TECHNICAL SUPPORT ASSISTANCE OF MACT IMPLEMENTATION DRAFT QUALITATIVE RISK CHECK SUMMARY REPORT FACILITY PRIORITIZATION GROUPING Submitted to:

U. S. Environmental Protection Agency Region 4 RCRA Permitting Section Waste Management Division 61 Forsyth Street, SW Atlanta, Georgia 30303 Submitted by:

Tetra Tech EM Inc. 101 Marietta Street NW, Suite 2400 Atlanta, Georgia 30303 EPA Region : 4 Site : Multi state/ Multi facility Contract No. : 68 W99 018 Work Assignment No. : R04808 Date Prepared : September 24, 2001 EPA Work Assignment Manager : Mr. Jay Bassett Telephone No. : 404/ 562 8542 Prepared by : Tetra Tech EM Inc. Project Manager : Tim R. Jarosch Telephone No. : 404/ 225 5502 Approved:

Michael R. Jones Regional Manager CONTENTS ( Continued)

Section Page ii 1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.2 Technical Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2.0 FACILITY SPECIFIC PRIORITIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 2.1 3V, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 2.1.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 2.1.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 2.1.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 2.2 Albemarle Corporation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 2.2.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 2.2.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 2.2.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 2.3 Catalytica Pharmaceuticals, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 2.3.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 2.3.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 2.3.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 2.4 Diversified Scientific Services, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 2.4.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 2.4.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 2.4.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 2.5 DSM Chemical North America, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 2.5.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 2.5.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 2.5.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 2.6 First Chemical Corporation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 2.6.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 2.6.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 CONTENTS ( Continued)

Section Page iii 2.6.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64 2.7 Giant Cement Company . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 2.7.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 2.7.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 2.7.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75 2.8 GlaxoSmithKline, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 2.8.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 2.8.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 2.8.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 2.9 LWD, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89 2.9.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89 2.9.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 2.9.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94 2.10 Mallinckrodt Chemical, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 2.10.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 2.10.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101 2.10.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104 2.11 Monsanto Company . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 2.11.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 2.11.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 112 2.11.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 115 2.12 Rohm and Haas Company . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 120 2.12.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 120 2.12.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 123 2.12.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126 2.13 Tennessee Eastman . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131 2.13.1 Facility Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131 2.13.2 Risk Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133 2.13.3 MACT Based Facility Prioritization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137 1 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 142 1.0 INTRODUCTION Tetra Tech EM Inc. ( Tetra Tech) received Work Assignment No. R04808 from the U. S. Environmental Protection Agency ( EPA) under Resource Conservation and Recovery Act ( RCRA) Enforcement,

Permitting, and Assistance ( REPA) II Contract No. 68 W99 018 on March 22, 2000. Under this work assignment, Tetra Tech was directed to perform and prepare a preliminary site specific human health qualitative " risk check" report for the 13 hazardous waste combustion facilities identified under this work assignment. Tetra Tech has completed this portion of the work assignment. As a continuation of this work assignment and based on the original scope of work and verbal direction from the EPA Work Assignment Manager ( WAM), Tetra Tech developed a facility summary report. The main objectives of the summary report are to ( 1) develop two independent prioritization strategies including a risk based prioritization strategy and a Maximum Achievable Control Technology ( MACT) based prioritization strategy; ( 2)

evaluate individual qualitative guiding factors on a facility specific basis and assign each factor into either the high, medium, or low prioritization grouping utilizing the two independent prioritization strategies identified above; and ( 3) provide final recommendations for assigning each facility into one of the three prioritization groupings utilizing the risk based approach and MACT based approach.

This summary report is intended for use as a permitting tool by the RCRA permitting authority and facilities to efficiently manage and evaluate potential adverse risk impacts to human health and the environment associated with the combustion of RCRA regulated hazardous wastes. In addition, this report is intended to provide a means by which facilities can be prioritized, based on their overall potential for resulting in adverse health impacts, for evaluation to determine if compliance with MACT standards alone are protective of human health and the environment or if additional permit or risk management options are required to ensure protection of human health and the environment.

This summary report includes two main sections, Section 1.0, which includes the background ( Section 1.1)

and technical approach ( Section 1.2), and Section 2.0, which contains the facility specific prioritization results. Section 2.0 also presents facility specific discussions, including Section 2. X, which introduces the specific facility; Section 2. X. 1, which discusses the facility specific background information including 2 process descriptions and permit history; Section 2. X. 2, which describes the process and findings used to assign a facility into one of three prioritization groupings based on the risk based facility prioritization strategy; and Section 2. X. 3, which describes the process and findings used to assign a facility into one of the three prioritization groupings based on the MACT based facility prioritization strategy.

1.1 BACKGROUND RCRA gives EPA, or authorized states, the authority to regulate facilities that manage hazardous waste.

Section 3005 ( c)( 3) of RCRA ( codified in Title 40 of the Code of Federal Regulations [ 40 CFR]

270.32( b)( 2)) directs the RCRA permitting authority to include terms and conditions in the RCRA permit,

as necessary, to ensure protection of human health and the environment. These provisions are generally referred to as the omnibus authority. Under 40 CFR 270.10( k), the permitting authority may require a permitted facility or permit applicant to submit additional information when the permitting authority has reason to believe that additional permit conditions may be warranted under 270.32( b)( 2). A site specific risk assessment can provide the information necessary to make the determination regarding what, if any,

additional permit conditions are needed for a particular hazardous waste facility. Thus, the information required to establish permit conditions could include a risk assessment, or the necessary information required to conduct a risk assessment.

On September 30, 1999, EPA, under joint authority of the Clean Air Act ( CAA) and RCRA, promulgated the Phase I MACT rule. The Phase I MACT rule consisted of revised emissions standards for hazardous waste incinerators, hazardous waste burning cement kilns, and hazardous waste burning lightweight kilns.

Revised emission standards for hazardous waste burning boilers, halogen acid furnaces ( HAF), or sulfuric acid recovery furnaces ( SARF) are not part of the Phase I rule, but are anticipated to be covered in the upcoming Phase II MACT standards rulemaking.

Although the Phase I rule does not apply to hazardous waste burning boilers, HAFs, or SARFs, the qualitative guiding factors developed under this rule still provide useful information for determining whether a site specific risk assessment may be necessary to meet RCRA protectiveness mandates. For example, although " volumes and types of wastes being burned" was identified as a qualitative guiding factor in the Phase I rulemaking, information relative to this guiding factor ( e. g., wastes containing highly 3 toxic constituents both from an acute and chronic perspective) provides stakeholders with the information necessary to determine if boilers, HAFs, or SARFs, which are the responsibility of RCRA, are protective of human health and the environment. For these reasons and to meet the objectives of this report, sources covered under the future Phase II rulemaking are still included in this report. These sources will be evaluated against the qualitative guiding factors presented in the Phase I rulemaking using site specific information to identify those characteristics that may significantly influence risk posed by a particular source in a manner consistent with emissions sources covered in the Phase I rule.

The Phase I MACT standards reflect the performance of MACT as specified by the CAA and are generally more restrictive than existing RCRA standards. EPA generally anticipates that sources complying with the MACT standards will not pose an unacceptable risk to human health and the environment. However, as definitive findings cannot be made as part of the MACT rulemaking, a national RCRA risk assessment evaluation of both direct and indirect risk was performed to determine if the MACT standards satisfied the RCRA protectiveness mandate. The national risk evaluation did not, however, quantitatively assess the proposed standards with respect to non dioxin products of incomplete combustion ( PIC) and may not take into account unique site specific factors ( e. g., air dispersion patterns or proximity to receptors). Therefore,

EPA recommends that for hazardous waste combustion facilities subject to Phase I final MACT standards,

permitting authorities should evaluate the need for a risk assessment on a case by case basis. The qualitative guiding factors as outlined in the MACT rule preamble ( 64 Federal Register 52842, September 30, 1999) reflect the types of considerations inherent in determining if a site specific risk assessment is necessary. The omnibus provision is a RCRA statutory requirement and does not have a CAA counterpart.

Because the CAA does not override RCRA, the RCRA permitting authorities are responsible for supplementing the national MACT standards on a site specific basis, as necessary, to ensure adequate protection of human health and the environment under RCRA.

To assist EPA Region 4 in prioritizing its permitting activities and risk management strategies, EPA Region 4 has directed Tetra Tech to develop a qualitative risk check summary prioritization report. The report will focus on the qualitative guiding factors utilized in the facility specific qualitative risk check reports. Examples of the qualitative guiding factors used to develop the facility specific reports included the following: 4 ° Volume and types of wastes being burned; for example, wastes containing highly toxic constituents both from an acute and chronic perspective ° Identities and quantities of non dioxin products of incomplete combustion most likely to be emitted and to pose significant risk based on known toxicities ( confirmation of which should be made through emissions testing)

° Presence or absence of other on site sources of hazardous air pollutants so as to significantly influence interpretation of the source in question ° Presence or absence of other off site sources of pollutants in sufficient proximity so as to significantly influence interpretation of a facility specific risk assessment ° Particular site specific considerations related to air dispersion modeling, such as unique dispersion patterns resulting from site specific terrain characteristics, surface roughness, building wake effects, etc.

° Type of receptor and exposure scenario( s)

° Particular site specific considerations, such as proximity to receptors ° Presence or absence of and proximity to water bodies and watersheds ° Presence of and proximity to special sub populations, such as schools, hospitals, nursing homes, day care centers, parks, and community activity centers that would indicate the presence of potentially sensitive receptors ° Presence or absence and proximity of significant ecological considerations, such as high background levels of a particular contaminant or proximity of a particular sensitive ecological area ° Concerns raised by the public These qualitative guiding factors represent site specific characteristics that may significantly influence the risk posed by a particular source, and therefore should be considered to establish the need for further site specific evaluation. These qualitative guiding factors, when evaluated using site specific data, will ( 1) provide a qualitative process by which the permitting authority can prioritize those facilities where there is reason to believe that operation in accordance with current or future MACT standards alone will not be protective of human health and the environment, ( 2) assist the permitting authority to determine whether a site specific risk assessment may be warranted, and ( 3) assist the permitting authority to establish risk management priorities such that potentially unacceptable risks to human health and the environment are identified and managed appropriately. 5 1.2 TECHNICAL APPROACH As discussed in Section 1.0, one of the main objectives of this work assignment was to develop two independent prioritization strategies. Because this report is designed to be used as a permitting tool by facilities and the permitting authority to ( 1) evaluate overall potential adverse risk impacts to human health and the environment and ( 2) determine whether compliance with current and future MACT standards alone will satisfy the RCRA protectiveness requirements, it was necessary to develop a technical approach that considered the needs of both objectives. Therefore, two independent prioritization strategies were developed. Specifically, these prioritization strategies include the overall risk based prioritization strategy and the MACT based prioritization strategy.

Overall Risk based Prioritization Strategy The main focus of the overall risk based facility prioritization strategy is to assign each facility's qualitative guiding factor as related to facility specific characteristics and, subsequently, the overall facility to either a high, medium, or low prioritization group based on the degree or relative significance to which these factors contribute or result in adverse impacts to human health and the environment ( see discussion below). The risk based facility prioritization strategy is based solely on the site specific conditions at the facility, and does not take into account current or future MACT standards or the known limitations associated with the methodologies used to conduct the national MACT risk assessment.

Overall MACT based Prioritization Strategy The main focus of the MACT based facility prioritization strategy is similar to the risk based approach, in that they are both based on the qualitative guiding factors. However, the MACT strategy will focus on evaluating each qualitative guiding factor and overall facility based on the degree to which these factors indicate that compliance with MACT standards alone may not be protective of human health and the environment.

Specific to the MACT based prioritization strategy, it should be noted that although current Phase I MACT standards do not apply to facilities operating hazardous waste fueled boilers, it is believed that development of future Phase II MACT standards, which will apply to facilities operating boilers, will also include a national MACT risk assessment. With this assumption in mind, it is also believed that the 6 qualitative guiding factors listed in Section 1.1 and the known limitations of the Phase I national MACT risk assessment will also apply to boilers. As a result, the same criteria for evaluating and assigning facilities that are subject to Phase I MACT standards into one of the three prioritization groupings utilizing the MACT based facility prioritization strategy are also applied to facilities with boilers.

