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Summary
Note
to
reader:
This
redline­
strikeout
version
of
chapter
6
of
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
chapter
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
chapter.
(
Note:
Office
of
Management
and
Budget
comments
and
questions
on
all
other
chapters
and
appendices
of
the
Assessment
document
were
minor
and
resulted
in
no
substantive
changes
to
any
other
parts
of
the
Assessment
document).

Deletions
are
shown
with
the
following
attributes
and
color:
Strikeout,
Blue
RGB(
0,0,255).
Deleted
text
is
shown
as
full
text.
Insertions
are
shown
with
the
following
attributes
and
color:
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Underline,
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RGB(
255,0,0).
Moved
blocks
are
marked
in
the
new
location,
and
only
referenced
in
the
old
location.
Moved
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are
shown
in
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following
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Orange
RGB(
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The
document
was
marked
with
285
Deletions,
348
Insertions,
1
Move.
FINAL
DRAFT:
March
2004
1
We
did
not
include
an
analysis
to
assess
the
potential
magnitude
of
property
value
benefits
caused
by
the
MACT
standards
due
to
limitations
of
the
benefits
transfer
approach
and
because
property
value
benefits
likely
overlap
with
some
human
health
and
ecological
benefits;.
As
a
result,
including
property
value
benefits
may
result
in
doublecounting
The
benefits
assessment
also
does
not
examine
how
secondary
impacts
such
as
emissions
from
increased
coal
use
at
combustion
sources
that
stop
burning
hazardous
waste
as
fuel
may
result
in
human
health
and
ecological
damages.

6­
2
NOTE:
After
this
Assessment
was
prepared,
the
Agency
modified
its
proposal
for
the
HWC
MACT
replacement
standards.
The
benefits
analysis
presented
in
this
chapter
does
not
reflect
this
change.
Information
on
the
costs,
benefits,
and
other
impacts
of
EPA's
proposed
HWC
MACT
replacement
standards
is
available
in
EPA,
"
Addendum
to
the
Assessment
of
the
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Proposed
Rule,"
March
2004.
This
document
can
be
found
in
the
docket.

NOTE:
This
chapter
does
not
provide
quantified
or
monetary
estimates
of
the
benefits
associated
with
reduced
dioxin
emissions.
However,
estimates
of
the
benefits
associated
with
reduced
dioxin
emissions
under
the
revised
proposal
for
the
HWC
MACT
replacement
standards
are
available
in
EPA,
"
Addendum
to
the
Assessment
of
the
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Proposed
Rule,"
March
2004.
This
document
can
be
found
in
the
docket.

BENEFITS
ASSESSMENT
CHAPTER
6
______________________________________________________________________________

This
chapter
presents
the
benefits
assessment
for
the
proposed
HWC
MACT
replacement
standards.
To
evaluate
incremental
benefits
to
society
of
emission
reductions
at
hazardous
waste
combustion
facilities
we
use
results
from
EPA's
1998
multiple
pathway
human
health
and
ecological
risk
assessment
updated
to
address
incremental
benefits
of
the
replacement
standards
(
e.
g.,
assuming
that
the
2002
interim
standards
are
in
place).
1
This
chapter
also
briefly
discusses
how
the
proposed
FINAL
DRAFT:
March
2004
6­
3
MACT
replacement
standards
may
potentially
lead
to
changes
in
the
types
and
quantities
of
wastes
generated
and
managed
at
combustion
facilities
through
increased
waste
minimization.
FINAL
DRAFT:
March
2004
6­
4
The
chapter
is
organized
into
eight
sections:


Risk
Assessment
Overview:
Provides
a
brief
summary
of
the
methodology
and
key
results
from
the
multiple
pathway
risk
assessment
which
forms
the
basis
for
the
human
health
and
ecological
benefits
assessment.


Human
Health
Benefits
Analysis:
Describes
the
approach
and
presents
results
for
characterizing
human
health
benefits
from
the
risk
results.
Where
possible,
we
assign
monetary
values
to
these
risk
reductions
using
different
economic
valuation
techniques.
We
also
describe
benefits
to
sensitive
subpopulations
in
quantitative,
non­
monetary
terms.


Visibility:
Describes
the
approach
and
presents
results
for
characterizing
visibility
improvements.
We
assign
monetary
values
to
these
improvements
using
economic
valuation
techniques.


Ecological
Benefits
Analysis:
Describes
the
methodology
and
results
from
the
1999
standards
ecological
benefits
assessment
and
provides
a
comparison
to
the
expected
ecological
benefits
of
the
replacement
standards.


Forest
Health
and
Aesthetics:
Describes
the
impacts
of
HAPs
on
forest
ecosystems
and
provides
examples
of
forest
health
and
aesthetics
benefit
assessments.
Forest
health
and
aesthetics
benefits
results
are
described
in
qualitative
terms
due
to
the
lack
of
research
linking
measurable
effects
of
HAPs
on
forest
ecosystems.


Agricultural
Productivity:
Describes
the
potential
effects
of
emissions
on
agricultural
productivity.
Agricultural
productivity
benefits
are
described
in
qualitative
terms
as
little
research
has
been
done
on
the
effects
of
the
compounds
of
concern
in
this
analysis.


Waste
Minimization
Benefits:
Describes
the
benefits,
if
any,
that
the
replacement
MACT
standards
may
have
on
increasing
waste
minimization
practices.


Conclusions:
Summarizes
key
findings
from
the
benefits
assessment.
FINAL
DRAFT:
March
2004
6­
5
FINAL
DRAFT:
March
2004
2
Although
we
extrapolate
benefits
from
the
estimates
presented
in
the
1999
Assessment
and
the
1999
Addendum,
the
2002
Interim
Standards
serve
as
the
baseline
of
our
analysis.
The
2002
Interim
Standards
are
generally
similar
to
the
standards
examined
in
the
1999
Assessment
and
Addendum;
therefore,
these
1999
analyses
serve
as
a
reasonable
approximation
of
the
2002
Interim
Standards
baseline.

6­
6
This
benefits
analysis
builds
upon
the
results
and
discussions
presented
in
the
1999
Assessment
and
the
1999
Addendum.
These
documents
are
cited
as
source
material
for
the
current
analysis
because
they
generally
provide
a
reasonable
approximation
of
the
2002
Interim
Standards
baseline.
***
However,
it
is
important
to
note
that
the
2002
Interim
Standards,
not
the
1999
standards,
represent
the
baseline
for
the
HWC
MACT
replacement
standards***.
When
the
1999
analyses
are
used
to
approximate
the
2002
baseline,
this
Assessment
identifies
the
necessary
adjustments.

It
is
also
important
to
note
that
the
benefits
analysis
assumes
a
baseline
scenario
with
constant
future
capacity
and
with
combustion
facilities
operating
at
levels
corresponding
to
trial
burn
performance.
As
explained
in
the
"
Regulatory
Baseline"
chapter,
the
characteristics
of
waste
fed
during
normal
operations
may
differ
significantly
from
that
fed
during
trial
burns.
In
particular,
facilities
often
"
spike"
the
waste
feed
at
the
trial
burns
with
high
levels
of
metals,
chlorine,
and
mercury.
This
situation
results
in
emission
estimates
that
likely
exceed
"
typical"
emissions.
Therefore,
the
risk
reductions
and
benefits
estimates
may
overstate
true
benefits.
Conversely,
if
significant
numbers
of
facilities
cease
burning
waste
altogether,
then
risk
reductions
at
those
facilities
may
in
some
cases
be
greater
than
this
analysis
assumes.

BENEFITS
QUANTIFICATION
OVERVIEW
The
basis
for
the
quantitative
benefits
assessment
is
an
extrapolation
of
particulate
matter
(
PM)
benefits
estimated
for
the
1999
standards
in
the
1999
Assessment.
2
This
section
provides
an
overview
of
the
methods
used
to
extrapolate
the
incremental
benefits
of
the
replacement
standards
from
those
estimated
for
the
1999
standards.
Any
comparison
of
the
2002
interim
standards,
currently
in
place,
to
the
proposed
HWC
MACT
replacement
standards
is
complicated.
No
separate
risk
assessment
was
conducted
for
the
interim
standards.
In
general,
because
the
interim
standards
involved
only
modest
changes
from
the
1999
standards
the
benefits
for
the
interim
standards
are
likely
to
be
similar
in
magnitude
to
the
1999
standards.
Therefore,
we
assume
that
the
benefits
estimates
in
the
1999
Assessment
are
a
reasonable
proxy
for
benefits
realized
under
the
2002
interim
standards.
FINAL
DRAFT:
March
2004
3
See
"
Human
Health
and
Ecological
Risk
Assessment
Support
to
the
Development
of
Technical
Standards
for
Emissions
from
Combustion
Units
Burning
Hazardous
Wastes:
Background
Document"
JulyNovember
19998.

4
It
should
be
noted
that
the
avoided
incidence
estimates
were
based
entirely
on
the
incremental
decrease
in
ambient
air
concentrations
associated
with
emission
controls
on
the
hazardous
waste
sources
subject
to
the
1999
rule.
Background
levels
of
PM
were
assumed
to
be
sufficiently
high
to
exceed
any
possible
threshold
of
effect
but
ambient
background
levels
of
PM
were
not
otherwise
considered
in
the
analysis.

5
To
account
for
the
increase
in
population
since
the
1990
census
was
taken,
we
also
adjusted
the
avoided
incidence
estimates
by
the
ratio
of
the
population
at
the
national
level
(
corresponding
to
the
concentration­
response
function)
for
the
year
2000
census
vs.
the
1990
census.

6­
7
For
the
1999
Assessment,
EPAwe
estimated
the
avoided
incidence
of
mortality
and
morbidity
associated
with
reductions
in
PM
emissions.
3
The
risk
assessment
developed
estimated
cases
of
mortality
and
morbidity
avoided
for
children
and
the
elderly,
as
well
as
the
general
population,
using
concentration­
response
functions
derived
from
human
epidemiological
studies
available
in
1998.
Morbidity
effects
included
respiratory
and
cardiovascular
illnesses
requiring
hospitalization,
as
well
as
other
illnesses
not
requiring
hospitalization,
such
as
acute
and
chronic
bronchitis
and
acute
upper
and
lower
respiratory
symptoms.
The
risk
assessment
also
estimated
decreases
in
PM­
related
minor
restricted
activity
days
(
MRADs)
and
work
loss
days
(
WLDs).
Rates
of
avoided
incidence,
work
days
lost,
and
days
of
restricted
activity
were
estimated
for
each
of
16
sectors
surrounding
a
facility
using
the
concentration­
response
functions
and
sector­
specific
estimates
of
the
corresponding
population
and
model­
derived
ambient
air
concentration,
either
annual
mean
PM
10
or
PM
2.5
concentrations
or
distributions
of
daily
PM
10
or
PM
2.5
concentrations,
depending
on
the
concentration­
response
function.
The
sectors
were
defined
by
four
concentric
rings
out
to
a
distance
of
20
kilometers
(
about
12
miles),
each
of
which
was
divided
into
four
quadrants.
The
sector­
specific
rates
were
weighted
by
facility­
specific
sampling
weights
and
then
summed
to
give
the
total
incidence
rates
for
a
given
source
category.
4
To
assess
the
benefits
of
the
proposed
HWC
MACT
replacement
standards,
EPAwe
took
the
avoided
incidence
estimates
from
the
1999
Assessment
and
adjusted
them
to
reflect
both
the
PM
emission
reductions
projected
to
occur
under
the
replacement
standards
***(
incremental
to
the
2002
Interim
Standards)***,
and
changes
in
the
universe
of
facilities
burning
hazardous
wastes
since
the
1999
Assessment.
For
cement
kilns,
lightweight
aggregate
kilns,
and
incinerators,
the
estimates
were
made
by
adjusting
the
respective
estimates
at
the
source
category
level
by
the
ratio
of
emission
reductions
(
for
the
replacement
standards
vs.
the
1999
standards)
and
the
ratio
of
the
number
of
facilities
affected
by
the
rules
(
facilities
currently
burning
hazardous
wastes
vs.
facilities
burning
hazardous
wastes
in
the
1999
Assessment).
5
For
liquid
and
solid
fuel­
fired
boilers
and
hydrochloric
acid
production
furnaces,
EPAwe
extrapolated
the
avoided
incidence
from
the
incinerator
source
FINAL
DRAFT:
March
2004
6­
8
category
using
a
similar
approach,
except
that
the
ratios
of
the
exposed
populations
were
used
(
corresponding
to
the
concentration­
response
functions
from
the
1999
Assessment),
instead
of
the
number
of
facilities.
FINAL
DRAFT:
March
2004
6
OMB
guidance
recommends
that
federal
agencies
conduct
probabilistic
assessments
of
the
benefits
associated
with
new
regulation.
Office
of
Management
and
Budget.
Informing
Regulatory
Decisions:
2003
Report
to
Congress
on
the
Costs
and
Benefits
of
Federal
Regulations
and
Unfunded
Mandates
on
State,
Local,
and
Tribal
Entities.
2003.

7
"
Human
Health
and
Ecological
Risk
Assessment
Support
to
the
Development
of
Technical
Standards
for
Emissions
from
Combustion
Units
Burning
Hazardous
Wastes:
Background
Document
­
Final
Report,"
November
1998.

6­
9
EPAWe
estimated
the
exposed
populations
for
hazardous
waste­
burning
boilers
and
HCl
production
furnaces
using
the
same
GIS
methods
as
the
1999
Assessment
(
e.
g.,
a
16
sector
overlay).
Nonetheless,
the
extrapolated
estimates
are
subject
to
additional
uncertainty,
especially
for
solid
fuelfired
boilers
and
HCl
production
furnaces
because
these
two
source
categories
have
only
a
small
number
of
facilities
and
may
be
poorly
represented
by
the
incinerator
facilities
analyzed
in
the
1999
Assessment.

It
is
important
to
note
that
the
proposed
HWC
MACT
replacement
standards
are
incremental
to
the
previous
(
2002
interim)
rule.
Therefore,
benefits
are
more
modest
than
the
1999
estimates
because
the
baseline
reflects
the
implementation
of
the
rule
similar
to
the
1999
rule,
and
assumes
that
a
significant
portion
of
the
benefits
estimated
in
the
1999
Assessment
have
already
been
captured.
Although
the
benefits
estimated
in
this
analysis
are
expected
to
be
more
modest
than
those
estimated
in
the
1999
Assessment
the
benefits
captured
by
both
analyses
represent
only
a
portion
of
the
benefits
associated
with
this
rule.
Specific
ecological
and
human
health
benefits
are
not
captured
because
of
lack
of
research
linking
measurable
effects
of
HAPs
on
human
and
ecosystem
health
and
ecosystems.

The
benefits
estimates
in
this
assessment
are
presented
as
point
estimates
instead
of
in
probabilistic
terms.
6
Although
probabilistic
estimates
would
provide
valuable
information
about
the
uncertainty
associated
with
the
benefits
of
the
proposed
HWC
MACT
replacement
standards,
probabilistic
analysis
was
not
amenable
to
our
methodology
of
adjusting
the
benefits
estimates
presented
in
the
1999
Assessment,
which
were
not
expressed
in
probabilistic
terms.***
In
certain
cases,
however,
we
present
monetized
estimates
as
a
range
to
reflect
uncertainty
in
valuation
techniques.***

RISK
ASSESSMENT
OVERVIEW
The
basis
for
the
1999
benefits
Assessment
was
a
multiple­
pathway
risk
assessment
developed
by
the
Economics,
Methods
and
Risk
Analysis
Division
in
EPA's
Office
of
Solid
Waste.
This
risk
assessment
was
designed
to
estimate
baseline
risks
from
hazardous
waste
combustion
emissions,
as
well
as
expected
risks
after
the
1999
MACT
standards
were
implemented.
7
This
section
provides
an
FINAL
DRAFT:
March
2004
8
EPA
The
Agency
expects
that
hazardous
waste­
burning
kilns
that
are
able
to
use
feed
control
to
achieve
emissions
reductions
will
also
generate
cement
kiln
dust
(
CKD)
with
a
lower
toxicity
than
prior
to
feed
control
(
in
particular,
lower
SVM
content)
(
USEPA
"
Selection
of
MACT
Standards
and
Technology,"
Chapter
12
of
Volume
3
Technical
Support
Document
for
HWC
MACT
Standards,
July
1999.)
The
risk
assessment
did
not
address
the
potential
human
health
and
ecological
benefits
associated
with
reduced
toxicity
CKD.

9
A
less
detailed
screening­
level
analysis
was
used
in
the
1999
Assessment
to
identify
the
potential
for
ecological
risks.

