1
Hazardous
Waste
Combustor
MACT
Standards
Final
Rule
Briefing
for
OMB
August
22,
2005
Scope
 
Background/
General
Status
Update
 
Summary
of
Floor
Methodologies
Used
to
Develop
the
Final
Standards
 
Comparison
of
Alternative
MACT
Floor
Methodologies
Options
to
Final
Rule
Floor
Option
 
Why
are
the
Final
Rule
Methodologies
Preferred
Relative
to
the
Alternative
Floor
Options?

 
Summary
of
Beyond­
the­
Floor
Options
That
Were
Under
Consideration
 
Summary
of
Final
Rule
Cost
and
Benefits
 
Summary
of
Other
Key
Issues

Site
Specific
Risk
Assessment

CAA
112(
D)(
4)
Health
Based
Limits
For
Hydrogen
Chloride
And
Chlorine
Gas

Use
of
Data
From
Sources
That
Have
Upgraded
to
Comply
With
MACT
Emission
Standards
That
Have
Already
Been
Promulgated

Standards
Can
be
No
Less
Stringent
Than
the
Interim
MACT
Standards

Summary
of
Stakeholder
Positions
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
 
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
filed
motions
with
both
courts
to
extend
the
completion
date
to
September
14,
2005.
Both
courts
have
granted
the
motions.

 
We
are
currently
on
track
to
have
final
rule
signed
no
later
than
September
14,
2005
 
Attachment
A
includes
a
summary
of
the
emission
standards
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
3
Summary
of
the
MACT
Floor
Methodologies
Used
to
Develop
Final
Standards
 
Key
issue
relative
to
standard
setting
procedures
o
MACT
standards
must
reflect
a
minimum
level
of
stringency,
known
as
the
"
Floor"

o
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)


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

This
is
somewhat
unique,
in
that
most
MACT
rules
for
combustion
units
assess
only
back­
end
control
o
For
cement
kilns,
lightweight
aggregate
kilns,
and
liquid
fuel
boilers,
we
normalize
metal
emission
standards
based
on
the
energy
content
of
the
hazardous
waste

These
so
called
`
thermal
emission
standards'
are
expressed
as
allowable
mass
emissions
of
pollutants
attributable
to
the
hazardous
waste
per
million
BTUs
hazardous
waste
fired
to
the
combustion
unit
 
Thus,
a
cement
kiln's
allowable
mass
emission
rate
(
e.
g.,
pounds
per
hour)
would
be
contingent
on
how
much
hazardous
waste
is
fired
to
displace
fossil
fuel
on
a
"
per
million
BTU
hazardous
waste
basis"


It
is
standard
practice
for
EPA
to
normalize
HAP
emissions
per
unit
of
raw
material
processed.
This
allows
performance
to
be
assessed
equally
across
sources
on
a
percent
control
efficiency
basis,

irrespective
of
the
size
of
the
production
unit
or
amount
of
raw
material
the
unit
processes
4
 
The
thermal
emissions
normalization
approach
does
this
by
linking
each
source's
allowable
emissions
to
the
amount
of
raw
material
it
processes
 
the
raw
material
being
the
energy
that
is
recovered
from
processing
the
hazardous
waste
 
Summary
of
Final
Rule
Methodologies:
We
generally
use
the
same
methodologies
to
calculate
the
floor
levels
that
were
proposed
(
exceptions
are
discussed
later
in
this
section)

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
"
SRE/
Feed
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

Best
performers
are
those
sources
with
the
best
aggregate
score
(
or
those
representing
the
top
12%

of
the
aggregated
scores
in
instances
where
there
are
30
or
more
sources)


The
floor
standards
are
equivalent
to
the
average
of
the
emission
levels
of
these
sources
with
a
variability
factor
added.
The
lowest
emitters
may
(
in
some
cases)
not
be
considered
a
`
best
performing'
source
because
their
aggregated
score
may
not
be
among
the
best.

o
For
particulate
matter,
we
define
best
performing
sources
as
those
with
the
best
back­
end
air
pollution
control
units
solely
(
e.
g.,
those
sources
equipped
with
baghouses).
We
call
this
methodology
the
"
APCD
Approach"


Identical
to
methodology
used
in
Industrial
Boiler
MACT
rule
5

Feed
control
is
not
assessed
as
a
MACT
control
technique
for
PM,
primarily
because
ash
feed
control
does
not
always
assure
metal
HAP
emissions
are
reduced
to
levels
consistent
with
MACT,

whereas
back­
end
control
always
assures
sources
remove
a
given
percentage
of
metal
HAP
that
is
processed
in
the
combustor

