­
1­
5/
07/
97
REVISED
INTERIM
WTI
METALS
LIMITS
REFLECTING
THE
DETAILED
RISK
ASSESSMENT
(
corrected
version)

A.
METHOD
OF
ESTABLISHING
LIMITS
The
risk
assessment
looked
at
two
different
routes
of
exposure:
direct
exposure
(
i.
e.,
inhalation),
and
indirect
exposure
(
i.
e.,
exposure
such
as
might
occur
through
food
chain
uptake).
Both
of
these
involve
the
study
of
long­
term
"
chronic"
effects,
but
indirect
exposure
tends
to
be
a
longer­
term
effect
than
direct
exposure.

Even
though
the
type
of
chronic
effects
evaluated
when
looking
at
direct
exposure
are
associated
with
long­
term
exposure
to
air
contaminants,
the
EPA
has
historically
protected
communities
from
direct
exposure
to
emissions
from
hazardous
waste
combustion
facilities
by
conservatively
setting
maximum
hourly
(
i.
e.,
relatively
short
term)
limits
on
the
emissions
of
the
toxic
and
carcinogenic
metals.
Part
of
the
reason
for
doing
this
is
to
help
ensure
that
there
will
be
no
short­
term,
or
"
acute,"
effects
from
fluctuations
in
the
normal
emissions.

Indirect
exposure
routes,
on
the
other
hand,
are
generally
associated
with
the
slow
buildup
of
contaminants
in
the
soil
and
plants.
Because
of
this,
it
is
quite
possible
that
a
particular
hourly
emission
rate
might
be
quite
safe
from
the
standpoint
of
direct­
route
exposure,
but
that
continuous
emission
at
this
same
rate
over
several
years
might
eventually
create
an
unacceptable
indirect­
route
exposure.
Because
of
this,
both
hourly
and
annual
limits
might
be
appropriate
in
some
cases.
In
this
exercise,
hourly
limits
will
be
established,
and
the
need
for
annual
limits
will
be
evaluated
for
each
metal.

In
this
exercise,
hourly
limits
will
be
calculated
as
prescribed
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
most
appropriate
reference
air
concentrations
("
RACs")
and
risk­
specific
doses
("
RSDs").
Potential
annual
limits
will
also
be
calculated.
In
most
cases,
this
will
be
done
by
taking
the
annual
emissions
assumed
in
the
"
Maximum
Permit
Limit
Emission"
scenarios
of
the
risk
assessment,
and
reducing
those
annual
values
linearly
as
necessary
to
bring
the
resulting
hazard
index
("
HI")
down
to
1.0
for
ecological
effects
and
0.25
for
human
health
effects.
For
example,
if
a
maximum
emission
of
a
particular
metal
was
hypothetically
assumed
to
be
1000
lbs/
yr,
and
the
resulting
human
health
HI
from
that
emission
was
found
to
be
0.75,
this
exercise
would
conclude
that
the
annual
emission
would
need
to
be
reduced
by
a
factor
of
3,
resulting
in
an
annual
emission
limit
of
333
lbs.
­
2­
Table
1
summarizes
the
HI
values
calculated
in
the
WTI
risk
assessment
for
the
"
Maximum
Permit
Limit
Emission"
scenarios,
and
the
suggested
annual
reduction
factors.
Table
2
summarizes
various
emission
data
and
converts
these
suggested
annual
reduction
factors
into
suggested
annual
emission
limits.

The
HI
values
shown
in
Table
1
represent
the
total
HI
from
both
the
direct
routes
and
indirect
routes
of
exposure,
excerpted
from
the
WTI
risk
assessment.
The
HI
information
in
the
risk
assessment
was
not
presented
in
such
a
way
as
to
specify
what
fraction
of
the
total
HI
value
was
a
result
of
direct
routes
and
what
fraction
was
a
result
of
indirect
routes,
we
have
concluded
that
restricting
emission
per
the
technique
contained
in
the
BIF
Rule
(
but
using
the
more
conservative
RACs
used
the
risk
assessment)
should
properly
address
inhalation
exposure
(
because
the
BIF
Rule
calculations
are
essentially
a
direct
inhalation
route
risk
assessment),
and
that
restricting
annual
emissions
(
where
warranted)
based
on
total
HI
as
described
above
should
ensure
that
indirect
routes
are
also
properly
addressed.

Because
the
BIF
Rule
prescribes
that
metals
feed
rates,
as
opposed
to
emission
rates,
be
set
in
RCRA
permits,
it
is
anticipated
that
the
following
analysis
will
largely
be
used
to
establish
feed
limits.
However,
the
emission
limit
information
can
be
used
for
setting
emission
limits
should
continuous
in­
stack
monitoring
be
judged
appropriate
for
verifying
compliance.
At
the
time
of
this
writing,
WTI
has
applied
for
a
permit
modification
to
install
and
operate
a
continuous
emission
monitor
which
would
capture
a
sample
stream
of
combustion
gas
from
the
stack
and
automatically
analyze
the
stream
for
all
regulated
metals
via
ICP.

In
this
exercise,
emissions
and
feed
rates
are
routinely
given
both
in
units
of
pounds
per
hour
("
lbs/
hr")
and
grams
per
second
("
g/
sec").
However,
because
the
BIF
Rule
of
40
CFR
266.106
prescribes
that
metals
feed
limits
should
normally
be
established
on
a
60­
minute
rolling
average
basis
or
equivalent,
it
should
be
noted
that
any
values
given
in
g/
sec
should
actually
be
implemented
as
a
lb/
hr
value
on
a
60­
minute
rolling
average
basis
(
or
similar
as
deemed
appropriate)
and
not
on
a
minute­
by­
minute
or
second­
by­
second
basis.

B.
ESTIMATION
OF
SYSTEM
REMOVAL
EFFICIENCIES
("
SREs")
FOR
METALS:

The
following
is
the
approach
that
Region
5
and
the
Ohio
EPA
have
developed
regarding
the
setting
certain
INTERIM
metals
feed
limits
for
WTI,
should
the
State
of
Ohio
decide
to
renew
the
RCRA
permit.

1.
When
evaluating
the
impacts
of
metals
emissions,
the
WTI
risk
assessment
evaluated
two
different
metals
emission
scenarios:
(
1)
estimated
actual
emissions,
aThe
thermodynamic
modeling
was
also
used
to
evaluate
whether
SREs
might
be
predicted
to
diminish
at
the
significantly
lower
feed
rates
assumed
in
the
"
estimated
actual
emissions"
scenario.
EPA
felt
this
was
an
important
issue
in
light
of
the
common
finding
that
SREs
are
frequently
lower
at
lower
metal
feed
rates
This
investigation
concluded
that
within
the
ranges
of
feed
rates
evaluated,
no
significant
decreases
in
SRE
were
predicted.

bIt
should
be
noted
that,
in
this
exercise
and
in
the
risk
assessment,
the
BIF
allowable
was
calculated
using
a
new,
lower,
dispersion
factor
(
DF)
developed
as
part
of
the
risk
assessment.
Because
this
new
DF
is
lower
than
the
one
used
to
set
the
present
permit
limits,
the
risk
assessment
actually
assumed
higher­
than­
present
emission
limits.

­
3­
and
(
2)
full
maximum
permit
limit
emissions
(
for
8760
hours
of
operation
per
year).
The
first
emission
scenario
used
estimates
of
actual
emissions,
considering
the
profiles
and
projected
quantities
of
wastes
expected
to
be
received
at
WTI,
along
with
measured
SREs
(
for
metals
tested
during
the
trial
burn)
and
estimated
SREs
(
for
metals
not
tested
during
the
trial
burn).
The
estimated
SREs
were
conservatively
developed
based
on
detailed
thermodynamic
modelinga
of
the
combustion
train,
and
included
comparisons
of
SRE
predictions
to
the
known
SREs
from
the
trial
burn.
In
this
way,
SREs
were
estimated
for
barium,
silver,
thallium,
nickel,
and
selenium.
Details
of
the
modeling
are
contained
in
Volume
III
of
the
WTI
risk
assessment.

The
second
emission
scenario,
maximum
permit
limit
emissions,
was
evaluated
in
order
to
determine
whether
additional
permit
conditions
might
be
appropriate.
It
is
not
expected
that
WTI
would
ever
emit
at
these
rates.
This
exercise
assumed
that
all
"
adjusted
tier
1"
metals
were
emitted
at
full
BIF
allowableb,
and
that
all
"
tier
3"
metals
were
emitted
at
the
emission
rates
actually
recorded
during
the
trial
burn
(
i.
e.,
the
high­
temperature
metals
runs).
Again,
this
maximum
permit
limit
scenario
projected
these
emissions
out
to
8760
hours
per
year
operation.

It
was
understood
from
the
beginning
that
using
this
technique
would
project
artificially
high
hazard
indices
and/
or
risks
when
plugged
into
the
risk
assessment,
but
it
was
decided
that
it
was
more
appropriate
to
generate
these
high
HI
values
and
then
adjust
emission
limits
downward
rather
than
using
the
alternate
technique
of
calculating
more
realistic
emissions
and
hazard
indices,
and
then
setting
emission
limits
by
adjusting
these
upward.

