IEc
DRAFT:
May
2005
1
To
isolate
the
activities
required
under
the
"
replacement
standards,"
this
analysis
assumes
that
facilities
have
already
completed
upgrades
required
for
full
compliance
with
the
2002
Interim
Standards.

4­
1
COMPLIANCE
COST
ANALYSIS
CHAPTER
4
______________________________________________________________________________

INTRODUCTION
Combustion
facilities
complying
with
the
hazardous
waste
combustion
(
HWC)
maximum
achievable
control
technology
(
MACT)
replacement
standards
will
likely
achieve
the
required
emission
reductions
by
installing
new
pollution
control
devices,
modifying
existing
controls
already
in
place,
limiting
toxics
in
their
waste
feed,
limiting
the
total
waste
feed,
or
through
some
combination
of
the
four.
In
addition,
facilities
will
need
to
comply
with
monitoring,
reporting,
and
record
keeping
requirements
that
are
part
of
the
standards.
This
chapter
of
the
Assessment
focuses
on
the
costs
associated
with
all
potential
activities
necessary
to
achieve
compliance
with
the
HWC
MACT
replacement
standards
for
both
existing
facilities
and
potential
new
sources.
1
We
analyze
costs
incurred
by
facilities,
as
well
as
costs
incurred
by
various
government
entities
as
they
administer
compliance
activities.
The
chapter
is
organized
into
five
sections:


Costing
Methodology.
This
section
explains
our
methodology
for
estimating
the
compliance
costs
associated
with
the
emissions
controls
necessary
under
the
HWC
MACT
replacement
standards.
The
section
also
characterizes
costs
associated
with
other
requirements
of
the
replacement
standards,
such
as
permit
modifications,
testing
and
analysis,
and
reporting
and
record
keeping
requirements.


Results
of
Compliance
Cost
Analysis.
The
results
section
presents
compliance
cost
estimates
for
combustion
systems
and
shows
how
these
costs
vary
across
source
categories,
assuming
all
sources
choose
to
comply
with
the
HWC
MACT
replacement
standards.
IEc
DRAFT:
May
2005
4­
2

Limitations
of
the
Compliance
Cost
Analysis.
This
section
describes
data
limitations
and
uncertainties
that
are
important
to
highlight
as
caveats
to
the
compliance
cost
analysis.


Government
Costs.
This
section
reviews
costs
for
government
entities
as
they
administer
and
enforce
the
HWC
MACT
replacement
standards.


Summary.
We
conclude
the
chapter
with
a
brief
review
of
key
findings
from
the
compliance
cost
analysis.

This
chapter
presents
the
costs
associated
with
full
compliance
with
the
HWC
MACT
replacement
standards.
Because
some
facilities
may
decide
to
stop
burning
hazardous
instead
of
installing
the
pollution
controls
necessary
to
comply
with
the
standards,
the
costs
presented
in
this
chapter
represent
a
high­
end
estimate
of
the
costs
associated
with
the
standards.
We
discuss
how
facilities
might
respond
to
the
HWC
MACT
replacement
standards
in
Chapter
5.

COSTING
METHODOLOGY
Total
compliance
costs
for
existing
hazardous
waste
combustion
facilities
will
depend
on
the
pollution
control
measures
necessary
for
compliance
at
individual
facilities
and
the
costs
associated
with
these
measures.
To
estimate
these
costs,
we
developed
an
engineering
model
that
identifies
the
pollution
control
technologies
required
by
each
individual
system.
Based
on
the
technologies
selected,
the
model
then
generates
system­
specific
estimates
of
HWC
MACT
compliance
costs.
In
addition
to
these
pollution
control
costs,
the
model
includes
other
compliance
costs
associated
with
monitoring
requirements,
sampling
and
analysis,
permit
modifications,
and
other
record
keeping
and
reporting
requirements.
Some
of
these
component
costs
may
be
specific
to
individual
combustion
systems,
while
others
are
consistent
across
all
systems
within
a
source
category
(
e.
g.,
cement
kilns)
or
across
the
entire
HWC
MACT
universe.
Exhibit
4­
1
provides
an
overview
of
the
procedure
used
in
this
system­
specific
compliance
cost
analysis.
IEc
DRAFT:
May
2005
4­
3
Exhibit
4­
1
OVERVIEW
OF
SYSTEM­
SPECIFIC
COMPLIANCE
COST
ANALYSIS
Set
allowable
emissions
for
HAPs
of
concern
Baseline
emissions
for
actual
combustion
systems
included
in
the
model
APCDs
currently
in
place
Calculate
%

reduction
required
for
each
HAP
Gas
flow
rate
Total
chlorine
in
feed
System
type
Evaluate
what
new
APCDs
or
DOMs
would
be
required
to
achieve
the
emissions
reduction
(
accounts
for
joint
control
of
multiple
HAPs)

Estimate
HW
feed
control
costs
and/
or
retrofit
costs
KEY
Input
Process/
Calculation
Output/
Result
NOTES
1.
Setting
of
allowable
emissions
for
hazardous
air
pollutants
(
HAPs)
based
on
MACT
analysis
using
Trial
Burn
Reports.
Baseline
emissions
also
determined
using
Trial
Burn
Reports
(
measured
at
the
stack)
and
imputation.
See
U.
S.
EPA,
Technical
Support
Document
for
HWC
MACT
Standards,
Volume
II:
HWC
Database,
forthcoming
February
2004.

2.
All
other
data
inputs
from
U.
S.
EPA,
Draft
Technical
Support
Document
for
HWC
MACT
Standards,
Volume
II:
HWC
Database,
June
2005.

3.
A
DOM
is
a
design,
operation,
or
maintenance
change
to
an
existing
Air
Pollution
Control
Device
(
APCD).
CEMs
are
continuous
emission
monitoring
systems.

