TECHNICAL
SUPPORT
ASSISTANCE
OF
MACT
IMPLEMENTATION
DRAFT
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
FACILITY
PRIORITIZATION
GROUPING
Submitted
to:

U.
S.
Environmental
Protection
Agency
Region
4
RCRA
Permitting
Section
Waste
Management
Division
61
Forsyth
Street,
SW
Atlanta,
Georgia
30303
Submitted
by:

Tetra
Tech
EM
Inc.
101
Marietta
Street
NW,
Suite
2400
Atlanta,
Georgia
30303
EPA
Region
:
4
Site
:
Multi­
state/
Multi­
facility
Contract
No.
:
68­
W99­
018
Work
Assignment
No.
:
R04808
Date
Prepared
:
September
24,
2001
EPA
Work
Assignment
Manager
:
Mr.
Jay
Bassett
Telephone
No.
:
404/
562­
8542
Prepared
by
:
Tetra
Tech
EM
Inc.
Project
Manager
:
Tim
R.
Jarosch
Telephone
No.
:
404/
225­
5502
Approved:

Michael
R.
Jones
Regional
Manager
CONTENTS
(
Continued)

Section
Page
ii
1.0
INTRODUCTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
1.1
Background
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2
1.2
Technical
Approach
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
2.0
FACILITY­
SPECIFIC
PRIORITIZATION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
2.1
3V,
Inc.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
11
2.1.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
11
2.1.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
12
2.1.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
15
2.2
Albemarle
Corporation
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
19
2.2.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
19
2.2.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
21
2.2.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
24
2.3
Catalytica
Pharmaceuticals,
Inc.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
29
2.3.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
29
2.3.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
31
2.3.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
34
2.4
Diversified
Scientific
Services,
Inc.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
39
2.4.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
39
2.4.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
41
2.4.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
44
2.5
DSM
Chemical
North
America,
Inc.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
49
2.5.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
49
2.5.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
51
2.5.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
54
2.6
First
Chemical
Corporation
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
59
2.6.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
59
2.6.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
61
CONTENTS
(
Continued)

Section
Page
iii
2.6.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
64
2.7
Giant
Cement
Company
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
69
2.7.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
69
2.7.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
72
2.7.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
75
2.8
GlaxoSmithKline,
Inc.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
80
2.8.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
80
2.8.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
82
2.8.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
85
2.9
LWD,
Inc.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
89
2.9.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
89
2.9.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
91
2.9.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
94
2.10
Mallinckrodt
Chemical,
Inc.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
99
2.10.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
99
2.10.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
101
2.10.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
104
2.11
Monsanto
Company
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
109
2.11.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
109
2.11.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
112
2.11.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
115
2.12
Rohm
and
Haas
Company
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
120
2.12.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
120
2.12.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
123
2.12.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
126
2.13
Tennessee
Eastman
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
131
2.13.1
Facility
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
131
2.13.2
Risk­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
133
2.13.3
MACT­
Based
Facility
Prioritization
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
137
1
REFERENCES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
142
1.0
INTRODUCTION
Tetra
Tech
EM
Inc.
(
Tetra
Tech)
received
Work
Assignment
No.
R04808
from
the
U.
S.
Environmental
Protection
Agency
(
EPA)
under
Resource
Conservation
and
Recovery
Act
(
RCRA)
Enforcement,

Permitting,
and
Assistance
(
REPA)
II
Contract
No.
68­
W99­
018
on
March
22,
2000.
Under
this
work
assignment,
Tetra
Tech
was
directed
to
perform
and
prepare
a
preliminary
site­
specific
human
health
qualitative
"
risk
check"
report
for
the
13
hazardous
waste
combustion
facilities
identified
under
this
work
assignment.
Tetra
Tech
has
completed
this
portion
of
the
work
assignment.
As
a
continuation
of
this
work
assignment
and
based
on
the
original
scope
of
work
and
verbal
direction
from
the
EPA
Work
Assignment
Manager
(
WAM),
Tetra
Tech
developed
a
facility
summary
report.
The
main
objectives
of
the
summary
report
are
to
(
1)
develop
two
independent
prioritization
strategies
including
a
risk­
based
prioritization
strategy
and
a
Maximum
Achievable
Control
Technology
(
MACT)­
based
prioritization
strategy;
(
2)

evaluate
individual
qualitative
guiding
factors
on
a
facility­
specific
basis
and
assign
each
factor
into
either
the
high,
medium,
or
low
prioritization
grouping
utilizing
the
two
independent
prioritization
strategies
identified
above;
and
(
3)
provide
final
recommendations
for
assigning
each
facility
into
one
of
the
three
prioritization
groupings
utilizing
the
risk­
based
approach
and
MACT­
based
approach.

This
summary
report
is
intended
for
use
as
a
permitting
tool
by
the
RCRA
permitting
authority
and
facilities
to
efficiently
manage
and
evaluate
potential
adverse
risk
impacts
to
human
health
and
the
environment
associated
with
the
combustion
of
RCRA
regulated
hazardous
wastes.
In
addition,
this
report
is
intended
to
provide
a
means
by
which
facilities
can
be
prioritized,
based
on
their
overall
potential
for
resulting
in
adverse
health
impacts,
for
evaluation
to
determine
if
compliance
with
MACT
standards
alone
are
protective
of
human
health
and
the
environment
or
if
additional
permit
or
risk
management
options
are
required
to
ensure
protection
of
human
health
and
the
environment.

This
summary
report
includes
two
main
sections,
Section
1.0,
which
includes
the
background
(
Section
1.1)

and
technical
approach
(
Section
1.2),
and
Section
2.0,
which
contains
the
facility­
specific
prioritization
results.
Section
2.0
also
presents
facility­
specific
discussions,
including
Section
2.
X,
which
introduces
the
specific
facility;
Section
2.
X.
1,
which
discusses
the
facility­
specific
background
information
including
2
process
descriptions
and
permit
history;
Section
2.
X.
2,
which
describes
the
process
and
findings
used
to
assign
a
facility
into
one
of
three
prioritization
groupings
based
on
the
risk­
based
facility
prioritization
strategy;
and
Section
2.
X.
3,
which
describes
the
process
and
findings
used
to
assign
a
facility
into
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.

1.1
BACKGROUND
RCRA
gives
EPA,
or
authorized
states,
the
authority
to
regulate
facilities
that
manage
hazardous
waste.

Section
3005
(
c)(
3)
of
RCRA
(
codified
in
Title
40
of
the
Code
of
Federal
Regulations
[
40
CFR]

270.32(
b)(
2))
directs
the
RCRA
permitting
authority
to
include
terms
and
conditions
in
the
RCRA
permit,

as
necessary,
to
ensure
protection
of
human
health
and
the
environment.
These
provisions
are
generally
referred
to
as
the
omnibus
authority.
Under
40
CFR
270.10(
k),
the
permitting
authority
may
require
a
permitted
facility
or
permit
applicant
to
submit
additional
information
when
the
permitting
authority
has
reason
to
believe
that
additional
permit
conditions
may
be
warranted
under
270.32(
b)(
2).
A
site­
specific
risk
assessment
can
provide
the
information
necessary
to
make
the
determination
regarding
what,
if
any,

additional
permit
conditions
are
needed
for
a
particular
hazardous
waste
facility.
Thus,
the
information
required
to
establish
permit
conditions
could
include
a
risk
assessment,
or
the
necessary
information
required
to
conduct
a
risk
assessment.

On
September
30,
1999,
EPA,
under
joint
authority
of
the
Clean
Air
Act
(
CAA)
and
RCRA,
promulgated
the
Phase
I
MACT
rule.
The
Phase
I
MACT
rule
consisted
of
revised
emissions
standards
for
hazardous
waste
incinerators,
hazardous
waste
burning
cement
kilns,
and
hazardous
waste
burning
lightweight
kilns.

Revised
emission
standards
for
hazardous
waste
burning
boilers,
halogen
acid
furnaces
(
HAF),
or
sulfuric
acid
recovery
furnaces
(
SARF)
are
not
part
of
the
Phase
I
rule,
but
are
anticipated
to
be
covered
in
the
upcoming
Phase
II
MACT
standards
rulemaking.

Although
the
Phase
I
rule
does
not
apply
to
hazardous
waste
burning
boilers,
HAFs,
or
SARFs,
the
qualitative
guiding
factors
developed
under
this
rule
still
provide
useful
information
for
determining
whether
a
site­
specific
risk
assessment
may
be
necessary
to
meet
RCRA
protectiveness
mandates.
For
example,
although
"
volumes
and
types
of
wastes
being
burned"
was
identified
as
a
qualitative
guiding
factor
in
the
Phase
I
rulemaking,
information
relative
to
this
guiding
factor
(
e.
g.,
wastes
containing
highly
3
toxic
constituents
both
from
an
acute
and
chronic
perspective)
provides
stakeholders
with
the
information
necessary
to
determine
if
boilers,
HAFs,
or
SARFs,
which
are
the
responsibility
of
RCRA,
are
protective
of
human
health
and
the
environment.
For
these
reasons
and
to
meet
the
objectives
of
this
report,
sources
covered
under
the
future
Phase
II
rulemaking
are
still
included
in
this
report.
These
sources
will
be
evaluated
against
the
qualitative
guiding
factors
presented
in
the
Phase
I
rulemaking
using
site­
specific
information
to
identify
those
characteristics
that
may
significantly
influence
risk
posed
by
a
particular
source
in
a
manner
consistent
with
emissions
sources
covered
in
the
Phase
I
rule.

The
Phase
I
MACT
standards
reflect
the
performance
of
MACT
as
specified
by
the
CAA
and
are
generally
more
restrictive
than
existing
RCRA
standards.
EPA
generally
anticipates
that
sources
complying
with
the
MACT
standards
will
not
pose
an
unacceptable
risk
to
human
health
and
the
environment.
However,
as
definitive
findings
cannot
be
made
as
part
of
the
MACT
rulemaking,
a
national
RCRA
risk
assessment
evaluation
of
both
direct
and
indirect
risk
was
performed
to
determine
if
the
MACT
standards
satisfied
the
RCRA
protectiveness
mandate.
The
national
risk
evaluation
did
not,
however,
quantitatively
assess
the
proposed
standards
with
respect
to
non­
dioxin
products
of
incomplete
combustion
(
PIC)
and
may
not
take
into
account
unique
site­
specific
factors
(
e.
g.,
air
dispersion
patterns
or
proximity
to
receptors).
Therefore,

EPA
recommends
that
for
hazardous
waste
combustion
facilities
subject
to
Phase
I
final
MACT
standards,

permitting
authorities
should
evaluate
the
need
for
a
risk
assessment
on
a
case­
by­
case
basis.
The
qualitative
guiding
factors
as
outlined
in
the
MACT
rule
preamble
(
64
Federal
Register
52842,
September
30,
1999)
reflect
the
types
of
considerations
inherent
in
determining
if
a
site­
specific
risk
assessment
is
necessary.
The
omnibus
provision
is
a
RCRA
statutory
requirement
and
does
not
have
a
CAA
counterpart.

Because
the
CAA
does
not
override
RCRA,
the
RCRA
permitting
authorities
are
responsible
for
supplementing
the
national
MACT
standards
on
a
site­
specific
basis,
as
necessary,
to
ensure
adequate
protection
of
human
health
and
the
environment
under
RCRA.

To
assist
EPA
Region
4
in
prioritizing
its
permitting
activities
and
risk
management
strategies,
EPA
Region
4
has
directed
Tetra
Tech
to
develop
a
qualitative
risk
check
summary
prioritization
report.
The
report
will
focus
on
the
qualitative
guiding
factors
utilized
in
the
facility­
specific
qualitative
risk
check
reports.
Examples
of
the
qualitative
guiding
factors
used
to
develop
the
facility
specific
reports
included
the
following:
4
°
Volume
and
types
of
wastes
being
burned;
for
example,
wastes
containing
highly
toxic
constituents
both
from
an
acute
and
chronic
perspective
°
Identities
and
quantities
of
non­
dioxin
products
of
incomplete
combustion
most
likely
to
be
emitted
and
to
pose
significant
risk
based
on
known
toxicities
(
confirmation
of
which
should
be
made
through
emissions
testing)

°
Presence
or
absence
of
other
on­
site
sources
of
hazardous
air
pollutants
so
as
to
significantly
influence
interpretation
of
the
source
in
question
°
Presence
or
absence
of
other
off­
site
sources
of
pollutants
in
sufficient
proximity
so
as
to
significantly
influence
interpretation
of
a
facility­
specific
risk
assessment
°
Particular
site­
specific
considerations
related
to
air
dispersion
modeling,
such
as
unique
dispersion
patterns
resulting
from
site­
specific
terrain
characteristics,
surface
roughness,
building
wake
effects,
etc.

°
Type
of
receptor
and
exposure
scenario(
s)

°
Particular
site­
specific
considerations,
such
as
proximity
to
receptors
°
Presence
or
absence
of
and
proximity
to
water
bodies
and
watersheds
°
Presence
of
and
proximity
to
special
sub­
populations,
such
as
schools,
hospitals,
nursing
homes,
day
care
centers,
parks,
and
community
activity
centers
that
would
indicate
the
presence
of
potentially
sensitive
receptors
°
Presence
or
absence
and
proximity
of
significant
ecological
considerations,
such
as
high
background
levels
of
a
particular
contaminant
or
proximity
of
a
particular
sensitive
ecological
area
°
Concerns
raised
by
the
public
These
qualitative
guiding
factors
represent
site­
specific
characteristics
that
may
significantly
influence
the
risk
posed
by
a
particular
source,
and
therefore
should
be
considered
to
establish
the
need
for
further
site­
specific
evaluation.
These
qualitative
guiding
factors,
when
evaluated
using
site­
specific
data,
will
(
1)
provide
a
qualitative
process
by
which
the
permitting
authority
can
prioritize
those
facilities
where
there
is
reason
to
believe
that
operation
in
accordance
with
current
or
future
MACT
standards
alone
will
not
be
protective
of
human
health
and
the
environment,
(
2)
assist
the
permitting
authority
to
determine
whether
a
site­
specific
risk
assessment
may
be
warranted,
and
(
3)
assist
the
permitting
authority
to
establish
risk
management
priorities
such
that
potentially
unacceptable
risks
to
human
health
and
the
environment
are
identified
and
managed
appropriately.
5
1.2
TECHNICAL
APPROACH
As
discussed
in
Section
1.0,
one
of
the
main
objectives
of
this
work
assignment
was
to
develop
two
independent
prioritization
strategies.
Because
this
report
is
designed
to
be
used
as
a
permitting
tool
by
facilities
and
the
permitting
authority
to
(
1)
evaluate
overall
potential
adverse
risk
impacts
to
human
health
and
the
environment
and
(
2)
determine
whether
compliance
with
current
and
future
MACT
standards
alone
will
satisfy
the
RCRA
protectiveness
requirements,
it
was
necessary
to
develop
a
technical
approach
that
considered
the
needs
of
both
objectives.
Therefore,
two
independent
prioritization
strategies
were
developed.
Specifically,
these
prioritization
strategies
include
the
overall
risk­
based
prioritization
strategy
and
the
MACT­
based
prioritization
strategy.

Overall
Risk­
based
Prioritization
Strategy
The
main
focus
of
the
overall
risk­
based
facility
prioritization
strategy
is
to
assign
each
facility's
qualitative
guiding
factor
as
related
to
facility­
specific
characteristics
and,
subsequently,
the
overall
facility
to
either
a
high,
medium,
or
low
prioritization
group
based
on
the
degree
or
relative
significance
to
which
these
factors
contribute
or
result
in
adverse
impacts
to
human
health
and
the
environment
(
see
discussion
below).
The
risk­
based
facility
prioritization
strategy
is
based
solely
on
the
site­
specific
conditions
at
the
facility,
and
does
not
take
into
account
current
or
future
MACT
standards
or
the
known
limitations
associated
with
the
methodologies
used
to
conduct
the
national
MACT
risk
assessment.

Overall
MACT­
based
Prioritization
Strategy
The
main
focus
of
the
MACT­
based
facility
prioritization
strategy
is
similar
to
the
risk­
based
approach,
in
that
they
are
both
based
on
the
qualitative
guiding
factors.
However,
the
MACT
strategy
will
focus
on
evaluating
each
qualitative
guiding
factor
and
overall
facility
based
on
the
degree
to
which
these
factors
indicate
that
compliance
with
MACT
standards
alone
may
not
be
protective
of
human
health
and
the
environment.

Specific
to
the
MACT­
based
prioritization
strategy,
it
should
be
noted
that
although
current
Phase
I
MACT
standards
do
not
apply
to
facilities
operating
hazardous
waste
fueled
boilers,
it
is
believed
that
development
of
future
Phase
II
MACT
standards,
which
will
apply
to
facilities
operating
boilers,
will
also
include
a
national
MACT
risk
assessment.
With
this
assumption
in
mind,
it
is
also
believed
that
the
6
qualitative
guiding
factors
listed
in
Section
1.1
and
the
known
limitations
of
the
Phase
I
national
MACT
risk
assessment
will
also
apply
to
boilers.
As
a
result,
the
same
criteria
for
evaluating
and
assigning
facilities
that
are
subject
to
Phase
I
MACT
standards
into
one
of
the
three
prioritization
groupings
utilizing
the
MACT­
based
facility
prioritization
strategy
are
also
applied
to
facilities
with
boilers.

As
discussed
in
Section
1.0,
each
prioritization
strategy
will
include
both
an
analysis
of
the
individual
qualitative
guiding
factors
evaluated
in
the
facility­
specific
qualitative
risk
check
report
and
an
overall
facility
prioritization.
Individual
qualitative
guiding
factors
will
be
assigned
to
a
high,
medium,
or
low
prioritization
grouping
based
on
their
propensity
to
result
in
adverse
health
impacts.
Classification
in
the
low
prioritization
grouping
indicates
a
reduced
or
lower
prioritization
level,
while
classification
in
the
high
prioritization
grouping
indicates
an
increased
prioritization
level
or
heightened
need
for
further
action.

In
addition
to
the
individual
prioritization,
an
overall
facility
prioritization
will
also
be
made
by
assigning
each
facility
into
one
of
the
three
prioritization
groupings
(
i.
e.,
low,
medium,
or
high)
based
on
the
prioritization
results
of
the
individual
qualitative
guiding
factors.
More
importantly,
the
overall
facility
prioritization
will
also
include
consideration
of
how
each
qualitative
guiding
factor
relates
to
each
other
collectively,
resulting
in
an
increased
or
"
additive"
potential
for
adverse
risk
impacts.
Finally,
the
overall
facility
prioritization
will
be
completed
by
comparing
the
13
facilities'
site­
specific
characteristics
to
ensure
that
the
facilities
in
each
prioritization
grouping
share
commonalities
or
similar
site­
specific
conditions
associated
with
other
facilities
assigned
to
the
same
prioritization
grouping.

As
discussed
above,
the
decision
to
assign
a
facility
into
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
strategy
and
MACT­
based
strategy
are
made
independent
of
each
other
and
do
not
include
an
evaluation
of
findings
across
prioritization
strategies.
Thus,
a
facility
that
is
assigned
to
the
high
prioritization
grouping
utilizing
the
risk­
based
prioritization
strategy
(
Section
2.
X.
2)
will
not
necessarily
be
grouped
in
the
high
priority
category
utilizing
the
MACT­
based
prioritization
strategy
(
Section
2.
X.
3).
In
addition,
since
each
facility's
grouping
is
based
on
a
qualitative
review
of
site­
specific
facility
information,

a
facility's
classification
to
one
of
the
three
prioritization
grouping
does
not
necessarily
indicate
whether
the
facility
is
operating
in
a
manner
that
is
protective
of
human
health
or
the
environment;
rather,
it
is
intended
for
use
as
a
permitting
tool
to
compare
and
contrast
the
site­
specific
risk
check
findings
in
order
to
prioritize
those
facilities
that
may
require
additional
quantitative
investigation.
7
Specifically,
the
"
low"
prioritization
grouping
is
intended
to
represent
those
facilities
that
(
1)
have
little
or
no
observed
site­
specific
characteristics
that
indicate
an
increased
potential
for
adverse
impact
to
human
health
and
the
environment
or
(
2)
when
compared
with
facilities
assigned
to
the
medium
or
high
prioritization
grouping,
clearly
have
a
lower
potential
for
adverse
impacts
relative
to
the
higher
priority
groupings.

The
"
medium"
prioritization
category
is
designated
for
those
facilities
that
exhibit
one
or
more
significant
site­
specific
characteristics,
which
provide
a
strong
indication
that
potential
adverse
impacts
to
human
health
and
the
environment
exist,
and
therefore
will
require
additional
risk
assessment
activities
to
quantify
risk
impacts.
This
category
may
also
contain
those
facilities
where
sufficient
data
is
not
available
to
evaluate
a
specific
qualitative
guiding
factor
resulting
in
the
inability
to
formulate
qualitative
conclusions
and
determine
the
protectiveness
of
facility
operations.

The
"
high"
prioritization
category
is
reserved
for
those
facilities
that
exhibit
individual
or
multiple
sitespecific
characteristics
that
clearly
indicate
an
increased
potential
for
adverse
health
impacts.
In
addition,

this
group
may
also
contain
those
facilities
where
significant
data
gaps
and
uncertainties
limit
the
ability
to
formulate
or
support
qualitative
conclusions
regarding
the
potential
for
adverse
risk
impacts.

Each
facility­
specific
section
(
i.
e.,
2.
X)
will
include
a
prioritization
table
and
summary
paragraph
specific
to
each
of
the
facility
prioritization
strategies.
The
facility­
specific
prioritization
table,
included
in
both
the
risk­
based
prioritization
section
and
the
MACT­
based
prioritization
section,
will
identify
to
which
prioritization
grouping
each
individual
qualitative
guiding
factors
was
assigned.
In
addition,
the
table
will
also
designate
the
overall
facility
prioritization
grouping.
The
overall
designation
specific
to
the
risk­
based
and
MACT­
base
prioritization
strategy
will
be
based
on
(
1)
a
review
of
individual
qualitative
guiding
factor
prioritizations,
(
2)
consideration
of
how
each
qualitative
guiding
factor
relates
to
each
other
collectively,
and
(
3)
a
comparison
with
the
other
facilities
included
in
this
report.
As
recommended
in
the
qualitative
risk
check
reports,
qualitative
guiding
factors
should
be
considered
collectively
due
TO
their
complex
interplay.
When
all
guiding
factors
are
considered
collectively,
the
potential
risk
impacts
and
risk
trends
are
better
identified
and
defined,
and
will
provide
an
additional
level
of
confidence
in
making
risk
management
decisions.
8
The
summary
paragraph
following
each
prioritization
table
will
provide
further
justification
supporting
the
assignment
of
a
facility
to
a
specific
prioritization
grouping.
In
addition,
the
summary
paragraph
will
also
(
1)
identify
any
facility­
specific
issues
or
site­
specific
characteristics
that
complicated
the
final
decision
to
assign
a
facility
to
a
specific
grouping,
and
(
2)
include
comparisons
with
the
other
prioritization
categories
to
identify
common
characteristics
exhibited
within
each
group
as
a
means
to
further
justify
the
final
overall
facility
prioritization.
9
2.0
FACILITY­
SPECIFIC
PRIORITIZATION
The
following
two
tables
provide
an
overview
of
the
overall
facility
prioritization
groupings.
Specifically,

the
first
table
contains
the
results
of
the
overall
facility­
specific
prioritization
groupings
utilizing
the
riskbased
facility
prioritization
strategy.
The
second
table
contains
the
results
of
the
overall
facility­
specific
prioritization
groupings
utilizing
the
MACT­
based
facility
prioritization
strategy.
For
facility­
specific
findings,
refer
to
the
13
facility­
specific
sections
provided
below.

RISK­
BASED
FACILITY
PRIORITIZATION
OVERVIEW
TABLE
FACILITY
PRIORITIZATION
GROUPING
Low
Medium
High
3V,
Inc.
­
Georgetown,
South
Carolina
(
see
Section
2.1)

Albemarle
Corporation
­
Orangeburg,
South
Carolina
(
see
Section
2.2)

Catalytica
Pharmaceuticals,
Inc.
­
Greenville,
North
Carolina
(
see
Section
2.3)

DSM
Chemicals
North
America,
Inc.
­
Augusta
Georgia
(
see
Section
2.5)

Diversified
Scientific
Services,
Inc.
­
Kingston,
Tennessee
(
see
Section
2.4)

First
Chemical
Corporation
­
Pascagoula,
Mississippi
(
see
Section
2.6)

GlaxoSmithKline,
Incorporated
­
RTP,
North
Carolina
(
see
Section
2.8)

Giant
Cement
Company
­
Harleyville,
South
Carolina
(
see
Section
2.7)

LWD,
Inc.
­
Calvert
City,
Kentucky
(
see
Section
2.9)

Mallinckrodt
Chemical
Company
­
Raleigh,
North
Carolina
(
see
Section
2.10)

Monsanto
Company
­
Augusta,
Georgia
(
see
Section
2.11)

Rohm
and
Hass
Company
­
Louisville,
Kentucky
(
see
Section
2.12)

Tennessee
Eastman
­
Kingsport,
Tennessee
(
see
Section
2.13)

10
MACT­
BASED
FACILITY
PRIORITIZATION
OVERVIEW
TABLE
FACILITY
PRIORITIZATION
GROUPING
Low
Medium
High
3V,
Inc.
­
Georgetown,
South
Carolina
(
see
Section
2.1)

Albemarle
Corporation
­
Orangeburg,
South
Carolina
(
see
Section
2.2)

Catalytica
Pharmaceuticals,
Inc.
­
Greenville,
North
Carolina
(
see
Section
2.3)

DSM
Chemicals
North
America,
Inc.
­
Augusta
Georgia
(
see
Section
2.5)

Diversified
Scientific
Services,
Inc.
­
Kingston,
Tennessee
(
see
Section
2.4)

First
Chemical
Corporation
­
Pascagoula,
Mississippi
(
see
Section
2.6)

GlaxoSmithKline,
Incorporated
­
RTP,
North
Carolina
(
see
Section
2.8)

Giant
Cement
Company
­
Harleyville,
South
Carolina
(
see
Section
2.7)

LWD,
Inc.
­
Calvert
City,
Kentucky
(
see
Section
2.9)

Mallinckrodt
Chemical
Company
­
Raleigh,
North
Carolina
(
see
Section
2.10)

Monsanto
Company
­
Augusta,
Georgia
(
see
Section
2.11)

Rohm
and
Hass
Company
­
Louisville,
Kentucky
(
see
Section
2.12)

Tennessee
Eastman
­
Kingsport,
Tennessee
(
see
Section
2.13)

11
2.1
3V,
INC.

