***********************************************

BRIEFING
FOR
OMB
ON
PROPOSED
NESHAP
(
CAA
112D)

FOR
HAZARDOUS
WASTE
COMBUSTORS
***********************************************

Office
of
Solid
Waste
January
26,
2004
***********************************************
­
2­

PURPOSE
OF
BRIEFING

To
summarize
MACT
rulemaking
proposal
for
hazardous
waste
combustors
SCOPE
OF
BRIEFING

BACKGROUND
­
­
DESCRIPTION
OF
AFFECTED
INDUSTRY
SECTORS

OVERVIEW
OF
CLEAN
AIR
ACT
REQUIREMENTS
GOVERNING
TECHNOLOGY­
BASED
EMISSION
STANDARDS

HISTORY
­
IMPETUS
OF
RULEMAKING
­
LITIGATION
­
COURT
DECISION

SCOPE
OF
RULEMAKING

DESCRIPTION
OF
FLOOR
METHODOLOGIES
USED
TO
ADDRESS
COURT
OPINION

PROPOSED
STANDARDS,
COSTS
AND
BENEFITS
­
3­

BACKGROUND
­
­
DESCRIPTION
OF
AFFECTED
INDUSTRY
SECTORS

Industry
sectors
combusting
hazardous
waste
that
are
subject
to
this
rulemaking:

o
Cement
Kilns,
Lightweight
Aggregate
Kilns,
Incinerators,
Industrial
Boilers,
Hydrochloric
Acid
Production
Furnaces

Amount
of
hazardous
waste
combusted
and
number
of
affected
sources
o
See
figures
on
following
pages
­
4­

Estimated
Total
Annual
Hazardous
Waste
Generation
U.
S.
Tons
Total,
Excluding
Combusted
HW,
36,426,050
Combusted
Hazardous
Waste,
3,600,000
­
5­

Estimated
Annual
Quantity
of
Hazardous
Waste
Combusted
U.
S.
Tons
Commercial
Incinerators
452,200
Captive
Incinerators
(
On­

Site)
1,010,600
Commercial
Energy
Recovery
(
Cement
Kilns,
LWAKs)

1,093,800
Captive
Energy
Recovery
(
Boilers
)
1,001,500
­
6­

Hazardous
Waste
Burning
Sources
Commercial
Incinerators,
15
On­
Site
Incinerators,
92
Cement
Kilns,
26
LWAKs,
7
Solid
Fuel
Boilers,
12
Liquid
Fuel
Boilers,
107
HCL
Production
Furnaces,
17
­
7­

OVERVIEW
OF
CLEAN
AIR
ACT
REQUIREMENTS
GOVERNING
TECHNOLOGY­
BASED
EMISSION
STANDARDS

Hazardous
waste
combustor
(
HWC)
emissions
historically
regulated
by
RCRA
(
risk­
based
standards)


HWC
emissions
of
hazardous
air
pollutants
(
HAPs)
also
must
be
regulated
under
CAA
technology­
based
standards
reflecting
the
performance
of
the
Maximum
Achievable
Control
Technology
(
MACT)

o
OSW
designated
as
lead
office
to
issue
these
technology­
based
standards
for
HWCs
o
MACT
standards,
for
the
most
part,
will
supersede
current
RCRA
emission
standards

MACT
standards
(
CAA
112(
d)(
3))
must
reflect
a
minimum
level
of
stringency,
known
as
the
"
Floor"

o
What
is
the
Floor?
MACT
standards
for
existing
sources
shall
not
be
less
stringent
than
the
average
emission
limitation
achieved
by
the
best
performing
12
percent
of
the
existing
sources
(
for
which
the
Administrator
has
emissions
information),
in
the
category
or
subcategory
with
30
or
more
sources;
or
the
average
emission
limitation
achieved
by
the
best
performing
5
sources
in
the
category
or
subcategory
with
fewer
than
30
sources.


Costs
cannot
be
considered
in
determining
the
Floor
level.
Considerations
of
risk
are
likewise
legally
irrelevant.


EPA
must
then
determine
if
more
stringent
standards
are
achievable,
and
must
consider
costs,
energy
use,

and
nonair
health
and
environmental
impacts
in
making
this
determination.
Standards
issued
pursuant
to
this
authority
are
called
`
beyond­
the­
floor'.
­
8­


Comparable
provisions
exist
for
establishing
standards
for
new
sources,
except
Floor
is
based
on
performance
of
the
single
best
performing
source.