As discussed in Section 1.0, each prioritization strategy will include both an analysis of the individual qualitative guiding factors evaluated in the facility specific qualitative risk check report and an overall facility prioritization. Individual qualitative guiding factors will be assigned to a high, medium, or low prioritization grouping based on their propensity to result in adverse health impacts. Classification in the low prioritization grouping indicates a reduced or lower prioritization level, while classification in the high prioritization grouping indicates an increased prioritization level or heightened need for further action.

In addition to the individual prioritization, an overall facility prioritization will also be made by assigning each facility into one of the three prioritization groupings ( i. e., low, medium, or high) based on the prioritization results of the individual qualitative guiding factors. More importantly, the overall facility prioritization will also include consideration of how each qualitative guiding factor relates to each other collectively, resulting in an increased or " additive" potential for adverse risk impacts. Finally, the overall facility prioritization will be completed by comparing the 13 facilities' site specific characteristics to ensure that the facilities in each prioritization grouping share commonalities or similar site specific conditions associated with other facilities assigned to the same prioritization grouping.

As discussed above, the decision to assign a facility into one of the three prioritization groupings specific to the risk based strategy and MACT based strategy are made independent of each other and do not include an evaluation of findings across prioritization strategies. Thus, a facility that is assigned to the high prioritization grouping utilizing the risk based prioritization strategy ( Section 2. X. 2) will not necessarily be grouped in the high priority category utilizing the MACT based prioritization strategy ( Section 2. X. 3). In addition, since each facility's grouping is based on a qualitative review of site specific facility information,

a facility's classification to one of the three prioritization grouping does not necessarily indicate whether the facility is operating in a manner that is protective of human health or the environment; rather, it is intended for use as a permitting tool to compare and contrast the site specific risk check findings in order to prioritize those facilities that may require additional quantitative investigation. 7 Specifically, the " low" prioritization grouping is intended to represent those facilities that ( 1) have little or no observed site specific characteristics that indicate an increased potential for adverse impact to human health and the environment or ( 2) when compared with facilities assigned to the medium or high prioritization grouping, clearly have a lower potential for adverse impacts relative to the higher priority groupings.

The " medium" prioritization category is designated for those facilities that exhibit one or more significant site specific characteristics, which provide a strong indication that potential adverse impacts to human health and the environment exist, and therefore will require additional risk assessment activities to quantify risk impacts. This category may also contain those facilities where sufficient data is not available to evaluate a specific qualitative guiding factor resulting in the inability to formulate qualitative conclusions and determine the protectiveness of facility operations.

The " high" prioritization category is reserved for those facilities that exhibit individual or multiple sitespecific characteristics that clearly indicate an increased potential for adverse health impacts. In addition,

this group may also contain those facilities where significant data gaps and uncertainties limit the ability to formulate or support qualitative conclusions regarding the potential for adverse risk impacts.

Each facility specific section ( i. e., 2. X) will include a prioritization table and summary paragraph specific to each of the facility prioritization strategies. The facility specific prioritization table, included in both the risk based prioritization section and the MACT based prioritization section, will identify to which prioritization grouping each individual qualitative guiding factors was assigned. In addition, the table will also designate the overall facility prioritization grouping. The overall designation specific to the risk based and MACT base prioritization strategy will be based on ( 1) a review of individual qualitative guiding factor prioritizations, ( 2) consideration of how each qualitative guiding factor relates to each other collectively, and ( 3) a comparison with the other facilities included in this report. As recommended in the qualitative risk check reports, qualitative guiding factors should be considered collectively due TO their complex interplay. When all guiding factors are considered collectively, the potential risk impacts and risk trends are better identified and defined, and will provide an additional level of confidence in making risk management decisions. 8 The summary paragraph following each prioritization table will provide further justification supporting the assignment of a facility to a specific prioritization grouping. In addition, the summary paragraph will also ( 1) identify any facility specific issues or site specific characteristics that complicated the final decision to assign a facility to a specific grouping, and ( 2) include comparisons with the other prioritization categories to identify common characteristics exhibited within each group as a means to further justify the final overall facility prioritization. 9 2.0 FACILITY SPECIFIC PRIORITIZATION The following two tables provide an overview of the overall facility prioritization groupings. Specifically,

the first table contains the results of the overall facility specific prioritization groupings utilizing the riskbased facility prioritization strategy. The second table contains the results of the overall facility specific prioritization groupings utilizing the MACT based facility prioritization strategy. For facility specific findings, refer to the 13 facility specific sections provided below.

RISK BASED FACILITY PRIORITIZATION OVERVIEW TABLE FACILITY PRIORITIZATION GROUPING Low Medium High 3V, Inc.  Georgetown, South Carolina ( see Section 2.1)

Albemarle Corporation  Orangeburg, South Carolina ( see Section 2.2)

Catalytica Pharmaceuticals, Inc.  Greenville, North Carolina ( see Section 2.3)

DSM Chemicals North America, Inc.  Augusta Georgia ( see Section 2.5)

Diversified Scientific Services, Inc.  Kingston, Tennessee ( see Section 2.4)

First Chemical Corporation  Pascagoula, Mississippi ( see Section 2.6)

GlaxoSmithKline, Incorporated  RTP, North Carolina ( see Section 2.8)

Giant Cement Company  Harleyville, South Carolina ( see Section 2.7)

LWD, Inc.  Calvert City, Kentucky ( see Section 2.9)

Mallinckrodt Chemical Company  Raleigh, North Carolina ( see Section 2.10)

Monsanto Company  Augusta, Georgia ( see Section 2.11)

Rohm and Hass Company  Louisville, Kentucky ( see Section 2.12)

Tennessee Eastman  Kingsport, Tennessee ( see Section 2.13)

10 MACT BASED FACILITY PRIORITIZATION OVERVIEW TABLE FACILITY PRIORITIZATION GROUPING Low Medium High 3V, Inc.  Georgetown, South Carolina ( see Section 2.1)

Albemarle Corporation  Orangeburg, South Carolina ( see Section 2.2)

Catalytica Pharmaceuticals, Inc.  Greenville, North Carolina ( see Section 2.3)

DSM Chemicals North America, Inc.  Augusta Georgia ( see Section 2.5)

Diversified Scientific Services, Inc.  Kingston, Tennessee ( see Section 2.4)

First Chemical Corporation  Pascagoula, Mississippi ( see Section 2.6)

GlaxoSmithKline, Incorporated  RTP, North Carolina ( see Section 2.8)

Giant Cement Company  Harleyville, South Carolina ( see Section 2.7)

LWD, Inc.  Calvert City, Kentucky ( see Section 2.9)

Mallinckrodt Chemical Company  Raleigh, North Carolina ( see Section 2.10)

Monsanto Company  Augusta, Georgia ( see Section 2.11)

Rohm and Hass Company  Louisville, Kentucky ( see Section 2.12)

Tennessee Eastman  Kingsport, Tennessee ( see Section 2.13)

11 2.1 3V, INC.

This section presents the information and approach used in assigning 3V, Inc. ( 3V) to one of the three prioritization groupings based on ( 1) the facility's overall potential for resulting in adverse health impacts and ( 2) an assessment of the protectiveness of current or future MACT standards to determine if additional permit limits may be required to ensure protection of human health and the environment. Section 2.1.1 presents facility specific background information including process descriptions and permit history.

Section 2.1.2 describes the process and findings used to assign a facility to one of the three prioritization groupings specific to the risk based facility prioritization strategy. Section 2.1.3 describes the process and findings used to assign a facility to one of the three prioritization groupings following the MACT based facility prioritization strategy. Specific sources of information used to evaluate the 3V facility are cited and referenced at the end of this report.

2.1.1 Facility Information The following summarizes the facility specific information provided in Section <IP_ADDRESS> of the 3V Qualitative Risk Check Report ( EPA 2001k). This information is intended to provide a general facility overview including process descriptions and permit history.

The 3V facility operates a chemical manufacturing plant that produces a wide range of organic materials used in the textiles, plastics, detergents, water treatment, and cosmetic industries. The facility is located about 7 kilometers west of Georgetown, South Carolina, in Georgetown County. The 3V facility property consists of 120 acres and is located in a sparsely populated rural area ( DRE Environmental Services [ DRE] 1995a). The facility consists of five process operation areas: Alpha, Beta, Gamma, Delta 1, and Delta 2. The Alpha plant produces polyvinyl acetate and a thickening agent. Optical brightener is produced in the Beta plant; and chlorine stabilizers, a swimming pool additive, are produced in the Gamma plant. Plastol B is produced in the Delta 1 and Delta 2 plants. The resulting product is a certain fraction of the distillate, while other non acceptable distillate fractions and excess distillate products are considered waste products ( DRE 1995a). Specifically, waste generated includes nonhazardous, hazardous due to flammability, and hazardous based on the definition of waste code F003. 12 3V currently operates two natural gas fired tube boilers used to generate process steam for energy at the facility. One of these boilers, the No. 2 energy recovery boiler ( boiler no. 2), burns RCRA regulated hazardous waste ( i. e., distillate waste byproducts) generated during facility manufacturing operations.

Boiler no. 2 is a Cleaver Brooks package steam boiler model NCB600 800. Since boiler no. 2 burns hazardous waste, it is subject to the Boiler and Industrial Furnace ( BIF) regulations in 40 CFR 266 Subpart H and is currently operating under interim status ( General Engineering 1998).

There is currently no pollution control equipment installed on the boiler exhaust. The waste fuel burner nozzle is designed to operate at a maximum flow rate of 170 gallons per hour ( gal/ hr). Boiler no. 2 can operate at a heat capacity of 33.47 million British thermal units per hour ( MMBtu/ hr). The maximum waste feed of 170 gal/ hr can be fed into boiler no. 2 without reaching maximum heat capacity.

A RCRA permit application ( including a trial burn plan) was submitted to EPA on February 16, 1995.

Compliance certification testing was performed in February 1999 for boiler no. 1 to demonstrate compliance with the particulate matter, metals, and total chloride standards under current BIF regulations ( General Engineering 1999). 3V's RCRA permit application has been under review jointly by EPA Region 4 and the South Carolina Department of Health and Environmental Control ( DHEC) since June 1, 2000 ( DHEC 2000).

2.1.2 Risk Based Facility Prioritization This section describes findings relative to assigning 3V to one of the three prioritization groupings using the risk based facility prioritization strategy. Specifically, the following prioritization table presents results for the individual qualitative guiding factors evaluated in the 3V Qualitative Risk Check Report ( EPA 2001k).

In addition, the table also identifies which prioritization grouping the overall facility was assigned to using the risk based facility prioritization strategy. The paragraph following the prioritization table provides further justification supporting why the facility was assigned to its specific prioritization grouping. 13 OVERALL RISK BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High Section <IP_ADDRESS>   Volumes and Types of Waste Being Burned

Section <IP_ADDRESS>   Emissions Quantification

Section 2.2.2   Other On site and Off site Emission Sources

Section <IP_ADDRESS>   Terrain Characteristics

Section <IP_ADDRESS>   Land Use for Dispersion Coefficients and Surface Roughness

Section <IP_ADDRESS>   Building Wake Effects

Section <IP_ADDRESS>   Particle Size Distribution

Section <IP_ADDRESS>   Meteorological Conditions

Section <IP_ADDRESS>   Physical Source Parameters

Section <IP_ADDRESS>   ( Receptor) Grid Node Array

Section 4.2.1   Type of Receptors and Exposure Scenario( s)

Section 4.2.2   Proximity to Exposure Scenario Location

Section 4.2.3   Presence or Absence and Proximity of Water Bodies and Water Sheds

Section 4.2.4   Proximity to Special Subpopulations

Section 4.2.5   Presence or Absence and Proximity of Ecological Areas

Section 4.2.6   Public Concerns

3V Georgetown, South Carolina Risk based Prioritization Grouping: Low Based on ( 1) a review of the individual qualitative guiding factors and their associated groupings presented in the above table, ( 2) consideration of how each qualitative guiding factor interrelates collectively, and ( 3)

a comparison with the 12 other facilities included in this report, 3V has been placed in the low prioritization group for the risk based prioritization strategy. 3V's designation in the low priority grouping is due in large part to the combination of a non variable waste stream that has not been shown to contain PBTs or 14 other known risk drivers and lack of receptors located in close proximity to the facility. In addition, when compared with the 12 other facilities included in this summary report, 3V does not exhibit the multiple complicating characteristics that exist at those facilities assigned to the medium or high prioritization groups. Specifically, justification for grouping 3V into the low prioritization grouping includes the following:

3V only treats on site generated hazardous wastes. In comparison, facilities assigned to the medium and high prioritization groupings typically treat both on and off site generated wastes.

