November
2005
Impacts
of
Other
Solid
Waste
Incinerator
Rule
on
Affected
Small
Entities
Draft
Report
Prepared
for
Gayle
Kline
ICF
Consulting
9300
Lee
Highway
Fairfax,
VA
22031
For
delivery
to
William
Nickerson
U.
S.
Environmental
Protection
Agency
Headquarters
Office
of
Policy,
Economics,
and
Innovation
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
Prepared
by
Katherine
Heller
Thomas
Holloway
Jeff
Coburn
Alex
Rogozhin
RTI
International
Health,
Social,
and
Economics
Research
Research
Triangle
Park,
NC
27709
EPA
Contract
Number
68­
W­
02­
045
RTI
Project
Number
0208687.003.054
EPA
Contract
Number
RTI
Project
Number
68­
W­
02­
045
0208687.003.054
Impacts
of
Other
Solid
Waste
Incinerator
Rule
on
Affected
Small
Entities
Draft
Report
November
2005
Prepared
for
Gayle
Kline
ICF
Consulting
9300
Lee
Highway
Fairfax,
VA
22031
For
delivery
to
William
Nickerson
U.
S.
Environmental
Protection
Agency
Headquarters
Office
of
Policy,
Economics,
and
Innovation
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
Prepared
by
Katherine
Heller
Thomas
Holloway
Jeff
Coburn
Alex
Rogozhin
RTI
International*
Health,
Social,
and
Economics
Research
Research
Triangle
Park,
NC
27709
*
RTI
International
is
a
trade
name
of
Research
Triangle
Institute.
iii
CONTENTS
Section
Page
Section
1
Introduction
........................................................................................................
1­
1
1.1
Objective
of
this
Analysis
.................................................................................
1­
2
1.2
Organization
of
this
Report
...............................................................................
1­
2
Section
2
Identifying
OSWI
Units
and
Characterizing
their
Owners...................................
2­
1
2.1
Identifying
OSWI
Units
....................................................................................
2­
1
2.2
Identifying
Small
and
Potentially
Small
Entities
Owning
OSWI
Units
..............
2­
2
Section
3
Estimating
Costs
Under
Alternative
Compliance
Options
...................................
3­
1
3.1
Locating
OSWI
Units,
Rural
OSWI,
and
Landfills............................................
3­
1
3.2
Estimating
Costs
for
Compliance
or
Switching
to
Landfilling
...........................
3­
1
3.2.1
Estimating
Landfill
Switching
Costs
(
Option
1)
....................................
3­
2
3.2.2
Estimating
Costs
of
Complying
with
OSWI
Rule
(
Option
2)
.................
3­
2
3.2.3
Identifying
Each
OSWI's
Cost­
Minimizing
Compliance
Option............
3­
3
Section
4
Detailed
Examination
of
Selected
OSWI.............................................................
4­
1
4.1
Summary
of
Interview
Results
..........................................................................
4­
1
4.2
Revision
of
Costs
Based
on
Interview
Results...................................................
4­
5
4.3
Summary
..........................................................................................................
4­
7
Section
5
Conclusions
........................................................................................................
5­
1
References
........................................................................................................................
R­
1
iv
Appendixes
A:
List
of
OSWI
Units..............................................................................................
A­
1
B:
OSWI
Contact
List
..............................................................................................
B­
1
C:
Supporting
Memoranda........................................................................................
C­
1
v
LIST
OF
TABLES
Number
Page
2­
1
Number
of
OSWI
by
Owner
Category.......................................................................
2­
2
2­
2
Ownership
Size
Distribution
of
OSWI
Units..............................................................
2­
3
3­
1
Rural
Landfills
That
May
Be
Eligible
for
Exemption.................................................
3­
1
4­
1
OSWI
Units
to
be
Contacted
to
Assess
Validity
of
Estimated
Impacts
.......................
4­
2
4­
2
Revised
and
Original
Data
and
Cost
Estimates
..........................................................
4­
3
4­
3
Revised
and
Original
Compliance
Option
Costs
and
Cost­
to­
Revenue
Ratio
(
CRR)........................................................................................................................
4­
6
4­
4
Summary
of
Projected
Impacts
..................................................................................
4­
8
1­
1
SECTION
1
INTRODUCTION
On
November
9,
2000,
pursuant
to
the
requirements
of
Section
129
of
the
Clean
Air
Act,

EPA
published
a
notice
announcing
that
the
Administrator
would
promulgate
new
source
performance
standards
(
NSPS)
and
emission
guidelines
for
Other
Solid
Waste
Incinerators
(
OSWIs)
by
November
15,
2005.
Subsequent
to
that
notice,
a
consent
decree
requiring
that
EPA
propose
regulations
for
the
OSWI
source
category
by
November
30,
2004,
and
promulgate
by
November
30,
2005
was
agreed
upon.
On
December
9,
2004,
EPA
published
proposed
rules
setting
standards
for
OSWIs
for
the
following
pollutants:
particulate
matter,
sulfur
dioxide,

hydrogen
chloride,
oxides
of
nitrogen,
carbon
monoxide,
lead,
cadmium,
mercury,
and
dioxins
and
dibenzofurans.

In
the
preamble's
discussion
of
the
economic
impacts
of
the
rule,
EPA
estimated
that
if
all
of
the
affected
units
installed
controls
to
comply
with
the
proposed
standards,
the
cost
would
be
approximately
$
63
million
per
year.
However,
EPA
concluded
that
it
would
be
more
costeffective
for
most
OSWI
units
to
use
an
alternative
waste
disposal
method
(
landfilling)
rather
than
installing
the
controls
necessary
to
comply
with
the
proposed
standards.
EPA
noted
that
the
number
of
OSWI
units
has
declined
in
recent
years
because
of
cheaper
alternative
disposal
methods.
EPA
conducted
an
analysis
of
several
model
units
that
determined
that
switching
from
incineration
to
landfilling
would
actually
result
in
a
cost
savings
for
many
OSWIs.
EPA
stated
that,
because
most
existing
OSWI
units
would
incur
no
additional
cost
by
switching
to
landfilling,
the
economic
impacts
of
the
rule
are
negligible.

On
February
7,
2005,
the
Small
Business
Administration's
Office
of
Advocacy
submitted
comments
on
the
proposed
rule,
stating
its
concern
that
the
basis
for
EPA's
certification
that
the
rule
would
not
have
a
significant
impact
on
a
substantial
number
of
small
entities
(
SISNOSE),
as
required
by
section
605
(
b)
of
the
RFA,
"
ignored
the
proposal's
impact
on
existing
incineration
units
located
in
small
school
districts,
other
small
governmental
jurisdictions,
and
small
organizations."
Specifically,
the
Office
of
Advocacy
expressed
concern
regarding
EPA's
assertion
that
all
affected
units
would
switch
to
landfilling
rather
than
installing
the
required
controls,
incurring
negligible,
if
any,
cost.
The
Office
of
Advocacy
challenged
this
assertion
because
it
did
not
believe
that
EPA
had
sufficient
understanding
of
the
number
of
affected
OSWIs
or
the
number
of
affected
OSWIs
that
are
owned
by
small
entities,
and
because
it
did
not
believe
that
EPA
adequately
determined
the
economic
impacts
on
actual
owners
of
affected
units.
The
Office
of
Advocacy
argued
that
EPA's
cost
estimate
based
on
model
units
(
rather
than
1­
2
actual
units)
and
national
average
costs
(
rather
than
locality­
specific
actual
costs)
did
not
adequately
address
whether
certain
small
entities
may
incur
costs.

1.1
Objective
of
this
Analysis
To
address
the
data
and
methodological
issues
raised
by
SBA
and
other
commenters
to
the
proposed
rule,
EPA's
Office
of
Policy
Economics
and
Innovation
undertook
this
analysis,

directing
RTI,
International
(
RTI)
to
gather
information
on
potential
OSWI
units
currently
operating
and
their
owners,
estimate
their
baseline
operating
costs,
identify
nearby
landfills
to
which
they
may
send
their
waste
if
they
stop
incinerating
it,
and
estimate
the
costs
of
disposing
of
their
waste
by
landfilling
instead
of
incineration.
The
cost
of
continuing
to
operate
the
incinerator
in
compliance
with
the
rule
was
then
estimated,
and
each
OSWI's
compliance
and
landfill
costs
were
compared.
EPA
assumed
that
the
facilities
would
then
choose
to
respond
to
the
rule
using
their
lower­
cost
option
(
complying
with
the
OSWI
rule
and
continuing
to
incinerate
or
shutting
down
the
incinerator
and
sending
the
waste
to
a
landfill).
To
assess
the
magnitude
of
the
impact
on
each
OSWI's
owner,
the
lower
cost
of
compliance
was
compared
with
the
owner's
baseline
revenues.
To
assess
the
validity
of
the
analysis
conducted
using
existing
data,
nine
OSWI
owned
by
small
entities
were
contacted
and
interviewed
to
determine
the
accuracy
of
the
data
and
assumptions.
Based
on
data
gathered
during
these
interviews,

estimated
costs
were
re­
estimated
under
each
compliance
option
for
several
of
the
OSWI,
and
compared
with
the
costs
estimated
using
existing
data.

The
investigation
generally
confirmed
the
conclusions
reached
by
EPA's
analysis
at
proposal.
For
each
OSWI,
the
estimated
cost
of
landfilling
the
waste
was
less
than
the
estimated
cost
of
complying
with
the
rule.
For
the
vast
majority
of
OSWI
units,
landfilling
offered
absolute
cost
savings.
Interviews
with
OSWI
estimated
to
have
high
cost­
to­
revenue
ratios
under
conservative
(
high­
end)
throughput
assumptions
indicated
that
the
analysis
using
existing
data
generally
over­
estimated
throughput
and
thus
over­
estimated
costs.
After
incorporating
interview
results,
no
small
entities
that
own
OSWI
units
are
projected
to
incur
costs
exceeding
one
percent
of
revenues.

1.2
Organization
of
this
Report
The
report
presents
the
results
of
the
analysis
in
the
following
sections.
Section
2
presents
a
characterization
of
existing
OSWI
units
and
their
owners.
Section
3
describes
the
estimated
costs
of
waste
management
alternatives:
complying
with
the
OSWI
rule
and
continuing
to
operate
the
incinerator,
or
of
shutting
down
the
incinerator
and
sending
the
waste
to
a
landfill.
In
addition,
Section
3
describes
estimated
impacts
on
small
entities
owning
OSWI
units.
Section
4
1­
3
assesses
the
validity
of
the
analysis
by
interviewing
9
OSWI
units
owned
by
small
entities.

Section
5
presents
our
conclusions.
Several
appendices
provide
additional
details.
2­
1
SECTION
2
IDENTIFYING
OSWI
UNITS
AND
CHARACTERIZING
THEIR
OWNERS
The
analysis
addressed
the
data
issues
raised
by
SBA
and
other
commenters
to
the
proposed
rule,
by
gathering
additional
information
about
potentially
affected
facilities
and
their
owners.
The
first
step
was
to
compile
an
extensive
list
of
"
candidate"
OSWI
units,
then
narrow
the
list
to
those
believed
to
be
currently
in
operation
and
in­
scope
for
the
rule.

2.1
Identifying
OSWI
Units
A
list
of
potential
OSWI
was
compiled
by
combining
data
from
several
sources:

 
the
OSWI
inventory
compiled
for
the
proposed
rule,

 
an
updated
OSWI
inventory
provided
by
OAQPS,

 
the
National
Emissions
Inventory
Draft
2002
database,

 
permits,

 
comments
on
the
previous
analysis,

 
data
provided
by
EPA
Regions
and
States,
and
 
a
commercially
available
database
of
municipal
waste
facilities
maintained
by
Chartwell,
Inc.

Initially,
the
inventory
included
potential
OSWI
units
identified
through
any
of
the
sources,
resulting
in
a
list
of
approximately
500
potential
OSWI.
Units
were
then
eliminated
if
it
was
learned
that
they
are
not
currently
in
operation,
or
are
not
in
scope
for
the
regulation.
The
major
difference
between
the
inventory
presented
here
and
the
inventory
developed
for
proposal
is
due
to
the
removal
of
units
believed
to
have
ceased
operation.
For
example,
data
from
the
state
of
Illinois
led
us
to
remove
more
than
100
of
the
units
that
had
been
in
earlier
inventories;
the
evidence
that
they
had
shut
down
was
corroborated
by
their
absence
from
the
2002
NEI.
Many
other
potential
OSWI
units
were
identified
as
human
or
animal
crematories
or
other
types
of
combustion
units
not
classified
as
OSWI.
Currently,
the
database
for
this
analysis
contains
173
OSWI
units
believed
to
be
operating
and
in­
scope.
Table
2­
1
shows
the
ownership
distribution
of
these
OSWIs.
2­
2
Table
2­
1.
Number
of
OSWI
by
Owner
Category
Owner
Category
Number
of
OSWI
Federal
27
State
9
County
10
City
12
School
district
48
Commercial
7
Nonprofit
60
Total
173
2.2
Identifying
Small
and
Potentially
Small
Entities
Owning
OSWI
Units
Data
from
a
variety
of
sources
was
used
to
characterize
the
owners
of
the
OSWI
units
as
small
or
not
small.
City
and
county
governments
were
characterized
based
on
data
from
the
Census
of
Governments
(
2002).
School
districts
were
characterized
based
on
data
from
the
National
Center
for
Education
Statistics
(
2005).
Commercial
and
non­
profit
entities
were
characterized
based
on
data
from
publicly
available
sources
such
as
entities'
annual
reports
and
from
Dun
&
Bradstreet's
commercially
available
database.

The
criteria
used
to
define
"
small"
are
those
set
by
the
Regulatory
Flexibility
Act
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA);
the
criteria
differ
for
businesses,
governments,
and
organizations.
Business
definitions
refer
to
the
parent
company
of
any
affected
OSWI.
Small
businesses
are
defined
by
the
Small
Business
Administration
and
published
in
13
CFR
121.201;
the
definitions
are
set
by
NAICS
code
and
generally
depend
on
the
number
of
employees
or
company
annual
receipts.
Small
governmental
jurisdiction
is
the
government
of
a
city,
county,
town,
school
district,
or
special
district
with
a
population
less
than
50,000.
Both
of
these
criteria
are
relatively
clear
and
given
adequate
data,

straightforward
to
apply.
The
definition
of
"
small
organization"
is
"
any
not­
for­
profit
enterprise
which
is
independently
owned
and
operated
and
is
not
dominant
in
its
field"
(
5
USC
601).

Determining
whether
an
organization
is
dominant
is
somewhat
ambiguous.
To
be
conservative,

we
assume
that
all
the
nonprofits
are
potentially
small
(
i.
e.,
not
dominant)
and
initially
treat
all
nonprofits
as
if
they
were
small
entities;
however,
in
subsequent
steps
of
the
analysis
we
use
estimated
cost­
to­
revenue
ratios
to
focus
on
entities
with
potentially
larger
impacts.
2­
3
Table
2­
2
shows
the
number
of
OSWI
owner
entities
of
each
type,
and
the
number
that
are
identified
by
these
criteria
as
small
(
or
assumed
to
be
small,
in
the
case
of
nonprofit
organizations).
The
number
of
OSWI
differ
from
the
number
of
entities
because
a
single
entity
can
own
multiple
OSWI.
Note
that,
because
all
nonprofits
are
treated
as
if
they
are
small,
more
than
60
percent
of
OSWI
are
identified
as
being
potentially
owned
by
small
entities.
Appendix
A
provides
a
listing
of
the
173
OSWI
units
and
indicates
whether
the
owner
is
a
small
entity.

Additional
information
is
shown
in
Appendix
C,
Memorandum
1.

Table
2­
2.
Ownership
Size
Distribution
of
OSWI
Units
Owner
Category
Number
of
OSWI
Number
of
OSWI
Owned
by
Small
or
Potentially
Small
Entitiesa
Number
of
Small
or
Potentially
Small
Entitiesa
Federal
27
0
0
State
9
0
0
County
10
4
4
City
12
10
10
School
district
48
31
27
Commercial
7
3
3
Nonprofita
60
60
48
Total
173
108
92
a
All
nonprofit
organizations
are
treated
as
if
they
are
small.
3­
1
SECTION
3
ESTIMATING
COSTS
UNDER
ALTERNATIVE
COMPLIANCE
OPTIONS
Section
2,
above,
describes
the
identification
and
characterization
of
OSWI
units
that
are
believed
to
be
operating
and
covered
by
the
proposed
rule.
The
list
of
OSWI
units,
along
with
a
file
of
solid
waste
landfills
(
from
the
Chartwell
Atlas
database),
were
submitted
for
GIS
processing
so
they
could
be
mapped
to
the
nearest
two
landfills
using
straightline
distances.
The
GIS
analysis
output
results
file
was
then
combined
with
the
OSWI
and
landfill
databases
to
pull
in
tipping
fees
and
other
relevant
information.

3.1
Locating
OSWI
Units,
Rural
OSWI,
and
Landfills
Each
OSWI
unit
was
geo­
coded
to
establish
its
location.
Once
the
OSWI
were
located,

the
metropolitan
statistical
area
(
MSA)
closest
to
each
OSWI
was
identified.
Seven
Institutional
Waste
Incinerators
(
IWIs)
were
identified
that
met
the
definition
of
a
rural
IWI
by
being
more
than
50
miles
from
the
border
of
a
metropolitan
statistical
area
(
MSA).
These
7
rural
IWIs
are
listed
in
Table
3­
1.
Under
the
provisions
of
the
final
rule,
these
7
rural
IWIs
may
be
able
to
petition
for
exemption.
These
rural
OSWI
were
flagged
in
the
database.

Table
3­
1.
Rural
Landfills
That
May
Be
Eligible
for
Exemption
RTI
ID
Facility
Name
City
State
17
Kirksville
College
of
Osteopathic
Medicine
Kirksville
MO
159
Alpena
Comm
College
Alpena
MI
209
Dartmouth
College
Hanover
NH
274
Jeffers
High
School
Painesdale
MI
290
Laughlin
Air
Force
Base
Del
Rio
TX
420
University
of
Alaska
Fairbanks
AK
432
USAF
Clear
Clear
USA
AK
For
each
OSWI
in
the
database,
the
two
nearest
landfills
in
the
Chartwell
database
were
identified,
and
information
on
their
tipping
fees
was
gathered
from
Chartwell,
Inc.
These
data
are
shown
in
Memorandum
2,
in
Appendix
C.

3.2
Estimating
Costs
for
Compliance
or
Switching
to
Landfilling
For
purposes
of
this
analysis,
it
was
assumed
that
there
are
two
primary
compliance
options.
Option
1
is
to
switch
from
incinerating
waste
to
landfilling.
Option
2
is
to
comply
with
3­
2
the
final
OSWI
rule
and
continue
incinerating.
The
cost
for
both
options
was
calculated,
and
OSWI
owners
are
assumed
to
choose
the
lower
cost
option.

3.2.1
Estimating
Landfill
Switching
Costs
(
Option
1)

First,
the
cost
of
landfilling
waste
currently
being
incinerated
was
estimated
for
each
OSWI,
based
on
actual
throughput
data
where
available,
and
based
on
average
incinerator
capacity
when
actual
throughput
data
was
not
reported.
Missing
data
were
filled
based
on
reported
capacities
and
operating
days.
Separate
statistics
for
Very
Small
Municipal
Waste
Combustors
(
VSMWCs)
and
IWIs
were
developed.
Using
the
units
that
reported
throughput
data,
a
lower­
end
capacity
estimate
was
computed
using
the
10th
percentile
throughput
for
each
class
of
incinerator
(
VSMWCs
and
IWIs),
a
midrange
capacity
estimate
using
the
arithmetic
average
throughput,
and
an
upper­
end
capacity
estimate
using
the
90th
percentile
throughput.

To
compute
transportation
cost
to
the
landfills,
a
hauling
fee
of
$
0.50/
ton/
mile
(
Heimlich,

2005)
was
assumed.
Using
the
throughput
estimates,
reported
tipping
fee
from
the
Chartwell
database,
and
the
estimated
hauling
fee,
the
estimated
disposal
cost
for
the
closest
and
second
closest
landfills
was
calculated.
Landfill
distances
and
tipping
fees
were
based
on
site
specific
data
for
each
OSWI
(
see
Appendix
C,
Memorandum
2,
Table
3).
We
selected
the
lower
of
these
land
disposal
costs
as
the
landfill
cost
(
see
Appendix
C,
Memorandum
3,
Table
4).

EPA
had
estimated
at
proposal
that
landfilling
would
often
represent
absolute
cost
savings
relative
to
baseline
incinerator
costs.
To
test
this
assertion,
baseline
incineration
costs
were
estimated
using
site
specific
incinerator
throughput
data
as
described
above
and
a
regression
of
the
incinerator
operating
costs
that
were
developed
for
the
proposal
(
excluding
capital
recovery
because
this
will
be
incurred
whether
the
incinerator
is
operating
or
not).
For
details
on
the
regression
analysis
and
cost
estimation,
please
refer
to
Appendix
C,
Memorandum
3.

Finally,
net
switching
costs
were
calculated
as
landfill
cost
minus
incinerator
operating
costs.
Negative
switching
costs
indicated
OSWI
for
which
landfilling
represents
an
absolute
cost
savings.

3.2.2
Estimating
Costs
of
Complying
with
OSWI
Rule
(
Option
2)

To
estimate
the
costs
of
complying
with
the
OSWI
rule,
RTI
calculated
compliance
costs
for
each
OSWI
using
a
regression
of
the
OSWI
compliance
costs
that
were
developed
for
the
proposal.
For
details
on
the
regression
analysis
and
cost
estimation,
please
refer
to
Appendix
C,

Memorandum
3.
3­
3
3.2.3
Identifying
Each
OSWI's
Cost­
Minimizing
Compliance
Option
Assuming
that
each
OSWI
would
choose
to
comply
using
its
lowest­
cost
option
(
Option
1:
Switch
to
Landfill
or
Option
2:
Comply
with
OSWI
Rule),
the
estimated
costs
for
each
option
for
each
OSWI
were
compared.
Option
1
(
Landfilling)
was
found
to
be
the
lower
cost
option
for
all
OSWI.
Appendix
C,
Memorandum
3,
Table
4
shows
estimated
baseline
OSWI
operating
costs,
landfilling
costs,
and
compliance
costs
for
each
OSWI
unit.

At
this
stage
in
the
analysis,
using
central
tendency
estimates
of
throughput,
landfilling
is
projected
to
be
less
expensive
than
complying
with
the
rule
for
all
173
OSWI
units,
and
only
12
of
the
173
are
expected
to
incur
positive
costs
by
switching
to
landfilling.
The
remaining
161
are
projected
to
experience
cost
savings.
4­
1
SECTION
4
DETAILED
EXAMINATION
OF
SELECTED
OSWI
The
next
stage
in
the
analysis
is
to
estimate
potential
impacts
on
small
entities
owning
OSWI
units,
and
to
select
a
small
number
of
them
for
interviews
to
assess
the
reliability
of
our
estimated
impacts.
The
severity
of
impacts
on
small
entities
is
usually
measured
in
terms
of
the
ratio
of
costs
of
compliance
to
owner
entity
revenues,
the
cost­
to­
revenue
ratio
or
CRR.

For
all
108
OSWI
owned
by
small
or
potentially
small
entities,
compliance
costs
were
calculated
assuming
(
1)
upper­
end
incinerator
throughput
estimates,
and
(
2)
that
entities
choose
the
cost
minimizing
compliance
option.
CRRs
were
then
calculated
for
each
entity
(
for
entities
owning
more
than
one
OSWI
unit,
costs
were
summed
across
the
units).
The
entities
chosen
for
interviews
were
those
with
the
highest
projected
CRRs
under
these
assumptions.
In
short,
more
detailed
information
was
gathered
for
those
entities
that
might
experience
high
compliance
costs.

For
details
on
these
calculations,
please
see
Appendix
C,
Memorandum
3,
Table
5.

As
a
result
of
this
approach,
nine
entities
were
contacted.
Those
entities
include
all
the
entities
projected
to
experience
CRRs
greater
than
0.5%
assuming
high
incinerator
throughput.

The
nine
entities
include
eight
small
government
jurisdictions
and
one
small
business.
This
analysis
found:

 
Eight
OSWI
units
owned
by
six
nonprofits
have
positive
costs,
but
none
of
the
entities
have
costs
exceeding
0.1
percent
of
revenue.

 
Twelve
OSWI
units
owned
by
12
small
governments
have
positive
costs;
8
have
CRR
of
approximately
1
percent
or
greater.

 
One
OSWI
unit
owned
by
a
small
business
has
a
CRR
greater
than
1
percent.

The
nine
entities
contacted
to
obtain
information
about
actual
OSWI
operations
and
costs
are
shown
in
Table
4­
1,
and
contact
details
are
in
Appendix
B.

Among
these
units,
OSWI
39
(
Seagull
Sanitation
Systems)
is
commercially
owned.
All
the
others
are
owned
by
small
governmental
entities,
including
towns,
counties,
and
a
school
system.
(
OSWI
274
is
an
IWI
owned
by
Jeffers
High
School.)

4.1
Summary
of
Interview
Results
Of
the
nine
facilities
contacted,
three
have
already
shut
their
incinerators
down,
and
six
are
still
operating
their
incinerators.
Of
these
six
facilities,
three
plan
to
shut
their
incinerators
down
eventually
(
before
the
compliance
deadline
for
the
final
OSWI
rule),
one
plans
to
seek
an
4­
2
Table
4­
1.
OSWI
Units
to
be
Contacted
to
Assess
Validity
of
Estimated
Impacts
RTI
ID
OSWI
Name
Cost
Based
on
High­
End
Throughput
($/
year)
Owner
Revenue
($
million/
year)
Estimated
CRR
39
Seagull
Sanitation
Systems
$
167,474
1.75
9.57%

130
Town
of
Readsboro
Incinerator
$
82,601
1.02
8.07%

143
Ossipee
Incinerator
Facility
$
116,922
9.28
1.26%

144
Town
of
Candia
$
123,666
8.64
1.43%

145
Town
of
Litchfield
Incinerator
&
Recycling
Facility
$
410,381
16.3
2.52%

146
Wilton
Recycling
Center
$
533,882
8.23
6.49%

149
Hebron­
Bridgewater
Refuse
District
$
80,108
2.15
3.73%

150
Shelby
County
Community
Services
$
69,174
7.05
0.98%

274
Jeffers
High
School
$
38,801
2.10
1.85%

exemption
to
the
OSWI
rule,
one
plans
to
comply
with
the
OSWI
rule,
and
one
is
currently
undecided
whether
to
comply
or
shut
down.

Those
units
still
in
operation
were
asked
about
actual
waste
throughput,
operating
hours,

and
operating
costs.
Based
on
the
responses,
the
original
estimates
of
daily
waste
throughput
were
substantially
overestimated
(
3
to
6
times),
due
to
the
fact
that
capacity
information
was
used
in
the
original
estimates,
rather
than
actual
throughput,
which
was
unavailable
at
the
time.

The
original
estimates
of
operating
hours
were
mostly
overestimated
(
1
to
8
times);
the
original
estimates
were
based
on
averages
for
the
type
of
OSWI
(
VSMWC
or
IWI),
because
actual
information
on
operating
hours
was
unavailable
at
the
time.
The
information
collected
on
operating
costs
was
somewhat
unclear
and
was
sometimes
provided
for
the
entire
operation,
not
just
the
incinerator.
Operating
costs
for
just
the
incinerator
were
provided
in
only
three
cases;

one
claimed
to
have
practically
zero
cost,
while
the
other
two
had
higher
costs
than
previously
determined,
indicating
the
original
estimates
of
operating
costs
may
have
been
underestimated
(
30
to
40
percent
of
actual
costs).
Table
4­
2
shows
data
used
in
initial
estimates
and
data
collected
during
interviews
for
the
nine
OSWI.

Some
of
the
contacts
were
aware
of
the
OSWI
rule
and
noted
that
they
have
several
years
before
the
rule
is
implemented.
Consequently,
they
had
not
yet
completed
any
cost
estimates
for
either
complying
or
landfilling.
Only
one
of
the
facilities
has
an
add­
on
control
device.
The
incinerator
at
this
facility
is
newly
installed,
with
state­
of­
the­
art
equipment,
wet
scrubber,
and
4­
3
Table
4­
2.
Revised
and
Original
Data
and
Cost
Estimates
RTI
ID
Facility
Name
Road
Distance
(
miles)
Tipping
Fee
($/
ton)
Annual
Quantity
(
tpy)
LF
Disposal
Costs
($/
yr)
Baseline
Incinerator
Operating
Costs
($/
yr)
Compliance
Costs
($/
yr)

39
Seagull
Sanitation
Systems,
Pebbly
Beach
Disposal
Site
Incinerator,

Avalon,
CA
Closed
(
Original
Estimate)
 

(
40.88)
 

($
42.87)
 

(
3,182)
 

($
201,453)
 

($
133,830)
 

($
333,295)

130
Town
of
Readsboro
Incinerator,
Readsboro,

VT
Closed
(
Original
Estimate)
 

(
26.04)
 

($
45.00)
 

(
3,358)
 

($
194,851)
 

($
138,710)
 

($
342,994)

143
Ossipee
Incinerator
Facility,
Ossipee,
NH
Revised
Estimate
(
Original
Estimate)
66.1
(
7.42)
$
67.00
($
55.95)
994.5
(
4,030)
$
99,500
($
240,430)
$
71,453
($
157,194)
$
212,971
($
379,939)

144
Town
of
Candia
Candia,
NH
Revised
Estimate
(
Original
Estimate)
33.4
(
10.08)
$
82.00
($
55.95)
1,170
(
4,030)
$
115,479
($
245,790)
$
76,676
($
157,194)
$
222,625
($
379,939)

145
Town
of
Litchfield
Incinerator
&
Recycling
Facility,
Litchfield,
NH
Revised
Estimate
(
Original
Estimate)
145
(
12.04)
$
107.60
($
80.00)
1,118
(
6,179)
$
201,352
($
531,546)
$
75,135
($
215,549)
$
219,765
($
498,163)

146
Wilton
Recycling
Center
Wilton,
NH
Revised
Estimate
(
Original
Estimate)
60.3
(
8.68)
$
16.67
($
80.00)
832
(
8,060)
$
38,954
($
679,780)
$
66,544
($
265,980)
$
204,033
($
601,609)

149
Hebron­
Bridgewater
Refuse
District,

Bridgewater,
NH
Revised
Estimate
(
Original
Estimate)
50.5
(
18.5)
$
77.91
($
25.90)
637
(
3,869)
$
65,713
($
206,787)
$
60,529
($
152,772)
$
86,526
($
371,072)

150
Shelby
County
Community
Services,

Shelbyville,
IL
Closed
(
Original
Estimate)
 

(
33.6)
 

($
30.00)
 

(
1,560)
 

($
73,008)
 

($
88,072)
 

($
244,077)

274
Jeffers
High
School,

Painesdale,
MI
Revised
Estimate
(
Original
Estimate)
10
(
39.06)
$
60.00
($
54.20)
9.6
(
445)
$
1,415
($
32,784)
$
0
($
54,394)
$
50
($
182,727)
4­
4
continuous
emissions
monitoring
system
(
CEMS).
Another
contact
was
also
unsure
how
they
would
respond,
stating
that
they
have
not
yet
made
a
decision
whether
to
install
emission
controls
and
comply
or
shut
down
and
send
waste
to
a
landfill.
One
contact
expected
to
continue
operating
and
would
apply
for
an
exemption
as
a
rural
IWI,
because
it
is
more
than
50
miles
from
the
border
of
the
nearest
metropolitan
statistical
area
(
MSA).
The
remaining
contacts
still
operating
did
not
believe
they
would
be
able
to
achieve
the
limits
in
the
rule,
and
they
are
planning
to
shut
down
their
incinerators.

In
addition
to
cost
and
compliance
issues,
some
of
the
contacts
cited
encroaching
development,
nuisance
complaints,
and
the
age
of
the
incinerator
as
factors
for
why
they
are
planning
to
shut
down
their
incinerators.

For
those
facilities
that
may
landfill
their
waste
instead
of
incinerate,
contacts
stated
that
they
did
(
or
would)
send
their
waste
to
landfills
different
from
the
ones
identified
as
the
closest
landfills.
Some
of
the
contacts
indicated
they
would
send
the
waste
to
a
transfer
station,
rather
than
directly
to
a
landfill.
Where
contacts
did
provide
landfill
information,
the
landfills
RTI
originally
chose
did
not
match
the
landfills
cited
by
the
contacts;
distances
transported
and
tipping
fees
were
generally
higher
than
originally
assumed.

Information
was
also
requested
from
the
OSWIs
about
the
revenue
for
their
municipality
or
commercial
enterprise.
For
the
municipalities,
the
original
revenue
estimates
obtained
from
Federal
government
sources
were
reported
to
be
overestimated
(
3
to
5
times).
By
contrast,
for
the
only
commercial
enterprise
among
the
nine
contacted,
the
original
revenue
estimate
appeared
to
be
underestimated
(
55
percent
of
actual
revenue).
However,
many
of
the
contacts
were
not
certain
about
the
accuracy
of
their
revenue
estimates,
and
RTI
did
not
contact
additional
staff
for
more
authoritative
estimates.
Because
the
original
revenue
data
came
from
Federal
data
sources
(
Census
of
Governments
and
National
Center
for
Education
Statistics)
and
is
thus
thought
reliable,
RTI
chose
to
continue
to
use
its
original
revenue
estimates.

The
final
question
to
the
contacts
concerned
whether
there
were
other
factors
besides
cost
that
might
influence
their
decision
to
incinerate
vs.
landfill.
Through
a
literature
review,
some
factors
that
might
cause
landfilling
to
be
impracticable
for
some
OSWI
had
been
identified,
such
as
harsh
climate
or
long
distances
to
landfills
that
accept
the
types
of
waste
they
incinerate.
The
contacts
provided
some
additional
examples.
Two
contacts
noted
that
EPA
had
overlooked
the
issue
of
what
to
do
with
the
waste
that
cannot
be
landfilled,
such
as
the
contraband
and
confidential
records
they
receive
from
police
departments,
and
the
materials
they
receive
from
the
Department
of
Fish
&
Game
(
e.
g.,
rabid
animal
remains).
Another
contact
noted
their
very
4­
5
low
incinerator
operating
costs
(
essentially
the
cost
of
a
match)
made
any
other
type
of
disposal
uneconomic
at
present.
A
third
contact
noted
that
there
were
political
considerations:
their
stateof
the­
art
facility
had
been
funded
by
the
citizens
of
their
municipalities,
and
they
did
not
want
to
throw
away
the
substantial
sum
of
money
they
had
already
spent.
Contacts
also
generally
commented
on
the
limited
landfill
space
and
the
cost
to
haul
and
landfill
waste.
For
additional
details,
see
Appendix
C,
Memorandum
4.

4.2
Revision
of
Costs
Based
on
Interview
Results
Based
on
the
information
collected
through
the
telephone
contacts,
new
costs
for
switching
to
landfills
or
complying
with
the
OSWI
rule
requirements
were
developed
for
the
nine
entities
contacted.
These
costs
were
compared
to
the
original
central­
tendency
costs
calculated
for
these
units.
The
results
of
this
analysis
are
summarized
in
Table
4­
3.
The
remainder
of
this
section
provides
a
description
of
the
revised
cost
estimates
generated
for
the
OSWI
units
as
a
result
of
the
telephone
contacts.
For
detailed
information
about
the
interviews,

see
Appendix
C,
Memorandum
5.

Several
key
pieces
of
information
have
a
strong
influence
on
projected
costs,
particularly
incinerator
throughput,
landfill
tipping
fees,
and
the
distance
to
the
landfill.
For
each
of
the
nine
facilities,
actual
throughput
based
on
information
received
from
the
telephone
conversations
was
lower,
sometimes
substantially
so,
than
the
original
central
tendency
estimate
of
throughput.

Landfill
tipping
fees
were
generally
higher
than
originally
estimated,
and
landfill
distances
farther.
Revised
data
are
shown
in
Table
4­
2.

Three
of
the
facilities
that
were
contacted
(
Seagull
Sanitation
Systems,
Town
of
Readsboro,
and
Shelby
County
Community
Services)
indicated
they
are
no
longer
in
operation.

Given
that
their
throughput
is
zero,
it
is
also
assumed
that
their
potential
costs
resulting
from
the
OSWI
rule
are
also
zero.

The
original
throughput
estimate
for
Ossippee
was
projected
to
be
around
4,000
tpy,
but
based
on
the
telephone
contact,
it
appears
that
actual
throughput
is
closer
to
1,000
tpy.
The
landfill
tipping
fee
is
higher
($
67
per
ton
compared
to
an
estimated
$
60)
and
the
landfill
farther
(
66
miles
vs.
7).

Similarly,
the
original
throughput
estimate
for
the
town
of
Candia
was
projected
to
be
approximately
4,000
tpy
but
is
probably
closer
to
1,000
tpy.
The
person
contacted
also
indicated
that
the
landfill
they
use
has
a
higher
tipping
fee
($
82
per
ton,
compared
to
an
original
estimate
of
around
$
60
per
ton)
and
is
farther
away
(
33
miles
vs.
10).
4­
6
Table
4­
3.
Revised
and
Original
Compliance
Option
Costs
and
Cost­
to­
Revenue
Ratio
(
CRR)

RTI
ID
Facility
Name
Option
1 
Shut
Down/
Landfill
($/
yr)
Option
2 

Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Cost­
to­

Revenue
Ratio
CRR>
0.5%?