HISTORY
­
IMPETUS
OF
RULEMAKING
­
LITIGATION
­
COURT
DECISION

Originally
planned
to
promulgate
MACT
standards
for
HWCs
in
two
phases
o
Phase
1:
hazardous
waste
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
o
Phase
2:
hazardous
waste
boilers
and
hydrochloric
acid
production
furnaces
o
Phase
1
MACT
standards
promulgated
September
1999
­
Regulated
specific
HAP
metals,
particulate
matter
(
as
a
surrogate
for
other
HAP
metals),

dioxin/
furans,
total
chlorine,
and
organic
hazardous
air
pollutant
emissions
­
­
Estimated
total
annualized
social
costs
to
comply
with
rule:
$
50­
63
million
­
­
Estimated
total
annualized
human
health
benefits:
$
19
million
­
Industry
and
environmental
groups
litigated

Court
Decision
o
On
July
24,
2001,
DC
Circuit
Court
granted
Sierra
Club's
Petition
for
Review
­
9­

­
Vacated
the
challenged
emission
standards
o
Court
said
EPA
failed
to
demonstrate
that
its
methodology
for
ascertaining
the
floor
level
for
new
and
existing
sources
adequately
assessed
the
performance
of
the
average
of
the
12%
of
best
performing
sources;
key
inadequacy
was
failure
to
assess
"
best
performing"


What
was
our
general
methodology?

o
Defined
MACT
control
for
each
pollutant
as
either
a
"
back
end"
control
(
assessing
performance
of
air
pollution
control
device
on
stack
emissions),
or
hazardous
waste
feedrate
control,
or
combination
of
both
o
Looked
at
emissions
from
all
sources
using
that
MACT
technology
when
properly
designed
and
operated,
not
just
the
best
12%
(
expanded
MACT
pool)

o
Highest
emissions
in
expanded
pool
represented
the
MACT
floor
o
Method
was
chosen
as
a
way
to
assess
emission
variability
for
the
best
performing
sources
­
OAQPS
used
this
methodology
in
a
number
of
their
rules
as
well

What
specifically
did
the
Court
reject?

o
We
failed
to
justify
that
expansion
of
the
MACT
pool
reflected
the
best
sources'
performance
o
Court
opinion
left
door
open
for
negotiated
interim
standards;
ultimate
standards
satisfying
the
court's
­
10­

mandate
still
required

Negotiated
Interim
Standards
o
The
court
indicated
it
would
not
vacate
the
rule
until
we
adopted
interim
standards,
so
that
there
would
be
no
regulatory
gap.
In
February
2002,
we
negotiated
interim
standards
that
remain
in
effect
until
we
promulgate
replacement
standards
that
address
the
court
opinion
o
Key
aspects
of
negotiated
agreement
­
Interim
standards:

­
­
Relaxed
10
of
the
48
promulgated
emission
standards
(
see
Attachment
A
for
a
comparison
of
the
standards
promulgated
in
1999
and
the
negotiated
interim
standards)

­
­
­
These
standards
do
not
represent
MACT;
they
are
placeholders
­
­
Delayed
the
compliance
date
one
year
­
­
Relaxed
several
compliance/
implementation
requirements
­
Schedule
for
rule
actually
reflecting
MACT
(
called
replacement
standards):

­
­
Entered
into
consent
decree
(
which
is
judicially
enforceable)
requiring
us
to
issue
a
final
rule
for
incinerators,
cement
kilns,
and
aggregate
kilns
by
June
14,
2005

By
a
different
consent
decree,
MACT
standards
for
boilers
and
hydrochloric
acid
production
furnaces
are
­
11­

subject
to
that
same
completion
date
o
Phase
2
rulemaking
also
on
court­
enforceable
schedule
to
propose
by
March
31,
2004
SCOPE
OF
RULEMAKING

Emissions
Database
o
We
have
updated
the
emissions
database
that
was
used
to
support
the
1999
rule
for
incinerators,

cement
kilns,
and
lightweight
aggregate
kilns
o
Industry
stakeholders
believe
we
are
inappropriately
using
emissions
data
from
sources
that
tested
after
retrofitting
their
emission
control
systems
to
meet
the
emission
standards
promulgated
in
September
1999
(
which
were
vacated
and
replaced
by
the
February
2002
Interim
Standards).