The hazardous waste stream treated at 3V is not considered to be highly variable as the facility is permitted to treat only wastes that contain two RCRA waste codes ( i. e., waste that is hazardous due to the characteristic of ignitability, D001, and by listing, F003). In addition, the facility only treats byproduct wastes generated during the manufacturing process.

Neither of the two waste codes that 3V is permitted to treat contain known PBTs or common risk drivers. In comparison, facilities assigned to the medium and high prioritization groupings typically treat wastes that are known or permitted to contain PBT and other common risk drivers.

3V only operates one hazardous waste boiler. In comparison, facilities assigned to the medium and high prioritization groupings typically have multiple sources.

Residential, farmer, fisher, and acute exposure scenarios are not located within close proximity to 3V. For example, the closest residential exposure scenario is located approximately 2 kilometers southeast of the facility. In comparison, facilities assigned to the higher prioritization groupings typically have exposure scenario locations within 1 to 1.5 kilometers of the facility boundary.

Absence of water bodies within 3 kilometers of the facility that exhibit characteristics that typically result in higher risk impact. In comparison, facilities assigned to the higher prioritization groupings typically have multiple water bodies that exhibit characteristics indicative of higher risk impacts, and are within 1 to 1.5 kilometers of the facility boundary.

No documented public concerns are associated with facility operations. In comparison, facilities assigned to the medium and high prioritization groupings typically have documented public concerns.

For a detailed discussion on the site specific qualitative guiding factors, refer to the 3V Qualitative Risk Check Report ( EPA 2001k). Further justification for assigning 3V to the low prioritization group is based on the fact that while some of the qualitative guiding factors evaluated for this facility have been 15 individually assigned to the medium or high grouping, these guiding factors alone do not justify promoting 3V into one of the higher prioritization groupings. Additionally, due to the absence of complex interplay or additive relationships between these guiding factors, the potential for adverse impacts is lessened and does not warrant designation to a higher prioritization grouping. For example, although the qualitative guiding factor associated with " the presence or absence and proximity to ecological areas" was assigned to the high prioritization grouping, 3V only operates one boiler. This boiler treats on site generated wastes that are considered well characterized and not known to contain PBTs or other highly toxic compounds known to be risk drivers, which, if present, would be expected to result in adverse impacts to these habitats and receptors. In addition, although threatened and endangered species are present in Georgetown County,

it is not known if these species utilize habitats within the 3V assessment area. Furthermore, in comparison to the 12 other facilities included in this report, 3V exhibits fewer site specific characteristics that indicate an increased potential for adverse risk impacts, which are common to the medium and high groupings.

Therefore, based on a review of site specific characteristics and a comparison to the other facilities in this report, it has been determined that 3V is best represented by facilities assigned to the low priority grouping and lacks commonalities or similar site specific conditions associated with facilities assigned to the higher priority groupings.

As discussed in Section 1.2, placement into the low prioritization group does not eliminate the need for conducting a site specific risk assessment since facilities in this grouping may still quantitatively result in adverse health impacts. Therefore, consistent with the 3V Qualitative Risk Check Report ( EPA 2001k),

additional site specific risk assessment activities are still warranted and will help both the facility and the permitting authority demonstrate that the facility is operating in a manner protective of human health and the environment.

2.1.3 MACT Based Facility Prioritization This section describes the process and findings relative to assigning 3V to one of the three prioritization groupings based on the MACT based facility prioritization strategy. The following prioritization table presents results for the individual qualitative guiding factors evaluated in the 3V Qualitative Risk Check Report ( EPA 2001k). In addition, the table also identifies which facility specific prioritization group the 3V facility was assigned to. The paragraph following the prioritization table provides the basis for why the 16 facility was assigned to its specific prioritization grouping.

MACT BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High Section <IP_ADDRESS>   Volumes and Types of Waste Being Burned

Section <IP_ADDRESS>   Emissions Quantification

Section 2.2.2   Other On site and Off site Emission Sources

Section <IP_ADDRESS>   Terrain Characteristics

Section <IP_ADDRESS>   Land Use for Dispersion Coefficients and Surface Roughness

Section <IP_ADDRESS>   Building Wake Effects

Section <IP_ADDRESS>   Particle Size Distribution

Section <IP_ADDRESS>   Meteorological Conditions

Section <IP_ADDRESS>   Physical Source Parameters

Section <IP_ADDRESS>   ( Receptor) Grid Node Array

Section 4.2.1   Type of Receptors and Exposure Scenario( s)

Section 4.2.2   Proximity to Exposure Scenario Location

Section 4.2.3   Presence or Absence and Proximity of Water Bodies and Water Sheds

Section 4.2.4   Proximity to Special Subpopulations

Section 4.2.5   Presence or Absence and Proximity of Ecological Areas

Section 4.2.6   Public Concerns

3V Georgetown, South Carolina MACT based Prioritization Grouping: Low As discussed in Section 1.1, while Phase I MACT standards do not apply to facilities operating hazardous waste fueled boilers, it is believed that the development of future Phase II MACT standards, which will apply to facilities operating boilers, will also include a national MACT risk assessment. With this assumption in mind, it is also believed that the qualitative guiding factors listed in section 1.0 and the 17 known limitations of the Phase I national MACT risk assessment will also apply to boilers. As a result, the same criteria for evaluating and assigning facilities that are subject to Phase I MACT standards to one of the three prioritization groupings utilizing the MACT based facility prioritization strategy are also applied to facilities with boilers. Based on ( 1) a review of the individual qualitative guiding factors and their associated groupings presented in the table above, ( 2) consideration of how each qualitative guiding factor interrelates collectively, and ( 3) a comparison with the 12 other facilities included in this report, 3V has been assigned to the low prioritization grouping for the MACT based prioritization strategy. 3V's designation in the low priority grouping is primarily influenced by the observation that when compared with the other facilities evaluated in this report 3V generally exhibits fewer site specific characteristics that indicate compliance with MACT standards alone will not be protective of human health and the environment.

Specifically, justification for grouping 3V into the low prioritization grouping includes the following:

Presence of well characterized waste feed generated on site and known or permitted to contain chemicals not anticipated to be covered under future MACT Standards ( e. g., non dioxin PICs). In comparison, facilities assigned to the medium and high prioritization groupings typically treat wastes from on and off site sources that are known or permitted to contain PBTs and other common risk drivers.

Residential, farmer, and fisher exposure scenarios are not located in close proximity to 3V. For example, the closest residential location is over 2 kilometers from the facility boundary. In comparison, facilities assigned to the higher prioritization groupings typically have exposure scenario locations within 1 to 1.5 kilometers of the facility boundary. In addition, the Phase I National MACT Risk Assessment utilized 16 sector based grid averaging. Based on the assumption that the same approach will be utilized in future MACT risk assessments, this approach, when applied on a site specific basis, may result in the averaging of locally elevated media concentrations ( hotspots), resulting in the potential underestimation of upper bound risk estimates for those exposure scenarios located in close proximity to 3V. However, because 3V does not have any exposure scenarios located within close proximity to the facility, there is less potential for underestimating risk to these receptors.

The selection of representative water bodies in the national MACT risk assessment supporting Phase I MACT standards may have been biased to meet multiple selection criteria, resulting in the potential for overlooking more heavily impacted water bodies and their associated watersheds. However, because there are no water bodies within 3 kilometers of the facility that exhibit characteristics that typically result in higher risk impacts, there is less potential that the national MACT risk assessment that is expected to support Phase II MACT standards will overlook more heavily impacted water bodies in the 3V assessment area. 18

The national MACT risk assessment supporting the Phase I MACT standards did not include a separate analysis or consideration of special subpopulations. However, the closest known special subpopulation is located approximately 2 kilometers southsoutheast of the facility. Therefore, there is less potential that the national MACT risk assessment that is expected to support Phase II MACT standards will overlook special subpopulations in the 3V assessment area.

The national MACT risk assessment supporting the Phase I MACT standards did not consider potential implications associated with public concerns. However, because there are no documented public concerns associated with facility operations, there is less potential that the national MACT risk assessment that is expected to support Phase II MACT standards will overlook special subpopulations in the 3V assessment area.

For a detailed discussion on site specific qualitative guiding factors, refer to the 3V Qualitative Risk Check Report ( EPA 2001k). Further justification for assigning 3V to the low prioritization group is based on the fact that while some of the qualitative guiding factors evaluated for this facility have been individually assigned to the medium or high group, these individual guiding factors alone do not justify promoting the facility to a higher prioritization grouping. Additionally, 3V does not exhibit the complex interplay or additive relationships between guiding factors typically found in the facilities assigned to the higher prioritization groups. Therefore, based on a review of site specific characteristics and a comparison to the other facilities in this report, it has been determined that, for the MACT based prioritization grouping, 3V is best represented by facilities assigned to the low priority grouping and lacks commonalities or similar site specific conditions associated with facilities assigned to the higher groupings.

As discussed in Section 1.2, placement into the low prioritization group does not eliminate the need for conducting a site specific risk assessment since facilities in this grouping may still quantitatively result in adverse health impacts. Therefore, consistent with the 3V Qualitative Risk Check Report ( EPA 2001k),

additional site specific risk assessment activities are still warranted and will help both the facility and permitting authority demonstrate that no adverse impacts to human health and the environment are attributable to the combustion of hazardous waste through 3V facility operations. 19 2.2 ALBEMARLE CORPORATION This section presents the information and approach used in assigning Albemarle Corporation ( Albemarle)

to one of the three prioritization groupings based on ( 1) the facility's overall potential for resulting in adverse health impacts and ( 2) an assessment of the protectiveness of current or future MACT standards to determine if additional permit limits may be required to ensure protection of human health and the environment. Section 2.2.1 presents facility specific background information including process descriptions and permit history. Section 2.2.2 describes the process and findings used to assign a facility into one of the three prioritization groupings specific to the risk based facility prioritization strategy.

Section 2.2.3 describes the process and findings used to assign a facility into one of the three prioritization groupings following the MACT based facility prioritization strategy. Specific sources of information used to evaluate the Albemarle facility are cited and referenced at the end of this report.

2.2.1 Facility Information The following summarizes the facility specific information provided in Section <IP_ADDRESS> of the Albemarle Qualitative Risk Check Report ( EPA 2001i). This information is intended to provide a general facility overview including process descriptions and permit history.

Albemarle owns and operates a chemical manufacturing facility that produces industrial organic and specialty chemical intermediates used in the agricultural, pharmaceutical, and petroleum industries.

Albemarle operates a hazardous waste fuel steam boiler  the 1 HE 3800 1 No. 4 boiler ( boiler no. 4)  that is subject to the RCRA BIF regulations promulgated in Title 40 CFR Part 266. The Albemarle facility is located at Cannon Bridge Road in Orangeburg, South Carolina, at latitude 33  21' 25" north and longitude 79  22' 55" west. The City of Orangeburg is about 2 kilometers northwest of the Albemarle facility, and the North Fork Edisto River is approximately 500 meters east of the facility.

This facility was originally constructed in 1937 as Wannamaker Chemical Company ( EPA 1999). Ethyl Corporation purchased the facility in 1953. In 1996, the Albemarle division was split off as an independent corporation. The facility occupies approximately 300 acres and employs about 500 persons ( TRC 1993).

Albemarle operates 24 hours a day and 7 days a week. Albemarle installed a computerized boiler 20 management controller ( CBMC) and an oxygen trim system after the BIF rules were promulgated in 1991.

The oxygen trim system manages the flow of waste fuel to achieve optimal firing conditions.