Yes/
No
39
Seagull
Sanitation
Systems,
Pebbly
Beach
Disposal
Site
Incinerator
Closed
(
Original
Estimate)
 

($
67,623)
 

($
333,295)
 

($
67,623)
 

(
9.57%)
 

(
Yes)

130
Town
of
Readsboro
Incinerator
Closed
(
Original
Estimate)
 

($
56,140)
 

($
342,994)
 

($
56,140)
 

(
8.07%)
 

(
Yes)

143
Ossipee
Incinerator
Facility
Revised
Estimate
(
Original
Estimate)
$
28,047
($
83,236)
$
212,971
($
379,939)
$
28,047
($
83,236)
0.30%

(
1.26%)
No
(
Yes)

144
Town
of
Candia
Revised
Estimate
(
Original
Estimate)
$
38,803
($
88,595)
$
222,625
($
379,939)
$
38,803
($
88,595)
0.45%

(
1.43%)
No
(
Yes)

145
Town
of
Litchfield
Incinerator
&
Recycling
Facility
Revised
Estimate
(
Original
Estimate)
$
126,216
($
315,997)
$
219,765
($
498,163)
$
126,216
($
315,997)
0.78%

(
2.52%)
Yes
(
Yes)

146
Wilton
Recycling
Center
Revised
Estimate
(
Original
Estimate)
 $
27,590
($
413,801)
$
204,033
($
601,609)
 $
27,590
($
413,801)
 
0.34%

(
6.49%)
No
(
Yes)

149
Hebron­
Bridgewater
Refuse
District
Revised
Estimate
(
Original
Estimate)
$
5,184
($
54,015)
$
86,526
($
371,072)
$
5,184
($
54,015)
0.24%

(
3.73%)
No
(
Yes)

150
Shelby
County
Community
Services
Closed
(
Original
Estimate)
 

($
15,088)
 

($
333,295)
 

($
15,088)
 

(
0.98%)
No
(
Yes)

274
Jeffers
High
School
Revised
Estimate
(
Original
Estimate)
$
1,415
( $
21,610)
$
50
($
182,727)
$
50
( $
21,610)
0.002%

(
1.85%)
No
(
Yes)
4­
7
The
town
of
Litchfield
was
projected
to
have
annual
throughput
of
over
6,000
tpy
but
is
currently
operating
at
around
1,000
tpy.
The
landfill
they
would
likely
use
also
has
a
higher
tipping
fee
($
108
per
ton,
compared
to
the
initial
estimate
of
$
80)
and
is
farther
away
(
145
miles
vs.
12).

The
throughput
at
the
Wilton
Recycling
Center
was
projected
to
be
around
8,000
tpy
but
is
actually
around
800
tpy.
The
transfer
station
they
may
use
has
a
lower
tipping
fee
($
17
per
ton
compared
to
$
80)
but
is
farther
away
(
60
miles
compared
to
9).

The
OSWI
unit
in
the
Hebron­
Bridgewater
refuse
district
is
processing
approximately
600
tpy
compared
to
an
original
estimate
of
approximately
3,800
tpy.
The
landfill
that
is
likely
used
has
a
higher
tipping
fee
($
72
per
ton
vs.
$
26)
and
is
farther
away
(
51
miles
vs.
19)
than
originally
thought.

Jeffers
High
School
reported
extremely
low
waste
throughput
(
9.6
tpy
compared
to
the
original
estimate
of
445
tpy).
Their
costs
are
negligible
(
the
cost
of
a
match),
compared
to
our
estimated
costs
of
$
54,400
per
year.
They
plan
to
petition
for
a
rural
OSWI
exemption,
because
they
are
located
more
than
50
miles
from
the
nearest
MSA.

Tables
4­
2
and
4­
3
present
the
revised
costs
for
each
of
the
entities
contacted.
Because
three
of
the
units
are
not
operating,
their
actual
costs
are
zero.
While
some
of
the
elements
of
the
cost
estimation
are
higher
than
we
had
estimated,
costs
are
uniformly
lower
(
generally
much
lower)
because
reported
throughputs
were
much
lower
than
our
estimated
throughputs.
As
a
result,
none
of
the
OSWI
have
CRRs
exceeding
1
percent
based
on
our
revised
estimates.
Only
one
(
145,
Litchfield,
NH)
has
revised
costs
exceeding
0.5
percent
of
revenues.

4.3
Summary
The
analysis
identified
117
entities
that
own
OSWI
believed
to
be
in
operation
and
subject
to
the
rule.
Ninety­
two
of
the
117
are
small
entities
or
are
nonprofit
entities
that
are
assumed
small.
Of
the
117
entities
identified
from
publicly
available
sources,
the
telephone
interviews
determined
that
three
were
no
longer
operating
their
OSWI,
reducing
the
number
of
entities
with
operating
OSWI
to
114,
of
which
89
are
small
or
assumed
small.
Using
central
tendency
throughput
assumptions
and
the
information
obtained
during
the
interviews,
105
entities,
including
83
small
or
assumed
small,
are
projected
to
save
money
by
switching
to
a
landfill.
No
entity,
small
or
otherwise,
is
projected
to
incur
costs
exceeding
one
percent
of
revenues.
Four
entities,
all
small
governments,
are
projected
to
have
CRRs
exceeding
0.1
4­
8
percent.
Only
one
entity
is
projected
to
have
a
CRR
exceeding
0.5
percent.
Table
4­
4
summarizes
these
impacts.

Table
4­
4.
Summary
of
Projected
Impacts
RTI
OSWI
ID
Entity
Type
Small
Entitya
Original
Projection
of
Medium
Throughput
CRR
Revised
Projection
of
Medium
Throughput
CRRb
Original
Projection
of
High
Throughput
CRR
Revised
Projection
of
High
Throughput
CRRb
145
Gov
yes
1.94%
0.78%
2.52%
0.78%

146
Gov
yes
5.03%
6.49%

144
Gov
yes
1.03%
0.45%
1.43%
0.45%

143
Gov
yes
0.90%
0.30%
1.26%
0.30%

149
Gov
yes
2.52%
0.24%
3.73%
0.24%

132
Gov
yes
0.08%
0.08%
0.18%
0.18%

116
Com
no
0.01%
0.01%
0.02%
0.02%

142
Com
no
0.01%
0.01%
0.04%
0.04%

299
Gov
no
0.01%
0.01%
0.01%
0.01%

130
Gov
yes
5.48%
0
8.07%
0
150
Gov
yes
0.21%
0
0.98%
0
39
Com
yes
3.86%
0
9.57%
0
140
Gov
yes
0.41%
0.41%

184
Gov
yes
0.18%
0.18%

439
Gov
no
0.12%
0.12%

274
Gov
yes
0.01%
1.85%
0.01%

120
Gov
no
0.07%
0.07%

483
Gov
yes
0.04%
0.04%

473
NP
yes
0.02%
0.02%

468
Gov
no
0.01%
0.01%

390
NP
yes
0.01%
0.01%

420
NP
yes
0.01%
0.01%

422
NP
yes
0.01%
0.01%

426
NP
yes
0.01%
0.01%

415,416,417c
NP
yes
0.01%
0.01%

Blanks
indicate
projected
cost
savings.

aEntities
that
are
small
or
assumed
to
be
small
(
in
the
case
of
nonprofits).

bCRRs
for
entities
that
were
interviewed
were
revised,
others
were
not
changed.

cThese
three
units
are
owned
by
the
same
entity.
5­
1
SECTION
5
CONCLUSIONS
At
EPA's
direction,
RTI
undertook
an
independent
estimate
of
facility­
specific
costs
of
compliance
and
costs
of
landfilling
for
over
170
OSWI
identified
as
currently
operating
and
in
scope
for
the
rule.
The
objective
of
this
analysis
was
to
address
concerns
raised
by
commenters
on
the
proposed
OSWI
rule,
including
concerns
about
the
accuracy
of
the
profile
of
affected
small
entities,
concerns
about
the
methods
employed
by
EPA
in
analyzing
costs
and
impacts
for
proposal
(
such
as
use
of
national
averages
and
model
plants),
and
concerns
about
the
validity
of
EPA's
assertion
that
costs
for
affected
small
entities
would
be
low,
and
many
affected
entities
would
experience
cost
savings
by
switching
from
incineration
to
landfilling.
This
supplemental
analysis
attempts
to
respond
to
those
concerns
by
focusing
on
actual
units
that
are
operating
and
in
scope,
paying
particular
attention
to
small
businesses,
and
using
site
specific
information
on
throughput
and
costs.

The
cost
estimations
used
current,
publicly
available,
site
specific
data
and
were
based
on
a
regression
of
the
model
facility
costs
from
the
analysis
for
the
proposed
rule.
In
general,
our
estimated
costs
supported
EPA's
assertion
in
the
Preamble
to
the
proposed
OSWI
rule
that
costs
for
OSWI
would
be
low,
and
that
most
owners
would
experience
absolute
cost
savings
by
switching
to
landfilling.
The
analysis
estimated
that
12
OSWI
would
incur
positive
compliance
costs
and
none
are
expected
to
incur
costs
greater
than
1
percent
of
revenue.

To
assess
the
accuracy
of
the
estimated
costs,
and
the
validity
of
the
conclusions,
costs
of
compliance
were
estimated
assuming
high­
end
throughput,
and
the
nine
OSWI
owned
by
small
entities
that
were
estimated
to
have
costs
exceeding
0.5
percent
of
baseline
revenues
were
contacted
for
in­
depth
interviews
about
their
operations
and
expected
response
to
the
rule.
All
other
OSWI
owners,
small
and
otherwise,
were
estimated
to
have
CRRs
less
than
0.5
percent.

The
interviews
revealed
that
three
of
the
nine
had
already
shut
down
operations.
Of
the
remaining
six,
three
more
expect
to
shut
down
prior
to
the
rule's
implementation.
One
other
will
likely
petition
for
a
rural
OSWI
exemption.
Of
the
remaining
two,
one
expects
to
continue
operating
although
it
is
not
sure
it
will
be
able
to
comply
with
the
rule
without
additional
investment.
The
final
OSWI
is
unsure
how
it
will
respond,
as
it
has
not
yet
investigated
its
compliance
options.

For
the
six
OSWI
currently
operating,
information
on
actual
throughput,
landfill
choices,

and
operating
parameters
and
costs
was
collected
during
the
interviews.
Uniformly,
interviews
5­
2
revealed
that
the
estimation
based
on
90th
percentile
throughput
had
overestimated
throughput.

In
addition,
the
contacts
revealed
that
they
did
not
send
their
waste
to
the
nearest
landfill,
as
the
cost
estimation
had
assumed.
While
the
cost
per
ton
of
landfilling
was
sometimes
higher
than
estimated,
because
actual
throughput
was
generally
much
smaller
than
estimated,
revised
costs
were
uniformly
lower
than
originally
estimated.
When
costs
were
re­
estimated
based
on
interview
data,
none
of
the
six
small
entities
with
operating
OSWIs
had
costs
exceeding
one
percent
of
owners'
revenues.
Only
one
has
costs
exceeding
0.5
percent
of
revenues.
Thus,
RTI
concludes
that
EPA's
assessment
at
proposal
that
costs
of
complying
with
the
rule
would
generally
be
relatively
small,
and
that
many
OSWI,
including
most
of
those
owned
by
small
entities,
would
experience
cost
savings
as
a
result
of
the
rule,
is
probably
correct.
R­
1
REFERENCES
Barr,
L.,
and
T.
Holloway,
RTI.
October
4,
2005.
"
OSWI
Inventory
Information
Received
from
EPA
Regions
and
States."
Memorandum
submitted
by
RTI
to
project
file.

Chartwell
Information,
EBI,
Inc.
2004.
The
Directory
&
Atlas
of
Solid
Waste
Disposal
Facilities.
Eighth
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Chartwell
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CAAPP
Permit
Denial.
2003.
"
Robbins
Resource
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Illinois
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Coburn,
J.,
T.
Holloway,
and
K.
Heller.
October
10,
2005.
"
Selection
of
Small
Entities
for
Detailed
Cost
Analysis."
Memorandum
submitted
by
RTI
to
W.
Nickerson,
U.
S.
Environmental
Protection
Agency,
Office
of
Policy,
Economics,
and
Innovation,
through
G.
Kline,
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Dun
&
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Small
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<
http://
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dnb.
com/
default.
asp?
bhcd2=
1127767288>.

Heimlich,
J.
E.
Ohio
State
University,
Fact
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Landfills.
<
http://
ohioline.
osu.
edu/
cdfact
0111.
html>.
Accessed
2005.

Holloway,
T.,
and
J.
Coburn.
October
26,
2005.
"
Additional
Reasons
Why
Landfilling
Infeasible
for
Small
Entities."
Memorandum
submitted
by
RTI
to
W.
Nickerson,
U.
S.
Environmental
Protection
Agency,
Office
of
Policy,
Economics,
and
Innovation,
through
G.
Kline,
ICF.

National
Emissions
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U.
S.
Environmental
Protection
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Office
of
Air
Quality
Planning
and
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<
http://
www.
epa.
gov/
ttn/
chief/
net/
2002inventory.
html>.
Accessed
August 
September
2005.

U.
S.
Department
of
Education.
National
Center
for
Education
Statistics.
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"
Census
2000
School
District
Profiles."
<
http://
nces.
ed.
gov/
surveys/
sdds/
main1.
asp>
and
"
Search
for
Public
School
Districts."
<
http://
nces.
ed.
gov/
ccd/
districtsearch/>.

U.
S.
Department
of
Commerce.
Bureau
of
the
Census.
Census
of
Governments.
2002.
"
County
Governments."
<
http://
www.
census.
gov/
prod/
2005pubs/
gc02x43.
pdf>;
"
Municipal
Governments:
At
or
Above
25,000 
Finances
of
Municipal
and
Township
Governments:
2002."
<
http://
www.
census.
gov/
prod/
2005pubs/
gc024x4.
pdf>;
"
Municipal
Governments:
Below
25,000 
Finances
of
Municipal
and
Township
Governments:
2002."
<
www.
census.
gov/
prod/
2005pubs/
gc024x4.
pdf>;
and
"
Municipal
Governments:
Population
Estimates
for
All
Places,
2002."
<
http://
www.
census.
gov/
popest/
cities/
SUBEST2004
4.
html>.
APPENDIX
A
LIST
OF
OSWI
UNITS
A­
1
Table
A­
1.
List
of
OSWI
Units
RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
1
1
1
Naval
Air
Weapons
Station
China
Lake
CA
IWI
0
0
9
1
1
National
Security
Agency
Fort
Meade
MD
IWI
0
0
10
1
1
National
Security
Agency
Fort
Meade
MD
IWI
0
0
11
1
1
Naval
Surface
Warfare
Cntr 
Indian
HD
Indian
Head
MD
IWI
0
0
12
1
1
Naval
Surface
Warfare
Cntr 
Indian
HD
Indian
Head
MD
IWI
0
0
18
1
1
Malmstrom
AFB
Malmstrom
AFB
MT
IWI
0
0
19
1
1
Los
Alamos
National
Laboratory
Los
Alamos
NM
IWI
0
0
20
1
1
U.
S.
Department
of
the
Army
Hawthorne
NV
IWI
0
0
21
1
1
Tinker
AFB
U.
S.
Air
Force
Logistics
Ctr
Midwest
City
OK
IWI
0
0
23
1
1
U.
S.
Navy:
Weapons
Station
Goose
Creek
SC
IWI
0
0
24
1
1
U.
S.
Airforce:
Charleston
AFB
Charleston
AFB
SC
IWI
0
0
25
1
1
U.
S.
Airforce:
Shaw
AFB
Sumter
SC
IWI
0
0
26
1
1
Main
Base
Hill
Air
Force
Base
UT
IWI
0
0
93
1
1
U.
S.
Army 
Fort
Belvoir
Fort
Belvoir
VA
IWI
0
0
122
1
1
Navy
Salvage
Fuel
Boiler
Plant
Norfolk
VA
VSMWC
0
0
152
1
1
101st
Airborne
Div./
Fort
Campbell
Clarksville
TN
IWI
0
0
153
1
1
88
ABW/
EMP
Wright­
Patterson
AFB
OH
IWI
0
0
290
1
1
Laughlin
Air
Force
Base
Del
Rio
TX
IWI
0
1
322
1
1
Naval
Security
Grp
Activity 
Winter
HBR
Gouldsboro
ME
IWI
0
0
323
1
1
Naval
Security
Grp
Activity 
Winter
HBR
Gouldsboro
ME
IWI
0
0
324
1
1
Naval
Surface
Warfare
Center
Crane
Crane
IN
IWI
0
0
340
1
1
Peterson
AFB
CES
CEV
Peterson
AFB
CO
IWI
0
0
408
1
1
U.
S.
Army
Air
Defense
Art
El
Paso
TX
IWI
0
0
431
1
1
U.
S.
Military
Academy
West
Point
NY
IWI
0
0
432
1
1
USAF
Clear
Clear
USA
AK
IWI
0
1
471
1
1
U.
S.
Department
of
Justice
FBI
Richmond
VA
IWI
0
0
498
1
1
Naval
Security
Group
Activity
Sugar
Grove
WV
IWI
0
0
2
2
2
Calif.
Dept.
of
Food
&
Ag.
Truckee
CA
IWI
0
0
(
continued)
A­
2
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
3
2
2
Calif.
Dept.
of
Food
&
Ag.
Truckee
CA
IWI
0
0
186
2
2
Calif
Correctional
Center
Susanville
CA
IWI
0
0
22
3
2
PA
Dept
of
Corr/
Dallas
Sci
Dallas
PA
IWI
0
0
97
4
7
WIS
DOA/
UW
Madison 
Charter
St
Heating
Plant
Madison
WI
IWI
2
0
98
4
7
WIS
DOA/
UW
Madison 
Charter
St
Heating
Plant
Madison
WI
IWI
2
0
99
4
7
WIS
DOA/
UW
Madison 
Charter
St
Heating
Plant
Madison
WI
IWI
2
0
100
4
7
WIS
DOA/
UW
Madison 
Charter
St
Heating
Plant
Madison
WI
IWI
2
0
101
4
7
University
of
Wisconsin
(
Mad)
Safety
Dept
Madison
WI
IWI
2
0
299
5
2
Louisiana
State
Penitentiary
Angola
LA
IWI
0
0
309
6
2
Maryland
Department
of
Hearth
&
Mental
Hygiene 

Pub
Baltimore
MD
IWI
0
0
325
7
2
NE
Game
&
Parks
Commission
Lincoln
NE
IWI
0
0
439
8
2
Wash
State
Park
&
Recreation
Comm
Olympia
WA
IWI
0
0
499
9
2
WVDEP 
Office
of
Waste
Management
Arthurdale
WV
IWI
0
0
38
10
3
LA
Co.,
Sanitation
Dist
Pomona
CA
VSMWC
0
0
120
11
3
Carter
County
Air
Curtain
Destruction
Elizabethton
TN
VSMWC
0
0
285
12
3
Kalamaoo
Valley
Comm
Co
Kalamaoo
MI
IWI
0
0
293
13
3
Elgin
Community
College
Elgin
IL
IWI
0
0
(
continued)
A­
3
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
470
14
3
Henrico
County
Police
Glen
Allen
VA
IWI
0
0
484
15
3
Mercer
County
Vo­
Tech
Mercer
PA
IWI
0
0
500
16
4
Huntington
Sanitary
Board
Huntington
WV
IWI
0
0
121
17
4
City
of
Alcoa
Incinerator
Friendsville
TN
VSMWC
1
0
129
18
4
City
of
Southside
Place
Incinerator
Southside
Place
TX
VSMWC
1
0
130
19
4
Town
of
Readsboro
Incinerator
Readsboro
VT
VSMWC
1
0
132
20
4
Siloam
Springs
Siloam
Springs
AR
VSMWC
1
0
138
21
4
City
of
Lufkin
Lufkin
TX
VSMWC
1
0
139
22
4
City
of
Norfolk
Waste
Facility
Norfolk
NE
VSMWC
1
0
140
23
4
City
of
Sulphur
Springs
Sulphur
Springs
TX
VSMWC
1
0
143
24
3
Ossipee
Incinerator
Facility
Ossipee
NH
VSMWC
1
0
144
25
4
Town
of
Candia
Candia
NH
VSMWC
1
0
145
26
4
Town
of
Litchfield
Incinerator
&
Recycling
Facility
Litchfield
NH
VSMWC
1
0
146
27
4
Wilton
Recycling
Center
Wilton
NH
VSMWC
1
0
(
continued)
A­
4
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
149
28
3
Hebron
Bridgewater
Refuse
District
Bridgewater
NH
VSMWC
1
0
6
29
5
Grayslake
Community
High
School
127
Grayslake
IL
IWI
1
0
45
30
5
Gross
School 
Dist
95
Brookfield
IL
IWI
1
0
57
31
5
Diekman
School 
District
149
Dolton
IL
IWI
1
0
58
32
5
Berger­
Vandenberg
School
Dolton
IL
IWI
1
0
66
33
5
Marquardt
School 
District
15
Glendale
Heights
IL
IWI
1
0
69
34
5
Jackson
Junior
High
School
Villa
Park
IL
IWI
1
0
72
35
5
Pioneer
School
West
Chicago
IL
IWI
1
0
79
36
5
Triopia
High
School 
District
27
Concord
IL
IWI
1
0
89
37
5
Freeport
School
District
145 
Empire
School
Freeport
IL
IWI
1
0
90
38
5
Carl
Sandburg
School 
District
145
Freeport
IL
IWI
1
0
91
39
5
Rock
Falls
Township
High
School
Rock
Falls
IL
IWI
1
0
165
40
5
Athens
Area
School
District
Athens
Borough
PA
IWI
1
0
184
41
5
Burrell
School
District
Lower
Burrell
City
PA
IWI
1
0
195
42
5
Chatterton
Jr
High
School
Warren
MI
IWI
1
0
(
continued)
A­
5
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
234
117
5
Fitgerald
High
School
Warren
MI
IWI
1
0
437
43
5
Waldron
Area
Schools
Waldron
MI
IWI
1
0
469
43
5
Powhatan
High
School
Powhatan
VA
IWI
1
0
476
44
5
Hollidaysburg
Area
School
District
Holidaysburg
PA
IWI
1
0
477
45
5
Forest
Hills
School
District
(
Ele/
Hi)
Sidman
PA
IWI
1
0
480
45
5
Forest
Hills
School
District
(
Ele)
Sidman
PA
IWI
1
0
479
46
5
Northern
Cambria
School
District
(
Ele/
Mi)
Barnesboro
PA
IWI
1
0
481
47
5
Carmichaels
Area
School
District
Carmichaels
PA
IWI
1
0
482
47
5
Carmichaels
Area
School
District
Carmichaels
PA
IWI
1
0
483
48
5
Purchase
Line
School
District
(
Jr/
Sr/
Ele)
Commodore
PA
IWI
1
0
485
49
5
Trinity
Area
School
District
Washington
PA
IWI
1
0
486
50
5
Burrell
School
District
(
Ele)
Lower
Burrell
PA
IWI
1
0
487
51
5
Hempfield
Area
School
District
(
Sr.
High)
Greenburg
PA
IWI
1
0
488
51
5
Hempfield
Area
School
District
(
Sr.
High)
Greenburg
PA
IWI
1
0
490
52
5
Elizabeth
Forward
School
District 
Middle
School
Incinerator
Elizabeth
PA
IWI
1
0
(
continued)
A­
6
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
491
53
5
Keystone
Oaks
School
District 
High
School
Incinerator
Pittsburgh
PA
IWI
1
0
39
54
6
Seagull
Sanitation
Avalon
CA
VSMWC
1
0
307
55
7
Marian
Manor
Healthcare
Center
Glen
Ullin
ND
IWI
2
0
497
56
6
Grant
County
Nursing
Home
Petersburg
WV
IWI
1
0
61
57
7
Regina
Dominican
High
School
Wilmette
IL
IWI
2
0
63
58
7
Misericordia
School 
North
Chicago
IL
IWI
2
0
379
59
7
St
Clare
De
Montefalco
Parish
Grosse
Pointe
Park
MI
IWI
2
0
381
60
7
St
Gerard
Parish
Detroit
MI
IWI
2
0
460
61
7
Piney
Forest
Healthcare
Danville
Danville
VA
IWI
2
0
489
62
7
Bishop
McCort
High
School
Johnstown
PA
IWI
2
0
492
63
7
North
Catholic
High
School 
Incinerator,
Pyronics
Pittsburgh
PA
IWI
2
0
493
64
7
Sisters
of
the
Holy
Spirit
Pittsburgh
PA
IWI
2
0
494
65
7
St.
Angela
Merici
Parish
McKeesport
PA
IWI
2
0
159
66
7
Alpena
Comm
College
Alpena
MI
IWI
2
1
(
continued)
A­
7
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
274
67
5
Jeffers
High
School
Painesdale
MI
IWI
1
1
17
68
7
Kirksville
College
of
Osteopathic
Medici­
College
Kirksville
MO
IWI
2
1
46
69
5
Goodwin
Elem
School
Cicero
IL
IWI
0
0
48
69
5
Woodbine
School 
District
99
Cicero
IL
IWI
0
0
49
69
5
Sherlock
School
Cicero
IL
IWI
0
0
52
69
5
Drexel
School
District
99
Cicero
IL
IWI
0
0
53
69
5
Columbus
School
District
99
Cicero
IL
IWI
0
0
55
69
5
McKinley
School
Cicero
IL
IWI
0
0
56
69
5
Lincoln
School 
District
99
Cicero
IL
IWI
0
0
501
69
5
Cicero 
East
School 
Dist
99
Cicero
IL
IWI
0
0
81
70
5
Springfield
Public
Schools
District
186
Springfield
IL
IWI
0
0
82
70
5
Springfield
High
School 
District
186
Springfield
IL
IWI
0
0
83
70
5
Washington
Middle
School 
District
186
Springfield
IL
IWI
0
0
84
70
5
Southeast
High
School 
District
186
Springfield
IL
IWI
0
0
85
70
5
Lanphier
High
School 
District
186
Springfield
IL
IWI
0
0
87
70
5
Franklin
Middle
School 
District
186
Springfield
IL
IWI
0
0
65
71
5
Addison
Trail
High
School 
District
88
Addison
IL
IWI
0
0
459
72
5
Concord
Elementary
School
Concord
VA
IWI
0
0
468
73
5
John
M
Gandy
Elementary
School
Ashland
VA
IWI
0
0
116
74
6
Ampacet
Corporation
Deridder
LA
VSMWC
0
0
118
75
6
BFI
Waste
Systems
of
North
America 
Reserve
Reserve
LA
VSMWC
0
0
(
continued)
A­
8
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
495
76
6
Vincentian
Home
Inc.
(
Senior
Residence
Home)
Pittsburgh
PA
IWI
0
0
142
77
6
Environmental
Solutions
LLC
Cannon
Falls
MN
VSMWC
0
0
4
78
7
Univ
Cal,
Riverside
Riverside
CA
IWI
2
0
8
79
7
Kansas
University
Medical
Center
Kansas
City
KS
IWI
2
0
200
80
7
Colorado
State
Univ
Fort
Collins
CO
IWI
2
0
399
81
7
Texas
A
&
M
University
College
Station
TX
IWI
2
0
409
82
7
UC 
Davis
Davis
CA
IWI
2
0
410
83
7
UCSD/
Campus
La
Jolla
CA
IWI
2
0
411
84
7
UCSF/
Parnassus
San
Francisco
CA
IWI
2
0
412
85
7
University
of
NE
Swine
Research
Ithaca
NE
IWI
2
0
414
86
7
University
of
Houston
Houston
TX
IWI
2
0
418
87
7
University
of
Alabama
at
Birmingham
(
Incinerator)
Birmingham
AL
IWI
2
0
419
87
7
University
of
Alabama
at
Birmingham
(
Incinerator)
Birmingham
AL
IWI
2
0
428
88
7
UNL
Manter
Hall
Lincoln
NE
IWI
2
0
436
89
7
VPI
&
State
University
Blacksburg
VA
IWI
2
0
(
continued)
A­
9
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
462
90
7
University
of
Virginia 
Medical
Center
Charlottesville
VA
IWI
2
0
463
90
7
University
of
Virginia 
Medical
Center
Charlottesville
VA
IWI
2
0
464
90
7
University
of
Virginia 
Medical
Center
Charlottesville
VA
IWI
2
0
465
90
7
University
of
Virginia 
Medical
Center
Charlottesville
VA
IWI
2
0
472
91
7
Norfolk
International
Airport
Norfolk
VA
IWI
2
0
42
92
7
Orlando
Sanford
Int'l
Airport
Sanford
FL
VSMWC
2
0
178
93
7
Boston
University
#
2
Boston
MA
IWI
2
0
179
94
7
Boston
University
Engr
&
Sci
Ctr
Boston
MA
IWI
2
0
217
95
7
Duke
University
Heating
Plant
Durham
NC
IWI
2
0
251
96
7
Hampton
University
Hampton
VA
IWI
2
0
302
97
7
M.
I.
T.
Bldg.
#
56
Animal
Care
Facility
Cambridge
MA
IWI
2
0
304
97
7
M.
I.
T.
College
of
Health
Science
Cambridge
MA
IWI
2
0
344
98
7
Purdue
University 
Wade
Utility
Plant
West
Lafayette
IN
IWI
2
0
374
99
7
Southern
Research
Institute
Birmingham
AL
IWI
2
0
375
99
7
Southern
Research
Institute
Birmingham
AL
IWI
2
0
390
100
7
Stanford
University
Palo
Alto
CA
IWI
2
0
415
101
7
University
of
Rochester
(
Strong
Memorial
Hosp.)
Rochester
NY
IWI
2
0
(
continued)
A­
10
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
416
101
7
University
of
Rochester
(
Strong
Memorial
Hosp.)
Rochester
NY
IWI
2
0
417
101
7
University
of
Rochester
(
Strong
Memorial
Hosp.)
Rochester
NY
IWI
2
0
422
102
7
University
of
Idaho,
Holm
Research
Center
Moscow
ID
IWI
2
0
426
103
7
University
of
Maryland 
Medical
School
Teaching
Fac
Baltimore
MD
IWI
2
0
461
104
7
Mary
Washington
College
Fredericksburg
VA
IWI
2
0
467
105
7
Randoph­
Macon
College
Ashland
VA
IWI
2
0
473
106
7
Loudoun
Hospital
Center 
Cornwall
Campus
Leesburg
VA
IWI
2
0
474
107
7
MWAA 
Washington
Dulles
International
Airport
Chantilly
VA
IWI
2
0
475
108
7
Bridgewater
College
Bridgewater
VA
IWI
2
0
496
109
7
Duke
University
Heating
Plant
Durham
NC
IWI
2
0
124
110
3
Smith
Island
Incinerator
Ewell
MD
VSMWC
1
0
134
111
4
City
of
Aurora
Aurora
IL
VSMWC
0
0
150
112
3
Shelby
County
Community
Services
Shelbyville
IL
VSMWC
1
0
391
113
6
Steepmeadow
Club
Inc
Rock
Island
IL
IWI
1
0
424
114
7
University
of
Illinois
Champaign
IL
IWI
2
0
(
continued)
A­
11
Table
A­
1.
List
of
OSWI
Units
(
continued)

RTI_

ID
Owner
ID
Owner
Typea
OSWI
Name
City
State
OSWI
Type
Small
Entityb
>
50mi
MSA
209
115
7
Dartmouth
College
Hanover
NH
IWI
2
1
420
116
7
University
of
Alaska
Fairbanks
AK
IWI
2
1
a
Owner
type
key:
1
=
Federal,
2
=
State,
3
=
County,
4
=
Municipal,
5
=
School
district,
6
=
Commercial,
7
=
Nonprofit.

b
Small
entity
key:
0
=
Not
small,
1
=
Small
entity,
2
=
Nonprofit,
treated
as
small.
APPENDIX
B
OSWI
CONTACT
LIST
B­
1
RTI
ID
39
Seagull
Sanitation
Systems,
Pebbly
Beach
Disposal
Site
Incinerator
1
Dump
Rd,
P.
O.
Box
295
Avalon,
CA
90704
Contact:
Joanne
Long,
Site
Supervisor
(
310)
510­
0675
RTI
ID
130
Town
of
Readsboro
Incinerator
P.
O.
Box
246
Readsboro,
VT
05350
Contact:
Stanley
Russell,
Chairman
of
Board
(
802)
423­
5405
RTI
ID
143
Ossipee
Incinerator
Facility
50
Chickville
Rd
Ossipee,
NH
03864­
6851
Contact:
Ron
Davis,
Supervisor
(
603)
539­
4121
RTI
ID
144
Town
of
Candia
74
High
St
Candia,
NH
03034­
5751
Contact:
Manager
(
603)
483­
2892
RTI
ID
145
Town
of
Litchfield
Incinerator
&
Recycling
Facility
2
Liberty
Way
Litchfield,
NH
03052
Contact:
David
Mellon,
Manager
(
603)
424­
6900
RTI
ID
146
Wilton
Recycling
Center
Route
101,
P.
O.
Box
83
Wilton,
NH
03086
Contact:
Morris
Guay
(
603)
654­
6150
RTI
ID
149
Hebron­
Bridgewater
Refuse
District
297
Mayhew
Turnpike
Bridgewater,
NH
03222
Contact:
Terry
Murphy,
Bridgewater
Selectman
(
603)
744­
5055
Other
Contacts:
Gerry
MacDonald,
Manager;
John
Matthews,
Hebron
Selectman
(
603)
744­
2631;
Hank
Woolner,
Bridgewater
Selectman
(
603)
744­
5055
B­
2
RTI
ID
150
Shelby
County
Community
Services
1810
W
South
3rd
St,
P.
O.
Box
650
Shelbyville,
IL
62565
Contact:
Office
(
217)
774­
5587
RTI
ID
274
Jeffers
High
School
43084
Goodell
St
Painesdale,
MI
49955
Contact:
Office
(
906)
482­
0580
Jan
Maierle,
Principal
Dan
Sternhagen,
Superintendent
APPENDIX
C
SUPPORTING
MEMORANDA
(
Note
that
Memoranda
1
through
4
reflect
facility
information
prior
to
contacting
the
nine
small
entities
with
projected
costs
exceeding
0.5
percent.
Thus,
the
facility
counts
may
differ
from
those
in
Sections
4
and
5
of
the
report,
which
incorporate
interview
information.)
TO:
William
Nickerson,
EPA
THROUGH:
Gayle
Kline,
ICF
FROM:
Katherine
Heller
Tom
Holloway
Leigh
Barr
Alex
Rogozhin
DATE:
August
15,
2005
SUBJECT:
Memorandum
1.
Identification
of
OSWI
Facilities
and
Potential
Small
Entities
Introduction
On
November
9,
2000,
pursuant
to
the
requirements
of
Section
129
of
the
Clean
Air
Act,
EPA
published
a
notice
announcing
that
the
Administrator
would
promulgate
NSPS
standards
for
Other
Solid
Waste
Incinerators
(
OSWIs)
by
November
15,
2005.
On
December
9,
2004,
EPA
published
a
proposed
rule
setting
standards
for
OSWIs
for
the
following
pollutants:
particulate
matter,
sulfur
dioxide,
hydrogen
chloride,
oxides
of
nitrogen,
carbon
monoxide,
lead,
cadmium,
mercury,
and
dioxins
and
dibenzofurans.
The
rule
is
under
court
order
to
be
finalized
by
November
2005.

In
the
preamble's
discussion
of
the
economic
impacts
of
the
rule,
EPA
estimated
that
if
all
of
the
affected
units
installed
controls
to
comply
with
the
proposed
standards,
the
cost
would
be
approximately
$
63
million
per
year.
However,
EPA
concluded
that
it
would
be
more
costeffective
for
most
OSWI
units
to
use
an
alternative
waste
disposal
method
(
landfilling)
rather
than
installing
the
controls
necessary
to
comply
with
the
proposed
standards.
EPA
noted
that
the
number
of
OSWI
units
has
declined
in
recent
years
because
of
cheaper
alternative
disposal
methods.
EPA
conducted
an
analysis
of
several
model
units
that
determined
that
switching
from
incineration
to
landfilling
would
actually
result
in
a
cost
savings
for
many
OSWIs.
EPA
stated
that,
because
most
existing
OSWI
units
would
incur
no
additional
cost
by
switching
to
landfilling,
the
economic
impacts
of
the
rule
are
negligible.

On
February
7,
2005,
the
Small
Business
Administration's
Office
of
Advocacy
submitted
comments
on
the
proposed
rule,
stating
its
concern
that
the
basis
for
EPA's
certification
that
the
rule
would
not
have
a
significant
impact
on
a
substantial
number
of
small
entities
(
SISNOSE),
as
required
by
section
605
(
b)
of
the
RFA,
"
ignored
the
proposal's
impact
on
existing
incineration
units
located
in
small
school
districts,
other
small
governmental
jurisdictions,
and
small
organizations."
Specifically,
the
Office
of
Advocacy
expressed
concern
regarding
EPA's
assertion
that
all
affected
units
would
switch
to
landfilling
rather
than
installing
the
required
controls,
incurring
negligible,
if
any,
cost.
The
Office
of
Advocacy
challenged
this
assertion
because
it
did
not
believe
that
EPA
had
sufficient
understanding
of
the
number
of
affected
OSWIs
or
the
number
of
affected
OSWIs
that
are
owned
by
small
entities,
and
because
it
did
not
Nickerson
Memorandum
1
August
15,
2005
Page
2
believe
that
EPA
adequately
determined
the
economic
impacts
on
actual
owners
of
affected
units.
The
Office
of
Advocacy
argued
that
EPA's
cost
estimate
based
on
model
units
(
rather
than
actual
units)
and
national
average
costs
(
rather
than
locality­
specific
actual
costs)
did
not
adequately
address
whether
certain
small
entities
may
incur
costs.

Identifying
potential
OSWI
units
Our
analysis
addressed
the
data
issues
raised
by
SBA
and
other
commenters
to
the
proposed
rule,
by
gathering
additional
information
about
potentially
affected
facilities
and
their
owners.
RTI
has
compiled
a
list
of
potential
OSWI
by
combining
data
from
several
sources:

 
The
OSWI
inventory
compiled
for
the
proposed
rule,
 
An
updated
OSWI
inventory
provided
by
OAQPS,
 
The
National
Emissions
Inventory
Draft
2002
database,
 
Permits,
 
Comments
on
the
previous
analysis,
 
Data
provided
by
EPA
Regions
and
States,
and
 
A
commercially
available
database
of
municipal
waste
facilities
maintained
by
Chartwell,
Inc.