Add
additional
compliance
costs
(
e.
g.,
CEMs,
permitting)
Total
new
compliance
costs
per
system
Stack
moisture
Temperature
at
APCD
inlet
Select
standards
IEc
DRAFT:
May
2005
4­
4
IEc
DRAFT:
May
2005
2
Feed
control
costs
in
this
analysis
are
based
on
the
cost
of
the
technology
retrofit
that
would
potentially
be
required
to
control
the
pollutant
in
the
absence
of
feed
control.
For
any
given
system,
we
estimate
feed
control
costs
by
multiplying
the
cost
of
the
corresponding
retrofit
technology
by
the
ratio
of
the
emission
reduction
required
by
the
standards
to
the
emission
reduction
achievable
with
the
retrofit
technology.
Since
such
technologies
are
generally
more
expensive
per
ton
of
reduced
emissions
than
feed
control,
the
estimates
of
feed
control
costs
presented
in
this
analysis
are
upper
bound
estimates.
A
more
detailed
discussion
of
the
feed
control
cost
analysis
is
found
in
the
U.
S.
EPA,
Draft
Technical
Support
Document
for
the
HWC
MACT
Standards,
Volume
V:
Emission
Estimates
and
Engineering
Costs,
June
2005.

4­
5
Air
Pollution
Control
Measures
The
engineering
model
that
we
used
for
this
analysis
assigns
control
technologies
and
their
associated
costs
to
individual
combustion
systems
based
on
a
variety
of
system­
specific
parameters,
including
system
type
(
e.
g.,
liquid
injection,
rotary
kiln,
coal
boiler),
gas
flow
rate,
and
kiln
temperature.
The
control
methods
selected
may
include
the
installation
of
new
air
pollution
controls,
the
modification
of
existing
controls,
or
hazardous
waste
feed
control
(
i.
e.,
limiting
the
total
volume
of
waste
or
the
amount
of
toxics
in
the
waste
feed).
2
Exhibit
4­
2
presents
more
detail
on
these
options.

A
facility's
selection
of
control
technologies
in
response
to
the
HWC
MACT
replacement
standards
is
likely
to
depend
significantly
on
the
emissions
reductions
required
for
compliance
with
the
standards.
Therefore,
the
engineering
cost
model
that
we
used
for
the
compliance
cost
analysis
compares
each
system's
baseline
emissions
(
i.
e.,
emissions
reflecting
full
compliance
with
the
2002
Interim
Standards)
to
its
emissions
requirements
under
the
HWC
MACT
replacement
standards.
For
each
combustion
system,
the
engineering
model
subtracts
the
maximum
emissions
allowed
under
the
replacement
standards
from
the
system's
baseline
emissions
to
determine
the
reduction
required
for
compliance.
For
example,
a
liquid
boiler
with
baseline
mercury
emissions
of
15
µ
g/
dscm
would
need
to
reduce
its
mercury
emissions
by
33.3
percent
to
comply
with
the
corresponding
HWC
MACT
replacement
standard
of
10
µ
g/
dscm.

Percent
Emissions
Reduction
=
Baseline
Emission
Level
­
MACT
Standard
Baseline
Emission
Level
=
(
15
­
10)
/
15
=
0.333
=
33.3%.
IEc
DRAFT:
May
2005
4­
6
Exhibit
4­
2
AIR
POLLUTION
CONTROL
MEASURES
ASSIGNED
IN
COMPLIANCE
COST
ANALYSIS
Pollutant
Pollution
Control
Measures
Comments
PM,
Low­
Volatile
Metals,
Semi­
Volatile
Metals
C
Fabric
Filter
C
Feed
Control
(
SVM/
LVM
only)

C
Make
improvements
to
existing
control
devices
Depending
on
flue
gas
temperature
and
other
site­
specific
factors,
additional
flue
gas
cooling
equipment
(
e.
g.,
water
quench)
may
be
required
to
integrate
the
fabric
filter
into
any
existing
wet
scrubbing
systems.

HCl
and
Chlorine
C
Packed
Tower
Scrubber
C
Spray
Tower
Scrubber
C
Feed
Control
C
Make
improvements
to
existing
control
devices
Mercury
C
Carbon
Injection/
Carbon
Bed
C
Feed
Control
Carbon
injection
must
be
accompanied
by
a
dry
particulate
matter
(
PM)
control
device.

Dioxin/
Furan
C
Temperature
Control
C
Carbon
Injection/
Carbon
Bed
Temperature
control
applicable
only
for
systems
operating
at
higher
temperatures.

Notes:
1.
"
Draft
Technical
Support
Document
for
the
HWC
MACT
Standards,
Volume
V:
Emission
Estimates
and
Engineering
Costs,"
U.
S.
Environmental
Protection
Agency.
June
2005.
2.
Control
measures
assigned
in
compliance
cost
analysis
include
installation
of
new
devices,
changes
in
design,
operation,
and
maintenance
(
DOM)
to
existing
devices,
or
adoption
of
waste
feed
control
for
particular
constituents.
3.
Controls
for
CO
and
hydrocarbons
are
not
presented
here
because
the
CO/
HC
standards
do
not
require
facilities
to
achieve
additional
reductions
in
CO/
HC
emissions.

After
estimating
the
percentage
reduction
in
emissions
required
for
compliance,
the
engineering
cost
model
then
identifies
the
control(
s)
that
most
cost­
effectively
achieve(
s)
the
emissions
reductions
required
under
the
replacement
standards.
The
cost
of
these
measures
represent
the
retrofit
costs
for
the
system
in
question.

Administrative
Compliance
Costs
In
addition
to
the
pollution
control
measures
necessary
to
reduce
emissions,
combustion
systems
will
also
incur
costs
associated
with
administrative
requirements
of
the
HWC
MACT
replacement
standards.
As
shown
in
Exhibit
4­
3,
these
costs
total
approximately
$
7.4
million
annually
IEc
DRAFT:
May
2005
3
There
are
141
commercial
combustion
units
in
the
HWC
MACT
universe.
However,
one
LWAK
facility
has
four
units
but
just
three
air
pollution
control
systems.
Similarly,
another
LWAK
facility
has
three
units
but
only
two
air
pollution
control
systems.

4
Draft
Technical
Support
Document
for
the
HWC
MACT
Standards,
Volume
V:
Emission
Estimates
and
Engineering
Costs,
U.
S.
Environmental
Protection
Agency.
June
2005.

