Economic
Impact
Analysis
of
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Site
Remediation
­
Final
Draft
EPA­
452/
R­
03­
016
August
2003
Economic
Impact
Analysis
of
the
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Site
Remediation­
Final
Draft
By:

RTI
International*
Center
for
Regulatory
Economics
and
Policy
Research
Research
Triangle
Park,
North
Carolina
27709
Prepared
for:

US.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Office
of
Air
and
Radiation
Research
Triangle
Park,
NC
27711
*
RTI
International
is
a
trade
name
of
Research
Triangle
Institute.
iv
CONTENTS
Section
Page
1
Introduction
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1­
1
1.1
Agency
Requirements
for
an
EIA
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1­
1
1.2
Summary
of
the
Source
Category
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1­
2
1.3
Summary
of
Potential
Economic
Impacts
and
Market
Adjustments
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1­
3
1.4
Organization
of
this
Report
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1­
5
2
Affected
Industries
and
Engineering
Costs
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2­
1
2.1
Characterizing
the
Remediation
Activities
Affected
by
the
Rule
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2­
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2.2
Potentially
Affected
Industries
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2­
2
2.2.1
The
BRS
Data
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2­
3
2.2.2
The
Limitations
of
the
BRS
Database
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2­
3
2.3
Control
Technologies
and
Compliance
Cost
Estimates
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2­
4
2.3.1
Control
Technologies
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2­
5
2.3.2
Control
Cost
Estimates
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2­
6
2.3.3
Monitoring,
Inspection,
Recordkeeping,
and
Reporting
Costs
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2­
6
2.3.4
Formatting
Engineering
Cost
Estimates
for
Economic
Analysis
2­
7
2.4
Summary
of
Estimated
Control
Costs
for
Potentially
Affected
Industries
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2­
7
3
Economic
Impact
Analysis:
Methods
and
Results
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3­
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3.1
Qualitative
Discussion
of
Economic
Impacts
on
Firms
and
Consumers
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3.1.1
Firm­
Level
Decisions
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3­
2
v
3.1.1.1
Remediation
Resulting
from
Past
Production
Decisions
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3­
2
3.1.1.2
Remediation
Resulting
from
Future
Production
Decisions
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3­
3
3.1.2
A
Qualitative
Analysis
of
Market
Impacts
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3­
4
3.1.3
Impact
on
Consumers
and
Social
Welfare
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3­
5
3.2
Selection
of
Industries
for
the
Economic
Impact
Analysis
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3­
6
3.3
Economic
Impact
Methodology
and
Results
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3­
6
3.4
Small
Business
Impacts
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3­
7
3.5
Conclusions
and
Qualifications
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3­
12
3.5.1
Conclusions
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3­
12
3.5.2
Qualifications
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3­
12
References
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R­
1
vi
LIST
OF
FIGURES
Number
Page
2­
1
Distribution
of
Total
Annual
Compliance
Costs
by
Industry
($
1997)
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2­
9
3­
1
Market
for
Off­
Site
Waste
Treatment
Services
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3­
3
3­
2
Marginal
Cost
Curve
for
Final
Market
Good
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3­
4
3­
3
Market
Equilibrium
Without
and
With
Regulation
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3­
5
vii
LIST
OF
TABLES
Number
Page
2­
1
Total
Annual
Control
Costs
(
TACC)
for
Site
Remediation
MACT
by
Industry:
1997
BRS
Data
Set
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2­
8
3­
1
Economic
Data
for
15
Industries
with
Highest
Total
Annual
Control
Costs
(
TACC)
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3­
8
3­
2
SIC
and
NAICS
Codes
for
15
Industries
with
Highest
Total
Annual
Control
Costs
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3­
9
3­
3
Economic
Impact
Screening
Analysis
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3­
11
viii
LIST
OF
ACRONYMS
BRS:
Biennial
Reporting
System
CAA:
Clean
Air
Act
CSR:
Cost­
to­
sales
ratio
EIA:
Economic
impact
analysis
EPA:
U.
S.
Environmental
Protection
Agency
GDP:
Gross
domestic
product
HAPs:
Hazardous
air
pollutants
LQG:
Large
Quantity
Generator
MACT:
Maximum
achievable
control
technology
MIRR:
Monitoring,
inspections,
recordkeeping,
and
reporting
NAICS:
North
American
Industrial
Classification
System
NESHAP:
National
Emissions
Standard
for
Hazardous
Air
Pollutants
NPL:
National
Priorities
List
NSPS:
New
Source
Performance
Standards
NTI:
National
Toxics
Inventory
OAQPS:
Office
of
Air
Quality
Planning
and
Standards
OSWRO:
Off­
Site
Waste
and
Recovery
Operations
RCRA:
Resource
Conservation
and
Recovery
Act
of
1976
ROS:
Return­
on­
sales
SIC:
Standard
Industrial
Classification
SVE:
Soil
vapor
extraction
TSD:
Treatment,
Storage,
and
Disposal
VOCs:
Volatile
organic
compounds
1EPA
must
periodically
review
the
list
of
HAPs
and,
where
appropriate,
revise
this
list
by
rule.
In
addition,
any
person
may
petition
EPA
under
Section
112(
b)(
3)
to
modify
the
list
by
adding
or
deleting
one
or
more
substances.

2In
addition,
Executive
Order
(
EO)
12866
requires
a
more
comprehensive
analysis
of
benefits
and
costs
for
proposed
significant
regulatory
actions.
Office
of
Management
and
Budget
(
OMB)
guidance
under
EO
12866
stipulates
that
a
full
benefit­
cost
analysis
is
required
only
when
the
regulatory
action
has
an
annual
effect
on
the
economy
of
$
100
million
or
more.
Other
statutory
and
administrative
requirements
include
examination
of
the
composition
and
distribution
of
benefits
and
costs.
For
example,
the
Regulatory
Flexibility
Act
(
RFA),
as
amended
by
the
Small
Business
Regulatory
Enforcement
and
Fairness
Act
of
1996
(
SBREFA),
requires
EPA
to
consider
the
economic
impacts
of
regulatory
actions
on
small
entities.

1­
1
SECTION
1
INTRODUCTION
The
Clean
Air
Act's
(
CAA's)
purpose
is
to
protect
and
enhance
the
quality
of
the
nation's
air
resources.
To
accomplish
this
goal,
the
Act
vested
the
U.
S.
Environmental
Protection
Agency
(
EPA)
with
the
authority
to
establish
national
emission
standards
for
188
hazardous
air
pollutants
(
HAPs)
that
cause
or
may
cause
adverse
health
effects
or
adverse
environmental
and
ecological
effects.
1
EPA
has
determined
that
site
remediation
activities
can
be
sources
of
organic
HAPs
(
including
benzene,
ethyl
benzene,
toluene,
vinyl
chloride,
and
xylenes)
and
other
volatile
organic
compounds
(
VOCs).
The
range
of
potential
human
health
effects
associated
with
exposure
to
these
organic
HAPs
and
VOCs
includes
cancer,
aplastic
anemia,
upper
respiratory
tract
irritation,

liver
damage,
and
neurotoxic
effects
(
e.
g.,
headache,
dizziness,
nausea,
tremors).
The
proposed
rule
would
implement
Section
112(
d)
of
the
CAA
by
requiring
those
affected
site
remediation
activities
to
meet
emission
limitation,
operating
limit,
and
work
practice
standards
reflecting
the
application
of
the
maximum
achievable
control
technology
(
MACT).

1.1
Agency
Requirements
for
an
EIA
Congress
and
the
Executive
Office
have
imposed
statutory
and
administrative
requirements
for
conducting
economic
analyses
to
accompany
regulatory
actions.
Section
317
of
the
CAA
specifically
requires
estimation
of
the
cost
and
economic
impacts
for
specific
regulations
and
standards
proposed
under
the
authority
of
the
Act.
2
The
Office
of
Air
Quality
Planning
and
Standards'
(
OAQPS')
Economic
Analysis
Resource
Document
provides
detailed
instructions
and
expectations
for
economic
analyses
that
support
rulemaking
(
EPA,
1999b).
In
the
case
of
the
site
remediation
MACT
standard,
these
requirements
are
fulfilled
by
providing
an
overview
of
potential
1­
2

industry­
level
impacts
and

societal­
level
impacts
(
qualitative
discussion).

1.2
Summary
of
the
Source
Category
Site
remediation
is
one
of
the
approximately
170
categories
of
sources
included
in
the
National
Emissions
Standard
for
Hazardous
Air
Pollutants
(
NESHAP)
source
category
list.
Sites
undergoing
remediation
include,
but
are
not
limited
to,
voluntary
cleanup
actions
and
underground
storage
tank
sites.
However,
not
all
sites
will
be
subject
to
the
rule.
Site
remediation
includes,
but
is
not
limited
to,
the
following
activities:
contaminated
soils
cleaning,

soil
vapor
extraction
(
SVE),
and
groundwater
cleanup
or
removal
of
hazardous
substances.
Site
remediation
does
not
include
remediation
activities
at
gasoline
stations,
cleanup
of
contamination
at
farm
or
residential
sites,
or
the
installation
of
controls
at
municipal
solid
waste
landfills
to
comply
with
the
New
Source
Performance
Standards
(
NSPS)
or
CAA,
Section
III(
d)
emission
guidelines
(
Nizich,
2001).
Superfund
NPL
sites
and
permitted
or
federal
order
RCRA
corrective
action
cleanups
are
exempted
from
the
rule.

The
site
remediation
source
category
potentially
includes
a
wide
variety
of
industries.