This
section
presents
the
information
and
approach
used
in
assigning
3V,
Inc.
(
3V)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.1.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.

Section
2.1.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.1.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
3V
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.1.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
3V
Qualitative
Risk
Check
Report
(
EPA
2001k).
This
information
is
intended
to
provide
a
general
facility
overview
including
process
descriptions
and
permit
history.

The
3V
facility
operates
a
chemical
manufacturing
plant
that
produces
a
wide
range
of
organic
materials
used
in
the
textiles,
plastics,
detergents,
water
treatment,
and
cosmetic
industries.
The
facility
is
located
about
7
kilometers
west
of
Georgetown,
South
Carolina,
in
Georgetown
County.
The
3V
facility
property
consists
of
120
acres
and
is
located
in
a
sparsely
populated
rural
area
(
DRE
Environmental
Services
[
DRE]
1995a).
The
facility
consists
of
five
process
operation
areas:
Alpha,
Beta,
Gamma,
Delta­
1,
and
Delta­
2.
The
Alpha
plant
produces
polyvinyl
acetate
and
a
thickening
agent.
Optical
brightener
is
produced
in
the
Beta
plant;
and
chlorine
stabilizers,
a
swimming
pool
additive,
are
produced
in
the
Gamma
plant.
Plastol
B
is
produced
in
the
Delta­
1
and
Delta­
2
plants.
The
resulting
product
is
a
certain
fraction
of
the
distillate,
while
other
non­
acceptable
distillate
fractions
and
excess
distillate
products
are
considered
waste
products
(
DRE
1995a).
Specifically,
waste
generated
includes
nonhazardous,
hazardous
due
to
flammability,
and
hazardous
based
on
the
definition
of
waste
code
F003.
12
3V
currently
operates
two
natural
gas­
fired
tube
boilers
used
to
generate
process
steam
for
energy
at
the
facility.
One
of
these
boilers,
the
No.
2
energy
recovery
boiler
(
boiler
no.
2),
burns
RCRA
regulated
hazardous
waste
(
i.
e.,
distillate
waste
byproducts)
generated
during
facility
manufacturing
operations.

Boiler
no.
2
is
a
Cleaver
Brooks
package
steam
boiler
model
NCB600­
800.
Since
boiler
no.
2
burns
hazardous
waste,
it
is
subject
to
the
Boiler
and
Industrial
Furnace
(
BIF)
regulations
in
40
CFR
266
Subpart
H
and
is
currently
operating
under
interim
status
(
General
Engineering
1998).

There
is
currently
no
pollution
control
equipment
installed
on
the
boiler
exhaust.
The
waste
fuel
burner
nozzle
is
designed
to
operate
at
a
maximum
flow
rate
of
170
gallons
per
hour
(
gal/
hr).
Boiler
no.
2
can
operate
at
a
heat
capacity
of
33.47
million
British
thermal
units
per
hour
(
MMBtu/
hr).
The
maximum
waste
feed
of
170
gal/
hr
can
be
fed
into
boiler
no.
2
without
reaching
maximum
heat
capacity.

A
RCRA
permit
application
(
including
a
trial
burn
plan)
was
submitted
to
EPA
on
February
16,
1995.

Compliance
certification
testing
was
performed
in
February
1999
for
boiler
no.
1
to
demonstrate
compliance
with
the
particulate
matter,
metals,
and
total
chloride
standards
under
current
BIF
regulations
(
General
Engineering
1999).
3V's
RCRA
permit
application
has
been
under
review
jointly
by
EPA
Region
4
and
the
South
Carolina
Department
of
Health
and
Environmental
Control
(
DHEC)
since
June
1,
2000
(
DHEC
2000).

2.1.2
Risk­
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
3V
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
3V
Qualitative
Risk
Check
Report
(
EPA
2001k).

In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
13
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

3V
Georgetown,
South
Carolina
Risk­
based
Prioritization
Grouping:
Low
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,
and
(
3)

a
comparison
with
the
12
other
facilities
included
in
this
report,
3V
has
been
placed
in
the
low
prioritization
group
for
the
risk­
based
prioritization
strategy.
3V's
designation
in
the
low
priority
grouping
is
due
in
large
part
to
the
combination
of
a
non­
variable
waste
stream
that
has
not
been
shown
to
contain
PBTs
or
14
other
known
risk
drivers
and
lack
of
receptors
located
in
close
proximity
to
the
facility.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
3V
does
not
exhibit
the
multiple
complicating
characteristics
that
exist
at
those
facilities
assigned
to
the
medium
or
high
prioritization
groups.
Specifically,
justification
for
grouping
3V
into
the
low
prioritization
grouping
includes
the
following:


3V
only
treats
on­
site
generated
hazardous
wastes.
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
treat
both
on­
and
off­
site
generated
wastes.


The
hazardous
waste
stream
treated
at
3V
is
not
considered
to
be
highly
variable
as
the
facility
is
permitted
to
treat
only
wastes
that
contain
two
RCRA
waste
codes
(
i.
e.,
waste
that
is
hazardous
due
to
the
characteristic
of
ignitability,
D001,
and
by
listing,
F003).
In
addition,
the
facility
only
treats
byproduct
wastes
generated
during
the
manufacturing
process.


Neither
of
the
two
waste
codes
that
3V
is
permitted
to
treat
contain
known
PBTs
or
common
risk
drivers.
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
treat
wastes
that
are
known
or
permitted
to
contain
PBT
and
other
common
risk
drivers.


3V
only
operates
one
hazardous
waste
boiler.
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
have
multiple
sources.


Residential,
farmer,
fisher,
and
acute
exposure
scenarios
are
not
located
within
close
proximity
to
3V.
For
example,
the
closest
residential
exposure
scenario
is
located
approximately
2
kilometers
southeast
of
the
facility.
In
comparison,
facilities
assigned
to
the
higher
prioritization
groupings
typically
have
exposure
scenario
locations
within
1
to
1.5
kilometers
of
the
facility
boundary.


Absence
of
water
bodies
within
3
kilometers
of
the
facility
that
exhibit
characteristics
that
typically
result
in
higher
risk
impact.
In
comparison,
facilities
assigned
to
the
higher
prioritization
groupings
typically
have
multiple
water
bodies
that
exhibit
characteristics
indicative
of
higher
risk
impacts,
and
are
within
1
to
1.5
kilometers
of
the
facility
boundary.


No
documented
public
concerns
are
associated
with
facility
operations.
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
have
documented
public
concerns.

For
a
detailed
discussion
on
the
site­
specific
qualitative
guiding
factors,
refer
to
the
3V
Qualitative
Risk
Check
Report
(
EPA
2001k).
Further
justification
for
assigning
3V
to
the
low
prioritization
group
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
15
individually
assigned
to
the
medium
or
high
grouping,
these
guiding
factors
alone
do
not
justify
promoting
3V
into
one
of
the
higher
prioritization
groupings.
Additionally,
due
to
the
absence
of
complex
interplay
or
additive
relationships
between
these
guiding
factors,
the
potential
for
adverse
impacts
is
lessened
and
does
not
warrant
designation
to
a
higher
prioritization
grouping.
For
example,
although
the
qualitative
guiding
factor
associated
with
"
the
presence
or
absence
and
proximity
to
ecological
areas"
was
assigned
to
the
high
prioritization
grouping,
3V
only
operates
one
boiler.
This
boiler
treats
on­
site
generated
wastes
that
are
considered
well
characterized
and
not
known
to
contain
PBTs
or
other
highly
toxic
compounds
known
to
be
risk
drivers,
which,
if
present,
would
be
expected
to
result
in
adverse
impacts
to
these
habitats
and
receptors.
In
addition,
although
threatened
and
endangered
species
are
present
in
Georgetown
County,

it
is
not
known
if
these
species
utilize
habitats
within
the
3V
assessment
area.
Furthermore,
in
comparison
to
the
12
other
facilities
included
in
this
report,
3V
exhibits
fewer
site­
specific
characteristics
that
indicate
an
increased
potential
for
adverse
risk
impacts,
which
are
common
to
the
medium
and
high
groupings.

Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that
3V
is
best
represented
by
facilities
assigned
to
the
low
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
higher
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
low
prioritization
group
does
not
eliminate
the
need
for
conducting
a
site­
specific
risk
assessment
since
facilities
in
this
grouping
may
still
quantitatively
result
in
adverse
health
impacts.
Therefore,
consistent
with
the
3V
Qualitative
Risk
Check
Report
(
EPA
2001k),

additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
the
permitting
authority
demonstrate
that
the
facility
is
operating
in
a
manner
protective
of
human
health
and
the
environment.

2.1.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
3V
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
3V
Qualitative
Risk
Check
Report
(
EPA
2001k).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
3V
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
16
facility
was
assigned
to
its
specific
prioritization
grouping.

MACT­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

3V
Georgetown,
South
Carolina
MACT­
based
Prioritization
Grouping:
Low
As
discussed
in
Section
1.1,
while
Phase
I
MACT
standards
do
not
apply
to
facilities
operating
hazardous
waste
fueled
boilers,
it
is
believed
that
the
development
of
future
Phase
II
MACT
standards,
which
will
apply
to
facilities
operating
boilers,
will
also
include
a
national
MACT
risk
assessment.
With
this
assumption
in
mind,
it
is
also
believed
that
the
qualitative
guiding
factors
listed
in
section
1.0
and
the
17
known
limitations
of
the
Phase
I
national
MACT
risk
assessment
will
also
apply
to
boilers.
As
a
result,
the
same
criteria
for
evaluating
and
assigning
facilities
that
are
subject
to
Phase
I
MACT
standards
to
one
of
the
three
prioritization
groupings
utilizing
the
MACT­
based
facility
prioritization
strategy
are
also
applied
to
facilities
with
boilers.
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
table
above,
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,
and
(
3)
a
comparison
with
the
12
other
facilities
included
in
this
report,
3V
has
been
assigned
to
the
low
prioritization
grouping
for
the
MACT­
based
prioritization
strategy.
3V's
designation
in
the
low
priority
grouping
is
primarily
influenced
by
the
observation
that
when
compared
with
the
other
facilities
evaluated
in
this
report
3V
generally
exhibits
fewer
site­
specific
characteristics
that
indicate
compliance
with
MACT
standards
alone
will
not
be
protective
of
human
health
and
the
environment.

Specifically,
justification
for
grouping
3V
into
the
low
prioritization
grouping
includes
the
following:


Presence
of
well
characterized
waste
feed
generated
on
site
and
known
or
permitted
to
contain
chemicals
not
anticipated
to
be
covered
under
future
MACT
Standards
(
e.
g.,
non­
dioxin
PICs).
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
treat
wastes
from
on­
and
off­
site
sources
that
are
known
or
permitted
to
contain
PBTs
and
other
common
risk
drivers.


Residential,
farmer,
and
fisher
exposure
scenarios
are
not
located
in
close
proximity
to
3V.
For
example,
the
closest
residential
location
is
over
2
kilometers
from
the
facility
boundary.
In
comparison,
facilities
assigned
to
the
higher
prioritization
groupings
typically
have
exposure
scenario
locations
within
1
to
1.5
kilometers
of
the
facility
boundary.
In
addition,
the
Phase
I
National
MACT
Risk
Assessment
utilized
16­
sector
based
grid
averaging.
Based
on
the
assumption
that
the
same
approach
will
be
utilized
in
future
MACT
risk
assessments,
this
approach,
when
applied
on
a
site­
specific
basis,
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
resulting
in
the
potential
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenarios
located
in
close
proximity
to
3V.
However,
because
3V
does
not
have
any
exposure
scenarios
located
within
close
proximity
to
the
facility,
there
is
less
potential
for
underestimating
risk
to
these
receptors.


The
selection
of
representative
water
bodies
in
the
national
MACT
risk
assessment
supporting
Phase
I
MACT
standards
may
have
been
biased
to
meet
multiple
selection
criteria,
resulting
in
the
potential
for
overlooking
more
heavily
impacted
water
bodies
and
their
associated
watersheds.
However,
because
there
are
no
water
bodies
within
3
kilometers
of
the
facility
that
exhibit
characteristics
that
typically
result
in
higher
risk
impacts,
there
is
less
potential
that
the
national
MACT
risk
assessment
that
is
expected
to
support
Phase
II
MACT
standards
will
overlook
more
heavily
impacted
water
bodies
in
the
3V
assessment
area.
18

The
national
MACT
risk
assessment
supporting
the
Phase
I
MACT
standards
did
not
include
a
separate
analysis
or
consideration
of
special
subpopulations.
However,
the
closest
known
special
subpopulation
is
located
approximately
2
kilometers
southsoutheast
of
the
facility.
Therefore,
there
is
less
potential
that
the
national
MACT
risk
assessment
that
is
expected
to
support
Phase
II
MACT
standards
will
overlook
special
subpopulations
in
the
3V
assessment
area.


The
national
MACT
risk
assessment
supporting
the
Phase
I
MACT
standards
did
not
consider
potential
implications
associated
with
public
concerns.
However,
because
there
are
no
documented
public
concerns
associated
with
facility
operations,
there
is
less
potential
that
the
national
MACT
risk
assessment
that
is
expected
to
support
Phase
II
MACT
standards
will
overlook
special
subpopulations
in
the
3V
assessment
area.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
3V
Qualitative
Risk
Check
Report
(
EPA
2001k).
Further
justification
for
assigning
3V
to
the
low
prioritization
group
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
medium
or
high
group,
these
individual
guiding
factors
alone
do
not
justify
promoting
the
facility
to
a
higher
prioritization
grouping.
Additionally,
3V
does
not
exhibit
the
complex
interplay
or
additive
relationships
between
guiding
factors
typically
found
in
the
facilities
assigned
to
the
higher
prioritization
groups.
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that,
for
the
MACT­
based
prioritization
grouping,
3V
is
best
represented
by
facilities
assigned
to
the
low
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
higher
groupings.

As
discussed
in
Section
1.2,
placement
into
the
low
prioritization
group
does
not
eliminate
the
need
for
conducting
a
site­
specific
risk
assessment
since
facilities
in
this
grouping
may
still
quantitatively
result
in
adverse
health
impacts.
Therefore,
consistent
with
the
3V
Qualitative
Risk
Check
Report
(
EPA
2001k),

additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
no
adverse
impacts
to
human
health
and
the
environment
are
attributable
to
the
combustion
of
hazardous
waste
through
3V
facility
operations.
19
2.2
ALBEMARLE
CORPORATION
This
section
presents
the
information
and
approach
used
in
assigning
Albemarle
Corporation
(
Albemarle)

to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.2.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.2.2
describes
the
process
and
findings
used
to
assign
a
facility
into
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.

Section
2.2.3
describes
the
process
and
findings
used
to
assign
a
facility
into
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
Albemarle
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.2.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
Albemarle
Qualitative
Risk
Check
Report
(
EPA
2001i).
This
information
is
intended
to
provide
a
general
facility
overview
including
process
descriptions
and
permit
history.

Albemarle
owns
and
operates
a
chemical
manufacturing
facility
that
produces
industrial
organic
and
specialty
chemical
intermediates
used
in
the
agricultural,
pharmaceutical,
and
petroleum
industries.

Albemarle
operates
a
hazardous
waste
fuel
steam
boiler
­
the
1­
HE­
3800­
1
No.
4
boiler
(
boiler
no.
4)
­
that
is
subject
to
the
RCRA
BIF
regulations
promulgated
in
Title
40
CFR
Part
266.
The
Albemarle
facility
is
located
at
Cannon
Bridge
Road
in
Orangeburg,
South
Carolina,
at
latitude
33

21'
25"
north
and
longitude
79

22'
55"
west.
The
City
of
Orangeburg
is
about
2
kilometers
northwest
of
the
Albemarle
facility,
and
the
North
Fork
Edisto
River
is
approximately
500
meters
east
of
the
facility.

This
facility
was
originally
constructed
in
1937
as
Wannamaker
Chemical
Company
(
EPA
1999).
Ethyl
Corporation
purchased
the
facility
in
1953.
In
1996,
the
Albemarle
division
was
split
off
as
an
independent
corporation.
The
facility
occupies
approximately
300
acres
and
employs
about
500
persons
(
TRC
1993).

Albemarle
operates
24
hours
a
day
and
7
days
a
week.
Albemarle
installed
a
computerized
boiler
20
management
controller
(
CBMC)
and
an
oxygen
trim
system
after
the
BIF
rules
were
promulgated
in
1991.

The
oxygen
trim
system
manages
the
flow
of
waste
fuel
to
achieve
optimal
firing
conditions.

Plant
wastes
are
transferred
via
pipeline
or
tank
trucks
from
the
various
processing
areas
throughout
the
Albemarle
plant
to
boiler
no.
4
(
TRC
1993).
The
wastes
are
stored
in
four
aboveground
waste
storage
and
feed
tanks
that
are
located
east
of
the
boiler.
Tanks
T­
100M­
2
and
T­
30M­
61
collect
and
blend
hazardous
waste
received
from
tank
trailers
and
pipelines.
Tanks
T­
30M­
66
and
T­
10M­
32
are
fuel
burn
tanks
that
receive
waste
blended
in
the
collection
tanks
or
directly
from
tank
trailers
and
pipelines.
Some
wastes
are
also
burned
directly
from
the
tank
trailers
that
deliver
hazardous
waste
to
the
RCRA
facility.
During
normal
operation,
wastes
that
are
burned
in
boiler
no.
4
vary
between
10,000
and
20,000
British
thermal
units
per
pound
(
Btu/
lb)
in
heat
value.
The
total
feed
rate
of
liquid
waste
fuel
to
boiler
no.
4
varies
between
1.5
and
3.5
gallons
per
minute
(
gpm).
For
high
Btu
wastes,
the
heat
capacity
of
the
boiler
is
4.6
gpm.

In
November
1980,
Albemarle
submitted
a
RCRA
Part
A
permit
application
to
obtain
interim
status.
EPA
requested
a
RCRA
Part
B
permit
application
in
February
1982,
which
Albemarle
submitted
to
EPA
in
July
1982.
EPA
determined
that
a
Part
B
permit
was
no
longer
required
if
Albemarle
managed
RCRA
wastes
for
less
than
90
days.
However,
after
the
BIF
regulations
(
40
CFR
Part
266,
Subpart
F)
were
promulgated
in
1991,
Albemarle
was
required
to
submit
a
RCRA
Part
A
permit
application
and
certificate
of
precompliance
to
obtain
interim
status
for
boiler
no.
4
since
it
used
hazardous
waste
as
fuel.
Boiler
no.
4
is
located
287
meters
from
the
boundary
of
the
property
(
Ethyl
Corporation
[
Ethyl]
1991).
Albemarle
ceased
burning
hazardous
waste
fuel
in
boiler
no.
4
while
air
emissions
controls
were
being
upgraded
in
1992.
In
1992,
Albemarle
elected
to
exercise
a
1­
year
extension
for
the
compliance
testing
as
required
upon
renovation
of
boiler
no.
4.
Renovations
included
changes
in
the
waste
feed
collection
system
and
design
of
the
burner,
installation
of
additional
controls
and
monitors,
installation
of
a
baghouse,
and
replacement
of
the
existing
stack.
In
January
1993,
EPA
requested
that
Albemarle
prepare
and
submit
a
RCRA
Part
B
permit
application
and
a
trial
burn
plan
for
boiler
no.
4.
Albemarle
submitted
these
documents
to
EPA
in
June
1993.
In
June
1999,
Albemarle
submitted
a
compliance
test
notification
report
to
EPA,
and
conducted
the
test
in
August.
EPA
Region
4
and
the
South
Carolina
Department
of
Health
and
Environmental
Control
(
DHEC)
have
been
reviewing
Albemarle's
RCRA
Part
B
permit
application
since
June
6,
2000.
21
2.2.2
Risk­
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
Albemarle
into
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Albemarle
Qualitative
Risk
Check
Report
(
EPA
2001i).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
22
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Albemarle
Orangeburg,
South
Carolina
Risk­
based
Prioritization
Grouping:
Low
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,
and
(
3)

a
comparison
with
the
12
other
facilities
included
in
this
report,
Albemarle
has
been
placed
in
the
low
prioritization
grouping
for
the
MACT­
based
prioritization
strategy.
Albemarle's
designation
in
the
low
priority
grouping
is
primarily
influenced
by
the
observation
that,
in
general,
Albemarle
exhibits
less
site­
23
specific
characteristics
that
indicate
an
increased
potential
for
adverse
health
impacts.
Specifically,

justification
for
grouping
Albemarle
into
the
low
prioritization
grouping
includes
the
following:


Albemarle
only
treats
on­
site
hazardous
waste
generated
as
a
byproduct
of
a
manufacturing
process.
As
a
result,
the
waste
feed
is
considered
well
characterized.
In
addition,
the
waste
does
not
contain
known
PBTs
and
is
not
expected
to
contain
other
known
risk
drivers.
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
treat
both
on­
and
off­
site
generated
wastes,
which
are
moderately
to
highly
variable
and
contain
known
PBTs
or
risk
drivers.


Albemarle
only
operates
one
hazardous
waste
boiler.
In
comparison,
most
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
operate
multiple
hazardous
waste
combustors.


Residential,
farmer,
fisher,
and
acute
exposure
scenarios
are
present
in
the
Albemarle
assessment
area
and
are
in
close
proximity
(
e.
g.,
within
1
to
2
kilometers)
to
the
facility
in
several
locations.
However,
Albemarle
only
operates
one
boiler,
which
was
outfitted
with
additional
air
pollution
control
technology
in
1992,
and
treats
only
on­
site
generated
waste
byproducts.
Therefore,
potential
risk
impacts
are
believed
to
be
less
likely
than
those
facilities
assigned
to
the
higher
priority
groupings,
which
typically
treat
large
volumes
of
highly
variable
waste
received
from
both
on­
and
off­
site
sources.


Absence
of
water
bodies
located
within
3
kilometers
of
the
facility
that
exhibit
characteristics
that
typically
result
in
higher
risk
impact.
In
comparison,
facilities
assigned
to
the
higher
prioritization
groupings
typically
have
multiple
water
bodies,
which
exhibit
characteristics
indicative
of
higher
risk
impacts,
and
are
located
within
1
to
1.5
kilometers
of
the
facility
boundary.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Albemarle
Qualitative
Risk
Check
Report
(
EPA
2001i).
Further
justification
for
assigning
Albemarle
in
the
low
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
medium
or
high
grouping,
these
guiding
factors
alone
do
not
justify
promoting
Albemarle
into
one
of
the
higher
prioritization
groupings.
Additionally,
due
to
the
absence
of
complex
interplay
or
additive
relationships
between
these
guiding
factors,
the
potential
for
adverse
impacts
is
lessened
and
does
not
warrant
designation
to
a
higher
prioritization
grouping.
For
example,
although
the
qualitative
guiding
factor
associated
with
"
the
type
of
receptors
and
exposure
scenarios"
was
assigned
to
the
high
priority
grouping
due
to
the
presence
of
potential
receptors
in
the
close
proximity
the
facility,

Albemarle
only
operates
one
boiler,
which
treats
on­
site
generated
wastes
that
are
considered
well
characterized
and
not
known
to
contain
PBTs
or
other
highly
toxic
compounds
known
to
be
risk
drivers.

The
final
decision
to
assign
Albemarle
to
the
low
prioritization
grouping
is
also
reinforced
by
comparing
24
the
facility
with
the
12
others
included
in
this
report.
Albemarle
is
best
represented
by
site­
specific
characteristics
exhibited
by
the
low
priority
grouping,
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
high
priority
grouping.

As
discussed
in
Section
1.2,
placement
into
the
low
prioritization
grouping
does
not
eliminate
the
need
for
conducting
a
site­
specific
risk
assessment
since
facilities
in
this
grouping
may
still
quantitatively
result
in
adverse
health
impacts.
Therefore,
consistent
with
the
Albemarle
Qualitative
Risk
Check
Report
(
EPA
2001i),
additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
the
facility
is
operating
in
a
manner
protective
of
human
health
and
the
environment.

2.2.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
Albemarle
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Albemarle
Qualitative
Risk
Check
Report
(
EPA
2001i).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
grouping
the
Albemarle
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
a
specific
prioritization
grouping.
25
MACT­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Albemarle
Orangeburg,
South
Carolina
MACT­
based
Prioritization
Grouping:
Medium
As
discussed
in
Section
1.1,
while
Phase
I
MACT
standards
do
not
apply
to
facilities
operating
hazardous
waste
fueled
boilers,
it
is
believed
that
development
of
future
Phase
II
MACT
standards,
which
will
apply
to
facilities
operating
boilers,
will
also
include
a
national
MACT
risk
assessment.
With
this
assumption
in
mind,
it
is
also
believed
that
the
qualitative
guiding
factors
listed
in
section
1.0
and
the
known
limitations
of
the
Phase
I
national
MACT
risk
assessment
will
also
apply
to
boilers.
As
a
result,
the
same
criteria
for
26
evaluating
and
assigning
facilities
that
are
subject
to
Phase
I
MACT
standards
to
one
of
the
three
prioritization
groupings
utilizing
the
MACT­
based
facility
prioritization
strategy
are
also
applied
to
facilities
with
boilers.
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
table
above,
(
2)
considering
how
each
qualitative
guiding
factor
interrelates
collectively,
and
(
3)
a
comparison
with
the
12
other
facilities
included
in
this
report,
Albemarle
has
been
placed
in
the
medium
prioritization
grouping
utilizing
the
MACT­
based
prioritization
strategy.

Albemarle's
designation
in
the
medium
priority
grouping
is
primarily
influenced
by
the
observation
that,
in
general,
Albemarle
exhibits
several
site­
specific
characteristics,
when
compared
with
all
facilities
evaluated
in
this
report,
which
indicate
an
increased
potential
that
compliance
with
MACT
standards
alone
may
not
be
protective
of
human
health
and
the
environment.
Specifically,
the
decision
to
assign
Albemarle
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
well
characterized
waste
feed
generated
on
site
that
are
known
or
permitted
to
contain
chemicals
not
anticipated
to
be
covered
under
future
MACT
Standards
(
e.
g.,
non­
dioxin
PICs).
Since
future
MACT
limits
are
not
expected
to
apply
to
all
stack
emissions,
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
low
and
high
prioritization
groupings,
Albemarle
exhibits
multiple
site­
specific
characteristics
that
indicate
an
increased
potential
from
those
facilities
in
the
low
grouping
and
lack
complex
individual
and
additive
qualitative
guiding
factors
indicative
of
the
high
priority
grouping.


