1
Hazardous
Waste
Combustor
MACT
Standards
Final
Rule
Briefing
for
OMB
April
21,
2005
Scope
 
Background/
General
Status
Update
 
Summary
of
Floor
Options
That
Were
Under
Consideration
 
Comparison
of
the
Two
Main
Floor
Options
That
Were
Under
Consideration
 
Summary
of
Beyond­
the­
Floor
Options
That
Were
Under
Consideration
2
Background/
General
Status
Update
 
This
final
rule
will
subject
5
industry
sectors
that
combust
hazardous
waste
to
standards
reflecting
Maximum
Achievable
Control
Technology
(
MACT),
pursuant
to
Section
112(
d)
of
the
Clean
Air
Act
o
Incinerators,
cement
kilns,
lightweight
aggregate
kilns,
industrial
boilers,
and
hydrochloric
acid
production
furnaces
o
Regulates
emissions
of
hazardous
air
pollutants:
metals
(
e.
g.,
mercury
and
lead),
particulate
matter
(
in
part
as
a
surrogate
for
other
metals
not
directly
controlled
with
an
emission
limitation),
hydrogen
chloride
and
chlorine
gas,
dioxin
and
furans,
and
other
organic
hazardous
air
pollutants
 
Attachment
F
(
last
attachment)
provides
the
following
background
information:

o
Quantities
of
hazardous
waste
combusted
and
the
number
of
sources
within
each
source
category
that
will
be
subject
to
this
rule
o
Brief
overview
of
the
Clean
Air
Act
requirements
governing
technology­
based
emission
standards,

including
definitions
of
technology­
based
floor
standards
and
beyond­
the­
floor
standards
o
Historical
summary
of
the
regulatory
process
for
hazardous
waste
combustors,
including
previous
court
decisions
affecting
these
source
categories
 
Key
Stakeholders
o
Sierra
Club:
Represented
by
Earth
Justice
(
previous
winning
litigant)

o
Environmental
Technology
Council:
Represents
subset
of
commercial
incinerators
o
Cement
Kiln
Recycling
Coalition:
Represents
cement
kilns
that
combust
hazardous
waste
o
American
Chemistry
Council:
Represents
subset
of
on­
site
incinerators,
boilers,
and
hydrochloric
acid
production
furnaces
at
chemical
and
petroleum
plants
o
Solite
Corporation:
Represents
one
of
the
two
lightweight
aggregate
kiln
facilities
3
o
Federal
facilities

5
DOD
facilities
(
10
sources)
and
1
DOE
facility

Primarily
responsible
for
destroying
chemical
weapon
wastes
 
We
were
previously
subject
to
two
separate
judicially
enforceable
consent
decrees
(
one
from
the
District
Court
and
one
from
the
Court
of
Appeals)
that
stipulated
we
must
promulgate
this
rulemaking
no
later
than
June
14,
2005
o
We
recently
filed
motions
with
both
courts
to
extend
the
completion
date
to
September
14,
2005.
One
court
has
granted
the
motion,
the
other
will
do
so
(
since
there
was
no
opposition)

 
We
are
currently
on
track
to
have
this
rule
signed
no
later
than
September
14,
2005
 
Attachment
A
includes
a
summary
of
the
emission
standards
that
will
be
included
in
the
Final
Rule
package
o
For
comparative
purposes,
the
table
also
includes
the
emission
standards
that
we
proposed,
and
the
interim
emission
standards
to
which
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
are
currently
subject
to
o
The
standards
that
are
in
bold
reflect
beyond­
the­
floor
standards
Summary
of
the
MACT
Floor
Options
That
Were
Under
Consideration
 
MACT
standards
must
reflect
a
minimum
level
of
stringency,
known
as
the
"
Floor"

 
For
several
regulated
pollutants
(
metals
and
chlorine),
emissions
are
controlled
by:
1)
limiting
the
amount
of
pollutant
that
is
fed
in
the
hazardous
waste
into
the
combustion
unit
(
we
call
this
hazardous
waste
feed
control);

and
2)
controlling
the
percent
of
the
pollutant
that
is
removed
from
the
combustion
unit
prior
to
being
emitted
to
the
atmosphere
(
we
call
this
system
removal
efficiency,
or
more
generally
back­
end
control)

o
Note
that
feed
control
is
a
feasible
means
of
controlling
pollutants
in
the
hazardous
waste
input,
but
is
not
a
feasible
means
of
controlling
input
of
other
materials
like
raw
materials
and
fossil
fuels;
back­
end
control
applies
to
control
of
pollutants
from
all
feeds
to
the
combustion
unit
 
Why
is
hazardous
waste
feed
control
applicable
to
hazardous
waste
combustors?
4
o
These
sources
have
been
subject
to
hazardous
waste
pollutant
feed
rate
limitations
pursuant
to
RCRA
requirements,
and
have
been
controlling
their
hazardous
waste
feed
inputs
using
various
techniques
(
e.
g.,

fuel
blending,
selection
of
wastes
that
are
combusted
or
sent
off­
site,
waste
minimization)

o
As
a
result,
we
have
taken
the
position
that
the
MACT
standard
setting
process
for
hazardous
waste
combustors
must
account
for
both
hazardous
waste
pollutant
feed
control
and
back­
end
control