Initially,
we
included
in
our
inventory
of
potential
OSWI
units
any
unit
identified
through
any
of
the
sources.
We
initially
compiled
a
list
of
approximately
500
potential
OSWI.
We
then
eliminated
units
that
we
have
learned
are
not
currently
in
operation,
or
are
not
in
scope
for
the
regulation.
The
major
difference
between
the
inventory
presented
here
and
the
inventory
developed
for
proposal
results
from
removing
units
no
longer
in
operation.
For
example,
data
from
the
state
of
Illinois
led
us
to
remove
more
than
100
of
the
units
that
had
been
in
earlier
inventories;
the
evidence
that
they
had
shut
down
was
corroborated
by
their
absence
from
the
2002
NEI.
Many
other
potential
OSWI
units
were
identified
as
human
or
animal
crematories
or
other
types
of
combustion
units
not
classified
as
OSWI.
Currently,
the
database
for
this
analysis
contains
173
OSWI
units
believed
to
be
operating
and
in­
scope.
Table
1
shows
the
ownership
distribution
of
these
OSWI.

Identifying
Small
and
Potentially
Small
Entities
Owning
OSWI
Units
We
collected
data
from
a
variety
of
sources
to
characterize
the
owners
of
the
OSWI
units
as
small
or
not
small.
City
and
county
governments
were
characterized
based
on
data
from
the
Census
of
Governments
(
2002).
School
districts
were
characterized
based
on
data
from
the
National
Center
for
Education
Statistics.
Commercial
and
non­
profit
entities
were
characterized
based
on
data
from
publicly
available
sources
and
from
Dun
&
Bradstreet's
commercially
available
database.

The
criteria
used
to
define
"
small"
are
those
set
by
the
Regulatory
Flexibility
Act
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA);
the
criteria
differ
for
Nickerson
Memorandum
1
August
15,
2005
Page
3
businesses,
governments,
and
organizations.
Business
definitions
refer
to
the
parent
company
of
any
affected
OSWI.
Small
businesses
are
defined
by
the
Small
Business
Administration,
published
in
13
CFR
121.201;
the
definitions
are
set
by
NAICS
code
and
generally
depend
on
the
number
of
employees
or
company
annual
receipts.
Small
governmental
jurisdiction
is
the
government
of
a
city,
county,
town,
school
district,
or
special
district
with
a
population
less
than
50,000.
Both
of
these
criteria
are
relatively
clear
and
given
adequate
data,
straightforward
to
apply.
The
definition
of
"
small
organization"
is
"
any
not­
for­
profit
enterprise
which
is
independently
owned
and
operated
and
is
not
dominant
in
its
field."
Determining
whether
an
organization
is
dominant
is
somewhat
ambiguous.
To
be
conservative,
we
assume
that
all
the
nonprofits
are
potentially
small
(
i.
e.,
not
dominant);
however,
in
subsequent
steps
of
the
analysis
we
exclude
entities
with
very
small
cost­
to­
revenue
ratios.

Table
1
shows
the
number
of
OSWI
owner
entities
of
each
type,
and
the
number
that
are
identified
by
these
criteria
as
small
(
or
assumed
to
be
small,
in
the
case
of
nonprofit
organizations).
Note
that,
because
all
nonprofits
are
treated
as
if
they
are
small,
more
than
60
percent
of
OSWI
are
identified
as
being
potentially
owned
by
small
entities.
The
data
on
which
these
determinations
are
based
are
shown
in
Table
2.

Table
1.
Ownership
Size
Distribution
of
OSWI
Units
Owner
Category
Number
of
OSWI
Number
of
OSWI
Owned
by
Small
or
Potentially
Small
Entities
Number
of
Small
or
Potentially
Small
Entities
Federal
27
0
0
State
9
0
0
County
10
4
4
City
12
10
10
School
District
48
31
27
Commercial
7
3
3
Nonprofita
60
60
48
Total
173
108
92
aAll
nonprofit
organizations
are
treated
as
if
they
are
small.

REFERENCES
Barr,
L.
and
T.
Holloway,
RTI.
October
4,
2005.
OSWI
Inventory
Information
Received
from
EPA
Regions
and
States.
Memorandum
submitted
by
RTI
to
project
file.

Chartwell
Information,
EBI,
Inc.
2004.
The
Directory
&
Atlas
of
Solid
Waste
Disposal
Facilities.
Eighth
Edition.
Nickerson
Memorandum
1
August
15,
2005
Page
4
CAAPP
Permit
Denial.
2003.
Robbins
Resource
Recovery
Partners,
LP.
Prepared
by
Illinois
Environmental
Protection
Agency,
Division
of
Air
Pollution
Control.
December
29.

Dun
&
Bradstreet
Small
Business
Solutions.
http://
smallbusiness.
dnb.
com/
default.
asp?
bhcd2=
1127767288
Huckaby,
J.
and
B.
Lange,
Eastern
Research
Group,
Inc.
(
ERG).
2004.
Inventory,
Subcategories,
and
Model
Plants
for
the
Other
Solid
Waste
Incineration
(
OSWI)
Source
Category.
Memorandum
submitted
by
ERG
to
F.
Porter,
M.
Johnson,
and
B.
Shrager,
U.
S.
Environmental
Protection
Agency.
November
23.

Johnson,
M.
2005.
Re:
OSWI
Inventory.
E­
mail
and
attachment
from
Mary
Johnson,
U.
S.
Environmental
Protection
Agency,
to
Thomas
Holloway,
RTI.
August
23.

Johnson,
M.
2005.
Existing
OSWI
Inventory.
E­
mail
and
attachment
from
Mary
Johnson,
U.
S.
Environmental
Protection
Agency,
to
Thomas
Holloway,
RTI.
August
18.

Keuler,
C.
2005.
Docket
ID
No.
OAR­
2003­
0156.
E­
mail
and
attachments
submitted
by
Cindy
Keuler,
Alyeska
Pipeline
Service
Co.,
Environment
Department,
to
Group
A­
and­
RDocket
EPA.
Sent
on
behalf
of
Carl
Rutz,
Environmental
Manager,
Alyeska
Pipeline
Service
Company.
February
7.

Montana
Air
Quality
Operating
Permit.
2004.
U.
S.
Department
of
the
Air
Force,
Malmstrom
Air
Force
Base,
Montana.
Prepared
by
Montana
Department
of
Environmental
Quality,
Permitting
and
Compliance
Division.
December
11.

National
Emissions
Inventory.
Draft
2002.
U.
S.
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards.
Available
at
http://
www.
epa.
gov/
ttn/
chief/
net/
2002inventory.
html.
Accessed
August­
September
2005.

U.
S.
Census
Bureau.
"
2002
Census
of
Governments."
<
http://
www.
census.
gov/
govs/
www/
cog2002.
html>.
Accessed
2005.

U.
S.
Department
of
Education.
National
Center
for
Education
Statistics.

Census
2000
School
District
Profiles.
http://
nces.
ed.
gov/
surveys/
sdds/
main1.
asp
Search
for
Public
School
Districts.
http://
nces.
ed.
gov/
ccd/
districtsearch/

U.
S.
Department
of
Commerce.
Bureau
of
the
Census.
Census
of
Governments.
2002.

County
Governments
<
http://
www.
census.
gov/
prod/
2005pubs/
gc02x43.
pdf>
Nickerson
Memorandum
1
August
15,
2005
Page
5
Municipal
Governments:
At
or
Above
25,000
 
Finances
of
Municipal
and
Township
Governments:
2002
<
http://
www.
census.
gov/
prod/
2005pubs/
gc024x4.
pdf>
Below
25,000
­
Finances
of
Municipal
and
Township
Governments:
2002
<
www.
census.
gov/
prod/
2005pubs/
gc024x4.
pdf>
and
Population
Estimates
for
All
Places
2002
http://
www.
census.
gov/
popest/
cities/
SUB­
EST2004­
4.
html
Nickerson
Memorandum
1
August
15,
2005
Page
6
turning
knowledge
into
practice
Table
2.
Characterization
of
OSWI
Owners
Government
Commercial
RTI
ID
Owner
Entity
OSWI
Type
Facility
Name
Ownership
Flag
a
Population
Served
(
in
2000)
Revenue
($
Million)
Annual
Expenditure
($
Million)
Sales
($
million)
Employment
Small,
all
nonprofits
included
1
1
IWI
NAVAL
AIR
WEAPONS
STATION
1
296,800,000
$
1,853,000.2
0
9
1
IWI
NATIONAL
SECURITY
AGENCY
1
296,800,000
$
1,853,000.2
0
10
1
IWI
NATIONAL
SECURITY
AGENCY
1
296,800,000
$
1,853,000.2
0
11
1
IWI
NAVAL
SURFACE
WARFARE
CNTR­
INDIAN
HD
1
296,800,000
$
1,853,000.2
0
12
1
IWI
NAVAL
SURFACE
WARFARE
CNTR­
INDIAN
HD
1
296,800,000
$
1,853,000.2
0
18
1
IWI
MALMSTROM
AFB
1
296,800,000
$
1,853,000.2
0
19
1
IWI
LOS
ALAMOS
NATIONAL
LABORATORY
1
296,800,000
$
1,853,000.2
0
20
1
IWI
US
DEPARTMENT
OF
THE
ARMY
1
296,800,000
$
1,853,000.2
0
21
1
IWI
TINKER
AFB
US
AIR
FORCE
LOGISTICS
CTR
1
296,800,000
$
1,853,000.2
0
23
1
IWI
US
NAVY:
WEAPONS
STATION
1
296,800,000
$
1,853,000.2
0
24
1
IWI
US
AIRFORCE:
CHARLESTON
AFB
1
296,800,000
$
1,853,000.2
0
25
1
IWI
US
AIRFORCE:
SHAW
AFB
1
296,800,000
$
1,853,000.2
0
26
1
IWI
MAIN
BASE
1
296,800,000
$
1,853,000.2
0
93
1
IWI
US
ARMY
­
FORT
BELVOIR
1
296,800,000
$
1,853,000.2
0
122
1
VSMWC
NAVY
SALVAGE
FUEL
BOILER
PLANT
1
296,800,000
$
1,853,000.2
0
152
1
IWI
101ST
AIRBORNE
DIV./
FORT
CAMPBELL
1
296,800,000
$
1,853,000.2
0
153
1
IWI
88
ABW/
EMP
1
296,800,000
$
1,853,000.2
0
322
1
IWI
NAVAL
SECURITY
GRP
ACTIVITY­
WINTER
HBR
1
296,800,000
$
1,853,000.2
0
323
1
IWI
NAVAL
SECURITY
GRP
ACTIVITY­
WINTER
HBR
1
296,800,000
$
1,853,000.2
0
324
1
IWI
NAVAL
SURFACE
WARFARE
CENTER
CRANE
1
296,800,000
$
1,853,000.2
0
340
1
IWI
PETERSON
AFB
21CES
CEV
1
296,800,000
$
1,853,000.2
0
408
1
IWI
U.
S.
ARMY
AIR
DEFENSE
ART
1
296,800,000
$
1,853,000.2
0
431
1
IWI
US
MILITARY
ACADEMY
1
296,800,000
$
1,853,000.2
0
471
1
IWI
US
DEPARTMENT
OF
JUSTICE
FBI
1
296,800,000
$
1,853,000.2
0
(
continued)
Nickerson
Memorandum
1
August
15,
2005
Page
7
turning
knowledge
into
practice
Table
2.
Characterization
of
OSWI
Owners
(
continued)
Government
Commercial
RTI
ID
Owner
Entity
OSWI
Type
Facility
Name
Ownership
Flag
a
Population
Served
(
in
2000)
Revenue
($
Million)
Annual
Expenditure
($
Million)
Sales
($
million)
Employment
Small,
all
nonprofit
s
included
498
1
IWI
NAVAL
SECURITY
GROUP
ACTIVITY
1
296,800,000
$
1,853,000.2
0
290
1
IWI
LAUGHLIN
AIR
FORCE
BASE
1
296,800,000
$
1,853,000.2
0
432
1
IWI
USAF
CLEAR
1
296,800,000
$
1,853,000.2
0
2
2
IWI
CALIF.
DEPT.
OF
FOOD
&
AG.
2
33,872,000
$
151,245.4
0
3
2
IWI
CALIF.
DEPT.
OF
FOOD
&
AG.
2
33,872,000
$
151,245.4
0
22
3
IWI
PA
DEPT
OF
CORR/
DALLAS
SCI
2
12,286,268
$
46.2
0
186
2
IWI
CALIF
CORRECTIONAL
CENTER
2
33,872,000
$
151,245.4
0
299
5
IWI
LOUISIANA
STATE
PENITENTIARY
2
4,469,635
$
18,078.5
0
309
6
IWI
MARYLAND
DEPARTMENT
OF
HEALTH
&

MENTAL
HYGIENE­
PUB
2
5,311,508
$
20,787.9
0
325
7
IWI
NE
GAME
&
PARKS
COMMISSION
2
1,713,239
$
6,001.9
0
439
8
IWI
WASH
STATE
PARK
&
RECREATION
COMM
2
6,067,000
$
23.8
0
499
9
IWI
WVDEP­
OFFICE
OF
WASTE
MANAGEMENT
2
1,807,436
$
9,130.2
0
38
10
VSMWC
LA
CO.,
SANITATION
DIST
3
9,519,338
$
14,788.2
0
120
11
VSMWC
CARTER
COUNTY
AIR
CURTAIN
DESTRUCTION
3
56,742
$
50.3
0
285
12
IWI
KALAMAZOO
VALLEY
COMM
CO
3
238,603
$
128.2
0
293
13
IWI
ELGIN
CUMMUNITY
COLLEGE
3
404,119
$
162.0
0
470
14
IWI
HENRICO
COUNTY
POLICE
3
262,300
$
694.6
0
484
15
IWI
MERCER
COUNTY
VO­
TECH
3
120,293
$
47.2
0
124
110
VSMWC
SMITH
ISLAND
INCINERATOR
3
27,327
$
52.0
1
143
24
VSMWC
OSSIPEE
INCINERATOR
FACILITY
3
4,232
$
9.3
1
149
28
VSMWC
HEBRON
BRIDGEWATER
REFUSE
DISTRICT
3
979
$
2.1
1
150
112
VSMWC
SHELBY
COUNTY
COMMUNITY
SERVICES
3
22,893
$
7.0
1
500
16
IWI
HUNTINGTON
SANITARY
BOARD
4
51,475
$
50.2
0
134
111
VSMWC
CITY
OF
AURORA
4
142,990
$
183.9
0
(
continued)
Nickerson
Memorandum
1
August
15,
2005
Page
8
turning
knowledge
into
practice
Table
2.
Characterization
of
OSWI
Owners
(
continue)
Government
Commercial
RTI
ID
Owner
Entity
OSWI
Type
Facility
Name
Ownership
Flag
a
Population
Served
(
in
2000)
Revenue
($
Million)
Annual
Expenditure
($
Million)
Sales
($
million)
Employment
Small,
all
nonprofits
included
121
17
VSMWC
CITY
OF
ALCOA
INCINERATOR
4
7,898
$
18.2
1
129
18
VSMWC
CITY
OF
SOUTHSIDE
PLACE
INCINERATOR
4
1,552
$
1.3
1
130
19
VSMWC
TOWN
OF
READSBORO
INCINERATOR
4
804
$
1.0
1
132
20
VSMWC
SILOAM
SPRINGS
4
10,935
$
15.9
1
138
21
VSMWC
CITY
OF
LUFKIN
4
32,709
$
41.0
1
139
22
VSMWC
CITY
OF
NORFOLK
WASTE
FACILITY
4
23,488
$
35.1
1
140
23
VSMWC
CITY
OF
SULPHUR
SPRINGS
4
14,570
$
14.2
1
144
25
VSMWC
TOWN
OF
CANDIA
4
3,939
$
8.6
1
145
26
VSMWC
TOWN
OF
LITCHFIELD
INCINERATOR
&

RECYCLING
FACILITY
4
7,423
$
16.3
1
146
27
VSMWC
WILTON
RECYCLING
CENTER
4
3,753
$
8.2
1
46
69
IWI
GOODWIN
ELEM
SCHOOL
5
86,096
$
36.8
0
48
69
IWI
WOODBINE
SCHOOL­
DISTRICT
99
5
86,096
$
36.8
0
49
69
IWI
SHERLOCK
SCHOOL
5
86,096
$
36.8
0
52
69
IWI
DREXEL
SCHOOL
DISTRICT
99
5
86,096
$
36.8
0
53
69
IWI
COLUMBUS
SCHOOL
DISTRICT
99
5
86,096
$
36.8
0
55
69
IWI
MCKINLEY
SCHOOL
5
86,096
$
36.8
0
56
69
IWI
LINCOLN
SCHOOL
­
DISTRICT
99
5
86,096
$
36.8
0
65
71
IWI
ADDISON
TRAIL
HIGH
SCHOOL­
DISTRICT
88
5
83,148
$
20.9
0
81
70
IWI
SPRINGFIELD
PUBLIC
SCHOOLS
DISTRICT
186
5
118,454
$
60.1
0
82
70
IWI
SPRINGFIELD
HIGH
SCHOOL
­
DISTRICT
186
5
118,454
$
60.1
0
83
70
IWI
WASHINGTON
MIDDLE
SCHOOL
­
DISTRICT
186
5
118,454
$
60.1
0
84
70
IWI
SOUTHEAST
HIGH
SCHOOL
­
DISTRICT
186
5
118,454
$
60.1
0
85
70
IWI
LANPHIER
HIGH
SCHOOL
­
DISTRICT
186
5
118,454
$
60.1
0
87
70
IWI
FRANKLIN
MIDDLE
SCHOOL
­
DISTRICT
186
5
118,454
$
60.1
0
459
72
IWI
CONCORD
ELEMENTARY
SCHOOL
5
51,078
$
30.1
0
(
continued)
Nickerson
Memorandum
1
August
15,
2005
Page
9
turning
knowledge
into
practice
Table
2.
Characterization
of
OSWI
Owners
(
continued)
Government
Commercial
RTI
ID
Owner
Entity
OSWI
Type
Facility
Name
Ownership
Flag
a
Population
Served
(
in
2000)
Revenue
($
Million)
Annual
Expenditure
($
Million)
Sales
($
million)
Employment
Small,
all
nonprofits
included
468
73
IWI
JOHN
M
GANDY
ELEMENTARY
SCHOOL
5
86,320
$
60.7
0
501
69
IWI
CICERO­
EAST
SCHOOL­
DIST
99
5
86,096
$
36.8
0
6
29
IWI
GRAYSLAKE
COMMUNITY
HIGH
SCHOOL
127
5
35,065
$
6.1
1
45
30
IWI
GROSS
SCHOOL­
DIST
95
5
10,930
$
3.2
1
57
31
IWI
DIEKMAN
SCHOOL
­
DISTRICT
149
5
31,001
$
12.2
1
58
32
IWI
BERGER­
VANDENBERG
SCHOOL
5
31,001
$
12.2
1
66
33
IWI
MARQUARDT
SCHOOL­
DISTRICT
15
5
24,839
$
10.7
1
69
34
IWI
JACKSON
JUNIOR
HIGH
SCHOOL
5
37,838
$
17.3
1
72
35
IWI
PIONEER
SCHOOL
5
29,744
$
16.0
1
79
36
IWI
TRIOPIA
HIGH
SCHOOL
­
DISTRICT
27
5
2,514
$
1.9
1
89
37
IWI
FREEPORT
SCHOOL
DISTRICT
145
­
EMPIRE
SCHOOL
5
31,705
$
17.0
1
90
38
IWI
CARL
SANDBURG
SCHOOL
­
DISTRICT
145
5
31,705
$
17.0
1
91
39
IWI
ROCK
FALLS
TOWNSHIP
HIGH
SCHOOL
5
15,074
$
3.5
1
165
40
IWI
ATHENS
AREA
SCHOOL
DISTRICT
5
14,633
$
12.3
1
184
41
IWI
BURRELL
SCHOOL
DISTRICT
5
14,848
$
8.9
1
195
42
IWI
CHATTERTON
JR
HIGH
SCHOOL
5
17,748
$
13.3
1
234
117
IWI
FITZGERALD
HIGH
SCHOOL
5
17,748
$
13.3
1
437
43
IWI
WALDRON
AREA
SCHOOLS
5
2,319
$
1.8
1
469
43
IWI
POWHATAN
HIGH
SCHOOL
5
22,377
$
13.8
1
476
44
IWI
HOLIDAYSBURG
AREA
SCHOOL
DISTRICT
5
27,238
$
18.2
1
477
45
IWI
FOREST
HILLS
SCHOOL
DISTRICT
(
HI)
HIGH
SCHOOL
5
13,606
$
9.2
1
479
46
IWI
NORTHERN
CAMBRIA
SCHOOL
DISTRICT
(
ELE/
MI)
5
8,572
$
6.1
1
480
45
IWI
FOREST
HILLS
SCHOOL
DISTRICT
(
ELE)
5
13,606
$
9.2
1
481
47
IWI
CARMICHAELS
AREA
SCHOOL
DISTRICT
5
7,120
$
5.5
1
482
47
IWI
CARMICHAELS
AREA
SCHOOL
DISTRICT
5
7,120
$
5.5
1
Nickerson
Memorandum
1
August
15,
2005
Page
10
turning
knowledge
into
practice
Table
2.
Characterization
of
OSWI
Owners
(
continued)
Government
Commercial
RTI
ID
Owner
Entity
OSWI
Type
Facility
Name
Ownership
Flag
a
Population
Served
(
in
2000)
Revenue
($
Million)
Annual
Expenditure
($
Million)
Sales
($
million)
Employment
Small,
all
nonprofits
included
483
48
IWI
PURCHASE
LINE
SCHOOL
DISTRICT
(
JR/
SR/
ELE)
5
7,687
$
6.1
1
485
49
IWI
TRINITY
AREA
SCHOOL
DISTRICT
5
25,591
$
18.0
1
486
50
IWI
BURRELL
SCHOOL
DISTRICT
(
ELE)
5
14,848
$
8.9
1
487
51
IWI
HEMPFIELD
AREA
SCHOOL
DISTRICT
(
SR.

HIGH)
5
48,464
$
32.1
1
488
51
IWI
HEMPFIELD
AREA
SCHOOL
DISTRICT
(
SR.

HIGH)
5
48,464
$
32.1
1
490
52
IWI
ELIZABETH
FORWARD
SCHOOL
DISTRICT
­

MIDDLE
SCHOOL
INCINERATOR
5
19,219
$
13.2
1
491
53
IWI
KEYSTONE
OAKS
SCHOOL
DISTRICT
­
HIGH
SCHOOL
INCINERATOR
5
22,172
$
14.4
1
274
67
IWI
JEFFERS
HIGH
SCHOOL
5
2,927
2.1
1
116
74
VSMWC
AMPACET
CORPORATION
6
$
609
1,400
0
118
75
VSMWC
BFI
WASTE
SYSTEMS
OF
NORTH
AMERICA
­

RESERVE
6
$
5,362
2,600
0
495
76
IWI
VINCENTIAN
HOME
INC.
(
SENIOR
RESIDENCE
HOME)
6
$
13
300
0
142
77
VSMWC
ENVIRONMENTAL
SOLUTIONS
LLC
6
$
516
3,496
0
39
54
VSMWC
SEAGULL
SANITATION
6
$
2
10
1
497
56
IWI
GRANT
COUNTY
NURSING
HOME
6
$
3
156
1
391
113
IWI
STEEPMEADOW
CLUB
INC
6
$
0.08
4
1
97
4
IWI
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
7
5,364,000
$
1,905.8
1
98
4
IWI
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
7
5,364,000
$
1,905.8
1
99
4
IWI
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
7
5,364,000
$
1,905.8
1
100
4
IWI
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
7
5,364,000
$
1,905.8
1
(
continued)
Nickerson
Memorandum
1
August
15,
2005
Page
11
turning
knowledge
into
practice
Table
2.
Characterization
of
OSWI
Owners
(
continued)
Government
Commercial
RTI
ID
Owner
Entity
OSWI
Type
Facility
Name
Ownership
Flag
a
Population
Served
(
in
2000)
Revenue
($
Million)
Annual
Expenditure
($
Million)
Sales
($
million)
Employment
Small,
all
nonprofits
included
101
4
IWI
UNIVERSITY
OF
WISCONSIN
(
MAD)
SAFETY
DEPT
7
5,364,000
$
1,905.8
1
307
55
IWI
MARIAN
MANOR
HEALTHCARE
CENTER
7
$
2
150
1
4
78
IWI
UNIV
CAL,
RIVERSIDE
7
33,872,000
$
15,121.0
1
8
79
IWI
KANSAS
UNIVERSITY
MEDICAL
CENTER
7
2,688,000
$
529.6
1
200
80
IWI
COLORADO
STATE
UNIV
7
4,327,020
$
562.9
1
399
81
IWI
TEXAS
A
&
M
UNIVERSITY
7
20,949,136
$
394.1
1
409
82
IWI
UC­
DAVIS
7
33,872,000
$
15,121.0
1
410
83
IWI
UCSD/
CAMPUS
7
33,872,000
$
15,121.0
1
411
84
IWI
UCSF/
PARNASSUS
7
33,872,000
$
15,121.0
1
412
85
IWI
UNIVERSITY
OF
NE
SWINE
RESEARCH
7
1,713,239
$
1,336.3
1
414
86
IWI
UNIVERSITY
0F
HOUSTON
7
20,949,136
$
398.0
1
418
87
IWI
UNIVERSITY
OF
ALABAMA
AT
BIRMINGHAM
(
INCINERATOR)
7
4,452,307
$
461.9
1
419
87
IWI
UNIVERSITY
OF
ALABAMA
AT
BIRMINGHAM
(
INCINERATOR)
7
4,452,307
$
461.9
1
428
88
IWI
UNL
MANTER
HALL
7
1,713,239
$
1,336.3
1
436
89
IWI
VPI
&
STATE
UNIVERSITY
7
7,104,033
$
564.6
1
462
90
IWI
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
7
7,104,033
$
564.6
1
463
90
IWI
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
7
7,104,033
$
564.6
1
464
90
IWI
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
7
7,104,033
$
564.6
1
465
90
IWI
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
7
7,104,033
$
564.6
1
472
91
IWI
NORFOLK
INTERNATIONAL
AIRPORT
7
7,104,033
$
564.6
1
42
92
VSMWC
ORLANDO
SANFORD
INT'L
AIRPORT
7
38,000
$
242.6
650
1
61
57
IWI
REGINA
DOMINICAN
HIGH
SCHOOL
7
1
63
58
IWI
MISERICORDIA
SCHOOL
­
NORTH
7
1
Nickerson
Memorandum
1
August
15,
2005
Page
12
turning
knowledge
into
practice
Table
2.
Characterization
of
OSWI
Owners
(
continued)
Government
Commercial
RTI
ID
Owner
Entity
OSWI
Type
Facility
Name
Ownership
Flag
a
Population
Served
(
in
2000)
Revenue
($
Million)
Annual
Expenditure
($
Million)
Sales
($
million)
Employment
Small,
all
nonprofits
included
178
93
IWI
BOSTON
UNIVERSITY
#
2
7
$
1,128.9
10400
1
179
94
IWI
BOSTON
UNIVERSITY
ENGR
&
SCI
CTR
7
$
1,128.9
10400
1
217
95
IWI
DUKE
UNIVERSITY
HEATING
PLANT
7
$
2,408
26,000
1
251
96
IWI
HAMPTON
UNIVERSITY
7
$
171.0
1,050
1
302
97
IWI
M.
I.
T.
BLDG.
#
56
ANIMAL
CARE
FACILITY
7
$
1,832.3
7850
1
304
97
IWI
M.
I.
T.
COLLEGE
OF
HEALTH
SCIENCE
7
$
1,832.3
7850
1
344
98
IWI
PURDUE
UNIVERSITY­
WADE
UTILITY
PLANT
7
$
688.8
1
374
99
IWI
SOUTHERN
RESEARCH
INSTITUTE
7
$
75.1
605
1
375
99
IWI
SOUTHERN
RESEARCH
INSTITUTE
7
$
75.1
605
1
379
59
IWI
ST
CLARE
DE
MONTEFALCO
PARISH
7
$
2.1
84
1
381
60
IWI
ST
GERARD
PARISH
7
$
165
1
390
100
IWI
STANFORD
UNIVERSITY
7
$
3,743.9
15000
1
415
101
IWI
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
7
$
1,808.9
13000
1
416
101
IWI
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
7
$
1,808.9
13000
1
417
101
IWI
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
7
$
1,808.9
13000
1
422
102
IWI
UNIVERSITY
OF
IDAHO,
HOLM
RESEARCH
CENTER
7
$
160.9
1
426
103
IWI
UNIVERSITY
OF
MARYLAND­
MEDICAL
SCHOOL
TEACHING
FAC
7
$
1,160.0
1
460
61
IWI
PINEY
FOREST
HEALTHCARE
DANVILLE
7
$
9.3
180
1
461
104
IWI
MARY
WASHINGTON
COLLEGE
7
$
37.1
700
1
467
105
IWI
RANDOPH­
MACON
COLLEGE
7
$
29.7
295
1
473
106
IWI
LOUDOUN
HOSPITAL
CENTER
­
CORNWALL
CAMPUS
7
$
46.0
1000
1
474
107
IWI
MWAA
­
WASHINGTON
DULLES
INTERNATIONAL
AIRPORT
7
$
442.2
1187
1
(
continued)
Nickerson
Memorandum
1
August
15,
2005
Page
13
turning
knowledge
into
practice
Table
2.
Characterization
of
OSWI
Owners
(
continued)
Government
Commercial
RTI
ID
Owner
Entity
OSWI
Type
Facility
Name
Ownership
Flag
a
Population
Served
(
in
2000)
Revenue
($
Million)
Annual
Expenditure
($
Million)
Sales
($
million)
Employment
Small,
all
nonprofits
included
475
108
IWI
BRIDGEWATER
COLLEGE
7
$
25.3
270
1
489
62
IWI
BISHOP
MCCORT
HIGH
SCHOOL
7
1
492
63
IWI
NORTH
CATHOLIC
HIGH
SCHOOL
­

INCINERATOR,
PYRONICS
7
1
493
64
IWI
SISTERS
OF
THE
HOLY
SPIRIT
7
$
1.2
42
1
494
65
IWI
ST.
ANGELA
MERICI
PARISH
7
$
0.2
6
1
496
109
IWI
DUKE
UNIVERSITY
HEATING
PLANT
7
$
2,408
26,000
1
159
66
IWI
ALPENA
COMM
COLLEGE
7
$
42.0
1
17
68
IWI
KIRKSVILLE
COLLEGE
OF
OSTEOPATHIC
MEDICI­
COLLEGE
7
1
424
114
IWI
UNIVERSITY
OF
ILLINOIS
7
$
2,406
26,000
1
209
115
IWI
DARTMOUTH
COLLEGE
7
$
569
5,000
1
420
116
IWI
UNIVERSITY
OF
ALASKA
7
$
323
6,629
1
TO:
William
Nickerson,
EPA
THROUGH:
Gayle
Kline,
ICF
FROM:
Jeff
Coburn
Jamie
Cajka
Katherine
Heller
DATE:
August
30,
2005
SUBJECT:
Memorandum
2.
Location
of
Small
Entities
and
Possible
Landfill
Alternatives
Purpose
The
purpose
of
this
memorandum
is
to
document
the
results
of
the
GIS
analysis.
The
GIS
analysis
was
used
to
identify
rural
institutional
waste
incinerators
(
IWI)
and
to
identify
the
nearest
landfills
for
each
other
solid
waste
incinerator
(
OSWI)
unit.

Approach
to
Locating
Small
OSWI
and
Landfills
As
described
in
an
earlier
Memorandum,
RTI
compiled
a
list
of
potential
OSWI
units
that
are
believed
to
be
operating
and
covered
by
the
proposed
rule.
The
list
of
OSWI
units,
along
with
a
file
of
solid
waste
landfills
(
from
the
Chartwell
Atlas
database),
were
submitted
for
GIS
processing
so
they
could
be
mapped
to
the
nearest
two
landfills
using
straightline
distances.
Attachment
1
provides
a
summary
of
the
GIS
processing
steps
used.
The
GIS
analysis
output
results
file
was
then
combined
with
the
OSWI
and
landfill
databases
to
pull
in
tipping
fees
and
other
relevant
information.

Discussion
of
Results
Seven
IWIs
were
identified
that
met
the
definition
of
a
rural
IWI
by
being
more
than
50
miles
from
the
border
of
a
metropolitan
statistical
area
(
MSA).
These
7
rural
IWIs
are
listed
in
Table
1.
Under
the
provisions
of
the
final
rule,
these
7
rural
IWIs
may
petition
for
exemption.
These
rural
OSWI
were
flagged
in
the
database.

The
compiled
results
file
that
combines
the
GIS
output
file
with
the
OSWI
and
landfill
databases
is
provided
below.
Table
2
provides
a
description
of
the
fields
in
the
compiled
results
sheet.
Table
3
shows
OSWI­
specific
findings.
Nickerson
Memorandum
2
August
30,
2005
Page
2
Table
1.
Rural
IWIs
that
may
petition
for
exemption
(
IWIs
more
than
50
miles
from
the
border
of
an
MSA)
 
flagged
in
database
RTI
ID
State
Facility
Identifier
Facility
Name
City
State
17
0036
KIRKSVILLE
COLLEGE
OF
OSTEOPATHIC
MEDICINE
KIRKSVILLE
MO
159
26007E212
ALPENA
COMM
COLLEGE
ALPENA
MI
209
RTI13
DARTMOUTH
COLLEGE
HANOVER
NH
274
26061E211
JEFFERS
HIGH
SCHOOL
PAINESDALE
MI
290
484650003
LAUGHLIN
AIR
FORCE
BASE
DEL
RIO
TX
420
RTI403
UNIVERSITY
OF
ALASKA
FAIRBANKS
AK
432
22900005
USAF
CLEAR
CLEAR
USA
AK
Table
2.
Description
of
Electronic
Results
File
Summarized
in
Table
3
Column
Heading
Description
RTI_
ID
OSWI
facility
code
in
Task
1
database
OSWI
Name
Facility
name
with
OSWI
unit
City
City
location
of
OSWI
unit
State
State
location
of
OSWI
unit
LF_
CODE_
1
Landfill
facility
code
for
nearest
landfill
TIP_
FEE_
1
Tipping
fee
charged
by
nearest
landfill
($/
ton)
RoadDist1
(
miles)
Road
distance
to
nearest
landfill
(
miles)
LF_
CODE_
2
Landfill
facility
code
for
2nd
closest
landfill
TIP_
FEE_
2
Tipping
fee
charged
by
2nd
closest
landfill
($/
ton)
RoadDist2
(
miles)
Road
distance
to
2nd
closest
landfill
(
miles)
ATTACHMENT
1
Synopsis
of
OSWI
Project
GIS
Processing
Inputs
Two
Excel
files
were
received
on
08/
24/
05:
OSWI_
open_
2005.
xls
and
LFdata.
xls.
The
former
contained
two
sheets:
IWI
(
institutional
waste
incinerators)
and
VSMWC
(
very
small
municipal
waste
combustors).
Although
approximately
1/
3
of
the
records
had
a
longitude
and
latitude
value,
all
records
had
an
address.

Processing
These
two
sheets
were
combined
into
a
single
dbase
file
and
sent
to
TeleAtlas
via
ftp
for
geocoding.
Geocoding
is
the
process
of
matching
an
address
to
a
database
of
street
names
and
address
ranges.
Once
an
address
has
been
located
along
a
street,
the
location
is
converted
to
a
latitude
and
longitude.
Those
IWI
or
VSMWC
records
that
did
not
have
a
latitude
and
longitude
were
given
one
based
on
the
geocoded
address.
The
landfills
all
had
latitude
and
longitude
values
so
they
did
not
need
to
be
sent
to
TeleAtlas
for
geocoding.
Addresses
that
could
not
be
matched
to
a
location
were
moved
to
the
correct
location
by
hand.
The
correct
location
was
determined
by
a
variety
of
internet
mapping
sites.

The
two
files
containing
latitude
and
longitude
values
were
loaded
into
ArcGIS
and
converted
into
spatially
referenced
shapefiles.
A
layer
of
Metropolitan
Statistical
Areas
(
MSAs)
were
also
loaded
into
the
GIS
and
buffered
to
a
distance
of
50
miles.
All
IWI
facilities
greater
than
50
miles
from
an
MSA
(
7
facilities)
were
identified
and
flagged,
because
they
may
petition
for
exemption.

All
shapefiles
(
remaining
IWI
merged
with
VSMWC,
and
landfills)
were
projected
into
equidistant
conic
projection
that
would
allow
the
correct
distances
to
be
calculated
between
points.
A
pointdistance
tool
within
ArcGIS
was
used
to
calculate
the
distance
between
all
input
IWI/
VSMWC
facilities
and
land
fills.
The
closest
two
landfill
ids
were
recorded
as
well
as
their
respective
distances
from
the
IWI/
VSMWC
facilities.