­
Stakeholders
refer
to
this
as
"
MACT­
on­
MACT,"
i.
e.,
establishing
MACT
floors
based
on
sources
that
already
upgraded
to
meet
the
1999
standards.

­
We
believe
the
proposed
approach
to
use
all
available
emissions
data
from
existing
sources
to
calculate
MACT
floors
is
appropriate
because
the
motivation
for
a
source's
performance
is
legally
irrelevant
in
developing
the
floors.


Phase
1
Sources
(
cement
kilns,
lightweight
aggregate
kilns,
and
incinerators)
­
12­

o
Must
propose/
promulgate
emission
standards
reflecting
MACT
for
virtually
every
HAP
­
We
will
retain
the
carbon
monoxide,
hydrocarbon,
and
destruction
and
removal
efficiency
standards
promulgated
in
1999
­
­
We
do
not
need
to
propose
these
standards
again
because
they
were
not
challenged
o
Majority
of
compliance
requirements
promulgated
in
1999
will
not
be
addressed/
affected
by
this
rulemaking
since
they
were
not
vacated
by
the
court
o
We
are
addressing
a
total
of
17
compliance
requirements
in
the
proposal
­
Some
we
are
required
to
propose
and/
or
take
comment
on
as
a
result
of
the
settlement
agreement
­
Some
we
are
required
to
address
because
they
were
previously
litigated
issues
that
were
"
put
in
abeyance"

­
Others
are
fixes
and/
or
clarifications
­
These
compliance
issues
apply
to
both
phase
1
and
phase
2
sources

Phase
2
sources
(
boilers,
hydrochloric
acid
production
furnaces)

o
Must
propose/
promulgate
full
suite
of
emission
standards
and
compliance
provisions
­
13­

­
We
are
proposing
the
same
compliance
provisions
that
are
currently
required
for
the
phase
1
source
categories

Site
Specific
Risk
Assessment
(
SSRA)

o
In
February
2002,
the
Cement
Kiln
Recycling
Coalition
(
CKRC)
filed
a
petition
with
EPA
requesting
that
we
repeal
the
SSRA
Policy
and
Guidance
and
promulgate
them
as
regulations
if
we
continue
to
believe
that
they
are
necessary.

o
We
will
be
partially
granting
and
denying
CKRC's
request
­
We
are
proposing
to
deny
CKRC's
request
that
we
repeal
the
SSRA
policy
and
guidance
because
we
believe
that
there
may
be
situations
where
permitting
authorities
find
that
compliance
with
the
MACT
standards
alone
may
not
be
sufficiently
protective.
In
those
situations,
it
is
important
that
the
permitting
authority
retain
the
ability
to
use
a
tool
such
as
an
SSRA
to
estimate
potential
risk.

­
We
are
proposing
to
grant
CKRC's
request
by
codifying
our
explicit
authority
to
require
SSRAs
on
a
site­
specific
basis
using
notice
and
comment
rulemaking
procedures,
since
we
agree
with
CKRC
that
it
would
be
appropriate
to
codify
the
authority
to
require
SSRAs
and
SSRA­
based
permit
conditions
for
the
sake
of
regulatory
clarity
and
transparency.
We
are
requesting
comment
on
our
tentative
decision.

o
Site
Specific
Risk
Assessment
guidance
was
designated
for
review
as
part
of
OMB's
2002
Report
to
Congress
on
the
Costs
and
Benefits
of
Regulations
and
Unfunded
Mandates
on
State,
Local,
and
­
14­

Tribal
Entities
or
"
Thompson
Report",
based
on
comments
submitted
by
CKRC.
In
our
response
for
the
Thompson
Report,
we
stated
that
we
would
respond
to
CKRC's
petition
as
soon
as
possible,
but
no
later
than
the
proposal
of
the
Phase
I
and
Phase
II
rules.

