­
1­
Hazardous
Waste
Combustor
MACT
Response
to
Issues
Raised
by
OMB
March
3,
2004
Issue
Page
#

1.
Beyond­
the­
Floor
Justification
2
2.
Inclusion
of
Data
From
Sources
That
8
May
Have
Upgraded
to
Comply
With
Interim
Standards
3.
Total
Chlorine
Standard
­
Method
26
Bias
Issue
9
4.
Stakeholder's
Objection
to
Thermal
Emission
Limits
10
5.
Stakeholder's
Request
for
an
Alternative
to
the
13
Particulate
Matter
Standard
6.
Stakeholders
Objection
to
Requiring
Site
13
Specific
Risk
Assessments
7.
Miscellaneous
Issues
(
Inclusion
of
Waste
14
Minimization
in
the
Benefits
Discussion,
Discounting
Benefits,
Corrected
RIA
Background
Document
Language,
SO
2
benefits)
­
2­

Increm
ental
Total
Annualized
Cost
Cost­
Effectiveness
Incremental
Annualilzed
Capital
Cost
#
Sources
Incurring
BTF
Cost
Total
Annualilzed
Cost,
from
Baseline
Coal­
Fired
Boilers
(
Solid
Fuel
Boilers)
Non­
discounted:
$
74,000
3%
discount
rate:
$
71,500
3
7%
discount
rate:
$
68,400
3
TCl
440
ppm
v
110
ppm
v
790
tpy
$
3.7
M
$
4,700/
ton
$
0.18
M
6/
12
$
4.2
M
$
2.60
$
27­$
280
m
illion
in
1999
dollars4
Lightweight
Aggregate
K
ilins
TCl
600
ppm
v
150
ppm
v
280
tpy
$
1.9
M
$
6,800/
ton
$
0.10
M
7/
7
$
1.9
M
$
1.75
Benefits
no
t
m
onetized,
bu
t
include
a
reduction
in
acidification
of
acid­
sensitive
surface
waters
Non­
discounted:
$
154,000
­
$
912,000
3%
discount
rate:
$
56,000
­
$
495,000
5
7%
discount
rate:
$
15,000
­
$
222,000
5
Liquid
Fuel
Boilers
Non­
discounted:
$
5,000
­
$
29,000
3%
discount
rate:
$
1,800
­
$
16,000
5
7%
discount
rate:
$
500
­
$
7,000
5
HCl
Production
Furnaces
Non­
discounted:
$
180,000
­
$
1,100,000
3%
discount
rate:
$
67,000
­
$
594,000
5
7%
discount
rate:
$
18,000
­
$
267,000
5
Market­
Adjusted
Costs
(
Millions)
2
Engineering
Costs
Floor
Level
BTF
Stnd
Emission
Reductions
Annualized
Incremental
Benefits
Source/
HAP
Summary
o
f
Costs,
Benefits,
and
Cost­
Effectiveness
for
P
roposed
Beyond­
the­
Floor
(
BTF)
S
tandards
for
Existing
Sources
2
To
provide
consistent
cost
estimates
for
each
source
category,
we
assume
that
the
proportional
distribution
of
m
arket­
adjusted
costs
across
pollutants
is
consistent
with
the
proportional
distribution
of
engineering
costs
across
pollu
tants.
S
ince
specific
facilities
m
ay
send
waste
off
s
ite
instead
of
upgrading
to
comply
with
the
standards,
this
assumption
m
ay
not
reflect
the
actual
distribution
of
m
arketadjusted
costs
across
po
llutants.

1
Tons
of
m
etal
HAP
Dioxin/
Furan
6.8
ng
TEQ/
dscm
0.40
ng
TEQ/
dscm
2.3
gpy
$
1.9
M
3
Our
analysis
of
PM
m
or
tality
be
nefits
assumes
that
25
pe
rcent
of
prem
ature
m
ortalities
associated
w
ith
PM
exposure
occur
during
the
first
year,
25
pe
rcent
occur
during
the
second
year,
and
16.7
percent
occur
in
each
of
the
three
subsequent
years
after
exposure.
W
e
assume
no
time
lag
is
associated
w
ith
PM
m
orbidity
effects.
This
m
ethodology
is
consistent
w
ith
EPA's
an
alysis
of
the
proposed
C
lear
Skies
Act
of
2003.
EPA,
Technical
Addendum:
M
ethodologies
for
the
Benefit
Analysis
of
the
C
lear
S
kies
Act
of
2003
,
S
eptember
2003.

4
This
range
reflects
our
lower
bound
estimate
an
d
our
average
estimate
based
on
results
presented
in
U
.
S.
EPA,
2
003
Technical
A
ddendum:
Methodologies
for
the
Benefit
A
nalysis
of
the
Clear
Skies
Act
of
2003
,
Septem
ber
2003
and
U.
S.
EPA,
Benefits
o
f
the
P
roposed
Inter­
State
Air
Q
uality
Rule
,
January
2004.
A
ssuming
a
discount
rate
of
3
percent,
we
estimate
that
annual
benefits
range
from
$
29
million
to
$
349
m
illion.
A
t
a
discount
rate
of
7
percent,
annual
benefits
fall
in
the
range
of
$
27
m
illion
to
$
340
m
illion.

5
T
he
range
of
benefits
associated
with
reduced
dioxin/
furan
emissions
reflects
a
latency
pe
riod
ranging
from
21
to
34
years
(
see:
J.
Neum
ann
and
B.
Unsworth,
Addenda
to
M
ortality
Valuation
Methodology,
internal
memorandum
submitted
to
Jim
DeMocker,
September
28,
1993).
In
add
ition,
the
low
end
of
the
ranges
presented
reflects
a
cancer
risk
factor
of
1.5
x
10
5
[
mg/
kg/
day]­
1.
The
upper
end
of
each
range
represents
a
cancer
risk
factor
of
9
.0
x
105
[
mg/
kg/
day]­
1.
This
range
reflects
EPA's
effort
currently
und
erway
to
refine
estimates
of
dioxin
cancer
risk
factors.

6
Our
econom
ic
m
odel
indicates
that
the
single
boiler
system
that
would
incur
increm
ental
en
gineering
costs
un
der
the
A
gency
Preferred
A
pproach
is
predicted
to
close
in
both
the
Floor
and
BTF
m
arket
adjusted
scenarios;
it
therefore
incurs
no
incremental
m
arket
adjusted
costs.
$
830,000/
gram
$
0.39
M
10/
17
$
1.90
$
1.9
M
Dioxin/
Furan
3.0
ng
TEQ/
dscm
0.40
ng
TEQ/
dscm
0.06
gpy
$
0.08
M
$
1,300,000/
gram
$
0.008
M
1/
104
$
0.13
M
0.00
6
Dioxin/
Furan
6.1
ng
TEQ/
dscm
0.40
ng
TEQ/
dscm
1.9
gpy
$
1.8
M
$
950,000/
gram
$
0.44
M
7/
7
$
1.3
M
$
87,000/
ton
$
0.85
M
11/
12
$
1.5
M
$
0.88
$
1.8
M
$
1.68
PM
0.060
gr/
dscf
0.030
gr/
dscf
15
tpy
1
1.
Beyond­
the­
Floor
Justification.
(
Issue
raised
by
ACC
and
CRWI)

The
table
below
provides
a
summary
of
the
costs
and
benefits
for
each
of
the
six
proposed
beyond­
the­
foor
standards.
Following
this
table,
we
provide
our
rationale
as
to
why
these
beyond­
the­
floor
standards
are
appropriate.
­
3­
Beyond­
the­
Floor
Justification
(
continued)

A.
Coal­
Fired
(
Solid
Fuel)
Boilers
1.
PM:

a.
The
BTF
Standard
Is
Cost­
Effective
(
CE)
at
$
87,000/
ton
HAP
Metal.

Consideration
of
Agency
CE
Precedence:

EPA
determined
that
$
2,500/
ton
is
CE
for
metal
HAP,
HCl,
and
organic
HAP
combined.
Pulp
and
Paper
Combustion
MACT
NPRM
(
Dec.
8,
1007).

EPA
determined
that
$
22,000/
ton
is
not
CE
for
metal
HAP,
HCl,
and
HF
combined.
Clay
Products
MACT
NPRM,
67
FR@
47910
(
July
22,
2002).
Rationale
included
the
fact
that
the
cost
for
BTF
stnds
would
be
substantially
higher
than
the
Floor­­$
101
million
vs
$
39
million.
In
addition,
BTF
costs
to
small
businesses
would
be
substantially
higher­­$
39
million
vs
$
7
million.

EPA
determined
that
$
250,000/
ton
is
not
CE
for
lead
and
manganese
b/
c
sources
would
be
required
to
remove
existing
FFs
and
replace
them
with
more
efficient
FFs
to
achieve
a
very
low
standard­­
0.001
gr/
dscf.
Iron
and
Steel
Foundry
MACT
NPRM,
67
FR@
78287
(
Dec.
23,
2002).

BTF
PM
Standard
for
Coal
Boilers
Burning
Hazardous
Waste
Is
Cost­
Effective
at
$
87,000/
ton
HAP
Metal
b/
c:

Incremental
total
annualized
cost
would
be
only
$
1.3
million
to
improve
the
design,
operation,
and
maintenance
of
existing
ESPs
and
FFs
to
remove
15
tons/
yr
of
metal
HAP
several
of
which
are
highly
toxic
or
carcinogenic.

The
BTF
standard
would
not
pose
a
significant
economic
impact
on
a
substantial
number
of
potentially
affected
small
entities.

b.
The
BTF
Standard
Is
Comparable
to
the
Floor
Standard
for
Industrial
Boilers.

The
Floor
is
0.060
gr/
dscf.
The
BTF
standard
of
0.030
gr/
dscf
would
be
comparable
to
the
Floor
standard
of
0.034
gr/
dscf
for
industrial
coal­
fired
boilers
that
do
not
burn
hazardous
waste.

No
reason
for
MACT
control
to
be
different
for
coal
boilers
that
burn
hazardous
waste
b/
c
hazardous
waste
does
not
affect
PM
emissions
significantly.

c.
Monetized
Health
and
Environmental
Benefits
Are
Significant:
$
74,000/
yr
nondiscounted,
$
72,000
discounted
at
3%,
and
$
68,000
discounted
at
7%.
­
4­
2.
TCl
a.
The
BTF
Standard
Is
Cost­
Effective
(
CE)
at
$
4,700/
ton
Consideration
of
Agency
CE
Precedence:

EPA
determined
that
$
1,100/
ton
is
CE
for
HCl.
Hazardous
Waste
Combustor
MACT
FRM,
68
FR@
52900
(
Sept.
30,
1999).