Because
site
remediation
activities
are
not
specific
to
a
particular
industry
or
process,
creating
a
comprehensive
list
of
all
potentially
affected
industries
is
not
possible.
For
the
economic
impact
analysis,
EPA
used
the
1997
Biennial
Reporting
System
(
BRS)
database
to
identify
a
sample
of
facilities
that
generated
remediation
wastes
in
1997
and
who
might
have
been
subject
to
the
rule
if
the
rule
had
been
enacted
in
that
year.
The
data
were
used
to
estimate
the
quantity
of
remediation
wastes
generated
by
various
regulatory
categories,
the
physical
form
of
the
remediation
wastes
generated
(
e.
g.,
inorganic
liquids,
organic
solids,
or
organic
sludges),
and
the
quantities
and
methods
used
to
manage
and
treat
the
remediation
wastes
on­
site
(
e.
g.,
incineration,
aqueous
organic
treatment,
or
stabilization).
The
Agency
believes
that
the
1997
BRS
database
provides
a
fair
representation
of
nationwide
baseline
conditions
for
site
remediations
activities.
A
comparison
of
the
total
quantity
of
remediation­
derived
wastes
reported
in
the
BRS
database
for
the
years
1993,
1995,
and
1997
showed
that
the
total
quantity
of
remediation
waste
treated
on­
site
for
these
years
remained
about
the
same,
approximately
22
million
tons
(
Nizich,
2001).

The
engineering
cost
analysis
(
Zerbonia,
2001)
indicates
that
490
different
Standard
Industrial
Classification
(
SIC)
codes
had
facilities
generating
remediation
waste
streams
in
1997.

Of
these,
four
SIC
codes
generated
more
than
500
waste
streams
per
code,
28
SIC
codes
generated
more
than
100
waste
streams
per
code,
48
SIC
codes
generated
more
than
50
waste
streams
per
code,
84
SIC
codes
generated
more
than
25
waste
streams
per
code,
and
190
SIC
codes
generated
10
or
more
waste
streams
per
code.
Major
industry
sectors
that
are
engaged
in
1­
3
site
remediation
activities
include
industrial
organic
chemical
manufacturing,
petroleum
refining,

waste
management
(
refuse),
plating
and
polishing,
aircraft,
and
semiconductors
to
list
a
few.

1.3
Summary
of
Potential
Economic
Impacts
and
Market
Adjustments
Implementation
of
the
proposed
rules
will
increase
the
costs
of
production
at
affected
facilities.
The
response
of
producers
to
the
additional
production
costs
associated
with
rule
compliance
and
the
response
of
consumers
to
changes
in
market
conditions
determine
the
economic
impact
of
the
regulation.
The
proposed
rule
may
influence
firms'
choices
of
remediation
activities.
For
example,
they
may
elect
not
to
conduct
the
remediation
or
the
increased
costs
associated
with
on­
site
control
of
air
emissions
may
encourage
firms
to
use
offsite
treatment
for
any
remediation
wastes
generated.
As
a
result,
demand
for
off­
site
remediation
waste
management
services
will
likely
increase,
placing
upward
pressure
on
prices
that
would
in
turn
reduce
the
quantity
of
services
demanded
in
this
market.
In
addition
to
off­
site
remediation
waste
materials
management
and
treatment
services,
higher
production
costs
for
products
supplied
by
firms
affected
by
the
rule
(
i.
e.,
higher
on­
site
remediation
costs
and
higher
off­
site
remediation
service
prices)
may
result
in
changes
in
the
markets
for
their
particular
products.

Higher
production
costs
can
lead
to
reduced
production
of
commodities
and/
or
increased
prices
for
commodities.
These
potential
changes
in
market
prices
and
output
will
in
turn
affect
society's
welfare
through
losses
to
consumers
and
producers.

As
discussed
above,
the
site
remediation
source
category
can
include
a
large
variety
of
industries.
Although
the
BRS
database
provides
information
on
which
firms
might
have
been
affected
if
the
rule
had
been
implemented
in
1997,
EPA
does
not
have
information
on
the
industries
and
firms
that
will
actually
be
affected
when
the
rule
is
implemented.
By
the
date
at
which
the
rule
is
implemented,
the
remediation
projects
ongoing
in
1997
will
most
likely
be
finished.
Given
the
lack
of
certain
information
on
the
affected
industries
and
facilities
and
the
large
number
of
potentially
affected
industries,
we
can
only
examine
the
general
implications
of
the
rule
using
industry­
level
data
from
the
most
recent
Economic
Census
(
U.
S.
Bureau
of
the
Census,
2000).
Given
the
uncertainty
about
which
firms
would
be
impacted,
EPA
determined
that
the
most
appropriate
way
to
analyze
the
industry
data
was
at
the
SIC
level
because
the
BRS
data
used
the
SIC
system
and
the
bridge
between
the
SIC
and
NAICS
codes
was
not
one­
to­
one.

However,
we
also
report
the
corresponding
NAICS
codes
associated
with
the
15
industries
in
the
economic
impact
analysis.

The
Agency
employed
an
engineering
or
financial
analysis
that
takes
the
form
of
estimating
impacts
through
the
ratio
of
compliance
costs
to
the
value
of
sales
(
cost­
to­
sales
ratio
or
CSR)
using
total
industry
revenues,
control
costs,
and
accounting
measures
of
profit.
The
analysis
assesses
the
burden
of
the
rule
by
assuming
the
affected
industries
fully
absorb
the
control
3$
1997.
EPA
adjusted
the
$
2000
estimates
using
a
cost
factor
(
0.9753)
developed
from
the
Chemical
Engineering
Composite
Plant
Cost
Index.

1­
4
costs,
rather
than
passing
them
on
to
consumers
in
the
form
of
higher
prices.
One
drawback
of
this
approach
is
that
it
does
not
consider
interactions
between
producers
and
consumers
in
a
market
context.
It
is
likely
that
some
percentage
of
the
control
costs
may
be
passed
along
to
other
parties
through
various
economic
exchanges,
in
particular
in
the
form
of
higher
prices
for
consumers.
Therefore,
it
likely
overstates
the
impacts
on
facilities
and
firms
affected
by
the
rule
and
understates
the
impacts
on
consumers.
The
primary
advantages
of
this
approach
are
its
simplicity
and
its
relatively
limited
data
requirements.

Out
of
the
490
different
SIC
codes
that
had
facilities
generating
remediation
waste
streams
in
1997,
over
80
SIC
codes
were
predicted
to
have
annual
compliance
costs
as
a
result
of
the
rule,

and
15
industries
accounted
for
91
percent
of
the
total
annual
compliance
costs
of
$
7.96
million.
3
For
the
12
industries
with
revenue
data,
all
had
CSRs
less
than
0.02
percent.
Profitability
data
for
the
SIC
codes
also
show
the
lower
quartile
return
on
sales
for
industries
with
data
was
between
0.4
and
1.8
percent
(
Dun
&
Bradstreet,
1997).
None
of
the
industries
was
shown
to
have
a
CSR
in
excess
of
the
lower
quartile
return
on
sales.
Given
the
information
available
to
the
Agency,
it
does
not
appear
that
the
rule
would
impose
significant
costs
on
the
potentially
affected
industries.

However,
as
discussed
in
more
detail
in
the
report,
the
nature
of
the
proposed
rule
and
the
data
makes
fully
assessing
the
impact
of
the
regulation
difficult.

Small
business
impacts
were
particularly
difficult
to
assess.
As
discussed
in
the
Preamble,

this
rule
sets
minimum
standards
to
be
met
when
parties
engage
in
future
site
remediation
activities,
but
it
does
not
itself
require
any
party
to
undertake
such
activities.
States
may
choose
to
direct
a
party
to
undertake
site
remediation,
or
parties
may
undertake
remediation
activities
voluntarily.
EPA
anticipates
that
parties
that
undertake
site
remediation
generally
will
do
so
voluntarily
and
that
the
impact
of
this
rule
on
those
parties
will
not
be
significant.
Further,

because
States
and
other
parties
will
decide
whether
to
undertake
site
remediation
activities,
it
is
extremely
difficult,
if
not
impossible,
to
predict
how
many
or
what
types
of
small
entities
will
undertake
such
activities.
The
rule
is
structured
to
avoid
impacts
on
small
businesses.
The
rule
specifically
excludes
from
its
scope
remediations
conducted
at
gasoline
stations,
farm
sites
and
residential
sites
(
on
the
ground
that
these
remediations
would
not
exceed
the
threshold
for
major
sources).
Moreover,
the
rule
would
apply
only
to
remediation
sites
located
at
a
facility
that
is
a
major
source
under
the
Clean
Air
Act
and
engages
in
a
"
MACT
activity"
(
defined
as
a
nonremediation
activity
covered
in
the
MACT
list
of
major
source
categories
pursuant
to
CAA
section
112
(
c)).
Such
sources
tend
to
be
large
businesses.
The
rule
also
contains
emission
thresholds
that
are
not
likely
to
apply
to
small
businesses.
For
example,
the
rule
exempts
sources
where
the
total
annual
quantity
of
HAP
contained
in
all
extracted
remediation
material
at
the
1­
5
facility
is
less
than
1
megagrams
(
Mg)
per
year.
For
these
reasons,
EPA
certifies
that
the
rule,
if
promulgated,
will
not
impose
a
significant
economic
impact
on
a
substantial
number
of
small
entities.

1.4
Organization
of
this
Report
The
remainder
of
this
report
supports
and
details
the
methodology
and
the
results
of
the
EIA
of
the
site
remediation
NESHAP.


Section
2
presents
an
overview
of
the
site
remediation
source
category
and
the
estimated
engineering
control
costs.


Section
3
describes
the
EIA
methodology
and
reports
economic
impact
results.
This
section
also
includes
qualifications
of
the
analysis.
1This
section
is
based
on
information
in
Nizich
(
2001).

2­
1
SECTION
2
AFFECTED
INDUSTRIES
AND
ENGINEERING
COSTS
Section
2
describes
the
remediation
activities
affected
by
the
rule
and
the
methods
used
by
the
Agency
to
identify
potentially
affected
industries
and
calculate
engineering
compliance
cost
estimates.
The
broad
nature
of
the
rule
results
in
a
large
number
of
potentially
affected
industries.