Floor
standards
are
equivalent
to
the
average
emission
levels
from
a
group
of
sources
that
are
representative
of
12
percent
of
the
source
category
that
are
equipped
with
the
best
type
of
air
pollution
control
devices
(
with
a
variability
factor
added)

o
For
the
total
chlorine
standard
for
hydrochloric
acid
production
furnaces,
we
define
best
performing
sources
as
those
with
the
best
demonstrated
back­
end
control
efficiency,
as
determined
by
each
source's
total
chlorine
system
removal
efficiency,
which
is
a
measure
of
the
amount
of
chlorine
that
is
emitted
relative
to
the
amount
that
is
processed
in
the
combustor.


Feed
control
is
not
assessed
as
a
MACT
control
technique
because
chlorine
feed
control
would
improperly
limit
these
sources
feedstock,
which
is
chlorine
o
For
Dioxin/
Furans,
we
define
best
performing
sources
as
those
with
the
lowest
emissions

Dioxin/
Furans
are
not
feed
controlled
pollutants
­
they
are
predominately
formed
post
combustion
in,
for
instance,
dry
air
pollution
devices
or
waste
heat
boilers

For
subcategories
equipped
solely
with
wet
air
pollution
control
systems
(
or
no
air
pollution
control
system),
we
do
not
establish
a
numerical
dioxin/
furan
emission
limitation,
but
rather
establish
a
surrogate
standard
of
`
good
combustion
practices'
via
compliance
with
the
carbon
monoxide
or
hydrocarbon
standard,
as
well
as
the
destruction
and
removal
efficiency
standard
 
A
numerical
MACT
floor
for
these
sources
would
not
be
replicable
by
the
best
performing
sources
or
duplicable
by
other
sources
6
Substantive
Changes
That
Have
Been
Made
Relative
to
Proposed
Rule
Approaches
 
Revised
methodology
that
better
accounts
for
emissions
variability
when
calculating
the
floor
levels
from
data
that
includes
non­
detect
measurements
o
See
preamble
section
titled
"
Statistical
Imputation
to
Address
Variability
of
Nondetect
Values"

 
Revised
methodology
to
calculate
the
Hg
standard
for
lightweight
aggregate
kilns
that
better
accounts
for
mercury
fluctuations
in
their
waste
feeds
 
Revised
methodology
to
account
for
method
26
bias
for
total
chlorine
measurements
less
than
20
ppmv
o
Approach
adjusts
sources
emissions
to
20
ppmv
in
instances
where
they
have
measured
emissions
lower
than
20
ppmv
 
Subcategorization
of
liquid
fuel
boilers
based
on
the
energy
content
of
the
hazardous
waste
o
We
proposed
emission
standards
that
are
normalized
in
the
thermal
emissions
format
for
all
liquid
fuel
boilers
o
American
Chemistry
Council
(
ACC)
commented
that
thermal
emissions
unfairly
penalize
sources
that
burn
low
BTU
hazardous
wastes,
primarily
because
of
their
inability
to
blend
hazardous
waste
to
a
specified
BTU
content
(
as
is
done
at
cement
kilns
and
lightweight
aggregate
kilns).
ACC
requested
that
we
allow
sources
to
comply
with
emission
standards
that
are
normalized
either
on
a
mass
emission
concentration
format
or
a
thermal
emissions
format

We
are
finalizing
emission
standards
that
are
normalized
on
a
mass
emission
concentration
based
format
for
sources
that
combust
hazardous
waste
with
less
than
10,000
BTU/
lb;
and,


We
are
finalizing
emission
standards
that
are
normalized
on
a
thermal
emissions
basis
for
sources
that
combust
hazardous
waste
with
greater
than
10,000
BTU/
lb
7

We
believe
this
approach
is
responsive
to
ACC
concerns,
and
is
appropriate
because
sources
burning
hazardous
waste
with
energy
content
greater
than
10,000
BTU/
lb
are
primarily
processing
hazardous
waste
for
energy
recovery
purposes
Comparison
of
Alternative
MACT
Floor
Methodologies
Options
to
Final
Rule
Floor
Option
 
We
evaluated
two
other
MACT
floor
options
that
use
different
methodologies
to
calculate
the
MACT
floor
standards
 
Attachment
B
summarizes
the
differences
in
these
methodologies,
and
compares
the
social
costs
and
emission
reductions,
relative
to
final
rule
floor
 
Note
that
a
more
detailed
discussion
of
the
final
rule
cost
and
benefits
(
that
account
for
beyond
the
floor
standards)

is
presented
later
Why
Are
We
Promulgating
the
Final
Rule
Floor
Option?