EPA
determined
that
$
45,000/
ton
is
not
CE
for
HCl.
Industrial
Boiler
MACT
NPRM,
68
FR@
1677
(
Jan.
13,
2003).

BTF
TCl
Standard
for
Coal
Boilers
Burning
Hazardous
Waste
Is
Cost­
Effective
at
$
4,700/
ton
HCl
b/
c:

Incremental
total
annualized
cost
would
be
only
$
3.7
million
to
install
dry
scrubbing
(
i.
e.,
lime
injection)
to
remove
790
tons/
yr
of
TCl.

CE
value
of
$
4,700
is
within
the
range
of
values
that
the
Agency
could
reasonably
determine
is
CE.

b.
Monetized
Health
Benefits
from
Collateral
Reductions
in
SO
2
Emissions
Would
Be
Substantial:
$
27­
280
million/
yr
(
1999
dollars)

B.
Lightweight
Aggregate
Kilns
1.
TCl
a.
The
BTF
Standard
Is
Cost­
Effective
(
CE)
at
$
6,800/
ton
Consideration
of
Agency
CE
Precedence:
See
discussion
above.

BTF
TCl
Standard
Is
CE
at
$
6,800/
ton
HCl
b/
c:

Incremental
total
annualized
cost
would
be
only
$
1.9
million
to
install
dry
scrubbing
to
remove
280
tons/
yr
of
TCl.

CE
value
of
$
6,800
is
within
the
range
of
values
that
the
Agency
could
reasonably
determine
is
CE.

b.
HCl
Reductions
from
the
Floor
(
600
ppmv)
Will
Reduce
Acidification
of
Acid­
Sensitive
Surface
Waters.

2.
D/
F
­
5­
a.
The
BTF
Standard
Is
Cost­
Effective
at
$
0.95
million/
gram
TEQ.

Consideration
of
Agency
CE
Precedence:

EPA
determined
that
a
CE
of
$
25,000/
gram
is
CE
to
control
D/
F
to
an
emission
level
of
0.4
ng
TEQ/
dscm
for
lightweight
aggregate
kilns
that
burn
hazardous
waste.
Hazardous
Waste
Combustor
MACT
FRM,
64
FR@
52892
(
Sept.
30,
1999).

EPA
determined
that
a
CE
of
$
370,000/
gram
is
CE
to
control
D/
F
to
an
emission
level
of
0.4
ng
TEQ/
dscm
for
hazardous
waste
incinerators
equipped
with
heat
recovery
boilers.
Hazardous
Waste
Combustor
MACT
FRM,
64
FR@
53861.

EPA
determined
that
CE
values
of
$
530,000/
gram,
$
660,000/
gram,
and
$
827,000/
gram
were
not
CE
to
control
D/
F
to
an
emission
level
of
0.2
ng
TEQ/
dscm
for
hazardous
waste
burning
lightweight
aggregate
kilns,
cement
kilns,
and
incinerators.
Hazardous
Waste
Combustor
MACT
FRM,
64
FR@
52892,
52876,
and
52961.

BTF
D/
F
Standard
for
Lightweight
Aggregate
Kilns
Burning
Hazardous
Waste
Is
Cost­
Effective
at
$
0.95
million/
gram
TEQ
b/
c:

D/
F
are
highly
toxic.
EPA
has
accepted
relatively
high
CE
values
for
HAP
that
are
particularly
problematic.

EPA
determined
that
$
18,000,000
is
CE
for
mercury.
Chlorine
Production
MACT
NPRM,
67
FR@
44682­
3
(
July
3,
2002).

The
incremental
total
annualized
cost
would
be
only
$
1.8
million
to
install
activated
carbon
injection
to
achieve
a
BTF
standard
of
0.4
ng
TEQ/
dscm
to
remove
1.9
grams
TEQ/
yr.

The
lower
CE
values
that
EPA
determined
were
not
CE
were
to
establish
a
BTF
standard­­
0.2
ng
TEQ/
dscm­­
that
is
generally
considered
to
be
below
the
level
of
health
risk
concern.

This
BTF
standard
is
consistent
with
the
BTF
standard
EPA
promulgated
for
hazardous
waste
incinerators
with
heat
recovery
boilers­­
use
of
activated
carbon
injection
to
control
D/
F
to
0.4
ng
TEQ/
dscm.
64
FR@
53861.

D/
F
emission
levels
at
the
Floor
 
6.1
ng
TEQ/
dscm­­
are
very
high
and
may
expose
individuals
to
substantial
cancer
risk
Without
a
BTF
standard,
RCRA
permit
writers
would
likely
require
site­
specific
risk
assessments
and
associated
RCRA
permit
conditions
to
control
D/
F.
Not
only
is
this
inconsistent
w/
our
preference
to
minimize
risk
assessments,
it
also
would
result
in
emission
limits
being
retained
in
the
RCRA
permit,
thus
complicating
implementation,
compliance,
and
enforcement.
1
The
D/
F
potency
slope
factor
used
to
support
the
lower
benefit
values
is
not
supported
by
the
current
science.
Rather,
the
upper
bound
on
the
lifetime
risk
of
all
cancers
combined
of
1E­
03
risk/(
pgTEQ/
kg/
day)
is
the
value
recommended
in
the
draft
dioxin
reassessment
as
being
an
estimate
representative
for
the
general
population
(
September,
2000
SAB
Review
Draft).
The
reported
range
is
actually
1E­
03
to
9E­
03,
so
individuals
could
have
a
lifetime
excess
cancer
risk
of
considerably
more
than
1E­
03
risk/(
pgTEQ/
kg/
day).
By
comparison,
the
1985
slope
factor
is
1.56E­
04
risk/(
pgTEQ/
kg/
day).
In
addition,
D/
F
cause
many
effects
other
than
cancer.
Current
background
exposures
exceed
any
RfC/
RfD
that
could
be
estimated
from
the
available
data,
which
are
substantial.
These
include
developmental
effects,
reproductive
effects,
and
metabolic
effects
(
e.
g.,
increased
incidence
of
diabetes).
Therefore,
any
benefits
based
solely
on
avoided
cancer
incidence
will
underestimate
the
overall
benefits
of
reducing
D/
F
emissions,
particularly
since
the
non­
cancer
benefits
would
not
be
affected
by
the
latency
period
typically
associated
with
many
forms
of
cancer.

­
6­
b.
Monetized
Health
Benefits
Are
Significant:
$
150,000
­
$
910,000
nondiscounted,
$
56,000
­
$
500,000
discounted
at
3%,
and
$
15,000
­
$
220,000
discounted
at
7%.
1
C.
Liquid
Fuel
Boilers:
D/
F
1.
The
BTF
Standard
Is
Cost­
Effective
at
$
1.3
million/
gram
TEQ.

Consideration
of
Agency
CE
Precedence:
See
discussion
above.

BTF
D/
F
Standard
for
Liquid
Fuel
Boilers
Burning
Hazardous
Waste
Is
Cost­
Effective
at
$
1.3
million/
gram
TEQ
b/
c:

As
discussed
above,
D/
F
are
highly
toxic.
EPA
has
accepted
relatively
high
CE
values
for
HAP
that
are
particularly
problematic.

The
incremental
total
annualized
cost
would
be
only
$
0.08
million
for
one
source
to
install
activated
carbon
injection
to
achieve
a
BTF
standard
of
0.4
ng
TEQ/
dscm.

As
discussed
above,
the
lower
CE
values
that
EPA
determined
were
not
CE
were
to
establish
a
BTF
standard­­
0.2
ng
TEQ/
dscm­­
that
is
generally
considered
to
be
below
the
level
of
health
risk
concern.

This
BTF
standard
is
consistent
with
the
BTF
standard
EPA
promulgated
for
hazardous
waste
incinerators
with
heat
recovery
boilers­­
use
of
activated
carbon
injection
to
control
D/
F
to
0.4
ng
TEQ/
dscm.

D/
F
emission
levels
at
the
Floor
 
3.0
ng
TEQ/
dscm­­
are
very
high
and
may
expose
individuals
to
substantial
cancer
risk.
See
discussion
above
regarding
implications
on
RCRA
permitting.
­
7­
2.
Monetized
Health
Benefits
Are
Significant:
$
5,000
­
$
29,000
nondiscounted,
$
1,800
­
$
16,000
discounted
at
3%,
and
$
500
­
$
7,000
discounted
at
7%.

D.
HCl
Production
Furnaces:
D/
F
1.
The
BTF
Standard
Is
Cost­
Effective
at
$
0.83
million/
gram
TEQ.

Consideration
of
Agency
CE
Precedence:
See
discussion
above.

BTF
D/
F
Standard
for
HCl
Production
Furnaces
Burning
Hazardous
Waste
Is
Cost­
Effective
at
$
0.83
million/
gram
TEQ
b/
c:

As
discussed
above,
D/
F
are
highly
toxic.
EPA
has
accepted
relatively
high
CE
values
for
HAP
that
are
particularly
problematic.

The
incremental
total
annualized
cost
would
be
only
$
1.9
million
to
install
activated
carbon
injection
to
achieve
the
BTF
standard
of
0.4
ng
TEQ/
dscm
and
remove
2.3
grams
TEQ/
yr.

As
discussed
above,
the
lower
CE
values
that
EPA
determined
were
not
CE
were
to
establish
a
BTF
standard­­
0.2
ng
TEQ/
dscm­­
that
is
generally
considered
to
be
below
the
level
of
health
risk
concern.

This
BTF
standard
is
consistent
with
the
BTF
standard
EPA
promulgated
for
hazardous
waste
incinerators
with
heat
recovery
boilers­­
use
of
activated
carbon
injection
to
control
D/
F
to
0.4
ng
TEQ/
dscm.

D/
F
emission
levels
at
the
Floor
 
6.8
ng
TEQ/
dscm­­
are
very
high
and
may
expose
individuals
to
substantial
cancer
risk.
See
discussion
above
regarding
implications
on
RCRA
permitting.