Outputs
A
file
called
summary_
statistics_
by_
RTI_
ID.
dbf
was
generated
containing
the
RTI_
ID,
the
landfill
codes,
and
the
distances.
Nickerson
Memorandum
2
August
30,
2005
Page
4
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

1
1
NAVAL
AIR
WEAPONS
STATION
CA
0
CA0042
29
2.1
CA0037
29
3.78
9
1
NATIONAL
SECURITY
AGENCY
MD
0
MD0119
66.25
7.28
MD0013
65
7.98
10
1
NATIONAL
SECURITY
AGENCY
MD
0
MD0119
66.25
7.28
MD0013
65
7.98
11
1
NAVAL
SURFACE
WARFARE
CNTR­
INDIAN
HD
MD
0
VA0187
45
14.14
VA0058
45
20.16
12
1
NAVAL
SURFACE
WARFARE
CNTR­
INDIAN
HD
MD
0
VA0187
45
14.14
VA0058
45
20.16
18
1
MALMSTROM
AFB
MT
0
MT0004
24.86
9.94
MT0032
19.5
82.32
19
1
LOS
ALAMOS
NATIONAL
LABORATORY
NM
0
NM0009
12.5
1.54
NM0069
25
23.94
20
1
US
DEPARTMENT
OF
THE
ARMY
NV
0
NV0126
18.85
7.84
NV0014
24
43.4
21
1
TINKER
AFB
US
AIR
FORCE
LOGISTICS
CTR
OK
0
OK0093
40.45
6.86
OK0092
16.5
8.26
23
1
US
NAVY:
WEAPONS
STATION
SC
0
SC0114
29.25
10.92
SC0037
59.5
15.12
24
1
US
AIRFORCE:
CHARLESTON
AFB
SC
0
SC0114
29.25
1.68
SC0037
59.5
20.72
25
1
US
AIRFORCE:
SHAW
AFB
SC
0
SC0043
38
8.96
SC0020
33
25.2
26
1
MAIN
BASE
UT
0
UT0007
25
3.36
UT0005
29.5
9.94
93
1
US
ARMY
­
FORT
BELVOIR
VA
0
VA0187
45
20.58
MD0067
61
21.7
122
1
NAVY
SALVAGE
FUEL
BOILER
PLANT
VA
0
VA0314
20
7.42
VA0355
38.55
13.44
152
1
101ST
AIRBORNE
DIV./
FORT
CAMPBELL
TN
0
TN0049
33
27.02
TN0020
112.15
33.04
153
1
88
ABW/
EMP
OH
0
OH0349
35.5
11.06
OH0102
29.88
11.06
290
1
LAUGHLIN
AIR
FORCE
BASE
TX
1
TX0184
24.83
3.64
TX0137
25.84
57.4
322
1
NAVAL
SECURITY
GRP
ACTIVITY­
WINTER
HBR
ME
0
ME0029
59.57
67.9
ME0290
59.57
77.98
323
1
NAVAL
SECURITY
GRP
ACTIVITY­
WINTER
HBR
ME
0
ME0029
59.57
67.9
ME0290
59.57
77.98
324
1
NAVAL
SURFACE
WARFARE
CENTER
CRANE
IN
0
IN0170
23.5
22.82
IN0112
28
42.98
340
1
PETERSON
AFB
21CES
CEV
CO
0
CO0043
26.25
7.84
CO0210
21
12.6
408
1
U.
S.
ARMY
AIR
DEFENSE
ART
TX
0
TX0563
24
7.28
NM0025
24.6
14.84
431
1
US
MILITARY
ACADEMY
NY
0
NY0047
25.25
28.14
NY0025
60
29.26
432
1
USAF
CLEAR
AK
1
AK0044
54.31
58.8
AK0072
50
64.82
471
1
US
DEPARTMENT
OF
JUSTICE
FBI
VA
0
VA0449
50
7.42
VA0490
41
7.84
498
1
NAVAL
SECURITY
GROUP
ACTIVITY
WV
0
VA0086
29
32.76
VA0106
40
33.6
2
2
CALIF.
DEPT.
OF
FOOD
&
AG.
CA
0
CA0506
24.84
34.02
NV0001
11.19
36.12
3
2
CALIF.
DEPT.
OF
FOOD
&
AG.
CA
0
CA0506
24.84
34.02
NV0001
11.19
36.12
186
2
CALIF
CORRECTIONAL
CENTER
CA
0
CA0455
20.25
5.6
CA0045
27
28.28
(
continued)
Nickerson
Memorandum
2
August
30,
2005
Page
5
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
(
continued)

RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

22
3
PA
DEPT
OF
CORR/
DALLAS
SCI
PA
0
PA0083
55
24.36
PA0088
72
31.78
97
4
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
WI
0
WI0007
36
7.84
WI0008
34.5
18.34
98
4
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
WI
0
WI0007
36
7.84
WI0008
34.5
18.34
99
4
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
WI
0
WI0007
36
7.84
WI0008
34.5
18.34
100
4
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
WI
0
WI0007
36
7.84
WI0008
34.5
18.34
101
4
UNIVERSITY
OF
WISCONSIN
(
MAD)
SAFETY
DEPT
WI
0
WI0007
36
8.4
WI0008
34.5
18.2
299
5
LOUISIANA
STATE
PENITENTIARY
LA
0
LA0148
25.69
38.08
LA0042
25
38.5
309
6
MARYLAND
DEPARTMENT
OF
HEARTH
&

MENTAL
HYGIENE­
PUB
MD
0
MD0031
67.5
9.66
MD0119
66.25
15.26
325
7
NE
GAME
&
PARKS
COMMISSION
NE
0
NE0026
17
2.52
NE0016
32
28.42
439
8
WASH
STATE
PARK
&
RECREATION
COMM
WA
0
WA0053
66.3
3.36
WA0482
92.45
42.7
499
9
WVDEP­
OFFICE
OF
WASTE
MANAGEMENT
WV
0
MD0087
30
30.8
PA0090
44.5
37.66
38
10
LA
CO.,
SANITATION
DIST
CA
0
CA0485
39.56
11.06
CA0096
27
13.16
120
11
CARTER
COUNTY
AIR
CURTAIN
DESTRUCTION
TN
0
TN0175
32.16
10.78
VA0263
26.5
25.62
285
12
KALAMAOO
VALLEY
COMM
CO
MI
0
MI0888
36.6
15.82
MI0039
37.5
30.94
293
13
ELGIN
CUMMUNITY
COLLEGE
IL
0
IL0020
45
2.66
IL0062
45.15
16.38
470
14
HENRICO
COUNTY
POLICE
VA
0
VA0449
50
6.02
VA0490
41
8.12
(
continued)
Nickerson
Memorandum
2
August
30,
2005
Page
6
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
(
continued)

RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

484
15
MERCER
COUNTY
VO­
TECH
PA
0
OH0091
36
28.84
OH0092
22
39.62
500
16
HUNTINGTON
SANITARY
BOARD
WV
0
KY0216
33.83
16.52
KY0005
35
17.08
121
17
CITY
OF
ALCOA
INCINERATOR
TN
0
TN0014
26
0.14
TN0039
33.57
27.72
129
18
CITY
OF
SOUTHSIDE
PLACE
INCINERATOR
TX
0
TX0250
12.3
8.12
TX0236
30.3
8.12
130
19
TOWN
OF
READSBORO
INCINERATOR
VT
0
VT0050
26.04
MA0745
35.7
132
20
SILOAM
SPRINGS
AR
0
AR0074
36
23.1
OK0001
15.5
43.96
138
21
CITY
OF
LUFKIN
TX
0
TX0002
17.25
11.9
TX0146
25.26
27.02
139
22
CITY
OF
NORFOLK
WASTE
FACILITY
NE
0
NE0058
27.55
37.24
NE0018
26
69.44
140
23
CITY
OF
SULPHUR
SPRINGS
TX
0
TX0538
29.85
21.98
TX0175
22.5
47.6
143
24
OSSIPEE
INCINERATOR
FACILITY
NH
0
NH0119
67
7.42
NH0060
67
11.06
144
25
TOWN
OF
CANDIA
NH
0
NH0027
82
10.08
NH0131
82
29.96
145
26
TOWN
OF
LITCHFIELD
INCINERATOR
&

RECYCLING
FACILITY
NH
0
NH0131
107.6
12.04
NH0052
107.6
13.16
146
27
WILTON
RECYCLING
CENTER
NH
0
NH0053
16.67
8.68
NH0131
16.67
10.08
149
28
HEBRON
BRIDGEWATER
REFUSE
DISTRICT
NH
0
NH0037
77.91
13.16
NH0077
77.91
25.9
6
29
GRAYSLAKE
COMMUNITY
HIGH
SCHOOL
127
IL
0
IL0067
36
0.42
IL0065
38.5
13.72
45
30
GROSS
SCHOOL­
DIST
95
IL
0
IL0030
45.5
5.6
IL0032
38
12.04
(
continued)
Nickerson
Memorandum
2
August
30,
2005
Page
7
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
(
continued)

RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

57
31
DIEKMAN
SCHOOL
­
DISTRICT
149
IL
0
IL0236
37.5
2.66
IN0061
50
16.8
58
32
BERGER­
VANDENBERG
SCHOOL
IL
0
IL0236
37.5
2.94
IN0061
50
17.36
66
33
MARQUARDT
SCHOOL­
DISTRICT
15
IL
0
IL0030
45.5
12.74
IL0020
45
18.2
69
34
JACKSON
JUNIOR
HIGH
SCHOOL
IL
0
IL0030
45.5
6.16
IL0208
37.5
17.08
72
35
PIONEER
SCHOOL
IL
0
IL0062
45.15
7.28
IL0020
45
13.16
79
36
TRIOPIA
HIGH
SCHOOL
­
DISTRICT
27
IL
0
IL0110
25.5
41.16
IL0120
41
55.02
89
37
FREEPORT
SCHOOL
DISTRICT
145
­
EMPIRE
SCHOOL
IL
0
IL0129
35
5.32
IL0297
47.5
42.84
90
38
CARL
SANDBURG
SCHOOL
­
DISTRICT
145
IL
0
IL0129
35
5.32
IL0297
47.5
43.26
91
39
ROCK
FALLS
TOWNSHIP
HIGH
SCHOOL
IL
0
IL0296
36
21
IL0055
20.15
21.42
165
40
ATHENS
AREA
SCHOOL
DISTRICT
PA
0
NY0740
55
16.1
NY0296
55
16.1
184
41
BURRELL
SCHOOL
DISTRICT
PA
0
PA0101
63
14.56
PA0073
63
24.36
195
42
CHATTERTON
JR
HIGH
SCHOOL
MI
0
MI1623
30.05
23.94
MI0074
39
24.92
234
117
FITGERALD
HIGH
SCHOOL
MI
0
MI1623
30.05
23.8
MI0074
39
25.62
437
43
WALDRON
AREA
SCHOOLS
MI
0
OH0142
43.5
27.3
MI0062
50.76
31.22
469
43
POWHATAN
HIGH
SCHOOL
VA
0
VA0490
41
19.32
VA0083
50
19.6
476
44
HOLLIDAYSBURG
AREA
SCHOOL
DISTRICT
PA
0
PA0078
53.5
30.1
PA0072
42
39.76
(
continued)
Nickerson
Memorandum
2
August
30,
2005
Page
8
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
(
continued)

RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

477
45
FOREST
HILLS
SCHOOL
DISTRICT
(
ELE/
HI)
PA
0
PA0193
48.54
17.08
PA0072
42
20.3
480
45
FOREST
HILLS
SCHOOL
DISTRICT
(
ELE)
PA
0
PA0193
48.54
17.08
PA0072
42
20.3
479
46
NORTHERN
CAMBRIA
SCHOOL
DISTRICT
(
ELE/
MI)
PA
0
PA0072
42
19.04
PA0110
44.76
31.5
481
47
CARMICHAELS
AREA
SCHOOL
DISTRICT
PA
0
PA0090
44.5
9.24
PA0108
35
25.48
482
47
CARMICHAELS
AREA
SCHOOL
DISTRICT
PA
0
PA0090
44.5
9.24
PA0108
35
25.48
483
48
PURCHASE
LINE
SCHOOL
DISTRICT
(
JR/
SR/
ELE)
PA
0
PA0072
42
23.38
PA0110
44.76
27.58
485
49
TRINITY
AREA
SCHOOL
DISTRICT
PA
0
PA0077
50
0.56
PA0087
52
24.92
486
50
BURRELL
SCHOOL
DISTRICT
(
ELE)
PA
0
PA0101
63
14.56
PA0073
63
24.36
487
51
HEMPFIELD
AREA
SCHOOL
DISTRICT
(
SR.
HIGH)
PA
0
PA0114
50.54
3.64
PA0073
63
15.4
488
51
HEMPFIELD
AREA
SCHOOL
DISTRICT
(
SR.
HIGH)
PA
0
PA0114
50.54
3.64
PA0073
63
15.4
490
52
ELIZABETH
FORWARD
SCHOOL
DISTRICT
­

MIDDLE
SCHOOL
INCINERATOR
PA
0
PA0096
52.38
2.24
PA0073
63
8.82
491
53
KEYSTONE
OAKS
SCHOOL
DISTRICT
­
HIGH
SCHOOL
INCINERATOR
PA
0
PA0087
52
4.34
PA0099
67.64
4.48
39
54
SEAGULL
SANITATION
CA
0
CA0058
9.94
CA1613
40.88
307
55
MARIAN
MANOR
HEALTHCARE
CENTER
ND
0
ND0036
26.05
0.14
ND0042
21
55.44
497
56
GRANT
COUNTY
NURSING
HOME
WV
0
WV0020
37
29.54
VA0089
36
46.06
61
57
REGINA
DOMINICAN
HIGH
SCHOOL
IL
0
IL0208
37.5
9.38
IL0033
34.5
13.3
(
continued)
Nickerson
Memorandum
2
August
30,
2005
Page
9
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
(
continued)

RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

63
58
MISERICORDIA
SCHOOL
­
NORTH
IL
0
IL0208
37.5
12.04
IL0032
38
17.78
379
59
ST
CLARE
DE
MONTEFALCO
PARISH
MI
0
MI0084
26
26.04
MI1623
30.05
31.64
381
60
ST
GERARD
PARISH
MI
0
MI1623
30.05
11.62
MI0070
42
17.22
460
61
PINEY
FOREST
HEALTHCARE
DANVILLE
VA
0
VA0072
30
15.12
VA0038
15
21.7
489
62
BISHOP
MCCORT
HIGH
SCHOOL
PA
0
PA0193
48.54
7.98
PA0072
42
18.2
492
63
NORTH
CATHOLIC
HIGH
SCHOOL
­

INCINERATOR,
PYRONICS
PA
0
PA0099
67.64
3.78
PA0087
52
9.38
493
64
SISTERS
OF
THE
HOLY
SPIRIT
PA
0
PA0099
67.64
7
PA0087
52
11.06
494
65
ST.
ANGELA
MERICI
PARISH
PA
0
PA0073
63
7.14
PA0096
52.38
8.26
159
66
ALPENA
COMM
COLLEGE
MI
1
MI0289
36.6
5.74
MI0108
33
40.18
274
67
JEFFERS
HIGH
SCHOOL
MI
1
MI0012
60
39.06
MI0010
60
83.02
17
68
KIRKSVILLE
COLLEGE
OF
OSTEOPATHIC
MEDICI­
COLLEGE
MO
1
MO0009
19.5
0.28
MO0042
38.27
42.56
46
69
GOODWIN
ELEM
SCHOOL
IL
0
IL0032
38
6.86
IL0030
45.5
9.66
48
69
WOODBINE
SCHOOL­
DISTRICT
99
IL
0
IL0032
38
5.18
IL0030
45.5
11.34
49
69
SHERLOCK
SCHOOL
IL
0
IL0032
38
6.3
IL0030
45.5
10.5
52
69
DREXEL
SCHOOL
DISTRICT
99
IL
0
IL0032
38
5.32
IL0030
45.5
11.2
53
69
COLUMBUS
SCHOOL
DISTRICT
99
IL
0
IL0032
38
5.6
IL0030
45.5
10.78
55
69
MCKINLEY
SCHOOL
IL
0
IL0032
38
7.84
IL0030
45.5
9.38
56
69
LINCOLN
SCHOOL
­
DISTRICT
99
IL
0
IL0032
38
6.58
IL0030
45.5
10.08
501
69
CICERO­
EAST
SCHOOL­
DIST
99
IL
0
IL0032
38
6.16
IL0030
45.5
10.5
(
continued)
Nickerson
Memorandum
2
August
30,
2005
Page
10
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
(
continued)

RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

81
70
SPRINGFIELD
PUBLIC
SCHOOLS
DISTRICT
186
IL
0
IL0120
41
3.08
IL0013
27
35.56
82
70
SPRINGFIELD
HIGH
SCHOOL
­
DISTRICT
186
IL
0
IL0120
41
2.66
IL0013
27
35.14
83
70
WASHINGTON
MIDDLE
SCHOOL
­
DISTRICT
186
IL
0
IL0120
41
3.64
IL0013
27
35.84
84
70
SOUTHEAST
HIGH
SCHOOL
­
DISTRICT
186
IL
0
IL0120
41
0.98
IL0013
27
31.5
85
70
LANPHIER
HIGH
SCHOOL
­
DISTRICT
186
IL
0
IL0120
41
3.08
IL0013
27
35.14
87
70
FRANKLIN
MIDDLE
SCHOOL
­
DISTRICT
186
IL
0
IL0120
41
3.22
IL0013
27
34.16
65
71
ADDISON
TRAIL
HIGH
SCHOOL­
DISTRICT
88
IL
0
IL0030
45.5
10.36
IL0208
37.5
15.12
459
72
CONCORD
ELEMENTARY
SCHOOL
VA
0
VA0064
48
11.34
VA0060
39
14
468
73
JOHN
M
GANDY
ELEMENTARY
SCHOOL
VA
0
VA0054
50
10.92
VA0449
50
11.06
116
74
AMPACET
CORPORATION
LA
0
TX0523
23
45.36
TX0829
21
48.72
118
75
BFI
WASTE
SYSTEMS
OF
NORTH
AMERICA
­

RESERVE
LA
0
LA0076
25.69
8.4
LA0137
25.69
11.48
495
76
VINCENTIAN
HOME
INC.
(
SENIOR
RESIDENCE
HOME)
PA
0
PA0099
67.64
11.9
PA0087
52
15.26
142
77
ENVIRONMENTAL
SOLUTIONS
LLC
MN
0
MN0196
48
23.1
MN0130
60
24.36
4
78
UNIV
CAL,
RIVERSIDE
CA
0
CA0102
30.54
8.54
CA0133
36.34
9.38
8
79
KANSAS
UNIVERSITY
MEDICAL
CENTER
KS
0
KS0120
43
5.88
KS0049
39
13.72
200
80
COLORADO
STATE
UNIV
CO
0
CO0081
15.12
7
CO0162
27.75
25.9
399
81
TEXAS
A
&
M
UNIVERSITY
TX
0
TX0018
23.5
9.1
TX0597
25.84
79.24
409
82
UC­
DAVIS
CA
0
CA0209
0
0.7
CA0208
36
0.7
(
continue)
Nickerson
Memorandum
2
August
30,
2005
Page
11
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
(
continued)

RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

410
83
UCSD/
CAMPUS
CA
0
CA0147
41
16.8
CA0148
49.75
22.12
411
84
UCSF/
PARNASSUS
CA
0
CA0162
49.5
7.7
CA0008
58
19.6
412
85
UNIVERSITY
OF
NE
SWINE
RESEARCH
NE
0
NE0035
27.81
28.28
NE0026
17
33.32
414
86
UNIVERSITY
0F
HOUSTON
TX
0
TX0250
12.3
3.78
TX0236
30.3
3.78
418
87
UNIVERSITY
OF
ALABAMA
AT
BIRMINGHAM
(
INCINERATOR)
AL
0
AL0116
29
2.1
AL0050
45
8.96
419
87
UNIVERSITY
OF
ALABAMA
AT
BIRMINGHAM
(
INCINERATOR)
AL
0
AL0116
29
2.1
AL0050
45
8.96
428
88
UNL
MANTER
HALL
NE
0
NE0026
17
0.56
NE0016
32
26.46
436
89
VPI
&
STATE
UNIVERSITY
VA
0
VA0448
31.5
24.92
VA0029
38.55
33.18
462
90
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
VA
0
VA0021
43
10.64
VA0352
52
25.2
463
90
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
VA
0
VA0021
43
10.64
VA0352
52
25.2
464
90
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
VA
0
VA0021
43
10.64
VA0352
52
25.2
465
90
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
VA
0
VA0021
43
10.64
VA0352
52
25.2
472
91
NORFOLK
INTERNATIONAL
AIRPORT
VA
0
VA0314
20
11.9
VA0104
20
14.28
42
92
ORLANDO
SANFORD
INT'L
AIRPORT
FL
0
FL0223
33.17
14
FL0250
30.65
27.16
178
93
BOSTON
UNIVERSITY
#
2
MA
0
MA0650
43.5
15.96
MA0055
69.94
19.32
179
94
BOSTON
UNIVERSITY
ENGR
&
SCI
CTR
MA
0
MA0650
43.5
15.96
MA0055
69.94
19.32
217
95
DUKE
UNIVERSITY
HEATING
PLANT
NC
0
NC0083
45
16.94
NC0115
29.5
23.94
(
continued)
Nickerson
Memorandum
2
August
30,
2005
Page
12
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
(
continued)

RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

251
96
HAMPTON
UNIVERSITY
VA
0
VA0418
27.5
10.5
VA0314
20
13.3
302
97
M.
I.
T.
BLDG.
#
56
ANIMAL
CARE
FACILITY
MA
0
MA0650
43.5
15.54
MA0055
69.94
19.32
304
97
M.
I.
T.
COLLEGE
OF
HEALTH
SCIENCE
MA
0
MA0650
43.5
15.54
MA0055
69.94
19.32
344
98
PURDUE
UNIVERSITY­
WADE
UTILITY
PLANT
IN
0
IN0017
32
32.62
IN0139
30.65
34.44
374
99
SOUTHERN
RESEARCH
INSTITUTE
AL
0
AL0116
29
2.1
AL0050
45
8.82
375
99
SOUTHERN
RESEARCH
INSTITUTE
AL
0
AL0116
29
2.1
AL0050
45
8.82
390
100
STANFORD
UNIVERSITY
CA
0
CA0170
75
3.22
CA0001
55.77
18.2
415
101
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
NY
0
NY0310
48
15.26
NY0317
45
17.92
416
101
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
NY
0
NY0310
48
15.26
NY0317
45
17.92
417
101
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
NY
0
NY0310
48
15.26
NY0317
45
17.92
422
102
UNIVERSITY
OF
IDAHO,
HOLM
RESEARCH
CENTER
ID
0
ID0011
55
9.52
WA0058
69
10.64
426
103
UNIVERSITY
OF
MARYLAND­
MEDICAL
SCHOOL
TEACHING
FAC
MD
0
MD0031
67.5
8.68
MD0119
66.25
13.86
461
104
MARY
WASHINGTON
COLLEGE
VA
0
VA0271
42
7.84
VA0101
36
9.1
467
105
RANDOPH­
MACON
COLLEGE
VA
0
VA0449
50
10.5
VA0054
50
10.78
473
106
LOUDOUN
HOSPITAL
CENTER
­
CORNWALL
CAMPUS
VA
0
VA0062
55
6.02
VA0489
55
7.42
474
107
MWAA
­
WASHINGTON
DULLES
INTERNATIONAL
AIRPORT
VA
0
VA0489
55
14.84
VA0062
55
16.52
(
continued)
Nickerson
Memorandum
2
August
30,
2005
Page
13
turning
knowledge
into
practice
Table
3.
Landfill
Data
for
OSWI
Units
(
continued)

RTI_
ID
Owner
ID
OSWI
Name
State
>
50mi
MSA
LF_
CODE_
1
TipFee_
1
($/
ton)
RoadDist1
(
miles)
LF_
CODE_
2
TipFee_
2
($/
ton)
RoadDist2
(
miles)

475
108
BRIDGEWATER
COLLEGE
VA
0
VA0086
29
8.4
VA0106
40
19.6
496
109
DUKE
UNIVERSITY
HEATING
PLANT
NC
0
NC0083
45
15.4
NC0115
29.5
25.48
124
110
SMITH
ISLAND
INCINERATOR
MD
0
MD0091
52
24.08
MD0073
35
28.28
134
111
CITY
OF
AURORA
IL
0
IL0062
45.2
9.7
IL0020
45.0
24.1
150
112
SHELBY
COUNTY
COMMUNITY
SERVICES
IL
0
IL0191
33.6
IL0013
40.3
391
113
STEEPMEADOW
CLUB
INC
IL
0
IL0118
24.0
6.6
IL0117
36.0
9.9
424
114
UNIVERSITY
OF
ILLINOIS
IL
0
IL0136
28.0
45.9
IL0176
31.0
53.3
209
115
DARTMOUTH
COLLEGE
NH
1
NH0037
69.26
27.02
NH0045
60.6
38.92
420
116
UNIVERSITY
OF
ALASKA
AK
1
AK0044
54.31
11.34
AK0072
50
23.94
TO:
William
Nickerson,
EPA
THROUGH:
Gayle
Kline,
ICF
FROM:
Jeff
Coburn
Tom
Holloway
Katherine
Heller
DATE:
September
12,
2005
SUBJECT:
Memorandum
3.
Selection
of
Small
Entities
for
Detailed
Cost
Analysis
Background
RTI
is
supporting
EPA
in
evaluating
potential
small
entity
impacts
associated
with
EPA's
proposed
rule
regulating
emissions
from
Other
Solid
Waste
Incinerators
(
OSWI),
to
address
concerns
voiced
by
the
Small
Business
Administration
and
other
commenters
on
the
proposed
rule.
The
model
plant
analysis
conducted
for
the
proposal
indicated
that
most
OSWI
would
incur
no
additional
cost
or
perhaps
a
slight
savings
by
shutting
down
their
waste
combustion
unit
and
sending
the
waste
to
a
landfill.
This
memorandum
describes
the
methods
used
in
this
supplemental
analysis
to
estimate
the
costs
of
compliance
with
the
proposed
rule
and
the
costs
of
switching
to
landfilling,
and
the
criteria
used
to
identify
small
entities
for
detailed
cost
analysis.

Previous
memoranda
have
described
RTI's
process
for
identification
of
OSWI
units
that
are
currently
operating
and
in
scope
for
the
regulation,
characterizing
their
ownership
by
type,
size
and
location,
and
identifying
the
two
landfills
located
closest
to
each
OSWI.

RTI
identified
173
OSWI
units
still
operating
and
in
scope.
Of
these,
7
were
identified
as
being
located
farther
than
50
miles
from
the
border
of
an
MSA.
Because
these
"
rural"
OSWI
have
the
option
of
petition
for
exemption
from
the
rule,
these
units
were
flagged
in
the
database.

Of
the
173
OSWI,
RTI
identified
48
units
that
are
owned
by
small
entities,
as
defined
by
the
Regulatory
Flexibility
Act
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
RFA/
SBREFA).
These
include
45
units
owned
by
small
governments
and
3
units
owned
by
small
businesses.
These
units
are
assigned
a
small
business
flag
of
"
1"
in
the
database.
The
RFA/
SBREFA
criteria
for
small
nonprofit
organizations
is
somewhat
ambiguous
("
independently
owned"
and
"
not
dominant").
To
avoid
arbitrarily
identifying
nonprofit
organizations
as
dominant
or
not
dominant,
RTI
classified
all
nonprofit
organizations
as
potentially
small
and
treats
them,
at
least
for
tabulation
purposes,
as
small
entities.
These
units
are
assigned
a
small
business
flag
of
"
2"
in
the
database.
Thus,
there
are
a
total
of
108
OSWI
units
owned
by
small
or
potentially
small
entities.
For
all
of
the
small
or
potentially
small
OSWI
units,
RTI
identified
the
two
nearest
landfills,
and
compiled
data
on
distance
to
the
landfills
and
tipping
fees
at
the
landfills.
Nickerson
Memorandum
3
September
12,
2005
Page
2
Estimating
Costs
for
Compliance
or
Switching
to
Landfilling
Estimating
landfill
switching
costs
(
Option
1)

RTI
first
estimated
the
cost
of
landfilling
waste
currently
being
incinerated,
for
each
OSWI.
RTI
computed
landfill
costs
based
on
actual
throughput
data
where
available,
and
based
on
incinerator
capacity
when
actual
throughput
data
was
not
reported.
Missing
data
were
filled
based
on
reported
capacities
and
operating
days.
We
developed
separate
statistics
for
Very
Small
Municipal
Waste
Combustors
(
VSMWCs)
and
Institutional
Waste
Incinerators
(
IWIs).
Using
the
units
that
reported
throughput
data,
we
calculated
a
lower­
end
capacity
estimate
using
the
10th
percentile
throughput
for
each
class
of
incinerator
(
VSMWCs
and
IWIs),
a
midrange
capacity
estimate
using
the
arithmetic
average
throughput,
and
an
upper­
end
capacity
estimate
using
the
90th
percentile
throughput.

We
assumed
a
hauling
fee
of
$
0.50/
ton/
mile.
Using
these
data,
we
calculated
the
estimated
disposal
cost
for
the
closest
and
second
closest
landfills.
Landfill
distances
and
tipping
fees
were
based
on
site
specific
data
for
each
OSWI.
We
selected
the
lower
of
these
land
disposal
costs
as
the
landfill
cost.

EPA
had
estimated
at
proposal
that
landfilling
would
often
represent
absolute
cost
savings
relative
to
baseline
incinerator
costs.
To
test
this
assertion,
we
estimated
baseline
incineration
costs
using
site
specific
incinerator
throughput
data
as
described
above
and
a
regression
of
the
incinerator
operating
costs
that
were
developed
for
the
proposal.
We
excluded
capital
recovery
because
this
cost
will
be
incurred
whether
the
incinerator
is
operating
or
not.
We
conducted
separate
regressions
for
the
incinerator
operation
and
maintenance
(
O&
M)
cost
and
the
property
tax,
insurance,
and
administration
cost,
because
O&
M
cost
tends
to
behave
more
linearly
than
other
costs.
We
tried
various
types
of
regressions
(
linear,
power,
logarithmic,
etc.)
on
each
cost,
and
chose
the
regression
equation
with
the
best
R2
value.
We
found
the
best
results
when
the
batch
OSWI
units
were
considered
separately
from
the
intermittent
OSWI
units
in
the
regression.
Consequently,
we
developed
separate
equations
for
batch
and
intermittent
OSWI
units,
assuming
zero
cost
at
zero
throughput
for
the
batch
units.
The
switch
point
between
the
batch
and
intermittent
OSWI
equations
was
identified
by
determining
where
the
two
equations
intersect
(
i.
e.,
are
equal
to
one
another).
Tables
1
and
2
below
show
the
cost
data
we
used
in
the
regression,
as
well
as
the
regression
equations
we
chose
to
determine
the
incinerator
operation
costs.
The
x
and
y
coordinates
for
the
equations
are
also
identified.

After
we
determined
the
incinerator
operation
costs,
we
calculated
net
switching
costs
as
landfill
cost
minus
incinerator
operating
costs.
Negative
switching
costs
indicated
OSWI
for
which
landfilling
represents
an
absolute
cost
savings.
Of
the
173
OSWI
believed
to
be
in
scope
and
operating,
161
are
estimated
to
experience
cost
savings
if
they
switch
to
landfilling
their
waste;
only
12
are
projected
to
incur
any
positive
costs
by
switching
to
landfilling
at
baseline,
based
on
these
calculations.
Nickerson
Memorandum
3
September
12,
2005
Page
3
Table
1.
Regression
Results
for
O&
M
Costs
Capacity,
tpd
1
5
15
30
Waste
flow,
tpy
(
x)
121
290
870
1740
Electricity
$
71
$
587
$
1,426
$
2,684
Natural
gas
$
3,905
$
4,764
$
10,490
$
19,078
Water
$
0
$
20
$
60
$
121
Operating
labor
$
2,182
$
11,947
$
11,947
$
11,947
Supervisory
labor
$
327
$
1,792
$
1,792
$
1,792
Maintenance
labor
$
2,143
$
1,837
$
1,837
$
1,837
Maintenance
materials
$
1,285
$
2,736
$
4,504
$
6,169
Ash
disposal
$
436
$
1,044
$
3,132
$
6,263
PC
refractory
replacement
$
1,065
$
1,769
$
3,260
$
4,959
SC
refractory
replacement
$
561
$
1,443
$
2,851
$
4,416
Overhead
$
3,563
$
10,988
$
12,049
$
13,047
Total
O&
M­­
3rd
qtr
1998
$
15,538
$
38,927
$
53,348
$
72,313
Total
O&
M­­
Sept
2003
(
y)
$
17,061
$
42,742
$
58,576
$
79,400
Equation,
x
>
310
y
=
25.175x
+
35,903,
R2
=
0.9987
Equation,
x
 
310
y
=
141x,
R2
=
1.0
Table
2.
Regression
Results
for
Property
Taxes,
Insurance,
and
Administration
Costs
Capacity,
tpd
1
5
15
30
Waste
flow,
tpy
(
x)
121
290
870
1740
Property
tax,
insurance,
and
administration­­
3rd
qtr
1998
$
2,569
$
5,473
$
9,009
$
12,338
Property
tax,
insurance,
and
administration­­
Sept
2003
(
y)
$
2,821
$
6,009
$
9,892
$
13,547
Equation,
x
>
234
y
=
458.91x0.4537,
R2
=
1.0
Equation,
x
 
234
y
=
23.312x,
R2
=
1.0
Estimating
costs
of
complying
with
OSWI
Rule
(
Option
2)

To
estimate
the
costs
of
complying
with
the
OSWI
rule,
RTI
calculated
compliance
costs
for
each
OSWI
using
a
regression
of
the
OSWI
compliance
costs
that
were
developed
for
the
proposal.
We
tried
various
types
of
regressions
(
linear,
power,
logarithmic,
etc.)
on
the
OSWI
compliance
costs,
and
the
linear
regression
equation
had
the
best
R2
value.
Because
the
type
of
OSWI
unit
(
batch
or
intermittent)
was
not
a
significant
factor
in
compliance
costs
(
an
excellent
R2
value
was
obtained
with
batch
and
intermittent
units
together),
we
decided
to
use
a
single
compliance
cost
equation
for
all
OSWI
units
(
batch
and
intermittent).
Table
3
below
shows
the
cost
data
we
used
in
the
regression,
as
well
as
the
regression
equation
we
chose
to
determine
the
compliance
costs.
The
x
and
y
coordinates
for
the
equation
are
also
identified.
Nickerson
Memorandum
3
September
12,
2005
Page
4
Table
3.
Regression
Results
for
Compliance
Costs
Capacity,
tpd
1
5
15
30
Waste
flow,
tpy
(
x)
121
290
870
1740
WS­
Annualized
capital
$
18,355
$
23,674
$
34,310
$
50,265
WS­
Annual
(
direct
and
indirect)
$
23,609
$
32,381
$
52,352
$
82,309
CEMS­
Annualized
capital
$
10,825
$
10,825
$
10,825
$
10,825
CEMS­
Annual
(
direct
and
indirect)
$
23,125
$
23,125
$
23,125
$
23,125
CEMS­
Quarterly
audits
$
30,835
$
30,835
$
30,835
$
30,835
Performance
test
and
report
$
30,926
$
30,926
$
30,926
$
30,926
Recordkeeping
and
Reporting
$
22,698
$
22,698
$
22,698
$
22,698
Title
V
$
1,966
$
2,008
$
2,112
$
2,269
Total
cost
of
control
(
y)
$
162,339
$
176,470
$
207,183
$
253,251
Equation
y
=
55.005x
+
158,269,
R2
=
0.9972
Identifying
each
OSWI's
cost­
minimizing
compliance
option
RTI
assumed
that
each
OSWI
would
choose
to
comply
using
its
lowest­
cost
option
(
Option
1:
Switch
to
Landfill
or
Option
2:
Comply
with
OSWI
Rule).
We
compared
the
estimated
costs
for
each
option
for
each
OSWI.
Option
1
(
Landfilling)
was
found
to
be
the
lower
cost
option
for
all
OSWI.
See
Table
4.

Comparing
high
throughput
estimated
compliance
costs
to
owner
revenue
The
severity
of
impacts
on
small
entities
is
usually
defined
in
terms
of
the
ratio
of
costs
of
compliance
to
owner
entity
revenues.
To
be
conservative,
RTI
estimated
compliance
costs
under
the
lower
cost
option,
but
based
on
upper­
end
incinerator
throughput.
This
approach
provides
upper
bound
estimated
compliance
cost
for
each
OSWI
unit,
to
identify
those
small
entities
that
appear
most
likely
to
incur
significant
impacts
due
to
the
rule.
For
all
108
OSWI
owned
by
small
or
potentially
small
entities,
we
summed
the
cost
per
unit
to
calculate
estimated
upper
bound
cost
per
owner
entity.
We
then
compared
the
summed
costs
for
each
owner
entity
to
the
owner's
revenue
(
see
Table
5).
We
refer
to
this
criterion
as
the
cost­
to­
revenue
ratio
or
CRR.
The
analysis
showed
the
following
results:
o
Twelve
small
governments
owning
twelve
OSWI
units,
one
small
business
owning
one
OSWI
unit,
and
six
nonprofits
owning
8
OSWI
units
have
positive
costs,
assuming
high­
end
throughput.
o
No
non­
profits
had
a
CRR
exceeding
0.1%.
o
8
small
entities
had
a
CRR
exceeding
1.0%.
o
1
additional
small
entity
had
a
CRR
just
under
1.0%
Nickerson
Memorandum
3
September
12,
2005
Page
5
Units
recommended
for
detailed
cost
analysis
RTI
recommends
conducting
a
detailed
cost
analysis
for
the
nine
small
entities
having
projected
high­
throughput
CRRs
of
approximately
1
percent
or
greater.
o
Of
the
9
small
entities,
8
are
small
government
jurisdictions
and
one
is
a
small
business.
o
The
OSWI
units
at
the
9
small
entities
are
unit
numbers:
39,
130,
143,
144,
145,
146,
149,
150,
and
274.
o
8
of
the
9
units
are
VSMWC;
1
of
the
9
units
is
an
IWI.

References
Holloway,
T.
and
J.
Coburn.
2005.
Confirmation
of
Potential
Impacts
on
Small
Entities.
Memorandum
submitted
by
RTI
to
W.
Nickerson,
U.
S.
Environmental
Protection
Agency,
Office
of
Policy,
Economics,
and
Innovation,
through
G.
Kline,
ICF.
October
16.

Dijkgraaf,
E.
and
H.
Vollebergh.
2003.
Burn
or
Bury?
A
Social
Cost
Comparison
of
Final
Waste
Disposal
Methods.
April.

Burning
Garbage
and
Land
Disposal
in
Rural
Alaska.
2004.
Alaska
Energy
Authority
and
Alaska
Department
of
Environmental
Conservation.
May.

Shrager,
B.
2004.
OSWI 
Documentation
of
Teleconference
with
Representatives
of
the
State
of
Alaska.
Memorandum
submitted
by
EPA
to
project
files.
July
21.