DESCRIPTION
OF
FLOOR
METHODOLOGIES
USED
TO
ADDRESS
COURT
OPINION

Background
o
In
the
1999
rule,
the
Court
concluded
that
we
did
not
show
that
our
"
expanded
MACT
pool"
approach
to
account
for
emissions
variability
actually
reflected
the
worst
performance
of
the
best
performing
sources
o
What
are
we
doing
different
to
address
the
Court
opinion?

­
No
longer
using
the
expanded
MACT
pool
concept
to
address
emission
variability
­
Instead,
we
calculate
floor
levels
using
only
the
emissions
from
the
top
12%
of
the
sources
­
The
methodologies,
as
described
later,
define
how
the
top
12%
sources
are
chosen
o
How
are
we
addressing
emission
variability?

­
Most
importantly,
we
add
a
statistical
variability
factor
to
the
average
emissions
of
the
top
12%

of
sources
to
establish
a
floor
level
that
the
average
of
the
best
performing
sources
could
be
expected
to
achieve
in
99
of
100
tests
when
operating
under
the
same
conditions
under
which
­
15­

the
emissions
data
were
obtained
­
We
also
generally
base
the
floor
on
compliance
test
data
that
were
conducted
under
worst
foreseeable
operational
circumstances
(
e.
g.,
spiked
feeds
of
metals
and
chlorine,
detuned
emission
control
device);
or
absent
compliance
test
data,
we
base
the
floor
on
data
from
normal
operations,
and
express
the
standard
as
a
long
term
emission
limit
­
­
This
accounts
for
day­
to­
day,
month­
to­
month,
emissions
variability

Description
of
MACT
Approaches
Used
to
Calculate
Proposed
Floor
Levels
o
Two
generic
MACT
methodology
approaches:

­
1.
Emissions
Approach:
Best
performers
are
sources
with
lowest
stack
emission
concentrations
­
2.
SRE/
Feed
Approach:
For
metal
and
chlorine
standards,
best
performers
are
sources
with
the
best
combination
of
hazardous
waste
feed
control
of
metals/
chlorine
and
back­
end
(
stack)
air
pollution
control
as
defined
by
our
ranking
procedure
­
­
SRE
=
system
removal
efficiency
­­
the
%
metal/
chlorine
that
is
emitted
compared
to
the
amount
fed
­
­
Hazardous
waste
combustors
utilize
both
hazardous
waste
feed
control
and
back­
end
air
pollution
control
to
limit
their
emissions;
as
a
result,
both
are
components
of
MACT
control
for
these
pollutants

Special
Considerations
for
Energy
Recovery
Sources
­
16­

o
Energy
recovery
sources­­
cement
kilns,
lightweight
aggregate
kilns,
and
liquid
fuel
boilers
 
burn
hazardous
waste
fuels
at
various
firing
rates
to
displace
fossil
fuel
­­
from
5%
to
100%
hazardous
waste
fuel
o
Both
the
Emissions
Approach
and
SRE/
Feed
Approach
can
be
biased
against
sources
with
high
hazardous
waste
firing
rates
­
Their
emissions
and
feedrates
of
metals/
chlorine
can
be
higher
because
hazardous
waste
generally
has
higher
levels
of
metals/
chlorine
than
the
displaced
fossil
fuel.

o
To
avoid
this
potential
bias,
we
are
altering
the
form
of
the
standard
for
these
sources.
We
do
so
by
expressing
emission
limits
(
for
both
the
Emissions
Approach
and
SRE/
Feed
Approach)
as
"
hazardous
waste
thermal
emission
concentrations"
(
when
data
are
available
to
calculate
thermal
emissions),

which
represents
pounds
of
metal/
chlorine
in
emissions
attributable
to
the
hazardous
waste
per
million
BTU
of
heat
input
from
hazardous
waste

Special
Consideration
for
Particulate
Matter
Floors
o
We
are
proposing
particulate
matter
standards
to
control
HAP
metals
(
except
mercury)
that
originate
from
both
the
hazardous
waste
and
nonhazardous
feedstreams
(
e.
g.,
coal,
raw
material)

o
We
use
the
MACT
methodology
approach
the
Agency
used
in
the
proposed
Industrial
Boiler
MACT
to
identify
the
best
performing
sources
for
particulate
matter
­
17­

­
Industrial
Boiler
MACT
methodology
identifies
best
performers
as
those
with
the
best
back­
end
pollution
control
devices
­
methodology
does
not
directly
assess
feed
control
­
­
This
is
because
feed
control
of
fossil
fuels
is
neither
duplicable
(
by
a
single
source)
nor
replicable
(
by
other
sources).

o
We
do
not
believe
ash
feed
control
needs
to
be
directly
assessed
for
establishing
PM
floors
­
PM
standard
is
a
surrogate
to
control
metals
­
­
PM
(
ash)
feed
control
may
not
appropriately
assess
feed
control
of
metals
because
the
ash
can
contain
varying
levels
of
metals.


