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This
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version
of
the
Addendum
to
the
Assessment
of
Potential
Costs,
Benefits
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Replacement
Standards,
Proposed
Rule,
shows
all
changes
made
after
the
draft
version
of
this
Addendum
was
submitted
to
the
Office
of
Management
and
Budget
(
OMB)
in
December
of
2003.
Some
of
these
changes
were
made
as
a
result
of
discussions
with
OMB
while
many
others
were
made
by
EPA
in
response
to
ongoing
internal
review.
Changes
made
to
this
document
specifically
in
response
to
OMB
comments
are
identified
in
the
following
manner:
***
xxxxx***.
All
other
changes
were
made
by
EPA.
OMB
has
reviewed
and
approved
the
final
version
of
this
Addendum.

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ADDENDUM
TO
THE
ASSESSMENT
OF
THE
POTENTIAL
COSTS,
BENEFITS,
&
AND
OTHER
IMPACTS
OF
THE
HAZARDOUS
WASTE
COMBUSTION
MACT
REPLACEMENT
STANDARDS:
PROPOSED
RULE
Economics,
Methods,
and
Risk
Analysis
Division
Office
of
Solid
Waste
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Ave,
N.
W.
Washington,
DC
20460
December
2003
March
2004
TABLE
OF
CONTENTS
INTRODUCTION
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1
MAJOR
CHANGES
REFLECTED
IN
THE
ADDENDUM
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1
Changes
to
the
Proposed
Replacement
Standards
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1
Changes
to
the
Regulatory
Baseline
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Changes
in
Emissions
Projections
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7
REVISED
COST
AND
BENEFIT
ESTIMATES
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9
Revised
Cost
Analysis
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10
Engineering
Costs
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10
Social
Costs
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11
Distribution
of
Costs
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11
Revised
Economic
Impact
Estimates
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15
Revised
Benefits
Analysis
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15
EQUITY
CONSIDERATIONS
AND
OTHER
IMPACTS
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27
Assessment
of
Small
Entity
Impacts
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Children's
Health
Protection
Analysis
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Energy
Impact
Analysis
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20
Non­
air
Environmental
Impacts
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21
COST
EFFECTIVENESS
ANALYSIS
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21
APPENDICES
***
Appendix
A:
Potential
Benefits
Associated
with
SO
2
Emissions
Reductions
Achieved
Under
Beyond­
The­
Floor
Chlorine
Standards
for
Solid
Fuel
Boilers
and
LWAKs***
(
added
as
an
Appendix
in
response
to
OMB
review)

Appendix
B:
Detailed
Cost
Model
Results
Appendix
C:
Emissions
Reductions
Achieved
Under
the
Revised
Agency
Preferred
Approach
FINAL
DRAFT:
March
2004
1
All
options
include
chlorine
controls
for
HCl
production
furnaces.
With
or
without
chlorine
controls
pertains
to
§
112(
d)(
4)
of
the
Clean
Air
Act.

1
INTRODUCTION
The
purpose
of
this
Addendum
is
to
provide
revised
information
on
the
costs
and
benefits
of
the
Agency's
proposed
hazardous
waste
combustion
(
HWC)
MACT
replacement
standards.
This
aAddendum
is
necessary
because
the
Agency
revised
the
initialwe
have
revised
the
regulatory
baseline
as
well
as
the
***
total
chlorine
(
TCl)***
and
particulate
matter
(
PM)
standards,
as
evaluated
in
the
2004
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Replacement
Standards:
Proposed
Rule,
November
2003
(
the
2004
Assessment).
This
aAddendum
provides
revised
social
cost
and
benefit
estimates
for
six
options:
three
floor
options
and
three
"
beyond­
the­
floor"
(
BTF)
options
(
including
the
Agency
Preferred
Approach).
In
addition,
for
each
option
cost
estimates
are
estimated
"
with
chlorine
controls"
and
"
without
chlorine
controls."
1
Note,
however,
that
the
changes
in
the
PM
and
***
chlorine
standards***
affect
both
the"
with
chlorine
controls"
and
"
without
chlorine
controls"
versions
of
the
standards.
Finally,
this
Addendum
includes
a
discussion
of
potential
monetized
benefits
associated
with
reduced
dioxin
emissions
under
the
proposed
HWC
MACT
replacement
standards.

The
Addendum
is
organized
into
twofour
sections.
The
first
section
discusses
the
changes
we
made
to
the
proposed
chlorine
and
PM
replacement
standards
and
the
regulatory
baseline,
as
well
as
the
rationale
behind
these
changes.
The
standards
for
other
hazardous
air
pollutants
remain
unchangedThis
section
also
provides
revised
estimates
of
the
emissions
reductions
expected
as
a
result
of
the
replacement
standards.
The
second
section
summarizes
theprovides
revised
cost
and
benefit
estimates.
This
section
also
highlights
and
summarizes
major
changes
in
our
assessment
of
economic
impacts.

CHANGES
TO
THE
PROPOSED
PM
REPLACEMENT
STANDARDS
The
Agency
is
modifying
relative
to
estimates
presented
in
the
2004
Assessment.
The
third
section
of
the
Addendum
discusses
equity
impacts
of
the
proposed
replacement
standards
and
other
pertinent
regulatory
concerns.
The
Addendum
concludes
with
a
presentation
of
revised
cost­
effectiveness
estimates.

MAJOR
CHANGES
REFLECTED
IN
THE
ADDENDUM
This
Addendum
provides
results
that
reflect
Agency
revisions
to
the
proposed
HWC
MACT
replacement
standards,
regulatory
baseline,
and
the
emissions
reductions
anticipated
in
response
to
the
revised
standards.
We
discuss
the
nature
and
rationale
for
these
changes
below.
FINAL
DRAFT:
March
2004
2
The
Agency
also
considered
the
likelihood
that
solid
fuel
boiler
and
LWAK
facilities
may
qualify
for
risk­
based
emission
limits
(
instead
of
technology­
based
emissions
limits)
pursuant
to
§
112(
d)(
4)
of
the
Clean
Air
Act.

2
Changes
to
the
Proposed
Replacement
Standards
We
have
altered
our
proposed
standards
for
PM
***
and
chlorine***.
The
modifications
related
to
chlorine
reflect
the
Agency's
interpretation
of
beyond­
the­
floor
cost­
effectiveness,
and
the
changes
associated
with
PM
are
consistent
with
updates
to
EPA
methods
for
estimating
emissions.

Revised
Chlorine
Standards
***
As
illustrated
in
Exhibit
1,
we
have
revised
the
proposed
chlorine
replacement
standards
for
solid
fuel
boilers
and
lightweight
aggregate
kilns
(
LWAKs)
under
the
Agency
Preferred
Approach.
The
revised
chlorine
standards
under
the
Agency
Preferred
Approach
do
not
require
solid
fuel
boilers
or
LWAKs
to
meet
a
beyond­
the­
floor
standard
for
chlorine.
Therefore,
the
Agency
Preferred
Approach
for
solid
fuel
boilers
is
now
440
parts
per
million
by
volume
(
ppmv),
compared
to
the
standard
of
110
ppmv
presented
in
the
2004
Assessment.
Similarly,
the
chlorine
standard
for
LWAKs
under
the
revised
Agency
Preferred
Approach
is
600
ppmv
instead
of
150
ppmv
as
presented
in
the
2004
Assessment.
These
changes
reflect
the
Agency's
determination
that
the
beyond­
the­
floor
standards
for
TCl
are
not
cost­
effective2***.

Revised
PM
Standards
The
Agency
has
modified
the
proposed
PM
MACT
replacement
standards
to
reflect
updated
methods
of
characterizing
the
technical
features
of
individual
combustion
systems.
In
developing
the
PM
MACT
replacement
standards
presented
in
the
2004
Assessment,
wethe
Agency
relied
upon
a
database
containing
detailed
information
on
the
performance
characteristics
of
individual
combustion
systems.
This
included,
including
the
effectiveness
of
fabric
filters
installed
at
facilities
that
emit
PM.
Although
several
years'
worth
of
data
are
available
for
several
fabric
filters,
the
PM
standards
analyzed
in
the
2004
Assessment
reflect
only
the
most
recent
performance
data
associated
with
each
filter.
To
achieve
a
more
representative
assessment
of
the
performance
of
each
fabric
filter,
we
decided
to
augment
itsSince
completing
the
analysis
for
the
2004
Assessment,
we
have
determined
that
estimates
of
fabric
filter
performance
that
account
for
less
recent
data
would
better
represent
the
variation
in
fabric
filter
performance
over
time.
The
Agency
has
therefore
augmented
the
summary
of
each
fabric
filter's
performance
with
less
recent
data
reflecting
system
trial
burns,
risk
burns,
and
certification
and
compliance
testing.
Since
MACT
standards
are
based
on
the
technological
characteristics
of
the
lowest
emitting
sources
in
the
regulated
universe,
we
are
now
amendinghave
amended
the
proposedpreviously
established
HWC
PM
MACT
replacement
standards
for
PM.
FINAL
DRAFT:
March
2004
3
Exhibit
1
summarizes
the
updated
PM
replacement
standards
for
the
Agency
Preferred
Approach,
as
well
as
thosethe
PM
standards
includedevaluated
under
the
Agency
Preferred
Approach
in
the
November
20034
Assessment.
As
the
tableExhibit
1
indicates,
the
updated
PM
standards
for
allmost
source
categories
under
the
Agency
Preferred
Approach
are
less
stringent
than
the
standards
originally
presentedanalyzed
in
the
2004
Assessment.
FINAL
DRAFT:
March
2004
3
Design
levels
for
the
proposed
HWC
MACT
replacement
standards
are
estimated
as
the
average
performance
of
the
top
performing
systems.

4
Design
levels
are
usually
represented
as
a
percentage
of
the
regulatory
standard.
For
example,
a
firm
with
a
design
level
of
70
percent
would
attempt
to
meet
an
emissions
standard
of
0.010
g/
dscf
by
targeting
an
emissions
level
of
0.007.

5
In
this
case,
fabric
filter
performance
in
more
recent
years
appears
to
have
decreased
from
previous
levels.

4
Exhibit
1
PARTICULATE
MATTER
(
PM)
REPLACEMENT
STANDARDS
UPDATED
AND
PREVIOUS
STANDARDS
FOR
PM
AND
CHLORINE
REPLACEMENT
MACT
MACT
Source
Category
Updated
ProposalPM
Standards
(
gr/
dscf)
Previous
PM
Standards
(
gr/
dscf)
***
Updated
Cl
Standards***
(
ppmv)
Previous
Cl
Standards
(
ppmv)

Agency
Preferred
Approach
Incinerators
0.01985
0.010
1.5
ppmv
1.5
ppmv
Cement
Kilns
0.0280
0.014
110
ppmv
110
ppmv
LWAKs
0.02915
0.017
***
600
ppmv***
150
ppmv
Solid
Fuel
Boilers
0.0630
0.030
***
440
ppmv***
110
ppmv
Liquid
Fuel
Boilers
0.03102
0.026
2.5E­
2
lbs
of
Cl
in
HW
per
MMBtu
in
HW
2.5E­
2
lbs
of
Cl
in
HW
per
MMBtu
in
HW
HCl
Production
Furnaces
TCl
as
surrogate
TCl
as
surrogate
14
ppmv
or
99.9927%
SRE
14
ppmv
or
99.9927%
SRE
Consistent
with
less
stringent
PM
standards,
the
updatedwe
have
estimated
new
PM
design
levels
for
most
source
categories
(
i.
e.,
the
self­
imposed
PM
emissions
ceilings
that
systems
try
not
to
surpass
to
ensure
that
they
do
not
violate
the
standards).
3,4
These
revised
design
levels
affect
our
cost
analysis;
lower
design
levels
(
i.
e.,
more
stringent
design
levels)
require
facilities
to
install
more
expensive
(
and
more
effective)
abatement
technologies.
For
most
source
categories,
the
revised
design
levels
are
also
less
stringent
thanrelative
to
those
associated
with
the
previous
PM
replacement
standards
evaluated
in
the
2004
Assessment.
However,
because
of
methodological
changes
in
estimating
fabric
filter
effectiveness,
as
outlined
above,
the
updated
PM
design
level
for
liquid
boilers
is
lower
(
i.
e.,
more
stringent)
than
that
estimated
for
the
2004
Assessment.
5
In
the
currentupdated
analysis,
we
estimate
a
liquid
boiler
PM
design
level
of
0.0127
gr/
dscfgrams
per
dry
square
cubic
foot
FINAL
DRAFT:
March
2004
5
(
g/
dscf)
to
meet
the
proposed
standard
of
0.032
g/
dscf,
whereas
we
previously
applied
an
estimateestimated
a
design
level
of
0.014
gr/
dscf.
Because
of
this
decline
in
the
estimated
liquid
boiler
PM
design
level,
the
estimates
of
liquid
boiler
compliance
costs
presented
in
the
following
section
exceed
those
presented
in
the
Assessment.
The
PM
design
level
for
coal
boilers
is
also
more
stringent
under
the
revised
standards,
but
this
change
has
no
impact
on
estimates
of
coal
boiler
costs.
PM
design
levels
for
all
other
source
categories
are
no
more
stringent
than
those
estimated
for
the
Assessment.

REVISED
COST
AND
BENEFIT
ESTIMATES
In
addition
to
the
modifications
to
the
proposed
PM2004
Assessment.
FINAL
DRAFT:
March
2004
6
Design
levels
for
the
2002
Interim
Standards
were
estimated
as
the
product
of
the
2002
Interim
Standards
and
the
ratio
of
the
design
level
of
the
proposed
replacement
standards
to
the
proposed
replacement
standards
themselves.
For
example,
the
cement
kiln
design
level
for
chlorine
under
the
proposed
replacement
standards
is
66
ppmv,
and
the
proposed
chlorine
replacement
standards
for
cement
kilns
is
110
ppmv.
Since
the
2002
Interim
Standard
for
cement
kiln
emissions
of
chlorine
is
130
ppmv,
the
corresponding
design
level
associated
with
the
2002
Interim
Standards
is
130
ppmv*(
66
ppmv)/(
110
ppmv),
or
78
ppmv.

6
Changes
to
the
Regulatory
Baseline
In
addition
to
revising
the
replacement
standards,
we
have
applied
revised
assumptions
and
methods
to
the
regulatory
baseline,
which
assumes
full
compliance
with
the
2002
Interim
Standards.
More
specifically,
the
2002
baseline
has
been
altered
to
reflect
both
design
level
changes
and
improvements
in
data
quality.

Typically,
a
regulatory
baseline
reflects
data
about
the
state
of
the
regulated
industry
or
industries
prior
to
the
regulation's
development.
However,
development
of
the
proposed
HWC
MACT
replacement
standards
described
above,
the
cost
and
benefit
estimates
presented
in
this
section
reflect
changes
in
PM
design
levels
estimatedoverlaps
with
the
implementation
of
the
2002
Interim
Standards.
The
Agency,
therefore,
developed
baseline
conditions
(
e.
g.,
baseline
emissions)
reflecting
facilities'
expected
responses
to
the
2002
Interim
Standards.
To
maintain
consistency
with
the
analysis
of
the
proposed
replacement
standards,
we
have
assumed
that
ratios
of
design
levels
to
standards
for
the
2002
Interim
Standards.
Similar
to
are
the
same
as
those
associated
with
the
proposed
replacement
standards.
6
Since
the
ratios
associated
with
the
replacement
standards
have
changed,
EPA
estimates
ofwe
re­
estimated
design
levels
associated
with
the
2002
Interim
Standards
have
changed
because
of
the
revised
technological
characterization
of
fabric
filters.
As
a
result,
EPA's
estimate
of
baseline
PM
emissions
for
the
replacement
standards
(
i.
e.,
PM
emissions
after
implementation
of.
This
modification
changes
estimates
of
both
the
reduction
in
PM
emissions
achieved
in
response
to
the
2002
Interim
Standards)
is
now
lower
for
some
source
categories
and
higher
for
others
than
was
estimated
for
the
Assessment.

Major
findings
of
the
current
analysis
are
as
follows:

$

Text
Was
Moved
From
Here:
1
$
Annualized
market­
adjusted
costs
of
the
Agency
Preferred
Approach
are
now
estimated
to
be
approximately
$
55.6
million,
which
is
approximately
3.6
percent
lower
than
the
$
57.6
million
estimate
presented
in
the
Assessment.

$
Boilers
bear
more
than
80
percent
($
45.2
million)
of
the
market
adjusted
costs
and
the
baseline
PM
emissions
assumed
for
the
analysis
of
the
proposed
HWC
MACT
replacement
standards.
This
reflects
the
fact
that
these
facilities
are
not
subject
to
any
emissions
requirementsNote
that
boilers
and
HCl
production
furnaces
are
not
affected
by
this
methodological
change
because
these
systems
are
not
regulated
under
the
2002
Interim
FINAL
DRAFT:
March
2004
7
Non­
detect
data
points
are
those
below
the
discernable
limits
of
emission
measurement
tools.
The
level
below
which
quantified
measurements
are
not
possible
is
referred
to
as
the
detection
limit.

7
Standards.
In
addition,
the
$
45.2
million
estimate
is
3
percent
greater
than
the
$
43.9
million
estimate
in
the
Assessment
because
of
the
design
level
changes
outlined
above.

$
Our
revised
analysis
indicates
that
economic
impacts
are
largely
unchanged
from
those
in
the
Assessment.
The
only
substantial
change
is
a
slight
reduction
in
employment
gains,
which
are
now
approximately
6
percent
lower
under
the
Agency
Preferred
Approach.

$
We
estimate
annual
health
benefits
of
approximately
$
4.5
million
associated
with
the
Agency
Preferred
Approach.
This
estimate
is
approximately
15
percent
lower
than
that
We
have
also
modified
estimates
of
baseline
metals
emissions
from
boilers
and
HCl
production
furnaces
to
reflect
changes
in
the
management
of
non­
detect
data
points
for
these
emissions.
7
In
developing
the
baseline
metals
emissions
presented
in
the
2004
Assessment
($
5.28
million).
Reduced
benefits
associated
with
chronic
bronchitis
make
up
approximately
75
percent
of
the
decline
in
estimated
benefits.

$
Visibility
benefits,
we
received
several
non­
detect
data
points
from
boilers
and
HCl
production
furnaces.
When
coding
these
data,
the
Agency
assumed
that
the
corresponding
detection
limits
would
reasonably
approximate
the
non­
detected
metals
emissions
of
each
combustion
system.
However,
several
boilers
and
HCl
production
furnaces
employed
rudimentary
measurement
techniques
incapable
of
capturing
small
yet
detectable
metals
emissions.
If
these
facilities
had
used
more
advanced
measurement
techniques,
they
would
have
applied
a
smaller
detection
limit
to
their
non­
detect
data
points.
Therefore,
the
conservative
assumption
that
non­
detected
emissions
were
equal
to
the
high
detection
limits
associated
with
the
revised
Agency
Preferred
Approach
of
the
replacement
standards
range
from
$
115,000
per
year
to
$
5.8
million
per
year.
This
reflects
a
14
percent
and
27
percent
decline,
respectively
from
the
monetized
visibility
benefits
estimatesrudimentary
measurement
techniques
likely
overstated
actual
emissions
associated
with
non­
detect
data
points.
The
Agency
has
therefore
re­
coded
boilers'
non­
detect
data
points
for
metals
emissions
as
half
the
detection
limit,
which
represents
the
central
tendency
between
zero
emissions
and
the
detection
limit.

Exhibit
2
presents
the
revised
baseline
emissions
estimates
(
i.
e.,
emissions
expected
in
the
presence
of
the
2002
Interim
Standards)
that
reflect
the
changes
to
the
design
levels
and
the
refined
treatment
of
non­
detect
emissions
data.
As
Exhibit
2
shows,
current
estimates
of
baseline
PM
emissions
from
cement
kilns
and
incinerators
are
lower
than
those
presented
in
the
2004
Assessment.
These
two
figures
represent
two
different
methodologies
for
estimating
visibility
benefits.
FINAL
DRAFT:
March
2004
8
Cost
Analysis
Text
Was
Moved
From
Here:
2
Annualized
engineering
costs
with
chlorine
controls
rangereductions
reflect
the
updated
PM
design
levels
for
these
systems;
we
now
estimate
more
stringent
cement
kiln
and
incinerator
PM
design
levels
of
0.0115
g/
dscf
and
0.00315
g/
dscf
respectively
for
the
2002
Interim
Standards,
compared
to
the
estimates
of
0.0214
g/
dscf
and
0.0033
g/
dscf
prepared
for
the
2004
Assessment.
In
contrast,
the
increase
in
baseline
PM
emissions
from
$
72.1
million
per
year
underLWAKs
reflects
a
less
stringent
LWAK
PM
baseline
design
level
of
0.0105
g/
dscf
compared
to
0.0088
g/
dscf
in
the
Option
1
Floor
to
approximately
$
135
million
per
year
under
the
Option
3
"
beyond
the
floor"
(
BTF).
Without
controls
on
chlorine,
annual
engineering
costs
range
from
$
52.7
million
under
the
Option
1
Floor
to
$
82.9
million
under
Option
3
BTF2004
Assessment.
When
chlorine
controlsSince
metals
are
included
in
the
standards,
costs
of
the
BTF
versions
of
Options
1,
2,
and
3
are
14.8
percent,
8.9
percent,
and
8.7
percent
greater
than
costs
associated
with
their
corresponding
floor
options.
2
Without
chlorine
controls,
these
differentials
are
9.5
percent,
6.4
percent,
and
6.7
percent
respectively.

