ADDENDUM
TO
THE
ASSESSMENT
OF
THE
POTENTIAL
COSTS,
BENEFITS,
&
OTHER
IMPACTS
OF
THE
HAZARDOUS
WASTE
COMBUSTION
MACT
FINAL
RULE
STANDARDS
Economics,
Methods,
and
Risk
Analysis
Division
Office
of
Solid
Waste
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Ave,
N.
W.
Washington,
DC
20460
September
2005
TABLE
OF
CONTENTS
INTRODUCTION
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1
MAJOR
CHANGES
REFLECTED
IN
THE
ADDENDUM
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1
Changes
to
the
Standards
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1
Changes
to
the
Regulatory
Baseline
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3
Waste
Quantity
Estimates
Based
on
2003
BRS
Data
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6
BASELINE
PROFITABILITY
ANALYSIS
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9
REVISED
COST
AND
BENEFIT
ESTIMATES
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12
Revised
Cost
Analysis
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12
Revised
Economic
Impact
Estimates
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16
Revised
Benefits
Analysis
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18
EQUITY
CONSIDERATIONS
AND
OTHER
IMPACTS
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27
Assessment
of
Small
Entity
Impacts
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27
Children's
Health
Protection
Analysis
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29
Energy
Impact
Analysis
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29
COST
EFFECTIVENESS
ANALYSIS
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30
APPENDICES
Appendix:
Detailed
Cost
Model
Results
REVIEW
DRAFT
1
INTRODUCTION
The
purpose
of
this
Addendum
is
to
present
a
revised
analysis
of
the
costs
and
benefits
of
the
hazardous
waste
combustion
(
HWC)
maximum
achievable
control
technology
(
MACT)
final
standards.
This
analysis
reflects
EPA's
revisions
to
the
regulatory
baseline
and
to
several
of
the
final
standards
for
liquid
boilers
and
incinerators
as
evaluated
in
the
Assessment
of
the
Potential
Costs,
Benefits,
and
Other
Impacts
of
the
Hazardous
Waste
Combustion
MACT
Final
Rule
Standards
(
the
Assessment).
In
addition,
this
Addendum
incorporates
2003
waste
quantity
and
composition
data
from
EPA's
Biennial
Reporting
System
(
BRS)
into
the
Agency's
revised
cost
and
economic
impact
analysis.

The
Addendum
is
organized
into
five
sections.
In
the
first
section
we
discuss
the
major
changes
reflected
in
this
document,
including
the
changes
to
the
final
standards
and
to
the
regulatory
baseline,
as
well
as
the
rationale
for
these
changes.
This
section
also
provides
revised
waste
quantity
estimates
based
on
2003
BRS
data.
The
second
section
presents
revised
estimates
of
hazardous
waste
combustion
systems'
baseline
profitability.
The
third
section
provides
revised
cost
and
benefit
estimates
and
summarizes
major
changes
in
economic
impacts
relative
to
estimates
presented
in
the
Assessment.
In
the
fourth
section,
we
discuss
the
equity
impacts
of
the
final
standards
and
other
pertinent
regulatory
concerns.
We
conclude
the
Addendum
with
a
presentation
of
revised
costeffectiveness
estimates.

MAJOR
CHANGES
REFLECTED
IN
THE
ADDENDUM
This
Addendum
provides
results
that
reflect
Agency
revisions
to
the
standards
and
to
the
regulatory
baseline,
as
well
as
updated
(
2003)
waste
quantity
information
from
EPA's
Biennial
Reporting
System
(
BRS).
We
discuss
the
nature
and
rationale
for
these
changes
below.

Changes
to
the
Standards
EPA
is
modifying
the
liquid
boiler
standards
for
chlorine,
mercury,
semi­
volatile
metals
(
SVM),
and
low­
volatile
metals
(
LVM)
and
the
incinerator
standards
for
dioxin
and
SVM
to
ensure
that
the
final
standards
are
consistent
with
Clean
Air
Act
Amendments
of
1990.
Exhibit
1
presents
the
previous
and
updated
versions
of
these
standards.
REVIEW
DRAFT
2
Exhibit
1
UPDATED
AND
PREVIOUS
MACT
STANDARDS
FOR
CHLORINE,
MERCURY,
SVM,
LVM,
AND
DIOXIN
MACT
Liquid
Boilers
Incinerators
Updated
TCl
Standards
5.08E­
2lb/
MMBtu
or
31
ppmv;
depending
on
BTU
content
of
hazardous
waste
32
ppmv
Previous
TCl
Standards
Facility
chooses
between
6.65E­
2
lbs/
MMBtu
and
34
ppmv
32
ppmv
Updated
Mercury
Standards
4.2E­
5lb/
MMBtu
or
19
ug/
dscm;
depending
on
BTU
content
of
hazardous
waste
130
ug/
dscm
Previous
Mercury
Standards
Facility
chooses
between
1.5E­
5
lbs/
MMBtu
and
10
ug/
dscm
130
ug/
dscm
Updated
SVM
Standards
8.2
E­
5
lb/
MMBtu
or
146
ug/
dscm;
depending
on
BTU
content
of
hazardous
waste
230
ug/
dscm
Previous
SVM
Standards
Facility
chooses
between
2.5E­
5
lb/
MMBtu
and
26
ug/
dscm
200
ug/
dscm
Updated
LVM
Standards
1.26E­
4
lb/
MMBtu
or
370
ug/
dscm;
depending
on
BTU
content
of
hazardous
waste
92
ug/
dscm
Previous
LVM
Standards
Facility
chooses
between
1.6E­
4
lb/
MMBtu
and
160
ug/
dscm
92
ug/
dscm
Updated
Dioxin
Standards
0.40
ng
TEQ/
dscm
for
dry
APCD
sources;
CO
or
HC
and
DRE
standard
as
surrogate
for
others
0.20
ng
TEQ/
dscm
or
0.40
ng
TEQ/
dscm
and
temperature
control
<
400
°
F
at
APCD
inlet
for
dry
APCDs
or
WHB;
0.40
ng
TEQ/
dscm
for
others.

Previous
Dioxin
Standards
0.40
ng
TEQ/
dscm
for
dry
APCD
sources;
CO
or
HC
and
DRE
standard
as
surrogate
for
others
0.30
ng
TEQ/
dscm
for
dry
APCDs
or
WHBs;
0.20
ng
TEQ/
dscm
if
APCD>
400
°
F;
0.40
ng
TEQ/
dscm
for
others.
REVIEW
DRAFT
1
A
more
complete
explanation
of
EPA's
methodology
for
estimating
baseline
emissions
is
presented
in
U.
S.
EPA,
Technical
Support
Document
for
the
HWC
MACT
Standards,
Volume
V:
Emission
Estimates
and
Engineering
Costs,
September
2005.

3
Revised
Liquid
Boiler
Standards
Under
the
revised
version
of
the
final
standards,
liquid
boilers
must
comply
with
either
a
thermal­
based
emissions
standard
or
an
emissions­
based
standard,
depending
upon
the
heating
value
of
the
waste
combusted
by
the
system.
A
thermal­
based
emissions
standard
would
require
systems
to
limit
hazardous
air
pollutant
emissions
per
million
Btu
of
waste
feed,
whereas
an
emissions­
based
standard
would
require
systems
to
limit
HAP
concentrations
per
unit
of
emissions.
Systems
that
burn
high­
Btu
waste
(
i.
e.,
greater
than
or
equal
to
10,000
Btu
per
pound)
are
required
to
comply
with
the
thermal­
based
emissions
standards
for
total
chlorine,
mercury,
SVM,
and
LVM,
while
systems
with
low­
Btu
waste
(
i.
e.,
less
than
10,000
Btu
per
pound)
must
comply
with
an
emissions­
based
standard.

Revised
Incinerator
Standards
As
shown
in
Exhibit
1,
EPA
has
revised
the
final
incinerator
standards
for
dioxin
and
SVM.
Under
the
revised
SVM
standard,
incinerators
are
required
to
limit
SVM
emissions
to
230
ug/
dscm,
compared
to
the
200
ug/
dscm
standard
analyzed
in
the
Assessment.
For
dioxin,
incinerators
with
a
waste
heat
boiler
(
WHB)
or
a
dry
air
pollution
control
device
(
APCD)
may
now
choose
between
limiting
emissions
to
0.20
nanograms
(
ng)
TEQ/
dscm
or
limiting
emissions
to
0.40
ng
TEQ/
dscm
while
simultaneously
maintaining
an
air
temperature
of
less
than
400
degrees
Fahrenheit
at
the
APCD
inlet.
Other
incinerators
are
required
to
meet
a
standard
of
0.40
ng
TEQ/
dscm.
In
contrast,
under
the
previous
version
of
the
standards,
the
dioxin
standard
would
have
been
0.30
ng
TEQ/
dscm
for
systems
with
dry
APCDs
or
a
WHP,
0.20
ng
TEQ/
dscm
for
systems
with
an
APCD
gas
temperature
exceeding
400
degrees
Fahrenheit,
and
0.40
ng
TEQ/
dscm
for
all
other
systems.

Changes
to
the
Regulatory
Baseline
In
addition
to
revising
the
final
standards,
EPA
has
changed
some
of
its
baseline
emissions
estimates
to
reflect
changes
in
its
characterization
of
several
systems'
emissions
test
data.
EPA's
baseline
emissions
estimates
for
an
individual
system
depend
in
part
on
whether
that
system's
emissions
data
were
collected
during
a
compliance
test
or
through
another
type
of
emissions
test.
To
estimate
baseline
emissions
from
compliance
test
data,
EPA
converts
the
observed
emissions
to
the
desired
units
(
e.
g.,
dry
standard
cubic
meters)
and
performs
few,
if
any,
additional
calculations.
However,
to
estimate
baseline
emissions
from
emissions
data
not
characterized
as
compliance
test
data,
EPA
carried
out
a
number
of
other
calculations.
1
Since
completing
the
baseline
emissions
analysis
reflected
in
the
Assessment,
EPA
has
changed
its
characterization
of
the
test
data
associated
with
a
number
of
systems.
Such
changes
have
affected
the
Agency's
estimates
of
these
systems'
baseline
emissions.

Exhibit
2
presents
revised
estimates
of
baseline
emissions
that
reflect
these
changes
in
REVIEW
DRAFT
4
designation
as
well
as
the
baseline
emissions
estimates
reported
in
the
Assessment.
As
Exhibit
2
indicates,
the
revised
estimates
of
commercial
incinerator
SVM
and
LVM
emissions
are
greater
than
the
estimates
previously
developed
by
the
Agency.
Similarly,
the
Agency
now
estimates
that
cement
kilns
emit
3.04
grams
of
dioxin
in
the
baseline,
compared
to
the
estimate
of
2.93
grams
per
year
presented
in
the
Assessment.
In
contrast,
EPA
has
reduced
its
estimates
of
baseline
dioxin
and
mercury
emissions
for
incinerators
and
its
baseline
estimate
of
LVM
emissions
for
liquid
boilers.
REVIEW
DRAFT
5
Exhibit
2
BASELINE
EMISSIONS
SUMMARY
­
HWC
MACT
FINAL
STANDARDS
Cement
Kilns
LWAKs
Commercial
Incinerators
On­
site
Incinerators
Liquid
Boilers
Coal
Boilers
HCl
Production
Furnaces
TOTAL*

Dioxins/

Furans
(
g/
yr)
Revised
Estimate
3.04
1.10
0.46
0.74
1.39
0.94
0.25
7.91
Assessment
Estimate
2.93
1.10
0.58
0.91
1.39
0.94
0.25
8.10
Particulate
Matter
(
tons/
year)
Revised
Estimate
720.20
21.40
34.34
75.61
2,540.18
886.97
27.53
4,306.23
Assessment
Estimate
720.20
21.40
34.34
75.61
2,540.18
886.97
27.53
4,306.23
Mercury
(
tons/
year)
Revised
Estimate
2.24
0.06
0.17
0.18
0.23
0.08
0.00
2.97
Assessment
Estimate
2.24
0.06
0.24
0.23
0.23
0.08
0.00
3.09
Semi­
Volatile
Metals
(
tons/
year)
Revised
Estimate
3.03
0.05
0.52
0.65
1.94
1.12
0.02
7.32
Assessment
Estimate
3.03
0.05
0.50
0.65
1.94
1.12
0.02
7.30
Low­
Volatile
Metals
(
tons/
year)
Revised
Estimate
0.24
0.03
0.19
0.28
9.44
1.48
0.05
11.71
Assessment
Estimate
0.24
0.03
0.15
0.28
13.14
1.48
0.05
15.37
Chlorine
(
tons/
year)
Revised
Estimate
1,538.98
409.15
81.82
343.06
3,109.67
1,980.80
149.81
7,613.29
Assessment
Estimate
1,538.98
409.15
81.82
343.06
3,109.67
1,980.80
149.81
7,613.29
*
Does
not
include
non­
enumerated
metals
captured
through
PM
control.
REVIEW
DRAFT
2
Using
2003
BRS
data
and
estimates
of
permitted
hazardous
waste
feed
rates
for
each
facility,
we
performed
two
regression
analyses
specific
to
individual
types
of
facilities
to
estimate
hazardous
waste
quantities
as
a
function
of
permitted
hazardous
waste
feed
rates.
The
incinerator
regression
analysis
yielded
a
statistically
significant
coefficient
value
of
0.815
with
a
standard
error
of
0.175
(
95
percent
confidence
interval
of
0.463
to
1.167).
Our
regression
analysis
for
energy
recovery
facilities
(
i.
e.,
boilers
and
kilns)
generated
a
statistically
significant
coefficient
of
1.177
with
a
standard
error
of
0.141
(
95
percent
confidence
interval
of
0.893
to
1.460).