Proposed
MACT
Floor
Methodology
Hierarchy
o
SRE/
Feed
Approach
used
for
metals/
chlorine
when
data
allow
­
If
SRE/
Feed
Approach
cannot
be
used,
then
we
use
the
Emissions
Approach
­
­
Emissions
approach
is
not
the
preferred
approach
for
feed
controlled
pollutants
because
we
do
not
necessarily
believe
the
sources
with
the
lowest
emissions
in
fact
represent
the
best
performing
sources
o
Emissions
Approach
used
for
other
floors
(
e.
g.,
dioxin/
furan
floors)

o
Express
floors
as
hazardous
waste
thermal
emission
concentration
for
energy
recovery
units
when
data
allow
­
18­

o
Exception:

­
Industrial
Boiler
MACT
technology­
based
approach
used
for
PM
for
all
sources
categories

Special
Consideration
for
Total
Chlorine
Standards
(
invoking
Section
112(
d)(
4))

o
For
pollutants
for
which
a
health
threshold
has
been
established,
Section
112(
d)(
4)
allows
the
Administrator
to
consider
the
threshold
level
with
an
ample
margin
of
safety
when
establishing
emission
standards.
This
level
is
likely
to
be
less
restrictive
than
MACT.

o
We
will
propose
to
invoke
112(
d)(
4)
for
the
total
chlorine
standard
for
all
source
categories
except
hydrochloric
acid
production
furnaces
(
for
which
the
chlorine
standard
is
a
surrogate
to
control
metal
HAP)

­
EPA
has
invoked
this
authority
for
several
promulgated
and
proposed
MACT
rules
o
Note
that
we
have
not
provided
preamble
and
regulatory
language
for
invoking
112(
d)(
4).
We
have
inserted
a
"
placeholder",
however,
that
states
this
section
will
be
inserted
at
a
later
time.

­
The
Agency
is
determining
how
it
should
apply
112(
d)(
4)
in
the
future.
Issues
include:
Hazard
Index
limit;
accounting
for
emissions
of
HAP
from
collocated
sources
that
affect
the
target
organ;
accounting
for
ambient
background;
and
HCl
acidification
of
acid­
sensitive
surface
waters.
­
19­

PROPOSED
STANDARDS,
COSTS/
BENEFITS/
RISK
ASSESSMENT

Attachments
B
and
C
summarize
the
proposed
standards
for
new
and
existing
sources
for
each
source
category

Attachment
D
summarizes
the
proposed
beyond­
the­
floor
standards

Emission
reductions
for
all
source
categories
for
proposed
standards
(
note
that
emission
reductions
for
phase
1
sources
do
not
include
the
emission
reductions
that
are
necessary
for
compliance
with
the
interim
standards)

o
Dioxin/
furans:
5
grams/
year
o
Mercury:
1
ton/
year
o
Particulate
Matter:
1700
tons/
year
o
Semivolatile
Metals:
4
tons/
year
o
Low
Volatile
Metals:
10
tons/
year
o
Total
Chlorine
(
upper
bound,
no
sources
use
112d4
provision):
2600
tons/
year
o
Total
Chlorine
(
lower
bound,
all
eligible
sources
use
112d4
provision
and
do
not
upgrade
chlorine
control
device):
140
tons/
year

Retrofit
and
compliance
costs
for
proposed
standards
(
annualized
­
no
market
adjustments)

o
$
83
million/
year
(
upper
bound,
no
sources
use
112d4
provision)

o
$
58
million/
year
(
lower
bound,
all
eligible
sources
use
112d4
provision
and
do
not
upgrade
chlorine
control
device)

o
compliance
costs
for
phase
1
sources
do
not
include
costs
incurred
to
comply
with
interim
standards