 
The
final
rule
floor
option
identifies
best
performers
by
identifying
and
assessing
how
pollutant
emissions
are
controlled
­
hazardous
waste
feed
control
and
back­
end
control
 
The
final
rule
floor
option
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
8
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
SRE/
Feed
methodology
is
a
surrogate
for
this
known
but
not
directly
quantifiable
variability.

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
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
9
 
See
Attachment
C
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
Costs
are
Reasonable

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
beyond­
the­
floor
standard
for
new
liquid
fuel
boilers,
we
requested
comment
on
going
beyond­
the­
floor
and
received
no
adverse
comment
o
Will
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
will
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
$
4.9
million
per
gram
of
additional
dioxin
emission
reduction,

respectively
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
10

$
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
o
$
9,700
and
$
5,200
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
Summary
of
Final
Rule
Cost
and
Benefits
 
Attachment
D
includes
a
summary
of
the
number
of
affected
sources
subject
to
this
final
rule,
which
includes
estimated
quantities
of
hazardous
waste
processed
for
each
source
category
 
Numbers
in
(
)
reflect
a
net
revenue,
numbers
in
[
]
reflect
impacts
assuming
all
sources
incur
total
chlorine
retrofit
costs
to
comply
with
floor
standards
because
they
elect
to
not
implement
alternative
risk
based
112(
d)(
4)
emission
limitations
 
Total
Social
Costs:
$
22.6
[
28.6
]
million
per
year
 
Total
engineering
costs:
$
40.2
[
46.7
]
million
per
year
 
Estimated
Total
Market­
Adjusted
Cost
Impacts
by
Sector
(
million
dollars).

o
Cement
Kilns
($
0.1)
[(
0.5)]

o
LWAKs
($
0.2)
[(
0.2)]

o
Commercial
Incinerators
($
14.5)
[(
14.2)]
11
o
On­
Site
Incinerators
$
1.5
[
2.7]

o
Liquid
Boilers
$
29.3
[
33.1]

o
Solid
Boilers
$
2.0
[
2.3]

o
HCl
Production
Furnaces
$
0.6
[
0.6]

o
Generators
$
3.6
[
4.2]

 
Estimated
Economic
Impacts:

o
Market
Exits
(
systems)


Cement
Kilns
0
[
0]


Commercial
Incinerators
3
[
3]


LWAKs
0
[
0]


On­
Site
Incinerators
26
[
26]


Liquid
Boilers
8
[
8]


Coal
Boilers
2
[
2]


HCl
Production
Furnaces
0
[
0]

 
Quantity
of
Waste
Reallocated
(
U.
S.
tons)
58,900
[
58,900]

 
Employment
Impacts
o
Annual
Gains
323
[
375]
FTEs
o
Annual
Dislocations
310
[
310]
FTEs
 
Expected
Combustion
Price
Change
+
0.3%
[+
0.4%
]

 
Monetized
Benefits
(
million
dollars
per
year):

o
Non­
Discounted
Values:


PM
Related
Benefits
$
6.29

Dioxin
related
cancer
deaths
$
0.02
12
 
Sub­
total
Human
Health:
$
6.31

Visibility
Benefits
$
0.18
­
$
6.63

Total
Monetized
Benefits:
$
6.48
­
$
12.93
o
Discounted
Values
(
3
percent):


PM
Related
Benefits
$
5.95

Dioxin
related
cancer
deaths
$
0.01
 
Sub­
total
Human
Health:
$
5.96

Visibility
Benefits
$
0.18
­
$
6.63

Total
Monetized
Benefits:
$
6.13
­
$
12.58
o
Discounted
Values
(
7
percent):


PM
Related
Benefits
$
5.61

Dioxin
related
cancer
deaths
$
0.00
 
Sub­
total
Human
Health:
$
5.61

Visibility
Benefits
$
0.18
­
$
6.63

Total
Monetized
Benefits:
$
5.79
­
$
12.24
 
Non­
Monetized
Benefits:

o
Reduction
in
lead
exposure
to
below
10
ug/
dL
possible
for
fewer
than
seven
children
per
year.

o
Ecological
benefits
possible
 
Small
Entity
Impacts:

o
None
of
the
eight
small
businesses
impacted
by
this
final
rule
are
expected
to
incur
significant
economic
impacts
13
Summary
of
Other
Key
Issues
Site­
Specific
Risk
Assessment
Approach
 
The
final
rule
will
codify
the
authority
to
require
site­
specific
risk
assessments
(
SSRAs)
on
a
case­
by­
case
basis
and
add
conditions
to
RCRA
permits
based
on
SSRA
results
under
the
authority
of
RCRA
§
§
3004(
a)
and
(
q)
and
3005(
c).