Under
the
Agency
Preferred
Approach,
both
with
and
without
chlorine
controls,
liquid
boilers
bear
the
most
significant
portion
of
total
engineering
costs.
With
chlorine
controls,
liquid
boiler
engineering
costs
represent
approximately
54
percent
of
total
engineering
costs.
This
figure
increases
to
70
percent
of
engineering
costs
when
chlorine
controls
are
not
included
in
the
standards.

Text
Was
Moved
From
Here:
3
.

PM,
several
of
the
revised
baseline
metals
emissions
estimates
are
lower
than
those
presented
in
the
2004
Assessment.
As
illustrated
in
Exhibit
2,
revised
estimates
of
baseline
semi­
volatile
metals
(
SVM),
low­
volatile
metals
(
LVM),
and
mercury
emissions
for
boilers
are
lower
than
those
presented
in
the
2004
Assessment.
Across
most
other
source
categories,
estimates
of
baseline
LVM
emissions
are
also
lower
than
estimates
in
the
2004
Assessment.
FINAL
DRAFT:
March
2004
9
Exhibit
2
SUMMARY
OF
SOCIAL
COST
ESTIMATES
­
With
Chlorine
Controls
(
millions
of
2002
dollars)
BASELINE
EMISSIONS
SUMMARY
­
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDSa
Cement
KilnsaKil
ns
LWAKsaL
WAKs
Commercial
Incinerators
aIncinerator
s
On­
site
Incinerators
Liquid
BoilersCoal
Boilers
and
Process
Heaters
HCl
Production
Furnaces
Generator
s
that
currently
send
waste
to
commerci
al
facilitiesT
OTALbOp
tion
1
FloorMar
ketadjusted
Costs($
2.7
)($
0.1)($
10
.6)$
9.1$
36
.7$
1.5$
1.5
$
10.6$
46.4
Engineeri
ng
Costs$
6.5$

0.5$
3.7$
12
.8$
44.7$
1.

8$
1.5NA$
72.1TOTA
L
Dioxins/

Furans
(
g/
yr)
Revised
Estimate
4.6
2.1
0.6
1.0
2.0
2.6
12.9
2004
Assessment
Estimate
4.6
2.1
0.6
1.0
2.0
2.6
12.9
FINAL
DRAFT:
March
2004
10
Particulate
Matter
(
pounds/
year)
Revised
Estimate
1,700,000
44,000
63,000
151,000
6,800,000
80,000
8,800,000
2004
Assessment
Estimate
2,700,000
36,000
69,000
158,000
6,800,000
80,000
9,800,000
Mercury
(
pounds/
year)
Revised
Estimate
1,840
25
620
592
1,690
7
4,800
2004
Assessment
Estimate
1,840
25
620
592
1,793
7
4,900
Semi­
Volatile
Metals
(
pounds/
year)
Revised
Estimate
8,100
112
580
726
6,100
36
15,600
2004
Assessment
Estimate
8,400
108
579
736
7,700
36
17,500
Low­
Volatile
Metals
(
pounds/
year)
Revised
Estimate
513
67
331
565
29,100
150
30,700
2004
Assessment
Estimate
712
66
335
581
31,000
150
32,700
Chlorine
(
pounds/
year)
Revised
Estimate
3,800,000
835,000
106,000
485,000
10,700,000
306,000
16,200,000
2004
Assessment
Estimate
3,800,000
835,000
106,000
485,000
10,700,000
306,000
16,200,000
Notes:

a.
Emissions
estimates
are
presented
in
pounds
per
year
for
all
pollutants,
except
dioxins/
furans,
which
are
presented
in
grams
per
year.
FINAL
DRAFT:
March
2004
11
Changes
in
Emissions
Projections
We
have
changed
projections
of
the
emissions
reductions
achieved
in
response
to
the
standards
to
reflect
the
changes
to
the
regulatory
baseline
and
the
proposed
HWC
MACT
replacement
standards
have
been
revised,.
Exhibit
3
presents
the
updated
projections
of
the
percentage
reduction
in
emissions,
by
pollutant
and
source
category.
In
addition,
Appendix
C
to
this
Addendum
provides
numerical
estimates
(
in
tons)
of
the
emissions
reductions
achieved
under
the
revised
HWC
MACT
replacement
standards.
For
some
pollutants,
these
revised
projections
represent
a
significant
change
from
the
projections
presented
in
the
2004
Assessment.
For
example,
under
the
Agency
Preferred
ApproachMarket­
adjusted
Costs($
5.4)$
3.3($
11.4)$
9.1$
36.8$
5.0$
3.4$
14.2$
55.6Engineering
Costs$
6.5$
4.2$
3.7$
12.8$
44.9$
6.9$
3.4NA$
82.8Option
2
FloorMarket­
adjusted
Costs$
0($
1.1)($
14.9)$
11.7$
47.2$
1.5$
1.8$
33.2$
80.0Engineering
Costs$
28.0$
0.8$
4.7$
16.6$
60.4$
1.8$
1.8NA$
114.7Option
2
BTFMarket­
adjusted
Costs($
2.4)$
2.0($
15.5)$
11.7$
47.4$
5.0$
3.4$
36.6$
88.6Engineering
Costs$
28.0$
4.1$
4.7$
16.6$
60.7$
6.9$
3.4NA$
124.9
of
the
replacement
standards,
we
no
longer
expect
reductions
in
PM
emissions
from
LWAKs
or
incinerators
Text
Was
Moved
From
Here:
4
$
1.9($
15.9)$
12.2$
54.9$
5.0$
4.1$
38.5$
100.3Engineering
Costs$
29.7$
4.2$
4.8$
17.0$
67.8$
6.9$
4.1NA$
135.0
Text
Was
Moved
From
Here:
5
b.
Government
administrative
costs
are
included
i
(
commercial
and
on­
site).
In
the
total
social
cost
estimates.
Government
costs
range
from
$
4202004
Assessment,
000
to
$
447,000
per
year
across
all
six
marker­
adjusted
cost
options.
For
the
upper
bound
estimate,
under
which
all
systems
upgrade
and
there
is
no
market
adjustment,
annual
government
costsAgency
projected
that
PM
emissions
would
befall
by
at
least
25
percent
for
each
of
these
sources.
Furthermore,
the
Agency
now
expects
cement
kiln
PM
emissions
to
fall
by
approximately
$
543,0005
percent,
compared
to
the
40­
45
percent
reduction
reported
in
the
2004
Assessment.
In
contrast,
the
reduction
in
boiler
PM
emissions
will
be
slightly
greater
under
the
revised
HWC
MACT
replacement
standards
than
projected
in
the
2004
Assessment.

These
changes
in
PM
projections
affect
the
Agency's
SVM
and
LVM
emissions
projections.
Since
SVM
and
LVM
are
distributed
within
PM,
metals
emissions
fluctuate
with
changes
in
PM
emissions.
Consequently,
we
now
expect
cement
kiln
SVM
emissions
to
fall
by
20­
30
percent,
compared
to
the
45­
55
percent
reduction
presented
in
the
2004
Assessment.
Similarly,
the
Agency's
revised
estimate
of
the
reduction
in
cement
kiln
LVM
emissions
is
approximately
one­
third
lower
than
the
corresponding
estimate
in
the
2004
Assessment.
LVM
emissions
from
LWAKs
and
incinerators
are
now
expected
to
decline
by
less
than
10
percent,
instead
of
by
23­
28
percent
as
previously
estimated.
The
emissions
reductions
presented
in
Exhibit
3
do
not
capture
the
5.4
tons
of
reduced
FINAL
DRAFT:
March
2004
8
Non­
enumerated
metals
include
manganese,
cobalt,
nickel,
selenium,
and
antimony.

9
In
addition
to
the
emissions
reductions
presented
in
the
2004
Assessment,
solid
fuel
boilers'
compliance
with
the
chlorine
standards
under
the
Agency
Preferred
Approach
proposed
in
the
2004
Assessment
would
reduce
SO2
emissions
by
approximately
22,000
tons
per
year
as
a
result
of
the
implementation
of
dry
scrubber
systems
to
control
chlorine.
Appendix
A
to
this
Addendum
contains
an
analysis
of
the
benefits
associated
with
this
reduction
in
SO2
emissions.
Note,
however,
that
these
reductions
are
not
anticipated
under
the
updated
Agency
Preferred
Approach
that
eliminates
beyond
the
floor
(
BTF)
standards
for
coal­
fired
boilers
and
LWAKs.

12
non­
enumerated
metals
emissions
associated
with
the
revised
PM
standards.
8
Projected
emissions
reductions
for
chlorine
have
also
changed
relative
to
those
presented
in
the
2004
Assessment,
reflecting
EPA's
decision
to
eliminate
beyond­
the­
floor
chlorine
controls
for
solid
fuel
boilers
and
LWAKs.
As
Exhibit
3
indicates,
the
***
Agency
now
expects
no
reduction
in
LWAK's
chlorine
emissions
under
the
Agency
Preferred
Approach***,
compared
to
the
reduction
of
nearly
70
percent
associated
with
the
LWAK
chlorine
standard
presented
in
the
2004
Assessment.
Similarly,
***
we
now
expect
a
20
percent
reduction
in
boiler
emissions
of
chlorine***;
the
2004
Assessment
reported
an
estimated
35
percent
reduction.
***
The
analytical
assumption
supporting
these
modifications
to
projected
chlorine
emissions
also
eliminates
the
22,000
ton­
per­
year
reduction
in
SO
2
emissions
that
would
have
been
achieved
under
the
version
of
the
Agency
Preferred
Approach***
analyzed
in
the
2004
Assessment.
9
Exhibit
3
Text
Was
Moved
From
Here:
6
TOTALbOption
1
FloorPERCENT
CHANGE
IN
AGGREGATE
EMISSIONS
UNDER
AGENCY
PREFERRED
APPROACH
FINAL
DRAFT:
March
2004
13
0%
20%
40%
60%
80%
100%
120%

D/
F
PM
Hg
SVM
LVM
TCl
Percent
Change
Cement
Kilns
LWAKs
Commercial
Incinerators
Onsite
Incinerators
Boilers
and
Process
Heaters
HCl
Production
Furnaces
For
on­
site
and
commercial
incinerators,
cement
kilns,
and
LWAKs,
percent
change
in
emissions
is
relative
to
the
2002
Interim
Standards.
For
boilers
and
HCl
production
furnaces,
percent
change
is
relative
to
the
1991
RCRA
Boiler
and
Industrial
Furnaces
rule.

REVISED
COST
AND
BENEFIT
ESTIMATES
The
cost
and
benefit
estimates
presented
in
this
document
are
consistent
with
the
analytical
framework
described
in
Chapters
4,
5,
and
6
of
the
2004
Assessment.
Detailed
model
results
are
included
in
Appendix
B
to
this
Addendum.
Additional
information
on
the
economic
model
used
to
develop
cost
estimates
is
available
in
Appendix
D
of
the
2004
Assessment.

Major
findings
of
the
current
analysis
are
as
follows:

Text
Moved
Here:
1
E
°
The
analysis
now
estimates
upper
bound
engineering
costs
of
***$
8277.89***
million
per
year
are
now
estimated
for
the
Agency
Preferred
Approach,
with
chlorine
controls.
This
represents
a
3n
8.29
percent
reduction
compared
to
the
estimate
of
$
85.5
million
presented
in
the
2004
Assessment.
FINAL
DRAFT:
March
2004
10
The
avoided
mortality
benefits
included
in
this
estimate
were
calculated
in
1999
dollars,
in
contrast
to
estimated
morbidity
benefits
and
estimated
social
costs,
which
were
estimated
in
2002
dollars.
Therefore,
estimated
total
benefits
are
not
comparable
to
estimates
of
costs.

14
End
Of
Moved
Text
°
Market­
adjusted
Costs($
0.
costs
of
the
***
Agency
Preferred
Approach
with
chlorine
controls
are
now
estimated
to
be
approximately
$
50.0
million,
which
is
approximately
13.2
percent
lower
than
the
$
57.6
million
estimate
presented
in
the
2004
Assessment***.

°
Boilers
and
HCl
production
furnaces
bear
approximately
83
percent
($
41.5
million)
of
the
costs
of
the
proposed
replacement
standards.
This
reflects
the
fact
that
these
facilities
are
not
subject
to
any
emissions
requirements
under
the
2002
Interim
Standards.
In
addition,
the
$
41.5
million
estimate
is
5.5
percent
less
than
the
$
43.9
million
estimate
in
the
2004
Assessment
because
of
the
elimination
of
beyond­
the­
floor
chlorine
standards
for
solid
fuel
boilers.

°
Estimates
of
economic
impacts
are
largely
unchanged
from
those
in
the
2004
Assessment.
Estimated
employment
gains
are
now
approximately
6
percent
lower
under
the
Agency
Preferred
Approach.
In
addition,
the
analysis
now
projects
an
increase
of
1.05
percent
in
combustion
pricing,
as
opposed
to
the
1.4
percent
increase
presented
in
the
2004
Assessment.

°
Monetized
health
benefits
associated
with
the
Agency
Preferred
Approach
are
approximately
$
4.50
million.
10
This
estimate
is
approximately
8.2
percent
greater
than
that
presented
in
the
2004
Assessment.

°
Visibility
benefits
associated
with
the
revised
Agency
Preferred
Approach
of
the
replacement
standards
range
from
$
106,300
per
year
to
$
5.78
million
per
year.
These
two
figures
represent
two
different
methodologies
for
estimating
visibility
benefits.
Estimates
in
the
2004
Assessment
ranged
from
$
105,800
to
$
7.41
million
per
year.

Revised
Cost
Analysis
Text
Moved
Here:
2
Revised
engineering
and
market­
adjusted
cost
estimates
are
presented
in
Exhibit
23
and
Exhibit
34.
The
market­
adjusted
costs
included
in
these
exhibits
reflect
a
100
percent
cost
passthrough
consistent
with
the
market­
adjusted
costs
presented
in
Exhibit
5­
7
of
the
2004
Assessment.
WithUnder
the
revised
PM
replacement
standards
revised,
total
costs
for
each
option
included
in
the
2004
Assessment
have
decreased.
The
engineering
costs
of
the
Agency
Preferred
Approach
with
chlorine
controls
are
now
estimated
at
***$
8277.89***
million
per
year,
compared
to
$
85.5
million
FINAL
DRAFT:
March
2004
11
As
explained
in
the
2004
Assessment,
the
Agency
Preferred
Approach
is
the
beyond­
the­
floor
version
of
the
Option
1
Floor.

15
in
the
2004
Assessment.
Similarly,
the
total
social
costs
of
the
Agency
Preferred
Approach
with
chlorine
controls
are
now
approximately
***$
550.60***
million
per
year,
compared
to
$
57.6
million
per
year
in
the
2004
Assessment.
End
Of
Moved
Text
7)$
0.1($
7.0)$
1.0$
32.6$
1.0$
1.5$
7.4$
36.2
Engineering
Costs
Annualized
engineering
costs
with
chlorine
controls
range
from
$
572.91
million
per
year
under
the
Option
1
Floor
to
approximately
$
130.5$
1
million
per
year
under
the
Option
3
"
beyond
the
floor"
(
BTF).
0$
1.5$
40.3$
1.3$
1.5NA
Without
controls
on
chlorine,
annual
engineering
costs
range
from
$
52.7
million
under
the
Option
1
Floor
to
$
82.9
million
under
Option
3
BTF.
When
chlorine
controls
are
included
in
the
standards,
costs
of
the
BTF
versions
of
Options
1,
2,
and
3
are
8.0
percent,
5.0
percent,
and
5.1
percent
greater
than
costs
associated
with
their
corresponding
floor
options.
11
Without
chlorine
controls,
these
differentials
are
9.5
percent,
6.4
percent,
and
6.7
percent,
respectively.

Average
per­
system
engineering
costs
associated
with
the
revised
Agency
Preferred
Approach
with
chlorine
controls
have
changed
for
several
source
categories.
***
Per­
system
costs
for
coal
boilers
are
now
$
286,400,
which
represents
a
46
percent
reduction***
compared
to
the
estimate
of
$
528,009
per
system
presented
in
the
2004
Assessment.
In
addition,
revised
per
system
cement
kiln
engineering
costs,
approximately
$
245,400
per
system,
are
24
percent
lower
than
the
estimate
of
$
323,700
presented
in
the
2004
Assessment.
Commercial
and
on­
site
incinerator
per­
system
engineering
costs,
$
239,400
and
$
135,800
respectively,
are
now
approximately
$
20,000
lower
than
the
corresponding
estimates
presented
in
the
2004
Assessment.
***
Average
LWAK
engineering
costs
have
fallen
by
$
192,600
per
system***
to
$
394,100.
In
contrast,
per­
system
engineering
costs
for
liquid
boilers,
$
378,300,
have
increased
by
approximately
3.3
percent
relative
to
the
estimate
of
$
366,000
per
system
presented
in
the
2004
Assessment.
Per­
system
engineering
costs
for
HCl
production
furnaces
are
unchanged.

Social
Costs
Text
Moved
Here:
3
W
Market­
adjusted
costs
when
the
standards
include
chlorine
controls,
market­
adjusted
costs
range
from
$
46.4
million
under
the
Option
1
Floor
to
$
100$
94.37
million
under
Option
3
BTF.
Without
chlorine
controls,
this
range
is
$
36.2­
$
64.9
million.
As
mentioned
above,
annual
social
costs
associated
with
the
Agency
Preferred
Approach
with
chlorine
controls
are
***$
550.60***
million.
These
costs
are
approximately
207.8
percent
more
than
the
costs
of
the
Option
1
Floor
and
nearly
50approximately
36
percent
lower
than
the
engineering
costs
of
the
Agency
Preferred
Approach3.
End
Of
Moved
Text
FINAL
DRAFT:
March
2004
16
M
Compared
to
estimates
presented
in
the
2004
Assessment,
market­
adjusted
costs
for
cement
kilns
and
on­
site
incinerators
under
the
Agency
Preferred
Approach
are
now
slightly
lower.
Similarly,
estimates
of
coal
boiler
and
LWAK
costs
are
also
lower,
reflecting
the
elimination
of
beyond­
the­
floor
chlorine
controls
for
these
sources.
In
contrast,
current
estimates
of
liquid
boiler
costs
are
higher
than
their
corresponding
estimates
in
the
2004
Assessment
due
to
a
lower
(
i.
e.,
more
stringent)
estimate
of
the
PM
design
level
for
liquid
boilers
under
the
replacement
standards.
Our
estimate
of
commercial
incinerator
savings
is
now
slightly
lower
since
combustion
prices
do
not
increase
as
much
under
the
revised
standards.
Estimates
of
HCl
production
furnace
costs
are
unchanged.

Distribution
of
Costs($
2.0)$
1.7($
7.4)$
1.0$
32.7$
2.2$
3.4$
9.2$
41.1Engineering
C
Among
source
categories,
boilers
and
HCl
production
furnaces
bear
the
most
significant
portion
of
total
engineering
and
market­
adjusted
costs
associated
with
the
proposed
HWC
MACT
replacement
standards.
This
distribution
of
costs
reflects
the
focus
of
past
regulation
on
incinerators
and
commercial
kilns.
The
2002
Interim
Standards
did
not
regulate
boilers
and
HCl
production
furnaces;
the
proposed
replacement
standards
are
the
first
hazardous
waste
combustion
MACT
regulations
to
address
these
systems.