Total
annualized
market­
adjusted
costs
­
20­

o
$
56
million/
year
(
upper
bound,
all
eligible
sources
use
112d4
provision
and
do
not
upgrade
chlorine
control
device)

o
$
41
million/
year
(
lower
bound,
no
sources
use
112d4
provision)

o
Phase
II
sources
represent
about
80
percent
of
the
upper
bound
market
adjusted
total.
Our
economic
model
indicates
that
commercial
incinerators
and
cement
kilns
would
experience
net
gains
following
all
market
adjustments.
This
occurs
due
to
increased
waste
receipts
and
relatively
low
upgrade
costs.

Total
annual
government
costs
are
approximately
$
500,000
­
600,000
for
the
proposed
standards.


Health
benefits
o
Total
annual
monetized
benefits
are
estimated
to
range
from
$
4.5
million
to
$
10.3
million
for
the
Agency's
proposed
approach,
attributable
primarily
to
particulate
matter
reductions.


Risk
Assessment
o
A
comprehensive
risk
assessment
is
not
being
conducted
for
this
rule;
however,
a
comprehensive
risk
assessment
for
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
was
conducted
for
the
1999
HWC
MACT
rule
in
order
to
show
that
national
RCRA
standards
were
no
longer
required
o
For
this
proposed
rule,
we
are
comparing
characteristics
of
the
sources
covered
by
the
1999
rule
to
the
sources
covered
by
the
replacement
rule
that
are
related
to
risk
o
These
characteristics
include
emissions,
stack
characteristics,
meteorology,
and
potentially
exposed
population
o
We
will
use
statistical
comparisons
to
support
the
conclusion
of
the
1999
risk
assessment
that
the
standards
are
sufficiently
protective
that
national
RCRA
standards
are
not
needed,
but
that
site­
­
21­

specific
standards
pursuant
to
RCRA
omnibus
provision
could
still
be
needed
o
Risk
inferences
for
boilers
and
HCl
production
furnaces
will
be
based
on
comparisons
with
incinerators
for
the
1999
rule
o
Note
we
are
currently
reevaluating
the
comparative
risk
analysis
methodology
originally
used
to
lend
additional
support
to
our
conclusion
that
these
proposed
technology­
based
standards
are
generally
protective.
This
preamble
section,
and
associated
background
document,
will
be
updated
in
the
near
future
if
in
fact
this
reevaluation
results
in
a
revised
methodology
to
assess
risks
from
these
sources.

We
are
confident
any
changes
to
this
comparative
risk
methodology
will
not
result
in
changes
to
our
original
conclusion
that
these
proposed
standards
are
generally
protective.

STAKEHOLDERS

Who
are
the
key
stakeholders?

o
Sierra
Club:
Represented
by
Earth
Justice
o
Cement
Kiln
Recycling
Coalition
(
CKRC):
Represents
cement
kilns
that
combust
hazardous
waste
o
American
Chemistry
Council
(
ACC):
Represents
subset
of
on­
site
incinerators,
boilers,
and
hydrochloric
acid
production
furnaces
at
chemical
and
petroleum
plants
o
Coalition
for
Responsible
Waste
Incineration
(
CRWI):
Represents
subset
of
incinerators,
boilers,

cement
kilns,
hydrochloric
acid
prod.
furnaces;
overlapping
membership
with
other
stakeholders
­
22­

o
Environmental
Treatment
Council
(
ETC):
Represents
subset
of
commercial
incinerators
o
Solite
Corporation:
Operates
two
of
the
three
lightweight
aggregate
kiln
facilities
­
23­

Attachment
B.
Proposed
Standards
for
Existing
Sources
Incinerators
Cement
Kilns
Lightweight
Aggregate
Kilns
Solid
Fuel­
Fired
Boilers1
Liquid
Fuel­
Fired
Boilers1
Hydrochloric
Acid
Production
Furnaces1
Dioxin/
Furans
(
ng
TEQ/
dscm)
0.28
for
dry
APCD
and
WHB
sources;
6
0.40
for
others
0.20
or
0.40
+

400

F
at
APCD
inlet
0.40
CO
or
THC
standard
as
a
surrogate
0.40
for
dry
APCDsources;