This
is
somewhat
unique,
in
that
most
MACT
rules
for
combustion
units
assess
only
back­
end
control
 
We
focused
on
two
options
that
would
use
different
MACT
floor
calculation
methodologies
for
the
pollutants
(
metals
and
chlorine)
that
are
controlled
with
feed
control
and
back­
end
control
o
These
two
options
(
A
and
C)
are
described
below
o
The
key
difference
is
that
Option
C
defines
best
performers
as
those
with
the
lowest
emissions;
Option
A
captures
the
lowest
emissions
possible
while
trying
to
assure
that
facilities
can
use
either
back
end
control
or
feed
control
to
achieve
most
or
all
of
the
reductions
needed.

 
We
also
assessed
other
options
which
are
variants
of
these
approaches,
two
of
which
are
briefly
described
later
(
Options
B
and
D)

 
Option
A:
Proposed
Option
o
We
have
selected
Option
A
as
the
floor
option
to
go
forward
with
in
the
Final
Rule
package
o
Uses
the
same
methodologies
to
calculate
the
floor
levels
that
were
proposed
(
with
a
couple
exceptions)


We
requested
comment
from
key
stakeholders
on
these
exceptions
in
a
recent
notice;
these
exceptions
include
a
revised
methodology
that
better
accounts
for
emissions
variability
when
calculating
the
floor
levels
from
data
that
includes
non­
detect
measurements;
a
revised
methodology
5
to
calculate
the
Hg
standard
for
lightweight
aggregate
kilns
that
better
accounts
for
mercury
fluctuations
in
their
waste
feeds;
and
a
provision
that
gives
liquid
fuel
boilers
the
option
to
comply
with
alternative
emission
standards
o
For
metals
and
chlorine,
we
define
best
performing
sources
as
those
with
the
best
combination
of
hazardous
waste
feed
control
and
back­
end
control
as
defined
by
a
ranking
procedure:
we
call
this
methodology
the
"
double
ranking
approach"


Hazardous
waste
feed
control
levels
are
ranked
from
best
to
worst,
and
each
source
is
assigned
a
ranking
score
(
e.
g.,
the
lowest
feeder
gets
a
ranking
of
1)


Back­
end
control
efficiencies
are
ranked
from
best
to
worst
and
each
source
is
assigned
a
ranking
score

Each
source's
feed
control
and
back
end
control
ranking
score
are
added
together,
yielding
an
aggregated
score

The
best
performers
are
defined
as
those
with
the
best
aggregated
scores.
The
floor
standard
would
then
be
the
average
of
the
emission
levels
of
these
sources
with
a
variability
factor
added.
This
means
that
lowest
emitters
may
(
in
some
cases)
not
be
considered
a
`
best
performing'
source.

o
For
regulated
pollutants
that
are
not
controlled
with
both
hazardous
waste
feed
control
and
back­
end
control
(
the
main
examples
being
particulate
matter
and
dioxin/
furans),
other
methodologies
are
used
to
identify
the
best
performing
sources,
including
ranking
by
lowest
emissions,
and
assessing
emissions
from
sources
using
the
best
back­
end
control
type
­
methodologies
that
have
been
used
in
other
MACT
rules
for
combustion
sources
 
Option
C:
Emissions­
Based
Approach
o
Identical
to
Option
A,
except
we
don't
use
the
double
ranking
approach
to
identify
the
best
performers
for
metals
and
chlorine

Best
performers
are
instead
defined
as
simply
those
with
the
lowest
emissions
o
Much
closer
to
how
Sierra
Club
(
the
previous
winning
litigant)
believes
we
should
calculate
floors
6
o
We
call
this
approach
"
straight
emissions
with
exceptions"
because
it
does
not
use
this
emissions­
based
methodology
in
instances
where
we
believe
it
would
not
be
technically
appropriate
or
legally
defensible

For
example,
the
lowest
chlorine
emitting
hydrochloric
acid
production
furnaces
could
have
low
emissions
because
they
have
relatively
lower
chlorine
feeds;
an
emission
standard
that
implicitly
considers
chlorine
feed
control
for
hydrochloric
acid
production
furnaces
would
be
inappropriate
because
chlorinated
wastes
are
these
sources'
feedstock
from
which
they
recover
hydrochloric
acid
as
a
product.