3Although
we
were
not
able
to
estimate
the
quantity
of
hazardous
waste
burned
at
this
facility,
the
cost
estimates
presented
in
this
Addendum
include
the
costs
likely
to
be
incurred
by
this
facility
6
Waste
Quantity
Estimates
Based
on
2003
BRS
Data
The
cost
and
economic
impact
estimates
presented
in
this
Addendum
reflect
the
quantity
and
characteristics
of
waste
burned
by
hazardous
waste
combustion
systems
in
2003,
as
reported
in
the
2003
BRS.
In
contrast,
the
results
presented
in
the
Assessment,
which
was
completed
before
the
2003
BRS
data
were
available,
are
based
on
waste
quantity
data
from
the
2001
BRS.
The
more
recent
2003
BRS
data
are
more
likely
to
reflect
current
operating
conditions
at
hazardous
waste
combustion
facilities.

Based
on
the
2003
BRS
data,
we
estimate
that
hazardous
waste
combustion
facilities
burned
approximately
3.3
million
tons
of
waste
in
2003
(
Exhibit
3),
approximately
12
percent
less
than
the
3.8
million­
ton
estimate
we
developed
from
the
2001
BRS
data.
On­
site
incinerators
and
cement
kilns
each
burned
approximately
28
percent
of
this
waste,
while
solid­
fuel
and
liquid­
fuel
boilers
combined
managed
roughly
26
percent.
Commercial
incinerators
accounted
for
slightly
more
than
13
percent
of
the
waste
burned
in
2003
and
LWAKs
and
HCl
production
furnaces
each
burned
approximately
two
percent.
Although
cement
kilns,
commercial
incinerators,
and
LWAKs
burned
almost
44
percent
of
the
waste
affected
by
the
final
standards,
they
represent
slightly
less
than
19
percent
of
the
facilities
in
the
HWC
MACT
universe.

Of
the
145
facilities
included
in
the
regulatory
universe,
we
use
2003
BRS
waste
quantity
data
to
describe
the
waste
management
activities
of
129
facilities.
The
remaining
16
facilities,
including
nine
liquid
boilers,
four
on­
site
incinerators,
two
HCl
production
furnaces,
and
one
cement
kiln,
provided
incomplete
waste
quantity
data
for
the
2003
BRS.
We
use
2001
BRS
waste
quantity
data
for
five
of
these
facilities
and
1999
BRS
quantities
for
an
additional
five.
For
five
of
the
remaining
six
facilities,
we
estimate
waste
quantities
based
on
the
results
of
a
simple
regression
analysis.
2
Insufficient
information
was
available
to
estimate
the
quantity
of
hazardous
waste
treated
by
the
remaining
facility,
an
on­
site
incinerator
located
in
Texas3.
REVIEW
DRAFT
7
Exhibit
3
QUANTITY
OF
WASTE
TREATED
AS
REPORTED
BY
COMBUSTION
FACILITIES
IN
2003
BRS
Type
of
Combustion
Device
Number
of
Facilities
Percentage
of
Total
Facilitiesb
Waste
Treated
On
Site
(
annual
short
tons)
Percentage
of
Total
Waste
On­
Site
Incinerators
66
45.5%
925,828
28.0%

Cement
Kilns
13
9.0%
924,237
27.9%

Commercial
Incinerators
11
7.6%
447,524
13.5%

LWAKs
3
2.1%
74,839
2.3%

Liquid
Fuel
Boilers
&
Process
Heatersa
53
36.6%
727,198
22.0%

Solid
Fuel
Boilers
4
2.8%
137,882
4.2%

HCl
Production
Furnaces
8
5.5%
79,587
2.4%

Total
145b
100%
3,317,095
100%

Notes:
a
Since
process
heaters
are
subject
to
liquid
fuel
boiler
regulations,
they
are
included
in
this
category.
b
Column
does
not
add
to
total
because
3
facilities
have
more
than
one
type
of
system
and
are
represented
more
than
once.
For
these
facilities,
the
waste
quantity
is
divided
evenly
among
the
types
of
systems
at
each
facility
to
avoid
double
counting.
Sources:
EERGC
Corporation
and
U.
S.
EPA,
Biennial
Reporting
System,
2003.

Waste
Quantities
by
Industry
Exhibit
4
presents
waste
quantity
estimates
for
individual
industries
that
burn
hazardous
waste.
As
Exhibit
4
indicates,
the
chemical
industry
manages
approximately
58
percent
of
the
hazardous
waste
combusted
in
the
U.
S.
 
more
than
all
the
other
industries
combined.
The
second
most
significant
industry
with
respect
to
the
management
of
combusted
hazardous
waste
is
the
waste
management
and
remediation
sector,
which
manages
approximately
21
percent
of
the
hazardous
waste
combusted
in
the
U.
S..
In
addition,
the
petroleum
/
coal
products
and
mining
industries
each
account
for
roughly
five
percent
of
the
waste
affected
by
the
final
standards.
REVIEW
DRAFT
8
Exhibit
4
2003
WASTE
QUANTITIES
BY
MANAGING
INDUSTRY
Industry
Subsector
(
NAICS
Code)
Number
of
Facilities
Waste
Treated
(
short
tons)
Percentage
of
Total
Waste
Treated
325:
Chemical
Manufacturing
102
1,928,148
58.13%

562:
Waste
Management
and
Remediation
Services
15
688,190
20.75%

324:
Petroleum
and
Coal
Products
Manufacturing
3
171,523
5.17%

212:
Mining
(
Except
Oil
and
Gas)
3
165,914
5.00%

327:
Nonmetallic
Mineral
Product
Manufacturing
10
120,743
3.64%

928:
National
Security
2
117,044
3.53%

326:
Plastics
and
Rubber
Products
Manufacturing
3
46,839
1.41%

541:
Professional,
Scientific,
and
Technical
Services
1
40,215
1.21%

339:
Miscellaneous
Manufacturing
2
34,608
1.04%

332:
Fabricated
Metal
Product
Manufacturing
2
2,389
0.07%

424:
Merchant
Wholesalers,
Nondurable
Goods
1
698
0.02%

TOTALa
144
3,316,311
100%

Notes:
a
Fifteen
facilities
did
not
report
NAICS
codes
in
the
2003
BRS.
For
14
of
these
facilities,
we
used
2001
BRS
NAICS
codes
to
determine
the
appropriate
industry
sector.
One
facility,
TX000020202,
did
not
report
a
NAICS
code
in
the
2003
or
the
2001
BRS.
Therefore,
the
waste
quantities
presented
in
this
exhibit
do
not
total
to
3,317,095
and
the
number
of
facilities
reflected
in
this
exhibit
is
144,
rather
than
145.

Sources:
U.
S.
EPA
Biennial
Reporting
System,
2001
and
2003
Waste
Forms
As
outlined
in
the
Assessment,
hazardous
waste
pricing
varies
significantly
by
waste
form.
Exhibit
5
presents
waste
quantity
estimates
by
waste
form
as
reflected
in
the
2003
BRS.
As
Exhibit
5
illustrates,
76
percent
of
the
total
waste
treated
by
hazardous
waste
combustion
facilities
is
liquid.
Of
the
remaining
24
percent,
solids
account
for
14
percent,
sludges
10
percent,
and
gases
and
lab
packs
less
than
one
percent
combined.
Approximately
94
percent
of
the
facilities
in
the
universe
burn
fuel­
grade
waste,
most
of
which
is
liquid.

Non­
liquid
wastes
managed
by
systems
in
the
HWC
MACT
universe
include
lab
packs
(
i.
e.,
small
containers
of
hazardous
waste
packaged
together
in
a
larger
drum),
sludges,
solids,
and
gaseous
waste.
These
wastes
are
often
highly
contaminated
and
tend
to
have
limited
to
no
fuel
value.
As
a
REVIEW
DRAFT
4
Similar
to
the
baseline
profitability
analysis
presented
in
the
Assessment,
we
do
not
assess
the
baseline
profitability
of
boilers
and
HCl
production
furnaces
because
we
assume
that
these
systems
will
continue
to
burn
9
Exhibit
5
QUANTITY
OF
WASTE
COMBUSTION
IN
2003
(
SHORT
TONS)
BY
WASTE
FORM
TOTAL:
3,317,095
short
tons
Sludges
335,356
10%
Lab
Packs
12,119
0.37%

Organic
Liquids
2,162,238
65%
Gases
2,614
0.08%
Inorganic
Liquids
350,891
11%
Solids
453,877
14%

result,
on­
site
and
commercial
incinerators
generally
burn
these
wastes.

BASELINE
PROFITABILITY
ANALYSIS
As
described
in
Chapter
3
of
the
Assessment,
an
important
aspect
of
accurately
assessing
the
costs
and
economic
impacts
associated
with
the
final
standards
is
determining
which
systems
are
likely
to
close
in
the
baseline.
Because
this
depends
on
the
baseline
profitability
of
individual
combustion
systems,
we
have
updated
our
analysis
of
each
system's
baseline
operating
profits
to
reflect
waste
data
from
the
2003
BRS.
4
The
quantity
of
waste
that
a
system
manages
and
the
REVIEW
DRAFT
hazardous
waste,
regardless
of
market
conditions.

5
The
baseline
profitability
estimates
presented
in
this
Addendum
reflect
the
hazardous
waste
combustion
pricing
presented
in
Exhibit
3­
2
of
the
Assessment.

10
characteristics
of
this
waste
can
significantly
affect
the
profitability
of
a
system's
hazardous
waste
combustion
activities.
Therefore,
to
the
extent
that
the
2003
BRS
data
differ
from
the
2001
BRS
data,
our
updated
estimates
of
baseline
profitability
may
differ
from
the
corresponding
estimates
presented
in
the
Assessment.

Exhibit
6
presents
our
updated
estimates
of
mean
and
median
profitability
per
system
for
cement
kilns/
LWAKs,
commercial
incinerators,
and
on­
site
incinerators.
5
As
Exhibit
6
indicates,
mean
and
median
profits
for
commercial
incinerators
are
$
12.6
million
and
$
11.2
million
respectively,
both
of
which
are
lower
than
the
corresponding
estimates
presented
in
the
Assessment.
This
decline
in
commercial
incinerator
profitability
reflects
the
fact
that
these
systems
managed
less
waste
in
2003
than
in
2001.

Exhibit
6
MEAN
AND
MEDIAN
ANNUAL
OPERATING
PROFITS
PER
SYSTEM
IN
THE
BASELINE
Source
Category
Mean
Profits
per
System
Median
Profits
per
System
Cement
Kilns/
LWAKsa,
b,
c
$
9,688,000­$
24,074,000
$
9,383,000­$
11,673,000
Commercial
Incinerators
$
12,624,000
$
11,241,000
On­
site
Incineratorsa,
d,
e
$
1,331,000
$
213,000
Notes:
a.
Estimated
profits
for
on­
site
incinerators,
cement
kilns,
and
LWAKs
are
based
only
on
combustion
activities
at
these
facilities.
Profits
associated
with
sales
of
cement
and
other
products
are
not
included.
b.
Cement
kiln
and
LWAK
profits
include
avoided
fuel
costs
associated
with
hazardous
waste
that
they
burn.
c.
The
range
in
cement
kiln
and
LWAK
profits
reflects
uncertainty
about
the
prices
these
facilities
charge
to
accept
different
waste
forms.
The
high­
end
of
the
range
assumes
that
cement
kilns/
LWAKs
receive
approximately
$
774
per
ton
on
average.
The
low­
end
estimate
assumes
they
receive
$
320
per
ton
on
average.
d.
Average
profits
for
on­
site
incinerators
are
based
on
systems
for
which
baseline
capital
cost
data
are
available.
e.
Average
on­
site
incinerator
profits
include
the
transportation
costs
they
avoid
by
treating
waste
on
site.

For
on­
site
incinerators,
we
now
estimate
mean
and
median
profits
per
system
of
$
1,331,000
and
$
213,000
respectively.
While
our
estimated
mean
value
is
less
than
the
corresponding
estimate
presented
in
the
Assessment,
median
profits
per
system
are
significantly
higher
when
using
the
2003
BRS
data
instead
of
the
2001
BRS.
The
change
in
mean
profits
per
system
reflects
the
decline
in
the
volume
of
waste
managed
by
on­
site
incinerators
between
2001
and
2003,
and
the
change
in
median
profits
per
system
reflects
specific
waste
quantity
and
composition
changes
at
individual
facilities.

Similar
to
the
cement
kiln/
LWAK
profitability
estimates
included
in
the
Assessment,
we
REVIEW
DRAFT
6
Chapter
3
of
the
Assessment
presents
additional
information
on
this
uncertainty.

7
The
derivation
of
this
11.9
percent
value
is
presented
in
Chapter
3
of
the
Assessment.

11
present
cement
kiln/
LWAK
profitability
as
a
range
in
Exhibit
6
to
reflect
uncertainty
in
the
prices
charged
by
these
facilities.
6
For
the
high
end
of
this
range,
we
assume
that
cement
kilns
and
LWAKs
charge
the
same
prices
as
commercial
incinerators,
and
for
the
low­
end
we
assume
that
the
premium
that
cement
kilns
and
LWAKs
charge
for
halogenated
waste
(
i.
e.,
the
difference
in
price
between
halogenated
and
non­
halogenated
waste)
is
approximately
11.9
percent
of
the
premium
charged
by
commercial
incinerators.
7
Based
on
this
approach,
we
now
estimate
a
wider
range
of
mean
cement
kiln/
LWAK
per
system
profits
than
presented
in
the
Assessment
and
a
narrower
range
for
median
profits
per
system.
These
changes
do
not
reflect
a
specific
pattern
among
cement
kiln/
LWAK
systems
but
instead
reflect
changes
in
the
quantity
and
composition
of
waste
managed
by
individual
systems.