2.
Monetized
Health
Benefits
Are
Substantial:
$
180,000
­
$
1,100,000
nondiscounted,
$
67,000
­
$
594,000
discounted
at
3%,
and
$
18,000
­
$
270,000
discounted
at
7%.
­
8­
2.
Inclusion
of
Data
From
Sources
That
May
Have
Upgraded
to
Comply
With
Interim
Standards.
(
Issue
raised
by
ACC
and
CRWI)

The
table
below
summarizes
the
estimated
impacts
to
the
MACT
floors
of
removing
data
from
sources
that
may
have
upgraded
to
comply
with
the
1999
standards.
EPA
and
stakeholders
identified
six
sources
that
may
have
upgraded.
Four
cement
kiln
standards
and
two
incinerator
standards
would
be
impacted.
The
remainder
of
the
standards
would
remain
unchanged.

Category
Pollutant
EPA's
Proposed
Floor
Level
Projected
MACT
Floor
Level
Removing
Sources
Cement
kilns
PM
0.028
gr/
dscf
0.033
gr/
dscf
Cement
kilns
Hg
64
ug/
dscm
48
ug/
dscm
Cement
kilns
SVM
4.0
x
10­
4
lb/
MMBtu
8.5
x
10­
4
lb/
MMBtu
Cement
kilns
LVM
1.4
x
10­
5
lb/
MMBtu
1.9
x
10­
5
lb/
MMBtu
Incinerators
SVM
59
ug/
dscm
230
ug/
dscm
Incinerators
TCl
1.5
ppmv
2.2
ppmv
The
projected
SVM
floor
level
for
cement
kilns
could
be
less
stringent
than
the
interim
standard
for
some
sources.
Thus,
in
order
to
avoid
any
backsliding
from
the
current
level
of
performance
achieved
by
cement
kilns,
the
projected
floor
level
would
be
expressed
as
a
dual
standard:
8.5
x
10­
4
lb/
MMBtu
or
330
ug/
dscm.
This
would
ensure
that
all
sources
are
complying
with
a
limit
that
is
at
least
as
stringent
as
the
interim
standard.
Note
that
we
believe
we
are
obligated
to
consider
the
emissions
data
that
was
excluded
from
the
above
MACT
floor
analysis.
Nonetheless,
the
proposal
requests
comment
on
two
alternative
approaches
to
calculate
MACT
floors
(
see
Part
Two,
Section
III)
because
this
is
known
to
be
a
controversial
issue,
and
we
want
input
from
all
stakeholders.
As
a
result,
we
believe
it
prudent
discuss
this
issue
(
and
alternative
options)
openly
in
the
preamble
in
order
to
give
all
parties
the
opportunity
to
comment.
­
9­
3.
Total
Chlorine
Standard
­
Method
26
Bias
Issue
(
Issue
raised
by
ACC
and
CRWI)

Issue:
CRWI
raised
the
following
issues/
concerns
regarding
the
data
used
to
calculate
total
chlorine
standard.

1)
Request
that
EPA
provide
a
scientific
justification
as
to
why
the
database
is
suitable
for
use
in
a
statistical
calculation
to
develop
a
MACT
standard
given
that
the
data
was
generated
for
a
distinctly
different
measurement
objective
(
i.
e.,
pass/
fail
question
at
a
much
higher
compliance
point).

EPA
Response:
The
same
measurement
method,
the
SW­
846
version
of
the
Air
Method
26A,
was
used
to
obtain
all
results
contained
in
the
database.
This
method
contains
procedures
to
ensure
data
quality
regardless
of
the
measured
level.
The
method
does
not,
as
CRWI
infers,
allow
a
less
stringent
data
quality
standard
based
on
the
measured
level.

2)
Given
the
known
and
suspected
biases
in
the
measurement
system,
method
variability,
and
source
variability,
request
that
EPA
provide
a
concrete
rationale
to
justify
that
sources
can
realistically
achieve
compliance
in
a
defensible
manner
with
a
standard
of
less
than
20
ppm.

EPA
Response:
CRWI
provided
a
report,
authored
by
Joette
Steger,
et.
al.,
to
document
the
bias
they
believe
appears
in
Method
26A.
We
further
analyzed
Steger's
results,
found
on
Table
III
of
Steger's
paper,
and
believe
the
negative
bias
Steger
reports
was
brought
about
by
using
an
overwhelming
amount
of
water
spiking
during
the
test.
Steger's
data
shows
that
a
significant
negative
bias
was
observed
whenever
38
to
50%
of
the
water
spiked
into
the
sampling
train
were
in
form
of
water
droplets.
(
For
the
purposes
of
this
discussion
we
define
a
"
significant
negative
bias"
as
any
recovery
less
than
93%.)

We
also
checked
our
HCl
emissions
data
to
see
if
water
droplets
could
be
present
in
the
sample
line.
We
found
that
water
droplets
could
be
present
in
three
of
our
test
conditions:
327C10
at
5%
water
droplets;
808C1
at
12.5%
water
droplets;
and
3204C1
at
8%
water
droplets.
None
of
these
stack
conditions
approach
the
38
to
50%
observed
to
be
a
problem
by
Steger.
These
stack
gas
conditions
most
closely
resemble
Steger's
run
B­
5,
with
10%
water
droplets.
No
negative
bias
was
observed
for
Steger's
run
B­
5.

3)
Request
that
EPA
investigate
whether
the
identified
measurement
system
biases
may
change
over
time
or
be
different
from
source
to
source,
and
how
achievability
of
compliance
may
be
affected.

EPA
Response:
As
discussed
above,
we
do
not
believe
the
method
has
a
low
measurement
bias
due
to
condensation.
­
10­
4.
Stakeholder's
Objection
to
Thermal
Emission
Limits
(
Issue
raised
by
ACC)

Issue:
American
Chemistry
Council
objects
to
the
inclusion
of
thermal
emission
limitations
for
liquid
fuel­
fired
boilers
for
the
following
four
reasons:

1.
ACC
states
emission
standards
that
are
expressed
in
the
thermal
emissions
format
are
not
needed
for
liquid
fuel­
fired
boilers
because
the
"
competitiveness
issues"
that
exist
for
cement
kilns
do
not
apply
to
the
boiler
source
category.

EPA
Response:
We
are
not
proposing
thermal
emission
limits
for
energy
recovery
units
to
address
competitiveness
issues.
Rather,
we
believe
thermal
emissions
are
appropriate
for
energy
recovery
units
because
standards
based
either
on
a
concentration
basis
(
or
total
thermal
heat
input
basis)
are
biased
against
sources
that
feed
more
hazardous
waste
to
recover
more
energy.
We
believe
our
approach
to
use
hazardous
waste
thermal
emissions
as
the
baseline
emissions
format
to
assess
best
performers
is
appropriate
because
it
supports
the
concept
of
promoting
energy
recovery
from
hazardous
waste
that
has
lower
pollutant
concentration
levels
per
million
BTUs.

2.
ACC
believes
that
demonstrating
compliance
for
these
units
could
present
significant
difficulties
due
to
detection
limit
issues.

EPA
Response:
We
believe
the
metal
HAP
emission
concentration
compliance
level
for
some
sources
may
be
close
to
the
method
detection
limit.
Specifically,
sources
that
feed
hazardous
waste
to
account
for
a
small
fraction
of
the
total
heat
input
may
have
difficulty
measuring
the
low
levels
of
metals
necessary
to
demonstrate
compliance
with
the
standard.
We
are
currently
developing
a
mechanism
(
that
we
would
request
comment
on)
that
would
provide
relief
to
sources
that
have
difficulty
complying
with
the
standard
because
of
detection
limit
issues.

3.
ACC
believes
it
is
arbitrary
that
liquid
fuel­
fired
boilers
burning
waste
fuel
with
a
higher
heating
value
(
e.
g.,
high
BTU
solvents
with
trace
metals)
would
be
allowed
greater
HAP
mass
emissions
than
liquid
fuel­
fired
boilers
burning
lower
BTU
waste
with
an
identical
metals
feed
concentration.

EPA
Response:
ACC
is
correct
that
sources
burning
waste
fuel
with
a
higher
heating
value
(
e.
g.,
high
BTU
solvents)
would
be
allowed
to
emit
HAP
at
higher
concentration
levels
as
compared
to
sources
burning
lower
BTU
waste
with
an
identical
metals
feed
concentration
(
i.
e.,
an
identical
metals
feed
concentration
based
on
mg/
kg,
as
opposed
to
lb/
million
BTUs).
We
believe
this
is
appropriate
because
of
the
reasons
discussed
in
#
1
above.

4.
ACC
believes
that
EPA
should
propose
standards
for
liquid
fuel­
fired
boilers
based
on
the
approach
the
Agency
finalized
for
nonhazardous
waste
industrial
boilers
because
the
affected
sources
are
similar.
They
have
communicated
to
EPA
that
they
prefer
the
standards
to
be
calculated
using
the
industrial
boiler
MACT
floor
methodology,
and
that
the
standards
be
expressed
in
the
same
format
(
i.
e.,
using
a
"
total
thermal
emissions
format"
instead
of
hazardous
waste
thermal
emissions
format).

EPA
Response:
The
nonhazardous
waste
industrial
boiler
sources
do
not
have
the
above
discussed
bias
because
they
do
not
burn
hazardous
waste.
If
we
were
to
use
the
industrial
boiler
MACT
methodology,
emission
standards
may
be
biased
against
sources
that
feed
high
BTU
content
­
11­
hazardous
wastes.
As
a
result,
we
believe
it
is
appropriate
to
propose
emission
limitations
that
differ
slightly
in
format
when
compared
to
the
industrial
boiler
MACT.
In
addition,
although
the
hazardous
waste
burning
boilers
are
functionally
similar
to
nonhazardous
waste
boilers,
their
method
of
controlling
emissions
are
not.
Hazardous
waste
boilers
control
metal
HAP
and
chlorine
both
by
front­
end
hazardous
waste
feed
control,
and
back­
end
air
pollution
control.
Nonhazardous
boilers
control
these
emissions
only
by
back­
end
control
technologies.
We
therefore
do
not
believe
that
the
MACT
methodology
used
in
Industrial
Boiler
MACT
is
appropriate
for
hazardous
waste
boilers
because
the
methodology
does
not
assess
hazardous
waste
feed
control
as
a
floor
control
technology.
[
Note
that
we
do
use
the
Industrial
Boiler
MACT
methodology
to
calculate
floor
levels
for
the
particulate
matter
standard
for
all
source
categories
because
we
believe
particulate
matter
emissions
are
primarily
controlled
via
back­
end
control
technologies.
Nonetheless,
we
have
calculated
emission
standards
using
the
approaches
recommended
by
ACC.
Results
of
the
analysis
indicate
that
our
proposed
approach
generally
results
in
lower
retrofit
costs.
The
table
below
summarizes
these
results.
­
12­

LIQUID
FUEL­
FIRED
BOILERS:
COMPARISON
OF
FLOOR
LEVELS
AND
COSTS
FOR
MACT
FLOOR
APPROACHES
FOR
EXISTING
SOURCES
MACT
Approach
Proposed
Approach.