 
We
believe
that
SSRAs
are
likely
to
continue
to
be
necessary
at
some
facilities
(
i.
e.,
mainly
those
that
have
not
previously
conducted
an
SSRA)
and
therefore,
we
are
finalizing
the
proposed
language
in
§
§
270.10(
l)
and
270.32(
b)(
3).
However,
modifications
have
been
made
to
§
270.10(
l)
to
provide
further
clarification
of
the
Agency's
intent
in
response
to
commenters'
major
concerns.

o
Section
270.10(
l)
has
been
revised
to
provide
more
detail,
both
with
respect
to
the
basis
for
the
determination
that
an
SSRA
is
necessary,
and
with
respect
to
the
type
of
information
the
permit
authority
might
need:

 
Language
has
been
added
to
remind
permit
authorities
that
the
determination
that
the
MACT
standards
may
not
be
sufficiently
protective
is
to
be
based
only
on
factors
relevant
to
the
potential
risk
from
the
hazardous
waste
combustion
unit
at
the
site;
and
 
Language
has
been
added
to
identify
guiding
factors
for
permitting
authorities
to
consult
in
determining
whether
the
MACT
will
be
sufficiently
protective
at
an
individual
site.

o
We
believe
that
the
new
provisions
are
beneficial
in
two
ways:
1)
they
provide
notice
to
the
regulated
community
and
public
that
an
SSRA
may
be
necessary
to
support
a
source's
permit;
and
2)
they
remind
the
permitting
agencies
of
the
importance
of
evaluating
whether
an
SSRA
would
be
necessary
on
a
site­
specific
basis.

CAA
112(
d)(
4)
Health
Based
Limits
for
Hydrogen
Chloride
and
Chlorine
Gas
 
We
are
finalizing
alternative
risk­
based
chlorine
standards
pursuant
to
the
CAA
112(
d)(
4)

o
112(
d)(
4)
standards
are
risk­
based
standards
for
threshold
pollutants
which
assure
that
there
will
not
be
exposure
to
the
threshold
level
14
 
Major
principles
used
to
implement
these
risk
based
standards
are
identical
to
those
used
in
the
Industrial
Boiler
MACT
Rule
 
The
minor
differences
between
the
procedures
used
in
this
final
rule
relative
to
the
Industrial
Boiler
Final
Rule
are
presented
in
Attachment
E
Use
of
Data
From
Sources
That
Have
Upgraded
to
Comply
With
MACT
Emission
Standards
That
Have
Already
Been
Promulgated
 
Even
though
we
are
promulgating
what
we
call
"
replacement
MACT
standards"
for
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
based
on
litigation
of
the
1999
final
rule,
these
sources
had
to
comply
with
the
negotiated
interim
MACT
standards
no
later
than
September,
2003.

 
For
this
final
rulemaking
effort,
we
have
updated
the
emissions
database
that
was
used
to
support
the
1999
final
NESHAPs
rule
for
hazardous
waste
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
 
Some
of
this
updated
data
is
from
sources
that
have
upgraded
their
facilities
to
achieve
the
emission
standards
promulgated
in
1999
(
and
subsequently
revised
in
the
February
2002
Interim
Standards
Final
Rule)

 
Industry
stakeholders
oppose
this,
and
refer
to
this
as
"
MACT­
on­
MACT,"
i.
e.,
establishing
MACT
floors
based
on
sources
that
already
upgraded
to
meet
promulgated
MACT
standards.