As
indicated
in
Exhibit
7,
most
commercial
combustion
systems
are
adequately
covering
their
baseline
waste­
burning
costs.
We
estimate
that
every
cement
kiln
and
LWAK
system
earns
at
least
$
100
per
ton
through
its
waste­
burning
operations.
However,
our
updated
profitability
analysis
suggests
that
three
commercial
incinerator
systems
may
be
unprofitable
in
the
baseline,
compared
to
the
two
commercial
incinerators
identified
as
potentially
unprofitable
in
the
Assessment.
Although
these
systems
appear
unprofitable,
we
assume
that
they
will
remain
open
in
the
baseline.
The
losses
that
we
estimate
for
these
systems
are
small
relative
to
the
estimated
profits
of
other
commercial
incinerators,
and
for
all
three
of
these
systems,
our
estimates
of
profitability
depend
on
assumptions
about
the
allocation
of
waste
to
individual
systems
within
a
single
facility.
Because
BRS
reports
waste
quantities
at
the
facility
level
rather
than
at
the
system
level,
we
estimated
system
waste
quantities
based
on
the
relative
capacity
of
systems
located
at
the
same
facility.
If
the
three
systems
that
we
identified
as
unprofitable
receive
more
waste
than
we
estimate,
then
our
baseline
profitability
assessment
understates
their
revenues
and
profits.

Exhibit
7
BASELINE
OPERATING
PROFITS
PER
TON
OF
HAZARDOUS
WASTE
BURNED
(
Number
of
Systems
Falling
in
Profit
Range)

<$
0
$
0­$
100
$
100­$
500
$
500­$
1,000
>$
1,000
Cement
Kilns/
LWAKsa,
b
0
0
32­
9
0­
18
0­
5
Commercial
Incinerators
3
0
8
2
2
On­
site
Incineratorsc,
d
9
3
6
2
0
REVIEW
DRAFT
12
a.
Cement
kiln
and
LWAK
profits
per
ton
include
avoided
fuel
costs.
b.
The
range
in
cement
kiln
and
LWAK
estimates
reflect
uncertainty
about
the
prices
these
facilities
charge
to
treat
different
waste
forms.
c.
These
results
show
profits
per
ton
only
for
those
incinerators
for
which
baseline
capital
cost
data
are
available.
d.
On­
site
incinerator
profits
include
savings
associated
with
transportation
costs
avoided
by
treating
waste
on
site.
Note:
See
Appendix
for
system
sector
totals.
REVIEW
DRAFT
13
REVISED
COST
AND
BENEFIT
ESTIMATES
The
cost
and
benefit
estimates
presented
in
this
document
are
consistent
with
the
analytical
framework
described
in
Chapters
4,
5,
and
6
of
the
Assessment.
Detailed
model
results
are
included
in
the
Appendix
to
this
Addendum.
Additional
information
on
the
economic
model
used
to
develop
our
cost
estimates
is
available
in
Appendix
D
of
the
Assessment.

Major
findings
of
the
current
analysis
are
as
follows:

°
The
engineering
costs
of
the
Final
Rule
Standards
are
now
estimated
to
be
$
40.7
million
per
year,
6.4
percent
less
than
the
corresponding
estimate
presented
in
the
Assessment.

°
We
estimate
that
the
market­
adjusted
costs
of
the
Final
Rule
Standards
will
be
approximately
$
22.6
million
per
year,
approximately
17.8
percent
lower
than
the
$
27.5
million
estimate
presented
in
the
Assessment.

°
Among
the
different
types
of
combustion
systems
affected
by
the
final
standards,
liquid
boilers
are
expected
to
incur
the
highest
costs.
Marketadjusted
costs
for
these
systems
under
the
Final
Rule
Standards
are
estimated
to
be
$
29.3
million,
while
estimated
engineering
costs
for
these
systems
are
$
31.4
million.

°
Under
the
revised
version
of
the
final
standards,
we
expect
39
market
exits
and
the
reallocation
of
nearly
59,000
tons
of
waste
to
other
systems,
compared
to
the
36
market
exits
and
47,100­
ton
reallocation
of
waste
estimated
in
the
Assessment.
This
apparent
shift
toward
greater
offsite
management
reflects
the
decline
in
the
volume
of
waste
combusted
by
many
systems
between
2001
and
2003.
As
waste
quantities
fall
for
individual
systems,
their
potential
offsite
disposal
costs
also
decline.

°
We
estimate
total,
non­
discounted
benefits
ranging
from
$
6.48
million
to
$
12.93
million
per
year
for
the
Final
Rule
Standards,
just
$
0.02
million
less
than
estimated
in
the
Assessment.

Revised
Cost
Analysis
Exhibit
8
presents
our
estimates
of
the
engineering
and
market­
adjusted
costs
associated
with
the
revised
standards.
The
market­
adjusted
costs
included
in
this
exhibit
reflect
a
100
percent
cost
pass­
through,
consistent
with
the
principal
market­
adjusted
costs
presented
in
Exhibit
5­
5
of
the
Assessment.
These
estimates
also
reflect
updated
waste
quantity
data
for
each
facility,
as
reported
in
the
2003
BRS.
Under
the
revised
version
of
the
Final
Rule
Standards,
total
costs
are
expected
to
be
lower
than
the
costs
of
the
previous
version
of
the
final
standards
included
in
the
Assessment.
The
engineering
costs
of
the
Final
Rule
Standards
are
now
estimated
to
be
$
40.7
million
per
year,
REVIEW
DRAFT
8
Although
we
have
updated
our
analysis
to
reflect
waste
quantity
data
from
the
2003
BRS,
this
change
does
not
affect
our
engineering
cost
estimates,
which
are
not
based
on
BRS
data.

9
Consistent
with
the
estimates
presented
in
the
Assessment,
our
updated
estimates
of
average
engineering
costs
per
system
reflect
costs
associated
with
system
upgrades
but
not
with
administrative
requirements
associated
with
the
final
standards
(
e.
g.,
performance
tests
and
record
keeping).

14
compared
to
the
$
43.5
million
estimate
presented
in
the
Assessment.
Similarly,
we
estimate
that
the
total
social
costs
of
the
Final
Rule
Standards
will
be
approximately
$
22.6
million
per
year,
whereas
we
had
previously
estimated
social
costs
of
$
27.5
million
per
year
for
the
version
of
the
final
standards
included
in
the
Assessment.
These
results
reflect
EPA's
decision
to
allow
all
facilities,
except
for
HCl
production
furnaces,
to
choose
between
technology­
based
emissions
limits
for
chlorine
and
site­
specific,
risk­
based
chlorine
emissions
standards.
In
developing
the
final
standards,
however,
EPA
considered
versions
of
the
standards
that
would
require
all
facilities
to
comply
with
the
technology­
based
emissions
limits.
The
costs
and
economic
impacts
of
these
regulatory
alternatives
are
presented
in
the
Appendix
to
this
Addendum.

Engineering
Costs
Annualized
engineering
costs
associated
with
the
four
options
presented
in
this
document
range
from
$
39.4
million
per
year
under
the
Primary
Floor
Option
to
approximately
$
70.5
million
per
year
under
Alternative
Floor
Option
2.
The
engineering
costs
associated
with
the
revised
Final
Rule
Standards
and
Primary
Floor
Option
are
6.4
and
6.9
percent
lower,
respectively,
than
the
corresponding
estimates
presented
in
the
Assessment.
Because
EPA
has
not
modified
Alternative
Floor
Options
1
and
2,
our
engineering
cost
estimates
for
these
regulatory
options
remain
unchanged
relative
to
those
reported
in
the
Assessment.
8
Average
per­
system
engineering
costs
associated
with
the
revised
Final
Rule
Standards
have
changed
for
commercial
incinerators,
on­
site
incinerators,
and
liquid
boilers.
9
Per­
system
costs
for
commercial
incinerators
are
now
$
12,300,
which
represents
a
78
percent
reduction
compared
to
the
estimate
of
$
55,400
per
system
presented
in
the
Assessment.
In
addition,
under
the
revised
Final
Rule
Standards,
we
estimate
per
system
engineering
costs
of
$
10,200
for
on­
site
incinerators,
nearly
30
percent
less
than
the
corresponding
estimate
of
$
14,300
included
in
the
Assessment.
Our
updated
estimate
for
liquid
boilers
B$
256,300
B
has
also
fallen
relative
to
our
previous
estimate
of
$
274,200
per
system.
For
cement
kilns,
LWAKs,
coal
boilers,
and
HCl
production
furnaces,
our
estimates
of
persystem
engineering
costs
are
unchanged.
REVIEW
DRAFT
15
Exhibit
8
SUMMARY
OF
SOCIAL
COST
ESTIMATES
(
millions
of
2002
dollars)

Cement
Kilns
LWAKs
Commercial
Incinerators
On­
site
Incinerators
Liquid
Boilers
Coal
Boilers
HCl
Production
Furnaces
Generators
that
currently
send
waste
to
commercial
facilities
TOTALb
Primary
Floor
Option
Market­
adjusted
Costsa
($
0.1)
($
0.2)
($
14.5)
$
1.5
$
29.2
$
1.3
$
0.6
$
3.6
$
21.9
Engineering
Costs
$
3.1
$
0.1
$
0.4
$
2.0
$
31.3
$
1.4
$
0.6
NA
$
39.4
Final
Rule
Standards
Market­
adjusted
Costsa
($
0.1)
($
0.2)
($
14.5)
$
1.5
$
29.3
$
2.0
$
0.6
$
3.6
$
22.6
Engineering
Costs
$
3.1
$
0.1
$
0.4
$
2.0
$
31.4
$
2.6
$
0.6
NA
$
40.7
Alternative
Floor
Option
1
Market­
adjusted
Costsa
($
0.1)
($
0.5)
($
14.3)
$
4.1
$
30.8
$
1.3
$
0.6
$
9.0
$
31.4
Engineering
Costs
$
6.6
$
0.1
$
2.3
$
5.6
$
32.9
$
1.4
$
0.6
NA
$
50.0
Alternative
Floor
Option
2
Market­
adjusted
Costsa
$
1.6
($
0.5)
($
16.5)
$
3.7
$
41.3
$
1.3
$
0.8
$
18.0
$
50.2
Engineering
Costs
$
14.9
$
0.8
$
2.3
$
4.8
$
45.0
$
1.4
$
0.8
NA
$
70.5
NOTES:

a.
Our
estimates
of
market­
adjusted
costs
assume
that
commercial
facilities
pass
100
percent
of
their
compliance
costs
onto
their
customers
in
the
form
of
higher
prices.

b.
Totals
will
not
add
due
to
rounding.
In
addition,
government
administrative
costs
are
included
in
the
total
social
cost
estimates.
These
costs
range
from
$
451,000
to
$
463,000
per
year
across
all
four
options
under
the
market­
adjusted
scenario.
For
the
engineering
cost
scenario,
under
which
we
assume
all
systems
upgrade,
annual
government
costs
are
approximately
$
503,000.
REVIEW
DRAFT
10
According
to
the
2003
BRS,
the
facility
where
these
two
systems
are
located
burned
approximately
51
tons
of
hazardous
waste
in
2003,
whereas
the
2001
BRS
indicates
that
this
facility
burned
nearly
41,500
tons
of
hazardous
waste
in
2001.

11
Similar
to
cement
kilns,
net
savings
for
LWAKs
may
also
be
lower
due
to
the
relatively
low
increase
in
hazardous
waste
combustion
pricing
under
the
revised
final
standards.
This
impact,
however,
is
not
reflected
in
our
results
because
of
rounding.

16
Social
Costs
Across
the
regulatory
options
considered
in
this
document,
we
estimate
that
market­
adjusted
costs
would
range
from
$
21.9
million
under
the
Primary
Floor
Option
to
$
50.2
million
under
Alternative
Floor
Option
2.
As
indicated
above,
social
costs
expected
under
the
Final
Rule
Standards
are
$
22.6
million
per
year,
approximately
3.2
percent
more
than
the
market­
adjusted
costs
of
the
Primary
Floor
Option
and
44.5
percent
lower
than
the
engineering
costs
associated
with
the
Final
Rule
Standards.

For
on­
site
incinerators,
coal
boilers,
and
liquid
boilers
our
estimates
of
social
costs
for
the
revised
Final
Rule
Standards
are
approximately
17,
23,
and
6
percent
lower,
respectively,
than
the
corresponding
estimates
presented
in
the
Assessment.
Similarly,
our
revised
estimate
of
commercial
incinerator
savings
is
approximately
14
percent
greater
than
estimated
in
the
Assessment.
For
incinerators
and
liquid
boilers,
these
differences
largely
reflect
changes
in
the
standards,
but
we
estimate
lower
costs
for
coal
boilers
because
the
2003
BRS
data
incorporated
into
our
current
analysis
indicate
that
two
coal
boiler
systems
burned
significantly
less
hazardous
waste
in
2003
than
in
2001.10
In
contrast
to
the
lower
costs
and
higher
savings
experienced
by
boilers
and
incinerators,
our
estimate
of
cement
kiln
savings
is
approximately
$
200,000
lower
than
the
estimate
presented
in
the
Assessment.
This
difference
in
savings
largely
reflects
the
lower
increase
in
combustion
pricing
expected
under
the
revised
version
of
the
final
standards
relative
to
increase
estimated
in
the
Assessment.
11
Our
social
cost
estimate
for
HCl
production
furnaces
is
unchanged
relative
to
the
estimate
generated
for
the
Assessment.

Distribution
of
Costs
As
suggested
by
the
results
presented
in
Exhibit
8,
we
expect
that
the
market­
adjusted
costs
of
the
final
standards
will
be
most
significant
for
liquid
boilers,
which
are
expected
to
incur
costs
of
$
29.3
million.
Liquid
boiler
costs
are
likely
to
exceed
the
total
costs
of
the
rule
because
the
standards
result
in
apparent
welfare
gains
for
commercial
facilities
receiving
waste
from
on­
site
facilities
that,
as
a
result
of
the
rule,
stop
burning
hazardous
waste
themselves
and
send
it
offsite.
After
liquid
boilers,
we
expect
market­
adjusted
costs
to
be
greatest
for
generators
that
send
their
waste
to
commercial
facilities
in
the
baseline.
We
estimate
$
3.6
million
in
annual
market­
adjusted
costs
for
these
facilities.
Similar
to
market­
adjusted
costs,
our
estimates
of
engineering
costs
for
the
Final
Rule
Standards
are
most
significant
for
liquid
boilers;
engineering
costs
for
these
systems
represent
77
percent
of
the
total
engineering
costs
associated
with
the
final
rule.
The
concentration
of
marketadjusted
and
engineering
costs
among
liquid
boilers
reflects
the
focus
of
past
regulation
on
REVIEW
DRAFT
12
The
Assessment
presented
economic
impacts
as
a
range
to
reflect
impacts
under
a
principal
analysis
reflecting
a
100
percent
cost
pass­
through
for
commercial
facilities
and
a
sensitivity
analysis
reflecting
zero
cost­
pass
through.
Because
the
economic
impact
estimates
presented
in
this
Addendum
reflect
a
100­
percent
cost
pass­
through
scenario,
we
compare
the
results
presented
in
this
Addendum
to
the
100­
percent
cost
pass­
through
results
reported
in
the
Assessment.