Rutz,
C.
2005.
Comments
on
the
Proposed
Standards
of
Performance
for
New
Stationary
Sources
and
Emission
Guidelines
for
Existing
Sources:
Other
Solid
Waste
Incineration
Units;
Proposed
Rule.
Letter
and
attachment
from
Alyeska
Pipeline
Service
Co.
to
EPA.
February
7.
Nickerson
Memorandum
3
September
12,
2005
Page
6
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
1
1
1
NAVAL
AIR
WEAPONS
STATION
0
41.00
$
1,232
$
6,737
$
(
5,505)
$
160,524
$
(
5,505)
1853000
0.00%

9
1
1
NATIONAL
SECURITY
AGENCY
0
265.58
$
18,323
$
43,223
$
(
24,900)
$
172,877
$
(
24,900)
1853000
0.00%

10
1
1
NATIONAL
SECURITY
AGENCY
0
249.96
$
17,245
$
40,863
$
(
23,618)
$
172,018
$
(
23,618)
1853000
0.00%

11
1
1
NAVAL
SURFACE
WARFARE
CNTR­
INDIAN
HD
0
58.58
$
3,050
$
9,626
$
(
6,576)
$
161,491
$
(
6,576)
1853000
0.00%

12
1
1
NAVAL
SURFACE
WARFARE
CNTR­
INDIAN
HD
0
58.58
$
3,050
$
9,626
$
(
6,576)
$
161,491
$
(
6,576)
1853000
0.00%

18
1
1
MALMSTROM
AFB
0
1,900.08
$
56,679
$
97,840
$
(
41,161)
$
262,783
$
(
41,161)
1853000
0.00%

19
1
1
LOS
ALAMOS
NATIONAL
LABORATORY
0
444.64
$
5,900
$
54,394
$
(
48,493)
$
182,727
$
(
48,493)
1853000
0.00%

20
1
1
US
DEPARTMENT
OF
THE
ARMY
0
444.64
$
10,125
$
54,394
$
(
44,269)
$
182,727
$
(
44,269)
1853000
0.00%

21
1
1
TINKER
AFB
US
AIR
FORCE
LOGISTICS
CTR
0
44.10
$
910
$
7,246
$
(
6,336)
$
160,695
$
(
6,336)
1853000
0.00%

23
1
1
US
NAVY:
WEAPONS
STATION
0
16.40
$
569
$
2,695
$
(
2,125)
$
159,171
$
(
2,125)
1853000
0.00%

24
1
1
US
AIRFORCE:
CHARLESTON
AFB
0
8.52
$
256
$
1,400
$
(
1,144)
$
158,738
$
(
1,144)
1853000
0.00%

25
1
1
US
AIRFORCE:
SHAW
AFB
0
0.47
$
20
$
76
$
(
57)
$
158,295
$
(
57)
1853000
0.00%

26
1
1
MAIN
BASE
0
444.64
$
11,863
$
54,394
$
(
42,531)
$
182,727
$
(
42,531)
1853000
0.00%

93
1
1
US
ARMY
­
FORT
BELVOIR
0
127.00
$
7,022
$
20,868
$
(
13,846)
$
165,255
$
(
13,846)
1853000
0.00%

122
1
1
NAVY
SALVAGE
FUEL
BOILER
PLANT
0
3,288.07
$
77,960
$
136,767
$
(
58,807)
$
339,130
$
(
58,807)
1853000
0.00%

152
1
1
101ST
AIRBORNE
DIV./
FORT
CAMPBELL
0
245.91
$
11,437
$
40,250
$
(
28,813)
$
171,795
$
(
28,813)
1853000
0.00%

153
1
1
88
ABW/
EMP
0
956.31
$
33,863
$
70,306
$
(
36,443)
$
210,871
$
(
36,443)
1853000
0.00%

290
1
1
LAUGHLIN
AIR
FORCE
BASE
0
273.23
$
7,282
$
44,376
$
(
37,094)
$
173,298
$
(
37,094)
1853000
0.00%

322
1
1
NAVAL
SECURITY
GRP
ACTIVITY­
WINTER
HBR
0
254.11
$
23,764
$
41,490
$
(
17,726)
$
172,246
$
(
17,726)
1853000
0.00%

323
1
1
NAVAL
SECURITY
GRP
ACTIVITY­
WINTER
HBR
0
254.11
$
23,764
$
41,490
$
(
17,726)
$
172,246
$
(
17,726)
1853000
0.00%

324
1
1
NAVAL
SURFACE
WARFARE
CENTER
CRANE
0
444.64
$
15,522
$
54,394
$
(
38,871)
$
182,727
$
(
38,871)
1853000
0.00%

340
1
1
PETERSON
AFB
21CES
CEV
0
819.70
$
22,378
$
66,169
$
(
43,792)
$
203,356
$
(
43,792)
1853000
0.00%

408
1
1
U.
S.
ARMY
AIR
DEFENSE
ART
0
204.92
$
5,664
$
33,672
$
(
28,007)
$
169,541
$
(
28,007)
1853000
0.00%

431
1
1
US
MILITARY
ACADEMY
0
444.64
$
17,483
$
54,394
$
(
36,910)
$
182,727
$
(
36,910)
1853000
0.00%

432
1
1
USAF
CLEAR
0
444.64
$
36,643
$
54,394
$
(
17,751)
$
182,727
$
(
17,751)
1853000
0.00%

471
1
1
US
DEPARTMENT
OF
JUSTICE
FBI
0
54.65
$
2,455
$
8,979
$
(
6,524)
$
161,275
$
(
6,524)
1853000
0.00%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
7
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
498
1
1
NAVAL
SECURITY
GROUP
ACTIVITY
0
173.05
$
7,853
$
28,434
$
(
20,581)
$
167,787
$
(
20,581)
1853000
0.00%

1
z
0
1853000
0.00%

2
2
2
CALIF.
DEPT.
OF
FOOD
&
AG.
0
203.09
$
5,940
$
33,371
$
(
27,430)
$
169,440
$
(
27,430)
151245
0.00%

3
2
2
CALIF.
DEPT.
OF
FOOD
&
AG.
0
710.82
$
20,792
$
62,826
$
(
42,034)
$
197,368
$
(
42,034)
151245
0.00%

186
2
2
CALIF
CORRECTIONAL
CENTER
0
436.80
$
10,068
$
54,138
$
(
44,069)
$
182,295
$
(
44,069)
151245
0.00%

2
z
0
151245
­
0.0001%

22
3
2
PA
DEPT
OF
CORR/
DALLAS
SCI
0
200.94
$
13,499
$
33,017
$
(
19,518)
$
169,322
$
(
19,518)
46.1645
­
0.04%

2
z
0
46.1645
­
0.04%

97
4
7
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
2
444.64
$
17,750
$
54,394
$
(
36,644)
$
182,727
$
(
36,644)
1905.8
0.00%

98
4
7
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
2
444.64
$
17,750
$
54,394
$
(
36,644)
$
182,727
$
(
36,644)
1905.8
0.00%

99
4
7
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
2
444.64
$
17,750
$
54,394
$
(
36,644)
$
182,727
$
(
36,644)
1905.8
0.00%

100
4
7
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
2
444.64
$
17,750
$
54,394
$
(
36,644)
$
182,727
$
(
36,644)
1905.8
0.00%

101
4
7
UNIVERSITY
OF
WISCONSIN
(
MAD)
SAFETY
DEPT
2
1,606.61
$
64,586
$
89,418
$
(
24,833)
$
246,640
$
(
24,833)
1905.8
0.00%

7
z
2
1905.8
­
0.01%

299
5
2
LOUISIANA
STATE
PENITENTIARY
0
4,098.48
$
181,358
$
159,071
$
22,287
$
383,706
$
22,287
18078.5
0.00%

2
z
0
18078.5
0.0001%

309
6
2
MARYLAND
DEPARTMENT
OF
HEARTH
&

MENTAL
HYGIENE­
PUB
0
273.23
$
19,763
$
44,376
$
(
24,613)
$
173,298
$
(
24,613)
20787.9
0.00%

2
z
0
20787.9
­
0.0001%

325
7
2
NE
GAME
&
PARKS
COMMISSION
0
444.64
$
8,119
$
54,394
$
(
46,274)
$
182,727
$
(
46,274)
6001.93
0.00%

2
z
0
6001.93
­
0.0008%

439
8
2
WASH
STATE
PARK
&
RECREATION
COMM
0
444.64
$
30,227
$
54,394
$
(
24,167)
$
182,727
$
(
24,167)
23.8131
­
0.10%

2
z
0
23.8131
­
0.1015%

499
9
2
WVDEP­
OFFICE
OF
WASTE
MANAGEMENT
0
444.64
$
20,187
$
54,394
$
(
34,207)
$
182,727
$
(
34,207)
9130.22
0.00%

2
z
0
9130.22
­
0.0004%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
8
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
38
10
3
LA
CO.,
SANITATION
DIST
0
3,818.41
$
128,222
$
151,388
$
(
23,166)
$
368,301
$
(
23,166)
14788.2
0.00%

2
z
0
14788.2
­
0.0002%

120
11
3
CARTER
COUNTY
AIR
CURTAIN
DESTRUCTION
0
3,288.07
$
123,467
$
136,767
$
(
13,300)
$
339,130
$
(
13,300)
50.3
­
0.03%

3
z
0
50.3
­
0.0264%

285
12
3
KALAMAZOO
VALLEY
COMM
CO
0
1,639.39
$
72,969
$
90,364
$
(
17,395)
$
248,444
$
(
17,395)
128.219
­
0.01%

3
z
0
128.219
­
0.0136%

293
13
3
ELGIN
CUMMUNITY
COLLEGE
0
873.60
$
40,474
$
67,809
$
(
27,335)
$
206,321
$
(
27,335)
162.049
­
0.02%

3
z
0
162.049
­
0.0169%

470
14
3
HENRICO
COUNTY
POLICE
0
444.64
$
20,036
$
54,394
$
(
34,358)
$
182,727
$
(
34,358)
694.602
0.00%

3
z
0
694.602
­
0.0049%

484
15
3
MERCER
COUNTY
VO­
TECH
0
444.64
$
18,591
$
54,394
$
(
35,803)
$
182,727
$
(
35,803)
47.2
­
0.08%

3
z
0
47.2
­
0.0759%

500
16
4
HUNTINGTON
SANITARY
BOARD
0
444.64
$
18,715
$
54,394
$
(
35,679)
$
182,727
$
(
35,679)
50.196
­
0.07%

4
z
0
50.196
­
0.0711%

121
17
4
CITY
OF
ALCOA
INCINERATOR
1
3,288.07
$
85,720
$
136,767
$
(
51,047)
$
339,130
$
(
51,047)
18.2283
­
0.28%

4
z
1
18.2283
­
0.2800%

129
18
4
CITY
OF
SOUTHSIDE
PLACE
INCINERATOR
1
3,358.33
$
54,942
$
138,710
$
(
83,768)
$
342,994
$
(
83,768)
1.3142
­
6.37%

4
z
1
1.3142
­
6.3741%

130
19
4
TOWN
OF
READSBORO
INCINERATOR
1
3,358.33
$
194,851
$
138,710
$
56,140
$
342,994
$
56,140
1.02381
5.48%

4
z
1
1.02381
5.4834%

132
20
4
SILOAM
SPRINGS
1
5,910.67
$
221,532
$
208,304
$
13,227
$
483,385
$
13,227
15.9424
0.08%

4
z
1
15.9424
0.0830%

138
21
4
CITY
OF
LUFKIN
1
3,288.07
$
76,283
$
136,767
$
(
60,484)
$
339,130
$
(
60,484)
40.987
­
0.15%

4
z
1
40.987
­
0.1476%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
9
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
139
22
4
CITY
OF
NORFOLK
WASTE
FACILITY
1
6.61
$
305
$
1,086
$
(
781)
$
158,633
$
(
781)
35.1298
0.00%

4
z
1
35.1298
­
0.0022%

140
23
4
CITY
OF
SULPHUR
SPRINGS
1
3,288.07
$
134,285
$
136,767
$
(
2,482)
$
339,130
$
(
2,482)
14.2315
­
0.02%

4
z
1
14.2315
­
0.0174%

143
24
3
OSSIPEE
INCINERATOR
FACILITY
1
4,030.00
$
240,430
$
157,194
$
83,236
$
379,939
$
83,236
9.28023
0.90%

3
z
1
9.28023
0.8969%

144
25
4
TOWN
OF
CANDIA
1
4,030.00
$
245,790
$
157,194
$
88,595
$
379,939
$
88,595
8.63771
1.03%

4
z
1
8.63771
1.0257%

145
26
4
TOWN
OF
LITCHFIELD
INCINERATOR
&

RECYCLING
FACILITY
1
6,179.33
$
531,546
$
215,549
$
315,997
$
498,163
$
315,997
16.2777
1.94%

4
z
1
16.2777
1.9413%

146
27
4
WILTON
RECYCLING
CENTER
1
8,060.00
$
679,780
$
265,980
$
413,801
$
601,609
$
413,801
8.22984
5.03%

4
z
1
8.22984
5.0280%

149
28
3
HEBRON
BRIDGEWATER
REFUSE
DISTRICT
1
3,868.80
$
206,787
$
152,772
$
54,015
$
371,072
$
54,015
2.14682
2.52%

3
z
1
2.14682
2.5161%

6
29
5
GRAYSLAKE
COMMUNITY
HIGH
SCHOOL
127
1
488.20
$
17,678
$
55,806
$
(
38,128)
$
185,123
$
(
38,128)
6.1
­
0.63%

5
z
1
6.1
­
0.6251%

45
30
5
GROSS
SCHOOL­
DIST
95
1
390.56
$
17,193
$
52,615
$
(
35,423)
$
179,752
$
(
35,423)
3.2
­
1.11%

5
z
1
3.2
­
1.1070%

57
31
5
DIEKMAN
SCHOOL
­
DISTRICT
149
1
390.56
$
15,166
$
52,615
$
(
37,450)
$
179,752
$
(
37,450)
12.2
­
0.31%

5
z
1
12.2
­
0.3070%

58
32
5
BERGER­
VANDENBERG
SCHOOL
1
468.68
$
18,264
$
55,175
$
(
36,911)
$
184,048
$
(
36,911)
12.2
­
0.30%

5
z
1
12.2
­
0.3025%

66
33
5
MARQUARDT
SCHOOL­
DISTRICT
15
1
449.15
$
23,297
$
54,540
$
(
31,243)
$
182,974
$
(
31,243)
10.7
­
0.29%

5
z
1
10.7
­
0.2920%

69
34
5
JACKSON
JUNIOR
HIGH
SCHOOL
1
507.73
$
23,376
$
56,435
$
(
33,059)
$
186,197
$
(
33,059)
17.3
­
0.19%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
10
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
5
z
1
17.3
­
0.1911%

72
35
5
PIONEER
SCHOOL
1
488.20
$
23,819
$
55,806
$
(
31,987)
$
185,123
$
(
31,987)
16
­
0.20%

5
z
1
16
­
0.1999%

79
36
5
TRIOPIA
HIGH
SCHOOL
­
DISTRICT
27
1
507.73
$
23,396
$
56,435
$
(
33,038)
$
186,197
$
(
33,038)
1.9
­
1.74%

5
z
1
1.9
­
1.7389%

89
37
5
FREEPORT
SCHOOL
DISTRICT
145
­
EMPIRE
SCHOOL
1
488.20
$
18,386
$
55,806
$
(
37,421)
$
185,123
$
(
37,421)
17
­
0.22%

5
z
1
17
­
0.2201%

90
38
5
CARL
SANDBURG
SCHOOL
­
DISTRICT
145
1
361.27
$
13,605
$
51,639
$
(
38,033)
$
178,141
$
(
38,033)
17
­
0.22%

5
z
1
17
­
0.2237%

91
39
5
ROCK
FALLS
TOWNSHIP
HIGH
SCHOOL
1
390.56
$
12,053
$
52,615
$
(
40,562)
$
179,752
$
(
40,562)
3.5
­
1.16%

5
z
1
3.5
­
1.1589%

165
40
5
ATHENS
AREA
SCHOOL
DISTRICT
1
546.46
$
34,455
$
57,673
$
(
23,218)
$
188,327
$
(
23,218)
12.3
­
0.19%

5
z
1
12.3
­
0.1888%

184
41
5
BURRELL
SCHOOL
DISTRICT
1
888.00
$
62,409
$
68,245
$
(
5,836)
$
207,114
$
(
5,836)
8.9
­
0.07%

5
z
1
8.9
­
0.0656%

195
42
5
CHATTERTON
JR
HIGH
SCHOOL
1
1,092.93
$
45,925
$
74,391
$
(
28,466)
$
218,386
$
(
28,466)
13.3
­
0.21%

5
z
1
13.3
­
0.2140%

234
117
5
FITZGERALD
HIGH
SCHOOL
1
218.59
$
9,170
$
35,916
$
(
26,747)
$
170,292
$
(
26,747)
13.3
­
0.20%

5
z
1
13.3
­
0.2011%

437
43
5
WALDRON
AREA
SCHOOLS
1
227.69
$
13,013
$
37,413
$
(
24,400)
$
170,793
$
(
24,400)
1.8
­
1.36%

469
43
5
POWHATAN
HIGH
SCHOOL
1
444.64
$
22,526
$
54,394
$
(
31,868)
$
182,727
$
(
31,868)
13.8
­
0.23%

5
z
1
15.6
­
1.59%

476
44
5
HOLLIDAYSBURG
AREA
SCHOOL
DISTRICT
1
91.08
$
5,636
$
14,965
$
(
9,329)
$
163,279
$
(
9,329)
18.2
­
0.05%

5
z
1
18.2
­
0.05%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
11
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
477
45
5
FOREST
HILLS
SCHOOL
DISTRICT
(
ELE/
HI)
1
500.93
$
26,123
$
56,216
$
(
30,093)
$
185,822
$
(
30,093)
9.2
­
0.33%

480
45
5
FOREST
HILLS
SCHOOL
DISTRICT
(
ELE)
1
45.54
$
2,375
$
7,483
$
(
5,108)
$
160,774
$
(
5,108)
9.2
­
0.06%

5
z
1
9.2
­
0.38%

479
46
5
NORTHERN
CAMBRIA
SCHOOL
DISTRICT
(
ELE/
MI)
1
455.39
$
23,462
$
54,744
$
(
31,282)
$
183,318
$
(
31,282)
6.1
­
0.51%

5
z
1
6.1
­
0.51%

481
47
5
CARMICHAELS
AREA
SCHOOL
DISTRICT
1
200.37
$
9,566
$
32,923
$
(
23,358)
$
169,290
$
(
23,358)
5.5
­
0.42%

482
47
5
CARMICHAELS
AREA
SCHOOL
DISTRICT
1
182.15
$
8,696
$
29,930
$
(
21,234)
$
168,288
$
(
21,234)
5.5
­
0.39%

5
z
1
5.5
­
0.81%

483
48
5
PURCHASE
LINE
SCHOOL
DISTRICT
(
JR/
SR/
ELE)
1
444.64
$
23,873
$
54,394
$
(
30,521)
$
182,727
$
(
30,521)
6.1
­
0.50%

5
z
1
6.1
­
0.50%

485
49
5
TRINITY
AREA
SCHOOL
DISTRICT
1
45.54
$
2,290
$
7,483
$
(
5,193)
$
160,774
$
(
5,193)
18
­
0.03%

5
z
1
18
­
0.03%

486
50
5
BURRELL
SCHOOL
DISTRICT
(
ELE)
1
296.00
$
20,803
$
47,803
$
(
27,000)
$
174,551
$
(
27,000)
8.9
­
0.30%

5
z
1
8.9
­
0.30%

487
51
5
HEMPFIELD
AREA
SCHOOL
DISTRICT
(
SR.

HIGH)
1
273.23
$
14,306
$
44,376
$
(
30,070)
$
173,298
$
(
30,070)
32.1
­
0.09%

488
51
5
HEMPFIELD
AREA
SCHOOL
DISTRICT
(
SR.

HIGH)
1
273.23
$
14,306
$
44,376
$
(
30,070)
$
173,298
$
(
30,070)
32.1
­
0.09%

5
z
1
32.1
­
0.19%

490
52
5
ELIZABETH
FORWARD
SCHOOL
DISTRICT
­

MIDDLE
SCHOOL
INCINERATOR
1
163.94
$
8,771
$
26,937
$
(
18,166)
$
167,286
$
(
18,166)
13.2
­
0.14%

5
z
1
13.2
­
0.14%

491
53
5
KEYSTONE
OAKS
SCHOOL
DISTRICT
­
HIGH
SCHOOL
INCINERATOR
1
273.23
$
14,801
$
44,376
$
(
29,575)
$
173,298
$
(
29,575)
14.4
­
0.21%

5
z
1
14.4
­
0.21%

39
54
6
SEAGULL
SANITATION
1
3,182.01
$
201,453
$
133,830
$
67,623
$
333,295
$
67,623
1.75
3.86%

6
z
1
1.75
3.86%

307
55
7
MARIAN
MANOR
HEALTHCARE
CENTER
2
27.32
$
714
$
4,490
$
(
3,776)
$
159,772
$
(
3,776)
2.4
­
0.16%

7
z
2
2.4
­
0.16%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
12
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
497
56
6
GRANT
COUNTY
NURSING
HOME
1
31.88
$
1,650
$
5,238
$
(
3,588)
$
160,022
$
(
3,588)
3
­
0.12%

6
z
1
3
­
0.12%

61
57
7
REGINA
DOMINICAN
HIGH
SCHOOL
2
464.40
$
19,110
$
55,036
$
(
35,926)
$
183,813
$
(
35,926)
0
0.00%

7
z
2
0
0.00%

63
58
7
MISERICORDIA
SCHOOL
­
NORTH
2
507.73
$
22,096
$
56,435
$
(
34,338)
$
186,197
$
(
34,338)
0
0.00%

7
z
2
0
0.00%

379
59
7
ST
CLARE
DE
MONTEFALCO
PARISH
2
683.08
$
26,654
$
61,966
$
(
35,312)
$
195,842
$
(
35,312)
2.1
­
1.68%

7
z
2
2.1
­
1.68%

381
60
7
ST
GERARD
PARISH
2
245.91
$
8,818
$
40,250
$
(
31,432)
$
171,795
$
(
31,432)
165.2
­
0.02%

7
z
2
165.2
­
0.02%

460
61
7
PINEY
FOREST
HEALTHCARE
DANVILLE
2
444.64
$
11,494
$
54,394
$
(
42,900)
$
182,727
$
(
42,900)
9.3
­
0.46%

7
z
2
9.3
­
0.46%

489
62
7
BISHOP
MCCORT
HIGH
SCHOOL
2
444.64
$
22,721
$
54,394
$
(
31,672)
$
182,727
$
(
31,672)
0
0.00%

7
z
2
0
0.00%

492
63
7
NORTH
CATHOLIC
HIGH
SCHOOL
­

INCINERATOR,
PYRONICS
2
102.46
$
5,809
$
16,836
$
(
11,027)
$
163,905
$
(
11,027)
0
0.00%

7
z
2
0
0.00%

493
64
7
SISTERS
OF
THE
HOLY
SPIRIT
2
42.69
$
2,456
$
7,015
$
(
4,559)
$
160,617
$
(
4,559)
1.2
­
0.38%

7
z
2
1.2
­
0.38%

494
65
7
ST.
ANGELA
MERICI
PARISH
2
54.65
$
3,088
$
8,979
$
(
5,891)
$
161,275
$
(
5,891)
0.16
­
3.68%

7
z
2
0.16
­
3.68%

159
66
7
ALPENA
COMM
COLLEGE
2
546.46
$
21,569
$
57,673
$
(
36,104)
$
188,327
$
(
36,104)
42
­
0.09%

7
z
2
42
­
0.09%

274
67
5
JEFFERS
HIGH
SCHOOL
1
444.64
$
32,784
$
54,394
$
(
21,610)
$
182,727
$
(
21,610)
2.1
­
1.03%

5
z
1
2.1
­
1.03%

17
68
7
KIRKSVILLE
COLLEGE
OF
OSTEOPATHIC
MEDICI­
COLLEGE
2
203.09
$
3,989
$
33,371
$
(
29,382)
$
169,440
$
(
29,382)
0
0.00%

7
z
2
0
0.00%

46
69
5
GOODWIN
ELEM
SCHOOL
0
390.56
$
16,181
$
52,615
$
(
36,434)
$
179,752
$
(
36,434)
36.8
­
0.10%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
13
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
48
69
5
WOODBINE
SCHOOL­
DISTRICT
99
0
390.56
$
15,853
$
52,615
$
(
36,762)
$
179,752
$
(
36,762)
36.8
­
0.10%

49
69
5
SHERLOCK
SCHOOL
0
390.56
$
16,072
$
52,615
$
(
36,544)
$
179,752
$
(
36,544)
36.8
­
0.10%

52
69
5
DREXEL
SCHOOL
DISTRICT
99
0
390.56
$
15,880
$
52,615
$
(
36,735)
$
179,752
$
(
36,735)
36.8
­
0.10%

53
69
5
COLUMBUS
SCHOOL
DISTRICT
99
0
390.56
$
15,935
$
52,615
$
(
36,680)
$
179,752
$
(
36,680)
36.8
­
0.10%

55
69
5
MCKINLEY
SCHOOL
0
390.56
$
16,372
$
52,615
$
(
36,243)
$
179,752
$
(
36,243)
36.8
­
0.10%

56
69
5
LINCOLN
SCHOOL
­
DISTRICT
99
0
390.56
$
16,126
$
52,615
$
(
36,489)
$
179,752
$
(
36,489)
36.8
­
0.10%

501
69
5
CICERO­
EAST
SCHOOL­
DIST
99
0
50.00
$
2,054
$
8,216
$
(
6,162)
$
161,019
$
(
6,162)
36.8
­
0.02%

5
z
0
36.8
­
0.71%

81
70
5
SPRINGFIELD
PUBLIC
SCHOOLS
DISTRICT
186
0
488.20
$
20,768
$
55,806
$
(
35,038)
$
185,123
$
(
35,038)
60.1
­
0.06%

82
70
5
SPRINGFIELD
HIGH
SCHOOL
­
DISTRICT
186
0
351.51
$
14,879
$
51,311
$
(
36,432)
$
177,604
$
(
36,432)
60.1
­
0.06%

83
70
5
WASHINGTON
MIDDLE
SCHOOL
­
DISTRICT
186
0
351.51
$
15,052
$
51,311
$
(
36,259)
$
177,604
$
(
36,259)
60.1
­
0.06%

84
70
5
SOUTHEAST
HIGH
SCHOOL
­
DISTRICT
186
0
351.51
$
14,584
$
51,311
$
(
36,727)
$
177,604
$
(
36,727)
60.1
­
0.06%

85
70
5
LANPHIER
HIGH
SCHOOL
­
DISTRICT
186
0
351.51
$
14,953
$
51,311
$
(
36,358)
$
177,604
$
(
36,358)
60.1
­
0.06%

87
70
5
FRANKLIN
MIDDLE
SCHOOL
­
DISTRICT
186
0
351.51
$
14,978
$
51,311
$
(
36,333)
$
177,604
$
(
36,333)
60.1
­
0.06%

5
z
0
60.1
­
0.36%

65
71
5
ADDISON
TRAIL
HIGH
SCHOOL­
DISTRICT
88
0
1,125.00
$
50,693
$
75,343
$
(
24,651)
$
220,150
$
(
24,651)
20.9
­
0.12%

5
z
0
20.9
­
0.12%

459
72
5
CONCORD
ELEMENTARY
SCHOOL
0
444.64
$
20,454
$
54,394
$
(
33,940)
$
182,727
$
(
33,940)
30.1
­
0.11%

5
z
0
30.1
­
0.11%

468
73
5
JOHN
M
GANDY
ELEMENTARY
SCHOOL
0
444.64
$
24,660
$
54,394
$
(
29,734)
$
182,727
$
(
29,734)
60.7
­
0.05%

5
z
0
60.7
­
0.05%

116
74
6
AMPACET
CORPORATION
0
3,288.07
$
149,147
$
136,767
$
12,380
$
339,130
$
12,380
609
0.00%

6
z
0
609
0.00%

118
75
6
BFI
WASTE
SYSTEMS
OF
NORTH
AMERICA
­

RESERVE
0
3,288.07
$
98,281
$
136,767
$
(
38,487)
$
339,130
$
(
38,487)
5362
0.00%

6
z
0
5362
0.00%

495
76
6
VINCENTIAN
HOME
INC.
(
SENIOR
RESIDENCE
HOME)
0
136.62
$
8,146
$
22,448
$
(
14,301)
$
165,784
$
(
14,301)
12.8
­
0.11%

6
z
0
12.8
­
0.11%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
14
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
142
77
6
ENVIRONMENTAL
SOLUTIONS
LLC
0
3,288.07
$
195,805
$
136,767
$
59,038
$
339,130
$
59,038
516.2
0.01%

6
z
0
516.2
0.01%

4
78
7
UNIV
CAL,
RIVERSIDE
2
710.82
$
24,744
$
62,826
$
(
38,082)
$
197,368
$
(
38,082)
15121
0.00%

7
z
2
15121
0.00%

8
79
7
KANSAS
UNIVERSITY
MEDICAL
CENTER
2
26.25
$
1,204
$
4,313
$
(
3,109)
$
159,713
$
(
3,109)
529.6
0.00%

7
z
2
529.6
0.00%

200
80
7
COLORADO
STATE
UNIV
2
507.73
$
9,454
$
56,435
$
(
46,981)
$
186,197
$
(
46,981)
562.9
­
0.01%

7
z
2
562.9
­
0.01%

399
81
7
TEXAS
A
&
M
UNIVERSITY
2
1,366.16
$
38,321
$
82,439
$
(
44,118)
$
233,415
$
(
44,118)
394.1
­
0.01%

7
z
2
394.1
­
0.01%

409
82
7
UC­
DAVIS
2
710.82
$
249
$
62,826
$
(
62,577)
$
197,368
$
(
62,577)
15121
0.00%

7
z
2
15121
0.00%

410
83
7
UCSD/
CAMPUS
2
312.00
$
15,413
$
49,971
$
(
34,558)
$
175,431
$
(
34,558)
15121
0.00%

7
z
2
15121
0.00%

411
84
7
UCSF/
PARNASSUS
2
24.87
$
1,327
$
4,087
$
(
2,760)
$
159,637
$
(
2,760)
15121
0.00%

7
z
2
15121
0.00%

412
85
7
UNIVERSITY
OF
NE
SWINE
RESEARCH
2
10.28
$
346
$
1,688
$
(
1,342)
$
158,834
$
(
1,342)
1336.3
0.00%

7
z
2
1336.3
0.00%

414
86
7
UNIVERSITY
0F
HOUSTON
2
720.00
$
10,217
$
63,109
$
(
52,892)
$
197,873
$
(
52,892)
398
­
0.01%

7
z
2
398
­
0.01%

418
87
7
UNIVERSITY
OF
ALABAMA
AT
BIRMINGHAM
(
INCINERATOR)
2
710.82
$
21,360
$
62,826
$
(
41,465)
$
197,368
$
(
41,465)
461.9
­
0.01%

419
87
7
UNIVERSITY
OF
ALABAMA
AT
BIRMINGHAM
(
INCINERATOR)
2
710.82
$
21,360
$
62,826
$
(
41,465)
$
197,368
$
(
41,465)
461.9
­
0.01%

7
z
2
461.9
­
0.02%

428
88
7
UNL
MANTER
HALL
2
187.20
$
3,235
$
30,759
$
(
27,524)
$
168,566
$
(
27,524)
1336.3
0.00%

7
z
2
1336.3
0.00%

436
89
7
VPI
&
STATE
UNIVERSITY
2
30.00
$
1,319
$
4,929
$
(
3,611)
$
159,919
$
(
3,611)
564.6
0.00%

7
z
2
564.6
0.00%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
15
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
462
90
7
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
2
264.12
$
12,762
$
43,003
$
(
30,240)
$
172,797
$
(
30,240)
564.6
­
0.01%

463
90
7
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
2
728.62
$
35,207
$
63,375
$
(
28,169)
$
198,347
$
(
28,169)
564.6
0.00%

464
90
7
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
2
304.20
$
14,699
$
49,034
$
(
34,335)
$
175,001
$
(
34,335)
564.6
­
0.01%

465
90
7
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
2
391.63
$
18,924
$
52,651
$
(
33,727)
$
179,811
$
(
33,727)
564.6
­
0.01%

7
z
2
564.6
­
0.02%

472
91
7
NORFOLK
INTERNATIONAL
AIRPORT
2
444.64
$
11,538
$
54,394
$
(
42,855)
$
182,727
$
(
42,855)
564.6
­
0.01%

7
z
2
564.6
­
0.01%

42
92
7
ORLANDO
SANFORD
INT'L
AIRPORT
2
349.27
$
14,030
$
51,236
$
(
37,205)
$
177,481
$
(
37,205)
242.6
­
0.02%

7
z
2
242.6
­
0.02%

178
93
7
BOSTON
UNIVERSITY
#
2
2
132.00
$
6,795
$
21,689
$
(
14,894)
$
165,530
$
(
14,894)
1128.94
0.00%

7
z
2
1128.94
0.00%

179
94
7
BOSTON
UNIVERSITY
ENGR
&
SCI
CTR
2
1.00
$
51
$
164
$
(
113)
$
158,324
$
(
113)
1128.94
0.00%

7
z
2
1128.94
0.00%

217
95
7
DUKE
UNIVERSITY
HEATING
PLANT
2
65.59
$
2,720
$
10,777
$
(
8,057)
$
161,877
$
(
8,057)
2407.85
0.00%

7
z
2
2407.85
0.00%

251
96
7
HAMPTON
UNIVERSITY
2
37.52
$
1,000
$
6,165
$
(
5,165)
$
160,333
$
(
5,165)
171
0.00%

7
z
2
171
0.00%

302
97
7
M.
I.
T.
BLDG.
#
56
ANIMAL
CARE
FACILITY
2
273.23
$
14,009
$
44,376
$
(
30,367)
$
173,298
$
(
30,367)
1832.3
0.00%

304
97
7
M.
I.
T.
COLLEGE
OF
HEALTH
SCIENCE
2
444.64
$
22,797
$
54,394
$
(
31,597)
$
182,727
$
(
31,597)
1832.3
0.00%

7
z
2
1832.3
0.00%

344
98
7
PURDUE
UNIVERSITY­
WADE
UTILITY
PLANT
2
683.48
$
32,718
$
61,978
$
(
29,260)
$
195,864
$
(
29,260)
688.8
0.00%

7
z
2
688.8
0.00%

374
99
7
SOUTHERN
RESEARCH
INSTITUTE
2
444.64
$
13,362
$
54,394
$
(
41,032)
$
182,727
$
(
41,032)
75.1
­
0.05%

375
99
7
SOUTHERN
RESEARCH
INSTITUTE
2
444.64
$
13,362
$
54,394
$
(
41,032)
$
182,727
$
(
41,032)
75.1
­
0.05%

7
z
2
75.1
­
0.11%

390
100
7
STANFORD
UNIVERSITY
2
710.82
$
46,111
$
62,826
$
(
16,714)
$
197,368
$
(
16,714)
3743.93
0.00%

7
z
2
3743.93
0.00%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
16
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
415
101
7
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
2
1,639.39
$
88,462
$
90,364
$
(
1,903)
$
248,444
$
(
1,903)
1808.9
0.00%

416
101
7
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
2
1,639.39
$
88,462
$
90,364
$
(
1,903)
$
248,444
$
(
1,903)
1808.9
0.00%

417
101
7
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
2
1,639.39
$
88,462
$
90,364
$
(
1,903)
$
248,444
$
(
1,903)
1808.9
0.00%

7
z
2
1808.9
0.00%

422
102
7
UNIVERSITY
OF
IDAHO,
HOLM
RESEARCH
CENTER
2
444.64
$
26,572
$
54,394
$
(
27,822)
$
182,727
$
(
27,822)
160.9
­
0.02%

7
z
2
160.9
­
0.02%

426
103
7
UNIVERSITY
OF
MARYLAND­
MEDICAL
SCHOOL
TEACHING
FAC
2
655.76
$
47,110
$
61,115
$
(
14,005)
$
194,339
$
(
14,005)
1160
0.00%

7
z
2
1160
0.00%

461
104
7
MARY
WASHINGTON
COLLEGE
2
444.64
$
18,030
$
54,394
$
(
36,363)
$
182,727
$
(
36,363)
37.1
­
0.10%

7
z
2
37.1
­
0.10%

467
105
7
RANDOPH­
MACON
COLLEGE
2
0.04
$
2
$
7
$
(
4)
$
158,271
$
(
4)
29.7
0.00%

7
z
2
29.7
0.00%

473
106
7
LOUDOUN
HOSPITAL
CENTER
­
CORNWALL
CAMPUS
2
444.64
$
25,794
$
54,394
$
(
28,600)
$
182,727
$
(
28,600)
46
­
0.06%

7
z
2
46
­
0.06%

474
107
7
MWAA
­
WASHINGTON
DULLES
INTERNATIONAL
AIRPORT
2
109.29
$
6,822
$
17,958
$
(
11,136)
$
164,281
$
(
11,136)
442.2
0.00%

7
z
2
442.2
0.00%

475
108
7
BRIDGEWATER
COLLEGE
2
444.64
$
14,762
$
54,394
$
(
39,632)
$
182,727
$
(
39,632)
25.3
­
0.16%

7
z
2
25.3
­
0.16%

496
109
7
DUKE
UNIVERSITY
HEATING
PLANT
2
507.73
$
21,447
$
56,435
$
(
34,988)
$
186,197
$
(
34,988)
2407.85
0.00%

7
z
2
2407.85
0.00%

124
110
3
SMITH
ISLAND
INCINERATOR
1
123.59
$
6,073
$
20,307
$
(
14,234)
$
165,067
$
(
14,234)
52.006
­
0.03%

3
z
1
52.006
­
0.03%

134
111
4
CITY
OF
AURORA
0
260.00
$
12,995
$
42,380
$
(
29,385)
$
172,570
$
(
29,385)
183.863
­
0.02%

4
z
0
183.863
­
0.02%

150
112
3
SHELBY
COUNTY
COMMUNITY
SERVICES
1
3,182.01
$
148,918
$
133,830
$
15,088
$
333,295
$
15,088
7.048
0.21%

3
z
1
7.048
0.21%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
17
turning
knowledge
into
practice
Table
4.
Estimated
Compliance
Costs
Based
on
Medium
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI_