 
Option
B:
Stakeholder
Recommended
Approach
o
Same
as
Option
A,
but
uses
a
slightly
revised
methodology
for
the
standards
that
were
calculated
using
the
double
ranking
approach:
we
call
this
approach
the
"
triple
ranking
approach"


The
revised
methodology
was
recommended
by
a
stakeholder
group
that
represents
commercial
incinerators

It
is
identical
to
the
double
ranking
methodology
previously
discussed,
except
each
sources
emissions
are
added
as
a
third
ranking
factor

We
requested
comment
on
this
approach
in
a
recent
notice
that
was
sent
to
key
stakeholders;
all
commenters
ultimately
opposed
the
approach
 
Option
D:
Straight
Emissions
Approach
o
Defines
best
performers
as
those
sources
with
the
lowest
emissions
in
our
database
for
all
pollutants
o
Technically
inappropriate
and
harder
to
defend
than
Option
C
for
a
few
standards
(
for
reasons
given
in
previous
Option
C
discussion)

Comparing
Floor
Options
A
and
C
 
Attachment
B
summarizes
the
difference
between
the
Option
A
and
Option
C
floor
levels
 
Attachment
C
summarizes
the
market
adjusted
costs
for
each
source
category
and
each
option
7
o
Market
adjusted
costs
account
for
market
exits,
waste
diversions
and
price
impacts
o
Compliance
costs
and
emission
reductions
assume
all
source
categories
eligible
for
alternative
risk­
based
chlorine
standards
pursuant
to
the
112(
d)(
4)
provisions
will
not
incur
any
costs
for
chlorine
control
upgrades

112(
d)(
4)
standards
are
risk­
based
standards
for
threshold
pollutants
which
assure
that
there
will
not
be
exposure
to
the
threshold
level
o
The
total
net
cost
line
(
the
upper
line
in
the
plot)
also
accounts
for
price
impacts
to
pre­
existing
customers
of
commercial
hazardous
waste
burners
o
Liquid
fuel
boilers
have
substantially
higher
costs
than
others

This
is
expected
given
that
this
is
their
first
MACT
standard,
and
given
that
they
represent
39%

(
104)
of
the
sources
affected
by
this
rule
(
267)

o
Commercial
incinerators
and
lightweight
aggregate
kilns
are
expected
to
experience
net
revenues
(
i.
e.,

profits)
under
options
A
and
C;
cement
kilns
are
expected
to
experience
net
revenues
under
Option
A
o
Option
C
has
higher
net
costs
than
Option
A,
although
the
difference
in
cost
not
including
hazardous
waste
generators
(
i.
e.,
pre­
existing
customers)
is
not
substantial

Option
A
is
projected
to
result
in
33
market
exits
(
1
commercial
incinerator,
22
onsite
incinerators,

and
10
liquid
fuel
boilers),
and
Option
C
is
predicted
to
result
in
one
additional
market
exit

Market
exits
for
onsite
incinerators
and
boilers
do
not
result
in
facility
closures;
the
facility
rather
sends
its
waste
to
an
offsite
commercial
hazardous
waste
combustor
for
treatment
 
Attachment
D
summarizes
emission
reductions
and
cost
effectiveness
for
each
floor
option
o
Option
A
gets
2
tons/
year
less
hazardous
air
pollutant
emissions
reductions
compared
to
Option
C,
and
is
slightly
more
cost
effective
8

The
difference
in
emission
reduction
is
relatively
small
given
the
reductions
for
all
pollutants
under
Option
A
is
1709
tons
per
year
(
mostly
attributable
to
particulate
matter)

Why
is
Option
A
Our
Recommended
Floor
Option?

 
Option
A
identifies
best
performers
by
identifying
and
assessing
how
pollutant
emissions
are
controlled
­
hazardous
waste
feed
control
and
back­
end
control
o
Option
A
methodology
preserves
the
opportunity
for
sources
to
use
either
feed
control
or
back­
end
control
to
comply
with
the
floor
standards
o
The
double
ranking
methodology
accomplishes
this
by
assessing
both
feed
control
and
back­
end
control
in
the
ranking
process;
in
doing
so
it
avoids
the
following
problematic
outcomes
that
otherwise
would
occur
if
we
were
to
use
the
Option
C
"
straight
emissions"
methodology:


Emission
standards
could
be
driven
by
low
hazardous
waste
feeders
­
this
is
undesirable
because
it
is
similar
to
prohibiting
the
amount
of
feedstock
to
a
production
unit;
prohibiting
the
burning
of
hazardous
waste
is
also
undesirable
given
treatment
requirements
under
RCRA
land
ban

Emission
standards
could
be
driven
by
the
best
back­
end
controlled
units
 
this
would
be
prohibitive
of
feed
control

Emission
standards
could
be
driven
by
both
the
best
back­
end
controlled
units
and
the
best
feed
controlled
units
­
this
is
problematic
because
the
standard
would
not
reflect
the
range
of
emissions
from
the
best
performing
feed
control
sources
and
best
controlled
back­
end
controlled
units
9
 
Option
A
best
deals
with
the
issue
of
deriving
standards
which
must
be
achieved
continuously
(
either
in
stack
tests
or
by
parametric
monitoring),
given
our
data
is
comprised
of
emissions
tests
that
are
"
snapshots"
in
time
o
Industry
has
commented
that
even
though
we
apply
a
statistical
variability
factor
to
the
compliance
test
emissions
when
calculating
the
floor
levels,
we
still
have
not
adequately
accounted
for
emissions
variability,
claiming
the
MACT
floors
are
not
achievable
by
the
best
performing
sources
o
We
believe
(
and
have
empirical
support)
that
there
is
further
variability
which
is
not
fully
reflected
by
our
various
statistical
protocols
for
assessing
variability,
nor
is
it
fully
captured
by
use
of
compliance
test
data.