 
We
are
compelled
to
use
all
available
emissions
data
to
calculate
MACT
floors
because:

o
The
motivation
for
a
source's
performance
is
legally
irrelevant
in
developing
the
floors
o
The
Statute
indicates
that
EPA
is
to
base
MACT
floor
levels
on
performance
of
sources
"
for
which
the
Administrator
has
emissions
information"
15
Standards
Can
be
No
Less
Stringent
Than
the
Interim
MACT
Standards
for
Incinerators,
Cement
Kilns,
and
Lightweight
Aggregate
Kilns
 
In
instances
where
the
calculated
final
rule
floor
levels
are
higher
than
the
interim
standards,
we
"
cap"
the
floor
at
the
interim
standard
level
because
these
sources
are
currently
achieving
these
levels.

o
As
a
result,
these
final
rule
standards
ensure
that
sources
will
emit
HAP
at
levels
no
higher
than
levels
achieved
under
current
regulations
 
Industry
stakeholders
oppose
this,
stating
the
interim
standards
are
simply
placeholders
without
the
necessary
statutory
basis
to
qualify
as
emission
limitations
for
purposes
of
establishing
MACT
floors
o
We
are
compelled
to
use
the
binding
regulatory
limit
as
the
floor
in
these
instances
because
it
is
the
best
means
available
to
us
to
estimate
performance
 
Cement
kiln
and
lightweight
aggregate
kiln
emission
standards
that
are
expressed
in
units
of
thermal
emissions
(
pounds
of
allowable
pollutant
emissions
attributable
to
the
hazardous
waste
per
million
BTU
hazardous
waste
fired)
may
be
either
more
or
less
stringent
than
the
interim
emission
standards,
which
are
expressed
as
mass
of
allowable
emissions
from
all
feed
inputs
per
volume
of
combustion
gas.

o
For
this
final
rule,
these
sources'
allowable
mass
emission
concentrations
will
be
dependent
on
the
amount,

and
energy
content,
of
the
hazardous
waste
they
process
o
The
final
rule
specifies
that
these
sources
must
achieve
both
emission
limitations
16
 
CKRC
opposes
this
because
it
may
require
some
sources
to
simultaneously
comply
with
two
different
sets
of
emission
standards
and
operating
limits
o
Thermal
emissions
only
requires
the
monitoring
of
HAP
inputs
from
the
hazardous
wastes,
whereas
the
interim
standard
mass
emission
concentration
standards
require
the
monitoring
of
HAP
inputs
from
all
feedstreams
(
including
raw
material
and
coal)

o
We
do
not
consider
such
an
outcome
to
be
overly
burdensome
in
the
instances
where
this
may
result
because
kilns
are
currently
required
to
monitor
the
inputs
from
all
feedstreams
Summary
of
Stakeholder
Positions
 
Sierra
Club:
Represented
by
Earth
Justice
(
previous
winning
litigant)

o
Opposes
any
floor
methodology
other
than
a
straight
emissions
approach
that
does
not
use
statistics
to
account
for
emissions
variability;
contends
HAP
feed
control
in
nonhazardous
process
streams
must
be
accounted
for
in
MACT
floor
analysis;
opposes
thermal
emission
standard
format
 
Environmental
Technology
Council:
Represents
subset
of
commercial
incinerators
o
Opposes
thermal
emission
standards;
comments
focused
on
concerns
relating
to
achievability
of
existing
source
incinerator
SVM
emission
standard
 
Cement
Kiln
Recycling
Coalition:
Represents
cement
kilns
that
combust
hazardous
waste
o
Opposes
SSRA
approach,
supports
thermal
emissions
format,
believes
mercury
standard
should
be
based
on
long­
term
hazardous
waste
feed
concentration
data
(
final
rule
does
this),
opposes
concept
that
standards
can
be
no
less
stringent
than
the
interim
MACT
standards;
oppose
use
of
data
from
sources
that
have
upgraded
to
comply
with
MACT
emission
standards
that
have
already
been
promulgated
17
o
Will
oppose
new
source
particulate
matter
standard

New
source
standard
is
based
on
a
source
that
was
designed
to
achieve
the
new
source
particulate
matter
interim
standard
 
Coalition
for
Responsible
Waste
Incineration:
Represents
subset
of
incinerators,
boilers,
cement
kilns
and
hydrochloric
acid
production
furnaces;
overlapping
membership
with
other
stakeholders
o
Believes
standards
for
existing
sources
should
be
simultaneously
achievable
by
6%
of
the
sources;
believes
new
source
standards
should
be
simultaneously
achieved
by
at
least
one
existing
source

We
believe
that
MACT
standards
have
to
be
simultaneously
achievable
for
a
group
of
HAPs
in
situations
where
the
emission
controls
are
technically
interdependent,
i.
e.,
when
implementation
of
one
emission
control
technology
prevents
the
source
from
implementing
another
control
technology
 