17
incinerators
and
commercial
kilns,
as
the
2002
Interim
Standards
did
not
regulate
liquid
boilers,
coal
boilers,
or
HCl
production
furnaces.
Total
costs
for
the
latter
two
are
relatively
low
compared
to
liquid
boiler
costs
because
liquid
boilers
significantly
outnumber
coal
boilers
and
HCl
production
furnaces.

Revised
Economic
Impact
Estimates
Exhibit
9
presents
EPA's
updated
estimates
of
the
economic
impacts
associated
with
the
Final
Rule
Standards.
These
estimates
reflect
EPA's
changes
to
the
final
standards
since
the
completion
of
the
Assessment
and
the
inclusion
of
the
2003
BRS
waste
quantity
data
in
EPA's
model
of
the
hazardous
waste
combustion
market.
Many
of
the
economic
impact
estimates
presented
in
Exhibit
9
differ
from
the
corresponding
estimates
presented
in
Chapter
5
of
the
Assessment.
12
These
differences
are
as
follows:

Market
Exits:
We
now
estimate
that
three
commercial
incinerator
systems
may
close
in
response
to
the
Final
Rule
Standards,
whereas
we
had
previously
estimated
that
only
two
of
these
systems
would
close.
Based
on
the
updated
waste
quantity
data
in
the
2003
BRS,
we
estimate
that
all
three
of
these
systems
may
be
unprofitable
in
the
baseline.
Therefore,
the
closure
of
these
systems
in
the
near
future
would
not
necessarily
be
attributable
to
the
final
standards.
In
addition,
we
now
expect
three
more
on­
site
incinerator
closures
and
two
more
coal
boiler
closures
under
the
final
standards
than
estimated
in
the
Assessment.
For
liquid
boilers,
we
expect
just
eight
closures
under
the
Final
Rule
Standards,
which
is
three
less
than
previously
estimated.

Waste
Reallocation:
Based
on
the
changes
to
the
standards
and
the
updated
waste
quantity
data
in
the
2003
BRS,
we
estimate
that
approximately
58,900
tons
of
hazardous
waste
will
be
reallocated
as
the
result
of
system
closures
(
i.
e.,
sent
to
a
commercial
facility
or
consolidated
to
another
system
at
the
same
facility),
approximately
25
percent
more
than
the
estimate
of
47,100
tons
presented
in
the
Assessment.

Employment
Impacts:
Under
the
revised
version
of
the
Final
Rule
Standards,
we
expect
employment
gains
of
323
full­
time
equivalents
(
FTEs),
27
fewer
FTEs
than
previously
estimated.
This
decline
in
employment
gains
is
consistent
with
our
updated
cost
estimates,
which
are
lower
than
those
presented
in
the
Assessment.
This
reduction
in
costs
implies
that
facilities
will
use
fewer
labor
resources
to
comply
with
the
final
standards
than
previously
estimated.
In
contrast
to
this
decline
in
employment
gains,
we
expect
45
more
employment
dislocations
under
the
revised
final
standards
REVIEW
DRAFT
18
than
under
the
previous
version
of
the
standards.
This
reflects
the
greater
number
of
market
exits
that
we
currently
expect
relative
to
the
market
exit
estimate
presented
in
the
Assessment.

Combustion
Prices:
We
now
estimate
that
hazardous
waste
combustion
prices
may
increase
by
approximately
0.3
percent
as
a
result
of
the
Final
Rule
Standards,
compared
to
the
projected
0.4
percent
increase
reported
in
the
Assessment.

Other
Industry
Impacts:
Under
the
revised
version
of
the
Final
Rule
Standards,
several
of
our
estimates
of
other
industry
impacts
(
e.
g.,
changes
in
the
profitability
and
cost
structure
of
the
combustion
industry)
are
different
than
previously
estimated
in
the
Assessment.
We
now
estimate
that
the
final
standards
will
increase
commercial
incinerator
profits
by
10.4
percent,
compared
to
the
6.7
percent
increase
presented
in
the
Assessment.
The
profitability
of
cement
kiln
hazardous
waste
burning
operations
is
not
likely
to
change
significantly.
However,
we
expect
waste
burning
profits
for
LWAKs
to
increase
by
0.3
percent
instead
of
the
0.4
percent
increase
expected
under
the
previous
version
of
the
final
standards.
Related
to
these
changes
in
profitability,
we
estimate
that
the
revised
version
of
the
final
standards
will
increase
waste
burning
costs
by
5.4
percent,
1.1
percent,
and
0.4
percent
for
cement
kilns,
LWAKs,
and
commercial
incinerators
respectively.
We
previously
estimated
increases
of
5.1
percent,
1.2
percent,
and
0.9
percent
for
these
respective
groups.
REVIEW
DRAFT
19
Exhibit
9
SUMMARY
OF
ECONOMIC
IMPACT
ANALYSISa
Economic
Impact
Measure
MACT
Final
Rule
Standards
And
Alternative
Options
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Market
Exits
(
systems)

Cement
Kilns
0
0
0
0
Commercial
Incinerators
3
3
3
3
LWAKs
0
0
0
0
On­
Site
Incineratorsa
26
26
26
26
Liquid
Boilers
8
8
7
11
Coal
Boilersa
2
2
2
2
HCl
Production
Furnaces
0
0
0
0
Quantity
of
Waste
Reallocateda
(
U.
S.
tons)
58,900
58,900
58,400
59,900
Employment
Impacts
Annual
Gainsa
317
323
399
559
Annual
Dislocationsa
310
310
305
325
Expected
Combustion
Price
Change
0.3%
0.3%
0.9%
1.7%

Notes:
a.
Estimates
reflect
market­
adjusted
scenario
under
which
commercial
facilities
pass
100
percent
of
their
compliance
costs
onto
their
customers.

Revised
Benefits
Analysis
This
section
presents
estimates
of
the
health
and
visibility
benefits
associated
with
the
emissions
reductions
expected
under
the
revised
version
of
the
final
standards.
Exhibit
10
summarizes
these
expected
emissions
reductions.
In
general
these
reductions
are
the
same
as
those
presented
in
the
Assessment.
However,
we
now
estimate
that
emissions
of
SVM/
LVM
and
dioxin
will
decline
by
9.4
tons
and
0.2
grams
per
year,
respectively,
under
the
Final
Rule
Standards.
For
the
Assessment
we
had
previously
estimated
an
SVM/
LVM
emissions
reduction
of
12.3
tons
per
year
and
a
dioxin
emissions
reduction
of
0.4
grams
per
year.
These
differences
reflect
changes
in
the
liquid
boiler
standards
for
SVM
and
LVM
and
changes
in
the
incinerator
standard
for
dioxin.
REVIEW
DRAFT
20
Exhibit
10
ANNUAL
EMISSIONS
REDUCTIONS
FOR
THE
FINAL
HWC
MACT
STANDARDS
Standard
Particulate
Matter
(
tons/
yr)
Mercury
(
tons/
yr)
SVM/
LVM
(
tons/
yr)
Dioxins/
Furans
(
grams/
yr)
Chlorine
(
tons/
yr)

Final
Rule
Standards
2,138
0.2
9.4
0.2
107
Primary
Floor
Option
1,669
0.2
8.6
0.14
107
Alternative
Floor
Option
1
1,669
0.2
12.0
0.3
107
Alternative
Floor
Option
2
3,005
0.6
18.6
0.3
127
1999
Standards
2,449
3.9
97.1
28.7
5,132
Source:
EERGC,
Inc.,
June,
2005.

Exhibits
11
through
14
present
the
human
health
and
visibility
benefits
expected
under
the
Final
Rule
Standards,
the
Primary
Floor
Option,
Alternative
Floor
Option
1,
and
Alternative
Floor
Option
2.
The
estimates
included
in
these
exhibits
are
consistent
with
the
analytic
methods
outlined
in
Chapter
6
of
the
Assessment.
As
Exhibit
12
indicates,
the
total
non­
discounted
benefits
associated
with
the
revised
version
of
the
Final
Rule
Standards
are
expected
to
range
from
$
6.48
million
to
$
12.93
million,
just
$
0.02
million
less
than
estimated
in
the
Assessment.
This
relatively
small
difference
in
benefits
reflects
the
nature
of
EPA's
changes
to
the
final
standards.
Although
EPA
altered
the
standards
for
dioxin,
the
standards
for
PM,
which
is
the
more
significant
of
the
two
pollutants
with
respect
to
benefits,
are
unchanged.
Therefore,
despite
the
changes
in
the
final
dioxin
standards,
our
estimates
of
total
benefits
are
nearly
the
same
as
those
presented
in
the
Assessment.
REVIEW
DRAFT
13
These
estimates
are
derived
from
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005,
Table
4­
11.
We
adjust
the
values
presented
in
this
document
to
develop
VSL
estimates
consistent
with
personal
income
in
2005.
Additional
information
on
our
derivation
of
VSL
values
is
presented
in
Chapter
6
of
the
Assessment.

21
Exhibit
11
HUMAN
HEALTH
BENEFITS
SUMMARY:
REDUCED
INCIDENCE
OF
ADVERSE
HEALTH
EFFECTS
Type
of
Benefit
Final
Rule
Standards
Primary
Floor
Option
Alternative
Floor
Option
1
Alternative
Floor
Option
2
PM­
related
Health
Benefits
Premature
mortality
0.46
0.455
0.45
0.75
Respiratory
Illness
Hospital
Admissions
1.21
1.20
1.20
1.97
Cardiovascular
Disease
Hospital
Admissions
0.53
0.52
0.52
0.87
Chronic
Bronchitis
7.70
7.65
7.65
12.54
Acute
Bronchitis
5.86
5.81
5.81
9.60
Lower
Respiratory
Symptoms
51.95
51.53
51.53
85.15
Upper
Respiratory
Symptoms
6.02
5.98
5.98
9.88
Minor
Restricted
Activity
Days
5,142
5,103
5,103
8,391
Work
Loss
Days
617
613
613
1,007
Dioxin­
related
Health
Benefits
Dioxin­
related
cancer
deaths
0.002
0.002
0.004
0.004
PM­
related
Benefits
As
indicated
in
Exhibit
11,
the
PM
standards
under
the
Final
Rule
Standards
are
expected
to
reduce
premature
mortality
by
less
than
one
case
per
year.
In
addition,
the
Final
Rule
Standards
are
expected
to
reduce
the
incidence
of
chronic
bronchitis
by
7.7
cases
per
year
and
hospital
admissions
associated
with
cardiovascular
disease
or
respiratory
illness
by
1.74
cases
per
year.
These
and
other
human
health
benefits
related
to
reduced
PM
exposure
are
valued
at
$
5.61
million
to
$
6.29
million
per
year
under
the
Final
Rule
Standards,
depending
on
discounting
assumptions.
The
mortality
benefits
reflected
in
these
estimates
are
uncertain,
as
the
value
of
a
statistical
life
may
be
as
low
as
$
1.1
million
or
as
high
as
$
11.4
million.
13
Under
these
alternative
VSL
values,
benefits
associated
with
avoided
mortality
range
from
$
0.40
million
($
1.1
million
VSL,
7
percent
discount
rate)
to
$
5.21
million
($
11.4
million
VSL,
benefits
not
discounted).
In
addition
to
these
public
health
benefits,
we
estimate
that
the
final
PM
standards
will
yield
visibility
benefits
ranging
from
$
0.18
million
to
$
6.63
million
per
year.
As
indicated
above,
the
PM­
related
benefits
presented
in
Exhibits
12
through
14
are
exactly
the
same
as
those
presented
in
the
Assessment.
Chapter
6
of
the
Assessment
contains
additional
information
on
these
benefits.
REVIEW
DRAFT
22
Exhibit
12
MONETIZED
BENEFITS
SUMMARY:
BASELINE
TO
FINAL
RULE
STANDARDS
Type
of
Benefit
Avoided
Cases
per
Year
Annual
Nondiscounted
Value
(
millions
of
2002
dollars)
Annual
Discounted
Value
­
3
Percent
Discount
Rate
(
millions
of
2002
dollars)
Annual
Discounted
Value
­
7
Percent
Discount
Rate
(
millions
of
2002
dollars)
PM­
related
Health
Benefits
Premature
mortalitya
0.46
$
2.87
$
2.52
$
2.19
($
0.52­$
5.21)
($
0.46­$
4.58)
($
0.40­$
3.97)