10
For
a
more
detailed
discussion
of
the
land
use
characterization,
see:
Zachary
Pekar
and
Tony
Marimpietri,

"
Description
of
Methodologies
and
Data
Sources
Used
in
Characterizing
Land
Use
(
including
Human/
Livestock
Populations),
Air
Modeling
Impacts,
and
Waterbody/
Watershed
Characteristics
for
HWC
Study
Areas,"
Memorandum,
Prepared
for
David
Layland,
U.
S.
Environmental
Protection
Agency,
27
January
1998.

11
According
to
the
risk
assessment,
the
random
sample
of
65
facilities
ensures
that
the
probability
of
modeling
at
least
one
high­
risk
facility
is
90
percent.
The
other
11
combustion
facilities
were
selected
for
the
risk
assessment
at
Proposal.
Because
these
11
facilities
were
not
selected
at
random,
they
are
handled
differently
from
the
65
randomly
selected
facilities
in
extrapolating
risks
to
reflect
the
universe
of
facilities.

12
PM
is
not
evaluated
in
the
screening
for
ecological
risks.
Also,
the
national
risk
assessment
did
not
include
an
assessment
of
the
risk
posed
by
nondioxin
products
of
incomplete
combustion
(
PICs)
due
to
the
lack
of
sufficient
emission
measurements.

13
Includes
divalent
mercury
(
via
ingestion),
elemental
mercury
(
via
inhalation),
and
methyl
mercury
(
via
ingestion).
We
recognize
that
these
chemicals
are
not
all
HAPs;
however,
the
risk
assessment
analyzed
all
chemical
constituents
covered
by
the
rule
for
which
sufficient
data
were
available.
Both
chromium
(
III)
and
chromium
(
VI)
were
evaluated
in
the
risk
assessment.

6­
10
overview
of
the
risk
assessment,
which
analyzed
both
human
health
and
ecological
risks
that
result
from
direct
and
indirect
exposure
to
emissions
from
facilities
that
burn
hazardous
waste.
8
A
multiple
pathway
analysis
that
models
both
inhalation
and
ingestion
pathways
was
used
to
estimate
human
health
risks.
9
The
Assessment
used
a
statistically­
based
stratified
random
sampling
approach
in
which
76
hazardous
waste
combustion
facilities
and
their
site­
specific
land
uses
and
environmental
settings
were
characterized.
10
The
randomly
selected
facilities
in
the
study
included:
43
on­
site
incinerators,
13
commercial
incinerators,
15
cement
kilns,
and
five
lightweight
aggregate
kilns.
11
The
current
Assessment
adjusts
the
estimates
from
the
1999
Assessment
to
project
the
human
health
benefits
of
the
replacement
standards.

The
pollutants
analyzed
in
the
risk
assessment
included
dioxins
and
furans,
selected
metals,
and
PM.
12
The
metals
modeled
in
the
Assessment
include
the
following:
antimony,
arsenic,
barium,
beryllium,
cadmium,
chromium
copper,
cobalt,
lead,
manganese,
mercury,
nickel,
selenium,
silver,
and
thallium.
13
The
risk
assessment
modeled
fate
and
transport
of
the
emissions
of
these
pollutants
FINAL
DRAFT:
March
2004
6­
11
to
arrive
at
concentrations
in
air,
soil,
surface
water,
and
sediments.
To
assess
human
health
risks,
these
concentrations
can
be
converted
to
estimated
doses
to
the
exposed
populations
using
exposure
factors
such
as
inhalation
and
ingestion
rates.
These
risk
assessment
calculated
cancer
and
noncancer
risks
using
these
doses,
if
the
appropriate
health
benchmarks
were
available.
FINAL
DRAFT:
March
2004
14
The
methodology
used
to
develop
the
eco­
toxicological
criteria
is
largely
a
product
of
the
ecological
risk
assessment
work
conducted
to
support
the
proposed
HWIR
for
process
waste.

15
Some
of
the
exposure
levels
will
not
be
sector
specific
(
e.
g.,
exposure
to
dioxin
in
dairy
products
is
based
on
an
average
concentration
at
dairies
throughout
the
entire
study
area.)

6­
12
This
Assessment
provides
a
discussion
of
the
ecological
benefits
that
may
be
associated
with
the
replacement
standards
by
comparing
emissions
reductions
to
the
reductions
from
the
1999
standards.
In
the
1999
Assessment,
soil,
surface
water
and
sediment
concentrations
were
compared
with
eco­
toxicological
criteria
representing
protective
screening
values
for
ecological
risks
to
assess
potential
ecological
risks.
14
Because
these
criteria
were
based
on
de
minimis
ecological
effects
and
thus
represented
conservative
values,
an
exceedence
of
the
eco­
toxicological
criteria
did
not
necessarily
indicate
ecological
damage;
it
simply
suggested
that
potential
damages
could
not
be
ruled
out.

To
characterize
the
non­
cancer
risks
to
the
populations
listed
above,
the
1999
risk
assessment
broke
down
the
area
surrounding
each
modeled
combustion
facility
into
16
polar
grid
sectors,
as
illustrated
in
Exhibit
6­
1.
For
each
polar
grid
sector,
risk
estimates
were
developed
for
different
age
groups
and
receptor
populations
(
e.
g.,
0­
5
year
old
children
of
subsistence
fishers).
This
approach
was
used
because
geographic
and
demographic
differences
across
polar
grid
sectors
lead
to
sectoral
variation
in
individual
risks.
Thus,
individual
risk
results
are
aggregated
across
sectors
and
weighted
by
population
in
each
sector
to
generate
the
distribution
of
risk
to
individuals
in
the
affected
area.
15
An
additional
Monte
Carlo
analysis
was
conducted
to
incorporate
variability
in
other
exposure
factors
such
as
inhalation
and
ingestion
rates.

HUMAN
HEALTH
BENEFITS
This
section
describes
in
greater
detail
the
approaches
for
characterizing
human
health
benefits.
The
starting
point
for
assessing
benefits
is
identifying
those
pollutants
for
which
emission
reductions
are
expected
to
result
in
improvements
to
human
health
or
the
environment.
We
then
summarize
the
relevant
results
from
the
risk
assessment
for
the
pollutants
of
concern,
focusing
on
population
risk
results
based
on
central
tendency
exposure
parameters
so
that
benefits
can
be
appropriately
compared
with
total
costs.
We
express
the
risk
assessment
data
as
indicators
of
potential
benefits,
such
as
reduced
potential
for
developing
particular
illnesses.
Where
possible,
we
assign
monetary
values
to
these
benefits
using
a
benefits
transfer
approach.

Human
Health
Benefits
Methodology
FINAL
DRAFT:
March
2004
6­
13
Exhibit
6­
1
DIAGRAM
OF
16
SECTOR
POLAR­
BASED
GRID
USED
IN
THE
RISK
ASSESSMENT
Waterbody
(
lake)

One
of
16
sectors
U.
S.
Census
Block
Group
0­
2
km
ring
2­
5
km
ring
5­
10
km
ring
10­
20
km
ring
The
approach
for
assessing
human
health
benefits
is
divided
into
two
components
 
benefits
from
cancer
risk
reductions
and
benefits
from
non­
cancer
risk
reductions.
We
separate
the
discussion
in
this
way
because
the
interpretation
of
risk
reductions
for
carcinogenic
pollutants
is
very
different
than
that
for
non­
carcinogens.
As
explained
above,
for
both
cancer
and
non­
cancer
benefits,
we
focus
on
population
risks
because
these
results
form
the
basis
for
assessing
total
benefits
of
the
proposed
HWC
MACT
replacement
standards.
In
general,
these
results
concern
the
population
overall
with
regards
to
different
age
groups,
though
risk
reductions
associated
with
certain
pollutants,
such
as
lead,
specifically
affect
children
within
the
population.
In
these
cases,
we
focus
on
the
benefits
to
a
subset
population,
ages
0­
19.

In
addition
to
population
results,
we
also
describe
individual
risk
results
for
the
hypothetical
worst
case
scenarios
for
both
cancer
and
non­
cancer
risks.
Because
we
do
not
have
population
data
for
the
most
sensitive
sub­
populations,
we
can
only
describe
individual
risk
results
for
subsistence
farmers
and
fishermen
and
cannot
make
statements
concerning
the
total
number
of
people
that
may
experience
health
benefits
associated
with
the
proposed
HWC
MACT
replacement
standards.
FINAL
DRAFT:
March
2004
16
Cancer
incidence
estimates
used
direct
and
indirect
exposure
pathways
for
all
non­
subsistence
receptors,
excluding
recreational
anglers.
Population
risks
could
not
be
calculated
for
recreational
anglers
because
detailed
population
data
were
not
available
for
this
receptor
population.

17
In
a
December
30,
1997
benefits
methodology
memorandum,
we
noted
that
summing
these
estimates
may
pose
the
potential
for
double­
counting,
considering
that
dioxin­
contaminated
food
ingestion
is
also
evaluated
on
the
local
level
(
Industrial
Economics,
Incorporated,
Social
Science
Discussion
Group.
Handbook
for
Non­
Cancer
Valuation:
Draft.
Prepared
for
U.
S.
EPA,
1997,
as
cited
in
U.
S.
EPA,
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
Office
of
Solid
Waste,
July
1999).
However,
if
we
make
the
assumption
that
most
of
the
agriculture
products
produced
within
20
kilometers
of
the
facility
are
consumed
outside
the
local
area,
then
we
minimize
the
double­
counting
potential.
A
follow­
up
phone
call
with
EPA
and
Research
Triangle
Institute,
the
contractor
that
prepared
the
Combustion
Risk
Assessment,
confirmed
that
this
in
fact
is
a
reasonable
assumption.

6­
14
Approach
for
Assessing
Benefits
from
Cancer
Risk
Reductions
In
this
analysis
we
discuss
the
potential
cancer
risk
reductions
by
comparing
the
replacement
standards
to
the
results
of
the
1999
Assessment.
The
basic
approach
for
assessing
benefits
from
cancer
risk
reductions
in
the
1999
Assessment
relied
on
two
analytic
components.
First,
the
risk
assessment
estimated
cancer
risk
reductions
for
all
non­
subsistence
receptors
in
the
vicinity
of
combustion
facilities.
These
risk
reduction
estimates
were
derived
from
the
median
individual
risk
values
and
population
data
for
non­
subsistence
population.
16
Carcinogens
included
in
the
risk
assessment
were
dioxins/
furans,
arsenic,
beryllium,
cadmium,
chromium
(
VI),
and
nickel.
Second,
the
risk
assessment
estimated
cancer
risk
reductions
associated
with
the
ingestion
of
dioxin­
contaminated
foods
grown
or
raised
near
combustion
facilities
but
distributed
nationwide.
We
then
calculated
total
cancer
risk
reductions
by
summing
the
avoided
cases
in
communities
near
combustion
facilities
with
the
number
of
cases
avoided
due
to
reduced
dioxin
in
the
national
food
supply.
17
That
is,

Total
cancer
risk
reductions
=
Avoided
cases
in
communities
near
combustion
facilities
+
Avoided
cases
due
to
reduced
dioxin
in
the
national
food
supply.

The
1999Addendum
to
the1999
Assessment
estimated
0.376
cancer
deaths
would
be
avoided
annually
with
a
reduction
of
28.7
grams
of
dioxins/
furans
emissions
per
year.
The
replacement
standards
will
reduce
dioxins/
furans
emissions
by
0.4
grams
annually
for
each
of
the
Floor
options
and
24.47
grams
annually
for
the
Agency
Preferred
Approach
(
Exhibit
6­
53).
Thus,
the
replacement
standards
are
expected
to
avoid
less
than
0.376
cancer
deaths
annually.

To
assign
monetary
values
to
cancer
risk
reduction
estimates,
we
apply
the
value
of
a
statistical
life
(
VSL)
to
the
risk
reduction
expected
to
result
from
the
replacement
MACT
standards.
FINAL
DRAFT:
March
2004
18
Viscusi,
W.
Kip.
Fatal
Tradeoffs:
Public
and
Private
Responsibilities
for
Risk.
New
York:
Oxford
University
Press,
1992.

19
VSL
was
converted
to
2002
dollars
using
the
Consumer
Price
Index
for
all
goods.
WTP
estimates
are
converted
using
the
Consumer
Price
Index
for
all
goods,
while
cost
of
illness
estimates
are
converted
using
the
Consumer
Price
Index
for
medical
expenditures
only.

20
U.
S.
EPA
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
January
2004.
Pg.
4­
65.

21
This
mean
value
and
range
are
consistent
with
estimates
presented
in
U.
S.
EPA,
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
January
2004,
inflation
adjusted.

22
Particulate
matter
is
the
only
***
non­
carcinogenother
pollutant***
in
the
risk
assessment
for
which
there
is
sufficient
dose­
response
information
to
estimate
numbers
of
cases
of
disease
and
deaths
from
exposures.

6­
15
The
VSL
is
based
on
an
individual's
willingness
to
pay
(
WTP)
to
reduce
a
risk
of
premature
death
or
their
willingness
to
accept
(
WTA)
increases
in
mortality
risk.
17
Because
t
There
are
many
different
estimates
of
VSL
in
the
economic
literature,
we
would
estimate
the
reduced
mortality
benefits
using
a
range
of
VSL
estimates
from.
Viscusi18
presents
26
policy­
relevant
value­
of­
life
studies.
***
As
shown
in
Exhibit
6­
2,
the
estimated
VSL
figures
from***
tThese
studies
range
from
$
0.860
million
to
$
198.5623
million,
with
an
average
value
of
$
6.8842
million
(
in
2002
dollars).
19
***
For
this
analysis
we
are
altering
the
value
of
a
statistical
life
(
VSL)
to
reflect
new
information
in
the
ongoing
academic
debate
over
the
appropriate
characterization
of
the
value
of
reducing
the
risk
of
premature
mortality.
We
are
characterizing
the
VSL
distribution
in
a
more
general
fashion,
based
on
two
recent
meta
analyses
of
the
wage­
risk­
based
VSL
literature.
The
new
distribution
is
assumed
to
be
normal,
with
a
mean
of
$
5.5
million
(
in
1999
dollars)
and
a
95
percent
confidence
interval
between
$
1
and
$
10
million.
20,21
***
To
value
the
mortality
risk
reductions,
we
would
multiply
the
expected
number
of
annual
premature
statistical
deaths
avoided
by
the
high­
end,
low­
end,
and
mean
value
of
the
VSL
estimates.
The
Agency
welcomes
public
comment
on
the
appropriate
methodology
for
valuing
reductions
in
the
risk
of
premature
death.

Approach
for
Assessing
Benefits
from
Non­
Cancer
Risk
Reductions
A
variety
of
approaches
are
used
to
evaluate
the
benefits
of
reducing
particulate
matter,
for
which
we
estimate
both
morbidity
and
mortality
benefits.
22
For
lead
and
mercury,
we
compare
the
replacement
standards
to
the
results
of
the
1999
Assessment.
In
the
1999
Assessment
we
used
upper
bound
estimates
of
the
population
at
risk
because
we
only
had
information
on
the
potential
of
an
adverse
effect
and
we
could
not
say
anything
about
the
likelihood
of
the
effects.

We
assign
monetary
values
to
non­
cancer
benefits
using
a
direct
cost
approach
which
focuses
on
the
expenditures
averted
by
decreasing
the
occurrence
of
an
illness
or
other
health
effects.
While
the
WTP
approach
used
for
valuing
the
cancer
risk
reductions
is
conceptually
superior
to
the
direct
FINAL
DRAFT:
March
2004
6­
16
cost
approach,
measurement
difficulties,
such
as
estimating
the
severity
of
various
illnesses,
preclude
us
from
using
this
approach
here.
Direct
cost
measures
are
expected
to
understate
true
benefits
because
they
do
not
include
cost
of
pain,
suffering,
and
time
lost.
On
the
other
hand,
because
we
use
upper
bound
estimates
of
the
population
at
risk,
we
cannot
conclude
that
the
results
are
biased
in
one
direction
or
the
other.
FINAL
DRAFT:
March
2004
23
The
benefits
discussion
that
follows
in
the
rest
of
this
paragraph
is
adapted
from
EPA,
Regulatory
Impact
Analysis
of
the
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.

24
U.
S.
EPA,
Regulatory
Impact
Analysis
of
The
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.

25
U.
S.
EPA,
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
January
2004.

26
Research
Triangle
Institute,
Human
Health
and
Ecological
Risk
Assessment
Support
to
The
Development
of
Technical
Standards
for
Emissions
from
Combustion
Units
Burning
Hazardous
Wastes:
Background
Document,
prepared
for
U.
S.
EPA,
Office
of
Solid
Waste,
July
1999.