Under
the
Agency
Preferred
Approach,
boiler
and
HCl
production
furnace
engineering
costs
represent
approximately
two­
thirds
of
total
engineering
costs.
This
figure
increases
to
80
percent
of
engineering
costs
when
chlorine
controls
are
not
included
in
the
Agency
Preferred
Approach.
Similarly,
boilers
and
HCl
production
furnaces
incur
83
percent
of
total
social
costs
under
the
Agency
Preferred
Approach
and
more
than
92
percent
of
social
costs
when
chlorine
controls
are
excluded
from
these
standards.
Boilers
and
HCl
production
furnaces
represent
a
higher
percentage
of
marketadjusted
costs
than
engineering
costs
because
these
systems,
unlike
commercial
incinerators
and
commercial
kilns,
are
unable
to
offset
engineering
costs
by
managing
waste
commercially.
FINAL
DRAFT:
March
2004
17
Exhibit
4
SUMMARY
OF
SOCIAL
COST
ESTIMATES
­
With
Chlorine
Controls
(
millions
of
2002
dollars)

Cement
Kilnsa
$
5.9LW
AKsa
$
2.3Commer
cial
Incinerators
b
$
1.0On­
site
Incinerators
$
1.5Liqui
d
Boilers
$
40.4Coa
l
Boilers
$
2.6HCl
Production
Furnaces
$
3.4Generators
that
currently
send
waste
to
commercial
facilities
NA$
57.7
TOTALc
Option
21
Floor
Market­
adjusted
Costs
($
12.37)
($
0.41)
($
10.6)
$
9.1)
$
36.4$
33.

27
$
1.05
$
1.85
$
210.46
$
5246.34
Engineering
Costs
$
17$
6.5
$
0.5
$
3.7
$
0.8$
2$
12.0$

4.8
$
414.1$
1.

37
$
1.8
$
1.5
NA
$
702.21
Option
2
BTFAgen
cy
Preferred
Approach
Market­
adjusted
Costs
($
05.24)
***$
1.05
($
911.4)
$
9.1
$
36.8
***$
1.3
$
3.4
$
33.14$
2.2
$
350.4$
2
1.9$
56.60
Engineering
CostsCostsd
$
17$
6.5
$
2.8***
$
3.7
$
12.3$
2.0$
4.

8
$
414.39
$
23.64**

*
$
3.4
NA
$
747.79
Option
32
Floor
Market­
adjusted
Costs
$
1.20
($
01.41)
($
9.4$
14.9)
$
411.07
$
3947.2
$
1.05
$
1.8
$
22.4$
33.2
$
680.10
Engineering
Costs
$
1928.50
$
0.9$
2.1$

5.58
$
46$
4.7
$
16.06
$
60.4
$
1.38
$
1.8
NA
$
77$
114.

7
Option
32
BTF
Market­
adjusted
Costs
($
02.14)
$
0.92
($
915.75)
$
411.07
$
39$
47.4
$
1.3
$
23.24
$
436.16
$
283.8$
6
4.90
Engineering
CostsCostsd
$
19.5$
2.3
$
2.1$
5.5$

46.2$
28.0
$
3.0
$
4.7
$
16.6
$
60.7
$
3.4
$
3.4
NA
$
120.4
Text
Moved
Here:
4
Option
3
Floor
Market­
adjusted
Costs
$
1.7
($
1.1)
($
15.2)
$
12.2
$
54.7
$
1.5
$
1.8
$
35.3
$
91.3
Engineering
Costs
$
29.7
$
0.9
$
4.8
$
17.0
$
67.6
$
1.8
$
1.8
NA
$
124.2
Option
3
BTF
Market­
adjusted
Costs
($
0.9)
End
Of
Moved
Text
$
0.1
($
15.9)
$
12.2
$
54.9
$
1.3
$
4.1
$
38.5
$
94.7
FINAL
DRAFT:
March
2004
18
Engineering
Costsd
$
29.67
$
3.1
$
4.8
$
17.0
$
67.8
$
3.4
$
4.1
NA
$
82$
130.

95
NOTES:

a.
***
Social
cost
estimates
presented
here
are
adapted
from
estimates
that
reflect
the
change
in
the
proposed
PM
standards
but
not
the
change
in
the
proposed
chlorine
standards
for
coal
boilers
and
LWAKs.
To
generate
our
estimate,
we
subtracted
the
incremental,
floor
to
beyond­
the­
floor
LWAK
and
coal
boiler
chlorine
control
costs
estimated
in
the
2004
Assessment
from
social
cost
estimates
that
reflected
the
updated
PM
proposal
but
not
the
updated
chlorine
proposal.***

ab.
Social
cost
estimates
for
commercial
systems
reflect
simplifying
assumptions
that
all
commercial
facilities
are
able
to
charge
the
same
prices
for
each
waste
type
(
e.
g.,

"
halogenated
waste")
and
are
able
to
increase
prices
in
order
to
offset
cost
increases.
These
estimates
may
understate
social
costs
to
commercial
kilns
if
these
systems
are
unable
to
increase
prices
and
charge
lower
prices
for
waste
with
lower
halogen
content.
However,
while
commercial
kiln
costs
reflect
some
uncertainty,
total
social
costs
estimates
are
not
significantly
affected,
because
changes
in
assumptions
about
commercial
kiln
combustion
pricing
generally
reflect
a
transfer
from
waste
generators
to
kilns.
The
Economic
Assessment
developed
for
this
rule
describes
a
sensitivity
analysis
that
addresses
the
uncertainty
associated
with
cement
kiln
costs.

bc.
GTotals
will
not
add
due
to
rounding.
In
addition,
government
administrative
costs
are
included
in
the
total
social
cost
estimates.
Government
costs
range
from
$
4270,000
to
$
45547,000
per
year
across
all
six
market­
adjusted
cost
options.
For
the
upper
bound
estimate,
under
which
all
systems
upgrade
and
there
is
no
market
adjustment,

annual
government
costs
are
approximately
$
543,000.
Compared
to
estimates
presented
in
the
Assessment
(
Exhibit
5­
7),
market­
adjusted
costs
(
with
chlorine
­
Exhibit
2)
are
now
slightly
lower
for
cement
kilns
and
marginally
higher
for
commercial
incinerators,
under
d.
Updated
estimates
of
beyond­
the­
floor
engineering
costs
are
available
in
U.
S.
EPA,
"
Technical
Support
Document
for
the
HWC
MACT
Standards,
Volume
V:

Emission
Estimates
and
Engineering
Costs,"
February
2004.
The
updated
results
in
the
technical
support
document
reflect
co­
control
cost
savings
associated
with
beyond­
the­
floor
dioxin
controls
for
LWAKs
and
beyond­
the­
floor
PM
controls
for
coal
boilers.
Under
the
Agency
Preferred
Approach.
In
contrast,
current
estimates
of
liquid
boiler
costs
are
higher
than
their
corresponding
estimates
in
the
Assessment
because
we
have
reduced
our
estimate
of
the
PM
design
level
for
liquid
boilers
under
the
replacement
standards
.
Similarly,
estimates
of
LWAK
costs
are
also
higher
because
the
PM
design
level
for
the
2002
Interim
Standards
is
now
higher.
This
higher
design
level
for
the
2002
Interim
Standards
implies
that
updated
estimates,
updated
engineering
costs
are
approximately
$
77.2
million.
FINAL
DRAFT:
March
2004
19
Exhibit
5
Text
Moved
Here:
6
SUMMARY
OF
SOCIAL
COST
ESTIMATES
­
No
Chlorine
Controls
(
millions
of
2002
dollars)

Cement
Kilnsa
LWAKsa
Commercial
Incinerators
a
On­
site
Incinerators
Liquid
Boilers
Coal
Boilers
HCl
Production
Furnaces
Generators
that
currently
send
waste
to
commercial
facilities
End
Of
Moved
Text
of
LWAK
emissions
in
the
baseline
exceed
estimates
used
for
the
Assessment.

TOTALb
Option
1
Floor
Market­
adjusted
costs
for
on­
site
incinerators
are
reduced
by
about
11
percent
from
the
estimate
presented
in
the
Assessment.

Estimates
of
coal
boiler
and
HCl
production
furnace
costs
remain
unchanged
from
those
in
the
Assessment.

Costs
($
0.7)
$
0.1
($
7.0)
$
1.0
$
32.6
$
1.0
$
1.5
$
7.4
$
36.2
Engineering
Costs
$
5.9
$
0.5
$
1.0
$
1.5
$
40.3
$
1.3
$
1.5
NA
$
52.7
Agency
Preferred
Approach
Market­
adjusted
Costs
($
2.0)
$
1.7
($
7.4)
$
1.0
$
32.7
$
2.2
$
3.4
$
9.2
$
41.1
Engineering
Costs
$
5.9
$
2.3
$
1.0
$
1.5
$
40.4
$
2.6
$
3.4
NA
$
57.7
Option
2
Floor
Market­
adjusted
Costs
$
1.3
($
0.4)
($
9.1)
$
3.4
$
33.2
$
1.0
$
1.8
$
20.4
$
52.3
Engineering
Costs
$
17.7
$
0.8
$
2.0
$
4.8
$
41.1
$
1.3
$
1.8
NA
$
70.2
FINAL
DRAFT:
March
2004
20
Option
2
BTF
Market­
adjusted
Costs
$
0.2
$
1.0
($
9.4)
$
3.4
$
33.4
$
2.2
$
3.4
$
21.9
$
56.6
Engineering
Costs
$
17.7
$
2.3
$
2.0
$
4.8
$
41.3
$
2.6
$
3.4
NA
$
74.7
Option
3
Floor
Market­
adjusted
Costs
$
1.2
($
0.4)
($
9.4)
$
4.0
$
39.2
$
1.0
$
1.8
$
22.4
$
60.1
Engineering
Costs
$
19.5
$
0.9
$
2.1
$
5.5
$
46.0
$
1.3
$
1.8
NA
$
77.7
Option
3
BTF
Market­
adjusted
Costs
($
0.1)
$
0.9
($
9.7)
$
4.0
$
39.3
$
2.2
$
4.1
$
23.8
$
64.9
Engineering
Costs
$
19.5
$
2.3
$
2.1
$
5.5
$
46.2
$
2.6
$
4.1
NA
$
82.9
Text
Moved
Here:
5
NOTES:

a.
Social
cost
estimates
for
commercial
systems
reflect
simplifying
assumptions
that
all
commercial
facilities
are
able
to
charge
the
same
prices
for
each
waste
type
e.
g.,

"
halogenated
waste")
and
are
able
to
increase
prices
in
order
to
offset
cost
increases.
These
estimates
may
understate
social
costs
to
commercial
kilns
if
these
systems
are
unable
to
increase
prices
and
charge
lower
prices
for
waste
with
lower
halogen
content.
However,
while
commercial
kiln
costs
reflect
some
uncertainty,
total
social
costs
estimates
are
not
significantly
affected,
because
changes
in
assumptions
about
commercial
kiln
combustion
pricing
generally
reflect
a
transfer
from
waste
generators
to
kilns.
The
Economic
Assessment
developed
for
this
rule
describes
a
sensitivity
analysis
that
addresses
the
uncertainty
associated
with
cement
kiln
costs.

End
Of
Moved
Text
b.
Totals
will
not
add
due
to
rounding.
In
addition,
government
administrative
costs
are
included
in
the
total
social
cost
estimates.
Government
costs
range
from
$
427,000
to
$
455,000
per
year
across
all
six
options.
For
the
upper
bound
estimate,
under
which
all
systems
upgrade,
annual
government
costs
are
approximately
$
543,000.
FINAL
DRAFT:
March
2004
12
This
estimate
reflects
beyond­
the­
floor
chlorine
controls
for
LWAKs
and
coal
boilers.
Since
the
Agency
has
eliminated
beyond­
the­
floor
chlorine
standards
for
these
systems,
estimated
job
gains
may
be
lower
than
the
estimate
presented
in
this
Addendum.

13
This
estimated
price
increase
reflects
the
beyond­
the­
floor
standard
that
the
Agency
considered
for
LWAKs.
Since
LWAKs
are
not
required
to
meet
beyond­
the­
floor
chlorine
controls
under
the
revised
Agency
Preferred
Approach,
the
estimated
increase
in
commercial
combustion
prices
may
be
lower
than
presented
in
this
Addendum.

21
Major
Revisions
toRevised
Economic
Impact
Estimates
Estimates
of
economic
impacts
change
very
little
from
those
included
in
the
2004
Assessment.
The
only
notable
changes
are
inEstimated
employment
gains,
which
decrease
by
approximately
6
percent
in
the
current
analysis.
With3
percent
to
559
full­
time
equivalents
under
the
revised
Agency
Preferred
Approach.
12
This
reflects
the
fact
that
with
less
stringent
PM
standards
for
several
facilities,
fewer
labor
resources
will
be
required
to
comply
with
the
standards.
In
addition,
we
now
estimate
that
combustion
prices
may
increase
by
approximately
1.05
percent
as
a
result
of
the
replacement
standards,
compared
to
the
projected
1.4
percent
increase
reported
in
the
2004
Assessment.
13
Market
exits
are
virtually
unchanged
from
exits
reported
in
the
2004
Assessment.
Since
market
exits
do
not
change
considerably,
no
major
changes
occur
in
the
estimated
quantity
of
hazardous
waste
reallocated.

Benefits
Analysis
Monetized
health
benefits
of
approximately
$
4.5
million
per
year
are
estimated
for
the
revised
version
of
the
Agency
Preferred
Approach.
This
is
a
decline
of
about
15
percent
from
the
$
5.28
million/
yr
estimate
presented
in
the
Assessment.
This
revised
estimate
reflects
changes
in
the
proposed
PM
standards
as
well
as
an
adjustment
to
the
inflation
factor
EPA
used
to
estimate
benefits.
4
Across
other
options,
monetized
health
benefits
were
found
to
range
from
$
4.4
million
to
$
8.3
million.
Overall,
monetized
health
benefits
were
found
to
be
approximately
15­
19
percent
lower
than
those
presented
in
the
Assessment.
For
(
e.
g.,
120,855
tons
under
the
Agency
Preferred
Approach,
reduced
chronic
bronchitis
benefits
represent
approximately
75
percent
of
this
decline.
Reduced
benefits
associated
with
premature
deaths
and
minor
restricted
activity
represent
most
of
the
remaining
25
percent.

Under
the
revised
PM
replacement
standards,
we
estimated
annual
visibility
benefits
associated
with
the
Agency
Preferred
Approach
ranging
from
$
115,000
to
$
5.8
million.
The
low
end
of
this
range,
which
is
a
decline
of
about
14
percent
from
the
low­
end
estimate
($
134,000)
in
the
Assessment,
assumes
a
linear
relationship
between
health
benefits
and
visibility
benefits.
In
contrast,
the
higher
FINAL
DRAFT:
March
2004
14
The
revised
estimates
of
SVM
and
LVM
emissions
reductions
described
above
have
no
effect
on
monetized
benefits
estimates,
which
are
based
completely
on
estimated
PM
emission
reductions.

22
of
the
two
estimates
assumes
a
linear
relationship
between
PM
emissions
reductions
and
visibility
improvements.
This
figure
is
approximately
27
percent
lower
than
the
high­
end
estimate
($
8
million))
does
not
change
as
a
result
of
the
changes
to
the
proposed
standards.

Most
of
the
revised
estimates
of
other
industry
impacts
(
e.
g.,
changes
in
the
profitability
and
cost
structure
of
the
combustion
industry)
are
similar
to
estimates
presented
in
the
2004
Assessment.
Similar
to
the
current
estimates
of
health
benefits,
changes
in
the
low­
end
and
high­
end
visibility
estimates
reflect
less
stringent
PM
standards
and
an
adjustment
to
the
inflation
factor
EPA
applied
in
the
analysis.
Both
estimates
are
based
on
results
presented
in
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010.5However,
we
now
estimate
that
cement
kiln
and
commercial
incinerator
waste
burning
costs
may
increase
by
10.3
percent
and
1.3
percent
respectively,
compared
to
the
potential
increases
of
14
percent
and
3.9
percent
reported
in
the
2004
Assessment.
In
addition,
the
Agency
now
estimates
a
possible
9
percent
increase
in
cement
kiln
pollution
control
costs.
This
is
nearly
3
percentage
points
lower
than
the
11.9
percent
increase
that
we
had
previously
estimated
in
the
2004
Assessment.

Revised
Benefits
Analysis
This
section
provides
updated
estimates
of
the
health
and
visibility
benefits
associated
with
the
revised
replacement
standards.
The
benefits
analysis
has
been
revised
to
include
the
following:


*
**
Monetized
benefits
associated
with
reduced
dioxin
emissions,***


Revised
estimates
of
benefits
associated
with
reduced
PM
emissions,
reflecting
changes
to
the
baseline
and
the
proposed
standards
as
outlined
above,


*
**
Discounted
estimates
of
benefits
that
are
not
immediately
realized
after
emissions
are
reduced***.

The
results
presented
below
include
only
those
benefits
associated
with
reduced
PM
***
and
dioxin.
14***
Although
little
information
is
available
on
the
potential
magnitude
of
benefits
associated
with
reduced
emissions
of
the
other
pollutants
included
in
the
standards,
reductions
in
the
emissions
of
these
pollutants
are
likely
to
improve
human
health.
For
example,
adverse
health
effects
associated
with
hydrogen
chloride
exposure
are
well
documented.
These
include
eye,
nose,
and
respiratory
tract
irritation;
pulmonary
edema;
gastritis;
bronchitis;
and
dermatitis.
Prolonged
exposure
to
low
concentrations
of
hydrogen
chloride
may
also
lead
to
dental
discoloration
and
erosion.
The
benefits
FINAL
DRAFT:
March
2004
15
The
"
with
chlorine
controls"
version
of
the
standards
analyzed
in
the
2004
Assessment
may
have
reduced
coal
boiler
emissions
of
SO2.
The
benefits
associated
with
this
emissions
reduction
are
not
included
in
the
2004
Assessment
or
in
the
primary
results
of
this
Addendum
but
are
provided
in
Appendix
A
of
this
Addendum.

23
associated
with
reducing
the
incidence
of
these
ailments
are
likely
to
be
lower
under
the
"
without
chlorine
controls"
version
of
each
option
than
the
corresponding
"
with
chlorine
controls"
option.

Our
estimates
of
the
physical
effects
associated
with
the
revised
PM
replacement
standards
are
presented
in
Exhibit
6.
The
exhibit
does
not
differentiate
between
"
with
chlorine
controls"
and
"
without
chlorine
controls"
versions
of
the
standards
because
***
none
of
the
quantified
benefits
presented
in
Exhibit
6
are
associated
with
reduced
chlorine
emissions.
15***

Most
of
the
quantified
reductions
in
physical
effects
reported
in
Exhibit
6
are
slightly
lower
than
the
corresponding
results
presented
in
the
2004
Assessment,
although
the
number
of
premature
deaths
is
largely
unchanged
across
all
regulatory
options.
Differences
between
current
and
previous
results
are
least
pronounced
under
the
Agency
Preferred
Approach.
Compared
to
results
presented
in
the
2004
Assessment,
0.1
fewer
cases
of
chronic
bronchitis
and
upper
respiratory
illness
are
avoided
each
year
under
the
Agency
Preferred
Approach.
In
addition,
0.4
fewer
work
loss
days
and
lower
respiratory
illness
cases
are
avoided
each
year
under
the
revised
Agency
Preferred
Approach.
Under
the
Option
1
Floor
and
the
Option
2
Floor,
annual
reductions
in
lower
respiratory
illness,
work
loss
days,
and
minor
restricted
activity
are
0.8,
3.4,
and
28
cases
less
respectively
than
estimates
presented
in
the
2004
Assessment.
Similarly,
0.1
fewer
cases
of
acute
and
chronic
bronchitis
and
upper
respiratory
illness
are
avoided
under
the
revised
Option
1
and
2
Floors.
Results
associated
with
the
revised
Option
3
Floor
differ
most
significantly
from
the
corresponding
estimates
presented
in
the
2004
Assessment.
Our
current
estimate
of
6,848.6
avoided
minor
restricted
activity
cases
represents
a
decline
of
438.6
avoided
cases
compared
to
the
annual
reductions
presented
in
the
2004
Assessment.
In
addition,
we
now
anticipate
the
avoidance
of
52.6
fewer
work
loss
days
per
year
and
of
5.1
fewer
lower
respiratory
cases
per
year
under
the
revised
Option
3
Floor.
Our
current
estimates
of
chronic
and
acute
bronchitis
cases
avoided
under
this
option
are
0.7
and
0.6
annual
cases
less
respectively
than
the
estimates
presented
in
the
2004
Assessment.
FINAL
DRAFT:
March
2004
16
USEPA,
1985.
Health
Assessment
Document
for
Polychlorinated
Dibenzo­
p­
Dioxins.
EPA/
600/
8­
84/
014F.
Final
Report.
Office
of
Health
and
Environmental
Assessment.
Washington,
DC.
September,
1985.