Because
of
the
difficulty
in
predicting
which
industries
and
companies
will
actually
be
affected
by
the
rule
when
it
is
implemented,
the
Agency
considers
the
results
to
provide
an
indication
of
the
types
of
industries
that
will
be
affected
and
the
possible
distribution
of
impacts.
The
economic
analysis,
which
is
based
on
the
data
described
in
this
section,
provides
a
similarly
general
overview
of
the
possible
distribution
of
costs
with
a
qualitative
discussion
of
likely
market
impacts.

2.1
Characterizing
the
Remediation
Activities
Affected
by
the
Rule1
A
site
remediation
is
performed
in
response
to
the
release
of
hazardous
substances
into
the
environment
(
e.
g.,
soil,
groundwater,
or
other
environmental
media).
It
involves
taking
appropriate
action
to
remove,
store,
treat,
and/
or
dispose
of
the
hazardous
substances
to
the
extent
necessary
to
protect
human
health
and
the
environment.
The
term
"
cleanup"
generally
refers
to
the
activities
performed
to
address
the
hazardous
substance
contamination.
This
term
frequently
is
used
interchangeably
with
the
term
"
remediation."

Site
remediations
can
be
performed
to
address
hazardous
substance
contamination
resulting
from
either
past
or
current
human
activities.
Examples
of
such
activities
include
accidental
releases
of
chemical
substances;
undetected
leaks
in
tanks
or
pipelines;
releases
from
the
use
of
incorrectly
designed
or
poorly
maintained
equipment
for
managing
materials
containing
hazardous
substances;
improper
disposal
of
hazardous
substances
in
surface
impoundments,

containers,
waste
piles,
or
landfills;
and
abandoned
hazardous
substances.

For
the
purpose
of
implementing
the
rule,
a
site
remediation
is
one
or
more
activities
or
processes
used
to
remove,
destroy,
degrade,
transform,
or
immobilize
organic
HAP
constituents
in
soils,
sediments,
groundwater,
surface
waters,
or
other
types
of
solid
or
liquid
environmental
media
as
well
as
"
pure"
materials
that
are
not
mixed
with
environmental
media.
The
rule
would
not
apply
to
site
remediations
specifically
excluded
from
applicability.
The
proposed
rule
would
not
apply
to
the
following:
2­
2

site
remediation
involving
the
cleanup
of
radioactive
mixed
waste
managed
in
compliance
with
all
applicable
regulations
under
Atomic
Energy
Act
and
Nuclear
Waste
Policy
Act
authorities

site
remediations
performed
to
clean
up
remediation
material
containing
little
or
no
organic
HAPs;
the
proposed
rule
would
not
apply
to
any
facility
for
which
the
owner
or
operator
demonstrates
that
the
total
annual
organic
HAP
mass
content
of
the
remediation
material
to
be
cleaned
up
at
the
facility
site
is
less
than
1
megagram
per
year
(
Mg/
yr)


Superfund
NPL
sites
and
permitted
or
federal
order
RCRA
corrective
action
cleanups
are
exempted
from
the
rule.

2.2
Potentially
Affected
Industries
The
proposed
NESHAP
would
affect
owners
and
operators
of
facilities,
subject
to
the
exceptions
described
in
Section
2.1,
that
are
major
sources
of
HAP
emissions
and
at
which
a
site
remediation
is
conducted
to
clean
up
media
or
other
material
contaminated
with
any
of
the
organic
HAP
substances
listed
in
the
rule.
Because
of
the
nature
of
activities
regulated
by
the
source
category,
a
comprehensive
list
of
SIC
or
North
American
Industry
Classification
System
(
NAICS)
codes
cannot
be
compiled
for
businesses
or
facilities
potentially
regulated
by
this
action.

The
rule
may
be
applicable
to
any
type
of
business
or
facility
at
which
a
site
remediation
is
conducted
to
clean
up
media
contaminated
with
organic
HAPs
and
other
hazardous
material.
For
many
businesses
and
facilities
subject
to
the
rule,
the
regulated
sources
(
i.
e.,
the
site
remediation
activities)
are
not
the
predominant
activity,
process,
operation,
or
service
conducted
at
the
facility.
The
Agency
is
aware
of
site
remediation
activities
potentially
subject
to
the
rule
being
performed
at
facilities
listed
under
SIC
codes
for
petroleum
refining,
organic
chemical
manufacturing,
refuse
systems,
waste
management,
business
services,
miscellaneous
services,
and
nonclassifiable.
Therefore,
the
industrial
code
alone
for
a
given
facility
does
not
determine
whether
the
facility
is
or
is
not
potentially
subject
to
this
rule
(
Nizich,
2001).

For
the
economic
impact
analysis,
the
Agency
identified
a
sample
of
industries
that
might
be
affected
by
the
regulation
using
the
best
available
data:
the
1997
BRS
database.
The
remainder
of
Section
2.2
describes
the
BRS
database
and
the
limitations
of
using
these
data
to
identify
potentially
affected
industries.

2.2.1
The
BRS
Data
EPA,
in
partnership
with
the
states,
collects
information
biennially
regarding
the
generation,
management,
and
final
disposition
of
hazardous
wastes
regulated
under
RCRA,
as
amended.
The
purpose
of
The
National
Biennial
RCRA
Hazardous
Waste
Report
(
Based
on
2­
3
1997
Data)
is
to
communicate
the
findings
of
EPA's
1997
BRS
data
collection
efforts
to
the
public,
government
agencies,
and
the
regulated
community
(
EPA,
1999a).
The
report
provides

an
overview
of
national
hazardous
waste
generation
and
management
practices;


data
on
waste­
handling
practices
in
the
EPA
regions,
states,
and
largest
facilities
nationally,
including
the
quantity
of
waste
generated,
managed,
shipped
and
received,
and
imported
and
exported
between
states
and
the
number
of
generators
and
managing
facilities;


data
on
each
state's
waste
handling
practices,
including
overall
totals
for
generation,
management,
and
shipments
and
receipts,
as
well
as
totals
for
the
largest
50
facilities;


a
list
of
large
quantity
generators
that
identifies
every
hazardous
waste
generator
in
the
United
States
that
reported
itself
to
be
a
large
quantity
generator
in
1997;
and

a
list
of
treatment,
storage,
and
disposal
facilities
that
identifies
every
hazardous
waste
manager
in
the
United
States
that
reported
itself
to
be
a
treatment,
storage,
or
disposal
facility
in
1997.

The
BRS
database
provides
information
on
the
facility
name,
location,
quantity
of
waste
generated
by
waste
treatment
category,
SIC
code,
and
other
useful
information.
To
generate
estimates
of
the
annual
control
cost
for
facilities,
it
is
necessary
to
have
information
on
the
quantity
of
waste
generated
at
the
facility
level,
and
the
BRS
is
the
best
source
of
such
information.

2.2.2
The
Limitations
of
the
BRS
Database
Using
the
1997
BRS
data
to
identify
the
affected
industries
raises
a
number
of
issues.

Most,
if
not
all,
of
the
remediation
projects
underway
in
1997
will
be
completed
by
the
year
in
which
the
rule
takes
effect.
Thus,
the
specific
companies
identified
in
the
1997
BRS
database
may
or
may
not
incur
compliance
costs
when
the
rule
is
implemented.
In
addition,
the
BRS
data
do
not
include
the
activities
of
off­
site
waste
treatment
facilities,
which
will
be
subject
to
the
rule.

However,
the
Agency
anticipates
that
the
off­
site
treatment
facilities
that
would
be
subject
to
the
rule
will
already
have
the
necessary
control
equipment
as
a
result
of
complying
with
other
EPA
rules.
In
addition,
the
quantity
of
shipped
remediation
waste
for
off­
site
treatment
is
typically
only
a
small
percentage
of
the
total
quantity
of
remediation
waste
generated
(
e.
g.,
<
6
percent
in
1997).
Thus,
the
Agency
believes
this
rule
should
impose
minimal
costs
on
off­
site
waste
treatment
firms.
Furthermore,
the
BRS
data
identify
only
large
quantity
generators,
which
may
2Facilities
must
report
their
activities
involving
RCRA
hazardous
waste
to
BRS
if
they
are
either
a
RCRAdefined
LQG
or
a
TSD
facility.
Large
Quantity
Generator:
A
generator
is
defined
as
a
federal
LQG
if
it
meets
any
of
the
following
criteria
during
the
year:
[
a]
the
facility
generated
in
one
or
more
months
1,000
kg
(
2,200
lbs)
or
more
of
RCRA
hazardous
waste;
or
[
b]
the
facility
generated
in
one
or
more
months,
or
accumulated
at
any
time,
1
kg
(
2.2
lbs)
of
RCRA
acute
hazardous
waste;
or
[
c]
the
facility
generated
or
accumulated
at
any
time
more
than
100
kg
(
220
lbs)
of
spill
cleanup
material
contaminated
with
RCRA
acute
hazardous
waste.
The
wastes
that
are
not
to
be
counted
in
determining
whether
a
site
is
a
LQG
include:
(
i)
RCRA
hazardous
wastes
managed
in
systems
regulated
under
the
Clean
Water
Act
(
i.
e.,
wastewater
treatment
plants)
or
the
Safe
Drinking
Water
Act
(
i.
e.,
underground
injection
wells),
(
ii)
wastes
that
are
recycled
or
reclaimed,
and
(
iii)
wastes
regulated
only
by
a
given
state
and
not
by
RCRA.
Treatment,
Storage,
and
Disposal
Facility:
This
is
a
facility
that
treats,
stores,
or
disposes
of
hazardous
waste.
Treatment
is
any
method,
technique,
or
process
designed
to
(
1)
change
the
physical,
chemical,
or
biological
character
or
composition
of
any
hazardous
waste
to
neutralize
such
waste;
(
2)
recover
energy
or
material
resources
from
the
waste;
or
(
3)
render
such
waste
nonhazardous
or
less
hazardous.
Storage
is
the
temporary
holding
of
hazardous
waste
until
it
is
treated,
disposed
of,
or
stored
elsewhere.
Storage
methods
include
use
of
containers,
tanks,
and
surface
impoundments.
Disposal
is
the
discharge,
deposit,
injection,
dumping,
spilling,
leaking,
or
placing
of
waste
so
that
it
may
enter
the
environment
(
air,
land,
or
water).