6­
17
Benefits
from
Reduced
Exposure
to
Particulate
Matter
Epidemiological
studies
have
linked
PM
(
alone
or
in
combination
with
other
air
pollutants)
with
a
series
of
health
effects.
23
PM
can
accumulate
in
the
respiratory
system
and
aggravate
health
problems
such
as
asthma,
or
it
can
penetrate
deep
into
the
lungs
and
lead
to
even
more
serious
health
problems.
These
health
effects
include
premature
death,
respiratory
symptoms
and
disease,
diminished
lung
function,
and
weakened
respiratory
tract
defense
mechanisms.
Children,
the
elderly,
and
people
with
cardiopulmonary
disease,
such
as
asthma,
are
most
at
risk
from
these
health
effects.

***
Since
performing
the
risk
assessment
for
the
1999
Assessment,
EPA
has
updated
its
benefits
methodology
to
reflect
recent
advances
in
air
quality
modeling
and
human
health
benefits
modeling.
To
estimate
PM
exposure
for
the
1999
risk
assessment,
the
Agency
used
the
Industrial
Source
Complex
Model­
Short
Term
Version
3
(
ISCST3).
More
recent
EPA
benefits
analyses
have
used
more
advanced
air­
quality
models.
For
example,
the
Agency's
assessment
of
the
industrial
boilers
and
process
heaters
NESHAP
used
the
Climatological
Regional
Dispersion
Model
(
CRDM),
which
uses
a
national
source­
receptor
matrix
to
estimate
exposure
associated
with
PM
emissions.
24
Similarly,
the
Agency's
analysis
of
the
proposed
Inter­
state
Air
Quality
Rule
used
the
Regional
Modeling
System
for
Aerosols
and
Deposition
(
REMSAD),
which
also
accounts
for
the
long­
range
transport
of
particles.
25
In
contrast,
ISCST3
modeled
exposure
within
a
20­
kilometer
radius
of
each
emissions
source
for
the
1999
risk
assessment.
26
To
the
extent
that
PM
is
transported
further
than
20
km
from
each
emissions
source,
the
1999
risk
assessment
may
underestimate
PM
exposure.
In
addition,
to
estimate
exposure
in
the
1999
risk
assessment,
EPA
used
block­
group­
level
data
from
the
1990
Census.
More
recent
studies
use
data
from
the
2000
Census.

More
recent
EPA
benefits
analyses
also
apply
a
different
concentration­
response
function
for
PM
mortality
than
that
used
for
the
1999
risk
assessment.
In
1999,
EPA
used
the
concentration­
FINAL
DRAFT:
March
2004
27Pope,
C.
A.,
III,
M.
J.
Thun,
M.
M.
Namboodiri,
D.
W.
Dockery,
J.
S.
Evans,
F.
E.
Speizer,
and
C.
W.
Heath,
Jr.
1995.
Particulate
air
pollution
as
a
predictor
of
mortality
in
a
prospective
study
of
U.
S.
adults.
American
Journal
of
Respiratory
and
Critical
Care
Medicine151:
669­
674,
as
cited
in
Research
Triangle
Institute,
op.
cit.

28
Krewski
D,
Burnett
RT,
Goldbert
MS,
Hoover
K,
Siemiatycki
J,
Jerrett
M,
Abrahamowicz
M,
White
WH.
2000.
Reanalysis
of
the
Harvard
Six
Cities
Study
and
the
American
Cancer
Society
Study
of
Particulate
Air
Pollution
and
Mortality.
Special
Report
to
the
Health
Effects
Institute,
Cambridge
MA,
July
2000.

6­
18
response
function
published
by
Pope,
et
al.
in
1995.27
Since
that
time,
health
scientists
have
refined
estimates
of
the
concentration­
response
relationship,
and
EPA
has
updated
its
methodology
for
estimating
benefits
to
reflect
these
more
recent
estimates.
In
its
regulatory
impact
analysis
of
the
nonhazardous
boiler
MACT
standards,
EPA
used
the
Krewski,
et
al.
re­
analysis
of
the
1995
Pope
study
to
estimate
avoided
premature
mortality.
28
Since
the
relative
risk
estimated
in
the
Krewski
study
(
1.18)
is
nearly
the
same
as
that
presented
in
Pope
et
al.(
1.17),
the
Agency
assumes
that
updating
the
1999
risk
assessment
to
reflect
the
results
of
the
2000
Krewski
study
would
have
minimal
impact
on
the
estimated
benefits
associated
with
the
proposed
HWC
MACT
replacement
standards.***

To
assess
benefits
from
reduced
exposure
to
particulate
matter
in
1999,
EPAwe
first
estimated
the
number
of
excess
mortality
and
hospital
admissions
in
the
baseline
and
under
various
1999
MACT
standard
scenarios.
EPAWe
then
subtracted
the
number
of
cases
post­
MACT
from
the
number
of
cases
in
the
baseline
to
determine
potential
avoided
deaths
and
hospital
admissions.
Hospital
admissions
are
associated
with
respiratory
illness
and
cardiovascular
disease.
For
the
current
assessment
EPAwe
scaled
the
cases
found
in
the
1999
Assessment
to
reflect
current
conditions
and
emission
reductions
achieved
by
the
proposed
HWC
MACT
replacement
standards.
FINAL
DRAFT:
March
2004
29
Work
loss
days
and
mild
restricted
activity
days
do
not
necessarily
affect
a
worker's
income
and
do
not
generally
require
hospitalization.
It
does,
however,
result
in
lost
economic
productivity
and
consequently,
a
loss
to
society.

6­
19
***
Exhibit
6­
2***

***
SUMMARY
OF
MORTALITY
VALUATION
ESTIMATESStudyType
of
EstimateValuation
(
millions
2002$)
Kneisner
and
Leeth
(
1991)
(
US)
Labor
Market0.86Smith
and
Gilbert
(
1984)
Labor
Market0.98Dillingham
(
1985)
Labor
Market1.35Butler
(
1983)
Labor
Market1.60Miller
and
Guria
(
1991)
Contingent
Value1.72Moore
and
Viscusi
(
1988a)
Labor
Market3.57Viscusi,
Magat,
and
Huber
(
1991b)
Contingent
Value3.94Marin
and
Psacharopoulos
(
1982)
Labor
Market4.06Gegax
et
al.
(
1985)
Contingent
Value4.80Kneisner
and
Leeth
(
1991)
(
Australia)
Labor
Market4.80Gerking,
de
Haan,
and
Schulze
(
1988)
Contingent
Value4.92Cousineau,
Lacroix,
and
Girard
(
1988)
Labor
Market5.17Jones­
Lee
(
1989)
Contingent
Value5.54Dillingham
(
1985)
Labor
Market5.66Viscusi
(
1978,
1979)
Labor
Market5.90R.
S.
Smith
(
1976)
Labor
Market6.64V.
K.
Smith
(
1976)
Labor
Market6.77Olson
(
1981)
Labor
Market7.50Viscusi
(
1981)
Labor
Market9.47R.
S.
Smith
(
1974)
Labor
Market10.46Moore
and
Viscusi
(
1988a)
Labor
Market10.58Kneisner
and
Leeth
(
1991)
(
Japan)
Labor
Market10.95Herzog
and
Schlottman
(
1987)
Labor
Market13.16Leigh
and
Folson
(
1984)
Labor
Market14.02Leigh
(
1987)
Labor
Market15.01Gaten
(
1988)
Labor
Market19.56Source:
Viscusi,
W.
Kip.
Fatal
Tradeoffs:
Public
and
Private
Responsibilities
for
Risk.
New
York:
Oxford
University
Press,
1992
***
In
addition
to
avoided
illnesses
and
deaths,
benefits
of
reduced
PM
emissions
include
valuation
of
work
loss
days
and
mild
restricted
activity
days
(
MRAD).
To
assess
benefits
from
reduced
particulate
matter
exposure,
EPAwe
first
estimated
the
number
of
excess
mortality
cases,
cases
of
illnesses,
restricted
activity
days,
and
work
loss
days
in
the
baseline.
We
then
estimate
the
number
of
cases
under
four
MACT
standards:
Option
1
Floor,
Option
2
Floor,
Option
3
Floor,
and
Agency
Preferred
Approach.
To
determine
potential
benefits
for
each
option,
we
then
subtract
the
number
of
post­
MACT
cases
from
the
number
of
baseline
cases.
We
estimated
benefits
based
on
the
dollar
value
associated
with
the
following
health
conditions:


respiratory
illness,


upper
respiratory
symptoms,


lower
respiratory
symptoms,


chronic
bronchitis,


acute
bronchitis,


cardiovascular
disease,


work
loss
days,
and

mild
restricted
activity
days
(
MRAD).
29
For
avoided
deaths,
we
assign
monetary
values
in
the
same
way
as
for
avoided
cancer
cases,
FINAL
DRAFT:
March
2004
30
These
estimates
come
from
the
following
source:
U.
S.
Environmental
Protection
Agency,
The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990,
October
1997,
I11­
I12.
Estimates
for
COPD
and
physician
charges
for
the
remaining
four
illnesses
come
from
Abt
Associates,
Incorporated,
The
Medical
Costs
of
Five
Illnesses
Related
to
Exposure
to
Pollutants,
Prepared
for
U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics,
Washington,
DC,
1992,
as
cited
in
U.
S.
EPA,
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
Office
of
Solid
Waste,
July
1999.
Hospital
charge
estimates
for
the
remaining
illnesses
are
from
A.
Elixhauser,
R.
M.
Andrews,
and
S.
Fox,
Agency
for
Health
Care
Policy
and
Research
(
AHCPR),
Center
for
General
Health
Services
Intramural
Research,
U.
S.
Department
of
Health
and
Human
Services,
Clinical
Classifications
for
Health
Policy
Research:
Discharge
Statistics
by
Principal
Diagnosis
and
Procedure,
1993,
as
cited
in
U.
S.
EPA,
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
Office
of
Solid
Waste,
July
1999;
Pope,
C.
A.,
III,
D.
W.
Dockery,
J.
D.
Spengler,
and
M.
E.
Raizenne.
1991.
Respiratory
Health
and
PM10
pollution:
a
Daily
Time
Series
Analysis.
American
Review
of
Respiratory
Diseases.
144:
668­
674,
as
cited
in
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003;
Schwartz
J.,
and
Nease
L.
M.,
2000.
Fine
Particles
are
more
strongly
associated
than
coarse
particles
with
acute
respiratory
health
effects
in
schoolchildren.
Epidemiology.
11L
6­
10,
as
cited
in
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003;
Schwartz
J.,
Dockery,
D.
W.,
Nease,
L.
M.,
Wypij,
D.,
Ware,
J.
H.,
Spengler,
J.
D.,
Koutrakis,
P.,
Speizer,
F.
E.,
and
Ferris,
Jr.,
B.
G.
1994.
Acute
Effects
of
Summer
Air
Pollution
on
Respiratory
Symptom
Reporting
in
Children.
American
Journal
of
Respiratory
Critical
Care
Medicine.
150.
1234­
1242,
as
cited
in
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003;
and
Dockery,
D.
W.,
J.
Cunningham,
A.
I.
Damokosh,
L.
M.
Neas,
J.
D.
Spengler,
P.
Koutrakis,
J.
H.
Ware,
M.
Raizenne,
and
F.
R.
Speizer.
1996.
Health
Effects
of
Acid
Aerosols
on
North
American
Children­
Respiratory
Symptoms.
Enviromental
Health
Perspectives.
104(
5)"
500­
505.

6­
20
using
a
range
of
estimates
for
the
statistical
value
of
a
life
(
see
discussion
above).
For
the
avoided
illnesses
listed
above,
we
estimate
the
avoided
costs
of
hospital
admissions
for
each
of
the
health
effects
associated
with
exposure
to
particulate
matter.
To
value
the
morbidity
risk
reductions,
we
multiply
the
expected
number
of
annual
reductions
in
hospital
admissions
for
each
ailment
by
the
cost
of
illness
for
that
condition,
as
shown
in
Exhibit
6­
32.
The
estimated
cost
of
each
illness
includes
the
hospital
charge,
the
costs
of
associated
physician
care,
and
the
opportunity
cost
of
time
spent
in
the
hospital.
30
Since
these
estimates
do
not
include
post­
hospital
costs
or
pain
and
suffering
of
the
afflicted
individuals,
the
cost
of
illness
estimates
may
understate
benefits.
FINAL
DRAFT:
March
2004
6­
21
Exhibit
6­
2
AVOIDED
COST
OF
CASES
ASSOCIATED
WITH
PM
Illness
Estimated
Cost
Per
Incidence
(
2002
$)

Respiratory
Illness1
$
9,011
Upper
respiratory
symptoms2
$
27
Lower
respiratory
symptoms3
$
18
Chronic
bronchitis4
$
377,229
Acute
bronchitis5
$
55
Cardiovascular
disease1
$
15,018
Work
loss
days
(
cost
per
day)
1
$
112
Minor
restricted
activity
days
(
cost
per
day)
1
$
39
Sources:
1
U.
S.
Environmental
Protection
Agency,
The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990,
October
1997,
I11­
I12
2
Pope,
C.
A.,
III,
D.
W.
Dockery,
J.
D.
Spengler,
and
M.
E.
Raizenne.
1991.
Respiratory
Health
and
PM10
pollution:
a
Daily
Time
Series
Analysis.
American
Review
of
Respiratory
Diseases.
144:
668­
674,
as
cited
in
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003.
3
Average
of
Schwartz
J.,
and
Nease
L.
M.,
2000.
Fine
Particles
are
more
strongly
associated
than
coarse
particles
with
acute
respiratory
health
effects
in
schoolchildren.
Epidemiology.
11L
6­
10,
as
cited
in
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003;
and
Schwartz
J.,
Dockery,
D.
W.,
Nease,
L.
M.,
Wypij,
D.,
Ware,
J.
H.,
Spengler,
J.
D.,
Koutrakis,
P.,
Speizer,
F.
E.,
and
Ferris,
Jr.,
B.
G.
1994.
Acute
Effects
of
Summer
Air
Pollution
on
Respiratory
Symptom
Reporting
in
Children.
American
Journal
of
Respiratory
Critical
Care
Medicine.
150.
1234­
1242,
as
cited
in
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003.
4
U.
S.
EPA,
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
January
2004.
5
Neumann,
J.
E.,
M.
T.
Dickie,
and
R.
E.
Unsworth.
1994.
Industrial
Economics,
Incorporated.
Memorandum
to
Jim
DeMocker,
U.
S.
EPA,
Office
of
Air
and
Radiation.
Linkage
Between
Health
Effects
Estimation
and
Morbidity
Valuation
in
the
Section
812
Analysis
­­
Draft
Valuation
Document.
March
31.
Note:
Cardiovascular
disease
is
assumed
to
be
Ischemic
heart
disease.
FINAL
DRAFT:
March
2004
31
Based
on
the
population
estimated
in
the
1999
Assessment.

32
U.
S.
EPA,
The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990,
October
1997.

33
Benefits
estimate
was
converted
to
2002
dollars
using
the
Consumer
Price
Index
for
all
goods.
WTP
estimates
are
converted
using
the
Consumer
Price
Index
for
all
goods,
while
cost
of
illness
estimates
are
converted
using
the
Consumer
Price
Index
for
medical
expenditures
only.

34
The
benefits
discussion
that
follows
in
the
rest
of
this
paragraph
is
adapted
from
EPA,
Regulatory
Impact
Analysis
of
the
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.
Additional
information
related
to
the
health
effects
associated
with
mercury
are
provided
in
chapter
9
of
this
report.

6­
22
Benefits
from
Reduced
Exposure
to
Lead
The
primary
effect
from
chronic
exposure
to
lead
is
to
the
central
nervous
system.
Children
are
particularly
sensitive
to
the
effects
of
lead
and
excess
exposure
can
affect
a
child's
nervous
system
and
cognitive
development.
The
proposed
HWC
MACT
replacement
standards
will
reduce
lead
emissions
by
approximately
five
to
seven
tons
per
year
for
the
Floor
and
Agency
Preferred
Approach
options,
or
less
than
0.01
pounds
per
person.
31
The
1999
standards
were
expected
to
reduce
lead
emissions
by
89
tons
per
year,
or
0.17
pounds
per
person,
and
were
expected
to
reduce
cumulative
lead
exposures
for
seven
children
age
0­
5
to
less
than
10
µ
g/
dL.
The
benefits
associated
with
the
replacement
standards
are
expected
to
be
more
modest
per
year,
reducing
the
cumulative
lead
exposures
for
fewer
than
seven
children
age
0­
5,
to
less
than
10
µ
g/
dL
annually.

