineration of wastewater sludge.
DATA GAPS TESTING WOULD FILL: It appears there are no data on dioxins in the ICCR
databases.
ALTERNATIVES TO TESTING: One alternative to testing would be the adoption of a
current standard such as those for the medical waste or municipal solid waste combustor
MACTs; another would be to develop a MACT standard based on engineering judgement or
experience with other similar facilities.
DESCRIPTION OF COMBUSTION UNITS AND MATERIALS RECOMMENDED TO
BE TESTED: Tests should be conducted on stack emissions from the incineration of industrial
1-9
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wastewater sludges and the incineration of non-wastewater industrial solid waste to determine
the effectiveness of add-on controls. The primary test should be for dioxin. However, stack
tests for all 129 pollutants should be conducted. The primary purpose of the tests would be to
determine the effectiveness of add on controls in controlling dioxin emissions.
NUMBER OF COMBUSTION UNITS AND TESTS RECOMMENDED: Tests should be
conducted on one unit burning industrial wastewater solid waste. This unit should have
particulate controls that make it representative of a controlled unit. In order to be
representative of the entire category, the wastewater going to the wastewater treatment plant
that produces the sludge should contain halogenated and metal components. It is also
recommended that the testing of this type of incinerator be coordinated testing of boilers
burning sludges.
Tests should also be conducted on three units burning industrial non-wastewater solid waste.
Tests should be conducted on units controlled for particulates. The selection of units to be
tested should be based on an analysis of the feed to the unit, the particulate control device, and
the use of a temperature quench system.
RECOMMENDED POLLUTANTS TO TESTED: Concurrent tests should be conducted
for all Section 129 pollutants at the inlet and outlet of the air pollution control device. The
waste streams should also be characterized for chlorine and metal content. This could be
accomplished through testing or an engineering analysis of the feed.
LEVERAGING OF RESOURCES:
COST: It is estimated that the total cost for the testing program would be between $600,000
and $700,000.
I - 10
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SOURCE: Incinerators
SOURCES/SUBCATEGORIES RECOMMENDED TO BE TESTED: Metal parts
reclaimer burnoff units.
PURPOSE & NEED FOR TESTING: Reviews of the survey and emissions databases
indicate that additional emissions data should be collected to support rulemaking development
for metal parts reclaimer burnoff units. The emission test database has little information for
metal parts reclaimer burnoff units, while the survey database indicates the existence of very
limited emissions data, mostly for PM and CO. Emissions data should be collected to establish
numerical emission limits for the nine Section 129 pollutants.
SUMMARY OF CURRENTLY AVAILABLE TEST DATA: The ICCR Coordinating
Committee recommends subcategorizing metal parts reclaimer units into three groupings,
electrical winding reclaimer burnoff units, polyvinyl chloride fPVCVcoated metal parts
reclaimer burnoff units, and non-PYC-coated metal parts reclaimers burnoff units. Based on
review of the survey database, existing emission test data are as follows:
POLLUTANT
ELECTRICAL
WINDINGS
PVC-COATED
PARTS
NON-PVC-
COATED
PARTS
TOTAL
Carbon
monoxide
14
0
4
18
Lead
1
0
0
1
Nitrogen oxides
7
0
3
10
Particulate matter
12
0
7
19
Sulfur dioxide
4
0
3
7
Cadmium
1
0
0
1
Dioxins
2
0
0
2
Hydrogen
chloride
3
0
0
3
Mercury
1
0
0
1
Most of the Section 129 pollutant emission test data are for electrical winding reclaimer burnoff
units. Reliable, recent, Section 129 pollutant emission data for PVC-coated and non-PVC-
coated metal parts reclaimer burnoff units is limited.
DATA GAPS TESTING WOULD FILL: Due to the large amounts of chlorine present in
PVC, published ambient PCDD/PCDF data, and operational conditions, it is likely that
hydrogen chloride and dioxins are emitted from PVC-coated metal parts reclaimer burnoff units.
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For PVC-coated and non-PVC-coated metal parts reclaimer burnoff units, no emissions data
exist for metals, hydrogen chloride, and dioxins. Testing would assist in establishing numerical
emission limits for these pollutants as required under Section 129.
ALTERNATIVES TO TESTING: A materials balance approach could be employed to
estimate hydrogen chloride emissions from PVC-coated metal parts reclaimer burnoff units.
Natural gas combustion emission factors could be used to estimate emissions of NOx, due to
the fact that most NOx emissions would not be expected to be fuel-derived. However, for the
other Section 129 pollutants, especially dioxins, emission data should be collected by stack
testing. Samples of cured coatings pyrolyzed in non-PVC-coated metal parts reclaimer burnoff
units could be collected and this could provide direction for further stack testing.
DESCRIPTION OF COMBUSTION UNITS AND MATERIALS TO BE TESTED: Most
metal parts reclaimer burnoff units are small natural gas-fired batch units equipped with
afterburners. A few may be equipped with wet scrubbers or fabric filters. They are often only
differentiated based on the type of parts they are used to reclaim. Many non-PVC-coated parts
reclaimer burnoff units burn off cured coatings from paint hooks and racks. Other non-PVC
coatings include rubber, nylon, and polyethylene. Electrical winding reclaimer burnoff units
burn off transformer cores or electric motor windings. Transformer dielectric fluid may contain
PCBs. Electric motor windings are generally coated with a clear, nonpigmented varnish. A
small number (estimated 30 to 50) of units burn off plastisol-coated electroplating racks.
Plastisol is a suspension of PVC in a phthalate plasticizer. Plastisol serves as a tough,
temperature- and chemical-resistant dielectric on the surface of the metal electroplating racks.
NUMBER OF COMBUSTION UNITS AND TESTS RECOMMENDED: Given the
similarity of design and operation of most metal parts reclaimer burnoff units, a relatively small
number of emission tests would help support Section 129 pollutant emission limits. Complete
Section 129 pollutant testing is recommended for two PVC-coated metal parts reclaimer
burnoff units and two non-PVC-coated metal parts reclaimer burnoff units. Due to the
existence of Section 129 pollutant emission data for electrical winding reclaimer burnoff units,
no additional testing for this type of unit is recommended at this time.
POLLUTANTS RECOMMENDED TO BE TESTED: The ICCR Coordinating Committee
recommends concurrent outlet-only testing for the entire set of Section 129 pollutants -
particulate matter, carbon monoxide, sulfur dioxide, nitrogen oxides, lead, hydrogen chloride,
dioxins, cadmium, and mercury.
LEVERAGING OF RESOURCES: Local Ohio air agency staff could provide stack test
observers to ensure conformance to U.S. EPA Reference Methods.
COST: Outlet-only testing for the nine Section 129 pollutants (per unit) is estimated to be
about $65,000. Cost estimates may need to be adjusted based on the methods used. The total
cost for four tests would be about $260,000.
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SOURCE: Incinerators
SOURCES/SUBCATEGORIES RECOMMENDED TO BE TESTED: Pathological waste
incinerators and crematories.
PURPOSE & NEED FOR TESTING: To show the effect that varying ratios of non-tissue
pathological waste and up to 30% "other" waste have on emission levels of Section 129
pollutants from human crematories and three distinct classes of pathological incinerators. The
"other" waste feed may include hospital, medical, infectious, or pharmaceutical wastes.
This information should be collected to examine the following assumptions: (a) emissions
among human crematories and all of the pathological waste incinerators are sufficiently similar
that they can be treated as one subcategory for regulatory development, (b) pollution prevention
in the form of limits on waste feed content is a viable regulatory alternative, and (c) emissions
from these incinerators have distinct differences from other classes of incinerators that have
previously been the subject of regulatory development. In addition, the purpose is to help
evaluate the impact of operating parameters on emissions to determine whether equipment
design and parameters can achieve reductions of emissions and the performance of add-on
controls. Finally, the information could be used as a basis for estimating reductions in emissions
for various regulatory alternatives for the purpose of economic analysis.
SUMMARY OF CURRENTLY AVAILABLE TEST DATA: Limited test data for Section
129 criteria pollutants may be available. However, it appears little consistent data under known
test conditions, including waste feed, are available for all Section 129 pollutants, except a test
for a human crematorium using California Air Resources Board methods and two tests from the
EPA on a medical waste incinerator burning greater than 95% animal tissue. EPA is currently
obtaining test reports identified in the ICR database. It is unlikely, however, that useful data
will be obtained from these requests. In addition, other test reports reviewed have not clearly
identified waste streams or the technology of the test methods utilized. In summary, the
emissions information reviewed thus far has not been shown to be consistent, complete, and
compatible with EPA methods and test procedures.
DATA GAPS TESTING WOULD FILL: The data should be collected to support MACT
emission limitations.
ALTERNATIVES TO TESTING: The ICCR Coordinating Committee is not aware of any
other sources of data.
DESCRIPTION OF COMBUSTION UNITS AND MATERIALS RECOMMENDED TO
BE TESTED: Units that are expected to be representative of all the units in the subcategory
should be selected for testing. For the under 100 lb/hr group, the unit tested should be of a
single-chamber design. Non-tissue wastes should be burned that are expected to give the
highest emission levels.
I - 13
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NUMBER OF COMBUSTION UNITS AND TESTS RECOMMENDED: Four units total
— two representative retort design units in the 100 to 500 lb/hr grouping; one representative
multi-chamber design unit in the greater than 500 lb/hr grouping; and one representative single
chamber, under 100 lb/hr unit. There are a maximum of nine tests recommended, each test
consists of three sampling runs (see attached Matrix of Test Conditions).
RECOMMENDED POLLUTANTS TO BE TESTED: All the 129 pollutants in every
testing scenario. The largest data gap is for dioxins/furans, which are the most expensive
pollutants to sample. However, sampling for the remaining 129 pollutants would be worth the
additional cost.
LEVERAGING OF RESOURCES:
COST: Based on $70,000 per test for all the 129 pollutants, the total cost is estimated to be
about $630,000 for all nine tests.
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MATRIX OF TEST CONDITIONS
Pathological Waste Incinerators and Crematories
Combustor
characteristics
>500 lb/hr; multi-
chamber; animal
incinerator; 1 sec.
ret. time; 1800°F
sec. chamber temp.
100-500
lb/hr;
retort;
human
crematory;
1 sec. ret.
time;
1600°F sec.
chamber
temp.
100-500
lb/hr
retort;
animal
incinerator;
1 sec. ret.
time;
1600°F sec.
chamber
temp.
<100 lb/hr;
single
chamber;
poultry
incinerator;
standard
operating
cond.
Test case #
1
2
3
4
5
6
7
8
9
Priority
(A is highest)
C
A
A
A
A
B
B
C
D
% of tissue by
mass
70
30
30
80-
90
50-
60
90
60
10
0
90
% of bedding/
container by
mass
20
60
40
10-
201
40-
502
10
10
0
0
% of other
feed by mass
10
10
30
0
0
0
30
0
10
Cardboard cremation container weighing approximately 15 lb.
2Cremation container with wood, cloth, and/or cardboard, typically 40 to 100 lb.
I- 15
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SOURCE: Reciprocating Internal Combustion Engines (RICE)
SOURCES/SUBCATEGORIES RECOMMENDED TO BE TESTED: Four subcategories
should be tested:
• Spark ignited natural gas-fired two stroke lean burn engines
• Compression ignited liquid fuel (diesel fired) engines
• Spark ignited natural gas-fired four stroke lean burn engines
• Spark ignited natural gas-fired four stroke rich burn engines
PURPOSE & NEED FOR TESTING: The following goals are recommended for emissions
testing:
1. Acquire additional emissions data that can assist in determining the effectiveness of after-
treatment control devices to reduce formaldehyde and other HAPs;
2. Acquire additional emissions data that can assist determining the effectiveness of combustion
modifications to reduce formaldehyde and other HAPs;
3. Acquire additional emissions data that can assist in determining typical emissions for engines
throughout the operating range.
The testing recommendations are designed around Goal #1, for the following reasons:
• Emissions data to demonstrate the effectiveness of possible MACT control devices for
existing RICE is a data gap in the ICCR Emissions Database for RICE, (see Appendix
A of the Test Plan)
• Understanding of the effects of combustion modifications on HAPs is in its infancy, and
would require a very extensive research program to identify potential control techniques,
along with confirming testing.
In addition, the recommendations are further focused to address the effectiveness of after-
treatment control devices on formaldehyde emissions, primarily, and on other HAPs,
secondarily. Emissions data should be collected for all HAPs included on the target list of
pollutants; however, the control devices recommended for testing were selected principally for
their potential to reduce formaldehyde emissions. This focus was added to the testing
recommendations for the following reasons:
• Formaldehyde is a product of incomplete combustion and generally is the HAP emitted
in the greatest quantities from RICE.
• A possible basis for maximum achievable control technology (MACT) for formaldehyde
I - 16
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has been identified based on the results of earlier emissions testing. There is less
understanding of possible MACT for other HAPs.
The test recommendations also support Goal #3 in part, since recommendations are included to
record pre-controlled emissions throughout a 16-point test matrix during the testing.
SUMMARY OF CURRENTLY AVAILABLE TEST DATA: The ICCR Coordinating
Committee reviewed the emissions data in the EPA ICCR Emissions Database for RICE, and
determined the emission levels reported were highly variable. The variability could be attributed
to 1) interferences associated with certain test methods or 2) the operating conditions of the
engines when tested. In addition, many of the test reports lacked key information about
engineering and operating parameters that could affect HAP emissions, such as makes, models,
engine types, horsepower rating, speed, and air to fuel ratio. The ICCR Coordinating
Committee also recommends that data should be collected regarding the effectiveness of
possible MACT control devices in reducing HAP emissions. Although there are some data in
the database for before and after control, the data for NSCR correspond to a limited number of
pollutants and high detection limits, and the data for oxidation catalysts include only a small
number of pollutants measured both before and after controls. A representative control
efficiency is difficult to determine with the data currently available.
DATA GAPS TESTING WOULD FILL: The recommended testing would fill the following
key emissions data gaps:
1. The effect of operating conditions on emissions, including:
• Air to fuel ratio sensitivity
• Speed and load
• Air manifold temperature
• Jacket water temperature
• Injection or spark timing sensitivity
• Engine balance sensitivity
2. The effectiveness of possible MACT control devices in reducing HAP emissions, including
oxidation catalysts and NSCR.
ALTERNATIVES TO TESTING: The alternative to testing would be to set a MACT floor
based on an equipment standard, since little data are available to determine either a numerical
emission limit or a percent reduction.
DESCRIPTION OF COMBUSTION UNITS AND MATERIALS RECOMMENDED TO
BE TESTED:
• 2-stroke lean burn natural gas engine with oxidation catalyst: Cooper Bessemer GMV4-
TF
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• 4-stroke lean burn natural gas engine with oxidation catalyst: Waukesha 3521 GL
• 4-stroke rich burn natural gas engine with NSCR catalyst: White Superior 6G825
• 4-stroke diesel engine with oxidation catalyst: Caterpillar 3508 "interim"
NUMBER OF COMBUSTION UNITS AND TESTS RECOMMENDED: Four
combustion units should be tested following a recommended 16-point test matrix of operating
conditions. These are listed below:
• Four corners of the torque/speed envelope (runs 1-4)
• Air to fuel ratio sensitivity (runs 1, 5-6)
• Speed and load (run 7)
• Air manifold temperature (run 8)
• Jacket water temperature (runs 1, 11-12)
• Injection or spark timing sensitivity (runs 13-14)
• Engine balance sensitivity (runs 1, 15-16)
RECOMMENDED POLLUTANTS TO BE TESTED: Emissions data for the following
criteria pollutants should be collected:
• Carbon monoxide (CO)
• Nitrogen oxides (NOx)
• Total hydrocarbons (THC)
• Particulate matter (PM) (diesel only)
Ten hazardous air pollutants are included in the test recommendations for all engines, regardless
of fuel:
• BTEX (benzene, toluene, ethylbenzene, and xylene)
• Three aldehydes (formaldehyde, acetaldehyde, and acrolein)
• Naphthalene
• 1,3-butadiene
PAHs
In addition, n-hexane and metals are included for diesel fuel.
LEVERAGING OF RESOURCES: Gas Research Institute and PRC International currently
plan to conduct some of the tests recommended above at a projected cost of $ 200,000. To
minimize costs incurred by EPA, EPA could decide not to repeat these tests.
COST: The recommended emissions tests, data analysis and data reporting would cost
$870,000. If EPA decides not to repeat or duplicate the testing GRI and PRC plan to
undertake, EPAs costs would be reduced by about $200,000 to $ 670,000.
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ATTACHMENT II
ICCR COORDINATING COMMITTEE
BOILER EMISSION TESTING RECOMMENDATIONS
JULY 29, 1998
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TABLE OF CONTENTS
Section Page
1.0 INTRODUCTION 1
2.0 SOLID/LIQUID/GASEOUS FUEL/WASTE CHARACTERIZATION 7
3.0 PHASE I EMISSION TESTING 11
4.0 PRIORITIZATION 17
5.0 ESTIMATED COSTS 17
6.0 SUMMARY OF PROPOSED PHASE I EMISSION TEST 17
LIST OF APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
LIST OF TABLES
Table
1 Possible Fuel Analysis Test Method
2 Number of Boilers in ICCR Survey Database Firing Nonfossil Materials
LIST OF FIGURES
Figure Illustrating Overall Test Plan Strategy (Phases I and II)
List of Materials for Fuel/Waste Analysis and Suggested Number
of Samples
Fuel/Waste Sampling and Analysis Methods
Estimated Costs to Conduct Phase I Testing
Figure
1 Frequency Distribution for Industrial Sludge Co-fired With Wood
-------
1.0 INTRODUCTION
The ICCR Coordinating Committee recommends that additional fuel characterization
and hazardous air pollutant (HAP) emissions data be gathered for boilers. The boiler source
category is large and highly variable. The ICCR Survey Database shows that boilers combust
many nonfossil materials and wood materials, in addition to fossil fuels. The ICCR Emissions
Database currently contains no HAP emission test data for most types of nonfossil materials.
While the ICCR Survey Database indicate some additional test reports are available and EPA
has requested these, there will probably still be data gaps on emissions from nonfossil materials.
The purpose of Phase I testing would be to assess characteristics and emissions from
combustion of nonfossil materials where data are incomplete, and to determine the effects of co-
firing these materials with other materials for which there is likely to be sufficient data (wood or
coal). The data could be used to help determine into which subcategory co-fired units should be
placed (i.e. should they be dealt with on the basis of the primary fuel they are firing, or placed
in a nonfossil subcategory). The Committee recommends that the data be collected at a
representative unit so that it could be used to help establish emission standards.
In order to obtain additional emissions data (both hazardous air pollutants (HAPs) and
criteria pollutants), the Committee recommends this Phase I plan for materials analysis and
emissions testing of boilers. The Committee has developed this Phase I test plan with the
knowledge that resources under ICCR are extremely limited. The Phase I Test Plan does not
address all the questions that could be answered regarding emissions from boilers and the
effectiveness of potential maximum achievable control technology (MACT). However, the
results of this Phase I test plan would provide additional data, address key data gaps that have
been identified in the ICCR Emissions Database for boilers, and provide information for
prioritizing recommendations under Phase II stack testing.
1.1 Overall Test Plan Strategy
The Committee recommends a 2-phase test plan. Phase I would focus on filling obvious
data gaps. Phase I would obtain more information on fuel/waste characteristics in order to
better focus and prioritize further emission testing recommendations under a Phase II to fill
remaining data gaps.
1.1.1 Why a Multi-Phase Test Plan?
Good utilization of resources
• Characterize fuels/wastes in Phase I because easy, low cost, and fills many data gaps.
• Field test boiler representing large population to fill data gaps on emissions from
combustion of nonfossil materials and determine the effects of co-firing the most
common non-fossil materials with a primary fuel.
II- 1
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• Extend resources to detailed emissions testing at later date, as needed.
Effective Method to Obtain Test Data with Large Variance in Population
• Not similar equipment like Reciprocating Internal Combustion Engines or Stationary
Gas Turbines.
• Not just gaseous and liquid fossil fuels (a few exceptions) like Process Heaters.
• Fuel characterization provides definition on many dissimilarities.
Limits Number of Emissions Tests
• Use fuel/waste characterization to categorize many sources.
• Test only a few categories later instead of many "apparently different" sources now.
1.1.2 Fuels/Waste and Emissions Data
The Committee used the following three steps to identify potential data gaps with regard
to boilers that could be filled by testing.
Obtain data directly applicable
• The Committee has reviewed the following data sources to obtain information on the
types of fuels/wastes combusted in boilers and available emission test data:
ICCR Inventory database.
ICCR Survey database and survey attachments.
ICCR Emissions database.
Fuel/waste characterization data submitted by stakeholders
Previous EPA reports such as wood characterization reports
Utilize data indirectly applicable
• The Committee also reviewed data from other source categories that may be applicable
to some subcategories of boilers. These data sources include:
Utility HAPs.
Municipal solid waste.
Office of Solid Waste data (BIF boiler or incinerator tests).
Other ICCR Sources.
Literature search (continuing during Phase I).
Define Data Gaps
II-2
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• Data gaps established by what above sources do not provide.
• Use Test Plan to fill gaps.
1.1.3 Phase I Goals
Elements of Phase I Testing
• Fuel/waste characterization.
• Boiler emissions test.
Fill Gaps with the Greatest Need or Impact
• Large number of sources with similar fuels/wastes.
• Highly suspected HAP emitters.
Focus on Nonfossil Fuels
• Develop subcategorization.
• Assess emissions from combustion of nonfossil materials where data are incomplete.
• Determine the effects of cofiring the most common nonfossil materials with other
materials for which we likely have sufficient data (e.g., wood).
Perform Qualitative and Quantitative Evaluation of Potential Control Techniques
• Fuel/waste characterization helps determine what control techniques are technically
feasible or not feasible for a subcategory.
• Emission test should be collected at a controlled boiler and include inlet and outlet
testing.
Predict Emissions from Fuel/Waste Characterizations
• Input to developing Phase II emission test recommendations.
• Control device performance.
Obtain Immediate Emissions Data for Large Category With Data Gap
• Representative boiler.
• Combusting non-fossil materials of interest with a primary fuel.
1.1.4 Strategy of Fuel/Waste Characterization
• Define intrinsic properties of fuel/waste (C, H, O, S, N, halogens, moisture, heat
content, metals, etc.).
II-3
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Determine Similar Fuels/Wastes
Characterization could allow grouping of nonfossil fuels/wastes with similar
characteristics. Some may look similar to fossil or wood materials.
Reduce size of "other" subcategory
Identify similarities in multiple fuel classifications.
Refine Nonfossil HAPs list
Identify materials with halogens or metals.
Predicted Emissions
Determine recommendations for Phase II testing (e.g., which fuels/wastes require further
emission testing).
Perform qualitative evaluation of control techniques.
.5 Objectives of Phase I Emission Testing
Choose Representative Boiler
Large population with no or little data.
Multi nonfossil fuel boiler cofiring common nonfossil materials with a primary fuel.
Determine Emissions
Metals
Dioxin and PAH
Criteria Pollutants
Section 129 Pollutants
Use in Identifying HAPs of Concern for Subcategory
Use to identify effects of fuel mixtures
Evaluate Control Device Performance on Pollutants
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1.1.6 Objectives of Phase II Testing
The purposes of Phase II testing would be to:
• Fill potential data gaps on emissions from fuel/wastes and/or boiler subcategories for
which there are little or no emissions data.
• Establish performance of control techniques, i.e., fill potential data gaps on control
device performance and impact of combustion control techniques (good combustion
practices) on emissions.
• Fill data gaps on interactions between criteria pollutants and HAP emissions.
• Understand the effects of operating parameters on emissions.
1.2 Components of the Phase I Test Plan
Phase I of the recommended boiler test program is designed to collect data in the most
cost-effective manner to determine the emissions behavior of different fuels/wastes for which
little or no data may exist. Emissions could be determined by the following methods:
• Fuel/waste analysis, and
• Emissions/control technique performance testing.
The recommended Phase I test plan contains two basic elements:
• Recommendations for Fuel/Waste Sampling and Analyses
• Recommendations for Emission Testing of a Combination Fuel-Fired Boiler
The recommended Phase I solid/liquid fuel/waste characterization plan has two components:
• Recommendations Collection and Analyses of Fuels/Wastes
• Recommendations for Specific Analyses
The Recommended Phase I emission test plan has four components:
• Purpose and Background Information on Data and Data Gaps,
• Recommendations for Boilers, Fuels/Wastes, and Emission Control Techniques Tested,
• Recommendations for Matrix of Operating Conditions Tested,
• Recommendations for Pollutants to be Measured During Testing, and test Methods to
Quantify Emissions.
Each of these components is discussed in the sections below. A summary table for
the proposed emission test is provided in the final section of these recommendations.
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1.3 Testing Goals
The Committee has identified the following goals for Phase I and/or Phase II testing:
1. Acquire additional fuel/waste characterization data that can assist in grouping
materials with similar characteristics and identify materials of particular concern
to prioritize recommendations for Phase II emission testing.
2. Acquire emission data from a representative boiler combusting nonfossil
materials where data are incomplete such that the data could be used to help
establish emission standards.
3. Acquire emissions data that can assist in determining the effect of cofiring
nonfossil fuels/wastes with primary fuels for which there is likely to be sufficient
data (e.g., wood).
4. Acquire additional emissions data that can assist in determining emissions for
boilers throughout the operating range and the effects of operating parameters.
5. Acquire additional emissions data that can assist in determining the effectiveness
and inter-relationships of combustion modifications in terms of controlling HAPs
and criteria pollutants (namely, NOx and CO).
6. Acquire additional emissions data that can assist in determining the effectiveness
of post-combustion control devices to reduce HAPs.
The recommended Phase I test plan is designed around Goals #1, 2, and 3:
• Fuel/waste characterization data on many of the fuel/waste materials currently
combusted in boilers is a data gap in the ICCR Inventory, Survey and Emissions
Databases for boilers.
• This plan would accomplish the above goals at a lower cost than a very extensive testing
program to address the HAP effects from cofiring a multitude of combinations of
fuels/wastes identified in the databases.
In addition, the Committee has focused the recommended Phase I plan to address the
effectiveness of a post-combustion control device on HAPs. The Committee recommends
gathering emissions data for all HAPs included on the recommended target list of pollutants.
The recommended Phase I test plan also will support Goal #6 in part, since simultaneous inlet
and outlet (of the control device) emission sampling is recommended during testing.
2.0 SOLID/LIQUID/GASEOUS FUEL/WASTE CHARACTERIZATION
2.1 Materials to Sample
The Committee recommends that approximately 8 different fuel/waste materials be
sampled and analyzed (see Appendix B) Each of these fuels/wastes is currently being burned in
boilers or incinerators based on the results of the ICCR Survey Database. For each material, the
II-6
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Committee recommends that samples from 1 to 12 facilities would be collected and analyzed.
This results a maximum of 34 samples. In the recommendations developed at the April 1998
Committee meeting, 36 different materials (120 samples) were identified for possible sampling
and analysis. As discussed at that meeting, the Committee reviewed other available data to
reduce the list of materials to sample. In particular, some fuel/waste analyses were attached to
the ICR Survey responses, included in emission test reports, or submitted by stakeholders. The
Committee reviewed these to see if they were complete and provide the needed information. A
literature search was also conducted to see if fuel analyses are already available for some of the
fuel/waste materials. Based on the data available from these sources, the Committee
significantly reduced the recommended number of materials to sample. The main focus of the
recommendations is on a characterization of nonfossil materials. Where mixtures of materials
are burned, each constituent should be separately collected and analyzed, if possible.
The materials recommended for fuel/waste analysis include:
• Various solid materials such as waste paper and agricultural materials;
• Sludges from industrial wastewater treatment;
• Liquids from various industries such as coke plant liquids and tall oils; and
• Coatings from specified manufacturing processes.
The list of materials and the recommended number of samples of each material is
included in Appendix B.
2.2 Sampling and Analyses Procedures
The Committee recommends the use of generally accepted procedures (industry specific)
or official methods (EPA, ASTM etc.) for the collection and analysis of the fuel/waste
materials. Since the fuel mix will most likely vary for each boiler and among different boilers,
the most cost effective and best technical approach to sample collection and analysis should be
considered. This approach is necessary in order to have a consistent on-site sampling and off-
site analysis to evaluate the results. Since the physical state of the fuels will be solids, liquids
and/or gases, sampling protocols should be specific to each as well as the analysis, giving
consideration to the chemical composition of the material.
Sampling procedures should be established for the various types of materials,
considering their physical state. Where multiple fuels/waste materials are co-fired, each material
should be separately sampled whenever possible. To account for inherent variation in the
material, and save on analysis costs, multiple "samples" of the same materials could be from a
facility and then composited for analysis (rather than collect a single sample that may not be
representative). In other cases, such as gaseous fuels, a grab or an integrated sample may be the
best approach. A sampling form should be developed to record the procedures used to take
each sample, the time, the sampling location, and other relevant information.
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While on-site, the Committee recommends that the following be recorded:
• The type of plant/process;
• The origin of the fuel/waste materials;
• Known compounds or base ingredients;
• Typical mixtures combusted; and
• Any practices that are used to exclude certain materials prior to combustion.
Potential fuel analysis methods are provided as examples in Table 1. However,
depending on the material, different or customized methods may be needed. The Committee
plans to undertake a review of existing methods specific to the targeted fuels/wastes and the
most appropriate methods will be recommended. In those cases where no method exists, a
customized method may have to be developed with appropriate quality control (QC) measures
to demonstrate the accuracy of the results and the precision of the method. Such QC measures
could include matrix spikes and analysis by the method of standard additions.
For all solid and liquid fuel/waste materials, the Committee recommends that the
following analyses from Table 1 should be conducted:
• Ultimate analysis;
• Metals;
• Heat content;
• Moisture content; and
• Total organic and inorganic halogens.
The Committee recommends that the analyses in Table 1 should be conducted for
materials as appropriate depending on their physical state and composition. For example, for
some types of materials, the Committee recommends that the following be analyzed:
• Extractions for pesticides and PCBs;
• Extractions for Plastic monomers, if appropriate; and
• Various preservatives for materials such as treated wood.
Each of three sample matrices (for solids, liquids, and gasses) are briefly discussed
below, however, in Phase I only solid and liquid materials will be analyzed. See Appendix B for
more detailed information on the analyses recommended for each type of material.
Solids
The Committee recommends that solid materials be characterized as to heat content
(BTU), metals content, chloride content, ultimate analysis, moisture content, and density. If any
of the materials have been chemically treated, then additional testing is recommended to
determine qualitatively and quantitatively the specific compound(s). This could involve solvent
II- 8
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Table 1
Possible Fuel Analysis Test Method
Aniihsis
IVMi-lhori
CiuisliliK'iil
Ciiiulilions
1 IU-1 I'llilM-
(solicit S )/li(| ii i«l( I.
)/gas(G)
Ultimate
ASTM-
3176,3177,3178
Carbon, Hydrogen,
Sulfur, Nitrogen,
Oxygen, Chlorine
S, L, G
Metals in Fuel, (in
ashed sample)
ASTM D3683 (solids),
ASTM-D482 (liquid)
to ash, SW846
methods to sample
metals, e.g, ICAP
6010, 7470 (for Hg),
orNAA
As, Be, Sb, Cd,
Cr(total), Cu, Pb,
Mn„ Hg, Ni, Ag,
Zn; Probably also
Al, Fe, K, Si, Na, P,
V, calcium
S, L
Heat Content
ASTM-D240, 2015
As received basis,
dry basis and wet
basis
S, L, G
Moisture Content
ASTM D3302 (solids),
ASTM-D271, or
ASTM-095 if volatile
liquids, or water
content by Karl Fisher,
ASTM-D1774
S, L
Total Halogens
SW846, M5050,
9056 (organic)
Chlorine, Fluorine,
Bromine, Iodine
Organic and
Inorganic
S, L, G
Particle Size
D422, D293
S
Viscosity
ASTM-D455
L
Specific Gravity
ASTM-D1298
L
Bottoms, sediment,
and water
ASTM-D96, D473,
D4006
L
Organics
GC/MS methods
Organic
compounds
S, L, G
extraction following EPA Method 3050 and subsequent analysis by gas chromatography/mass
spectrometry (GC/MS). If metals are to be determined, the Committee recommends that the
sample first be digested to solubilize the metals and then the solution analyzed by standard EPA
methods. The digestion step may be accomplished by identifying a method that has been
developed specifically for this matrix. If sludges are involved, the Committee recommends that
the sample be filtered to remove the water. The two fractions (filtered solids and water) should
then be analyzed separately.
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The analysis of some types of solids may present unique situations and may need to be
addressed on an individual basis. For example, metals content could be determined using the
specialized analysis technique of neutron activation analysis (NAA). NAA requires minimal
sample preparation time and can provide detection limits that are equivalent or lower than
standard wet chemical methods for metals analysis.
Liquids
Liquid samples can be generally divided into two groups; aqueous and organic.
Different approaches to sample preparation and analysis should be considered for these two
groups. Waste organic solvents are routinely characterized for heat content and chloride
content before being combusted. The Committee recommends that compound-specific
composition be determined by dilution with an appropriate solvent and should be analyzed by
GC/MS following EPA Method 8270. In many cases, the chemical composition is known prior,
especially when a particular waste stream is generated by the facility itself. This could preclude
the need for such an analysis. Aqueous samples could be characterized for organic compounds
by preforming a liquid/liquid extraction with an appropriate solvent such as dichloromethane
(methylene chloride) followed by analysis by GC/MS. Metals content could be determined
following standard EPA methods such as Method 6010 (inductively coupled argon plasma
spectroscopy, ICAPS).
Gases
The composition of gaseous streams can vary widely in complexity. Natural gas is a
simple matrix and well characterized, whereas coke oven gas is very complex and contains,
among other things, benzene, toluene, xylenes (BTEX), napthalene, polynuclear aromatics, and
various sulfur compounds. Therefore, gas streams may need to be addressed on an individual
basis. Generally, if gases are sampled during Phase I or Phase II, the Committee recommends
that gaseous streams be sampled using an EPA sampling train consisting of a heated probe,
heated filter for the removal of particulate matter, a sorbent resin and a series of impingers
followed by a vacuum pump and a dry gas meter. To determine the composition of a gas
stream for compounds with boiling points less than approximately 130 °C, the Committee
recommends that Tenax resin be the sorbent material. For most compounds with boiling points
greater than 100 °C, the Committee recommends that XAD-2 resin be the sorbent of choice. In
both cases, after preparation, the Committee recommends that the samples be analyzed by
GC/MS. This approach allows the collection of an integrated sample over a specific time period
and concentrates specific compounds that may be otherwise too low in concentration to detect.
Another approach is to collect a grab sample in an inert bag (Teflon or Tedlar) and perform an
analysis by injecting a known volume of the sampled gas directly into a GC/MS or a gas
chromatograph equipped with a flame ionization detector (GC/FID). In this case the
compounds of interest are usually at the ppm level or higher. The grab sampling method would
not allow detection of lower concentrations. Another alternative would be analyze the gas
sample by fourier transform infrared spectroscopic (FTIR) techniques.
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3.0
PHASE I EMISSION TESTING
3.1 Purpose of Phase I Emission Testing
The purpose is to assess characteristics and emissions from combustion of nonfossil
materials where data are incomplete, and to determine the effects of co-firing these materials
with other materials for which there is likely to be sufficient data (wood or coal). The data
would be used to help determine into which subcategory co-fired units should be placed (i.e.
should they be dealt with on the basis of the primary fuel they are firing, or placed in a nonfossil
subcategory). The data could be collected at a representative unit so that it can be used to help
establish emission standards.
3.2 Background
The Committee searched the databases and other sources of available data to identify
potential emissions data gaps for boilers, and structured a proposed test plan to fill these
potential data gaps. In particular, the Committee searched the Survey Database to determine
the types of nonfossil materials combusted, and the combinations in which these nonfossil
materials are co-fired with fossil or wood primary fuels and identifying the number of boilers
combusting each nonfossil material and the number of boilers combusting each co-fired
combination. The Committee also searched the emission database and determined the amount
of HAP and Section 129 pollutant emission test data in the database for the nonfossil materials.
In addition, the Committee reviewed the list of test reports EPA has requested from ICR survey
respondents and summarized the amount of emission test data expected for each nonfossil
material and each co-fired combination.
Based on this review, the Committee believes there may be data gaps in emissions data
for HAPs of interest and Section 129 pollutants from boilers that co-fire various nonfossil
materials with primary fuels (wood or coal). The most prevalent and representative types of
nonfossil co-fired boilers for which HAP and Section 129 pollutant emission data may be
lacking are industrial sludges and tires co-fired with wood. Data on the effects on emissions of
co-firing different percentages of these materials may be lacking. Such data would determine
into which of the current subcategories co-fired boilers should be placed (i.e. classified by
primary fuel or in a nonfossil subcategory) and to characterize emissions and develop emission
standards for that will apply to nonfossil co-fired units. Emission data may also be lacking on
the effects of co-firing various percentages of wood and coal, which is a common practice.
Therefore, the recommended phase I emission test would focus on collecting data on nonfossil
materials (sludges and tires) co-fired with wood at varying percentages and on co-firing of coal
and wood at varying percentages. Additional details and rationale are provided below.
3.3 Discussion of Data. Data Gaps and Uses of Data
There may be little emissions test data on HAPs of interest and Section 129 pollutants
11-11
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for boilers firing various nonfossil materials. Version 3 of the emission database contains only
fossil fuel and wood data. While tests of nonfossil co-fired boilers are being submitted to EPA
by ICR survey respondents, several of these tests do not contain all of the section 129 pollutants
and HAPs of interest, and the nonfossil materials tend to be fired at very low percentages during
the tests. Thus, there may be data gaps on nonfossil combustion remaining after the available
test reports are collected. The Committee identified the most common nonfossil materials
combusted, and suggests focusing testing on combustion of these materials in co-fired boilers.
Virtually all of the boilers that fire nonfossil materials co-fire them with a primary fuel —
either wood or coal. The majority of boilers co-fire with wood, although some co-fire nonfossil
materials with both wood and coal or with only coal. Thus, to test a typical, representative unit
and maximize the relevance of the data collected, nonfossil material emission tests could be
conducted at a boiler that co-fires nonfossil materials with wood, or with wood and coal.
Nonfossil materials are typically co-fired at from less than 1 percent to about 20 to
30 percent on an annual basis. A relatively small number of units burn higher percents,
depending on the material (see Figure 1). A major uncertainty in developing regulations may be
how the percent co-fired influences emissions. These data may be needed to estimate emissions
and develop emission limits. The Committee also is uncertain into which subcategories to put
co-fired units. Subcategories have been initially developed based on the primary fuel. Should
nonfossil co-fired units be placed in a subcategory based on the primary fuel or dealt with as a
separate nonfossil subcategory? For example, should a boiler that fires a given percentage of
nonfossil materials with wood or coal be included in a wood or coal subcategory of in a
nonfossil subcategory? To fill these data gaps, the Committee recommends testing the nonfossil
materials most commonly fired with wood at different percentage levels.
The nonfossil materials suggested for testing are industrial sludges and tires. These are
the nonfossil materials that are combusted in the largest number of boilers, according to ICR
survey data (see Table 2). The effects of co-firing various percentages of these materials should
be generally representative of the effects of co-firing other nonfossil materials, because they
represent the range of physical states (sludges and solids) and constituents likely to be found in
other nonfossil materials. Waste oil may also be considered because it is co-fired at a relatively
large number of boilers (but usually at a very low percentage).
Similarly, there is uncertainty on how to subcategorize coal-fired boilers that co-fire
wood and on the emission characteristics of these types of boilers. To address this issue, Phase
I testing could include testing a boiler burning coal and wood at varying percentages to
determine whether emissions differ from typical coal-fired units.
To address these data gaps, the Committee recommends testing a representative boiler
co-firing nonfossil materials with wood at various percentages and burning wood with coal at
various percentages, as described in Section 3.4 through 3.6.
II- 12
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Figure 1. Frequency Distribution for Industrial Sludge Co-fired With Wood
Sludge with Wood
30
25
20
O
pq
O 15
^ 10
~ Series 1
1—1
1 1
LO
O
o
O
O
OJ
CO
LO
CD
o
LO
o
o
O
OJ
-------
Table 2
Number of Boilers in ICCR Survey Database Firing Nonfossil Materials
IntliMriiil
Slutl»e
Tires
\\ iislo Oil
I'liislic.
Co-fired w/coal
11
8
15
2
Co-fired w/wood
72
22
33
3
Co-fired w/coal
and wood
29
26
9
1
Percent-fired
range
1-60%
1-30%
1-60%
1-90%
SIC codes3
26, 24,49,28,
37,25,89
26, 49, 20, 35, 24,
81
26, 49, 24, 97,01
26, 30, 38, 28
SIC
01 -
Agriculture Production - Crops
SIC
20 -
Food & Kindred Products
SIC
24 -
Lumber & Wood Products (exc. Furniture)
SIC
25 -
Furniture & Fixtures
SIC
26 -
Paper & Allied Products
SIC
28 -
Chemicals & Allied Products
SIC
30 -
Rubber & Misc. Plastic Products
SIC
35 -
Industrial/Commercial Machinery
SIC
37 -
Transportation Equipment
SIC
38 -
Instruments, Optical Goods, Clocks
SIC
39 -
Misc. Manufacturing Industries
SIC
49 -
Electric, Gas & Sanitary Services
SIC
81 -
Legal Services
SIC
89 -
Services Not Elsewhere Classified
SIC
92 -
Justice, Public Order, Safety
SIC
97 -
National Security & International Affairs
co-fire solid non-wood, nonfossil materials including industrial sludge and tires with a primary
fuel (e.g., wood) fuels. The boiler should not burn waste off-gases during the testing.
Fuels Wastes
The Committee recommends that a co-fired unit burning industrial sludge and tires with a
primary fuel (wood) be selected. If possible, the boiler should also be able to fire coal and
possibly waste oil. Testing such a boiler would provide emissions information on commonly
fired, representative nonfossil materials.
Emission Controls
The Committee recommends that the selected boiler be tested with an emission control device
II- 14
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that may serve as a possible control option, for example a PM control device and/or a scrubber.
Preliminary MACT floors may be equivalent to emission limits achieved by boilers controlled
with PM control devices such as fabric filters or ESPs (or equivalent technology) for reducing
metal HAPs, scrubbers (or an equivalent control technology) for reducing inorganic HAP's, and
good combustion practices for reducing organic HAPs.
3.5 Recommended Matrix of Operating Conditions to he Tested
In order to address the potential data gaps identified in Section 3.3, the Committee
recommends control device inlet and outlet measurements for multiple runs with the following
conditions:
• Burning wood (the primary fuel) under representative operating conditions.
• Burning wood with sludge at three different percentages under representative operating
conditions.
• Burning wood with tires at three different percentages under representative operating
conditions.
• Burning wood with coal at three different percentages under representative operating
conditions.
• Burning wood with waste oil at one or two different percentages, if the boiler tested is able to
burn waste oil.
The Committee recommends that a boiler "expert" be on-site during all testing to monitor
operating parameters and ensure that the testing is conducted at representative conditions.
Process conditions should be monitored during the test.
3.6 Recommendations For Pollutants Measured During Testing and Test Methods
Pollutants
The Committee recommends that emissions data for Section 129 pollutants, HAPs of interest,
and criteria pollutants be collected before and after the emission control device using inlet/outlet
testing. The Section 129 pollutants that would be tested are:
• Particulate matter (PM)1
• Carbon monoxide (CO)
• Nitrogen Oxides (NOx)
• Sulfur Dioxide (S02)
• Hydrogen Chloride (HC1)
• Lead (Pb)
• Cadmium (Cd)
Methods for fine particulates are being investigated.
II- 15
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• Mercury (Hg)
• Dioxins/Furans
Based on the HAPs reasonably expected to be emitted from the fuel/waste materials being
tested, the following additional HAPs are recommended for testing:
• Additional metals (e.g., antimony, arsenic, beryllium, chromium, manganese, nickel)
• Polynuculear Aromatic Hydrocarbons (PAH)
• Polychlorinated Biphenyls (PCB)
• Benzene
• Formaldehyde
• Radionuclides (coal runs only)
The pollutants that could be analyzed using available test methods are also being considered.
If an additional pollutant could be analyzed with negligible additional costs using the same test
methods then it may be included in these test recommendations.
Diluent gas (oxygen, carbon dioxide, moisture) measurements should also be made.
Test Methods
Final test methods should be determined considering the following recommendations. The
test methods selected should yield results that are of sufficient quality to be used to help
establish emission limits for the pollutants of interest. Test methods to be considered include:
Method 23: Dioxins/furans, PAHs, PCBs
Method 29: Metals
Method 5: Particulate Matter1
Method 114: Radionuclides (coal runs only)
FTIR and/or other Benzene, Formaldehyde, NOx, CO, S02, HC1
methods
4.0 PRIORITIZATION
The Committee has designed this recommended Test Plan to give priority to obtaining
additional emission information addressing potential data gaps and providing information for
prioritizing and minimizing recommendations for Phase II stack testing.
Methods for fine particulates are being investigated.
II- 16
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5.0 ESTIMATED COSTS
Appendix D contains information on the estimated costs of the recommended Phase I test
program. The fuel/waste analyses portion would cost approximately $183,000 to $221,000.
The emissions testing portion would cost approximately $820,000 to 1,070,000, based on input
from the Testing and Monitoring Protocol Work Group.