2.
For
the
permit
limit
emissions
scenario,
the
risk
assessment
has
demonstrated
that
the
artificially
high
"
adjusted
tier
1"
emission
rates
for
Ba,
Ag,
Tl,
Ni,
and
Se,
because
they
assume
absolutely
no
SRE,
would
result
in
projected
impacts
where
hazard
indices
could
range
as
high
as
4250
(
See
Table
1).
Although
these
are
not
real
emissions,
Region
5
and
Ohio
EPA
presently
believe
it
is
appropriate
to
use
cLimits
being
considered
would
be
set
depending
on
whether
the
HI
exceedance
is
due
to
direct,
indirect,
or
ecological
exposure.
A
high
HI
associated
with
a
direct
exposure
would
result
in
reduced
hourly
emission
rates,
and
a
high
HI
associated
with
an
indirect
or
ecological
effect
would
result
in
annual
limits
being
imposed
in
addition
to
hourly
limit
(
e.
g.,
"
Emissions
shall
be
restricted
to
no
more
than
2
lb/
hr
and
no
more
than
500
lb/
yr").
Rather
that
generating
separate
HI
values
for
direct
and
indirect
routes,
direct
routes
will
be
addressed
in
this
exercise
via
"
BIF
Rule
calculations"
and
indirect
routes
will
be
addressed
by
using
the
"
total"
HI
values
given
in
the
risk
assessment.

­
4­
this
information
to
calculate
emission/
feedc
restrictions
such
that
no
metal
emission
would
result
in
a
HI
greater
than
0.25
for
human
health
effects,
or
1.0
for
ecological
effects,
per
USEPA
guidelines.
Because
there
has
been
no
trial
burn
to
establish
SREs
for
these
metals,
a
typical
approach
would
be
to
simply
assume
that
all
Ba,
Ag,
Tl,
Ni,
and
Se
fed
to
the
incinerator
will
be
emitted
out
the
stack.
However,
such
an
approach
would
require
that
extremely
low
feed
limits
be
imposed
in
this
case.

3.
Because
of
the
extensive
thermodynamic
modeling
conducted
in
this
case,
Region
5
and
Ohio
developed
the
following
interim
approach
to
be
used
in
the
permits
until
a
new
metals
trial
burn
can
be
conducted
(
perhaps
1
year)
to
establish
actual
SREs
for
Ba,
Ag,
Tl,
Se,
and
Ni,
at
appropriate
feed
rates:

a.
For
Ba,
Ag,
Ni,
and
Tl,
apply
a
safety
factor
of
10
to
the
conservative
SREs
developed
via
thermodynamic
modeling
in
the
WTI
risk
assessment
for
these
four
metals.
Thus,
a
safety
factor
of
10
would
be
applied
to
the
SRE
of
99.977%
estimated
for
these
metals
in
the
risk
assessment,
resulting
in
a
very
conservative
interim
SRE
of
99.77%.
Note
that
the
risk
assessment
SRE
value
was
largely
based
on
the
measured
SRE
for
arsenic
(
the
lowest
demonstrated
SRE
for
any
metal
in
its
category,
and
one
of
the
lowest
feed­
rate
metals
during
the
trial
burn)
after
mechanistic
comparisons
to
Ba,
Ag,
Ni,
and
Tl.

Additional
information
relative
to
this
issue
was
collected
during
a
1996
performance
test.
Nickel
SREs
were
evaluated
during
three
of
the
four
runs.
SREs
demonstrated
during
two
runs,
with
nickel
feed
rates
of
3.3
and
14.8
lbs/
hr,
were
99.96
%
and
99.997
%,
respectively.
These
feed
rates
are
considered
to
be
typical.
During
a
third
test
run,
feed
rates
were
reduced
4
orders
of
magnitude
to
.003
lb/
hr,
and
the
SRE
fell,
as
would
be
expected.
During
this
low
feed
run,
the
SRE
was
approximately
72
%.

b.
For
Se,
the
SRE
predicted
by
the
thermodynamic
modeling
was
99.7%,
based
on
comparison
to
SO2
(
determined
in
the
modeling
to
be
a
good
surrogate
for
Se
because
it
is
a
similarly
volatile
compound
which
forms
a
­
5­
water­
soluble
vapor).
However,
the
peer
review
pointed
out
a
potential
weakness
in
using
SO2
as
a
surrogate
for
selenium,
and
we
recognize
that
subsequent
stack
testing
for
selenium
would
help
validate
this
estimate.

Stack
testing
for
Se
was
later
conducted
during
the
four­
run
1996
performance
test,
and
that
testing
demonstrated
the
following:

SRE
=
99.5
%
@
26.6
lb/
hr
Se
feed
SRE
=
99.994
%
@
0.32
lb/
hr
Se
feed
SRE
=
99.9998
%
@
21.3
lb/
hr
Se
feed
SRE
=
99.5
%
@
31.6
lb/
hr
Se
feed
Although
there
was
a
lot
of
variation
in
the
results,
the
results
do
seem
to
validate
the
assumption
used
in
the
risk
assessment.
The
average
of
these
four
runs
was
99.75,
which
tends
to
match
the
model
results.
Even
though
this
testing
was
not
an
official
trial
burn,
we
believe
this
combined
data
can
be
used
on
an
interim
basis
until
a
subsequent
selenium
trial
burn
can
be
conducted.
The
suggested
interim
SRE
for
selenium
would
be
99.7
%.

c.
At
the
present
time,
mercury
will
continue
to
be
handled
as
an
"
adjusted
tier
1"
metal,
i.
e.,
it
will
be
assumed
that
there
is
no
SRE.
This
is
discussed
further
below.

C.
CALCULATION
OF
LIMITS
FOR
INDIVIDUAL
METALS:

Barium:

For
each
metal,
limiting
values
should
be
evaluated
for
(
1)
maximum
hourly
emissions,
(
2)
maximum
hourly
metal
feed,
(
3)
maximum
annual
emissions,
and
(
4)
maximum
annual
metal
feed.
In
most
cases,
only
the
maximum
hourly
metals
feed
limit
will
need
to
be
set
in
the
permit.
Annual
limits
might
be
necessary
in
some
cases
if
the
risk
assessment
predicted
greater
problems
with
indirect
exposure
than
with
direct
exposure.

1)
Maximum
Hourly
Emissions
of
Barium:

This
is
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
air
concentration
("
RAC").
This
approach
considers
direct
exposure
risks.
Although
the
BIF
Rule
prescribes
an
RAC
for
Barium
of
50
µ
g/
m3,
the
USEPA
risk
assessment
concluded
that
a
better
RAC
value
based
on
more
recent
data
would
be
0.13
µ
g/
m3.
A
summary
chart
comparing
the
RACs
and
risk
specific
doses
("
RSDs")
of
the
BIF
Rule
to
the
RACs
and
RSDs
used
in
the
risk
assessment
is
attached
as
Table
3.
dSee
USEPA
Risk
Assessment
Volume
I,
Chapter
IV,
Table
IV­
3.

ePenetration
is
defined
as
(
1
­
removal
efficiency).
In
this
case,
the
penetration
would
be
calculated
as
(
1
­
0.9977)
=
.0023.

­
6­
The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
secd.
From
this
and
the
above,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

(
Max
Emission
Rate)
=
(
RAC)
/
(
DF)

Max
Emission
Rate
=
(
0.13
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
0.143
g/
sec
(=
1.13
lb/
hr)

2)
Maximum
Hourly
Feed
Rate
of
Barium:

Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
would
conservatively
be
expected
to
result
in
an
emission
of
0.143
g/
sec
or
less
can
be
estimated
as
described
earlier.
From
the
analysis
contained
in
Section
B
of
this
document,
the
interim
SRE
estimated
for
Barium
would
be
99.77%,
which
is
the
same
as
a
penetratione
of
.0023.
Per
the
BIF
Rule,
feed
rates
are
generally
to
be
calculated
and
implemented
as
hourly
rolling
averages.
Feed
rate
would
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
0.143
g/
sec)
/
(.
0023)

=
62.2
g/
sec
(=
473
lb/
hr)
­
7­
3)
Annual
Maximum
Emission
Rate
of
Barium
In
addition
to
hourly
maximum
metal
emission/
feed
limits,
annual
emission
limits
might
be
warranted.
From
attached
Table
2,
the
maximum
annual
emission
rate
has
been
calculated
as:

Suggested
Annual
Emission
Limit
=
(
Max
Permit
Limit
Emission)
/
(
Suggested
Reduction)

Suggested
Annual
Emission
Limit
=
682
lbs/
yr
4)
Interim
Annual
Maximum
Feed
Rate
of
Barium
Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
results
in
an
emission
of
682
lbs/
yr
or
less
can
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
682
lbs/
yr
)
/
(.
0023)

=
296,000
lbs/
yr
Mercury:

For
each
metal,
limiting
values
should
be
evaluated
for
(
1)
maximum
hourly
emissions,
(
2)
maximum
hourly
metal
feed,
(
3)
maximum
annual
emissions,
and
(
4)
maximum
annual
metal
feed.