Respiratory
Illness
Hospital
Admissions
1.21
$
0.01
$
0.01
$
0.01
Cardiovascular
Disease
Hospital
Admissions
0.53
$
0.01
$
0.01
$
0.01
Chronic
Bronchitis
7.70
$
3.03
$
3.03
$
3.03
Acute
Bronchitis
5.86
$
0.00
$
0.00
$
0.00
Lower
Respiratory
Symptoms
51.95
$
0.00
$
0.00
$
0.00
Upper
Respiratory
Symptoms
6.02
$
0.00
$
0.00
$
0.00
Minor
Restricted
Activity
Days
5,142
$
0.29
$
0.29
$
0.29
Work
Loss
Days
617
$
0.08
$
0.08
$
0.08
Total
PM
Health
Benefits
$
6.29
$
5.95
$
5.61
Dioxin­
related
Health
Benefits
Total
dioxin­
related
cancer
deathsb
0.002
$
0.02
$
0.01c
$
0.00c
($
0.00­$
0.03)
a
($
0.00­$
0.02)
d
($
0.00­$
0.01)
d
TOTAL
HUMAN
HEALTH
BENEFITS
$
6.31
$
5.95
$
5.61
Visibility
Benefits
TOTAL
VISIBILITY
BENEFITS
$
0.18­$
6.63
$
0.18­$
6.63
$
0.18­$
6.63
TOTAL
BENEFITS
$
6.48­$
12.93
$
6.13­$
12.58
$
5.79­$
12.24
Notes:
a.
Avoided
premature
mortality
benefit
estimates
reflect
a
VSL
range
of
$
1.1
million
to
$
11.4
million,
with
a
central
VSL
estimate
of
$
6.2
million.
These
values
are
derived
from
willingness­
to­
pay
based
VSL
estimates
presented
in
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005.
VSL
estimates
reflect
income
in
2005
and
were
adjusted
to
2002
dollars
using
the
GDP
deflator.
b.
The
primary
estimate
of
dioxin
benefits
presented
here
reflects
EPA's
current
guidance
on
the
cancer
risk
(
1.5
x
105
[
mg/
kg/
day]­
1)
associated
with
dioxin/
furans.
The
Agency
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
dioxin
and
dioxin­
like
compounds.
This
reassessment
is
currently
under
review
at
the
National
Academy
of
Sciences
(
NAS).
Evidence
compiled
from
this
draft
reassessment
indicates
that
the
carcinogenic
effects
of
dioxin/
furans
may
be
six
times
greater
than
estimated
in
the
1985
analysis
with
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.
c.
Discounted
benefits
associated
with
dioxin­
related
cancer
deaths
reflect
a
21­
34
year
period
between
dioxin
exposure
and
death
(
Jim
Neumann
and
Bob
Unsworth,
Addenda
to
Mortality
Valuation
Methodology,
internal
memorandum
submitted
to
Jim
DeMocker,
U.
S.
EPA
Office
of
Air
and
Radiation,
September
28,
1993)
and
a
central
VSL
value
of
$
6.2
million
derived
from
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005.
This
value
reflects
income
in
2005
and
was
converted
to
2002
dollars
using
the
GDP
deflator.
d.
This
range
reflects
the
21­
34
year
period
between
dioxin
exposure
and
death
(
Jim
Neumann
and
Bob
Unsworth,
Addenda
to
Mortality
Valuation
Methodology,
internal
memorandum
submitted
to
Jim
DeMocker,
September
28,
1993)
and
VSL
values
ranging
from
$
1.1
million
to
$
11.4
million
(
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005).
VSL
estimates
reflect
income
in
2005
and
are
adjusted
to
2002
dollars
using
the
GDP
deflator.
REVIEW
DRAFT
23
Exhibit
13
HUMAN
HEALTH
BENEFITS
SUMMARY:
BASELINE
TO
MACT
ALTERNATIVES
(
millions
of
2002
dollars)

Option
Primary
Floor
Option
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Type
of
Benefit
Annual
Nondiscounted
Value
Annual
Discounted
Value
­
3
Percent
Discount
Rate
Annual
Discounted
Value
­
7
Percent
Discount
Rate
Annual
Nondiscounted
Value
Annual
Discounted
Value
­
3
Percent
Discount
Rate
Annual
Discounted
Value
­
7
Percent
Discount
Rate
Annual
Nondiscounted
Value
Annual
Discounted
Value
­
3
Percent
Discount
Rate
Annual
Discounted
Value
­
7
Percent
Discount
Rate
PM­
related
Health
Benefits
Premature
mortalitya
$
2.84
$
2.50
$
2.17
$
2.84
$
2.50
$
2.17
$
4.66
$
4.10
$
3.55
($
0.52­$
5.17)
($
0.45­$
4.55)
($
0.39­$
3.94)
($
0.52­$
5.17)
($
0.45­$
4.55)
($
0.39­$
3.94)
($
0.85­$
8.47)
($
0.74­$
7.45)
($
0.65­$
6.46)

Respiratory
Illness
Hospital
Admissions
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
$
0.02
$
0.02
$
0.02
Cardiovascular
Disease
Hospital
Admissions
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
$
0.01
Chronic
Bronchitis
$
3.01
$
3.01
$
3.01
$
3.01
$
3.01
$
3.01
$
4.93
$
4.93
$
4.93
Acute
Bronchitis
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Lower
Respiratory
Symptoms
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Upper
Respiratory
Symptoms
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
$
0.00
Minor
Restricted
Activity
Days
$
0.29
$
0.29
$
0.29
$
0.29
$
0.29
$
0.29
$
0.47
$
0.47
$
0.47
Work
Loss
Days
$
0.08
$
0.08
$
0.08
$
0.08
$
0.08
$
0.08
$
0.14
$
0.14
$
0.14
Total
PM
Health
Benefitsa
$
6.24
$
5.90
$
5.57
$
6.24
$
5.90
$
5.57
$
10.23
$
9.67
$
9.13
($
3.92­$
8.57)
($
3.86­$
7.95)
($
3.79­$
7.34)
($
3.92­$
8.57)
($
3.86­$
7.95)
($
3.79­$
7.34)
($
6.42­$
14.04)
($
6.32­$
13.03)
($
6.22­$
12.03)
REVIEW
DRAFT
Exhibit
13
HUMAN
HEALTH
BENEFITS
SUMMARY:
BASELINE
TO
MACT
ALTERNATIVES
(
millions
of
2002
dollars)

Option
Primary
Floor
Option
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Type
of
Benefit
Annual
Nondiscounted
Value
Annual
Discounted
Value
­
3
Percent
Discount
Rate
Annual
Discounted
Value
­
7
Percent
Discount
Rate
Annual
Nondiscounted
Value
Annual
Discounted
Value
­
3
Percent
Discount
Rate
Annual
Discounted
Value
­
7
Percent
Discount
Rate
Annual
Nondiscounted
Value
Annual
Discounted
Value
­
3
Percent
Discount
Rate
Annual
Discounted
Value
­
7
Percent
Discount
Rate
24
Dioxin­
related
Health
Benefits
Dioxin­
related
cancer
deathsb
$
0.01
$
0.00­$
0.01c
$
0.00
$
0.03
$
0.01
$
0.00­$
0.01c
$
0.03
$
0.01
$
0.00­$
0.01c
($
0.00­$
0.02)
d
($
0.00­$
0.01)
d
($
0.00)
($
0.00­$
0.05)
d
($
0.00­$
0.03)
d
($
0.00­$
0.01)
d
($
0.00­$
0.05)
d
($
0.00­$
0.03)
d
($
0.00­$
0.01)
d
TOTAL
HUMAN
HEALTH
BENEFITS
­
MONETIZED
$
6.25
$
5.91
$
5.57
$
6.27
$
5.92
$
5.57
$
10.26
$
9.69
$
9.14
Notes:

e.
Avoided
premature
mortality
benefit
estimates
reflect
a
VSL
range
of
$
1.1
million
to
$
11.4
million,
with
a
central
VSL
estimate
of
$
6.2
million.
These
values
are
derived
from
willingness­

topay
based
VSL
estimates
presented
in
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005.
VSL
estimates
reflect
income
in
2005
and
were
adjusted
to
2002
dollars
using
the
GDP
deflator.

f.
The
primary
estimate
of
dioxin
benefits
presented
here
reflects
EPA's
current
guidance
on
the
cancer
risk
(
1.5
x
105
[
mg/
kg/
day]­
1)
associated
with
dioxin/
furans.
The
Agency
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
dioxin
and
dioxin­
like
compounds.
This
reassessment
will
is
currently
under
review
at
the
National
Academy
of
Sciences
(
NAS).
Evidence
compiled
from
this
draft
reassessment
indicates
that
the
carcinogenic
effects
of
dioxin/
furans
may
be
as
much
as
six
times
as
great
as
believed
in
1985,
reflecting
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.

g.
This
range
of
monetized
benefits
reflects
a
21­
34
year
period
between
dioxin
exposure
and
death
(
Jim
Neumann
and
Bob
Unsworth,
Addenda
to
Mortality
Valuation
Methodology,
internal
memorandum
submitted
to
Jim
DeMocker,
U.
S.
EPA
Office
of
Air
and
Radiation,
September
28,
1993)
and
a
central
VSL
value
of
$
6.2
million
derived
from
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005.
This
VSL
value
reflects
income
in
2005
and
was
converted
to
2002
dollars
with
the
GDP
deflator.

h.
Range
in
parentheses
reflects
a
21­
34
year
period
between
dioxin
exposure
and
death
(
Jim
Neumann
and
Bob
Unsworth,
Addenda
to
Mortality
Valuation
Methodology,
internal
memorandum
submitted
to
Jim
DeMocker,
September
28,
1993)
and
VSL
values
ranging
from
$
1.1
million
to
$
11.4
million
(
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005).
VSL
estimates
reflect
income
levels
in
2005
and
were
adjusted
to
2002
dollars
using
the
GDP
deflator.
REVIEW
DRAFT
14
U.
S.
EPA,
1985.
Health
Assessment
Document
for
Polychlorinated
Dibenzo­
p­
Dioxins.
EPA/
600/
8­
84/
014F.
Final
Report.
Office
of
Health
and
Environmental
Assessment.
Washington,
DC.
September,
1985.
The
Agency
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
dioxin
and
dioxinlike
compounds.
This
reassessment
is
currently
under
review
at
the
National
Academy
of
Sciences
(
NAS).
Evidence
compiled
from
this
draft
reassessment
indicates
that
the
carcinogenic
effects
of
dioxin/
furans
may
be
as
much
as
six
times
as
great
as
believed
in
1985,
reflecting
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.

15
The
primary
form
of
lead
exposure
to
children
is
via
ingestion
of
contaminated
soil.

25
Dioxin­
related
Benefits
Under
the
revised
version
of
the
Final
Rule
Standards
for
dioxin,
we
expect
$
0.02
million
in
non­
discounted
dioxin­
related
benefits,
as
shown
in
Exhibit
12.
As
Exhibit
13
indicates,
we
estimate
$
0.01
million
in
dioxin­
related
health
benefits
under
the
Primary
Floor
Option,
$
0.02
million
less
than
the
corresponding
estimate
presented
in
the
Assessment.
Dioxin­
related
benefits
expected
under
Alternative
Floor
Option
1
and
Alternative
Floor
Option
2
are
the
same
as
estimated
in
the
Assessment.

Similar
to
the
analysis
presented
in
the
Assessment,
the
estimated
dioxin
benefits
presented
in
this
Addendum
reflect
a
cancer
risk
slope
factor
of
1.56
x
105
[
mg/
kg/
day]­
1.
This
slope
factor
is
derived
from
the
Agency's
1985
health
assessment
document
for
polychlorinated
dibenzo­
p­
dioxins
and
represents
an
upper
bound
95th
percentile
confidence
limit
of
the
excess
cancer
risk
from
lifetime
exposure.
14
In
addition,
to
estimate
the
discounted
benefits
of
reduced
dioxin
emissions,
we
assume
a
21­
to
34­
year
lag
between
the
decline
in
dioxin
exposure
and
avoided
mortality.

Other
Benefits
In
addition
to
the
PM­
and
dioxin­
related
benefits
outlined
above,
the
revised
Final
Rule
Standards
may
yield
health
and
ecological
benefits
associated
with
reduced
emissions
of
lead,
mercury
and
other
hazardous
air
pollutants.

Lead.
The
Final
Rule
Standards
are
expected
to
reduce
lead
emissions
by
approximately
2.5
tons
per
year.
By
comparison,
the
1999
Standards
were
projected
to
reduce
lead
emissions
by
89
tons
per
year,
causing
cumulative
lead
exposures
to
decline
to
less
than
10
µ
g/
dL
for
seven
children
younger
than
the
age
of
six.
15
Given
the
relatively
modest
reduction
in
lead
emissions
associated
with
the
final
standards,
the
Final
Rule
is
likely
to
reduce
cumulative
lead
exposure
to
below
10
µ
g/
dL
(
from
above
this
level)
for
fewer
than
seven
children
per
year.
The
HWC
MACT
final
standards
will
also
result
in
reduced
lead
levels
for
children
in
sub­
populations
with
especially
high
levels
of
exposure.
However,
the
small
number
of
cases
identified
in
the
1999
Assessment
suggests
that
these
benefits
will
be
small.
REVIEW
DRAFT
26
Exhibit
14
SUMMARY
OF
ANNUAL
BENEFITS
RESULTING
FROM
THE
HWC
MACT
FINAL
STANDARDS
Benefit
Category
and
Pollutant
Monetary
Value
(
millions
of
year
2002
dollars)

Non­
discounted
Three
Percent
Discount
Rate
Seven
Percent
Discount
Rate
Human
Health
Benefits
Dioxin/
Furansa,
b:
Baseline
to
Primary
Floor
Option
$
0.01
$
0.00­$
0.01
$
0.00
Primary
Floor
Option
to
Final
Rule
Standards
(
Primary
Option
Beyond­
the­
Floor)
c
$
0.00
$
0.00
$
0.00
Baseline
to
Final
Rule
Standards
(
Primary
Option
Beyond­
the­
Floor)
c
$
0.02
$
0.01
$
0.00
Particulate
Matter
­
Avoided
Mortalityb,
d
Baseline
to
Primary
Floor
Option
$
2.84
$
2.50
$
2.17
Primary
Floor
Option
to
Final
Rule
Standards
(
Primary
Option
Beyond­
the­
Floor)
c
$
0.02
$
0.02
$
0.02
Baseline
to
Final
Rule
Standards
(
Primary
Option
Beyond­
the­
Floor)
c
$
2.87
$
2.52
$
2.19
Particulate
Matter
­
Avoided
Morbidity
Baseline
to
Primary
Floor
Option
$
3.40
$
3.40
$
3.40
Primary
Floor
Option
to
Final
Rule
Standards
(
Primary
Option
Beyond­
the­
Floor)
c
$
0.02
$
0.02
$
0.02
Baseline
to
Final
Rule
Standards
(
Primary
Option
Beyond­
the­
Floor)
c
$
3.43
$
3.43
$
3.43
Human
Health
Subtotal
­
Final
Rule
Standards
Incremental
to
the
Baseline
$
6.31
$
5.96d
$
5.62
Visibility
Benefits:

PM­
related
Visibility
Improvements
Baseline
to
Primary
Floor
Option
$
0.18
­
$
5.18
$
0.18
­
$
5.18
$
0.18
­
$
5.18
Primary
Floor
Option
to
Final
Rule
Standards
(
Primary
Option
Beyond­
the­
Floor)
c
$
0.00­$
1.45
$
0.00­$
1.45
$
0.00­$
1.45
Baseline
to
Final
Rule
Standards
(
Primary
Option
Beyond­
the­
Floor)
c
$
0.18
­
$
6.63
$
0.18
­
$
6.63
$
0.18
­
$
6.63
Visibility
Subtotal
­
Final
Rule
Standards
Incremental
to
the
Baseline
$
0.18
­
$
6.63
$
0.18
­
$
6.63
$
0.18
­
$
6.63
TOTAL
BENEFITSd
$
6.48
­
$
12.93
$
6.13
­
$
12.58
$
5.79
­
$
12.24
REVIEW
DRAFT
Exhibit
14
SUMMARY
OF
ANNUAL
BENEFITS
RESULTING
FROM
THE
HWC
MACT
FINAL
STANDARDS
Benefit
Category
and
Pollutant
Monetary
Value
(
millions
of
year
2002
dollars)

Non­
discounted
Three
Percent
Discount
Rate
Seven
Percent
Discount
Rate
16
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.

