Process and sites diagram - US Environmental Protection Agency

J^daral Bagiatar / Ual. Si,Ho. IS J Tuasdodf, {oanary 23, 1990 / Aales «ad tegnlattaos tMS
pnlliition.control |APC] sonihber solids
wdl face economic impT^* due to tha
removal of this waste stream horn the
BeviO exdusion by today's final rule.
because thpy hum HatnHT»nTm.fl«iia
waste as fueL Because this sector was
not evaluated te the origteal screening
analysis for tee NPRM. tee fodowing
paragraphs present the Agency's costing
approach and iengineering design
assumptions for evaluating compliance
options and eatimating costs.
In general teere are a multitede of
possible compliance options available to
lightweight aggregate pioducera, varying
from conversion to iossd fuels to various
possible waste reduction nieteods to
possible delisting petition cations.
Because of lack of date necessary to
perform quantitative cost estimates for
most of teeae alternatives (as wed as
time constrainte on this final courtordered
rule), tee Agency's screening
analysis has been forced to focus ooly
on the extremely high-cost option of
managing the APC scrubber solids
(generated as wet sludges) as Subtitle C
hazardous wastes. 'Die Agency's coot
estimates ase teus based en the
difference te dis^sal coste between
maaaging tha reported sludge vnhimas
m unlined impoundmente or waste pdes
veraus disposal ta a permitted subtiUe C
londfid. For teese and other reasons
ouUined below, the Agency's cost
estimates ibr this sector should be
regarded as upper-bound eetimatas.
The waste quantities potentiady
subjed to subtitte C londfiO dirpf TBI
have been estiaiated using responses to
tee tedustry survey and. te one case.
%vritten public comments. Methods for
developing teese estimates are
described te a supplemental technicsil
background daoiaDant that ssay ba
found ta the daclcBt for today's nde.*
Hie Agency bos a«"'i'"'"i that ^y^f i«»fif^^
quantities reported by tee faddties
represent relatively dry laoterial. and
that dewatering would aot be feasibte as
s volume redaction mcfcad prior to lani
disposal ff dewateriug wauhl be
possible, then tha muBtdy af waste for
subtitle C landfid dispaaaltas been
overestlmstad and to Miasctent EPA
bas. accortfingly oraiaaMuiated
compiianca costs, ivfafc&an direcdy
related to the mass of wastsibat must
be disposed.
The Agency has aisD-eoRserratively
assumed teat aU lightwaighlJiggregate
kdas st each affected focilMy (most
• Addandum la Iha Tac/inkialW^ienund
Doeumant DanhpatatH of Iha Coit and Sconomtc
Impacts af lapiaamnlia$ Uta tmiU Ulnaml
PtBcauinf HaataaCntonaBaoMaiicAiiahrsIs
Stafl Office anelld Wa«ta, ISBPA. Taaaaiy tz.
facihUas operate thiae to &re fcilaa] do
and wid continue to bum listed
hazardaus wastes as fiial Consequently.
m this analysis tee entire scrubber
solids stream for ad faddties is assumed
to be affeded by tee derived-from nde
and teerefore subject to subtitle C. To
tee extent teat some or od faddties do
not bum listed hazardous wastes te ad
of their kites and/or do (or could)
segregate Usted aixd non-listed
(characteristic) hazardous wastes prior
to thai use as fuel, EPA bas further
oveiestimated costs and impacts.
te addition, the Agency has some
concerns about the waste volume date
reported by one of the two affected
firms, tee SoUte Corporation. Solite's
fadhUes report waste generation rates
that are oubetantially higher tean any
other lightweigfat aggregate producer,
even when corrected for differences te
plant size and production rate. Tbe
waste-to-produd ratio calodated by
EPA for SoUte's faddties ranges from 15
percent to more than 25 percent This is
from two and one had to 210 times tee
ratio calculated for tee other reporting
facilities generating the same waate.