SRE­
Feed/
Emissions:

HW
Thermal
Emissions1
SRE­
Feed/
Emissions:

Stack
Gas
Concentration2
Control
Technology:

HW
Thermal
Emissions3
Control
Technology:

Stack
Gas
Concentration2
Floor
Levels
D/
F
3.0
ng
TEQ/
dscm
3.0
ng
TEQ/
dscm
3.0
ng
TEQ/
dscm
3.0
ng
TEQ/
dscm
PM4
0.032
gr/
dscf
0.032
gr/
dscf
0.032
gr/
dscf
0.032
gr/
dscf
Hg
3.7
lb/
1012
Btu
0.47
ug/
dscm
9.5
lb/
1012
Btu
11
ug/
dscm
SVM
11
lb/
1012
Btu
8.7
ug/
dscm
5.4
lb/
1012
Btu
4.1
ug/
dscm
Cr
110
lb/
1012
Btu
27
ug/
dscm
29
lb/
1012
Btu
20
ug/
dscm
TCl
24
lb/
109
Btu
25
ppmv
29
lb/
109
Btu
15
ppmv
Total
Annualized
Cost
w/
TCl
$
39
million
$
55
million
$
49
million
$
42
million
w/
o
TCl
$
35
million
$
47
million
$
34
million
$
37
million
1
SRE­
Feed
Approach
used
for
Cr
and
TCl
identifies
best
performing
sources
based
on
the
aggregate
ranking
for
hazardous
waste
feedrate
of
the
HAP
and
SRE
of
the
control
device.
Emissions
Approach
used
for
D/
F,
Hg,
and
SVM
identifies
best
performing
sources
based
on
stack
gas
concentrations.
HW
Thermal
Emissions
are
pounds
of
HAP
from
hazardous
waste
per
1012
or
109
Btu
from
hazardous
waste.

2
Stack
gas
concentrations
can
be
converted
to
lb/
MM
Btu
assuming
9000
dscf/
MM
Btu
at
0%
O2
3
Control
Technology
Approach
identifies
best
performers
based
on
nominal
control
efficiency
(
i.
e.,
based
on
generic
engineering
information)
of
the
air
pollution
control
device.
This
approach
is
not
appropriate
for
HAP
where
control
of
the
HAP
hazardous
waste
feedrate
relates
to
control
of
emissions.

4
Control
Technology
Approach
is
used
for
PM
universally
because
hazardous
waste
feedrate
control
of
ash
does
not
relate
to
emissions
of
nonenumerated
metal
HAP
for
which
the
PM
standard
is
a
surrogate.
­
13­
5.
Stakeholder's
Request
for
an
Alternative
to
the
Particulate
Matter
Standard
(
Issue
raised
by
ACC)

Issue:
American
Chemistry
Council
supports
inclusion
of
an
alternative
to
the
particulate
matter
standards
for
incinerators
and
boilers.

EPA
Response:
We
agree.
We
are
proposing
a
simplified
version
of
the
alternative
to
the
particulate
matter
standard
that
was
promulgated
in
the
1999
rule.
This
alternative
to
the
particulate
matter
standard
would
apply
to
liquid
and
solid
fuel­
fired
boilers
and
incinerators.
We
are
also
requesting
comment
another
alternative
to
the
particulate
matter
that
would
be
applicable
to
all
source
categories
that
would
be
subject
to
a
particulate
matter
standard.

6.
Stakeholder
Objection
to
Requiring
Site­
Specific
Risk
Assessments
(
Issue
raised
by
ACC
and
CRWI)

Issue:
ACC
and
CRWI
group
stated
that,
"
EPA
should
not
require
site­
specific
risk
assessments
(
SSRAs)
as
part
of
the
permanent
replacement
standards
rulemaking."

Individually,
ACC
stated
that
"
OMB
should
ensure
that
EPA
does
not
require
SSRAs
as
part
of
the
permanent
replacement
standards
rulemaking."
CRWI
feels
that
"
If
EPA
does
not
propose
to
require
SSRAs,
but
keeps
the
status
the
same
as
it
currently
is,
no
action
by
OMB
is
needed.
If
EPA
proposes
to
require
SSRAs,
we
suggest
that
you
ask
EPA
to
address
all
the
issues
raised
under
the
previous
question
and
especially
to
justify
requiring
an
untested
method
to
set
site­
specific
operating
parameters
to
show
compliance."

EPA
Response:
We
agree
with
CRWI
and
ACC
that
we
should
not
require
SSRAs.
We
also
agree
with
CRWI
that
SSRAs
should
not
be
required,
for
many
of
the
same
reasons
that
CRWI
described
under
its
potential
ramifications
question.
Thus,
in
the
rulemaking,
we
have
only
proposed
to
make
explicit
an
authority
that
has
been
and
remains
available
under
the
omnibus
authority
(
RCRA
statutory
authority
or
"
omnibus"
authority
as
provided
under
Section
3005(
c)(
3))
and
its
implementing
regulations
(
see
40
CFR
270.10(
k)).
Although
we
believe
that
the
RCRA
omnibus
authority
provides
sufficient
authority
to
conduct
SSRAs
where
they
are
determined
to
be
necessary,
we
also
believe
it
appropriate
to
explicitly
codify
the
omnibus
authority
for
the
sake
of
regulatory
clarity
and
transparency.
­
14­
7.
Miscellaneous
Issues
(
Inclusion
of
Waste
Minimization
in
the
Benefits
Discussion,
Discounting
Benefits,
Corrected
RIA
Background
Document
Language,
SO2
benefits)

1.
Issue:
Should
waste
minimization
be
included
and
discussed
as
a
benefit?

Response:
OSW
plans
to
maintain
the
waste
minimization
discussion
as
part
of
the
benefits
section.
We
believe
that
waste
minimization
resulting
from
the
proposed
standards
would
be
a
benefit
for
the
following
key
reasons:
1)
Emissions
reductions
resulting
from
waste
minimization
at
the
generator
level
would
occur
beyond
those
necessary
for
compliance
with
the
replacement
standards.
These
benefits
would
not
be
captured
in
the
benefits
assessment,
2)
Waste
minimization
is
also
likely
to
result
in
benefits
such
as
reduced
waste
handling
costs
and
reduced
risks
associated
with
waste
spills
and
waste
management.

We
plan
to
incorporate
the
following
discussion
into
the
waste
minimization
section
of
the
Preamble
and
RIA:

A
quantitative
assessment
of
the
benefits
associated
with
waste
minimization
may
result
in
double­
counting
of
some
of
the
benefits
described
earlier
in
this
chapter.
For
example,
waste
minimization
may
reduce
emissions
of
hazardous
air
pollutants
and
therefore
have
a
positive
effect
on
public
health.
A
portion
of
these
health
impacts
are
captured
in
the
analysis
of
health­
related
benefits
presented
above.
However,
emissions
reductions
beyond
those
necessary
for
compliance
with
the
replacement
standards
are
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.
These
impacts
are
not
captured
in
the
quantitative
analysis
of
costs
and
benefits
presented
in
this
Assessment.

Note
that
a
revised
Chapter
Six
of
the
RIA
that
includes
this
revised
waste
minimization
benefits
discussion
is
attached.

2.
Issue:
OMB
requested
that
monetized
human
health
benefits
associated
with
avoided
premature
Deaths
be
discounted
in
order
to
be
consistent
with
Agency
and
OMB
guidance.

Response:
OSW
is
preparing
discounted
figures
for
all
BTF
levels,
where
possible.
OSW
will
also
prepare
an
aggregated
discounted
figure
that
includes
all
monetized
benefits
(
morbidity
and
visibility).
These
figures
will
be
presented
to
OMB.
The
aggregated
figure,
along
with
the
non­
discounted
figure
will
be
incorporated
into
the
Addendum.

3.
Issue:
RIA
background
document
appears
to
have
errors
(
e.
g.,
page
6­
3
and
exhibit
6­
5).

Response:
We
have
corrected
this
language.
A
revised
Chapter
Six
of
the
RIA
is
attached.

4.
Issue:
SO
2
benefits
associated
with
total
chlorine
beyond­
the
floor
standard
for
solid
fuel­
fired
boilers.
­
15­
Response:
OSW
has
prepared
a
stand
alone
assessment
document
that
describes
the
methodology,
data
sources,
findings,
and
limitations
associated
with
these
newly
monetized
benefits.
This
document
is
attached.
These
findings
will
also
be
incorporated
into
the
Addendum
to
the
RIA,
and
the
benefits
section
in
part
four
of
the
Preamble.
OMB
REVIEW
DRAFT:
November
2003
2
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
human
health
and
ecological
benefits;
including
property
value
benefits
may
result
in
double­
counting.
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
16
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).
2
This
chapter
also
briefly
discusses
how
the
proposed
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.

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
sub­
populations
in
quantitative,
non­
monetary
terms.
OMB
REVIEW
DRAFT:
November
2003
6­
17

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.

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)
OMB
REVIEW
DRAFT:
November
2003
3
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.

4
See
"
Human
Health
and
Ecological
Risk
Assessment
Support
to
the
Development
of
Technical
Standards
for
Emissions
from
Combustion
Units
Burning
Hazardous
Wastes:
Background
Document"
July
1999.

5
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.

6­
18
benefits
estimated
for
the
1999
standards
in
the
1999
Assessment.
3
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.

For
the
1999
Assessment,
EPA
estimated
the
avoided
incidence
of
mortality
and
morbidity
associated
with
reductions
in
PM
emissions.
4
The
risk
assessment
developed
estimated
cases
of
mortality
and
morbidity
avoided
for
children
and
the
elderly,
as
well
as
the
general
population,
using
concentrationresponse
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.
5
To
assess
the
benefits
of
the
proposed
HWC
MACT
replacement
standards,
EPA
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.
OMB
REVIEW
DRAFT:
November
2003
6
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.

7
OMB
guidance
recommends
that
federal
agencies
conduct
probabilistic
assessments
of
the
benefits
associated
with
new
regulation.
Office
of
Management
and
Budge.
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.