This
is
not
the
case
for
the
group
of
HAPs
regulated
in
this
final
rule
o
Raised
several
data
quality
issues
in
comments
including:


Claiming
several
best
performing
sources
were
not
representative
of
other
sources
within
the
source
category
 
We
carefully
evaluated
these
comments
and
revised
the
database
as
appropriate

Handling
of
nondetect
emission
measurements
when
calculating
floor
levels
in
manner
that
does
not
dampen
the
emission
variability
assessment
(
we
have
accounted
for
this
through
use
of
the
statistical
imputation
procedures)


Method
26
bias
resulting
from
chlorine
measurements
below
20
ppmv
(
as
previously
discussed,
we
have
accounted
for
this),
and
raised
other
concerns
regarding
data
quality
relative
to
test
method
issues
 
American
Chemistry
Council:
Represents
subset
of
on­
site
incinerators,
boilers,
and
hydrochloric
acid
production
furnaces
at
chemical
and
petroleum
plants
18
o
Believes
we
lack
sufficient
data
to
establish
several
emission
standards
o
Supports
thermal
emissions
format;
however
opposes
the
proposed
requirement
for
all
liquid
fuel
boilers
to
comply
with
thermal
emission
standards
(
they
believe
sources
should
have
the
option
to
comply
with
emission
standards
that
are
expressed
either
in
thermal
or
mass
emission
concentration
format
because
several
boilers
process
hazardous
waste
with
relatively
lower
heating
values)

o
Opposes
proposed
dioxin/
furan
standards
for
incinerators
because
it
does
not
allow
sources
to
comply
with
the
standard
through
use
of
temperature
control
only

The
proposed
existing
source
emission
standard
was
0.28
ng
TEQ/
dscm
for
sources
equipped
with
dry
air
pollution
control
systems

Sources
that
use
temperature
control
to
comply
with
the
floor
standard
may
have
difficulty
achieving
the
floor

The
proposed
standard
did
not
account
for
this
achievability
concern
because
several
best
performing
sources
used
activated
carbon
to
control
emissions

This
is
no
longer
an
issue
because
database
changes
have
resulted
in
a
dioxin/
furan
floor
level
equivalent
to
the
interim
standards
for
existing
sources
 
Solite
Corporation:
Represents
two
of
the
three
lightweight
aggregate
kiln
facilities
o
Opposes
concept
that
standards
can
be
no
less
stringent
than
the
interim
MACT
standards;
believes
their
mercury
standard
should
be
based
on
long­
term
hazardous
waste
concentration
data
(
the
final
rule
uses
this
data);
opposes
any
beyond­
the­
floor
standard
for
dioxin/
furans
(
as
previously
discussed,
we
are
no
longer
going
beyond­
the­
floor
for
dioxin/
furans
for
this
source
category);
believes
MACT
floors
should
only
be
based
on
current
regulatory
limits
irrespective
of
the
levels
that
were
demonstrated
in
sources'
emission
tests
 
Federal
facilities
o
5
DOD
facilities
(
10
sources)
and
1
DOE
facility
19
o
Primarily
responsible
for
destroying
chemical
weapon
wastes
o
Primary
comment
was
sources
that
feed
de
minimis
levels
of
metals
or
chlorine
should
be
screened
out
from
the
MACT
analysis
prior
to
identifying
best
performers
o
Although
we
did
not
screen
sources
that
had
de
minimis
levels
of
metals
and
chlorine
from
the
MACT
analyses,
we
believe
that
the
SRE/
Feed
methodology
accommodates
this
concern
because
it
applies
equal
ranking
factors
to
front­
end
feed
control
and
back­
end
air
pollution
control
20
incinerator
(
final)
0.2
or
0.40
and
temp
control
<
400
°
F
at
APCD
inlet
130
0.013
230
92
32
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
either
120
ug/
dscm
(
HW
MTEC
feed
restriction)
or
120
ug/
dscm
(
total
emissions)
0.028
330
and
7.6E­
04
[
700]
2.1
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
1.2E­
6
lb/
MMBtu
or
6.8
ug/
dscm;

depending
on
BTU
content
of
hazardous
waste
0.035
6.2
E­
6
lb/
MMBtu
or
78
ug/
dscm;

depending
on
BTU
content
of
HW
1.41E­
5lb/
MMBtu
or
12
ug/
dscm;

depending
on
BTU
content
of
HW
5.08E­
2
lb/
MMBtu
or
31
ppmv;