6.0 SUMMARY OF PROPOSED PHASE I EMISSION TEST
Boiler Subcategory:
Boiler to be Tested:
Nonfossil materials cofired with primary fuel
Stoker, million Btu/hr, probably in timber
products industry
Fuel:
Sludge, tires, and wood (primary fuel). Also possibly
capable of firing coal and waste oil
Control Device:
? (probably ESP and/or scrubber)
Pollutants to be Measured:
Criteria Pollutants:
NCL CO, PM1, S09
Hazardous Air Pollutants
(including Section 129 HAPs):
Test Methods to be Used:
Method 23:
Method 29:
Method 5:
Benzene, formaldehyde, PAH, PCB, dioxins/furans, HC1,
radionuclides during coal runs. Metals: including
antimony, arsenic, beryllium, cadmium, chromium, lead,
manganese, mercury, nickel
(Note: If other HAPs are obtained using the same test
methods at little additional cost, also measure these, e.g.
BTEX, other aldehydes)
Dioxins/furans, PAH, PCB
Metals
PM1
Methods for fine particulates are being investigated.
II- 17
-------
Method 114:
Radionuclides (coal runs only)
FTIR and/or other Benzene, Formaldehyde, NOx, CO, S02, HC1
methods:
Operating Conditions:
Burning wood under representative operating conditions, control device inlet and outlet.
Burning wood and sludge at 3 different percentages under representative operating
conditions, control device inlet and outlet.
Burning wood and tires at 3 different percentages under representative operating
conditions, control device inlet and outlet.
Burning wood and waste oil at a low percentage, control device inlet and outlet (if the
boiler tested is able to burn waste oil)
Burning wood and coal at 3 different percentages, under representative operating
conditions, control device inlet and outlet.
II- 18
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APPENDIX A
Boiler Test Plan Strategy
Data Gap
LU
(/)
<
I
CL
(f)
(/)
C, H, 0, N, S
>-
_l
CI, F, Br
<
H20
<
Metals
_l
LU
Ash
3
Btu
LL
BOILER TEST
1 Large #, Little or No
Subcategories
Fossil
Non-Fossil
Wood
Qualitative
Evaluation of Control
Techniques
Characterization of
Similar Fuels
Reduce Size of
"Other" Subcategory
Refine Non-Fossil
HAPs List
T
MACT
FLOOR
*•>
to
1-
Parametric
CM
Testing
LU
(/)
(/)
c
<
o
I
<0
Control
CL
t/J
'E
Technique
c
LU
Performance
Select
MACT
Model
Plants
Regulation
Fill Remaining
Gaps
Emission Factors
HAPs of Concern
Control
Technique
Effect on Criteria
Pollutants vs.
HAPs
II- 19
-------
APPENDIX B
Table B-l Nonfossil Materials Which May Be Lacking Data and Suggested Number of Samples
Miilcriiil
lioilors ( oniluj^inii
MiiU-riiil'
SIC
codes
I'lilllls In
Siiilipk'1'
(omiiK-nls
1. Coke plant liquids
>7
33
3
2. Tall oils and turpentines
10
28, 26
3
Fuel analysis for one facility sent with survey.
3. Waste activated biological
sludge from brewery wastes
2
49
1
4. Wastewater treatment
sludges
89
24, 26,
28, 37,
49, 89
6
Analyze 3 from SIC 28 and 3 from SIC 37. Analyses for other
SIC (e.g., SIC 24 and 26) were attached to ICR surveys, or there
are very few facilities (e.g., SIC 89).
5. Waste paper from printing
(e.g, with inks)
>7
24, 27,
26
3
6a. Rice hulls
c
20, 28
3
Sample from various geographic locations.
6b. Shells (peanut, almond,
walnut)
c
01
3-6
Sample various materials and geographic locations.
6c. Corn stalks
c
28, 20
3
Sample from various geographic locations.
7. Mil-spec coatings
d
4
Sample at 2 aerospace and 2 military transport facilities.
8. Automotive body coatings
d
2
Sample 2 automobile coating facilities
aBased on survey database responses. Actual number may be higher, because some fuel/waste descriptions overlapped, were unclear, or unavailable.
bThe number of plants to collect material samples from was selected as follows. A minimum of 3 plants to allow statistical evaluation and account for variation
among sites. If the material is combusted by plants in multiple SIC codes and the characteristics of the material are likely to vary at least one plant per SIC code.
cSome surveys that indicated agricultural materials did not provide a description, so the number of boilers burning each type is not available.
dNot available.
11-20
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APPENDIX C
Fuel/Waste Sampling and Analysis Methods
C1.0 INTRODUCTION
The Industrial Combustion Coordinated Rulemaking (ICCR) Coordinating Committee
recommends a two phase program to characterize HAPs emissions from industrial, commercial,
and institutional boilers. The boilers combust fuels/wastes having a wide variety of physical and
chemical properties. These fuels/wastes include national gas, refinery fuel gas, other industrial
gases, fuel oils, coal, tire derived fuels, process engineered fuels, paper, plastics, industrial
sludges, bagasse, other agricultural materials, wood, and wood products. The Phase I test
program would include fuel/waste sampling and analyses to screen several nonfossil materials
for which fuel/waste analyses data may be lacking. The results of these fuel/waste analyses
could be used to group materials with similar characteristics, identify materials of particular
concern, and thereby prioritize Phase II emission testing. This document suggests guidelines for
sampling and analyzing fuels/wastes fired in industrial, commercial and institutional boilers. The
objective of this document is to introduce the reader to basic fuel/waste sampling and analytical
strategies and procedures and provide references for more specific test methods as the
fuels/wastes and sources to be characterized are determined. This document does not attempt
to provide the reader with specific sampling and analytical strategies for every type of fuel/waste
stream that may be encountered.
Many of the fuels/wastes under consideration are not homogenous and an understanding
of the fuel/waste properties and processing could be required to develop protocols for collection
of a representative sample. For many of the fuels/wastes to be characterized during this program
it is likely that information from industry experts and fuel/waste sampling site representatives
could be needed to develop a site-specific Test Protocol. Therefore this document first presents
guidelines on what types of information might be collected and considered prior to collecting
samples for a fuel/waste characterization program (Section C2). Section C2 also includes a
discussion of procedures for collecting fuel/waste samples. Analytical procedures are presented
in Section C3.
C2.0 SAMPLE COLLECTION
C2.1 Definitions
The following terms are used to generally characterized fuel/waste streams:
Representative sample - sample that exhibits the average properties of the whole stream.
Homogeneous fuel/waste - uniform composition throughout the fuel/waste. Any sample
of the fuel/waste would be a representative sample.
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Heterogeneous fuel/waste - the fuel/waste is not consistent in composition. There is
variation between samples so a single sample of a size suitable for analysis is not representative
of the property of concern.
Random heterogeneity - fuel/waste constituents are randomly distributed throughout the
fuel/waste with respect to space and time.
Non-random Tor stratified^) heterogeneity - fuel/waste heterogeneity varies over space or
time. Each strata has its own constituent concentration distribution and mean concentration
levels.
Random sampling - a sampling strategy where every unit in the population has a
theoretically equal chance of being sampled.
Composite Sampling - In composite sampling, a number of individually collected
samples are combined into a single sample for analysis.
Segregation - fuel/waste is separated into groups with similar physical or chemical
properties prior to sample collection or analysis.
Homogenization - to process the fuel/waste components into more similar physical or
chemical forms through grinding, blending, etc.
C2.2 Overview of Sampling Strategies
Most sampling and analytical guidance documents and methods that have been
developed by EPA and ASTM are for fossil fuel and hazardous waste characterization.
Guidance documents and test methods for fossil fuels provide a starting point for developing
Test Protocols for homogeneous fuels/wastes while guidance documents and test methods for
hazardous waste are a starting point for non-homogeneous fuels/wastes.
C2.2.1 Pre-Sampling Planning
EPA SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,
(chapter nine) discusses considerations important in development of a fuel/waste
characterization plan. A sampling plan should start with a clear, concise outline of the
regulatory and scientific objectives of the program. Data quality objectives (DQO) should be
developed by and agreed to by all program decision makers. Establishment of DQOs is
especially critical for development of a sampling plan for non-homogeneous fuels/wastes.
Defining the DQOs also serves to force the thought and communication between decision
makers and other participants to develop a sampling and analysis plan for non-homogeneous
fuels/wastes.
Data quality objectives that should be addressed include:
11-22
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• Confidence Interval
• Precision
• Accuracy
• Detection Limits
The first goal of the sampling plan is the collection of a representative sample. The
confidence interval indicates the degree of confidence that the sample collected is representative
of the fuel/waste. Calculation of confidence intervals is described in Chapter 9 of EPA SW-
846. A second goal of the sampling plan is assurance that a sufficient number of samples
would be collected over a period of time to quantify the variability of the fuel/waste over time.
Detection limits should be sufficiently low to detect levels of concern (e.g. health risk or
regulatory limits).
C2.2.2 Sampling Strategy
Several sampling strategies are available for obtaining representative samples with
homogenous or random heterogeneous fuels/wastes. Selection of the proper strategy could
require some knowledge of fuel/waste characteristics through process knowledge, previous
sampling data, or analysis of pre-screening samples. The same methods may be utilized for
more excessively stratified heterogeneous fuels/wastes but the statistical uncertainty and number
of samples that may be required may increase. The sampling strategies discussed in SW-846 are
outlined in Table C2-1. This table contains a brief description, applicability, and the advantages
and disadvantage of each sampling strategy or technique. In general, for a homogeneous
fuel/waste, one sample is adequate to characterize the fuel/waste. A total of three samples are
often collected to determine the sampling and analytical precision. Some form of random
sampling may be required to collect a representative sample of a non-homogenous
(heterogeneous) fuels/wastes. With random sampling, every unit in a population (e.g., every
location in a drum of fuel/waste) has an equal chance of being selected. Simple random
sampling includes division of the population (or fuel/waste) by an imaginary grid, assignment of
a sequential numbers to each division or location, and selection of sample locations through use
of a random-numbers table. A random numbers table is used to prevent bias in selection of
sample locations. Guidance on how to use a random number table for fuel/waste sampling is
can be found in EPA's "Drum Handling Practices at Hazardous Waste Sites" (EPA, 1986).
For a fuel/waste that is known to be non-randomly (stratified) heterogeneous in it's
chemical or physical properties, stratified random sampling may be appropriate. With
stratified random sampling, simple random sampling is applied to the various non-random strata
of the fuel/waste. This sample collection method may require knowledge of the extent and
areas of stratification in the fuel/waste. Specific data for each stratum would not be collected.
The samples collected during random sampling can either be analyzed individually or as a
composited sample. Composite sampling is utilized when an average or normalized value is
required. The advantage of composite sampling is reduced analytical cost. The disadvantage is
lose of information regarding the range of values in the fuel/waste.
11-23
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Systematic random sampling is another probability type of probability sampling. With
systematic sampling, the first sample unit to be sampled from a population is randomly selected
but all subsequent samples are collected at fixed space or time intervals. The disadvantage of
this sampling is collection of non-representative samples when cycles or changes in trends occur
in the population. The advantage is convenience.
Authoritative sampling is a non-statistical sample collection method based on detailed
knowledge of the fuel/waste. Authoritative sampling is not normally utilized since it is more
prone to bias in specification of sample locations and frequency and the validity of the data
cannot always be proven or quantified. Further information on statistical methods and examples
of probability sampling techniques can be found in EPA's SW-846, Chapter Nine (EPA, 1992).
Development of a fuel/waste characterization plan is more difficult for excessively
stratified heterogeneous fuels/wastes. Characterization of these excessively stratified
heterogenous fuels/wastes presents a number of special problems including:
• It is difficult (or impossible) to accurately and precisely characterize the population. In
general, a greater number of samples will have to be collected relative to a homogenous
fuel/waste to achieve a given level of certainty. The number of samples required can
become quite extensive.
• Customary sample segregation, compositing, and homogenization schemes may not be
appropriate or acceptable.
• Utilizing standard sampling methodology, collection of a representative sample of a
fuel/waste with particles of varied physical sizes greater than one centimeter may
require collection of tens or hundred of pounds of material.
• Reduction of large sample volumes to tiny homogeneous aliquot required for analysis
may be difficult.
• Quantification of "hot spots" (localized contamination) is difficult / impossible without
very extensive statistical sampling.
A discussion of statistical sampling strategies for these excessively stratified wastes is
contained in references 5 and 6.
C2.2.3 Number of Samples
The number of samples collected depends on the available resources, the desired degree
of confidence, and the objective(s) of the characterization activity. EPA's "A Rationale for the
Assessment of Errors in the Sampling of Soils" (EPA, 1990) provides tables and a discussion
for the number of samples that are required to obtain a certain level of confidence when the data
11-24
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are normally distributed or can be transformed to a normal distribution (random heterogeneous).
It has been recommended that this guidance is also applicable to heterogeneous waste
("Characterizing Heterogeneous Wastes: Methods and Recommendations" (EPA, 1992)). If
historical data indicates that inaccuracy or variability is increased in the preparation and handling
of a sample, and this affects detrimentally the required accuracy, then more frequent sampling
may be justified. If the fuel/waste to be sampled is containerized, the EPA-approved ASTM
method D 140-70 for estimating the number of containers to sample should be consulted(4).
EPA's "Waste Analysis Guidance for Facilities that Burn Hazardous Waste" (EPA, 1994)
provides guidance on sample location for various situations(3).
C2.2.4 Information Requirements for Specification of a Sampling Strategy
Table C2-2 contains questions and information requirements that typically are addressed
prior to selecting and detailing a sample collection strategy.
C2.2.5 Sampling Methods/Techniques
This section contains an overview of sampling techniques for liquid, solids and gases.
Liquids
The EPA and ASTM have developed sampling methods for liquids, including those for
either containerized (drum, tank, or pond) or free flowing. A mixer may be required for liquids
with immiscible liquid and solid phases. Sampling methods include:
• Tap Sampling (ASTM D4057-9.3) - Good for free flowing liquids.
• Coliwasa ^Composite Liquid Fuel Sampler) (ASTM D 4057-9.6) - Used for sampling of
liquids in drums, pits, tanks, or similar containers. It is not appropriate for high viscosity
fluids.
• Dipper (Dip Sampler) (ASTM D 4057-9.5) - Used for grab samples.
• Weighted Bottle (ASTM 4057-9.7) - Not good for high viscosity liquids.
• Glass Open Tube
• Manual pumping fPeristalics. bellows. Diaphragm, or Siphon)
Solids and Viscous Liquids
Sampling method have also been developed for viscous liquids, slurries, sludges, and
11-25
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solids. Standard EPA sampling methods for solids as outlined in Chapter 9 of EPA SW-846
include:
• Thief Grain Sampler" or Punchy - Used for sampling of dry powder or granular
materials. Not for sticky materials or particles greater than 0.25 inch.
• Trier or Corer - Used for depth sampling of sludge or moist, sticky solids. It is not
appropriate for coarse or granular material.
• Trowel, scoop, or spoon - Used for surface sampling of moist or dry solids.
• Auger (Helical or Spiral) - Effective for depth sampling of packed solids. It produces a
disrupted sample.
ASTM sampling methods include:
• ASTM D-140 — For sampling viscous liquids.
• ASTM D-346 — For sampling crushed or powdered solids.
• ASTM D-420 — For sampling soil or rock-like material.
• ASTM D-1452 — For sampling soil-like material.
• ASTM D-2234 — For sampling fly ash-like material.
Gases
• Tedlar Bag
C3.0 ANALYTICAL METHODOLOGY
Analytical methodologies are listed in Tables C3-1 and C3-2. Other analytical methods
may also be applicable. Test methods have not been specifically developed for every type of
fuel/waste and required measurement. Therefore, it is anticipated that a test method developed
for a specific fuel/waste may be applicable to other fuels/wastes having similar characteristics.
For example, test methods for coal are expected to be applicable to other solid fuels/wastes.
However, analytical labs could be consulted prior to applying test methods to fuels/wastes for
which the test method was not specifically developed.
C4.0 REFERENCES
1. EPA, "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,"
11-26
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SW-846, 4th Edition, 1992.
2. U.S.EPA OSWER, "Waste Analysis at Facilities That Generate, Treat, Store,
and Dispose of Hazardous Waste: A Guidance Manual," OSWER 9938.4-03,
PB94-963603, April 1994.
3. U.S.EPA, "Waste Analysis Guidance for Facilities that Burn Hazardous Wastes
Draft," EPA Enforcement and Compliance Assurance (2224A), EPA 530-R-94-
019, October 1994.
4. ASTM (American Society for Testing and Materials, "1994 Annual Bood of
ASTM Standards," Philadelphia, PA, Annual Series, 1994.
5. U.S. EPA (United States Environmental Protection Agency), Rupp, G., and R.R.
Jones, (editors), "Characterizing Heterogeneous Wastes: Methods and
Recommendations," EPA/600/R-92/033 (NTIS No. PB92-216894), US EPA
Office of Research and Development and U.S. Department of Energy, February
1992b.
6. Maney, J.P., "Characterizing Heterogeneous Materials," in "Environmental
Monitoring Issues: Results of Workshops Held in July 1992 as Part of EPA's
Eighth Annual Waste Testing and Quality Assurance Symposium," D. Friedman
(editor), U.S. EPA Office of Modeling, Monitoring Systems and QA, and
U.S. EPA Office of Solid Waste, EPA/600/R-93/033 (NTIS No. PB93-216075),
March 1993.
7. DOE, "Preparation of Waste Analysis Plans Under the Resource Conservation
and Recovery Act (Interim Guidance)," DOE/EH—0306, March 1993.
11-27
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TABLE C2-1. OVERVIEW OF MAJOR SAMPLING APPROACHES AND TYPES
Siini|)lin<>
Di'llnilion
Applii'iihiliU
Random (Simple Stratified
Systematic)
Techniques where sample
selection and location are
determined through the
application of statistical
methods.
Used to collect representative
samples where data is insufficient
to justify authoritative sampling
(e.g., streams of unknown or
variable concentration).
See discussions below for each respective random
sampling technique.
• Simple Random
All locations/points in a
stream or unit from which a
sample can be attained are
identified, and a suitable
number of samples are
randomly selected.
Used to collect representative
samples of streams that are
heterogeneous throughout the
entire stream or unit (e.g.,
multiple drums of unknown
origin).
Advantages: Most appropriate with little or no
information is available concerning the distribution
of chemical contaminants.
Disadvantages: Mav misrepresent streams with
areas of high concentration or stratification.
• Stratified Random
Areas of non-uniform
properties or concentrations
are identified and stratified
(segregated).
Subsequently, simple
random samples are
collected from each stratum
of the fuel or unit.
Used to collect representative
samples from streams or units
that are known to have areas of
non-uniform properties (strata) or
concentration (hot spots) (e.g.,
surface impoundment with
multiple layers).
Advantages: Provides for increased accuracy of fuel
representation if strata or a typically high or low
concentration area is present.
Disadvantages: Requires greater knowledge of fuel
than for simple random sampling and may require
sophisticated statistical applications.
• Systematic Random
The first sampling point is
randomly selected but all
subsequent samples are
collected at fixed space
intervals (e.g., along a
transect or time intervals).
An alternate procedure used to
collect representative samples
from modestly heterogeneous
streams that provides for
simplified sample identification.
Advantages: Provides for easier sample
identification and collection than other techniques.
Disadvantages: Mav require larger number of
samples than compositing to obtain representative
sample.
Authoritative
Technique where sample
locations are selected based
on detailed knowledge of
the stream without regard to
randomization
Streams of known
physical/chemical properties and
concentrations.
Requires in-depth knowledge of properties and
constituents of streams. Rationale for sample
selection must be well documented and defensible.
11-28
-------
TABLE C2-1. OVERVIEW OF MAJOR SAMPLING APPROACHES AND TYPES (Continued)
Siini|)lin<>
Di'llnilion
Applii'iihiliU
Ath i's/l)isii(h
Grab
A sample taken from a
particular location at a
distinct point in time.
Most common type used for
random sampling. Useful in
determining fuels variability (e.g.,
range of concentration) when
multiple or frequent samples are
obtained.
Advantages: Simplest technique, best measure of
variability.
Disadvantages: Mav require larger number of
samples than compositing to obtain representative
sample.
Composite
A number of individually
collected samples that are
combined into a single
sample for subsequent
analysis.
Used where average or
normalized concentration
estimates of a fuels constituents
are desired.
Advantages: Reduces analytical costs. Mav reduce
the number of samples needed to gain accurate
representation of a stream.
Disadvantage: Onlv provides the average
concentrations of a stream (i.e., information about
concentration range is lost).
11-29
-------
TABLE C2-2. TYPICAL INFORMATION COLLECTED AND QUESTIONS
ANSWERED PRIOR TO SELECTING A SAMPLING STRATEGY
Process Data and Historical Sampling Data
• Physical characteristics (size distribution, hardness, viscosity, density, specific gravity, etc.) and composition (base ingredient
or known compounds) or trace constituents.
• Description and schematic of the fuel storage, processing and feed systems. Batch, containerized, continuous, etc.
• Sampling and analytical methods previously used for characterization.
Fuel Characteristics
• Does available historical data provide a good understanding of the fuel properties and the homogeneity of the fuel?
• Number of total fuel streams. Can all streams be characterized at the same time?
• Are there multiple components to each fuel? If so, are the components miscible? Are the components well mixed?
• Is the fuel mixed with another fuel prior to combustion?
• Is the fuel particle size stratified? In time? In Space? By source?
• Is the fuel composition stratified? In time? In space? By source?
• Can the stratification be eliminated?
• Is the fuel milled, sorted, segregated, homogenized, or otherwise processed prior to combustion?
• Can the fuel be segregated by type? By size? By composition?
• If the fuel contains a contaminant of interest (metals, halogens, etc.), is the compound distributed throughout the fuel?
• What is the expected range of variability?
• Does the fuel contain toxic or hazardous constituents
Sample Location
• Is all of the fuel easily accessible?
• Are there obvious sample locations within the fuel storage, processing, and feed systems?
• Size of available sample ports
• Size of available sample ports
11-30
-------
TABLE C3-1. ANALYTICAL METHODS FOR FUELS
Mciisu mncnl
Applicable
PiTpumlion
Method
Pri'piiriilion
I'mccdurc
Ansihliciil Modioli (2)
AiiiiMiciil
Principle
Mi'lhnri
ColllllH-lllS
Ultimate Analysis
S,1
ASTM D 3176 (A)
- Carbon & Hydrogen
D 2013
may include:
D-3178(A), E 777(B,C)
comb. & absorption
- Sulfur
D 2013
drying
D 3177(A), E775 (B,C)
eschka or bomb washing
- Oxygen
D 2013
crushing
by difference
difference
- Ash content
D 2013
division
D 3174(A),
D1102(B,C)
Controlled combustion
- Moisture
D 2013
or mixing
D 3173(A), E871(B,C)
drying
D95 may be
more
appropriate
Heat Content (solid fuels - as
received, wet and dry basis)
s
D 2013
as above
D2015 (A), E711 (B,C)
calorimetry
(liquid petroleum fuels)
1
none
none
ASTM D 240
calorimetry
Fuel Gas Analysis
- Composition
g
none
none
D1945 (NG), D1946
(reformed gas), D2163
(LPG)
GC
- Heating Value
s
none
none
ASTM D 3588
compositional analysis
- Relative Density
s
none
none
ASTM D 3588
compositional analysis
- Compressibility Factor
s
none
none
ASTM D 3588
compositional analysis
Viscosity
1
none
none
ASTM D445
viscometer
Specific Gravity
1
none
none
ASTM D1298
hydrometer
Bottoms, Sediment, and
Water (BS&W)
1
none
none
ASTM D96
centrifuge
rough method
11-31
-------
TABLE C3-1. ANALYTICAL METHODS FOR FUELS (Continued)
Mciisu mncnl
Applicable
PiTpumlion
Method
PiTpumlion
I'mccdurc
Ansihliciil Modioli (2)
AiiiiMiciil
Principle
Mi'lhnri
(olllllK-lllS
ASTM D473
solvent extraction
more accurate
methods
ASTM D4006
distillation
Particle Size Distribution
1
none
none
D 422 (A)
Sieve Analysis
Total Organic Halogens (CI,
Fl, Br, I)
SW-846
M5050
bomb
combustion
SW-846 M9056
Pesticides and PCBs
(2) Listed ASTM E methods were developed for refuse derived fuel (RDF) or wood fuel and are listed as applicable to both. The RDF methods are similar to the
coal methods.
• Method was developed for or is listed for the following fuels (but can be applied to other fuels):
A - coal and coke, B- refuse derived fuel (RDF), C - wood and wood waste, D - solid waste and petroleum products.
(3) Cost are for estimate purposes only and will change based on lab used, matrix analyzed, number of samples analyzed, etc.
(4) Method detection limit may vary depending on sample matrix
Applicable to: s - solid fuels, 1 - liquid fuels, g - gaseous fuels.
11-32
-------
TABLE C3-2. SAMPLE PREPARATION AND ANALYTICAL
METHODS FOR FUELS: METALS ANALYSIS
I'iM'iiim-U-r
IC I'-AKS
FAAS
(.1 AAS
Aiisih liiiil
MciIkkI
Ansil. DL
(mii 1) (2)
Ansih liiiil
Mrlhinl
Aiiiil. 1)1.
(ini: 1) (2)
Aiiiih liiiil
Mrlhcul
Aiiiil. 1)1. (m» 1) (2)
Metals
-As
6010
0.1
7061
0.005
7060
0.01
-Be
6010
0.001
7090
0.005
7091
0.01
-Sb
6010
0.05
7040
0.5
7041
0.01
-Cd
6010
0.01
7130
0.01
7131
0.001
- Cr (total)
6010
0.01
7190
0.04
7191
0.005
-Cu
6010
0.02
7210
0.04
7211
0.005
-Pb
6010
0.05
7420
0.05
7421
0.003
-Mg
6010
0.01
7450
1
-Hg
7470/7471 (3)
0.005
-Ni
6010
0.02
7520
0.05
7521
(4)
-Mn
6010
0.01
7460
0.04
7461
(4)
- Se
6010
0.1
7740
0.005
-Ag
6010
0.01
7760
0.01
7761
0.0005
- Zn
6010
0.02
7950
0.04
7951
(4)
- A1
6010
0.02
7020
0.2
-Fe
6010
0.1
7380
0.04
7381
(4)
-K
6010
1
7610
1
-Na
6010
0.03
7770
1
ICP-AES: Inductively Coupled Plasma - Atomic Emission Spectroscopy
FAAS: Flame Atomic Adsorption Spectroscopy
GFAAS: Graphite Furnace Atomic Absorption Spectroscopy
PnU'iiiiiil Pivpiii iiliiiii
Mrlhinlv (?)
IVoiTlllllV
A|>|>IU';il>k' Muli iirv
Aiiiih lii ;il liMi umrnl
ASTM E 926-88
various (6)
RDF
AA,GFAA, ICP
ASTM D 3683-78 (7)
ashing/acid digestion
coal
AA
ASTM D 3684-94
Bomb Comb (8)
coal
AA
EPA SW-846 Method
3052
Mcrowave assisted
AD
ashes, oils, sediments, sludges, soils
AA, GFAA, CVAA, ICP
EPA Method 200.2
Acid Digestion
water/soils
AA, GFAA, ICP
EPA SW-846 Method
3050B
Acid Digestion
Sediments, Sludges, Soils
AA, GFAA, ICP
EPA SW-846 Method
Acid Digestion
Oils and other viscous petroleum
AA, GFAAJCP
(2) Analytical Detection Limit
(3) Cold Vapor AA
(4) Lab contacted does not utilize this method for these metals.
(5) These are just a few of the numerous preparation techniques for metals analysis.
(6) Includes both high and low temperature methods of oxidation along with acid digestion.
(7) This is actually an analytical method (AA) but includes the sample preparation methodology.
(8) This is the ASTM cold vapor AA method. It includes a prep method of bomb combustion and a dilute nitric acid to absorb the
Hg.
11-33
-------
Appendix D
Estimated Costs to Conduct Phase I Testing
D.1.0 INTRODUCTION
This appendix presents cost estimates for the Phase I fuel analysis and emission test
program. These cost estimates are intended to provide a general cost range. Once the exact
number and type of fuel/waste samples and locations (plants) and an emission testing site are
selected and protocols are refined, more refined cost estimates can be developed.
D.2.0 FUEL/WASTE SAMPLING AND ANALYSIS COSTS
Phase I fuel/waste sampling and analysis costs will vary depending on:
• The number of fuel/waste materials sampled;
• The number of samples per material;
• The number of plants from which samples are collected and their locations;
• Physical state of the material and sampling method;
• Types of chemical analyses conducted, and
• Complexity of sample preparation portion of the analyses, which depends on characteristics
of the material.
Approximate costs have been calculated based on:
• The number of solid and liquid fuel/waste materials and number of plants to sample specified
in Appendix B;
• The types of analyses specified in Section 2.0 of the Test Plan and Appendix C; and
• The assumption that for a given fuel/waste material at a given plant, 3 samples will typically
be collected and analyzed.
As discussed in the text, once fuel/waste materials and plant site selections are final, more
detailed site-specific sampling and analysis protocols should be developed, and cost estimates
can be refined.
Total costs for Phase I fuel/waste sampling and analysis are estimated to range from
approximately $183,000 to $221,000. Tables D2-1 through D2-4 present calculations of these
costs. Table D2-1 shows costs to develop site/material-specific protocols, collect samples, and
prepare reports. Table D2-2 presents analysis costs for solid/sludge materials. Table D2-3
presents analysis costs for liquid materials. Data reduction and QA costs are included in the
analysis costs. Adding the totals from Tables D2-1, D2-2 and D2-3 result in a total cost range
of $183,000 to $221,000.
11-34
-------
D.3.0 EMISSION TESTING COSTS
The costs of the emission test are estimated to be $820,000 to $1,070,000. This is a rough
estimate. A breakout of these costs, by task is shown in Table D3-1. The cost estimate is based
on control device inlet and outlet measurements for 10 test conditions, with 3 test runs for each
condition as follows:
• Burning wood.
• Burning wood and sludge at 3 different percentages.
• Burning wood and tires at 3 different percentages.
• Burning wood and coal at 3 different percentages.
Additional assumptions include:
• Method 5 for PM; Method 29 for metals; Method 23 for dioxins/furans, PAH, and PCB;
FTIR with full QA/QC for benzene, formaldehyde, NOx, CO, SO2, and HC1. If EPA CEM
methods were used for some of these pollutants, costs would increase because additional
staff and protocol gases would be needed.
• 10 people on site for 44 days straight. One six-hour test per day with 1 day between
conditions for process to line out. This day in between will also be used to prepare sampling
equipment for the next condition as well as perform FTIR validation for the next condition.
(Note: If a 4-hour test run is sufficient for dioxin/furan given the desired detection limits, it
would be possible to conduct two runs on some days, reducing the number of days on site
and the test costs).
• An estimate of 80 sampling train samples of each type (including blanks) to be collected.
• Fed-X shipments of samples from field to lab each day.
• No contingency days built into cost.
• Upper end of range calculated by adding 30 percent to cost.
It is uncertain that a test site able to burn all four of the materials at the desired percentages
will be located. If such a site cannot be located, the number of tests may be reduced.
Alternatively, if a site can be found that co-fires waste oil in addition to the listed materials, 1 or
2 additional tests co-firing waste oil may be added. A detailed estimate can be made after a
specific test site is selected, the exact number of test runs is defined, and the test methods and
detection limits are determined.
11-35
-------
Table D2-1. Management, Protocol Development,
Travel, Sampling, and Reporting Costs
Ke iil°
cost per
site
Number
of Sites"
Ke lor Tol.il
Cost
1. Management, contact site, arrange visit, develop
site/material-specific sampling protocol.
$640-960b
23
$14,720 - $22,080
2. Travel to 15 sites by car, prepare test equipment,
collect samples (average of 1.5 materials per site,
3 samples of each material).
$1,000°
15
$15,000
3. Travel to city by air, visit 4 plants in same area,
collect an average of 1.5 materials per site,
3 samples of each material ($2,530 for first site,
$1,000 for 3 additional sites = $5,530 for 4 sites).4
$5,530
2
$11,060
4. Generate report for each site to document materials
sampled, sampling procedure, sampling log forms,
analysis procedures, analysis results. Send copy to
site.6
$480b
23
$11,040
TOTAL
$51,820 -$59,180
^Assume collect samples from 23 plants. Appendix B indicates that samples of various solid and liquid
fuel/waste materials would be collected from a maximum of 34 plants, but most of the fuels/waste are cofired.
Assume collect an average of 1.5 fuel/waste materials of interest per plant, so 23 are visited rather than
34 plants. Assume 15 plants are within driving distance of the EPA sampling contractor. Assume the other 8 are
located in 2 different cities/areas requiring air travel. Contractor could fly to the city for 1 week and drive to
collect samples from 4 plants in that area.
bTaken from Table D-4, items 2 and 4.
Tor plants within driving distance, used the low end of the range on Table D-4, item 3 ($820) and added $180
(3 labor hours) to collect 3 samples of a second material at the same plant, for a total of $1,000.
d$2,530 is the upper end of the range on Table D-4, item 3 ($2,350) plus $180 to collect 3 samples of a second
material at the same site. This cost includes air fare. The $1,000 represents the costs for each additional plant
within driving distance (see footnote c).
eData reduction costs are included in the analysis costs in tables D-2 and D-3 rather than under reporting costs.
11-36
-------
Table D2-2. Solid and Sludge Analysis Costs
Tjpe ol Analysis
Analysis Cost Kan<>e
lor 3 Samples of
Same Material from
a Single Plant (S)1
Number of 3-
sel Solid
Material
Samples
Kan<>e lor Total
Costs (S)
Ultimate analysis
448 - 523b
28c
12,544 - 14,644
Heat content
155 - 176
28
4,340 - 4,928
Particle size distribution analysis
249-291
28
6,972 - 8,148
Total organic halogens
600 - 720
28
16,800-20,160
Metals
736 - 912d
28
20,608 - 25,536
Mercury
142- 169
28
3,976 - 4,732
Pesticides or PCBs
513 -627e
15f
7,695 - 9,405
Semi-volatile organics by Method 8270
1,020- 1,6208
10f
10,200 - 16,200
Dioxin/furan by high resolution GC/MS
2,700 - 3,300h
6f
16,200- 19,800
Total Cost for all Analyses
99,335 - 123,553
aCost are taken from Table D-4 unless otherwise noted. Labor hour costs for data reduction and review are
included in these analyses costs rather than under reporting on Table D-1.
bAdded $50 to the ultimate analysis costs shown in Table D-4 to add N and CI analysis.
cAppendix B shows that samples of the various solid and sludge fuel/waste materials would be collected from a
maximum of 28 plants.
dThe low end of the range is taken from Table D-4, ICPAES method for all metals. The high end represents the cost
of NAA (based on telecon with NC State University) including a full QA/QC package. (ICPAES could also cost
over $900 for materials that require complex sample preparation).
eAnalysis cost of $150 per sample x 3 samples = $450 plus $120 (2 hours) for data reduction = $570. Assumed
+ 10% to create range.
fAssume these additional organics analyses are done for a subset of the samples, depending on the type of fuel/waste
being analyzed.
8Analysis costs range from $300 to $500 per sample x 3 samples = $900 to $1,500. Added $120 (2 hours) for data
reduction, for a total of $1,020 to $1,620.
hCosts are approximately $1,000 per sample, or $3,000 for 3 samples, + 10%.
11-37
-------
Table D2-3. Liquids Analysis Costs
Tjpe ol Analysis
Analysis Cost Kan<>e
lor 3 Samples of
Same Material from
a Single Plant (S)1
Number of 3-
sel l.i(|iiid
Material
Samples
Kan<>e lor Total
Costs (S)
Ultimate analysis
448 - 523b
6C
2,688 - 3,138
Heat content
155 - 176
6
930 - 1,056
Viscosity
141 - 159
6
856 - 954
Specific gravity
128- 143
6
768 - 858
Bottom, sediment and water
303 - 357d
6
1,818-2,142
Total organic halogens
600 - 720
6
3,600 - 4,320
Metals
736 - 912d
6
4,416 - 5,472
PCBs
513 -627e
4f
2,052 - 2,508
Semi-volatile organics by Method 8270
1,053 - 1,2878
6f
6,318-7,722
Dioxin/furan by high resolution GC/MS
2,700 - 3,300h
3f
8,100 - 9,900
Total Cost for all Analyses
31,536 - 38,070
aCost are taken from Table D-4 unless otherwise noted. Labor hour costs for data reduction and review are
included in these analyses costs rather than under reporting on Table D-1.
bAdded $50 to the ultimate analysis costs shown in Table D-4 to add N and CI analysis.
cAppendix B shows that samples of the various liquid fuel/waste materials will be collected from 16 plants.
dThe low end of the range is taken from Table D-4, ICPAES method for all metals. The high end represents the cost
of NAA (based on telecon with NC State University) including a full QA/QC package. (ICPAES could also cost
over $900 for materials that require complex sample preparation).
eAnalysis cost of $150 per sample x 3 samples = $450 plus $120 (2 hours) for data reduction = $570. Assumed
+ 10% to create range.
fAssume these additional organics analyses are done for a subset of the samples, depending on the type of fuel/waste
material.
8Analysis costs of $350 per sample x 3 samples = $1,050 plus $120 (2 hours) for data reduction = $1,170. Assumed
+ 10% for range.
hCosts are approximately $1,000 per sample, or $3,000 for 3 samples, + 10%.
11-38
-------
Table D2-4. Cost Model to Estimate Fuel Sampling and
Analytical Costs: Three Samples of One Fuel
Tusk/Alii* il\
r.slimali'ri (
<»>l (Ml 1)
1. Pre-test site visit.
410
2,180
2. Project management and Test Protocol preparation.
640
960
3. Prepare test equipment, travel to site, and collect three samples.
820
2,350
4. Reporting.
480
800
Total - Tasks 1-4
2,350
6,290
Ultimate analysis and data reduction for three liquid or solid fuel samples (C, H, S,
O, ash, moisture.
398
473
Heat content analysis and data reduction for three liquid or solid fuel samples
(HHV).
155
176
Fuel gas analysis and data reduction for three samples (composition (C, H, O, N),
HHV, density, and compressibility factor).
546
654
Viscosity analysis and data reduction for three liquid fuel samples.
141
159
Specific gravity analysis and data reduction for three liquid fuel samples.
128
143
Bottoms, sediment, and water analysis and data reduction for three liquid fuel
samples.
303
357
Particle size distribution analysis and data reduction for three solid fuel samples.
249
291
Total organic halogens analysis and data reduction for three liquid or solid fuel
samples (F, CI, Br, I).
600
720
Cost for all metals
Metals analysis and data reduction for three liquid or solid fuel samples by
ICPAES (see footnote 2).
736
872
Metals analysis and data reduction for three liquid or solid fuel samples by flame
AAS (see footnote 3).
736
872
Metals analysis and data reduction for three liquid or solid fuel samples by
GFAAS (see footnote 4).
995
1,189
Cost
per metal
Metals analysis and data reduction for three liquid or solid fuel samples by
ICPAES (see footnote 2).
85
99
Metals analysis and data reduction for three liquid or solid fuel samples by flame
AAS (see footnote 3).
85
99
Metals analysis and data reduction for three liquid or solid fuel samples by
GFAAS (see footnote 4).
115
136
Mercury analysis and data reduction for three liquid or solid fuel samples by
CVAAS.
142
169
1. For tasks 1 to 4, low cost based on easy-to-access source within 50 miles of testing company, high cost based on difficult-to-access source
within 1,000 miles of testing company. Pre-test site visit may not be required for all sources. For analyses, cost range represents a typical cost
plus or minus 10 percent.
2. Metals include: Al, Sb, As, Be, Cd, Cr, Cu, Fe, Pb, Mg, Mn, Ni, K, Se, Ag, Na, V, Zn.
3. Metals include: Al, Sb, As, Be, Cd, Cr, Cu, Fe, Pb, Mg, Mn, Ni, K, Ag, Na, V, Zn.
4. Metals include: Sb, As, Be, Cd, Cr, Cu, Fe, Pb, Mn, Ni, Ag, V, Zn.
11-39
-------
Table D3-1. Stack Test Cost Breakdown by Task
Task
Kslinialeri Cost
(SK)»
Pre-test Site Visit
$8,200
QAPP Preparation
$14,400
Site-Specific Test Plan Preparation
$13,200
Field Preparation
$29,200
Field Test
$494,400
Post Test Recovery
$19,300
Analysis/Data Review
$214,700
Reporting
$27,200
TOTAL COST
$820,600
(low end of range)
Upper End of Cost Range (+ 30%)
$1,067,000
(upper end of range)
aCosts per task represent the lower end of the range of estimated test costs without any
contingency. A factor of 30% is added at the end (last row of table) to provide a ballpark cost
range.
11-40
-------
ATTACHMENT III
ICCR COORDINATING COMMITTEE
RECOMMENDED SUBCATEGORIES AND MACT FLOORS
FOR
EXISTING STATIONARY RECIPROCATING INTERNAL
COMBUSTION ENGINES (RICE)
July 29,1998
-------
TABLE OF CONTENTS
EXECUTIVE SUMMARY i
1.0 SUBCATEGORIES FOR EXISTING RICE 1
1.1 Reasons for Subcategorization 1
1.1.1 Fuel Type 2
1.1.1.1 Liquid Fuels 2
1.1.1.2 Gaseous Fuels 2
1.1.2 Engine Design Characteristics 3
1.1.2.1 Ignition System (SI or CI) 4
1.1.2.1.1 Spark Ignition (SI) 4
1.1.2.1.2 Compression Ignition (CI) 5
1.1.2.2 Air Scavenging Cycles (2-stroke or 4-stroke) 5
1.1.2.2.1 4-Stroke Cycle (4SC) 5
1.1.2.2.2 2-Stroke cycle (2SC) 6
1.1.2.3 Air-to-Fuel Ratio ("rich" or "lean") 6
1.1.3 Emergency Power Units 6
1.1.4 Small Engines 7
1.2 Engines in the ICCR Population Database by Subcategory 8
2.0 APPROACH AND RATIONALE FOR MACT FLOORS 9
2.1 Available Information 9
2.1.1 ICCR Population Database 9
2.1.2 ICCR Emissions Database 10
2.1.3 State Air Regulations and Air Permit Limits for HAPs 10
2.1.3.1 Unified Air Toxics Website (UATW) 11
2.1.3.2 RACT/BACT/LAER Databases 11
2.1.3.3 Permit Information in the ICCR Population Database 12
2.2 Rationale for MACT Floor Determinations 12
2.2.1 Existing Emission Control Techniques 12
2.2.1.1 Control Techniques Most Likely to Reduce HAPs 13
2.2.1.2 Prevalence of Controls Most Likely to Reduce HAPs 16
2.2.2 Good Combustion Practices for RICE 17
2.2.2.1 Possible Good Combustion Practices 17
2.2.2.1.1 Proper Engine Operation 18
2.2.2.1.2 Routine Engine Inspection and
Performance Analyses 18
2.2.2.1.3 Preventive Maintenance 19
2.2.2.2 Prevalence of Good Combustion Practices 20
2.2.3 State Air Emission Regulations for HAPs 21
2.2.4 State Air Permit Limitations for HAPs 22
2.2.5 Emissions 22
-------
EXECUTIVE SUMMARY
RICE Subcategories
The ICCR Coordinating Committee recommends the following ten subcategories for existing
RICE for the purpose of identifying the MACT floors:
• Spark-Ignition, Natural Gas 4-Stroke Rich Burn Engines
• Spark-Ignition, Natural Gas 4-Stroke Lean Burn Engines
• Spark-Ignition, Natural Gas 2-Stroke Lean Burn Engines
• Spark-Ignition, Digester Gas and Landfill Gas Engines
• Spark-Ignition, Propane, Liquid Petroleum Gas (LPG), and Process Gas Engines
• Spark-Ignition, Gasoline Engines
• Compression-Ignition, Liquid Fuel Engines (diesel, residual/crude oil, kerosene/naphtha)
• Compression-Ignition, Dual Fuel Engines
• Emergency Power Units
• Small Engines (200 brake horsepower or less)
The Committee believes these ten subcategories are appropriate for identifying MACT floors to
fully capture significant technical and operational differences among existing RICE.
The Committee recognizes that the final subcategories for any MACT standards established for
existing RICE may be different than those established for the purposes of identifying MACT
floors to incorporate additional information gained in developing the final MACT standards.
MACT Floors for Existing RICE
Section 112 of the Clean Air Act defines the MACT floor as "... the average emission limitation
achieved by the best performing 12 percent of existing sources...".
Based on the above subcategories, the Committee has identified the best performing 12 percent
of existing sources within the Spark-Ignition, Natural Gas 4-Stroke Rich Burn Engine
subcategory. The best performing 12 percent of engines in this subcategory are those engines
using non-selective catalytic reduction (NSCR). Consequently, for this subcategory, the
Committee recommends that the MACT floor be based on engines using NSCR.
For all other subcategories of existing RICE, the Committee is unable to identify a best
performing 12 percent of existing sources. As a result, the Committee is unable to identify a
MACT floor and therefore recommends that there is no MACT floor for RICE in the other
subcategories.
These recommendations are summarized below by subcategory.