Plant wastes are transferred via pipeline or tank trucks from the various processing areas throughout the Albemarle plant to boiler no. 4 ( TRC 1993). The wastes are stored in four aboveground waste storage and feed tanks that are located east of the boiler. Tanks T 100M 2 and T 30M 61 collect and blend hazardous waste received from tank trailers and pipelines. Tanks T 30M 66 and T 10M 32 are fuel burn tanks that receive waste blended in the collection tanks or directly from tank trailers and pipelines. Some wastes are also burned directly from the tank trailers that deliver hazardous waste to the RCRA facility. During normal operation, wastes that are burned in boiler no. 4 vary between 10,000 and 20,000 British thermal units per pound ( Btu/ lb) in heat value. The total feed rate of liquid waste fuel to boiler no. 4 varies between 1.5 and 3.5 gallons per minute ( gpm). For high Btu wastes, the heat capacity of the boiler is 4.6 gpm.

In November 1980, Albemarle submitted a RCRA Part A permit application to obtain interim status. EPA requested a RCRA Part B permit application in February 1982, which Albemarle submitted to EPA in July 1982. EPA determined that a Part B permit was no longer required if Albemarle managed RCRA wastes for less than 90 days. However, after the BIF regulations ( 40 CFR Part 266, Subpart F) were promulgated in 1991, Albemarle was required to submit a RCRA Part A permit application and certificate of precompliance to obtain interim status for boiler no. 4 since it used hazardous waste as fuel. Boiler no. 4 is located 287 meters from the boundary of the property ( Ethyl Corporation [ Ethyl] 1991). Albemarle ceased burning hazardous waste fuel in boiler no. 4 while air emissions controls were being upgraded in 1992. In 1992, Albemarle elected to exercise a 1 year extension for the compliance testing as required upon renovation of boiler no. 4. Renovations included changes in the waste feed collection system and design of the burner, installation of additional controls and monitors, installation of a baghouse, and replacement of the existing stack. In January 1993, EPA requested that Albemarle prepare and submit a RCRA Part B permit application and a trial burn plan for boiler no. 4. Albemarle submitted these documents to EPA in June 1993. In June 1999, Albemarle submitted a compliance test notification report to EPA, and conducted the test in August. EPA Region 4 and the South Carolina Department of Health and Environmental Control ( DHEC) have been reviewing Albemarle's RCRA Part B permit application since June 6, 2000. 21 2.2.2 Risk Based Facility Prioritization This section describes findings relative to assigning Albemarle into one of the three prioritization groupings using the risk based facility prioritization strategy. Specifically, the following prioritization table presents results for the individual qualitative guiding factors evaluated in the Albemarle Qualitative Risk Check Report ( EPA 2001i). In addition, the table also identifies which prioritization grouping the overall facility was assigned to using the risk based prioritization strategy. The paragraph following the prioritization table provides further justification supporting why the facility was assigned to its specific prioritization grouping. 22 OVERALL RISK BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High Section <IP_ADDRESS>   Volumes and Types of Waste Being Burned

Section <IP_ADDRESS>   Emissions Quantification

Section 2.2.2   Other On site and Off site Emission Sources

Section <IP_ADDRESS>   Terrain Characteristics

Section <IP_ADDRESS>   Land Use for Dispersion Coefficients and Surface Roughness

Section <IP_ADDRESS>   Building Wake Effects

Section <IP_ADDRESS>   Particle Size Distribution

Section <IP_ADDRESS>   Meteorological Conditions

Section <IP_ADDRESS>   Physical Source Parameters

Section <IP_ADDRESS>   ( Receptor) Grid Node Array

Section 4.2.1   Type of Receptors and Exposure Scenario( s)

Section 4.2.2   Proximity to Exposure Scenario Location

Section 4.2.3   Presence or Absence and Proximity of Water Bodies and Water Sheds

Section 4.2.4   Proximity to Special Subpopulations

Section 4.2.5   Presence or Absence and Proximity of Ecological Areas

Section 4.2.6   Public Concerns

Albemarle Orangeburg, South Carolina Risk based Prioritization Grouping: Low Based on ( 1) a review of the individual qualitative guiding factors and their associated groupings presented in the above table, ( 2) consideration of how each qualitative guiding factor interrelates collectively, and ( 3)

a comparison with the 12 other facilities included in this report, Albemarle has been placed in the low prioritization grouping for the MACT based prioritization strategy. Albemarle's designation in the low priority grouping is primarily influenced by the observation that, in general, Albemarle exhibits less site 23 specific characteristics that indicate an increased potential for adverse health impacts. Specifically,

justification for grouping Albemarle into the low prioritization grouping includes the following:

Albemarle only treats on site hazardous waste generated as a byproduct of a manufacturing process. As a result, the waste feed is considered well characterized. In addition, the waste does not contain known PBTs and is not expected to contain other known risk drivers. In comparison, facilities assigned to the medium and high prioritization groupings typically treat both on and off site generated wastes, which are moderately to highly variable and contain known PBTs or risk drivers.

Albemarle only operates one hazardous waste boiler. In comparison, most facilities assigned to the medium and high prioritization groupings typically operate multiple hazardous waste combustors.

Residential, farmer, fisher, and acute exposure scenarios are present in the Albemarle assessment area and are in close proximity ( e. g., within 1 to 2 kilometers) to the facility in several locations. However, Albemarle only operates one boiler, which was outfitted with additional air pollution control technology in 1992, and treats only on site generated waste byproducts. Therefore, potential risk impacts are believed to be less likely than those facilities assigned to the higher priority groupings, which typically treat large volumes of highly variable waste received from both on and off site sources.

Absence of water bodies located within 3 kilometers of the facility that exhibit characteristics that typically result in higher risk impact. In comparison, facilities assigned to the higher prioritization groupings typically have multiple water bodies, which exhibit characteristics indicative of higher risk impacts, and are located within 1 to 1.5 kilometers of the facility boundary.

For a detailed discussion on site specific qualitative guiding factors, refer to the Albemarle Qualitative Risk Check Report ( EPA 2001i). Further justification for assigning Albemarle in the low prioritization grouping is based on the fact that while some of the qualitative guiding factors evaluated for this facility have been individually assigned to the medium or high grouping, these guiding factors alone do not justify promoting Albemarle into one of the higher prioritization groupings. Additionally, due to the absence of complex interplay or additive relationships between these guiding factors, the potential for adverse impacts is lessened and does not warrant designation to a higher prioritization grouping. For example, although the qualitative guiding factor associated with " the type of receptors and exposure scenarios" was assigned to the high priority grouping due to the presence of potential receptors in the close proximity the facility,

Albemarle only operates one boiler, which treats on site generated wastes that are considered well characterized and not known to contain PBTs or other highly toxic compounds known to be risk drivers.

The final decision to assign Albemarle to the low prioritization grouping is also reinforced by comparing 24 the facility with the 12 others included in this report. Albemarle is best represented by site specific characteristics exhibited by the low priority grouping, and lacks commonalities or similar site specific conditions associated with facilities assigned to the high priority grouping.

As discussed in Section 1.2, placement into the low prioritization grouping does not eliminate the need for conducting a site specific risk assessment since facilities in this grouping may still quantitatively result in adverse health impacts. Therefore, consistent with the Albemarle Qualitative Risk Check Report ( EPA 2001i), additional site specific risk assessment activities are still warranted and will help both the facility and permitting authority demonstrate that the facility is operating in a manner protective of human health and the environment.

2.2.3 MACT Based Facility Prioritization This section describes the process and findings relative to assigning Albemarle to one of the three prioritization groupings based on the MACT based facility prioritization strategy. The following prioritization table presents the results for the individual qualitative guiding factors evaluated in the Albemarle Qualitative Risk Check Report ( EPA 2001i). In addition, the table also identifies which facility specific prioritization grouping the Albemarle facility was assigned to. The paragraph following the prioritization table provides the basis for why the facility was assigned to a specific prioritization grouping. 25 MACT BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High Section <IP_ADDRESS>   Volumes and Types of Waste Being Burned

Section <IP_ADDRESS>   Emissions Quantification

Section 2.2.2   Other On site and Off site Emission Sources

Section <IP_ADDRESS>   Terrain Characteristics

Section <IP_ADDRESS>   Land Use for Dispersion Coefficients and Surface Roughness

Section <IP_ADDRESS>   Building Wake Effects

Section <IP_ADDRESS>   Particle Size Distribution

Section <IP_ADDRESS>   Meteorological Conditions

Section <IP_ADDRESS>   Physical Source Parameters

Section <IP_ADDRESS>   ( Receptor) Grid Node Array

Section 4.2.1   Type of Receptors and Exposure Scenario( s)

Section 4.2.2   Proximity to Exposure Scenario Location

Section 4.2.3   Presence or Absence and Proximity of Water Bodies and Water Sheds

Section 4.2.4   Proximity to Special Subpopulations

Section 4.2.5   Presence or Absence and Proximity of Ecological Areas

Section 4.2.6   Public Concerns

Albemarle Orangeburg, South Carolina MACT based Prioritization Grouping: Medium As discussed in Section 1.1, while Phase I MACT standards do not apply to facilities operating hazardous waste fueled boilers, it is believed that development of future Phase II MACT standards, which will apply to facilities operating boilers, will also include a national MACT risk assessment. With this assumption in mind, it is also believed that the qualitative guiding factors listed in section 1.0 and the known limitations of the Phase I national MACT risk assessment will also apply to boilers. As a result, the same criteria for 26 evaluating and assigning facilities that are subject to Phase I MACT standards to one of the three prioritization groupings utilizing the MACT based facility prioritization strategy are also applied to facilities with boilers. Based on ( 1) a review of the individual qualitative guiding factors and their associated groupings presented in the table above, ( 2) considering how each qualitative guiding factor interrelates collectively, and ( 3) a comparison with the 12 other facilities included in this report, Albemarle has been placed in the medium prioritization grouping utilizing the MACT based prioritization strategy.

Albemarle's designation in the medium priority grouping is primarily influenced by the observation that, in general, Albemarle exhibits several site specific characteristics, when compared with all facilities evaluated in this report, which indicate an increased potential that compliance with MACT standards alone may not be protective of human health and the environment. Specifically, the decision to assign Albemarle to the medium prioritization grouping is supported by the following key factors:

Presence of well characterized waste feed generated on site that are known or permitted to contain chemicals not anticipated to be covered under future MACT Standards ( e. g., non dioxin PICs). Since future MACT limits are not expected to apply to all stack emissions, the potential for adverse health impacts from these emissions exists. In comparison with the low and high prioritization groupings, Albemarle exhibits multiple site specific characteristics that indicate an increased potential from those facilities in the low grouping and lack complex individual and additive qualitative guiding factors indicative of the high priority grouping.

Presence of other significant on site fugitive emission sources. Fugitive emission sources were not evaluated in the national MACT risk assessment conducted to support development of current Phase I MACT Standards, nor are they expected to be considered during in the national MACT risk assessment conducted during the development of future Phase II MACT Standards. The presence of over 278,000 pounds of fugitive emissions indicates a clear increased potential for adverse impacts. In addition, when compared with facilities assigned to the low and high prioritization groupings, Albemarle emits significantly larger quantities of fugitive emissions typically associated with facilities assigned to the low prioritization grouping; however, the types of compounds emitted as fugitive emissions are not known risk drivers, as the compounds emitted by facilities in the high prioritization grouping usually are.

Utilizing the same modeling methodologies presented in the national MACT risk assessment for selecting the appropriate terrain option would result in the misclassification of terrain in the Albemarle assessment area. This mis classification increases the potential that concentration and deposition will be underestimated in areas with increased terrain. This issue is especially important in the Albemarle assessment area since many exposure scenario locations are located in areas of increased terrain. Since these areas are present in the assessment area and many of them are known or capable of supporting the default exposure pathways, there is an 27 increased potential that the national MACT risk assessment that is expected to support Phase II MACT limits underestimated risk in these areas. As a result, there is an increased potential that the Phase II MACT limits will result in higher risk estimates than originally predicted. Therefore, protection to human health and the environment under the Phase II MACT standards cannot be confirmed without the introduction of additional site specific information and a site specific refinement to air dispersion modeling methodologies, which were not included in the national MACT risk assessment to support Phase I MACT standards.