depending
on
HW
BTU
level
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
99.92SRE
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)
21
incinerator
(
final)
0.11
for
dry
APCD
and/
or
WHB;
0.20
for
others
8.1
0.0015
10
23
21
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
either
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
and
180
1.5E­
5
and
54
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]
and
110
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
1.2E­
6
lb/
MMBtu
or
6.8
ug/
dscm;

depending
on
BTU
content
of
hazardous
waste
0.0087
6.2
E­
6
lb/
MMBtu
or
78
ug/
dscm;

depending
on
HW
BTU
content
1.41E­
5lb/
MMBtu
or
12
ug/
dscm;

depending
on
BTU
content
5.08E­
2
lb/
MMBtu
or
31
ppmv;
depending
on
BTU
content
of
hazardous
waste
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
22
Attachment
B
­
Comparison
of
the
Alternative
MACT
Floor
Options
to
the
Final
Rule
Floor
Approaches
Floor
Option
Features
Total
Social
Costs
($
MM/
yr)
Metal
HAP
Reductions
(
tons/
year)
PM
Reductions
(
tons/
year)
HCl/
Cl2
Reductions
(
tons/
year)

Alternative
Floor
Option
1
(
aka
Option
C)
For
metals
and
HCl/
Cl2,
defines
best
performers
as
those
with
the
lowest
emissions
rather
than
using
the
SRE/
Feed
approach
Closer
to
how
Sierra
Club
(
the
previous
winning
litigant)
believes
we
should
calculate
floors
(
relative
to
the
final
rule
floor
methodologies)
31.4
[
33.8]
1
11
1,670
106
[
900]
1
Alternative
Floor
Option
2
(
aka
Option
D)
Defines
best
performers
as
those
with
the
lowest
emissions
for
all
standards
Main
difference
from
Alternative
Option
1
is
HCl/
Cl2
floor
for
HCl
production
furnaces,
and
PM
floors
for
all
source
categories
are
calculated
using
the
straight
emissions
methodology,
and
emissions
for
energy
recovery
sources
are
normalized
using
mass
emission
concentrations
(
ug/
dscm)
rather
than
thermal
emissions
(
lb/
MM
Btu)

Closer
to
how
Sierra
Club
believes
we
should
define
best
performers
relative
to
Option
1,
but
they
would
still
oppose
this
option
b/
c
we
statistically
adjust
the
floor
levels
to
account
for
run­
to­
run
emissions
variability.
50.2
[
66.5]
1
16
3,000
126
[
3,600]
1
Final
Rule
Floor
For
metals
and
HCl/
Cl2,
defines
best
performers
using
SRE/
Feed
approach
For
PM,
defines
best
performers
using
the
APCD
approach
(
OAQPS
approach)

For
HCl
production
furnaces,
defines
best
performers
as
those
w/
the
best
system
removal
efficiency
(
SRE)

Uses
thermal
emission
concentrations
(
lb/
MM
Btu)
rather
than
mass
emission
concentrations
(
ug/
dscm)
for
energy
recovery
source
categories
Statistically
adjusts
floors
to
account
for
run­
to­
run
emissions
variability
21.9
[
27.8]
1
8.8
1,670
106
[
1220]
1
1
Numbers
in
[
]
reflect
impacts
assuming
all
sources
incur
total
chlorine
retrofit
costs
to
comply
with
floor
standards
because
they
elect
not
to
implement
alternative
health
based
112(
d)(
4)

emission
limitations
23
Attachment
C
 
Summary
of
Beyond­
the­
Floor
Options
BTF
Options
for
Existing
Sources:
Option
A
Selected
(
8­
18)

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
$
4,900,000/
gram
$
9,700
$
5,200


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)
0.038
1.2
2.2
1.2
0.58
2.6
4.4
BTF
Standards
Selected
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
$
150,000/
gram
TEQ
$
3,700/
ton


Emission
Reductions
for
Average
Source
1.0
gram
TEQ
82
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.
24
Attachment
D
­
Summary
of
Affected
Sources
Subject
To
This
Final
Rule
Hazardous
Waste
Burning
Universe
Affected
y
the
Final
Rule:

A
total
of
265
total
systems
operated
at
145
different
facilities.