MACT Floors
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RICE Subcategory
MACT Floor
Spark-Ignition, Natural Gas 4-Stroke Rich Burn Engines
Based on Non-Selective Catalytic
Reduction
Spark-Ignition, Natural Gas 4-Stroke Lean Burn Engines
No MACT Floor
Spark-Ignition, Natural Gas 2-Stroke Lean Burn Engines
No MACT Floor
Spark-Ignition, Digester Gas and Landfill Gas Engines
No MACT Floor
Spark-Ignition, Propane, LPG, and Process Gas Engines
No MACT Floor
Spark-Ignition, Gasoline Engines
No MACT Floor
Compression-Ignition, Liquid-Fuel Engines
(diesel, residual/crude oil, kerosene/naphtha)
No MACT Floor
Compression-Ignition, Dual Fuel Engines
No MACT Floor
Emergency Power Units
No MACT Floor
Small Engines (200 brake horsepower or less)
No MACT Floor
In forwarding these recommendations to EPA the Committee acknowledges that final
requirements in any MACT standards for existing RICE may include requirements that go
beyond the MACT floors.
Rationale for RICE Subcategories
Existing stationary RICE come in a variety of makes, models, and sizes. The Committee
recommends ten subcategories for existing RICE to distinguish between different classes of
engines. The ten subcategories incorporate the following factors:
• fuel type,
• engine design characteristics,
• emergency power use, and
• small engine size (200 brake horsepower or less).
Fuel type is recommended as one basis for subcategorization to incorporate the following
factors:
1. Stationary RICE use a variety of liquid and/or gaseous fuels.
2. Fuels, in general, are not interchangeable for stationary RICE, as engine design
and operating characteristics vary depending on fuel type. For example, certain
fuels are ignited in the internal combustion process by means of compression
(compression ignition, or CI), while other fuels are ignited by means of an
electrical spark (spark ignition, or SI).
3. Fuel composition and associated mixing affect initiation, rate and completeness
of combustion, which, in turn, may influence HAPs formation and emissions.
4. Fuel type also can affect the viability of control options to reduce HAP emissions
from RICE, as some fuels, such as landfill gas and digester gas, tend to foul
catalytic controls and render them ineffective. Also, some oxidation catalysts
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may be unsuitable for liquid fuel CI engines depending on the sulfur content of
the fuel.
Engine design characteristics, including ignition system (compression ignition or spark ignition),
air scavenging cycle (4-stroke or 2-stroke), and air-to-fuel ratio (rich burn or lean burn), are
also recommended as additional bases for subcategorization to incorporate the following
factors:
1. Ignition systems and air scavenging cycles are design characteristics and are not
interchangeable for existing RICE. Also, operation in rich or lean burn mode is
principally fixed by engine design.
2. Engine design characteristics affect the combustion process, including
factors that may influence HAPs formation, such as fuel and air mixing,
ignition, flame propagation, and quenching.
3. Engine design characteristics also can affect the viability of control options to
reduce HAP emissions from RICE by affecting the constituents in the RICE
exhaust stream and the exhaust temperature.
In addition, a subcategory for emergency power units is recommended in the RICE
subcategories to incorporate the following factors:
1. Emergency power units are used during emergencies. For example, 1) when
electric power from the local utility is interrupted or becomes unreliable and 2)
to pump water in the case of fire or flood. The duration of the emergencies is
entirely beyond the control of the source, and, when they do occur (except in the
case of a major catastrophe) rarely last more than a few hours, often only a few
minutes.
2. Emissions from these units are expected to be low on an annual basis; emissions
occur only during emergency situations or for a very short time to perform
maintenance checks and operator training. State and local regulators generally
have not required emission controls for emergency power units.
3. Emergency power units operate for very few hours per year. EPA previously
determined that 500 hours is an appropriate default assumption for estimating
the number of hours that an emergency power unit could be expected to operate
under worst-case conditions. In reality, most emergency power units operate for
less than 500 hours, some as little as 50 hours or less per year.
4. Add-on catalytic control devices that are most applicable to reduce HAPs from
RICE would be less effective on an annual basis for emergency power units,
since emergency power units generally operate for brief periods (only a few
minutes or hours). Therefore, a greater percentage of the emergency power
units' operation, as compared to operation of peaking or baseload engines, will
occur during catalyst warm-up, when the catalyst's effectiveness will be lower.
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Finally, small engine size is recommended as a basis for subcategorization to incorporate the
following factors:
1. Although stationary RICE range in size from 50 brake horsepower (bhp) to
11,000 bhp, engines 200 brake horsepower or less generally have different
utilization than larger engines. In most cases, engines 200 brake horsepower or
less are nonroad sources (as defined in 40 CFR Part 89.2), not stationary
sources. Small stationary units are more likely to be used for oil/gas field
production or irrigation, while large stationary units are more likely to be used in
electric power generation, gas transmission and gas processing.
2. Small stationary engines (other than emergency power units) generally are not
located at facilities that are major sources of HAP emissions.
3. HAP emissions from a small unit are expected to be low on an annual basis and
state and local air regulatory authorities generally have not required emission
controls for small stationary engines, which are less cost-effective to regulate.
Rationale for RICE MACT Floor Determinations
The MACT floor for existing sources is the "... average emission limitation achieved by the best
performing 12 percent of existing sources...". In order to identify the best performing group of
sources and recommend MACT floors, the Committee reviewed the following available
information related to HAPs emissions from existing RICE:
• existing add-on controls that may reduce HAPs,
• existing good combustion practices that may reduce HAPs, and
• existing emissions data, air regulations, and air permit limitations for HAPs.
The Committee assessed the prevalence of existing, add-on controls by reviewing information
available in the ICCR Population Database for RICE. No existing control techniques are in
place specifically to address the formation or reduction of HAPs from existing RICE. Among
existing add-on controls, however, controls that involve oxidation are the most likely to reduce
HAPs from RICE. For Spark Ignition, Natural Gas, 4-Stroke Rich Burn Engines, 12 percent or
more of engines in the ICCR Population Database for that subcategory use non-selective
catalytic reduction (NSCR) controls. NSCR is a catalytic post-combustion control device that
incorporates oxidation and, based on engineering judgement, is likely to oxidize HAP emissions,
such as formaldehyde, from spark ignition natural gas-fired 4-stroke rich burn engines.
Therefore, the best performing 12 percent of existing sources in this subcategory is represented
by engines with NSCR and the Committee recommends that the MACT floor for Spark
Ignition, Natural Gas, 4-Stroke Rich Burn Engines be based on the use of NSCR. The
Committee reviewed the possibility of establishing HAP emission limitations or emission
reduction requirements based on this MACT floor for the Spark Ignition Natural Gas 4-Stroke
Rich Burn subcategory. However, the Committee recommends that the emissions data available
in the ICCR Emissions Database at present are insufficient to set appropriate HAP emission
limitations or HAP emission reduction requirements for SI natural gas 4-stroke rich burn units
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using NSCR.
For the other subcategories, the Committee recommends that there are insufficient numbers of
engines using add-on controls that may reduce HAPs in the ICCR Population Database to use
this approach to identify the best performing 12 percent of sources in these subcategories. As
outlined below, the Committee examined other approaches for identifying the best performing
12 percent of sources within these other subcategories (e.g., emission data; State regulations
and permits; good combustion practices; etc.), but is unable to identify a best performing 12
percent of existing sources within these subcategories based on any approach. Thus the
Committee recommends that there is no best performing 12 percent of existing sources within
these other subcategories and that there is no MACT floor for these other subcategories.
The Committee considered the use of emissions data to identify a best performing 12 percent of
existing sources within each of the other subcategories by reviewing available emissions test
data for HAPs, state air regulations for RICE, and air permit limits. The Committee
recommends that the available emissions test data are insufficient to be used as the basis for
identifying MACT floors. The existing data varies widely and often lacks information about the
status of the RICE tested, including key engineering and operating data. These factors
prevented the Committee from identifying a best performing 12 percent of existing sources,
since the Committee is unable to determine whether any specific emission levels (i.e.,
performance) would be achievable for existing RICE.
The Committee confirmed that there are no state air emission regulations for HAP emissions
from RICE units. In addition, the Committee reviewed state air permit limitations for HAPs and
recommends that the few HAP emission limitations identified are also insufficient to be used as
the basis for identifying MACT floors. Within each subcategory much less than 12 percent of
engines are subject to state air permits and, given the variability seen in the emission data as
mentioned above as well as the small number of engines subject to permits, the Committee is
unable to determine whether any specific emission levels (i.e., performance) would be
achievable for existing RICE.
The Committee assessed existing good combustion practices by using information available in
the ICCR Population Database, information from state air permitting authorities and the
expertise of various stakeholders. Practices that maintain good engine performance may lead to
more complete combustion and, therefore, may decrease the likelihood of increased HAP
emissions that may be associated with incomplete combustion or engine failure. However, at
this time, the Committee is unable to identify any emissions data to link improved maintenance
and operating practices to reduced HAP emissions. Existing regulatory requirements for
inspection and maintenance practices were identified for only a few sources in two states:
Louisiana and California. In both cases, the source owners and operators established inspection
and maintenance plans that are site-specific and the content of the plans was negotiated with the
air permitting authorities. Based on a review of all available information, the Committee was
unable to identify a best performing 12 percent of engines within the other RICE subcategories
by considering specific maintenance, inspection, and/or operating practices.
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RECOMMENDED SUBCATEGORIES AND MACT FLOOR FOR
EXISTING STATIONARY RECIPROCATING INTERNAL COMBUSTION ENGINES
(RICE)
The purpose of this document is to transmit the Committee's recommendations and rationale for
subcategories and MACT floors for existing RICE to EPA.
Section 1.0 presents the Committee's recommendations regarding subcategories for existing
RICE and the rationale supporting those subcategories. Section 2.0 presents the Committee's
MACT floor recommendations for each subcategory, along with the supporting rationale for
these recommendations.
1.0 SUBCATEGORIES FOR EXISTING RICE
Existing stationary RICE come in a variety of makes, models, and sizes and use a variety of
liquid and gaseous fuels. In order to distinguish between different classes of engines, the
Committee recommends ten subcategories of existing RICE for the purpose of identifying
MACT floor. The Committee recommends that these ten subcategories are the minimum
number necessary for identifying the MACT floor to fully capture significant technical and
operational differences among existing RICE. The RICE subcategories are listed below:
• Spark-Ignition, Natural Gas 4-Stroke Rich Burn Engines
• Spark-Ignition, Natural Gas 4-Stroke Lean Burn Engines
• Spark-Ignition, Natural Gas 2-Stroke Lean Burn Engines
• Spark-Ignition, Digester Gas and Landfill Gas Engines
• Spark-Ignition, Propane, Liquid Petroleum Gas (LPG), and Process Gas Engines
• Spark-Ignition, Gasoline Engines
• Compression-Ignition, Liquid Fuel Engines (diesel, residual/crude oil,
kerosene/naphtha)
• Compression-Ignition, Dual Fuel Engines
• Emergency Power Units
• Small Engines (200 brake horsepower or less)
1.1 Reasons for Subcategorization
The Committee recommends these subcategories for RICE to incorporate factors that may
affect the HAP emissions from RICE and/or the viability of control techniques that may reduce
HAP emissions from RICE. The Committee believes that fuel type and engine design
characteristics are the key factors that affect HAP emissions and the viability of controls. In
addition, the Committee also recommends subcategories for RICE classified as emergency
power units and RICE classified as small engines.
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Further discussion of the rationale for subcategorization is provided in the sections below.
1.1.1 Fuel Type
Fuel type is recommended as a basis for subcategorization to incorporate the following factors:
1. Stationary RICE use a variety of liquid and/or gaseous fuels.
2. Fuels, in general, are not interchangeable for stationary RICE, as engine design
and operating characteristics vary depending on fuel type. For example, certain
fuels are ignited in the internal combustion process by means of compression
(compression ignition, or CI), while other fuels are ignited by means of an
electrical spark (spark ignition, or SI).
3. Fuel type, composition and associated mixing affect initiation, rate and
completeness of combustion, which, in turn, may influence HAPs formation and
HAP emissions.
4. Fuel type also can affect the viability of control options to reduce HAP emissions
from RICE, as some fuels, such as landfill gas and digester gas, tend to foul
catalytic controls and render them ineffective. Also, some oxidation catalysts
may be unsuitable for liquid fuel CI engines depending on the sulfur content of
the fuel.
1.1.1.1 Liquid Fuels
The following liquid fuels are used for stationary RICE: diesel, residual/crude oil,
kerosene/naphtha (jet fuel), and gasoline. Two subcategories are recommended for liquid fuels
to distinguish between those fuels that are used in CI engines and those fuels that are used in SI
engines. There is no further subcategorization recommended for liquid-fueled RICE.
Liquid fuels used in CI engines include distillate oil (Nos. 1-4), residual oil (Nos. 5 and 6), and
kerosene/naphtha (jet fuel). Gasoline is the only liquid fuel used in stationary SI engines. With
the exception of extremely small co-generation applications (~ < 100 kW) gasoline engines are
seldom utilized in stationary applications. Most stationary liquid-fueled engines operate using
compression ignition. CI engines operate on a wide variety of liquid fuels ranging from light
distillates such as No. 1 fuel oil to residuals from the refining process, sometimes called residual
or "heavy" fuel, that are virtually solid at room temperature.
1.1.1.2 Gaseous Fuels
The following gaseous fuels are used for stationary RICE: natural gas, digester gas, landfill gas,
propane, liquid petroleum gas (LPG), and process gas. Most gaseous fuels are used in SI
engines. In CI engines, gaseous fuels may be used as the primary fuel, but a small pilot injection
of liquid fuel (usually diesel) is required for ignition. CI engines where liquid fuel is used for
ignition and gaseous fuels are used as the primary fuel are commonly called "dual fuel" engines.
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Subcategories for gaseous fuels distinguish between CI engines (dual fuel) and SI engines. In
addition, further subcategories are recommended for gaseous fuels used in SI engines to reflect
the differences in the gaseous fuels, which affect engine design characteristics, and may affect
HAP emissions formation and the viability of control devices.
Natural gas is recommended as a separate subcategory. For the purposes of this
subcategorization, natural gas means a naturally occurring mixture of hydrocarbon and non-
hydrocarbon gases found in geologic formations beneath the earth's surface, of which the
principal constituent is methane. Natural gas may be either field gas or pipeline quality gas.
Digester and landfill gases are recommended as a separate subcategory. These fuels are by-
products of wastewater treatment and land application of municipal refuse. These gases, which
are formed through anaerobic decomposition of organic materials, are principally comprised of
methane (50% - 65%) and carbon dioxide (35% - 50%). Trace quantities of other compounds
including hydrogen sulfide, ammonia, volatile organic compounds (VOCs) and particulate
matter (PM) also are present. Digester and landfill gases are similar in their composition, and
their emissions after combustion are very similar to natural gas. There are, however, some
differences in that emissions from digester and landfill gas would contain trace quantities of
chlorinated compounds typically not found in natural gas.
Both digester gas and landfill gas contain a family of silicon-based gases collectively called
siloxanes. Siloxanes are found in many cosmetics and cleaning solutions that are disposed of in
either landfills or sewers. Combustion of siloxanes forms compounds that can foul fuel systems,
combustion chambers, and post-combustion catalysts. The fouling renders catalysts inoperable
within a very short time period. Because of this problem, catalytic technology has not been
demonstrated to work effectively on internal combustion engines burning these fuels. This also
includes dual fuel engines that burn diesel and either digester gas or landfill gas. Dual fuel
engines are common within the wastewater treatment and landfill industries.
Propane, liquid petroleum gas (LPG), and process gas are recommended as a third subcategory.
All three are refined gases that largely consist of C2 through C4 hydrocarbons in either the alkane
or alkene family. These differences in fuel composition may lead to different HAP emissions
than those from natural gas.
1.1.2 Engine Design Characteristics
The following engine design characteristics are recommended as a basis for RICE
subcategories:
• ignition system (compression ignition or spark ignition)
• air scavenging cycle (4-stroke or 2-stroke)
• air-to-fuel ratio (rich burn or lean burn)
These design characteristics are recommended as a basis for subcategorization to incorporate
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the following factors:
1. Ignition systems and air scavenging cycles are not interchangeable for existing
RICE. Also, operation in rich or lean burn mode is principally fixed by engine
design.
2. Engine design characteristics affect the combustion process, including factors
that may influence HAPs formation, such as fuel and air mixing, ignition, flame
propagation, and quenching.
3. Engine design characteristics also can affect the viability of control options to
reduce HAP emissions from RICE by affecting the constituents in the RICE
exhaust stream and the exhaust temperature.
Descriptions of the ignition systems for RICE, the air scavenging cycles, and air-to-fuel ratios
are provided below.
1.1.2.1 Ignition System (CI or SI)
There are two ignition systems for stationary RICE: spark ignition (SI), also known as Otto
cycle, and compression ignition (CI) also known as the Diesel cycle. The SI cycle uses lower
compression ratios than does the CI cycle and relies on an electrical spark to ignite the fuel
mixture in the cylinder. The CI cycle uses high compression ratios and the resultant high
temperatures to produce auto-ignition of the fuel in the cylinder. The intake process for both SI
and CI cycles, including the fuel mixing process and ignition timing, affects the initiation and the
rate of combustion, which, in turn, may influence HAPs formation. A more detailed description
of both operating cycles is provided below.
1.1.2.1.1 Spark Ignition (SI)
SI engines utilize a "spark" generated by a spark plug and associated electronics to initiate
combustion. Traditionally, one or more of these spark plugs are mounted directly in the
combustion chamber. When applied to larger bore engines, such open combustion chamber
(OCC) systems result in significant combustion instability and can operate only at moderately
lean air-to-fuel ratios. To extend the lean limit (thereby reducing fuel usage and reducing NOx
emissions) engine manufacturers introduced two-stage combustion. In the first stage, the spark
ignites a small quantity of fuel in a rich air-to-fuel mixture in a separate chamber, which is
known as a pre-combustion chamber (PCC). Then, in the second stage, the bulk of the fuel,
which is in a very lean air-to-fuel mixture, is ignited by the hot, burning gases jetting from the
PCC. Recently several after-market manufacturers have offered alternative electrical based
ignition systems such as plasma jets. Typically these high-energy ignition systems operate in an
OCC.
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1.1.2.1.2 Compression Ignition (CI)
Compression ignition engines operate at significantly higher compression ratios than SI engines,
with the resultant heat of compression raising the temperature of the trapped air or air and fuel
charge to ~800°F or more. Fuel (usually liquid) injected into this hot compressed gas then
spontaneously vaporizes, disassociates and ignites. Often CI engines are referred to as "diesel"
engines after the originator and patent holder of the method, Rudolph Diesel. While some
diesel engines utilize a pre-combustion chamber to assist in ignition, particularly at part load,
most large stationary CI diesels have OCCs to maximize efficiency and performance.
Dual fuel CI engines scavenge or inject gaseous fuels into the combustion chamber with the
fresh air charge and then utilize a small "pilot injection" of liquid fuel (usually No. 2 diesel) to
ignite the mixture. The less expensive gaseous fuel usually provides 90-99% of the input energy
while the more expensive liquid fuel provides the balance. Originally, dual fuel engines were
simple conversions of OCC diesel engines which maintained the ability to operate on "full
diesel" (i.e. 100% liquid fuel). While offering favorable NOx emissions in this configuration,
subsequent regulations to further reduce NOx emissions resulted in several engine manufacturers
offering such engines fitted with PCCs to reduce the pilot fraction to ~ 1% or less.
1.1.2.2 Air Scavenging Cycles (2-stroke or 4-stroke)
Reciprocating internal combustion engines utilize either 2-stroke cycle (2SC) or 4-stroke cycle
(4SC) scavenging. Two-stroke engines complete the power cycle in a single crankshaft
revolution as compared to the two crankshaft revolutions required for 4-stroke engines.
The scavenging cycle impacts the trapped air and fuel charge and mixing, which may impact
HAPs formation. A description of the scavenging cycles is provided below.
1.1.2.2.1 4-Stroke Cycle (4SC)
4SC engines are the most familiar engine type due to their use in vehicular applications. A 4SC
engine undergoes four distinct events or strokes: intake, compression, power and exhaust. 4SC
engines may be either naturally aspirated (NA) or turbocharged (TC). A 4SC NA engine uses
the suction from the intake stroke to entrain the air charge and uses the exhaust stroke to
remove exhaust gases from the cylinder. Inasmuch as maximum power delivery is limited by the
air supply, 4SC NA engines tend to operate near or slightly rich of stoichiometry, the theoretical
air-to-fuel ratio required for complete combustion, and are commonly called rich-burn engines.
In general, financial and performance considerations require that large stationary 4SC engines
operate at specific outputs two to four times that obtainable with NA alone. These large 4SC
engines use an auxiliary air compressor to increase the charge density at the engine intake. The
most common method is to use an exhaust-driven turbine, called a turbocharger. Turbocharged
units produce a higher power output for a given engine displacement. In order to maximize the
fresh air charge density, most 4SC turbocharged (4SC TC) engines utilize an aftercooler or
intercooler to remove the heat of compression from the fresh air charge. Typically, mechanical
and/or thermal loading limits the output of 4SC TC engines. 4SC TC gaseous-fueled engines
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that are spark-ignited can operate from rich of stoichiometric to more than twice as lean as
stoichiometric (over 100% excess combustion air).
1.1.2.2.2 2-Stroke Cycle (2SC)
To maximize power output/density, 2SC engines combine the intake and compression
operations into one stroke and the power and exhaust operations into a second stroke.
Consequently, an auxiliary device is required to "scavenge" the engine. In their simplest form
this may consist of pumping off the underside of the piston or the addition of one or more
scavenging pump cylinders to the same crankshaft connecting the power cylinders. In more
sophisticated applications gear or motor driven blowers may supply scavenging air. Typically,
due to inherent limitations in 2SC scavenging, these pump scavenged (2SC PS) or blower
scavenged (2SC BS) 2SC engines operate somewhat lean of stoichiometric and are also
classified as "lean burn".
Like 4SC, financial and performance considerations (in particular the load of crank driven
pumps/blowers), require that larger more modern stationary 2SC engines utilize turbochargers
(2SC TC) and intercoolers to increase charge air density and specific output. 2SC TC engines
typically operate lean of stoichiometric conditions and are known as lean burn engines.
1.1.2.3 Air-to-Fuel Ratio ("rich " or "lean ")
Stationary RICE operate with various air-to-fuel ratios. In general, air-to-fuel ratios may be
classified as either rich or lean of stoichiometry, the theoretical air-to-fuel ratio required for
complete combustion. All stationary CI engines are lean burn engines, usually utilizing
turbochargers and intercoolers to achieve the desired fresh air density. SI engines may be either
rich-burn engines or lean burn engines.
A common method used to differentiate between "rich burn" and "lean burn" engines is the
percentage oxygen in the exhaust stream. Several regulatory agencies have adopted a value of
4% oxygen in the exhaust as the defining limit for "rich burn" engines. An engine with more
than 4% exhaust oxygen is classified as "lean burn". In point of fact, most "lean burn" engines
manufactured today have at least 7% exhaust oxygen.
1.1.3 Emergency Power I Jnits
Emergency power units are defined as stationary RICE that operate as mechanical or electrical
power sources during emergencies, or for scheduled maintenance checks or operator training.
For example, 1) when electric power from the local utility is interrupted or becomes unreliable
and 2) to pump water in the case of fire or flood. The emission source is typically a gasoline or
diesel-fired engine but may be a gaseous-fueled engine. This subcategory would not include 1)
peaking units at electric utilities; 2) engines at industrial facilities that typically operate at low
rates, but are not confined to emergency purposes; and 3) any standby generator that is used
during time periods when power is reliably available from the utility.
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A subcategory for emergency power units is recommended in the RICE subcategories to
incorporate the following factors:
1. Emergency power units are used during emergency. For example, 1) when
electric power from the local utility is interrupted or becomes unreliable and 2)
to pump water in the case of fire or flood. The duration of the emergencies is
entirely beyond the control of the source, and, when they do occur (except in the
case of a major catastrophe) rarely last more than a few hours, often only a few
minutes.
2. Emissions from these units are expected to be low on an annual basis;
emissions occur only during emergency situations or for a very short time
to perform maintenance checks and operator training. State and local
regulators generally have not required emission controls for emergency
power units.
3. Emergency power units operate for very few hours per year.
EPA previously determined that 500 hours is an appropriate
default assumption for estimating the number of hours that an
emergency power unit could be expected to operate under worst-
case conditions. (Memorandum on Calculating Potential to Emit
(PTE) for Emergency Generators from John S. Seitz, Director of
the Office of Air Quality Planning and Standards, September 6,
1995.) In reality, most emergency power units operate for less
than 500 hours, some as little as 50 hours or less per year.
4. Add-on catalytic control devices that are most applicable to reduce HAPs from
RICE would be less effective on an annual basis for emergency power units,
since emergency power units generally operate for brief periods (only a few
minutes or hours). Therefore, a greater percentage of the emergency power
units' operation, as compared to operation of peaking or baseload engines, will
occur during catalyst warm-up, when the catalyst's effectiveness will be lower.
1.1.4 Small Engines
Stationary RICE range in size from 50 brake horsepower (bhp) to 11,000 bhp. A separate
subcategory for small engines (200 bhp or less) is recommended to incorporate the following
factors:
1. Engines 200 brake horsepower or less generally have different utilization than larger
engines. In most cases, engines 200 brake horsepower or less are nonroad sources (as
defined in 40 CFR Part 89.2), not stationary sources. Small stationary units are more
likely to be used for oil/gas field production or irrigation, while large stationary units are
more likely to be used in electric power generation, gas transmission, and gas
processing.
2. Small stationary engines (other than emergency power units) generally are not located at
facilities that are major sources of HAP emissions.
3. HAP emissions from a small unit are expected to be low on an annual basis and state and
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local air regulatory authorities generally have not required emission controls for small
stationary engines, which are less cost-effective to regulate. For example, the State of
Texas only requires that stationary engines rated at 250 bhp or greater be registered with
the state air regulatory agency.
1.2 Engines in the ICCR Population Database by Subcategory
The following diagram provides the total number of RICE included in the ICCR Population
Database Version 2 and the distribution of these units within each assigned subcategory. The
Committee recommends using version 2 of the ICCR Population Database instead of version 3
due to the following reasons:
1. The additional units under version 3 do not affect the determined MACT
Floor(s).
2. Information for the additional units does not include specific parameters, such as
engine make and model, which are necessary for subcategorization.
3. Considerable efforts were expended in refining the gathered data in version 2.
The RICE distribution in the Population Database by subcategory is presented below.
EPA Population Database Subcategorization Chart
*3,190 natural gas-fired engines contain enough information to be further subcategorization
Engines
28,200
Emergency Power Units Small Engines
5,700 I 2,900
I 200 brake horsepower or less
I and not emergency power units
Spark Ignition Compression Ignition
15,000 4,600
All fuels from Liquid Fuel Spark Ignition Residual/Crude Oil, Dual Fuel (Oil/Gas),
and Gaseous Fuel Spark Ignition Kerosene/Naphtha (Jet Fuel), and Distillate Oil (Diesel)
Gasoline*'
200
Gaseous Fuel
14,800
Digester Gas, Landfill Gas, Propane, LPG,
Natural Gas, Process Gas, and Non-fossilM/aste
Liquid Fuel
4,100
Residual/Crude Oil,
Distillate Oil (Diesel), and Kerosene/Naphtha (Jet Fuel)
Dual Fuel
500
Dual Fuel (Oil/Gas)
Digester/Landfill Gas*"
150
Also includes Non-fossil/Waste
Propane, LPG, and Process Gas*"
150
Natural Gas
14,500*
4-stroke*
2-stroke*
Rich Burn Lean Burn Lean Burn
1,180* 920* 1,090*
Natural Gas Natural Gas Natural Gas
**Further subcategorization not necessary for MACT floor determination.
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2.0
APPROACH AND RATIONALE FOR MACT FLOORS
The MACT floor for existing sources is defined in Section 112 of the Clean Air Act as the "...
average emission limitation achieved by the best performing 12 percent of existing sources...".
In order to identify the best performing group of sources and recommend MACT floors, the
Committee reviewed the following available information related to HAPs emissions from
existing RICE:
• existing add-on controls that may reduce HAPs,
• existing good combustion practices that may reduce HAPs, and
• existing emissions, air regulations, and air permit limitations for HAPs.
The recommended MACT floors are summarized by subcategory below.
MACT Floors
KICK Subcategory
MACT Moor
Spark-Ignition, Natural Gas 4-Stroke Rich Burn
Engines
Based on Non-Selective Catalytic
Reduction
Spark-Ignition, Natural Gas 4-Stroke Lean Burn
Engines
No MACT Floor
Spark-Ignition, Natural Gas 2-Stroke Lean Burn
Engines
No MACT Floor
Spark-Ignition, Digester Gas and Landfill Gas Engines
No MACT Floor
Spark-Ignition, Propane, LPG, and Process Gas Engines
No MACT Floor
Spark-Ignition, Gasoline Engines
No MACT Floor
Compression-Ignition, Liquid-Fuel Engines
(diesel, residual/crude oil, kerosene/naphtha)
No MACT Floor
Compression-Ignition, Dual Fuel Engines
No MACT Floor
Emergency Power Units
No MACT Floor
Small Engines (200 brake horsepower or less)
No MACT Floor
2.1 Available Information
Inventory information and emissions source test reports in the ICCR Population and Emissions
Databases were used as the primary basis to identify MACT floors. State regulations, state air
permits, stakeholder expertise, and information from equipment manufacturers and state air
regulatory representatives also were considered.
2.1.1 ICCR Population Database
The ICCR Population Database was used for information about existing engines, including
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information about the prevalence of emission controls. For RICE, the ICCR Population
Database currently has inventory information on approximately 28,000 RICE, of which 5,700,
or 20% of the entries, are emergency power units. The Committee recommends the use of the
ICCR Population Database to identify MACT floors for existing RICE, based on the following:
1. Engines for all known fuels are included in the database.
2. Engines are included for key user segments (SIC codes) that may have facilities that are
major sources of HAP emissions.
3. Small and large engines are included in the database.
4. Engines used for emergency power, peaking, and base loads are included in the
database.
5. The database provides information on control techniques for existing engines.
6. The conclusions drawn from the database regarding the prevalence of existing control
techniques are consistent with experience with existing engines and experiences of state
air permitting authorities and equipment manufacturers.
Emergency power units were identified in the ICCR Population Database by examining
information provided in the "Combustor Description" field and information in the "Hours of
Operation" field. If the total number of hours of operation was 500 or less, the engine was
considered an emergency power unit. Also, if the "Combustor Description" field included the
word "emergency," the engine was considered an emergency power unit.
2.1.2 ICCR Emissions Database
The ICCR Emissions Database for RICE includes over 30 air emissions test reports for HAPs.
Engines in the ICCR Emissions Database range in size from 39 to 5,500 brake horsepower, so
small and large engines have been captured. The test reports represent applications in industrial,
pipeline, and utility sectors. The majority of the source tests were conducted in the State of
California as part of the AB2588 (Air Toxics "Hot Spots" Information Assessment Act of 1987)
program. The State of California is the only state with regulatory requirements for estimating
air toxic emissions from RICE. Other emissions data collected by the Gas Research Institute for
natural gas-fired engines have been considered in the MACT floor evaluation as well.
2.1.3 State Air Regulations and Air Permit Limits for HAPs
For the purpose of identifying MACT floors, the Committee limited its review of state air
regulations and air permit limits to HAPs only. Although some states regulate air emissions of
volatile organic compounds (VOCs) from existing RICE, and some HAPs are VOCs, the
relationship between VOC and HAP emissions from existing RICE is unknown. Therefore, the
Committee recommends that VOC emission limitations are insufficient, at this time, to estimate
HAP emissions.
Available information on state air regulations and air permit limits for HAPs was obtained from
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the following sources:
• Unified Air Toxics Website (UATW),
• RACT/BACT/LAER Databases, and
• permit limit information in the ICCR Population Database for RICE.
The information was verified by contacting several states, including Alaska, California,
Louisiana, North Carolina, and Texas.
2.1.3.1 Unified Air Toxics Website (UATW)
The Unified Air Toxics Website (UATW) was designed as the USEPA's "one stop" site for all
information regarding HAPs emissions. The UATW is available on the EPA TTNWEB at
http://www.epa.gov/ttn/uatw. The UATW includes HAPs permits and regulations for most
state and local agencies. The UATW is an evolving site jointly designed by the EPA Office of
Air Quality Planning and Standards (OAQPS), the State and Territorial Air Pollution Program
Administrators (STAPPA), and the Association of Local Air Pollution Control Officials
(ALAPCO).
The UATW was searched for state and local agencies known to have stringent regulation
requirements for toxic emissions, including California, Florida, Louisiana, New Hampshire,
North Carolina, Pennsylvania, South Coast AQMD, and Texas. The UATW was also searched
using the following keywords: formaldehyde, engine, state, permit, and regulation. In addition,
the UATW was searched for state air permit limitations for RICE.
2.1.3.2 RACT/BACT/LAER Databases
The RACT/BACT/LAER Clearinghouse contains information from air permits submitted by
most of the state and local air pollution control programs in the United States. The database is
available on-line at the TTN web site of the EPA:
http://www.epa.gov/ttn/catc in the CATC (Clean Air Technology) technical site
Emissions limits for RICE were searched by downloading all available databases (historical,
transient, and current) of the RACT/BACT/LAER Clearinghouse. Several tables are included
in each database; however, only two tables were determined to be relevant to the emission limits
search: the Master Table (BLMSTR) and the Notes Table (BLNOTES). BLMSTR contains
general information about facilities and their emission permits. BLNOTES provides comments
and other additional information about the permits.
The historical, transient, and current RACT/BACT/LAER databases were searched individually
for state air permit limitations for RICE.
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2.1.3.3 Permit Limit Information in the ICCR Population Database
Version 3 of the ICCR Population Database includes HAPs air permit limits for 49 engines, out
of 28,000 engines total (or less than 0.2 percent). The engines with HAP air permit limits are
located at facilities in Louisiana and California. There are 15 facilities with HAP permit limits —
14 are in Louisiana, and one is in California. HAP permit limits for these engines are reported
for at least one of the following pollutants:
xylenes toluene
naphthalene n-hexane
formaldehyde ethylbenzene
chlorine benzene
aldehydes
2.2 Rationale for Recommended MACT Floors
2.2.1 Existing Emission Control Techniques
The Committee assessed existing emission control techniques by 1) determining which control
techniques are most likely to reduce HAPs and 2) reviewing information available in the ICCR
Population Database to determine the prevalence of those controls for existing RICE.
As outlined below, the Committee identified a best performing 12 percent of existing engines
within the subcategory of Spark Ignition, Natural Gas, 4-Stroke Rich Burn Engines. The best
performing 12 percent of engines within this subcategory are represented by those engines using
non-selective catalytic reduction (NSCR) and the Committee recommends that the MACT floor
for this subcategory be based on engines using NSCR. For each of the other subcategories, the
Committee was unable to identify a best performing 12 percent of engines. As a result, the
Committee was unable to identify a MACT floor for engines within the other subcategories and
recommends that there is no MACT floor for these other subcategories.
A breakdown, by subcategory, of emission controls for existing RICE included in the ICCR
Population Database, is provided in the table below.
Emission Controls for Existing RICE Included in the ICCR Population Database
Subcategory
No. of
Units
No Add-on
Controls (%)
Add-on Controls
(%)
SI Natural Gas 4-Stroke Rich Burn
1,180
71%
25% Catalytic
Reduction
4% Other*
SI Natural Gas 4-Stroke Lean Burn
920
94%
3% Catalytic
Reduction
3% Other*
SI Natural Gas 2-Stroke Lean Burn
O
o
99%
1% Other*
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Subcategory
No. of
Units
No Add-on
Controls (%)
Add-on Controls
(%)
SI Digester and Landfill Gas
150
89%
10% Air Injection
2% Steam or Water
Injection
SI Propane, LPG and Process Gas
150
96%
3% Other*
1% Catalytic
Reduction
SI Gasoline
200
100%
none
CI Liquid Fuel
(diesel, residual/crude oil, kerosene/naphtha)
4,100
97%
3% Other*
CI Dual Fuel
500
95%
1% Catalytic
Reduction
3% Steam or Water
Injection
1% Other*
Emergency Power Units
5,700
99%
1% Other*
Small Engines (200 bhp or less)
2,900
98%
1% Catalytic
Reduction
1% Other*
* Other includes add-on controls such as exhaust gas recirculation (ERG) and pre-combustion chamber (PCC)
2.2.1.1 Control Techniques Most Likely to Reduce HAPs
The Committee reviewed control techniques used on existing RICE to identify those techniques
that are most likely to reduce HAPs. Due to the lack of adequate HAP emissions data for
existing engines with controls, the Committee relied principally on engineering judgement and
stakeholder expertise to determine which controls would be most likely to reduce HAPs, such
as formaldehyde, from existing RICE.
Most emissions control strategies for stationary RICE focus on the reduction of nitrogen oxides
(NOx), either by altering the combustion process (through parametric controls or combustion
modifications) or after-treatment catalytic controls. In addition, there are some after-treatment
catalytic controls in place to reduce carbon monoxide (CO) and/or volatile organic compounds
(VOCs). No existing control techniques are in place specifically to address the formation or
reduction of HAP emissions from existing RICE.
The control techniques reviewed are presented below.
• For CI liquid-fueled engines:
• Oxidation catalyst
• Selective catalytic reduction (SCR)
• Exhaust gas recirculation (EGR)
• Pre-combustion chamber (PCC)
• Fuel-injection timing adjustment
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NOTE: EGR and PCC are not available as retrofits for existing CI liquid-fueled RICE.
Fuel-injection timing adjustment is available for only a limited number of CI liquid fuel
engine models.
• For CI dual fuel engines:
• Oxidation catalyst
• Selective catalytic reduction (SCR)
• Pre-combustion chamber (PCC)
• Steam or Water Injection
NOTE: Oxidation catalysts and SCR are not viable for CI dual fuel engines that use
digester gas or landfill gas. PCC is available for only a limited number of CI dual fuel
engine models.
• For SI gasoline engines:
• Oxidation catalyst (lean burn engines only)
• Selective catalytic reduction (SCR) (lean burn engines only)
• Non-selective catalytic reduction (rich burn engines only)
• For SI gaseous-fueled engines:
• Oxidation catalyst (lean-burn engines only)
• Selective catalytic reduction (SCR) (lean-burn engines only)
• Pre-combustion chamber (PCC) (lean burn engines only)
• Non-selective catalytic reduction (rich burn engines only)
• Steam or Water Injection
NOTE: Oxidation catalysts, NSCR, and SCR are not viable for SI gaseous-fueled
engines that use digester gas or landfill gas. PCC is available for only a limited number
of SI gaseous-fueled engine models.
The Committee recommends that control techniques which alter the combustion process to
reduce NOx emissions, including PCC, EGR, and Steam or Water Injection are not be likely to
reduce HAP emissions, such as formaldehyde, that result from incomplete combustion. Existing
combustion modification techniques reduce NOx emissions from RICE by lowering the
combustion temperature in the engine cylinders. These techniques are not expected to reduce
HAPs and may result in higher HAP emissions.
Based on a review of emissions test data, contacts with control equipment manufacturers and
state air regulatory representatives, and stakeholder expertise, the Committee recommends that
add-on control devices which involve oxidation are most applicable for HAPs reduction from
RICE. The primary HAPs constituent from natural gas engines is formaldehyde, CH20, which
is formed when conditions do not allow methane to oxidize completely. Formaldehyde is a
product of partial combustion, as is CO. The removal of formaldehyde and similar HAPs
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requires the use of a catalyst that promotes further oxidation. Three types of catalytic controls
have been applied to stationary RICE for NOx reduction:
1) Selective catalytic reduction, (SCR) — injects a "reducing agent" (typically ammonia, NH3)
into the exhaust upstream of the catalyst to "extract oxygen" from NOx compounds,
transforming them into molecular nitrogen, N2.
2) Non-selective catalytic reduction, (NSCR) — is used on "rich-burn" engines that can operate
at approximately stoichiometric (chemically correct) air-to-fuel ratios. NSCR catalysts are
formulated to enhance both reduction and oxidation reactions and will lower emissions of
NOx, carbon monoxide (CO), and some volatile organic compounds (VOCs). NSCR
catalysts rely on the engine to produce sufficient CO to act as a reducing agent to extract
oxygen from the NOx compounds. Maintaining the proper CO/NOx ratio for proper
operation requires very precise air-to-fuel ratio control. NSCR may not be a viable control
for digester gas or landfill gas as these fuels tend to foul the catalyst.
3) Oxidation catalysts — are used on lean burn engines to reduce the CO and some VOCs.
Oxidation catalysts may not be viable controls for digester gas or landfill gas as these fuels
tend to foul the catalyst.
Current installations of SCRs are not expected to be effective in reducing HAPs, such as
formaldehyde, since the SCR devices are formulated to enhance reduction reactions only.
Existing SCRs do not use oxidation to lower emissions. New SCR technology has been
developed that does incorporate oxidation and may be applicable for HAP reduction. However,
for existing sources and for the purpose of identifying the best performing 12 percent of existing
sources (i.e., MACT floors), existing SCRs were not considered applicable control devices that
may reduce HAPs.
NSCR catalysts are formulated to enhance both reduction and oxidation reactions. It is
therefore expected that both NSCR and oxidation catalysts will exhibit some effectiveness in
oxidizing formaldehyde and other similar HAPs. Therefore, for rich burn engines, non-selective
catalytic reduction (NSCR) controls are the most applicable existing control device that
achieves oxidation. For lean burn engines, catalysts designed to oxidize CO are the most
applicable existing control devices.
The ICCR Population Database identified "direct flame afterburners" as an emission control
device for rich-burn landfill gas engines (note: listed as air injection in the above table). All
known stationary internal combustion engines at landfills are lean burn engines, except for 11
rich burn (stoichiometric) engines operated by a company in California. The Committee
obtained more information on the type of emission control technique used on these rich-burn
engines by contacting the owner/operator and by reviewing information provided by air
regulatory personnel from California. Based on the information provided, the Committee
recommends that the control technique in place is incorrectly classified as "direct flame
afterburners" in the ICCR Population Database and should be classified as fuel-rich/air injection.
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The engines in question initially were equipped with non-selective catalytic reduction (NSCR)
units to control NOx emissions. After early failure of the NSCR devices, the operator met
emission reduction requirements by modifying the operating parameters of the engines. These
modifications included fuel-rich operation of the engines to reduce NOx formation. While
successful at reducing NOx, CO emissions increased. CO was reduced by injecting air into the
exhaust gas stream to oxidize the unburned fuel and "afterburn" the exhaust. Although
originally considered temporary, the fuel-rich/air injection systems have been in place since the
early 1980's.
Although no actual emissions data exists, there are several theoretical problems with this
emission control system. Rich-burn engines operating fuel-rich produce more CO and
formaldehyde emissions than engines operating at proper air-to-fuel ratios. The injection of air
must be done precisely; if either too much or too little air is injected, both the rate of exhaust
gas combustion and the resulting CO reduction efficiency will be affected. Proper mixing of the
injected air is also important; poor air distribution can cause sections of the exhaust gas stream
to remain unburned. Even if the control system is working perfectly, there is no evidence that it
will reduce HAP emissions beyond that of a properly tuned engine.
Violation notices written between January 1, 1990 and May 21, 1998, against the landfills
indicate compliance problems for the control systems. At one plant, seven NOx emissions
violations and two CO emissions violations were recorded. At the second plant, five NOx
emissions violations and two CO emissions violations were recorded. No engine violations
were recorded at the third plant.
In summary, the fuel-rich/air injection systems in use on rich-burn engines at these landfills are
temporary emission control devices that are not performing consistently in the field. There is no
evidence that these systems reduce HAP emissions, nor is there any evidence to suggest that
HAPs emissions from fuel-rich/air injection systems on rich-burn RICE at landfills are any
different from HAPs emissions from lean-burn RICE at landfills.
Therefore, the Committee identified only two control techniques that may reduce HAPs from
existing RICE: NSCR for rich-burn engines and oxidation catalysts for lean-burn engines.
2.2.1.2 Prevalence of Controls Most Likely to Reduce HAPs
A breakdown, by subcategory, of emission controls which may reduce HAPs emissions for
existing RICE included in the ICCR Population Database, is provided in the table below.
Add-On Emission Controls for Existing RICE Which May Reduce HAPs Emissions
No. of
Add-on Controls Which May
Subcategory
Units
Reduce HAPs Emissions (%)
SI Natural Gas 4-Stroke Rich Burn
1,180
25% Catalytic Reduction
SI Natural Gas 4-Stroke Lean Burn
920
3% Catalytic Reduction
SI Natural Gas 2-Stroke Lean Burn
O
o
None
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No. of
Add-on Controls Which May
Subcategory
Units
Reduce HAPs Emissions (%)
SI Digester and Landfill Gas
150
None
SI Propane, LPG and Process Gas
150
1% Catalytic Reduction
SI Gasoline
200
None
CI Liquid Fuel
(diesel, residual/crude oil, kerosene/naphtha)
4,100
None
CI Dual Fuel
500
1% Catalytic Reduction
Emergency Power Units
5,700
None
Small Engines (200 bhp or less)
2,900
1% Catalytic Reduction
As shown above, 25% of existing RICE subcategorized as Spark Ignition, Natural Gas 4-Stroke
Rich Burn engines have NSCR controls installed. Therefore, the Committee recommends that
the best performing 12 percent of existing engines for the Spark Ignition, Natural Gas 4-Stroke
Rich Burn subcategory is represented by those engines using NSCR and that the MACT floor
for spark ignition natural gas 4-stroke rich burn engines should be based on NSCR.