Particle size distributions utilized in the national MACT risk assessment to support Phase I MACT standards were not source specific but were generalized based on combustion unit type. As stated above, it is assumed that the national MACT risk assessment to support Phase II MACT standards will utilize the same methodologies as those used in the national MACT risk assessment to support Phase I MACT standards. Defining particle size distribution by combustion unit type introduces significant uncertainty, thereby resulting in the inability to accurately quantify risk impacts. Due to this potentially significant uncertainty, protection based on compliance with future Phase II MACT Limits cannot be inferred based on this methodology, but will require additional site specific risk assessment activities, including introduction of representative particle size distribution data collected as part of a trial burn designed to support a site specific risk assessment.

The national MACT risk assessment to support Phase I MACT standards did not include an evaluation of acute exposure. Since ( 1) actual and potential acute exposure scenario locations are located in close proximity to the facility; ( 2) Albemarle reports annual emissions of over 2,000 pounds of hydrogen cyanide, which could have severe effects on acute receptors; and ( 3) it is assumed that future MACT risk assessments will also not include an evaluation of acute exposure, no definitive conclusions regarding the protectiveness of MACT standards can be made without additional risk assessment activities.

Residential exposure scenario locations are within close proximity ( i. e., within 1 kilometer) to the Albemarle facility. The Phase I National MACT Risk Assessment utilized 16 sector based grid averaging. Based on the assumption that the same approach will be utilized in future MACT risk assessments, this approach, when applied on a site specific basis, may result in the averaging of locally elevated media concentrations ( hotspots), which could result in the underestimation of upper bound risk estimates for those exposure scenarios located in close proximity to Albemarle. Due to this potential underestimation, protection based on compliance with future Phase II MACT limits alone cannot be inferred, which further establishes the need for additional risk assessment activities.

Established presence of significant ecological habitats and ecological receptors, including threatened or endangered species in close proximity to Albemarle. The national MACT Risk Assessment did not include a separate analysis or consideration of threatened or endangered species. Based on the assumption that future MACT risk assessment will also not include an evaluation of threatened or endangered species, 28 there is an increased potential that future Phase II Standards may not ensure protection of human health and the environment.

Presence of documented public concern issues. The National MACT Risk Assessment did not consider potential impacts associated with public concerns. The permitting authority may need to consider additional risk management options or permit strategies, in addition to future Phase II MACT limits, to ensure public concerns have been addressed.

For a detailed discussion on site specific qualitative guiding factors, refer to the Albemarle Qualitative Risk Check Report ( EPA 2001i). Further justification for assigning Albemarle to the medium prioritization grouping is based on the fact that while some of the qualitative guiding factors evaluated for this facility have been individually assigned to the low or high group, these individual factors alone do not justify prioritizing Albemarle into the low or high grouping. In addition, when compared with facilities in the low prioritization grouping, Albemarle clearly exhibits several unique site specific factors which indicate that future MACT standards may not satisfy RCRA protectiveness mandates. Furthermore, when compared with facilities in the high prioritization groupings, Albemarle clearly lacks the complex or additive relationships between qualitative guiding factors, which are common to those facilities assigned to the high prioritization grouping.

As discussed in Section 1.2, placement into the medium prioritization group confirms the need for conducting additional site specific risk assessment activities, since facilities in this grouping have an increased potential for contributing to adverse health impacts. Therefore, consistent with the Albemarle Qualitative Risk Check Report ( EPA 2001i), additional site specific risk assessment activities are still warranted and will help both the facility and permitting authority demonstrate that compliance with future MACT Standards meet the requirements of the RCRA omnibus provisions.

2.3 CATALYTICA PHARMACEUTICALS, INC.

This section presents the information and approach used in assigning Catalytica Pharmaceuticals, Inc.

( Catalytica) to one of the three prioritization groupings based on ( 1) the facility's overall potential to cause adverse health impacts and ( 2) an assessment of the protectiveness of current or future MACT standards to determine if additional permit limits may be required to ensure protection of human health and the environment. Section 2.3.1 presents facility specific background information including process descriptions and permit history. Section 2.3.2 describes the process and findings used to assign a facility to 29 one of the three prioritization groupings specific to the risk based facility prioritization strategy. Section 2.3.3 describes the process and findings used to assign a facility to one of the three prioritization groupings following the MACT based facility prioritization strategy. Specific sources of information used to evaluate the Catalytica facility are cited and referenced at the end of this report.

2.3.1 Facility Information The following summarizes the facility specific information provided in Section <IP_ADDRESS> of the Catalytica Qualitative Risk Check Report ( EPA 2001b). This information is intended to provide a general facility overview including process descriptions and permit history.

Catalytica owns and operates a chemical manufacturing and pharmaceutical production facility in Greenville, North Carolina. The facility is subject to RCRA requirements promulgated at 40 CFR 260 through 262, 264, and 270 and to the equivalent North Carolina Department of the Environment and Natural Resources ( NCDENR) state regulations. The facility is located about 4.7 kilometers north of Greenville, Pitt County, North Carolina, near the junction of U. S. Highway ( US) 13N and North Carolina Highway ( NC) 11 with US 264. The facility was originally owned by Burroughs Wellcome and has been in operation since 1970. The facility was purchased by Catalytica in the mid to late 1990s ( Tetra Tech 2001b). The property consists of approximately 600 acres, of which 175 acres are developed with the 49 buildings that comprise the facility ( Catalytica 2000). These buildings house the chemical manufacturing operations, the pharmaceutical production operations, and their associated warehouses; the research and development laboratories; the engineering facilities building; the environmental operations; administrative offices; and the hazardous waste management facility. The hazardous waste management facility stores and treats hazardous waste generated by facility operations. This facility has two waste drum storage areas, which contain 450 barrels, 16 hazardous waste storage tanks, four waste incinerators, and a liquid waste evaporator ( International Center for Toxicology and Medicine [ ICTM] 1999).

Catalytica treats 98 to 100 percent of the hazardous waste generated at the facility on site. No waste is accepted at the facility from off site sources. Hazardous waste is accumulated and stored either in 55

gallon drum containers, 500 to 5,000 gallon transfer containers, or fixed tanks ( ICTM 1999). The waste consists of two groups: ( 1) hazardous waste generated by chemical manufacturing operations, which 30 include liquids that are corrosive, reactive, ignitable, or toxic and solid waste that has been contaminated with spent solvents or has toxic characteristics, and ( 2) hazardous wastes generated by other departments,

which include off specification, commercial chemicals and laboratory packs of laboratory chemicals.

These wastes are burned in one of the four on site incinerators, or they are sent to an approved RCRA treatment, storage, and disposal facility. Catalytica does not perform land disposal of hazardous waste ( ICTM 1999).

Catalytica operates four waste incinerators: Prenco, NAO, McGill I, and McGill II; each has its own stack. The Prenco incinerator was manufactured by Prenco Manufacturing Company and is 21 feet long with a cross sectional area of 5.59 square feet. The NAO incinerator was manufactured by the National Air Oil Burner Company, Inc. and is 14.75 feet long with a cross sectional area of 12.6 square feet. The McGill I and McGill II incinerators were manufactured by McGill Americas, Inc. ( McGill Americas).

Both incinerators are 20 feet long with a cross sectional area of 36.9 square feet ( Compliance Strategies and Solutions, Inc. [ CSS] 1999).

The McGill II incinerator is the only incinerator equipped with an air pollution control system ( APCS).

The APCS includes a water weir, spray contractor, quench tank, Calvery wet scrubber, packed tower absorber, and wet electrostatic precipitator; the APCS was designed primarily to remove particulate matter and acid gases ( hydrochloric acid and chlorine) before the emissions are introduced into the atmosphere.

All of the incinerators are operated under positive pressure and have sealed wall construction to eliminate fugitive emissions from their combustion chambers. In addition, an automatic waste feed cut off ( AWFCO) system, which prevents the feeding of hazardous waste if burning conditions are outside the permitted limits, has been incorporated into the operating systems of each of the incinerators ( CSS 1999).

Natural gas provides the auxiliary fuel that is simultaneously fed to all of the incinerators along with the hazardous waste. The natural gas has a heat content of approximately 1,000 British thermal units per standard cubic foot ( Btu/ scf). The Prenco and McGill I incinerators are each fired by an air atomization burner that was designed by McGill Americas. The McGill II incinerator is fired by three air atomization burners that were also designed by McGill Americas. The NAO incinerator is fired by a number 1 SAR fuel oil burner, which steam atomizes the hazardous waste with the auxiliary fuel in an NAO cylindrical type gas burner for efficient combustion ( CSS 1999). 31 The Catalytica facility has been in operation since 1970; however, available information does not indicate whether the facility operated a hazardous waste incinerator at this time. Burroughs Wellcome was initially permitted in 1989 by the NCDENR under RCRA Part B as a treatment, storage, and disposal facility. A trial burn was performed, and an analysis of metals and particulate matter was conducted to support the 1989 permit application. Catalytica then purchased the facility in the mid to late 1990s and has been in operation under the 1989 permit limits since the time the facility was purchased. The permit expired in October 1999, and a new Part A and B permit application, which includes a trial burn plan, risk burn plan,

and risk assessment protocol, was submitted in 1999 and is currently under review by EPA Region 4 and the NCDENR. No trial burn or risk burn has been conducted to support a site specific risk assessment at the facility to date ( Tetra Tech 2001b). Currently, Catalytica is operating its incinerators in accordance with the 1989 RCRA permit limits while the Part A and Part B permit application is reviewed by EPA Region 4 and NCDENR.

2.3.2 Risk Based Facility Prioritization This section describes findings relative to assigning Catalytica to one of the three prioritization groupings using the risk based facility prioritization strategy. Specifically, the following prioritization table presents the results for the individual qualitative guiding factors evaluated in the Catalytica Qualitative Risk Check Report ( EPA 2001b). In addition, the table also identifies which prioritization grouping the overall facility was assigned to using the risk based facility prioritization strategy. The paragraph following the prioritization table provides further justification supporting why the facility was assigned to its specific prioritization grouping.

OVERALL RISK BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High Section <IP_ADDRESS>   Volumes and Types of Waste Being Burned

Section <IP_ADDRESS>   Emissions Quantification

Section 2.2.2   Other On site and Off site Emission Sources

Section <IP_ADDRESS>   Terrain Characteristics

Section <IP_ADDRESS>   Land Use for Dispersion Coefficients and Surface Roughness

Section <IP_ADDRESS>   Building Wake Effects

OVERALL RISK BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High 32 Section <IP_ADDRESS>   Particle Size Distribution

Section <IP_ADDRESS>   Meteorological Conditions

Section <IP_ADDRESS>   Physical Source Parameters

Section <IP_ADDRESS>   ( Receptor) Grid Node Array

Section 4.2.1   Type of Receptors and Exposure Scenario( s)

Section 4.2.2   Proximity to Exposure Scenario Location

Section 4.2.3   Presence or Absence and Proximity of Water Bodies and Water Sheds

Section 4.2.4   Proximity to Special Subpopulations

Section 4.2.5   Presence or Absence and Proximity of Ecological Areas

Section 4.2.6   Public Concerns

Catalytica Greenville, North Carolina Risk based Prioritization grouping: Medium Based on ( 1) a review of the individual qualitative guiding factors and their associated groupings presented in the above table, and ( 2) considering how each qualitative guiding factor interrelates collectively,

Catalytica has been placed in the medium prioritization grouping utilizing the overall risk based prioritization strategy. The medium designation is intended to heighten the awareness of several key factors that indicate an increased potential for adverse impacts to human health and the environment. When compared with the 12 other facilities included in this summary report, Catalytica exhibits multiple characteristics consistent with those facilities assigned to the medium prioritization grouping. Specifically,

the decision to Catalytica to the medium prioritization grouping is supported by the following key factors:

Catalytica treats a moderately variable hazardous waste feed that is listed under several RCRA waste codes, including some that contain compounds that are known PBTs and common risk drivers; however, the waste codes that are known to contain PBTs and common risk drivers only make up a minor percentage of the waste feed. 33 Additionally, Catalytica only treats waste that is generated on site. In comparison, facilities in the high prioritization group typically treat highly variable waste that is received from both on and off site sources, and facilities in the low prioritization grouping typically treat well characterized waste that is generated on site.