Presence
of
other
significant
on­
site
fugitive
emission
sources.
Fugitive
emission
sources
were
not
evaluated
in
the
national
MACT
risk
assessment
conducted
to
support
development
of
current
Phase
I
MACT
Standards,
nor
are
they
expected
to
be
considered
during
in
the
national
MACT
risk
assessment
conducted
during
the
development
of
future
Phase
II
MACT
Standards.
The
presence
of
over
278,000
pounds
of
fugitive
emissions
indicates
a
clear
increased
potential
for
adverse
impacts.
In
addition,
when
compared
with
facilities
assigned
to
the
low
and
high
prioritization
groupings,
Albemarle
emits
significantly
larger
quantities
of
fugitive
emissions
typically
associated
with
facilities
assigned
to
the
low
prioritization
grouping;
however,
the
types
of
compounds
emitted
as
fugitive
emissions
are
not
known
risk
drivers,
as
the
compounds
emitted
by
facilities
in
the
high
prioritization
grouping
usually
are.


Utilizing
the
same
modeling
methodologies
presented
in
the
national
MACT
risk
assessment
for
selecting
the
appropriate
terrain
option
would
result
in
the
misclassification
of
terrain
in
the
Albemarle
assessment
area.
This
mis­
classification
increases
the
potential
that
concentration
and
deposition
will
be
underestimated
in
areas
with
increased
terrain.
This
issue
is
especially
important
in
the
Albemarle
assessment
area
since
many
exposure
scenario
locations
are
located
in
areas
of
increased
terrain.
Since
these
areas
are
present
in
the
assessment
area
and
many
of
them
are
known
or
capable
of
supporting
the
default
exposure
pathways,
there
is
an
27
increased
potential
that
the
national
MACT
risk
assessment
that
is
expected
to
support
Phase
II
MACT
limits
underestimated
risk
in
these
areas.
As
a
result,
there
is
an
increased
potential
that
the
Phase
II
MACT
limits
will
result
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
to
human
health
and
the
environment
under
the
Phase
II
MACT
standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
site­
specific
refinement
to
air
dispersion
modeling
methodologies,
which
were
not
included
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.


Particle
size
distributions
utilized
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards
were
not
source­
specific
but
were
generalized
based
on
combustion
unit
type.
As
stated
above,
it
is
assumed
that
the
national
MACT
risk
assessment
to
support
Phase
II
MACT
standards
will
utilize
the
same
methodologies
as
those
used
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
future
Phase
II
MACT
Limits
cannot
be
inferred
based
on
this
methodology,
but
will
require
additional
site­
specific
risk
assessment
activities,
including
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment.


The
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards
did
not
include
an
evaluation
of
acute
exposure.
Since
(
1)
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility;
(
2)
Albemarle
reports
annual
emissions
of
over
2,000
pounds
of
hydrogen
cyanide,
which
could
have
severe
effects
on
acute
receptors;
and
(
3)
it
is
assumed
that
future
MACT
risk
assessments
will
also
not
include
an
evaluation
of
acute
exposure,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.


Residential
exposure
scenario
locations
are
within
close
proximity
(
i.
e.,
within
1
kilometer)
to
the
Albemarle
facility.
The
Phase
I
National
MACT
Risk
Assessment
utilized
16­
sector
based
grid
averaging.
Based
on
the
assumption
that
the
same
approach
will
be
utilized
in
future
MACT
risk
assessments,
this
approach,
when
applied
on
a
site­
specific
basis,
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
which
could
result
in
the
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenarios
located
in
close
proximity
to
Albemarle.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
future
Phase
II
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


Established
presence
of
significant
ecological
habitats
and
ecological
receptors,
including
threatened
or
endangered
species
in
close
proximity
to
Albemarle.
The
national
MACT
Risk
Assessment
did
not
include
a
separate
analysis
or
consideration
of
threatened
or
endangered
species.
Based
on
the
assumption
that
future
MACT
risk
assessment
will
also
not
include
an
evaluation
of
threatened
or
endangered
species,
28
there
is
an
increased
potential
that
future
Phase
II
Standards
may
not
ensure
protection
of
human
health
and
the
environment.


Presence
of
documented
public
concern
issues.
The
National
MACT
Risk
Assessment
did
not
consider
potential
impacts
associated
with
public
concerns.
The
permitting
authority
may
need
to
consider
additional
risk
management
options
or
permit
strategies,
in
addition
to
future
Phase
II
MACT
limits,
to
ensure
public
concerns
have
been
addressed.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Albemarle
Qualitative
Risk
Check
Report
(
EPA
2001i).
Further
justification
for
assigning
Albemarle
to
the
medium
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
low
or
high
group,
these
individual
factors
alone
do
not
justify
prioritizing
Albemarle
into
the
low
or
high
grouping.
In
addition,
when
compared
with
facilities
in
the
low
prioritization
grouping,
Albemarle
clearly
exhibits
several
unique
site­
specific
factors
which
indicate
that
future
MACT
standards
may
not
satisfy
RCRA
protectiveness
mandates.
Furthermore,
when
compared
with
facilities
in
the
high
prioritization
groupings,
Albemarle
clearly
lacks
the
complex
or
additive
relationships
between
qualitative
guiding
factors,
which
are
common
to
those
facilities
assigned
to
the
high
prioritization
grouping.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities,
since
facilities
in
this
grouping
have
an
increased
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
Albemarle
Qualitative
Risk
Check
Report
(
EPA
2001i),
additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
future
MACT
Standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.

2.3
CATALYTICA
PHARMACEUTICALS,
INC.

This
section
presents
the
information
and
approach
used
in
assigning
Catalytica
Pharmaceuticals,
Inc.

(
Catalytica)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
to
cause
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.3.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.3.2
describes
the
process
and
findings
used
to
assign
a
facility
to
29
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.3.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
Catalytica
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.3.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
Catalytica
Qualitative
Risk
Check
Report
(
EPA
2001b).
This
information
is
intended
to
provide
a
general
facility
overview
including
process
descriptions
and
permit
history.

Catalytica
owns
and
operates
a
chemical
manufacturing
and
pharmaceutical
production
facility
in
Greenville,
North
Carolina.
The
facility
is
subject
to
RCRA
requirements
promulgated
at
40
CFR
260
through
262,
264,
and
270
and
to
the
equivalent
North
Carolina
Department
of
the
Environment
and
Natural
Resources
(
NCDENR)
state
regulations.
The
facility
is
located
about
4.7
kilometers
north
of
Greenville,
Pitt
County,
North
Carolina,
near
the
junction
of
U.
S.
Highway
(
US)
13N
and
North
Carolina
Highway
(
NC)
11
with
US
264.
The
facility
was
originally
owned
by
Burroughs
Wellcome
and
has
been
in
operation
since
1970.
The
facility
was
purchased
by
Catalytica
in
the
mid­
to
late­
1990s
(
Tetra
Tech
2001b).
The
property
consists
of
approximately
600
acres,
of
which
175
acres
are
developed
with
the
49
buildings
that
comprise
the
facility
(
Catalytica
2000).
These
buildings
house
the
chemical
manufacturing
operations,
the
pharmaceutical
production
operations,
and
their
associated
warehouses;
the
research
and
development
laboratories;
the
engineering
facilities
building;
the
environmental
operations;
administrative
offices;
and
the
hazardous
waste
management
facility.
The
hazardous
waste
management
facility
stores
and
treats
hazardous
waste
generated
by
facility
operations.
This
facility
has
two
waste
drum
storage
areas,
which
contain
450
barrels,
16
hazardous
waste
storage
tanks,
four
waste
incinerators,
and
a
liquid
waste
evaporator
(
International
Center
for
Toxicology
and
Medicine
[
ICTM]
1999).

Catalytica
treats
98
to
100
percent
of
the
hazardous
waste
generated
at
the
facility
on
site.
No
waste
is
accepted
at
the
facility
from
off­
site
sources.
Hazardous
waste
is
accumulated
and
stored
either
in
55­

gallon
drum
containers,
500­
to
5,000­
gallon
transfer
containers,
or
fixed
tanks
(
ICTM
1999).
The
waste
consists
of
two
groups:
(
1)
hazardous
waste
generated
by
chemical
manufacturing
operations,
which
30
include
liquids
that
are
corrosive,
reactive,
ignitable,
or
toxic
and
solid
waste
that
has
been
contaminated
with
spent
solvents
or
has
toxic
characteristics,
and
(
2)
hazardous
wastes
generated
by
other
departments,

which
include
off­
specification,
commercial
chemicals
and
laboratory
packs
of
laboratory
chemicals.

These
wastes
are
burned
in
one
of
the
four
on­
site
incinerators,
or
they
are
sent
to
an
approved
RCRA
treatment,
storage,
and
disposal
facility.
Catalytica
does
not
perform
land
disposal
of
hazardous
waste
(
ICTM
1999).

Catalytica
operates
four
waste
incinerators:
Prenco,
NAO,
McGill
I,
and
McGill
II;
each
has
its
own
stack.
The
Prenco
incinerator
was
manufactured
by
Prenco
Manufacturing
Company
and
is
21
feet
long
with
a
cross­
sectional
area
of
5.59
square
feet.
The
NAO
incinerator
was
manufactured
by
the
National
Air
Oil
Burner
Company,
Inc.
and
is
14.75
feet
long
with
a
cross­
sectional
area
of
12.6
square
feet.
The
McGill
I
and
McGill
II
incinerators
were
manufactured
by
McGill
Americas,
Inc.
(
McGill
Americas).

Both
incinerators
are
20
feet
long
with
a
cross­
sectional
area
of
36.9
square
feet
(
Compliance
Strategies
and
Solutions,
Inc.
[
CSS]
1999).

The
McGill
II
incinerator
is
the
only
incinerator
equipped
with
an
air
pollution
control
system
(
APCS).

The
APCS
includes
a
water
weir,
spray
contractor,
quench
tank,
Calvery
wet
scrubber,
packed
tower
absorber,
and
wet
electrostatic
precipitator;
the
APCS
was
designed
primarily
to
remove
particulate
matter
and
acid
gases
(
hydrochloric
acid
and
chlorine)
before
the
emissions
are
introduced
into
the
atmosphere.

All
of
the
incinerators
are
operated
under
positive
pressure
and
have
sealed
wall
construction
to
eliminate
fugitive
emissions
from
their
combustion
chambers.
In
addition,
an
automatic
waste
feed
cut­
off
(
AWFCO)
system,
which
prevents
the
feeding
of
hazardous
waste
if
burning
conditions
are
outside
the
permitted
limits,
has
been
incorporated
into
the
operating
systems
of
each
of
the
incinerators
(
CSS
1999).

Natural
gas
provides
the
auxiliary
fuel
that
is
simultaneously
fed
to
all
of
the
incinerators
along
with
the
hazardous
waste.
The
natural
gas
has
a
heat
content
of
approximately
1,000
British
thermal
units
per
standard
cubic
foot
(
Btu/
scf).
The
Prenco
and
McGill
I
incinerators
are
each
fired
by
an
air
atomization
burner
that
was
designed
by
McGill
Americas.
The
McGill
II
incinerator
is
fired
by
three
air
atomization
burners
that
were
also
designed
by
McGill
Americas.
The
NAO
incinerator
is
fired
by
a
number
1
SAR
fuel
oil
burner,
which
steam
atomizes
the
hazardous
waste
with
the
auxiliary
fuel
in
an
NAO
cylindrical
type
gas
burner
for
efficient
combustion
(
CSS
1999).
31
The
Catalytica
facility
has
been
in
operation
since
1970;
however,
available
information
does
not
indicate
whether
the
facility
operated
a
hazardous
waste
incinerator
at
this
time.
Burroughs
Wellcome
was
initially
permitted
in
1989
by
the
NCDENR
under
RCRA
Part
B
as
a
treatment,
storage,
and
disposal
facility.
A
trial
burn
was
performed,
and
an
analysis
of
metals
and
particulate
matter
was
conducted
to
support
the
1989
permit
application.
Catalytica
then
purchased
the
facility
in
the
mid
to
late
1990s
and
has
been
in
operation
under
the
1989
permit
limits
since
the
time
the
facility
was
purchased.
The
permit
expired
in
October
1999,
and
a
new
Part
A
and
B
permit
application,
which
includes
a
trial
burn
plan,
risk
burn
plan,

and
risk
assessment
protocol,
was
submitted
in
1999
and
is
currently
under
review
by
EPA
Region
4
and
the
NCDENR.
No
trial
burn
or
risk
burn
has
been
conducted
to
support
a
site­
specific
risk
assessment
at
the
facility
to
date
(
Tetra
Tech
2001b).
Currently,
Catalytica
is
operating
its
incinerators
in
accordance
with
the
1989
RCRA
permit
limits
while
the
Part
A
and
Part
B
permit
application
is
reviewed
by
EPA
Region
4
and
NCDENR.

2.3.2
Risk­
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
Catalytica
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Catalytica
Qualitative
Risk
Check
Report
(
EPA
2001b).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.

OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
32
Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Catalytica
Greenville,
North
Carolina
Risk­
based
Prioritization
grouping:
Medium
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
considering
how
each
qualitative
guiding
factor
interrelates
collectively,

Catalytica
has
been
placed
in
the
medium
prioritization
grouping
utilizing
the
overall
risk­
based
prioritization
strategy.
The
medium
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
When
compared
with
the
12
other
facilities
included
in
this
summary
report,
Catalytica
exhibits
multiple
characteristics
consistent
with
those
facilities
assigned
to
the
medium
prioritization
grouping.
Specifically,

the
decision
to
Catalytica
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Catalytica
treats
a
moderately
variable
hazardous
waste
feed
that
is
listed
under
several
RCRA
waste
codes,
including
some
that
contain
compounds
that
are
known
PBTs
and
common
risk
drivers;
however,
the
waste
codes
that
are
known
to
contain
PBTs
and
common
risk
drivers
only
make
up
a
minor
percentage
of
the
waste
feed.
33
Additionally,
Catalytica
only
treats
waste
that
is
generated
on
site.
In
comparison,
facilities
in
the
high
prioritization
group
typically
treat
highly
variable
waste
that
is
received
from
both
on­
and
off­
site
sources,
and
facilities
in
the
low
prioritization
grouping
typically
treat
well
characterized
waste
that
is
generated
on
site.


Catalytica
operates
four
hazardous
waste
incinerators,
which
are
capable
of
operating
simultaneously.
In
comparison,
facilities
assigned
to
the
low
prioritization
grouping
typically
only
operate
a
single
hazardous
waste
combustor.


Catalytica
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
limited
information
is
available.


The
Catalytica
facility
is
located
in
close
proximity
to
residential,
farmer,
and
fisher
exposure
scenarios.
For
example,
the
closest
residential
exposure
scenario
is
located
approximately
1
kilometer
north­
northwest
of
the
facility.


Presence
of
water
bodies
within
3
kilometers
of
the
facility
that
exhibit
characteristics
that
typically
result
in
higher
risk
impact.


Closest
known
special
subpopulation
is
located
approximately
2
kilometers
southsoutheast
of
the
facility.


No
documented
public
concerns
are
associated
with
facility
operations.
In
comparison,
facilities
assigned
to
the
high
prioritization
groupings
typically
have
documented
public
concern
issues
For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Catalytica
Qualitative
Risk
Check
Report
(
EPA
2001b).
Further
justification
for
assigning
Catalytica
to
the
medium
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
low
or
high
group,
when
these
factors
are
considered
collectively,
justification
for
assigning
Catalytica
to
one
of
the
other
prioritization
groupings
is
not
supported.
Catalytica
was
not
assigned
to
the
high
prioritization
grouping
because
when
compared
with
those
facilities
assigned
to
the
high
prioritization
grouping,
Catalytica
clearly
lacked
the
complicating
factors
associated
with
the
facilities
assigned
to
the
high
prioritization
grouping.
For
example,
although
the
qualitative
guiding
factor
associated
with
"
proximity
to
exposure
scenario
location"
was
individually
grouped
into
the
high
prioritization
grouping
due
to
the
presence
of
receptors
within
1
kilometer
of
the
facility,
because
the
volumes
and
types
of
wastes
treated
at
the
Catalytica
facility
are
generated
on
site
as
a
byproduct
of
the
manufacturing
process
and,
therefore,
are
considered
to
be
only
moderately
variable,

inadequate
justification
was
available
to
support
allocation
into
the
high
prioritization
grouping.
Therefore,

based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
34
has
been
determined
that
Catalytica
is
best
represented
by
facilities
assigned
to
the
medium
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
low
and
high
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
a
sitespecific
risk
assessment
since
facilities
in
this
grouping
have
an
increased
potential
to
contribute
to
adverse
impacts
to
human
health
and
the
environment.
Further,
consistent
with
the
findings
presented
in
the
Catalytica
Qualitative
Risk
Check
Report
(
EPA
2001b),
a
site­
specific
quantitative
risk
assessment
at
the
Catalytica
facility
is
recommended
to
provide
the
facility
and
permitting
authority
with
the
information
necessary
to
assess
potential
liabilities
and
ensure
the
protection
of
human
health
and
the
environment.

2.3.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
Catalytica
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Catalytica
Qualitative
Risk
Check
Report
(
EPA
2001b).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
grouping
the
overall
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
a
facility
was
assigned
to
its
specific
prioritization
grouping.

MACT­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

MACT­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
35
Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Catalytica
Greenville,
North
Carolina
MACT­
based
Prioritization
Grouping:
Medium
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
(
2)
considering
how
each
qualitative
guiding
factor
interrelates
collectively,
and
(
3)
a
comparison
with
the
12
other
facilities
included
in
this
report,
Catalytica
has
been
placed
in
the
medium
prioritization
grouping
utilizing
the
MACT­
based
prioritization
strategy.
Catalytica's
designation
in
the
medium
priority
grouping
is
primarily
influenced
by
the
observation
that,
in
general,
Catalytica
exhibits
several
site­
specific
characteristics,
when
compared
with
all
facilities
evaluated
in
this
report,
which
indicate
an
increased
potential
that
compliance
with
MACT
standards
alone
may
not
be
protective
of
human
health
and
the
environment.
Specifically,
the
decision
to
assign
Catalytica
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
moderately
variable
hazardous
waste
known
or
permitted
to
contain
chemicals
not
covered
under
current
MACT
Standards
(
e.
g.,
non­
dioxin
PICs).
Since
MACT
limits
do
not
apply
to
all
stack
emissions,
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
low
and
high
prioritization
groupings,
Catalytica
exhibits
multiple
site­
specific
characteristics
that
indicate
an
increased
potential
from
those
facilities
in
the
low
grouping,
and
lack
complex
individual
36
and
additive
qualitative
guiding
factors
indicative
of
the
high
priority
grouping.


Presence
of
other
on­
site
sources
not
evaluated
in
the
national
MACT
risk
assessment
(
e.
g.,
16,685
pounds
of
emissions
from
fugitive
sources).
The
presence
of
over
16,000
pounds
of
fugitive
emissions
indicates
a
clear
increased
potential
for
adverse
impacts.
In
addition,
when
compared
with
facilities
assigned
to
the
low
and
high
prioritization
groupings,
Catalytica
emits
larger
quantities
of
fugitive
emissions
typically
associated
with
facilities
assigned
to
the
low
prioritization
grouping;
however,
the
types
of
compounds
emitted
as
fugitive
emissions
are
not
known
risk
drivers,
as
are
the
compounds
typically
emitted
by
facilities
in
the
high
prioritization
grouping.


modeling
methodologies
presented
in
the
national
MACT
risk
assessment
would
result
in
the
mis­
classification
of
terrain
in
the
assessment
area
resulting
in
an
increased
potential
for
underestimating
concentration
and
deposition,
especially
in
areas
associated
with
increased
terrain
elevation.
Since
areas
with
increased
terrain
elevation
are
present
in
the
assessment
area,
and
many
of
them
are
known
or
capable
of
supporting
the
default
exposure
pathways,
there
is
an
increased
potential
that
the
National
MACT
Risk
assessment
underestimated
risk
in
these
areas.
As
a
result,
there
is
an
increased
potential
that
the
Phase
I
MACT
limits
evaluated
in
the
National
MACT
Risk
Assessment
resulted
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
to
human
health
and
the
environment
under
the
Phase
I
MACT
Standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
site­
specific
refinement
to
air
dispersion
modeling
methodologies.


Particle
size
distributions
utilized
in
the
National
MACT
Risk
Assessment
were
not
source
specific,
but
were
generalized
based
on
combustion
unit
type.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
Phase
I
MACT
Limits
cannot
be
inferred,
but
require
additional
site­
specific
risk
assessment
activities
including
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment.


The
National
MACT
Risk
Assessment
did
not
include
an
evaluation
of
acute
exposure.
Since
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.


Residential
exposure
scenario
locations
are
located
in
close
proximity
(
i.
e.,
within
1
kilometer)
to
the
Catalytica
facility.
The
Phase
I
National
MACT
Risk
Assessment
utilized
16­
sector
based
grid
averaging.
This
approach,
when
applied
on
a
site­
specific
basis,
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots).
This
averaging
could
result
in
the
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenarios
located
in
close
proximity
to
Catalytica.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
Phase
I
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.
37

Presence
of
significant
ecological
habitats
and
ecological
receptors
in
close
proximity
to
Catalytica,
including
several
threatened
or
endangered
species.
Because
the
national
MACT
risk
assessment
did
not
include
a
separate
analysis
or
consideration
of
threatened
or
endangered
species,
there
is
an
increased
potential
that
current
MACT
standards
may
not
ensure
protection
of
human
health
and
the
environment.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Catalytica
Qualitative
Risk
Check
Report
(
EPA
2001b).
Further
justification
for
assigning
Catalytica
to
the
medium
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
low
or
high
group,
these
individual
factors
alone
do
not
justify
prioritizing
Catalytica
into
the
low
or
high
grouping.
In
addition,
when
compared
with
facilities
in
the
low
prioritization
grouping,
Catalytica
clearly
exhibits
several
unique
site­
specific
factors
which
indicate
that
current
MACT
standards
may
not
satisfy
RCRA
protectiveness
mandates.
Furthermore,
when
compared
with
facilities
in
the
high
prioritization
groupings,
Catalytica
clearly
lacks
the
complex
or
additive
relationships
between
qualitative
guiding
factors
that
are
common
to
those
facilities
assigned
to
the
high
prioritization
grouping.
38
As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities,
since
facilities
in
this
grouping
have
an
increased
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
Catalytica
Qualitative
Risk
Check
Report
(
EPA
2001b),
additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
current
MACT
standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.
39
2.4
DIVERSIFIED
SCIENTIFIC
SERVICES,
INC.

This
section
presents
the
information
and
approach
used
in
assigning
Diversified
Scientific
Services,
Inc.

(
DSSI)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.4.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.4.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.4.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
DSSI
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.4.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
DSSI
Qualitative
Risk
Check
Report
(
EPA
2001h).
This
information
is
intended
to
provide
a
general
facility
overview
including
process
descriptions
and
permit
history.

DSSI
owns
and
operates
an
industrial
mixed­
waste
boiler
system,
which
is
used
specifically
to
incinerate
hazardous
waste
fuels,
including
aqueous
and
organic
liquids
and
solvents,
scintillation
liquids,
pumpable
paints,
and
waste
and
hydraulic
oils
with
beneficial
recovery
of
thermal
energy.
The
DSSI
boiler
is
subject
to
general
guidance
by
the
Tennessee
Department
of
Environment
and
Conservation
(
TDEC)
and
the
requirements
of
RCRA
promulgated
under
40
CFR
266
by
U.
S.
EPA.
Additionally,
DSSI
is
permitted
to
treat
most
RCRA
listed
wastes
under
waste
codes
"
D,"
"
F,"
"
K,"
"
P,"
"
U;"
mixed
wastes
with
specific
low
radioactivity
characteristics;
and
low­
level
radioactive
nonhazardous
wastes.

The
DSSI
facility
is
located
near
Highway
58,
approximately
3
kilometers
east
of
the
city
of
Kingston
and
21
kilometers
southeast
of
Oak
Ridge,
Tennessee.
The
DSSI
incinerator
facility
covers
80
acres
in
the
Kingston
area
of
Roane
County,
Tennessee.
An
office
complex
and
school
for
the
disabled
border
the
DSSI
facility
to
the
west.
Land
use
surrounding
the
facility
is
predominantly
agricultural
and
forested
land
40
with
several
residential
communities
scattered
throughout.
In
addition,
the
facility
is
bordered
by
a
singlefamily
residence
located
to
the
southeast.
Constructed
features
on
the
facility
property
include
(
1)
administrative,
laboratory,
and
processing
buildings;
(
2)
a
retention
pond;
(
3)
two
guardhouses;
(
4)
a
live
drum
storage
area;
(
5)
a
maintenance
area;
(
6)
a
tank
farm;
and
(
7)
two
trailers.

DSSI
receives
hazardous
wastes
from
a
variety
of
off­
site
sources,
including
government
installations,

hospitals,
industrial
firms,
power
plants,
research
laboratories,
and
universities.
Hazardous
wastes
are
received
in
pails,
totes,
drums,
or
bulk­
liquid
tanks
and
are
identified
as
"
containerized
liquids."
All
hazardous
wastes
are
analyzed
before
they
are
burned
to
ensure
efficiency
of
combustion
and
compliance
with
constituent
limits.

Containerized
liquids
are
decanted
and
pumped
into
two
test
tanks
in
the
process
building
to
allow
for
intermediate
bulking
of
approximately
1,000
gallons
of
waste.
Immediately
northwest
of
the
process
building
is
a
covered
bulk
liquid
tank
farm
with
a
coated­
concrete
truck
bay
for
unloading.
From
the
test
tanks,
waste
liquids
are
pumped
into
one
of
five
tanks
in
the
tank
farm
to
store
and
blend
liquid
wastes
into
fuels
before
they
are
incinerated
in
the
boiler
system.
Bulk
tankers
are
unloaded
directly
into
any
one
of
the
five
tanks
located
in
the
tank
farm
area.
The
tank
farm
is
constructed
with
a
retention
slab
and
concrete
berm
and
is
designed
to
contain
spilled
wastes
and
fire
suppression
water.

Prepared
waste
fuel
blends,
based
on
specific
physical,
chemical,
and
radiological
properties,
are
transferred
from
the
tank
farm
back
to
the
waste
fuel
surge
tank
located
in
the
process
building.
The
surge
tank
is
utilized
to
feed
the
waste
blends
directly
to
the
boiler
system
via
positive
displacement
feed
pumps.

The
boiler
system
process
is
controlled
by
established
maximum
and
minimum
operational
parameters
maintained
through
the
use
of
AWFCOs.