As also shown in this table, less than 12 percent of the existing RICE in all other subcategories,
have installed add-on controls which may reduce HAPs emissions. Therefore, based on an
approach of examining the use of add-on controls which may reduce HAPs emissions, the
Committee is unable to identify a best performing 12 percent of existing RICE within these
other subcategories and recommends - based on this approach to identifying MACT floors - that
there is no MACT floor within these other subcategories.
2.2.2 Good Combustion Practices for RICE
The Committee also examined existing good combustion practices as an approach to identify
MACT floors (i.e., best performing 12 percent of RICE) by 1) researching and reviewing
possible good combustion practices for the purpose of HAPs reduction from RICE and 2)
assessing the prevalence of those practices by reviewing information available in the ICCR
Population Database, information from state air permitting authorities and the expertise of
stakeholders. As outlined below, the Committee was unable to identify a best performing 12
percent of engines within any subcategory using this approach and recommends - based on this
approach to identifying MACT floors - that there are no MACT floors.
2.2.2.1 Possible Good Combustion Practices
Practices that maintain good engine performance may lead to more complete combustion, and
therefore, may decrease the likelihood of increased HAP emissions that may be associated with
incomplete combustion or engine failure. In general, good engine performance is sustained by
proper engine operation, routine engine inspection and engine performance analyses, and, as
necessary, preventive maintenance. Most existing practices have been developed as a result of
economic incentives (to improve fuel efficiency and avoid costs associated with engine failure)
or as a result of air emission limitations for nitrogen oxides (NOx). Descriptions of existing
practices for engine operation, routine engine inspection and engine performance analyses, and
preventive maintenance are provided below. The effectiveness of existing practices for fuel
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efficiency or NOx emission reduction is well documented. However, the Committee has not
identified any data to link improved maintenance, inspection, and operating practices to reduced
HAP emissions. Also, specific recommendations for maintenance and operating practices are
engine-specific, site-specific, or both. Therefore, the Committee is unable to identify a best
performing 12 percent of existing engines within any subcategory using this approach of
considering the use of existing good combustion practices on HAPs emissions. Consequently,
the Committee recommends that there is no MACT floor based on the use of good combustion
practices for existing RICE.
2.2.2.1.1 Proper Engine Operation
"Operator" has been considered by the Committee as an individual whose work duties include
the operation, evaluation, and/or adjustment of the combustion system, i.e., internal combustion
engine. Both manufacturers and engine dealers conduct training schools to train dealer service
personnel to assess engine operation and maintain customer engines. Engine operators are
encouraged to participate in these schools.
Engine operation for stationary RICE differs depending on the type of engine, the engine's use,
the size of the engine, the level of automation and age of the unit. Engine operation for CI
engines is very different from engine operation requirements for SI engines. CI engines are
manufactured and adjusted at the factory to produce the requisite power. Power is achieved by
the proper selection of fuel system components, turbochargers, aftercooling, piston compression
ratio and fuel supply. These components are, in effect, a matched set designed to achieve the
desired engine performance, as well as to provide the reliability and durability demanded by the
customer. This matched set of components results in an essentially adjustment-free engine that
is ready to run when received by the customer. Procedures for starting and stopping the engine
are covered in an Operation Manual, as are maintenance requirements (described below). A CI
engine does not require an operator to evaluate and adjust the combustion system. In fact,
many CI engines operate unattended and may be started and stopped by remote control. The
engines are equipped with sensors to detect high coolant temperature, low oil pressure, and
excessive engine speed. When these sensors are tripped, the engine load will be reduced or the
engine will be shut down.
SI engines also are set in the factory, but user installations may require site-specific adjustments
depending on the type of fuel used and its heating value. The increased number of engine
variables associated with SI engines requires more frequent attention from an operator.
Periodic checks of the oxygen content in the exhaust are required to assure continued proper
engine operation. Manufacturers provide Operating Manuals that describe procedures for
measuring the oxygen content of the exhaust gas and adjusting the spark timing and air-to-fuel
ratio to achieve the correct oxygen levels for proper engine performance.
Many installations of RICE may not have an operator. Some installations may consist of a
single engine that is operated without supervision and maintained by trained service personnel
from the engine dealer. For installations involving a number of engines that may operate
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continuously, there will be personnel in attendance to monitor the engines' operation and follow
the maintenance plans developed for the specific engines and their type of operation and
conditions.
As mentioned above, the Committee has not identified any data to link operator training or
operating practices to reduced HAP emissions. The Committee is unable to identify a best
performing 12 percent of engines within any engine subcategory based on considerations of
operator training or engine operation. As a result, the Committee recommends that there is no
MACT floor based on the operator training or engine operation for existing RICE.
2.2.2.1.2 Routine Engine Inspection and Performance Analyses
All engine manufacturers provide their customers with recommendations about routine engine
inspection and performance analyses. Some examples of engine items related to engine
performance that should be inspected routinely are engine air cleaners, turbochargers, spark
plugs, valve lash, ignition systems, ignition coils and wiring, and aftercooler cores.
Manufacturers' recommendations for specific inspection/maintenance schedules may differ
depending on the design and size of engines and whether the engine is a CI engine or an SI
engine.
Some engine users develop site-specific programs of engine inspection and analyses to evaluate
engine performance. These programs generally have been developed as a result of economic
incentives, i.e., incentives to identify more closely when engine shutdown/maintenance is
required to sustain good engine performance. Many times engine users implement these site-
specific programs in lieu of the inspection/maintenance schedules recommended by the engine
manufacturer. Typical engine parameters that may be inspected in these site-specific programs
include temperatures, pressures, and fuel usage. Engine users rely on their extensive experience
with specific engines to develop these site-specific programs and to identify when changes in the
monitored parameters warrant engine shutdown for maintenance.
The Committee has not identified any data to link engine inspection or performance analysis to
reduced HAP emissions and the Committee is unable to identify a best performing 12 percent of
engines within any engine subcategory based on considerations of engine inspection or
performance analysis. As a result, the Committee recommends that there is no MACT floor
based on engine inspection or performance analysis for existing RICE.
2.2.2.1.3 Preventive Maintenance
All engine manufacturers provide their customers with preventive maintenance
recommendations. These recommendations specify a program of inspection and repair actions
that should be conducted before a failure occurs. The objective of this repair-before-failure
concept is to prevent most failures from ever occurring and to eliminate catastrophic events that
could permanently disable or destroy the unit. In general these recommendations are meant to
serve as a guideline to help the engine user keep the engine performing well. Also, engine
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owners may need to verify that preventive maintenance items have been conducted per the
manufacturer's recommendations in order to maintain the warranty for the engine. Therefore,
engine maintenance records are important. Accurate records can be used to determine
operating costs, establish maintenance schedules, and for other business decisions. Maintenance
records in some cases are required by air permitting authorities in order to document that the
engine is being maintained and that any required inspections are conducted at the proper
intervals.
Most engine owners implement some form of preventive maintenance program because it is a
well-documented fact that preventive maintenance programs provide the best return on
investment. A preventive maintenance program will ultimately reduce engine downtime because
the user can plan repairs and adjust his operation schedule accordingly. This not only permits
an operator to budget and control costs, but, in addition, the engine is maintained at optimum
operating conditions for best performance.
Some examples of engine items related to engine performance that should be inspected,
serviced, and/or replaced routinely are engine air cleaners, turbochargers, spark plugs, valve
lash, ignition systems, ignition coils and wiring, and aftercooler cores. Manufacturers'
recommendations for specific inspection/maintenance schedules may differ depending on the
design and size of engines and whether the engine is a CI engine or an SI engine. Engine
manufacturers provide Maintenance Manuals for their products that describe in considerable
detail what to maintain and how to perform the maintenance. Engine owners may train on-site
personnel to maintain an engine, or, in some cases, engine owners contract with the engine
dealer to provide a trained serviceman to perform the recommended maintenance rather than
training and having the work done by the owner's personnel.
One of the most extensive maintenance procedures for stationary RICE is engine overhaul. The
overhaul period of an engine is defined as the interval after which the major wear items in the
engine should be replaced. Many of the items that are replaced or rebuilt after this interval are
load sensitive and total fuel consumed may be used to determine the point of overhaul rather
than clock hours. Manufacturers provide information on how to adjust clock hours to account
for fuel used. Therefore, hours to overhaul are application-specific and are based on a user's
knowledge, experience, and records of operation.
The Committee has not identified any data to link preventative maintenance practices to reduced
HAP emissions. The Committee is unable to identify a best performing 12 percent of engines
within any engine subcategory based on considerations of preventative maintenance practises.
As a result, the Committee recommends that there is no MACT floor based consideration of
preventative maintenance practises for existing RICE.
2.2.2.2 Prevalence of Good Combustion Practices
The Committee reviewed the Population Database and the Emissions Database for inclusion of
"Good Combustion Practices." In the Population Database, the data fields that were reviewed
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included the "Combustor Operator Training" of the "Turbine & Engine (T&E) Information"
Table, and "Scheduled Shutdowns" and "Unscheduled Shutdowns" of the "Combustor Device -
General" Table. No information was found in any of these data fields. Similarly, the Emissions
Database did not include any references for good combustion practices for RICE. The gathered
source test reports in the Emissions Database were mainly conducted for compliance purposes
and did not include specific engine operating conditions, such as air-to-fuel ratio, ignition
timing, and maintenance information.
For existing engines, engine manufacturers have recommended schedules to evaluate engine
performance that vary by engine. In addition, users have developed inspection and maintenance
schedules based on site-specific conditions or experience using an engine for a specific
application.
State and local agencies known to have stringent regulations were contacted regarding "Good
Combustion Practices." These agencies included California, Florida, Texas, Louisiana, North
Carolina, Ventura County Air Pollution Control District, and South Coast Air Quality
Management District. None of the contacted agencies, except for Ventura County APCD and
Louisiana, have any requirements for good combustion practices for RICE. Instead, these
agencies' requirements concentrate on emissions monitoring rather than prescribed practices for
RICE.
Ventura County APCD Rule 74.9 includes a requirement for RICE operator inspection plans.
The rule requires a detailed maintenance procedure and inspection schedule for each engine and
emission control system. Inspections must occur either quarterly or after every 2000 hours of
engine run time; compliance source testing occurs annually. Inspection logs are also required.
Certain sources in Louisiana have requirements for inspection and maintenance of RICE as a
part of Title V permits. Louisiana allowed facilities to opt for the inspection and maintenance
requirements in lieu of semiannual testing requirements to demonstrate compliance with
emission limitations for criteria pollutants. The inspection and maintenance requirements are to
be performed semiannually and include the preparation of a report with complete performance
and condition analyses, adjustments made, and lists and dates for future repairs and/or
maintenance work. This report must be kept on-site.
Therefore, based on a review of the available information, the Committee identified existing
requirements for good combustion practices for only a few sources in two States: Louisiana
and California. In both cases, the source owners and operators establish an inspection and
maintenance plan that is site-specific and the content of the plan is negotiated with the air
permitting authorities. The plans are in place for criteria pollutants, such as NOx.
The Committee has not identified any data to link good combustion practices to reduced HAP
emissions. The Committee is unable to identify a best performing 12 percent of engines within
any engine subcategory based on considerations of good combustion practices. As a result, the
Committee recommends that there is no MACT floor based on considerations of good
III - 21
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combustion practices for existing RICE.
2.2.3 State Air Emission Regulations for HAPs
Based on a review of information available through the UATW and interviews with state air
permitting authorities from Alaska, California, Louisiana, North Carolina, and Texas, the
Committee was unable to identify any state air emission regulations that establish specific
emission limitations for HAP emissions from RICE units.
2.2.4 State Air Permit Limitations for HAPs
No air emission limits for HAPs from RICE were identified in either the RACT/BACT/LAER
databases or the UATW. Emission limits were only found for criteria pollutants such as NOx or
S02. Although HAP emission limits for 49 RICE were identified in the ICCR Population
Database, the Committee recommends that these permit limits do not identify a best performing
12 percent of existing RICE within any subcategory since:
1. There was insufficient information in the ICCR Population Database to allow the
Committee to properly subcategorize the units.
2. The HAP limits for the 49 engines are site-specific (all values are different) and it
is unclear whether the limits would be achievable for engines at other facilities.
3. It is unclear whether the permit limitations are based on emissions testing or on
the use of emission factors, such as AP-42.
4. The 49 engines represent less than 0.2 percent of all engines in the ICCR
Population Database.
2.2.5 Emissions
The Committee reviewed the ICCR Emissions Database for RICE and associated emissions test
reports to determine if the emissions data could be used for to identify MACT floors. Based on
a review of the available emissions information, the Committee recommends that the existing
emissions data are inadequate to identify a best performing 12 percent of existing RICE. In
addition, the Committee recommends that the existing emission data are also inadequate to
identify achievable HAPs emission limitations for existing RICE. The HAP emission levels
reported in the ICCR Emissions Database for RICE are highly variable. For example,
formaldehyde levels for natural gas-fired engines cover 6 orders of magnitude. This variability
could be attributed to two possible causes:
1. reported formaldehyde levels for lean burn and diesel engines may be artificially
low due to interference with DNPH-based test methods, and
2. emissions may be affected by the operating condition of the engine when tested.
The Committee carefully reviewed the test reports to determine if the variability could be
explained by the operating conditions of the engines and discovered that many of the test
III - 22
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reports lacked key information about engineering and operating parameters that could affect
HAP emissions. For example, the air-to-fuel ratio often was lacking, as was the as-tested
horsepower and speed. The Committee recommends that there is insufficient information in the
test reports to account for the unexplained variability in the emissions data included in the ICCR
Emissions Database for RICE. The Committee also notes that there are no existing HAPs
emissions data for a single engine that was tested over its entire envelope of operating
conditions.
Based on this review, the Committee identified key emissions data gaps, including the following:
1. the effect of operating conditions on emissions, and
2. the effectiveness of possible MACT control devices in reducing HAP emissions.
EPA also has noted the deficiencies in the ICCR Emissions Database for possible MACT
control devices. In an October 1, 1997 memorandum to the RICE Emissions Subgroup, EPA
staff noted that although there is some data in the database for before and after controls, the
data for NSCR "correspond to a limited number of pollutants and high detection limits (FTIR
with a 0.5 ppm detection limit)," and the data for oxidation catalysts have the following
limitations, "1) the unavailability of emission data necessary to estimate a representative control
efficiency, and 2) only a small portion of the pollutants were measured before and after
controls."
Consequently, the Committee recommends that the available emission data are insufficient to
identify a best performing 12 percent of existing RICE within any subcategory. Thus, based on
a review of the available HAPs emission data, the Committee recommends that there is no
MACT floors. Given the critical data gaps, the Committee recommends that additional
emissions data are needed to support the MACT rule development. The test plan developed
and recommended to EPA by the Committee would provide additional emissions data.
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ATTACHMENT IV
ICCR COORDINATING COMMITTEE
THOUGHTS ON
POLLUTION PREVENTION PLANNING REQUIREMENTS
OFFERED TO EPA FOR CONSIDERATION
JULY 28,1998
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POLLUTION PREVENTION PLANNING REQUIREMENTS
(Non-consensus)
Recommendation
The ICCR Coordinating Committee offers the thoughts contained in this document to
EPA for consideration in efforts to incorporate pollution prevention into the MACT standards
the EPA is charged with developing for combustion turbines, stationary internal combustion
engines, process heaters, industrial-commercial-institutional boilers, and non-hazardous solid
waste incinerators under Sections 112 and 129 of the Clean Air Act.
There were disagreements among Committee members on the thoughts outlined in this
document. Consequently, in reviewing and considering these thoughts, the Committee urges
the EPA to review and consider the discussion of this document by the Committee. This
discussion may be found in the minutes from the July 28 - 29, 1998, meeting of the ICCR
Coordinating Committee in Long Beach, California.
General Concept
This document does not identify specific pollution prevention measures or techniques to
consider. After much discussion, the Committee concluded that the feasibility of many pollution
prevention measures and techniques is often dependent on facility specific conditions or
circumstances. On the other hand, pollution prevention - as a concept - could be viewed as a
continuous and on-going process.
As a result, rather than focus on identification of specific pollution prevention measures
and techniques, the Committee decided to focus on identifying a way to include requirements in
regulations developed to limit HAPs emissions from combustion sources that would effectively
require facilities that operate these sources to implement a pollution prevention planing process.
The Committee's thoughts on Pollution Prevention Planning Requirements outlined in this
document are the result of this effort.
These requirements would require a facility to undertake a pollution prevention planning
process; they would not require a facility to implement any specific pollution prevention
measure or technique. In essence, these pollution prevention planning requirements would
require a facility to asses its operations related to combustion devices, identify potential
pollution prevention options, evaluate the feasibility of these options, and then repeat this
process periodically. Any decision to implement a specific pollution prevention option identified
and evaluated by the facility is left to the facility. Pollution prevention is often very attractive
from an economic viewpoint and a facility is most likely to identify and evaluate options which
offer the most attractive economic payback. Thus, a facility is highly likely to implement those
options it concludes are feasible.
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Rationale for Including Pollution Prevention (P2) Planning Requirements in
MACT Standards
EPA has identified pollution prevention as its guiding principle and preferred approach
for environmental protection. (EPA Administrator P2 Policy Statement, June 15, 1993)
Both the Pollution Prevention Act and Clean Air Act contain authority for this proposal
and such potential measures.
The right-to-know and components for public involvement and information are
cornerstones for effective environmental programs whether facility-based or government
mandated, in addition to fostering a proactive and responsible community spirit.
While the pollution prevention planning process and periodic reports are mandated,
implementation of identified prevention options are not required — thus sources can flexibly
direct resources to the best investment options or other priorities as needed to comply and to
fulfill other business obligations.
In-house corporate or facility programs along with other planning, permitting, or related
requirements may be folded-in with this proposed process and its required reports so that
duplication of effort is avoided.
The recommendation achieves the proper balance between broad guidelines for sources
with robust environmental programs in place, while including specific guidelines for those that
may require assistance to more thoroughly evaluate prevention opportunities with their sources.
Studies and documentation further substantiate the above statements and lend even
greater support by specifically identifying and tallying the return (cost benefit) of related
planning requirements:
"Average savings from reduction projects outweigh planning costs. Facilities that could
estimate their costs spent an average of $35,000 on planning activities; the cost per
facility drops to $13,000 when calculating planning costs using an average salary and
time figures provided by facilities. At the same time, facilities that predict cost savings
from their actions to reduce toxics use and NPO expect to save an average of $116.000
per year, including facilities that had not estimated actual savings. The average savings
is $66,000 for all facilities that were able to state whether they would save money
through planning." ("Evaluation of the Effectiveness of P2 Planning in NJ - A Program-
Based Evaluation", May 1996)
"80% considered the planning document to be beneficial to their study; 77% broke even
or had a net cost savings from P2 activities; 48% had a net cost savings of $40,000 or
greater." ("Is P2 Planning Beneficial in Texas", 1995)
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"From 1990-1997, total monetized TURA costs were $76.6 million; total monetized
benefits were $90.5 million (not including non-monetized benefits such as decreased risk
for workers, increased revenue from improvements in processes and products, value of
data to public data users, etc.)." ("Evaluating Progress — A Report on the Findings of
the Massachusetts Toxics Use Reduction Program Evaluation", March 1997)
"89% of the generators reported cost savings during the last three years. 66% reported
savings up to $25,000. 5% reported savings greater than $100,000 during the same
period." ("Report by the State Auditor of California - Review of the CDTSC's
Implementation of the Hazardous Waste Source Reduction and Management Review
Act of 1989", 1993)
Leading corporations, companies and associations recognize the importance and success
of prevention approaches and have public statements supporting programs similar to this
recommendation and its provisions:
"P2 Pays" (3M, among others)
"P2 is a multimedia concept that reduces or eliminates discharges to air, water, or land
and includes the development of more environmentally acceptable products, changes in
processes and practices, source reduction, beneficial use, and environmentally sound
recycling." (Industry Experience with P2 Programs, API)
"Candor in dealing with internal and external perceptions and expectations regarding
industry's environmental performance." (in reference to historically successful elements
of management support to overcome barriers to P2, Ibid)
"Once you put down how you are planning to manage and dispose of waste... that sets
the basis for how you do waste minimization, how you can look at alternatives." (p. 9,
Responding to Environmental Challenge, API)
"Earn the public trust" (p. ii, memo from CMA Chairman, The Year in Review 1995-
1996, Responsible Care Progress Report), "To recognize and respond to community
concerns about chemicals and our operations" (p. iii, Guiding Principle 1., Ibid)
"...the Pollution Prevention Code uses a hierarchy of pollution prevention activities that
include source reduction, recycle/reuse, energy recovery and treatment." (p. 5, Ibid, the
P2 Code is one of six management practices encompassing the Responsible Care
program)
"The need to stay internationally competitive will motivate continued gains in energy
efficiency." (CMA homepage)
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Recommended Consideration by EPA
The thoughts contained in this document are offered to EPA for consideration in the
development of pollution prevention planning requirements in the MACT standards developed
for combustion turbines, stationary internal combustion engines, process heaters, industrial-
commercial-institutional boilers, and non-hazardous solid waste incinerators under Sections 112
and 129 of the Clean Air Act. Specific regulatory language is attached. This is not intended to
imply that EPA should incorporate this language verbatim; EPA should determine what
pollution prevention planning requirements are appropriate for which source categories, and
consider the attached document accordingly, whether it be in whole, in part, or with revisions.
For example, EPA may conclude that certain types of assessments are not appropriate
for certain combustion devices. Alternatively, EPA may conclude that more detailed
assessments or specifics metrics for certain categories or subcategories of sources are
appropriate. It is intended that the table included in paragraph XX.XXO(d) be refined by EPA
to identify which assessments are required for which categories and/or subcategories of sources.
Likewise, EPA may decide to include specific compounds (i.e., HAPs) in the fuel
characterization assessment or may decide to exempt certain commercial fuels from the need for
a fuel assessment.
Although language is included in the attachment to address the applicability of these
requirements to source categories, it is the responsibility of EPA to determine to which
categories or subcategories of sources pollution prevention planning requirements should apply.
The EPA may wish to consider subcategories and de minimis levels in determining applicability.
Similarly, EPA may decide that pollution prevention planning be required for all units with
design capacities greater than a specific heat input level (i.e., MMBtu/hr).
IV-4
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POLLUTION PREVENTION PLANNING REQUIREMENTS
OVERVIEW
WHAT IS POLLUTION PREVENTION ?
Pollution prevention means "source reduction" as defined in the Pollution Prevention
Act, and other practices that reduce or eliminate the creation of pollutants through: increased
efficiency in the use of raw materials, energy, water, or other resources; or protection of natural
resources by conservation. The Pollution Prevention Act defines source reduction to mean any
practice which:
• reduces the amount of any hazardous substance, pollutant, or contaminant entering any
waste stream or otherwise released into the environment (including fugitive emissions)
prior to recycling, treatment, or disposal; and
• reduces the hazards to public health and the environment associated with the release of
such substances, pollutants, or contaminants.
Source reduction includes equipment or technology modifications, process or procedure
modifications, reformulation or redesign of products, substitution of raw materials, and
improvements in housekeeping, maintenance, training, or inventory control.
WHY IS POLLUTION PREVENTION IMPORTANT ?
For combustion devices, one may characterize pollution prevention in terms of
techniques which affect inputs to the combustion device, improve the performance of the
combustion device, or practices which conserve energy or utilize the energy produced more
efficiently. For example, switching to cleaner fuels, reducing the amount of waste generated
which would otherwise be combusted, increasing the energy conversion efficiency of a system,
and energy demand side management practices would all be considered pollution prevention.
A wide range of pollution prevention measures, methods, practices, and other
techniques are currently employed by sources within the scope of the ICCR effort. Pollution
prevention can reduce emissions of hazardous air pollutants and can also lead to non-air quality
health and environmental benefits. In many cases pollution prevention can reduce energy
consumption, lead to more efficient energy generation, or more efficient energy use. Pollution
prevention can result in cost savings, improve the corporate "bottom line" and may be more
cost effective than mandated command and control measures. Given the potential
environmental, as well as economic, benefits associated with pollution prevention, EPA has
identified pollution prevention as its guiding principle and preferred approach for environmental
protection. Finally, EPA has stated that incorporating pollution prevention requirements into
regulations is a high priority.
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OVERVIEW OF REQUIREMENTS
The pollution prevention planning requirements include the following steps:
T FORM A TEAM AND ESTABLISH OBJECTIVES
1. Form a team of interdisciplinary individuals with management participation. There is no
minimum size requirement for the "team".
2. Develop a statement of objectives for pollution prevention planning.
TT PERFORM ASSESSMENTS AND DRAFT POT J JITTON PREVENTION REPORT
3. Identify the appropriate assessments to perform. There are four types of assessments:
fuel, waste minimization, combustion device efficiency, and energy consumption. The
type(s) of assessments performed depend on the type of combustion device and
materials burned.
4. Perform assessments to identify pollution prevention options with the greatest potential
and evaluate these pollution prevention options.
5. Develop an implementation plan. Considering the results of all assessments, determine
which pollution prevention options — if any — are likely to be implemented. Develop an
implementation plan that includes the schedule for implementation of these pollution
prevention options.
6. Develop a draft Pollution Prevention Report that summarizes the results of the
assessments and includes the implementation plan for those pollution prevention options
the facility is likely to implement.
TTT PROVIDE AN OPPORTUNITY FOR PUBLIC REVIEW OF DRAFT POLLUTION
PREVENTION REPORT
7. Provide an opportunity for public review and comment on the draft Pollution Prevention
Report by making it publicly available.
8. Hold a public meeting, if one is requested.
TV FTN AT JZE POT JIJTTON PREVENTION REPORT
9. Respond to public comments and summarize the responses for inclusion in the final
Pollution Prevention Report.
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10. Develop a final Pollution Prevention Report that summarizes the results of the
assessments, includes an implementation plan, summarizes public comments, and
identifies any changes made to the assessments and/or the implementation plan.
11. Make the final Pollution Prevention Report available to the public.
VT REPORT STATUS AND REPEAT POLLUTION PREVENTION PLANNING
PROCESS
12. Make Status Reports publicly available once per year discussing progress made on the
implementation plan and a description of how and why the plan has changed, if
applicable.
13. Repeat process within 7 years or in conjunction with Title V permit renewal process.
After second final Pollution Prevention Report is made available to the public, repeat
process every five years.
KEY POINTS
A. OVERT,AP WTTH EXTSTTNG REQUIREMENTS AND PRACTICES
• These pollution prevention requirements are intended to work with existing pollution
prevention efforts and not create duplicative or redundant activities. For example, if a
facility already has a pollution prevention team or performs periodic pollution prevention
assessments, these activities can serve to satisfy the requirements.
• Likewise, if an owner or operator has many similar units located at different facilities,
some pollution prevention planning requirements — such as statement of objectives,
consideration of pollution prevention options, etc. — may be portable from one location
to another and can serve to satisfy these requirements.
• Flexibility is included in these requirements to allow facilities already submitting reports
of pollution prevention related activities, such as Toxic Release Inventory (TRI)
Reports, to adjust the scheduling of the reports necessary to satisfy these pollution
prevention planning requirements to match existing activities. Additionally, if sufficient
information is included in another report, that report may be submitted and serve to
satisfy some or all (as appropriate) of the reporting requirements included in these
pollution prevention planning requirements.
• EPA is encouraged to identify additional opportunities for consolidation of reporting
and recordkeeping activities.
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B. T JMTTS OF REQUIREMENTS AND COMPLIANCE
• These pollution prevention planning requirements require only that a facility undertake a
pollution prevention planning process and develop a Pollution Prevention Report. They
do not require facilities to implement specific pollution prevention options that may be
identified in this planning process.
• These requirements are based on the belief that it is not necessary to require pollution
prevention options to be implemented. If a pollution prevention option is found by the
facility to be attractive, the merits of the option will lead the facility to implement it.
Pollution prevention options often result in cost savings and thus provide an economic
incentive for implementation.
• The objectives of these requirements, therefore, are that a facility: (1) make a good faith
effort to undertake and complete a pollution prevention planning process, and (2) fulfill
certain reporting and recordkeeping requirements. Compliance with these pollution
prevention planning requirements will be determined on this basis alone.
• Local or State permitting authorities or State pollution prevention planning agencies or
offices may work with a facility or provide technical assistance and guidance to a
facility, as appropriate.
C. FOCUS OF ASSESSMENTS
• Pollution prevention planning is an on-going, continuous, iterative process. As a result,
it is not necessary or reasonable that all pollution prevention options be evaluated in the
first iteration. Pollution prevention options are numerous and not all are appropriate or
equally effective for all combustion devices. The objective is to identify those that hold
the most promise and evaluate their feasibility.
• Facilities may limit the focus of the assessments by considering only those options that
are most likely to be successful and have the greatest impact on emission reductions.
The provisions for periodic re-assessment will ensure that facilities continue to consider
pollution prevention options.
D. DETERMINATION OF FEASIBILITY
• The facility determines the technical applicability, costs, potential benefits, etc.
associated with pollution prevention options that the facility identifies in the
assessments.
• The facility determines which pollution prevention options are feasible for
implementation. In determining feasibility, a facility is encouraged to consider all
pollution prevention options identified in the assessments which are technically
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applicable and consider all factors the facility believes may affect the feasibility of
implementing these options, such as potential environmental benefits, relative
effectiveness, costs and potential savings, capital availability, resource constraints, and
other relevant factors.
E. DIFFERENCE BETWEEN A PLAN AND A REPORT
• An implementation plan is developed for those pollution prevention option(s) that are
determined by the facility to be feasible and will likely be implemented. The plan
identifies the actions to be taken to implement the option(s), a schedule for those
actions, and targets in terms of the anticipated effects on baseline metrics. A plan is not
necessary if the facility determines no pollution prevention options are feasible or likely
to be implemented.
• Two types of reports are made available to the public: Pollution Prevention Reports and
Annual Status Reports.
• The Pollution Prevention Report provides a summary of the assessments performed. If
pollution prevention options are determined by the facility to be feasible and will likely
be implemented, the report also includes the implementation plan mention previously
(e.g., a schedule for implementation and targets for improvements). The Pollution
Prevention Report is made available to the public even if no pollution prevention options
are likely to be implemented.
• The Annual Status Report provides the status of implementation of the plan, including
any major changes to the plan and progress made towards achieving targeted
improvements. Annual Status Reports are developed and made available to the public
even if a facility decides that no pollution prevention options are likely to be
implemented, in order to report on pollution prevention measures the facility may be
implementing outside a formal pollution prevention process and to encourage the facility
to periodically consider pollution prevention options.
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Paragraph XX.XXO - Pollution Prevention Planning Requirements
XX.XXO(a) What is pollution prevention?
Pollution prevention means "source reduction" and other practices that reduce or
eliminate the creation of pollutants through: increased efficiency in the use of raw materials,
energy, water, or other resources; or protection of natural resources by conservation.
Source reduction means any practice which: reduces the amount of any hazardous
substance, pollutant, or contaminant entering any waste stream or otherwise released into the
environment (including fugitive emissions) prior to recycling, treatment, or disposal; and
reduces the hazards to public health and the environment associated with the release of such
substances, pollutants, or contaminants. The term includes equipment or technology
modifications, process or procedure modifications, reformulation or redesign of products,
substitution of raw materials, and improvements in housekeeping, maintenance, training, or
inventory control.
XX.XXO(b) What facilities do these requirements apply to?
Any facility that operates a combustion device on-site which must comply with these
regulations must also comply with the pollution prevention planning requirements. Combustion
devices include boilers, reciprocating internal combustion engines, process heaters, incinerators,
and stationary combustion turbines.
XX.XXO(c) What steps do I take to comply with these requirements?
There are several steps to take to comply with these pollution prevention planning
requirements. These steps are to be completed by the dates specified in paragraph
XX.XXl(i)(l). Steps I and II are to be completed six months prior to the date by which Step IV
is completed. The steps to be implemented are outlined below and in Figure 1:
Step I - Form A Team And Establish Objectives
(1) Form a team. Form a team of individuals who will be responsible for ensuring
that the pollution prevention planning process is completed and that includes
management participation. There is no minimum size requirement for the team,
however, it is recommended that the team be composed of interdisciplinary individuals
with technical knowledge of the combustion device(s), associated processes, operation
and maintenance procedures, and the facility as a whole.
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Figure 1. General Steps Required for Pollution Prevention Planning
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(2) Develop a statement of objectives. Develop a statement of objectives which is
included in your Pollution Prevention Report. The statement allows you to clarify your
goals and overall approach for pollution prevention planning at your facility. The
statement needs to identify the objectives for pollution prevention planning, a qualitative
description of what is to be accomplished, and identify who will be responsible for
ensuring that this pollution prevention planning process will be completed.
Step II - Perform Assessments And Draft Pollution Prevention Report
(3) Determine the appropriate assessments to perform. Determine the appropriate
assessments to perform at your facility as specified in paragraph XX.XXO(d). There are
four types of assessments: a fuel assessment, a waste minimization assessment, a
combustion device efficiency assessment, and an energy consumption assessment. The
type of assessment(s) necessary depends on the type of combustion device(s) and the
materials burned. For example, you would perform a waste minimization assessment for
an incinerator burning cardboard and paper waste, but would perform a fuel
assessment, a combustion device efficiency assessment, and an energy consumption
assessment for a boiler burning residual oil.
(4) Identify option and perform assessments. Identify pollution prevention options
which may be applicable and perform the appropriate assessments as specified in
paragraphs XX.XXO(e), XX.XXO(f), XX.XXO(g), and XX.XXO(h) to determine the
technical applicability, costs, potential benefits, etc., of these options. Only processes
that are connected to combustion device inputs and outputs, or those that directly
impact the operation of a combustion device are included in the assessments.
For instance, if you generate energy from a steam boiler and the steam is used only to
power an on-site process line, you would perform an energy consumption
assessment for that process line, but not for any other energy consuming processes
for which you purchase energy. Assessments may be combined or consolidated if
multiple units burn common materials or provide energy to common on-site end
uses. Several resources and sources of guidance for pollution prevention
planning and assistance are provided in Appendix A.
(5) Develop an implementation plan. Evaluate the feasibility of implementing the
pollution prevention options assessed and decide which pollution prevention
options will likely be implemented. If pollution prevention options are likely to
be implemented, develop an implementation plan. Include the items specified in
paragraph XX.XXO(i) in the plan for each option likely to be implemented.
(6) Develop a draft Pollution Prevention Report. Develop a draft Pollution
Prevention Report which includes a summary of each assessment performed and the
implementation plan. All elements included in the draft Pollution Prevention Report are
listed in paragraph XX.XXl(a). Complete the draft Pollution Prevention Report no
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later than six months prior to the completion date specified in paragraph XX.XXl(i)(l).
Step III - Provide An Opportunity For Public Review Of Draft Pollution Prevention
Report
(7) Allow for public review and comment. Provide an opportunity for the public to
review and comment on your draft Pollution Prevention Report as specified in
paragraphs XX. XX 1(d) and XX. XX 1(e).
(8) Hold a public meeting. Hold a public meeting if one is requested through the
comments received, as specified in paragraph XX.XXl(f).
Step IV - Finalize Pollution Prevention Report
(9) Respond to public comment. Summarize your response to the comments
received from the public and include these with your final Pollution Prevention Report.
(10) Develop a final Pollution Prevention Report. Develop a final Pollution
Prevention Report, including the elements listed in paragraph XX.XXl(b).
(11) Make the final Pollution Prevention Report available to the public. Make the
final Pollution Prevention Report available to the public no later than one month after
the completion date specified in paragraph XX.XXl(i)(l).
Step V - Report Status And Repeat Pollution Prevention Planning Process
(12) Complete Annual Status Reports. Complete an Annual Status Report, including
the elements specified in paragraph XX.XXl(c) and make the Annual Status Report
available to the public as specified in paragraph XX.XXl(d) and XX.XXl(i)(3).
(13) Repeat the pollution prevention planning process. Repeat the pollution
prevention planning process so that a Pollution Prevention Report is made available to
the public approximately every five years, with the exception of the first and second final
Pollution Prevention Report. The schedule for repeating the process is flexible, as
specified in paragraph XX.XXl(i)(l), to allow activities to be coordinated with existing
pollution prevention related activities, other reporting requirements, and Title V
permitting schedules.
XX.XXO(d) How do I determine which assessments to perform?
The assessments to perform are based on the type of combustion device(s) operated on-
site and the type of material being burned in the device(s). Use the following table to determine
which assessments to perform:
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If you
operate a...
and if the unit burns...
you must perform...
a fuel
assessment?
a waste
minimization
assessment?
a
combustion
device
efficiency
assessment?
an energy
consumption
assessment?
process
heater
only non-waste
yes
no
yes
yes
process
heater
only waste
no
yes
yes
yes
process
heater
both waste and non-
waste
yes
yes
yes
yes
boiler
only non-waste
yes
no
yes
yes
boiler
only waste
no
yes
yes
yes
boiler
both waste and non-
waste
yes
yes
yes
yes
incinerator1
only waste
no
yes
no
no
incinerator1
both waste and non-
waste
yes
yes
no
no
reciprocating internal combustion engine
yes
no
yes
yes
stationary combustion turbine
yes
no
yes
yes
subcategory X
?
?
?
?
1 Note: Incinerator as the term is used above means a combustion device burning a waste without energy recovery. A
combustion device burning a waste with energy recovery is considered a boiler.
XX.XXO(e) How do I do a fuel assessment?
If applicable, perform a fuel assessment to determine if the fuel burned in the combustion
device(s) can be modified to decrease emissions. Include a general characterization of the fuel,
baseline metrics, current pollution prevention practices, options to reduce emissions, and an
evaluation of the feasibility of these options.
(1) Characterization. For each fuel burned, describe:
i. the composition and its variability
ii. rate of fuel combustion and its variability
iii. origins of the fuel
Note: The EPA may consider to refine this to include specific compounds or
constituents (i.e., HAPs, moisture content, etc.) in a fuel characterization assessment or
may consider exempting certain commercial fuels from the need for a fuel assessment.
(2) Establish baseline metrics. Calculate at least one of the following metrics or
another measurement that is representative of fuel combustion and is appropriate to
determine progress in implementing pollution prevention options:
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i.
emissions / time period
ii.
emissions / energy output
iii.
emissions / energy input
iv.
emissions / unit of fuel
v.
emissions / unit of production
vi.
amount of fuel / time period
vii.
amount of fuel / energy output
viii.
amount of fuel / unit of production
(3) Identify current pollution prevention practices. Identify any pollution prevention
practices associated with the fuel being burned that are currently in use.
(4) Identify pollution prevention options. Identify additional pollution prevention
options that may reduce emissions from fuel combustion by modifying or improving the
fuel. Examples of options include:
i. use of alternative fuels (fuel switching)
ii. pretreatment (reducing pollutants prior to combustion by reducing their
level in the fuel or improving the properties or characteristics of the fuel
to improve its combustion)
Facilities should identify those options which are most appropriate for the unit and the
facility and are most likely to be found feasible for implementation.
(5) Evaluate pollution prevention options. Evaluate the pollution prevention options
that have been identified to determine the following:
i. technical applicability
ii. cost to implement
iii. associated savings
iv. unique safety considerations
v. emission reductions
XX.XXO(f) How do I do a waste minimization assessment?
If applicable, perform a waste minimization assessment to determine if the waste burned
in the combustion device(s) can be modified or reduced to decrease emissions. Include in the
assessment a general characterization of the waste stream, baseline metrics, current pollution
prevention practices or waste minimization techniques, options to reduce emissions, and an
evaluation of the feasibility of these options.
(1) Characterization. For each waste stream, describe:
i. the composition and its variability
ii. rate of waste combustion and its variability, including whether
combustion is continuous or intermittent
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iii. origins of the waste (for example, the processes and raw materials that
the waste originated from)
Note: Certain State or other waste accounting reports may be sufficient to meet this
characterization requirement.
(2) Establish baseline metrics. Calculate at least one of the following metrics or
another measurement that is representative of waste combustion and is appropriate to
determine progress in implementing pollution prevention options:
i.
emissions / time period
ii.
emissions / energy output
iii.
emissions / energy input
iv.
emissions / unit of waste
v.
emissions / unit of production
vi.
amount of waste burned / time period
vii.
amount of waste burned / energy output
viii.
amount of waste burned / unit of production
(3) Identify current pollution prevention practices. Identify any pollution prevention
practices associated with waste minimization that are currently in use.
(4) Identify pollution prevention options. Identify additional pollution prevention
options that may reduce emissions from waste combustion by reducing or modifying the
waste. Examples of options include:
i. source reduction, such as changes to product (for example, substitution,
reformulation, or conservation), changes to input materials (for example,
substitution or purification), changes to process, or changes to operating
practices (for example, loss prevention and waste segregation)
ii. recycling, such as returns to process, use in other processes, or
implementation of a resource recovery process
iii. alternative disposal methods
iv. development of a waste tracking/accounting system to reveal additional
or uneasily identifiable options for reducing emissions, such as a gradual
phase down of specified components or toxic constituents in the waste
feed stream (for example, maintain a log for characterizing and
documenting the waste feed stream on a regular basis)
Facilities should identify those options that are most appropriate for the unit and the
facility and are most likely to be found feasible for implementation.
(5) Evaluate pollution prevention options. Evaluate the pollution prevention options
that have been identified to determine the following:
i. technical applicability
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ii. cost to implement
iii. associated savings (for example, consider raw material value, waste
conversion costs, disposal costs, operational costs, and savings from
other processes made more efficient by the reduction in waste)
iv. unique safety considerations
v. emission reductions
vi. impact on other media (for example, soil and water)
XX.XXO(g) How do I do a combustion device efficiency assessment?
If applicable, perform an assessment to determine the efficiency of combustion device
operations. The assessment includes a general characterization of each combustion device,
baseline metrics, current pollution prevention practices, options to reduce emissions by
improving device efficiency, and an evaluations of the feasibility of these options.
(1) Characterization. For each combustion device, describe:
i. current maintenance practices
ii. methods used to capture or recover heat generated by the combustion
device
iii. methods used to generate steam from the combustion device
iv. methods used to generate electricity from steam generated from the
combustion device
(2) Establish baseline metrics. Calculate at least one of the following metrics or
another measurement that is representative of device efficiency and is appropriate to
determine progress in implementing pollution prevention options:
i. emissions / time period
ii. emissions / energy output
iii. emissions / unit of production
iv. energy input / energy output
v. amount of fuel / energy output
(3) Identify current pollution prevention practices. Identify any pollution prevention
practices associated with combustion device efficiency that are currently in use.
(4) Identify pollution prevention options. Identify additional pollution prevention
options that may reduce emissions by improving device efficiency. Examples of options
include:
i. improved energy recovery capabilities (for example, use of alternative
steam system design and operation to improve efficiency or employ
steam-electric cogeneration)
ii. improved combustion device efficiency through work practices, such as
developing or modifying operator training programs to implement good
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combustion practices and maintenance
iii. minimizing heat loss (for example, use insulation and recover waste heat
where possible)
Facilities should identify those options that are most appropriate for the unit and the
facility and are most likely to be found feasible for implementation.
(5) Evaluate pollution prevention options. Evaluate the pollution prevention options
that have been identified to determine the following:
i. technical applicability
ii. cost to implement
iii. associated savings (for example, perform an economic analysis to
determine long range savings which might justify process or equipment
changes)
iv. unique safety considerations
v. emission reductions
XX.XXO(h) How do I do an energy consumption assessment?
If applicable, perform an energy consumption assessment to determine if the energy
produced on-site and consumed on-site by the combustion device(s) is efficiently utilized. Only
on-site energy consumption produced by on-site combustion device(s) which must comply with
these regulations need to be included in this assessment. You are not required to evaluate the
use of energy that is produced on-site, but consumed off-site; similarly, you are not required to
evaluate the use of energy produced off-site, but consumed on-site. Include in the assessment a
general characterization of energy use and the processes associated with energy production,
baseline metrics, current pollution prevention or energy conservation practices, options to
reduce energy consumption, and an evaluation of the feasibility of implementing the energy
efficiency opportunities or conservation measures.
(1) Characterization. For each combustion device, describe:
i. on-site end uses for the energy generated (for example, process heating
and cooling, space heating and cooling, lighting, mechanical drives, and
other consumption or losses)
ii. processes associated with energy production and distribution
(2) Establish baseline metrics. Calculate at least one of the following metrics or
another measurement that is representative of energy utilization and is appropriate to
determine progress in implementing pollution prevention options:
i. emissions / time period
ii. emissions / unit of production
iii. amount of fuel / time period
iv. amount of fuel / unit of production
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v. Btu consumption/square feet/time period (energy utilization index)
(3) Identify current pollution prevention practices. Identify any pollution prevention
practices or energy conservation measures associated with energy efficiency that are
currently in use.