CO
or
THC
standard
as
surrogate
for
others
0.40
Mercury
130
ug/
dscm
64
ug/
dscm2
67
ug/
dscm2
10
ug/
dscm
3.7E­
6
lb/
MMBtu2,5
Total
chlorine
standard
as
surrogate
Particulate
Matter
0.015
gr/
dscf
8
0.028
gr/
dscf
0.025
gr/
dscf
0.030
gr/
dscf
8
0.032
gr/
dscf
8
Total
chlorine
standard
as
surrogate
Semivolatile
Metals
(
lead
+
cadmium)
59
ug/
dscm
4.0E­
4
lB/
MMBtu5
3.1E­
4
lb/
MMBtu5
and
250
ug/
dscm3
170
ug/
dscm
1.1E­
5
lb/
MMBtu2,5
Total
chlorine
standard
as
surrogate
Low
Volatile
Metals
(
arsenic
+
beryllium
+

chromium)
84
ug/
dscm
1.4E­
5
lbs/
MMBtu5
9.5E­
5
lb/
MMBtu5
and
110
ug/
dscm3
210
ug/
dscm
1.1E­
4
lbMMBtu4,5
Total
chlorine
standard
as
surrogate
Total
Chlorine
(
hydrogen
chloride
+
chlorine
gas)
1.5
ppmv
7
110
ppmv
7
150
ppmv
7
110
ppmv
7
2.5E­
2
lb/
MMBtu5,
7
14
ppmv
or
99.9927%

system
removal
efficiency
Carbon
Monoxide
(
CO)

or
Hydrocarbons
(
HC)
100
ppmv
CO
or
10
ppmv
HC
See
Part
Two,

Section
VIII
100
ppmv
CO
or
20
ppmv
HC
100
ppmv
CO
or
10
ppmv
HC
Destruction
and
Removal
Efficiency
(
DRE)
99.99%
for
each
principal
organic
hazardous
pollutant.
For
sources
burning
hazardous
wastes
F020,
F021,
F022,
F023,
F026,
or
F027,
however,
99.9999%
for
each
principal
organic
hazardous
pollutant.

Notes:

1
Particulate
matter,
semivolatile
metal,
low
volatile,
and
total
chlorine
standards
apply
to
major
sources
only
for
solid
fuel­
fired
boilers,
liquid
fuel­
fired
boilers,
and
hydrochloric
acid
production
furnaces.

2
Standard
is
based
on
normal
emissions
data.

3
Sources
must
comply
with
both
the
thermal
emissions
and
emission
concentration
standards.

4
Low
volatile
metal
standard
for
liquid
fuel­
fired
boilers
is
for
chromium
only.
Arsenic
and
beryllium
are
not
included
in
the
low
volatile
metal
total
for
liquid
fuel­
fired
boilers.

5
Standards
are
expressed
as
mass
of
pollutant
contributed
by
hazardous
waste
per
million
Btu
contributed
by
the
hazardous
waste.

6
APCD
denotes
"
air
pollution
control
device",
WHB
denotes
"
waste
heat
boiler".

7
Sources
may
elect
to
comply
with
site­
specific,
risk­
based
emission
limits
for
hydrogen
chloride
and
chlorine
gas
based
on
national
exposure
standards.
See
Part
Two,

Section
XIII.

8
Sources
may
elect
to
comply
with
an
alternative
to
the
particulate
matter
standard.
See
Part
Two,
Section
XVIII.
­
24­

Attachment
C.
Proposed
Standards
for
New
Sources
Incinerators
Cement
Kilns
Lightweight
Aggregate
Kilns
Solid
Fuel
Boilers
1
Liquid
Fuel
Boilers
1
Hydrochloric
Acid
Production
Furnaces1
Dioxin/
Furans
(
ng
TEQ/
dscm)
0.11
for
dry
APCD
or
WHBs5;

0.2
for
others
0.20
or
0.40
+
400

F
at
inlet
to
particulate
matter
control
device
0.40
Carbon
monoxide
(
CO)
or
hydrocarbon
(
HC)
as
a
surrogate
0.015
for
dry
APCD;