27
Notes:
a.
The
range
of
dioxin
benefits
reflects
a
lag
of
21­
34
years
between
exposure
to
dioxin
and
avoided
mortality.
In
addition,
the
primary
estimate
of
dioxin
benefits
presented
here
reflects
EPA''
s
current
guidance
on
the
cancer
risk
(
1.5
x
105
[
mg/
kg/
day]­
1)
associated
with
dioxin/
furans.
The
Agency
has
been
conducting
a
reassessment
of
the
human
health
risks
associated
with
dioxin
and
dioxin­
like
compounds.
This
reassessment
is
currently
under
review
at
the
National
Academy
of
Sciences
(
NAS).
Evidence
compiled
from
this
draft
reassessment
indicates
that
the
carcinogenic
effects
of
dioxin/
furans
may
be
as
much
as
six
times
as
great
as
believed
in
1985,
reflecting
an
upper
bound
cancer
risk
slope
factor
of
1
x
106
[
mg/
kg/
day]­
1
for
some
individuals.
b.
The
mortality­
related
benefits
presented
in
this
exhibit
reflect
a
mean
VSL
value
of
$
6.2
million.
This
value
is
consistent
with
the
VSL
value
used
in
U.
S.
EPA,
Regulatory
Impact
Analysis
for
the
Final
Clean
Air
Interstate
Rule,
March
2005,
adjusted
for
inflation
and
real
income
in
2005.
c.
The
Final
Rule
Standards
represent
a
beyond­
the­
floor
version
of
the
Primary
Floor
Option.
d.
Totals
may
not
add
due
to
rounding.

Mercury.
The
revised
Final
Rule
Standards
for
mercury
are
expected
to
reduce
mercury
emissions
by
approximately
0.21
tons
per
year,
approximately
95
percent
less
than
the
four­
ton
reduction
expected
under
the
1999
Standards.
We
do
not
attempt
to
quantify
the
mercury­
related
benefits
associated
with
the
final
standards.
However,
because
the
reduction
in
mercury
emissions
represents
a
fraction
of
the
reduction
expected
under
the
1999
Standards,
any
mercury­
related
benefits
associated
with
the
final
standards
are
likely
to
be
less
than
the
corresponding
benefits
under
the
1999
Standards.

Ecological
Benefits:
The
ecological
benefit
results
presented
in
the
1999
Assessment
reflect
the
29­
gram
decline
in
dioxin
emissions
and
the
100­
ton
reduction
in
metals
emissions
expected
under
the
1999
Standards.
Based
on
these
emissions
reductions,
the
1999
Assessment
estimated
that
ecotoxicological
hazard
quotients
would
fall
below
levels
of
concern
for
38
square
kilometers
of
water
surface
area
under
the
1999
Standards.
For
terrestrial
ecosystems,
the
1999
Assessment
estimated
that
hazard
quotients
would
fall
below
levels
of
concern
for
115
to
147
square
kilometers
of
land
under
the
1999
standards.
16
Under
the
revised
Final
Rule
Standards,
EPA
anticipates
a
0.20­
gram
reduction
in
dioxin
emissions
and
a
9.6­
ton
reduction
in
metals
emissions.
Because
these
reductions
are
less
than
those
associated
with
the
1999
Standards,
ecological
benefits
associated
with
the
final
standards
are
likely
to
be
smaller
than
those
resulting
from
the
1999
Standards.
However,
the
1999
Assessment
did
not
REVIEW
DRAFT
28
estimate
the
ecological
benefits
associated
with
reduced
emissions
from
boilers
and
industrial
furnaces.
These
systems
were
not
included
in
the
regulatory
universe
in
1999
but
are
among
those
facilities
regulated
under
the
HWC
MACT
final
standards.
Because
the
final
standards
represent
the
Agency's
first
attempt
to
limit
emissions
of
hazardous
air
pollutants
from
boilers,
ecological
benefits
associated
with
the
final
standards
may
be
concentrated
around
these
facilities.

EQUITY
CONSIDERATIONS
AND
OTHER
IMPACTS
EPA's
changes
to
the
final
standards
have
no
impact
on
most
of
the
equity
considerations
and
other
regulatory
concerns
addressed
under
Executive
Orders
relevant
to
this
rulemaking.
The
costs
associated
with
the
revised
Final
Rule
Standards
range
from
$
22.6
million
(
market­
adjusted
costs)
to
$
40.7
million
(
engineering
costs).
Since
these
costs
total
less
than
$
100
million,
the
final
standards
do
not
represent
a
significant
unfunded
mandate
and
are
consequently
exempt
from
requirements
associated
with
the
Unfunded
Mandates
Reform
Act.
Because
the
changes
to
the
final
standards
do
not
reflect
changes
in
the
location
or
operating
status
of
any
regulated
facilities,
the
standards
may
still
result
in
significant
health
and
environmental
benefits
to
minority
and
low­
income
populations
living
in
proximity
to
hazardous
waste
combustion
facilities,
as
suggested
in
the
Assessment.
For
the
same
reasons
described
in
the
Assessment,
the
final
standards
are
unlikely
to
have
a
significant
joint
impact
on
the
actions
of
facilities
directly
affected
by
other
regulations.
Likewise,
the
revised
standards
do
not
have
implications
as
defined
in
Executive
Order
13175,
"
Consultation
With
Indian
Tribal
Governments;"
Executive
Order
13132,
"
Federalism;"
and
Executive
Order
12630,
"
Government
Actions
and
Interference
with
Constitutionally
Protected
Property
Rights."
The
remainder
of
this
section
discusses
the
impacts
of
the
final
standards
on
small
entities,
children's
health
protection,
and
energy
use.

Assessment
of
Small
Entity
Impacts
Under
the
revised
Final
Rule
Standards,
none
of
the
hazardous
waste
combustion
facilities
that
we
identified
as
small
businesses,
based
on
thresholds
set
by
the
Small
Business
Administration,
are
likely
to
incur
annual
costs
greater
than
one
percent
of
gross
annual
sales
(
Exhibit
15).
Therefore,
we
conclude
that
neither
a
substantial
number
of
facilities
nor
a
substantial
fraction
of
the
affected
industries
will
face
significant
adverse
impacts.
In
addition,
for
the
cement
kiln
and
LWAK
facilities
listed
in
Exhibit
15,
estimated
compliance
costs
may
be
offset,
at
least
partially,
by
revenues
and
fuel
savings
associated
with
waste
received
from
boilers
and
industrial
furnaces
that
stop
burning
hazardous
waste
in
response
to
the
HWC
MACT
final
standards.
Taking
these
savings
into
account,
our
model
predicts
that
a
system
at
just
one
of
the
small
hazardous
waste
combustion
facilities
will
stop
burning
hazardous
waste
in
response
to
the
final
standards,
indicating
that
offsite
waste
management
costs
for
this
system
are
likely
to
be
less
than
its
potential
compliance
costs.
In
summary,
this
analysis
indicates
that
the
HWC
MACT
final
standards
would
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
hazardous
waste
combustion
facilities/
companies.
REVIEW
DRAFT
29
SMALL
ENTITY
ANALYSIS
RESULTS
Facility
Name/
Parent
Companya
EPA
ID
Combustor
Type
Corporate
Entity
Annual
Salesb
(
Year
2002$)
Total
Compliance
Costs
(
Final
Rule
Standards)
c
(
Year
2002$)
Costs
as
a
Percentage
of
Sales
(
CPS)

Reilly
Industries,
Inc.
IND000807107
Liquid
Boiler
$
317,000,000
$
403,600
0.13%

Rubicon,
Inc.
LAD008213191
Liquid
Boiler
$
456,600,000
$
625,300
0.14%

Continental
Cement
Company
MOD054018288
Cement
Kiln
$
51,500,000
$
65,600
0.13%

Thermalkem
(
Norlite);
subsidiary
of
United
Oil
Recovery
NYD080469935
LWAK
$
49,300,000
$
28,200
0.06%

3V,
Inc.
d
SCD980500052
Liquid
Boiler
$
61,500,000
$
121,100
0.20%

Velsicol
Chemical
Corporation
TND007024664
On­
Site
Incinerator
$
147,300,000
$
17,300
0.01%

Resolution
Performance
Products
LAD980622104
On­
Site
Incinerator
$
957,900,000
$
41,700
0.00%

Merisol
USA,
LLC
TXD008106999
Liquid
Boiler
$
64,700,000
$
296,500
0.46%

Notes:
a
Except
in
the
case
of
Norlite,
the
name
of
each
facility's
parent
company
is
the
same
as
the
name
of
the
facility
itself.
b
Corporate
entity
data
obtained
from
ReferenceUSA,
Dun
and
Bradstreet,
company
websites,
and
company
financial
documents.
c
Compliance
costs
represent
upper­
bound
engineering
costs
that
assume
facilities
upgrade
to
comply
with
standards.
d
3V,
Incorporated
is
an
Italian­
owned
company
with
facilities
in
the
United
States,
Italy,
and
several
other
countries.
Employment
in
the
U.
S.
is
at
least
270
people,
and
overall
employment
worldwide
is
likely
over
500
people
(
the
small
business
size
threshold).
However,
we
included
this
facility
as
a
small
business
because
we
were
unable
to
confirm
its
total
employment.
Available
sales
data
are
for
the
single
facility
in
South
Carolina.
REVIEW
DRAFT
17
U.
S.
EPA,
Environmental
Health
Threats
to
Children,
EPA
175­
F­
96­
001,
September
1996,
4.

18
U.
S.
Dept.
of
Transportation,
Bureau
of
Transportation
Statistics,
"
Average
Motor
Vehicle
Miles
Per
Gallon,"
July
21,
2003,
September
23,
2003.
<
http://
www.
bts.
gov/
products/
transportation_
indicators.
september_
2002/
Environment/
excel/
Average_
Motor_
Vehicle_
Miles_
Per_
Gallon.
xls>.

19
Based
on
average
2004
on­
highway
diesel
prices
cited
by
the
U.
S.
Department
of
Energy,
Energy
Information
Administration,
"
Monthly
U.
S.
On­
highway
Diesel
Fuel
Prices."
<
http://
tonto.
eia.
doe.
gov/
oog/
ftparea/
wogirs/
xls/
psw18vwall.
xls>.

30
Children's
Health
Protection
Analysis
Most
health
benefits
associated
with
the
final
standards
result
from
reduced
PM
emissions.
Because
EPA's
revisions
to
the
final
standards
include
no
changes
to
the
standards
for
PM,
our
estimate
of
the
benefits
associated
with
the
Final
Rule
Standards
has
not
changed
significantly
relative
to
the
estimate
presented
in
the
Assessment.
As
described
in
the
Assessment,
we
were
unable
to
develop
separate
results
for
children,
but
we
assume
that
children
would
experience
significant
health
benefits
since
they
are
particularly
vulnerable
to
the
effects
of
PM
exposure.
17
Reductions
in
lead
and
mercury
emissions
under
the
revised
Final
Rule
Standards
are
expected
to
be
approximately
the
same
as
presented
in
the
Assessment.
Therefore,
the
children's
health
benefits
associated
with
the
revised
final
standards
for
these
pollutants
are
also
likely
to
be
the
same
as
the
corresponding
benefits
associated
with
the
standards
analyzed
in
the
Assessment.

Energy
Impact
Analysis
The
30
systems
that
we
expect
will
start
sending
waste
offsite
in
response
to
the
revised
Final
Rule
Standards
will
increase
their
energy
use
by
using
fuel
to
transport
their
waste
to
different
facilities.
Assuming
that
waste
is
sent
to
the
nearest
combustion
facility,
these
facilities
will
ship
their
waste
approximately
7,993
miles
per
year.
This
figure
reflects
the
number
of
tons
that
each
facility
would
send
offsite,
the
tonnage
of
waste
that
can
be
transported
per
truck,
and
the
miles
that
each
truck
would
travel.
Based
on
statistics
from
the
Department
of
Transportation,
trucks
average
6.0
miles
per
gallon
of
fuel.
18
Therefore,
transporting
waste
an
additional
7,993
miles
per
year
requires
the
use
of
an
additional
1,332
gallons
of
fuel
annually.
At
a
unit
cost
of
$
1.74
per
gallon
of
diesel
fuel,
the
resulting
increase
in
fuel
expenditures
will
total
almost
$
2,318
annually.
19
For
sources
that
upgrade
rather
than
consolidate
or
send
their
waste
offsite,
energy
consumption
will
increase,
as
new
APCDs
require
energy
to
operate.
We
do
not
estimate
the
exact
energy
requirements
and
costs
associated
with
upgrades
for
the
226
systems
that
we
expect
to
continue
burning
hazardous
waste
under
the
Final
Rule
Standards.
REVIEW
DRAFT
31
COST
EFFECTIVENESS
ANALYSIS
The
revised
version
of
the
HWC
MACT
final
standards
does
not
significantly
change
most
of
the
cost­
effectiveness
estimates
reported
in
the
Assessment.
Exhibits
16
and
17
present
updated
cost­
effectiveness
results
to
reflect
EPA's
revisions
to
the
final
standards.
Key
findings
from
these
updated
results
include
the
following:

°
The
liquid
boiler
standards
for
mercury
and
LVM
under
the
revised
Final
Rule
Standards
and
Primary
Floor
Option
are
more
cost­
effective
than
the
corresponding
standards
presented
in
the
Assessment.
In
contrast,
the
SVM
standards
for
liquid
boilers
under
the
revised
Final
Rule
Standards
are
less
cost
effective
than
the
liquid
boiler
SVM
standard
included
in
the
Assessment.