24
Exhibit
6
REDUCTION
IN
ANNUAL
INCIDENCE
OF
PHYSICAL
EFFECTS
ASSOCIATED
WITH
PM
Agency
Preferred
Approach
Option
1
Floor
Option
2
Floor
Option
2
BTF­
D
Option
3
Floor
Option
3
BTF­
D
Premature
deaths
avoided
0.3
0.3
0.3
0.3
0.6
0.6
Respiratory
illness
0.9
0.9
0.9
0.9
1.6
1.6
Cardiovascular
disease
0.4
0.4
0.4
0.4
0.7
0.7
Chronic
bronchitis
5.6
5.5
5.5
5.6
10.3
10.4
Acute
bronchitis
4.3
4.2
4.2
4.3
7.8
7.9
Lower
respiratory
symptoms
38.0
37.3
37.3
38.0
69.1
69.8
Upper
respiratory
symptoms
4.4
4.3
4.3
4.4
8.0
8.1
Work
loss
days
450.7
443.9
443.9
450.7
822.1
829.2
Minor
restricted
activity
days
3,754.4
3,698.1
3,698.1
3,754.4
6,848.6
6,907.4
Restricted
Activity
days
1,236.4
1,217.9
1,217.9
1,236.4
2,255.4
2,274.8
The
proposed
replacement
standards
are
also
likely
to
reduce
the
number
of
cancer
deaths
associated
with
dioxin/
furans
emissions.
The
Addendum
to
the
1999
Assessment
estimated
that
0.36
premature
cancer
deaths
would
be
avoided
annually
due
to
the
annual
emissions
reduction
of
28.7
grams
of
mass
doxin/
furans,
associated
with
the
1999
dioxin/
furan
standards.
***
Assuming
that
the
proportional
relationship
between
dioxin/
furans
emissions
and
premature
cancer
deaths
is
constant,
we
estimate
that
approximately
0.058
premature
cancer
deaths
will
be
avoided
on
an
annual
basis
under
the
Agency
Preferred
Approach
because
of
reduced
dioxin/
furans
emissions.
This
estimate
reflects
a
cancer
risk
slope
factor
of
1.56
x
105
[
mg/
kg/
day]­
1.
This
cancer
slope
factor
is
derived
from
the
Agency's
1985
health
assessment
document
for
polychlorinated
dibenzo­
p­
dioxins16
and
represents
an
upper
bound
95th
percentile
confidence
limit
of
the
excess
cancer
risk
from
a
lifetime
exposure.***
FINAL
DRAFT:
March
2004
17
U.
S.
EPA,
Exposure
and
Human
Health
Reassessment
of
2,3,7,8­
Tetrachlorodibenzo­
p­
Dioxin
(
TCDD)
and
Related
Compounds,
September
2000.
Note:
Toxicity
risk
factors
presented
in
this
document
should
not
be
considered
EPA's
official
estimate
of
dioxin
toxicity,
but
rather
reflect
EPA's
ongoing
effort
to
reevaluate
dioxin
toxicity.

25
***
For
the
past
12
years
the
Agency
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
dioxin
and
dioxin­
like
compounds.
This
reassessment17
will
soon
be
under
review
at
the
National
Academy
of
Sciences
(
NAS),
as
specified
by
Congress
in
the
Conference
Report
accompanying
EPA's
fiscal
year
2003
appropriation
(
Title
IV
of
Division
K
of
the
Conference
Report
for
the
Consolidated
Appropriations
Resolution
of
2003).
Evidence
compiled
from
this
draft
reassessment
indicates
that
the
carcinogenic
effects
of
dioxin/
furans
may
be
as
much
as
six
times
as
great
as
believed
in
1985,
reflecting
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.
Agency
scientists'
more
likely
(
central
tendency)
estimates
(
derived
from
the
ED
01
rather
than
the
LED
01)
result
in
slope
factors
and
risk
estimates
that
are
within
2­
3
times
of
the
upper
bound
estimates
(
i.
e.,
between
3
x
105
[
mg/
kg/
day]­
1
and
5
x
105
[
mg/
kg/
day]­
1)
based
on
the
available
epidemiological
and
animal
cancer
data.
Risks
could
be
as
low
as
zero
for
some
individuals.
Use
of
the
alternative
upper
bound
cancer
risk
slope
factor
would
result
in
up
to
0.35
premature
cancer
deaths
avoided
in
response
to
the
proposed
replacement
standards
for
dioxin/
furans.
The
assessment
of
upper
bound
cancer
risk
using
this
alternative
slope
factor
should
not
be
considered
Agency
policy.
The
proposed
standards
for
dioxin
in
today's
rule
were
not
based
on
this
draft
reassessment***.

***
Our
estimates
of
avoided
premature
cancer
deaths
associated
with
the
proposed
replacement
standards
for
dioxin
and
various
options
are
presented
in
Exhibit
7.
However,
since
dioxin
causes
several
other
health
effects,
such
as
impaired
development
and
reduced
fertility,
the
values
in
Exhibit
7
are
believed
to
underestimate
the
actual
benefits
associated
with
reduced
dioxin/
furans
emissions.***
FINAL
DRAFT:
March
2004
18
U.
S.
EPA,
Exposure
and
Human
Health
Reassessment
of
2,3,7,8­
Tetrachlorodibenzo­
p­
Dioxin
(
TCDD)
and
Related
Compounds,
September
2000.
Note:
Toxicity
risk
factors
presented
in
this
document
should
not
be
considered
EPA's
official
estimate
of
dioxin
toxicity,
but
rather
reflect
EPA's
ongoing
effort
to
reevaluate
dioxin
toxicity.

26
***
Exhibit
7***

REDUCTION
IN
ANNUAL
INCIDENCE
OF
PREMATURE
CANCER
DEATHS
ASSOCIATED
WITH
DIOXIN/
FURANSa,
b
Agency
Preferred
Approach
Option
1
Floor
Option
2
Floor
Option
2
BTF­
D
Option
3
Floor
Option
3
BTF­
D
0.058
0.005
0.005
0.058
0.005
0.058
Notes:

a.
The
primary
estimates
assume
that
the
proportional
relationship
between
cancer
deaths
and
dioxin/
furans
emissions
is
constant.
All
estimates
rely
on
results
of
the
risk
analysis
prepared
for
EPA,
Assessment
of
The
Potential
Costs,
Benefits
&
Other
Impacts
of
The
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
July
1999.
b.
As
discussed
in
the
text
above,
the
Agency
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
dioxin
and
dioxin­
like
compounds.
This
reassessment
will
soon
be
under
review
at
the
National
Academy
of
Sciences
(
NAS),
as
specified
by
Congress
in
the
Conference
Report
accompanying
EPA's
fiscal
year
2003
appropriation
(
Title
IV
of
Division
K
of
the
Conference
Report
for
the
Consolidated
Appropriations
Resolution
of
2003).
Evidence
compiled
from
this
draft
reassessment
indicates
that
the
carcinogenic
effects
of
dioxin/
furans
may
be
as
much
as
six
times
as
great
as
believed
in
1985,
reflecting
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.
Use
of
the
alternative
upper
bound
cancer
risk
slope
factor
would
result
in
up
to
0.35
premature
cancer
deaths
avoided
in
response
to
the
proposed
replacement
standards
for
dioxin/
furans.
The
assessment
of
upper
bound
cancer
risk
using
this
alternative
slope
factor
should
not
be
considered
Agency
policy.

***
A
detailed
accounting
of
the
monetized,
non­
discounted
benefits
of
the
revised
replacement
standards
is
presented
in
Exhibit
8.
Our
central
estimate
of
the
annual
health
benefits
associated
with
the
revised
version
of
the
Agency
Preferred
Approach
is
approximately
$
4.50
million,
reflecting
a
range
of
$
2.73
million
to
$
6.27
million.
The
central
estimate
of
$
4.50
million
represents
an
8.2
percent
increase
over
the
annual
benefits
of
$
4.16
million
reported
in
the
2004
Assessment.
This
increase
in
benefits
reflects
the
monetization
of
avoided
cancer
deaths
associated
with
reduced
dioxin/
furans
exposure;
these
benefits
were
not
monetized
in
the
2004
Assessment.
Across
all
three
beyond­
the­
floor
options,
our
primary
estimate
of
benefits
associated
with
reduced
dioxin
emissions
is
$
0.06
million
to
$
0.58
million.
Recent
evidence
suggests,
however,
that
the
toxicity
of
dioxin
may
be
as
much
as
six
times
greater
than
reflected
in
these
estimates.
18***
As
explained
above,
we
have
FINAL
DRAFT:
March
2004
27
also
made
minor
modifications
to
baseline
PM
emissions
and
the
proposed
PM
replacement
standards,
but
these
changes
have
little
impact
on
monetized
benefits
estimates
since
the
current
estimate
of
avoided
mortalities
is
nearly
the
same
as
that
presented
in
the
2004
Assessment.

Across
the
three
floor
options,
we
estimate
health
benefits
ranging
from
approximately
$
2.64
million
to
$
11.04
million,
compared
to
the
range
of
$
4.12
million
to
$
8.08
million
presented
in
the
2004
Assessment.
This
range
of
benefits
associated
with
the
revised
version
of
the
proposed
replacement
standards
reflects
a
VSL
range
of
$
1.0
million
to
$
10.0
million.
Benefits
are
greater
under
the
beyond­
the­
floor
versions
of
the
replacement
standards
because
the
PM
standards
for
solid
fuel
boilers
and
the
dioxin/
furans
standards
for
LWAKs,
liquid
fuel
boilers,
and
HCl
production
furnaces
are
more
stringent
under
the
BTF
options.
FINAL
DRAFT:
March
2004
28
Exhibit
8
MONETIZED
NON­
DISCOUNTED
VALUE
OF
BENEFITS
ASSOCIATED
WITH
THE
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDS
(
2002
Dollars
in
Millions)
a
Type
of
Benefit
Agency
Preferred
Approach
Option
1
Floor
Option
2
Floor
Option
2
BTF­
D
Option
3
Floor
Option
3
BTF­
D
Human
Health
Benefits
­
Particulate
Matterb
Premature
deaths
avoidedc
$
1.84
($
0.34
­
$
3.35)
$
1.81
($
0.33
­
$
3.30)
$
1.81
($
0.33
­
$
3.30)
$
1.84
($
0.34
­
$
3.36)
$
3.36
($
0.61
­
$
6.10)
$
3.39
($
0.62
­
$
6.16)

Respiratory
illness
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
Cardiovascular
disease
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
Chronic
bronchitis
$
2.12
$
2.09
$
2.09
$
2.12
$
3.87
$
3.91
Acute
bronchitis
$
0
$
0
$
0
$
0
$
0
$
0
Lower
respiratory
symptoms
$
0
$
0
$
0
$
0
$
0
$
0.01
Upper
respiratory
symptoms
$
0
$
0
$
0
$
0
$
0
$
0
Work
loss
days
$
0.05
$
0.05
$
0.05
$
0.05
$
0.09
$
0.09
Minor
restricted
activity
$
0.15
$
0.15
$
0.15
$
0.15
$
0.27
$
0.27
***
Human
Health
Benefits
­
Dioxin/
Furans***

Premature
cancer
deaths
avoided
(
primary
estimate)
d
$
0.32
($
0.06
­
$
0.58)
$
0.03
($
0.01
­
$
0.05)
$
0.03
($
0.01
­
$
0.05)
$
0.32
($
0.06
­
$
0.58)
$
0.03
($
0.01
­
$
0.05)
$
0.32
($
0.06
­
$
0.58)

Annual
Monetized
Health
Benefitse,
f,
g
$
4.50
($
2.73
­
$
6.27)
$
4.14
($
2.64
­
$
5.65)
$
4.14
($
2.64
­
$
5.65)
$
4.50
(
2.73
­
$
6.27)
$
7.65
($
4.88
­
$
10.42)
$
8.01
($
4.97
­
$
11.04)

Visibilityh
Total
Visibility
Benefits
­
PM
emissions
$
0.11
­
$
5.78
$
0.10
­
$
4.43
$
0.10
­
$
4.43
$
0.11
­
$
5.88
$
0.19
­
$
8.03
$
0.20
­
$
9.44
Total
Annual
Monetary
Benefitsf
$
2.84
­
$
12.05
$
2.74
­
$
10.08
$
2.74
­
$
10.08
$
2.84
­
$
12.15
$
5.07
­
$
18.45
$
5.17
­
$
20.48
FINAL
DRAFT:
March
2004
Exhibit
8
MONETIZED
NON­
DISCOUNTED
VALUE
OF
BENEFITS
ASSOCIATED
WITH
THE
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDS
(
2002
Dollars
in
Millions)
a
29
Notes:
a.
***
Benefits
associated
with
avoided
mortality
are
presented
in
1999
dollars
and
benefits
associated
with
avoided
morbidity
are
presented
in
2002
dollars***.
b.
To
avoid
potential
double
counting
with
benefits
related
to
minor
restricted
activity
days,
we
do
not
provide
monetized
estimates
associated
with
restricted
activity
days.
c.
***
Monetized
benefits
associated
with
avoided
premature
mortality
reflect
a
VSL
range
of
$
1.0
million
to
$
10.0
million,
with
a
central
VSL
estimate
of
$
5.5
million.
These
values
are
consistent
with
those
presented
in
U.
S.
EPA,
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
January
2004.
However,
these
VSL
values
are
in
1999
dollars
and
are
therefore
inconsistent
with
morbidity
and
cost
estimates,
which
are
presented
in
2002
dollars***.
d.
***
The
primary
estimate
of
dioxin
benefits
presented
here
reflects
EPA's
current
guidance
on
the
cancer
risk
(
1.5
x
105
[
mg/
kg/
day]­
1)
associated
with
dioxin/
furans.
These
values
reflect
a
VSL
range
of
$
1.0
million
to
$
10.0
million.
As
discussed
in
the
text
above,
the
Agency
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
dioxin
and
dioxin­
like
compounds.
This
reassessment
will
soon
be
under
review
at
the
National
Academy
of
Sciences
(
NAS),
as
specified
by
Congress
in
the
Conference
Report
accompanying
EPA's
fiscal
year
2003
appropriation
(
Title
IV
of
Division
K
of
the
Conference
Report
for
the
Consolidated
Appropriations
Resolution
of
2003).
Evidence
compiled
from
this
draft
reassessment
indicates
that
the
carcinogenic
effects
of
dioxin/
furans
may
be
as
much
as
six
times
as
great
as
believed
in
1985,
reflecting
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.
Use
of
the
alternative
upper
bound
cancer
risk
slope
factor
would
result
in
up
to
0.35
premature
cancer
deaths
avoided
in
response
to
the
proposed
replacement
standards
for
dioxin/
furans.
The
assessment
of
upper
bound
cancer
risk
using
this
alternative
slope
factor
should
not
be
considered
Agency
policy***.
e.
***
This
estimate
differs
from
benefits
associated
with
the
standards
presented
in
the
2004
Assessment
in
that
it
does
not
include
benefits
associated
with
beyond­
the­
floor
chlorine
standards
for
solid­
fuel
boilers
or
LWAKs.
As
explained
in
Appendix
A
of
this
Addendum,
the
solid
fuel
boiler
beyond­
the­
floor
standard
for
chlorine
analyzed
in
the
2004
Assessment
(
110
ppmv)
would
have
reduced
emissions
of
SO2,
a
PM
precursor,
by
approximately
22,000
tons
per
year.
Adapting
from
benefits
estimates
presented
in
U.
S.
EPA,
2003
Technical
Addendum:
Methodologies
for
the
Benefit
Analysis
of
the
Clear
Skies
Act
of
2003,
September
2003
and
U.
S.
EPA,
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
January
2004,
we
estimate
that
the
benefits
associated
with
the
solid
fuel
boiler
beyond­
the­
floor
standard
for
chlorine
would
yield
annual
health
benefits
of
approximately
$
288.5
million
(
in
2002
dollars)
under
the
Agency
Preferred
Approach***
f.
Totals
may
not
add
due
to
rounding.
g.
***
Because
of
the
uncertainty
associated
with
the
"
high
cancer
risk"
estimate
of
dioxin
benefits,
this
estimate
is
not
included
in
the
total
benefits
estimates
presented
in
this
exhibit.***
h.
***
This
estimate
differs
from
benefits
associated
with
the
standards
presented
in
the
2004
Assessment
in
that
it
does
not
include
benefits
associated
with
beyond­
the­
floor
chlorine
standards
for
solid­
fuel
boilers
or
LWAKs
(
see
note
b).
As
illustrated
in
Appendix
B
of
this
Addendum,
the
benefits
associated
with
the
solid
fuel
boiler
beyond­
the­
floor
standard
for
chlorine
analyzed
in
the
2004
Assessment
could
yield
annual
visibility
benefits
of
approximately
$
6.06
million
(
in
2002
dollars)
under
the
Agency
Preferred
Approach.
***

In
addition
to
benefits
resulting
from
reduced
PM
emissions,
the
2004
Assessment
also
provided
general
estimates
of
the
health
benefits
associated
with
reduced
metals
emissions.
The
Addendum
to
the
1999
Assessment
estimated
that
the
reduction
in
lead
emissions
associated
with
the
1999
standards
would
reduce
lead
exposure
below
levels
of
concern
(
i.
e.,
a
blood
level
of
at
least
10
µ
g/
dl)
for
seven
children
annually.
However,
the
relatively
modest
reduction
in
lead
emissions
expected
under
the
proposed
HWC
MACT
replacement
standards
suggests
that
the
replacement
standards
will
reduce
lead
exposure
below
levels
of
concern
for
fewer
than
seven
children
annually.
FINAL
DRAFT:
March
2004
19
U.
S.
EPA,
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010,
November
1999.
20
Jim
Neumann
and
Bob
Unsworth,
Addenda
to
Mortality
Valuation
Methodology,
internal
memorandum
submitted
to
Jim
DeMocker,
September
28,
1993.
21
U.
S.
EPA,
2003
Technical
Addendum:
Methodologies
for
the
Benefit
Analysis
of
the
Clear
Skies
Act
of
2003,
September
2003
30
Under
the
revised
PM
replacement
standards,
we
estimate
annual
visibility
benefits
associated
with
the
Agency
Preferred
Approach
ranging
from
$
106,300
to
$
5.78
million.
The
low
end
of
this
range,
which
is
approximately
0.5
percent
greater
than
the
low­
end
estimate
in
the
2004
Assessment,
assumes
a
linear
relationship
between
health
benefits
and
visibility
benefits.
In
contrast,
the
higher
of
the
two
estimates
assumes
a
linear
relationship
between
PM
emissions
reductions
and
visibility
improvements
and
is
approximately
22
percent
lower
than
the
high­
end
estimate
presented
in
the
2004
Assessment.
Across
other
regulatory
options,
the
lower
estimate
ranges
from
$
104,600
to
$
195,500
per
year,
which
represents
a
0.3
to
4.9
percent
decline
compared
to
the
low­
end
estimates
presented
in
the
2004
Assessment.
Varying
between
$
4.43
and
$
9.44
million
annually,
the
high­
end
estimates
for
these
options
are
approximately
25
percent
less
than
the
corresponding
results
in
the
2004
Assessment.
Similar
to
the
current
estimates
of
health
benefits,
changes
in
the
low­
end
and
high­
end
visibility
estimates
reflect
less
stringent
PM
standards
and
an
adjustment
to
the
inflation
factor
applied
in
the
analysis.
Both
estimates
are
based
on
results
presented
in
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010.1919
Chapter
6
of
the
2004
Assessment
contains
additional
information
on
the
methodologies
associated
with
both
estimates.