6­
19
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).
6
For
liquid
and
solid
fuel­
fired
boilers
and
hydrochloric
acid
production
furnaces,
EPA
extrapolated
the
avoided
incidence
from
the
incinerator
source
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.

EPA
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
fuel­
fired
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.
7
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.
OMB
REVIEW
DRAFT:
November
2003
8
"
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.

9
EPA
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.

10
A
less
detailed
screening­
level
analysis
was
used
in
the
1999
Assessment
to
identify
the
potential
for
ecological
risks.

11
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.

12
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.

6­
20
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.
8
This
section
provides
an
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.
9
A
multiple
pathway
analysis
that
models
both
inhalation
and
ingestion
pathways
was
used
to
estimate
human
health
risks.
10
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.
11
The
randomly
selected
facilities
in
the
study
included:
43
on­
site
incinerators,
13
commercial
incinerators,
15
cement
kilns,
and
five
lightweight
aggregate
kilns.
12
The
current
Assessment
adjusts
the
estimates
from
the
1999
Assessment
to
project
the
human
health
benefits
of
the
replacement
standards.
OMB
REVIEW
DRAFT:
November
2003
13
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.

14
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.

15
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.

16
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
21
The
pollutants
analyzed
in
the
risk
assessment
included
dioxins
and
furans,
selected
metals,
and
PM.
13
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.
14
The
risk
assessment
modeled
fate
and
transport
of
the
emissions
of
these
pollutants
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
non­
cancer
risks
using
these
doses,
if
the
appropriate
health
benchmarks
were
available.

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
ecotoxicological
criteria
representing
protective
screening
values
for
ecological
risks
to
assess
potential
ecological
risks.
15
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.
16
An
additional
Monte
Carlo
analysis
was
conducted
to
incorporate
variability
in
other
exposure
factors
such
as
inhalation
and
OMB
REVIEW
DRAFT:
November
2003
6­
22
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
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
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
OMB
REVIEW
DRAFT:
November
2003
17
Cancer
incidence
estimates
used
direct
and
indirect
exposure
pathways
for
all
nonsubsistence
receptors,
excluding
recreational
anglers.
Population
risks
could
not
be
calculated
for
recreational
anglers
because
detailed
population
data
were
not
available
for
this
receptor
population.

18
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).
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
23
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.

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.
17
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.
18
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
Addendum
to
the1999
Assessment
estimated
0.36
cancer
deaths
would
be
avoided
annually
with
a
OMB
REVIEW
DRAFT:
November
2003
19
We
use
the
VSL
approach
for
the
MACT
benefits
assessment
instead
of
applying
estimates
of
the
Value
of
a
Statistical
Life
Year
(
which
values
the
number
of
life
years
lost
as
the
result
of
premature
mortality)
because,
while
we
have
age
stratified
cancer
incidence
data
for
the
local
populations
near
incinerators,
we
do
not
have
such
data
for
cancer
incidence
from
nationwide
consumption
of
dioxin­
contaminated
foods.

20
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.

21
Particulate
matter
is
the
only
non­
carcinogen
in
the
risk
assessment
for
which
there
is
sufficient
dose­
response
information
to
estimate
numbers
of
cases
of
disease
and
deaths
from
exposures.

6­
24
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
4.7
grams
annually
for
the
Agency
Preferred
Approach
(
Exhibit
6­
5).
Thus,
the
replacement
standards
are
expected
to
avoid
less
than
0.36
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.
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.
19
Because
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
26
policy­
relevant
value­
of­
life
studies.
As
shown
in
Exhibit
6­
2,
the
estimated
VSL
figures
from
these
studies
range
from
$
0.80
million
to
$
18.23
million,
with
an
average
value
of
$
6.42
million
(
in
2002
dollars).
20
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.

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.
21
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
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
OMB
REVIEW
DRAFT:
November
2003
6­
25
population
at
risk,
we
cannot
conclude
that
the
results
are
biased
in
one
direction
or
the
other.

Benefits
from
Reduced
Exposure
to
Particulate
Matter
To
assess
benefits
from
reduced
exposure
to
particulate
matter
in
1999,
EPA
first
estimated
the
number
of
excess
mortality
and
hospital
admissions
in
the
baseline
and
under
various
1999
MACT
standard
scenarios.
EPA
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
EPA
scaled
the
cases
found
in
the
1999
Assessment
to
reflect
current
conditions
and
emission
reductions
achieved
by
the
proposed
HWC
MACT
replacement
standards.

Exhibit
6­
2
SUMMARY
OF
MORTALITY
VALUATION
ESTIMATES
Study
Type
of
Estimate
Valuation
(
millions
2002$)

Kneisner
and
Leeth
(
1991)
(
US)
Labor
Market
0.80
Smith
and
Gilbert
(
1984)
Labor
Market
0.92
Dillingham
(
1985)
Labor
Market
1.26
Butler
(
1983)
Labor
Market
1.49
Miller
and
Guria
(
1991)
Contingent
Value
1.61
Moore
and
Viscusi
(
1988a)
Labor
Market
3.33
Viscusi,
Magat,
and
Huber
(
1991b)
Contingent
Value
3.67
Marin
and
Psacharopoulos
(
1982)
Labor
Market
3.78
Gegax
et
al.
(
1985)
Contingent
Value
4.47
Kneisner
and
Leeth
(
1991)
(
Australia)
Labor
Market
4.47
Gerking,
de
Haan,
and
Schulze
(
1988)
Contingent
Value
4.59
Cousineau,
Lacroix,
and
Girard
(
1988)
Labor
Market
4.82
Jones­
Lee
(
1989)
Contingent
Value
5.16
Dillingham
(
1985)
Labor
Market
5.27
Viscusi
(
1978,
1979)
Labor
Market
5.50
R.
S.
Smith
(
1976)
Labor
Market
6.19
V.
K.
Smith
(
1976)
Labor
Market
6.31
Olson
(
1981)
Labor
Market
6.99
Viscusi
(
1981)
Labor
Market
8.83
R.
S.
Smith
(
1974)
Labor
Market
9.75
Moore
and
Viscusi
(
1988a)
Labor
Market
9.86
Kneisner
and
Leeth
(
1991)
(
Japan)
Labor
Market
10.20
OMB
REVIEW
DRAFT:
November
2003
Exhibit
6­
2
SUMMARY
OF
MORTALITY
VALUATION
ESTIMATES
Study
Type
of
Estimate
Valuation
(
millions
2002$)

22
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
26
Herzog
and
Schlottman
(
1987)
Labor
Market
12.27
Leigh
and
Folson
(
1984)
Labor
Market
13.07
Leigh
(
1987)
Labor
Market
13.99
Gaten
(
1988)
Labor
Market
18.23
Source:
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,
EPA
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).
22
For
avoided
deaths,
we
assign
monetary
values
in
the
same
way
as
for
avoided
cancer
cases,
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
3.
The
estimated
cost
of
each
illness
includes
the
hospital
charge,
the
costs
of
associated
physician
care,
and
the
opportunity
cost
of
time
OMB
REVIEW
DRAFT:
November
2003
23
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.
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.,
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.,
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.
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.,
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
27
spent
in
the
hospital.
23
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.
OMB
REVIEW
DRAFT:
November
2003
6­
28
Exhibit
6­
3
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
bronchitis1
$
382,969
Acute
bronchitis4
$
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.
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.

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
OMB
REVIEW
DRAFT:
November
2003
24
Based
on
the
population
estimated
in
the
1999
Assessment.

25
U.
S.
EPA,
The
Benefits
and
Costs
of
the
Clean
Air
Act,
1970
to
1990,
October
1997.

26
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.

27
It
is
important
to
note
that
OSW
is
currently
working
to
obtain
ORD
review
of
the
risk
assessment
for
mercury.
Given
the
current
state
of
scientific
knowledge,
there
is
controversy
regarding
modeling
mercury
concentrations
in
fish.

28
N.
J.
Waitzman,
R.
M
Scheffler,
and
P.
S.
Romano,
The
Costs
of
Birth
Defects,
Lanham,
Maryland:
University
Press
of
America,
Inc.,
1996.
This
study
provides
estimates
of
the
costs
of
birth
defects
involving
major
structural
anomalies,
and
includes
both
direct
and
indirect
costs.
The
direct
costs
include
medical,
developmental,
and
special
education
outlays.
Indirect
costs
consist
of
the
foregone
earnings
and
fringe
benefits
from
premature
mortality,
excess
morbidity,
lower
6­
29
less
than
0.01
pounds
per
person
(
see
below,
Exhibit
6­
5).
24
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.
25
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.
26
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.
27
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).
28
In
a
survey
of
the
non­
cancer
economic
literature,
this
study
was
found
to
provide
reasonable
OMB
REVIEW
DRAFT:
November
2003
wages,
and
lower
labor
force
participation
rates.
In
addition,
indirect
costs
include
foregone
nonmarket
production,
based
on
the
cost
of
hiring
people
for
household
work.

29
U.
S.
Environmental
Protection
Agency,
Social
Science
Discussion
Group,
Handbook
for
Non­
Cancer
Valuation:
Draft,
Prepared
for
U.
S.
EPA
by
Industrial
Economics,
Incorporated,
September
30,
1997.

30
U.
S.
Department
of
Commerce,
Bureau
of
the
Census,
Statistical
Abstract
of
the
United
States
1995,
115th
ed.,
73.

6­
30
benefit
measures.
29
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.
30
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
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.

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
5).
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.
OMB
REVIEW
DRAFT:
November
2003
6­
31
Exhibit
6­
4
COSTS
OF
ILLNESS
ASSOCIATED
WITH
VARIOUS
BIRTH
DEFECTS
Health
Condition
Cost
per
Case
(
thousands)

Spina
bifida
$
405
Truncus
arteriosus
$
697
Transposition
of
great
arteries/
Double
Outlet
Right
Ventricle
$
368
Single
ventricle
$
474
Tetralogy
of
Fallot
$
360
Cleft
lip
or
palate
$
140
Tracheoesophageal
fistula
$
200
Atresia
of
the
small
intestine
$
103
Colorectal
atresia
$
169
Renal
agenesis
$
345
Urinary
tract
obstruction
$
116
Upper­
limb
reduction
$
138
Lower­
limb
reduction
$
274
Diaphragmatic
hernia
$
345
Gastroschisis
$
149
Omphalocele
$
243
Down
syndrome
$
622
Median
$
274
Source:
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
OMB
REVIEW
DRAFT:
November
2003
6­
32
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.