The
mixed­
waste
boiler
consists
of
two
main
elements:
a
high­
intensity
dual
fuel
burner,
and
a
direct­
fired
boiler.
The
burner
uses
purchased
propane
to
bring
the
boiler
up
to
normal
operational
temperature
and
pressure.
Waste
fuel
is
then
added
on
a
mass
rate
basis
while
the
propane
converts
to
an
"
as
needed"
basis
and
ensures
system
steam
demand
is
maintained.
The
system
features
waste
feed
mechanisms,
combustion
chambers,
a
continuous
emissions
monitoring
system
(
CEMS),
an
APCS,
and
a
flue
gas
stack.
The
APCS
consists
of
a
dual­
column
spray
dryer
and
quench,
a
baghouse,
a
packed
bed
scrubber
and
mist
eliminator,
41
a
steam
reheater,
and
a
high
energy
particulate
air
(
HEPA)
filter.
Residue
from
the
pollution
control
process
is
regarded
as
generated
waste
and
is
disposed
of
at
a
licensed
and
permitted
disposal
facility.

Information
on
the
regulatory
history
of
the
boiler
and
facility
was
limited
to
the
BIF
Revised
Certification
of
Compliance
for
Hazardous
Waste
Boiler
Operation
(
DSSI
1996).
On
October
18,
1995,
DSSI
revised
its
certification
of
compliance
to
include
improvements
to
the
APCS
equipment
and
boiler
system
as
specified
in
40
CFR
266.103
(
b)(
3).
Two
days
later,
DSSI
provided
a
compliance
test
notification
to
EPA
Region
IV.
After
discussions
on
conflicting
parameters
and
proposed
test
conditions,
DSSI
submitted
another
certification
of
compliance
to
EPA
Region
IV
on
January
26,
1996.
Compliance
testing
was
performed
February
22
through
24,
1996,
to
demonstrate
that
the
boiler
was
operating
within
its
emissions
limits
and
to
establish
operational
condition
limits.
The
facility
is
currently
operating
under
interim
permit
status
pursuant
to
40
CFR
Part
266.

2.4.2
Risk­
Based
Facility
Prioritization
This
section
describes
the
findings
relative
to
assigning
DSSI
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
DSSI
Qualitative
Risk
Check
Report
(
EPA
2001h).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
42
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

DSSI
Kingston,
Tennessee
Risk­
based
Prioritization
Grouping:
High
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

DSSI
has
been
assigned
to
the
high
prioritization
group
based
on
the
overall
risk­
based
prioritization
strategy.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
DSSI
clearly
exhibits
multiple
complicating
factors
that
individually
or
collectively
support
its
designation
in
the
43
high
prioritization
group.
This
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
Specifically,
the
decision
to
assign
DSSI
to
the
high
prioritization
grouping
is
supported
by
the
following
key
factors:


DSSI
treats
hazardous
waste
that
is
received
from
both
on­
and
off­
site
sources.
In
comparison,
facilities
assigned
to
the
lower
prioritization
grouping
typically
only
treat
waste
generated
onsite.


The
hazardous
waste
stream
treated
at
DSSI
is
considered
to
be
highly
variable
as
the
facility
is
permitted
to
treat
waste
listed
under
several
RCRA
waste
codes,
including
some
that
contain
known
PBTs
and
common
risk
drivers.
In
comparison,
facilities
in
the
lower
prioritization
groupings
typically
treat
better
characterized
waste
that
do
not
contain
known
PBTs
and
common
risk
drivers.


DSSI
is
permitted
to
process
"
mixed
wastes"
with
specific
low
radioactivity
characteristics,
as
well
as
low­
level
radioactive
non­
hazardous
wastes
with
atomic
numbers
1­
83,
88,
90,
and
92.


DSSI
operates
only
one
hazardous
waste
boiler,
but
reports
that
over
80
percent
of
its
emissions
are
from
fugitive
sources.
Also,
DSSI
is
located
within
10
kilometers
of
the
Toxic
Substances
Control
Act
(
TSCA)
incinerator,
which
is
located
on
site
at
the
East
Tennessee
Technical
Park.


DSSI
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
limited
information
is
available.


The
DSSI
facility
is
located
in
close
proximity
to
residential
and
farmer
exposure
scenarios.
For
example,
the
closest
residential
exposure
scenario
is
located
less
than
1
kilometer
north
of
the
facility.
In
comparison,
facilities
in
the
lower
prioritization
groupings
are
typically
located
more
than
1.5
kilometers
from
exposure
scenarios.


The
closest
known
special
subpopulation
is
located
adjacent
to
the
facility
to
the
west.
In
comparison,
facilities
in
the
lower
prioritization
groupings
are
typically
located
more
than
2
kilometers
from
special
subpopulations.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
DSSI
Qualitative
Risk
Check
Report
(
EPA
2001h).
Further
justification
for
assigning
DSSI
to
the
high
prioritization
group
is
based
on
the
relationship
or
complex
interplay
associated
with
many
of
the
qualitative
guiding
factors
individually
assigned
to
the
high
group.
For
example,
the
combination
of
a
highly
variable
waste
feed
received
from
both
on­
and
off­
site
sources,
compounded
by
the
presence
of
reported
on­
site
fugitive
emissions
that
comprise
more
that
80
percent
of
the
emissions
reported
at
the
facility,
coupled
with
the
presence
and
close
proximity
of
residential
and
farmer
exposure
scenarios,
significantly
elevates
the
44
potential
for
adverse
impacts
to
human
health
and
the
environment.
Therefore,
based
on
a
review
of
sitespecific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that
DSSI
is
best
represented
by
facilities
assigned
to
the
high
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
lower
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
high
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities
at
the
DSSI
facility
in
order
to
quantify
risk
impacts
to
human
health
and
the
environment,
since
facilities
in
this
grouping
have
the
largest
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
DSSI
Qualitative
Risk
Check
Report
(
EPA
2001h),
additional
site­
specific
risk
assessment
activities
are
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
the
DSSI
facility
meets
the
requirements
of
the
RCRA
omnibus
provisions.

2.4.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
DSSI
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
DSSI
Qualitative
Risk
Check
Report
(
EPA
2001h).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
DSSI
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
45
MACT­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

DSSI
Kingston,
Tennessee
MACT­
based
Prioritization
Grouping:
High
As
discussed
in
Section
1.1,
while
Phase
I
MACT
standards
do
not
apply
to
facilities
operating
hazardous
waste
fueled
boilers,
it
is
believed
that
development
of
future
Phase
II
MACT
standards,
which
will
apply
to
facilities
operating
boilers,
will
also
include
a
national
MACT
risk
assessment.
With
this
assumption
in
mind,
it
is
also
believed
that
the
qualitative
guiding
factors
listed
in
section
1.0
and
the
known
limitations
of
the
Phase
I
national
MACT
risk
assessment
will
also
apply
to
boilers.
As
a
result,
the
same
criteria
for
46
evaluating
and
assigning
facilities
that
are
subject
to
Phase
I
MACT
standards
to
one
of
the
three
prioritization
groupings
utilizing
the
MACT­
based
facility
prioritization
strategy
are
also
applied
to
facilities
with
boilers.
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
table
above,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,
DSSI
has
been
placed
in
the
high
prioritization
group
for
the
MACT­
based
prioritization
strategy.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
DSSI
clearly
exhibits
multiple
complicating
factors
that
individually
or
collectively
support
its
designation
in
the
high
prioritization
group.
This
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
a
remaining
potential
for
adverse
impacts
to
human
health
and
the
environment
exists
even
after
complying
with
current
MACT
standards.
Specifically,
the
decision
to
assign
DSSI
to
the
high
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
highly
variable
hazardous
waste
received
from
both
on­
and
off­
site
sources
known
or
permitted
to
contain
chemicals
not
expected
to
be
covered
under
future
MACT
standards
(
e.
g.,
non­
dioxin
PICs,
10
of
the
12
PBTs).
Since
future
MACT
limits
are
not
expected
to
apply
to
these
stack
emissions,
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
lower
prioritization
groupings,
DSSI
exhibits
multiple
site­
specific
characteristics
and
complex
individual
and
additive
qualitative
guiding
factors,
which
indicate
an
increased
potential
from
those
facilities
in
the
low
and
medium
groupings.


Presence
of
other
significant
on­
site
fugitive
emission
sources
(
e.
g.,
80
percent
of
emissions
from
fugitive
sources
as
reported
in
1999
TRI
inventory).
Fugitive
emission
sources
were
not
evaluated
in
the
national
MACT
risk
assessment
conducted
to
support
development
of
current
Phase
I
MACT
Standards,
nor
are
they
expected
to
be
considered
during
the
national
MACT
risk
assessment
conducted
during
development
of
future
Phase
II
MACT
Standards.
The
presence
of
potentially
significant
amounts
of
fugitive
emissions
indicates
a
clear
increased
potential
for
adverse
impacts.
In
addition,
when
compared
with
facilities
assigned
to
the
lower
prioritization
groupings,
DSSI
is
capable
of
emitting
more
known
risk
drivers
as
fugitive
emissions
due
to
its
highly
variable
waste
feed
than
the
facilities
in
the
low
and
medium
groupings.


Presence
of
off­
site
emission
sources,
including
the
TSCA
incinerator,
which
is
located
within
10
kilometer
of
the
DSSI
facility
boundary.
Aggregate
off­
site
emission
sources
were
not
included
in
the
national
MACT
risk
assessment
supporting
Phase
I
MACT
limits
and
are
not
expected
to
be
included
in
the
national
MACT
risk
assessment
anticipated
to
support
Phase
II
MACT
limits.
The
presence
of
other
hazardous
waste
combustion
facilities
in
close
proximity
to
the
DSSI
facility
indicates
an
increased
potential
for
adverse
impacts
to
receptors.


Utilizing
the
same
modeling
methodologies
presented
in
the
national
MACT
risk
assessment
for
selecting
the
appropriate
terrain
option
would
result
in
the
mis­
47
classification
of
terrain
in
the
DSSI
assessment
area.
This
mis­
classification
increases
the
potential
that
concentration
and
deposition
will
be
underestimated
in
areas
with
increased
terrain.
This
issue
is
especially
important
in
the
DSSI
assessment
area
since
many
exposure
scenario
locations
are
located
in
areas
of
increased
terrain.
Since
areas
with
increased
terrain
elevation
are
present
in
the
assessment
area
and
many
of
them
are
known
or
capable
of
supporting
the
default
exposure
pathways,
there
is
an
increased
potential
that
the
national
MACT
risk
assessment
that
is
expected
to
support
Phase
II
MACT
limits
underestimated
risk
in
these
areas.
As
a
result,
there
is
an
increased
potential
that
the
Phase
II
MACT
limits
will
result
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
to
human
health
and
the
environment
under
the
Phase
II
MACT
standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
site­
specific
refinement
to
air
dispersion
modeling
methodologies,
which
were
not
included
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.


Particle
size
distributions
utilized
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards
were
not
source­
specific,
but
were
generalized
based
on
combustion
unit
type.
As
stated
above,
it
is
assumed
that
the
national
MACT
risk
assessment
to
support
Phase
II
MACT
standards
will
utilize
the
same
methodologies
as
those
used
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
future
Phase
II
MACT
Limits
cannot
be
inferred
based
on
this
methodology,
but
will
require
additional
site­
specific
risk
assessment
activities
including
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
sitespecific
risk
assessment.


The
national
MACT
risk
assessment
conducted
to
support
Phase
I
MACT
limits
did
not
include
an
evaluation
of
acute
exposure,
and
it
is
assumed
that
the
national
MACT
risk
assessment
to
support
Phase
II
MACT
standards
will
utilize
the
same
methodologies.
Since
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.


Residential
exposure
scenario
locations
are
located
in
close
proximity
(
i.
e.,
within
1
kilometer)
to
the
DSSI
facility.
The
Phase
I
national
MACT
risk
assessment
utilized
16­
sector
based
grid
averaging.
Based
on
the
assumption
that
the
same
approach
will
be
utilized
in
future
MACT
risk
assessments,
this
approach,
when
applied
on
a
site­
specific
basis,
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
resulting
in
the
potential
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenarios
located
in
close
proximity
to
DSSI.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
future
Phase
II
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


Presence
of
special
subpopulations
located
adjacent
to
the
DSSI
facility
boundary.
48
The
national
MACT
Risk
Assessment
did
not
include
a
separate
analysis
or
consideration
of
special
subpopulations.
Based
on
the
assumption
that
future
MACT
risk
assessment
will
also
not
include
an
evaluation
of
special
subpopulations,
there
is
an
increased
potential
that
future
Phase
II
Standards
may
not
ensure
protection
to
these
receptors.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
DSSI
Qualitative
Risk
Check
Report
(
EPA
2001h).
Further
justification
for
assigning
DSSI
to
the
high
prioritization
group
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
medium
or
low
group,
these
individual
guiding
factors
alone
do
not
justify
placing
the
facility
in
a
lower
prioritization
grouping.
Additionally,
the
site­
specific
characteristics
at
the
DSSI
facility
exhibits
the
complex
interplay
or
additive
relationships
between
guiding
factors
typically
found
in
the
facilities
assigned
to
the
high
prioritization
group.
Therefore,
based
on
a
review
of
sitespecific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that,

for
the
MACT­
based
prioritization
grouping,
DSSI
is
best
represented
by
facilities
assigned
to
the
high
priority
grouping
and
exhibits
multiple
site­
specific
characteristics
that
clearly
indicate
an
increased
potential
for
adverse
health
impacts.

As
discussed
in
Section
1.2,
placement
into
the
high
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities
at
the
DSSI
facility
in
order
to
quantify
risk
impacts
to
human
health
and
the
environment
since
facilities
in
this
grouping
have
the
largest
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
DSSI
Qualitative
Risk
Check
Report
(
EPA
2001h),
additional
site­
specific
risk
assessment
activities
are
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
future
MACT
standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.
49
2.5
DSM
CHEMICALS
NORTH
AMERICA,
INC.

This
section
presents
the
information
and
approach
used
in
assigning
DSM
Chemicals
North
America,
Inc.

(
DSM)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.5.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.5.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.5.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
DSM
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.5.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
DSM
Qualitative
Risk
Check
Report
(
EPA
2001j).
This
information
is
intended
to
provide
a
general
facility
overview
including
process
descriptions
and
permit
history.

DSM
is
owned
and
operated
by
Dutch
State
Mines
of
North
America
and
was
previously
known
as
Nipro;

its
operations
began
in
1965
(
DSM
1994).
The
DSM
facility
is
located
about
1.6
kilometers
east
of
Augusta
in
Richmond
County,
Georgia.
The
facility
occupies
approximately
600
acres
and
is
bordered
by
the
Savannah
River
on
the
south
and
southeast,
agricultural
land
on
the
east,
Laney
Walker
Boulevard
on
the
north,
Columbia
Nitrogen
Road
on
the
west
and
northwest,
and
industrial
properties
on
the
southwest.

Specifically,
the
site
is
located
at
33o26'
12"
north
latitude
and
81o56'
07"
west
longitude.
DSM
manufacturers
synthetic
organic
chemicals
and
is
the
largest
supplier
of
caprolactum,
a
monomer
of
nylon
used
in
production
of
nylon­
fiber
(
DSM
1996).
The
DSM
facility
consists
of
office
buildings,
farmland,

and
property
that
is
leased
to
other
companies.
The
production
and
process
areas
occupy
about
150
acres,

and
the
holding
ponds,
wastewater
treatment
plant,
and
farmland
occupy
about
250
acres.
50
DSM
operates
four
natural
gas­
fired
boilers
that
discharge
flue
gases
through
a
common
stack
(
DSM
1998).
Only
two
of
the
boilers,
H­
002
and
H­
2002,
are
permitted
to
burn
hazardous
waste.
Boilers
H­
002
and
H­
2002
are
operated
primarily
to
produce
steam
for
the
caprolactum
manufacturing
plant.
Both
boilers
are
Babcock
&
Wilcox
natural
gas­
fired,
water
tube
boilers
(
DSM
1998).
The
H­
002
boiler
consumes
162
million
British
thermal
units
(
Btu)
per
hour
and
supplies
125,000
pounds
per
hour
of
saturated
steam
at
300
pounds
per
square
inch
gauge
(
psig).
The
H­
2002
boiler
consumes
361
million
Btu
per
hour
and
supplies
278,000
pounds
per
hour
of
saturated
steam
at
300
psig.
The
primary
fuel
for
both
boilers
is
natural
gas,
but
both
boilers
also
burn
small
quantities
of
a
waste
organic
fuel
(
a
light
residue).

The
light
residue
is
characterized
as
a
light
organic
by­
product
from
cyclohexanone
distillation
and
nonwater
soluble
organics
that
could
not
be
recovered
or
reused
in
the
process.
The
light
residue
is
characterized
as
hazardous
based
on
ignitability
(
D001)
and
toxicity
(
D­
018)
(
DSM
1998).
Specifically,

of
the
non­
metal
compounds
listed
in
Appendix
VIII
of
40
CFR
Part
261,
the
light
residue
is
known
to
contain
toluene
and
benzene.
Other
wastes
generated
from
the
manufacturing
and
maintenance
processes
include:
benzene
still
bottoms,
paint
wastes,
paint
thinners,
laboratory
wastes,
spill
cleanup
wastes,
and
spent
catalyst.

Controls
within
the
system
prevent
DSM
from
burning
more
than
23
percent
light
residue
at
any
time.
At
maximum
rates,
fuel
feed
to
the
H­
002
boiler
is
about
77
percent
natural
gas
and
23
percent
light
residue.

At
maximum
rates,
fuel
feed
to
the
H­
2002
boiler
consists
of
89
percent
natural
gas
and
11
percent
light
residue.
The
H­
002
and
H­
2002
boilers
are
equipped
with
a
continuous
emissions
monitoring
(
CEM)

system,
and
only
one
boiler
may
burn
light
residue
at
a
time;
however,
no
air
pollution
control
devices
(
APCD)
have
been
installed
on
these
units.
The
CEM
systems
consist
of
carbon
monoxide
and
oxygen
analyzers.

The
DSM
facility
generates
hazardous
wastes
from
various
on­
site
operations.
Most
of
the
wastes
are
associated
with
the
Oxanone
process
unit
(
DSM
1994).
Wastes
are
stored
in
one
of
the
facility's
two
storage
tanks,
T­
527B
and
T­
2523.
Tank
T­
527B
is
a
20,000­
gallon
vessel
permitted
under
Georgia
Hazardous
Waste
Facility
Permit
Number
HW­
016(
S)­
2
for
storing
the
organic
light
residue.
Tank
T­

2523
is
a
25,000­
gallon
vessel
that
is
used
to
store
the
light
residue
before
it
is
burned
in
the
boilers.
Tank
T­
2523
is
intended
for
less­
than­
90­
day
storage,
although
it
is
operated
in
the
same
manner
as
the
permitted
tank.
Both
tanks
are
operated
in
parallel
and
are
rotated
with
one
used
as
a
storage
tank
while
the
other
is
used
as
the
burn
tank,
and
vice­
versa.
Approximately
725,000
gallons
of
light
residue
are
51
generated
annually
by
on­
site
operations.

Nonhazardous
wastes
are
stored
separately
and
mainly
consist
of
waste
oil
and
spent
catalyst
sent
for
recycling.
These
wastes
are
considered
light
by­
products
from
cyclohexanone
distillation
and
from
the
light
organic
wastes
from
the
wastewater
collection
system.
Process
wastewater
is
treated
in
the
wastewater
treatment
plant
(
WWTP).
All
sumps
and
drains
are
directed
to
the
treatment
facility.
After
the
wastewater
is
treated,
it
is
discharged
to
the
Savannah
River.

Boilers
H­
002
and
H­
2002
are
currently
operating
under
interim
status
as
specified
in
the
BIF
Requirements
of
40
CFR
Part
266.
DSM
submitted
a
Certification
of
Precompliance
for
the
H­
002
and
H­

2002
boilers
on
August
19,
1991.
A
Certification
of
Compliance
(
CoC)
for
the
H­
2002
boiler
was
submitted
in
September
1992,
and
a
CoC
was
also
submitted
for
the
H­
002
boiler
in
November
1992.

Recertifications
for
these
boilers
were
submitted
in
October
1995.
Each
boiler
operates
under
Georgia
Air
Quality
Permit
2869­
121­
10372,
which
was
modified
in
1997
(
DSM
1998).
In
1998,
DSM
applied
for
a
Low
Risk
Waste
Exemption
and
a
waiver
of
the
destruction
and
removal
efficiency
(
DRE)
trial
burn
for
the
H­
002
and
H­
2002
boilers.
No
information
was
available
in
facility
files
on
the
status
of
the
application
for
the
Low
Risk
Waste
Exemption
or
waiver
for
the
DRE
trial
burn.

2.5.2
Risk­
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
DSM
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
DSM
Qualitative
Risk
Check
Report
(
EPA
2001j).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
52
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

DSM
Augusta,
Georgia
Risk­
Based
Prioritization
Grouping:
Low
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

DSM
has
been
placed
in
the
low
prioritization
group.
DSM's
designation
in
the
low
priority
group
is
due
in
large
part
to
the
combination
of
a
well
characterized
waste
stream,
which
does
not
contain
known
PBTs,

with
the
lack
of
receptors
located
in
close
proximity
to
the
facility.
In
addition,
when
compared
with
the
12
53
other
facilities
included
in
this
summary
report,
DSM
does
not
exhibit
the
multiple
complicating
factors
that
individually
or
collectively
support
those
facilities
that
have
been
assigned
to
the
medium
or
high
prioritization
groups.
Specifically,
justification
for
grouping
DSM
into
the
low
prioritization
grouping
includes
the
following:


DSM
only
treats
hazardous
waste
that
is
generated
on
site.
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
treat
both
on­
and
off­
site
generated
wastes.


The
hazardous
waste
feed
at
DSM
is
well
characterized,
and
the
facility
is
only
permitted
to
burn
waste
listed
under
two
RCRA
waste
codes­
D001(
ignitability)
and
D018
(
toxicity­
benzene).
Neither
of
these
waste
codes
contains
known
PBTs
or
common
risk
drivers.
In
addition,
DSM
has
filed
for
a
low
risk
waste
exemption.
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
treat
wastes
that
are
known
or
permitted
to
contain
PBTs
and
other
common
risk
drivers.


The
only
fuel
source
used
(
other
than
the
hazardous
waste
feed)
is
natural
gas,
which
comprises
no
less
than
77
percent
of
the
total
fuel
at
any
time.


DSM
only
operates
one
hazardous
waste
boiler
at
a
given
time.
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
have
multiple
hazardous
waste
combustors,
which
are
capable
of
operating
simultaneously.


The
closest
residential
exposure
scenario
is
located
approximately
2
kilometers
northnortheast
of
DSM.
In
comparison,
facilities
assigned
to
the
higher
prioritization
groupings
typically
have
residential
exposure
scenario
locations
within
1
to
1.5
kilometers
of
the
facility
boundary.


The
closest
known
special
subpopulation
is
located
approximately
2
kilometers
north
of
the
facility.


No
documented
public
concerns
are
associated
with
facility
operations.
Facilities
with
significant
documented
public
concerns
are
generally
assigned
to
the
medium
or
high
priority
groupings.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
DSM
Qualitative
Risk
Check
Report
(
EPA
2001j).
Further
justification
for
assigning
DSM
to
the
low
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
medium
or
high
grouping,
these
guiding
factors
alone
do
not
justify
promoting
DSM
into
one
of
the
higher
prioritization
groupings.
Additionally,
due
to
the
absence
of
complex
interplay
or
additive
relationships
between
these
guiding
factors,
the
potential
for
adverse
impacts
is
lessened
and
54
does
not
warrant
designation
to
a
higher
prioritization
grouping.
For
example,
although
the
qualitative
guiding
factor
associated
with
"
the
type
of
receptors
and
exposure
scenarios"
was
assigned
to
the
high
priority
grouping
due
to
the
presence
of
potential
receptors
in
the
assessment
area,
DSM
only
operates
one
boiler
at
a
given
time,
which
treats
on­
site
generated
wastes
that
are
considered
well
characterized
and
not
known
to
contain
PBTs
or
other
highly
toxic
compounds
known
to
be
risk
drivers.
The
final
decision
to
assign
DSM
to
the
low
prioritization
grouping
is
also
reinforced
by
comparing
the
facility
with
the
12
others
included
in
this
report.
DSM
is
best
represented
by
site­
specific
characteristics
exhibited
by
the
low
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
high
priority
grouping.

As
discussed
in
Section
1.2,
placement
into
the
low
prioritization
group
does
not
eliminate
the
need
for
conducting
a
site­
specific
risk
assessment
since
facilities
in
this
grouping
may
still
quantitatively
result
in
adverse
health
impacts.
Therefore,
consistent
with
the
DSM
Qualitative
Risk
Check
Report
(
EPA
2001j),

additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
the
facility
is
operating
in
a
manner
protective
of
human
health
and
the
environment.

2.5.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
DSM
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
DSM
Qualitative
Risk
Check
Report
(
EPA
2001j).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
DSM
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
explains
why
the
facility
was
assigned
to
a
specific
prioritization
grouping.
55
MACT­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

DSM
Augusta,
Georgia
MACT­
based
Prioritization
Grouping:
Low
As
discussed
in
Section
1.1,
while
Phase
I
MACT
standards
do
not
apply
to
facilities
operating
hazardous
waste
fueled
boilers,
it
is
believed
that
development
of
the
future
Phase
II
MACT
standards,
which
will
apply
to
facilities
operating
boilers,
will
also
include
a
national
MACT
risk
assessment.
With
this
assumption
in
mind,
it
is
also
believed
that
the
qualitative
guiding
factors
listed
in
section
1.0
and
the
known
limitations
of
the
Phase
I
national
MACT
risk
assessment
will
also
apply
to
boilers.
As
a
result,
the
56
same
criteria
for
evaluating
and
assigning
facilities
that
are
subject
to
Phase
I
MACT
standards
to
one
of
the
three
prioritization
groupings
utilizing
the
MACT­
based
facility
prioritization
strategy
are
also
applied
to
facilities
with
boilers.
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
table
above,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,
DSM
has
been
placed
in
the
low
prioritization
group
for
the
MACT­
based
prioritization
strategy.
DSM's
designation
in
the
low
priority
group
is
due
in
large
part
to
the
combination
of
a
waste
stream
that
does
not
show
extensive
variability
and
does
not
contain
known
PBTs
with
the
lack
of
receptors
located
in
close
proximity
to
the
facility.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
DSM
does
not
exhibit
the
multiple
complicating
factors
that
individually
or
collectively
support
those
facilities
that
have
been
assigned
to
the
medium
or
high
prioritizations
groups.
Specifically,
justification
for
grouping
DSM
into
the
low
prioritization
grouping
includes
the
following:


Presence
of
well
characterized
waste
feed
generated
on
site
and
known
or
permitted
to
contain
chemicals
not
anticipated
to
be
covered
under
future
MACT
Standards
(
e.
g.,
non­
dioxin
PICs).
In
comparison,
facilities
assigned
to
the
medium
and
high
prioritization
groupings
typically
treat
wastes
from
on­
and
off­
site
sources
that
are
known
or
permitted
to
contain
PBTs
and
other
common
risk
drivers.