Catalytica operates four hazardous waste incinerators, which are capable of operating simultaneously. In comparison, facilities assigned to the low prioritization grouping typically only operate a single hazardous waste combustor.

Catalytica has not performed a trial burn designed to support a site specific risk assessment; therefore, limited information is available.

The Catalytica facility is located in close proximity to residential, farmer, and fisher exposure scenarios. For example, the closest residential exposure scenario is located approximately 1 kilometer north northwest of the facility.

Presence of water bodies within 3 kilometers of the facility that exhibit characteristics that typically result in higher risk impact.

Closest known special subpopulation is located approximately 2 kilometers southsoutheast of the facility.

No documented public concerns are associated with facility operations. In comparison, facilities assigned to the high prioritization groupings typically have documented public concern issues For a detailed discussion on site specific qualitative guiding factors, refer to the Catalytica Qualitative Risk Check Report ( EPA 2001b). Further justification for assigning Catalytica to the medium prioritization grouping is based on the fact that while some of the qualitative guiding factors evaluated for this facility have been individually assigned to the low or high group, when these factors are considered collectively, justification for assigning Catalytica to one of the other prioritization groupings is not supported. Catalytica was not assigned to the high prioritization grouping because when compared with those facilities assigned to the high prioritization grouping, Catalytica clearly lacked the complicating factors associated with the facilities assigned to the high prioritization grouping. For example, although the qualitative guiding factor associated with " proximity to exposure scenario location" was individually grouped into the high prioritization grouping due to the presence of receptors within 1 kilometer of the facility, because the volumes and types of wastes treated at the Catalytica facility are generated on site as a byproduct of the manufacturing process and, therefore, are considered to be only moderately variable,

inadequate justification was available to support allocation into the high prioritization grouping. Therefore,

based on a review of site specific characteristics and a comparison to the other facilities in this report, it 34 has been determined that Catalytica is best represented by facilities assigned to the medium priority grouping and lacks commonalities or similar site specific conditions associated with facilities assigned to the low and high priority groupings.

As discussed in Section 1.2, placement into the medium prioritization group confirms the need for a sitespecific risk assessment since facilities in this grouping have an increased potential to contribute to adverse impacts to human health and the environment. Further, consistent with the findings presented in the Catalytica Qualitative Risk Check Report ( EPA 2001b), a site specific quantitative risk assessment at the Catalytica facility is recommended to provide the facility and permitting authority with the information necessary to assess potential liabilities and ensure the protection of human health and the environment.

2.3.3 MACT Based Facility Prioritization This section describes the process and findings relative to assigning Catalytica to one of the three prioritization groupings based on the MACT based facility prioritization strategy. The following prioritization table presents results for the individual qualitative guiding factors evaluated in the Catalytica Qualitative Risk Check Report ( EPA 2001b). In addition, the table also identifies which facility specific prioritization grouping the overall facility was assigned to. The paragraph following the prioritization table provides the basis for why a facility was assigned to its specific prioritization grouping.

MACT BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High Section <IP_ADDRESS>   Volumes and Types of Waste Being Burned

Section <IP_ADDRESS>   Emissions Quantification

Section 2.2.2   Other On site and Off site Emission Sources

Section <IP_ADDRESS>   Terrain Characteristics

Section <IP_ADDRESS>   Land Use for Dispersion Coefficients and Surface Roughness

Section <IP_ADDRESS>   Building Wake Effects

Section <IP_ADDRESS>   Particle Size Distribution

Section <IP_ADDRESS>   Meteorological Conditions

MACT BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High 35 Section <IP_ADDRESS>   Physical Source Parameters

Section <IP_ADDRESS>   ( Receptor) Grid Node Array

Section 4.2.1   Type of Receptors and Exposure Scenario( s)

Section 4.2.2   Proximity to Exposure Scenario Location

Section 4.2.3   Presence or Absence and Proximity of Water Bodies and Water Sheds

Section 4.2.4   Proximity to Special Subpopulations

Section 4.2.5   Presence or Absence and Proximity of Ecological Areas

Section 4.2.6   Public Concerns

Catalytica Greenville, North Carolina MACT based Prioritization Grouping: Medium Based on ( 1) a review of the individual qualitative guiding factors and their associated groupings presented in the above table, ( 2) considering how each qualitative guiding factor interrelates collectively, and ( 3) a comparison with the 12 other facilities included in this report, Catalytica has been placed in the medium prioritization grouping utilizing the MACT based prioritization strategy. Catalytica's designation in the medium priority grouping is primarily influenced by the observation that, in general, Catalytica exhibits several site specific characteristics, when compared with all facilities evaluated in this report, which indicate an increased potential that compliance with MACT standards alone may not be protective of human health and the environment. Specifically, the decision to assign Catalytica to the medium prioritization grouping is supported by the following key factors:

Presence of moderately variable hazardous waste known or permitted to contain chemicals not covered under current MACT Standards ( e. g., non dioxin PICs). Since MACT limits do not apply to all stack emissions, the potential for adverse health impacts from these emissions exists. In comparison with the low and high prioritization groupings, Catalytica exhibits multiple site specific characteristics that indicate an increased potential from those facilities in the low grouping, and lack complex individual 36 and additive qualitative guiding factors indicative of the high priority grouping.

Presence of other on site sources not evaluated in the national MACT risk assessment ( e. g., 16,685 pounds of emissions from fugitive sources). The presence of over 16,000 pounds of fugitive emissions indicates a clear increased potential for adverse impacts. In addition, when compared with facilities assigned to the low and high prioritization groupings, Catalytica emits larger quantities of fugitive emissions typically associated with facilities assigned to the low prioritization grouping; however, the types of compounds emitted as fugitive emissions are not known risk drivers, as are the compounds typically emitted by facilities in the high prioritization grouping.

modeling methodologies presented in the national MACT risk assessment would result in the mis classification of terrain in the assessment area resulting in an increased potential for underestimating concentration and deposition, especially in areas associated with increased terrain elevation. Since areas with increased terrain elevation are present in the assessment area, and many of them are known or capable of supporting the default exposure pathways, there is an increased potential that the National MACT Risk assessment underestimated risk in these areas. As a result, there is an increased potential that the Phase I MACT limits evaluated in the National MACT Risk Assessment resulted in higher risk estimates than originally predicted. Therefore, protection to human health and the environment under the Phase I MACT Standards cannot be confirmed without the introduction of additional site specific information and a site specific refinement to air dispersion modeling methodologies.

Particle size distributions utilized in the National MACT Risk Assessment were not source specific, but were generalized based on combustion unit type. Defining particle size distribution by combustion unit type introduces significant uncertainty, thereby resulting in the inability to accurately quantify risk impacts. Due to this potentially significant uncertainty, protection based on compliance with Phase I MACT Limits cannot be inferred, but require additional site specific risk assessment activities including introduction of representative particle size distribution data collected as part of a trial burn designed to support a site specific risk assessment.

The National MACT Risk Assessment did not include an evaluation of acute exposure. Since actual and potential acute exposure scenario locations are located in close proximity to the facility, no definitive conclusions regarding the protectiveness of MACT standards can be made without additional risk assessment activities.

Residential exposure scenario locations are located in close proximity ( i. e., within 1 kilometer) to the Catalytica facility. The Phase I National MACT Risk Assessment utilized 16 sector based grid averaging. This approach, when applied on a site specific basis, may result in the averaging of locally elevated media concentrations ( hotspots). This averaging could result in the underestimation of upper bound risk estimates for those exposure scenarios located in close proximity to Catalytica. Due to this potential underestimation, protection based on compliance with Phase I MACT limits alone cannot be inferred, which further establishes the need for additional risk assessment activities. 37

Presence of significant ecological habitats and ecological receptors in close proximity to Catalytica, including several threatened or endangered species. Because the national MACT risk assessment did not include a separate analysis or consideration of threatened or endangered species, there is an increased potential that current MACT standards may not ensure protection of human health and the environment.

For a detailed discussion on site specific qualitative guiding factors, refer to the Catalytica Qualitative Risk Check Report ( EPA 2001b). Further justification for assigning Catalytica to the medium prioritization grouping is based on the fact that while some of the qualitative guiding factors evaluated for this facility have been individually assigned to the low or high group, these individual factors alone do not justify prioritizing Catalytica into the low or high grouping. In addition, when compared with facilities in the low prioritization grouping, Catalytica clearly exhibits several unique site specific factors which indicate that current MACT standards may not satisfy RCRA protectiveness mandates. Furthermore, when compared with facilities in the high prioritization groupings, Catalytica clearly lacks the complex or additive relationships between qualitative guiding factors that are common to those facilities assigned to the high prioritization grouping. 38 As discussed in Section 1.2, placement into the medium prioritization group confirms the need for conducting additional site specific risk assessment activities, since facilities in this grouping have an increased potential for contributing to adverse health impacts. Therefore, consistent with the Catalytica Qualitative Risk Check Report ( EPA 2001b), additional site specific risk assessment activities are still warranted and will help both the facility and permitting authority demonstrate that compliance with current MACT standards meet the requirements of the RCRA omnibus provisions. 39 2.4 DIVERSIFIED SCIENTIFIC SERVICES, INC.

This section presents the information and approach used in assigning Diversified Scientific Services, Inc.

( DSSI) to one of the three prioritization groupings based on ( 1) the facility's overall potential for resulting in adverse health impacts and ( 2) an assessment of the protectiveness of current or future MACT standards to determine if additional permit limits may be required to ensure protection of human health and the environment. Section 2.4.1 presents facility specific background information including process descriptions and permit history. Section 2.4.2 describes the process and findings used to assign a facility to one of the three prioritization groupings specific to the risk based facility prioritization strategy. Section 2.4.3 describes the process and findings used to assign a facility to one of the three prioritization groupings following the MACT based facility prioritization strategy. Specific sources of information used to evaluate the DSSI facility are cited and referenced at the end of this report.

2.4.1 Facility Information The following summarizes the facility specific information provided in Section <IP_ADDRESS> of the DSSI Qualitative Risk Check Report ( EPA 2001h). This information is intended to provide a general facility overview including process descriptions and permit history.

DSSI owns and operates an industrial mixed waste boiler system, which is used specifically to incinerate hazardous waste fuels, including aqueous and organic liquids and solvents, scintillation liquids, pumpable paints, and waste and hydraulic oils with beneficial recovery of thermal energy. The DSSI boiler is subject to general guidance by the Tennessee Department of Environment and Conservation ( TDEC) and the requirements of RCRA promulgated under 40 CFR 266 by U. S. EPA. Additionally, DSSI is permitted to treat most RCRA listed wastes under waste codes " D," " F," " K," " P," " U;" mixed wastes with specific low radioactivity characteristics; and low level radioactive nonhazardous wastes.

The DSSI facility is located near Highway 58, approximately 3 kilometers east of the city of Kingston and 21 kilometers southeast of Oak Ridge, Tennessee. The DSSI incinerator facility covers 80 acres in the Kingston area of Roane County, Tennessee. An office complex and school for the disabled border the DSSI facility to the west. Land use surrounding the facility is predominantly agricultural and forested land 40 with several residential communities scattered throughout. In addition, the facility is bordered by a singlefamily residence located to the southeast. Constructed features on the facility property include ( 1) administrative, laboratory, and processing buildings; ( 2) a retention pond; ( 3) two guardhouses; ( 4) a live drum storage area; ( 5) a maintenance area; ( 6) a tank farm; and ( 7) two trailers.

DSSI receives hazardous wastes from a variety of off site sources, including government installations,

hospitals, industrial firms, power plants, research laboratories, and universities. Hazardous wastes are received in pails, totes, drums, or bulk liquid tanks and are identified as " containerized liquids." All hazardous wastes are analyzed before they are burned to ensure efficiency of combustion and compliance with constituent limits.