The
double
ranking
approach
is
a
surrogate
for
this
known
but
not
directly
quantifiable
variability.

o
Use
of
the
Option
C
methodology
could
increase
the
likelihood
that
we
are
identifying
best
performing
sources
that
are
operating
at
the
low
end
of
their
emissions
variability
range,
given
the
methodology
simply
selects
the
lowest
emitting
sources
 
Option
A
reduces
the
likelihood
of
that
happening
given
emissions
are
not
directly
assessed
in
the
selection
of
best
performers
 
Although
not
legally
germane
(
and
hence
not
a
ground
for
decision),
Option
A
produces
floor
levels
that
have
been
determined
to
be
generally
protective
for
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
o
Option
A
yields
emission
standards
that
are
equivalent
to,
or
more
stringent
than,
the
interim
standards
that
are
applicable
to
these
source
categories

Although
Option
A
results
in
a
few
instances
where
the
calculated
floor
levels
are
higher
than
the
interim
standards,
in
such
instances
we
"
cap"
the
floor
at
the
interim
standard
level
because
these
10
sources
are
currently
achieving
those
levels.
Thus,
we
do
not
allow
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
to
backslide
from
existing
emission
standards

Note
that
this
"
no
backsliding"
concept
would
apply
to
all
options
considered,
and
that
all
floor
options
have
instances
where
the
floor
values
would
be
"
capped"
at
the
interim
standards
level
o
The
interim
standards
were
not
significantly
different
than
the
emission
standards
promulgated
in
1999,

which
we
determined
to
be
generally
protective
of
human
health
and
the
environment
after
we
conducted
a
comprehensive
risk
assessment
Summary
of
Beyond­
the­
Floor
Options
That
Were
Under
Consideration
 
EPA
must
also
determine
if
standards
more
stringent
than
the
floor
are
achievable,
and
must
consider
costs,
energy
use,
and
non­
air
health
and
environmental
impacts
in
making
this
determination
o
We
call
these
beyond­
the­
floor
(
BTF)
standards
 
We
considered
three
beyond­
the­
floor
options
for
new
and
existing
sources
o
Beyond­
the­
Floor
Option
A
(
Selected
Beyond­
the­
Floor
Option)


Would
establish
more
stringent
dioxin/
furan
standards
for
liquid
fuel
boilers
with
dry
air
pollution
control
devices
(
APCDs),
and
more
stringent
particulate
matter
standards
for
solid
fuel
boilers
o
Beyond­
the­
Floor
Option
B:
Includes
the
same
beyond­
the­
floor
standards
included
in
Option
A
above,

but
adds
the
following:


More
stringent
dioxin/
furan
standards
for
lightweight
aggregate
kilns,
hydrochloric
acid
production
furnaces,
and
liquid
fuel
boilers
with
wet/
no
air
pollution
control
systems
11
o
Beyond­
the­
Floor
Option
C:
Includes
the
same
beyond­
the­
floor
standards
included
in
Option
B
above,

but
adds
the
following:


More
stringent
total
chlorine
standards
for
lightweight
aggregate
kilns
and
solid
fuel
boilers
 
See
Attachment
F
for
a
summary
of
the
beyond­
the­
floor
levels,
incremental
costs,
cost
effectiveness,
and
emission
reductions
associated
with
the
above
assessed
beyond­
the­
floor
options
 
Why
did
we
select
Beyond­
the­
Floor
Option
A?

o
Standards
have
reasonable
cost­
effectiveness

For
existing
sources,
$
630K
per
gram
of
additional
dioxin
emission
reduction
and
$
2,600
per
ton
of
additional
particulate
matter
reduction
o
We
proposed
these
standards
for
existing
sources;
no
commenters
opposed
these
standards

Although
we
did
not
propose
a
new
source
beyond­
the­
floor
standard
for
the
liquid
fuel
boilers,
we
requested
comment
on
going
beyond­
the­
floor
and
received
no
adverse
comment
o
Would
reduce
high
floor
emission
levels
consistent
with
other
similar
source
categories

Liquid
fuel
boiler
dioxin/
furan
existing
source
floor
of
3.3
ng
TEQ/
dscm
would
be
reduced
to
0.40

Helps
avoid
need
to
use
RCRA
omnibus
authority
to
lower
dioxin/
furan
emissions

Low
annualized
cost
 
adds
only
an
additional
$
1
million
to
the
cost
of
the
floor
 
Why
Did
We
Not
Select
Beyond­
the­
floor
Option
B?

o
Not
as
cost
effective
as
Option
A

Cost
effectiveness
for
lightweight
aggregate
kilns,
boilers,
and
hydrochloric
acid
production
furnaces
are
$
2.5,
$
4,
and
$
6.6
million
per
gram
of
additional
dioxin
emission
reduction,

respectively
12
o
Although
we
proposed
beyond­
the­
floor
standards
for
lightweight
aggregate
kilns
and
hydrochloric
acid
production
furnaces,
the
cost
effectiveness
was
much
better
at
proposal

$
0.95
and
$
0.8
million
per
gram
of
additional
dioxin
reduction
for
lightweight
aggregate
kilns
and
hydrochloric
acid
production
furnaces,
respectively
 