Presence
of
off­
site
emission
sources,
including
the
Monsanto
facility,
which
is
located
within
1
kilometer
of
the
DSM
facility
boundary.
Aggregate
off­
site
emission
sources
were
not
included
in
the
national
MACT
risk
assessment
supporting
Phase
I
MACT
limits
and
are
not
expected
to
be
included
in
the
national
MACT
risk
assessment
anticipated
to
support
Phase
II
MACT
limits.
The
presence
of
other
hazardous
waste
combustion
facilities
in
close
proximity
to
the
DSM
facility
indicates
an
increased
potential
for
adverse
impacts
to
receptors.


Residential
exposure
scenarios
are
not
located
in
close
proximity
to
DSM.
For
example,
the
closest
residential
location
is
approximately
2
kilometers
from
the
facility
boundary.
In
comparison,
facilities
assigned
to
the
higher
prioritization
groupings
typically
have
exposure
scenario
locations
within
1
to
1.5
kilometers
of
the
facility
boundary.
In
addition,
the
Phase
I
National
MACT
Risk
Assessment
utilized
16­
sector
based
grid
averaging.
Based
on
the
assumption
that
the
same
approach
will
be
utilized
in
future
MACT
risk
assessments,
this
approach,
when
applied
on
a
site­
specific
basis,
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
resulting
in
the
potential
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenarios
located
in
close
proximity
to
DSM.
However,
because
DSM
does
not
have
residential
exposure
scenarios
located
within
close
proximity
to
the
facility,
there
is
less
potential
for
underestimating
risk
to
these
receptors.


The
selection
of
representative
water
bodies
in
the
national
MACT
risk
assessment
supporting
Phase
I
MACT
standards
may
have
been
biased
to
meet
multiple
selection
57
criteria,
resulting
in
the
potential
for
overlooking
more
heavily
impacted
water
bodies
and
their
associated
watersheds.
However,
there
are
no
water
bodies
that
are
known
to
be
capable
of
fishing
within
3
kilometers
of
the
facility
that
exhibit
characteristics
that
typically
result
in
higher
risk
impacts.
Therefore,
there
is
less
potential
that
the
national
MACT
risk
assessment
that
is
expected
to
support
Phase
II
MACT
standards
will
overlook
risk
to
receptors
from
more
heavily
impacted
water
bodies
in
the
DSM
assessment
area.


The
national
MACT
risk
assessment
supporting
the
Phase
I
MACT
standards
did
not
include
a
separate
analysis
or
consideration
of
special
subpopulations.
However,
the
closest
known
special
subpopulation
is
located
approximately
2
kilometers
from
the
facility.
Therefore,
it
is
less
likely
that
the
national
MACT
risk
assessment
expected
to
support
Phase
II
MACT
standards
will
overlook
special
subpopulations
in
the
DSM
assessment
area.


The
national
MACT
risk
assessment
supporting
the
Phase
I
MACT
standards
did
not
consider
potential
implications
associated
with
public
concerns.
However,
because
there
are
no
documented
public
concerns
associated
with
facility
operations,
there
is
less
potential
that
the
national
MACT
risk
assessment
that
is
expected
to
support
Phase
II
MACT
standards
will
overlook
special
subpopulations
in
the
DSM
assessment
area.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
DSM
Qualitative
Risk
Check
Report
(
EPA
2001h).
Further
justification
for
assigning
DSM
to
the
low
prioritization
group
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
medium
or
high
group,
these
individual
guiding
factors
alone
do
not
justify
promoting
the
facility
to
a
higher
prioritization
grouping.
Additionally,
DSM
does
not
exhibit
the
complex
interplay
or
additive
relationships
between
guiding
factors
typically
found
in
the
facilities
assigned
to
the
higher
prioritization
groups.
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that,
for
the
MACT­
based
prioritization
grouping,
DSM
is
best
represented
by
facilities
assigned
to
the
low
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
higher
groupings.
58
As
discussed
in
Section
1.2,
placement
into
the
low
prioritization
group
does
not
eliminate
the
need
for
conducting
a
site­
specific
risk
assessment
since
facilities
in
this
grouping
may
still
quantitatively
result
in
adverse
health
impacts.
Therefore,
consistent
with
the
DSM
Qualitative
Risk
Check
Report
(
EPA
2001h),

additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
no
adverse
impacts
to
human
health
and
the
environment
are
attributable
to
the
combustion
of
hazardous
waste
through
DSM
facility
operations.
59
2.6
FIRST
CHEMICAL
CORPORATION
This
section
presents
the
information
and
approach
used
in
assigning
First
Chemical
Corporation
(
First
Chemical)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
to
cause
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.6.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.6.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.6.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
First
Chemical
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.6.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
First
Chemical
Qualitative
Risk
Check
Report
(
EPA
2001c).
This
information
is
intended
to
provide
a
general
facility
overview
including
process
descriptions
and
permit
history.

First
Chemical
owns
and
operates
a
chemical
manufacturing
facility
specializing
in
the
production
of
industrial,
intermediate,
specialty,
and
performance
chemicals.
The
principal
products
manufactured
are
aniline,
nitrated
aromatics,
and
aromatic
amines.
A
liquid
injection
incineration
facility
designed
to
oxidize
both
RCRA
listed
and
characteristic
wastes
is
located
on
site.
The
facility
is
subject
to
the
requirements
of
RCRA
promulgated
at
40
CFR
260
through
262,
264
Subparts
A
through
H,
270
and
to
the
equivalent
Mississippi
Department
of
Environmental
Quality
(
MDEQ)
air
regulations.
The
facility
is
located
in
the
town
of
Pascagoula,
Jackson
County,
Mississippi,
approximately
10
kilometers
west
of
the
Alabama
and
Mississippi
border.
The
facility
occupies
60
acres
in
the
Bayou
Casotte
Industrial
Park
on
the
east
side
of
Highway
611
about
1
mile
south
of
the
Jackson
County
Airport
(
First
Chemical
1999a).
The
facility
has
been
in
operation
since
March
1989.
Constructed
features
on
the
property
include
the
following:

(
1)
administrative
buildings;
(
2)
aniline
manufacturing
areas;
(
3)
tank
farm
and
drum
storage
units;

(
4)
cooling
towers
and
sumps;
(
5)
two
open
ponds;
(
6)
two
closed
ponds;
(
7)
stainless­
steel
wash
treatment
tank;
(
8)
wastewater
treatment
plant;
and
(
9)
landfill.
60
The
facility
incinerates
waste
generated
on
site.
Wastes
meeting
waste
feed
limitations
(
i.
e.,
limitations
established
in
the
permit)
for
the
incinerator
are
pumped
through
aboveground
fixed
piping
systems,

managed
onsite
in
five
aboveground
storage
tanks
(
AST),
and
treated
via
incineration.
Occasionally,

wastes
are
placed
into
Department
of
Transportation
(
DOT)
approved
trailer
mounted
tanks
located
at
the
unit
for
temporary
holding
prior
to
incineration.
When
filled,
these
trailers
are
moved
to
unloading
areas
where
the
contents
are
transferred
into
the
permitted
tanks
or
fed
directly
to
the
incinerator.
The
ASTs
are
identified
as
TK­
1057,
TK­
1058,
TK­
1059,
TK­
1060
and
TK­
1403.
Wastes
that
do
not
meet
waste
feed
requirements
are
transported
to
an
off­
site
treatment,
storage,
and
disposal
facility
(
TSDF)
that
is
approved
by
First
Chemical
and
permitted
by
EPA
(
First
Chemical
1999a).

The
carbon
steel
or
stainless­
steel
storage
tanks
used
to
store
waste
materials
prior
to
treatment
in
the
onsite
liquid
injection
incinerator
are
covered
(
with
the
exception
of
TK­
1057)
and
equipped
with
secondary
containment.
The
secondary
containment
structures
are
designed
to
contain
the
volume
of
the
largest
tank
in
addition
to
the
accumulated
rainfall
resulting
from
the
24­
hour,
25­
year
storm
event.
The
tanks
are
overlaid
with
non­
flammable
nitrogen
to
protect
ignitable
wastes
and
are
located
on
raised
concrete
pads
to
facilitate
early
leak
detection.
TK­
1057
is
the
only
tank
equipped
with
a
scrubber
(
First
Chemical
1999a).

The
liquid
injection
incinerator
is
a
refractory­
lined,
horizontal
two­
chamber
system
designed
to
destroy
a
large
amount
of
waste
and
to
restrict
the
development
of
nitrogen
oxides
(
NOx)
from
nitrogen­
containing
compounds
in
the
waste
feed.
The
two­
chamber
system
consists
of
a
reduction
furnace
and
a
re­
oxidation
chamber.
Operational
temperature
is
achieved
by
burning
natural
gas
as
an
auxiliary
fuel
in
a
high
intensity
burner.
Liquid
waste
streams
are
atomized
with
steam
and
fed
to
the
burner
once
the
operating
temperature
is
reached.
Reducing
conditions
are
maintained
in
the
burner
and
reduction
furnace
by
a
controller
that
modulates
the
amount
of
combustion
air
to
the
burner.
Gases
exit
the
burner
and
are
cooled
in
a
quench
bustle
by
recycled
flue
gases
prior
to
entering
the
first­
stage
reduction
furnace.
The
quench
bustle
is
a
high­
velocity
venturi
section
that
mixes
the
hot
burner
gas
with
the
cooler
recycled
flue
gas
to
reduce
the
temperature
(
Focus
1998).
61
The
reducing
environment
prevents
the
nitrogen
in
the
waste
from
being
oxidized
to
NOx
in
the
first­
stage
reduction
furnace.
A
blower
injects
air
from
a
re­
oxidation
bustle
into
the
combustible
gas
from
the
quench
bustle.
Oxidation
of
the
combustibles
results
from
oxygen
in
the
injected
air
mixing
with
the
carbon
monoxide,
hydrogen,
and
hydrocarbon
combustibles
in
the
flue
gas
(
Focus
1998).

The
flue
gas
exits
the
re­
oxidation
chamber
and
passes
through
a
water
tube
boiler
and
an
economizer
section
and
cools
the
flue
gas.
A
blower
recycles
a
portion
of
the
flue
gas
back
to
the
burner
and
the
quench
bustles
before
and
after
the
reduction
chamber
for
gas
cooling.
The
remainder
of
the
flue
gas
is
exhausted
to
the
atmosphere
through
a
stack,
which
is
180
feet
(
approximately
55
meters)
high
(
Focus
1998a).
The
stack
does
not
have
an
air
pollution
control
device
(
APCD)
(
MDEQ
1997).

First
Chemical
submitted
Part
A
and
Part
B
RCRA
permit
applications
in
January
1999.
No
previous
permit
applications
were
identified
in
the
facility
files;
however,
Mr.
Jay
Bassett
of
EPA
Region
4
stated
in
an
interview
with
Tetra
Tech
that
the
facility
was
permitted
prior
to
the
January
1999
permit
application.

Mr.
Bassett
also
stated
that
the
January
1999
permit
application
has
not
been
approved
to
date
(
Tetra
Tech
2001c).
The
Part
A
permit
application
indicated
that
the
facility
held
several
other
environmental
permits
for
air
emissions,
discharge
of
non­
contact
cooling
water,
POTW
pretreatment,
stormwater
discharge,
and
post­
closure
of
lagoon
#
3
(
First
Chemical
1999b).

2.6.2
Risk­
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
First
Chemical
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
First
Chemical
Qualitative
Risk
Check
Report
(
EPA
2001c).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
62
OVERALL
RISK
­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

First
Chemical
Pascagoula,
Mississippi
Risk­
based
Prioritization
Grouping:
Medium
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
considering
how
each
qualitative
guiding
factor
interrelates
collectively,
First
Chemical
has
been
placed
in
the
medium
prioritization
grouping
utilizing
the
overall
risk­
based
prioritization
strategy.
The
medium
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
When
compared
with
the
63
12
other
facilities
included
in
this
summary
report,
First
Chemical
exhibits
multiple
characteristics
consistent
with
those
facilities
assigned
to
the
medium
prioritization
grouping.
Specifically,
the
decision
to
assign
First
Chemical
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


First
Chemical
treats
a
moderately
variable
hazardous
waste
feed
that
is
listed
under
several
RCRA
waste
codes,
including
some
that
contain
compounds
that
are
common
risk
drivers.
Additionally,
First
Chemical
only
treats
waste
that
is
generated
on
site.
In
comparison,
facilities
in
the
high
prioritization
group
typically
treat
highly
variable
waste
that
is
received
from
both
on­
and
off­
site
sources,
and
facilities
in
the
low
prioritization
grouping
typically
treat
well
characterized
waste
that
is
generated
on
site.


First
Chemical
operates
one
hazardous
waste
incinerator.
In
comparison,
facilities
in
the
high
priority
grouping
typically
have
multiple
emissions
sources.


First
Chemical
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
limited
information
is
available.


The
First
Chemical
facility
is
located
in
close
proximity
to
residential,
farmer,
and
fisher
exposure
scenarios.
For
example,
the
closest
residential
exposure
scenario
is
located
approximately
0.75
kilometers
north­
northwest
of
the
facility.


The
closest
known
special
subpopulation
is
located
approximately
2
kilometers
westnorthwest
of
the
facility.


Presence
of
significant
ecological
habitats
and
ecological
receptors
in
close
proximity
to
First
Chemical
(
e.
g.,
Mississippi
sandhill
crane).


Elevated
public
concerns
associated
with
the
protectiveness
of
current
permit
limits.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
First
Chemical
Qualitative
Risk
Check
Report
(
EPA
2001c).
Further
justification
for
assigning
First
Chemical
to
the
medium
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
low
or
high
group,
justification
for
assigning
First
Chemical
to
one
of
the
other
prioritization
groupings
is
not
supported
when
these
factors
are
considered
collectively.
First
Chemical
was
not
assigned
to
the
high
prioritization
grouping
because,
when
compared
with
facilities
assigned
to
the
high
prioritization
grouping,
First
Chemical
clearly
lacked
the
complicating
factors
associated
with
the
facilities
assigned
to
the
high
prioritization
grouping.
For
example,
although
the
qualitative
guiding
factor
associated
with
"
proximity
to
exposure
scenario
location"
was
individually
grouped
into
the
high
prioritization
grouping
due
to
the
presence
of
receptors
within
1
kilometer
of
the
facility,
because
the
waste
feed
at
the
First
Chemical
facility
is
generated
on
site
as
a
byproduct
of
the
64
manufacturing
process
and,
therefore,
is
considered
to
be
only
moderately
variable,
inadequate
justification
was
available
to
support
allocation
into
the
high
prioritization
grouping.
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that
First
Chemical
is
best
represented
by
facilities
assigned
to
the
medium
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
low
and
high
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
a
sitespecific
risk
assessment
since
facilities
in
this
grouping
have
an
increased
potential
to
contribute
to
adverse
impacts
to
human
health
and
the
environment.
Further,
consistent
with
the
findings
presented
in
the
First
Chemical
Qualitative
Risk
Check
Report
(
EPA
2001c),
a
site­
specific
quantitative
risk
assessment
at
the
First
Chemical
facility
is
recommended
to
provide
the
facility
and
permitting
authority
with
the
information
necessary
to
assess
potential
liabilities
and
ensure
the
protection
of
human
health
and
the
environment.

2.6.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
First
Chemical
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
First
Chemical
Qualitative
Risk
Check
Report
(
EPA
2001c).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
First
Chemical
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
65
MACT­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

First
Chemical
Pascagoula,
Mississippi
MACT­
based
Prioritization
Grouping:
Medium
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
(
2)
considering
how
each
qualitative
guiding
factor
interrelates
collectively,
and
(
3)
a
comparison
with
the
12
other
facilities
included
in
this
report,
First
Chemical
has
been
placed
in
the
medium
prioritization
grouping
utilizing
the
MACT­
based
prioritization
strategy.
First
Chemical's
designation
in
the
medium
priority
grouping
is
primarily
influenced
by
the
observation
that,
in
general,
First
Chemical
66
exhibits
several
site­
specific
characteristics
when
compared
with
all
facilities
evaluated
in
this
report,
which
indicate
an
increased
potential
that
compliance
with
MACT
standards
alone
may
not
be
protective
of
human
health
and
the
environment.
Specifically,
the
decision
to
assign
First
Chemical
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
moderately
variable
hazardous
waste
known
or
permitted
to
contain
chemicals
not
covered
under
current
MACT
Standards
(
e.
g.,
non­
dioxin
PICs).
Since
MACT
limits
do
not
apply
to
all
stack
emissions,
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
low
and
high
prioritization
groupings,
First
Chemical
exhibits
multiple
site­
specific
characteristics
that
indicate
an
increased
potential
from
those
facilities
in
the
low
grouping
and
lack
complex
individual
and
additive
qualitative
guiding
factors
indicative
of
the
high
priority
grouping.


Presence
of
other
on­
site
sources
not
evaluated
in
the
national
MACT
risk
assessment
(
e.
g.,
9,117
pounds
of
emissions
from
fugitive
sources).
The
presence
of
over
9,000
pounds
of
fugitive
emissions
indicates
a
clear
increased
potential
for
adverse
impacts.
In
addition,
when
compared
with
facilities
assigned
to
the
low
and
high
prioritization
groupings,
First
Chemical
emits
larger
quantities
of
fugitive
emissions
typically
associated
with
facilities
assigned
to
the
low
prioritization
grouping;
however,
the
types
of
compounds
emitted
as
fugitive
emissions
are
not
known
risk
drivers,
as
the
compounds
emitted
by
facilities
in
the
high
prioritization
grouping
usually
are.


modeling
methodologies
presented
in
the
national
MACT
risk
assessment
would
result
in
the
mis­
classification
of
terrain
in
the
assessment
area
resulting
in
an
increased
potential
for
underestimating
the
concentration
and
deposition,
especially
in
areas
associated
with
increased
terrain
elevation.
As
a
result,
there
is
an
increased
potential
that
the
Phase
I
MACT
limits
evaluated
in
the
National
MACT
Risk
Assessment
resulted
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
of
human
health
and
the
environment
under
the
Phase
I
MACT
Standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
site­
specific
refinement
to
air
dispersion
modeling
methodologies.


Particle
size
distributions
utilized
in
the
national
MACT
risk
assessment
were
not
source
specific
but
were
generalized
based
on
combustion
unit
type.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
Phase
I
MACT
Limits
cannot
be
inferred,
but
require
additional
site­
specific
risk
assessment
activities
including
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment.


The
national
MACT
risk
assessment
did
not
include
an
evaluation
of
acute
exposure.
Since
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.
67

Residential
exposure
scenario
locations
are
located
in
close
proximity
(
i.
e.,
within
0.75
kilometer)
to
the
First
Chemical
facility.
The
Phase
I
National
MACT
Risk
Assessment
utilized
16­
sector
based
grid
averaging.
This
approach,
when
applied
on
a
site­
specific
basis,
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
This
averaging
could
result
in
the
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenarios
located
in
close
proximity
to
First
Chemical.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
Phase
I
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


Presence
of
significant
ecological
habitats
and
ecological
receptors
in
close
proximity
to
First
Chemical,
including
several
threatened
or
endangered
species.
Because
the
national
MACT
risk
assessment
did
not
include
a
separate
analysis
or
consideration
of
threatened
or
endangered
species,
there
is
an
increased
potential
that
current
MACT
standards
may
not
ensure
protection
of
human
health
and
the
environment.


Presence
of
potentially
significant
documented
public
concern
issues.
The
national
MACT
risk
assessment
did
not
consider
potential
impacts
associated
with
public
concerns.
The
permitting
authority
may
need
to
consider
additional
risk
management
options
or
permit
strategies,
in
addition
to
the
current
MACT
standards,
to
ensure
public
concerns
have
been
addressed.
Therefore,
inferred
protection
under
Phase
I
MACT
is
not
supported.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
First
Chemical
Qualitative
Risk
Check
Report
(
EPA
2001c).
Further
justification
for
assigning
First
Chemical
to
the
medium
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
low
or
high
group,
these
individual
factors
alone
do
not
justify
prioritizing
First
Chemical
into
the
low
or
high
grouping.
In
addition,
when
compared
with
facilities
in
the
low
prioritization
grouping,
First
Chemical
clearly
exhibits
several
unique
site­
specific
factors
which
indicate
that
current
MACT
standards
may
not
satisfy
RCRA
protectiveness
mandates.
Furthermore,
when
compared
with
facilities
in
the
high
prioritization
groupings,
First
Chemical
clearly
lacks
the
complex
or
additive
relationships
between
qualitative
guiding
factors,
which
are
common
to
those
facilities
assigned
to
the
high
prioritization
grouping.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities,
since
facilities
in
this
grouping
have
an
increased
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
First
Chemical
Qualitative
Risk
Check
Report
(
EPA
2001c),
additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
current
68
MACT
standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.
69
2.7
GIANT
CEMENT
COMPANY
This
section
presents
the
information
and
approach
used
in
assigning
Giant
Cement
Company
(
Giant)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.7.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.7.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.7.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
Giant
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.7.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
Giant
Qualitative
Risk
Check
Report
(
EPA
2001d).
This
information
is
intended
to
provide
a
general
facility
overview,
including
process
descriptions
and
permit
history.

Giant
owns
and
operates
a
Portland
cement
manufacturing
facility
in
Harleyville,
South
Carolina.
Giant
operates
four
kilns
that
use
hazardous
waste
as
fuel
to
provide
energy
to
the
clinker
and,
therefore,
are
subject
to
the
RCRA
requirements
promulgated
in
Title
40
CFR
Parts
260
through
263,
265,
266,
268,
and
270,
and
the
equivalent
South
Carolina
Department
of
Health
and
Environmental
Control
(
SCDHEC)
state
regulations.
The
Giant
facility
is
located
near
the
junction
of
Interstate
26
and
State
Highway
(
SH)
453
about
1.6
kilometers
north
of
Harleyville
in
the
northeastern
part
of
Dorchester
County.
The
facility
occupies
approximately
1,385
acres
of
land
and
has
been
in
operation
since
1947.
Physical
structures
on
the
property
include
the
cement
manufacturing
facility;
raw
material
and
product
storage
including
container,
drum,
and
tank
farm
storage
units;
a
quarry;
and
buffer
zones.
Giant
also
operates
the
following
hazardous
waste
management
units
to
store
liquid
and
solid
hazardous
waste:
70
S01­
A
Solvent
Unloading
and
Drum
Storage
Area
S02­
A
Solvent
Storage
Tanks
(
6
tanks)

S02­
B
Solids
Storage
Tanks
(
2
tanks)

S02­
F
Heated
Liquid
Storage
Tank
S06
Containment
Building,
which
houses
the
particle
size
reduction
unit
(
X02­
A)

Giant
receives
a
variety
of
hazardous
wastes
from
on­
site
and
off­
site
sources
(
i.
e.,
other
facilities)
via
rail
tank
cars
and
tank
vehicles
(
RFW
1996a).
For
the
waste
generated
on
site,
Giant
collects
and
stores
it
prior
to
use.
For
the
waste
that
is
received
from
off­
site
sources,
Giant
first
analyzes
the
waste
fuels
for
PCBs,

BIF
metals,
heating
value,
and
total
halogen
content,
and
then
stores
the
waste
prior
to
use.

Liquid
waste
fuel
is
stored
in
one
of
the
bulk
liquid
storage
tanks
(
S02­
A)
and
pumped
into
one
of
the
four
independent
cement
kilns.
Vapors
from
the
liquid
fuel
are
vented
into
the
operating
kilns.
During
kiln
downtime,
the
vapors
are
ducted
into
a
carbon
adsorption
system.
All
solid
waste
is
stored
in
a
containment
building
that
is
completely
enclosed
and
ventilated
by
five
separate
fans
 
one
primary
air
fan
intake
for
each
of
the
four
cement
kilns
and
one
separate
ventilation
fan
that
discharges
combustion
air
to
the
solid
fuel
burning
system.
In
addition,
Giant
has
two
solid
fuel
storage
tanks
(
S02­
B)
that
are
associated
with
Kilns
2
and
3.
These
tanks
receive
waste
fuel
from
the
containment
building
by
a
mechanical
conveyance
system
after
the
solid
wastes
have
been
processed.
These
tanks
generally
store
the
waste
for
a
short
period
of
time
before
the
waste
is
transported
to
the
kilns
via
mechanic
conveyors
and
pneumatically
injected
into
the
kilns.

Giant
operates
four
wet
process
rotary
kilns
 
Kilns
2,
3,
4,
and
5
 
which
exhaust
through
two
stacks.

Kilns
2
and
3
and
Kilns
4
and
5,
respectively,
are
served
by
two
different
shared
cement
kiln
stacks.
Kilns
2,
3,
and
4
each
have
a
production
capacity
of
32
tons
per
hour.
Kiln
5
has
a
slightly
larger
diameter
and
can
produce
36
tons
of
clinker
per
hour.
Combined,
the
kilns
have
a
production
capacity
of
132
tons
of
clinker
per
hour.
Each
kiln
is
equipped
with
a
dedicated
reverse
jet
baghouse
with
a
cloth
area
of
approximately
76,000
square
feet
for
air
pollution
control.
Exhausts
from
Kilns
2
and
3
are
filtered
through
their
individual
baghouses
and
released
to
the
atmosphere
via
a
shared
stack;
exhausts
from
Kilns
4
and
5
are
filtered
through
their
individual
baghouses
and
are
released
to
the
atmosphere
via
a
shared
stack.

Raw
materials
for
clinker
production
include
marl
or
limestone,
clay
or
bottom
ash,
sand
and
mill
scale,
or
71
iron
ore,
which
contain
silica,
aluminum,
iron,
and
calcium.
These
materials
are
ground
and
mixed
with
water
to
produce
a
slurry,
which
is
loaded
into
a
kiln
and
converted
to
clinker.
Fuel
is
added
to
the
low
end
of
each
kiln,
while
the
slurry
is
loaded
on
the
higher,
cooler
end
of
the
kiln.
The
temperature
of
the
slurry
gradually
increases
as
the
slurry
moves
through
the
kiln.
When
the
clinker
is
formed,
it
drops
into
the
clinker
cooler,
which
is
located
below
the
low
end
of
the
kiln.
The
exhaust
is
filtered
through
the
baghouse
and
released
from
the
stack.
The
cement
kiln
dust
generated
during
this
process
collects
in
the
baghouse
and
is
removed
through
reverse
jet
bag
cleaning
and
collection
of
the
dust
in
hoppers
beneath
the
filtration
area.

The
dust
is
removed
from
the
hoppers
via
an
enclosed
screw
conveyor
system,
and
a
portion
of
the
dust
is
returned
to
the
kilns.