5
There
will
be
additional
costs
for
"
problematic"
sources
(
e.
g.,
those
facilities
currently
not
demonstrating
compliance
with
RCRA
destruction
and
reduction
efficiency
(
DRE)
standards).
These
additional
costs
are
not
included
in
our
estimates
because
they
would
be
incurred
absent
the
HWC
MACT
replacement
standards.

6
This
estimate
is
based
on
EERGC's
communication
with
several
facilities
during
the
preparation
of
the
1999
Assessment.

4­
7
for
the
126
boilers
and
industrial
furnace
systems
and
the
139
incinerator
and
commercial
kiln
systems
in
the
HWC
MACT
universe.
3
Boilers
and
HCl
production
furnaces
incur
most
of
these
costs
because
incinerators
and
commercial
kilns
already
meet
many
of
these
requirements
under
the
2002
Interim
Standards.

$
Performance
Testing
Requirements:
With
an
annual
cost
of
$
4.7
million,
performance
testing
requirements
represent
most
of
the
administrative
compliance
costs
of
the
HWC
MACT
replacement
standards.
4
These
costs
reflect
stack
sampling
for
metals,
PM,
dioxins/
furans,
total
chlorine,
and
organics
under
two
worst­
case
operating
scenarios
analyzed
once
every
five
years,
as
required
by
the
standards.
5
$
Permitting
and
Other
Reporting
and
Record
Keeping
Requirements:
The
HWC
MACT
replacement
standards
require
facilities
to
complete
a
number
of
record
keeping
and
reporting
procedures
associated
with
permitting
and
other
compliance
activities.
These
record
keeping
and
reporting
procedures
apply
to
both
new
compliance
activities
as
well
as
to
modifications
of
existing
Clean
Air
Act
(
CAA)
and
Resource
Conservation
and
Recovery
Act
(
RCRA)
permitting
and
compliance
measures.
We
estimate
that
facilities
will
incur
approximately
$
769,000
in
reporting
and
record
keeping
costs
due
to
the
replacement
standards.

$
Shutdown
Costs:
We
also
investigated
the
significance
of
shutdown
costs
associated
with
the
installation
of
pollution
control
equipment
or
the
implementation
of
other
pollution
control
measures
required
under
the
replacement
standards.
Our
examination
of
facility
shutdown
periods
suggests
that
facilities
could
install
pollution
controls
during
routine
maintenance
shutdowns
(
which
we
assume
require
at
least
three
weeks
per
year).
6
Because
virtually
all
the
technologies
that
may
be
adopted
in
response
to
the
replacement
standards
have
an
installation
time
of
three
weeks
or
less,
we
assume
that
a
facility
could
install
all
of
its
retrofits
simultaneously
during
a
single
facility
shutdown,
suggesting
that
no
additional
shutdown
time
will
IEc
DRAFT:
May
2005
4­
8
be
necessary
for
most
facilities.
IEc
DRAFT:
May
2005
4­
9
Exhibit
4­
3
SUMMARY
OF
OTHER
COMPLIANCE
COST
COMPONENTS
(
year
2002
dollars)

Compliance
Component
Annual
Cost
per
Respondent/
Activity
Annual
Estimated
Number
of
Systems
Estimated
Total
Annual
Costsb
Incinerators
and
Commercial
Kilnsb
Boilers
and
HCl
Production
Furnaces
Incinerators
and
Commercial
Kilnsa
Boilers
and
HCl
Production
Furnaces
Reading
of
the
Regulations
(
See
Note
5)
$
750
$
750
139
126
$
198,750
Compliance
with
Standards
and
General
Requirements
(
e.
g.,
weekly
testing
of
the
automatic
waste
feed
cutoff
(
AWFCO)
system
and
operating
and
maintenance
plan)
$
0
$
2,500
139
126
$
315,000
Performance
Testing
Requirements
$
10,000
$
26,100
139
126
$
4,678,600
Operator
Certification
and
Training
$
0
$
3,250
139
126
$
409,500
Operating
and
Maintenance
Plan
$
0
$
1,550
139
126
$
195,300
Notification
and
General
Reporting
and
Record
Keeping
Requirements
(
e.
g.,
Notice
of
Intent
to
Comply
(
NIC)
with
standards)
$
1,000
$
5,000
139
126
$
769,000
Startup,
Shutdown,
and
Malfunction
Plan
$
0
$
1,050
139
126
$
132,300
Feedstream
Analysis
Plan
$
0
$
2,800
139
126
$
352,800
CMS
and
CEMS
Requirements
$
0
$
2,250
139
126
$
283,500
Emergency
Safety
Vent
Plan
$
0
$
150
139
126
$
18,900
ESTIMATED
TOTAL
ANNUAL
INCREMENTAL
IMPACT
=
$
7,353,650
Notes:
a.
Incinerator
and
commercial
kiln
costs
are
lower
than
boiler
and
industrial
furnace
costs
because
the
former
already
meet
many
of
these
requirements
under
the
2002
Interim
Standards.

b.
Estimated
annual
costs
are
calculated
based
on
the
cost
per
activity
multiplied
by
the
estimated
number
of
systems
performing
each
activity
per
year.
Totals
may
not
add
due
to
rounding.

Source:
U.
S.
EPA,
Supporting
Statement
for
EPA
Information
Collection
Request
#
1773.10
"
New
and
Amended
Reporting
and
Recordkeeping
Requirements
for
National
Emissions
Standards
for
Hazardous
Air
Pollutants
from
Hazardous
Waste
Combustors,"
October
2003.
IEc
DRAFT:
May
2005
4­
10
RESULTS
OF
COMPLIANCE
COST
ANALYSIS
FOR
EXISTING
SOURCES
Excluding
administrative
costs,
we
expect
that
each
combustion
system
on
average
will
spend
between
approximately
$
3,330
and
$
274,200
annually
to
comply
with
the
Agency
Preferred
Approach,
as
shown
in
Exhibit
4­
4.
This
variation
reflects
differences
in
the
replacement
standards
across
source
categories.
For
example,
as
outlined
in
Chapter
1,
the
liquid
boiler
standard
for
mercury
emissions
is
10
µ
g/
dscm
while
the
corresponding
LWAK
standard
is
120
µ
g/
dscm.
In
addition,
the
variation
in
costs
shown
in
Exhibit
4­
4
is
consistent
with
differences
in
emissions
across
source
categories.
Although
the
LWAK
standard
for
PM
is
more
stringent
than
the
liquid
boiler
standard,
the
average
LWAK
system
emits
approximately
6,100
pounds
of
PM
per
year,
while
liquid
boilers
on
average
emit
nearly
49,000
pounds
of
PM
per
year.
Consequently,
compliance
costs
associated
with
PM
controls
are
much
higher
for
liquid
boilers
than
for
LWAKs.
Exhibit
4­
4
also
shows
that
costs
do
not
differ
significantly
between
the
Option
A
Floor
and
the
Agency
Preferred
Approach,
which
reflects
the
similarities
between
these
two
regulatory
options.
Exhibits
4­
5
and
4­
6
present
additional
detail
associated
with
the
results
presented
in
Exhibit
4­
4.