ID
Owner
ID
Owner
Type
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
391
113
6
STEEPMEADOW
CLUB
INC
1
710.82
$
19,398
$
62,826
$
(
43,427)
$
197,368
$
(
43,427)
0.081
­
53.61%

6
z
1
0.081
­
53.61%

424
114
7
UNIVERSITY
OF
ILLINOIS
2
710.82
$
36,224
$
62,826
$
(
26,602)
$
197,368
$
(
26,602)
2405.6
0.00%

7
z
2
2405.6
0.00%

209
115
7
DARTMOUTH
COLLEGE
2
36.00
$
2,882
$
5,915
$
(
3,033)
$
160,249
$
(
3,033)
568.7
0.00%

7
z
2
568.7
0.00%

420
116
7
UNIVERSITY
OF
ALASKA
2
710.82
$
42,635
$
62,826
$
(
20,190)
$
197,368
$
(
20,190)
323
­
0.01%

7
z
2
323
­
0.01%

92
$
12
24.00
107
$
679,780
$
161
12
10
Nickerson
Memorandum
3
September
12,
2005
Page
18
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
1
1
NAVAL
AIR
WEAPONS
STATION
0
41.00
1,232
6,737
(
5,505)
160,524
(
5,505)
1853000.2
0.00%

9
1
NATIONAL
SECURITY
AGENCY
0
681.36
47,007
61,912
(
14,905)
195,747
(
14,905)
1853000.2
0.00%

10
1
NATIONAL
SECURITY
AGENCY
0
641.28
44,242
60,663
(
16,421)
193,543
(
16,421)
1853000.2
0.00%

11
1
NAVAL
SURFACE
WARFARE
CNTRINDIAN
HD
0
150.30
7,826
24,696
(
16,870)
166,536
(
16,870)
1853000.2
0.00%

12
1
NAVAL
SURFACE
WARFARE
CNTRINDIAN
HD
0
150.30
7,826
24,696
(
16,870)
166,536
(
16,870)
1853000.2
0.00%

18
1
MALMSTROM
AFB
0
1,900.08
56,679
97,840
(
41,161)
262,783
(
41,161)
1853000.2
0.00%

19
1
LOS
ALAMOS
NATIONAL
LABORATORY
0
1,823.64
24,200
95,656
(
71,456)
258,578
(
71,456)
1853000.2
0.00%

20
1
US
DEPARTMENT
OF
THE
ARMY
0
1,823.64
41,524
95,656
(
54,131)
258,578
(
54,131)
1853000.2
0.00%

21
1
TINKER
AFB
US
AIR
FORCE
LOGISTICS
CTR
0
44.10
910
7,246
(
6,336)
160,695
(
6,336)
1853000.2
0.00%

23
1
US
NAVY:
WEAPONS
STATION
0
16.40
569
2,695
(
2,125)
159,171
(
2,125)
1853000.2
0.00%

24
1
US
AIRFORCE:
CHARLESTON
AFB
0
8.52
256
1,400
(
1,144)
158,738
(
1,144)
1853000.2
0.00%

25
1
US
AIRFORCE:
SHAW
AFB
0
0.47
20
76
(
57)
158,295
(
57)
1853000.2
0.00%

26
1
MAIN
BASE
0
1,823.64
48,655
95,656
(
47,001)
258,578
(
47,001)
1853000.2
0.00%

93
1
US
ARMY
­
FORT
BELVOIR
0
127.00
7,022
20,868
(
13,846)
165,255
(
13,846)
1853000.2
0.00%

122
1
NAVY
SALVAGE
FUEL
BOILER
PLANT
0
7,740.20
183,520
257,434
(
73,914)
584,019
(
73,914)
1853000.2
0.00%

152
1
101ST
AIRBORNE
DIV./
FORT
CAMPBELL
0
393.12
18,284
52,700
(
34,416)
179,893
(
34,416)
1853000.2
0.00%

153
1
88
ABW/
EMP
0
1,528.80
54,135
87,169
(
33,034)
242,361
(
33,034)
1853000.2
0.00%

290
1
LAUGHLIN
AIR
FORCE
BASE
0
436.80
11,641
54,138
(
42,497)
182,295
(
42,497)
1853000.2
0.00%

322
1
NAVAL
SECURITY
GRP
ACTIVITYWINTER
HBR
0
406.22
37,990
53,133
(
15,143)
180,613
(
15,143)
1853000.2
0.00%

323
1
NAVAL
SECURITY
GRP
ACTIVITYWINTER
HBR
0
406.22
37,990
53,133
(
15,143)
180,613
(
15,143)
1853000.2
0.00%

324
1
NAVAL
SURFACE
WARFARE
CENTER
CRANE
0
1,823.64
63,663
95,656
(
31,992)
258,578
(
31,992)
1853000.2
0.00%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
19
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
340
1
PETERSON
AFB
21CES
CEV
0
1,310.40
35,774
80,807
(
45,033)
230,348
(
45,033)
1853000.2
0.00%

408
1
U.
S.
ARMY
AIR
DEFENSE
ART
0
327.60
9,055
50,503
(
41,448)
176,289
(
41,448)
1853000.2
0.00%

431
1
US
MILITARY
ACADEMY
0
1,823.64
71,706
95,656
(
23,950)
258,578
(
23,950)
1853000.2
0.00%

432
1
USAF
CLEAR
0
1,823.64
150,286
95,656
54,631
258,578
54,631
1853000.2
0.00%

471
1
US
DEPARTMENT
OF
JUSTICE
FBI
0
87.36
3,924
14,354
(
10,430)
163,074
(
10,430)
1853000.2
0.00%

498
1
NAVAL
SECURITY
GROUP
ACTIVITY
0
276.64
12,554
44,890
(
32,336)
173,486
(
32,336)
1853000.2
0.00%

0
1853000.2
0.00%

2
2
CALIF.
DEPT.
OF
FOOD
&
AG.
0
521.04
15,240
56,861
(
41,621)
186,929
(
41,621)
151245.39
0.00%

3
2
CALIF.
DEPT.
OF
FOOD
&
AG.
0
1,823.64
53,341
95,656
(
42,314)
258,578
(
42,314)
151245.39
0.00%

186
2
CALIF
CORRECTIONAL
CENTER
0
436.80
10,068
54,138
(
44,069)
182,295
(
44,069)
151245.39
0.00%

0
151245.39
­
0.0001%

22
3
PA
DEPT
OF
CORR/
DALLAS
SCI
0
200.94
13,499
33,017
(
19,518)
169,322
(
19,518)
46.164524
­
0.04%

0
46.164524
­
0.04%

97
4
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
2
1,823.64
72,800
95,656
(
22,856)
258,578
(
22,856)
1905.8
0.00%

98
4
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
2
1,823.64
72,800
95,656
(
22,856)
258,578
(
22,856)
1905.8
0.00%

99
4
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
2
1,823.64
72,800
95,656
(
22,856)
258,578
(
22,856)
1905.8
0.00%

100
4
WIS
DOA
/
UW
MADISON­­
CHARTER
ST
HEATING
PLANT
2
1,823.64
72,800
95,656
(
22,856)
258,578
(
22,856)
1905.8
0.00%

101
4
UNIVERSITY
OF
WISCONSIN
(
MAD)

SAFETY
DEPT
2
2,568.38
103,249
116,731
(
13,482)
299,543
(
13,482)
1905.8
0.00%

2
1905.8
­
0.01%

299
5
LOUISIANA
STATE
PENITENTIARY
0
6,552.00
289,926
225,579
64,347
518,662
64,347
18078.549
0.00%

0
18078.549
0.0004%

309
6
MARYLAND
DEPARTMENT
OF
HEARTH
&
MENTAL
HYGIENE­
PUB
0
436.80
31,594
54,138
(
22,544)
182,295
(
22,544)
20787.889
0.00%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
20
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
0
20787.889
­
0.0001%

325
7
NE
GAME
&
PARKS
COMMISSION
0
1,823.64
33,300
95,656
(
62,356)
258,578
(
62,356)
6001.93
0.00%

0
6001.93
­
0.001%

439
8
WASH
STATE
PARK
&
RECREATION
COMM
0
1,823.64
123,971
95,656
28,315
258,578
28,315
23.813123
0.12%

0
23.813123
0.12%

499
9
WVDEP­
OFFICE
OF
WASTE
MANAGEMENT
0
1,823.64
82,793
95,656
(
12,862)
258,578
(
12,862)
9130.217
0.00%

0
9130.217
­
0.0001%

38
10
LA
CO.,
SANITATION
DIST
0
7,144.80
239,922
241,494
(
1,572)
551,269
(
1,572)
14788.208
0.00%

0
14788.208
­
0.00001
%

120
11
CARTER
COUNTY
AIR
CURTAIN
DESTRUCTION
0
7,740.20
290,645
257,434
33,210
584,019
33,210
50.3
0.07%

0
50.3
0.07%

285
12
KALAMAOO
VALLEY
COMM
CO
0
2,620.80
116,652
118,200
(
1,548)
302,426
(
1,548)
128.219
0.00%

0
128.219
0.00%

293
13
ELGIN
CUMMUNITY
COLLEGE
0
873.60
40,474
67,809
(
27,335)
206,321
(
27,335)
162.049
­
0.02%

0
162.049
­
0.02%

470
14
HENRICO
COUNTY
POLICE
0
1,823.64
82,173
95,656
(
13,482)
258,578
(
13,482)
694.602
0.00%

0
694.602
­
0.002%

484
15
MERCER
COUNTY
VO­
TECH
0
1,823.64
76,246
95,656
(
19,409)
258,578
(
19,409)
47.2
­
0.04%

0
47.2
­
0.04%

500
16
HUNTINGTON
SANITARY
BOARD
0
1,823.64
76,757
95,656
(
18,899)
258,578
(
18,899)
50.196
­
0.04%

0
50.196
­
0.04%

121
17
CITY
OF
ALCOA
INCINERATOR
1
7,740.20
201,787
257,434
(
55,647)
584,019
(
55,647)
18.228347
­
0.31%

1
18.228347
­
0.31%

129
18
CITY
OF
SOUTHSIDE
PLACE
INCINERATOR
1
4,225.00
69,121
162,533
(
93,412)
390,665
(
93,412)
1.3142026
­
7.11%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
21
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
1
1.3142026
­
7.11%

130
19
TOWN
OF
READSBORO
INCINERATOR
1
4,225.00
245,135
162,533
82,601
390,665
82,601
1.0238136
8.07%

1
1.0238136
8.07%

132
20
SILOAM
SPRINGS
1
7,436.00
278,701
249,295
29,406
567,286
29,406
15.942355
0.18%

1
15.942355
0.18%

138
21
CITY
OF
LUFKIN
1
7,740.20
179,573
257,434
(
77,862)
584,019
(
77,862)
40.987
­
0.19%

1
40.987
­
0.19%

139
22
CITY
OF
NORFOLK
WASTE
FACILITY
1
6.61
305
1,086
(
781)
158,633
(
781)
35.129827
0.00%

1
35.129827
0.00%

140
23
CITY
OF
SULPHUR
SPRINGS
1
7,740.20
316,110
257,434
58,675
584,019
58,675
14.231539
0.41%

1
14.231539
0.41%

143
24
OSSIPEE
INCINERATOR
FACILITY
1
5,070.00
302,476
185,554
116,922
437,144
116,922
9.2802258
1.26%

1
9.2802258
1.26%

144
25
TOWN
OF
CANDIA
1
5,070.00
309,219
185,554
123,666
437,144
123,666
8.6377149
1.43%

1
8.6377149
1.43%

145
26
TOWN
OF
LITCHFIELD
INCINERATOR
&

RECYCLING
FACILITY
1
7,774.00
668,719
258,338
410,381
585,878
410,381
16.277674
2.52%

1
16.277674
2.52%

146
27
WILTON
RECYCLING
CENTER
1
10,140.00
855,208
321,326
533,882
716,020
533,882
8.2298411
6.49%

1
8.2298411
6.49%

149
28
HEBRON
BRIDGEWATER
REFUSE
DISTRICT
1
4,867.20
260,152
180,044
80,108
425,989
80,108
2.1468197
3.73%

1
2.1468197
3.73%

6
29
GRAYSLAKE
COMMUNITY
HIGH
SCHOOL
127
1
1,252.50
45,353
79,108
(
33,755)
227,163
(
33,755)
6.1
­
0.55%

1
6.1
­
0.55%

45
30
GROSS
SCHOOL­
DIST
95
1
1,002.00
44,108
71,678
(
27,570)
213,384
(
27,570)
3.2
­
0.86%

1
3.2
­
0.86%

57
31
DIEKMAN
SCHOOL
­
DISTRICT
149
1
1,002.00
38,908
71,678
(
32,770)
213,384
(
32,770)
12.2
­
0.27%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
22
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
1
12.2
­
0.27%

58
32
BERGER­
VANDENBERG
SCHOOL
1
1,202.40
46,858
77,632
(
30,775)
224,407
(
30,775)
12.2
­
0.25%

1
12.2
­
0.25%

66
33
MARQUARDT
SCHOOL­
DISTRICT
15
1
1,152.30
59,770
76,152
(
16,382)
221,651
(
16,382)
10.7
­
0.15%

1
10.7
­
0.15%

69
34
JACKSON
JUNIOR
HIGH
SCHOOL
1
1,302.60
59,972
80,579
(
20,607)
229,919
(
20,607)
17.3
­
0.12%

1
17.3
­
0.12%

72
35
PIONEER
SCHOOL
1
1,252.50
61,109
79,108
(
17,998)
227,163
(
17,998)
16
­
0.11%

1
16
­
0.11%

79
36
TRIOPIA
HIGH
SCHOOL
­
DISTRICT
27
1
1,302.60
60,024
80,579
(
20,555)
229,919
(
20,555)
1.9
­
1.08%

1
1.9
­
1.08%

89
37
FREEPORT
SCHOOL
DISTRICT
145
­

EMPIRE
SCHOOL
1
1,252.50
47,169
79,108
(
31,939)
227,163
(
31,939)
17
­
0.19%

1
17
­
0.19%

90
38
CARL
SANDBURG
SCHOOL
­
DISTRICT
145
1
926.85
34,905
69,419
(
34,514)
209,250
(
34,514)
17
­
0.20%

1
17
­
0.20%

91
39
ROCK
FALLS
TOWNSHIP
HIGH
SCHOOL
1
1,002.00
30,922
71,678
(
40,756)
213,384
(
40,756)
3.5
­
1.16%

1
3.5
­
1.16%

165
40
ATHENS
AREA
SCHOOL
DISTRICT
1
873.60
55,080
67,809
(
12,728)
206,321
(
12,728)
12.3
­
0.10%

1
12.3
­
0.10%

184
41
BURRELL
SCHOOL
DISTRICT
1
1,419.60
99,769
83,997
15,772
236,354
15,772
8.9
0.18%

1
8.9
0.18%

195
42
CHATTERTON
JR
HIGH
SCHOOL
1
1,747.20
73,417
93,465
(
20,048)
254,374
(
20,048)
13.3
­
0.15%

1
13.3
­
0.15%

234
117
FITGERALD
HIGH
SCHOOL
1
349.44
14,659
51,241
(
36,582)
177,490
(
36,582)
13.3
­
0.28%

1
13.3
­
0.28%

437
43
WALDRON
AREA
SCHOOLS
1
364.00
20,803
51,730
(
30,928)
178,291
(
30,928)
1.8
­
1.72%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
23
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
469
43
POWHATAN
HIGH
SCHOOL
1
1,823.64
92,386
95,656
(
3,270)
258,578
(
3,270)
13.8
­
0.02%

1
15.6
­
0.22%

476
44
HOLLIDAYSBURG
AREA
SCHOOL
DISTRICT
1
145.60
9,010
23,924
(
14,914)
166,278
(
14,914)
18.2
­
0.08%

1
18.2
­
0.08%

477
45
FOREST
HILLS
SCHOOL
DISTRICT
(
ELE/
HI)
1
800.80
41,762
65,592
(
23,831)
202,317
(
23,831)
9.2
­
0.26%

480
45
FOREST
HILLS
SCHOOL
DISTRICT
(
ELE)
1
72.80
3,797
11,962
(
8,165)
162,273
(
8,165)
9.2
­
0.09%

1
9.2
­
0.35%

479
46
NORTHERN
CAMBRIA
SCHOOL
DISTRICT
(
ELE/
MI)
1
728.00
37,507
63,356
(
25,850)
198,313
(
25,850)
6.1
­
0.42%

1
6.1
­
0.42%

481
47
CARMICHAELS
AREA
SCHOOL
DISTRICT
1
320.32
15,292
50,255
(
34,963)
175,888
(
34,963)
5.5
­
0.64%

482
47
CARMICHAELS
AREA
SCHOOL
DISTRICT
1
291.20
13,902
47,081
(
33,179)
174,286
(
33,179)
5.5
­
0.60%

1
5.5
­
1.24%

483
48
PURCHASE
LINE
SCHOOL
DISTRICT
(
JR/
SR/
ELE)
1
1,823.64
97,911
95,656
2,256
258,578
2,256
6.1
0.04%

1
6.1
0.04%

485
49
TRINITY
AREA
SCHOOL
DISTRICT
1
72.80
3,660
11,962
(
8,302)
162,273
(
8,302)
18
­
0.05%

1
18
­
0.05%

486
50
BURRELL
SCHOOL
DISTRICT
(
ELE)
1
473.20
33,256
55,322
(
22,065)
184,297
(
22,065)
8.9
­
0.25%

1
8.9
­
0.25%

487
51
HEMPFIELD
AREA
SCHOOL
DISTRICT
(
SR.
HIGH)
1
436.80
22,871
54,138
(
31,267)
182,295
(
31,267)
32.1
­
0.10%

488
51
HEMPFIELD
AREA
SCHOOL
DISTRICT
(
SR.
HIGH)
1
436.80
22,871
54,138
(
31,267)
182,295
(
31,267)
32.1
­
0.10%

1
0.00%

490
52
ELIZABETH
FORWARD
SCHOOL
DISTRICT
­
MIDDLE
SCHOOL
INCINERATOR
1
262.08
14,021
42,694
(
28,673)
172,685
(
28,673)
13.2
­
0.22%

1
13.2
­
0.22%

491
53
KEYSTONE
OAKS
SCHOOL
DISTRICT
­

HIGH
SCHOOL
INCINERATOR
1
436.80
23,661
54,138
(
30,476)
182,295
(
30,476)
14.4
­
0.21%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
24
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
1
14.4
­
0.21%

39
54
SEAGULL
SANITATION
1
5,954.00
376,948
209,474
167,474
485,769
167,474
1.75
9.57%

1
1.75
9.57%

307
55
MARIAN
MANOR
HEALTHCARE
CENTER
2
43.68
1,141
7,177
(
6,036)
160,672
(
6,036)
2.4
­
0.25%

2
2.4
­
0.25%

497
56
GRANT
COUNTY
NURSING
HOME
1
50.96
2,638
8,373
(
5,735)
161,072
(
5,735)
3
­
0.19%

1
3
­
0.19%

61
57
REGINA
DOMINICAN
HIGH
SCHOOL
2
464.40
19,110
55,036
(
35,926)
183,813
(
35,926)
0
0.00%

2
0
0.00%

63
58
MISERICORDIA
SCHOOL
­
NORTH
2
1,302.60
56,689
80,579
(
23,890)
229,919
(
23,890)
0
0.00%

2
0
0.00%

379
59
ST
CLARE
DE
MONTEFALCO
PARISH
2
1,092.00
42,610
74,363
(
31,753)
218,334
(
31,753)
2.1
­
1.51%

2
2.1
­
1.51%

381
60
ST
GERARD
PARISH
2
393.12
14,097
52,700
(
38,603)
179,893
(
38,603)
165.2
­
0.02%

2
165.2
­
0.02%

460
61
PINEY
FOREST
HEALTHCARE
DANVILLE
2
1,823.64
47,141
95,656
(
48,515)
258,578
(
48,515)
9.3
­
0.52%

2
9.3
­
0.52%

489
62
BISHOP
MCCORT
HIGH
SCHOOL
2
1,823.64
93,188
95,656
(
2,468)
258,578
(
2,468)
0
0.00%

2
0
0.00%

492
63
NORTH
CATHOLIC
HIGH
SCHOOL
­

INCINERATOR,
PYRONICS
2
163.80
9,286
26,914
(
17,628)
167,279
(
17,628)
0
0.00%

2
0
0.00%

493
64
SISTERS
OF
THE
HOLY
SPIRIT
2
68.25
3,926
11,214
(
7,288)
162,023
(
7,288)
1.2
­
0.61%

2
1.2
­
0.61%

494
65
ST.
ANGELA
MERICI
PARISH
2
87.36
4,937
14,354
(
9,418)
163,074
(
9,418)
0.16
­
5.89%

2
0.16
­
5.89%

159
66
ALPENA
COMM
COLLEGE
2
873.60
34,481
67,809
(
33,328)
206,321
(
33,328)
42
­
0.08%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
25
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
2
42
­
0.08%

274
67
JEFFERS
HIGH
SCHOOL
1
1,823.64
134,457
95,656
38,801
258,578
38,801
2.1
1.85%

1
2.1
1.85%

17
68
KIRKSVILLE
COLLEGE
OF
OSTEOPATHIC
MEDICI­
COLLEGE
2
521.04
10,233
56,861
(
46,628)
186,929
(
46,628)
0
0.00%

2
0
0.00%

46
69
GOODWIN
ELEM
SCHOOL
0
1,002.00
41,513
71,678
(
30,165)
213,384
(
30,165)
36.8
­
0.08%

48
69
WOODBINE
SCHOOL­
DISTRICT
99
0
1,002.00
40,671
71,678
(
31,006)
213,384
(
31,006)
36.8
­
0.08%

49
69
SHERLOCK
SCHOOL
0
1,002.00
41,232
71,678
(
30,445)
213,384
(
30,445)
36.8
­
0.08%

52
69
DREXEL
SCHOOL
DISTRICT
99
0
1,002.00
40,741
71,678
(
30,936)
213,384
(
30,936)
36.8
­
0.08%

53
69
COLUMBUS
SCHOOL
DISTRICT
99
0
1,002.00
40,882
71,678
(
30,796)
213,384
(
30,796)
36.8
­
0.08%

55
69
MCKINLEY
SCHOOL
0
1,002.00
42,004
71,678
(
29,674)
213,384
(
29,674)
36.8
­
0.08%

56
69
LINCOLN
SCHOOL
­
DISTRICT
99
0
1,002.00
41,373
71,678
(
30,305)
213,384
(
30,305)
36.8
­
0.08%

501
69
CICERO­
EAST
SCHOOL­
DIST
99
0
50.00
2,054
8,216
(
6,162)
161,019
(
6,162)
36.8
­
0.02%

0
36.8
­
0.60%

81
70
SPRINGFIELD
PUBLIC
SCHOOLS
DISTRICT
186
0
1,252.50
53,281
79,108
(
25,827)
227,163
(
25,827)
60.1
­
0.04%

82
70
SPRINGFIELD
HIGH
SCHOOL
­
DISTRICT
186
0
901.80
38,173
68,663
(
30,489)
207,873
(
30,489)
60.1
­
0.05%

83
70
WASHINGTON
MIDDLE
SCHOOL
­

DISTRICT
186
0
901.80
38,615
68,663
(
30,048)
207,873
(
30,048)
60.1
­
0.05%

84
70
SOUTHEAST
HIGH
SCHOOL
­
DISTRICT
186
0
901.80
37,416
68,663
(
31,247)
207,873
(
31,247)
60.1
­
0.05%

85
70
LANPHIER
HIGH
SCHOOL
­
DISTRICT
186
0
901.80
38,363
68,663
(
30,300)
207,873
(
30,300)
60.1
­
0.05%

87
70
FRANKLIN
MIDDLE
SCHOOL
­
DISTRICT
186
0
901.80
38,426
68,663
(
30,237)
207,873
(
30,237)
60.1
­
0.05%

0
60.1
­
0.30%

65
71
ADDISON
TRAIL
HIGH
SCHOOLDISTRICT
88
0
1,125.00
50,693
75,343
(
24,651)
220,150
(
24,651)
20.9
­
0.12%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
26
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
0
20.9
­
0.12%

459
72
CONCORD
ELEMENTARY
SCHOOL
0
1,823.64
83,887
95,656
(
11,768)
258,578
(
11,768)
30.1
­
0.04%

0
30.1
­
0.04%

468
73
JOHN
M
GANDY
ELEMENTARY
SCHOOL
0
1,823.64
101,139
95,656
5,483
258,578
5,483
60.7
0.01%

0
60.7
0.01%

116
74
AMPACET
CORPORATION
0
7,740.20
351,095
257,434
93,661
584,019
93,661
609
0.02%

0
609
0.02%

118
75
BFI
WASTE
SYSTEMS
OF
NORTH
AMERICA
­
RESERVE
0
7,740.20
231,355
257,434
(
26,080)
584,019
(
26,080)
5362
0.00%

0
5362
0.00%

495
76
VINCENTIAN
HOME
INC.
(
SENIOR
RESIDENCE
HOME)
0
218.40
13,023
35,886
(
22,863)
170,282
(
22,863)
12.8
­
0.18%

0
12.8
­
0.18%

142
77
ENVIRONMENTAL
SOLUTIONS
LLC
0
7,740.20
460,929
257,434
203,494
584,019
203,494
516.2
0.04%

0
516.2
0.04%

4
78
UNIV
CAL,
RIVERSIDE
2
1,823.64
63,481
95,656
(
32,175)
258,578
(
32,175)
15121
0.00%

2
15121
0.00%

8
79
KANSAS
UNIVERSITY
MEDICAL
CENTER
2
26.25
1,204
4,313
(
3,109)
159,713
(
3,109)
529.6
0.00%

2
529.6
0.00%

200
80
COLORADO
STATE
UNIV
2
1,302.60
24,254
80,579
(
56,324)
229,919
(
56,324)
562.9
­
0.01%

2
562.9
­
0.01%

399
81
TEXAS
A
&
M
UNIVERSITY
2
2,184.00
61,261
105,908
(
44,647)
278,400
(
44,647)
394.1
­
0.01%

2
394.1
­
0.01%

409
82
UC­
DAVIS
2
1,823.64
638
95,656
(
95,017)
258,578
(
95,017)
15121
0.00%

2
15121
0.00%

410
83
UCSD/
CAMPUS
2
312.00
15,413
49,971
(
34,558)
175,431
(
34,558)
15121
0.00%

2
15121
0.00%

411
84
UCSF/
PARNASSUS
2
24.87
1,327
4,087
(
2,760)
159,637
(
2,760)
15121
0.00%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
27
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
2
15121
0.00%

412
85
UNIVERSITY
OF
NE
SWINE
RESEARCH
2
10.28
346
1,688
(
1,342)
158,834
(
1,342)
1336.3
0.00%

2
1336.3
0.00%

414
86
UNIVERSITY
0F
HOUSTON
2
720.00
10,217
63,109
(
52,892)
197,873
(
52,892)
398
­
0.01%

2
398
­
0.01%

418
87
UNIVERSITY
OF
ALABAMA
AT
BIRMINGHAM
(
INCINERATOR)
2
1,823.64
54,800
95,656
(
40,855)
258,578
(
40,855)
461.9
­
0.01%

419
87
UNIVERSITY
OF
ALABAMA
AT
BIRMINGHAM
(
INCINERATOR)
2
1,823.64
54,800
95,656
(
40,855)
258,578
(
40,855)
461.9
­
0.01%

2
461.9
­
0.02%

428
88
UNL
MANTER
HALL
2
187.20
3,235
30,759
(
27,524)
168,566
(
27,524)
1336.3
0.00%

2
1336.3
0.00%

436
89
VPI
&
STATE
UNIVERSITY
2
30.00
1,319
4,929
(
3,611)
159,919
(
3,611)
564.6
0.00%

2
564.6
0.00%

462
90
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
2
422.24
20,403
53,661
(
33,258)
181,494
(
33,258)
564.6
­
0.01%

463
90
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
2
1,164.80
56,283
76,522
(
20,239)
222,339
(
20,239)
564.6
0.00%

464
90
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
2
486.30
23,498
55,745
(
32,247)
185,018
(
32,247)
564.6
­
0.01%

465
90
UNIVERSITY
OF
VIRGINIA
­
MEDICAL
CENTER
2
626.08
30,252
60,187
(
29,935)
192,707
(
29,935)
564.6
­
0.01%

2
564.6
­
0.02%

472
91
NORFOLK
INTERNATIONAL
AIRPORT
2
1,823.64
47,323
95,656
(
48,332)
258,578
(
48,332)
564.6
­
0.01%

2
564.6
­
0.01%

42
92
ORLANDO
SANFORD
INT'L
AIRPORT
2
349.27
14,030
51,236
(
37,205)
177,481
(
37,205)
242.6
­
0.02%

2
242.6
­
0.02%

178
93
BOSTON
UNIVERSITY
#
2
2
132.00
6,795
21,689
(
14,894)
165,530
(
14,894)
1128.938
0.00%

2
1128.938
0.00%

179
94
BOSTON
UNIVERSITY
ENGR
&
SCI
CTR
2
1.00
51
164
(
113)
158,324
(
113)
1128.938
0.00%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
28
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
2
1128.938
0.00%

217
95
DUKE
UNIVERSITY
HEATING
PLANT
2
65.59
2,720
10,777
(
8,057)
161,877
(
8,057)
2407.848
0.00%

2
2407.848
0.00%

251
96
HAMPTON
UNIVERSITY
2
37.52
1,000
6,165
(
5,165)
160,333
(
5,165)
171
0.00%

2
171
0.00%

302
97
M.
I.
T.
BLDG.
#
56
ANIMAL
CARE
FACILITY
2
436.80
22,395
54,138
(
31,743)
182,295
(
31,743)
1832.3
0.00%

304
97
M.
I.
T.
COLLEGE
OF
HEALTH
SCIENCE
2
1,823.64
93,498
95,656
(
2,158)
258,578
(
2,158)
1832.3
0.00%

2
1832.3
0.00%

344
98
PURDUE
UNIVERSITY­
WADE
UTILITY
PLANT
2
1,753.50
83,940
93,646
(
9,706)
254,720
(
9,706)
688.8
0.00%

2
688.8
0.00%

374
99
SOUTHERN
RESEARCH
INSTITUTE
2
1,823.64
54,800
95,656
(
40,855)
258,578
(
40,855)
75.1
­
0.05%

375
99
SOUTHERN
RESEARCH
INSTITUTE
2
1,823.64
54,800
95,656
(
40,855)
258,578
(
40,855)
75.1
­
0.05%

2
75.1
­
0.11%

390
100
STANFORD
UNIVERSITY
2
1,823.64
118,300
95,656
22,644
258,578
22,644
3743.926
0.00%

2
3743.926
0.00%

415
101
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
2
2,620.80
141,418
118,200
23,219
302,426
23,219
1808.9
0.00%

416
101
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
2
2,620.80
141,418
118,200
23,219
302,426
23,219
1808.9
0.00%

417
101
UNIVERSITY
OF
ROCHESTER
(
STRONG
MEMORIAL
HOSP.)
2
2,620.80
141,418
118,200
23,219
302,426
23,219
1808.9
0.00%

2
1808.9
0.00%

422
102
UNIVERSITY
OF
IDAHO,
HOLM
RESEARCH
CENTER
2
1,823.64
108,981
95,656
13,325
258,578
13,325
160.9
0.01%

2
160.9
0.01%

426
103
UNIVERSITY
OF
MARYLAND­
MEDICAL
SCHOOL
TEACHING
FAC
2
1,048.32
75,311
73,062
2,249
215,932
2,249
1160
0.00%

2
1160
0.00%

461
104
MARY
WASHINGTON
COLLEGE
2
1,823.64
73,949
95,656
(
21,707)
258,578
(
21,707)
37.1
­
0.06%

(
continued)
Nickerson
Memorandum
3
September
12,
2005
Page
29
turning
knowledge
into
practice
Table
5.
Estimated
Compliance
Costs
Based
on
High­
End
Throughput,
and
Cost­
to­
Revenue
Ratio
(
CRR)
(
continued)

Compliance
Costs
RTI
_
ID
Entity
OSWI
Name
Small
Entity
Medium
Annual
Q
(
tpy)
LF
Disposal
Costs
($/
yr)
Incinerator
Oper.
Costs
($/
yr)
Option
1
Landfill
($/
yr)
Option
2
Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Revenue
(
MM$)
CRR
2
37.1
­
0.06%

467
105
RANDOPH­
MACON
COLLEGE
2
0.04
2
7
(
4)
158,271
(
4)
29.7
0.00%

2
29.7
0.00%

473
106
LOUDOUN
HOSPITAL
CENTER
­

CORNWALL
CAMPUS
2
1,823.64
105,789
95,656
10,134
258,578
10,134
46
0.02%

2
46
0.02%

474
107
MWAA
­
WASHINGTON
DULLES
INTERNATIONAL
AIRPORT
2
174.72
10,906
28,709
(
17,803)
167,879
(
17,803)
442.2
0.00%

2
442.2
0.00%

475
108
BRIDGEWATER
COLLEGE
2
1,823.64
60,545
95,656
(
35,111)
258,578
(
35,111)
25.3
­
0.14%

2
25.3
­
0.14%

496
109
DUKE
UNIVERSITY
HEATING
PLANT
2
1,302.60
55,022
80,579
(
25,557)
229,919
(
25,557)
2407.848
0.00%

2
2407.848
0.00%

124
110
SMITH
ISLAND
INCINERATOR
1
155.48
7,640
25,547
(
17,907)
166,821
(
17,907)
52.006
­
0.03%

1
52.006
­
0.03%

134
111
CITY
OF
AURORA
0
260.00
12,995
42,380
(
29,385)
172,570
(
29,385)
183.863
­
0.02%

0
183.863
­
0.02%

150
112
SHELBY
COUNTY
COMMUNITY
SERVICES
1
5,954.00
278,647
209,474
69,174
485,769
69,174
7.048
0.98%

1
7.048
0.98%

391
113
STEEPMEADOW
CLUB
INC
1
1,823.64
49,767
95,656
(
45,889)
258,578
(
45,889)
0.081
­
56.65%

1
0.081
­
56.65%

424
114
UNIVERSITY
OF
ILLINOIS
2
1,823.64
92,933
95,656
(
2,723)
258,578
(
2,723)
2405.6
0.00%

2
2405.6
0.00%

209
115
DARTMOUTH
COLLEGE
2
36.00
2,882
5,915
(
3,033)
160,249
(
3,033)
568.7
0.00%

2
568.7
0.00%

420
116
UNIVERSITY
OF
ALASKA
2
1,823.64
109,382
95,656
13,726
258,578
13,726
323
0.00%

2
323
0.00%
TO:
William
Nickerson,
EPA
THROUGH:
Gayle
Kline,
ICF
FROM:
Tom
Holloway
Jeff
Coburn
DATE:
October
16,
2005
SUBJECT:
Memorandum
4.
Additional
Reasons
Why
Landfilling
May
Be
Infeasible
for
Small
Entities
Background
In
previous
memoranda,
RTI
has
determined
the
universe
of
small
entities
in
the
other
solid
waste
incinerator
(
OSWI)
industry,
determined
their
landfill
alternatives
based
on
location,
and
estimated
the
costs
of
switching
from
incineration
to
landfilling.
The
purpose
of
this
memorandum
is
to
present
other
reasons
RTI
has
identified
that
would
make
it
infeasible
or
more
costly
for
these
small
entities
to
send
waste
to
a
landfill
rather
than
incinerating
it.

Additional
Reasons
Landfilling
Infeasible
Based
on
RTI's
contacts
with
nine
small
entities
and
public
comments
on
the
proposed
rule,
RTI
has
identified
10
factors
that
mitigate
against
using
landfills
as
an
alternative
to
incineration.
These
factors
are
listed
in
Table
1
below.
Of
these
10
factors,
the
first
6
factors
listed
below
are
expected
to
be
the
most
applicable
to
the
small
entities
RTI
has
identified,
since
they
are
based
primarily
on
actual
contacts
with
nine
of
these
small
entities.
The
final
4
factors,
based
on
information
from
Alaskan
government
and
industry,
are
believed
to
be
more
applicable
to
facilities
in
Alaska
and
similar
less
developed
areas.
Nickerson
Memorandum
4
October
16,
2005
Page
2
Table
1.
Factors
Mitigating
Against
Using
Landfills
Factors
Details
Ref.