1)
Maximum
Hourly
Emissions
of
Mercury:

This
is
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
air
concentration
("
RAC").
This
approach
considers
direct
exposure
risks.
Although
the
BIF
Rule
prescribes
an
RAC
for
Mercury
of
.08
µ
g/
m3,
the
USEPA
risk
assessment
concluded
that
a
better
value
based
on
more
recent
data
would
be
.075
µ
g/
m3.
­
8­
The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
these,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

(
Max
Emission
Rate)
=
(
RAC)
/
(
DF)

Max
Emission
Rate
=
(
0.075
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
.0824
g/
sec
(=
0.65
lb/
hr)

2)
Maximum
Hourly
Feed
Rate
of
Mercury:

During
the
1993
trial
burn,
WTI
demonstrated
virtually
no
SRE
for
mercury.
More
recent
test
data
has
demonstrated
that
WTI
can
achieve
a
mercury
SRE
of
approximately
95%.
However,
at
the
time
of
this
writing,
the
U.
S.
EPA
and
the
Ohio
EPA
have
not
made
a
final
decision
as
to
whether
the
quantity
and
quality
of
new
test
data
is
sufficient
to
allow
WTI
to
use
this
new
demonstrated
SRE
value.
Therefore,
the
very
conservative
assumption
is
made
in
this
analysis
that
all
mercury
fed
to
the
incinerator
is
emitted
out
the
stack.
If
and
when
subsequent
data
is
judged
sufficient
to
allow
a
higher
SRE
in
these
calculations,
the
U.
S.
EPA
and/
or
Ohio
EPA
will
make
the
appropriate
changes
in
the
feed
limits.

Maximum
Feed
Rate
=
Maximum
Emission
Rate
=
.0824
g/
sec
(
=
0.65
lb/
hr)

3)
Annual
Maximum
Emission
Rate
of
Mercury
In
addition
to
hourly
maximum
metal
emission/
feed
limits,
annual
emission
limits
might
be
warranted.
From
attached
Table
2,
the
maximum
annual
emission
rate
has
been
calculated
as:

Suggested
Annual
Emission
Limit
=
(
Max
Permit
Limit
Emission)
/
(
Suggested
Reduction)

Suggested
Annual
Emission
Limit
=
355
lbs/
yr
­
9­
4)
Interim
Annual
Maximum
Feed
Rate
of
Mercury:

Because
a
new
mercury
SRE
has
not
been
approved
as
of
this
writing,
the
very
conservative
assumption
is
made
here
that
all
mercury
fed
to
the
incinerator
is
emitted
out
the
stack.

Maximum
Annual
Feed
Rate
=
Maximum
Annual
Emission
Rate
=
355
lbs/
yr
Silver:

For
each
metal,
limiting
values
should
be
evaluated
for
(
1)
maximum
hourly
emissions,
(
2)
maximum
hourly
metal
feed,
(
3)
maximum
annual
emissions,
and
(
4)
maximum
annual
metal
feed.

1)
Maximum
Hourly
Emissions
of
Silver:

This
is
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
air
concentration
("
RAC").
This
approach
considers
direct
exposure
risks.
The
BIF
Rule
prescribes
an
RAC
for
silver
of
3
µ
g/
m3
(
note
that
the
USEPA
risk
assessment
used
a
more
current
RAC
value
of
4.4
µ
g/
m3
based
on
more
recent
data,
but
for
the
purposes
of
this
analysis,
the
more
conservative
BIF
value
will
be
used).
A
summary
chart
comparing
the
RACs
and
risk
specific
doses
("
RSDs")
of
the
BIF
Rule
to
the
RACs
and
RSDs
used
in
the
risk
assessment
is
attached
as
Table
3.

The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
this
and
the
above,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

(
Max
Emission
Rate)
=
(
RAC)
/
(
DF)

Max
Emission
Rate
=
(
3.0
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
3.3
g/
sec
(
=
26
lb/
hr)
­
10­
2)
Maximum
Hourly
Feed
Rate
of
Silver:

Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
would
conservatively
be
expected
to
result
in
an
emission
of
3.3
g/
sec
or
less
can
be
estimated
as
described
earlier.
From
the
analysis
contained
in
Section
B
of
this
document,
the
interim
SRE
estimated
for
silver
would
be
99.77%,
which
is
the
same
as
a
penetration
of
.0023.
Per
the
BIF
Rule,
feed
rates
are
generally
to
be
calculated
and
implemented
as
hourly
rolling
averages.
Feed
rate
would
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
3.3
g/
sec)
/
(.
0023)

=
1435
g/
sec
(
=
11,370
lb/
hr)

3)
Annual
Maximum
Emission
Rate
of
Silver
In
addition
to
hourly
maximum
metal
emission/
feed
limits,
annual
emission
limits
might
be
warranted.
From
attached
Table
2,
the
maximum
annual
emission
rate
has
been
calculated
as:

Suggested
Annual
Emission
Limit
=
(
Max
Permit
Limit
Emission)
/
(
Suggested
Reduction)

Suggested
Annual
Emission
Limit
=
954
lbs/
yr
4)
Interim
Annual
Maximum
Feed
Rate
of
Silver
Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
results
in
an
emission
of
954
lbs/
yr
or
less
can
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)
­
11­
Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
954
lbs/
yr
)
/
(.
0023)

=
415,000
lbs/
yr
Thallium:

For
each
metal,
limiting
values
should
be
evaluated
for
(
1)
maximum
hourly
emissions,
(
2)
maximum
hourly
metal
feed,
(
3)
maximum
annual
emissions,
and
(
4)
maximum
annual
metal
feed.

1)
Maximum
Hourly
Emissions
of
Thallium:

This
is
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
air
concentration
("
RAC").
This
approach
considers
direct
exposure
risks.
Although
the
BIF
Rule
prescribes
an
RAC
for
thallium
of
0.50
µ
g/
m3,
the
USEPA
risk
assessment
concluded
that
a
better
RAC
value
based
on
more
recent
data
would
be
0.061
µ
g/
m3.
A
summary
chart
comparing
the
RACs
and
risk
specific
doses
("
RSDs")
of
the
BIF
Rule
to
the
RACs
and
RSDs
used
in
the
risk
assessment
is
attached
as
Table
3.

The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
this
and
the
above,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

(
Max
Emission
Rate)
=
(
RAC)
/
(
DF)

Max
Emission
Rate
=
(
0.061
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
.067
g/
sec
(=
0.53
lb/
hr)
­
12­
2)
Maximum
Hourly
Feed
Rate
of
Thallium:

Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
would
conservatively
be
expected
to
result
in
an
emission
of
.067
g/
sec
or
less
can
be
estimated
as
described
earlier.
From
the
analysis
contained
in
Section
B
of
this
document,
the
interim
SRE
estimated
for
thallium
would
be
99.77%,
which
is
the
same
as
a
penetration
of
.0023.
Per
the
BIF
Rule,
feed
rates
are
generally
to
be
calculated
and
implemented
as
hourly
rolling
averages.
Feed
rate
would
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(.
067
g/
sec)
/
(.
0023)

=
29.1
g/
sec
(=
231
lb/
hr)

3)
Annual
Maximum
Emission
Rate
of
Thallium:

In
addition
to
hourly
maximum
metal
emission/
feed
limits,
annual
emission
limits
might
be
warranted.
From
attached
Table
2,
the
maximum
annual
emission
rate
has
been
calculated
as:

Suggested
Annual
Emission
Limit
=
(
Max
Permit
Limit
Emission)
/
(
Suggested
Reduction)

Suggested
Annual
Emission
Limit
=
6.6
lbs/
yr
4)
Interim
Annual
Maximum
Feed
Rate
of
Thallium:

Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
results
in
an
emission
of
6.6
lbs/
yr
or
less
can
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)
­
13­
Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
6.6
lbs/
yr
)
/
(.
0023)

=
2870
lbs/
yr
Nickel:

For
each
metal,
limiting
values
should
be
evaluated
for
(
1)
maximum
hourly
emissions,
(
2)
maximum
hourly
metal
feed,
(
3)
maximum
annual
emissions,
and
(
4)
maximum
annual
metal
feed.

1)
Maximum
Hourly
Emissions
of
Nickel:

This
is
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
air
concentration
("
RAC").
This
approach
considers
direct
exposure
risks.
Although
the
BIF
Rule
prescribes
an
RAC
for
nickel
of
20
µ
g/
m3,
the
USEPA
risk
assessment
concluded
that
a
better
RAC
value
based
on
more
recent
data
would
be
18
µ
g/
m3.

The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
this
and
the
above,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

(
Max
Emission
Rate)
=
(
RAC)
/
(
DF)

Max
Emission
Rate
=
(
18
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
19.8
g/
sec
(=
156
lb/
hr)
­
14­
2)
Maximum
Hourly
Feed
Rate
of
Nickel:

Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
would
conservatively
be
expected
to
result
in
an
emission
of
19.8
g/
sec
or
less
can
be
estimated
as
described
earlier.
From
the
analysis
contained
in
Section
B
of
this
document,
the
interim
SRE
estimated
for
nickel
would
be
99.77%,
which
is
the
same
as
a
penetration
of
.0023.
Per
the
BIF
Rule,
feed
rates
are
generally
to
be
calculated
and
implemented
as
hourly
rolling
averages.
Feed
rate
would
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
19.8
g/
sec)
/
(.
0023)

=
8610
g/
sec
(
=
68,260
lb/
hr)

3)
Annual
Maximum
Emission
Rate
of
Nickel:

In
addition
to
hourly
maximum
metal
emission/
feed
limits,
annual
emission
limits
might
be
warranted.
From
attached
Table
2,
the
maximum
annual
emission
rate
has
been
calculated
as:

Suggested
Annual
Emission
Limit
=
(
Max
Permit
Limit
Emission)
/
(
Suggested
Reduction)

Suggested
Annual
Emission
Limit
=
4170
lbs/
yr
4)
Interim
Annual
Maximum
Feed
Rate
of
Nickel:

Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
results
in
an
emission
of
4170
lbs/
yr
or
less
can
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)
­
15­
Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
4170
lbs/
yr
)
/
(.
0023)

=
1.8
E+
6
lbs/
yr
Selenium:

For
each
metal,
limiting
values
should
be
evaluated
for
(
1)
maximum
hourly
emissions,
(
2)
maximum
hourly
metal
feed,
(
3)
maximum
annual
emissions,
and
(
4)
maximum
annual
metal
feed.