3This
section
draws
from
Nizich
(
2001)
and
Zerbonia
(
2001).

2­
4
exclude
many
other
waste
generators.
2
To
the
extent
that
large
quantity
generators
are
large
companies,
small
businesses
may
not
be
adequately
represented
in
this
database.
Furthermore,
the
BRS
database
does
not
identify
which
facilities
are
major
sources
of
HAPs,
so
it
is
possible
that
some
of
the
firms
in
the
BRS
that
generate
waste
are
not
major
sources
of
HAPs
and
thus
would
not
be
subject
to
the
rule.
In
addition,
the
database
would
not
include
information
on
firms
that
are
major
sources
of
HAPs
but
generate
small
quantities
of
waste.
These
firms
may
still
be
required
to
comply
with
the
rule
but
would
not
be
identified
in
the
BRS
data.

Despite
these
limitations,
the
Agency
believes
the
BRS
data
provide
the
best
coverage
of
potentially
affected
firms
to
conduct
the
economic
impact
analysis.
As
stated
above,
providing
a
comprehensive
list
of
affected
industries
is
difficult
because
of
the
broad
nature
of
the
rule.
The
National
Toxics
Inventory
(
NTI)
is
a
database
that
can
be
used
to
identify
major
sources
of
HAP
emissions,
but
it
does
not
contain
the
information
on
site
remediation
activities
necessary
to
calculate
control
costs.
The
Agency
was
unable
to
match
the
BRS
data
with
the
data
on
major
sources
in
the
NTI.
Therefore,
it
was
determined
that
the
BRS
database
provides
the
best
indication
of
the
industries
that
might
be
affected
by
the
rule.

2.3
Control
Technologies
and
Compliance
Cost
Estimates3
The
Agency
calculated
estimated
compliance
costs
for
the
490
potentially
affected
industries.
Below,
we
briefly
describe
the
control
technologies
identified
in
the
rule
and
the
method
used
to
calculate
the
compliance
costs.

2.3.1
Control
Technologies
2­
5
The
proposed
rule
defines
three
groups
of
affected
sources:
process
vents,
remediation
material
management
units,
and
equipment
leaks.
The
affected
source
for
process
vents
is
the
entire
group
of
process
vents
associated
with
both
in
situ
and
ex
situ
remediation
activities.
The
affected
source
for
remediation
material
management
units
is
the
entire
group
of
tanks,
surface
impoundments,
containers,
oil/
water
separators,
and
transfer
systems
used
to
store,
transfer,
treat,

or
otherwise
manage
remediation
material.
The
affected
source
for
equipment
leaks
is
the
entire
group
of
remediation
equipment
components
(
e.
g.,
pumps,
valves)
that
contain
or
contact
remediation
material
having
a
total
organic
HAP
concentration
equal
to
or
greater
than
10
percent
by
weight
and
are
intended
to
operate
for
300
hours
or
more
during
a
calendar
year.

Given
the
unique
nature
of
the
site
remediation
source
category,
the
extent
of
information
currently
available
to
the
Agency,
and
the
complexities
of
gathering
additional
meaningful
information,
we
decided
to
forgo
statistically
computing
an
emission
limitation
or
identifying
a
specific
control
technology
that
represents
the
MACT
floor
for
site
remediations.
The
MACT
floor
for
existing
affected
sources
is
some
level
of
air
emission
control
beyond
no
controls.

Because
the
provisions
of
Section
112
allow
the
Agency
to
select
MACT
for
a
source
category
that
is
more
stringent
than
the
MACT
floor
(
provided
that
the
control
level
selected
is
technically
achievable
and
that
we
consider
the
cost
of
achieving
the
emissions
reductions,
any
nonair
quality
health
and
environmental
impacts,
and
energy
requirements
associated
with
the
selected
control
level
(
CAA
Section
112
(
d)
(
2)),
we
chose
to
select
the
MACT
technology
directly.

To
select
a
MACT
technology
from
alternatives
beyond
the
MACT
floor
for
each
affected
source,
we
looked
at
the
types
of
air
emission
controls
required
under
national
air
standards
for
sources
similar
to
those
sources
that
potentially
may
be
associated
with
site
remediations.
These
air
standards
are
NESHAP
for
other
source
categories,
particularly
the
Off­
Site
Waste
and
Recovery
Operations
(
OSWRO)
NESHAP
(
EPA,
1994,
as
cited
in
Zerbonia
[
2001])
under
40
CFR
63
subpart
DD,
and
the
air
standards
for
RCRA
hazardous
waste
treatment,
disposal,
and
recovery
facilities
under
subparts
AA,
BB,
and
CC
in
40
CFR
parts
264
and
265.
The
control
levels
established
by
the
emission
limitation
and
work
practices
proposed
in
the
rule
that
are
being
implemented
at
existing
sources
subject
to
these
similar
rules
demonstrate
that
the
control
levels
are
technically
achievable
(
Nizich,
2001).
4$
1997.
EPA
adjusted
the
$
2000
estimates
using
a
cost
factor
(
0.9753)
developed
from
the
Chemical
Engineering
Composite
Plant
Cost
Index.

2­
6
2.3.2
Control
Cost
Estimates4
According
to
the
nationwide
emission
and
control
cost
estimates
memorandum
(
Zerbonia,

2001),
in
estimating
nationwide
HAP
emissions
from
site
remediation
sources,
the
1997
BRS
database
was
used
to
estimate
the
quantity
of
remediation
wastes
generated
by
various
regulatory
categories
(
e.
g.,
underground
storage
tanks),
the
physical
form
of
the
remediation
wastes
generated
(
e.
g.,
inorganic
liquids,
organic
solids,
or
organic
sludges),
and
the
quantities
and
methods
used
to
manage
and
treat
the
remediation
wastes
on­
site
(
e.
g.,
incineration,
aqueous
organic
treatment,
or
stabilization).
The
1997
BRS
data
were
used
to
represent
nationwide
baseline
conditions
for
site
remediations
activities.
A
comparison
of
the
total
quantity
of
remediation­
derived
wastes
reported
in
the
BRS
database
for
the
years
1993,
1995,
and
1997
showed
that
the
total
quantity
of
remediation
waste
treated
on­
site
for
these
years
remained
about
the
same,
approximately
22
million
tons
(
this
estimate
includes
some
operations
that
are
exempt
from
the
rule).

The
estimation
of
control
costs
for
site
remediation
activities
was
based
on
the
methodology
developed
for
the
OSWRO
NESHAP
(
EPA,
1994,
as
cited
in
Zerbonia
[
2001]).

Using
this
methodology,
overall
control
cost
factors
were
developed
to
estimate
the
costs
of
applying
controls
to
the
various
remediation
waste
management
and
treatment
system
units
(
e.
g.,

tanks,
air
and
steam
strippers,
and
process
vents)
based
on
the
model
unit
type
used
to
characterize
the
remediation
activity.
Separate
cost
factors
were
developed
for
each
of
the
different
waste
management
model
units
based
on
the
"
form"
of
the
waste
stream.
Waste
form
codes
were
assigned
according
to
the
waste
description
code
reported
for
the
waste
stream.
The
total
annual
cost
for
the
control
requirement
is
$
7.80
million.

2.3.3
Monitoring,
Inspection,
Recordkeeping,
and
Reporting
Costs
According
to
the
nationwide
emission
and
control
cost
estimates
memorandum
(
Zerbonia,

2001),
the
annual
monitoring,
inspections,
recordkeeping,
and
reporting
(
MIRR)
costs
were
calculated
based
on
the
number
of
site
remediation
emission
sources
or
system
types
and
the
cost
factors
for
MIRR
source
types,
expressed
as
annual
cost
per
emission
source.
The
engineering
analysis
used
data
obtained
from
EPA's
1997
BRS
database
to
characterize
the
number
of
emission
sources
within
the
remediation
waste
treatment
category
or
system
type
that
would
be
required
to
apply
controls.
The
cost
factors
used
were
those
developed
for
the
OSWRO
NESHAP;
the
methodology
and
derivation
of
the
MIRR
cost
factors
are
discussed
in
Appendix
E
of
the
OSWRO
NESHAP
BID,
September
8,
1994.
The
costs
are
based
on
use
of
the
control
technologies
applicable
to
the
various
waste
management
and
treatment
system
types.
To
5Wastes
not
potentially
affected
by
the
MACT
applicability
(
i.
e.,
CERCLA
and
RCRA
Corrective
Action
sites
with
source
codes
of
A61,
A62,
and
A63)
were
not
included
in
the
analysis.

6$
1997.
EPA
adjusted
the
$
2000
estimates
using
a
cost
factor
(
0.9753)
developed
from
the
Chemical
Engineering
Composite
Plant
Cost
Index.

2­
7
estimate
MIRR
costs
the
Agency
had
to
determine
the
type
of
on­
site
process
systems
used
to
manage
or
treat
the
wastes
(
i.
e.,
treatment
methods).
This
information
was
obtained
from
Section
II,
Box
D
of
Form
GM.
The
total
annual
cost
for
MIRR
is
$
0.16
million.

2.3.4
Formatting
Engineering
Cost
Estimates
for
Economic
Analysis
The
total
quantity
of
waste
managed5
and
total
annual
compliance
costs
were
estimated
for
all
the
treatment
categories
(
see
Tables
6a
and
7a
of
the
control
cost
estimates
memorandum
[
Zerbonia,
2001]).
Using
this
information,
the
Agency
calculated
the
average
annual
control
cost
per
ton
of
waste
managed
in
each
treatment
category.
The
BRS
database
lists
the
quantity
of
waste
generated
by
facility
by
treatment
category.
Multiplying
the
average
control
cost
for
each
treatment
category
by
the
number
of
tons
of
waste
managed
by
a
facility
for
each
treatment
category
and
summing
over
all
the
treatment
categories
for
each
facility
yields
an
estimate
of
the
annual
compliance
cost
for
the
facility.
Aggregating
the
estimated
facility
compliance
costs
over
SIC
codes
produces
an
estimate
of
the
annual
compliance
cost
for
each
SIC
code
in
the
BRS
data.