The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990
monetizes
benefits
of
reduced
lead
emissions
by
associating
high
blood
lead
levels
with
reduction
in
IQ.
32
The
analysis
estimates
annual
benefits
of
about
$
42
million
associated
with
reductions
ranging
from
5,000
to
13,000
tons
of
lead,
depending
on
the
year.
33
The
reduction
of
lead
emissions
and
increase
in
IQ
does
not
display
a
linear
relationship
and
cannot
be
transferred
to
this
analysis
so
we
do
not
attempt
to
monetize
them.

Benefits
from
Reduced
Exposure
to
Mercury
Reduced
mercury
emissions
under
the
proposed
replacement
standards
may
generate
a
range
of
human
health
benefits.
34
A
reduction
in
mercury
emissions
is
likely
to
reduce
the
deposition
of
mercury
in
lakes,
rivers,
and
streams,
which
will
subsequently
reduce
bioaccumulation
of
methylmercury
in
fish.
Since
consumption
of
fish
containing
methylmercury
may
cause
adverse
health
effects,
reductions
in
the
bioaccumulation
of
methylmercury
in
fish
could
lead
to
human
health
benefits.

When
humans
consume
fish
containing
methylmercury,
the
ingested
methylmercury
is
FINAL
DRAFT:
March
2004
35
EPA,
Regulatory
Impact
Analysis
of
the
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.

6­
23
absorbed
into
the
blood
and
distributed
to
tissue
throughout
the
body.
In
pregnant
women,
methylmercury
can
be
passed
on
to
the
developing
fetus,
leading
to
a
number
of
neurological
disorders
in
children.
These
disorders
can
lead
to
learning
disabilities
and
developmental
problems,
which
may
lead
to
later
adverse
economic
consequences.
The
effects
of
prenatal
exposure
can
occur
at
doses
that
do
not
affect
the
mother.
In
addition,
children
who
consume
fish
containing
methylmercury
may
develop
neurological
disorders,
which
may
lead
to
other
adverse
economic
effects.
A
more
detailed
description
of
the
benefits
associated
with
reduced
mercury
exposure
is
presented
in
EPA's
regulatory
impact
analysis
of
the
non­
hazardous
boiler
MACT
standards.
35
Since
the
numerical
relationship
between
mercury
exposure
and
the
health
effects
described
above
is
highly
uncertain,
we
do
not
quantify
the
benefits
associated
with
reduced
mercury
emissions.
Instead,
we
present
a
qualitative
discussions
of
the
benefits
that
might
result
from
the
proposed
HWC
MACT
replacement
standards
for
mercury.

Text
Moved
Here:
1
Benefits
from
Reduced
Exposure
to
Chlorine
This
analysis
does
not
quantify
the
benefits
associated
with
reductions
in
chlorine
emissions.
The
replacement
standards
are
expected
to
reduce
total
chlorine
emissions,
a
combination
of
hydrogen
chloride
(
HCl)
and
chlorine
gas
(
Cl
2)
emissions,
by
approximately
1,426
to
4,806
tons
per
year
for
the
Floor
options
and
2,490
tons
per
year
for
the
Agency
Preferred
Approach
(
Exhibit
6­
53).
Hydrogen
chloride
is
corrosive
to
the
eyes,
skin,
and
mucous
membranes.
Acute
inhalation
can
cause
eye,
nose,
and
respiratory
tract
irritation
and
inflamation,
and
pulmonary
edema.
Chronic
occupational
inhalation
has
been
reported
to
cause
gastritis,
bronchitis,
and
dermatitis
in
workers.
Long
term
exposure
can
also
cause
dental
discoloration
and
erosion.
No
information
is
available
on
the
reproductive
or
developmental
effects
in
humans.
Chlorine
gas
inhalation
can
cause
bronchitis,
asthma
and
swelling
of
the
lungs,
headaches,
heart
disease,
and
meningitis.
Acute
exposure
causes
more
severe
respiratory
and
lung
effects,
and
can
result
in
fatalities.
No
information
is
available
on
the
reproductive
or
developmental
effects
in
humans.
The
proposed
HWC
MACT
replacement
standards
are
expected
to
reduce
chlorine
exposure
for
people
in
close
proximity
to
hazardous
waste
combustion
facilities,
and
are
therefore
likely
to
reduce
the
risk
of
all
of
these
health
effect
among
those
populations.
However,
without
detailed
exposure
modeling
it
is
not
possible
to
quantify
the
impact
of
the
proposed
HWC
MACT
replacement
standards.
FINAL
DRAFT:
March
2004
6­
24
End
Of
Moved
Text
Benefits
from
Reduced
Exposure
to
Lead
The
primary
effect
from
chronic
exposure
to
lead
is
to
the
central
nervous
system.
Children
are
particularly
sensitive
to
the
effects
of
lead
and
excess
exposure
can
affect
a
child's
nervous
system
and
cognitive
development.
The
proposed
HWC
MACT
replacement
standards
will
reduce
lead
emissions
by
approximately
five
to
seven
tons
per
year
for
the
Floor
and
Agency
Preferred
Approach
options,
or
less
than
0.01
pounds
per
person
(
see
below,
Exhibit
6­
5).
22
The
1999
standards
were
expected
to
reduce
lead
emissions
by
89
tons
per
year,
or
0.17
pounds
per
person,
and
were
expected
to
reduce
cumulative
lead
exposures
for
two
children
age
0­
5
to
less
than
10
µ
g/
dL.
The
benefits
associated
with
the
replacement
standards
are
expected
to
be
more
modest
per
year,
reducing
the
cumulative
lead
exposures
for
fewer
than
two
children
age
0­
5,
to
less
than
10
µ
g/
dL
annually.

The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990
monetizes
benefits
of
reduced
lead
emissions
by
associating
high
blood
lead
levels
with
reduction
in
IQ.
23
The
analysis
estimates
annual
benefits
of
about
$
49
million
associated
with
reductions
ranging
from
5,000
to
13,000
tons
of
lead,
depending
on
the
year.
24
The
reduction
of
lead
emissions
and
increase
in
IQ
does
not
display
a
linear
relationship
and
cannot
be
transferred
to
this
analysis
so
we
do
not
attempt
to
monetize
them.

Benefits
from
Reduced
Exposure
to
Mercury
The
1999
Assessment
considered
benefits
from
reduced
exposure
to
mercury.
The
1999
standards
were
expected
to
reduce
mercury
emissions
by
four
tons
per
year,
the
replacement
standards
are
expected
to
reduce
mercury
emissions
by
about
one
ton
per
year
(
Exhibit
6­
5).
This
Assessment
provides
no
quantification
of
health
benefits
associated
with
the
reduction
of
mercury
emission
resulting
from
the
replacement
standards
but
does
provide
a
discussion
of
the
benefits
estimated
in
the
1999
Assessment.
The
Assessment
noted
that
recreational
anglers
exposed
to
mercury
above
levels
of
concern
are
potentially
at
risk
for
bearing
children
with
developmental
abnormalities.
25
To
project
the
benefits
of
reduced
exposure,
the
1999
risk
assessment
estimated
the
median
cost
of
developmental
abnormalities
using
a
range
of
estimates
for
various
birth
defects
provided
in
the
Waitzman
et
al.
study
(
see
Exhibit
6­
4).
26
In
a
survey
of
the
non­
cancer
economic
literature,
this
study
was
found
to
provide
reasonable
benefit
measures.
27
The
birth
rate
of
the
general
population
indicates
that
1.67
percent
of
recreational
anglers
potentially
at
risk
will
have
children
in
a
given
year.
28
This
estimate
also
may
understate
benefits
because
it
does
not
include
avoided
pain
and
suffering.

It
is
important
to
note
that
the
approach
used
in
the
1999
Assessment
uses
upper
bound
estimates
of
the
population
at
risk
to
compute
benefits
for
mercury.
For
the
1999
Assessment
the
cost
of
developmental
abnormalities
was
applied
to
all
recreational
anglers
potentially
at
risk
(
e.
g.,
those
exposed
to
mercury
above
FINAL
DRAFT:
March
2004
6­
25
levels
of
concern
(
HQ>
1))
(
Exhibit
6­
4).
This
approach
did
not
allow
us
to
say
anything
about
the
likelihood
of
an
adverse
effect
for
the
anglers
at
risk;
we
could
only
say
that
we
could
not
rule
out
adverse
impacts
for
these
individuals.
Subsistence
fishermen,
those
individuals
who
obtain
a
significant
portion
of
their
dietary
fish
intake
from
their
own
fishing
activities,
potentially
faced
even
greater
risk
for
bearing
children
with
developmental
abnormalities
as
a
result
of
higher
mercury
exposure
levels
in
their
daily
fish
consumption.

Text
Was
Moved
From
Here:
1
***
Exhibit
6­
4***

COSTS
OF
ILLNESS
ASSOCIATED
WITH
VARIOUS
BIRTH
DEFECTSHealth
ConditionCost
per
Case
(
thousands)
Spina
bifida$
510Truncus
arteriosus$
877Transposition
of
great
arteries/
Double
Outlet
Right
Ventricle
$
463Single
ventricle$
597Tetralogy
of
Fallot
$
453Cleft
lip
or
palate$
176Tracheoesophageal
fistula$
252Atresia
of
the
small
intestine$
129Colorectal
atresia$
212Renal
agenesis$
434Urinary
tract
obstruction$
146Upper­
l
imb
reduction
$
173Lower­
limb
reduction
$
345Diaphragmatic
hernia$
434Gastroschisis$
187Omphalocele$
305Down
syndrome$
782Median$
345Source:
Waitzman
et
al.
(
1996).
Note:
Figures
are
in
2002
dollars.

Human
Health
Benefit
Results
This
Assessment
provides
quantified
human
health
benefits
from
both
cancer
and
non­
cancer
risk
reductions
related
to
PM
emissions
reductions
for
each
of
the
Floor
options
and
the
Agency
Preferred
Approach.
In
addition,
benefits
from
reduced
exposure
to
lead
and
mercury
are
discussed
and
compared
to
the
1999
standards
benefits
estimates.
Finally,
we
are
not
able
to
quantify
benefits
to
reduced
exposure
to
chlorine
but
we
discuss
potential
effects
of
hydrogen
chloride
and
chlorine
gas.

In
general,
the
1999
standards
resulted
in
greater
incremental
emissions
reductions
than
are
expected
under
the
proposed
HWC
MACT
replacement
standards
(
Exhibit
6­
5).
This
is
reasonable
given
that
the
proposed
HWC
MACT
replacement
standards
address
only
emissions
reductions
not
already
captured
by
the
2002
interim
standards.
One
notable
exception
is
that
Option
3
Floor
is
associated
with
a
greater
PM
emissions
reduction
than
the
options
considered
for
the
1999
standards.
Among
the
proposed
HWC
MACT
replacement
standards
options
Option
3
Floor
is
expected
to
result
in
the
most
human
health
benefits.
The
Agency
Preferred
Approach
is
expected
to
result
in
more
human
health
benefits
than
Option
1
Floor
and
Option
2
Floor.
FINAL
DRAFT:
March
2004
6­
26
Human
Health
Benefit
Results
This
section
discusses
quantified
human
health
benefits
from
risk
reductions
related
to
PM
emissions
reductions
for
each
of
the
Floor
options
and
the
Agency
Preferred
Approach.
Cancer
risk
reductions
associated
with
dioxin
emissions
reductions
are
also
discussed.
In
addition,
benefits
from
reduced
exposure
to
lead
and
mercury
are
discussed
and
compared
to
the
1999
standards
benefits
estimates.
Finally,
we
are
not
able
to
quantify
benefits
to
reduced
exposure
to
chlorine
but
we
discuss
potential
effects
of
hydrogen
chloride
and
chlorine
gas.

In
general,
the
1999
standards
resulted
in
greater
incremental
emissions
reductions
than
are
expected
under
the
proposed
HWC
MACT
replacement
standards
(
Exhibit
6­
3).
This
is
reasonable
given
that
the
proposed
HWC
MACT
replacement
standards
address
only
emissions
reductions
not
already
captured
by
the
2002
interim
standards.
One
notable
exception
is
that
Option
3
Floor
is
associated
with
a
greater
PM
emissions
reduction
than
the
options
considered
for
the
1999
standards.
Among
the
proposed
HWC
MACT
replacement
standards
options
Option
3
Floor
is
expected
to
result
in
the
most
human
health
benefits.
The
Agency
Preferred
Approach
is
expected
to
result
in
more
human
health
benefits
than
Option
1
Floor
and
Option
2
Floor.

Exhibit
6­
3
AVOIDED
COST
OF
CASES
ASSOCIATED
WITH
PMIllnessEstimated
Cost
Per
Incidence
(
2002
$)
Respiratory
Illness1
$
11,333Upper
respiratory
symptoms2
$
31Lower
respiratory
symptoms3
$
20Chronic
bronchitis1
$
482,256Acute
bronchitis4
$
59Cardiovascular
disease1
$
18,888Work
loss
days
(
cost
per
day)
1
$
121Minor
restricted
activity
days
(
cost
per
day)
1
$
55Sources:
1
U.
S.
Environmental
Protection
Agency,
The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990,
October
1997,
I11­
I12
2
Pope,
C.
A.,
III,
D.
W.
Dockery,
J.
D.
Spengler,
and
M.
E.
Raizenne.
1991.
Respiratory
Health
and
PM10
pollution:
a
Daily
Time
Series
Analysis.
American
Review
of
Respiratory
Diseases.
144:
668­
674.
3
Average
of
Schwartz
J.,
and
Nease
L.
M.,
2000.
Fine
Particles
are
more
strongly
associated
than
coarse
particles
with
acute
respiratory
health
effects
in
schoolchildren.
Epidemiology.
11L
6­
10.
and
Schwartz
J.,
Dockery,
D.
W.,
Nease,
L.
M.,
Wypij,
D.,
Ware,
J.
H.,
Spengler,
J.
D.,
Koutrakis,
P.,
Speizer,
F.
E.,
and
Ferris,
Jr.,
B.
G.
1994.
Acute
Effects
of
Summer
Air
Pollution
on
Respiratory
Symptom
Reporting
in
Children.
American
Journal
of
Respiratory
Critical
Care
Medicine.
150.
1234­
1242.
4
Neumann,
J.
E.,
M.
T.
Dickie,
and
R.
E.
Unsworth.
1994.
Industrial
Economics,
Incorporated.
Memorandum
to
Jim
DeMocker,
U.
S.
EPA,
Office
of
Air
and
Radiation.
Linkage
Between
Health
Effects
Estimation
and
Morbidity
Valuation
in
the
Section
812
Analysis
­­
Draft
Valuation
Document.
March
31.
Note:
Cardiovascular
disease
is
assumed
to
be
Ischemic
heart
disease.
FINAL
DRAFT:
March
2004
6­
27
Exhibit
6­
5
ANNUAL
EMISSIONS
REDUCTION
FOR
THE
PROPOSED
HWC
MACT
NNUAL
EMISSIONS
REDUCTIONS
FOR
THE
PROPOSED
HWC
MACT
REPLACEMENT
STANDARD
OPTIONS
AND
THE
1999
STANDARDSTANDARDS
Standard
Particulate
Matter
(
tons/
yr)
a
Mercury
(
tons/
yr)
LeadSVM/
LVM
(
tons/
yr)
Dioxins/
Furans
(
grams/
yr)
Chlorine
(
tons/
yr)

Agency
Preferred
Approach
2,215
(
9.7)
0.9
15216.4
4.7
2,490638
Option
1
Floor
1,829
(
4.7)
0.9
1515.8
0.4
1,426570
Option
2
Floor
1,829
(
4.7)
1.3
616.7
0.4
23,957106
Option
3
Floor
3,254
(
15.5)
1.3
720.4
0.4
4,806955
1999
Standard
2,449
(
6.2)
43.9
8997.1
28.7
5,132
Notes
a.
Values
in
parentheses
following
the
PM
emissions
reductions
estimates
represent
emissions
reductions
of
nonenumerated
metals
(
i.
e.,
antimony,
cobalt,
nickel,
selenium,
and
manganese)
attributable
to
the
PM
replacement
standards.

A
summary
of
the
quantified
benefits
for
the
Agency
Preferred
Approach
are
provided
in
Exhibit
6­
64,
and
the
summary
of
quantified
benefits
of
the
Floor
options
are
presented
in
Exhibit
6­
75.
Below,
we
describe
the
results
in
more
detail.