In
1991,
Giant
filed
a
RCRA
Part
A
permit
application
for
all
four
rotary
cement
kilns.
Since
1991,
Giant
has
been
operating
under
RCRA
Interim
Status,
as
defined
by
RCRA
regulations
governing
BIF
facilities
and
air
quality
operating
permits
issued
by
SCDHEC.
In
August
1991,
Giant
conducted
a
trial
burn
program
and
submitted
the
original
Certification
of
Precompliance
for
Kilns
2,
3,
4,
and
5,
as
required
by
the
BIF
regulations.
In
June
1992,
Giant
submitted
an
amended
precompliance
certification
document.
The
precompliance
certification
established
emission
limits
for
particulate
matter
(
PM)
and
Tier
III
metals
and
chloride.
Giant
is
currently
operating
under
the
limits
of
the
precompliance
certification,
as
revised
by
the
certification
test
conducted
in
1995.
The
revised
precompliance
certification
includes
emission
limits
for
PM,
Tier
III
metals,
chloride,
and
hydrogen
chloride
(
RFW
1998).
Giant
conducted
a
compliance
test
program
in
1998
in
order
to
demonstrate
compliance
for
Kilns
2,
3,
4,
and
5,
as
required
by
the
RCRA
BIF
regulations.
Prior
to
executing
the
test
program,
Giant
received
EPA
approval
to
use
the
test
data
from
Kiln
4
as
surrogate
test
data
for
Kilns
2
and
3.
Compliance
tests
were
conducted
under
maximum
operating
conditions.
The
1998
test
results
indicated
that
emission
concentrations
from
Kilns
4
and
5
were
in
compliance
with
the
emission
limits
established
in
the
Certification
of
Precompliance.
The
1998
compliance
test
was
also
used
to
define
operating
limits
for
Kilns
2,
3,
4,
and
5
during
interim
status
operations.
In
November
1996,
Giant
submitted
a
RCRA
Part
B
permit
application,
a
trial
burn
plan,
and
a
risk
assessment
work
plan
to
EPA.
No
information
was
identified
in
the
facility
files
to
indicate
that
a
trial
burn
had
been
performed.
Based
on
information
available
in
the
files,
neither
EPA
nor
SDHEC
have
approved
the
Part
B
Permit.

2.7.2
Risk­
Based
Facility
Prioritization
72
This
section
describes
the
findings
relative
to
assigning
Giant
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Giant
Qualitative
Risk
Check
Report
(
EPA
2001d).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
73
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Giant
Harleyville,
South
Carolina
Risk­
based
Prioritization
Grouping:
High
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

Giant
has
been
assigned
to
the
high
prioritization
group
based
on
the
overall
risk­
based
prioritization
strategy.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
Giant
clearly
exhibits
multiple
complicating
factors
that
individually
or
collectively
support
its
designation
in
the
74
high
prioritization
group.
This
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
Specifically,
the
decision
to
assign
Giant
to
the
high
prioritization
grouping
is
supported
by
the
following
key
factors:


Giant
treats
hazardous
waste
that
is
received
from
both
on­
and
off­
site
sources.
In
comparison,
facilities
assigned
to
the
low
prioritization
grouping
typically
only
treat
waste
generated
onsite.


The
hazardous
waste
stream
treated
at
Giant
is
considered
to
be
highly
variable
as
the
facility
is
permitted
to
treat
most
D­,
K­,
P­,
U­,
and
F­
listed
RCRA
hazardous
waste,
including
some
that
contain
known
PBTs,
highly
chlorinated
compounds,
and
other
common
risk
drivers.
In
comparison,
facilities
in
the
lower
prioritization
groupings
typically
treat
better
characterized
wastes
that
do
not
contain
known
PBTs
or
common
risk
drivers.


Giant
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
limited
information
is
available.


Presence
of
four
on­
site
cement
kilns
capable
of
operating
simultaneously
and
exhausting
through
shared
stacks.
In
comparison,
facilities
assigned
to
the
low
prioritization
grouping
typically
only
operate
a
single
hazardous
waste
combustor.


Presence
and
close
proximity
of
residential,
farmer,
and
fisher
exposure
scenarios.
For
example,
the
closest
known
residential
exposure
scenario
location
is
within
1
kilometer
of
the
facility.


Presence
and
proximity
of
numerous
waterbodies
and
their
associated
water
sheds,
several
of
which
(
e.
g.,
Huttos
Lake)
exhibit
characteristics
that
typically
result
in
higher
risk
impacts.


Presence
of
significant
ecological
habitats
and
ecological
receptors
in
close
proximity
to
Giant.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Giant
Qualitative
Risk
Check
Report
(
EPA
2001d).
Further
justification
for
assigning
Giant
to
the
high
prioritization
group
is
based
on
the
relationship
or
complex
interplay
associated
with
many
of
the
qualitative
guiding
factors
individually
assigned
to
the
high
group.
For
example,
the
combination
of
a
highly
variable
waste
feed
received
from
both
on­
and
off­
site
sources,
compounded
by
the
presence
of
four
on­
site
cement
kilns
permitted
to
treat
a
wide
variety
of
chemicals,
including
highly
chlorinated
compounds
and
known
PBTs,

and
capable
of
operating
concurrently,
coupled
with
the
presence
and
close
proximity
of
residential,
farmer
and
fisher
exposure
scenarios
and
significant
ecological
habitats,
significantly
elevates
the
potential
for
75
adverse
impacts
to
human
health
and
the
environment.
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that
Giant
is
best
represented
by
facilities
assigned
to
the
high
priority
grouping
and
lacks
commonalities
or
similar
sitespecific
conditions
associated
with
facilities
assigned
to
the
low
and
high
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
high
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities
at
the
Giant
facility
in
order
to
quantify
risk
impacts
to
human
health
and
the
environment
since
facilities
in
this
grouping
have
the
largest
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
Giant
Qualitative
Risk
Check
Report
(
EPA
2001d),
additional
site­
specific
risk
assessment
activities
are
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
the
Giant
facility
meets
the
requirements
of
the
RCRA
omnibus
provisions.

2.7.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
Giant
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Giant
Qualitative
Risk
Check
Report
(
EPA
2001d).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
Giant
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
76
MACT­
BASED
FACILITY
PRIORITIZATION
TABLE
QUALITATIVE
GUIDING
FACTORS
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Giant
Harleyville,
South
Carolina
MACT­
Based
Prioritization
Grouping:
High
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

Giant
has
been
placed
in
the
high
prioritization
group
for
the
MACT­
based
prioritization
strategy.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
Giant
clearly
exhibits
multiple
complicating
factors
that
individually
or
collectively
support
its
designation
in
the
high
prioritization
group.
This
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
which
77
indicate
that
a
remaining
potential
for
adverse
impacts
to
human
health
and
the
environment
exists
even
after
complying
with
current
MACT
standards.
Specifically,
the
decision
to
assign
Giant
to
the
high
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
highly
variable
hazardous
waste
received
from
both
on­
and
off­
site
sources
known
or
permitted
to
contain
chemicals
not
covered
under
current
MACT
Standards
(
e.
g.,
non­
dioxin
PICs,
10
of
the
12
PBTs).
Since
MACT
limits
do
not
apply
to
these
stack
emissions,
the
potential
for
adverse
health
impacts
exists
and
should
be
further
evaluated
quantitatively.
Giant
exhibits
multiple
site­
specific
characteristics
and
complex
individual
and
additive
qualitative
guiding
factors
that
are
not
present
in
the
lower
prioritization
groupings.
These
characteristics,
typically
of
those
facilities
assigned
to
the
high
priority
grouping,
result
in
an
increased
potential
that
Phase
I
MACT
Standards
alone
will
not
be
sufficient
to
ensure
protection
of
human
health
and
the
environment.


Presence
of
on­
site
fugitive
emissions
sources
not
evaluated
in
the
national
MACT
risk
assessment.
The
presence
of
potentially
significant
fugitive
emissions
indicates
a
clear
increased
potential
for
adverse
impacts,
especially
when
considering
the
fact
that
fugitive
emission
sources
were
not
included
in
the
national
MACT
risk
assessment.
In
addition,
when
compared
to
most
of
the
facilities
assigned
to
the
lower
prioritization
groupings,
Giant
emits
larger
quantities
of
fugitive
emissions
that
have
a
higher
probability
of
containing
multiple
toxic
compounds
due
to
the
highly
variable
waste
feed
stored
and
transported
in
these
sources.


Based
on
a
review
of
site­
specific
terrain
characteristics,
modeling
methodologies
presented
in
the
National
MACT
risk
assessment
would
result
in
the
mis­
classification
of
terrain
in
the
assessment
area,
resulting
in
an
increased
potential
for
underestimating
concentration
and
deposition,
especially
in
areas
associated
with
increased
terrain
elevation.
As
a
result,
there
is
an
increased
potential
that
the
Phase
I
MACT
limits
evaluated
in
the
National
MACT
Risk
Assessment
resulted
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
to
human
health
and
the
environment
under
the
Phase
I
MACT
Standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
site­
specific
refinement
to
air
dispersion
modeling
methodologies.


Particle
size
distributions
utilized
in
the
National
MACT
Risk
Assessment
were
not
source
specific,
but
were
generalized
based
on
combustion
unit
type.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
(
1)
protection
based
on
compliance
with
Phase
I
MACT
Limits
cannot
be
inferred,
and
(
2)
additional
site­
specific
risk
assessment
activities,
which
include
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment,
are
required.


The
National
MACT
Risk
Assessment
did
not
include
an
evaluation
of
acute
exposure.
Since
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
78
proximity
to
the
facility,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.


Residential
exposure
scenario
locations
are
located
in
close
proximity
(
i.
e.,
within
1
kilometer)
to
the
Giant
Facility.
The
National
MACT
Risk
Assessment
utilized
16­
sector
based
grid
averaging.
This
approach
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
resulting
in
the
potential
underestimation
of
upperbound
risk
estimates.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
Phase
I
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


The
selection
of
representative
water
bodies
in
the
National
MACT
Risk
Assessment
may
have
been
biased
to
meet
multiple
selection
criteria,
resulting
in
the
potential
for
overlooking
more
heavily
impacted
water
bodies
and
their
associated
watersheds,
which
may
result
in
the
underestimation
of
risk
to
receptors.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
Phase
I
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


Presence
of
significant
ecological
habitats
and
ecological
receptors
in
close
proximity
to
Giant,
including
several
state­
listed
threatened
or
endangered
species
located
in
the
nearby
Francis
Beidler
Park.
The
National
MACT
Risk
Assessment
did
not
include
a
separate
analysis
or
consideration
of
threatened
or
endangered
species.
Therefore,
protection
based
on
Phase
I
MACT
standards
cannot
be
inferred,
but
should
be
evaluated
quantitatively
by
conducting
a
site­
specific
risk
assessment.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Giant
Qualitative
Risk
Check
Report
(
EPA
2001d).
Further
justification
for
assigning
Giant
to
the
high
prioritization
group
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
medium
or
low
group,
these
individual
guiding
factors
alone
do
not
justify
placing
the
facility
in
a
lower
prioritization
grouping.
Additionally,
the
site­
specific
characteristics
at
the
Giant
facility
exhibit
the
complex
interplay
or
additive
relationships
between
guiding
factors
typically
found
in
the
facilities
assigned
to
the
high
prioritization
group.
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that,
for
the
MACT­
based
prioritization
grouping,
Giant
is
best
represented
by
facilities
assigned
to
the
high
priority
grouping
and
exhibits
multiple
site­
specific
characteristics
that
clearly
indicate
an
increased
potential
for
adverse
health
impacts.

As
discussed
in
Section
1.2,
placement
into
the
high
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities
at
the
Giant
facility
in
order
to
quantify
risk
impacts
to
79
human
health
and
the
environment
since
facilities
in
this
grouping
have
the
largest
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
Giant
Qualitative
Risk
Check
Report
(
EPA
2001d),
additional
site­
specific
risk
assessment
activities
are
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
current
MACT
standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.
80
2.8
GLAXOSMITHKLINE,
INCORPORATED
This
section
presents
the
information
and
approach
used
in
assigning
GlaxoSmithKline,
Incorporated
(
GSK)

to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.8.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.8.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.8.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
GSK
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.8.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
GSK
Qualitative
Risk
Check
Report
(
EPA
2001l).
This
information
is
intended
to
provide
a
general
facility
overview
including
process
descriptions
and
permit
history.

GSK
owns
and
operates
a
research
and
development
facility
in
Research
Triangle
Park
(
RTP),
Durham
County,
North
Carolina.
Operations
at
the
facility
are
focused
on
the
discovery,
development,
and
marketing
support
for
new
pharmaceuticals.
The
facility
maintains
an
incinerator
complex
that
incinerates
both
RCRA­
regulated
and
non­
RCRA­
regulated
waste
chemicals
in
liquid,
semisolid,
and
solid
forms
(
GSK
1999).
The
incineration
system
is
designed
to
incinerate
hazardous
waste
via
thermal
oxidation
and
is
subject
to
the
requirements
of
RCRA
promulgated
at
Title
40
CFR
Parts
260
through
263;
264,
Subparts
A
through
H;
and
North
Carolina
Department
of
Environment
and
Natural
Resources
(
NCDENR)
state
regulations
at
North
Carolina
Air
Code
(
NCAC)
15A:
13A.
0013.

The
GSK
facility
located
in
RTP
consists
of
three
campuses:
North
Campus,
Imperial
Campus,
and
South
Campus.
The
incinerator
complex
is
located
on
the
North
Campus.
The
North
Campus
is
located
along
State
Route
147
in
RTP,
about
8
kilometers
from
the
community
of
Durham,
North
Carolina,
in
the
central
81
part
of
Durham
County.
Buildings
on
the
North
Campus
property
include
research
and
development
offices
and
laboratories,
a
pilot
production
area,
research
administration
facilities,
a
Hazardous
Waste
Materials
Management
Building
(
HMMB),
an
Environmental
Safety
Facility
(
ESF),
and
the
Building
15
hazardous
waste
storage
area
(
GSK
1997).
The
total
area
of
the
facility,
including
all
three
campuses,
is
about
1,315
acres
(
DRE
1997).

Hazardous
wastes
generated
at
GSK
are
stored
in
either
the
HMMB,
the
ESF,
or
Building
15.
The
HMMB
includes
a
loading
area,
a
hazardous
materials
laboratory
for
waste
staging
and
segregation,
a
hazardous
waste
treatment
room,
and
waste
storage
areas
for
flammable
waste
(
solvent
waste),
caustic
waste,
acid
waste,
reactive
waste,
and
radioactive
waste
(
GSK
1997).
Also,
one
of
the
rooms
in
the
HMMB
is
used
to
store
waste
that
is
to
be
shipped
off
site
for
disposal
(
GSK
1997).
The
ESF
houses
the
incinerator
complex
and
also
includes
(
1)
a
loading
dock
area;
(
2)
a
liquid
waste
storage
room
for
flammable
wastes
(
solvent
wastes);
(
3)
a
waste
storage
room
for
scintillation
vials;
(
4)
flammable
scintillation
cocktails
and
labpacks;

and
(
5)
waste
storage
areas
for
incinerator
ash,
baghouse
dust,
animal
bedding
waste,
and
animal
carcasses
(
GSK
1997).
Finally,
the
Building
15
hazardous
waste
storage
area
consists
of
a
concrete
pad
adjacent
to
Building
15,
which
is
bordered
by
two
concrete
walls;
the
other
two
sides
are
diked
with
a
6­
inch
concrete
barrier.
This
area
is
used
for
staging
and
storage
of
wastes
generated
from
operations
at
Building
15
.

GSK's
incinerator
unit
is
composed
of
a
primary
combustion
chamber
(
PCC)
with
a
solid
waste
ram
feeder
and
a
dual
fuel
liquid
injection
burner,
a
secondary
combustion
chamber
(
SCC),
a
dry
ash
conveyor
system,

and
an
APCS
(
GSK
1999).
The
PCC
is
a
fixed
hearth
design
and
is
16
feet,
5
inches
long
with
an
internal
diameter
of
6
feet,
5
inches.
The
cross­
sectional
area
of
the
PCC
is
about
32.3
square
feet
(
ft2)
with
a
volume
of
400
cubic
feet
(
ft3).
The
incinerator
operates
in
two
separate
and
distinct
feed
modes:
solids
mode
and
liquids
mode.
In
solids
mode,
the
unit
is
ram
fed
and
uses
the
controlled­
air
PCC
to
remove
hazardous
organic
contaminants
from
solid
wastes,
which
are
batch
fed.
In
liquids
mode,
a
natural
gas
and
liquid
dual
fuel
burner
introduces
hazardous
liquid
waste
to
the
PCC.

The
waste
materials
treated
in
the
PCC
pass
through
three
treatment
phases:
(
1)
drying,
when
the
water
is
evaporated
from
the
feed
stock;
(
2)
heating
and
volatilization
of
organics;
and
(
3)
holding,
when
the
treated
material
is
held
at
temperature
for
a
period
of
time
to
ensure
complete
destruction
of
organic
contaminants
(
GSK
1999).
After
wastes
are
treated
in
the
PCC,
the
material
is
passed
through
to
the
SCC.
The
SCC
82
provides
high
temperature,
residence
time,
and
turbulent
mixing
for
further
heating
and
thermal
destruction
of
any
organic
constituents
that
remain
in
the
gases
from
the
PCC
(
GSK
1999).
The
APCS
treats
gas
exiting
the
gas
mixer
to
remove
acid
gases,
particulates,
and
trace
metals
before
it
is
discharged
through
the
stack
to
the
atmosphere.
The
APCS
consists
of
two
subsystems:
(
1)
a
heat
exchanger
with
dry
lime
injection
and
absorption,
and
(
2)
a
fabric
filter
(
GSK
1999).
Gases
exiting
the
fabric
filter
are
drawn
into
the
induced
draft
(
ID)
fan,
which
maintains
a
negative
pressure
throughout
the
incineration
system;
the
gases
are
then
discharged
through
the
stack
(
GSK
1999).
The
stack
is
made
of
carbon
steel
with
a
3­
inch
acid­
resistant
refractory
lining.
The
top
elevation
of
the
stack
is
134
meters
(
GSK
1999).

GSK
holds
an
EPA
Hazardous
Waste
Service
Association
(
HWSA)
permit
and
RCRA
Part
A
and
Part
B
permits.
In
May
1997,
GSK
submitted
a
Class
III
permit
modification
for
the
North
Campus
Incinerator
to
upgrade
the
fixed
hearth
incinerator,
which
increased
the
liquid
waste
capacity
of
the
unit
through
installation
of
a
new
air­
atomized
burner.
The
permit
modification
was
requested
because
of
increased
throughput
demands
at
the
GSK
North
Campus
Incinerator
(
GSK
1999).
A
RCRA
regulated
trial
burn
was
conducted
in
April
1999
pursuant
to
the
May
1997
request
to
revise
the
facility
permit.
The
current
RCRA
Part
B
permit
will
expire
in
November
2001
(
Tetra
Tech
2001e).

2.8.2
Risk­
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
GSK
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
GSK
Qualitative
Risk
Check
Report
(
EPA
2001l).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.

OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
83
Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

GSK
Research
Triangle
Park,
North
Carolina
Risk­
based
Prioritization
Grouping:
Medium
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

GSK
has
been
placed
in
the
medium
prioritization
group.
The
medium
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
When
compared
with
the
12
other
facilities
included
in
this
summary
report,
GSK
exhibits
multiple
characteristics
consistent
with
those
facilities
assigned
to
the
medium
prioritization
84
grouping.
Specifically,
justification
for
assigning
GSK
to
the
medium
prioritization
grouping
includes
the
following:


GSK
treats
a
moderately
variable
hazardous
waste
feed
that
is
listed
under
several
RCRA
waste
codes.
Additionally,
GSK
only
treats
waste
that
is
generated
on
site.
In
comparison,
facilities
in
the
high
prioritization
group
typically
treat
highly
variable
waste
that
is
received
from
both
on
and
off
site
sources,
and
facilities
in
the
low
prioritization
grouping
typically
treat
well
characterized
waste
that
is
generated
on
site.


GSK
operates
only
one
hazardous
waste
incinerator.
In
comparison,
facilities
in
the
high
prioritization
grouping
typically
have
multiple
sources.


GSK
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
limited
information
is
available.


GSK
Is
located
in
close
proximity
to
residential,
farmer,
and
fisher
exposure
scenarios.
For
example,
the
closest
residential
exposure
scenario
is
located
within
approximately
1.0
kilometer
of
the
facility
boundary.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
GSK
Qualitative
Risk
Check
Report
(
EPA
2001l).
Further
justification
for
assigning
GSK
to
the
medium
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
low
or
high
group,
justification
for
assigning
GSK
to
one
of
the
other
prioritization
groupings
is
not
supported
when
these
factors
are
considered
collectively.
GSK
was
assigned
to
the
medium
prioritization
grouping
because,
when
compared
with
facilities
assigned
to
the
low
prioritization
grouping,
GSK
exhibited
site­
specific
characteristics
indicating
an
increased
potential
for
adverse
risk
impacts
more
consistent
with
facilities
assigned
to
the
medium
prioritization
grouping.
For
example,
although
the
qualitative
guiding
factor
associated
with
"
proximity
to
exposure
scenario
location"

was
individually
grouped
into
the
high
prioritization
grouping
due
to
the
presence
of
receptors
within
1
kilometer
of
the
facility,
because
the
waste
feed
is
typically
well
characterized,
since
its
generated
as
a
onsite
waste
byproduct,
and
since
volumes
of
wastes
treated
annually
is
estimated
at
only
546,000
pounds,

GSK,
while
clearly
indicating
the
potential
for
adverse
risk
impact,
does
not
exhibit
multiple
high
prioritization
grouping
or
the
complex
interplay
associated
with
facilities
assigned
to
the
high
prioritization
grouping.
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that
GSK
is
best
represented
by
facilities
assigned
to
the
medium
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
low
and
high
priority
groupings.
85
As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
a
sitespecific
risk
assessment
since
facilities
in
this
grouping
have
an
increased
potential
to
contribute
to
adverse
impacts
to
human
health
and
the
environment.
Further,
consistent
with
the
findings
presented
in
the
GSK
Qualitative
Risk
Check
Report
(
EPA
2001l),
a
site­
specific
quantitative
risk
assessment
at
the
GSK
facility
is
recommended
to
provide
the
facility
and
permitting
authority
with
the
information
necessary
to
assess
potential
liabilities
and
ensure
the
protection
of
human
health
and
the
environment.

2.8.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
GSK
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
GSK
Qualitative
Risk
Check
Report
(
EPA
2001l).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
GSK
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
86
MACT­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

GSK
Research
Triangle
Park,
North
Carolina
MACT­
based
Prioritization
Grouping:
Medium
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
(
2)
considering
how
each
qualitative
guiding
factor
interrelates
collectively,
and
(
3)
a
comparison
with
the
12
other
facilities
included
in
this
report,
GSK
has
been
placed
in
the
medium
prioritization
grouping
utilizing
the
MACT­
based
prioritization
strategy.
GSK's
designation
in
the
medium
priority
grouping
is
primarily
influenced
by
the
observation
that,
in
general,
GSK
exhibits
several
site­
87
specific
characteristics
when
compared
with
all
facilities
evaluated
in
this
report,
which
indicate
an
increased
potential
that
compliance
with
MACT
standards
alone
may
not
be
protective
of
human
health
and
the
environment.
Specifically,
the
decision
to
assign
GSK
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
moderately
variable
hazardous
waste
known
or
permitted
to
contain
chemicals
not
covered
under
current
MACT
Standards
(
e.
g.,
non­
dioxin
PICs).
Since
MACT
limits
do
not
apply
to
all
stack
emissions,
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
low
and
high
prioritization
groupings,
GSK
exhibits
multiple
site­
specific
characteristics
that
indicate
an
increased
potential
from
those
facilities
in
the
low
grouping,
and
lack
complex
individual
and
additive
qualitative
guiding
factors
indicative
of
the
high
priority
grouping.


modeling
methodologies
presented
in
the
national
MACT
risk
assessment
would
result
in
the
mis­
classification
of
terrain
in
the
assessment
area
resulting
in
an
increased
potential
for
underestimating
concentration
and
deposition,
especially
in
areas
associated
with
increased
terrain
elevation.
As
a
result,
there
is
an
increased
potential
that
the
Phase
I
MACT
limits
evaluated
in
the
National
MACT
Risk
Assessment
resulted
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
of
human
health
and
the
environment
under
the
Phase
I
MACT
Standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
site­
specific
refinement
to
air
dispersion
modeling
methodologies.


Particle
size
distributions
utilized
in
the
national
MACT
Risk
Assessment
were
not
source­
specific,
but
were
generalized
based
on
combustion
unit
type.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
Phase
I
MACT
Limits
cannot
be
inferred,
but
require
additional
site­
specific
risk
assessment
activities
including
the
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment.


The
national
MACT
risk
assessment
did
not
include
an
evaluation
of
acute
exposure.
Since
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.


Residential
exposure
scenario
locations
are
located
in
close
proximity
(
i.
e.,
within
1
kilometer)
to
the
GSK
facility.
The
Phase
I
national
MACT
risk
assessment
utilized
16­
sector
based
grid
averaging.
This
approach,
when
applied
on
a
site­
specific
basis,
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
resulting
in
the
potential
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenarios
located
in
close
proximity
to
GSK.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
Phase
I
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.
88
For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
GSK
Qualitative
Risk
Check
Report
(
EPA
2001l).
Further
justification
for
assigning
GSK
to
the
medium
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
low
or
high
group,
these
individual
factors
alone
do
not
justify
prioritizing
GSK
into
the
low
or
high
grouping.
In
addition,
when
compared
with
facilities
in
the
low
prioritization
grouping,
GSK
clearly
exhibits
several
unique
site­
specific
factors
which
indicate
that
current
MACT
standards
may
not
satisfy
RCRA
protectiveness
mandates.
Furthermore,
when
compared
with
facilities
in
the
high
prioritization
groupings,
GSK
clearly
lacks
the
complex
or
additive
relationships
between
qualitative
guiding
factors,
which
are
common
to
those
facilities
assigned
to
the
high
prioritization
grouping.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities,
since
facilities
in
this
grouping
have
an
increased
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
GSK
Qualitative
Risk
Check
Report
(
EPA
2001l),
additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
current
MACT
standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.
89
2.9
LWD,
INC.

This
section
presents
the
information
and
approach
used
in
assigning
LWD,
Inc.
(
LWD)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.9.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.

Section
2.9.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.9.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
LWD
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.9.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
LWD
Qualitative
Risk
Check
Report
(
EPA
2001a).
This
information
is
intended
to
provide
a
general
facility
overview
including
process
descriptions
and
permit
history.