Exhibit
6­
5
ANNUAL
EMISSIONS
REDUCTIONS
FOR
THE
PROPOSED
HWC
MACT
REPLACEMENT
STANDARDS
Standard
Particulate
Matter
(
tons/
yr)
Mercury
(
tons/
yr)
Lead
(
tons/
yr)
Dioxins/
Furans
(
grams/
yr)
Chlorine
(
tons/
yr)

Agency
Preferred
Approach
2,215
0.9
5.4
4.7
2,635
Option
1
Floor
1,829
0.9
5.1
0.4
1,570
Option
2
Floor
1,829
1.3
5.8
0.4
3,106
Option
3
Floor
3,254
1.3
6.6
0.4
4,955
1999
Standard
2,449
3.9
89
28.7
5,132
A
summary
of
the
quantified
benefits
for
the
Agency
Preferred
Approach
are
provided
in
Exhibit
6­
6,
and
the
summary
of
quantified
benefits
of
the
Floor
options
are
presented
in
Exhibit
6­
7.
Below,
we
describe
the
results
in
more
detail.

Benefits
from
Cancer
Risk
Reductions
Less
than
0.36
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
from
home­
OMB
REVIEW
DRAFT:
November
2003
31
The
following
pathways
pertain
to
this
subsistence
receptor:
ingestion
of
homeproduced
beef,
pork,
chicken,
eggs,
milk,
root
vegetables,
exposed
fruit,
exposed
vegetables,
and
fish
caught
on
farm
ponds.

32
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.

33
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.

34
Other
pollutants
were
found
to
pose
negligible
individual
risks
and
so
are
not
included
in
the
results.

6­
33
production.
31
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
100,000.32
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.
33
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.
34
Total
annual
health
benefits
are
valued
at
about
$
4.5
million
for
Option
1
Floor
and
Option
2
Floor
and
the
Agency
Preferred
Approach,
and
$
8.7
million
for
Option
3
Floor.

Particulate
Matter.
The
proposed
HWC
MACT
replacement
standards
are
expected
to
avoid
less
OMB
REVIEW
DRAFT:
November
2003
35
U.
S.
EPA,
Environmental
Health
Threats
to
Children,
EPA
175­
F­
96­
001,
September
1996,
page
4.

36The
primary
form
of
lead
exposure
to
children
is
via
ingestion
of
contaminated
soil.

6­
34
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
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
$
4.5
million
to
$
8.7
million
per
year.
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.
35
Mercury.
The
1999
standards
were
expected
to
reduce
mercury
emission
by
four
tons
per
year.
The
proposed
HWC
MACT
replacement
standards
are
expected
to
reduce
mercury
emissions
by
an
additional
one
ton
per
year
(
Exhibit
6­
5).
The
benefits
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
mercurycontaminated
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
and
subsistence
fishers.
Following
the
implementation
of
the
proposed
HWC
MACT
replacement
standards,
the
hazard
index
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
mercury
exposure,
as
mercury
health
science
is
continuing
to
evolve.

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
seven
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
seven
children
age
0­
5
less
than
10
µ
g/
dL
annually.
36
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
OMB
REVIEW
DRAFT:
November
2003
6­
35
standards.
The
small
number
of
cases
identified
in
the
1999
Assessment
suggests
that
these
benefits
may
be
modest.
OMB
REVIEW
DRAFT:
November
2003
6­
36
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,
52
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,
102
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
8
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,
53
cases
of
respiratory
symptoms,
and
about
5,000
days
of
work
loss
or
MRAD.
The
Agency
Preferred
Approach
does
have
additional
health
benefits
that
are
not
quantified
including
Cl,
dioxin,
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
(
Exhibit
6­
5).

However,
one
of
the
greatest
differences
between
the
HWC
MACT
Standards
Floor
options
and
the
Agency
Preferred
Approach;
is
the
increased
reduction
in
dioxin
emissions
with
the
Agency
Preferred
Approach;
a
six
fold
increase
in
emissions
reduced
is
expected
under
the
Agency
Preference
Approach.
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
0.36
cancer
cases
per
year
that
were
expected
to
be
avoided
due
to
the
1999
standards.
Although
the
incremental
reduction
in
dioxin
emissions
from
the
Agency
Preferred
Approach
are
expected
to
be
about
12
times
less
than
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,
1
9
9
8
,
1
9
9
9
)
,
Ma
n
z
et
al
.
(
1
9
9
1
)
,
O
t
t
e
t
a
l.
(
1
9
9
6
)
,
OMB
REVIEW
DRAFT:
November
2003
37
Steenland,
K;
Piacitelli,
L;
Deddens,
J;
et
al.
(
1999)
Cancer,
heart
disease,
and
diabetes
in
workers
exposed
to
2,3,7,8­
Tetrachlorodibenzo­
p­
dioxin.
J
Nat
Cancer
Ins
91(
9):
779­
786;
Fingerhut,
MA;
Halperin,
WE;
Marlow,
DA;
et
al.
(
1991)
Cancer
mortality
in
workers
exposed
to
2,3,7,8­
tetrachlorodibenzo­
p­
dioxin.
N
Engl
J
Med
324:
212­
218;
Becher,
H;
Flesch­
Janys,
D;
Kauppinen,
T;
et
al.
(
1996)
Cancer
mortality
in
German
male
workers
exposed
to
phenoxy
herbicides
and
dioxins.
Cancer
Causes
Control
7:
312­
321;
Flesch­
Janys,
D.
(
1997)
Letters
to
the
editor:
the
first
author
replies.
Am
J
Epidemiol
146(
4):
362­
363;
Flesch­
Janys,
D;
Berger,
J;
Gurn,
P;
et
al.
(
1995)
Exposure
to
polychlorinated
dioxins
and
furans
(
PCDD/
F)
and
mortality
in
a
cohort
of
workers
from
a
herbicide­
producing
plant
in
Hamburg,
Federal
Republic
of
Germany.
Am
J
Epidemiol
142(
11):
1165­
1175;
Flesch­
Janys,
D;
Steindorf,
K;
Gurn,
P;
et
al.
(
1998)
Estimation
of
the
cumulated
exposure
to
polychlorinated
dibenzo­
p­
dioxins/
furans
and
standardized
mortality
ratio
analysis
of
cancer
mortality
by
dose
in
an
occupationally
exposed
cohort.
Environ
Health
Perspect
106(
supplement
2):
655­
662;
Flesch­
Janys,
D.;
Becher,
J.;
Berger,
J.;
et
al.
(
1999)
Epidemiological
investigation
of
breast
cancer
incidence
in
a
cohort
of
female
workers
with
high
exposure
to
PCDD/
F
and
HCH.
Organohalogen
Compounds
44:
379­
382;
Manz,
A;
Berger,
J;
Dwyer,
JH;
et
al.
(
1991)
Cancer
mortality
among
workers
in
chemical
plant
contaminated
with
dioxin.
Lancet
338:
959­
964;
Ott,
MG;
Zober,
A.
(
1996)
Cause
specific
mortality
and
cancer
incidence
among
employees
exposed
to
2,3,7,8­
TCDD
after
a
1953
reactor
accident.
Occup
Environ
Med
53:
606­
612;
Zober,
A;
Messerer,
P;
Huber,
P.
(
1990)
Thirty­
fouryear
mortality
follow­
up
of
BASF
employees
exposed
to
2,3,7,8­
TCDD
after
the
1953
accident.
Int
Arch
Occup
Environ
Health
62:
138­
157;
Kogevinas,
M;
Becher,
H;
Benn,
T;
et
al.
(
1997)
Cancer
mortality
in
workers
exposed
to
phenoxy
herbicides,
chlorophenols,
and
dioxin.
An
expanded
and
updated
international
cohort
study.
Am
J
Epidemiol
145
(
12):
1061­
1075;
Saracci,
R;
Kogevinas,
M;
Bertazzi,
P;
et
al.
(
1991)
Cancer
mortality
in
workers
exposed
to
chlorophenoxy
herbicides
and
chlorophenols.
Lancet
38(
3774):
1027­
1032;
Hooiveld,
M;
Heederik,
D.
(
1996)
Preliminary
results
of
the
second
follow­
up
of
a
Dutch
cohort
occupationally
exposed
to
phenoxy
herbicides,
chlorophenols,
and
contaminants.
Organohalogen
Compounds
30:
185­
189;
and
Hooiveld,
M;
Heederik,
DJ
J;
Kogevinas,
M;
et
al.
(
1998)
Second
follow­
up
of
a
Dutch
cohort
occupationally
exposed
to
phenoxy
herbicides,
chlorophenols,
and
contaminants.
Am
J
Epidemiol
147(
9):
891­
901.

6­
37
Zober
et
al.
(
1990),
Kogevinas
et
al.
(
1997),
Saracci
et
al.
(
1991),
and
Hooiveld
et
al.
(
1996,
1998)).
37
As
a
result,
benefits
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).

Reduced
dioxin
emissions
may
result
in
additional
cancer
risk
reductions
for
the
most
sensitive
subpopulations
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
OMB
REVIEW
DRAFT:
November
2003
38
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.

39
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.

6­
38
cancer
with
a
probability
of
five
in
100,000.38
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.
39
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.