1)
Maximum
Hourly
Emissions
of
Selenium:

This
is
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
air
concentration
("
RAC").
This
approach
considers
direct
exposure
risks.
The
BIF
Rule
prescribes
an
RAC
for
selenium
of
4.0
µ
g/
m3
(
note
that
the
USEPA
risk
assessment
used
a
more
current
RAC
value
of
4.4
µ
g/
m3
based
on
more
recent
data,
but
for
the
purposes
of
this
analysis,
the
more
conservative
BIF
value
will
be
used).

The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
this
and
the
above,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

(
Max
Emission
Rate)
=
(
RAC)
/
(
DF)

Max
Emission
Rate
=
(
4.0
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
4.4
g/
sec
(=
34.9
lb/
hr)
­
16­
2)
Maximum
Hourly
Feed
Rate
of
Selenium:

Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
would
conservatively
be
expected
to
result
in
an
emission
of
4.4
g/
sec
or
less
can
be
estimated
as
described
earlier.
From
the
analysis
contained
in
Section
B
of
this
document,
the
interim
SRE
estimated
for
selenium
would
be
99.7%,
which
is
the
same
as
a
penetration
of
.003.
Per
the
BIF
Rule,
feed
rates
are
generally
to
be
calculated
and
implemented
as
hourly
rolling
averages.
Feed
rate
would
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
4.4
g/
sec)
/
(.
005)

=
1467
g/
sec
(
=
11,630
lb/
hr)

3)
Annual
Maximum
Emission
Rate
of
Selenium:

In
addition
to
hourly
maximum
metal
emission/
feed
limits,
annual
emission
limits
might
be
warranted.
From
attached
Table
2,
the
maximum
annual
emission
rate
has
been
calculated
as:

Suggested
Annual
Emission
Limit
=
(
Max
Permit
Limit
Emission)
/
(
Suggested
Reduction)

Suggested
Annual
Emission
Limit
=
102
lbs/
yr
4)
Interim
Annual
Maximum
Feed
Rate
of
Selenium:

Until
further
testing
can
be
performed
to
precisely
establish
the
system
removal
efficiency
for
this
metal,
an
interim
feed
rate
which
results
in
an
emission
of
102
lbs/
yr
or
less
can
be
calculated
as
follows:

(
Feed
Rate)
X
(
Penetration)
=
(
Emission
Rate)

(
Feed
Rate)
=
(
Emission
Rate)
/
(
Penetration)
­
17­
Maximum
Feed
Rate
=
(
Maximum
Emission
Rate)
/
(
Penetration)

Maximum
Feed
Rate
=
(
102
lbs/
yr
)
/
(.
003)

=
3.4
E+
4
lbs/
yr
Antimony:

For
each
metal,
limiting
values
should
be
evaluated
for
(
1)
maximum
hourly
emissions,
(
2)
maximum
hourly
metal
feed,
(
3)
maximum
annual
emissions,
and
(
4)
maximum
annual
metal
feed.

1)
Maximum
Hourly
Emissions
of
Antimony:

This
is
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
air
concentration
("
RAC").
This
approach
considers
direct
exposure
risks.
The
BIF
Rule
prescribes
an
RAC
for
antimony
of
0.30
µ
g/
m3
(
note
that
the
USEPA
risk
assessment
used
a
more
current
RAC
value
of
.35
µ
g/
m3
based
on
more
recent
data,
but
for
the
purposes
of
this
analysis,
the
more
conservative
BIF
value
of
0.30
µ
g/
m3
will
be
used).

The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
this
and
the
above,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

(
Max
Emission
Rate)
=
(
RAC)
/
(
DF)

Max
Emission
Rate
=
(
0.30
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
0.33
g/
sec
(
=
2.6
lb/
hr)
fTable
2
of
Attachment
VII­
1
to
Volume
VIII
of
the
risk
assessment
indicates
that
the
trial
burn
emission
rate
for
antimony,
if
projected
out
to
8760
hours
of
operation
per
year,
would
only
result
in
a
predicted
HI
of
.0016
at
the
point
of
maximum
concentration.
Therefore,
it
appears
that
this
emission
limit
could
be
increased
by
several
orders
of
magnitude
without
having
a
significant
risk
impact.
This
issue
is
still
being
considered.

­
18­
2)
Maximum
Hourly
Feed
Rate
of
Antimony:

Until
new
trial
burn
testing
indicates
that
a
different
feed
rate
is
appropriate,
the
feed
rate
recorded
during
the
trial
burn
(
which
resulted
in
an
antimony
emission
of
1.6
E­
4
g/
sec,
or
1.27
E­
3
lb/
hr)
should
remain
as
the
regulatory
feed
rate
limit.

Feed
Rate
Limit
=
1.18
g/
sec
(
=
9.4
lbs/
hr)

3)
Annual
Maximum
Emission
Rate
of
Antimony:

In
addition
to
the
hourly
maximum
metal
emission/
feed
limit,
an
annual
emission
limit
might
be
warranted.
From
attached
Table
2,
no
maximum
annual
emission
rate
was
found
to
be
necessary
for
antimony.
However,
this
was
based
on
a
trial
burn
emission
rate
of
1.6
E­
4
g/
sec
projected
to
8760
hours/
year
operation.
Therefore,
the
risk
assessment
at
this
time
only
shows
that
this
specific
annual
emission
rate
would
be
protectivef.
This
value
can
be
used
as
an
annual
emission
limit
(
although
further
risk
assessment
calculation
might
demonstrate
that
higher
values
are
also
fully
protective).

Annual
Emission
Limit
=
(
Trial
Burn
Emission
Rate)
X
(
8760
hours/
yr)

Annual
Emission
Limit
=
(
1.6
E­
4
g/
sec)
X
(
3600
sec/
hr)
X
(
8760
hrs/
yr)

Annual
Emission
Limit
=
5046
g/
yr
(
=
11.1
lb/
yr)
­
19­
4)
Interim
Annual
Maximum
Feed
Rate
of
Antimony:

At
this
time,
there
is
no
information
indicating
that
an
annual
restriction
on
antimony
feed
rate
would
be
needed
in
addition
to
the
hourly
value
given
above.

Annual
Feed
Limit
=
(
9.4
lb/
hr)
X
8760
hrs/
yr
=
82,300
lbs/
yr
Arsenic:

1)
Maximum
Hourly
Emissions
of
Arsenic:

For
a
carcinogen
such
as
arsenic,
the
emission
rate
would
normally
be
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
specific
dose
("
RSD").
This
approach
considers
direct
exposure
cancer
risks
from
this
carcinogenic
metal.
The
RSD
used
in
the
WTI
risk
assessment
was
the
same
as
the
RSD
prescribed
in
the
BIF
Rule,
i.
e.,
.0023
µ
g/
m3.
However,
in
the
BIF
Rule
calculations,
the
TOTAL
cancer
risk
associated
with
arsenic,
beryllium,
cadmium,
and
hexavalent­
chromium
together
must
be
equal
to
or
less
than
10­
5.
A
common
way
to
implement
this
is
to
divide
the
RSD
by
4,
which
ascribes
one­
quarter
of
the
allowable
theoretical
cancer
risk
to
each
of
the
four
metals.
This
technique
will
be
used
in
the
calculations
below.
However,
it
must
be
noted
that
the
permittee
has
the
right
to
apportion
these
differently
depending
on
the
specific
wastes
received
at
the
facility,
so
that
any
emission
or
feed
values
calculated
below
for
the
four
carcinogenic
metals
will
remain
tentative
until
accepted
by
the
permittee.

The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
the
above
information,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)
gThe
BIF
Rule
calculations
of
emission
limit
base
the
limit
on
a
simple
risk
assessment
which
only
considers
direct
inhalation
exposure.
The
BIF­
calculations
do
not
consider
indirect
routes
of
exposure,
which
in
some
cases
may
be
the
more
sensitive
pathways.
The
calculations
in
this
document
are
designed
to
consider
both
direct
and
indirect
routes
of
exposure,
because
they
are
based
on
the
detailed
risk
assessment.