This
analysis
does
not
quantify
The
annual
emissions
reductions
achieved
under
the
HWC
MACT
replacement
standards
may
not
have
an
immediate
impact
on
public
health.
***
Specifically,
avoided
mortalities
resulting
from
annual
reductions
in
PM
and
dioxin/
furans
emissions
may
occur
over
a
period
of
several
years.
For
example,
the
epidemiological
literature
suggests
that
premature
mortality
associated
with
dioxin/
furans
emissions
may
not
occur
until
21
to
34
years
following
exposure.
20
Similarly,
the
premature
mortalities
resulting
from
PM
emissions
may
be
distributed
over
the
five
years
subsequent
to
exposure.
21
Since
a
portion
of
the
benefits
associated
with
reduced
chlorine
emissions
under
the
proposed
HWC
MACT
replacement
standards
because
little
information
is
available
on
the
potential
magnitude
of
these
benefits.
However,
adverse
health
effectsmay
materialize
over
a
period
of
several
years,
we
estimated
discounted
benefits
as
a
sensitivity
analysis***.
The
results
of
this
analysis
are
presented
in
Exhibit
9.
For
comparison,
Exhibit
9
also
includes
non­
discounted
benefits.
FINAL
DRAFT:
March
2004
31
***
Exhibit
9***

Comparison
of
Discounted
And
Non­
discounted
Benefits
of
the
Hazardous
Waste
Combustion
MACT
Replacement
Standards
Benefit
Category
and
Pollutant
Monetized
Valuea,
b
(
million
2002
dollars
per
year)

Non­
discounted
Three
Percent
Discount
Rate
Seven
Percent
Discount
Rate
Human
Health
Benefits
Dioxin/
Furansc:
Baseline
to
Floor
­
Floor
to
Beyond­
the­
Floor
­

Baseline
to
Beyond­
the­
Floor:
$
0.03
$
0.29
$
0.32
$
0.01
­
$
0.02
$
0.11
­
$
0.16
$
0.12
­
$
0.17
$
0.003
­
$
0.01
$
0.03
­
$
0.07
$
0.03
­
$
0.08
Particulate
Matterd:
Mortality
­
Morbidity
­

Baseline
to
Beyond­
the­
Floor:
$
1.84
$
2.34
$
4.18
$
1.70
$
2.34
$
4.04
$
1.54
$
2.34
$
3.87
TCle:
Not
monetized
Not
monetized
Not
monetized
Mercury:
Not
monetized
Not
monetized
Not
monetized
Lead:
Not
monetized
Not
monetized
Not
monetized
Human
Health
Sub
Total:
f
$
4.50
$
4.15
­
$
4.21
$
3.91
­
$
3.95
Visibility
Benefits:

Visibility
Sub­
total
Particulate
Matter:
$
0.11
­
$
5.78
$
0.11
­
$
5.78
$
0.11
­
$
5.78
Grand
Total
f
$
4.61
­
$
10.28
$
4.26
­
$
9.99
$
4.02
­
$
9.73
FINAL
DRAFT:
March
2004
***
Exhibit
9***

Comparison
of
Discounted
And
Non­
discounted
Benefits
of
the
Hazardous
Waste
Combustion
MACT
Replacement
Standards
32
Notes:

a.
Estimates
of
monetized
benefits
presented
in
this
exhibit
reflect
a
central
VSL
estimate
of
$
5.5
million.
This
value
reflects
the
mean
of
the
estimated
VSL
95
percent
confidence
interval
estimated
for
U.
S.
EPA,
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
January
2004.
In
contrast,
estimates
in
Exhibit
8
reflect
this
central
value
and
the
$
1
million
to
$
10
million
range.
b.
Benefits
associated
with
chlorine
exposure
are
well
documented.
These
include
eye,
nose,
and
respiratory
tract
irritation;
pulmonary
edema;
gastritis;
bronchitis,
asthma
and
swelling
of
the
lungs;
headaches;
heart
disease;
meningitis;
and
death.
The
avoided
mortality
are
expressed
in
1999
dollars,
unlike
compliance
costs
and
benefits
associated
with
reducing
the
incidence
of
these
ailments
are
likely
to
be
significantly
lower
under
the
"
without
chlorine
controls"
version
of
each
option
than
the
corresponding
"
with
chlorine
controls"
option.

reduced
morbidity,
which
are
expressed
in
2002
dollars.
Since
a
portion
of
benefits
are
in
1999
dollars
instead
of
2002
dollars,
the
estimate
of
total
benefits
presented
here
is
not
comparable
with
cost
estimates.
c.
Total
dioxin/
furans
emissions
reductions
are
4.68
grams
per
year,
represented
by
0.42
grams
interim
baseline
to
floor
and
4.26
grams
floor
to
BTF.
The
range
of
monetized
benefits
reflects
a
latency
period
ranging
from
21
years
to
34
years.
In
addition,
this
range
reflects
a
cancer
risk
factor
of
1.5
x
105
[
mg/
kg/
day]­
1.
As
discussed
in
the
text
above,
the
Agency
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
dioxin
and
dioxin­
like
compounds.
This
reassessment
will
soon
be
under
review
at
the
National
Academy
of
Sciences
(
NAS),
as
specified
by
Congress
in
the
Conference
Report
accompanying
EPA's
fiscal
year
2003
appropriation
(
Title
IV
of
Division
K
of
the
Conference
Report
for
the
Consolidated
Appropriations
Resolution
of
2003).
Evidence
compiled
from
this
draft
reassessment
indicates
that
the
carcinogenic
effects
of
dioxin/
furans
may
be
as
much
as
six
times
as
great
as
believed
in
1985,
reflecting
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.
Use
of
the
alternative
upper
bound
cancer
risk
slope
factor
would
result
in
up
to
0.35
premature
cancer
deaths
avoided
in
response
to
the
proposed
replacement
standards
for
dioxin/
furans.
The
assessment
of
upper
bound
cancer
risk
using
this
alternative
slope
factor
should
not
be
considered
Agency
policy.
d.
Monetized
PM
mortality
benefits
assume
that
25
percent
of
premature
mortalities
occur
during
the
first
year,
25
percent
occur
during
the
second
year,
and
16.7
percent
occur
in
each
of
the
three
subsequent
years
after
exposure.
We
assume
no
time
lag
is
associated
with
PM
morbidity
effects.
This
methodology
is
consistent
with
EPA's
analysis
of
the
proposed
Clear
Skies
Act
of
2003.
EPA,
Technical
Addendum:
Methodologies
for
the
Benefit
Analysis
of
the
Clear
Skies
Act
of
2003,
September
2003.
e.
The
beyond­
the­
floor
version
of
the
chlorine
standards
analyzed
in
the
2004
Assessment
would
yield
ancillary
benefits
associated
with
reduced
emissions
of
SO2.
These
benefits
are
not
presented
in
the
2004
Assessment,
but
Appendix
A
to
this
Addendum
presents
information
on
these
benefits.
f.
Totals
may
not
add
due
to
rounding.
Totals
do
not
include
dioxin
benefits
associated
with
the
high­
end
dioxin
toxicity
estimate.

***
As
Exhibit
9
shows,
monetized
benefits
of
the
proposed
HWC
MACT
replacement
standards
range
from
$
4.02
million
to
$
10.28
million,
depending
on
which
discount
rate
is
used.
For
example,
the
high­
end
estimate
of
total
non­
discounted
benefits
is
$
10.28
million,
whereas
our
highend
estimates
discounted
at
3
percent
and
7
percent
are
$
9.99
million
and
$
9.73
million
respectively.
Although
our
estimates
of
total
benefits
are
sensitive
to
discounting
assumptions,
discounting
has
no
effect
on
our
estimates
of
morbidity
and
visibility
benefits
because
we
assume
that
there
is
no
latency
associated
with
these
benefits.
***

It
is
important
to
emphasize
that
the
monetized
benefits
presented
in
this
Addendum
represent
only
a
portion
of
the
benefits
associated
with
the
proposed
replacement
standards.
Specifically,
ecological
benefits
and
health
benefits
associated
with
reduced
emissions
of
chlorine,
mercury,
lead,
FINAL
DRAFT:
March
2004
33
and
several
other
hazardous
air
pollutants
are
not
monetized.
FINAL
DRAFT:
March
2004
22
Total
compliance
costs
represent
engineering
costs,
the
upper­
bound
estimate
of
costs.
This
conservative
approach
generally
overestimates
compliance
costs
as
a
percentage
of
total
sales.
23
This
estimate
does
not
reflect
the
elimination
of
the
beyond­
the­
floor
chlorine
standards
for
LWAKs
under
the
Agency
Preferred
Approach.
This
facility's
compliance
costs
as
a
percent
of
total
sales
are
likely
to
be
lower
than
estimated
in
this
Addendum.

34
EQUITY
CONSIDERATIONS
AND
OTHER
IMPACTS
Changes
to
the
PM
replacement
standards
and
design
levels
have
no
impact
on
most
of
the
equity
considerations
and
other
regulatory
concerns
addressed
under
relevant
Executive
Orders.
The
costs
associated
with
the
proposed
PM
replacement
standards
under
the
Agency
Preferred
Approach
range
from
$
55.6
to
$
82.8
million.
Since
these
costs
total
less
than
$
100
million,
the
proposed
replacement
standards
do
not
represent
a
significant
unfunded
mandate
and
are
consequently
exempt
from
requirements
associated
with
the
Unfunded
Mandates
Reform
Act.
Because
the
changes
to
the
proposed
standards
do
not
reflect
changes
in
locations
or
operating
status
of
regulated
facilities,
the
proposed
replacement
standards
may
still
result
in
significant
health
and
environmental
benefits
to
minority
and
low­
income
populations
living
in
proximity
to
hazardous
waste
combustion
facilities.
For
the
same
reasons
described
in
the
2004
Assessment,
the
proposed
PM
replacement
standards
will
not
be
likely
to
have
a
significant
joint
impact
on
the
actions
of
facilities
controlled
by
other
regulations.
Likewise,
the
revised
replacement
standards
do
not
have
implications
as
defined
in
Executive
Order
13175,
"
Consultation
With
Indian
Tribal
Governments;"
Executive
Order
13132,
"
Federalism;"
and
Executive
Order
12630,
"
Government
Actions
and
Interference
with
Constitutionally
Protected
Property
Rights."
The
remainder
of
this
section
discusses
the
impacts
of
the
proposed
PM
replacement
standards
on
small
entities,
children's
health
protection,
and
energy
use,
as
well
as
non­
air
environmental
impacts.

Assessment
of
Small
Entity
Impacts
According
to
the
Small
Business
Administration,
the
same
six
facilities
as
those
identified
in
the
2004
Assessment
are
small
businesses.
The
total
compliance
costs
per
facility,
however,
vary
due
to
the
proposed
PM
replacement
standards.
22
As
Exhibit
10
demonstrates,
under
the
revised
replacement
standards,
estimated
costs
decline
for
most
facilities
classified
as
small
businesses.
Costs
at
the
one
facility
where
compliance
costs
exceed
1
percent
of
total
annual
sales
increase
marginally
from
2.21
percent
of
annual
sales
to
2.23
percent.
23
Under
the
market­
adjusted
scenario,
we
expect
that
this
facility
will
continue
to
operate.
Therefore,
the
new
proposed
PM
replacement
standards
are
not
likely
to
result
in
a
significant
economic
impact
on
a
substantial
number
of
small
hazardous
waste
combustion
facilities.
FINAL
DRAFT:
March
2004
35
Exhibit
10
SMALL
ENTITY
ANALYSIS
RESULTS
Facility
Name/

Parent
Companya
EPA
ID
Combustor
Type
Corporate
Entity
Annual
Sales
(
dollars)
b
Total
Compliance
Costs
in
the
2004
Assessment
(
Agency
Preferred
Approach)
c
(
dollars)
Revised
Total
Compliance
Costs
(
Agency
Preferred
Approach)
d
(
dollars)
Revised
Costs
As
a
Percentage
of
Sales
(
CPS)

Reilly
Industries,

Inc.
IND000807107
Liquid
Boiler
$
329,600,000
$
715,900
$
704,600
0.21%

Rubicon,
Inc.
LAD008213191
Liquid
Boiler
$
465,000,000
$
848,800
$
844,800
0.18%

Continental
Cement
Company
MOD054018288
Cement
Kiln
$
52,400,000
$
238,900
$
87,300
0.17%

Thermalkem
(
Norlite);
subsidiary
of
United
Oil
Recovery
NYD080469935
LWAK
$
49,100,000
$
1,077,600
$
1,092,500e
2.23%

3V,
Inc.
f
SCD980500052
Liquid
Boiler
$
62,600,000
$
45,100
$
44,100
0.07%

Velsicol
Chemical
Corporation
TND007024664
On­
Site
Incinerator
$
150,000,000
$
5,200
$
6,800
<
0.01%
FINAL
DRAFT:
March
2004
Exhibit
10
SMALL
ENTITY
ANALYSIS
RESULTS
36
Notes:

a
Except
in
the
case
of
Norlite,
the
name
of
each
facility's
parent
company
is
the
same
as
the
name
of
the
facility
itself.

b
Corporate
entity
data
obtained
from
ReferenceUSA,
Dun
and
Bradstreet,
company
websites,
and
company
financial
documents.

c
Total
compliance
costs
represent
the
upper­
bound
engineering
costs
under
the
proposed
HWC
MACT
replacement
standards
described
in
the
2004
Assessment,
assuming
facilities
upgrade
to
comply
with
proposed
standards.

d
Revised
total
compliance
costs
represent
the
upper­
bound
engineering
costs
under
the
proposed
PM
replacement
standards,
assuming
facilities
upgrade
to
comply
with
proposed
standards.

e
Estimated
compliance
costs
for
this
facility
do
not
reflect
the
elimination
of
the
beyond­
the­
floor
chlorine
controls
for
LWAKs.
The
compliance
cost
value
presented
here
for
this
facility
may
overestimate
the
facility's
actual
compliance
costs
under
the
Agency
Preferred
Approach.

f
3V,
Incorporated
is
an
Italian­
owned
company
with
facilities
in
the
United
States,
Italy,
and
several
other
countries.
Employment
in
the
U.
S.
is
at
least
270
people,
and
overall
employment
worldwide
is
likely
over
500
people
(
the
small
business
size
threshold).
However,
we
included
this
facility
as
a
small
business
because
it
is
an
internationally­
owned
company
and
we
were
unable
to
confirm
total
employment.
Sales
data
are
for
the
single
facility
in
South
Carolina.
FINAL
DRAFT:
March
2004
24
U.
S.
EPA,
Environmental
Health
Threats
to
Children,
EPA
175­
F­
96­
001,
September
1996,
4.

25
Note
that
lead­
related
benefits,
while
modest,
may
be
higher
than
those
reported
in
the
2004
Assessment.
These
benefits
are
expected
to
be
less
than
the
seven
cases
estimated
in
the
July
23,
1999
Addendum
and
under
the
2002
Interim
Standards.

37
Children's
Health
Protection
Analysis
Most
health
benefits
associated
with
the
proposed
replacement
standards
result
from
reduced
PM
emissions.
The
revision
to
the
proposed
PM
replacement
standards,
however,
does
not
change
the
number
of
avoided
premature
deaths
and
illnesses
in
children,
relative
to
results
presented
in
the
2004
Assessment.
The
standards
should
still
prevent
less
than
one
premature
death
and
approximately
54
illness
cases
per
year.
As
described
in
the
2004
Assessment,
separate
results
are
not
available
for
children.
We
assume,
however,
that
children
would
experience
significant
health
benefits
since
they
are
particularly
vulnerable
to
the
effects
of
PM
exposure.
24
Benefits
associated
with
mercury
and
lead
controls
will
also
remain
the
same
since
the
mercury
and
lead
standards
have
not
changed.
25
If
the
Agency
implements
chlorine
controls,
the
effect
on
children's
health
will
be
positive.
We
do
not
quantify
the
exact
magnitude
of
these
benefits
given
available
data,
but
reduced
chlorine
emissions
may
prevent
eye,
nose,
and
respiratory
tract
irritations;
pulmonary
edema;
gastritis;
bronchitis;
asthma
and
swelling
of
the
lungs;
headaches;
heart
disease;
meningitis;
and
death.
We
assume
that
children
would
experience
some
of
these
health
benefits
as
their
exposure
to
chlorine
declines.

Energy
Impact
Analysis
In
order
to
comply
with
the
proposed
PM
replacement
standards,
regulated
hazardous
waste
combustion
facilities
may
upgrade
their
pollution
abatement
systems,
consolidate
hazardous
waste
into
fewer
systems
located
on
site,
or
stop
burning
hazardous
waste.
Under
the
market­
adjusted
scenario,
we
expect
that
hazardous
waste
combustion
systems
will
comply
as
described
in
the
2004
Assessment.
Of
the
276
systems
in
the
regulatory
universe,
218
will
upgrade,
45
will
close
and
ship
their
waste
off­
site,
and
13
will
consolidate.
Consequently,
compared
to
results
presented
in
the
2004
Assessment,
energy
use
impacts
are
unchanged
under
the
revised
PM
replacement
standards.
The
standards
will
result
in
the
use
of
an
additional
1,0172,722
million
Btus
of
energy
per
year,
costing
at
least
$
1,377,396.
This
increase
represents
less
than
0.0032
percent
of
the
energy
consumed
in
2002,
and
consequently,
the
rule
does
not
represent
a
"
significant
energy
action"
as
defined
in
Executive
Order
12311,
"
Actions
Concerning
Regulations
That
Significantly
Affect
Energy
Supply,
Distribution,
or
Use."
As
in
the
2004
Assessment,
these
estimates
do
not
include
energy
and
costs
associated
with
system
upgrades
and
thus
underestimate
the
total
energy
impact
of
the
proposed
PM
replacement
standards.
FINAL
DRAFT:
March
2004
38
Non­
air
Environmental
Impacts
Most
of
our
estimates
of
the
non­
air
environmental
impacts
associated
with
the
revised
standards
are
similar
to
those
presented
in
the
2004
Assessment.
Differences
between
current
and
previous
estimates
reflect
changes
in
the
standards
and
slight
modifications
to
the
technologies
we
assume
different
systems
will
implement
to
comply
with
the
standards.

The
Agency
now
estimates
that
systems
using
wet
scrubbers
to
control
chlorine
emissions
will
generate
an
additional
4.6
billion
gallons
of
wastewater
per
year,
compared
to
the
4.0
billion
gallons
estimated
in
the
Assessment.
In
addition,
we
estimate
that
systems
installing
dry
scrubbers
to
limit
chlorine
emissions
will
generate
approximately
33,000
tons
of
spent
sorbent
per
year,
just
1,000
tons
less
than
estimated
in
the
2004
Assessment.
We
also
project
that
facilities
using
activated
carbon
to
control
emissions
of
dioxins/
furans
and
mercury
will
generate
approximately
8,000
tons
of
carbon
on
an
annual
basis,
which
represents
a
3,000
ton
reduction
relative
to
the
estimate
presented
in
the
2004
Assessment.
Controls
for
other
pollutants
will
likely
increase
annual
water
consumption
by
500
million
gallons
and
generate
an
additional
5,000
tons
of
solid
waste
per
year.
The
former
estimate
is
50
percent
less
than
the
corresponding
estimate
presented
in
the
2004
Assessment.

COST
EFFECTIVENESS
ANALYSIS
The
revised
proposal
for
the
HWC
MACT
replacement
standards
does
not
significantly
change
most
of
the
cost­
effectiveness
estimates
reported
in
the
2004
Assessment.
Exhibits
11
and
12
present
the
updated
cost­
effectiveness
results.
These
exhibits
do
not
present
separate
estimates
for
versions
of
the
standards
that
exclude
controls
on
chlorine
emissions.
With
the
exception
of
estimates
associated
with
chlorine,
the
cost­
effectiveness
for
such
versions
of
the
standards
are
the
same
as
the
corresponding
versions
of
the
replacement
standards
that
include
chlorine
controls.
Key
findings
from
these
updated
results
include
the
following:

°
Cost­
effectiveness
per
ton
of
reduced
PM
emissions
from
LWAKs
and
incinerators
are
not
calculated
because
the
revised
standards
do
not
require
PM
controls
at
these
systems.

°
The
LWAK
and
coal
boiler
chlorine
standards
under
the
Agency
Preferred
Approach
are
now
more
cost
effective
than
the
corresponding
standards
presented
in
the
2004
Assessment.
This
change
reflects
the
elimination
of
beyond­
the­
floor
chlorine
standards
for
these
sources.

°
Across
all
source
categories,
cost­
effectiveness
estimates
associated
with
SVM
and
LVM
have
changed
relative
to
the
estimates
reported
in
the
2004
Assessment.
These
changes
are
consistent
with
the
revised
PM
standards
FINAL
DRAFT:
March
2004
39
since
emissions
of
SVM
and
LVM
are
influenced
by
controls
on
PM.

°
Per
unit
health
improvement,
the
revised
proposal
for
the
HWC
MACT
PM
replacement
standards
is
more
cost­
effective
than
the
previous
proposal.
Under
the
Agency
Preferred
Approach,
the
cost­
effectiveness
of
the
revised
PM
standards
is
approximately
$
47.9
million
per
life
saved
and
$
2,617
per
avoided
morbidity
case,
both
of
which
represent
an
18
percent
improvement
compared
to
the
corresponding
estimates
of
$
58.4
million
per
life
saved
and
$
3,187
per
avoided
illness
presented
in
the
2004
Assessment.
These
revised
estimates
reveal
that
the
revised
PM
standards
are
more
cost­
effective
than
the
previous
standards
because
estimated
reductions
in
premature
death
and
morbidity
have
changed
little
from
estimates
presented
in
the
2004
Assessment,
while
estimated
engineering
costs
have
fallen.