Benefits
from
Cancer
Risk
Reductions
Dioxin
­
Less
than
0.376
cancer
cases
per
year
are
expected
to
be
avoided
due
to
the
proposed
HWC
MACT
replacement
standards.
Based
on
the
1999
Assessment
the
majority
of
the
cancer
risk
reductions
are
linked
to
consumption
of
dioxin­
contaminated
agricultural
products
exported
beyond
the
boundaries
of
the
study
area
(
e.
g.,
within
20
km).
Less
than
one­
third
of
the
cancer
risk
reductions
occurred
in
local
populations
living
near
combustion
facilities.
Cancer
risks
for
local
populations
were
attributed
primarily
to
reductions
in
arsenic
and
chromium
emissions;
these
pollutants
accounted
for
almost
85
percent
of
total
local
cancer
incidence
in
the
baseline.

In
1999,
across
all
receptor
populations,
individual
cancer
risks
were
greatest
for
subsistence
farmers,
individuals
who
obtain
the
majority
of
their
dietary
intake
of
all
agricultural
commodities
FINAL
DRAFT:
March
2004
36
The
following
pathways
pertain
to
this
subsistence
receptor:
ingestion
of
home­
produced
beef,
pork,
chicken,
eggs,
milk,
root
vegetables,
exposed
fruit,
exposed
vegetables,
and
fish
caught
on
farm
ponds.

37
The
hypothetical
scenario
with
the
greatest
individual
cancer
risk
is
that
for
children
(
ages
0­
5
and
6­
11)
of
subsistence
farmers
resulting
from
dioxin
associated
with
commercial
incinerator
emissions.

38
Baseline
cancer
risk
for
subsistence
farmers
ages
0­
5
and
6­
11
associated
with
cement
kiln
emissions
was
2E­
05;
it
remained
2E­
05
following
the
implementation
of
the
1999
standards.
It
is
important
to
emphasize
that
because
of
the
absence
of
subsistence
farmer
population
estimates,
these
hypothetical
scenarios
represent
only
the
upper
bound,
worst
case
risks
possible.
No
conclusions
can
be
made
as
to
the
incidence
rates
associated
with
these
hypothetical
worst
case
individual
risks.

39
Other
pollutants
were
found
to
pose
negligible
individual
risks
and
so
are
not
included
in
the
results.

6­
28
from
home­
production.
36
Dioxin
and
arsenic
were
the
primary
pollutants
that
drive
the
cancer
risks
for
this
sensitive
receptor
population.
Lack
of
population
data
prevented
the
quantification
of
benefits
for
this
hypothetical
sub­
population,
but
the
reduction
in
risk
from
baseline
to
implementation
of
the
1999
standards
was
characterized.
Subsistence
farmers
exposed
to
the
highest
individual
risks
faced
getting
cancer
with
a
probability
of
five
in
100,000.37
With
the
exception
of
one
particular
scenario,
the
cancer
risk
for
all
subsistence
farmers
was
reduced
to
below
levels
of
concern
after
implementation
of
the
1999
standards.
38
The
1999
Assessment
found
that
in
addition
to
the
cancer
risk
reductions
for
the
overall
population,
the
1999
standards
would
result
in
lower
cancer
risks
for
the
children
of
especially
sensitive
sub­
populations.
Children
of
subsistence
farmers,
who
potentially
face
the
greatest
individual
risk
of
any
receptor
population,
were
expected
to
experience
a
reduction
in
individual
cancer
risk
by
a
factor
as
high
as
0.005.
Risk
reductions
may
be
associated
with
the
proposed
HWC
MACT
replacement
standards,
particularly
near
facilities
with
boilers
and
industrial
furnaces
that
are
not
subject
to
regulation
under
the
2002
interim
standards.

Benefits
from
Non­
Cancer
Risk
Reductions
Most
of
the
human
health
benefits
from
the
proposed
HWC
MACT
replacement
standards
come
from
reductions
in
particulate
matter.
Some
additional
benefits
which
are
not
quantified
in
this
analysis,
may
come
from
reductions
in
exposure
to
lead,
mercury,
chlorine,
and
dioxin
for
people
living
near
combustion
facilities.
39
Total
annual
health
benefits
are
valued
at
about
$
5$
4.12
million
forunder
the
Option
1
Floor
and
Option
2
Floor
and,***
$
4.16
million
under***
the
Agency
Preferred
Approach,
and
$
10$
8.08
million
for
Option
3
Floor.

Particulate
Matter.
The
proposed
HWC
MACT
replacement
standards
are
expected
to
avoid
less
than
one
premature
death
for
each
of
the
regulatory
options,
54
illnesses
annually
for
Option
1
Floor
and
Option
2
Floor
and
Agency
Preferred
Approach,
and
105
illnesses
annually
for
FINAL
DRAFT:
March
2004
40
U.
S.
EPA,
Environmental
Health
Threats
to
Children,
EPA
175­
F­
96­
001,
September
1996,
page
4.

6­
29
Option
3
Floor;
all
illnesses
are
associated
with
exposure
to
PM.
These
and
other
human
health
benefits
related
to
reduced
PM
exposure
are
valued
at
$
5$
2.68
million
to
$
10$
5.64
million
per
year
under
the
Agency
Preferred
Approach.
Benefits
from
reduced
exposure
to
PM
come
primarily
from
liquid
boilers.
Reductions
in
the
number
of
respiratory
diseases
account
for
over
half
of
the
morbidity
benefits.
While
separate
results
are
not
available
for
children,
it
is
safe
to
assume
that
many
of
the
respiratory
health
benefits
will
be
experienced
by
children,
who
are
thought
to
be
especially
vulnerable
to
the
effects
of
PM
exposure.
40
Mercury.
***
The
1999
standards
were
expected
to
reduce
mercury
emission
by
four
tons
per
year.
The
proposed
HWC
MACT
replacement
standards
are
expected
to
reduceMercury
emitted
from
hazardous
waste
burning
incinerators,
kilns,
boilers,
and
other
natural
and
man­
made
sources
is
carried
by
winds
through
the
air
and
eventually
is
deposited
to
water
and
land.
Recent
estimates
(
which
are
highly
uncertain)
of
annual
total
global
mercury
emissions
by
an
additional
one
ton
per
year
(
Exhibit
6­
5).
The
benefitsfrom
all
sources
(
natural
and
anthropogenic)
are
about
5,000
to
5,500
tons
per
year
(
tpy).
Of
this
total,
about
1,000
tpy
are
estimated
to
be
natural
emissions
and
about
2,000
tpy
are
estimated
to
be
contributions
through
the
natural
global
cycle
of
re­
emissions
of
mercury
associated
with
the
reduction
under
the
proposed
HWC
MACT
replacement
standards
are
not
quantified
in
this
analysis.

The
1999
Assessment
found
risk
reductions
in
recreational
anglers
potentially
exposed
to
mercury­
contaminated
fish
could
be
significant,
with
fewer
anglers
at
risk
for
having
offspring
with
developmental
abnormalities.
Baseline
mercury
risks
are
greatest
for
subsistence
fishermen,
individuals
who
obtain
a
significant
portion
of
their
dietary
fish
intake
from
self­
caught
fish.
Subsistence
fishermen
face
an
overall
non­
cancer
risk
with
a
hazard
index
as
high
as
10
for
some
individuals
that
is
driven
primarily
by
methyl
mercury.
The
1999
Assessment
found
the
baseline
risks
for
mercury
to
be
less
than
one
for
methyl
mercury
intake
from
fish
for
recreational
anglers
andpast
anthropogenic
activity.
Current
anthropogenic
emissions
account
for
the
remaining
2,000
tpy.
Point
sources
such
as
fuel
combustion;
waste
incineration;
industrial
processes;
and
metal
ore
roasting,
refining,
and
processing
are
the
largest
point
source
categories
on
a
world­
wide
basis.
Given
the
global
estimates
noted
above,
U.
S.
anthropogenic
mercury
emissions
are
estimated
to
account
for
roughly
3
percent
of
the
global
total,
and
U.
S.
hazardous
waste
burning
incinerators,
kilns,
and
boilers
are
estimated
to
account
for
about
0.0045
percent
of
total
global
emissions.

Mercury
exists
in
three
forms:
elemental
mercury,
inorganic
mercury
compounds
(
primarily
mercuric
chloride),
and
organic
mercury
compounds
(
primarily
methylmercury).
Mercury
is
usually
released
in
an
elemental
form
and
later
converted
into
methylmercury
by
bacteria.
Methylmercury
may
be
more
toxic
to
humans
than
other
forms
of
mercury,
in
part
because
it
is
more
easily
absorbed
FINAL
DRAFT:
March
2004
41
Regulatory
Impact
Analysis
of
the
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.

42
Regulatory
Impact
Analysis
of
the
Final
Industrial
Boilers
and
Process
Heaters
NESHAP:
Final
Report,
February
2004.

6­
30
in
the
body41.
If
the
deposition
is
directly
to
a
water
body,
then
the
processes
of
aqueous
fate,
transport,
and
transformation
begin.
If
deposition
is
to
land,
then
terrestrial
fate
and
transport
processes
occur
first
and
then
aqueous
fate
and
transport
processes
occur
once
the
mercury
has
cycled
into
a
water
body.
In
both
cases,
mercury
may
be
returned
to
the
atmosphere
through
resuspension.
In
water,
mercury
is
transformed
to
methylmercury
through
biological
processes
and
for
exposures
affected
by
this
rulemaking.
Methylmercury
is
considered
to
be
the
form
of
greatest
concern.
Once
mercury
has
been
transformed
into
methylmercury,
it
can
be
ingested
by
the
lower
trophic
level
organisms
where
it
can
bioaccumulate
in
fish
tissue
(
i.
e.,
concentrations
of
mercury
remain
in
the
fish's
system
for
a
long
period
of
time
and
accumulates
in
the
fish
tissue
as
predatory
fish
consume
other
species
in
the
food
chain).
Fish
and
wildlife
at
the
top
of
the
food
chain
can,
therefore,
have
mercury
concentrations
that
are
higher
than
the
lower
species,
and
they
can
have
concentrations
of
mercury
that
are
higher
than
the
concentration
found
in
the
water
body
itself.
In
addition,
when
humans
consume
fish
containing
methylmercury,
the
ingested
methymercury
is
almost
completely
absorbed
into
the
blood
and
distributed
to
all
tissues
(
including
the
brain);
it
also
readily
passes
through
the
placenta
to
the
fetus
and
fetal
brain42.

Based
on
the
findings
of
the
National
Research
Council,
EPA
has
concluded
that
benefits
of
Hg
reductions
would
be
most
apparent
at
the
human
consumption
stage,
as
consumption
of
fish
is
the
major
source
of
exposure
to
methylmercury.
At
lower
levels,
documented
Hg
exposure
effects
may
include
more
subtle,
yet
potentially
important,
neurodevelopmental
effects.
Some
subpopulations
in
the
U.
S.,
such
as:
Native
Americans,
Southeast
Asian
Americans,
and
lower
income
subsistence
fishers.
Following
the
implementation
of
the
proposed
HWC
MACT
replacement
standards,
the
hazard
index,
may
rely
on
fish
as
a
primary
source
of
nutrition
and/
or
for
cultural
practices.
Therefore,
they
consume
larger
amounts
of
fish
than
the
general
population
and
may
be
at
a
greater
risk
to
the
adverse
health
effects
from
Hg
due
to
increased
exposure.
In
pregnant
women,
methylmercury
can
be
passed
on
to
the
developing
fetus,
and
at
sufficient
exposure
may
lead
to
a
number
of
neurological
disorders
in
children.
Thus,
children
who
are
exposed
to
low
concentrations
of
methylmercury
prenatally
may
be
at
increased
risk
of
poor
performance
on
neurobehavioral
tests,
such
as
those
measuring
attention,
fine
motor
function,
language
skills,
visual­
spatial
abilities
(
like
drawing),
and
verbal
memory.
The
effects
from
prenatal
exposure
can
occur
even
at
doses
that
do
not
result
in
effects
in
the
mother.
Mercury
may
also
affect
young
children
who
consume
fish
containing
mercury.
Consumption
by
children
may
lead
to
neurological
disorders
and
developmental
FINAL
DRAFT:
March
2004
6­
31
problems,
which
may
lead
to
later
economic
consequences.

In
response
to
potential
risks
of
mercury­
containing
fish
consumption,
EPA
and
FDA
have
issued
fish
consumption
advisories
which
provide
recommended
limits
on
consumption
of
certain
fish
species
for
different
populations.
EPA
and
FDA
have
developed
a
new
joint
advisory
that
was
released
in
March
2004.
This
new
FDA­
EPA
fish
advisory
recommends
that
women
and
young
children
reduce
the
risks
of
Hg
consumption
in
their
diet
by
moderating
their
fish
consumption,
diversifying
the
types
of
fish
they
consume,
and
by
checking
any
local
advisories
that
may
exist
for
local
rivers
and
streams.
This
collaborative
FDA­
EPA
effort
will
greatly
assist
in
educating
the
most
susceptible
populations.
Additionally,
the
reductions
of
Hg
from
this
regulation
may
potentially
lead
to
fewer
fish
consumption
advisories
(
both
from
federal
or
state
agencies),
which
will
benefit
the
fishing
community.
Currently
44
states
have
issued
fish
consumption
advisories
for
non­
commercial
fish
for
some
or
all
of
their
waters
due
to
contamination
of
mercury.
The
scope
of
FCA
issued
by
states
varies
considerably,
with
some
warnings
applying
to
all
water
bodies
in
a
state
and
others
applying
only
to
individual
lakes
and
streams.
Note
that
the
absence
of
a
state
advisory
does
not
necessarily
indicate
that
there
is
no
risk
of
exposure
to
unsafe
levels
of
mercury
in
recreationally
caught
fish.
Likewise,
the
presence
of
a
state
advisory
does
not
indicate
that
there
is
a
risk
of
exposure
to
unsafe
levels
of
mercury
in
recreationally
caught
fish,
unless
people
consume
these
fish
at
levels
greater
than
those
recommended
by
the
fish
advisory.

Reductions
in
methylmercury
concentrations
in
fish
should
reduce
exposure,
subsequently
reducing
the
risks
of
mercury­
related
health
effects
in
the
general
population,
to
children,
and
to
certain
subpopulations.
Fish
consumption
advisories
(
FCA)
issued
by
the
States
may
also
help
to
reduce
exposures
to
potential
harmful
levels
of
methylmercury
in
fish.
To
the
extent
that
reductions
in
mercury
emissions
reduces
the
probability
that
a
water
body
will
have
a
FCA
issued,
there
are
a
number
of
benefits
that
will
result
from
fewer
advisories,
including
increased
fish
consumption,
increased
fishing
choices
for
recreational
fishers,
increased
producer
and
consumer
surplus
for
the
commercial
fish
market,
and
increased
welfare
for
subsistence
fishermen
may
be
further
reduced,
suggesting
that
subsistence
fishermen
will
potentially
experience
reduced
risks
of
having
children
with
developmental
abnormalities.
This
reduction
is
likely
to
be
less
than
the
reductions
described
in
the
1999
Assessment,
but
relying
on
past
analyses
may
also
underestimate
the
benefits
of
reduced
mercuryfishing
populations.

There
is
a
great
deal
of
variability
among
individuals
in
fish
consumption
rates;
however,
critical
elements
in
estimating
methylmercury
exposure,
as
mercury
health
science
is
continuing
to
evolve.
and
risk
from
fish
consumption
include
the
species
of
fish
consumed,
the
concentrations
of
methylmercury
in
the
fish,
the
quantity
of
fish
consumed,
and
how
frequently
the
fish
is
consumed.
The
typical
U.
S.
consumer
eating
a
wide
variety
of
fish
from
restaurants
and
grocery
stores
is
not
in
danger
of
consuming
harmful
levels
of
methylmercury
from
fish
and
is
not
advised
to
limit
fish
FINAL
DRAFT:
March
2004
6­
32
consumption.
Those
who
regularly
and
frequently
consume
large
amounts
of
fish,
either
marine
or
freshwater,
are
more
exposed.
Because
the
developing
fetus
may
be
the
most
sensitive
to
the
effects
from
methylmercury,
women
of
child­
bearing
age
are
regarded
as
the
population
of
greatest
interest.
The
EPA,
Food
and
Drug
Administration,
and
many
States
have
issued
fish
consumption
advisories
to
inform
this
population
of
protective
consumption
levels.