The
annual
control
cost
estimates
by
SIC
code
are
only
approximations
based
on
average
costs
for
each
waste
stream
as
calculated
by
the
Agency.
However,
they
should
provide
a
basis
for
a
general
assessment
of
the
impact
of
the
proposed
regulation.

2.4
Summary
of
Estimated
Control
Costs
for
Potentially
Affected
Industries
Using
the
BRS
database,
of
the
490
industries
(
by
SIC)
potentially
affected
by
the
rule,

four
SIC
codes
generated
more
than
500
waste
streams
per
code,
28
SIC
codes
generated
more
than
100
waste
streams
per
code,
48
SIC
codes
generated
more
than
50
waste
streams
per
code,

84
SIC
codes
generated
more
than
25
waste
streams
per
code,
and
190
SIC
codes
generated
10
or
more
waste
streams
per
code.
Major
industry
sectors
that
are
engaged
in
site
remediation
activities
include
industrial
organic
chemical
manufacturing,
petroleum
refining,
waste
management
(
refuse),
plating
and
polishing,
aircraft,
and
semiconductors
to
list
a
few.

Using
the
methodology
described
above,
the
Agency
estimates
approximately
16
percent
of
the
490
potentially
affected
industries
identified
in
the
1997
BRS
database
might
have
faced
additional
control
costs
associated
with
HAP
and
VOC
emission
reductions
if
the
proposed
MACT
standards
had
been
implemented
in
1997.
According
to
the
nationwide
emission
and
control
cost
estimates
memorandum
(
Zerbonia,
2001),
total
control
costs
for
this
rule
are
estimated
to
be
$
7.96
million6.
Table
2­
1
presents
the
total
compliance
costs
for
the
top
15
2­
8
industries
potentially
affected
by
the
rule.
These
industries
account
for
91
percent
of
the
total
national
compliance
cost
estimate
(
see
Figure
2­
1).

Table
2­
1.
Total
Annual
Control
Costs
(
TACC)
for
Site
Remediation
MACT
by
Industry:
1997
BRS
Data
Set
SIC
Code
Description
Total
Annual
Control
Costsa
Share
of
TACC
3351
Copper
rolling
and
drawing
$
1,454,760
18%

2819
Industrial
inorganic
chemicals,
n.
e.
c.
$
1,164,347
15%

9999
Unclassifiable
establishments
$
1,055,556
13%

2869
Industrial
organic
chemicals,
n.
e.
c.
$
893,113
11%

3354
Aluminum
extruded
products
$
559,896
7%

2491
Wood
preserving
$
465,774
6%

3728
Aircrat
parts
and
equipment,
n.
e.
c.
$
393,920
5%

3334
Primary
aluminum
$
288,344
4%

2816
Inorganic
pigments
$
275,047
3%

3861
Photographic
equipment
and
supplies
$
194,294
2%

Unknown
$
128,052
2%

9224
Fire
Protection
$
116,520
1%

4953
Refuse
systems
$
113,032
1%

3795
Tanks
and
tank
components
$
83,487
1%

5171
Petroleum
bulk
stations
and
terminals
$
67,051
1%

Subtotal
$
7,243,193
91%

Other
$
716,356
9%

Total
$
7,959,549
100%

a
$
1997.
EPA
adjusted
the
$
2000
estimates
using
a
cost
factor
(
0.9753)
developed
from
the
Chemical
Engineering
Composite
Plant
Cost
Index.
Note
these
cost
also
include
in
situ.
2­
9
Refuse
Systems
(
1%)
Fire
Protection
(
1%)

Unknown
(
2%)
Photographic
Equipment
and
Supplies
(
2%)

Primary
Aluminum
(
4%)

Aircraft
Parts
and
Equipment,
n.
e.
c.
(
5%)
Industrial
Organic
Chemicals,
n.
e.
c.
(
11%)
Unclassifiable
Establishments
(
13%)
Copper
Rolling
and
Drawing
(
18%)

Industrial
Inorganic
Chemicals,
n.
e.
c.
(
15%)
Tanks
and
Tank
Components
(
1%)
Other
(
9%)

Wood
Preserving
(
6%)
Aluminum
Extruded
Products
(
7%)
Petroleum
Bulk
Stations
and
Terminals
(
1%)

Inorganic
Pigments
(
3%)
TACC
=
$
7.96
million
Figure
2­
1.
Distribution
of
Total
Annual
Compliance
Costs
by
Industry
($
1997)
3­
1
SECTION
3
ECONOMIC
IMPACT
ANALYSIS:
METHODS
AND
RESULTS
The
underlying
objective
of
the
economic
impact
analysis
is
to
evaluate
the
effect
of
the
proposed
regulation
on
the
welfare
of
affected
stakeholders
and
society
in
general.
The
proposed
rules
to
control
air
pollution
sources
from
site
remediation
activities
will
affect
a
wide
variety
of
industries.
Implementation
of
the
proposed
rules
will
increase
the
costs
of
production
at
affected
facilities.
The
response
of
producers
to
the
additional
production
costs
associated
with
rule
compliance
and
the
response
of
consumers
to
changed
market
conditions
determine
the
economic
impact
of
the
regulation.
Specifically,
the
increased
costs
of
production
associated
with
the
rule
may
induce
affected
owners
to
change
production
processes,
inputs,
or
output
rates
or
to
cease
operations.
If
the
remediation
is
not
required,
the
increased
costs
associated
with
the
rule
may
alter
the
firm's
decision
about
whether
or
not
to
remediate.
These
actions
have
broader
societal
implications
because
they
are
transmitted
through
market
relationships
such
as
price
and
output
to
producers
and
consumers.

EPA
typically
develops
partial
equilibrium
computational
models
to
measure
the
size
and
distribution
of
economic
impacts
associated
with
air
pollution
regulations.
These
models
account
for
behavioral
responses
by
producers
and
consumers
to
the
regulation
(
i.
e.,
reactions
by
producers
and
consumers
result
in
changes
in
prices
and
production
levels).
Many
attempts
were
made
to
collect
data
in
the
format
needed
for
such
an
analysis.
After
critical
review,
however,
the
Agency
concluded
that
the
data
were
insufficient
to
develop
a
market
model.
As
a
result,
the
Agency
developed
a
qualitative
description
of
potential
market
impacts
of
the
rule
and
conducted
a
simple
screening
analysis,
described
in
more
detail
below,
to
develop
quantitative
measures
of
the
economic
impacts
associated
with
the
rule.

3.1
Qualitative
Discussion
of
Economic
Impacts
on
Firms
and
Consumers
The
proposed
rule
will
potentially
change
the
decisions
made
by
firms
regarding
the
remediation
of
contaminated
media
(
e.
g.,
soil
or
ground
water)
and
ultimately
could
influence
decisions
regarding
their
primary
production
operations.
As
a
result
of
changes
in
the
cost
of
production
at
the
firm
level,
supply
and
demand
for
services
will
directly
impact
the
affected
industry
and
may
indirectly
impact
other
industries.
Below
we
describe
the
possible
actions
for
firms
that
will
have
sites
they
need
to
remediate
at
the
time
the
rule
is
implemented
and
the
decision
firms
face
about
the
generation
and
clean
up
of
future
contaminated
media.
We
discuss
3­
2
the
possible
impacts
on
market
supply
and
demand
for
the
final
products
in
the
affected
industry
and
indirect
impacts
on
other
industries.
Finally,
we
summarize
the
possible
impacts
on
consumers
and
social
welfare.

3.1.1
Firm­
Level
Decisions
In
baseline,
firms
choose
a
mix
of
products,
level
of
production,
and
method
of
production.
The
production
process
generates
materials
and
residual
wastes
that
can
contaminate
the
local
media
at
the
site,
both
anticipated
and
accidental,
that
must
be
remediated
either
on­
site
or
off­
site.
Firms
that
remediate
on­
site
can
choose
between
one
or
more
on­
site
treatment
methods
and
purchasing
remediation
services
from
off­
site
providers.
Off­
site
waste
handlers
will
also
choose
between
one
or
more
treatment
methods
to
handle
the
flow
of
waste
they
receive
from
site
remediation
projects
and
other
sources.
Given
these
choices,
firms
will
attempt
to
minimize
costs
of
complying
with
new
regulations.

3.1.1.1
Remediation
Resulting
from
Past
Production
Decisions
Depending
on
the
choices
firms
have
made
in
the
past,
there
may
be
contaminated
media
that
must
be
remediated
when
the
proposed
rule
is
implemented.
These
firms
face
a
choice
of
remediating
the
waste
or
materials
on­
site
or
shipping
off­
site
to
a
third­
party
remediator.
The
rule
will
potentially
affect
the
costs
of
both
alternatives.
Firms
that
decide
to
remediate
waste
materials
from
site
remediation
projects
on­
site
will
face
increased
costs
for
remediation
due
to
the
rule.
The
rule
may
also
change
the
relative
cost
of
different
remediation
alternatives,
leading
the
firm
to
change
the
way
it
treats
remediation
waste
materials.
In
either
case,
the
cost
of
on­
site
remediation
will
increase,
causing
an
increase
in
the
cost
of
producing
the
final
goods
supplied
by
that
firm.

Alternatively,
the
firm
could
decide
to
send
its
remediation
waste
materials
off­
site
for
treatment.
As
discussed
in
Section
2,
the
Agency
assumes
that
the
off­
site
waste
treatment
firms
have
already
installed
the
required
control
technology,
so
the
proposed
rule
should
not
impose
additional
costs
on
off­
site
waste
treatment
facilities.
However,
if
demand
for
off­
site
waste
treatment
increases
as
a
result
of
the
rule,
then
the
cost
of
off­
site
remediation
may
increase.