(4) Identify pollution prevention options. Identify additional pollution prevention
options that may reduce emissions through energy efficiency opportunities, energy
conservation measures, or operation and maintenance procedures. Examples of options
include:
i. reduced peak loads or load shifting (for example, modify periods when
equipment is operating unnecessarily or inefficiently)
ii. energy conservation measures (for example, demand side management,
increased building insulation, etc.)
iii. installation of energy efficient technologies (for example, upgrade
lighting, heating, or cooling systems)
iv. process changes (for example, modifications to equipment, process
heating, or process cooling)
v. maintenance and tune-ups of building systems to operate at designed
efficiencies (for example, changing filters and calibrating controls)
vi. installing electric meters on building systems to monitor variations in
energy use
vii. improved steam management and utilization (for example, consider steam
distribution/condensate return opportunities, eliminate or find a use for
vented steam, or use steam at its lowest possible pressure for heating)
viii. develop or improve current maintenance programs (for example,
minimize leaks, calibrate instruments and controls, and maintain steam
traps)
Facilities should identify those options that are most appropriate for the unit and the
facility and are most likely to be found feasible for implementation.
(5) Evaluate pollution prevention options. Evaluate the pollution prevention options
that have been identified to determine the following:
i. technical applicability
ii. cost to implement
iii. energy cost savings (based on life-cycle cost and interactions between the
energy conservation measures)
iv. opportunities to participate in public/private partnerships, such as Energy
Star, Green Lights, Steam Challenge, or Motor Challenge
v. unique safety considerations
vi. emission reductions
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XX.XXO(i) How do I develop an implementation plan?
(1) Determine which pollution prevention options will likely be implemented.
Considering all of the pollution prevention options identified through all of the
assessments, evaluate the feasibility of implementing those options considered
technically applicable. Based on the results of this feasibility analysis, decide which
pollution prevention options will likely be implemented. The following should be taken
into consideration in evaluating feasibility:
i. capital availability
ii. resource constraints (for example, employee availability limitations)
iii. relative effectiveness of options identified (for example, compare the
effectiveness of two options in terms of cost per pound of pollutant
reduced)
iv. other relevant factors
(2) Develop a plan to implement the options identified. Develop a plan to implement
the pollution prevention options that are likely to be implemented, including for each
pollution prevention option likely to be implemented:
i. identification of the pollution prevention option
ii. a schedule for implementing the pollution prevention option
iii. targets for improvement in terms of the baseline metric(s) and related to
the implementation schedule
Paragraph XX.XX1 - What Do I Report?
Prepare a Pollution Prevention Report and Annual Status Reports.
XX.XXl(a) What does the draft Pollution Prevention Report include?
Include in the draft Pollution Prevention Report:
(1) Pollution prevention statement of objectives.
(2) A summary of the assessments performed, identifying:
i. the combustion device
ii. type of assessments performed (fuel, waste minimization, control device
efficiency, and/or energy consumption)
iii. metrics that will be used to measure progress in implementing pollution
prevention options and baseline values of those metrics
iv. pollution prevention options identified
(3) The implementation plan, which includes, for each pollution prevention option
likely to be implemented:
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i. identification of the pollution prevention option
ii. a schedule for implementing the pollution prevention option
iii. targets for improvement in terms of the baseline metric(s) and related to
the implementation schedule
(4) A brief explanation of the results of the feasibility analysis that led to your choice
of pollution prevention options to implement.
XX.XXl(b) What does the final Pollution Prevention Report include?
Prepare a final Pollution Prevention Report considering both written public comments
and comments received at the public meeting, if one is held, including:
(1) Pollution prevention statement of objectives.
(2) A summary of the assessments performed, identifying:
i. the combustion device
ii. type of assessments performed (fuel, waste minimization, control device
efficiency, and/or energy consumption)
iii. metrics that will be used to measure progress in implementing pollution
prevention options and baseline values of those metrics
iv. pollution prevention options identified
(3) The implementation plan, which includes, for each pollution prevention option
likely to be implemented:
i. identification of the pollution prevention option
ii. a schedule for implementing the pollution prevention option
iii. targets for improvement in terms of the baseline metric(s) and related to
the implementation schedule
(4) A brief explanation of the results of the feasibility analysis that led to your choice
of pollution prevention options to implement.
(5) A summary of the public comments received during the comment period and at
the public meeting, if one was held, and your responses to these comments.
(6) A discussion of how the assessments and/or the implementation plan have
changed from the draft report, if changes have been made.
XX.XXl(c) What do the Annual Status Reports include?
Include in the Annual Status Report:
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(1) A summary on the status of the implementation plan included in the
Pollution Prevention Report, including a brief discussion of major changes to
implementation of the plan. This discussion should include reasons why options
previously identified as likely for implementation are not being implemented or
are no longer considered feasible.
(2) Progress made towards achieving targeted improvements, expressed in
terms of metrics identified in the Pollution Prevention Report. For example, a
facility may determine that approximately 100 tons per day of waste were burned
before pollution prevention options were implemented. The facility may set a
target to reduce waste burned to 50 tons per day over five years in the Pollution
Prevention Report. In the Annual Status Report, the facility may state that, after
one year of implementing a pollution prevention option, they are burning 75 tons
of waste per day.
(3) A summary of other benefits realized. Types of benefits may include
environmental (for example, reduced energy consumption, reduced waste
disposal, reduced waste generation, or emission reductions) and financial (for
example, savings in disposal costs or savings in energy costs).
XX.XXl(d) How do I make my reports available to the public?
Make the draft Pollution Prevention Report, final Pollution Prevention Report, and
Annual Status Reports available to the public upon written request to anyone who lives in the
city or county or parish in which the facility is located and by at least one of the following
options or another option that ensures public access to the reports:
(1) Maintain current versions of reports in a public place in the county in which the
facility is located (Tor example, at a public library, municipal government building, or
post office),
(2) Maintain current versions of reports and allow public viewing copies on-site.
(3) Maintain current versions of reports on an Internet site.
XX.XXl(e) How do I allow for public review of my draft Pollution Prevention Report?
(1) Make the draft report available. Make the draft Pollution Prevention Report
available to the public as specified in paragraph XX.XXl(d) no less than six months
prior to the completion date specified in paragraph XX.XXl(i)(l).
(2) Notify public that draft report is available. Publish a notification that the draft
Pollution Prevention Report is available for public review in the principal newspaper(s)
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serving the area in which your facility is located no less than six months prior to the
completion date specified in paragraph XX.XXl(i)(l). Include in the notification:
i. the locations where the draft report may be reviewed
ii. the address to which members of the public may send written requests for
a copy of the draft report
iii. the dates that the public comment period on the draft report begins and
ends (you must allow a minimum of 30 days for the comment period) and
an address where written comments can be submitted
iv. a statement that a public meeting will be held to discuss the draft report if
one is requested in writing during the public comment period
(3) Submit draft report. Submit a copy of the draft report to the State air pollution
control agency, unless otherwise designated by the agency. Also, provide a copy to the
State or local pollution prevention office, if such an office exists.
XX.XXl(f) What do I do if the public requests a meeting?
If a public meeting is requested through the comments received, take following steps:
(1) Notify public of meeting. Publish a notification of the public meeting in the
principal newspaper(s) serving the area in which your facility is located and notify
directly those individuals who submitted comments during the public comment period
(where notification is possible based on the written comment submitted) no later than 14
days prior to the public meeting. Include in the notification:
i. the date, time, and location of the meeting
ii. an agenda that shows the approximate amount of time that each
individual who requested a public meeting will be provided to speak and
the approximate amount of time that will be provided for others who may
wish to speak
(2) Conduct a public meeting. Conduct a public meeting in the city or county or
parish in which your facility is located. An individual representing the facility must
conduct the public meeting and it is recommended that the facility manager or a
supervisor attend the meeting, as well as representatives from the team formed, to
ensure the pollution prevention planning process was completed.
XX.XXl(g) Do Title V public participation requirements satisfy these requirements?
If a facility chooses to align its pollution prevention planning process with its Title V
reauthorization timeline, the public participation requirements associated with the Title V
process may serve to satisfy the requirements of paragraph XX.XXl(d, e, f, and h).
XX.XXl(h) How do I make the final Pollution Prevention Report available to the
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public?
(1) Make the final report available. Make the final Pollution Prevention Report
available to the public as specified in paragraph XX.XXl(d) no later than one month
following the completion date specified in paragraph XX.XXl(i)(l).
(2) Notify public that final report is available. Notify the public that the final
Pollution Prevention Report is available in the principal newspaper(s) serving the area in
which your facility is located no later than one month following the final pollution
prevention report completion date. Include in this notification the locations where the
final report may be viewed and the address to which members of the public may send
written requests for a copy of the final report. Also notify those individuals who
submitted comments on the draft Pollution Prevention Report and/or attended the public
meeting, if one was conducted, by mail (electronic or postal) that the final report is
available.
(3) Submit final report. Submit a copy of the final report to the State air pollution
control agency, unless otherwise designated by the agency. Also, provide a copy to the
State or local pollution prevention office, if such an office exists.
XX.XXl(i) When do I repeat this pollution prevention planning process?
(1) Final Pollution Prevention Report. Repeat the process and comply with these
pollution prevention planning requirements so that a final Pollution Prevention Report is
made available to the public at least every five years, with the exception of the first and
second Pollution Prevention Report. To allow facilities to adjust this pollution
prevention planning process to coincide with Title V permitting requirements, additional
time is allowed for completion of the second final Pollution Prevention Report. The
following completion dates are the dates by which the final Pollution Prevention Reports
are to be completed:
Final Pollution Prevention
Report
Completion Date
First Report
No more than three years after the promulgation date of this
regulation
Second Report
No more than seven years after completion of first final report
or at the same time your Title V permit renewal application is
submitted
Third and Subsequent Reports
No later than five years after completion of the previous final
report
(2) Repeat process periodically. This pollution prevention planning process may be
repeated more frequently and may be conducted in conjunction with other planning
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requirements or as part of a systematic quality or environmental performance review that
includes the combustion device. Repeating the process includes all the steps taken to
produce your first Pollution Prevention Report and outlined in paragraph XX.XXO(c),
and completing Steps I and II six months prior to the final report completion date.
(3) Annual Status Reports. Complete an Annual Status Report every year following
completion of a final Pollution Prevention Report.
Paragraph XX.XX2 - Pollution Prevention Recordkeeping Requirements
XX.XX2(a) What records do I keep?
The following documents must be maintained and made available upon request to the
State air pollution control agency, unless otherwise designated by the agency, and to the State
or local pollution prevention office, if such office exists:
(1) Results of assessments. Retain the results of the most recently completed
pollution prevention assessments at your facility, including the results of characterizing
the combustion device, identifying existing pollution prevention options, identifying
pollution prevention options, and evaluating pollution prevention options.
(2) Results of feasibility analyses. Retain the results of the feasibility analyses used
to determine which pollution prevention options are likely to be implemented.
(3) Reports. Retain a copy of the following reports at your facility:
i. the most recent draft Pollution Prevention Report
ii. the most recent final Pollution Prevention Report
iii. Annual Status Reports completed during the previous five years
XX.XX2(b) How long do I keep the records?
(1) Draft Pollution Prevention Reports. Retain a copy of the most recent draft
Pollution Prevention Report until the next draft Pollution Prevention Report is
completed.
(2) Final Pollution Prevention Reports. Retain a copy of the most recent final
Pollution Prevention Report until the next final Pollution Prevention Report is
completed.
(3) Annual Status Reports. Retain Annual Status Reports for at least five years.
(4) Results of assessments. Retain the results of the most recently performed
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assessments described in paragraph XX.XX2(a)(l) until new assessments are completed.
(5) Results of feasibility analysis. Retain the results of the most recently performed
feasibility analysis described in paragraph XX.XX2(a)(2) until a new analysis is
completed.
Paragraph XX.XX3 - Determination Of Compliance
XX.XX3(a) How will compliance be determined?
(1) Assessment of compliance. Compliance with these requirements will be assessed
through review of the reports developed by the facility and the records maintained by the
facility to determine if:
i. the facility made a good faith effort to undertake and complete a
pollution prevention planning process, as described in these requirements
ii. the facility provided the public an opportunity to review the reports and
held a public meeting, if one was requested by the public
iii. the facility fulfilled the requirements associated with reporting and
recordkeeping
(2) Determination of compliance. Compliance with these requirements will be
determined by:
i. the State air pollution control agency, unless otherwise delegated by the
agency, or
ii. the U.S. Environmental Protection Agency, if the State air pollution
control agency does not accept delegation of authority to determine
compliance with these regulations
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Appendix A
Resources for Pollution Prevention Planning
Initial list of information providers and services. There are a number of government
assistance programs that provide information and services to assist with pollution
prevention planning. Listed below are a few select contacts where further information
or more specific (e.g., local) contact information may be obtained.
EPA Pollution Prevention Information Clearinghouse
National Pollution Prevention Roundtable
Regional P2Rx Centers
State P2 programs
SBA Small Business Development Centers
CAA State Small Business Assistance Programs
NIST Manufacturing Extension Partnership
EPA Energy Star Buildings
DOE
FEMP
State Energy Commissions, Energy Efficiency and Renewable Offices
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Pollution Prevention Planning Requirements:
Areas of Concern and Non-Consensus
Over the past two years EPA has made pollution prevention (P2) one of its top priorities and is
working to incorporate pollution prevention into existing regulatory and non-regulatory
programs. Industry considers pollution prevention an important initiative because it provides
opportunities for (1) improving the environment, (2) developing cost-effective solutions, and (3)
eliminating the need for additional command and control regulations.
In order to accomplish the goals of pollution prevention, EPA and industry must work
cooperatively to create a flexible process which recognizes practical limitations and economic
considerations of business. Critical to the success of pollution prevention is the recognition that
processes differ between industries and individual facilities that a "one size fits all" approach is
not appropriate. Industry supports the incorporation of a P2 planning process in those portions
of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) to be
promulgated for ICCR sources, that are found to meet the statutory requirements applicable to
Maximum Achievable Control Technology (MACT) rules.
The above thoughts on Pollution Prevention Planning Requirements do not completely reflect
some of the concerns industry representatives identified during Committee discussions.
Consequently, the industry representatives do not support the inclusion of the above thoughts
on Pollution Prevention Planning Requirements in any mandatory regulatory scheme. Some
specific concerns are listed below:
Document should be a Guidance and not a Requirement - Pollution Prevention planning
should be undertaken under a flexible framework that allows for facility-specific
assessments. The specific and rigid nature of the thoughts outlined above would result in
the consumption of resources in the planning process, rather than be more productively
allocated to the implementation of prevention measures.
Process should be Voluntary or Linked to Alternative Compliance - The ICCR rules
should provide incentives to encourage the voluntary evaluation and implementation of P2
based solutions. In developing a broad and overarching pollution prevention process for
ICCR sources, consideration should be given to making it voluntary and/or linking it to an
alternative compliance scenario. As currently written, the above thoughts provide no
recognition or relief for those facilities which have already voluntarily assessed, and in many
cases implemented, P2 efforts.
Mandatory P2 Planning should meet Legal Requirements of the CAA - Regulatory
options requiring P2 Planning could be incorporated into MACT standards for the ICCR
subcategories only to the extent that the required planning elements are part of the 'MACT
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Floor' or are shown to be cost-effective, in the context of all the requirements of Section
112(d) of the Clean Air Act (CAA). The above thoughts do not make it clear that these
legal requirements must be satisfied.
Document Presented Could Impose Substantial Legal Liability - The P2 planning
process, as outlined in the above thoughts, includes numerous, detailed elements. If all
these detailed elements were made regulatory requirements, any effort by an applicable
source to tailor the process to the site-specific needs of its own facility could result in non-
compliance and potential legal liability. Because P2 is so specific to particular facilities, we
believe it is unwise—as well as dangerous from a liability standpoint—to impose prescriptive
requirements.
P2 Planning Process Outlined Is Cumbersome - The general process outlined in the
above thoughts is both cumbersome and resource intensive with uncertain environmental
benefits. In particular, the public participation process outlined goes well beyond a mere
public notification, normally associated with facility permits, by requiring facilities to
respond and resolve public concerns — normally done in the context of a pre-construction
permit — and not when the intended regulatory compliance is the completion of a P2
Planning Report.
• Initial and On-Going Reporting Requirements Are Burdensome - The implied level of
detail in the initial planning report, as well as requiring a continuous process of status
updates and new planning cycles is unprecedented in MACT rules, it potentially establishes
an 'ever-moving-target' for facilities' compliance. In addition, it has been noted before in
the context of P2 planning initiatives around the country that simplified and consolidated
reporting requirements for various regulatory mandates should be encouraged so that
resources would be available for work at preventing pollution rather than merely reporting
on it. Finally, it is unlikely that the burdens associated with these planning requirements
meet the objectives of the Paperwork Reduction Act.
In conclusion, industry would like to re-iterate that we support the creation of a voluntary and
flexible pollution prevention framework, which can be a Win-Win process to encourage
enhanced environmental protection while reducing regulatory burden. Industry representatives
will be available to further discuss these concerns with the US EPA in any appropriate forum.
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ATTACHMENT V
ICCR COORDINATING COMMITTEE
THOUGHTS ON
ALTERNATIVE COMPLIANCE - FLEXIBLE PERMITTING
OFFERED TO EPA FOR CONSIDERATION
JULY 28, 1998
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Alternative Compliance - Flexible Permitting
(Non-Consensus)
Recommendation
The ICCR Coordinating Committee offers the thoughts contained in this document to EPA for
consideration in the Title V permitting process. These thoughts offer for consideration review
and approval of site specific compliance alternatives associated with ICCR MACT rulemakings.
There were disagreements among Committee members on the thoughts outlined in this
document. Consequently, in reviewing and considering these thoughts, the Committee urges
EPA to review and consider the discussion of this document by the Committee. This discussion
may be found in the minutes from the July 28 - 29, 1998 meeting of the ICCR Coordinating
Committee in Long Beach, California.
Background
The alternative emission standard as defined in the General Provisions (40 CFR 63.2) currently
available is limited to those cases where EPA has determined that an emission standard cannot
be prescribed or enforced for a specific pollutant and, therefore, is not generally applicable to
ICCR sources. Federal Register proposal and rulemaking is also required as part of the
approval process, which makes this option very time-consuming and cumbersome.
While it would be preferable to include the thoughts outlined below in the ICCR regulations
instead of revisions to the Title V permitting process, EPA staff have indicated that provisions
impacting the Title V permitting process need to be handled through Title V rule revisions. The
flexibility provided by using this approach could allow facilities to invest in those areas of plant
operations where the most real environmental benefits could be achieved. To make this option
practical, it is important that the Title V permitting process be used as the mechanism for review
and approval of the compliance alternatives.
The Committee has devoted substantial resources to researching and compiling P2 techniques
which achieve environmental benefits through (1) modifying how a combustion unit is operated,
(2) affecting certain combustion feedstreams, or (3) reducing the energy requirements on the
unit, e.g., by conserving or using the energy outputs more efficiently. These techniques could
provide environmental benefits and reduce the burden and cost of compliance at ICCR affected
facilities. Numeric MACT emission standards are commonly established and expressed in terms
or units which might limit the benefits of using Pollution Prevention techniques toward
achieving compliance.
In a separate document ("Options For ICCR MACT Rules"), the Committee also offers
thoughts to EPA for consideration that MACT emission limit options for specific pollutants be
included in ICCR MACT standards where EPA determines that the data supports establishment
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of a numeric emission limit for those pollutants. However, it is recognized that all possible
combinations or specific situations cannot be accommodated with options identified during the
MACT development process.
The Clean Air Act includes provisions to allow a source owner or operator to demonstrate
alternative means to achieve compliance with a promulgated MACT standard [Section
112(h)(3)], A definition of "alternative emission standard" based on Section 112(h)(3) is
incorporated into EPA's General Provisions for MACT standards at 40 CFR 63.2. However,
this alternative emission standard is limited to those cases where EPA has determined that an
emission standard cannot be prescribed or enforced for a specific pollutant. Because most
ICCR units are point sources (not fugitive emission sources), this greatly restricts the
applicability of this provision. Even if this provision were not limited in this way, the alternative
emission standard procedure, which requires EPA Federal Register notice and rulemaking as
part of the approval process, is overly cumbersome and time-consuming given the limited
compliance deadlines of MACT standards.
This thoughts contained in this document and the document Options For ICCR MACT Rules
mentioned above are not meant to either interpret or replace the Section 112(h)(3) provisions
for alternative emission standards. The thoughts in this document outline an additional
mechanism for owners and operators to demonstrate and gain approval of alternative
compliance approaches which are designed to encourage the use of P2 as a means of
compliance with MACT, but which are not specifically addressed in the ICCR rules.
The thoughts in this document are offered to EPA for consideration relative to the Title V
permitting process. These thoughts would allow the source owner or operator to outline an
approach for demonstrating compliance using a pollution prevention based alternative and
submit it as part of the Title V permit application. The details of alternative compliance
monitoring and recordkeeping would be approved through the Title V permitting process. By
using the Title V permitting process, owner or operator could work closely with permitting
authorities that are familiar with the facility and the process to determine an appropriate
compliance alternative. In addition, the Title V permitting process would provide an
opportunity for EPA and the public to offer comments/input on the proposed compliance
alternative. The approach requires that compliance with the alternatives be quantifiable,
accountable, enforceable, and based on reproducible procedures.
Definitions
Pollution prevention means "source reduction" and other practices that reduce or eliminate the
creation of pollutants through: increased efficiency in the use of raw materials, energy, water,
or other resources; or protection of natural resources by conservation.
Source reduction means any practice which: reduces the amount of any hazardous substance,
pollutant, or contaminant entering any waste stream or otherwise released into the environment
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(including fugitive emissions) prior to recycling, treatment, or disposal; and reduces the hazards
to public health and the environment associated with the release of such substances, pollutants,
or contaminants. The term includes equipment or technology modifications, process or
procedure modifications, reformulation or redesign of products, substitution of raw materials,
and improvements in housekeeping, maintenance, training, or inventory control.
"Input changes" include modifications to fuel/waste stream input feed rate or composition or
other actions which result in reductions in emissions of pollutants regulated under this rule. An
example of this would be elimination or reduction of a specific waste stream or conversion to a
cleaner burning fuel.
"Output changes" include reductions in energy or capacity demand that result in the combustion
of less fuel or waste and thereby reduce emissions of pollutants regulated under this rule. These
can also include operational or equipment changes which increase device efficiency. Examples
of this would be proper installation and maintenance of steam traps, insulation of buildings and
steam lines, or installation of an economizer on a steam boiler.
Applicability
Alternative compliance provisions should be available to owners or operators who are subject to
ICCR MACT standards where the MACT standard includes specific emission limits for control
of pollutants regulated under this rule.
Principles
1. Input and/or output changes may be used in achieving compliance with emission limitations
or reductions as an alternative to simply meeting the MACT standard control requirement by
application of combustor control techniques.
2. Sources may demonstrate compliance by using a combination of compliance approaches
including any combination of input and/or output changes and combustion device-specific
control measures.
Permitting Process
1. Selection, development and proposal to the permitting agency of compliance alternatives are
the responsibility of the owner or operator of the affected unit. Explanation of and justification
for the metric or basis used, the input and/or output changes selected, and demonstration of
equivalency and environmental benefits are examples of information which must be included in
the proposal submitted by the owner or operator.
2. Alternatives must be measured over the same timeframe in which the associated MACT
standard is expressed in order to determine equivalency. Mass per unit time is considered a
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preferred basis, but specific source categories could have other bases considered appropriate for
the category. A basis of lbs/yr may be appropriate for chronic-effect HAPs whereas another
metric (e.g., shorter time period) may be more appropriate for acute-effect HAPs.
3. The permitting agency would issue a Title V permit (or a revision to an existing Title V
permit) that includes an alternative emission limit, if determined by the permitting agency to be
equivalent to, or more stringent than, that contained in the applicable requirement and provided
there are greater overall environmental benefits as shown by the environmental impact
evaluation.
4. Approval of the compliance alternative shall be accomplished as part of the facility's Title V
air permit approval process. The Title V approval process provides opportunity for public
comment, EPA oversight, and expedited approval.
Compliance. Monitoring, and Recordkeeping
1. Methods for demonstrating compliance, including recordkeeping requirements are to be
developed and proposed to the permitting agency by the owner or operator of the affected unit
for review and approval.
2. The alternative emissions limit must be quantifiable, accountable, enforceable, and based on
reproducible procedures.
Aggregation of Sources
1. For the purposes of this compliance alternative, the owner or operator of Section 112
regulated sources under this rule may aggregate emissions of pollutants from those sources
which are under common control at a single site.
2. This aggregation is applicable to units providing the same service, (e.g., steam systems which
may include combustion devices and alternative energy sources).
3. This aggregation is not applicable to Section 129 sources.
4. While emissions may be aggregated and applied across multiple sources, the environmental
impact must meet the requirements given below in Environmental Impact Evaluation.
Environmental Impact Evaluation
1. This compliance alternative approval process and compliance procedures are intended to be
a useful, viable, and appealing alternative to the MACT standard.
2. The overall effect of the alternative emission limit must provide greater environmental
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benefit than the promulgated emission standard considering non-air quality health and
environmental impacts.
3. Exclusively for purposes of evaluating additional environmental benefits, ICCR source
owners or operators who purchase electricity may consider reduced purchased power and its
associated emission reductions from electric utilities, e.g., installation of cogeneration facilities
which reduce the quantity of electricity purchased from the grid. Published or estimated average
state or area electric utility emission rates can be used for this purpose.
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Alternative Compliance - Flexible Permitting
Areas of Concern and Non-Consensus
While some sources and state agencies have stated that environmental operating permits can
create disincentives to implementing pollution prevention, the ICCR Environmental Caucus
remains unconvinced that the thoughts included in this document are warranted or within the
scope of the ICCR process. Further the Environmental Caucus strongly object to any changes
to permitting programs which do not incorporate specific enforcement certainties and public
health safeguards.
Congress Explicitly Restricted Options for "Flexible MACT Permits"
Section 112(h)(3) does provide the opportunity for sources to propose alternative means of
complying with MACT emission standards. However, the applicability of this option is clearly
confined to those sources covered by MACT emission standards developed pursuant to Section
112(h)(1).
Recommendation Fails to Fully Consider All Relevant Title V Issues
Perhaps no other program embodied in the Clean Air Act Amendments of 1990 has
encountered more problems or fallen shorter of expectations than the Title V Operating Permit
Program. An alarmingly few permits have actually been issued, reviews are backlogged among
overburdened and under funded air agencies and public participation has been rare. Any
thoughts offered to EPA regarding permit flexibility should only be made after a vigorous
review of these and other relevant issues with representation from a wider array of stakeholders.
Case-hv-Case MACT Permits May Contribute to Delays and Frustrate Public
Participation
Given the extensive backlog of permits to be issued, any thoughts that would in essence create a
case-by-case MACT compliance scenario is extremely problematic. Already, some state
legislatures have attempted to circumvent adequate agency review by proposing default
approval based upon submittal dates. Likewise, most state legislatures have capped permit fees
at a level which fails to cover the cost of agency review. The thoughts offered in this document
would only compound these problems by promoting unique and often complicated MACT
compliance demonstrations. In addition, public interest groups could envision "flexible"
demonstrations of compliance understandable to only expensive consultants.
Compliance. Monitoring and Recordkeeping Requirements Should Be Well Defined by
MACT Rules
Compliance certainty is critical to the effectiveness of emission standards. The Clean Air Act
requires continuous compliance and also requires monitoring and compliance certifications that
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demonstrate continuous compliance. Rather than allowing for sources to offer any conceivable
method for demonstrating compliance, the section of the thoughts included in this document
should either be removed or appropriate requirements should be developed by the EPA.
Quantifying the Environmental Benefit of Reduced Electricity Consumption is
Prohlematic
Estimating the environmental benefit for each marginal electron on the grid displaced by
increased on-site generation is problematic for several reasons. First, HAP emission factors are
at best suspect for many sources connected to the grid. Secondly, Title IV requirements,
consumers' growing preferences for clean energy and EPA's proposed NOx SIP Call should lead
to cleaner energy in future years (providing reasonable national deregulation guidance is
forthcoming). Finally, the energy portfolio for every power pool varies significantly on a
annual, seasonal and daily basis.
Environmental Impact Evaluation Must Provide Basic Puhlic Health Guarantees
Congress envisioned a significant reduction in the number of individuals and communities
exposed to unacceptable risk from toxic air pollution through the application of MACT,
followed by the residual risk program. Any alternative to — or variation from — that strategy
must contain specific public health guarantees. Therefore, we offer the following thought to
EPA for consideration regarding this section:
#4 Public health impacts (e.g., ambient air concentrations) shall not be increased by the
compliance alternative relative to those which would occur by implementing the MACT rule as
required.
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ATTACHMENT VI
ICCR COORDINATING COMMITTEE
THOUGHTS ON
OPTIONS FOR ICCR MACT RULES
OFFERED TO EPA FOR CONSIDERATION
JULY 28, 1998
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Options For ICCR MACT Rules
(Non-consensus)
Recommendation
The ICCR Coordinating Committee offers the thoughts contained in this document to EPA for
consideration in efforts to develop MACT standards EPA is charged with developing for
combustion turbines, stationary internal combustion engines, process heaters, industrial-
commercial-institutional boilers, and non-hazardous waste incinerators under Sections 112 and
129 of the Clean Air Act.
There were disagreements among Committee members on the thoughts outlined in this
document. Consequently, in reviewing and considering these thoughts, the Committee urges
the EPA to review and consider the discussion of this document by the Committee. This
discussion may be found in the minutes from the July 28 - 29, 1998 meeting of the ICCR
Coordinating Committee in Long Beach, California.
EPA should consider and, where appropriate, evaluate MACT options for each of the MACT
standards. Options which provide incentives for energy use reductions, waste reductions, and
other pollution prevention solutions in lieu of or in addition to the use of control devices are
preferable because add-on controls are costly to implement, generate waste, and consume
energy. EPA should not feel restricted to the selection of one basis for a pollutant emission
limit (e.g., lb/hr, ppm). One emission limit for a given pollutant might not provide an
opportunity for optimal use of pollution prevention efforts toward achieving compliance across
the range of facilities which will be subject to these rules. Because of the diversity of affected
facilities, multiple compliance options for each pollutant may optimize incentives to invest in
pollution prevention efforts.
Introduction
The Committee devoted substantial resources to researching and compiling P2 techniques which
achieve environmental benefits through (1) modifying how a combustion unit is operated, (2)
affecting certain combustion feedstreams, or (3) reducing the energy requirements on the unit,
e.g., by conserving or using the energy outputs more efficiently. These techniques could
provide environmental benefits and reduce the burden and cost of compliance at ICCR affected
facilities. Establishment of a single numeric MACT emission limit per pollutant (e.g., ppm) on
an individual source basis might significantly restrict the benefits of using Pollution Prevention
techniques toward achieving compliance.
Sections 112 and 129 of the Clean Air Act do not restrict the number of MACT emission limit
options which may be proposed and promulgated for a given pollutant in a single rule. An
example of EPA's use of this flexibility in previous rulemakings was in the medical waste
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incinerator (MWI) rule where for some pollutants the owner or operator is provided the
flexibility of complying with a stack gas concentration or a percent reduction limit. There are
many ways to express MACT standards. Some metrics are better than others at reflecting the
accomplishments of source reduction, energy conservation, and other pollution prevention
efforts.
Section 112 provides EPA the latitude to define the source category broadly as a collection of
sources having a common function and, therefore, the resultant MACT standards would apply
to a group of sources, as appropriate. Aggregation at facilities with multiple units within the
same category provides greater flexibility with respect to the application of pollution prevention
techniques and/or control devices. The issue of aggregation of Section 112 units is also
important to the use of MACT options. MACT options could be established which allow
owners or operators to accomplish input or output changes either independently or in
combination with control application to meet an overall emissions limit across multiple sources.
Such flexibility within the ICCR MACT standards would provide opportunities to more
economically achieve the greater environmental benefits possible through P2 efforts.
Definitions
Pollution prevention means "source reduction" and other practices that reduce or eliminate the
creation of pollutants through: increased efficiency in the use of raw materials, energy, water,
or other resources; or protection of natural resources by conservation.
Source reduction means any practice which: reduces the amount of any hazardous substance,
pollutant, or contaminant entering any waste stream or otherwise released into the environment
(including fugitive emissions) prior to recycling, treatment, or disposal; and reduces the hazards
to public health and the environment associated with the release of such substances, pollutants,
or contaminants. The term includes equipment or technology modifications, process or
procedure modifications, reformulation or redesign of products, substitution of raw materials,
and improvements in housekeeping, maintenance, training, or inventory control.
"Input changes" include modifications to fuel/waste stream input feed rate or composition or
other actions which result in reductions in emissions of pollutants regulated under this rule. An
example of this would be elimination or reduction of a specific waste stream or conversion to a
cleaner burning fuel.
"Output changes" include reductions in energy or capacity demand that result in the combustion
of less fuel or waste and thereby reduce emissions of pollutants regulated under this rule. These
can also include operational or equipment changes which increase device efficiency. Examples
of this would be proper installation and maintenance of steam traps, insulation of buildings and
steam lines, or installation of an economizer on a steam boiler.
Applicability
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MACT options should be considered by the EPA in those cases where it is determined that the
data supports establishment of a numeric emission limit for control of a specific pollutant.
Principles
1. MACT options should allow for input and/or output changes as methods of reducing
emissions.
2. MACT options should allow use of approaches which may include any combination of input
and/or output changes and combustion device-specific control measures.
MACT Options
The EPA should consider providing a series of equivalent options for complying with an ICCR
rule. These options may include any combination of the following examples or other options
which may be appropriate for the source type. The owner or operator would choose with
which single option to demonstrate compliance.
Compliance Option A - a stack gas concentration standard (e.g., ppm, gr/dscf)
Compliance Option B - an emission rate standard (e.g., lb/hr, lb/day, lb/week, lb/month, lb/yr)
Compliance Option C - a heat/power indexed emission standard (e.g., lb/MM Btu)
Compliance Option D - a percent removal standard across the air pollution control train
Compliance Option E - a feed (fuel and/or waste) de Minimis standard
Compliance Option F - a percent reduction in pounds of waste generated and subsequently
combusted indexed to an appropriate basis such as production, occupancy, or square footage
Compliance Option G - a percent reduction in on-site energy consumption indexed to an
appropriate basis such as production, occupancy, or square footage
Compliance Option H - a list of best operating practices determined by the source work group
to achieve comparable emission reductions to the numeric emission limit
Aggregation of Sources
1. The EPA should consider aggregation of emissions of pollutants from Section 112 regulated
sources within the same source category under this rule which are under common control at a
single site.
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2. This aggregation can be considered for units providing the same service, (e.g., steam systems
which may include combustion devices and alternative energy sources).
3. This aggregation is not applicable to Section 129 sources.
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Options For ICCR MACT Rules
Areas of Concern and Non-Consensus
Pollution prevention can offer both significant economic savings to sources affected by ICCR
MACT rules and provide superior environmental and public health benefits in comparison to
MACT rules based on end-of-pipe controls. The ICCR Environmental Caucus offers thoughts
to EPA for consideration in several areas and thoughts on specific language modifications.
Pollution Prevention Should Not he an Option But a Requirement
As discussed by the Environmental Caucus, EPA not only has the authority to consider
pollution prevention and other techniques in the development of MACT rules, but EPA is
required to set MACT floors which incorporate pollution prevention practices which reflect the
best performing sources. In addition, EPA also has an obligation to require all achievable
pollution prevention measures that will reduce emissions beyond the floor. Therefore, EPA
must determine what pollution prevention practices are in use, or could be included in each
subcategory.
Unfortunately, no data on pollution prevention practices were collected through the initial
Section 114 information collection request. Absent these data, the EPA will be unable to
determine which pollution prevention practices for specific subcategories are required
components of the MACT standards verses "options". Therefore, if EPA considers "options"
for compliance, these options should be restricted to pollution prevention techniques which are
demonstrated to be — at a minimum — beyond the MACT floor.
Options Will Penalize Progressive Facilities
If — as implied in this document — emissions standards are narrowly defined by MACT rules as
emission rates or concentrations, additional compliance options will be most attractive only to
those facilities which have failed to implement pollution prevention. Instead, MACT standards
should be least burdensome to the best performing 12% of sources in each category.
Aggregation of Sources (units) Should Provide Both Superior Environmental Results and
Meet specific Public Health Equivalence Demonstrations
While the ability to aggregate ICCR units could increase the compliance options for
owner/operators, this provision should require an additional level of analysis. Evaluation of
environmental and public health impacts of the proposed options by subcategory or by
individual units will be required. Such evaluations should ensure that the public health benefits
of all MACT options provide equal environmental and public health benefits to all impacted
individuals, communities and ecosystems.
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ATTACHMENT VII
ICCR COORDINATING COMMITTEE
— DRAFT —
Industrial/Commercial Waste Incinerators (ICWI)
and
Other Solid Waste Incinerators (OSWI)
Thoughts on
Regulatory Alternatives
Offered to EPA For Consideration
July 28,1998
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PREFACE
The ICCR Coordinating Committee offers the thoughts contained in this document to EPA
for consideration in preparing the "Regulatory White Paper" EPA is required to submit to
litigants under a consent decree between the litigants and EPA resulting from litigation on the
development of MACT standards under Section 129 of the Clean Air Act for the source
category of Industrial and Commercial Solid Waste Incinerators (a.k.a ICWI).
This document is a draft document, in the sense that the Committee may develop and forward
additional thoughts to EPA at the September 16 - 17, 1998 meeting of the Committee in
Durham, North Carolina. While it would be unrealistic to expect every Committee member to
agree with every thought in this document, the Committee concurs with the overall content and
focus of these thoughts and reached consensus on forwarding them to EPA for consideration.
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TABLE OF CONTENTS
Page
Preface i
Table of Contents ii
1.0 Introduction 1
2.0 Background 1
3.0 Applicability 4
4.0 Subcategory Characterizations and Regulatory Alternatives 4
5.0 Pollution Prevention 4
6.0 Statutes and Executive Orders 7
7.0 Issues and Needs 9
Attachment A Example Applicability Language and Definitions 18
Attachment B Draft Subcategory Definition Sheets 23
Tables
Table 1 Incinerator Subcategories 11
Table 2 Summary of Preliminary Subcategory Definitions 12
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1.0 INTRODUCTION
This document contains initial thoughts by the Committee which are offered to EPA for
consideration regarding categories of nonhazardous solid waste incinerators for regulation
under section 129 of the Clean Air Act, the pollutants to be regulated, and potential control
alternatives for each incinerator subcategory. Additionally, this document contains thoughts on
other relevant subcategory-specific information such as subcategory population statistics,
combustion device descriptions, the status of data collection and analysis, and issues and needs.
The thoughts presented in this document should be considered as draft.
This document is organized into sections on background, applicability, subcategory
characterizations and regulatory alternatives, pollution prevention, statutes and executive
orders, and issues and needs. Additionally, thoughts on draft applicability language and
preliminary definition sheets for the emission source subcategories are attached.
2.0 BACKGROUND
The Charter of the ICCR Coordinating Committee charges the Committee to develop
recommendations to EPA regarding the development of nonhazardous solid waste incineration
regulations under Section 129 of the Clean Air Act. In this effort, the Committee has analyzed
the ICCR databases, identified emission source subcategories, developed recommendations for
emission testing, and efforts are progressing to identify MACT floors and regulatory control
options.
Because EPA has indicated that boilers and process heaters that combust nonhazardous
solid waste should be considered "solid waste incineration units" under Section 129, the
Committee has provided preliminary placeholder subcategories for boilers, and appropriate
subcategories may be added for process heaters in future drafts. However, the number and
description of boiler and process heater subcategories that may ultimately be addressed under
Section 129 remains uncertain at this time, in part because the Agency has yet to adopt a
definition of nonhazardous solid waste for use in Section 129 regulations.
This definition of nonhazardous solid waste is crucial to determining whether certain
combustion units will ultimately be considered nonhazardous solid waste incineration units
subject to Section 129 or combustion units subject to Section 112. While EPA staff have stated
that the Clean Air Act directs EPA to regulate any device burning nonhazardous solid waste as
an incinerator under Section 129 of the Act, it should be noted that incinerators, boilers, and
process heaters - as most people use these terms - have distinctively different functions.
Whereas the primary purpose of an incinerator is to reduce the volume of waste, the primary
purpose of a boiler is to produce useful steam or hot water, and process heaters are designed to
transfer useful heat to an industrial or commercial process.
The Committee offers the following thoughts to EPA for consideration on nonhazardous
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solid waste incineration subcategories for possible regulation under Section 129:
¦ Miscellaneous Industrial and Commercial Waste Incinerators
¦ Wood and wood waste incinerators — including separate groupings for milled
solid and engineered wood; harvested wood and agricultural waste; construction,
demolition, and treated wood wastes; and possibly finishing wastes.
¦ Pathological waste incinerators and crematories — including separate groupings
based on feed rate for poultry farms; human crematories; and hospital, animal
control, and research facilities.
¦ Drum reclaimer furnaces
¦ Parts reclaimer burnoff units
¦ Potential Section 129 solid mixed feed boilers
¦ Potential Section 129 liquid mixed feed boilers
Section 129 addresses four categories of incineration units — municipal solid waste (MSW)
combustors, hospital and medical infectious waste (HMIW) incinerators, industrial and
commercial waste incinerators (ICWI), and other solid waste incinerators (OSWI). Rules
addressing the first two categories have been promulgated. However, rule applicability
excludes units combusting less than 40 tons per day (tpd) of municipal solid waste (determined
by weight on a quarterly average basis), larger such units combusting less than 30% municipal
solid waste, and units burning less than 10% hospital and medical infectious wastes. EPA has
decided to address the <40 tpd municipal solid waste units outside of the ICCR. The <30%
municipal solid waste and <10% hospital and medical infectious waste incineration units are
included in the ICCR and will be addressed in one of the subcategories ultimately established for
the Section 129 rulemaking.
At this time a separate set of regulatory requirements (e.g., emission limits) for each of the
above subcategories and groupings is envisioned. However, further subdividing or combining
of these subcategories and groupings may occur as additional information is received and
analyzed. Additionally, it may be necessary to create a miscellaneous or other category to
ensure that any units not covered by the above subcategories are addressed.
EPA staff have indicated that Section 129 addresses all combustion devices (e.g.,
incinerator units and other combustor units) burning nonhazardous solid waste. The identified
subcategories are believed to provide comprehensive coverage, with the Miscellaneous
Industrial and Commercial Waste Incineration category believed to include the mixed feed and
industrial solid waste incineration units not included in any of the other subcategories.
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However, should that not prove to be the case, the Miscellaneous Industrial and Commercial
Waste Incineration category could be expanded to include units not covered, or a new
miscellaneous category could be defined. To date, all incinerators in the ICCR's databases that
have been determined to be the responsibility of the ICCR are assigned to one of the
subcategories. Thus, it is unclear whether an additional miscellaneous or other category will
ultimately be necessary.
The Committee offers the thought to EPA for consideration that the regulatory
requirements for the above nonhazardous solid waste incineration subcategories could be
addressed in a single rulemaking package (i.e., a single preamble and regulation for proposal,
and the same for promulgation) for efficiency purposes and because many of the requirements
(e.g., for monitoring, recordkeeping, reporting, operator training and certification, siting, and
pollution prevention) may be the same across multiple subcategories. This approach could
simplify the rulemaking process, thereby fostering understanding of the regulatory requirements
and better compliance.
Because Section 129 distinguished between Industrial and Commercial Solid Waste
Incinerators (ICWI) and Other Solid Waste Incinerators (OSWI), EPA staff have indicated that
the rulemaking package would also need to distinguish between these two categories of
combustion units, or explicitly consider and reject this approach with a rational and logical
explanation for why it is more reasonable to combine these two categories into one category
(e.g., if the same emission limits were recommended for both categories). Although the consent
decree only requires EPA to discuss regulatory alternatives for ICWI sources, OSWI sources
are also discussed in this document due to their similarity and because, as mentioned above, the
Committee offers the thought of a combined regulation to EPA for consideration.
Much of the Committee's effort has been devoted to analyzing data contained in the
following three databases:
¦ ICCR Inventory database — a detailed listing of industrial and commercial
combustion units developed by EPA from existing State andfederal databases.
¦ ICCR Information collection request (ICR) survey database — responses from a
recent EPA Information Collection Request (ICR) survey providing updated and
detailed information for facilities identified in the inventory database as
combusting nonhazardous solid waste.
¦ ICCR Emissions database — emissions data collected by EPA from State
agencies representing source testing of a variety of combustion units.
The ICCR inventory database contains 8,091 facilities believed to have one or more
incineration units. However, the responses to the ICR indicate that many of these units have
been shut down or otherwise do not exist. (This may reflect the substantial progress made by
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industry in recent years to reduce the amount of waste produced.) Other units were eliminated
from consideration because they were determined to be burning hospital and infectious medical
waste, municipal waste, or other types of materials outside the scope of the ICCR. The status
of about 1,700 potential units remains unknown because of insufficient information. Taking all
of these factors into consideration, the Committee's best estimate of the number of incineration
units in the inventory and ICR databases that are currently in operation is about 1,600. This
estimate could increase or decrease by several hundred units as more information becomes
available (e.g., the results of a follow-up mailing to facilities not responding to the first mailing).
The extent to which the inventory and ICR databases capture all operating incinerators
in the U.S. is unknown. However, based on population estimates for individual subcategories, a
rough guess is that the inventory and ICR databases represent most of the wood, wood waste,
and drum and parts reclaimer units currently operating in the U.S. and over 50% of the
remaining incineration subcategories, with the exception of several thousand poultry farm
incinerators. These poultry farm units, typically rated at <100 lb/hr, have probably never been
regulated or permitted due to their small size. In summary, although not all incineration units
are captured within the ICCR databases, the Committee believes that the databases are
representative of the cross-section of U.S. incinerators and provide a sufficient basis for
rulemaking.