LWD
owns
and
operates
a
hazardous
waste
storage
and
treatment
facility
for
RCRA
characteristic
and
listed
hazardous
wastes
in
liquid,
semi­
solid,
and
solid
forms.
The
facility
is
subject
to
RCRA
requirements
promulgated
at
Title
40
CFR
Parts
260
through
263,
265,
268
and
270,
and
the
equivalent
Kentucky
Department
of
Environmental
Protection
(
KDEP)
state
regulations
at
401
Kentucky
Administrative
Regulations
(
KAR).
The
facility
is
located
about
0.8
kilometers
north
of
Calvert
City,

Marshall
County,
Kentucky.
The
facility
occupies
31
acres
of
land
within
the
Calvert
City
Industrial
Complex
and
has
been
in
operation
since
the
early
1970s.
LWD
began
operating
this
facility
in
1978,
and
acquired
ownership
of
the
property
in
1980.
Constructed
features
on
the
facility
property
include
(
1)
administrative,
preparation,
receiving,
and
laboratory
buildings;
(
2)
container,
drum,
and
tank
farm
storage
units;
(
3)
an
incineration
building,
which
houses
three
incinerators;
(
4)
a
water
storage
tank;
(
5)
a
clean­
closed,
scrubber
liquor­
cooling
pond
with
liner
and
ancillary
equipment;
and
(
6)
a
closed
landfill.
90
LWD
receives
a
wide
variety
of
hazardous
waste
from
on­
and
off­
site
sources.
Hazardous
waste
is
shipped
to
LWD
in
packages,
drums,
and
bulk
tank
trucks.
Upon
receipt
of
hazardous
waste,
LWD
screens
and
characterizes
the
hazardous
waste.
The
screening
and
characterization
process
consists
of
on­
site
sampling,
analysis,
and
registration
in
a
waste
tracking
system.
Once
screened
and
characterized,

LWD
stores
the
hazardous
waste
and
prepares
it
for
treatment.
LWD
operates
container,
drum,
and
tank
farm
storage
units.
The
tank
farm
is
located
on
the
north
side
of
the
property.

Hazardous
wastes
managed
by
LWD
are
treated
in
one
of
three
operational
hazardous
waste
incinerators
(
Units
1,
2,
and
3).
Each
incinerator
unit
features
waste
feed
mechanisms,
combustion
chambers,
air
pollution
control
devices,
flue
gas
stacks,
and
computerized
process
control
and
instrumentation
equipment.

Unit
1,
a
multi­
chamber
liquid
injection
unit,
has
a
heat
input
capacity
of
40
million
British
thermal
units
per
hour
(
Btu/
hr)
and
is
designed
to
treat
organic
and
aqueous
liquids.
Pollution
control
devices
for
Unit
1
consist
of
a
gas
conditioning
system,
a
baghouse
for
particulate
control,
and
a
scrubber
for
acid
gas
removal.
However,
Unit
1
was
operated
without
air
pollution
control
equipment
until
1978.
Units
2
and
3
have
primary
chambers
that
are
rotary
kilns
designed
to
treat
pumpable
sludges,
packaged
and
bulk
solids,

and
organic
and
aqueous
liquids.
Unit
2
has
a
heat
input
capacity
of
50
million
Btu/
hr,
and
Unit
3
has
a
heat
input
capacity
of
100
million
Btu/
hr.
Stack
heights
are
30.8
meters
for
all
three
units.

In
1978,
KDEP
required
LWD
to
take
interim
compliance
measures
to
reduce
emissions
from
Unit
1
while
construction
of
Unit
2
was
underway.
In
1980,
LWD
filed
RCRA
Part
A
permit
applications
for
Units
1
and
2.
In
1983,
LWD
submitted
RCRA
Part
B
permit
applications
for
all
three
units.
Unit
3
was
granted
RCRA
interim
status
in
1983.
In
1988,
LWD
updated
and
submitted
the
Part
B
permit
applications
for
all
three
units
and
conducted
a
trial
burn
for
each
unit.
In
1990,
KDEP
denied
LWD's
permit
because
of
trial
burn
failures
in
Units
1
and
3
in
September
1990
and
previous
environmental
violations.
However,
KDEP
allowed
for
LWD
to
operate
under
a
restraining
order
until
1991.
In
1991,
KDEP
signed
an
Agreed
Order
containing
provisions
for
additional
trial
burn
testing
for
the
two
units
in
March
1993
and
for
one
unit
in
January
1994.
These
trial
burns
did
not
include
an
analysis
for
metals
and
PICs.
Consequently,
EPA
and
KDEP
will
not
issue
a
permit
until
LWD
conducts
a
complete
trial
burn.
Therefore,
approval
of
the
final
permit
has
not
been
granted.

2.9.2
Risk­
Based
Facility
Prioritization
91
This
section
describes
findings
relative
to
assigning
LWD
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
LWD
Qualitative
Risk
Check
Report
(
EPA
2001a).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
92
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

LWD
Calvert
City,
Kentucky
Risk­
Based
Prioritization
Grouping:
High
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

LWD
has
been
assigned
to
the
high
prioritization
group
based
on
the
overall
risk­
based
prioritization
strategy.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
LWD
clearly
exhibits
multiple
complicating
factors
that
individually
or
collectively
support
its
designation
in
the
93
high
prioritization
group.
This
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
Specifically,
the
decision
to
assign
LWD
to
the
high
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
highly
variable
hazardous
waste
received
from
both
on­
and
off­
site
sources.
In
comparison,
facilities
assigned
to
the
low
prioritization
grouping
typically
only
treat
waste
generated
onsite.


LWD
is
permitted
to
store
and
treat
over
450,000
gallons
of
RCRA
listed
hazardous
waste
per
year,
including
over
200
individual
chemicals,
which
may
include
RCRA
D­,
K­,
P­,
U­,
and
F­
listed
wastes
(
except
F020
and
F021).
These
waste
codes
contain
known
PBTs
and
other
common
risk
drivers.
In
comparison,
facilities
in
the
lower
prioritization
groupings
typically
treat
better
characterized
wastes
that
do
not
contain
known
PBTs
or
common
risk
drivers.


LWD
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
limited
information
is
available.


Presence
of
3
on­
site
incinerators
capable
of
operating
simultaneously.
In
comparison,
facilities
assigned
to
the
low
prioritization
grouping
typically
only
operate
a
single
hazardous
waste
combustor.


Presence
and
close
proximity
of
residential,
farmer,
and
fisher
exposure
scenarios.
For
example,
the
closest
known
residential
exposure
scenario
locations
is
within
0.8
kilometers
from
the
facility.


Presence
and
proximity
of
numerous
waterbodies
and
their
associated
water
sheds,
several
of
which
(
e.
g.,
clear
pond)
exhibit
characteristics
that
typically
result
in
higher
risk
impacts.


Elevated
public
concerns
associated
with
facility
operations,
including
concerns
associated
with
the
protectiveness
of
current
permit
limits
and
the
presence
of
radioactive
materials
in
the
waste
feed.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
LWD
Qualitative
Risk
Check
Report
(
EPA
2001a).
Further
justification
for
assigning
LWD
to
the
high
prioritization
group
is
based
on
the
relationship
or
complex
interplay
associated
with
many
of
the
qualitative
guiding
factors
individually
assigned
to
the
high
group.
For
example,
the
combination
of
a
highly
variable
waste
feed
received
from
both
on
and
off
site
sources,
compounded
by
the
presence
of
three
on­
site
incinerators
permitted
to
treat
over
200
RCRA
listed
chemicals
and
capable
of
operating
concurrently,
coupled
with
the
presence
and
close
proximity
of
residential,
farmer,
and
fisher
exposure
scenarios,
and
in
conjunction
with
documented
public
concerns
associated
with
the
safe
operation
of
the
LWD
based
on
current
permit
limits,
94
significantly
elevates
the
potential
for
adverse
impacts
to
human
health
and
the
environment.
Therefore,

based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that
LWD
is
best
represented
by
facilities
assigned
to
the
high
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
low
and
medium
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
high
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities
at
the
LWD
facility
in
order
to
quantify
risk
impacts
to
human
health
and
the
environment,
since
facilities
in
this
grouping
have
the
largest
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
LWD
Qualitative
Risk
Check
Report
(
EPA
2001a),
additional
site­
specific
risk
assessment
activities
are
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
the
LWD
facility
meets
the
requirements
of
the
RCRA
omnibus
provisions.

2.9.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
LWD
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
LWD
Qualitative
Risk
Check
Report
(
EPA
2001a).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
LWD
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
95
MACT­
BASED
FACILITY
PRIORITIZATION
TABLE
QUALITATIVE
GUIDING
FACTORS
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

LWD
Calvert
City,
Kentucky
MACT­
based
Prioritization
Grouping:
High
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

LWD
has
been
placed
in
the
high
prioritization
grouping
for
the
MACT­
based
prioritization
strategy.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
LWD
clearly
exhibits
multiple
complicating
factors
that
individually
or
collectively
support
its
designation
in
the
high
96
prioritization
grouping.
This
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
which
indicate
that
a
remaining
potential
for
adverse
impacts
to
human
health
and
the
environment
exists
even
after
complying
with
current
MACT
standards.
Specifically,
the
decision
to
assign
LWD
to
the
high
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
highly
variable
hazardous
waste
received
from
both
on­
and
off­
site
sources
known
or
permitted
to
contain
chemicals
not
covered
under
current
MACT
Standards
(
e.
g.,
non­
dioxin
PICs,
10
of
the
12
PBTs).
Since
MACT
limits
do
not
apply
to
all
stack
emissions,
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
lower
prioritization
groupings,
LWD
exhibits
multiple
sitespecific
characteristics
and
complex
individual
and
additive
qualitative
guiding
factors,
which
indicate
an
increased
potential
from
those
facilities
in
the
low
and
medium
groupings.


Presence
of
other
on­
site
sources
not
evaluated
in
the
MACT
risk
assessment.
The
presence
of
potentially
significant
amounts
of
fugitive
emissions
indicates
a
clear
increased
potential
for
adverse
impacts.
In
addition,
when
compared
with
facilities
assigned
to
the
lower
prioritization
groupings,
LWD
is
capable
of
emitting
more
known
risk
drivers
as
fugitive
emissions
due
to
its
highly
variable
waste
feed
than
the
facilities
in
the
low
and
medium
groupings.


modeling
methodologies
presented
in
the
National
MACT
risk
assessment
would
result
in
the
mis­
classification
of
terrain
in
the
assessment
area
resulting
in
an
increased
potential
for
underestimating
concentration
and
deposition,
especially
in
areas
associated
with
increased
terrain
elevation.
Since
areas
with
increased
terrain
elevation
are
present
in
the
assessment
area
and
many
of
them
are
known
or
capable
of
supporting
the
default
exposure
pathways,
there
is
an
increased
potential
that
the
National
MACT
Risk
assessment
underestimated
risk
in
these
areas.
As
a
result,
there
is
an
increased
potential
that
the
Phase
I
MACT
limits
evaluated
in
the
National
MACT
Risk
Assessment
resulted
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
of
human
health
and
the
environment
under
the
Phase
I
MACT
Standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
site­
specific
refinement
to
air
dispersion
modeling
methodologies.


Particle
size
distributions
utilized
in
the
National
MACT
Risk
Assessment
were
not
source
specific,
but
were
generalized
based
on
combustion
unit
type.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
Phase
I
MACT
Limits
cannot
be
inferred,
but
require
additional
site­
specific
risk
assessment
activities
including
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment.


The
National
MACT
Risk
Assessment
did
not
include
an
evaluation
of
acute
exposure.
Since
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
97
standards
can
be
made
without
additional
risk
assessment
activities.


Residential
exposure
scenario
locations
are
located
in
close
proximity
(
i.
e.,
within
0.8
kilometers)
to
the
LWD
Facility.
The
National
MACT
Risk
Assessment
utilized
16­
sector
based
grid
averaging.
This
approach
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
resulting
in
the
potential
underestimation
of
upper­
bound
risk
estimates.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
Phase
I
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


The
selection
of
representative
water
bodies
in
the
National
MACT
Risk
Assessment
may
have
been
biased
to
meet
multiple
selection
criteria,
resulting
in
the
potential
for
overlooking
more
heavily
impacted
water
bodies
and
their
associated
watersheds,
which
may
result
in
the
underestimation
of
risk
to
receptors.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
Phase
I
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


Presence
of
significant
ecological
habitats
and
ecological
receptors
in
close
proximity
to
LWD,
including
several
threatened
or
endangered
species
(
e.
g.,
freshwater
mussels).
Because
the
national
MACT
risk
assessment
did
not
include
a
separate
analysis
or
consideration
of
threatened
or
endangered
species,
there
is
an
increased
potential
that
current
MACT
standards
may
not
ensure
protection
of
human
health
and
the
environment.


Presence
of
potentially
significant
documented
public
concern
issues.
The
National
MACT
Risk
Assessment
did
not
consider
potential
impacts
associated
with
public
concerns.
Therefore,
inferred
protection
under
Phase
I
MACT
standards
is
not
supported.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
LWD
Qualitative
Risk
Check
Report
(
EPA
2001a).
Further
justification
for
assigning
LWD
to
the
high
prioritization
group
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
medium
or
low
group,
these
individual
guiding
factors
alone
do
not
justify
placing
the
facility
in
a
lower
prioritization
grouping.
Additionally,
the
site­
specific
characteristics
at
the
LWD
facility
exhibits
the
complex
interplay
or
additive
relationships
between
guiding
factors
typically
found
in
the
facilities
assigned
to
the
high
prioritization
group.
Therefore,
based
on
a
review
of
sitespecific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that,

for
the
MACT­
based
prioritization
grouping,
LWD
is
best
represented
by
facilities
assigned
to
the
high
priority
grouping
and
exhibits
multiple
site­
specific
characteristics
that
clearly
indicate
an
increased
potential
for
adverse
health
impacts.
98
As
discussed
in
Section
1.2,
placement
into
the
high
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities
at
the
LWD
facility
in
order
to
quantify
risk
impacts
to
human
health
and
the
environment,
since
facilities
in
this
grouping
have
the
largest
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
LWD
Qualitative
Risk
Check
Report
(
EPA
2001a),
additional
site­
specific
risk
assessment
activities
are
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
current
MACT
standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.
99
2.10
MALLINCKRODT
CHEMICAL
COMPANY
This
section
presents
the
information
and
approach
used
in
assigning
the
Mallinckrodt
Chemical
Company
(
Mallinckrodt)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.10.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.10.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.10.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
Mallinckrodt
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.10.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
Mallinckrodt
Qualitative
Risk
Check
Report
(
EPA
2001f).
This
information
is
intended
to
provide
a
general
facility
overview
including
process
descriptions
and
permit
history.

Mallinckrodt
owns
and
operates
a
chemical
plant
that
manufactures
bulk
pharmaceutical
products
and
other
organic
chemicals.
The
primary
process
at
the
facility
involves
manufacturing
acetaminophen
(
APAP)
and
its
precursor,
para­
aminophenol
(
PAP).
The
PAP
process
generates
a
waste
stream
described
as
"
distillation
bottoms
from
the
production
of
aniline,"
which
has
a
hazardous
waste
code
of
K083.
The
facility
is
subject
to
the
requirements
of
RCRA
promulgated
at
Title
40
CFR
Parts
260
through
262,
266
Subpart
H,
and
270.
Mallinckrodt
is
required
under
40
CFR
266.103
to
certify
that
Boilers
1
and
2
comply
with
the
BIF
emission
standards.
Mallinckrodt
is
located
at
8801
Capital
Blvd
in
Raleigh,
Wake
County,
North
Carolina,
about
13
kilometers
northeast
of
downtown
Raleigh
along
U.
S.
Highway
1.
The
facility
is
bordered
by
U.
S.
Highway
1
on
the
east
and
Durant
Road
on
the
south.
The
Mallinckrodt
property
consists
of
about
438
acres,
which
includes
two
PAP
Plants,
the
APAP
Plant,
the
Waste
Treatment
Plant,
and
the
Parenteral
Plant.
100
Mallinckrodt
operates
two
industrial
boilers
that
burn
hazardous
waste
(
Boiler
1
and
Boiler
2)
on
site.
The
boilers
generate
steam
that
is
used
to
heat
process
vessels
and
reactors
at
the
plant
to
manufacture
products
and
other
organic
chemicals.
Mallinckrodt
uses
the
K083
waste
as
fuel
to
power
the
boilers.
Mallinckrodt
receives
no
hazardous
waste
from
off­
site
sources.

According
to
information
obtained
from
the
facility
files,
Boiler
1
has
been
active
since
August
1991
and
Boiler
2
has
been
active
since
August
1993.
Boiler
1
can
burn
natural
gas
or
K083
waste
and
is
rated
at
15,000
pounds
per
hour
(
lbs/
hr)
with
a
heat
input
capacity
of
18.6
million
British
thermal
units
per
hour
(
Btu/
hr).
Boiler
2
is
a
sealed
system
that
operates
under
positive
pressure
and
is
rated
at
25,000
lbs/
hr
with
a
heat
input
capacity
of
30.3
million
Btu/
hr.
Neither
boiler
is
equipped
with
an
APCD.
The
stack
height
for
both
boilers
is
15.2
meters
(
50
feet),
and
the
stack
diameter
for
both
is
0.84
meters
(
2.8
feet).

The
exit
temperature,
which
is
based
on
stack
tests,
is
628
Kelvin
(
K)
for
Boiler
1
and
489
K
for
Boiler
2.

The
exit
velocities
are
also
based
on
stack
tests;
the
exit
velocity
for
Boiler
1
is
13.30
meters
per
second
(
m/
sec)
and
6.36
m/
sec
for
Boiler
2.
(
TEI
1995)

Mallinckrodt
submitted
a
Certification
of
Precompliance
for
Boiler
1
on
August
21,
1991.
The
initial
Certification
of
Compliance
(
COC)
was
submitted
on
September
1,
1992,
which
was
designed
to
demonstrate
that
Boiler
1
is
capable
of
burning
hazardous
waste
within
the
applicable
emission
limits.
A
Recertification
of
Compliance
is
required
within
3
years
after
the
previous
COC
is
submitted
(
DRE
1995b).
In
addition,
a
stack
test
was
conducted
in
December
1993
for
Boiler
2,
and
the
data
from
that
test
were
used
for
model
input
(
TEI
1995).
A
stack
test
for
Boiler
1
was
completed
in
June
1995,
and
the
average
values
from
three
tests
were
used
in
the
air
modeling
for
the
Recertification
of
Compliance,

which
was
submitted
to
EPA
August
29,
1995
(
TEI
1995).
Mallinckrodt
submitted
a
RCRA
Part
B
Permit
Renewal
Application
to
EPA
on
May
4,
2001;
however,
this
application
has
not
been
approved
by
EPA
to
date.
Mallinckrodt's
permit
is
scheduled
to
expire
in
September
2001
(
Tetra
Tech
2001d).
101
2.10.2
Risk
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
Mallinckrodt
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Mallinckrodt
Qualitative
Risk
Check
Report
(
EPA
2001f).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
102
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Mallinckrodt
Raleigh,
North
Carolina
Risk­
based
Prioritization
Grouping:
medium
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

Mallinckrodt
has
been
assigned
to
the
medium
prioritization
group
utilizing
the
overall­
risk
based
prioritization
strategy.
The
medium
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
However,
103
when
compared
with
facilities
assigned
to
the
high
prioritization
grouping,
Mallinckrodt's
potential
risk
impacts
are
clearly
lower.
In
addition,
even
though
several
individual
guiding
factors
were
assigned
to
the
high
prioritization
grouping,
there
is
less
additive
interaction
between
the
qualitative
guiding
factors
for
this
facility
and
increased
uncertainty,
which
limits
definitive
qualitative
conclusions.
Specifically,
the
decision
to
assign
Mallinckrodt
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Mallincrodt
treats
waste
generated
on
site
that
is
considered
to
be
moderately
variable.
Several
toxic
metals,
including
hexavalent
chromium,
have
been
detected
in
the
waste
feed
and
stack
emission
from
Mallinckrodt's
two
boilers.
In
addition,
neither
of
these
boilers
are
equipped
with
an
APCD.
In
comparison,
facilities
in
the
high
prioritization
group
typically
treat
highly
variable
waste
that
is
received
from
both
on­
and
off­
site
sources,
and
facilities
in
the
low
prioritization
grouping
typically
treat
well
characterized
waste
that
is
generated
on
site.


Mallinckrodt
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
limited
information
is
available.


Presence
and
close
proximity
of
residential,
farmer,
fisher,
and
acute
exposure
scenarios.
For
example,
the
closest
known
residential
exposure
scenario
location
is
located
adjacent
to
the
facility
boundary.


Presence
and
proximity
and
numerous
water
bodies
and
their
associated
watersheds,
several
of
which
(
e.
g.,
Greshams
Lake)
are
located
approximately
2.8
kilometers
from
the
facility
boundary.


Presence
of
threatened
or
endangered
species
in
the
study
area.
It
should
be
noted
however
that
their
presence
within
close
proximity
or
within
the
facility
boundary
has
not
been
confirmed.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors
refer
to
the
Mallinckrodt
Qualitative
Risk
Check
Report
(
EPA
2001f).
The
final
decision
to
assign
Mallinckrodt
to
the
medium
prioritization
group
was
further
complicated
by
the
potential
risk
impacts
associated
with
the
presence
of
hexavalent
chromium
(
Cr+
6).
Although
it
is
acknowledged
that
this
compound
can
be
a
significant
risk
driver,
stack
data
and
air
dispersion
modeling
data
were
not
available
to
quantify
risk
impacts.
Potential
risk
impacts
associated
with
this
compound
are
considered
significant,
however,
when
compared
with
those
facilities
assigned
to
the
high
prioritization
grouping,
and
considering
the
uncertainties
associated
with
Cr+
6
at
this
facility,
Mallinckrodt
was
believed
to
be
better
represented
by
the
medium
prioritization
grouping.
It
should
also
be
noted
that
this
facility
is
considered
a
high
priority
within
the
medium
grouping
as
a
result
of
potential
risk
impacts
associated
with
exposure
to
Cr+
6
and
other
site­
specific
factors
identified
in
the
above
table.
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
104
facilities
in
this
report,
it
has
been
determined
that
Mallinckrodt
is
best
represented
by
facilities
assigned
to
the
medium
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
low
and
high
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
a
sitespecific
risk
assessment
since
facilities
in
this
grouping
have
an
increased
potential
to
contribute
to
adverse
impacts
to
human
health
and
the
environment.
Furthermore,
to
remain
consistent
with
the
findings
presented
in
the
Mallinckrodt
Qualitative
Risk
Check
Report
(
EPA
2001f),
a
site­
specific
quantitative
risk
assessment
at
the
Mallinckrodt
facility
is
recommended
to
provide
the
facility
and
permitting
authority
with
the
information
necessary
to
assess
potential
liabilities
and
ensure
the
protection
of
human
health
and
the
environment.

2.10.3
MACT
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
Mallinckrodt
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Mallincrodt
Qualitative
Risk
Check
Report
(
EPA
2001f).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
Mallinckrodt
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
a
specific
prioritization
grouping.
105
MACT­
BASED
FACILITY
PRIORITIZATION
TABLE
QUALITATIVE
GUIDING
FACTORS
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Mallinckrodt
Raleigh,
North
Carolina
MACT
Based
Prioritization
Grouping:
Medium
As
discussed
in
Section
1.1,
while
Phase
I
MACT
standards
do
not
apply
to
facilities
operating
hazardous
waste
fueled
boilers,
it
is
believed
that
the
development
of
future
Phase
II
MACT
standards,
which
will
apply
to
facilities
operating
boilers,
will
also
include
a
national
MACT
risk
assessment.
With
this
assumption
in
mind,
it
is
also
believed
that
the
qualitative
guiding
factors
listed
in
section
1.0
and
the
known
limitations
of
the
Phase
I
national
MACT
risk
assessment
will
also
apply
to
boilers.
As
a
result,
the
same
criteria
for
evaluating
and
assigning
facilities
that
are
subject
to
Phase
I
MACT
standards
to
one
of
the
three
prioritization
groupings
(
utilizing
the
MACT­
based
facility
prioritization
strategy)
are
also
106
applied
to
facilities
with
boilers.
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
table
above,
(
2)
considering
how
each
qualitative
guiding
factor
interrelates
collectively,
and
(
3)
a
comparison
with
the
12
other
facilities
included
in
this
report,

Mallinckrodt
has
been
placed
in
the
medium
prioritization
grouping
utilizing
the
MACT­
based
prioritization
strategy.
Mallinckrodt's
designation
in
the
medium
priority
grouping
is
primarily
influenced
by
the
observation
that,
in
general,
Mallinckrodt
exhibits
several
site­
specific
characteristics
when
compared
with
all
facilities
evaluated
in
this
report,
which
indicate
an
increased
potential
that
compliance
with
MACT
standards
alone
may
not
be
protective
of
human
health
and
the
environment.
Specifically,
the
decision
to
assign
Mallinckrodt
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
moderately
characterized
waste
feed
generated
on
site
that
is
known
or
permitted
to
contain
chemicals
not
anticipated
to
be
covered
under
future
MACT
Standards
(
e.
g.,
non­
dioxin
PICs
and
hexavalent
chromium).
Since
future
MACT
limits
are
not
expected
to
apply
to
all
stack
emissions,
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
low
and
high
prioritization
groupings,
Mallinckrodt
exhibits
multiple
site­
specific
characteristics,
which
indicate
an
increased
potential
from
those
facilities
in
the
low
grouping,
and
lack
complex
individual
and
additive
qualitative
guiding
factors
indicative
of
the
high
priority
grouping.


Presence
of
other
significant
on­
site
fugitive
emission
sources.
Fugitive
emission
sources
were
not
evaluated
in
the
national
MACT
risk
assessment
conducted
to
support
development
of
current
Phase
I
MACT
Standards,
nor
are
they
expected
to
be
considered
during
in
the
national
MACT
risk
assessment
conducted
during
development
of
future
Phase
II
MACT
Standards.
The
fact
that
fugitive
emissions
make
up
78
percent
of
the
total
air
emissions
at
Mallinckrodt
(
as
reported
in
the
1999
TRI
Inventory)
indicates
a
clear
increased
potential
for
adverse
impacts.
In
addition,
when
compared
with
facilities
assigned
to
the
low
and
high
prioritization
groupings,
Mallinckrodt
emits
larger
quantities
of
fugitive
emissions
typically
associated
with
facilities
assigned
to
the
low
prioritization
grouping;
however,
the
types
of
compounds
emitted
as
fugitive
emissions
are
not
known
risk
drivers,
while
the
compounds
emitted
by
facilities
in
the
high
prioritization
grouping
usually
are.