Figure
3­
1
shows
the
upward­
sloping
supply
curve
for
off­
site
remediation
services,
Soff,
and
a
baseline
demand
curve,
D.
Assuming
that
the
off­
site
remediation
industry
is
perfectly
competitive,
an
increase
in
demand
to
D

will
result
in
an
increase
in
the
price
of
off­
site
remediation
services
from
Poff
to
Poff

.
3­
3
$

D
Soff
poff
poff
 

Qoff
Qoff
 
D
 

Figure
3­
1.
Market
for
Off­
Site
Waste
Treatment
Services
Q
$
MCfinal
good
 

MCfinal
good
2.
Marginal
Cost
Curve
for
Final
Market
Good
Regardless
of
whether
the
site
remediation
waste
material
is
treated
on­
site
or
off­
site,
the
cost
of
remediation
may
increase,
leading
to
an
increase
in
the
cost
of
producing
the
final
market
goods
supplied
by
the
firm.
In
Figure
3­
2
the
marginal
cost
curve
for
producing
the
final
market
good
for
a
firm
in
a
perfectly
competitive
industry
will
shift
upwards
from
MCfinal
good
to
MCfinal
good

indicating
an
increase
in
the
marginal
cost
of
producing
a
unit
of
the
final
market
good.

The
following
firm
decision
rule
summarizes
the
options
the
firm
faces:

[
]
min
(
);
(
,
)
C
p
C
b
c
off
on
on
where
C(
poff)
is
the
cost
of
off­
site
remediation
given
the
price
of
remediation
services.
C(
bon,
con)

is
the
total
cost
of
on­
site
remediation,
which
is
equal
to
the
baseline
cost
of
on­
site
remediation
(
bon)
and
the
additional
cost
associated
with
the
rule
(
con).
The
firm
will
choose
the
treatment
strategy
that
minimizes
the
cost
of
treating
site
remediation
waste
given
the
additional
costs
imposed
by
the
rule
directly
on
firms
that
remediate
on­
site
and
indirectly
through
an
increase
in
the
demand
for
off­
site
treatment
services
for
firms
that
send
their
waste
off­
site
for
treatment.

3.1.1.2
Remediation
Resulting
from
Future
Production
Decisions
The
proposed
rule
may
also
influence
future
production
decisions
that
affect
the
generation
of
wastes
that
could
contaminate
local
media
and
ultimately
need
remediation.
In
this
context,
firms
have
more
options
than
when
they
are
facing
the
choice
of
how
to
clean
up
existing
contaminated
media.
In
addition
to
the
choice
between
on­
site
and
off­
site
management
of
remediation
materials,
looking
to
the
future
firms
may
choose
to
3­
4
Q 
P
Q
P 
$
Sfinal
good
 

Sfinal
good
Dfinal
good
Figure
3­
3.
Market
Equilibrium
Without
and
With
Regulation

change
output
levels
to
reduce
the
amount
of
waste
generated
or
the
likelihood
of
an
accidental
release
of
hazardous
waste,


change
the
mix
of
outputs
to
produce
products
that
generate
less
waste
or
reduce
the
likelihood
of
an
accidental
release
of
waste,


change
production
processes
or
the
mix
of
inputs
to
reduce
the
amount
of
waste
generated
or
reduce
the
likelihood
of
an
accidental
release
of
waste,
or

cease
operations
if
total
revenues
are
less
than
total
costs
(
production
costs
plus
remediation
costs).

3.1.2
A
Qualitative
Analysis
of
Market
Impacts
The
Agency
qualitatively
evaluated
the
potential
market
impacts
of
the
rule
using
the
model
of
perfect
competition.
In
these
markets,
buyers
and
sellers
exert
no
individual
influence
on
market
prices.
Price
is
set
by
the
collective
actions
of
producers
and
consumers
of
products
and
services
who
take
the
market
price
as
a
given
in
making
their
production
and
consumption
choices.
Figure
3­
3
illustrates
a
market
in
which
prices
and
quantities
for
final
goods
are
determined
by
the
intersection
of
market
supply
and
demand
curves.
The
baseline
consists
of
a
market
price
and
quantity
(
P,
Q)
that
is
determined
by
the
downward­
sloping
market
demand
curve
(
Dfinal
goods)
and
the
upward­
sloping
market
supply
curve
(
Sfinal
goods).
3­
5
Incorporating
these
regulatory
control
costs
results
in
an
upward
shift
(
from
Sfinal
goods
to
Sfinal
goods

)
of
the
aggregate
supply
curve.
At
the
new
equilibrium
with
the
regulation,
the
market
price
increases
from
P
to
P

and
market
output
declines
from
Q
to
Q

.
In
the
long
run,
if
the
firms
decide
to
change
the
mix
of
inputs
or
outputs
produced
as
a
result
of
the
regulation,
this
will
further
affect
market
prices
and
quantities.
To
the
extent
that
firms
are
able
to
adapt
their
processes
to
reduce
the
need
for
site
remediation
or
to
reduce
the
cost
of
treating
the
waste
from
site
remediation,
the
long­
run
costs
of
the
rule
may
be
lower.

3.1.3
Impact
on
Consumers
and
Social
Welfare
The
analytics
above
suggest
we
could
expect
upward
pressure
on
prices
in
industries
that
need
site
remediation
services,
so
prices
will
be
directly
or
indirectly
affected
by
the
proposed
regulation
as
producers
make
new
choices.
Among
other
things,
the
magnitude
of
these
price
changes
would
depend
on

the
size
of
the
unit
control
costs
relative
to
market
price,


the
elasticity
of
consumer
demand
for
the
products,


the
elasticity
of
supply
by
the
producers,
and

the
number
of
affected
firms
and
their
share
of
the
market.

Higher
production
costs
and
increases
in
price
reduce
quantity
demanded
by
consumers
and
output
by
firms
for
each
product,
leading
to
changes
in
economic
welfare
of
consumers
and
the
profitability
of
firms.
These
market
adjustments
would
determine
the
social
costs
of
the
regulation
and
its
distribution
across
stakeholders
(
producers
and
consumers).
Without
more
detailed
data
and
analysis,
predicting
the
magnitude
of
the
social
costs
of
the
regulation
is
difficult.

3.2
Selection
of
Industries
for
the
Economic
Impact
Analysis
As
discussed
in
Section
2,
the
Agency
identified
over
490
industries
(
SIC
codes)
that
would
potentially
have
been
affected
by
the
rule
using
the
1997
BRS
database.
Out
of
this
490,

over
80
industries
were
identified
that
might
have
faced
additional
control
costs
if
the
proposed
MACT
standards
had
been
implemented
in
1997.
The
data
requirements
for
collecting
data
on
each
of
these
industry's
activities
(
i.
e.,
company
financial
data
for
each
affected
company
within
the
industry
and
market
data
for
each
affected
industry)
are
substantive
given
the
large
number
of
potentially
affected
industries.
Therefore,
the
Agency
employed
the
following
strategy
to
select
a
limited
number
of
industries
for
the
economic
analysis.
First,
the
Agency
aggregated
the
facilitylevel
costs
by
SIC
code
to
compute
the
total
costs
of
the
rule
for
each
affected
SIC
code
(
presented
in
Table
2­
1).
The
cost
estimates
do
not
include
Superfund
NPL
sites
and
permitted
3­
6
or
federal
order
RCRA
corrective
action
cleanups
that
are
exempted
from
the
rule.
Out
of
this
list,
EPA
identified
the
15
industries
with
the
highest
total
annual
compliance
cost
estimates.

These
15
industries,
listed
in
Table
3­
1,
account
for
approximately
91
percent
of
the
total
national
compliance
cost
estimate
($
7.24
million).
Given
the
uncertainty
about
which
firms
would
be
impacted
and
because
the
BRS
data
is
reported
using
the
SIC
system
and
the
bridges
between
the
SIC
and
NAICS
code
classifications
were
not
one­
to­
one
for
all
industries,
EPA
determined
the
most
appropriate
way
to
analyze
the
industry
data
was
using
the
SIC
system.
Table
3­
2
lists
the
NAICS
codes
associated
with
the
15
SIC
codes
analyzed
that
would
potentially
be
impacted
by
the
rule.

3.3
Economic
Impact
Methodology
and
Results
The
Agency
employed
an
engineering
or
financial
analysis
to
estimate
impacts,
which
takes
the
form
of
the
ratio
of
compliance
costs
to
the
value
of
sales
(
cost­
to­
sales
ratio
or
CSR).

The
analysis
assesses
the
burden
of
the
rule
by
assuming
the
affected
firms
fully
absorb
the
control
costs,
rather
than
passing
them
on
to
consumers
in
the
form
of
higher
prices.
One
drawback
for
this
approach
is
that
it
does
not
consider
interaction
between
producers
and
consumers
in
a
market
context
(
i.
e.,
the
interaction
between
change
in
price
and
change
in
quantity
demanded
and
supplied).
Therefore,
it
likely
overstates
the
impacts
on
facilities
and
firms
affected
by
the
rule
and
understates
the
impacts
on
consumers.
EPA
calculated
a
CSR
for
each
of
the
15
industries
as
follows:

CSR
=
Total
Annual
Compliance
Costs/
Values
of
Shipments
or
Receipts
(
3.1)

To
compute
these
ratios,
EPA
attempted
to
collect
basic
economic
information
for
all
15
industries
identified
in
Section
3.2
using
the
U.
S.
Census
Bureau's
"
Comparative
Statistics
1987
SIC
Basis"
(
U.
S.
Census
Bureau,
2001)
(
see
Table
3­
1).
However,
1997
data
were
available
for
only
8
of
the
15
industries
(
53
percent).
The
Agency
obtained
1992
revenue
statistics
for
four
of
the
remaining
seven
industries
missing
data
(
U.
S.
Census
Bureau,
1995a­
d).
For
the
screening
analysis,
1992
data
were
adjusted
to
1997
dollars
using
a
GDP
deflator.
As
shown
in
Table
3­
3,

shipments
for
the
12
industries
ranged
from
$
4
to
$
182
billion.