°
The
incinerator
standards
for
SVM
and
LVM
under
the
Final
Rule
Standards
and
the
Primary
Floor
Option
are
more
cost
effective
relative
to
the
corresponding
standards
included
in
the
Assessment.

°
Per
unit
health
improvement,
the
revised
dioxin
standards
included
in
this
Addendum
are
more
cost­
effective
than
the
dioxin
standards
reflected
in
the
Assessment.
Our
estimated
cost­
effectiveness
values
for
the
Final
Rule
Standards
and
the
Primary
Floor
Option
are
$
53.0
million
and
$
29.3
million
respectively,
compared
to
the
estimates
of
$
215.2
million
and
$
199.9
million
presented
in
the
Assessment.
The
cost­
effectiveness
of
PM­
related
health
benefits
is
the
same
as
estimated
in
the
Assessment.
REVIEW
DRAFT
32
Exhibit
16
COST­
EFFECTIVENESS
RESULTSa
Pollutant
Source
Options
Dioxin
(
TEQ),
$
1,000/
gram
Hg,
$
1,000/
ton
SVM,
$
1,000/
ton
LVM,
$
1,000/
ton
PM,
$
1,000/
ton
TCl,
$
1,000/
ton
LWAKs
Baseline
to
Final
Rule
Standards
­
­
$
1,788
$
5,850
­
­

Primary
Floor
Option
to
Final
Rule
Standards
­
­
­
­
­
­

Baseline
to
Primary
Floor
Option
­
­
$
1,788
$
5,850
­
­

Baseline
to
Alternative
Floor
Option
1
­
­
$
1,788
$
5,850
­
­

Baseline
to
Alternative
Floor
Option
2
­
$
117,743
­
$
10,368
­
­

Incinerators
Baseline
to
Final
Rule
Standards
­
­
$
241
$
581
$
90.44
­

Primary
Floor
Option
to
Final
Rule
Standards
­
­
­
­
­
­

Baseline
to
Primary
Floor
Option
­
­
$
241
$
581
$
90.44
­

Baseline
to
Alternative
Floor
Option
1
$
4,258
­
$
4,942
$
9,116
$
90.44
­

Baseline
to
Alternative
Floor
Option
2
$
4,258
­
$
2,360
$
4,052
$
18.17
­

Cement
Kilns
Baseline
to
Final
Rule
Standards
­
$
10,002
$
209
$
11,433
$
15.81
­

Primary
Floor
Option
to
Final
Rule
Standards
­
­
­
­
­
­

Baseline
to
Primary
Floor
Option
­
$
10,002
$
209
$
11,433
$
15.84
­

Baseline
to
Alternative
Floor
Option
1
­
$
10,002
$
1,394
$
17,200
$
15.81
­

Baseline
to
Alternative
Floor
Option
2
­
$
24,342
$
442
$
5,156
$
5.60
­

Liquid
Boilers
Baseline
to
Final
Rule
Standards
$
450
$
50,332
$
3,692
$
318
$
8.53
­

Primary
Floor
Option
to
Final
Rule
Standards
$
490
­
­
­
­
­
REVIEW
DRAFT
Exhibit
16
COST­
EFFECTIVENESS
RESULTSa
Pollutant
Source
Options
Dioxin
(
TEQ),
$
1,000/
gram
Hg,
$
1,000/
ton
SVM,
$
1,000/
ton
LVM,
$
1,000/
ton
PM,
$
1,000/
ton
TCl,
$
1,000/
ton
33
Baseline
to
Primary
Floor
Option
$
364
$
50,332
$
3,692
$
318
$
8.53
­

Baseline
to
Alternative
Floor
Option
1
$
364
$
52,407
$
3,676
$
231
$
8.53
­

Baseline
to
Alternative
Floor
Option
2
$
364
$
62,753
$
1,369
$
261
$
9.37
­

Coal
Boilers
Baseline
to
Final
Rule
Standards
­
$
23,250
$
223b
$
204b
$
2.82
­

Primary
Floor
Option
to
Final
Rule
Standards
­
­
­
­
$
2.57
­

Baseline
to
Primary
Floor
Option
­
$
23,250
$
715
$
368
$
5.92
­

Baseline
to
Alternative
Floor
Option
1
­
$
23,250
$
715
$
368
$
5.92
­

Baseline
to
Alternative
Floor
Option
2
­
$
23,250
$
715
$
368
$
5.92
­

HCl
Production
Furnaces
Baseline
to
Final
Rule
Standards
­
­
­
­
­
$
1.56
Primary
Floor
Option
to
Final
Rule
Standards
­
­
­
­
­
­

Baseline
to
Primary
Floor
Option
­
­
­
­
­
$
1.56
Baseline
to
Alternative
Floor
Option
1
­
­
­
­
­
$
1.56
Baseline
to
Alternative
Floor
Option
2
­
­
­
­
­
$
2.47
Notes:
a.
This
table
includes
pollutants
where
more
than
one
option
was
under
consideration.
b.
Although
the
SVM
and
LVM
standards
for
coal
boilers
are
the
same
under
the
Final
Rule
Standards
and
the
Primary
Floor
Option,
the
PM
controls
required
under
the
Final
Rule
Standards
have
the
ancillary
effect
of
reducing
SVM
and
LVM
emissions.
We
incorporate
these
additional
emissions
reductions
into
our
costeffectiveness
estimates.
Because
the
Final
Rule
Standards
do
not
require
coal
boilers
to
achieve
SVM
or
LVM
emissions
reductions
beyond
those
associated
with
the
Primary
Floor
Option,
we
do
not
estimate
the
incremental
cost­
effectiveness
of
coal
boilers
complying
with
the
Final
Rule
Standards
for
SVM
and
LVM
incremental
to
the
Primary
Floor
Option.
REVIEW
DRAFT
34
Exhibit
17
COST­
EFFECTIVENESS
PER
UNIT
HEALTH
AND
ECOLOGICAL
IMPROVEMENT
(
2002
dollars
per
unit
benefit)

Benefit
Type
Pollutant
Final
Rule
Standards
Primary
Floor
Option
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Cost
of
Controla
Benefit
Cost­
Effectivenessb
Cost
of
Controla
Benefit
Cost­
Effectivenessb
Cost
of
Controla
Benefit
Cost­
Effectivenessb
Cost
of
Controla
Benefit
Cost­
Effectivenessb
Health
Benefits
Avoided
Premature
Mortality
Casesc,
d
PM
$
16.8
million
0.46
avoided
cases
$
36.6
million
per
life
saved
$
15.3
million
0.45
avoided
cases
$
33.6
million
per
life
saved
$
15.3
million
0.45
avoided
cases
$
33.6
million
per
life
saved
$
27.3
million
0.75
avoided
cases
$
36.7
million
per
life
saved
Avoided
Morbiditye
PM
$
16.8
million
5,832
avoided
cases
$
2,900
per
avoided
case
$
15.3
million
5,789
avoided
cases
$
2,600
per
avoided
case
$
15.3
million
5,789
avoided
cases
$
2,600
per
avoided
case
$
27.3
million
9,519
avoided
cases
$
2,900
per
avoided
case
Avoided
Cancer
Deaths
Dioxin
$
0.1
million
0.002
avoided
cases
$
53.0
million
per
life
saved
$
0.1
million
0.002
avoided
cases
$
29.3
million
per
life
saved
$
0.9
million
0.004
avoided
cases
$
215.2
million
per
life
saved
$
0.9
million
0.004
avoided
cases
$
215.2
million
per
life
saved
Avoided
Morbidity
(
lead)
f
SVM
$
6.2
million
fewer
than
2
avoided
cases
Unknown
$
6.3
million
fewer
than
2
avoided
cases
Unknown
$
11.3
million
fewer
than
2
avoided
cases
Unknown
$
5.3
million
fewer
than
2
avoided
cases
Unknown
Visibility
Benefits
Improvements
in
Recreational
Visibility
PM
$
16.8
million
$
0.2
­
$
6.6
million
in
visibility
benefits
Unknown
$
15.3
million
$
0.2
­

$
5.2
million
in
visibility
benefits
Unknown
$
15.3
million
$
0.2
­
$
5.2
million
in
visibility
benefits
Unknown
$
27.3
million
$
0.3
­
$
9.3
million
in
visibility
benefits
Unknown
Ecological
Benefits
REVIEW
DRAFT
Exhibit
17
COST­
EFFECTIVENESS
PER
UNIT
HEALTH
AND
ECOLOGICAL
IMPROVEMENT
(
2002
dollars
per
unit
benefit)

Benefit
Type
Pollutant
Final
Rule
Standards
Primary
Floor
Option
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Cost
of
Controla
Benefit
Cost­
Effectivenessb
Cost
of
Controla
Benefit
Cost­
Effectivenessb
Cost
of
Controla
Benefit
Cost­
Effectivenessb
Cost
of
Controla
Benefit
Cost­
Effectivenessb
35
Area
of
Land
and
Water
with
Reduced
Ecological
Risk
Dioxin,
Mercury,

and
Leadh
$
13.0
million
less
than
185
km2
Unknown
$
13.1
million
less
than
185
km2
Unknown
$
20.8
million
less
than
185
km2
Unknown
$
30.7
million
less
than
185
km2
Unknown
Notes:

a.
Engineering
costs.

b.
Costs
per
unit
benefit.

c.
These
cost­
effectiveness
per
unit
benefit
measures
are
upper
bound
estimates
that
apply
the
full
costs
of
control
(
by
pollutant)
to
a
single
type
of
benefit
(
e.
g.,
lives
saved).
The
cost
per
unit
benefit
measures
should
not
be
reported
in
isolation
from
other
benefit
estimates;
they
should
only
be
used
as
relative
measures
to
compare
across
MACT
standards.

d.
All
figures
are
incremental
from
the
baseline
to
the
HWC
MACT
final
standards.

e.
Pm
morbidity
includes
hospital
admissions
from
respiratory
illness
and
cardiovascular
disease,
chronic
bronchitis,
acute
bronchitis,
upper
and
lower
respiratory
symptoms,
minor
restricted
activity
days,
and
work
loss
days.

f.
Avoided
morbidity
associated
with
lead
exposure
is
represented
as
the
number
of
children
whose
blood
lead
levels
fall
below
the
critical
level
of
10
ug/
dL.

g.
Although
we
estimate
monetized
visibility
benefits,
we
do
not
estimate
specific
visibility
impacts
(
e.
g.,
changes
in
visibility
index
values).
Therefore,
we
are
unable
to
calculate
the
costeffectiveness
of
the
visibility
improvements
associated
with
the
HWC
MACT
final
standards.