Containerized liquids are decanted and pumped into two test tanks in the process building to allow for intermediate bulking of approximately 1,000 gallons of waste. Immediately northwest of the process building is a covered bulk liquid tank farm with a coated concrete truck bay for unloading. From the test tanks, waste liquids are pumped into one of five tanks in the tank farm to store and blend liquid wastes into fuels before they are incinerated in the boiler system. Bulk tankers are unloaded directly into any one of the five tanks located in the tank farm area. The tank farm is constructed with a retention slab and concrete berm and is designed to contain spilled wastes and fire suppression water.

Prepared waste fuel blends, based on specific physical, chemical, and radiological properties, are transferred from the tank farm back to the waste fuel surge tank located in the process building. The surge tank is utilized to feed the waste blends directly to the boiler system via positive displacement feed pumps.

The boiler system process is controlled by established maximum and minimum operational parameters maintained through the use of AWFCOs.

The mixed waste boiler consists of two main elements: a high intensity dual fuel burner, and a direct fired boiler. The burner uses purchased propane to bring the boiler up to normal operational temperature and pressure. Waste fuel is then added on a mass rate basis while the propane converts to an " as needed" basis and ensures system steam demand is maintained. The system features waste feed mechanisms, combustion chambers, a continuous emissions monitoring system ( CEMS), an APCS, and a flue gas stack. The APCS consists of a dual column spray dryer and quench, a baghouse, a packed bed scrubber and mist eliminator, 41 a steam reheater, and a high energy particulate air ( HEPA) filter. Residue from the pollution control process is regarded as generated waste and is disposed of at a licensed and permitted disposal facility.

Information on the regulatory history of the boiler and facility was limited to the BIF Revised Certification of Compliance for Hazardous Waste Boiler Operation ( DSSI 1996). On October 18, 1995, DSSI revised its certification of compliance to include improvements to the APCS equipment and boiler system as specified in 40 CFR 266.103 ( b)( 3). Two days later, DSSI provided a compliance test notification to EPA Region IV. After discussions on conflicting parameters and proposed test conditions, DSSI submitted another certification of compliance to EPA Region IV on January 26, 1996. Compliance testing was performed February 22 through 24, 1996, to demonstrate that the boiler was operating within its emissions limits and to establish operational condition limits. The facility is currently operating under interim permit status pursuant to 40 CFR Part 266.

2.4.2 Risk Based Facility Prioritization This section describes the findings relative to assigning DSSI to one of the three prioritization groupings using the risk based facility prioritization strategy. Specifically, the following prioritization table presents the results for the individual qualitative guiding factors evaluated in the DSSI Qualitative Risk Check Report ( EPA 2001h). In addition, the table also identifies which prioritization grouping the overall facility was assigned to using the risk based facility prioritization strategy. The paragraph following the prioritization table provides further justification supporting why the facility was assigned to its specific prioritization grouping. 42 OVERALL RISK BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High Section <IP_ADDRESS>   Volumes and Types of Waste Being Burned

Section <IP_ADDRESS>   Emissions Quantification

Section 2.2.2   Other On site and Off site Emission Sources

Section <IP_ADDRESS>   Terrain Characteristics

Section <IP_ADDRESS>   Land Use for Dispersion Coefficients and Surface Roughness

Section <IP_ADDRESS>   Building Wake Effects

Section <IP_ADDRESS>   Particle Size Distribution

Section <IP_ADDRESS>   Meteorological Conditions

Section <IP_ADDRESS>   Physical Source Parameters

Section <IP_ADDRESS>   ( Receptor) Grid Node Array

Section 4.2.1   Type of Receptors and Exposure Scenario( s)

Section 4.2.2   Proximity to Exposure Scenario Location

Section 4.2.3   Presence or Absence and Proximity of Water Bodies and Water Sheds

Section 4.2.4   Proximity to Special Subpopulations

Section 4.2.5   Presence or Absence and Proximity of Ecological Areas

Section 4.2.6   Public Concerns

DSSI Kingston, Tennessee Risk based Prioritization Grouping: High Based on ( 1) a review of the individual qualitative guiding factors and their associated groupings presented in the above table, and ( 2) consideration of how each qualitative guiding factor interrelates collectively,

DSSI has been assigned to the high prioritization group based on the overall risk based prioritization strategy. In addition, when compared with the 12 other facilities included in this summary report, DSSI clearly exhibits multiple complicating factors that individually or collectively support its designation in the 43 high prioritization group. This designation is intended to heighten the awareness of several key factors that indicate an increased potential for adverse impacts to human health and the environment. Specifically, the decision to assign DSSI to the high prioritization grouping is supported by the following key factors:

DSSI treats hazardous waste that is received from both on and off site sources. In comparison, facilities assigned to the lower prioritization grouping typically only treat waste generated onsite.

The hazardous waste stream treated at DSSI is considered to be highly variable as the facility is permitted to treat waste listed under several RCRA waste codes, including some that contain known PBTs and common risk drivers. In comparison, facilities in the lower prioritization groupings typically treat better characterized waste that do not contain known PBTs and common risk drivers.

DSSI is permitted to process " mixed wastes" with specific low radioactivity characteristics, as well as low level radioactive non hazardous wastes with atomic numbers 1 83, 88, 90, and 92.

DSSI operates only one hazardous waste boiler, but reports that over 80 percent of its emissions are from fugitive sources. Also, DSSI is located within 10 kilometers of the Toxic Substances Control Act ( TSCA) incinerator, which is located on site at the East Tennessee Technical Park.

DSSI has not performed a trial burn designed to support a site specific risk assessment; therefore, limited information is available.

The DSSI facility is located in close proximity to residential and farmer exposure scenarios. For example, the closest residential exposure scenario is located less than 1 kilometer north of the facility. In comparison, facilities in the lower prioritization groupings are typically located more than 1.5 kilometers from exposure scenarios.

The closest known special subpopulation is located adjacent to the facility to the west. In comparison, facilities in the lower prioritization groupings are typically located more than 2 kilometers from special subpopulations.

For a detailed discussion on site specific qualitative guiding factors, refer to the DSSI Qualitative Risk Check Report ( EPA 2001h). Further justification for assigning DSSI to the high prioritization group is based on the relationship or complex interplay associated with many of the qualitative guiding factors individually assigned to the high group. For example, the combination of a highly variable waste feed received from both on and off site sources, compounded by the presence of reported on site fugitive emissions that comprise more that 80 percent of the emissions reported at the facility, coupled with the presence and close proximity of residential and farmer exposure scenarios, significantly elevates the 44 potential for adverse impacts to human health and the environment. Therefore, based on a review of sitespecific characteristics and a comparison to the other facilities in this report, it has been determined that DSSI is best represented by facilities assigned to the high priority grouping and lacks commonalities or similar site specific conditions associated with facilities assigned to the lower priority groupings.

As discussed in Section 1.2, placement into the high prioritization group confirms the need for conducting additional site specific risk assessment activities at the DSSI facility in order to quantify risk impacts to human health and the environment, since facilities in this grouping have the largest potential for contributing to adverse health impacts. Therefore, consistent with the DSSI Qualitative Risk Check Report ( EPA 2001h), additional site specific risk assessment activities are warranted and will help both the facility and permitting authority demonstrate that the DSSI facility meets the requirements of the RCRA omnibus provisions.

2.4.3 MACT Based Facility Prioritization This section describes the process and findings relative to assigning DSSI to one of the three prioritization groupings based on the MACT based facility prioritization strategy. The following prioritization table presents the results for the individual qualitative guiding factors evaluated in the DSSI Qualitative Risk Check Report ( EPA 2001h). In addition, the table also identifies which facility specific prioritization group the DSSI facility was assigned to. The paragraph following the prioritization table provides the basis for why the facility was assigned to its specific prioritization grouping. 45 MACT BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High Section <IP_ADDRESS>   Volumes and Types of Waste Being Burned

Section <IP_ADDRESS>   Emissions Quantification

Section 2.2.2   Other On site and Off site Emission Sources

Section <IP_ADDRESS>   Terrain Characteristics

Section <IP_ADDRESS>   Land Use for Dispersion Coefficients and Surface Roughness

Section <IP_ADDRESS>   Building Wake Effects

Section <IP_ADDRESS>   Particle Size Distribution

Section <IP_ADDRESS>   Meteorological Conditions

Section <IP_ADDRESS>   Physical Source Parameters

Section <IP_ADDRESS>   ( Receptor) Grid Node Array

Section 4.2.1   Type of Receptors and Exposure Scenario( s)

Section 4.2.2   Proximity to Exposure Scenario Location

Section 4.2.3   Presence or Absence and Proximity of Water Bodies and Water Sheds

Section 4.2.4   Proximity to Special Subpopulations

Section 4.2.5   Presence or Absence and Proximity of Ecological Areas

Section 4.2.6   Public Concerns

DSSI Kingston, Tennessee MACT based Prioritization Grouping: High As discussed in Section 1.1, while Phase I MACT standards do not apply to facilities operating hazardous waste fueled boilers, it is believed that development of future Phase II MACT standards, which will apply to facilities operating boilers, will also include a national MACT risk assessment. With this assumption in mind, it is also believed that the qualitative guiding factors listed in section 1.0 and the known limitations of the Phase I national MACT risk assessment will also apply to boilers. As a result, the same criteria for 46 evaluating and assigning facilities that are subject to Phase I MACT standards to one of the three prioritization groupings utilizing the MACT based facility prioritization strategy are also applied to facilities with boilers. Based on ( 1) a review of the individual qualitative guiding factors and their associated groupings presented in the table above, and ( 2) consideration of how each qualitative guiding factor interrelates collectively, DSSI has been placed in the high prioritization group for the MACT based prioritization strategy. In addition, when compared with the 12 other facilities included in this summary report, DSSI clearly exhibits multiple complicating factors that individually or collectively support its designation in the high prioritization group. This designation is intended to heighten the awareness of several key factors that indicate a remaining potential for adverse impacts to human health and the environment exists even after complying with current MACT standards. Specifically, the decision to assign DSSI to the high prioritization grouping is supported by the following key factors:

Presence of highly variable hazardous waste received from both on and off site sources known or permitted to contain chemicals not expected to be covered under future MACT standards ( e. g., non dioxin PICs, 10 of the 12 PBTs). Since future MACT limits are not expected to apply to these stack emissions, the potential for adverse health impacts from these emissions exists. In comparison with the lower prioritization groupings, DSSI exhibits multiple site specific characteristics and complex individual and additive qualitative guiding factors, which indicate an increased potential from those facilities in the low and medium groupings.

Presence of other significant on site fugitive emission sources ( e. g., 80 percent of emissions from fugitive sources as reported in 1999 TRI inventory). Fugitive emission sources were not evaluated in the national MACT risk assessment conducted to support development of current Phase I MACT Standards, nor are they expected to be considered during the national MACT risk assessment conducted during development of future Phase II MACT Standards. The presence of potentially significant amounts of fugitive emissions indicates a clear increased potential for adverse impacts. In addition, when compared with facilities assigned to the lower prioritization groupings, DSSI is capable of emitting more known risk drivers as fugitive emissions due to its highly variable waste feed than the facilities in the low and medium groupings.

Presence of off site emission sources, including the TSCA incinerator, which is located within 10 kilometer of the DSSI facility boundary. Aggregate off site emission sources were not included in the national MACT risk assessment supporting Phase I MACT limits and are not expected to be included in the national MACT risk assessment anticipated to support Phase II MACT limits. The presence of other hazardous waste combustion facilities in close proximity to the DSSI facility indicates an increased potential for adverse impacts to receptors.

Utilizing the same modeling methodologies presented in the national MACT risk assessment for selecting the appropriate terrain option would result in the mis 47 classification of terrain in the DSSI assessment area. This mis classification increases the potential that concentration and deposition will be underestimated in areas with increased terrain. This issue is especially important in the DSSI assessment area since many exposure scenario locations are located in areas of increased terrain. Since areas with increased terrain elevation are present in the assessment area and many of them are known or capable of supporting the default exposure pathways, there is an increased potential that the national MACT risk assessment that is expected to support Phase II MACT limits underestimated risk in these areas. As a result, there is an increased potential that the Phase II MACT limits will result in higher risk estimates than originally predicted. Therefore, protection to human health and the environment under the Phase II MACT standards cannot be confirmed without the introduction of additional site specific information and a site specific refinement to air dispersion modeling methodologies, which were not included in the national MACT risk assessment to support Phase I MACT standards.