The
CSR
analysis
results
do
not
show
significant
impacts
for
any
industry.
All
of
the
ratios
are
less
than
0.02
percent.
A
review
of
profitability
measures
(
Dun
&
Bradstreet,
1997)

shows
that
these
values
are
significantly
below
return­
on­
sales
(
ROS)
data
for
even
the
lower
quartiles
of
industries
with
data
available.
The
lowest
lower
quartile
ROS
measure
was
0.4
percent
(
petroleum
bulk
stations
and
terminals).

The
CSR
should
be
interpreted
with
care.
Again,
we
emphasize
that
this
approach
does
not
account
for
the
fact
that
the
regulation
may
cause
the
economic
conditions
to
change.
The
3­
7
CSR
approach
assumes
that
firms
continue
to
produce
the
same
quantity
of
output
using
the
same
inputs,
production
process,
and
remediation
method.
In
addition,
the
firms
are
assumed
to
absorb
all
costs.
This
approach
essentially
holds
fixed
all
interaction
between
facility
production
and
market
forces.
In
reality,
some
percentage
of
the
control
costs
may
be
passed
along
to
other
parties
through
various
economic
exchanges.
Therefore,
it
is
likely
that
the
CSR
overstates
the
impacts
on
industries
and
understates
the
impacts
on
consumers.

3.4
Small
Business
Impacts
Small
business
impacts
were
particularly
difficult
to
assess.
As
discussed
in
the
Preamble,

this
rule
sets
minimum
standards
to
be
met
when
parties
engage
in
future
site
remediation
activities,
but
it
does
not
itself
require
any
party
to
undertake
such
activities.
States
may
choose
to
direct
a
party
to
undertake
site
remediation,
or
parties
may
undertake
remediation
activities
voluntarily.
EPA
anticipates
that
parties
that
undertake
site
remediation
generally
will
do
so
voluntarily
and
that
the
impact
of
this
rule
on
those
parties
will
not
be
significant.
Further,

because
States
and
other
parties
will
decide
whether
to
undertake
site
remediation
activities,
it
is
extremely
difficult,
if
not
impossible,
to
predict
how
many
or
what
types
of
small
entities
will
undertake
such
activities.
The
rule
is
structured
to
avoid
impacts
on
small
businesses.
The
rule
specifically
excludes
from
its
scope
remediations
conducted
at
gasoline
stations,
farm
sites
and
residential
sites
(
on
the
ground
that
these
remediations
would
not
exceed
the
threshold
for
major
sources).
Moreover,
the
rule
would
apply
only
to
remediation
sites
3­
8
Table
3­
1.
Economic
Data
for
15
Industries
with
Highest
Total
Annual
Control
Costs
(
TACC)

SIC
Code
Description
Establishments
Value
of
Shipments
($
103)
Paid
Employees
Annual
Payroll
($
103)

2491
Wood
Preserving
451
$
4,461,521
11,668
$
298,123
2816
Inorganic
Pigments
74
$
3,734,497
8,608
$
395,570
2819
Industrial
Inorganic
Chemicals,
NEC
667
D
D
D
2869
Industrial
Organic
Chemicals,
NEC
740
D
D
D
3334
Primary
Aluminum
21
$
6,224,610
15,763
$
707,402
3351
Copper
Rolling
and
Drawing
129
$
7,679,080
21,150
$
786,621
3354
Aluminum
Extruded
Products
160
$
6,177,701
30,357
$
944,829
3728
Aircraft
Parts
and
Equipment,
NEC
1,138
$
20,073,061
127,729
$
5,747,346
3795
Tanks
and
Tank
Components
37
D
D
D
3861
Photographic
Equipment
and
Supplies
739
$
21,305,761
63,642
$
2,928,089
4953
Refuse
Systems
NR
NR
NR
NR
5171
Petroleum
Bulk
Stations
and
Terminals
9,104
$
181,554,365
116,215
$
3,524,999
9224
Fire
Protection
NR
NR
NR
NR
9999
Unclassifiable
Establishments
NA
NA
NA
NA
Unknown
NA
NA
NA
NA
D
=
Withheld
to
avoid
disclosure.

NA
=
Not
available.

NR
=
Not
reported.

Source:
U.
S.
Bureau
of
the
Census.
"
Comparative
Statistics
1987
SIC
Basis."
<
http://
www.
census.
gov/
epcd/
ec97sic/>.
As
obtained
on
December
20,

2001.
3­
9
Table
3­
2.
SIC
and
NAICS
Codes
for
15
Industries
with
Highest
Total
Annual
Control
Costs
SIC
Code
Description
NAICS
NAICS
Description
2491
Wood
preserving
321114
Wood
preservation
2816
Inorganic
pigments
325131
Inorganic
Dye
and
Pigment
Manufacturing
(
pt)

325182
Carbon
Black
Manufacturing
(
pt)

2819
Industrial
inorganic
chemicals,
n.
e.
c.
211112
Natural
gas
liquid
extraction
325131
Inorganic
dye
and
pigment
mfg
325188
All
other
basic
inorganic
chemical
mfg
325998
All
other
miscellaneous
chemical
product
and
preparation
mfg
331311
Alumina
refining
2869
Industrial
organic
chemicals,
n.
e.
c.
325110
Petrochemical
Manufacturing
(
pt)

325188
All
other
basic
inorganic
chemical
mfg
(
pt)

325193
Ethyl
alcohol
mfg
325120
Industrial
gas
mfg
(
pt)

325199
All
other
basic
organic
chemical
mfg
(
pt)

3334
Primary
aluminum
331312
Primary
aluminum
production
3351
Copper
rolling
and
drawing
331421
Copper
rolling,
drawing,
and
extruding
3354
Aluminum
extruded
products
331316
Aluminum
extruded
product
mfg
3728
Aircraft
parts
and
equipment,
n.
e.
c.
336413
Other
aircraft
part
and
auxiliary
equipment
mfg
3795
Tanks
and
tank
components
336992
Military
armored
vehicle,
tank,
and
tank
component
mfg
(
pt)
(
continued)
3­
10
Table
3­
2.
SIC
and
nNAICS
Codes
for
15
Industries
with
Highest
Total
Annual
Control
Costs
(
continued)

SIC
Code
Description
NAICS
NAICS
Description
3861
Photographic
equipment
and
supplies
325992
Photographic
film,
paper,
plate,
and
chemical
mfg
333315
Photographic
and
photocopying
equipment
mfg
(
pt)

4953
Refuse
Systems
562211
Hazardous
waste
treatment
and
disposal
562212
Solid
waste
landfill
562213
Solid
waste
combustors
and
incinerators
562219
Other
nonhazardous
waste
treatment
and
disposal
562920
Materials
recovery
facility
5171
Petroleum
bulk
stations
and
terminals
422710
Petroleum
bulk
stations
and
terminals
454311
Heating
oil
dealers
(
selling
for
consumption
 
retail)

454312
Liquefied
petroleum
dealers
(
selling
for
consumption
 
retail)

9224
Fire
Protection
92216
Fire
Protection
9999
Unclassifiable
Establishments
NA
Unknown
NA
3­
11
Table
3­
3.
Economic
Impact
Screening
Analysis
SIC
Code
Description
Value
of
Shipments
($
103)
Total
Annual
Compliance
Costs
($
103)
Cost­
to­
Sales
Ratio
Lower
Quartile."

Return
on
Sales
2491
Wood
Preserving
$
4,461,521
$
418
0.009%
0.6%

2816
Inorganic
Pigments
$
3,724,497
$
258
0.007%
NA
2819
Industrial
Inorganic
Chemicals,
NEC
$
20,169,205
$
1,158
0.006%
0.9%

2869
Industrial
Organic
Chemicals,
NEC
$
60,226,652
$
737
0.001%
1.2%

3334
Primary
Aluminum
$
6,224,610
$
367
0.006%
NA
3351
Copper
Rolling
and
Drawing
$
7,679,080
$
1,306
0.017%
NA
3354
Aluminum
Extruded
Products
$
6,177,701
$
551
0.009%
1.8%

3728
Aircraft
Parts
and
Equipment,
NEC
$
20,073,061
$
259
0.001%
1.3%

3795
Tanks
and
Tank
Components
$
22,586,854
$
80
0.000%
NA
3861
Photographic
Equipment
and
Supplies
$
21,305,761
$
175
0.001%
0.7%

4953
Refuse
Systems
$
15,654,017
$
104
0.001%
0.5%

5171
Petroleum
Bulk
Stations
and
Terminals
$
181,554,365
$
60
0.000%
0.4%

9224
Fire
Protection
NR
$
115
NA
NA
9999
Unclassifiable
Establishments
NA
$
891
NA
NA
Unknown
NA
$
111
NA
NA
NA
=
Not
available.

NR
=
Not
reported.

Source:
U.
S.
Bureau
of
the
Census.
"
Comparative
Statistics
1987
SIC
Basis."
<
http://
www.
census.
gov/
epcd/
ec97sic/>.
As
obtained
on
December
20,
2001.

Dun
and
Bradstreet.
1997.
Industry
Norms
&
Key
Business
Ratios:
Desk­
Top
Edition
1996­
97.
Murray
Hill,
NJ:
Dun
&
Bradstreet.

U.
S.
Bureau
of
the
Census.
March
10,
1995a.
1992
Census
of
Manufactures
 
Industry
Series:
Industrial
Inorganic
Chemicals
(
Industries
2812,
2813,

2816,
and
2819).
MC92­
I­
28A.
Washington,
DC:
U.
S.
Government
Printing
Office.