Incinerator
operating
costs
 
Very
low
operating
costs
for
simple
incineration
units
(
essentially
the
cost
of
a
match)
1
Hauling
and
landfill
costs
 
In
more
remote
areas,
costs
to
haul
and
landfill
waste
are
more
expensive
1
Wastes
that
cannot
be
landfilled
 
Some
wastes
(
e.
g.,
contraband,
confidential
records,
remains
of
rabid
animals)
cannot
be
landfilled
because
of
issues
of
law
enforcement,
confidentiality,
and
public
health
1
Political
considerations
 
Incinerator
purchased
and
installed
using
funds
specifically
requested
from
the
community
 
Reluctance
to
tell
community
that
the
costly
incinerator
purchased
with
public
funds
will
be
removed,
especially
less
affluent
community
with
limited
funds
1
Pollution
 
Landfills
run
high
risk
of
leakages
to
air
(
e.
g.,
methane
offgassing),
water,
and
soil
(
including
groundwater)

 
Incinerator
shutdown
could
encourage
burning
in
burn
barrels,
resulting
in
more
air
pollution
 
Windblown
litter
1,2,3
Landfill
issues
 
Landfills
consume
a
lot
of
space
 
New
landfills
not
being
sited
because
of
limited
space,
public
opposition
 
Existing
landfills
filling
up,
getting
more
expensive
1,2,3
Harsh
winter
climate,
lack
of
electrical
power
 
At
extremely
low
temperatures
(
40
below
zero),
mechanical
equipment
at
landfill
is
hard
to
start,
hydraulic
hoses
break,
and
fuel
freezes
 
Electrical
power
not
available
at
landfill
site
 
Some
incinerators
can
be
operated
without
heavy
equipment,
diesel,
propane,
or
electricity
3
Waste
management
 
No
local
government
and,
therefore,
no
organized
waste
management
 
Limited
budget
to
pay
for
sanitation
services
 
Landfill
cannot
be
properly
located,
operated,
closed,
or
monitored
 
Unavailability
of
quality
cover
material
3,4
Transportation
of
waste
 
No
viable
waste
transportation
options
 
Not
connected
to
road
system
 
During
summer
months,
ground
thaw
makes
transportation
of
waste
difficult
 
Have
to
ship
waste
out
of
state
because
local
ordinances
preclude
acceptance
of
waste
generated
outside
their
locale
4,5
Animal
attraction
to
waste
 
Increased
animal
hazing
 
Spread
of
disease
 
Threats
to
worker
safety
3,4,5
Nickerson
Memorandum
4
October
16,
2005
Page
3
References
1.
Holloway,
T.
and
J.
Coburn.
2005.
Confirmation
of
Potential
Impacts
on
Small
Entities.
Memorandum
submitted
by
RTI
to
W.
Nickerson,
U.
S.
Environmental
Protection
Agency,
Office
of
Policy,
Economics,
and
Innovation,
through
G.
Kline,
ICF.
October
16.
2.
Dijkgraaf,
E.
and
H.
Vollebergh.
2003.
Burn
or
Bury?
A
Social
Cost
Comparison
of
Final
Waste
Disposal
Methods.
April.
3.
Burning
Garbage
and
Land
Disposal
in
Rural
Alaska.
2004.
Alaska
Energy
Authority
and
Alaska
Department
of
Environmental
Conservation.
May.
4.
Shrager,
B.
2004.
OSWI 
Documentation
of
Teleconference
with
Representatives
of
the
State
of
Alaska.
Memorandum
submitted
by
EPA
to
project
files.
July
21.
5.
Rutz,
C.
2005.
Comments
on
the
Proposed
Standards
of
Performance
for
New
Stationary
Sources
and
Emission
Guidelines
for
Existing
Sources:
Other
Solid
Waste
Incineration
Units;
Proposed
Rule.
Letter
and
attachment
from
Alyeska
Pipeline
Service
Co.
to
EPA.
February
7.
TO:
William
Nickerson,
EPA
THROUGH:
Gayle
Kline,
ICF
FROM:
Tom
Holloway
Jeff
Coburn
DATE:
October
16,
2005
SUBJECT:
Memorandum
5.
Confirmation
of
Potential
Impacts
on
Small
Entities
I.
Background
On
December
9,
2004,
EPA
proposed
new
source
performance
standards
(
NSPS)
for
other
solid
waste
incinerators
(
OSWIs)
pursuant
to
the
requirements
in
section
129
of
the
Clean
Air
Act
(
CAA).
The
proposed
rule
defines
an
OSWI
as
either
a
very
small
municipal
waste
combustor
(
VSMWC)
or
an
institutional
waste
incinerator
(
IWI).
In
the
preamble
to
the
proposed
rule,
EPA
said
it
expected
the
cost
impacts
of
the
rule
to
be
minimal
because
most
municipalities
and
institutions
would
choose
to
shut
down
their
existing
units
and
select
an
alternative
waste
disposal
method
(
primarily
landfilling),
which
would
result
in
a
negligible
cost
increase
or
even
cost
savings
for
some
units.
In
their
comments
on
the
proposed
rule,
the
Small
Business
Administration
(
SBA)
and
others
expressed
concerns
about
the
accuracy
of
this
conclusion,
especially
regarding
the
potential
impacts
on
small
entities.

At
EPA's
direction,
RTI
reevaluated
EPA's
cost
estimates
for
complying
with
the
proposed
rule
and
switching
to
landfilling,
developed
new
site­
specific
cost
estimates
for
OSWIs
nationwide,
and
identified
nine
small
entities
to
contact
by
telephone
for
further
information.
RTI
identified
those
nine
small
entities
using
criteria
discussed
in
a
previous
memorandum.
1
RTI
also
looked
into
reasons
besides
cost
for
why
landfilling
may
not
be
feasible
for
small
entities.
2
The
purpose
of
this
memorandum
is
to
present
the
results
of
the
telephone
contacts,
determine
the
accuracy
of
RTI's
cost
estimates
and
feasibility
assessments,
and
present
revised
findings
based
on
this
new
information.

II.
Summary
A.
Contacts
The
attachments
to
this
memorandum
provide
detailed
information
on
the
contacts
with
the
nine
small
entities.
Attachment
1
presents
a
list
of
the
facilities
that
were
contacted;
Attachment
2
presents
a
list
of
the
questions
used
during
telephone
contacts
with
the
facilities;
Attachment
3
presents
detailed
profiles
of
the
facilities'
responses
to
the
questions;
Attachment
4
presents
a
tabular
summary
of
the
new
data
(
with
RTI's
original
data
projections
highlighted
in
parentheses);
and
Attachment
5
presents
the
revised
cost
estimates
(
and
supporting
information)
calculated
using
the
new
data
(
with
RTI's
original
cost
estimates
highlighted
in
parentheses).
Nickerson
Memorandum
5
October
16,
2005
Page
2
Of
the
nine
facilities
RTI
contacted,
three
have
already
shut
their
incinerators
down,
and
six
are
still
operating
their
incinerators.
Of
these
six
facilities,
three
plan
to
shut
their
incinerators
down
eventually
(
before
implementation
of
the
OSWI
rule),
one
plans
to
seek
an
exemption
to
the
OSWI
rule,
one
plans
to
comply
with
the
OSWI
rule,
and
one
is
currently
undecided
whether
to
comply
or
shut
down.

For
those
units
still
in
operation,
RTI
inquired
about
actual
waste
throughput,
operating
hours,
and
operating
costs.
Based
on
the
responses,
the
original
estimates
of
daily
waste
throughput
were
overestimated
(
3
to
6
times),
due
to
the
fact
that
capacity
information
was
used
in
the
original
estimates,
rather
than
actual
throughput,
which
was
unavailable
at
the
time.
The
original
estimates
of
operating
hours
were
mostly
overestimated
(
1
to
8
times);
the
original
estimates
were
based
on
averages
for
the
type
of
OSWI
(
VSMWC
or
IWI),
because
actual
information
on
operating
hours
was
unavailable
at
the
time.
The
information
collected
on
operating
costs
was
somewhat
sketchy,
sometimes
provided
for
the
entire
operation,
not
just
the
incinerator.
Operating
costs
for
just
the
incinerator
were
provided
in
only
three
cases;
one
had
practically
zero
cost,
while
the
other
two
had
higher
costs
than
previously
determined,
indicating
RTI's
original
estimates
of
their
operating
costs
were
underestimated
(
30
to
40
percent
of
actual
costs).

Some
of
the
contacts
were
aware
of
the
OSWI
rule
and
noted
that
they
have
several
years
before
the
rule
is
implemented.
Consequently,
they
had
not
yet
completed
any
cost
estimates
for
either
complying
or
landfilling.
Only
one
of
the
facilities
has
an
add­
on
control
device.
The
incinerator
at
this
facility
is
newly
installed,
with
state­
of­
the­
art
equipment,
wet
scrubber,
and
continuous
emissions
monitoring
system
(
CEMS).
One
contact
has
not
yet
made
a
decision
whether
to
install
emission
controls
and
comply
or
shut
down
and
send
waste
to
a
landfill.
Another
contact
expected
to
continue
operating
and
would
apply
for
an
exemption
as
a
rural
IWI,
because
it
is
more
than
50
miles
from
the
border
of
the
nearest
metropolitan
statistical
area
(
MSA).
The
remaining
contacts
still
operating
did
not
believe
they
would
be
able
to
achieve
the
limits
in
the
rule,
and
they
are
planning
to
shut
down
their
incinerators.

In
addition
to
cost
and
compliance
issues,
some
of
the
contacts
cited
encroaching
development,
nuisance
complaints,
and
the
age
of
the
incinerator
as
factors
for
why
they
are
planning
to
shut
down
their
incinerators.

For
those
facilities
which
may
landfill
their
waste
instead
of
incinerate,
RTI's
landfill
determinations
(
location,
cost)
did
not
match
the
responses
from
the
contacts.
Some
of
the
contacts
indicated
they
would
send
the
waste
to
a
transfer
station,
rather
than
directly
to
a
landfill.
Where
contacts
did
provide
landfill
information,
the
landfills
RTI
originally
chose
did
not
match
the
landfills
cited
by
the
contacts.

In
its
original
cost
estimates,
RTI
determined
the
impact
of
switching
to
landfilling
based
on
the
ratio
of
compliance
costs
to
owner
entity
revenues.
To
be
conservative,
RTI
estimated
compliance
costs
under
the
lower
cost
option,
but
based
on
upper­
end
incinerator
throughput.
(
In
each
case,
landfilling
was
the
lower
cost
option.)
RTI
used
the
cost­
to­
revenue
ratio
(
CRR)
Nickerson
Memorandum
5
October
16,
2005
Page
3
for
the
municipality
or
institution
to
narrow
the
list
of
small
entities
to
investigate
further,
in
particular,
those
small
entities
above
a
CRR
of
0.5
percent.
Consequently,
when
RTI
contacted
the
nine
small
entities,
RTI
requested
information
about
the
revenue
for
their
municipality
or
institution.
Based
on
the
information
provided,
the
original
revenue
estimates
for
municipalities
appeared
to
be
overestimated
(
3
to
5
times),
and
the
original
revenue
estimate
for
the
only
institution
among
the
nine
contacted
appeared
to
be
underestimated
(
55
percent
of
actual
revenue).
However,
many
of
the
contacts
were
unable
to
provide
budget
estimates
or
could
not
be
certain
about
the
accuracy
of
their
budget
estimates,
and
RTI
did
not
contact
municipal
or
institutional
administrative
staff
for
more
authoritative
estimates.
Consequently,
RTI
plans
to
use
its
original
revenue
estimates.

The
final
question
to
the
contacts
concerned
whether
there
were
other
factors
besides
cost
that
might
influence
their
decision
to
incinerate
vs.
landfill.
Two
contacts
noted
that
EPA
had
overlooked
the
issue
of
what
to
do
with
the
waste
that
cannot
be
landfilled,
such
as
the
contraband
and
confidential
records
they
receive
from
police
departments,
and
the
materials
they
receive
from
the
Department
of
Fish
&
Game
(
e.
g.,
rabid
animal
remains).
Another
contact
noted
their
very
low
incinerator
operating
costs
(
essentially
the
cost
of
a
match).
A
third
contact
noted
that
their
state­
of­
the­
art
facility
had
been
funded
by
the
citizens
of
their
municipalities,
and
they
did
not
want
to
throw
away
the
substantial
sum
of
money
they
had
already
spent.
Contacts
also
generally
commented
on
environmental
considerations,
the
limited
landfill
space,
and
the
cost
to
haul
and
landfill
waste.
In
summary,
contacts
mentioned
some
of
the
factors
that
RTI
had
already
considered
(
pollution
and
landfill
issues)
and
added
a
few
more
(
wastes
that
cannot
be
landfilled,
low
incinerator
operating
costs,
and
political
considerations).
2
B.
Costs
Based
on
the
information
collected
through
the
telephone
contacts,
new
costs
for
switching
to
landfills
or
complying
with
the
OSWI
rule
requirements
were
developed.
These
costs
were
compared
to
the
original
central­
tendency
costs
calculated
for
these
units.
The
results
of
this
analysis
are
summarized
in
Table
1
and
presented
in
greater
detail
in
Attachment
5
(
with
RTI's
original
estimates
highlighted
in
parentheses).
The
remainder
of
this
section
provides
a
description
of
the
revised
cost
estimates
generated
for
the
OSWI
units
as
a
result
of
the
telephone
contacts.
Nickerson
Memorandum
5
October
16,
2005
Page
4
Table
1.
Original
and
Revised
Costs
Unit
ID
Unit
Name
Original
Costs
(
Central
Tendency)
($/
yr)
Revised
Costs
($/
yr)
Revised
CRR
39
Seagull
Sanitation
Systems
$
67,623
n/
a
n/
a
130
Town
of
Readsboro
Incinerator
$
56,140
n/
a
n/
a
143
Ossipee
Incinerator
Facility
$
83,236
$
28,047
0.30%

144
Town
of
Candia
$
88,595
$
38,803
0.45%

145
Town
of
Litchfield
Incinerator
&
Recycling
Facility
$
315,997
$
126,216
0.78%

146
Wilton
Recycling
Center
$
413,801
$
55,801
­
0.34%

149
Hebron­
Bridgewater
Refuse
District
$
54,015
$
5,184
0.24%

150
Shelby
County
Community
Services
$
15,088
n/
a
n/
a
274
Jeffers
High
School
­
$
21,610
$
50
to
1,415a
<
0.1%

a
Lower
cost
dependent
on
the
inclusion
of
an
alternative
compliance
certification
for
rural
IWIs;
higher
cost
based
on
landfilling
the
waste.

Several
key
pieces
of
information
have
a
strong
influence
on
projected
costs,
particularly
incinerator
throughput,
landfill
tipping
fees,
and
the
hauling
distance
to
the
landfill
or
transfer
station.
For
the
six
facilities
still
operating,
actual
throughput
based
on
information
received
from
the
telephone
conversations
was
lower,
sometimes
substantially
so,
than
the
original
central
tendency
estimate
of
throughput.
(
The
original
throughput
estimates
for
these
facilities
were
actually
based
on
incinerator
capacity.)
Landfill
tipping
fees
were
generally
higher
than
originally
estimated,
and
hauling
distances
(
to
a
landfill
or
transfer
station)
were
farther.
The
higher
tipping
fees
and
hauling
distances
would
normally
result
in
higher
landfill
costs
(
about
60
to
100
percent
higher),
if
waste
throughput
remained
the
same.
However,
the
lower
waste
throughput
estimates
provided
by
the
contacts
more
than
cancel
out
any
cost
increases
due
to
greater
hauling
distance
or
tipping
fees,
resulting
in
lower
landfill
costs
(
about
50
to
95
percent
lower)
for
all
six
facilities
still
operating.
The
lower
waste
throughput
also
reduced
the
incinerator
operation
and
compliance
costs
for
these
facilities.

Three
of
the
facilities
that
were
contacted
(
Seagull
Sanitation,
Town
of
Readsboro,
and
Shelby
County
Community
Services)
indicated
they
are
no
longer
in
operation.
Given
that
their
throughput
is
zero,
it
is
also
assumed
that
their
potential
costs
resulting
from
the
OSWI
rule
are
also
zero.
However,
by
shutting
down,
Shelby
County
also
expects
to
lose
the
revenue
that
it
has
been
receiving
for
providing
incineration
services
to
local
businesses.

The
original
throughput
estimate
for
the
town
of
Ossipee
was
projected
to
be
around
4,000
tpy,
but,
based
on
the
telephone
contact,
it
appears
that
actual
throughput
is
closer
to
1,000
tpy.
The
landfill
they
may
use
has
a
higher
tipping
fee
($
67/
ton,
compared
to
an
original
estimate
of
around
$
56/
ton,
the
State
average),
and
the
landfill
is
farther
(
66
miles
vs.
7).
3,4
Nickerson
Memorandum
5
October
16,
2005
Page
5
Similarly,
the
original
throughput
estimate
for
the
town
of
Candia
was
projected
to
be
approximately
4,000
tpy,
but
is
probably
closer
to
1,000
tpy.
The
landfill
they
expect
to
use
has
a
higher
tipping
fee
($
82/
ton,
compared
to
an
original
estimate
of
around
$
56/
ton,
the
State
average)
and
is
farther
away
(
33
miles
vs.
10).
3,4
Litchfield
was
projected
to
have
an
annual
throughput
of
over
6,000
tpy,
but
is
currently
operating
at
around
1,000
tpy.
The
landfill
they
may
use
has
a
much
higher
tipping
fee
($
107.60/
ton,
compared
to
$
80/
ton
county
average)
and
is
much
farther
(
160
miles
vs.
9).
3,4
Wilton's
throughput
was
projected
to
be
around
8,000
tpy,
but
is
actually
around
800
tpy.
The
transfer
station
they
may
use
has
a
lower
tipping
fee
($
17/
ton,
compared
to
$
80/
ton
county
average),
but
is
farther
away
(
60
miles
vs.
9).
3,4
The
OSWI
unit
in
the
Hebron­
Bridgewater
Refuse
District
is
calculated
to
process
approximately
600
tpy,
compared
to
an
original
estimate
of
approximately
3,800
tpy.
The
landfill
that
may
be
used,
if
they
decide
to
switch
to
landfilling,
has
a
higher
tipping
fee
($
78/
ton,
compared
to
$
45/
ton)
and
is
farther
away
(
51
miles
vs.
26)
than
originally
projected.
3,4
The
IWI
at
Jeffers
High
School
was
projected
to
have
a
throughput
of
around
450
tpy,
but
actually
processes
around
10
tpy.
The
IWI
has
practically
no
operating
cost;
its
only
cost
would
be
the
cost
to
obtain
an
exemption
from
the
OSWI
rule
as
a
rural
IWI;
if
it
fails
to
obtain
the
exemption,
its
only
cost
would
be
the
cost
to
personally
haul
the
trash
to
the
nearest
transfer
station.
The
transfer
station
has
a
slightly
higher
tipping
fee
than
the
landfill
originally
projected
($
60/
ton,
compared
to
$
54/
ton),
but
it
is
closer
(
10
miles
vs.
39).
3
To
summarize:

 
Nine
facilities
were
chosen
on
the
basis
of
original
estimates
of
upper
bound
costs.
 
Three
of
the
nine
facilities
have
already
closed
down
and,
thus,
have
zero
projected
compliance
costs.
 
Based
on
information
provided
during
the
telephone
contacts,
costs
for
the
remaining
six
facilities
were
revised.
 
The
revised
costs
for
these
facilities
are
significantly
lower
than
originally
projected.
 
All
of
the
revised
CRRs
for
these
facilities
are
below
1
percent,
unlike
original
estimates,
and
only
one
facility
remains
above
0.5
percent.

III.
References
1.
Coburn,
J.,
T.
Holloway,
and
K.
Heller.
2005.
Selection
of
Small
Entities
for
Detailed
Cost
Analysis.
Memorandum
submitted
by
RTI
to
W.
Nickerson,
U.
S.
Environmental
Protection
Agency,
Office
of
Policy,
Economics,
and
Innovation,
through
G.
Kline,
ICF.
September
12.
Nickerson
Memorandum
5
October
16,
2005
Page
6
2.
Holloway,
T.
and
J.
Coburn.
2005.
Additional
Reasons
Why
Landfilling
May
Be
Infeasible
for
Small
Entities.
Memorandum
submitted
by
RTI
to
W.
Nickerson,
U.
S.
Environmental
Protection
Agency,
Office
of
Policy,
Economics,
and
Innovation,
through
G.
Kline,
ICF.
October
16.

3.
Chartwell
Information,
EBI,
Inc.
2004.
The
Directory
&
Atlas
of
Solid
Waste
Disposal
Facilities.
Eighth
Edition.

4.
MSN.
2005.
MSN
Maps
&
Directions.
Website:
http://
mappoint.
msn.
com/(
mw2p2x55hotti145ngudhq55)/
DirectionsFind.
aspx.
Accessed
October
24,
2005.

5.
Carter,
C.
2005.
Bridgewater,
Hebron
Build
$
2
Million
Incinerator.
Advanced
Combustion
Systems.
Website:
http://
www.
acs­
acs.
com/
pages/
combust/
news.
htm.
Accessed
October
6,
2005.

6.
Repa,
E.
2005.
NSWMA's
2005
Tip
Fee
Survey.
NSWMA
Research
Bulletin
05­
3,
March.

7.
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
2004.
May
2004
State
Occupational
Employment
and
Wage
Estimates 
Michigan.
Website:
http://
stats.
bls.
gov/
oes/
current/
oes_
mi.
htm#
b37­
0000.
Accessed
October
21,
2005.
Nickerson
Memorandum
5
October
16,
2005
Page
7
Attachment
1.
Contact
List
RTI
ID
39
Seagull
Sanitation
Systems,
Pebbly
Beach
Disposal
Site
Incinerator
1
Dump
Rd,
P.
O.
Box
295
Avalon,
CA
90704
Contact:
Joanne
Long,
Site
Supervisor
(
310)
510­
0675
RTI
ID
130
Town
Of
Readsboro
Incinerator
P.
O.
Box
246
Readsboro,
VT
05350
Contact:
Stanley
Russell,
Chairman
of
Board
(
802)
423­
5405
RTI
ID
143
Ossipee
Incinerator
Facility
50
Chickville
Rd
Ossipee,
NH
03864­
6851
Contact:
Ron
Davis,
Supervisor
(
603)
539­
4121
RTI
ID
144
Town
Of
Candia
74
High
St
Candia,
NH
03034­
5751
Contact:
Manager
(
603)
483­
2892
RTI
ID
145
Town
Of
Litchfield
Incinerator
&
Recycling
Facility
2
Liberty
Way
Litchfield,
NH
03052
Contact:
David
Mellon,
Manager
(
603)
424­
6900
RTI
ID
146
Wilton
Recycling
Center
Route
101,
P.
O.
Box
83
Wilton,
NH
03086
Contact:
Morris
Guay
(
603)
654­
6150
RTI
ID
149
Hebron­
Bridgewater
Refuse
District
297
Mayhew
Turnpike
Bridgewater,
NH
03222
Contact:
Terry
Murphy,
Bridgewater
Selectman
(
603)
744­
5055
Other
Contacts:
Gerry
MacDonald,
Manager;
John
Matthews,
Hebron
Selectman
(
603)
744­
2631;
Hank
Woolner,
Bridgewater
Selectman
(
603)
744­
5055
Nickerson
Memorandum
5
October
16,
2005
Page
8
RTI
ID
150
Shelby
County
Community
Services
1810
W
South
3rd
St,
P.
O.
Box
650
Shelbyville,
IL
62565
Contact:
Office
(
217)
774­
5587
RTI
ID
274
Jeffers
High
School
43084
Goodell
St
Painesdale,
MI
49955
Contact:
Office
(
906)
482­
0580
Jan
Maierle,
Principal
Dan
Sternhagen,
Superintendent
Nickerson
Memorandum
5
October
16,
2005
Page
9
Attachment
2.
Survey
Questions
1.
Are
you
still
operating
your
incinerator?

a.
If
so,
why?

b.
If
not,
why
not?
[
If
due
to
OSWI
rule,
skip
question
7.
Otherwise,
skip
to
Question
9]

2.
What
are
the
waste
throughput
and
operating
schedule
for
your
incinerator?
(
Check
database
to
compare
with
our
estimates.)

a.
Annual
quantity
(
tpy)

b.
Typical
operating
day
throughput
(
tpd)

c.
Is
this
a
batch,
intermittent/
continuous
incinerator?

d.
Confirm
incinerator
type
 
VSMWC
or
IWI
e.
Operating
hours
per
operating
day
i.
What
portion
of
this
are
you
actively
charging
waste?

ii.
What
portion
is
for
start­
up?

iii.
What
portion
is
for
burn­
down?

f.
Operating
days
per
year
i.
Days
per
week
ii.
Weeks
per
year
3.
What
are
the
estimated
annual
operating
costs
(
or
budget)
for
your
incinerator?
Basis
of
estimate?
(
Check
database
to
compare
with
our
estimates.)

4.
How
do
you
currently
dispose
of
your
incinerator
fly
ash?
If
to
a
landfill 

a.
Landfill
name
b.
Tipping
fee
c.
Hauling
cost
and
frequency
5.
Are
you
familiar
with
the
proposed
Other
Solid
Waste
Incinerator
(
OSWI)
regulation?

6.
The
proposed
rule
is
based
on
afterburner/
wet
scrubber
(
emission
limits
of
0.013
gr/
dscf
PM;
3.7
ppmv
HCl,
3.1
ppmv
SO2,
5.0
ppmv
CO).

a.
What
air
emission
controls
do/
did
you
use
on
the
incinerator,
if
any?

b.
Could
your
incinerator
currently
achieve
these
emission
limits?
Nickerson
Memorandum
5
October
16,
2005
Page
10
c.
Do
you
have
any
stack
test
data
for
your
incinerator?
If
so,
can
you
provide
summary
results?

7.
Have
you
considered
the
following
compliance
options?
Which
do
you
expect
to
select
and
why?

a.
Switch
to
landfill
b.
Comply
with
OSWI
emission
limitations
c.
Certify
as
a
rural
IWI
d.
Other
(
specify)

8.
If
you
developed
costs
estimates
for
the
alternative
compliance
options,
what
were
the
overall
costs
(
total
$
or
$/
ton)
of
each
of
the
alternatives
considered?

a.
Switch
to
landfill
b.
Comply
with
OSWI
emission
limitations
c.
Certify
as
a
rural
IWI
d.
Other
(
specify)

9.
If
you
currently
use
(
or
plan
to
comply
by
switching
to)
landfill
disposal,
to
which
landfill
do
you
(
or
are
you
planning
to)
send
your
waste?

a.
Name
of
landfill
b.
Tipping
fee
for
this
landfill
($/
ton)

c.
Distance
to
this
landfill
(
miles)

d.
Hauling
fees/
type
of
hauling
contract?

i.
Self
haul
or
contract
hauler
ii.
If
contract
hauler,
name
of
contractor
used
iii.
Hauling
quantity
and
frequency
(
bin
fees?)

iv.
Mileage
fee
10.
Do
you
think
you
saved
(
or
will
save)
money
by
switching
to
landfill
disposal?

11.
What
is
the
annual
revenue
(
overall
budget)
of
your
municipality
(
or
school)?
Basis
for
revenue?

12.
Are
there
any
other
factors
influencing
your
decision
to
incinerate
vs.
landfill
that
we
did
not
discuss?
Do
you
have
any
questions
for
me/
us?
Nickerson
Memorandum
5
October
16,
2005
Page
11
Attachment
3.
Facility
Profiles
A.
Seagull
Sanitation
System
and
the
Town
of
Readsboro
The
incinerators
at
Seagull
Sanitation
Systems
in
Avalon,
California
(
Unit
39)
and
the
Town
of
Readsboro
in
Readsboro,
Vermont
(
Unit
130)
are
no
longer
operating
and
have
been
completely
removed
from
these
facilities.
The
contacts
cited
State
and
local
agency
emission
limitations
and
permitting
requirements
as
why
they
no
longer
operate
their
incinerators.
Because
these
incinerator
units
are
no
longer
operating,
the
OSWI
rule
is
not
applicable
to
these
facilities.

B.
Ossipee
Incinerator
The
Ossipee
Incinerator
facility
(
Unit
143)
burns
municipal
waste
for
the
town
of
Ossipee,
New
Hampshire.
The
incinerator
burns
about
1,300
to
1,400
pounds
(
lbs)
of
waste
per
hour.
The
amount
of
waste
burned
per
day
varies
by
season,
with
about
12,000
to
15,000
lbs
of
waste
burned
per
day
during
the
summer,
and
about
4,000
lbs
of
waste
burned
the
rest
of
the
year.
Based
on
this
information,
the
average
daily
throughput
was
calculated
to
be:

[(
12,000
lb/
d
+
15,000
lb/
d)
/
2]
x
(
3
summer
months
(
mos)
/
12
mos)
+
(
4,000
lb/
d)
x
(
9
other
mos
/
12
mos)
=
3.1875
tons
per
day
(
tpd)

Operating
hours
for
the
facility
are
9:
00
to
4:
00
on
Monday,
Tuesday,
Friday,
and
Saturday;
9:
00
to
5:
00
on
Thursday;
and
9:
00
to
1:
00
on
Sunday,
which
comes
out
to
be
6
days
per
week
(
d/
wk)
and
40
hours
per
week
(
hr/
wk).
Based
on
this
information
and
assuming
the
facility
operates
52
weeks
per
year
(
wk/
yr),
the
daily
and
annual
operating
schedules
were
calculated
to
be:

(
40
hr/
wk)
/
(
6
d/
wk)
=
6.7
hours
per
day
(
hr/
d)
(
6
d/
wk)
x
(
52
wk/
yr)
=
312
days
per
year
(
d/
yr)

The
annual
throughput
is
(
3.1875
tpd)
x
(
312
d/
yr)
=
994.5
tons
per
year
(
tpy).
In
addition
to
incineration,
the
facility
also
does
a
lot
of
recycling.
The
budget
for
the
facility
is
$
360,000
plus
fuel
costs
and
includes
four
full­
time
personnel.

Ossipee
contracts
with
North
Conway
Incineration
to
haul
its
incinerator
fly
ash
6
times
per
year
to
the
Berlin,
New
Hampshire
landfill,
and
the
hauling
cost
is
$
245.
(
The
Chartwell
directory
indicates
the
tipping
fee
for
this
landfill
is
$
67/
ton.
3)
The
facility
has
recently
gone
to
a
higher
stack
at
the
request
of
the
State
and
releases
about
6.75
tpy
of
emissions.

The
contact
did
not
expect
the
incinerator
to
meet
the
requirements
of
the
OSWI
rule
and
expected
the
incinerator
would
be
shut
down
and
the
waste
compacted
at
a
transfer
station
prior
to
being
sent
to
a
landfill.
The
transfer
station
is
not
known.
The
contact
noted
that
the
State
is
not
issuing
any
more
landfills.
The
contact
did
not
know
exactly
what
the
cost
would
be
to
switch
to
a
landfill,
but
he
expected
it
could
take
several
years
before
they
have
to
shut
down
the
Nickerson
Memorandum
5
October
16,
2005
Page
12
incinerator.
The
contact
was
unsure
about
the
revenue
for
the
town
but
guessed
it
was
around
$
3
million.

Finally,
the
contact
pointed
out
that
EPA
has
overlooked
the
issue
of
the
wastes
they
burn
that
cannot
be
landfilled,
specifically,
contraband
(
drugs)
and
records
from
police
departments
and
rabid
animal
remains
from
the
Department
of
Fish
&
Game.

The
incinerator
operating
costs
and
compliance
costs
for
Ossipee
were
revised
using
the
original
cost
equations
and
the
new
annual
waste
throughput
number.
Assuming
the
waste
is
shipped
to
the
same
landfill
as
the
ash
(
i.
e.,
Berlin),
the
landfill
cost
for
Ossipee
was
revised
using
the
original
cost
equation,
the
new
annual
waste
throughput
number,
and
the
new
landfill
information
(
landfill
distance,
tipping
fee).
Because
no
information
was
available
on
hauling
frequency
for
the
waste,
the
original
$
0.50/
ton/
mile
was
used
to
determine
the
hauling
cost.
Because
the
identify
of
the
transfer
station
is
unknown,
the
distance
from
the
Ossipee
facility
to
the
Berlin
landfill
(
66.1
miles)
was
used,
which
was
determined
using
MapPoint.
4
The
tipping
fee
for
the
Berlin
landfill
($
67/
ton)
was
taken
from
the
Chartwell
directory.
3
The
CRR
(
0.30
percent)
was
determined
by
dividing
the
cost
of
the
lower
cost
option
(
landfilling)
by
the
original
revenue
estimate.

C.
Town
of
Candia
The
Town
of
Candia
incinerator
(
Unit
144)
burns
municipal
waste
for
the
town
of
Candia,
New
Hampshire.
The
incinerator
burns
about
250
lbs
of
waste
every
20
to
30
minutes,
for
a
total
of
about
20
to
25
tons
per
week
(
ton/
wk).
The
amount
of
waste
burned
per
week
varies
by
season,
with
the
spring/
summer
busier
than
fall/
winter.
The
incinerator
operates
4
d/
wk,
52
wk/
yr.
Based
on
this
information,
the
average
daily
throughput
and
annual
operating
time
were
calculated
to
be:

[(
20
ton/
wk
+
25
ton/
wk)
/
2]
/
(
4
d/
wk)
=
5.625
tpd
(
4
d/
wk)
x
(
52
wk/
yr)
=
208
d/
yr
The
annual
throughput
is
(
5.625
tpd)
x
(
208
d/
yr)
=
1,170
tpy.
Based
on
the
waste
throughput
and
operating
days
provided
above,
the
minimum
operating
hr/
d
was
calculated
to
be:

(
250
lb/
20
min)
/
(
20
ton/
wk)
x
(
4
d/
wk)
x
(
2,000
lb/
ton)
/
(
60
min/
hr)
=
13
hr/
d
The
budget
for
the
entire
operation
is
$
398,000,
which
includes
$
24,000
for
propane
for
the
afterburners.

Candia
contracts
with
Casella
Waste
to
take
the
incinerator
fly
ash
to
the
Bethlehem,
New
Hampshire
landfill,
and
the
hauling
cost
is
$
1,500
to
$
2,000.
The
ash
is
hauled
16
to
18
tons
at
a
time.
(
The
Chartwell
directory
indicates
the
tipping
fee
for
this
landfill
is
$
77.91/
ton.
3)

The
contact
said
that
he
was
not
familiar
with
the
OSWI
rule,
but
knew
that
it
was
more
stringent
that
current
requirements.
He
also
knew
that
the
State
would
be
adopting
the
rule,
and
that
it
Nickerson
Memorandum
5
October
16,
2005
Page
13
would
come
into
effect
in
several
years.
He
noted
that
the
facility
has
an
aging
incinerator,
whose
permit
was
due
to
expire
in
April
2008.
The
incinerator
is
equipped
with
afterburners,
and
its
stack
was
raised
20
to
30
feet
about
2
to
3
years
ago
at
the
request
of
the
State.
Testing
was
done
on
the
incinerator
at
that
time,
and
the
data
are
on
file
at
the
town
hall.

The
contact
said
that
if
EPA
stayed
with
the
OSWI
standards
as
proposed,
it
would
shut
them
down.
He
did
not
think
the
incinerator
would
be
able
to
comply
with
the
requirements
of
the
OSWI
rule,
and
they
were
not
willing
to
put
more
money
into
it.
He
also
noted
that
there
was
local
opposition
to
the
incinerator
(
odor
complaints),
and
the
emission
controls
were
not
very
good.
He
expected
the
incinerator
would
be
shut
down
and
the
facility
converted
into
a
transfer
station,
with
the
waste
then
sent
to
a
landfill.
He
said
the
waste
would
probably
be
taken
to
the
landfill
in
Rochester,
New
Hampshire,
with
a
hauling
cost
of
$
136.22/
haul.
(
According
to
the
Chartwell
directory,
the
tipping
fee
for
this
landfill
is
$
82/
ton.
3)
They
are
currently
working
on
the
costs
to
switch
to
a
landfill.
The
contact
estimated
the
revenue
for
the
town
was
around
$
1.5
to
$
1.7
million.

The
incinerator
operating
costs
and
compliance
costs
for
Candia
were
revised
using
the
original
cost
equations
and
the
new
annual
waste
throughput
number.
Assuming
the
waste
is
shipped
to
the
Rochester
landfill,
the
landfill
cost
for
Candia
was
revised
using
the
original
cost
equation,
the
new
annual
waste
throughput
number,
and
the
new
landfill
information
(
landfill
distance,
tipping
fee).
Because
no
information
was
available
on
the
hauling
frequency
for
the
waste,
the
original
$
0.50/
ton/
mile
was
used
to
determine
the
hauling
cost.
The
distance
from
the
Candia
facility
to
the
Rochester
landfill
(
33.4
miles)
was
determined
using
MapPoint.
4
The
tipping
fee
for
the
Berlin
landfill
($
82/
ton)
was
taken
from
the
Chartwell
directory.
3
The
CRR
(
0.45
percent)
was
determined
by
dividing
the
cost
of
the
lower
cost
option
(
landfilling)
by
the
original
revenue
estimate.

D.
Town
of
Litchfield
Incinerator
&
Recycling
Facility
The
Town
of
Litchfield
Incinerator
&
Recycling
Facility
(
Unit
145)
burns
municipal
waste
for
the
town
of
Litchfield,
New
Hampshire.
The
incinerator
burns
about
21
to
22
ton/
wk
of
waste,
but
they
could
burn
5
times
that
amount.
The
operating
hours
for
the
incinerator
are
scattered.
According
to
the
facility,
operating
hours
are:

3:
00
to
7:
00
on
Wednesday
7:
00
to
12:
00
on
Thursday
4:
00
to
8:
00
on
Friday
7:
00
to
4:
00
on
Saturday
9:
00
to
12:
00
on
Sunday
This
operating
schedule
adds
up
to
be
25
hr/
wk,
5
d/
wk,
and
(
25
hr/
wk)
/
(
5
d/
wk)
=
5
hr/
d.
Based
on
this
information
and
with
the
facility
operating
52
wk/
yr,
the
average
daily
throughput
and
annual
operating
time
were
calculated
to
be:

[(
21
ton/
wk
+
22
ton/
wk)
/
2]
/
(
5
d/
wk)
=
4.3
tpd
Nickerson
Memorandum
5
October
16,
2005
Page
14
(
5
d/
wk)
x
(
52
wk/
yr)
=
260
d/
yr
The
annual
throughput
is
(
4.3
tpd)
x
(
260
d/
yr)
=
1,118
tpy.
In
addition
to
incineration,
the
facility
also
does
a
lot
of
recycling.
The
budget
for
the
entire
facility
is
$
340,000,
which
includes
both
recycling
and
incineration.

Litchfield
contracts
with
Casella
Waste
of
Montpelier,
Vermont
to
haul
its
incinerator
fly
ash
3
times
per
year,
and
the
hauling
cost
is
$
75/
ton.
(
The
Chartwell
directory
indicates
the
tipping
fee
for
the
Montpelier
landfill
is
$
107.60/
ton.
3)
The
incinerator
is
equipped
with
an
afterburner.
Testing
has
been
done
on
the
incinerator,
and
the
data
are
on
file
with
the
State.