Utilizing
the
same
modeling
methodologies
presented
in
the
national
MACT
risk
assessment
for
selecting
the
appropriate
terrain
option
would
result
in
the
misclassification
of
terrain
in
the
Mallinckrodt
assessment
area.
This
mis­
classification
increases
the
potential
that
concentration
and
deposition
will
be
underestimated
in
areas
with
increased
terrain.
This
issue
is
especially
important
in
the
Mallinckrodt
assessment
area
since
many
exposure
scenario
locations
are
located
in
areas
of
increased
terrain.
Since
areas
with
increased
terrain
elevation
are
present
in
the
assessment
area
and
many
of
them
are
known
or
capable
of
supporting
the
default
exposure
pathways,
there
is
an
increased
potential
that
the
national
MACT
risk
assessment
that
is
expected
to
support
Phase
II
MACT
limits
underestimated
risk
in
107
these
areas.
As
a
result,
there
is
an
increased
potential
that
the
Phase
II
MACT
limits
will
result
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
of
human
health
and
the
environment
under
the
Phase
II
MACT
standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
sitespecific
refinement
to
air
dispersion
modeling
methodologies,
which
were
not
included
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.


Particle
size
distributions
utilized
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards
were
not
source­
specific,
but
were
generalized
based
on
combustion
unit
type.
As
stated
above,
it
is
assumed
that
the
national
MACT
risk
assessment
to
support
Phase
II
MACT
standards
will
utilize
the
same
methodologies
as
those
used
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
future
Phase
II
MACT
Limits
cannot
be
inferred
based
on
this
methodology,
but
will
require
additional
site­
specific
risk
assessment
activities
including
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
sitespecific
risk
assessment.


The
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards
did
not
include
an
evaluation
of
acute
exposure.
Since
(
1)
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility
and
(
2)
it
is
assumed
that
future
MACT
risk
assessments
will
also
not
include
an
evaluation
of
acute
exposure,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.


Residential
exposure
scenario
locations
are
located
in
close
proximity
(
i.
e.,
adjacent)
to
the
Mallinckrodt
facility.
The
Phase
I
national
MACT
risk
assessment
utilized
16­
sector
based
grid
averaging.
Based
on
the
assumption
that
the
same
approach
will
be
utilized
in
future
MACT
risk
assessments,
this
approach,
when
applied
on
a
site­
specific
basis,
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
resulting
in
the
potential
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenario
located
in
close
proximity
to
Mallinckrodt.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
future
Phase
II
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


The
representative
water
bodies
selected
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
limits
may
have
been
biased
to
meet
multiple
selection
criteria,
resulting
in
the
potential
for
overlooking
more
heavily
impacted
water
bodies
and
their
associated
watersheds,
which
may
result
in
the
underestimation
of
risk
to
receptors.
Assuming
that
the
national
MACT
risk
assessment
expected
to
be
conducted
to
support
Phase
II
MACT
limits
will
follow
the
same
methodology,
protection
based
on
compliance
with
Phase
II
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


Established
presence
of
significant
ecological
habitats
in
close
proximity
to
the
Mallinckrodt
facility
and
ecological
receptors,
including
threatened
or
endangered
species
(
e.
g.,
red­
cockaded
woodpecker),
in
Wake
County.
The
national
MACT
Risk
108
Assessment
did
not
include
a
separate
analysis
or
consideration
of
threatened
or
endangered
species.
Based
on
the
assumption
that
future
MACT
risk
assessment
will
also
not
include
an
evaluation
of
threatened
or
endangered
species,
there
is
an
increased
potential
that
future
Phase
II
Standards
may
not
ensure
protection
of
human
health
and
the
environment.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Mallinckrodt
Qualitative
Risk
Check
Report
(
EPA
2001f).
Further
justification
for
assigning
Mallinckrodt
to
the
medium
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
low
or
high
group,
these
individual
factors
alone
do
not
justify
prioritizing
Mallinckrodt
into
the
low
or
high
grouping.
In
addition,
when
compared
with
facilities
in
the
low
prioritization
grouping,
Mallinckrodt
clearly
exhibits
several
unique
site­
specific
factors
which
indicate
that
future
MACT
standards
may
not
satisfy
RCRA
protectiveness
mandates.
Furthermore,
when
compared
with
facilities
in
the
high
prioritization
groupings,
Mallinckrodt
clearly
lacks
the
complex
or
additive
relationships
between
qualitative
guiding
factors,
which
are
common
to
those
facilities
assigned
to
the
high
prioritization
grouping.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities,
since
facilities
in
this
grouping
have
an
increased
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
Mallinckrodt
Qualitative
Risk
Check
Report
(
EPA
2001f),
additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
future
MACT
Standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.
109
2.11
MONSANTO
COMPANY
This
section
presents
the
information
and
approach
used
in
assigning
the
Monsanto
Company
(
Monsanto)

to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.11.1
presents
facility­
specific
background
information,
including
process
descriptions
and
permit
history.
Section
2.11.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.11.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
Monsanto
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.11.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
Monsanto
Qualitative
Risk
Check
Report
(
EPA
2001e).
This
information
is
intended
to
provide
a
general
facility
overview,
including
process
descriptions
and
permit
history.

Monsanto
owns
and
operates
a
multi­
use,
multi­
tenant
facility
in
Augusta,
Georgia.
Specific
operations
performed
at
the
facility
include
the
manufacture
of
pharmaceuticals
by
Searle,
the
manufacture
of
aspartame
(
also
known
as
"
nutrasweet")
by
The
NutraSweet
Company
(
NutraSweet),
and
veterinary
manufacturing.
The
veterinary
manufacturing
portion
of
the
Monsanto
facility
was
under
construction
at
the
time
of
the
Part
B
permit
application
(
Monsanto
1999)
and
was
anticipated
to
begin
operation
in
1999.

No
information
was
identified
regarding
the
current
status
of
the
veterinary
manufacturing
portion
of
the
facility.
Searle
and
NutraSweet
operations
are
conducted
in
separate
sub­
plants
within
the
main
facility.

Waste
streams
generated
at
the
sub­
plants
are
generally
treated
in
one
of
three
combustion
units
located
on
site,
including
a
hazardous
waste
incinerator
(
HWI),
which
treats
hazardous
wastes
generated
by
Searle,

and
two
boilers,
referred
to
as
Boiler
#
1
and
Boiler
#
2,
which
treat
hazardous
wastes
generated
by
NutraSweet.
No
off­
site
wastes
are
treated
at
the
Monsanto
facility.
110
The
facility's
HWI
is
subject
to
the
requirements
of
RCRA
promulgated
at
40
CFR
260
through
263,
265,

270,
and
the
equivalent
Georgia
Environmental
Protection
Division
(
GEPD)
state
regulations.
The
facility's
boilers
are
subject
to
the
Boiler
and
Industrial
Furnace
(
BIF)
Rule
requirements
of
RCRA
promulgated
at
40
CFR
266
Subpart
H
and
Part
268
Subpart
D
and
the
equivalent
GEPD
state
regulations.

The
facility
is
located
along
the
western
bank
of
the
Savannah
River
about
5
kilometers
southeast
of
Augusta,
Richmond
County,
Georgia.
The
portion
of
the
Savannah
River
east
of
the
facility
forms
the
Georgia­
South
Carolina
state
line.
The
facility
occupies
approximately
135
total
acres
of
land,

approximately
55
acres
of
which
are
developed.
The
facility
is
located
in
an
industrial
area
southeast
of
Augusta
and
has
been
in
operation
since
the
1970s.
Constructed
features
on
the
facility
property
include
(
1)
administrative,
preparation,
receiving,
maintenance,
and
laboratory
buildings;
(
2)
container,
drum,
and
tank
farm
storage
units;
(
3)
an
incinerator
building
and
associated
outbuildings;
(
4)
boiler
buildings
and
associated
outbuildings;
(
5)
a
veterinary
manufacturing
plant;
(
6)
a
laydown
yard
for
equipment
and
machinery;
and
(
7)
Searle
and
NutraSweet
process
buildings.

Hazardous
wastes
generated
on
site
by
Searle
and
NutraSweet
are
containerized
and
stored
in
packages,

drums,
and
bulk
tanks.
Hazardous
wastes
are
screened
and
characterized
on
site
via
sampling,
analysis,

and
registration
in
a
waste
tracking
system.
Once
screened
and
characterized,
the
hazardous
waste
is
prepared
for
treatment
in
either
the
incinerator
unit
or
one
of
the
boilers.
The
facility
is
equipped
with
container,
drum,
and
tank
farm
storage
units,
which
are
located
throughout
the
facility.

Hazardous
wastes
generated
on
site
in
the
Searle
plant
(
pharmaceutical
manufacturing)
include
(
1)
hot
solvent
waste
(
HSW),
a
primarily
organic
stream,
and
(
2)
cold
solvent
waste
(
CSW),
a
primarily
aqueous
stream;
these
wastes
are
generally
treated
in
the
HWI
located
in
the
northeastern
corner
of
the
property.

The
incinerator
unit
is
a
liquid
injector
unit
fueled
by
natural
gas
and
has
a
horizontal
combustion
chamber.

The
HWI
features
waste
feed
mechanisms,
a
horizontal
combustion
chamber,
APCDs,
a
flue
gas
stack,
and
computerized
process
control
and
instrumentation
equipment.
The
HWI
has
a
heat
input
capacity
of
about
22
million
Btu/
hr
and
is
designed
to
treat
organic
and
aqueous
liquids.
Pollution
control
devices
for
the
HWI
include
a
quench
chamber
gas
conditioning
system,
a
fiber
filter
mist
eliminator
for
particulate
control,
and
variable
throat
venturi
and
packed
bed
scrubbers
to
remove
gas­
borne
solid
and
liquid
particulates
and
acid
gases.
In
addition,
the
HWI
is
equipped
with
an
automatic
waste
feed
cutoff
system
111
and
stack
gas
monitoring
system
that
sounds
an
alarm
if
target
carbon
monoxide
(
CO)
levels
are
exceeded.

The
stack
height
of
the
HWI
is
16.31
meters.

The
primary
hazardous
waste
stream
generated
in
the
aspartame
manufacturing
process
and
treated
on
site
is
referred
to
as
"
A"­
Waste.
"
A"­
Waste
is
a
reactor
byproduct
stream
composed
primarily
of
methanol,

water,
and
organic
compounds
and
is
typically
treated
on
site
in
one
of
the
facility's
two
boilers
(
Boiler
#
1
and
Boiler
#
2).
According
to
the
facility's
revised
RCRA
Part
B
permit,
other
wastes
generated
on
site,

including
spent
solvents,
laboratory
and
maintenance
wastes,
and
wastes
from
spill
clean­
up,
may
be
burned
in
the
boilers.
Both
boilers
are
forced­
draft,
two­
stage
combustion
units
designed
to
treat
pumpable
organic
and
aqueous
liquids
and
off­
gas.
Boiler
#
1
has
a
heat
input
capacity
of
66
million
Btu/
hr,
while
Boiler
#
2
has
a
heat
input
capacity
of
26
million
Btu/
hr.
For
both
boilers,
flue
gas
from
the
second
stage
of
combustion
flows
through
a
fire­
tube
heat
recovery
boiler
in
which
process
steam
is
generated.
A
fraction
of
the
cooled
fuel
gas
exiting
the
boilers
is
recirculated
to
the
inlet
of
the
second
combustion
stage,

and
the
remainder
flows
to
a
quench/
packed
bed
scrubber.
The
first
stage
of
the
scrubbing
process
involves
cooling
flue
gas
and
removing
hydrogen
chloride.
The
second
scrubber
stage
is
a
caustic
packed
bed
process
for
removing
chlorine
gas
and
residual
hydrogen
chloride.
A
demister
then
removes
entrained
water
droplets.
Exhaust
stack
heights
are
29.72
meters
for
Boiler
#
1
and
29.87
meters
for
Boiler
#
2.

Information
concerning
the
regulatory
history
of
the
HWI
and
Boiler
#
1
and
Boiler
#
2
was
contained
in
various
trial
burn
plans
(
ENSR
International
[
ENSR]
1993,
1998a,
1999),
a
compliance
recertification
report
for
Boiler
#
1
and
Boiler
#
2
(
ENSR
2000),
RCRA
Parts
A
and
B
permit
applications
(
NutraSweet
2000a,
2000b),
and
a
Protocol
for
Screening
Risk
Assessment
(
ENSR
1998b).
A
Notice
of
Hazardous
Waste
Activity
was
filed
for
the
HWI
in
February
1982,
and
a
RCRA
Part
B
Permit
Application
(
Vol.
I,

Subpart
11)
was
submitted
in
January
1982.
A
draft
permit
for
incinerating
of
liquid
organic
and
aqueous
wastes
in
the
HWI
was
issued
to
the
facility
in
July
1987,
followed
by
a
final
permit
issued
in
September
1987.
The
RCRA
Part
B
permit
for
the
HWI
was
amended
in
March
1990
to
incorporate
new
performance
standards.
Air
dispersion
modeling
was
performed
for
Boiler
#
1
and
Boiler
#
2
at
the
NutraSweet
subplant
in
May
1992
to
determine
allowable
emission
rates
(
Radian
1992).
The
facility
submitted
a
RCRA
Part
B
Permit
Renewal
Application
in
January
1997
(
including
incineration
of
HSW
and
CSW)
and
subsequently
received
Permit
#
HW­
048(
ST).
A
RCRA
Part
C
Permit
Application
was
submitted
in
June
1999,
which
included
a
Protocol
for
Screening
Risk
Assessment
(
ENSR
1998b).
112
Monsanto
submitted
a
RCRA
Part
B
Permit
Application
in
May
1999,
which
included
a
Trial
Burn
Plan
and
target
physical
and
chemical
parameters
for
the
HWI,
Boiler
#
1,
and
Boiler
#
2.
Finally,
NutraSweet
submitted
a
Compliance
Recertification
Report
for
Boiler
#
1
and
Boiler
#
2
Pursuant
to
the
BIF
Regulations
in
November
2000
(
ENSR
2000).
This
Recertification
Report
contained
the
results
of
a
test
burn
performed
for
Boiler
#
1
and
Boiler
#
2.
No
evidence
was
found
in
the
file
to
indicate
that
a
trial
burn
to
support
a
site­
specific
risk
assessment
has
been
conducted
on
the
HWI
or
either
of
the
boilers.

2.11.2
Risk
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
Monsanto
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Monsanto
Qualitative
Risk
Check
Report
(
EPA
2001e).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
113
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Monsanto
August,
Georgia
Risk­
based
Prioritization
Grouping:
medium
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

Monsanto
has
been
assigned
to
the
medium
prioritization
group
utilizing
the
overall­
risk
based
prioritization
strategy.
The
medium
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
However,
114
when
compared
with
facilities
assigned
to
the
high
prioritization
grouping,
Monsanto's
potential
risk
impacts
are
clearly
lower
than
those
facilities.
In
addition,
even
though
several
individual
guiding
factors
were
assigned
to
the
high
prioritization
grouping,
there
is
less
additive
interaction
between
the
qualitative
guiding
factors
for
this
facility
and
increased
uncertainty,
which
limits
definitive
qualitative
conclusions.

Specifically,
the
decision
to
assign
Monsanto
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Monsanto
generates
and
treats
an
estimated
343
million
pounds
of
hazardous
waste
annually
in
the
on­
site
incinerator
and
two
boilers.
In
comparison,
most
facilities
ranked
in
the
low
prioritization
group
treat
significantly
less
hazardous
waste
and
only
operate
one
hazardous
waste
combustor.


Monsanto
is
permitted
to
burn
most
RCRA
D­,
F­,
P,
and
U­
listed
wastes,
including
known
PBTs
and
common
risk
drivers.
In
comparison,
facilities
ranked
in
the
low
prioritization
group
typically
treat
waste
that
is
better
characterized
and
does
not
contain
PBTs
or
common
risk
drivers.


Monsanto
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
information
on
actual
stack
emission
is
limited.


Presence
of
residential,
farmer,
fisher,
and
acute
exposure
scenarios
located
within
3
kilometers
of
the
Monsanto
Facility.
Facilities
in
the
high
prioritization
grouping
typically
have
sources
that
are
located
within
1
to
1.5
kilometers
of
the
facility
boundary.


Presence
and
proximity
of
numerous
water
bodies
and
their
associated
watersheds,
several
of
which
(
e.
g.,
Clay
Ponds)
are
located
within
2.0
kilometers
from
the
facility
boundary.
In
addition,
the
clay
Ponds
exhibit
several
characteristics
(
e.
g.,
small,
low
volumetric
flow
rates)
that
may
result
in
increased
water
body
concentrations.


Presence
of
threatened
or
endangered
species
(
e.
g.,
wood
stork
and
red­
cockaded
woodpecker)
in
the
study
area.
However,
it
should
be
noted
that
their
presence
within
close
proximity
or
within
the
facility
boundary
has
not
been
confirmed.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Monsanto
Qualitative
Risk
Check
Report
(
EPA
2001e).
Several
individual
qualitative
guiding
factors
assigned
to
the
medium
and
high
prioritization
groupings
indicate
an
increased
potential
for
adverse
risk
impacts.
Specifically,
the
volumes
and
type
of
wastes
and
associated
emissions
are
considered
significant;
however,
since
actual
and
potential
future
exposure
scenarios
are
not
located
within
close
proximity
(
i.
e.,
1
to
2
kilometers)
to
the
facility
boundary,
Monsanto
was
believed
to
be
better
represented
by
the
medium
prioritization
grouping.

In
addition,
when
compared
to
the
12
other
facilities
included
in
this
report,
Monsanto
consistently
exhibited
characteristics
associated
with
the
those
facilities
assigned
to
the
medium
prioritization
grouping.
115
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
Monsanto
is
best
represented
by
facilities
assigned
to
the
medium
priority
grouping
and
lacks
commonalities
or
similar
site­
specific
conditions
associated
with
facilities
assigned
to
the
low
and
high
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
a
sitespecific
risk
assessment
since
facilities
in
this
grouping
have
an
increased
potential
to
contribute
to
adverse
impacts
to
human
health
and
the
environment.
Further,
consistent
with
the
findings
presented
in
the
Monsanto
Qualitative
Risk
Check
Report
(
EPA
2001e),
a
site­
specific
quantitative
risk
assessment
at
the
Monsanto
facility
is
recommended
to
provide
the
facility
and
permitting
authority
with
the
information
necessary
to
assess
potential
liabilities
and
ensure
the
protection
of
human
health
and
the
environment.

2.11.3
MACT
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
Monsanto
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Monsanto
Qualitative
Risk
Check
Report
(
EPA
2001e).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
Monsanto
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
a
specific
prioritization
grouping.
116
MACT­
BASED
FACILITY
PRIORITIZATION
TABLE
QUALITATIVE
GUIDING
FACTORS
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters
Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Monsanto
Augusta,
Georgia
MACT­
based
Prioritization
Grouping:
Medium
As
discussed
in
Section
1.1,
while
Phase
I
MACT
standards
do
not
apply
to
facilities
operating
hazardous
waste
fueled
boilers,
it
is
believed
that
the
development
of
future
Phase
II
MACT
standards,
which
will
apply
to
facilities
operating
boilers,
will
also
include
a
national
MACT
risk
assessment.
With
this
assumption
in
mind,
it
is
also
believed
that
the
qualitative
guiding
factors
listed
in
section
1.0
and
the
known
limitations
of
the
Phase
I
national
MACT
risk
assessment
will
also
apply
to
boilers.
As
a
result,
the
117
same
criteria
for
evaluating
and
assigning
facilities
that
are
subject
to
Phase
I
MACT
standards
to
one
of
the
three
prioritization
groupings
utilizing
the
MACT­
based
facility
prioritization
strategy
are
also
applied
to
facilities
with
boilers.
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
table
above,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,
Monsanto
has
been
assigned
to
the
medium
prioritization
group
utilizing
the
MACT­
based
prioritization
strategy.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
Monsanto
clearly
exhibits
multiple
complicating
factors
that
individually
or
collectively
support
its
designation
in
the
medium
prioritization
group.
This
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
the
potential
for
remaining
adverse
risk
impacts
even
after
compliance
with
current
and
future
MACT
Standards.
Specifically,
the
decision
to
assign
Monsanto
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
moderately
characterized
waste
feed
known
or
permitted
to
contain
chemicals
not
covered
under
current
MACT
standards
nor
anticipated
to
be
covered
under
future
MACT
Standards
(
e.
g.,
non­
dioxin
PICs).
Since
current
MACT
limits
do
not
apply
to
all
stack
emissions
and
future
MACT
limits
are
not
expected
to,
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
low
and
high
prioritization
groupings,
Monsanto
exhibits
multiple
site­
specific
characteristics
which
indicate
an
increased
potential
from
those
facilities
in
the
low
grouping,
and
lack
complex
individual
and
additive
qualitative
guiding
factors
indicative
of
the
high
priority
grouping.


Presence
of
other
significant
on­
site
sources,
including
the
presence
of
one
incinerator,
two
boilers,
and
associated
fugitive
emission
sources.
Fugitive
emission
sources
were
not
evaluated
in
the
national
MACT
risk
assessment
conducted
to
support
the
development
of
current
Phase
I
MACT
Standards,
nor
are
they
expected
to
be
considered
during
the
national
MACT
risk
assessment
conducted
during
the
development
of
future
Phase
II
MACT
Standards.
The
fact
that
fugitive
emissions
have
been
established
at
the
Monsanto
facility
indicates
a
clear
increased
potential
for
adverse
impacts.
In
addition,
when
compared
with
facilities
assigned
to
the
low
and
high
prioritization
groupings,
Monsanto
emits
larger
quantities
of
fugitive
emissions
than
those
typically
associated
with
facilities
assigned
to
the
low
prioritization
grouping;
however,
the
types
of
compounds
emitted
as
fugitive
emissions
are
not
known
risk
drivers,
as
the
compounds
emitted
by
facilities
in
the
high
prioritization
grouping
usually
are.


Presence
of
off­
site
emission
sources,
including
the
DSM
facility,
which
is
located
within
1
kilometer
of
the
Monsanto
facility
boundary.
Aggregate
off­
site
emission
sources
were
not
included
in
the
national
MACT
risk
assessment
supporting
Phase
I
MACT
limits
and
are
not
expected
to
be
included
in
the
national
MACT
risk
assessment
anticipated
to
support
Phase
II
MACT
limits.
The
presence
of
other
hazardous
waste
combustion
facilities
in
close
proximity
to
the
Monsanto
facility
indicates
an
increased
potential
for
adverse
impacts
to
receptors.
118

Utilizing
the
same
modeling
methodologies
presented
in
the
national
MACT
risk
assessment
for
selecting
the
appropriate
terrain
option
would
result
in
the
misclassification
of
terrain
in
the
Monsanto
assessment
area.
This
mis­
classification
increases
the
potential
that
concentration
and
deposition
will
be
underestimated
in
areas
with
increased
terrain.
This
issue
is
especially
important
in
the
Monsanto
assessment
area
since
many
exposure
scenario
locations
are
located
in
areas
of
increased
terrain.
Since
areas
with
increased
terrain
elevation
are
present
in
the
assessment
area,
and
many
of
them
are
known
or
capable
of
supporting
the
default
exposure
pathways,
there
is
an
increased
potential
that
the
national
MACT
risk
assessment
that
supported
Phase
I
MACT
limits
underestimated
risk
in
these
areas.
Assuming
that
the
methodology
in
performing
the
national
MACT
risk
assessment
supporting
Phase
II
MACT
limits
will
be
the
same,
it
will
also
likely
underestimate
risk
in
these
areas.
As
a
result,
there
is
an
increased
potential
that
both
the
Phase
I
MACT
limits
and
the
Phase
II
MACT
limits
will
result
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
to
human
health
and
the
environment
under
the
Phase
I
or
Phase
II
MACT
standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
site­
specific
refinement
to
air
dispersion
modeling
methodologies.


Particle
size
distributions
utilized
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards
were
not
source­
specific,
but
were
generalized
based
on
combustion
unit
type.
As
stated
above,
it
is
assumed
that
the
national
MACT
risk
assessment
to
support
Phase
II
MACT
standards
will
utilize
the
same
methodologies
as
those
used
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
current
or
future
MACT
limits
cannot
be
inferred
based
on
this
methodology,
but
will
require
additional
site­
specific
risk
assessment
activities
including
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
sitespecific
risk
assessment.


The
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards
did
not
include
an
evaluation
of
acute
exposure.
Since
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility
and
it
is
assumed
that
future
MACT
risk
assessments
will
also
not
include
an
evaluation
of
acute
exposure,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.


The
selection
of
representative
water
bodies
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
limits
may
have
been
biased
to
meet
multiple
selection
criteria,
resulting
in
the
potential
for
overlooking
more
heavily
impacted
water
bodies
and
their
associated
watersheds,
which
may
result
in
the
underestimation
of
risk
to
receptors.
Assuming
that
the
national
MACT
risk
assessment
expected
to
be
conducted
to
support
Phase
II
MACT
limits
will
follow
the
same
methodology,
protection
based
on
compliance
with
Phase
II
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.
119

Established
presence
of
significant
ecological
habitats
in
close
proximity
to
the
Monsanto
facility
and
ecological
receptors,
including
threatened
or
endangered
species.
The
national
MACT
Risk
Assessment
did
not
include
a
separate
analysis
or
consideration
of
threatened
or
endangered
species.
Based
on
the
assumption
that
future
MACT
risk
assessment
will
also
not
include
an
evaluation
of
threatened
or
endangered
species,
there
is
an
increased
potential
that
current
and
future
MACT
standards
may
not
ensure
protection
of
human
health
and
the
environment.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Monsanto
Qualitative
Risk
Check
Report
(
EPA
2001e).
Further
justification
for
assigning
Monsanto
to
the
medium
prioritization
grouping
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
low
or
high
group,
these
individual
factors
alone
do
not
justify
prioritizing
Monsanto
into
the
low
or
high
grouping.
In
addition,
when
compared
with
facilities
in
the
low
prioritization
grouping,
Monsanto
clearly
exhibits
several
unique
site­
specific
factors
which
indicate
that
future
MACT
standards
may
not
satisfy
RCRA
protectiveness
mandates.
Furthermore,
when
compared
with
facilities
in
the
high
prioritization
groupings,
Monsanto
clearly
lacks
the
complex
or
additive
relationships
between
qualitative
guiding
factors,
which
are
common
to
those
facilities
assigned
to
the
high
prioritization
grouping.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities,
since
facilities
in
this
grouping
have
an
increased
potential
for
contributing
to
adverse
health
impacts.
Therefore,
as
consistent
with
the
Monsanto
Qualitative
Risk
Check
Report
(
EPA
2001e),
additional
site­
specific
risk
assessment
activities
are
still
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
current
and
future
MACT
standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.