The
EPA's
1997
Mercury
Study
RTC
supports
a
plausible
link
between
anthropogenic
releases
of
Hg
from
industrial
and
combustion
sources
in
the
U.
S.
and
methylmercury
in
fish.
However,
these
fish
methylmercury
concentrations
also
result
from
existing
background
concentrations
of
Hg
(
which
may
consist
of
Hg
from
natural
sources,
as
well
as
Hg
which
has
been
re­
emitted
from
the
oceans
or
soils)
and
deposition
from
the
global
reservoir
(
which
includes
Hg
emitted
by
other
countries).
Given
the
current
scientific
understanding
of
the
environmental
fate
and
transport
of
this
element,
it
is
not
possible
to
quantify
how
much
of
the
methylmercury
in
locallycaught
fish
consumed
by
the
U.
S.
population
is
contributed
by
U.
S.
emissions
relative
to
other
sources
of
Hg
(
such
as
natural
sources
and
re­
emissions
from
the
global
pool).
As
a
result,
the
relationship
between
Hg
emission
reductions
from
Phase
I
and
Phase
II
sources
assessed
in
this
rule,
FINAL
DRAFT:
March
2004
43The
primary
form
of
lead
exposure
to
children
is
via
ingestion
of
contaminated
soil.

6­
33
and
methylmercury
concentrations
in
fish
cannot
be
calculated
in
a
quantitative
manner
with
confidence.
In
addition,
there
is
uncertainty
regarding
over
what
time
period
these
changes
would
occur.

Given
the
present
understanding
of
the
Hg
cycle,
the
flux
of
Hg
from
the
atmosphere
to
land
or
water
at
one
location
is
comprised
of
contributions
from:
the
natural
global
cycle;
the
cycle
perturbed
by
human
activities;
regional
sources;
and
local
sources.
Recent
advances
allow
for
a
general
understanding
of
the
global
Hg
cycle
and
the
impact
of
the
anthropogenic
sources.
It
is
more
difficult
to
make
accurate
generalizations
of
the
fluxes
on
a
regional
or
local
scale
due
to
the
sitespecific
nature
of
emission
and
deposition
processes.
Similarly,
it
is
difficult
to
quantify
how
the
water
deposition
of
Hg
leads
to
an
increase
in
fish
tissue
levels.
This
will
vary
based
on
the
specific
characteristics
of
the
individual
lake,
stream,
or
ocean.***

Lead.
The
proposed
HWC
MACT
replacement
standards
will
reduce
lead
emissions
by
approximately
five
to
seven
tons
per
year
for
the
Floor
and
Agency
Preferred
Approach
options
(
Exhibit
6­
5).
In
comparison,
the
1999
standards
were
expected
to
reduce
lead
emissions
by
89
tons
per
year,
and
were
expected
to
reduce
cumulative
lead
exposures
for
twoseven
children
age
0­
5
to
less
than
10
µ
g/
dL.
The
benefits
associated
with
the
proposed
HWC
MACT
replacement
standards
are
therefore
expected
to
be
modest,
reducing
the
cumulative
lead
exposures
for
less
than
twoseven
children
age
0­
5
less
than
10
µ
g/
dL
annually.
43
The
proposed
HWC
MACT
replacement
standards
will
also
result
in
reduced
lead
levels
for
children
of
sub­
populations
with
especially
high
levels
of
exposure.
Children
of
subsistence
fishermen,
commercial
beef
farmers,
and
commercial
dairy
farmers
who
face
the
greatest
levels
of
cumulative
lead
exposure
will
also
experience
comparable
reductions
in
overall
exposure
as
a
result
of
the
MACT
standards.
The
small
number
of
cases
identified
in
the
1999
Assessment
suggests
that
these
benefits
may
be
modest.

NOTE:
This
chapter
does
not
provide
quantified
or
monetary
estimates
of
the
benefits
associated
with
reduced
dioxin
emissions.
However,
estimates
of
the
benefits
associated
with
reduced
dioxin
emissions
under
the
revised
proposal
for
the
HWC
MACT
replacement
standards
are
available
in
EPA,
"
Addendum
to
the
Assessment
of
the
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Proposed
Rule,"
March
2004.
This
document
is
available
in
the
docket.
FINAL
DRAFT:
March
2004
6­
34
Human
Health
Benefits
Summary
The
measurable
annual
human
health
benefits
associated
with
emission
reductions
from
Option
1
Floor
and
Option
2
Floor
of
the
HWC
MACT
replacement
standards
include
less
than
one
avoided
premature
death,
reductions
of
1.3
hospital
admission
(
respiratory
illness
and
cardiovascular
disease
involve
hospital
admissions),
ten
cases
of
bronchitis,
5242
cases
of
respiratory
symptoms,
and
about
4,200
days
of
work
loss
or
MRAD.
For
Option
3
Floor
annual
human
health
benefits
include
less
than
one
avoided
premature
death,
reductions
of
three
hospital
admission,
19
cases
of
bronchitis,
10283
cases
of
respiratory
symptoms,
and
about
8,200
days
of
work
loss
or
MRAD.
Additional
ecological
and
human
health
benefits
are
possible
but
not
quantified
in
this
analysis
due
to
lack
of
data.
Exhibit
6­
86
summarizes
the
quanitifiable
human
health
benefits
across
combustion
sources
for
the
Agency
Preferred
Approach
and
Floor
options
1
through
3.
Overall,
the
majority
of
the
human
health
benefits
are
due
to
reductions
in
liquid
boiler
emissions.
This
is
primarily
due
to
the
fact
that
liquid
boilers
comprise
the
largest
portion
of
the
total
number
of
hazardous
waste
combustion
systems,
roughly
40
percent.

Annual
human
health
benefits
associated
with
emission
reductions
from
the
Agency
Preferred
Approach
include
less
than
one
avoided
premature
death,
reductions
of
1.3
hospital
admission,
ten
cases
of
bronchitis,
5343
cases
of
respiratory
symptoms,
and
about
54,000200
days
of
work
loss
or
MRAD.
The
Agency
Preferred
Approach
does
have
additional
health
benefits
that
are
not
quantified,
including
Clchlorine,
dioxin,
metals,
etc.
This
analysis
quantifies
only
the
human
health
benefits
associated
with
reduction
in
PM
emissions.
Thus,
the
quantified
Agency
Preferred
Approach
benefits
do
not
differ
greatly
from
Option
1
Floor
and
Option
2
Floor
and
are
less
than
Option
3
Floor
(
ExhibitExhibits
6­
4
and
6­
5).

However,
one
of
the
greatestmost
substantial
differences
between
the
HWC
MACT
Standards
Floor
options
and
the
Agency
Preferred
Approach;
is
the
increased
reduction
in
dioxin
emissions
withunder
the
Agency
Preferred
Approach;
a
six
foldn
eleven­
fold
increase
in
emissions
reduced
is
expected
under
the
Agency
PreferencePreferred
Approach
when
compared
to
the
Option
1
Floor
(
see
Exhibit
6­
3).
The
primary
concern
associated
with
dioxin
is
increased
cancer
risk.
In
the
1999
Assessment
cancer
risk
reductions
linked
to
consumption
of
dioxin­
contaminated
agricultural
products
exported
beyond
20
km
of
the
facility
accounted
for
the
majority
of
the
0.376
cancer
cases
per
year
that
were
expected
to
be
avoided
due
to
the
1999
standards.
Although
tThe
incremental
reduction
in
dioxin
emissions
from
the
Agency
Preferred
Approach
areis
expected
to
be
about
12
times
less
than6
percent
of
the
reductions
achieved
under
the
1999
standards,***
recent
studies
have
shown
a
substantial
increase
in
cancer
risk
estimates
for
exposure
to
dioxin.
(
See,
for
example,
Steenland
et
al.
(
1999),
Fingerhut
et
al.
(
1991),
Becher
et
al.
(
1996),
Flesch­
Janys
et
al.
(
1995,
1998,
1999),
Manz
et
al.
(
1991),
Ott
et
al.
(
1996),
FINAL
DRAFT:
March
2004
44
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.

45
The
hypothetical
scenario
with
the
greatest
individual
cancer
risk
is
that
for
children
(
ages
0­
5
and
6­
11)
of
subsistence
farmers
resulting
from
dioxin
associated
with
commercial
incinerator
emissions.

46
Baseline
cancer
risk
for
subsistence
farmers
ages
0­
5
and
6­
11
associated
with
cement
kiln
emissions
was
2E­
05;
it
remained
2E­
05
following
the
implementation
of
the
1999
standards.
It
is
important
to
emphasize
that
because
of
the
absence
of
subsistence
farmer
population
estimates,
these
hypothetical
scenarios
represent
only
the
upper
bound,
worst
case
risks
possible.
No
conclusions
can
be
made
as
to
the
incidence
rates
associated
with
these
6­
35
Zober
et
al.
(
1990),
Kogevinas
et
al.
(
1997),
Saracci
et
al.
(
1991),
and
Hooiveld
et
al.
(
1996,
1998)).
35
***
As
a
result,
benefits.

***
For
the
past
12
years
the
Agency
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
reductions
in
dioxin
may
be
significantly
higher
than
the
quantified
estimates
provided
here
(
e.
g.
because
the
estimates
here
are
based
on
older
studies).
dioxin
and
dioxin­
like
compounds.
This
reassessment44
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.***

Reduced
dioxin
emissions
may
result
in
additional
cancer
risk
reductions
for
the
most
sensitive
sub­
populations,:
subsistence
fishermen
and
farmers,
and
their
children.
Because
we
do
not
have
population
data
for
the
most
sensitive
sub­
populations,
we
can
only
describe
individual
risk
results
for
subsistence
farmers
and
fishermen
and
cannot
make
statements
concerning
the
total
number
of
people
that
may
experience
health
benefits
associated
with
the
Agency
Preferred
Approach.
In
1999,
across
all
receptor
populations,
individual
cancer
risks
were
greatest
for
subsistence
farmers.
These
cancer
risks
were
driven
primarily
by
dioxin
and
arsenic.
Subsistence
farmers
exposed
to
the
highest
individual
risks
faced
getting
cancer
with
a
probability
of
five
in
100,000.45
With
the
exception
of
one
particular
scenario,
the
cancer
risk
for
all
subsistence
farmers
was
reduced
to
below
levels
of
concern
after
implementation
of
the
1999
standards,
based
on
risk
data
available
at
the
time.
However
the
1999
standards
did
not
address
boilers
and
industrial
furnaces.
46
Children
of
subsistence
farmers,
who
FINAL
DRAFT:
March
2004
hypothetical
worst
case
individual
risks.

6­
36
potentially
face
the
greatest
individual
risk
of
any
receptor
population,
were
expected
to
experience
a
reduction
in
individual
cancer
risk
by
a
factor
as
high
as
0.005.
FINAL
DRAFT:
March
2004
6­
37
Exhibit
6­
64
HUMAN
HEALTH
BENEFITS
SUMMARY:
BASELINE
TO
AGENCY
PREFERRED
APPROACH
Type
of
Benefit
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$)
(
millions)

Human
Health
Benefits
Premature
deaths
avoidedavoideda
0.3
$
2$
1.81
($
0.33
­
$
3.279)

Respiratory
illness
0.9
$
0.01
Cardiovascular
disease
0.4
$
0.01
Chronic
bronchitis
5.7
$
2.7314
Acute
bronchitis
4.3
$
0
Lower
respiratory
symptoms
38.4
$
0
Upper
respiratory
symptoms
4.5
$
0
Work
loss
days
451.1
$
0.05
Minor
restricted
activity
days
37573,757.8
$
0.2115
Restricted
Activity
Days
1,237.5
NAb
Total
Annual
Monetary
Benefits
$
5.28
$
4.16
($
2.68
­
$
5.64)

Notes:

a.
***
Avoided
mortality
is
expressed
in
millions
of
1999
dollars.
Range
of
avoided
mortality
benefits
reflects
VSL
range
of
$
1.0
million
to
$
10.0
million,
consistent
with
the
range
presented
in
U.
S.
EPA
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
January
2004.***
b.
To
avoid
potential
double
counting
with
minor
restricted
activity
days,
benefits
associated
with
restricted
activity
days
are
not
monetized.
FINAL
DRAFT:
March
2004
6­
38
Exhibit
6­
75
HUMAN
HEALTH
BENEFITS
SUMMARY:
BASELINE
TO
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDS
FLOOR
OPTIONS
Option
Option
1
Floor
Option
2
Floor
Option
3
Floor
Type
of
Benefit
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$)
(
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$)
(
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$)
(
millions)

Human
Health
Benefits
Premature
deaths
avoided
0.3
$
2$
1.79
($
0.33
­
$
3.256)
0.3
$
2$
1.79
($
0.33
­
$
3.256)
0.6
$
4$
3.53
($
0.64
­
$
6.42)

Respiratory
illness
0.9
$
0.01
0.9
$
0.01
1.7
$
0.02
Cardiovascular
disease
0.4
$
0.01
0.4
$
0.01
0.8
$
0.01
Chronic
bronchitis
5.6
$
2.7112
5.6
$
2.7112
11.0
$
54.2813
Acute
bronchitis
4.3
$
0
4.3
$
0
8.4
$
0
Lower
respiratory
symptoms
38.1
$
0
38.1
$
0
74.2
$
0
Upper
respiratory
symptoms
4.4
$
0
4.4
$
0
8.6
$
0
Work
loss
days
447.3
$
0.05
447.3
$
0.05
874.7
$
0.110
Minor
restricted
activity
days
37263,726.1
$
0.2115
37263,726.1
$
0.2115
72877,287.2
$
0.4029
Restricted
activity
days
1,227.1
NAb
1,227.1
NAb
2,399.8
NAb
Total
Annual
Monetary
Benefits
$
54.2312
$
5.23$
10.25($
2.66
­

$
5.59)
$
4.12
($
2.66
­
$
5.59)
$
8.08
($
5.19
­
$
10.97)
FINA
6­
39
Notes:
a.
***
Range
of
avoided
mortality
benefits
reflects
VSL
range
of
$
1.0
million
to
$
10.0
million,
consistent
with
VSL
estimates
presented
in
U.
S.
E
Inter­
State
Air
Quality
Rule,
January
2004.***
b.
To
avoid
potential
double
counting
with
minor
restricted
activity
days,
benefits
associated
with
restricted
activity
days
are
not
monetized.
FINAL
DRAFT:
March
2004
6­
40
Exhibit
6­
86
BENEFITS
SUMMARY:
CASES
AVOIDED
BY
SOURCE,
BASELINE
TO
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDS
Agency
Recommended
Approach
Option
1
Floor
Option
2
Floor
Option
3
Floor
Type
of
Benefit
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)

LWAK/
Human
Health
Benefits
Premature
deaths
avoided
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Respiratory
illness
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Cardiovascular
disease
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Chronic
bronchitis
0.1
$
0.043
0.1
$
0.043
0.1
$
0.043
0.1
$
0.043
Acute
bronchitis
0.1
$
0.00
0.1
$
0.00
0.1
$
0.00
0.1
$
0.00
Lower
respiratory
symptoms
0.5
$
0.00
0.5
$
0.00
0.5
$
0.00
0.5
$
0.00
Upper
respiratory
symptoms
0.1
$
0.00
0.1
$
0.00
0.1
$
0.00
0.1
$
0.00
Work
loss
days
4.2
$
0.00
4.2
$
0.00
4.2
$
0.00
4.2
$
0.00
Minor
restricted
activity
35.0
$
0.00
35.0
$
0.00
35.0
$
0.00
35.0
$
0.00
Subtotal
$
0.043
$
0.043
$
0.043
$
0.043
Cement
Kilns/
Human
Health
Benefits
Premature
deaths
avoided
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Respiratory
illness
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Cardiovascular
disease
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Chronic
bronchitis
0.1
$
0.043
0.1
$
0.043
0.1
$
0.043
0.1
$
0.064
Acute
bronchitis
0.1
$
0.00
0.1
$
0.00
0.1
$
0.00
0.1
$
0.00
Lower
respiratory
symptoms
0.6
$
0.00
0.6
$
0.00
0.6
$
0.00
0.9
$
0.00
Upper
respiratory
symptoms
0.1
$
0.00
0.1
$
0.00
0.1
$
0.00
0.1
$
0.00
Work
loss
days
4.1
$
0.00
4.1
$
0.00
4.1
$
0.00
5.9
$
0.00
Minor
restricted
activity
34.4
$
0.00
34.4
$
0.00
34.4
$
0.00
48.9
$
0.00
FINAL
DRAFT:
March
2004
Exhibit
6­
86
BENEFITS
SUMMARY:
CASES
AVOIDED
BY
SOURCE,
BASELINE
TO
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDS
Agency
Recommended
Approach
Option
1
Floor
Option
2
Floor
Option
3
Floor
Type
of
Benefit
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)