Exhibit
4­
5
shows
the
percentage
of
combustion
systems
requiring
each
specific
control
measures
under
each
MACT
option.
As
shown
in
Exhibit
4­
5,
feed
control
is
required
by
all
system
types
under
all
four
regulatory
options.
For
LWAKs
and
HCl
production
furnaces,
we
anticipate
that
feed
control
will
be
the
only
control
measure
necessary
to
comply
with
the
replacement
standards.
In
addition,
we
expect
that
most
liquid
boilers
and
cement
kilns
will
implement
feed
control
to
limit
their
emissions
under
all
four
versions
of
the
standards.
As
shown
in
Exhibit
4­
6,
feed
control
also
represents
a
significant
portion
of
system
costs.
However,
because
feed
control
is
a
relatively
inexpensive
approach
for
controlling
emissions,
feed
control
costs
represent
a
smaller
portion
of
costs
than
other
technologies
adopted
by
fewer
systems.
For
example,
although
21
percent
of
on­
site
incinerators
are
expected
to
use
feed
control
to
limit
emissions
under
the
Agency
Preferred
Approach,
feed
control
represents
just
6
percent
of
on­
site
incinerator
costs.
In
contrast,
only
9
percent
of
onsite
incinerator
systems
are
expected
to
install
a
new
quench,
but
costs
associated
with
this
technology
represent
24
percent
of
on­
site
incinerator
costs.
IEc
DRAFT:
May
2005
4­
11
Exhibit
4­
4
AVERAGE
COMPLIANCE
COSTS
PER
COMBUSTION
SYSTEMa
(
Assuming
No
Market
Exit,
2002
dollars)

MACT
Option
Cement
Kilns
LWAKs
Commercial
Incinerators
On­
site
Incinerators
Liquid
Boilers
Coal
Boilers
HCl
Production
Furnaces
Option
A
Floor
$
113,600
$
3,330
$
55,360
$
14,295
$
273,879
$
69,956
$
16,645
Agency
Preferred
Approach
$
113,600
$
3,330
$
55,360
$
14,295
$
274,243
$
170,246
$
16,645
Option
C
Floor
$
253,279
$
3,330
$
143,524
$
50,305
$
270,869
$
69,956
$
16,645
Option
D
Floor
$
585,607
$
96,331
$
143,415
$
41,930
$
387,517
$
69,956
$
31,250
Notes:

a.
Estimates
calculated
assuming
all
facilities
upgrade
to
comply
with
the
HWC
MACT
replacement
standards.
Estimates
do
not
include
permitting
and
other
costs
listed
in
Exhibit
4­
3.
IEc
DRAFT:
May
2005
4­
12
Exhibit
4­
5
PERCENTAGE
OF
SYSTEMS
REQUIRING
CONTROL
MEASURES
Control
Measure
Option
A
Floor
Agency
Preferred
Approach
Option
C
Floor
Option
D
Floor
Cement
Kilns
DESP
Improvements
48.00%
48.00%
48.00%
68.00%
Fabric
Filter
Improvements
8.00%
8.00%
8.00%
4.00%
Feed
Control
88.00%
88.00%
92.00%
100.00%
Lightweight
Aggregate
Kilns
Feed
Control
42.86%
42.86%
42.86%
71.43%
Commercial
Incinerators
DESP
Improvements
0.00%
0.00%
0.00%
6.67%
Fabric
Filter
Improvements
46.67%
46.67%
46.67%
53.33%
DOM
High­
Energy
Wet
Scrubber
6.67%
6.67%
6.67%
20.00%
Quench
60.00%
60.00%
60.00%
60.00%
Feed
Control
46.67%
46.67%
93.33%
93.33%
Onsite
Incinerators
Fabric
Filter
1.23%
1.23%
1.23%
2.47%
DESP
Improvements
3.70%
3.70%
3.70%
6.17%
Fabric
Filter
Improvements
75.31%
75.31%
75.31%
69.14%
DOM
High­
Energy
Wet
Scrubber
8.64%
8.64%
8.64%
13.58%
Quench
8.64%
8.64%
8.64%
8.64%
Feed
Control
20.99%
20.99%
75.31%
67.90%
Liquid
Boilers
New
Fabric
Filter
54.81%
54.81%
54.81%
90.38%
Carbon
Injection
0.00%
0.96%
0.00%
0.00%
DESP
Improvements
2.88%
2.88%
2.88%
0.00%
Fabric
Filter
Improvements
0.96%
0.96%
0.96%
1.92%
DOM
High­
Energy
Wet
Scrubber
1.92%
1.92%
1.92%
0.00%
Quench
0.96%
0.96%
0.96%
0.96%
Feed
Control
71.15%
69.23%
69.23%
90.38%
Coal
Boilers
DESP
Improvements
41.67%
83.33%
41.67%
41.67%
Fabric
Filter
Improvements
0.00%
16.67%
0.00%
0.00%
Feed
Control
75.00%
33.33%
75.00%
75.00%
HCl
Production
Furnaces
Feed
Control
40.00%
40.00%
40.00%
60.00%
Note:
Percentages
in
this
exhibit
are
not
additive.
Each
combustion
system
may
require
one
or
more
control
measures.
Source:
EERGC
Inc.,
April
2005.
IEc
DRAFT:
May
2005
4­
13
Exhibit
4­
6
PERCENT
OF
TOTAL
NEW
COMPLIANCE
COSTS
BY
CONTROL
MEASURE
Control
Measure
Option
A
Floor
Agency
Preferred
Approach
Option
C
Floor
Option
D
Floor
Cement
Kilns
DESP
Improvements
14.84%
14.84%
6.66%
15.72%
Fabric
Filter
Improvements
6.53%
6.53%
2.93%
2.62%
Feed
Controls
78.62%
78.62%
90.41%
81.66%
Lightweight
Aggregate
Kilns
Feed
Control
100.00%
100.00%
100.00%
100.00%
Commercial
Incinerators
DESP
Improvements
0.00%
0.00%
0.00%
1.05%
Fabric
Filter
Improvements
13.72%
13.72%
5.29%
16.00%
DOM
High­
Energy
Wet
Scrubber
5.36%
5.36%
2.07%
16.43%
Quench
70.47%
70.47%
27.18%
27.20%
Feed
Control
10.44%
10.44%
65.46%
39.32%
Onsite
Incinerators
Fabric
Filter
6.36%
6.36%
1.81%
5.32%
DESP
Improvements
2.37%
2.37%
0.67%
7.26%
Fabric
Filter
Improvements
47.80%
47.80%
13.58%
24.46%
DOM
High­
Energy
Wet
Scrubber
12.71%
12.71%
3.61%
10.95%
Quench
24.45%
24.45%
6.95%
8.34%
Feed
Control
6.31%
6.31%
73.38%
43.67%
Liquid
Boilers
Fabric
Filter
45.35%
45.29%
45.85%
54.74%
Carbon
Injection
0.00%
0.00%
0.00%
0.00%
DESP
Improvements
1.48%
1.48%
1.50%
0.00%
Fabric
Filter
Improvements
0.07%
0.07%
0.07%
0.05%
DOM
High­
Energy
Wet
Scrubber
0.45%
0.45%
0.45%
0.00%
Quench
0.18%
0.46%
0.18%
0.13%
Feed
Control
52.47%
52.26%
51.94%
45.08%
Coal
Boilers
DESP
Improvements
27.19%
59.69%
27.19%
27.19%
Fabric
Filter
0.00%
26.35%
0.00%
0.00%
Feed
Control
72.81%
13.96%
72.81%
72.81%
HCl
Production
Furnaces
Feed
Control
100.00%
100.00%
100.00%
100.00%
Source:
EERGC
Inc.,
April
2005.
IEc
DRAFT:
May
2005
7
The
compliance
cost
estimates
for
cement
kilns
do
not
take
into
account
the
Portland
Cement
MACT,
which
addresses
non­
hazardous
cement
kilns.
If
the
Portland
Cement
MACT
is
accounted
for
in
these
estimates,
the
compliance
costs
for
cement
kilns
under
proposed
hazardous
waste
combustion
MACT
replacement
standards
would
likely
be
lower.

4­
14
Compliance
costs
vary
even
more
markedly
when
comparing
across
individual
systems
within
a
given
source
category.
The
following
compliance
cost
results
for
the
Agency
Preferred
Approach
illustrate
the
wide
variability
across
specific
combustion
systems:


Cement
Kilns
­­
Annual
per­
system
compliance
costs
range
from
$
0
to
$
718,100
with
an
average
cost
of
$
113,600
per
system.
7

Commercial
Incinerators
­­
Annual
per­
system
compliance
costs
range
from
$
14,200
to
$
127,500,
with
an
average
cost
of
$
55,400
per
system.


LWAKs
­­
Annual
per­
system
compliance
costs
range
from
$
0
to
$
18,600,
with
an
average
cost
of
$
3,300
per
system.


On­
Site
Incinerators
­­
Annual
per­
system
compliance
costs
range
from
$
0
to
$
89,500,
with
an
average
cost
of
$
14,300
per
system.


Liquid
Boilers
 
Annual
per­
system
compliance
costs
range
from
$
0
to
$
1,603,700,
with
an
average
of
$
274,200
per
system.


Coal
Boilers
 
Annual
per­
system
compliance
costs
range
from
$
67,700
to
$
315,100,
with
an
average
of
$
170,200
per
system.


HCl
Production
Furnaces
 
Annual
per­
system
compliance
costs
range
from
$
0
to
$
130,400,
with
an
average
of
$
16,600.

COMPLIANCE
COSTS
FOR
NEW
COMBUSTION
SOURCES
While
most
of
this
analysis
focuses
on
the
HWC
MACT
replacement
standards
for
existing
sources,
this
Assessment
also
evaluates
the
HWC
MACT
replacement
standards
for
new
facilities
constructed
or
reconstructed
after
the
proposal
date
of
the
replacement
standards.
New
sources
are
not
included
in
the
universe
of
systems
included
in
our
compliance
cost
analysis
because
systemspecific
data
are
not
yet
available
for
these
systems.
However,
we
estimate
that
costs
for
new
sources
will
be
negligible
in
the
short
run
because
very
few
new
combustion
sources
are
expected
to
go
online
during
the
next
several
years.
Of
the
few
sources
planned,
a
significant
portion
are
U.
S.
Department
of
Defense
incinerators
specializing
in
the
treatment
of
chemical
weapons.
Since
these
facilities
will
IEc
DRAFT:
May
2005
8
Personal
communication
with
Bruce
Springsteen
of
EERGC,
September
16,
2003.

9
For
more
information
on
the
approach
taken
for
estimating
emissions
reduction
requirements,
see
U.
S.
EPA,
Draft
Technical
Support
Document
for
HWC
MACT
Standards,
Volume
V:
Emissions
Estimates
and
Engineering
Costs,
June
2005.

4­
15
treat
waste
posing
a
significant
threat
to
human
health,
we
assume
that
they
will
be
equipped
with
state­
of­
the­
art
control
technologies,
even
in
the
absence
of
the
HWC
MACT
replacement
standards.
In
addition,
past
experience
indicates
that
most
new
sources
tend
to
be
designed
to
cost­
effectively
incorporate
the
most
technologically
advanced
control
devices.
8
We
therefore
assume
that
new
sources
will
not
incur
significant
costs
to
comply
with
the
HWC
MACT
replacement
standards.

