GCI TECH NOTES©
Volume 4, Number 06
Gossman Consulting, Inc.
Effluent Limitations Guidelines, Pretreatment
Standards and NSPS for Industrial Waste Combustors
(FR-63, pages 6392-6423)
David Constans and Jim
Effluent Limitations Guidelines, Pretreatment Standards and NSPS for
Industrial Waste Combustors (FR-63, pages 6392-6423) is a proposed rule
released for comment in February 1998 with comments to the EPA to be
by May 7, 1998. Upon first reading, the proposed regulation would
to focus on a very narrow segment of industrial waste combustors that
wet scrubbing systems as air pollution control devices. Indeed, the
appears almost innocuous. Briefly, the proposed regula-tion applies to
commercial industrial waste combustors that receive industrial waste
off-site and discharge industrial waste combustor wastewater. This
discharge, per this rule, must meet the BPT Effluent Limitations limits
in the table below. Interpreting the rule in this narrow fashion would
result in a rule that applies to perhaps as many as eleven facilities.
This is the interpretation EPA used in their economic analysis.
the rule can be more broadly interpreted to include virtually every
kiln, whether they use hazardous waste fuels or not, and for a broader
range of pollutants than those listed.
BPT Effluent Limitation (mg/l)
|Total Suspended Solids
Priority and non-conventional Pollutants
Significant Details of the Rule and Comments
- This rule exempts the 274 private non-commercial waste combustion
That is, facilities which combust internally generated wastes. There
a number of such facilities which combust wastes very similar in
characteristics to those combusted at commercial facilities and utilize
the same or similar processes which generate the same or similar
The EPA points out that the majority of these either do not generate
device effluent emissions or these emissions are part of the facility
emissions that are treated. Indeed, the same can be said of commercial
waste combustion facilities which have complex and compre-hensive
covering every emission from the facility. It appears inconsistent
subject commercial facilities to an effluent guideline while exempting
non-commercial facilities that perform the same activity.
- EPA mentions hazardous waste combustors and the hazardous waste
rule (HWC) in this proposed rule, but there is also the currently
non-hazardous waste NESHAP rule aimed at the Portland cement industry.
EPA now proposes yet another way to pull cement kilns under yet another
proposed, seemingly redundant, rule and expands the universe of "waste
combustor facilities" by including facilities that perform "recovery
of components from ... non-hazardous industrial waste received from
facilities." So in essence, EPA is using this rule to cast a wide
net and combine both hazardous and non-hazardous combustion facilities
under the umbrella of "industrial waste combustor facilities"
no matter whether the waste used in the manufacturing process is
- Cement facilities routinely utilize industrial wastes in their
As an example, steel mill scale containing iron, an essential
in the production of cement, is utilized as a raw feed material. Other
similar industrial wastes are used as well, such as foundry sand
silica and iron) and industrial wastes containing alumina. The use of
non-hazardous industrial wastes allows cement companies to use less
resources and to minimize their raw material costs. This proposed
would cause nearly every cement kiln in the U.S. to be classed as a
waste combustor due to use of such industrial wastes.
- The proposed regulation in other respects does not appear to be
to regulate facilities that use alternate raw materials such as steel
scale or foundry sand, which are added to the kiln raw feed. The
of these materials, iron, silica and alumina are indeed "recovered",
but it is questionable that they are "combusted." A narrow
of the rule would not include these activities, however, the wording of
the rule clearly targets such activities. Nor is the rule seemingly
limited to combustion wastewater; that is, waste used in air
control systems, or to the pollutants listed in the table.
- The concern is that the EPA has indicated that it "...will
developing limits for these waste streams in this rule." These
include floor wash water, truck/equipment wash water or container wash
water and presumably laboratory drain water. In addition to the
proposed for regulation (TSS, pH and nine metals) the possibility
that "developing limits" may also include organic constituents.
This is indicated by EPA's statement: "Because these other streams
contain both organic and inorganic pollutants...." Clearly then
the EPA has set the stage for a considerable expansion of this
At this point nothing can be done about EPA's possible expansion of
rule to include more facilities, more effluent streams or more
Comments have been submitted to the EPA regarding the above points, and
hopefully some clarification and narrowing of the rule will result.
there is some indication that state agencies will utilize this proposed
regulation in formulating permit conditions for wastewater releases
facilities which are subject to RCRA permitting. In any event, it would
seem prudent that any facility which utilizes industrial wastes should
examine their process and determine if there are any effluent
which might be subject to these regulations, and then analyze those
to determine what pollutants are present and in what concentrations.