Why
Did
We
Not
Select
Beyond­
the­
Floor
Option
C?

o
Cost
effectiveness
numbers
are
in
the
"
gray
area"
of
what
EPA
has
considered
to
be
cost
effective
for
hydrogen
chloride/
chlorine
gas

$
5,300
and
$
3,200
per
ton
of
additional
hydrogen
chloride/
chlorine
gas
emission
reduction
for
lightweight
aggregate
kilns
and
solid
fuel
boilers,
respectively
o
There
are
little
health
benefits
associated
with
the
chlorine
reductions

There
would
be
ecological
benefits
with
the
chlorine
reductions
and
significant
health
benefits
associated
with
collateral
particulate
sulfate
reductions
13
incinerator
(
final)
For
dry
APCD
or
WHB,
0.30
or
0.20
if
APCD
>
400F;
0.40
for
others
130
0.013
200
92
57
incinerator
(
prop)
For
dry
APCD
or
WHB:
0.28;
For
others
:
0.2
or
0.4
and
temp
control
at
inlet
of
APCD
<
400F
130
0.015
59
84
1.5
incinerator
(
interim
std)
0.2
or
0.40
and
temp
control
<
400
°
F
at
APCD
inlet
­

all
sources
(
beyond­
the­
floor
for
waste
heat
boilers)
130
0.015
240
97
77
Cement
Kiln
(
final)
0.2
or
0.40
and
temp
control
<
400
°
F
at
APCD
inlet
3.0
ppmw
(
HW
feed)
AND
120
ug/
dscm
(
HW
MTEC
feed
restriction)
or
120
ug/
dscm
(
total
emissions)
0.028
330
and
7.6E­
04
[
700]
2.2
E­
5
[
20]
120
Cement
Kiln
(
prop)
0.2
or
0.40
and
temp
control
<
400
°
F
at
APCD
inlet
64
N
(
total
emissions)
0.028
4.00E­
04
1.4E­
05
110
Cement
Kiln
(
interim
std)
0.2
or
0.40
and
temp
control
<
400
°
F
at
APCD
inlet
120
total
emissions
or
120
HW
MTEC
feed
restriction
0.03
­
0.05
330
56
130
LWAK
(
final)
0.20
or
RQ<
400F
120
HW
MTEC
feed
restriction
or
120
total
emissions
0.025
250
and
3.0E­
4
[
340]
110
and
9.5E­
5
[
110]
600
LWAK
(
prop)
0.40
67N
(
total
emissions)
0.025
250
and
3.1E­
4
110
and
9.5E­
5
600
LWAK
(
interim
std)
0.20
or
RQ<
400F
120
total
emissions
or
120
HW
MTEC
feed
restriction
0.025
250
110
600
SFB
(
final)
Carbon
Monoxide/
total
hydrocarbon
(
surrogate)
11
0.030
180
380
440
SFB
(
prop)
Carbon
Monoxide/
total
hydrocarbon
(
surrogate)
10
0.030
170
210
440
LFB
(
final)
0.4
for
dry
apcds;
Carbon
Monoxide/
total
hydrocarbon
(
surrogate)
for
others
10N
or
1.5E­
5N
[
18]
0.035
26N
or
2.5E­
5N
[
30]
160
or
1.6E­
4
[
190]
­

chrome
only
56
or
140E­
3
[
120]

LFB
(
prop)
0.4
for
dry
apcds;
Carbon
Monoxide/
total
hydrocarbon
(
surrogate)
for
others
3.7E­
6N
0.032
1.1E­
5
N
1.1E­
4
(
chrome
only)
2.5
E­
2
HCl
PF
(
final)
Carbon
Monoxide/
total
hydrocarbon
(
surrogate)
150
or
99.923SRE
HCl
PF
(
prop)
0.4
14
or
99.9927
E­
5
N
[
XX]
LWAK
stands
for
lightweight
aggregate
kiln,
LFB
for
liquid
fuel
boiler,
SFB
for
solif
fuel
boiler,
and
HCL
PF
for
hydrochloric
acid
production
furnace
SRE
=
system
removal
efficiency,
a
measure
of
control
device
operating
efficiency
APCD
stands
for
air
pollution
control
device
HW
MTEC
stands
for
hazardous
waste
maximum
theoretical
emission
concentration,
which
is
a
feed
restriction
normalized
by
combustor
size
Attachment
A:
Comparison
of
Final
Rule,
Proposed,
and
Interim
Standards:
Existing
Sources
Total
chlorine
as
surrogate
Source
Category
For
final
satandards,
a
number
in
brackets
is
the
mass
concentration
equivalent
(
ug/
dscm)
of
a
thermal
emission
Floor
assuming
the
source
fulfills
100%
of
its
energy
demand
from
the
hazardous
waste.

Notes
Standards
in
bold
reflect
beyond­
the­
floor
standards
Dioxin/
Furans
(
ng
TEQ/
dscm)
Mercury
(
ug/
dscm,
or
lb/
MMBtu)
Particulate
Matter
(
gr/
dscf)

Total
chlorine
as
surrogate
N
refers
to
a
metal
hazardous
air
pollutant
Floor
calculated
using
Normal
data.
Compliance
with
Normal­
based
Floors
will
be
implemented
by
a
long­
term
average
(
e.
g.,
month
or
year)
limit
on
feedrate.