U.
S.
Bureau
of
the
Census.
March
2,
1995b.
1992
Census
of
Manufactures
 
Industry
Series:
Industrial
Organic
Chemicals
(
Industries
2861,
2865,
and
2869).
MC92­
I­
28F.
Washington,
DC:
U.
S.
Government
Printing
Office.

U.
S.
Bureau
of
the
Census.
February
24,
1995c.
1992
Census
of
Manufactures
 
Industry
Series:
Shp
and
Boat
Building,
Railroad
and
Miscellaneous
Transportation
Equipment
(
Industries
3731,
3732,
3743,
3751,
3792,
3795,
and
3799).
MC92­
I­
37C.
Washington,
DC:
U.
S.
Government
Printing
Office.

U.
S.
Bureau
of
the
Census.
April
19,
1995d.
1992
Census
of
Transportation,
Communications,
and
Utilities
 
Subject
Series:
Establishment
and
Firm
Size
(
Including
Legal
Form
of
Organization).
UC92­
S­
1.
Washington,
DC:
U.
S.
Government
Printing
Office.
3­
12
located
at
a
facility
that
is
a
major
source
under
the
Clean
Air
Act
and
engages
in
a
"
MACT
activity"
(
defined
as
a
non­
remediation
activity
covered
in
the
MACT
list
of
major
source
categories
pursuant
to
CAA
section
112
(
c)).
Such
sources
tend
to
be
large
businesses.
The
rule
also
contains
emission
thresholds
that
are
not
likely
to
apply
to
small
businesses.
For
example,
the
rule
exempts
sources
where
the
total
annual
quantity
of
HAP
contained
in
all
extracted
remediation
material
at
the
facility
is
less
than
1
Mg
per
year.
For
these
reasons,
EPA
certifies
that
the
rule,
if
promulgated,
will
not
impose
a
significant
economic
impact
on
a
substantial
number
of
small
entities.

3.5
Conclusions
and
Qualifications
3.5.1
Conclusions
The
economic
impact
analyses
focused
on
a
set
of
industries
that
were
known
to
be
large
quantity
generators
of
hazardous
waste
who
were
generating
hazardous
and
non­
hazardous
waste
as
part
of
a
site
remediation
in
1997
as
reported
in
the
BRS
database.
The
Agency
believes
that
the
data
provide
an
overview
of
the
potential
impacts
of
the
rule.
However
the
Agency
recognizes
that
the
set
of
industries
identified
in
the
data
will
probably
not
be
the
exact
industries
that
will
be
directly
affected
by
the
rule
in
the
year
the
rule
is
implemented.
As
stated
in
Section
3.4,
the
Agency
anticipates
that
parties
that
undertake
site
remediation
generally
will
do
so
voluntarily
and
that
the
impact
of
this
rule
on
those
parties
will
not
be
significant.

3.5.2
Qualifications
In
addition
to
qualifications
mentioned
elsewhere
in
the
report,
the
results
and
assessments
of
the
screening
analysis
should
be
viewed
in
light
of
the
following
limitations
and
uncertainties:


EPA
used
the
1997
BRS
database
to
identify
future
remediation
sites.
The
actual
firms
and
industries
affected
by
the
rule
may
differ
from
this
population.


The
1997
categories
of
waste
treatment
options
in
the
BRS
may
change
and/
or
the
distribution
of
wastes
within
each
category
may
change
for
future
remediation
sites.


The
engineering
cost
estimates
represent
an
upper­
bound
estimate
for
the
firm's
costs.
There
may
be
lower
cost
alternatives
that
achieve
the
same
emission
reductions.


Superfund
NPL
sites
and
permitted
or
federal
order
RCRA
corrective
action
cleanups
are
exempted
from
the
rule.
R­
1
REFERENCES
Dun
and
Bradstreet.
1997.
Industry
Norms
&
Key
Business
Ratios:
Desk­
Top
Edition
1996­
97.

Murray
Hill,
NJ:
Dun
&
Bradstreet.

Nizich,
Greg,
EPA/
WCPG.
December
19,
2001.
Personal
communication
with
Carol
Mansfield,

RTI.
Updated
preamble
and
rule
for
site
remediation.

U.
S.
Bureau
of
the
Census.
March
10,
1995a.
1992
Census
of
Manufactures
 
Industry
Series:

Industrial
Inorganic
Chemicals
(
Industries
2812,
2813,
2816,
and
2819).
MC92­
I­
28A.

Washington,
DC:
U.
S.
Government
Printing
Office.

U.
S.
Bureau
of
the
Census.
March
2,
1995b.
1992
Census
of
Manufactures
 
Industry
Series:

Industrial
Organic
Chemicals
(
Industries
2861,
2865,
and
2869).
MC92­
I­
28F.

Washington,
DC:
U.
S.
Government
Printing
Office.

U.
S.
Bureau
of
the
Census.
February
24,
1995c.
1992
Census
of
Manufactures
 
Industry
Series:
Ship
and
Boat
Building,
Railroad
and
Miscellaneous
Transportation
Equipment
(
Industries
3731,
3732,
3743,
3751,
3792,
3795,
and
3799).
MC92­
I­
37C.
Washington,

DC:
U.
S.
Government
Printing
Office.

U.
S.
Bureau
of
the
Census.
April
19,
1995d.
1992
Census
of
Transportation,
Communications,

and
Utilities
 
Subject
Series:
Establishment
and
Firm
Size
(
Including
Legal
Form
of
Organization).
UC92­
S­
1.
Washington,
DC:
U.
S.
Government
Printing
Office.

U.
S.
Bureau
of
the
Census.
2000.
E9700A1:
Economy­
Wide
Key
Statistics
(
1997
NAICS
Basis):
1997
[
Computer
File].
<
http://
factfinder.
census.
gov/
servlet/

DatasetMainPageServlet?_
lang=
en>.

U.
S.
Bureau
of
the
Census.
"
Comparative
Statistics
1987
SIC
Basis."

<
http://
www.
census.
gov/
epcd/
ec97sic/>.
As
obtained
on
December
20,
2001.
R­
2
U.
S.
Environmental
Protection
Agency
(
EPA).
<
http://
www.
epa.
gov/
epaoswer/

hazwaste/
data/
br97/
index.
htm>.
1999a.

U.
S.
Environmental
Protection
Agency
(
EPA).
1999b.
OAQPS
Economic
Analysis
Resource
Document.
Durham,
NC:
Innovative
Strategies
and
Economics
Group.

Zerbonia,
Robert,
RTI.
September
26,
2001.
Personal
communication
with
Greg
Nizich,

EPA/
WCPG.
Summary
of
nationwide
emission
and
control
cost
estimates
for
the
site
remediation
MACT
project.
TECHNICAL
REPORT
DATA
(
Please
read
Instructions
on
reverse
before
completing)

1.
REPORT
NO.

EPA­
452/
R­
03­
016
2.
3.
RECIPIENT'S
ACCESSION
NO.

4.
TITLE
AND
SUBTITLE
Economic
Impact
Analysis
of
the
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Site
Remediation
­
Final
Draft
5.
REPORT
DATE
August
2003
6.
PERFORMING
ORGANIZATION
CODE
7.
AUTHOR(
S)
8.
PERFORMING
ORGANIZATION
REPORT
NO.

RTI
Project
Number
7647­
004­
392
9.
PERFORMING
ORGANIZATION
NAME
AND
ADDRESS
RTI
International
Center
for
Regulatory
Economics
and
Policy
Research,
Hobbs
Bldg.
Research
Triangle
Park,
NC
27709
10.
PROGRAM
ELEMENT
NO.

11.
CONTRACT/
GRANT
NO.

68­
D­
99­
024
12.
SPONSORING
AGENCY
NAME
AND
ADDRESS
Office
of
Air
Quality
Planning
and
Standards
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
13.
TYPE
OF
REPORT
AND
PERIOD
COVERED
Final
14.
SPONSORING
AGENCY
CODE
EPA/
200/
04
15.
SUPPLEMENTARY
NOTES
16.
ABSTRACT
The
final
rule
would
implement
Section
112(
d)
of
the
CAA
by
requiring
those
affected
site
remediation
activities
to
meet
emission
limitation,
operating
limit,
and
work
practice
standards
reflecting
the
application
of
the
maximum
achievable
control
technology
(
MACT).
The
economic
impact
analyses
focused
on
a
set
of
industries
that
were
known
to
be
large
quantity
generators
of
hazardous
waste
who
were
generating
hazardous
and
non­
hazardous
waste
as
part
of
a
site
remediation
in
1997
as
reported
in
the
BRS
database.
The
Agency
believes
that
the
data
provide
an
overview
of
the
potential
impacts
of
the
rule.
The
Agency
employed
an
engineering
or
financial
analysis
that
takes
the
form
of
estimating
impacts
through
the
ratio
of
compliance
costs
to
the
value
of
sales
(
cost­
to­
sales
ratio
or
CSR)
using
total
industry
revenues,
control
costs,
and
accounting
measures
of
profit.

17.
KEY
WORDS
AND
DOCUMENT
ANALYSIS
a.
DESCRIPTORS
b.
IDENTIFIERS/
OPEN
ENDED
TERMS
c.
COSATI
Field/
Group
economic
impacts
small
business
impacts
social
costs
Air
Pollution
Control
Economic
Impact
Analysis
Regulatory
Flexibility
Analysis
18.
DISTRIBUTION
STATEMENT
Release
Unlimited
19.
SECURITY
CLASS
(
Report)

Unclassified
21.
NO.
OF
PAGES
36
20.
SECURITY
CLASS
(
Page)

Unclassified
22.
PRICE
R­
4
EPA
Form
2220­
1
(
Rev.
4­
77)
PREVIOUS
EDITION
IS
OBSOLETE
United
States
Office
of
Air
Quality
Planning
and
Standards
Publication
No.
EPA­
452/
R­
03­
016
Environmental
Protection
Air
Quality
Strategies
and
Standards
Division
August
2003
Agency
Research
Triangle
Park,
NC