­
20­
("
BIF"
Max
Emission
Rate)
=
(
RSD/
4)
/
(
DF)

("
BIF"
Max
Emission
Rate)
=
(
0.0023
µ
g/
m3)
/
(
4)
X
(
0.91
µ
g/
m3/
g/
sec)

=
6.3
E­
4
g/
sec
(
=
5
E­
3
lb/
hr)

2)
Maximum
Hourly
Feed
Rate
for
Arsenic:

Until
new
trial
burn
testing
indicates
that
a
different
feed
rate
is
appropriate,
the
feed
rate
recorded
during
the
trial
burn
(
which
resulted
in
an
emission
of
1.6
E­
4
g/
sec)
should
remain
as
the
regulatory
feed
rate
limit.
Therefore,
based
on
the
trial
burn
feed
rate:

Feed
Rate
Limit
=
0.479
g/
sec
(
=
3.8
lbs/
hr)

3)
Annual
Maximum
Emission
Rate
for
Arsenic:

Per
Table
1,
there
is
no
suggested
annual
limit.
This
was
verified
against
"
Table
2"
of
the
Appendix
VII
to
Volume
VIII
of
the
risk
assessment.
In
that
table,
which
evaluates
cancer
risks
and
human
health
His
at
the
maximum
permitted
emission
rates,
all
HI
values
are
well
below
0.25
and
all
cancer
risk
factors
are
well
below
the
regulatory
value
of
10­
5.

The
human
health
portion
of
the
risk
assessment
demonstrated
that
the
metals
emissions
demonstrated
during
the
trial
burn
add
up
to
a
total
calculated
cancer
risk
of
10­
6,
as
shown
in
Table
4,
when
both
direct
and
indirect
exposure
routes
are
considered.
Therefore,
any
annual
permit
limits
calculated
below
per
the
BIF
Rule
should
be
evaluated
against
the
trial
burn
emission
values,
and
the
actual
annual
permit
limits
imposed
should
be
restricted
to
no
more
than
a
factor
of
10
times
that
recorded
during
the
trial
burn.
Per
this
analysis,
if
the
"
BIF­
calculated"
emission
limit
value
is
less
than
10
times
the
measured
trial
burn
emission
rate,
the
conclusion
would
be
that
the
BIF­
calculated
value
is
fully
protective
for
both
directg
and
indirect
routes
of
exposure.
­
21­
The
average
trial
burn
emission
for
arsenic
was
recorded
as
1.6
E­
4
g/
sec.
As
a
risk
check,
ten
times
this
value
would
be
1.6
E­
3
g/
sec,
which
is
higher
than
the
"
BIF­
calculated"
value.
Therefore,
the
"
BIF­
calculated"
value
of
6.3
E­
4
is
less
that
10
times
the
trial
burn
value
and
therefore
is
appropriate
and
protective
on
both
an
hourly
and
annual
basis.

(
Annual
Emission
Limit)
=
(
5
E­
3
lb/
hr)
X
(
8760
hrs/
yr)

=
43.8
lbs/
yr
4)
Interim
Annual
Maximum
Feed
Rate
of
Arsenic
For
the
reasons
cited
in
the
above
paragraph,
no
annual
maximum
feed
rate
would
be
required.

(
Annual
Feed
Limit)
=
(
3.8
lbs/
hr)
X
(
8760
hrs/
yr)

=
3.33
E+
4
lbs/
yr
Beryllium:

1)
Maximum
Hourly
Emissions
of
Beryllium:

For
a
carcinogen
such
as
beryllium,
the
emission
rate
would
normally
be
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
specific
dose
("
RSD").
This
approach
considers
direct
exposure
cancer
risks
from
this
carcinogenic
metal.
The
RSD
used
in
the
WTI
risk
assessment
was
the
same
as
the
RSD
prescribed
in
the
BIF
Rule,
i.
e.,
.0042
µ
g/
m3.
However,
in
the
BIF
Rule
calculations,
the
TOTAL
cancer
risk
associated
with
arsenic,
beryllium,
cadmium,
and
hexavalent­
chromium
together
must
be
equal
to
or
less
than
10­
5.
A
common
way
to
implement
this
is
to
divide
the
RSD
by
4,
which
ascribes
one­
quarter
of
the
allowable
theoretical
cancer
risk
to
each
of
the
four
metals.
This
technique
will
be
used
in
the
calculations
below.
However,
it
must
be
noted
that
the
permittee
has
the
right
to
apportion
these
differently
depending
on
the
specific
wastes
received
at
the
facility,
so
that
any
emission
or
feed
values
calculated
below
for
the
four
carcinogenic
metals
will
remain
tentative
until
accepted
by
the
permittee.
­
22­
The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
the
above
information,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

("
BIF"
Max
Emission
Rate)
=
(
RSD/
4)
/
(
DF)

("
BIF"
Max
Emission
Rate)
=
(
0.00105
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
1.1
E­
3
g/
sec
(
=
9.1
E­
3
lb/
hr)

2)
Maximum
Hourly
Feed
Rate
of
Beryllium:

Until
new
trial
burn
testing
indicates
that
a
different
feed
rate
is
appropriate,
the
feed
rate
recorded
during
the
trial
burn
(
which
resulted
in
an
average
emission
of
<
3.6
E­
6
g/
sec)
should
remain
as
the
regulatory
feed
rate
limit.

Feed
Rate
Limit
=
.0378
g/
sec
(
=
0.30
lbs/
hr)

3)
Annual
Maximum
Emission
Rate
of
Beryllium:

Per
Table
1,
there
is
no
suggested
annual
limit
from
the
risk
assessment.
However,
this
was
based
on
a
trial
burn
emission
rate
of
3.6
E­
6
g/
sec.

The
human
health
portion
of
the
risk
assessment
demonstrated
that
continuous
emission
of
heavy
metals
at
the
rates
measured
during
the
trial
burn
add
up
to
a
total
calculated
cancer
risk
of
10­
6,
as
shown
in
Table
4,
when
both
direct
and
indirect
routes
of
exposure
are
considered.
Any
permit
emission
limits
representing
higher
emissions,
such
as
BIF­
calculated
allowable
hourly
emissions,
need
to
also
consider
the
trial
burn
emission
values
used
in
the
risk
assessment.
Annual
emissions
should
be
restricted
to
no
more
than
a
factor
of
10
times
that
recorded
during
the
trial
burn
(
because
the
trial­
burn
emissions
demonstrated
a
10­
6
cancer
risk,
which
is
one
tenth
of
the
normal
standard
of
10­
5)
to
ensure
longterm
protectiveness
from
indirect
exposure
effects.

The
average
trial
burn
emission
for
beryllium
was
recorded
as
<
3.6
E­
6
g/
sec.
As
a
risk
check,
ten
times
this
value
would
be
3.6
E­
5
g/
sec,
which
is
lower
(
i.
e.,
more
­
23­
restrictive)
than
the
"
BIF­
calculated"
value.
This
means
that
the
hourly
BIF
value
might
not
be
fully
protective
when
projected
out
to
the
long
term.
This
value
of
3.6
E­
5
g/
sec,
projected
out
to
an
annual
emission,
would
be
an
appropriate
protective
annual
emission
limit.

Recommended
Annual
Emission
Limit
=
(
3.6
E­
5
g/
sec)
X
(
3.15
sec/
yr)

=
1135
g/
yr
(
=
2.5
lbs/
yr)

4)
Interim
Annual
Maximum
Feed
Rate
of
Beryllium
Until
new
trial
burn
testing
indicates
that
a
different
feed
rate
is
appropriate,
the
hourly
feed
rate
recorded
during
the
trial
burn
should
remain
as
the
regulatory
feed
rate
limit.
The
annual
feed
limit
would
simply
be
this
same
value
projected
out
to
8760
hours
per
year:

Annual
Feed
Limit
=
(
Hourly
Feed
Limit)
X
(
8760
hours/
yr)

Annual
Feed
Limit
=
(.
0378
g/
sec)
X
(
3600
sec/
hr)
X
(
8760
hrs/
yr)

Annual
Feed
Limit
=
1190
kg/
yr
(
=
2630
lb/
yr)

Cadmium:

1)
Maximum
Hourly
Emissions
of
Cadmium:

For
a
carcinogen
such
as
cadmium,
the
emission
rate
would
normally
be
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
specific
dose
("
RSD").
This
approach
considers
direct
exposure
cancer
risks
from
this
carcinogenic
metal.
The
RSD
used
in
the
WTI
risk
assessment
was
the
same
as
the
RSD
prescribed
in
the
BIF
Rule,
i.
e.,
.0056
µ
g/
m3.
However,
in
the
BIF
Rule
calculations,
the
TOTAL
cancer
risk
associated
with
arsenic,
beryllium,
cadmium,
and
hexavalent­
chromium
together
must
be
equal
to
or
less
than
10­
5.
A
common
way
to
implement
this
is
to
divide
the
RSD
by
4,
which
ascribes
one­
quarter
of
the
allowable
theoretical
cancer
risk
to
each
of
the
four
metals.
This
technique
is
used
in
the
calculations
below,
but
it
must
be
noted
that
the
permittee
has
the
right
to
apportion
these
differently
depending
on
the
specific
wastes
received
at
the
facility,
so
that
any
emission
or
feed
values
calculated
below
for
the
four
carcinogenic
metals
will
remain
tentative
until
accepted
by
the
permittee.
­
24­
The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
the
above
information,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

("
BIF"
Max
Emission
Rate)
=
(
RSD/
4)
/
(
DF)

("
BIF"
Max
Emission
Rate)
=
(
0.0014
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
1.54
E­
3
g/
sec
(
=
1.22
E­
2
lb/
hr)

2)
Maximum
Hourly
Feed
Rate
of
Cadmium:

Until
new
trial
burn
testing
indicates
that
a
different
feed
rate
is
appropriate,
the
feed
rate
recorded
for
cadmium
during
the
trial
burn
(
which
resulted
in
an
average
emission
of
1.9
E­
4
g/
sec)
should
remain
as
the
regulatory
feed
rate
limit.