LIMITATIONS
OF
THE
COMPLIANCE
COST
ANALYSIS
This
analysis
of
compliance
costs
associated
with
the
HWC
MACT
replacement
standards
is
limited
by
a
number
of
uncertainties.
The
most
significant
of
these
uncertainties
are
as
follows:


Available
emissions
data
are
limited
for
some
facilities.
Emissions
data
are
based
on
trial
burns
required
of
individual
combustion
systems,
but
information
for
some
pollutants
often
is
not
available.
In
these
cases,
the
emissions
reduction
requirements
are
assigned
to
systems
according
to
the
underlying
statistical
distribution
for
each
pollutant
(
which
is
based
on
emissions
of
the
pollutant
at
facilities
where
data
are
available).
9

Due
to
data
limitations
with
respect
to
waste
feed
characteristics,
it
is
difficult
to
determine
the
extent
to
which
feed
control
may
be
used
as
a
feasible
alternative
method
of
compliance
with
the
HWC
MACT
replacement
standards.

As
a
result
of
these
limitations,
individual
combustion
system
decision­
making
may
result
in
actual
compliance
behavior
different
than
that
predicted
in
the
engineering
cost
model
used
for
this
analysis.
While
uncertainty
exists,
we
do
not
believe
that
compliance
costs
are
systematically
biased
either
upward
or
downward.

ROLE
OF
SITE­
SPECIFIC
RISK
ASSESSMENTS
As
part
of
the
HWC
MACT
replacement
standards
rulemaking,
the
Agency
is
explicitly
codifying
the
authority
for
permit
writers
to
evaluate
the
need
for
and,
where
appropriate,
require
Site
Specific
Risk
Assessments
(
SSRAs).
The
Agency
is
also
codifying
the
authority
for
permit
writers
to
add
conditions
to
RCRA
permits
that
they
determine
are
necessary
to
protect
human
health
and
IEc
DRAFT:
May
2005
10
The
policy
regarding
site
specific
risk
assessments
(
SSRAs)
originated
as
part
of
EPA's
1994
final
Combustion
Strategy,
and
a
revised
Site­
Specific
Risk
Assessment
Policy
was
articulated
as
part
of
the
1999
HWC
MACT
standards
rulemaking.
EPA
provided
further
clarification
of
the
appropriate
use
of
the
SSRA
policy
and
technical
guidance
in
an
April
10,
2003
memorandum
from
Marianne
Lamont
Horinko,
Assistant
Administrator
for
OSWER,
to
the
EPA
Regional
Administrators
titled
Use
of
the
Site­
Specific
Risk
Assessment
Policy
and
Guidance
for
Hazardous
Waste
Combustion
Facilities.
This
document
is
available
in
the
docket
(
Docket
#
RCRA­
2003­
0016).

11
EPA
estimates
that
in
approximately
33
percent
of
the
cases
where
there
is
a
need
for
an
SSRA,
the
permitting
authority
incurs
some
or
all
of
the
cost
of
conducting
the
study.

4­
16
the
environment
based
on
the
results
of
an
SSRA.
The
intent
is
to
change
the
regulatory
mechanism
that
is
the
basis
for
SSRAs
while
retaining
the
same
SSRA
policy
from
a
substantive
standpoint
for
combustion
facilities.
10
SSRAs
are
currently
implemented
as
part
of
the
RCRA
permitting
process
to
address
cases
in
which
existing
practices
and
standards
(
including
MACT
standards)
may
not
be
fully
protective
of
human
health
and
the
environment.
The
policy
recommends
that
for
hazardous
waste
combustors
subject
to
the
replacement
standards,
permitting
authorities
should
evaluate
the
need
for
an
SSRA
on
a
case­
by­
case
basis.
While
SSRAs
are
not
anticipated
to
be
necessary
for
every
facility,
they
should
be
conducted
where
there
is
some
reason
to
believe
that
operation
in
accordance
with
the
HWC
MACT
replacement
standards
alone
may
not
be
fully
protective
of
human
health
and
the
environment.
Should
the
SSRA
demonstrate
that
supplemental
requirements
are
needed
to
protect
human
health
and
the
environment,
additional
conditions
and
limitations
should
be
included
in
the
facility's
RCRA
permit
pursuant
to
the
omnibus
authority.

Facilities
that
must
conduct
an
SSRA
will
incur
either
a
portion
of
the
cost
(
i.
e.,
the
permitting
authority
conducts
the
SSRA)
or
the
entire
cost
to
conduct
the
risk
assessment.
11
This
analysis
assesses
the
potential
facility­
level
costs
of
conducting
an
SSRA
under
various
conditions.

To
assess
the
potential
magnitude
of
these
costs,
EPA
examined
typical
costs
associated
with
risk
assessments
conducted
in
support
of
SSRAs.
Our
analysis
indicates
that
the
cost
of
an
SSRA
for
a
facility
operating
under
normal
conditions
is
likely
to
be
between$
157,000
and
$
220,000,
including
costs
associated
with
the
collection
of
risk
data
concurrent
with
a
performance
burn
and
the
collection
of
other
relevant
data.
Excluding
data
collection
costs,
SSRAs
for
facilities
operating
under
normal
conditions
cost
approximately
$
84,000.
SSRA
cost
data
and
public
comments
received
by
EPA
suggest
that
the
cost
of
collecting
risk
data
during
performance
tests
is
IEc
DRAFT:
May
2005
12
A
risk
burn
is
an
emissions
test
designed
to
collect
data
specifically
for
a
site
specific
risk
assessment.
However,
facilities
are
often
able
to
obtain
the
information
otherwise
gathered
through
a
risk
burn
during
their
normally
scheduled
trial
burns,
which
are
tests
of
facilities'
ability
to
meet
the
performance
standards
set
forth
in
the
rule.