Exhibit
11
COST­
EFFECTIVENESS
RESULTSa
Pollutant
Source
Options
TEQ,
$
1,000/
gram
Hg,
$
1,000/
ton
SVM,
$
1,000/
ton
LVM,
$
1,000/
ton
PM,
$
1,000/
ton
TCl,
$
1,000/
ton
LWAKs
Baseline
to
Floor
Option
1
­
$
120,054
$
1,861
$
6,283
­
­

Baseline
to
Agency
Preferred
Approach
***$
91
5
$
120,054
$
1,861
$
6,283
­
$
6.82
Option
1
Floor
to
Agency
Preferred
Approach
$
915**
*
­
­
­
­
$
6.82
Baseline
to
Floor
Option
2
­
$
119,961
$
1,794
$
5,172
­
­

Baseline
to
Option
2
BTF­
D
$
724
$
119,961
$
1,794
$
5,172
­
$
6.59
Option
2
Floor
to
Option
2
BTF­
D
$
724
­
­
­
­
$
6.59
Baseline
to
Floor
Option
3
­
$
119,960
$
2,985
$
8,127
­
­

Baseline
to
Option
3
BTF­
D
$
767
$
119,960
$
2,985
$
8,127
­
$
5.45
Option
3
Floor
to
Option
3
BTF­
D
$
767
­
­
­
­
$
5.45
Incinerator
s
Baseline
to
Floor
Option
1
$
2,627
­
$
2,965
$
3,607
­
$
44.34
Baseline
to
Agency
Preferred
Approach
$
2,627
­
$
2,965
$
3,607
­
$
44.34
Option
1
Floor
to
Agency
Preferred
Approach
­
­
­
­
­
­
FINAL
DRAFT:
March
2004
Exhibit
11
COST­
EFFECTIVENESS
RESULTSa
Pollutant
Source
Options
TEQ,
$
1,000/
gram
Hg,
$
1,000/
ton
SVM,
$
1,000/
ton
LVM,
$
1,000/
ton
PM,
$
1,000/
ton
TCl,
$
1,000/
ton
40
Baseline
to
Floor
Option
2
$
2,627
­
$
4,402
$
7,724
­
$
39.38
Baseline
to
Option
2
BTF­
D
$
2,627
­
$
4,402
$
7,724
­
$
39.38
Option
2
Floor
to
Option
2
BTF­
D
­
­
­
­
­
­

Baseline
to
Floor
Option
3
$
2,627
­
$
4,339
$
6,806
­
$
38.74
Baseline
to
Option
3
BTF­
D
$
2,627
­
$
4,339
$
6,806
­
$
38.74
Option
3
Floor
to
Option
3
BTF­
D
­
­
­
­
­
­

Cement
Kilns
Baseline
to
Floor
Option
1
­
$
16,567
$
405
$
10,458
$
13.17
$
8.62
Baseline
to
Agency
Preferred
Approach
­
$
16,567
$
405
$
10,458
$
13.17
$
8.62
Option
1
Floor
to
Agency
Preferred
Approach
­
­
­
­
­
­

Baseline
to
Floor
Option
2
­
$
22,501
$
1,319
$
20,535
$
13.95
$
13.14
Baseline
to
Option
2
BTF­
D
­
$
22,501
$
1,319
$
20,535
$
13.95
$
13.14
Option
2
Floor
to
Option
2
BTF­
D
­
­
­
­
­
­

Baseline
to
Floor
Option
3
­
$
22,501
$
1,489
$
13,189
$
7.85
$
13.14
Baseline
to
Option
3
BTF­
D
­
$
22,501
$
1,489
$
13,189
$
7.85
$
13.14
Option
3
Floor
to
Option
3
BTF­
D
­
­
­
­
­
­

Liquid
Boilers
Baseline
to
Floor
Option
1
$
373
$
13,072
$
4,172
$
733
$
9.67
$
6.40
Baseline
to
Agency
Preferred
Approach
$
662
$
13,072
$
4,172
$
733
$
9.67
$
6.40
Option
1
Floor
to
Agency
Preferred
Approach
$
1,313
­
­
­
­
­

Baseline
to
Floor
Option
2
$
373
$
14,191
$
4,161
$
738
$
9.39
$
13.52
Baseline
to
Option
2
BTF­
D
$
662
$
14,191
$
4,161
$
738
$
9.39
$
13.52
Option
2
Floor
to
Option
2
BTF­
D
$
1,916
­
­
­
­
­

Baseline
to
Floor
Option
3
$
373
$
17,209
$
1,215
$
262
$
9.60
$
6.51
FINAL
DRAFT:
March
2004
Exhibit
11
COST­
EFFECTIVENESS
RESULTSa
Pollutant
Source
Options
TEQ,
$
1,000/
gram
Hg,
$
1,000/
ton
SVM,
$
1,000/
ton
LVM,
$
1,000/
ton
PM,
$
1,000/
ton
TCl,
$
1,000/
ton
41
Baseline
to
Option
3
BTF­
D
$
662
$
17,209
$
1,215
$
262
$
9.60
$
6.51
Option
3
Floor
to
Option
3
BTF­
D
$
1,313
­
­
­
­
­

Coal
Boilers
Baseline
to
Floor
Option
1
­
$
23,274
$
687
$
343
$
4.68
$
1.16
Baseline
to
Agency
Preferred
Approach
***­
$
23,274
$
687b
$
343b
$
3.32
$
1.16c
Option
1
Floor
to
Agency
Preferred
Approach
­***
­
­
­
$
3.97
­
c
Baseline
to
Floor
Option
2
­
$
23,274
$
687
$
343
$
4.68
$
1.16
Baseline
to
Option
2
BTF­
D
­
$
23,274
$
687b
$
343b
$
3.76
$
1.16
Option
2
Floor
to
Option
2
BTF­
D
­
­
­
­
$
3.69
­

Baseline
to
Floor
Option
3
­
$
23,274
$
683
$
339
$
4.43
$
1.16
Baseline
to
Option
3
BTF­
D
­
$
23,274
$
683b
$
339b
$
3.21
$
1.16
Option
3
Floor
to
Option
3
BTF­
D
­
­
­
­
$
3.82
­

HCl
Production
Furnaces
Baseline
to
Floor
Option
1
­
­
­
­
­
$
4.99
Baseline
to
Agency
Preferred
Approach
$
823
­
­
­
­
$
4.99
Option
1
Floor
to
Agency
Preferred
Approach
$
823
­
­
­
­
­

Baseline
to
Floor
Option
2
­
­
­
­
­
$
7.32
Baseline
to
Option
2
BTF­
D
$
698
­
­
­
­
$
7.32
Option
2
Floor
to
Option
2
BTF­
D
$
698
­
­
­
­
­

Baseline
to
Floor
Option
3
­
­
­
­
­
$
7.21
Baseline
to
Option
3
BTF­
D
$
987
­
­
­
­
$
7.21
Option
3
Floor
to
Option
3
BTF­
D
$
987
­
­
­
­
­
FINAL
DRAFT:
March
2004
Exhibit
11
COST­
EFFECTIVENESS
RESULTSa
Pollutant
Source
Options
TEQ,
$
1,000/
gram
Hg,
$
1,000/
ton
SVM,
$
1,000/
ton
LVM,
$
1,000/
ton
PM,
$
1,000/
ton
TCl,
$
1,000/
ton
42
Notes:
a.
This
table
includes
pollutants
where
more
than
one
option
was
under
consideration.
b.
Despite
higher
SVM
and
LVM
emission
reductions
under
the
beyond­
the­
floor
option,
cost
effectiveness
for
coal
boiler
SVM
and
LVM
under
the
beyond­
the­
floor
option
are
equal
to
cost
effectiveness
estimates
under
the
corresponding
Floor.
Since
the
incremental
reductions
under
the
beyond­
the­
floor
option
are
due
to
tighter
PM
restrictions,
we
do
not
incorporate
them
into
our
estimate
of
the
cost
effectiveness
of
beyond­
the­
floor
SVM
and
LVM
standards.
c.
The
chlorine
standards
under
the
Agency
Preferred
Approach
evaluated
in
the
2004
Assessment
included
a
beyond­
thefloor
standard
for
coal
boilers.
The
cost­
effectiveness
of
this
beyond­
the­
floor
standard,
incremental
to
the
floor
standard,
was
$
473,000
per
ton.
Incremental
to
the
baseline,
the
cost­
effectiveness
of
the
standard
was
$
349,000
per
ton.
FINAL
DRAFT:
March
2004
43
Exhibit
12
COST­
EFFECTIVENESS
PER
UNIT
HEALTH
IMPROVEMENTa,
b,
c,
d
(
using
unadjusted,
maximum
cost
of
control,
2002$)

Benefit
Type
Pollutant(
s)
Option
1
Floor
Agency
Preferred
Approach
Option
2
Floor
Option
2
BTF­
D
Option
3
Floor
Option
3
BTF­
D
Health
Benefits
Avoided
Premature
Mortality
Cases
e
PM
$
42.6
million
per
life
saved
$
47.9
million
per
life
saved
$
41.5
million
per
life
saved
$
46.9
million
per
life
saved
$
38.0
million
per
life
saved
$
40.6
million
per
life
saved
Avoided
Premature
Mortality
Cases
Dioxins/
Furans
$
159.5
million
per
life
saved
$
85.9
million
per
life
saved
$
159.5
million
per
life
saved
$
81.0
million
per
life
saved
$
159.5
million
per
life
saved
$
92.4
million
per
life
saved
Avoided
Morbidity
(
PM)
f
PM
$
2,361
per
case
$
2,617
per
case
$
2,303
per
case
$
2,560
per
case
$
2,273
per
case
$
2,412
per
case
Avoided
Morbidity
(
lead)
g
SVM
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Ecological
Benefits
Reduction
in
area
of
Land
and
Water
Impacted
dioxin,
mercury,
lead
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Notes:
a
Engineering
costs.
b
Dollar
per
unit
benefit.
c
These
cost­
effectiveness
per
unit
benefit
measures
are
upper
bound
estimates
that
apply
the
full
costs
of
control
(
by
pollutant)
to
a
single
type
of
benefit
(
e.
g.,
lives
saved).
The
cost
per
unit
benefit
measures
should
not
be
reported
in
isolation
from
other
benefit
estimates;
they
should
only
be
used
as
relative
measures
to
compare
across
MACT
standards.
d
All
figures
are
incremental
from
the
baseline
to
the
HWC
MACT
standards.
e
Mortality
cases
comprise
fatal
cancers
and
fatalities
from
exposure
to
particulate
matter.
f
PM
morbidity
cases
comprise
hospital
admissions
from
respiratory
diseases,
cases
of
chronic
bronchitis
and
asthma,
work
loss
days,
and
mild
restricted
activity
days.
g
SO
2
morbidity
cases
comprise
reduced
incidence
of
chronic
bronchitis,
acute
bronchitis,
non­
fatal
myocardial
infarctions,
hospital
admissions
(
respiratory
and
cardiological),
emergency
room
visits,
respiratory
symptoms,
g
Morbidity
cases
associated
with
exposure
to
lead
are
cases
in
which
children
have
blood
lead
levels
above
10

g/
dL.
FINAL
DRAFT:
March
2004
44
Appendix
A
Hazardous
Waste
Combustion
MACT
Replacement
Standards:
Proposed
Rule
FINAL
DRAFT:
March
2004
26
The
specific
technology
is
simple
direct
duct
injection
dry
scrubbing.
EPA
Floor
option
regulatory
scenarios
(
i.
e.,
Floor
Option
1,
Floor
Option
2,
and
Floor
Option
3)
would
not
require
dry
scrubbers
and
would
therefore
incur
no
benefits
associated
with
SO
2
reductions.

45
Assessment
of
Benefits
Associated
with
the
Beyond­
the­
Floor
Standard
for
TCl
from
Solid
Fuel
Boilers
Burning
Hazardous
Waste
We
have
identified
expected
reductions
in
sulfur
dioxide
(
SO
2)
emissions
from
coal
fired
boilers
that
may
occur
under
***
one
option***
considered
for
the
Hazardous
Waste
Combustion
(
HWC)
MACT
replacement
standards.
This
option
would
require
coal­
fired
(
i.
e.,
solid
fuel)
hazardous
waste
burning
boilers
and
LWAKs
to
meet
a
beyond­
the­
floor
standard
for
chlorine.
Under
this
option,
facilities
with
coal­
fired
hazardous
waste
burning
boilers
would
need
to
install
flue
gas
desulfurization
(
i.
e.,
"
dry
scrubber")
technology26
In
addition
to
controlling
releases
of
chlorine,
dry
scrubbers
will
reduce
emissions
of
sulfur
dioxide
from
these
facilities.

This
Assessment
examines
anticipated
benefits
associated
with
SO
2
emissions
reductions.
To
develop
a
range
of
potential
benefits
estimates
of
SO
2
reductions,
we
adjusted
published
national
estimates
of
SO
2
control
benefits
to
reflect
our
estimate
of
the
total
SO
2
emissions
(
tons/
year)
avoided
in
response
to
the
beyond­
the­
floor
(
BTF)
standard
for
chlorine
in
solid
fuel
boilers.
We
first
provide
two
estimates
of
benefits
based
on
extrapolation
from
available
literature.
We
then
incorporate
a
number
of
very
conservative
assumptions
to
provide
a
"
lower
bound"
estimate
of
benefits.
Finally,
we
discuss
the
primary
limitations
associated
with
our
analysis.

Sulfur
Dioxide
Emission
Reductions
Four
facilities
in
the
HWC
MACT
regulated
universe
have
solid
fuel
boilers.
These
facilities
are:
1)
Eastman
Chemical
Company
in
Tennessee
(
seven
boilers),
2)
Union
Carbide
in
West
Virginia
(
one
boiler),
3)
Celanese
Chemicals
in
Texas
(
two
boilers),
and,
4)
Eastman
Chemical
Company
facility
in
Arkansas
(
two
boilers).
None
of
the
boilers
at
these
facilities
are
currently
equipped
with
dry
scrubbers.

We
estimate
baseline
(
SO
2)
emissions
from
these
facilities
at
37,000
tons
per
year,
reflecting
operating
requirements
under
test
conditions.
The
Texas
and
Arkansas
facilities
are
assumed
to
use
low
sulfur
coal
(
sulfur
content
of
0.6
percent),
and
the
West
Virginia
and
Tennessee
facilities
are
believed
to
use
eastern
coal
(
sulfur
content
ranging
from
one
to
five
percent,
with
an
average
value
of
2.5
percent).
FINAL
DRAFT:
March
2004
46
Our
engineers
have
determined
that
the
installation
of
dry
scrubbers
for
required
control
of
HCl
(
beyond­
the­
floor
standard)
will
reduce
SO
2
emissions
by
60
percent,
or
22,000
tons
per
year.
Exhibit
1
summarizes
the
SO
2
emissions
reductions.

Exhibit
1
SUMMARY
OF
ESTIMATED
SO2
EMISSION
REDUCTIONS
Beyond­
the­
Floor
Standard
for
TCl
­
Solid
Fuel
Boilers
Facility
Sulfur
Content
of
Coal
Baseline
SO2
Emissions
SO2
Emission
Reductions
SO2
Emissions
Under
TCl
BTF
Option
Eastman
Chemical
Co.,
Kingsport,
Tennessee
2.5%
26,130
15,680
10,450
Celanese
Chemicals,
Pampa,
Texas
0.6%
6,280
3,770
2,510
Union
Carbide,
South
Charleston,
West
Virginia
2.5%
4,000
2,400
1,600
Eastman
Chemical
Co.,
Batesville,
Arkansas
0.6%
550
330
220
TOTAL
36,960
22,180
14,780
FINAL
DRAFT:
March
2004
27
U.
S.
EPA,
2003,
Technical
Addendum:
Methodologies
for
the
Benefit
Analysis
of
the
Clear
Skies
Act
of
2003,
accessed
February
17,
2004,
at
<
http://
www.
epa.
gov/
clearskies/
tech_
addendum.
pdf>;
U.
S.
EPA,
2003,
Technical
Support
Document
for
the
Clear
Skies
Act
2003
Air
Quality
Modeling
Analysis,
accessed
February
17,
2002,
at
<
http://
www.
epa.
gov/
air/
clearskies/
aq_
modeling_
tsd_
csa2003.
pdf>;
U.
S.
EPA,
Benefits
of
the
Proposed
Inter­
State
Air
Q
u
a
l
i
t
y
Ru
l
e
,
a
c
c
e
s
s
e
d
Fe
b
r
u
a
r
y
17
,
2
0
0
4
,
a
t
<
http://
www.
epa.
gov/
interstateairquality/
tsd0175.
pdf>.
In
addition,
we
examined
an
unpublished
draft
report
by
Carrothers
et
al.
(
2002),
which
estimates
national
exposure
to
PM
2.5
and
gaseous
precursors
from
coal­
fired
power
plants
and
mobile
sources.
The
report
then
estimates
benefits
associated
with
reduced
mortality
due
to
decreases
in
emissions.
Carrothers,
Timothy
J.,
Scott
K.
Wolff,
Jouni
Tuomisto,
Andrew
M.
Wilson,
Jonathan
I.
Levy,
John
D.
Graham,
John
D.
Graham,
John
S.
Evans,
2002,
Assessing
the
Economic
Value
of
Further
Research
about
Fine
Particle
Air
Pollution:
Model
Framework
and
Preliminary
Findings,
final
review
draft.

47
Evaluation
of
Benefits
To
develop
initial
estimates
of
potential
benefits
associated
with
SO
2
emissions
reductions,
we
scale
existing
published
national
benefits
assessments
associated
with
SO
2
emissions
reductions
under
the
Clear
Skies
Initiative
and
the
Inter­
State
Air
Quality
Rule
(
IAQR).
27
As
detailed
in
these
documents
and
other
literature,
a
significant
percentage
of
the
benefits
associated
with
the
control
of
SO
2
results
from
avoided
health
effects
associated
with
the
development
of
fine
particulate
matter
(
PM)
formed
by
SO
2
in
the
atmosphere.
The
Clear
Skies
Initiative
and
the
IAQR
both
examine
benefits
associated
with
reduction
in
PM
resulting
from
both
SO
2
and
nitrogen
(
NOx)
releases.

Our
preliminary
benefit
estimate
assumes
a
linear
relationship
between
quantity
of
sulfur
dioxide
controlled
and
monetary
benefits.
In
addition,
we
assume:


The
facilities
in
the
HWC
MACT
universe
are
similar
to
the
national
average
addressed
in
the
Clear
Skies
and
IAQR
analyses
in
terms
of
affected
populations
and
avoided
health
impacts.


The
relationship
between
benefits
and
quantity
of
SO
2
emissions
reduced
is
linear
even
at
relatively
small
quantities
(
i.
e.,
22,000
tons).


Where
benefits
related
to
particulate
matter
associated
with
SO
2
emissions
reductions
and
NOx
reductions
are
not
reported
separately,
the
relationship
between
benefits
is
proportional
to
the
quantity
of
pollutants
(
i.
e.,
if
SO
2
emissions
represent
50
percent
of
the
per
weight
pollutant
reductions,
then
they
FINAL
DRAFT:
March
2004
28
Note
that
this
is
a
conservative
assumption
because
in
general,
SO
2
is
a
more
efficient
precursor
of
particulate
matter
than
nitrous
oxides.
29
These
estimates
reflect
the
average
of
a
range
of
discount
rates
and
scenarios.
Low
end
estimates
reflect
IAQR
study
near
term
benefits
using
a
seven
percent
discount
rate;
High­
end
estimates
reflect
Clear
Skies
study
longer
term
benefits
using
a
three
percent
discount
rate.
The
estimates
also
exclude
ozone­
related
benefits;
IAQR
study
estimated
total
benefits
(
including
ozone­
related
benefits)
at
$
54
to
$
84
billion;
the
Clear
Skies
study
estimated
total
benefits
(
including
ozone­
related
benefits)
at
$
52
to
$
113
billion.
30
The
Clear
Skies
and
IAQR
total
predictions
(
SO
2
plus
NO
x)
of
approximately
5.0
million
tons/
yr
emissions
reductions
(
3.5/
5.0
=
70
percent).