h.
Costs
for
lead
were
estimated
together
with
costs
for
cadmium,
the
other
semi­
volatile
metal
considered
in
this
analysis.
Therefore,
we
use
total
SVM
costs
as
a
proxy
for
lead
costs.
REVIEW
DRAFT
36
Appendix
DETAILED
COST
MODEL
RESULTS
REVIEW
DRAFT
37
This
appendix
contains
detailed
model
results
supporting
the
analysis
of
the
HWC
MACT
final
standards
presented
in
the
main
body
of
this
document.
We
present
model
results
for
the
Final
Rule
Standards,
the
Primary
Floor
Option,
Alternative
Floor
Option
1,
and
Alternative
Floor
Option
2.
The
results
for
these
regulatory
options
reflect
EPA's
decision
to
allow
all
facilities,
except
for
HCl
production
furnaces,
to
choose
between
technology­
based
emissions
limits
for
chlorine
and
sitespecific
risk­
based
chlorine
emissions
standards.
In
developing
the
final
standards,
however,
EPA
considered
versions
of
the
standards
that
would
require
all
facilities
to
comply
with
the
technologybased
emissions
limits.
This
appendix
presents
the
estimated
costs
and
economic
impacts
of
these
regulatory
alternatives
in
addition
to
estimated
impacts
for
the
regulatory
options
outlined
above.
All
of
the
results
presented
in
this
appendix
reflect
waste
quantity
data
from
EPA's
2003
Biennial
Report.
For
all
of
the
results
presented
in
this
appendix,
we
assume
that
commercial
combustion
facilities
pass
100
percent
of
their
compliance
costs
on
to
their
customers
by
raising
prices.
REVIEW
DRAFT
38
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
­$
14,529,422.75
­$
14,529,422.75
­$
14,335,906.97
­$
16,455,080.68
­$
119,952.52
­$
119,952.52
­$
109,518.09
$
1,596,886.85
­$
167,554.08
­$
167,554.08
­$
528,988.85
­$
505,226.64
$
1,508,640.85
$
1,508,640.85
$
4,124,873.38
$
3,738,975.86
Phase
1
Subtotal
­$
13,308,288.50
­$
13,308,288.50
­$
10,849,540.52
­$
11,624,444.61
$
3,553,022.95
$
3,553,022.95
$
9,026,824.67
$
17,954,164.08
$
29,235,788.46
$
29,274,190.13
$
30,838,362.69
$
41,284,546.73
$
1,332,750.25
$
1,997,880.57
$
1,333,413.62
$
1,334,520.48
$
620,445.81
$
620,445.81
$
620,445.81
$
766,504.85
Phase
2
Subtotal
$
31,188,984.53
$
31,892,516.51
$
32,792,222.13
$
43,385,572.06
$
21,433,718.98
$
22,137,250.96
$
30,969,506.28
$
49,715,291.53
Onsite
Incinerators
Liquid
Boilers
Commercial
Incinerators
Cement
Kilns
LWAKs
Pre­
existing
customers
of
commercial
combustion
facilities
Net
Private
Sector
Costs,
by
Unit
Type
Coal
Boilers
HCl
Production
Furnaces
Total
Final
Standards:
Technology­
and
Risk­
Based
Chlorine
Standards
for
All
Systems
Except
HCl
Production
Furnaces
REVIEW
DRAFT
39
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
$
360,164.22
$
360,164.22
$
2,329,108.56
$
2,327,478.76
$
3,133,757.12
$
3,133,757.12
$
6,625,713.59
$
14,933,927.69
$
105,557.64
$
105,557.64
$
105,557.64
$
756,568.61
$
1,993,191.29
$
1,993,191.29
$
5,560,318.32
$
4,760,891.49
Phase
1
Subtotal
$
5,592,670.26
$
5,592,670.26
$
14,620,698.10
$
22,778,866.56
$
31,336,888.79
$
31,375,290.46
$
32,891,989.71
$
45,023,370.87
$
1,384,272.17
$
2,587,757.24
$
1,384,272.17
$
1,384,272.17
$
620,445.81
$
620,445.81
$
620,445.81
$
766,504.85
Phase
2
Subtotal
$
33,341,606.78
$
34,583,493.51
$
34,896,707.70
$
47,174,147.89
$
38,934,277.04
$
40,176,163.77
$
49,517,405.80
$
69,953,014.45
Private
Sector
Engineering
Costs
Liquid
Boilers
Coal
Boilers
Onsite
Incinerators
HCl
Production
Furnaces
Commercial
Incinerators
Cement
Kilns
Total
LWAKs
Baseline
Prices
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
$
1,089.32
$
1,093.07
$
1,093.07
$
1,098.76
$
1,108.24
$
223.36
$
224.13
$
224.13
$
225.30
$
227.24
$
602.74
$
604.81
$
604.81
$
607.96
$
613.21
$
506.65
$
508.39
$
508.39
$
511.04
$
515.45
$
3,707.66
$
3,720.42
$
3,720.42
$
3,739.77
$
3,772.05
$
1,785.89
$
1,792.04
$
1,792.04
$
1,801.36
$
1,816.91
$
1,089.32
$
1,093.07
$
1,093.07
$
1,098.76
$
1,108.24
$
223.36
$
224.13
$
224.13
$
225.30
$
227.24
$
963.80
$
967.11
$
967.11
$
972.14
$
980.54
$
602.74
$
604.81
$
604.81
$
607.96
$
613.21
$
744.44
$
747.01
$
747.01
$
750.89
$
757.37
$
506.65
$
508.39
$
508.39
$
511.04
$
515.45
Combustion
Prices
($
per
ton)

Waste
Form
Organic
Liquids
(
NonHal)

Inorganic
Liquid
(
Nonhalogenated)

Inorganic
Liquid
(
Halogenated)

Organic
Liquids
(
Halogenated)

Gases
Inorganic
Sludge
(
Nonhalogenated)

Inorganic
Solids
(
NonHal)

Lab
Packs
Organic
Sludges
(
Halogenated)

Organic
Sludges
(
NonHal)

Organic
Solids
(
Halogenated)

Organic
Solids
(
NonHal)

Final
Standards:
Technology­
and
Risk­
Based
Chlorine
Standards
for
All
Systems
Except
HCl
Production
Furnaces
REVIEW
DRAFT
40
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Baseline
Total
Commercial
Incinerators
3
3
3
3
15
Cement
Kilns
0
0
0
0
25
LWAKs
0
0
0
0
7
Onsite
Incinerators
26
26
26
26
92
Liquid
Boilers
8
8
7
11
104
Coal
Boilers
2
2
2
2
12
HCl
Production
Furnaces
0
0
0
0
10
Total
39
39
38
42
265
Number
of
Closed
Systems,
by
Unit
Type
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
To
Commercial
Incinerators
42,722
42,722
42,722
42,722
To
Cement
Kilns
or
LWAKs
2,289
2,289
1,780
3,287
Non­
commercial
Consolidation
13,915
13,915
13,915
13,915
Total
58,926
58,926
58,417
59,924
Quantity
of
Waste
Sent
Offsite
or
Rerouted
(
tons)

Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Commercial
Incinerators
229,597.59
Pre­
MACT
Capacity
(
tons)
463,243.06
105,858.48
105,858.48
105,858.48
462,245.22
105,858.48
463,243.06
Available
Capacity
at
Commercial
Facilities
Cement
Kilns/
LWAKs
Post­
MACT
(
tons)
463,751.96
465,532.26
Final
Standards:
Technology­
and
Risk­
Based
Chlorine
Standards
for
All
Systems
Except
HCl
Production
Furnaces
REVIEW
DRAFT
41
Lost
Gained
Lost
Gained
Lost
Gained
Lost
Gained
Commercial
Incinerators
73.3
2.2
73.3
2.2
73.3
9.6
73.3
9.4
Cement
Kilns
0.0
15.3
0.0
15.3
0.0
33.0
0.0
81.0
LWAKs
0.0
0.9
0.0
0.9
0.0
0.9
0.0
5.2
Onsite
Incinerators
191.8
9.8
191.8
9.8
191.8
21.1
191.8
17.2
Liquid
Boilers
36.0
182.9
36.0
183.1
30.3
195.4
50.7
261.4
Coal
Boilers
9.0
9.1
9.0
13.0
9.0
9.1
9.0
9.1
HCl
Production
Furnaces
0.0
5.6
0.0
5.6
0.0
5.6
0.0
6.4
APCD
Industry
­
90.9
­
92.8
­
124.1
­
169.7
Total
310.2
316.8
310.2
322.8
304.5
398.8
324.9
559.4
Number
of
Jobs
Lost
and
Gained,
by
Unit
Type
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Primary
Floor
Option
Final
Rule
Standards
Annual
Cost
Primary
Floor
Option
$
463,461.17
Final
Rule
Standards
$
463,461.17
Alternative
Floor
Option
1
$
467,456.52
Alternative
Floor
Option
2
$
451,475.11
Government
Costs
Final
Standards:
Technology­
and
Risk­
Based
Chlorine
Standards
for
All
Systems
Except
HCl
Production
Furnaces
REVIEW
DRAFT
42
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
­$
14,217,295.11
­$
14,217,295.11
­$
14,421,611.12
­$
18,604,209.83
­$
512,052.09
­$
512,052.09
­$
406,014.83
$
3,440,395.84
­$
213,890.48
­$
213,890.48
­$
565,983.88
­$
1,089,460.21
$
2,723,616.56
$
2,723,616.56
$
5,276,493.37
$
4,867,372.90
Phase
1
Subtotal
­$
12,219,621.12
­$
12,219,621.12
­$
10,117,116.46
­$
11,385,901.31
$
4,238,949.49
$
4,238,949.49
$
9,574,469.22
$
26,600,036.95
$
33,058,777.58
$
33,097,179.25
$
31,556,273.11
$
48,429,173.70
$
1,655,030.76
$
2,320,161.07
$
1,655,676.98
$
1,657,787.90
$
620,445.81
$
620,445.81
$
620,445.81
$
766,504.85
Phase
2
Subtotal
$
35,334,254.15
$
36,037,786.14
$
33,832,395.91
$
50,853,466.44
$
27,353,582.52
$
28,057,114.50
$
33,289,748.68
$
66,067,602.09
Net
Private
Sector
Costs,
by
Unit
Type
Coal
Boilers
HCl
Production
Furnaces
Total
Onsite
Incinerators
Liquid
Boilers
Commercial
Incinerators
Cement
Kilns
LWAKs
Pre­
existing
customers
of
commercial
combustion
facilities
Final
Standards:
Technology­
Based
Chlorine
Standards
for
All
Systems
REVIEW
DRAFT
43
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
$
964,492.40
$
964,492.40
$
2,795,154.77
$
2,793,524.97
$
3,215,355.47
$
3,215,355.47
$
6,707,311.94
$
23,128,691.38
$
105,557.64
$
105,557.64
$
105,557.64
$
756,568.61
$
3,585,754.95
$
3,585,754.95
$
7,000,501.12
$
6,172,775.58
Phase
1
Subtotal
$
7,871,160.45
$
7,871,160.45
$
16,608,525.46
$
32,851,560.54
$
35,229,195.05
$
35,267,596.72
$
33,660,485.55
$
52,343,863.19
$
1,706,467.63
$
2,909,952.70
$
1,706,467.63
$
1,706,467.63
$
620,445.81
$
620,445.81
$
620,445.81
$
766,504.85
Phase
2
Subtotal
$
37,556,108.50
$
38,797,995.24
$
35,987,398.99
$
54,816,835.67
$
45,427,268.95
$
46,669,155.69
$
52,595,924.45
$
87,668,396.21
Total
LWAKs
HCl
Production
Furnaces
Commercial
Incinerators
Cement
Kilns
Onsite
Incinerators
Liquid
Boilers
Coal
Boilers
Private
Sector
Engineering
Costs
Baseline
Prices
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
$
1,089.32
$
1,093.80
$
1,093.80
$
1,099.34
$
1,117.43
$
223.36
$
224.28
$
224.28
$
225.42
$
229.13
$
602.74
$
605.22
$
605.22
$
608.28
$
618.29
$
506.65
$
508.73
$
508.73
$
511.31
$
519.72
$
3,707.66
$
3,722.90
$
3,722.90
$
3,741.75
$
3,803.32
$
1,785.89
$
1,793.23
$
1,793.23
$
1,802.31
$
1,831.97
$
1,089.32
$
1,093.80
$
1,093.80
$
1,099.34
$
1,117.43
$
223.36
$
224.28
$
224.28
$
225.42
$
229.13
$
963.80
$
967.76
$
967.76
$
972.66
$
988.66
$
602.74
$
605.22
$
605.22
$
608.28
$
618.29
$
744.44
$
747.50
$
747.50
$
751.29
$
763.65
$
506.65
$
508.73
$
508.73
$
511.31
$
519.72
Organic
Sludges
(
Halogenated)

Organic
Sludges
(
NonHal)

Organic
Solids
(
Halogenated)

Organic
Solids
(
NonHal)

Inorganic
Liquid
(
Halogenated)

Organic
Liquids
(
Halogenated)

Gases
Inorganic
Sludge
(
Nonhalogenated)

Inorganic
Solids
(
NonHal)

Lab
Packs
Waste
Form
Organic
Liquids
(
NonHal)

Inorganic
Liquid
(
Nonhalogenated)
Combustion
Prices
($
per
ton)

Final
Standards:
Technology­
Based
Chlorine
Standards
for
All
Systems
REVIEW
DRAFT
44
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Baseline
Total
Commercial
Incinerators
3
3
3
3
15
Cement
Kilns
0
0
0
0
25
LWAKs
0
0
0
0
7
Onsite
Incinerators
26
26
27
27
92
Liquid
Boilers
8
8
7
12
104
Coal
Boilers
2
2
2
2
12
HCl
Production
Furnaces
0
0
0
0
10
Total
39
39
39
44
265
Number
of
Closed
Systems,
by
Unit
Type
Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
To
Commercial
Incinerators
42,722
42,722
42,944
42,944
To
Cement
Kilns
or
LWAKs
2,289
2,289
1,780
3,876
Non­
commercial
Consolidation
13,915
13,915
13,915
13,915
Total
58,926
58,926
58,640
60,736
Quantity
of
Waste
Sent
Offsite
or
Rerouted
(
tons)

Primary
Floor
Option
Final
Rule
Standards
Alternative
Floor
Option
1
Alternative
Floor
Option
2
105,858.48
463,243.06
Available
Capacity
at
Commercial
Facilities
Cement
Kilns/
LWAKs
Post­
MACT
(
tons)
463,751.96
465,532.26
Pre­
MACT
Capacity
(
tons)
463,243.06
105,636.15
105,858.48
105,636.15
461,656.00
Commercial
Incinerators
229,597.59
Fin
al
Sta
nda
rds:
Tec
hno
log
y­
Base
d
Chl
orin
e
Sta
nda
rds
for
All
Syst
ems
REVIEW
DRAFT
45
Lost
Gained
Lost
Gained
Lost
Gained
Lost
Gained
Commercial
Incinerators
73.3
3.9
73.3
3.9
73.3
10.8
73.3
10.6
Cement
Kilns
0.0
15.8
0.0
15.8
0.0
33.4
0.0
119.4
LWAKs
0.0
0.9
0.0
0.9
0.0
0.9
0.0
5.2
Onsite
Incinerators
191.8
16.2
191.8
16.2
199.8
25.8
199.8
21.8
Liquid
Boilers
36.0
202.5
36.0
202.8
30.3
199.5
54.2
295.5
Coal
Boilers
9.0
11.5
9.0
15.4
9.0
11.5
9.0
11.5
HCl
Production
Furnaces
0.0
5.6
0.0
5.6
0.0
5.6
0.0
6.4
APCD
Industry
­
112.2
­
114.1
­
131.7
­
234.2
Total
310.2
368.6
310.2
374.7
312.5
419.3
336.3
704.7
Number
of
Jobs
Lost
and
Gained,
by
Unit
Type
Alternative
Floor
Option
1
Alternative
Floor
Option
2
Primary
Floor
Option
Final
Rule
Standards
Annual
Cost
Primary
Floor
Option
$
463,461.17
Final
Rule
Standards
$
463,461.17
Alternative
Floor
Option
1
$
467,456.52
Alternative
Floor
Option
2
$
447,479.75
Government
Costs
Final
Standards:
Technology­
Based
Chlorine
Standards
for
All
Systems