Exhibit
6­
6
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
avoided
0.3
$
2.11
Respiratory
illness
0.9
$
0.01
Cardiovascular
disease
0.4
$
0.01
Chronic
bronchitis
5.7
$
2.17
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
3757.8
$
0.15
Total
Annual
Monetary
Benefits
$
4.50
OMB
REVIEW
DRAFT:
November
2003
6­
39
OMB
REVIEW
DRAFT:
November
2003
6­
40
Exhibit
6­
7
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
$
2.09
0.3
$
2.09
0.6
$
4.12
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
$
2.15
5.6
$
2.15
11.0
$
4.20
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
$
0.10
Minor
restricted
activity
3726.1
$
0.15
3726.1
$
0.15
7287.2
$
0.29
Total
Annual
Monetary
Benefits
$
4.46
$
4.46
$
8.73
OMB
REVIEW
D
6­
41
OMB
REVIEW
DRAFT:
November
2003
6­
42
Exhibit
6­
8
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
$
0.03
0.1
$
0.03
0.1
$
0.03
0.1
$
0.03
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
$
0.03
$
0.03
$
0.03
$
0.03
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
$
0.03
0.1
$
0.03
0.1
$
0.03
0.1
$
0.04
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
OMB
REVIEW
DRAFT:
November
2003
Exhibit
6­
8
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
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
Subtotal
$
0.03
$
0.03
$
0.03
$
0.05
All
Incinerators/
Human
Health
Benefits
Premature
deaths
avoided
0.0
$
0.13
0.0
$
0.13
0.0
$
0.13
0.0
$
0.24
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
$
0.12
0.3
$
0.12
0.3
$
0.12
0.6
$
0.23
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
$
0.00
0.3
$
0.00
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
$
0.27
$
0.27
$
0.27
$
0.49
OMB
REVIEW
DRAFT:
November
2003
Exhibit
6­
8
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
44
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
$
0.04
$
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
OMB
REVIEW
DRAFT:
November
2003
Exhibit
6­
8
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
45
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
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
$
1.96
0.3
$
1.96
0.3
$
1.96
0.6
$
3.88
Respiratory
illness
0.8
$
0.01
0.8
$
0.01
0.8
$
0.01
1.6
$
0.01
Cardiovascular
disease
0.4
$
0.01
0.4
$
0.01
0.4
$
0.01
0.7
$
0.01
Chronic
bronchitis
5.1
$
1.97
5.1
$
1.97
5.1
$
1.97
10.2
$
3.89
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
$
0.09
Minor
restricted
activity
3,424.3
$
0.13
3,424.3
$
0.13
3,424.3
$
0.13
6,780.1
$
0.27
Subtotal
$
4.12
$
4.12
$
4.12
$
8.16
Total
$
4.50
$
4.46
$
4.46
$
8.73
VISIBILITY
BENEFITS
OMB
REVIEW
D
40
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.

41
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.

42
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.

43
U.
S.
EPA,
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010,
November
1999.

44
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003.

6­
46
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.
40
In
addition,
Chestnut
and
Dennis
(
1997)
used
data
representative
of
the
Eastern
United
States
from
McClelland
et
al.
(
1990)
to
measure
WTP
in
residential
areas.
41,42
EPA
has
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
billion.
43
Assuming
a
linear
relationship,
reduced
PM
associated
with
the
proposed
HWC
MACT
replacement
standards
could
result
in
a
visibility
benefit
from
approximately
$
6.1
million
for
Option
1
Floor
and
Option
2
Floor,
$
7.4
million
for
the
Agency
Preferred
Approach,
and
$
10.9
million
for
Option
3
Floor,
proportional
to
national
reductions.
This
comparative
approach
of
linear
extrapolation
produces
similar
results
($
6.1
million
to
$
10.9
million)
when
comparing
benefits
of
emissions
reductions
of
the
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines.
44
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.
This
approach
has
several
limitations.
In
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010
and
Draft
OMB
REVIEW
D
45
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.

46
U.
S.
EPA,
The
Benefits
and
Costs
of
the
Clean
Air
Act
1990
to
2010,
November
1999.

47
U.
S.
EPA,
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines,
Assessment
and
Standards
Division,
April
2003.

6­
47
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).
45
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
$
68
to
$
108
billion
and
visibility
benefits
of
$
2
to
$
3
billion
are
estimated
for
reductions
in
PM
emissions.
46
In
the
Draft
Regulatory
Impact
Analysis:
Control
of
Emission
from
Nonroad
Diesel
Engines
EPA
estimates
human
health
benefits
of
$
58
to
$
104
billion
and
visibility
benefits
of
$
1
to
$
2
billion
associated
with
reductions
in
PM
emissions.
47
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
$
113,000
for
Option
1
Floor
and
Option
2
Floor,
$
114,000
for
the
Agency
Preferred
Approach,
and
$
222,000
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,
OMB
REVIEW
D
48
Threatened
and
endangered
species
and/
or
habitats
were
not
included
in
the
analysis.

49
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
48
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
ecotoxicological
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.

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.
48

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).
49

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
OMB
REVIEW
DRAFT:
November
2003
6­
49
toxicological
criteria
and
a
real
benefit
measure,
such
as
increased
fish
populations,
for
which
a
benefits
transfer
approach
could
assign
monetary
values.
OMB
REVIEW
D
50
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.

51
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.
(
Mercury
Study
Report
to
Congress
Volume
VI,
1997)

6­
50
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.
50
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
screeninglevel
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.
51
While
the
total
value
of
forest
health
is
difficult
to
estimate,
visible
deterioration
OMB
REVIEW
D
(
Several
studies
are
cited
in
this
report.)

52
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;
this
work
studies
the
relationship
between
forest
characteristics
and
the
value
of
recreational
participation.
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;
Walsh
et
al.
1990,
Estimating
the
public
benefits
of
protecting
forest
quality,
Journal
of
Forest
Management,
30:
175­
189.,
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.

53
MacKenzie,
James
J.,
and
Mohamed
T.
El­
Ashry,
Air
Pollution's
Toll
on
Forests
and
Crops
(
New
Haven,
Yale
University
Press,
1989).

6­
51
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
health
are
available
to
place
a
value
on
aesthetic
degradation
of
forests.
52
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.
53
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
OMB
REVIEW
D
54
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.

55
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
52
higher
combustion
prices.
54
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
alternatives
in
the
short
term
generally
exceed
the
cost
of
combustion.
55
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.

A
quantitative
assessment
of
the
benefits
associated
with
waste
minimization
may
result
in
doublecounting
of
some
of
the
benefits
described
earlier
in
this
chapter.
For
example,
waste
minimization
may
reduce
emissions
of
hazardous
air
pollutants
and
therefore
have
a
positive
effect
on
public
health.
A
portion
of
these
health
impacts
are
captured
in
the
analysis
of
health­
related
benefits
presented
above.
However,
emissions
reductions
beyond
those
necessary
for
compliance
with
the
replacement
standards
are
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.
These
impacts
are
not
captured
in
the
quantitative
analysis
of
costs
and
benefits
presented
in
this
Assessment.
OMB
REVIEW
DRAFT:
November
2003
6­
53
Exhibit
6­
9
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
avoided
0.3
$
2.11
0.3
$
2.09
0.3
$
2.09
0.6
$
4.12
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
$
2.17
5.6
$
2.15
5.6
$
2.15
11.0
$
4.20
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
$
0.09
Minor
restricted
activity
3757.8
$
0.15
3726.1
$
0.15
3726.1
$
0.15
7287.2
$
0.29
Annual
Monetary
Health
Benefits
$
4.50
$
4.46
$
4.46
$
8.73
Visibility
Annual
Monetary
Visibility
Benefits
$
0.11
to
$
7.41
$
0.11
to
$
6.12
$
0.11
to
$
6.12
$
0.22
to
$
10.89
Total
Annual
Monetary
Benefits
$
4.61
to
$
11.91
$
4.57
to
$
10.58
$
4.57
to
$
10.58
$
8.95
to$
19.62
OMB
REVIEW
DRAFT:
November
2003
6­
54
CONCLUSIONS
Overall,
the
Agency
Preferred
Approach
is
expected
to
result
annually
in
approximately
$
4.5
in
human
health
benefits
beyond
the
baseline.
In
addition,
the
proposed
Agency
Preferred
Approach
is
expected
to
result
in
$
100,000
to
$
7.4
million
in
visibility
benefits
beyond
the
baseline
(
see
Exhibit
6­
8
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
0.36
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
index
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
likely
to
be
small
based
on
the
1999
Assessment.


Reduced
lead
exposure
in
children.
The
Agency
Preferred
Approach
is
expected
to
reduce
lead
exposure
in
children,
including
children
of
sub­
populations
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
$
7.4
million
annually
for
a
30
percent
change
in
particulate
matter
concentration
from
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
$
100,000
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
OMB
REVIEW
DRAFT:
November
2003
6­
55
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.

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
childrens
health
implications
of
this
proposed
rule.
OMB
REVIEW
DRAFT:
November
2003
56
The
specific
technology
is
simple
direct
duct
injection
dry
scrubbing.
EPA
Floor
option
regulatory
scenarios
(
i.
e.,
Floor
Option
1,
Floor
Option
2,
and
Floor
Option
3)
would
not
require
dry
scrubbers
and
would
therefore
incur
no
benefits
associated
with
SO
2
reductions.

6­
56
February
25,
2004
Hazardous
Waste
Combustion
MACT
Replacement
Standards:
Proposed
Rule
Assessment
of
Benefits
Associated
with
the
Beyond­
the­
Floor
Standard
for
TCl
from
Solid
Fuel
Boilers
Burning
Hazardous
Waste
We
have
identified
expected
reductions
in
sulfur
dioxide
(
SO
2)
emissions
from
coal
fired
boilers
as
a
result
of
the
Hazardous
Waste
Combustion
(
HWC)
MACT
replacement
standards.
The
HWC
MACT
standard
for
chlorine
under
the
"
Agency
Preferred
Approach"
regulatory
scenario
will
require
facilities
with
coal­
fired
(
i.
e.,
solid
fuel)
hazardous
waste
burning
boilers
to
install
flue
gas
desulfurization
(
i.
e.,
"
dry
scrubber")
technology.
56
In
addition
to
controlling
releases
of
chlorine,
dry
scrubbers
will
reduce
emissions
of
sulfur
dioxide
from
these
facilities.

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

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

We
estimate
baseline
(
SO
2)
emissions
from
these
facilities
at
37,000
tons
per
year,
reflecting
operating
requirements
under
test
conditions.
The
Texas
and
Arkansas
facilities
are
assumed
to
use
OMB
REVIEW
DRAFT:
November
2003
57
U.
S.
EPA,
2003,
Technical
Addendum:
Methodologies
for
the
Benefit
Analysis
of
the
Clear
Skies
Act
of
2003,
accessed
February
17,
2004,
at
<
http://
www.
epa.
gov/
clearskies/
tech_
addendum.
pdf>;
U.
S.
EPA,
2003,
Technical
Support
Document
for
the
Clear
Skies
Act
2003
Air
Quality
Modeling
Analysis,
accessed
February
17,
2002,
at
<
http://
www.
epa.
gov/
air/
clearskies/
aq_
modeling_
tsd_
csa2003.
pdf>;
U.
S.
EPA,
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
accessed
February
17,
2004,
at
<
http://
www.
epa.
gov/
interstateairquality/
tsd0175.
pdf>.
In
addition,
we
examined
an
unpublished
draft
report
by
Carrothers
et
al.
(
2002),
which
estimates
national
6­
57
low
sulfur
coal
(
sulfur
content
of
0.6
percent),
and
the
West
Virginia
and
Tennessee
facilities
are
believed
to
use
eastern
coal
(
sulfur
content
ranging
from
one
to
five
percent,
with
an
average
value
of
2.5
percent).