48
represent
50
percent
of
the
benefits).
28
The
Clear
Skies
and
IAQR
analyses
each
predicted
a
total
reduction
in
SO
2
emissions
of
roughly
3.5
million
tons
and
NOx
reductions
of
1.5
million
tons.
The
total
benefits
associated
with
particulate
matter
reductions
were
estimated
at
$
51.5
to
$
109.3
billion
(
1999
dollars)
in
the
Clear
Skies
analysis
and
$
54.5
to
$
83.6
billion
(
1999
dollars)
in
the
IAQR
analysis.
29
Assuming
that
SO
2
emissions
reductions
represent
roughly
70
percent30
of
total
particulate
matter
benefits,
we
estimate
that
a
reduction
of
22,000
tons
of
SO
2
emissions
under
the
HWC
MACT
standards
would
incur
total
monetized
benefits
ranging
from
$
212
million
to
$
350
million
per
year.
This
result
reflects
a
"
dollar
per
ton"
range
of
$
9,700
to
$
15,900
for
benefits
per
ton
of
SO
2
removed.
If
only
mortality
is
included,
annual
monetized
benefits
would
range
from
$
193
million
to
$
320
million,
reflecting
a
"
dollar
per
ton"
range
of
approximately
$
8,800
to
14,600
for
benefits
per
ton
of
SO
2
removed.

Exhibit
2
provides
a
more
detailed
summary
of
the
range
of
potential
benefits
based
on
both
studies.
FINAL
DRAFT:
March
2004
49
Exhibit
2
SUMMARY
OF
BENEFITS
ASSOCIATED
WITH
SO2
EMISSION
REDUCTIONS
Benefit
Category
IAQR
Analysis
(
million
1999$)
Clear
Skies
Analysis
(
million
1999$)

Total
Mortality
50,000
­
72,000
47,000
­
100,000
Total
Infant
Mortality
Benefits
130
­
180
 
Total
Other
Benefits
4,902
­
5,019
4,518
­
9,184
Total
Benefits
54,532
­
83,599
51,518
­
109,284
Total
SO2
Benefits
39,911
­
57,812a
34,478
­
73,255b
Total
Benefits
of
HWC
MACT
SO2
Reductions:
BTF
Option
(
based
on
22,000
tons/
yr)
c
Total
Benefits
(
millions)
$
247.4
­
$
332.9
$
212.4
­
$
350.0
Average
of
Total
Benefits
(
millions)
$
281.7
$
281.9
Total
Benefits,
per
Ton
(
dollars)
$
10,642
­
$
15,133
$
9,655
­
$
15,908
Average
of
Total
Benefits,
per
Ton
(
dollars)
$
12,808
$
12,814
Mortality
Benefits
Only
(
millions)
$
215.2
­
$
307.4
$
193.8
­
$
320.3
Average
of
Mortality
Benefits
Only
(
millions)
$
259.5
$
257.7
Mortality
Benefits
Only,
per
Ton
(
dollars)
$
9,783
­
$
13,971
$
8,808
­
$
14,557
Average
of
Mortality
Benefits
Only,
per
Ton
(
dollars)
$
11,797
$
11,714
Notes:
a
Based
on
3.7
­
3.8
million
tons
SO2
avoided,
adjusted
to
exclude
28­
31%
NOx
contribution.
b
Based
on
3.6
­
4.6
million
tons
SO2
avoided,
adjusted
to
exclude
33%
NOx
contribution.
c
These
ranges
reflect
the
use
of
different
discount
rates,
time
frames,
and
assumptions
about
non­
mortality
benefits.
Low
end
estimates
reflect
near
term
mortality
benefits
only,
using
a
seven
percent
discount
rate;
highend
estimates
reflect
longer
term
total
benefits
using
a
three
percent
discount
rate.
FINAL
DRAFT:
March
2004
50
FINAL
DRAFT:
March
2004
31
Note
that
this
assumption
is
very
conservative
and
is
designed
solely
to
develop
a
lower
bound
estimate.
Because
boilers
are
designed
to
provide
power
for
other
facility
processes,
it
would
be
unusual
for
them
to
operate
at
levels
as
low
as
50
percent.
In
addition,
trial
burn
data
(
collected
as
part
of
the
RCRA
permitting
process)
were
used
to
identify
total
coal
requirements
for
boilers.
Trial
burns
are
typically
designed
to
reflect
maximum
hazardous
waste
combustion.
Because
SO
2
is
associated
with
the
supplemental
fuel
coal
(
and
not
with
hazardous
waste),
it
is
possible
that
trial
burn
data
may
understate
baseline
SO
2
emissions
if
normal
operations
involve
less
hazardous
waste
and
more
coal.

51
Lower
Bound
Estimate
of
Benefits
In
addition
to
the
estimates
based
on
a
simple
extrapolation
of
Clear
Skies
and
IAQR
analyses,
we
have
developed
a
conservative
lower­
bound
estimate
of
potential
benefits
(
mortality
only)
associated
with
SO
2
emissions
reductions
resulting
from
the
BTF
TCl
level
for
solid
fuel
boilers.
This
estimate
includes
only
emissions
reductions
from
the
Tennessee
Eastman
facility
and
makes
the
following
conservative
assumptions:


The
facility
uses
only
coal
with
a
low
sulfur
content
of
one
percent
(
initial
estimate
is
based
on
sulfur
content
of
2.5
percent);


The
facility
operates
boilers
at
50
percent
of
the
intensity
reflected
in
the
trial
burn
data
(
initial
estimate
assumes
that
boilers
operate
as
continuous
process
equipment
at
90
percent
of
annual
trial
burn
capacity);
and
31

The
low­
end
benefit
estimate
of
$
8,808
per
ton
of
SO
2
eliminated
accurately
reflects
regional
benefits
in
northeastern
Tennessee.

The
resulting
reductions
in
SO
2
emissions
from
the
facility
are
therefore
3,100
tons
per
year
rather
than
15,680
tons
per
year.
Under
these
lower­
bound
assumptions,
we
estimate
annual
benefits
of
roughly
$
27
million
associated
with
SO
2
emission
reductions.
This
reflects
only
the
Eastman
Tennessee
facility
and
does
not
consider
any
benefits
associated
with
the
remaining
three
facilities
with
coal­
fired
hazardous
waste
boilers.
FINAL
DRAFT:
March
2004
52
Key
Limitations:

This
assessment
incorporates
various
key
assumptions
and
limitations.
These
include:


the
affected
populations
for
each
of
the
facilities
of
concern
are
assumed
to
be
generally
consistent
with
populations
affected
by
facilities
examined
in
the
Clear
Skies
and
IAQR
analyses,


*
**
The
specific
technology
required
to
meet
the
TCl
BTF
standard
is
simple
direct
duct
injection
dry
scrubbing.
This
technology
is
also
expected
to
result
in
the
SO
2
emission
reductions.
[
Note:
The
EPA
Floor
option
regulatory
scenarios
would
not
require
dry
scrubbers
and
would
therefore
incur
no
potential
benefits
associated
with
SO
2
reductions.***

the
boiler
operation
and
stack
heights
of
the
facilities
of
concern
are
generally
representative
of
the
boilers
and
stack
heights
at
the
facilities
examined
in
the
Clear
Skies
and
IAQR
analyses,


the
linear
extrapolation
of
national­
level
SO
2
reduction
benefits
is
reasonable
for
quantities
of
roughly
20,000
tons;
and

baseline
emissions
estimates
used
in
this
analysis
reflect
current
emissions
for
each
of
the
facilities
of
concern.
FINAL
DRAFT:
March
2004
32
See
note
above.

53
Appendix
B
DETAILED
COST
MODEL
RESULTS
NOTE:
After
the
cost
model
was
run
to
generate
the
results
presented
in
this
Appendix,
EPA
eliminated
beyond­
the­
floor
chlorine
standards
for
LWAKs
and
solid
fuel
boilers.
The
results
presented
in
this
Appendix
do
not
reflect
this
change.

This
appendix
contains
model
results
for
the
twelve
versions
of
the
HWC
MACT
replacement
standards
analyzed
in
the
Addendum
to
the
Assessment
of
the
Potential
Costs,
Benefits,
&
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Replacement
Standards:
Proposed
Rule.
Results
associated
with
Option
1
BTF­
D
represent
the
costs
and
other
impacts
of
the
Agency
Preferred
Approach.
32
The
results
for
all
options
reflect
potential
price
increases
for
hazardous
waste
incineration
services
in
response
to
the
HWC
MACT
replacement
standards,
as
well
as
the
most
recent
estimates
of
waste
quantities,
government
costs,
and
monitoring/
performance
testing
costs.
The
results
presented
in
this
appendix
assume
that
commercial
kilns
and
incinerators
charge
the
same
premium
for
treating
halogenated
waste
and
that
commercial
facilities
pass
100
percent
of
their
compliance
costs
on
to
their
customers.
The
total
cost
estimates
presented
in
this
appendix
do
not
include
government
costs,
which
are
presented
separately
for
each
regulatory
option.
FINAL
DRAFT:
March
2004
54
SDL
Option
1
Floor,
w/

Cl
Controls
SDL
Option
1
Floor,

w/
o
Cl
Controls
SDL
Option
1
BTF­
D,

w/
Cl
Controls
SDL
Option
1
BTF­
D,

w/
o
Cl
Controls
­$
10,632,036.21
­$
7,044,493.23
­$
11,388,208.31
­$
7,408,633.54
­$
2,688,983.11
­$
721,165.72
­$
5,387,442.55
­$
2,023,205.48
­$
93,980.33
$
88,125.70
$
3,329,093.48
$
1,740,084.93
$
9,141,869.51
$
978,411.78
$
9,143,982.97
$
978,679.18
Phase
1
Subtotal
­$
4,273,130.15
­$
6,699,121.48
­$
4,302,574.41
­$
6,713,074.92
$
10,562,921.73
$
7,412,957.36
$
14,187,412.95
$
9,161,964.85
$
36,710,295.36
$
32,586,162.22
$
36,846,275.87
$
32,660,129.66
$
1,511,207.10
$
1,023,168.32
$
5,023,990.34
$
2,221,088.88
$
1,470,615.58
$
1,470,615.58
$
3,359,766.69
$
3,359,766.69
Phase
2
Subtotal
$
39,692,118.04
$
35,079,946.13
$
45,230,032.90
$
38,240,985.24
$
45,981,909.62
$
35,793,782.01
$
55,114,871.43
$
40,689,875.16
Onsite
Incinerators
Liquid
Boilers
Commercial
Incinerators
Cement
Kilns
LWAKs
Pre­
existing
customers
of
commercial
combustion
facilities
Net
Private
Costs,
by
Unit
Type:
SDL
Option
1
Coal
Boilers
HCl
Production
Furnaces
Total
OPTION
1
FINAL
DRAFT:
March
2004
55
SDL
Option
1
Floor,
w/

Cl
Controls
SDL
Option
1
Floor,

w/
o
Cl
Controls
SDL
Option
1
BTF­
D,

w/
Cl
Controls
SDL
Option
1
BTF­
D,

w/
o
Cl
Controls
$
3,165,323.58
$
1,034,979.26
$
3,165,323.58
$
1,034,979.26
$
6,489,684.46
$
5,940,214.96
$
6,489,421.16
$
5,939,951.66
$
541,887.94
$
541,887.94
$
4,166,642.46
$
2,291,158.72
$
9,038,854.68
$
968,809.83
$
9,038,854.68
$
968,809.83
Phase
1
Subtotal
$
19,235,750.66
$
8,485,891.98
$
22,860,241.88
$
10,234,899.47
$
34,600,145.55
$
30,819,781.39
$
34,732,671.87
$
30,892,336.96
$
1,381,306.23
$
893,522.89
$
4,893,793.90
$
2,091,300.82
$
1,470,615.58
$
1,470,615.58
$
3,359,766.69
$
3,359,766.69
Phase
2
Subtotal
$
37,452,067.37
$
33,183,919.87
$
42,986,232.46
$
36,343,404.48
$
56,687,818.03
$
41,669,811.85
$
65,846,474.34
$
46,578,303.95
Onsite
Incinerators
Liquid
Boilers
Commercial
Incinerators
Cement
Kilns
HCl
Production
Furnaces
Total
Coal
Boilers
Upgrade
Expenditures,
by
Unit
Type:
SDL
Option
1
LWAKs
FINAL
DRAFT:
March
2004
56
SDL
Option
1
Floor,
w/

Cl
Controls
SDL
Option
1
Floor,

w/
o
Cl
Controls
SDL
Option
1
BTF­
D,

w/
Cl
Controls
SDL
Option
1
BTF­
D,

w/
o
Cl
Controls
$
3,653,499.14
$
1,034,979.26
$
3,653,499.14
$
1,034,979.26
$
6,489,684.46
$
5,940,214.96
$
6,489,421.16
$
5,939,951.66
$
541,887.94
$
541,887.94
$
4,166,642.46
$
2,291,158.72
$
12,807,392.58
$
1,517,236.48
$
12,807,392.58
$
1,517,236.48
Phase
1
Subtotal
$
23,492,464.12
$
9,034,318.63
$
27,116,955.34
$
10,783,326.12
$
44,736,319.42
$
40,304,055.83
$
44,890,789.55
$
40,376,611.41
$
1,834,543.61
$
1,346,760.27
$
6,864,742.06
$
2,641,019.14
$
1,470,615.58
$
1,470,615.58
$
3,359,766.69
$
3,359,766.69
Phase
2
Subtotal
$
48,041,478.61
$
43,121,431.68
$
55,115,298.30
$
46,377,397.24
$
71,533,942.73
$
52,155,750.31
$
82,232,253.65
$
57,160,723.36
Liquid
Boilers
Coal
Boilers
Onsite
Incinerators
HCl
Production
Furnaces
Commercial
Incinerators
Cement
Kilns
Private
Engineering
Costs:
SDL
Option
1
Total
LWAKs
SDL
Option
1
Floor,

w/
Cl
Controls
SDL
Option
1
Floor,

w/
o
Cl
Controls
SDL
Option
1
BTF­
D,

w/
Cl
Controls
SDL
Option
1
BTF­
D,

w/
o
Cl
Controls
Baseline
Total
Commercial
Incinerators
2
0
2
0
15
Cement
Kilns
0
0
0
0
26
LWAKs
0
0
0
0
7
Onsite
Incinerators
32
29
32
29
92
Liquid
Boilers
22
20
22
20
107
Coal
Boilers
2
2
2
2
12
HCl
Production
Furnaces
0
0
0
0
17
Total
58
51
58
51
276
Number
of
Closed
Systems,
by
Unit
Type:
Option
1
FINAL
DRAFT:
March
2004
57
SDL
Option
1
Floor,

w/
Cl
Controls
SDL
Option
1
Floor,

w/
o
Cl
Controls
SDL
Option
1
BTF­
D,

w/
Cl
Controls
SDL
Option
1
BTF­
D,

w/
o
Cl
Controls
To
Commercial
Incinerators
44,548
23,085
44,548
23,085
To
Cement
Kilns
or
LWAKs
9,041
7,698
9,041
7,698
Non­
commercial
Consolidation
67,266
56,732
67,266
56,732
Total
120,855
87,515
120,855
87,515
Quantity
of
Waste
Sent
Offsite
or
Rerouted
(
tons):
Option
1
Annual
Cost
SDL
Option
1
Floor,
w/
Cl
controls
$
447,479.75
SDL
Option
1
Floor,
w/
o
Cl
controls
$
455,470.46
SDL
Option
1
BTF­
D,
w/
Cl
controls
$
447,479.75
SDL
Option
1
BTF­
D,
w/
o
Cl
controls
$
455,470.46
Government
Costs:
Option
1
SDL
Option
1
Floor,
w/
Cl
controls
SDL
Option
1
Floor,
w/
o
Cl
controls
SDL
Option
1
BTF­
D,
w/
Cl
controls
SDL
Option
1
BTF­
D,
w/
o
Cl
controls
Commercial
Incinerators
188,193.00
504,875.53
Pre­
MACT
Capacity
(
tons)
495,834.52
165,107.76
116,547.89
165,107.76
497,177.63
Available
Capacity
at
Commercial
Facilities:
Option
1
Cement
Kilns/
LWAKs
Post­
MACT
(
tons)
116,547.89
497,177.63
495,834.52
FINAL
DRAFT:
March
2004
58
Lost
Gained
Lost
Gained
Lost
Gained
Lost
Gained
Commercial
Incinerators
47.8
13.6
0.0
5.3
47.8
13.6
0.0
5.3
Cement
Kilns
0.0
32.9
0.0
30.1
0.0
32.9
0.0
30.1
LWAKs
0.0
3.5
0.0
3.5
0.0
29.1
0.0
14.8
Onsite
Incinerators
237.2
39.4
215.4
5.2
237.2
39.4
215.4
5.2
Liquid
Boilers
92.0
208.7
82.9
191.1
92.0
208.7
82.9
191.3
Coal
Boilers
9.5
10.7
9.5
7.0
9.5
32.7
9.5
11.2
HCl
Production
Furnaces
0.0
11.7
0.0
11.7
0.0
23.8
0.0
23.8
APCD
Industry
­
162.3
­
110.7
­
178.8
­
125.0
Total
386.5
482.8
307.8
364.7
386.5
559.0
307.8
406.8
Number
of
Jobs
Lost
and
Gained,
by
Unit
Type:
Option
1
SDL
Option
1
BTF­
D,
w/

Cl
controls
SDL
Option
1
BTF­
D,

w/
o
Cl
controls
SDL
Option
1
Floor,
w/

Cl
controls
SDL
Option
1
Floor,
w/
o
Cl
controls
Baseline
Prices
SDL
Option
1
Floor,

w/
Cl
Controls
SDL
Option
1
Floor,

w/
o
Cl
Controls
SDL
Option
1
BTF­
D,

w/
Cl
Controls
SDL
Option
1
BTFD
w/
o
Cl
Controls
$
1,080.54
$
1,090.25
$
1,087.36
$
1,093.60
$
1,088.97
$
127.05
$
128.19
$
127.85
$
128.59
$
128.04
$
560.14
$
565.17
$
563.68
$
566.91
$
564.51
$
557.14
$
562.15
$
560.66
$
563.87
$
561.49
$
2,820.00
$
2,845.34
$
2,837.80
$
2,854.07
$
2,842.01
$
940.00
$
948.45
$
945.93
$
951.36
$
947.34
$
1,080.54
$
1,090.25
$
1,087.36
$
1,093.60
$
1,088.97
$
127.05
$
128.19
$
127.85
$
128.59
$
128.04
$
1,010.14
$
1,019.22
$
1,016.52
$
1,022.34
$
1,018.02
$
560.14
$
565.17
$
563.68
$
566.91
$
564.51
$
1,067.14
$
1,076.73
$
1,073.88
$
1,080.03
$
1,075.47
$
557.14
$
562.15
$
560.66
$
563.87
$
561.49
Combustion
Prices
($
per
ton):
SDL
Option
1
Waste
Form
Organic
Liquids
(
NonHal)

Inorganic
Liquid
(
Nonhalogenated)

Inorganic
Liquid
(
Halogenated)

Organic
Liquids
(
Halogenated)

Gases
Inorganic
Sludge
(
Nonhalogenated)

Inorganic
Solids
(
NonHal)

Lab
Packs
Organic
Sludges
(
Halogenated)

Organic
Sludges
(
NonHal)

Organic
Solids
(
Halogenated)

Organic
Solids
(
NonHal)
FINAL
DRAFT:
March
2004
59
SDL
Option
2
Floor,
w/

Cl
Controls
SDL
Option
2
Floor,

w/
o
Cl
Controls
SDL
Option
2
BTF­
D,

w/
Cl
Controls
SDL
Option
2
BTF­
D,

w/
o
Cl
Controls
­$
14,853,559.44
­$
9,091,171.81
­$
15,549,719.33
­$
9,391,107.51
$
30,109.86
$
1,349,763.14
­$
2,449,616.16
$
154,312.84
­$
1,102,743.58
­$
362,052.10
$
2,036,645.82
$
1,007,040.17
$
11,734,629.27
$
3,394,237.55
$
11,739,156.66
$
3,395,574.68
Phase
1
Subtotal
­$
4,191,563.89
­$
4,709,223.22
­$
4,223,533.01
­$
4,834,179.83
$
33,249,151.48
$
20,442,700.24
$
36,573,582.53
$
21,877,957.21
$
47,162,524.41
$
33,242,337.01
$
47,353,184.07
$
33,415,151.29
$
1,513,054.10
$
1,024,229.18
$
5,025,812.88
$
2,222,124.15
$
1,842,814.77
$
1,842,814.77
$
3,444,134.59
$
3,444,134.59
Phase
2
Subtotal
$
50,518,393.28
$
36,109,380.95
$
55,823,131.53
$
39,081,410.03
$
79,575,980.86
$
51,842,857.97
$
88,173,181.05
$
56,125,187.40
Onsite
Incinerators
Liquid
Boilers
Commercial
Incinerators
Cement
Kilns
LWAKs
Pre­
existing
customers
of
commercial
combustion
facilities
Net
Private
Costs,
by
Unit
Type:
SDL
Option
2
Coal
Boilers
HCl
Production
Furnaces
Total
OPTION
2
FINAL
DRAFT:
March
2004
60
SDL
Option
2
Floor,
w/