Number
of
Systems,
by
Source
Category:

Commercial
Incinerators:
15
(
5.7%)

Cement
Kilns:
25
(
9.4%)

LWAKs
7
(
2.6%)

OnSite
Incinerators
92
(
34.7%)

Liquid
Boilers
104
(
39.3%)

Solid
Fuel
Boilers:
12
(
4.5%)

HCl
Production
Furnaces:
10
(
3.8%)

Waste
Quantity
Estimates:

Total
2003
Hazardous
Waste
Quantity
Burned
(
U.
S.
tons):
3,317,095
Total
2003
Waste
Quantity
Burned
by
Source
Category
(
U.
S.
tons):

Commercial
Incinerators:
447,524
(
13.5
%)

Cement
Kilns:
924,237
(
27.9%)

LWAKs
74,839
(
2.3%)

OnSite
Incinerators
925,828
(
28.0%)

Liquid
Boilers
727,198
(
22.0%)

Solid
Fuel
Boilers:
137,882
(
4.2%)

HCl
Production
Furnaces:
79,587
(
2.4%)
25
Attachment
D
(
continued)

Total
2003
Waste
Quantity
Burned
by
Waste
Form
(
U.
S.
tons):

Organic
Liquids
2,162,238
(
65%)

Solids
453,877
(
14%)

Inorganic
Liquids
350,891
(
11%)

Sludges
335,356
(
10%)

Lab
Packs
12,119
(
0.37%)

Gases
2,614
(
0.08%)

Total
2003
Waste
Quantity
Burned
by
Industry
Sector
(
U.
S.
tons):

Chemical
Manufacturing
1,928,148
(
58%)

Waste
Management
Services
688,190
(
21%)

Petroleum
and
Coal
Manufacturers
171,523
(
5%)

Mining
165,914
(
5%)
26
Attachment
E:
Implementation
Of
Health­
Based
Limits
For
Hcl
And
Cl2
Under
The
Hwc
Mact
Rule
Vs
The
Industrial
Boiler
Mact
Rule1
Major
principles
are
identical.
There
are
minor
differences
in
some
features.

Feature
HWC
MACT
Industrial
Boiler
MACT
Comment
Exposure
Standard:
Hazard
Index
not
greater
than
1.0
Yes
Yes
Consider
emissions
from
collocated
sources
w/
in
the
regulated
source
category
Yes
Yes
2­
tiered
approach
to
establish
limits:
look­
up
tables
or
site­
specific
risk
assessment
Yes
Yes
Emissions
testing
to
document
emission
rates
Yes
Yes
Revise
eligibility
demonstration
if
changes
to
facility
may
increase
emissions
Yes
Yes
Eligibility
demonstration
based
on
chronic
exposure
(
RfCs)
Yes
Yes
Assess
acute
exposure
to
determine
if
hourly
rolling
average
chlorine
feedrate
limit
needed
Yes
No
HWC
chlorine
feedrates
can
be
high
and
can
vary
substantially
over
the
averaging
period
for
the
long­
term
chlorine
feedrate
limit
Acute
exposure
threshold
acute
Reference
Emission
Levels
(
aRELs)
1
acute
exposure
guideline
levels
(
AEGL­
1)
2
AEGL­
1
values
are
protective
for
a
single
exposure
while
aRELs
are
protective
for
multiple
exposures
over
a
lifetime.
Multiple
exposures
at
the
threshold
may
occur
at
HWCs
due
to
high
Cl
feedrates
and
APCD
or
other
malfunctions
and
peak
meteorological
conditions.

Cap
on
emission
rates
Yes
No
Cap
at
current
Interim
Standards
prevents
backsliding
and
minimizes
potential
for
adverse
eco
impacts
Approval
of
eligibility
demonstration
Yes
No
Warranted
b/
c
HWCs
can
have
much
higher
HCl/
Cl2
emissions
that
may
approach
a
Hazard
Index
of
1.0
Chlorine
feedrate
limit
Yes
No
HWCs
can
have
high
and
variable
Cl
feedrates
while
industrial
boilers
generally
have
low
and
relatively
constant
Cl
feedrates.

1
The
aRELs
for
HCl
and
Cl2
are
2.1
mg/
m3
and
0.21
mg/
m3,
respectively.

2
The
AEGL­
1
values
for
HCl
and
Cl2
are
2.7
mg/
m3
and
1.4
mg/
m3,
respectively.

1
Industrial,
Commercial,
and
Institutional
Boiler
and
Process
Heater
MACT.
See
69
FR
55218,
Sept.
13,
2004,
and
40
CFR
Part
63,
Subpart
DDDDD,
App.
A.