Feed
Rate
Limit
=
1.47
g/
sec
(
=
11.7
lbs/
hr)

3)
Annual
Maximum
Emission
Rate
of
Cadmium:

Per
Table
1,
there
is
no
suggested
annual
limit
from
the
risk
assessment.
However,
this
was
based
on
a
trial
burn
emission
rate
for
cadmium
of
1.9
E­
4
g/
sec,
so
the
following
further
analysis
is
appropriate:

The
potential
cancer
and
toxicity
effects
of
cadmium
were
verified
against
"
Table
2"
of
the
Appendix
VII
to
Volume
VIII
of
the
risk
assessment.
In
that
table,
which
evaluates
cancer
risks
and
human
health
HI
values
at
the
maximum
permitted
emission
rates,
all
HI
values
are
well
below
0.25
and
all
cancer
risk
factors
are
well
below
the
regulatory
value
of
10­
5.

The
human
health
portion
of
the
risk
assessment
demonstrated
that
the
metals
emissions
during
the
trial
burn
add
up
to
a
total
calculated
cancer
risk
of
10­
6,
as
shown
in
Table
4.
Therefore,
any
permit
limits
calculated
per
the
BIF
Rule
should
be
evaluated
against
the
trial
burn
emission
values,
and
the
annual
permit
limits
­
25­
imposed
should
be
restricted
to
no
more
than
a
factor
of
10
times
the
emission
rate
recorded
during
the
trial
burn.

The
average
trial
burn
emission
for
cadmium
was
recorded
as
1.9
E­
4
g/
sec.
As
a
risk
check,
ten
times
this
value
(
based
on
the
fact
that
the
emission
rates
used
in
the
permit
limit
scenario
of
the
risk
assessment
resulted
in
cancer
risks
of
10%
of
the
regulatory
limit,
as
described
above)
would
be
1.9
E­
3
g/
sec,
which
is
higher
than
the
"
BIF­
calculated"
value.
Therefore,
the
BIF
value
is
fully
protective
even
when
both
direct
and
indirect
routes
of
exposure
are
considered.
Therefore,
the
annual
limit
can
be
the
same
as
the
hourly
limit
projected
out
to
8760
hours.

Annual
Emission
Limit
=
(
Hourly
Emission
Limit)
X
(
8760
hrs/
yr)

Annual
Emission
Limit
=
(
1.54
E­
3
g/
sec)
X
(
3600
sec/
hr)
X
(
8760
hrs/
yr)

Annual
Emission
Limit
=
48.6
kg/
yr
(
=
107
lb/
yr)

4)
Interim
Annual
Maximum
Feed
Rate
for
Cadmium:

Until
new
trial
burn
testing
indicates
that
a
different
feed
rate
is
appropriate,
the
hourly
feed
rate
recorded
during
the
trial
burn
should
remain
as
the
regulatory
feed
rate
limit.
The
annual
feed
limit
would
simply
be
this
same
value
projected
out
to
8760
hours
per
year:

Annual
Feed
Limit
=
(
Hourly
Feed
Limit)
X
(
8760
hours/
yr)

Annual
Feed
Limit
=
(
1.47
g/
sec)
X
(
3600
sec/
hr)
X
(
8760
hrs/
yr)

Annual
Feed
Limit
=
46,360
kg/
yr
(
=
102,100
lb/
yr)

Chromium:

1)
Maximum
Hourly
Emissions
of
Chromium:

For
a
carcinogen
such
as
chromium,
the
emission
rate
would
normally
be
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
specific
dose
("
RSD").
This
approach
considers
direct
exposure
cancer
risks
from
this
carcinogenic
metal.
The
RSD
used
in
the
WTI
risk
assessment
was
the
same
as
the
RSD
prescribed
in
the
BIF
Rule,
i.
e.,
.00083
µ
g/
m3.
However,
in
the
BIF
Rule
calculations,
the
TOTAL
cancer
risk
associated
with
arsenic,
beryllium,
cadmium,
and
hexavalent­
chromium
together
­
26­
must
be
equal
to
or
less
than
10­
5.
A
common
way
to
implement
this
is
to
divide
the
RSD
by
4,
which
ascribes
one­
quarter
of
the
allowable
theoretical
cancer
risk
to
each
of
the
four
metals.
This
technique
will
be
used
in
the
calculations
below,
but
it
must
be
noted
that
the
permittee
has
the
right
to
apportion
these
differently
depending
on
the
specific
wastes
received
at
the
facility,
so
that
any
emission
or
feed
values
calculated
below
for
the
four
carcinogenic
metals
will
remain
tentative
until
accepted
by
the
permittee.

This
analysis
of
chromium
emissions
assumes
that
all
chromium
emitted
out
the
stack
is
in
the
most
carcinogenic
form,
i.
e.,
hexavalent
chromium.

The
refined
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
the
above
information,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

("
BIF"
Max
Emission
Rate)
=
(
RSD/
4)
/
(
DF)

("
BIF"
Max
Emission
Rate)
=
(
2.075
E­
4
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
2.28
E­
4
g/
sec
(
=
1.81
E­
3
lb/
hr)

2)
Maximum
Hourly
Feed
Rate
of
Chromium:

Until
new
trial
burn
testing
indicates
that
a
different
feed
rate
is
appropriate,
the
feed
rate
recorded
during
the
trial
burn
(
which
resulted
in
an
average
emission
of
1.5
E­
4
g/
sec)
should
remain
as
the
regulatory
feed
rate
limit.

Feed
Rate
Limit
=
22.4
g/
sec
(
=
178
lbs/
hr)

3)
Annual
Maximum
Emission
Rate
of
Chromium:

Per
Table
1,
there
is
no
suggested
annual
limit
from
the
risk
assessment.
However,
this
was
based
on
a
trial
burn
chromium
emission
rate
of
1.5
E­
4
g/
sec,
so
the
following
further
analysis
is
appropriate
to
verify
that
the
slightly
higher
"
BIF­
calculated"
emission
limit
value
of
2.28
E­
4
g/
sec
is
fully
protective.
­
27­
The
potential
cancer
and
toxicity
effects
were
verified
against
"
Table
2"
of
the
Appendix
VII
to
Volume
VIII
of
the
risk
assessment.
In
that
table,
which
evaluates
cancer
risks
and
human
health
HI
values
at
the
maximum
permitted
emission
rates,
all
HI
values
are
well
below
0.25
and
all
cancer
risk
factors
are
well
below
the
regulatory
value
of
10­
5.

The
human
health
portion
of
the
risk
assessment
demonstrated
that
the
metals
emissions
recorded
during
the
trial
burn
add
up
to
a
total
calculated
cancer
risk
of
10­
6,
as
shown
in
Table
4.
Therefore,
any
permit
limits
calculated
per
the
BIF
Rule
should
be
evaluated
against
the
trial
burn
emission
values,
and
the
actual
permit
limits
imposed
should
be
restricted
to
no
more
than
a
factor
of
10
times
the
trial
burn
emission
values.

The
average
trial
burn
emission
for
chromium
was
recorded
as
1.5
E­
4
g/
sec.
As
a
risk
check,
ten
times
this
value
(
this
10X
factor
is
based
on
the
fact
that
the
emission
rates
used
in
the
permit
limit
scenario
of
the
risk
assessment
resulted
in
cancer
risks
of
10%
of
the
10­
5
regulatory
value,
as
described
above)
would
be
1.5
E­
3
g/
sec,
which
is
higher
than
the
"
BIF­
calculated"
value.
Therefore,
the
BIF
value
is
fully
protective
even
when
both
direct
and
indirect
routes
of
exposure
are
considered.
Even
at
an
emission
rate
10
times
the
trial
burn
emission
rate,
all
values
would
be
below
these
thresholds.
Because
the
"
BIF­
calculated"
emission
limit
is
less
than
10
times
the
trial
burn
emission
rate,
no
additional
annual
limits
appear
to
be
warranted
as
long
as
the
hourly
limit
is
complied
with.
The
annual
emission
limit
would
simply
be
the
same
as
the
hourly
limit
projected
out
to
8760
hours
per
year.