Scientific
Notation.
Thermal
emissions
are
presented
in
scientific
notation
and
expressed
as
lb/
MM
Btu
(
lb
of
hazardous
air
pollutant
attributable
to
hazardous
waste
per
million
Btu
of
heat
input
from
hazardous
waste)
Semi
Volatile
Metals
(
ug/
dscm,

or
lb/
MMBtu)
Low
Volatile
Metal
(
ug/
dscm,
or
lb/
MMBtu)
Total
Chlorine
(
ppmv
or
lb/
MMBtu)
14
incinerator
(
final)
0.11
for
dry
APCD
and/
or
WHB;
0.20
for
others
8.1
0.0015
10
23
3.2
incinerator
(
prop)
0.11
for
dry
APCD
and/
or
WHB;
0.20
for
others
8.0
0.0007
6.5
8.9
0.18
inc
(
interim
std)
0.2
­
all
sources
(
was
beyond­
the­
floor
standard
for
waste
heat
boilers)
45
0.0150
120
97
21
Cement
Kiln
(
final)
0.2
or
0.40
and
temp
control
<
400
°
F
at
APCD
inlet
1.9
ppmw
(
HW
feed)
AND
120
ug/
dscm
(
HW
MTEC
feed
restriction)
or
120
ug/
dscm
(
total
emissions)
0.0023
6.2
E­
5
[
57]
1.5E­
5
[
14]
86
Cement
Kiln
(
prop)
0.2
or
0.40
and
temp
control
<
400
°
F
at
APCD
inlet
35
N
(
total
emissions)
0.0058
6.2
E­
05
1.4E­
05
78
CK
(
interim
std)
0.2
or
0.40
and
temp
control
<
400
°
F
at
APCD
inlet
120
total
emissions
or
120
HW
MTEC
feed
restriction
0.03
­
0.05
180
54
86
LWAK
(
final)
0.20
or
rapid
quench<
400F
120
total
emissions
or
120
HW
MTEC
feed
restriction
0.0098
43
and
3.7E­
5
[
42]
3.2
E­
5
[
36]
600
LWAK
(
prop)
0.40
67N
(
total
emissions)
0.0099
43
and
2.4
E­
05
3.2E­
05
and
110
600
LWAK
(
interim
std)
0.20
or
rapid
quench<
400F
120
total
emissions
or
120
HW
MTEC
feed
restriction
0.0250
43
110
600
SFB
(
final)
Carbon
monoxide/
total
hydrocarbon
(
surrogate)
11
0.015
180
190
73
SFB
(
prop)
Carbon
monoxide/
total
hydrocarbon
(
surrogate)
10
0.015
170
190
73
LFB
(
final)
0.4
for
dry
apcds;
Carbon
monoxide/
total
hydrocarbon
(
surrogate)
for
others
1.4N
OR
1.2E­
6N
[
1.4]
0.0087
4.7N
or
6.2E­
6N
[
7.4]
12
or
3.9E­
5
[
47]

(
chrome
only)
1.3
or
7.2E­
4
[
1.2]

LFB
(
prop)
0.015
or
temp
control
<
400F
for
dry
apcds;
Carbon
monoxide/
total
hydrocarbon
for
others
3.80E­
07
0.0076
4.3
E­
6
N
3.6
E­
5
(
chrome
only)
7.20E­
04
HCl
PF
(
final)
Carbon
monoxide/
total
hydrocarbon
(
surrogate)
25
or
99.987
SRE
HCL
PF
(
prop)
0.4
1.2
or
99.9994
SRE
E­
5
N
[
XX]
SRE
=
system
removal
efficiency,
a
measure
of
control
device
operating
efficiency
APCD
stands
for
air
pollution
control
device
Attachment
A
Continued:
Comparison
of
Final
Standards,
Proposed
Standards,
and
Interim
Standards:
New
Sources
For
the
Final
Standards,
a
number
in
brackets
is
the
mass
concentration
equivalent
(
ug/
dscm)
of
a
thermal
emission
Floor
assuming
the
source
fulfills
100%
of
its
energy
demand
from
the
hazardous
waste.

Source
Category
Dioxin/
Furans
(
ng
TEQ/
dscm)
Total
Chlorine
(
ppmv
or
lb/
MMBtu)

Standards
in
Bold
Represent
Beyond­
the­
Floor
Standards
Mecury
(
ug/
dscm,
or
lb/
MMBtu)

HW
MTEC
stands
for
hazardous
waste
maximum
theoretical
emission
concentration,
which
is
a
feed
restriction
normalized
by
combustor
size
Notes
Particulate
Matter
(
gr/
dscf)
Semi
Volatile
Metals
(
ug/
dscm,

or
lb/
MMBtu)
Low
Volatile
Metals
(
ug/
dscm,

or
lb/
MMBtu)

