Process and sites diagram - US Environmental Protection Agency

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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/inkialWîenund 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. Â'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. £. Aggregotaâd Seotar CampHance Coatt Tbs loipaot sofeening analysiB projecte "teat atevsn fBcdOtes ta four ffiSerant mlnaralptaaasslag ooamodity
2350 Federal Registar / Vol. 55, No. 1» / Tuesday, January 23. 19» / Rules and Regulations secton wid be affeded directly by today's ftaal rule. Thirty-five faddties ta these four secton are expected to be unaffected by today's rale because teey eiteer (1) do not generate tee processing waste te question. (2) routteely recycle tee material as a process teput or (3) produce a waste that apparentiy does not faU standard EPA hazardous waste test criteria. Anoteer three faciUties. one in tee titanium dioxide sector, and two in tee lead sector, are believed to be unaffected by virtue of already incorporating subtide C (or equivalent NPDES wastewater treatment) practices in teefr current waste management systems. In aggregate, tee total impact of today's rule is estimated to be about S18.5 milUon per year. EPA cost estimates for tedividual commodity secton and faciUties are presented te Table 4. For tee reasons discussed above, tee major part of tee total estimated compliance coste (88 percent) fads upon tee five Ughtweight aggregate faciUties currenUy burning Usted hazardous wastes as fuel Cost impacte range from S2.S mdUon annuady for tee Noriite and Florida SoUte fadUties to almost B4.8 miUion aimuaUy for SoUte's Arvonia, Virginia, faciUty. The reasons for tee large magnitede of teese compUanca cost estimates are tba host of conservative analytical assumptions articulated above, togeteer wite tee relatively large quantities of scrubber wastes reported by tee SoUte company. One oteer sector, titanium dioxide, te e
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Process and sites diagram - US Environmental Protection Agency

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