3.0 APPLICABILITY
The thoughts presented in this document apply to all incineration units that are not
exempt from Section 129 or addressed by other rulemakings. Section 129(g)(1) exempts wastes
required to have a permit under Section 3005 of the Solid Waste Disposal Act (i.e., hazardous
wastes), material recovery facilities which combust waste for the primary purpose of recovering
metals, qualifying small power production and co-generation facilities, and air curtain
incinerators combusting only yard and wood wastes and clean lumber. Additionally, municipal
waste combustors and hospital and medical infectious waste incinerators are included in the
thoughts presented in this document because they are being addressed by EPA in parallel
rulemakings or because they are already covered by other rulemakings. An example of draft
applicability language and definitions for a combined ICWI/OSWI rule are presented in
Attachment A.
4.0 SUBCATEGORY CHARACTERIZATIONS AND REGULATORY
ALTERNATIVES
Descriptions of each potential subcategory are presented in Attachment B and
summarized in Table 2. Additionally, information is presented on pollutants considered for
regulation (at a minimum the nine pollutants listed in Section 129), whether a subcategory falls
under ICWI or OSWI, any groupings within the subcategory, population statistics, material
combusted, combustion device description, the basis for subcategory bounds, the floor level of
control, the status of data collection and analysis, issues and needs, and other comments.
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Based on the information currently available, it appears that most existing incineration
units have minimal or no controls in place. The exception is for most drum reclaimer furnaces
and parts reclaimer burnoff ovens, which appear to have thermal oxidizers. Good combustion
practices are routinely applied to pathological units due to State regulations and could represent
the MACT floor for this subcategory. Only very limited test data on most pollutants of interest
are available for all incinerator subcategories, and the Committee has forwarded
recommendations to EPA for emission testing. Some subcategories (e.g., wood wastes) are
small in terms of the number of operating units, and these may be candidates for merging into a
larger subcategory.
5.0 POLLUTION PREVENTION
The Committee offers the thought to EPA for consideration that pollution prevention
could be considered an integral part of the Section 129 rulemaking and the Committee is
committed to a further investigation of the feasibility, practicality, and cost-effectiveness of
various pollution prevention techniques. This commitment is consistent with the goals of the
Pollution Prevention Act of 1990 and EPA policy to consider and facilitate the adoption of
source reduction techniques. Additionally, EPA has stated its opinion that Section 129(a)(3) of
the Clean Air Act anticipates that pollution prevention may be included in regulations (i.e., as
the basis of a floor or control level above the floor) by stating that standards "... shall be based
on methods and technologies for the removal or destruction of pollutants before, during, or
after combustion ... [emphasis added]."
As a starting point, the Committee plans to consider the waste management plan
approach used in the Section 129 rules for municipal waste and hospital and medical infectious
waste incineration. The Committee generally agrees with the overall objective of certain waste
management plans, which is to examine the feasibility, practicality, net environmental impact,
and cost of and approach to separating certain components of solid waste from the combustion
waste stream so as to reduce the amount of toxic emissions from the combusted waste.
Additionally, possible pollution prevention items such as good combustion practices
(GCP), operator training, and pollution prevention metrics will be reviewed as well as
approaches for alternative compliance and pollution prevention planning in developing any
further thoughts or recommendations on MACT standards for incinerators under Section 129.
The potential pollution prevention approaches identified to date are discussed below.
Good combustion practices. The Committee has prepared guidance for the Committee
to consider on GCP options. The good combustion techniques covered in this guidance
include:
¦ Operator practices
¦ Maintenance knowledge and practices
¦ Stoichiometric ratio (air/fuel)
VII- 5
-------
¦ Firebox residence time, temperature, and turbulence
¦ Fuel/waste quality, handling, sizing, dispersion, and liquid atomization
¦ Combustion air distribution
If appropriate, implementation of these techniques could be accomplished in MACT standards
developed under Section 129 through a combination of documented operating and maintenance
procedures, logs and record-keeping, training on equipment and procedures, routinely
scheduled inspections and maintenance, burner and control adjustments, system design,
fuel/waste monitoring, and various system adjustments. (Although operator training itself could
also be considered a good combustion practice, it is covered separately below.) The Committee
offers the thought to EPA for consideration that these techniques are potentially applicable to
incineration units under Section 129, although the Committee has not yet studied the specific
applicability, benefit, disbenefit, or cost effectiveness of these techniques.
The Committee plans to evaluate practical and effective combustion practices applicable
to the incinerators. Because of the variety of unit designs and waste types being addressed, it
may be appropriate to develop a separate set of GCPs for each subcategory. For some
subcategories, no GCPs may be appropriate. On the other hand, if there are practical and
effective combustion practices that are the same or similar among multiple subcategories, a
single set of GCPs for all units covered by those subcategories may be considered.
Operator Training/Qualification. Section 129(d) requires EPA to "... develop and
promote a model State program for the training and certification of solid waste incineration unit
operators ..." The Committee has developed a list of training/qualification activities for the
Committee to consider and this list includes the following definition of "operator:"
¦ Operator means an individual or individuals whose work duties include the
operation, evaluation, and/or adjustment of the combustion system.
The Committee may consider this definition in developing further thoughts or recommendations
on MACT standards under Section 129, although additional specificity will be needed and a
clear distinction will have to be made between the incinerator "operator' and the
"owner/operator" of the unit or facility.
The Committee's initial list of potential pollution prevention approaches for
consideration by the Committee within further thoughts or recommendations for incinerators
under Section 129 includes specific training program elements, including:
¦ Training and qualification criteria
¦ Training programs and qualification exams
¦ Training program materials and documentation of qualification
The Committee may consider these requirements for some incinerator operators, although the
VII-6
-------
details still need to be worked out. Additional work will be required to fine tune the training
content for the specific types of units covered under Section 129, and separate sets of training
content for specific subcategories may prove to be necessary.
Metrics. Emission limits previously promulgated under Section 129 (i.e., the municipal
waste and hospital and medical infectious waste rules) have been expressed in units of
concentration (e.g., ng/dscm or ppm). Concentration units are effective in reducing emissions
based on control device efficiency and may also encourage pollution prevention. However,
some pollution prevention techniques that significantly reduce mass emission rates may not
concurrently reduce mass concentrations.
To encourage pollution prevention, the Committee plans to consider metrics other than
concentration emission limits, where the numerator in the emission limit would be based on
pollutant mass (e.g., ng) and the denominator would be based on time, energy output, heat
input, fuel/waste input, or unit of production. However, compliance with such metrics may be
impractical where the metrics are combustion unit size/capacity specific (e.g., metrics based on
time), difficult to measure (e.g., metrics based on energy output, heat input, or fuel/waste
input), or difficult to quantify (e.g., metrics based on unit of production).
Regulatory Options. The Committee is also considering regulatory options such as
waste accounting and recordkeeping and work practice standards to include in further thoughts
or recommendations for MACT standards for incinerators under Section 129. Waste
accounting and recordkeeping would provide a paper trail of waste feedstream composition,
thereby highlighting opportunities for source separation, source elimination, or recycle/recovery.
Work practice standards would require specific handling or separation procedures for waste
materials prior to burning, thereby reducing undesirable materials (e.g., waste components
leading to specific HAP emissions) and potentially improving combustion efficiency (e.g., by
removing high moisture content materials from the waste steam).
The Committee plans to consider both of these techniques, although further information
is needed on: (1) what specific handling or separation procedures might be applied to each of
the subcategories, (2) the data or reasoning (e.g., based on combustion chemistry or engineering
calculations) leading to the conclusion that a specific handling or separation procedure would
provide a significant net life-cycle environmental benefit, and (3) evaluation of the potential
benefit versus the burden (including economic burden) imposed.
6.0 STATUTES AND EXECUTIVE ORDERS
In addition to the substantive requirements imposed by the Clean Air Act when
promulgating regulations, the EPA must comply with a number of administrative responsibilities
prior to adopting regulations. Some of these obligations flow from statutes and others from
executive orders (EOs) signed by the President as directives to the Executive Branch.
VII-7
-------
EPA must comply with administrative requirements in the following five statutes at the
proposal stage of a regulation's development.2
¦ Section 307(d) of the Clean Air Act requires that regulations under Section 129
be supported by a rulemaking docket and allow for both written and oral
comment upon the proposed rule.
¦ Under the Paperwork Reduction Act, EPA must obtain a control number from
the Office of Management and Budget (OMB) if the regulation contains any
information collection request (reporting obligations under an applicable
emission standard, for instance) calling for answers to identical questions posed
to ten or more persons.
¦ The National Technology Transfer and Advancement Act (NTTAA) mandates
that EPA must use existing suitable voluntary consensus standards (e.g., test
methods) unless their use would be inconsistent with applicable law or otherwise
impractical in EPA's judgement.
¦ If the proposed regulation will contain a federal mandate forcing State, local, and
tribal governments, in the aggregate, or the private sector to spend in excess of
$100 million in any given year, the Unfunded Mandates Reform Act (UMRA)
requires EPA to prepare a statement identifying a number of economic and
environmental costs and benefits associated with the proposed rule, both locally
and nationally. UMRA also requires that, for proposed rules which require an
UMRA statement, EPA must identify and consider a reasonable number of
regulatory alternatives and select the least costly, most cost-effective, or least
burdensome option that is consistent with the agency's statutory duties, unless
EPA explains its choice not to select one of the foregoing options. UMRA lastly
contains two consultation requirements: (1) EPA must consult with elected
officers of State, local, and tribal governments with regard to proposed rules that
contain significant Federal intergovernmental mandates, and (2) it must develop
a small government agency plan (which provides for notice to, input from, and
education for, small governments regarding a proposed rule) for any rule that
might significantly or uniquely affect small governments.
¦ The Regulatory Flexibility Act (RFA), as amended by the Small Business
Regulatory Enforcement Fairness Act, requires EPA to prepare an initial
regulatory flexibility analysis (IRFA), convene a small business advocacy review
2One additional statutory administrative requirement is triggered when the Agency
promulgates final regulations. Under the Congressional Review Act, EPA generally must submit
all rules of general applicability to Congress and the Comptroller General before the rule may take
effect.
VII- 8
-------
panel, and include the IRFA or a summary of it in the proposal's preamble,
unless the Administrator can certify that a proposed regulation will not have a
significant economic impact on a substantial number of small entities.
In addition to its statutory obligations, EPA has the following three EOs to consider.
¦ Under EO 12875, EPA must develop an effective process for elected officials
and other representatives of State, local, and tribal governments to provide
meaningful input on regulatory proposals. Also, EPA may not (unless required
by law) promulgate a regulation that creates an unfunded mandate upon State,
local, or tribal governments without either providing funds necessary to pay the
direct costs of compliance or consulting with representatives of affected
governments prior to promulgation. (This is the same requirement that Congress
subsequently enacted in UMRA.)
¦ Prior to proposal, EO 12866 requires that EPA seek involvement of parties
affected by a proposed rule and suggests that at least a 60 day comment period
on proposed rules be offered. The same EO also requires that EPA submit to
OMB any proposed or final significant regulatory action for interagency review.3
¦ E.O. 12898 specifies that EPA must make achieving environmental justice part
of its mission by identifying and addressing, as appropriate, practicable, and
permitted by law, disproportionately high and adverse human health or
environmental effects of its rulemaking actions on minority and low-income
populations.4
3Significant is defined as an action having an annual effect on the economy of $100 million
or more; adversely affecting in any material way the economy, a sector of the economy, jobs, the
environment, public health or safety, or affected governments or communities; creating a serious
inconsistency or interfering with an action taken or planned by another agency; materially altering
the budgetary impact of entitlements, grants, etc., or the rights/obligations of recipients; or raising
novel legal or policy issues.
4If a rule is significant under E.O. 12866 and it involves an environmental health or safety
risk that EPA has reason to believe may disproportionately affect children, EO 13045 requires
EPA to evaluate the environmental health or safety effects of the planned regulation on children
and explain why the proposal is preferable to other potentially effective and reasonably feasible
alternatives considered by the Agency. Since the standards to be developed under Section 129
are technology-based and not health- or risk-based, EO 13045 does not apply to the
determination of MACT floor. The Committee is currently considering whether and how EO
13045 would otherwise influence its other recommendations for MACT standard regulatory
development (e.g., the selection of pollutants in addition to those listed in section 129(a)(4)).
VII-9
-------
The ICCR has, to date, laid the groundwork for developing recommendations aiding
EPA's compliance with these obligations. Specifically, the Committee may develop further
thoughts or recommendations for model plants, which may reflect the design of typical facilities
in the affected industry and could be used when EPA seeks to conduct the economic and
environmental analyses necessary to comply with UMRA, RFA, and EO 12866. The EPA
could consider the effect of proposed regulations upon these model plants as illustrative of the
impact the proposals may have nationally. In addition, the Committee, in the course of
recommending hazardous air pollutants (HAPs) for testing and regulation under Section 112,
have generally identified existing test methods for measuring HAPs, and use of these existing
test methods for determining compliance with regulations could be useful to the EPAs
compliance with the NTTAA's requirement to search for applicable voluntary consensus
standards. Next, Section 129(a)(3) directs that standards for new sources incorporate "siting
requirements that minimize, on a site specific basis, to the maximum extent practicable, potential
risks to public health and the environment." Siting requirements may trigger environmental
justice concerns, and the Committee may consider the EPA Environmental Justice
Implementation Plan in developing further thoughts or recommendations that address such
concerns.
7.0 ISSUES AND NEEDS
Waste Burning Boilers. EPA staff have indicated that Section 129 of the Clean Air Act
requires that any combustion devices burning nonhazardous solid wastes be regulated as
incinerators under Section 129. However, some on the Committee believe there may be an
unresolved issue concerning boilers that burn waste or waste mixed with fuels (e.g. coal or
natural gas). Some believe Section 129 focuses on what is burned and not on the device in
which it is burned. Therefore, while it may be clear that a boiler burning nonhazardous solid
waste, as ultimately defined by EPA, is covered by Section 129, does this also mean if the boiler
burns any amount of waste that it must be regulated under Section 129, or is there a minimum
amount of waste that must be burned before it falls under Section 129? In the case of boilers,
this issue may be complex since the composition and amount of waste burned may vary with
time, and the toxicity of the emissions will also vary depending upon the composition of the
waste stream.
Waste Composition Averaging Time. In many cases, incinerators burn waste streams
that are not homogeneous. Depending upon the facility and wastes disposed of, waste "A" may
be burned for several hours early in the work day, followed by waste "B," followed by wastes
"C" and "D" or a mixture of A, B, C, and D in varying amounts. In some cases, waste "E" will
be burned for several months, followed by waste "F" for some period of time. This may result
in widely varying emissions over the course of a day, month, or year. Unless emissions testing
is done when each waste is burned and in all possible combinations, emissions data will not be
representative of actual operating conditions. Operating permits often specify a waste
composition to be burned (e.g., % waste "X" per unit time), and long averaging times may
result in periods of emissions of widely varying toxicities while still conforming to the
VII - 10
-------
conditions of the permit. Based on the above operating scenarios, an analysis of potential
variables is needed to define an acceptable averaging time for each subcategory. This analysis is
necessary for purposes of determining the applicability of the standards, setting the level of the
standards, and determining compliance. The heart of the issue is how averaging time impacts
toxicity of emissions by allowing variability of mass emission rates while still assuring the
protection of human health.
VII - 11
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TABLE 1. INCINERATOR SUBCATEGORIES
SUBCATEGORY
CURRENT SUBCATEGORY WASTES
Patholoeical Wastes and
Crematories
~ Poultry farms ... (<100 Ib/hr)
~ Human crematories ... (100-500 Ib/hr)
~ Hospital, animal control, research facilities ... (>500 Ib/hr)
Chemical. Petroleum, and
Pharmaceutical Solids. Liquids,
and Sludses
~ Miscellaneous Industrial and Commercial Waste Incinerators
Wood. Construction &
Demolition, and Agricultural
Wastes
~ Wood and wood wastes, including these groupings:
a. Milled solid and engineered wood
b. Harvested wood and agricultural
c. Construction, demolition, and treated wood
d. Finishing wastes (under consideration)
Metal Parts and Drums
~ Drum reclaimer furnaces
~ Parts reclaimer burnoff units
VII - 12
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TABLE 2. SUMMARY OF PRELIMINARY SUBCATEGORY DEFINITIONS
SUB-
CATEGOR
Y NAME
GROUPIN
G WITHIN
SUB-
CATEGOR
Y
MATERIAL COMBUSTED
ICW
I or
OS
WI
EST. NO. OF
UNITS
POLLUTAN
TS
CONSIDERE
D FOR
REGULATIO
N
FLOOR
LEVEL OF
CONTROL
REGULATOR
Y
ALTERNATIV
ESABOVE
FLOOR
IN
DAT
A-
BAS
E
NATIO
N-
WIDE
Miscellaneo
None
By-products of industrial
ICW
-150
Section 129
Preliminary
us Industrial
identified at
operations (including
I
pollutants
: CO and
and
this time
combinations with less that
particulate
Commercial
30% trash or less than 10%
controls
Waste
medical waste),
appear to
Incinerators
environmental control device
be present
sludges, waste by-products,
at more
maintenance residues, off-
than 12
test and out-dated materials,
percent
and packaging materials
surveyed
units
VII - 13
-------
EST. NO. OF
GROUPIN
UNITS
POLLUTAN
SUB-
G WITHIN
ICW
TS
FLOOR
REGULATOR
CATEGOR
SUB-
MATERIAL COMBUSTED
I or
IN
DAT
A-
BAS
E
CONSIDERE
LEVEL OF
Y
Y NAME
CATEGOR
OS
NATIO
N-
WIDE
D FOR
CONTROL
ALTERNATIV
Y
WI
REGULATIO
N
ESABOVE
FLOOR
Wood and
Milled
Wastes and residues
OS
18
Section 129
No control
Considering
Wood
Solid and
resulting from wood-working
WI
pollutants
good
Wastes
Engineered
Wood
Wastes
manufacturing activities,
containing 2 to 15 percent by
weight adhesives, glues, and
binders in engineered woods,
and containing no more than
5 percent by weight of
contaminants such as
cardboard, paper, paints, and
solvents
combustion
practices,
source
separation,
particulate
controls,
scrubbers,
ESPs,
afterburners,
and secondary
combustors
VII - 14
-------
EST. NO. OF
GROUPIN
UNITS
POLLUTAN
SUB-
G WITHIN
ICW
TS
FLOOR
REGULATOR
CATEGOR
SUB-
MATERIAL COMBUSTED
I or
IN
DAT
A-
BAS
E
CONSIDERE
LEVEL OF
Y
Y NAME
CATEGOR
OS
NATIO
N-
WIDE
D FOR
CONTROL
ALTERNATIV
Y
WI
REGULATIO
N
ESABOVE
FLOOR
Harvested
Wastes and residues
OS
8
Section 129
No control
Considering
Wood and
resulting from land clearing,
WI
pollutants
good
Agriculture
orchard, silviculture, nursery,
combustion
1 Wastes
green-house, agricultural,
and forest management
activities and sawmill
operations and con-taining
no more than 5 percent by
volume of contaminants such
as sand, dirt, cardboard, and
paper
practices,
source
separation,
particulate
controls,
scurbbers,
ESPs,
afterburners,
and secondary
combustors
VII- 15
-------
EST. NO. OF
GROUPIN
UNITS
POLLUTAN
SUB-
G WITHIN
ICW
TS
FLOOR
REGULATOR
CATEGOR
SUB-
MATERIAL COMBUSTED
I or
IN
DAT
A-
BAS
E
CONSIDERE
LEVEL OF
Y
Y NAME
CATEGOR
OS
NATIO
N-
WIDE
D FOR
CONTROL
ALTERNATIV
Y
WI
REGULATIO
N
ESABOVE
FLOOR
Constructio
Wastes and residues
OS
9
Section 129
No control
Considering
n,
resulting from: (1) the
WI
pollutants
good
Demolition,
construction, remodeling,
combustion
and Treated
repairing, and demolition of
practices,
Wood
individual residences,
source
Wastes
commercial buildings, and
other structures, and (2) the
treatment of wood products
that are impregnated or
otherwise treated with
various preservatives for the
purpose of protecting or
other-wise extending the
structural properties of the
wood
separation,
particulate
controls,
scurbbers,
ESPs,
afterburners,
and secondary
combustors
VII - 16
-------
EST. NO. OF
GROUPIN
UNITS
POLLUTAN
SUB-
G WITHIN
ICW
TS
FLOOR
REGULATOR
CATEGOR
SUB-
MATERIAL COMBUSTED
I or
IN
DAT
A-
BAS
E
CONSIDERE
LEVEL OF
Y
Y NAME
CATEGOR
OS
NATIO
N-
WIDE
D FOR
CONTROL
ALTERNATIV
Y
WI
REGULATIO
N
ESABOVE
FLOOR
Pathological
<100 lb/hr
Human or animal remains,
OS
Potentia
Section 129
Good
Waste
(primarily
anatomical parts and/or
WI
iiy
pollutants
combustion
Incinerators
poultry
tissue, the bags/containers
several
practices
and
farmers;
used to collect and transport
thousan
Crematories
also small
animal
crematories
, veterinary
centers,
humane
societies,
and
pharma-
ceutical
companies)
the waste material, and
animal bedding (if
applicable)
d
VII - 17
-------
EST. NO. OF
GROUPIN
UNITS
POLLUTAN
SUB-
G WITHIN
ICW
TS
FLOOR
REGULATOR
CATEGOR
SUB-
MATERIAL COMBUSTED
I or
IN
DAT
A-
BAS
E
CONSIDERE
LEVEL OF
Y
Y NAME
CATEGOR
OS
NATIO
N-
WIDE
D FOR
CONTROL
ALTERNATIV
Y
WI
REGULATIO
N
ESABOVE
FLOOR
100 to 500
lb/hr
(primarily
human
crematories
; also
animal
crematories
, veterinary
clinics,
humane
societies,
and
pharma-
ceutical
companies)
OS
WI
2,000
Section 129
pollutants
Good
combustion
practices
VII- 18
-------
EST. NO. OF
GROUPIN
UNITS
POLLUTAN
SUB-
G WITHIN
ICW
TS
FLOOR
REGULATOR
CATEGOR
SUB-
MATERIAL COMBUSTED
I or
IN
DAT
A-
BAS
E
CONSIDERE
LEVEL OF
Y
Y NAME
CATEGOR
OS
NATIO
N-
WIDE
D FOR
CONTROL
ALTERNATIV
Y
WI
REGULATIO
N
ESABOVE
FLOOR
cc
>500 lb/hr
(primarily
animal
disposal
systems for
hospitals,
animal
control
facilities,
and
research
facilities)
OS
WI
100
Section 129
pollutants
Good
combustion
practices
Drum
None
An incinerator used to
ICW
44
55
To include
Thermal
Spray dryer or
Reclaimer
reclaim steel containers (e.g.,
I
Section 129
oxidizers
wet scrubber for
Furnaces
55 gallon drums) for reuse or
to prepare them for recycling
by burning or pyrolyzing
interior and exterior
container coatings and
residues prior to cleaning by
abrasive shot blasting (cont-
ainers must be empty as
defined by RCRA prior to
processing)
list
acid gases;
fabric filter for
metals; GCPs
VII - 19
-------
EST. NO. OF
GROUPIN
UNITS
POLLUTAN
SUB-
G WITHIN
ICW
TS
FLOOR
REGULATOR
CATEGOR
SUB-
MATERIAL COMBUSTED
I or
IN
DAT
A-
BAS
E
CONSIDERE
LEVEL OF
Y
Y NAME
CATEGOR
OS
NATIO
N-
WIDE
D FOR
CONTROL
ALTERNATIV
Y
WI
REGULATIO
N
ESABOVE
FLOOR
Parts
None
An incinerator used to
ICW
332
-1350
Section 129
Thermal
Spray dryer or
Reclaimer
reclaim metal parts such as
I
pollutants
oxidizers
wet scrubber for
Burnoff
paint hooks and racks,
acid gases;
Units
electric motor armatures,
transformer winding cores,
and electroplating racks for
use in their current form by
burning off cured paint,
plastisol (i.e., polyvinyl
chloride and phthalate
plasticizer), varnish, or
unwanted parts such as
plastic spacers or rubber
grommets
fabric filter for
metals; GCPs
VII - 20
-------
EST. NO. OF
GROUPIN
UNITS
POLLUTAN
SUB-
G WITHIN
ICW
TS
FLOOR
REGULATOR
CATEGOR
SUB-
MATERIAL COMBUSTED
I or
IN
DAT
A-
BAS
E
CONSIDERE
LEVEL OF
Y
Y NAME
CATEGOR
OS
NATIO
N-
WIDE
D FOR
CONTROL
ALTERNATIV
Y
WI
REGULATIO
N
ESABOVE
FLOOR
Potential
None
Various non-fossil Section
ICW
322
Section 129
Preliminary
Preliminary:
Section 129
129 solid materials generally
I
pollutants
: fabric
carbon
Solid Mixed
co-fired with other non-fossil
filters for
adsorption for
Feed Boilers
materials or fossil fuels
metals,
scrubbers
for
inorganic
HAPs, and
GCPs for
organic
HAPs;
scrubbers
for Hg from
new units
organic HAPs
and Hg; none
identified for
metals and
inorganic HAPs
VII - 21
-------
SUB-
CATEGOR
Y NAME
GROUPIN
G WITHIN
SUB-
CATEGOR
Y
MATERIAL COMBUSTED
ICW
I or
OS
WI
EST. NO. OF
UNITS
POLLUTAN
TS
CONSIDERE
D FOR
REGULATIO
N
FLOOR
LEVEL OF
CONTROL
REGULATOR
Y
ALTERNATIV
ESABOVE
FLOOR
IN
DAT
A-
BAS
E
NATIO
N-
WIDE
Potential
None
Various non-fossil Section
ICW
153
Section 129
Preliminary
Preliminary:
Section 129
129 liquid materials
I
pollutants
: Existing
Fabric filters for
Liquid
generally co-fired with other
units —
metals and
Mixed Feed
non-fossil materials or fossil
ESPs for
carbon
Boilers
fuels
metals,
adsorption for
scrubbers
organic HAPs
for
and Hg; none
inorganic
identified for
HAPs, and
inorganic HAPs
GCPs for
organic
HAPs.
New units -
- fabric
filters for
metals, gas
absorbers
for
inorganic
HAPs,
GCPs for
organic
HAPs, and
scrubbers
forHg
VII - 22
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ATTACHMENT A
EXAMPLE APPLICABILITY LANGUAGE AND DEFINITIONS
Subpart [?] — Standards of Performance for Solid Waste Incineration Units for Which
Construction is Commenced After [date]
Section [?] Am I subject to this regulation?
(a) Except as provided in paragraph (b) of this Section, the affected facility to which this
subpart applies is each individual Solid Waste Incineration Unit for which construction or
reconstruction is commenced after [date] or for which modification is commenced after [date],
(b) The following facilities are not subject to this subpart:
(1) Any incinerator or other unit required to have a permit under Section 3005 of the Solid
Waste Disposal Act (subpart EEE).
(2) Any materials recovery facility (including primary or secondary smelters) which
combusts waste for the primary purpose of recovering metals.
(3) Any qualifying small power production facility, as defined in Section 3(17)(C) of the
Federal Power Act (16 U.S.C. 769(17)(C)), or qualifying cogeneration facilities, as defined in
Section 3(18)(B) of the Federal Power ACT (16 U.S.C. 796(18)(B)), which burn homogeneous
waste (such as units which burn tires or used oil, but not including refuse-derived fuel) for the
production of electric energy or, in the case of qualifying cogeneration facilities, which burn
homogeneous waste for the production of electric energy and steam or forms of useful energy
(such as heat) which are used for industrial, commercial, heating, or cooling purposes.
(4) Any air curtain incinerator that burns only wood wastes, yard wastes, and clean lumber
and that complies with the opacity limitations in subpart [?].
(5) Any incinerator or other unit which meets the applicability requirements under subpart
Cb, Ce, Ea, Eb, or Ec of this part (i.e., standards or guidelines for municipal waste and hospital
and medical infectious waste incinerators).
(6) Municipal sewage sludge incinerators which meet the applicability requirements under
subpart [?].
Sec. [?] How are the terms used in this subpart defined?
Air Curtain Incinerator means an Incinerator that operates by forcefully projecting a curtain
of air across an open chamber or pit in which burning occurs; Incinerators of this type can be
VII - 23
-------
constructed above or below ground and with or without refractory walls and floor.
Boiler means an enclosed device using controlled flame combustion and having the primary
purpose of recovering and exporting useful thermal energy in the form of hot water, saturated
steam, or superheated steam. The principal components of a boiler are a burner, a firebox, a
heat exchanger, and a means of creating and directing gas flow through the unit. A boiler's
combustion chamber and primary energy recovery section(s) must be of integral design (i.e., the
combustion chamber and the primary energy recovery section(s), such as waterwalls and
superheaters, must be physically formed into one manufactured or assembled unit. (A unit in
which the combustion chamber and the primary energy recovery section(s) are joined only by
ducts or connections carrying flue gas is not integrally designed; however, secondary energy
recovery equipment (such as economizers or air preheaters) need not be physically formed into
the same unit as the combustion chamber and the primary energy recovery section.) Only stand
alone boilers are covered by this definition; waste heat boilers which are associated with
stationary gas turbines or engines are excluded.
Commercial and Industrial Solid Waste Incineration Units means the following types of
Solid Waste Incineration Units: Miscellaneous Industrial and Commercial Waste Incinerators;
Drum Reclaimer Furnaces; Parts Reclaimer Burnoff Units; and [any other applicable
subcategories of boilers and process heaters].
Construction. Demolition, and Treated Wood Waste Incinerator means an Incinerator
combusting Solid Waste comprised, in aggregate, of more than [number] percent by weight, as
measured on a [time period] basis, of wastes and residues resulting from: (1) the construction,
remodeling, repairing, and demolition of individual residences, commercial buildings, and other
structures, including pallets; forming and framing lumber; treated lumber; shingles; tar-based
products; plastics; plaster; wallboard; insulation material; broken glass; painted or contaminated
lumber; chemically treated lumber; white goods; reinforcing steel; and plumbing, heating, and
electrical parts; and (2) the treatment of wood products that are impregnated or otherwise
treated with various preservatives (e.g., creosote, copper compounds, arsenic compounds,
pentachlorophenol, [to be added]) for the purpose of protecting or otherwise extending the
structural properties of the wood.
Drum Reclaimer Furnace means an incinerator used to reclaim steel containers (e.g., 55
gallon drums) for reuse or to prepare them for recycling by burning or pyrolyzing interior and
exterior container coatings and residues prior to cleaning by abrasive shot blasting. (Containers
must be empty as defined by RCRA prior to processing.)
Harvested Wood and Agricultural Waste Incinerator means an Incinerator combusting
Solid Waste comprised, in aggregate, of more than [number] percent by weight, as measured on
a [time period] basis, of wastes and residues resulting from land clearing, orchard, silviculture,
nursery, greenhouse, agricultural, and forest management activities and sawmill operations and
containing no more than 5 percent by volume of contaminants such as sand, dirt, cardboard, and
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paper.
Incinerator means any enclosed device using controlled flame combustion to combust Solid
Waste for the primary purpose of reducing the volume of waste and does not incorporate heat
recovery as part of its integral design.
Liquid Mixed Feed Boiler means a Boiler combusting Solid Waste comprised, in aggregate,
of more than [number] percent by weight, as measured on a [time period] basis, of various non-
fossil liquid materials which are generally co-fired with other non-fossil materials or fossil fuels.
Milled Solid and Engineered Wood Waste Incinerator means an Incinerator combusting
Solid Waste comprised, in aggregate, of more than [number] percent by weight, as measured on
a [time period] basis, of wastes and residues resulting from woodworking manufacturing
activities, containing 2 to 15 percent by weight adhesives, glues, and binders in engineered
woods, and containing no more than 5 percent by weight of contaminants such as cardboard,
paper, paints, and solvents.
Miscellaneous Industrial and Commercial Waste Incinerator means an Incinerator
combusting Solid Waste comprised, in aggregate, of more than [number] percent by weight, as
measured on an annual basis, of byproducts of industrial operations (including combinations
with less that 30% trash or less than 10% medical waste), environmental control device sludges,
waste byproducts, maintenance residues, off-test and out-dated materials, and packaging
materials.
Other Solid Waste Incineration Units means the following types of Solid Waste Incineration
Units: Construction, Demolition, and Treated Wood Waste Incinerators; Harvested Wood and
Agricultural Waste Incinerators; Milled Solid and Engineered Wood Waste Incinerators;
Pathological Waste Incinerators and Crematories; and [any other applicable subcategories of
boilers and process heaters].
Parts Reclaimer Burnoff Unit means an Incinerator used to reclaim metal parts such as paint
hooks and racks, electric motor armatures, transformer winding cores, and electroplating racks
for use in their current form by burning off cured paint, plastisol (i.e., polyvinyl chloride and
phthalate plasticizer), varnish, or unwanted parts such as plastic spacers or rubber grommets.
Pathological Waste Incinerator and Crematory means an Incinerator combusting Solid
Waste comprised, in aggregate, of more than 90 percent by weight, as measured on a daily basis
(and more than 70 percent on an individual batch basis), of only human or animal remains,
anatomical parts and/or tissue, the bags/containers used to collect and transport the waste
material, and animal bedding (if applicable).
Process Heater means an enclosed device using a controlled flame with physical provisions
for recovery and exporting thermal energy to an industrial or commercial process or process
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stream, principally in a form other than hot water, saturated steam, or superheated steam.
Solid Mixed Feed Boiler means a Boiler combusting Solid Waste comprised, in aggregate,
of more than [number] percent by weight, as measured on a [time period] basis, of various non-
fossil solid materials which are generally co-fired with other non-fossil materials or fossil fuels.
Solid Waste means ... [This definition is currently under discussion at EPA. The definition
will apply only to units under Section 129 that combust nonhazardous solid waste.]
Solid Waste Incineration Unit means a distinct operating unit of any facility which combusts
any Solid Waste material from commercial or industrial establishments or the general public
(including single and multiple residences, hotels, and motels).
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ATTACHMENT B
DRAFT SUBCATEGORY DEFINITION SHEETS
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SUBCATEGORY NAME: Miscellaneous Industrial and Commercial Waste Incinerators
ASSIGNED CAA Section (ICWI OR OSWI): Section 129 (ICWI)
GROUPINGS WITHIN SUBCATEGORY: None identified at this time, but further analysis
could lead to subdividing, particularly separating industrial wastewater sludges.
POPULATION STATISTICS: Approximately 150 combustors identified in the EPA
population database; approximately 80 provided ICR responses and are included in the survey
database.
MATERIAL COMBUSTED: Byproducts of industrial and commercial operations, including
combinations with less than 30 percent trash and 10 percent medical waste, environmental
control device sludges, waste byproducts, maintenance residues, off-test and out-dated
materials, and packaging materials.
COMBUSTION DEVICE: All types of incinerators are used, including, but not limited to,
single and multi chamber, fluid bed, rotary kilns, multiple hearth, and tray types. Air pollution
control devices are generally add-on units whose type and efficiency are driven by state
regulations and permit conditions.
BASIS FOR SUBCATEGORY BOUNDS: This subcategory includes solids, liquid, and
sludge incinerators mostly within SIC code 28, but includes incinerators burning similar
materials at all types of facilities.
POLLUTANTS CONSIDERED FOR REGULATIONS: Particulate matter (total and fine),
opacity (as appropriate), S02, HC1, NOx, CO, Pb, Cd, Hg, and dioxins and furans.
FLOOR LEVEL OF CONTROL: Preliminary review indicates CO and particulate control
are present at more than 12 percent of the surveyed units.
REGULATORY ALTERNATIVES ABOVE FLOOR: To be determined
STATUS OF DATA COLLECTION AND ANALYSIS: Initial source list identified;
gathering emission and control data.
ISSUES AND NEEDS: Developing test plan to address pollutants for which there does not
appear to be any emission or permit limit data.
OTHER COMMENTS: Based on the information available, there is no indication of whether
the material being combusted or the equipment design leads to different HAP emissions.
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SUBCATEGORY NAME: Wood and Wood Waste Incinerators
ASSIGNED CAA SECTION (ICWI OR OSWI): Section 129 (OSWI).
GROUPINGS WITHIN SUBCATEGORY:
Milled Solid and Engineered Wood Wastes
Harvested Wood and Agricultural Wastes
Construction, Demolition, and Treated Wood Wastes
Finishing wastes (under consideration)
POPULATION STATISTICS:
All units identified in the database as combusting materials associated with agricultural activities
were individually verified. Of the 18 units listed in the database, no units were found to be
incinerators actually combusting agricultural types of materials. Seven units were no longer in
existence, five units were small MWC's, four units were combusting materials within
combustion devices: one unit was a boiler, and one unit was a process heater. Two agricultural
trade associations and a multinational company were solicited for assistance in identifying
agricultural incineration units within their organizational membership and outside the database.
Neither were able to verify the existence of such units. Thus, it is the belief of the Committee
that incineration units dedicated to the combustion of agricultural waste are few to non-existent.
If such units exist, it is the belief of the Committee that these units are small to very small in
nature.
Twenty two units were identified within the database as combusting various types of wood
materials. Nine units were identified as being "air curtain" incineration units, seven units were
identified as small to very small incineration units without specific pollution controls combusting
various types of wood materials, two units were MWC's, one unit was a teepee, one unit was
an open burning operation, one unit was a boiler, and one unit is no longer in operation.
The Committee believes that air curtain units are properly addressed under Section 129 g(l) of
the rule in which air curtain units are exempted from this rulemaking if they burn wood waste,
yard waste, and clean lumber and comply with opacity limits as set forth by the Administrator. It
is also the understanding of the Committee that under the current MWC rules, there are no
opacity limits specified for air curtain units burning the above materials.
The Committee believes there may be more teepee and open burning operations combusting
wood than has been identified in the database. The Committee offers the thought to EPA for
consideration that various State permit conditions dealing with these units provide valuable
guidance and could be consulted and reviewed prior to the setting of any federal conditions or
standards. The Committee also offers the thought to EPA for consideration that any federal
VII - 29
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requirements for teepees and open burning be based on the State rules.
Of the seven units identified as incineration units combusting various materials consisting of
wood, these units were found to be small to very small in size. These units were also found to
have no specific pollution control and were operating infrequently on an as needed or batch
basis. The Committee offers the thought to EPA for consideration that these units may be
difficult to control outside of good combustion practices. Although the number of units
identified in the database combusting these materials is small, the the Committee believes the
database to be correct in that most wood type materials are combusted as fuels in boilers.
Although this particular category has a small number of units identified, the Committee offers
the thoughts to EPA for consideration that these units probably not be placed or moved into a
broader miscellaneous category and probably only be regulated under the current list of
pollutants in Section 129.
MATERIALS COMBUSTED:
Milled Solid and Engineered Wood Wastes. Wastes and residues resulting from woodworking
manufacturing activities. The specific characteristics of these materials vary depending on the
specie of wood (e.g., pine, oak, and poplar) and the engineered wood (e.g. particleboard,
plywood, and fiberboard) used. The proportion of adhesives, glues, and binders normally found
in engineered wood ranges from 2 to 15 percent by weight depending on the product. The
composition is variable and contains no more than 5 percent by weight of other contaminants
such as cardboard, paper, paints, and solvents.
Harvested Wood and Agricultural Wastes. Wastes and residues resulting from land clearing,
orchard, silviculture, nursery, greenhouse, agricultural, and forest management activities and
sawmill operations. The specific characteristics of these materials vary. The moisture content is
variable. The composition contains no more than 5 percent by volume of contaminants such as
sand, dirt, cardboard, and paper.
Construction. Demolition, and Treated Wood Wastes. Construction wastes are wastes and
residues resulting from the construction, remodeling, and repairing of individual residences,
commercial buildings, and other structures. The composition is variable and generally includes
pallets, forming and framing lumber, treated lumber, shingles, tar-based products, plastics,
plaster, wallboard, insulation material, plumbing, heating, and electrical parts. Demolition
wastes are generally the same as construction wastes but may include broken glass, painted or
contaminated lumber, chemically treated lumber, white goods, and reinforcing steel. Treated
wood wastes are wastes and residues resulting from the treatment of wood products that are
impregnated or otherwise treated with various preservatives (e.g., creosote, copper compounds,
arsenic compounds, pentachlorophenol, [additional preservatives to be added]) for the purpose
of protecting or otherwise extending the structural properties of the wood. The composition is
variable and contains such contaminants as organic and inorganic chemicals, metals, oils, paint,
solvents, and pigments.
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Finishing Wastes. Preliminary data indicate the possibility of incinerators that burn finishing
wastes as a primary feed material. If further evaluation confirms the existence of such
incinerators, a finishing waste category could be added.
COMBUSTION DEVICE: Includes single and multi-chamber and fluidized bed incinerators
(i.e., devices without heat recovery) of various sizes, and also open burning, air curtain
incinerators, and teepees. The types of waste combusted in each of these combustion devices is
illustrated in the following matrix.
COMBUSTIO
N DEVICE
WOOD AND WOOD WASTE TYPE
Milled solid
and
engineered
Harvested
wood and
agricultural
Constructio
n,
demolition,
and treated
Finishing
Open burning
~
?
Air curtain
?
~
?
?
Teepee
~
?
?
?
Incinerator
~
?
~
?
BASIS FOR SUBCATEGORY BOUNDS: Waste and equipment type and possibly size;
other criteria are being considered.
POLLUTANTS CONSIDERED FOR REGULATION: Section 129 Pollutants
FLOOR LEVEL OF CONTROL: No control
REGULATORY ALTERNATIVES ABOVE FLOOR: Yet to be evaluated, but considering
good combustion practices, source separation, particulate controls, scurbbers, ESPs,
afterburners, and secondary combustors.
STATUS OF DATA COLLECTION AND ANALYSIS: The survey database indicates six
units to have test data, and EPA is obtaining these test reports. The database indicates 11 units
to have some kind of control, but independent verification identified no units as having controls.
Two units were identified as being teepee burners and 2 units were identified as air curtains.
ISSUES AND NEEDS: Test data are lacking. Additional testing may be needed for milled,
harvested, and treated wood wastes, although due to the small number of units in the category,
the Committee at this time offers the thought to EPA for consideration that testing may not be
necessary. Instead, the Committee offers the thought to EPA for consideration that adequate
data of good quality may currently exist within State permit conditions and regulations and that
VII-31
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these data could be consider by EPA to establish emission limits.
OTHER COMMENTS: The Committee does not know if the applicability of an agricultural
subcategory is valid. Although independent verification of the 18 facilities listed as agricultural
facilities in the database indicated no such facility or unit exists, the Committee will continue to
carry this category until a more definitive determination is made. For emissions data, the
Committee is considering a EPA test summary, tests reported in the 1998 EPA dioxin emissions
inventory report, and test data reported in the ICR survey responses. A number of survey test
reports have been requested from sources by EPA.
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SUBCATEGORY NAME: Pathological Waste Incinerators and Crematories
ASSIGNED CAA Section (ICWI OR OSWI): Section 129 (OSWI).
GROUPINGS WITHIN SUBCATEGORY:
By mass burn rates as follows: less than 100 lb/hr; 100 to 500 lb/hr; over 500 lb/hr. Profiles for
each of these groups is given below. Grouping is also possible by the amount and composition
of material burned that is not animal or human remains.
Less than 100 lb/hr mass burn rate
Typical user profile- Primarily poultry farmers; secondarily small animal crematories,
veterinary centers, humane societies, and pharmaceutical companies. Little or no training on
operating parameters by a qualified source.
Annual operating hours per unit- unknown
Typical waste profile- Primarily poultry carcasses; secondarily small animal remains, the
bags/containers used to collect and transport the waste material, and animal bedding.
Typical design profile- For poultry units: single chamber systems; fueled with #2 fuel oil, LP
gas, or natural gas; no air or temperature controls; manual operating system; batch fed; no add-
on emission controls.
100 to 500 lb/hr mass burn rate
Typical user profile- Primarily human crematories; secondarily: animal crematories; veterinary
clinics; humane societies; and pharmaceutical companies. Training often required and usually
conducted by manufacturers or service organizations.
Annual operating hours per unit- 700
Typical waste profile- Primarily human remains and associated containers; secondarily: animal
remains, the bags/containers used to collect and transport the waste material, and animal
bedding.
Typical design profile- Multiple chamber systems; fueled with natural gas, LP gas, or #2 fuel
oil; limited air controls; limited temperature controls; manual control system; batch fed; no add-
on emissions control devices.
Greater than 500 lb/hr mass burn rate
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Typical user profile- Primarily animal disposal systems for hospitals, animal control facilities,
and research facilities.
Annual operating hours per unit- 1000
Typical waste profile- Primarily animal remains, the bags/containers used to contain them, and
animal bedding.
Typical design profile- Multiple chamber systems; fueled with natural gas, LP gas, or #2 fuel
oil; air and temperature controls; automatic control systems; mechanical feed with intermittent
charging; no add-on emissions control devices.
MATERIALS COMBUSTED: Pathological waste is waste material consisting of only human
or animal remains, anatomical parts and/or tissue, the bags/containers used to collect and
transport the waste material, and animal bedding, if applicable (from the HMIWIMACT).