13
Note
that
this
estimate
is
considerably
less
than
a
cost
range
provided
by
the
Cement
Kiln
Recycling
Coalition
of
$
200,000
to
$
1,000,000
(
with
an
upper
bound
of
$
1,300,000).
EPA's
research
suggested
that
the
costs
of
conducting
SSRAs
have
decreased
in
recent
years.
A
full
comparative
discussion
of
the
cost
estimates
is
available
in
the
document
Hazardous
Waste
Combustion
MACT
­
Replacement
Standards:
Proposed
Rule.
Preliminary
Cost
Assessment
for
Site
Specific
Risk
Assessment,
November,
2003,
included
in
the
rulemaking
docket.

14
A
limited
number
of
facilities
may
need
to
conduct
a
full
risk
burn,
which
costs
approximately
$
286,000,
if
collecting
data
during
performance
testing
is
not
possible.

15
SSRAs
under
unusual
conditions
require
site
specific
modeling,
extensive
interactions
with
stakeholders
and
regulators,
and
targeted
ecological
analyses.
In
contrast,
for
SSRAs
under
normal
conditions,
we
assume
the
following:
use
of
previously
collected
performance
burn
data,
use
of
standard
commercial
modeling
software
consistent
with
Agency
guidance,
and
limited
interaction
with
state
and
Federal
oversight
authorities.

16
Since
this
initial
analysis
in
2003,
EPA
has
identified
additional
facilities
to
include
in
the
HWC
MACT
universe
that
are
not
included
in
this
number.
However,
because
of
anecdotal
evidence
suggesting
that
several
SSRAs
that
were
in
progress
in
2003
are
now
complete,
we
do
not
adjust
this
estimate
upward.
In
addition,
this
is
a
high­
end
estimate
that
includes
some
facilities
for
which
a
final
determination
has
not
been
reached.

17
Information
provided
by
EPA
staff,
July
2003.

4­
17
approximately
20­
40
percent
of
the
cost
associated
with
a
full
risk
burn.
12
Therefore,
we
estimate
that
these
costs
range
from
$
57,000
to
$
115,000.13,14
Other
data
collection
costs
are
between
$
16,000
and
$
22,000
per
facility,
depending
on
the
level
of
effort
required.

For
a
limited
number
of
facilities
operating
under
unusual
conditions,
SSRA
costs
may
be
as
high
as
$
815,000.15
For
such
facilities,
collecting
risk
data
during
a
performance
test
may
not
be
feasible
or
appropriate,
in
which
case
these
facilities
need
to
conduct
a
full
risk
burn,
which
costs
approximately
$
286,000
per
facility.
We
also
estimate
that
facilities
operating
under
unusual
conditions
will
incur
$
41,000
in
costs
associated
with
the
collection
of
other
data
required
for
an
SSRA.
In
addition,
because
of
the
unusual
conditions
at
these
facilities,
the
cost
of
their
SSRA
activities
other
than
data
collection
is
approximately
$
488,000
per
facility.

Information
available
from
EPA
regions
suggests
that
SSRAs
are
necessary
for
most
hazardous
waste
combustion
facilities.
As
of
July
2003,
available
data
from
EPA
regions
suggested
that
98
of
the
145
facilities
in
the
HWC
MACT
universe
are
either
in
the
process
of
conducting
an
SSRA
or
could
be
required
to
conduct
one
at
a
later
date.
16,17
For
these
facilities,
the
total
cost
of
the
SSRA
process
might
be
affected
by
the
HWC
MACT
replacement
standards.
Of
the
98
facilities
that
EPA
identified,
five
are
believed
to
be
operating
under
unusual
conditions.
IEc
DRAFT:
May
2005
4­
18
IEc
DRAFT:
May
2005
18
The
analysis
assumes
that
the
risk
assessment
will
be
expensed
over
five
years
as
a
non­
capital
cost.

4­
19
While
implementation
of
the
HWC
MACT
replacement
standards
may
reduce
the
need
for
SSRAs,
it
is
difficult
to
project
how
significant
such
a
reduction
may
be.
Although
the
replacement
standards
are
generally
more
stringent
than
both
the
Interim
Standards
and
the
1999
Standards,
certain
conditions
may
require
additional
protective
measures.
For
example,
thermal
emissions
standards
under
the
HWC
MACT
replacement
standards,
which
restrict
HAP
emissions
per
unit
of
energy
in
the
waste
feed,
will
not
address
the
contribution
of
non­
hazardous
wastes
or
raw
materials
to
a
combustor's
total
emissions.
SSRAs
may
continue
to
be
needed
in
some
cases
to
address
these
emissions.
In
addition,
certain
site­
specific
factors
or
circumstances
beyond
the
standards
themselves
may
affect
the
decision
to
require
an
SSRA
for
an
individual
combustor.
For
example,
a
source's
close
proximity
to
a
water
body
or
an
endangered
species
habitat,
or
to
sensitive
populations
with
potentially
different
exposure
pathways,
such
as
Native
Americans,
will
likely
influence
a
permitting
authority's
decision
of
whether
an
SSRA
is
necessary.

To
estimate
SSRA
implementation
costs,
we
assume
that
all
98
of
the
facilities
in
the
universe
that
have
not
yet
completed
an
SSRA
will
do
so
in
the
future.
Assuming
average
facility­
level
SSRA
costs
of
$
157,000­$
220,000
for
facilities
operating
under
normal
conditions
and
$
815,000
for
facilities
operating
under
unusual
conditions,
the
completion
of
98
SSRAs
would
cost
between
$
18.6
million
and
$
24.6
million,
annualized
to
roughly
$
4.5­$
6.0
million
per
year
over
five
years,
assuming
a
seven
percent
discount
rate.
18
In
addition,
some
facilities
may
be
required
to
implement
permit
requirements
more
stringent
than
those
required
under
the
replacement
standards.
However,
a
screening­
level
comparison
by
EPA
regional
staff
suggests
that
the
Agency
Preferred
Approach
for
the
HWC
MACT
replacement
standards
is
generally
as
stringent
as
requirements
under
SSRAs.
This,
in
turn,
may
indicate
that
the
HWC
MACT
replacement
standards
might
reduce
the
need
to
conduct
SSRAs
in
the
future.