The
contact
said
that
he
was
a
little
familiar
with
the
OSWI
rule,
and
had
received
a
mailing
from
EPA
about
their
incinerator.
He
said
that
the
regulatory
person
at
their
facility
would
know
more,
but
he
was
not
in.
The
contact
knew
that
the
rule
would
take
effect
in
several
years,
and
he
said
their
facility
would
be
closed
by
then.
He
said
that,
as
of
now,
they
could
not
meet
the
limits
and
would
have
to
add
a
scrubber
in
order
to
comply.
However,
he
said
that
the
equipment
as
it
exists
did
not
warrant
adding
anything,
and
he
would
recommend
to
the
Selectmen
that
they
get
a
price
on
a
compactor
in
the
budget
for
next
year.
He
mentioned
the
incinerator's
high
fuel
costs
as
another
factor.
The
contact
did
not
know
where
the
waste
would
be
taken,
but
said
it
could
be
Casella
Waste
or
others.
Although
it
would
cost
more
to
landfill
the
waste
than
to
burn
it,
the
contact
said
the
breakeven
point
gets
closer
and
closer.
The
contact
had
no
idea
about
the
revenue
for
the
town
and
recommended
that
RTI
contact
the
town
hall
for
this
information.

The
contact
noted
that
housing
developments
had
been
encroaching
more
and
more
on
their
facility
each
year
and
mentioned
the
nuisance
factor
as
another
reason
why
they
are
expecting
to
shut
down
the
incinerator,
besides
the
State
and
Federal
government.
However,
he
also
pointed
out
that
there
are
some
wastes
they
burn
that
cannot
be
landfilled,
specifically,
contraband
(
drugs)
and
records
from
police
departments
and
lots
of
other
materials
from
the
Department
of
Fish
&
Game.

The
incinerator
operating
costs
and
compliance
costs
for
Litchfield
were
revised
using
the
original
cost
equations
and
the
new
annual
waste
throughput
number.
Assuming
the
waste
is
shipped
to
the
same
landfill
as
the
ash
(
i.
e.,
Montpelier),
the
landfill
cost
for
Litchfield
was
revised
using
the
original
cost
equation,
the
new
annual
waste
throughput
number,
and
the
new
landfill
information
(
landfill
distance,
tipping
fee).
Because
no
information
was
available
on
hauling
frequency
for
the
waste,
the
original
$
0.50/
ton/
mile
was
used
to
determine
the
hauling
cost.
The
distance
from
the
Litchfield
facility
to
the
Montpelier
landfill
(
145
miles)
was
determined
using
MapPoint.
4
The
tipping
fee
for
the
Montpelier
landfill
($
107.60/
ton)
was
taken
from
the
Chartwell
directory.
3
The
CRR
(
0.78
percent)
was
determined
by
dividing
the
cost
of
the
lower
cost
option
(
landfilling)
by
the
original
revenue
estimate.
Nickerson
Memorandum
5
October
16,
2005
Page
15
E.
Wilton
Recycling
Center
The
incinerator
at
the
Wilton
Recycling
Center
(
Unit
146)
burns
municipal
waste
for
the
town
of
Wilton,
New
Hampshire.
The
incinerator
burns
about
1
ton
per
hour
(
tph)
of
waste
for
8
hr/
d,
or
8
tpd.
The
incinerator
operates
2
d/
wk
for
52
wk/
yr,
or
104
d/
yr.
The
annual
throughput
is
(
8
tpd)
x
(
104
d/
yr)
=
832
tpy.
In
addition
to
incineration,
the
facility
also
does
a
lot
of
recycling.
The
contact
could
not
provide
any
information
about
the
budget
for
the
incinerator,
noting
that
costs
for
the
entire
facility
are
lumped
together.

Wilton
currently
sends
its
incinerator
fly
ash
to
either
the
Charlestown
transfer
station
or
the
Berlin
landfill.
(
According
to
the
Chartwell
directory,
the
tipping
fees
are
$
16.67/
ton
for
Charlestown
and
$
67/
ton
for
Berlin.
3)
Wilton
sends
about
six
dumpsters
per
week
of
material
to
these
facilities,
not
all
from
the
incinerator.
According
to
the
contact,
the
incinerator
is
not
equipped
with
an
afterburner
or
any
add­
on
controls.

The
contact
had
some
familiarity
with
the
OSWI
rule,
noting
that
they
have
several
years
to
decide
what
to
do
about
the
incinerator.
He
recommended
RTI
talk
to
a
Selectman
for
further
information.
He
said
that
whether
they
will
be
able
to
comply
with
the
OSWI
rule
depends
on
what
they
decide
to
do.
They
could
follow
the
path
that
the
Hebron­
Bridgewater
facility
took
and
try
to
come
into
compliance
with
the
emission
limits
(
see
next
section).
Testing
has
been
done
on
the
incinerator,
but
the
contact
could
not
give
out
that
information
without
the
approval
of
a
Selectman.
Because
no
decision
has
been
made,
the
contact
could
not
say
definitively
where
the
waste
would
be
taken
if
they
decide
to
landfill,
but
said
it
could
be
the
same
place
that
takes
the
ash.
The
contact
did
not
know
whether
they
would
save
money
by
switching
to
a
landfill.
He
also
did
not
know
the
revenue
for
the
town.

The
incinerator
operating
costs
and
compliance
costs
for
Wilton
were
revised
using
the
original
cost
equations
and
the
new
annual
waste
throughput
number.
Assuming
the
facility
decides
to
landfill
the
waste
and
haul
it
to
the
same
transfer
station
as
the
ash
(
i.
e.,
Charlestown),
the
landfill
cost
for
Wilton
was
revised
using
the
original
cost
equation,
the
new
annual
waste
throughput
number,
and
the
transfer
station
information
(
hauling
distance,
tipping
fee).
Because
no
hauling
frequency
for
the
waste
was
available,
the
original
$
0.50/
ton/
mile
was
used
to
determine
the
hauling
cost.
The
distance
from
the
Wilton
facility
to
the
Charlestown
transfer
station
(
60.3
miles)
was
determined
using
MapPoint.
4
The
tipping
fee
for
the
Charltestown
transfer
station
($
16.67/
ton)
was
taken
from
the
Chartwell
directory.
3
The
CRR
for
the
landfilling
option
(­
0.34
percent)
was
determined
by
dividing
the
cost
of
the
lower
cost
option
(
landfilling)
by
the
original
revenue
estimate.
If
the
facility
decides
to
comply
with
the
rule,
the
CRR
is
2.48
percent,
based
on
the
revised
compliance
cost
and
original
revenue
estimate.

F.
Hebron­
Bridgewater
Refuse
District
The
incinerator
at
the
Hebron­
Bridgewater
Refuse
District
(
Unit
149)
burns
refuse­
derived
material
(
sorted
trash)
for
the
towns
of
Hebron
and
Bridgewater,
New
Hampshire.
The
incinerator
burns
about
750
lbs
of
waste
per
hour
for
8
to
10
hr/
d,
or
about
7,000
lb/
d
(
3.5
tpd).
They
burn
about
2
to
3
days
trash
in
1
day
or
less.
The
incinerator
operates
3
d/
wk
during
the
Nickerson
Memorandum
5
October
16,
2005
Page
16
winter
and
4
d/
wk
during
the
summer.
Assuming
the
incinerator
operates
52
wk/
yr,
the
annual
operating
days
were
calculated
to
be:

[(
3
d/
wk)
x
(
6
mos)
/
(
12
mos)
+
(
4
d/
wk)
x
(
6
mos)
/
(
12
mos)]
x
(
52
wk/
yr)
=
182
d/
yr
The
annual
throughput
is
(
3.5
tpd)
x
(
182
d/
yr)
=
637
tpy.
Before
they
incinerate,
they
do
a
lot
of
recycling
first
(
99.9
percent).
The
contact
estimated
the
annual
budget
for
the
incinerator
to
be
about
$
450,000.

Hebron­
Bridgewater
currently
sends
its
incinerator
fly
ash
to
the
Bethlehem
landfill.
They
contract
with
North
Country
Environmental
Services
for
this
service.
(
According
to
Chartwell,
the
tipping
fee
for
the
Bethlehem
landfill
is
$
77.91.3)
Hebron­
Bridgewater
contracts
with
a
commercial
hauler,
sending
a
load
every
6
to
8
weeks,
at
a
cost
of
$
1,000/
load.

According
to
the
contact,
the
incinerator
has
been
outfitted
with
the
best
equipment
that
can
be
installed,
including
a
primary
and
secondary
chamber,
wet
scrubber,
and
CEMS
for
carbon
monoxide
(
CO),
oxygen
(
O2),
opacity,
and
(
soon)
sulfur
dioxide
(
SO2).
Testing
has
been
done
on
the
incinerator,
and
the
contact
provided
pages
from
their
permit
application
with
emissions
data.
He
noted
that
Advanced
Combustion
Systems
(
ACS)
had
installed
their
system.
(
See
also
the
article
at
the
ACS
website
for
more
about
the
installation
of
this
system.
5)

The
contact
had
some
familiarity
with
the
OSWI
rule
and
said
he
doubted
they
could
meet
the
limits
of
the
rule
at
the
stringent
levels
proposed.
He
was
especially
concerned
about
the
limits
for
lead.
He
said
that
if
they
are
unable
to
reduce
their
emissions
beyond
the
limits
they
are
already
meeting,
they
may
have
to
shut
down
in
2
to
5
years.
However,
their
intention
now
is
to
try
and
comply
with
the
rule.
He
indicated
that
they
needed
more
time
from
EPA
in
order
to
make
it
work;
the
technology
is
just
not
there
yet.
Their
state­
of­
the­
art
facility
had
been
funded
by
the
citizens
of
their
municipalities,
and
they
did
not
want
to
throw
away
the
substantial
sum
of
money
they
had
already
spent.
He
indicated
they
may
have
to
pass
a
bond
issue
to
obtain
additional
funds
to
upgrade
the
incinerator
even
further.
He
noted
that
the
current
cost
of
propane
fuel
($
1/
gallon)
is
also
hurting
them.
They
would
like
to
recover
the
energy
from
the
incinerator,
but
they
just
exhaust
the
heat
right
now.
Because
they
have
decided
to
try
and
comply
with
the
rule,
no
information
was
provided
on
which
landfill
the
waste
would
otherwise
be
taken.
With
regard
to
the
revenue,
the
contact
estimated
that
they
raise
about
$
750,000
in
taxes
each
year,
spending
about
30
percent
of
the
revenue
on
waste
management.

The
incinerator
operating
costs
for
Hebron­
Bridgewater
were
revised
using
the
original
cost
equations
and
the
new
annual
waste
throughput
number.
Because
Hebron­
Bridgewater
is
already
equipped
with
the
control
and
monitoring
equipment
needed
to
comply
with
the
rule,
the
compliance
costs
were
revised
using
a
new
cost
equation
(
0.1846
x
annual
throughput
+
86,408)
and
the
new
annual
waste
throughput
number.
The
new
cost
equation
accounts
only
for
those
costs
that
the
facility
is
not
already
incurring,
which
include
quarterly
CEMS
audits,
performance
test
and
report,
recordkeeping
and
reporting,
and
title
V
costs.
The
equation
does
not
include
wet
scrubber
costs
or
CEMS
costs
(
other
than
audits).
Nickerson
Memorandum
5
October
16,
2005
Page
17
Assuming
the
facility
decides
to
landfill
the
waste
and
haul
it
to
the
same
landfill
as
the
ash
(
i.
e.,
Bethlehem),
the
landfill
cost
for
Hebron­
Bridgewater
was
revised
using
the
original
cost
equation,
the
new
annual
waste
throughput
number,
and
the
new
landfill
information
(
landfill
distance,
tipping
fee).
Because
no
information
was
available
on
hauling
frequency
for
the
waste,
the
original
$
0.50/
ton/
mile
was
used
to
determine
the
hauling
cost.
The
distance
from
the
Hebron­
Bridgewater
facility
to
the
Bethlehem
landfill
(
50.5
miles)
was
determined
using
MapPoint.
4
The
tipping
fee
for
the
Bethlehem
landfill
($
77.91/
ton)
was
taken
from
the
Chartwell
directory.
3
The
CRR
for
the
landfilling
option
(
0.24
percent)
was
determined
by
dividing
the
cost
of
the
lower
cost
option
(
landfilling)
by
the
original
revenue
estimate.
If
the
facility
decides
to
comply
with
the
rule,
the
CRR
is
4.02
percent,
based
on
the
revised
compliance
cost
and
original
revenue
estimate.

G.
Shelby
County
Community
Services
Shelby
County
Community
Services
(
Unit
150)
is
a
not­
for­
profit
company
that
provides
services
to
businesses
in
Shelby
County,
Illinois.
The
incinerator
was
installed
to
burn
paper,
cardboard,
and
wood,
but
the
demand
for
this
service
has
been
less
than
projected.
As
such,
the
unit
has
not
been
operating,
although
it
is
still
in­
place.
The
contact
expressed
concern
that
eliminating
this
service
could
increase
barrel
burning
of
the
wastes.
When
the
unit
was
operating,
it
typically
processed
approximately
1,000
lbs
of
waste
per
month
(
lb/
mo)
(
or
6
tpy).
Even
with
a
$
100/
ton
incinerator
tipping
fee
(
an
above
average
incinerator
tipping
fee
according
to
the
2005
Tip
Fee
Survey),
this
would
only
translate
into
$
600
of
potentially
lost
annual
revenue.
6
Given
that
the
unit
is
not
currently
operating
due
to
lack
of
demand,
this
$
600
lost
revenue
is
likely
an
upper
estimate.
Assuming
the
parts
and
metal
salvage
covers
the
cost
of
removing
the
incinerator,
this
lost
revenue
appears
to
be
the
only
impact
for
this
entity.
Once
the
incinerator
unit
has
been
permanently
shut
down,
the
OSWI
rule
would
no
longer
be
applicable
to
this
facility.

H.
Jeffers
High
School
The
Jeffers
High
School
incinerator
(
Unit
274)
in
Painesdale,
Michigan
is
a
very
low
technology
batch
institutional
waste
incinerator
(
IWI).
It
is
used
solely
to
burn
cardboard
wastes
and
contains
no
natural
gas
burners
or
emission
controls.
The
annual
waste
throughput
is
9.6
tpy.
The
incinerator
is
operated
1
day
every
1
or
2
weeks,
2
to
3
hours
per
day,
for
40
wk/
yr,
which
amounts
to
about
30
d/
yr.
Based
on
this
information,
the
daily
waste
throughput
for
the
incinerator
is
(
9.6
tpy)
/
(
30
d/
yr)
=
0.32
tpd.

The
annual
operating
costs
for
the
unit
were
estimated
to
be
essentially
$
0
("
cost
of
a
match").
There
is
no
significant
ash
from
the
incinerator
and
no
emissions
test
data.
The
contact
was
familiar
with
the
OSWI
rule
and
did
not
think
their
incinerator
could
meet
the
emission
limits.
This
facility
is
more
than
50
miles
from
the
border
of
the
nearest
MSA
and
intends
to
obtain
an
exemption
from
the
emission
limits
in
the
OSWI
rule
by
certifying
that
it
is
a
rural
IWI.
Assuming
this
certification
process
costs
$
500
and
needs
to
be
re­
assessed
every
census
period
(
every
10
years),
the
average
annual
compliance
cost
for
this
facility
was
estimated
at
$
50/
year.
Nickerson
Memorandum
5
October
16,
2005
Page
18
Without
the
rural
IWI
compliance
option,
the
facility
would
haul
the
cardboard
to
the
Houghton
transfer
station
10
miles
from
the
school.
Annual
land
disposal
costs
are
estimated
to
be
$
580/
yr
in
tipping
fees,
$
585/
yr
in
labor,
and
$
250/
yr
in
mileage,
for
a
total
of
$
1,415/
yr.
These
estimates
are
based
on
the
following:

 
0.8
tons
of
waste
per
month
(
ton/
mo)
 
$
60/
ton
tipping
fee
at
the
transfer
station3
 
1
trip
every
2
weeks
(
or
26
trips
per
year)
 
1
hour
per
round
trip
 
20
miles
round­
trip
 
$
0.485/
mile
(
based
on
federal
mileage
reimbursement
rate)
 
$
22.50/
hour
(
based
on
average
salary
of
$
11.26/
hr
for
a
Michigan
grounds/
maintenance
worker,
assuming
100
percent
benefits/
overhead/
administration
cost
burden
on
labor)
7
The
CRR
(<
0.1
percent)
was
estimated
to
apply
to
either
option
(
rural
IWI
exemption,
landfilling)
by
dividing
the
cost
of
the
higher
cost
option
(
landfilling $
1,415)
by
the
original
revenue
estimate.
Nickerson
Memorandum
5
October
16,
2005
Page
19
turning
knowledge
into
practice
Attachment
4.
OSWI
Contact
Summariesa
RTI
ID
39
130
143
144
145
146
149
150
274
Facility
name
Seagull
Sanitation
Systems,
Pebbly
Beach
Disposal
Site
Incinerator
Town
Of
Readsboro
Incinerator
Ossipee
Incinerator
Facility
Town
Of
Candia
Town
Of
Litchfield
Incinerator
&

Recycling
Facility
Wilton
Recycling
Center
Hebron­
Bridgewater
Refuse
District
Shelby
County
Community
Services
Jeffers
High
School
Location
Avalon,
CA
Readsboro,

VT
Ossipee,
NH
Candia,
NH
Litchfield,
NH
Wilton,
NH
Bridgewater,

NH
Shelbyville,

IL
Painesdale,
MI
Contact
status
Contacted
by
Jeff
C.
Contacted
by
Jeff
C.
Contacted
by
Tom
H.
Contacted
by
Tom
H.
Contacted
by
Tom
H.
Contacted
by
Tom
H.
Contacted
by
Tom
H.
Contacted
by
Jeff
C.
Contacted
by
Jeff
C.

Operating?
No
No
Yes
Yes
Yes
Yes
Yes
In­
place,
but
not
being
used
Yes
Annual
waste
throughput?
0
Annual
throughput
currently
0;

480
tpy
when
operated
(
annual
capacity
projected
to
be
3,358
tpy)
Annual
throughput
=

994.5
(
calc.)

(
annual
capacity
projected
to
be
4,030
tpy)
Annual
throughput
=

1,170
(
calc.)

(
annual
capacity
projected
to
be
4,030
tpy)
Annual
throughput
=

1,118
tpy
(
calc.);
could
burn
5x
that
amount
(
annual
capacity
projected
to
be
6,179
tpy)
Annual
throughput
=

832
tpy
(
calc.)

(
annual
capacity
projected
to
be
8,060
tpy)
Annual
throughput
=

637
tpy
(
calc.);

sorted
trash,
not
MSW
(
annual
capacity
projected
to
be
3,869
tpy)
Annual
throughput
currently
0;

avge
6
tpy
when
operate
(
not
reported:

used
VSMWC
avge
=
3,182
tpy)
Annual
throughput
=

9.6
tpy
(
reported)

(
not
reported:

used
IWI
avge
=
445
tpy)

Daily
waste
throughput?
0
Daily
throughput
currently
0;
2
tpd
when
operated
(
reported)

(
daily
capacity
reported
as
12.5
tpd)
Daily
throughput
=

6­
7.5
tpd
summer,
2
tpd
rest
of
yr
(
reported);

avge
3.1875
tpd
(
daily
capacity
reported
as
15
tpd)
Daily
throughput
=

5­
6.25
tpd
(
calc.,
20­
25
ton/
wk­
varies
by
season,
4
d/
wk);
avge
5.625
tpd
(
daily
capacity
reported
as
15
tpd)
Daily
throughput
=

4.2­
4.4
tpd
(
calc.,
21­
22
ton/
wk);
avge
4.3
tpd;
could
burn
5x
that
amount
(
daily
capacity
reported
as
23
tpd)
Daily
throughput
=

8
tpd
(
reported)

(
daily
capacity
reported
as
30
tpd)
Daily
throughput
=

3.5
tpd
(
reported)

(
daily
capacity
reported
as
14.4
tpd
for
previous
unit,
9
tpd
for
new
unit)
Daily
throughput
currently
0
(
not
reported:

used
VSMWC
avge
=
12.238
tpd)
Daily
throughput
=

0.32
tpd
(
calc.)

(
not
reported:

used
IWI
avge
=
1.953
tpd)

Batch/
interm.?
Interm.
Interm.
Interm.
Interm.
Interm.
Batch
(
continued)
Nickerson
Memorandum
5
October
16,
2005
Page
20
turning
knowledge
into
practice
Attachment
4.
OSWI
Contact
Summariesa
(
continued)

RTI
ID
39
130
143
144
145
146
149
150
274
VSMWC/

IWI?
VSMWC
VSMWC
VSMWC
VSMWC
VSMWC
IWI?
(
see
desc.
under
landfill?)

(
VSMWC)
IWI
Oper.
hr/
d?
0
0
6.7
hr/
d
(
calc.,

40
hr/
wk,
6
d/
wk)
>
13
hr/
d
(
calc.,

load
250
lb
every
20­
30
min,
20­
25
ton/
wk,
4
d/
wk)
5
hr/
d
avge
(
calc.,
4
hr/
d
Wed
and
Fri,
5
hr/
d
Thur,
9
hr/
d
Sat,
3
hr/
d
Sun)
8
hr/
d
(
reported)
8­
10
hr/
d
(
reported)
Currently
0
2­
3
hr/
d
(
reported)

Oper.
d/
yr?

­
d/
wk
­
wk/
yr
0
0
312
d/
yr
(
calc.)

­
6
d/
wk
­
52
wk/
yr
(
not
reported:

used
VSMWC
avge
=
269
d/
yr)
208
d/
yr
(
calc.)

­
4
d/
wk
­
52
wk/
yr
(
not
reported:

used
VSMWC
avge
=
269
d/
yr)
260
d/
yr
(
calc.)

­
5
d/
wk
­
52
wk/
yr
(
not
reported:

used
VSMWC
avge
=
269
d/
yr)
104
d/
yr
(
calc.)

­
2
d/
wk
­
52
wk/
yr
(
not
reported:

used
VSMWC
avge
=
269
d/
yr)
182
d/
yr
(
calc.)

­
3
d/
wk
winter,

4
d/
wk
summer;

avge
3.5
d/
wk
­
52
wk/
yr
(
not
reported:

used
VSMWC
avge
=
269
d/
yr)
Currently
0
30
d/
yr
(
calc.)

­
1
d
every
1
or
2
wks
­
40
wk/
yr
(
not
reported:

used
IWI
avge
=
228
d/
yr)

Oper.
costs?
$
0
$
0
$
360,000
+

fuel
cost
($
157,000)
No
specific
figure,

$
398,000
for
whole
oper.

($
24,000
for
propane)

($
157,000)
$
340,000
for
entire
facility
(
recycling
and
incineration)

($
216,000)
Don't
know;

cost
lumped
into
everything
else
($
266,000)
$
450,000
($
153,000)
Currently
$
0
$
0
(
cost
of
a
match­
burn
only
cardboard

($
54,400)

(
continued)
Nickerson
Memorandum
5
October
16,
2005
Page
21
turning
knowledge
into
practice
Attachment
4.
OSWI
Contact
Summariesa
(
continued)

RTI
ID
39
130
143
144
145
146
149
150
274
Ash
disposal?

­
Landfill
­
Tipping
fee
­
Haul
cost
Yes
­
Berlin
­
$
67/
ton
(
Chartwell)

­
$
245
haul
cost
,
6
loads/
yr
Yes
­
Bethlehem
­
$
77.91/
ton
(
Chartwell)

­
$
1,500­
2,000
haul
cost,
16­

18
tons
at
a
time
Yes
­
Montpelier,

VT
(
Casella
Waste)

­
$
107.60/
ton
(
Chartwell)

­
$
75/
ton
haul
cost,
3
loads/
yr
Yes
­
Charlestown
transfer
station
or
Berlin
landfill
­
$
16.67/
ton
for
Charlestown
$
67/
ton
for
Berlin,

(
Chartwell)

­
Haul
6
dumpsters/

wk,
not
all
from
incinerator
Yes
­
Bethlehem
­
$
77.91/
ton
(
Chartwell)

­
$
1,000/
load
haul
cost,
every
6­
8
wks
No
significant
ash.

Know
reg?
Some
No,
but
more
stringent;
to
be
adopted
by
NH
Some;
reg
person
not
there
today;

reviewed
mailing
from
EPA
Some;
believe
they
have
until
Feb
08
to
decide
Yes
No
Yes
Controls?
Yes;
upgraded
to
higher
stack
last
yr
(
none)
Yes;
afterburner,

raised
stack
2­

3
yrs
ago
(
none)
Yes;
afterburner
(
none)
No;
no
afterburner
(
none)
Yes;
primary/

secondary
chambers;
wet
scrubber;
evaporate
the
scrubbed
water
&
store
the
residue
~
1
in./
yr;
CEMS
for
CO,
O2,

opacity,
and
(
soon)
SO2
(
no
info)
No
No
(
continued)
Nickerson
Memorandum
5
October
16,
2005
Page
22
turning
knowledge
into
practice
Attachment
4.
OSWI
Contact
Summariesa
(
continued)

RTI
ID
39
130
143
144
145
146
149
150
274
Achieve
limits?
No
No
No,
not
as
they
are
now;

would
have
to
add
scrubber;

expect
to
be
closed
by
time
rule
takes
effect
Don't
know;

depends
on
what
they
decide
to
do
Unsure
No
No
Test
data?
6.75
tpy
emissions
Yes;
when
raised
stack
(
at
town
hall)
Yes;
on
file
with
State
Yes;
cannot
give
out
without
OK
from
Selectmen
Yes;
meas.
at
inlet
and
outlet,

but
inlet
very
low;
agreed
to
have
vendor
send
data
to
us
No
No
Option
selected?

­
Landfill
­
Comply
­
Exemptio
n
Send
to
transfer
station
(
unknown),

compact
waste,

then
landfill
Convert
to
transfer
station,
compact
waste,

haul
to
landfill;

won't
be
able
to
comply;

emission
controls
not
good;
it's
an
aging
incinerator;

odor
complaints
from
neighbors
Compact
waste;
trying
to
get
price
on
compactor
added
to
budget
for
next
yr;
may
have
Casella
Waste
or
someone
else
haul
off
waste;

equipment
doesn't
warrant
adding
more
controls;

fuel
costs
for
incinerator
also
very
high;

development
also
encroaching
on
facility
(
nuisance
factor)
Don't
yet
know;
could
follow
path
Hebron­
Bridgewater
facility
took
Comply;
need
more
time
to
make
it
work;

technology
not
there
yet
to
comply
Landfill
Apply
for
exemption
for
rural
IWI
(
continued)
Nickerson
Memorandum
5
October
16,
2005
Page
23
turning
knowledge
into
practice
Attachment
4.
OSWI
Contact
Summariesa
(
continued)

RTI
ID
39
130
143
144
145
146
149
150
274
Option
costs?

­
Landfill
­
Comply
­
Exemption
No
idea
about
cost,
could
take
several
yrs
before
have
to
shut
down
($
240,000­

landfill,

$
380,000­

comply)
Working
on
costs
now
($
246,000­

landfill,

$
380,000­

comply)
Don't
yet
know
($
532,000­

landfill,

$
498,000­

comply)
Don't
yet
know
($
680,000­

landfill,

$
602,000­

comply)
Don't
know
cost
to
comply
($
207,000­

landfill,

$
371,000­

comply)
See
next
item
for
estimated
landfill
costs
Landfill?

­
Name
­
Tipping
fee
­
Distance
­
Haul
cost
­
Use
transfer
station:
Triple
T
hauling
­
Pay
$
310/
per
compactor
pick­
up
+

$
90/
ton
disposal
fee
­
Compactor
holds
8­
10
tons
­
Use
4/
mo;

also
have
demo
boxes:

$
135/
box
pick­
up
+

$
90/
mo
rent
+

$
90/
ton
disposal
No
idea
(
could
assume
same
as
for
ash)

(
Conway:

$
55.95/
ton
NH
avge,
7.42
mi;

Tamworth:

$
55.95/
ton
NH
avge;

11.06
mi)
­
Rochester
­
$
82/
ton
(
Chartwell)

­
33.4
mi
(
MapPoint)

­
$
136/
haul
(
Chester:

$
55.95/
ton
NH
avge,
10.08
mi;
Amherst:

$
80/
ton
co.

avge,
29.96
mi)
Don't
know
(
could
assume
same
as
for
ash)

(
Amherst:

$
80/
ton
co.

avge,
12.04
mi;
Nashua:

$
80/
ton
co.

avge;
13.16
mi)
Same
as
for
ash
(
New
Ipswich:

$
80/
ton
co.

avge,
8.68
mi;
Amherst:

$
80/
ton
co.

avge,
10.08
mi)
N/
A
(
could
assume
same
as
for
ash)

(
Hebron:

$
69.26/
ton
co.

avge,
13.16
mi;

Franklin,

$
40.50/
ton,
25.9
mi)
This
facility
is
a
private,

not­
for­
profit
company
that
provides
services
to
businesses
in
the
area;
incinerator
was
used
to
burn
paper,

wood,
&
cardboard;
essentially,

this
is
a
service
they
will
no
longer
provide.
­
Houghton
transfer
station
­
$
60/
ton
(
Chartwell)

­
Self­
haul:
0.8
ton/
mo,
1
extra
trip
every
2
wks,
20­
mi
round
trip
(
1
hr
time
+
mileage
cost),
labor
­
Annual
cost
about
$
1,415
(
Greenland:

$
54.2/
ton,

39.06
mi;
Marquette:

$
38.58/
ton,

83.02
mi)

Save
$
if
landfill?
Not
willing
to
put
money
into
it
Yes,
but
breakeven
point
gets
closer
and
closer
Don't
yet
know
N/
A
N/
A
No
(
continued)
Nickerson
Memorandum
5
October
16,
2005
Page
24
turning
knowledge
into
practice
Attachment
4.
OSWI
Contact
Summariesa
(
continued)

RTI
ID
39
130
143
144
145
146
149
150
274
Annual
revenue?
$
3MM
guess
($
9.28MM)
$
1.5­
1.7MM
($
8.64MM)
Don't
know;

could
get
from
town
hall
($
16.3MM)
Don't
know
($
8.23MM)
$
750,000/
yr
raised
in
taxes;

30%
of
revenue
for
waste
mgmt
($
2.15MM)
$
3.8MM
annual
budget
(
but
have
7%

cut
next
year)

($
2.1MM)

Other
factors?
Closed
due
to
South
Coast
AQMD
emission
limits
that
they
could
not
meet
Closed
due
to
State
emission
limits
that
they
could
not
meet
Burn
records,

contraband
from
police;

rabid
animal
remains
from
Fish
&
Game
Burn
records,

contraband
from
police;

lot
of
materials
from
Fish
&

Game
Don't
want
to
throw
away
what
they
have
already
spent;

methane
gas
from
landfills
Eliminating
their
service
could
increase
barrel
burning
of
the
wastes
a
Original
RTI
estimates
highlighted
in
parentheses.
Nickerson
Memorandum
5
October
16,
2005
Page
25
turning
knowledge
into
practice
Attachment
5.
Revised
and
Original
Cost
Estimatesa
RTI
ID
Facility
Name
Location
LF
Codeb
Road
Distance
(
miles)
Tipping
Fee
($/
ton)
Daily
Throughput
(
tpd)
Annual
Operating
Days
(
d/
yr)
Annual
Throughput
(
tpy)
Landfill
Disposal
Costs
($/
yr)
Incinerator
Operation
Costs
($/
yr)
Compliance
Costs
($/
yr)

39
Seagull
Sanitation
Systems,
Pebbly
Beach
Disposal
Site
Incinerator
Avalon,
CA
­­

(
CA1613)
­­

(
40.88)
­­
($
42.87)
­­

(
12.238)
­­

(
260)
­­

(
3,182)
­­
($
201,453)
­­
($
133,830)
­­
($
333,295)

130
Town
of
Readsboro
Incinerator
Readsboro,
VT
­­

(
VT0050)
­­

(
26.04)
­­
($
45.00)
­­

(
12.5)
­­

(
269)
­­

(
3,358)
­­
($
194,851)
­­
($
138,710)
­­
($
342,994)

143
Ossipee
Incinerator
Facility
Ossipee,
NH
NH0058
(
NH0119)
66.1
(
7.42)
$
67.00
($
55.95)
3.1875
(
15)
312
(
269)
994.5
(
4,030)
$
99,500
($
240,430)
$
71,453
($
157,194)
$
212,971
($
379,939)

144
Town
of
Candia
Candia,
NH
NH0056
(
NH0027)
33.4
(
10.08)
$
82.00
($
55.95)
5.625
(
15)
208
(
269)
1,170
(
4,030)
$
115,479
($
245,790)
$
76,676
($
157,194)
$
222,625
($
379,939)

145
Town
of
Litchfield
Incinerator
&

Recycling
Facility
Litchfield,
NH
VT0011
(
NH0131)
145
(
12.04)
$
107.60
($
80.00)
4.3
(
23)
260
(
269)
1,118
(
6,179)
$
201,352
($
531,546)
$
75,135
($
215,549)
$
219,765
($
498,163)

146
Wilton
Recycling
Center
Wilton,
NH
NH0072
(
NH0053)
60.3
(
8.68)
$
16.67
($
80.00)
8
(
30)
104
(
269)
832
(
8,060)
$
38,954
($
679,780)
$
66,544
($
265,980)
$
204,033
($
601,609)

149
Hebron­
Bridgewater
Refuse
District
Bridgewater,
NH
NH0024
(
NH0077)
50.5
(
25.9)
$
77.91
($
45.00)
3.5
(
14.4)
182
(
269)
637
(
3,869)
$
65,713
($
206,787)
$
60,529
($
152,772)
$
86,526
($
371,072)

150
Shelby
County
Community
Services
Shelbyville,
IL
­­

(
IL0191)
­­

(
33.6)
­­
($
30.00)
­­

(
6)
­­

(
260)
­­

(
1,560)
­­
($
73,008)
­­
($
88,072)
­­
($
244,077)

274
Jeffers
High
School
Painesdale,
MI
MI0178
(
MI0012)
10
(
39.06)
$
60.00
($
54.20)
0.32
(
1.953)
30
(
228)
9.6
(
445)
$
1,415
($
32,784)
$
0
($
54,394)
$
50
($
182,727
)

(
continued)
Nickerson
Memorandum
5
October
16,
2005
Page
26
turning
knowledge
into
practice
Attachment
5.
Revised
and
Original
Cost
Estimatesa
(
continued)

RTI
ID
Facility
Name
Location
Option
1­
Shut
Down/
Landfill
($/
yr)
Option
2­

Comply
OSWI
($/
yr)
Low­
Cost
Option
($/
yr)
Fixed
Costs
@

90th%
Cap.

($/
yr)
Revenue
(
MM$)
Cost­
to­
Revenue
Ratio
>
CRR
of
0.5%?
(
1=
Yes,

0=
No)

39
Seagull
Sanitation
Systems,
Pebbly
Beach
Disposal
Site
Incinerator
Avalon,
CA
­­
($
67,623)
­­
($
333,295)
­­
($
67,623)
­­
($
167,474)
­­
($
1.75)
­­

(
9.57%)
­­

(
1)

130
Town
of
Readsboro
Incinerator
Readsboro,
VT
­­
($
56,140
)
­­
($
342,994)
­­
($
56,140)
­­
($
82,601)
­­
($
1.02)
­­

(
8.07%)
­­

(
1)

143
Ossipee
Incinerator
Facility
Ossipee,
NH
$
28,047
($
83,236)
$
212,971
($
379,939)
$
28,047
($
83,236)
­­
($
116,922)
$
9.28
($
9.28)
0.30%

(
1.26%)
0
(
1)

144
Town
of
Candia
Candia,
NH
$
38,803
($
88,595)
$
222,625
($
379,939)
$
38,803
($
88,595)
­­
($
123,666)
$
8.64
($
8.64)
0.45%

(
1.43%)
0
(
1)

145
Town
of
Litchfield
Incinerator
&

Recycling
Facility
Litchfield,
NH
$
126,216
($
315,997)
$
219,765
($
498,163)
$
126,216
($
315,997)
­­
($
410,381)
$
16.28
($
16.28)
0.78%

(
2.52%)
1
(
1)

146
Wilton
Recycling
Center
Wilton,
NH
­
$
27,590
($
413,801)
$
204,033
($
601,609)
­
$
27,590
($
413,801)
­­
($
533,882)
$
8.23
($
8.23)
­
0.34%

(
6.49%)
0
(
1)

149
Hebron­
Bridgewater
Refuse
District
Bridgewater,

NH
$
5,184
($
54,015)
$
86,526
($
371,072)
$
5,184
($
54,015)
­­
($
80,108)
$
2.15
($
2.15)
0.24%

(
3.73%)
0
(
1)

150
Shelby
County
Community
Services
Shelbyville,
IL
­­
($
15,088)
­­
($
333,295)
­­
($
15,088)
­­
($
69,174)
­­
($
7.048)
­­

(
0.98%)
­­

(
1)

274
Jeffers
High
School
Painesdale,
MI
$
1,415
(­
$
21,610)
$
50
($
182,727)
$
50
(­
$
21,610)
­­
($
38,801)
$
2.1
($
2.1)
<
0.1%

(
either
option)

(
1.85%)
0
(
1)

a
Original
RTI
estimates
highlighted
in
parentheses;
original
cost
estimates
are
central
tendency
costs;
original
CRR
determined
using
high­
end
costs.

b
Landfill
codes:
(
1)
CA1613
=
San
Diego,
CA;
(
2)
VT0050
=
Shaftsbury,
VT;
(
3)
NH0058
=
Berlin,
NH;
(
4)
NH0119
=
Conway,
NH;
(
5)
NH0056
=
Rochester,

NH;
(
6)
NH0027
=
Chester,
NH;
(
7)
VT0011
=
Montpelier,
VT;
(
8)
NH0131
=
Amherst,
NH;
(
9)
NH0053
=
New
Ipswich,
NH;
(
10)
NH0024
=
Bethlehem,
NH;

(
11)
NH0077
=
Franklin,
NH;
(
12)
IL0191
=
Effingham,
IL;
(
13)
MI0012
=
Greenland,
MI.
Transfer
station
codes:
(
1)
NH0072
=
Charlestown,
NH;
(
2)
MI0178
=
Houghton,
MI.