COMBUSTION DEVICE:
These combustors are generally single or multiple chamber designs. They are fueled with fossil
fuel and operate with excess air. The wastes, consisting of at least 90% by mass pathological
waste as defined above, are fed as single batches or intermittently fed. (The Committee offers
the thought to EPA for consideration that the 90% limit could be determined on a daily basis,
but maybe at no time any batch consist of less than 70% pathological material.) Typically these
combustors have no add-on emission control devices.
A crematory incinerator could be a pathological waste incinerator which is primarily used to
reduce single batches of human or animal remains and their containers (pathological waste) to
their basic elements with the intent of recovering the cremated remains for memorialization
purposes.
Pathological waste combustors could be classified into the following design categories:
Retort incinerators — multiple chamber incinerator designs in which the secondary chamber
is located directly beneath the primary chamber. The purpose of this configuration is that
the hearth of the primary chamber is heated by the products of combustion flowing through
the secondary chamber. This type of design could be superior for controlling fluids involved
POPULATION STATISTICS:
Nationwide estimate
by size groupings:
Less than 100 lb/hr- Possibly several thousand units
100 to 500 lb/hr- 2000 units
Over 500 lb/hr- 100 units
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in the incineration of human and animal tissue. Because the temperature of the secondary
chamber affects the temperature of the primary chamber, excessive temperature in the
secondary chamber (above 1600°F) could have a tendency to increase emissions due to the
accelerated burning rate of the charge.
In-line incinerators — similar to the retort design in that the chambers share a common wall.
In the in-line design the secondary chamber is not underneath the hearth, but is behind the
primary chamber. This design could be less effective than the retort in destroying the fluids
from human and animal tissue.
Multi-chamber incinerators — multiple chamber incinerator designs consisting of separated
primary and secondary chambers. The secondary chamber is generally located above the
primary chamber with the two chambers having no common ceilings, hearth, or walls
between them. The temperature in the secondary chamber has little or no influence on the
primary chamber temperature. This design could be preferable in processing non-tissue
wastes.
BASIS FOR SUBCATEGORY BOUNDS: As regulation development proceeds, it may
be beneficial to make subdivisions based on size, waste mix, or other criteria.
POLLUTANTS CONSIDERED FOR REGULATION: Section 129 pollutants
FLOOR LEVEL OF CONTROL (EXISTING): Good combustion practice
REGULATORY ALTERNATIVES ABOVE FLOOR (EXISTING): To be
determined.
BEST CONTROLLED SIMILAR SOURCE (FLOOR-NEW): To be determined.
REGULATORY ALTERNATIVES ABOVE FLOOR (NEW): To be determined
STATUS OF DATA COLLECTION AND ANALYSIS: EPA has obtained numerous
emission test reports on criteria pollutants and has requested additional test information for
the Section 129 pollutants. However, the available data are incomplete and do not represent
the scenarios of concern. The Committee offers the thought to EPA for consideration that
EPA request information from the ICR respondents indicating they have information on the
use of add-on emissions control devices.
ISSUES AND NEEDS: The majority of the units in the less than 100 lb/hr grouping are
not represented in the databases.
OTHER COMMENTS: None
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SUBCATEGORY NAME: Drum Reclaimer Furnaces
ASSIGNED CAA SECTION (ICWI OR OSWI): Section 129 (ICWI).
GROUPINGS WITHIN SUBCATEGORY: None
POPULATION STATISTICS:
ICCR Inventory Database - 38 facilities, 44 units
Trade group estimate - 55 units (national population)
MATERIALS COMBUSTED: The drum reclaimer furnace is used to reclaim steel
containers, most often 55-gallon drums, for reuse or to prepare them for recycling. Drums
are prepared for cleaning by abrasive shot blasting by being processed through the furnace,
where interior and exterior coatings and residues are burned or pyrolyzed. Drums must be
empty as defined by RCRA prior to furnace processing. Natural gas is most often fired as
the primary fuel in drum furnaces.
COMBUSTION DEVICE: The typical drum reclaimer furnace is a semi-continuous
tunnel furnace equipped with a high temperature thermal oxidizer. Heat inputs listed in the
ICCR inventory database range from 1.2 MMBtu/hr to 15.6 MMBtu/hr.
BASIS FOR SUBCATEGORY BOUNDS: Due to the easy identification and substantial
number of these units in the ICCR inventory database, their unique purpose, and the
potential for emissions of Section 129 pollutants, they were subcategorized for further
study. Drum reclaimer furnaces are distinct from parts reclaimer burnoff units because the
drum reclaimer furnaces tend to be larger, with greater heat input, are semi-continuous
rather than batch, and hazardous constituents potentially present in the drums may result in
emissions different from those of parts reclaimers.
POLLUTANTS CONSIDERED FOR REGULATION: These include the complete set
of Section 129 pollutants: PM, S02, CO, NOx, Pb, and HC1, dioxins/furans, Hg, and Cd.
PM (RM5) emissions are likely to be fairly well-characterized, and there exist a number of
State regulations on PM emissions from these furnaces. However, queries of the
SURVEYV2.MDB database indicate that no HAPs data are available. The 112(c)(6)
emissions inventory lists a 2,3,7,8-TCDD TEQ emission factor of 1.09E-07 lbs per 1000
drums burned.
FLOOR LEVEL OF CONTROL: This is likely to be a high-temperature thermal oxidizer
along with practices such as ensuring that the drums are empty of all materials that can be
reasonably removed by techniques other than combustion, and thermal oxidizer preheat
prior to introducing drums into the furnace. Numerical emission standards for all Section
129 pollutants are required.
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REGULATORY ALTERNATIVES ABOVE FLOOR: Since the floor control does not
control acid gases, a spray dryer or wet scrubber may be considered, depending on
emissions of acid gases. Similarly, Cd and Pb are not controlled in a thermal oxidizer, and
this suggests specifying a fabric filter. In addition, some good combustion practice
guidelines may be applicable. Numerical emission standards for all Section 129 pollutants
are required.
STATUS OF DATA COLLECTION AND ANALYSIS: Based on SURVEYV2.MDB,
there appear to be no HAPs emission test data available for drum reclaimer furnaces. The
Committee is currently working with trade group representatives to further refine combustor
description and population estimates and obtain existing emissions data on the other
Section 129 pollutants.
ISSUES AND NEEDS: The Committee offers the thought to EPA for consideration that
there may be a paucity of emissions data for certain Section 129 pollutants.
OTHER COMMENTS: Recommendations for stack testing have been forwarded to EPA.
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SUBCATEGORY NAME: Parts Reclaimer Burnoff Units
ASSIGNED CAA SECTION (ICWI OR OSWI): Section 129 (ICWI).
GROUPINGS WITHIN SUBCATEGORY:
Electrical winding reclaimer burnoff units
Non-PVC coated parts reclaimer burnoff units
PVC coated parts reclaimer burnoff units
POPULATION STATISTICS: ICCR Inventory database - 332 units. The Committee
estimates the national populations of the three groupings within the subcategory as follows:
Electrical winding reclaimer burnoff units -300
Non-PVC coated parts reclaimer burnoff units -1000
PVC coated parts reclaimer burnoff units -50
MATERIALS COMBUSTED: This type of incinerator is used to reclaim metal parts for
reuse in their current form. Coatings such as cured paint, plastisol, or varnish or unwanted
parts such as plastic spacers or rubber grommets are burned off a wide variety of metal parts
in these units. Plastisol coatings are comprised of polyvinyl chloride and phthalate
plasticizer. Plastisol and paint both may contain heavy metal pigments. Metal parts fed to
these primarily batch units include paint hooks/racks, electric motor armatures, transformer
winding cores, and electroplating racks.
COMBUSTION DEVICE: Parts reclaimer burnoff units are typically small, batch, fossil
fuel-fired units. The parts reclaimer burnoff units listed in the ICCR Inventory database list
a range of heat inputs from 0.2 MMBtu/hr to 3.7 MMBtu/hr. They are often called burnoff
ovens or pyrolysis units and often not recognized as "incinerators." Operations consist of
loading the cold burnoff oven with metal parts, igniting the thermal oxidizer, if present, and
main burner (both usually natural gas-fired), and allowing the combustible coating or part to
pyrolyze into an fragile ash-like material (often over a period of hours) which may be then
mechanically removed or abrasive-blasted off the metal part. Because of the wide variety of
parts recycled in these units, facility size varies widely, from small electric motor repair
shops to large automobile assembly plants.
BASIS FOR SUBCATEGORY BOUNDS: These units are subcategorized on the basis
of similar purpose — recovering a metal part for reuse in its current form. This places them
in Section 129 rather than in Section 112 with the scrap metal recovery units, which are
excluded by Section 129(g)(1)(A). They are kept separate from drum reclaimer furnaces
because they tend to be smaller batch units and do not have the potential for burning RCRA
hazardous wastes. However, the Committee expects that at least some Section 129
pollutants are emitted from units in this subcategory.
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POLLUTANTS CONSIDERED FOR REGULATION: The Committee believes that
there is a potential for emissions of all Section 129 pollutants from parts reclaimer burnoff
units. Review of SURVEYV2.MDB indicates the existence of HAPs emissions data for at
least two electrical winding reclaimer burnoff units (ICCR Facility IDs - 34017W091 and
550570416). The Committee possesses a data summary of an old stack test of a PVC
coated rack reclaimer burnoff unit that indicates the presence of HC1 and organic
compounds in stack emissions. In addition, any metals present in coating pigments also
have the potential to be emitted.
FLOOR LEVEL OF CONTROL: Based on review ofICCRV2.MDB, at least 25% of
parts reclaimer burnoff units are equipped with thermal oxidizers. This is consistent with the
floor for drum reclaimer furnaces. Practices such as thermal oxidizer preheat and the
removal of excess combustible materials (e.g., paper, rope, cloth, and visibly loose
coatings/parts) could be specified in the floor. Numerical emission standards for all Section
129 pollutants are required.
REGULATORY ALTERNATIVES ABOVE FLOOR: The ICCR Inventory database
lists a number of units controlled by a wet scrubber or a fabric filter in addition to a thermal
oxidizer. The floor level of control (thermal oxidizer) does not control metals or acid gases,
and control alternatives above the floor could examine scrubbers, spray dryers, and fabric
filters. In addition, some of the good combustion practices guidelines may be applicable.
Numerical emission standards for all Section 129 pollutants are required.
STATUS OF DATA COLLECTION AND ANALYSIS: Based on review of
SURVEYV2.MDB, there appear to be at least two parts reclaimer burnoff units with HAPs
emission data. These test reports are being obtained by EPA.
ISSUES AND NEEDS: The Committee has forwarded recommendations to EPA regarding
stack testing of two non-PVC coated parts reclaimers burnoff units and two PVC coated
parts reclaimers burnoff units. The Committee has also forwarded recommendations to EPA
for an analysis of six cured coatings prior to processing in a parts reclaimer burnoff unit.
OTHER COMMENTS: None
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SUBCATEGORY NAME: Unclassified Metals-Related Incinerators
ASSIGNED CAA SECTION (ICWI OR OSWI): Sections 129 or 112
GROUPINGS WITHIN SUBCATEGORY: Not applicable
POPULATION STATISTICS: ICCR Inventory database - 212 units.
OTHER COMMENTS:
The unclassified subcategory represents units that have not been positively identified as
drum reclaimer furnaces, parts reclaimer burnoff units, or scrap metal recovery units based
on reviews of the inventory and survey databases. Survey responses have allowed
identification of many previously unclassified units as parts reclaimer burnoff units, and it is
likely that many currently unclassified units are probably parts reclaimer burnoff units.
Review of the current inventory of unclassified units indicates that many are "incinerators"
associated with fabricated metal products industries such as appliance manufacturing, metal
pipe coating, automotive parts manufacturing, electrical motor/transformer manufacturing,
and pumps and compressors manufacturing. However, it is not clear whether these
incinerators are parts reclaimer burnoff units or plant trash incinerators.
There are entries for semiconductor and electronics manufacturers, as well as ammunition
manufacturers. If the units are used to recover the metals content of the electronic
equipment, or the brass components of ammunition, these could be considered scrap metal
recovery units, and are excluded from Section 129.
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SUBCATEGORY NAME: Potential Section 129 Solid Mixed Feed Boilers
ASSIGNED CAA SECTION (ICWI OR OSWI): Section 129 Boilers (ICWI)
POPULATION STATISTICS: There are approximately 322 boilers identified in the EPA
ICR Survey Version 2.0 database that may fall into this subcategory.
MATERIAL COMBUSTED: Various non-fossil Section 129 solid materials. These
materials are generally co-fired with other non-fossil materials or fossil fuels.
COMBUSTION DEVICE: All types of boilers are used, including bubbling and
circulating fluidized beds, cell-tubes, cyclone-fired, dutch ovens, fire tubes and water tubes,
stokers, wet and dry bottom units, wall-fired and tangentially-fired and package and field-
erected units.
BASIS FOR SUBCATEGORY BOUNDS: This subcategory includes all boilers that fire
above a minimum percentage of Section 129 solid materials. These boilers may potentially
have different controls than the section 129 liquid materials due to the difference in the
physical state of fuels burned.
POLLUTANTS CONSIDERED FOR REGULATION: Section 129 Pollutants
FLOOR LEVEL OF CONTROL: Further analysis is being done.
Existing Sources. At this time, the Committee offers the thought to EPA for consideration
that the preliminary MACT floor level of control may be equivalent to the emission limit for
boilers in this subcategory controlled with fabric filters (or an equivalent control technology)
for controlling metallic HAPs, scrubbers (or an equivalent control technology) for reducing
inorganic HAPs, and good combustion practices for reducing organic HAPs. These thoughts
are based on preliminary control techniques rankings for all boiler subcategories. Further
analysis will look at combinations of controls.
New Sources. Same results as existing sources. In addition, the Committee offers the
thought to EPA for consideration that the preliminary MACT floor for new sources for
controlling mercury may be scrubbers. These results are based on preliminary control
techniques rankings for all boiler subcategories. Further analysis will look at combinations
of controls.
REGULATORY ALTERNATIVES ABOVE THE FLOOR: No regulatory alternatives
have been identified for controlling metals and inorganic HAPs. The Committee offers the
thought to EPA for consideration that alternatives above the MACT floor level of control
for new and existing sources may be carbon absorption for control of organic HAPs and
mercury.
VII - 41
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STATUS OF DATA COLLECTION AND ANALYSIS: The EPA sent an Information
Collection Request (ICR) to facilities with boilers burning potential 129 materials.
Responses provided information on the control techniques being used on the boilers in this
subcategory. Emission test reports were gathered on boilers burning the materials
combusted. However, only minimal data was obtained for some of the section 129
pollutants and HAPs. EPA has requested additional test reports from ICR respondents, but
data gaps may remain.
ISSUES AND NEEDS: The Committee has forwarded to EPA recommendations for
testing of non-fossil materials and control devices. A definition of non-hazardous solid
waste is needed. The level of Section 129 materials that trigger regulation under Section
129 needs to be determined. The Committee needs to further analyze the boilers and their
control equipment in this subcategory to determine if more refined subcategories are
needed.
OTHER COMMENTS: None
VII - 42
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SUBCATEGORY NAME: Potential Section 129 Liquid Mixed Feed Boilers
ASSIGNED CAA SECTION (ICWI OR OSWI): Section 129 Boilers (ICWI)
POPULATION STATISTICS: There are approximately 153 boilers identified in the EPA
ICR Survey Version 2.0 database that may fall into this subcategory.
MATERIAL COMBUSTED: Various non-fossil Section 129 liquid materials. These
materials are generally co-fired with other non-fossil materials or fossil fuels.
COMBUSTION DEVICE: All types of boilers are used, including bubbling fluidized
beds, cell-tubes, cyclone-fired, dutch ovens, fire tubes and water tubes, stokers, wet and dry
bottom units, wall-fired and tangentially-fired and package and field-erected units.
BASIS FOR SUBCATEGORY BOUNDS: This subcategory includes all boilers that fire
above a minimum percentage of Section 129 liquid materials but no Section 129 solid
materials. These boilers may potentially have different controls than the section 129 solid
materials due to the difference in the physical state of fuels burned.
POLLUTANTS CONSIDERED FOR REGULATION: Section 129 Pollutants
FLOOR LEVEL OF CONTROL: Further analysis is being done.
Existing Sources. The Committee offers the thought to EPA for consideration that the
preliminary MACT floor level of control may be equivalent to the emission limit for boilers
in this subcategory controlled with ESPs (or an equivalent technology) for reducing metallic
HAPs, scrubbers (or an equivalent control technology) for reducing inorganic HAPs, and
good combustion practices for reducing organic HAPs. These thoughts are based on
preliminary control techniques rankings for all boiler subcategories. Further analysis will
look at combinations of controls.
New Sources. The Committee offers the thought to EPA for consideration that the
preliminary MACT floor level of control may be equivalent to the emission limit for boilers
in this subcategory controlled with fabric filters (or an equivalent control technology) for
reducing metallic HAPs, gas absorbers (or an equivalent control technology) for reducing
inorganic HAPs, good combustion practices for reducing organic HAPs, and scrubbers for
reducing mercury. These thoughts are based on preliminary control techniques rankings for
all boiler subcategories. Further analysis will look at combinations of controls.
REGULATORY ALTERNATIVES ABOVE THE FLOOR: The Committee offers the
thought to EPA for consideration that alternatives above the MACT floor level of control
could be emission limits for boilers controlled with fabric filters (or an equivalent control
technology) for metals, and carbon adsorption for organic HAPs and mercury. At this time,
VII - 43
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the Committee offers the thought to EPA for consideration that no above the floor
alternatives have been identified for inorganic HAPs.
STATUS OF DATA COLLECTION AND ANALYSIS: The EPA sent an Information
Collection Request (ICR) was sent to facilities with boilers burning potential 129 materials.
Responses provided information on the control techniques being used on the boilers in this
subcategory. Emission test reports were gathered on boilers burning the materials
combusted. However, only minimal data was obtained for some of the Section 129
pollutants and HAPs. EPA has requested additional test reports from ICR respondents, but
data gaps may remain.
ISSUES AND NEEDS: The Committee has forwarded to EPA recommendations for
testing of non-fossil materials and control devices. A definition of non-hazardous solid waste
is needed. The level of Section 129 materials that trigger regulation under Section 129
needs to be determined. The Committee needs to further analyze the boilers and their
control equipment in this subcategory to determine if more refined subcategories are
needed.
OTHER COMMENTS: None
VII - 44
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ATTACHMENT VIII
ICCR Coordinating Committee
\
Thoughts On An
Economic and Benefits Analysis
Framework
Offered To EPA for Consideration
July 29,1998
-------
CONTENTS
Section Page
1 Introduction 1-1
2 Scope of Regulation and Information Sources 2-1
3 An Economic Analysis Methodology 3-1
4 A Benefits Analysis Methodology 4-1
References R-l
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SECTION 1
INTRODUCTION
The thoughts in this document are forwarded to the Agency by the ICCR
Coordinating Committee for consideration by the Agency in performing economic and benefit
analyses for MACT standards the Agency is charged with developing for combustion turbines,
stationary internal combustion engines, process heaters, industrial-commercial-institutional
boilers, and nonhazardous waste incinerators under Sections 112 and 129 of the Clean Air Act.
1.1 Economic and Benefits Analysis for a Significant Regulatory Action
To protect the public's health and welfare the Clean Air Act as amended (CAAA)
provides the U.S. Environmental Protection Agency (EPA) with the authority, among other
things, to establish ambient air quality standards and to undertake actions designed to reduce
the release of pollutants of anthropogenic origin to the atmosphere. The Agency's regulatory
development program includes conducting assessments of health and ecological effects,
exposure and risk, and economic impacts and benefits of Agency initiatives. Economic and
benefits analysis can contribute to informed Agency decisionmaking under the CAAA.
Table 1-1 and Table 1-2 list the primary statutes and executive orders (EO) that are
relevant for the ICCR process. In addition, a summary of the analysis requirements for each
statute and EO are provided. These analysis requirements provide the starting point for
developing economic and benefits analysis methodology.
1.2 Modeling Results Typically Used to Support Required Economic and Benefits
Analysis
The Clean Air Act, other statutes, and executive orders (EOs) do not typically specify
specific methods or impact metrics to be used in analyzing economic impacts or social benefits.
Table 1-3 links commonly used impact metrics with the statutes and EOs they support.
Section 3 of this report presents one modeling approach which could be used for estimating
these impact metrics.
National-level compliance costs and benefits of emissions reductions provide the basis
for cost-benefit analysis of proposed regulations. However, to meet all the
VIII -1-1
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Table 1-1. Statutes and Their Analysis for a Significant Regulatory Action
Statutes Analysis Requirements
Clean Air Act Impact analysis
• cost of compliance
• inflationary effects
• small business effects
• effects on consumers
• effects on energy users
Cost-effectiveness analysis
Determine if significant impact on substantial number
of small entities. If so
• initial regulatory flexibility analysis (IRFA)
• Small Business Advocacy Review Panel
Unfunded Mandates Reform Act Budgetary impact analysis for state, local, and tribal
governments, including impacts on private sector
• consider reasonable range of alternative
regulations
• show that adopted regulation is most cost-
effective and least burdensome
Regulatory Flexibility Act (RFA) and
SBREFA
requirements of the statutes and EOs, analysis of proposed regulations needs to be conducted
at various levels of aggregation.
Market-level models are used to estimate the impact of the regulation on production
levels and commodity prices. Changes in production that resulted from adding the control
costs can affect the magnitude of the social costs, and changes in price help determine the
distribution of social costs between consumers and producers. Market-level models are also
used to assess the change in imports and exports associated with a regulation.
Facility-level analysis, which is based on profit-maximizing behavior, can be used to
evaluate the regulation's impact on plant closures. Facilities may cease to produce a particular
product by closing a product line or stopping production altogether by closing the entire
facility, which is determined by comparing total revenues and total costs at the facility level.
Facility- and company-level impacts are typically analyzed using typical or model facilities.
Thus, impact estimates are for representative facilities and not specific entities.
Table 1-2. Executive Orders and Their Analysis Requirements
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Executive Orders
Analysis Requirements
• Assess costs to determine if regulation is
"significant" (exceeds $100 million)
• If significant, assess benefits
• Consider/evaluate regulatory alternatives
Assess impact on state, local, and tribal governments
(no threshold, does not include impacts on private
sector)
Analyze distribution of costs and benefits with
respect to
• minority populations
• low-income populations
Determine if regulatory action is likely to be
economically significant and to disproportionately
affect children. If so
• evaluate health or safety effects on children
• explain why regulation is preferable to others
a The applicability of EO 13045 to the ICCR is currently being discussed. The benefit methodology is designed to
meet any eventual analysis requirements in the area of children's health for the ICCR process.
Company-level effects are computed by identifying the ownership of facilities and
aggregating the financial effects up to the company level. To satisfy the conditions of the RFA
and SBREFA, economic impact analyses include an assessment of small company impacts.
Several approaches are available to estimate changes in the financial status of firms affected by
regulatory alternatives. The commonly used approach uses ratios computed with financial
data.
Community-level impacts are used to estimate changes in employment and changes in
tax revenues attributable to the proposed regulation. The implementation of the regulation
and the associated resource reallocations may change government revenues and costs at the
federal, state, and local levels. The costs of program administration may be based on
engineering cost analyses or developed by analogy with similar government programs.
Changes in tax revenues that may derive from these impacts can also be calculated.
EO 12866: Regulatory Planning and
Review
EO 12875: Enhancing the
Intergovernmental Partnership
EO 12898: Environmental Justice
EO 13045: Children's Health®
VIII - 1 - 3
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1.3 Overview of Economic and Benefits Analysis for Regulatory Development
Figure 1-1 presents an overview of one approach to economic and benefits analysis for
the ICCR regulatory development. Because the modeling approach is still evolving as
information and data become available, not all the activities represented in Figure 1-1 may be
included in the final analysis. However, this figure does reflect the fundamentals of one
approach and illustrates basic relationships between input data, analysis, and modeling results.
The approach illustrated in this figure is based on established microeconomic theory and
incorporates behavioral market models for the economic analysis. In addition, the analysis is
conducted at the facility level and results aggregated to obtain national impacts. This approach
provides modeling results that support the distributional impact and benefits analysis required
by the statutes and EOs presented in Table 1-3. The majority of the efforts would be focused
on developing the industry profiles, the economic impact analysis, and the benefits analysis.
Industry profiles provide information on the affected entities. Data are typically
obtained from a combination of sources, including information summarized in previous
regulatory support documents; data from publicly available sources; and data from
stakeholders, including any affected trade associations. The information is used to identify
affected commodities; characterize baseline conditions in affected markets, including prices
and quantities, market structure, and international trade; identify and locate producers and
consumers of affected commodities; identify and characterize the firms owning the affected
facilities; and characterize baseline conditions in the communities where affected producers are
located (the populations who will affected by the regulation).
Economic impact analysis analyzes the economic impacts of the regulation. The
industry profile provides the baseline characterization of market conditions from which the
impacts of the regulation are estimated. Frequently an analysis involves using an analytical
computer model to simulate the responses of the affected entities to the regulation. The model
is designed to be consistent with economic theory and to produce integrated estimates of the
responses of affected facilities, firms, and markets. Included are impact estimates for selected
location and company size categories to support impact analysis for small businesses, small
communities, and minority and low-income populations. In addition, multiple model
specifications can be used to generate policy-making information to support evaluation of
different regulatory alternatives.
Benefits analysis involves analyzing all the categories of benefits, by first identifying,
then quantifying and where possible monetizing, the benefits. The benefits of pollution controls
are defined as the increases in human welfare that result from improvements in environmental
quality. Assessing the benefits of air pollution controls requires a conceptual framework that
specifically links reductions in air pollutant emissions to human welfare enhancements. Such a
framework distinguishes the essential components of benefits and ensures that all relevant
benefits are accounted for and not double counted.
VIII - 1 - 5
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Figure 1-1. Overview of Economic and Benefits Analysis
VIII - 1 - 6
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SECTION 2
SCOPE OF REGULATION AND INFORMATION SOURCES
This section identifies the combustion source categories and potential pollutants which
could be included in an economic and benefits analysis and discusses modeling and data issues
specific to the ICCR.
2.1 Affected Universe of Sources
Seven categories of combustion sources are listed for regulatory development under
Section 112 (National Emission Standard for Hazardous Air Pollutants) or Section 129 (solid
waste combustion) of the Clean Air Act. In addition, existing Section 111 (New Source
Performance Standards [NSPS]) regulations affecting some of these source categories are
periodically reviewed and revised. The Clean Air Act requires regulations for all of the
categories listed below to be promulgated under Sections 112 and/or 129 by November 2000.
• industrial boilers (Sections 112 and 111)
• commercial-institutional boilers (Sections 112 and 111)
• process heaters (Sections 112 and 111)
• industrial-commercial solid waste incinerators (Sections 129 and 111)
• other solid waste incinerators (Sections 129 and 111)
• stationary combustion turbines (Sections 112 and 111)
• stationary internal combustion (Sections 112 and 111)
The coordination of these rulemakings will result in more consistent regulations with
potentially greater environmental benefits at a lower cost than piecemeal regulations.
Not included in the scope of the ICCR analysis are combustion units associated with
public utilities and municipal waste combustors (MWCs). These combustion sources are
covered under separate regulations.
2.2 Pollutants Considered
The ICCR Coordinating Committee is evaluating the magnitude of emissions and other
factors to focus regulatory efforts on the most significant pollutants and environmental issues
related to specific sources.
A preliminary list of pollutants to be considered for regulation as part of the ICCR are
VIII -2-1
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• hazardous air pollutants (HAPs) listed in Section 112;
• criteria pollutants regulated under Section 111 NSPS (e.g., S02, NOx, and PM); and
• pollutants listed in Section 129 (i.e., total and fine PM, opacity, S02, NOx, HC1,
CO, lead, cadmium, mercury, and dioxins and furans).
2.3 Modeling Issues
Because regulatory development may evolve onto different time schedules, the
Committee may estimate both incremental and cumulative impacts on a flow basis (i.e., in
stages as cost and benefits information becomes available).
If the economic and benefits analysis is conducted on a flow basis, as information is
developed, the Committee may develop both incremental and cumulative economic and benefits
analyses. The Committee would use incremental impact analysis primarily to assess the
efficiency of regulatory alternatives (i.e., emissions reductions per control costs—lbs/$). In
contrast, cumulative impact analysis could be more appropriate to assess impacts per facility
(such as cost/sales for SBREFA) or when the benefits are not linearly related to emissions
(such as for chemical reactions in the atmosphere for the creation of ozone or for nonlinear
dose-response functions to assess mortality rates).
The Committee plans to analyze small business impacts. The small business impact
assessment could be complicated by the fact that the facility-level impacts may be developed
separately for the various source categories. Thus, to determine the full impact on small
entities all cost and distributional information should be merged together. For example, for a
given entity control costs associated with boilers alone may not be significant compared to the
company's sales. However, when costs associated with all five source categories are summed
together, total control costs may exceed the cost-to-sales ratio threshold used to identify
significant impacts. As a result, if regulatory development evolve onto different time schedules,
the small business analysis may be incomplete.
2.4 Information Sources
The Committee plans to develop estimates of regulatory compliance costs, baseline
emissions, changes in emissions, and the distribution of costs and emissions across sources.
Table 2-1 lists the inputs that should be developed for each subcategory.
Table 2-1. Inputs for Each Subcategory
Facility and combustion unit IDs
Baseline emissions without a new regulation in place
VIII - 2 - 2
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For each control alternative
- incremental capital costs
- incremental operating/maintenance cost
- emission reductions
An estimate of the total population of units in the subcategory
A statement about the representativeness of the subcategory database compared to the
national population of units
Note: Baseline emissions, emission reductions, and control system costs could be developed on either an actual unit
or model unit basis.
In addition, as part of the industry profiles the ICCR Coordinating Committee plans to
collect information on and prepare profiles of significantly affected industries. Potential data
sources include information gathered by EPA and summarized in regulatory support
documents, data available from publicly available sources, and data from stakeholder groups.
2.5 Linking Data
The Committee is planning to develop cost and emissions impacts on a "model source"
basis and plans to try to link the model sources to the ICCR Inventory Database. The above
figure illustrates how model sources could be potentially linked to the ICCR Inventory
Database. Key parameters that could be used to facilitate the linking are unit capacity, fuel
type, operating hours, and source-specific characteristics such as combined-cycle heat recovery
for turbines.
2.6 Common Analysis Parameters
To support the integration of information, the Committee plans to use the following
common baseline projection year and denomination for real dollars in estimating compliance
costs.
• Baseline year of analysis: 2005
• Cost data in real dollars: $1998
In addition, the Committee plans to use common discount rate(s) for estimating market
costs, emission reduction benefits, and social benefits for impacts. One commonly used
discount rate is 7 percent. However, additional discount rates may be used for sensitivity
analysis.
VIII -2-3
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Engineering Analysis
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Figure 2-2. Combine Cost and Emissions Estimates
VIII -2-4
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SECTION 3
ECONOMIC ANALYSIS METHODOLOGY PLAN
This section begins with background information on typical modeling approaches and
presents details on one economic impact modeling approach. Section 3.2 describes information
the Committee plans to develop as part of the industry profile. The theoretical structure for
modeling market components and an approach for operationalizing the model are presented in
Sections 3.3 and 3.4, respectively. Finally, Section 3.5 outlines the screening processes the
Committee plans to use to select focus industries and to determine if upstream fuel or waste
markets should be included in the analysis.
3.1 Background on Economic Modeling Approaches
As discussed in Section 1, the economic impact analysis must satisfy the requirements
of the various statutes and executive orders listed in Tables 1-1 and 1-2, respectively.
However, the scope of the economic impact analysis typically varies in response to the
magnitude and distribution of impacts associated with regulatory alternatives and with the time
and resources available for the analysis. Section 317 of the CAA states that "the assessment
required . . . shall be as extensive as practicable, . . . taking into account the time and resources
available to the Environmental Protection Agency and other duties and authorities which [the
Agency] is required to carry out."
In general, the economic impact analysis methodology should consider the effect of the
different regulatory alternatives. Several types of economic impact modeling approaches could
be used to support regulatory development. These approaches can be viewed as varying along
two modeling dimensions:
1. the scope of economic decisionmaking accounted for in the model
2. the scope of interaction between different segments of the economy
Each of these dimensions was considered. The advantages and disadvantages of each are
discussed below.
3.1.1 Modeling Dimension 1: Scope of Economic Decisionmaking
Models incorporating different levels of economic decisionmaking can generally be
categorized as with behavior responses and without behavior responses (accounting approach).
Table 3-1 provides a brief comparison of the two approaches. The behavioral approach is
grounded in economic theory related to producer and consumer behavior in response to
VIII -3-1
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Table 3-1. Comparison of Modeling Approaches
EIA With Behavioral Responses
Incorporates control costs into production function
Includes change in quantity produced
Includes change in market price
Estimates impacts for
• affected producers
• unaffected producers
• consumers
• foreign trade
EIA Without Behavioral Responses
• Assumes firm absorbs all control costs
• Typically uses discounted cash flow analysis to evaluate burden of control costs
• Includes depreciation schedules and corporate tax implications
• Does not adjust for changes in market price
• Does not adjust for changes in plant production
changes in market conditions. In essence, this approach models the expected reallocation of
society's resources in response to regulation. This approach includes examining impacts at the
facility and market levels, as well as consumer impacts and overall changes in social welfare.
Table 3-2 indicates the range of modeling results that can be developed based on
behavioral response models. The changes in price and production from the market-level
impacts are used to estimate the distribution of social costs between consumers and producers.
The facility-, company-, and community-level impacts are used to assess the distribution of
social benefits and costs that are required by many of the statutes and executive orders.
Facility- and company-level impacts refer to impacts on typical facility or company subgroups.
The Committee does not plan to model impacts on specific/actual entities.
In contrast, the non-behavioral/accounting approach essentially holds fixed all
interaction between facility production and market forces. As a result, a number of important
phenomena in an economic impact analysis, such as price, market quantity, consumer,
international trade, and net social welfare effects, are not well addressed in the nonbehavioral
VIII - 3 - 2
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Table 3-2. Market Model Results using Behavioral Models
Market-level impacts for selected products
• Product price changes
• Production changes
• Consumption changes
• Changes in imports and exports
• Employment
Typical facility-level impacts
• Costs (capital and annual operating)
• Closures
• Production
Typical company-level impacts
• Changes in financial viability
• Financial failure
• Capital requirements and the cost of capital
Community-level impacts
• Employment
• Tax receipts
Social benefits and costs
Environmental impacts
• Residuals releases by pollutant and medium
• Environmental quality by media
approach. These are all important elements of a conceptually sound economic impact analysis.
Moreover, omitting these factors could lead to misleading conclusions. For instance, certain
characteristics of demand conditions in an industry may imply that consumers bear a large
impact of the regulatory burden, thereby mitigating the impact on producers' profits and plant
closures. This response could be estimated if the regulation is modeled in a market context.
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3.1.2 Modeling Dimension 2: Interaction Between Economic Sectors
Because of the large number of markets potentially affected by the ICCR, an issue
arises concerning the level of sectoral interaction to model. In the broadest sense, all markets
are directly or indirectly linked in the economy, thus, all commodities and markets are to some
extent affected by the regulation. For example, the ICCR may indirectly affect the market for
potatoes, because the cost of steel incurred to produce farming equipment may increase with
the regulation in effect. However, the impact of steel prices on the potato market is expected
to be so small that it would be impossible to discern. On the other hand, the impact on the
market for steel may be significant and useful to explicitly incorporate into the model.
Alternative approaches for modeling interactions between economic sectors can
generally be divided in three groups:
• Partial equilibrium model: individual markets are modeled in isolation.
• General equilibrium model: all sectors of the economy are modeled together.
• Multiple-market partial equilibrium model: A subset of related markets are
modeled together, with intersectoral linkages explicitly specified.
Partial Equilibrium Model
In a partial equilibrium approach individual markets are modeled in isolation. The only
factor affecting the market is the cost of the regulation on facilities in the industry being
modeled. Effects on other industries (such as the impact of the change in the price of steel on
the cost of producing potatoes) are not included in the analysis because they are assumed to be
negligible. Typically, the only factor affecting the market is the cost of the regulation on
facilities in the industry being modeled. Under perfect competition, market prices and
quantities are determined by the intersection of market supply and demand curves for the
commodities. The market supply curve is the sum of all facility supply curves, and a market
demand curve is the sum of the demand curves for all demanders of the commodity.
Partial equilibrium models focus on intra- and interfirms effects. Control costs directly
affect facilities' business decisions, such as facility production levels, inputs and raw material
used in the production process, and a facility's decision to continue to operate or shut down.
Individual facility-level responses to control costs are then aggregated to the market level to
determine the market supply.
General Equilibrium Model
General equilibrium models are well suited to analyze large-scope environmental
policies, such as the ICCR, because they capture welfare and employment effects across all
sectors of the economy and specifically model interactions between economic sectors. General
VIII -3-4
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equilibrium models operationalize neoclassical microeconomic theory by modeling not only the
direct effects of control costs, but also potential input substitution effects, changes in
production levels associated with changes in market prices across all sectors, and the associated
changes in welfare economywide. The interactions among the different sectors of the economy
allow for the estimation of distribution effects between different production sectors and across
different consumer groups.
However, one of the major limitations to general equilibrium modeling is that markets
are typically aggregated at a fairly high level to obtain a manageable number of production
sectors for empirical modeling. There is a basic tradeoff in general equilibrium models
between the institutional realism of the model and its mathematical tractability. Jorgenson and
Wilcoxen (1990) have developed one of the larger general equilibrium models, which includes
35 production sectors.
This tradeoff leads to a loss in the level of detail in the analysis, which is particularly
troublesome when evaluating facility- or community-level impacts. In addition, few general
equilibrium models have the capability to evaluate the regional issues that are an integral part of
air quality regulations.
An additional disadvantage of general equilibrium modeling is that substantial time and
resources are required to develop a new model or tailor an existing model for analyzing
regulatory alternatives.
Multiple-Market Partial Equilibrium Model
To account for the relationships and links between different markets without employing
a full general equilibrium model, analysts can use an integrated partial equilibrium model. In
instances where separate markets are closely related and there are strong interconnections,
there are significant advantages to estimating market adjustments in different markets
simultaneously using an integrated market modeling approach.
As an intermediate step between a simple, single-market partial equilibrium approach
and a full general equilibrium approach, identifying and modeling the most significant subset of
market interactions using an integrated partial equilibrium framework provide important
information. In effect, the modeling technique is to link two or more standard partial
equilibrium models by specifying the interactions between supply functions and then solving for
all prices and quantities across all markets simultaneously. The number of linkages is limited
only by the resources allocated to the modeling task.
3.1.3 One Approach for Consideration
One thought the ICCR Coordinating Committee offers to EPA for consideration is a
market modeling approach that incorporates behavioral responses modeled at the facility level.
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In addition, another thought the Committee offers for consideration is use of a multiple-market
partial equilibrium model as described above. Multiple-market partial equilibrium analysis
provides a manageable approach to incorporate interactions between markets into the
economic impact analysis to accurately estimate the impact of regulations.
Figure 3-1 presents an overview of the market linkages in this type of economic impact
modeling approach. For illustrative purposes, the model is segmented into upstream markets,
industry production processes, and downstream markets. The key intermarket linkages
modeled should be the fuel and waste disposal markets' interactions with manufacturing
industries significantly affected by the regulation. These linkages are be discussed in detail in
Section 3.3.
3.2 Industry Profiles
The first step in a modeling approach for the economic impact analysis is to develop
industry profiles. For a selected number of industries (referred to as focus industries), a
detailed industry profile could be developed.1 The industry profiles characterize the baseline
against which the regulatory alternatives could be evaluated.
The industry profiles could
• identify and characterize affected entities;
• define and characterize small entities to prepare to conduct analyses under RFA and
SBREFA;
• define the products produced, including the production process, product attributes,
and production methods and costs (supply determinants);
• identify product characteristics and uses, product users, and possible substitutes
(demand determinants);
• summarize industry organization, including market integration, the structure of
affected markets, financial position of firms, and employment; and
• describe product market characteristics including output prices, relevant price
elasticities, domestic and foreign production levels, and domestic and foreign
consumption levels.
To provide the data used in the economic analysis, the industry profile could identify
affected entities and identify the commodities for which markets could be analyzed. In
Section 3.5 describes the screening process that could be used to select the focus
industries.
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analyzing the economic impacts, model facilities of different sizes or types could be developed,
reflecting the distribution of affected entities. Because government agencies are likely to be
affected by the regulation, the profile includes budget data on the affected agencies.
Demographic data could also be included on the communities in which affected facilities are
located to identify areas with low-income and minority populations. For selected communities,
this information could be used to compare with-regulation conditions with the baseline
without-regulation conditions.
3.3 Modeling Market Components
A limited number of focus industries could be selected to be explicitly modeled in the
economic impact analysis. As shown in Figure 3-1, the primary components of this model are
individual facility production processes, downstream product markets, and upstream input
markets. This subsection discusses each component in turn and then describes the linkages that
could be incorporated into the empirical model.
3.3.1 Production Process
In this model, the production process for an individual facility could be modeled as
shown in Figure 3-2. In the figure the facility's production process is shown inside the dashed
lines. The market for its products (downstream market) is to the right of the dashed box and
the inputs to its production process are shown to the left of the dashed box. Inputs are
segmented into three categories: fuel to generate Btus, landfill for waste disposal, and all other
inputs.
The production process is divided into energy production and the manufacturing
process. Regulatory costs could be modeled as increasing the facility's cost of energy ($/Btus)
for heat, power, and electricity generation. In the example, Fuel A is used to generate Btus in
the facility's existing units and in the process generates pollutants (p). The pollutants are then
treated before emissions (e) are released into the environment. Thus, the cost of the regulation
(CA, end of pipe treatment, for example) affects the facility's cost of generating Btus.
In this modeling approach, because Btus are an input into the manufacturing process, a
change in the price per Btu due to control costs affects the facility's manufacturing process in
the same way as a change in fuel prices or as a tax on fuels. The effect is that the price of a key
input into the manufacturing process has increased ($/Btu) and this price increase will affect the
facility's supply decision, as shown in the upward shift in the supply function in Figure 3-2.
Figure 3-2 also illustrates the facility's fuel switching option. The change in the type of
fuel used is referred to as fuel switching. Alternative units burning Fuel B could be purchased.
If the alternative units burn a cleaner fuel, the control costs associated with the regulation will
be less (CB < CA). If the difference in regulatory costs outweighs the equipment costs of
switching, then the facility can lower its cost of Btus used in the manufacturing process by
VIII - 3 - 7
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Figure 3-1. Economic Impact
VIII - 3 - 8
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Figure 3-2. Focus Industry A
VIII -3-9
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switching from Fuel A to Fuel B.
Regulatory costs could be modeled as also affecting the facility's waste disposal options
by increasing the cost of incineration (Q). In this approach waste disposal could be modeled as
an input into the manufacturing process, and regulation increases the cost of the disposal
option incineration. This increased cost of incineration in turn may increase the facility's
demand for landfill services.
In summary, the direct costs of the regulation (CA and C,) may induce the facility to
modify its production process and change its
• demand for different fuels.
• demand for landfill services, and
• supply of products.
For each focus industry selected, the facility's links to these three markets could be modeled.
The Committee offers the thought to EPA for consideration that the prices for all other inputs
(AOIs) would not significantly change as a result of the regulation, and there is no need to
explicitly model the markets associated with AOIs.
3.3.2 Downstream Product Markets
A partial equilibrium analysis could be conducted for the downstream product market
associated with each selected focus industry. The product market modeled could be the first
well-defined market downstream from the industry. In many instances this could be a market
for intermediate products, as opposed to final products consumed by end users. For example,
if the steel industry is selected as a focus industry, the supply and demand for rolled steel could
be modeled, as opposed to modeling the market for automobiles (that use steel as an input).
In a perfectly competitive market, the point where supply equals demand determines the
market price and quantity. In this analysis, regulation-induced shifts in the supply function in
downstream product markets are determined by the relationship between control costs, input
prices, production costs, and output rates, as described in the previous section. The
Committee offers the thought to EPA for consideration that the demand for the product is
unchanged by the regulation.
Developing the Supply Function
To develop the supply side of the market model, the following steps could be developed
for each market to be analyzed:
1. Establish baseline production levels.
VIII - 3 - 10
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2. Assign fixed and variable control costs for each facility.
3. Estimate supply response from each facility.
4. Aggregate supply responses across facilities to get market supply response.
Baseline supply conditions could be developed to establish the baseline market conditions from
which the impacts of the regulation are measured. For each selected industry, information
could be collected as part of the industry profile to support the develop of the baseline supply
conditions.
As shown in Figure 3-3, the market could be viewed as having two separate supply
segments, and these segments combine to generate the aggregate market supply function. The
two supply groups are
• suppliers that incur control costs to comply with the regulation (panel a),
• suppliers that are not required to bear control costs to comply with the regulation
(panel b).
Figure 3-3 shows one means of looking at the regulation-induced impact on the supply
function. By raising marginal costs, the regulation causes an upward shift in the supply
function of the producers bearing the control costs from S10 to Sn in panel a. The supply
function for the producers not bearing compliance costs remains unchanged by the regulation
(S20) in panel b. The combined effect of the regulation-induced changes in supply for the
different groups causes the aggregate supply function to shift upward and inward from ST0 to
ST, in panel c. This shift in the aggregate supply function leads to a new equilibrium market
price and quantity.