It
is
important
to
note
that
the
SSRA
cost
estimates
presented
here
are
not
included
in
the
cost
estimates
presented
in
Chapter
5.
In
addition,
to
the
extent
that
the
replacement
standards
reduce
the
number
of
facilities
requiring
an
SSRA,
the
estimates
presented
above
may
overestimate
total
SSRA
costs.

GOVERNMENT
COSTS
In
addition
to
the
private
sector,
the
HWC
MACT
replacement
standards
will
also
affect
EPA
and
other
government
entities.
As
government
agencies
administer
and
enforce
the
replacement
standards,
they
will
incur
costs
associated
with
permitting,
inspections,
and
other
activities.
This
section
reviews
government
costs
associated
with
the
replacement
standards'
permitting
and
reporting
requirements.
New
government
costs
under
the
replacement
standards
will
include
only
those
costs
associated
with
the
regulation
of
boilers
and
HCl
production
furnaces,
as
incinerators,
cement
kilns,
and
LWAKs
are
already
regulated
under
the
2002
Interim
Standards.
IEc
DRAFT:
May
2005
19
Sources:
U.
S.
EPA,
Supporting
Statement
for
EPA
Information
Collection
Request
#
1773.10
"
New
and
Amended
Reporting
and
Recordkeeping
Requirements
for
National
Emissions
Standards
for
Hazardous
Air
Pollutants
from
Hazardous
Waste
Combustors,"
October
2003.

4­
20
The
government
costs
resulting
from
the
HWC
MACT
replacement
standards
are
mainly
associated
with
the
review
of
permits
and
other
combustion
facility
documents
required
by
provisions
of
RCRA
and
the
CAA.
Facility
documents
that
require
agency
review
include
the
following:
performance
test
plans,
emergency
safety
valve
(
ESV)
and
automatic
waste
feed
cutoff
(
AWFCO)
violation
reports,
and
notices
of
intent
to
comply
(
NIC)
with
the
standards.
Exhibit
4­
7
presents
the
total
annual
government
costs
for
reviewing
these
documents.
19
These
figures
represent
annual
costs
expended
over
the
first
three
years
following
rule
promulgation.
Overall,
government
costs
are
projected
to
be
approximately
$
503,244
per
year.
EPA
as
well
as
state
and
local
agencies
that
hold
relevant
permitting
responsibilities
will
incur
these
costs.
The
distribution
of
costs
across
different
government
entities
depends
largely
on
the
way
in
which
different
agencies
share
responsibility
for
permitting.

Exhibit
4­
7
SUMMARY
OF
HWC
MACT
REPLACEMENT
STANDARDS'
INCREMENTAL
COSTS
TO
GOVERNMENTa
(
2002
dollars)

HWC
MACT
Component
Annual
Cost
per
Respondent/
Activity
Annual
Estimated
Number
of
Systems
Estimated
Total
Annual
Costsb
Review
of
Compliance
with
Standards
and
General
Requirements
(
e.
g.,
review
of
operator
training
and
certification
programs)
$
507
126
$
63,882
Review
of
Performance
Testing
Requirements
$
1,161
126
$
146,286
Review
of
Monitoring
Requirements
(
e.
g.,
review
of
feedstream
analysis
plans)
$
734
126
$
92,484
Review
of
Notification,
General
Reporting
and
Record
Keeping
Requirements
(
e.
g.,
review
of
Notice
of
Intent
to
Comply
(
NIC)
$
1,592
126
$
200,595
ESTIMATED
TOTAL
ANNUAL
INCREMENTAL
IMPACT
=
$
503,244
Notes:
a.
No
government
costs
are
associated
with
facilities
regulated
by
the
2002
Interim
Standards.
Government
costs
are
only
associated
with
boilers
and
industrial
furnaces.
Estimates
reflect
only
the
first
three
years
following
the
promulgation
of
the
MACT
replacement
standards,
the
time
period
covered
by
the
Information
Collection
Requests
(
ICRs),
and
are
based
on
a
universe
of
approximately
172
HWC
potential
respondents
or
facilities.
b.
Totals
may
not
add
due
to
rounding.
Source:
Estimates
from
U.
S.
EPA,
Supporting
Statement
for
EPA
Information
Collection
Request
#
1773.10
"
New
and
Amended
Reporting
and
Recordkeeping
Requirements
for
National
Emissions
Standards
for
Hazardous
Air
Pollutants
from
Hazardous
Waste
Combustors,"
October
2003.
IEc
DRAFT:
May
2005
4­
21
IEc
DRAFT:
May
2005
4­
22
SUMMARY
To
comply
with
the
HWC
MACT
replacement
standards,
individual
combustion
systems
will
incur
costs
associated
with
new
pollution
control
measures,
performance
testing,
permitting,
and
other
requirements.
We
estimated
these
costs
with
an
engineering
model
that
identified
the
least­
cost
compliance
strategy
for
each
combustion
system
and
estimated
system­
specific
costs
based
on
the
unit
costs
of
technologies
included
in
each
system's
compliance
strategy.
The
major
findings
of
our
analysis
of
these
and
other
costs
include
the
following:


Average
per
system
costs
associated
with
the
HWC
MACT
replacement
standards
are
highest
for
liquid
boilers
across
all
four
regulatory
options
considered
in
this
chapter.
Per
system
costs
are
lowest
for
LWAKs.
Under
the
Agency
Preferred
approach,
per
system
costs
for
these
systems
are
approximately
$
3,300,
compared
to
$
274,200
for
liquid
boilers.


Feed
control
is
expected
to
be
the
most
widely
used
emissions
control
measure
for
complying
with
the
replacement
standards.


Changes
in
record
keeping
and
reporting
activities
associated
with
new
compliance
requirements
and
permit
modifications
result
in
total
costs
of
about
$
7.4
million
across
all
combustion
facilities
per
year.
The
majority
of
these
costs
are
associated
with
boilers
and
industrial
furnaces;
incinerators
and
commercial
kilns
generally
perform
these
activities
to
comply
with
the
2002
Interim
Standards.


Government
administrative
costs,
borne
primarily
by
EPA
offices
and
state
environmental
agencies,
total
approximately
$
503,000
per
year.

These
cost
estimates
form
the
basis
for
assessing
the
social
costs
and
other
economic
impacts
of
the
rule
in
Chapter
5.
