  SEQ CHAPTER \h \r 1 

MEMORANDUM

TO:		Toni Jones, U.S. Environmental Protection Agency

FROM:  	Eastern Research Group, Inc.	

DATE:  	November 21, 2011

SUBJECT:  	Summary of the Secondary Impacts of Control Options for CISWI
Standards for Reconsideration Proposal

1.0  Purpose

This memorandum summarizes the secondary impacts associated with control
devices used to comply with the proposed emission standards for
Commercial and Industrial Solid Waste Incineration (CISWI) units. 
Secondary impacts result from the consumption of fuel, water, and
electricity and generation of solid wastes by control devices.  Section
2.0 provides a background for the standards, Section 3.0 presents the
secondary impact estimates associated with control devices necessary for
all units to comply with the standards, and Section 4.0 presents the air
emission estimates associated with the secondary impacts.  

2.0  Background

The U.S. Environmental Protection Agency, under section 129 of the Clean
Air Act (CAA), is required to regulate emissions of the following nine
pollutants from CISWI units: hydrogen chloride (HCl), carbon monoxide
(CO), lead (Pb), cadmium (Cd), mercury (Hg), particulate matter (PM),
dioxins/furans (PCDD/PCDF), nitrogen oxides (NOx), and sulfur dioxide
(SO2). 

On December 1, 2000, the EPA established new source performance
standards (NSPS) and emission guidelines (EG) for CISWI units under
Sections 111 and 129 of the CAA.  In 2001, EPA was granted a petition
for reconsideration regarding the definitions of “commercial and
industrial waste” and “commercial and industrial solid waste
incineration unit.”  Also in 2001, the United States Court of Appeals
for the District of Columbia Circuit granted the EPA’s voluntary
remand, without vacatur, of the 2000 rule.  In 2005, the EPA proposed
and finalized the CISWI definition rule which revised the definitions of
“solid waste,” “commercial and industrial waste,” and
“commercial and industrial waste incineration unit.”  In 2007, the
United States Court of Appeals for the District of Columbia Circuit
vacated and remanded the 2005 commercial and industrial solid waste
incineration definition rule.

 

On March 21, 2011, the EPA promulgated revised NSPS and EG as its
response to the voluntary remand that was granted in 2001 and the
vacatur and remand of the commercial and industrial solid waste
incineration definition rule in 2007.  In addition, the standards
re-development included the 5-year technology review of the new source
performance standards and emission guidelines required under Section
129.  Following that action, the Administrator received petition[s] for
reconsideration and identified some issues that warranted further
opportunity for public comment.  In addition, data were received that
enabled the EPA to revise the CISWI inventory of waste-burning kilns and
energy recovery units to more accurately reflect the definition of
non-hazardous secondary materials.

The EPA has developed maximum achievable control technology (MACT)
floors and emission limits in the development of the proposed standards.
The development of the proposed emission limits used to determine these
options is discussed in more detail in a separate memorandum.1  

3.0   Summary of Secondary Impact Estimates 

To comply with the final standards, facilities may need to install the
following types of controls on CISWI units:

Wet scrubbers (WS) to reduce HCl and SO2 emissions, 

Fabric filters (FF) to reduce Cd, Pb, and PM emissions,

Duct sorbent injection/fabric filter (DIFF) systems to reduce HCl and
SO2 emissions,

Regenerative Thermal Oxidizers (RTO) to reduce CO emissions,

Selective non-catalytic reduction (SNCR) to reduce NOx emissions,

Activated carbon injection (ACI) systems to reduce PCDD/PCDF and Hg
emissions, and

Afterburner retrofits, tune-ups, or oxidation catalysts to reduce CO
emissions.

Additional electricity is required to operate the pumps and fans
associated with wet scrubbers, FF, DIFF, and SNCR systems.  Also, water
and subsequent wastewater disposal are required to operate wet
scrubbers, DIFF and SNCR systems.  Activated carbon injection systems
require activated carbon as well as a method to dispose of the dust
produced from the ACI system.  RTOs require natural gas to oxidize the
carbon monoxide in the flue gas.  Although afterburners require natural
gas to operate, these are primarily replacing existing afterburners, so
the change in natural gas consumption may be minimal, and we do not have
the data to be able to estimate this change.

The algorithms used in the cost analysis provide annual cost estimates
for electricity, water, and carbon requirements as itemized components
of the annual costs for the control device.2  These cost elements for
the control devices anticipated to be installed to comply with the final
standards were then summed up to provide an estimate of the overall
costs of electricity, water and activated carbon.  To estimate the
secondary impact components (e.g., electricity, water, and dust from
carbon), the itemized annual cost of each component was divided by the
unit price of the component utilized by the algorithm.  To estimate the
additional annual fuel requirements for each combustion unit operating
an RTO the annual operating hours were multiplied by the natural gas
fuel requirement.