6­
41
Subtotal
$
0.043
$
0.043
$
0.043
$
0.065
All
Incinerators/
Human
Health
Benefits
Premature
deaths
avoided
0.0
$
0.141
0.0
$
0.141
0.0
$
0.141
0.0
$
0.260
Respiratory
illness
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.1
$
0.00
Cardiovascular
disease
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Chronic
bronchitis
0.3
$
0.162
0.3
$
0.162
0.3
$
0.162
0.6
$
0.293
Acute
bronchitis
0.3
$
0.00
0.3
$
0.00
0.3
$
0.00
0.5
$
0.00
Lower
respiratory
symptoms
2.4
$
0.00
2.4
$
0.00
2.4
$
0.00
4.4
$
0.00
Upper
respiratory
symptoms
0.3
$
0.010
0.3
$
0.010
0.3
$
0.00
0.5
$
0.00
Work
loss
days
27.5
$
0.00
27.5
$
0.00
27.5
$
0.00
50.4
$
0.01
Minor
restricted
activity
229.1
$
0.01
229.1
$
0.01
229.1
$
0.01
419.9
$
0.02
Subtotal
$
0.3125
$
0.3125
$
0.3125
$
0.5845
FINAL
DRAFT:
March
2004
Exhibit
6­
86
BENEFITS
SUMMARY:
CASES
AVOIDED
BY
SOURCE,
BASELINE
TO
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDS
Agency
Recommended
Approach
Option
1
Floor
Option
2
Floor
Option
3
Floor
Type
of
Benefit
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)

6­
42
Coal
Boilers/
Human
Health
Benefits
Premature
deaths
avoided
0.0
$
0.02
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Respiratory
illness
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Cardiovascular
disease
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Chronic
bronchitis
0.1
$
0.02
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Acute
bronchitis
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Lower
respiratory
symptoms
0.4
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Upper
respiratory
symptoms
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Work
loss
days
4.2
$
0.00
0.4
$
0.00
0.4
$
0.00
0.4
$
0.00
Minor
restricted
activity
34.9
$
0.00
3.2
$
0.00
3.2
$
0.00
3.2
$
0.00
Subtotal
$
0.054
$
0.00
$
0.00
$
0.00
HCl
Production
Furnaces/
Human
Health
Benefits
Premature
deaths
avoided
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Respiratory
illness
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Cardiovascular
disease
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Chronic
bronchitis
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Acute
bronchitis
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Lower
respiratory
symptoms
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Upper
respiratory
symptoms
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Work
loss
days
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
FINAL
DRAFT:
March
2004
Exhibit
6­
86
BENEFITS
SUMMARY:
CASES
AVOIDED
BY
SOURCE,
BASELINE
TO
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDS
Agency
Recommended
Approach
Option
1
Floor
Option
2
Floor
Option
3
Floor
Type
of
Benefit
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
(
2002$
millions)

6­
43
Minor
restricted
activity
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
0.0
$
0.00
Subtotal
$
0.00
$
0.00
$
0.00
$
0.00
Liquid
Boilers/
Human
Health
Benefits
Premature
deaths
avoided
0.3
$
21.1068
0.3
$
21.1068
0.3
$
21.1068
0.6
$
43.1733
Respiratory
illness
0.8
$
0.01
0.8
$
0.01
0.8
$
0.01
1.6
$
0.021
Cardiovascular
disease
0.4
$
0.01
0.4
$
0.01
0.4
$
0.01
0.7
$
0.01
Chronic
bronchitis
5.1
$
21.4894
5.1
$
21.4894
5.1
$
21.4894
10.2
$
43.9083
Acute
bronchitis
3.9
$
0.00
3.9
$
0.00
3.9
$
0.00
7.7
$
0.00
Lower
respiratory
symptoms
34.5
$
0.00
34.5
$
0.00
34.5
$
0.00
68.4
$
0.00
Upper
respiratory
symptoms
4.0
$
0.00
4.0
$
0.00
4.0
$
0.00
7.9
$
0.00
Work
loss
days
411.1
$
0.05
411.1
$
0.05
411.1
$
0.05
813.9
$
0.1009
Minor
restricted
activity
3,424.3
$
0.193
3,424.3
$
0.193
3,424.3
$
0.193
6,780.1
$
0.3827
Subtotal
$
43.841
$
43.841
$
43.841
$
97.584
Total
$
54.2816
$
54.2312
$
54.2312
$
10.25$
8.08
FINAL
DRAFT:
March
2004
47
Chestnut,
L.
and
R.
Rowe.
1989.
"
Economic
Valuation
of
Changes
in
Visibility:
A
State
of
the
Science
Assessment
for
NAPAP,"
as
cited
in
National
Acid
Preparation
Assessment
Program,
Methods
for
Valuing
Acidic
Deposition
and
Air
Pollution
Effects.
NAPAP
State
of
Science
and
State
of
Technology
Report
No.
27,
Part
B.
December,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002.
..

48
Chestnut,
L.
and
R.
Dennis.
1997.
"
Economic
Benefits
of
Improvements
in
Visibility:
Acid
Rain
Provisions
of
the
1990
Clean
Air
Act
Amendments"
Journal
of
Air
and
Waste
Management
Association
47:
395­
402,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002.

49
McClelland,
G.
et
al.
1991.
Valuing
Eastern
Visibility:
A
field
test
of
the
Contingent
Valuation
Method.
Prepared
for
Office
of
Policy,
Planning
and
Evaluation,
USEPA,
June,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002.

50
U.
S.
EPA,
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010,
November
1999.

51
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003.

6­
44
VISIBILITY
BENEFITS
Particulate
matter
emissions
are
a
primary
cause
of
reduced
visibility.
Changes
in
the
level
of
ambient
PM
caused
by
the
reduction
in
emissions
from
the
proposed
HWC
MACT
replacement
standards
will
increase
the
level
of
visibility
in
some
parts
of
the
U.
S.
Visibility
directly
affects
people's
enjoyment
of
a
variety
of
daily
activities.
Individuals
value
visibility
both
in
the
places
they
live
and
work,
in
the
places
they
travel
to
for
recreational
purposes.
For
example,
Chestnut
and
Row
(
1989)
examined
WTP
for
improved
visibility
in
recreational
settings.
47
In
addition,
Chestnut
and
Dennis
(
1997)
used
data
representative
of
the
Eastern
United
States
from
McClelland
et
al.
(
19901)
to
measure
WTP
in
residential
areas.
48,49
EPAWe
hasve
incorporated
these
methods
in
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010.
We
can
estimate
the
upper
bound
and
lower
bound
benefits
associated
with
PM
emissions
reductions
with
the
proposed
HWC
MACT
replacement
standards
using
two
different
methodologies,
each
comparing
reductions
to
those
associated
with
the
Clean
Air
Act.

The
first
approach
assumes
a
linear
relationship
between
PM
reductions
and
visibility
improvements.
A
national
decrease
of
PM
emissions
of
two
percent
(
823,000
tons
annually)
is
associated
with
annual
visibility
benefits
of
roughly
$
2.75
billion
(
in
2002
dollars).
50
Assuming
a
linear
relationship,
reduced
PM
associated
with
the
proposed
HWC
MACT
replacement
standards
could
result
in
a
visibility
benefit
from
approximately
$
7$
6.12
million
for
the
Option
1
Floor
and
the
Option
2
Floor,
$
8$
7.41
million
for
the
Agency
Preferred
Approach,
and
$
12$
10.89
million
for
Option
3
Floor,
proportional
to
national
reductions.
This
comparative
approach
of
linear
extrapolation
produces
similar
results
($
6.12
million
to
$
11$
10.89
million)
when
comparing
benefits
of
emissions
reductions
of
the
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines.
51
The
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines
used
a
similar
approach
to
the
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010.
FINAL
DRAFT:
March
2004
52
Although
no
quantified
analysis
of
the
proximity
of
facilities
to
Class
1
areas
has
been
performed,
facilities
are
distributed
over
a
wide
area
including
Gulf
of
Mexico
Coast,
Great
Lakes,
and
the
Mississippi
which
include
numerous
recreation
areas.
Also,
the
WTP
of
households
for
increases
in
residential
visibility
is
higher
than
their
WTP
for
recreational
visibility.
The
EPA,
in
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010,
estimated
the
WTP
per
household
for
residential
visibility
changes
to
be
$
141,
and
$
65
to
$
137
for
recreational
visibility
changes
in
National
Parks
(
depending
on
household
and
park
location).
Thus,
visibility
benefits
are
likely.

53
U.
S.
EPA,
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010,
November
1999.

54
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003.

6­
45
This
approach
has
several
limitations.
In
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010
and
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines
EPA
valued
recreational
visibility
(
e.
g.,
realized
through
visits
to
Class
1
areas,
most
of
which
are
National
Parks).
52
In
this
Assessment
no
quantified
analysis
of
the
proximity
of
facilities
to
Class
I
areas
has
been
performed.
Another
limitation
of
this
method
is
that
it
assumes
that
visibility
improvements
are
related
to
direct
PM
emissions
only.
In
both
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010
and
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines
EPA
valued
both
direct
PM
emissions
and
gaseous
PM
precursors.
No
reductions
in
gaseous
precursors
are
quantified
for
the
proposed
HWC
MACT
replacement
standards,
thus,
this
method
may
overestimate
visibility
benefits
and
represents
the
upper
bound
of
potential
visibility
benefits.

The
second
approach
is
to
assume
a
linear
relationship
between
health
benefits
and
visibility
benefits
associated
with
reduction
in
PM
emissions.
In
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010
annual
human
health
benefits
of
roughly
$
6893
to
$
1048
billion
(
2002
dollars)
and
visibility
benefits
of
$
2
to
$
3
billion
are
estimated
for
reductions
in
PM
emissions.
53
In
the
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines
EPAthe
Agency
estimatesd
human
health
benefits
of
$
5861
to
$
1048
billion
(
2002
dollars)
and
visibility
benefits
of
$
1
to
$
2
billion
associated
with
reductions
in
PM
emissions.
54
Assuming
a
linear
relationship
between
human
health
benefits
and
visibility
benefits,
the
proposed
HWC
MACT
replacement
standards
could
result
in
a
visibility
benefit
of
approximately
$
13304,000900
for
the
Option
1
Floor
and
Option
2
Floor,
$
13405,000800
for
the
Agency
Preferred
Approach,
and
$
26105,000500
for
Option
3
Floor.
This
approach
also
has
several
limitations
as
it
still
does
not
take
into
account
Class
I
areas,
or
any
reductions
in
PM
precursors.
This
method
represents
the
lower
bound
of
visibility
benefits.

ECOLOGICAL
BENEFITS
This
section
provides
a
comparison
of
the
ecological
benefits
derived
in
the
1999
Assessment
and
the
potential
benefits
associated
with
the
proposed
HWC
MACT
replacement
standards.
Ecological
benefits
derived
in
the
1999
Assessment
were
based
on
a
screening
analysis
for
ecological
risks
that
compared
soil,
surface
water,
and
sediment
concentrations
with
eco­
toxicological
criteria
based
on
de
minimis
thresholds
for
ecological
effects.
Because
these
criteria
represented
conservative
values,
an
exceedence
of
the
eco­
toxicological
criteria
only
indicates
the
potential
for
adverse
ecological
effects
and
does
not
necessarily
indicate
ecological
damages.
For
this
reason,
the
benefits
of
avoiding
adverse
ecological
impacts
were
discussed
qualitatively.
FINAL
DRAFT:
March
2004
55
Threatened
and
endangered
species
and/
or
habitats
were
not
included
in
the
analysis.

56
A
description
of
the
eco­
toxicological
criteria
developed
can
be
found
in
"
Description
of
the
SERA
Methodology,"
Memorandum
Prepared
by
Research
Triangle
Institute,
Prepared
for
the
U.
S.
EPA,
20
February
1998.

6­
46
The
basic
approach
for
determining
whether
ecosystems
and/
or
biota
are
potentially
at
risk
consisted
of
five
steps:


First,
the
risk
assessment
identified
susceptible
ecological
receptors.
Because
combustion
facilities
are
located
across
the
country,
ecological
receptors
for
the
screening
analysis
were
chosen
to
represent
relatively
common
species
and
communities
of
wildlife.
55

Second,
the
risk
assessment
developed
eco­
toxicological
criteria
for
receptors
that
represent
acceptable
pollutant
concentrations
(
e.
g.,
at
these
levels,
there
is
a
low
potential
for
adverse
ecological
effects).
56

Third,
the
risk
assessment
estimated
baseline
and
post­
MACT
pollutant
concentrations
in
sediments,
soils,
and
surface
water
in
the
study
areas.


Fourth,
for
each
land
area
or
water
body
modeled,
the
risk
assessment
compared
the
modeled
media
concentrations
to
ecologically
protective
levels
to
estimate
eco­
toxicological
hazard
quotients.


Finally,
to
estimate
the
potential
for
adverse
ecological
effects
in
the
study
areas
the
risk
assessment
totaled
the
number
of
polar
grid
sectors
(
for
terrestrial
ecosystems)
and
water
bodies
(
from
aquatic
ecosystems)
with
hazard
quotients
exceeding
one.

To
assess
potential
ecological
benefits
from
the
risk
assessment
results,
the
number
of
sectors
or
water
bodies
potentially
at
risk
in
the
baseline
with
the
number
post­
1999
standards
were
compared.
The
reduction
in
the
number
of
sectors
or
water
bodies
potentially
at
risk
indicated
a
potential
for
avoiding
adverse
ecological
impacts.
Monetary
values
were
not
assigned
to
these
potential
benefits
because
the
surface
area
of
land
or
water
affected
corresponding
to
the
number
of
grid
sectors
or
water
bodies
potentially
at
risk
could
not
be
calculated,
and
no
clear
link
exists
between
an
exceedance
in
the
eco­
toxicological
criteria
and
a
real
benefit
measure,
such
as
increased
fish
populations,
for
which
a
benefits
transfer
approach
could
assign
monetary
values.
FINAL
DRAFT:
March
2004
57
The
low­
end
estimate
assumed
the
same
waterbodies
or
land
areas
are
affected
by
different
pollutants.
That
is,
under
the
six
square
kilometers
of
land
nearby
incinerators
that
experienced
ecological
improvements
associated
with
lead
emission
reductions
are
captured
in
the
87
square
kilometers
of
land
nearby
incinerators
associated
with
mercury
reductions.

58
Although
the
primary
pollutants
which
are
detrimental
to
vegetation
aesthetics
and
growth
are
tropospheric
ozone,
sulfur
dioxide,
and
hydrogen
fluoride,
three
pollutants
which
are
not
regulated
in
the
MACT
standards,
some
literature
exists
on
the
relationship
between
metal
deposition
and
vegetation
health.
(
Studies
cited
in
U.
S.
EPA.
Mercury
Study
Report
to
Congress
Volume
VI,
1997)
(
Several
studies
are
cited
in
this
report.),
Volume
VI:
An
Ecological
Assessment
for
Anthropogenic
Mercury
Emissions
in
the
United
States.
December
1997).

6­
47
Ecological
Benefit
Results
Ecological
benefits
were
assessed
in
the
1999
Assessment
based
on
reductions
of
approximately
100
tons
per
year
in
dioxin/
furans
and
selected
metals.
Lead
was
the
only
pollutant
of
concern
for
aquatic
ecosystems.
Mercury
appeared
to
be
of
greatest
concern
for
terrestrial
ecosystems.
Dioxin
and
lead
emission
reductions
also
provided
some
potential
benefits
for
terrestrial
ecosystems.
Under
the
1999
standards,
the
eco­
toxicological
hazard
quotient
was
reduced
to
below
the
level
of
concern
for
38
square
kilometers
of
water
surface
area.
For
terrestrial
ecosystems,
the
land
area
that
experienced
reductions
in
ecological
risk
criteria
below
levels
of
concern
ranged
from
115
square
kilometers
to
147
square
kilometers
under
the
1999
standards.
57
The
proposed
HWC
MACT
replacement
standards
will
reduce
dioxin/
furans
and
selected
metals
from
17
tons
annually
for
Option
1
Floor
and
Agency
Preferred
Approach,
Option
2
Floor
18
tons
annually,
and
22
tons
annually
for
Option
3
Floor.
In
general
the
proposed
HWC
MACT
replacement
standards
will
produce
fewer
incremental
benefits
than
those
estimated
for
the
1999
Assessment
(
and
later,
for
the
2002
Interim
standards).
However,
the
1999
Assessment
did
not
estimate
the
ecological
benefits
of
MACT
standards
for
boilers
and
industrial
furnaces.
These
systems
were
excluded
from
the
universe
in
1999
but
are
part
of
the
universe
addressed
by
the
proposed
HWC
MACT
repayment
standards.
As
a
result,
while
the
total
ecological
benefits
of
the
proposed
rule
are
likely
to
be
modest,
areas
near
facilities
with
boilers
may
enjoy
more
significant
ecological
benefits
under
the
proposed
HWC
MACT
replacement
standards
than
areas
near
facilities
that
have
already
complied
with
the
2002
Interim
standards.