NoDeteeleaa. the date reported ta the
Natinoal Survey and used ta this
analysis ore consistent vrite tnfoanatian
previously submitted to EPA by tee
company. This may or may not be
related to the issue of moisture content
discussed above. It should be noted,
howevec that these very high reported
waste ^ner&tien rates lead direcdy te
significant compliance coet estimates. U
acteal waste generation rates are lower,
acteal compliance costs and associated
impacte will be less than tboee predided
here.
Anoteer conservative assumption teat
tba Agency bas made te conducting this
anal^'sfsls teat affected firms would
contteue using current air pollution
control meteods and. teerefore, continue
SDgeneratewat APC scmtifoer soUds.
Newly one baV of tee l^tweight
aggregate indnstry ourenty uses dry
couection meteods. induding one of tee
faddties cpareted by SoUte teat burns
hasardous svaste fuel. Waste generation
rates using dry coUection methods are
generady sigE^cantly tower tean teose
ststaig wet caOection metbods. ta
additioa infonnation snbmJtted to EPA
indicates teal at some faddties. tee APC
dost te recycled into tes lightweight
asragate kilas from which tf is
fsnerated. subh teat tee prooess does
nat generate any subatoatlal quantity of
solid wastes. To tee eKtent that tee
faddties sscamteed te teis analysis coald
Inalal dry dat coUectian systems snd
Tscssle tee seUds rathorlhan contteus
tBssa wet GoBactioo sysfaams, coste aad
related tnqiacte-CDuld be reduced even ij
tee-fadUftes continued te utilize Usted
hazaadauB wastes as fuel supplements.
Fteally. the affeded firms, SoUte and
NorUte. could potestiaUy avoid subtitie
C reguialian ahogeteer by eiteer (1)
converting entirely to oteer fuels and
discontinuing uae of Usted hazardous
wastee as fuel or (2) having their waste
streams de-listed on a site-specific
basis. EPA notes here teat Solite has
indicated te iU public commente on tee
September 25.1989, and previous
proposed rules teat it would not .
contteue to accept and burn hazardous
waste fuels d tee BeviU exemption were
to be removed from its wastes. While
tee Agency recognizes that this courae
of action is a distted possibiUty and
perhaps the least cost compUance
alternative, tee Agency was not able te
tee present screening analysis to
evaluate tee avaiiabte fuel converaion
option due to a lock of factual
infonnation about such.faclora as
retrofitting coste. thermal value of
currently used hazotdons waste fuels,
and tbe revenues accruing to the two
films lor accepting the hazardaus
wastes buut individiial geneaatora. For
tee sameeoasons. Le., tnsuffident date,
it has also not been possible So predid
tee outoome ef any attempt by the firms
to have tee APC oaubber wastes te
question offidaUy delisted (withdrawn
from sabtitte C regulation) hy tee
Agency.
Simdotly, wdtdefiPA acknowledges
that tatermediate ahematives may be
avadabie. such as bnmteg only
characteristic rateer tean listed
bozartlQus wastes te at least some kilns
currenUy avadabie information is
inaafficient to assess tee feasibility or
cost Implications af this type of
operational change.
ConaequKtiUy. ^A's compUance cost
analysis has been conduotad iietng tee
best ouneatly available information to
develop what are essentially worst-case
compUance cost estimates tar the
lightweight aggregate commodity sector
To tee extent that tba affected faciUties
can (1) avoid eubtiUe C regtdation by
fuel changes and/or equipment
modifications or sucaesoful delisting
pgtitinna, or (2) ftTrlty'waste-RducUon
techniques ta geiieiata lesser quantities
of AFC scrubber soUds lubject to tee
derivsd-from rule, the coate and taipact!
.tapoctadJiarsjaBysapreaent a
sitbetaBtial evsrestiaBte.
£. Aggregota^ad Seotar CampHance
Coatt
Tbs loipaot sofeening analysiB
projecte "teat atevsn fBcdOtes ta four
ffiSerant mlnaralptaaasslag ooamodity