Our
engineers
have
determined
that
the
installation
of
dry
scrubbers
for
required
control
of
HCl
(
beyond­
the­
floor
standard
of
the
agency
preferred
approach)
will
reduce
SO
2
emissions
by
60
percent,
or
22,000
tons
per
year.
Exhibit
1
summarizes
the
SO
2
emissions
reductions.

Exhibit
1
SUMMARY
OF
ESTIMATED
SO2
EMISSION
REDUCTIONS
Associated
with
the
AGENCY
PREFERRED
APPROACH
Beyond­
the­
Floor
Standard
for
TCl
­
Solid
Fuel
Boilers
Facility
Sulfur
Content
of
Coal
Baseline
SO2
Emissions
SO2
Emission
Reductions
SO2
Emissions
Under
Agency
Preferred
Approach
Eastman
Chemical
Co.,
Kingsport,
Tennessee
2.5%
26,130
15,680
10,450
Celanese
Chemicals,
Pampa,
Texas
0.6%
6,280
3,770
2,510
Union
Carbide,
South
Charleston,
West
Virginia
2.5%
4,000
2,400
1,600
Eastman
Chemical
Co.,
Batesville,
Arkansas
0.6%
550
330
220
TOTAL
36,960
22,180
14,780
Evaluation
of
Benefits
To
develop
initial
estimates
of
potential
benefits
associated
with
SO
2
emissions
reductions,
we
scale
existing
published
national
benefits
assessments
associated
with
SO
2
emissions
reductions
under
the
Clear
Skies
Initiative
and
the
Inter­
State
Air
Quality
Rule
(
IAQR).
57
As
detailed
in
these
OMB
REVIEW
DRAFT:
November
2003
exposure
to
PM
2.5
and
gaseous
precursors
from
coal­
fired
power
plants
and
mobile
sources.
The
report
then
estimates
benefits
associated
with
reduced
mortality
due
to
decreases
in
emissions.
Carrothers,
Timothy
J.,
Scott
K.
Wolff,
Jouni
Tuomisto,
Andrew
M.
Wilson,
Jonathan
I.
Levy,
John
D.
Graham,
John
D.
Graham,
John
S.
Evans,
2002,
Assessing
the
Economic
Value
of
Further
Research
about
Fine
Particle
Air
Pollution:
Model
Framework
and
Preliminary
Findings,
final
review
draft.

58
Note
that
this
is
a
conservative
assumption
because
in
general,
SO
2
is
a
more
efficient
precursor
of
particulate
matter
than
nitrous
oxides.

59
These
estimates
reflect
the
average
of
a
range
of
discount
rates
and
scenarios.
Low
end
estimates
reflect
IAQR
study
near
term
benefits
using
a
seven
percent
discount
rate;
High­
end
estimates
reflect
Clear
Skies
study
longer
term
benefits
using
a
three
percent
discount
rate.
The
estimates
also
exclude
ozone­
related
benefits;
IAQR
study
estimated
total
benefits
(
including
ozone­
related
benefits)
at
$
54
to
$
84
billion;
the
Clear
Skies
study
estimated
total
benefits
(
including
ozone­

6­
58
documents
and
other
literature,
a
significant
percentage
of
the
benefits
associated
with
the
control
of
SO
2
results
from
avoided
health
effects
associated
with
the
development
of
fine
particulate
matter
(
PM)
formed
by
SO
2
in
the
atmosphere.
The
Clear
Skies
Initiative
and
the
IAQR
both
examine
benefits
associated
with
reduction
in
PM
resulting
from
both
SO
2
and
nitrogen
(
NOx)
releases.

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


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


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


Where
benefits
related
to
particulate
matter
associated
with
SO
2
emissions
reductions
and
NOx
reductions
are
not
reported
separately,
the
relationship
between
benefits
is
proportional
to
the
quantity
of
pollutants
(
i.
e.,
if
SO
2
emissions
represent
50
percent
of
the
per
weight
pollutant
reductions,
then
they
represent
50
percent
of
the
benefits).
58
The
Clear
Skies
and
IAQR
analyses
each
predicted
a
total
reduction
in
SO
2
emissions
of
roughly
3.5
million
tons
and
NOx
reductions
of
1.5
million
tons.
The
total
benefits
associated
with
particulate
matter
reductions
were
estimated
at
$
51.5
to
$
109.3
billion
(
1999
dollars)
in
the
Clear
Skies
analysis
and
$
54.5
to
$
83.6
billion
(
1999
dollars)
in
the
IAQR
analysis.
59
OMB
REVIEW
DRAFT:
November
2003
related
benefits)
at
$
52
to
$
113
billion.

60
The
Clear
Skies
and
IAQR
total
predictions
(
SO
2
plus
NO
x)
of
approximately
5.0
million
tons/
yr
emissions
reductions
(
3.5/
5.0
=
70
percent).

6­
59
Assuming
that
SO
2
emissions
reductions
represent
roughly
70
percent60
of
total
particulate
matter
benefits,
we
estimate
that
a
reduction
of
22,000
tons
of
SO
2
emissions
under
the
HWC
MACT
standards
would
incur
total
monetized
benefits
ranging
from
$
212
million
to
$
350
million
per
year.
This
result
reflects
a
"
dollar
per
ton"
range
of
$
9,700
to
$
15,900
for
benefits
per
ton
of
SO
2
removed.
If
only
mortality
is
included,
annual
monetized
benefits
would
range
from
$
193
million
to
$
320
million,
reflecting
a
"
dollar
per
ton"
range
of
approximately
$
8,800
to
14,600
for
benefits
per
ton
of
SO
2
removed.

Exhibit
2
provides
a
more
detailed
summary
of
the
range
of
potential
benefits
based
on
both
studies.
OMB
REVIEW
DRAFT:
November
2003
6­
60
Exhibit
2
SUMMARY
OF
BENEFITS
ASSOCIATED
WITH
SO2
EMISSION
REDUCTIONS
Benefit
Category
IAQR
Analysis
(
million
1999$)
Clear
Skies
Analysis
(
million
1999$)

Total
Mortality
50,000
­
72,000
47,000
­
100,000
Total
Infant
Mortality
Benefits
130
­
180
 
Total
Other
Benefits
4,902
­
5,019
4,518
­
9,184
Total
Benefits
54,532
­
83,599
51,518
­
109,284
Total
SO2
Benefits
39,911
­
57,812a
34,478
­
73,255b
Total
Benefits
of
HWC
MACT
SO2
Reductions:
Agency
Preferred
Approach
(
based
on
22,000
tons/
yr)
c
Total
Benefits
(
millions)
$
247.4
­
$
332.9
$
212.4
­
$
350.0
Average
of
Total
Benefits
(
millions)
$
281.7
$
281.9
Total
Benefits,
per
Ton
(
dollars)
$
10,642
­
$
15,133
$
9,655
­
$
15,908
Average
of
Total
Benefits,
per
Ton
(
dollars)
$
12,808
$
12,814
Mortality
Benefits
Only
(
millions)
$
215.2
­
$
307.4
$
193.8
­
$
320.3
Average
of
Mortality
Benefits
Only
(
millions)
$
259.5
$
257.7
Mortality
Benefits
Only,
per
Ton
(
dollars)
$
9,783
­
$
13,971
$
8,808
­
$
14,557
Average
of
Mortality
Benefits
Only,
per
Ton
(
dollars)
$
11,797
$
11,714
Notes:
a
Based
on
3.7
­
3.8
million
tons
SO2
avoided,
adjusted
to
exclude
28­
31%
NOx
contribution.
b
Based
on
3.6
­
4.6
million
tons
SO2
avoided,
adjusted
to
exclude
33%
NOx
contribution.
c
These
ranges
reflect
the
use
of
different
discount
rates,
time
frames,
and
assumptions
about
non­
mortality
benefits.
Low
end
estimates
reflect
near
term
mortality
benefits
only,
using
a
seven
percent
discount
rate;
high­
end
estimates
reflect
study
longer
term
total
benefits
using
a
three
percent
discount
rate.
OMB
REVIEW
DRAFT:
November
2003
61
Note
that
this
assumption
is
very
conservative
and
is
designed
solely
to
develop
a
lower
bound
estimate.
Because
boilers
are
designed
to
provide
power
for
other
facility
processes,
it
would
be
unusual
for
them
to
operate
at
levels
as
low
as
50
percent.
In
addition,
trial
burn
data
(
collected
as
part
of
the
RCRA
permitting
process)
were
used
to
identify
total
coal
requirements
for
boilers.
Trial
burns
are
typically
designed
to
reflect
maximum
hazardous
waste
combustion.
Because
SO
2
is
associated
with
the
supplemental
fuel
coal
(
and
not
with
hazardous
waste),
it
is
possible
that
trial
burn
data
may
understate
baseline
SO
2
emissions
if
normal
operations
involve
less
hazardous
waste
and
more
coal.

6­
61
Lower
Bound
Estimate
of
Benefits
In
addition
to
the
estimates
based
on
a
simple
extrapolation
of
Clear
Skies
and
IAQR
analyses,
we
have
developed
a
conservative
lower­
bound
estimate
of
potential
benefits
(
mortality
only)
associated
with
SO
2
emissions
reductions
resulting
from
the
BTF
TCl
level
for
solid
fuel
boilers.
This
estimate
includes
only
emissions
reductions
from
the
Tennessee
Eastman
facility
and
makes
the
following
conservative
assumptions:


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


The
facility
operates
boilers
at
50
percent
of
the
intensity
reflected
in
the
trial
burn
data
(
initial
estimate
assumes
that
boilers
operate
as
continuous
process
equipment
at
90
percent
of
annual
trial
burn
capacity);
and
61

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

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

Key
Limitations:

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


the
affected
populations
for
each
of
the
facilities
of
concern
are
assumed
to
be
generally
consistent
with
populations
affected
by
facilities
examined
in
the
Clear
Skies
and
IAQR
analyses,
OMB
REVIEW
DRAFT:
November
2003
6­
62

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


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

baseline
emissions
estimates
used
in
this
analysis
reflect
current
emissions
for
each
of
the
facilities
of
concern.