N
refers
to
a
metal
hazardous
air
pollutant
Floor
calculated
using
Normal
data.
Compliance
with
Normal­
based
Floors
will
be
implemented
by
a
long­
term
average
(
e.
g.,

month
or
year)
limit
on
feedrate.
Total
Chlorine
as
surrogate
Scientific
Notation.
Thermal
emissions
are
presented
in
scientific
notation
and
expressed
as
lb/
MM
Btu
(
lb
of
hazardous
air
pollutant
attributable
to
hazardous
waste
per
million
Btu
of
heat
input
from
hazardous
waste)
Total
Chlorine
as
surrogate
LWAK
stands
for
lightweight
aggregate
kiln,
LFB
for
liquid
fuel
boiler,
SFB
for
solif
fuel
boiler,
and
HCL
PF
for
hydrochloric
acid
production
furnace
15
Attachment
B
 
Difference
in
Floor
Standards
Across
Options
A,
B,
and
C
Semivolatile
metals
(
ug/
dscm,
or
lb/
MMBtu)
Low
volatile
metals
(
ug/
dscm,
or
lb/
MMBtu)
Total
Chlorine
(
ppmv,
or
lb/
MMBtu)

A
200
92
57
B
49
71
did
not
calculate
C
22
21
did
not
calculate
A
7.6
E­
4
[
700]
and
330
2.2E­
5
[
20]

B
3.1E­
4
[
280]
and
330
1.8E­
5
[
16]

C
1.3E­
4
[
120]
1.4E­
5
[
13]

A
160
or
1.6E­
4
[
190]
(
chrome
only)
56
or
140E­
3
[
120]

B
160
or
1.6E­
4
[
190]
(
chrome
only)
did
not
calculate
C
29
or
1.2E­
4
[
140]
(
chrome
only)
did
not
calculate
Semivolatile
metals
(
ug/
dscm,
or
lb/
MMBtu)
Low
volatile
(
ug/
dscm,
or
lb/
MMBtu)
Total
chlorine
(
ppmv,
or
lb/
MMBtu)

A
10
23
3.2
B
10
23
did
not
calculate
C
5.3
3.5
did
not
calculate
A
6.2E­
5
[
57]
1.5E­
5
[
14]

B
6.2E­
5
[
57]
1.8E­
6
[
1.6]

C
4.2E­
5
[
38]
1.8E­
6
[
1.6]

A
12
or
3.9E­
5
[
47]
(
chrome
only)

B
19
or
1.1E­
5
[
13]
(
chrome
only)

C
19
or
1.1E­
5
[
13]
(
chrome
only)

[
XX]

E­
5
Differences
in
Floors
for
Existing
Sources:
Options
A
vs
B
vs
C
Incinerators
Incinerators
Cement
kilns
Liquid
fuel
boilers
Cement
Kilns
Floor
Floor
Option
Floor
Floor
Liquid
fuel
boilers
Differences
in
Floors
for
New
Sources:
Options
A
vs
B
vs
C
A
number
in
brackets
is
the
mass
concentration
equivalent
(
ug/
dscm)
of
a
thermal
emission
Floor
Scientific
Notation.
Thermal
emissions
are
presented
in
scientific
notation
and
expressed
as
lb/
MM
Btu
(
lb
of
hazardous
air
pollutant
attributable
to
hazardous
waste
per
million
Btu
of
heat
input
from
hazardous
waste)
16
Attachment
C:
Net
Costs
of
Floor
Options
Net
Costs
for
Floor
Options,
w/
o
TCl
(
4­
19)
54.7
36.9
27.4
26.4
25.4
32.1
36.6
29.6
­
20.0
­
10.0
0.0
10.0
20.0
30.0
40.0
50.0
60.0
A:
Double
Ranking
C:
Straight
Emissions
w/

Exceptions
B:
Triple
Ranking
D:
Straight
Emissions
$

MM
Annualized
Cost
Commercial
INC
HCL
PF
SFB
Onsite
INC
LFB
LWAK
CK
Total
Net
Cost
Net
Cost
to
HWCs
17
Attachment
D:
Emission
Reductions
and
Cost
Effectiveness
Emission
Reductions
and
Cost
Effectiveness,
w/
o
TCl
(
4­
19)

[
CE
includes
PM
reductions
of
1,700
tpy
for
A
thru
C
and
3,000
tpy
for
D]

[
PM
reductions
and
D/
F
reductions
(
0.34
g
TEQ)
not
shown]

5.6
5.7
5.7
7.6
2.4
4.3
4.3
5.7
21,000
20,000
22,000
25,000
0
2
4
6
8
10
12
14
16
A:
Double
Ranking
C:
Straight
Emissions
w/

Exceptions
B:
Triple
Ranking
D:
Straight
Emissions
Emissions
Reductions
(

TPY)
0
5,000
10,000
15,000
20,000
25,000
30,000
Cost­

Effectiveness
($/

ton)
Hg
SVM
LVM
Cost
per
Ton
18
Attachment
E
 
Summary
of
Beyond­
the­
Floor
Options
BTF
Options
for
Existing
Sources
(
4­
19)