Cl
Controls
SDL
Option
2
Floor,

w/
o
Cl
Controls
SDL
Option
2
BTF­
D,

w/
Cl
Controls
SDL
Option
2
BTF­
D,

w/
o
Cl
Controls
$
4,165,271.17
$
2,037,899.93
$
4,165,271.17
$
2,037,899.93
$
27,965,218.06
$
17,693,435.65
$
27,965,218.06
$
17,693,435.65
$
815,489.45
$
815,489.45
$
4,139,920.51
$
2,264,436.78
$
11,533,002.81
$
3,307,188.20
$
11,533,002.81
$
3,307,188.20
Phase
1
Subtotal
$
44,478,981.49
$
23,854,013.23
$
47,803,412.54
$
25,302,960.55
$
42,064,030.21
$
31,465,455.05
$
42,246,559.19
$
31,395,773.63
$
1,381,306.23
$
893,522.89
$
4,893,793.90
$
2,091,300.82
$
1,842,814.77
$
1,842,814.77
$
3,444,134.59
$
3,444,134.59
Phase
2
Subtotal
$
45,288,151.21
$
34,201,792.71
$
50,584,487.67
$
36,931,209.04
$
89,767,132.70
$
58,055,805.94
$
98,387,900.22
$
62,234,169.59
Onsite
Incinerators
Liquid
Boilers
Commercial
Incinerators
Cement
Kilns
HCl
Production
Furnaces
Total
Coal
Boilers
Upgrade
Expenditures,
by
Unit
Type:
SDL
Option
2
LWAKs
FINAL
DRAFT:
March
2004
61
SDL
Option
2
Floor,
w/

Cl
Controls
SDL
Option
2
Floor,

w/
o
Cl
Controls
SDL
Option
2
BTF­
D,

w/
Cl
Controls
SDL
Option
2
BTF­
D,

w/
o
Cl
Controls
$
4,698,190.92
$
2,037,899.93
$
4,698,190.92
$
2,037,899.93
$
27,965,218.06
$
17,693,435.65
$
27,965,218.06
$
17,693,435.65
$
815,489.45
$
815,489.45
$
4,139,920.51
$
2,264,436.78
$
16,550,359.22
$
4,792,531.87
$
16,550,359.22
$
4,792,531.87
Phase
1
Subtotal
$
50,029,257.65
$
25,339,356.91
$
53,353,688.71
$
26,788,304.23
$
60,449,413.61
$
41,095,380.54
$
60,711,650.14
$
41,278,175.21
$
1,834,543.61
$
1,346,760.27
$
6,864,742.06
$
2,641,019.14
$
1,842,814.77
$
1,842,814.77
$
3,444,134.59
$
3,444,134.59
Phase
2
Subtotal
$
64,126,771.98
$
44,284,955.58
$
71,020,526.79
$
47,363,328.93
$
114,156,029.64
$
69,624,312.48
$
124,374,215.50
$
74,151,633.16
Liquid
Boilers
Coal
Boilers
Onsite
Incinerators
HCl
Production
Furnaces
Commercial
Incinerators
Cement
Kilns
Private
Engineering
Costs:
SDL
Option
2
Total
LWAKs
SDL
Option
2
Floor,

w/
Cl
Controls
SDL
Option
2
Floor,

w/
o
Cl
Controls
SDL
Option
2
BTF­
D,

w/
Cl
Controls
SDL
Option
2
BTF­
D,

w/
o
Cl
Controls
Baseline
Total
Commercial
Incinerators
2
0
2
0
15
Cement
Kilns
0
0
0
0
26
LWAKs
0
0
0
0
7
Onsite
Incinerators
33
30
33
30
92
Liquid
Boilers
29
20
29
21
107
Coal
Boilers
2
2
2
2
12
HCl
Production
Furnaces
0
0
0
0
17
Total
66
52
66
53
276
Number
of
Closed
Systems,
by
Unit
Type:
Option
2
FINAL
DRAFT:
March
2004
62
SDL
Option
2
Floor,

w/
Cl
Controls
SDL
Option
2
Floor,

w/
o
Cl
Controls
SDL
Option
2
BTF­
D,

w/
Cl
Controls
SDL
Option
2
BTF­
D,

w/
o
Cl
Controls
To
Commercial
Incinerators
48,230
26,766
48,230
26,766
To
Cement
Kilns
or
LWAKs
16,087
7,698
16,087
8,564
Non­
commercial
Consolidation
67,266
56,732
67,266
56,732
Total
131,582
91,196
131,582
92,062
Quantity
of
Waste
Sent
Offsite
or
Rerouted
(
tons):
Option
2
SDL
Option
2
Floor,
w/
Cl
controls
SDL
Option
2
Floor,
w/
o
Cl
controls
SDL
Option
2
BTF­
D,
w/
Cl
controls
SDL
Option
2
BTF­
D,
w/
o
Cl
controls
Commercial
Incinerators
188,193.00
504,875.53
Pre­
MACT
Capacity
(
tons)
488,788.88
161,426.70
112,866.84
161,426.70
497,177.63
Available
Capacity
at
Commercial
Facilities:
Option
2
Cement
Kilns/
LWAKs
Post­
MACT
(
tons)
112,866.84
496,311.83
488,788.88
Annual
Cost
SDL
Option
2
Floor,
w/
Cl
controls
$
419,512.27
SDL
Option
2
Floor,
w/
o
Cl
controls
$
455,470.46
SDL
Option
2
BTF­
D,
w/
Cl
controls
$
419,512.27
SDL
Option
2
BTF­
D,
w/
o
Cl
controls
$
451,475.11
Government
Costs:
Option
2
FINAL
DRAFT:
March
2004
63
Lost
Gained
Lost
Gained
Lost
Gained
Lost
Gained
Commercial
Incinerators
47.8
18.4
0.0
10.6
47.8
18.4
0.0
10.6
Cement
Kilns
0.0
145.8
0.0
96.9
0.0
145.8
0.0
96.9
LWAKs
0.0
5.4
0.0
5.4
0.0
29.0
0.0
14.7
Onsite
Incinerators
245.2
51.0
223.4
15.7
245.2
51.0
223.4
15.7
Liquid
Boilers
119.3
241.5
82.9
195.5
119.3
241.5
86.3
194.3
Coal
Boilers
9.5
10.7
9.5
7.0
9.5
32.7
9.5
11.2
HCl
Production
Furnaces
0.0
13.8
0.0
13.8
0.0
24.1
0.0
24.1
APCD
Industry
­
283.7
­
157.6
­
299.0
­
170.4
Total
421.8
770.3
315.8
502.5
421.8
841.5
319.2
537.9
Number
of
Jobs
Lost
and
Gained,
by
Unit
Type:
Option
2
SDL
Option
2
BTF­
D,
w/

Cl
controls
SDL
Option
2
BTF­
D,

w/
o
Cl
controls
SDL
Option
2
Floor,
w/

Cl
controls
SDL
Option
2
Floor,
w/
o
Cl
controls
Baseline
Prices
SDL
Option
2
Floor,

w/
Cl
Controls
SDL
Option
2
Floor,

w/
o
Cl
Controls
SDL
Option
2
BTF­
D,

w/
Cl
Controls
SDL
Option
2
BTFD
w/
o
Cl
Controls
$
1,080.54
$
1,111.15
$
1,099.36
$
1,114.22
$
1,100.69
$
127.05
$
130.65
$
129.26
$
131.01
$
129.42
$
560.14
$
576.01
$
569.90
$
577.60
$
570.59
$
557.14
$
572.92
$
566.85
$
574.51
$
567.53
$
2,820.00
$
2,899.89
$
2,869.13
$
2,907.89
$
2,872.58
$
940.00
$
966.63
$
956.38
$
969.30
$
957.53
$
1,080.54
$
1,111.15
$
1,099.36
$
1,114.22
$
1,100.69
$
127.05
$
130.65
$
129.26
$
131.01
$
129.42
$
1,010.14
$
1,038.76
$
1,027.74
$
1,041.62
$
1,028.98
$
560.14
$
576.01
$
569.90
$
577.60
$
570.59
$
1,067.14
$
1,097.37
$
1,085.73
$
1,100.40
$
1,087.04
$
557.14
$
572.92
$
566.85
$
574.51
$
567.53
Combustion
Prices
($
per
ton):
SDL
Option
2
Waste
Form
Organic
Liquids
(
NonHal)

Inorganic
Liquid
(
Nonhalogenated)

Inorganic
Liquid
(
Halogenated)

Organic
Liquids
(
Halogenated)

Gases
Inorganic
Sludge
(
Nonhalogenated)

Inorganic
Solids
(
NonHal)

Lab
Packs
Organic
Sludges
(
Halogenated)

Organic
Sludges
(
NonHal)

Organic
Solids
(
Halogenated)

Organic
Solids
(
NonHal)
FINAL
DRAFT:
March
2004
64
SDL
Option
3
Floor,
w/

Cl
Controls
SDL
Option
3
Floor,

w/
o
Cl
Controls
SDL
Option
3
BTF­
D,

w/
Cl
Controls
SDL
Option
3
BTF­
D,

w/
o
Cl
Controls
­$
15,216,727.09
­$
9,382,100.40
­$
15,897,834.01
­$
9,682,618.40
$
1,736,297.03
$
1,177,655.95
­$
886,739.70
­$
91,535.02
­$
1,143,437.54
­$
427,109.79
$
1,938,973.22
$
941,794.39
$
12,236,289.96
$
3,951,805.13
$
12,240,719.45
$
3,953,144.86
Phase
1
Subtotal
­$
2,387,577.64
­$
4,679,749.11
­$
2,604,881.04
­$
4,879,214.18
$
35,266,378.27
$
22,362,839.41
$
38,518,925.61
$
23,800,882.78
$
54,662,219.58
$
39,170,275.21
$
54,857,663.51
$
39,278,217.96
$
1,511,485.56
$
1,022,652.72
$
5,025,971.52
$
2,222,280.96
$
1,825,249.10
$
1,825,249.10
$
4,063,291.11
$
4,061,001.70
Phase
2
Subtotal
$
57,998,954.24
$
42,018,177.02
$
63,946,926.13
$
45,561,500.62
$
90,877,754.87
$
59,701,267.32
$
99,860,970.70
$
64,483,169.22
Net
Private
Costs,
by
Unit
Type:
SDL
Option
3
Coal
Boilers
HCl
Production
Furnaces
Total
Onsite
Incinerators
Liquid
Boilers
Commercial
Incinerators
Cement
Kilns
LWAKs
Pre­
existing
customers
of
commercial
combustion
facilities
OPTION
3
FINAL
DRAFT:
March
2004
65
SDL
Option
3
Floor,
w/

Cl
Controls
SDL
Option
3
Floor,

w/
o
Cl
Controls
SDL
Option
3
BTF­
D,

w/
Cl
Controls
SDL
Option
3
BTF­
D,

w/
o
Cl
Controls
$
4,224,525.39
$
2,148,236.27
$
4,224,525.39
$
2,148,236.27
$
29,743,955.17
$
19,472,172.77
$
29,743,955.17
$
19,472,172.77
$
887,076.65
$
887,076.65
$
4,150,527.94
$
2,336,023.97
$
12,031,916.34
$
3,862,966.92
$
12,031,916.34
$
3,862,966.92
Phase
1
Subtotal
$
46,887,473.55
$
26,370,452.61
$
50,150,924.84
$
27,819,399.93
$
51,734,745.94
$
36,499,149.67
$
51,925,884.96
$
36,605,325.20
$
1,379,573.19
$
891,789.85
$
4,893,793.90
$
2,091,300.82
$
1,825,249.10
$
1,825,249.10
$
3,780,695.19
$
3,780,695.19
Phase
2
Subtotal
$
54,939,568.22
$
39,216,188.61
$
60,600,374.04
$
42,477,321.21
$
101,827,041.77
$
65,586,641.23
$
110,751,298.88
$
70,296,721.14
Upgrade
Expenditures,
by
Unit
Type:
SDL
Option
3
LWAKs
Cement
Kilns
HCl
Production
Furnaces
Total
Coal
Boilers
Commercial
Incinerators
Onsite
Incinerators
Liquid
Boilers
FINAL
DRAFT:
March
2004
66
SDL
Option
3
Floor,
w/

Cl
Controls
SDL
Option
3
Floor,

w/
o
Cl
Controls
SDL
Option
3
BTF­
D,

w/
Cl
Controls
SDL
Option
3
BTF­
D,

w/
o
Cl
Controls
$
4,793,785.11
$
2,148,236.27
$
4,793,785.11
$
2,148,236.27
$
29,743,955.17
$
19,472,172.77
$
29,743,955.17
$
19,472,172.77
$
887,076.65
$
887,076.65
$
4,150,527.94
$
2,336,023.97
$
17,012,345.65
$
5,474,939.65
$
17,012,345.65
$
5,474,939.65
Phase
1
Subtotal
$
52,437,162.59
$
27,982,425.34
$
55,700,613.88
$
29,431,372.66
$
67,595,056.06
$
46,048,070.44
$
67,793,126.46
$
46,161,177.35
$
1,832,155.84
$
1,344,372.50
$
6,864,742.06
$
2,641,019.14
$
1,825,249.10
$
1,825,249.10
$
4,090,382.62
$
4,090,382.62
Phase
2
Subtotal
$
71,252,461.00
$
49,217,692.04
$
78,748,251.14
$
52,892,579.11
$
123,689,623.59
$
77,200,117.38
$
134,448,865.02
$
82,323,951.77
Private
Engineering
Costs:
SDL
Option
3
Total
LWAKs
HCl
Production
Furnaces
Commercial
Incinerators
Cement
Kilns
Onsite
Incinerators
Liquid
Boilers
Coal
Boilers
SDL
Option
3
Floor,

w/
Cl
Controls
SDL
Option
3
Floor,

w/
o
Cl
Controls
SDL
Option
3
BTF­
D,

w/
Cl
Controls
SDL
Option
3
BTF­
D,

w/
o
Cl
Controls
Baseline
Total
Commercial
Incinerators
2
0
2
0
15
Cement
Kilns
0
0
0
0
26
LWAKs
0
0
0
0
7
Onsite
Incinerators
33
30
33
30
92
Liquid
Boilers
27
26
27
26
107
Coal
Boilers
2
2
2
2
12
HCl
Production
Furnaces
0
0
1
1
17
Total
64
58
65
59
276
Number
of
Closed
Systems,
by
Unit
Type:
Option
3
FINAL
DRAFT:
March
2004
67
SDL
Option
3
Floor,

w/
Cl
Controls
SDL
Option
3
Floor,

w/
o
Cl
Controls
SDL
Option
3
BTF­
D,

w/
Cl
Controls
SDL
Option
3
BTF­
D,

w/
o
Cl
Controls
To
Commercial
Incinerators
48,230
26,766
48,230
26,766
To
Cement
Kilns
or
LWAKs
11,577
10,705
12,267
11,394
Non­
commercial
Consolidation
67,266
56,732
67,266
56,732
Total
127,072
94,203
127,762
94,892
Quantity
of
Waste
Sent
Offsite
or
Rerouted
(
tons):
Option
3
Annual
Cost
SDL
Option
3
Floor,
w/
Cl
controls
$
427,502.98
SDL
Option
3
Floor,
w/
o
Cl
controls
$
431,498.33
SDL
Option
3
BTF­
D,
w/
Cl
controls
$
423,507.62
SDL
Option
3
BTF­
D,
w/
o
Cl
controls
$
427,502.98
Government
Costs:
Option3
SDL
Option
3
Floor,
w/
Cl
controls
SDL
Option
3
Floor,
w/
o
Cl
controls
SDL
Option
3
BTF­
D,
w/
Cl
controls
SDL
Option
3
BTF­
D,
w/
o
Cl
controls
161,426.70
494,170.81
Available
Capacity
at
Commercial
Facilities:
Option
3
Cement
Kilns/
LWAKs
Post­
MACT
(
tons)
112,866.84
493,481.22
492,608.96
504,875.53
Pre­
MACT
Capacity
(
tons)
493,298.55
161,426.70
112,866.84
Commercial
Incinerators
188,193.00
FINAL
DRAFT:
March
2004
68
Lost
Gained
Lost
Gained
Lost
Gained
Lost
Gained
Commercial
Incinerators
47.8
18.7
0.0
11.3
47.8
18.7
0.0
11.3
Cement
Kilns
0.0
154.2
0.0
105.3
0.0
154.2
0.0
105.3
LWAKs
0.0
5.7
0.0
5.7
0.0
29.0
0.0
15.0
Onsite
Incinerators
245.2
53.6
223.4
18.5
245.2
53.6
223.4
18.5
Liquid
Boilers
113.3
303.8
109.0
229.2
113.3
303.8
109.0
229.2
Coal
Boilers
9.5
10.7
9.5
7.0
9.5
32.7
9.5
11.2
HCl
Production
Furnaces
0.0
13.6
0.0
13.6
3.4
26.0
3.4
26.0
APCD
Industry
­
310.5
­
173.2
­
326.2
­
187.0
Total
415.8
870.7
341.9
563.7
419.2
944.2
345.2
603.5
Number
of
Jobs
Lost
and
Gained,
by
Unit
Type:
Option
3
SDL
Option
3
BTF­
D,
w/

Cl
controls
SDL
Option
3
BTF­
D,

w/
o
Cl
controls
SDL
Option
3
Floor,
w/

Cl
controls
SDL
Option
3
Floor,
w/
o
Cl
controls
Baseline
Prices
SDL
Option
3
Floor,

w/
Cl
Controls
SDL
Option
3
Floor,

w/
o
Cl
Controls
SDL
Option
3
BTF­
D,

w/
Cl
Controls
SDL
Option
3
BTFD
w/
o
Cl
Controls
$
1,080.54
$
1,113.01
$
1,101.14
$
1,116.01
$
1,102.46
$
127.05
$
130.87
$
129.47
$
131.22
$
129.63
$
560.14
$
576.97
$
570.82
$
578.53
$
571.50
$
557.14
$
573.88
$
567.76
$
575.43
$
568.44
$
2,820.00
$
2,904.75
$
2,873.75
$
2,912.58
$
2,877.22
$
940.00
$
968.25
$
957.92
$
970.86
$
959.07
$
1,080.54
$
1,113.01
$
1,101.14
$
1,116.01
$
1,102.46
$
127.05
$
130.87
$
129.47
$
131.22
$
129.63
$
1,010.14
$
1,040.50
$
1,029.39
$
1,043.30
$
1,030.64
$
560.14
$
576.97
$
570.82
$
578.53
$
571.50
$
1,067.14
$
1,099.21
$
1,087.48
$
1,102.17
$
1,088.79
$
557.14
$
573.88
$
567.76
$
575.43
$
568.44
Combustion
Prices
($
per
ton):
SDL
Option
3
Organic
Sludges
(
Halogenated)

Organic
Sludges
(
NonHal)

Organic
Solids
(
Halogenated)

Organic
Solids
(
NonHal)

Inorganic
Liquid
(
Halogenated)

Organic
Liquids
(
Halogenated)

Gases
Inorganic
Sludge
(
Nonhalogenated)

Inorganic
Solids
(
NonHal)

Lab
Packs
Waste
Form
Organic
Liquids
(
NonHal)

Inorganic
Liquid
(
Nonhalogenated)
FINAL
DRAFT:
March
2004
69
APPENDIX
C
Exhibit
C­
1
Emissions
Reductions
Achieved
Under
the
Revised
Agency
Preferred
Approach
Particulate
Matter
(
tons/
yr)
a
Mercury
(
tons/
yr)
Dioxin/
Furans
(
grams/
yr)
Chlorine
(
tons/
yr)
SVM/
LVM
(
tons/
yr)

Cement
Kilns
43
(
0.11)
0.23
0
64
1.14
Incinerators
0
(
0)
0
0.28
289
0.45
LWAKs
0
(
0)
0.004
1.91
0
0.02
Coal
Boilers
437
(
5.42)
0.02
0
421
1.34
HCl
Production
Furnaces
0
(
0)
0
2.29
144
0
Liquid
Boilers
1,247
(
2.41)
0.68
0.20
659
11.40
TOTAL:
Revised
Proposalb
1,727
(
7.94)
0.93
4.69
1,577
14.35
TOTAL:
2004
Assessment
2,215
(
9.67)
0.93
4.69
2,638
16.41
Notes:

a.
Numbers
in
parentheses
after
the
estimates
of
PM
emissions
reductions
represent
reductions
in
nonenumerated
metals
emissions
associated
with
the
PM
standards.
The
non­
enumerated
metals
are
manganese,
cobalt,
nickel,
antimony,
and
selenium.
b.
Totals
may
not
add
due
to
rounding.