Two control scenarios were considered for the proposed standards: 

Compliance by additional control only, and

Compliance or choose another method of disposal, depending on which cost
was lowest.

These scenarios are described in sections 3.1 and 3.2, respectively.
3.1  Compliance by Additional Control Only

In the first scenario, each CISWI unit in all subcategories complies
with the proposed MACT floor standards by installing the anticipated
control devices and associated monitoring equipment. 

Table 3-1 shows the estimated values for secondary impacts, by
subcategory, for the “All units comply” scenario.

Table  3-1. Secondary Impacts for MACT Compliance 

All units comply	 	 	 	 

Subcategory	Electricity Required (MWh/yr)	Water Required (gal/yr)
Activated Carbon Required (ton/yr)	Dust Produced (ton/yr)	Supplemental
Fuel Requirements (MMft3/yr)

ERU - Liquid/Gas	5,637	21,303,000	0	308	-

ERU - Solids	187,499	90,042,168,599	4,424	 16,721	-

Incinerators	7,725	102,581,104	235	335	-

Small, remote	140	0	5	10	-

Kilns	48,624	 424,226,569	5,328	5,450	1,288

Totals	249,626	 90,590,279,272	9,993	22,824	1,288



3.2  Compliance or Alternative Method of Disposal

The second scenario entails a situation where facilities considered
alternative disposal options and, where the alternative disposal methods
are less expensive than adding control devices to comply with the
standards, would instead cease burning waste and use alternative
disposal methods.  In addition to the electricity, water, and activated
carbon requirements for those facilities that choose to add control
devices to comply with the standards, secondary impacts also occur when
alternative waste-handling methods are used.  For the majority of
incinerators, it would be less expensive to send waste to a landfill
than to comply with the proposed emission limits (i.e., facilities would
choose to shut down CISWI units).  According to our estimates based on
unit capacities and annual operating hours, this would result in
approximately 110,417 tons per year of additional waste being sent to
landfills.  This would also result in subsequent landfill gas emissions
from decomposition of this waste, which would likely be sent to a
landfill gas flare.  This gas flaring would result in emissions of NOx
and CO, with some SO2, PM, and small amounts of mercury also being
emitted.  Further details on landfill emissions can be found in a
separate memorandum.3  For small, remote units, it was determined that
it is generally less expensive for facilities to segregate their waste
and divert the nonferrous metal and chlorinated plastic to a landfill
than to landfill all of their waste.  In this case, the landfilled
material is considered non-digestable and will not contribute
significantly to landfill emissions. While not quantified in our
analysis, there are also likely to be secondary emissions associated
with the transport of the waste to a landfill site.  These emissions
would be site-specific and depend primarily on the number of trips, type
of vehicle, and distance traveled necessary to transport the waste to
the landfill.  

Table 3-2 shows the estimated values for secondary impacts resulting
from each facility choosing the lowest-cost option for its units. 
Details regarding the unit-specific, lowest-cost options can be found in
the compliance cost memorandum.2 

Table  3-2.  Secondary Impacts for MACT Compliance for Lowest Cost
Options

Lowest Cost Option	 	 	 	 	 

Subcategory	Electricity Required (MWh/yr)	Water Required (gal/yr)
Activated Carbon Required (ton/yr)	Dust Produced (ton/yr)	Supplemental
Fuel Requirements (ft3/yr)	Annual Waste Diverted to Landfill (ton/yr)

ERU - Liquid/Gas	5,637	21,303,000	0	308	-

	ERU - Solids	 187,499	 90,042,168,599 	 4,424	 16,721	-

	Incinerators	494	8,178	67	68	-	110,417

Small, remote	29	0	1	3	-

	Kilns	48,624	 424,226,569	5,328	5,450	1,288

	Totals	 242,283	 90,487,706,345	 9,820	 22,549 	1,288	110,417



4.0 Summary of Secondary Impact Emission Estimates

Emission factors from EPA’s eGRID4 database were used to calculate
emissions resulting from the electricity required for additional control
devices, and emission factors from EPA’s AP-42 emission factor
document5 were used to calculate emissions resulting from the combustion
of additional fuel for RTOs.  Increased electrical use from the control
options will require additional fuel to be burned in power plants,
resulting in emissions of CO2 and criteria pollutants, such as SO2, NOx,
and CO. Emissions of these pollutants (caused by increase in
electricity) were estimated using EPA’s eGRID database.4  The eGRID
database summarizes emissions of criteria pollutants on a per electrical
usage basis (lb emitted per MW-hr), on a national average or state
average basis.  For this analysis the national average was used.  To
estimate emissions from combustion of natural gas, emission factors from
EPA’s AP-42 emission factor document were used.5  