BTF
A
BTF
B
BTF
C
LFB
SFB
LWAK
LFB
HCl
PF
LWAK
SFB
D/
F
for
Dry
APCD
PM
D/
F
D/
F
for
Wet/
No
APCD
D/
F
TCl
TCl
Floor
Level
3.3
ng
TEQ/
dscm
or
400T
[
2.4]
0.074
gr/
dscf
[
6.1
ng
TEQ/
dscm]
[
1.4
ng
TEQ/
dscm]
[
0.52
ng
TEQ/
dscm]
600
ppmv
440
ppmv
BTF
Level
0.40
ng
TEQ/
dscm
0.03
gr/
dscf
0.40
ng
TEQ/
dscm
0.40
ng
TEQ/
dscm
0.40
ng
TEQ/
dscm
150
ppmv
110
ppmv
BTF
Technology
AC
(
activated
carbon)
Moderate
DOM
1
AC/
FF
AC/
FF
AC
Dry
Scrubber
Dry
Scrubber
Cost­
Effectiveness,

before
Closures
$
630,000/
gram
$
2,600/
ton
$
2,500,000/
gram
$
4,000,000/
gram
$
6,600,000/
gram
$
5,300
$
3,200


Emission
Reductions
0.06
470
tpy
0.9
g/
yr
0.3
g/
yr
0.1
g/
yr
270
tpy
800
tpy


Annualized
Cost,

before
Closures
($
MM)
0.38
1.2
2.2
1.2
0.58
1.4
2.5
BTF
Recommendations
for
New
Sources
LFB
SFB
D/
F
for
Dry
APCD
PM
Floor
Level
0.024
ng
TEQ/
dscm
or
400T
[
2.4]
0.061
gr/
dscf
BTF
Level
0.40
ng
TEQ/
dscm
0.015
BTF
Technology
AC
(
activated
carbon)
FF
Cost­
Effectiveness
for
Average
Source
$
120,000/
gram
TEQ
$
5,000/
ton


Emission
Reductions
for
Average
Source
1.2
gram
TEQ
60
tpy


Annualized
Cost
for
Average
Source
($
MM)
$
150,000
$
300,000
1
Moderate
modification
to
design,
operation,
or
maintenance
of
existing
ESP
or
FF
[
]
Emission
level
allowed
at
the
floor.
There
is
no
numerical
floor
limit.
19
Attachment
F:
Background
Information
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
20
Estimated
annual
hazardous
waste
generation:
40,821,481
U.
S.
tons
Source:
Biennial
reporting
system
(
2001
data)

Estimated
Total
Annual
Hazardous
Waste
Generation
U.
S.
Tons
Total,
Excluding
Combusted
HW,
37,049,591
Combusted
Hazardous
Waste,
3,771,890
21
Total
2001
quantity
combusted:
3,771,890
U.
S.
tons
Source:
Biennial
reporting
system
(
2001
data,
adjusted)

Estimated
Annual
Quantity
of
Hazardous
Waste
Combusted
U.
S.
Tons
Commercial
Incinerators
508,672
Captive
Incinerators
(
On­

Site)
1,232,534
Commercial
Energy
Recovery
(
Cement
Kilns,

LWAKs)
1,057,917
Captive
Energy
Recovery
(
Liquid&
Coal
Boilers)

896,296
HAFs
76,471
22
Source:
OSW
Estimates
Total
Number
of
Hazardous
Waste
Burning
Sources
Potentially
Affected
by
Rule:
267
Hazardous
Waste
Burning
Sources
Commercial
Incinerators,
15
On­
Site
Incinerators,
92
Cement
Kilns,
25
LWAKs,
9
Coal
Fired
Boilers,
12
Liquid
Fired
Boilers,
104
HCL
Production
Furnaces,
10
23
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))
are
not
only
technology­
based,
but
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
non­
air
health
and
environmental
impacts
in
making
this
determination.
Standards
issued
pursuant
to
this
authority
are
called
`
beyond­
the­
floor'.
24

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

Promulgated
MACT
standards
for
hazardous
waste
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
in
1999
o
Estimated
total
annualized
costs
to
comply
with
rule:
$
50­
63
million
o
Estimated
total
annualized
human
health
benefits:
$
19
million
o
Industry
and
environmental
groups
litigated

Court
Decision
o
On
July
24,
2001,
DC
Circuit
Court
granted
Sierra
Club's
Petition
for
Review
­
Vacated
the
challenged
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"

o
Court
opinion
left
door
open
for
negotiated
interim
standards

Negotiated
Interim
Standards
25
o
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:

­
­
Relax
10
of
the
48
promulgated
emission
standards
­
­
Delay
the
compliance
date
one
year
­
­
Relax
several
compliance/
implementation
requirements
­
Entered
into
consent
decree
(
which
is
judicially
enforceable)
which
required
us
to
issue
final
rule
by
June
14,
2005

We
were
also
on
a
court
enforceable
schedule
to
issue
MACT
standards
for
hazardous
waste
boilers
and
hydrochloric
acid
production
furnaces
no
later
than
June
14,
2005
­
Result
of
broader
consent
decree
between
OAQPS
and
Sierra
Club
that
addresses
enforceable
schedules
for
the
MACT
rules
that
have
not
been
promulgated
on
time
(
in
accordance
with
statutory
deadlines)