It
is
important
to
note
that
these
reductions
of
ecological
risk
criteria
below
levels
of
concern
only
indicate
the
potential
for
an
ecological
improvement.
It
is
not
clear
that
a
MACT
standard
would
necessarily
provide
ecological
benefits
to
areas
around
combustion
facilities.
Also,
because
the
screening­
level
nature
of
the
ecological
risk
assessment
did
not
allow
us
to
predict
the
type
or
magnitude
of
benefits,
we
could
not
assign
monetary
values
to
these
potential
ecological
benefits.

Forest
Health
and
Aesthetics
Mercury,
lead,
and
chlorides
are
among
the
HAPs
that
can
cause
damage
to
the
health
and
visual
appearance
of
plants.
58
While
the
total
value
of
forest
health
is
difficult
to
estimate,
visible
deterioration
in
the
health
of
forests
and
plants
can
cause
a
measurable
change
in
recreation
behavior.
Several
studies
that
measure
the
change
in
outdoor
recreation
behavior
according
to
forest
FINAL
DRAFT:
March
2004
59
See,
for
example,
Brown,
T.
C.
et
al.
1989,
Scenic
Beauty
and
Recreation
Value:
Assessing
the
Relationship,
In
J.
Vining,
ed.,
Social
Science
and
Natural
Resources
Recreation
Management,
Westview
Press,
Boulder,
Colorado,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002;
this
work
studies
the
relationship
between
forest
characteristics
and
the
value
of
recreational
participation.
AFor
estimates
of
the
WTP
of
visitors
and
residents
to
avoid
forest
damage,
also
see
Peterson,
D.
G.
et
al.
1987,
Improving
Accuracy
and
Reducing
Cost
of
Environmental
Benefit
Assessments.
Draft
Report
to
the
US
EPA,
by
Energy
and
Resource
Consultants,
Boulder,
Colorado,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002;
Walsh
et
al.
1990,
Estimating
the
public
benefits
of
protecting
forest
quality,
Journal
of
Forest
Management,
30:
175­
189,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002;
and
Homes
et
al.
1992,
Economic
Valuation
of
Spruce­
Fir
Decline
in
the
Southern
Appalachian
Mountains:
A
comparison
of
Value
Elicitation
Methods.
Presented
at
the
Forestry
and
the
Environment:
Economic
Perspectives
Conference,
March
9­
1,
1992
Jasper,
Alberta,
Canada
for
estimates
of
the
WTP
of
visitors
and
residents
to
avoid
forest
damage.,
as
cited
in
Industrial
Economics,
Incorporated,
"
Initial
Review
of
Potential
Benefits
Associated
with
Hazardous
Waste
Combustion
MACT
Standards,"
Memorandum,
prepared
for
U.
S.
EPA,
30
April,
2002.

60
MacKenzie,
James
J.,
and
Mohamed
T.
El­
Ashry,
Air
Pollution's
Toll
on
Forests
and
Crops
(
New
Haven,
Yale
University
Press,
1989).

61
U.
S.
Environmental
Protection
Agency,
Addendum
to
the
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Standards:
Final
Rule,
July
23,
1999.

6­
48
health
are
available
to
place
a
value
on
aesthetic
degradation
of
forests.
59
Although
these
studies
are
available,
additional
research
is
needed
to
fully
understand
the
effects
of
these
HAPs
on
the
forest
ecosystem.
Thus,
these
benefits
are
not
quantified
in
this
analysis.

Productivity
to
Agricultural
Land
Emissions
that
are
sufficient
to
cause
structural
and
aesthetic
damage
to
vegetation
are
likely
to
affect
growth
as
well.
Little
research
has
been
done
on
the
effects
of
compounds
such
as
chlorine,
heavy
metals
(
as
air
pollutants),
and
PM
on
agricultural
productivity.
60
Even
though
the
potential
for
visible
damage
and
production
decline
from
metals
and
other
pollutants
suggests
the
proposed
HWC
MACT
replacement
standards
could
increase
agricultural
productivity
these
changes
cannot
be
quantified.

WASTE
MINIMIZATION
BENEFITS
As
discussed
in
Chapter
5,
all
commercial
combustion
facilities
that
remain
in
operation
will
experience
increased
costs
under
the
MACT
standards.
To
protect
their
profits,
combustion
facilities
will
have
an
incentive
to
pass
these
increased
costs
on
to
their
customers
in
the
form
of
higher
combustion
prices.
In
1999
we
conducted
a
waste
minimization
analysis
to
inform
the
expected
price
change
under
the
1999
(
and
later
the
2002
interim)
standards.
Based
on
the
results
of
this
analysis,
we
estimated
that
as
much
as
240,000
tons
of
waste
might
be
reallocated
to
waste
minimization
alternatives
in
response
to
higher
combustion
prices.
61
Since
the
publication
of
the
1999
Assessment,
however,
approximately
100,000
tons
of
waste
have
already
been
reallocated.
In
addition,
given
the
current
pricing
structure
of
the
hazardous
waste
combustion
market,
the
costs
of
waste
minimization
FINAL
DRAFT:
March
2004
62
In
the
long­
term,
waste
minimization
may
take
place
as
companies
upgrade
manufacturing
processes.
However,
increased
waste
management
costs
are
only
one
factor
in
these
larger
decisions.
We
therefore
do
not
anticipate
that
the
replacement
standards
would
cause
a
significant
change
in
the
quantity
of
waste
combusted.

6­
49
alternatives
in
the
short
term
generally
exceed
the
cost
of
combustion.
62
When
the
additional
costs
of
compliance
with
the
MACT
standards
are
taken
into
account,
waste
minimization
alternatives
still
tend
to
exceed
the
higher
combustion
costs.
This
inelasticity
in
the
demand
for
combustion
suggests
that
in
the
short
term
large
reductions
in
waste
quantities
are
not
likely.

While,
short­
tern
options
for
waste­
minimization
may
be
limited
it
is
likely
that
over
the
longer
term
(
e.
g.
as
production
systems
are
updated)
companies
will
continue
to
seek
alternatives
to
expensive
waste­
management
(
e.
g.,
source
reduction).
To
the
extent
that
increases
in
combustion
prices
provide
additional
incentive
to
adopt
more
efficient
processes,
the
proposed
HWC
MACT
replacement
standard
may
contribute
to
the
longer
term
process
based
waste
minimization
efforts.
However,
we
are
not
able
to
isolate
and
quantify
the
specific
impact
of
the
proposed
HWC
MACT
replacement
standards
on
source
reduction
decisions.

***
No
waste
minimization
impacts
are
captured
in
the
quantitative
analysis
of
costs
and
benefits
presented
in
this
Assessment.
A
quantitative
assessment
of
the
benefits
associated
with
waste
minimization
at
the
source
may
result
in
double­
counting
of
some
of
the
benefits
described
earlier
in
this
chapter.
For
example,
waste
minimization
may
further
reduce
emissions
of
hazardous
air
pollutants
and
therefore
have
a
positive
effect
on
public
health.
Emissions
reductions
beyond
those
necessary
for
compliance
with
the
replacement
standards
are
also
not
addressed
in
this
benefits
assessment.
In
addition,
waste
minimization
is
likely
to
result
in
specific
types
of
benefits
not
captured
in
this
Assessment.
For
example,
waste
generators
that
engage
in
waste
minimization
will
experience
a
reduction
in
their
waste
handling
costs
and
could
also
reduce
the
risk
related
to
waste
spills
and
waste
management.
The
cost
of
implementing
waste
minimization
technology
has
not
been
assessed
in
this
analysis.
These
costs
are
likely
to
at
least
partially
offset
corresponding
benefits.
***
FINAL
DRAFT:
March
2004
6­
50
Exhibit
6­
97
BENEFITS
SUMMARY:
BASELINE
TO
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDS
(
2002
Dollars
in
Millions)

Option
Agency
Preferred
Approach
Option
1
Floor
Option
2
Floor
Option
3
Floor
Type
of
Benefit
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
Reduction
in
Number
of
Cases
per
Year
Annual
Undiscounted
Value
Human
Health
Benefits
Premature
deaths
avoidedavoideda
0.3
$
2$
1.81
($
0.33
­

$
3.279)
0.3
$
2$
1.79
($
0.33
­

$
3.256)
0.3
$
2$
1.79
($
0.33
­

$
3.256)
0.6
$
4$
3.53
($
0.64
­$
6.42)

Respiratory
illness
0.9
$
0.01
0.9
$
0.01
0.9
$
0.01
1.7
$
0.02
Cardiovascular
disease
0.4
$
0.01
0.4
$
0.01
0.4
$
0.01
0.8
$
0.01
Chronic
bronchitis
5.7
$
2.7314
5.6
$
2.7112
5.6
$
2.7112
11.0
$
54.2813
Acute
bronchitis
4.3
$
0
4.3
$
0
4.3
$
0
8.4
$
0
Lower
respiratory
symptoms
38.4
$
0
38.1
$
0
38.1
$
0
74.2
$
0
Upper
respiratory
symptoms
4.5
$
0
4.4
$
0
4.4
$
0
8.6
$
0
Work
loss
days
451.1
$
0.05
447.3
$
0.05
447.3
$
0.05
874.7
$
0.110
Minor
restricted
activity
days
37573,757.8
$
0.2115
37263,726.

1
$
0.2115
37263,726.

1
$
0.2115
72877,287.2
$
0.4029
Annual
Monetary
Health
Benefits
$
54.2816
$
5.23$
5.23$
1
0.25($
2.68
­

$
5.64)
$
4.12
($
2.66
­$
5.59)
$
4.12
($
2.66
­$
5.59)
$
8.08
($
5.19­$
10.97)

Visibility
Annual
Monetary
Visibility
Benefits
$
0.131
to
$
87.0341
$
0.130
to
$
6.6312
$
0.130
to
$
6.6312
$
0.261
to
$
110.809
FINAL
DRAFT:
March
2004
6­
51
Total
Annual
Monetary
Benefits
$
52.4179
to
$
13.3105
$
52.3676
to
$
11.8771
$
52.3676
to
$
11.87$
10.51
to$
22.0571
Notes:
a.
***
Avoided
mortality
is
expressed
in
millions
of
1999
dollars.
Range
of
avoided
mortality
benefits
reflects
VSL
range
of
$
1.0
million
to
$
10.0
range
presented
in
U.
S.
EPA
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
January
2004.***
FINAL
DRAFT:
March
2004
6­
52
CONCLUSIONS
Overall,
the
Agency
Preferred
Approach
is
expected
to
result
annually
in
approximately***
$
5$
4.16
million***
in
human
health
benefits
beyond
the
baseline.
In
addition,
the
proposed
Agency
Preferred
Approach
is
expected
to
result
in
$
1005,000800
to
$
8$
7.41
million
in
visibility
benefits
beyond
the
baseline
(
see
Exhibit
6­
87
for
a
summary
of
the
quantified
annual
monetary
benefits
of
the
proposed
HWC
MACT
replacement
standards).
In
particular,
the
Agency
Preferred
Approach
is
expected
to
result
in:


Reductions
in
premature
deaths.
Risk
reductions
associated
with
the
Agency
Preferred
Approach
is
expected
to
result
in
less
than
one
fewer
premature
deaths
annually.
Particulate
matter
accounts
for
most
of
the
human
health
benefits.


Cancer
risk
reductions.
The
Agency
Preferred
Approach
is
expected
to
avoid
less
than
0.376
cancer
deaths
annually
when
compared
to
the
1999
standards.
The
value
of
this
avoided
cancer
case
is
not
quantified
in
this
Assessment.


Reductions
in
diseases
associated
with
particulate
matter
exposure.
Hospital
admissions
for
diseases
associated
with
particulate
matter
are
expected
to
be
reduced
by
approximately
1.3
cases
per
year.
Respiratory
illnesses
account
for
almost
70
percent
of
the
hospital
admissions.
In
addition,
approximately
53
occurrences
of
acute
respiratory
conditions
will
be
avoided
annually
due
to
the
Agency
Preferred
Approach.


Reduced
risk
for
***
subsistence
fishermen
associated
with
mercury.
The
hazard
indexmercury.
Reductions
in
methylmercury
concentrations
in
fish
should
reduce
exposure,
subsequently
reducing
the
risks
of
mercury­
related
health
effects
in
the
general
population,
to
children,
and
to
certain
subpopulations.
Fish
consumption
advisories
(
FCA)
issued
by
the
States
may
also
help
to
reduce
exposures
to
potential
harmful
levels
of
methylmercury
in
fish.

To
the
extent
that
reductions
in
mercury
emissions
reduces
the
probability
that
a
water
body
will
have
a
FCA
issued,
there
are
a
number
of
benefits
that
will
result
from
fewer
advisories,
including
increased
fish
consumption,

increased
fishing
choices
for
recreational
fishers,
increased
producer
and
consumer
surplus
for
the
commercial
fish
market,
and
increased
welfare
for
subsistence
fishermen
may
be
reduced,
suggesting
that
subsistence
fishermen
will
potentially
experience
reduced
risks
of
having
children
with
developmental
abnormalities,
but
this
reduction
is
FINAL
DRAFT:
March
2004
6­
53
likely
to
be
small
based
on
the
1999
Assessment.
fishing
populations.***
FINAL
DRAFT:
March
2004
6­
54

Reduced
lead
exposure
in
children.
The
Agency
Preferred
Approach
is
expected
to
reduce
lead
exposure
in
children,
including
children
of
subpopulations
with
especially
high
levels
of
exposure
(
children
of
subsistence
fishermen,
commercial
beef
farmers,
and
commercial
dairy
farmers).
However,
the
small
number
of
cases
identified
in
the
1999
Assessment
suggests
that
these
benefits
may
be
modest.


Potential
improvement
in
visibility.
An
upper
bound
estimate
of
visibility
benefits,
assuming
a
linear
relationship
with
WTP
for
improved
visibility
and
particulate
matter
concentration
visibility
improvements
associated
with
particulate
matter,
could
result
in
benefits
of
$
8$
7.41
million
annually
for
a
30
percent
change
in
particulate
matter
concentration
from
the
baseline.
A
lower
bound
estimate
of
visibility
benefits,
assuming
a
linear
relationship
between
human
health
benefits
and
visibility
benefits
reductions
in
PM
emissions,
could
result
in
$
1005,000800
in
visibility
benefits.


Potential
ecological
improvements.
The
Agency
Preferred
Approach
is
likely
to
result
in
some
ecological
benefits.
In
comparison
with
the
1999
standards
the
Agency
Preferred
Approach
is
likely
to
produce
less
ecological
benefits
than
estimated
in
the
1999
Assessment.
That
is,
less
than
38
square
kilometers
of
water,
and
147
square
kilometers
of
terrestrial
areas
may
experience
a
decrease
in
potential
risks
to
ecosystems.


Increased
forest
health
and
aesthetics.
Mercury,
lead,
and
chlorides
are
among
the
HAPs
that
can
cause
damage
to
the
health
and
visual
appearance
of
plants.
While
the
total
value
of
forest
health
is
difficult
to
estimate,
visible
deterioration
in
the
health
of
forests
and
plants
can
cause
a
measurable
change
in
recreation
behavior.
These
benefits
are
not
quantified
in
this
analysis.


Increased
productivity
to
agricultural
land.
Emissions
that
are
sufficient
to
cause
structural
and
aesthetic
damage
to
vegetation
are
likely
to
affect
growth
as
well.
The
Agency
Preferred
Approach
could
increase
agricultural
productivity
but
are
not
quantified
in
this
analysis.


Waste
minimization
benefits.
The
Agency
Preferred
Approach
is
likely
to
produce
a
small
reduction,
if
any,
in
short­
term
generation
waste
combusted
because
the
demand
for
combustion
is
relatively
inelastic.
However,
impacts
fo
this
rule
on
long­
term
process
decisions
are
unknown.
FINAL
DRAFT:
March
2004
6­
55
It
is
important
to
emphasize
that
the
monetized
portion
of
the
benefits
represent
only
a
portion
of
the
benefits
associated
with
this
rule.
Specifically
ecological
benefits,
chlorine,
dioxin,
mercury,
lead,
etc.
health
benefits
are
not
quantified
or
monetized.
In
some
locations
these
benefits
may
be
significant.
In
addition,
specific
sub­
populations
near
combustion
facilities,
including
children
and
minority
populations,
may
be
disproportionately
affected
by
environmental
risks
and
may
therefore
enjoy
more
significant
benefits.
Chapter
7
provides
a
more
detail
discussion
of
the
environmental
justice
and
children's
health
implications
of
this
proposed
rule.