Developing the Demand Function
Even though the Committee offers the thoughts to EPA for consideration that the
demand for the product is unchanged by the regulation, the baseline demand conditions for the
product are important to determining the new equilibrium price and quantity. The intersection
of market supply and market demand curves determines the market price and quantity; thus, the
shape of the demand curve influences the change in price and quantity associated with the
regulation.
The demand function quantifies the change in quantity demanded in response to a
change in market price. This is referred to as the elasticity of demand. Depending on industry
conditions, demand could be modeled as either a single domestic market demand, multiple
domestic market demand segments (e.g., consumer and institutional demand), or as some
combination of domestic and foreign demand segments.
VIII -3-11
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In most cases, demand functions or functional parameters such as demand elasticities
can be found in the literature and modified to the current situation. In other cases, estimates
are not available from the literature, and a "reasonable" range of elasticity estimates could be
assigned based on estimates from similar commodities. Special factors may be considered for
foreign demand, because export demand is typically modeled as more elastic than domestic
demand, taking into account the extent to which non-U.S. products can substitute for U.S.
products in the world market.
3.3.3 Upstream Input Markets
Modeling upstream markets that provide inputs to multiple industries moves away from
a strict partial equilibrium analysis. With upstream markets included in the model, changes in
production levels in one industry can affect the production process in other industries through
changes in the aggregate demand for common inputs.
The Committee offers the thought to EPA for consideration that the fuel and waste
disposal markets are likely to be the primary upstream markets affected by the regulation. As
shown in Figure 3-4, compliance costs associated with Btu production could be modeled as
increasing the price of energy (t $/Btu). This impact on the price of Btus to the facility feeds
back to the fuel markets in two ways. The first is through the company's input decisions for
the type of fuel it is going to burn to generate Btus for its manufacturing process. One
Compliance Costs
Figure 3-4. Fuel Market Interactions with Facility-Level Production Decisions
approach to modeling fuel switching is discussed in Section 3.4.1.
The second feedback pathway to the fuel markets is through the facility's change in
VIII - 3 - 12
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output. The change in facility output is determined by the size of the Btu cost increase
(typically variable cost per output), the facility's production function (slope of facility-level
supply curve), and the characteristics of the facility's downstream market (other market
suppliers and market demander). For example, if consumers' demand for a product is not
sensitive to price, then producers can pass the cost of the regulation through to consumers and
the facility output will not change. However, if only a small number of facilities in a market are
affected, then competition will prevent a facility from raising its prices.
One thought the Committee offers to EPA for consideration is not modeling technical
changes in the manufacturing process. For example, if the cost of Btus increases, a facility may
use measures to increase manufacturing efficiency or capture waste heat. These facility-level
responses are a form of pollution prevention. However, as mentioned, the thought the
Committee offers to EPA for consideration is not incorporating these responses into the model
and considering doing so as beyond the scope of the analysis.
3.4 Operationalizing the Economic Impact Model
The production process is linked to the upstream and downstream markets through the
supply and demand for commodities as described in the previous section. Compliance costs
will affect both the input mix a facility uses in its production process (oil versus natural gas or
incineration of waste versus landfill) and the cost of producing its product (cost per unit output
increases).
Figure 3-5 illustrates the linkages which could be used to operationalize the estimation
of economic impacts associated with compliance costs. In both the upstream fuel and waste
disposal markets, supply could be assumed to not be affected by the compliance costs (supply
is exogenous; it is determined outside the model) and the demand for different fuel types or
waste disposal could be determined by aggregating facility-level production decisions (demand
is endogenous; it is simulated by the model). Similarly, in the downstream markets, product
demand could be assumed to not be affected by compliance costs (exogenous demand), and the
product supply could be determined by aggregating facility-level production decisions
(endogenous supply).
Adjustments in the facility-level production process and upstream and downstream
markets occur simultaneously. A computer model could be used to numerically simulate
market adjustments by iterating over commodity prices until equilibrium is reached (i.e., until
supply equals demand in all markets being modeled).
3.4.1 Computer Model
A computer model that could be used would consist of a series of computer
spreadsheet modules. The modules could integrate the engineering inputs and the facility- and
market-level adjustment parameters to estimate the regulation's impact on the price and
VIII - 3 - 13
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Figure 3-5. Operationalizing the Estimation of Economic Impact
VIII - 3 - 14
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quantity in each market being analyzed. At the heart of this model could be a market-clearing
algorithm that compares the total quantity supplied to the total quantity demanded for each
market commodity.
Current prices and production levels could be used to calibrate the baseline scenario
(without regulation) for the model. Then, the compliance costs associated with the regulation
could be introduced as a "shock" to the system, and the supply and demand for market
commodities allowed to adjust to account for the increased production costs resulting from the
regulation. An iterative process could be used, if the supply does not equal demand in all
markets, a new set of prices could be "called out" and sent back to producers and consumers to
"ask" what their supply and demand would be based on these new prices. This technique is
referred to as an auctioneer approach because new prices are continually called out until an
equilibrium set of prices is determined (i.e., where supply equals demand for all markets).
Supply and demand quantities could be computed at each price iteration. The market
supply would then simply be the sum of responses from individual suppliers within the market.
Included in the iterative process could be an assessment of the plant closure decision. As
illustrated in Figure 3-3, after shutdowns are accounted for, production could be aggregated
across all suppliers to obtain the total supply for each market. The quantity demanded for each
market could be obtained by using the mathematical specification of the demand function.
Modeling Plant Closures
Because the profit-maximizing level of production for a facility may actually reflect
minimizing losses, it may be in the best interest of the facility to liquidate its assets and
shutdown. Plant closures decrease the industry supply; however, this decrease in industry
supply may be partially compensated for by increases in production by other facilities.
One approach to modeling plant closures is to use financial data to assess the impact of
the regulation on profitability. However, a major limitation of this approach is that financial
data are typically available only at the firm level and not at the facility level (where the closure
decision if typically made). Hence, many important factors influencing the closure decision,
such as the age of a specific facility or facility-level production costs, cannot be included in the
analysis. In addition, analyzing individual firms or facilities is very resource intensive.
As a result, one thought the Committee offers to EPA for consideration is not trying to
predict the probability of closure at specific facilities (such as plant X will close but plant Z will
not). Alternatively, another thought the Committee offers to EPA for consideration is
assessing the probability of closure for "typical" facilities and using this to adjust the aggregate
market supply. This approach provides information on national-level impacts associated with
plant closures but is less useful for estimating regional- and community-level impacts.
VIII-3 - 15
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Modeling Fuel Switching
Similar to modeling plant closures, the thought the Committee offers to EPA for
consideration is modeling fuel switching decisions for "typical" facilities. Facility-level data on
specific equipment and production modification costs associated with fuel switching would be
expensive and time consuming to develop. As inputs into the analysis, the thought offered to
EPA for consideration is using secondary data on the population of units with fuel switching
capabilities and on the relative changes in fuel prices to simulate fuel switching.
The Manufacturing Energy Consumption Survey (MECS) is one potential source of
secondary data to model fuel switching. Table 3-3 presents information on the existing
capacity of units with the capability to switch from coal to alternative energy sources. The
fourth column of Table 3-3 implies that, of the total capacity of coal units in the U.S.,
46.1 percent have the capability to switch to alternative energy sources. And, of the switchable
units, 69.5 percent (column 6) have the capability to switch to natural gas. Figure 3-6 presents
information on establishments' likelihood of switching based on changes in the relative price of
competing fuels. As part of the 1994 MECS, approximately 28 percent of establishments
indicated that they would switch from fuel oil to natural gas if the relative price difference
between the two fuels were to change 5 percent.
An additional source of secondary data on fuel switching behavior is shown in
Table 3-4, which contains fuel price elasticities developed by the U.S. Department of Energy
for the National Energy Modeling System (NEMS). The diagonal elements in the table
represent own price elasticities. For example, the table indicates that for steam coal, a
1 percent change in the price of coal will lead to a 0.499 percent decrease in the use of coal.
The off diagonal elements are cross price elasticities and indicate fuel switching propensities.
For example, for steam coal, the second column indicates that a 1 percent increase in the price
of coal will lead to a 0.061 percent increase in the use of natural gas.
When using secondary data, analysts should use caution when incorporating this type of
fuel switching information into an impact analysis. For example, the MECS data in Figure 3-6
are based on stated intentions for hypothetical price scenarios and are subject to possible bias
associated with stated intentions versus actual behavior. In addition, the price elasticities in
Table 3-4 include not only behavioral changes associated with fuel switching, but also changes
in energy use from market-induced changes in production.
However, secondary data on fuel switching can provide useful insights into potential
impacts associated with changes in the relative price of fuels. As described in the following
section, a screening test could first be conducted to determine if fuel switching resulting from
the regulation is likely to be have a "measurable" economic impact. If so, a fuel switching
feedback loop (shown in Figure 3-5) could be incorporated into the model.
VIII - 3 - 16
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to price
• 38.7%) — estimate cannot be
provided
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more expensive alternative
$ Current $ Alternative
Fuel Fuel
$ Current
Fuel
Figure 3-6. Percentage of Establishments by Level of Price Difference Between
Residual Fuel Oil and Less Expensive Natural Gas that Would Switch Fuels
Source: U.S. Department of Energy, Energy Information Administration. December 1997. "1994 Manufacturing
Energy Consumption Survey." DOE/EIA-0512(94). Washington, DC: U.S. Department of Energy.
VIII-3 - 18
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Table 3-4. Fuel Price Elasticities
Own and Cross Elasticities in 2015
Inputs
Electricity
Natural Gas
Coal
Residual
Distillate
Electricity
-0.074
0.092
0.605
0.080
0.017
Natural Gas
0.496
-0.229
1.087
0.346
0.014
Steam Coal
0.021
0.061
-0.499
0.151
0.023
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0.036
0.650
-0.587
0.012
Distillate
0.247
0.002
0.578
0.044
-0.055
Source: U.S. Department of Energy, Energy Information Administration. January 1998. "Model Documentation
Report: Industrial Sector Demand Module of the National Energy Modeling System."
DOE/EIA-M064(98). Washington, DC: U.S. Department of Energy.
3.4.2 Aggregating Social Costs
After the model has reached equilibrium in all the relevant markets, the changes in price
and quantity could be used along with engineering cost estimates to calculate total social costs.
Engineering costs could be categorized in terms of fixed costs and variable costs. Total social
costs should be the sum of total fixed costs plus total variable costs for all industries.
Total fixed costs could be determined by weighting the engineering fixed cost estimates
($/unit) by the number of units in facilities that decide to comply with the regulation (i.e., the
affected population less plant closure units). Total variable costs could be determined by
weighting the engineering variable cost estimates ($/output) by the output simulated by the
computer model (i.e., baseline output less the change in production resulting from the
regulation). Finally, the change in price could be used to allocate social costs between
consumers and producers.
3.5 Screening Procedures for Determining Scope of Analysis
Because the modeling approach outlined in this document has been developed prior to
reviewing preliminary estimates of costs and emissions reductions, the focus industries to be
selected and final scope analysis are yet to be determined. Focus industries could be selected
on the following screening criteria:
• high total cost impacts,
• high relative cost impacts (e.g., industry cost-to-sales ratios or $/Btu),
VIII - 3 - 19
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• potential small business impacts,
• significant benefits impacts,
• available information,
• large variation in the distribution of costs, and
• high fuel switching potential.
It is likely that total industry costs could be closely related to Btu usage and that relative
industry cost impacts could be related to Btu intensity per unit output. In addition, the fuel mix
industries use to meet their energy requirements may also significantly affect the magnitude of
the regulation's impact. Table 3-5 shows the total inputs of energy and the fuel source for
selected industry groups.
A preliminary screening process could be conducted to assess potential impacts on the
fuel markets and on the waste disposal market. This preliminary screening could be used to
determine the level of effort appropriate for modeling the fuel markets and waste disposal
market. For example, if it is determined that the regulation's average impact on the cost of
energy ($/Btu) is less than 1 percent, this change could be considered not large enough to
induce significant fuel switching activity.
Alternatively, if the change in the cost of energy resulting from the regulation is large
enough to induce fuel switching (significantly affecting at least one fuel type), these effects
could try to be captured in the model. For example, if there is a significant switch from coal to
natural gas, the price of natural gas may increase. This price increase could impact units and
industries regardless of whether they are "affected" or "nonaffected" by engineering control
costs. Although the change in the fuel prices may be small, the aggregate impact on the
national economy may by large.
A similar screening process could be conducted for waste disposal to determine if the
regulation's impact has the potential to significantly affect the facility's disposal decision and,
hence, the market for waste disposal. An additional issue which might be considered for waste
disposal is that these markets are likely to be regional, and selected community-level impacts
may be large even if national-level impacts are small.
VIII - 3 - 20
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SECTION 4
BENEFITS ANALYSIS METHODOLOGY PLAN
4.1 Theoreti cal B asi s for B enefits Analy si s
The benefits of pollution controls are defined as the changes in human welfare that
result from improvements in environmental quality. Therefore, assessing the benefits of air
pollution controls requires a conceptual framework that specifically links reductions in air
pollutant emissions to human welfare enhancements. Such a framework serves to distinguish
the essential components of benefits and to ensure that all relevant benefits are accounted for
and that double counting of benefits is avoided.
Figure 4-1 illustrates one simple framework for this purpose. It depicts three
fundamental "systems"—an environmental system and two human (market production and
household) systems—and a number of flows to and from these systems. Pollutant releases are
shown as flows of residuals from human activities into the environmental system (i.e., the
atmosphere), which disperses and transforms them. The flows from the environmental system
to the human systems are defined as environmental "services," which support human life itself,
in addition to a variety of production, leisure, and other related human activities. Humans, who
reside in the household system, either receive these services directly (e.g., through the air they
breathe) or indirectly through the market production system and market exchange (e.g.,
through purchases of agricultural products whose yields depend in part on air quality). In
essence, humans ultimately convert these service flows into human welfare, which is abstractly
measured by household or individual "utility."
Through this simple framework, pollution controls can be represented as reductions in
pollutant releases to the environment. These reductions lead to a change in both the quantity
and quality of the flow of environmental services to human systems and, consequently, to
changes in utility and human welfare.
The next conceptual hurdle is to translate changes in human welfare to a monetary
measure of value. The most widely accepted measure in the economics profession for valuing
changes in utility is individuals' maximum willingness to pay (WTP).1
'A related concept is willingness to accept (WTA), which refers to the minimum
compensation individuals would be willing to accept to forgo a positive change. It is also a
benefits measure and may be more appropriate in certain circumstances; however, under certain
restrictive assumptions WTP and WTA will be equal. For simplicity one thought the Committee
offers to EPA for consideration is focusing on WTP as the conceptual basis for assessing benefits.
VIII -4-1
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Human Welfare
Figure 4-1. Conceptual Framework Linking Pollutant Releases to Human Welfare
The use of WTP to measure the value of an improvement in air quality amounts to asking
what monetary payment would exactly offset (and thus be inversely equivalent to) the change
in utility that an individual experiences with cleaner air. When the WTP for all changed
environmental service flows is summed across all affected individuals, it provides a measure of
the total aggregated benefits of the improvement in air quality.
4.2 Analysis Framework
Assessing the benefits of reductions in pollutant emissions involves three fundamental
analytical steps:
• Identify the primary pollutants of concern and the ways in which environmental
services are impaired or damaged by emissions of these pollutants.
• Quantify the measurable physical effects of changes in emissions.
• Monetize the values associated with the physical effects and related behavioral
changes.
VIII -4-2
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A thorough identification of damages associated with pollutant emissions recognizes the
various ways in which pollutants interact and are transformed in the environment. Figure 4-2
illustrates this for several major categories of air pollutants: volatile organic compounds
(VOCs), hazardous air pollutants (HAPs), particulate matter (PM), nitrogen oxides (NOx), and
sulfur oxides (SOx). The atmospheric interaction of pollutants creates a myriad of pathways
through which emissions ultimately affect air quality and impair the services that humans
receive from the environment. These changes in environmental services can be mapped into
broad categories of potential damages, such as those described below (adapted from Freeman,
1993):
• Direct damages to humans:
— health damages: health damages include primarily the increased morbidity (both
acute and chronic) and mortality associated with exposures to harmful
substances.
— visibility and other aesthetic damages: impaired visibility, odors, and other
adverse aesthetic effects can result from air pollution.
• Indirect damages through ecosystems:
— reduced economic productivity of ecosystems: these damages include the
reduced productivity of commercial ecological systems used for agriculture,
forestry, and commercial fishing in the areas affected by releases.
— reduced quality of recreation activities: recreation damages result primarily
from the reduced quality of ecological resources used for recreational activities,
such as fishing and swimming.
— reduced intrinsic/nonuse value: nonuse damages include the lost value
individuals associate with preserving, protecting, and improving the quality of
resources that is not motivated by their own use of these resources. This
category of damages also includes the altruistic and bequest values individuals
associate with improvements in the welfare of others.
• Indirect damages through nonliving systems:
— reduced productivity of materials and structures: impacts such as soiling
corrosion and decay of materials and structures, in effect, reduce their
productivity.
As shown in Figure 4-3, quantifying the impacts of pollutant emissions could require
two general stages of modeling. The first stage involves translating pollutant emissions to air
quality by applying air dispersion models. Additional fate and transport modeling of pollutants
could describe how atmospheric concentrations are further transported and accumulate in other
VIII - 4 - 3
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Sulfur Oxides Particulate Nitrogen
(mainly sulfur dioxide) Matter Oxides
Hazardous Air Pollutants and
Volatile Organic Compounds
Human Health Materials Aquatic Ecosystems Vegetation and Visibility
Terrestrial
Ecosystems
Figure 4-2. Identification of Damage Pathways for Major Air Pollutants
Source: Adapted from National Acid Precipitation Assessment Program. June 1993. 1992 Report to Congress.
p. 25.
VIII -4-4
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media, such as water and biota. Applying these models to both baseline (without regulation)
and control (with regulation) emissions levels could provide estimates of reductions in ambient
pollutant concentrations in air, water, and soil. The second stage involves translating changes
in ambient concentrations to changes in physical effects. For example, by applying existing
concentration- response functions the effects of reductions in ambient concentrations could be
measured as reductions in adverse health risks or increases in crop yields and visibility.
Quantification of these physical effects depends on the existence and reliability of fate
and transport models, concentration-response functions, and other supporting data such as for
emissions, climatic conditions, population distributions, and land uses. Where these models or
data are not available, the benefits analysis could be limited to a thorough qualitative
description of impacts.
Assigning monetary value to the physical effects is an extension of the quantification
steps, as shown in Figure 4-3. This step requires analysts to estimate total WTP for
improvements in environmental quality and/or the related changes in physical effects, by
appropriately aggregating individuals' WTP for the changes in question. As shown in
Table 4-1, several empirical valuation methods involving primary data collection exist for
estimating individuals' WTP.
Nonbehavioral approaches generally measure the cost of repairing or treating air
pollution damage. Assuming that these damage costs are avoidable through improvements in
air quality, they are often used to approximate benefits. Although rather straightforward and
easy to apply, nonbehavioral approaches are not specifically designed to measure WTP and
may therefore only provide rough (and usually lower-bound) approximations of true benefits.
Behavioral approaches are preferable on theoretical grounds because they are designed
to measure WTP; however, they also suffer from limitations. Revealed preference approaches
rely on observed behavior to infer individuals' WTP for environmental (or related)
improvements, but the data requirements are generally burdensome, and they require
assumptions about individuals' perceptions of the improvements. Stated preference methods
use surveys to directly elicit individuals' WTP for similar improvements, but it is often difficult
to validate whether individuals' stated WTP reflects their true WTP.
Resource constraints effectively preclude the direct application of these methods for
benefits analysis. Therefore, WTP estimates could be derived from existing studies that have
either applied these methods directly (in related contexts) or that have used the results of these
methods from other studies. In principle, through a process of "benefits transfer," estimated
values for specific air quality-related impacts (e.g., health effects), air quality improvements, or
even emissions reductions could be taken from existing studies and applied to the present
context. For example, reductions in mortality could be valued using information from studies
that have applied revealed or stated preference methods to estimate individuals' WTP to reduce
their risks of premature death. The accuracy and reliability of value estimates from transfer
VIII - 4 - 5
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Figure 4-3. General Procedural Framework for the Quantification and Valuation of
Emissions Reductions
VIII -4-6
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Table 4-1. Classification of Valuation Methods
Be
Characterization of
Valuation Method
Types of Assumptions
Required for Valuation
Method
Valuation Method
havioral
•
•
Revealed
Preference
Market exists for product •
produced with affected air •
resource services, or •
Marketed good or service
used jointly with air
resources affected in
production or
consumption activities
Factor income
Hedonic
Travel cost
Stated
Preference
Impacts on air resource
and/or its services can be
described and valued in
simulated market using
expressed preferences
• Contingent valuation
• Conjoint analysis
Nonbehavior
al
Damage
Cost
Value of affected air
resource is at least equal
to the cost of remediation
• Replacement costs
• Restoration costs
• Cost of illness
Source: Adapted from Smith, V.K., and J. V. Krutilla. 1982. "Toward Formulating the Role of
National Resources in Economic Models." In Explorations in Environmental Economics,
V.K. Smith and J.V. Krutilla, eds., pp. 1-43. Baltimore, MD: Johns Hopkins Press.
procedures such as these will depend on the quality of original studies and the
correspondence between the original study context to this policy context.
Valuation of the quantified effects of the proposed emissions controls therefore depends
on the existence and quality of applicable valuation studies and estimates. Where these are
not available, the benefits analysis is again limited to a thorough qualitative description of
impacts.
4.2.1 Identify the Primary Pollutants of Concern and Characterize Their Effects
The first step in the analysis could be to identify the primary pollutants of concern for
each of the five combustion source categories and to characterize the damages associated
with each of these. Pollutants can be generally categorized as either HAPs, as specified in
Section 112 of the Clean Air Act Amendment of 1990, or as conventional criteria
pollutants. One thought the Committee offers to EPA for consideration is dropping
VIII -4-7
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pollutants with very low emissions.
Criteria pollutants, including carbon monoxide (CO), NOx, VOCs, S02, PM, and lead,
are emitted in large quantities from a variety of sources across the nation. The impacts of
these pollutants have been widely studied, and they are associated with a broad range of
damages to human health and the environment. EPA has systematically reviewed and
summarized the findings of these studies and identified the primary adverse effects of each
of these pollutants (EPA, 1997a). For those criteria pollutants that are found to be emitted
in large quantities from ICCR sources and expected to be significantly reduced by the
emissions controls under consideration, their primary adverse effects could be summarized
and the key areas of uncertainty associated with these and other potential effects could be
discussed.
HAPs are less ubiquitous than the criteria pollutants; however, they are of particular
concern because of their potential to cause serious health problems even at relatively low
levels of exposure. They may also cause a number of other damages to the environment
and human welfare. HAPs can be broadly categorized according to their carcinogenic
potential, as well as to their potential to cause noncancer health effects. Known or
suspected carcinogens could be given greater priority in the benefits analysis because of the
severity of cancer and because these effects are more easily quantified than noncancer
effects. HAPs could be categorized according to their carcinogenic weight-of-evidence and
giving higher priority to those that are known human carcinogens. Other important
considerations in prioritizing HAPs of concern are their persistence in the environment and
their potential to bioaccumulate. These properties are particularly important for examining
multipathway exposures beyond direct inhalation. One thought the Committee offers to
EPA for consideration is prioritizing HAPs according to their quantity of emissions prior to
ICCR controls and to the expected reduction in emissions as a result of these controls. For
those HAPs receiving the highest priority, the thought the Committee offers to EPA for
consideration is summarizing the evidence regarding their potential to cause human health
and other damages.
4.2.2 Select and Characterize Emissions Sources for Emissions, Air Quality,
and Exposure Modeling
Measuring emissions, air quality changes, and exposure impacts will not be feasible for
each of the sources covered by the ICCR. To the extent that this type of modeling is
conducted for this rule, it could be based on a sample of affected facilities. There are three
general approaches for doing this.
The first, and most thorough, approach could be to select a (stratified) random sample
of facilities that is large enough to support statistically valid inferences regarding the
universe of affected sources and then model impacts at each of these facilities. The main
limitations of this approach are that it would still require modeling a relatively large sample
VIII - 4 - 8
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of facilities and that the randomly selected facilities may not be those with the most accurate
and complete data required for modeling.
The second approach could be to select and characterize a limited number of model
facilities for each of the source categories. Rather than being selected at random, these
facilities could be "average" or "typical" facilities, chosen to be reasonably representative of
a large portion of the affected facilities. This limits the number of facilities to be modeled,
but it also increases the uncertainty for extrapolating results to the larger universe of
facilities.
The third approach could be to select only one or two facilities for analysis and to use
these as case studies. These case study facilities could be selected to represent worst case
scenarios or to reflect more typical conditions; however, the results would probably be
interpreted as illustrative. They probably do not provide an appropriate basis for
quantifying aggregate impacts from the larger universe of affected facilities.
Time, data, and other resource constraints for this analysis could effectively preclude the
first approach; therefore, any emissions, air quality, or exposure modeling could be based
on either a model facility approach or a case study approach. These approaches are
discussed below for specific applications. An alternative to modeling air quality and
exposure could be to transfer results from similar studies that have already modeled these
processes. This approach is also outlined below.
4.2.3 Model Emissions for Selected Pollutants
The ICCR Emissions Database that is being compiled contains detailed pollutant-specific
emissions testing data for a wide variety of emissions sources. Possibly these data could
provide a basis for linking emissions rates (e.g., pounds per year) to facility characteristics
(unit type, fuel type, design capacity, operating rate, control device) and for defining model
facilities based on these characteristics. If possible, aggregate emissions for all affected
sources could be estimated (under baseline and with-regulation scenarios) by mapping each
source in the ICCR Inventory Database to a corresponding model facility.
For certain pollutants, estimates of aggregate emissions reductions could provide an
adequate basis for estimating their associated benefits. That is, using benefits transfer, as
described above, these changes could be directly valued using average per-ton values
derived from other studies. This is the case, for example, for reductions in most of the
criteria pollutant emissions. For this reason, one thought the Committee offers to EPA for
consideration is air quality and exposure modeling for HAPs only.
4.2.4 Select and Model Primary Exposure Pathways
To the extent that air quality and exposure modeling is conducted for ICCR pollutants,
VIII -4-9
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it could be limited to HAPs. For this reason this discussion focuses on models for
estimating human health risks. As shown in Figure 4-4, human exposures can be divided
between direct exposures (through inhalation) and indirect exposures. Indirect exposures
can occur through several physical and biological pathways as a result of atmospheric
deposition of pollutants to land and water. Ultimately humans can ingest or absorb harmful
substances through the consumption of water and food or through incidental contact.
Modeling Direct Inhalation Exposure
The Human Exposure Model (HEM) could be used to estimate health risks from HAP
emissions. Built around an air dispersion model such as the Industrial Source Complex
(ISC) models, HEM estimates ground-level pollutant concentrations at specific points in the
vicinity (within 50 km) of an emissions source and the number of individuals exposed at
each point. The key inputs to HEM include information regarding
• pollutant-specific emissions rates,
• plant configuration (e.g., stack height, stack diameter),
• local meteorological conditions (e.g., average wind speed),
• local terrain/topographical conditions (e.g., urban vs. rural), and
• local population distribution.
The HEM results could provide the basis for estimating direct cancer and noncancer health
risks from inhalation of HAPs to populations surrounding an emissions source.
Because HEM is highly automated, it could be relatively easily adapted to model direct
exposures under a variety of alternative conditions. A model facility could be specified by
selecting a vector of key input values that is reasonably representative of a larger group of
facilities. This process could be repeated for other model facility specifications. With an
estimate of the number of facilities corresponding to each model facility, the HEM results
from the model facility runs could be used to develop rough estimates of exposures (and
therefore risks) for all affected facilities.
The level of effort required for this approach increases substantially with the number of
model plants selected, the number of pollutants modeled, and the number of emissions
scenarios (baseline and with-regulation) included. Therefore, in selecting the number of
model plants, it could be important to trade off the increase in precision against the added
cost of including an additional model plant. The number of pollutants could also be limited
through an additional screening process, for example, by using preliminary HEM results to
estimate baseline maximum individual risks (MIR) (described in Section 4.2.5) and
excluding pollutants with very low risk from subsequent HEM runs.
VIII - 4 - 10
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Figure 4-4. Physical and Biological Routes of Exposure
VIII - 4 - 11
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Modeling Indirect Multipathway Exposures
The modeling of indirect exposures builds on the air dispersion component of the direct
exposure model and extends it into other media where pollutants are further transported
and dispersed. It probably requires additional layers of modeling and supporting data,
which increase substantially with the number of indirect exposure scenarios examined. For
example, as shown in Figure 4-4, atmospheric deposition to water can lead to indirect
exposure through fish consumption. This requires information on the geographical
distribution of surface water in the vicinity of the emissions source, as well as
bioaccumulation rates of pollutants in fish tissue, fishing participation rates by anglers, and
fish consumption rates. Deposition to land can lead to uptake by plants and animals that are
subsequently consumed by humans. Among other things, this requires information on how
these plants and animals are locally distributed both before and after they are exposed.
The level of effort and data required to comprehensively estimate indirect exposures
precludes the use of a model plant approach to estimate aggregate impacts from these
exposures. Nevertheless, a more limited case study approach of selected exposure
pathways could serve to illustrate the types and magnitude of indirect impacts associated
with HAP emissions from combustion units.
An important step in conducting such a case study analysis is to select the pollutants and
the emissions sources or model plants to be analyzed. The fundamental criteria for
selecting pollutants could be their persistence in the environment and potential to
bioaccumulate. This tends to focus attention on inorganic pollutants such as mercury,
arsenic, lead, cadmium, and chromium and on dioxins and radioactive pollutants. Case
study facilities could be selected by identifying one or two emissions sources with average-
to-high emissions of the key pollutants and also selecting sites with reasonably
representative characteristics for indirect exposures (e.g., a site with a high proportion of
surface water acreage and a typical rural or urban site).
The next step could be to select the specific exposure scenarios to be assessed at the
case study site(s). One useful approach for illustrating potential impacts through indirect
exposures could be to select two general categories of exposure scenarios: one
representing high-end exposure assumptions and another representing more central-
tendency exposure assumptions. For example, the high-end scenario might include a
subsistence fisher scenario that assumes lifetime exposure and high fish consumption rates.
A central-tendency scenario might include shorter-term exposure and more average
consumption rates for a recreational angler. An additional step might be to estimate the
number of individuals represented by each exposure scenario; however, this is considerably
more difficult than estimating populations exposed via inhalation because, in addition to
residential location, it requires broad-based information on behaviors (e.g., recreation, food
consumption). Because of this uncertainty and because the case study results are less
appropriate for drawing inferences for all affected facilities, one thought the Committee
VIII - 4 - 12
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offers to EPA for consideration is that estimating exposed populations for indirect
exposures be given much less priority than for direct inhalation exposures.
The case study analyses of indirect exposures will most likely not provide results that are
appropriate for estimating aggregate impacts at all affected facilities; however, they could
provide the basis for estimating plausible ranges of individual health risks under alternative
scenarios and for identifying the pollutants of primary concern. In addition, the case study
sites could provide a framework for examining exposures and risks to sensitive ecological
systems. For example, by examining indirect exposures through atmospheric deposition of
pollutants to surface water, this provides one basis for modeling exposures and potential
risks to aquatic ecosystems as well. Again, such an analysis would only serve to illustrate
the potential for ecological damages from combustion sources affected by the proposed
rule.
4.2.5 Estimate Human Health Risks Through the Modeled Exposure Pathways
Modeling each of the exposure pathways described above could provide the foundation
for estimating both the cancer and noncancer risks associated with these exposures.
Inhalation Cancer Risks
The HEM analysis described above could provide estimates of ambient ground-level
concentrations of selected pollutants at various points, generally within 50 km of each
model facility. Overlaying these estimates onto Census data and linking populations to each
of these points could allow the estimation of the number of people exposed at each modeled
concentration level. Applying concentration-response functions (i.e., cancer slope factors)
to the concentration estimates for the carcinogenic pollutants could allow an estimate of
cancer risk in at least two ways:
• maximum individual cancer risk (MIR)—cancer risk to the individual(s) living at
the point with the highest measured concentrations of carcinogens
• cancer incidence—the total number of additional expected cancer cases as a
result of the modeled exposures
Estimating pollutant-specific MIR under baseline conditions could also screen out
pollutants that do not contribute significantly to risks (e.g., those with estimated MIR
below 10"6) and, probably do not need to be carried over to the analysis of risk reductions
with regulation. Both risk measures could be estimated under baseline conditions, as well
as under specific emissions control scenarios, thus providing estimates of reductions in
cancer risks at the modeled facilities. The estimated levels and reductions in cancer
incidence could be extrapolated to all affected facilities using estimates of the number of
facilities corresponding to each model facility.
VIII - 4 - 13
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Inhalation Noncancer Risks
To assess noncancer risks, the HEM results could be compared to reference
concentrations (RfCs) for the noncarcinogenic HAPs. RfCs are considered to be protective
thresholds for inhalation exposure and are defined as the estimate of the daily atmospheric
concentrations associated with inhalation exposures that are likely to be without deleterious
effect during a lifetime. The ratio of a pollutant's estimated concentration to its RfC (i.e.,
the hazard index [HI]) could indicate the noncancer threat from the pollutant. As with
cancer risks, the HI could be estimated for the maximally exposed individual. Under
baseline conditions these results could be also used to screen out the noncarcinogenic HAPs
whose His are estimated to be well below 1 even for the most highly exposed individual. In
contrast to cancer risks estimates, however, there is probably insufficient information to
estimate the incidence of noncancer health effects. Nevertheless, the population data could
be used to estimate the number of individuals in the vicinity of the model facility that are
exposed to levels exceeding the RfCs.
Noncancer risks could be estimated under baseline conditions, as well as under specific
emissions control scenarios. The estimated reduction in the number of individuals at risk of
noncancer effects could be extrapolated to all affected facilities in the same way that cancer
risks are aggregated across facilities.
Indirect Cancer and Noncancer Risks
Using the estimated exposure concentrations from the case study scenarios, indirect
risks could be estimated using the same general approach as for inhalation risks. The
primary differences are that the estimated concentrations are in different media than air
(e.g., fish tissue), and they will affect humans through different routes, frequencies, and
durations of exposure. MIR cancer and noncancer risks could be estimated using the high-
end exposure assumptions. In principle, the central-tendency exposure scenarios could also
be used to estimate cancer incidence and populations at risk of noncancer effects in the
vicinity of the case study facilities. However, as discussed above, there is probably much
more uncertainty in estimating populations exposed via indirect pathways, and these results
are likely to be much more difficult to extrapolate to all the affected combustion sources.
As a result, to depict potential indirect risks from the affected sources, the case study
analysis could rely primarily on estimates of individual risk under alternative exposure
scenarios.
Ecological Risks
As discussed above, the case studies for estimating indirect exposure risks may also
provide a useful framework and context for examining ecological risks. For example,
estimated concentrations of persistent and bioaccumulative toxics in surface water, soils,
and biota could be used as a starting point for estimating exceedances of critical ecological
VIII - 4 - 14
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benchmarks. As with noncancer effects, it is probably difficult to extrapolate these impacts
beyond the case study area and to assess them in monetary terms; nevertheless, they could
be used to illustrate the potential threats to ecological systems from combustion sources.
An alternative indicator of ecological risks could be the proximity of combustion sources
to known locations of threatened and endangered species of plants and animals. This
proximity could be assessed by merging source location information from the ICCR
Inventory Database with threatened and endangered species occurrence data from the
Nature Conservancy. Proximity does not necessarily imply threat, but by comparing the
number of such species in the vicinity of affected facilities with numbers in other areas of
the U.S., it might be possible to develop a rough indicator of potential threats to vulnerable
species.
Alternative Approaches to Assessing Risks
Regardless of whether the approaches outlined above for quantitatively assessing cancer,
noncancer, and ecological risks prove to be feasible, the analysis could include a qualitative
assessment of these risks. For indirect and ecological risks in particular this could include
reviewing the evidence linking the primary HAPs of concern to health and ecological effects
and discussing the exposure pathways that are likely to be most problematic.
In addition, one possible alternative to the modeling approaches discussed above for
quantifying risks is to transfer the results from EPA's Study of Hazardous Air Pollutant
Emissions from Electric Utility Steam Generating Units (EPA, 1998). Using methods very
similar to those outlined above, this analysis measured baseline cancer and noncancer risks
(direct and indirect) for as many as 67 HAPs from 684 plants in the U.S. For direct
inhalation risks, it also measured long-range transport of HAP emissions and risks
extending beyond the local vicinity of plants.
The results of the direct inhalation cancer risk assessment are shown in Table 4-2. All
noncancer risks from inhalation were found to be well below the RfCs for the pollutants of
concern.
Assuming that emissions from the combustion units covered by the ICCR have the same
per-unit impacts as those from electric utility units, the cancer estimates in Table 4-2 could
be used to infer baseline risks for ICCR sources. Although this assumption may be
reasonable, using this approach could involve an evaluation of the comparability of electric
utility and ICCR risks. It could include a comparison of pollutants emitted, plant
configurations, and plant locations. To the extent that there are systematic differences in
these factors, the analysis could evaluate how these differences are expected to affect the
cancer risk estimates for ICCR sources. For example, if ICCR sources are generally
located in more densely populated areas, then, other things equal, the per-unit health
impacts of their emissions are expected to be greater than those from electric utility units.
VIII - 4 - 15
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Table 4-2. Baseline Estimated Cancer Risks from Direct Exposure (Inhalation) to
HAP Emissions from Electric Utility Steam Generating Units: Local and Long-
Range Impacts in 1994
Oil-Fired Plants (137 plants)
Coal-Fired Plants (426 plants)
Pollutant
Nationwid
e
Emissions
(tons/yr)
Max i in Li in
Individual
Risk
(MIR)
Annual
Cancer
Incidence
Nationwi
de
Emissions
(tons/yr)
Max i in u in
Individual
Risk
(MIR)
Annual
Cancer
Incidence
Radionuclides
—
1 x 1CT5
0.2
—
Not
estimated
0.7
Nickel
320
5
0.2
52
1 x 10"8
0.038
Chromium
3.9
5 x 1CT6
0.02
62
2 x 10"6
0.15
Arsenic
4
1 x 1CT5
0.05
56
3 x 10"6
0.37
Cadmium
1.1
2 x 1CT6
0.006
3.2
3 x 10"7
0.005
All Others
8 x 1CT7
0.006
1 x 10"6
0.028
Total
6 x 1CT5
0.5
4 x 10"6
1.3
Using this approach suggests a discussion of the potential biases and uncertainties inherent
in such a transfer. One important limitation of this approach is that it could only provide
estimates of baseline direct cancer risks. Reductions in cancer risks could be inferred
directly from percentage reductions in emissions rather than from modeled cancer risks
under alternative emissions control scenarios.
The indirect risk assessment for electric utility units used four model plants to assess
risks from three HAPs—arsenic, mercury, and dioxins—under various exposure
assumptions. For arsenic and dioxins, the highest predicted cancer MIRs were in the 10"4
range but most were below 10"5. For mercury, developmental and neurological effects
through fish consumption were of primary concern but were not specifically quantified. The
applicability of these results to ICCR combustion sources depends on the representativeness
of the four model plants used in the analysis. Using the results of the electric utility analysis
suggests a comparison of the four model plants with the universe of ICCR combustion
sources.
4.2.6 Estimate Monetary Benefits
Although emissions reductions from ICCR combustion sources have the potential to
improve human welfare in a number of ways, only some of these effects are quantifiable and
even fewer can be expressed in dollar terms. As discussed previously, valuing these
emissions reductions is likely to require the application of benefits transfer, because
VIII - 4 - 16
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conducting an "original" valuation study is beyond the scope of analysis. Therefore,
benefits could be estimated by applying values derived in comparable studies. Two areas in
particular present opportunities for transferring benefits estimates. The first area is the
estimated reductions in cancer incidence (from direct inhalation exposures), which could be
conservatively interpreted as reductions in mortality and could be valued using previously
derived estimates of the value of a "statistical life." The second area is the estimated
reductions in criteria pollutant emissions (in particular VOCs, PM, and S02), which could
be valued using per-ton benefit estimates derived from EPA's analysis of the revised
NAAQS for PM and ozone (EPA, 1997b).
The Value of Cancer Cases Avoided
Based on a large number of economic studies that have examined individuals' WTP to
reduce (or WTA compensation to increase) their risk of death, the value of a statistical life
is generally assumed to be roughly equal to $5 million (ranging from about $ 1 million to as
much as $14 million). The value of cancer incidence reductions from direct inhalation
exposures could be approximated using this statistical life value; however, it is important to
recognize the limitations of this approach. Valuing each avoided cancer case at an average
of $5 million may overestimate their value because not all cancers are fatal and because
many cancers may only occur after a long latency period (in which case the number of life
years saved is less and, thus, the value of statistical life may be lower). Conversely, the
dread, pain-and-suffering, and involuntariness associated with cancer risks from HAP
exposures may make these risks relatively more valuable to avoid. In contrast to the
estimates of cancer incidence, other measures of risk reductions, such as reductions in
cancer MIRs and reductions in noncancer risks, can not be quantified in terms that can be
valued.
The Value of Reduced Criteria Pollutant Emissions
In its analysis of the revised NAAQS for PM and ozone, EPA estimated the nationwide
emissions reductions of several criteria pollutants that would be necessary to achieve certain
ambient standards. The Agency also estimated many of the benefits that would result from
achieving the standards. In particular it estimated the monetary value of several categories
of avoided health effects, and the value of improved visibility, reduced soiling of
households, and improved yields for certain crops. By apportioning these benefits to the
different categories of pollutants, it may be possible to approximate the benefits per ton of
emissions reductions for each one. These estimates are summarized in Table 4-3. Applying
these per-unit values to the criteria pollutant emissions reductions resulting from the
proposed controls on ICCR sources could provide a rough estimate of their benefits.
For both benefits transfer applications discussed above, there are several areas of
uncertainty, both in the original benefit estimates and in the transferability of these estimates
to the ICCR context. Therefore, the results of the analysis could be qualified with a
VIII - 4 - 17
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discussion of the sources and potential magnitudes of these uncertainties.
4.2.7 Characterize and Summarize Benefits
The final step in the analysis is to summarize the findings. One important component of
this could be to review the quantified and monetized benefit estimates and to qualitatively
assess those benefits that were not quantifiable. This also could involve a discussion of the
primary areas of uncertainty in the analysis.
Table 4-3. Per-Ton Benefit Estimates for Selected Criteria Pollutants (1990 $)
Pollutant
Lower-Bound Estimate
Upper-Bound Estimate
VOCs
$444
$2,007
PM10
$9,600
$9,800
S02
Eastern U.S.
$4,409
$9,764
Western U.S.
$3,190
$3,805
Source: U.S. Environmental Protection Agency. 1997b. Memorandum from McKeever, Michele,
EPA/ISEG, to Conner, Lisa, EPA/ISEG. November 4. Benefits transfer analysis for pulp and
paper.
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Freeman, A. Myrick III. 1993. The Measurement of Environmental and Resource Values:
Theory and Methods. Washington, DC: Resources for the Future.
Industrial Combustion Coordinated Rulemaking Federal Advisory Committee. "Industrial
Combustion Coordinated Rulemaking: Organizational Structure and Process."
June 1997. Revision 2.
Jorgenson, Dale W., and Peter J. Wilcoxen. 1990. "Environmental Regulation and U.S.
Economic Growth." RAND Journal of Economics 21(2):314-340.
National Acid Precipitation Assessment Program. June 1993. 1992 Report to Congress.
p. 25.
Smith, V.K., and J.V. Krutilla. 1982. "Toward Formulating the Role of National
Resources in Economic Models." In Explorations in Environmental Economics,
V.K. Smith and J.V. Krutilla, eds., pp. 1-43. Baltimore, MD: Johns Hopkins Press.
U.S. Department of Energy, Energy Information Administration. December 1997. "1994
Manufacturing Energy Consumption Survey." DOE/EIA-0512(94). Washington,
DC: U.S. Department of Energy.
U.S. Department of Energy, Energy Information Administration. January 1998. "Model
Documentation Report: Industrial Sector Demand Module of the National Energy
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Energy.
U.S. Environmental Protection Agency. October 1997a. The Benefits and Costs of the
Clean Air Act, 1970 to 1990. Research Triangle Park, NC: Office of Air Quality
Planning and Standards.
U.S. Environmental Protection Agency. 1997b. Memorandum from McKeever, Michele,
EPA/ISEG, to Conner, Lisa, EPA/ISEG. November 4. Benefits transfer analysis
for pulp and paper.
U.S. Environmental Protection Agency. 1997c. Regulatory Impact Analyses (RIA) for the
for the Particulate Matter and Ozone National Ambient Air Quality Standards and
Proposed Regional Haze Rule. Research Triangle Park, NC: Office of Air Quality
Planning and Standards.
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U.S. Environmental Protection Agency. February 1998. Study of Hazardous Air Pollutant
Emissions from Electric Utility Steam Generating Units—Final Report to
Congress. Vol.1. EPA-453/R-98-004a. Research Triangle Park, NC: Office of
Air Quality Planning and Standards.
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