Tables 4-1 summarizes the resulting emissions of CO2, CO, NOx, and SO2
from combustion of natural gas supplemental fuel and increase
electricity usage for the control options analyzed for existing sources.
 Table 4-2 shows the resulting emissions of CO2, CO, NOx, and SO2 from
combustion of natural gas supplemental fuel and increase electricity
usage for the lowest cost options analyzed for existing sources.

The Appendix to the secondary impacts analysis contains the spreadsheets
supporting these summaries. Table  4-1.  Secondary Emission Impacts for
MACT Compliance

Subcategory	Electricity Requirements and Emissions (tons/yr)
Supplemental Fuel Requirements and Emissions (tons/yr)	Total Secondary
Emissions (tons/yr)

	Mw-hr/yr	CO2 Emitted	NOx Emitted	SO2 Emitted	Million ft3 Natural Gas/
yr	CO2 Emitted	CO Emitted	NOx Emitted	CO2 Emitted	CO Emitted	NOx Emitted
SO2 Emitted

ERU - Liquid/Gas	5,637	3,747	5.46	14.82	-	-	-	-	3,747	-	5.46	14.82

ERU - Solids	187,499	124,626	181.56	493.02	-	-	-	-	124,626

	-	181.56	493.02

Incinerators	7,725	5,135	7.48	20.31	-	-	-	-	5,135	-	7.48	20.31

Small, remote	140	93	0.14	0.37	-	-	-	-	93	-	0.14	0.37

Kilns	48,624	32,319	47.08	127.85	1,288	77,287	54.1	64.4	109,606	54.1
111.49	127.85

Totals	249,626	165,920	242	656	1,288	77,287	54.1	64.4	243,207	54.1	306
656

a. National emission factors from Egrid4 for EGUs.









	b. Natural gas emission factors from AP-42.5









	

Table  4-2.  Secondary Emission Impacts for Lowest Cost Option

Subcategory	Electricity Requirements and Emissions (tons/yr)
Supplemental Fuel Requirements and Emissions (tons/yr)	Total Secondary
Emissions (tons/yr)

	Mw-hr/yr	CO2 Emitted	NOx Emitted	SO2 Emitted	Million ft3 Natural Gas/
yr	CO2 Emitted	CO Emitted	NOx Emitted	CO2 Emitted	CO Emitted	NOx Emitted
SO2 Emitted

ERU - Liquid/Gas	5,637	3,747	5.46	14.82	-	-	-	-	3,747	-	5.46	14.82

ERU - Solids	187,499	124,626	181.56	493.02	-	-	-	-	124,626	-	181.56
493.02

Incinerators	494	328	0.48	1.30	-	-	-	-	328	-	0.48	1.30

Small, remote	29	19	0.03	0.08	-	-	-	-	19	-	0.03	0.08

Kilns	48,624	32,319	47.08	127.85	1,288	77,287	54.1	64.4	109,606	54.1
111.49	127.85

Totals	242,283	161,039	235	637	1,288	77,287	54.1	64.4	238,327	54.1	299
637

a. National emission factors from Egrid4 for EGUs.









	b. Natural gas emission factors from AP-42.5









	References

1.  “CISWI Emission Limit Calculations for Existing and New Sources
for Reconsideration Proposal” Memorandum from Eastern Research Group,
Inc. to Toni Jones, U.S. Environmental Protection Agency.  November 3,
2011.

2.  “Reconsideration Proposal Compliance Cost Analyses for CISWI
Units” Memorandum from Eastern Research Group, Inc. to Toni Jones,
U.S. Environmental Protection Agency.  November 20, 2011.

3.  “Reconsideration Proposal Baseline Emissions and Emissions
Reductions Estimates for Existing CISWI Units” Memorandum from Eastern
Research Group, Inc. to Toni Jones, U.S. Environmental Protection
Agency.  November 20, 2011.

4. EPA eGRID database eGRID2007 Version 1.1.  Year 2005 summary tables
located at
www.epa.gov/cleanenergy/documents/egridzips/eGRID2007V1_1_year05_Summary
Tables.pdf

5. U.S. Environmental Protection Agency, 1995.  Compilation of Air
Pollutant Emission Factors (AP-42), Fifth Edition, Volume 1:  Stationary
and Point Sources, Chapter 1: External Combustion Sources.

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