Annual
Emission
Limit
=
(
Hourly
Emission
Limit)
X
(
8760
hrs/
yr)

Annual
Emission
Limit
=
(
2.28
E­
4
g/
sec)
X
(
3600
sec/
hr)
X
(
8760
hrs/
yr)

Annual
Emission
Limit
=
7190
g/
yr
(
=
15.8
lb/
yr)

4)
Interim
Annual
Maximum
Feed
Rate
of
Chromium:

Until
new
trial
burn
testing
indicates
that
a
different
feed
rate
is
appropriate,
the
hourly
chromium
feed
rate
recorded
during
the
trial
burn
should
remain
as
the
regulatory
feed
rate
limit.
The
annual
feed
limit
would
simply
be
this
same
value
projected
out
to
8760
hours
per
year:

Annual
Feed
Limit
=
(
Hourly
Feed
Limit)
X
(
8760
hours/
yr)
­
28­
Annual
Feed
Limit
=
(
22.4
g/
sec)
X
(
3600
sec/
hr)
X
(
8760
hrs/
yr)

Annual
Feed
Limit
=
7.06
E+
5
kg/
yr
(
=
1.56
E+
6
lb/
yr)

Lead:

1)
Maximum
Hourly
Emissions
of
Lead:

This
is
calculated
as
described
in
the
BIF
Rule
at
40
CFR
266.106,
using
the
dispersion
factor
("
DF")
and
the
reference
air
concentration
("
RAC").
This
approach
considers
direct
exposure
risks.
The
BIF
Rule
prescribes
an
RAC
for
lead
of
.09
µ
g/
m3.
The
USEPA
risk
assessment
used
a
different
technique
for
evaluating
lead
toxicity,
known
as
the
Uptake/
Biokenetic
Model.
This
technique
cannot
be
readily
compared
to
the
BIF
calculation
technique,
so
additional
evaluation
might
be
warranted
to
verify
any
significant
changes
in
the
emission
limit.

The
refined
air
dispersion
modeling
used
in
the
risk
assessment
resulted
in
a
DF
of
0.91
µ
g/
m3/
g/
sec.
From
this
information,
the
calculated
hourly
max
emission
rate
would
be:

(
Emission
Rate)
X
(
DF)
=
(
Ground
Level
Concentration)

(
Emission
Rate)
=
(
Ground
Level
Concentration)
/
(
DF)

(
Max
Emission
Rate)
=
(
RAC)
/
(
DF)

Max
Emission
Rate
=
(
0.09
µ
g/
m3)
/
(
0.91
µ
g/
m3/
g/
sec)

=
0.10
g/
sec
(=
0.78
lb/
hr)

The
human
health
impact
of
this
"
BIF­
calculated"
emission
limit
is
presently
being
re­
evaluated
because
it
is
considerably
greater
than
what
was
evaluated
in
the
risk
assessment.
In
the
interim,
it
is
recommended
that
the
emissions
of
Pb
be
restricted
to
no
more
than
2­
3
times
the
average
of
the
actual
measured
values
from
the
1993
trial
burns.
Therefore,
it
is
recommended
that
until
further
analysis
is
completed,
the
following
emission
limit
be
imposed:

Maximum
Emission
Rate
=
3
X
(.
0012
g/
sec)

=
.0036
g/
sec
(
=
.029
lb/
hr)
­
29­
2)
Maximum
Hourly
Feed
Rate
of
Lead:

Until
new
trial
burn
testing
indicates
that
a
different
feed
rate
is
appropriate,
the
feed
rate
recorded
during
the
trial
burn
(
which
resulted
in
an
emission
of
1.2
E­
3
g/
sec)
should
remain
as
the
regulatory
feed
rate
limit.

Feed
Rate
Limit
=
12.6
g/
sec
(
=
100
lbs/
hr)

3)
Annual
Maximum
Emission
Rate
of
Lead:

At
this
time,
there
is
no
information
indicating
that
an
annual
restriction
on
lead
emission
rate
is
needed
in
addition
to
the
hourly
value
given
above.

Annual
Emission
Limit
=
(.
029
lb/
hr)
X
8760
hrs/
yr
=
254
lb/
yr
4)
Interim
Annual
Maximum
Feed
Rate
of
Lead:

At
this
time,
there
is
no
information
indicating
that
an
annual
restriction
on
lead
feed
rate
would
be
needed
in
addition
to
the
hourly
value
given
above.

Annual
Feed
Limit
=
(
100
lb/
hr)
X
8760
hrs/
yr
=
8.7
E+
5
lbs/
yr
aBased
on
projected
annual
emissions
at
"
maximum
permit
limit"
hourly
maximum
emission
rates
only.
See
USEPA
Risk
Assessment
Volume
VIII,
Attachment
VII­
1
for
complete
listing
of
predicted
human
health
HI
and
cancer
risk
values
at
full
permit
limit
metals
emission
rates.

bSee
Volume
VI,
Chapter
VII,
Section
E.
1.
a.,
p.
VII­
12.
HI
effects
potentially
above
the
value
of
1
shown
in
chart
are
associated
with
food
chain
impacts
to
either
the
short­
tailed
shrew
or
the
American
robin.

cThis
HI
is
largely
caused
by
direct
exposure,
due
to
a
much
lower
barium
RAC
used
in
the
risk
assessment.

dThis
ascribes
only
25%
of
the
available
Human
Health
HI
for
toxicological
effects
from
this
pollutant
to
this
one
emission
source,
per
USEPA
guidance.
This
factors
in
the
fact
that
there
might
be
other
pollution
sources
also
impacting
the
area.

eThis
is
the
greater
of
the
HI
or
Cancer
Risk
suggested
reduction.
The
Cancer
risk
of
1.5
E­
3
would
require
a
reduction
by
150x
to
bring
the
risk
down
to
1.0
E­
5.

­
30­
Table
1
Potential
reductions
in
annual
emissiona
rates
at
WTI:

Metal
Ecob
HHRA
HHRA
Sugg'd
HI>
1
HI>
1
Cancer>
10­
5
Reduction
______________________________________________________________________

Ba
416
1400c
NA
1400
x
4d
=
5600x
Hg
4.1
4.3c
NA
4.3
x
4
=
17.2x
Ag
5.2
60
NA
60
x
4
=
240x
Tl
4250
650
NA
4250x
Ni
367
14
1.5
E­
3
367xe
Se
3000
30
NA
3000x
Sb
ok
ok
ok
none
As
ok
ok
ok
none
­
31­
Metal
Eco
HHRA
HHRA
Sugg'd
Annual
HI>
1
HI>
1
Cancer>
10­
5
Reduction
______________________________________________________________________
Be
ok
ok
ok
none
Cd
ok
ok
ok
none
Cr
ok
ok
ok
none
Pb
ok
no
RfD/
slope
fctr.
NA
none
Al
ok
not
evaluated
NA
none
Cu
ok
not
evaluated
NA
none
Zn
ok
not
evaluated
NA
none
aEstimated
Actual
emission
values
are
those
developed
by
MRI
based
on
averaging
of
waste
profile
information
from
WTI,
and
represent
the
emissions
thought
to
reflect
reality
much
more
closely
than
does
extrapolating
the
hourly
permit
limits
out
to
annual
emission
values.

bMax
possible
emissions
based
on
continuous
emission
at
the
hourly
"
permit
limit"
values
in
the
risk
assessment
were
based
on
the
following:
(
1)
Actual
trial
burn
emission
values
from
3/
93
trial
burn
where
that
metal
was
tested,
or
(
2)
"
BIF
Adjusted
Tier
1"
calculated
allowable
values
for
metals
which
were
not
tested
during
the
3/
93
trial
burn
(
except
for
Copper,
Zinc,
and
Aluminum,
which
are
not
presently
regulated
under
RCRA).
These
Adjusted
Tier
1
values
were
based
on
possible
future
permit
use
of
newest
Dispersion
Factor
("
DF")
of
0.92
(
used
in
the
R/
A)
instead
of
older
DF
=
1.50
(
which
was
used
to
set
the
present
permit
limits).
This
new
lower
DF
was
used
here
and
in
the
risk
assessment
because
it
was
assumed
that
the
permittee
might
request
approval
of
these
higher
hourly
emission
rates
reflecting
the
updated
modeling.

cThese
values
are
calculated
based
on
the
g/
sec
emission
values
for
(
1)
actual
predicted
and
(
2)
possible
maximum
used
in
the
risk
assessment,
multiplied
by
69462
pound­
per­
year
per
gram­
per­
second.
­
32­
TABLE
2
Metal
MRI
Possible
Max
Emissions:
Present
R/
A­
Projected
Suggested
Suggested
Estimated
Actuala
Rsk
Assmntb
Present
Limit
Feed
Annual
Emissionc
Annual
Annual
Annual
Avg.
Limit
Estd.
Actual
Possible
Max
Reduc.
Factor
Limit
Ba
1.5
E­
4
g/
sec
55
g/
sec
33.4
g/
s
33.4
g/
s
10
lb/
yr
3.82E+
6
lb/
y
5600x
682
lb/
y
(
436
lbs/
hr)
(
265
lbs/
hr)
(
265
lbs/
hr)

Hg
1.4
E­
3
g/
sec
.088
g/
sec
.053
g/
s
.0184
g/
s
97
lb/
yr
6110
lb/
y
17.2x
355
lb/
y
(
0.7
lb/
hr)
(
0.42
lbs/
hr)
(
0.146
lbs/
hr)

Ag
1.5
E­
5
g/
sec
3.3
g/
sec
2.0
g/
s
2.0
g/
s
1.0
lb/
yr
2.29E+
5
lb/
y
240x
954
lb/
y
(
26
lbs/
hr)
(
15.9
lbs/
hr)
(
15.9
lbs/
hr)

Tl
3.4
E­
5
g/
sec
0.55
g/
sec
0.333
g/
s
0.333
g/
s
2.4
lbs/
yr
3.82
E+
4
lb/
yr
4250x
6.6
lb/
y
(
4.4
lbs/
hr)
(
2.65
lbs/
hr)
(
2.65
lb/
hr)
­
33­