Particle size distributions utilized in the national MACT risk assessment to support Phase I MACT standards were not source specific, but were generalized based on combustion unit type. As stated above, it is assumed that the national MACT risk assessment to support Phase II MACT standards will utilize the same methodologies as those used in the national MACT risk assessment to support Phase I MACT standards. Defining particle size distribution by combustion unit type introduces significant uncertainty, thereby resulting in the inability to accurately quantify risk impacts. Due to this potentially significant uncertainty, protection based on compliance with future Phase II MACT Limits cannot be inferred based on this methodology, but will require additional site specific risk assessment activities including introduction of representative particle size distribution data collected as part of a trial burn designed to support a sitespecific risk assessment.

The national MACT risk assessment conducted to support Phase I MACT limits did not include an evaluation of acute exposure, and it is assumed that the national MACT risk assessment to support Phase II MACT standards will utilize the same methodologies. Since actual and potential acute exposure scenario locations are located in close proximity to the facility, no definitive conclusions regarding the protectiveness of MACT standards can be made without additional risk assessment activities.

Residential exposure scenario locations are located in close proximity ( i. e., within 1 kilometer) to the DSSI facility. The Phase I national MACT risk assessment utilized 16 sector based grid averaging. Based on the assumption that the same approach will be utilized in future MACT risk assessments, this approach, when applied on a site specific basis, may result in the averaging of locally elevated media concentrations ( hotspots), resulting in the potential underestimation of upper bound risk estimates for those exposure scenarios located in close proximity to DSSI. Due to this potential underestimation, protection based on compliance with future Phase II MACT limits alone cannot be inferred, which further establishes the need for additional risk assessment activities.

Presence of special subpopulations located adjacent to the DSSI facility boundary. 48 The national MACT Risk Assessment did not include a separate analysis or consideration of special subpopulations. Based on the assumption that future MACT risk assessment will also not include an evaluation of special subpopulations, there is an increased potential that future Phase II Standards may not ensure protection to these receptors.

For a detailed discussion on site specific qualitative guiding factors, refer to the DSSI Qualitative Risk Check Report ( EPA 2001h). Further justification for assigning DSSI to the high prioritization group is based on the fact that while some of the qualitative guiding factors evaluated for this facility have been individually assigned to the medium or low group, these individual guiding factors alone do not justify placing the facility in a lower prioritization grouping. Additionally, the site specific characteristics at the DSSI facility exhibits the complex interplay or additive relationships between guiding factors typically found in the facilities assigned to the high prioritization group. Therefore, based on a review of sitespecific characteristics and a comparison to the other facilities in this report, it has been determined that,

for the MACT based prioritization grouping, DSSI is best represented by facilities assigned to the high priority grouping and exhibits multiple site specific characteristics that clearly indicate an increased potential for adverse health impacts.

As discussed in Section 1.2, placement into the high prioritization group confirms the need for conducting additional site specific risk assessment activities at the DSSI facility in order to quantify risk impacts to human health and the environment since facilities in this grouping have the largest potential for contributing to adverse health impacts. Therefore, consistent with the DSSI Qualitative Risk Check Report ( EPA 2001h), additional site specific risk assessment activities are warranted and will help both the facility and permitting authority demonstrate that compliance with future MACT standards meet the requirements of the RCRA omnibus provisions. 49 2.5 DSM CHEMICALS NORTH AMERICA, INC.

This section presents the information and approach used in assigning DSM Chemicals North America, Inc.

( DSM) to one of the three prioritization groupings based on ( 1) the facility's overall potential for resulting in adverse health impacts and ( 2) an assessment of the protectiveness of current or future MACT standards to determine if additional permit limits may be required to ensure protection of human health and the environment. Section 2.5.1 presents facility specific background information including process descriptions and permit history. Section 2.5.2 describes the process and findings used to assign a facility to one of the three prioritization groupings specific to the risk based facility prioritization strategy. Section 2.5.3 describes the process and findings used to assign a facility to one of the three prioritization groupings following the MACT based facility prioritization strategy. Specific sources of information used to evaluate the DSM facility are cited and referenced at the end of this report.

2.5.1 Facility Information The following summarizes the facility specific information provided in Section <IP_ADDRESS> of the DSM Qualitative Risk Check Report ( EPA 2001j). This information is intended to provide a general facility overview including process descriptions and permit history.

DSM is owned and operated by Dutch State Mines of North America and was previously known as Nipro;

its operations began in 1965 ( DSM 1994). The DSM facility is located about 1.6 kilometers east of Augusta in Richmond County, Georgia. The facility occupies approximately 600 acres and is bordered by the Savannah River on the south and southeast, agricultural land on the east, Laney Walker Boulevard on the north, Columbia Nitrogen Road on the west and northwest, and industrial properties on the southwest.

Specifically, the site is located at 33o26' 12" north latitude and 81o56' 07" west longitude. DSM manufacturers synthetic organic chemicals and is the largest supplier of caprolactum, a monomer of nylon used in production of nylon fiber ( DSM 1996). The DSM facility consists of office buildings, farmland,

and property that is leased to other companies. The production and process areas occupy about 150 acres,

and the holding ponds, wastewater treatment plant, and farmland occupy about 250 acres. 50 DSM operates four natural gas fired boilers that discharge flue gases through a common stack ( DSM 1998). Only two of the boilers, H 002 and H 2002, are permitted to burn hazardous waste. Boilers H 002 and H 2002 are operated primarily to produce steam for the caprolactum manufacturing plant. Both boilers are Babcock & Wilcox natural gas fired, water tube boilers ( DSM 1998). The H 002 boiler consumes 162 million British thermal units ( Btu) per hour and supplies 125,000 pounds per hour of saturated steam at 300 pounds per square inch gauge ( psig). The H 2002 boiler consumes 361 million Btu per hour and supplies 278,000 pounds per hour of saturated steam at 300 psig. The primary fuel for both boilers is natural gas, but both boilers also burn small quantities of a waste organic fuel ( a light residue).

The light residue is characterized as a light organic by product from cyclohexanone distillation and nonwater soluble organics that could not be recovered or reused in the process. The light residue is characterized as hazardous based on ignitability ( D001) and toxicity ( D 018) ( DSM 1998). Specifically,

of the non metal compounds listed in Appendix VIII of 40 CFR Part 261, the light residue is known to contain toluene and benzene. Other wastes generated from the manufacturing and maintenance processes include: benzene still bottoms, paint wastes, paint thinners, laboratory wastes, spill cleanup wastes, and spent catalyst.

Controls within the system prevent DSM from burning more than 23 percent light residue at any time. At maximum rates, fuel feed to the H 002 boiler is about 77 percent natural gas and 23 percent light residue.

At maximum rates, fuel feed to the H 2002 boiler consists of 89 percent natural gas and 11 percent light residue. The H 002 and H 2002 boilers are equipped with a continuous emissions monitoring ( CEM)

system, and only one boiler may burn light residue at a time; however, no air pollution control devices ( APCD) have been installed on these units. The CEM systems consist of carbon monoxide and oxygen analyzers.

The DSM facility generates hazardous wastes from various on site operations. Most of the wastes are associated with the Oxanone process unit ( DSM 1994). Wastes are stored in one of the facility's two storage tanks, T 527B and T 2523. Tank T 527B is a 20,000 gallon vessel permitted under Georgia Hazardous Waste Facility Permit Number HW 016( S) 2 for storing the organic light residue. Tank T

2523 is a 25,000 gallon vessel that is used to store the light residue before it is burned in the boilers. Tank T 2523 is intended for less than 90 day storage, although it is operated in the same manner as the permitted tank. Both tanks are operated in parallel and are rotated with one used as a storage tank while the other is used as the burn tank, and vice versa. Approximately 725,000 gallons of light residue are 51 generated annually by on site operations.

Nonhazardous wastes are stored separately and mainly consist of waste oil and spent catalyst sent for recycling. These wastes are considered light by products from cyclohexanone distillation and from the light organic wastes from the wastewater collection system. Process wastewater is treated in the wastewater treatment plant ( WWTP). All sumps and drains are directed to the treatment facility. After the wastewater is treated, it is discharged to the Savannah River.

Boilers H 002 and H 2002 are currently operating under interim status as specified in the BIF Requirements of 40 CFR Part 266. DSM submitted a Certification of Precompliance for the H 002 and H

2002 boilers on August 19, 1991. A Certification of Compliance ( CoC) for the H 2002 boiler was submitted in September 1992, and a CoC was also submitted for the H 002 boiler in November 1992.

Recertifications for these boilers were submitted in October 1995. Each boiler operates under Georgia Air Quality Permit 2869 121 10372, which was modified in 1997 ( DSM 1998). In 1998, DSM applied for a Low Risk Waste Exemption and a waiver of the destruction and removal efficiency ( DRE) trial burn for the H 002 and H 2002 boilers. No information was available in facility files on the status of the application for the Low Risk Waste Exemption or waiver for the DRE trial burn.

2.5.2 Risk Based Facility Prioritization This section describes findings relative to assigning DSM to one of the three prioritization groupings using the risk based facility prioritization strategy. Specifically, the following prioritization table presents the results for the individual qualitative guiding factors evaluated in the DSM Qualitative Risk Check Report ( EPA 2001j). In addition, the table also identifies which prioritization grouping the overall facility was assigned to using the risk based facility prioritization strategy. The paragraph following the prioritization table provides further justification supporting why the facility was assigned to its specific prioritization grouping. 52 OVERALL RISK BASED FACILITY PRIORITIZATION QUALITATIVE GUIDING FACTOR PRIORITIZATION GROUPING Low Medium High Section <IP_ADDRESS>   Volumes and Types of Waste Being Burned

Section <IP_ADDRESS>   Emissions Quantification

Section 2.2.2   Other On site and Off site Emission Sources

Section <IP_ADDRESS>   Terrain Characteristics

Section <IP_ADDRESS>   Land Use for Dispersion Coefficients and Surface Roughness

Section <IP_ADDRESS>   Building Wake Effects

Section <IP_ADDRESS>   Particle Size Distribution

Section <IP_ADDRESS>   Meteorological Conditions

Section <IP_ADDRESS>   Physical Source Parameters

Section <IP_ADDRESS>   ( Receptor) Grid Node Array

Section 4.2.1   Type of Receptors and Exposure Scenario( s)

Section 4.2.2   Proximity to Exposure Scenario Location

Section 4.2.3   Presence or Absence and Proximity of Water Bodies and Water Sheds

Section 4.2.4   Proximity to Special Subpopulations

Section 4.2.5   Presence or Absence and Proximity of Ecological Areas

Section 4.2.6   Public Concerns

DSM Augusta, Georgia Risk Based Prioritization Grouping: Low Based on ( 1) a review of the individual qualitative guiding factors and their associated groupings presented in the above table, and ( 2) consideration of how each qualitative guiding factor interrelates collectively,

DSM has been placed in the low prioritization group. DSM's designation in the low priority group is due in large part to the combination of a well characterized waste stream, which does not contain known PBTs,

with the lack of receptors located in close proximity to the facility. In addition, when compared with the 12 53 other facilities included in this summary report, DSM does not exhibit the multiple complicating factors that individually or collectively support those facilities that have been assigned to the medium or high prioritization groups. Specifically, justification for grouping DSM into the low prioritization grouping includes the following:

DSM only treats hazardous waste that is generated on site. In comparison, facilities assigned to the medium and high prioritization groupings typically treat both on and off site generated wastes.

The hazardous waste feed at DSM is well characterized, and the facility is only permitted to burn waste listed under two RCRA waste codes D001( ignitability) and D018 ( toxicity benzene). Neither of these waste codes contains known PBTs or common risk drivers. In addition, DSM has filed for a low risk waste exemption. In comparison, facilities assigned to the medium and high prioritization groupings typically treat wastes that are known or permitted to contain PBTs and other common risk drivers.

The only fuel source used ( other than the hazardous waste feed) is natural gas, which comprises no less than 77 percent of the total fuel at any time.