CO
or
HC
as
surrogate
for
others
0.40
Mercury
8
ug/
dscm
35
ug/
dscm2
67
ug/
dscm2
10
ug/
dscm
3.8E­
7
lb/
MMBtu2,4
TCl
as
surrogate
Particulate
matter
0.00070
gr/
dscf
7
0.0058
gr/
dscf
0.0099
gr/
dscf
0.015
gr/
dscf
7
0.0076
gr/
dscf
7
TCl
as
surrogate
Semivolatile
Metals
(
lead
+
cadmium)
6.5
ug/
dscm
6.2E­
5
lb/
MMBtu4
2.4E­
5
lb/
MMBtu4
170
ug/
dscm
4.3E­
6
lb/
MMBtu2,4
TCl
as
surrogate
Low
Volatile
Metals
(
arsenic
+
beryllium
+

chromium)
8.9
ug/
dscm
1.4E­
5
lb/
MMBtu4
3.2E­
5
lb/
MMBtu4
190
ug/
dscm
3.6E­
5
lb/
MMBtu
in
HW3,4
TCl
as
surrogate
Total
Chlorine
(
Hydrogen
chloride
+

chlorine
gas)
0.18
ppmv
6
78
ppmv
6
150
ppmv
6
73
ppmv
6
7.2E­
4
lb/
MMBtu4,6
1.2
ppmv
or
99.99937%
SRE
Carbon
monoxide
(
CO)

or
Hydrocarbons
(
HC)
100
ppmv
CO
or
10
ppmv
HC
See
Part
Two,

Section
VIII
100
ppmv
CO
or
20
ppmv
HC
100
ppmv
CO
or
10
ppmv
HC
Destruction
and
Removal
Efficiency
99.99%
for
each
principal
organic
hazardous
pollutant.
For
sources
burning
hazardous
wastes
F020,
F021,
F022,
F023,
F026,
or
F027,
however,
99.9999%
for
each
principal
organic
hazardous
pollutant.

Notes:

1
Particulate
matter,
semivolatile
metal,
low
volatile
metal,
and
total
chlorine
standards
apply
to
major
sources
only
for
solid
fuel­
fired
boilers,
liquid
fuelfired
boilers,
and
hydrochloric
acid
production
furnaces.

2
Standard
is
based
on
normal
emissions
data.

3
Low
volatile
metal
standard
for
liquid
fuel­
fired
boilers
is
for
chromium
only.
Arsenic
and
beryllium
are
not
included
in
the
low
volatile
metal
total
for
liquid
fuel­
fired
boilers.

4
Standards
are
expressed
as
mass
of
pollutant
contributed
by
hazardous
waste
per
million
Btu
contributed
by
the
hazardous
waste.

5
APCD
denotes
"
air
pollution
control
device",
WHB
denotes
"
waste
heat
boiler".

6
Sources
may
elect
to
comply
with
site­
specific,
risk­
based
emission
limits
for
hydrogen
chloride
and
chlorine
gas
based
on
national
exposure
standards.
See
Part
Two,
Section
XVIII
and
Section
XIII.

7
Sources
may
elect
to
comply
with
an
alternative
to
the
particulate
matter
standard.
See
Part
Two,
Section
XVIII.
­
25­

Attachment
D.
Proposed
Beyond­
the­
Floor
Standards
(
Existing
Sources)

Coal­
Fired
Boilers
Lightweight
Aggregate
Kilns
Liquid
Fuel
Boilers
HCl
Production
Furnaces
PM
TCl
TCl
D/
F
D/
F
D/
F
Floor
Level
0.06
gr/
dscf
440
ppm
600
ppm
6.4
ng
TEQ/
dscm
3.0
ng
TEQ/
dscm
6.8
ng
TEQ/
dscm
BTF
Standard
0.03
gr/
dscf
110
ppm
150
ppm
0.4
ng/
dscm
0.4
ng/
dscm
0.4
ng/
dscm
 
Emission
Reduction
400
ton/
yr
790
ton/
yr
280
ton/
yr
1.9
gram/
yr
0.06
gram/
yr
2.3
gram/
yr
 
Annualized
Cost,
before
Closures
($
MM)
1.5
3.7
1.9
2.2
0.08
1.9
Cost­
Effectiveness,
before
Closures
$
3,600/
ton
$
4,700/
ton
$
6,800/
ton
$
910,000/
gram
$
1,300,000/
gra
m
$
820,000/
gram