Metal
MRI
Possible
Max
Emissions
Present
R/
A­
Projected
Suggested
Suggested
Estimated
Actual
Rsk
Assmnt
Present
Limit
Feed
Annual
Emission
Annual
Annual
Annual
Avg.
Limit
Estd.
Actual
Possible
Max
Reduct.
Factor
Limit
Ni
5.0
E­
6
g/
sec
22
g/
sec
None
None
0.35
lb/
yr
1.53E+
6
lbs/
yr
367x
4170
lbs/
y
(
174
lbs/
hr)

Se
4.7
E­
4
g/
sec
4.4
g/
sec
None
None
33
lbs/
yr
3.06E+
5
lbs/
yr
3000x
102
lbs/
y
(
35
lbs/
hr)

Sb
4.2
E­
6
g/
sec
1.6
E­
4
g/
sec
0.20
g/
s
1.18
g/
s
0.3
lb/
yr
11.1
lbs/
yr
none
(
1.27
E­
3
lb/
hr)
(
1.59
lb/
hr)
(
9.4
lbs/
hr)

As
3.7
E­
5
g/
sec
1.1
E­
4
g/
sec
.0015
g/
s
0.479
g/
s
2.6
lbs/
yr
7.64
lbs/
yr
none
(
8.7
E­
4
lb/
hr)
(.
0121
lb/
hr)
(
3.8
lb/
hr)

Be
3.3
E­
8
g/
sec
<
3.6
E­
6
g/
sec
.0028
g/
s
.0378
g/
s
.0023
lb/
yr
0.25
lb/
yr
none
(<
2.85
E­
5
lb/
hr)
(.
0222
lb/
hr)
(
0.3
lb/
hr)

Cd
1.6
E­
5
g/
sec
1.9
E­
4
g/
sec
.00373
g/
s
1.47
g/
s
1.1
lb/
yr
13.2
lbs/
yr
none
(
1.5
E­
3
lb/
hr)
(.
0296
lb/
hr)
(
11.7
lb/
hr)
dAlthough
the
value
for
Cr6+
measured
during
the
trial
burn
was
1.7
E­
6
g/
sec,
only
a
fraction
of
the
chrome
in
the
waste
feed
was
Cr6+
during
the
trial
burn.
For
regulatory
purposes,
all
chromium
exiting
the
stack
is
presently
being
considered
to
be
Cr6+,
since
it
is
possible
that
the
chromium
in
the
waste
feed
could
potentially
be
100%
Cr6+
at
any
time
after
the
trial
burn.
Therefore,
the
total
chromium
emission
of
1.5
E­
4
g/
sec
is
being
considered
Cr6+.

eChromium
feed
limit
is
a
limit
on
total
chromium.
­
34­

Cr6+
7.1
E­
7
g/
sec
1.5
E­
4
g/
secd
5.5E­
4g/
se
22.4
g/
s
.05
lb/
yr
10.4
lbs/
yr
none
(
1.2
E­
3
lb/
hr)
(.
00439
lb/
hr)
(
178
lb/
hr)

Pb
4.3
E­
5
g/
sec
1.2
E­
3
g/
sec
.060
g/
s
12.6
g/
s
3.0
lbs/
yr
83.4
lbs/
yr
none
(
9.5
E­
3
lb/
hr)
(
0.47
lb/
h)
(
100
lb/
h)

Metal
MRI
Possible
Max
Emissions
Present
R/
A­
Projected
Suggested
Suggested
Estimated
Actual
Rsk
Assmnt
Present
Limit
Feed
Annual
Emission
Annual
Annual
Annual
Avg.
Limit
Estd.
Actual
Possible
Max
Reduct.
Factor
Limit
Al
1.2
E­
4
g/
sec
n/
a
None
None
8.34
lbs/
yr
n/
a
none
Cu
9.4
E­
5
g/
sec
n/
a
None
None
6.5
lbs/
yr
n/
a
none
Zn
1.2
E­
4
g/
sec
n/
a
None
None
8.34
lbs/
yr
n/
a
none
­
35­
Table
3
Comparison
of
RACs
and
RSDs
from
BIF
Rule
and
WTI­
RA
BIF
WTI­
R/
A
BIF
WTI­
RA
Metal
TB
Emiss.
RAC
RAC
RSD
RSD
(
g/
s)
(
µ
g/
m3)
(
µ
g/
m3)
(
µ
g/
m3)
(
µ
g/
m3)
_________________________________________________________________________________________

Ba
50
0.13
Hg
.08
.075
Ag
3.0
4.4
Tl
0.50
.061
Ni
20
18
Se
4
4.4
Sb
1.6
E­
4
0.30
0.35
As
1.1
E­
4
.0023
.0023
Be
3.6
E­
6
.0042
.0042
Cd
1.9
E­
4
.0056
.0056
Cr
1.5
E­
4
.00083
.00083
Pb
1.2
E­
3
.09
Not
Applic
­
36­
Table
4
Maximum
Potential
Cancer
Risks
from
Arsenic,
Beryllium,
Cadmium,
and
Chromium
Calculated
in
Risk
Assessment
Under
"
Permit
Limit"
Emission
Scenario:

As
4.5
E­
7
Be
2.6
E­
9
Cd
9.3
E­
8
Cr
4.9
E­
7
TOTAL
1.0
E
­
6
­
37­
TABLE
5
Possible
New1
Metals
Feed
and
Emission
Limits
Present
Hourly
Present
Hourly
New
Hourly
New
Hourly
New
Annual
New
Annual
ESTIMATED3
Emission
Feed
Emission
Feed
Emission
Feed
ANNUAL
Metal
Limit
Limit
Limit
Limits
Limit
Limit
EMISSION
Ba
265
lbs/
hr
265
lbs/
hr
1.13
lb/
hr
493
lbs/
hr
682
lbs/
yr
2.96
E+
5
lbs/
yr
10
lbs/
yr
Hg
0.42
lb/
hr
0.146
lb/
hr
0.65
lb/
hr
0.65
lb/
hr
355
lbs/
yr
355
lbs/
yr
97
lbs/
yr
Ag
15.9
lbs/
hr
15.9
lbs/
hr
26
lbs/
hr
11,370
lbs/
hr
954
lbs/
yr
4.15
E+
5
lbs/
yr
1
lb/
yr
Tl
2.65
lbs/
hr
2.65
lbs/
hr
0.53
lb/
hr
231
lbs/
hr
6.6
lbs/
yr
2870
lbs/
yr
2.4
lb/
yr
Ni
None
None
156
lbs/
hr
68,260
lb/
hr
4170
lbs/
yr
1.8
E+
6
lbs/
yr
0.34
lb/
yr
Se
None
None
34.9
lbs/
hr
11,630
lbs/
hr
102
lbs/
yr
3.4
E+
4
lbs/
yr
33
lb/
yr
Sb
1.59
lb/
hr
9.4
lbs/
hr
2.6
lbs/
hr
9.4
lbs/
hr
11.1
lbs/
yr
(
82,300
lbs/
yr)
0.3
lb/
yr
As
.0121
lb/
hr
3.8
lbs/
hr
.005
lbs/
hr
3.8
lbs/
hr
(
43.8
lbs/
yr)
(
3.3
E+
4
lbs/
yr)
2.6
lb/
yr
­
38­

TABLE
5
Continued
Possible
New
Metals
Feed
and
Emission
Limits
Present
Present
New
Hourly
New
Hourly
Annual
Annual
ESTIMATED
Emission
Feed
Emission
Feed
Emission
Feed
ANNUAL
Metal
Limit
Limit
Limit
Limits
Limit
Limit
EMISSION
Be
.0222
lb/
hr
0.3
lb/
hr
.0091
lb/
hr
0.30
lb/
hr
2.50
lbs/
yr
(
2630
lbs/
yr)
.0023
lb/
yr
Cd
.0296
lb/
hr
11.7
lb/
hr
.0122
lb/
hr
11.7
lbs/
hr
(
107
lbs/
yr)
(
1.0
E+
5
lbs/
yr)
1.1
lb/
yr
Cr+
.00439
lb/
hr
178
lb/
hr
.0018
lb/
hr
178
lbs/
hr
(
15.8
lbs/
yr)
(
1.56
E+
6
lbs/
yr)
.05
lb/
yr
Pb
0.47
lb/
hr
100
lb/
hr
0.029
lb/
hr4
100
lbs/
hr
(
254
lbs/
yr)
(
8.7
E+
5
lbs/
yr)
3.0
lb/
yr
1.
Note
that
these
values
listed
as
"
New"
or
"
Annual"
represent
maximum
values;
Actual
permit
limits
can
be
set
at
lower
levels
that
given
in
chart,
if
appropriate.
These
reflect
USEPA
limits;
State
limits
might
be
more
restrictive.

2.
Parentheses
indicate
annual
limits
which
are
the
same
as
the
hourly
multiplied
by
8760
hours/
yr.

3.
ESTIMATED
ANNUAL
lists
the
emission
values
used
in
the
risk
assessment,
based
on
actual
WTI
waste
profiles,
operation
at
full
thermal
capacity
365
days
per
year,
and
the
most
precise
available
estimates
of
metals
removal
efficiencies.

4.
These
new
emission
limits
for
lead
are
conservative
interim
limits,
subject
to
change
upon
further
evaluation.
